# Development of the Point Source Emission Inventory for 2007 in the SESARM Region
(Version 1.8)

Prepared for:

John Hornback Executive Director, Southeastern States Air Resource Managers, Inc. 526 Forest Parkway, Suite F Forest Park, GA 30297-6140. (404) 361-4000, FAX (404) 361-2411 hornback@metro4-sesarm.org

January 26, 2011 MACTEC Projec t No. 6066-09-0326.02 Contract Agreement CONTRACT #: S-2009-06-02 Submitted by MACTEC Engineering and Consulting, Inc. 404 SW 140 th Terrace Newberry, FL 32669-3000 (352) 333-6617, FAX (352) 333-6622 wrbarnard@mactec.com



### ______________________ ______________________ Edward Sabo William R. Barnard Principal Senior PrincipalDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page i

MACTEC Engineering and Consulting, Inc. 

### Table of Contents

1.0 ANNUAL 2007 INVENTORY FOR POINT SOURCES .......................................................... 1
1.1 INTRODUCTION .............................................................................................................. . 1 1.2 INITIAL DATA SOURCES AND QA REVIEW .................................................................... 3 1.2.1 State Submittals and Conversion into a NIF Database ............................................. 3 1.2.1.1 Alabama ............................................................................................................... . 6 1.2.1.2 Alabama – Jefferson County ................................................................................. 7 1.2.1.3 Florida ............................................................................................................... .... 7 1.2.1.4 Georgia ............................................................................................................... ... 7 1.2.1.5 Kentucky .............................................................................................................. .. 8 1.2.1.6 Kentucky – Jefferson County................................................................................. 8 1.2.1.7 Mississippi ........................................................................................................... .. 8 1.2.1.8 North Carolina ....................................................................................................... 9 1.2.1.9 North Carolina – Buncombe County .................................................................... 10 1.2.1.10 North Carolina – Forsyth County ..................................................................... 10 1.2.1.11 North Carolina – Mecklenburg County ............................................................ 11 1.2.1.12 South Carolina ................................................................................................. 12 1.2.1.13 Tennessee ....................................................................................................... 13 1.2.1.14 Tennessee – Davidson County ....................................................................... 13 1.2.1.15 Tennessee – Hamilton County ........................................................................ 13 1.2.1.16 Tennessee – Knox County .............................................................................. 14 1.2.1.17 Tennessee – Shelby County ........................................................................... 14 1.2.1.18 Virginia ............................................................................................................. 14 1.2.1.19 West Virginia ................................................................................................... 14 1.3 EPA CAMD HOURLY EMISSION DATA ......................................................................... 15 1.4 PM AUGMENTATION ..................................................................................................... 17 1.4.1 Initial QA and Remediation of PM Pollutants .......................................................... 20 1.4.2 Updating of PM Factor Ratios ................................................................................. 20 1.4.3 PM Emission Calculations ....................................................................................... 21 1.4.4 PM Emission Results .............................................................................................. 22 1.5 EMISSION RELEASE POINT QA CHECKS .................................................................... 24 1.5.1 QA Checks and Gap-Filling for Location Coordinates ............................................. 24 1.5.2 QA Checks and Gap-Filling for Emission Release Parameters .............................. 25 1.6 STATE REVIEW OF INITIAL VERSION .......................................................................... 29 1.6.1 Alabama .................................................................................................................. 29 1.6.2 Alabama – Jefferson County ................................................................................... 29 1.6.3 Florida ..................................................................................................................... 2 9 1.6.4 Georgia .................................................................................................................... 30 1.6.5 Kentucky .................................................................................................................. 32Development of Point Source Emission Inventory for 2007 January 26, 2011 Page ii

MACTEC Engineering and Consulting, Inc. 1.6.6 Kentucky – Jefferson County .................................................................................. 33 1.6.7 Mississippi ............................................................................................................... 33 1.6.8 North Carolina ......................................................................................................... 34 1.6.9 North Carolina – Buncombe County ........................................................................ 34 1.6.10 North Carolina – Forsyth County ......................................................................... 34 1.6.11 North Carolina – Mecklenburg County ................................................................ 35 1.6.12 South Carolina ..................................................................................................... 35 1.6.13 Tennessee ........................................................................................................... 36 1.6.14 Tennessee – Davidson County ........................................................................... 37 1.6.15 Tennessee – Hamilton County ............................................................................ 37 1.6.16 Tennessee – Knox County .................................................................................. 37 1.6.17 Tennessee – Shelby County ............................................................................... 38 1.6.18 Virginia ................................................................................................................ 38 1.6.19 West Virginia ....................................................................................................... 38 1.7 STAKEHOLDER REVIEW .............................................................................................. 39 1.7.1 Alabama .................................................................................................................. 39 1.7.2 Florida ..................................................................................................................... 3 9 1.7.3 Georgia .................................................................................................................... 40 1.7.4 Kentucky .................................................................................................................. 40 1.7.5 North Carolina ......................................................................................................... 40 1.7.6 Tennessee ............................................................................................................... 40 1.8 IDENTIFICATION OF EGU AND NONEGU POINT SOURCES ...................................... 41 1.9 FINAL S/L AGENCY QA REVIEW ................................................................................... 42 1.9.1 Kentucky .................................................................................................................. 42 1.9.2 North Carolina ......................................................................................................... 42 1.9.3 North Carolina – Forsyth County ............................................................................. 43 1.9.4 South Carolina ......................................................................................................... 43 1.9.5 Virginia .................................................................................................................... 4 3 1.9.6 West Virginia ........................................................................................................... 43 1.10 2007 POINT SOURCE EMISSION SUMMARY ........................................................... 43 1.11 DATA FILES ................................................................................................................ 52 1.12 REFERENCES ............................................................................................................ 53Development of Point Source Emission Inventory for 2007 January 26, 2011 Page iii

MACTEC Engineering and Consulting, Inc. List of Exhibits

Exhibit 1 – Summary of Initial Point Source Submittals Exhibit 2 – PM Compound Descriptions Exhibit 3 – PM Compounds Reported in Initial State Submittals Exhibit 4 – PM Cases and Steps Requi red to Augment PM Emissions Exhibit 5 – Comparison of PM Emissions from the Initial S/L Data Submittals and Version 1.1 of the SEMAP 2007 Point Source Inventory Exhibit 6 – Stack Parameter Data Replacement Matrix Exhibit 7 – 2002 and 2007 Point Source CO Emissions by State Exhibit 8 – 2007 Point Source CO Emissions by Category Exhibit 9 – 2002 and 2007 Point Source NH3 Emissions by State Exhibit 10 – 2007 Point Source NH3 Emissions by Category Exhibit 11 – 2002 and 2007 Point Source NOx Emissions by State Exhibit 12 – 2007 Point Source NOx Emissions by Category Exhibit 13 – 2002 and 2007 Point Source PM10-PRI Emissions by State Exhibit 14 – 2007 Point Source PM10-PRI Emissions by Category Exhibit 15 – 2002 and 2007 Point Source PM25-PRI Emissions by State Exhibit 16 – 2007 Point Source PM25-PRI Emissions by Category Exhibit 17 – 2002 and 2007 Point Source SO2 Emissions by State Exhibit 18 – 2007 Point Source SO2 Emissions by Category Exhibit 19 – 2002 and 2007 Point Source VOC Emissions by State Exhibit 20 – 2007 Point Source VOC Emissions by CategoryDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page iv

MACTEC Engineering and Consulting, Inc. 

### Acronyms and Abbreviations
Acronym Description CAMD Clean Air Markets Division of EPA CAP Criteria Air Pollutant CEM Continuous Emission Monitoring System CE Control Equipment (NIF table) CERR Consolidated Emission Reporting Rule CO Carbon Monoxide EGU Electric Generating Unit EM Emission (NIF table) EP Emission Process (NIF table) EPA U.S. Environmental Protection Agency ER Emission Release (NIF table) EU Emission Unit (NIF table) LATLON Latitude / Longitude MANE-VU Mid-Atlantic/Northeast Visibility Union MARAMA Mid-Atlantic Regional Air Management Association NAAQS National Ambient Air Quality Standards NEI National Emission Inventory NH3 Ammonia NIF3.0 National Emission Inventory Input Format Version 3.0 nonEGU Non Electric Generating Unit NOx Oxides of Nitrogen PE Period (NIF table) PM Particulate Matter PM-CON Primary PM, Condensable portion only (all < 1 micron) PM-FIL Primary PM, Filterable portion only

PM-PRI Primary PM, includes filterables and condensables PM-PRI= PM-FIL + PM-CON PM10-FIL Primary PM10, Filterable portion only

PM10-PRI Primary PM10, includes filterables and condensables, PM10- PRI = PM0-FIL + PM-CON PM25-FIL Primary PM2.5, Filterable portion only

PM25-PRI Primary PM2.5, includes filterables and condensables PM25-PRI= PM25-FIL + PM-CONDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page v

MACTEC Engineering and Consulting, Inc. Acronym Description QA Quality Assurance QAPP Quality Assurance Project Plan SCC Source Classification Code SEMAP Southeastern Modeling, Analysis, and Planning SESARM Southeastern State Air Resource Managers, Inc. SMOKE Sparse Matrix Operator Ke rnel Emissions (modeling system) SI Site (NIF Table) SIC Standard Industrial Classification code SIP State Implementation Plan S/L State/Local SO2 Sulfur Dioxide TR Transaction (NIF Table) TSD Technical Support Document UTM Universal TransMercator VISTAS Visibility Improvement State and Tribal Association of the Southeast VOC Volatile Organic CompoundsDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page 1

MACTEC Engineering and Consulting, Inc. 

### 1.0 ANNUAL 2007 INVENTORY FOR POINT SOURCES

1.1 INTRODUCTION In 2009, the Southeastern State Air Resource Managers, Inc. ( SESARM) initiated a new Southeastern Modeling, Analysis, and Pla nning (SEMAP) project. The SEMAP project addresses the next phase of ozone, fine partic le, and regional haze assessment obligations through funding from two grants awarded by th e U.S. Environmental Protection Agency (EPA). This technical support document (TSD) explains the data sources, methods, and results for preparing the 2007 criteria air pollutant (CAP) and ammonia (NH3) emission inventory for point sources for the Southeastern U.S. Th e region includes Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee, Virginia, and West Virginia. In general, point sour ces in this inventory are sources classified as major sources under the Title V permitting program and sources required to submit hourly emissions data to EPA under various Clean Air Act programs. Some State and local agencies included smaller sources in the point s ource inventory. The inventory includes annual emissions for sulfur dioxide (SO2), oxides of nitrogen (NOx), volatile organic compounds (VOC), carbon monoxide (CO), ammonia ( NH3), and five components of particulate matter (PM). The inventory also includes particulate matter (PM) emissions, categorized as filterable, condensable, or total. Filterable emissions are generally considered to be the particles that are trapped by the glass fiber filter in the front half of a Reference Method 5 or Method 17 sampling train. Vapors and particles less th an 0.3 microns pass through the filter. Condensable particulate matter is material th at is emitted in the vapor state which later condenses to form homogeneous and/or hetero geneous aerosol particle s. The PM species in the inventory are categorized as: all filterable and c ondensable particles with an aerodynamic diameter less than or equal to a nominal 10 and 2.5 micrometers (i.e., PM10- PRI and PM25-PRI); filterable par ticles with an aerodynamic diameter less than or equal to a nominal 10 and 2.5 micrometers (i.e., PM 10-FIL and PM25-FIL); and condensable particles (PM-CON). Note that PM10-PRI equals the sum of PM10-FIL and PM-CON, and PM25-PRI equals the su m of PM25-FIL and PM-CON. The EPA has provided guidance on developing emission inventories to be used with models and other analyses for demonstrating attainment of air quality goals for ozone, fine particles, and regional haze (EPA 2005, EPA 2007). According to the EPA guidance, there are potentially two different base year emissions inventories. One is the base case inventory which represents the actual emissions for the meteorological period that is being modeled. This inventory is generally used for model performance evaluations. TheDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page 2

MACTEC Engineering and Consulting, Inc. second potential base year inventory is called the baseline inventory, which is generally used as the basis for projecting emissions to the future. The ba se case inventory may include day specific information (e.g. hourly continuous emission monitoring data for point sources) that USEPA considers not approp riate for using in future year projections. Therefore, the baseline inventory may need to replace the day specific emissions with average or “typical” emissions (for certai n types of sources). For the 2007 SEMAP inventory, the base case and baseline inventories are one in the same. The inventory went through several rounds of quality assurance (QA) reviews by State and local (S/L) agencies, as well as a review by stakeholders. Numerous corrections and improvements were made to the inventory. Updated versions of the inventory were released throughout the invent ory development process to facilitate S/L agency and stakeholder review. The following summarizes the different versions of the inventory:

 Version 1.1, released April 2010. S/L agency submittals were compiled into this initial version of the inve ntory, emissions for units re porting to EPA’s Clean Air Markets Division (CAMD) were analyzed, and the PM emissions were augmented to provide a complete set of PM speci es. Sections 1.2, 1.3, and 1.4 of this report describe the work done to prepare Version 1.1.

 Version 1.2, not released. Th is version was used intern ally and included updates to stack parameters as described in Section 1.5 of this report.

 Version 1.3, released May 18, 2010. This version contained the updates and corrections to the inventory specified by S/ L agencies as described in Section 1.6. This version was released for Stakeholder review.

 Version 1.4, not released. Th is version was used intern ally and included updates to classify units into electric generating units (EGUs) and nonEGUs according to the classification scheme discussed in S ection 1.7. It also included updates and corrections based upon stakeholder review, as well as additional review by S/L agencies, as described in Section 1.8.

