Technical Support Document (TSD) For for Cecil County, Maryland, located

in the Philadelphia-Wilmington-Atlantic

City, PA-NJ-DE 8 Hour Ozone Nonattainment

Area: State Jinpiementation

Plan (SIP) Attainment Demonstration and Base Year Inventory. Submitted
June
15, 2007
by the Maryland Department

of the Environment TSD Prepared December,
2008 Alice

H. Chow Air Quality Analysis Branch, 3AP22 U.S. Environmental Protection Agency, Region

3 1650 Arch Street Philadelphia, Permsylvania

19103 Reviewed

by Walter Wilkie, Chief Air Quality Analysis Branch (3AP22) /2/’ Date SignedI. Introduction The purpose

of this document

is to provide

a technical summary

of the Air Quality Analysis Branch’s (AQAB) review

of the emissions inventories submitted
with the Cecil County, Maryland’s portion

of the Philadelphia Nonattainment

Area

8 Hour Ozone State Implementation

Plan (SIP)
by the Maryland Department

of the Environment (MDE). This review determines

the approvability

of the SIP Base Year Inventory

and an evaluation

of the methods used for projection

year inventories.

A SIP Base Year Inventory

is the starting point from which other SIP inventories

are derived

as well

as serving

as the benchmark

for other SIP planning activities,
such

as the establishment

of an emissions reduction credit program. Projection
year inventories

are essentially
used

to track progress;

the purpose

of which

is to demonstrate

a reduction

in emissions

of regulated sources from the Base Year

to

a projected
year. Cecil County,

a part of the Philadelphia Nonattainment

Area, was designated

as an

8 hour ozone nonattainment

area with

a Subpart

2 classification. Subpart

2 area(s)

are required

to submit initial SIP base year inventories

to EPA by June
15, 2006; with the final Base Year inventory

due with the SIP
to EPA by June
15, 2007. Maryland Department

of the Environment

has submitted Cecil County

as MDE’s portion

of the Philadelphia Nonattainment

Area

8 Hour Ozone SIP and has requested EPA’s approval. Any questions pertaining

to this technical summary should

be directed

to Walter K. Wilkie, Chief, Air Quality Analysis Branch,

at 215-814-2150

or via email

at wilkie.walter(epa.gov. II 2002 SIP Base Year Inventory The SIP base year inventory

is the primary inventory
from which other inventories (3-year cycle inventories, reasonable further progress inventories, modeling inventories)

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

to ensure that the base year inventory

is comprehensive, accurate,

and current

for all actual emissions. 1

The base year inventory includes emissions estimates from stationary point and nonpoint sources, onroad mobile sources,
and nonroad mobile sources.

For the
8- hour ozone NAAQS,

the pollutants

to be inventoried

are VOC, NOx and CO (carbon monoxide).

For the 8-hour ozone NAAQS, VOC, NOx and CO emissions should

be reported

as actual annual and actual summer weekday emissions (defined

as an average day’s emissions

for

a typical summer
day during
the ozone season). MDE’s base year inventOry

is for 2002. The Philadelphia Nonattainment

Area (Philadelphia— Wilmington— Atlantic City, PA-DE-MD-NJ) includes Cecil County, MD.

A significant amount

of documentation

is required

for these SiP base year estimates which MDE has provided. In the MDE request,

the base year used was 2002. MDE’s
Air and Radiation Management Administration (ARMA)

is primarily responsible

for compiling

the Point “Emissions Inventoty Guidance

for Implementation

of Ozone and Particulate Matter National Ambient Air Quality Standards (NAAQS)

