Appendix G Quality Assurance Of The Emissions InventoriesTABLE OF CONTENTS

**I. INTRODUCTION ..............................**

**................................................... ..............................................1** 

**II. QUALITY ASSURANCE OF AREA AND NONROAD MOBILE S OURCES EMISSIONS** 

**INVENTORIES........................................**

**................................................... ........................................1** 

**III. QUALITY ASSURANCE OF POINT SOURCE EMISSIONS INVENTORY .................................2** 

**A. Initial Data Evaluation........................**

**................................................... ........................................2** 

**B. Follow up Review Performed by SCDHEC...........**

**................................................... .....................3** 

**C. Emission Inventory QA Review ...................**

**................................................... ..............................3** 

**D. Eliminating Double Counting of EGU Units.......**

**................................................... .......................4** 

**E. EGU Quality Assurance steps....................**

**................................................... .................................5** 

**IV. Quality Assurance of On-Road Mobile Source E missions Inventory .................................**  **................5**

**Appendix G.1. Quality Assurance Project Plan.......**

**................................................... ..................................6** **1** QUALITY ASSURANCE OF THE EMISSIONS INVENTORIES

I. INTRODUCTION

**The attainment modeling for the Charlotte-Gastonia -Rock Hill, NC-SC 8-hour ozone**  **nonattainment area (the Metrolina area) was perform ed in conjunction with the regional haze modeling**  **being done by the Southeast Regional Planning Organ ization, Visibility Improvement State and Tribal**  **Association of the Southeast (VISTAS) and the fine particulate matter (PM2.5) and ozone modeling being**  **done by the Association of Southeastern Integrated Planning (ASIP). VISTAS and ASIP are run by the**  **ten Southeast states (Alabama, Florida, Georgia, Ke ntucky, Mississippi, North Carolina, South Carolina** 

**, Tennessee, Virginia and West Virginia). Since the r**  **egional haze and PM2.5 modeling uses annual simulations and includes an intermediate year that**  **is the attainment year required for the Metrolina nonattainment area, the South Carolina Department o**  **f Health and Environmental Control (SCDHEC) decided to use this modeling for its attainment dem**  **onstration. The sections below discuss the quality assurance (QA) procedures used by SCDHEC and the VI**  **STAS/ASIP emissions inventory contractors.**

II. QUALITY ASSURANCE OF AREA AND NONROAD MOBILE S OURCES EMISSIONS

INVENTORIES

**Many emission estimation methods are based on AP-4 2 factors located on the U.S.**  **Environmental Protection Agency (USEPA) website at http://www.epa.gov/ttn/chief/ap42/**  **, factors given in the Procedures document, and factors given in th**  **e documents of the Emission Inventory Improvement Program (EIIP) website located at**  **http://www.epa.gov/ttn/chief/eiip/ . Sources of error would primarily be**  **associated with multiplier values, data entry error s, and the accuracy of formulas. The inventory**  **developed by the VISTAS/ASIP contractor, MACTEC, fo llowed specific QA procedures. These**  **procedures are outlined in the report entitled, Doc umentation of the Base G 2002 Base Year, 2009, and**  **2018, Emission Inventories for VISTAS prepared for VISTAS by MACTEC, Inc. (a copy of this report is**  **attached to Appendix F). Throughout the inventory d evelopment process, QA steps were performed to**  **ensure that no double counting of emissions occurre d, and to ensure that a full and complete inventory**  **was developed for VISTAS/ASIP. QA was an important component to the inventory development**  **process and MACTEC performed the following QA steps on the area source component of the 2002 and** 

**2009 inventories:**

**1. All Consolidated Emissions Reporting Rule (CER R) and National Emissions Inventory (NEI)**  **Input Format (NIF) State supplied data submittals w ere run through the USEPA's Format and Content**  **checking software.**

