Technical Support Document (TSD)-

Review of Emissions Inventories for the 

Redesignation Request and Maintenance Plan of the 

Maryland portion ofthe Martinsburg-Hagerstown, WV-MD 

1997 PM2.s N onattainment Area 

Submitted on December 23, 2013 by: 

Maryland Department of the Environment 

TSD Prepared on April25, 2014 by: 

Emlyn Velez-Rosa 

Office of Air Program Planning, 3AP30 

OnBehalfof 

Office of Air Monitoring and Analysis, 3AP40 

U.S. Environmental Protection Agency, Region 3 

1650 Arch Street 

Philadelphia, Pennsylvania 19103 

ReViewed by Alice H. Chow, Associate Director 

Office of Air Monitoring and Analysis (3AP40) 

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I. Introduction 

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

Monitoring and Analysis (OAMA) review of the emissions inventories submitted with the 

Redesignation Request and Maintenance Plan for the Maryland portion of the MartinsburgHagerstown, WV-MD nonattainment area (“the Martinsburg Area” or “the Area”) for the 1997 

annual fine particulate matter (PM2.5) national ambient air quality standard (NAAQS). The 

Martinsburg Area is comprised of Berkeley County in West Virginia and Washington County in 

Maryland (the Maryland portion of the Area). These plans were prepared by the Maryland 

Department of the Environment (MDE). This review does not determine the approvability of the 

redesignation request or maintenance plan. Emissions inventories in a redesignation request are 

used to show permanent and enforceable emission reductions between the year the area was 

designated as a nonattainment area and the year the area came into attainment. In a maintenance 

plan, the emissions inventories are used to reflect the emissions during the time the 

nonattainment area came into attainment and are then projected to show that the area will remain 

in attainment for at least 10 years after redesignation. Any questions pertaining to this technical 

summary should be directed to Alice H. Chow, Associate Director, Office of Air Monitoring and 

Analysis, at 215-814-2144 or via email at chow.alice@epa.gov. 

II. Comprehensive Emissions Inventory 

Under section 172(c)(3) of the Clean Air Act (CAA), states are required to submit a 

comprehensive, accurate, current accounting of actual emissions from all sources (point, 

nonpoint, nonroad, and onroad) in the nonattainment area. For PM2.5 nonattainment areas, this 

inventory must contain primary PM2.5 emissions (including condensibles), sulfur dioxide (SO2), 

nitrogen oxides (NOx), volatile organic compounds (VOC), and ammonia (NH3). On December 

7, 2012 (77 FR 72966), EPA approved the 2002 emissions inventory submitted by the State of 

Maryland with the attainment plans for the 1997 annual PM2.5 NAAQS to satisfy the 

requirements of section 172(c)(3) for the Maryland portion of the Martinsburg Area. 

III. Emissions Inventories for Redesignation Request and Maintenance Plan 

2007 Attainment Year Inventory and Maintenance Plan Base Year Inventory 

States are required to submit an inventory used for the year of attainment, which is 

referred to as the attainment year inventory or the maintenance plan base year inventory. 

Maryland used a 2007 emissions inventory as its attainment year and maintenance plan base year 

emissions inventory for the Washington County maintenance plan. The 2007 inventory is 

appropriate to use because 2007 is part of the three-year period of 2007-2009 that demonstrated 

attainment of the 1997 annual PM2.5 NAAQS in the Martinsburg Area. The 2007 emissions 

inventory is used as the basis for the projected inventories that are used to show the Area will 

remain in attainment. 
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For the 2007 emissions inventory for the point, nonpoint, and nonroad source categories, 

MDE submitted the 2007 Version 3 Emissions Inventory developed through the Mid-Atlantic 

Regional Air Management Association (MARAMA) regional planning process. Documentation 

of the development of the 2007 emissions inventory can be found in MARAMA’s January 23, 

2012 “Technical Support Document for the Development of the 2007 Emission Inventory for the 

Regional Air Quality Modeling in the Northeast / Mid-Atlantic Region Version 3.3” (MARAMA 

2007 TSD). 

 

The Washington County 2007 point source inventory was classified as emissions from 

electric generating units (EGUs) and from non-EGU sources. EPA guidance for emissions 

inventory development provides that actual emissions should be used for purposes of the 

comprehensive emissions inventory. The point source inventory submitted was developed by 

MARAMA in consultation with MDE. 

