**U NITED STATES ENVIRONMENTAL PROTECTION AGENCY**  **REGION III 1650 Arch Street**  **Philadelphia, Pennsylvania 19103**

**DATE:** October 24, 2011 **SUBJECT:** Technical Support Document

- Pennsy lvania; Attainment Plan for the

Pennsy lvania Portion of the Philadel phia

- Wilmington, Pennsylvania

- New Jersey

Delaware 1997 Fine Particulate Matter Nonattainment Area

/s/ **FROM:** Rose Quinto, Environmental Engineer

Office of Air Program Planning **TO:** File /s/ **THRU:** Cristina Fernandez, Associate Director

Office of Air Program Planning This document provides a technical review of a revision to the Pennsylvania State Implementation Plan (SI P) submitted by the Pennsy lvania Department of the Environment al Protection (PADEP) on April 12 , 20 10 . This SI P revision addr ess es the attainment plan of the 1997 annual fine particulate matter (PM 2.5 ) national ambient air quality standard (NAAQS) for the Pennsylvania portion of the Philadelphia

- Wilmington , Pennsylvania

- New Jersey

- Delaware (PA

- NJ

- DE) nonattainment area ( Philadel phia area)

. The attainment plan includes Philadelphia area ’s attainment demonstration, motor vehicle emission budgets (MVEBs) used for transportation conformity purposes, an analy sis of reasonably available control measures (RACM) and reasonably

available control technology (RACT), base y ear emission s inventor y , and contingency

measures.
**A. BACKGROUND I.**  **Designation History** On July 18, 1997 (62 FR 36852), the Environmental Protection Agency ( EPA ) established the 1997 PM 2.5 NAAQS, including an annua l standard of 15.0 micrograms per cubic meter (  g/m 3 ) based on a 3

- ye ar average of annual mean PM 2.5 concentrations and a 24

- hour (or daily ) standard of 65  g/m 3 based on a 3

- ye ar average of the 98th percentile of 24

- hour concentrations. EPA established t he standards based on significant evidence and numerous health studies demonstrating that serious health effects are associated with exposures to PM 2.5 . Following promulgation of a new or revised NAAQS, EPA is required by the Clean Air Act ( CAA ) to desi gnate areas throughout the United States as attaining or not attaining the2

NAAQS; this designation process is described in section 107(d)(1) of the CAA. I n 1999, EPA and S tate A ir Q uality A gencies initiated the monitoring process for the 1997 PM 2.5 NAAQS and by January 2001 , established a complete set of air quality monitors. On January

5, 2005 (70 FR 944) , EPA p romulgated initial air quality designations for the 1997 PM 2.5 NAAQS based on air quality monitoring data for calendar y ears 2001

- 20 03. On Apri l 14, 2005 (70 FR 19844) , EPA p romulgated a supplemental rule amending the A gency ’s initial designations , with the same effective date (April 15, 2005) as 70 FR 944

. As a result of th is supplemental rule, PM 2.5 nonattainment designations are in effect for 39 areas, comprising 208 counties within 20 S tates (and the District of Columbia) nationwide, with a combined population of about 88 million. The Pennsylvania portion of the Philadelphia area is included in the list of areas not attaining the 1997 PM 2.5 NAAQS

. The Pennsy lvania portion of the Philadelphia area consists of the following counties : Bucks, Chester, Delaware, Montgomery , and Philadelphia. Itshould be noted that on November 13, 2009 (74 FR 58688), EPA revised the existing designation tables in 40 CFR part 81.339 to clarify that the 1997 designations were for both the annual PM 2.5 NAAQS and the 24

- h our PM 2.5 NAAQS

. The Pennsylvania portion of the Philadelphia area was designated unclassifiable/attainment for the 24

- hour PM 2.5 NAAQS

.
**II .**  **Clean Air Fine Particle Implementation Rule** On April 25 , 2007 (72 FR 20586) , EPA iss ued the Clean Air Fine Particle Implementation Rule for the 1997 PM 2.5 NAAQS . Th e “ PM 2.5 I mplementation R ule ” describes the CAA framework and requirements for developing S IP s for areas designated nonattainment for the 1997 PM 2.5 NAAQS (attainment plans)

. An attainment plan must include a demonstration that a nonattainment area will meet the applicable NAAQS within the t ime provided in the statute. This demonstration mus t include modeling (40 CFR 51.1007) that is performed in accordance with EPA modeling guidance (EPA

- 454/B

- 07

- 002, April 2007). It must also include supporting technical analy ses and descri ptions of all relevant adopted F ederal, s tate , and local regulation s and control measures that have been adopted in order to provide attainment by

the proposed attainment date

. For the 1997 PM 2.5 NAAQS, an attainment plan must show that a nonattainment area will attain the 1997 PM 2.5 NAAQS as expeditiously as practica

ble, but within five y ears of designation (i.e. attainment date of April 2010 based on air quality data for 2007

- 2009)

. I f the area is not expected to meet the NAAQS by April 2010, a s tate may request to extent the attainment date by

one to five y ears bas ed on the severity of the nonattainment problem or the feasibility of implementing control measures (CAA section 172(a)(2)) in the specific area

. For EPA to approve an extension of the attainment date beyond 2010, the state must provide an analy sis to sup port the request and demonstrate that the attainment date is as expeditious as practicable for the area given the facts and circumstances of the area and consistent with the3

statutory criteria for an extension. For each nonattainment area, the s tate must demonstrate that it has adopted all RACM , including all RACT as needed to provide for attainment of the PM 2.5 standards in the area “ as expeditiously

as practicable. ” The PM 2.5 I mplementation R ule provides guidance for making these RACM and RACT determin ations. Any measures that are necessary to meet these requirement s which are not already either F edera lly

promulgated or in an EPA

- approved part of the SI P must be submitted as part of the s tate’s attainment plan

. Any s tate measures must meet the applica

ble statutory

and regulatory

requirements, and in particular, must be Federally enforceable. The PM 2.5 I mplementation R ule also includes guidance on pollutants that s tates must address in their attainment demonstrations

. Section 302(g) of the CAA author izes EPA to regulate criteria pollutants and their precursors. Inthe case of PM 2.5 , the main chemical precursors are sulfur dioxide (SO 2 ), nitrogen oxides (NO x ), ammonia (NH 3 ), and volatile organic compounds (VOCs ). The effect of reducing emissions of p recursor pollutants that contribute to PM 2.5 concentrations varies by area, however, depending on PM 2.5 composition, emission levels, and other area

- specific factors. For this reason, the PM 2.5 Implementation R ule provided guidance recommending that state s elect direct PM 2.5 emissions and the precursor that would be most effective for attaining the NAAQS within the specific area, based upon an appropriate technical demonstration. Inaccordance with the PM 2.5 I mplementation R ule, direct PM 2.5 emissions me ans “ solid particles emitted directly

from an air emissions source or activity , or gaseous emissions or liquid droplets from an air emissions source or activity which condense to form particulate matter at ambient temperatures. Direct PM 2.5 emissions incl ude elemental carbon, directly emitted organic carbon, directly

emitted sulfate, directly

emitted nitrate, and other inorganic particles (including but not limited to crustal material, metals, and sea salt). ” The PM 2.5 I mplementation R ule requires all s ta tes to addres s SO 2 as a PM 2.5 attainment plan precursor and to evaluate SO 2 for possible control measures in all PM 2.5 nonattainment areas. States are also required to address NO X as a PM 2.5 attainment plan precursor and evaluate reasonable controls for N O X in PM 2.5 attainment plans, unless the s tate and EPA make a finding that NO X emissions fro m sources in the s tate do not significantly c ontribute to PM 2.5 concentrations in the relevant nonattainment area. Although current scientific information shows th at certain VOC emissions are precursors to the formation of secondary organic aerosol, and significant progress has been made in understanding the role of gaseous organic material in the formation of organic PM, this relationship remains complex. Further research and technical tools are needed to better characterize emissions invento ries for specific VOC compounds and to determine the extent of the contribution of specific VOC compounds to organic PM mass. Because of these factors, the PM 2.5 I mplementatio n R

ule did not require s tates to address VOCs as PM 2.5 attainment plan4

precursors and evaluate them fo r control measures, unless the S tate or EPA makes a finding that VOCs significantly

contribute to a PM 2.5 nonattainment problem in the s tate or to other d ownwind air quality

concerns. The PM 2.5 I mplementation R ule describes the formation of particles related to NH 3 emissions, which is a complex, nonlinear process. Though recent studies have improved our unde rstanding of the role of NH 3 in aerosol formatio n, ongoing research is needed to better describe the relationships between NH 3 emissions, particulate matter concentrations, and related impacts. Also, area specific data are needed to evaluate the effectiveness of reducing NH 3 emissions on reducing PM 2.5 concentrations in different areas , and to determine where NH 3 decreases may

increase the acidity

of particles and precipitation. For these reasons, in the PM 2.5 I mplementation R

ule, NH 3 is presumed not to be a PM 2.5 attainment plan precursor, meaning that the s tate is not required to address NH 3 in its attainment plan or evaluate sources of NH 3 emissions for reduction measures , unless the state or EPA makes a finding that NH 3 significantly contributes to a PM 2.5 nonattainment problem in the area or to othe r downwind air quality concerns. The presumpti ve inclusion of NO X and the presumptive exclusion of VOC and NH 3 as attainment plan precursors can be reversed based on an acceptable technical demonstratio n for a particular area by

the s tate or EPA. Such a demonstration should include information from multiple sources, including results of speciation data analy ses, air quality modeling studies, chemical tracer studies, emission inventories, or special intensive measurement studies to evaluate specific atmosp heric chemistry in an area ( S ee PM 2.5 I mplementation R ule for more information)

