# PM 2.5 

# 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

### {This page left blank for printing pur poses}

# F

- 1: Liberty

- Clairton Emission Inventories and Source

Assessment Analysis

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### 2007 AND 2014 LIBERTY-CLAIRTON PM 2.5



### NONATTAINMENT AREA EMISSION INVENTORIES AND

SOURCE ASSESSMENT ANALYSIS

COUNTY OF ALLEGHENY CONTRACT NUMBER 130103

CONSULTANT TECHNICAL SUPPORT FOR AI R POLLUTANT AREA A ND MOBILE SOURCES

ANALYSIS

Prepared for:

Allegheny County Health Department

301 39 th



### 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, 2012January 17, 2012

2007 and 2014 Liberty-Clairton PM 2.5

Nonattainment Area Emission Inventories and Source Assessment Analysis



### iii CONTENTS

Page

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

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

CHAPTER I. IN TRODUCTION ...................................................................................................... ............................... 1

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

CHAPTER II. AR EA SOURCES ..................................................................................................... .............................. 3

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

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

B. IDENTIFICATION OF PRIORI TY SOURCE CATEGORIES ............................................................. 3

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

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

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

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

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

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

6. Natural Gas Ex ploration .................................................................................................... 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 PRIORI TY SOURCE CATEGORIES ........................................................... 15

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

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

2. Commercial Mari ne Vessels .............................................................................................. 17

3. Diesel Constructi on (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/Fl eet Data Inputs .................................................................................. 24

2. I/M and Fuel Pa rameters ................................................................................................... 26

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

4. Vehicle Technol ogy/Programs .......................................................................................... 27

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

6. Vehicle Population Gr owth Assumption ............................................................................ 28January 17, 2012

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### iv 7. Final Results ................................................................................................................. .... 29

CHAPTER V. SOURCE IMPACT ANAL YSIS FOR THE LIBER TY MONITOR ........................................................... 31

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

B. LIMITATIONS OF EXISTING DATA AND AN ALYSES ................................................................... 33

C. MICROINVENTORY OF LOCAL SOURCES IN LIBERTY BOROUGH AND INVESTIGATION

OF OPERATIONAL IRREGULARITIES, TR ENDS, DAILY AND DIURNAL EMISSIONS

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

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

E. CONCENTRATION SPIKES POTENTIALLY I NDICATING UPSETS AND EQUIPMENT

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

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

2. Operating Pa tterns ............................................................................................................ 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 Or ganic Carbon ......................................................................................... 47

4. Ammonium Sulfate, Nitrate, and Secondary Organic PM 2.5



### .............................................. 48

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

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

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

TABLES AND FIGURES

Page

Table II-1. 2007 Allegh eny County Area Source Em issions (tons per year) ...................................................... ........... 3

Table II-2. RWC So urce Categories ............................................................................................. .................................. 4 Table II-3. Comparison of EPA RWC Tool Appliance Profil es and NAA Appli ance Profiles ......................................... 5

Table II-4. Residential Wood Combustion Gr owth Rates ......................................................................... ..................... 6

Table II-5. Area Source Cate gories for which Point Source Subtractions Were Performed ........................................ .. 8 Table II-6. Area Source Categor ies for which Point S ource Subtractions We re Not Performed ................................... 8

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

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

Table II-9. 2014 Area Source Emission Estimate s (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 Fa ctors (lbs/gallons fuel) ............................................... ........ 18 Table III-4. County to NAA Alloca tion for Construction Equipment ............................................................. ................ 19

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

Table III-6. 2007 Off-Road Emissions fo r Liberty-Clairton Ar ea (tons/year) ................................................... ............. 20

Table III-7. 2014 Off-Road Emissions fo r Liberty-Clairton Ar ea (tons/year) ................................................... ............. 20 Table IV-1. Summary of Analysis Tools ........................................................................................ .............................. 22 Table IV-2. Summary of Data Para meters for Liberty-Clairton ................................................................... .................. 24

Table IV-3. Base and Forecasted Vehi cle Miles of Travel (Millions) ............................................................ ................ 28 Table IV-4. Vehicle Popula tion Estimated Classified by MOVES Source Type ...................................................... ..... 28January 17, 2012

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Nonattainment Area Emission Inventories and Source Assessment Analysis



### v Table IV-5. Liberty-Clairton PM 2.5 

### NAA – On-Road Emissions Summar y by Road Type (t ons/year) .......................... 29
Table IV-6. Liberty-Clairton PM 2.5



### NAA On-Road Emission s Summary by Fuel Ty pe (tons/year) .............................. 29
Table V-1. Measured Composition of 20 Highest PM 2.5



### Days at Liberty Monitor ........................................................ 31 Table V-2. Comparison of Species Concentrations on Average and High Mass Concentration Days (μg/m 3 

### ) ........... 33

Table V-3. PMF Results for Hi ghest 20 Days Measured at Liberty Site, Liberty - Clairton NAA ................................. 35 Table V-4. Comparison of Species Concentrations at Hillman, Liberty and Lawrenceville Sites (μg/m 3 

### ) ................... 36

Table V-5. Point Source Facilities Believ ed to Contribute to Liberty-Clairton PM 2.5



### Nonattainment (a)



### ......................... 41 Table V-6. 2007 Emissions Summary for Liberty-Clairton PM 2.5



### NAA.......................................................................... 42 Table V-7. 2007 Emissions Summary for Sources in Allegheny County, PA - Outside the Liberty-Clairton PM 2.5 

### NAA ........................................................................................................................... ................................................... 43 Table V-8. Measured Sp ecies at Liberty Site fo r High and Low Days ............................................................ ............. 44 Table V-9. Monthly Vari ability in Measured K an d PMF Factor s 2 and 9 ......................................................... ........... 46 Table V-10. PMF Results at Liberty Site for All Da ys with Measured Speciation Data (2005 - 2010) ......................... 48

Figure IV-1. PPSU ITE Process ................................................................................................. .................................. 23 Figure V-1. Enrichment of Species Measured at Liberty Site Compared to Lawrenceville Site (μg/m 3 

### ) ..................... 32
Figure V-2. Excess PM 2.5



### (Liberty - Lawrenceville) Using PMF Analysis (μg/m 3 

### ) ....................................................... 32
Figure V-3. Locati on of Monitors in Areas Upwind of Li berty (SAHS) Air Mo nitoring Site ....................................... .... 36 Figure V-4. Liberty-Cla irton Tour Routing for October 5 and 6, 2011 .......................................................... ............... 39 Figure V-5. Sulfate, Nitrate and Ammo nium at Liberty Mo nitoring St ation ...................................................... ............ 49 Figure V-6. Com parison of Meas ured Chlorine at Liberty and Lawrence ville, by Month ........................................... .. 50January 17, 2012

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### vii 

# ACRONYMS AND ABBREVIATIONS

μg/m 3 

### 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 High way 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

NH 3 

### ammonia

NH 4 

### ammonium NLEV National Low Emission Vehicle Program NMIM National Mobile Inventory Model

NO 3 

### Nitrate

NO

x 

### 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

PM 10



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

PM 2.5



### particulate matter with an aerodynamic diameter of 2.5 microns or less

PMF Positive Matrix Factorization ppm parts per millionJanuary 17, 2012

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Nonattainment Area Emission Inventories and Source Assessment Analysis



### viii 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

SO 2 

### sulfur dioxide

SO 4 

### 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 compoundsJanuary 17, 2012

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### ix 

# ACKNOWLEDGEMENTS

This acknowledges the valuable assistance provided by Allegheny County Health Department (ACHD) staff with
surveying the key sources in the Liberty-Clairton PM 2.5