**2. Source Classification Code (SCC) level emissio n summaries were prepared and evaluated to** 

**ensure that emissions were consistent and that ther e were no missing sources.** 

**3. Fields were either added or used within each N IF data table to track the sources of data for** 

**each emission record.**

**4. Data product summaries were provided to both t he VISTAS Emission Inventory Technical**  **Advisor and to Area Source and Fires Special Intere st Workgroup (SIWG) representatives for review and**  **comment. Changes based on these comments were imple mented in the files.** 

**5. Version numbering was used for all inventory f iles developed. The version numbering process**  **used a decimal system to track major and minor chan ges. For example, a major change would result in a** **2**

**version going from 1.0 to 2.0. A minor change would cause a version number to go from 1.0 to 1.1.**  **Minor changes resulting from largely editorial chan ges would result in a change from 1.00 to 1.01.** 

**6. All final NIF files were checked using the USE PA's Format and Content checking software**  **and summary information by State and pollutant were prepared comparing the current inventory to the**  **previous version of the inventory.**

**In addition for the 2009 projection inventories, T ier comparisons (by pollutant) were developed**  **between the 2002 base year inventory and the 2009 p rojection inventories. Also, total VISTAS/ASIP**  **pollutant summaries were prepared to compare total emissions by pollutant between versions of the**  **inventory.**

**For the fires inventory, data related to fuel load ing and fuel consumption was reviewed and**  **approved by the VISTAS Fire Special Interest Work G roup (SIWG) to ensure that values used for each**  **type of fire and each individual fire were appropri ate. Members of the VISTAS Fire SIWG included**  **representatives from most State Divisions of Forest ry (or equivalent), as well as U.S. Forest Service**  **and National Park Service personnel.** 

III. QUALITY ASSURANCE OF POINT SOURCE EMISSIONS I NVENTORY

A. Initial Data Evaluation

**The VISTAS/ASIP contractor, MACTEC, conducted an i nitial review of the 2002 point source**  **CERR data in accordance with the QA procedures spec ified in the Quality Assurance Project Plan**  **(QAPP) for this project (a copy of the QAPP is atta ched to this Appendix). The following evaluations**  **were completed to identify potential data quality i ssues associated with the CERR data:** 

**• Compared the number of sites in the CERR submitt al to the number of sites in the**  **VISTAS/ASIP draft 2002 inventory; the number of sit es in the CERR submittal was less than in the**  **VISTAS/ASIP draft 2002 inventory, since the CERR da ta was limited to major sources, while the**  **VISTAS/ASIP draft 2002 inventory contained data for both major and minor sources; verified with state** 

**and local contacts that minor sources not included in the CERR point source inventory were included in**  **the CERR area source inventory.**

**• Checked for correct pollutant codes and correct ed to make them NIF-compliant.** 

**• Checked for types of particulate matter codes r eported (i.e., PM-FIL, PM-CON, PM-PRI,**  **PM10-PRI, PM10-FIL, PM25-PRI, PM25-FIL); corrected codes with obvious errors (i.e., changed**  **PMPRI to PM-PRI). (The PM augmentation process for filling in missing PM pollutants is discussed in**  **Appendix F).**

**• Converted all emission values to tons to allow for preparation of emission summaries using** 

**consistent units.**

**• Checked start and end dates in the Emissions Pe riod record (PE) and Emissions record (EM)**  **tables to confirm consistency with the 2002 base ye ar.** 

**• Compared annual and daily emissions when daily emissions were reported. In some cases, the**  **daily value was non-zero (but very small) but the a nnual value was zero. This was generally the result**  **of rounding in a state or local agency's submittal.** **3**

**• Compared ammonia emissions as reported in the C ERR submittals and the 2002 Toxics**  **Release Inventory; worked with state and local agen cies to resolve any outstanding discrepancies.** 

**• Compared sulfur dioxide (SO2) and nitrogen oxid e (NOx) emissions for Electric Generating**  **Units (EGUs) to the USEPA's Clean Air Markets Divis ion continuous emission monitoring (CEM)**  **database to identify any outstanding discrepancies. (A full discussion of the EGU emissions analysis**  **is discussed in Appendix F.)** 

