### Pennsylvania Department. of**Envi~on~enta~** 

### Protection

Rachel Carson State Office Building

P.O. Box 2063 Harrisburg, PA 17105-2063

November 10, 2009

Secretary

William C. Early Acting Regional Administrator

U.S. Environmental Protection Agency, Region III

1650 Arch Street (Mail Code: 3RAOO) Philadelphia, PA 19103-2029

Dear Mr. Early: 717-787-2814

In accordance with Section 172 of the Clean Air Act, 42 U.S.C. § 7502, I am pleased to

submit the attainment demonstration and base year inventory for the Pittsburgh-Beaver Valley

fine particulate (PM2.5) nonattainment area (Pittsburgh-Beaver Valley Area) for approval as a revision to Permsylvania's State Implementation Plan (SIP). The Pittsburgh-Beaver Valley Area

consists of Beaver, Butler, Washington, and Westmoreland counties and portions of Allegheny, Armstrong, Greene and Lawrence counties. This SIP revision, which is based, in part, on photochemical grid modeling, air quality trends, and emission trends, demonstrates how the

Commonwealth will attain the health-based PM 2 .5 National Ambient Air Quality Standard (NAAQS) by April 2010. The public participation process for this SIP revision included a public hearing in Pittsburgh on October 6, 2009, and a 30-day written comment period, which closed on October 9, 2009.

I have enclosed two hard copies and one compact disk of the SIP revision for the Pittsburgh-Beaver Valley Area PM2.5 nonattainment area. This submittal includes the following: (l) attainment demonstration and base year inventory (including the mobile emissions budget for

purposes of transportation conformity); (2) certification of public participation activities; (3)

technical appendices (appendices consisting of data files are provided in electronic form only);

and (4) comment and response document. In addition, the SIP submittal includes an analysis of

reasonable further progress, the base year 2002 emissions inventory, analysis of reasonably

available control measures, a description of contingency measures that will be implemented to bring the area back into attainment should violations ofthe NAAQS occur after the standard is
attained, and mobile source emission budgets for purposes of transportation conformity.

Thank you in advance for the expeditious review and processing of this SIP submittal.

Please contact Joyce E. Epps, Director, Bureau of Air Quality, bye-mail atjeepps@state.pa.us or by telephone at 717-787-9702, if you have questions or need additional information.

Enclosures

An Equal Opportunity Employer

# Since~f\.**~~e.-**

John Hanger Secretary

www.dep.state.pa.us Printed on Recycled paper@

# Commonwealth of Pennsylvania



# S TATE 

# I MPLEMENTATION 

# P LAN 

# R EVISION 

# :

A TTAINMENT 

# D EMONSTRATION AND 

# B ASE



# Y EAR 

# I NVENTORY



# P ITTSBURGH



# - B EAVER 

# V ALLEY



# F INE 

# P ARTICULATE 

# N ONATTAINMENT 

# A REA

NOVEMBER 

# 2009

Bureau of Air Quality Pennsylvania Department of Environmental Protection

P.O. Box 8468 Harrisburg, PA 17105

- 8468

717

- 787

- 9495

www.depweb.state.pa.us

John Hanger Secretary Edward G. Rendell

Governorblank for two -sided copyingTable of Contents

Executive Summary

................................ ................................ ................................ ............. i

I. INTRODUCTION AND OVERVIEW

................................ ................................ .......... 1 A. Health and Environmental Effects of Fine Particulate Matter ( PM 2.5 )

.............. 1

B. Sources of PM 2.5 and Implications for Reduction

................................ ................. 1 C. Purpose and Structure of this Document

................................ ............................... 4

D. Public Par ticipation

................................ ................................ ................................ . 5

II. NATURE OF THE PROBLE M IN THE PITTSBURGH

- BEAVER VALLEY AREA

................................ ................................ ................................ ................................ ............. 7 A. Background

................................ ................................ ................................ .............. 7 B. Air Quality Monitoring Trends Analysis

................................ .............................. 8 1. Design Value Trend

................................ ................................ ............................... 8

2. NO 2 Monitoring Trend

................................ ................................ ......................... 10

3. SO 2 Monitoring Trend

................................ ................................ ......................... 11 C. Seasonal Variability

................................ ................................ .............................. 11

1. FRM Monitoring Trends

................................ ................................ ...................... 11 2. Speciation Monitoring Trends

................................ ................................ ............. 11

III. EMISSION INVENTORIES

................................ ................................ ..................... 13 A. Summary of 2002 Emissions

................................ ................................ ................ 14 B. Summary of Inventory Methodologies

................................ ................................ 15 C. Projected Inventories

................................ ................................ ............................ 18 1. Summary of 2009 Estimated Emissions

................................ .............................. 1 8 2. Growth Projection Methodologies

................................ ................................ ....... 18 D. Reasonable Further Progress (RFP) Requirements

................................ .......... 21

E. Motor Vehicle Emission Budgets for Transportation Conformity

................... 22

IV. CONTROL STRATEGIES

................................ ................................ ....................... 25

A. Permanent and Enforceable Control Measures

................................ ................. 25 1. Stationary Point Sources

................................ ................................ ...................... 25 2. Highway Vehicle Sources

................................ ................................ .................... 27

3. Nonroad Sources

................................ ................................ ................................ .. 30 B. Reasonably Av ailable Control Measures/Reasonably Available Control Technology Analysis

................................ ................................ ................................ ... 31

C. Other Measures

- VOC Control Measures

................................ ......................... 33

V. AT TAINMENT DEMONSTRATI ON AND WEIGHT OF EVI DENCE (WOE)

..... 34 A. Attainment Demonstration Background and Objectives

................................ .. 34 B. Pittsburgh

- Beaver Valley Area Conceptual Model Description

....................... 35 C. Modeling Domain and Photochemical Modeling System

................................ .. 37

D. Model Performanc e Evaluation

................................ ................................ ........... 39 1. Daily PM 2.5 Mass

................................ ................................ ................................ . 39

2. PM 2.5 Speciation

................................ ................................ ................................ ... 41 E. Projected 2009 Design Values for the Pittsburgh

– Beaver Valley

Nonattainment Area

................................ ................................ ................................ ... 43

1. Overview

................................ ................................ ................................ ............... 43

2. Modeled Attainment T est

................................ ................................ .................... 43 3. Determine Baseline Design Values

................................ ................................ ..... 44 4. Relative Response Factor Calculations

................................ ................................ 46

5. Annual SMAT Results

................................ ................................ ......................... 47

6. 24

- Hour SMAT Results

................................ ................................ ....................... 49F. Unmonitored Area Analysis

................................ ................................ ............... 50

G. Local Area Analysis

................................ ................................ .............................. 51 H. Weight of Evidence and Other Documentation Supporting Attainment

........ 53

I. Conclusions

................................ ................................ ................................ ............. 58

VI. CONTINGENCY MEASURES FOR THE ATTAINMENT DEMONSTRATION 59 A. Contingency Measure R equirement

................................ ................................ .... 59 B. Identified Contingency Measures

................................ ................................ ........ 60

ACRONYMS AND ABBREVIATIONS

................................ ................................ ......... 65

Table of Ta bles

Table E

- 1: Summary of Pittsburgh

- Beaver Valley Area Direct PM 2.5 and Precursor

Emissions

................................ ................................ ................................ .................. iii

Table II

- 1: Pittsburgh

- Beaver Valley Area Annual PM 2.5 Average and Design Value Trend (ug/m3)

................................ ................................ ................................ ............ 8

Table III

- 1: 2002 Annual Emissions (Tons per Year)

................................ ................ 15

Table III

- 2: 2009 Projected Emissions (Tons per Year)

................................ ............. 18

Table III

- 3: Regional Nonattainment Area VMT and Emissions

............................ 21

Table III

- 4 Comparison of 2009 On

- Road Mobile Precursor Emissions to the Total Projected 2009 Inventory

................................ ................................ ....................... 23

Table III

- 5: Motor Vehicle Emission Budgets

................................ ............................. 23

Table IV

- 1: Summary of Emission Reductions 2002

- 2009 from Control Measures 25

Table V

- 1: Annual PM 2.5 Quarterly RRF Values

................................ ........................ 48

Table V

- 2: Annual SMAT Results for the Pittsburgh

- Beaver Valley Area 2009 On

The

- Books

- On

- The

- Way Control Measures

................................ ........................ 48

Table V

- 3: 24

- hour PM 2.5 Quarterly RRF Values

................................ ....................... 49

Table V

- 4: 24

- hour SMAT Results for the Pittsburgh

- Beaver Valley Area 2009 On

The

- Books

- On

- The

- Way Control Measures

................................ ........................ 50

Table V

- 5: Summary o f Large PM 2.5 Sources near the North Braddock Monitor

... 52

Table V

- 6: Summary of PM 2.5 Weight of Evidence Guidelines (EPA Guidance)

..... 54

Table VI

- 1: Changes in Design Value and Emissions Expected by 2009

.................. 59

Table VI

- 2: Calculation of Required and Excess Emissions Reductions

................. 60

Table VI

- 3: Calculation of Required Contingency Plan Reductions

........................ 60

Table of Figures

Figure E

- 1: Map of Southwestern Pennsylvania PM 2.5 Nonattainment Areas

.......... ii Figure 1: Pittsburgh

- Beaver Valley Area Monitor Trend

................................ ........... 9 Figure 2: NO 2 Monitoring Trend

................................ ................................ ................. 10 Figure 3: SO 2 Monitoring Trend

................................ ................................ .................. 11 Figure 4: Pennsylvania’s PM 2.5 Nonattainment Areas

................................ ............... 35 Figure 5: Pittsburgh

- Beaver Valley Area Percentage of Total Mass

........................ 37 Figure 6. OTC Modeling Study Domain

................................ ................................ ...... 38 Figure 7: Mean Fractional Error

................................ ................................ ................. 40 Figure 8: Mean Fractional Bias

................................ ................................ .................... 41 Figure 9: Time Series of SO 4 Mass

................................ ................................ ............... 42 Figure 10. Wind Rose: North Braddock Monitoring Location (1998

- 2000)

............ 53 Figure 11: Pittsburgh

- Beaver Valley Area PM 2.5 Trends

................................ .......... 57APPENDICES

APPENDIX A: A IR Q UALITY M ONITORING I NFORMATION

A

- 1 United States Environmental Protection Agency Air Quality System Quick L ook: Pennsylvania (1999

- 2008)

A

- 2 United States Environmental Protection Agency Air Quality System: Quart erly PM 2.5 Data (1999

- 2008)

APPENDIX B: S TATIONARY P OINT S OURCES

B

- 1 Methodology

– Preparation of Pennsylvania Point Source Inventories and Instructions for Completing the Annual Emissions Reporting Forms

B

- 2 Facility Annual Emissions

B

- 3 Bank ed Emissions Reduction Credits

APPENDIX C: STATIONARY AREA SOURCES

C

- 1 Pennsylvania 2002 Area Source Criteria Air Pollutant Emission Estimation Methods (EH Pechan, Feb. 2004)

C

- 2 Area Source Annual Emissions

APPENDIX D : EMISSIONS PROJECTIONS

D

- 1 Development of Emission Projections for 2009, 2012, and 2018 for NonEGU Point, Area, and Nonroad Sources in the MANE

- VU Region (MACTEC, Feb. 2007)

D

- 2 Documentation of 2018 Emissions from Electric Generating Units in the Eastern United States for M

ANE

- VU’s Regional Haze Modeling (Alpine Geophysics, April 2008)

D

- 3 Future Year Electricity Generating Sector Emission Inventory Development Using the Integrated Planning Model (IPM®) in Support of Fine Particulate Mass and Visibility Modeling in the VIST

AS and Midwest RPO Regions (ICF, April 2005)

APPENDIX E : H IGHWAY V EHICLE S OURCES I NVENTORY I NFORMATION

E

- 1 Mobile Source Highway Emissions Inventory

– An Explanation of Methodology

E

- 2 Highway Emissions Estimates

E

- 3 MOBILE6.2 Input Parameter Sum mary
E

- 4 MOBILE6.2 Sample Input File (available electronically)

E

- 5 Traffic Growth Forecasting System Report

APPENDIX F: N ONROAD S OURCES

F

- 1 Emissions Estimation Methodology

F

- 2 Nonroad Source Emissions

APPENDIX G : R EASONABLY A VAILABLE C ONTROL M E ASURES

G

- 1 Identification and Evaluation of Candidate Control Measures, Final Technical Support Document ( MACTEC, Feb. 2007)

G

- 2 OTC Initial List of Measures (Appendix B of Candidate Control Measures TSD)

G

- 3 Assessment of Reasonable Progress for Regio nal Haze in MANE

- VU Class I Areas ( MACTEC, July 2007)

APPENDIX H : M ODELING D EMONSTRATION

H

- 1 CMAQ Model Performance and Assessment for Base Year 2002 PM 2 .5 Mass and Speciation (NY DEC, Dec. 2007)

H

- 2 M eteorological Modeling of 2002 U sing Penn State/NCAR 5th Generation Mesoscale Model (MM5) (NY DEC, Mar. 2006)

H

- 3 Processing of 2002 Anthropogenic Emissions: OTC Regional and Urban 12km Base

Year Simulation (NY DEC, Mar. 2007)

H

- 4 PM 2.5 Modeling U

sing the SMOKE/CMAQ System O ver the Ozone Transport Region (OTR) (NY DEC, Feb. 2006)

H

- 5 Processing of 2002 Biogenic Emissions for OTC / MANE

- VU Regional and Urban Modeling (NY DEC, Sep. 2006)

H

- 6 Final Air

- Quality Modeling Protocol for the Annual PM 2.5 NAAQS: Pittsburgh

- Beaver Valley Annual PM 2.5 Nonattainmen t Area (PA DEP, Oct. 2007)

H

- 7 Sample Calculation of P rojected 2009 PM 2.5 Annual and 24

- hour C oncentrationsblank for two -sided copying- i

-

E xecutive Summary

Particulate matter is a mixture of microscopic solids and liquid droplets suspended in air

that includ e : acids (such as nitrates and sulfates), organic chemicals, metals, soil or dust particles and allergens (such as fragments of pollen or mold spores). Fine particle pollution or PM 2.5 describes particulate matter that is less than or equal to 2.5

micro meter s (μm) in diameter, approximately 1/30th the diameter of a human hair.

Health studies have shown a significant association between exposure to fine particles and premature death from heart or lung disease. Fine particles can aggravate heart and lung diseas es and have been linked t o effects such as cardiovascular symptoms

, cardiac arrhythmias

, heart attacks

, respiratory symptoms , asthma attacks, and bronchitis. These effects can result in increased hospital admissions, emergency room visits, absences from

s chool or work, and restricted activity days. Individuals that may be particularly sensitive to fine particle exposure include people with heart or lung disease, older adults, and

children.

The U nited States Environmental Protection Agency (EPA) issued fin e particle (PM 2.5 ) national ambient air quality standards (NAAQS) in 1997 after evaluating hundreds of health studies and conducting an extensive peer review process. The EPA established an

annual primary (health

- based) and secondary (welfare

- based) standa rd of 15.0 microgr ams per cubic meter (μg/m 3 ), based on the 3

- year average of annual mean PM 2.5 concentrations. The EPA also established a primary and secondary 24

- hour standard of 65 μg/m 3 determined by the 3

- year average of the 98th percentile of 24

- hour

concentrations.

On December 17, 2004

, the EPA issued air quality designations for the PM 2.5 standard based on air quality monitoring data from 2001

- 2003. The final designations were published in the Federal Register on January 5, 2005 (70 FR 944). The designations

be came effective on April 5, 2005. On April 5, 2005, the EPA issued a supplemental notice changing the designation of certain areas from nonattainment to attainment based on newly available air quality data (70 FR 19844; published in the Federal Register on April 14, 2005). The EPA designated eight areas in Pennsylvania as PM 2.5 nonattainment

areas , comprising all or part s of 21 Pennsylvania counties

.

The Pittsburgh

- Beaver Valley PM 2.5 Nonattainment Area ( Pittsburgh

- Beaver Valley

Area ) is located in sout hwestern Pennsylvania and consists of Beaver, Butler, Washington, and Westmoreland counties and portions of Allegheny, Armstrong, Greene

and Lawrence counties. The Pittsburgh

- Beaver Valley Area is required to attain the

PM 2.5 NAAQS no later than five year s from the effective date of designation, or April 5,

2010.

As shown in Figure E

- 1, five municipalities near the Clairton Coke Works in Allegheny County are designated as a separate nonattainment area, the Liberty

- Clairton PM 2.5 Nonattainment Area. The Liberty

- Clairton PM 2.5 Nonattainment Area was designated as- ii

-

a separate, distinctively local

- source impacted, nonattainment area because the combination of emissions from the coke plant in a narrow river valley creates a local air quality problem uniquely different from the remainder of the Pittsburgh

- Beaver Valley

Area

. The Liberty

- Clairton PM 2.5 Nonattainment Area was also previously designated as

a PM 10 nonattainment area.

Figure E

- 1: Map of Southwestern Pennsylvania PM 2.5

Nonattainment Areas

T his State Implementation P lan ( SIP ) revision contains information on PM 2.5 trends and

emissions and demonstrates that the Pittsburgh

- Beaver Valley Area meets all requirements necessary for an approvable SIP revision. This SIP revision also establishes

mot or vehicle budgets for purposes of transportation conformity. Once the EPA approves the budgets for purposes of conformity, the Pittsburgh

- Beaver Valley Area’s designated Metropolitan Planning Organization (MPO), the Southwestern Pennsylvania

Commission

, must use these budgets in its air quality analyses for transportation planning

purposes.

PM 2.5 c an be emitted directly or formed secondarily in the atmosphere by chemical reactions of gases in the atmosphere. Potential precursors of secondary PM 2.5 inclu de sulfur dioxide ( SO 2 ), nitrogen oxides (NOx), volatile organic compounds (VOC), and ammonia ( NH 3 ).- iii

-

While emissions of direct PM 2.5 are projected to increase from 2002 to 2009 in the Pittsburgh

- Beaver Valley Area , e missions of the PM 2.5 precursors SO 2 and NOx are projected to decrease over the same time period. The emissions inventory shows this apparent increase in PM 2.5 emissions from stationary sources from 2002 to 2009 because the 2002 inventory was based on emissions reported to the Pennsylvania D epartment of Environmental Protection (DEP or Department ) by facilities and did not include

condensable PM for many facilities. The projected 2009 PM 2.5 emissions for electric generating units (EGUs) include condensable PM emissions which were calculated based

on factors derived from defaults contained in AP 42 Fifth Edition, Compilation of Air

Pollutant Emission Factors.

. The emission projections tak e into account both growth in economic activity that

increases emissions and control measures implemented to reduce emissions. Based on speciated data from the Lawrenceville monitor, sulfate s and nitrate s account for 46 % of

the PM 2.5 mass in the Pittsburgh

- Beaver Valley Area

. Because sulfate s and nitrate s are formed from atmospheric reactions of SO 2 and NOx , t he reduction of emissions of SO 2 and NOx is expected to result in attainment of the PM 2.5 air quality standard in the Pittsburgh

- Beaver Valley Area

.

Table E

- 1: Summary of Pittsburgh

- Beaver Valley Area Direct PM 2.5 and Precursor

Emissions

Pollutant 20 02 2009

PM 2.5 14904 27969

PM 10 54879 69613

SO 2 476871 129074

NOx 198483 111897

VOC 80898 63230

NH 3 5303 6440

The permanent and enforceable control measures that enable the Pittsburgh

- Beaver Valley Area to demonstrate attainment of the PM 2.5 NAAQS include:

The Clean Air Interstate Rule (CAIR) and the NOx “SIP Call” reducing interstate pollution transport ; State regulation of smaller sources of nitrogen oxides, cement kilns and large stationary internal combustion engines ; The Pennsylvania and feder al new motor vehicle emission control programs for passenger and light

- duty trucks ; The Pennsylvania and federal heavy

- duty diesel emission control programs ; Federal fuel programs for highway vehicles and nonroad mobile equipment ; and Federal regulation of offroad diesel and gasoline

- powered vehicles and equipment

.- iv

-

In addition, Pennsylvania’s Diesel

- Powered Motor Vehicle Idling Act of 2008 will assist

the Pittsburgh

- Beaver Valley Area in attaining and maintaining air quality.

Pennsylvania and other membe r states of the Ozone Transport Commission (OTC) and

Mid

- Atlantic/Northeast Visibility Union (MANE

- VU) worked together to analyze potential control measures. The Pennsylvania Department of Environmental Protection (Department)

, based on this process that includ ed stakeholders and the other

OTC/MANE

- VU states, concluded that there are no additional reasonable cost

- effective measures that would advance the ability of the area to attain the standard by one year or

more.

T he OTC ’s modeling platform , t he Comm unity Multi

- scale Air Quality (CMAQ) photochemical grid model (version 4.5)

, was used to estimate projected 2009 PM 2.5 concentrations within the Pittsburgh

- Beaver Valley Area . CMAQ is an Eulerian grid model capable of simulating air pollutant concentratio ns in the atmosphere using mathematical equations to characterize chemical and physical properties.

A review of the base case (2002) run indicated the CMAQ model did a reasonable job reproducing actual concentrations. Based on this analysis

, it is reasona ble to assume the

model can estimate the projected PM 2.5 concentrations within the Pittsburgh

- Beaver Valley Area for 2009

. The year 2009 will be the last complete year of annual emissions and ambient monitoring data that the EPA will use to determine whet her the Pittsburgh

Beaver Valley Area achieves attainment in April 2010.