 Version 1.5, released September 2, 2010. This version removed extraneous or incomplete information that was not needed for air quality modeling, such as emissions of hazardous air pollutants and emissions for non-annual averaging times. This version was provided to SEMAP for use in preparing emission density maps and bubble plots that were provided to S/L agencies for final QA of source locations and emission values.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 3

MACTEC Engineering and Consulting, Inc.  Version 1.6, released October 20, 2010. This version included updates provided by S/L agencies after their re view of the emission density maps and bubble plots.

 Version 1.7, released December 7, 2010. Th is version included emission updates to two facilities in Kentucky and replaced geographic coordinates with latitude and longitude for all sources (in previous ve rsions, the geographic coordinates were a mixture of latitude/longitude and UTM c oordinates, depending on the agency).

 Version 1.8, released January 26, 2001. Th is version included revisions to the documentation and data files to respond to comments from EPA Region 4 dated November 10, 2011. The main revision to the data files was to de lete facilities in North Carolina that had permanently shut down prior to 2007 but were inadvertently included in the 2007 inventory with non-zero emissions. State-level emission summaries of the 2007 point source inventory, referred to as Version 1.7, are provided in Section 1.10. Final deli verables are described in Section 1.11.

1.2 INITIAL DATA SOURCES AND QA REVIEW Version 1.1 of the 2007 point source invent ory was developed using data submitted by State and local agencies in the region, as well as da ta the CAMD hourly emission monitoring database.

1.2.1 State Submittals and Conversion into a NIF Database Each S/L agency collects point source data a ccording to EPA approved procedures that are included in each State’s point source emission inventory qual ity assurance project plan with accompanying standard operating proce dures. These plans and procedures are updated on a continuing basis and are available upon request. States were requested to submit 2007 data for those major sources that they would normally submit to EPA during the 3-year re quirements of the Consolidated Emission Reporting Rule (CERR). Some S/L agencies we re able to submit a complete set of data representing 2007. Other S/L agencies were only able to submit 2007 data for very large sources. In this case, inventories for other ye ars were used to create a complete 2007 point source inventory. In a few other cases, the S/L agency submittal was supplemented with data from EPA’s 2005-based modeling platform (EPA 2009c). S/L agencies prepare point source emission inventory files in a variety of formats – some use the NEI Input Format (NIF) while others used different formats. Exhibit 1 summarizes the data sources and formats for the S/L agency point source submittals with additional explanatory notes provided in the following sections.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 4

MACTEC Engineering and Consulting, Inc. As noted in Exhibit 1, a few S/L agencies prov ided emissions data for a year other than 2007. Georgia was the only State that reques ted that a linear pr ojection from 2005/2008 to 2007 be made when both 2005 and 2008 were availabl e. There result of this interpolation for Georgia showed that for sources where 2007 were not available, the emissions changed very little between 2005 and 2007. Other S/ L agencies indicated that 2005, 2006, or 2008 emissions data should be considered repres entative of 2007 for modeling purposes. This recommendation appears to be reasonable, give n the small amount of emissions associated with the facilities where 2007 we re not available (i.e., 97 perc ent of the point source NOx emissions and 99 percent of the SO2 emissi ons are 2007 data). It was decided that spending limited resources to obtain and apply appropriate growth fact ors to project these emissions from 2005/2006/2008 to 2007 woul d provide an almost unnoticeable improvement to the SEMAP 2007 inventory. Also note that some S/L agencies submitted many more facilities than were included in the 2002 VISTAS inventory, while others submitted fe wer facilities. An explanation of the reason why the number of facilities differs between 2002 and 2007 is provided for each S/L agency in the following sub-sections . SESARM’s area source contractor has developed procedures to reconc ile the point and area source i nventories to both (1) ensure that emissions minor point sources that are included the point s ource inventory are not double counted in the area source inventory and (2) that emissions from minor point source sources that are not in the point source inventory are included in the area source inventory.

After the each S/L submittal was formatte d into a standard NIF database, MACTEC performed an initial review of the S/L inventories using EPA’s Basic Format and Content Checker tool (EPA 2004). The tool was used to verify the data was in the correct format, to check for referential integrity and duplicate re cord issues, and to check certain fields for proper valid codes and ranges. Only minor i ssues were identified and were resolved by MACTEC without the need for assistance from the S/L agenci es. Following this initial QA review, these individual inventory files were consolidated into a single data set. Additional QA activities identified in the Quality A ssurance Project Plan (SESARM 2009) were carried out and documented in the remainder of this document.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 5

MACTEC Engineering and Consulting, Inc. Exhibit 1 – Summary of Point Source Data Sources

Agency # of Facilities in VISTAS 2002

Inventory # of Facilities in SEMAP 2007 V_1_8

Inventory Submittal Format Data Used for 2007 Inventory

AL 319 910 NIF ACCESS 2007 data for 328 major facilities; 2007 data for 613 minor facilities; 31 facilities had only HAP emissions and were removed from the 2007 CAP inventory AL Jefferson 243 237 NIF ACCESS 2007 data for 37 very large facilities; 2005 S/L data for 237 facilities, which also included the 37 very large facilities FL 1,050 1,136 NIF Text 2007 data for 1,136 facilities GA 234 268 NIF ACCESS 2007 S/L data for 74 facilities 2007 CAMD data for 19 facilities not in S/L submittal 2008 S/L data for 109 additional facilities 2005 S/L data for 66 additional facilities

KY 1,581 2,306 NIF xml 2007 data for 2,780 facilities 474 facilities had only HAP emissions and were removed from the 2007 CAP inventory 781 facilities were included in the 2007 SEMAP inventory but were not included in the 2002 VISTAS inventory KY Jefferson 76 154 NIF ACCESS 2007 data for 154 facilities

MS 640 282 NIF Text 2007 data for 46 facilities 2005 NEI data for 236 facilities NC 994 1,908 ORL xls 2007 data for 2,145 facilities See Section 1.1.1.8 for more information regarding the increase in the number of facilities NC Buncombe 6 65 NIF ACCESS 2007 data for 9 Title V facilities 2006 S/L data 65 facilities, which also included the 9 Title V facilities NC Forsyth 30 84 EIS ACCESS 2007/08 data for 84 facilities See Section 1.9.3 for discussion NC Mecklenburg 242 221 Quasi-ORL xls 2007 data for 221 facilities

SC 802 291 NIF xml 2007 data for 291 facilitiesDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page 6

MACTEC Engineering and Consulting, Inc. Agency # of Facilities in VISTAS 2002

Inventory # of Facilities in SEMAP 2007 V_1_8

Inventory Submittal Format Data Used for 2007 Inventory

TN 373 232 NIF xls 2007 data for 166 Type A and other facilities 2005 NEI data for 66 facilities TN Davidson 201 205 NIF Text 2007 data for 205 facilities

TN Hamilton 220 177 Quasi-ORL xls 2007 data for 177 facilities

TN Knox 11 9 NIF ACCESS 2007 data for 9facilities

TN Shelby 35 29 NIF xls 2008 S/L data for 29 facilities

VA 762 801 NIF ACCESS 2007 data for 801 facilities

WV 192 177 NIF ACCESS 2007 data for 177 facilities

1.2.1.1 Alabama
Alabama’s initial submittal contained two National Emission Inventory (NEI) Input Format (NIF) ACCESS database files. The first contained 2007 emissions data for 328 major sources, while the second contained 2007 emission data for 613 minor sources. MACTEC merged the major s ource file with the minor s ource found and identified 10 facilities that were in both files. We used the data fr om the 2007 major source file and deleted the data from the minor source file to ensure that there was no double counting of emissions for these 10 facilities. Alabama en sured that the minor source emissions that were included in the point source file were not double counted in th e area source file. Another contractor reconciled the point and area source inventories and Alabama reviewed the results on a per category basis to ensure that d ouble counting did not occur. There were numerous records flagged for out -of-range values for stack parameters or location coordinates, or inconsistencies between the flow rate and velocity. These cases are discussed later in this document. A la rge increase in VOC and PM emissions from 2002 to 2007 was identified. Alabama investigat ed this problem and identified a serious problem in their data conversion process. New Emission (EM) and Control Equipment (CE) tables were provided in Ma y 2010 to correct this problem.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 7

MACTEC Engineering and Consulting, Inc. 1.2.1.2 Alabama – Jefferson County Jefferson County submitted two NIF ACCESS data base files. The first contained 2007 emissions data for 37 very large sources, wh ile the second containe d 2005 emission data for 237 sources. MACTEC merged the 2007 very large source file with the 2005 file and identified that the 37 very large facilities were in both files. We used the data from the 2007 file and deleted the corresponding facili ties from the 2005 file to ensure no double counting of emissions. MACTEC did not pr oject 2005 emission data to 2007, as the 2005 data was considered to be representative of 2007. Jefferson County submitted emissions data for a large number of hazardous air pollutants. Since these pollutants are not needed for regi onal ozone and fine pa rticle modeling, they were stripped from the EM and CE tables.

The EPA’s Basic Format and Content Checker identified several relational widow/orphan issues. These were caused by the Emission Un it ID and Emission Release Point ID being reversed in the EP table for some records. MACTEC made the necessa ry corrections to the NIF EP table to ensure that all NIF EM records had a match in the NIF Emission Unit (EU), Emission Process (EP), and EM tables. The flow rates provided in the NIF Emission Re lease (ER) table were reported in cubic feet per minute. The NIF specifications require that this field be reported in cubic feet per second. MACTEC recalculated the flow rate by dividing the flow rate provided by Jefferson County by 60.

1.2.1.3 Florida Florida submitted NIF tables in ASCII text format with 2007 emissions data for 1,139 facilities. There were numerous records flagged for out-of-range values for stack parameters or location coordinates, or incons istencies between the fl ow rate and velocity by the EPA’s Basic Format and Content Checker. These cases are discussed later in Section 1.5 of this document. Otherwis e the data passed all of the QA checks.

1.2.1.4 Georgia Georgia submitted three NIF ACCESS database files. The first contained 2007 emissions data for 74 very large sources. The sec ond file contained 2008 emission data for 109 additional facilities. And the third file cont ained 2005 data for 69 a dditional facilities. MACTEC merged the three file s using the 2007 data when av ailable, the 2008 data where 2007 data were not available, and 2005 data as a last resort. We us ed the data from the 2007 file and deleted the corresponding facili ties from the 2008/2005 files to ensure no double counting of emissions. No significan t issues were identified by EPA’s BasicDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page 8

MACTEC Engineering and Consulting, Inc. Format and Content Checker. No projecting of 2005 emissions to 2007 or back casting of 2008 emissions to 2007 was done during the init ial processing of the submittals. See Section 1.6.4 for a discussion of how 2007 emissi ons were subsequently estimated for the final SEMAP inventory when only 2005 or 2008 data were available.

1.2.1.5 Kentucky Kentucky submitted an xml file that was loaded into an ACCESS database with NIF tables with 2007 emissions data for 2,780 facilities. There were approximate ly 474 facilities in Kentucky’s submittal that had only HAP emi ssions (i.e., emissions were zero for all criteria air pollutants at the facility) a nd were removed from the 2007 inventory. An additional 781 facilities were included in the 2007 SEMAP inventory but were not included in the 2002 VISTAS inventory. Thes e additional faciliti es in the 2007 SEMAP inventory were generally very small sources, and the aggregate NOx emissions from these 781 small facilities totaled only 805 tons per year.

The EPA’s Basic Format and Content Checker identified several relational widow issues, that is, there were SI, ER, EU, EP, PE and CE records with no corresponding emissions data in the EM file. These widow records we re removed from the SI, ER, EU, EP, PE, and CE tables. The flow rates provided in the ER table were reported in cubic feet per minute. The NIF specifications require that this field be reported in cubic feet per second. MACTEC recalculated the flow rate by dividing the flow rate provided by Kentucky by 60. There were numerous records flagged for out -of-range values for stack parameters or location coordinates, or inconsistencies betw een the flow rate and velocity by the EPA’s Basic Format and Content Checker. These cases are discussed later in Section 1.5 of this document.

1.2.1.6 Kentucky – Jefferson County Jefferson County submitted two NIF ACCESS da tabases containing 2007 emissions data – one file contained criteria air pollutants and the other fi le contained hazardous air pollutants. Only the criteria air pollutant file was proce ssed. Jefferson County’s submittal passed all of checks made by the EPA’s Basic Format and Content Checker.

1.2.1.7 Mississippi Mississippi submitted NIF tables in ASCII text format with 2007 emissions data for 45 facilities. Mississippi’s submittal passed al l of checks made by the EPA’s Basic Format and Content Checker.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 9

MACTEC Engineering and Consulting, Inc. Mississippi’s 2007 submittal was supplement ed with data from EPA’s 2005-based modeling platform (EPA 2009c). The data were provided in SMOKE ORL format, converted into a NIF database, and merged with Mississippi’s submittal. We used the data from Mississippi’s 2007 file and deleted the corresponding facilities from the 2005 EPA file to ensure no double counting of emi ssions. Mississippi decided to include 236 facilities from the 2005 NEI from the 2007 SEMA P inventory. At this time, MACTEC did not perform any projecting of 2005 data to 2007. No significant issues were identified by EPA’s Basic Format and Content Checker.

