SUBJECT: Technical Support Document -Maryland; 2002 Base Year Emissions Inventory,

Reasonable Further Progress Plan, Contingency Measures, Reasonably AvailableControl Measures, and Transportation Conformity Budgets for the Baltimore 1997

8-Hour Ozone Moderate Nonattainment Area

FROM: Maria A. Pino, Air Quality Planning Specialist )9’?V-c2bzt

Office of Air Program Planning

TO: FileTHRU: Cristina Fernandez, Associate Director

Office of Air Program Planning

This document provides a technical review of a revision to the Maryland State

Implementation Plan (SIP) submitted by the Maryland Department ofthe Environment (MDE)on June 4, 2007 to address emissions inventory, reasonable further progress (RFP), reasonablyavailable control measures (RACM) analysis, and contingency measure requirements under the

1997 8-hour ozone national ambient air quality standard (NAAQS) for the Baltimore moderate

nonattainment area. The SIP revision also establishes a motor vehicle emissions budget (MVEB)

for 2008 for the Baltimore moderate nonattainment area. Maryland’s SIP revision submittal,

entitled “Baltimore Nonattainment Area 8-Hour Ozone State Implementation Plan and Base YearInventory, SIP Number 07-04,” will be referred to as “the Baltimore 8-hour ozone plan”

throughout this document.

A. BACKGROUND

I. General Requirements

Section 182 of the Clean Air Act (CAA) and the Environmental Protection Agency’s

(EPA’s) 1997 8-hour ozone regulations (40 CFR 5 1.910) require each moderate and above8-hour ozone nonattainment area to submit an emissions inventory and RFP SIP revision that

describes how the area will achieve actual emissions reductions of volatile organic compounds

(VOC) and nitrogen oxides (NOx) from a baseline emissions inventory. An emissions inventoryis an estimation of actual emissions of air pollutants in an area. The emissions inventory for anozone nonattainment area contains VOC and NOx emissions, which are precursors to ozone

formation. In this case, a “baseline” emissions inventory is required for the year 2002.
RACM and must be included in the SIP. RACM are necessary to ensure that the attainment dateis achieved “as expeditious as practicable.”

Phase 1 ofthe 8-hour ozone implementation rule, published on April 30, 2004 (69 FR

23951), set out criteria for classifying nonattainment areas under the 1997 8-hour ozone standard.The Phase 1 rule also addressed revocation of the 1-hour NAAQS; how anti-backsliding

principles will ensure continued progress toward attainment ofthe 8-hour ozone NAAQS;

attainment dates; and the timing of emissions reductions needed for attainment. On November

29, 2005, EPA published the Phase 2 final rule for implementation of the 8-hour standard. ThePhase 2 rule addressed the RFP control and planning obligations as they apply to areasdesignated nonattainment for the 1997 8-hour ozone NAAQS (70 FR 71612). The Phase 2 final

rule was revised on June 8, 2007 (72 FR 31727). Among other things, the Phase 1 and 2 rules

outline the SIP requirements and deadlines for various requirements in areas designated as

moderate nonattainment. The rules set a due date ofJune 15, 2007 for the required base year

emission inventory, RFP plan, modeling and attainment demonstration, RACM, MVEB, and

contingency measures (40 CFR 51.908(a), (c)).

Section 1 82(b)( 1) ofthe CAA and EPA’s 1997 8-hour ozone implementation rule (40

CFR 5 1.910) require each 8-hour ozone nonattainment area designated moderate and above to

submit for review and approval into its SIP an emissions inventory and RFP plan that describes

how the area will achieve actual emissions reductions of VOC and NOx from a baselineemissions inventory. For a moderate 8-hour ozone nonattainment area with an attainment date

more than 5 years after designation, a 15 percent RFP reduction in ozone precursor emissions is

required within 6 years (2002-200 8). For a moderate area with an approved 15 percent rate-ofprogress (ROP) plan under the 1-hour standard, states can use reductions from VOC or NOx or a

combination of either. For a moderate area without and approved ROP plan, a 15% reduction in

VOC is required. The reductions may come from anywhere within the 8-hour nonattainment

area. Table 1 outlines these requirements.

Table 1. RFP Requirements for Moderate 8-Hour Ozone Nonattainment Areas withAttainment Dates More than 5 Years after Designation

Area Requirement 40 CFR Reference

With approved 15% 15% VOC and/or NOx reductions 51.910(a)(l)(iii)(B)(2) &

VOC ROP plan (2002— 2008) 51.910(b)(2)(b)(ii)

Without approved 15% VOC reductions (2002 -2008). 51.910(a)(1)(iii)(B)(1)

15% VOC ROP plan The reductions may come from

anywhere within the 8-hour

nonattainment area.

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II. The Baltimore Area

In 1997, EPA revised the health-based NAAQS for ozone, setting it at 0.08 parts per

million (ppm) averaged over an 8-hour time frame. EPA set the 8-hour ozone standard based on

scientific evidence demonstrating that ozone causes adverse health effects at lower ozone

concentrations and over longer periods of time, than was understood when the pre-existing

1-hour ozone standard was set. EPA determined that the 8-hour standard would be more

protective of human health, especially children and adults who are active outdoors, and

individuals with a pre-existing respiratory disease, such as asthma.

