PM2.5 SIP

Appendix F

Inventory Revisions

F-1: Liberty-Clairton Emission Inventories and 

Source Assessment Analysis

F-2: Local Inventory Revisions 2007/2014

F-3: Regional 2014 Interpolations/Projections
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F-1: Liberty-Clairton Emission Inventories and Source 

Assessment Analysis
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2007 AND 2014 LIBERTY-CLAIRTON PM2.5 NONATTAINMENT AREA EMISSION INVENTORIES AND 

SOURCE ASSESSMENT ANALYSIS 

COUNTY OF ALLEGHENY CONTRACT NUMBER 130103 

CONSULTANT TECHNICAL SUPPORT FOR AIR POLLUTANT AREA AND MOBILE SOURCES 

ANALYSIS 

Prepared for: 

Allegheny County Health Department 

301 39th Street 

Pittsburgh, PA 15201-1891 

Prepared by: 

TranSystems|E.H. Pechan & Associates 

5528-B Hempstead Way 

Springfield, VA 22151 

and 

Thompson G. Pace, Consultant 

Raleigh, NC 

and 

Michael Baker Jr. Inc. 

1304 Concourse Drive, Suite 200 

Linthicum, MD 21090-1014 

January 17, 2012 

 

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CONTENTS 

Page

ACRONYMS AND ABBREVIATIONS .......................................................................................................................... vii

ACKNOWLEDGEMENTS ............................................................................................................................................. ix

CHAPTER I. INTRODUCTION ..................................................................................................................................... 1

 A. REPORT ORGANIZATION ............................................................................................................... 1

CHAPTER II. AREA SOURCES ................................................................................................................................... 3

 A. 2007 MID-ATLANTIC NORTHEAST VISIBILITY UNION (MANE-VU) EMISSIONS INVENTORY 

SUMMARY ........................................................................................................................................ 3

 B. IDENTIFICATION OF PRIORITY SOURCE CATEGORIES ............................................................. 3

 C. EMISSIONS INVENTORY REFINEMENTS ...................................................................................... 3

 1. Residential Wood Combustion ............................................................................................ 3

 2. Construction Dust ................................................................................................................ 6

 3. Industrial and Commercial/Institutional (ICI) Fuel Combustion ........................................... 7

 4. Commercial Cooking ........................................................................................................... 9

 5. Open Burning ...................................................................................................................... 9

 6. Natural Gas Exploration .................................................................................................... 10

 7. All Other Area Sources ..................................................................................................... 12

 D. 2007 AND 2014 LIBERTY-CLAIRTON EMISSIONS INVENTORY SUMMARY .............................. 12

CHAPTER III. OFF-ROAD SOURCES ....................................................................................................................... 15

 A. 2007 MANE-VU EMISSIONS INVENTORY SUMMARY ................................................................. 15

 B. IDENTIFICATION OF PRIORITY SOURCE CATEGORIES ........................................................... 15

 C. EMISSIONS INVENTORY REFINEMENTS .................................................................................... 15

 1. Locomotives ...................................................................................................................... 16

 2. Commercial Marine Vessels .............................................................................................. 17

 3. Diesel Construction (NMIM) .............................................................................................. 19

 D. 2007 AND 2014 LIBERTY-CLAIRTON EMISSIONS INVENTORY SUMMARY .............................. 20

CHAPTER IV. ON-ROAD SOURCES ......................................................................................................................... 21

 A. ANALYSIS METHODOLOGY .......................................................................................................... 21

 B. ANALYSIS TOOLS .......................................................................................................................... 22

 C. DATA SOURCES ............................................................................................................................ 23

 1. Base Traffic Data/Fleet Data Inputs .................................................................................. 24

 2. I/M and Fuel Parameters ................................................................................................... 26

 3. Meteorology Data .............................................................................................................. 26

 4. Vehicle Technology/Programs .......................................................................................... 27

 5. Traffic Growth Assumptions .............................................................................................. 27

 6. Vehicle Population Growth Assumption ............................................................................ 28
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 7. Final Results ..................................................................................................................... 29

CHAPTER V. SOURCE IMPACT ANALYSIS FOR THE LIBERTY MONITOR ........................................................... 31

 A. EXISTING DATA AND ANALYSES ................................................................................................. 31

 B. LIMITATIONS OF EXISTING DATA AND ANALYSES ................................................................... 33

 C. MICROINVENTORY OF LOCAL SOURCES IN LIBERTY BOROUGH AND INVESTIGATION 

OF OPERATIONAL IRREGULARITIES, TRENDS, DAILY AND DIURNAL EMISSIONS 

VARIABILITY ................................................................................................................................... 37

 D. SOURCE IDENTIFICATION, LOCATION, AND EMISSIONS TABULATION ................................. 40

 E. CONCENTRATION SPIKES POTENTIALLY INDICATING UPSETS AND EQUIPMENT 

MALFUNCTION ............................................................................................................................... 44

 1. Upsets and Malfunctions ................................................................................................... 44

 2. Operating Patterns ............................................................................................................ 45

 F. DATA SYNTHESIS .......................................................................................................................... 45

 1. Potassium - Residential Wood Combustion, Cooking, and Open Biomass Burning ......... 46

 2. Crustal Materials and Fugitive Dust .................................................................................. 47

 3. Elemental and Organic Carbon ......................................................................................... 47

 4. Ammonium Sulfate, Nitrate, and Secondary Organic PM2.5 .............................................. 48

 5. Chlorine ............................................................................................................................. 50

 6. Overall Source Contributions ............................................................................................ 51

CHAPTER VI. REFERENCES .................................................................................................................................... 53

TABLES AND FIGURES 

Page

Table II-1. 2007 Allegheny County Area Source Emissions (tons per year) ................................................................. 3

Table II-2. RWC Source Categories ............................................................................................................................... 4

Table II-3. Comparison of EPA RWC Tool Appliance Profiles and NAA Appliance Profiles ......................................... 5

Table II-4. Residential Wood Combustion Growth Rates .............................................................................................. 6

Table II-5. Area Source Categories for which Point Source Subtractions Were Performed .......................................... 8

Table II-6. Area Source Categories for which Point Source Subtractions Were Not Performed ................................... 8

Table II-7. Emission Factor Source by Emissions Process and Pollutant ................................................................... 12

Table II-8. 2007 Area Source Emission Estimates (tons/year) .................................................................................... 12

Table II-9. 2014 Area Source Emission Estimates (tons/year) .................................................................................... 13

Table III-1. 2007 Off-Road Emissions for Allegheny County (tons per year) ............................................................... 15

Table III-2. Tug and Loaded Barge Trips and Tons of Coal for Locks 2 and 3 of the Monongahela River .................. 17

Table III-3. 2007 Commercial Marine Vessel Emission Factors (lbs/gallons fuel) ....................................................... 18

Table III-4. County to NAA Allocation for Construction Equipment ............................................................................. 19

Table III-5. Modeled Diesel Sulfur Levels for NONROAD (ppm) ................................................................................. 20

Table III-6. 2007 Off-Road Emissions for Liberty-Clairton Area (tons/year) ................................................................ 20

Table III-7. 2014 Off-Road Emissions for Liberty-Clairton Area (tons/year) ................................................................ 20

Table IV-1. Summary of Analysis Tools ...................................................................................................................... 22

Table IV-2. Summary of Data Parameters for Liberty-Clairton ..................................................................................... 24

Table IV-3. Base and Forecasted Vehicle Miles of Travel (Millions) ............................................................................ 28

Table IV-4. Vehicle Population Estimated Classified by MOVES Source Type ........................................................... 28
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Table IV-5. Liberty-Clairton PM 2.5 NAA – On-Road Emissions Summary by Road Type (tons/year) .......................... 29

Table IV-6. Liberty-Clairton PM2.5 NAA On-Road Emissions Summary by Fuel Type (tons/year) .............................. 29

Table V-1. Measured Composition of 20 Highest PM2.5 Days at Liberty Monitor ........................................................ 31

Table V-2. Comparison of Species Concentrations on Average and High Mass Concentration Days (μg/m3) ........... 33

Table V-3. PMF Results for Highest 20 Days Measured at Liberty Site, Liberty - Clairton NAA ................................. 35

Table V-4. Comparison of Species Concentrations at Hillman, Liberty and Lawrenceville Sites (μg/m3) ................... 36

Table V-5. Point Source Facilities Believed to Contribute to Liberty-Clairton PM2.5 Nonattainment(a) ......................... 41

Table V-6. 2007 Emissions Summary for Liberty-Clairton PM2.5 NAA.......................................................................... 42

Table V-7. 2007 Emissions Summary for Sources in Allegheny County, PA - Outside the Liberty-Clairton PM2.5

NAA .............................................................................................................................................................................. 43

Table V-8. Measured Species at Liberty Site for High and Low Days ......................................................................... 44

Table V-9. Monthly Variability in Measured K and PMF Factors 2 and 9 .................................................................... 46

Table V-10. PMF Results at Liberty Site for All Days with Measured Speciation Data (2005 - 2010) ......................... 48

Figure IV-1. PPSUITE Process ................................................................................................................................... 23

Figure V-1. Enrichment of Species Measured at Liberty Site Compared to Lawrenceville Site (μg/m3) ..................... 32

Figure V-2. Excess PM2.5 (Liberty - Lawrenceville) Using PMF Analysis (μg/m3) ....................................................... 32

Figure V-3. Location of Monitors in Areas Upwind of Liberty (SAHS) Air Monitoring Site ........................................... 36

Figure V-4. Liberty-Clairton Tour Routing for October 5 and 6, 2011 ......................................................................... 39

Figure V-5. Sulfate, Nitrate and Ammonium at Liberty Monitoring Station .................................................................. 49

Figure V-6. Comparison of Measured Chlorine at Liberty and Lawrenceville, by Month ............................................. 50

 
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ACRONYMS AND ABBREVIATIONS 

μg/m3 microgram per cubic meter 

ACHD Allegheny County Health Department 

ACS American Community Survey 

AHS American Housing Survey 

BPR Bureau of Public Roads 

Btus British thermal units 

CA LEVII California Low Emission Vehicle Program 

CPF Conditional Probability Function 

EC elemental carbon 

EGU electricity-generating unit 

EPA U.S. Environmental Protection Agency 

ERTAC Eastern Regional Technical Advisory Committee 

FHWA Federal Highway Administration 

FRA Federal Railroad Association 

FRM Federal Reference Method 

GIS Geographic Information System 

GTM gross ton-mile 

GVWR gross vehicle weight rating 

HPMS Highway Performance Monitoring System 

I/M inspection/maintenance 

ICI industrial, commercial, and institutional 

K potassium 

LPG liquefied petroleum gas 

MANE-VU Mid-Atlantic Northeast Visibility Union 

MOVES MOtor Vehicle Emissions Simulator 

MPOs metropolitan planning organizations 

MSA metropolitan statistical area 

NAA nonattainment area 

NAAQS National Ambient Air Quality Standards 

NEI National Emissions Inventory 

NH3 ammonia 

NH4 ammonium 

NLEV National Low Emission Vehicle Program 

NMIM National Mobile Inventory Model 

NO3 Nitrate 

NOx oxides of nitrogen 

NS Norfolk Southern 

NTD National Transit Database 

OBD on-board diagnostics 

OC organic carbon 

ORV Ohio River Valley 

PA DEP Pennsylvania Department of Environmental Protection 

PCV Pennsylvania Clean Vehicles 

PennDOT Pennsylvania Department of Transportation 

PM10 particulate matter with an aerodynamic diameter of 10 microns or less 

PM2.5 particulate matter with an aerodynamic diameter of 2.5 microns or less 

PMF Positive Matrix Factorization 

ppm parts per million 
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RMS Roadway Management System 

RVP Reid vapor pressure 

RWC residential wood combustion 

SAHS Southwest Allegheny High School 

SCCs Source Classification Codes 

SIP State Implementation Plan 

SO2 sulfur dioxide 

SO4 sulfate 

TS|Pechan TranSystems|E.H. Pechan 

URR Union Railroad Company 

US ACE U.S. Army Corps of Engineers 

VMT vehicle miles traveled 

VOC volatile organic compounds 

 
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ACKNOWLEDGEMENTS 

This acknowledges the valuable assistance provided by Allegheny County Health Department (ACHD) staff with 

surveying the key sources in the Liberty-Clairton PM2.5 nonattainment area and gathering data used to develop 

improved emission estimates. Tony Sadar was the ACHD project manager for this effort. Jason Maranche provided 

the positive matrix factorization analyses used in the source impact analysis. Tony Sadar, Jason Maranche, and 

Shaun Vozar led the site visits to the nonattainment area. Jayme Graham provided overall direction to the project 

team. 

 
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CHAPTER I. INTRODUCTION 

The Liberty-Clairton nonattainment area (NAA), consisting of Glassport, Liberty, Lincoln, and Port Vue boroughs and 

the City of Clairton, is located about 10 miles southeast of the City of Pittsburgh. The area is made up of complex 

river valley terrain, approximately three miles wide by five miles long. It includes a 4 mile winding portion of the 

Monongahela River and is bordered by the Youghiogheny River to the east. The area includes rural land, densely 

populated residential areas, and industrial facilities. About 21 thousand people live in the NAA, which is one percent 

of the metropolitan statistical area (MSA) population. The Pittsburgh MSA consists of seven counties: Allegheny, 

Armstrong, Beaver, Butler, Fayette, Washington, and Westmoreland. 

The Liberty-Clairton particulate matter with an aerodynamic diameter of 2.5 microns or less (PM2.5) NAA was 

designated a separate NAA from the surrounding Pittsburgh-Beaver Valley NAA because, in addition to the regional 

air quality problem, there is a localized air quality issue in the local sources and the specific geologic and 

meteorological features of the area. Large industry is located along the river sides in the valley. The sharp differences 

in elevation between the industrial and residential areas and the high hillsides surrounding them create a significant 

river basin, and spikes in localized PM2.5 concentrations coincide with temperature inversions. 

The Liberty-Clairton area has many inversions each year, with the least favorable dispersion conditions occurring 

from July through November. These inversions usually break up just before noon, and on average may set up as 

early as sunset of the previous day (Sadar, 2011a; 2011b). Air quality is often much poorer during the months with 

the most inversions. The 2010 PM2.5 State Implementation Plan (SIP) contains an analysis of 2002 continuous PM2.5

data and inversion characterization. It shows a dramatic increase in PM2.5 concentrations when inversions are 

present (ACHD, 2011a). 

A. REPORT ORGANIZATION 

This report documents the 2007 and 2014 PM2.5 and PM2.5 precursor emission inventories that were developed by 

TranSystems Corporation|E.H. Pechan & Associates (TS|Pechan) and Michael Baker Jr. Inc. for the Liberty-Clairton 

PM2.5 NAA. This report is organized in four major sections, or chapters (besides this Introduction). This analysis 

focuses on mobile and area source emissions in this NAA. Point source emissions are estimated each year by the 

Allegheny County Health Department (ACHD) staff, so point source emissions were not part of this contract effort. 

Chapter II. Area Sources 

Chapter III. Off-road Sources 

Chapter IV. On-road Sources 

Chapter V. Source Impact Analysis for Liberty Monitor 

 
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CHAPTER II. AREA SOURCES 

A. 2007 MID-ATLANTIC NORTHEAST VISIBILITY UNION (MANE-VU) EMISSIONS 

INVENTORY SUMMARY 

Table II-1 presents a summary of the source categories that the 2007 MANE-VU inventory indicates as the major 

contributors to PM2.5, sulfur dioxide (SO2), and ammonia (NH3) emissions in Allegheny County (MARAMA, 2011). In 

each case, two source categories are responsible for a majority of total area source emissions. In the case of PM2.5-

PRI emissions, the Residential Wood and Fugitive Dust categories account for 80 percent of total area source 

emissions. The Industrial and Commercial Coal Combustion categories are estimated to contribute 87 percent of 

total SO2 emissions. Fertilizer Application and Residential Wood Combustion (RWC) are responsible for 71 percent 

of NH3 emissions in Allegheny County. 

Table II-1. 2007 Allegheny County Area Source Emissions (tons per year) 

Source Category PM2.5-PRI SO2 NH3

Residential Wood Combustion (Stoves, Fireplaces, Furnaces) 1,533.0 32.8 89.9 

Fugitive Dust (Construction, Paved/Unpaved Roads) 1,291.0 0.0 0.0 

Commercial Cooking 289.0 0.0 0.0 

Residential Heating - Gas, Oil and Coal 169.0 17.1 12.3 

Industrial Coal Combustion 117.4 7,499.3 2.4 

Commercial/Institutional Coal Combustion 58.0 3,702.4 1.2 

Fertilizer Application 0.0 0.0 134.2 

Open Burning 0.0 0.0 0.0 

All Other Area Source Categories 73.8 1,669.6 75.1 

TOTAL 3,531.0 12,921.2 315.1 

B. IDENTIFICATION OF PRIORITY SOURCE CATEGORIES 

Based on the information supplied in Table II-1, additional information gathered from visits to the NAA, and the 

feasibility of implementing improved methods, TS|Pechan prioritized the following source categories for emissions 

estimation refinements: Residential Wood Combustion; Construction Dust; Industrial Coal Combustion; 

Commercial/Institutional Coal Combustion; Commercial Cooking; and Open Burning. For each of these source 

categories, the sections that follow describe our understanding of how the current Allegheny County 2007 MANE-VU 

emission estimates were developed, our approach to developing refined NAA-level emission estimates for 2007; and 

our methods for estimating 2014 NAA emissions. In addition, ACHD directed TS|Pechan to develop 2014 emission 

projections for natural gas exploration, reflecting assumed development of Marcellus Shale gas reserves. 

C. EMISSIONS INVENTORY REFINEMENTS 

1. Residential Wood Combustion 

a. Background 

Allegheny County RWC emissions are categorized in the nine Source Classification Codes (SCCs) displayed in 

Table II-2. The bulk of the PM2.5 emissions from these sources are from three SCCs: 

 SCC 2104008100 – Fireplace: general; 
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 SCC 2104008210 – Woodstoves: fireplace inserts, non-U.S. Environmental Protection Agency (EPA) 

certified; and 

 SCC 2104008310 – Woodstoves: freestanding, non-EPA certified. 

The base year emissions from this category were developed by PADEP from a 2007 run of EPA’s RWC emissions 

estimation tool (EPA, 2008a). 

Table II-2. RWC Source Categories 

SCC Description1 Description2 Description3 Description4 

2104008100 Stationary Source Fuel Combustion Residential Wood Fireplace: general 

2104008210 Stationary Source Fuel Combustion Residential Wood Woodstove: fireplace inserts; non-EPA 

certified 

2104008220 Stationary Source Fuel Combustion Residential Wood Woodstove: fireplace inserts; EPA certified; 

non-catalytic 

2104008230 Stationary Source Fuel Combustion Residential Wood Woodstove: fireplace inserts; EPA certified; 

catalytic 

2104008310 Stationary Source Fuel Combustion Residential Wood Woodstove: freestanding, non-EPA 

certified 

2104008320 Stationary Source Fuel Combustion Residential Wood Woodstove: freestanding, EPA certified, 

non-catalytic 

2104008330 Stationary Source Fuel Combustion Residential Wood Woodstove: freestanding, EPA certified, 

catalytic 

2104008400 Stationary Source Fuel Combustion Residential Wood Woodstove: pellet-fired, general 

(freestanding or fireplace insert) 

2104008510 Stationary Source Fuel Combustion Residential Wood Furnace: Indoor, cordwood-fired, non-EPA 

certified 

2104008610 Stationary Source Fuel Combustion Residential Wood Hydronic heater: outdoor 

b. Base Year Estimation Method 

To estimate emissions for the Liberty-Clairton NAA, TS|Pechan performed a new 2007 run of the RWC tool with the 

following tool input refinements: 

(1) Replaced Allegheny County occupied housing units data with the number of occupied housing units in the 

NAA – the tool estimates the number of wood-burning appliances by multiplying appliance profiles 

(representing the percentage of wood-burning appliances per occupied housing unit, e.g., 10.7 percent of 

occupied housing units are assumed to have a wood-burning fireplace) by the number of occupied housing 

units; 

(2) Replaced the current appliance profiles that are based on 2004 American Housing Survey (AHS) data for 

the Pittsburgh MSA with sub-MSA profiles developed from 2004 AHS data specifically representing the nonPittsburgh portion of Allegheny County (Census, 2005); 

(3) Adjusted the current appliance profiles to remove the estimated proportion of appliances that are burning 

fuels other than wood (e.g., natural gas); and 

(4) Updated the tool’s estimates of the Allegheny County number of pellet stoves, indoor furnaces, and outdoor 

hydronic heaters (otherwise known as outdoor wood boilers) based on revisions to the data that are used to 

spatially allocate the estimated regional/state population of each appliance type. 

For item (1), we incorporated the Bureau of the Census’ American Community Survey (ACS) estimates of average 

occupied housing units over the 2005-2009 time-frame for the NAA (i.e., summed the number of units reported for 

Clairton City and each of the four boroughs of interest [Glassport, Liberty, Lincoln, and Port Vue]) (Census, 2011). 
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The RWC tool reports 544,711 occupied housing units in Allegheny County; the ACS reports 9,604 occupied units for 

the NAA. 

For item (2), we updated the wood appliance profiles with data that are more geographically specific to the NAA. In 

particular, the AHS provides separate data for the non-Pittsburgh portion of Allegheny County that can be used to 

calculate appliance profiles. Table II-3 presents a comparison of the appliance profiles in the EPA’s RWC tool and 

the updated appliance profiles. In addition to the above, the updated appliance profiles incorporate an additional tool 

refinement noted as item (3) above. Whereas the EPA tool assumes that all fireplaces and stoves burn wood, we 

used the ACS reported count of housing units that burn wood for main heating and the count that burn wood for other 

heating to estimate the proportion of total fireplaces and stoves that burn wood. These adjustments are incorporated 

in the updated appliance profiles presented in the last column of Table II-3. 

Table II-3. Comparison of EPA RWC Tool Appliance Profiles and NAA Appliance Profiles 

SCC SCC Description Burn Type 

% of Occupied Housing 

Units with Appliance 

EPA Updated 

2104008100 Fireplace: general 

Main Heating 0 0 

Secondary Heating 2.48 1.14 

Pleasure 4.10 10.57 

2104009000 Residential Firelog Total: All Combustor Types 

Main Heating 0 0 

Secondary Heating 0.39 0.18 

Pleasure 0.64 1.65 

2104008210 Woodstove: fireplace inserts; non-EPA certified 

Main Heating 0.02 0 

Secondary Heating 2.50 1.35 

Pleasure 0 0 

2104008220 Woodstove: fireplace inserts; EPA certified; noncatalytic 

Main Heating 0.01 0 

Secondary Heating 1.01 0.55 

Pleasure 0 0 

2104008230 Woodstove: fireplace inserts; EPA certified; 

catalytic 

Main Heating 0.002 0 

Secondary Heating 0.34 0.18 

Pleasure 0 0 

2104008310 Woodstove: freestanding, non-EPA certified 

Main Heating 0.12 0 

Secondary Heating 2.64 1.28 

Pleasure 0 0 

2104008320 Woodstove: freestanding, EPA certified, noncatalytic 

Main Heating 0.05 0 

Secondary Heating 1.07 0.52 

Pleasure 0 0 

2104008330 Woodstove: freestanding, EPA certified, catalytic 

Main Heating 0.02 0 

Secondary Heating 0.36 0.17 

Pleasure 0 0 

For item (4), the EPA’s RWC tool estimates the number of the three other types of wood burning appliances in each 

county by allocating regional or state total estimates of pellet stoves, indoor furnaces, and outdoor wood boilers. For 

indoor furnaces and outdoor wood boilers, the tool performs the allocation based on the ratio of the estimated county 

number of woodstoves that are used for main heating as estimated by the tool to the estimated state number of these 

units estimated by the tool. As noted by main heating woodstove entries in Table II-3, applying the proposed 

updated appliance profiles will yield an estimate of zero woodstoves used for main heating in the NAA. Based on 

personal observations, TS|Pechan identified more than one outdoor wood boiler in the NAA. Therefore, we 

estimated the number of wood boilers in the NAA by multiplying the state wood boiler estimate by the proportion of 

the NAA number of total woodstoves as estimated by the updated tool to the state number of these units estimated 
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by the updated tool. For consistency, we used the same procedure to allocate the state number of indoor furnaces to 

the NAA. 

The procedure to estimate the number of pellet stoves is similar to that used for outdoor wood boilers and indoor 

furnaces. Because separate burn rates are incorporated into the tool for pellet stoves used for main heating, pellet 

stoves used for secondary heating, and pellet stoves used for pleasure burning, the spatial allocation procedure was 

performed using the estimated state and NAA counts of each of these three pellet stove uses. 

TS|Pechan evaluated information provided by ACHD on the impact of the Southwest Pennsylvania Great American 

Woodstove Change-out Program (ACHD, 2011b). This information indicates that the program’s impact was less than 

expected. We calculated an estimate that less than 0.3 percent of the total cords of wood burned in Allegheny 

County was burned in the lower-emitting woodstoves attributed to the change-out program, and that only 15 annual 

cords of wood are burned in lower-emitting replaced woodstoves in the NAA. Given these small impacts, we did not 

adjust the RWC tool to try account for the effect of the wood stove change-out program. 

c. 2014 Estimation Method 

To estimate the change in emissions activity for this category, we applied residential wood combustion growth rate 

assumptions developed by EPA (EPA, 2008b). The growth rates displayed in Table II-4 represent the EPA’s 

estimates for the combined effect of activity growth and Federal New Source Performance Standards for wood 

heating units. 

Table II-4. Residential Wood Combustion Growth Rates 

SCC Description Growth Rate Assumption* 

2104008100 Fireplace: General +1%/year 

2104008210 Woodstove: Fireplace Inserts; Non-EPA Certified -2%/year 

2104008220 Woodstove: Fireplace Inserts; EPA Certified; Non-catalytic +2%/year 

2104008230 Woodstove: Fireplace Inserts; EPA Certified; Catalytic +2%/year 

2104008310 Woodstove: Freestanding, Non-EPA Certified -2%/year 

2104008320 Woodstove: Freestanding, EPA Certified, Non-Catalytic +2%/year 

2104008330 Woodstove: Freestanding, EPA Certified, Catalytic +2%/year 

2104008400 Woodstove: Pellet-fired, General (freestanding or fireplace insert) +2%/year 

2104008510 Furnace: Indoor, Cordwood-fired, Non-EPA Certified -2%/year 

2104008610 Hydronic Heater: Outdoor +1%/year 

* Represents estimated combined effect of activity growth and emissions control (where applicable). 

2. Construction Dust 

a. Background 

The 2007 MANE-VU inventory indicates that the Fugitive Dust category is the second largest contributor to total 

Allegheny County area source PM2.5 emissions. This category includes dust from multiple activities including travel 

on paved roads and unpaved roads, construction activity, and agricultural tilling. Approximately 77 percent of total 

Allegheny County Fugitive Dust PM2.5 emissions are attributed to Construction, with Nonresidential Construction 

accounting for the majority of these emissions. The Construction Fugitive Dust emissions in the 2007 MANE-VU 

inventory were taken from the 2008 National Emissions Inventory (NEI) Version 1. The main emissions activity data 

input used to calculate 2008 NEI estimates is the number of acres of land disturbed. This source category is further 

disaggregated into three SCCs: 
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 SCC 2311010000 – Residential Construction; 

 SCC 2311020000 – Nonresidential Construction; and 

 SCC 2311030000 – Road Construction. 

The NEI estimates the number of acres of nonresidential construction in each county by allocating national annual 

dollar value of nonresidential construction data, after converting to acres of construction using an assumed 1.301 

acres per million dollars conversion factor, to counties based on non-residential construction (NAICS Code 2362) 

employment from the Bureau of the Census’ County Business Patterns. Similar approaches are used to estimate 

construction acreage for the other two categories. 

b. Base Year Estimation Method 

Our approach to estimating Construction Fugitive Dust emissions for the NAA was to replace the NEI’s estimated 

construction acreage values for Allegheny County with NAA-specific acreage estimates. The Southwestern 

Pennsylvania Commission provided TS|Pechan with land cover acreage data by land use type for years 2000/2001 

and 2006 (SPC, 2011a). TS|Pechan computed the average annual increase in urban built-up land cover from these 

data for the land use types associated with each Construction Dust SCC. The information below displays the 

following for each SCC: land use cover types that were assumed to match each SCC, Allegheny County’s acreage 

estimates from the NEI; the NAA acreage estimates derived by allocating Allegheny County’s NEI acreage estimates 

based on the ratio of NAA to County population; and acreage estimates derived from the annual average change in 

urban land cover from the available 2000/2001-2006 period. 

