## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 1 

# Appendix A: Tacoma

- Pierce County PM 2.5 

# Redesignation Request and Maintenance Plan

Emissions Inventory Documentation

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 2 

# Table of Contents

1 Introduction

................................ ................................ ................................ .............................. 3

2 Emissions Summaries

................................ ................................ ................................ .............. 3

3 Inventory Development

................................ ................................ ................................ ............ 8

3.1 General Information

................................ ................................ ................................ .......... 8

3.2 Point Sources

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

3.3 Minor Stationary Sources Inventoried as Point Sources

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

3.4 Nonpoint Sources

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

3.4.1 Residential Wood Combustion

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

3.4.2 Paved Road Dust

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

3.4.3 Petroleum Distribution

................................ ................................ .............................. 25

3.4.4 Fugitive Dust Emissions from Coal Trains

................................ ............................... 27

3.4.5 National Emissions Inventory Categories

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

3.5 Nonroad Mobile Sources

................................ ................................ ................................ . 32

3.5.1 Nonroad Mobile, Except Locomotives, Marine, and Port Sources

.......................... 32

3.5.2 Locomotives

................................ ................................ ................................ .............. 34

3.5.3 Marine a nd Port of Tacoma Sources

................................ ................................ ......... 35

3.6 Onroad Mobile Sources

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

3.6.1 Vehicle Miles Traveled

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

3.6. 2 Vehicle Population

................................ ................................ ................................ .... 39

3.6.3 MOVES Modeling and Emissions Estimates

................................ ........................... 39

4 Quality Assurance and Quality Control

................................ ................................ ................. 40

4.1 Quality Control Procedures

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

4. 2 Quality Assurance Procedures

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

Appendix A1

– National Emissions Inventory Source Categories

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

Appendix A2

– Residential Wood Combustion Temperature Adjustment

................................ .. 43

References

................................ ................................ ................................ ................................ ..... 44

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 3 

# Tacoma

- Pierce County PM 2.5 

# Redesignation Request and Maintenance Plan

Emission Inventory Documentation

1 Introduction

As part of developing a state implementation plan (SIP) revision, the Washington State

Department of Ecology (Ecology) submitted an emission inventory (EI) preparation plan (IPP)

and prepared an inventory of direct fine particles (PM 2.5 

## ) and their precursors. The precursors

are nitrogen oxides ( NO X 

## ), sulfur dioxide (SO 2 

## ) , volatile organic compounds (VOCs) and

ammonia (NH 3 

## ). Ecology prepared nonattainment area winter day and annual inventories for the

attainment year (2011), the final year of the maintenance plan (2026), and an interim year

(2017).

The responsibility of the EI was a shared effort by Ecology , the Puget Sound Clean Air Agency

(PSCAA) , and the Puget Sound Regional Coun cil . Ecology performed most of the calculations,

ran the models, and wrote the documents while much of the specific information (i.e., sources of

pollutants, survey data, etc.) needed for that task was provided by PSCAA. The Puget Sound

Regional Council (PSRC) provided traffic and economic forecasting data.

This document provides documentation for the attainment year and projection year inventories

per United States Environmental Protection Agency (EPA) inventory guidance. 1



## 2 Emissions Summaries

Annual emi ssions and winter weekday emissions are presented here. Tables and charts are

included. Tables show source types by major sector group. Sectors are abbreviated as PT

- Point Sources, NP

- Nonpoint Sources, NR

- Nonroad Sources, OR

- Onroad Sources.

Abb reviations for each source are shown in the table below.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 4 Table 1 : Abbreviations Used in Emissions Summaries

Sector Source Type Abbreviation

PT1 Point Sources

- Major MAJOR

PT2 Point Sources

– Minor MINOR

NP Architectural Coatings ARCH

NP Commercial Cooking COOK

NP Consumer & Commercial Solvents SOLV

NP Surface Coating SURF

NP Dust

– Construction DUST _CNST

NP Dust

- Paved Roads DUST_ PAV

NP Dust

– Coal Trains DUST_ RR

NP Fertilizer Application FERT

NP Gas Cans GAS _CANS

NP Gas Stations GAS_STN

NP Livestock Waste LIVE

NP Residential Fuel, except Wood FUEL

NP Residential Fuel, Wood

- Certified Stoves & Inserts RWC

- C

NP Residential Fuel, Wood

– Firelogs RWC

- LG

NP Residential Fuel, Wood

– Fireplaces RWC

- FP

NP Residential Fuel, Wood

- Pellet Stoves RWC

- PL

NP Residential Fuel, Wood

- Uncertified Stoves & Inserts RWC

- U

OR Onroad ONRD

NR Locomotives RR

NR Marine

- Harbor Craft HARB

NR Marine

- Ocean

- going Vessels OCEAN

NR Marine

- Pleasure Craft BOAT

NR Nonroad

- Commercial COMM

NR Nonroad

- Construction CNSTR

NR Nonroad

- Industrial IND

NR Nonroad

- Lawn and Garden LAWN

NR Nonroad

- Railroad Equipment RAIL

NR Port of Tacoma, non

- Marine PORT

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 5

Figure 1 : PM

2.5 

## Winter Day Emissions in Pounds

Category 2011 2017 2026

RWC 25,519 25,355 25,788

Onroad 2,497 1,642 1,149

Dust 2,023 2,069 2,631

Point

- Major 1,313 1,940 1,848

Nonroad 1,384 957 697

Other 1,025 1,136 1,266

TOTAL 33,761 33,099 33,379



## Table 2 : PM

2.5 

## , SO 2 

## , and NO X 

## Emissions, Winter Weekday, lbs

Gp Source PM2.5 SO2 NOx

2011 2017 2026 2011 2017 2026 2011 2017 2026

PT1 MAJOR 1,313 1,940 1,848 1,972 3,686 3,686 6,466 7,363 7,338

PT2 MINOR 0 55 55 0 258 258 0 303 314

NP RWC

- FP 5,477 5,410 5,311 93 92 90 603 596 585

NP RWC

- U 13,237 12,121 11,106 173 158 145 1,211 1,109 1,016

NP RWC

- C 6,421 7,418 8,927 160 187 227 883 1,035 1,260

NP RWC

- PL 60 73 93 6 8 10 75 91 116

NP RWC

- LG 325 333 350 0 0 0 88 90 95

NP FUEL 49 53 58 687 738 813 3,810 4,093 4,506

NP COOK 975 1,028 1,153 0 0 0 0 0 0

NP DUST_CNST 596 654 678 0 0 0 0 0 0

NP DUST_PAV 1,232 1,318 1,392 0 0 0 0 0 0

NP DUST_RR 196 96 561 0 0 0 0 0 0

OR ONRD 2,497 1,642 1,149 242 223 208 60,799 36,339 19,896

NR COMM 75 62 48 3 2 3 1,041 791 660

NR CNSTR 729 444 180 20 7 8 8,260 5,121 2,764

NR IND 52 26 16 3 2 2 990 539 499

NR LAWN 179 194 219 2 2 2 492 405 421

NR RAIL 1 1 0 0 0 0 7 5 3

NR RR 43 32 16 11 1 1 1,612 1,367 954

NR PORT 118 132 143 1,188 1,500 1,958 2,497 2,752 2,675

NR OCEAN 156 34 45 2,901 140 182 2,286 2,732 3,566

NR HARB 31 31 30 1 1 1 879 817 741

NR BOAT 0 0 0 0 0 0 7 7 6

TOTAL 33,761 33,099 33,379 7,463 7,004 7,594 92,006 65,555 47,414

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 6 Table 3 : VOC and NH 3 

## Emissions, Winter Weekday, lbs

Gp Source VOC NH3

2011 2017 2026 2011 2017 2026

PT1 MAJOR 2,219 5,128 5,193 265 265 265

PT2 MINOR 266 2,076 2,527 0 0 1

NP RWC

- FP 4,386 4,333 4,254 418 413 405

NP RWC

- U 22,926 20,994 19,236 735 673 617

NP RWC

- C 5,076 5,914 7,155 359 420 510

NP RWC

- PL 1 1 1 6 7 9

NP RWC

- LG 452 464 487 0 0 0

NP FUEL 217 234 257 766 823 906

NP COOK 143 150 169 0 0 0

NP ARCH 2,721 2,868 3,216 0 0 0

NP SURF 4,765 5,023 5,633 0 0 0

NP SOLV 12,179 12,837 14,397 0 0 0

NP GAS_STN 1,105 1,172 1,383 0 0 0

NP GAS_CANS 1,629 1,717 1,813 0 0 0

NP FERT 0 0 0 3 3 3

NP LIVE 0 0 0 0 0 0

OR ONRD 33,198 20,303 11,977 973 746 645

NR COMM 1,010 722 791 0 0 0

NR CNSTR 1,161 881 731 0 0 0

NR IND 175 64 51 0 0 0

NR LAWN 3,913 3,928 4,458 0 0 0

NR RAIL 1 1 1 0 0 0

NR RR 91 66 42 0 0 0

NR PORT 136 133 108 0 0 0

NR OCEAN 72 91 119 0 0 0

NR HARB 31 33 36 0 0 0

NR BOAT 46 30 17 0 0 0

TOTAL 97,920 89,161 84,051 3,525 3,351 3,361

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 7 Table 4 : PM

2.5 

## , SO 2 

## , and NO X 

## Emissions, Annual, tons

Gp Source PM2.5 SO2 NOx

2011 2017 2026 2011 2017 2026 2011 2017 2026

PT1 MAJOR 240 354 337 360 673 673 1,180 1,344 1,339

PT2 MINOR 0 10 10 0 47 47 0 55 57

NP RWC

- FP 254 251 246 4 4 4 28 28 27

NP RWC

- U 613 561 514 8 7 7 56 51 47

NP RWC

- C 297 344 413 7 9 11 41 48 58

NP RWC

- PL 3 3 4 0 0 0 3 4 5

NP RWC

- LG 15 15 16 0 0 0 4 4 4

NP FUEL 4 4 5 56 60 66 311 335 368

NP COOK 181 191 214 0 0 0 0 0 0

NP DUST_CNST 114 126 130 0 0 0 0 0 0

NP DUST_PAV 209 224 237 0 0 0 0 0 0

NP DUST_RR 20 11 63 0 0 0 0 0 0

OR ONRD 359 229 150 44 40 37 10,697 6,377 3,458

NR COMM 12 10 8 0 0 0 157 120 99

NR CNSTR 140 85 34 4 1 1 1,582 981 529

NR IND 11 5 3 1 0 0 204 114 108

NR LAWN 48 51 56 1 1 1 226 165 166

NR RAIL 0 0 0 0 0 0 1 1 0

NR RR 8 6 3 2 0 0 294 249 174

NR PORT 22 24 26 217 274 357 456 502 488

NR OCEAN 28 6 8 529 25 33 417 499 651

NR HARB 6 6 5 0 0 0 160 149 135

NR BOAT 1 0 0 0 0 0 14 14 13

TOTAL 2,585 2,518 2,485 1,234 1,143 1,239 15,833 11,041 7,728

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 8 Table 5 : VOC and NH 3 

## Emissions, Annual, tons

Gp Source VOC NH3

2011 2017 2026 2011 2017 2026

PT1 MAJOR 405 936 948 48 48 48

PT2 MINOR 49 379 461 0 0 0

NP RWC

- FP 203 201 197 19 19 19

NP RWC

- U 1,062 972 891 34 31 29

NP RWC

- C 235 274 331 17 19 24

NP RWC

- PL 0 0 0 0 0 0

NP RWC

- LG 21 21 23 0 0 0

NP FUEL 18 19 21 63 67 74

NP COOK 27 28 31 0 0 0

NP ARCH 629 663 743 0 0 0

NP SURF 760 801 898 0 0 0

NP SOLV 2,265 2,388 2,678 0 0 0

NP GAS_STN 216 229 255 0 0 0

NP GAS_CANS 303 320 338 0 0 0

NP FERT 0 0 0 8 8 8

NP LIVE 0 0 0 0 0 0

OR ONRD 5,058 3,114 1,938 184 142 123

NR COMM 167 118 129 0 0 0

NR CNSTR 223 169 140 0 0 0

NR IND 35 13 11 0 0 0

NR LAWN 918 765 852 0 0 0

NR RAIL 0 0 0 0 0 0

NR RR 17 12 8 0 0 0

NR PORT 25 24 20 0 0 0

NR OCEAN 13 17 22 0 0 0

NR HARB 6 6 7 0 0 0

NR BOAT 58 33 17 0 0 0

TOTAL 12,711 11,502 10,957 374 336 325



## 3 Inventory Development

3.1 General Information

Ecology developed nonattainment area inventor ies of emissions for attainment year 20 11 and

projection year s 201 7 and 2026 . The inventory includes a nnual a nd typical winter day emissions

estimates of PM 2.5 

## , N O X

, 

## SO 2 

## , VOC, and NH 3



## .

A list of sources was developed using the 20 11 National Emissions Inventory ( NEI ) , local

knowledge, and categories as defined in the 2005 Emissions Inventory Guidance for

Implementation of Ozone and Particulate Matter National Ambient Air Quality Standards

(NAAQS) and Regional Haze Regulations. 1 

## The list of sources is in Appendix A 1

– National

Emissions Inventory Source Categories

. We used t he guidance to select esti m ation methods and

gather ed information necessary to develop the attainment year and projection inventor ies

.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 9 Temporal Allocation

Past exceedances of th e 24

- hour PM 2.5 

## standard occurred primarily during cold days in the

months of October through March. The design day temperature profile calculated for the SIP

revision 2008 base year inventory was used for the maintenance plan inventories. The profile is

representa tive of a cold, winter

- like day. It was based on temperatures measur ed on days

between Jan uary 1, 2006 and December 31, 2010 when daily fine particle concentrations

exceeded 25 μg/m 3



## .

Figure 2 : Design Day Temperature P rofile

Table 6 : Design Day Temperature Profile in Fahrenheit

Hour 0 1 2 3 4 5 6 7 8 9 10 11

Temperature 28 27 27 28 28 28 29 29 30 33 36 41

Hour 12 13 14 15 16 17 18 19 20 21 22 23

Temperature 43 45 46 45 41 37 34 34 34 32 32 32



## The temperature profile was used to calculate residential wood combustion, onroad mobile, and

some nonroad mobile source emissions. For other sources, winter weekday emissions were

calculated from annual emissions using temporal allocation profile s. Methods for each category

are described beginning in Section 3.2

.

