# Commonwealth of Pennsylvania



# S TATE 

# I MPLEMENTATION 

# P LAN 

# R EVISION 

# :

A TTAINMENT 

# D EMONSTRATION AND 

# B ASE



# Y EAR 

# I NVENTORY



# P ENNSYLVANIA 

# P ORTION OF THE



# P HILADELPHIA



# - W ILMINGTON 

# , PA

- NJ

- DE

F INE 

# P ARTICULATE 

# N ONATTAINMENT 

# A REA



# A PRIL 

# 2010

Bureau of Air Quality Pennsylvania Department of Environmental Protection

P.O. Box 8468 Harrisburg, PA 17105

- 8468

717

- 787

- 9495

www.depweb.state.pa.us

John Hanger Secretary Edward G. Rendell

Governorblank for two

- sided copyingTable of Contents

Executive Su mmary

................................ ................................ ................................ ............. i

I. INTRODUCTION AND OVERVIEW

................................ ................................ .......... 1 A. Health and Environmental Effects of Fine Particulate Matter ( PM 2.5 )

.............. 1

B. Sources of PM 2.5 and Implications for Reduction

................................ ................. 1 C. Purpose and Structure of this Document

................................ ............................... 4 D. Public Participation

................................ ................................ ................................ . 5

II. NATURE OF THE PROBLE M IN THE PHILADELPHI A AREA

............................ 6 A. Background

................................ ................................ ................................ .............. 6 B. Air Quality Monitoring Trends Analysis

................................ .............................. 7 1. Design Value Trend

................................ ................................ ............................... 7

2. NO 2 Monitoring Trend

................................ ................................ ........................... 9

3. SO 2 Monitoring Trend

................................ ................................ ......................... 10 C. Seasonal Variability

................................ ................................ .............................. 10 1. FRM Monitoring Trends

................................ ................................ ...................... 10 2. Speciation Monitoring Trends

................................ ................................ ............. 11

III. EMISSION INVENTORIES

................................ ................................ ..................... 12 A. Summary of 2002 Emissions

................................ ................................ ................ 12 B. Summary of Inventory Methodologies

................................ ................................ 13 C. Proje cted Inventories

................................ ................................ ............................ 16 1. Summary of 2009 Estimated Emissions

................................ .............................. 16 2. Growth Projection Methodologies

................................ ................................ ....... 16 D. Reasonable Further Progress (RFP) Requirements

................................ .......... 20

E. Motor Vehicle Emission Budgets for Transportation Conformity

................... 20

IV. CONTROL STRATEGIES

................................ ................................ ....................... 23

A. Permanent and Enforceable Control Measures

................................ ................. 23 1. Stationary Poin t Sources

................................ ................................ ...................... 23 2. Highway Vehicle Sources

................................ ................................ .................... 26

3. Nonroad Sources

................................ ................................ ................................ .. 29 B. Reasonably Available Control Measures/Reasonably Available Control Technology Analysis

................................ ................................ ................................ ... 29

C. Other Measures

- VOC Control Measures

................................ ......................... 31

V. ATTAINMENT DEMON STRATION AND WEIGHT OF EVIDENCE (WOE)

..... 33 A. Attainment Demonstration Background and Objectives

................................ .. 33 B. Philadelphia Area Conceptual Model Description

................................ ............. 34 C. Modeling Domain and Photochemical Modeling System

................................ .. 36

D. Model Pe rformance Evaluation

................................ ................................ ........... 38 1. Daily PM 2.5 Mass

................................ ................................ ................................ . 38

2. PM 2.5 Speciation

................................ ................................ ................................ ... 40 E. Projected 2009 Design Values for the Philadelphia Nonattainment Area

....... 42

1. Overview

................................ ................................ ................................ ............... 42

2. Modeled Attainment Test

................................ ................................ .................... 42 3. Determine Baseline Design Values

................................ ................................ ..... 43 4. Relative Response Factor Calculations

................................ ................................ 45

5. Annual SMAT Results

................................ ................................ ......................... 46

6. 24

- Hour SMAT Results

................................ ................................ ....................... 48

F. Unmonitored Area Analysis

................................ ................................ ............... 49G. Local Area Analysis

................................ ................................ .............................. 50

H. Weight of Evidence and Other Documentation Supporting Attainment

........ 53

I. Conclusions

................................ ................................ ................................ ............. 56

VI. CONTINGENCY MEASURES FOR THE ATTAINMENT DEMONSTRATION 57 A. Contingency Measure Requir ement

................................ ................................ .... 57 B. Identified Contingency Measures

................................ ................................ ........ 58

ACRONYMS AND ABBREVIATIONS

................................ ................................ ......... 63

Table of Tables

Table E

- 1: Summary of the Five

- County Philadelphia Area Direct PM and Precursor Emissions (Tons per Year)

................................ ................................ .... iii

Table II

- 1: Phila delphia Area PM 2.5 Annual Average and Design Values (μg/m 3 )

... 7

Table III

- 1: 2002 Annual Emissions (Tons per Year)

................................ ................ 13

Table III

- 2 : 2009 Projected Emissions (Tons per Year)

................................ ............. 16

Table III

- 3: Five

- County Philadelphia Area VMT and Emissions

.......................... 18

Table III

- 4 Com parison of 2009 On

- Road Mobile Precursor Emissions to the Total Projected 2009 Inventory

................................ ................................ ....................... 21

Table III

- 5: Motor Vehicle Emission Budgets

................................ ............................. 22

Table IV

- 1: Summary of Emission Reductions 2002

- 2009 from Control Measures 23

Table V

- 1: Annual PM 2.5 Quarterly RRF Values

................................ ........................ 47

Table V

- 2: Annual SMAT Results for the Philadelphia Area 2009 On The Books/On The Way Control Measures

................................ ................................ ................... 47

Table V

- 3: 24

- hour PM 2.5 Quarterly RRF Values

................................ ....................... 48

Table V

- 4: 24

- hour SMAT Results for the Philadelphia Area 2009 On The Books/On The Way Control Measures

................................ ................................ . 49

Table V

- 5: Summary of Large PM 2.5 Sources near the Chester Monitor

.................. 51

Table V

- 6: Summary of PM 2.5 Weight of Evidence Guidelines (EPA Guidance)

..... 53

Table VI

- 1: Changes in Desig n Value and Emissions Expected by 2009

.................. 57

Table VI

- 2: Calculation of Required and Excess Emissions Reductions

................. 58

Table VI

- 3: C alculation of Required Contingency Plan Reductions

........................ 58

Table of Figures

Figure E

- 1: Map of the Philadelphia

- Wilmington, PA

- NJ

- DE Nonattainment Area ii Figure 1: PM 2.5 Annual Average and Design Value Trends

................................ ......... 8 Figure 2: NO 2 Monitoring Trend

................................ ................................ ................... 9 Figure 3: SO 2 Monitoring Trend

................................ ................................ .................. 10 Figure 4: Pennsylvania’s PM 2.5 Nonattainment Areas

................................ ............... 34 Figure 5: Phila delphia Area Percentage of Total Mass

................................ .............. 36 Figure 6. OTC Modeling Study Domain

................................ ................................ ...... 37 Figure 7: Mean Fractional Error

................................ ................................ ................. 39 Figure 8: Mean Fractional Bias

................................ ................................ .................... 40 Figure 9: Time Series of SO 4 Mass

................................ ................................ ............... 41

Fi gure 10. Wind Rose: Philadelphia Int’l Airport Location (2004

- 2008)

................. 52 Figure 11: Philadelphia Area PM 2.5 Trends

................................ ................................ 55APPENDICES

APPENDIX A: A IR Q UALITY M O NITORING I NFORMATION

A

- 1 United States Environmental Protection Agency Air Quality System Quick L ook: Pennsylvania (1999

- 2008)

A

- 2 United States Environmental Protection Agency Air Quality System: Quarterly PM 2.5 Data (1999

- 2008)

APPENDIX B: S TATIO NARY P OINT S OURCES

B

- 1 Methodology

– Preparation of Pennsylvania Point Source Inventories and Instructions for Completing the Annual Emissions Reporting Forms

B

- 2 Facility Annual Emissions

B

- 3 Banked Emissions Reduction Credits

APPENDIX C: STA TIONARY AREA SOURCES

C

- 1 Pennsylvania 2002 Area Source Criteria Air Pollutant Emission Estimation Methods (EH Pechan, Feb. 2004)

C

- 2 Area Source Annual Emissions

APPENDIX D : EMISSIONS PROJECTIONS

D

- 1 Development of Emission Projections for 200 9, 2012, and 2018 for NonEGU Point,

Area and Nonroad Sources in the MANE

- VU Region (MACTEC, Feb. 2007)

D

- 2 Documentation of 2018 Emissions from Electric Generating Units in the Eastern United States for MANE

- VU’s Regional Haze Modeling (Alpine Geophysics , April 2008)

D

- 3 Future Year Electricity Generating Sector Emission Inventory Development Using the Integrated Planning Model (IPM®) in Support of Fine Particulate Mass and Visibility Modeling in the VISTAS and Midwest RPO Regions (ICF, April 2005)

APPE NDIX E : H IGHWAY V EHICLE S OURCES I NVENTORY I NFORMATION

E

- 1 Mobile Source Highway Emissions Inventory

– An Explanation of Methodology

E

- 2 Highway Emissions Estimates

E

- 3 MOBILE6.2 Input Parameter Summary

E

- 4 MOBILE6.2 Sample Input File

E

- 5 Traffic Growth Forecasting System Report

APPENDIX F: N ONROAD S OURCES

F

- 1 Emissions Estimation Methodology

F

- 2 Nonroad Source Emissions

F

- 3 Philadelphia International Airport Inventory and Methodology

F

- 4 Capacity Enhancement Program Construction Period A ir Emissions Inventory

APPENDIX G : R EASONABLY A VAILABLE C ONTROL M EASURES

G

- 1 Identification and Evaluation of Candidate Control Measures, Final Technical Support Document ( MACTEC, Feb. 2007)

G

- 2 OTC Initial List of Measures ( Appendix B of Candidate Con trol Measures TSD)

G

- 3 Assessment of Reasonable Progress for Regional Haze in MANE

- VU Class I Areas ( MACTEC, July 2007)

APPENDIX H : M ODELING D EMONSTRATION

H

- 1 CMAQ Model Performance and Assessment for Base Year 2002 PM 2 .5 Mass and Speciation (NY DEC, De c. 2007)

H

- 2 M eteorological Modeling of 2002 U sing Penn State/NCAR 5th Generation Mesoscale Model (MM5) (NY DEC, Mar. 2006)

H

- 3 Processing of 2002 Anthropogenic Emissions: OTC Regional and Urban 12km Base

Year Simulation (NY DEC, Mar. 2007)

H

- 4 PM 2.5 M odeling U sing the SMOKE/CMAQ System O ver the Ozone Transport Region (OTR) (NY DEC, Feb. 2006)

H

- 5 Processing of 2002 Biogenic Emissions for OTC / MANE

- VU Regional and Urban Modeling (NY DEC, Sep. 2006)

H

- 6 Final Air

- Quality Modeling Protocol for the Annu al PM 2.5 NAAQS: Philadelphia

Wilmington, PA

- NJ

- DE Annual PM 2.5 Nonattainment Area (PA DEP, Oct. 2007)

H

- 7 Sample Calculation of Projected 2009 PM 2.5 Annual and 24

- hour Concentrations- i

-

E xecutive Summary

Particulate matter is a mixture of microscopic sol ids and liquid droplets suspended in air

that includ e : acids (such as nitrates and sulfates), organic chemicals, metals, soil or dust particles and allergens (such as fragments of pollen or mold spores). Fine particle pollution or PM 2.5 describes particul ate matter that is less than or equal to 2.5 micro meter (μm) in diameter, approximately 1/30th the diameter of a human hair.

Health studies have shown a significant association between exposure to fine particles and premature death from heart or lung disease. Fine particles can aggravate heart and lung diseas es and have been linked t o effects such as cardiovascular symptoms

, cardiac arrhythmias

, heart attacks

, respiratory symptoms , asthma attacks, and bronchitis. These effects can result in increased hospital admissions, emergency room visits, absences from

s chool or work, and restricted activity days. Individuals that may be particularly sensitive to fine particle exposure include people with heart or lung disease, older adults, and

children.

The U nited States Environmental Protection Agency (EPA) issued fin e particle (PM 2.5 ) national ambient air quality standards (NAAQS) in 1997 after evaluating hundreds of health studies and conducting an extensive peer review process. The EPA established an

annual primary (health

- based) and secondary (welfare

- based) standa rd of 15.0 micrograms per cubic meter (μg/m 3 ), based on the 3

- year average of annual mean PM 2.5 concentrations. The EPA also established a primary and secondary 24

- hour standard of 65 μg/m 3 determined by the 3

- year average of the 98th percentile of 24

- hou r concentrations.

On December 17, 2004

, the EPA issued air quality designations for the PM 2.5 standard based on air quality monitoring data from 2001

- 2003. The final designations were published in the Federal Register on January 5, 2005 (70 FR 944). T he designations became effective on April 5, 2005. On April 5, 2005, the EPA issued a supplemental notice changing the designation of certain areas from nonattainment to attainment based on newly available air quality data (70 FR 19844; published in the F ederal Register on April 14, 2005). The EPA designated eight areas in Pennsylvania as PM 2.5 nonattainment

areas , comprising all or part s of 21 Pennsylvania counties

.

The Philadelphia

- Wilmington , PA

- NJ

- DE Nonattainment Area (Philadelphia Area) is compri sed of 9 counties in Pennsylvania, New Jersey and Delaware. The Philadelphia Area is required to attain the PM 2.5 NAAQS no later than five years from the effective date of designation, or April 5, 2010. Bucks, Chester, Delaware, Montgomery and Philadelph ia counties (five

- county Philadelphia area) in Pennsylvania are included in the Philadelphia Area. Figure E

- 1 displays a map of the Philadelphia Area.- ii

- Figure E

- 1: Map of the Philadelphia

- Wilmington, PA

- NJ

- DE

Nonattainment Area

This State Impleme ntation P lan ( SIP ) revision contains information on PM 2.5 trends and

emissions and demonstrates that the five

- county P hiladelphia a rea meets all requirements necessary for an approvable SIP revision. This SIP revision also establishes motor vehicle budget s for purposes of transportation conformity. Once the EPA approves the budgets for purposes of conformity, the five

- county Philadelphia area’s designated Metropolitan Planning Organization (MPO), the Delaware Regional Planning

Commission must use these bu dgets in its air quality analyses for transportation planning

purposes.

PM 2.5 c an be emitted directly or formed secondarily in the atmosphere by chemical reactions of gases in the atmosphere. Potential precursors of secondary PM 2.5 include

sulfur dioxide ( SO 2 ), nitrogen oxides (NOx), volatile organic compounds (VOC), and ammonia ( NH 3 ).

E missions of the PM 2.5 precursors SO 2 and NOx are projected to decrease from 2002 to

2009 in the five

- county P hiladelphia a rea
, w hile emissions of direct PM 2.5 are proje cted

to increase over the same time period. Because sulfates and nitrates are formed from atmospheric reactions of SO 2 and NOx, the reduction of emissions of SO 2 and NOx is- iii

-

expected to result in attainment of the PM 2.5 air quality standard in the Philadel phia Area. Based on speciated data from the Chester monitor, sulfates and nitrates account for 46%

of the PM 2.5 mass in the P hiladelphia Area. The emission projections tak e into account both growth in economic activity that increases emissions and contro l measures implemented to reduce emissions.

Table E

- 1: Summary of the Five

- C ounty Philadelphia Area Direct PM and

Precursor Emissions (Tons per Year)

Pollutant 2002 2009

PM 2.5 14727 15219

PM 10 61758 66035

SO 2 40459 28200

NOx 120248 91651

VOC 1229 73 101 834

NH 3 7705 9239

The permanent and enforceable control measures that enable the Pennsylvania portion of

the P hiladelphia Area to demonstrate attainment of the PM 2.5 NAAQS include:

The Clean Air Interstate Rule (CAIR) and the NOx “SIP Call” redu cing interstate pollution transport ; State regulation of smaller sources of NOx , cement kilns and large stationary internal combustion engines ; The Pennsylvania and federal new motor vehicle emission control programs for passenger and light

- duty trucks ;
T he Pennsylvania and federal heavy

- duty diesel emission control programs ; Federal fuel programs for highway vehicles and nonroad mobile equipment ; and Federal regulation of offroad diesel and gasoline

- powered vehicles and equipment

.

In addition, Pennsylva nia’s Diesel

- Powered Motor Vehicle Idling Act of 2008 will assist

the Pennsylvania portion of the Philadelphia Area in attaining and maintaining air quality.

Pennsylvania and other member states of the Ozone Transport Commission (OTC) and

Mid

- Atlantic/Nort heast Visibility Union ( MANE

- VU ) worked together to analyze potential control measures. The Pennsylvania Department of Environmental Protection (Department)

, based on this process that includ ed stakeholders and the other

OTC/MANE

- VU states, concluded that there are no additional reasonable cost

- effective measures that would advance the ability of the area to attain the standard by one year or

more.- iv

-

T he OTC ’s modeling platform , t he Community Multi

- scale Air Quality (CMAQ) photochemical grid model (version 4.5)

, was used to estimate projected 2009 PM 2.5 concentrations within the Philadelphia A rea . CMAQ is a n Eulerian grid model capable of simulating air pollutant concentrations in the atmosphere using mathematical equations to characterize chemical and phy sical properties.

A review of the base case (2002) run indicated the CMAQ model did a reasonable job reproducing actual concentrations. Based on this analysis

, it is reasonable to assume the

model can estimate the projected PM 2.5 concentrations within the P hiladelphia A rea for

2009

. The year 2009 will be the last complete year of annual emissions and ambient monitoring data that the EPA will use to determine whether the P hiladelphia Area attains the standard by April 2010.

Projected PM 2.5 concentrations f rom CMAQ indicate the Philadelphia Area will attain the

annual and 24

- hour PM 2.5 standard s in 2009. Additional evidence supporting this

conclusion include s recent lower concentrations at monitors within the P hiladelphia Area

and the possib ility that the m odel under

- predicts the air quality benefits of emission

reductions

.

A number of potential emission control measures were developed during the OTC/

MANE

- VU/ Mid

- Atlantic Regional Air Management Association ( MARAMA ) collaborative strategy development proces s

. These measures are outlined in the technical support document titled: Development of Emission Projections for 2009, 2012, and 2018 for NonEGU Point, Area, and Nonroad Sources in the MANE

- VU Region

, developed by

MARAMA

. This document, which can be fou nd in Appendix D

- 1, provides details on the specific factors, control assumptions, and implementation schedules used in the emission projection calcula t ions for each source category.