1.2.1.8 North Carolina North Carolina submitted a SMOKE one-record-p er-line (ORL) file with 2007 data for 2,145 facilities. MACTEC converted the ORL file to a NIF database. There was no control information in the ORL file, so we we re not able to create a NIF CE table. There were numerous records flagged for out -of-range values for stack parameters or location coordinates, or inconsistencies betw een the flow rate and velocity by the EPA’s Basic Format and Content Checker. These cases are discussed later in Section 1.5 of this document. Otherwise the data passed all of the QA checks. A large increase in VOC emissions from 2002 to 2007 was identified. North Carolina investigated this problem and identified a seri ous problem in their data conversion process. New EM and CE tables were provided in May 2010 to correct this problem. The 2007 SEMAP inventory contains many more sources than were included in the 2002 VISTAS inventory. There are three reasons to explain the large incr ease in the number of facilities in the 2007 inventor y versus the 2002 inventory:

 There are some new permit sources added since 2002;

 There were about 163 facilities in NC’s initial submittal that were permanently closed between 2002 and 2006 that were in advertently left in the 2007 inventory with non-zero emissions. These facil ities were removed from the 2007 SEMAP inventory; and

 Most the new facilities in 2007 are due to the following reason: 2002 was the year NC changed the emission reporting system. From 1993 to 2002, all non-title V sources reported their emission onc e every three years (1993, 1996, 1999, and 2002). Since 2002, NC changed the emissi on reporting system from once every three years to once every five year and each facility reports their emission the year their permit expired. So the 2007 point s ource emission inventory is much more inclusive compared to 2002 emission inve ntory, which only included the facilities reported during the year of 2002, not all facilities that operated in 2002.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 10

MACTEC Engineering and Consulting, Inc. 1.2.1.9 North Carolina – Buncombe County Buncombe County submitted two NIF ACCESS da tabase files. The first contained 2007 emissions data for 9 Title V facilities, wh ile the second contained 2006 emission data for 65 facilities. MACTEC merged the 2007 Title V source file with the 2006 file and verified that the 9 Title V facilities were in both files. We used the data from the 2007 file for the Title V facilities and deleted the corresponding facilities from the 2006 file to ensure no double counting of emissions. We also delete d all records for Snid er Tire (Facility ID 0861) which ceased operation in 2006 and di d not operate in 2007. MACTEC did not project the 2006 emissions to 2007, as the 2006 emissions are considered to be representative of 2007. There were several records flagged for out-of-ra nge values for stack parameters or location coordinates, or inconsistenc ies between the flow rate a nd velocity by the EPA’s Basic Format and Content Checker. These cases ar e discussed later in Section 1.5 of this document. Otherwise the data passed all of the QA checks.

1.2.1.10 North Carolina – Forsyth County Forsyth County provided 2008 data for 84 f acilities in an EIS-formatted ACCESS database. The data is actually a mix of 2008, 2007 and previous year data, but Forsyth County indicated that the submittal is repres entative of calendar year 2007. MACTEC performed data reformatting a number of da ta augmentation steps to create reasonably complete NIF tables, as follows:

 SI Table – relevant fields from the “F acilitySite” ACCESS table were mapped to NIF SI table fields.

 ER Table – relevant fields from the “R eleasePoint” ACCESS table were mapped to NIF ER table fields. The flow rate in th e “Release Point” table was in cubic feet per minute. The NIF specifications require th at this field be re ported in cubic feet per second. MACTEC recalculated the flow rate by dividing the flow rate provided by 60. There were no stack-level geogra phic coordinates in the “ReleasePoint GeographicCoordinates” ACCESS table. However, there were facility-level coordinates for some facilities in th e “FacilitySiteGeographicCoordinates” ACCESS table, and these were used for all emission release points associated with the facility. Where a faci lity match could not be made, we substituted the county centroid for the geographic coordinate s (longitude -80.24, latitude 36.114).

 EU Table – relevant fields from the “EmissionUnit” ACCESS table were mapped to NIF EU table fields.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 11

MACTEC Engineering and Consulting, Inc.  EP Table – relevant fields from th e “EmissionProcess” ACCESS table were mapped to NIF EP table fields. The emi ssion release point id entifier was obtained from the “ReleasePointAppor tionment” ACCESS table.

 PE Table – relevant fields from th e “EmissionProcess” ACCESS table were mapped to NIF PE table fields.

 CE Table – no information on control equipment was provided.

 EM Table – relevant fields from the “Emissions” ACCESS table were mapped to NIF ER table fields. The emission releas e point identifier was obtained from the “ReleasePointApportionment” ACCESS table. There were several records flagged for out-of-ra nge values for stack parameters or location coordinates, or inconsistenc ies between the flow rate a nd velocity by the EPA’s Basic Format and Content Checker. These cases ar e discussed later in Section 1.5 of this document. Otherwise the data passed all of the QA checks.

1.2.1.11 North Carolina – Mecklenburg County Mecklenburg County provided 2007 emissions data for 539 facilities in a spreadsheet that contained a limited number of NIF fields. MACTEC performed data reformatting and a number of data augmentation steps to create reasonably complete NIF tables, as follows:

 SI Table – only the facility id# and faci lity name were provided; we obtained the SIC code from the VISTAS 2002 B&F inve ntory where we were able to match facilities.

 ER Table – the submittal did not contain any stack parameters and the geographic coordinates were in NC State Planar coordinates, not UTM coordinates or latitude/longitude as requir ed by the NIF specification. To fill in the geographic coordinates, we obtained the latitude and longitude from the VISTAS 2002 B&F inventory where we were able to match faci lities. Where a facility match could not be made, we substituted the county ce ntroid for the geographic coordinates (longitude -80.789, latitude 35.252). Stack parameters for the Stage I gasoline distribution facilities were assigned a fug itive release height of 10 feet. Stack parameters for all other sources will be filled in according to the gap-filling procedures discussed later in Se ction 1.5 of this document.

 EU Table – the submittal only contained th e unit description, all other EU non-key data elements were left blank.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 12

MACTEC Engineering and Consulting, Inc.  EP Table – the submittal only contained SCC and the process description, all other EP non-key data elements were left blank.

 PE Table – we filled in the PE table with the PE key identifiers, and added the startdate of 20070101 and end date of 20071231. All other PE non-key data elements were left blank.

 CE Table – no control information was pr ovided, so the CE table is blank.

 EM Table – the submittal contained annual em issions for all criteria air pollutants and ammonia. After reformatting the spreadsheet into NIF tables, we ran the EPA’s Basic Format and Content Checker and did not detect any QA issu es other than the missing stack parameters. Mecklenburg County initially in cluded 319 Stage I gasoline st ations in the point source inventory. For consistency with other countie s in North Carolina (where Stage I emissions are included in the area source inventory) and to avoid double counting, these gasoline stations were removed from the point source inventory.

1.2.1.12 South Carolina
South Carolina submitted an xml file that wa s loaded into an ACCE SS database with NIF tables with 2007 emissions da ta for 293 facilities.

The EPA’s Basic Format and Content Check er identified that certain EM records associated with facility ID 2320-0034 (NAN YA Plastics) were assigned to FIPS 45041 (Florence County) while other NIF records associ ated with this plant were associated with FIPS 45089 (Williamsburg County). MACTEC ch anged the FIPS to 45089 for the records in the EM table to resolve this orphan issue. Geographic coordinates in the ER table were not changed. The flow rates provided in the ER table were reported in cubic feet per minute. The NIF specifications require that this field be reported in cubic feet per second. MACTEC recalculated the flow rate by dividing the flow rate provide d by South Carolina by 60. South Carolina’s 2007 submittal included many fe wer facilities than were in the VISTAS 2002 inventory. South Carolina reviewed data from EPA’s 2005-based modeling platform. South Carolina decided that the sources that were included in the 2002 but not in the 2007 inventory were predominantly minor sources, and that the use of EPA’s 2005 NEI data was not appropriate for use in the 2007 SEMAP inventory.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 13

MACTEC Engineering and Consulting, Inc. 1.2.1.13 Tennessee Tennessee submitted two spreadsheets with NIF tables for all counties except the four local program counties. The first file contained 2007 emissions data for 45 very large sources (i.e., Type A sources), while the second contained 2007 emission data for additional smaller facilities. MACTEC merg ed the two files and checked for duplicate facilities. One facility – JW Aluminum (Facility ID 47113- 0010) – was found in both submittals. Only the Type A submittal for this facility was used to avoid double counting of emissions. Tennessee submitted emissions data for a large number of hazardous air pollutants. Since these pollutants are not needed for regional ozone and fine particle modeling, they were stripped from the EM and CE tables.

The EPA’s Basic Format and Content Checker identified several relational widow/orphan issues. MACTEC made the nece ssary corrections to the NIF tables to ensure that all EM records had a match in the EU, EP, PE and EM tables. Tennessee’s 2007 submittals were supplemen ted with data from EPA’s 2005-based modeling platform. These data were downl oaded from EPA’s ftp site (file name: 2005v4CAPHAP_orl_point.zip). The data we re provided in SMOKE ORL format, converted into a NIF database, and merged with South Carolina’s submittal. We used the data from Tennessee’s 2007 files and delete d the corresponding f acilities from the 2005 EPA file to ensure no double counting of em issions. At this ti me, MACTEC did not perform any projecting of 2005 data to 2007. No significant issues were identified by EPA’s Basic Format and Content Checker. An additional 280 facilities were added during this augmentation process.

1.2.1.14 Tennessee – Davidson County Davidson County submitted NIF tables in ASCII text format with 2007 emissions data for 205 facilities. There were numerous records flagged for out-of-range values for stack parameters or location coordinates, or incons istencies between the fl ow rate and velocity by the EPA’s Basic Format and Content Checker. These cases are discussed later in Section 1.5 of this document. Otherwis e the data passed all of the QA checks.

1.2.1.15 Tennessee – Hamilton County Hamilton County provided data re presentative of 2007 for 177 facilities in a spreadsheet that contained the NIF fields needed fo r regional air quality modeling. MACTEC performed data reformatting to create reasonably complete NIF tables. The data passed all of the QA checks.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 14

MACTEC Engineering and Consulting, Inc. 1.2.1.16 Tennessee – Knox County Knox County submitted a NIF ACCESS database containing 2007 emissions data for 9 facilities. There were a few r ecords flagged for out-of-range values for stack parameters or location coordinates, or inconsistencies betw een the flow rate and velocity by the EPA’s Basic Format and Content Checker. These cases are discussed later in Section 1.5 of this document. Otherwise the data passed all of the QA checks.

1.2.1.17 Tennessee – Shelby County Shelby County submitted a spreadsheet with NIF tables for 29 facilities with 2008 emissions data. The 2008 was considered repr esentative of 2007 for a ll sources except the TVA Allen Plant (Facility ID 47157-00528), fo r which we used the 2007 annual SO2 and NOx emissions as reported in EPA’s CAMD database. Shelby County submitted emissions data for a large number of hazardous air pollutants. Since these pollutants are not needed for regi onal ozone and fine pa rticle modeling, they were stripped from the EM and CE tables.

The EPA’s Basic Format and Content Checker identified several relational widow/orphan issues. MACTEC made the nece ssary corrections to the NIF tables to ensure that all EM records had a match in the EU, EP, PE and EM tables.

1.2.1.18 Virginia Virginia submitted a NIF ACCESS database containing 2007 emissions data for 801 facilities. Since Virginia is participat ing with MARAMA in developing a regional modeling inventory for the northeastern Stat es, Virginia’s data has already undergone considerable QA review and updating. As pa rt of the MARAMA inventory development process, Virginia provided emissions data for a number of additional distributed generation units. Virginia’s submittal to MARAMA wa s subjected to the QA and PM augmentation procedures described in this report. Virginia has accepted the MARAMA 2007 point source inventory for use in the SEMAP 2007 point source modeling inventory.

1.2.1.19 West Virginia West Virginia submitted a NIF ACCESS databa se containing 2007 emissions data for 177 facilities. West Virginia’s submittal passed all of checks made by the EPA’s Basic Format and Content Checker with the exception of so me of the stack parameter values. There were numerous records flagged for out-of-rang e values for stack parameters or location coordinates, or inconsistenc ies between the flow rate a nd velocity by the EPA’s BasicDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page 15

MACTEC Engineering and Consulting, Inc. Format and Content Checker. These cases ar e discussed later in Section 1.5 of this document.

1.3 EPA CAMD HOURLY EMISSION DATA The second source of data was the hourly emi ssion data reported to EPA by facilities to comply with various provisions of the Cl ean Air Act. MACTEC downloaded the 2007 CAMD annual inventory containing NOx and SO2 emissions, heat i nput data and other information from the CAMD web site (EPA 2009a). MACTEC prepared an initial crosswalk file to match facilities and units in the CAMD inventory to facilities and un its in the 2007 SEMAP inventory. In the CAMD inventory, the Office of Regulatory Information Systems (ORIS) identification (ID) code identifies unique facilities and the unit ID identifies unique boilers a nd internal combustion engines (i.e., turbines and reci procating engines).

MACTEC also downloaded the 2007 CAMD hour ly inventory containing hourly NOx and SO2 emissions and heat input data from the CAMD website (EPA 2009b). MACTEC summed the hourly emissions to the annual le vel (or 6-month level for 6-month reporting units) by emission unit. The summed hourly da ta was compared to the annual summary data, which matched in virtually all cases. This check was made because MARAMA is considering using the actual 2007 ho urly data rather than averag e temporal profiles in the next round of regional air quality modeling. As a starting point for developing the CA MD-to-NIF crosswalk, MACTEC obtained and used the CAMD-to-NIF crosswalk that was developed for the VISTAS Best & Final inventory (VISTAS, 2007). This file was us eful for matching many facilities and units. However, in many other cases either the CAMD unit identifier changed or the facility and unit identifiers in the S/L database changed. For example, the facility IDs in West Virginia’s 2002 VISTAS database were a 4-di git field, while the faci lity IDs in the 2007 SEMAP inventory are a 5-digit field. In Kentucky, the f acility IDs in the 2002 VISTAS database consisted of the five-digit FIPS code followed by a 5-digit facility ID, while the facility IDs in the 2007 SEMAP inventory consis ted of only the 5-dig it facility ID. In North Carolina, nearly all un it IDs changed between 2002 and 2007. MACTEC prepared an Excel Workbook file fo r each S/L agency with linkages between the CAMD identifiers and the S/L agency identifiers and a comparison between the CAMD annual summary emissions, the annua l emissions summed from the hourly CAMD database, and annual emissions reported in the S/L inventory. This spreadsheet matched the CAMD unit-level IDs (ORISID and UNITID) with corresponding NIF table IDs (FIPS,Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 16

MACTEC Engineering and Consulting, Inc. SITE ID, EU ID, EP ID, ER ID). Emissions were shown as obtained from (1) the CAMD unit level file, (2) the sum of the CAMD hourly emission file, and (3 ) the State submitted NIF tables. Note that the CAMD Emissions are reported at the unit level while the NIF emissions are reported at the Unit/Process/Stack level.