. The PM 2.5 I mplementation R ule also provided g uidance on other elements of a s tate’s attainment plan, including, but not limited to, consideration of emission inventories, contingency measures, and MVEBs used for transportation conformity purposes. There are, however, three aspects of the PM 2.5 Implementation Rule for which EPA received petitions requesting reconsideration. These pertain to the presumption or advance determin ation that compliance with the requirements of the Clean Air Interstate Rule (CAI R) automatically

satisfie s the requirements for RACT or RACM for NOx or SO 2 emissions f ro m electric generating unit (EGU) sources participating in regional cap and trade progr ams ; the suggestion in the preamble that the economic feasibility element of a RACT determination for EGUs should include consideration of whether the cost of a measure is reasonable in light of the benefits; and the policy

described in the preamble of al lowing certain emissions reductions f ro m outside the nonattainment are a to be credited as meeting the RFP requirement. EPA is granting these petitions and intends to undertake rulemaking to change these aspects of the PM 2.5 Implementation Rule. The attai nment plan for the Pennsylvania portion of the Philadelphia area did not rely

on any of these aspects of the rule.5

**III. Attaining Data Determination and**  **Finding of Attainment** The data in Table 1 indicates that the Pennsylvania portion of the Philadelph ia area is meeting the 1997 annual PM 2.5 NAAQS. I n addition, Table 2 shows that the Philadelphia area continues to attain the 1997 annual PM 2.5 NAAQS by 2010. More detailed information can be found in a technical support document ( TSD ) , entitled “Technic al Support Document for the Modeling Portion of the Commonwealth of Pennsylvania’s Fine Particulate Matter State Implementation Plan,” dated October 11, 2011, available on line at www.regulations.gov , Docket No. **EPA -**  **R03 -**  **OAR -**  **2010 -**  **0391.** However, this action does not determine that the Pennsylvania portion of the Philadelphia area has attained the 1997 annual PM 2.5 NAAQS and the information is included here only

to support the Pennsy lvania ’s demonstration that the P ennsylvania portion of the Philadelphia area could meet the attainment date of April 5, 2010, and continues to attain based on the most recent data available. EPA plans to take action to formally determine the Pennsylvania portion of the Philadelphia area ’s attainment of the 1997 annual PM 2.5 NAAQS in a separate action.
**Table 1. 2009 Annual Averaged PM 2.5**  **Design Value County**  **Site Name Site Number**  **Design Value (μg/m 3**  **)** Bucks Bristol 420170012 12.1 Chester New Garden 420290100 12.4 Delaware Chester 4204 50002 13.3 Montgomery Norristown 420910013 11.3 Philadelphia AMS L ab 421010004 12.9 Philadelphia NE Airport 421010024 11.9 Philadelphia Broad Street 421010047 13.5 Philadelphia Elmwood 421010136 12.7

**Table 2. 2008 -**  **2010 Monitored Annual**  **Design Value s**  **County Site Name**  **Site Number Design Value (μg/m**  **3 )**  **2008 2009**  **2010** Bucks Bristol 420170012 12.6 12.2 11.3 Chester New Garden 420290100 13.4 13.9 13.8 Delaware Chester 420450002 14.1 13.7 13.1 Montgomery Norristown 420910013 12.3 11.7 10.5 Philadel phia AMS L ab 421010004 13.4 12.5 11.5 Philadelphia NE Airport 421010024 12.4 11.5 10.5 Philadelphia Broad Street 421010047 14.5 13.0 11.9 Philadelphia Elmwood 421010136 13.2 13.36

**B . COMPONENTS OF**  **PENNSYLVANIA ’S**  **ATTAINMENT PLAN** Inaccordance with section 172 (c) of the CAA and the PM 2.5 I mplem entation R ule , the attainment plan submitted on April 12, 2010 by PADEP for the Pennsylvania portion of the Philadelphia area include d: (1) an emission s inventor y for the plan’s base y ear (2002) ; (2) an atta inment demonstration ; and (3) MVEBs for the attainment y ear. The attainment demonstration includes: (a) technical analy ses that locate, identify , and quantify sources of emissions contributing to violations of the 1997 annual PM 2.5 NAAQS; (b) analy ses of future ye ar emissions r eductions and air quality improvements expected to result f rom national and local programs from new measures to meet RACM/RACT; (c) adopted emission reduction measures with sche dules for implementation; and (d ) contingency measures for NO x and SO 2 to be implemented if the area did not meet RFP or did not attain the standard by the attainment date

. To analy ze future ye ar emissions reductions and air quality improvements, Pennsylvania use d local, regional , and national modeling anal ys es that have been developed to support Federal and lo cal emission reduction programs. This modeling was performed in accordance with EPA’s “Guidance on the Use of Models and Other Analy ses for Determining Attainment of Air Quality Goals for Ozone , PM 2.5 , and Regional Haze” (EPA

- 454/B

- 07

- 002, April 2007).

**C .**  **EPA’S REVIEW AND TECHNICAL INFORMATION** The following EPA analy sis of the PM 2.5 attainment plan for the Pennsylvania portion of the Philadelphia area, addresses all required elements of a PM 2.5 a ttainment plan as described in the PM 2.5 I mplementation R ule (72 FR 20586). **I. Pollutants Addressed**  Inaccordance with policies described in the PM 2.5 Implementation Rule, Pennsylvania ’s PM 2.5 attainment plan evaluates emissions of direct PM 2.5 , SO 2 , and NOx in the Pennsylvania portion of the Philadelphia area

. Because of uncertainties regarding NH 3 emission inventories and the efficacy

of ammonia control technologies as noted earlier in this notice, the final rule set s forth the presumption that NH 3 is not a PM 2.5 precursor and that the s tates are not required to address NH 3 in their attainment plan. Similarly , VOC emissions are presumed not to be an attainment plan precursor because of uncertainties regarding the role of VOC in secondary organic a erosol formation. Pennsylvania’s attainment plan does not reverse this presumption

. **II. E**  **missions Inventory Requirements** Section 172(c)(3) of the CAA requires s tates to develop emissions inventories of point, area, onroad mobile, and nonroad mobile sou rces for their attainment demonstrations. These inventories provide a detailed accounting of all emissions and emissions sources by precursor or pollutant. Inaddition, inventories are used to model air quality to demonstrate that attainment of7

the 1997 PM 2.5 NAAQS as expeditiously as practicable, and if an attainment extension beyond 2010 is needed to support the need for such an extension. Emissions inventory guidance was provided in the April 1999 document “Emissions Inventory Guidance for I mplementat ion of Ozone and Particulate Matter NAAQS and Regional Haze Regulations,” (EPA

– 454/R

– 99

– 006), which was updated in November 2005 (EPA

– 454/R

– 05

– 001). Emissions reporting requirements were provided in the 2002 Consolidated Emissions Reporting Rule (CERR) (6 7 FR 39602). On December 17, 2008 (73 FR 76539), EPA promulgated the Air Emissions Reporting Requirements (AERR) to update emissions reporting requirements in the CERR, and to harmonize, consolidate and simplify data reporting by

states. Inaccordance wi th the A ERR and the November 2005 guidance, the PM 2.5 I mplementation R

ule required s tates to submit inventory information on directly

emitted PM 2.5 and PM 2.5 precursors and any additional inventory

information needed to support an attainment demonstration. PM 2.5 is comprised of filterable and condensable emissions. Condensable particulate matter (CPM) can comprise a significant percentage of direct PM 2.5 emissions from certain sources, and are required to be included in national emission inventories based on emission factors. Test Methods 201A and 202 are available for source

- specific measurement of condensable emissions. However, the PM 2.5 Implementation Rule acknowledged that there were issues and concerns related to availability and implementation of these test methods as well as uncertainties in existing data for condensable PM 2.5 . I n recognition of these concerns, EPA established a transition period during which EPA could assess possible revisions to available test methods and to allow time for Stat es to update emissions inventories as needed to address direct PM 2.5 , including condensable emissions. Because of the time required for this assessment, EPA recognized that States would be limited in how to effectively address CPM emissions, and establish ed a period of transition, up to January 1, 2011, during which State submissions for PM 2.5 were not required to address CPM emissions. Amendments to these test methods were proposed on March 25, 2009 (74 FR 12969), and finalized on December 21, 2010 (75 F R 80118). The amendments to Method 201A add ed a particle

- sizing device for PM 2.5 sampling , and t he amendments to Method 202 revise d the sample collection and recovery procedures of the method to reduce the formation of reaction artifacts that could lead t o inaccurate measurements of CPM emissions

. The period of transition for establishing emissions limits for condensable direct PM 2.5 ended on January

1, 2011. PM 2.5 submissions made during the transition period are not required to address CPM emission s; however, States must address the control of direct PM 2.5 emissions, including condensable emissions, with any new action taken after this January 1, 2011. Pennsylvania submitted the Pennsylvania portion of the Philadelphia area attainment plan prior to January

1, 2011 and did not consider condensables. InJuly 2008, EarthJustice filed a petition requesting reconsideration of EPA's transition period for CPM emissions provided in the PM 2.5 Implementation Rule. In January 2009, EPA8

decided to allow stat es that have not previously addressed CPM to continue to exclude CPM for PSD permitting during the transition period. Today ’s action reflects a review of Pennsylvania’s submittal based on current EPA guidance as described in the PM 2.5 Implementation Rule. More information and the review and evaluation of the methods used for the emissions inventory submitted by