This SIP revision contains a contingency plan for the five

- county Philad elphia area that provides assurance that should the P hiladelphia Area fail to meet a milestone, fail to attain the NAAQS by the attainment date or violate the standard during the maintenance period

, the area can be brought back into attainment as expeditio usly as practicable

.1 I. INTRODUCTION AND OVERVIEW

A. Health and Environmental Effects of Fine Particulate Matter ( PM 2.5 )

Particulate matter (PM) includes both solid and liquid particles suspended in the air. PM is chemically and physically diverse an d originates from a variety of human and natural activities. PM is composed of particles in a wide range of sizes. Particles less than 10

micrometers in diameter (PM 10 ) pose a health concern because they can be inhaled into and accumulate in the respirat ory system. Particles less than 2.5 micrometers in diameter (PM 2.5 ) are referred to as fine particles and generally pose the largest health risks. Because of their small size, fine particles can penetrate deeply into the lungs.

Many scientific studies h ave linked exposure to elevated levels of PM 2.5 to premature death, aggravated respiratory disease

, including asthma and chronic bronchitis, cardiovascular disease, changes in lung function and increased respiratory problems

, such as coughing and painful b reathing

, as well as increased susceptibi lity to respiratory

infections. Individuals particularly sensitive to PM 2.5 exposure include older adults, people with heart and lung disease and children.

The recent article, “Fine

- Particulate Air Pollution and L ife Expectancy in the United States” by C. Arden Pope, III, et al., was published in the New England Journal of Medicine on January 22, 2009. The authors of the article were able to demonstrate that

decreased PM 2.5 concentrations contributed to a signific ant improvement in life expectancy. The study used statistical analyses to evaluate the role the PM 2.5 reductions

that occurred in the 1980s and 1990s had on the increased life expectancy observed over that period. The study found that a reduction of 10 micrograms per cubic meter (μg/m 3 ) of

PM 2.5 was associated with an average increase in life expectancy of 7.3 months.

PM 2.5 has significant environmental impacts

, including acid rain and stream eutrophication. PM 2.5 also affects visibility (regional ha ze) through the scattering and absorption of light. Fine particles, similar in size to the wavelength of light, are most efficient, per unit of mass, at reducing visibility. Soiling and materials damage can also be caused by PM 2.5 in the air.

B. Sour ces of PM 2.5 and Implications for Reduction

Fine particle pollution can be emitted directly or formed secondarily in the atmosphere.

PM 2.5 emitted directly into the air in a stable solid or liquid chemical form (including PM 2.5 that is formed near its so urce by condensation) is referred to as “primary” PM 2.5 . PM 2.5 formed by chemical reactions of gases in the atmosphere is considered to be “secondary”

PM 2.5 . The chemical composition of PM 2.5 in an area depends on the mix of emissions, location, time of year, and weather. The chemical composition of PM 2.5 can include sulfate, nitrate, ammonium, particle

- bound water, black (elemental) carbon, a great variety of organic compounds, and miscellaneous inorganic material

, such as dust and metals.2

Primary PM 2. 5 includes soot from diesel engines, condensed organic material from incomplete combustion and compounds from condensation during combustion or smelting.

The atmospheric chemistry of PM 2.5 formation is complex. Formation of secondary PM 2.5 depends on n umerous factors

, including the relative concentration of precursors, atmospheric conditions and the interactions of precursors with each other and with other particles, clouds or fog. The contribution of different precursors will vary by location.

The principal forms of secondary PM 2.5 include:

Sulfates, formed from emissions of sulfur dioxide (SO 2 ) from power plants

and industrial facilities ; Nitrates, formed from emissions of nitrogen oxides (NO

x ) from power plants, vehicles, and other combustion sou rces ;
Ammonium (NH 3 ) , formed primarily from emissions of ammonia from animal operations ; and Secondary organic aerosol

, formed from emissions of v olatile organic

c ompounds ( VOCs ) from incomplete combustion and evaporation from a wide diversity of sources.

To protect public health and the environment, the United States Environmental Protection Agency (EPA) is required by the Clean Air Act (CAA) to set and periodically revise National Ambient Air Quality Standard s (NAAQS) for six criteria pollutants. Parti culate matter is one of the criteria pollutants

. The EPA sets NAAQS based on its review of existing scientific knowledge about the adverse health and welfare effects of the pollutant.

After the EPA sets or revises a NAAQS, s tates have the responsibility for devising strategies to attain and maintain the standard. Previous particulate matter standards were

set for PM and PM 10

. I n 1997, after evaluating hundreds of health studies and conducting an extensive peer review process, the EPA promulgated NAAQS b ased on the level of particles smaller than 2.5 micrometers ( PM 2.5 ) . In setting the 1997 standard s for PM 2.5 , the EPA recognized that the smaller particles were most directly associated with adverse

health effects.

The EPA set the annual health

- based s tandard for PM 2.5 at 15 .0 μg/m 3 . This is determined by the 3

- year average of annual mean PM 2.5 concentrations. The EPA set the 24

- hour

standard at a level of 65 (μg/m 3 ) , as determined by the 3

- year average of the 98th percentile of 24

- hour concentrations

. The EPA set l evels to protect the environment at the

same level as it set the health

- based standards. T he EPA revised the 24

- hour standard in

2006 to be more protective . However , this document addresses attainment of the 1997

PM 2.5 NAAQS

. Measures in cluded in this document , or measures as protective, will continue to be in place to assist with attaining the more protective standard in the future.

The Philadelphia

- Wilmington, PA

- NJ

- DE Nonattainment Area (Philadelphia Area) is comprised of nine countie s in Pennsylvania, New Jersey and Delaware. The Philadelphia Area is required to attain the PM 2.5 NAAQS no later than five years from the effective date of designation, or by April 5, 2010. Bucks, Chester, Delaware, Montgomery and3

Philadelphia counties ( five

- county Philadelphia area) in Pennsylvania are included in the Philadelphia Area.

The Philadelphia Area was designated as nonattainment because it violated the 1997

annual standard of 15.0 μg/m 3 b ased on 2001

- 03 monitoring data . The Philadelphia Area

did not violate the 1997 24

- hour standard of 65 μg/m 3

.

Because of the complexity and variability of the process of particulate matter formation,

the EPA recognizes that effective control measu res for PM 2.5 will vary among nonattainment areas

. In the EPA’s Clean Air Fine Particle Implementation Rule ( 7 2 FR

20586 , April 25, 2007 ) (the implementation rule)

, the EPA establishe d general presumptive policies for assessing which PM 2.5 precursors shou ld be evaluate d for possible

controls. The EPA requires states to evaluate control measures for SO 2 and primary PM 2.5 in all locations. The EPA requires states to evaluate control measures for NO

x unless a technical demonstration is made to show NO

x does not significantly contribute to PM 2.5

. The EPA requires states to evaluate measures for VOC and NH 3 only if a technical demonstration is made to show they significantly contribute to PM 2.5 in that area. While

this State Implementation Plan ( SIP ) revisio n provides emissions information for all pollutants ( PM 10 , PM 2.5 , SO 2 , NOx, VOC and NH 3 )

, as required, it does not provide

technical demonstrations pertaining to the level of contribution by NOx, VOC, or NH 3 to

PM 2.5 concentrations . Therefore, the C ommonw ealth will consider SO 2 and N Ox as PM 2.5 precursors for purposes of this attainment plan and reasonable further progress. 1 The EPA has indicated that virtually all nonattainment problems appear to result from a combination of local emissions and transport ed emissions from upwind areas. 2

The CAA requires that an area’s attainment date be the date by which attainment can be achieved as expeditiously as practicable

, but no later than five years from the effective date of designation, or no later than April 5, 2010. If appropriate, the EPA could extend the attainment date up to but no l ater than 10 years after the date of designation. States are required to propose and justify an attainment date in their attainment plan. This SIP

revision sets an April 201 0 attainment date for the Philadelphia Area

. The analysis is based on modeling of projected emissions for 2009 because 2009 will be the last complete year of annual emissions and ambient monitoring data that the EPA will use to determine if

the Philadelph ia Area attain s the standard by April 2010.

The EPA Administrator is authorized under Section 179(a) of the CAA to impose sanctions after making a finding or determination relating to a SIP revision, or after disapproving a SIP revision, in whole or in par t. Mandatory sanctions would be imposed for (1) a state’s failure to submit a plan or plan element, or to make a submission that satisfies the minimum criteria of section 110(k) of the CAA in relation to any element of the plan; (2) the EPA’s disapproval of a plan in whole or in part; (3) the EPA’s determination that a state has failed to make a required submission, including a required submission satisfying the minimum criteria of section 110(k); or (4) a state’s failure to

1 The EPA’s definition of PM 2.5 attainment plan precursor can be found in 40 CFR Part 51, Subpart Z,

section 51.1000.

2 Clean Air Fine Particle Implementation Rule, 72 FR 20587.4

implement any requirement of an approved plan. If the state fails to correct any SIP deficiency within 18 months from the Administrator's finding, determination or disapproval, mandatory sanctions would be imposed. There are two mandatory sanctions

for non complying states: (1) limitatio ns on certain federal highway funding; and (2) "offset" limitations on certain developments in affected areas that require each new stationary emission source to be paired with a reduction in area emissions amounting to

double the amount of increased emiss ions from the new source.

In addition, failure to submit a plan, failure to implement a plan, or the EPA

disapproval of a plan can also affect the ability of transportation planning agencies

to meet transportation conformity requirements, and thus the ab ility to implement

transportation projects. The EPA may also impose discretionary sanctions under

Section 110 of the CAA. On November 20, 2009, the EPA made a finding that the

Commonwealth failed to submit a plan with the required elements for the

Philade lphia Area . The EPA published a Federal Register notice to that effect on

November 27, 2009. The Department anticipates submitting the SIP revision in

spring 2010 to provide EPA with ample time for approval before the sanction

deadlines.

C. Purpose a nd Structure o f t his Document

In December 2004

, after consultation with states and receipt of public input, the EPA designated eight areas in Pennsylvania comprised of all or part s of 21 Pennsylvania

counties as PM 2.5 nonattainment areas based on air qualit y monitoring data from 2001

- 2003. Under Section 110 of the CAA

, states are required to develop a revision s to the SIP

to demonstrate how the area will attain the standard by April 2010, meet emission reduction requirements in the CAA and ensure that in th e event of a future violation or failure to meet emission reduction milestones, the area is brought back to atta inment as quickly as possible.

This SIP revision is organized as follows:

Section I provides general information about PM 2.5 pollution

, includ ing information about the health and environmental impacts of PM 2.5 and sources of PM 2.5 and its precursors. Section I also provides an overview of the health

- based PM 2.5 standard and Pennsylvania’s responsibility to develop strategies to attain air quali ty standards.

Section II provides information characterizing the PM 2.5 problem in the Philadelphia Area

, examines current monitoring information

, and analyzes trends.5

Section III describes emission inventories for PM 2.5 and its precursors, SO 2 and NOx

. Base year and projected emission inventories are also included as required for PM 10 , VOC

and NH 3

. Section III describes how this SIP revision meets the requirement for “reasonable further progress” under Section 172 of the CAA 3

. Section III also contains the highway vehicle emission budgets for purposes of transportation conformity. Technical

information on methodologies and inputs for point, area, highway and nonroad actual and projected emission inventories is contained in the Appendices B through F, r elating to : (1) stationary point sources; (2) stationary area sources; (3) emissions projections; (4) highway vehicle sources inventory information; and (5) nonroad sources.

Section IV describes the control measures implemented in the Pennsylvania port ion of the Philadelphia Area that produce emission reductions between 2002 and 2009 in order to

attai n the NAAQS in a timely fashion and how Pennsylvania meets the requirement for identifying Reasonably Available Control Measures (RACM) that could advance the attainment of the standard by one year or more. Appendix G, relating to Reasonably Available Control Measures, includes s pecific information and recommendations developed by the Ozone Transport Commission ( OTC ) and the Mid

- Atlantic/Northeast

Visibilit y Union ( MANE

- VU ) states for additional controls to aid in reaching attainment

.

Section V discusses the modeling that was done to evaluate attainment by April 2010 and the “weight of evidence” analysis. Together, these comprise the attainment demonstrat ion. Based on modeling, statistical analyses and other evidence, the attainment demonstration

indicates the P hiladelphia Area will attain the 1997 PM 2.5 standards by April 2010. Appendix H includes detailed technical information on the Community Multi

- sc ale Air Quality ( CMAQ ) model performance, meteorological data, modeling emission inventories and modeling analysis used to project 2009 annual and 24

- hour PM 2.5 design values

.

Section VI is the contingency plan, meeting the requirement that the Commonweal th be able to address unanticipated failures to meet emission or air quality requirements in a timely fashion.

D. Public P articipation

Requirements for a public comment process are set forth in Section 110(a ) ( 2) of the CAA

, 40 CFR Section 51.102(d) a nd 35 P.S. Section 4007.5 On February 6, 2010 , the Pennsylvania Department of Environmental Protection (DEP or Department) published a notice of public hearing and commenced a 30

- day written comment period on the proposed

attainment demonstration and bas e year inventory for the Pennsylvania portion of the Philadelphia Area. 40 Pa.B. 756

. The Department held a public hearing in Norristown on th e SIP revision on March 11 , 2010

. Th e public comment period closed on March 12

, 2010

. No one attended the publ ic hearing, and no comments were received during the public comment period. Proof of public notice is included in the SIP submittal.

3 Clean Air Fine Particle Implementation Rule, 72 FR 20633

.6

II. NATURE OF THE PROBLE M IN THE PHILADELPHIA AREA

A. Background

The Philadelphia

- Wilmington, PA

- NJ

- DE Nonattainm ent Area (Philadelphia Area) is comprised of nine counties in Pennsylvania, New Jersey and Delaware. Bucks, Chester, Delaware, Montgomery and Philadelphia counties (five

- county Philadelphia area) in Pennsylvania are included in the Philadelphia Area. Oth er PM 2.5 nonattainment areas near

the P hiladelphia Area include the York, Lancaster, Reading, and Harrisburg

- Lebanon

Carlisle nonattainment areas in Pennsylvania, the Baltimore nonattainment area in Maryland and the New York

- N. New Jersey

- Long Island intra state nonattainment area. Topographically, the Philadelphia Nonattainment Area is bounded on the east by higher

t errain. However, much of the area is situated in the Atlantic Coastal Plain Province, as designated by the Pennsylvania Department of Conserv ation of Natural Resources. This area has the lowest elevations (much closer to sea level) within the Commonwealth. Therefore, there is little impact of terrain that influences the air quality of many of the

other areas across the Commonwealth.

Severa l types of PM 2.5 monitors operate within the five

- county P hiladelphia a rea

. These

include eight f

ederal r eference m ethod (FRM) moni tor s. F our of these sites are operated by the Department, including B ristol, Chester, New Garden and Norristown

. The

addit ion al four monitors, which include Broad Street, Elmwood, the Philadelphia Air Management Service (AMS) Lab and Northeast Airport , are operated by the Philadelphia

AMS

. In addition to the FRM s
, four speciation monitor s (at Chester, New Garden, the

Philade lphia AMS Lab and Elmwood ) and f our continuous monitors (at Chester, Norristown, the Philadelphia AMS Lab and Northeast Airport ) are maintained within the region . FRM data has been collected since 1999 on a one in three day frequency (1/3) at
most of the monitors, except at Elmwood and the Philadelphia AMS Lab (which takes samples every day (1/1)) . Speciated monitoring on a one in six day frequency (1/6) has occurred since April of 2002

, while at least one continuous monitor has operated since

October 200 3

.7

B . Air Quality Monitoring Trends Analysis

A short summary of monitoring trends in the P hiladelphia Area is provided as follows:

1. Design Value Trend

A monitor’s annual design value is determined by first calculating its quarterly a verage. Quarterly averages are then averaged to calculate the monitor’s average annual PM 2.5 concentration. Three consecutive years of average annual PM 2.5 concentrations are then averaged to determine a monitor’s annual PM 2.5 design value. Table II

- 1 d isplays PM 2.5 annual averages for each monitor and the maximum design value for the Philadelphia

Area.

T able II

- 1: Philadelphia Area PM 2.5 Annual Average and Design Value s ( μ g/m 3 )

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 

## Pennsylvania

Bristol 12.00 13.64 14.47 14.15 14.42 13.04 14.34 12.15 13.02 12.66

Chester 13.12 15.99 15.86 14.73 15.29 15.02 16.51 13.99 14.45 13.84

New Garden 14.61 15.57 14.25 15.87 12.59 14.07 13.68

Norristown 13.02 13.47 14.88 13.60 13.86 12.00 12.48 12 .05 13.09 11.66

AMS Lab 14.64 14.93 16.47 14.38 14.80 13.89 14.21 13.48 13.74 13.01

Broad Street 15.53 17.14 16.98 15.57 16.13 14.39 15.06 15.52 14.37 1 3 .50

Elmwood 14.54 14.81 16.69 13.97 14.03 12.73 14.23 13.14 13.33 NE Airport 12.95 14. 66 14.62 13.66 13.19 12.78 12.93 12.40 12.85 11.99



## Delaware

Bellefonte 14.26 15.39 15.58 13.97 14.81 13.90 14.30 12.32 13.43 13.76

Lums Pond 13.55 14.20 14.54 13.00 13.26 13.21 13.77 11.43 12.45 12.17

MLK 16.01 16.72 17.50 15.21 1 5.26 14.92 14.90 14.54 14.09 14.19

Newark 15.42 15.24 15.79 14.56 14.80 14.54 14.42 12.70 13.38 13.03 

## New Jersey

Camden 13.65 15.02 14.52 14.00 16.25 13.30 14.47 12.17 13.64 12.29

Gibbstown 13.24 15.14 14.53 13.02 13.76 12.38 14.2 5 9.00 13.30

Pennsauken 14.05 15.48 14.23 14.62 13.92 13.16 14.27 12.36 13.87 12.70 

## Max Design

Value 16.74 16.56 16.23 15.36 15.61 15.17 14.98 1 4.46

Source: Data extracted from the US EPA Ai r Quality System AMP 450 Report. See Appendix A

- 1 for the AMP 450 Report data for Pennsylvania monitors.

Note: Monitoring results for 2009 have not yet been quality assured; EPA requires certification by June 2010.8

Figure 1 displays PM 2.5 annual averages for each monitor in the Pennsylvania portion of

the Ph iladelphia Area. The maximum design value shown is the maximum for the interstate Philadelphia area. The 2001 maximum design value was observed at a Delaware

monitor. The 2002

– 2008 maximum design values were observed at Pennsylvania

monitors.