MACTEC added three fields to the NIF EP ta ble to facilitate the linkage to the CAMD database. We added fields to store the CAMD ORISID , CAMD Unit ID, and CAMD number of reporting months. MACTEC prepared a CAMD-to-NIF crosswalk spreadsheet for each State. S/L agencies were asked to review this lis t and verify that (1) the linka ges are correct, (2) there are no large sources missing from the CAMD-to-NIF crosswalk, and (3) there are not any large discrepancies between the emissions reported to CAMD and the emi ssions reported in the SEMAP database. There are three types of possible linkages:

 CAMD facility has no match in NIF SI fac ility table. The emissions from these facilities reported to CAMD are small, and initially accounted for about 0.5% of the NOx and 0.07% of the SO2 emissions in the CAMD database.

 CAMD unit could not be matched in NIF. The emissions from these facilities reported to CAMD were small, accoun ting for about 0.9% of the NOx and 0.007% of the SO2 emissions in the CAMD database. Most of the units that could not be matched at the unit level are either peaking units or industrial sources such as paper mills or chemical plants. In addition, there were several instances where multiple CAMD units matc h to a single NIF record (i.e., units are grouped in the NIF tables but report ed individually in the CAMD database).

 CAMD unit matches with a single NIF record or CAMD unit matches with multiple NIF records (in many cases, the NIF tables include multiple records for different fuel types). The emissi ons from these units reported to CAMD account for about 98.6% of the NOx and 99.9% of the SO2 emissions in the CAMD database. In most cases the su m of the emissions from the matching NIF records are generally very close to the CAMD unit level emissions; and S/L agencies verified th at linkages were correct. As another QA check, MACTEC compiled a list of sources with EGU SCCs of 1-01-xxxxx and 2-01-xxx-xx in the S/L agency NIF tables that could not be linked to the CAMD CEM table to help resolve some of the linka ge issues noted above. S/L agencies madeDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page 17

MACTEC Engineering and Consulting, Inc. significant efforts to improve the crosswalk between the CA MD identifiers and the S/L agency identifiers.

1.4 PM AUGMENTATION PM compounds may be reported in several form s, as identified in Exhibit 2. Exhibit 3 provides a count of the number of annual NI F EM table records in each agency’s NIF Submittal by type of PM compound. The PM augmentations process gap-fills missing PMpollutant complements. We generated emission estimates for filterable and primary PM2.5, filterable and primary PM-10 and condensable PM if emission estimates for those species were missing from the S/L agency submittal .For example, if a S/L agency provided only PM10-PRI emissions, the PM augm entation process filled in estimates for PM-CON, PM10-FIL, PM25-PRI, and PM25-FIL. The PM augmentation process is essentially th e same process used in developing the 2002 VISTAS Best and Final invent ory and is virtually identical to the EPA methodology used for the 2002 NEI (EPA 2006a). The steps in the PM augmentation process were as follows:

 Step 1: Initial QA and remediati on of S/L provided PM pollutants;

 Step 2: Updating of PM factor ratios pr eviously developed for MARAMA based on factors from the Factor Information and Retrieval Data System and the EPA PM Calculator;

 Step 3: Implementation of the ra tios developed in step 2;

 Step 4: Presentation of PM augmentation results to S/L agencies for review and comment; and

 Step 5: Updates to augmented values in cases where the S/L agency was able to obtain source-specific data.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 18

MACTEC Engineering and Consulting, Inc. Exhibit 2 – PM Compound Descriptions

Pollutant Code Pollutant Pollutant Description PM-CON Primary PM Condensable portion only (all < 1 micron) Material that is vapor phas e at stack conditions, but which condenses and/or reacts upon cooling and dilution in the ambient air to form solid or liquid PM immediately after discharge from the stack. PM-FIL Primary PM, Filterable portion only Particles that are directly em itted by a source as a solid or liquid at stack or release conditions and captured on the filter of a stack test train. PM-PRI Primary PM, includes filterables and condensables PM-PRI= PM-FIL + PM-CON Particles that enter the atmosphere as a direct emission from a stack or an open source. It is comprised of two components: Filterable PM and Condensable PM.

PM10-FIL Primary PM10, Filterable portion only Particles with an aerodynamic diameter equal to or less than 10 micrometers that ar e directly emitted by a source as a solid or liquid at stack or release conditions and captured on the filter of a stack test train. PM10-PRI Primary PM10, includes filterables and condensables, PM10- PRI = PM0-FIL + PM-CON Particles with an aerodynamic diameter equal to or less than 10 micrometers that ent er the atmosphere as a direct emission from a stack or an open source. It is comprised of two components: Filterable PM and Condensable PM. (As specified in § 51.15 (a)(2), These two PM components are the components measured by a stack sampling train such as EPA Method 5.) PM25-FIL Primary PM2.5, Filterable portion only Particles with an aerodynamic diameter equal to or less than 2.5 micrometers that ar e directly emitted by a source as a solid or liquid at stack or release conditions and captured on the filter of a stack test train. PM25-PRI Primary PM2.5, includes filterables and condensables PM25-PRI= PM25-FIL + PM-CON Particles with an aerodynamic diameter equal to or less than 2.5 micrometers that enter the atmosphere as a direct emission from a stack or an open source. It is comprised of two components: Filterable PM and Condensable PM. (As specified in § 51.15 (a)(2), These two PM components are the components measured by a stack sampling train such as EPA Method 5.)Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 19

MACTEC Engineering and Consulting, Inc. Exhibit 3 – PM Compounds Reported in Initial St ate Submittals

Number of Annual EM Records in S/L Agency’s Initial NIF SubmittalAgency PMCON PMFIL PMPRI PM10- FIL PM10- PRI PM25- FIL PM25- PRI

AL 0 4,748 0 2,918 0 2,035 0

AL Jefferson 0 318 0 631 0 626 0

FL 0 3,576 0 3,672 0 0 0

GA 0 137 2,912 0 1,869 0 1,285

KY 0 0 29,856 0 29,859 0 99

KY Jefferson 20 0 222 20 222 20 214

MS 1 413 56 3,073 429 3,251 429 3,251

NC 0 0 0 0 9,120 0 5,800

NC Buncombe 26 40 63 40 63 40 58 NC Forsyth 12 4 408 23 381 5 210 NC Mecklenburg 0 0 0 0 613 0 309

SC 1 1,241 409 6,645 1,439 5,992 1,422 4,224

TN 1 2,274 3,175 1,258 2,811 2,560 2,641 2,441

TN Davidson 0 0 0 0 775 0 649

TN Hamilton 0 0 394 0 279 0 332

TN Knox 0 0 0 0 15 0 1 TN Shelby 57 189 79 70 279 63 99

VA 2 5,238 0 0 5,238 5,241 5,238 5,241

WV 167 2,138 802 1,814 737 1,586 691
1) Includes PM records from EPA’s 2005-based modeling inventory, which have already been augmented by EPA 2) Virginia’s PM augmentation was previously performed using an identical augmentation process during the development of the 2007 regional emission inventory for the Northeast/Mid-Atlantic StatesDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page 20

MACTEC Engineering and Consulting, Inc. 1.4.1 Initial QA and Remediation of PM Pollutants Prior to executing the PM augmentation pr ocess, we first reviewed the data for inconsistencies. If values are found to be inconsistent, they were replaced. The consistency checks and replacement actions are as follows:

1. If PM10-PRI >0 and PM25-PRI > PM10- PRI (and PM10-FIL, PM25-FIL and PMCON are null or 0), then set PM25-PRI = PM10-PRI. 2. If PM10-FIL > 0 and PM25-FIL > PM10- FIL (and PM10-PRI, PM25-PRI and PMCON are null or 0), then set PM25-FIL = PM10-FIL. 3. If PM10-PRI >0 and PM10-FIL > PM10-PRI (and PM25-PRI, PM25-FIL and PMCON are null or 0), then set PM10-FIL = PM10-PRI. 4. If PM25-PRI > 0 and PM25-FIL > PM25- PRI (and PM10-PRI, PM10-FIL and PMCON are null or 0), then set PM25-FIL = PM25-PRI. The consistency checks revealed very few o ccurrences of inconsistencies, and when inconsistencies did occur, the emission values were very small. As a result, S/L agencies were not asked to review this information and provide corrections because the inconsistencies did not involve significant emission sources . The replacement actions above were appropriate for an inventory used for regi onal air quality modeling.

1.4.2 Updating of PM Factor Ratios The augmentation steps require the use of ra tios developed from available emissions and particle size distribution data. Th ese ratios are needed when only one PM term is available, and two or more terms need to be augmented. Examples of how we used the PM ratios are shown below:

PM-FIL × RatioCON/FIL = PM-CON PM-PRI × RatioCON/PRI = PM-CON PM-CON × RatioFIL/CON = PM-FIL PM-CON × RatioPRI/CON = PM-PRI A table of PM compound ratios was devel oped utilizing the tabl e developed for the MANE-VU 2002 inventory (MARAMA, 2006). Th is table is keyed by SCC, primary control device, and secondary c ontrol device and provides the ratios listed in the above equations. We updated this table to include SCC, primary control device, and secondary control device codes found in the 2007 SEMAP inventory that were not contained in the 2002 MANE-VU inventory.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 21

MACTEC Engineering and Consulting, Inc. 1.4.3 PM Emission Calculations The gap-filling requires that the data be anal yzed and separated into cases. The cases determine which math steps and ratios of PM terms will be applied. Exhibit 4 shows the various cases and the augmentati on method that was applied.

Exhibit 4 – PM Cases and Required Steps to Augment PM Emissions

Case PM Reported Augmentation Methodology

1 PM25-PRI PM-CON = PM25-PRI * CON_P25 ratio PM25-FIL = PM25-PRI - PM-CON PM10-FIL = PM25-FIL * F10_F25 ratio PM10-PRI = PM-CON + PM10-FIL 2 PM10-PRI PM-CON = PM10-PRI * CON_P10 ratio PM10-FIL = PM10-PRI - PM-CON PM25-FIL = PM10-FIL / F10_F25 ratio PM25-PRI = PM-CON + PM25-FIL
3 PM25-PRI PM10-PRI PM-CON = PM10-PRI * CON_P10 ratio PM10-FIL = PM10-PRI - PM-CON PM25-FIL = PM25-PRI - PM-CON 4 PM10-FIL PM-CON = PM-CON * CON_F10 ratio PM10-PRI = PM-CON + PM10-FIL PM25-FIL = PM10-FIL / F10_F25 ratio PM25-PRI = PM-CON + PM25-FIL
5 PM10-FIL PM25-FIL PM-CON = PM10-FIL * CON_F10 ratio PM10-PRI = PM-CON + PM10-FIL PM25-PRI = PM-CON + PM25-FIL
6 PM10-FIL PM10-PRI PM-CON = PM10-PRI - PM10-FIL PM25-FIL = PM10-FIL * F25_F10 ratio PM25-PRI = PM-CON + PM25-FIL 7 PM25-FIL PM-CON = PM25-FIL * CON_F25 ratio PM10-FIL = PM25-FIL * F10-F25 ratio PM10-PRI = PM-CON + PM10-FIL PM25-PRI = PM-CON + PM25-FIL
8 PM10-FIL PM10-PRI PM25-FIL PM25-PRI PM-CON = PM25-PRI - PM25-FIL

9 PM-PRI PM-CON = PM-PRI * CON_PRI ratio PM-FIL = PM-PRI - PM-CON PM10-FIL = PM-FIL * F10_FIL ratio PM10-PRI = PM-CON + PM10-FIL PM25-FIL = PM10-FIL / F10_F25 ratio PM25-PRI = PM-CON + PM25-FILDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page 22

MACTEC Engineering and Consulting, Inc. Case PM Reported Augmentation Methodology

10 PM25-FIL PM25-PRI PMCON = PM25-PRI - PM25-FIL PM10-FIL = PM25-FIL * F10_F25 ratio PM10-PRI = PM-CON + PM10-FIL
11 PM-CON PM10-FIL PM25-FIL PM10-PRI = PM-CON + PM10-FIL PM25-PRI = PM-CON + PM25-FIL

12 PM-CON PM10-FIL = PM-CON * F10_CON ratio PM25-FIL = PM10-FIL * F25_F10 ratio PM10-PRI = PM-CON + PM10-FIL PM25-PRI = PM-CON + PM25-FIL
13 PM-CON PM10-FIL PM10-PRI PM25-FIL = PM10-FIL / F10_F25 ratio PM25-PRI = PMCON + PM25-FIL

14 PM-CON PM10-FIL PM10-PRI PM25-FIL PM25-PRI None required; all PM compounds present

15 PM-CON PM-FIL PM10-FIL = PM-CON / CON_F10 ratio PM25-FIL = PM10-FIL / F10_F25 ratio PM10-PRI = PM-CON + PM10-FIL PM25-PRI = PM-CON + PM25-FIL
16 PM-CON PM10-PRI PM25-PRI PM10-FIL = PM10-PRI - PM-CON PM25-FIL = PM25-PRI - PM-CON

17 PM-FIL PM10-FIL = PM-FIL * F10_FIL ratio PM_CON = PM10-FIL * CON_F10 ratio PM25-FIL = PM10-FIL / F10_F25 ratio PM10-PRI = PM-CON + PM10-FIL PM25-PRI = PM-CON + PM25-FIL

After completing the calculations , the data was QA checked to ensure that the calculations resulted in consistent values for the PM comp lement. On a few occasions, the mix of ratio value and the pollutants and values provided by the S/L agency resulted in negative values when FIL was back-calculated. In this case th e negative FIL value was set to zero and the PRI value was readjusted. In a few cases the appropriate combination of ratios, SCC, and control efficiencies were not available to calculate the PM10-PRI and PM25-PRI values. In these cases, PM10-PRI and PM25-PRI were set equal.

