Technical Support Document (TSD) for the Redesignation Request and Maintenance Plan

For the Charleston, WV

2006 PM 2.5 Nonattainment Area

Submitted December 2012 by the West Virginia Department of Environmental Protection

TSD Prepared August 2013 by Jessica L. Fry Office of Air Monitoring and Analysis, 3AP40 U.S. Environmental Protection Agency, Region 3

1650 Arch Street Philadelphia, Pennsylvania 19103

/s/

____________________________________________ Reviewed by Alice H. Chow

, Associate Director Office of Air Monitoring and Analysis (3AP40)

8/29/2013

_________________ Date SignedI. Introduction

The purpose of this document is to provide a technical summary of the Office o f Air Monitoring and Analysis (OAMA) review of the emissions inventories submitted with the Redesignation Request and Maintenance Plan for the Charleston, WV 2006 PM 2.5 Nonattainment Area by the West Virginia Department of Environment al Protection (WVDEP). This review does not determine the approvability of the redesignatio n request or maintenance plan. Emissions inventories in a redesignation request are used to show permanent and enforceable emission reductions between the year the area was designated as a nonattainment area and the year the

area came into attainment. In a maintenance plan, the emissions inventories are use d to reflect the emissions during the time the area came into attainment and are then projected to show that

the area will remain in attainment. Any questions pertaining to this technical summary should be

directed to Alice H. Chow

, Associate Director, Office of Air Monitoring and Analysis, at 215

- 814

- 21 44 or via email at chow.alice@epa.gov

.

II. Emissions Inventories for Redesignation Request

200 5 Nona ttainment Year Inventory

In a redesignation request, emissions inventories are used to support the States claim that the area has permanent and enforceable emissions reductions. In order to do this, the state should estimate the percent reduction (from the year that was used to determine the design value for designation and classification) achieved from federal and state control measures; this is usually termed as the nonattainment year inventor y

. The 2005 nonattainment year inventory contains primary PM 2.5 emissions (including condensibles), SO 2 and NO

x . WVDEP did not

include VOC and NH 3 emissions having determined them to be insignificant. This section will

discuss the 2005 base/nonattainment year inventory that was used in the Charleston, WV Redesignation Request and Maintenance Plan submitted by WVDEP.

WVDEP compiled emissions inventories for the nonattainment area which consists of

Kanawha and Putnam Counties.

The 200 5 point source inventory contained emissions for electric generating units (EGUs) and Non

- EGU sources in Kanawha and Putman Counties. EPA guidance for emissions inventory development provides that actual emissions should be used for purposes of the base

yea r inventory. WVDEP used WV Department of Air Quality’s (DAQ) 2005 annual emissions inventory submitted to EPA’s National Emissions Inventory (NEI) database and EPA’s Clean Air Markets Division (CAMD) database to compile their inventory. Much of the work in developing the inventory involved realigning the EGUs and Non

- EGUs from the 2005 dataset

submitted to the NEI with the CAMD dataset.

For the 2005 n onpoint emissions, WVDEP used 2005 NEI v2 data developed by the

EPA.For 2005 n onroad mobile sources, WV DEP generated the emissions using EPA’s

NONROAD model. Since marine, air and rail/locomotive (MAR) emissions are not part of the NONROAD model, they were calculated separately outside of the NONROAD model.

The 2005 onroad m obile source inventory was de veloped using EPA’s highway mobile

source emissions model MOVES2010a. The analysis was performed by Michael Baker Jr. Inc., under contract to the WV Department of Transportation (WVDOT) and the responsible Metropolitan Organization (MPO), the Regional Int ergovernmental Council (RIC). In order to develop local data inputs t he latest planning assumptions and regional planning t ools were used.

Data used to develop inputs was obtained from WVDOT, DEP, RIC and other national/local

sources.

OAMA staff reviewed the files and the emission results provided by WVDEP and found them to be acceptable.