Figure 1: P M 2.5 Annual Ave rage and Design Value Trends9

2. NO 2 Monitoring T rend

Figure 2 displays the Philadelphia city vs. outside Philadelphia city annual NO 2 concentration trend from 1999 to 2008. The Philadelphia city monitor is adequately represented by the monitored values at the Philadelphia AMS Lab . The outside Philadelphia city monitor is adequately represented by the Chester monitor.

Figure 2 : NO 2 Monitoring Trend10

3. SO 2 Monitoring Trend

Figure 3 displays the Philadelphia city vs. outside Philadelphia city annual S O 2 concentration trend from 1999 to 2008. The Philadelphia city monitor is adequately represented by the monitored values at the Philadelphia AMS Lab . The outside Philadelphia city monitor is adequately represented by the Chest er monitor.

Figure 3 : SO 2 Monitoring Trend

C . S easonal Variability

1. FRM Monitoring Trends

Summary of seasonal variability in FRM data: There appears to be little variability in quarterly FRM values at monitor s located in the P hiladelphia Are a

. Throughout the region, the monitors’ 3 rd quarter values (summer) tend to report the highest concentrations

and the 4 th quarter (autumn) tend to report the lowest concentrations. This seasonal variability is primarily due to the meteorological conditio ns that set up in those particular

seasons . The 3 rd quarter tends to have more stable conditions

, and the 4 th quarter tends to

have more volatile conditions.11

2. Speciation Monitoring Trends

Summary of seasonal variability in speciated data: R aw speciat ion data for the Philadelphia Area indicates some seasonal variability in the primary components. Sulfates have the largest variability with 1 st quarter concentrations approximately half

concentrations measured in the 3 rd quarter. Nitrates vary in nearly the opposite direction

with 1 st quarter measurements higher than 2 nd

, 3 rd and 4 th quarter measurements. Organic

c arbon, elemental carbon, a mmonium and crustal mass do not appear to show much seasonal variability.12

III. EMISSION INVENTORIES

Section 51 .1008 of 40 CFR Part 51 requires an inventory of pollutants to meet the requirements of section 1 72 (c )( 3) of the CAA. As specified by the EPA, the pollutants inventoried by Pennsylvania include PM 10 , PM 2.5 , SO 2 , NOx, VOC, and NH 3

. In addition, projection s of future emissions have been made for the milestone year 2009. Information

on the manmade sources of direct PM and its potential precursors, SO 2 , NOx, VOC, and

NH 3 was compiled for:

“Stationary sour ces” (or “point” sources)

, which are sources for whic h the Department collects individual emissions

- related information. Generally

, they represent major stationary sources but may be smaller.

“ A rea sources
, ” which are industrial

, commercial , and residential sources too small

or too numerous to be handled i ndividually . These include but are not limited to commercial and residential open burning, architectural and industrial maintenance coatings application and clean

- up, consumer product use, and vehicle refueling at

service stations. Where there is overlap between stationary point sources and stationary area sources, the area source values are adjusted to remove any double counting.

“Highway vehicles

, ” which include passenger cars and light

- duty trucks, other trucks, buses and motorcycles.

“Nonroad sourc es
, ” which encompass a diverse collection of engines

, including but

not limited to outdoor power equipment, recreational vehicles, farm and construction machinery, lawn and garden equipment, industrial equipment,

recreational marine vessels , commercial mar ine vessels, locomotives, ships, and

aircraft.

The inventory for the Pennsylvania portion of the Philadelphia Area was compiled for Bucks, Chester, Delaware, Montgomery and Philadelphia counties.

A. Summary of 2002 Emissions

An emission inventory is an estimate of the emissions from sources in a particular area. The Department developed an emission inventory for 2002, which is the base year for attainment planning purposes with respect to 8

- hour ozone and PM 2.5 SIPs , and for planning purposes with respe ct to the regional haze SIPs. The 2002 base year inventory

i ncludes the pollutants PM 10 , PM 2.5 , SO 2 , NOx, VOC, and NH 3 . The inventory consists of

sources in four sectors: stationary point sources, stationary area sources, highway vehicle

sources and nonro ad sources. MANE

- VU compiled a regional inventory from t he

emission inventories of the Northeastern and Mid

- Atlantic states

. This regional inventory was used to perform the regional modeling analysis used in Pennsylvania’s air quality13

management planning efforts to attain the 8

- hour ozone NAAQS and the PM 2.5 NAAQS

, and to prepare the regional haze plan.

An emissions inventory for the base year, 2002, was developed in accordance with EPA guidance 4

. Table III

- 1 summarizes the emissions for 2002.

Table III

- 1: 2002 Annual Emissions ( Tons per Year )

Philadelphia Area 2002 PM 2.5 PM 10 SO 2 NOx VOC NH 3 Stationary Point Sources 2139 3430 23745 22124 8183 256

Area Sources 10020 55224 13153 13029 59227 4821

Highway Vehicle Sources 1033 1492 1920 63476 33974 2614

Non

- Road Sources 1535 1611 1640 21619 21589 14

Totals 14727 61758 40459 120248 122973 7705

B. Summary of Inventory Methodologies

Inventory development methodology is summarized below.

Stationary Point Sources. The Department requires owners a nd operators of larger facilities to submit annual production figures and emission calculations each year. Throughput data are multiplied by emission factors from Factor Information Retrieval (FIRE) Data System and the EPA’s publication series AP

- 42 and ar e based on Source

Classification Code s (SCC). Each process has at least one SCC assigned to it. If the owners and operators of facilities provide more accurate emission data based upon other factors, these more accurate emission estimates supersede those calculated using SCC

codes. Appendix B

- 1 includes information on stationary point source emission methodology

, and Appendix B

- 2 is the data set for facility 2002 annual emissions. Appendix B

- 3 is a table document ing the banked emissions reduction credits for the five

county Philadelphia a rea in the 2009 emission projection

.

Area Sources

. Area source emissions are generally estimated by multiplying an emission factor by some known indicator or collective activity for each area source category at the

co unty level. Pennsylvania estimates emissions from area sources using emission factors and SCC codes in a method similar to that used for Stationary Point Sources. Emission factors may also be derived from research and guidance documents if those document s are more accurate than FIRE and AP

- 42 factors. Throughput estimates are derived from

county

- level activity data, by apportioning national or statewide activity data to counties, from census numbers, and from county employee numbers. County employee num bers are based upon North American Industry Classification System (NAICS) codes to establish

4 Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations

– EPA

- 454/R

- 05

- 001. August, 2005. Updated November, 2005.14

that those numbers are specific to the industry covered. More specific information on the procedure used for each industry type is contained in Pennsylvania 2002 Area Source Criteria Air Pollutant Emission Estimation Methods, (E.H. Pechan & Associates, Inc., February 2004) which is contained in Appendix C

- 1

. Appendix C

- 2 is a table containing stationary area source s emissions data for the five

- county Philadelphia area

.

Highway Vehicle Sources. The Department employs an emissions estimation methodology that uses the current EPA

- approved highway vehicle emission model, MOBILE 6.2, to estimate highway vehicle emissions. In addition, Pennsylvania uses a MOBILE pre

- and post

- processing software package called PPSUITE to process and compile Pennsylvania’s robust highway network and detailed highway vehicle data. The Pennsylvania Department of Transportation ( PennDOT ) provided estimates of vehicle miles traveled (VMT) by vehicle type and roadway type. The Pennsylvania methodology is consistent with the January 2002 guidance published by the EPA’s Office of Transportation and Air Quality (OTAQ) entitled

, Technical Guidance on the Use of MOBILE6 for Emissions Inventory Preparation

.

More information on highway emission methodology is available in Appendix E. Appendix E

- 1 provides the 2002 base year and 2009 projections of mobile (highway)

VMT and annual PM 2.5 direct and precursor emissions. The document summarize s the methodology and data inputs used to produce the mobile emissions inventory. Appendix

E

- 2 is the t able of 2009 five

- county Philadelphia area Annual Highway Emissions listed b y SCC . Appendix E

- 3 describes the inputs to MOBILE6.2 used to generate emission factors for a specific area. Some examples of the inputs described in Appendix E

- 3 are the type and frequency of vehicle emission testing, the fuel types required in the area, temperatures by month

, and fleet age. The summary in Appendix E

- 3 indicates wh en default information contained in the model is used rather than specific area information. Finally, Appendix E

- 4 is an electronic file that pro vides all of the input coding for a sample segment and scenario used in Pennsylvania’s MOBILE6.2 modeling syst em

.

Nonroad Sources. The 2002 emissions for the majority of nonroad emission source categories and pollutants were estimated using the EPA NONROAD 2005 model. The NONROAD model estimates emissions for diesel, gasoline, liquefied petroleum gasoline,

and compressed natural gas

- fueled nonroad equipment types and includes growth factors. The National Mobile Inventory Model (NMIM) was used to estimate emissions of

ammonia from sources contained in the NONROAD model. The NONROAD model does

not estimate emis sions from aircraft

, locomotives or commercial marine vessels

. Emissions from aircraft, locomotives, and commercial marine vessels were estimated using EPA guidance and best available information. If specific local operational data was available, that da ta was used to estimate emissions. State and national data was used if

local data was unavailable.

The Department has worked with the staff of the Philadelphia Division of Aviation to obtain accurate operational information for emission sources at Phil adelphia International Airport (PHL). The Division of Aviation operates PHL as well as the Northeast Philadelphia Airport. The 2002 PHL Inventory described in Appendix F

- 3 includes15

aircraft and aircraft

- related equipment from the EPA

- approved model, Emis sions and Dispersion Modeling System (EDMS), and also additional on

- airport highway, stationary and area source emissions. In some cases, emissions occurring at PHL are accounted for only in the regional inventory; these emissions are identified as such i n the Appendix.

For 2002 aircraft emissions from the Northeast Philadelphia Airport, the Department estimated emissions using operations data obtained from the Federal Aviation

Administration’s (FAA) Terminal Area forecast and modeling the emissions di rectly with

the EDMS.

Emissions produced by aircraft at small airports in the Philadelphia area were estimat ed by using airport operation statistics, which can be found a t www.airnav.com and the FAA’s Terminal Area Forecast Detailed Report. An emission s factor for a typical general aviation single engine, multi

- engine, and jet engine aircraft were derived by averaging the

emissions factors from a basket of emission factors for common aircraft of each of the three types of aircraft. Emission factors and operational characteristics contained in EDMS were used. The proportion of operations among the three groups of aircraft was determined by examining the number of each aircraft type based at each airport. For military operations at small airports, the t ype of aircraft and its emission factors are sometimes identifiable. If not, emission factors calculated to represent an “average” military aircraft are used. Growth was estimated using estim ates of future operations at

P hiladelphia airports found in the FAA Terminal Area Forecast Detailed Report.

For 2002 locomotive emissions, the Department projected emissions from a 1999 survey when the Department obtained fuel use statistics from class II and III railroads. For class I railroads, which produce most of the locomotive emissions in the Commonwealth , the Department conducted a 2002 inventory because the 1999 fuel use data for class I railroads

was skewed by gridlock caused by the acquisition of Conrail by CSX and Norfolk Southern. Emissions were ge nerated using EPA emission factors. Emissions were grown using national railroad fuel use trends supplied by the Association of American Railroads

.

The Philadelphia Area contains the Port of Philadelphia. The port is home to several

refineries where la rge oil tankers often call and shipping terminals

. All air emissions from

commercial marine vessel (CMV) traffic in the Port of P hiladelphia were estimated using the methodology outlined in the EPA’s publication C ommercial Marine Activity for Deep

Sea Por ts in the United States , Final Report . A comprehensive understanding of the methodology can be achieved by reviewing this document. Additional understanding of the port’s operations was obtained from conversations with tug boat operators in the port

and s hip traffic data provided by the Philadelphia Regional Port Authority

. E mission

estimates were based on port activity data provided by the United States Army Corps of Engineers Waterborne Commerce Statistics Center and best available EPA nonroad

emissions factors. Fuel use and emissions factors for CMV were based on the most current

data available.

Appendix F

- 1 is the technical document providing the methodology and description of the procedures used to generate 2002 and 2009 county

- level pollutant emission estimates for16

nonroad mobile engines included in the EPA’s NONROAD2005 m odel, locomotive engines

, and aircraft operations. The t able of the specific emission s data used to calculate the nonroad emissions sorted by source category is available as Appendix F

- 2.

C. Projected Inventories

1. Summary of 2009 Estimated Emissions

Table III

- 2 summarizes the emissions expected in 2009. These emissions take activity and emissions growth and/or controls from 2002 into account. Appendix D, relating to

e missions projections, contains the technical support documents that describe the methodologies used to project the 2002 baseline emissions to 2009.

Table III

- 2: 2009 Projected Emissions ( Tons per Year )

Philadelphia Area 2009 PM 2.5 PM 10 SO 2 NOx VOC NH 3 Stationary Point Sources 2817 3849 12658 22252 7881 357

Area Sources 10324 59533 13972 13775 55868 5749

Highway Vehicle Sources 699 1193 327 36318 20298 3118

Non

- Road Sources 1356 1428 800 18874 15971 16

PHL Capacity Enhancement Program 0 0 0 0 254 0

Emission Reduction

Credits Banked 23 32 442 432 1561 0

Totals 15219 66035 28200 91651 101834 9239

Sulfur and n itrogen are major contributors to the P hiladelphia Area ’s PM 2.5 nonattainment problem. Therefore, even though the direct PM 2.5 emissions inc rease in 2009, the

reductions of PM 2.5 precursors, SO 2 and NOx

, will ensure that the P hiladelphia Area attains

the PM 2.5 NAAQS by 2010

.

2. Growth Projection Methodologies

This section describes the data, methods, and assumptions utilized in developing e stimates of emissions changes between 2002 and the milestone year 2009. Appendix

D

- 1 contains the technical support document en titled

, Development of Emission Projections for 2009, 2012, and 2018 for Non

- EGU Point, Area, and Nonroad Sources in

the MANE

- V U Region

, developed by Mid

- Atlantic Regional Air Management Association ( MARAMA ). The document provides details on the specific factors, control assumptions, and implementation schedules used in the emission projection calculations for each source

categor y.17

Stationary Point Sources. For electric generating units (EGUs), t he Department used the

EPA’s Integrated Planning Model ( IPM ) modeling as adjusted by the Visibility Improvement State and Tribal Association of the Southeast (VISTAS), specifically

VIS TAS 2.1.9, to predict the results of the EPA’s CAIR at affected facilities throughout the CAIR region. The emissions for 2009 resulting from application of the CAIR cap and trade program for annual NOx and SO 2 emissions

, as predicted by IPM

, were used. T he technical support documents that describe the methodologies used to project the emissions from EGUs, Documentation of 2018 Emissions from Electric Generating Units in the Eastern United States for MANE

- VU’s Regional Haze Modeling (Alpine Geophysics, Apr il 2008) and Future Year Electricity Generating Sector Emission Inventory D evelopment Using the Integrated Planning Model (IPM®) in Support of Fine Particulate Mass and Visibility Modeling in the VISTAS and Midwest RPO Regions (ICF, April 2005) are include d as Appendices D

- 2 and D

- 3, respectively.

For non

- EGU point sources, t he methodology for projecting emissions to 2009 is the same as the methodology described below for stationary area sources as d ocumented in Appendix D

- 1

, Development of Emission Proj ections for 2009, 2012, and 2018 for Non

EGU Point, Area, and Nonroad Sources in the MANE

- VU Region

. This report was prepared for MARAMA as part of an effort to assist states in developing attainment plans

for ozone and fine particles, and in developing r egional haze plans . It describes the data sources, methods, and results for emission forecasts for three years, three emission sectors,

two emission control scenarios

, seven pollutants, and 11 states plus the District of

Columbia. MARAMA developed projec tions for 2009

, 2012

, and 2018.

Area Sources. Area source emissions were projected from the 2002 inventory.

The factors used for the temporal allocation of projections to 2009 from the 2002 baseline inventory were provided by MARAMA, which is coordi nating air quality technical projects for the Northeast and Mid

- Atlantic states. The factors were in the form of Sparse Matrix Operator Kernel Emissions (SMOKE) v2.2 input files 5

.

A table of growth factors for 2009 was provided by MARAMA. For each stat e, county and SCC, this table includes state growth factors derived from the Energy Information Administration (EIA) Annual Energy Outlook, 2005; and/or factors extracted from the Economic Growth Analysis System (EGAS). Where more than one factor was avail able, the first choice was the EIA factor followed by the EGAS factor.

MARAMA also supplied tables of control factors, rule effectivenes s factors, and rule penetration factors for any control measures applicable to these sources.

For the area sources, t hese factors were available by SCC and pollutant. There may be more than one generic control factor that applies to a given SCC and pollutant. In cases

5 For additional information on the SMOK E file formats, please refer to the SMOKE v2.2 Users Manual, available from the Center for Environmental Modeling for Policy Development (CEMPD) at http://cf.unc.edu/cep/empd/products/smoke/index.cfm#Documentation.18

where there was more than one applicable factor, the following formula may have been applied recursivel y to generate reductions that are a composite of those factors.

Where

CF is the control factor

RE is the rule effectiveness factor RP is the rule penetration factor

As described for stationary point sources above, Appendix D in cludes the MARAMA

report, Development of Emission Projections for 2009, 2012, and 2018 for NonEGU
Point, Area, and Nonroad Sources in the MANE

- VU Region

, which documents the methodology for projecting emissions to 2009.

Highway Vehicle Sources. The EPA’s a pproved highway vehicle emission model, MOBILE 6.2, projects highway vehicle average fleet emission factors. State specific information was used where available and appropriate. Traffic forecasts were compiled using information from PennDOT ’s Traffic I nformation System and

socioeconomic data. The Pennsylvania methodology for estimating highway vehicle emissions is consistent with the January 2002 guidance published by the EPA’s Office of Transportation and Air Quality ( OTAQ ) entitled

, Technical Guidanc e on the Use of MOBILE6 for Emissions Inventory Preparation

. Appendi ces E

- 1 through E

- 5 include

s pecific information on the highway emission s inventory methodology , data files of

emissions estimates , MOBILE6.2 input parameters

, a MOBILE6.2 sample input fi le,

and the traffic growth forecasting system report

.

As shown in Table III

- 3

, VMT for the future analysis year increases 17 % from 25 .3 billion

to 2 9.6 billion VMT within the five

- county Philadelphia area

. Despite the growth in VMT,

emissions of the most significant vehicle

- related precursor s are significantly lower in the

future a nalysis year

.

