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Control Measures, and Transportation Conformity Budgets for the Philadelphia

1997 8-Hour Ozone Moderate Nonattainment Area

FROM: Maria A. Pino, Air Quality Planning Specialist

Office of Air Program Planning

TO: File

7 /

TFIRU: 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 Cecil County portion

of the Philadelphia moderate nonattainment area. The SIP revision also establishes a motor

vehicle emissions budget (MVEB) for 2008 for the Cecil County portion ofthe Philadelphia

moderate nonattainment area. Maryland’s SIP revision submittal, entitled “Cecil County,Maryland 8-Hour Ozone State Implementation Plan and Base Year Inventory, SIP Number 07-05,” will be referred to as “the Cecil County 8-hour ozone plan” throughout this document.

A. BACKGROUNDI. 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 51.910) 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 inventory

is 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.

Pursuant to section 1 72(c)( 1) of the CAA, states are required to submit plans for
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 ofthe 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, andcontingency measures (40 CFR 51.908(a), (c)).

Section 182(b)(1) ofthe CAA and EPA’s 1997 8-hour ozone implementation rule (40

CFR 51.910) require each 8-hour ozone nonattainment area designated moderate and above tosubmit 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 baseline

emissions 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 isrequired within 6 years (2002-2008). 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 acombination of either. For a moderate area without and approved ROP plan, a 15% reduction inVOC is required. The reductions may come from anywhere within the 8-hour nonattainment

area. Table 1 outlines these requirements.

Table 1. RF’P 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)(1)(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.

In addition, RFP plans must include contingency measures, which are additional controls

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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

I-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

Philadelphia-Wilmington-Atlantic City moderate nonattainment area (Philadelphia NAA). This

NAA includes Cecil County in Maryland; Bucks, Chester, Delaware, Montgomery and

Philadelphia Counties in Pennsylvania; Atlantic, Burlington, Camden, Cape May, Cumberland,

Gloucester, Mercer, Ocean, and Salem Counties in New Jersey; and the entire State of Delaware.

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

under Subpart 2 of the 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 Philadelphia 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) of theCAA. For ozone nonattainment areas, the emissions inventory needs to contain VOC and NOxemissions 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 its portion ofthe Philadelphia NAA (i.e.,

Cecil County) on June 4, 2007. A summary ofthe Cecil County 2002 base year VOC and NOxemissions inventory is included in Table 2, below.

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Maryland discusses its 2002 base year inventory for the Cecil County in Section 3.0 of

the Cecil County 8-hour ozone plan. Appendix A ofthe Cecil County 8-hour ozone plan

contains Maryland’s 2002 base year inventory for Cecil County. EPA Region 3’s Air Quality

Analysis Branch (AQAB) reviewed Maryland’s 2002 base year inventory for Cecil County using

the appropriate EPA policy and guidance. Please see the attached “Technical Support Document

(TSD) for Cecil County, Maryland, located in the Philadelphia-Wilmington-Atlantic City, PA

NJ-DE 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 AnalysisBranch Chief, on December 19, 2008 (Cecil County Emission Inventory TSD). As discussed indetail in the Cecil County Emission Inventory TSD, Maryland’s procedures, methodologies, and

result for the Cecil County 2002 base year inventory 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) of the CAA and 40 CFR 51.910. This baseline value

has been determined to be the 2002 adjusted base year inventory. Sections 182(b)(l)(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). TheFMVCP and RVP emissions reductions are determined by the state using EPA’s on-road mobilesource 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 calculatedfrom 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 Philadelphia 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),

EPA interpreted 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 planfor 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

the 8-hour NAAQS, a SIP revision that meets the requirements of 40 CFR 51.91 0(b)(2). The

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ozone nonattainment area (62 FR 40457). Therefore, according to the Phase 2 Rule, the RFP

plan for the Cecil County may use either NOx or VOC emissions reductions (or both) to achievethe 15 percent emission reduction 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 following

manner:

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 between

2002 and 2008 NOx emissions factors calculated in Step B and multiply by 2002 VMT. This

result is the NOx emissions reductions that will occur between 2002 and 2008 without the

benefits 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.