### 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.January 17, 2012

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### 1 

# 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. T he 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 (PM 2.5



### ) 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 loca ted 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 PM 2.5



### 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 PM 2.5



### State Implementation Plan (SIP) contains an analysis of 2002 continuous PM 2.5 

### data and inversion characterization. It shows a dramatic increase in PM 2.5



### concentrations when inversions are present (ACHD, 2011a).



## A. REPORT ORGANIZATION

This report documents the 2007 and 2014 PM 2.5



### and PM 2.5



### precursor emission inventories that were developed by TranSystems Corporation|E.H. Pechan & Associates (TS|Pechan) and Michael Baker Jr. Inc. for the Liberty-Clairton

PM 2.5



### 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 He alth Department (ACHD) st aff, so point source emis sions 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 MonitorJanuary 17, 2012

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### 2 [This page intentionally left blank.]January 17, 2012

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### 3 

# CHAPTER II. AREA SOURCES

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

INVENTORY SUMMARY

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

contributors to PM 2.5



### , sulfur dioxide (SO 2 

### ), and ammonia (NH 3 

### ) 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 PM 2.5



### - 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 SO 2 

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

of NH 3 

### emissions in Allegheny County.

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

Source Category PM 2.5

-PRI SO 2 NH 3 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 pr ioritized 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 unders tanding 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 PM 2.5



### emissions from these sources are from three SCCs:

 SCC 2104008100 – Fireplace: general;January 17, 2012

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### 4  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 de veloped 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 W ood Woodstove: fireplace inserts; EPA certified; non-catalytic
2104008230 Stationary Source Fuel Combustion Residential W ood 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 Resi dential Wood Woodstove: pellet-fired, general (freestanding or fireplace insert)

2104008510 Stationary Source Fuel Combustion Residentia l 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 applianc es 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 [G lassport, Liberty, Lincoln, and Port Vue]) (Census, 2011).January 17, 2012

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### 5 The RWC tool reports 544,711 occupied housing units in A llegheny County; the ACS reports 9,604 occupied units for

the NAA.

For item (2), we updated the wood appliance profiles with dat a 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 comparis on 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 A ppliance 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 perform s the allocation based on the ratio of the estimated county number of woodstoves that are used for main heating as esti mated 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 estimatedJanuary 17, 2012

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### 6 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 ef fect of the wood stove change-out program.

c. 2014 Estimation Method

To estimate the change in em issions activity for this cat egory, we applied residential wood combustion growth rate assumptions developed by EPA (EPA, 2008b). The grow th 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 W ood 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 (frees tanding 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 PM 2.5



### emissions. This category includes dust from multiple activities including travel
on paved roads and unpaved roads, constr uction activity, and agricultural tilling. Approximately 77 percent of total Allegheny County Fugitive Dust PM 2.5



### 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:January 17, 2012

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### 7  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 em issions 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/Instit utional (ICI) Fuel Combustion

a. Background

We understand that the Pennsylvania Department of En vironmental 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 t hat 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 SO 2 

### emissions.January 17, 2012

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### 8 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 Subtract ions 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 Commercia l/Institutional LPG Total: All Combustor
Types



### Table II-6. Area Source Categories for which Po int 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 so urce 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.January 17, 2012

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### 9 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 fo r this category is the mass of meat and french fries cooked on each of five equipment types (e.g., under-fir ed charbroiling).

b. Base Year Estimation Method

We are not aware of the availability of NAA-level emission s 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). A fter removing out-of-county entri es 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 lo wer 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 elimin ating emissions from this source category.January 17, 2012

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### 10 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 E nergy 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: SO 2 

### 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: NO

x 

### is emitted from the combustion of fossil fuels. NO

x 

### 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.January 17, 2012

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### 11 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 prod uced 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 em issions 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 perc ent 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 NO

x 

### 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 PM 2.5



### , SO 2 

### , and NH 3 

### , 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 NO

x 

### emission factors computed from the Barnett shale study by

the ratio of the NO

x 

### and the other pollutant’s emis sion factor as reported in EPA’s NONROAD model for compressor engines and drilling equipment engines . Note that although SO 2 

### 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 SO 2 

### emissions from this process.January 17, 2012

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

Emission Process VOC NO X PM 2.5

SO 2 NH 3

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 INVEN TORY 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 PM 2.5

-PRI SO 2 NH 3 VOC NO X 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 38.80 143.88January 17, 2012

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

Source Category PM 2.5

-PRI SO 2 NH 3 VOC NO X 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 38.46 138.26January 17, 2012

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### 14 [This page intentionally left blank.]January 17, 2012

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### 15 

# CHAPTER III. OFF-ROAD SOURCES

A. 2007 MANE-VU EMISSIONS INVENTORY SUMMARY

Table III-1 provides a summary of 2007 county-lev el off-road emissions for PM 2.5



### , SO 2 

### , and NH 3 

### , as calculated by MANE-VU for Allegheny County.

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

Offroad Category PM 2.5

- PRI SO 2 NH 3 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 comp rised 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 PM 2.5



### from diesel offroad equipment modeled by NMIM, 68 percent is due to diesel
construction equipment.

Aircraft emissions correspond primarily to operations at Pi ttsburgh 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, emissi on 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 PM 2.5



### 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.January 17, 2012

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### 16 

### 1. Locomotives

a. Background

Current emission estimates for Allegh eny County Class I and Class II/III line ha ul 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 pr epared 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 Railro ad Association and Class II/III rout e 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 with in 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 Compan y (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.January 17, 2012

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### 17 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 NO

x 

### , particulate matter with an aerodynamic diameter of 10 microns or less (PM 10



### ), PM 2.5



### , VOC, as well as SO 2 

### were modeled. Control factors were based on the ch ange in fleet-average emission factors published by EPA between 2007 and 2014 (EPA, 2009). For SO 2 

### , 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 La ke 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 re port obtained from the Port of Pittsbur gh 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 Rive r. The report provided the number of tug trips traveling upbound a nd downbound through each of thes e locks. A summary of the data obtained is pr ovided 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 9,136,200January 17, 2012

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### 18 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 th at 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 t he locks. In the absence of field or surv ey 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 tu g 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 em ission factors ap plied to the fuel consumption

estimates.

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

PM 2.5

SO 2 NH 3 NO
x 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 Comm erce 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 forJanuary 17, 2012

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### 19 Category 1 & 2 engines (EPA, 2008c). For SO 2 

### , 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 co nstruction equipment are base d 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 contribu tes to approximately 50 percent of total NMIM PM 2.5



### 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 co mpiled data from the SPC on agricultural land use in the Liberty-Clairton area to allocate emissi ons 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 Allocat ion 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 reduc tions 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 areJanuary 17, 2012

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### 20 provided in Table III-5. NONROAD assu mes a higher fuel sulfur level for recreational marine engines compared to land-based equipment.

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

Year Land Marine

2007 351 435

2014 20 52



## D. 2007 AND 2014 LIBERTY-CLAIRTON EMISSIONS INVEN TORY SUMMARY

Tables III-6 and III-7 pr ovide a summary of 2007 and 2014 off-road em issions for the Libert y-Clairton area, as calculated using the refinements discussed in Section C of this chapter. With the exception of NH 3 

### , 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 SO 2 NH 3 VOC NO
x 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 SO 2 NH 3 VOC NO
x 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 58.47 387.10January 17, 2012

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### 21 

# 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 re gulations 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 th e 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 in cluding Federal (EPA, FH WA), 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 determin ing 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 PM 2.5



### 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 deve loped 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 dataJanuary 17, 2012

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### 22 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 NO
x

.