On April 30, 2004 (69 FR 23951), EPA finalized its attainment/nonattainment

designations for areas across the country with respect to the 8-hour ozone standard. Theseactions became effective on June 15, 2004. Among those nonattainment areas is the Baltimore,

Maryland moderate nonattainment area (NAA). This NAA includes Baltimore City and AnneArundel, Baltimore, Carroll, Harford, and Howard Counties, all in Maryland.

Pursuant to Phase 1 ofthe 8-hour ozone implementation rule, an area was classified

under Subpart 2 ofthe CAA based on its 8-hour design value ifthat area had a 1-hour designvalue at or above 0.121 ppm (the lowest 1-hour design value in Table 1 of Subpart 2). Based on

this criterion, the Baltimore NAA was classified under Subpart 2 as moderate nonattainment

areas.B. EVALUATION OF STATE SUBMITTAL

I. Base Year Emissions Inventory

An emissions inventory is a comprehensive, accurate, and current inventory of actual

emissions from all sources. The emissions inventory is required by section 172(c)(3) ofthe

CAA. For ozone nonattainment areas, the emissions inventory needs to contain VOC and NOx

emissions because these pollutants are precursors of ozone. EPA recommended 2002 as the base

year emissions inventory, and is therefore the starting point for calculating RFP. Maryland

submitted its 2002 base year emissions inventory for the Baltimore NAA on June 4, 2007. Asummary ofthe Baltimore NAA 2002 base year VOC and NOx emissions inventory is includedin Table 2, below.

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Maryland discusses its 2002 base year inventory for the Baltimore NAA in Section 3.0 of

the Baltimore 8-hour ozone plan. Appendix A of the Baltimore 8-hour ozone plan contains

Maryland’s 2002 base year inventory for the Baltimore NAA. EPA Region 3’s Air Quality

Analysis Branch (AQAB) reviewed Maryland’s 2002 base year inventory for the Baltimore NAAusing the appropriate EPA policy and guidance. Please see the attached “Technical SupportDocument (TSD) for the Baltimore Nonattainment Area: 8 Hour Ozone State ImplementationPlan (SIP) Attainment Demonstration and Base Year Inventory,” prepared by Alice H. Chow andsigned by Walter Wilkie, Air Quality Analysis Branch Chief, on December 19, 2008 (Baltimore

Emission Inventory TSD). As discussed in detail in the Baltimore Emission Inventory TSD,Maryland’s procedures, methodologies, and result for the Baltimore NAA 2002 base yearinventory are approvable.

II. Adjusted Base Year Inventory, 2008 RFP Target Levels

The process for determining the emissions baseline from which the RFP reductions are

calculated is described in section 1 82(b)( 1) ofthe CAA and 40 CFR 51.910. This baseline value

has been determined to be the 2002 adjusted base year inventory. Sections 182(b)(1)(B) and (D)require the exclusion from the base year inventory of emissions benefits resulting from the

Federal Motor Vehicle Control Program (FMVCP) regulations promulgated by January 1, 1990and the Reid Vapor Pressure (RVP) regulations promulgated June 11, 1990 (55 FR 23666). The

FMVCP and RVP emissions reductions are determined by the state using EPA’s on-road mobile

source emissions modeling software, MOBILE6. The FMVCP and RVP emission reductions are

then removed from the base year inventory by the state, resulting in an adjusted base year

inventory. The emission reductions needed to satisfy the RFP requirement are then calculated

from the adjusted base year inventory. These reductions are then subtracted from the adjusted

base year inventory to establish the emissions target for the RFP milestone year (2008).

For moderate areas like the Baltimore NAA, the CAA specifies a 15 percent reduction in

ozone precursor emissions over an initial 6-year period. In the Phase 2 Rule (70 FR 71612), EPAinterpreted this requirement for areas that were also designated nonattainment and classified as

moderate or higher for the 1-hour ozone standard. In the Phase 2 Rule, EPA provided that an

area classified as moderate or higher that has the same boundaries as an area, or is entirelycomposed of several areas or portions of areas, for which EPA fully approved a 15 percent plan

for the 1-hour NAAQS, is considered to have met the requirements of section 1 82(b)( 1) ofthe

CAA for the 8-hour NAAQS. In this situation, a moderate nonattainment area is subject to RFP

under section 1 72(c)(2) of the CAA and shall submit, no later than 3 years after designation for

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Maryland submitted a 15% Plan SIP revision for the Baltimore nonattainment area. On February2, 2000, EPA approved Maryland’s 15% plan for the Baltimore severe ozone nonattainment area

(65 FR 5252). Therefore, according to the Phase 2 Rule, the RFP plan for the Baltimore NAA

may use either NOx or VOC emissions reductions (or both) to achieve the 15 percent emissionreduction requirement.

According to section 1 82(b)( 1 )(D) of the CAA, emission reductions that resulted from the

FMVCP and RVP rules promulgated prior to 1990 are not creditable for achieving RFP emission

reductions. Therefore, the 2002 base year inventory must be adjusted by subtracting the VOC

and NOx emission reductions that are expected to occur between 2002 and the future milestone

years due to the FMVCP and RVP rules. The adjustments are calculated in the followingmanner:A) Estimate the actual anthropogenic base year inventory for both VOC and NOx in 2002 with

all 2002 control programs in place.