Table III

- 3 : Five

- County Philadelphia Area VMT and Emissions

Direct PM PM Precursor s

YEAR VMT PM 2.5 PM 10 VOC NOx SO 2 NH 3
2002 25,315,915,277 1,033 1,492 33,974 63,476 1,920 2,614

2009 29,561,772,617 699 1,193 20,298 36,318 327 3,118

Nonroad Sources

. Projected emissions for the majority of nonroad emission source categories and pollutants were estimated using the EPA NONROAD 2005 model, which

contains default assumptions for projected years. The NMIM estimated future NH 3 emissions from source categories in the NONROAD model. The NONROAD model and

NMIM estimate emissions for diesel, gasoline, liquefied petroleum gasoline, and compressed natural gas

- fue led nonroad equipment types and include growth factors.19

The Department worked with the staff of the Philadelphia Division of Aviation to obtain accurate operational information for emission sources at Philadelphia International Airport (PHL). Emissions from commercial aircraft are estimated using the EPA

- approved Emissions & Dispersion Modeling System (EDMS). Growth was estimated using estimates

of futur e operations at PHL from the Federal Aviation Administration ’s (FAA) APO

Terminal Area Forecast Detail ed Report. The complete methodology for determining emissions produced from normal airport operations at PHL is described in Appendix F

- 3. Major construction is anticipated at PHL to relieve aircraft congestion, potentially starting

in 2010.

Emissions from small aircraft were calculated by using airport operation statistics, which

can be found at www.airnav.com and the FAA ’s APO Terminal Area Forecast Detailed Report.

For locomotive emissions, the Department proj ected emissions from 2002 to 2009, using national fuel consumption data obtained from the Association of Ame rican Railroads and

the EPA emission factors developed for the locomotive fleet in future years.

Commercial marine vessel emissions were grown usin g projected activity , fuel use and emission estimates from the EPA document, Final Regulatory Analysis: Control of Emissions from Marine Diesel Engines, November 1999.

Additional information about nonroad emission projection methodologies can also be

fo und in Appendix F. Appendix F

- 1 is the technical document providing the methodology and description of the procedures used to generate 2002 and 2009 county

- level pollutant emission estimates for nonroad mobile engines included in the EPA’s NONROAD2005

mod el, locomotive engines and aircraft operations. The t able of nonroad emissions data sorted by source category is available as Appendix F

- 2.

PHL Capacity Enhancement Program

. PHL is planning to implement the Capacity Enhancement Program (CEP). The CEP wi ll be an effort to reduce ground delays at the airport and throughout the nationwide air traffic system. T he estimated maximum annual

e missions of VOC , 254 tons, from the CEP were specifically identified and accounted for in the projected inventory in ord er to provide an emissions budget for the PHL CEP in

accordance with the General Conformity Regulation in 40 CFR §93.158(a), (relating to

criteria for determining conformity of general F ederal actions )

. The methodology for estimating emissions produced du ring the CEP is described in Appendix F

- 4.

T he purpose of general conformity is: 1) not to cause or contribute to a new violation of the NAAQS, 2) not to increase the frequency or severity of existing violations of the NAAQS, and 3) not to delay the timel y attainment of any NAAQS or any required interim

emission reductions or milestones.

PHL is one of the most congested airports in the nation. The CEP when complete will reduce aircraft delays and overall emissions at PHL . As of early 2010, the FAA

, the agency taking the federal action, was considering two alternatives which were titled20

Alternative A and Alternative B. Alternative A would produce fewer emissions than

Alternative B. Emissions from Alternative A would be produced mostly in the first 5 years of the project while maximum emissions from Alternative B would occur at about year 10 of the project or 2020. Because the Department cannot determine which al ternative will eventually be built , the maximum level of emissions produced due to aircra ft delay and

construction emissions from Alternative B are included as two line items in the 2009 inventory. In addition, the airport has implemented many mitigation projects that have reduced emissions from aircraft and ground support equipment operation s. Mostly these

emission reductions have addressed PM 2.5 and NOx. Not many emission reduction projects are possible to reduce emissions of VOC on airport property. Pennsylvania proposes to establish budge ts for CEP emissions of VOC in order to ensure th at the CEP emissions do not impede clean air goals established in the SIP. The CEP budgeted emissions of VOC will not impede the clean air goals in the SIP because the VOC emissions used to model attainment of the fine particulate standard were over 10,0 00 tons in excess of the VOC emissions that were projected in the 2009 emissions inventory.

O nce the EPA approves the SIP, including the 2009 projected emissions inventory (Table

III

- 2)

, a general conformity budget for PHL’s CEP project for VOC will be es tablished

.

D. Reasonable Further Progress (RFP) Requirements

Section 172(c ) ( 2) of the CAA requires that plans for nonattainment areas provide reasonable further progress

. In accordance with 40 CFR 51.1009

, if a state submits an

attainment demonstrati on for an area which demonstrates that the area will attain the PM 2.5 NAAQS within five years of designation, the state is not required to submit a separate RFP plan. In that case, compliance with the emission reduction measures in the attainment

demonstr ation and SIP will meet the requirements for achieving RFP for the area. This

attainment demonstration and SIP revision demonstrate that t he Philadelphia Area will

attain the PM 2.5 NAAQS by the area’s attainment date of April 2010 , which is within five

ye ars of designation . Therefore, c ompliance with the emission reduction measures described in this plan meets the requirements for achieving RFP for the area.

E. Motor Vehicle Emission Budgets f or Transportation Conformity

Section 176 of the CAA provide s a mechanism by which federally funded or approved highway and transit plans, programs, and projects are determined not to produce new air quality violations, worsen existing violations, or delay timely attainment of the NAAQS. EPA regulations issued to implement transportation conformity provide that motor vehicle emission “budgets” establish caps of these emissions that cannot be exceeded by the predicted transportation system emissions in the future. Transportation agencies in Pennsylvania are respon sible for making timely transportation conformity determinations. The responsible agency in the five

- county Philadelphia a rea is the Delaware Regional Planning Commission , the designated Metropolitan Planning Organization (MPO) under federal transportatio n planning requirements.21

Pennsylvania proposes to establish budgets for highway emissions for direct PM 2.5 and NOx in order to ensure that transportation emissions do not impede clean air goals in the next decade and beyond. The information in Table III

- 5

, once the EPA approves it for purposes of conformity, will establish transportation conformity budgets for the five

county Philadelphia area

.

Amendments to the 40 CFR p art 93 transportation conformity regulations to address the

1997 PM 2.5 standard were published in the Federal Register on May 6, 2005 ( 70 F R

24280 ) to account for PM 2.5 and its precursors. Section 93.102 requires conformity determinations to be applicable to direct emissions of PM 2.5 and NOx (unless a determination is made that transporta tion

- related emissions are not significant contributors

to PM 2.5 ), but to emissions of SO 2 , VOC, and NH 3 only if a finding is made that transportation

- related emissions of these pollutants are significant contributors to PM 2 .5

.

Motor vehicle emissions of SO 2 , VOC, and NH 3 were analyzed to determine if motor vehicle budgets should be established for these pollutants. Table III

- 4 illustrates the on

road mobile source fraction of the total 2009 inventory for each of these pollutant s

. Motor

vehicle emission s of VOC and NH 3 account for 20 % and 3 4 % of the total projected 2009 inventory for VOC and NH 3 , respectively. Motor vehicle emissions of SO 2 account for 1 % of the total projected 2009 inventory for SO 2

.

Table III

- 4 Comparison of 2009 O n

- Road Mobile Prec ursor Emissions to the Total Projected 2009 Inventory

2009 SO 2 VOC NH 3

On

- Road Mobile Source Projected Inventory (Tons) 327 20298 3118

Total Projected 2009 Inventory (Tons) 28200 101 834 9239

Percent of Total Projected 2009 Inventory (%) 1.16 19.93 33.7 5

Motor vehicle emissions budget for S O 2 , VOC, and NH 3 are needed only if the state air agency director or the EPA Regional Administrator makes a finding that motor vehicle emissions budgets must be established in order to attain the NAAQS for PM 2.5

. B ecause the reactions that form particulate matter from emissions of VOC are complex and highly variable, there is considerable uncertainty regarding the contribution of VOC to particulate

for mation. Likewise, much uncertainty remains regarding the role of NH 3 in particulate

formation. As discussed earlier in Section I, the Commonwealth is not considering VOC

or NH 3 as PM 2.5 precursors for the purpose of the attainment plan because of the uncertainty surrounding their role in particulate formation. Theref ore, this SIP revision is not establishing a motor vehicle emission budget for VOC or NH 3 . As shown in Table III

4, motor vehicle emission s of SO 2 are a small percentage of the total inventory. Based on

these facts and the fact that n o applicable finding has been made for these pollutants , this

SIP revision is only establishing motor vehicle emission budgets for direct PM 2.5 and NOx

, as shown in Table III

- 5

.22 Table III

- 5 : Motor Vehicle Emission Budgets

2009 PM 2.5 NO x Tons/year 699 36318

The Departmen t has included direct PM 2.5 re

- entrained road dust emissions from paved and unpaved roads in the area source inventory. However, a number of fugitive dust

studies have indicated that the PM 2.5 / PM 10 ratios measured by EPA FRM samplers are significantly l ower than predicted by AP

- 42 emission factors. As a result, the PM 2.5 emission estimates using AP

- 42 are biased high by as much as a factor of two, compared to FRM samplers. The Department believes that the emissions from paved and unpaved roads are signi ficantly over

- predicted and

, therefore, has not included those emissions in

the motor vehicle emission budgets at this time. Appendix C

- 2 , relating to area source annual emissions, contains estimates of the PM 2.5 emissions attributable to paved and

unpave d roads

.

Transportation construction

- related fugitive dust emissions are not a significant contributor to the air quality pro blem. At the Philadelphia Area speciation monitor, the crustal component was found to be small compared to other components of PM 2.5 (see Section V, Figure 5). Given that construction

- related fugitive dust is one of many source categories contributing to the crustal material observed at the monitor , and transportation construction

is a small subset of all construction , it is safe to conclude that transportation construction

related fugitive emissions are insignificant

.23 IV. CONTROL STRATEGIES

A. Permanent and Enforceable Control Measures

This section describes the federal and state measures that will provide the direct PM 2. 5 , SO 2 and NO

x emission reductions leading to emission reductions and attainment of the

standard.

A summary of the quantity of emission reductions expected from 2002 to 2009 is included

in Table IV

- 1. (Positive values indicate emission reductions, nega tive values indicate an increase in emissions.) The emission reduction estimates account for any anticipated growth in the activity of sources regulated by the strategy. For some pollutants and categories, emissions in 2009 are anticipated to be higher t han they were in 2002. In those

cases , projected growth in emissions is larger than anticipated emission reductions from control measures for that pollutant and source category. Each measure is explained in greater detail in the following sections.

Tabl e IV

- 1: Summary of Emission Reductions 2002

- 2009 from Control Measures

2002

- 2009 Difference PM 2.5 SO 2 NOx
Stationary Point Sources

- 678 11087

- 128

Area Sources

- 304

- 819

- 745
Highway Vehicle Sources 334 1593 27158

Nonroad Sources 179 841 2745

Total

- 469 12702 29030

Note: Positive values indicate emission reductions. Negative values indicate an increase

in emissions.

1. Stationary Point Sources

Clean Air Interstate Rule (CAIR). EPA’s CAIR (70 FR 25162, May 12, 2005) was

remanded to EPA for rev isions by the United States Court of Appeals for the District of Columbia on December 23, 2008. The Court ordered the EPA to fix the flaws in CAIR, but did not set a deadline. EPA intends to promulgate a replacement rule in 2011. In the meantime, CAIR i s being implemented. Pennsylvania transitioned from the NOx SIP Call to the federal CAIR in 2009. The CAIR is to provide the incentive for large electric generation units (EGUs) to reduce emissions below 2002 levels throughout the 28

- state CAIR region. Pennsylvania and other nearby states were required to adopt a regulation implementing the requirements of the CAIR or an equivalent program. On April 28, 2006, the EPA promulgated Federal Implementation Plans (FIPs) to reduce the interstate transport of N Ox and SO 2 that contribute significantly to nonattainment and interfere with

maintenance of the 8

- hour ozone and PM 2.5 NAAQS. The EGUs in Pennsylvania w ere regulated under the FIP until the EPA approve d a SIP revision for the implementation of24

CAIR for th e affected EGUs, at which point the approved CAIR SIP revision supersede d the FIP requirements in Pennsylvania. The Pennsylvania CAIR regulation was published in

the Pennsylvania Bulletin on April 12, 2008. (38 Pa.B. 1705) On May 23, 2008, the Departmen t submitted to the EPA a SIP revision for the Department’s CAIR regulatory requirements under §§ 145.201

- 145.223 (relating to CAIR NOx and SO 2 trading programs), effective April 12, 2008 (38 Pa.B . 1705), that provide for a CAIR NOx Ozone Season Trading Pro gram and a CAIR NOx Annual Trading Program. The EPA approved the Department’s CAIR regulation as a SIP revision effective December 10, 2009 (74 FR 65446).

Interstate Pollution Transport Reduction

-- In response to the f ederal NOx SIP call rule, Pennsylva nia and other covered states adopted NOx control regulations for large industrial boilers and internal combustion engines, EGUs , and cement plants. The regulation covering industrial boilers and electric generators required emission reductions to

commence May 1, 2003, while the regulation covering large internal combustion engines and cement plants required emission reductions to commence May 1, 2005. The EPA approved th ese regulation s , found in 25 Pa. Code Chapter 145, on August 21, 2001 (66 F R

43 795) an d September 29, 2006 ( 71 F R 57428).

Small Sources of NOx, Cement Kilns, and Large Stationary Internal Combustion Engines. The Department established additional ozone season requirements for small sources of NOx in the counties of Bucks, Chester, Delaware , Montgomery, and Philadelphia in regulations that were adopted December 11, 2004

. The rules (25 Pa. Code Chapter 129) apply to owners and operators of certain boilers, turbines, and stationary internal combustion units located in Bucks, Chester, Delaware , Montgomery, and Philadelphia Counties. The emission limits are differentiated by fuel type and allow alternative compliance mechanisms. By November 1 st of each year, owners and operators

of these sources must surrender NOx allowances if actual emission s exceed allowable

emissions. The amendments required the NOx emission limits to be implemented by May 1, 2005. EPA approved this program on September 29, 2006 ( 71 FR 57428).

New Source Review Program s

. The federal N ew S o urce R eview (NSR) program s a re preconstruction review and permitting program s applicable to new or modified major stationary sources subject to Title I, Parts C and D of the federal CAA. The program s consist of the P revention of S ignificant D eterioration (PSD) requirements, which ar e applicable in areas attaining the NAAQS

, and the Nonattainment NSR requirements

, which are applicable in geographic areas not attaining and maintaining the NAAQS.

The Department’s PSD regulations

, codified in 25 Pa.Code Chapter 127, Subchapter D,

were approved by the EPA on August 21, 1984 and codified at 40 CFR § 52.2058 (49 F R 33128) . The federal PSD regulations codif i ed in 40 CFR Part 52 are incorporated by reference in their entirety in 25 Pa. Code § 127.83 (relating to adoption by reference). Th e PSD program requires any new source to implement Best Available Control Technology (BACT) and limits a new source's allowable impact on the environment.25

The EPA granted “ limited ” approval of the Department’s revised NSR regulations codified

in 25 Pa.Co de Chapter 127, Subchapter E, and published a final rule on December 7, 1997 ( 62 F R 64722 ). On October 19, 2001

, the EPA converted the limited approval to a “ full ” approval for all areas of the Commonwealth except the five

- county Philadelphia area (Bucks, Chester, Delaware, Montgomery, and Philadelphia counties) ( 66 F R 53904 )

. N onattainment NSR requ irements include compliance with the lowest achievable emission

rate and emission offsets.

These federally enforceable programs, inco r porated in the Commonwealth’s SIP,

will also reduce emissions to provide continued improvements.

Federal Standards for Hazardous Air Pollutants. Federal standards to control hazardous air pollutants (HAPs) require Maximum Achievable Control Technology (MACT) at units located at major source s of HAPs. The EPA has issued a series of regulations that are applicable to sourc es in Pennsylvania. These MACT standards are adopted and incorporated by reference in Section 6.6 of Pennsylvania’s Air Pollution Control Act and implementing regulations and are also included in federally enforceable permits issued by the Department for affected sources. Controls w ith a 2002 compliance

date and earlier are included in the base year inventory for 2002, while controls with a compliance date of 2003 and later are included in the projection inventories. A list of the categories for which fe deral MACT standards have been issued is contained in Appendix

D

- 1

.

Source Surveillance. Pursuant to 40 CFR Part 51, Subpart K ( relating to s ource

s urveillance )

, the SIP revision is required to provide for monitoring of the status of compliance with any rules and regulations that set forth any portion of the control strategy. These include provisions, as applicable, for:

emissions reports and recordkeeping for stationary sources; periodic testing and inspection of stationary sources;

enforcement and com plaint investigation of visible emission limitations;
enforceable test methods for emission limits; and continuous emission monitoring for stationary sources.

Subpart K also requires monitoring of the implementation of transportation control measures (TCM s). T here are no TCMs in this SIP.

After review, the Department finds that the rules and regulations for stationary sources

, which are part of the control strategy for attaining the PM 2.5 standard

, as well as the Department’s comprehensive permitting pr ogram requirements in 25 Pa. Code Chapter

127 and the Commonwealth’s SIP in 40 CFR 52.2020

, meet the requirements of Subpart

K.26

2. Highway Vehicle Sources

Even with increases in VMT that occur from 2002 through 2009

, highway vehicle

emissions will c ontinue to decrease . As more vehicles subject to cleaner new car standards replace older vehicles subject to less stringent new vehicle standards, the fleet as a whole emits fewer emissions, compensating for the incr ease in vehicle miles traveled. These

decreases can be attributed to the programs described below.

Federal Motor Vehicle Control Programs (FMVCP) and Pennsylvania Clean Vehicle Program for passenger vehicles and light

- duty trucks and cleaner gasoline.

Tier 1 tailpipe standards established by the CAA Amendments of 1990 include NOx and VOC limits for light

- duty gasoline vehicles (LDGVs) and light

- duty gasoline trucks (LDGTs). These standards began to be phased in 1994. Evaporative VOC emissions were reduced in gasoline

- powered cars starting with M odel Y ear (MY) 1998.

In 1998, under the authority of section 177 of the CAA, the Department adopted the Pennsylvania Clean Vehicles Program (28 Pa. B. 5873, Dec. 5, 1998)

. The Pennsylvania Clean Vehicles Program incorporates by reference certain Ca lifornia Low Emission

Vehicle (CA LEV) emission standards for passenger cars and light

- duty trucks. As required under Section 177 of the CAA, these provisions are identical to the low emission standards adopted by California

. T he regulation does not inco rporate by reference the California zero emissions vehicle (ZEV) or emissions control warranty systems statement provisions.