Pennsylvania are found in section I II of Pennsylvania’s attainment plan submittal and a TSD entitled, “Technical Support Document for the Pennsylv ania P ortion of the Philadelphia

- Wilmington, PA

- NJ

- DE PM 2.5 Noanattainment Area: State Implementation Plan Attainment Demonstration and Base Year Inventory ,” dated October 11, 2011

.
**1. 2002 Base Year Emission Inventories**  An emission inventory

is an estima te of the emissions from sources in a particular area. PADEP developed an emission inventory for 2002, which is the base y ear for attainment planning purposes with respect to 8

- hour ozone and PM 2.5 SI Ps and for planning purposes with respect to the region al haze SI Ps. The 2002 base y ear inventory includes the pollutants PM 10 , PM 2.5 , SO 2 , NOx, VOC, and NH 3 . The inventory consists of four sectors: stationary point sources, stationary

area sources, highway

vehicle sources and nonroad sources. The Mid

Atlantic/Northeast Visibility Union (MANE

- VU) compiled a regional inventory from the emission inventories of the Northeastern and Mid

- Atlantic states. This regional inventory was used to perform the regional modeling analy sis used in the Pennsylvania’s air qu ality management effort to attain the 8

- hour ozone NAAQS and the PM 2.5 NAAQS, and to prepare the regional haze plan. **Stationary sources (or point source s)**  are sources for which PADEP collects individual emissions

- related information. They generally repre sent major stationary sources but may

be smaller. The point source data for 2002 is derived from the Air Information Management Sy stem/environment, Facility , Application, Compliance Tracking Sy stem (AI MS/eFACTS). The AI MS/eFACTS database is comprised o f sources identified and inventoried by PADEP’s regional and central offices through permitting, field inspections, and survey s. More information is found in Appendix B

- 1 of Pennsylvania’s attainment plan that includes information on stationary point sour ce emission methodology , and Appendix B

- 2 is the data that set for facility 2002 annual emissions. Appendix B

- 3 is a table documenting banked emission reduction credits for the Pennsylvania portion of the Philadelphia area (5 counties) in the 2009 emissio n projection. **Area sources** are industrial, commercial, and residential sources too small or too numerous to be handled individually . These include but are not limited to commercial and residential open burning architectural and industrial maintenance coatings applications and clean

up, consumer product use, and vehicle refueling at service stations. Where there is overlap between stationary

point sources and stationary area sources, the area source values are adjusted to remove any

double counting. PADE P’s inventory contained estimations of emissions by multiplying an emission factor by an indicator or activity

level for each category

at the county9

level. These emissions are calculated on an annual basis since the activity data are generally available o n an annual basis. Area source estimates were provided by source classification code (SCC). More information is found in Appendix C

- 1 of Pennsylvania’s attainment plan where specific information on the procedure used for each industry ty pe is contained and Appendix C

- 2 is a table containing stationary area source emissions data for the Pennsylvania portion of the Philadelphia area (5 counties). **Highway vehicles,** which include passenger cars and light

- duty trucks, other trucks, buses and motorcy cles. Onr oad mobile source emissions inventory was developed using the most current version of EPA’s highway mobile source emissions model MOBI LE6.2. PADEP also used PPSUI TE, an enhanced version of the Post Processor for Air Quality software sy stems used for previ ous inventory submissions in Pennsy lvania. The Pennsylvania Department of Transportation (PennDOT) provided estimates of vehicles miles traveled (VMT) by vehicle ty

pe and roadway

ty pe. Pennsylvania’s methodology is consistent with the January 2002 guidan ce publishe d by

EPA’s Office of Transportation and Air Quality (OTAG) entitled, “Technical Guidance on the Use of MOBI LE6 for Emissions Inventory Preparation.” More information on highway emission methodology

is available in Appendix E of the Pennsylvan ia’s attainment plan. Appendix E

- 1 provides the 2002 base y ear and 2009 projections of mobile (highway

) VMT and annual PM 2.5 direct and precursor emissions. The document summarizes the methodology and data inputs used to produce the mobile emissions inve ntory
. Appendix E

- 2 is a table of 2009 five

- county Philadelphia area annual highway emissions listed by SCC. Appendix E

- 3 describes the inputs to MOBI LE6.2 used to generate emission factors for a specific area. Some examples of the inputs described in Appendix E

- 3 are the ty pe and frequency of vehicle emission testing, the fuel ty pes required in the area, temperatures by month, and fleet age. The summary in Appendix E

- 3 indicates when default information contained in the model is used rather than specif ic area information. Appendix E

- 4 is an electronic file that provides all of the input coding for a sample segment and scenario used in Pennsylvania’s MOBI LE6.2 modeling sy stem. **Nonroad sources** encompass a diverse collection of engines, including but no t limited to outdoor power equipment, recreational vehicles, farm and construction machinery , lawn and garden equipment, industrial equipment, recreational marine vessels, commercial marine vessels, locomotives, ships, and aircraft. The majority of nonroa d emission source categories were estimated using the EPA NONROAD 2005 model . The NONROAD model estimates emissions for diesel, gasoline, liquefied petroleum gasoline, and compressed natural gas

- fueled nonroad equipment ty

pes and includes growth factors. The NONROAD model does not estimate emissions from aircraft, locomotives or commercial marine vessels. Emissions from aircraft, locomotives or commercial marine vessels were estimated using EPA guidance and best available information. More information on nonroad sources is found in Appendix F of the Pennsylvania’s attainment plan. Appendix F

- 1 is the technical document providing the methodology and10

description of the procedures used to generate 2002 and 2009 county

- level pollutant emission estimates for nonroad mobile engines included in EPA’s NONROAD 2005 model, locomotive engines and aircraft operations. Appendix F

- 2 is a table of the specific emissions data used to calculate the nonroad emissions sorted by source category . Appendix F

- 3 contains the 2002 Philadelphia I nternational Airport (PHL ) inventory that includes aircraft and aircraft

- related equipment f

rom the EPA

- approved mode l, “E missions and D ispersion M odeling S ys tem (EDMS) ,” and also additional on - airport highway , stationary and area source emissions

. The emissions inventory

for the base y ear, 2002, was developed in accordance with EPA guidance, “Emissions Inventory Guidance for I mplementation of Ozone and Particulate Matter National Ambient Air Quality Standards and Regional Haze Regulat ions, EPA

- 454/R

- 05

- 001, August 2005, updated November 2005.” Table 3 summarizes the emissions for 2002. **Table 3. 2002 Annual Emissions (Tons per Year) Philadelphia area 2002**  **PM 2.5**  **PM 10**  **SO 2**  **NOx VOC**  **NH 3**  Stationary

Point Sources 2139 3430 23745 221 24 8183 256 Area Sources 10020 55224 13153 13029 59227 4821 Highway Vehicle Sources 1033 1492 1920 63476 33974 2614 Nonroad Sources 1535 1611 1640 21619 21589 14 **Total** 14727 61758 40459 120248 122973 7705

**2. 2009 Proj**  **ected Emission Inventories** Table 4 summarizes the emissions expected in 2009. These emissions take activity and emissions growth and/or controls from 2002 into account. Appendix D of the Pennsylvania’s attainment plan, relating to emissions projections , contains documents that describe the methodologies used to project the 2002 baseline emissions to 2009. **Table 4. 2009 Projected Emissions (Tons per Year) Philadelphia area 2009**  **PM 2.5**  **PM 10**  **SO 2**  **NOx VOC**  **NH 3**  Stationary

Point Sources 2817 3840 12658 2 2252 7881 357 Area Sources 10324 59533 13972 13755 55868 5749 Highway Vehicle Sources 699 1193 327 36318 20298 3118 Nonroad Sources 1356 1428 800 18874 15971 16 PHLCapacity Enhancement Program 0 0 0 0 254 0 Emission Reduction Credits Banked 23 32 442 432 1561 0 **Totals** 15219 66035 28200 91651 101834 923911

Sulfur and nitrogen are major contributors to the Pennsylvania portion of Philadelphia area’s PM 2 .5 nonattainment problem. Therefore, even though the direct PM 2.5 emissions increase in 2009, the reductions of PM 2.5 precursors, SO 2 and NOx, ensures that the Philadelphia area attains the PM 2.5 NAAQS by 2010.