I I I. Emissions Inventories for Maintenance Plan

2008 Attainment Year Inventory and Maintenance Plan Base Year Inventory

Under section 172(c)( 3) states are required to submit a comprehensive, accurate, current accounting of actual emissions from all sources (point, nonpoint, nonroad, and onroad) in the

nonattainment area. Th is inventory contains primary PM 2.5 emissions (including condensibles),

SO 2 , NO

x , VOC, and NH 3. In a Maintenance Plan, states are required to submit an inventory used for the ye ar of attainment, which is called the attainment year i nventory and can also be referred to as the maintenance plan base year i nventory. This invent ory is used as the basis for the projected inventories that are used to show the area will remain in attainment. The base year inventory submitted by WVDEP contains primary PM 2.5 emissions (including condensibles),

SO 2 and NO

x

. Emissions for VOC and NH 3 f or the nonattainment area have been supplemented

with emissions from the 2008 NEI v1.5 NEI. This section will discuss the 2008 emissions

i nventory that was used in the Charleston, WV Redesignation Request and Maintenance Plan in order to fulfill the 172(c )(3) and attainment year emissions inventory requirements.

The 200 8 point source inventory contained emissions for EGU and Non

- EGU sources in

Kanawha and Putman Counties. EPA guidance for emissions inventory development provides

that actual emissions sho uld be used for purposes of the bas e year inventory. WVDEP used

WV DAQ 2008 annual emissions inventory submitted to EPA’s NEI database and EPA’s CAMD database to compile their inventory. Much of the work in developing the inventory involved realigning the EGUs and Non

- EGUs from the 2008 dataset submitted to the NEI with the CAMD

dataset

.

For the 2008 n onpoint emissions, WVDEP used 2008 NEI v1.5 data developed by the

EPA. Commercial marin e vessels and l ocomotive emissions contained in the 2008 NEI v1.5

were moved to the non

- road data category

.For 2008 n onroad mobile sources, WVDEP generated the emissions using EPA’s

NONROAD model. Since marine, air and rail/locomotive (M AR) emissions ar e not part of the NONROAD model, they were calculated separately outside of the NONROAD model.

The 2008 onroad m obile source inventory was developed using EPA’s highway mobile source emissions model MOVES2010a. The analysis was performed by Michael Bak er Jr. Inc., under contract to the WVDOT and the responsible RIC. In order to develop local data inputs the latest planning assumptions and regional planning tools were used. Data used to develop inputs was obtained from WVDOT, DEP, RIC and other nationa l/local sources.

OAMA staff reviewed the files and the emission results provided by WVDEP and found

them to be acceptable.

2018 and 2025 Projection Emission Inventories

Projection inventories are used to show that the area will remain in attainment. WVDEP

used 2018 and 2025 emission projections for the interim and maintenance plan end year, respectively.

WVDEP used EPA’s Integrated Planning Model (IPM) projections to support the Cross State Air Pollution Rule (CSAPR). IPM projections of 2014 (released as 2014, the projected future year data provided with this platform is generally representative of several years around

2012 and 2014 such as 2018 1 ), 2020 and 2030 were used. WVDEP compiled p oint source EGUs

from EPA’s CSAPR inventories of 2018 and 2025 was interpolated between 2020 and 2030

inventories. WVDEP acknowledges the D.C. Circuit Court ruling which vacated and remanded

CSAPR and ordered EPA to continue administ ering the Clean Air Interstate Rule (CAIR) and explains in their plan that even without the impleme ntation of CSAPR there will be sufficient

reductions to remain in attainment of the standard. Non

- EGU p oint source emissions,

inventories for 2018 and 2025 were grown from the 2008 inventory using Workforce West Virginia economic forecasts.

Nonpoint source emissions for 2018 and 2025 were based on the 2008 inventory using

Workforce West V ir ginia economic forecasts. The Workforce WV projections were selec ted because their projections were based more on local data, provided more coverage of various categories

, and a wider range of years based on 2008 emissions data . WVDEP compiled and associated Workforce WV’s growth factors with North American Industrial Classification System codes with WVDEP’s Source Classification Codes. Calculations were made and final estimates reflected both positive and negative growth.

Nonroad source emissions for 2018 and 2025 were developed using monthly NO N ROAD

model runs and s ummarizations of monthly data to obtain annual data values . MAR emissions

for 2018 and 2025 were based on the 2008 inventory using Workforce WV economic forecasts.

1 Posted June 29, 2011, 2014 Emissions Data Files,

f tp://ftp.epa.gov/EmisInventory/2005v4_2/2014emis/readme_2005v4_2_CAP_BAFM_HAPs_inventories_2014_inp

uts.txtThe same methodology was used to project MAR emissions as was discussed previously for

n on point sources.

Onroad mobile projection emissions for 2018 and 2025 were calculated from MOVES2010a produced emission factors as performed by Michael Baker Jr. Inc., under contract

to the WVDOT and RIC.

OAMA staff reviewed the methodologies provided by W VDEP and found them to be acceptable

.