Appendix B 

Point Source Emissions 

Inventory Documentation 
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North Carolina Reasonable Further Progress Demonstration November 30, 2009 

TABLE OF CONTENTS 

1. INTRODUCTION ...................................................................................................................... 3

2. 2002 POINT SOURCE INVENTORY DEVELOPMENT ........................................................ 3

2.1 Development of 2002 Actual Point Source Inventory .................................................... 4

2.1.1 Consolidated Emissions Reporting Rule (Non-EGU point) ................................... 4

2.1.2 EGU Analysis ......................................................................................................... 5

2.1.3 Summary of the 2002 Actual Inventory.................................................................. 6

3. 2008 POINT SOURCE EMISSIONS INVENTORY DEVELOPMENT .................................. 6

3.1 North Carolina 2008 EGU Emission Projections ........................................................... 7

3.2 North Carolina 2008 Non-EGU Emission Projections ................................................... 7

3.2.1 Growth assumptions for non-EGU sources ............................................................ 8

3.2.2 Control Programs applied to non-EGU sources...................................................... 9

3.2.3 Sources Shutdown After 2002 .............................................................................. 12

4. QUALITY ASSURANCE (QA)............................................................................................... 12

LIST OF TABLES 

Table 2.1.3-1 2002 Actual Point Source Inventory for North Carolina.......................................... 6

Table 3.2.2-1 MACT controls in the Metrolina area by SCC codes ............................................. 10
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1. INTRODUCTION 

The attainment modeling for the Charlotte-Gastonia-Rock Hill, North Carolina-South Carolina 

8-hour ozone nonattainment area (referred to as the Metrolina area) was performed in 

conjunction with the regional haze modeling being done by the Southeast Regional Planning 

Organization, Visibility Improvement State and Tribal Association of the Southeast (VISTAS) 

and the fine particulate matter (PM2.5) and ozone modeling being done by the Association of 

Southeastern Integrated Planning (ASIP). VISTAS and ASIP are run by the ten Southeast states 

(Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee, 

Virginia and West Virginia). Since the regional haze and PM2.5 modeling uses annual 

simulations and includes an intermediate year that is the original attainment year required for the 

Metrolina nonattainment area, the North Carolina Division of Air Quality (NCDAQ) decided to 

use the this modeling as the base modeling for its attainment demonstration. 

The 2002 base year emissions inventory from the attainment demonstration was the starting 

point for the Reasonable Further Progress (RFP) demonstration. The 2008 emissions for the 

utility sector were provided by the utility company. The 2008 emissions for non-utility sources 

were developed by applying growth and control factors to the 2002 base year and these factors 

were applied through the Sparse Matrix Operator Kernel Emissions (SMOKE) preprocessor so 

that the 2002 and 2008 emissions estimates were comparable. 

Although the VISTAS/ASIP developed emission estimates for all pollutants of concern for 

regional haze, fine particulate matter and ozone, only the emissions inventory discussions 

relevant to ozone formation, i.e., nitrogen oxides (NOx) and volatile organic compounds 

(VOCs), will be discussed in this document. The other pollutants are discussed in detail in the 

regional haze and fine particulate matter State Implementation Plans (SIPs). 

2. 2002 POINT SOURCE INVENTORY DEVELOPMENT 

This section details the development of the 2002 base year inventory for point sources. The 

starting point of the point source sector of the inventory was the incorporation of data submitted 

by State and Local (S/L) agencies to the United States Environmental Protection Agency 

(USEPA) as part of the Consolidated Emissions Reporting Rule (CERR) requirements. Work on 

incorporating the CERR data into the revised base year involved: 1) obtaining the data from the 

USEPA or the S/L agencies, 2) evaluating the emissions and pollutants reported in the CERR 

submittals, 3) augmenting CERR data with annual emission estimates for primary coarse 

particulate matter (PM10-PRI) and PM2.5-PRI; 4) evaluating the emissions from electric 

generating units, 5) completing quality assurance reviews for each component of the point source 
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inventory, and 6) updating the database with corrections or new information from S/L agencies 

based on their review of the 2002 inventory. This document will not address the augmenting of 

the particulate matter since these pollutants are not considered an ozone precursor. The 

remaining processes used to perform the emission inventory development are described in the 

first portion of this section. 