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Table 3. Cecil County 2002 Anthropogenic Base Year Inventory (Ozone Season tpd)

Source Category VOC

Point 0.28 0.02

Area 4.93 0.20

Non-Road 8.37 2.97

On-Road 4.00 14.22

Total 17.58 17.40

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 measuresturned off, and calculating the difference. See Tables 5-2 and 5-3 of the Cecil County 8-hour ozone plan. The non-creditable reductions are calculated in Table 4, below.

Table 4. Cecil County Non-Creditable Emission Reductions (Ozone Season tpd)

Source Category VOC NOx(i) 2002 On-Road 5.42 16.09(ii) 2008 On-Road 4.73 13.90

Non-creditable Reductions (i) — (ii) 0.69 2.19

D & E) Maryland’s calculations ofthe Cecil County 2002 VOC and NOx inventories adjusted

relative to 2008 and VOC and NOx target levels for 2008 are found in Table 5-4 andAppendix C of the Cecil County 8-hour ozone plan, and are summarized in Table 5, below.

Table 5. Cecil County 2008 RFP Target Level Calculations Ozone Season tpd

Description Formula VOC NOx

A 2002 Rate-Of Progress Base Year Inventory 17.58 17.40

B FMVCP/RVP Reductions Between 2002 And 2008 0.69 2.19C 2002 Adjusted Base Year Inventory Relative To 2008 A -B 16.89 15.21

D RFP Ratio 0.07 0.08

E Emissions Reductions Required Between 2002 & 2008 C * D 1.18 1.22

F fargetLevelfor2008 C-E 15.71 13.99

NOx

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

Table 6. Cecil County 2008 Projected Controlled VOC & NOx Emissions

Emission Source VOC Emissions NOx Emissions

Category (tpd) (tpd)

Point 0.39 0.02

Area 4.75 0.23

Non-road 7.23 2.87

Mobile 2.29 7.93Total 14.65 11.05

To determine if 2008 RFP is met in Cecil County, the total projected controlled emissions

must be compared to the target levels calculated in the previous section of this document. Asshown below in Table 7, the total VOC and NOx emission projections meet the 2008 emission

targets. Therefore, the 2008 REP in Cecil County is demonstrated.

Table 7. Determination of whether RFP is met in 2008 in Cecil County

VOC Emissions NOx Emissions Description (tpd) (tpd)

I Total 2008 Projected Controlled A 14.65 11.05 Emissions

B Target Level for 2008 15.71 13.99

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 REP requirement in

Cecil County are described in Section 6.0 of the Cecil County 8-hour ozone plan. To meet the

RFP requirement for the Cecil County, 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 RFP using the MOBILE model for

the following measures:

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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 evaporativeemission 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 thePhiladelphia NAA. The first phase ofthe RFG program was designed to reduce ozone

precursor emissions by 64,000 tons per year (tpy) in RFG areas. The second (current) phase

ofthe RFG program began in 2000, and is designed to reduce ozone precursor emissions byan additional 41,000 tpy in RFG areas. The program has been in place in the Cecil Countysince 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. National

LEV 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.

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• 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 emissionsresult 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 utility

engines rated at 37 kilowatts or above. This measure applies to all compression-ignition

engines 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. See

40 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 previouslyunregulated non-road engines, including large industrial spark-ignition engines, recreationalvehicles, 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 Philadelphia 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 Cecil County

since 1995.

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diesel

powered locomotives and locomotive engines. This regulation took effect in 

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 and2008 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 (SCCs) were identified. Projected emissions were pulling from Appendix

C ofthe Cecil County 8-hour ozone plan. See Table 8 for 2008 projected uncontrolled

emissions.

Table 8. Rail Road Engine Uncontrolled 2008 VOC Emissions in Cecil County

SCC Source Subcategory NOx (tpd)

2285002005 railroad line haul engines (Class I Line-Haul) 0.7283990842285002010 railroad yard engines (Class I Switch) 0

Total for Cecil County 0.728399084

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

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

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• Architectural and Industrial Maintenance (AIM) Coatings

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

rule, COMAR 26.11.33, was effective on March 29, 2004. EPA approved this rule into theMaryland 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 of the 2001 Pechan report.

To determine the projected uncontrolled 2008 VOC emissions for AIM coatings, six SCCs

were identified. Projected emissions were pulling from Appendix C of the Cecil County 8-hour ozone plan. See Table 9 for 2008 projected uncontrolled emissions.