**3. Growth Projections Methodologies**  Growth p rojections m ethodologies describe the data, methods and assumptions utilize in developing estimates of emissions changes between 2002 and the milestone y ear 2009. Appendix D

- 1 of the Pennsy lvania’s attainment plan contains the technical support document e ntitled, “Development of Emission Projections for 2009, 2012, and 2018 for Non

- EGU Point, Area, and Nonroad Sources in the MANE

- VU Region,” developed by the Mid

- Atlantic Regional Air Management Association (MARAMA). Th is document provides detail on the sp ecific factors, control assumptions, and implementation schedules used in the emission projection calculations for each source category

.
**III. Attainment Demonstratio n**  **- Modeling**  All attainment demonstrations must include modeling that is performed in a ccordance with EPA’s “Guidance on the Use of Models and Other Analy ses for Demonstrating Attainment of Air Quality

Goals for Ozone, PM 2.5 , and Regional Haze” (EPA

- 454/B

- 07

- 002, April 2007)

. Modeling may

be based on national (e.g., EPA), regional (e.g., Oz one Transport Commission), local modeling, or a combination th ereof, if appropriate. A description of modeling used to support Philadelphia ’s attainment demonstration follows. More detailed information on the modeling is discussed in a TSD entitled, “Tec hnical Support Document for the Modeling Portion of the Commonwealth of Pennsylvania’s Fine Particulate Matter State Implementation Plan,” dated October 11, 2011 and s ection V of the Pennsylvania’s attainment plan. Based on 2006

– 2008 monitoring data, al l monitors in the Pennsy lvania portion of the Philadelphia area meet the EPA’s annual PM 2.5 standard (15.0 μg/m 3 ). The Philadelphia area’s maximum 2008 annual design value of 14.5 μg/m 3 was observed at the Broad Street monitor. Based on 2006

– 2008 monitoring data, a ll monitors within the Philadelphia area are monitoring attainment of the 1 997 24

- hour PM 2.5 standard (65 μg/m 3 ). The maximum 2008 24

- hour design value in the P hiladelphia area was 36 μg/m 3 , observed at the New Garden monitor. The Philadelphia area is required to attain the PM 2.5 standard no later than five y ears from the effectiv e date of designation of April 5, 2005 (April, 2010). The purpose of the attainment demonstration is to ensure, through grid modeling, that projected emissions (with controls) will not cause the nonattainment area to exceed the 1997 PM 2.5 NAAQS. A comple x grid model was run and processed over the entire Northeast to determine if the P hiladelphia area would attain the PM 2.5 standard by April 5, 2010.12

**Philadelphia Area Conceptual Model Description** A conceptual model describes how weather patterns affec t the formation and transport of PM 2.5 , accounting for emissions and photochemistry

. The conceptual model for the Philadelphia area was based on information from the Northeast States for Coordinated Air

- Use Management (NESCAUM) final report entitled , “ The Nature of the Fine Particle and Regional Haze Air Quality Problems in the MANE

- VU Region: A Conceptual Description (2006) ” and PADEP ’s modeling protocol documentation (October 2007). The NESCAUM document contains a conceptual description that explains h ow elevated regional PM 2.5 peak concentrations in the summer differ significantly from the largely

urban peak concentrations observed during winter. On average, summertime concentrations of sulfate in the northeastern United States are more than twice that of the next most important fine particle constituent, organic carbon (OC), and more than four times the combined concentration of nitrate and black carbon (BC) constituents. Episodes of high summertime sulfate concentrations are consistent with stagnant meteorological flow conditions upwind of the Pennsylvania portion of the Philadelphia area and the accumulation of airborne sulfate (via atmospheric oxidation of SO 2 ) followed by

long

- range transport of sulfur emissions from industrialized areas within an d outside the area. National assessments have indicated that in the winter, sulfate levels in urban areas are higher than background sulfate levels across the eastern U.S., indicating that the local urban contribution to wintertime sulfate levels is signi ficant relative to the regional sulfate contribution from long

- range transport. A network analy sis for the winter of 2002 suggests that the local enhancement of sulfate in urban areas of the MANE

- VU region ranges from 25 to 40% and that the long

- range transport component of PM 2.5 sulfate is still the dominant contributor in most eastern cities. Inthe winter, urban organic carbon (OC) and sulfate each account for about a third of the overall PM 2.5 mass concentration observed in Philadelphia and New York C ity areas. Nitrate also makes a significant contribution to urban PM 2.5 levels observed in the northeastern United States during the winter months. Wintertime concentrations of OC and nitrate in urban areas can be twice the average regional concentration s of these pollutants, indicating the importance of local source contributions. This is likely because winter conditions are more conducive to the formation of local inversion lay ers which prevent vertical mixing. Under these conditions, emissions from t ailpipe, industrial and other local sources become concentrated near the Earth’s surface, adding to background pollution levels associated with regionally transported emissions. **The Model U**  **sed in the Attainment Demonstration** By agreement of OTC, the N ew York State Department of Environmental Conservation13

(NYSDEC) ran the Community Multi

- scale Air Quality

Model (CMAQ) for the states in the northeast ozone transport region that includes Pennsylvania. EPA agrees CMAQ is appropriate for this modeling demo nstration. The inputs of the model are described in section V of the attainment plan submittal. **Meteorological Time Periods Used in the Modeling** Since the Philadelphia area’s attainment demonstration used a resource intensive photochemical grid model, EPA accepts the use of single, recent representative y ear to be used for an annual simulation. Two factors were used in selecting 2002 as the representative year: the observed annual mean concentrations of PM 2.5 are close to the 3

- ye ar observed design v alue at all, or most monitoring sites, and the pattern of quarterly mean values is similar to the pattern of quarterly mean concentrations averaged over 3 y ears. **Meteorological Data Used in the Air Quality Model** The OTC modeling committee decided to us e a prognostic meteorological model that provides life

- like meteorological inputs to the photochemical grid model. The Pennsy lvania State University

/National Center for Atmospheric Research Mesoscale Meteorological Model (MM5) version 3.6 was chosen for the modeling analy sis. The MM5 model provides a reasonable representation of weather conditions at th e surface and aloft. **Domain of the Model, Horizontal/Vertical Resolution and the Initial and Boundary Conditions**  The model ing domain extends from Main e to Florida and out in the Atlantic Ocean on the east and we st to the Mississippi River. The size of the modeling domain was made large enough to include all emission sources that affect PM 2.5 concentration in the northeastern United States

. Even this b oundary

is defined by

a larger photochemical model ing domain th at cover s much of North America

. Over the northeastern United States, the model used 12 kilometer grid cells

. The Pennsy lvania portion of the Ph iladelphia area i s included in the 12 kilometer grid cell area. T he OTC Modeling Committee used a 12

- kilometer grid size for the areas in and near its states to provide a fine enough grid resolution to adequately capture the PM patterns experienced in the ozone transport region (OTR). Outside the loc al area s the grid resolution used in the modeling is 36 kilometers . The selection of model domains and horizontal grid resolution was deemed acceptable to EPA. Vertical resolution is the number of lay ers and the size of each lay er in the model. The laye rs in the photochemical grid model were set up to be compatible with the model that produced weather conditions for the photochemical grid model. T he vertical resolution used in the modeling exercise followed EPA’s modeling guidance and therefore adequa tely represent s t he atmosphere where PM 2.5 is emitted, forms and is transported.14

**Emission s Used in the Air Quality Model**  The emissions data for 2002 were generated by individual states within the OTR and assembled and processed through Mid

- Atlantic Northeast Visibility Union (MANE

- VU), a Regional Planning Organization (RPO). These emissions were then processed by NYSDEC using the sparse matrix operator kernel emissions (SMOKE) emissions processor to provide CMAQ compatible inputs. The 2002 emissio ns for the non

- OTR areas within the modeling domain were obtained from the corresponding RPOs and were processed using SMOKE, in manner similar to that of the OTR emissions. The OTR states, through MANE

- VU, contracted MACTEC Federal Programs (called Contr actor) to develop 2009, 2012 and 2018 inventories based on 2002 inventories that the states had previously developed for the base

- ye ar model work. The Contractor, in consultation with the states, developed the necessary growth and control factors and appli ed to the 2002 inventory

. **Base Case Run Model Performance Evaluation** NYSDEC performed a model evaluation for the OTC to determine how well CMAQ reproduced the 2002 PM 2.5 concentrations. CMAQ was employ ed to simulate PM 2.5 for the calendar y ear 2002. A review of PM 2.5 and its individual species was conducted for the study domain. Several observations were made with respect to model performance: 1) a pproximately 80

– 90 percent of organic mass (OM) is in the primary fraction ; 2) CMAQ captures seasona l variation in SO 4 well ; 3) CMAQ appears to overestimate primary PM 2.5 components, especially during colder months ; and CMAQ appears to underestimate secondary OM during the summer. These issues are not of great regulatory concern since attainment tests a re based on the application of relative response factors. Therefore, the regional and local model performance is acceptable for PM 2.5 . While there are some differences between the spatial data between sub

regions, there is nothing to suggest a tendency f or the model to respond in a sy stematically different manner between regions. Examination of the statistical metrics by sub

- region confirms the absence of significant performance problems arising in one area but not in another, building confidence that th e CMAQ modeling sy stem is operating consistently across the full OTC domain. This confidence in the modeling results allows for the modeling sy stem to be used to support the attainment plan to meet the 1997 annual PM 2.5 NAAQS. **2009 C ontrol**  **Case M odel**  **ing and Modeled Attainment Test**  As previously

mentioned, the Pennsylvania portion of the Philadelphia area has an attainment date of April 5, 2010. The PM 2.5 NAAQS include an annual standard of 15 μg/m 3 based on the 3

- ye ar average of annual mean PM 2.5 conc entrations.15

The purpose of a modeling assessment is to determine if control strategies currently being implemented (“on the books”) will lead to attainment of the annual average NAAQS for PM 2.5 by 2009. The modeling is applied in a relative sense, simil ar to the 8

- hour ozone attainment test. However, the PM 2.5 attainment test is more complicated and reflects the fact that PM 2.5 is a mixture. I n the test, ambient PM 2.5 is divided into major components, with a separate relative response factor (RRF) and future design value (DVF) calculated for each of the PM 2.5 components. Since the attainment test is calculated on a per species basis, the attainment test for PM 2.5 is referred to as the Speciated Modeled Attainment Test (SMAT ). **Annual SMAT Results** Tabl e 4 presents the results of the annual SMAT results for the Philadelphia area. The SMAT results demonstrate that the projected average annual arithmetic mean PM 2.5 concentration calculated at each Federal Reference Method (FRM) monitor attains the annual PM 2.5 NAAQS. Specifically , all calculations are less than15 μg/m 3 . Table 4 presents the results of the annual SMAT results for a suite of regional modeling runs conducted by OTC each representing OTB/OTW