2.1 Development of 2002 Actual Point Source Inventory 

VISTAS/ASIP contracted with MACTEC to develop the 2002 emission inventory. The NCDAQ 

submitted the most updated statewide emission inventory to the contractor with the exception of 

the emissions from the three local programs. For the three local programs, Forsyth, 

Mecklenburg, and Buncombe Counties, the CERR submittal from the USEPA was used. Once 

all of the files were obtained, MACTEC ran the files through the USEPA’s National Emissions 

Inventory (NEI) Input Format (NIF) Basic Format and Content checking tool to ensure that the 

files were submitted in standard NIF format and that there were no referential integrity issues 

with those files. 

The primary task in preparing the 2002 base year inventory was the incorporation of corrections 

and new information as submitted by the S/L agencies based on their review of the previous draft 

versions of the inventory. The following subsections document the data sources for the 

inventory, the checks made on the CERR submittals, the evaluation of electric generating units 

(EGU) emissions, and other quality assurance/quality control (QA/QC) checks. The final 

subsection summarizes the 2002 NOx and VOC inventory by sector (EGU and non-EGU). 

Throughout the development of the point source emissions inventory, the NCDAQ completed 

detailed reviews of the inventories prepared by the VISTAS/ASIP contractor and provided 

comments and data corrections when needed. 

2.1.1 Consolidated Emissions Reporting Rule (Non-EGU point) 

The CERR was published in the Federal Register on Monday, June 10, 2002 (67 FR 39602). 

This brief summary is provided as a quick introduction to the CERR and covers the major items 

in the rule. 

The purpose of the CERR is to simplify reporting, offer options for data collection and exchange, 

and unify reporting dates for various categories of criteria pollutant emission inventories. The 

rule applies to S/L agencies. Previous reporting requirements have, at times, forced reporting 

agencies into inefficient collecting and reporting activities. This rule consolidates the emission 

inventory reporting requirements found in various parts of the Clean Air Act (CAA). 
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Consolidation of reporting requirements will enable S/L agencies to better explain to program 

managers and the public the necessity for a consistent inventory program, increases the 

efficiency of the emission inventory program, and provide more consistent and uniform data. 

States are required to prepare a comprehensive statewide inventory every three years. The first 

inventory was for the year 2002 and was due June 1, 2004. This CERR inventory was used for 

the VISTAS/ASIP 2002 base year. 

2.1.2 EGU Analysis 

MACTEC made a comparison of the annual sulfur dioxide (SO2) and NOx emissions for EGUs 

as reported in the S/L agencies CERR submittals and the data from the USEPA’s Clean Air 

Markets Division (CAMD) continuous emission monitoring (CEM) database to identify any 

outstanding discrepancies. Facilities report hourly CEM data to the USEPA for units that are 

subject to CEM reporting requirements of the NOx SIP Call rule and Title IV of the CAA. The 

USEPA sums the hourly CEM emissions to the annual level, and MACTEC compared these 

annual CEM emissions to those in the S/L inventories. The 2002 CEM inventory containing 

NOx and SO2 emissions and heat input data were downloaded from the USEPA CAMD web site 

(www.epa.gov/airmarkets). The data were provided by quarter and by emission unit. 