SCC Assumed Land Use Cover Type(s) 

Estimated Construction Acreage 

MANE-VU Inventory Estimates Derived 

from Annual Change 

in Land Cover 

Allegheny 

County 

Allocated 

to NAA* 

Residential Residential 301.5 4.9 1.8 

Non Residential Commercial and Services plus Industrial 3,482.8 57.1 0.7 

Road Construction Transportation Communication and Utilities 382.4 5.4 0.1 

*Based on ratio of NAA population to Allegheny County Population. 

c. 2014 Estimation Method 

To estimate the change in emissions activity for this category, we multiplied the acreage estimates noted above by a 

factor of 1.007. This factor represents the ratio of the projected population growth rate between 2013 and 2014 

(1.000) and the population growth rate between 2006 and 2007 (0.993). We used the most recent set of population 

projections for each NAA municipality as obtained from the Southwest Pennsylvania Commission (SPC, 2011b). We 

are not aware of any control programs that would affect 2014 emissions for this source category. 

3. Industrial and Commercial/Institutional (ICI) Fuel Combustion 

a. Background 

We understand that the Pennsylvania Department of Environmental Protection (PA DEP) did not perform point 

source subtractions as part of developing area source emission estimates for Allegheny County. Therefore, 

categories that have both a point and area source component, would be overrepresented in MANE-VU’s area source 

emissions inventory for Allegheny County to the extent that there are point source emissions reported for a given 

source category. Of source categories with a point source component, the Industrial Coal Combustion and 

Commercial Coal Combustion categories warrant particular attention due to the magnitude of their SO2 emissions. 
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Because the extra effort was not prohibitive, we developed updated 2007 Allegheny County area source emission 

estimates for all ICI fuel combustion categories by performing point source subtractions for these categories. 

b. Base Year Estimation Method 

TS|Pechan performed point source subtractions on all pollutants reported for the ICI fuel combustion area source 

categories in the 2007 MANE-VU inventory for Allegheny County. Table II-5 displays the list of source categories for 

which one or more related point source categories appear in Allegheny County’s point source emissions inventory. 

Table II-6 presents the list of area source categories for which no related point source categories were identified in 

Allegheny County’s point inventory. We updated the Allegheny County area source emission estimates by first 

subtracting the current emissions reported for ICI fuel combustion categories in the MANE-VU inventory by the 

emissions reported in the county’s point source inventory. After performing the point source subtractions, we 

allocated the resulting Allegheny County area source emission estimates to the NAA using the NAA to county 

population ratio (0.0164). 

Table II-5. Area Source Categories for which Point Source Subtractions Were Performed 

SCC Description1 Description2 Description3 Description4 

2102002000 Stationary Source Fuel Combustion Industrial Bituminous/ 

Subbituminous Coal 

Total: All Boiler Types 

2102004000 Stationary Source Fuel Combustion Industrial Distillate Oil Total: Boilers and IC 

Engines 

2102006000 Stationary Source Fuel Combustion Industrial Natural Gas Total: Boilers and IC 

Engines 

2102007000 Stationary Source Fuel Combustion Industrial Liquified Petroleum 

Gas (LPG) 

Total: All Boiler Types 

2103002000 Stationary Source Fuel Combustion Commercial/Institutional Bituminous/ 

Subbituminous Coal 

Total: All Boiler Types 

2103004000 Stationary Source Fuel Combustion Commercial/Institutional Distillate Oil Total: Boilers and IC 

Engines 

2103006000 Stationary Source Fuel Combustion Commercial/Institutional Natural Gas Total: Boilers and IC 

Engines 

2103007000 Stationary Source Fuel Combustion Commercial/Institutional LPG Total: All Combustor 

Types 

Table II-6. Area Source Categories for which Point Source Subtractions Were Not Performed 

SCC Description1 Description2 Description3 Description4 

2102005000 Stationary Source Fuel Combustion Industrial Residual Oil Total: All Boiler Types 

2102011000 Stationary Source Fuel Combustion Industrial Kerosene Total: All Boiler Types 

2103005000 Stationary Source Fuel Combustion Commercial/Institutional Residual Oil Total: All Boiler Types 

2103011000 Stationary Source Fuel Combustion Commercial/Institutional Kerosene Total: All Combustor Types 

It was necessary to use emissions data to perform the point source subtractions because we did not have access to 

point source throughput data (note that sources often do not report these data due to confidentiality concerns). Due 

to a lack of control information in the point source data that we were provided, we were unable to back-out the effect 

of any point source controls before performing the point source subtractions. This limitation results in overstating 

area source ICI fuel combustion emission estimates to the extent that ICI fuel combustion emissions in Allegheny 

County’s point source inventory incorporates the effects of emission controls. 
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c. 2014 Estimation Method 

To estimate 2014 ICI Fuel Combustion area source emissions for the NAA, we assumed that the rate of change in 

emissions activity between 2007 and 2014 equals the projected change in NAA population between these years 

(SPC, 2011b). We are not aware of any control programs that would affect 2014 emissions for this source category. 

4. Commercial Cooking 

a. Background 

The 2007 MANE-VU inventory for Commercial Cooking reflects the 2008 NEI emission estimates for this category. 

The emissions activity data for this category is the mass of meat and french fries cooked on each of five equipment 

types (e.g., under-fired charbroiling). 

b. Base Year Estimation Method 

We are not aware of the availability of NAA-level emissions activity data for this source category. However, we 

refined the default county allocation procedure that relies on the ratio of NAA to county population to estimate NAA 

emissions from Allegheny County emissions. The ACHD provided TS|Pechan with a list of establishments in 

Allegheny that undergo food inspections (ACHD, 2011c). After removing out-of-county entries on this list, TS|Pechan 

estimated the total count of restaurants in Allegheny County at 6,982. Based on the “Municipality” entries on this list, 

we estimate that 98 restaurants are located in the NAA. We used the ratio of NAA to County restaurants to allocate 

MANE-VU’s Allegheny County Commercial Cooking emissions to the NAA. This resulted in smaller NAA emissions 

than use of the default population approach due to the lower percentage represented by the restaurant data (1.42 

percent) than the population data (1.64 percent). 

c. 2014 Estimation Method 

We assumed that the rate of change in emissions activity between 2007 and 2014 for this category will equal the 

projected change in NAA population between these years. We used the most recent set of population projections for 

each NAA municipality as obtained from the Southwest Pennsylvania Commission (SPC, 2011b). We are not aware 

of any control programs that would affect 2014 emissions for this source category. 

5. Open Burning 

a. Background 

The 2007 MANE-VU inventory, which is derived from the 2008 NEI, does not report any emissions from Open 

Burning. The Open Burning source category is comprised of the following SCCs: 

 SCC 2610000100 – Open Burning, Yard Waste-Leaves; 

 SCC 2610000400 – Open Burning, Yard Waste-Brush; 

 SCC 2610000500 – Open Burning, Land Clearing Debris; and 

 SCC 2610030000 – Open Burning, Household Waste. 

Because the Bureau of the Census categorized at least 80 percent of Allegheny County’s total population as located 

in urbanized areas in 2000 (last year available), the 2008 NEI assumed that an open burning ban would be in place 

that would be 100 percent effective at eliminating emissions from this source category. 
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b. Base Year Estimation Method 

TS|Pechan assumed 97 percent compliance with the open burning ban in the NAA based on the rule effectiveness 

rate we applied in a 2002 MANE-VU inventory effort. We also replaced the acreage estimates used in the 2008 NEI 

to estimate the emissions activity for Land Clearing Debris with the estimates described in the Construction Dust 

category described earlier. For the other three Open Burning SCCs, we estimated NAA emissions activity by 

allocating the NEI’s Allegheny County activity data to the NAA using the ratio of NAA population to county population. 

After applying the 97 percent rule effectiveness adjustment, the estimated volume of waste burned for each of these 

three categories is as follows: Yard Waste-Leaves: 146 pounds; Yard Waste-Brush: 146 pounds; and Household 

Waste: 3,280 pounds. 

c. 2014 Estimation Method 

To estimate 2014 Open Burning emissions for the NAA, we assumed that the rate of change in emissions activity 

between 2007 and 2014 will equal the projected change in NAA population between these years (SPC, 2011b). We 

are not aware of any additional control programs that would affect 2014 emissions for this source category. 

6. Natural Gas Exploration 

a. Background 

The MANE-VU area source inventory does not report any natural gas exploration emissions. A review of the 

Allegheny County point source inventory identified emissions in one related SCC (31000299—Natural Gas 

Production; Other Not Classified). Because the emissions record for this SCC is listed as “USS - CLAIRTON 

WORKS” and the UNITDESC = “COG VENTING” and the PROCDESC = “ACCIDENTAL VENT,” we do not believe 

that these emissions are associated with natural gas production. 

Below is a short primer on potential criteria pollutant emission sources from Marcellus Shale natural gas exploration 

taken from a report prepared for the New York State Energy Research and Development Authority (ICF, 2009). 

1. Particulate Matter (PM): The most common sources of particulate matter from natural gas operations are 

dust or soil entering the air during pad construction or from traffic on access roads, and diesel exhaust from 

vehicles and engines used to power machinery at natural gas facilities. Particulate matter can also be 

emitted during venting and flaring operations. 

2. Sulfur Dioxide: SO2 is formed during the combustion of fossil fuels that contain sulfur, such as diesel or raw 

natural gas. Flares and machinery that run on diesel and natural gas emit sulfur dioxide at natural gas 

drilling operations. 

3. Nitrogen Oxides: NOx is emitted from the combustion of fossil fuels. NOx is emitted in exhaust from 

construction and other vehicles used at well sites, from flaring at natural gas operations, and also as part of 

exhaust from diesel and natural gas engines that power machinery such as compressor engines and other 

heavy equipment. 

4. Carbon Monoxide: Carbon monoxide is emitted during flaring, and from the operation of machinery at 

natural gas development sites. 

5. Volatile Organic Compounds (VOC): VOC emissions depend to a significant degree on gas composition. 

b. Base Year Estimation Method 

There are no base year emissions in the NAA for Marcellus Shale gas exploration. 
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c. 2014 Estimation Method 

ACHD directed TS|Pechan to develop 2014 emission estimates for natural gas exploration associated with 

development of Marcellus Shale gas reserves. TS|Pechan reviewed 2007-2011 information from PA DEP’s “Permits 

Issued by County with Location Information” to identify the number of Marcellus Shale well permits in the NAA 

(PADEP, 2011). The first year with any Marcellus Shale well permits in Allegheny County was 2008—one Marcellus 

Shale permit was listed in Fawn and the other in Frazier. Over the entire 2008-2011 period, 16 Marcellus Shale wells 

have been permitted in Allegheny County (besides Fawn and Frazier, the other two municipalities listed with permits 

are Forward and Plum). Of these 16 permits, only 3 have produced gas to date (all in Fawn). It is important to note 

that typically many fewer wells are actually drilled than are permitted. 

Although available information does not indicate that any Marcellus Shale gas exploration will occur in the NAA by 

2014, it is not possible to be certain. Therefore, we developed NAA emission estimates for 2014 by multiplying 

estimates of NAA production in 2014 by emission factors originating from the only identified study (Armendariz, 2009) 

that estimated criteria pollutant emissions from shale gas exploration. 

We estimated NAA production by allocating projected shale gas production in Pennsylvania to the NAA using oil and 

gas lease acreage data. Based on municipality-level data on oil and gas leases in Allegheny County and a recent 

Associated Press survey of 37 companies that appear on Pennsylvania's list of active Marcellus Shale operators, we 

estimate that the NAA accounts for approximately 0.01 percent of total state-level leased acreage (University of 

Pittsburgh, 2011; AP, 2011). A recent Penn State University study projects 6.5 billion cubic feet of Marcellus shale 

natural gas production in year 2014 (Considine, Watson, and Blumsack, 2010). 

Next, we calculated VOC and NOx emission factors per million cubic feet of natural gas production for the following 

natural gas exploration processes from a 2009 study performed in the Barnett shale region in Texas: 

 Compressor engine exhaust; 

 Condensate and oil tanks; 

 Production fugitives; 

 Well drilling, hydraulic fracturing, and well completions; 

 Natural gas processing; and 

 Natural gas transmission fugitives (Armendariz, 2009). 

To develop emission estimates for PM2.5, SO2, and NH3, we identified the processes with the potential to emit these 

pollutants. Table II-7 displays a list of pollutants for which emissions were developed for each process, and the 

source used to calculate each emission factor. Entries of “Nonroad ratio” in this table indicate that we estimated an 

emission factor for that pollutant by multiplying the NOx emission factors computed from the Barnett shale study by 

the ratio of the NOx and the other pollutant’s emission factor as reported in EPA’s NONROAD model for compressor 

engines and drilling equipment engines . Note that although SO2 emissions are associated with gas processing 

plants (specifically from gas sweetening and sulfur recovery units), these plants are large-scale operations that are 

few in number (Pennsylvania has less than 10 gas processing plants—all of which are located in Northern 

Pennsylvania). Because there are no plans to locate such a plant in the NAA, we did not estimate SO2 emissions 

from this process. 
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Table II-7. Emission Factor Source by Emissions Process and Pollutant 

Emission Process VOC NOX PM2.5 SO2 NH3

Compressor engines Barnett study Barnett study NONROAD ratio NONROAD ratio NONROAD ratio 

Condensate and oil tanks Barnett study 

Production fugitives Barnett study

Well drilling and completions Barnett study Barnett study NONROAD ratio NONROAD ratio NONROAD ratio

Gas processing Barnett study 

Transmission fugitives Barnett study

7. All Other Area Sources 

a. Background 

The base year and 2014 projected emissions for all other non-priority area source categories were estimated as 

described below. 

b. Base Year Estimation Method 

For all other area source categories, TS|Pechan used the 2007 MANE-VU emission estimates for Allegheny County, 

and allocated these emissions to the NAA assuming 1.64 percent of these county emissions are from the NAA – 

based on the percentage of county population in the NAA. 

c. 2014 Estimation Method 

To project 2014 emissions for all other source categories, we assumed that the rate of change in emissions activity 

between 2007 and 2014 will equal the projected change in NAA population between these years (SPC, 2011b). We 

did not model any additional control programs that would affect 2014 emissions for these source categories. 

D. 2007 AND 2014 LIBERTY-CLAIRTON EMISSIONS INVENTORY SUMMARY 

Tables II-8 and II-9 summarize the 2007 and 2014 area source emission estimates for the Liberty-Clairton 

nonattainment area. 

Table II-8. 2007 Area Source Emission Estimates (tons/year) 

Source Category PM2.5-PRI SO2 NH3 VOC NOX CO 

Residential Wood Combustion (Stoves, Fireplaces, Furnaces) 15.738 0.403 0.947 18.595 1.873 110.357 

Fugitive Dust (Construction, Paved/Unpaved Roads) 5.151 0.000 0.000 0.000 0.000 0.000 

Commercial Cooking 4.104 0.000 0.000 0.626 0.000 1.646 

Residential Heating - Gas, Oil and Coal 3.049 0.280 0.201 3.145 33.945 18.114 

Industrial Coal Combustion 0.000 31.419 0.040 0.000 0.000 0.000 

Commercial/Institutional Coal Combustion 0.000 0.000 0.020 0.000 0.000 0.549 

Fertilizer Application 0.000 0.000 2.200 0.000 0.000 0.000 

Open Burning 1.023 0.001 0.000 0.888 0.384 12.893 

All Other Area Source Categories 0.598 16.536 0.841 232.678 2.601 0.323 

Total Area 29.66 48.64 4.25 255.93 38.80 143.88 
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Table II-9. 2014 Area Source Emission Estimates (tons/year) 

Source Category PM2.5-PRI SO2 NH3 VOC NOX CO 

Residential Wood Combustion (Stoves, Fireplaces, Furnaces) 15.114 0.398 0.915 16.986 1.883 105.070 

Fugitive Dust (Construction, Paved/Unpaved Roads) 5.325 0.000 0.000 0.000 0.000 0.000 

Commercial Cooking 4.062 0.000 0.000 0.620 0.000 1.629 

Residential Heating - Gas, Oil and Coal 3.018 0.277 0.199 3.114 33.605 17.933 

Industrial Coal Combustion 0.000 31.105 0.040 0.000 0.000 0.000 

Commercial/Institutional Coal Combustion 0.000 0.000 0.020 0.000 0.000 0.544 

Fertilizer Application 0.000 0.000 2.178 0.000 0.000 0.000 

Open Burning 1.013 0.001 0.000 0.879 0.381 12.764 

Natural Gas Exploration / Production 0.001 0.000 0.000 0.027 0.015 0.000 

All Other Area Source Categories 0.593 16.370 0.833 230.351 2.575 0.320 

Total Area 29.13 48.15 4.18 251.98 38.46 138.26 

 
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CHAPTER III. OFF-ROAD SOURCES 

A. 2007 MANE-VU EMISSIONS INVENTORY SUMMARY 

Table III-1 provides a summary of 2007 county-level off-road emissions for PM2.5, SO2, and NH3, as calculated by 

MANE-VU for Allegheny County. 

Table III-1. 2007 Off-Road Emissions for Allegheny County (tons per year) 

Offroad Category 

PM2.5-

PRI SO2 NH3

Locomotives 63.6 21 1 

Commercial Marine Vessels 111.6 64 4 

Off-Road Diesel 281.2 253.4 2.8 

Off-Road Gas 114.4 6.6 2.1 

Aircraft 26.5 74.0 NA 

Total Offroad 597.4 419.0 9.4 

NA = Not available. 

Locomotive category emissions are comprised of Class I and smaller Class II/III line haul operations, as well as 

passenger operations. Commercial Marine Vessel emissions account for tug and passenger vessel traffic along 

Allegheny County waterways serving the Port of Pittsburgh. Off-Road Diesel and Off-Road Gasoline categories 

correspond to off-road engines as modeled by EPA’s National Mobile Inventory Model (NMIM). NMIM includes 

categories such as lawn and garden, commercial, industrial, farm, and construction equipment, among others. Of the 

approximately 280 tons PM2.5 from diesel offroad equipment modeled by NMIM, 68 percent is due to diesel 

construction equipment. 

Aircraft emissions correspond primarily to operations at Pittsburgh International Airport, as well as other general 

aviation airports in the county. However, no airports operate within the Liberty-Clairton NAA. The nearest airport to 

the Liberty-Clairton area is the Allegheny County Airport in West Mifflin. As such, emission contributions from aircraft 

will not be considered further for this study. In addition, since no passenger rail lines operate in the NAA, this 

category is excluded from the base year inventory. 

B. IDENTIFICATION OF PRIORITY SOURCE CATEGORIES 

TS|Pechan identified Class I and II/III line haul locomotives, commercial marine vessels, and diesel construction 

equipment to be the most significant contributing categories to off-road PM2.5 emissions in the Liberty-Clairton NAA. 

As such, these are the priority categories with respect to making improvements to the base year SIP emissions 

inventory. As stated earlier, passenger rail does not operate in the NAA boundary and no airports are in the NAA 

boundary; therefore emissions for these categories are not included in the base year and forecast year SIP 

inventories. Other non-priority source categories accounted for in the Allegheny County off-road inventory (i.e., all 

NMIM gasoline, and all NMIM diesel excepting construction) are allocated from the county level to the NAA using 

population as the surrogate indicator. 

C. EMISSIONS INVENTORY REFINEMENTS 

The following sections provide a discussion of revisions made to 2007 base year emissions for priority source 

categories, as well as a description of methods used for estimating 2014 emissions. 
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1. Locomotives 

a. Background 

Current emission estimates for Allegheny County Class I and Class II/III line haul locomotives are based on a 2007 

emissions inventory developed by the Eastern Regional Technical Advisory Committee (ERTAC). Base year 

emissions for locomotives are reported for the following SCCs: 

 2285002006 – Diesel Class I Line Haul; and 

 2285002007 – Diesel Class II/III Line Haul. 

For both of these classes of locomotives, we relied on the county-level estimates developed by ERTAC, and 

allocated county-level emissions to the NAA based on rail track mileage. Emissions associated with switch 

locomotive activity at railyards (SCC 2285002010) are not accounted for by ERTAC in Allegheny County. As such, 

an effort was made to obtain activity data to characterize railyards in or near the NAA. The following provides more 

details for each class of railroad. 

b. Base Year Estimation Method 

For the Class I rail lines, link-level traffic density (expressed as gross ton-mile [GTM]) available from the Federal 

Railroad Association (FRA), were used in developing county-level ERTAC estimates. The link-level GTM data are 

confidential, so the relevant Class I rail lines operating in the area must grant permission to release these data. 

TS|Pechan made an information request through ERTAC to the Class I rail lines operating in the area, namely CSX 

and Norfolk Southern (NS), to obtain the link-level inventory that comprises Allegheny County. Both CSX and NS 

were not responsive to this request. As such, we allocated county-level Class I rail emissions to the NAA using the 

ratio of NAA to county-wide track miles. Of the 362 miles of active rail track miles in Allegheny County, 14.2 are in 

the Liberty-Clairton area, resulting in an allocation of 3.92 percent (SPC, 2011c). 

For the Class II/III rail lines, ERTAC prepared county emissions for Class II/III rail lines (ERTAC, 2011). It was 

confirmed through the Southwestern Pennsylvania Commission that Union Railroad Company (URR) is the only 

active Class II rail line operating in the Liberty-Clairton area. Fuel use for most rail lines, including URR, were 

estimated by ERTAC assuming a fuel consumption factor of 2,814 gallons/mile (calculated based on total industry 

fuel use from the American Shortline and Regional Railroad Association and Class II/III route miles available from the 

FRA). ERTAC estimated that URR consumes 93,758 gallons of diesel fuel in Allegheny County. Of the 33.3 miles of 

URR track miles in Allegheny County, 3.5 miles occur within the Liberty-Clairton area (SPC, 2011c). Using track 

miles as a surrogate, fuel use in the Liberty-Clairton area was estimated. 

Although ERTAC developed a yard inventory for many larger railyards in the nation, switchyard activity in Allegheny 

County was not characterized. TS|Pechan contacted companies that operate switch locomotives within or near the 

NAA, including the McKeesport Connecting Railroad Company, and Dura-Bond Industries. Dura-Bond Industries 

owns a pipe coating plant near Elg Metals in Port Vue, and operates a Turtle Creek switcher on the property. The 

McKeesport Connecting Railroad Company is located just outside the northern border of the NAA, where the 

Monongahela and Youghiogheny rivers meet. Dura-Bond provided information on the operating schedule and fuel 

consumption rate of the switcher, resulting in a fuel consumption estimate of 2,496 gallons/yr. No response was 

obtained from the McKeesport Connecting Railroad Company (owned by Transtar). Since ERTAC had listed the 

McKeesport Connecting Railroad Company as a shortline rail, and developed a fuel consumption estimate of 2,556 

gallons/yr, this value was used as the default activity. 
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c. 2014 Estimation Method 

For rail line haul and switchyard operations, TS|Pechan developed estimates of 2014 emissions based on freight rail 

sector fuel consumption forecasts published by the Energy Information Administration. Table 67 of the Energy 

Information Administration’s Annual Energy Outlook, 2011 provides national-level forecasts of freight rail distillate oil 

(diesel) consumption [in trillion British thermal units [Btus]) out to 2035 (EIA, 2011). In addition, expected reductions 

for NOx, particulate matter with an aerodynamic diameter of 10 microns or less (PM10), PM2.5, VOC, as well as SO2

were modeled. Control factors were based on the change in fleet-average emission factors published by EPA 

between 2007 and 2014 (EPA, 2009). For SO2, reductions were calculated based on a 2007 base year diesel fuel 

sulfur content of 300 parts per million (ppm), and an estimated 2014 diesel fuel sulfur content of 20 ppm. 

2. Commercial Marine Vessels 

a. Background 

The current inventory for Allegheny County is based on the PA DEP’s Port of Pittsburgh inventory, which was 

prepared using procedures from EPA’s guidance, “Commercial Marine Activity for Great Lake and Inland River Ports 

in the United States, 1999.” Emissions were allocated from the entire Port of Pittsburgh area to Allegheny County 

based on the relative number of piers, wharves, and docks. This resulted in an allocation of approximately 50 

percent of total Port of Pittsburgh emissions to Allegheny County. Emissions were reported for both diesel in-port 

and underway vessel activity (SCC 2280002100 and 2280002200) (Trostle, 2011). 

b. Base Year Estimation Method 

Vessels moving within inland river ports have two primary modes of operation, river cruise and maneuvering. River 

cruise is considered to be the speed when traveling on the river which varies due to weather and river conditions, 

congestion in the river, and load on the tug. River cruise speeds are also adjusted for the river current. When 

calculating river cruise time-in-mode, river current is added to the tug speed for downbound traffic and subtracted 

from the tug speed for upbound traffic to derive the overall speed. Maneuvering is calculated to take place when a 

tug maneuvers a barge into a dock or fleeting area or when a tow maneuvers through a lock. Activity for this 

category accounted for time spent in each of these two operating modes, combined with the number of trips and an 

assumed fuel consumption rate for each size (i.e., horsepower) category of tugboat. 

TS|Pechan calculated emissions using the same general methodology as used for the entire Pittsburgh area, but 

using local trip data that represents an approximate 12-mile segment of the waterway that overlaps with the NAA. 

Trip data were provided in a 2007 report obtained from the Port of Pittsburgh Commission, as recorded by two locks 

on the Monongahela River surrounding the area of interest (Brinza, 2011). Lock 2 is located within the NAA, 

upstream of the Clairton Coke Works at Elizabeth, while Lock 3 is downstream of Clairton at Braddock, north of the 

junction where the Youghiogheny meets the Monongahela River. The report provided the number of tug trips 

traveling upbound and downbound through each of these locks. A summary of the data obtained is provided in Table 

III-2. 

Table III-2. Tug and Loaded Barge Trips and Tons of Coal for Locks 2 and 3 of the Monongahela River 

Tugs Loaded Barges Tons of Coal 

Lock # Upbound Downbound Upbound Downbound Upbound Downbound 

Lock 2 1,626 1,628 6,808 7,186 7,722,400 7,958,200 

Lock 3 2,814 2,857 3,548 8,172 3,074,600 9,136,200 
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Barges in the Port of Pittsburgh are mostly loaded in the downbound direction and unloaded in the upbound direction. 

The dry cargo barges are non self-propelled and therefore do not contribute to emissions. Information on the number 

of loaded/empty barges and the amount of coal transported was used to assist in characterizing the reported tug trips 

as either calling or passing traffic. An indication that a tug has stopped or called can be made by making note of 

commodities passing through Lock 2 and 3. For example, Table III-2 shows that 7.7 million tons of coal moved 

upbound through Lock 2. Lock 3 shows that only 3.1 million tons of coal moved upbound through that lock. As such, 

4 million tons of coal was unloaded at some point between those two locks (likely the terminal at Clairton Coke 

Works). 

The lock data give an indication of the number of tugs passing, but do not provide information on vessel 

origin/destination, or trip paths between the locks. In the absence of field or survey data to characterize the tug traffic 

patterns, simplifying assumptions were made of tug travel upstream and downstream. Within the 12-mile waterway 

segment, we considered Clairton Coke Works to be a primary destination (similar to a port). In the downbound 

direction, we estimated that 1,229 tugs are calling and 1,628 are passing. This was estimated by subtracting Lock 2 

downbound traffic (1,628) from Lock 3 downbound traffic (2,857); 1,229 are assumed to "call" on Clairton Coke 

Works; the remaining 1,628 tugs passes. The 1,229 calling tugs originating from Lock 3 are then assumed to turn 

around and go back upbound through Lock 3 (~4 miles roundtrip). The 1,626 moving upbound through Lock 2 are 

assumed to be "calling," and travel the entire length of waterway. Upbound passing traffic is assumed to be zero. 

TS|Pechan used the same river cruise and maneuvering speeds and associated time-in-mode assumed by PA DEP 

in their Port of Pittsburgh calculations, and a river current of 3.5 miles per hour. We also used the same horsepower 

distribution and load factors assumed by PA DEP for the tug fleet. Tugboats are estimated to run at close to 

maximum power, 75 percent load, for calculating fuel usage, since they push cargo downstream and empty barges 

upstream against a strong current. 

TS|Pechan reviewed the emission factors applied by PA DEP to the fuel consumption to calculate emissions. 

Revisions were made to emission rates for some pollutants to ensure that values were consistent with EPA baseline 

emission rates (EPA, 2008c). Table III-3 lists the fuel-based emission factors applied to the fuel consumption 

estimates. 