The nonpoint source emissions inventory for 2007 was developed using 2007 specific 

activity data along with EPA emission factors and the most recently available emission 

calculation methodologies. 

The 2007 nonroad emissions were generated the emissions using EPA’s National Mobile 

Inventory Model 2008 (NMIM), which used NONROAD 2008a emissions model. Marine, air 

and rail/locomotive (MAR) emissions are not part of the NMIM and were calculated separately 

using the most recent methodologies and inputs. 

The 2007 onroad mobile source inventory was developed by using EPA’s highway 

mobile source emissions model MOVES2010a and the most recent planning assumptions. Local 

data inputs to MOVES2010a reflect the latest available planning assumptions using data 

obtained from MDE, Maryland’s Motor Vehicle Administration (MVA), Maryland State 

Highway Administration (SHA), Hagerstown/ Eastern Panhandle Metropolitan Planning 

Organization (HEPMPO), and other local/national sources. Documentation of the onroad 

inventory development is available in MDE’s “On-Road (Highway) Mobile Emissions Inventory 

Documentation for the Washington County, Maryland PM2.5 Nonattainment Area,” found in 

Appendix F on the State submittal. 

EPA’s OAMA reviewed the files and the emission results provided by MDE and found them to 

be acceptable. 

2017 and 2025 Projected Emission Inventories 

Projected inventories are used to show that the area will remain in attainment. MDE used 

2017 and 2025 emission projections developed through the MARAMA regional planning 

process for the interim and maintenance plan end year, respectively. The projected inventories 

are derived by applying the appropriate growth and control factors to the 2007 attainment year 

emissions inventory. Emission projections, emission methodologies, control factors, and growth 

factors for the 2017 and 2025 inventories can be found in MARAMA’s January 23, 2012 

“Technical Support Document for the Development of the 2017/2020 Emission Inventory for 

Regional Air Quality Modeling in the Northeast/Mid-Atlantic Region,Version 3.3” and 
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“Technical Support Document for the Development of the 2025 Emission Inventory for PM

Nonattainment Counties in the MANE-VU Region, Version 3.3, Rev. 2,” respectively. 

Projected emissions for EGU point sources were developed based on electricity 

generation projections that are delineated by region and fuel. Growth factors for EGU sources 

are based on the U.S. Energy Information Administration’s (EIA’s) 2011 Annual Energy 

Outlook (AEO2011) (Appendix F, Table 96 - Electricity Generation by Electricity Market 

Module Region and Fuel Source). Projected emissions for non-EGU unit point sources were 

developed using AEO fuel consumption forecasts, State-level employment projections, and other 

State-specific emission projection data. 

The projected onroad mobile source inventories were developed by using EPA’s highway 

mobile source emissions model MOVES2010a, the most recent planning assumptions, and Statedeveloped growth factors. Local data inputs to MOVES2010a reflect the latest available 

planning assumptions using data obtained from MDE, Maryland’s Motor Vehicle Administration 

(MVA), Maryland State Highway Administration (SHA), Hagerstown/ Eastern Panhandle 

Metropolitan Planning Organization (HEPMPO), and other local/national sources. Growth 

factors were developed and selected based on consultation between Maryland Department of 

Transportation (MDOT), HEPMPO and MDE. Documentation of the onroad inventory 

development is available in MDE’s “On-Road (Highway) Mobile Emissions Inventory 

Documentation for the Washington County, Maryland PM2.5 Nonattainment Area,” found in 

Appendix F on the State submittal. 

Projected emissions for nonroad mobile sources were developed using NMIM2008 

(version NMIM20090504), which used NONROAD2008a model (version July 2009), EPA’s 

most recently approved emissions estimation tool for nonroad sources. Emissions from airport 

ground support equipment were estimated based on EPA’s aircraft inventory that was prepared 

using the Federal Aviation Administration’s (FAA’s) Emissions and Dispersion Modeling 

System (EDMS). Because NONROAD2008a does not estimate emissions from marine vessel, 

airport, and railroad sources, these emissions were estimated separately. Emissions data for 

commercial marine vessels are based on recent EPA regulatory impact analyses. Airports 

emissions were projected by applying growth data reported by the FAA. Railroad emissions 

were projected based on growth data available in the AEO2010. 

EPA’s OAMA reviewed the methodologies submitted by MDE and found them to be 

acceptable.