Projected PM 2.5 concentrations from CMAQ indicate the Pittsburgh

- Beaver Valley Area

will attain the annual and 24

- hour PM 2.5 standard s in 2009. Additional evidence supporting this co nclusion include s recent lower concentrations at monitors within the Pittsburgh

- Beaver Valley Area , significant SO 2 controls installed on large source s with in

and near the Pittsburgh

- Beaver Valley Area and possible model under

- predictions of the air qualit y benefits of emission reductions

.

A number of potential emission control measures were developed during the OTC/

MANE

- VU/ Mid

- Atlantic Regional Air Management Association ( MARAMA ) collaborative strategy development process

. These measures are outlined in the technical support document titled: Development of Emission Projections for 2009, 2012, and 2018 for NonEGU Point, Area, and Nonroad Sources in the MANE

- VU Region

, developed by

MARAMA

. This document, which can be found in Appendix D

- 1, provides detai ls on the specific factors, control assumptions, and implementation schedules used in the emission projection calcula t ions for each source category.

This SIP revision contains a contingency plan that provides assurance that should the Pittsburgh

- Beaver Va lley Area fail to meet a milestone, fail to attain the NAAQS by the

attainment date or violate the standard during the maintenance period

, the area can be brought back into attainment as expeditiously as practicable

.1 I. INTRODUCTION AND OVERVIEW

A. Health and Environmental Effects of Fine Particulate Matter ( PM 2.5 )

Particulate matter (PM) includes both solid and liquid particles suspended in the air. PM is chemically and physically diverse and originates from a variety of human and natural

activiti es. PM is composed of particles in a wide range of sizes. Particles less than 10

micrometers in diameter (PM 10 ) pose a health concern because they can be inhaled into and accumulate in the respiratory system. Particles less than 2.5 micrometers in diame ter (PM 2.5 ) are referred to as fine particles and generally pose the largest health risks. Because of their small size, fine particles can penetrate deeply into the lungs.

Many scientific studies have linked exposure to elevated levels of PM 2.5 to premat ure death, aggravated respiratory disease

, including asthma and chronic bronchitis, cardiovascular disease, changes in lung function and increased respiratory problems

, such as coughing and painful breathing

, as well as increased susceptibi lity to respirat ory infections. Individuals particularly sensitive to PM 2.5 exposure include older adults, people with heart and lung disease and children.

The recent article, “Fine

- Particulate Air Pollution and Life Expectancy in the United States” by C. Arden Pope, II I, et al., was published in the New England Journal of Medicine on January 22, 2009. The authors of the article were able to demonstrate that

decreased PM 2.5 concentrations contributed to a significant improvement in life expectancy. The study used stati stical analyses to evaluate the role the PM 2.5 reductions

that occurred in the 1980s and 1990s had on the increased life expectancy observed over that period. The study found that a reduction of 10 micrograms per cubic meter (μg/m 3 ) of

PM 2.5 was associated with an average increase in life expectancy of 7.3 months.

PM 2.5 has significant environmental impacts

, including acid rain and stream eutrophication. PM 2.5 also affects visibility (regional haze) through the scattering and absorption of light. Fine particles, similar in size to the wavelength of light, are most efficient, per unit of mass, at reducing visibility. Soiling and materials damage can also be caused by PM 2.5 in the air.

B. Sources of PM 2.5 and Implications for Reduction

Fine particle pollution can be emitted directly or formed secondarily in the atmosphere.

PM 2.5 emitted directly into the air in a stable solid or liqui d chemical form (including PM 2.5 that is formed near its source by condensation) is referred to as “primary” PM 2.5 . PM 2.5 formed by chemical reactions of gases in the atmosphere is considered to be “secondary”

PM 2.5 . The chemical composition of PM 2.5 in an area depends on the mix of emissions, location, time of year, and weather. The chemical composition of PM 2.5 can include sulfate, nitrate, ammonium, particle

- bound water, black (elemental) carbon, a great variety of organic compounds, and miscellaneous inorganic material

, such as dust and metals.2

Primary PM 2.5 includes soot from diesel engines, condensed organic material from incomplete combustion and compounds from condensation during combustion or smelting.

The atmospheric chemistry of PM 2.5 forma tion is complex. Formation of secondary PM 2.5 depends on numerous factors

, including the relative concentration of precursors, atmospheric conditions and the interactions of precursors with each other and with other particles, clouds or fog. The contribu tion of different precursors will vary by location.

The principal forms of secondary PM 2.5 include:

Sulfates, formed from emissions of sulfur dioxide from power plants and

industrial facilities ; Nitrates, formed from emissions of nitrogen oxides from p ower plants, vehicles, and other combustion sources ; Ammonium, formed primarily from emissions of ammonia from animal operations ; and Secondary organic aerosol

, formed from emissions of v olatile organic

c ompounds ( VOCs ) from incomplete combustion and evapo ration from a wide diversity of sources.

To protect public health and the environment, the United States Environmental Protection Agency (EPA) is required by the Clean Air Act (CAA) to set and periodically revise National Ambient Air Quality Standard s (N AAQS) for six criteria pollutants. Particulate matter is one of the criteria pollutants

. The EPA sets NAAQS based on its review of existing scientific knowledge about the adverse health and welfare effects of the pollutant.

After the EPA sets or revises a NAAQS, s tates have the responsibility for devising strategies to attain and maintain the standard. Previous particulate matter standards were

set for PM and PM 10

. I n 1997, after evaluating hundreds of health studies and conducting an extensive peer re view process, the EPA promulgated NAAQS based on the level of particles smaller than 2.5 micrometers ( PM 2.5 ) . In setting the 1997 standard s for PM 2.5 , the EPA recognized that the smaller particles were most directly associated with adverse

health effects.

The EPA set the annual health

- based standard for PM 2.5 at 15 .0 μg/m 3 . This is determined by the 3

- year average of annual mean PM 2.5 concentrations. The EPA set the 24

- hour

standard at a level of 65 (μg/m 3 ) , as determined by the 3

- year average of the 98th percentile of 24

- hour concentrations. The EPA set l evels to protect the environment at the

same level as it set the health

- based standards. While the EPA revised the 24

- hour standard

in 2006 to be more protective

, designation of specific nonattainmen t areas for the 2006

revision to the standards were not yet effective at the time this plan was developed

. Therefore, this document addresses attainment of the 1997 PM 2.5 NAAQS

. Measures included in this document will continue to be in place to assist wi th attaining the more protective standard in the future.

The Pittsburgh

- Beaver Valley PM 2.5 Nonattainment A rea ( Pittsburgh

- Beaver Valley Area )

, located in southwestern Pennsylvania, consists of Beaver, Butler, Washington, and3

Westmoreland counties and por tions of Allegheny, Armstrong, Greene and Lawrence counties. Five municipalities near the Clairton Coke Works in Allegheny County are designated as a separate nonattainment area, the Liberty

- Clairton PM 2.5 Nonattainment Area. The Liberty

- Clairton PM 2.5 N onattainment Area was designated as a separate, distinctively local

- source impacted, nonattainment area because the combination of emissions from the coke plant in a narrow river valley creates a local air quality problem uniquely different from the remain der of the Pittsburgh

- Beaver Valley Area

. The Liberty

Clairton PM 2.5 Nonattainment Area was also previously designated as a PM 10 nonattainment area.

The Pittsburgh

- Beaver Valley Area was designated as nonattainment because it violated

the 1997 annual s tandard of 15.0 μg/m 3 b ased on 2001

- 03 monitoring data . The Pittsburgh

- Beaver Valley Area did not violate the 1997 24

- hour standard of 65 μg/m 3

.

Because of the complexity and variability of the process of particulate matter formation,

the EPA recognizes that effective control measures for PM 2.5 will vary among nonattainment areas

. In the EPA’s Clean Air Fine Particle Implementation Rule ( 7 2 FR

20586 , April 25, 2007 ) (the implementation rule)

, the EPA establishe d general presumptive policies for assessing which PM 2.5 precursors should be evaluate d for possible

controls. The EPA requires states to evaluate control measures for sulfur dioxide ( SO 2 ) and primary PM 2.5 in all locations. The EPA requires states to evaluate control measures for nitrogen oxides ( NO

x ) unless a technical demonstration is made to show NO

x does not significantly contribute to PM 2.5

. The EPA requires states to evaluate measures for VOC

and ammonia (NH 3 ) only if a technical demonstration is made to show they significantly

contribute t o PM 2.5 in that area. While this State Implementation Plan ( SIP ) revision provides emissions information for all pollutants ( PM 10 , PM 2.5 , SO 2 , NOx, VOC and NH 3 )

, as required, it does not provide technical demonstrations pertaining to the level of

contribu tion by NOx, VOC, or NH 3 to PM 2.5 concentrations . Therefore, the

C ommonwealth will consider SO 2 and N Ox as PM 2.5 precursors for purposes of this attainment plan and reasonable further progress. 1 The EPA has indicated that virtually all nonattainment prob lems appear to result from a combination of local emissions and transported emissions from upwind areas. 2

The CAA requires that an area’s attainment date be the date by which attainment can be achieved as expeditiously as practicable

, but no later than f ive years from the effective date of designation, or no later than April 5, 2010. If appropriate, the EPA could extend the attainment date up to but no l ater than 10 years after the date of designation. States are required to propose and justify an attai nment date in their attainment plan. This SIP

revision sets an April 2010 attainment date for the Pittsburgh

- Beaver Valley Area

. The analysis is based on modeling of projected emissions for 2009 because 2009 will be the last complete year of annual emiss ions and ambient monitoring data that the EPA will use

to determine if the Pittsburgh

- Beaver Valley Area attain s the standard by April 2010.

1 The EPA’s definition of PM 2.5 attainment plan precursor can be found in 40 CFR Part 51, Subpart Z,

section 51.1000.

2 Clean Air Fine Particle Implementation Rule, 72 FR 20587.4

The EPA Administrator is authorized under Section 179(a) of the CAA to impose sanctions after making a finding or d etermination relating to a SIP revision, or after disapproving a SIP revision, in whole or in part. Mandatory sanctions would be imposed for (1) a state’s failure to submit a plan or plan element, or to make a submission that

satisfies the minimum criteri a of section 110(k) of the CAA in relation to any element of the plan; (2) the EPA’s disapproval of a plan in whole or in part; (3) the EPA’s determination that a state has failed to make a required submission, including a required submission satisfying th e minimum criteria of section 110(k); or (4) a state’s failure to implement any requirement of an approved plan. If the state fails to correct any SIP deficiency within 18 months from the Administrator's finding, determination or disapproval, mandatory san ctions would be imposed. There are two mandatory sanctions

for non complying states: (1) limitations on certain federal highway funding; and (2) "offset" limitations on certain developments in affected areas that require each new stationary emission source to be paired with a reduction in area emissions amounting to

double the amount of increased emissions from the new source.

In addition, failure to submit a plan, failure to implement a plan, or the EPA

disapproval of a plan can also affect the ability of transportation planning agencies

to meet transportation conformity requirements, and thus the ability to implement

transportation projects. The EPA may also impose discretionary sanctions under

Section 110 of the CAA.

C. Purpose a nd Structure o f t his D ocument

In December 2004

, after consultation with states and receipt of public input, the EPA designated eight areas in Pennsylvania comprised of all or part s of 21 Pennsylvania

counties as PM 2.5 nonattainment areas based on air quality monitoring data f rom 2001

- 2003. Under Section 110 of the CAA , t he Commonwealth of Pennsylvania (Commonwealth or Pennsylvania) is required to develop a revision to the SIP to
demonstrate how the Pittsburgh

- Beaver Valley Area will attain the standard by April 2010,

meet emi ssion reduction requirements in the CAA and ensure that in the event of a future violation or failure to meet emission reduction milestones, the area is brought back to attainment as quickly as possible.

This SIP revision is organized as follows:

Secti on I provides general information about PM 2.5 pollution

, including information about the health and environmental impacts of PM 2.5 and sources of PM 2.5 and its precursors. Section I also provides an overview of the health

- based PM 2.5 standard and Pennsylv ania’s responsibility to develop strategies to attain air quality standards.

Section II provides information characterizing the PM 2.5 problem in the Pittsburgh

- Beaver Valley Area , examines current monitoring information

, and analyzes trends.5

Section III describes emission inventories for PM 2.5 and its precursors, SO 2 and NOx

. Base year and projected emission inventories are also included as required for PM 10 , VOC

and NH 3

. Section III describes how this SIP revision meets the requirement for

“reasonable further progress” under Section 172 of the CAA 3

. Section III also contains the highway vehicle emission budgets for purposes of transportation conformity. Technical

information on methodologies and inputs for point, area, highway and nonroad actual and

p rojected emission inventories is contained in the Appendices B through F, relating to : (1) stationary point sources; (2) stationary area sources; (3) emissions projections; (4) highway vehicle sources inventory information; and (5) nonroad sources.

Sec tion IV describes the control measures implemented in the Pittsburgh

- Beaver Valley

Area that produce emission reductions between 2002 and 2009 in order to attai n the NAAQS in a timely fashion and how Pennsylvania meets the requirement for identifying

Reaso nably Available Control Measures (RACM) that could advance the attainment of the standard by one year or more. Appendix G, relating to Reasonably Available Control Measures, includes s pecific information and recommendations developed by the Ozone Transpor t Commission ( OTC ) and the Mid

- Atlantic/Northeast Visibility Union (MANE

VU) states for additional controls to aid in reaching attainment

.

Section V discusses the modeling that was done to evaluate attainment by April 2010 and the “weight of evidence” ana lysis. Together, these comprise the attainment demonstration. Based on modeling, statistical analyses and other evidence, the attainment demonstration

indicates the Pittsburgh

- Beaver Valley Area will attain the 1997 PM 2.5 standards by April

2010. Append ix H includes detailed technical information on the Community Multi

- scale Air Quality ( CMAQ ) model performance, meteorological data, modeling emission inventories and modeling analysis used to project 2009 annual and 24

- hour PM 2.5 design

values

.

Section V I is the contingency plan, meeting the requirement that the Commonwealth be able to address unanticipated failures to meet emission or air quality requirements in a timely fashion.

D. Public P articipation

Requirements for a public comment process are set forth in Section 110(a ) ( 2) of the CAA

, 40 CFR Section 51.102(d) and 35 P.S. Section 4007.5 On September 5, 2009, the Pennsylvania Department of Environmental Protection (DEP or Department) published a notice of public hearing and commenced a 30

- day written comment period on the proposed

attainment d emonstration and base year inventory for the Pittsburgh

- Beaver Valley Area

. 39 Pa.B. 5278. The Department held a public hearing in Pittsburgh on the proposed SIP

revision on October 6, 2009 . The public c omment period closed on October 9 , 200 9

. T he Department has prepare d a Comment and Response Document addressing comments received during the public participation process. Proof of public notice and a copy of the Comment and Response Document are included in the SIP submittal.

3 Clean Air Fine Particle Implementation Rule, 72 FR 20633

.67

II. NATURE OF THE PROBLE M IN THE PITTSBURGH

- BEAVER VALLEY

AREA

A. Background

The Pittsburgh

- Beaver Valley Area , located in southwestern Pennsylvania, consists of Beaver, Butler, Washington, and Westmoreland counties and por tions of Allegheny, Armstrong, Greene and Lawrence counties

. Five municipalities near the Clairton Coke Works in Allegheny County are designated as a separate, local

- source impacted nonattainment area, the Liberty

- Clairton PM 2.5 Nonattainment Area. Other PM 2.5 nonattainment areas near the Pittsburgh

- Beaver Valley Area include Morgantown, WV to the south, Stuebenville

- Weirton, OH

- WV to the west

, Youngstown, OH to the northwest and Johnstown, PA to the east. Topographically, the Pittsburgh

- Beaver Valley Ar ea is

bounded on the east by the high terrain of the Laurel and Chestnut Ridge Mountains

. T here are several major rivers that run through the region, including the Ohio, Allegheny, Monongahela, and Youghiogheny

. These rivers, along with the rising terrai n around them, create unique wind patterns.

Several types of PM 2.5 monitors operate within the Pittsburgh

- Beaver Valley Area . These

include eleven f

ederal r eference m ethod (FRM) moni tor s. Five of these sites are operated by the Department, including Bea ver Falls, Charleroi, Florence, Greensburg, and Washington

. The addition al six monitors, which include Coraopolis, Harrison, Lawrenceville, North Braddock, North Park, and South Fayette, are operated by the Allegheny County Health Department (ACHD). In a ddition to the FRM s
, three speciation

monitor s (at Florence, Greensburg, and Lawrenceville) and four continuous monitors (at Beaver Falls, Charleroi, Kittanning, and Lawrenceville) are maintained within the region

. FRM data has been collected since 1999 o n a one in three day frequency (1/3). Speciated monitoring on a one in six day frequency (1/6) has occurred since April of 2002

, while the Tempered Element Oscillating Microbalance ( TEOM ) monitor has operated almost continuously since August 2004.8

B . Air Quality Monitoring Trends Analysis

A short summary of monitoring trends in the Pittsburgh

- Beaver Valley Area is provided as

follows:

1. Design Value Trend

Table II

- 1: Pittsburgh

- Beaver Valley Area Annual PM 2.5 Average and Design Valu e Trend (ug/m3)

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Beaver Falls 16.14 17.19 15.26 15.67 15.38 18.30 14.87 15.72 13.69

Charleroi 15.44 15.27 15.90 15.88 14.89 13.99 16.36 14.42 15.51 13.03

Florence 12.98 13.20 14.43 13.21 13.40 13.21 1 4.23 11.94 13.79 11.30 Greensburg 14.90 15.78 16.11 14.96 15.32 14.92 16.81 14.32 15.26 12.67 Washington 14.58 15.16 15.85 14.49 14.74 14.14 15.88 13.08 14.83 12.27

Coraopolis * 15.63 13.38 15.33 13.63 15.71 13.26 14.67 12.38 13.6 4

Harrison 17.45 16.09 16.11 16.09 15.50 15.02 15.95 14.03 15.06 13.39

Lawrenceville 16.23 15.63 16.58 15.33 15.20 15.46 15.82 14.40 14.89 12.87

N. Braddock 17.69 16.45 17.09 16.92 16.80 15.79 17.16 15.03 16.38 14.15

N. Park * 11.99 14.49 14.87 13.63 13.96 12.28 14.44 11.50 13.02 S. Fayette 14.98 14.09 14.04 12.31 13.23 13.00 14.22 11.14 13.47 10.77

Max Annual

Value 17.19 16.92 16.80 15.79 18.30 15.03 16.38 14.15

Source: Data extracted from Appendix A

- 1 (US EPA Air Quality System AMP 450 Repo rt)

* The Cora o polis and N. Park monitor were shut down for 2008 due to limited staff at

ACHD9 Figure 1: Pittsburgh

- Beaver Valley Area Monitor Trend10

2. NO 2 Monitoring T rend

Figure 2 : NO 2 Monitoring Trend

Figure 2 displays the rural vs. urban annual NO 2 concentration trend from 1999 to 2008. The rural monitor is adequately represented by the monitored values at Florence. The urban monitor is adequately represented by the Pittsburgh (Carnegie) monitor.11

3. SO 2 M onitoring Trend

Figure 3 : SO 2 Monitoring Trend

The following graph displays the rural vs. urban annual SO 2 concentration trend from 1999 to 2008. The rural monitor is adequately represented by the monitored values at Florence.

The urban monitor is ade quately represented by the Pittsburgh (Carnegie) monitor.

C . S easonal Variability

1. FRM Monitoring Trends

Summary of seasonal variability in FRM data: There appears to be little variability in quarterly FRM values at monitor s located in the Pittsb urgh

- Beaver Valley Area

. In the more urbanized areas, monitored v alues during the 1 st , 2 nd and 3 rd quarters tend to run higher than 4 th quarter values. By contrast

, the monitoring site s in rural areas (such as Florence and South Fayette) have substantial ly higher 2 nd and 3 rd quarter averages than 1 st

and 4 th quarter averages

.

2. Speciation Monitoring Trends

Summary of seasonal variability in speciated data: R aw speciation data for the Pittsburgh

- Beaver Valley Area indicates some seasonal variability i n the primary components. Sulfates have the largest variability with 1 st quarter concentrations approximately half concentrations measured in the 3 rd quarter. Nitrates vary in nearly the12

opposite direction with 1 st quarter measurements higher than 2 nd

, 3 rd and 4 th quarter measurements. Organic carbon, elemental carbon, ammonium and crustal mass do not appear to show much seasonal variability.13

III. EMISSION INVENTORIES

Section 51.1008 of 40 CFR Part 51 requires an inventory of pollutants to meet the requirements of section 1 72 (c )( 3) of the CAA. As specified by the EPA, the pollutants inventoried by Pennsylvania include PM 10 , PM 2.5 , SO 2 , NOx, VOC, and NH 3

. In addition, projections of future emissions have been made for the milestone year 2009. Infor mation

on the manmade sources of direct PM and its potential precursors, SO 2 , NOx, VOC, and

NH 3 was compiled for:

“Stationary sour ces” (or “point” sources)

, which are sources for which the Department collects individual emissions

- related information. Gen erally

, they represent major stationary sources but may be smaller.

“ A rea sources
, ” which are industrial

, commercial , and residential sources too small or too numerous to be handled individually . These include but are not limited to

commercial and reside ntial open burning, architectural and industrial maintenance coatings application 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.

“Highway vehicles

, ” which include passenger cars and light

- duty trucks, other trucks, buses and motorcycles.