Table III-3. 2007 Commercial Marine Vessel Emission Factors (lbs/gallons fuel) 

PM2.5 SO2 NH3 NOx HC 

0.009 0.037 0.018 0.419 0.009 

Passenger vessel traffic in the NAA was determined to be negligible. Passenger vessel trips amounting to an 

average of 4 upbound/downbound trips were included in the 2007 Monongahela Lock 2 and Lock 3 report, but since 

this is such a small fraction of the tug traffic in the area, passenger vessel traffic and associated emissions were not 

estimated. 

c. 2014 Estimation Method 

Commercial marine activity is comprised largely of tugboats pushing barges loaded with coal to Clairton Coke Works, 

with some traffic passing through to other terminals. As such, TS|Pechan estimated 2014 commercial marine activity 

based on a linear extrapolation of historical estimates of tons of coal transported along the Ohio River System, as 

published by the U.S. Army Corps of Engineers (US ACE). Historical data for the time period 1984 through 2009 is 

available from the US ACE’s publication, “Waterborne Commerce of the United States” (USACE, 2011). Reductions 

due to Federal commercial marine rulemakings were also reflected in the 2014 emissions inventory. Control factors 

were developed based on emission reductions calculated from national base case and control case inventories for 
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Category 1 & 2 engines (EPA, 2008c). For SO2, reductions were calculated based on an estimated 2014 diesel fuel 

sulfur content of 52 ppm. 

3. Diesel Construction (NMIM) 

a. Background 

2007 emissions for diesel construction equipment are based on EPA’s NMIM (which incorporates EPA’s predecessor 

NONROAD model). NMIM estimates emissions for many off-road categories, including construction, farm, industrial, 

commercial, among others, but excludes locomotive, commercial marine and aircraft engine emissions. NMIM was 

run using all EPA default activity inputs with a few exceptions, including adjustments to fuel parameter and 

temperature data. 

County-wide, diesel construction equipment contributes to approximately 50 percent of total NMIM PM2.5 emissions, 

and 33 percent of total nonroad emissions. However, current construction activity levels in the Liberty-Clairton area 

are believed to be relatively low. As such, improvements to base year emissions for this category were limited to 

refining the county to NAA allocation procedures. TS|Pechan also compiled 2007 in-use diesel construction 

equipment populations and model year distributions assumed by EPA’s NONROAD model for Allegheny County, and 

provided these to the Constructor’s Association of Western Pennsylvania for a reasonableness review. However, the 

association was not able to provide feedback in the necessary time frame, and believed that an extensive survey of 

the contractor community would be needed to compile meaningful information and make valid comparisons to the 

default data. 

b. Base Year Estimation Method 

Construction equipment emissions representing Allegheny County were allocated to the Liberty-Clairton area based 

on the ratio of land disturbed in the NAA relative to the land disturbed in the county, obtained from the Southwestern 

Pennsylvania Commission (SPC). In addition, TS|Pechan compiled data from the SPC on agricultural land use in the 

Liberty-Clairton area to allocate emissions from farm equipment. All other NMIM equipment types were allocated to 

the Liberty-Clairton NAA based on population. Table III-4 lists the fractions applied for construction and farm 

equipment. 

Table III-4. County to NAA Allocation for Construction Equipment 

Acres, 2006 

Equipment Land Use 

Allegheny 

County 

LibertyClairton NAA Fraction 

Construction Urban Built-Up 238,539 3,557 0.0149 

Farm Agricultural 23,815 65 0.0027 

c. 2014 Estimation Method 

2014 emissions for NONROAD (NMIM) categories were estimated using the change in emissions between a 

national-level model run for 2007 and 2014. It was determined that the effort to replicate the MANE-VU 2007 

Allegheny County NMIM results, and then run using comparable inputs at the county level for 2014 was not 

warranted, given than Liberty-Clairton area emissions are estimated to be less than 2 percent of total Allegheny 

county emissions. The chosen approach was also used since growth and control assumptions in NONROAD do not 

vary by county (i.e., relative growth rates and emission reductions specific to equipment types/pollutants calculated at 

a national level would be equivalent). Fuel sulfur levels used in the base year and 2014 national model runs are 
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provided in Table III-5. NONROAD assumes a higher fuel sulfur level for recreational marine engines compared to 

land-based equipment. 

Table III-5. Modeled Diesel Sulfur Levels for NONROAD (ppm) 

Year Land Marine 

2007 351 435 

2014 20 52 

D. 2007 AND 2014 LIBERTY-CLAIRTON EMISSIONS INVENTORY SUMMARY 

Tables III-6 and III-7 provide a summary of 2007 and 2014 off-road emissions for the Liberty-Clairton area, as 

calculated using the refinements discussed in Section C of this chapter. With the exception of NH3, emissions for all 

pollutants decrease between 2007 and 2014, due to the continued phase-in of nonroad engine standards and fuel 

sulfur limitations. 

Table III-6. 2007 Off-Road Emissions for Liberty-Clairton Area (tons/year) 

Nonroad Category PM25-PRI SO2 NH3 VOC NOx

Nonroad Diesel 4.30 3.87 0.04 5.52 50.06 

Nonroad Gas 1.87 0.11 0.04 70.55 22.69 

Locomotive 2.44 0.80 0.04 3.95 75.57 

CMV 6.36 12.44 0.05 6.55 289.62 

Total Nonroad 14.96 17.22 0.16 86.57 437.94 

Table III-7. 2014 Off-Road Emissions for Liberty-Clairton Area (tons/year) 

Nonroad Sector PM25-PRI SO2 NH3 VOC NOx

Nonroad Diesel 3.08 0.24 0.05 3.85 36.78 

Nonroad Gas 1.98 0.12 0.04 45.46 10.78 

Locomotive 1.32 0.13 0.03 2.47 55.18 

CMV 6.06 5.50 0.05 6.70 284.36 

Total Nonroad 12.44 5.99 0.17 58.47 387.10 
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CHAPTER IV. ON-ROAD SOURCES 

This chapter outlines the approach used to develop the highway mobile source inventory, including a discussion of 

the data sources, parameters and overall analysis approach. The highway inventory utilizes EPA’s new emission 

model, the Motor Vehicle Emissions Simulator (MOVES). MOVES2010a, the most recent version of the software, 

represents a significant departure from the previous MOBILE6.2 model including new vehicle emission rates 

reflecting the latest regulations pertaining to fuel efficiency and vehicle emission standards. The analysis approach 

and data assumptions are consistent with EPA technical guidance and other statewide inventories conducted by PA 

DEP). This includes the use of roadway and traffic count data from the Pennsylvania Department of Transportation 

(PennDOT), accepted post processing software to estimate hourly speeds, and traffic and vehicle population growth 

rates utilizing available PennDOT and regional data sources. Other traffic, environmental, vehicle fleet, fuel and 

control strategy inputs have been prepared using the latest local-specific planning assumptions. 

The analysis methodologies and data sources have undergone review from multiple agencies. The Pennsylvania Air 

Quality Workgroup, a state-wide interagency consultation group including Federal (EPA, FHWA), state (PennDOT, 

PA DEP) and regional [metropolitan planning organizations (MPOs)] agencies has played a key role in reviewing the 

MOVES emission calculation process, local data sources, and methods in determining future growth for vehicle miles 

of travel (VMT) and vehicle population. 

 

A. ANALYSIS METHODOLOGY 

Guidance documents from EPA were used to develop the base and future year emissions inventories for the LibertyClairton PM2.5 NAA and include: 

 Policy Guidance on the Use of MOVES2010 for SIP Development, Transportation Conformity, and Other 

Purposes, EPA Office of Air and Radiation, EPA-420-B-09-046, December 2009 (EPA, 2009). 

 Technical Guidance on the Use of MOVES2010 for Emission Inventory Preparation in State Implementation 

Plans and Transportation Conformity, EPA Office of Air and Radiation, and Office of Transportation and Air 

Quality, EPA-420-B-10-023, April 2010 (EPA, 2010a). 

 Motor Vehicle Emission Simulator, User Guide for MOVES2010a, EPA-420-B-10-036, August 2010 (EPA, 

2010b). 

The highway mobile source emission inventory was developed using available travel data and EPA’s MOVES2010a 

emission model. The methodologies used in the development of this inventory conform to the recommendations 

provided in EPA’s Technical Guidance. A mix of local data and national data (internal to MOVES2010a) has been 

used for this submission. Local data was used for the more significant inputs into the process and include: 

 Vehicle type vehicle miles traveled (VMT). 

 Average speed distribution. 

 Vehicle type mixes. 

 Source type population (for light-duty vehicles). 

 Vehicle age distribution. 

 Hourly distributions. 

 Meteorology data. 

 Inspection/Maintenance (I/M) program. 

 Fuel supply. 

The data used reflects the latest planning assumptions and is primarily based on data assembled from PennDOT, the 

Department of Motor Vehicles, the local MPO (SPC) and other local/national sources. Where available 2007 data 
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was used, however 2008 data already been vetted by stakeholders (projected back to 2007) was also used as 

appropriate. 

The analysis methodology is consistent with past statewide inventory efforts including the 2008 NEI submission. This 

includes the use of custom post processing software to calculate hourly speeds and prepare key traffic input files to 

the MOVES2010a emission model. 

B. ANALYSIS TOOLS 

The mobile vehicle emissions inventory analysis utilizes several key software/programs for producing the county 

emissions totals. These tools are outlined in Table IV-1. 

Table IV-1. Summary of Analysis Tools 

Tool Purpose 

MOVES2010a Produces emission rates for each ozone precursor, VOC and NOx. 

PPSUITE Processes the highway data; calculates hourly congested speeds for each state roadway segment; 

prepares MOVES2010a input files; processes MOVES2010a output files into a summary report. 

CENTRAL Provides a batch menu driven process to execute PPSUITE, MOVES2010a, and other MYSQL steps. 

The Liberty-Clairton PM2.5 on-road inventory was developed using EPA’s MOVES2010a emission model. EPA’s 

MOVES model was officially released on March 2, 2010 and was followed with a revised version (MOVES2010a) in 

August 2010. The MOVES2010a model provides a more robust estimate of emissions as compared to its 

predecessor MOBILE6.2. MOVES2010a has been integrated with local traffic, vehicle fleet, environmental, fuel, and 

control strategy data to estimate emissions. 

PPSUITE is an enhanced version of the Post Processor for Air Quality software system that has been used for 

previous inventory and conformity submissions in Pennsylvania. The software has undergone significant revisions to 

ensure consistency with the MOVES2010a. PPSUITE was used to calculate hourly congested speeds for each 

roadway link, apply vehicle type fractions, aggregate VMT, prepare MOVES2010a traffic-related input files, and 

process MOVES2010a outputs. The PPSUITE software and process methodologies are consistent with that used for 

state inventories and transportation conformity analyses throughout Pennsylvania. Figure IV-1 summarizes the key 

functions of PPSUITE. 

CENTRAL is a menu-driven software platform that executes the PPSUITE and MOVES2010a processes in batch 

mode. The software allows users to execute runs with a variety of input options and integrates custom MYSQL steps 

into the process. CENTRAL provides important quality control and assurance steps including file naming and 

storage automation. 
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Figure IV-1. PPSUITE Process 

C. DATA SOURCES 

The latest planning assumptions were used in preparing inputs to the MOVES emission model. The data includes 

Allegheny County specific parameters regarding temperatures, fuel, and fleet age. Specific traffic conditions and 

vehicle population have been prepared for the Liberty Clairton nonattainment area. Much of the data has been 

prepared as part of inventory efforts in support of statewide analyses for the PA DEP; and has undergone review and 

acceptance by the Pennsylvania Air Quality Workgroup, the interagency consultation group that consists of EPA, 

FHWA, PennDOT, PA DEP, and MPOs (SPC in this case). 

Table IV-2 outlines all of the major data sources and processes proposed for this effort. The subsequent sections 

expand on these in greater detail. Details of the MOVES input files generated by PPSUITE can be found in 

Appendices A and B (provided separately). 
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Table IV-2. Summary of Data Parameters for Liberty-Clairton 

Parameter Source 

Analysis Years 2007, 2014 

Season Annual – 12 Month Approach – 1 representative day per month 

MOVES Domain / Calculation type County / Inventory Mode 

Pollutants PM2.5, NOx, SO2, NH3, VOC 

Emission Calculation Method Inventory Mode 

Area Liberty Clairton 

Traffic Inputs 

VMT Data Source 2008 PennDOT Roadway Management System (RMS) “Snapshot” 

Integrated with PennDOT BHSTE GIS Signal Locations 

VMT Adjustments For 2008-2007: Highway Performance Monitoring System (HPMS) County by 

Functional Class VMT 

For 2008-2014: Functional Class VMT & Growth Rates based on SPC Regional Travel 

Demand Model 

Local VMT Adjustments Using GIS, The portion of TIGER local roadway mileage in the nonattainmentmaintenance area vs. county total – Apply ratio to the total HPMS local VMT reported 

for the county 

Seasonal Adjustments Traffic Data Report PennDOT Bureau of Public Roads (BPR) (2008 Data) 

Hourly Patterns Traffic Data Report PennDOT BPR (2008 Data) 

Annual VMT Calculated by PPSUITE 

Hourly Speeds Calculated by PPSUITE (Minimum Speed = 2.5 miles per hour) 

Road Type Distribution Calculated by PPSUITE; User assigned Road Type to RMS links 

MOVES Inputs 

Vehicle Age Distribution 2010 registration data for light-duty vehicles from PennDOT’s Bureau of Motor Vehicles 

Registration Database; MOVES Defaults for Heavy-Duty Vehicles 

Fuel Parameters (Gasoline/Diesel) MOVES2010a default data (except for gasohol market penetration and Reid vapor 

pressure (RVP) values which were updated) 

I/M Parameters PAOBDII & Idle 

(Changes made to default I/M Program Parameters) 

Temperatures 10-year monthly average hourly airport temperatures - humidity from WeatherBank, 

Inc. (www.weatherbank.com) 

Month VMT Fractions Calculated based on seasonal adjustment factors 

Day VMT Fractions Calculated based on seasonal adjustment factors 

Hour VMT Fractions Calculated by PPSUITE 

Ramp Fraction MOVES Defaults (8% of vehicle hours traveled) 

Source Type Population 2007 - Based on 2008 registration data and MOVES default VMT and population. 

2014 - Based on projected household growth from Woods and Poole Inc. (Methodology 

approved by PA Air Quality Work Group consisting of EPA, FHWA, DEP, DOT) 

Early NLEV/PCV/CALLEVII EPA provided MOVES override database files 

Stage II MOVES Default Process 

Alternative Vehicle Technology MOVES Default (no input file provided) 

1. Base Traffic Data/Fleet Data Inputs 

a. Baseline Traffic Volumes 

The 2008 PennDOT RMS database serves as the primary source for the county and functional class VMT estimates 

and roadway volumes for the baseline traffic data. The RMS has been updated to provide a “snapshot” of the 

regional roadway system and traffic volumes in 2008 and also includes traffic signal locations. As 2007 RMS data 

was not readily available, HPMS data was used to factor the 2008 volumes back to 2007 levels with individual 
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adjustment factors calculated for each of the functional classes as they exist in the RMS database and are 

represented in the NAA. Note that there are no limited access freeways or expressways within the Liberty-Clairton 

NAA and as such growth factors were not developed for these roadway classifications. 

The RMS database only includes roadways maintained by PennDOT. As a result, a significant number of local 

roadways are not fully represented in the database. PennDOT has procedures to estimate county local VMT as part 

of the HPMS reporting system. For the Liberty-Clairton inventory, local VMT was estimated as a percentage of the 

Allegheny County total. Using GIS, the portion of TIGER local roadway mileage in the nonattainment area was 

calculated and compared to the total county mileage to estimate the relative portion. 

b. Seasonal Adjustments 

The PPSuite framework developed for this analysis calculates annual emissions by running MOVES for a single 

representative day for each month of the year (12 runs). Per the MOVES technical guidance option, monthly 

analyses were conducted only for the weekday option and factored to represent monthly/annual totals. The daily and 

monthly seasonal adjustment factors were developed from data contained in the document: 2008 Pennsylvania 

Traffic Data prepared by PennDOT’s BPR (PennDOT, 2008). The seasonal and daily factors are based on statistical 

analyses of 2008 traffic counts taken at permanent and in-pavement automatic traffic recorders. 

c. Congested Speeds 

PPSUITE calculates congested speeds by hour of the day for each roadway segment and provides the information 

as input to the MOVES2010a software. The speed calculations found in PPSUITE are a variation of the BPR speedflow formula and are fully consistent with the guidance provided by EPA and FHWA. To disaggregate the daily RMS 

volumes to hourly values, auto and truck hourly pattern data from PennDOT’s 2008 Pennsylvania Traffic Data Report 

was used to develop distributions of traffic by hour, which in turn is used to create an input file used by PPSUITE in 

its internal calculations. 

d. Vehicle Population 

Vehicle population is a key component in the calculation of start and evaporative emissions. MOVES2010a requires 

vehicle population by 13 source types in order to determine evaporative emissions. Data from the Department of 

Motor Vehicles was first used to estimate county-specific values. Allegheny County 2008 vehicle registration data 

was used to estimate vehicle population for light-duty vehicles and school buses. For transit buses, data from 

PennDOT and the National Transit Database (NTD) was used to estimate transit bus populations for the county. 

Next the county information was factored to represent the Liberty-Clairton portion of the region. These adjustment 

factors were based on the proportion of population in the nonattainment area as compared to the county total. For all 

other heavy-duty vehicles, MOVES2010a national default vehicle mileage accumulation rates were applied to 

regional heavy-duty VMT to estimate heavy-duty vehicle population. 

e. VMT by Source Type 

For input to the MOVES emission model, total VMT must be disaggregated into the six HPMS vehicle groups 

(passenger cars, other 2-axle light trucks, buses, single-unit trucks, combination trucks, motorcycles) This input is 

done internally by PPSUITE based on the vehicle mix patterns provided as input to the software. For this inventory 

the vehicle mix patterns were calculated utilizing a combination of the following sources: 

 2008 RMS truck percentages; 

 PennDOT and 2008 NTD transit data; 

 2008 school bus registration data; and 
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 EPA’s MOVES2010a default distribution for all other source types. 

The functional class groupings used in PPSUITE are necessary for HPMS reporting, however they are not 

compatible with MOVES2010a. As a final step, PPSUITE re-aggregates the VMT into MOVES2010a’s roadway 

classifications. This step is somewhat redundant as all roadways in the Liberty-Clairton PM2.5 NAA are classified in 

MOVES2010a as urban, non-restricted. 

f. Vehicle Age Distribution 

Vehicle age distributions for each of the 13 source types are a required input into MOVES2010a and PPSUITE. The 

distributions reflect the percentage of vehicles in the fleet up to 31 years old and must total 100 percent. Recent 

2010 registration data from PennDOT’s Bureau of Motor Vehicles Registration database has indicated a substantially 

older fleet than recorded in the 2002-2008 period. As such the 2010 vehicle age distributions have been used for this 

inventory. Due to insufficient data, only data for light-duty vehicles are used; heavy-duty vehicle age distributions are 

based on the MOVES2010a defaults for Allegheny County. As the registration data downloaded was based on 

MOBILE6.2 vehicle categories, the data was converted to source types using the EPA convertor spreadsheets 

provided with the MOVES2010a emission model. 

2. I/M and Fuel Parameters 

a. I/M Program 

The I/M program inputs to the MOVES2010a model are based on past and current programs at the county level (all 

Pennsylvania I/M programs are based on county boundaries). The MOVES2010a model has simplified the I/M 

program input parameters compared to MOBILE6.2. The default I/M program parameters included in MOVES2010a 

were examined and changes made to the defaults to match the actual local program. 

The Pennsylvania I/M program was upgraded and expanded throughout the state with a phase-in period starting in 

September 2003 and was fully implemented by June 2004. The program requirements vary by region and include 

on-board diagnostics (OBD) technology. The program, named PAOBDII, has been implemented in the Pittsburgh 

Region, including Allegheny County. The program consists of the OBDII program along with tailpipe tests (idle in this 

region) and gas cap tests. 

b. Fuel Assumptions 

The MOVES2010a default fuel formulation and fuel supply data was reviewed and updated based on available local 

volumetric fuel property information provided by PA DEP. The gasohol market penetration and RVP values was also 

updated, with MOVES2010a default data used for the remaining parameters. Updated assumptions included: 

 0.00 percent ethanol (for summer RVP months); 

 6.78 percent ethanol (for winter months); and 

 7.8 RVP during summer months. 

3. Meteorology Data 

Updated weather information was obtained from WeatherBank, Inc. (www.weatherbank.com) using the 10-year 

average minimum and maximum monthly temperature and relative humidity values obtained at the Pittsburgh 

International Airport. The MOVES2010a model requires temperature and relative humidity data for each hour of the 

day. EPA’s data converters were used to convert minimum and maximum daily temperatures to an hourly 
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temperature profile that could be input to MOVES2010a. These assumptions are consistent with recent inventory 

efforts. 

4. Vehicle Technology/Programs 

a. Federal Programs 

Current Federal vehicle emissions control and fuel programs are incorporated into the MOVES2010a software. 

These include the National Program standards covering model year vehicles through 2016. Modifications of default 

emission rates were required to reflect the early implementation of the National Low Emission Vehicle Program 

(NLEV) program in Pennsylvania. To reflect these impacts, EPA has released instructions and input files that can be 

used to model these impacts (EPA, 2010c). This inventory utilized the August 2010 version of the files 

(http://www.epa.gov/oms/models/moves/tools.htm). 

b. State Programs 

The Pennsylvania Clean Vehicles (PCV) Program, adopted in 1998, incorporated the California Low Emission 

Vehicle Program (CA LEVII) by reference, although it allowed automakers to comply with the NLEV program as an 

alternative to this Pennsylvania program until model year 2008. Beginning with model year 2008, “new” passenger 

cars and light-duty trucks with a gross vehicle weight rating (GVWR) of 8,500 pounds or less that are sold or leased 

and titled in Pennsylvania must be certified by the California Air Resources Board or be certified for sale in all 50 

states. For this program, a “new” vehicle is a qualified vehicle with an odometer reading less than 7,500 miles. PA 

DEP and PennDOT worked with the automobile manufacturers, dealers and other interested business partners and 

finalized procedures for complying with these new requirements. 

The impacts of this program were modeled for all analysis years beyond 2008 using the same EPA guidance and 

tools as downloaded for the early NLEV analysis. EPA has also provided input files that reflect the CAL LEVII 

program. Modifications were made to these files to reflect the 2008 start date in Pennsylvania. 

5. Traffic Growth Assumptions 

Traffic growth forecasting plays a pivotal role in estimating future year emissions for the region. There are many 

uncertainties affecting projections of traffic growth including the current economic conditions, future growth in 

population and employment, etc. Growth rates for this emissions inventory were based on an assessment of 

available data sources. 

All SIP mobile source highway inventories include the review and assessment of county-specific growth rates from a 

PennDOT study originally completed in 2005 and documented in the report, Statistical Evaluation of Projected Traffic 

Growth, Traffic Growth Forecasting System: Final Report, March 14, 2005 (Baker, 2005). As part of that study, a 

statewide traffic growth forecasting system was developed that incorporates traffic data from PennDOT’s Traffic 

Information System and socioeconomic forecasts. That forecasting system is maintained by the PennDOT BPR and 

is updated on a periodic basis. This system was last updated in December of 2009 to develop new statistical 

relationships between historic VMT growth and population (through 2008). The forecast population was estimated 

from the Woods and Poole data “2010 State Profile”. The results of the study have been shared between PennDOT, 

PA DEP, and other Interagency Consultation Group members, including the PA Conformity Work Group. 

The growth rates from the PennDOT BPR forecasting system were evaluated against other available data including 

the SPC travel model. For the development of motor vehicle emissions budgets, upper estimates of the VMT growth 

range are used for the forecast analyses. From an air quality perspective, the use of the upper boundary is 
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conservative, and provides for factors outside the agency’s control (e.g., potential socio-economic growth above 

current forecasts, fleet age distributions, vehicle type distribution) that influence motor vehicle emissions. 

For the Liberty-Clairton PM2.5 NAA, the PennDOT BPR Growth Rate forecasting system was used to convert 2008 

volumes to 2007, while growth rates from 2007-2014 are based on the SPC regional travel demand model. Of the 

multiple sources reviewed, these yielded the highest estimates of traffic volumes and in turn the highest estimate of 

the on-road emissions. Resulting VMT estimates are shown in Table IV-3. 

Table IV-3. Base and Forecasted Vehicle Miles of Travel (Millions) 

VMT (Millions)* % Change 2007 2014 

94.701 107.171 13.2% 

* All VMT is classified as Urban, Unrestricted in 

MOVES for Liberty-Clairton.

6. Vehicle Population Growth Assumption 

Vehicle population growth forecasting plays an important key role in determining emissions for future years for the 

region. For this inventory, the vehicle population was forecasted by considering county-specific household and 

population growth. Liberty-Clairton area vehicle population estimates by MOVES source types are shown in Table 

IV-4. 

The household and population data was obtained from the PennDOT study documented in the reports discussed 

above as well as the Statistical Evaluation of Projected Traffic Growth, Traffic Growth Forecasting System: Final 

Report, March 14, 2005. The forecast household and population were estimated from the Woods and Poole data 

“2010 State Profile.” The highest growth between household and population data was obtained for the county. The 

household growth rate yielded the higher value and did not exceed VMT growth. This value was ultimately used to 

project the 2007 vehicle population to 2014. 

Table IV-4. Vehicle Population Estimated Classified by MOVES Source Type 

MOVES Source 

Type ID 

Vehicle Population 

2007 2014 

11 443 488 

21 6,572 6,626 

31 4,625 4,749 

32 1,545 1,586 

41 2 3 

42 14 14 

43 20 21 

51 1 2 

52 94 105 

53 11 13 

54 21 24 

61 23 25 

62 26 29 

Total 13,397 13,685 
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7. Final Results 

Table IV-5 summarizes the 2007 and 2014 on-road vehicle estimates for the Liberty-Clairton NAA by MOVES road 

type. 

Table IV-5. Liberty-Clairton PM 2.5 NAA – On-Road Emissions Summary by Road Type (tons/year) 

Table IV-6 provides an on-road emissions summary by fuel type for the Liberty-Clairton NAA as well as the expected 

change in VMT and emissions between 2007 and 2014. 

Table IV-6. Liberty-Clairton PM2.5 NAA On-Road Emissions Summary by Fuel Type (tons/year) 

2007 

Fuel Type 

Annual VMT 

(millions) 

Speed 

(miles/hour) PM2.5 VOC NOx SO2 NH3

Gasoline 88.717 29.1 4.17 164.42 175.63 1.80 4.51 

Diesel Fuel 5.985 29.1 5.74 8.10 98.66 0.35 0.15 

Area Total 94.701 29.1 9.91 172.52 274.29 2.15 4.66 

2014 

Fuel Type 

Annual VMT 

(millions) 

Speed 

(miles/hour) PM2.5 VOC NOx SO2 NH3

Gasoline 100.203 29.1 3.34 89.91 93.23 0.81 3.18 

Diesel Fuel 6.968 29.1 2.84 5.15 57.80 0.09 0.18 

Area Total 107.171 29.1 6.18 95.06 151.03 0.90 3.36 

Change in VMT and Total Emissions: 2007-2014 

Fuel Type 

Annual VMT 

(millions) 

Speed 

(miles/hour) PM2.5 VOC NOx SO2 NH3

Gasoline 11.486 - -0.83 -74.51 -82.39 -0.99 -1.33 

Diesel Fuel 0.983 - -2.89 -2.95 -40.86 -0.26 0.02 

Area Total 12.469 - -3.73 -77.46 -123.26 -1.24 -1.31 

 

2007 

Road Type 

Annual VMT 

(millions) 

Speed 

(miles/hour) PM2.5 VOC NOX SO2 NH3

Off-Road - - 1.82 121.60 75.43 0.16 0.00 

Urban Unrestricted 94.701 29.1 8.09 50.92 198.86 1.99 4.66 

Area Total 94.701 - 9.91 172.52 274.29 2.15 4.66 

2014 

Road Type 

Annual VMT 

(millions) 

Speed 

(miles/hour) PM2.5 VOC NOX SO2 NH3

Off-Road - - 1.16 72.74 51.72 0.07 0.00 

Urban Unrestricted 107.171 29.1 5.02 22.32 99.31 0.84 3.36 

Area Total 107.171 - 6.18 95.06 151.03 0.90 3.36 
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CHAPTER V. SOURCE IMPACT ANALYSIS FOR THE LIBERTY MONITOR 

A. EXISTING DATA AND ANALYSES 

The Liberty-Clairton NAA has extensive speciated PM2.5 monitoring data at both the Liberty site, situated on South 

Allegheny High School (SAHS) in the NAA, and at the ACHD offices in Lawrenceville 11 miles to the north-northwest 

(bearing 333 ̊). The Liberty site also collects wind speed and direction data, a Federal Reference Method (FRM) and 

an hourly PM2.5 sampler. As tabulated above, the ACHD compiles extensive emissions data on criteria and 

hazardous air pollutants. 

