Technical Support Document (TSD) for the Redesignation Request and Maintenance Plan For the Reading, PA 1997 PM2

.sNonattainment Area

SubmittedNovember 2013 by the Pennsylvania Department ofEnvironmental Protection TSD Prepared April 2014 by Jessica L. Fry Office ofAir Monitoring and Analysis, 3AP40 U.S. Environmental ProtectionAgency, Region 3 1650 Arch Street Philadelphia, Pennsylvania 19103

Reviewed byAlice H. Chow, Associate Director Office ofAir Monitoring andAnalysis (3AP40)

# o¥/1~/wty 'Date'Signed

### I. Introduction The purpose ofthis document is to provide a technical summary ofthe Office ofAir Monitoring and Analysis (OAMA) review ofthe emissions inventories submitted withthe Redesignation Request and Maintenance Plan for the Reading, P A 1997 PM2.s Nonattainment Area (NAA) by Pennsylvania Department ofEnvironmental Protection (PADEP). The Reading NAA consists of Berks County, PA. This review does not determine the approvability ofthe redesignation request ormaintenance plan. Emissions inventories in a redesignation request are used to show permanent and enforceable emissionreductions betweenthe yearthe area was designated as a nonattainment area and the year the areacame into attainment. In a maintenance plan, the emissions inventories are used to reflect the emissions during the time the area came into attainment and are thenprojected to showthatthe area will remain in attainment. Any questions pertaining to this technical summary should be directed to Alice H. Chow, Associate Director, Office ofAir Monitoring and Analysis, at 215-814-2144 or via email at chow.alice@epa.gov. 

### II. Emissions Inventories for Redesignation Request 

### 2002 Nonattainment YearInventory In a redesignationrequest, emissions inventories are used to support the State's claimthat the areahas permanent and enforceable emissions reductions. Inorder to do this, the state should estimate the percentreduction (from the year that was used to determine the design value for designation and classification) achieved from federal and state control measures; this is usually termed as the nonattainment year inventory. Forthe purpose ofthis planthe year 2002 was used the nonattainment year inventory. The 2002 nonattainment year inventory contains primary PM2.s emissions (including condensibles), S02,NOx, VOC, andNH3 emissions. This sectionwill discuss the 2002 nonattainment year inventory that was used inthe Reading, P A Redesignation Request and Maintenance Plan submittedby PADEP. PADEP compiled emissions inventories for the nonattainment area which consists of Berks County. The 2002 point source inventory contained emissions for electric generating units (EGUs) and Non-EGU sources in Berks County

. PADEP developed their 2002 inventory by using emissions directly reported bythe facilities. The 2002 point source inventory does not include condensable PM emissions for many facilities. The nonpoint source emissions inventory for 2002 was developed using 2002 specific activity data along withEPA emission factors and the mostrecently available emission calculationmethodologies. For 2002 nonroad mobile sources, PADEP generated the emissions using EPA's NONROAD 2005 model. Since marine, air and rail/locomotive (MAR) emissions are notpart of the NONROAD model, they were calculated separately outside ofthe NONROAD model.The 2002 onroad mobile source inventory was developed using EPA's highway mobile source emissions model MOVES2010. PADEP used local activity to replace default inputs in the model where appropriate. OAMA staffreviewed the files and the emissionresults providedby PADEP and found them to be acceptable.



### III. Emissions Inventories for Maintenance Plan 

### 2007Attainment YearInventory andMaintenance Plan Base YearInventory Under section 172(c)(3) states are required to submit a comprehensive, accurate, current accounting ofactual emissions from all sources (point, nonpoint, nonroad, and onroad) inthe nonattainment area. This inventory contains primary PM2.s emissions (including condensables), S02, NOx, VOC, and NHJ

. In a Maintenance Plan, states are required to submit an inventory used for the year ofattainment, which is called the attainment year inventory and can also be referred to as the maintenance planbase year inventory. This inventory is used as the basis for the projected inventories that are used to show the area will remain in attainment. The base year inventory submitted by PADEP contains primary PM2.s emissions (including condensables), S02, NOx, VOC, and NH3 emissions. This sectionwill discuss the 2007 emissions inventory that was used inthe Reading Redesignation Request and Maintenance Planin orderto fulfill the 1 72(c)(3) and attainment year emissions inventory requirements. The 2007 point source inventory contained emissions for EGU and Non-EGU sources in Berks County. EPA guidance for emissions inventory development provides that actual emissions should be used for purposes ofthe base year inventory. PADEP developed their 2007 inventory by using emissions directly reported by the facilities. The EGU inventory was augmented and missing condensable PM emissions were supplemented using emission factors developed for MARAMA in 2008. The nonpoint source emissions inventory for 2007 was developed using 2007 specific activity data along with EPA emission factors and the most recently available emission calculation methodologies. PADEP used 2008 NEI datato fill in any missing categories in the 2007 inventory. For 2007 nonroad mobile sources, PADEP generated the emissions using EPA's NMIM2008 model. Since marine, air andrail/locomotive (MAR) emissions are notpart ofthe NONROAD model, they were calculated separately outside ofthe NONROAD model. The 2007 onroad mobile source inventory was developed using EPA's highway mobile source emissions model MOVES2010. PADEP used local activity to replace default inputs in the model where appropriate. OAMA staffreviewed the files and the emissionresults provided by PADEP and found them to be acceptable.

### 2017and2025Projection Emission Inventories Projection inventories are used to showthat the area will remain in attainment. PADEP used 2017 and 2025 emission projections for the interim and maintenance plan end year, respectively. For EGU emissions, PADEP used growth factors based on the Annual Energy Outlook (AE02011) and applied them to the 2007 inventory. For non-EGU emissions projections were based onVersion 3.3 ofthe 2007 MANE-VU+VA inventory. MARAMA growth factors were developed using AEO fuel consumption forecasts, state-level employment projections, and other state-specific emission projection data. Nonpoint source emissions for 2017 and 2025 were developed similarly to the non-EGU point sources. Emission projections were based on Version 3.3 ofthe 2007 MANE-VU+VA inventory. MARAMA growth factors were developed using AEO fuel consumption forecasts, state-level employment projections, and other state-specific emissionprojection data. Nonroad source emissions for 2017 and 2025 were developed using NMIM model runs which contain default assumptions for projected years. Aircraft emissions were projectedby applying activity growth datareported inthe Federal AviationAdministration's (FAA's) Terminal AreaForecast (TAF) system for 2009-2030 (FAA2010). Railroad emissions were based onthe MARAMA MANE-VU+Va inventory. The 2017 and 2025 onroad mobile source inventory was developed using EPA's highway mobile source emissions model MOVES2010. PADEP used local activity to replace default inputs inthe model where appropriate OAMA staffreviewed the methodologies provided by PADEP and found themto be acceptable.