“Nonroad sources

, ” which encompass a diverse collection of engines

, including but

not 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 inventory for the Pi ttsburgh

- Beaver Valley Area was compiled for the following counties and partial counties that comprise the nonattainment area:

Beaver, Butler, Washington, and Westmoreland counties Armstrong County (partial)

– Elderton Borough, Plumcreek Township, and

W ashington Township Greene County (partial)

– Monongahela Township Lawrence county (partial)

– Township of Taylor south of New Castle City Allegheny County (partial)

– entire county except Lincoln Borough, Clairton City, Glassport Borough, Liberty Borough, and Port Vue Borough which comprise the Liberty

- Clairton PM 2.5 Nonattainment Area

.

Emissions were estimated for the partial counties in the nonattainment area as follows. Point source emissions were included in the inventory if the point source is locate d in the nonattainment area. Area source and nonroad source emission estimates were apportioned14

to the nonattainment area based on the percentage of county population in the nonattainment municipalities, using U.S. Census Bureau sub

- county population data

.

Mobile source VMT and emissions were estimated for the partial counties in the nonattainment area using the following methodology. The townships within each partial county were identified based on the nonattainment area designation description. Usin g GIS, township boundaries were overla i d on the PennDOT Roadway Management System (RMS) state roadway segments and used to identify which road segments fell within the

nonattainment area. These state roadway segments were used for the analysis of VMT and

emissions for non

- local state

- owned roadways.

The PennDOT RMS roadway data contains some local segments (those which are state

owned and function as local roads). Since the RMS database does not contain a comprehensive representation of local roads, loc al VMT is typically reconciled to the reported HPMS local VMT for each county in Pennsylvania. For the partial areas the following methods were used to estimate local VMT:

Three methods were analyzed for each partial county in the nonattainment area and the highest values were chosen to ensure that local VMT was not under

- represented in the analysis. These values were used to estimate emissions for the partial counties in the

nonattainment area. The methods are:

Calculate local VMT based on local road segments in RMS database (as discussed this could underestimate local VMT) Using GIS, determine the portion of the T opologically I ntegrated G eographic

E ncoding and R eferencing (TIGER) 4 roadway loc al mileage in the nonattainment municipalities vs. county total and a pply this percentage to county HPMS local VMT.

Determine the percentage of population in nonattainment municipalities versus the county population and a pply this percentage to c ounty HPMS local VMT.

A. Summary of 2002 Emissions

An emission inventory is an estimate of the emissions from sources in a particular area. The Department developed an emission inventory for 2002, which is the base year for attainment planning purposes with respect to 8

- hour ozone and PM 2.5 SIPs , and for planning purposes with respect to the regional haze SIPs. The 2002 base year inventory

i ncludes the pollutants PM 10 , PM 2.5 , SO 2 , NOx, VOC, and NH 3 . The inventory consists of

sources in four sectors: sta tionary point sources, stationary area sources, highway vehicle

sources and nonroad sources. MANE

- VU compiled a regional inventory from t he

4 The Census Bureau's Geography Division maintains two databases used in this analysis. The MAF, or Master Address File, is a complete and current list of all addresses and locations where people live or work, covering an estimated 115 million residences, as well as 60 million businesses and other structures

in the U.S. The TIGER ® is a digital database that identifies the type, location and name of streets, rivers, railroads and other geographic features, and geospatially defines their relationships to ea ch other, to the MAF addresses, and to numerous other entities. See http ://www.census.gov/geo/www/tiger15

emission inventories of the Northeastern and Mid

- Atlantic states

. This regional inventory was used to perform the regional modeling analysis used in Pennsylvania’s air quality management planning efforts to attain the 8

- hour ozone NAAQS and the PM 2.5 NAAQS

, and to prepare the regional haze plan.

An emissions inventory for the base year, 2002, was developed in accord ance with EPA guidance 5

. Table III

- 1 summarizes the emissions for 2002.

Table III

- 1: 2002 Annual Emissions ( Tons per Year )

Pittsburgh

- Beaver Valley

Area 2002 PM 2.5 PM 10 SO 2 NOx VOC NH 3 Stationary Point Sources 4868 11149 463501 110618 5157 462

Area Sources 7916 41206 9905 8622 36683 2948

Highway Vehicle Sources 824 1164 1770 53268 25638 1884

Non

- Road Sources 1297 1359 1694 25975 13421 8

Totals 14904 54879 476871 198483 80898 5303

B. Summary of Inventory Methodologies

Inventory development met hodology is summarized below.

Stationary Point Sources. The Department requires owners and operators of larger facilities to submit annual production figures and emission calculations each year. Throughput data are multiplied by emission factors from Fa ctor Information Retrieval (FIRE) Data System and the EPA’s publication series AP

- 42 and are based on Source Classification Code (SCC). Each process has at least one SCC assigned to it. If the owners and operators of facilities provide more accurate emiss ion data based upon other factors, these emission estimates supersede those calculated using SCC codes. Appendix B

- 1

includes information on stationary point source emission methodology

, and Appendix B

- 2

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

- 3 is a table document ing the

banked emissions reduction credits for the Pittsburgh

- Beaver Valley Area in the 2009 emission projection

.

The 2002 inventory was based on emissions reported to the Department by facilities. In 2002, many faciliti es did not include condensable PM in their estimates of direct PM

emissions

. Condensable PM is a vapor or gas at stack temperature that condenses to a liquid or solid at stack exit.

Area Sources

. Area source emissions are generally estimated by mu ltiplying an emission factor by some known indicator or collective activity for each area source category at the

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

– EPA

- 454/R

- 05

- 001. August, 2005. Updated November, 2005.16

county level. Pennsylvania estimates emissions from area sources using emission factors

and SCC codes in a method similar to that used for Sta tionary Point Sources. Emission factors may also be derived from research and guidance documents if those documents are

more accurate than FIRE and AP

- 42 factors. Throughput estimates are derived from

county

- level activity data, by apportioning national or statewide activity data to counties, from census numbers, and from county employee numbers. County employee numbers are based upon North American Industry Classification System (NAICS) codes to establish that those numbers are specific to the industry covered. More specific information on the procedure used for each industry type is contained in Pennsylvania 2002 Area Source Criteria Air Pollutant Emission Estimation Methods, (E.H. Pechan & Associates, Inc., February 2004) which is contained in Appendi x C

- 1

. Appendix C

- 2 is a table containing stationary area source s emissions data for the Pittsburgh

- Beaver Valley Area

.

Highway Vehicle Sources. The Department employs an emissions estimation methodology that uses the current EPA

- approved highway vehic le emission model, MOBILE 6.2, to estimate highway vehicle emissions. In addition, Pennsylvania uses a MOBILE pre

- and post

- processing software package called PPSUITE to process and compile Pennsylvania’s robust highway network and detailed highway vehicl e data. The Pennsylvania Department of Transportation ( PennDOT ) provided estimates of vehicle miles traveled (VMT) by vehicle type and roadway type. The Pennsylvania methodology is consistent with the January 2002 guidance published by the EPA’s Office o f Transportation and Air Quality (OTAQ) entitled

, Technical Guidance on the Use of MOBILE6 for Emissions Inventory Preparation

.

More information on highway emission methodology is available in Appendix E. Appendix E

- 1 provides the 2002 base year and 200 9 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 inventory. Appendix

E

- 2 is the t able of 2009 Pittsburgh

- Beaver Valley Area Annual Highway Emissions listed by SCC . Appendix E

- 3 describes the inputs to MOBILE6.2 used to generate emission factors for a specific area. Some examples of the inputs described in Appendix E

- 3 are the type and frequency of vehicle emission testing, t he fuel types 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 specific area information. Finally, Appendix E

- 4 is an electronic file tha t pro vides all of the input coding for a sample segment and scenario used in Pennsylvania’s MOBILE6.2 modeling system

.

Nonroad Sources. The 2002 emissions for the majority of nonroad emission source categories and pollutants 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 types and includes growth factors. The National Mobile Inventory Model (NMIM) was used to e stimate emissions of

ammonia from sources contained in the NONROAD model. The NONROAD model does

not estimate emissions from aircraft

, locomotives or commercial marine vessels

. Emissions from aircraft, locomotives, and commercial marine vessels were esti mated using EPA guidance and best available information. If specific local operational data was17

available, that data was used to estimate emissions. State and national data was used if

local data was unavailable.

Emissions from commercial aircraft ope rations for 2002 were estimated using the EPA

approved Emissions and Dispersion Modeling System (EDMS) 4.20, the latest version available at the time the inventory was developed. Pittsburgh International Airport (PIT) supports the vast majority of the com mercial aircraft operations in the Pittsburgh

- Beaver Valley Area . In addition, a military wing flies cargo aircraft out of PIT. The Department estimated emissions using operations data obtained from the United States Department of Transportation, Federal Aviation Administration’s (FAA) Terminal Area F orecast for commercial aircraft operations and the Airnav.com website for military operations. Using this operations data, e missions were modeled directly using the EDMS

.

Emissions produced by aircraft a t small airports in the Pittsburgh

- Beaver Valley Area were estimat ed by using airport operation statistics, which can be found at www.airnav.com and

the Federal FAA’s Terminal Area Forecast Detailed Report. An emissions factor for a typical general aviati on single engine, multi

- engine, and jet engine aircraft were derived by averaging the emissions factors from a basket of emission factors for common aircraft of each of the three types of aircraft. Emission factors and operational characteristics

containe d in EDMS were used. The proportion of operations among the three groups of aircraft was determined by examining the number of each aircraft type based at each airport. For military operations at small airports, the type of aircraft and its emission

fact ors are sometimes identifiable. If not, emission factors calculated to represent an “average” military aircraft are used. Growth was estimated using estim ates of future operations at Pittsburgh airports found in the FAA Terminal Area Forecast Detailed

Re port.

For 2002 locomotive emissions, the Department projected emissions from a 1999 survey when the Department obtained fuel use statistics from class II and III railroads. For class I railroads, which produce most of the emissions in the Commonweal th , the Department conducted a 2002 inventory because the 1999 fuel use data for class I railroads was skewed by gridlock caused by the acquisition of Conrail by CSX and Norfolk Southern. Emissions were generated using EPA emission factors. Emissions wer e grown using national railroad

fuel use trends supplied by the Association of American Railroads

.

All air emissions from commercial marine vessel (CMV) traffic in the seven county area of the Port of Pittsburgh were estimated using the methodology outli ned in the EPA’s publication Commercial Marine Activity for Great Lakes and Inland River Ports in the United States, Final Report . A comprehensive understanding of the methodology can be achieved by reviewing this document. Additional information was obt ained from conversations with tug operators in the port. Emission estimates were based on number of CMV trips, trip durations, lock data, and the engine size of the tug fleet based in the Pittsburgh

- Beaver Valley Area . Emissions were distributed to the c ounty level based on the number of piers, wharves, and docks in each individual county. Relevant CMV operational data was obtained from the U.S. Army Corps of Engineers website.18

Appendix F

- 1 is the technical document providing the methodology and descri ption of the procedures used to generate 2002 and 2009 county

- level pollutant emission estimates for nonroad mobile engines included in the EPA’s NONROAD2005 m odel, locomotive engines

, and aircraft operations. The t able of the specific emission s data used to calculate the nonroad emissions sorted by source category is available as Appendix F

- 2.

C. Projected Inventories

1. Summary of 2009 Estimated Emissions

Table III

- 2 summarizes the emissions expected in 2009. These emissions take activity and

emiss ions growth and/or controls from 2002 into account. Appendix D, relating to emissions projections, contains the technical support documents that describe the methodologies used to project the 2002 baseline emissions to 2009.

Table III

- 2: 2009 Projected Emissions ( Tons per Year )

Pittsburgh

- Beaver Valley

Area 2009 PM 2.5 PM 10 SO 2 NOx VOC NH 3 Stationary Point Sources 18160 24710 114889 51361 4666 782

Area Sources 8127 42749 10452 9101 34042 3528

Highway Vehicle Sources 509 852 230 28739 14098 2121

Non

- R oad Sources 1142 1200 1385 21246 10055 9

Emission Reduction Credits

Banked 31 102 2118 1450 368 0

Totals 27969 69613 129074 111897 63230 6440

Sulfur and n itrogen are the major contributors to the Pittsburgh

- Beaver Valley Area ’s

PM 2.5 nonattainment prob lem. Therefore, even though the direct PM 2.5 emissions are predicted to increase in 2009, the reductions of PM 2.5 precursors, SO 2 and NOx

, will ensure that the Pittsburgh

- Beaver Valley Area attains the PM 2.5 NAAQS by 2010

. The emissions inventory shows t his apparent increase in PM 2.5 emissions from stationary sources from

2002 to 2009 because the 2002 inventory was based on emissions reported to the Department by facilities and did not include condensable PM for many facilities. The projected 2009 PM 2.5 emissions for electric generating units (EGUs) include condensable

PM emissions which were calculated based on factors derived from AP

- 42 defaults.

2. Growth Projection Methodologies

This section describes the data, methods, and assumptions utilized in developing estimates of emissions changes between 2002 and the milestone year 2009. Appendix

D

- 1 contains the technical support document en titled

, Development of Emission Projections for 2009, 2012, and 2018 for Non

- EGU Point, Area, and Nonroad Sources i n the MANE

- VU Region , developed by Mid

- Atlantic Regional Air Management Association19

( MARAMA ). The document provides details on the specific factors, control assumptions, and implementation schedules used in the emission projection calculations for each so urce category.

Stationary Point Sources. For EGUs

, t he Department used the EPA’s Integrated Planning Model ( IPM ) modeling as adjusted by the Visibility Improvement State and Tribal Association of the Southeast (VISTAS), specifically VISTAS 2.1.9, to pr edict the

results of the EPA’s CAIR at affected facilities throughout the CAIR region. The emissions for 2009 resulting from application of the CAIR cap and trade program for

annual NOx emissions

, as predicted by IPM

, were used. IPM estimates NOx and SO 2 emissions only. Operating parameters predicted by IPM for each EGU and emission factors were used to predict emissions of VOC, PM 10 , PM 2.5 , condensable PM, and NH 3

. The technical support documents that describe the methodologies used to project the

emis sions from EGUs, Documentation of 2018 Emissions from Electric Generating Units in the Eastern United States for MANE

- VU’s Regional Haze Modeling (Alpine Geophysics, April 2008) and Future Year Electricity Generating Sector Emission Inventory D evelopment U sing the Integrated Planning Model (IPM®) in Support of Fine Particulate Mass and Visibility Modeling in the VISTAS and Midwest RPO Regions (ICF, April 2005) are included as Appendices D

- 2 and D

- 3, respectively.

For non

- EGU point sources, t he methodology for projecting emissions to 2009 is the same as the methodology described below for stationary area sources as d ocumented in Appendix D

- 1

, Development of Emission Projections for 2009, 2012, and 2018 for Non

EGU Point, Area, and Nonroad Sources in the MA NE

- VU Region

. This report was prepared for MARAMA as part of an effort to assist states in developing attainment plans

for ozone and fine particles, and in developing regional haze plans . It describes the data sources, methods, and results for emission f orecasts for three years, three emission sectors,

two emission control scenarios

, seven pollutants, and 11 states plus the District of Columbia. MARAMA developed projections for 2009

, 2012

, and 2018.

The projected 2009 PM 2.5 emi ssions for EGUs include condensable PM. Emissions of

condensable PM were calculated based on factors derived from AP

- 42 defaults. Because the 2002 inventory was based on emissions reported to the Department by facilities and did

not include condensable s for many facilities, the emissions inventory shows an apparent

increase in PM 2.5 emissions from stationary sources from 2002 to 2009.

Area Sources. Area source emissions were projected from the 2002 inventory.

The factors used for the temporal allocation of projections to 20 09 from the 2002 baseline inventory were provided by MARAMA, which is coordinating air quality technical projects for the Northeast and Mid

- Atlantic states. The factors were in the form of Sparse Matrix Operator Kernel Emissions (SMOKE) v2.2 input files 6

.

6 For additional information on the SMOKE file formats, please refer to the SMOKE v2.2 Users Manual, available from the Center for Environmental Modeling for Policy Development (CEMPD) a t http://cf.unc.edu/cep/empd/products/smoke/index.cfm#Documentation.20

A table of growth factors for 2009 was provided by MARAMA. For each state, county and SCC, this table includes state growth factors derived from the Energy Information Administration (EIA) Annual Energy Outlook, 2005; and/or factors extracted from the Economic Growth Analysis System (EGAS). Where more than one factor was available, the first choice was the EIA factor followed by the EGAS factor.

MARAMA also supplied tables of control factors, rule effectivenes s factors, and rule penetration factors for any control measures applicable to these sources.

For the area sources, these factors were available by SCC and pollutant. There may be more than one generic control factor that applies to a given SCC and pollutant. In cases

where there was more than o ne applicable factor, the following formula may have been applied recursively to generate reductions that are a composite of those factors.

Where

CF is the control factor

RE is the rule effectiveness factor RP is the rule penetr ation factor

As described for stationary point sources above, Appendix D includes the MARAMA

report, Development of Emission Projections for 2009, 2012, and 2018 for NonEGU Point, Area, and Nonroad Sources in the MANE

- VU Region, which documents the

method ology for projecting emissions to 2009.

Highway Vehicle Sources. The EPA’s a pproved highway vehicle emission model, MOBILE 6.2, projects highway vehicle average fleet emission factors. State specific information was used where available and appropriate. Traffic forecasts were compiled using information from PennDOT ’s Traffic Information System and

socioeconomic data. The Pennsylvania methodology for estimating highway vehicle emissions is consistent with the January 2002 guidance published by the EPA’s Office of Transportation and Air Quality ( OTAQ ) entitled

, Technical Guidance on the Use of MOBILE6 for Emissions Inventory Preparation

. Appendi ces E

- 1 through E

- 5 include

s pecific information on the highway emission s inventory methodology , data files of

emissions estimates , MOBILE6.2 input parameters

, a MOBILE6.2 sample input file,

and the traffic growth forecasting system report

.

As shown in Table III

- 3

, VMT for the future analysis year increases 11% from 18.3 billion

to 20.3 billion VMT within the nona ttainment area

. Despite the growth in VMT, emissions of the most significant vehicle

- related precursor, NOx, are significantly lower in the future

a nalysis year

.21 Table III

- 3 : Regional Nonattainment Area VMT and Emissions

Direct PM

YEAR VMT PM 2.5 PM 10 VOC NOx SO 2 NH 3
2002 18,322,527,954 824 1,164 25,638 53,268 1,770 1,884

2009 20,266,112,739 509 852 14,098 28,739 230 2,121

Nonroad Sources

. Projected emissions for the majority of nonroad emission source categories and pollutants were esti mated using the EPA NONROAD 2005 model, which contains default assumptions for projected years. The NMIM estimated future ammonia emissions from source categories in the NONROAD model. The NONROAD model and

NMIM estimate emissions for diesel, gasoline, l iquefied petroleum gasoline, and compressed natural gas

- fueled nonroad equipment types and include growth factors.

Future aircraft emissions from small and large airports were calculated by using future airport operation estimates , which can be fou nd in the FA A ’s Terminal Area Forecast Detailed Report. Emission factors from aircraft and the aircraft mix remained unchanged in future years.

For locomotive emissions, the Department projected emissions from 2002 to 2009, using national fuel consumption da ta obtained from the Association of Ame rican Railroads and

the EPA emission factors developed for the locomotive fleet in future years.

Commercial marine vessel emissions were grown using projected activity , fuel use and

emission estimates from the EPA do cument, Final Regulatory Analysis: Control of Emissions from Marine Diesel Engines, November 1999.

Additional information about nonroad emission projection methodologies can also be found in Appendix F. Appendix F

- 1 is the technical document providing the methodology and description of the procedures used to generate 2002 and 2009 county

- level pollutant emission estimates for nonroad mobile engines included in the EPA’s NONROAD2005 model, locomotive engines and aircraft operations. The t able of nonroad emissions data sorted by source category is available as Appendix F

- 2.

D. Reasonable Further Progress (RFP) Requirements

Section 172(c ) ( 2) of the CAA requires that plans for nonattainment areas provide reasonable further progress

. In accordance with 40 CFR 51.1009

, if a state submits an

attainment demonstration for an area which demonstrates that the area will attain the PM 2.5 NAAQS within five years of designation, the state is not required to submit a separate RFP plan. In that case, compliance wit h the emission reduction measures in the attainment demonstration and SIP will meet the requirements for achieving RFP for the area. This

attainment demonstration and SIP revision demonstrate that t he Pittsburgh

- Beaver Valley

Area will attain the PM 2.5 NA AQS by the area’s attainment date of April 2010 , which is22

within five years of designation . Therefore, c ompliance with the emission reduction measures described in this plan meets the requirements for achieving RFP for the area.

E. Motor Vehicle Emissi on Budgets f or Transportation Conformity

Section 176 of the CAA provides a mechanism by which federally funded or approved highway and transit plans, programs, and projects are determined not to produce new air quality violations, worsen existing violatio ns, or delay timely attainment of the NAAQS.

. EPA regulations issued to implement transportation conformity provide that motor vehicle emission “budgets” establish caps of these emissions that cannot be exceeded by the predicted transportation system emi ssions in the future. Transportation agencies in Pennsylvania are responsible for making timely transportation conformity determinations. The responsible agency in the Pittsburgh

- Beaver Valley Area is the Southwestern Pennsylvania Commission , the designa ted Metropolitan Planning Organization (MPO) under federal transportation planning requirements.