**• Prepared State-level emission summaries by poll utant for both the EGU and non-EGU sectors**  **to allow state and local agencies to compare emissi ons as reported in the 1999 NEI Version 2, the**  **VISTAS/ASIP draft 2002 inventory, and the CERR subm ittals.** 

**• Prepared facility-level emission summaries by p ollutant to allow state and local agencies to**  **review facility level emissions for reasonableness and accuracy. MACTEC communicated the results of**  **these analyses through email/telephone exchanges wi th the state and local point source contacts as wel**  **l as through Excel summary spreadsheets. The state and**  **local agencies submitted corrections and updates as necessary to resolve any QA issues from these check**  **s.**

B. Follow up Review Performed by SCDHEC

**The following QA checks were performed both togeth er and separate for EGU and non-EGU**  **point sources by the SCDHEC:**

**• Data product summaries and raw NIF 3.0 data fil es were examined.** 

**• NIF files were examined to identify problems wi th latitude and longitude, as well as, stack** 

**parameters.**

**• County emissions totals were examined to assure the counties with the highest emissions were**  **consistent with what was expected.**

**• Errors detected in earlier model runs were rech ecked with each successive model run to assure**  **their correction was carried forward in subsequent runs.** 

**• The Integrated Planning Model (IPM) results for all South Carolina EGUs were thoroughly**  **reviewed. Changes were made when the IPM results di ffered from planned controls and/or expected** 

**control efficiencies. Comments were also made to ac count for agreed upon future emission rates in the**  **Santee Cooper Consent Decree with SCDHEC and the US EPA.** 

**• Facility level emission summaries for 2009 were examined for both the base case and CAIR** 

**case to ensure that emissions were consistent and t hat there were no missing sources.** 

**• Ensured that stack parameters were modified app ropriately and where necessary at facilities** 

**where new controls are scheduled to be installed.**

**• Data were examined to assure there were no doub le counted facilities (an example would be if**  **a facility were known by two different names and co unted under each).** 

C. Emission Inventory QA Review**4**

**Throughout the inventory development process, QA s teps were performed to ensure that double**  **counting of emissions did not occur and to ensure t hat a full and complete inventory was developed for**  **VISTAS/ASIP. QA was an important component to the i nventory development process and MACTEC**  **performed the following QA steps on the point sourc e component of the VISTAS/ASIP revised 2002 base**  **year inventory:**

**1. Facility level emission summaries were prepare d and evaluated to ensure that emissions were**  **consistent and that there were no missing sources.**

**2. State-level EGU and non-EGU comparisons (by po llutant) were developed between the 2002**  **base year inventory, the draft VISTAS 2002 inventor y, and the 1999 NEI Version 2 inventory.** 

**3. Data product summaries and raw NIF 3.0 data fi les were provided to the VISTAS Emission**  **Inventory Technical Advisor and to the Point Source , EGU, and non-EGU Special Interest Work Group**  **representatives for review and comment. Changes bas ed on these comments were reviewed and approved**  **by the state and local point source contact prior t o implementing the changes in the files.** 

**4. Version numbering was used for all inventory f iles developed. The version numbering process**  **used a decimal system to track major and minor chan ges.** 

D. Eliminating Double Counting of EGU Units

**The following procedures were used to avoid double counting of EGU emissions in the 2009**  **point source inventory. The 2002 VISTAS point sourc e emission inventory contains both EGUs and non** 

**EGUs. Since this file contains both EGUs and non-EG U point sources and EGU emissions are projected**  **using the IPM, it was necessary to split the 2002 p oint source file into two components. The first**  **component contains those emission units accounted f or in the IPM forecasts. The second component**  **contains all other point sources not accounted for in IPM.** 

**The VISTAS/ASIP contractor, Pechan, developed 2009 NIF files for EGUs from the IPM parsed**  **files. All IPM matched units were initially removed from the 2009 point source inventory to create the**  **non-EGU inventory (which was projected to 2009 usin g the non-EGU growth and control factors). This**  **was done on a unit-by-unit basis based on a cross-r eference table that matches IPM emission unit**  **identifiers (ORISPL plant code and BLRID emission u nit code) to VISTAS NIF emission unit identifiers**  **(FIPSST state code, FIPSCNTY county code, State Pla nt ID, State Point ID). When there was a match** 