Preliminary Findings – It is important to note that the Liberty and Lawrenceville locations are influenced by somewhat 

different sources. The PM2.5 concentrations and species concentrations for the 20 highest sites days at the Liberty 

site from 2005-2010 are shown in Table V-1. Figure V-1 shows how selected species are enriched at the Liberty 

Borough site. Figure V-2 shows which Positive Matrix Factorization (PMF) factors for Liberty Borough are enriched 

over similar factors from the Lawrenceville PMF analysis. In general, the factors in Liberty Borough are larger 

(especially the ones with high carbon concentrations), owing to its proximity to Clairton Works. The species 

concentrations for all days and the highest 25 percent of the PM2.5 daily measurements for both Liberty and 

Lawrenceville are shown in Table V-2 (ACHD, 2011d). 

Table V-1. Measured Composition of 20 Highest PM2.5 Days at Liberty Monitor 

Date 

PM2.5 by FRM at 

Liberty Monitor 

(POC1) 

Total of 

Measured 

(incl. Trace) 

Ammonium

(NH4)+ 

Nitrate 

(NO3) 

Sulfate 

(SO4) 

Organic 

Carbon (OC) 

Elemental 

Carbon (EC) 

9/13/2005 89.0 71.4 10.6 2.1 29.3 17.8 11.0 

10/31/2005 83.1 77.9 10.0 1.4 13.3 27.7 16.7 

8/4/2007 62.6 34.1 5.6 1.4 16.9 6.8 2.7 

4/18/2008 56.0 50.4 8.0 1.8 11.5 13.4 8.5 

2/17/2007 54.1 54.6 9.8 3.3 10.6 14.4 8.0 

5/29/2006 54.1 50.1 7.3 2.6 14.9 16.8 7.0 

11/12/2005 48.8 40.8 4.6 1.4 5.0 13.3 12.6 

8/28/2007 47.3 42.4 7.5 1.0 23.6 6.3 3.3 

7/7/2010 47.1 40.4 5.3 1.2 15.5 10.6 6.6 

7/17/2008 45.1 40.3 6.5 1.5 17.3 7.9 6.1 

7/10/2006 45.1 38.3 6.8 0.8 18.4 8.6 3.0 

9/3/2008 45.0 45.0 6.6 2.1 15.0 11.6 8.3 

2/22/2006 44.7 44.1 6.4 3.6 8.2 16.2 6.0 

9/8/2006 44.4 47.1 7.7 1.7 16.9 12.9 5.5 

7/29/2008 44.4 38.6 5.6 1.7 13.8 11.5 5.2 

9/21/2008 43.8 44.6 7.8 2.2 15.2 11.0 6.0 

9/19/2005 43.0 41.7 6.8 1.3 16.6 8.4 7.8 

7/21/2005 42.7 39.5 6.2 1.5 14.7 10.9 5.3 

8/30/2010 41.8 36.1 4.8 1.3 13.9 9.1 6.0 

4/2/2010 41.2 35.3 3.9 1.0 5.8 13.4 7.2 

Average 51.2 45.6 6.9 1.7 14.8 12.4 7.1 

SOURCE: ACHD, 2011d. 

NOTE: See Section B for discussion of the difference between FRM and "measured" mass. 
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Figure V-1. Enrichment of Species Measured at Liberty Site Compared to Lawrenceville Site (μg/m3) 

SOURCE: ACHD, 2011d.

Figure V-2. Excess PM2.5 (Liberty - Lawrenceville) Using PMF Analysis (μg/m3)

SOURCE: ACHD, 2011d. 

‐0.4

‐0.2

0.0

0.2

0.4

0.6

0.8

1.0

1.2

1.4

Se

EC

As

Br

Cl

Si

Pb

NH4

Cu

Al

V

Sulfate

OC

Ca

Zn

K_xrf

Na_xrf

Ni

Nitrate

Ti

Cr

Fe

Mn

Enrichment: Liberty ‐ Lawrenceville (ug/m3)

‐2

‐1.5

‐1

‐0.5

0

0.5

1

1.5

2

2.5

3

3.5

Excess PM2.5 at Liberty by PMF (ug/m3)
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Table V-2. Comparison of Species Concentrations on Average and High Mass Concentration Days (μg/m3) 

Average All Days 2005-10 Average High 25% of Days 

Liberty Lawrenceville Liberty Lawrenceville 

Total of Measured Species 18.8 15.2 34.7 26.2 

NH4+ 2.4 1.87 4.8 3.42 

NO3

-

 1.3 1.57 1.5 2.38 

SO4

-- 5.3 4.44 10.2 8.41 

OC 4.4 3.80 8.8 5.53 

EC 2.15 0.80 4.99 1.14 

Al 0.035 0.027 0.059 0.039 

As 0.0047 0.0020 0.011 0.0027 

Br 0.011 0.0045 0.025 0.0068 

Ca 0.044 0.041 0.074 0.059 

Cl 0.25 0.024 0.78 0.048 

Cr 0.0022 0.0035 0.0021 0.0052 

Cu 0.0071 0.0056 0.0098 0.0082 

Fe 0.099 0.16 0.14 0.22 

Pb 0.017 0.010 0.039 0.014 

Mn 0.0030 0.0060 0.0036 0.0088 

Ni 0.0016 0.0019 0.0015 0.0029 

K_xrf 0.066 0.066 0.10 0.098 

K_ion 0.050 0.056 0.089 0.090 

Se 0.0099 0.0036 0.024 0.0048 

Si 0.14 0.071 0.29 0.097 

Na_xrf 0.048 0.049 0.086 0.072 

Na_ion 0.086 0.082 0.122 0.110 

Ti 0.0027 0.0031 0.0049 0.0053 

V 0.0012 0.0010 0.0017 0.0014 

Zn 0.033 0.033 0.059 0.043 

SOURCE: ACHD, 2011d. 

Existing Data Analyses by ACHD - The ACHD has performed significant ambient and meteorological monitoring in 

the county, including both the Lawrenceville and Liberty Borough areas. They have analyzed this monitoring data by 

performing a PMF analysis of measured concentrations of ambient speciated data collected at the Liberty Borough 

site, also known as the SAHS site and at the ACHD's Lawrenceville office site. The details of the PMF analysis will 

not be repeated here since they are well documented in the report (ACHD, 2011d). 

The PMF is a multivariate factor analysis that analyzes a set of speciated ambient data and develops a set of factor 

species profiles and their associated factor concentrations. An analyst then uses wind direction data, measured 

source species profiles and emission inventories to interpret which sources are represented by the factors. The PMF 

tool is described in the PMF users manual (EPA, 2008d). The ACHD also performed a Conditional Probability 

Function (CPF) of the wind direction data at the monitor atop the SAHS. It shows the frequency of wind directions 

associated with the highest factor sums for each factor category in the PMF performed at the SAHS site. The 

analysis shows more detail on the wind directions associated with high concentrations than could be learned from a 

wind rose. The PMF and CPF analysis is summarized in the ACHD report and the details will not be repeated here. 

B. LIMITATIONS OF EXISTING DATA AND ANALYSES 

The speciation measurements, PMF analysis and emissions inventory estimates offer a rich data and analysis set to 

support "first order" estimates of the impacts of important source types on air quality in the NAA. However, as 
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discussed below, there are limitations to these analyses that limit attempts to provide quantitative source impact 

estimates based on data measurements and emissions estimates alone. 

Measured Data - It is important to recognize the origin and status of the measured data used in these analyses. 

ACHD conducted the PMF analysis with speciation data from the PM2.5 Speciation Network. The data was not 

adjusted using the SANDWICH technique to account for the numerous biases and idiosyncrasies that are known to 

create differences between the FRM-measured PM2.5 mass and the analyzed components reported in the PM2.5

Speciation Network. The sum of measured species is almost always less than a co-located FRM instrument due to 

the net effect of these biases and the fact that non carbon organic matter and oxide-related oxygen are not 

measured. The SANDWICH technique uses the speciation data to provide estimates of PM2.5 components as they 

might be measured by the PM2.5 FRM (Frank, 2006). The implication is that the sum of the species for unadjusted 

data cannot be quantitatively compared to a FRM-measured concentration since the mass and relative amounts of 

each species and their totals would likely change after the adjustment. The unadjusted mass averaged about 10 

percent less than the PM2.5 mass at the Liberty site during the 2005-10 timeframe. 

PMF Analysis - The PMF analysis indicates likely sources and their relative importance to the average PM2.5

concentrations because it groups species into source-related "factors" that tend to cluster together across a number 

of sampling days. It provides an indication of the relative importance of these groups to average PM2.5 air quality. 

However, an important limitation of this PMF analysis affects its use to help understand the source contributions on 

the specific days with the highest PM2.5 FRM-measured mass concentration. 

The ACHD's PMF analysis was run on all days (not just the high days). Table V-3 shows that PMF only accounts (on 

average) for about 60 percent of the measured mass at the Liberty Site on the high PM2.5 days. While the source 

types will not likely change drastically, their relative contributions to the sum of the measured species will likely 

change. Therefore, it is not advisable to attempt to relate PMF factors (and their inferred source characteristics) to 

PM2.5 FRM concentrations on high days in a quantitative way. 

Note also that the PMF was run on all data, but the CPF was run on the 25 percent highest days only. There are 

likely some differences in the wind direction between the "typical" and "high" days. Note that the average measured 

species and PMF-modeled species concentrations are very close in value since the PMF provides a good fit to the 

measured data "on average." TS|Pechan used unadjusted speciation data in this analysis to maintain consistency 

with the PMF analyses. (Note: ACHD has recently rerun some of the PMF analyses on high days, by season and 

during periods of lower industrial activity. These expanded analyses have not shown any large differences in the 

conclusions identified in the September PMF report (ACHD, 2011b)). 

Speciated Background Data - PMF accounts for essentially all of the speciated mass when averaged over all data 

points - low as well as high. For example, the PMF tool "groups" measured species into "factors". These factors may 

reflect only local sources, but may also include transported mass from similar sources upwind of the local source(s) 

with which they are associated. There is no way for the PMF analysis to distinguish among local and transported 

mass from similar sources if they are chemically similar and if the transport plume crosses over the local source. 

TS|Pechan identified an upwind monitor with speciation data at Hillman State Park, located about 30 miles westnorthwest of the Liberty monitor. It is in a sparsely populated wooded area with active farms about 1 mile west. 

However, it may be influenced by sources in the Steubenville, OH area, including steelmaking facilities about 13 

miles to the west-southwest or sources farther away in Wheeling, WV. The relative locations of the ambient 

monitoring sites and sources in areas downwind of the Liberty site are illustrated in Figure V-3. The levels at Hillman 

(a.k.a. Florence) are similar to data at the S. Fayette site in western Allegheny County. Selected 2005-8 speciation 

data from the Hillman site is tabulated in Table V-4 along with corresponding data from Liberty (aka SAHS) and 

Lawrenceville sites. As expected, PM2.5 and many of the species are highly enriched above values at the Hillman 

site, because of the close proximity of industrial sources to the Liberty site. The Lawrenceville data are roughly midrange between the Liberty and Hillman values. 
 2007 and 2014 Liberty-Clairton PM2.5 Nonattainment Area Emission Inventories and Source Assessment Analysis 

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Table V-3. PMF Results for Highest 20 Days Measured at Liberty Site, Liberty - Clairton NAA 

PMF Results for Liberty Site Factors and Their Key Species (Highest Days in 2005-2010)

Date 

PM2.5

(POC1) 

Factor 

Sum Cr Ni (#1) 

OC EC SO4

(#2) Se (#3) 

OC EC Cu 

(#4) NO3 (#5)

EC OC S 

(#6) 

S04 OC EC 

(#7) EC Si (#8) K (#9) 

Chlorin

(#10) 

9/13/2005 89.0 30 6.44 3.60 1.80 1.76 1.65 5.82 6.44 -0.20 -0.20 -0.10/31/2005 83.1 71 1.54 11.69 17.03 1.81 -0.20 2.56 1.54 5.37 -0.20 29.8/4/2007 62.6 20 3.64 0.51 0.87 0.84 1.06 1.51 3.64 2.10 1.65 0.04/18/2008 56.0 42 1.00 0.43 1.12 1.64 1.16 3.59 1.00 2.63 3.45 22.2/17/2007 54.1 50 1.30 2.11 3.05 0.20 3.14 -0.20 1.30 3.34 2.34 32.5/29/2006 54.1 29 2.73 6.69 1.50 1.73 1.24 4.87 2.73 1.06 2.82 1.11/12/2005 48.8 32 0.32 5.58 4.19 1.90 0.49 1.65 0.32 3.33 1.50 12.8/28/2007 47.3 21 5.53 1.30 0.34 2.45 0.64 0.94 5.53 0.97 0.56 -0.07/7/2010 47.1 23 2.50 2.95 1.70 2.04 0.25 4.42 2.50 1.36 3.08 0.7/17/2008 45.1 21 3.78 2.18 1.28 1.06 1.14 2.80 3.78 1.16 0.86 0.7/10/2006 45.1 19 4.29 2.90 0.59 0.72 0.28 1.59 4.29 1.48 1.35 0.09/3/2008 45.0 25 2.51 3.93 0.75 1.55 1.58 5.87 2.51 2.82 0.11 0.2/22/2006 44.7 31 0.84 3.53 1.04 2.73 3.09 2.99 0.84 1.15 2.18 11.9/8/2006 44.4 30 3.10 3.92 1.62 2.21 1.02 3.97 3.10 5.95 0.39 3.7/29/2008 44.4 21 3.06 3.88 1.30 1.78 0.76 2.31 3.06 1.03 2.48 0.9/21/2008 43.8 29 2.68 1.73 0.40 1.43 1.60 4.06 2.68 5.33 2.96 4.9/19/2005 43.0 29 3.69 3.98 9.94 1.10 0.75 2.30 3.69 1.77 -0.10 0.7/21/2005 42.7 21 3.36 2.62 1.21 1.11 1.16 2.64 3.36 3.03 0.39 0.08/30/2010 41.8 20 1.94 2.91 1.02 1.42 0.64 5.18 1.94 1.19 1.14 0.4/2/2010 41.2 33 -0.17 3.08 1.68 2.87 -0.20 4.44 -0.17 1.78 3.24 10.Average 51.2 29.9 2.7 3.5 2.6 1.6 1.1 3.2 2.7 2.3 1.5 62 Std Dev 26.29 24.85 3.32 4.91 7.98 1.34 1.76 3.32 3.32 3.31 2.49 20.SOURCE: ACHD, 2011d. 
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Figure V-3. Location of Monitors in Areas Upwind of Liberty (SAHS) Air Monitoring Site 

SOURCE: EPA, 2011a 

Table V-4. Comparison of Species Concentrations at Hillman, Liberty and Lawrenceville Sites (μg/m3) 

2005-2008 PM2.5 Speciation and FRM Enrichment 

Hillman Lawrenceville Liberty Lib-Hill 

PM2.5 Mass (FRM) 13.0 15.1 19.4 6.4 

Ammonium 1.53 2.10 2.72 1.2 

Nitrate 0.84 1.58 1.42 0.58 

Sulfate 4.82 5.22 5.91 1.1 

Elemental Carbon 0.68 0.80 2.44 1.8 

Organic Carbon 2.46 3.80 4.24 1.8 

arsenic 0.0015 0.0021 0.0053 0.004 

aluminum 0.019 0.028 0.0371 0.018 

bromine 0.0036 0.0048 0.011 0.007 

calcium 0.028 0.045 0.046 0.019 
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2005-2008 PM2.5 Speciation and FRM Enrichment 

Hillman Lawrenceville Liberty Lib-Hill 

chromium 0.0022 0.0043 0.0023 0.000 

chlorine 0.0081 0.016 0.29 0.286 

iron 0.065 0.16 0.11 0.044 

lead 0.0048 0.010 0.017 0.012 

manganese 0.0028 0.0064 0.0032 0.000 

nickel 0.0009 0.0020 0.0018 0.001 

magnesium 0.0051 0.0054 0.0083 0.003 

selenium 0.0024 0.0033 0.0085 0.006 

titanium 0.0028 0.0045 0.0038 0.001 

vanadium 0.0015 0.0016 0.0019 0.000 

silicon 0.065 0.082 0.16 0.090 

zinc 0.018 0.036 0.034 0.016 

potassium 0.050 0.084 0.077 0.026 

Total Measured 10.6 14.0 17.5 6.9 

EC and OC at Lawrenceville are 2005-10. 

S. Fayette FRM (12.6 microgram per cubic meter (μg/m3) average for 2005-2008), consistent with the Hillman State Forest 

(Florence) FRM (13 μg/m3). 

SOURCE: EPA, 2011a. 

The relatively high PM2.5 and species concentrations for PM2.5 and species mass at the Hillman site (upwind of the 

Liberty site) suggests that there is a non negligible "background" impacting the Liberty-Clairton area. A rough 

approximation based on Table V-4 is that the average PM2.5 excess at Liberty is 6-7 μg/m3 over the Hillman and S. 

Fayette areas. Similarly, NH4, SO4, and NO3 combined are enriched 3 μg/m3 and EC and OC combined are enriched 

3.5 μg/m3 at Liberty over the Hillman area. The enrichment could be more if NH4, SO4, NO3 or carbon transported 

from the Ohio River Valley (ORV) impacts Hillman more than Liberty. Qualitatively, it is likely that any impact of 

transport from Steubenville (or industrial areas to its south) on Liberty-Clairton will be less compared to its impact on 

Hillman, since for example Steubenville is over 40 miles from Liberty Borough, but only 13 miles from Hillman State 

Forest. Thus, the background coming into Liberty is likely to be lower and the impact of local sources higher than the 

enrichment in Table V-4 suggests. 

Thus, the concentration at the Liberty site (compared to Hillman State Forest) is enriched by an average of at least

6.9 μg/m3 over this 4 year period due to local sources. An analysis of background concentrations, incoming wind 

flow, and transport patterns from upwind sources is needed if measured air quality alone is used to estimate 

background. 

C. MICROINVENTORY OF LOCAL SOURCES IN LIBERTY BOROUGH AND 

INVESTIGATION OF OPERATIONAL IRREGULARITIES, TRENDS, DAILY AND 

DIURNAL EMISSIONS VARIABILITY 

Point, area and mobile sources in the immediate vicinity and upwind of the Liberty Monitor are more likely to impact 

that monitor than similar sources located several boroughs distant. Therefore a “microinventory” in the Liberty 

Borough monitoring site vicinity was conducted to tabulate land use, terrain and 2007 Emissions Inventory data 

spatially. 

A microinventory is a compilation of sources in the vicinity of an air monitoring station, spatially allocated into small 

grids. This microinventory conducted in this study is based loosely on the microinventory concept used by EPA and 

others for total suspended particulate and PM10. Its size and shape correspond to the NAA for area and mobile 

sources but point sources up to 10miles distant are considered. For high priority source categories of interest, the 
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microinventory may include information on source operating patterns and day-to-day emissions variability due to 

upsets/malfunctions and intermittent operation. This microinventory facilitates comparison of the 2007 inventory to 

PMF and other receptor-based analyses to support evaluation the sources’ potential to impact PM2.5 air quality and 

setting priorities for evaluating the 2007 emissions (Pace, et al., 1978). 

Google Earth and other databases were used to locate sources, assign land use and describe terrain. The 

microinventory utilizes the 2008 inventory, visual inspection of the selected areas near the Liberty monitor and 

interviews with ACHD staff. TS|Pechan has recorded and summarized results in spreadsheets and maps. Although 

this is an area and mobile source review, point sources, especially those source types that were implicated in the 

PMF analysis are included in the microinventory. The microinventory began with an intensive driving tour to inspect 

the Liberty NAA and perimeter. Results of the driving tour are below. 

Inspection of the Liberty-Clairton NAA - On October 5 and 6, 2011, TS|Pechan Senior Associate & Vice President, 

Jim Wilson, and Tom Pace, Consultant to TS|Pechan, accompanied Tony Sadar, Jason Maranche, and Shaun Vozar 

of the ACHD on an extensive driving tour of the area. A map of the main routing covered is shown in Figure V-4. 

The purpose of the tour was to view as much of the area as possible to observe sources in and near the NAA and to 

observe the neighborhood around the monitor to identify sources that might be unduly influencing the measured 

PM2.5 or selected species. Specifically, we attempted to augment Google Earth views to clarify the types of land 

cover, terrain and potential point, area and mobile sources. In this tour, activities and sources that we did not 

observe were as important as what we did observe. For example, we looked for: 

 Signs or indications of open burning (household waste, yardwaste, agricultural waste); 

 Firewood stored and ready to burn this winter; 

 Small sources (asphalt batch, cement); 

 Traffic levels and proximity to the Liberty site; 

 Truck stops and areas where trucks could gather or idle; 

 Rail switchyards; 

 Unpaved roads and parking areas, cropland; 

 Signs of logging or fires for resource management; 

 General characterization of types and availability of restaurants; and 

 Proximity of above to the monitor and unusual activities around the monitor. 
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Figure V-4. Liberty-Clairton Tour Routing for October 5 and 6, 2011 

SOURCE: Maranche, 2011. 

Tour Observations- Important Sources and Emphasis in the Emissions Inventory 

 The diesel truck and tugboat operation in Clairton Works is under-represented in their inventory. 

 There is much less commercial/residential/agricultural diesel equipment operating in the Liberty-Clairton 

area than observed in other areas of the county. 

 Observed little land disturbance or other nonindustrial fugitive dust generation. 

 Observed less commercial charbroiling in the area than in other parts of Allegheny County. 

 Open burning was likely low but not "zero". 

 Residential wood burning is a significant source, based on observed wood storage at homes. 

 County-level allocation to grids in the NAA by the current population approach must be reviewed: cooking, 

open burning, fugitive dust, agricultural lands, quarries, etc., would likely be overestimated in the area if 

allocations were made on population. 

 Clairton Works is a point source and is thus not included in the review; however, it is obviously the most 

important source affecting the NAA and the Liberty air quality monitoring site by far. 

 Above conclusions are based on the site tour and preliminary review of the emissions inventory. 
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D. SOURCE IDENTIFICATION, LOCATION, AND EMISSIONS TABULATION 

Source Emissions, Locations – Tables V-5, V-6, and V-7 summarize the microinventory for point, area and mobile 

source emissions. Note that the site tour was a part of the microinventory. Table V-5 describes the important point 

sources and tabulates their distance and direction from the Liberty monitor. Tables V-6 and V-7 tabulate these 

source emissions as well as important area and mobile source categories. Table V-6 includes only those sources 

within the NAA and Table V-7 includes those in the rest of the county, but outside of the NAA. Only point sources 

within 10 miles (16 kilometers) are included as they are the ones most likely to impact the Liberty Monitor. The large 

SO2 emissions outside of the 10 mile cutoff come almost entirely from the Orion Cheswick electricity-generating unit 

(EGU) which is almost always downwind of the Liberty area. It is clear from the microinventory that the Clairton 

Works is by far the most important source, but other sources just outside the NAA (US Steel's Irvin Plant and USS 

Corporation's Edgar Thompson Plant) may be relevant to air quality at the Liberty monitor as well. 

Land Use/Cover – “The Liberty-Clairton Area is made up of complex river valley terrain, approximately 3 miles wide 

by 5 miles long. It includes a 4-mile winding portion of the Monongahela River and is bordered by the Youghiogheny 

River to the east. The area includes rural land, densely populated residential areas, and industrial facilities. River 

valleys lie at 718 feet in elevation (mean sea level), while adjacent hilltops can be greater than 1,250 feet” (ACHD, 

2011d). 

Land use in the area - mixed, a combination of wooded/grassland/water, residential/strip commercial and industrial. 

Using Google Earth, TS|Pechan tabulated the land use into the above categories: 

Wooded, grassland, water 48 percent 

Residential, Strip Commercial 42 percent 

Industrial 10 percent 

Industry was located at least 1.5 miles from the SAHS monitor. 

Terrain - Clairton Works stretches several miles along the Monongahela River at an elevation of 740-760 feet above 

mean sea level. Everything else in the NAA is on terrain above it, except several industries (e.g., Koppers, Guardian, 

Eastman) also along the river bank. Clairton City rises to the west to an elevation of just over 1,000 feet. Across the 

river, the land rises rapidly to a shelf with elevations ranging from over 1,150 feet in Lincoln Borough (to the East), 

1,050 feet at the Liberty Monitoring site, 950 feet in Liberty Borough (to the Northeast), 860 feet in Glassport (to the 

north) and almost 1,200 feet in Port Vue (to the north). There are two cuts in the escarpment that facilitate the 

transport of Clairton Works' emissions onto the upper shelf and the monitoring site. 
 2007 and 2014 Liberty-Clairton PM2.5 Nonattainment Area Emission Inventories and Source Assessment Analysis 

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Table V-5. Point Source Facilities Believed to Contribute to Liberty-Clairton PM2.5 Nonattainment(a)

Plant ID Facility Name Processes 

Degrees 

from 

North 

Kilometers 

from Liberty 

Monitor 

Miles fro

Libert

Monito

4200300027 Koppers Inc. - Clairton Plant Crudes, Carbon Black, Tar fr Coke Waste 218 2.4 4200300032 USS - Clairton Works Coke Batteries, Quench Towers 205 2.7 

4200300265 Eastman Chemical Resins, Inc. Plastics and Resin Mfg 204 7.5 4200300342 Guardian Industries Corp. Floreffe Glass Melt Furnace 207 8.7 4200300228 Precoat Metals, Div of Sequa Coatings Metals Coating 85 2.2 4200300203 US Steel Corporation - Irvin Plant Steel Reheat Furnace, annealing 290 3.0 4200300202 USS Corporation - Edgar Thompson Plant Steel Making - BOP, Finishing 7 7.8 4200300144 Bellefield Boiler Plant Steam Boiler - Coal 332 14.7 4200300009 Pittsburgh (Iron City) Brewing Brewery 331 17.1 14200300073 Pittsburgh Allegheny County Thermal, Ltd. EGU 319 17.4 14200300024 Bay Valley Foods, LLC Coal-fired Boiler 325 17.4 14200300389 NRG Energy Center, Pittsburgh Steam Boiler - Coal 319 18.2 14200300164 GE Consumer Products, Lighting Glass Fixture Mfg, Simplex Furnace 283 19.8 14200300003 Universal Stainless and Alloy Products EAF, Steel Alloy Mfg 281 20.8 14200300158 Orion Power Midwest - Brunot Plant EGU - Gas 316 21.6 1

(a)ACHD, 2011e. 
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Table V-6. 2007 Emissions Summary for Liberty-Clairton PM2.5 NAA 

Point Source Facilities Inside the Liberty-Clairton NAA(a) PM2.5- PRI SO2 NH3 HCl Cl Ni Pb Se AKoppers Inc. - Clairton Plant 6.1 0.3 0.0USS - Clairton Works 1,950.0 1,740 200 94.1(b) 1.3 .3 Eastman Chemical Resins, Inc. 16.8 4.4 0.1 4.6 Guardian Industries Corp. Floreffe 6.1 83 0.0 0.2 Total Point Source Emissions Inside the Liberty-Clairton NAA (a) 1,993 1,827 200 96.0 1.3 .3 0.0 0.2 Area Source Emissions Inside the Liberty-Clairton NAA(c)Residential Wood Comb. (Stoves, Fireplaces, Boilers) 15.7 0.4 0.9Industrial Coal Combustion 0.0 31.4 0.0Commercial Coal Combustion 0.0 0.0 0.0Open Burning 1.0 0.0 0.0Commercial Cooking 4.1 0.0 0.0Residential Heating - Gas, Oil and Coal 3.0 0.3 0.2Fugitive Dust (paved, unpaved, construction) 5.2 0.0 0.0Fertilizer Application 0.0 0.0 2.2Other Area Source Emissions 0.6 16.5 0.8Total Area Source Emissions Inside the Liberty-Clairton NAA 29.7 48.6 4.3Mobile Sources Inside the Liberty-Clairton NAA (c)HDDV 5.7 0.3 0.2Railroads 2.4 0.8 0.0CMV 6.4 12.4 0.0Non Road Diesel 4.3 3.9 0.0Highway Gas Vehicles 4.2 1.8 4.5Non Road Gas 1.9 0.1 0.0Other Mobile Source Emissions 0.0 0.0 0.2Total Mobile Source Emissions Inside the Liberty-Clairton NAA 24.9 19.4 4.8Total Emissions Inside the Liberty-Clairton NAA 2,048 1,895 209(a)ACHD, 2010. (b)HCl for Clairton Works is “adjusted 0.0” since 2004. (c)ACHD, 2011e. 
 2007 and 2014 Liberty-Clairton PM2.5 Nonattainment Area Emission Inventories and Source Assessment Analysis 

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Table V-7. 2007 Emissions Summary for Sources in Allegheny County, PA - Outside the Liberty-Clairton PM

Facilities w/in 16 km (10 miles) of SAHS Monitor, but Outside the Liberty-Clairton PM2.5 NAA* PM2.5-PRI SO2 NH3 HCl* Cl* Ni* Pb* SePrecoat Metals, Div of Sequa Coatings 0.8 0.1 US Steel Corporation - Irvin Plant 51 456 0.8 23.3 0.33USS Corporation - Edgar Thompson Plant 881 1,689 0.5 13.3 0.19 0.1 0.4 Bellefield Boiler Plant 77 707 31.1Pittsburgh (Iron City) Brewing 2.4 15.4 0.7Pittsburgh Allegheny County Thermal, Ltd. 2.8 0.2 Bay Valley Foods, LLC 60 543 22.9 0.0NRG Energy Center, Pittsburgh 2.6 0.2 GE Consumer Products, Lighting 20 0.1 1.7Universal Stainless and Alloy Products 18 13 0.2 0.0 Orion Power Midwest - Brunot Plant 2.3 3.9 0.2McConway and Torley 16 4.6 0.1 0Total Point Source Emissions Outside the Liberty-Clairton NAA (< 10 miles from SAHS)* 1,066 3,434 1.5 91.2 0.5 0.4 2.1 0Total Point Source Emissions Outside the Liberty-Clairton NAA (> 10 miles from SAHS)* 1,188 35,010 362 1,409 2.5 4.0 2.5 0Area Source Emissions Outside the Liberty-Clairton NAAResidential Wood Comb. (Stoves, Fireplaces, Furnaces) 1,517 32 89Industrial Coal Combustion 117 7,467 2.4Commercial Coal Combustion 58 3,702 1.2Open Burning 0 0.0 0.0Commercial Cooking 54 0.0 12.3Residential Heating - Gas, Oil and Coal 166 17 12.1Fugitive Dust (paved, unpaved, construction) 1,286 0.0 0.0Fertilizer Application 0 0.0 132Other Area Source Emissions 304 1,672 62Total Area Source Emissions Outside the Liberty-Clairton NAA (**) 3,500 12,890 311Mobile Source Emissions Outside the Liberty-Clairton NAAHDDV na na naRailroads 61 20 1CMV 105 51 4Non Road Diesel 277 249 2.8Highway Gas Vehicles na na naNon Road Gas 112 6.5 2.1Other Mobile Source Emissions 27 74 naTotal Mobile Source Emissions Outside the Liberty-Clairton NAA (**) 582 401 10Total Emissions Outside the Liberty-Clairton NAA 6,336 51,735 685*ACHD, 2010. **ACHD, 2011e. 
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E. CONCENTRATION SPIKES POTENTIALLY INDICATING UPSETS AND 

EQUIPMENT MALFUNCTION 

1. Upsets and Malfunctions 

Inspection of the data shows that many of the days with highest concentrations are associated with a large increase 

in a relatively few species. This is especially true for chlorine as previously discussed. Days with a spike in one or a 

few species may be related to a process upset or equipment malfunction instead of atmospheric conditions 

conducive to poor dispersion. A simple screening tool is suggested to identify the species which tend to have the 

most very high values. The presumption is the species with the highest ratios of “highest 25 percent of days” to 

“lowest 75 percent of days” would be most likely to be having upsets or malfunctions on the days with high ratios and 

the upsets/malfunctions would be occurring in the processes emitting those species. Based on Table V-8, the most 

likely species associated with upsets, malfunctions or intermittent sources are: chlorine, arsenic, EC, lead, bromine, 

selenium, OC, NH4, and silicon. Sorting the species concentration database can help identify specific days or time 

periods when one or more of these species is high. Note, a review of breakdown reports on hand at ACHD failed to 

show any strong indications of process breakdowns associated with the high 20 days, but other high days or a 

detailed investigation may provide additional data (Sadar, 2011a; 2011b). Likely sources (not an exhaustive list), 

based on the emissions inventory, wind vectors from CPF and SPECIATE (EPA, 2011b) are as follows: 

Ammonia - Solid Waste Combustion, Gas Vehicle Exhaust, Residential Gas, Coal & Wood Combustion 

Arsenic - Coke, Steelmaking, Sintering Furnace, Coal Burning, Glass Furnace 

Bromine - EAF, Sintering, Municipal Waste Combustion, Residential Natural Gas, Coal Combustion, Coke 

Chlorine - Muni Waste, Sintering, Open Biomass Fires, Res. Nat Gas, Wood, EAF, Foundries 

Elemental Carbon - Diesels, Coke, Nat. Gas Comb., Res Coal, Oil, Wood Comb. Charbroiling 

Lead - Muni Waste, EAF, Steel Mfg, Foundries, Glass Furnace, Sintering, Coal Comb. 