1.4.4 PM Emission Results Exhibit 5 compares the original PM emissi on estimates from the S/L submittals and the 2007 SEMAP emissions estimates calculated using the above methodology. This table isDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page 23

MACTEC Engineering and Consulting, Inc. intended to show that we took whatever Stat es provided in the way of PM and filled in gaps to add in PM-CON where emissions were missing in order to calculate PM 10 -PRI and PM 2.5 -PRI for all processes to get a complete set of particulate da ta. A spreadsheet (PM State SCC Sums.xls) shows the results obtained from the PM augmentation process by State and SCC. Exhibit 5 Comparison of PM Emissions fr om the Initial S/L Data Submittals and Version 1.1 of the SEMAP 2007 Point Source Inventory

State Database PM-CON PM10-PRI PM10-FIL PM25-PRI PM25-FIL

AL S/L Data 0 0 57,285 0 29,173

SEMAP 9,511 87,779 78,268 62,878 53,367 FL S/L Data 0 0 26,234 0 0

SEMAP 10,218 36,707 26,489 29,033 18,785 GA S/L Data 0 20,066 0 9,426 0

SEMAP 668 27,359 26,691 19,251 18,858 KY S/L Data 0 24,699 206 2,019 196

SEMAP 325 24,986 24,662 15,435 15,110 MS S/L Data 883 18,871 5,986 11,071 1,739

SEMAP 1,784 18,900 17,116 11,289 9,505 NC S/L Data 18 46,852 28 30,055 16

SEMAP 2,982 46,909 43,926 36,881 33,899 SC 1 S/L Data 81 30,602 910 21,488 416

SEMAP 909 31,904 30,995 24,235 23,326 TN 1 S/L Data 11,177 26,708 12,826 19,734 7,048

SEMAP 11,270 30,240 18,971 23,742 12,491 VA 2 S/L Data 4,783 19,203 14,419 14,888 10,105

SEMAP 4,783 19,203 14,419 14,875 10,092 WV S/L Data 129 6,444 7,507 4,462 3,398

SEMAP 3,904 13,736 9,833 9,173 5,269 1) Includes PM records from EPA’s 2005-based modeling inventory, which have already been augmented by EPA 2) Virginia’s PM augmentation was previously performed using an identical augmentation process during the development of the 2007 inventory for the Northeast/Mid-Atlantic StatesDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page 24

MACTEC Engineering and Consulting, Inc. 1.5 EMISSION RELEASE POINT QA CHECKS Stack parameters are an importa nt component of an emission inventory used for regional air quality modeling. Careful QA was required to ensure that the point source emissions were properly located both horizontally and ve rtically on the modeling grid. This section describes the procedures used to quality a ssure, augment, and where necessary, revise, stack parameters using standard ized procedures to identify and correct stack data errors. These procedures were implemented within th e NIF file itself, and are based on the QA procedures built into SMOKE that are desi gned to catch missing or out-of-range stack parameters.
1.5.1 QA Checks and Gap-Filling for Location Coordinates The emission release (ER) point record is used to report the location and relevant physical attributes of the emission release point. Locat ion coordinates must be reported to identify where emissions are released to the ambient air, via a st ack or non-stack (e.g., fugitive release). If a non-stack, or f ugitive release, coordinates may be reported for the general location of the emission release point. In the ER record, location data may be reported as x and y coordinates from either of two c oordinate systems - Latitude / Longitude (LATLON), or Universal TransMercator (UTM). X and Y coordinates reported as Latitude and Longitude must be reported in the decimal degree format specified. X and Y coordinates reported as UTM Ea sting and UTM Northing, must be reported in kilometers. In order to comply with the EPA data standard for Latitude/Longitude, any UTM data received in the SESARM files was processe d by the MACTEC Team and converted to, and stored as Latitude Measure and Longitude Measure in decimal degrees.

All conversions of UTM to LATLON were c onducting use a spreadsheet developed by the University of Wisconsin - Green Bay (Dutch 2005). This spreadsheet tool allowed for batch conversion of UTM data to decimal de gree format and was configured for WGS 84 DATUM. While errors using this spreadsheet ar e typically a few meters, rarely 10 or more, the accuracy of the conversion is limited to th e accuracy of the initial UTM data. A degree latitude/longitude is about 111,000 meters. T hus, to achieve roughly one-meter accuracy you need coordinates accurate to five decimal places. Four places will give you 10 meters accuracy and three will give you 100 meter accur acy. This accuracy could not be improved with the originally provided UTM coordinates, so all conversions should be checked for reasonableness.

Once all conversions were made to LATLON d ecimal degrees (also the requirement of the SMOKE emissions processing system), reasona bleness checks were conducted on each release point relative to county centroids a nd min/max coordinates associated with theDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page 25

MACTEC Engineering and Consulting, Inc. FIPS codes assigned to each stack. If a stack was found to exist outside of the western-, eastern-, northern- or southern-most bounda ry of the county (based on SMOKE’s county lat/lon file), the point was fl agged for additional review. Thes e flagged sources were then mapped with GIS software to determine their placement relative to the FIPS County associated with the stack. If a source wa s found to be outside of the county boundaries, it was further identified and reported for review by the data provider.

1.5.2 QA Checks and Gap-Filling for Emission Release Parameters In preparing emissions for grid modeling, valid parameters for the physical characteristics of each release point (stack height, diameter, temperature, velocity, and flow) are necessary to correctly place facility rele ase points and associated emissions into vertical layers for proper air quality modeling. Gaussian disper sion models need stack parameters to characterize the plume, which is needed to estimate proper concentrations from these models. The first step of our quality assura nce involves review of the Emission Release Point Type. Using this type code, we used a routine to assess the validity of the stack parameters, to replace values if necessary, and to fill-in missing data points. This methodology is virtually identical to the EPA methodology used for the 2002 NEI (EPA 2006a). We employed a routine that compared each emission release point parameter to a minimum and maximum range of values and when that parameter was missing or was found to exist outside of that range, we au gmented the parameter. We also checked nonfugitive stack parameters for internal consistency between:

 stack height and diameter, and

 stack diameter, exit gas velo city, and exit gas flow rate. When internal consistency was not met, we provided replacement values for the parameters. The following steps summarize the process of finding and replaci ng missing, out-of-range, or internally inconsistent stack parameters. Step 1: For fugitive emission release points, replace stack parameters For fugitive emission release points, we firs t compared the existing height against the following range thought to be representati ve of the minimum and maximum values allowable for most fugitive emission release points.

 Fugitive Release Height: 0.1 to 100 ftDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page 26

MACTEC Engineering and Consulting, Inc. If the height was valid, we kept the height a nd replaced all other stack parameters with the defaulted values listed below. If the height was invalid, we replaced all stack parameters with the defaulted values.

 Stack Height: 10 ft

 Stack Temperature: 72 o F

 Stack Diameter: 0.003ft

 Stack Velocity: 0.0003 ft/sec

 Stack Flow: 0 cu ft/sec Step 2: For non-fugitive emission release point s, find out-of-range or missing stack parameters For non-fugitive emission release points, we first compared existing stack parameters against a set of the following ranges thought to be representative of the minimum and maximum values allowable for most emission release points.

 Stack Height: 0.1 to 1000 ft

 Stack Temperature: 50 to 1,800 o F

 Stack Diameter: 0.1 to 50 ft

 Stack Velocity: 0.1 to 560 ft/sec

 Stack Flow: 0.001 to 1,100,000 ft 3 /sec First we identified missing or out-of range pa rameters. Then we evaluated the source category to determine if out-of-range paramete rs were plausible. If any parameter was missing or out-of range, the parameter was repla ced using the procedures described in Step 4. If all parameters were found to exist w ithin the bounds of the emission release point ranges, we proceeded to Step 3. Step 3: For non-fugitive emission release points, fi nd inconsistencies in stack parameters We determined any inconsistencies in st ack parameters by conducting the following two steps. A. For stack diameter, we compared the stack diameter to the stack height. For nonfugitive emission release points, the stack height may not be less than stack diameter. B. We determined the internal consistency between diameter, velocity and flow rate using the following equation.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 27

MACTEC Engineering and Consulting, Inc. Stack Flow [cu ft/sec] = ( Π [Pi] * (Stack Diameter [ft] / 2) ^ 2) * Stack Velocity [ft/sec]
If the calculated flow and the re ported flow are within 10 % of one another, then internal consistency was assumed to be valid. If a ll parameters were found to exist within the bounds of the emission release point ranges in Step 2, and the consistency checks (A) and (B) in Step 3 were satisfied, no additional st eps were taken. If any parameter was missing or out-of range, or if the parameters failed th e internal consistency tests, the parameter was replaced using the procedur es described in Step 4. Step 4: Replace stack parameters for non-fugitive emission release points The first step in replacing stack parameters was to determine if there are problems with stack height or diameter. Because stack hei ght and diameter are the physical parameters that are most easily measured or estimated, wh en there are problems with these parameters, then the entire set of stack parameters are deemed questionabl e. If either height or diameter were missing or out-of range, or if the stack diam eter was greater than stack height, then all five parameters were defaulted using nationa l default sets of physical parameter data contained in the 2002 NEI Stack Parameter Defa ult file (EPA 2006b). No additional steps were taken once all five pa rameters were defaulted. If stack height and diameter did not need re placement, then velocity and flow rate were evaluated next. If velocity and flow rate we re not internally consistent, we conducted QA on the flow rate to determine if it was reporte d in cubic feet per minute rather than cubic feet per second as required in the reporting to EPA. We corrected flow rates reported in cubic feet per minute to cubic feet per second and then evaluated the flow rate and velo city for internal consistency. If the internal consistency was not met for velocity, flow rate, and diameter , Exhibit 6 provides instructions on how we replaced missing, out-of-range values, or intern ally inconsistent values for velocity and flow rate based on different reported scenario s. Velocity and flow rate were augmented either by calculation or th e use of national defaults. Finally, in cases where all five parameters were not defaulted, and velocity and flow rate were evaluated and replaced if necessary, te mperature was evaluated. If temperature was missing or out-of-range, then the temperature was defaulted using nati onal default sets of physical parameter data in the order presented below.

1. SCC match 2. Facility level SIC Code match 3. National default for release points, if no SCC or SIC Code match is possibleDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page 28

MACTEC Engineering and Consulting, Inc. Stack parameter QA reports were sent to all da ta providers. The report contained all of the emissions release point records submitted and identifies which parameters were defaulted as a result of our QA. S/L agencies were aske d to review the defaulted records and revise the records if they do not agree with the defaulted values.

Exhibit 6 - Stack Parameter Data Replacement Matrix (X = Data value present)

Diameter Velocity Flow Rate Action

X X X 1. Check that velocity is within range. A. If velocity is within range and flow rate does not meet internal consistency for diameter, velocity and flow rate, then: > Calculate flow rate using internal consistency formula. B. If velocity is not within range, then: > Calculate velocity using internal consistency formula. > Check that calculated velocity is within range. If so, then default to calculated velocity. > If calculated velocity is not within range, then default all 5 parameters using national default set.
X - X 1. Calculate velocity using internal consistency formula. 2. Check that calculated velocity is within range. A. If calculated velocity is not within range, then: > Default all 5 parameters using national default sets. X X - 1. Check that velocity is within range. A. If velocity is within range, then: > Calculate flow rate using internal consistency formula. B. If velocity is not within range, then: > Default all 5 parameters using national default sets. X - - 1. Default velocity using national default sets. 2. Calculate flow rate using internal consistency formula.
- X X 1. Default all 5 parameters using national default sets.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 29

MACTEC Engineering and Consulting, Inc. 1.6 STATE REVIEW OF INITIAL VERSION This section describes changes made to the 2007 SEMAP point source inventory based on S/L agency review and comment. The followi ng changes were inco rporated to create Version 1.3 of the point source inventory.

1.6.1 Alabama A large increase in VOC and PM emissions from 2002 to 2007 was identified during the review of Alabama’s initial submittal. Alabam a investigated this problem and identified a serious problem in their data conversion process. New EM a nd CE tables were provided in May 2010 to correct this problem. The new subm ittals were subjected to the same QA and PM augmentation processes desc ribed in previous sections. Alabama reviewed the geographic coordinates fo r the 34 stacks that we re flagged as being outside of the appropriate county boundaries. No changes were needed – the sources were either located off-shore (out side the county boundary) or very close to the edge of the county boundary. In response to the QA checks of stack parame ters, Alabama changed the emission release type to “01” (fugitive sources) for 98 and accepted the default fugitive emission release characteristics. For another 71 stacks, Alabam a changed the emission release type to “02” (vertical release sources) and provided corrected stack parameters. Alabama also provided corrections for a number of additional st acks, either by accepting the recommended defaults or providing corrected data.

1.6.2 Alabama – Jefferson County Stack parameter changes were made for fugitive emission release points that were recommended for change based on the QA checks and gap filling process described in Section 1.5.2 of this report.