PPSUITE Processes the highway data; calculates hourly congested speeds for each state roadway segment; prepares MOVES2010a input files; processes MO VES2010a output files into a summary report.
CENTRAL Provides a batch menu driven process to execute PPSUITE, MOVES2010a, and other MYSQL steps.



### The Liberty-Clairton PM 2.5



### on-road inventory was developed usin g EPA’s MOVES2010a emission model. EPA’s MOVES model was officially released on March 2, 2010 an d 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 MOVES2010 a. 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 exec utes 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.January 17, 2012

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### 23 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, th e interagency consultation gr oup 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 MO VES input files generated by PPSUITE can be found in Appendices A and B (provided separately).January 17, 2012

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### 24 Table IV-2. Summary of Data Pa rameters 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 PM 2.5

, NO
x , SO 2 , NH 3 , 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 & Grow th 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 PennD OT 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 PPSUIT E; User assigned Road Type to RMS links
MOVES Inputs
Vehicle Age Distribution 2010 registration data for light-dut y 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 air port 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 c onsisting 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 tra ffic volumes in 2008 and also includes traffi c signal locations. As 2007 RMS data was not readily available, HPMS data was used to factor the 2008 volumes back to 2007 levels with individualJanuary 17, 2012

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### 25 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 ac cess 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 emis sions 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 fo r 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 dat a from PennDOT’s 2008 Pennsy lvania 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 estima te 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 truc ks, buses, single-unit trucks, combinatio n 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; andJanuary 17, 2012

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### 26  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 re dundant as all roadways in the Liberty-Clairton PM 2.5



### NAA are classified in

MOVES2010a as urban, non-restricted.

f. Vehicle Age Distribution

Vehicle age distributions for each of the 13 source type s are a required input into MOVES2010a and PPSUITE. The
distributions reflect the percen tage of vehicles in the fleet up to 31 year s 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 t he 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) te chnology. 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 hourlyJanuary 17, 2012

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### 27 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 in ventory utilized the August 2010 version of the files ( http://www.epa.gov/oms/m odels/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 manufactur ers, dealers and other interested business partners and finalized procedures for complying with these new requirements.

The impacts of this program were modeled for all anal ysis years beyond 2008 using the same EPA guidance and tools as downloaded for the early NL EV analysis. EPA has also provided in put 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 develop ed 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 Decemb er 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 othe r available da ta 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 isJanuary 17, 2012

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### 28 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 PM 2.5



### 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 For ecasted 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 pl ays an important key role in determinin g 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 Estimate d 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 13,685January 17, 2012

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### 29 

### 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 PM 2.5



### NAA On-Road Emissions Summar y by Fuel Type (tons/year)

2007

Fuel Type Annual VMT (millions) Speed (miles/hour) PM 2.5

VOC NO
x SO 2 NH 3
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) PM 2.5

VOC NO
x SO 2 NH 3
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) PM 2.5

VOC NO
x SO 2 NH 3
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) PM 2.5

VOC NO X SO 2 NH 3
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) PM 2.5

VOC NO X SO 2 NH 3
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 3.36January 17, 2012

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### 31 

# CHAPTER V. SOURCE IMPACT A NALYSIS FOR THE LIBERTY MONITOR

A. EXISTING DATA AND ANALYSES

The Liberty-Clairton NAA has extensive speciated PM 2.5



### 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 PM 2.5



### 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 PM 2.5



### 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), ow ing to its proximity to Clai rton Works. The species concentrations for all days and the highest 25 percent of the PM 2.5



### daily measurements for both Liberty and Lawrenceville are shown in Table V-2 (ACHD, 2011d).

Table V-1. Measured Composition of 20 Highest PM 2.5



### Days at Liberty Monitor

Date PM 2.5

by FRM at Liberty Monitor (POC1) Total of

Measured (incl. Trace) Ammonium (NH 4 )+ Nitrate (NO 3 ) Sulfate (SO 4 ) 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 th e difference between FRM and "measured" mass.January 17, 2012

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### 32 Figure V-1. Enrichment of Species Measured at Li berty Site Compared to Lawrenceville Site (μg/m 3 

### )

SOURCE: ACHD, 2011d.



### Figure V-2. Excess PM 2.5



### (Liberty - Lawrenceville) Using PMF Analysis (μg/m 3 

### )

SOURCE: ACHD, 2011d. ‐ 0.4 ‐ 0.2 0.0 0.2 0.4 0.6 0.8 1.0 1.2 1.4SeECAsBrClSiPbNH4CuAlVSulfateOCCaZnK_xrfNa_xrfNiNitrateTiCrFeMnEnrichment:Liberty‐Lawrenceville(ug/m3)

‐ 2

‐ 1.5

‐ 1 ‐ 0.5 0 0.5

1 1.5

2 2.5

3 3.5ExcessPM2.5atLibertybyPMF(ug/m3)January 17, 2012

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### 33 Table V-2. Comparison of Species Concentrations on Average and High Mass C oncentration Days (μg/m 3 

### )

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

NH 4 + 2.4 1.87 4.8 3.42

NO 3 - 1.3 1.57 1.5 2.38

SO 4 -- 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 ambi ent 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 am bient speciated data collected at the Liberty Borough

site, also known as the SAHS site and at the ACHD's Lawren ceville 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 se t 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, 200 8d). 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 th e 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 importan t source types on air quality in the NAA. However, asJanuary 17, 2012

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### 34 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 stat us of the measured data used in these analyses. ACHD conducted the PMF analysis wi th speciation data from the PM 2.5



### 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 PM 2.5



### mass and the analyzed components reported in the PM 2.5 

### 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 PM 2.5



### components as they might be measured by the PM 2.5



### 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 PM 2.5



### 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 PM 2.5 

### 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 PM 2.5



### 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 PM 2.5



### 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 PM 2.5



### days. While the source types will not likely change drastically, their relative co ntributions 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

PM 2.5



### 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 pop ulated wooded area with active farms about 1 mile west. However, it may be influenced by sour ces 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 simi lar 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 al ong with corresponding data from Liberty (aka SAHS) and
Lawrenceville sites. As expected, PM 2.5



