Technical Support Document (TSD) For Liberty

- Clairton PM 2.5 Nonattainment Area: State Implementation Plan (SI P) Attainment Demonstration

and Base Year Inventory Submitted April 2011 by

the Pennsylvania Department of Environmental Protection TSD Prepared October 2011 by

Jessica Fry Office of Air Monitoring and Anal ys is, 3AP40 U.S. Environmental Protection Agency , Region 3

1650 Arch Street Philadelphia, Pennsylvania 19103

/s/

____________________________________________ Reviewed b y Andrew H ass , Acting Associate Director Office of Air Monitoring and Anal ys is (3AP40)

October 5, 2011

_____ __________ Date Signed**I. Introduction**  The purpose of this document is to provide a technical summary of the Office o f Air Monitoring and Analy sis (OAMA) review of the emissions inventories submitted with the L iberty

- Clairton PM 2.5 Nonattainment Area State Implementation Plan (SI P) by the Allegheny

County Health Department (ACHD). This review determines the approvability

of the SI P Base Y ear Inventory and an evaluation of the methods used. A SI P Base Year Inventory

is the starting point from which other SI P inventories are derived as well as serving as the benchmark for other SI P planning activities, such as the establishment of an emissi ons reduction credit program. On January 5, 2005 the L ibert y Clairton area, located in Alleghen y County and comprised of the boroughs of Glassport, Liberty , Lincoln, Port Vue, and the cit y of Clairton was designated as nonattainment for the PM2.5 NAAQS. An y questions pertaining to this technical summary should be directed to Andrew Hass , Acting Associate Director, Office of Air Monitoring and Analy sis, at 215

- 814

- 2 049 or via email at hass.andrew@epa.gov

.
**II. 2002**  **SIP Base Year Inventory** The SI P base y ear inventory is the primary

inventory

from which other inventories (3

- ye ar cy cle inventories, reasonable further progress inventories, modeling inventories) are derived. The Clean Air Act calls for State, local, an d Tribal agencies to ensure that the base ye ar inventory is comprehensive, accurate, and current for all actual emissions. 1 The base year inventory includes emissions estimates from stationary point and nonpoint sources, nonroad mobile sources, and onroad mobile sources. For the PM2.5 NAAQS, the pollutants to be inventoried are PM 10, PM2.5, VOC, NOx, SO2 and NH 3 . For the NAAQS, emissions should be reported as actual annual emissions. In the Li bert y - Clairton area SI P the base y ear used was 2002. ACHD provided a point source inventory developed by the Mid

- Atlantic/Northeast Visibility Union (MANE

- VU) that contained emissions for five facilities in the nonattainment area . These stationary point sources included two major sources, two “s ynthetic minor” s ources, and one minor source. ACHD made corrections to the point source inventory which involved the addition of condensable PM emissions for EGUs based on stack tests and revised emission factors. For the 2002 Nonpoint Source emissions, also known as “ area sources,” ACHD provided an inventory

developed by

MANE

- VU that contained estimations of emissions by multiplying an emission factor by some known indicator or activity level for each category at the count y level. These emissions are ty picall y calculated on an annual basis because the activit y data are generally onl y available on an annual basis. Nonpoint source estimates were provided by SCC and were apportioned to the Liberty

- Clairton area based on population counts. The Nonroad Mobile Source 2002 inventory was prepared with EPA’s NONROAD2005 model. NONROAD estimates fuel consumption and emissions of total

1 “ Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations ” EPA

- 454/R

- 05

- 001, August 2005, upd ated November 2005.hy drocarbons, carbon monoxide, nitrogen oxides, sulfur dioxide, and particulate matter

for all nonroad mobile source categories except for airc raft, locomotives, and commercial marine vessels **.** The National Mobile Inventory Model (NMIM) was used to estimate emissions of ammonia from sources contained in the NONROAD model. PADEP provided emission estimates for locomotive engines, aircraft emissi ons, and commercial marine vessels (CMV) emissions separately . The emissions submitted were developed by E.H. Pechan and Associates for MANE

- VU. All Nonroad mobile source emissions were provided b y SCC and classification and were apportioned to the Liber ty
- Clairton area based on population. The Onroad Mobile Source 2002 emissions inventory was developed using EPA’s highway mobile source emissions model MOBILE 6.2. The data was compiled by PA DEP for Southwestern PA, with a separate estimate done for the Libert y - Clairton area. PADEP also used PPSUITE, an enhanced version of the Post Processor for Air Quality software s ys tems used for previous inventory submissions in Pennsylvania. The Pennsylvania Department of Transportation (PennDOT) provided estimate s of vehicle miles traveled (VMT) b y vehicle t ype and roadway t ype. The mobile source VMT and emissions for the L ibert y - Clairton area were estimated using GI S and the PennDOT Roadway Management Sy stem (RMS). OAMA staff reviewed the files and the emission results provided by ACHD and found them to be approvable.