1.6.3 Florida Stack parameter changes were made for fugitive emission release points that were recommended for change based on the QA checks and gap filling process described in Section 1.5.2 of this report. Florida updated the CAMD-to-NI F crosswalk table to link the CAMD and NIF identifiers. Florida updated cases where:

 the facility/emission unit may lik ely have been reported as a different facility (two CAMD ORIS facilities were combined in Florida’s NIF SI table);Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 30

MACTEC Engineering and Consulting, Inc.  the EU did not operate in 2007, which is why it was not included in Florida’s NIF database; or

 typographical errors caused a mism atch between CAMD and NIF. MACTEC made the above updates and now all CAMD units have a match in Florida’s NIF database.

1.6.4 Georgia Georgia specified that 2008 emissions data should be backcasted to 2007 or and 2005 emissions data should be projected to 2007. The backcasting of 2008 emissions and projecting of 2005 emissions was pe rformed in the following manner:

 Facilities with 2007 emissi ons do not get changed;

 For facilities with 2005 and 2008 emissi ons (but no 2007 emissions), 2007 emissions were estimated based on a linea r interpolation between facility level 2005 and 2008 emissions on a pollutant-by-polluta nt basis to calcula te facility level 2007 emissions. A scaling factor was then calculated as the ratio of reported 2008 emissions to interpolated 2007 emissions, wh ich was used to create to scale back 2008 reported emissions to 2007 at the emission process level.

 For facilities with only 2008 data (no 2007 or 2005 data available), we used the SIC growth factors from the VISTAS Best&Final inventory to backcast 2008 reported emissions to 2007. The VISTAS SIC growth factors were used to calculate a scaling factor which was used to scale back 2008 reported emissions to 2007 at the emission process level.

 For facilities with only 2005 data (no 2007 or 2008 data available), we used the SIC growth factors from the VISTAS Best&Final inventory to project 2005 reported emissions to 2007. The VISTAS SIC growth factors were used to calculate a scaling factor which was used to project 2005 reported emissions to 2007 at the emission process level. After the above backcasting and projecting was performed, additional adjustments were made for facilities where only 2005 data were av ailable and the facility did not operate in 2007 or operated for only part of 2007. Facil ities that did not operate in 2007 were removed from the NIF files. For facilit ies that operated for part of 2007, the 2005 emissions were approximated for 2007 by multip ly the 2005 emissions by a scaling factor of the number of days the facili ty operated in 2007 divided 3 65 days of full year operation.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 31

MACTEC Engineering and Consulting, Inc. Also, the end date in the NIF EM and PE tables were changed to reflect the actual date that the facility ceased operati on. These facilities were:

FIPS PLANTID FACILITY NAME DATE SHUTDOWN SCALING FACTOR 13159 15900011 Georgia-Pacific Corp Panelboard 15-Aug-07 0.62 13045 04500008 Southwire Co, Copper Division 7-Mar-07 0.18 13121 12100364 Ford Motor Co Atlanta Assembly 1-Dec-07 0.92 13121 12100004 General Shale Brick 28-Mar-07 0.24 13175 17500047 Victor Forstmann, Inc. 1-Apr-07 0.25 13081 08100019 Lasco Bathware 6-Nov-07 0.85 13089 08900031 Siemens Energy & Auto 1-Sep-06 0.00 13241 24100001 Rabun Apparel, Inc. Not operated in 2007 0.00 13261 26100005 Textron Automotive Company 1-Feb-07 0.08

The following facilities reported emissions data to CAMD but were not in Georgia’s NIF submittal:

FIPSST FIPSCNTY PLANTID ORISID FACILITY NAME 13 147 14700021 70454 HARTWELL ENERGY FACILITY 13 149 14900004 55061 TENASKA GEORGIA 13 149 14900005 55141 HEARD COUNTY POWER LLC 13 149 14900006 7917 CHATTAHOOCHEE ENERGY FACILITY 13 149 14900007 7946 WANSLEY 13 153 15300040 7348 GEORGIA POWER COMPANY, ROBINS CT 13 153 15300042 55040 MID GEORGIA COGEN 13 157 15700034 7765 GEORGIA POWER COMPANY, DAHLBERG 13 205 20500043 7768 SOWEGA POWER LLC 13 205 20500044 55304 BACONTON POWER 13 207 20700030 7829 SMARR ENERGY CENTER 13 233 23300042 7813 SEWELL CREEK ENERGY 13 263 26300013 7916 TALBOT COUNTY ENERGY 13 293 29300027 55267 WEST GEORGIA GENERATING CO 13 297 29700040 7764 MPC GENERATING 13 297 29700041 55244 DOYLE GENERATING FACILITY 13 297 29700042 55128 WALTON COUNTY POWER LLC 13 303 30300039 55332 WASHINGTON COUNTY 13 303 30300040 55672 DUKE ENERGY SANDERSVILLE LLCDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page 32

MACTEC Engineering and Consulting, Inc. MACTEC added these facilities and their associ ated emission units to the NIF tables. All of the units are gas-fired turbines. MACTEC calculated 2007 emissions for these units in the following manner:

 NOx – used the CAMD reported 2007 annual NOx emissions

 SO2 – used the CAMD reported 2007 annual SO2 emissions

 CO – calculated annual CO emissions us ing the CAMD reported 2007 annual heat input (mmBtu/year) and the AP-42 emission factor of 0.03 lbs/mmBtu

 PM10-PRI – calculated annua l PM10-PRI emissions using the CAMD reported 2007 annual heat input (mmBtu/year) and the AP-42 emission factor of 0.0066 lbs/mmBtu

 PM25-PRI – calculated annua l PM25-PRI emissions using the CAMD reported 2007 annual heat input (mmBtu/year) and the AP-42 emission factor of 0.0066 lbs/mmBtu

 VOC – calculated annual VOC emissions using the CAMD reported 2007 annual heat input (mmBtu/year) and the AP- 42 emission factor of 0.0021 lbs/mmBtu These calculations were review ed and approved by Georgia. Stack parameter changes were made for fugitive emission release points that were recommended for change based on the QA checks and gap filling process described in Section 1.5.2 of this report.

1.6.5 Kentucky Kentucky compared facility-level emissions in their State database to the emissions in the 2007 SEMAP inventory. They identified di screpancies at two facilities: (1) NRE Acquisition Co LLC (211450019), which appeared to be undercounted by 25.4955 tons of NOx in the draft 2007 SEMAP inventor y and (2) Chesapeake Applachia LLC (2119500252), which appeared to be underc ounted by about 76.7157 tons VOC and 6.7362 tons of CO in the SEMAP inventory. These discrepancies were iden tified and resolved, so that now the Kentucky database and the SEMAP 2007 are in agreement. Kentucky provided updated latitude and longitude data for 677 stacks that were identified as being located outside of the county boundari es. Stack parameter changes for the stack diameter, flow rate, and velocity were made for fugitive emission release points that were recommended for change based on the QA checks and gap filling process described in Section 1.5.2 of this report. We retained Ke ntucky’s values for stack height and exit gas temperature.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 33

MACTEC Engineering and Consulting, Inc. 1.6.6 Kentucky – Jefferson County Jefferson County updated the coordinates of em ission release points for large and mediumsized point sources. Large sources are those with Title V operating permits. Mediumsized sources are those with synthetic minor operating permits. Most of these emission release points will match those reported in the 2007 National Emissions Inventory (NEI). Many of these coordinates were digitized usi ng a geographic information system (GIS) in early April 2010. Others (those showing fewer significant digits in the UTM coordinates) were obtained by other means, usually by interpolation on USGS 1:24 000 scale paper maps. Generally the ones that were corrected were those that were found to be the most inaccurate as seen in the GIS. The 2007 SEMAP inventory was updated with this new location information.

1.6.7 Mississippi In preparing the initial version of th e 2007 SEMAP point source inventory, MACTEC added facilities from EPA’s 2005 NEI that were not included in Mississippi’s 2007 submittal. Mississippi reviewed the facilities that were added and indicated that much of the data for the 2005 NEI facilities was for ve ry small sources, contained dated emissions data, had some double-counting of sources, contai ned data for airports (which are included in the SEMAP nonroad inventory) and did not reliably represent emissions in 2007. As a result, Mississippi decided to remove most of the facilities added from the 2005 NEI from the 2007 SEMAP inventory. The emissions from these sources will be accounted for in the inventories for ar ea and nonroad sectors. Mississippi provided updated lati tude and longitude data for 15 stacks that were identified as being located outside of the county boundaries. Mississippi approved the stack pa rameter changes for the stacks that were recommended for change based on the QA checks and gap f illing process described in Section 1.5.2 of this report. Most of these changes affect ed fugitive emission sources with a emission release point of “9999”. These stacks were upda ted to change the emi ssion release type to “01 – fugitive” and to use the default fugitive emission release stack parameters described in Section 1.5.2. Mississippi reviewed the CA MD-to-NIF crosswalk and updated several linkages to correctly map CAMD identifiers to NIF. Three facilities (BTEC New Albany ORIS 13213, Natchez ORIS 2052, and AP Holdings S outhhaven ORIS 55219) are currently shut down and did not operate in 2007. Choc taw Gas generation (ORIS 55634), and RRI Energy (ORIS 55706), are newer and were not completely represented in Mississippi’sDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page 34

MACTEC Engineering and Consulting, Inc. original submittal. Mississippi provided the necessary stack data for modeling for both of these facilities.

1.6.8 North Carolina A large increase in VOC emissions from 2002 to 2007 was identified during the review of North Carolina’s initial submittal. North Carolina investigated this problem and identified a serious problem in their data conversion pr ocess. A new spreadsheet table was provided in May 2010 to correct this problem. MACTEC converted the spreadsheet file a NIF database. The new submittals were subjected to the same QA and PM augmentation processes described in previous sections. North Carolina reviewed the geographic coordina tes for the stacks that were flagged as being outside of the appropriate county bounda ries. The new submittal mentioned in the previous paragraph contained co rrections to the flagged latitu de and longitude issues. NC has reviewed the recommended stack repla cement parameters and agreed to accept all of the recommendations based on the SCC code. In addition, Duke Energy provided additional co rrections for stack parameters for 2007. For the Marshall Steam Plant, new FGD stack s were installed in May 2007 (combined stack for Units 1&2), March 2007 (Unit 3) and May 2006 (Unit 4). For other plants (Belews Creek, Cliffside, and G.G. Allen), new stacks will become operational after 2007.

1.6.9 North Carolina – Buncombe County Buncombe County approved the stack parame ter changes for the stacks that were recommended for change based on the QA checks and gap filling process described in Section 1.5.2 of this report. In a few cases , Buncombe County updated the original stack parameters for certain stacks and requeste d that the updated stack data be used. The geographic coordinates were inadvert ently truncated (not rounded) to 1/100 th of a degree during the compilation of the initial SEMAP inventory. This problem was corrected in Version 1.3. Buncombe County compared a sampling of th e 2007 SEMAP inventory to what they had submitted and found them to be in agreement.

1.6.10 North Carolina – Forsyth County Forsyth County reviewed the data in the SEMAP 2007 inventory and emissions data for the more significant processes, i.e. the highe st emitting sources. The emissions for all pollutants except PM for the processes they reviewed matched their data. The PMDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page 35

MACTEC Engineering and Consulting, Inc. emissions did not match the data they provided data in a few cases. The reason for this difference is due to correcting inconsistenc ies in the reported PM data during the PM augmentation process. For example, the Co rn Products International facility (ID 3706700732, emission point ES062C, process ID 62C-W had reported PM-CON emissions of 11.58 tons but PM10-PRI emissions of only 3.41 tons. Since PM-CON cannot be greater than PM10-PRI, the PM10-PRI value was replaced during the PM augmentation process. Forsyth County provided the mission facility na me (Wake Forest University) for Facility ID 3706700003. The geographic coordinates were incorrect for many facilities. These have been replaced for all facilities in Forsyth County.

1.6.11 North Carolina – Mecklenburg County Mecklenburg County approved the stack parameter changes for the stacks that were recommended for change based on the QA checks and gap filling process described in Section 1.5.2 of this report.

1.6.12 South Carolina In preparing the initial version of th e 2007 SEMAP point source inventory, MACTEC added facilities from EPA’s 2005 NEI that we re not included in South Carolina’s 2007 submittal. South Carolina reviewed the faciliti es that were added and indicated that much of the data for the 2005 NEI facilities was for very small sources, contained dated emissions data, had some double-counting of s ources, contained data for airports (which are included in the SEMAP nonroad inventory) and did not reliably represent emissions in 2007. As a result, South Carolina decided to re move many of the facilities added from the 2005 NEI from the 2007 SEMAP inventory because th ey were either minor sources, out of business, or airports. The emissions from these sources will be accounted for in the inventories for area and nonroad sectors. South Carolina provided updated latitude a nd longitude data for 14 stacks that were identified as being located outside of the county boundaries. Five of these stacks were associated with facilities from the 2005 NEI which were removed from the SEMAP inventory. For the remaining stacks that were flagged, the facility level latitude and longitude were used to more accurately locate the stack. South Carolina approved the stack parame ter changes for the stacks that were recommended for change based on the QA checks and gap filling process described inDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page 36

MACTEC Engineering and Consulting, Inc. Section 1.5.2 of this report. In several cas es, South Carolina updated the original stack parameters for certain stacks and requeste d that the updated stack data be used. South Carolina reviewed the PM augm entation of PM10-PRI and PM2.5-PRI and generally agreed with the small increases in the PM10-PRI and PM2.5-PRI emissions resulting from the augmentation process. South Carolina expresse d a concern about the increases that were made to the certain fuel burning SCCs (20100101, 20100201, and 20200201). The reason for the small PM10-PRI and PM25-PRI increase for these SCCs was that a few facilities had reported PM10- FIL and PM25-FIL, not PM10-PRI and PM25- PRI. Since the PM10-FIL and PM25-FIL were reported, the augmentation process calculated a PM-CON value and added it to th e PM10-FIL and PM25-FIL values to get the revised PM10-PRI and PM25-PRI values.