### and many of the species are highly enriched above values at the Hillmansite, because of the close proximity of industrial sources to the Liberty site. The Lawrenceville data are roughly midrange between the Liberty and Hillman values.November 30, 20112007 and 2014 Liberty-Clairton PM2.5Nonattainment Area Emission Inventories and Source Assessment Analysis35Table V-3. PMF Results for Highest 20 Days Measured at Liberty Site,Liberty - Clairton NAAPMF Results for Liberty Site Factors and TheirKey Species (Highest Days in 2005-2010)DatePM2.5(POC1)FactorSum Cr Ni (#1)OC EC SO4(#2) Se (#3)OC EC Cu(#4) NO3(#5)EC OC S(#6)S04OC EC(#7) EC Si (#8) K (#9)Chlorine(#10)Fe Mn Zn(#11)Al Ca Fe Ti(#12)9/13/2005 89.0 30 6.44 3.601.801.761.655.826.44-0.20-0.20-0.202.500.5010/31/2005 83.1 71 1.54 11.6917.031.81-0.202.561.545.37-0.2029.86-0.04-0.208/4/2007 62.6 20 3.64 0.510.870.841.061.513.642.101.650.021.852.534/18/2008 56.0 42 1.00 0.431.121.641.163.591.002.633.4522.361.592.262/17/2007 54.1 50 1.30 2.113.050.203.14-0.201.303.342.3432.82-0.200.755/29/2006 54.1 29 2.73 6.691.501.731.244.872.731.062.821.132.83-0.2011/12/2005 48.8 32 0.32 5.584.191.900.491.650.323.331.5012.170.320.168/28/2007 47.3 21 5.53 1.300.342.450.640.945.530.970.56-0.021.021.617/7/2010 47.1 23 2.50 2.951.702.040.254.422.501.363.080.151.081.277/17/2008 45.1 21 3.78 2.181.281.061.142.803.781.160.860.431.451.257/10/2006 45.1 19 4.29 2.900.590.720.281.594.291.481.350.03-0.061.309/3/2008 45.0 25 2.51 3.930.751.551.585.872.512.820.110.502.340.992/22/2006 44.7 31 0.84 3.531.042.733.092.990.841.152.1811.950.690.429/8/2006 44.4 30 3.10 3.921.622.211.023.973.105.950.393.530.95-0.187/29/2008 44.4 21 3.06 3.881.301.780.762.313.061.032.480.171.120.479/21/2008 43.8 29 2.68 1.730.401.431.604.062.685.332.964.112.39-0.209/19/2005 43.0 29 3.69 3.989.941.100.752.303.691.77-0.100.101.180.477/21/2005 42.7 21 3.36 2.621.211.111.162.643.363.030.390.071.221.218/30/2010 41.8 20 1.94 2.911.021.420.645.181.941.191.140.152.28-0.174/2/2010 41.2 33 -0.17 3.081.682.87-0.204.44-0.171.783.2410.521.594.71Average 51.2 29.9 2.7 3.52.61.61.13.22.72.31.56.51.30.92 Std Dev 26.29 24.85 3.32 4.917.981.341.763.323.323.312.4920.821.782.40SOURCE: ACHD, 2011d.November 30, 2011

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### 36 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/m 3 

### )

2005-2008 PM 2.5

Speciation and FRM Enrichment
Hillman Lawrenceville Liberty Lib-Hill

PM 2.5

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 0.019November 30, 2011

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### 37 2005-2008 PM 2.5

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/m 3 ) average for 2005-2008), consistent with the Hillman State Forest (Florence) FRM (13 μg/m 3 ).

SOURCE: EPA, 2011a.



### The relatively high PM 2.5



### and species concentrations for PM 2.5



### and species mass at the Hillman site (upwind of the Liberty site) suggests that there is a non negligible "b ackground" impacting the Liberty-Clairton area. A rough approximation based on Table V-4 is that the average PM 2.5



### excess at Liberty is 6-7 μg/m 3 

### over the Hillman and S. Fayette areas. Similarly, NH 4 

### , SO 4 

### , and NO 3 

### combined are enriched 3 μg/m 3 

### and EC and OC combined are enriched 3.5 μg/m 3 

### at Liberty over the Hillman area. The enrichment could be more if NH 4 

### , SO 4 

### , NO 3 

### 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/m 3 

### 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 PM 10



### . 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, theNovember 30, 2011

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### 38 microinventory may include information on source operat ing patterns and day-to-day emissions variability due to upsets/malfunctions and intermittent operation. This microi nventory facilitates comparison of the 2007 inventory to PMF and other receptor-based analyses to support evaluation the sources’ potential to impact PM 2.5



### 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 insp ection of the selected areas near the Liberty monitor and

interviews with ACHD staff. TS|Pechan has recorded and su mmarized results in spreads heets 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

PM 2.5



### 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 (househo ld 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.November 30, 2011

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### 39 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.November 30, 2011

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### 40 

## D. SOURCE IDENTIFICATION, LOCAT ION, 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

SO 2 

### emissions outside of the 10 mile cutoff come almost entir ely 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 sour ces 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), wh ile 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 rang ing from over 1,150 feet in Lincoln Borough (to the East),
1,050 feet at the Liberty Monitoring site, 950 feet in Libert y 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.November 30, 20112007 and 2014 Liberty-Clairton PM2.5Nonattainment Area Emission Inventories and Source Assessment Analysis41Table V-5. Point Source Facilities Believed to Contribute to Liberty-Clairton PM2.5Nonattainment(a)Plant ID Facility Name ProcessesDegreesfromNorthKilometersfrom LibertyMonitorMiles fromLibertyMonitor Latitude Longitude4200300027 Koppers Inc. - Clairton Plant Crudes, Carbon Black, Tar fr Coke Waste 2182.41.540.30675 -79.8855864200300032 USS - Clairton Works Coke Batteries, Quench Towers 2052.71.740.30807 -79.8830934200300265 Eastman Chemical Resins, Inc. Plastics and Resin Mfg 2047.54.740.26189 -79.9051384200300342 Guardian Industries Corp. Floreffe Glass Melt Furnace 2078.75.540.25388 -79.9158504200300228 Precoat Metals, Div of Sequa Coatings Metals Coating 852.21.440.32525 -79.8429074200300203 US Steel Corporation - Irvin Plant Steel Reheat Furnace, annealing 2903.02.140.33293 -79.9012834200300202 USS Corporation - Edgar Thompson Plant Steel Making - BOP, Finishing 77.85.140.39295 -79.8564774200300144 Bellefield Boiler Plant Steam Boiler - Coal 33214.79.240.43978 -79.9494214200300009 Pittsburgh (Iron City) Brewing Brewery 33117.110.740.45912 -79.9662214200300073 Pittsburgh Allegheny County Thermal, Ltd. EGU 31917.410.940.44152 -80.0038684200300024 Bay Valley Foods, LLC Coal-fired Boiler 32517.410.940.45181 -79.9857914200300389 NRG Energy Center, Pittsburgh Steam Boiler - Coal 31918.211.440.44841 -80.0094274200300164 GE Consumer Products, Lighting Glass Fixture Mfg, Simplex Furnace 28319.812.440.36444 -80.0966354200300003 Universal Stainless and AlloyProducts EAF, Steel Alloy Mfg 28120.813.040.35985 -80.1085914200300158 Orion Power Midwest - Brunot Plant EGU - Gas 31621.613.540.46313 -80.044596(a)ACHD, 2011e.November 30, 20112007 and 2014 Liberty-Clairton PM2.5Nonattainment Area Emission Inventories and Source Assessment Analysis42Table V-6. 2007 Emissions Summary for Liberty-Clairton PM2.5NAAPoint Source Facilities Inside the Liberty-ClairtonNAA(a)PM2.5-PRISO2NH3HCl ClNiPbSeAsCrMnKoppers Inc. - Clairton Plant 6.10.30.0USS - Clairton Works 1,950.01,74020094.1(b)1.3.32.7Eastman Chemical Resins, Inc. 16.84.40.14.6Guardian Industries Corp. Floreffe 6.1830.00.20.1Total Point Source Emissions Inside the Liberty-Clairton NAA (a)1,9931,82720096.0 1.3.30.00.20.02.80.0Area Source Emissions Inside the Liberty-Clairton NAA(c)Residential Wood Comb. (Stoves, Fireplaces, Boilers)15.70.40.9Industrial Coal Combustion 0.031.40.0Commercial Coal Combustion 0.00.00.0Open Burning 1.00.00.0Commercial Cooking 4.10.00.0Residential Heating - Gas, Oil and Coal 3.00.30.2Fugitive Dust (paved, unpaved, construction)5.20.00.0Fertilizer Application 0.00.02.2Other Area Source Emissions 0.616.50.8Total Area SourceEmissions Inside the Liberty-Clairton NAA29.748.64.3Mobile Sources Inside the Liberty-Clairton NAA(c)HDDV5.70.30.2Railroads 2.40.80.0CMV 6.412.40.0Non Road Diesel 4.33.90.0Highway Gas Vehicles 4.21.84.5Non Road Gas 1.90.10.0Other Mobile Source Emissions 0.00.00.2Total Mobile Source EmissionsInside the Liberty-Clairton NAA24.919.44.8Total Emissions Inside the Liberty-Clairton NAA2,0481,895209(a)ACHD, 2010.(b)HCl for Clairton Works is“adjusted 0.0” since 2004.(c)ACHD, 2011e.November 30, 20112007 and 2014 Liberty-Clairton PM2.5Nonattainment Area Emission Inventories and Source Assessment Analysis43Table V-7. 2007 Emissions Summaryfor Sources in Allegheny County, PA- Outside the Liberty-Clairton PM2.5NAAFacilities w/in 16 km (10 miles) of SAHS Monitor, but Outside the Liberty-Clairton PM2.5NAA*PM2.5-PRISO2NH3HCl*Cl*Ni*Pb*Se*As*Cr*Mn*Precoat Metals, Div of Sequa Coatings 0.80.1US Steel Corporation - Irvin Plant 51456 0.823.30.33USS Corporation - Edgar Thompson Plant 8811,689 0.513.30.190.10.40.8Bellefield Boiler Plant77707 31.1Pittsburgh (Iron City) Brewing 2.415.4 0.7Pittsburgh Allegheny County Thermal, Ltd. 2.80.2Bay Valley Foods, LLC60543 22.90.0NRG Energy Center, Pittsburgh 2.60.2GE Consumer Products, Lighting 200.1 1.7Universal Stainless and Alloy Products 1813 0.20.00.4Orion Power Midwest - Brunot Plant 2.33.9 0.2McConway and Torley164.6 0.10.00.00.10.4Total Point Source Emissions Outside the Liberty-Clairton NAA(< 10 miles from SAHS)*1,0663,4341.591.20.50.42.10.00.00.51.2Total Point Source Emissions Outside the Liberty-Clairton NAA(> 10 miles from SAHS)*1,18835,0103621,4092.54.02.50.80.44.42.4Area Source Emissions Outside the Liberty-Clairton NAAResidential Wood Comb. (Stoves, Fireplaces, Furnaces)1,51732 89Industrial Coal Combustion 1177,467 2.4Commercial Coal Combustion 583,702 1.2Open Burning00.0 0.0Commercial Cooking540.0 12.3Residential Heating - Gas, Oil and Coal 16617 12.1Fugitive Dust (paved, unpaved, construction) 1,2860.0 0.0FertilizerApplication00.0 132Other Area Source Emissions 3041,672 62Total Area Source Emissions Outside the Liberty-Clairton NAA (**)3,50012,890311Mobile Source Emissions Outside the Liberty-Clairton NAAHDDVnana naRailroads6120 1CMV10551 4Non Road Diesel277249 2.8Highway Gas Vehiclesnana naNon Road Gas1126.5 2.1Other Mobile Source Emissions 2774 naTotal Mobile Source Emissions Outside the Liberty-Clairton NAA (**)58240110Total Emissions Outside the Liberty-Clairton NAA6,33651,735685*ACHD, 2010.**ACHD, 2011e.January 17, 2012