– “On the Books, On the Way ” control measures. A ll runs demonstrate compliance with the annual PM 2.5 NAAQS.
**Table 4.**  **Annual SMAT Results for Philadelphia**  **- Wilmington, PA**  **- NJ**  **- DE**  **PM 2.5**  **Nonattainment Area On**  **- The**  **- Books**  **- On**  **- The**  **- Way Control Measures** 

Insummary , the basic photochemical grid modeling, pres ented in the Philadelphia area **AIRS ID Site** 

**Name County**  **State 2000**  **- 2004**  **Baseline Design Valu e**  **2009 Q1**  **Q2 Q3**  **Q4 DVF**  420170012 Bristol Bucks PA 14.14 13.69 14.73 13.85 12.1 420290100 New Garden Chester PA 14.39 14.73 16.36 13.76 12.4 420450002 Chester Delaware PA 15.07 15.96 16.34 13.74 13.3 420910013 Norristown Montgomery PA 12.68 13.62 1 3.96 12.34 11.3 421010004 AMS Lab Philadelphia PA 15.99 14.01 15.95 13.82 12.9 421010024 NE Airport Philadelphia PA 13.58 13.63 14.95 12.96 11.9 421010047 Broad Street Philadelphia PA 16.59 16.45 15.80 15.37 13.5 421010136 Elmwood Philadelphia PA 15.70 14.20 15.27 12.99 12.7 100031003 Bellefonte New Castle DE 14.87 15.16 15.50 13.13 12.6 100031007 Lums Pond New Castle DE 13.16 14.37 16.05 10.66 11.3 100031012 Newark New Castle DE 15.27 14.91 16.53 13.14 12.6 100032004 MLK New Castle DE 16.41 15.40 1 7.61 14.04 13.3 340070003 Camden Camden NJ 13.99 14.54 15.76 12.47 12.3 340071007 Pennsauken Camden NJ 13.99 14.00 14.75 13.59 12.3 340155001 Gibbstown Gloucester NJ 13.92 13.43 15.08 11.39 11.716

attainment plan, used the methods recommended in EPA’s modeling guidance. When EPA’s attainment test is applied to the modeling results, the 2009 annual

- average PM 2.5 design value is predicted to be 13.5μg/m 3 in the Philadelphia area. Therefore, based on EPA’s modeled attainment test, the Pennsylvania portion of the Philadelphia area reached attainment of the annual average PM 2.5 standard in 2009 before the attainment date of April 5, 2010. **Supplemental Analyses and Weight of Evidence (WOE) Determination** EPA’s modeling guidance states that additional analy ses are recommended to determine if attainment will be likely , even if the modeled attainment test is “passed.” The guidance recommends supplementary analy ses in all cases. EPA’s modeling guidance d escribes how to use a photochemical grid model and additional analy tical methods to complete a WOE analy sis to estimate if emissions control strategies will lead to attainment. A WOE analy sis is a supporting analy sis that helps to determine if the results of the photochemical modeling sy stem are correctly

(or not correctly

) predicting future air quality

. All models, including the CMAQ, model have inherent uncertaint ies. Over or under prediction may

result from uncertainties associated with emission inventories, meteorological data, and representation of PM 2.5 chemistry in the model. Therefore, EPA modeling guidance provides for other evidence to address these model uncertainties so that proper assessment of the probability

to attain the applicable standards can be made. EPA modeling guidance states that those modeling analy ses that show that attainment with the NAAQS will be reached in the future with some margin o f safety (i.e., estimated concentrations below 14.5 μg/m 3 for annual PM 2.5 and 62 μg/m 3 for 24

- hour PM 2.5 ) need more limited supporting material. Due to the fact that the modeling results presented in Table 4 fall below the aforementioned “weight of evidence” thresholds established by EPA, a limited suppl emental analy sis was deemed necessary to support the 2009 attainment demonstration. PADEP’s supporting evidence includes a brief summary of the modeling demonstration, recent trends in the Philadelphia area’s monitoring data and a brief analy sis of some o f the largest SO 2 sources within the nonattainment area ( s ection V of Pennsylvania’s attainment plan)

.
**I V.**  **Reasonably Available Control Measures/Reasonably Available Control Technology 1**  **. Requirements for RACM/RACT**  CAA section 172(c) (1) requires th at each attainment plan “provide for the implementation of all RACM as expeditiously as practicable, i ncluding such reductions in emissions from the existing sources in the area as may be obtained through the adoption, at a minimum, of RACT , and shall prov ide for attainment of the national primary ambient air quality standards.” EPA interprets RACM including RACT under section 172 as measures that a state finds are both reasonably

available and contribute to attainment as expeditiously are practicable17

in t he nonattainment area. Thus, what constitutes RACM or RACT in a PM 2.5 nonattainment area is closely

tied to the expeditious attainment demonstration of the plan. See 40 CFR section 51.1010; 72 FR 20586 at 20612. States are required to evaluate RACM/RA CT for direct PM 2.5 emissions and all of the area’ s attainment plan precursors. See 40 CFR section 51.1002 (c); 72 FR 20586 at 20589

- 97. Consistent with the guidance provided for the PM 2.5 Implementation Rule, a state initially must evaluate RACM/RACT for sources that emit direct PM 2.5 , SO 2 , and NOx. A state may establish with an appropriate demonstration that it should not regulate NOx in the specific nonattainment area, so it could thereby

forgo evaluation of RACM/RACT for NOx. Because EP A concluded that VOC and NH 3 are presumptively not regulatory

precursors for PM 2.5 , unless the state or EPA determines that it is necessary to regulate them in a specific nonattainment area, the state is not required to evaluate RACM/RA CT for sources of VOC or NH 3 un less there is a determination supported by

an appropriate demonstration that such emissions need to be regulated for expeditious attainment of the NAAQS in the specific area. For PM 2.5 attainment plans, the PM 2.5 Implementation Rule requires a combined ap proach to RACM and RACT under subpart 1 of Part D of the CAA. Subpart 1, unlike subparts 2 and 4, does not identify

specific source categories for which EPA must issue control technique documents or guidelines, or identify specific source categories for s tate and EPA evaluation during attainment plan development. See 72 FR 20586 at 20610. Rather, under subpart 1, EPA considers RACT to be part of an area’s overall RACM obligation consistent with the section 172 definition. Because of the variable nature of the PM 2.5 problem in different nonattainment areas which may

require states to develop attainment plans that address widely disparate circumstances, EPA determined not only that states should have flexibility with respect to RACM/RACT controls but also that in areas needing significant emission reductions, RACM/RACT controls on smaller sources may be necessary

to reach attainment as expeditiously as practicable. See 72 FR 20586 at 20612, 20615. Thus, under the PM 2.5 Implementation Rule, RACM and RACT are those reasonably available measures that contribute to attainment as expeditiously

as practicable in the specific nonattainment area. See 40 CFR section 51.1010; 72 FR 20586 at 20612. Specifically , the PM 2.5 Implementation Rule requires that attainmen t plans include the list of measures that a state considered and information sufficient to show that the state met all requirements for the determination of what constitutes RACM/RACT in a specific nonattainment area. See 40 CFR section 51.1010(a). In ad dition, the PM 2.5 Implementation Rule requires that the state, in determining whether a particular emissions reduction measure or set of measures must be adopted as RACM/RACT, consider the cumulative impact of implementing the available measures and to ado pt as RACM/RACT any potential measures that are reasonably available considering technological and economic feasibility if, considered collectively , they would advance the attainment date by one y ear or more. I f a measure or measures is not necessary for expeditious attainment of the NAAQS in the area, then by definition that measure is not RACM/RACT for purposes of the 1997 PM 2.5 NAAQS in that area. Any measures that are18

necessary to meet these requirement s which are not already either F ederally

promulga ted, part of the state’s SI P, or otherwise creditable in SI Ps must be submitted in enforceable form as part of a state’s attainment plan for the area. See 72 FR 20586 at 20614. Guidance provided in the PM 2.5 Implementation Rule for evaluating RACM/RACT level controls for an area also indicated that there could be flexibility with respect to those areas that were predicted to attain the 1997 PM 2.5 NAAQS within five y ears of designation as a result of existing national or local measures. See 72 FR 20586 at 20612. In such circumstances, EPA indicated that the state may conduct a more limited RACM/RACT analy sis that does not involve additional air quality

modeling. Moreover, the RACM/RACT analy sis for such area would focus on a review of reasonably availa ble measures, the estimation of potential emissions reductions, and the evaluation of the time needed to implement the measures. Thus, the PM 2.5 Implementation Rule guidance recommended that not all areas would need to conduct as rigorous an analy sis, and suggested that a less rigorous analy sis would be needed for those areas expected to attain within the initial five y ears from designation as a nonattainment area for the 1997 PM 2.5 NAAQS. A more comprehensive discussion of the RACM/RACT requirement for PM 2.5 attainment plans and EPA’s guidance for it can be found in the PM 2.5 Implementation Rule preamble. See 72 FR 20586 at 20609

– 20633.