B) Using the same highway vehicle activity inputs used to calculate the actual 2002 inventory,

run the appropriate motor vehicle emissions model for 2002 and for 2008 with all post-1990

CAA measures turned off. Any other local inputs for vehicle inspection and maintenance(I/M) programs should be set according to the program that was required to be in place in

1990. Fuel RVP should be set at 9.0 or 7.8 depending on the RVP required in the local area

as a result of fuel RVP regulations promulgated in June 1990.

C) Calculate the difference between 2002 and 2008 VOC emissions factors calculated in Step B

and multiply by 2002 VMT. The result is the VOC emissions reductions that will occur

between 2002 and 2008 without the benefits of any post-1990 CAA measures. These are thenon-creditable VOC reductions that occur over this period. Calculate the difference between2002 and 2008 NOx emissions factors calculated in Step B and multiply by 2002 VMT. Thisresult is the NOx emissions reductions that will occur between 2002 and 2008 without thebenefits of any post-1990 CAA measures. These are the non-creditable NOx reductions thatoccur over this period.

D) Subtract the non-creditable VOC reductions calculated in Step C from the actual

anthropogenic 2002 VOC inventory estimated in Step A. Subtract the non-creditable NOx

reductions calculated in Step C from the actual anthropogenic 2002 NOx inventory estimated

in Step A. These adjusted VOC and NOx inventories are the basis for calculating the targetlevel of emissions in 2008.

5
A) The Baltimore NAA 2002 anthropogenic base year inventory is found in Table 5

1 of the

Baltimore 8-hour ozone plan, and is summarized in Table 3, below.

Table 3. Baltimore NAA 2002 Anthropogenic Base Year Inventory (Ozone Season tpd)

Source Category VOC NOx

Point 13.88 111.88Area 116.81 8.18

Non-Road 70.22 40.96

On-Road 70.57 177.06

Total 271.48 338.08

B & C) Maryland calculated the non-creditable emission reductions between 2002 and 2008 by

modeling its 2002 and 2008 motor vehicle emissions with all post-1990 CAA measures

turned off, and calculating the difference. See Tables 5-2 and 5-3 ofthe Baltimore 8-hour

ozone plan. The non-creditable reductions are calculated in Table 4, below

Table 4. Baltimore NAA Non-Creditable Emission Reductions (Ozone Season tnd)

Source Category VOC NOx(i) 2002 On-Road 101.876 211.145

(ii) 2008 On-Road 92.778 188.541

Non-creditable

9 10 22 60 Reductions (i) — (ii)

D & E) Maryland’s calculations ofthe Baltimore NAA 2002 VOC and NOx inventories

adjusted relative to 2008 and VOC and NOx target levels for 2008 are found in Table 5-4and Appendix C ofthe Baltimore 8-hour ozone plan, and are summarized in Table 5, below.

Table 5. Baltimore NAA 2008 RFP Target Level Calculations (Ozone Season t )d)

Description Formula VOC NOx

A 2002 Rate-Of Progress Base Year Inventory 271.48 338.08

B FMVCP/RVP Reductions Between 2002 And 2008 9.10 22.60C 2002 Adjusted Base Year Inventory Relative To 2008 A -B 262.383 15.48

D RFP Ratio 0.08000.0700

E Emissions Reductions Required Between 2002 & 2008 C * D 20.99 22.08

F Target Level for 2008 C -E 241.39293.40

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Projected controlled 2008 emissions for the Baltimore NAA are summarized in Table 4-3

of the Baltimore 8-hour ozone plan. The data from Table 4-3 is presented in Table 6, below.

Table 6. Baltimore NAA 2008 Projected Controlled VOC & NOx Emissions (tpd)

Emission Source VOC Emissions NOx Emissions

Category (tpd) (tpd)

Point 15.63 122.64

Area 108.17 8.43

Non-road 54.21 39.60

Mobile 41.23 106.84

Total 219.25 277.50

To determine if 2008 RFP is met in the Baltimore NAA, the total projected controlled

emissions must be compared to the target levels calculated in the previous section of thisdocument. As shown below in Table 7, the total VOC and NOx emission projections meet the

2008 emission targets. Therefore, the 2008 RFP in the Baltimore NAA is demonstrated.

Table 7. Determination of whether RFP is met in 2008 in the Baltimore NAA

VOC Emissions NOx Emissions Description (tpd) (tpd)

I Total 2008 Projected A Controlled Emissions 219.25 277.50

B Target Level for 2008 241.39 293.40

RFP met if A < B Yes Yes

IV. Control Measures and Emission Reductions for RFP

The control measure Maryland took credit for in order to meet the RFP requirement in the

Baltimore NAA are described in Section 6.0 of the Baltimore 8-hour ozone plan. To meet theRFP requirement for the Baltimore NAA, Maryland used a combination of (1) on-road mobile,

(2) non-road mobile, and (3) area source control measures.(1) On-Road Mobile Measures

Maryland calculated the emission reductions for 2008 REP using the MOBILE model for

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which require 1-hour ozone J/M programs to continue until the areas have attained the 1997 8hour ozone standard. Maryland’s enhanced JIM program, COMAR 11.14.08, was effective on

January 2, 1995. EPA approved the program into the Maryland SIP on October 29, 1999.EPA approved Maryland’s revisions to the program on January 16, 2003. See 40 CFR

52. 1070.