Spatial Allocation

Em issions were calculated for the nonattainment area. For sour ces without specific coordinates

where emissions were initially calculated at the county level, spatial surrogates were used to

approximate both the location and magnitude of the emissions. Many of the surrogates are the

same as or similar to the surrogates used in the Pacific Northwest's air quality prediction model,

AIRPACT. Surrogates were allocated to the nonattainment area using GIS tools and scripts.

Each emissions source was assigned to an appropriate surrogate.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 10 Nonattainment Area emissions were estimated as:

E NAA 

## = E County 

## * Surrogate NAA 

## / Surrogate County



## Where E NAA 

## = emissions in the Nonattainment Area

E County 

## = emissions in county

Surrogate NAA 

## = surrogate activity in the NAA

Surrogate County 

## = surrogate activity in county.

Demographics

, Empl oyment

, and Vehicle Miles Traveled Surrogates

Demographic, employment, road length

, vehicle miles traveled ( VMT ) , and vehicle population

data are used in emissions calculations for several source categories. Vehicle population for

2011 was calculated as d escribed in Section 3.6.2

. PSRC provided the demographic,

employment, VMT, and road length data for Pierce County and the Nonattainment Area

. 2



## Table 7 : Demographic, Employment , and V ehicle Statistics with Growth from 20 11 Factors

Area 20 11 201 7 20 26

Value Value Growth Value Growth

Population

Pierce County 802,150 860,030 1.07 964,204 1.20

Pierce NAA 538,328 568,690 1.06 632,857 1.18

NAA/County ratio 0.67 0.66 0.66

Households

Pierce County 301,429 327,624 1.09 363,150 1.20

Pierce NAA 208,398 223,174 1.07 245,823 1.18

NAA/County ratio 0.69 0.68 0.68

Total Employment

Pierce County 316,777 351,060 1.11 395,106 1.25

Pierce NAA 209,798 230,101 1.10 260,043 1.24

NAA/County ratio 0.66 0.66 0.66

Construction Employment

Pierce County 19,101 20,827 1.09 21,528 1.13

Pierce NAA 11,862 12,352 1.04 12,966 1.09

NAA/County ratio 0.62 0.59 0.60

Road Length in Miles

Pierce County 3990.3 4083.7 1.02 4082 1.02

Pierce NAA 2,117 2,195 1.04 2,195 1.04

NAA/County ratio 0.53 0.54 0

. 54

Vehicle Miles Traveled

Pierce County 16,703,154 17,951,838 1.07 18,957,391 1.13

Pierce NAA 10,537,561 11,272,898 1.07 11,854,377 1.12

NAA/County ratio 0.63 0.63 0.63

Vehicle Population

Pierce County 645,639 685,561 1.06 745,445 1.15

Pierce NAA 407,316 430,853 1.06 466,158 1.14

NAA/County ratio 0.63 0.63 0.63

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 11 Land Use and Land Cover Surrogates

Land use and land cover were used to spatially allocate county emissions from several source

categories to the nonattainment area. The Environmental Protection Agency's Office of

Information, Resources Management land use/cover data (LULC , published 1994 ), and the U.S

. Geological Survey' s National Land Cover Database (NLCD , published 1999) were used.

Table 8 : Land Use and Land Cover in Acres

Land Use/Cover type Source Pierce Co. NAA NAA/County ratio

Confined Animal Feeding Operations LULC

code 23 205 0 0

Urban Land Use NLCD

codes 21

- 23 96

, 965 64

, 764 0.67

Agricultural Land Use NLCD

codes 81

- 84 29

, 841 5

, 331 0.18

Open Water NLCD

code 11 3,371 87,781 0.04



## Inventory Tasks

To estimate emissions, f

our basic tasks were completed for each source category. The f o ur tasks

were: 1) estimate the activity level, 2) adjust/allocate the activity level (or emissions) temporally

and spatially, 3) determine emission factors ( rates ) per the activity, and 4) estima te emissions.

The tasks are described below for each source category. T he summary of emissions estimates

can be found in Section 2

.

3.2 Point Sources

Industrial, com mercial or institutional stationary sources which emit criteria and/or hazardous air

pollutants are called point sources. Ma jor point sources are those with the potential to emit 100

tons per year or more of any one criteria pollutant (carbon monoxide, volatile organic

compounds, sulfur dioxide, nitrogen oxides, lead, and particulate matter) or a combination of

criteria pollutants, and/or point sources with the potential to emit 10 tons per year or more of any

single Hazardous Air Pollu tant, or 25 tons per year or more of a combination of Hazardous Air

Pollutants (Section 112, CAA). Facilities with a major source potential

- to

- emit are included in

Title V Air Operating Permit (AOP) programs unless a facility voluntarily adopts federally

enforceable permit limits that reduce their potential

- to

- emit below the criteria and HAPs

thresholds.

For nonattainment areas, the federal Clean Air Act defines point sources as any stationary source

having the potential to emit 100 tons per year of a cr iteria pollutant. There are eleven of these

sources in the nonattainment area , discussed here as major point sources

.

Simpson Tacoma Kraft (STK) is the only major point source in E cology’s jurisdiction. The ten

other major point sources in the nonattainment area fall within the Puget Sound Clean Air

A gency’s (PSCAA) jurisdiction.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 12 For a more thorough inventory, all sources registered with PSCAA that returned inventories were

included , even if they were not major point s ources

. These sources ar e referred to as minor

stationary sources and their emissions will be inc luded in this section of the EI documentation.

In summary Tables 1, 2, 3, 4, and 5 in the introduction section of this document they are listed

separately under PT2

– Minor.

PSCAA r egisters sources that could potentially emit at least:

1) 2 tons of any single hazardous air pollutant ;

2) 6 tons of total HAPs ; and

3) 25 tons of carbon monoxide, nitrogen oxides, particulate matter, sulfur dioxides, or

volatile organic compounds.

Sixteen of thes e sources submitted emission inventory reports to PSCAA and are reported here

. The emissions reported by these sources may be less than the requir ed reporting limits listed

above

.

Activity Level

Individual facility throughputs and production rates deter mine the activity level for each facility.

Spatial and Temporal Allocation

Point sources are located by county, address and coordinates. Throughput and emissions were

assumed uniform throu ghout the year and 25% of the annual total was assigned to each season.

Emission Rates and Estimates

Emissions estimates for each facility are calculated using a variety of emissions estimation

methods: continuous emissions monitors, stack test data, mass balance, bes t professional

judgment, manufacturer’s specifications, speciation profiles, EPA emission factors (e.g., AP

- 42),

and/or other state, manufacturer, or research group emission factors. Methods are selected

considering permit conditions, data availability, a nd resource constraints.

PSCAA Sources

For the 2011 inventory, Ec ology utilized the 2011 emissions provided by PSCAA for the sources

within their jurisdiction. One source, Graymont Western US Inc, changed their PM 2.5 

## emission

calculation process which re sulted in higher emission rates of PM 2.5 

## in 2012. Therefore, 2012

emissions were used for 2011 since the source felt that these were more accurate than the 2011

numbers.

There were seven sources that calculated only PM 10 

## emissions for their facilities. In these cases,

PM 2.5 

## was assumed to be equal to PM 10 

## . These sources are: Carauster Mill Group Inc; Feed

Commodities LLC; Frederickson Power; Simpson Lumber; Tucci & Sons Inc , McChord; Tucci

& Sons Inc , Taylor Way; and US Oil & Refining.

In addition, P SCAA only requires sources to submit an emissions inventory if the source exceeds

the thresholds for which a source would be required to obtain a registration with PSCAA. Those

thresholds are listed above.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 13 Since a facility is not required to submit an EI unless they are emitting above these amounts,

even i f there are no 2011 emissions reported for a facility in Table 9 , that facility could still be

emitting pollutants . Those emissions would be below the thresholds listed above but since there

was no emissions inventory submitted, there is no way to know wh at the facility emitted that

year. Therefore, if there is a zero in Table 9 for 2011, assume that the pollutant was unreported

but may have emitted that pollutant at a level below the registration thresholds. Using zero

emissions for these sources in the 2011 inventory is a conservative assumption because these

sources were all given non

- zero emissions for the future year inventories (see Table 9 below).

E cology So urces

Data for Simpson Tacoma Kraft was taken from the facility’s 2011 inventory. The facility

calculated additional PM 2.5 

## emissions that are needed for the inventory but which they are not

requi red by their permit to calculate

.

2011 emissions are shown in Table 9 : Point Source Emissions and Projections ( tons per year )

.

Emissions Projections

The projection inventories were calculated using the five year max for Simpson Tacoma Kraft,

unless the facility suggested an alternate projection based on expected facility changes

.

For PSCAA sources, facility projections were determined by PSCAA engineers through

c onsultation with the facility, engineering knowledge , or using the 10 year maximum emission

for each pollutant.

Projection emissions are shown in Table 9

.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 14 Table 9 : Point Source Emissions and Projections ( tons per year

)

Facility and Pollutant 2011

(tons) 2017

Projection

(tons) 2026

Projection

(tons) Major?

Arclin Surfaces, LLC X

VOC 11.55 34.64 75.16

Boeing Commercial Airplane, Frederickson X

NOX 0.00 15.12 12.98

PM2.5 0.00 4.25 4.25

SO2 0.00 0.16 0.16

VOC 60.86 74.07 80.15

Caraustar Mill Group Inc Tacoma Paperboard

NOX 0.00 43.09 45.03

PM2.5 0.00 2.16 2.16

SO2 0.00 47.14 47.14

Delta Prefinishing Corp

VOC 5.96 7.10 7.69

Feed Commodities LLC

NOX 0.00 1.83 1.83

PM2.5 0.00 5.00 5.00

SO2 0.00 0.01 0.01

VOC 0.00 126.81 126.81

Frederickson Power LP X

NOX 12.00 43.00 43.00

PM2.5 9.60 38.10 38.10

SO2 0.60 2.30 2.30

VOC 4.50 17.70 17.70

General Plastics Manufacturing Co

VOC 1.32 2.63 3.29

Georgia

- Pacific Gypsum LLC X

NOX 24.87 29.84 29.84

PM2.5 25.95 31.13 31.13

VOC 0.00 0.00 0.00

Graymont Western US Inc X

NOX 58.07 58.07 58.07

PM2.5 80.26 80.26 80.26

SO2 5.35 5.35 5.35

VOC 2.61 2.61 2.61

IDX

- Seattle

VOC 0.00 30.72 30.72

James Hardie Building Products Inc

VOC 5.59 11.18 22.36

Jet Door LLC

VOC 0.00 3.95 3.95

Lianga Pacific Inc

NH3 0.03 0.06 0.11

VOC 33.37 109.71 176.45

Milgard Manufacturing Inc

VOC 0.00 0.00 0.00

Parker Paint Manufacturing Co Inc Professional Paint

VOC 0.00 2.25 3.94

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 15

Facility and Pollutant 2011

(tons) 2017

Projection

(tons) 2026

Projection

(tons) Major?

Professional Coatings Inc X

VOC 58.94 117.89 117.89

Puget Sound Energy, Frederickson X

NOX 0.00 23.49 23.49

PM2.5 0.00 1.43 1.43

SO2 0.00 4.18 4.18

VOC 0.00 0.28 0.28

Rainier Richlite Co

VOC 2.26 6.79 8.15

Shore Terminals LLC

VOC 0.00 33.75 33.75

Sierra Pacific Industries X

NOX 0.00 4.80 4.80

PM2.5 0.00 16.00 16.00

SO2 0.00 1.60 1.60

VOC 0.00 241.00 241.00

Simpson Lumber Company, LLC X

NOX 6.42 12.10 9.64

PM2.5 22.19 50.10 33.29

SO2 0.07 0.10 0.11

VOC 39.00 98.45 58.50

Simpson Tacoma Kraft X

NH3 6.00 6.00 6.00

NOX 945.00 1013.00 1013.00

PM2.5 89.40 106.80 106.80

SO2 349.00 648.30 648.30

VOC 77.00 104.00 104.00

Tacoma Fixture Co Inc

VOC 0.00 40.36 40.36

Toray Composites America Inc X

VOC 35.80 56.12 61.17

Tucci & Sons Inc McChord

NOX 0.00 4.48 4.48

PM2.5 0.00 1.23 1.23

Tucci & Sons Inc Taylor Way

NOX 0.00 5.90 5.90

PM2.5 0.00 1.62 1.62

US Oil & Refining Co X

NH3 42.35 42.45 42.45

NOX 133.75 144.35 144.35

PM2.5 12.30 26.07 26.07

SO2 4.89 10.70 10.70

VOC 114.69 189.20 189.20

Westmark Products Inc

VOC 0.00 3.62 3.62

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 16 3.3 Minor Stationary Sources Inventoried as Point Sources

PSCAA inventoried minor stationary sources. Sources are required to report emissions from any

criteria pollutant that equals or exceeds 25 tons per year. 3 

## Minor stationary sources may report

emissions for less than this threshold. For more discussion on this refer to Section 3.2

. All

reported emissions of PM 2.5 

## , NO X 

## , SO 2 

## , NH 3 

## and VOC s a re included in this inventory (s ee Table

9 ).

