Technical Support Document (TSD) For the 

2011 Base Year Inventory 

For Areas of Marginal Nonattainment of the 

2008 Ozone NAAQS in Pennsylvania 

Submitted September 2015 by the 

Pennsylvania Department ofEnvironmenta1 Protection 

TSD Prepared January 2016 by 

Jessica L. Fry 

Office of Air Monitoring and Analysis, 3AP40 

U.S. Environmental Protection Agency, Region 3 

1650 Arch Street 

Philadelphia, Pennsylvania 191 03 

Reviewed by Alice H. Chow, Associate Director 

Office of Air Monitoring and Analysis (3AP40) 
I. Introduction 

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

Air Monitoring and Analysis (OAMA) review of the 2011 Base Year Inventory 

submitted for areas of marginal nonattainment ofthe 2008 Ozone NAAQS in 

Pennsylvania (PA), submitted by the Pennsylvania Department ofEnvironmental 

Protection (PADEP). There are five marginal nonattainment areas (NAAs) for the 2008 

Ozone NAAQS in Pennsylvania. EPA designated the NAAs as marginal for the 2008 

Ozone NAAQS effective July 20, 2012. This requires the area to submit a comprehensive 

base year inventory no later than 24 months from the July 20, 2012 effective date and 

every three years thereafter. A SIP Base Year Inventory is the starting point from which 

other SIP inventories are derived as well as serving as the benchmark for other SIP 

planning activities, such as the establishment of an emissions reduction credit program. 

Under the Clean Air Act (CAA) sections 172(c)(3) and 182(a)(l), states are required to 

submit emissions inventory information for all relevant sources for the areas that are 

designated nonattainment. PADEP has submitted a 2011 Base Year Inventory for the 

five Pennsylvania NAAs in order to fulfill the CAA requirements. Any questions 

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

Director, Office of Air Monitoring and Analysis, at 215-814-2144 or via email at 

chow .alice@epa.gov. 

II 2011 Base Year Inventory 

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

current accounting of actual emissions from all sources (point, non point, nonroad, and 

onroad) in the nonattainment area. The CAA section 182(a)(1) requires that areas 

designated as nonattainment and classified as marginal are to submit an inventory of all 

sources of ozone precursors no later than 2 years after the effective date of designation. 

This inventory contains actual annual emissions and typical ozone season day emissions 

for the ozone season of May through September for the ozone precursors, NOx, CO, and 

VOC. The base year inventory includes emissions estimates from stationary point and 

nonpoint sources, onroad mobile sources, and nonroad mobile sources. Below is a list of 

the five NAAs that are designated as marginal for the 2008 Ozone NAAQS: 

• Allentown-Bethlehem-Easton, P A 

o Carbon County 

o Lehigh County 

o Northampton County 

• Lancaster, P A 

o Lancaster County 

• Philadelphia-Wilmington-Atlantic City, PA-NJ-MD-DE 

o Bucks County · 

o Chester County 

o Delaware County 

o Montgomery County 

o Philadelphia County 
• Pittsburgh-Beaver Valley, PA 

o Allegheny County 

o Armstrong County 

o Beaver County 

o Butler County 

o Fayette County 

o Washington County 

o Westmoreland County 

• Reading, P A 

o Berks County 

P ADEP submitted a 2011 base year inventory for all source categories in the 

NAA. EPA guidance for emissions inventory development provides that actual 

emissions should be used for purposes ofthe base year inventory. PADEP used 

emissions from EPA's 2011 NEI v2 for the 2011 base year inventory for point, nonpoint, 

and nomoad sources. Documentation for the 2011 NEI can be found at 

http://www.epa.gov/ttn!chief/net/2011 inventory.html. In order to get summer day 

emission averages, P ADEP used the Emissions Modeling Framework (EMF) and 

imported Sparse Matrix Operator Kernel (SMOKE) files that were downloaded from the 

Emissions Inventory System (EIS) Gateway. 

Omoad emissions were prepared for P ADEP by Michael Baker, Jr., Inc. The 

analysis was completed by running EPA's highway mobile source emissions model 

MOVES 2010b using local and default data. Local data for 2011 was obtained from 

Pennsylvania Department of Transportation (PennDOT), the Bureau of Motor Vehicles, 

and other local sources. 

OAMA staff reviewed the results, procedures, and methodologies for the SIP base 

year, and found them to be acceptable.