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### 44 

## E. CONCENTRATION SPIKES POTE NTIALLY 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 wi th 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 processe s emitting those species. Based on Table V-8, the most likely species associated with upsets, malfunctions or intermi ttent sources are: chlorine, arsenic, EC, lead, bromine,

selenium, OC, NH 4 

### , 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, 201 1a; 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, Co ke, Nat. Gas Comb., Res Coal, Oil, Wood Comb. Charbroiling Lead - Muni Waste, EAF, Steel Mfg, Foundrie s, 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 Co mb., Steelmaking, EAF, Nat Gas

Table V-8. Measured Species at Li berty Site for High and Low Days

High 25%

(μg/m 3 ) Low 75% (μg/m 3 ) Ratio High

25% to Low 75% (μg/m 3 )

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

NH 4 + 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 2.4January 17, 2012

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### 45 High 25%

(μg/m 3 ) Low 75% (μg/m 3 ) Ratio High

25% to Low 75% (μg/m 3 )

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 PM 2.5



### nonattainment.

The analysis emphasizes those categories and sources that have the most influence on PM 2.5



### concentrations, with particular emphasis on e.g., carbon emitting sources, ammonia, SO 2 

### , 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 PM 2.5 

### concentrations on the highest days to determine what types of sources are responsible for those high PM 2.5 

### concentrations.

This analysis is limited in the firmness of its conclusions for several reasons. First, secondary SO 4 

### , NO 3 

### , and OC particle formation is complex and should be modeled using a chemical transport model such as CAMX; also, there isJanuary 17, 2012

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### 46 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 s peciation 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 PM 2.5



### 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 Combusti on, 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.January 17, 2012

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### 47 Tentatively, it is likely that transport from outside Alleg heny 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 SO 4 

### and NH 3 

### ) that the portion of PMF - 9 related to local wood burning is probably 0.8 μg/m 3 

### on average. The remaining K that was associated wi th 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 syst em. 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 specie s, so they are clearly import ant. This is just slightly less than the average contribution of (NH 4 

### ) 2



### SO 4 

### . 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 SO 4 

### 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 SO 2 

### in the wind sector associated with the SO 4 

### 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/m 3 

### for factors 2, 6, 8, and 10 are 1.9, 2.9, 0.6 and 1.0 μg/m 3 

### , respectively, for a total 6.4 μg/m 3 

### mostly attributable to Clai rton Works. Of this, 4.6 μg/m 3 

### is EC, OC, and trace (1.8 is NH 4 

### , SO 4 

### , and NO 3 

### ). PMF-7 is also from the Clairton Works direction but it is almost all ammonium
sulfate. Note some portion of these sources' impacts ma y 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 affe cted by transport since the OC at Hillman is 60 percent as high as the OC at Liberty.January 17, 2012

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### 48 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) NH 4 NO 3 SO 4 Wind

Direction OC EC Trace

Elements NH 4 NO 3 SO 4 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, Nitrat e, and Secondary Organic PM 2.5



### SO 4 

### and NO 3 

### are formed in the atmosphere from SO 2 

### and NO

x 

### , respectively. They are both almost always found in

the form of NH 4 

### , SO 4 

### , and NO 3 

### . The sum of ammonium sulfate an d nitrate at Hillman is 7.2 μg/m 3 

### 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.

SO 4 

### is usually formed in the summer and NO 3 

### is usually higher in the winter. However, Figure V-5 shows a surprising amount of (NH 4 

### ) 2



### SO 4 

### in the winter at Liberty. If there is enough ammonia present, the SO 4 

### and NO 3 

### will be fully neutralized, but the sulfur and nitrogen can exist in the fo rm 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 SO 4 

### and NO 3 

### for much of the year, but there may be about a 10-20 percent shortage of ammonia in the summ er and in December and January to fully neutralize the

SO 4 

### . Clairton Works emits about 30 percent of the SO 2 

### and 70 percent of the NO

x 

### emitted in or near the NAA. The source emitting 85 percent of the SO 2 

### 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, SO 2 

### , NO

x 

### , 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 photoch emical 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.January 17, 2012

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### 49 Factors 2, 6, 7, 8 and 10 are associated with S or SW winds and combined account for 3/4 (3 μg/m 3 

### ) of OC (the other 1.2 μg/m 3 

### is not associated with S or SW winds). OC presen ts 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. Howe ver, much of this OC is likely to be primary and some of it is likely from transport (Liberty is only 1.8 μg/m 3 

### 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 Am monium at Liberty Monitoring Station

SOURCE: ACHD, 2011d.