The first step in the EGU analysis involved preparing a crosswalk file to match facilities and 

units in the CAMD inventory to facilities and units in the S/L inventories. In the CAMD 

inventory, the Office of Regulatory Information Systems (ORIS) identification (ID) code 

identifies unique facilities and the unit ID identifies unique boilers and internal combustion 

engines (i.e., turbines and reciprocating engines). In the North Carolina point source emissions 

inventories, the State and county code (FIP code) and State facility ID together identify unique 

facilities and the emission unit ID identifies unique boilers or internal combustion engines. In 

most cases, there is a one-to-one correspondence between the CAMD identifiers and the S/L 

identifiers. However, in some of the S/L inventories, the emissions for multiple emission units 

are summed and reported under one emission unit ID. MACTEC created an Excel spreadsheet 

that contained an initial crosswalk with the ORIS ID and unit ID in the CEM inventory matched 

to the State and county FIPS, State facility ID, and emission unit ID in the emissions inventories. 

The initial crosswalk contained both the annual emissions summed from the CAMD database, as 

well as, the S/L emission estimate. The matching at the facility level was nearly complete. In 

some cases, however, S/L agencies or stakeholders’ assistance was needed to match some of the 

CEM units to emission units in the S/L inventories. 
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The second step in the EGU analysis was to prepare an Excel spreadsheet that compared the 

annual emissions from the hourly CAMD inventory to the annual emissions reported in the S/L 

inventory. The facility-level comparison of CEM to emission inventory NOx and SO2 emissions 

found that for most facilities, the annual emissions from the S/L inventory equaled the CAMD 

CEM emissions. Minor differences could be explained because the facility in the S/L inventory 

contained additional small or emergency units that were not included in the CAMD database. 

The minor inconsistencies found included small differences in emission estimates (<2 percent 

difference), exclusion/inclusion of small gas-fired units in the different databases, and grouping 

of emission units in S/L CERR submittals where CAMD listed each unit individually. MACTEC 

compared SO2 and NOx emissions on a unit-by-unit basis and did not find any major 

inconsistencies. The VISTAS EGU Special Interest Work Group (SIWG) approved use CAMD 

data with additional small or emergency units provided by S/L that were not includes in the 

CAMD database. 

2.1.3 Summary of the 2002 Actual Inventory 

Table 2.1.3-1 summarizes the final 2002 actual base year inventory for North Carolina. All 

values are in tons per year. The EGU emissions include the emissions from all processes with a 

Source Classification Code (SCC) of either 1-01-xxx-xx (External Combustion Boilers – Electric 

Generation) or 2-01-xxx-xx (Internal Combustion Engines – Electric Generation). Emissions for 

all other SCCs are included in the non-EGU column. 

Table 2.1.3-1 2002 Actual Point Source Inventory for North Carolina 

Pollutant All Point Sources EGUs Non-EGUs 

NOx 196,782 151,854 44,928 

VOC 62,170 988 61,182 

3. 2008 POINT SOURCE EMISSIONS INVENTORY DEVELOPMENT 

This section details the development of the 2008 emission inventory for point sources. There 

were two major sectors of the point source of the inventory. Different approaches were used for 

different sectors of the 2008 North Carolina point source inventory development. For Utility 

sector (EGU), the NCDAQ requested Duke Power to provide project 2008 emission estimates. 

For other point source sector (Non-EGU), the NCDAQ started with VISTAS/ASIP 2002 typical 

emissions, using Economic Growth and Analysis System growth factor model (EGAS) Version 

5.0 growth factor to grow the 2002 inventory to 2008, then applying with control scenario 
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accounts for post-2002 emission reductions from recently promulgated federal, State, local, and 

site-specific control programs, and finally applying allowable emission allocation based on North 

Carolina 15A NCAC 02D .1417- Emission Allocations for Large Combustion Sources. 

For both sectors, the NCDAQ generated 2008 inventory with control scenarios that account for 

post-2002 emission reductions from promulgated and proposed federal, State, local, and sitespecific control programs as of July 1, 2004. Section 3.1 discusses the EGU projection inventory 

development, while Section 3.2 discusses the non-EGU projection inventory development. 