South Carolina reviewed the CAMD-to-NIF crosswalk and updated several linkages to correctly map CAMD identifiers to NIF. South Carolina also compared the CAMDreported NOx and SO2 emissions to the NIF -reported emissions, and updated the NIF emissions for several coal-fired plants with the CAMD emissions after consulting with the affected facilities.

1.6.13 Tennessee In preparing the initial version of th e 2007 SEMAP point source inventory, MACTEC added facilities from EPA’s 2005 NEI th at were not included in Tennessee’s 2007 submittal. Tennessee reviewed the facilities th at were added and indicated that much of the data for the 2005 NEI facilities was for ve ry small sources, contained dated emissions data, had some double-counting of sources, contai ned data for airports (which are included in the SEMAP nonroad inventory) and did not reliably represent emissions in 2007. As a result, Tennessee decided to remove most of the facilities added from the 2005 NEI from the 2007 SEMAP inventory. The emissions from these sources will be accounted for in the inventories for ar ea and nonroad sectors. Tennessee provided updated 2007 emissions data for 16 facilities that were not in their original submittal:

FIPS Facility Identifier Facility Name 47149 0155 NISSAN NORTH AMERICA, INC. 47027 0022 HONEST ABE LOG HOMES, INC., ETC. 47029 0020 SONOCO PRODUCTS COMPANY 47031 0010 ARNOLD ENGINEERING DEVELOPMENT CENTER 47031 0067 BATESVILLE MANUFACTURING, INC. 47031 0113 M-TEK, INC.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 37

MACTEC Engineering and Consulting, Inc. FIPS Facility Identifier Facility Name 47031 0123 CREATEC CORPORATION 47047 0080 STABILT AMERICA, INC 47053 0119 Kongsberg Automotive 47071 0074 PRAXIS INDUSTRIES 47077 0060 VOLVO PENTA MARINE PRODUCTS, L.C. 47113 0020 ARMSTRONG HARDWOOD FLOORING 47125 0092 NYRSTAR CLARKSVILLE, INC 47151 0002 HARTCO FLOORING COMPANY 47151 0051 ARMSTRONG HARDWOOD FLOORING 47167 0079 QW MEMPHIS CORPORAT ION - COVINGTON DIVISION

Tennessee provided updated latitude and longitude data for 25 stacks that were identified as being located outside of the county boundaries. Tennessee also provided changes to the stack parameters for 29 stacks. Stack parameter changes were made for fugitive emission release points that were recommended for ch ange based on the QA checks and gap filling process described in Secti on 1.5.2 of this report.

1.6.14 Tennessee – Davidson County Davidson County reviewed the draft point so urce emission inventory and approved the emissions contained in it. Davidson County approved the stack para meter changes for 723 stacks that were recommended for change based on the QA checks and gap filling process described in Section 1.5.2 of this report. In severa l cases, Davidson County provided updated stack parameters for selected stacks.

1.6.15 Tennessee – Hamilton County Stack parameter changes were made for fugitive emission release points that were recommended for change based on the QA checks and gap filling process described in Section 1.5.2 of this report. Hamilton County provided updated stack latitude and longitude for three facilities that were identi fied as being located outside of the county boundaries.

1.6.16 Tennessee – Knox County Stack parameter changes were made for fugitive emission release points that were recommended for change based on the QA checks and gap filling process described inDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page 38

MACTEC Engineering and Consulting, Inc. Section 1.5.2 of this report. Knox County pr ovided updated stack latitude and longitude for one facility that was iden tified as being located outsi de of the county boundaries.

1.6.17 Tennessee – Shelby County Shelby County approved the stack parame ter changes for 765 stacks that were recommended for change based on the QA checks and gap filling process described in Section 1.5.2 of this report. In a few cases, Shelby County provided updated stack parameters for selected stacks. Hamilton County provided updated stack latitude and longitude for facilities that were flagged as being located outsi de of the county boundaries.

1.6.18 Virginia Virginia provided updated latit ude and longitude data for 115 stacks that were identified as being located outside of the county boundaries. Virginia approved the stack parameter cha nges for 540 stacks that were recommended for change based on the QA checks and gap filling process described in Section 1.5.2 of this report. The only exception was for the Jewel Coke Company (ID 51027-00004, stacks 1 and 3), where Virginia requested that the original stack exha ust gas temperatures of 1500 degrees Fahrenheit be retained. As part of the development of a 2007 inventor y for the Mid-Atlantic and Northeast States directed by MARAMA, Virginia devel oped and approved the 2007 CAMD-to-NIF crosswalk and the 2007 emission valu es for all sources.

1.6.19 West Virginia West Virginia approved the stack para meter changes for 540 stacks that were recommended for change based on the QA checks and gap filling process described in Section 1.5.2 of this report. There were four exceptions (Aker Plastics 5400300026, Gratech International 5403300001, Monongahe la Power Harrison 5403300015, DuPont Belle 5403900001) where West Virgin ia requested that the original stack parameters for certain stacks be retained. West Virginia reviewed the locations for the se ven facilities flagged as being outside of the county boundaries and provided updated stack la titude and longitude for these facilities. West Virginia reviewed the draft emission i nventory and confirmed that all point source facilities are represented in the inventory, that the PM a ugmentation procedure producedDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page 39

MACTEC Engineering and Consulting, Inc. reasonable results, and the 2007 emissions in th e SEMAP inventory agreed with the data they submitted. West Virginia reviewed the CAMD-to-NIF cr osswalk and identified the linkage between CAMD and NIF identifiers for the Union Carbide Corporation (5403900003) boilers B25, B26, and B27. West Virginia approved all other linkages between CAMD and NIF identifiers.

1.7 STAKEHOLDER REVIEW S/L agencies provided access to Version 1.3 of the 2007 point source inventory and solicited input from various stakeholders includi ng EPA, the regulated community, academia, environmental groups, and the general public. This section documents the changes made to Version 1.3 based on S/L agency review of stak eholder comments as well as any additional updates or corrections identif ied by the S/L agencies.

1.7.1 Alabama
The National Lime Association requested consideration of a modification to PM emissions data for one of their faciliti es in Alabama (Unimin Lime Co rporation, Calera Plant). The request was reviewed by State staff and the s uggested correction was justified and made.

1.7.2 Florida Lakeland Electric requested that the SO2 a nd NOx emission values from the EPA CAMD submittal be used instead of the values repor ted to the State. Th e CAMD represent the emissions more accurately that the State submittal for two plants (Plant IDs 1050004 and 1050003). Florida agreed to make these changes. Tampa Electric reviewed the database and s uggested several corrections. Most of the changes are due to the instal lation and operation of the S CR control devices on Big Bend units 1-4. Tampa Electric also evaluated filt erable and condensable PM emissions for all of its major generating units and provided be tter, unit specific, emission rates for these units where available. Finally, Tampa Electri c provided some corrections to stack exhaust gas parameters. Florida agreed to make all of these changes. Southern Company indicated that the invent ory stack data for Crist plant reflects the current scrubbed stack parameters, not the operating parameters in 2007. Appropriate stack parameters for 2007 were submitted and reviewed/approved by Florida.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 40

MACTEC Engineering and Consulting, Inc. 1.7.3 Georgia Georgia reviewed the emissions values a nd stack parameters for the Georgia Power facilities in the State. Ge orgia provided updated PM and NH3 emissions data for all Georgia Power facilities. The revised PM em ission values included condensable emissions which were previously missing from the inve ntory. Georgia also provided updated stack parameters for selected Georgia Power stacks. Georgia also identified a number of em ission units where the PM2.5 emissions were greater than the PM10 emissions. The source of this error was investigated and identified, and revisions were made to correct this error.

1.7.4 Kentucky Kentucky identified that the PM point sour ce emissions originally submitted for all Kentucky counties, excluding Jefferson County, should be considered as filterable PM emissions. The original submittal containe d pollutant codes (PM-PRI, PM10-PRI, PM25- PRI) that represent the sum of filterable and condensable emissions. These should have been reported as filterable only (PM-FIL, PM10-FIL, PM25-FIL). MACTEC changed the pollutant codes to represent filterable em issions only, and re-ran the PM augmentation process described previously in Section 1.4 to add condensable emissions to the filterable emissions. Kentucky reviewed and approved the revised PM emissions, except for a few EGUs. Kentucky worked with these utilities in obtaining updated PM emissions data that included both filterable and condensable em issions. These changes to the EGU PM emissions are discussed further in Section 1.9.

1.7.5 North Carolina Duke Energy indicated that the SCC for Marshall Units 1&2 were 10200202 and 10200502 (industrial boiler, coal and oil) but should be 10100202 and 10100502 (electric generation boiler, coal and oil). Duke Energy requested that the SCC be changed as that will impact how boilers are grouped by cat egory for various regulatory and emission projection scenarios.

1.7.6 Tennessee Tennessee identified three facilities (A PAC-TN Harrison Construction Division, Dyersburg Compressor Station, Ki mberly Clark Corporation) th at had duplicate entries in the emission inventory. MACTEC investigated this issue and identified the error. The duplicate entries were removed.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 41

MACTEC Engineering and Consulting, Inc. Tennessee also provided updated 2007 emissi ons data for the CalsonicKansei North America -Lewisburg Operations facility.

1.8 IDENTIFICATION OF EGU AND NONEGU POINT SOURCES States were asked to classify units in the 2007 SEMAP emissi ons inventory as either EGU or nonEGU for emission projection purposes. Emission projections for EGU point sources are being developed by the Eastern Regional Technical Advisory Committee (ERTAC). The emissions from point sources classified as nonEGUs will be projected using the methods and data developed by SEMAP.
Most, but not all, of the units that are required to report hour ly emissions to EPA’s Clean Air Markets Division (CAMD) are considered to be EGUs. CAMD implements EPA’s rule found in Volume 40 Part 75 of the Code of Federal Regulations (CFR), which requires an hourly accounting of emissions from each affect ed unit - i.e., sources participating in an emissions cap and trade program under the Acid Rain Control Program, the NOx Budget Trading Program, or the Clean Air Intersta te Rule. The following guidance was provided to States to determine whether a unit that repor ts to CAMD should be classified as an EGU or nonEGU: For the ERTAC process, a unit should only be considered EGU if it meets the following criteria:

 An EGU sells most of the power ge nerated to the electrical grid;

 An EGU burns mostly commercial fuel. Commercial fuel in this case means natural gas, oil, and coal. Wood would not be considered as commercial fuel because some states have them as renewa ble, therefore, to prevent double counting, unless it's already in the CAMD data base, units that burn wood and other renewable sources (depending on each st ate's own definition) should not be considered as EGU. The following units were NOT considered as EGU for the purpose of projection emissions:

 A unit that generates power for a facility but occasionally sells to the grid;

 Emergency generators;

 Distributed generation units. S/L agencies were provided with a list of units that report to CAMD as well as a list of units with an electric generating unit SCC (1-01-xxx-xx or 2-01-xxx-xx). From these lists, S/L agencies identified units that should be classified as EGUs a nd those that should be classified as nonEGUs. A few States also identified units with SCCs beginning with 1-01 or 2-01 that do not report to CAMD but which should be classified as EGUs; however, forDevelopment of Point Source Emission Inventory for 2007 January 26, 2011 Page 42

MACTEC Engineering and Consulting, Inc. emission projection purposes these units will be processed using the nonEGU projection methodology developed by SEMAP. MACTEC added a flag to the NIF EP table to identify each unit accord ing to the following classification scheme:

 EGU-CAMD are combustion units that report hourly emissions to the CAMD database and have been classified as EGUs by the S/L agency;

 EGU-nonCAMD are combustion units with SCC starting with 101 or 201 that are not contained in CAMD database;

 nonEGU-CAMD are combustion units that repor t hourly emissions to the CAMD database and have been classified as nonEGUs by the S/L agency; and

 nonEGU-nonCAMD are all other point sources not classified above. The above flags allow for sources to be cat egorized in different ways for emission projection and emission reporting purposes.

1.9 FINAL S/L AGENCY QA REVIEW Two final QA checks were made. The first ch eck was for S/L agencies to verify the PM emissions data for coal- and oil-fired units in cluded PM condensable emissions in addition to PM filterable emissions. The second check was for S/L agencies to verify the location and emission values for certain sources via review of emission bubbl e plots prepared by another SEMAP contractor. This section documents the changes made based on these final QA checks. In addition, the document ation was revised to address comments provided by EPA Region 4.

1.9.1 Kentucky Kentucky coordinated the review of PM emissions with util ities in the Commonwealth and provided updated PM condensable em issions for the following units:

 Duke Energy East Bend (21-015-00029) Unit 2;

 TVA Shawnee (21-145-00006) Units 1 through 10;

 TVA Paradise (21-177-00006) Units 1, 2, and 3; and

 Kentucky Energy Reid/Henderson (21-233-00001) Units H1 and H2 1.9.2 North Carolina Both Duke Energy and Progress Energy submitt ed information to confirm that the PM2.5- PRI and PM10-PRI emission estimates for its facilities do include both filterable and condensable values.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 43

MACTEC Engineering and Consulting, Inc. 1.9.3 North Carolina – Forsyth County In its original submittal, Forsyth County submitted a mix of 2007 and 2008 emission data. After further reviewing the 2007 and 2008 da ta, Forsyth County identified several revisions to make the data more representa tive of 2007. One facility (VP Buildings, Inc., Plant ID 00488) that shut down in 2008 was om itted for the initial submittal and was added to the SEMAP 2007 inventory. The only other si gnificant change was the addition of the coal boilers at R.J. Reynolds Tobacco Co mpany (Plant ID 00039) to the SEMAP 2007 inventory that were shut down in 2008. Some additional relatively minor corrections were made as well.

1.9.4 South Carolina
South Carolina confirmed that the PM conde nsable emissions are included in the PM10- PRI and PM2.5-PRI data provided for coal- and oil-fired EGUs.