### Table V-10 shows most of the SO 4 

### (3.9 out of 5.3 μg/m 3 

### ) and over half of the NH 4 

### (1.3 out of 2.4 μg/m 3 

### ) 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, (NH 4 

### ) 2



### SO 4 

### , comprising 5.2 μg/m 3 

### in this Factor 7 (or about 70 percent of the total fully neutralized

NH 4 

### SO 4 

### 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 SO 2 

### . Table V-7 shows that another 3,400 tons/year of SO 2 

### 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 SO 4 

### as SO 2 

### 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/m 3 

### of (NH 4 

### ) 2



### SO 4 

### 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 co uld 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 NH 4 

### NO 3 

### is represented by PMF-5. It contains 0.87 μg/m 3 

### of NO 3 

### and 0.31 μg/m 3 

### of NH 4 

### , suggesting fully neutralized NH 4 

### NO 3 

### of 1.18 μg/m 3 

### . Clairton Works emits over 70 percent of the point source NO

x 

### emitted within 10 miles of the Liberty site (ACHD, 2011c). However, the CPF analysis shows that while much of the

NH 4 

### NO 3 

### is associated with winds from the direction of Clai rton, other wind directions are associated with some NO 3 

### 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 9JanFebMarAprMayJunJulAugSeptOctNovDecSpeciesConcentration,ug/m3

NO3 Nitrate

SO4 Sulfate

Ammonium required

to fully neutralize

NH4+ Ammonium

availableJanuary 17, 2012

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### 50 and much lower values at Hillman. But, while NO

x 

### 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 NH 4 

### , SO 4 

### , and NO 3 

### (2.5 μg/m 3 

### ) 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 PM 2.5



### 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 sect ion 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 PM 2.5



### concentrations at the Liberty monitor. Identification of the responsible sources should be purs ued through further analysis and investigation.

Figure V-6. Comparison of Measured Chlori ne 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 DecChlorineConcentration,ug/m3

Month

Chlorine Liberty Borough Chlorine LawrencevilleJanuary 17, 2012

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### 51 

### 6. Overall Source Contributions

a. Source Contributions based on Emissions Inventory (2007 revised)

Within the NAA, Clairton Works' emissions of PM 2.5



### , SO 2 

### , and ammonia far exceeds those of any other point source or mobile or area source category. For NO

x 

### , 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 PM 2.5



### , SO 2 

### and NO

x 

### (but not nearly the amount of emissions as Clairton Works). The Bay Valley
Foods coal-fired boiler also emits significant PM 2.5



### and SO 2 

### . The Bayfield and Bellefield Boiler Plants are about 10 miles away from the Liberty Monitor, but the Irvin and T hompson 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 (Sp eciation at Liberty (2005-10) and Hillman Forest (2005-8)

Primary versus Secondary

7.5 μg/m 3 

### 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/m 3 

### is NH 4 

### SO 4 

### NO 3 

### (NH 4 

### 2.4, SO 4 

### 5.3, NO 3 

### 1.3) (55 percent of the PM 2.5



### 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 PM 2.5



### 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/m 3 

### (The EC at Liberty is mostly local since EC at the Hi llman 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.)

NH 4 

### , SO 4 

### , and NO 3 

### ~ 9 μg/m 3 

### 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 PM 2.5 

### 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/m 3 

### (Source is Clairton Works (or beyond) ~ none of these sources located between Clairton and Liberty MonitorJanuary 17, 2012

2007 and 2014 Liberty-Clairton PM 2.5

Nonattainment Area Emission Inventories and Source Assessment Analysis



### 52 EC OC Trace ~ 4.6 μg/m 3



### NH 4 

### , SO 4 

### , and NO 3 

### ~ 1.8 μg/m 3



### Factors 2 (Industry - 1.9 μg/m 3 

### ) - likely local Factor 6 (Industry - 2.9 μg/m 3 

### ) – 40 percent (NH 4 

### ) 2



### SO 4 

### -likely local Factor 8 (Coal/Coke - 0.6 μg/m 3 

### ) - likely local Factor 10 (Chlorine - 1 μg/m 3 

### ) - possibly upsets, malfunction

Factors 4, 5, 9: "Mostly local - not Clairton Works-related" ~ 3 μg/m 3 

### EC OC Trace ~ 1.3 μg/m 3



### NH 4 

### , SO 4 

### , and NO 3 

### ~ 1.8 μg/m 3



### Factor 4 (Gas Vehicles - 0.7 μg/m 3 

### ) ~ believed to be mostly locally emitted Factor 5 (NO 3 

### - 1.3 μg/m 3 

### ) is associated with all wind directions which suggests mostly local origin Factor 9 (Burning - 1.14 μg/m 3 

### ) ~ best guess ~ 0.8 μg/m 3 

### local wood burning (0.8 μg/m 3 

### ). 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/m 3



### NH 4 

### SO 4 

### - 5.2 μg/m 3 

### , 0.7 EC OC ~ NH 4 

### SO 4 

### likely transport

Minor Factors

Factor 1 (Metals - < 0.1 μg/m 3 

### ) Factor 3 (Coal/Glass - < 0.1 μg/m 3 

### ) Factor 11 (Steel Mfg - < 0.3 μg/m 3 

### ) Factor 12 (Crustal - < 0.3 μg/m 3 

### )

Overall Estimates from PMF Analyses Transport-related: 7 μg/m 3 

### (~44 percent) Local origin: 9 μg/m 3 

### (~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 PM 2.5



### at the Liberty monitoring site is of local origin (60 percent local emissions ~ 40 percent transport).January 17, 2012

2007 and 2014 Liberty-Clairton PM 2.5

Nonattainment Area Emission Inventories and Source Assessment Analysis



### 53 

# CHAPTER VI. REFERENCES

ACHD, 2007: Allegheny County Health Depa rtment, “State Implementation Plan for PM 2.5



### ,” Appendix C - Modeling Protocol, Pg 2, October 2007.

ACHD, 2010: Allegheny County Health Department, Poin t Source Emission Inventory Report 2008, April 2010.

ACHD, 2011a: Allegheny County Health Department, “Sta te 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 Departmen t, “Census of Restaurants,” transmitted October 2011.

ACHD, 2011d: Allegheny County He alth Department, "Allegheny County PM 2.5



### Source Apportionment Results using Positive Matrix Factorization Model (PMF Version 3.0) a nd 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-ente rprise-lowball-gas-drill-leaseshaunt/f93c1d3bb4594 97eb068e1 2dba03824c , 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 Project ed Traffic Growth, Traffi c Growth Forecasting System: Final Report,” March 14, 2005.

Brinza, 2011: M. Brinza, Port of Pi ttsburgh Commission, Email to K. Thesin g, 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.g ov/servlet/STTable?_b m=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 E nergy 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 Int egrated Analysis and Forecasting, Washington, DC, April

26, 2011.January 17, 2012

2007 and 2014 Liberty-Clairton PM 2.5

Nonattainment Area Emission Inventories and Source Assessment Analysis



### 54 EPA, 2009: U.S. Environmental Protection Agency, “Emissi on Factors for Locomotives,” Office of Transportation and Air Quality, EPA-420-F09-025, April 2009.