3.1 North Carolina 2008 EGU Emission Projections 

The NCDAQ requested Duke Power to provide hour specific projected emissions for their 

facilities. Typical summertime profile projections were requested from Duke Power. There 

were three Duke Power facilities in the Metrolina nonattainment area: Allen Steam, Buck Steam, 

and Riverbend. 

It was noted that some projections seemed high compared to 2002 values considering the 

controls that were being put in place. There was concern expressed by the company that 

projections needed to be conservative in case the modeled emission rates were to end up in a 

permit with an enforceable short-term averaging time (such as 24-hour or less), they needed to 

make sure there was some margin of compliance to allow for process upsets. Process upsets 

would be rare (not typical) but they would need the assurance to avoid enforcement issues. This 

concern was addressed by stating that these projections were to be used for as our best estimate 

of "typical operating conditions in 2008". 

Duke Power noted that all of their projections for 2007 and later are using the same generation 

profiles relative to a typical summer day. Differences between 2007, 2008, and other future 

years were associated with the timing of when they expect to have emissions controls in place. 

Estimates were based on April 1, 2005 Duke Power Compliance Plan for NC Clean Smokestacks 

Act compliance plan. All estimates should be considered “typical expected emissions”, not to be 

used for permit limits or regulatory compliance. 

Some SCC codes and stack parameters were updated due to new equipment coming on-line. 

Kris Knudsen of Duke Power supplied these changes. 

3.2 North Carolina 2008 Non-EGU Emission Projections 

This section details the development of the North Carolina 2008 non-EGU emission inventory. 

The general approach for assembling future year data was to use recently updated growth and 
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control data consistent with the USEPA’s Clean Air Interstate Proposed Rule (CAIR) analyses, 

supplement these data with available stakeholder input, and provide the results for stakeholder 

review to ensure credibility. 

The NCDAQ started with VISTAS 2002 typical emission inventory. The 2002 VISTAS/ASIP 

point source emission inventory file contains both EGUs and non-EGUs. Duke Power and 

Progress Energy facilities, for which we have hourly projections, were removed from this file. 

The rest of the file contains all other point sources and constitutes the non-EGU emissions 

inventory. First the 2002 emission inventory was grown to 2008 by using projection factors 

developed from EGAS version 5.0. This growth processing creates emission data sets for years 

other than a year for which an emissions inventory is available. For growth processing, SMOKE 

creates a growth matrix that contains the growth factors for each source and pollutant in the 

inventory. It then combines the growth matrix with the emission inventory to create a grown 

emission inventory. Next, a control file supplied by VISTAS contractor, MACTEC was applied. 

Then allowable emission allocation, the NCDAQ developed based on North Carolina 15A 

NCAC 2D .1417, was applied. The allowable emission allocation control file contains countyspecific, SIC-specific, SCC-specific controls. 

The following sections discuss each of these steps to development 2008 non-EGU emissions 

inventory in detail. 

3.2.1 Growth assumptions for non-EGU sources 

The NCDAQ developed the growth factor data by using EGAS version 5.0. EGAS is an 

economic and activity forecast tool that provides credible growth factors for developing emission 

inventory projections. The economic activity data used by EGAS 5.0 must be provided in the 

same format as the default economic activity data sets contained within it. These data are from: 

• Regional Economic Models Incorporated (REMI) Policy Insight Model, Version 

5.5 - a 53 sector, 50 State + DC model; 

• Department of Energy’s Annual Energy Outlook (2004); The REMI socioeconomic data 

(output by industry sector, population, farm sector value added, and gasoline and oil 

expenditures) are available by 4-digit SIC code at the State level. 