Minor stationary source projections were performed in the same way that major source

projections were calculated, please refer to 3.2 Point Sources , Emissions Projections.

3.4 Nonpoint Source s

Nonpoint sources include a variety of sources such as residential wood combustion, solvent

usage , and road dust. Nonpoint source emissions are typically estimate d by multiplying an

activity level by an emission factor in mass per activity.

Emissions = Activity level x Emission Factor

E missions estimation methods and data sources for each nonpoint source category are described

in the sub

- sections below.

3.4.1 Residential Wood Combustion

Residential wood combustion emissions were estimated using local survey data, EPA emission

factors, local wood

- burning device sales data, local change

- out program statistics , and other local

control program data

.

Activity Level

– Base Year 2008

The SIP revision base year 2008 inventory was the starting point for estimating 2011, 2017, and

2026 emissions. The 2008 inventory was updated to reflect a revised number of household s

estimate. 2 

## Residential wood combustion activity was estimated using data from a residential

wood combustion survey of 1,015 households conducted in the central Puget Sound area in 2007

(NRC2007). 4

, 5 

## This survey is the most recent and comprehensive survey conducted in the area,

and it solicited complete information to conduct an inventory

.

The survey was used to determine the percentage of households using wood burning devices and

the annual amou nt of wood burned per device for fireplaces, woodstoves, inserts, and pellet

stoves. Woodstoves and inserts were further broken out into three categories: certified catalytic,

certified non

- catalytic, and non

- certified.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 17 The survey included seven geograph ic groups. Three of the groups were used in this inventory :

Pierce Co. Urban Growth Area ( UGA ) , Pierce Co. Non

- Urban Growth Area ( NUGA ) , and King

County ( KING). The Pierce Co. Urban Growth area survey responses were used to derive most

of the activity parameters for the Nonattainment Area (NAA) . Parameters with low numbers of

data points (e.g., fire logs burned in a certified insert) were estimated by combining geographic

areas to get more data points. The split between catalytic and non

- cata lytic certified inserts and

woodstoves was made using the professional judgment of air quality and industry staff

. 6



## Because it was useful in the calculations, the county attainment area (AA) is included in some of

the tables below.

The survey gathered information on the amount of pellets, presto logs and cord wood burned

. To

calculate emissions using emission factors in lbs/ton burned, the weight of the wood burned was

estimated. The weight of a cord of wood varies with moisture content and species t ype. The

most common species reported in the survey were fir, alder, and maple. PSCAA estimated the

bone dry (zero percent moisture) weight of a cord to be 2189 lbs. Pellets are sold in 40

- lb sacks,

and fire logs were estimated at 8 lbs per log.

Annual emissions for each wood burning device were calculated according to the following

equation:

T/yr

= (HH) x (usage fraction) x (T burned/device

- yr) x (pollutant lbs /T) x (T/2000 lbs)

Where HH = number of households in the geographic area

T = tons



## The numbers of households in each of the three geographic areas were estimated by the Puget

Sound Regional Council (PSRC). The EPA data source is reference 9

. All of the other

parameter sources and values are described in the tables below.

Table 10 : Woodstove Parameter Data Sources, Base Year 2008

Parameter Fireplaces Inserts Woodstoves Pellet stoves

Pierce NAA

Own device (%) UGA UGA UGA UGA

Use device (%) UGA UGA+NUGA UGA UGA+NUGA+KING

Certified (% of devices used) n/a UGA+NUGA UGA n/a

Certified n on

- catalytic / catalytic split (%) n/a EPA EPA n/a

Cord wood burned UGA UGA+NUGA UGA n/a

Pellets burned n/a n/a n/a Entire survey

Fire logs burned UGA UGA+NUGA UGA n/a

Pierce AA

Own device (%) NUGA NUGA NUGA NUGA

Use device (%) NUGA NUGA NUGA UGA+NUGA+KING

Certified (% of devices used) n/a NUGA NUGA n/a

Certified non

- catalytic / catalytic split (%) n/a EPA EPA n/a

Cord wood burned NUGA NUGA NUGA n/a

Pellets burned n/a n/a n/a Entire Survey

Fire logs burned NUGA NUGA NUGA n/a

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 18 Table 11 : Woodstove Parameter Values, Base Year 2008

Parameter Fireplaces Inserts Woodstoves Pellet stoves

Pierce NAA

Own device (%) 16 7 16 2

Use device (%) 10.8 4.8 14.7 1.1

Certified (% of devices used) n/a 70 36 n/a

Certified non

- catalytic / catalytic split (%) n/a 75 / 25 75 / 25 n/a

Cord wood burned (tons) 1.0 1.8 1.9 n/a

Pellets burned (tons) n/a n/a n/a 0.7

Fire logs burned (tons) 0.01 0.03 0.01 n/a

Pierce AA

Own device (%) 19 11 11 2

Use device (%) 10.0 9.3 8.0 1.1

Certified (% of devices used) n/a 91 50 n/a

Certified non

- catalytic / catalytic split (%) n/a 8 7

. 5 / 1 2

. 5 8 7

. 5 / 1 2

. 5 n/a

Cord wood burned (tons) 0.9 2.0 1.1 n/a

Pellets burned (tons) n/a n/a n/a 0.7

Fire logs burned (tons) 0.01 0.01 0.03 n/a



## Activity Level

– Attainment Year 2011, and Projection Years 2017 and 2026

Activity was projected to each of the three inventory years using number of households, a nn ual

woodstove sales data, professional judgment, and PSCAA's Nonattainment Area woodstove

change

- out program statistics. PSRC provided estimated households for the Nonattainment Area

for 2011, 2017 and 2026

.

The Department of Revenue tracks wood burning device sales. The county of sale and out

- of

state sales are trac ked. 7 

## Pierce County sales plus a proportional fraction of the out

- of

- state sales

were used as the Pierce County total sales (see equation below) . Total sales from 2009 to 2011

were used to calculate the number of new devices from the base year 200 8 to 2011. For 2017

and 2026, total sales f

rom 2006 to 201 2 were used to calculate a n average annual sale s rate of

1,014 devices per year . The sales rate was multiplied by the number of years between the

inventory year and the base year (i.e., inventory year

– 2008) to calculate total new sales.

Total Pierce Sales Equation :

Total Pie r ce Sales = Sales PIERCE 

## + [ Sales OUT 

## x Sales PIERCE 

## / (Sales PIERCE 

## + Sales OTHER 

## ) ]

Where Sales OUT 

## = Out of state sales to WA

Sales PIERCE 

## = Pierce County sales

Sales OTHER 

## = All Other Counties sales

The sales were split among the Nonattainment Area and the rest of the county according to the

number of households in each area in the projection year. This was acceptable since the fraction

of households using devices was about the same for each area in the base year.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 19 Table 12 : Solid Fuel Burning Devi ce Sales, Number of Devices, 2006

- 2012

Area 2006 2007 2008 2009 2010 2011 2012 Average

All Other Counties 8,132 8,163 8,828 7,457 6,640 5,669 5,148

Pierce County 874 1,164 994 909 1,022 730 786

Out of State to WA 390 421 420 828 949 995 1,183

Total 9,396 9,748 10,242 9,194 8,611 7,394 7,117

Estimated Pierce p ortion of out of s tate sales to WA

38 53 43 90 127 114 157

Sum of Pierce sales plus out of state sales to WA portion

912 1,217 1,037 999 1,149 844 943 1,104



## Table 13 : New Sales from 200 9 to 2011, 2017, and 2026

Area 200 9

- 2011 200 9

- 201 7 200 9

- 20 26

Pierce NAA 2,025 6,220 12,347

Pierce AA 966 2,907 5,907



## The new sales were split into three groups for each of the three survey areas: catalytic inserts &

woodstoves (10%), non

- catalytic inserts & woodstoves (70%), and pellet stoves (20%), based on

professional judgment. 8 

## The 2008 base year inventory was updated to reflect the catalytic vs.

non

- catalytic split. The inserts & woodstoves group was split among inserts and woodstoves

based on t he 200 8 split of these device types for each area

.

Other assumptions are listed below, based on professional judgment 8 

## and PSCAA's woodstove

change

- out program:

 1/3 of woodstove and pellet stove sales are replacements of existing equipment

 2/3 of woodstove and pellet stove sales are new installations

 1/3 of i nsert sales are replacements of existing equipment

 1/3 of insert sales are installed in existing open fireplaces

 1/3 of insert sales are new installations

 621 devices in the Nonattainment Area were changed from wood to gas/electric from

200 8

- 2011. These w ere subtracted from uncertified devices for the 2011 attainment

inventory

.

 An estimated 849 devices in the Nonattainment Area were changed from wood to

gas/electric from 2008

- 7/2/2013 (date of data acquisition for this inventory). Funding

was secured to c hange out an additional 1,100 devices during 2014

- 2015. Based on

change out statistics from 2008

- 2013, it was estimated that 41 % or 455 of the 1,100

devices would be changed to gas/electric. Devices changed to gas/electric were

subtracted from uncertif

ied devices for the 2017 and 2026 projection inventories

.

 Due to lack of information on fireplaces, assumed none of the new sales were fireplaces.

 All replacement devices were assumed to replace uncertified devices.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 20 Table 14 : Number of Devices Used and Tons Burned

Parameter Pierce NAA Pierce AA

Devices Tons Devices Tons

Base Year 2008

Fireplace 22,226 21,624 9,058 8,389

Fireplace inserts; non

- EPA certified 2,915 5,337 769 1,553

Fireplace inserts; EPA certified; non

- catalytic 5,213 9,546 5,764 11,647

Fireplace inserts; EPA certified; catalytic 1,738 3,182 1,921 3,882

Woodstove; non

- EPA certified 19,287 36,942 3,623 3,966

Woodstove; EPA certified, non

- catalytic 8,266 15,832 2,717 2,974

Woodstove; EPA certified, catalytic 2,755 5,277 906 991

Pellet Stove 2,200 1,613 986 723

Residential Firelog Total: All Combustor Types 1,051 387

Total 64,600 100,404 25,745 34,513

Attainment Year 2011

Fireplace 22,092 21,493 8,927 21,493

Fireplace inserts; non

- EPA certified 2,699 4,943 637 4,943

Fireplace inserts; EPA certified; non

- catalytic 5,565 10,190 6,109 10,190

Fireplace inserts; EPA certified; catalytic 1,788 3,274 1,971 3,274

Woodstove; non

- EPA certified 18,336 35,120 3,511 35,120

Woodstove; EPA certified, non

- catalytic 9,358 17,924 3,016 17,924

Woodstove; EPA certified, catalytic 2,911 5,576 948 5,576

Pellet Stove 2,477 1,816 1,110 1,816

Residential Firelog Total: All Combustor Types 1,059 1,059

Total 65,226 101,395 26,229 101,395

Projection Year 2017

Fireplace 21,823 21,232 8,645 8,006

Fireplace inserts; non

- EPA certified 2,340 4,286 355 717

Fireplace inserts; EPA certified; non

- catalytic 6,271 11,483 6,850 13,841

Fireplace inserts; EPA certified; catalytic 1,889 3,459 2,077 4,196

Woodstove; non

- EPA certified 16,916 32,400 3,269 3,578

Woodstove; EPA certified, non

- catalytic 11,549 22,121 3,658 4,003

Woodstove; EPA certified, catalytic 3,224 6,176 1,040 1,138

Pellet Stove 3,033 2,224 1,376 1,009

Residential Firelog Total: All Combustor Types 1,085 414

Total 67,046 104,465 27,269 36,902

Projection Year 2026

Fireplace 21,425 20,844 8,220 7,613

* Fireplace inserts; non

- EPA certified 1,942 3,557 0 0

* Fireplace inserts; EPA certified; non

- catalytic 7,316 13,396 7,895 15,953

Fireplace inserts; EPA certified; catalytic 2,038 3,732 2,236 4,518

Woodstove; non

- EPA certified 15,693 30,058 2,905 3,179

Woodstove; EPA certified, non

- catalytic 14,791 28,331 4,623 5,060

Woodstove; EPA certified, catalytic 3,688 7,063 1,178 1,289

Pellet Stove 3,856 2,827 1,777 1,302

Residential Firelog Total: All Combustor Types 1,140 442

Total 70,749 110,948 28,833 39,356

* In 2026, the calculated projected devices and tons burned in the Attainment Area were

- 70 and

- 141, respectively.