Pennsylvania proposes to establish budgets for highway emissions for direct PM 2.5 and NOx in order to ensure that transportation emissions do not impede clean air goals in the next decade and beyond. The information in Table III

- 5 , once the EPA approves it for purposes of conformity, will establish transportation conformity budgets for the Pittsburgh

Beaver Valley Area

.

Amendments to the 40 CFR p art 93 transp ortation conformity regulations to address the

1997 PM 2.5 standard were published in the Federal Register on May 6, 2005 ( 70 F R

24280 ) to account for PM 2.5 and its precursors. Section 93.102 requires conformity determinations to be applicable to direct em issions of PM 2.5 and NOx (unless a determination is made that transportation

- related emissions are not significant contributors

to PM 2.5 ), but to emissions of SOx, VOC, and NH 3 only if a finding is made that transportation

- related emissions of these pollut ants are significant contributors to PM 2 .5

.

Motor vehicle emissions of S O x , VOC, and NH 3 were analyzed to determine if motor vehicle budgets should be established for these pollutants. Table III

- 4 illustrates the on

road mobile source fraction of the to tal 2009 inventory for each of these pollutant s

. VOC

and NH 3 account for a total of 22.30 % and 32.93 % of the total projected 2009 inventory

for VOC and NH 3 , respectively. Motor vehicle emissions of SOx account for 0.18 % of the total projected 2009 inven tory.23

Table III

- 4 Comparison of 2009 O n

- Road Mobile Precursor Emissions to the Total Projected 2009 Inventory

2009 SO 2 VOC NH 3

On

- Road Mobile Source Projected Inventory (Tons) 230 14098 2121 Total Projected 2009 Inventory (Tons) 129074 63230 6 440

Percent of Total Projected 2009 Inventory (%) 0.18 22.30 32.93

Motor vehicle emissions budget for S O x , VOC, and NH 3 are needed only if the state air agency director or the EPA Regional Administrator makes a finding that motor vehicle emissions budg ets must be established in order to attain the NAAQS for PM 2.5

. B ecause the reactions that form particulate matter from emissions of VOC are complex and highly variable, there is considerable uncertainty regarding the contribution of VOC to particulate

fo r mation. Likewise, much uncertainty remains regarding the role of NH 3 in particulate

formation. As discussed earlier in Section I, the Commonwealth is not considering VOC

or NH 3 as PM 2.5 precursors for the purpose of the attainment plan because of the

un certainty surrounding their role in particulate formation. Therefore, this SIP revision is not establishing a motor vehicle emission budget for VOC or NH 3 . As shown in Table III

4, motor vehicle emission s of SO 2 are a small percentage of the total invent ory. Based on

these facts and the fact that n o applicable finding has been made for these pollutants , this

SIP revision is only establishing motor vehicle emission budgets for direct PM 2.5 and NOx

, as shown in Table III

- 5

.

Table III

- 5 : Motor Vehicle Emi ssion Budgets

2009 PM 2.5 NO x Tons/year 509 28739

The Department has included direct PM 2.5 re

- entrained road dust emissions from paved and unpaved roads in the area source inventory. However, a number of fugitive dust

studies have indicated that the PM 2.5 / PM 10 ratios measured by EPA FRM samplers are significantly lower than predicted by AP

- 42 emission factors. As a result, the PM 2.5 emission estimates using AP

- 42 are biased high by as much as a factor of two, compared to FRM samplers. The Department believes that the emissions from paved and unpaved roads are significantly over

- predicted and

, therefore, has not included those emissions in

the motor vehicle emission budgets at this time. Appendix C

- 2 , relating to area source annual emissions, contains estimates of the PM 2.5 emissions attributable to paved and unpaved roads

.

Transportation construction

- related fugitive dust emissions are not a significant contributor to the air quality problem. At the Pittsburgh

- Beaver Valley Area speciation monitor , the crustal component was found to be small compared to other components of PM 2.5 (see24

Section V, Figure 5). Given that construction-related fugitive dust is one of many source categories contributing to the crustal material observed at the monitor, and transportation construction is a small subset of all construction, it is safe to conclude that transportation construction-related fugitive emissions are insignificant.25 IV. CONTROL STRATEGIES

A. Permanent and Enforceable Control Measures

This sect ion describes the federal and state measures that will provide the direct PM 2.5 , SO 2 and NO

x emission reductions leading to emission reductions and attainment of the

standard.

A summary of the quantity of emission reductions expected from 2002 to 2009 i s included

in Table IV

- 1. (Positive values indicate emission reductions, negative values indicate an increase in emissions.) The emission reduction estimates account for any anticipated growth in the activity of sources regulated by the strategy. For so me pollutants and categories, emissions in 2009 are anticipated to be higher than they were in 2002. In those

cases , projected growth in emissions is larger than anticipated emission reductions from control measures for that pollutant and source category. Each measure is explained in greater detail in the following sections.

Table IV

- 1: Summary of Emission Reductions 2002

- 2009 from Control Measures

2002

- 2009 Difference PM 2.5 SO 2 NOx
Stationary Point Sources

- 13292 348612 59257

Area Sources

- 212

- 547

- 479
Highway Vehicle Sources 315 1540 24529

Nonroad Sources 155 309 4729

1. Stationary Point Sources

Clean Air Interstate Rule (CAIR). EPA’s CAIR (70 FR 25162, May 12, 2005) was remanded to EPA for revisions by the United States Court of Appeals fo r the District of Columbia on December 23, 2008. The Court ordered the EPA to revise the CAIR consistent with the July 11, 2008 decision , but did not set a deadline. EPA intends to promulgate a replacement rule in 2011. In the meantime, CAIR is being im plemented. Pennsylvania transitioned from the NOx SIP Call to the federal CAIR in 2009. The

market

- based CAIR was designed to reduce large electric generation unit (EGU) emissions

of NOx and SO 2 below 2002 levels throughout the 28

- state CAIR region. Pen nsylvania and other nearby states were required to adopt a regulation implementing the requirements of the CAIR or an equivalent program. On April 28, 2006, the EPA promulgated Federal Implementation Plans (FIPs) to reduce the interstate transport of NOx and SO 2 that contribute significantly to nonattainment and interfere with maintenance of the 8

- hour

ozone and PM 2.5 NAAQS. The EGUs in Pennsylvania will be regulated under the FIP until the EPA approves a SIP revision for the implementation of CAIR for th e affected EGUs, at which point the approved CAIR SIP revision will supersede the FIP requirements in Pennsylvania. The Pennsylvania CAIR regulation was published in the Pennsylvania

Bulletin on April 12, 2008. (38 Pa.B. 1705). The Department submitted th e SIP revision to26

the EPA on May 23, 2008. EPA subsequently proposed approval of the Commonwealth’s

CAIR SIP Revision on Septem ber 24, 2009 (74 FR 48695).

Interstate Pollution Transport Reduction

-- In response to the f ederal NOx SIP call rule, Pennsylva nia and other covered states adopted NOx control regulations for large industrial boilers and internal combustion engines, EGUs , and cement plants. The regulation covering industrial boilers and electric generators required emission reductions to

commence May 1, 2003, while the regulation covering large internal combustion engines and cement plants required emission reductions to commence May 1, 2005. The EPA approved th ese regulation s , found in 25 Pa. Code Chapter 145, on August 21, 2001 (66 F R

43 795) an d September 29, 2006 ( 71 F R 57428).

New Source Review Program s

. The federal N ew S o urce R eview (NSR) program s are preconstruction review and permitting program s applicable to new or modified major stationary sources subject to Title I, Parts C and D of t he federal CAA. The program s consist of the P revention of S ignificant D eterioration (PSD) requirements, which are applicable in areas attaining the NAAQS

, and the Nonattainment NSR requirements

, which are applicable in geographic areas not attaining and m aintaining the NAAQS.

The Department’s PSD regulations , codified in 25 Pa.Code Chapter 127, Subchapter D,

were approved by the EPA on August 21, 1984 and codified at 40 CFR § 52.2058 (49 F R 33128) . The federal PSD regulations codif i ed in 40 CFR Part 52 are incorporated by reference in their entirety in 25 Pa. Code § 127.83 (relating to adoption by reference). The PSD program requires any new source to implement Best Available Control Technology (BACT) and limits a new source's allowable impact on the e nvironment.

The EPA granted “ limited ” approval of the Department’s revised NSR regulations codified in 25 Pa.Code Chapter 127, Subchapter E, and published a final rule on December 7, 1997 ( 62 F R 64722 ). On October 19, 2001

, the EPA converted the limited approval to a “ full ” approval for all areas of the Commonwealth except the five

- county Philadelphia area (Bucks, Chester, Delaware, Montgomery, and Philadelphia counties) ( 66 F R 53904 )

. N onattainment NSR requirements include compliance with the lowest achievable emission

rate and emission offsets.

These federally enforceable programs, inco r porated in the Commonwealth’s SIP,

will also reduce emissions to provide continued improvements.

Federal Standards for Hazardous Air Pollutants. Federal standards to control hazardous air pollutants (HAPs) require Maximum Achievable Control Technology (MACT) at units located at major source s of HAPs. The EPA has issued a series of regulations that are applicable to sources in Pennsylvania. These MACT standards are adopted and incorporated by reference in Section 6.6 of Pennsylvania’s Air Pollution

Control Act and implementing regulations and are also included in federally enforceable permits issued by the Department for affected sources. Controls with a 2002 compliance date and earlier are included in the base year inventory for 2002, while controls with a27

com pliance date of 2003 and later are included in the projection inventories. A list of the categories for which federal MACT standards have been issued is contained in Appendix

D

- 1

.

Source Surveillance. Pursuant to 40 CFR Part 51, Subpart K ( relating to s ource

s urveillance )

, the SIP revision is required to provide for monitoring of the status of compliance with any rules and regulations that set forth any portion of the control strategy. These include provisions, as applicable, for:

emissions reports and recordkeeping for stationary sources; periodic testing and inspection of stationary sources; enforcement and complaint investigation of visible emission limitations;
enforceable test methods for emission limits; and continuous emission monitoring for stat ionary sources.

Subpart K also requires monitoring of the implementation of transportation control measures (TCMs). T here are no TCMs in this SIP.

After review, the Department finds that the rules and regulations for stationary sources

, which are part of the control strategy for attaining the PM 2.5 standard

, as well as the Department’s comprehensive permitting program requirements in 25 Pa. Code Chapter 127

and the Commonwealth’s SIP in 40 CFR 52.2020

, meet the requirements of Subpart K.

2 . Highway Vehicle Sources

Even with increases in 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 stand ards, the fleet as a whole emits fewer emissions, compensating for the incr ease in vehicle miles traveled. These

decreases can be attributed to the programs described below.

Federal Motor Vehicle Control Programs (FMVCP) and Pennsylvania Clean Vehicle

P rogram for passenger vehicles and light

- duty trucks and cleaner gasoline.

Tier 1 tailpipe standards established by the CAA Amendments of 1990 include NOx and VOC limits for light

- duty gasoline vehicles (LDGVs) and light

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

- powered cars starting with M odel Y ear (MY) 1998.

In 1998, under the authority of section 177 of the CAA, the Department adopted the Pennsylvania Clean Vehicles Pro gram (28 Pa. B. 5873, Dec. 5, 1998)

. The Pennsylvania Clean Vehicles Program incorporates by reference 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

. T he regulation does not incorporate by reference the28

California zero emissions vehicle (ZEV) or emissions control warranty systems statement provisions.

In the same rulem aking, the Department adopted the National Low Emission Vehicle (NLEV) 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 comply with NLEV instead of the CA LEV program through MY 2005. These regulations affected vehicles 6,000 pounds and less and were t he regulations in effect for new motor vehicles in the baseline year, 2002.

In 1999, the EPA promulgated regulations more stringent than NLEV (Tier 2), starting with MY 2004. In order to participate in NLEV, Pennsylvania had been required to adopt langu age that extended its “commitment” to NLEV until MY 2006. In practical terms, the NLEV program was replaced for MY 2004 and later by the more stringent Federal “Tier 2” vehicle emissions regulations, 65 F R 6698 (Feb. 10, 2000), and vehicle manufacturers

o perating 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 incorp orate the California Low Emission Vehicle Program (CA LEV II) 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 years were estimated bas ed 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 MOBILE6.2 for Emissions Inventory Preparation published by the EPA’s OTAQ in January 2002. This m ethodology is further explained in Appendix E. The Department is assuming in its MOBILE modeling that the federal Tier 2 program applies to subject vehicles sold in Pennsylvania from MY 2004 through MY 2007 and the Pennsylvania Clean Vehicles Program appl ies to subject vehicles sold in MY 2008 and beyond.

Heavy

- Duty Diesel Control Programs. The EPA promulgated 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 engines made by these companies comply with these 2004 standards two model years early, in MY 2002. Pennsylvania includes these programs as provided in the MOBILE model.

In 2002, the Department adopted the Heavy

- Duty Diesel Emissions Control Program for model years starting after May 2004. The program incorporates California standards by reference and requires MY 2005 and subsequent new heavy

- duty diesel highway engines to be those certified by California. California standards we re more stringent than federal standards for the two model years between expiration of the consent decrees discussed29

above and the implementation of more stringent federal standar ds affecting MY 2007 and beyond. However, EPA ’s MOBILE model already assumes that the engines would comply with consent decree standards, even without an enforcement mechanism. The Department has used MOBILE defaults to calculate emissions from MY 2005 a nd 2006 highway engines.

The EPA adopted new emission standards for heavy

- duty engines and vehicles for MY 2007 and subsequent. For diesel engines, the standards will be phased in from 2007 to

2010 for NOx and VOCs. For gasoline engines, the standards w ill be phased in during

MY 2008 and 2009. Federal and California standards are virtually identical for MY 2007.

For MY 2008, California adopted requirements for idling restriction engine programming and an option al “clean NOx idle” standard. However, th ere is no EPA

- approved methodology to estimate emission reductions from this requirement. Therefore, the emission estimates use assumptions of the federal rule for MY 2007 through 2010

.

Because the new engine standards are adversely affected by sulfur in fuel, the EPA also requires most highway diesel fuel to contain no more than 15 parts per million (ppm) of

sulfur , beginning in the fall of 2006. There is a temporary compliance option allowing refiners to continue to produce up to 20 percent of their hig hway diesel fuel at 500 ppm

fuel until 2010. The Department u ses MOBILE defaults to estimate the effects of the phase

- in provision.

Vehicle Emission Inspection/Maintenance Program. In early 2004, Pennsylvania

revised the implementation of its Vehicle Em ission Inspection/Maintenance (I/M) Program in the four applicable counties (Allegheny, Beaver, Washington, Westmoreland) in the Pittsburgh

- Beaver Valley Area . The program applies to gasoline

- powered vehicles 9,000 pounds and under, MY 1975 and newer. Fo r 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 two

- speed idle test, visual inspection of pollution control de vices to ensure they are present, connected and the proper type 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 be found in 67 Pa.

Code Chapter 177. Pennsylvania submitted the revised emissions program as a SIP revision on December 1, 2003. The EPA approved the SIP revision on October 6, 2005. (70 FR 58313)

.

Low sulfur gasoline. Simultaneously with the Tier 2 program, the EPA published 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. Th e emission reduction analysis uses the default

as sumptions provided in MOBILE6 to account for the implementation of the federal sulfur

standard rule.

Diesel Vehicle Idling Restrictions. On October 9, 2008, Governor Rendell signed the

Diesel

- Powered Commercial Motor Vehicle Idling Act (Act 124 of 200 8). Act 124 of

2008 went into effect on February 6, 2009. This Act restricts subject drivers and owners30

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 minut es 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. Act 124 of 2008 specifically e xcludes some vehicles

, such as motor homes and farm vehicles used in farm applications. Additional exemptions are allowed for certain vehicles being used in specific applications. Truck drivers may idle sleeper

- berth equipped vehicles for the purposes of long duration travel rest if the temperature is extremely hot or cold. In May 2010, this temperature exemption expires. A properly

labeled “low

- NOx idle” engine may idle for an unlimited amount of time.

Act 124 of 2008 will be enforced by Department p ersonnel, and by state and local law enforcement personnel. The law preempts and supersedes local ordinances

, although rules in Allegheny County and Philadelphia County that are determined by those counties to be more stringent than the law may remain in effect. The Department estimates that 50 percent of all long duration idling for Class 8 trucks will be eliminated in 2010 when the temperature exemption for sleeper rest expires. Statewide emission reductions are estimated to be 1610 tons, 45 tons and 3 0 tons per year for NOx, VOC, and PM 2.5 , respectively. Emission reductions expected from this strategy are not included in the projected emissions inventory for 2009 since a period of compliance assistance and education is expected during that year Act 124 of 2008 will be submitted to EPA for approval as a revision to the Commonwealth’s SIP by the end of 2009.

3 . Nonroad Sources

The EPA has adopted a series of regulations affecting new diesel

- powered (“compression ignition”) and gasoline

- powered (“s park ignition”) nonroad engines of various sizes (horsepower) and applications. Information on these federal rules, including their implementation dates, can be found at www.epa.gov/nonroad. The Department used the assumptions built into the nonroad model (NONROAD2005) to estimate emissions for all milestone years.

No new national or international regulations are expected to be applicable to aircraft by the

attainment date. While the EPA has published a notice of proposed rulemaking for more stringent st andards for locomotives and large commercial marine diesel engines, the agency has not finalized any new standards.

The EPA will also require diesel fuel used in most nonroad applications to contain less sulfur. The sulfur will prevent damage to the more advanced emission control systems needed to meet the engine standards; it will also reduce fine particulate emissions from diesel engines. In 2007, fuel sulfur levels were limited to 500 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.31

B. Reasonably Available Control Measures/R easona bl y Available Control

Tech nology Analysis

Section 172(c) of the CAA requires states to “provide for implementation of all reasonably available control measures (RACM) as expeditiously as practicable.” T he regulatory requirement for RACM and reasonably available control technology (RACT) for PM 2.5 SIP

revisions is codified in 40 CFR 51.1010 : “For each PM 2.5 nonattainment area, the s tate shall submit with the attainment demonstration a SIP revision demonstrating that it has adopted all reasonably available control measures (includi ng RACT for stationary sources) necessary to demonstrate attainment as expeditiously as practicable and to meet any RFP requirements.”

The EPA states in the Clean Air Fine Particle Im plementation R ule preamble that it encourages states to conduct multi

- po llutant analyses for PM 2.5 and ozone to cull out potential RACM:

“They can also try to use consistent meteorological fields and emissions inventories so that the same control strategies are relatively easy to evaluate for both ozone and PM 2.5

. Modeling the same future year(s) for PM 2.5 and ozone can also make it easier to evaluate the impacts of controls on both pollutants. It should be noted that there are no specific modeling requirements other than the recommendation to try to harmonize the ozone,

PM 2.5 , and regional haze analyses whenever possible.” 7

The Commonwealth participated in two such collaborative process es with other states in the region. First, the OTC states formed a workgroup to identify and evaluate candidate

control measures. Worki ng from a preliminary list of approximately 1

, 000 potential control measures, t he workgroup identified and analyzed 30 candidate control measures. Appendi x G

- 1 contain s the OTC report entitled, Identification and Evaluation of Candidate Control Measures, Final Technical Support Document (MACTEC, Feb. 2007).

The initial list of control measures considered is available as Appendix G

- 2. Based on the OTC Workgroup analysis, the Commissioners recommended that States consider emission

reductions from the follo wing source categories:

• Consumer Products

• Portable Fuel Containers

• Adhesives and Sealants Application

• Diesel Engine Chip Reflash

• Cutback and Emulsified Asphalt Paving

• Asphalt Production Plants

• Cement Kilns

• Glass Furnaces

• Industrial, Comm ercial, and Institutional (ICI) Boilers

• Regional Fuels

7

. 72 FR 20609.32

• Electric Generating Units (EGUs)

The final report, included as Appendix G

- 1

, contains more detailed information about the process and includes tables summarizing the emission reduction potential o f each control measure by source category and projection year. There are five subsections discussing the control measure and emission reductions for the five source category sectors: non

- EGU point sources, area sources, EGUs, onroad mobile sources, and non road mobile sources.

The Department also participated in an assessment of control measures for pollutants and sources affecting visibility through the MANE

- VU regional haze planning process. As part of this effort, MANE

- VU developed a list of possible c ontrol measures for consideration. The following categories were selected for analysis:

Coal and oil

- fired EGUs
Point and area source industrial, commercial and institutional boilers

Cement kilns

Lime kilns The use of heating oil

Residential wood combusti on and open burning

Appendix G

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

- VU Class I Areas (MACTEC, July 2007) from the MANE

- VU control measure assessment project. This report presents the results of an analysis of the economic and environmental impacts of the potential control scenarios that c ould be implemented by MANE

- VU s tates to reduce emissions from selected source categories in order to make reasonable progress toward meeting visibility improve ment goals.

As required under 40 CFR 51.1010

, a SIP revision for a PM 2.5 nonattainment area must
demonstrate that all RACM, including RACT for stationary sources, necessary to demonstrate attainment as expeditiously as practicable have been 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 tech nical and economic feasibility must be adopted as RACM if, considered collectively, they would

advance the attainment date by one year or more. As discuss ed earlier in this document,

the Pittsburgh

- Beaver Valley Area expects to monitor attainment at the e nd of 2009. Therefore, any RACM measures would need to be in effect in 2008.

The Department determined that there were no additional control measures that could be adopted by January 1, 2008. In addition, existing measures and th ose planned for implemen tation by 2009 are expected to enable the Pittsburgh

- Beaver Valley Area to attain

the 1997 PM 2.5 NAAQS. Therefore, no further actions on RACM or RACT are warranted.