In the same rulemaking, the Department adopted the National Low Emission Vehicle (NLEV) program as a compliance alternative to the Pennsylvania Clean Vehicles Program. The NLEV program became effective in the Ozone Transport Region (OTR) in 1999. Pennsylvania’s New Motor Vehicle Emissions Control Program regulations in 25 Pa.

Code Sections 126.401

- 126.441 allowed automobile manufact urers to comply with NLEV instead of the CA LEV program through MY 2005. These regulations affected vehicles 6,000 pounds and less and were the regulations in effect for new motor vehicles in the baseline year, 2002.

In 1999, the EPA promulgated regulat ions more stringent than NLEV (Tier 2), starting with MY 2004. In order to participate in NLEV, Pennsylvania had been required to adopt language that extended its “commitment” to NLEV until MY 2006. In practical terms, the NLEV program was replaced for M Y 2004 and later by the more stringent Federal “Tier 2” vehicle emissions regulations, 65 F R 6698 (Feb. 10, 2000), and vehicle manufacturers operating under the NLEV program became subject to the Tier 2 requirements.

Pennsylvania amended the former New M otor Vehicle Control Program (which included the Pennsylvania Clean Vehicles Program) in 2006. The Clean Vehicles Program continues to incorporate the California Low Emission Vehicle Program (CA LEV II) by reference. As amended, the program affects MY 20 08 and newer passenger cars and light

duty trucks vehicles. 36 Pa

. B . 7424 (Dec

. 9, 2006).27

Emissions for milestone years were estimated based on compliance with the Pennsylvania Clean Vehicles Program according to the methodology described in section 7. 4.1 of the Technical Guidance on the Use of MOBILE6.2 for Emissions Inventory Preparation published by the EPA’s OTAQ in January 2002. This methodology is further explained in Appendix E. The Department is assuming in its MOBILE modeling that the federal Tier 2 program applies to subject vehicles sold in Pennsylvania from MY 2004 through MY 2007 and the Pennsylvania Clean Vehicles Program applies to subject vehicles sold in MY 2008 and beyond.

Reformulated Gasoline. Gasoline sold in the Philadelphia Area is required by the CAA to

be the cleaner

- burning reformulated gasoline meeting standards established in Section 211 of the CAA. This federally

- enforced program has been in place since January 1995.

Heavy

- Duty Diesel Control Programs. The EPA promulg ated more stringent national regulations for heavy

- duty engines and vehicles (over 14,000 pounds) starting with MY 2004. In addition, consent decrees with seven of the largest heavy

- duty engine manufacturers required, among other terms, that diesel engine s made by these companies comply with these 2004 standards two model years early, in MY 2002. Pennsylvania includes these programs as provided in the MOBILE model.

In 2002, the Department adopted the Heavy

- Duty Diesel Emissions Control Program for

model years starting after May 2004. The program incorporates California standards by reference and requires MY 2005 and subsequent new heavy

- duty diesel highway engines to be those certified by California. California standards we re more stringent than federa l standards for the two model years between expiration of the consent decrees discussed above and the implementation of more stringent federal standards affecting MY 2007 and beyond. However, EPA ’s MOBILE model already assumes that the engines would compl y with consent decree standards, even without an enforcement mechanism. The Department has used MOBILE defaults to calculate emissions from MY 2005 and 2006 highway engines.

The EPA adopted new emission standards for heavy

- duty engines and vehicles for M Y 2007 and subsequent. For diesel engines, the standards will be phased in from 2007 to

2010 for NOx and VOCs. For gasoline engines, the standards will be phased in during

MY 2008 and 2009. Federal and California standards are virtually identical for MY 2007.

For MY 2008, California adopted requirements for idling restriction engine programming and an option al “clean NOx idle” standard. However, there is no EPA

- approved methodology to estimate emission reductions from this requirement. Therefore, the

e mission estimates use assumptions of the federal rule for MY 2007 through 2010

.

Because the new engine standards are adversely affected by sulfur in fuel, the EPA also requires most highway diesel fuel to contain no more than 15 parts per million (ppm) of

sulfur , beginning in the fall of 2006. There is a temporary compliance option allowing refiners to continue to produce up to 20 percent of their highway diesel fuel at 500 ppm28

fuel until 2010. The Department u ses MOBILE defaults to estimate the effects of the phase

- in provision.

Vehicle Emission Inspection/Maintenance Program. The five

- county Philadelphia area has had a vehicle emissions inspection program since 1984. In early 2004, Pennsylvania

revised the implementation of its Vehicle Emission Inspe ction/Maintenance (I/M) Program

in the five

- county Philadelphia a rea. The program applies to gasoline

- powered vehicles 9,000 pounds and under, MY 1975 and newer. For vehicles MY 1996 and newer, the program consists of an annual on

- board diagnostics test and a gas cap pressure test. For subject vehicles MY 1995 and older, the program consists of an annual tailpipe test, visual inspection of pollution control devices to ensure they are present, connected and the proper type for the vehicle and a gas cap pr essure test. For vehicles older than 25 years, the program is a visual inspection and gas cap test. These regulations can be found in 67 Pa.

Code Chapter 177. Pennsylvania submitted the revised emissions program as a SIP revision on December 1, 2003. Th e EPA approved the SIP revision on October 6, 2005. (70 FR 58313)

.

Low sulfur gasoline. Simultaneously with the Tier 2 program, the EPA published a regulation requiring the reduction of sulfur in gasoline beginning in 2004, with full implementation in 200 6. Sulfur levels are capped at 80 ppm per gallon and annual refinery averages must be no more than 30 ppm. Th e emission reduction analysis uses the default assumptions provided in MOBILE6 to account for the implementation of the federal sulfur

standard r ule.

Diesel Vehicle Idling Restrictions. On October 9, 2008, Governor Rendell signed the

Diesel

- Powered Commercial Motor Vehicle Idling Act (Act 124 of 2008). Act 124 of

2008 went into effect on February 6, 2009. This Act restricts subject drivers a nd owners statewide from idling a diesel

- powered motor vehicle engaged in commerce with a gross vehicle weight of 10,001 pounds or more for more than five minutes in any continuous 60

- minute period. Also, no owner or operator of a location where the afore mentioned vehicles load, unload or park may allow the vehicles to idle for more than 5 minutes in a 60

- minute continuous period. Act 124 of 2008 specifically excludes some vehicles

, such as motor homes and farm vehicles used in farm applications. Additio nal exemptions are allowed for certain vehicles being used in specific applications. Truck drivers may idle sleeper

- berth equipped vehicles for the purposes of long duration travel rest if the temperature is extremely hot or cold. In May 2010, this tempe rature exemption expires. A properly

labeled “low

- NOx idle” engine may idle for an unlimited amount of time.

Act 124 of 2008 will be enforced by Department personnel, and by state and local law enforcement personnel. The law preempts and supersedes loc al ordinances

, although rules in Allegheny County and Philadelphia County that are determined by those counties to be more stringent than the law may remain in effect. The Department estimates that 50 percent of all long duration idling for Class 8 trucks will be eliminated in 2010 when the temperature exemption for vehicles with sleeper berths expires. Statewide emission reductions are estimated to be 1610 tons, 45 tons and 30 tons per year for NOx, VOC, and

PM 2.5 , respectively. Emission reductions expe cted from this strategy are not included in29

the projected emissions inventory for 2009 for two reasons: 1) the first year was a period of education to the regulated community; and 2) most of the emission reductions from the

law are expected to come from l ong

- term travel rest idling associated with sleeper berth equipped vehicles.

3 . Nonroad Sources

The EPA has adopted a series of regulations affecting new diesel

- powered (“compression ignition”) and gasoline

- powered (“spark ignition”) nonroad engines of various sizes (horsepower) and applications. Information on these federal rules, including their implementation dates, can be found at www.epa.gov/nonroad. The Department used the assumptions built into the nonroad model (NONROAD2005) to estimate emissio ns for all milestone years.

No new national or international regulations are expected to be applicable to aircraft by the

attainment date. While the EPA has published a notice of proposed rulemaking for more stringent standards for locomotives and large commercial marine diesel engines, the agency has not finalized any new standards.

The EPA will also require diesel fuel used in most nonroad applications to contain less sulfur. The sulfur will prevent damage to the more advanced emission control systems needed to meet the engine standards; it will also reduce fine particulate emissions from diesel engines. In 2007, fuel sulfur levels were limited to 500 ppm for nonroad applications other than ocean

- going marine vessels. In 2010, fuel sulfur levels will be reduced to the same sulfur concentration as in highway fuel, 15 ppm; this requirement applies in 2012 to locomotive and marine diesel fuel.

B. Reasonably Available Control Measures/R easona bl y Available Control Technology Analysis

Section 172(c) of the CAA requires states to “provide for implementation of all reasonably available control measures (RACM) as expeditiously as practicable.” T he regulatory requirement for RACM and reasonably available control technology (RACT) for PM 2.5 SIP

revisions is codified in 40 CFR 51.1010 : “For each PM 2.5 nonattainment area, the s tate shall submit with the attainment demonstration a SIP revision demonstrating that it has adopted all reasonably available control measures (including RACT for stationary sources)

nec essary to demonstrate attainment as expeditiously as practicable and to meet any RFP requirements.”

The EPA states in the Clean Air Fine Particle Im plementation R ule preamble that it encourages states to conduct multi

- pollutant analyses for PM 2.5 and ozon e to cull out potential RACM:

“They can also try to use consistent meteorological fields and emissions inventories so that the same control strategies are relatively easy to evaluate for both ozone and PM 2.5

.30

Modeling the same future year(s) for PM 2.5 and ozone can also make it easier to evaluate the impacts of controls on both pollutants. It should be noted that there are no specific modeling requirements other than the recommendation to try to harmonize the ozone,

PM 2.5 , and regional haze analyses w henever possible.” 6

The Commonwealth participated in two such collaborative process es with other states in the region. First, the OTC states formed a workgroup to identify and evaluate candidate

control measures. Working from a preliminary list of appro ximately 1

, 000 potential control measures, t he workgroup identified and analyzed 30 candidate control measures. Appendi x G

- 1 contain s the OTC report entitled, Identification and Evaluation of Candidate Control Measures, Final Technical Support Document (M ACTEC, Feb. 2007).

The initial list of control measures considered is available as Appendix G

- 2. Based on the OTC Workgroup analysis, the Commissioners recommended that States consider emission

reductions from the following source categories:

• Consumer Products

• Portable Fuel Containers

• Adhesives and Sealants Application

• Diesel Engine Chip Reflash

• Cutback and Emulsified Asphalt Paving

• Asphalt Production Plants

• Cement Kilns

• Glass Furnaces

• Industrial, Commercial, and Institutional (ICI) Boi lers

• Regional Fuels

• Electric Generating Units (EGUs)

The final report, included as Appendix G

- 1

, contains more detailed information about the process and includes tables summarizing the emission reduction potential of each control measure by source ca tegory and projection year. There are five subsections discussing the control measure and emission reductions for the five source category sectors: non

- EGU point sources, area sources, EGUs, onroad mobile sources, and nonroad mobile sources.

The Departme nt also participated in an assessment of control measures for pollutants and sources affecting visibility through the MANE

- VU regional haze planning process. As part of this effort, MANE

- VU developed a list of possible control measures for

consideration. The following categories were selected for analysis:

Coal and oil

- fired EGUs
Point and area source industrial, commercial and institutional boilers

Cement kilns

Lime kilns The use of heating oil Residential wood combustion and open burning

6

. 72 FR 20609.31

Appendix G

- 3 c ontains the final report entitled, Assessment of Reasonable Progress for Regional Haze in MANE

- VU Class I Areas (MACTEC, July 2007) from the MANE

- VU control measure assessment project. This report presents the results of an analysis of the

economic and en vironmental impacts of the potential control scenarios that c ould be implemented by MANE

- VU s tates to reduce emissions from selected source categories in order to make reasonable progress toward meeting visibility improvement goals.

As required under 40 CFR 51.1010

, a SIP revision for a PM 2.5 nonattainment area must
demonstrate that all RACM, including RACT for stationary sources, necessary to demonstrate attainment as expeditiously as practicable have been adopted. The cumulative impact of implementing available measures must be considered in determining whether a particular emission reduction measure or set of measures is required to be adopted as RACM. Potential measures that are reasonably available considering technical and economic feasibility must be adopted as RACM if, considered collectively, they would

advance the attainment date by one year or more. As discuss ed earlier in this document,

the P hiladelphia Area expects to monitor attainment at the end of 2009. Therefore, any

RACM measures would need to be in effect in 2008.

The Department determined that there were no additional control measures that could be adopted by January 1, 2008. In addition , existing measures and th ose planned for implementation by 2009 are expected to enable the P hila delphia Area to attain the 1997

PM 2.5 NAAQS. Therefore, no further actions on RACM or RACT are warranted.

Although the measures explored by the OTC and MANE

- VU workgroups are not required as RACM, many are worthwhile measures that Pennsylvania is current ly pursuing. Others are measures that Pennsylvania may consider for the future.

C. Other Measures

- VOC Control Measures

Although VOC is not a regulated PM 2.5 precursor for the P hiladelphia Area , several VOC

control measures are discussed in this secti on because they are included in the modeling

associated with this attainment demonstration.

Portable Fuel Containers. The Department adopted a portable fuel container regulation,

25 Pa. Code Chapter 130, Subchapter A, to address VOC loss resulting from permeation through portable gasoline containers, evaporative loss through container openings, and spillage during the filling of small tanks on machines such as lawn mowers, chain saws

and jet skis. The regulation was submitted to the EPA as a SIP revisi on on March 26, 2003 and approved on December 8, 2004 (69 F R 70893).

Consumer Products. This regulation applies statewide to any person who sells, supplies, offers for sale, or manufactures certain consumer products on or after January 1, 2005, for

use i n the Commonwealth. The program is contained in 25 Pa. Code Chapter 130, Subchapter B. It was submitted to the EPA as a SIP revision on March 26, 2003 and approved on December 8, 2004 (69 FR 70895). Additional regulations were adopted on October 11, 200 8 and submitted to the EPA as a SIP revision on April 14, 2009

.32

Architectural and Industrial Maintenance (AIM) Coatings . The Pennsylvania AIM Coatings regulation applies statewide to any person who supplies, sells, offers for sale, or manufactures, blend s or repackages an AIM coating for use within the Commonwealth, as well as a person who applies or solicits the application of an AIM coating within the Commonwealth. The AIM coating program requirements are specified in 25 Pa. Code Chapter 130, Subchapte r C. The regulation was submitted to the EPA as a SIP revision on December 3, 2003, with a supplement submitted on October 19, 2004. The EPA approved the provisions as an element of the SIP on November 23, 2004 (69 FR 69080).33

V. ATTAINMENT DEMON STRATI ON AND WEIGHT OF EVI DENCE (WOE)

A. Attainment Demonstration Background and Objectives

The EPA issued fine particle standards in 1997 after evaluating hundreds of health studies and conducting an extensive peer review process. The 1997 annual health

- ba sed standard

for PM 2.5 is 15.0 μg/m 3 , based on the 3

- year average of annual mean PM 2.5 concentrations.

The EPA also established a 24

- hour health

- based standard of 65 μg/m 3 , determined by the

3

- year average of the 98th percentile of 24

- hour concentrations. The EPA set levels to protect the environment at the same level s as it set the health

- based standards. Note that

w hile the EPA has subsequently revised the 24

- hour standard in 2006 to be more protective

, EPA designated the Philadelphia Area as nonattainment because it violate d the 1997 annual standard of 15.0 μg/m3 based on 2001

- 03 monitoring data. Therefore, t his SIP revision compares air quality data to the 1997 24

- hour standard (65 μg/m 3 ).

On April 1, 2003, the EPA issued a memorandum , “Designations for the Fine Particle National Ambient Air Quality Standards” outlining the schedule for designating areas

under the PM 2.5 standard and related guidance on nine factors to consider in identifying

nonattainment areas. The CAA provides for states and tribes to submit designation

recommendations to the EPA , and it requires the EPA to provide time for consultation in cases where the Administrator plans to promulgate a designation that modifies the state or tribal recommendation. On December 17, 2004

, the EPA published its air qual ity designations and classifications for the 1997 PM 2.5 NAAQS. These designations became effective on April 5, 2005.

Figure 4 graphically depicts all of the PM 2.5 nonattainment areas in Pennsylvania. Based

on 2006

– 2008 monitoring data, all monitors in the Philadelphia Area meet the EPA ’s

annual PM 2.5 standard (15.0 μg/m 3 ). The Philadelphia Area’s maximum 2008 annual design value of 14.5 μg/m 3 was observed at the Broad Street monitor. Based on 2006

– 2008 monitoring data, a ll monitors within the P hiladelphia A rea are monitoring attainment

of the 1 997 24

- hour PM 2.5 standard (65 μg/m 3 ). The maximum 200 8 24

- hour design value

in the P hiladelphia Area was 36 μg/m 3

, observed at the New Garden monitor. The Philadelphia A rea is required to attain the PM 2.5 standard no later than five years from the

effectiv e date of designation of April 5, 2005 (April, 2010).

Th e purpose of the attainment demonstration is to ensure, through grid modeling, that projected emissions (with controls) will not cause the nonattainment area to exceed the

1997 PM 2.5 NAAQS. A comple x grid model was run and processed over the entire

Northeast to determine if the P hiladelphia A rea would attain the PM 2.5 standard by April 5,

2010.

The procedures followed in this modeling analysis are in accordance with EPA ’s Guidance

on the Use of Mod els and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (EPA

- 454/B

- 07

- 002, April 2007). A brief summary of the modeling analysis used in this demonstration is included in the following34

sections. The De partment submitted a modeling protocol to the EPA in May 2006 for the

P hiladelphia Area that includes a more thorough description of th e modeling analysis

.

Figure 4 : Pennsylvania’s PM 2.5 Nonattainment Areas

B

. Philadelphia Area Conceptual Model Description

This section provides a brief description of the conceptual model for the P hiladelphia A rea

. The conceptual model was based on inf ormation from the Northeast States for Coordinated

Air

- Use Management (NESCAUM) final report entitled The Nature of the Fine Particle and Regional Haze Air Quality Problems in the MANE

- VU Region: A Conceptual Description (2006) and the Department’s modeli ng protocol documentation ( October 2007).35

Fine particulate formation in the east ern U nited States is a complex process involving local and regional meteorology, topography, chemistry and transport. Since a violation of an annual standard potentially inv olves a large range of conditions throughout the year, it is

difficult to determine a direct cause

- and

- effect relationship for such a violation. Violations of the annual standard ensure a large range of conditions will contribute to nonattainment making di rect cause

- and

- effect relationship s difficult to determine . In general

, the following statements can be used to provide a working conceptual model that describes the

annual PM 2.5 nonattainment problem in the P hiladelphia Area :

Secondary fine particulate formation is a major contributor to annual PM 2.5 nonattainment in the P hiladelphia A rea . Sulfates, o rganic c arbon and n itrates make

u p almost 75 % of the annual fine

- particulate concentrations ( see Figure 5 )

. Fine

- particulate chemistry favors sulfate forma tion during the warm summer months and nitrate formation during the colder winter months.