Since this cannot occur, the device and tons burned reductions were removed from the certified non

- catalytic inserts

instead.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 21 Emission Factors

Emission factors were taken from EPA's emission factor manual

, AP42

, and their residential

wood combustion tool. 9

, 10 

## Most of the factors in the tool are from A P42

, the Mid

- Atlantic

Regional Air Management Association ( MARAMA )

, or Environment Canada. Certified device

PM2.5 factors were calculated using annual Washington State woodstove sales data to weigh

emission factors in each standards class: pre

- Phase I, Phase I, and Phase II. The average of pre

Phase I and Phase I factors were assumed for s toves and inserts sol d during 1990

- 1992, and

Phase II factors were assumed for devices sold in 1993 and beyond. The last actual year of sales

data (2012) was one of the lowest years for sales. It was used to project future year sales for

calculating the emission factor, res ulting in a conservative (high) estimate.

Table 15 : Residential Wood

- burning Device Sales, Washington State

Inventory Year Sales Year s devices

All 1990

- 1992 36,567

2011 1993

- 2011 212,300

2017 1993

- 2017 256,700

2026 1993

- 2026 323,300



## Table 16 : Residential Wood Combustion Emission Factors in lbs/T Burned

Device PM 2.5



### NOX SO 2 

### VOC NH 3 

### Not Cert. or N/A pre

- Ph I Ph I Ph II

Fireplace 23.6 2.6 0.4 18.9 1.8

Inserts / Stoves, Not Cert 30.6 2.8 0.4 53 1.7

Inserts /S toves, Cert, non

- Cat. 25.8 20 .0 1 4.6 2.28 0.4 12 0.9

Inserts / Stoves, Cert, Cat. 24.2 19.6 16 .2 2 0.4 15 0.9

Pellet Stove 3.06 3.8 0.32 0.041 0.3

Residential Firelog: All 28.4 7.684 0 39.56 0



## Table 17 : Wtd. Average PM 2.5 

## Emission Factors for Certified Devices in lbs/T Burned

Year non

- Catalytic Catalytic

2011 16.0 17.2

2017 15.6 16.9

2026 15.4 16.8



## Temporal Allocation

Residential wood combustion emissions were calculated for the design day temperature profile

using a temperature adjustment equation based on heati ng degree days with a base of 50 degrees

(see Appendix A2

– Residential Wood Combustion Temperature Adjustment ). The temperature

adjustment eliminates the need for a monthly activity adjustment since the temperature

adjustment assumes activity is directly rel ated to temperature. The calculated daily emissions

were adjusted to weekday activity using AIRPACT temporal allocation profile 407, which was

calculated from the 2001 Washington State University woodstove survey. 11 

## The profile allocates

13.5 percent of a ctivity to each weekday.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 22 Spatial Allocation

Activity and emissions were calculated specifically for the Nonattainment Area

.

3.4.2 Paved Road Dust

Dust emissions are generated as vehicles pass along paved roadways and disturb the layer of

loose material on or near the road surface. This material contains particulate matter from soil,

brake and tire wear, exhaust, and other substances. However, t he paved road dust calculation

excludes emissions from exhaust and brake and tire wear which are estimated as part of the

onroad mobile sources emissions (see section 3.6 ). Paved road dust emissions were estimated

using vehicle miles traveled (VMT) activity from the Washington State Dept. of Transportation

(WSDOT) and the emission factor equation in AP

- 42.

Activity Level

Average daily VMT (ADVMT) based on the nationa l Department of Transportation’s Highway

Performance Monitoring System (HPMS) was obtained from WSDOT. WSDOT makes

estimates of county ADVMT by functional (roadway) classification from HPMS. 12 

## The HPMS

classifications available in the WSDOT data were help ful in applying the AP

- 42 emission factor

equation. Total Pierce County ADVMT from WSDOT was about 5 % higher t han the Puget

Sound Regional Council's (PSRC) travel demand model VMT estimate. The travel demand

model data was used to estimate onroad emissions , so there is a small inconsistency between the

VMT used for the paved road dust estimate and the onroad emissions estimates.

Table 18 : WSDOT 20 11 Pierce County ADVMT

Road Class Rural Urb an Total

Interstate 339,293 3,232,487 3,571,780

Other Freeway Expressway 0 2,757,282 2,757,282

Principle Arterial 0 3,911,320 3,911,320

Minor Arterial 649,373 3,331,841 3,981,214

Major Collector 203,903 1,133,785 1,337,688

Minor Collector 46,567 0 46,567

Local Roadway 93,268 1,775,665 1,868,933

Total 1,332,404 16,142,380 17,474,784

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 23 Emission Factors and Temporal Allocation

Monthly PM 2.5 

## emission rates in grams per mile were calculated using equation 2 in EPA's

AP42

. 13

, 14 

## Equation 2 estimates an emission rate for annual average conditions by incorporating

a precipitation correction factor. Daily winter emissions were calculated assuming no rainfall,

and therefore no precipitation adjustment (equation 2a)

.

E ext = [ k (sL )0.91 x (W)1.02 ] (1

– P /4 N ) equation (2)

E DAILY 

## = [ k (sL)0.91 x (W)1.02 ] equation (2a)

where E ext is the emission factor in g/VMT

k = g/VMT particle size multiplier (0.25 for PM 2.5 

## )

sL = silt loading in g/m 2



## W = mean vehicle weight (tons)

P = number of days with at least 0.01 inches of precipitation in the given month

N = number of days in the given month

EPA's AP42 recommended values for average silt loading by average daily traffic (ADT) class

were used. The HPMS facility types were classified into the ADT classes by dividing the

number of statewide ADVMT by the roadway mileage. The classifications are shown in Table

19

. Individual urban sampli ng areas are not shown in the table; however, with only minor

exceptions, they each showed the same ADT classification as the urban average.

Table 19 : WSDOT Statewide Estimated Average Daily Traffic, 20 11

Rural Interstate Free/ Expr Prin Art Min Art Maj Coll Min Coll Local

Miles 467 645 1,335 1,910 8,432 6,453 40,817

ADVMT (in 1,000s) 12,531 4,873 6,172 5,867 10,690 3,185 3,260

Estimated ADT 26,815 7,551 4,623 3,072 1,268 494 80

ADT Class > 10,000

limited access 5,000

- 10,000 500

- 5,000 500

- 5,000 500

- 5,000 < 500 < 500

silt loading (g/m 2 ) 0.015 0.06 0.2 0.2 0.2 0.6 0.6

Urban Interstate Free/Expr Prin Art Min Art Maj Coll Min Coll Local

Miles 297 377 1,355 2,684 2,431 0 16,540

ADVMT (in 1,000s) 29,788 14,416 24,122 20,737 8,376 0 12,051

Estimated ADT 100,320 38,273 17,804 7,727 3,446 0 729

ADT Class > 10,000

limited access 5,000

- 10,000 500

- 5,000 500

- 5,000 500

- 5,000 < 500 < 500

silt loading (g/m 2 ) 0.015 0.015 0.03 0.06 0.2 0.2 0.2



## Mean vehicle weight by road class was calculated from a Federal Highway Administration report

of in

- use operating weights and VMT by vehicle type and road class. 15



## Table 20 : Mean Vehicle Weight in Tons

Rural/Urban Interstate Free/Expr Prin Art Min Art Maj Coll Min Coll Local

Rural 5.71 5.71 3.80 3.16 2.74 2.62 2.49

Urban 3.27 2.56 2.51 2.26 2.18 2.18 2.14

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 24 Days per month of precipitation greater than 0.01 inches in 20 11 were obtained for SeaTac.

Table 21 : Days with Greater than 0.01 Inches of Precipitation

Month Days Month Days Month Days

01 20 05 16 09 8

02 15 06 13 10 18

03 25 07 8 11 16

04 23 08 2 12 13



## Monthly and day

- of

- week ADVMT adjustments were provided by WSDOT. 16 

## Weekday

adjustments are the average of Monday

- Friday adjustments.

Table 22 : WSDOT Monthly Adjustment Factors, 2008

Road Type Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Rural Interstate 0.77 0.85 0.93 1.00 1.03 1.12 1.22 1.24 1.10 1.03 0.89 0.83

Other Rural Arterial 0.77 0.86 0.9 0.95 1.04 1.12 1.25 1.26 1.11 1.03 0.84 0.79

Other Rural 0.72 0.77 0.82 0.87 1.05 1.23 1.42 1.36 1.20 1.01 0.84 0.71

Urban Interstate 0.92 0.97 0.99 1.01 1.06 0.99 0.98 0.98 0.99 0.95 0.91 0.91

Other Urban Arterial 0.92 0.95 0.98 1.01 1.06 1.07 1.06 1.07 1.03 1.00 0.93 0.93



## Table 23 : WSDOT Day

- of

- Week Adjustment Factors, 2008

Road Type Weekday

Rural Interstate 98.578

Other Rural Arterial 100.584

Other Rural 97.956

Urban Interstate 105.658

Other Urban Interstate 107.052



## Monthly emissions were calculated using the equation below

, w ith E from Equation 2 above.

Annual emissions were calculated by summing all months. Daily emissions were calculated

using the equati on below , with E from Equation 2a above (no precipitation), the January monthly

adjustment, and with D = 1.

V x T x D x E x (lb/454 g) x (T/2000 lbs)

- monthly emissions

where V = ADVMT

T = monthly VMT adjustment factor

D = number of days in month, and

E = emission factor in g/VMT

Spatial Allocation

Emissions were allocated to the Nonattainment Area using VMT as the surrogate as described in

Section 3.1 . Each inventory year's link

- level VMT were the surrogates ( Table 7 )

. The VMT wa s

provided by PSRC a nd is described more fully in Section 3.6

.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 25 Projected Emissions

Emissions for the projection years were estimated by multiplying the WSDOT ADVMT by

PSRC's county VMT growth factors (see Table 7 ) and using the emission factors calcu lated as

described above.

3.4.3 Petroleum Distribution

Emissions from fuel service stations res ult from evaporation of gasoline and gasoline vapors

during underground tank filling, underground tank breathing and emptying, and vehicle

refueling. Losses from fuel trucks in transit are also included here.

Also included in this section are diesel refueling emissions. This category was estimated by the

EPA and accepted by the Washington State Department of Ecology. The methodology behind

the estimation will be i ncluded in the 2011 NEI Technical Support Document 17 

## which is

currently in draft format.

The following information and data was taken from Ecology’s 2011 Comprehensive Emissions

Inventory and does not include the methodology for diesel refueling emission s

.

Activity Level

Activity data for gasoline distribution is gallons of gasoline distributed. This data was taken

from the 2011 Comprehensive emissions inventory prepared by Ecology. PSCAA did not report

gallons of gasoline from service stations in Pierce County . Gallons of gasoline w ere determined

using the equation below:

A nnual gallons , county = (County licensed vehicles/Total licensed vehicles in

Washington) x Total Gallons Gasoline sold in State

Table 24 : Gallons of Gasoline Sold in Pierce County

Licensed Vehicles in

Pierce County Total Licensed

Vehicles in WA Gallons Gasoline

Sold in WA Gallons of Gas Sold,

Pierce County

601,445 5,390, 474 2,601,564 ,000 290,270, 885



## Emission Factors

Refueling

To estimate the VOC emissions from refueling of gasoline, gasoline distributed in Pierce County

were multiplied by a VOC emission factor. The emission factor is in pounds per 1000 gallons of

gasoline, so the gallons of gasoline are shown reporte d as thousand gallons. Pierce County is

one of the six remaining counties in Washington that require Stage II vapor recovery at gas

stations. The EPA Mobile Vehicle Emission Simulator (MOVES) model was used to generate

VOC emiss ion factors for each seaso n for Pierce County , taking into account local details

including stage II vapor recovery requirements

.

Diesel refueling em issions were added to the refueling category in Table 2 7

.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 26 Table 25 : Pierce County VOC Refueling Emission s , Seasonal

Season Thousand Gallons of

Gas, Pierce County Emission Factor

(lb/1000 gal) Emissions (lbs) Emissions (tons)

Winter 65,818.45 .862 56,751.5 28.4

Spring 75,499.36 .827 62,472.8 31.2

Summer 77,530.82 .752 58,337.3 29.2

Fall 71,422.25 .652 46,551.5 23.3

Totals 224,113.1 112.1



## Underground Tank Filling, Breathing and Emptying, and Transit

Emission rates for underground tank filling, breathing and emptying, and transit losses were taken

from documentation released by the EPA for gasoline distribution for the 2011 National Emissions

Inventory (NEI). Emission factors for these categories do not vary by season.

Table 26 : Pierce County VOC Gasoline Distribution Emissions, Annual

Category Thousand Gallons of

Gas, Pierce County Emission Factor

(lb/1000 gal) Emissions (lbs) Emissions (tons)

Underground Tank

Filling 290,270. 885 .3 87

, 081.3 43.5

Breathing and

Emptying 290,270. 885 1 290

, 270.9 145.1

Transit 290,270. 885

. 0 6 17,416.3 8.7



## Temporal Allocation

As dis cussed above, MOVES output was generated by season. A temporal allocation was

determined using the ratio of gallons used per season to what was used per year. The ratio for

the winter season was approximately 23% in Pierce County. To temporally allocate the

emissions, the annual emissions were multiplied by 23% and then divided by the amount of days

in the season to determine winter weekday emissions for each category.