**2 . Pennsylvania’s Analysis of Pollutants and Sources Pennsylvania Portion of the**  **Philadelphia Area.** Pennsy lvania ’s analy sis appears in section I V.B, page 29 and Appendices G

- 1, G

- 2 and G

- 3 of the attainment plan submission. Based upon the emissions inventory for the area, Pennsylvania determined that it would be appropriate to evaluate sources of PM 2.5 , SO 2 , and NO x located in the nonattainment area for potential control as RACM/RACT. Pennsy lvania did not determine that controls of sources of VOC or NH 3 would be necessary for expeditious attainment of the NAAQS in this area, nor does EPA believe that there is a nee d to do so. Pennsylvania ’s determination with respect to which pollutants the plan should evaluate is at section I .B, page 1 of the attainment plan submittal. After evaluating which pollutants should be ad dressed in the attainment plan, Pennsylvania ide ntified all source categories of those emissions located within the nonattainment area to determine available controls that could bring the area into attainment as expeditiously as possible. See section I V.B of the attainment plan submittal. Based on the emissions inventory and other information, Pennsylvania identified the following source categories as sources that should be evaluated for controls:

- Consumer Products

- Portable Fuel Containers19

- Adhesives and Sealants Application

- Diesel Engine Chip Reflas h

- Cutback and Emulsified Asphalt Paving

- Cement Kilns

- Glass Furnaces

- In dustrial, Commercial, and Institutional (I CI ) Boilers

- Regional Fuels

- Electric Generating Units (EGUs) Appendix G

- 1 of the attainment plan submittal contains the Ozone Transport Commissi on (OTC) report entitled, “I dentification and Evaluation of Candidate Control Measures, Final Technical Support Document (MACTEC, February 2007).” This final report contains detailed information about the process and includes tables summarizing the emissi on reduction potential of each control measure by source category

and projection y ear. Pennsy lvania also participated in an assessment of control measures for pollutants and sources affecting visibility though the MANE

- VU regional haze process. MANE

- VU developed a list of control measures for consideration and analy sis:

- Coal and oil

- fired EGUs

- Point and area source industrial, commercial and institutional boilers

- Cement kilns

- Li me kilns

- The use of heating oil

- Residential wood combustion and open burnin g Appendix G

- 3 of the attainment plan submittal, contains the final report entitled, “Assessment of Reasonable Progress for Regional Haze in MANE

- VU Class IAreas (MACTEC, July 2000),” from the MANE

- VU control measure assessment project. This report pres ents the results of an analy sis of the economic and environmental impacts of the potential scenarios that could be implemented by MANE

- VU states to reduce emissions from selected source categories in order to make reasonable progress toward meeting visibil ity improvement goals. Inaccordance with 40 CFR 51.1010, a SI P revision for a PM 2.5 nonattainment area is required to demonstrate that all RACM, including RACT stationary sources necessary

to demonstrate attainment as expeditiously as practicable have be en adopted. The cumulative impact of implementing available measures must be considered in determining whether a particular emission reduction measure or set of measures is required to be adopted as RACM. Potential measures that are reasonably available considering technical and economic feasibility must be adopted as RACM if, considered collectively , they would advance the attainment date by one y ear or more. Since the Pennsylvania portion of the Philadelphia area attained at the end of 2009, any RACM m easures need to be in effect in 2008. PADEP determined that there are no additional control measures that could be adopted by January 1, 2008. I n addition, existing20

measures and measures planned for implementation by 2009, enables the Philadelphia area t o attain the 1997 PM 2.5 NAAQS. Therefore, no further actions on RACM or RACT are warranted.

**3 . Pennsylvania’s evaluation of RACM/RACT control measures for the Pennsylvania**  **Portion of the Philadelphia Area.** Inaccordance with section 172 of the CAA, th e Pennsylvania portion of the Philadelphia area has adopted all RACM, including RACT, needed to attain the standards “as expeditiously as practicable.” Pennsylvania’s demonstration for attaining the 1997 annual PM 2.5 NAAQS in the Pennsylvania portion of the Philadelphia area is based on enforceable measures.

**a. STATIONARY POINT SOURCES**  Small S ources of NOx, Cement Kilns and L arge Stationary I nternal Combustion Engines PADEP established additional ozone season requirements for small sources of NOx in the c ounties of Bucks, Chester, Delaware, Montgomery , and Philadelphia in regulations that were adopted on December 11, 2004 and approved by EPA on September 29, 2006 (71 FR 57428). New Source Review Programs The Federal New Source Review (NSR) programs are p reconstruction review and permitting programs applicable to new or modified major stationary sources subject to Title I , Parts C and D of the CAA. The programs consist of the Prevention of Significant Deterioration (PSD) requirements applicable in areas attaining the NAAQS, and the nonattainment NSR requirements applicable in geographic areas not attaining and maintaining the NAAQS. PADEP’s PSD regulations (25 Pa. Code Chapter 127, Subchapter D, were approved by EPA on August 21, 1984 (49 FR 33128) codifi ed at 40 CFR 52.2058. The Federal PSD regulations codified in 40 CFR 52 are incorporated by reference in 25 Pa. Code 127.83. The PSD program requires any

new source to implement best available control technology (BACT) and limits new source’s allowable i mpact on the environment. Federal Standards for Hazardous Air Pollutants Federal standards to control hazardous air pollutants (HAPs) require maximum available control technology

(MACT) at units located at major sources of HAPs. EPA has issued a series of regulations that are applicable to sources in Pennsy lvania. These MACT standards are adopted and incorporated by reference in Section 6.6 of the Pennsylvania’s Air Pollution Control Act, implementing regulations and also included as Federally enforceab le permits issued by PADEP for affected sources.21

Source Surveillance PADEP’s rules and regulations for stationary sources, which are part of the control strategy for attaining the PM 2.5 NAAQS, as well as PADEP’s comprehensive permitting program requirem ents in 25 Pa. Code Chapter 127 and Pennsylvania’s SI P in 40 CFR 52.2020 , meet the requirements of 40 CFR Part 51, subpart K (relating to source surveillance). Pursuant to 40 CFR Part 51, subpart K, a SI P revision is required to provide for monitoring the status of compliance with rules and regulations set forth any portion of the control strategy . These include provisions, as applicable for: (1) emission reports and recordkeeping for stationary sources; (2) periodic testing and inspection of stationary s ources; (3) enforcement and complaint investigation of visible emission limitations; (4) enforceable test methods for emission limits; and (5) continuous emission monitoring for stationary sources. **b. HIGHWAY VEHICLES**  Even with increases in vehicles miles traveled (VMT) that occur from 2002 through 2009. Highway

vehicle emissions will continue to decrease. As more vehicles subject to cleaner new car standards replace older vehicles subject to less stringent new vehicle standards, the fleet as a whole emit f

ewer emissions, compensating for the increase in VMT. These decreases are attributed to the programs described below. Federal Motor Vehicle Control Programs and Pennsylvania Clean Vehicle Program for P assenger V ehicles and L ight

- D uty T rucks and C leaner G a soline Tier 1 tailpipe standards established by the CAA include NOx and VOC limits for light

duty gasoline vehicles (LDGVs) and light

- duty gasoline trucks (LDGTs). These standards began to be phased in 1994. Evaporative VOC emissions were reduced in gas oline

- powered cars starting with Model Year (MY) 1998. In1998, under the authority of section 177 of the CAA, PADEP adopted the Pennsylvania Clean Vehicles Program (28 Pa. B. 5873, Dec. 5, 1998). The Pennsylvania Clean Vehicles Program incorporates by r eference certain California Low Emission Vehicle (CA LEV) emission standards for passenger cars and light

- duty trucks. As required under Section 177 of the CAA, these provisions are identical to the low emission standards adopted by California. The regul ation does not incorporate by reference the California zero emissions vehicle (ZEV) or emissions control warranty sy stems statement provisions. PADEP adopted the National L ow Emission Vehicle (NL EV) program as a compliance alternative to the Pennsylvania Clean Vehicles Program. The NLEV program became effective in the Ozone Transport Region (OTR) in 1999. Pennsylvania’s New Motor Vehicle Emissions Control Program regulations in 25 Pa. Code Sections 126.401

- 126.441 allowed automobile manufacturers to comp ly

with NL EV instead of the CA L EV program through MY 2005. These regulations affected vehicles 6,000 pounds and less and were the regulations in effect for new22

motor vehicles in the baseline y ear, 2002. In1999, EPA promulgated regulations more string ent than NL EV (Tier 2), starting with MY 2004. I n order to participate in NL EV, Pennsylvania had been required to adopt language that extended its “commitment” to NL EV until MY 2006. I n practical terms, the NL EV program was replaced for MY 2004 and later by the more stringent Federal “Tier 2” vehicle emissions regulations, 65 FR 6698 (Feb. 10, 2000), and vehicle manufacturers operating under the NLEV program became subject to the Tier 2 requirements. Pennsylvania amended the former New Motor Vehicle Control Program (which included the Pennsylvania Clean Vehicles Program) in 2006. The Clean Vehicles Program continues to incorporate the California L ow Emission Vehicle Program (CA L EV I I) by reference. As amended, the program affects MY 2008 and newer passenger cars and light

- duty trucks vehicles. 36 Pa. B . 7424 (Dec. 9, 2006). Emissions for milestone y ears were estimated based on compliance with the Pennsylvania Clean Vehicles Program according to the methodology described in section 7.4.1 of the “ Technical Guidance on the Use of MOBI LE6.2 for Emissions Inventory Preparation ,” published by

the EPA’s OTAQ in January 2002. This methodology is further explained in Appendix E of Pennsylvania’s attainment plan