Organic Carbon - Cooking, Res Wood Comb, Gas Vehicle High Emitters, Open Biomass Fires, Diesels, Natural Gas 

Comb., Charbroiling, Steelmaking, Coke, EAF 

Selenium - Coal Comb., Residential Nat Gas, Sintering, EAF, Glass Furnace 

Silicon - Crustal Dust, Coal Comb., Coke, Solid Waste Comb., Steelmaking, EAF, Nat Gas 

Table V-8. Measured Species at Liberty Site for High and Low Days 

 

High 25% 

(μg/m3) 

Low 75% 

(μg/m3) 

Ratio High 

25% to Low 

75% (μg/m3) 

Total of Measured Species 32.06 14.22 2.3 

Cl 0.80 0.074 10.7 

Se 0.025 0.005 4.8 

Pb 0.040 0.009 4.5 

As 0.011 0.003 4.5 

Elem Carbon 5.19 1.16 4.5 

Br 0.027 0.006 4.3 

Si 0.31 0.085 3.6 

Organic Carbon 8.91 3.02 3.0 

Zn 0.066 0.023 2.9 

NH4+ 4.72 1.73 2.7 

K_ion 0.094 0.037 2.5 

Na_xrf 0.089 0.035 2.5 

Ti 0.005 0.002 2.5 

SO4 9.55 3.94 2.4 

Al 0.063 0.026 2.4 
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High 25% 

(μg/m3) 

Low 75% 

(μg/m3) 

Ratio High 

25% to Low 

75% (μg/m3) 

Ca 0.078 0.034 2.3 

K_xrf 0.11 0.053 2.0 

Na_ion 0.13 0.072 1.8 

V 0.002 0.001 1.7 

Fe 0.14 0.085 1.7 

Cu 0.010 0.006 1.6 

Mn 0.004 0.003 1.5 

NO3- 1.68 1.17 1.4 

Ni 0.002 0.002 1.0 

Cr 0.002 0.002 0.9 

SOURCE: ACHD, 2011d. 

2. Operating Patterns 

No sources having unusual seasonal or day-to-day operating patterns were identified. Weekday - weekend patterns 

were an output of the PMF analysis. Of the 12 factors, the ones with weekend - weekday patterns at the Liberty site 

are: 

PMF - 4 (Gas Vehicles and Metals Processing) slightly lower on weekends; 

PMF - 5 (Nitrate) slightly lower on weekends; 

PMF - 7 (Sulfates) slightly lower on weekends; 

PMF - 8 (Coal/Coke) slightly lower on weekends; 

PMF - 9 (Burning) higher on weekends; 

PMF - 11 (Steel Mfg) slightly lower on weekends; and 

PMF - 12 (Crustal) slightly lower on weekends. 

F. DATA SYNTHESIS 

TS|Pechan has compared and contrasted the micro-inventory of the area near the Liberty air monitoring site with the 

measured speciation data and results of the PMF at the Liberty monitoring site. The PMF results and species at 

Liberty and Lawrenceville were examined along with species concentrations at the upwind Hillman State Forest site. 

TS|Pechan also considers source locations, transport times and secondary pollutant formation rates along with PMF 

analyses and secondary particle concentrations at Liberty, Hillman, and Lawrenceville to infer the likelihood that 

precursor emissions in the NAA are important contributors to PM2.5 nonattainment. 

The analysis emphasizes those categories and sources that have the most influence on PM2.5 concentrations, with 

particular emphasis on e.g., carbon emitting sources, ammonia, SO2, and chlorine. This section of the report is 

organized to facilitate discussion of the important sources and indicator species. 

TS|Pechan will estimate the impacts of major source groups and local versus regionally transported impacts to the 

extent possible using these data. Unusual seasonal patterns and concentration spikes by a particular species 

provide clues that some upset/malfunction conditions exist in the area. TS|Pechan also investigated the PM2.5

concentrations on the highest days to determine what types of sources are responsible for those high PM2.5

concentrations. 

This analysis is limited in the firmness of its conclusions for several reasons. First, secondary SO4, NO3, and OC 

particle formation is complex and should be modeled using a chemical transport model such as CAMX; also, there is 
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no way to distinguish between primary and secondary ambient carbon. Modeling is needed to distinguish between 

primary and secondary ambient carbon as well as the relative contributions of locally-emitted and transported 

particles. Second, an unambiguous background site with speciation data is not available. Third, the PMF, while 

excellent work, was run on all data (not just the high days) and it was run on unadjusted PM2.5 species data. Thus, a 

full quantitative estimate of local source impacts must include the atmospheric modeling (using CAMX) that will be 

conducted by others later in this overall project. 

1. Potassium - Residential Wood Combustion, Cooking, and Open Biomass Burning 

Potassium (K) is the most commonly used tracer specie for wood smoke. Other tracers do exist but they require 

special analyses and some require special sampling. Table V-9 suggests that the measured K has no discernable 

seasonal pattern, whereas wood burning would be expected to have a strong wintertime pattern. The PMF analysis 

does suggest a strong wintertime pattern in its burning factor (PMF - 9) and 60 percent of the measured K is 

associated with PMF - 9. This K is very likely from wood burning. However, other sources (with a stronger 

summertime influence) may be responsible for the additional K. Possibilities for this K source include the Industrial 

Carbon Factor (PMF - 2), which has a strong summertime pattern and is the second highest K component in the PMF 

run, and transport. PMF - 2 is associated with winds from the direction of the Clairton Works and coke dust is also a 

source of K. Also, it is noted that PMF - 9 was slightly higher on weekends, suggesting recreational fireplace usage. 

Table V-9. Monthly Variability in Measured K and PMF Factors 2 and 9 

Month 

Potassium, K 

(Measured) 

Burning Factor 

(PMF - 9) 

Industrial Carbon Factor 

(PMF - 2) 

January 0.069 1.34 0.70 

February 0.065 1.21 1.03 

March 0.065 1.15 0.70 

April 0.067 1.06 0.82 

May 0.068 0.85 1.17 

June 0.062 0.74 1.12 

July 0.082 0.70 1.30 

August 0.052 0.70 0.95 

September 0.057 0.70 1.04 

October 0.064 0.79 1.35 

November 0.079 1.34 0.94 

December 0.067 1.21 0.67 

SOURCE: ACHD, 2011d. 

The CPF wind analysis confirms that an area source like wood burning is very much involved with Factor 9, since it 

showed the high Factor 9 days to be associated with winds from all directions. Cooking is also a source of K, but the 

emissions inventory and site tour both suggest that cooking is not a significant source. This suggests that much of 

the K is likely related to local wood burning. Coal burning is also a source of K but there is no evidence of significant 

residential coal use. 

Another K source could be transport. Table V-4 showed that the concentration of K at the Hillman site (which is a 

rough indicator of the characteristics of air coming into the Liberty area from the west to southwest) was roughly twothirds (66 percent) the value of the K concentration at Liberty from 2005-2008. Some of this K is likely to transport 

into Allegheny County. Another point of note, there are virtually no very high K measurements in the speciation data 

(after July fireworks data were purged), suggesting that the K is not coming from occasional process upsets or 

equipment malfunctions. This would also seem to rule out impacts from wildfires and managed burning. 
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Tentatively, it is likely that transport from outside Allegheny County, industry and/or other sources comprise no more 

than 40 percent of the measured K because PMF- 9 accounts for 60 percent of the measured K and there is no 

consistent wind vector associated with PMF - 9. It appears from the review of the K found in other PMF factors and 

other species in PMF - 9 (~ 0.4 SO4 and NH3) that the portion of PMF - 9 related to local wood burning is probably 0.8 

μg/m3 on average. The remaining K that was associated with factors other than wood smoke (PMF - 2 and others) 

may be partly transport. We saw very little evidence of open burning of logging, yard waste or land clearing debris to 

suggest that this might contribute to the biomass combustion. Thus, it appears that the local wood burning is due to 

woodstoves, fireplaces, recreational fires and a few outdoor hydronic furnaces. 

2. Crustal Materials and Fugitive Dust 

Several species are often found in ambient air (Al, Ca, Fe, Si, Ti) that are associated with crustal matter. This crustal 

matter is usually emitted locally as fugitive dust from sources such as unpaved roads, construction and agricultural 

tilling which disturb the earth, and to a lesser extent dust from parking lots, paved roads, and off road recreational 

vehicles. In the Liberty-Clairton area, traditional sources of fugitive dust are not abundant owing to lack of farming 

and construction and a mature road system. However, in addition to fugitive dust, these elements can be emitted 

from other sources - Titanium is a paint pigment and is used in high performance alloys, calcium comes from mining 

and cement manufacturing, coal combustion and electric arc furnaces, aluminum can come from smelting operations, 

Fe is emitted in steelmaking and Si is abundant in coal. 

Table V-2 shows there is about twice as much Si measured at Liberty as Lawrenceville, but Lawrenceville is a more 

active area and appeared to have more fugitive dust sources. Silicon is also enriched at Liberty (compared to 

Lawrenceville) by twice as much as the enrichment of other crustal elements. Since silicon was identified in PMF- 8 

in the Liberty PMF analysis and was attributed to coke/coal dust, the PMF - 8 wind vector (from the CPF analysis) is 

from the south-southwest, Si is enriched at Liberty (over Lawrenceville) and Si is abundant in coke dust, it is 

reasonable to conclude likely that the excess Si at Liberty is associated with the Clairton Works. 

3. Elemental and Organic Carbon 

A summary of the composition of all the Liberty PMF factors is shown in Table V-10. Elemental and organic carbon 

combined account for almost 40 percent of the measured species, so they are clearly important. This is just slightly 

less than the average contribution of (NH4)2SO4. In the PMF analysis, 8 of the 12 Factors (2, 4, 5, 6, 7, 8, 9 and 10) 

are associated with almost all of the carbon and SO4 at the Liberty site. Five of these factors, [2, 6, 7, 8 and 10) are 

associated at least in part with emissions from the Clairton Works. Also, as shown in Tables V-5, V-6, and V-7, 

Clairton Works emits all of the local SO2 in the wind sector associated with the SO4 factor so PMF-7 may be partly 

due to Clairton Works’ emissions. 

The factors (2, 6, 8 and 10) are clearly related to Clairton Works because of the CPF wind directions associated with 

these factors and the composition of the factors. The PMF μg/m3 for factors 2, 6, 8, and 10 are 1.9, 2.9, 0.6 and 1.0 

μg/m3, respectively, for a total 6.4 μg/m3 mostly attributable to Clairton Works. Of this, 4.6 μg/m3 is EC, OC, and 

trace (1.8 is NH4, SO4, and NO3). PMF-7 is also from the Clairton Works direction but it is almost all ammonium 

sulfate. Note some portion of these sources' impacts may be from long range transport from the direction of the 

Clairton Works. 

From Table V-4, the EC at Liberty is mostly local since EC at the Hillman site is only 30 percent of the EC measured 

at Liberty. However, OC at Liberty may be significantly affected by transport since the OC at Hillman is 60 percent as 

high as the OC at Liberty. 
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Table V-10. PMF Results at Liberty Site for All Days with Measured Speciation Data (2005 - 2010) 

Liberty Site PMF Factors 

(2005-2010) 

EC, OC, Trace 

(Mainly 

Primary) 

NH4 NO3

SO4

Wind 

Direction OC EC 

Trace 

Elements NH4 NO3 SO4

Ind Carbon (2) 1.81 0.12 150-225 1.35 0.43 0.03 0.00 0.12 0.00

Gas Vehicle (4) 0.48 0.25 0-225 0.39 0.05 0.04 0.00 0.08 0.17

Nitrate (5) 0.12 1.17 all 0.12 0.00 0.00 0.31 0.87 0.00

Ind Carb & Sulf (6) 1.67 1.20 165-225 0.72 0.89 0.05 0.49 0.00 0.71

Sulfate (7) 0.72 5.18 165-225 0.55 0.15 0.01 1.27 0.00 3.91

Coal/Coke (8) 0.45 0.12 150-225 0.10 0.23 0.12 0.12 0.00 0.00

Burning (9) 0.74 0.40 0-255 0.68 0.04 0.02 0.00 0.14 0.26

Chlorine (10) 0.67 0.36 150-240 0.24 0.20 0.24 0.21 0.00 0.15

Coal/Glass (3) 0.02 0.05 150-240 0.00 0.01 0.01 0.01 0.00 0.04

Metals (1) 0.04 0.03 0-165 0.01 0.01 0.02 0.00 0.03 0.00

Steel (11) 0.21 0.07 0-105 0.12 0.03 0.07 0.00 0.04 0.03

Crustal (12) 0.08 0.01 0-225 0.00 0.00 0.08 0.01 0.00 0.00

Sum (1-12) 7.00 8.96 4.28 2.04 0.68 2.42 1.28 5.26

SOURCE: ACHD, 2011d. 

4. Ammonium Sulfate, Nitrate, and Secondary Organic PM2.5

SO4 and NO3 are formed in the atmosphere from SO2 and NOx, respectively. They are both almost always found in 

the form of NH4, SO4, and NO3. The sum of ammonium sulfate and nitrate at Hillman is 7.2 μg/m3 compared to 10.1 

at Liberty. This suggests that perhaps 70 percent of the ammonium sulfate and nitrate combined at Liberty is from 

transport. However, as much as half of the nitrate may be local and as much as 80 percent of the sulfate may be 

transported. 

SO4 is usually formed in the summer and NO3 is usually higher in the winter. However, Figure V-5 shows a 

surprising amount of (NH4)2SO4 in the winter at Liberty. If there is enough ammonia present, the SO4 and NO3 will be 

fully neutralized, but the sulfur and nitrogen can exist in the form of ammonium bisulfate, or sulfuric or nitric acid if 

there is a shortage of ammonia. Figure V-5 shows the seasonality of these pollutants at the Liberty site. It also 

shows that there is enough ammonia present to fully neutralize the SO4 and NO3 for much of the year, but there may 

be about a 10-20 percent shortage of ammonia in the summer and in December and January to fully neutralize the 

SO4. Clairton Works emits about 30 percent of the SO2 and 70 percent of the NOx emitted in or near the NAA. The 

source emitting 85 percent of the SO2 in Allegheny County in 2007, Orion Power's Cheswick EGU, is 15 miles north 

(upwind). The 2007 emissions reported were prior to the installation of an SO2 scrubber at Cheswick (Post-Gazette, 

2009). 

Ammonium nitrate and secondary organic particles can form quickly if there is sufficient dilution to promote oxidation. 

Even ammonium sulfate can form quickly in a cloud. An example is given of secondary organic aerosol formation 

during a wood smoke episode in Houston (Nocmongcol, et al., 2007). Organic particles can form rapidly in the 

presence of chloride, toluene, and oxygen (Rune, et al., 2001) and in the presence of sulfuric acid aerosol catalysts 

(Limbeck, et al., 1996). Salcedo discusses the rate of nitrate formation in Mexico City (Salcedo, et al., 2006). Also, 

inversions in the Liberty-Clairton area are often associated with light winds and stagnated air masses that provide 

longer times for secondary aerosol formation. The presence of ammonia, SO2, NOx, organic gases, and chlorine 

emissions from the Clairton works (which is "long and thin" in shape, somewhat aiding dilution) into an often foggy 

and stagnant environment makes this a complex system to evaluate. Detailed photochemical modeling may help 

resolve the various interactions and the amount of secondary formation versus transport of secondary particles into 

the area. However, the light winds and fog occurring on many inversion days, coupled with the mix of pollutants 

emitted certainly makes it plausible that there is significant secondary particle formation from Clairton works 

emissions, adding to those transported into the area. 
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Factors 2, 6, 7, 8 and 10 are associated with S or SW winds and combined account for 3/4 (3 μg/m3) of OC (the 

other 1.2 μg/m3 is not associated with S or SW winds). OC presents an interesting challenge. Secondarily formed 

OC is chemically identical to directly emitted (primary) OC (at least in terms of the commonly used sample analytical 

methods). There is significant VOC emitted by Clairton Works (583 tons/year) and 178 tons/year from Eastman, so 

there seems to be sufficient VOC emissions nearby, coupled with acidic gases and chlorides, to support some rapid 

formation of secondary OC from VOC. However, much of this OC is likely to be primary and some of it is likely from 

transport (Liberty is only 1.8 μg/m3 enriched above Hillman). Unfortunately, there is no way to resolve the source of 

secondary OC (or even how much of the OC is secondary) until appropriate photochemical modeling is performed. 

Figure V-5. Sulfate, Nitrate and Ammonium at Liberty Monitoring Station 

SOURCE: ACHD, 2011d. 

Table V-10 shows most of the SO4 (3.9 out of 5.3 μg/m3) and over half of the NH4 (1.3 out of 2.4 μg/m3) in the PMF 

Liberty analysis is found in PMF-7, which is associated with winds from 165 to 225 degrees - the direction of Clairton 

Works. Thus, (NH4)2SO4, comprising 5.2 μg/m3 in this Factor 7 (or about 70 percent of the total fully neutralized 

NH4SO4 measured at the Liberty site), appears to be strongly associated with Clairton Works. Clairton Works is 

shown in Table V-6 to emit 1,740 tons/year of SO2. Table V-7 shows that another 3,400 tons/year of SO2 is emitted 

from nearby sources in the west to north wind direction, but the CPF and PMF analysis indicates that these are not 

as important to Liberty's SO4 as SO2 from the direction of the Clairton emissions. Table V-6 shows that Clairton is the 

source of over 97 percent of the ammonia emissions in the NAA. 

About 4.6 μg/m3 of (NH4)2SO4 is found at the Lawrenceville site and some of this may be coming from the NAA. It is 

13 miles north-northeast of the Clairton Works and the CPF analysis shows significant transport from the south and 

southwest. Note that a significant portion of the sulfate could be transported from beyond the NAA. In fact, there is 

significant sulfate found at the Hillman site which supports the notion that a significant part of the sulfate may be due 

to long range transport. Modeling can help estimate the role of transport on Liberty's PM2.5 air quality. 

About two-thirds of the NH4NO3 is represented by PMF-5. It contains 0.87 μg/m3 of NO3 and 0.31 μg/m3 of NH4, 

suggesting fully neutralized NH4NO3 of 1.18 μg/m3. Clairton Works emits over 70 percent of the point source NOx

emitted within 10 miles of the Liberty site (ACHD, 2011c). However, the CPF analysis shows that while much of the 

NH4NO3 is associated with winds from the direction of Clairton, other wind directions are associated with some NO3

formation. Nitrate can form relatively quickly and locally, as seen by the higher nitrate in Lawrenceville than at Liberty 

0

1

2

3

4

5

6

7

8

9

Jan

Feb

Mar

Apr

May

Jun

Jul

Aug

Sept

Oct

Nov

Dec

Species Concentration, ug/m3

NO3 Nitrate

SO4 Sulfate

Ammonium required

to fully neutralize

NH4+ Ammonium

available
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and much lower values at Hillman. But, while NOx emitted by Clairton Works is likely responsible for much of the 

nitrate measured at Liberty, transport and other sources are also involved. The higher nitrate at Lawrenceville is 

likely due to a combination of additional formation during transport and from precursors near Lawrenceville. 

The remaining NH4, SO4, and NO3 (2.5 μg/m3) is associated mainly with Industrial Carbon/Sulfates (PMF-6), Burning 

(K - PMF-9) and Chlorine (PMF-10). PMF-6 and 10 are strongly affected by winds from the direction of Clairton 

Works. 

5. Chlorine 

Figure V-6 shows that the chlorine is much higher at the Liberty site than at the nearby Lawrenceville site. This 

would seem to rule out a ubiquitous source of chlorine or long range transport that would likely create elevated 

chlorine concentrations at both sites. Table V-8 shows that chlorine has the highest concentration ratio "high days" 

to "low days" of any measured specie. It is also much higher than the ratio of PM2.5 mass on the "high" versus "low" 

days. The apparent absence of high Chlorine on summer days may be due to instability of the Chlorine on the 

samples collected during warm weather. However, the high concentrations are seen in moderate weather months so 

it is unlikely the events are due to road salt applications. Another possibility is cooking or another source at the 

SAHS. The CPF analyses showed the Chlorine "source" was associated strongly with winds from the direction of 

Clairton Works. 

Together, this suggests that chlorine is likely associated with a sporadic source, intermittent process upsets or 

equipment malfunctions in the south - southwest wind vector. Also, it is possible that the chlorine is associated with 

specific meteorological conditions. In the previous section on upsets, ACHD was not able to identify significant 

breakdowns associated with these days. Regardless of whether the high Chlorine is readily attributable to a 

malfunction, it is still associated with some of the highest measured PM2.5 concentrations at the Liberty monitor. 

Identification of the responsible sources should be pursued through further analysis and investigation. 

Figure V-6. Comparison of Measured Chlorine at Liberty and Lawrenceville, by Month 

SOURCE: ACHD, 2011d. 

0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec

Chlorine Concentration, ug/m3

Month

Chlorine Liberty Borough Chlorine Lawrenceville
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6. Overall Source Contributions 

a. Source Contributions based on Emissions Inventory (2007 revised) 

Within the NAA, Clairton Works' emissions of PM2.5, SO2, and ammonia far exceeds those of any other point source 

or mobile or area source category. For NOx, it emits 6 times as much as Guardian Industries. 

Near, but outside of the NAA, USS' Irvin and Edgar Thompson Plants and the Bellefield Boiler Plant (coal-fired) all 

emit significant PM2.5, SO2 and NOx (but not nearly the amount of emissions as Clairton Works). The Bay Valley 

Foods coal-fired boiler also emits significant PM2.5 and SO2. The Bayfield and Bellefield Boiler Plants are about 10 

miles away from the Liberty Monitor, but the Irvin and Thompson USS facilities are 2 and 5 miles away, respectively. 

All these sources are west to north of the monitor and could impact it, but wind vectors show they would have much 

less impact on the Liberty site than Clairton Works' emissions. 

b. Source Contributions based on Measurements (Speciation at Liberty (2005-10) and Hillman Forest 

(2005-8) 

Primary versus Secondary 

 7.5 μg/m3 is EC OC and trace (EC 2.2, OC 4.5, trace 0.8) 

 (an undetermined but likely small of the OC is secondary) 

 

 9 μg/m3 is NH4 SO4 NO3 (NH4 2.4, SO4 5.3, NO3 1.3) 

 (55 percent of the PM2.5 at Liberty is ammonium sulfate and nitrate and all of this is assumed to be 

secondary. Some OC will also be secondary). 

 Note, on the 20 highest days, about 52 percent of the measured PM2.5 is ammonium sulfate and nitrate (see 

 Table V-1), compared to 55 percent on "average" days. 

Local versus Transport from outside NAA 

 EC OC Trace ~ 7.5 μg/m3

 (The EC at Liberty is mostly local since EC at the Hillman site is only 30 percent of the EC measured at 

Liberty. However, OC at Liberty is more affected by transport since the OC at Hillman is 60 percent as high 

as the OC at Liberty.) 

 NH4, SO4, and NO3 ~ 9 μg/m3 

The data in Table V-4 suggests that perhaps 70 percent of the ammonium sulfate and nitrate combined at 

Liberty is from transport. However, as much as half of the nitrate may be local and as much as 80 percent 

of the sulfate may be transported. 

Overall, we estimate the long term average PM2.5 at Liberty is about 38 percent local and 62 percent transport, based 

on measurement data. 

c. Source Contributions based on PMF (2005-2010) 

Factors 2, 6, 8, 10: "From Clairton Works Wind Vector - 6-7 μg/m3 

 (Source is Clairton Works (or beyond) ~ none of these sources located between Clairton and Liberty Monitor 
 January 17, 2012

2007 and 2014 Liberty-Clairton PM2.5 Nonattainment Area Emission Inventories and Source Assessment Analysis 

52 

 EC OC Trace ~ 4.6 μg/m3

 NH4, SO4, and NO3 ~ 1.8 μg/m3

 Factors 2 (Industry - 1.9 μg/m3) - likely local 

 Factor 6 (Industry - 2.9 μg/m3) – 40 percent (NH4)2SO4-likely local 

 Factor 8 (Coal/Coke - 0.6 μg/m3) - likely local 

 Factor 10 (Chlorine - 1 μg/m3) - possibly upsets, malfunction 

Factors 4, 5, 9: "Mostly local - not Clairton Works-related" ~ 3 μg/m3

 EC OC Trace ~ 1.3 μg/m3

 NH4, SO4, and NO3 ~ 1.8 μg/m3

 Factor 4 (Gas Vehicles - 0.7 μg/m3) ~ believed to be mostly locally emitted 

 Factor 5 (NO3 - 1.3 μg/m3) is associated with all wind directions which suggests mostly local origin 

 Factor 9 (Burning - 1.14 μg/m3) ~ best guess ~ 0.8 μg/m3 local wood burning (0.8 μg/m3). The PMF 

suggests that some of the remaining K (not in PMF-9) is from other sources, including transport. 

