UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 Sixth Avenue Seattle, WA 98101-3140

MEMORANDUM

SUBJECT: Review of Fairbanks Nonattainment Area Filterable/ Condensable PM 2.5 Emission

I n ventory

FROM: Matthew Jentgen, APU

TO: Claudia Vaupel, APU

The Alaska Department of Environmental Conservation (ADEC) submitted additional clarifying information on the filterable and condensable components of direct PM 2.5 on October 27, 2016 and No vember 3, 2016, as part of the emissions inventory prepared for the Fairbanks PM 2.5 nonattainment area (N AA). This clarifying information satisfies the requirements of EPA’s “ Fine Particulate Matter National Ambient Air Quality Standards: State Implementation Plan Requirements ” (2016 PM 2.5 Implementation Ru le, 40 CFR 51.1008(a)(1)(iv)), requiring that the inventory shall include separately reported PM 2.5 fi lterable and condensable emissions.

The clarifying information focused on the stationary point sources category, which was the only source category in the NAA for which PM 2.5 filterable and condensable emissions were available. 1 These steps

we re taken in accordance with the 2016 PM 2.5 Implementation Rule and in accordance with the draft

em issions inventory guidance. While other important PM 2.5 sources such as residential wood combustion

ex ist in the Fairbanks nonattainment area, no condensable PM 2.5 data are available for these sources in E P A’s Webfire, AP-42, or state databases.

Consequently, ADEC included PM 2.5 filterable and condensable emissions for its 2008 base-year inventory, 20 15 attainment-year projected inventory, and the 2017 RFP inventory. 2 In its October 27, 2016 submittal, AD EC noted that four of the point source facilities had incorrectly reported direct PM 2.5 emission factors, wi th two underreporting the condensable fraction for specific emission units and two others using conservative or overstated emission factors. This correction led to a modest PM 2.5 emissions increase in the NA A from 4.93 tons per day to 5.04 tons per day. ADEC then provided an analysis based on prior CMAQ modeling runs included in the initial 2014 SIP submittal to show that the scaled impact of the modeling correction was an increase of 0.12 μg/m 3 , a value that ADEC stated had no meaningful impact on the SIP

at tainment findings.

In its November 3, 2016 submittal, ADEC provided PM 2.5 filterable and condensable emissions as tons per da y at each of the stationary point sources. Excluding the emissions values from Eielson Air Force Base, which is outside the nonattainment area (as required by 40 CFR 51.1008(a)(1)(ii)), the emissions values for each stationary point source are included in the table below.

1 Due to the very minor contribution to PM 2.5 in the Fairbanks NAA from oil-fired heating devices, separate fi lterable and condensable emissions were not included for this source category.

2 This submittal was intended to clarify the modeling analysis for the Moderate area emissions inventory,

su bmitted December 2014. The 2008 emissions levels were held constant for stationary point sources in the Fairbanks NAA, so 2015 modeled emissions levels were identical to 2008. This is due to the modest demand growth forecast in the area and uncertainty in emissions reductions resulting from fuel switching at two facilities to cleaner distillate triggered by the shutdown at the supplying oil refinery.Facility Name Winter Season Average Day Direct PM 2.5 Emissions (tons/day) due to rounding, values may not be exact Condensable PM 2.5 Filterable

PM 2.5 Total Direct

PM 2.5 Flint Hills North Pole Refinery 0.034 0.018 0.053

GVEA Zehnder 0.044 0.074 0.119

GVEA North Pole Power Plant 0.299 0.501 0.799 Aurora Energy Chena Power Plant 0.170 0.009 0.179 UA Fairbanks Campus Power Plant 0.006 0.070 0.076 Doyon Utilities Ft. Wainwright Units 0.275 0.014 0.289

Total 0.828 0.686 1.515

ADEC has provided PM 2.5 filterable and condensable emissions information f rom its relevant sources. Thus, this information meets the requirements in th e 2016 PM 2.5 Implementation Rule (40 CFR 51.1008(a))

. The Fairbanks NAA emissions inventory tables have b een updated accordingly.