• Tier I Vehicle Emission Standards and New Federal Evaporative Test Procedures

The CAA required cleaner federal motor vehicle emissions standards (Tier I standards)

beginning with model year 1994. The CAA also requires a uniform level of evaporative

emission controls, which are more stringent than most evaporative controls used in older

vehicles. These federally implemented programs affect light duty vehicles and trucks. See 40

CFR Part 86.

• Reformulated Gasoline in On-Road Vehicles

Staring in 1995, only EPA- certified reformulated gasoline was allowed to be sold in in the

nine worst ozone nonattainment areas with populations exceeding 250,000, including theBaltimore NAA. The first phase of the RFG program was designed to reduce ozone precursoremissions by 64,000 tons per year (tpy) in RFG areas. The second (current) phase of the RFG

program began in 2000, and is designed to reduce ozone precursor emissions by an additional41,000 tpy in RFG areas. The program has been in place in the Baltimore NAA since 1995.

• National Low Emission Vehicle (NLEV) Program

The NLEV program is a vehicle technology program that provides light duty vehicles and

trucks that are significantly cleaner than pre-1998 models. The National LEV program was

developed through an unprecedented, cooperative effort by the northeastern states, auto

manufacturers, environmentalists, fuel providers, EPA, and other interested parties. NationalLEV vehicles are 70% cleaner than 1998 models. The National LEV program will result in

substantial reductions in VOCs and NOx. Maryland adopted the NLEV program on March

22, 1999, at COMAR 26.11.20.04. EPA approved COMAR 26.11.20.04 into the Maryland

SIP on December 28, 1999. See 40 CFR 52.1070.

• Federal Heavy-Duty Diesel Engine (HDDE) Rule

EPA’s heavy-duty engines rule addresses diesel vehicles weighing more than 8,500 pounds.These standards took effect in 2007, and will reduce emissions from new HDDEs by 95%

using ultra-low sulfur diesel fuel will be needed. See 40 CFR Part 86.As discussed in the Baltimore Emission Inventory TSD, EPA Region 3’s AQAB reviewed the

procedures that MDE used to develop its projected inventories, including the use of the

8
• Non-Road Small Gasoline Engines

This federal measure requires small gasoline-powered engine equipment, such as lawn andgarden equipment, manufactured after August 1, 1996 to meet federal emissions standards.

These measures apply to equipment with engines of less than 25 horsepower. VOC emissions

result from combustion and evaporation of gasoline used to power this equipment. See 40

CFR parts 90 and 91.

• Non-Road Diesel Engines Tier I and Tier II

This federal measure sets emissions standards for non-road, compression-ignition utilityengines rated at 37 kilowatts or above. This measure applies to all compression-ignitionengines except engines used in aircraft, marine vessels, locomotives and underground miningactivity. NOx emissions result from combustion of diesel fuel used to power this equipment.

See 69 FR 38957, June 29, 2004 and 40 CFR Parts 9, 69, 80, 86, 89, 94, 1039, 1048, 1051,

1065, and 1068.

• Marine Engine Standards

This measure controls exhaust emissions from new spark-ignition (SI) gasoline marine

engines, including outboard engines, personal watercraft engines, and jet boat engines. See40 CFR Parts 89, 90, and 91.

• Emissions Standards for Large Spark Ignition Engines

This federal measure controls VOC and NOx emissions from several groups of previously

unregulated non-road engines, including large industrial spark-ignition engines, recreational

vehicles, and diesel marine engines. The emission standards apply to all new engines sold in

the United States and any imported engines manufactured after these standards begin.

Controls on the category of large industrial spark-ignition engines are first required in 2004.Controls on the other engine categories are required beginning in years after 2005. See 40CFR Parts 89, 90, 91, 94, 1048, 1051, 1065, and 1068.

• Reformulated Gasoline Use in Non-Road Motor Vehicles and Equipment

This federally mandated measure requires the use of lower polluting reformulated” gasoline

in the Baltimore NAA. See “Reformulated Gasoline in On-road Vehicles,” above. This

measure affects the various non-road mobile sources that burn gasoline, such as lawn mowers,

trimmers, generators, and compressors. The program has been in place in the Baltimore NAA

since 1995.

As discussed in the Baltimore Emission Inventory TSD, EPA Region 3’s AQAB reviewed the

9
diesel

powered locomotives and 

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s 

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at

o

too

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ect 

000. See

63 FR 18998, April 16, 1998, and 40 CFR Parts 92.

Emission Benefit Calculation: Projected reductions are based on an emission reductionfactors derived from the April 1998 “Locomotive Emission Standards Regulatory Support

Document” from EPA’s Office of Mobile Sources, which is attached. Tables 6-2 and 6-3 of

the “Locomotive Emission Standards Regulatory Support Document” give expected emissionreduction factors for class I line-haul and class I switch railroad engines for the years 2000through 2040, in 5 year increments. Control efficiency (CE) factors for the years 2002 and

2008 were calculated through linear interpolation, as explained below.

The class I line-haul railroad engine NOx emission reduction factors for 2000, 2005, and2010 are 0.0100, 0.3200, and 0.4600, respectively.

Interpolation for 2002: 0.0100 + (0.3200 - 0.0100) x 2/5 = 0.134 = CE2002Interpolation for 2010: 0.3200 + (0.4600 - 0.3200) x 3/5 = 0.404 = CE2008

The class I switch railroad engine NOx emission reduction factors for 2000, 2005, and2010 are 0.0000, 0.0700, and 0.1700, respectively.