Table 27 : 2011 Pierce County VOC Gasoline Distribution Emissi ons, Winter Weekday

Category Annual Emission

(lbs) Temporal Allocation

Factor Winter Emissions

(lbs) Winter Weekday

Emissions (lbs)

Refueling 250,772.6 .23 57,677.7 640.9

Underground Tank

Filling 87,081.3 .23 20,028.7 222.5

Breathing and

Emptying 290,270.9 .23 66,762.3 741.8

Transit 17,416.3 .23 4,005.7 44.5



## Spatial Allocation

The nonattainment area population is 67 % of the population of Pierce County, as listed in Table

7 . In order to adjust the emissions to fit the area spatially, the winter weekday emissions of

Pie rce County were multiplied by 67 %.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 27 Table 28 : 2011 Nonattainment Area Winter Weekday VOC Gasoline Distribution Emissions

Category Winter

Weekday

Emissions ( lbs ) County: NAA

Ratio NAA Winter

Weekday

Emissions (lbs)

Vehicle Refueling (including

Diesel refueling) 64 0.9 .6 7 429.1

Underground Tank Filling 222.5 .6 7 146.9

Breathing and Emptying 741.8 .6 7 489.6

Transit 44.5 .6 7 29.4



## Projections

Ecology projected emissions from this category using population growth provided by PSRC in

Table 7

. Projected growth for 2017 and 2026 was 1.0 6 and 1.18, respectively.

Table 29 : Gasoline Distribution Nonattainment Area

, Winter Weekday VOC Projected

Emissions (lbs)

Category 2017 (Projected) 2026 (Projected)

Vehicle Refueling 455.1 537.1

Underground Tank Filling 158.0 186.5

Breathing_Emptying 526.8 621.7

Transit 31.6 37.3



## 3.4.4 Fugitive Dust Emissions from Coal Trains

Ecology is including information on coal dust generated by the transport of coal using trains

. Currently, there are proposed incre ases to the export of coal from the Seattle region.

Emission Factor and Spatial Allocation

Ecology estimated the tonnage of PM 2.5 

## from railroad transport for 2011 and pr ojections for 2017

and 2026

. The calculation s for the projected years assume all p roposed coal exporting will occur

as well as that expansions at Canadian facilities will allow more coal to be exported through the

Seattle region. A n equation from a study done of coal dust emissions in Canada 18 

## was used to

determine a Total Suspended Particulate (TSP) emission factor. This equation includes a spatial

comp onent (SD) that allocates the emission factor to the Nonattainment Area.

TSP Emissions Factor (kg/ 27 one )

= 0.1*(0.62*D) * 0.6 *(365

- P)/365 *(SD/D)*(100

- CE)/100

Where:

D = total distance travelled by rail cars (km)

SD = r ail segment length estimation for NAA (km)

P = number of days in the year with measureable precipitation (rain and snow)

CE = Control efficiency of any applied dust control measures (%)

The TSP emission factor was then converted to pounds per ton from kilograms per tonne

. Please

note that the control efficiency increases sig nificantly in 2017 because of revised control

strategies impos ed by BNSF as of October 2011 in their Coal Loading Rule. 19

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 28 Table 30 : TSP Emission Factor for Annual Coal Train Fugitive Dust Emissions

Year D SD P CE TSP EF

(lb/ton)

2011 2414 40 177 21.25 .10803

2017 2414 40 156 85

. 02288

2026 2414 40 156 85

. 02288



## A PM 2.5 

## to TSP ratio taken from US EPA AP

- 42 20 

## of .075, the amount of coal exported/projected

to be escorted for the year , and the TSP emission factor are used to calculate the portion of the

TSP emissions that are PM 2.5 

## using the following equation :

PM 2.5 

## Emissions (annual) = Tons of Coal Exported for year * TSP Emission factor * PM 2.5 

## : TSP Ratio

Table 31 : Annual PM 2.5 

## Emissions from Coal Trains in tons

Year Tons of Coal

Exported/Projected for

Export Annual Tons of

PM2.5

2011 4, 863,661 19.70

2017 12,579,831 10.79

202 6 73,206,881 62.80



## The tons of coal exported in 2011 were available from the U.S. Energy Information

Administration (EIA) . The data is reported quarterly

.

Projected year totals of coal exported include the addition of coal exports from a facility in

Washington that is currently in the planning phases and plans to be fully operational by 2019

, 21



## as well as the continued exports from Canada that travel through the nonattainment area. The

totals from the Canadian facilities also include anticipated expansion s at those sites. 22

, 23

, 24



## Temporal Allocation

Winter weekday emissions were calculated for coal trains by recalculating the emissions for the

winter period. Winter is typically December, January, and February for emissions inventory

purposes . Data for these months is captured in both the first quarter (January, February, and

March) and the fourth quarter (October, November December) in EIA data . 2011 coal exports

for the winter season were calculated by dividing each of these quarters by three to get a monthly

average for that quarter. The amount of coal exported during the winter season was obtained by

summing two months of the first quarter with one month from the fourth qua rter. The

percentage of the coal that was exported in 2011 during the winter season was determined. The

winter percentage for 2011 was then multiplied by the annual total of the estimates of coal to be

shipped during 2017 and 2026 to estimate the amounts that would be shipped during the winter

season in those years.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 29 Another adjustment made to calculate the winter weekday was to use zero for the number of days

of precipitation. This allows the final emissions to model the worst conditions expected in

wi nter. The modified emission factor variables and resultant emission factor are listed in the

table below.

Table 32 : TSP Emission Factor for Winter Weekday Coal Train Fugitive Dust Emissions

Year D SD P CE TSP EF

(lb/ton)

2011 2414 40 0 21.25

. 20974

2017 2414 40 0 85 .03995

2026 2414 40 0 85 .03995



## PM2.5 Emissions were then calculated using the following equation to arrive at tons per winter

season for 2011, 2017, and 2026.

PM 2.5 

## Emissions (winter) =

Tons of Coal Exported for Winter season * TSP Emission factor * PM 2.5 

## : TSP Ratio

That number was then converted to winter weekday in pounds by multiplying the tons by the

amount of lbs per ton, 2000, and dividing by the number of days in the winter season, 90.

Table 33 : PM

2.5 

## Emissions from Coal Trains, Winter Weekday in pounds

Year Winter Weekday

Emissions (lbs)

2011 195.59

2017 96.36

20 26 560.75



## 3.4.5 N ational Emissions Inventory Categories

Every 3 years, EPA develops a National Emissions Inventory (NEI). EPA estimates emissions

for all nonpoint categories. State and local air agencies may either accept the EPA estimates or

submit their own. The final NEI is a combination of state/local an d EPA estimates. For the

categories listed below, estimates from version 1 of the 2011 NEI 25 

## were used in the maintenance

plan inventory.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 30 Table 34 : Other Nonpoint Source Categories and NEI Data Source

Category NEI Source

Residential Distillate Oil and Natural Gas Combustion Ecology

Construction Dust

- Roads, Commercial/Industrial/Institutional EPA

Commercial C ooking EPA

Gas Cans Ecology

Non

- Industrial Commercial and Consumer Solvents Ecology and EPA

Architectural Surfa ce Coating Ecology

Industrial Surface Coating Ecology and EPA

Livestock EPA

Fertilizer Ecology



## Temporal Allocation

Annual emissions were adjusted to winter (January) weekday activity using AIRPACT temporal

allocation profiles for month and day of week. Several of the profiles came from EPA emissions

modeling files. 26 

## The descriptions and category assignments are shown in the tables below.

Table 35 : Temporal Profiles, Month and Weekday

Profile Description Source

Month

262 Win=25.0%, Spr=25.0%, Sum=25.0%, Fal=25.0% (uniform) EPA

485 Win=57.0%, Spr=22.5%, Sum=1.5%, Fal=19.2% EPA

996 Win=3.7%, Spr=31.4%, Sum=28.1%, Fal=36.7% EPA

998 Win=8.7%, Spr=47.1%, Sum=22.2%, Fal=22.1% EPA

1500 Win=17.7%, Spr=25.5%, Sum=34.3%, Fal =22.6% EPA from Gilliland NH3 profile

4002 Win=21.1%, Spr=25.1%, Sum=30.6%, Fal=23.1% Architectural Coating 1996 Quarterly

Business review revenue

4015 Win=20.7%, Spr=24.3%, Sum=30.6%, Fal=24.0% EPA NONROAD2008 model for

Construction Equipment (SEASON.DAT)

9008 Win=2 4

. 0 %, Spr=2 6.3 %, Sum=2 5.3 %, Fal=24. 4 % 2008 WSDOT urban interstate traffic

counters

Weekd ay

6 Weekday average = 16.7% EPA

7 Weekday average = 1 4.3% (uniform) EPA

2004 Weekday average = 15.1% 2008 WSDOT urban interstate traffic

counters



## Table 36 : Other Nonpoint Sources

- Tempora l Allocation, Month and Weekday

Category Month Day Type

Residential Distillate Oil and Natural Gas Combustion 485 7

Construction Dust

- Roads, Commercial/Industrial /Institutional 4015 6

Commercial C ooking 262 6

Gas Cans

- Spillage, Refilling 9008 2004

Gas Cans

- Permeation, Evaporation 262 7

Non

- Industrial Commercial and Consumer Solvents 262 7

Architectural Surface Coating 4002 7

Industrial Surface Coating 262 6

Livestock 1500 7

Fertilizer 996 & 998 7

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 31 Temporal Allocation

– Additional Adjustments for Construction Dust

A further adjustment was made to construction dust to account for higher soil moisture values in

the winter. The NEI dust equations contains a multiplier of 24/PE where PE is the 30

- year

average precipitation

- evaporation value from Thornthwaite’s PE Index. PM 2.5 

## concentrations in

the Nonattainment Area greater than or equal to 25 ug/m 3 

## from 2001

- 2010 occurred du ring Oct

Feb with few exceptions. A variation of Thornwaite's precipitation

- evaporation equation

(below) was used to calculate PE by month using 10 years of temperature and precipitation

data 27 

## from the Tacoma Narrows meteorological station. The calculated monthly PE values for

Oct

- Feb were normalized to produce a 12 month PE value representative of the winter (i.e., the

high PM 2.5 

## values). The normal annual PE was divided by the winter PE to produce a moisture

adjustment factor (60%).

PE Equation

PE = ∑ 12 

## 115 [P/T

- 10] 10/9



## where P is average monthly precipitation (inches) with 0.5 being the minimum value

T is average monthly temperature (degrees F) with 28.4 ° F being the minimum

value use d in the calculation.

Table 37 : Tacoma Narrows Temperature ( ° F) and Precipitation (Inches), 1999

- 2008

Parameter Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Year

Temperature 41.8 43 45.7 49.7 55.1 60.3 64.8 64.8 59.9 52.7 45.5 41.5 52.1

Precipitation 7.16 3.64 4.11 2.48 1.84 1.49 0.54 1.02 1.09 3.5 6.92 5.98 39.76



## The calculated 60% adjustment was reasonable when compared to other information:

 PSCAA regulations specify no visible emissions

 Emissions Inventory Improvement Program estimation method applies 50% control to

PM Nonattainment Area s

 Western Regional Air Partnership and AP42 attribute 10%

- 74% control efficiency for

watering depending on schedule and operation

Spatial Allocation

T he county emissions in the NEI were allocated to the nonattainment area using spatial

surrogates as described in Section 3.1 . The surrogate for each category is sh own below.

Table 38 : Other Nonpoint Sources

- Spatial Surrogates

Category Surrogate

Residential Distillate Oil and Natural Gas Combustion PSRC households

Construction Dust

- Commercial/Industrial/Institutional NLCD urban lands

Construction Dust

- Roads PSRC road miles

Commercial C ooking PSRC Population

Gas Cans PSRC population

Non

- Industrial Commercial and Consumer Solvents PSRC population

Architectural Surface Coating PSRC population

Industrial Surface Coating , except Traffic Markings PSRC population

Industrial Surface Coating

- Traffic Markings PSRC road miles

Livestock LULC CAFOs

Fertilizer NLDC agricultural lands

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 32 Projected Emissions

Nonpoint projections were made using county growth factors for source activity s urrogates from

PSRC as described in Section 3.1

. Emissions were projected by multiplying the emission s from

the attainment year by growth factors for the surrogate activity. The surrogate for each category

is shown in Table 39 : Other Nonpoint Sources

- Projection Surrogates

Projected Emissions = Emission s attain. year 

## x Projection year growth factor surrogate activity



## Table 39 : Other Nonpoint Sources

- Projection Surrogates

Category Surrogate

Residential Distillate Oil and Natural Gas Combustion PSRC households

Construction Dust

- Roads, Commercial/Industrial/Institutional PSRC construction employment

Commercial C ooking PSRC Population

Gas Cans PSRC population

Non

- Industrial Commercial and Consumer Solvents PSRC population

Architectural Surface Coating PSRC population

Industrial Surface Coating , except Traffic Markings PSRC population

Industrial Surface Coating

- Traffic Markings PSRC road miles

Livestock Assumed constant

Fertilizer Assumed constant



## 3.5 Nonroad Mobile Sources

Nonroad mobile sour ces include all off

- road vehicles and equipment. Locomotives and marine

vessels are also included in the nonroad category.