Although the measures explored by the OTC and MANE

- VU workgroups are not required

as RACM , many are worthwhile measures that Pennsylvania is currently pursuing. Others are measures that Pennsylvania may consider for the future.33

C. Other Measures

- VOC Control Measures

Although VOC is not a regulated PM 2.5 precursor for the Pittsburgh

- Beav er Valley Area

, several VOC control measures are discussed in this section because they are included in the modeling associated with this attainment demonstration.

Portable Fuel Containers. The Department adopted a portable fuel container regulation,

2 5 Pa. Code Chapter 130, Subchapter A, to address VOC loss resulting from permeation through portable gasoline containers, evaporative loss through container openings, and spillage during the filling of small tanks on machines such as lawn mowers, chain saw s and jet skis. The regulation was submitted to the EPA as a SIP revision on March 26, 2003 and approved on December 8, 2004 (69 F R 70893).

Consumer Products. This regulation applies statewide to any person who sells, supplies, offers for sale, or manuf

actures certain consumer products on or after January 1, 2005, for use in the Commonwealth. The program is contained in 25 Pa. Code Chapter 130, Subchapter B. It was submitted to the EPA as a SIP revision on March 26, 2003 and approved on December 8, 200 4 (69 FR 70895). Additional regulations were adopted on October 11, 2008 and submitted to the EPA as a SIP revision on April 14, 2009

.

Architectural and Industrial Maintenance (AIM) Coatings . The Pennsylvania AIM Coatings regulation applies statewide to any person who supplies, sells, offers for sale, or manufactures, blends or repackages an AIM coating for use within the Commonwealth, as well as a person who applies or solicits the application of an AIM coating within the Commonwealth. The AIM coating program requirements are specified in 25 Pa. Code Chapter 130, Subchapter C. The regulation was submitted to the EPA as a SIP revision on December 3, 2003, with a supplement submitted on October 19, 2004. The EPA approved the provisions as an element of the SIP on November 23, 2004 (69 FR 69080).34

V. ATTAINMENT DEMON STRATION AND WEIGHT OF EVIDENCE (WOE)

A. Attainment Demonstration Background and Objectives

The EPA issued fine particle standards in 1997 after evaluating hundreds of health studies

and conducting an extensive peer review process. The 1997 annual health

- based standard

for PM 2.5 is 15.0 μg/m 3 , based on the 3

- year average of annual mean PM 2.5 concentrations.

The EPA also established a 24

- hour health

- based standard of 65 μg/m 3 , determined by the

3

- year average of the 98th percentile of 24

- hour concentrations. The EPA set levels to protect the environment at the same level s as it set the health

- based standards. Note that

w hile the EPA has subsequently revised the 24

- hour standard in 2006 to be more protective, EPA designated the Pittsburgh

- Beaver Valley Area as nonattainment because it

viol ated the 1997 annual standard of 15.0 μg/m3 based on 2001

- 03 monitoring data. Therefore, t his SIP revision compares air quality data to the 1997 24

- hour standard (65 μg/m 3 ).

On April 1, 2003, the EPA issued a memorandum , “Designations for the Fine Parti cle National Ambient Air Quality Standards” outlining the schedule for designating areas

under the PM 2.5 standard and related guidance on nine factors to consider in identifying

nonattainment areas. The CAA provides for states and tribes to submit designat ion

recommendations to the EPA , and it requires the EPA to provide time for consultation in cases where the Administrator plans to promulgate a designation that modifies the state or tribal recommendation. On December 17, 2004

, the EPA published its air q uality designations and classifications for the 1997 PM 2.5 NAAQS. These designations became effective on April 5, 2005.

Figure 4 graphically depicts all of the PM 2.5 nonattainment areas within Pennsylvania. The Pittsburgh

- Beaver Valley Area currently vi olates the EPA ’s annual PM 2.5 standard (15.0 μg/m 3 ). The maximum 2008 annual design value in the area is 15. 5 μg/m 3

. All monitors

within the Pittsburgh

- Beaver Valley Area are currently in attainment of the 1997 24

- hour

PM 2.5 standard (65 μg/m 3 ). The maximum 200 8 24

- hour design valu e in the area is 40 μg/m 3

. The Pittsburgh

- Beaver Valley Area is required to attain the PM 2.5 standard no later than five years from the effective date of designation of April 5, 2005 (April, 2010).

Th e 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 complex grid model was run and processed over the entire

Northeast to determine if the Pittsburgh

- Beaver Valley Area would attain the PM 2.5 standard by April 5, 2010.

The procedures followed in this modeling analysis are in accordance with EPA ’s Guidance

on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regi onal Haze (EPA

- 454/B

- 07

- 002, April 2007). A brief summary of the modeling analysis used in this demonstration is included in the following sections. The Department submitted a modeling protocol to the EPA in October 2007 for35

the Pittsburgh

- Beaver Valley Area that includes a more thorough description of th e modeling analysis

.

Figure 4 : Pennsylvania’s PM 2.5 Nonattainment Areas

B

. Pittsb urgh

- Beaver Valley Area Conceptual Model Description

This section provides a brief description of the conceptual model for the Pittsburgh

- Beaver Valley Area

. The conceptual model 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 the Department’s modeling protocol documentation ( October 2007).36

Fine particulate formation in the east ern U nited States is a complex process involving local and regional meteorology, topography, chemistry and transport. Since a violation of an annual standard potentially involves a large range of conditions throughout the year, it i s difficult to determine a direct cause

- and

- effect relationship for such a violation. Violations of the annual standard ensure a large range of conditions will contribute to nonattainment making direct cause

- and

- effect relationship s difficult to determine

. In general

, the following statements can be used to provide a working conceptual model that describes the

annual PM 2.5 nonattainment problem in the Pittsburgh

- Beaver Valley Area :

Secondary fine particulate formation is a major contributor to annual PM 2. 5 nonattainment in the Pittsburgh

- Beaver Valley Area . Sulfates, o rganic c arbon and

n itrates make u p approximately 75 % of the annual fine

- particulate concentrations ( see Figure 5 )

. Fine

- particulate chemistry favors sulfate formation during the warm summer months and nitrate formation during the colder winter months.

In the summer time

, large high pressure systems create favorable conditions for the

oxidation of SO 2 , which eventually form s sulfates. These sulfates then contribute to episodes of high particu late concentrations.

In the winter time, local temperature inversions concentrate emissions near the surface leading to periods of elevated fine

- particulate concentrations. This is especially apparent if significant terrain features are present.

Continuou s measurements in the Pittsburgh

- Beaver Valley Area correlate well with

the FRM data . This indicat e s measurements from the conti nuous monitor generally

reflect actual concentrati ons in the nonattainment area. Average concentrations from the continuous mon itor show a general diurnal pattern with higher concentrations in the overnight and early morning hours than during the day due to atmospheric conditions and possibly local mobile source emissions (peaks during rush hour traffic, etc)

. In addition to th e d iurnal signal noted in the continuous monitoring data there is a strong weekly pattern in the continuous monitoring data with higher PM 2.5 concentrations on weekdays than on weekends

.

A range of control measures will be necessary to attain the PM 2.5 stand ard in the Pittsburgh

- Beaver Valley Area due to the complex interaction between local and regional

emissions and local meteorological conditions. Sulfates and nitrates are formed primarily through atmospheric reactions of precursor emissions of SO 2 , NOx a nd NH 3 . Organic

carbon is a combination of secondary organic particles formed from emissions of VOC and

the organic portion of primary PM 2.5 that is directly emitted or condenses near its source. Currently

, our understanding of sulfate and nitrate chemis try and its impacts on PM 2.5 concentrations far exceeds our understanding of contributions from anthropogenic VOC s. This is important because sulfates, nitrate s and organic carbon are major contributors to the

fine particulate problem in the Pittsburgh

- Be aver Valley Area

. T herefore

, it is reasonable

to assume that a mixture of regional and local SO 2 and NOx controls in addition to VOC

controls implemented for attainment of the 8

- hour ozone standard will assist in attain ing

the PM 2.5 standard.37 Figure 5 : Pittsburgh

- Beaver Valley Area Percentage of Total Mass Based on Speciated PM 2.5 Data Collected at Lawrenceville Averaged 2005 to 2007 Monitored Values

C

. Modeling Domain and Photochemical Modeling System

The modeling demonstration for the Pittsburgh

- Beaver Valley Area relies heavily on the OTC SIP quality

- modeling platform. Ozone modeling was the primary focus of this effort.

OTC ’s interaction with MANE

- VU and NESCAUM allowed it, through the regional modeling centers, to do additional year

- round mo deling for PM 2.5 and Regional Haze.

EPA ’s Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (EPA

- 454/B

- 07

- 002, April 2007) does not recommend a particular model or models for use in a SIP attainment demonstration. The OTC modeling committee used the CMAQ photochemical grid model (version 4.5) as part of its SIP modeling platform (OTC Final Modeling Protocol, 2006). CMAQ is an Eulerian grid model capable of simulating air pollutant concentrations in the atmosphere using mathematical equations to characterize chemical and physical properties

.

Meteorological and emission input files must be prepared regardless of which photochemical grid model is used. The regional fine pa rticulate modeling analysis

encompass ed an entire year of simulation for the year 2002 . This approach provided a good variety of episodes to characterize the Pittsburgh

- Beaver Valley Area ’s PM 2.5 nonattainment problem

.

Figure 6 shows the modeling domain used by the OTC Modeling Workgroup . A nested

grid approach wa s used with the lower resolution outer grid providing boundary conditions38

for a more refined grid covering the area of interest. The modeling domain was chosen to be large enough to properly si mulate regional transport. The outer domain boundary is far enough from the inner grid’s boundary so that clean

- boundary condition assumptions along the outer domain’s boundary are realistic and probably do not unduly influence

concentrations within the i nner domain.

Figure 6 . OTC Modeling Study Domain

Outer grid at 36

- kilometer resolution, inner grid at 12

- kilometer resolution

The meteorological files used in CMAQ were produced using the Pennsylvania State University/National Center for Atmospheric Re search ( PSU /NCAR) Mesoscale M odel

version 5 ( MM5 ) . MM5 is a limited

- area, nonhydrostatic, terrain

- following sigma

coordinate model designed to simulate or predict mesoscale atmospheric circulation. The model is publicly available and has been used for va rious air quality modeling studies in the past

.

The OTC Modeling Committee also examined two emissions processors (EMS2001 and SMOKE, both using CB4 chemistry) in its prior work and concluded that there are

differences between them that could be minimized by forcing the models to use a common speciation and surrogate database.

For areas with an attainment date of no later than April 5, 2010 for the PM 2.5 NAAQS, the emission reductions need to be implemented no later than the beginning of 2009. A

determin ation of attainment will be based on air quality monitoring data collected in 2007, 2008, and 2009. Therefore, the year to project future emissions should be no later than the last year of t he three

- year monitoring period, which in this case is 2009.

The emissions inventory was developed for 2009 using standard emissions projection techniques. The 2009 inventories developed by MANE

- VU were used in the attainment39

demonstration. The most recently available inventories from other regional planning organiza tions ( RPOs ) in the modeling domain were also used.

Emission inventory guidance documents were followed for developing projection year inventories for point, area, mobile, and biogenic emissions. These procedures address projections of spatial, temporal, and chemical composition change between the base year and projection year.

The control strategies developed for evaluation in the attainment demonstration were selected by the OTC’s Control Strategy Committee. These were selected from groups of strategi es developed by the technical subcommittees responsible for identifying and developing the regulations and/or other control measures.

Consideration was given to maintaining consistency with control measures likely to be implemented by other modeling domai ns that may be involved in region

- wide analysis. Also, technology

- based emission reduction requirements mandated by the CAA are included in the future year model runs.

D. Model Performance Evaluation

A critical component of every air quality modelin g study is the model performance evaluation where modeled estimates for the current year base case are compared against observed values to assess the model’s accuracy and provide an indication of its reliability. The results presented here serve as an ill ustration of some of the model evaluation and assessment, as outlined in the EPA modeling guidance document entitled

, Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for
Ozone, PM

2.5 , and Regional Haze (EP A

- 454/B

- 07

- 002, April 2007), performed on the Base Year 2002 CMAQ simulation.

The New York State Department of Environmental Conservation ( DEC ) , Division of Air Resources, conducted a performance evaluation of the 2002 base case CMAQ simulation

on behalf of the OTC member s tates. Model performance was evaluated over the entire year, except for the July 6

- 9, 2002 period which was excluded from this analysis since the

observed PM 2.5 and organic mass ( OM ) data at many sites were greatly affected by

Canadian forest fires. Appendix H , relating to Modeling Demonstration, provides comprehensive operational and diagnostic evaluation results. Highlights of this evaluation are provided in the following sections. The analysis examines model performance over a

wide area, including the entire O TR plus the S tate of Virginia (OTR+)

.

1. Daily PM 2.5 Mass

Model performance over the entire OTR+ region was examined using several statistics.

These included overall mean fractionalized bias (MFB) and mean fractional error ( MFE)

. Equations for these diagnostic s are summarized below and are included in the EPA modeling guidance document entitled

, Guidance on the Use of Models and Other Analyses40

for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional H

aze (EPA

- 454/B

- 07

- 002, April 2007)

.

Mean fractionalized bias (MFB), in %:

Mean fractional error (MFE), in %:

where P = Predicted (modeled) value, O = Observed value, and N = Number of observations

Figures 7 and 8 show MFE and MFB over the entire OTC+ region. The figures indicate the model is generally doing a reasonable job reproducing PM 2.5 across the entire domain with the exception of the New York City area and a few monitors in New England.

O verall, the mean bias (predicted minus observed) was about 3.8 g m - 3 , ranging from

- 17.7 g m - 3 to +24.0 g m - 3 . The highest over

- prediction tended to occur during the colder months, quarters 1 and 4, whereas the days on which the model tended to und er

- predict

PM 2.5 were more likely to occur during the summer months.

Figure 7: Mean Fractional Error

MFE ( %) at each FRM location over the entire year: blue, <30%; green, 30

- 45%; orange,

45

- 60%; red, 60

- 75%; pink, >75% (From NY DEQ report, 2007).41 Fig ure 8 : Mean Fractional Bias

MFB ( %) at each FRM location over the entire year: gray, <

- 45%; blue,

- 45 to

- 15%;

green,

- 15 to 15%; orange, 15

- 45%; red, 45

- 75%; pink, >75% (From NY DEQ report

, 2007 )

.

2. PM 2.5 Speciation

PM 2.5 is composed of several components. The primary components noted in the monitoring data include sulfates, nitrates and organic carbon; other components do not significantly contribute to PM 2.5 concentrations. For proper performance, CMAQ predictions for each individual componen t of PM 2.5 must also be examined.

Data from the various speciation networks in the OTR+ region were compared to model predicted values for the base case (2002). Again

, data from the July 6

- 9, 2002 period was excluded from this analysis due to the Canadi an forest fires.

Sulfates (SO 4 - ) are one of the primary contributors to the Pittsburgh

- Beaver Valley Area ’s

PM 2.5 nonattainment. Figure 11 depicts modeled and actual sulfate measurements in the OTR+ region. The CMAQ model appears to reproduce actual sul fate concentrations quite well along with its seasonal variability.

Nitrates (NO 3 - ) are another important contributor to the Pittsburgh

- Beaver Valley Area ’s

PM 2.5 nonattainment. CMAQ does less well reproducing actual concentrations than it d oes for sulfa tes . Modeled concentrations appear to be less accurate during the colder months (1 st and 4 th quarters) than the warmer months

.42

OM is another important contributor to the Pittsburgh

- Beaver Valley Area ’s PM 2.5 nonattainment. CMAQ does not do well reproduc ing the seasonal variability of OM though it does appear to do a better job reproducing observed winter values.

Figure 9 : Time Series of SO 4 Mass

Time series of SO 4 mass based on the composite average of all 21 IMPROVE monitors across the OTR+ region. The observed values are denoted with the black diamonds, the model predictions are denoted with gray squares (From NY DEQ report , 2007 ).

NY DE Q ’s model performance included an analysis of the meteorological model used to drive CMAQ

, as well as actual PM 2.5 values and PM 2.5 ’s speciated components. Appendix

H

- 2 is a technical listing of the model input s , as well as an assessment of the MM5

simulation to real

- world data. The analys i s shows that

, in general, the performance of the

MM5 is reasonable both at the surface and in the vertical, thereby providing confidence in the use of these data in the CMAQ simulations.

Both the MM5 and CMAQ runs appear to meet performance criteria over the entire OTR+ domain. Therefore, it can be assumed the modeling plat form provide s meaningful information in regard to projected 2009 PM 2.5 concentrations that will be used to assess the Pittsburgh

- Beaver Valley Area ’s future attainment of the PM 2.5 standard.43

E . Projected 2009 Design Value s for the Pittsburgh

– Beaver V alley Nonattainment

Area

1

. Overview

As mentioned previously , the Pittsburgh

- Beaver Valley Area has an attainment date of April 5, 2010. The PM 2.5 NAAQS include an annual standard of 15 .0 μg/m 3 based on the

3

- year average of annual mean PM 2.5 concentrat ions, and a 24

- hour standard of 65 μg/m 3

based on the 3

- year average of the 98th percentile of 24

- hour concentrations.

This section summarizes the procedures that are used to demonstrate attainment of the

PM 2.5 NAAQS. As described in EPA’s Guidance on th e Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (EPA

- 454/B

- 07

- 002, April 2007), an attainment demonstration consists of (a) analyses that estimate whether selected emissions reduction s will result in ambient concentrations that meet the NAAQS, and (b) an identified set of control measures that will result in the required emissions reductions. The necessary emission reductions for both of these attainment demonstration components may b e determined by relying on results obtained with air quality models.

EPA ’s Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (EPA

- 454/B

- 07

- 002, April 2007) recommends app lying a modeled attainment test to the air quality modeling results

to determine if the PM 2.5 NAAQS will be met. Additional technical or corroboratory analyses may also be used as part of a “supplemental analysis” or a more stringent “weight

of evidence” determination to supplement the modeled attainment test and to further support a demonstration of attainment of the NAAQS.

The modeled attainment test and additional corroborative analyses are described in further detail in the remaining portions of this section.

2. Model ed Attainment Test

The purpose of a modeling assessment is to determine if control strategies currently being implemented “on the books” (OTB ) and proposed control strategies will lead to attainment of the NAAQS for PM 2.5 by the attainm ent year of 2009. The modeling is applied in a relative sense, similar to the 8

- hour ozone attainment test : h owever, t he PM 2.5 attainment test is more complicated and reflects the fact that PM 2.5 is a combination of many different species. In the test, a mbient PM 2.5 is divided into major components . Then, a relative response factor (RRF) and future design value (DVF) is 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). The following sections outline the process to determine that 2009 projections of PM 2.5 will meet the NAAQS from regional modeling, as suggested in EPA’s modeling guidance.44

3. Determine Baseline Design Values

The first step in any attainment test process is to determine the baseline design value (DVB). The EPA guidance recommends using a DVB that is the average of the three design value periods that straddle the baseline inventory year (i.e., the average of the 2000

- 2002, 2001

- 2003, and 2002

- 2004 design value periods for a 2002 baseline inventory year).

This results in a 5

- year weighted average, with the baseline year having the heaviest weight (i.e., {[2000] + 2*[2001] + 3*[2002] + 2* [2003] + [2004]}/9).

For the SMAT process, a mean PM 2.5 DVB is determined, as well as component specific

DVB

, for each quarter. The following section will detail the calculation of baseline design

values needed for the PM 2.5 attainment test.

Mean PM

2. 5 Baseline Design Values

To begin the SMAT process, a mean PM 2.5 DVB is calculated on a quarterly basis for each

FRM monitor in the PM 2.5 nonattainment areas. Concentrations are calculated based on calendar quarters (Q1: January

- March; Q2: April

- June ; etc.) as the NAAQS is calculated for a calendar year, and the quarters need to fit evenly within a year. C alculating the attainment test on a quarterly basis also allows states to examine the differences in PM 2.5 composition that occur during the differ ent seasons.

Speciated Baseline Conditions

The monitored attainment test for PM 2.5 utilizes both PM 2.5 and individual PM 2.5 component species. A separate RRF is calculated for each PM 2.5 species. In order to perform the

recommended modeled attainment tes t, s tates should divide observed mass concentrations

of PM 2.5 into seven components (plus passive mass):

1. Mass associated with sulfates (SO4)

2. Mass associated with nitrates (NO3)

3. Mass associated with ammonium (NH4)

4. Mass associated with organic carbon (OC)

5. M ass associated with elemental carbon (EC)

6. Mass associated with particle bound water (PBW)

7. Mass associated with “other” primary inorganic particulate matter (Crustal)

8. P assively collected mass or the mass of the blank filter (Passive)

This yields the follow ing formula in order to calculate PM 2.5 :

PM2.5 FRM = [SO4] + [NO3] + [OC] + [EC] + [NH4] + [PBW] + [Crustal] + [Passive]

The second part of the process is to use the quarterly mean PM 2.5 DVBs with speciated data to calculate the quarterly mean concentrati ons of these 7 components at the FRM sites. This need to speciate the FRM data presents two issues:45

1. FRM measurements and speciated PM 2.5 measurements do not always measure the

same mass. 2. Not all FRM monitoring sites have co

- located Speciation Trends Ne twork ( STN ) speciation monitors.

The following sections will explain how these issues are addressed to produce the speciated values needed for this attainment demonstration.