EPA, 2008a: U.S. Environmental Prot ection Agency, “Residentia l 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 Prot ection 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 Protec tion Agency, “Regulatory Impact Analysi s: 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. Fo ley, "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 Purpos es,” Office of Air and Ra diation, EPA-42 0-B-09-046,

December 2009.

EPA, 2010a: U.S. Environmental Prot ection Agency, “Technical Guidance on the Use of MOVES2010 for Emission Inventory Preparation in State Implementation Plans and Trans portation 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 Pr otection Agency, “Motor Vehicle Em ission 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/monv als.html?co~42003~Alleghen y%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 Tech nical Advisory Committee, 2008 Class II/III line haul Em issions, transmitted in

file “ERTACRail-Class_II_III _10_5_2011.xls” in email, “Q uestion about link-level ERTAC Class I and Class II/III
emissions,” from M. Bergin, ERTAC to K. Thesi ng, TranSystems|E.H. Pe chan, October 19, 2011.

Frank, 2006: Neil Frank, "SANDWICH Material Balance Approach for PM 2.5



### Data Analysis," presented at 2006 National Air Modeling Conference, Las Vegas, NV, November 6-9, 2006.January 17, 2012

2007 and 2014 Liberty-Clairton PM 2.5

Nonattainment Area Emission Inventories and Source Assessment Analysis



### 55 ICF, 2009: ICF International, “Technic al 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 part icles,” 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. Khamwich ita, 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/d eputate/minres/o ilgas/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-ga zette.com/pg/1035 1/1111418-455.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 Tolu ene,” 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. Dzep ina, M.R. Canagaratna, Q. Z hang, 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. Card enas, 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, a nd J.L. Jimenez, “Characterization of ambient aerosols in Mexico City during the MCMA-2003 campaign with Ae rosol 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,” trans mitted by Anthony Sadar, ACHD, October 17, 2011.January 17, 2012

2007 and 2014 Liberty-Clairton PM 2.5

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, enti tled “CMV Emissions in Pittsburgh,” October 4, 2011.

University of Pittsburgh, 2011: University of Pittsburgh, “O il 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, “Waterbo rne 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

### {This page left blank for printing purposes}Page 1



### Summary of Local Inventory Revision s

Allegheny County and SWPA inventories for the PM 2.5 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

, w hile p rojected years were 2017/2020. For future case year 2014, interpolations were developed by TS| P echan based o n the MANE

- VU 2007 and 2017 inventories (see s ection F

- 3 of this a ppendix ).

ACHD revised or corrected specific local point sources in the MA NE

- VU 2007 and 2014

inventor ies based on location of sources, emissions /controls

, monitored data, and source apportionment analysis (see Appendix C). Sources examined were within approximate ly 10 km of the Liberty monitor, and also included some Washingto n 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 inv entory. 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 Liberty

Clairton emis sions . Point source subtractions were done to Allegheny County and Liberty

Clairton area sources to avoid double

- counting of commercial/institutional/industrial fuel

combustion sources . Additionally, for future case 2014, surrounding SWPA counties were

r evised by ACHD to include Marcellus shale gas area emission s 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) f or SO 2 and NO

x 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
supple mental 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 Towe rs : R evised based on newer stack test data. Includes revised PM

emissions, revised stack parameters. PM 2.5 data is given in the table below :

Quench Tower

Calculations , PM 2.5 Tower 1

, Batteries 1

- 3 Tower 3

,

Batteries 7

- 9 Tower 5

,

Batteries 13

- 15 Towe r 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

no n

- 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 f or 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 A ssessment (NATA) method used for buoyant coke

batter y 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, p ulverizing, 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

NH 3 emissions that were previously overestimated

.

1 http://www.epa.gov/ttn/atw/nata2005/ 05pdf/nata_tmd.pdfPage 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: SO 2 emi ssions 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 map s.

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 ae rial 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 correct ed 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

Rya n 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 So uth Hills LandfillPage 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 SO 2 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. )

Poi nt 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 /Di stillate 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 /Nat ural Gas /Total: Boilers and IC Engines

2103007000 Stationary Fuel Comb /Commercial/Institutional /Liquified Petroleum Gas /Total: All Combustor TypesPage 6



### 2007 Nonroad Source Revisions

Below are descriptions of the nonroad source revisions/corrections f or 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, emi ssions were set to 0.)Page 7



### 20 14 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 appendi x)

. 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 t he MANE

- VU inventory were n ot 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 so urces 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,

unles s listed below as a shutdown.

US Steel Mon Valley Works

– Clairton Plant

Batteries 7

- 9 and associated processes : Shutdown , i ncludes sources below:

BATTERY 7 FUGITIVES, BATTERY 7, CHARGING

BATTERY 7 FUGITIVES, BATTERY 7, DOOR LEAKS

BATTERY 7 FUGITIVE S, 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

BATT ERY 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, SOAK ING

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 MILLPage 8 Screening Station B (3): Shutdown, includes sources below:

SCREENING STATION B , SCREENING STATION B BAGHS

S CREENING 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

. PM 2.5 data is given in the table below:

Quench Tower Proje ctions , PM 2.5 Tower 1

, Batteries 1

- 3 Tower 5 A,

Batteries 13

- 15 Tower 7 A,

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 Ste el 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.

PE C 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 ba sed 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 UNDERFIRINGPage 9 PEC SYSTEM, BATTERY C, PE C 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 Indus tries

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 P lant

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 n ot added to the 2014 inventory as a minor source :

GM Metal Stamping

Ryan MetalsPage 10

GenOn Elrama

Electric Generating Units: Elrama boilers were revised to the final June 2012 CSAPR

allocations for SO 2 and NO

x . Emissions per heat input (based on 2007 le vels) 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 SO 2 and NO

x . Emissions per heat input (based on 200 7 levels) were then
used to scale the other pollutant emissions per boiler.Page 11



### 20 14 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|Pech an 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 disti llate oil SO 2 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 R oads /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 SCC s 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 /Bitu minous/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 Engi nes

2103007000 Stationary Fuel Comb /Commercial/Institutional /Liquified Petroleum Gas /Total: All Combustor TypesPage 12

Surrounding Counties

For Washington, Westmoreland, Greene, and Fayette Counties, ACHD developed future c ase

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 incr eases 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 PM 2.5 State Impl ementation 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

Washi ngton, 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

southwes t 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
Washingt on 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

calcula tions 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 tota l number of wells expected to already be operating in each county
in 2014. Thus, for example, according to PA DEP, 2 560 wells were drilled in Washington County from January 1, 2005 through December 31, 2011. And projections provided in

the Penn State Coo perative Extension report 1 for 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, 33 2 ; 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 Sh ale” 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 est imates 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 Engelder 5 and 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 NO

x emissions per new well will be:

Midstream NO

x Emissions = (2.4 tons NO

x /Bcf/new well) (1.825 Bcf/yr) = 4.39 tons

NO

x /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 NO

x 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,” 6 the total gas flow from Washington County existing wells during

2014 will be 0.365 Bcf, an d the corresponding midstream NO

x 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 conditi ons 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 (TP Y) 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 Coop erative Extension, June 2011. Se e Figure 4 and Table 1 in study,

available at : http://marcelluscoalition.org/wp

content/uploads/2011/08/PennsylvaniaState wideWorkforceAssessmentv1_Final_for_web.pdf