3.5.1 Nonroad Mobile

, Except Locomotives, Marine, and Port Sources

The Nonroad Mobile category includes emissions estimates from gasoline, diesel, compressed

natural gas (CNG), and liquefied petroleum gas (LPG) fueled equipment. Emissions were

e stimated using EPA's NONROAD2008a model. 28 

## Equipment in six categories w as inventoried :

 Lawn and Garden Equipment

 Recreational Marine Vessels

 Con struction and Mining Equipment

 Commercial Equipment

 Railroad Maintenance Equipment

 Industrial Equipment

Temporal Allocation and Emission Rates

Emissions were generated for the four seasons using the seasonal te mporal option in the

NONROAD2008a model for 2 0 11 base year and 2017 and 2026 projection year s . The month of

January, both weekday and weekend, was also chosen to represent a typical winter day scenario

for each year as well (see Table 40 ). NONROAD2008a requires user input of seasonal

meteorological and fuel parameters. The required fuel parameters are gasoline RVP and oxygen

content; sulfur contents of gasoline, diesel (land and marine), and com pressed natural gas (CNG)

and liquefied petroleum gas (LPG); and presence of stage II vapor recovery requirements.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 33 Table 40 : NONROAD MODEL PARAMETERS

Year Month

or

Season Fuel

RVP O2

Wt.

% Gas

Sulfur

% Diesel

Sulfur

% Marine

Diesel

Sulfur

% CNG/

LPG

Sulfur

% Min

temp

(°F) Max

temp

(°F) Avg

Temp

(°F) EtOH

blend

mkt

% EtOH

vol %

2011 Jan uary 14.7 3.5 0.003 0.0032 0.0236 0.003 26 47 36 100 10

2011 Win 14.7 3.5 0.003 0.0032 0.0236 0.003 34 46 42 100 10

2011 Spr 12.7 3.5 0.003 0.0032 0.0236 0.003 41 58 52 100 10

2011 Sum 10 3.5 0.003 0.0032 0.0236 0.003 53 74 67 100 10

2011 Fal 10 3.5 0.003 0.0032 0.0236 0.003 46 62 57 100 10

2017 Jan 14.7 3.5 0.0028 0.0011 0.0056 0.003 26 47 36 100 10

2017 Win 14.7 3.5 0.0028 0.0011 0.0056 0.003 34 46 42 100 10

2017 Spr 12.7 3.5 0.0028 0.0011 0.0056 0.003 41 58 52 100 10

2017 Sum 10 3.5 0.0028 0.0011 0.0056 0.003 53 74 67 100 10

2017 Fal 10 3.5 0.0028 0.0011 0.0056 0.003 46 62 57 100 10

2026 Jan 14.7 3.5 0.0028 0.0011 0.0055 0.003 26 47 36 100 10

2026 Win 14.7 3.5 0.0028 0.0011 0.0055 0.003 34 46 42 100 10

2026 Spr 12.7 3.5 0.0028 0.0011 0.0055 0.003 41 58 52 100 10

2026 Sum 10 3.5 0.0028 0.0011 0.0055 0.003 53 74 67 100 10

2026 Fal 10 3.5 0.0028 0.0011 0.0055 0.003 46 62 57 100 10



## Activity Level and Spatial Allocation

The NONROAD model contains data on statewide equipment types and usage. The model

utilizes spatial surrogates appropriate for each equipment type to disaggregate state activity

levels to individual counties. The default surrogates were used for all equipment types except

recreational marine vessels. The default spatial surrogate for recreational marine is water surface

area. This method can overesti mate recreational boat usage in certain counties due to the large

areas of open water in a county’s jurisdiction. A new allocation based on county boat

registrations was substituted for the default. Registrations for 20 11 were provided by the

Washington Department of Licensing ( Table 42 ). 29



## Emissions were allocated to the Nonattainment Area and modeling gr ids based on spatial

surrogates (see Table 7 and Table 8 ).

Table 41 : Spatial Allocations for Nonroad Sources

Category Surrogate Source

Recreational Marine Vessels Land Use: open water NLCD*

Railroad Maintenance Equipment Active Railroad Track WSDOT GIS files

Commercial Equipment Land Use: Urban NLCD

Construction and Mining Equipment Land Use: Urban NLCD

Industrial Equipment Land Use: Urban NLCD

Lawn and Garden Equipment Land Use: Urban NLCD



### * National Land Cover Database 30



## Table 42 : County Boat Registrations, 2011

County Registrations

Pierce 25359

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 34 3.5.2 Locomotives

Emissions from Class I line haul and switch yard locomotives were estimated using EPA

guidance and other information. 31 

## Two Class I railroads operate in Washington: Burlington

Northern Santa Fe Railway (BNSF) and Union Pacific Railroad (UPRR) . Amtrak was also

included in this inventory. Class 2 and 3 railroad locomotive emissions were not inventoried. A

special Northwest International Air Quality Environmental Science and Technology Consortium

(NW

- AIRQUEST ; formerly Northwest Regional Techn ical Center) project conducted by the

Oregon Department of Environmental Quality (ODEQ) found that emissions from Class 2 and 3

railroad locomotives were a small percentage of total locomotive emissions. 32

, 33



## This section does not include fugitive dust from coal trains. Please refer to 3.4.4 Fugitive Dust

from Coal Trains for those emission calculations and emissions.

Activi ty Level

Activity level is measured in gallons of diesel consumed by locomotives. BNSF Railway , UPRR

and Amtrak provided county fuel use for line haul and switch yard locomotives for 2011

. 34

, 35

, 36



## Activity was projected to 2017 and 2026 using the Pierce County population projection factors

( Table 7 ).

Coal dust emissions from the proposed Gateway Terminal coal export facility proposal in

Whatcom County and from Canad ian exports were estimated in Section 3.4.4 . Increased rail

traffic through the nonattainment area would increase diesel PM2.5 emissions. The increase is

not est imated in this plan. The environmental effects of the Gateway Terminal are currently

being studied through the State Environmental Policy Act and the National Environmental Policy

Act processes. 37 

## More detailed emissions and effects of those emissions wil l be discussed in

those environmental reviews. Without the terminal, projected locomotive PM2.5 emissions

estimates are very small, 0.10% and 0.05% of the 2017 and 2026 daily inventories , respectively.

Even a large increase in rail traffic would not sign ificantly increase total daily PM2.5 emissions,

nor cause the emissions to exceed the 2017 or 2026 emissions safety margin which is the

difference between the maintenance year 2011 emissions and the projected year emissions.

Temporal and Spatial Adjustments

The activity information was obtained by county; therefore, no spatial adjustments were

necessary at the county level. Emissions were allocated to the Nonattainment Area and using

active railroad track GIS data from WSDOT as the spatial surrog ate. The Nonattainment Area

has 39% of the Pierce County line haul and passenger track. It has 100% of the yards. 38



## Locomotives were assumed to operate uniformly year

- round per EPA guidance. 39



## Emission Rates

BNSF, UPRR and AMTRAK provided emissions esti mat es and emission factors for 2011 , but

were unable to project emissions into th e future. 2017 and 2026 projection year emissions

estimates, with the exception of SO 2 

## were calculated using EPA Guidance. 40 

## SO 2 

## emissions for

2017 and 2026 were estima ted using the ratio between 2011 and each projection year e mission

factor and multiplying by the total SO 2 

## emissions fro m 2011 (see Table 43 ).

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 35 Table 43 : Pierce County Locomotive Emission Factors in g/gal

T ype Pollutant 2011 2017 2026

Line Haul VOC 7.7 4.6 2.5

Line Haul NOx 149 114 69

Line Haul SO2 1.88 0.09 0.09

Line Haul PM2.5 4.4 2.9 1.5

Passenger VOC 8.1 4.6 1.8

Passenger NOx 167 112 64

Passenger SO2 1.88 0.09 0.09

Passenger PM2.5 4.5 2.8 1.2

Yard VOC 14 11.8 7.6

Yard NOx 235 206 144

Yard SO2 1.88 0.09 0.09

Yard PM2.5 5.3 4.5 3.1



## 3.5.3 Marine and Port of Tacoma Sources

Four types of marine and port sources were inventoried: ocean

- going vessels, harbor vessels,

cargo handling equipment, and port rail operations. Pleasure craft were also inventoried but

were included in Section 3.5.1 . The 2011 inventory prepared for the Puget Sound Maritime Air

Forum by Starcrest Consulting Group, LLC (2011 PSEI) was the starting point for the

inventories. 41 

## The PSEI is a bottom

- up , activity

- based emissions inventory.

Emissions Calculations for Projection Years 2017 and 2026

E missions were calculated by projecting the 20 11 inventory to each of the evaluation years.

Emissions for pollutant "P" were calculated:

E

year 

## = E 20 11 

## x A x F Where E = Emissions,

A = Act ivity adjustment factor

F = Fuel/engine adjustment factor for pollutant

Activity level and emission rates are described in the 2011 PSEI report. The report addressed

PM 10 

## , PM 2.5 

## , N o x, SO 2 

## , CO, and VOC . Projections were made using local information and

federal regulatory programs. The activity and fuel/engine adjustment factors are described in the

Activity Level and Emission Factors sections below.

Activity Level

Activity was projected using one of two activity surrogates for each type of ship or port

equipment: Port of Tacoma sector growth estimates, 42 

## or Pierce County population ( Table 7 ).

The sector growth estimates were give n as growth between 2011and 2015 (22%) and between

2015 and 2020 (10%). The 10% growth rate between 2015 and 2020 was assumed to continue

for the peri od 2020

- 2026. Sector growth was used to project activity for all sources except

harbor craft. Harbor craft emissions were not readily available by type (e.g., ferry, tug,

excursion). The 2008 base year inventory showed that emissions from ferries domina ted the

harbor craft inventory in the no nattainment area. Population was chosen to project harbor craft

emissions since it was believed to be an appropriate surrogate for ferry activity.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 36 Emission Factors

Ocean

- going Vessels

– Hotelling & Maneuvering

Chan ges in emission factors due to fuel changes were estimated. On March 26, 2010, the

International Marine Organization officially designated waters off North American coasts as an

Emission Control Area (ECA). New engine and fuel standards apply in ECAs. F uel sulfur

standards are:

 10,000 ppm starting August 2012 (1.0%)

 1,000 ppm starting January 2015 (0.1%)

In 20 11 , most ships used fuel with 2. 7 % sulfur content (20 11 PSEI). Some ships switch to a low

sulfur fuel (≤ 500 ppm) or use shore power at the Port of Tacoma. In 2011, the Port of Tacoma

estimated that 97% of the fuel used contained 2.7% sulfur, and 3% contained 0.5% sulfur

. Table

3.2 2 of the 20 11 PSEI provided fuel correction factors for changing sulfur content from 2.7% to

0 .5% and to 0.1% . The correction factors were used to estimate emission factor changes

between 2011 and the projection years 2017 and 2026

.

H arbor Craft

EPA's NONROAD2008 model was run for 20 11, 2017, and 2026 for the largest gasoline and

diesel powered boats. Emissions fact ors for harbor vessels were calculated and expressed as

g/ boat using the NONROAD model output. The ratio s of the project ion year to 20 11 emission

factors w ere calculated. The ratios were used as emission factor adjustments. The diesel fuel

sulfur conten t for all years was set to 15 ppm , ultra

- low sulfur diesel

.

Cargo Handling Equipment

Emissions reductions are being made in cargo handling equipment, bu t the range of equipment

and technologies make projections difficult. Cargo handling equipment is a sm all part of the

inventory; therefore, no adjustments were made.

Port Rail

EPA provided adjustment factors for locomotives as part of their rule making activity for

locomotives. 43 

## For 2017 and 2026 , adjustment factors were calculated as the ratio of the EPA

projection year emission factors to the attainment year 20 11 emission factors.

Temporal and Spatial Allocation

Emissions were assumed to occur uniformly throughout the year.

All ocean

- going vessel hotelling, cargo handling equipment, and port rail emissions were

assumed to occur in the Nonattainment Area. Port of Tacoma, PSCAA, and Ecology staff

assigned a fraction of the Pierce County ocean

- going vessel maneuvering and harbor craft

emissions to the Nonattainment Area when developing the 2008 attai nment year inventory. The

fractions were retained for this inventory.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 37 Table 44 : PSEI 2011 Pierce County Emissions (Tons)

, N AA Adjustment Factors, 2017 and

2026 Activity and Emission Rate Adjustment Factors

Category Pierce County 2011 Emissions (PSEI) in Tons Adjustments

PM2.5 N o x SO2 VOC Activity NAA

Ocean

- going vessels, maneuvering

2011 Emissions 0.57 9.56 8.83 0.29 0.17

2017 Adjustment factors 0.17 0.94 0.04 1.00 1.27 0.17

2026 Adjustment factors 0.17 0.94 0.04 1.00 1.66 0.17

Ocean

- going vessels, hotelling

2011 Emissions 28 416 528 13 1

2017 Adjustment factors 0.17 0.94 0.04 1.00 1.27 1

2026 Adjustment factors 0.17 0.94 0.04 1.00 1.66 1

Harbor c raft, diesel

- powered

2011 Emissions 28 801 0 26 0.2

2017 Adjustment factors 0.94 0.87 1.00 1.00 1.07 0.2

2026 Adjustment factors 0.81 0.71 1.00 1.00 1.18 0.2

Harbor c raft, g asoline

- powered

2011 Emissions 0 1 0 1 0.2

2017 Adjustment factors 1.00 0.93 0.98 1.00 1.07 0.2

2026 Adjustment factors 1.00 0.91 0.97 1.00 1.18 0.2

Cargo handling equipment

2011 Emissions 10 92 214 0 1

2017 Adjustment factors 1.00 1.00 1.00 1.00 1.27 1

2026 Adjustment factors 1.00 1.00 1.00 1.00 1.66 1

Port l ocomotives, switch yard

2011 Emissions 7 230 1 17 1

2017 Adjustment factors 0.85 0.88 1.00 0.84 1.27 1

2026 Adjustment factors 0.58 0.61 1.00 0.54 1.66 1

Port l ocomotives, line haul

2011 Emissions 5 134 1 7 1

2017 Adjustment factors 0.66 0.77 0.06 0.60 1.27 1

2026 Adjustment factors 0.34 0.46 0.06 0.32 1.66 1



## Double

- counting

There is potential for double

- counting in this category since it overlaps with other nonroad

sources. The sources are briefly discussed below.