SANDWICH

As the EPA ’s Guidance on the Use of Models and Other Analyses for Dem onstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (EPA

- 454/B

- 07

- 002, April 2007) notes, recent data analyses have noted that the FRM monitors do not measure the same components and do not retain all of the PM 2.5 that is measure d by STN samplers . T herefore

, measurements from FRM monitors cannot be directly compared to speciation measurements from the STN monitors

. By design, the FRM mass measurement

does not retain all ammonium nitrate and other semi

- volatile materials (negativ e sampling artifacts) and includes particle bound water associated with sulfates, nitrates and other hygroscopic species (positive sampling artifacts). This results in concentrations (and percent contributions to PM 2.5 mass) that may be different from the ambient levels of some

PM 2.5 chemical constituents.

To resolve the differences between FRM and STN total mass, EPA recommends using the “sulfate, adjusted nitrate, derived water, inferred carbonaceous ” (SANDWICH) material balance approach

. With the SA NDWICH approach, nitrate mass is adjusted to account for volatilization based on hourly meteorology parameters. Subsequently, quarterly average nitrate, sulfate, elemental carbon, ammonium a nd crustal mass can be calculated, as well as the Degree of Neutr alization (DON) of sulfates. Next

, the mass of particle bound water can be calculated from the previously obtained DON, sulfate, nitrate, and ammonium values. ( See more details on particle bound water calculations in the Annual SMAT

Results section

, belo w). Finally, organic carbon is calculated by taking the difference

between the total PM 2.5 mass as measured at the FRM monitor, and the calculated component mass (i.e., OC from mass balance ([OCMmb] = PM2.5 FRM - {[EC] + [SO4] + [NO3] + [NH4] + [PBW ] + [ Crustal ] + [ Passive ]}), where the Passive (mass) is the FRM sampling artifact normally set equal to 0.5 )

.

EPA Region 3 office provided SANDWICHed data for the Pittsburgh

- Beaver Valley Area

monitor s . For a description and use of the SANDWICH method

, see t he Definition of

SANDWICHed STN Data (EPA, 2006)

.

Speciated Profiles

While the SANDWICH method reconciles the differences between FRM and STN, a lingering issue is that not all FRM monitoring sites have co

- located STN monitors to provide speciated data. EPA guidance suggests four measures that can be taken to resolve the lack of speciated data:46

1. Use of concurrent data from a nearby speciated monitor

2. Use of representative data (from a different time period)

3. Use of interpolation techniques to create a spa tial field using ambient speciation

data

4. Use of interpolation techniques to create spatial fields, and gridded modeling outputs to adjust the species concentrations

Of the four methodologies, EPA recommends using one of the spatial interpolation technique s to estimate species concentrations at FRM sites that do not have speciation data (numbers 3 and 4

, above). To assist in this task, EPA began developing a software tool called “Modeled Attainment Test Software” (or MATS) that would perform the spatial

an alysis of described options number 3 and 4. However, the MATS tool was not available at the time this analysis was completed. In trying to pursue the EPA recommended course of action, opt ion 1 ( use of concurrent data from a nearby speciated monitor ) was utilized.

4. Relative Response Factor Calculations

The calculation of RRFs for this study was performed using the EPA recommended method for “nearby” grid cells for a 12

- kilometer horizontal grid resolution, with a 3x3 grid cell array for 12

- km resolu tion modeling. The relative response factor used in the modeled attainment test is computed by taking the ratio of the mean of the predictions in the future to the mean predictions with baseline emissions, over all relevant days.

For the 24

- hour and annu al PM 2.5 NAAQS, the spatially averaged value of the nearby predictions (mean value of the grid cell array) was used. Each component

- specific RRF was used in the modeled attainment test by taking the ratio of the mean of the spatially averaged daily predict ions in the future to the mean of the spatially averaged daily predictions with current emissions.

The basis for this approach is as follows:

1. Consequence of a control strategy may be “migration” of a predicted peak. If a

s tate were to confine its attenti on only to the cell containing a monitor, it might underestimate the RRF (i.e., overestimate the effects of a control strategy).

2. Uncertainty in the formulation of the model and the model inputs is consistent with recognizing some leeway in the precision of the predicted location of

concentrations.

3. Standard practice in defining a gridded modeling domain is to start in the southwest corner of the domain and determine grid cell location from there. Considering

several cells “near” a monitor rather than the sin gle cell containing the monitor diminishes the likelihood of inappropriate results that may occur from the geometry of the superimposed grid system.

4. The area does not exhibit strong spatial concentration gradients of observed primary PM 2.5

.47

5. Annual S MAT Results

A difficulty presented in estimating the future design values was missing STN data for

2000 and 2001at the Pittsburgh

- Beaver Valley Area monitor s . This limitation restricted

the calculation of SANDWICH data to the period 2002

– 2004. Therefore , the 2009 projected design values are based on speciation profiles developed using 2002

- 2004 STN

data

. Appendix H

- 7 contains a sample Excel spreadsheet showing the calculations utilized to compute the 2009 DVF (displayed in Table V

- 2).

There are three F RM monitors in the Pittsburgh nonattainment area that are co

- located with a speciated sampler: Florence, Greensburg, and Lawrenceville. However, since there

are eleven FRM monitor s within the Pittsburgh

- Beaver Valley Area

, the Department was

able to deter mine that the three speciated monitors in the nonattainment area were representative of all FRM monitor locations in order to complete the SMAT analysis. RRFs were only calculated for the sulfates, nitrates, organic carbon, elemental carbon and

crustal co mponent of PM 2.5 . Referencing the PM 2.5 FRM formula in section 3 above, the only components of PM 2.5 that were not included in the RRF calculation were ammonium

and wa ter. Base and f

uture case ammonium was calculated based on the DON value and

the follow ing formula presented in EPA’s Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze :

NH4 = 0.29 * NO3 + DON * SO4.

The particle bound water w as then calculated using the p article bound water formula

estimated fr om the Aerosol Inorganic Model . Due to the hygroscopic nature of ammonium sulfate and ammonium nitrate, retained sulfate, nitrate and ammonium will all contain water. Therefore, the final polynomial equation (seen below and referenced (EPA, 200 6 (2) ) ) contains sulfates, nitrates and ammonium within its calculation. The equation utilized was that for low acidity.

PBW = [202049.0

– 391494.6 * S

– 390912.1 * N + 442.4 * (S^1.5)

– 155.3 * (N^1.5)

- 293406.8 * (A^1.5) + 189277.5 * (S^2) + 377992.6 * N * S + 188636.8 * (N^2)

– 447.1 * (S^2.5)

– 507.2 * (S^1.5) * N

– 12.8 * (S^3) + 146.2 * (N^1.5) * S + 217.2 * (N^2.5) + 30.0 * (N^1.5) * (S^1.5)

– 18.6 * (N^3) + 216267.0 * (A^1.5) * S + 215419.9 * (A^1.5) * N

– 621.8 * (A^1.5) * (S^1.5) + 239.1 * (A^1.5) * (N^1.5)

+ 35413.1 * (A^3)] * (SO4 + NO3+ NH4)

where S = SO4 / (SO4 + NO3 + NH4) N = NO3 / (SO4 + NO3 + NH4) A = NH4 / (SO4 + NO3 + NH4)

Table V

- 1 displays the calculated quarterly RRFs for the design monitor of the Pittsburgh

Beaver Valley Area , North Braddock . Based on the results of the RRF calculations, all48

PM 2.5 constituents either remain the same or undergo a downward trend

, except for the crustal portion.

Table V

- 1 : Annual PM 2.5 Quarterly RRF Values

Quart er Sulfates Nitrates OC EC Crustal

1 st 0.9485 0.9806 0.9564 0.8426 1.1254

2 nd 0.7098 0.9081 1.0036 0.8456 1.2194

3 rd 0.6593 0.9179 0.9867 0.8405 1.2318

4 th 0.8942 0.9626 0.9966 0.8496 1.1628

Table V

- 2 presents the results of the annual SMAT results f or all of the monitors in the Pittsburgh

- Beaver Valley Area . The SMAT results demonstrate that the projected average

annual arithmetic mean PM 2.5 concentration calculated at each FRM monitor attains the

annual PM 2.5 NAAQS. Specifically, all DVF calculatio ns are less than 15 .0 μg/m 3

. Table

V

- 2 presents the results of the annual SMAT results for a suite of regional modeling runs conducted by OTC

, with each modeling run representing “ On the Books, On the Way ” (OTB/OTW) control measures. All runs demonstrate compliance with the annual NAAQS.

Table V

- 2 : Annual SMAT Results for the Pittsburgh

- Beaver Valley Area 2009 On

The

- Books

- On

- The

- Way Control Measures

AIRS ID Site

Name County State 2000

- 2004 DVB 2009 Q1 Q2 Q3 Q4 DVF

420030008 Lawrenceville Allegheny PA 13.75 15.71 19.5 3 13.52 13.3

420030067 South Fayette Allegheny PA 10.89 13.27 17.34 11.20 11.3

420030093 N. Park Allegheny PA 11.90 14.74 18.00 11.07 11.8

420030095 Coraopolis Allegheny PA 12.41 15.63 17.83 11.74 12.2

420031008 Harrison Allegheny PA 14.25 16.60 19.51 13.02 13.5

420031301 N. Braddock Allegheny PA 15.07 16.64 20.49 14.81 14.3

420070014 Beaver Falls Beaver PA 14. 50 14. 93 20.32 13. 82 13. 6

421250005 Charleroi Washington PA 12. 59 16.60 20. 32 12.0 3 13.0

421250200 Washington Washington PA 12. 42 15. 12 19. 9 0 12. 08 12.7

421255001 Florence Washington PA 10.90 14.54 17. 82 10. 84 11.6

421290008 Greensburg Westmoreland PA 13. 53 15. 46 20.04 12.5 0 13.0

Source: 2000

- 2004 DVB q uarterly c oncentrations c alculated from data in Appendix A

- 2.49

6

. 24

- Hour SMAT Result s

As with obtaining the a nnual SMAT Results, a difficulty presented in estimating the future design values was missing STN data for 2000 and 2001 at all of the Pittsburgh monitors

. This limitation restricted the calculation of SANDWICH data to the period 2002

– 2004. Therefore, the 2009 projected design values are based on speciation profiles developed using 2002

- 2004 STN data. Appendix H

- 7 contains a sample Excel spreadsheet showing the calculations utilized to compute the 2009 DVF (displayed in Table V

- 4).

The RRF calculations were very similar to t hose that were computed in the a nnual SMAT analysis, except that all modeled RRFs were compared with each monitoring year’s 24

- hour 98 th percentile design value. A quarterly analysis was completed consistent with the procedure outlined in EPA’s Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (EPA

- 454/B

- 07

- 002, April 2007).

The procedure that was completed was as follows. The top 25% of the days of the speciation and the modeling data were computed on a quarterly basis. The speciation data was compared with the quarterly PM 2.5 FRM data to compute a speciated composition of

the FRM data. Then after the RRFs were calculat ed ( the RRF values for North Braddock,

are shown below in Table V

- 3), these RRF values were applied to the speciated composition data to compute a 2009 speciated composition data. Once this was completed, a future year design value was reconstructed.

Tab le V

- 3: 24

- hour PM 2.5 Quarterly RRF Values

Quarter Sulfates Nitrates OC EC Crustal

1 st 0.9755 0.9843 0.9408 0.8291 1.0992

2 nd 0.6295 1.0926 0.9893 0.8471 1.2694

3 rd 0.6182 0.9962 0.9902 0.8429 1.2801

4 th 0.9090 0.9839 0.9965 0.8503 1.1666

Table V

- 4 displays the 24

- hour PM 2.5 SMAT results for all of the monitors within the Pittsburgh

- Beaver Valley Area . The SMAT results demonstrate that the projected 24

- hour

98 th percentile PM 2.5 concentration calculated at the FRM monitor attains the 24

- hour

PM 2.5 NAAQS. Specifically, all DVF calculations are less than 65 μg/m 3 . Table V

- 4 presents the results of the 24

- hour SMAT results for a suite of regional modeling runs conducted by OTC each representing OTB/OTW control measures. All runs demonstrate complian ce with the 24

- hour PM 2.5 NAAQS.50

Table V

- 4: 24

- hour SMAT Results for t he Pittsburgh

- Beaver Valley Area 2009 On

The

- Books

- On

- The

- Way Control Measures

AIRS ID Site

Name County State 24

- Hour 98 th Percentile DVB 2009

2000 2001 2002 2003 2004 DVF

42003 0008 Lawrenceville Allegheny PA 34.1 41.7 41.4 35.9 38.3 31.5

420030067 South Fayette Allegheny PA 32.0 37.0 47.6 42.1 42.2 31.3

420030093 N. Park Allegheny PA 33.9 37.9 52.5 56.6 47.2 38.1

420030095 Coraopolis Allegheny PA 31.1 38.4 46.2 38.6 46.6 33. 1

420031008 Harrison Allegheny PA 41.6 48.1 46.2 41.9 45.4 35.0

420031301 N. Braddock Allegheny PA 39.7 51.7 41.9 50.4 38.3 33. 6

420070014 Beaver Falls Beaver PA 43.6 49.3 37.7 33.8 43.0 31.9

421250005 Charleroi Washington PA 36.0 44.4 45.4 35.6 35.4 3 0.7

421250200 Washington Washington PA 33.3 38.9 37.2 33.4 34.0 28.8

421255001 Florence Washington PA 30.5 37.6 36.7 33.9 36.0 26.4

421290008 Greensburg Westmoreland PA 37.2 44.1 40.0 34.8 39.0 30.6

Source: 24

- Hour 98 th p ercentile DVB c oncentrations c alculated from data in Appendix A

- 1.

F. Unmonitored Area Analysis

F ollowing EPA ’s Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (EPA

- 454/B

- 07

- 002, April 2007)

, an unmo nitored area analysis “...is intended to ensure that a control strategy leads to reductions in ozone or PM 2.5 at other locations which could have baseline (and future) design values exceeding the NAA QS were a monitor deployed. ”

Projected annual PM 2.5 concent rations surrounding the Pittsburgh

- Beaver Valley Area indicate most areas in the Commonwealth, including the Pennsylvania nonattainment areas immediately surrounding the Pittsburgh

- Beaver Valley Area

, are projected to attain the standard by 2009. This ind icates there should be no areas where concentrations could reasonably be expected to exceed the annual PM 2.5 NAAQS within the nonattainment area

.

The fact that the Liberty

- Clairton PM 2.5 nonattainment area is a subsection of the Pittsburgh

- Beaver Valley PM 2.5 nonattainment area was also evaluated. The five (5) municipalities that make up the Liberty

- Clairton PM 2.5 nonattainment area were originally designated as nonattainment for PM 10 . At the time, the five (5) municipalities were tied together due to the extent at which the local source was believed to impact (due to local topographical and meteorological issues). In the time since the original PM 1051

nonattainment designation, the ACHD has monitored PM 2.5 in municipalities surrounding the Liberty

- Clairton PM 2.5 nonattainment area. The monitoring data has confirmed the boundaries of the original PM 10 nonattainment area, showing that the impacts of the local source within the region did not extend further than the five (5) municipality region.

The Air Quali ty Modeling Group ( EPA Research Triangle Park) has developed the MATS

, described on p. 39, above . MATS is a PC

- based software tool that can perform the

modeled attainment tests for PM 2.5 and ozone (O 3 ), and perform the uniform rate of progress analysis f

or regional haze (visibility). When this analysis was conducted , MATS was still in development and therefore was not utilized within this analysis.

G. Local Area Analysis

EPA ’s Guidance on the Use of Models and Other Analyses for Demonstrating Attainm ent of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (2007) suggests that it may be necessary to evaluate the impact of local primary PM sources for contributions to both the

24

- hour and annual NAAQS. Evaluation of local PM sources and their effec ts on monitor concentrations could be evaluated using a near

- scale model such as AERMOD or

CALPUFF.

Since the end of 2008, there are a total of nine (9) FRM monitors within the Pittsburgh

Beaver Valley Area ; five (5) FRM monitors run by the Department and fou r (4) FRM monitors run by the ACHD . In addition, there are three (3) speciation monitors and at least four (4) continuous PM 2.5 monitor s located within the Pittsburgh

- Beaver Valley Area

.

Pennsylvania has noted local source interference at Allegheny C ounty’s North Braddock monitor (PA DEP, September 2004). North Braddock has the highest annual PM 2.5 design value (15.5 μg/m 3 ) and the highest 24

- h our design value (40 μg/m 3 ) in the Pittsburgh

Beaver Valley Area in 2008. The 24

- hour design value is below the (1997) 24

- h our standard indicating compliance with the NAAQS even with significant local effects.

A review of the Commonwealth’s and Allegheny County’s 2002 emission s from the NEI database indicates ten (10) large sources with greater than 50 tons p er year (TPY) of direct

PM 2.5 emissions within 50 kilometers of the North Braddock PM 2.5 monitor. These sou rces are listed in Table V

- 5 . Each source’s PM 2.5 emissions, distance from the North Braddock

mon itor, direction from the North Braddock monitor, c ounty and emission to distance ratio (Q/d) are included in the table.52

Table V

- 5: Summary of Large PM 2.5 Sources n ear the North Braddock Monitor

Source Emissions

(TPY) Distance

(km) Direction County Q/d

US Steel

– Edgar Thompson 472.0 1.2 S Allegheny 3 80.5

US Steel

– Irvin 63.5 8.4 S E Allegheny 7.6

US Steel

– Clairton Coke 394.0 11.1 S SE Allegheny 35.6

Glenshaw Glass Co. 58.8 15.2 N W Allegheny 3.9

Reliant

– Cheswick 591.0 16.0 N E Allegheny 37.0

Reliant

– Elrama 556.0 17.5 SSE Washington 31.8

Shena ngo Inc. 70.2 21.1 WNW Allegheny 3.3

Allegheny Energy

– Mitchell 181.0 22.6 SE Washington 8.0

Alleg. Ludlum

– Brackenridge 271.0 25.5 NE Allegheny 10.6

AK Steel

– Butler Works 58.8 47.9 NNW Butler 1.2

The ratio of emissions to distance (Q/d) is often used as a screening tool to determine if a source could cause a significant model concentration. If a source’s Q/d ratio is larger than twenty (20) it usually warrants an analysis usin g a dispersion model. Table V

- 5 indicates four (4) sources exceed thi s Q/d ratio and probably warrant an analysis with a dispersion model to gauge their effects on the North Braddock monitor. A quick survey of local wind

patterns utilizing meteorological data collected from 1998 to 2000 at the North Braddock

monitor indica tes the flow around the North Braddock area is influenced by the Monongahela River valley the monitor sits in. Therefore, as shown in Figure 10 below, the North Braddock area generally experiences a strong west, northwest flow or southeast

flow. Based on the results from the wind rose analysis, three of the identified sources ( US

Steel

– Edgar Thompson, US Steel

– Clairton Coke, and Reliant

- Elrama ) lie upwind of

the North Braddock monitor , while the other source ( Reliant

- Cheswick ) li es in less

favorab le wind directions to transport direct PM 2.5 emissions to the North Braddock

monitor.53

Figure 10. Wind Rose: North Braddock Monitoring Location (1998

- 2000)

As noted earlier, the Department has observed enhancement of PM 2.5 concentrations at the

North Braddock monitor by local sources. Using emissions to distance ratios (Q/d) and local predominant wind directions; four (4) sources were identified for possible analysis with a dispersion model to gauge the effect of local direct PM 2.5 emissions on the No rth

Braddock monitor. A local area analysis using a dispersion model, however, was not

conducted since the modeled concentrations for the North Braddock monitor currently

would attain the PM 2.5 NAAQS. This does not preclude the Department from conducting a dispersion modeling analysis as part of a local area analysis in the future for the EPA’s

revised 24

- hour PM 2.5 standard.

The 2002 inventory was based on emissions reported to the Department by facilities and

did not include condensable s for many facil ities. If a local area analysis is needed in the

future to address the 2006 PM 2.5 NAAQS, the analysis would likely be based on inventory data from a more recent baseline year. At that point , the Department could evaluate whether the baseline inventory in cludes PM 2.5 condensable s, as appropriate.

H . Weight of E vidence and Other Documentation Supporting Attainment

The EPA ’s Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Ha ze (2007) encourages the use of corroboratory analyses to support the modeled attainment demonstration. These54

analyses

, collectively referred to as “ weight of evidence ” (WOE)

, help bolster the

assertions that an area will achieve attainment in the allotte d time.

Table V

- 6 outlines the types of supplemental information that EPA suggests will satisfy a weight of evidence demonstration . Generally

, the analyses become more complicated as the projected modeled values increase. The p rojected 2009 design value for the annual

standard in the Pittsburgh

- Beaver Valley Area , 14. 3 μg/m 3

, is below the lower bounds of the range of 14.5 μg/m 3 to 15.5 μg/m 3 for which EPA ’s Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (2007) requires a formal weight of evidence demonstration.

According to the EPA ’s Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze ( 2007), areas, such as the Pittsburgh

- Beaver Valley Area , that have a projected design value lower than 14.5 μg/m 3 a re recommended to provide basic supplemental analyse s to
support the result of the modeling demonstration. The basic supplemental analyse s can include additional modeling, analysis of trends in the monitoring data or emissions and/or observational models and diagnostic analyses. The Department’s supporting evidence

include s a brief summary of the modeling demonstration, recent trends in the Pittsburgh

Beaver Valley Area ’s monitor ing data and a brief analysis of some of the largest SO 2 sources within the nonattainment area

.