2. PA DEP Office of Oil and Gas Management Wells Drilled by County accesse d 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 we lls 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.c om/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/D CNR.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, PM 2.5 = 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

Produc tion 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 D ry

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 1 568 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



### 20 14 Nonro ad 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 C ORP

- 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 Developm ent 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. 4.3 99 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 Stamp ing 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 PITTSBURG H 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 7.100Page 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 B raddock 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 Tran sportation 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 0.1 00

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 55.37 9 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 6.9 80

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 12.873 156.367 111.158Page 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 M IDWEST, 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 1119.715Page 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 0.1 70 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 0.75 1 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

Je fferson 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 0.08 9 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 1.6 10 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 0.0 60 25.505 0.000 0.006 0.006

Tube City IMS Braddock 0.000 0.000 0.000 0.000 0.000 27.865 3.072Page 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 PR ODUCTS 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 S TA 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 2.991 438.450 221.481Page 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

### {This page left blank for printing purposes}

### 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 PM 2.5 

### 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 39 th 

### Street
Pittsburgh, PA 15201

- 1891

Prepared by:

TranSystems

5528

- B Hempstead Way Springfield, VA 22151

November 27, 2012

### 1



## S U M M A R Y

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 (PM 2.5 

### ) concentrations in
the Liberty

- Clairton are a. 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 Northe ast 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

- E GU POINT SOURCES

For the Lake Michigan s tates, 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 emiss ion file for the Lake Michigan s tates, 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 n on

- EGU emissions for the LADCO s tates.

Because the National Emissions Inventory (NEI) 2008 emissions file was used by the Allegheny County He alth Department (ACHD) to represent base year emissions, that file rather than the point source file that was supplied by

the LADCO s tates for the 2011 TranSystems study was used as the base year emissions file for developing the 2014

emis sion forecast fil e. The LADCO s tate 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 esti mates 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. NO

x 

### SIP Call

All states in the LADCO region affected by the oxides of nitrogen ( NO

x 

### ) State Implementation Plan ( SIP ) Call requirements (O hio, Indiana, Illinois, Michigan ) indicated that their sources were complying in 2008. Therefore, no
control factors are applied post

- 2008 to NO

x 

### SIP Call affected sources.

2. Maximum Achievable Control Technology ( MACT ) S tandards

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 t he 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 ) , NO

x 

### , and particulate matter ( PM ) benefits of these national emission standards for hazardous air pollutant s ( NESHAPs )

.

### 2

Reciprocating Internal Combustion Engine (RICE) Rules

EPA has prepared Source Classification Code ( SCC )

- level percentage reduction estimates from uncontrolled

emission level s for their recent RICE MACT rule s

. Because LADCO expressed a preference for reflecting incremental reductions relative to baseline emissions in this project‟s control factor files, T ranSystems 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 )

, NO

x 

### , and VOC (EPA, 2010). This information was used to develop the overall SI engine MACT reductions
for each pol lutant 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 un controlled 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 int o 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 qualit y 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. F or this analysis

, BART and Consent Decree
requirements were considered together because some states examined what the consent decrees require for
potential BART sources, a nd 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 c ontrol t echnique g uidelines ( CTGs ) issued by EPA between 2006 and 2008, and that agency estimated the effects of thei r expected revised regulations on VOC emissions. A summary of the key source categories and associated future year emission reductions is described below.

Miscellaneous Industrial Adhesive s : Ohio EPA provided separate tables identifying counties affecte d 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, T ranSystems applied the 50 percent VOC emission reduction that Ohio EPA provided for
Miscellaneous Industrial Adhesives only to records for which t here was not an overlapping SCC/county reported in the “Adhesives Processes” table. In keeping with Ohio EPA guidance, T ranSystems applied a 40 percent VOC emission reduction for all SCC/county combinations in the “Adhesive Processes” table. The 50 and 4 0 percent
reductions reflect the estimates reported in Ohio EPA‟s “p robable reduction s” columns in each table.

Automobile and Light

- Duty Truck (LDT) Coating processes: Ohio EPA estimates a probable 15 percent

additional VOC emission reduction attributabl e to VOC RACT regulations implement ing the new CTG for this source
category . The Ohio EPA provided a list of SCC/county combinations in the Cleveland

- Akron

- L orain ozone

nonattainment area affected by this CTG. In some cases these SCC/county combinations were listed as affected by

other CTGs. T ranSystems 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 ( SO 2 ) NO

x SO 2 NO

x

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 m etal coating processes. As with the Automobile and LDT Coating CTG, T ranSystems applied this reduction to only those SCC/county combinations
for which Ohio did not identify another CTG with a higher percentage emissions reduction.

5

. NO

x 

### RACT

Ohio EPA p rovided estimates of the expected post

- 2008 NO

x 

### emission reductions for four facilities in the Cleveland

Akron

- L orain ozone nonattainment area. These emission reductions are listed in T able 2 along with the affected
facility and source identifiers provi ded 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 NO

x 

### 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 fac tors 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 factor s 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, T ranSystems developed stationary source growth factors for LADCO by interpolating growth factors for the LADCO years of interest from the EPA growth factors , which represent ed emission s 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 d id 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 Outlo ok (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.

Fo r the following non

- combustion priority stationary point source categories, EPA developed projections data using a variety of methods and d ata sources : 1) Carbon Black; 2) Cement Manufacturing; 3) Copper Production; 4) Glass
Manufacturing; 5) I ron and Steel Manufacturing; 6) Petroleum Refining; 7) Primary Alumi num 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 NO

x 

### RACT Summary

Facility Name Facility ID Point ID NO

x Emissions 2008
(tons) Future Reductions

w/controls
(tons) NO

x 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 Outlo ok 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)

wh ere: 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 sta tes 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 NO

x 

### and SO 2 

### , and are o bse rved 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 NO

x CO SO 2 PM 10 PM 2.5 Ammonia ( NH 3 )

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 NO

x CO SO 2 PM 10 PM 2.5 NH 3
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 NO

x CO SO 2 PM 10 PM 2.5 NH 3
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

SO 2 

### emission declines in Wisconsin are attributable to expected reduced activity for the sectors with the most significant SO 2 

### emissions (rather than control programs). The SO 2 

### emission reduction s estimated for 2014 in Illinois
are attributable both to activity declines a nd expected control programs. T he effects of activity declines and control programs are about equal. SO 2 

### emission reductions estimated for this sector in Ohio (a 13.7 percent red uction) and Indiana (a 9 percent reduction) are all from expected declines in economic activity. The expected SO 2 

### emission
reductions in Michigan are mostly attributable to controls at BART eligible cement kilns.



## II. M ID

- 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 ef

fort 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 e stimates for Allegheny County were reviewed to understa nd where transport

factors needed t o be applied in order to estimate PM 10 

### and PM 2

. 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 A llegheny 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 PM 10 

### and PM 2.5 

### emission estimates for the above SCCs in order to provide the appropriate emission files for use in regional modeling of the Alleghe ny 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 NH 3 NO

x PM 10 PM 2.5 SO 2 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 NH 3 NO

x PM 10 - PRI PM 2.5 - PRI SO 2 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 NH 3 NO

x PM 10 PM 2.5 SO 2 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 p er year)

2007 State Totals

State CO NH 3 NO
x PM 10 PM 2.5 SO 2 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 NH 3 NO
x PM 10 PM 2.5 SO 2 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 NH 3 NO
x PM 10 PM 2.5 SO 2 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%



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