The NCDAQ considered recent projections for three key sectors in North Carolina where 

declining production was anticipated – SIC 22xx Textile Mill Products, 23xx Apparel and Other 

Fabrics, and 25xx Furniture and Fixtures. For the 2008 inventory, the NCDAQ decided to use a 
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growth factor of 1.0 for these SIC codes. Although the NCDAQ has data that shows a steady 

decline in these industries in North Carolina, the NCDAQ wanted to maintain the emission levels 

at 2002 levels so the future emission reduction credits were available in the event that they are 

needed for nonattainment areas. 

For the 2008 inventory, the NCDAQ made one additional change to the growth factors. The 

AEO2004 data was replaced with the more recent AEO2006 forecasts (released in February 

2006) to reflect changes in the energy market and to improve the emissions growth factors 

produced. The NCDAQ obtained the corresponding AEO2006 projection tables from DOE’s 

web site. The NCDAQ with help of VISTAS developed tables comparing the growth factors 

based on AEO2004 and AEO2006 and decided to use the AEO2006 growth factors for fuel 

burning SCCs. 

3.2.2 Control Programs applied to non-EGU sources 

The methodologies used to account for the emission reductions associated with these emission 

control programs are discussed in the following sections. 

3.2.2.1 NOx Emission Allocations (NOx SIP Call) to non-EGU sources 

The NCDAQ developed allowable emission allocation based on North Carolina rule 15A NCAC 

02D .1417 - Emission Allocations for Large Combustion Sources. 

Phase I of the NOx SIP call applies to certain large non-EGUs, including large industrial boilers 

and turbines, and cement kilns. The Phase II of the NOx SIP call rule was finalized on April 21, 

2004. States had until April 21, 2005, to submit SIPs meeting the Phase II NOx budget 

requirements. The Phase II rule applies to large IC engines, which are primarily used in pipeline 

transmission service at compressor stations. The final rule reflects a control level of 82 percent 

for natural gas-fired IC engines and 90 percent for diesel or dual fuel categories. 

The NCDAQ used more specific information on the anticipated controls at the compressor 

stations in the 2008 inventory instead of the default approach used by the USEPA in the 

proposed Phase II rule. The North Carolina rule 15A NCAC 02D .1417 applied to fossil fuelfired stationary boilers, combustion turbines, or combined cycle systems serving a generator with 

nameplate capacity greater than 25 megawatts electrical and selling any amount of electricity. 

The North Carolina rule 15A NCAC 02D .1417 also applied to fossil fuel-fired stationary 

boilers, combustion turbines, or combined cycle systems having a maximum design heat input 

greater than 250 million Btu per hour. 
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The NCDAQ applied NOx Emission Allocations for 2006 and later from the North Carolina rule 

15A NCAC 02D .1417 to the non-EGU sources that are subject to the rule to generate 2008 

emission inventory. 

3.2.2.2 2, 4, 7, and 10-year MACT Standards 

Maximum achievable control technology (MACT) requirements were also applied, as 

documented in the USEPA report entitled Control Packet Development and Data Sources, dated 

July 14, 2004 (see Appendix G). The point source MACTs and associated emission reductions 

were designed from Federal Register (FR) notices and discussions with the USEPA’s Emission 

Standards Division (ESD) staff. VISTAS did not apply reductions for MACT standards with an 

initial compliance date of 2001 or earlier, assuming that the effects of these controls are already 

accounted for in the 2002 inventories supplied by the States. Emission reductions were applied 

only for MACT standards with an initial compliance date of 2002 or greater. Table 3.2.2-1 lists 

MACT control with control efficiency (CE) applied in the Metrolina area by SCC codes. 