Table V

- 6 : Summary of PM 2.5 Weight of Evidence Guidelines (EPA Guidance)

Results of Modeled Attainment Test Supplement al Analyses

Annual PM 2.5 24

- Hour PM 2.5

Future Design Value < 14.5 μg/m 3 , all sites Future Design Value < 62 μg/m 3 , all sites Basic supplemental analyses should be completed to confirm the

outcome of the modeled attainment

test

Future Design Value

14.5

– 15.5 μg/m 3 , all

sites Future D esign Value

62

– 67 μg/m 3 , all

sites A weight of evidence demonstration

should be conducted to determine if aggregate supplemental analyses support the modeled attainment test

Future Design Value ≥ 15.5 μg/m 3 , all sites Future Design Value
≥ 68 μg/m 3 , all sites More qualitative results are less likely to support conclusion differing from the outcome of the

modeled attainment test

2009 Projected Modeling Concentration: The Department’s attainment demonstration

relies on results from the OT B /O T W CMAQ runs completed by the Virginia Department of Environmental Quality. Emissions for the base case (2002) and projected (2009) time55

frames were developed by MARAMA with input from all states that are part of the OTR plus the District of Columbia. Ba se

- case and projected emissions within the Pittsburgh

Beaver Valley Area appear to be reasonable ; therefore

, the projected design value for 2009 should reflect what will actually be monitored.

Recent analyses of projected CMAQ ozone design values suggest the model may actually

underestimate the impact of emission reductions on actual concentrations

. This modeled

underestimation of changes in ozone concentrations m a y be due to the model ’ s inability to adequately reproduce changes in ozone concentrations du e to large emission reductions. If CMAQ has the same shortfall with fine particulate concentrations

, then it may also

overestimate the projected 2009 PM 2.5 design value s for the Pittsburgh

- Beaver Valley

Area . Since the calculated design value is already well below 15.0 μg/m 3 , any overestimation of the projected 2009 annual PM 2.5 design value provides a further cushion bolstering the argum ent that the Pittsburgh

- Beaver Valley Area will reach attainment

.

In addition, the 2002 inventory was based on emissio ns reported to the Department by

facilities. In 2002, many facilities did not include condensable s in their estimates of direct

PM 2.5

. The projected 2009 PM 2.5 emissions for EGUs include condensable PM. For EGUs, e missions of condensable PM were calcula ted based on 2009 operating parameters predicted by IPM and emission factors derived from AP

- 42 defaults. Because the 2002 inventory was based on emissions reported to the Department by facilities and did not include condensables for many facilities, the emissions inventory shows an apparent

increase in PM 2.5 emissions from stationary sources from 2002 to 2009.

If the 2002 emissions inventory were corrected to account for the unreported condensable emissions, the modeled 2009 PM 2.5 concentrations would b e lower, i.e.

, the Pittsburgh

Beaver Valley Area would be predicted to attain the standard by a larger margin. If the 2002 emissions inventory were corrected to account for the unreported condensable emissions, 2002 would have higher total PM 2.5 emissions in the inventory. Within the modeling, a concentration was calculated for 2002 and 2009 (based on their respective inventories). Then, in order to calculate the anticipated 2009 monitored concentration, DEP utilized the speciated pollutants (such as sul fates, nitrates, elemental carbon, organic carbon, etc.) constructed from the 2002 and 2009 modeling runs. Then a ratio (known as a relative reduction factor (RRF)) was applied, using the results of the 2002 and 2009 modeling. The RRF is calculated by di viding the 2009 modeled results by the 2002

modeled results. Therefore, if the 2002 emissions inventory had higher total PM 2.5 emissions, the RRF calculated would have been lower (with a larger number being the denominator of the RRF calculation). With a lower RRF, the calculated speciated component attributable to the direct PM 2.5 emissions would have been lower, lowering the

overall 2009 PM 2.5 predicted concentration.

PM 2.5 and Emission Trends: Long

- term trends were analyzed for all PM 2.5 monitors in Pennsylvania , using PM 2.5 modeling protocols. No statisticall y significant trends in the

2001

- 0 8 design values were noted for the Pittsburgh

- Beaver Valley Area monitor s

. This finding was not unexpected

, since it appears that many monitors within the regi on are56

heavily influenced by the mobile

- source sector, which has recently had significant controls imposed on it

.

Figure 1 1 show s the values for the monitor (North Braddock) displaying the highest annual

and 24

- hour PM 2.5 concentration in the Pittsburgh

- B eaver Valley Area f rom 1999 through

200 8

. Over the last two years

, annual PM 2.5 averages appear to have declined slightly

. In fact, all PM 2.5 monitors, excluding North Braddock, in the Pittsburgh

- Beaver Valley Area are now in compliance with the annual P M 2.5 standard. This may be due to a combination

of weather conditions and emission decreases in the mobile source sector. While this is probably not a statistically significant trend

, it may be indicative of lower future PM 2.5 design values more in line with the annual PM 2.5 standard.57 Figure 11: Pittsburgh-Beaver Valley Area PM 2.5 Trends



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Controls on the largest SO 2 source s in the Pittsburgh

- Beaver Valley Area

, including Allegheny Energy

– H at field ’ s Ferry, Reliant

– Keystone, and Reliant

– Cheswick facilities, are scheduled to be operational in 2009. The projected SO 2 emission rate s for these three (3) sources should provide a substantial reduction in sulfate levels with in the Pittsburgh

- Beaver Valley Area

. As seen in Figure 5 (in this Section V ), s ulfate is a major

contributor to the Pittsburgh

- Beaver Valley Area ’s PM 2.5 nonattainment problem. This

reduction in PM 2.5 precursors coupled with somewhat lower recent annual PM 2.5 concentrations bolster s the C ommonwealth’s assertion that the Pittsburgh

- Beaver Valley

Area will soon be in compliance with the PM 2.5 NAAQS.

I. Conclusions

The Pittsburgh

- Beaver Valley Area ’s projected 2009 annual PM 2.5 concentration was estimated using the OTC’s modeling platform. A review of the base case (2002) run indic ated the CMAQ model did a reasonable job reproducing actual concentrations. Based on this analysis

, it is reasonable to assume the model can estimate the projected PM 2.5 concentrations within the Pittsburgh

- Beaver Valley Area for 2009. The Department

und erstands that the EPA anticipates using 2009 data to determine whether the Pittsburgh

Beaver Valley Area attains the PM 2.5 standard by its April 2010 attainment date

.

Projected PM 2.5 concentrations from CMAQ indicate the Pittsburgh

- Beaver Valley Area

will attain the annual standard by 2009 . Additional evidence supporting this conclusion

include s lower concentrations at all of the PM 2.5 monitors within the Pittsburgh

- Beaver Valley Area the last couple of years, significant SO 2 controls installed on some of the largest sources with in the nonattainment area and possible model under

- predictions of the air quality benefits of emission reductions

.59

VI. CONTINGENCY MEASURES FOR THE ATTAINMENT DEMONSTRATION

A. Contingency Measure Requirement

Pursuant to 40 CFR 51.1012

, the attainment plan for the Pittsburgh

- Beaver Valley Area must include a contingency plan that contains measures that qualify as contingency

measures fo r the attainment demonstration. This section fulfills the contingency measures requirement fo r the attainment demonstration. The contingency plan must provide for one year of reductions needed for attainment.

By 2009, e missions of SO 2 and NOx in the Pittsburgh

- Beaver Valley Area are projected

to decrease by 347, 796 tons and 86,586 tons, respec tively

. Based on modeling of the projected 2009 emissions, the Pittsburgh

- Beaver Valley Area is predicted to have a 2009 design value of 14.3 ug/m 3 . This is lower than the 15 ug/m 3 required for attainment of

the PM 2.5 standard

. Calculations were made to estimate the portion of the emission reduction that is necessary to reach the attainment concentration of 15 ug/m 3 and the portion of the emission reduction that reduces the design value below 1 5 ug/m 3 and is, therefore, excess

.

Table VI

- 1 contains info rmation about the changes in design value and emissions expected by 2009 in the Pittsburgh

- Beaver Valley Area

. Table VI

- 1 displays the 2002

actual and 2009 modeled design values and the 2002 actual and 2009 projected emissions

of PM 2.5 , SO 2 and NOx.

Ta ble VI

- 1: Change s in Design Value and Emissions Expected by 2009

Pittsburgh

- Beaver Valley Area Design

Value (ug/m 3 ) PM 2.5

(tons/year) SO 2

(tons/year) NOx

(tons/year)

2002 16.8 14904 476871 198483

2009 (Modeled/Projected) 14.3 27969 129074 111897

Predi cted Change from 2002

- 2009 2.5

- 13066 347796 86586

As shown in Table VI

- 2, for each pollutant, the change in pollutant emissions was divided by the predicted change in design value to yield the design value reduction rate

. Next, t he change in design val ue necessary to attain the standard (16.8 ug/m 3

– 15 ug/m 3
= 1.8 ug/m 3 ) was multiplied by the design value reduction rate to estimate the target

emissions reduction

. This represents the portion of emissions reduction necessary to

attain the standard. The rest of the emissions reduction is beyond what is necessary for

attainment and is

, therefore

, considered to be “excess” reduction.60 Table VI

- 2: Calculation of Required and Excess Emissions Reductions

Pittsburgh

- Beaver Valley Area Design

Value (ug/m 3 ) P M 2.5

(tons/year) SO 2

(tons/year) NOx

(tons/year)

Predicted Change from 2002

- 2009 2.5

- 13066 347796 86586

Design Value Reduction Rate (tons/ug/m 3 ) N/A 139119 34634

Target Reductions for Attainment 1.8 N/A 250413 62342

Calculated Excess Reductions 0.7 N/A 97383 24244

The contingency requirement is calculated by dividing the target emissions reduction by seven which is the number of years between 2002 and 2009. Table VI

- 3 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 VI

- 3 : Calculation of Required Contingency Plan Reductions

Pittsburgh

- Beaver Valley Area PM 2.5 (tons/year) SO 2

(tons/year) NOx

(tons/year)

Tar get Reductions for Attainment N/A 250413 62342

Calculated Excess Reductions N/A 97383 24244

Contingency Requirement N/A 35773 8906

Excess Reductions Satisfy Contingency Requirement N/A Yes Yes

B . Identified Contingency Measures

In addition to the c alculated excess reductions shown in Table s VI

- 2 and VI

- 3 above, the Department has identified additional control measures. EPA guidance encourages early implementation of contingency measures to guard against failure either to m eet
a milestone or attain the standard

. EPA's guidance on early implementation of

control measures encourages the early implementation of required control measures and of contingency measures as a means of guarding against failures to meet a61

milestone or to attain. The EPA states that a ny implemented measures (that are not

needed for the rate

- of

- progress requirements or for the attainment requirements) would

need to be “ backfilled ” , meaning replaced with another measure, only to the extent they are used to meet a milestone

. 8

The reductions from the designated contingency measures are surplus vis

- à

- vis the attainment demonstration contained in this SIP. As a result, the Department will not be required to replace any contingency measures that it chooses to implement in advance of

t he contingency plan requirement.

The following describes specific control measures that are anticipated to be in place in order to bring the area back into attainment should a violation occur.

On October 9, 2008, Governor Rendell signed Se nate Bill 295, which became Act 124 of 2008, the Diesel

- Powered Commercial Motor Vehicle Idling Act (Act 124) . Act 124 went into effect on February 6, 2009. The Department estimates that 50 percent of all long duration idling for Class 8 trucks will be eliminated in 2 010 when the temperature exemption for sleeper truck rest expires. Statewide emission reductions are estimated to be 1610 tons, 45 tons and 30 tons per year for NOx, VOC, and PM 2.5 , respectively. The Department may also utilize enhanced enforcement to ob tain additional emission

reductions.

Significant additional reductions in NOx, direct PM 2.5 and

, to a limited extent, SO 2 emissions will occur in emissions from highway and nonroad mobile sources after 2009.

NOx emissions from mobile sources are more tha n one

- third of the emissions in 2009

.

In addition, the following regulations are in development and are anticipated to be adopted in the relatively near future:

NOx controls for cement kilns NOx controls for glass furnaces

PM controls for outdoor wo od furnaces

Regulations to reduce VOC emission s are also in development, including controls on the manufacture and use of adhesives, primers and sealants and regulations incorporating the Control Techniques Guidelines issued by the EPA in 2006, 2007 and 2008

.

Once the Department’s Bureau of Air Quality has obtained an approved request to initiate a rulemaking, the rulemaking may proceed as follows:

8 EPA, "Guidance on the Post

- 1996 Rate

- of

- Progress Plan and the Attainment Demonstration," Corrected Version as of February 18, 1994, p. 50.62 Within 2 months: Review by Air Quality Technical Advisory Committee (AQTAC), Citizens Advisory Council and other advisory committees

, 9 as appropriate.

Within 5 months: Environmental Quality Board (EQB) meeting/action.

Within 7 months: Publi cation in the Pennsylvania Bulletin for comment as proposed rulemaking.

Within 9 months: Public hearing takes pl ace and comment period on proposed rule

closes.

Within 10 months : House and Senate Standing Committees and Independent Regulatory Review Commission (IRRC) comment on proposed rule.

Within 12 months: AQTAC, Citizens Advisory Council and other committee s , as appropriate, review responses to comments and draft final rulemaking.

Within 15 months: EQB meeting/action.

Within 16 months: IRRC action on final rulemaking.

Within 17 months: Attorney General review/action.

Within 18 months: Publi cation in the Pennsylvania Bulletin as final rulemaking and

submi ssion to the EPA as a SIP revision. The regulation would become effective

upon publication in the Pennsylvania Bulletin

.

9 Other committees could include the Small Business Compliance Advisory Committee and Agriculture Advisory Committee.63 REFERENCES

SECTION I

Pope III, C. Arden, M. Ezzati and D. Dockery. “Fine

- Parti culate Air Pollution and Life Expectancy in the United States.” New England Journal of Medicine. 360: 376

- 386 January 22, 2009.

EPA, 2007. Clean Air Fine Particle Implementation Rule. Final Rule. 72 FR 20 586 (April 25, 2007).

SECTION III

EPA, 2005. Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations.

EPA

- 454/R

- 05

- 001. August, 2005. Updated November, 2005

Final Technical Support Document, Devel opment of Emission Projections for 2009, 2012, and 2018 for NonEGU Point, Area, and Nonroad Sources in the MANE

- VU Region. Prepared by MACTEC for MARAMA, February 28, 2007.

Final Regulatory Analysis: Control of Emissions from Marine Diesel Engines , EPA,

November 1999.

SECTION V

The Nature of the Fine Particle and Regional Haze Air Quality Problems in the MANE

- VU Region: A Conceptual Description. Prepared by the Northeast States for Coordinated Air

Use Management (NESCAUM), November 2006.

Summary of Pennsylvania’s PM 2.5 Nonattainment Analysis, Prepared by the Pennsylvania Department of Environmental Protection, October 2007.

Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regio nal Haze. EPA , EPA

- 454/B

- 07

- 002, April

2007.

Final Air

- Quality Modeling Protocol f or the Annual PM 2.5 NAAQS: Pittsburgh

- Beaver Valley Annual PM 2.5 Nonattainment Area , prepared by the Pennsylvania Department of Environmental Protection, October 2007.

A Modeling Protocol for the OTC SIP Quality Modeling System For Assessment of the Ozone National Ambient Air Quality Standard in the Ozone Transport Region

, The Modeling Committee of the Ozone Transport Commission , March 2006.64

CMAQ Model Performance and Ass essment for Base Year 2002: PM 2.5 Mass and Speciation, Prepared by the New York State Department of Environmental Conservation,

December 2007.

Clegg, S.L., P. Brimblecombe, and A. S. Wexler, (1998), “Aerosol Inorganics Model; A Thermodynamic Model of the System H+

- NH4+

- SO42

- - NO3

- - H2O at Tropospheric Temperatures.”, J. Phys. Chem ., 102A, 2137

- 2154. ( http://www.aim.env.uea.ac.uk/aim/project.htm ).

EPA, 2004. Pro cedures for Estimating Future PM 2.5 Values for the CAIR Final Rule by Application of the (Revised) Speciated Modeled Attainment Test (SMAT). July 26, 2004.

Available on EPA’S CAIR PDF web page ( www.epa.gov/CAIR/pdfs/Revised

- SMAT.pdf ).

EPA, 2006. Definition of SANDWICHed STN Data. November 1, 2006. Available on

EPA’s Air Explorer web page ( www.epa.gov/mxplorer/sandwich_description.doc ).

EPA, 200 6 (2). SANDWICH Material Balance Approach for PM 2.5 Data Analysis (Presented at the 2006 National Air Monitoring Conference) . November 6

- 9, 2006. Available on EPA’s AMTIC web page ( www.epa.gov/ttn/amtic/files/ambient/2006conference/frank.pdf ).

SECTION VI

U. S. EPA, "State Implementation Pla ns; General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990", Proposed Rule, 57 Federal Register 13

, 498 (April 16, 1992).

EPA , "Guidance on the Post

- 1996 Rate

- of

- Progress Plan and the Attainment Demonstration," Corrected Version as of February 18, 1994, p. 50.

OTC 2007. Identification and Evaluation of Candidate Control Measures: Final Technical Support Document. Prepared by MACTEC Federal Programs, Inc., Herndon, Virginia for the Ozone Transport Commission. February 28, 2007.65 ACRONYMS AND ABBREVIATIONS

ACHD A llegheny County Health Department

AIM Architectural and Industrial Maintenance Coatings AQTAC Air Quality Technical Advisory Committee

BACT Best Available Control Technology

CAA Clean Air Act

CAIR Clean Air I nterstate Rule

CA LEV California Low Emission Vehicle (program)

CF Control Factor

CFR Code of Federal Regulations CMAQ Community Multi

- scale Air

- Quality Model

CMV Commercial Marine Vessel

DON Degree of Neutralization

DV B Baseline Design Value

DVF Future Design Value

EC Elemental Carbon

EDMS Emissions and Dispersion Modeling System

EGAS Economic Growth Analysis System

EGU Electric Generating Unit

EIA Energy Information Administration

EPA The U nited S tates Environmental Protection Agency EQB Environmental Quality Board

FAA Federal Aviation Administration

FIP Federal Implementation Plan

FIRE Factor Information Retrieval

FMVCP Federal Motor Vehicle Control Program

FR Federal Register

FRM Federal Reference Method

HAP Hazardous Air Pol lutant

ICI Industrial, Commercial, Institutional

I/M Inspection and Maintenance

IPM Integrated Planning Model

IRRC Independent Regulatory Review Commission

LDGV Light Duty Gasoline V ehicles

LDGT Light Duty Gasoline T rucks

MACT Maximum Achievable Control Technology

MANE

- VU Mid

- Atlanti c/ Northeast Visibility Union

MARAMA Mid

- Atlantic Regional Air Management Association

MATS Modeled Attainment Test Software

MM5 Mesoscale Model Version 5

MPO Metropolitan Planning Organization

MY Model Year NAAQS National Ambient Air Quality Standard

NAICS North American Industry Classification System

NBP NOx Budget Program

NESCAUM Northeast States for Coordinated Air

- Use Management66

NH 3 Ammonia

NH 4 + Ammonium

NLEV National Low Emission Vehicle (program)

NMIM N ational Mobile Inventory Model

NO x Oxides of Nitrogen

NO 2 Nitrogen Dioxide

NO 3 - Nitrates

NSR New Source Review

OC Organic Carbon

OM Organic Mass OTAQ Office of Transportation and Air Quality

OTB On the B ooks

OTC Ozone Transport Commission

OTW O n

- the

- W ay OTR Ozone Transport Region

PBW Particle Bound Water

PennDOT Pennsylvania Department of Transportation

PIT Pittsburgh International Airport

PM Particulate Matter

PM 2.5 Particulate Matter less than 2.5 microns in diameter or Fine P articulat es
PM 10 Particulate Matter less than 10 microns in diameter

ppm parts per million

PSD Prevention of Significant Deterioration

PSU/NCAR Pennsylvania State University National Center for Atmospheric Research

RACM Reasonably Available Control Measure

RAC T Reasonably Available Control Technology

RE Rule Effectiveness

RFP Reasonable Further Progress

RP Rule Penetration

RPO Regional Planning Organization

RRF Relative Response Factor

RVP Reid Vapor Pressure

SANDWICH Sulfate, Adjusted Nitrate, Derive d Water, Inferred Carbonaceous Material

Balance A pproach

SCC Source Classification Code

SCR Selective Catalytic Reduction

SIP State Implementation Plan

SMAT Speciated Modeled Attainment Test

SMOKE Sparse Matrix Operator Kernel Emissions

SO 2 Sulfur Dioxide

SO 4 - Sulfates

STN Speciation Trends Network

TCM Transportation Control Measures

TEOM Tampered Element Oscillating Microbalance M onitor

TSD Technical Support Document

μ g/m 3 M icrogram per cubic meter67

μm Micrometer VISTAS Visibility Improvement State and Tribal Association of the Southeast

VMT Vehicle Miles Traveled

VOC Volatile Organic Compound WOE Weight of Evidence

Z EV Zero Emissions Vehicle4500445684 10107

COMMONWEALTH OF PENNSYLVANIA
STO-52-1 REV.**12~BB** IHVO!CENo.