Interpolation for 2002: 0.0000 + (0.0700 - 0.0000) x 2/5 = 0.0280 = CE2002Interpolation for 2010: 0.0700 + (0.1700 - 0.0700) x 3/5 = 0.1300 = CE2008

To determine the projected uncontrolled 2008 VOC emissions for railroad engines, two sourceclassification codes (SCC5) were identified. Projected emissions were pulling from AppendixC of the Baltimore 8-hour ozone plan. Please note that Appendix C of the Baltimore 8-hourozone plan uses Federal Information Processing Standard (FIPS) county codes in lieu ofcounty names. See Table 8 for 2008 projected uncontrolled emissions.

Table 8. Rail Road Engine Uncontrolled 2008 VOC Emissions in the Baltimore NAA

County Name & FIPS Code SCC Source Subcategory NOx (tpd)

Anne Arundel 24003 2285002005 railroad line haul 0.264270646Baltimore 24005 engines 1.187250336

Carroll 24013 (Class I Line-Haul) 0.518027224

Harford 24025 0.556217163Howard 24027 0.512464138Baltimore City 24510 0.988266157

Total 4.026495664

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Emissions benefits for both source categories are calculated by multiplying 2008 uncontrolledemissions by the difference between CE2008 and CE2002, and multiplying by the ruleeffectiveness (RE) and rule penetration (RP) factors.

2008 Controlled = 2008 Uncontrolled

x [CE2008 — CE2002] x RE x RP Emissions Emissions

Assuming RE and RP of 1, the 2008 emissions benefits for class I line-haul and class I switch

railroad engines are as follows:

Class I Line-Haul: 4.026495664 X (0.4040 — 0.1340) = 1.087 tpdClass I Line-Switch: 2.725477153 X (0.1300 - 0.0280) = 0.278 tpd

Railroad Engine Projected 2008 Emission Reductions are: 1.087 + 0.278 = 1.37 tpdNOx.

(3) Area Source Measures

• Architectural and Industrial Maintenance (AIM) Coatings

A federal measure requires reformulation of AIM coatings, which are field-applied coatings

used by industry, contractors, and homeowners to coat houses, buildings, highway surfaces,and industrial equipment for decorative or protective purposes. VOC emissions result from

the evaporation of solvents from the coatings during application and drying. Maryland’s AIMrule, COMAR 26.11.33, was effective on March 29, 2004. EPA approved this rule into the

Maryland SIP on May 12, 2005, and approved revisions to COMAR 26.11.33 on October 19,

2005. See 40 CFR 52.1070.Emission Benefit Calculation: Projected reductions are based on an emission reduction

factor of 31 percent, based on the E.H. Pechan report, “Control Measure Development

Support Analysis for the Ozone Transport Commission Model Rules,” dated March 31, 2001

(2001 Pechan report), which is attached. See page 15 ofthe 2001 Pechan report.

To determine the projected uncontrolled 2008 VOC emissions for AIM coatings, six SCCswere identified. Projected emissions were pulling from Appendix C ofthe Baltimore 8-hourozone plan. See Table 9 for 2008 projected uncontrolled emissions.

11
g

g

Baltimore 2401002000 solvent-based architectural surface coatings 1.97675910824005 2401003000 water-based architectural surface coatings 1.744926361

2401008000 traffic paints 0.0666762142401100000 surface coatings for industrial maintenance 1.075350925

2401200000 surface coatings - other categories 1.075350925

Carroll 2401002000 solvent-based architectural surface coatings 0.4306536 19

24013 2401003000 water-based architectural surface coatings 0.380146903

2401008000 traffic paints 0.04 12535892401100000 surface coatings for industrial maintenance 0.2135196552401200000 surface coatings - other categories 0.2135 19655

Harford 2401002000 solvent-based architectural surface coatings 0.609513406

24025 2401003000 water-based architectural surface coatings 0.538030155

2401008000 traffic paints 0.026703812

2401100000 surface coatings for industrial maintenance 0.3 002808792401200000 surface coatings - other categories 0.300280879

Howard 2401002000 solvent-based architectural surface coatings 0.69873 87724027 2401003000 water-based architectural surface coatings 0.616791239

2401008000 traffic paints 0.035127521

2401 100000 surface coatings for industrial maintenance 0.327773 0582401200000 surface coatings - other categories 0.327773 058

Baltimore City 2401002000 solvent-based architectural surface coatings 1.5701 15754

24510 2401003000 water-based architectural surface coatings 1.385973818

2401008000 traffic paints 0.0 14666465

2401 100000 surface coatings for industrial maintenance 0.82789295 8

2401200000 surface coatings - other categories 0.827892958

Total for the Baltimore NAA 19.4219826

Please note that Table 9 contains emission information for five ofthe six identified SCCs.Zero emissions were projected for all counties for the sixth SCC, 2401008999: traffic paint

solvents. As stated above, counties are identified by FIPS code and not name in Appendix C

of the Baltimore 8-hour ozone plan.

AIM Coating Projected 2008 Emission Reductions are: 19.4219826 x 31% = 6.02 tpdVOC.