1.9.5 Virginia Virginia confirmed that the PM condensable emissions are included in the PM10-PRI and PM2.5-PRI data provided for coal- and oil-fired EGUs.

1.9.6 West Virginia After reviewing the emission density maps and emission bubble plots, West Virginia submitted revisions to the geographic coordina tes at three facilities (54-009-00012 Impress USA, 54-021-00001 Columbia Gas Glenvill e, 54-057-00008 Newpage Corporation).

1.10 2007 POINT SOURCE EMISSION SUMMARY This section presents State-level summari es of the annual point source emissions by pollutant in the 2007 SEMAP inventory and co mpares the emissions to the 2002 VISTAS Best and Final inventory. For most States and pollutants, point source emissions have decreased from 2002 to 2007.

Exhibit 7 shows that CO emissions in th e SEMAP region have decreased by about 30 percent between 2002 and 2007. Exhibit 8 show s that most of the point source CO emissions (about 81 percent) come from nonEGUs that are not required to report emissions to CAMD.

Exhibit 9 shows that NH3 emissions in the SEMAP region have remained about the same in 2002 and 2007, although NH3 emissions increase d substantially in some States while decreasing in others. Exhibit 10 shows that most of the point source NH3 emissions (about 90 percent) come from nonEGUs that are not required to report emissions to CAMD.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 44

MACTEC Engineering and Consulting, Inc. Exhibit 11 shows that NOx emissions have decreased by about 27 percent between 2002 and 2007. All States showed a decrease in NOx emissions from point sources. Exhibit 12 shows that about 69 percent of the point source NOx emissions come from EGUs that are required to report emissions to CAMD. Anot her 28 percent of the NOx emissions result from nonEGUs that are not required to report emissions to CAMD.

Exhibit 13 shows that PM10-PRI emissions in the SEMAP region have decreased by about 14 percent between 2002 and 2007, although PM10- PRI emissions increased substantially in some States while decreasing in others. Exhibit 14 shows that about 46 percent of the point source PM10-PRI emissions come from EGUs that are require d to report emissions to CAMD. Another 53 percen t of the PM10-PRI emissions result from nonEGUs that are not required to report emissions to CAMD.

Exhibit 15 shows that PM25-PRI emissions in the SEMAP region have decreased by about 12 percent between 2002 and 2007, although PM25- PRI emissions increased substantially in some States while decreasing in others. Exhibit 16 shows that about 45 percent of the point source PM25-PRI emissions come from EGUs that are require d to report emissions to CAMD. Another 54 percen t of the PM25-PRI emissions result from nonEGUs that are not required to report emissions to CAMD.

Exhibit 17 shows that SO2 emissions in th e SEMAP region have decreased by about 14 percent between 2002 and 2007. All States exce pt Georgia showed a decrease in SO2 emissions. Exhibit 18 shows that most of the point source SO2 emissions (about 87 percent) come from EGUs that are require d to report emissions to CAMD. Another 11 percent of the SO2 emissions result from nonEGUs that are not required to report emissions to CAMD.

Exhibit 19 shows that VOC emissions in th e SEMAP region have decreased by about 20 percent between 2002 and 2007. Exhibit 20 shows th at nearly all of the point source VOC emissions (about 97 percent) result from nonEGUs that are not required to report emissions to CAMD. The reasons for the differences between 2002 and 2007 are many and vary by State, facility, and pollutant. Examples include: 1) new controls added between 2002 and 2007; 2) change in emission factors or source test data; 3) inclus ion of PM condensables that were not included in 2002; 4) more {or less} facilities in 2002 inventory than in 2007 inventory; 5) new sources that came online between 2002 and 2007; 6) different fuels used in 2007 than in 2002; 7) industry specific ec onomic growth or cont raction between 2002 and 2007; 8) facility or emission unit clos ures; and 9) errors in 2002 inventory.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 45

MACTEC Engineering and Consulting, Inc. Exhibit 7 – 2002 and 2007 Point Source CO Emissions by State (tons/year)

STATE 2002 2007 Change Alabama 185,550 119,409 -36% Florida 139,045 111,280 -20% Georgia 140,561 82,547 -41% Kentucky 122,555 82,553 -33% Mississippi 59,871 40,294 -33% North Carolina 64,461 67,127 4% South Carolina 63,305 60,375 -5% Tennessee 122,348 50,667 -59% Virginia 70,688 72,029 2% West Virginia 100,220 65,230 -35% SEMAP 1,068,604 751,511 -30%

Exhibit 8 – 2007 Point Source CO Emissions by Category (tons/year)Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 46

MACTEC Engineering and Consulting, Inc. Exhibit 9 – 2002 and 2007 Point Source NH3 Emissions by State (tons/year)

STATE 2002 2007 Change Alabama 2,200 2,191 0%

Florida 1,657 1,661 0% Georgia 3,697 6,046 64% Kentucky 1,000 113 -89% Mississippi 1,359 1,640 21% North Carolina 1,234 1,706 38% South Carolina 1,553 1,125 -28% Tennessee 1,817 1,429 -21% Virginia 3,230 1,830 -43% West Virginia 453 366 -19% SEMAP 18,200 18,107 -1%

Exhibit 10 – 2007 Point Source NH3 Emissions by Category (tons/year)Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 47

MACTEC Engineering and Consulting, Inc. Exhibit 11 – 2002 and 2007 Point Source NO x Emissions by State (tons/year)

STATE 2002 2007 Change Alabama 244,348 196,145 -20% Florida 302,834 212,294 -30% Georgia 196,767 154,496 -21% Kentucky 237,209 208,455 -12% Mississippi 104,661 98,183 -6% North Carolina 196,782 100,949 -49% South Carolina 130,394 81,480 -38% Tennessee 221,652 144,792 -35% Virginia 147,300 112,938 -23% West Virginia 277,589 188,629 -32% SEMAP 2,059,536 1,498,361 -27%

Exhibit 12 – 2007 Point Source NOx Emissions by Category (tons/year)Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 48

MACTEC Engineering and Consulting, Inc. Exhibit 13 – 2002 and 2007 Point Source PM10-PRI Emissions by State (tons/year)

STATE 2002 2007 Change Alabama 32,886 34,800 6% Florida 57,243 35,796 -37% Georgia 32,834 33,214 1% Kentucky 21,326 30,678 44% Mississippi 21,106 12,368 -41% North Carolina 36,592 42,991 17% South Carolina 35,542 30,605 -14% Tennessee 49,814 27,882 -44% Virginia 17,211 19,203 12% West Virginia 22,076 13,736 -38% SEMAP 326,630 281,273 -14%

Exhibit 14 – 2007 Point Source PM10-PRI Emissions by Category (tons/year)Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 49

MACTEC Engineering and Consulting, Inc. Exhibit 15 – 2002 and 2007 Point Source PM25-PRI Emissions by State (tons/year)

STATE 2002 2007 Change Alabama 23,291 24,953 7% Florida 46,148 28,418 -38% Georgia 22,401 25,059 12% Kentucky 14,173 21,111 49% Mississippi 11,044 8,731 -21% North Carolina 26,998 33,441 24% South Carolina 27,399 23,493 -14% Tennessee 39,973 22,147 -45% Virginia 12,771 14,875 16% West Virginia 15,523 9,173 -41% SEMAP 239,721 211,401 -12%

Exhibit 16 – 2007 Point Source PM25-PRI Emissions by Category (tons/year)Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 50

MACTEC Engineering and Consulting, Inc. Exhibit 17 – 2002 and 2007 Point Source SO2 Emissions by State (tons/year)

STATE 2002 2007 Change Alabama 544,309 526,664 -3% Florida 518,721 371,619 -28% Georgia 568,731 683,370 20% Kentucky 518,086 433,731 -16% Mississippi 103,388 94,978 -8% North Carolina 522,113 420,554 -19% South Carolina 259,916 216,157 -17% Tennessee 413,755 287,698 -30% Virginia 305,106 243,048 -20% West Virginia 570,153 428,350 -25% SEMAP 4,324,278 3,706,169 -14%

Exhibit 18 – 2007 Point Source SO2 Emissions by Category (tons/year)Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 51

MACTEC Engineering and Consulting, Inc. Exhibit 19 – 2002 and 2007 Point Source VOC Emissions by State (tons/year)

STATE 2002 2007 Change Alabama 49,332 38,881 -21% Florida 40,995 33,683 -18% Georgia 34,952 36,717 5% Kentucky 46,321 47,679 3% Mississippi 43,852 34,587 -21% North Carolina 62,170 48,346 -22% South Carolina 38,927 29,281 -25% Tennessee 85,254 48,104 -44% Virginia 43,906 35,618 -19% West Virginia 15,775 12,503 -21% SEMAP 461,484 365,399 -21%

Exhibit 20 – 2007 Point Source VOC Emissions by Category (tons/year)Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 52

MACTEC Engineering and Consulting, Inc. 1.11 DATA FILES

These files are accessible on the MARAMA ftp site in the following location:

Address: ftp.mactec.com Login ID: externalclient Password: sen382 Folder: /OUTGOING/SEMAP_POINT_V_1_8/ Process level summary files containing all data that will be used in modeling:
AL SEMAP 2007 Process V_1_8.xls FL SEMAP 2007 Process V_1_8.xls GA SEMAP 2007 Process V_1_8.xls KY SEMAP 2007 Process V_1_8.xls MS SEMAP 2007 Process V_1_8.xls NC SEMAP 2007 Process V_1_8.xls SC SEMAP 2007 Process V_1_8.xls TN SEMAP 2007 Process V_1_8.xls VA SEMAP 2007 Process V_1_8.xls WV SEMAP 2007 Process V_1_8.xls

NIF 3.0 ACCESS Database w ith the 8 NIF tables:
SEMAP 2007 Point NIF V_1_8.mdb

NIF 3.0 ASCII delimited text files of the 8 NIF tables:
SEMAP 2007 PTTR V_1_8.txt SEMAP 2007 PTSI V_1_8.txt SEMAP 2007 PTER V_1_8.txt SEMAP 2007 PTEU V_1_8.txt SEMAP 2007 PTEP V_1_8.txt SEMAP 2007 PTPE V_1_8.txt SEMAP 2007 PTCE V_1_8.txt SEMAP 2007 PTEM V_1_8.txt Annual point source files in SMOKE ORL fo rmat are being prepared under SEMAP’s emission modeling contract.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 53

MACTEC Engineering and Consulting, Inc. 1.12 REFERENCES
Dutch 2005. Steven Dutch, Natural and Applied Sciences, University of Wisconsin - Green Bay. Converting UTM to Latitude and Longitude (Or Vice Versa) . Downloaded March 2009, last upd ated 19 April 2005. http://www.uwgb.edu/dutchs/Us efulData/UTMFormulas.HTM

EPA 2004. U.S. Environmental Protection Agency. Basic Format and Content Checker. Version Date 052604. Software no longer available on EPA web site.

EPA 2005. U.S. Environmental Protection Agency. Emissions Inventory Guidance for Implementation of Ozone and Particulate Matt er National Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations . EPA-454/R-05-001. August 2005. http://www.epa.gov/ttn/chief/ei docs/eiguid/eiguidfinal_nov2005.pdf

EPA 2006a. U.S. Environmental Protection Agency. NEI Quality Assurance and Data Augmentation for Point Sources . February, 2006. . ftp://ftp.epa.gov/EmisInventory/2002finalnei/ documentation/point/augm entation_point/2002nei_qa _augmentation_report0206.pdf
EPA 2006b. U.S. Environmental Protection Agency. 2002 NEI Stack Parameter Default

. ftp://ftp.epa.gov/EmisInventory/2002finalne i/documentation/augmentation_point_sector/

. EPA 2007. U.S. Environmental Protection Agency. Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goal s for Ozone, PM2.5, and Regional Haze. EPA -454/B-07-002. April 2007. http://www.epa.gov/ttn/scram/guidance/guide/final-03-pm-rh-guidance.pdf
EPA 2009a. U.S. Environmental Protection Agency. Clean Air Markets – Data and Maps Web Site; Unit Level Emissions Query for 2007. File downloaded on October 8, 2009. http://camddataandmaps.epa.gov/gdm/inde x.cfm?fuseaction=emissions.wizard

EPA 2009b. U.S. Environmental Protection Agency. Clean Air Markets – Emissions Data in SMOKE Format for 2007. File (hour_unit_2007.zip ) downloaded on October 8, 2009. http://camddataandmaps.epa.gov/gdm/index. cfm?fuseaction=emissions.prepacksmoke

EPA 2009c. U.S. Environmental Protection Agency. 2005 National Emissions Inventory Data & Documentation . file name: 2005v4CAPHAP_or l_point.zip. June 2009. ftp://ftp.epa.gov/EmisInventory/2005v4/2005emis

MARAMA 2006. Mid-Atlantic Regional Air Management Association. Technical Support Documentation for 2002 MANE-VU SI P Modeling Inventories, Version 3.Development of Point Source Emission Inventory for 2007 January 26, 2011 Page 54

MACTEC Engineering and Consulting, Inc. November 20, 2006. http://www.marama.org/technical-center/emissions-inventory/2002- inventory-and-projections/man e-vu-2002-emissions-inventory
SESARM 2009. Southeastern States Air Resource Managers, Inc. Point Source, OnRoad, and Fire Base Year, Future Year, and C ontrol Strategy Emissions Inventories – Quality Assurance Project Plan . August 2009.

VISTAS 2007. Visibility Improvement State and Trib al Association of the Southeast. Documentation of the Base G 2002 Base Year, 2009, and 2018 Emission Inventories for the Visibility Improvement State and Tri bal Association of the Southeast. February 2007. http://www.vistas-sesarm.or g/documents/VISTABF2003-20-2008.pdf