In the summer time

, large high pressure systems create favorable conditions for the

oxidation of SO 2 , which eventually form s sulfates. These sulfates then contribute to episodes of high particulate concentrations.

In the winter time, local temperature inversions concentrate emissions near the surface leading to periods of elevated fine

- particulate concentrations. This is especially apparent if significant terrain fea tures are present.

Continuous measurements in the P hiladelphia A rea correlate well with the FRM

data . This indicat e s measurements from the conti nuous monitor generally reflect

actual concentrati ons in the nonattainment area. Average concentrations from th e continuous monitor show a general diurnal pattern with higher concentrations in the overnight and early morning hours than during the day

, due to atmospheric conditions and possibly local mobile source emissions (peaks during rush hour traffic, etc

. )

In addition to th e diurnal signal noted in the continuous monitoring data

, there is a strong weekly pattern in the continuous monitoring data with higher PM 2.5 concentrations on weekdays than on weekends

.

A range of control measures will be necessary to atta in the PM 2.5 standard in the

P hiladelphia A rea due to the complex interaction between local and regional emissions and

local meteorological conditions. Sulfates and nitrates are formed primarily through atmospheric reactions of precursor emissions of SO 2 , NOx and NH 3 . Organic carbon is a

combination of secondary organic particles formed from emissions of VOC and the organic portion of primary PM 2.5 that is directly emitted or condenses near its source. Currently

, our understanding of sulfate and nitrate chemistry and its impacts on PM 2.5 concentrations far exceeds our understanding of contributions from anthropogenic VOC s. This is important because sulfates, nitrate s and organic carbon are major contributors to the

fine particulate problem in the P hilade lphia A rea

. T herefore

, it is reasonable to assume

that a mixture of regional and local SO 2 and NOx controls in addition to VOC controls implemented for attainment of the 8

- hour ozone standard will assist in attain ing the PM 2.5 standard.36 Figure 5 : P hil adelphia Area Percentage of Total Mass Based on Speciated PM 2.5 Data Collected at Chester Averaged 2005 to 2007 Monitored Values

C

. Modeling Domain and Photochemical Modeling System

The modeling demonstration for the P hiladelphia A rea relies heavily on the OTC SIP quality

- modeling platform. Ozone modeling was the primary focus of this effort. OTC ’s

interaction with MANE

- VU and NESCAUM allowed it, through the regional modeling centers, to do additional year

- round modeling for PM 2.5 and Regional Haze.

EPA ’s Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (EPA

- 454/B

- 07

- 002, April 2007) does not recommend a particular model or models for use in a SIP attainment

demonstr ation. The OTC modeling committee used the CMAQ photochemical grid model (version 4.5) as part of its SIP modeling platform (OTC Final Modeling Protocol, 2006). CMAQ is an Eulerian grid model capable of simulating air pollutant concentrations in the

atmo sphere using mathematical equations to characterize chemical and physical properties

.

Meteorological and emission input files must be prepared regardless of which photochemical grid model is used. The regional fine particulate modeling analysis

encompass ed an entire year of simulation for the year 2002 . This approach provided a good variety of episodes to characterize the P hiladelphia A rea ’s PM 2.5 nonattainment problem

.37

Figure 6 shows the modeling domain used by the OTC Modeling Workgroup . A nested

gri d approach wa s used with the lower resolution outer grid providing boundary conditions for a more refined grid covering the area of interest. The modeling domain was chosen to be large enough to properly simulate regional transport. The outer domain boun dary is far enough from the inner grid’s boundary so that clean

- boundary condition assumptions along the outer domain’s boundary are realistic and probably do not unduly influence

concentrations within the inner domain.

Figure 6 . OTC Modeling Study Doma in

Outer grid at 36

- kilometer resolution, inner grid at 12

- kilometer resolution

The meteorological files used in CMAQ were produced using the Pennsylvania State University/National Center for Atmospheric Research ( PSU /NCAR) Mesoscale M odel

version 5 ( MM5 ) . MM5 is a limited

- area, nonhydrostatic, terrain

- following sigma

coordinate model designed to simulate or predict mesoscale atmospheric circulation. The model is publicly available and has been used for various air quality modeling studies in the past

.

The OTC Modeling Committee also examined two emissions processors (EMS2001 and SMOKE, both using CB4 chemistry) in its prior work and concluded that there are differences between them that could be minimized by forcing the models to use a common speciation and surrogate database.

For areas with an attainment date of no later than April 5, 2010 for the PM 2.5 NAAQS, the emission reductions need to be implemented no later than the beginning of 2009. A

determination of attainment will be based on air quality monitoring data collected in 2007, 2008, and 2009. Therefore, the year to project future emissions should be no later than the last year of t he three

- year monitoring period, which in this case is 2009.38

The emissions inventory was developed for 2009 using standard emissions projection techniques. The 2009 inventories developed by MANE

- VU were used in the attainment demonstration. The most recently available inventories from other regional planning organizations ( RPOs ) in the modeling domain were also use d.

Emission inventory guidance documents were followed for developing projection year inventories for point, area, mobile, and biogenic emissions. These procedures address projections of spatial, temporal, and chemical composition change between the base year and projection year.

The control strategies developed for evaluation in the attainment demonstration were selected by the OTC’s Control Strategy Committee. These were selected from groups of strategies developed by the technical subcommittees respo nsible for identifying and developing the regulations and/or other control measures.

Consideration was given to maintaining consistency with control measures likely to be implemented by other modeling domains that may be involved in region

- wide analysis. Also, technology

- based emission reduction requirements mandated by the CAA are included in the future year model runs.

D. Model Performance Evaluation

A critical component of every air quality modeling study is the model performance

evaluation where modeled estimates for the current year base case are compared against observed values to assess the model’s accuracy and provide an indication of its reliability. The results presented here serve as an illustration of some of the model evaluation and

asse ssment, as outlined in the EPA modeling guidance document entitled

, Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for
Ozone, PM

2.5 , and Regional Haze (EPA

- 454/B

- 07

- 002, April 2007), performed on the

Base Year 2002 CMAQ simulation.

The New York State Department of Environmental Conservation ( DEC ) , Division of Air Resources, conducted a performance evaluation of the 2002 base case CMAQ simulation

on behalf of the OTC member s tates. Model performance was e valuated over the entire year, except for the July 6

- 9, 2002 period which was excluded from this analysis since the

observed PM 2.5 and organic mass ( OM ) data at many sites were greatly affected by

Canadian forest fires. Appendix H , relating to Modeling Dem onstration, provides comprehensive operational and diagnostic evaluation results. Highlights of this evaluation are provided in the following sections. The analysis examines model performance over a wide area, including the entire O TR plus the S tate of V irginia (OTR+)

.

1. Daily PM 2.5 Mass

Model performance over the entire OTR+ region was examined using several statistics.

These included overall mean fractionalized bias (MFB) and mean fractional error (MFE)

.39

Equations for these diagnostic s are summari zed below and are included in the EPA modeling guidance document entitled

, Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (EPA

- 454/B

- 07

- 002, April 2007)

.

Mean fraction alized bias (MFB), in %:

Mean fractional error (MFE), in %:

where P = Predicted (modeled) value, O = Observed value, and N = Number of observations

Figures 7 and 8 show MFE and MFB over the entire OTC+ region. The figures indicate the model is generally doing a reasonable job reproducing PM 2.5 across the entire domain with the exception of the New York City area and a few monitors in New England. Overall, the mean bias (predicted minus observed) w as about 3.8 g m - 3 , ranging from

- 17.7 g m - 3 to +24.0 g m - 3 . The highest over

- prediction tended to occur during the colder months, quarters 1 and 4, whereas the days on which the model tended to under

- predict

PM 2.5 were more likely to occur during the summer months.

Figure 7: Mean Fractional Error

MFE ( %) at each FRM location over the entire year: blue, <30%; green, 30

- 45%; orange,

45

- 60%; red, 60

- 75%; pink, >75% (From NY DEQ report, 2007).40 Figure 8 : Mean Fractional Bias

MFB ( %) at each FRM location over the entire year: gray, <

- 45%; blue,

- 45 to

- 15%;

green,

- 15 to 15%; orange, 15

- 45%; red, 45

- 75%; pink, >75% (From NY DEQ report

, 2007 )

.

2. PM 2.5 Speciation

PM 2.5 is composed of several components. The primary components noted in the

m onitoring data include sulfates, nitrates and organic carbon; other components do not significantly contribute to PM 2.5 concentrations. For proper performance, CMAQ predictions for each individual component of PM 2.5 must also be examined.

Data from the various speciation networks in the OTR+ region were compared to model predicted values for the base case (2002). Again

, data from the July 6

- 9, 2002 period was excluded from this analysis due to the Canadian forest fires.

Sulfates (SO 4 - ) are one of the p rimary contributors to the P hiladelphia A rea ’s PM 2.5 nonattainment. Figure 11 depicts modeled and actual sulfate measurements in the OTR+ region. The CMAQ model appears to reproduce actual sulfate concentrations quite well along with its seasonal variabi lity.

Nitrates (NO 3 - ) are another important contributor to the P hiladelphia A rea ’s PM 2.5 nonattainment. CMAQ does less well reproducing actual concentrations than it d oes for

sulfates . Modeled concentrations appear to be less accurate during the colder months (1 st

and 4 th quarters) than the warmer months

.41

OM is another important contributor to the P hiladelphia A rea ’s PM 2.5 nonattainment. CMAQ does not do well reproducing the seasonal variability of OM though it does appear to do a better job reproducin g observed winter values.

Figure 9 : Time Series of SO 4 Mass

Time series of SO 4 mass based on the composite average of all 21 Interagency Monitoring

of Protected Visual Environments ( IMPROVE ) monitors across the OTR+ region.

IMPROVE is a long

- term moni toring program established in the mid

- 1980s to provide data needed to assess the impacts of new emission sources, identify existing man

- made visibility impairment, and assess progress toward improving visibility in National Parks

and Wilderness Areas

. The observed values are denoted with the black diamonds, the model predictions are denoted with gray squares (From NY DEQ report , 2007 ).

NY DE Q ’s model performance included an analysis of the meteorological model used to drive CMAQ

, as well as actual PM 2 .5 values and PM 2.5 ’s speciated components. Appendix

H

- 2 is a technical listing of the model input s , as well as an assessment of the MM5

simulation to real

- world data. The analys i s shows that

, in general, the performance of the

MM5 is reasonable both at the surface and in the vertical, thereby providing confidence in the use of these data in the CMAQ simulations.

Both the MM5 and CMAQ runs appear to meet performance criteria over the entire OTR+ domain. Therefore, it can be assumed the modeling platform provide s meaningful information in regard to projected 2009 PM 2.5 concentrations that will be used to assess the

P hiladelphia A rea ’s future attainment of the PM 2.5 standard.42

E . Projected 2009 Design Value s for the P hiladelphia Nonattainment Area

1

. Ove rview

As mentioned previously , the P hiladelphia A rea has an attainment date of April 5, 2010.

The PM 2.5 NAAQS include an annual standard of 15 .0 μg/m 3 based on the 3

- year average of annual mean PM 2.5 concentrations, and a 24

- hour standard of 65 μg/m 3 based on the 3

- year average of the 98th percentile of 24

- hour concentrations.

This section summarizes the procedures that are used to demonstrate at tainment of the

PM 2.5 NAAQS. As described in EPA’s Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (EPA

- 454/B

- 07

- 002, April 2007), an attainment demonstration consists of (a) analyses that estimate whether selected emissions reductions will result in ambient concentrations that meet the NAAQS, and (b) an identified set of control measures that will result in the required emissions reductions. The necessary emission redu ctions for both of these attainment demonstration components may be determined by relying on results obtained with air quality models.

EPA ’s Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2. 5 , and Regional Haze (EPA

- 454/B

- 07

- 002, April 2007) recommends applying a modeled attainment test to the air quality modeling results

to determine if the PM 2.5 NAAQS will be met. Additional technical or corroboratory analyses may also be used as part of a “supplemental analysis” or a more stringent “weight of evidence” determination to supplement the modeled attainment test and to further support a demonstration of attainment of the NAAQS.

The modeled attainment test and additional corroborative analyses are described in further detail in the remaining portions of this section.

2. Model ed Attainment Test

The purpose of a modeling assessment is to determine if control strategies currently being implemented “on the books” (OTB ) and proposed control strate gies (“on the way” or OTW) will lead to attainment of the NAAQS for PM 2.5 by the attainment year of 2009. The modeling is applied in a relative sense, similar to the 8

- hour ozone attainment test : h owever, t he PM 2.5 attainment test is more complicated and reflects the fact that PM 2.5 is a combination of many different species. In the test, ambient PM 2.5 is divided into major

components . Then, a relative response factor (RRF) and future design value (DVF) is

calculated for each of the PM 2.5 components. Si nce the attainment test is calculated on a per species basis, the attainment test for PM 2.5 is referred to as the Speciated Modeled Attainment Test (SMAT). The following sections outline the process to determine that 2009 projections of PM 2.5 will meet th e NAAQS from regional modeling, as suggested in EPA’s modeling guidance.43

3. Determine Baseline Design Values

The first step in any attainment test process is to determine the baseline design value (DVB). The EPA guidance recommends using a DVB that is the average of the three design value periods that straddle the baseline inventory year (i.e., the average of the 2000

- 2002, 2001

- 2003, and 2002

- 2004 design value periods for a 2002 baseline inventory year).

This results in a 5

- year weighted average, wit h the baseline year having the heaviest weight (i.e., {[2000] + 2*[2001] + 3*[2002] + 2*[2003] + [2004]}/9).

For the SMAT process, a mean PM 2.5 DVB is determined, as well as component specific

DVB

, for each quarter. The following section will detail th e calculation of baseline design

values needed for the PM 2.5 attainment test.

Mean PM

2.5 Baseline Design Values

To begin the SMAT process, a mean PM 2.5 DVB is calculated on a quarterly basis for each

FRM monitor in the PM 2.5 nonattainment areas. Concent rations are calculated based on calendar quarters (Q1: January

- March; Q2: April

- June; etc.) as the NAAQS is calculated for a calendar year, and the quarters need to fit evenly within a year. C alculating the attainment test on a quarterly basis also al lows states to examine the differences in PM 2.5 composition that occur during the different seasons.

Speciated Baseline Conditions

The monitored attainment test for PM 2.5 utilizes both PM 2.5 and individual PM 2.5 component species. A separate RRF is calcu lated for each PM 2.5 species. In order to perform the recommended modeled attainment test, s tates should divide observed mass concentrations

of PM 2.5 into seven components (plus passive mass):

1. Mass associated with sulfates (SO 4 )

2. Mass associated with nitra tes (NO 3 )

3. Mass associated with ammonium (NH 4 )

4. Mass associated with organic carbon (OC)

5. Mass associated with elemental carbon (EC)

6. Mass associated with particle bound water (PBW)

7. Mass associated with “other” primary inorganic particulate matter (Crustal)

8. P a ssively collected mass or the mass of the blank filter (Passive)

This yields the following formula in order to calculate PM 2.5 :

PM2.5 FRM = [SO 4 ] + [NO 3 ] + [OC] + [EC] + [NH 4 ] + [PBW] + [Crustal] + [Passive]

The second part of the process is to use the q uarterly mean PM 2.5 DVBs with speciated data to calculate the quarterly mean concentrations of these 7 components at the FRM sites. This need to speciate the FRM data presents two issues:44

1. FRM measurements and speciated PM 2.5 measurements do not always m easure the

same mass. 2. Not all FRM monitoring sites have co

- located Speciation Trends Network ( STN ) speciation monitors.

The following sections will explain how these issues are addressed to produce the speciated values needed for this attainment demonst ration.

SANDWICH

As the EPA ’s Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (EPA

- 454/B

- 07

- 002, April 2007) notes, recent data analyses have noted that the FRM monito rs do not measure the same components and do not retain all of the PM 2.5 that is measured by STN samplers . T herefore

, measurements from FRM monitors cannot be directly compared to speciation measurements from the STN monitors

. By design, the FRM mass mea surement
does not retain all ammonium nitrate and other semi

- volatile materials (negative sampling artifacts) and includes particle bound water associated with sulfates, nitrates and other hygroscopic species (positive sampling artifacts). This results in concentrations (and percent contributions to PM 2.5 mass) that may be different from the ambient levels of some

PM 2.5 chemical constituents.

To resolve the differences between FRM and STN total mass, EPA recommends using the “sulfate, adjusted nitrate, derived water, inferred carbonaceous ” (SANDWICH) material balance approach

. With the SANDWICH approach, nitrate mass is adjusted to account for volatilization based on hourly meteorology parameters. Subsequently, quarterly average nitrate, sulfate, eleme ntal carbon, ammonium a nd crustal mass can be calculated, as well as the Degree of Neutralization (DON) of sulfates. Next

, the mass of particle bound water can be calculated from the previously obtained DON, sulfate, nitrate, and ammonium values. ( See mo re details on particle bound water calculations in the Annual SMAT

Results section

, below). Finally, organic carbon is calculated by taking the difference

between the total PM 2.5 mass as measured at the FRM monitor, and the calculated component mass (i.e. , OC from mass balance ([OCMmb] = PM2.5 FRM - {[EC] + [SO 4 ] + [NO 3 ] + [NH 4 ] + [PBW ] + [ Crustal ] + [ Passive ]}), where the Passive (mass) is the FRM sampling artifact normally set equal to 0.5 )

.

EPA Region 3 office provided SANDWICHed data for the Philade lphia A rea monitor s

. For a description and use of the SANDWICH method

, see the Definition of SANDWICHed

STN Data (EPA, 2006)

.

Speciated Profiles

While the SANDWICH method reconciles the differences between FRM and STN, a lingering issue is that not all F RM monitoring sites have co

- located STN monitors to provide speciated data. EPA guidance suggests four measures that can be taken to resolve the lack of speciated data:45

1. Use of concurrent data from a nearby speciated monitor

2. Use of representative data (f rom a different time period)

3. Use of interpolation techniques to create a spatial field using ambient speciation

data

4. Use of interpolation techniques to create spatial fields, and gridded modeling outputs to adjust the species concentrations

Of the four me thodologies, EPA recommends using one of the spatial interpolation techniques to estimate species concentrations at FRM sites that do not have speciation data (numbers 3 and 4

, above). To assist in this task, EPA began developing a software tool

called “M odeled Attainment Test Software” (or MATS) that would perform the spatial analysis of described options number 3 and 4. However, the MATS tool was not available at the time this analysis was completed. In trying to pursue the EPA recommended course

of ac tion, opt ion 1 ( use of concurrent data from a nearby speciated monitor ) was utilized.