Factor 7: "Transport - related" ~ 6 μg/m3

 NH4SO4 - 5.2 μg/m3, 0.7 EC OC ~ NH4SO4 likely transport 

Minor Factors 

Factor 1 (Metals - < 0.1 μg/m3) 

Factor 3 (Coal/Glass - < 0.1 μg/m3) 

Factor 11 (Steel Mfg - < 0.3 μg/m3) 

Factor 12 (Crustal - < 0.3 μg/m3) 

Overall Estimates from PMF Analyses 

 Transport-related: 7 μg/m3 (~44 percent) 

 Local origin: 9 μg/m3 (~56 percent) 

Overall, by averaging the transport vs. local estimates based on measurement data and PMF analyses, more than 

half of the long-term average PM2.5 at the Liberty monitoring site is of local origin (60 percent local emissions ~ 40 

percent transport). 
 January 17, 2012

2007 and 2014 Liberty-Clairton PM2.5 Nonattainment Area Emission Inventories and Source Assessment Analysis 

53 

CHAPTER VI. REFERENCES 

ACHD, 2007: Allegheny County Health Department, “State Implementation Plan for PM2.5,” Appendix C - Modeling 

Protocol, Pg 2, October 2007. 

ACHD, 2010: Allegheny County Health Department, Point Source Emission Inventory Report 2008, April 2010. 

ACHD, 2011a: Allegheny County Health Department, “State Implementation Plan,” Appendix A, Pg 48-53, April 

2011. 

ACHD, 2011b: Allegheny County Health Department “Final Report for the Southwest Pennsylvania Great American 

Woodstove Changeout Program,” The Southwest Pennsylvania Air Quality Partnership, November 2007. 

ACHD, 2011c: Allegheny County Health Department, “Census of Restaurants,” transmitted October 2011. 

ACHD, 2011d: Allegheny County Health Department, "Allegheny County PM2.5 Source Apportionment Results using 

Positive Matrix Factorization Model (PMF Version 3.0) and Conditional Probability Function (CPF)," draft, Pittsburgh, 

PA, September 13, 2011. 

ACHD, 2011e: MANE-VU 2007 Point Source Emissions Inventory for Allegheny County, PA, received from 

Allegheny County Health Department, October 2011. 

AP, 2011: Associated Press, "AP Enterprise: Lowball Gas Drill Leases Haunt PA," accessed from 

http://www.pennlive.com/newsflash/index.ssf/story/ap-enterprise-lowball-gas-drill-leaseshaunt/f93c1d3bb459497eb068e12dba03824c, July 23, 2011. 

Armendariz, 2009: Al Armendariz, Ph.D., “Emissions from Natural Gas Production in the Barnett Shale Area and 

Opportunities for Cost-Effective Improvements,” Southern Methodist University, Department of Environmental and 

Civil Engineering, Version 1.1., January 26, 2009. 

Baker, 2005: Michael Baker Jr., Inc., “Statistical Evaluation of Projected Traffic Growth, Traffic Growth Forecasting 

System: Final Report,” March 14, 2005. 

Brinza, 2011: M. Brinza, Port of Pittsburgh Commission, Email to K. Thesing, TranSystems|E.H. Pechan, “Lockage 

data,” October 13, 2011. 

Census, 2005: U.S. Census Bureau, “American Housing Survey for the Pittsburgh Metropolitan Area: 2004,” Current 

Housing Reports, H170/04-13, issued October 2005. 

Census, 2011: U.S. Census Bureau, “2005-2009 American Community Survey 5-Year Estimates,” American 

Community Survey, accessed from http://factfinder.census.gov/servlet/STTable?_bm=y&-geo_id=01000US&-

qr_name=ACS_2009_5YR_G00_S2504&-ds_name=ACS_2009_5YR_G00_, October 2011. 

Considine, Watson, and Blumsack, 2010: T.J. Considine, R. Watson, and S. Blumsack, “The Economic Impacts of 

the Pennsylvania Marcellus Shale Natural Gas Play: An Update,” The Pennsylvania State University, College of 

Earth and Mineral Sciences, Department of Energy and Mineral Engineering, May 24, 2010. 

EIA, 2011: Energy Information Administration, “Annual Energy Outlook, 2011, with Projections through 2035,” 

DOE/EIA-0383(2011), Department of Energy, Office of Integrated Analysis and Forecasting, Washington, DC, April 

26, 2011. 
 January 17, 2012

2007 and 2014 Liberty-Clairton PM2.5 Nonattainment Area Emission Inventories and Source Assessment Analysis 

54 

EPA, 2009: U.S. Environmental Protection Agency, “Emission Factors for Locomotives,” Office of Transportation and 

Air Quality, EPA-420-F09-025, April 2009. 

EPA, 2008a: U.S. Environmental Protection Agency, “Residential Heating - Residential Wood Combustion and Wax 

Firelogs,” accessed from http://projects.pechan.com/EPA/NonPoint_Emission_Estimates/index.html#ResidentialHeating, October 2011. 

EPA, 2008b: U.S. Environmental Protection Agency, “Technical Support Document: Preparation of Emissions 

Inventories for the 2002-based Platform, Version 3, Criteria Air Pollutants,” available from 

http://www.epa.gov/scram001/reports/Emissions%20TSD%20Vol1_02-28-08.pdf, January 2008. 

EPA 2008c: U.S. Environmental Protection Agency, “Regulatory Impact Analysis: Control of Emissions of Air 

Pollution from Locomotive Engines and Marine Compression Ignition Engines Less than 30 Liters Per Cylinder,” 

Office of Transportation and Air Quality, EPA-420-R-08-001. March 2008. 

EPA, 2008d: Norris, Gary, R. Vedentham, K. Wade, S. Brown, J. Prouty and C. Foley, "EPA Positive Matrix 

Factorization (PMF) User Guide," EPA 600/R-08/108, U.S. Environmental Protection Agency, Washington, DC, June 

2008. 

EPA, 2009: U.S. Environmental Protection Agency, “Policy Guidance on the Use of MOVES2010 for SIP 

Development, Transportation Conformity, and Other Purposes,” Office of Air and Radiation, EPA-420-B-09-046, 

December 2009. 

EPA, 2010a: U.S. Environmental Protection Agency, “Technical Guidance on the Use of MOVES2010 for Emission 

Inventory Preparation in State Implementation Plans and Transportation Conformity,” Office of Air and Radiation, and 

Office of Transportation and Air Quality, EPA-420-B-10-023, April 2010. 

EPA, 2010b: U.S. Environmental Protection Agency, “Motor Vehicle Emission Simulator, User Guide for 

MOVES2010a,” EPA-420-B-10-036, August 2010. 

EPA, 2010c: U.S. Environmental Protection Agency, “Instructions for Using LEV and NLEV Inputs for MOVES,” 

EPA-420-B-10-003a, August 2010. 

EPA, 2011a: U.S. Environmental Protection Agency, “U.S. EPA Air Quality System (AQS), 

http://epa.gov/air/data/monvals.html?co~42003~Allegheny%20Co%2C%20Pennsylvania, last accessed October 25, 

2011. 

EPA, 2011b: U.S. Environmental Protection Agency, “U.S. EPA Source Profile Library, 

http://projects.pechan.com/ttn/speciate4.3/, last accessed October 26, 2011. 

ERTAC, 2011: Eastern Regional Technical Advisory Committee, 2008 Class II/III line haul Emissions, transmitted in 

file “ERTACRail-Class_II_III_10_5_2011.xls” in email, “Question about link-level ERTAC Class I and Class II/III 

emissions,” from M. Bergin, ERTAC to K. Thesing, TranSystems|E.H. Pechan, October 19, 2011. 

Frank, 2006: Neil Frank, "SANDWICH Material Balance Approach for PM2.5 Data Analysis," presented at 2006 

National Air Modeling Conference, Las Vegas, NV, November 6-9, 2006. 
 January 17, 2012

2007 and 2014 Liberty-Clairton PM2.5 Nonattainment Area Emission Inventories and Source Assessment Analysis 

55 

ICF, 2009: ICF International, “Technical Assistance for the Draft Supplemental Generic EIS: Oil, Gas and Solution 

Mining Regulatory Program; Well Permit Issuance for Horizontal Drilling and High-Volume Hydraulic Fracturing to 

Develop the Marcellus Shale and Other Low Permeability Gas Reservoirs,” August 2009. 

Lattner, 2011: T. Lattner, Allegheny County Health Department, personal communication with K. Thesing, 

TranSystems|E.H. Pechan, October 25, 2011. 

Limbeck, et al., 1996: A. Limbeck, M. Kulmala, and H. Puxbaum (2003), “Secondary organic aerosol formation in the 

atmosphere via heterogeneous reaction of gaseous isoprene on acidic particles,” Geophys. Res. Lett., 30(19), 

doi:10.1029/2003GL017738, 1996. 

MARAMA, 2011: Mid-Atlantic Regional Air Management, Inc., “2007 Regional Emissions Inventory,” accessed from 

ftp.marama.org, October 2011. 

Maranche, 2011 - email from J. Maranche, Allegheny County Health Department, to J. Wilson, TranSystems 

Corporation, received November 2, 2011. 

Nocmongcol, et al., 2007: U. Nocmongcol, W. Khamwichita, M.P. Fraserb, and D.T. Allena, "Estimates of 

heterogeneous formation of secondary organic aerosol during a wood smoke episode in Houston, Texas," 

Atmospheric Environment Volume 41, Issue 14, Pages 3057-3070, May 2007. 

Pace, et al., 1978: T., K. Axetell, and R. Zimmer., "Microinventories for TSP," proceedings of APCA Specialty 

Conference: Emission Factors and Inventories, Anaheim, CA, November 1978. 

PADEP, 2011: Pennsylvania Department of Environmental Protection, “2010 Permit and Rig Activity Report,” 

http://www.dep.state.pa.us/dep/deputate/minres/oilgas/rig10.htm, accessed October 2011. 

PennDOT, 2008: Pennsylvania Department of Transportation, “2008 Pennsylvania Traffic Data,” Bureau of Planning 

and Research, 2008. 

Post-Gazette, 2009: Pittsburgh Post-Gazette, http://www.post-gazette.com/pg/10351/1111418-455.stm, 2009. 

Rune, et al., 2001 S. Rune, S. Karlsson, J. Szente, J.C. Ball, and M. Matti Maricq, “Homogeneous Aerosol Formation 

by the Chlorine Atom Initiated Oxidation of Toluene,” J. Phys. Chem. A, 105 (1), pp 82–96, 2001. 

Sadar, 2011a: email from T. Sadar, Allegheny County Health Department, to J. Wilson, TranSystems Corporation, 

October 21, 2011. 

Sadar, 2011b: email from T. Sadar, Allegheny County Health Department, to J. Wilson, TranSystems Corporation, 

October 8, 2011. 

Salcedo, et al, 2006: D. Salcedo, T.B. Onasch, K. Dzepina, M.R. Canagaratna, Q. Zhang, J.A. Huffman, P.F. DeCarlo, J.T. Jayne, P. Mortimer, D.R. Worsnop, C.E. Kolb, K.S. Johnson, B. Zuberi, L.C. Marr, R. Volkamer, L.T. 

Molina, M.J. Molina, B. Cardenas, R.M. Bernab ́ e, C. M ́arquez, J.S. Gaffney, N.A. Marley, A. Laskin, V. 

Hutthanandan, Y. Xie, W. Brune, R. Lesher, T. Shirley, and J.L. Jimenez, “Characterization of ambient aerosols in 

Mexico City during the MCMA-2003 campaign with Aerosol Mass Spectrometry: results from the CENICA 

Supersite,” Atmos. Chem. Phys., 6, 925–946, 2006. 

SPC, 2011a: Southwestern Pennsylvania Commission, “Unified GIS Land-Use / Land-Cover Classification: 

Allegheny County 2000-2006 Change Analysis,” transmitted by Anthony Sadar, ACHD, October 17, 2011. 
 January 17, 2012

2007 and 2014 Liberty-Clairton PM2.5 Nonattainment Area Emission Inventories and Source Assessment Analysis 

56 

SPC, 2011b: Southwestern Pennsylvania Commission, “Cycle 9 Forecast (adopted by the Commission on June 27, 

2011) for 2010 and 2015,” transmitted by Bob Schwartz, SPC, November 10, 2011. 

SPC, 2011c: Southwestern Pennsylvania Commission (SPC), Chuck Imbrogno, Email to T. Sadar, entitled “Rail Info 

Request,” November 3, 2011. 

Trostle, 2011: C. Trostle, Mobile Sources Section Chief, Pennsylvania Department of Environmental Protection, 

Email to K. Thesing, TranSystems|E.H. Pechan, entitled “CMV Emissions in Pittsburgh,” October 4, 2011. 

University of Pittsburgh, 2011: University of Pittsburgh, “Oil and Gas Leases by Municipality,” University Center for 

Social and Urban Research, Urban and Regional Analysis, accessed from 

http://www.ucsur.pitt.edu/thepub.php?pl=12, November 12, 2011. 

USACE, 2011: U.S. Army Corps of Engineers, “Waterborne Commerce of the United States; Calendar Year 2009, 

Part 5 - National Summaries,” Table 3-8, available at http://www.ndc.iwr.usace.army.mil//wcsc/pdf/wcusnatl09.pdf, 

2011. 
F-2: Local Inventory Revisions 2007/2014
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Page 1

Summary of Local Inventory Revisions

Allegheny County and SWPA inventories for the PM2.5 SIP were based on the MANE-VU Version 

3.3 inventory, as developed for MARAMA for Mid-Atlantic and Northeastern states (see Appendix 

E). The base year was 2007, while projected years were 2017/2020. For future case year 2014, 

interpolations were developed by TS|Pechan based on the MANE-VU 2007 and 2017 inventories 

(see section F-3 of this appendix).

ACHD revised or corrected specific local point sources in the MANE-VU 2007 and 2014 

inventories based on location of sources, emissions/controls, monitored data, and source 

apportionment analysis (see Appendix C). Sources examined were within approximately 10 km 

of the Liberty monitor, and also included some Washington County sources.

Minor sources potentially impacting Liberty-Clairton that were not included in the MANE-VU point 

inventory (and not accounted for as part of the SCC categories included in area source inventory)

were added as new sources to the local inventory. Emissions from these sources are relatively 

small.

Area and nonroad emissions for 2007 and 2014 were developed separately for Liberty-Clairton by 

TS|Pechan, and Allegheny County emissions were revised accordingly to subtract LibertyClairton emissions. Point source subtractions were done to Allegheny County and LibertyClairton area sources to avoid double-counting of commercial/institutional/industrial fuel 

combustion sources. Additionally, for future case 2014, surrounding SWPA counties were 

revised by ACHD to include Marcellus shale gas area emissions estimates.

ACHD also revised the future case 2014 Transport Rule emissions (June 2011) for GenOn 

Elrama and Allegheny Energy Mitchell power plants using the final CSAPR allocations (June 

2012) for SO2 and NOx along with calculated heat inputs to derive other pollutant emissions. All 

other emissions used for modeling were unchanged from the developed inventories, as given in 

Tables 5-2 and 5-3 of the SIP.

This section contains specific revisions to the modeling inventories, along with a listing of the 

point source emissions totals for 2007 and 2014 for Allegheny and Washington County facilities. 

The consent order and agreement (as amended in July 2011) with U. S. Steel is also provided as 

supplemental information.
Page 2

2007 Point Source Revisions

Below are descriptions of the point source revisions/corrections for baseline 2007.

US Steel Mon Valley Works – Clairton Plant

All Sources: Coordinates corrected, based on aerial maps.

Quench Towers: Revised based on newer stack test data. Includes revised PM 

emissions, revised stack parameters. PM2.5 data is given in the table below:

Quench Tower 

Calculations, PM2.5

Tower 1, 

Batteries 1-3

Tower 3,

Batteries 7-9

Tower 5, 

Batteries 13-15

Tower 7, 

Batteries 19-20 

Tower B,

B Battery

2007 Tons Coal Charged 995133 1039563 1284574 1305929 819673

2007 Quenches 74631 76263 82521 67276 24513

lbs/quench (tested) 1.75 1.75 0.60 1.94 2.72

tons/year (quench 

factor) 65.46 66.90 24.88 65.26 33.34

non-compliance factor -- -- 1.1 1.5 2.0

2007 lbs/quench 

(scaled) 3.00 3.00 0.66 2.91 5.44

2007 tons/year (scaled, 

averaged) 112.11 114.56 27.37 97.89 66.68

Notes:

- Use updated quench-based factors from 2010-2011 stack tests

- 2010-2011 stack tests for 5, 7, B

- Scale calculated values to 2007 based on non-compliance factors

- lbs/quench for 1, 3 is average of 5, 7, & B

Coke Oven Batteries: Stack heights corrected to 126 ft for all battery fugitives, based on 

the EPA 2005 National Air Toxics Assessment (NATA) method used for buoyant coke 

battery emissions.

1

Coke Oven Batteries, PEC System Fugitives: Stack parameters corrected to 126 ft 

height, 0 ft diameter, 0 ft/s velocity, and 72 °F temp.

Material Handling: Screening, loading/unloading, pulverizing, and boom conveying 

temperatures corrected to 72 °F.

Cooling Tower: Revised based on stack test data. Includes an increase in PM 

emissions, revised stack parameters.

Aeration Basin, Wastewater Treatment: Revised based on newer calculations, reducing

NH3 emissions that were previously overestimated.

 

1

http://www.epa.gov/ttn/atw/nata2005/05pdf/nata_tmd.pdf
Page 3

US Steel Mon Valley Works – Edgar Thomson Plant

All Sources (except BOP Operations and Continuous Caster): Coordinates corrected, 

based on aerial maps.

Blast Furnace 1 & 3 Casthouses: SO2 emissions decreased by a factor of 10. These 

emissions were erroneously calculated in the reported 2007 inventory. Temperatures 

also corrected to 72 °F.

BOP Flux: Temperature corrected to 72 °F.

Blast Furnace Breakdown: Temperature corrected to 72 °F.

US Steel Mon Valley Works – Irvin Plant

Cooling Tower: Coordinates corrected, based on aerial maps.

Annealing, Terne Line, COG Flaring: Temperature corrected to 72 °F.

Eastman Chemical Resins

All Sources: Coordinates corrected, based on aerial maps.

Plant Fugitives: VOCs increased by 3 tons, based on updated reporting methodology.

LTC Units: Scrubbers and baghouses, temperature corrected to 72 °F.

Guardian Industries

All Sources (except Raw Material Receiving): Coordinates corrected, based on aerial 

maps.

Koppers Industries

All Sources: Coordinates corrected, based on aerial maps.

Cooling Tower: Stack parameters corrected, based on permit application values.

Laurel Mountain Whirlpools

All Sources: Coordinates corrected, based on aerial maps. Temperature corrected to 72 

°F.

Liberty Pultrusions

All Sources: Coordinates corrected, based on aerial maps.
Page 4

Precoat Metals

All Sources: Coordinates corrected, based on aerial maps.

48 Coating Line: Prime coater, temperature corrected to 72 °F.

Minor Sources

The following Allegheny County minor sources were added to the 2007 inventory:

AKJ Industries

Bekavac Funeral Home

Braddock Recovery 

Chambers Development Co

Clairton Slag

Consol Coal

CP Industries

Dura-Bond Industries

ELG Metals

Gardner Denver Nash

GE Apparatus

GM Metal Stamping

Jefferson Crematory

Kelly Run Sanitation

Kinder-Morgan Liquids Terminal

Marathon Ashland West Eliz

Mid-Continent Coal & Coke

Mon Valley Transportation

Pennsylvania Electric Coil

Ryan Metals

Sanyo

Tech Met

Tube City IMS Braddock

Tube City IMS Clairton

Tube City IMS West Mifflin

TYK Refractories

The following Washington County minor sources were added to the 2007 inventory:

Equitrans LP/Hartson

Therm-O-Rock New Eagle

USA South Hills Landfill
Page 5

2007 Area Source Revisions

Below are descriptions of the area source revisions/corrections for baseline 2007.

Liberty-Clairton

Liberty-Clairton area emissions were developed by TS|Pechan (see section F-1 of this 

appendix). ACHD corrected the residential distillate oil SO2 emissions, which were 

previously underreported by a factor of 100. ACHD also applied fugitive dust transport 

factors (FDTF=0.23 for Allegheny County) to PM emissions for the following SCCs:

SCC SCC Short Name

2294000000 Paved Roads /All Paved Roads /Total: Fugitives

2296000000 Unpaved Roads /All Unpaved Roads /Total: Fugitives

2311010000 Construction: SIC 15 - 17 /Residential /Total

2311020000 Construction: SIC 15 - 17 /Industrial/Commercial/Institutional /Total

2311030000 Construction: SIC 15 - 17 /Road Construction /Total

2801000003 Agric - Crops /Tilling

Allegheny County

Liberty-Clairton area emissions were subtracted from Allegheny County, by SCC. (If 

result was <0, emissions were set to 0.)

Point source emissions with similar SCCs were subtracted from the SCCs given below. 

This eliminated double-counting for several large commercial/institutional/industrial 

combustion sources.

SCC SCC Short Name

2102004000 Stationary Fuel Comb /Industrial /Distillate Oil /Total: Boilers and IC Engines

2102006000 Stationary Fuel Comb /Industrial /Natural Gas /Total: Boilers and IC Engines

2102007000 Stationary Fuel Comb /Industrial /Liquified Petroleum Gas /Total: All Boiler Types

2103002000 Stationary Fuel Comb /Commercial/Institutional /Bituminous/Subbituminous Coal /Total: All Boiler Types

2103004000 Stationary Fuel Comb /Commercial/Institutional /Distillate Oil /Total: Boilers and IC Engines

2103006000 Stationary Fuel Comb /Commercial/Institutional /Natural Gas /Total: Boilers and IC Engines

2103007000 Stationary Fuel Comb /Commercial/Institutional /Liquified Petroleum Gas /Total: All Combustor Types
Page 6

2007 Nonroad Source Revisions

Below are descriptions of the nonroad source revisions/corrections for baseline 2007.

Liberty-Clairton

Liberty-Clairton area emissions were developed by TS|Pechan (see section F-1 of this 

appendix).

Allegheny County

Liberty-Clairton area emissions were subtracted from Allegheny County, by SCC. (If 

result was <0, emissions were set to 0.)
Page 7

2014 Point Source Revisions

Below are descriptions of the point source revisions/corrections for future case 2014. TS|Pechan 

interpolated 2014 non-EGU MANE-VU emissions based on 2007 and 2017 data (see section F-3 

of this appendix). Transport Rule (CSAPR) 2014 data was used for EGU sources.

Unless modified as described below, sources revised in the baseline 2007 case were held 

constant to 2014, replacing the interpolated 2014 MANE-VU data. I.e., growth/control factors 

used in the MANE-VU inventory were not used for the local sources of interest, focusing on the 

known modifications only. This mainly affects the US Steel boilers, which were projected to 

increase in emissions using the MANE-VU growth factors.

All other MANE-VU sources were based on the interpolated 2014 data unless mentioned below. 

Likewise, all EGUs were based on the modeled Transport Rule (CSAPR) 2014 inventory unless 

mentioned below. Minor sources added to the 2007 case were also added to the 2014 case, 

unless listed below as a shutdown.

US Steel Mon Valley Works – Clairton Plant

Batteries 7-9 and associated processes: Shutdown, includes sources below:

BATTERY 7 FUGITIVES, BATTERY 7, CHARGING

BATTERY 7 FUGITIVES, BATTERY 7, DOOR LEAKS

BATTERY 7 FUGITIVES, BATTERY #7, TOPSIDE LEAKS

BATTERY 7 FUGITIVES, BATTERY 7, SOAKING

BATTERY 7 FUGITIVES, BATTERY 7, DECARBONIZING

BATTERY 8 FUGITIVES, BATTERY 8, CHARGING

BATTERY 8 FUGITIVES, BATTERY 8, DOOR LEAKS

BATTERY 8 FUGITIVES, BATTERY #8, TOPSIDE LEAKS

BATTERY 8 FUGITIVES, BATTERY #8, SOAKING

BATTERY 8 FUGITIVES, BATTERY 8, DECARBONIZING

BATTERY 9 FUGITIVES, BATTERY 9, CHARGING

BATTERY 9 FUGITIVES, BATTERY 9, DOOR LEAKS

BATTERY 9 FUGITIVES, BATTERY #9, TOPSIDE LEAKS

BATTERY 9 FUGITIVES, BATTERY #9, SOAKING

BATTERY 9 FUGITIVES, BATTERY 9, DECARBONIZING

QUENCH TOWER #3

BATTERY 7, UNDERFIRING

BATTERY 8, UNDERFIRING

BATTERY 9, UNDERFIRING

PEC SYSTEM, BATTERIES 7-9, PEC BAGHOUSE STACK

PEC SYSTEM, BATTERIES 7-9, TRAVELING HOT CAR

PEC SYSTEM, BATTERIES 7-9, PEC FUGITIVES

PEC SYSTEM, BATTERIES 7-9, PRE PUSH

PEC SYSTEM, BATTERIES 7-9, UNCONTROLLED PUSHING

PEC SYSTEM, BATTERIES 7-9, BALL MILL
Page 8

Screening Station B (3): Shutdown, includes sources below:

SCREENING STATION B, SCREENING STATION B BAGHS

SCREENING STATION B, SCREEN STATION B LOADOUT

SCREENING STATION B, SCREENING FUGITIVES - B

Quench Towers: Revised based on new configuration. Includes revised PM emissions, 

three new stacks. PM2.5 data is given in the table below:

Quench Tower Projections, PM2.5

Tower 1, 

Batteries 1-3

Tower 5A, 

Batteries 13-15

Tower 7A, 

Batteries 19-20

Tower B, 

B Battery

Tower C, 

C Battery

2014 tons/year 65.46 8.75 38.00 33.34 9.00

Notes:

- Based on updated stack tests 2010-2011 for 1, B

- Based on US Steel projections for 5A, 7A, C

Batteries 19 & B, Fugitive Door Leaks: Emissions revised based on battery rebuilds. 

Scaled by factor of 0.537.

Batteries 19 & B, Underfiring: Emissions revised based on battery rebuilds. Scaled by 

factor of 0.537.

PEC System B, Fugitives & Baghouse Stack: Emissions revised based on battery 

rebuilds. Scaled by factor of 0.621.

Coal Unloading, Transfer, Pulverizing: Revised based on new configuration. Small 

increases in PM.

Screening Station 1 (1-3): Revised based on new configuration. Minor decrease in PM.

Coke Pile Erosion, Coke Transfer: Revised based on new configuration. Minor 

increases in PM.

C Battery and associated processes: New coke battery added to inventory, includes 

sources below:

BATTERY C FUGITIVES, BATTERY C CHARGING

BATTERY C FUGITIVES, BATTERY C DOOR LEAKS

BATTERY C FUGITIVES, BATTERY C OFFTAKES, LIDS

BATTERY C FUGITIVES, BATTERY C SOAKING

BATTERY C FUGITIVES, BATTERY C DECARBONIZING

BATTERY C UNDERFIRING
Page 9

PEC SYSTEM, BATTERY C, PEC BAGHOUSE STACK

PEC SYSTEM, BATTERY C, TRAVELING HOT CAR

PEC SYSTEM, BATTERY C, PEC FUGITIVES

PEC SYSTEM, BATTERY C, PRE PUSH

PEC SYSTEM, BATTERY C, UNCONTROLLED PUSHING

PEC SYSTEM, BATTERY C, BALL MILL

QUENCH TOWER C

SCREEN STN 4

Koppers Industries

Tar Refining Fugitives, Liquid Loading: Revised based on newer configuration.

Type A Pitch Tanks, RCO Tanks: Revised based on newer configuration.

Direct-Fired Thermal Oxidizer (4 MMBtu/hr): New source, added to inventory.

Bellefield Boiler Plant

All sources: Boilers 1, 3, and 5 switched from coal to natural gas in 2009. However, due 

to emission reduction credits (ERCs, or “banked emissions”) that have not been 

transferred, all sources for Bellefield were held constant at 2007 emissions.

Laurel Mountain Whirlpools

All Sources: Shutdown.

Precoat Metals

All Sources: Shutdown.

Iron City Brewing

All Sources: Shutdown.

Minor Sources

The following Allegheny County minor sources were shut down by 2014 (without banked 

emissions) and not added to the 2014 inventory as a minor source:

GM Metal Stamping

Ryan Metals
Page 10

GenOn Elrama

Electric Generating Units: Elrama boilers were revised to the final June 2012 CSAPR 

allocations for SO2 and NOx. Emissions per heat input (based on 2007 levels) were then 

used to scale the other pollutant emissions per boiler.