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2003, and approved revisions to COMAR 26.11.32 (phase 2) on December 10, 2007. See 40

CFR 52.1070.

Emission Benefit Calculation: Projected reductions are based on an emission reductionfactor of 14.2 percent, based on the 2001 Pechan report, page 8.

To determine the projected uncontrolled 2008 VOC emissions for consumer and commercial

products, one SCC was identified. Projected emissions were pulling from Appendix C oftheBaltimore 8-hour ozone plan. As stated above, Appendix C of the Baltimore 8-hour ozone

plan uses FIPS county codes in lieu of county names. See Table 10 for 2008 projected

uncontrolled consumer and commercial products emissions.Table 10. Consumer and Commercial Products Uncontrolled 2008 VOC Emissions in

the Baltimore NAA

County Name & FIPS Code SCC Source Subcategory VOC tpd

Anne Arundel 24003 2465000000 Emissions from 5.08606 1964

Baltimore 24005 commerciallconsumer solvents 7.829989181Carroll 24013 1.705829083

Harford 24025 2.414296893Howard 24027 2.767720653Baltimore City 24510 6.2192653 18

Total for the Baltimore NAA 26.02316309

Consumer and Commercial Products Projected 2008 Emission Reductions are:

26.02316309 x 14.2% = 3.70 tpd VOC.

• Portable Fuel Containers Rule, Phase I

This measure introduces performance standards for portable fuel containers and spouts, and isintended to reduce emissions from storage, transport and refueling activities. The rule alsoincluded administrative and labeling requirements. Maryland’s portable fuel container rule,

COMAR 26.11.13.07, was effective on January 21, 2002. EPA approved this rule into the

Maryland SIP on December August 30, 2004 (69 FR 38848), and approved revisions to

COMAR 26.11.13.07 (phase 2) on June 17, 2008 (73 FR 40970). See 40 CFR 52.1070.

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10 years

To determine the projected uncontrolled 2008 VOC emissions for portable fuel containers, six

SCCs were identified. Projected emissions were pulling from Appendix C of the Baltimore 8-

hour ozone plan. As explained above, Appendix C ofthe Baltimore 8-hour ozone plan usesFIPS county codes in stead of county names. See Table 11, below.Table 11. Portable Fuel Container Projected Uncontrolled 2008 VOC Emissions in theBaltimore NAA

County Name & SCC Source Subcategory VOC tpd

FIPS CodeAnne Arundel 2501011011 Residential -Permeation Area 0.11805324003 2501011012 Residential -Diurnal Area 1.015461

2501011016 Residential -Transport Area 0.055372501012011 Commercial -Permeation Area 0.0135812501012012 Commercial-DiurnalArea 0.181782501012016 Commercial -Transport Area 2.763266

Baltimore 2501011011 Residential - Permeation Area 0.196545

24005 2501011012 Residential - Diurnal Area 1.700588

2501011016 Residential -Transport Area 0.0935432501012011 Commercial -Permeation Area 0.0178682501012012 Commercial -Diurnal Area 0.2270252501012016 Commercial -Transport Area 3.448473

Carroll 2501011011 Residential -Permeation Area 0.037711

24013 2501011012 Residential -Diurnal Area 0.324979

2501011016 Residential -Transport Area 0.0177462501012011 Commercial - Permeation Area 0.0066552501012012 Commercial -Diurnal Area 0.0865132501012016 Commercial - Transport Area 1.318773

Harford 2501011011 Residential -Permeation Area 0.0559 124025 2501011012 Residential - Diurnal Area 0.483459

2501011016 Residential -Transport Area 0.026311

2501012011 Commercial -Permeation Area 0.006578

2501012012 Commercial -Diurnal Area 0.0887992501012016 Commercial - Transport Area 1.351712

Howard 2501011011 Residential -Permeation Area 0.062711

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Portable Fuel Containers Projected 2008 Emission Reductions are 19.71095 tpd x41.25% 8.13 tpd VOC.

RFP Emission Reduction SummaryFor certain control measures, the 2008 projected emission reductions calculated in this documentdiffer from the 2008 projected emission reductions that MDE has taken credit for in the

Baltimore 8-hour ozone plan. The total 2008 projected emission reductions calculated by EPA

are greater than the emission reductions claimed by MDE in the Baltimore 8-hour ozone plan.

Therefore, the emission reductions claimed in the Baltimore 8-hour ozone plan are approvable.Table 12 summarizes the emission reductions from each control measure and compares EPA’scalculated values with the reductions claimed in the Baltimore 8-hour ozone plan.

Table 12. Control Measures and 2008 Emission Reductions in the Baltimore NAA — Comparison of EPA Calculations and Baltimore 8-hour Ozone Plan

Baltimore 8-hour EPA Calculation Ozone Plan

VOC NOx VOC NOx Control Measure (tpd) (tpd) (tpd) (tpd)

On-road Mobile Measures 42.45 59.10 42.45 59.10

Non-road Model 17.89 6.74 17.89 6.74

Railroads (Tier2) 0.00 1.37 0.00 1.18

OTC -Consumer Products Phase 1 3.70 0.00 3.70 0.00OTC — AIM Coatings 6.02 0.00 6.03 0.00OTC —Portable Fuel Containers Phase 1 8.13 0.00 6.71 0.00

Total 78.19 67.21 76.78 67.02

2501012011 Commercial -Permeation Area 0.01 1077

2501012012 Commercial- Diurnal Area 0.1379562501012016 Commercial - Transport Area 2.094509

Total for the Baltimore NAA 19.7 1095

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reductions of at least 3 percent of the adjusted 2002 baseline emissions must be achieved. For

more information on contingency measures, see the April 16, 1992 General Preamble (57 FR

13512) and the November 29, 2005 Phase 2 8-hour ozone implementation rule (70 FR 71612).