4. Relative Response Factor Calculations

The calculation of RRFs for this study was performed using the EPA recommended method for “nearby” grid cells for a 12

- kilom eter horizontal grid resolution, with a 3x3 grid cell array for 12

- km resolution modeling. The relative response factor used in the modeled attainment test is computed by taking the ratio of the mean of the predictions in the future to the mean predictions with baseline emissions, over all relevant days.

For the 24

- hour and annual PM 2.5 NAAQS, the spatially averaged value of the nearby predictions (mean value of the grid cell array) was used. Each component

- specific RRF

was used in the modeled attainment test by taking the ratio of the mean of the spatially averaged daily predictions in the future to the mean of the spatially averaged daily predictions with current emissions.

The basis for this approach is as follows:

1. Consequence of a control strategy ma y be “migration” of a predicted peak. If a

s tate were to confine its attention only to the cell containing a monitor, it might underestimate the RRF (i.e., overestimate the effects of a control strategy).

2. Uncertainty in the formulation of the model and the model inputs is consistent with recognizing some leeway in the precision of the predicted location of

concentrations.

3. Standard practice in defining a gridded modeling domain is to start in the southwest corner of the domain and determine grid cell locatio n from there. Considering several cells “near” a monitor rather than the single cell containing the monitor diminishes the likelihood of inappropriate results that may occur from the geometry of the superimposed grid system.

4. The area does not exhibit stron g spatial concentration gradients of observed primary PM 2.5

.46

5. Annual SMAT Results

A difficulty presented in estimating the future design values was missing STN data for

2000 and 2001at the Philadelphia A rea monitor s . This limitation restricted the ca lculation of SANDWICH data to the period 2002

– 2004. Therefore, the 2009 projected design

values are based on speciation profiles developed using 2002

- 2004 STN data

.

There are four FRM monitors in the Pennsylvania portion of the Philadelphia A rea that are

co

- located with a speciated sampler: Chester

, New Garden

, Elmwood, and Philadelphia

AMS Lab . However, since there are eight FRM monitor s within the P hiladelphia Area

, the Department was able to determine that the four speciated monitors (including an add itional monitor in Camden, NJ) in the nonattainment area were representative of all FRM monitor

locations in order to complete the SMAT analysis. RRFs were only calculated for the sulfates, nitrates, organic carbon, elemental carbon and crustal component of PM 2.5

. Referencing the PM 2.5 FRM formula in section 3 above, the only components of PM 2.5 that

were not included in the RRF calculation were ammonium and wa ter. Base and f uture case
ammonium was calculated based on the DON value and the following form ula presented in

EPA’s Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze :

NH4 = 0.29 * NO3 + DON * SO4.

The particle bound water w as then calculated using the particle bound water formula

estimated fr om the Aerosol Inorganic Model . Due to the hygroscopic nature of ammonium sulfate and ammonium nitrate, retained sulfate, nitrate and ammonium will all contain water. Therefore, the final polynomial equation (seen below an d referenced (EPA, 200 6 (2) ) ) contains sulfates, nitrates and ammonium within its calculation. The equation utilized was that for low acidity.

PBW = [202049.0

– 391494.6 * S

– 390912.1 * N + 442.4 * (S^1.5)

– 155.3 * (N^1.5)

- 293406.8 * (A^1.5) + 18927 7.5 * (S^2) + 377992.6 * N * S + 188636.8 * (N^2)

– 447.1 * (S^2.5)

– 507.2 * (S^1.5) * N

– 12.8 * (S^3) + 146.2 * (N^1.5) * S + 217.2 * (N^2.5) + 30.0 * (N^1.5) * (S^1.5)

– 18.6 * (N^3) + 216267.0 * (A^1.5) * S + 215419.9 * (A^1.5) * N

– 621.8 * (A^1.5) * (S^1.5) + 239.1 * (A^1.5) * (N^1.5)

+ 35413.1 * (A^3)] * (SO4 + NO3+ NH4)

where S = SO4 / (SO4 + NO3 + NH4) N = NO3 / (SO4 + NO3 + NH4) A = NH4 / (SO4 + NO3 + NH4)

Table V

- 1 displays the calculated quarterly RRFs for the design monitor of the

P hiladel phia A rea
, Broad Street . Based on the results of the RRF calculations, all PM 2.5 constituents either remain the same or undergo a downward trend

, except for the crustal portion.47 Table V

- 1 : Annual PM 2.5 Quarterly RRF Values

Table V

- 2 presents the results of the annual SMAT results for all of the monitors i n the Pennsylvania portion of the Philadelphia A rea . The SMAT results demonstrate that the projected average annual arithmetic mean PM 2.5 concentration calculated at each FRM

monitor attains the annual PM 2.5 NAAQS. Specifically, all DVF calculations are l ess than

15 .0 μg/m 3

. Table V

- 2 presents the results of the annual SMAT results for a suite of regional modeling runs conducted by OTC

, with each modeling run representing

OTB/OTW control measures. All runs demonst rate timely attainment of the annual NAAQS.

Table V

- 2 : Annual SMAT Results for the Philadelphia Area 2009 On The Books / On

The Way Control Measures

Source: 2000

- 2004 DVB quarterly concentrations calculated from data in Appendix A

- 2. Quarter Sulfates Nitrates OC EC Crustal

1 st 0.9 429 0.8976 0.9514 0.8171 1.0988

2 nd 0.7272 0.7450 0.9867 0.8083 1.1700

3 rd 0.6619 0.8218 0.9875 0.7927 1.1869

4 th 0.9043 0.9008 0.9848 0.8058 1.1433

AIRS ID Site

Name County State 2000

- 2004 DVB 2009 Q1 Q2 Q3 Q4 DVF

420170012 Bristol Bucks PA 14.14 13.69 14.73 13.85 12.1

420290100 New Garden Chester PA 1 4.39 14.73 16.36 13.76 12.4

420450002 Chester Delaware PA 15.07 15.96 16.34 13.74 13.3

420910013 Norristown Montgomery PA 12.68 13.62 13.96 12.34 11.3

421010004 AMS Lab Philadelphia PA 15.99 14.01 15.95 13.82 12.9

421010024 NE Airport Philadelphia PA 1 3.58 13.63 14.95 12.96 11.9

421010047 Broad Street Philadelphia PA 16.59 16.45 15.80 15.37 13.5

421010136 Elmwood Philadelphia PA 15.70 14.20 15.27 12.99 12.7

100031003 Bellefonte New Castle DE 14.87 15.16 15.50 13.13 12.6

100031007 Lums Pond New Castl e DE 13.16 14.37 16.05 10.66 11.3

100031012 Newark New Castle DE 15.27 14.91 16.53 13.14 12.6

100032004 MLK New Castle DE 16.41 15.40 17.61 14.04 13.3

340070003 Camden Camden NJ 13.99 14.54 15.76 12.47 12.3

340071007 Pennsauken Camden NJ 13.99 14.00 14 .75 13.59 12.3

340155001 Gibbstown Gloucester NJ 13.92 13.43 15.08 11.39 11.748

6

. 24

- Hour SMAT Results

As with obtaining the a nnual SMAT Results, a difficulty presen ted in estimating the future design values was missing STN data for 2000 and 2001 at all of the Philadelphia area

monitors . This limitation restricted the calculation of SANDWICH data to the period

2002

– 2004. Therefore, the 2009 projected design values a re based on speciation profiles developed using 2002

- 2004 STN data.

The RRF calculations were very similar to t hose that were computed in the a nnual SMAT analysis, except that all modeled RRFs were compared with each monitoring year’s 24

- hour 98 th percent ile design value. A quarterly analysis was completed consistent with the procedure outlined in EPA’s Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (EPA

- 454/B

- 07

- 002, April 2007).

The procedure that was completed was as follows. The top 25% of the days of the speciation and the modeling data were computed on a quarterly basis. The speciation data was compared with the quarterly PM 2.5 FRM data to compute a speciated comp osition of

the FRM data. A fter the RRFs were calculated ( the RRF values for Elmwood

, are shown

below in Table V

- 3), these RRF values were applied to the speciated composition data to compute a 2009 speciate d composition data. Once this was completed , a future year design value was reconstructed.

Table V

- 3: 24

- hour PM 2.5 Quarterly RRF Values

Quarter Sulfates Nitrates OC EC Crustal

1 st 0.9549 0.9235 0.9211 0.8157 1.0852

2 nd 0.6761 0.7858 0.9841 0.8091 1.1758

3 rd 0.6023 0.8698 0.9947 0.7978 1.2134

4 th 0.9036 0.9237 0.9830 0.8089 1.1514

Table V

- 4 displays the 24

- hour PM 2.5 SMAT results for all of the monitors within the

P hiladelphia A rea

. The SMAT results demonstrate that the projected 24

- hour 98 th
percentile PM 2.5 concentration calculated at th e FRM monitor attains the 24

- hour PM 2.5 NAAQS. Specifically, all DVF calculations are less than 65 μg/m 3 . Table V

- 4 presents
the results of the 24

- hour SMAT results for a suite of regional modeling runs conducted by OTC each representing OTB/OTW control measures. All runs demonstrate attainment of

the 24

- hour PM 2.5 NAAQS.49

Table V

- 4: 24

- hour SMAT Results for t he P hiladelphia Area 2009 On The Books / On

The Way Control Measures

AIRS ID Site

Name County State 24

- Hour 98 th Percentile DVB 2009

2000 2001 2002 2003 2004 DVF

420170012 Bristol Bucks PA 38.4 38.5 37.2 39.6 29.9 32.9

420290100 New Garden * Chester PA

- - 33.7 38.5 32.7 32.5

420450002 Chester Delaware PA 36.2 39.5 31.9 37.8 30.5 33.7

420910013 Norristown Montgomery PA 31.5 47.6 36.8 37.5 28. 8 31.0

421010004 AMS Lab Philadelphia PA 41.2 40.2 39.7 39.9 34.3 35.9

421010024 NE Airport Philadelphia PA 37.5 37.1 33.7 38.7 33.4 31.0

421010047 Broad Street Philadelphia PA 39.0 39.6 36.2 42.3 31.5 33.5

421010136 Elmwood Philadelphia PA 39.0 46.0 3 7.0 35.6 29.5 33.9

100031003 Bellefonte New Castle DE 38.2 40.7 33.8 35.8 32.5 31.0

100031007 Lums Pond New Castle DE 36.4 35.9 30.6 36.5 30.8 28.4

100031012 Newark New Castle DE 39.8 39.5 41.5 36.4 29.1 31.7

100032004 MLK New Castle DE 39.3 43.2 40.6 37.4 34.1 34.5

340070003 Camden Camden NJ 32.1 41.2 36.8 43.0 35.0 32.0

340071007 Pennsauken Camden NJ 35.7 37.8 36.7 37.8 34.8 33.4

340155001 Gibbstown Gloucester NJ 34.1 40.8 35.7 35.1 29.0 30.0

* The New Garden monitor started operating in 2002.

S ource: Data extracted from the US EPA Air Quality System AMP 450 Report. See Appendix A

1 for the AMP 450 Report data for Pennsylvania monitors.

F. Unmonitored Area Analysis

F ollowing EPA ’s Guidance on the Use of Models and Other Analyses for Demonstrat ing Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (EPA

- 454/B

- 07

- 002, April 2007)

, an unmonitored area analysis “...is intended to ensure that a control strategy leads to reductions in ozone or PM 2.5 at other locations which could have b aseline (and future) design values exceeding the NAA QS were a monitor deployed. ”

Projected annual PM 2.5 concentrations surrounding the P hiladelphia A rea indicate most areas in the Commonwealth, including the Pennsylvania nonattainment areas immediately50

sur rounding the P hiladelphia A rea
, are projected to attain the standard by 2009. This

indicates there should be no areas where concentrations could reasonably be expected to

exceed the annual PM 2.5 NAAQS within the nonattainment area

.

The Air Quality Modelin g Group ( EPA Research Triangle Park) has developed the MATS

, described on p. 39, above . MATS is a PC

- based software tool that can perform the

modeled attainment tests for PM 2.5 and ozone (O 3 ), and perform the uniform rate of progress analysis for regiona l haze (visibility). However, w hen this analysis was conducted , MATS was still in development and therefore was not utilized within this analysis.

G. Local Area Analysis

EPA ’s Guidance on the Use of Models and Other Analyses for Demonstrating Attainme nt of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (2007) suggests that it may be necessary to evaluate the impact of local primary PM sources for contributions to both the

24

- hour and annual NAAQS. Evaluation of local PM sources and their effect s on monitor concentrations could be evaluated using a near

- scale model such as AERMOD or

CALPUFF.

Since the end of 2008, there are a total of eight ( 8 ) FRM monitors within the Philadelphia

A rea; four ( 4 ) FRM monitors run by the Department and fou r (4) FR M monitors run by the Philadelphia AMS. In addition, there are four ( 4 ) speciation monitors and at least f ive ( 5 )

continuous PM 2.5 monitor s located withi n the Philadelphia Area

.

Pennsylvania has noted local source interference at PA DEP ’s Chester monitor (PA DEP, September 2004). Chester has the second highest annual PM 2.5 design value (1 4.1 μg/m 3 )

and the fifth highest 24

- h our design value ( 33 μg/m 3 ) in the P hiladelphia Area in 2008.

The 24

- hour design value is below the (1997) 24

- h our standard indicat ing attainment of the NAAQS even with significant local effects.

A review of the Commonwealth’s , Philadelphia County ’s , Delaware’s, Maryland’s and New Jersey’s 2002 emission s from the NEI database indicates eighteen (1 8 ) large sources with greater than 5 0 tons per year (TPY) of direct PM 2.5 emissions within 50 kilometers of

the Chester PM 2.5 monitor. These sou rces are listed in Table V

- 5 . Each source’s PM 2.5 emissions, distance from the Chester mon itor, direction from the Chester monitor, county

, state, and emission to distance ratio (Q/d) are included in the table.51 Table V

- 5: Summary of Large PM 2.5 Sources n ear the Chester Monitor

Source Emissions

(TPY) Distance

(km) Direction County State Q/d

PQ Corp

– Chester 54.6 0.54 N Delaware PA 101.5

Kimberl y Clark

– Chester 97.8 1.35 NE Delaware PA 72.3

Conoco Phillips 89.0 2.53 WSW Delaware PA 35.2

Sunoco

– Marcus Hook. 241.4 4.84 WSW Delaware PA 49.9

Exelon

– Eddystone 400.9 5.03 ENE Delaware PA 79.8

PG&E Corp

– Logan 145.5 5.56 WSW Gloucester NJ 26.1

Valero Refining 128.7 9.50 E Gloucester NJ 13.6

Conectiv Del

. – Edge Moor 519.0 15.42 SW New Castle DE 33.7

Sunoco

– Philadelphia 212.1 16.62 ENE Philadelphia PA 12.8

PG&E Generating 257.3 18.98 SW Salem NJ 13.6

Sunoco 165.5 19.29 E Gloucester NJ 8.6

Deepwater Gener

. Station 107.6 20.82 SW Salem NJ 5.2

Anchor Glass Container 137.2 29.92 SSW Salem NJ 4.6

Sunoco Chemicals 113.9 31.98 ENE Philadelphia PA 3.6

Valero Refining 189.8 35.46 SW New Castle DE 5.4

Exelon

– Cromby Gen 160.6 37.67 NW Chester P A 4.3

Hope Creek Generating 53.1 43.23 SSW Salem NJ 1.2

Occidental Chem Corp 64.2 49.01 NW Montgomery PA 1.3

The ratio of emissions to distance (Q/d) is often used as a screening tool to determine if a source could cause a significant model concentrati on. If a source’s Q/d ratio is larger than twenty (20) it usually warrants an analysis usin g a dispersion model. Table V

- 5 indicates

seven ( 7 ) sources exceed this Q/d ratio and probably warrant an analysis with a dispersion model to gauge their effects o n the Chester monitor. A quick survey of local wind patterns utilizing meteorological data collected from 2004 to 200 8 at the Philadelphia International

A irport meteorological tower indicates the flow is not significantly influenced by any

terrain feature s (since the Chester monitor sits in a lowest regional elevation within the Commonwealth) . Therefore, as shown in Figure 10 below, the Chester area generally experiences a strong west, northwest and southwest flow , which is most likely driven by the synop tic weather pattern across the continental US

. Based on the results from the wind52

rose analysis, five (5) of the identified sources ( Conoco Philips, Sunoco

– Marcus Hook, PG&E Corp

– Logan, Conectiv Del.

– Edge Moor, and PQ Corp

- Chester ) lie upwind of

t he Chester monitor , while the other two (2) sourc es ( Kimberly Clark

– Chester and Exelon

- Eddystone ) li e in less favorable wind directions to transport direct PM 2.5 emissions to the

Chester monitor.

Figure 10. Wind Rose: Philadelphia Int’l Airport Locat ion ( 2004

- 200 8 )

As noted earlier, the Department has observed enhancement of PM 2.5 concentrations at the

Chester monitor by local sources. Using emissions to distance ratios (Q/d) and local predominant wind directions; seven ( 7 ) sources were identified for possible analysis with a dispersion model to gauge the effect of local direct PM 2.5 emissions on the North Braddock monitor. A local area analysis using a dispersion model, however, was not conducted

since the modeled concentrations for the Chester m onitor currently would attain the PM 2.5 NAAQS. This does not preclude the Department from conducting a dispersion modeling analysis as part of a local area analysis in the future for the EPA’s revised 24

- hour PM 2.5 standard.53

H . Weight of E vidence and Oth er Documentation Supporting Attainment

The EPA ’s Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (2007) encourages the use of corroboratory analyses to support the mode led attainment demonstration. These analyses

, collectively referred to as “ weight of evidence ” (WOE)

, help bolster the

assertions that an area will achieve attainment in the allotted time.

Table V

- 6 outlines the types of supplemental information that EPA suggests will satisfy a weight of evidence demonstration . Generally

, the analyses become more complicated as the projected modeled values increase. The p rojected 2009 design value for the annual

standard in the P hiladelphia A re a
, 13.5 μ g/m 3

, is below th e lower bounds of the range of 14.5 μg/m 3 to 15.5 μg/m 3 for which EPA ’s Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (2007) requires a formal weight of evidence demon stration.

According to the EPA ’s Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (2007 ), areas , such as the P hiladelphia Area, that have a projected design value lower than 14.5 μg/m 3 a re recommended to provide basic supplemental analyse s to support the result of the modeling demonstration. The basic supplemental analyse s can include additional modeling, analysis of trends in the monitoring data or emissions and/or obs ervational models and diagnostic analyses. The Department’s supporting evidence include s a brief summary of the modeling demonstration, recent trends in the P hiladelphia A rea’s

monitor ing data and a brief analysis of some of the largest SO 2 sources within the

nonattainment area

.

