Technical SupportDocument (TSD) For TheBaltimoreNonattainment Area: PM2.5 State ImplementationPlan (SIP) and Base Year Inventory.

SubmittedJune 6, 2008 bythe Maryland Depruiment ofthe Environment
TSD Prepared May20l0 Janet C. Kremer Office of

### AirMonitoring and Analysis, 3AP40 U.S. Environmental Protection Agency, Region 3 1650 Arch Street Philadelphia, Pennsylvania 19103

ReviewedbyWaltc1 Wilkie, Associate Director Office ofAirMonitoring and Analysis, (3AP40)

# --:5**~** Ib , 000 Date Signed 1

### I. Introduction

The purpose ofthis document is to provide a technical summary ofthe Office of Air Monitoring and Analysis' (OAMA) review ofthe emissions inventories submitted with the Baltimore PM2.5 State Implementation Plan (SIP) bythe Maryland Department ofthe Environment (MDE). This review determines the approvability ofthe SIP Base Year Inventory. 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 ofan emissions reduction credit program. Maryland Department ofthe Environment has submitted Baltimore PM2.5 SIP and 2002 Base Year Inventory and has requested EPA's approval. Any questions pertaining to this technical summary shouldbe directed to Walter K. Wilkie, Associate Director, Office ofAirMonitoring and Analysis, at 215-814-2150
or via email at wilkie.walter@epa.gov.



### II 2002 SIP Base Year Inventory

The SIP base year inventoryis 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 yearinventory includes emissions estimates from stationarypoint and nonpoint sources, onroad mobile sources, and nonroad mobile sources. ForPM2.5 NAAQS, the pollutants to be inventoried are VOC, NOx, NH3, S02, PM10 and PM2.5. All emissions shouldbe reported as actual annual emissions. MDE's base year inventory is for 2002. Forthe Baltimore SIP, the geographic coverage includes sources in Anne Arundel County, Baltimore County, Baltimore City, Carroll County, Harford County, and Howard County. A significant amount ofdocumentation is required for these SIP base year estimates whichMDE has provided.

In the MDE request, the base year used was 2002. MDE's Air and Radiation Management Administration (ARMA) is primarilyresponsible for compiling the Point Source data for 2002. ARMAuses several forms ofsource identification. The state's primary data source is from its permittingprogram, which includes permit applications and equipmentregistrations. ARMA also relies on its compliance program, which involves using information gathered from inspections and citizen complaints. ARMA provided its 2002 actual emissions at the facility level and at the process-level.

For the 2002 Nonpoint Source emissions, also known as "area sources," ARMA provid.ed an inventory that contained estimations ofemissions bymultiplying an**emis~ion** factor by some known indicator or activity level for each category at the county level. These emissions are calculated on an annual basis because the activity data are generally only available on an annual basis. Various sources ofemission factors or methodologies

1 "Emissions Inventory Guidance for Implementation ofOzone andParticulateMatterNationalAmbient Air Quality Standards (NAAQS) andRegionalHaze Regulations" EPA-454/R-05-001, August 2005were used, including EPA's AP-42, EPA's Emissions Inventory Improvement Program, and EPA mobile source model. Nonpoint source estimates were provided by SCC.

The Nonroad Mobile Source 2002 inventory was prepared with EPA's NONROAD2005 model, version as of03/21/2006, and EPA emission factors. NONROAD estimates fuel consumption and emissions oftotal hydrocarbons, carbon monoxide, nitrogen oxides, sulfur dioxide, and particulate matter for all nonroad mobile
source categories except for aircraft, locomotives, and commercial marine vessels. ARMAprovided emission estimates for locomotive engines, aircraft emissions and commercial marine vessels separately. For locomotive engine and line haul emissions, ARMArequested and received fuel usage and track mileage data from alll3 railroads operating 

### in the BaltimoreNAA. Paired with EPA emission and conversion factors, ARMA calculated locomotive emissions for the base year. For aircraft emissions, ARMA used several sources ofinformation: Federal Aviation Administration's (FAA) Airport Activity Statistics ofCertiftcated Route Air Can-iers; landing and takeoffcycle information by airport in Maryland; Aviation Administration and the Federal Aviation Administration Airport License Renewal Applications; and FAA's Emissions & DispersionModeling System (EDMS). For commercial marine vessels, ARMA used the emission inventoryprepared for the Maryland Port Administrationby Edwards and Kelcey (E&K). E&K analyzed the major categories ofair emissions associated with ship and port operations and their relationship to air quality issues in the Baltimore NAA. E&K also used EPA's guidance, Analysis ofCommercial Marine Vessels Emissions and Fuel ConsumptionData, (EPA-450-R-00-002), February 2000, to calculate emissions

. All Nonroad mobile source emissions were provided by SCC.

The OnroadMobile Source 2002 emissions inventory was developed using the most current version ofEPA's highway mobile source emissions model MOBILE 6.2 and traffic activity data from the Maryland State HighwayAdministration. ARMA also used PPSUITE, an enhanced version ofthe Post Processor for Air Quality softWare systems. ARMAprovided Mobile6.2 input and output files for review. Mobile emissioD;S values
were given inunits oftons peryear and were providedby

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ARMA also applied rule effectiveness and rule penetration for its 2002 PM2.5 base year inventories. Rule effectiveness reflects the actual ability ofa regulatory program to achieve the emission reductions required by regulation (or perhaps voluntarily adopted). ARMA applied rule effectiveness and where applicable, provided a justification ofa higherpercentage than EPA'sprevious policy (which assumed an 80% rule effectiveness for applicable sources unless otherwise specified). Rule penetration is
an estimate ofpercentage ofemissions in a source category that are emitted at facilities subject to the requirements ofa rule. ARMA applied rule penetration for its nonpoint
sources where applicable.
AQAB staffreviewed the results, procedures, and methodologies for the SIP base year, and found them to be approvable.