. PADEP’ s MOBI LE modeling of the F ederal T ier 2 program applies to subject vehicles sold in Pennsylvania from MY 2004 through MY 2007 and the Pennsylvania Clean Vehicles Program applies to subject vehicles sold in MY 2008 and bey ond. Reformulated gasoline Gasoline sold in the Philadelphia area is required by the CAA to be the cleaner

- burning reformulated gasoline meeting standards established in s ection 211 of the CAA. This federally

enforced program has been in place since January 1995. Heavy

- D uty

Diesel Control Programs E PA pro mulgated more stringent national regulations for heavy

- duty engines and vehicles (over 14,000 pounds) starting with MY 2004. In addition, consent decrees with seven of the largest heavy

- duty

engine manufacturers required, among other terms, that diesel en gines made by these companies comply with these 2004 standards two model y ears early , in MY 2002. Pennsylvania includes these programs as provided in the MOBI LE model. Vehicle Emission Inspection/Maintenance Program The Philadelphia area has had a ve hicle emissions inspection program since 1984. In early 2004, Pennsy lvania revised the implementation of its Vehicle Emission In spection/Maintenance (I /M) Program in the five

- county Philadelphia area. The program23

applies to gasoline

- powered vehicles 9,00 0 pounds and under, MY 1975 and newer. For vehicles MY 1996 and newer, the program consists of an annual on

- board diagnostics test and a gas cap pressure test. For subject vehicles MY 1995 and older, the program consists of an annual tailpipe test, visua l inspection of pollution control devices to ensure they are present, connected and the proper ty pe for the vehicle and a gas cap pressure test. For vehicles older than 25 years, the program is a visual inspection and gas cap test. These regulations can b e found in 67 Pa. Code Chapter 177. Pennsylvania submitted the revised emissions program as a SI P revision on December 1, 2003 which EPA approved on October 6, 2005 (70 FR 58313). Lo w sulfur gasoline Simultaneously

with the Tier 2 program, EPA publish ed a regulation requiring the reduction of sulfur in gasoline beginning in 2004, with full implementation in 2006. Sulfur levels are capped at 80 ppm per gallon and annual refinery averages must be no more than 30 ppm. The emission reduction analy sis use s the default assumptions provided in MOBI LE6 to account for the implementation of the Federal sulfur standard rule. Diesel Vehicle I dling Restrictions On October 9, 2008, Governor Rendell signed the Diesel

- Powered Commercial Motor Vehicle I dling Act (Act 124 of 2008). Act 124 of 2008 went into effect on February 6, 2009. This Act restricts subject drivers and owners statewide from idling a diesel

- powered motor vehicle engaged in commerce with a gross vehicle weight of 10,001 pounds or more for more than five minutes in any

continuous 60

- minute period. Also, no owner or operator of a location where the aforementioned vehicles load, unload or park may allow the vehicles to idle for more than 5 minutes in a 60

- minute continuous period.

**c. NONROAD SOURC**  **ES** EPA adopted a series of regulations affecting new diesel

- powered (“compression ignition”) and gasoline

- powered (“spark ignition”) nonroad engines of various sizes (horsepower) and applications. Information on these Federal rules, including their imple mentation dates, can be found at www.epa.gov/nonroad. PADEP used the assumptions built into the nonroad model (NONROAD2005) to estimate emissions for all milestone years. EPA will also require diesel fuel used in most nonroad applications to contain le ss sulfur. The sulfur will prevent damage to the more advanced emission control sy stems needed to meet the engine standards; it will also reduce fine particulate emissions from diesel engines. I n 2007, fuel sulfur levels were limited to 500 parts per mil lion ( ppm ) for nonroad applications other than ocean - going marine vessels. In 2010, fuel sulfur levels will be reduced to the same sulfur concentration as in highway fuel, 15 ppm; this requirement applies in 2012 to locomotive and marine diesel fuel

.24

**d. VOC**  **SOURCES** Although VOC is not a regulated PM 2.5 precursor for the Philadelphia area, VOC control measures approved by

EPA were included in the modeling associated with this attainment plan: portable fuel containers (December 8, 2004, 69 FR 70893) ; consume r products (December 8, 2004, 69 FR 70895) ; and architectural and industrial maintenance (AI M) coatings (November 23, 2004, 69 FR 69080).

**4 . RACM/RACT Demonstration and Control Strategy**  Pennsy lvania’s evaluation of RACM/RACT control measures for the Pe nnsylvania portion of the Philadelphia area is approvable. As noted above, the most current monitoring data for this area indicates that it is attaining the 1997 PM 2.5 NAAQS. EPA’s guidance for the PM 2.5 Implementation Rule recommended that if an area wa s predicted through the attainment plan to attain the standards within five y ears after designation, then the State could submit a more limited RACM/RACT analy sis and the State could elect not to do additional modeling. Inlight of the fact that the Pen nsylvania portion of the Philadelphia area is now attaining the standards, the attainment plan meets the RACM/RACT requirements of the PM 2.5 Implementation Rule, and that the level of control in the State’s attainment plan constitutes RACM/RACT for purpose s of the 1997 PM 2.5 NAAQS. Because the PM 2.5 Implementation Rule defines RACM/RACT as that level of control that is necessary to bring the area into at tainment, the current level of F ederally enforceable controls on sources located within the Philadelphia area is by definition RACM/RACT for this area for this purpose.

**V I**  **. Contingency Measures**  Inaccordance with Section 172(c)(9) of the CAA, the PM 2.5 I mplementation R ule requires that PM 2.5 attainment plans include contingency measures. These measure s must be fully adopted and should contain trigger mechanisms and an implementation schedule. I n addition, they

should be measures not already included in the SI P control strategy and should provide for emission reductions equivalent to one y ear of RFP. C ontingency measures are implemented if RFP targets are not achieved, or if attainment is not realized by the attainment date. Where an area has already achieved attainment by

the attainment date, it has no need to rely on contingency

measures to come int o attainment or to make further progress to attainment. However, in accordance with section 110(k)(2) of the CAA, EPA must take action on the contingency

measure s that were submitted by Pennsylvania. The PM 2.5 Implementation Rule requires that quantity o f emission reductions needed to satisfy contingency

requirements is an amount equal to one’s y ear worth of required reductions. Required reductions are the amount of reductions needed to attain compliance with the PM 2.525

NAAQS . By

2009, emissions of SO 2 and NOx in the Pennsy lvania portion of the Philadelphia area are projected to decrease by 12,259 tons and 28597 tons, respectively . Based on modeling of the projected 2009 emissions, the Philadelphia area is predicted to have a design value of 13.5  g/m 3 , which is lower than the 15  g/m 3 required for the attainment of the PM 2.5 NAAQS. Calculations were made to estimate the portion of the emission reduction that is necessary to reach the attainment concentration of 15  g/m 3 and the portion of the emission reduction that reduces the design value below 15  g/m 3 and is therefore, excess. Table 5 display s the 2002 actual and 2009 modeled design values and the 2002 actual and 2009 projected emissions of SO 2 and NOx. **Table 5 . Design Value and Emissions Expecte**  **d by 2009** Philadelphia area Design Value (  g/m 3 ) SO 2 (tons/y ear) NOx (tons/y ear) 2002 16.6 40459 120348 2009 (Modeled/Projected) 13.5 28200 91651 Change from 2002

- 2009 3.1 12259 28597

Table 6 shows that for each pollutant, the change in polluta nt emissions was divided by the change in design value to yield the value reduction rate. Then, the change in design value necessary to attain the standard (16.6  g/m 3

– 15  g/m 3 = 1.6  g/m 3 ) was multiplied by the design value reduction rate to estimate the target emissions reduction. This represents the portion of emission reduction necessary to attain the standard. The rest of the emissions reduction is bey ond what is necessary for attainment and is therefore, considered to be “excess” reduction. **Tabl e 6**  **. Calculation of Required and Excess Emissions Reductions** Philadelphia area Design Value (  g/m 3 ) SO 2 (tons/y ear) NOx (tons/y ear) Change from 2002

- 2009 3.1 12259 28597 Design Value Reduction Rate (tons/  g/m 3 ) 3955 9225 Target Reductions for Attainment 1.6 6327 14760 Calculated Excess Reductions 1.5 5932 13837 The contingency

requirement i s calculated by dividing the target emissions reduction by seven, which is the number of y ears b etween 2002 and 2009. Table 7 shows the calculation of the contingency

requirement reduction and demonstrates that the calculated excess reduction exceeds the amount of reduction necessary for the contingency

plan.