Cargo handling equipment

- This equipment is counted as industrial equipment in the

NONROAD model, but the county allocations are based on manufacturing employment, which is

not counted as port activity (Section 3.5.1 ). Therefore, emissions were not subtracted from the

NONROAD model totals.

Port of Tacoma Rail

- Three companies have rail operations in or near the Port of Tacoma:

BNSF, UP, and Tacoma Rail. Emissions from BNSF and UP were counted under the locomotive

category (Section 3.5.2 ). The 20 11 PSEI did not contain sufficient detail to determine whether

any e missions from BNSF or UP may have been double counted in this section.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 38 3.6 Onroad Mobile Sources

Onroad mobile source emissions come from exhaust, evaporation, and brake and tire wear.

EPA's Motor Vehicle Emission Simulator ( MOVES ) model was used with loca l and defau lt data

to calculate emissions. 44



## MOVES may be run to produce emissions (Inventory mode) or emission rates (Rates mode).

The winter day inventory was run in rates mode , and the annual inventory in the simpler

inventory mode.

This section describes the major components of the equation s

, data sources

, and process used in

the equation s to develop the emissions estimates . The major components are VMT, vehicle

population, and the MOVES data

.

3.6.1 Vehicle Miles Traveled

Two sources of VMT were used. For the annual calculation

, the WA Dept. of Transportation's

(WSDOT) Pierce County estimate was used. 45 

## The winter day calculations relied on both the

WSDOT Pierce County VMT and on VMT specifically allocated to the NAA provided by

PSRC.

PSRC provi ded average weekday daily vehicle miles traveled (ADVMT) in the County and

NAA for each evaluation year (2011, 2017, 2026). The WSDOT data was only available for

2011. PSRC's VMT data was used to calculate growth factors from 2011 ( Table 7 ). The growth

factors were used to project the 2011 WSDOT VMT to 2017 and 2026. The PSRC ratio of NAA

to County VMT was used to allocate the WSDOT VMT to the NAA.

PSRC's VMT estimates were produced using their travel demand model. The model estimates

VMT over individual roadway segments called links for five different time periods throughout

the day. There are over 9,000 links in PSRC's travel demand model within the nonattainment

area. The periods were AM (6am

- 9am), MD (9am

- 3pm), PM (3pm

- 6pm), EV (6pm

- 10pm), and

NT (10pm

- 6am). The link data included congested speed and road type.

Each link was assigned to its nearest MOVES speed bin and MOVES road type: Rural

R estricted, Rural Unrestricted, Urban Restricted, or Urban Unrestricted. Then the VMT was

summed by speed bin and road type for each time period.

Emissions for each time period were calculated by multiplying the summed VMT by the average

MOVES emission fa ctor for the time period. Daily onroad emissions were calculated by adding

the emissions from all 5 times periods.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 39 3.6.2 Vehicle Population

Vehicle population is used to determine the amount of emissions from engine starts and extended

idling. Vehicle populat ion in the NAA was not available. Vehicles were allocated to the NAA

using the NAA/County ratio of VMT ( Table 7 ) . The ratio was 0.6 3 for each year. County

vehicle counts are described in Appendix B

.

VehPop NAA 

## = VehPop County 

## x ( VMT NAA 

## / VMT County 

## )

where VehPop NAA 

## is the vehicle population in the Nonattainment area

VehPop County 

## is the vehicle population in Pierce County

VMT NAA 

## is the VMT in the Nonattainment area

VMT County 

## is the VMT in Pierce County

3.6.3 MOVES Modeling and Emissions Estimates

MOVES ver sion 2010b was used for the maintenance plan

. MOVES includes a default database

that includes emission relevant information for the entire United States. A combination of data

from the default database (version 20100410) and data from local sources were used for the

budget. The MOVES Technical Guidance for SIP inventories and the MOVES User’s Gu ide

were used in developing the local parameters. 46

, 47



## MOVES may be run to produce emissions (Inventory model) or emission rates (Rates mode).

The winter day inventory was run in rates mode , and the annual inventory in the simpler

inventory mode

.

Winter Daily Emissions

Winter day emission rates were run for Pierce County

. MOVES was run in Rates mode at the

county scale by hour for one weekday in January using the design day temperature profile.

Emission rates were output by hour, road type, and emission s process.

The winter day calculation equation using output from MOVES' Rates mode is shown below:

E = (M x Fgmi) + (V x Fgpveh)

where E = emissions in g

M = VMT

V = vehicle population

Fgmi = emission factor in g/mi from MOVES

Fgpveh = emission factor in g/vehicle from MOVES



## Annual Emissions

MOVES was run in Inventory mode at the county scale by hour for weekday s and weekend day s

for each of January, April, July, and October. Emissions were output by month.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 40 Annual emissions were calculated according to the equation below :

E Annual 

## = ∑( E Month 

## x 3)

Where E Annual 

## = annual emissions

E Month 

## = Emissions for each of 4 months , each representing a season: Jan =

winter, Apr = spring, Jul = summer, Oct = fall.

MOVES inputs are described in Appendix B

.

4 Quality Assurance and Quality Control

In order to provide data of sufficient quality for maintenance planning needs, the inventory

process included quality assurance (QA) and quality control (QC) procedures. The p rocedures

addressed data quality objectives of accuracy, completeness, comparability, and

representativeness. Ecology used the following target goals for each objective:

 Accuracy: The inventory calculated and documented all estimates using acceptable

met hods. Individual source requirements and availability of data and resources affected

estimation method selection.

 Completeness: Ecology addressed completeness by ensuring that the inventory included

all applicable source categories, and verified that the inventory contain ed all the

information required to estimate emissions.

 Representativeness: We calculated actual annual and peak PM 2.5 

## season daily emissions

for each evaluation year. The inventory calculations used local data wherever possible.

 Compara bility: Ecology compared data by source category to the prior 200 8 base year

inventory. We corrected or justified any discrepancies greater than 20%, involving

sources that made up greater than 5% of either the 200 8 or the 20 11 annual inventories.

We compared the projection inventories to the 20 11 base year inventory. We

investigated and either corrected or justified any discrepancies between the base year and

given projection year if they:

o w ere greater than the population increase percentage plus 10%

, and

o i nvolved sources that made up greater than 5% of the 20 11 or projection year

daily inventories.

The tables below show the results of the comparability checks. Highlighted categories met the

criteria for further investigat ion: Point Sources and Onr oad Mobile Sources

.

Point Sources increased substantially from 2011 through 2026 primarily due to the use of the ten

year maximum for the projection of PSCAA sources

. The ten year maximum was used because

of the recent economic downturn. Ecology and PSCAA agreed that a ten year maximum would

better characterize the future emissions from the facilities than a five year maximum which had

been used previously for this nonattainment area

.

Onroad mobile source emissions decreased substantially from 2011 through 2026 primarily due

to fleet turnover.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 41 Table 45 : Base Year 2008 and Attainment Year 2011 

## Inventory Comparison

Category 2008 EI 2011 EI D i screpancy

% lbs/day % lbs/day % 2011 / 2008

Point Sources 979 3% 1,313 4% 1.341

Residential Wood

Combustion 24,492 74% 25,519 76% 1.042

Residential non

Wood Fuel 54 0% 49 0% 0.912

Commercial Cooking 727 2% 975 3% 1.341

Construction Dust 852 3% 596 2% 0.700

Paved Road Dust 1,284 4% 1,232 4% 0.960

Coal Train Dust 196 1%

Onroad Mobile 3,041 9% 2,497 7% 0.821

Nonroad Other 1,079 3% 1,035 3% 0.960

Locomotives 55 0% 43 0% 0.783

Marine and Port 370 1% 306 1% 0.827

TOTAL 32,933 3 3,761 1.025



## Table 46 : Attainment Year 2011 and Projection Years 

## Inventory Comparison

Category 2011 EI 2017 EI 2026 EI Di screpancy

lbs/day % lbs/day % lbs/day % 2017/2011 2026/2011

Point Sources 1,313 4% 1,995 6% 1,903 6% 1.519 1.449

Res. Wood Comb 25,519 76% 25,355 77% 25,788 77% 0.994 1.011

Res. non

- Wood Fuel 49 0% 53 0% 58 0% 1.074 1.183

Comm. Cooking 975 3% 1,028 3% 1,153 3% 1.054 1.182

Construction Dust 596 2% 654 2% 678 2% 1.098 1.138

Paved Road Dust 1,232 4% 1,318 4% 1,392 4% 1.070 1.130

Coal Train Dust 196 1% 96 0% 561 2% 0.493 2.867

Onroad Mobile 2,497 7% 1,642 5% 1,149 3% 0.658 0.460

Nonroad Other 1,035 3% 726 2% 463 1% 0.702 0.447

Locomotives 43 0% 32 0% 16 0% 0.751 0.366

Marine and Port 306 1% 198 1% 218 1% 0.648 0.713

TOTAL 33,761 33,099 33,379 0.980 0.989



## 4.1 Q uality Control Procedures

Ecology performed calculations as appropriate for the given estimation method. QC checks were

an integral part of calculations. We performed c alculations electronically wherever possible to

minimize errors. We made hand calculations to verify electronic c alculation equations. This

final inventory report fully documents those calculations. During the development of the report

we made comparisons to the 200 8 inventory to catch any potential errors.

4.2 Quality Assurance Procedures

Several EI staff were involved in calculating the inventories. EI staff performed the reality/peer

review and sample calculation checks on one another's work. We used several quality assurance

checks to address the data quality objectives:

 reality/peer review checks,

 sampl e calculations,

 sensitivity analysis (emissions ranking) , and

 range check s (see Comparability objective )

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 42 Appendix A 1

– National Emissions Inventory Source Categories

Table 47 : 2011 Nat

ional Emissions Inventory (version 1) , Pierce County *

Sector Group Tons/yr Percent Total

PM25 SO2 NOX VOC NH3 PM25 SO2 NOX VOC NH3

E v ent Managed Burn s 82 6 8 234 16 2% 0% 0% 1% 1%

Nonp t Comm. Cook 271 40 8% 0% 0% 0% 0%

Nonpt Dust

, Ag ric 15 0% 0% 0% 0% 0%

Nonpt Dust, non

- Res

Cnstr 177 5% 0% 0% 0% 0%

Nonpt Dust, R es Cnstr 10 0% 0% 0% 0% 0%

Nonpt Dust, Road Cnstr 136 4% 0% 0% 0% 0%

Nonpt Dust

, Other 56 2% 0% 0% 0% 0%

Nonpt Dust, PavRoads 332 9% 0% 0% 0% 0%

Nonpt Dust, UnpvRoads 29 1% 0% 0% 0% 0%

Nonpt Fertilizer 0 44 0% 0% 0% 0% 2%

Nonpt Comm ercial 41 2 20 2 0 1% 0% 0% 0% 0%

Nonpt ResFuel

, D ist O il 4 79 33 1 2 0% 7% 0% 0% 0%

Nonpt ResFuel

, Keros

. 0 1 1 0 0 0% 0% 0% 0% 0%

Nonpt ResFuel

, LPG 0 0 48 2 0 0% 0% 0% 0% 0%

Nonpt ResFuel

, NGas 2 3 418 24 89 0% 0% 2% 0% 5%

Nonpt ResFuel

, Wood 1,471 24 162 1,660 83 41% 2% 1% 7% 4%

Nonpt Livestock 0 1,016 0% 0% 0% 0% 53%

Nonpt Misc 0 0 2 0 0% 0% 0% 0% 0%

Nonpt Managed Burn s 1 0 0 0% 0% 0% 0% 0%

Nonpt OpenBurning 75 6 26 110 2% 0% 0% 0% 0%

Nonpt BulkPlants 0 165 0% 0% 0% 1% 0%

Nonpt GasCans 0 453 0% 0% 0% 2% 0%

Nonpt GasStations 0 679 0% 0% 0% 3% 0%

Nonpt GasStat

, Stg2 0 130 0% 0% 0% 0% 0%

Nonpt PetStoreTrans 0 109 0% 0% 0% 0% 0%

Nonpt Ag Pesticides 0 15 0% 0% 0% 0% 0%

Nonpt Asphalt Pav 0 235 0% 0% 0% 1% 0%

Nonpt Dry Clean ing 0 3 0% 0% 0% 0% 0%

Nonpt Graphic Arts 0 69 0% 0% 0% 0% 0%

Nonpt Solv Con / Com 0 3,381 0% 0% 0% 14% 0%

Nonpt Surf Coat, Arch 0 939 0% 0% 0% 4% 0%

Nonpt Sur

f Coat, Ind ust 0 1,134 0% 0% 0% 5% 0%

Nonpt Wastewater 0 8 2 0% 0% 0% 0% 0%

Nonrd NR Model 350 10 3,659 3,844 5 10% 1% 18% 16% 0%

Nonpt CMV 63 608 1,321 46 1 2% 50% 6% 0% 0%

N onpt Locomotives 18 5 616 32 0 0% 0% 3% 0% 0%

Onrod Onroad 225 100 12,791 10,818 611 6% 8% 62% 44% 32%

P oint Airports 8 1 8 14 0% 0% 0% 0% 0%

P oint Point 205 365 1,379 416 48 6% 30% 7% 2% 3%

3,572 1,211 20,493 24,561 1,917 100% 100% 100% 100% 100%



## * Does not include w ildfire or biogenic emissions. H ighlighted categories were included in the inventory

. Estimates for the peach

- highlighted categories were taken directly from the NEI. Ecology made new calculations

for the categories highlighted in blue , so the estimates in the table will not match those in the maintenance plan