PUBUCATIONS:AUTHORIZATION AND INVOICE 

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TO: (NAME AND,ADDRESS OF NEWSPAPER) 

### Pittsburgh Post 34 Boulevard of Pittsburgh, PA Gazette the Allies
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### 94-0692700 F!l..OM, 

## 'NAME**ANq,~DDR'W** bF 

## AGENCY)

'AG',,",-TeIJ'PHOI"l'."" 9 4 9 5 

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### House :**111-/~/-** 

### 400 Market Street'····················
Bureau of Air Quality Harrisburg, PA 17105

HEREWITH IS ENCL.OSED COPY FOR PUBUCATION OF ADVERT1SE;MENT FOi't PROPOSALS TO 

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sex, religious creed, ancestry, age or national origin and that the Commonwealth, upon receipt of satisfactory evidence of such discrimination, shall have the rightto cancel said contract. Return this copy at once if you will not acceptthis advertisement underthe terms
set forth.

Proof of advertising in the form of a tearsheet must be included on Parts 1 ,2 & 3. Return original and two copies (signed by the editor or publisher) to Agency listed above. Part 1 must be notarized. Part 4 is yours.

Commonwealth to be billed only for actual number of printed lines published.

ACCOUNT FUND

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### ES published in the regular advertlsing'doibmns of said newspaper, in the editions of said newspaper, in all ref**~~~~b~~~~e~g5~CX~~~~1;and** invoiced above; and that the Commonwealth is not charged therefor at a rate higher than is charged any primary (health-baSed),1 advertiser for a similar amount of matter occupying similar space d
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. dard .was'delayed due to Linda M. Gaertner, NotalY PubHc *.=Th;;;;is;;a::;ff;:id::;a;v;:it;:m;;;;u;st;,b;e;;;;m;;a;;;d;;;e;;b;;y;t;;h;e;;O:;w;:n;:e;:r;." ;:Pu;b::;l;;is",h;e;;r,;o;:r;;tllega! challenges, tn the le owner or publisher. Ci Of Pittsbuf h AUegh. eny County ;:: Commonwearth of Penn-

- ,**~~v~ri~l~~e~~s~~g;:::** y omm!ss!or_,**=::.'..::.:S..::.:~.:.c.,-_-c-.J** prised80f ?;Il or parts of_CKTRANSMITTAL Member, Pep.flsvlvania Association of Notaries 21 countles·as PM2.S 'PA Bulletin, Doc. No. 09-1665 Page I of2



# NOTICES

Proposed Revision to the State Implementation Plan for the Pittsburgh-Beaver

Valley, Pennsylvania Fine Particulate Nonattainment Area; Public Hearing

[39 Pa.B. 5278] [Saturday, September 5, 2009]

Particulate matter (PM) includes both solid and liquid particles suspended in the air. Fine particle pollution describes PM that is less than or equal to 2.5 micrometers in diameter (PM 2 .5)· PM 2 . 5

concentrations above the Federal health-based standard pose a serious human health threat. Health

studies have shown a significant association between exposure to fine particles and premature death

from heart or lung disease. In 1997, the United States Environmental Protection Agency (EPA)

established an annual primary (health-based) and secondary (welfare-based) PM 2 .5 standard of 15.0

micrograms per cubic meter (f-lg/m\ based on the 3-year average of annual mean PM 2 . 5

concentrations. The EPA also established a primary and secondary 24-hour standard of 65 f-lg/m3

determined by the 3-year average of the 98th percentile of 24-hour concentrations. Implementation

of the standard was delayed due to legal challenges. In this Commonwealth, the EPA designated eight areas comprised of all or parts of 18 connties as PM 2 . 5 nonattainment areas for the annual

standard. For each nonattainment area, the Commonwealth is required to develop a State Implementation Plan (SIP) revision that demonstrates how the area will attain the standard by the prescribed attainment date, April 5, 2010.

The Department of Environmental Protection (Department) is seeking public comment on the SIP

revision for the Pittsburgh-Beaver Valley PMz.5 nonattainment area (Pittsburgh-Beaver Valley

Area). The proposed SIP revision contains information on PM 2 .5 trends and emissions to

demonstrate that the Pittsburgh-Beaver Valley Area meets all requirements necessary for an approvable SIP revision. The proposed SIP revision demonstrates how the area will attain the

PM 2 . 5 stan4ard by April 5, 20 I 0, by presenting evidence from air quality modeling, emission

trends, regional pollutant transport impacts and emission reductions through state and Federal

control measures. In addition, the proposed revision to the SIP contains the base year 2002

emissions inventory, mobile source emission budgets for purposes of transportation conformity and

a contingency plan to bring the area back into attainment should future violations of the standard

occur. After consideration of comments received, the SIP revision will be finalized and submitted

to the EPA for approval.

The proposed PM 2
. 5 SIP revision for the Pittsburgh-Beaver Valley Area is available on the

Department's web site at www.depweb.state.pa.us (choose "Air Topics") or through the contact

persons listed. Notice of the proposed SIP revision will also be published in newspapers of general

circulation in the affected area.

The Department will hold a public hearing to receive comments on the proposal on October 6, 2009, at I p.m. at the Department's Southwest Regional Office, 400 Waterfront Drive, Pittsburgh,

http://www.pabulletin.comlsecure/datalvoI39/39-36/1665.html 10/2312009PA Bulletin, Doc. No. 09-1665 Page 2 of2

P A. Persons wishing to present testimony at the hearing should contact Yvette House, P.O. Box 8468, Harrisburg, PA 17105, (717) 787-9495 oryhouse@state.pa.ustoreserveatime.Personswho

do not reserve a time will be able to testify as time allows. Witnesses should keep testimony to 10

minutes and should provide two written copies of their statement at the hearing.

Persons with a disability who wish to attend the hearing and require an auxiliary aid, service or other accommodation to participate in the proceeding should contact Yvette House at (717) 787-

9495 or yhouse@state.pa.us. TOO users may contact the Pennsylvania AT&T Relay Service at (800) 654-5984 to discuss how the Department can best accommodate their needs.

The Department must receive comments no later than October 9,2009. Written comments should

be sent to the attention of Arleen Shulman, Division of Air Resource Management, Bureau of Air Quality, P. O. Box 8468, Harrisburg, PA 17105-8468, ashulman@state.pa.us. Use "Pittsburgh

PMz.5 SIP" in the subject line.

JOHN HANGER, Secretary

IPa.B. Doc. No. 09-1665. Filed for public inspection September 4, 2009, 9:00 a.m.]

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This material has been drawn directly from the official Pennsylvania Bulletin full text database.

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http://www.pabulletin.comlsecure/data/voI39/39-36/1665.html 10/23/20091 Commonwealth of Pennsylvania Comment and Response Document for the Pittsburgh

- Beaver Valley Fine Particulate Attainment Demonstration

October 2009

On September 5, 2009 , the Pennsylvania Department of Environmental Protection ( DEP or Department) publis hed a notice of public hearing and commenced a 30

- day written comment period on the proposed attainment d emonstration and base year inventory for

the Pittsburgh

- Beaver Valley fine particulate (PM 2.5 ) nonattainment area ( Beaver, Butler, Washington, and West moreland counties and portions of Allegheny, Armstrong, Greene

and Lawrence counties ) 39 Pa.B. 5278 . The public hearing was held at the DEP’s

South west Regional Office, 400 Waterfront Drive

, Pittsburgh , PA on Tuesday

, October 6

, at 1 p.m. The comment per iod closed on October 9, 2009

.

This document summarizes the testimony received during the public hearing and the written comments received prior to the close of the public comment period. The list of

commentators is set forth below:

COMMENTATORS:

1. natashasoroka@aol.com (no information other than email was supplied)

2. Rachel Filippini

Executive Director Group Against Smog and Pollution, Inc. Wightman School Community Building 5604 Solway St., #204 Pittsburgh, PA 15217 (oral testimony)

3. Joint letter from the following parties:

Joe Osborne, Esq. Legal Director Group Against Smog and Pollution, Inc. 5604 Solway St., #204 Pittsburgh, PA 15217

Charles McPhedran, Esq. Senior Attorney Citizens for Pennsylvania’s Future 1518 Walnut Street, Suite 1100 Philadelphia, PA 19102

- 34062 Tom Hoffman Western Pennsylvania Director

Clean Water Action

100 5 th Avenue #1108 Pittsburgh, PA 15222

4. James Thompson, Air Director Allegheny County Health Department

301 39 th Street Pittsburgh, PA 15201

- 1891

COMMENTS AND RESPONSES

COMMENTS:

1. COMMENT: W hile the EPA’s Clean Air Fine Particle Implementation Rule gives states and localities discretion to determine if control measures for PM precursors such as VOCs should be considered, the rule also states that “[i]f information brought forward by commenters or the State in the SIP development process shows that the presumption in this rule for . . . VOC . . . is not technically justified for a particular nonattainment area, the State must conduct a technica l demonstration to reverse the presumption.”

The rule lists examples of “the types of analyses that would be appropriate to use in developing such a demonstration.” Included among these examples are “[s]pecialized monitoring and laboratory studies [tha t] assess the relative concentrations of organic compounds.” In 2009, such a study analyzed air toxics in Allegheny County and found that thirteen of thirty six monitored organic air toxics exceeded the national 75th percentile at one or more monitoring s ites. (The study is referenced as Allen Robinson et. al., Air Toxics in Allegheny County: Sources, Airborne Concentrations, and Human Exposure , Final Technical Report for Allegheny County Health Dept. at 3 (Mar. 2009),

available at: www.achd.net/air/pubs/

pdf/CMU%20Air%20Toxics%20FINAL%20REPORT%20REVIS ED%20MAR%2009.pdf)

All thirteen of the elevated compounds belong to chemical classes that have been recognized for their potential to contribute to PM2.5 concentrations. Most significant, seven of these thi rteen chemicals are aromatic compounds, which “are considered to be the most significant anthropogenic SOA [secondary organic aerosol] precursors and have been estimated to be responsible for 50 to 70 percent of total SOA in some

airsheds.” Based on this d ata, we believe PADEP must perform a technical demonstration to determine if VOCs significantly contribute to PM2.5 concentrations in

the nonattainment area. (3)3

RESPONSE: The Department appreciates the commentator’s information re garding the

contributi on of volatile organic compounds ( VOCs ) to PM 2.5 concentrations in the Pittsburgh

- Beaver Valley area.

As the commentator indicates, the U.S. Environmental Protection Agency’s (EPA’s)

PM 2.5 Implementation Rule establishes general presumptive policies for a ssessing which

PM 2.5 precursors should be evaluated for possible controls. The EPA requires states to

evaluate measures for VOC s only if the state or EPA makes a technical demonstration to

show VOCs significantly contribute to PM 2.5 in that nonattainment area. EPA discusses

the reasons fo r this position in the preamble to the final implementation regulation ( Clean Air Fine Particle Implementation Rule, 72 F ed. R eg. 20586 (Apr. 25, 2007) ). While the fact that some VOCs can form secondary organic aerosol ( SOA) is not disputed, the formation of SOA, and therefore the contribution of VOCs to fine particle concentrations, is complex and also highly variable, even on short time scales. EPA recognizes that

further research and standardized and approved technica l tools are needed to better characterize emissions inventories for specific VOC s and determine their contribution to fine particle formation.

The Department considered the data in the report on air toxics in Allegheny County referenced by the commentat or. First, the Department assessed whether emissions of the 13 air toxics found in the study at elevated concentrations comprise a large percentage of VOC emissions in Allegheny County. In 2004, Allegheny County point sources emitted

a total of 314 tons of the 13 air toxics based on air toxics emissions data published in the air toxics report referenced by the commentator. According to the Allegheny County Health Department 2004 Point Source Emission Report (available at
http://www.achd.net/air/pubs/pdf/aqemissionrpt2004.pdf ) , Allegheny County point sources

emitted a total of 2587 tons of VOC in 2004. Based on this information, in 2004,

emissions of the 13 elevated air toxics account for approximately 12% of Allegheny County’s VOC emissions. DEP does not conclude that this represents adequate support to technically justify the Department or EPA developing a demonstration that VOCs should be addressed in the region’s PM 2.5 attainment plan.

DEP also assessed other available data that EPA suggests would be appropriate to
consider in developing a demonstration to reverse the presumption that VOCs do not

need to be included in the PM 2.5 attainment plan for the Pittsburgh

- Beaver Valley are a

. VOC emissions are projected to decrease by 18,036 tons per year (22%) from 80

, 898 tons per year in 2002 to 62

, 862 tons per year in 2009 , primarily due to federal and state control measures being adopted for purposes of reducing ground

- level ozone. VOC s are a known contributor to ozone. Despite the substantial reduction in VOCs, t he modeling

conducted shows a minimal reduction in PM 2.5 concentrations. Based on the average of all Pittsburgh

- Beaver Valley monitors, the calculated quarterly average relat ive reduction factors range d from 0.96

– 1. 03 for the organic carbon fraction of PM 2.5 as a result of the 22% reduction in VOC. This may indicate that VOC reductions are not as vital as reductions of other precursors for attainment of the PM 2.5 standard i n the Pittsburgh

Beaver Valley area.4

Overall, the Department concludes that there is too much uncertainty regarding the role of VOCs in the formation of fine particulate to reverse the presumption at this time. In the future, the Department intends to continue to work with other states and EPA to develop tools to assess the role of VOCs in the formation of fine particulate.

2

. COMMENT: DEP must carry out an analysis to determine if VOC controls would provide for a more timely, certain, or cost effec tive PM2.5 control strategy . (1 ,2 )

RESPONSE: The Department disagree s that the rule states that DEP must carry out an analysis to determine if VOC controls are necessary under the conditions the commentator describes. Section 51.1002(c)(3) states that a state is not required to address VOC as a precursor and evaluate sources of VOC emissions for control measures unless the state or EPA provides an appropriate technical demonstration.

Furthermore, the requirements for Reasonably Available Control Measure (RACM) analysis under Section 51.1010( b ) are to consider measures that would advance the attainment date by one year. Since the attainment date is in less than one year, there are

no additional measures that could advance the attainment date in that fash ion. The criteria for improving certainty and cost

- effectiveness do not appear in either section.

3

. COMMENT: If VOCs are a significant contributor, more timely and cost

effective PM2.5 reduction methods may be available in the form of VOC controls. ( 3)

RESPONSE: As indicated in the response to Comment #1, the Department has concluded that too much uncertainty remains regarding the role of VOC in particulate formation to develop a demonstration that VOC significantly contributes to PM 2.5 concentratio ns in the Pittsburgh

- Beaver Valley area.

That said, the Pittsburgh

- Beaver Valley is also a nonattainment area for ground

- level ozone, for which VOCs are clearly a precursor and well understood. The Commonwealth has adopted a series of controls for VOCs t o reduce ozone and is developing additional measures for adhesives, primers, sealants and solvents as well as coatings for many commercial/industrial processes. As tools improve to measure emissions and account for the formation of fine particles, the Com monwealth will be able to include the benefits of

VOC controls in future State Implementation Plan ( SIP ) revisions to meet the more protective standards established in 2006.

4. COMMENT: Modeling assumptions for projecting 2009 emissions may be

over estimated. (1 ,2 )

RESPONSE: The assumptions used when inventories were projected and air quality modeling done were the best available at the time.5

5

. COMMENT: Second, modeling assumptions used to project 2009 emissions may overestimate real

- world air quality improvements. For instance, the automobile fleet turnover rates used to determine the age and emissions levels of US automobiles is based on annual vehicle sales in 2000. Given the current economic challenges, 2008 and

2009 auto sales are low er by roughly half than those included in the CMAQ model

. ( 1, 2)

RESPONSE: Fleet turnover rates can have significant impacts on the benefits from federal and state vehicle control strategies and ultimately on the forecasted emission

totals. Since this i tem significantly impacts calculations, Pennsylvania does not use MOBILE6.2 defaults in the preparation of the inventory. Instead, county

- specific vehicle registration data is obtained on a triennial basis and used within the emission calculation

process. Future SIP and transportation conformity submissions will utilize more recent planning assumptions as they are obtained and prepared for emission analyses. Variations in vehicle sales volumes and among the various vehicle types may occur between the upd ate cycles. Since the complex regional modeling was performed using a 2005 inventory and not all states update fleet age in the same fashion, the most current uniform data available at the time were used. DEP agrees that this may overestimate fleet

turno ver and air quality improvements. However, both the soaring gasoline and diesel prices in portions of these years as well as the economic situation also curtailed vehicle miles traveled, which would have the opposite effect.

6

. COMMENT: Another exam ple [of modeling assumptions] : projected 2009 emissions include estimated reductions in SO2 and NOx from the Clean Air Interstate

Rule or CAIR

. However, in the time since these estimations were made, the D.C. Circuit declared the rule “fatally flawed” an d remanded it to EPA. Industry uncertainty, first about whether the rule would continue to exist, and now about the final form of EPA’s CAIR replacement has caused electricity generators to cancel or delay SO2 and NOx controls originally intended under CA IR. ( 1, 2)

RESPONSE: EPA has advised states that because CAIR remains in effect during the remand, assumptions made about its effects in PM 2.5 SIPs for very near term attainment years such as 2009 remain valid. The Department does not believe that any c ontrols installed in anticipation of CAIR have been shut down because of “industry uncertainty

. ”

7

. COMMENT: In 2006, prompted by evidence that the 1997 standard was insufficient to protect public health, EPA issued an updated, more protective standar d. While SIP revisions to comply for the new standard will not be due for several years, we believe that given the health threat that additional years of exceeding the 2006 standard entail, DEP should make every effort to bring our region into compliance with the 2006 standard in the current SIP revision. (1,2)

RESPONSE: While the current SIP revision is designed to address the 1997 NAAQS

, t he Department is working in many ways to achieve even greater PM2.5 reductions

. Pennsylvania is supporting collab orative efforts on a regional basis to ensure EPA considers the 2006 standard in a rule to replace CAIR, is urging EPA to develop national6

standards for controls of SO 2 and NOx from industrial, commercial and institutional boilers, is developing a rule to regulate outdoor wood burning furnaces, is finalizing its rules to limit NOx from cement kilns and glass furnaces . In addition, the Department anticipates developing a regulation to reduce sulfur content in residential, commercial

and industrial fuel oils . Additional measures will be examined once preliminary modeling information for the 2006 standard (based on 2007 inventories and assumptions) is available on the amount of emission reduction necessary to attain that standard. A SIP

for the 2006 standard will be submitted in a timely fashion.

8

. COMMENT: The Proposed SIP Revision shows sharp increases in direct emissions of PM 2.5 between 2002 and 2009 (see Table E

- 1, p. iii). These increases appear to come from stationary sources (compare Table I II

- 1, p. 14 and Table III

- 2, p. 17). These increases also show up as “negative reductions,” especially striking when compared with the actual reductions in sulfur dioxide (SO2) and nitrogen oxides (NOx) over the same time period (Table IV

- 1, p. 23). From c onversations with DEP, we understand that this reflects a difference in the methodology for counting condensable PM between the 2002 actual inventory, in which most sources do not report condensables, and the 2009 projected inventory, which is based on a m odel that does include condensables. We suggest that DEP clarify this aspect of its approach to the emission inventory in the Proposed SIP Revision. (3)

RESPONSE: DEP agrees that the SIP revision could benefit from clarification regarding the emission inventory methodology and explanatory language has been added. The 2002 inventory was based on emissions reported to the Department by facilities. In 2002, many facilities did not include condensable PM in their estimates of direct PM

emissions

. For mo st source categories, the 2009 inventory was developed by projecting the 2002 inventory forward to 2009 using growth factors. For electric generating units (EGUs)

, the I ntegrated P lanning M odel (IPM) was used to predict 2009 operating parameters and emiss ions. The projected 2009 PM 2.5 emissions for EGUs include

condensable PM emissions which were calculated based on operating parameters predicted by IPM and emission factors derived from AP

- 42 defaults. Because the 2002 inventory did not include condensab les for many facilities, the emissions inventory shows an apparent increase in PM 2.5 emissions from stationary sources from 2002 to 2009.

If the 2002 emissions inventory were corrected to account for the unreported condensable emissions, the modeled 2009 PM 2.5 concentrations would be lower, i.e.

, the Pittsburgh

Beaver Valley area would be predicted to attain the standard by a larger margin.

If the 2002 emissions inventory were corrected to acc ount for the unreported condensable emissions, 2002 would essen tially have higher total PM 2.5 emissions in the inventory. Within the modeling, a concentration was calculated for 2002 and 2009 (based on their respective inventories). Then, in order to calculate the anticipated 2009 monitored concentration, DEP utiliz ed the speciated pollutants (such as sulfates, nitrates, elemental carbon, organic carbon, etc.) constructed from the 2002 and 2009 modeling runs. Then a ratio (known as a relative reduction factor (RRF)) was applied, using the results of the

2002 and 200 9 modeling. The RRF is calculated by dividing the 2009 modeled results by

the 2002 modeled results. Therefore, if the 2002 emissions inventory had higher total7

PM 2.5 emissions, the RRF calculated would have been lower (with a larger number being

the deno minator of the RRF calculation). With a lower RRF, the calculated speciated

component attributable to the direct PM 2.5 emissions would have been lower, lowering the

overall 2009 PM 2.5 predicted concentration.

9. COMMENT: On page i of this SIP the fu ll name of the "Pittsburgh

- Beaver Valley non

- attainment area" is given the short name of the "Pittsburgh area." The remaining 67 pages then use the term "Pittsburgh area." Over many years the City of Pittsburgh has experienced a difficult time in removing its antiquated image as a "smoky city." This use of the name Pittsburgh to refer to the eight

- county area reinforces this past image to those who are not aware of the large region. We request the term "Pittsburgh area" be replaced with the "Pittsburgh

- Bea ver area" to more accurately represent the larger community this non

- attainment area this represents. (4)

RESPONSE: The SIP has been changed to reflect the full name of the nonattainment area (Pittsburgh

- Beaver Valley).