Table 9. AIM Coating Uncontrolled 2008 VOC Emissions in Cecil County

SCC Source Subcategory VOC tpd

2401002000 solvent-based architectural surface coatings 0.2416695 192401003000 water-based architectural surface coatings 0.2133267092401008000 traffic paints 0.026062 156

2401100000 surface coatings for industrial maintenance 0.1361677772401200000 surface coatings - other categories 0.1361677772401008999 traffic paint solvents 0.497390156Total for Cecil County 1.250784094

AIM Coating Projected 2008 Emission Reductions are: 1.250784094 x 31% = 0.39 tpd

VOC.

• Commercial and Consumer Products, Phase I

Consumer and commercial products are items sold to retail customers for household, personalor automotive use, along with the products marketed by wholesale distributors for use in

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

products, one SCC was identified. Projected emissions were pulling from Appendix C of the

Cecil County 8-hour ozone plan. See Table 10 for 2008 projected uncontrolled consumer and

commercial products emissions.

Table 10. Consumer and Commercial Products Uncontrolled 2008 VOC Emissions inCecil County

SCC Source Subcategory VOC (tpd)

2465000000 Emissions from commercial/consumer solvents 0.95725863

Consumer and Commercial Products Projected 2008 Emission Reductions are:

0.95725863 x 14.2% = 0.14 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 also

included 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.

Emission Benefit Calculation:Implementation ofthis rule began on January 1, 2003. (69 FR 38849) Projected reductionsare based on an emission reduction factor of 75% after full implementation after 10 years.

(See MDE’s undated “Technical Support Document, COMAR 26.11.13.07, Control of VOC

Emissions from Portable Fuel Containers”, attached.) By the 2008 ozone season, the rule had

been implemented for 5.5 years.Emission reduction factor: 75% x 5.5 years = 4 1.25%

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 ofthe Cecil

County 8-hour ozone plan. See Table 11, below.

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2501012016 Commercial -Transport Area 0.508404Total for Cecil County 0.76918 1

Portable Fuel Containers Projected 2008 Emission Reductions are tpd: 0.769181x41.25% = 0.32 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 CecilCounty 8-hour ozone plan. The total 2008 projected emission reductions calculated by EPA are

greater than the emission reductions claimed by MDE in the Cecil County 8-hour ozone plan.Therefore, the emission reductions claimed in the Cecil County 8-hour ozone plan are

approvable. Table 12 summarizes the emission reductions from each control measure andcompares EPA’s calculated values with the reductions claimed in the Cecil County 8-hour ozone

plan.

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

Cecil County EPA Calculation 8-hour Ozone Plan

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

On-road Mobile Measures 1.75 3.78 1.75 3.78

Non-road Model 1.18 0.28 1.18 0.28

Railroads (Tier 2) 0.00 0.20 0.00 0.15

OTC -Consumer Products Phase 1 0.14 0.00 0.14 0.00OTC — ATM Coatings 0.39 0.00 0.39 0.00

OTC — Portable Fuel Containers Phase 1 0.32 0.00 0.26 0.00

Total 3.78 4.26 3.71 4.21

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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 Cecil County. MDE discusses its Cecil County contingency measures for failure to meet RFPin Section 10.2 of the Cecil County 8-hour ozone plan. MDE calculated the contingency VOC

reduction for Cecil County as shown in Table 13, below. The RFP contingency requirement maybe 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. Cecil County 2008 RFP Contingency Measure Target Level Calculations

Description Formula VOC NOx

A 2002 Rate-Of Progress Base Year Inventory 17.58 17.40

B FMVCP/RVP Reductions Between 2002 And 2008 0.69 2.19

C 2002 Adjusted Base Year Inventory Relative To 2008 A -B 16.89 15.21

DRFPRatio 0.07 0.08

E RFP Emissions Reductions Required Between 2002 & 2008 C * D 1.18 1.22

F Contingency Percentage 3% 0%

G Contingency Emission Reduction Requirements C * F 0.51 0

H Contingency Measure Target Level for 2008 C—E—G 15.20 13.99

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

Cecil County, 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 thecontingency measure requirement for Cecil County.