and Regional Haze Regulations” EPA-454/R-05-001,

August 2005Sourcedatafor2002.ARMAusesseveralformsofsourceidentification.Thestate’sprimarydatasourceisfromitspermittingprogram,whichincludespermitapplicationsandequipmentregistrations.ARMAalsoreliesonitsthecomplianceprogram,whichinvolvesusinginformationgatheredfrominspectionsandcitizencomplaints.ARMAprovidedits2002actualtypicalsummer(duringpeakozoneseason—June,July,August)weekdayemissionsforNOxandVOCatthefacilitylevelandattheprocess-level.Forthe2002NonpointSourceemissions,alsoknownas“areasources,”ARMAprovidedaninventorythatcontainedestimationsofemissionsbymultiplyinganemissionfactorbysomeknownindicatororactivitylevelforeachcategoryatthecountylevel.Theseemissionsaretypicallycalculatedonanannualbasisbecausetheactivitydataaregenerallyonlyavailableonanannualbasis.ARMAfurtherconvertedtheseannualemissionstoseasonalemissions,forozone,thesummerseasonisdefinedaspeakozoneseasonmonthsofJune,July,andAugust.Varioussourcesofemissionfactorsormethodologieswereused,includingEPA’sAP-42,EPA’sEmissionsInventoryImprovementProgram,andEPAmobilesourcemodel.NonpointsourceestimateswereprovidedbySCC.TheNonroadMobileSource2002inventorywaspreparedwithEPA’sNONROAD2005model,versionasof03/21/2006,andEPAemissionfactors.NONROADestimatesfuelconsumptionandemissionsoftotalhydrocarbons,carbonmonoxide,nitrogenoxides,sulfurdioxide,andparticulatematterforallnonroadmobilesourcecategoriesexceptforaircraft,locomotives,andcommercialmarinevessels.ARMAprovidedemissionestimatesforlocomotiveengines,aircraftemissionsandcommercialmarinevesselsseparately.Forlocomotiveengineandlinehaulemissions,ARMArequestedandreceivedfuelusageandtrackmileagedatafromall13railroadsoperatinginMaryland.PairedwithEPAemissionandconversionfactors,ARMAcalculatedlocomotiveemissionsforthebaseyear.Foraircraftemissions,ARMAusedseveralsourcesofinformation:FederalAviationAdministration’s(FAA)AirportActivityStatisticsofCertificatedRouteAirCarriers;landingandtakeoffcycleinformationbyairportinMaryland;AviationAdministrationandtheFederalAviationAdministrationAirportLicenseRenewalApplications;andFAA’sEmissions&DispersionModelingSystem(EDMS).Forcommercialmarinevessels,ARMAusedtheemissioninventorypreparedfortheMarylandPortAdministrationbyEdwardsandKelcey(E&K).E&KanalyzedthemajorcategoriesofairemissionsassociatedwithshipandportoperationsandARMAallocatedthesecruisingemissionstoCecilCounty.E&KalsousedEPA’sguidance,AnalysisofCommercialMarineVesselsEmissionsandFuelConsumptionData,(EPA-450-R-00-002),February2000,tocalculateemissions.AllNonroadmobilesourceemissionswereprovidedbySCC.TheOnroadMobileSource2002emissionsinventorywasdevelopedusingthemostcurrentversionofEPA’shighwaymobilesourceemissionsmodelMOBILE6.2andtrafficactivitydatafromtheMarylandStateHighwayAdministration.ARMAalsousedPPSUITE,anenhancedversionofthePostProcessorforAirQualitysoftwaresystems.ARMAprovidedMobile6.2inputandoutputfilesforreview.MobileemissionsvaluesweregiveninunitsoftonspersummerdayandwereprovidedbySCC.ARMAalsoappliedruleeffectivenessandrulepenetrationforits20028-hourozoneSIPbaseyearinventories.Ruleeffectivenessreflectstheactualabilityofa4 regulatory program

to achieve

the emission reductions required

by regulation

(or perhaps voluntarily adopted). ARMA applied rule effectiveness

and where applicable, provided

a justification

of

a higher percentage

than EPA’s previous policy (which assumed

an 80% rule effectiveness

for applicable sources unless otherwise specified).
Rule penetration

is an estimate

of percentage

of emissions

in

a source category
that are emitted

at facilities subject

to the requirements

of

a rule. ARMA applied rule penetration

for its nonpoint sources where applicable. AQAB staff reviewed

the results, procedures,

and methodologies

for the SIP base year, and found them

to be approvable. III. 2008 and 2009 Projection Emission Inventories Projection inventories

are used

to show that the area will remain

in attainment. Projection inventories

for the years 2008 and 2009 were used for the Cecil County
SIP. The 2008 projected inventory

is required

for reasonable further progress (RFP) and the 2009 projected inventory

is required

for the attainment
year. Inventories
were developed for all emission sources

for both years. The Point Source emissions

for 2008 and 2009 were projected, using growth surrogates
from EPA’s Economic Growth
and Analysis System, Version

5.0 (EGAS 5.0). The Nonpoint Source emissions

for 2008 and 2009 were projected using growth factors

to account

for population, household, vehicle miles travelled (VMT)
and employment

data from the Baltimore Metropolitan Council,

the Maryland Department

of Planning,

and MDE Mobile Source Division. For the 2008 and 2009 Nonroad Mobile Source inventories, ARMA used EPA’s NONROAD2005

model

to generate these future inventories.

The NONROAD model allows
for the calculation

of past year, present year, and future year inventories

(up
to the year 2050)

to be generated. Growth

for locomotives

and commercial marine vessels came from employment

data

as surrogates;

and, aircraft growth from small airports were projected using EPA’s EGAS model. The 2008 and 2009 Onroad Mobile Source inventories
were generated using EPA’s MOBILE6.2

and the Highway Performance Monitoring System (HPMS) vehicle miles traveled growth rates. Input data was provided

by the Baltimore Regional Transit Board and Baltimore Metropolitan Council. ARMA then ran PPSUITE

to calculate VMT and speeds;

the output

is then run
in MOBILE6.2

to calculate emissions. AQAB staff reviewed

the procedures,

and found them

to be reasonable

for development

of these inventories.