Allegheny Energy Mitchell

Electric Generating Units: Mitchell boilers were revised to the final June 2012 CSAPR 

allocations for SO2 and NOx. Emissions per heat input (based on 2007 levels) were then 

used to scale the other pollutant emissions per boiler.
Page 11

2014 Area Source Revisions

Below are descriptions of the area source revisions/corrections for future case 2014. For all area 

source emissions outside Liberty-Clairton, TS|Pechan interpolated 2014 MANE-VU emissions 

based on 2007 and 2017 data (see section F-3 of this appendix).

Liberty-Clairton

Liberty-Clairton area emissions were developed by TS|Pechan (see section F-1 of this 

appendix). ACHD corrected the residential distillate oil SO2 emissions, which were 

previously underreported by a factor of 100. ACHD also applied fugitive dust transport 

factors (0.23 for Allegheny County) to PM emissions for the following SCCs:

SCC SCC Short Name

2294000000 Paved Roads /All Paved Roads /Total: Fugitives

2296000000 Unpaved Roads /All Unpaved Roads /Total: Fugitives

2311010000 Construction: SIC 15 - 17 /Residential /Total

2311020000 Construction: SIC 15 - 17 /Industrial/Commercial/Institutional /Total

2311030000 Construction: SIC 15 - 17 /Road Construction /Total

2801000003 Agric - Crops /Tilling

Allegheny County

Liberty-Clairton area emissions were subtracted from Allegheny County, by SCC. (If 

result was <0, emissions were set to 0.)

Point source emissions with similar SCCs were subtracted from the SCCs given below. 

This eliminated double-counting for several large commercial/institutional/industrial 

combustion sources.

SCC SCC Short Name

2102004000 Stationary Fuel Comb /Industrial /Distillate Oil /Total: Boilers and IC Engines

2102006000 Stationary Fuel Comb /Industrial /Natural Gas /Total: Boilers and IC Engines

2102007000 Stationary Fuel Comb /Industrial /Liquified Petroleum Gas /Total: All Boiler Types

2103002000 Stationary Fuel Comb /Commercial/Institutional /Bituminous/Subbituminous Coal /Total: All Boiler Types

2103004000 Stationary Fuel Comb /Commercial/Institutional /Distillate Oil /Total: Boilers and IC Engines

2103006000 Stationary Fuel Comb /Commercial/Institutional /Natural Gas /Total: Boilers and IC Engines

2103007000 Stationary Fuel Comb /Commercial/Institutional /Liquified Petroleum Gas /Total: All Combustor Types
Page 12

Surrounding Counties

For Washington, Westmoreland, Greene, and Fayette Counties, ACHD developed future case 

2014 area source estimates to account for increases in Marcellus shale gas production. The 

methodology and estimates are described below.

Background: The exploration, development, and production of gas from the Marcellus 

Shale formation are expected to result in substantial increases in air pollutants in the 

region. This memo provides an explanation of the methodology taken to estimate several 

of those pollutants for the Allegheny County Health Department (ACHD) 2014 emissions 

inventory prepared for the county’s PM2.5 State Implementation Plan (SIP) modeling 

work. The SIP modeling base year was 2007, which was assumed to have insignificant 

levels of emissions from Marcellus Shale wells.

Estimate of Wells Drilled in 2014: Estimates of the total number of wells expected in 

Washington, Greene, Fayette, and Westmoreland counties in 2014 were derived from 

projections given in a June 2011 Penn State Cooperative Extension report.1 Table 1 of 

this report gives a total of 892 projected Marcellus Shale wells drilled in 2014 for 

southwest Pennsylvania. This total was distributed to the individual southwestern PA 

counties by assuming that the proportion in each county would be the same as reported 

by the PA DEP for 2011.2 For example, 31.2% of total wells in southwest PA were in 

Washington County (159 in Washington County versus a total of 509 in southwest PA). 

Assuming this same percentage will hold through 2014, the expectation for Washington 

County is for 278 wells to be drilled in 2014 (31.2% of 892 projected wells). Similar 

calculations were carried out for the other counties (Greene was 24.0% or 214 wells; 

Fayette, 10.6% or 95 wells; and Westmoreland, 11.8% or 105 wells).

Estimate of Existing Wells in Operation in 2014: Besides the 2014 new well totals, we 

must determine the total number of wells expected to already be operating in each county 

in 2014. Thus, for example, according to PA DEP,2560 wells were drilled in Washington 

County from January 1, 2005 through December 31, 2011. And projections provided in 

the Penn State Cooperative Extension report1for wells drilled in 2012 and 2013 show 

430 wells are expected. So, a total of 990 wells are anticipated to be operating in 

Washington County in 2014. (Similarly, for Greene County, 740 total wells are expected; 

for Fayette, 332; and for Westmoreland, 349.) 

Wet Versus Dry Wells: Based on the geology of the counties,3 we have assumed that 

40% of the wells are producing dry gas and 60% wet gas for Washington County, 70% 

dry gas / 30% wet gas for Greene County wells, and 100% dry gas for Fayette and 

Westmoreland wells.

Air Emission Factors: The “Emissions Per Well” provided in the table below are based on 

a Marcellus Shale operations analysis found in “An emissions inventory for the 

development and production of Marcellus Shale” by Anirban A. Roy, Peter J. Adams, and 

Allen L. Robinson of Carnegie Mellon University, 2012.4 In this draft report, mean values 

are given for 2009 and 2020. A number that is roughly the average of the two annual 

mean values was selected for the estimates given here. Furthermore, for the midstream 

(processing) emissions, a typical gas flow of 5 million cubic feet per day (mmcf/day) from 

new wells was assumed (a magnitude derived from a statement made by Penn State 

geologist Terry Engelder5and from a PA DCNR presentation titled “The Marcellus Shale 

Play in Pennsylvania” by John A. Harper and Jaime Kostelnik.6 Therefore, for example, 

the yearly flow for new wells will be:

Annual Flow = (5 mmcf/day/new well) (365 days/yr) = 1.825 billion cubic feet (Bcf)/new 

well/yr.
Page 13

Furthermore, the midstream NOx emissions per new well will be:

Midstream NOx Emissions = (2.4 tons NOx/Bcf/new well) (1.825 Bcf/yr) = 4.39 tons 

NOx/new well/yr.

It was assumed that midstream (and production) emissions during the start-up year 

(2014) would only be one-half, assuming that site preparation and initial production will 

be distributed rather evenly throughout the year. Thus, for example, midstream NOx

emissions per new well would be 2.20 TPY.

For wells already in operation in 2014, assuming a steady average production rate of 1 

mmcf/day per well based on production decline curves reported in “The Marcellus Shale 

Play in Pennsylvania,”6the total gas flow from Washington County existing wells during 

2014 will be 0.365 Bcf, and the corresponding midstream NOx emissions per existing well 

in 2014 is estimated to be about 0.90 TPY.

Caveats on This Estimation Approach: Development is frequently seasonal and 

refracking of existing locations can occur. Neither of these two conditions were 

considered in the emission estimates.

Results: Marcellus Shale air emission estimates for Washington, Greene, Fayette, and 

Westmoreland Counties in southwestern Pennsylvania are given in the table Estimated 

Marcellus Shale 2014 Air Emissions (TPY) on the following page.

References

1. “Pennsylvania Marcellus Shale Economic Impact Study” by the Marcellus Shale 

Education & Training Center, a collaboration of the Pennsylvania College of Technology and 

the Penn State Cooperative Extension, June 2011. See Figure 4 and Table 1 in study, 

available at: http://marcelluscoalition.org/wpcontent/uploads/2011/08/PennsylvaniaStatewideWorkforceAssessmentv1_Final_for_web.pdf

2. PA DEP Office of Oil and Gas Management Wells Drilled by County accessed June 28, 

2012. Available at: 

http://www.depreportingservices.state.pa.us/ReportServer/Pages/ReportViewer.aspx?/Oil_G

as/Wells_Drilled_By_County

3. Derived by Jason Maranche of ACHD from geological map of Marcellus Shale dry/wet gas 

demarcation and distribution of wells drilled in 2007 through 3/19/2012 from Marcellus Center 

for Outreach and Research (see www.marcellus.psu.edu).

4. “An emissions inventory for the development and production of Marcellus Shale” by 

Anirban A. Roy, Peter J. Adams, and Allen L. Robinson of Carnegie Mellon University, 2012 

– DRAFT.

5. Penn State University geologist Terry Engelder online interview, June 2010 (see 

http://www.youtube.com/watch?v=0uNzwFkrcqg&feature=relmfu.)

6. PA DCNR presentation titled “The Marcellus Shale Play in Pennsylvania” by John A. 

Harper and Jaime Kostelnik (www.marcellus.psu.edu/resources/PDFs/DCNR.pdf, see slide 

64, et al.).
Page 14

Estimated Marcellus Shale 2014 Air Emissions (TPY)

* Midstream emission factors, based on Reference 4, are: NOx = 2.4 tons/Bcf, PM2.5 = 0.03 tons/Bcf,

and VOCs = 5.2 tons/Bcf.

Wash Wash Greene Greene Fayette Westm

Dry (40%) Wet (60%) Dry (70%) Wet (30%) Dry Dry

111 167 150 64 95 105

 Development NOx 6.00 666 1002 900 384 570 630

PM2.5 0.30 33 50 45 19 29 32

VOC dry 3.00 333 450 285 315

VOC wet 14.00 2338 896

 Production NOx 0.45 50 75 68 29 43 47

 (Assumed at 50%) PM2.5 0.01 1 1 1 0 0 1

VOC dry 0.26 29 39 25 27

VOC wet 1.25 209 80

 Midstream* NOx 2.20 244 367 330 141 209 231

 (Assumed at 50%) PM2.5 0.05 6 8 8 3 5 5

VOC 4.75 527 793 713 304 451 499

Wash Wash Greene Greene Fayette Westm

 Dry(40%) Wet (60%) Dry (70%) Wet (30%) Dry Dry

396 594 518 222 332 349

 Production NOx 0.90 356 535 466 200 299 314

PM2.5 0.01 4 6 5 2 3 3

VOC dry 0.53 210 275 176 185

VOC wet 2.50 1485 555

 Midstream* NOx 0.90 356 535 466 200 299 314

PM2.5 0.01 4 6 5 2 3 3

VOC 1.90 752 1129 984 422 631 663

TOTALS Wash Greene Fayette Westm

NOx 4187 3183 1419 1536

PM2.5 118 91 40 44

VOC 7805 4717 1568 1689

DRILLED IN 2014 (i.e., NEW WELLS)

EXISTING IN 2014 (i.e., 2007-2013)

Number of wells ->

Emissions per well *

(TPY)

Number of wells ->

Emissions per Well *

(TPY)
Page 15

2014 Nonroad Source Revisions

Below are descriptions of the nonroad source revisions/corrections for future case 2014. For all 

nonroad source emissions outside Liberty-Clairton, TS|Pechan interpolated 2014 MANE-VU 

emissions based on 2007 and 2017 data (see section F-3 of this appendix).

Liberty-Clairton

Liberty-Clairton area emissions were developed by TS|Pechan (see section F-1 of this 

appendix).

Allegheny County

Liberty-Clairton area emissions were subtracted from Allegheny County, by SCC. (If 

result was <0, emissions were set to 0.)
Page 16

2007 Point Source Emissions Totals for Allegheny and Washington County 

Facilities

Facility SO2 NOx CO VOC NH3 PM10 PM2_5

Allegheny

ACN-PITTSBURGH, LLC 0.052 3.070 1.760 66.267 0.000 8.790 7.870

ALLEGHENY LUDLUM CORP - BRACKENRIDGE 37.031 246.261 196.567 73.216 0.000 328.363 274.060

ALLIED WASTE SERVICES OF PENNSYLVANIA 8.740 63.050 12.390 7.200 0.000 43.360 42.480

ASHLAND INC 0.076 18.583 36.510 17.153 0.090 1.325 1.246

BAY VALLEY FOODS, LLC 543.033 208.090 49.500 4.060 0.000 70.680 59.990

BELLEFIELD BOILER PLANT 707.402 253.800 27.417 3.233 0.000 108.235 77.685

Braddock Recovery 1.660 4.882 1.123 0.073 0.000 1.698 1.696

CALGON CARBON CORPORATION 2.939 4.458 5.218 1.948 458.500 2.862 2.281

Chambers Development Co 5.065 52.118 12.580 8.886 0.000 16.897 9.352

Clairton Slag 0.773 10.946 9.157 1.149 0.000 3.039 2.748

Consol Coal 0.680 0.170 0.038 0.020 0.000 0.660 0.660

CP Industries 0.006 1.066 0.895 1.019 0.000 8.702 0.943

EASTMAN CHEMICAL RESINS, INC. 4.399 73.230 29.750 177.747 0.120 22.029 17.569

Gardner Denver Nash 0.017 2.155 1.795 1.915 0.000 0.186 0.186

GE Apparatus 0.005 0.751 0.631 0.072 0.000 0.115 0.115

GE CONSUMER PRODUCTS, LIGHTING 0.066 66.764 9.970 0.738 0.000 19.842 19.840

GM Metal Stamping 0.946 6.481 2.981 1.813 0.000 3.184 1.283

GUARDIAN INDUSTRIES CORP. FLOREFFE 82.429 686.632 10.340 13.881 0.000 26.970 19.972

GULF OIL L.P. 0.310 4.100 9.700 28.065 0.000 3.557 2.037

IRON CITY BREWING CO. 15.390 7.480 6.120 1.558 0.000 4.704 2.372

Jefferson Crematory 0.170 0.060 0.002 0.001 0.000 0.060 0.060

Kelly Run Sanitation 1.689 15.810 13.192 1.649 0.000 6.727 4.984

Kinder-Morgan Liquids Terminal 0.192 2.671 2.033 1.779 0.000 0.210 0.202

LAUREL MOUNTAIN WHIRLPOOLS, INC. 0.000 0.080 0.080 5.037 0.000 0.008 0.008

LIBERTY PULTRUSIONS 0.003 0.480 0.400 11.260 0.000 0.089 0.050

Marathon Ashland West Eliz 0.030 4.850 4.070 2.000 0.063 0.370 0.370

NEVILLE CHEMICAL COMPANY 3.150 22.734 11.894 116.587 0.505 5.320 4.187

NRG ENERGY CENTER PITTSBURGH 0.160 40.510 24.480 1.590 0.000 2.590 2.590

PITT PENN OIL COMPANY 0.004 1.740 1.180 6.117 0.000 0.075 0.075

PITTSBURGH ALLEGHENY COUNTY THERMAL, LTD 0.200 74.330 30.780 2.004 0.000 2.730 2.730

PITTSBURGH TERMINALS CORP NEVILLE ISLAND 0.030 0.465 0.290 27.401 0.000 0.030 0.030

PITTSBURGH TERMINALS CORP. - CORAOPOLIS 0.000 0.070 0.050 35.837 0.000 0.005 0.005

PORT GLENSHAW GLASS, LLC 48.800 59.910 19.823 6.743 0.000 16.211 13.861

PPG INDUSTRIES, INC. - SPRINGDALE 0.025 4.190 3.510 86.326 0.000 2.050 2.050

PRECOAT METALS, DIV. OF SEQUA COATINGS 0.058 11.080 9.320 16.640 0.000 0.757 0.757

PRESSURE CHEMICAL COMPANY 0.003 0.550 0.460 11.400 0.000 0.040 0.040

Ryan Metals 0.360 0.050 0.000 0.010 0.000 7.100 7.100
Page 17

Facility SO2 NOx CO VOC NH3 PM10 PM2_5

Sanyo 0.000 0.000 0.000 8.603 0.000 1.726 1.726

SHENANGO INC. 295.477 770.247 428.271 71.792 1.894 203.743 182.557

SUN REFINING AND MARKETING, BLAWNOX 0.141 0.110 0.390 3.268 0.000 0.009 0.009

SUNOCO PARTNERS MARKETING & TERMINALS 0.001 0.080 0.060 24.835 0.000 0.006 0.006

Tube City IMS Braddock 0.000 0.000 0.000 0.000 0.000 27.865 3.072

Tube City IMS West Mifflin 0.001 0.167 0.140 0.012 0.000 1.025 0.522

TYK Refractories 0.047 7.974 6.693 4.581 0.000 0.478 0.478

UNIVERSAL STAINLESS & ALLOY PRODUCTS 13.060 58.099 99.590 25.377 0.000 24.115 18.100

US AIRWAYS MAINTENANCE BASE 0.018 3.000 2.440 19.430 0.000 0.268 0.259

US STEEL CORP - EDGAR THOMSON PLANT 1868.628 318.115 1300.948 68.643 0.450 874.041 803.292

US STEEL CORP - IRVIN PLANT 455.995 694.540 193.980 71.826 0.734 56.843 51.120

Allegheny Total 4099.262 3805.999 2578.519 1040.760 462.356 1909.689 1644.625

Liberty-Clairton

AKJ Industries 0.000 0.000 0.000 0.030 0.000 0.000 0.030

Bekavac Funeral Home 0.004 0.007 0.006 0.000 0.000 0.006 0.006

Dura-Bond Industries 0.689 12.366 3.959 1.077 0.000 4.596 3.600

ELG Metals 0.000 0.481 0.007 0.002 0.000 1.931 1.931

KOPPERS INC. CLAIRTON PLANT 0.325 13.580 13.840 15.229 0.000 7.371 5.961

Mid-Continent Coal & Coke 0.376 5.722 1.233 0.454 0.000 3.983 1.794

Mon Valley Transportation 0.000 0.000 0.000 0.000 0.000 8.120 3.758

Pennsylvania Electric Coil 0.003 0.340 0.284 2.040 0.000 0.026 0.026

Tech Met 0.000 2.030 0.000 1.140 0.000 0.000 0.000

Tube City IMS Clairton 0.000 0.001 0.000 0.000 0.000 0.310 0.310

US STEEL CORP - CLAIRTON PLANT 1739.948 4807.357 3559.262 570.576 18.419 1110.587 929.175

Liberty-Clairton Total 1741.345 4841.884 3578.590 590.548 18.419 1136.930 946.591

Washington

DOMINION PEOPLES/GIBSON STA 0.010 40.400 3.180 1.170 0.000 0.100 0.100

DYNO NOBEL INC/DONORA 0.000 244.300 11.300 0.700 10.800 59.899 47.982

Equitrans LP/Hartson 0.016 6.540 4.376 0.860 0.000 0.812 0.812

FLEXSYS AMER LTD PAR/MONONGAHELA 4.229 13.670 11.240 18.558 0.000 1.414 1.350

JESSOP STEEL CO/WASHINGTON 0.165 55.379 20.610 8.504 1.046 18.994 13.744

LANGELOTH METALLURGICAL/LANGELOTH 187.400 1.824 0.500 0.000 0.000 3.630 2.554

REGAL IND CORP/DONORA PLT 0.000 0.000 0.000 30.490 0.000 0.000 0.000

SEVERSTAL WHEELING/ALLENPORT 0.190 25.510 26.990 18.341 1.027 8.156 6.980

Therm-O-Rock New Eagle 0.009 1.440 1.230 0.090 0.000 5.301 3.884

UNION ELEC STEEL CORP/HARMON CREEK 1.737 52.280 81.198 14.372 0.000 12.514 10.922

USA South Hills Landfill 1.440 8.050 1.090 2.090 0.000 3.780 1.730

WORLD KITCHEN LLC/CHARLEROI 21.900 96.900 9.700 1.800 0.000 41.767 21.100

Washington Total 217.096 546.293 171.414 96.975 12.873 156.367 111.158
Page 18

Facility SO2 NOx CO VOC NH3 PM10 PM2_5

EGUs

ALLEGHENY ENERGY SUPPLY - SPRINGDALE 1.550 69.160 354.290 25.310 11.740 23.620 23.620

ALLEGHENY ENERGY SUPPLY CO/MITCHELL POWER STA 637.901 1495.639 31.350 11.700 0.000 152.450 79.850

ORION POWER MIDWEST - BRUNOT ISLAND 3.860 33.840 34.290 19.869 0.490 2.240 2.240

ORION POWER MIDWEST LP/ELRAMA POWER STA 4267.420 6027.450 230.930 22.420 6.930 1015.040 512.824

ORION POWER MIDWEST, CHESWICK STATION 34088.963 4455.162 297.582 10.367 0.629 601.352 501.181

EGU Total 38999.694 12081.251 948.442 89.666 19.789 1794.702 1119.715
Page 19

2014 Point Source Emissions Totals for Allegheny and Washington County 

Facilities

Facility SO2 NOx CO VOC NH3 PM10 PM2_5

Allegheny

ACN-PITTSBURGH, LLC 0.053 3.210 1.860 68.149 0.000 9.020 8.070

ALLEGHENY LUDLUM CORP - BRACKENRIDGE 36.987 263.370 210.900 73.890 0.000 329.298 275.024

ALLIED WASTE SERVICES OF PENNSYLVANIA 8.870 63.340 10.990 6.320 0.000 43.720 42.830

ASHLAND INC 0.086 22.832 36.230 16.783 0.090 1.582 1.505

BAY VALLEY FOODS, LLC 543.034 218.980 51.860 4.220 0.000 32.180 27.910

BELLEFIELD BOILER PLANT 707.402 253.800 27.417 3.233 0.000 108.235 77.685

Braddock Recovery 1.660 4.882 1.123 0.073 0.000 1.698 1.696

CALGON CARBON CORPORATION 2.953 4.900 5.610 1.964 461.350 2.877 2.293

Chambers Development Co 5.065 52.118 12.580 8.886 0.000 16.897 9.352

Clairton Slag 0.773 10.946 9.157 1.149 0.000 3.039 2.748

Consol Coal 0.680 0.170 0.038 0.020 0.000 0.660 0.660

CP Industries 0.006 1.066 0.895 1.019 0.000 8.702 0.943

EASTMAN CHEMICAL RESINS, INC. 4.399 73.230 29.750 177.747 0.120 22.029 17.569

Gardner Denver Nash 0.017 2.155 1.795 1.915 0.000 0.186 0.186

GE Apparatus 0.005 0.751 0.631 0.072 0.000 0.115 0.115

GE CONSUMER PRODUCTS, LIGHTING 0.077 69.545 12.292 0.870 0.000 20.003 19.993

GUARDIAN INDUSTRIES CORP. FLOREFFE 82.429 686.632 10.340 13.881 0.000 26.970 19.972

GULF OIL L.P. 0.310 4.200 9.960 28.805 0.000 3.540 2.020

Jefferson Crematory 0.170 0.060 0.002 0.001 0.000 0.060 0.060

Kelly Run Sanitation 1.689 15.810 13.192 1.649 0.000 6.727 4.984

Kinder-Morgan Liquids Terminal 0.192 2.671 2.033 1.779 0.000 0.210 0.202

LIBERTY PULTRUSIONS 0.003 0.480 0.400 11.260 0.000 0.089 0.050

Marathon Ashland West Eliz 0.030 4.850 4.070 2.000 0.063 0.370 0.370

NEVILLE CHEMICAL COMPANY 3.151 23.574 12.604 117.008 0.505 5.329 4.189

NRG ENERGY CENTER PITTSBURGH 0.160 42.660 25.760 1.660 0.000 2.690 2.690

PITT PENN OIL COMPANY 0.004 1.610 1.030 6.108 0.000 0.075 0.075

PITTSBURGH ALLEGHENY COUNTY THERMAL, LTD 0.200 78.260 32.400 2.094 0.000 2.860 2.860

PITTSBURGH TERMINALS CORP NEVILLE ISLAND 0.030 0.465 0.290 28.161 0.000 0.030 0.030

PITTSBURGH TERMINALS CORP. - CORAOPOLIS 0.000 0.070 0.050 36.807 0.000 0.005 0.005

PORT GLENSHAW GLASS, LLC 48.800 59.960 19.862 6.743 0.000 16.203 13.853

PPG INDUSTRIES, INC. SPRINGDALE 0.030 5.240 4.390 86.856 0.000 2.110 2.110

PRESSURE CHEMICAL COMPANY 0.004 0.690 0.570 11.470 0.000 0.050 0.050

Sanyo 0.000 0.000 0.000 8.603 0.000 1.726 1.726

SHENANGO INC. 325.580 781.417 429.951 71.862 1.894 206.001 184.441

SUN REFINING AND MARKETING, BLAWNOX 0.171 0.130 0.480 4.080 0.000 0.010 0.010

SUNOCO PARTNERS MARKETING $ TERMINALS L. 0.001 0.080 0.060 25.505 0.000 0.006 0.006

Tube City IMS Braddock 0.000 0.000 0.000 0.000 0.000 27.865 3.072
Page 20

Facility SO2 NOx CO VOC NH3 PM10 PM2_5

Tube City IMS West Mifflin 0.001 0.167 0.140 0.012 0.000 1.025 0.522

TYK Refractories 0.047 7.974 6.693 4.581 0.000 0.478 0.478

UNIVERSAL STAINLESS & ALLOY PRODUCTS 13.060 58.639 100.050 25.397 0.000 24.128 18.113

US AIRWAYS MAINTENANCE BASE 0.020 3.660 3.040 19.642 0.000 0.295 0.286

US STEEL CORP - EDGAR THOMSON PLANT 1868.628 318.115 1300.948 68.643 0.450 874.041 803.292

US STEEL CORP - IRVIN PLANT 455.995 694.540 193.980 71.826 0.734 56.843 51.120

Allegheny Total 4112.772 3837.250 2585.424 1022.743 465.206 1859.977 1605.163

Liberty-Clairton

AKJ Industries 0.000 0.000 0.000 0.030 0.000 0.000 0.030

Bekavac Funeral Home 0.004 0.007 0.006 0.000 0.000 0.006 0.006

Dura-Bond Industries 0.689 12.366 3.959 1.077 0.000 4.596 3.600

ELG Metals 0.000 0.481 0.007 0.002 0.000 1.931 1.931

KOPPERS INC. CLAIRTON PLANT 1.831 15.599 17.872 11.769 0.000 7.505 6.095

Mid-Continent Coal & Coke 0.376 5.722 1.233 0.454 0.000 3.983 1.794

Mon Valley Transportation 0.000 0.000 0.000 0.000 0.000 8.120 3.758

Pennsylvania Electric Coil 0.003 0.340 0.284 2.040 0.000 0.026 0.026

Tech Met 0.000 2.030 0.000 1.140 0.000 0.000 0.000

Tube City IMS Clairton 0.000 0.001 0.000 0.000 0.000 0.310 0.310

US STEEL CORP - CLAIRTON PLANT 1717.620 4312.803 4197.691 443.540 17.554 827.180 645.103

Liberty-Clairton Total 1720.523 4349.349 4221.051 460.052 17.554 853.657 662.653

Washington

DOMINION PEOPLES/GIBSON STA 0.010 41.600 2.870 1.020 0.000 0.100 0.100

DYNO NOBEL INC/DONORA 0.000 248.630 13.030 0.800 10.850 60.360 48.370

Equitrans LP/Hartson 0.016 6.540 4.376 0.860 0.000 0.812 0.812

FLEXSYS AMER LTD PAR/MONONGAHELA 4.251 15.044 12.401 18.729 0.000 1.444 1.384

JESSOP STEEL CO/WASHINGTON 0.143 59.960 25.670 8.750 1.180 19.130 13.900

LANGELOTH METALLURGICAL/LANGELOTH 187.400 1.820 0.500 0.000 0.000 3.630 2.540

REGAL IND CORP/DONORA PLT 0.000 0.000 0.000 30.490 0.000 0.000 0.000

SEVERSTAL WHEELING/ALLENPORT 0.204 27.070 29.710 18.480 1.090 8.180 7.012

Therm-O-Rock New Eagle 0.009 1.440 1.230 0.090 0.000 5.301 3.884

UNION ELEC STEEL CORP/HARMON CREEK 1.720 52.260 81.160 14.350 0.000 12.480 10.890

USA South Hills Landfill 1.440 8.050 1.090 2.090 0.000 3.780 1.730

WORLD KITCHEN LLC/CHARLEROI 21.910 35.920 12.090 1.940 0.000 41.990 21.310

Washington Total 217.103 498.334 184.127 97.599 13.120 157.207 111.932

EGUs

ALLEGHENYENERGYSUPPLYCO/MITCHELL 948.097 1335.000 44.054 17.311 0.000 181.931 102.098

ALLEGHENYENERGYSUPPLY-SPRINGDALE 0.000 40.131 86.190 2.155 7.121 0.446 0.320

ORIONPOWERMIDWEST,CHESWICKSTATION 2914.592 2825.813 319.295 25.553 19.457 716.111 697.418

ORIONPOWERMIDWEST/ELRAMA 1846.000 1943.000 99.725 9.682 2.991 438.450 221.481
Page 21

Facility SO2 NOx CO VOC NH3 PM10 PM2_5

ORIONPOWERMIDWEST-BRUNOTISLAND 4.430 14.269 5.259 0.217 0.394 0.299 0.292

EGUs Total 5713.119 6158.212 554.523 54.918 29.964 1337.236 1021.608
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In the Matter of: 

United States Steel Corporation 

600 Grant St. 

Pittsburgh, P A 15219-2800 

CONSENT ORDER and AGREEMENT 

THIRD AMENDMENT 

This CONSENT ORDER and AGREEMENT (Agreement) was entered into on March 

17,2008 by and between the Allegheny County Health Department (ACHD) and United States 

Steel Corporation (U. S. Steel), collectively referred to as "Parties." The First Amendment to the 

Agreement was entered into and effective on November 19,2008. The Second Amendment to 

the Agreement (Second Amendment to the 2008 COA) was entered and effective on September 

30,2010. In addition, a separate COA for B Battery was entered and effective on June 1,2007. 