To meet the requirements for contingency emission reductions, EPA allows states to use

NOx emission reductions to substitute for VOC emission reductions in their contingency plans.

However, MDE chose to use only VOC reductions to meet the contingency measure requirementin the Baltimore NAA. MDE discusses its Baltimore NAA contingency measures for failure to

meet RFP in Section 10.2 of the Baltimore 8-hour ozone plan. MDE calculated the contingencyVOC reduction for the Baltimore NAA as shown in Table 13, below. The RFP contingency

requirement may be met by including in the RFP plan a demonstration of 18 percent VOC &

NOx RFP. The additional 3 percent reduction above the 15 percent requirement must be

attributed to specific measures.

Table 13. Baltimore NAA 2008 RFP Contingency Measure Target Level Calculations

Description Formula VOC NOx

A ‘!002 Rate-Of Progress Base Year Inventory 271.48 338.08

B FMVCP/RVP Reductions Between 2002 And 2008 9.10 22.60C 002 Adjusted Base Year Inventory Relative To 2008 A -B 262.38 315.48

D FP Ratio 0.0800 0.0700

RFP Emissions Reductions Required Between 2002 &

F 2008 C * D 20.99 22.08F Contingency Percentage 3.00 0.00

G Contingency Emission Reduction Requirements C * F 7.87 0.00

H Contingency Measure Target Level for 2008 C — E — G 233.52 293.40

To determine if Maryland meets the three percent contingency measure requirement for the

Baltimore NAA, the total projected controlled emissions must be compared to the contingency

measure target levels calculated above. As shown below in Table 14, the total VOC and NOx

emission projections meet the 2008 contingency measure targets. Therefore, MDE has met the

contingency measure requirement for the Baltimore NAA

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VI. RACM Analysis and Determination

Pursuant to section 1 72(c)( 1) ofthe CAA, states are required to implement all RACM as

expeditiously as practicable for each nonattainment area. Specifically, section 172(c)(l) states

the following: “In general—Such plan provisions shall provide for the implementation of all

reasonably available control measures as expeditiously as practicable (including such reductions

in emissions from existing sources in the area as may be obtained through the adoption, at a

minimum, of reasonably available control technology) and shall provide for attainment ofthe

national primary ambient air quality standards.” Furthermore, in EPA’s Phase 2 Rule, EPA

describes how states must include a RACM analysis with their attainment demonstration (70 FR71659). The purpose of the RACM analysis is to determine whether or not reasonably available

control measures exist that would advance the attainment date for nonattainment areas. Control

measures that would advance the attainment date are considered RACM and must be included in

the SIP. RACM are necessary to ensure that the attainment date is achieved “as expeditious as

practicable.” RACM is defined by the EPA as any potential control measure for application topoint, area, on-road and non-road emission source categories that meets the following criteria:

• The control measure is technologically feasible

• The control measure is economically feasible• The control measure does not cause “substantial widespread and long-term adverse

impacts”

• The control measure is not “absurd, unenforceable, or impracticable”• The control measure can advance the attainment date by at least one year.

MDE addresses the RACM requirement in Section 7.0 and Appendix E of the Baltimore

8-hour ozone plan. To meet the RACM requirement, Maryland must demonstrate that it has

adopted all RACM necessary to move the Baltimore NAA toward attainment as expeditiously as

practicable and to meet all RFP requirements. As demonstrated above in section TV of this

document, Maryland has met the RFP requirements for the Baltimore NAA.

MDE used two independently developed lists of potential control measures for its RACM

analysis. The first list consists of the RACM analysis performed for the Washington, DC NAA’s

8-hour ozone plan. The second list of measures was developed by the Baltimore Metropolitan

Council (BMC) with MDE in 2006. These measures are evaluated in Appendices E-1 and E-2 of

the Baltimore 8-hour ozone plan.

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reductions in the 2008 ozone season. Therefore, the measures must be

implemented by May 2008.

• Is it economically feasible ($3,500-$5,000 per ton or less)?

o In the Baltimore 8-hour ozone plan, MDE states that this cost per ton range is

based on the Reasonably Available Control Technology (RACT) costs in theBaltimore NAA, which MDE states are as low as $3,500 per ton.

• Would it create substantial or widespread adverse impacts within the region?

o In the Baltimore 8-hour ozone plan, MDE states that, “some candidate RACM

measures have the potential to cause substantial and widespread adverse impacts

to a particular social group or sector ofthe economy. Due to environmental

justice concerns, measures that cause substantial or widespread adverse impacts

will not be considered RACM.”

