Technical Support Document (TSD) for the BaltimoreNonattaimentArea 8-Hour Ozone State ImplementationPlan: DemonstratingRate ofProgress for 2008,2011, and 2012 Revisionto 2002 Base Year Emissions; and Serious Area Attainment Demonstration

Submitted by the Maryland Department ofthe Environment

TSD PreparedNovember 2015 by Jessica L. Fry Office ofAir Monitoring and Analysis, 3AP40 U.S. Environmental Protection Agency, Region 3 1650 Arch Street Philadelphia, Pennsylvania 19103

Reviewedby Alice H. Chow, Associate Director Office ofAir Monitoring and Analysis (3AP40)I. Introduction

The purpose ofthis document is to provide atechnical summary ofthe Office of Air Monitoring and Analysis (OAMA) review ofthe emissions inventories submitted with the BaltimoreNonattaimentArea 8-Hour Ozone State Implementation Plan: Demonstrating Rate ofProgress for 2008, 2011, and 2012, Revision to 2002 Base Year Emissions; and Serious Area Attainment Demonstration submitted by Maryland Department ofthe Environment (MDE). The BaltimoreNonattainment Area (BNAA) is comprised ofBaltimore City and the counties ofBaltimore, Carroll
, Anne Arundel, Howard, and Harford. Effective March 2, 2012 EPAreclassified the BNAA from a moderate nonattainment areato a serious nonattainment area (NAA) for the 8-hour ozone National Ambient Air Quality Standard (NAAQS). Under the Clean Air Act (CAA) section 182(b)(1)(A) moderate and above NAAs are required to submit a "rate of progress" (ROP) plan which ensures a 15 percent VOC reduction by 6 years after the NAA designation. In addition, areas classified as serious and above are required under CAA section 182(c)(2)(B) to submit a plan to achieve at least a further annual 3 percent VOC reduction, also called, "annual reasonable further progress(RFP)." This review does not determine the approvability ofthe rate ofprogress plan or attainment demonstration. Any questions pertaining to this technical summary should be directed to Alice Chow, Associate Director, Office ofAir Monitoring and Analysis, at 215-814-2144

or via email at chow.alice@epa.gov.

II. 2002 Base YearInventory RFP Revisions

In a ROP/RFP planthe base year inventory is used to provide a reference point to determinethe emission reductions that must be achieved for the 15 percent VOC (or NOx) reduction, and the subsequent 3percent reductions for serious areas outto the attainment year. For ozone, the base year inventory for ROP/RFP is typically the same base year submitted in the nonattainment plan. Ifsignificant changes have occurred since the approval ofthe base year inventory, updates to the inventory shouldbe made to in order to make the emissions comparableto projected inventories. In June of2014,EPA approved the 2002 emissions inventories submitted by Maryland for the BNAA for the

ozoneNAAQS. 

### See (75 FR 31709, June 4, 2010). This section will discuss the revisions (ifany) made to the 2002 Base Inventory.

No revisions to the point and nonpoint (area) source inventories were made for RFP purposes.

The approved 2002 base year inventory for nonroad sources used the NONROAD2005 model. Since the time ofapproval, a new version ofthe model, NONROAD2008 has beenreleased. MDE updated emissions using the newversion. Aircraft, locomotives, and commercial marine vessels were calculated outside ofthe NONROAD2008 model, but were included in the nonroad inventory.The onroad mobile source inventory was also updated to take into account emission differences due to a newer model. MDE revised emissions for 2002 using MOVES2010, whichreplaced MOBILE6.2.

OAMA staffreviewed the emissions and believes them to be reasonable.

III. RFP Projected Inventories- 2008, 2011, and 2012

MDE submitted a 2008 projected inventory to fulfill the CAA section 182(b)(1)(A) requirement for moderate and above areas. The 2011 projected inventory is used to fulfill the 182(c)(2)(B) requirement for serious and above areas ofNAA, and the 2012 projected inventory is required for the attainment year. Inventories were developed for all emission sources for all three years.

The point source emissions for 2008, 2011, and 2012 were projected, using surrogates for EPA'sEconomic Growth and Analysis System, Version 5.0 (EGAS 5.0).

The nonpoint or area source emissions for 2008,2011, and 2012 were projected using growth factors to account for population, household and employment data from the Baltimore Metropolitan Council.

Forthe nonroadprojected inventories for 2008, 2011, and 2012, MDE used EPA'sNONROAD2008 model. TheNONROAD model allows for the calculation of past year, present year, and future year inventories to be generated. Emissions for aircraft, locomotive, and commercial marine vehicles are calculated outside ofthe NONROAD model. Growth for locomotives and commercial marine vessels came from employment data as surrogates. Aircraft emissions were estimated from Maryland Aviation Administration activity data and the Federal Aviation Administration's Terminal AreaForecasts.

The onroad emissions for 2008, 2011, and 2012 were estimated using the MOVES2010a model. The analysis was done by Michael Baker, Jr., Inc., in consultation with MDE. Local activity data was used to replace default inputs in the model where appropriate.

OAMA staffreviewed the emissions and believes them to be reasonable.