. Non

- highlighted categories were not included in the inventories. They are expected to be small contributors to the

total winter nonattainment area emissions.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 43 Appendix A2

– Residential Wood Combustion Temperature Adjustment

The design day temperature profile calculated for the SIP revision 2008 base year inventory was

used for t he maintenance plan inventories . R esidential wood combustion emissions were

calculated for the design day temperature profile . The calculation is similar to the residential

wood combustion temperature adjustment system used in the AIRPACT air quality forecasting

model. Briefly, analysis of several PM 2.5 

## and meteorological monitoring sites through out the

region showed a strong linear relationship between ambient temperature and ambient fine

particulate concentrations at temperatures below 50 degrees Fahrenheit. 48 

## This relationship was

used to develop the temperature adjustment system. The adjustm ent system involves

normalizing emissions to heating degree days (based on 50 degrees = HDD 50 

## ), and then

multiplying the normalized value by the heating degree days for the design day. A more detailed

description follows.

1) Calculate b aseline HDD 50



## Calculate annual HDD 50 

## for woodstove survey period Sept. 2006

– Aug. 2007. This is the sum of

the heating degree days for each day of the year. Daily min

- max temperatures from the South L

Street meteorological site were used.

Annual HDD

50 

### = ∑ 365 

### 50

– Tav g i



### ), where Tavg = the daily average temperature (sum over all 365 days).

I=1 

### If Tavg > 50, set the value of Tavg = 50.

= 1299



## 2) Calculate emissions as tons per HDD 50 

## Calculate annual county emissions (Tons/yr). Divide the annual emissions by the annual HDD 50 

## calculated in step (1). The result is emissions expressed as tons per HDD 50 

## . This can be viewed

as emissions normalized to heating degree days.

Tons/HDD

50 

### = (Tons/yr) / HDD

50 

### /yr)



## 3) Calculate the design day HDD 50



## The design day heating degree days are calculated as (50

– average temperature for the day).

The average temperatures used in the calculation is the average of the maximum and minimum

temperatures for the three design day temperature profiles.

Design Day HD D 50 

### = 50

– average temperature for the design day

Design Day HDD 50 

### = 50

– (46 + 27)/2 = 14



## 4) Calculate the design day emissions

Multiply the emissions in T/HDD 50 

## by the design day HDD 50 

## calculated in step (3). These are

the final daily emissions.

Tons/day = Tons/HDD

50 

### x HDD 50

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 44 References

1 

## 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

Emissions Inventory Group: Emissions Monitoring and Analysis Division, Office of Air

Quality Planning and Standards U.S. Environmental Protection Agency, Research Triangle

Park, NC 27711, August 2005.

2 

## Puget Sound Regional Council. A p ril 2014.

3 

## Puget Sound Clean Air Agency Regulation I Section 5.05(b) and Section 7.09(a)

4 

## Puget Sound Clean Air Agency Indoor Wood

- burning Emission Inventory Survey of King,

Kitsap, Pierce and Snohomish Counties, Report of Results . Prepared by Nationa l Research

Center, Inc., 3005 30th Street, Boulder, Colorado 80301. November 2007

5 

## Puget Sound Indoor Wood

- burning Emission Inventory Survey Data Review and Evaluation

. Prepared for John Crouch Hearth, Patio & Barbecue Association, 901 North Moore Stre et,

Suite 600 Arlington, VA 22209. Prepared by Jeremy Clark and James Houck, OMNI

Environmental Services, Inc. 13327 NE Airport Way, Portland, OR 97230. June 15, 2009.

6 

## Carole Cenci, Puget Sound Clean Air Agency; Gary Smith, Hearth, Barbeque and Patio

Association; and Tiffany Spiers, Master Builder's Assocication. Conversation and email from

Carole Cenci, PSCAA to Sally Otterson, Dept. of Ecology. Sept. 15, 2011.

7 

## Sol id Fuel Burning Device Fee Calendar Years 2006

- 2012

. Dept. of Revenue

. from file

Woodstove fees

– all counties.xlsx

. June 28, 2013

.

8 

## Carole Cenci, Puget Sound Clean Air Agency; Gary Smith, Hearth, Barbeque and Patio

Association; and Tiffany Spiers , Master Builder's Assocication. Conversation and email from

Carole Cenci, PSCAA to Sally Otterson, Dept. of Ecology. Sept. 15, 2011.

9 

## Compilation of Air Pollutant Emission Factors, Volume I: Stationary Point and Area Sources

. AP42. Table 1.10

- 1 (1 0 / 9 6 ).

10 

## EPA Residential Wood Combustion tool. rwc_estimation_tool_2011v1_120612.accdb

. V ersion 1 of EPA’s 20 11 NEI Residential Wood Combustion Tool (available for download at

ftp://ftp.epa.gov/pub/EmisInventory/2011nei/doc/ )

.

11 

## John Tarni, principal inv estigator. Thom Allen, study director. Wood Burning Stove Survey

for Idaho, Oregon and Washington State. Social and Economic Sciences Research Center.

Washington State University. Prepared for Gary Reinbold, Idaho Department of

Environmental Quality. Data Report and database of survey responses. August 2001.

12 

## Washington State Department of Transportation Highway Performance Monitoring System

(HPMS) 2011 DVMT by County & FC

- Estimated . Washington State Department of

Transportation. Spreadsheet VMTByCO2011_for DOE.xlsx

13 

## Compilation of Air Pollutant Emission Factors, Volume I: Stationary Point and Area Sources

. AP42. Section 13.2.1 (1/11).

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 45 14 

## Update based on work done by Midwest Research Institute for the Western Regional Air

Partnership (2005).

15 

## U.S. Department of Transportation, Federal Highway Administration

, 1997 Federal Highway

Cost Allocation Study, Final Report

, Tables II.6 and II.8.

16 

## Month of Year Factors for Statewide Traffic, and Day Of Week Factors For Statewide Traffic

. 2006

- 2008 d ata. WSDOT.

17 

## 2011 NEI Technical Support Document, Draft.

http://www.epa.gov/ttn/chief/net/2011nei/2011_neiv1_tsd_draft.pdf . Accessed 4/22/2014.

18 

## Cope and Bhattacharyya, 2001. A Study of Fugitive Coal Dust Emissions in Canada

. An

Unpublished Report Prepared for the Canadian Council of Ministers of the Environment

.

19 

## BNSF Railway Statement on STB Coal Dust Decision.

http://www.bnsf.com/customers/what

- can

- i

- ship/coal/coal

- dust.html . Accessed May 2014.

20 

## EPA, Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area

Sources, AP

- 42, Fifth Edition, U.S. Environmen tal Protection Agency, Office of Air quality

Planning and standards, Research Triangle Park, North Carolina. Industrial Wind Erosion,

Chapter 13.2.5

- 2, Page 3. Updated, Nov 2006.

htt p://www.epa.gov/ttn/chief/ap42/ch13/final/c13s0204.pdf . Accessed November, 2013.

21 

## Letter from Pacific International Terminals indicating that Gateway Terminal will be built to

full capacity by 2019 instead of using phased building approach through 2 026. Gateway

Project Proposal indicates that full capacity for coal exports will be 48MT.

22 

## Westshore expansion by 2017:

http: //portmetrovancouver.com/en/projects/OngoingProjects/Tenant

- Led

- Projects/Equipment

Replacement

- Upgrade

23 

## Westshore Expansion by 2026: http://www.westshore.com/pdf/finance/2013/ar.pdf pg 10

24 

## Fraser Surrey Expansion 2017/2026:

http://portmetrovancouver.com/en/projects/OngoingProjects/Tenant

- Led

Projects/F raserSurreyDocks/more

- information

--- fsd

25 

## 20 11 National Emissions Inventory, version 1

.

26 

## EPA modeling files for the Clean Air Interstate Rule, Feb. 2005. Files available through

CHIEF website ( http://www.epa.gov/ttn/chief/emch/temporal/ ).

temporal_profiles_cair_platform.xls, temporal_cross

- ref_cair_platform.xls

27 

## Western Climatic Data Center, 1999

- 2008 Average for Tacoma Narrows meteorological site.

28 

## Model and User’s Guide for the final NONROA D 2005 Model . United States Environmental

Protection Agency, Office of Air and Radiation. EPA420

- R

- 05

- 013. December 2005.

29 

## Vessel Registration Count by Moorage County and Length . Washington State Department of

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 46 Licensing. Total registrations for Mar.

- Dec. 2008.

30 

## Multi

- resolution Land Characteristics, National Land Cover Data. United States Geologic

Survey. 1992 data, 30 m resolution.

31 

## Emission Factors for Locomotives

- Technical Highlights (EPA

- 420

- F

- 09

- 025)

32 

## Regional Technical Center Demonstratio n Project: Summary Report. Idaho Department of

Environmental Quality, Oregon Department of Environmental Quality, Washington

Department of Ecology, US EPA Region 10, Washington State University, University of

Washington. January 11, 2002 (draft).

33 

## Orego n 1996 Railroad Emissions Inventory Project, Emission Estimate Methodology

Documentation . Oregon Department of Environmental Quality. August 2001.

34 

## BNSF Railway Company 2011 Estimation of BNSF Locomotive Emissions. Email transmittal

of information from Kelly Harvey , BNSF to Sarah Clouse, Washington State Department of

Ecology. June 12, 2012

.

35 

## Uni on Pacific Railroad Company 2011 Fuel Consumption by County (Line Haul) and Yard

Jobs in Washington. Transmitted by email from Jon Germer, Union Pacific Railroad to

Sarah Clouse, Washington Department of Ecology. July 31, 2012

.

36 

## AMTRAK Locomotive Fuel Consumption

– 2008. Email Transmittal of information from

Celia Ann H. Pfleckl, Amtrak to Sarah Clouse, Washington State Department of Ecology.

Ma y 31, 2012.

37 

## Gateway Pacific Terminal at Cherry Point Proposal web page.

http://www.ecy.wa.gov/geographic/gatewaypacific/.

38 

## Railroads in Washington State, at 1:24,000

. GIS data layer

(o: \ sdelayers \ transportation \ 24K_Railroads). Washington State Department of Transportation,

Geographic Services/CGIS. July 24, 2008.

39 

## Procedures for the Preparation of Emission Inventories for Carbon Monoxide and Precursors

o f Ozone . Volume II, table 6

- 11. EPA

- 454/R

- 92

- 026, December 1992.

40 

## EPA

- 420

- F

- 09

- 025, April 2009

41 

## 2011 Puget Sound Maritime Air Emissions Inventory . Prepared by: Starcrest Consulting

Group, LLC, Starcrest Consulting Group, LLC, Poulsbo, Washington 98370. September

2012.

42 

## 2015 and 2020 DPM Goal Setting Background worksheets. Port of Tacoma. POT Work

Sheet 1

- 16

- 2013.xlsx.

43 

## Emission Factors for Locomotives . Office of Transportation and Air Quality, U.S.

Environmental Protection Agency. EPA420

- F

- 09

- 025, April 2009.

http://www.epa.gov/otaq/locomotives.htm.

44 

## Version 2010b of the model and database movesdb20121030 were used.

## Emission Inventory Documentation

Tacoma

- Pierce County PM 2.5 

## Redesignation Request and Maintenance Plan Page 47 45 

### Washington State Department of Transportation Highway Performance Monitoring System (HPMS)

2011 DVMT by County & FC

- E stimated . Washington State Department of Transportation.

Spreadsheet VMTByCO2011_for DOE.xlsx

46 

## Using MOVES to Prepare Emission Inventories in State Implementation Plans and

Transportation Conformity: Technical Guidance for MOVES2010, 2010a and 2010b

. Transportation and Climate Division

, Office of Transportation and Air Quality

, U.S.

Environmental Protection Agency

. EPA

- 420

- B

- 12

- 028

. April 2012

.

47 

## Motor Vehicle Emission Simulator (MOVES)User Guide for MOVES2010b . Assessment and

Standards Division

, Of

fice of Transportation and Air Quality

, U.S. Environmental Protection

Agency. EPA

- 420

- B

- 12

- 001b

. June 2012

.

48 

## Bowman, Clint. Washington Dept. of Ecology. On a Possible Wood Stove Signature in

PM2.5 Observations . October 2008.