• Do the source’s emissions exceed a de minimis threshold, proposed as 0.1 tpd?

o The April 16, 1992 General Preamble for the Implementation of Title I ofthe

Clean Air Act Amendments of 1990 (57 FR 13498) states that measures can be

excluded from further consideration in a RACM analysis ifthose measures haveinsignificant (de minimis) emissions. “Where the sources affected by a particular

measure contribute only negligibly to ambient concentrations that exceed the

NAAQS, EPA’s policy is that it would be unreasonable and therefore would not

constitute RACM to require controls on the source.”

o In the Baltimore 8-hour ozone plan, MDE states that while the smallest major

source subject to RACT in a moderate NAA emits 50 tpy, MDE considered 25 tpy(approximately 0.1 tpd) sources. MDE further states that following the RACT

requirements and the precedent set by the San Francisco RACM analysis, it willnot consider control measures affecting source categories that produce less that

0.1 tpd NOx or VOC emissions.

Maryland evaluated over 200 potential control measures against these criteria. No

measures were found to be RACM. However, MDE states in the Baltimore 8-hour ozone plan

that many of the measures are worthwhile in that they can reduce emissions. MDE further states

that it will consider these potential control measures for future SIP revisions for the Baltimore

NAA.

EPA has reviewed MDE’s analysis. MDE evaluated all source categories that could

contribute meaningful emission reductions, and compiled an extensive list of potential control

measures. MDE considered the time needed to develop and adopt regulations and the time itwould take to see the benefit from these measures. EPA concurs with MDE’s conclusion that

there are no RACM that would have advanced the 2010 attainment date for the Baltimore NAA.

18
co

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adequacy ofsubmitted SIP budgets is described in 40 CFR 93.118(f).

States must establish VOC and NOx MVEBs for each ofthe milestone years up to the

attainment year and submit the mobile budgets to EPA for approval. Upon adequacydetermination or approval by EPA, states must conduct transportation conformity analysis for

their Transportation Improvement Programs (TIPs) and long range transportation plans to ensurehighway vehicle emissions will not exceed relevant MVEBs. Failure of demonstrating suchtransportation conformity lapses resulting in freezing of federal highway funds and all federalhighway projects in the lapsed area.

MDE discusses transportation conformity in Section 8.0 ofthe Baltimore 8-hour ozone

plan. MDE, in consultation with the Baltimore Regional Transportation Board (BRTB),

established MVEBs for 2008 MDE calculated the 2008 mobile emissions inventory using

EPA’s MOBILE6.2 and the Highway Performance Monitoring System (HPMS) model. MDEdescribes its methods in Appendix F of the Baltimore 8-hour ozone plan. MDE also established

MVEBs for 2009, but EPA is not evaluating that budget in this document.

The Baltimore NAA MVEB for the 2008 RFP is based on the projected 2008 mobile

source emissions accounting for all mobile control measures. The MVEBs for the 2008 RFP areshown in Table 15, below.

Table 15. Baltimore NAA 2008 RFP MVEBs

VOC (tpd) NOx (tpd)41.2 106.8

For budgets to be approvable, they must meet, at a minimum, EPA’s adequacy criteria

(40 CFR 93.1 18(e)(4)). In a March 27, 2009 Federal Register notice, EPA notified the public

that EPA found that the 2008 RFP MVEBs in the Baltimore 8-hour ozone plan are adequate fortransportation conformity purposes. (74 FR 13433) As a result of EPA’s finding, the State of

Maryland must use the MVEBs from the June 4, 2007 Baltimore 8-hour ozone plan for futureconformity determinations for the 8-hour ozone standard.

In addition to the budgets being adequate for transportation conformity purposes, as

stated above, EPA Region 3’s AQAB found the procedures Maryland used to develop the

MVEBs to be reasonable. The budgets are identical to the projected 2008 on-road mobile sourceemission inventories. (See Table 6, “Baltimore NAA 2008 Projected Controlled VOC & NOxEmissions (tpd).”) Because the 2008 RFP MVEBs are adequate for transportation conformity

19
Region 3

s AQAB determined that MDE used acceptable techniques and methodologies to

develop the Baltimore NAA 2002 base year emission and 2008 milestone year projectedinventories. Furthermore, EPA has found the Baltimore NAA’s 2008 RFP MVEBs adequate for

transportation conformity purposes. Therefore I recommend approval ofthe following SIPelements in MDE’s June 4,2007 Baltimore 8-hour ozone plan: the 2002 base year emissions

inventory, the RFP plan and associated 2008 projected emission inventories, the RACM analysis,

the contingency measures for failure to meet 2008 RFP, and the 2008 MVEBs for the Baltimoremoderate nonattainment area.

Attachments:

- “Technical Support Document (TSD) for the Baltimore Nonattainment Area: 8 Hour Ozone

State Implementation Plan (SIP) Attainment Demonstration and Base Year Inventory,”

prepared by Alice H. Chow and signed by Walter Wilkie, Air Quality Analysis Branch Chief,

on December 19, 2008 (Baltimore Emission Inventory TSD).

- EPA Office of Mobile Sources, “Locomotive Emission Standards Regulatory Support

Document,” April 1998.

- “Technical Support Document, COMAR 26.11.13.07, Control of VOC Emissions from

Portable Fuel Containers,” MDE, undated.

- E.H. Pechan, “Control Measure Development Support Analysis for the Ozone Transport

Commission Model Rules,” March 31, 2001.

- Adequacy Status of the 2008 Reasonable Further Progress Plan for the Baltimore 8-Hour

Ozone Nonattainment Area Motor Vehicle Emission Budgets (74 FR 13433).

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