**between the IPM ORISPL/BLRID and the VISTAS emissio n unit ID, the unit was assigned to the EGU**  **inventory; all other emission units were assigned t o the non-EGU inventory.** 

**If an emission unit was contained in the NIF files created by Pechan from the IPM output, the**  **corresponding unit was removed from the initial 200 9 point source inventory. The NIF 2009 EGU files**  **from the IPM parsed files were then merged with the non-EGU 2009 files to create the base 2009 point** 

**source files.**

**Next, MACTEC prepared several ad-hoc QA queries to verify that there was no double-counting** 

**of emissions in the EGU and non-EGU inventories. MA CTEC reviewed the IPM parsed files to identify**  **EGUs accounted for in IPM. MACTEC compared this lis t of emission units to the non-EGU inventory** 

**derived from the VISTAS cross-reference table to ve rify that units accounted for in IPM were not**  **doublecounted in the non-EGU inventory. As a resul t of this comparison, MACTEC made a few**  **adjustments in the cross-reference table to add emi ssion units for four plants to ensure these units** 

**accounted for in IPM were moved to the EGU inventor y.** **5**

**MACTEC reviewed the non-EGU inventory to identify remaining emission units with a Standard**  **Industrial Classification (SIC) code of "4911 Elect rical Services" or Source Classification Code of "1**  **-01- xxx-xx External Combustion Boiler, Electric Generat**  **ion". MACTEC compared the list of sources meeting these selection criteria to the IPM parsed**  **file to ensure that these units were not double-cou nted.**  **MACTEC asked state and local agencies to review the 2009 point source inventory to verify whether**  **there was any double counting of EGU emissions.**

E. EGU Quality Assurance steps

**Quality assurance was an important component to th e inventory development process and**  **MACTEC performed the following QA steps on the EGU component of the VISTAS/ASIP revised 2009**  **EGU inventory:**

**1. Provided IPM parsed files (i.e., Excel spreads heets that provide unit-level results derived from**  **the model plant projections obtained by the IPM) to the VISTAS EGU SIWG for review and comment.** 

**2. Provided facility level emission summaries for 2009 to the VISTAS EGU SIWG to ensure that** 

**emissions were consistent and that there were no mi ssing sources.** 

**3. Compared State-level emissions from the IPM pa rsed files with the post-processed NIF files to**  **verify that the post-processed NIF files were consi stent with the IPM parsed file results.** 

**VISTAS/ASIP requested state and local contacts to review of these files. The SCDHEC**  **completed a detailed review of the inventory prepar ed by the VISTAS/ASIP contractor. The SCDHEC**  **submitted corrections to the 2002 and 2009 point so urce emissions inventories and the VISTAS/ASIP**  **contractor incorporated these changes into the fina l inventory.** 

IV. Quality Assurance of On-Road Mobile Source Emi ssions Inventory

**Quality Assurance is one of the most important ste ps in performing an air quality modeling study.**  **Because emissions inventory development is tedious, time consuming and involves complex**  **manipulation of many different types of large data sets, errors are frequently made and, if rigorous Q**  **A measures are not in place, these errors may remain**  **undetected. For the on-road mobile source category, QA can be broken into two components: (1) input fi**  **les/data, and (2) SMOKE outputs/summaries.**

**South Carolina On-road mobile input data, such as speeds and vehicle mix, came from the default**  **values built into MOBILE6 and used the same assumpt ions as the CERR. Since much of South**  **Carolina's On-road Mobile inputs were default, we p ut more emphasis on reviewing the resulting** 

**emissions for reasonableness.**

**Upon completion of the modeling, VISTAS supplied t he emissions output summary files to the**  **SCDHEC. The modeling was an iterative process. To ensure the latest information was incorporated into**  **the current modeling effort, the latest version of the county emissions were compared to previous draf**  **t versions of the county emissions.** **6** Appendix G.1. Quality Assurance Project Plan