Table 3.2.2-1 MACT controls in the Metrolina area by SCC codes 

MACT Description SCC CE (%) 

MACT: RICE 

20100102 40 

20200102 40 

20200202 40 

20300101 40 

MACT: Polymers and resins II 30101881 67.4 

MACT: Polyesters 30101891 67.4 

30101899 67.4 

MACT: Iron & Steel Foundries 

30400301 40 

30400315 40 

30400320 40 

30400331 40 

30400350 40 

30400360 40 

30400371 40 

30400398 40 

MACT: Petroleum refineries - other 30601101 65.6 

MACT: Wood & Composite Wood Products 30700701 41.2 

30700799 41.2 

MACT: Fabric Printing, Coating and Dyeing 

40201101 60.2 

40201103 60.2 

40201210 60.2 
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Table 3.2.2-1 MACT controls in the Metrolina area by SCC codes 

MACT Description SCC CE (%) 

MACT: Rubber tire manufacture 

30800104 47.6 

30800107 47.6 

30800108 47.6 

30800120 47.6 

30800121 47.6 

30800197 47.6 

30800198 47.6 

30800199 47.6 

MACT: Paper and Other Web 40201301 82 

40201303 82 

MACT: Auto and Light-Duty Truck 

Manufacturing 

40201606 66.7 

40201620 66.7 

MACT: Metal Can 40201799 70.8 

40201806 53.1 

MACT: Metal Furniture 40202031 73.1 

MACT: Wood Building Products 40202103 74 

40202106 74 

MACT: Plastic Parts 40202201 77 

40202208 77 

MACT: Misc. Metal Parts & Products 

40202501 47.9 

40202502 47.9 

40202533 47.9 

40202536 47.9 

40202537 47.9 

40202542 47.9 

40202599 47.9 

MACT: Metal surface coating 

40202601 66.2 

40202606 66.2 

40202607 66.2 

40202699 66.2 

MACT: Municipal Solid Waste Landfills 50100410 75.2 

3.2.2.3 Combustion Turbine MACT 

The projection inventory does not include the NOx co-benefit effects of the MACT regulations 

for Gas Turbines or stationary Reciprocating Internal Combustion Engines, which the USEPA 

estimates to be small compared to the overall inventory. 
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North Carolina Reasonable Further Progress Demonstration November 30, 2009 

3.2.3 Sources Shutdown After 2002 

The NCDAQ identified and incorporated information regarding sources that have shut down 

after 2002 and set the emissions to zero in the projection inventories.  

Kannapolis Energy Partners in Cabarrus County was shutdown on July 24, 2004. After 

discussion on emission reduction credit banking, the NCDAQ decided to keep Kannapolis 

Energy Partners in the 2008 emission inventory. They were kept in the modeling file and were 

included in the allowable emission allocation control packet with emissions froze at 2002 levels 

for NOx. 

4. QUALITY ASSURANCE (QA) 

Most SMOKE input files were prepared by VISTAS/ASIP that has been reviewed. The 

exception was the input files with data provided by Duke Power. These files were developed inhouse by the NCDAQ. A “near” line-by-line comparison between data supplied by Duke Power 

and the input file developed was performed as a QA measure. The following paragraphs discuss 

the various post-processing QA measures performed. 

Log files generated for each run for each day were reviewed for problems. These log files reflect 

that the subroutines completed normally with no errors. 

SMOKE reports, generated during emissions processing, use the SMOKE intermediate files to 

create a large variety of emissions and activity data totals to be used for the QA of the emissions 

data. This QA is in addition to the QA performed by other SMOKE programs for checking file 

formats and input quality, and it focuses on analysis of the emissions values processed and 

output by SMOKE. For non-EGU runs performed on data sources inside North Carolina, county 

reports were generated for one day of each week for the entire modeling period. The day of 

week alternated weekly to make sure we captured several Mondays, several Tuesdays, etc. Bar 

charts were generated for each pollutant and compared with each other for consistency. Since 

these were annual and not hourly emissions, there should not be much variation between various 

days. This was noted to be the case. County total emissions were evaluated to ensure that the 

emission totals appeared reasonable for the type of sources located within the County (such as 

utilities). For Duke Power sources, where hourly profiles were obtained, county reports were 

generated for every day of the modeling period and reviewed. Weekend and holiday profiles 

were compared to weekday profiles and judged to be accurate.