Table 14. Evaluation of the Cecil County 2008 RFP Contingency Measure Requirement

Description VOC NOx

(tpd) (tpd)

A Total 2008 Projected Controlled Emissions 14.65 11.05

B Contingency Measure Target Level for 2008 15.20 13.99Contingency measure requirement met if A < B Yes Yes

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describes how states must include a RACM analysis with their attainment demonstration (70 FR71659). The purpose ofthe 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 aspracticable.” 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 Cecil

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

has adopted all RACM necessary to move Cecil County and the Philadelphia NAA toward

attainment as expeditiously as practicable and to meet all RFP requirements. As demonstratedabove in section IV of this document, Maryland has met the RFP requirements for Cecil County.

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

analysis. The first list consists ofthe 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 Cecil County 8-hour ozone plan.

MDE used the following criteria to determine of each potential control measure. Note,

EPA’s evaluation of certain MDE criteria is shown in the sub-bullets, below.

• Is it enforceable?• Is it technically feasible?

• Will it reduce emissions by the beginning of the 2008 ozone season (May 1, 2008)?

o In order for any measure to advance the attainment date ofJune 2010 to June

2009, the measures would have to be implemented and achieve the emission

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)?

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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 beexcluded from further consideration in a RACM analysis ifthose measures have

insignificant (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 Cecil County 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 will

not 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 Cecil County 8-hour ozone

plan that many ofthe 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 CecilCounty.

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

contribute meaningful emission reductions, and compiled an extensive list of potential controlmeasures. 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 Cecil County and the

Philadelphia NAA.

VII. Transportation Conformity Budgets

Transportation conformity is required by CAA section 176(c). EPA’s conformity rule

requires that transportation plans, programs and projects conform to state air qualityimplementation plans and establishes the criteria and procedure for determining whether or not

they do. Conformity to a SIP means that transportation activities will not produce new air quality

violations, worsen existing violations, or delay timely attainment ofthe national ambient airquality standards. The criteria by which we determine whether a SIP’s MVEBs are adequate forconformity purposes are outlined in 40 CFR 93.118(e)(4). The process for determining theadequacy of submitted SIP budgets is described in 40 CFR 93.118(f).

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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. MDE

describes its methods in Appendix F of the Cecil County 8-hour ozone plan. MDE also

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

The Cecil County 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 are shownin Table 15, below.

Table 15. Cecil County 2008 RFP MVEBs

VOC (tpd) NOx (tpd)

2.3 7.9

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

(40 CFR 93.11 8(e)(4)). In a March 27, 2009 Federal Register notice, EPA notified the public

that EPA found that the 2008 RFP MVEBs in the Cecil County 8-hour ozone plan are adequate

for transportation conformity purposes. (74 FR 13433) As a result of EPA’s finding, the State ofMaryland must use the MVEBs from the June 4, 2007 Cecil County 8-hour ozone plan for future

conformity 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 theMVEBs to be reasonable. The budgets are identical to the projected 2008 on-road mobile source

emission inventories. (See Table 6, “Cecil County 2008 Projected Controlled VOC & NOx

Emissions (tpd).”) Because the 2008 RFP MVEBs are adequate for transportation conformity

purposes and the methods MDE used to develop them are correct, the 2008 RFP budgets are

approvable.

C. SUMMARY AND RECOMMENDATIONS:

I have reviewed MDE’s 2008 RFP plan, contingency measures for failure to meet RFP,

and RACM analysis for Cecil County, Maryland and found them to be approvable. In addition,EPA Region 3’s AQAB determined that MDE used acceptable techniques and methodologies todevelop the Cecil County 2002 base year emission and 2008 milestone year projected

inventories. Furthermore, EPA has found Cecil County’s 2008 RFP MVEBs adequate for

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Wilmington-Atlantic City, PA-NJ-DE 8 Hour Ozone State Implementation Plan (SIP)

Attainment Demonstration and Base Year Inventory,” prepared by Alice H. Chow and signedby Walter Wilkie, Air Quality Analysis Branch Chief, on December 19, 2008 (Cecil CountyEmission 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 Maryland Portion of

the Philadelphia-Wilmington-Atlantic City 8-Hour Ozone Nonattainment Area Motor VehicleEmission Budgets (74 FR 13433).

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