**Table 7 . Calculation of Required Contingency Plan Reductions** 26 Philadelphia area SO 2 (tons/y ear) NOx (tons/y ear) Target Reductions for Attainment 6327 14760 Calculated Excess Reductions 5932 1383 7 Contingency

Requirement 904 2109 Excess Reductions Satisfy Contingency Requirement Yes Yes

The attainment plan for the Pennsylvania portion of the Philadelphia area includes contingency

measures to be implemented if the area fails to attain by i ts attainment date. The following describes the specific control measures that are anticipated to be in place in order to bring the area back into attainment should a violation occur. The Diesel

- Powered Commercial Motor Vehicle I dling Act (Act 124) wen t into effect on February 6, 2009. PADEP estimates 50 percent of all long duration idling for Class 8 trucks will be eliminated in 2010 when the temperature exemption for sleeper truck rest expires. Statewide emission reductions are estimated to be 1610 tons, 45 tons and 30 tons per y ear for NOx, VOC and PM 2.5 , respectively . PADEP will also utilize enhanced enforcement to obtain additional emission reductions. Significant additional reductions in NOx, direct PM 2.5 and SO 2 emissions will occur in emissio ns from highway

and nonmobile sources after 2009. In addition, NOx controls for cement kilns and glass furnaces were approved by EPA on July

19, 2011 (76 FR 42258) and August 22, 2011 (76 FR 52283), respectively . Furthermore, PM 2.5 control from the operation of outdoor wood

- fired boilers was approved by EPA on September 20, 2011 (76 FR 58114). Sulfur limits for fuel oil (home heating oil and residential oil) are anticipated to be adopted later. Regulations to reduce VOC emissions are also in development , including controls on the manufacture and use of adhesives, primers and sealants and regulations incorporating the Control Technique Guidelines issued by EPA in 2006, 2007 and 2008. As required, these measures were fully adopted rules or control mea sures that were ready to be implemented quickly upon failure of the area to attain, were in addition to those measures otherwise relied upon for attainment , had trigger mechanisms and a schedule for implementation, and were at the level of reductions equal to at least one y ear’s worth of reductions needed for attainment in the area. EPA finds that the measures submitted by Pennsylvania have satisfied the requirements for contingency purposes. EPA’s General Preamble interprets the control measure requir ements of sections 172(c)(9) and 182(c)(9) to allow states to implement measures before they are triggered (57 FR 13498, 13511). EPA has previously approved a number of SI Ps under this interpretation (66 FR 15844, April 3, 1997; 62 FR 66279, December 18, 1 997; 66 FR 30811, June 8, 2001; 66 FR 586, and 66 FR 634, January

3, 2001) and the Fifth Circuit has upheld EPA’s interpretation. Louisiana Environmental Action Network v. EPA , 382 F.3d 575 (Fifth Cir. 2004). I t does not27

matter whether or not a specific contingency measure is already

required by

law, as long as the emissions reductions that will result from the contingency measure have not been relied upon in the attainment demonstration. The contingency

measures in Pennsylvania’s attainment demonstratio n (described above) that are already

implemented and provide reductions in excess of those required by the attainment demonstration to attain the standards. The level of reductions provided is equal to at least one y ear’s worth of reductions needed for at tainment in the Pennsy lvania portion of the Philadelphia area

. One y ear’s worth of reductions needed for attainment is determined by dividing the emissions from base y ear levels that are needed for attainment by the number of ye ars between the base y ear and the attainment y ear. ( See PM 2.5 Implementation Rule , page 20643). Contingency

measures are imp lemented in the event that the Philadelphia a rea fails to attain the standards by

its attainment date. Although the Philadelphia area , as ind ic ated above, me t their attainment date of April 5, 2010 and thus is not required to implement contingency measures , by

relying on those measures that were already in place, Pennsylvania effectively implemented their control measures in advance.

**VI II**  **. Motor Vehicle**  **Emission Budgets** The CAA requires Federal actions in nonattainment and maintenance areas to “conform to” the g oals of SI Ps. This means that such actions will not: (a) c ause or contribute to violations of a NAAQS; (b) worsen the severity of an existing violation ; or (c) delay timely attainment of any NAAQS. Actions involving Federal Highway Administration (FHWA) or Federal Transit A dministration (FTA) funding or approval are subject to the transportation conformity rule (40 CFR part 93, subpart A). Und er this rule, metropolitan p lanning organizations (MPOs) in nonattainment and maintenance areas coordinate with S tate A ir Q uality and T ransportation A gencies, EPA, and the FHWA and FTA to demonstrate t hat their long range transportation plans ( “plans”) and transportation improvement programs (T IP ) conform to applicable SI Ps. This is ty pically determined by

showing that estimated emissions from existing and planned highway and transit projects are less than or equal to the MVEBs contained in the SI P. Secti on 176 (c) of t he CAA requires Federal actions in nonattainment and maintenance areas to “conform to” the goals of SI Ps. This me ans that such actions will not: cause or contr ibute to violations of a NAAQS, worsen the se verity of an existing violation, or delay timely attainment of any

NAAQS. Actions involving Federal Highway Administration (FHWA) or Federal Transit Administration (FTA) funding or approval are subject to the transportation conformity

r ule (40 CFR part 93, subpart A). Under this rule, metr opolitan planning o rganizations (MPOs) in nonattainment and mai ntenance areas coordinate with S tate A ir Q uality and T ransportation A gencies, EPA, and the FHWA and FTA to demonstrate that their long range transportation plans (“plans”) and transportation improvement programs (TI P) conform to applicable SI Ps. This is ty pically determined by

showing that estimated emissions from existing and planned highway

and transit projects are less than or equal to the MVEBs contained in the28

SI P. The MVEBs for the 2009 attainment y ear are based on the projected 2009 on

- road motor vehicle source emissions, accounting for the emission reductions from on

- road vehicle sourc e control measures , including transportation control measures and vehicle technology , fuel or maintenan ce - based measures. MVEBs for 2009 attainment y ear for the Pennsylvania portion of the Philadelphia area are 699 tons per ye ar for PM 2.5 - direct and 36,318 tons per ye ar for NOx as shown in Table 8. More detailed information can be found in the TSD entitle d, “Adequacy Findings for Motor Vehicle Emissions Budgets in the Attainment Demonstration for the Pennsylvania Portion of the Philadelphia

- Wilmington

- New Jersey City PM 2.5 NAAQS Nonattainment Area, ” dated October 6, 2011. **Table 8. Motor Vehicle Emission Budgets**  2009 PM 2.5 NOx Tons per y ear 699 36318 For MVEBs to be approvable, they must meet, at a minimum, EPA’s adequacy criteria (40 CFR 93.118(e)(4)). The MVEBs for the Pennsylvania portion of the Philadelphia area PM 2.5 attainment plan are being pos ted to EPA’s conformity w ebsite concurrently with the notice of proposed rulemaking (NPR) . The public comment period will end at the same time as the public comment period for the NPR . I n this case, EPA is concurrently processing the action on the attain ment plan and the adequacy process for the MVEBs contained therein. In t he NPR , EPA is proposing to find the MVEBs adequate, and also proposing to approve the MVEBs as part of the attainment plan. The MVEBs cannot be used for transportation conformity until the attainment plan and associated MVEBs are approved in a final Federal Register notice, or EPA otherwise finds the budgets adequate in a separate action following the comment period. Our action on the Pennsylvania portion of the Philadelphia are a MVEBs will also be announced on EPA’s conformity

website: http://www.epa.gov/otaq/stateresources/transconf/index.htm , (once there, click on “Adequacy

Review of SI P Submissions). The budgets that Pennsylvania submitted were calculated using the MOBI LE6.2 motor vehicle emissions model. EPA is proposing to approve the inventory and the conformity

budgets calculated using this model because this model was the most current model ava ilable at the time Pennsylvania was performi ng its analy sis. Separate from the NPR , EPA has issued an updated motor vehicle emissions model known as the Motor Vehicle Emission Simulator or MOVES. In its announcement of this model, EPA established a grace period for continued use of MOBI LE6.2 in transportation conformity determinations for transportation plans and TI Ps, after which states and MPOs (other than California) must use MOVES for transportation plan and TI P conformity

determinations. This grace period will expire in March 2012 ( or March 2013 once the extension becomes official ). Additional information on the use of MOVES in SI Ps and conformity determinations can29

be found in the December 2009 , “ Policy Guidance on the Use of MOVES2010 for State I mplementation Plan Development, Transportation Conformity , and Other Purposes

. ” This guidance document is available at: http://www.epa.gov/otaq/models/moves/420b09046.pdf

. During the confo rmity

grace period, the State and MPO(s) should use the interagency consultation process to examine how MOVES2010a will impact their future transportation plan and TI P conformity

determinations, including regional emissions analy ses. For example, an incre ase in emission estimates due to the use of MOVES2010a may affect an area’s ability

to demonstrate conformity

for its transportation plan and/or TI P. Therefore, state and local planners should carefully

consider whether the SI P and motor vehicle emissions budget(s) should be revised with MOVES2010a or if transportation plans and TI Ps should be revised before the end of the conformity

grace period, since doing so may be necessary

to ensure conformity determinations in the future. We would expect that state s and MPOs would work closely with EPA and the local FHWA and FTA offices to determine an appropriate course of action to address this ty pe of situation if it is expected to occur. I f Pennsylvania chooses to revise its PM 2.5 attainment plan , it should con sult Question 7 of the December 2009 , “ Policy Guidance on the Use of MOVES2010 for State I mplementation Plan Development, Transportation Conformity , and Other Purposes ,” for information on requirements related to such revisions.

**D .**  **SUMMARY AND RECOMMEN DATIONS**  **:** The PM 2.5 attainment plan for the Pennsy lvania portion of the Philadelphia area meets the requirements of the CAA as described in the Clean Air Fine Particle Implementation Rule (April 25, 2007, 72 FR 20586). The attainment plan supports a deter mination that the Pennsylvania portion of the Philadelphi a area attains the 1997 annual PM 2.5 NAAQS

. The attainment plan includes an attainment demonstration, MVEBs used for transportation conformity purposes, RACM /RACT analy sis, contingency measures, and the 2002 base y ear emission inventor ies

. Therefore, we recommend approval of the PM 2.5 attainment plan for the Pennsylvania portion of the Philadelphia area.