This Third Amendment to the 2008 COA supersedes and replaces the Agreement entered on 

March 17,2008 in its entirety, the First Amendment to the Agreement in its entirety; the Second 

Amendment to the Agreement in its entirety, and the June 1,2007 COA in its entirety; and, as 

such, the above referenced March 17, 2008 Agreement, the First Amendment to the Agreement, 

the Second Amendment to the 2008 COA, and the June 1, 2007 COA are all hereby terminated 

in their entirety. 

The ACHD has found and determined the following: 

A. The Director of the ACHD has been delegated authority pursuant to the federal Clean Air 

Act, 42 U.S.C. §§ 7401 et seq., and the Pennsylvania Air Pollution Control Act, 35 P.S. §§ 

4001 et seq., and the ACHD is a local health agency organized under Local Health 

Administration Law, Act 315 of August 24, 1951, P.L. 1304, as amended, 16 Pa.C.S. 

§I200I et seq., whose powers and duties include the enforcement of laws relating to public 

health within Allegheny County, including the Allegheny County Health Department's 

Rules and Regulations, Article XXI, Air Pollution Control (Article XXI). 

B. U. S. Steel operates coke oven batteries 1,2,3, 13, 14, 15, 19,20, and B (Batteries) located 

in Clairton, P A. 

Page 1 of32 































F-3: Regional 2014 Interpolations/Projections
{This page left blank for printing purposes}
LIBERTY-CLAIRTON PM2.5 SIP

LOCAL AND ADDITIONAL PROJECTIONS 2014

COUNTY OF ALLEGHENY CONTRACT NUMBER 130103

CONSULTANT TECHNICAL SUPPORT FOR AIR POLLUTANT AREA AND MOBILE SOURCES 

ANALYSIS

Prepared for:

Allegheny County Health Department

301 39th Street

Pittsburgh, PA 15201-1891

Prepared by:

TranSystems

5528-B Hempstead Way

Springfield, VA 22151

November 27, 2012
1

SUMMARY

This appendix describes the methods that were used to estimate 2014 emissions for regions whose emissions have 

the potential to affect particulate matter with an aerodynamic diameter of 2.5 microns or less (PM2.5) concentrations in 

the Liberty-Clairton area. The regions covered here include the Lake Michigan states and the Mid-Atlantic and 

Northeast states. TranSystems developed a non-electricity generating point source emissions file for 2014 for the 

Lake Michigan states. For the Mid-Atlantic and Northeast states, TranSystems developed 2014 emission files for 

non-electricity generating unit (EGU) point sources, area sources, and nonroad mobile sources (including marine 

aircraft and railroad locomotive emissions).

I. LAKE MICHIGAN STATES NON-EGU POINT SOURCES

For the Lake Michigan states, while that region had sponsored a contractor study that developed growth and control 

factors for the region from a 2008 base year, at the time of this analysis (June 2012) the Lake Michigan Air Directors 

Consortium (LADCO) had not used the growth and control factor data files to generate any future year emission files. 

Therefore, in order to generate a 2014 non-EGU point source emission file for the Lake Michigan states, it was 

necessary to use the growth and control factor files from the LADCO-sponsored study (TranSystems, 2011) to 

generate a best estimate of 2014 non-EGU emissions for the LADCO states.

Because the National Emissions Inventory (NEI) 2008 emissions file was used by the Allegheny County Health 

Department (ACHD) to represent base year emissions, that file rather than the point source file that was supplied by 

the LADCO states for the 2011 TranSystems study was used as the base year emissions file for developing the 2014 

emission forecast file. The LADCO state non-EGU inventories were developed according to LADCO methods for 

Illinois, Indiana, Michigan, Ohio, and Wisconsin. While the LADCO-sponsored growth and control factor 

development project also examined Minnesota, the 2014 emission estimates for Minnesota were from the U.S. 

Environmental Protection Agency (EPA) files developed for the Cross State Air Pollution Rule analysis.

The information that follows is from the report describing how the control factors were originally developed for 

LADCO. This explains the key regulations that were captured in the non-EGU point source analysis. While the 

analysis for LADCO included regulations and standards that have a potential effect on emissions through 2030, this 

analysis only incorporates the control factors that are expected to affect emissions in the period from 2008 to 2014.

A. LADCO NON-EGU POINT SOURCES CONTROL FACTOR DEVELOPMENT

1. NOx SIP Call

All states in the LADCO region affected by the oxides of nitrogen (NOx) State Implementation Plan (SIP) Call 

requirements (Ohio, Indiana, Illinois, Michigan) indicated that their sources were complying in 2008. Therefore, no 

control factors are applied post-2008 to NOx SIP Call affected sources.

2. Maximum Achievable Control Technology (MACT) Standards

After considering the list of EPA MACT standards affecting point sources with compliance dates after 2008, it was 

decided that the LADCO states would apply control factors only to those source categories to which control factors 

were applied in the comparable Mid-Atlantic Regional Air Management Association (MARAMA) Mid-Atlantic 

Northeast Visibility Union (MANE-VU) projections analysis. This decision was reached in part because the 

additional interim pollutant emission reductions from the newest set of MACT standards is expected to be modest, 

plus there has been no EPA guidance to states on how to estimate the volatile organic compound (VOC), NOx, and 

particulate matter (PM) benefits of these national emission standards for hazardous air pollutants (NESHAPs).
2

Reciprocating Internal Combustion Engine (RICE) Rules

EPA has prepared Source Classification Code (SCC)-level percentage reduction estimates from uncontrolled 

emission levels for their recent RICE MACT rules. Because LADCO expressed a preference for reflecting 

incremental reductions relative to baseline emissions in this project‟s control factor files, TranSystems reviewed the 

technical supporting documents for the RICE MACT rules for relevant information. For the RICE MACT rules for 

spark-ignition (SI) engines, EPA reports both baseline and post-control emission estimates for carbon monoxide 

(CO), NOx, and VOC (EPA, 2010). This information was used to develop the overall SI engine MACT reductions 

for each pollutant that were incorporated into the LADCO control factor files. Because analogous information was 

not available for the compression ignition (CI) engine MACT rule, it was necessary to rely on EPA‟s estimates of 

CO, PM, and VOC reductions relative to uncontrolled emissions (we do not expect that affected CI engines are 

controlled in the baseline to a significant degree, however). To identify the SCC/pollutant combinations to which 

the RICE MACT rules apply, the SCC/pollutant information incorporated into EPA‟s most recent emissions 

modeling files was used – control factor files prepared in support of version 4.1 of EPA‟s 2005-based air quality 

modeling platform (EPA, 2011). In keeping with EPA statements, the control factor files assume compliance with 

the CI engine standards by May 3, 2013, and the SI engine standards by October 19, 2013. 

3. Best Available Retrofit Technology (BART)/Consent Decree Sources

The control information for BART and Consent Decree sources is based on information provided by the state air 

pollution control agencies in the Midwest and is shown in Table 1. For this analysis, BART and Consent Decree 

requirements were considered together because some states examined what the consent decrees require for 

potential BART sources, and then make judgments about whether the reductions required by the consent decree are 

equal to or more stringent than BART.

4. Control Technique Guidelines

The Ohio EPA expects to revise its VOC emission regulations in the Cleveland-Akron-Lorain ozone nonattainment 

area in response to the new control technique guidelines (CTGs) issued by EPA between 2006 and 2008, and that 

agency estimated the effects of their expected revised regulations on VOC emissions. A summary of the key source 

categories and associated future year emission reductions is described below.

Miscellaneous Industrial Adhesives: Ohio EPA provided separate tables identifying counties affected by 

“Adhesive Processes” and “Industrial Adhesives” controls. However, they only provided compliance date information 

for “Miscellaneous Industrial Adhesives” (May 1, 2012), and the “Adhesive Processes” information table cites a state 

rule that regulates miscellaneous industrial adhesives. To address the overlaps in the Ohio EPA list of affected 

SCC/counties, TranSystems applied the 50 percent VOC emission reduction that Ohio EPA provided for 

Miscellaneous Industrial Adhesives only to records for which there was not an overlapping SCC/county reported in 

the “Adhesives Processes” table. In keeping with Ohio EPA guidance, TranSystems applied a 40 percent VOC 

emission reduction for all SCC/county combinations in the “Adhesive Processes” table. The 50 and 40 percent 

reductions reflect the estimates reported in Ohio EPA‟s “probable reductions” columns in each table.

Automobile and Light-Duty Truck (LDT) Coating processes: Ohio EPA estimates a probable 15 percent 

additional VOC emission reduction attributable to VOC RACT regulations implementing the new CTG for this source 

category. The Ohio EPA provided a list of SCC/county combinations in the Cleveland-Akron-Lorain ozone 

nonattainment area affected by this CTG. In some cases these SCC/county combinations were listed as affected by 

other CTGs. TranSystems applied the 15 percent VOC reduction to only those SCC/county combinations for which a 

CTG with a higher percentage reduction was not also identified by Ohio.
3

Table 1. Lake Michigan State BART Eligible Non-EGU Sources

State State 

ID Source Name County County ID Source ID

BART 

Emission 

Unit ID

Description Stack ID

Estimated Emission 

Reduction (%)

Estimated 

Compliance 

Dates

Sulfur 

Dioxide (SO2)

NOx SO2 NOx

ILLINOIS 17 Conoco Phillips Madison 119 119090AAA FCCU1 (Wood River) 90 50 121708 121708

FCCU 2 (Wood River) 90 50 121510 121510

ILLINOIS 17 Exxon Mobil Will 197 197800AAA FCCU 15 90 123111

ILLINOIS 17 CITGO Will 197 197090AAI FCCU Catalyst 

Regeneration 112D-1

7 90 123111

ILLINOIS 17 Marathon Crawford 033 033808AAB 50 123108

INDIANA 18 AGC DIVISION-ALCOA 

POWER GENERATING Warrick 173 00002 Boiler #2 Dry Bottom, pulverized coal-fired boiler 241-242 95 5 010109 010109

Boiler #3 Dry Bottom pulverized 

coal-fired boiler 242 95 5 010109 010109

Boiler #4 Dry Bottom, pulverized 

coal-fired boiler 243 95 5 010109 010109

MICHIGAN 26 Lafarge Midwest Inc. Alpena 007 B1477

EU-KILNS 

19, 20, 21, 

22, & 23

Three Portland Cement 

kilns (KG 5)

SV0031, 

32, 33 90 34 031212 031212

19 90 34 120112 031212

20 90 34 120112 031212

21 90 34 120112 031212

22 90 34 030114 031212

23 90 34 030114 031212

OHIO 39 P.H. Glatfelter Ross 067 0671010028 B002 Please see description in 

text (above). SV-5001

90

123114

B003 Please see description in 

text (above). SV-5001 123114
4

Miscellaneous Metal Coating: A 10 percent VOC emission reduction was applied to the SCCs and counties 

identified by Ohio EPA as affected by revised VOC RACT rules for miscellaneous metal coating processes. As with 

the Automobile and LDT Coating CTG, TranSystems applied this reduction to only those SCC/county combinations 

for which Ohio did not identify another CTG with a higher percentage emissions reduction.

5. NOx RACT

Ohio EPA provided estimates of the expected post-2008 NOx emission reductions for four facilities in the ClevelandAkron-Lorain ozone nonattainment area. These emission reductions are listed in Table 2 along with the affected 

facility and source identifiers provided by Ohio. We were not able to identify complete matches to this information in 

the LADCO base year inventory -- we assumed that the U.S. Steel facility was associated with SITE ID 02470780961 

(note addition of leading zero), and we included all base year NOx emission records for Alcoa SITE ID 1318170314 

because we were unable to identify POINT ID B004 and B005 records in the inventory.

B. EMISSIONS ACTIVITY GROWTH DATA

The LADCO region non-EGU point source emission estimates for 2014 used growth factors developed for LADCO 

during 2011 (TranSystems, 2011). The growth factor file used included growth factors for every forecast year after 

the base year, so for this assessment, the growth factor applied was the 2008 to 2014 growth factor. Growth factors 

are organized by EPA SCC.

For the LADCO state non-EGU projections, the general approaches used to develop emissions activity growth data 

were derived from data or projection methods used to support EPA efforts to improve non-EGU stationary source 

emission forecasts (Pechan, 2010 and Chappell, 2010).

With two major exceptions, TranSystems developed stationary source growth factors for LADCO by interpolating 

growth factors for the LADCO years of interest from the EPA growth factors, which represented emissions activity 

changes from a 2005 base year to each fifth year over the period 2010-2030. To the extent that source categories in 

the LADCO inventory did not match those available from the EPA project, a growth factor was assigned to the growth 

indicator that was applied to the most closely related SCC in the EPA database.

The first major exception to the general growth factor development approach was to update the EPA growth factors 

that were based on forecasts from the Energy Information Administration (EIA)‟s Annual Energy Outlook (AEO) to 

reflect projections from the latest (2011) AEO. Many of the EPA stationary source categories growth rates are based 

on AEO energy or socioeconomic forecasts. The majority of the AEO-based projections used reflected regional 

forecasts – i.e., the same growth rate is applied to each LADCO state because these states comprise the East North 

Central division.

For the following non-combustion priority stationary point source categories, EPA developed projections data using a 

variety of methods and data sources: 1) Carbon Black; 2) Cement Manufacturing; 3) Copper Production; 4) Glass 

Manufacturing; 5) Iron and Steel Manufacturing; 6) Petroleum Refining; 7) Primary Aluminum Manufacturing; 8) Pulp 

and Paper Manufacturing; 9) Secondary Aluminum Production; and 10) Sulfuric Acid Production. These 

methods/data sources included:

Regression analysis of historical NEI emissions with US Bureau of Census production and factor of

production data;

Industry output forecasts;

EGAS Version 5.0 projections;

EMPAX-CGE industry growth projections;

Chemical Economics Handbook information;
5

Table 2. Lake Michigan State NOx RACT Summary

Facility Name Facility ID Point ID

NOx Emissions 2008

(tons)

Future Reductions 

w/controls

(tons)

NOx Reduction 

Percentage

Emerald Performance 1677010029 B008 233 70 30

U.S. Steel 247080961 P039 178 120 67

Alcoa 1318170314 B004 & B005 96 73 76

NASA 1318001169 B005 54 40 74
6

US Bureau of Census data;

Department of Energy, Annual Energy Outlook 2010 forecasts; and 

Consultation with EPA industry sector experts.

More details on the priority stationary point source category emissions activity projection methods/data sources are 

provided in an EPA memorandum (Chappell, 2010).

C. RESULTS

Using the LADCO state growth factor file and control factor file for non-EGU point sources, the 2014 emissions were 

estimated as:

2014 emissions = 2008 emissions * GF (2008 to 2014) * (1-CF)

where:

GF = growth factor by county and SCC

CF = control factor by county and SCC

Table 3 provides state-level non-EGU point source emission summaries for the five Lake Michigan states. This table 

shows the estimated 2008 non-EGU emissions in these states followed by the 2014 estimates developed using 

growth and control factors. Percentage differences between 2008 and 2014 emissions are also provided. The most 

significant expected non-EGU point source emission reductions are for NOx and SO2, and are observed in Illinois and 

Michigan.

Table 3. Lake Michigan State Non-EGU Point Source Emission Estimates (tons per year) 2008 versus 2014

2008 Non-EGU

State VOC NOx CO SO2 PM10 PM2.5

Ammonia 

(NH3)

Illinois 51,489 82,101 93,090 106,750 19,424 10,948 1,296

Indiana 37,405 65,015 335,738 70,690 33,284 24,791 781

Michigan 27,833 72,612 76,461 56,941 19,246 11,311 711

Ohio 30,898 58,549 246,343 106,893 22,919 19,080 2,982

Wisconsin 30,420 39,720 62,937 60,013 9,047 1,088 424

Region Totals 178,044 317,997 814,569 401,287 103,920 67,218 6,193

2014 Non-EGU

State VOC NOx CO SO2 PM10 PM2.5 NH3

Illinois 52,777 80,260 76,562 86,031 19,696 11,115 1,407

Indiana 37,697 72,837 393,114 64,362 36,070 26,672 859

Michigan 28,141 74,518 70,262 42,936 19,325 11,547 782

Ohio 31,573 61,308 255,859 92,201 24,297 20,472 3,288

Wisconsin 27,789 37,916 33,898 46,993 8,698 894 444

Region Totals 177,977 326,838 829,695 332,523 108,086 70,699 6,779

Percentage Difference

State VOC NOx CO SO2 PM10 PM2.5 NH3

Illinois 2.5% -2.2% -17.8% -19.4% 1.4% 1.5% 8.6%

Indiana 0.8% 12.0% 17.1% -9.0% 8.4% 7.6% 10.0%

Michigan 1.1% 2.6% -8.1% -24.6% 0.4% 2.1% 9.9%

Ohio 2.2% 4.7% 3.9% -13.7% 6.0% 7.3% 10.3%

Wisconsin -8.6% -4.5% -46.1% -21.7% -3.9% -17.9% 4.8%

Region Totals 0.0% 2.8% 1.9% -17.1% 4.0% 5.2% 9.5%
7

SO2 emission declines in Wisconsin are attributable to expected reduced activity for the sectors with the most 

significant SO2 emissions (rather than control programs). The SO2 emission reductions estimated for 2014 in Illinois 

are attributable both to activity declines and expected control programs. The effects of activity declines and control 

programs are about equal. SO2 emission reductions estimated for this sector in Ohio (a 13.7 percent reduction) and 

Indiana (a 9 percent reduction) are all from expected declines in economic activity. The expected SO2 emission 

reductions in Michigan are mostly attributable to controls at BART eligible cement kilns.

II. MID-ATLANTIC STATES AND NEW ENGLAND STATES

A. REGIONAL EMISSION INVENTORIES

MARAMA coordinated the development of regional emission inventories for air quality modeling. The inventory 

includes emissions from Connecticut, Delaware, the District of Columbia, Maine, Maryland, Massachusetts, New 

Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, and Virginia. Version 2 of the 2007 

Emission Inventory and Version 2 of the Future Years Emission Inventories were used in this analysis (Vickers et al., 

2011).

The focus of the effort for the MARAMA/MANE-VU states was on using the available 2017 forecast year emission 

estimates by sector along with 2007 base year emission estimates for these sectors to interpolate to estimate 2014 

emissions. This interpolation was used to estimate 2014 emissions for the following sectors:

1. Non-EGU Point

2. Area

3. Nonroad (including marine, aircraft, and rail)

The general formula for performing the interpolations was as follows:

2014 Emissions = ((2017 Emis – 2007 Emis) / (2017-2007)) * (2014-2007) + 2007 Emis

The 2017 Existing Controls file was used to estimate 2017 emissions.

B. ALLEGHENY COUNTY EMISSION INVENTORIES

The MARAMA/MANE-VU emission estimates for Allegheny County were reviewed to understand where transport 

factors needed to be applied in order to estimate PM10 and PM2.5 emissions for regional modeling. This was done by 

comparing NEI Information Format (NIF) and Sparse Matrix Operator Kernel Emissions Model (SMOKE) format files. 

It was found that the transport factor for Allegheny County, Pennsylvania was 0.2308 for all of the fugitive dust SCCs 

to which it is applied. Those SCCs include:

Fugitive Dust Source Type SCCs

1. Paved Roads 2294000000

2. Unpaved Roads 2296000000

3. Construction Activity 2311010000, 2311020000, 2311030000

4. Agricultural Tilling 2801000003

These PM transport factors were applied to the PM10 and PM2.5 emission estimates for the above SCCs in order to 

provide the appropriate emission files for use in regional modeling of the Allegheny County emissions contribution.
8

C. RESULTS

Tables 4, 5, and 6 summarize the MARAMA/MANE-VU state-level 2014 emission estimates that were developed for 

the region using the interpolation methods described above.

Table 4. MARAMA/MANE-VU State 2014 Emission Estimates – Area Sources (tons per year)

State CO NH3 NOx PM10 PM2.5 SO2 VOC

Connecticut 39,161 4,442 11,497 15,444 8,077 13,885 49,631

Delaware 7,996 14,378 2,218 7,459 2,431 1,005 8,886

District of Columbia 5,319 186 1,556 2,494 1,118 1,069 5,397

Maine 48,235 6,063 6,169 19,943 8,359 8,453 27,869

Maryland 73,098 26,058 10,757 40,368 15,082 2,959 59,260

Massachusetts 76,605 13,876 19,365 58,100 18,258 17,155 72,091

Michigan 38,087 1,520 4,328 10,656 5,655 4,508 21,329

New Jersey 74,800 16,183 23,584 25,275 14,804 3,138 92,417

New York 214,378 46,062 66,213 147,081 48,898 29,169 187,781

Pennsylvania 207,566 75,939 46,411 139,341 49,798 59,090 168,439

Rhode Island 14,641 628 3,352 5,691 2,901 3,425 21,464

Vermont 47,918 8,013 3,748 18,535 9,000 3,336 12,850

Virginia 130,265 45,122 18,604 78,050 29,303 15,546 137,431

Area Total 978,071 258,470 217,802 568,437 213,684 162,738 864,844

Table 5. MARAMA/MANE-VU State 2014 Emission Estimates – Nonroad Mobile Sources (tons per year)

State CO NH3 NOx PM10-PRI PM2.5-PRI SO2 VOC

Connecticut 155,055 19 10,941 1,107 1,048 262 14,478

Delaware 44,684 6 3,667 353 335 85 4,869

District of Columbia 11,468 3 1,911 169 163 61 922

Maine 103,816 14 5,883 913 853 136 22,476

Maryland 262,786 33 18,468 2,027 1,919 456 25,406

Massachusetts 266,007 32 18,316 1,856 1,758 442 25,060

Michigan 78,247 11 6,440 670 631 144 12,853

New Jersey 387,029 45 25,403 2,656 2,516 610 33,457

New York 774,851 94 52,125 5,397 5,116 1,270 81,547

Pennsylvania 589,514 68 37,935 4,289 4,062 950 61,887

Rhode Island 41,312 5 2,960 270 256 68 4,036

Vermont 40,934 6 2,777 374 351 65 7,802

Virginia 359,400 50 28,958 3,125 2,964 748 39,039

Nonroad Total 3,115,101 386 215,783 23,204 21,972 5,297 333,831
9

Table 6. MARAMA/MANE-VU State 2014 Emission Estimates – Non-EGU Point Sources (tons per year)

State CO NH3 NOx PM10 PM2.5 SO2 VOC

Connecticut 2,904 0 7,207 609 540 3,221 1,505

Delaware 7,191 58 3,720 1,010 913 6,635 2,827

District of Columbia 318 0 751 32 31 377 59

Maine 18,861 590 19,348 4,488 3,624 13,342 4,900

Maryland 71,027 137 22,627 5,287 3,523 30,055 4,841

Massachusetts 5,521 357 13,806 2,941 2,511 8,346 3,886

Michigan 4,159 34 3,178 1,223 1,136 2,678 1,284

New Jersey 7,061 214 12,012 3,246 2,467 2,769 9,733

New York 54,115 1,077 30,017 4,321 2,355 42,741 9,802

Pennsylvania 82,389 2,099 65,979 21,304 12,926 54,429 28,555

Rhode Island 924 14 883 174 124 1,441 938

Vermont 1,080 0 686 134 103 268 333

Virginia 64,558 1,673 51,556 12,568 9,913 52,401 35,294

Point Total 320,108 6,252 231,770 57,338 40,167 218,705 103,955

In the MARAMA 2007 and 2017 file organization, the emission estimates for the commercial marine vessel, aircraft, 

and railroad locomotive emissions are computed and stored separately from the nonroad mobile emission estimates 

computed using EPA‟s National Mobile Inventory Model (NMIM). Table 7 provides state-level estimates of 2014 

marine, aircraft, and locomotive emissions, along with comparisons with 2007 emissions.

Table 7. MARAMA/MANE-VU State Nonroad Mobile-Marine/Aircraft/Rail Emissions (tons per year)

2007 State Totals

State CO NH3 NOx PM10 PM2.5 SO2 VOC

Connecticut 5,921 3 8,964 423 387 1,538 744

Delaware 2,253 0 6,283 369 339 2,140 806

District of Columbia 88 0 512 12 12 38 35

Maine 33,589 0 3,162 506 450 295 445

Maryland 13,760 7 22,704 897 783 2,481 2,006

Massachusetts 17,615 2 12,570 769 651 983 1,924

Michigan 2,266 0 1,441 72 60 544 192

New Jersey 24,162 10 22,259 951 865 7,273 3,354

New York 23,939 2 55,852 2,419 2,253 10,637 4,588

Pennsylvania 30,820 22 35,790 1,623 1,429 3,694 4,505

Rhode Island 2,277 1 3,263 138 128 667 184

Vermont 2,493 0 839 64 49 17 232

Virginia 28,444 17 45,599 2,402 2,074 4,673 4,312

Regional Totals 187,627 66 219,236 10,645 9,479 34,980 23,328

2014 State Totals

State CO NH3 NOx PM10 PM2.5 SO2 VOC

Connecticut 5,504 3 6,824 274 247 629 663

Delaware 2,154 0 4,893 203 185 838 766

District of Columbia 89 0 404 9 8 12 28

Maine 33,459 0 2,691 325 284 111 397

Maryland 13,301 8 17,594 585 501 1,075 1,761

Massachusetts 16,824 2 10,138 602 499 498 1,714

Michigan 2,104 0 1,339 60 49 220 179

New Jersey 24,503 12 20,948 639 577 2,838 3,383

New York 24,446 2 44,206 1,570 1,466 4,332 4,203

Pennsylvania 30,464 22 28,766 1,144 989 1,667 4,110

Rhode Island 2,578 1 2,516 105 94 267 207

Vermont 2,273 0 866 58 45 14 217

Virginia 28,557 17 36,268 1,843 1,547 2,378 3,891

Regional Totals 186,255 68 177,453 7,414 6,491 14,880 21,519
10

Percentage Difference

State CO NH3 NOx PM10 PM2.5 SO2 VOC

Connecticut -7.0% 1.7% -23.9% -35.2% -36.0% -59.1% -10.9%

Delaware -4.4% 1.3% -22.1% -45.0% -45.5% -60.9% -5.0%

District of Columbia 1.0% -1.8% -21.1% -30.7% -30.9% -69.5% -21.7%

Maine -0.4% 0.0% -14.9% -35.8% -36.9% -62.2% -10.8%

Maryland -3.3% 0.7% -22.5% -34.8% -36.0% -56.7% -12.2%

Massachusetts -4.5% 5.3% -19.3% -21.8% -23.3% -49.3% -10.9%

Michigan -7.2% 0.0% -7.1% -17.4% -18.6% -59.6% -6.8%

New Jersey 1.4% 17.8% -5.9% -32.8% -33.3% -61.0% 0.9%

New York 2.1% -0.9% -20.9% -35.1% -34.9% -59.3% -8.4%

Pennsylvania -1.2% 0.6% -19.6% -29.5% -30.8% -54.9% -8.8%

Rhode Island 13.2% 2.0% -22.9% -24.3% -26.6% -60.0% 12.8%

Vermont -8.8% 5.6% 3.2% -9.2% -9.0% -14.9% -6.8%

Virginia 0.4% 1.0% -20.5% -23.3% -25.4% -49.1% -9.8%

Regional Totals -0.7% 3.6% -19.1% -30.4% -31.5% -57.5% -7.8%

D. REFERENCES

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Point Source Category Emission Projection Improvements, Addendum to E.H. Pechan & Associates, Inc.‟s 

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EPA, 2010: U.S. Environmental Protection Agency, “Regulatory Impact Analysis (RIA) for Existing Stationary Spark 

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EPA, 2011: U.S. Environmental Protection Agency, “Technology Transfer Network, Clearinghouse for Inventories & 

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Pechan, 2010: E.H. Pechan & Associates, Inc. “Development of New Emissions Projections Estimation Methods and 

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TranSystems, 2011: TranSystems Corporation, “Development of 2008 Base Year Growth and Control Factors for 

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Vickers et al., 2011: A. Vickers, J. McDill, and P. Davis, “MARAMA 2007/2017/2020 Modeling Emissions Inventory

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