Table V

- 6 : Summary of PM 2.5 Weight of Evidence Guidelines (EPA Guidance)

Results of Modeled Attainment Test Supplemental Analyses

Annual PM 2.5 24

- Hour PM 2.5

Future Design Value < 14.5 μg/m 3 , all sites Future Design Value < 62 μg/m 3 , all sites Basic supplemental analyses should be

completed to confirm the outcome of

the modeled attainment test

Future Design Value

14.5

– 15.5 μg/m 3 , all

sites Future D esign Value

62

– 67 μg/m 3 , all sites A weight of evidence demonstration

should be conducted to determine if aggregate supplemental analyses support the modeled attainment test

Future Design Value ≥ 15.5 μg/m 3 , all sites Future Design Value
≥ 68 μg/m 3 , all sites More qualitative results are less likely to support conclusion differing from

the outcome of the modeled

attainment test54

2009 Projected Modeling Concentration: The Department’s attainment demonstration

relies on results from the OT B /O T W CMAQ runs completed by the Virginia Department of Environmental Quality. Emissions for the base case (2002) and projected (2009) time frames were developed by MARAMA with input from all jurisdictions that are part of the

OTR

. Base

- case and projected e missions within the P hiladelphia A rea appear to be

reasonable ; therefore

, the projected design value for 2009 should reflect what will actually

be monitored.

Recent analyses of projected CMAQ ozone design values suggest the model may actually

underestimat e the impact of emission reductions on actual concentrations

. This modeled

underestimation of changes in ozone concentrations m a y be due to the model ’ s inability to adequately reproduce changes in ozone concentrations due to large emission reductions. If CMAQ has the same shortfall with fine particulate concentrations

, then it may also

overestimate the projected 2009 PM 2.5 design value s for the P hiladelphia A rea

. Since the calculated design value is already well below 15.0 μg/m 3 , any overestimation of th e projected 2009 annual PM 2.5 design value provides a further cushion bolstering the

argum ent that the P hiladelphia A rea will reach attainment

.

PM 2.5 and Emission Trends: M any monitors within the region are h eavily influenced by

the mobile source sector

. Emissions from the mobile source sector are predicted to be significantly lower in 2009 compared to 2002. As more vehicles subject to cleaner new car standards replace older vehicles subject to less stringent standards, the fleet as a whole

emits fewer emissions.

Figure 1 1 show s the annual and 24

- hour PM 2.5 concentrations for the Chester monitor f rom 1999 through 200 8

. Over the last two years

, annual PM 2.5 averages appear to have

declined slightly

. In fact, all PM 2.5 monitors, excluding the Broad Str eet monitor, in the Philadelphia Area are monitoring attainment of the annual PM 2.5 standard , based on 2006

– 2008 monitoring data

. This may be due to a combination of weather conditions and

emission decreases in the mobile source sector and may be indica tive of lower future PM 2.5 design values allowing the Philadelphia Area to attain the annual PM 2.5 standard with a comfortable margin

.55 Figure 1 1 : Philadelphia Area PM 2.5 Trends56

I. Conclusions

The P hiladelphia Area ’s projected 2009 annual PM 2.5 conc entration was estimated using the OTC’s modeling platform. A review of the base case (2002) run indicated the CMAQ

model did a reasonable job reproducing actual concentrations. Based on this analysis

, it is

reasonable to assume the model can estimate the projected PM 2.5 concentrations within the

P hiladelphia Area for 2009. The Department understands that the EPA anticipates using

2009 data to determine whether the P hiladelphia Area attains the PM 2.5 standard by its April 2010 attainment date

.

Projected P M 2.5 concentrations from CMAQ indicate the P hiladelphia Area will attain the annual standard by 2009 . Additional evidence supporting this conclusion include s lower

concentrations at all of the PM 2.5 monitors within the P hiladelphia Area the last couple of

years and possible model under

- predictions of the air quality benefits of emission

reductions

.57

VI. CONTINGENCY MEASURES FOR THE ATTAINMENT DEMONSTRATION

A. Contingency Measure Requirement

Pursuant to 40 CFR 51.1012

, the attainment plan for the P hila delphia Area must include a contingency plan that contains measures that qualify as contingency measures fo r the

attainment demonstration. This section fulfills the contingency measures requirement for

the attainment demonstration. The contingency plan m ust provide for one year of

reductions needed for attainment.

By 2009, e missions of SO 2 and NOx in the Pennsylvania portion of the P hiladelphia

Area are projected to decrease by 12,259 tons and 28,597 tons, respectively

. Based on modeling of the projec ted 2009 emissions, the P hiladelphia Area is predicted to have a 2009 design value of 13.5 ug/m 3 . This is lower than the 15 ug/m 3 required for attainment

of the PM 2.5 standard

. Calculations were made to estimate the portion of the emission

reduction that is necessary to reach the attainment concentration of 15 ug/m 3 and the portion of the emission reduction that reduces the design value below 1 5 ug/m 3 and is, therefore, excess

.

Table VI

- 1 contains information about the changes in design value and emissi ons expected by 2009 in the five

- county Philadelphia a rea. Table VI

- 1 displays the 2002

actual and 2009 modeled design values and the 2002 actual and 2009 projected emissions

of PM 2.5 , SO 2 and NOx.

Table VI

- 1: Change s in Design Value and Emissions Exp ected by 2009

P hiladelphia Area Design

Value (ug/m 3 ) PM 2.5

(tons/year) SO 2

(tons/year) NOx

(tons/year)

2002 1 6.6 14727 40459 120248

2009 (Modeled/Projected) 13.5 15219 28200 91651

Predicted Change from 2002

- 2009 3.1

- 492 12259 28597

As shown in Table VI

- 2, for each pollutant, the change in pollutant emissions was divided by the predicted change in design value to yield the design value reduction rate

. Next, t he change in design value necessary to attain the standard ( 16.6 ug/m 3

– 15 ug/m 3

= 1.6 ug/m 3 ) was multip lied by the design value reduction rate to estimate the target

emissions reduction

. This represents the portion of emissions reduction necessary to attain the standard. The rest of the emissions reduction is beyond what is necessary for

attai nment and is

, therefore

, considered to be “excess” reduction.58 Table VI

- 2: Calculation of Required and Excess Emissions Reductions

Philadelphia Area Design

Value (ug/m 3 ) PM 2.5

(tons/year) SO 2

(tons/year) NOx

(tons/year)

Predicted Change from 2002

- 2009 3.1

- 492 12259 28597

Design Value Reduction Rate (tons/ug/m 3 ) N/A 3955 9225

Target Reductions for Attainment 1.6 N/A 6327 14760

Calculated Excess Reductions 1.5 N/A 5932 13837

The contingency requirement is calculated by dividing the target emission s reduction by seven which is the number of years between 2002 and 2009. Table VI

- 3 shows the calculation of the contingency requirement reduction and demonstrates that the calculated excess reduction exceeds the amount of reduction necessary for the

cont ingency plan.

Table VI

- 3 : Calculation of Required Contingency Plan Reductions

Philadelphia Area PM 2.5 (tons/year) SO 2

(tons/year) NOx

(tons/year)

Target Reductions for Attainment N/A 6327 14760

Calculated Excess Reductions N/A 5932 13837

Contingency Requirement N/A 904 2109

Excess Reductions Satisfy Contingency

Requirement N/A Yes Yes

B . Identified Contingency Measures

In addition to the calculated excess reductions shown in Table s VI

- 2 and VI

- 3 above, the Department has identified additional co ntrol measures. EPA guidance encourages early implementation of contingency measures to guard against failure either to m eet
a milestone or attain the standard

. EPA's guidance on early implementation of

control measures encourages the early implementatio n of required control measures and of contingency measures as a means of guarding against failures to meet a59

milestone or to attain. The EPA states that a ny implemented measures (that are not

needed for the rate

- of

- progress requirements or for the attainm ent requirements) would

need to be “ backfilled ” , meaning replaced with another measure, only to the extent they are used to meet a milestone

. 7

The reductions from the designated contingency measures are surplus vis

- à

- vis the

attainment demonstration conta ined in this SIP. As a result, the Department will not be required to replace any contingency measures that it chooses to implement in advance of the contingency plan requirement.

The following describes specific control measures that are anticipated to be in place in order to bring the area back into attainment should a violation occur.

On October 9, 2008, Governor Rendell signed Se nate Bill 295, which became Act 124 of 2008, the Diesel

- Powered Commercial Motor Vehicle Idling Act (Act 124) . Act 124 we nt into effect on February 6, 2009. The Department estimates that 50 percent of all long duration idling for Class 8 trucks will be eliminated in 2010 when the temperature exemption for sleeper truck rest expires. Statewide emission reductions are estima ted to be 1610 tons, 45 tons and 30 tons per year for NOx, VOC, and PM 2.5 , respectively. The Department may also utilize enhanced enforcement to obtain additional emission

reductions.

Significant additional reductions in NOx, direct PM 2.5 and

, to a limit ed extent, SO 2 emissions will occur in emissions from highway and nonroad mobile sources after 2009.

NOx emissions from mobile sources are more than one

- third of the emissions in 2009

.

In addition, the following regulations are in development and are ant icipated to be adopted in the relatively near future:

NOx controls for cement kilns NOx controls for glass furnaces Sulfur limits for fuel oil (home heating oil and residual fuel oil)

Regulations to reduce VOC emission s are also in development, inc luding controls on the manufacture and use of adhesives, primers and sealants and regulations incorporating the Control Techniques Guidelines issued by the EPA in 2006, 2007 and 2008

.

Once the Department’s Bureau of Air Quality has obtained an approved r equest to initiate a rulemaking, the rulemaking may proceed as follows:

7 EPA, "Guidance on the Post

- 1996 Rate

- of

- Progress Plan and the Attainment Demonstration," Corrected Version as of February 18, 1994, p. 50.60 Within 2 months: Review by Air Quality Technical Advisory Committee (AQTAC), Citizens Advisory Council and other advisory committees

, 8 as appropriate.

Within 5 months: Environmenta l Quality Board (EQB) meeting/action.

Within 7 months: Publi cation in the Pennsylvania Bulletin for comment as proposed rulemaking.

Within 9 months: Public hearing takes place and comment period on proposed rule

closes.

Within 10 months : House and Se nate Standing Committees and Independent Regulatory Review Commission (IRRC) comment on proposed rule.

Within 12 months: AQTAC, Citizens Advisory Council and other committee s, as appropriate, review responses to comments and draft final rulemaking.

Wit hin 15 months: EQB meeting/action.

Within 16 months: IRRC action on final rulemaking.

Within 17 months: Attorney General review/action.

Within 18 months: Publi cation in the Pennsylvania Bulletin as final rulemaking and

submi ssion to the EPA as a SIP r evision. The regulation would become effective

upon publication in the Pennsylvania Bulletin

.

8 Other committees could include the Small Business Compliance Advisory Committee and Agriculture Advisory Committee.61 REFERENCES

SECTION I

Pope III, C. Arden, M. Ezzati and D. Dockery. “Fine

- Particulate Air Pollution and Life Expectancy in the United States.” New England Jou rnal of Medicine. 360: 376

- 386 January 22, 2009.

EPA, 2007. Clean Air Fine Particle Implementation Rule. Final Rule. 72 FR 20 586 (April 25, 2007).

SECTION III

EPA, 2005. Emissions Inventory Guidance for Implementation of Ozone and Particulate

Matt er National Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations

. EPA

- 454/R

- 05

- 001. August, 2005. Updated November, 2005

Final Technical Support Document, Development of Emission Projections for 2009, 2012, and 2018 for NonEGU Point, Area, and Nonroad Sources in the MANE

- VU Region. Prepared by MACTEC for MARAMA, February 28, 2007.

Final Regulatory Analysis: Control of Emissions from Marine Diesel Engines , EPA,

November 1999.

SECTION V

The Nature of the Fine Particle and Regional Haze Air Quality Problems in the MANE

- VU Region: A Conceptual Description. Prepared by the Northeast States for Coordinated Air

Use Management (NESCAUM), November 2006.

Summary of Pennsylvania’s PM 2.5 Nonattainment Analysis, Prepared by the Pennsylvania Depa rtme nt of Environmental Protection, October 2007

.

Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze. EPA , EPA

- 454/B

- 07

- 002, April

2007.

Final Air

- Quality Modeling Proto col f or the Annual PM 2.5 NAAQS: Philadelphia

Wilmington PA

- NJ

- DE Annual PM 2.5 Nonattainment Area , prepared by the Pennsylvania Department of Environmental Protection, October 2007.

A Modeling Protocol for the OTC SIP Quality Modeling System For Assessmen t of the Ozone National Ambient Air Quality Standard in the Ozone Transport Region

, The Modeling Committee of the Ozone Transport Commission , March 2006.62

CMAQ Model Performance and Assessment for Base Year 2002: PM 2.5 Mass and Speciation, Prepared by the New York State Department of Environmental Conservation

, December 2007.

Clegg, S.L., P. Brimblecombe, and A. S. Wexler, (1998), “Aerosol Inorganics Model; A Thermodynamic Model of the System H+

- NH4+

- SO42

- - NO3

- - H2O at Tropospheric Temperatures.”, J

. Phys. Chem ., 102A, 2137

- 2154. ( http://www.aim.env.uea.ac.uk/aim/project.htm ).

EPA , 2004

. Pro cedures for Estimating Future PM 2.5 Values for the CAIR Final Rule by Application of the (Revised) Speciated Modeled Attainment Test (SMAT)

. July 26, 2004.

Av ailable on EPA’S CAIR PDF web page ( www.epa.gov/CAIR/pdfs/Revised

- SMAT.pdf )

.

EPA , 2006

. Definition of SANDWICHed STN Data. November 1, 2006. Available on

EPA’s Air Explorer web page ( www.epa.gov/mxplorer/sandwich_description.doc )

.

EPA, 200 6 (2). SANDWICH Material Balance Approach for PM 2.5 Data Analysis (Presented at the 2006 National Air Monitoring Conference) . November 6

- 9, 2006. Available on EPA’s AMTIC web page ( www.epa.gov/ttn/amtic/files/ambient/2006conference/frank.pdf ).

SECTION VI

U. S. EPA, "State Implementation Plans; General Preamble for the Implementation of

Title I of the Clean Air Act Amendments of 1990", Proposed Rule, 57 Federal Register 13

, 498 (April 16, 1992).

EPA , "Guidance on the Post

- 1996 Rate

- of

- Progress Plan and the Attainment Demonstration," Corrected Version as of February 18, 1994, p. 50.

OTC 2007. Identification and E valuation of Candidate Control Measures: Final Technical Support Document. Prepared by MACTEC Federal Programs, Inc., Herndon, Virginia for the Ozone Transport Commission. February 28, 2007.63 ACRONYMS AND ABBREVIATIONS

AIM Architectural and Industrial Ma intenance Coatings AQTAC Air Quality Technical Advisory Committee

BACT Best Available Control Technology

CAA Clean Air Act

CAIR Clean Air Interstate Rule

CA LEV California Low Emission Vehicle (program)

CF Control Factor

CFR Code of Federal Regulat ions CMAQ Community Multi

- scale Air

- Quality Model

CMV Commercial Marine Vessel

DON Degree of Neutralization

DV B Baseline Design Value

DVF Future Design Value

EC Elemental Carbon

EDMS Emissions and Dispersion Modeling System

EGAS Economic Growth A nalysis System

EGU Electric Generating Unit

EIA Energy Information Administration

EPA The U nited S tates Environmental Protection Agency EQB Environmental Quality Board

FAA Federal Aviation Administration

FIP Federal Implementation Plan

FIRE Factor Information Retrieval

FMVCP Federal Motor Vehicle Control Program

FR Federal Register

FRM Federal Reference Method

HAP Hazardous Air Pollutant

ICI Industrial, Commercial, Institutional

I/M Inspection and Maintenance

IPM Integrated Planning Mode l

IRRC Independent Regulatory Review Commission

LDGV Light Duty Gasoline V ehicles

LDGT Light Duty Gasoline T rucks

MACT Maximum Achievable Control Technology

MANE

- VU Mid

- Atlanti c/ Northeast Visibility Union

MARAMA Mid

- Atlantic Regional Air Management As sociation

MATS Modeled Attainment Test Software

MM5 Mesoscale Model Version 5

MPO Metropolitan Planning Organization

MY Model Year NAAQS National Ambient Air Quality Standard

NAICS North American Industry Classification System

NBP NOx Budget Progra m NESCAUM Northeast States for Coordinated Air

- Use Management

NH 3 Ammonia64

NH 4 + Ammonium

NLEV National Low Emission Vehicle (program)

NMIM National Mobile Inventory Model

NO x Oxides of Nitrogen

NO 2 Nitrogen Dioxide

NO 3 - Nitrates

NSR New Source Revie w OC Organic Carbon

OM Organic Mass OTAQ Office of Transportation and Air Quality

OTB On the B ooks

OTC Ozone Transport Commission

OTW On

- the

- W ay OTR Ozone Transport Region

PBW Particle Bound Water

PennDOT Pennsylvania Department of Transportatio n
PHL Philadelphia International Airport

PM Particulate Matter

PM 2.5 Particulate Matter less than 2.5 microns in diameter or Fine P articulates

PM 10 Particulate Matter less than 10 microns in diameter

ppm parts per million

PSD Prevention of Signific ant Deterioration

PSU/NCAR Pennsylvania State University National Center for Atmospheric Research

RACM Reasonably Available Control Measure

RACT Reasonably Available Control Technology

RE Rule Effectiveness

RFP Reasonable Further Progress

RP Rule Pe netration

RPO Regional Planning Organization

RRF Relative Response Factor

RVP Reid Vapor Pressure

SANDWICH Sulfate, Adjusted Nitrate, Derived Water, Inferred Carbonaceous Material

Balance A pproach

SCC Source Classification Code

SCR Selective Catalyti c Reduction

SIP State Implementation Plan

SMAT Speciated Modeled Attainment Test

SMOKE Sparse Matrix Operator Kernel Emissions

SO 2 Sulfur Dioxide

S O 4 - Sulf

ates
STN Speciation Trends Network

TCM Transportation Control Measures

TEOM Tampered Eleme nt Oscillating Microbalance M onitor

TSD Technical Support Document

μ g/m 3 M icrogram per cubic meter

μm M icro meter65

VISTAS Visibility Improvement State and Tribal Association of the Southeast

VMT Vehicle Miles Traveled

VOC Volatile Organic Compound

WOE Weight of Evidence

ZEV Zero Emi ssions Vehicle