Technical Support Document (TSD) for the 

Redesignation Request and Maintenance Plan 

For the Reading, PA 1997 PM2.s Nonattainment Area 

Submitted November 2013 by the Pennsylvania 

Department of Environmental Protection 

TSD Prepared April 20 14 by 

Jessica L. Fry 

Office of Air Monitoring and Analysis, 3AP40 

U.S. Environmental Protection Agency, Region 3 

1650 Arch Street 

Philadelphia, Pennsylvania 19103 

Reviewed by Alice H. Chow, Associate Director 

Office of Air Monitoring and Analysis (3AP40) 

o¥/1~/wty 'Date 'Signed 
I. Introduction 

The purpose of this document is to provide a technical summary of the Office of Air Monitoring 

and Analysis (OAMA) review of the emissions inventories submitted with the Redesignation 

Request and Maintenance Plan for the Reading, P A 1997 PM2.s Nonattainment Area (NAA) by 

Pennsylvania Department of Environmental Protection (PADEP). The Reading NAA consists of 

Berks County, PA. This review does not determine the approvability of the redesignation request 

or maintenance plan. Emissions inventories in a redesignation request are used to show 

permanent and enforceable emission reductions between the year the area was designated as a 

nonattainment area and the year the area came 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 then projected to show that the area will remain in attainment. Any questions 

pertaining to this technical summary should be directed to Alice H. Chow, Associate Director, 

Office of Air Monitoring and Analysis, at 215-814-2144 or via email at chow.alice@epa.gov. 

II. Emissions Inventories for Redesignation Request 

2002 Nonattainment Year Inventory 

In a redesignation request, emissions inventories are used to support the State's claim that 

the area has permanent and enforceable emissions reductions. In order to do this, the state 

should estimate the percent reduction (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. For the purpose of this plan the year 2002 

was used the nonattainment year inventory. The 2002 nonattainment year inventory contains 

primary PM2.s emissions (including condensibles), S02, NOx, VOC, and NH3 emissions. This 

section will discuss the 2002 nonattainment year inventory that was used in the Reading, P A 

Redesignation Request and Maintenance Plan submitted by P ADEP. 

P ADEP 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 by the 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 with EPA emission factors and the most recently available emission 

calculation methodologies. 

For 2002 nonroad mobile sources, PADEP generated the emissions using EPA's 

NONROAD 2005 model. Since marine, air and rail/locomotive (MAR) emissions are not part of 

the NONROAD model, they were calculated separately outside of the 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 staff reviewed the files and the emission results provided by PADEP and found 

them to be acceptable. 

III. Emissions Inventories for Maintenance Plan 

2007 Attainment Year Inventory and Maintenance Plan Base Year Inventory 

Under section 172(c)(3) states are required to submit a comprehensive, accurate, current 

accounting of actual emissions from all sources (point, nonpoint, nonroad, and onroad) in the 

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 of attainment, which is called the attainment year inventory and can also be referred 

to as the maintenance plan base 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 P ADEP contains primary PM2.s emissions (including condensables ), S02, 

NOx, VOC, and NH3 emissions. This section will discuss the 2007 emissions inventory that was 

used in the Reading Redesignation Request and Maintenance Plan in order to 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 of the 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. P ADEP used 2008 NEI data to 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 and rail/locomotive (MAR) emissions are not part ofthe 

NONROAD model, they were calculated separately outside of the 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 staff reviewed the files and the emission results provided by PADEP and found 

them to be acceptable. 
2017 and 2025 Projection Emission Inventories 

Projection inventories are used to show that the area will remain in attainment. P ADEP 

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 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 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 of the 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. 

Nonroad source emissions for 2017 and 2025 were developed using NMIM model runs 

which contain default assumptions for projected years. Aircraft emissions were projected by 

applying activity growth data reported in the Federal Aviation Administration's (FAA's) 

Terminal Area Forecast (TAF) system for 2009-2030 (F AA201 0). Railroad emissions were 

based on the 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 in the model where appropriate 

OAMA staff reviewed the methodologies provided by PADEP and found them to be 

acceptable.