Technical Support Document (TSD) For Emissi ons Inventories for the Delaware Nonattainment Area Particulate Matter (PM2.5) State Implementation Plan (SIP) Base Year Inventory . Submitted June 2 007 by

the Delaware Department of Natural Resources And Environmental Contr ol (DNREC) TSD Prepared April , 2010 Janet C. Kremer Office of Air Monitoring and Anal ys is, 3AP40 U.S. Environmental Protection Agency , Region 3

1650 Arch Street Philadelphia, Pennsylvania 19103

/s/

________________________________ ____________ Reviewed b y Walter Wilkie, Associate Director Office of Air Monitoring and Anal ys is, 3AP40

June 16, 2010

_________________ Dat e Signed2

**I. Introduction**  The purpose of this document is to provide a technical summary of th e Office of Air Monitoring and Analy sis (OAMA) review of the emissions invento ries submitted with the Delaware Nonattainment Area PM 2.5 SIP by DNREC . This review determine s the approvability

of the SIP Base Year Inventory and an evaluation of the methods used for projection ye ar inventories
. A SIP Base Year Inventory is the starting point from which other SIP inventories are derived as well as serving as the benchmark for other SIP planning activities, such as the establishment of an emission s reduction c redit program. Projection year inventories are essentiall y used to track progress; the purpose of which is to demonstrate a reduction in emissions of regulated sources from the Base Year to a projected ye ar. The Delaware Nonattainment Area was designated as a PM 2.5 nonattainment area in 2004
. D NREC has submitted the Delaware Nonattainment Area PM 2.5 SIP and has requested EPA’s approval. Any questions pertaining to this technical summary should be directed to Walter K. Wilkie, Associate Director , Office of Air Monitoring and Anal ys is , at 215
- 814
- 2150 or via email at wilkie.walter@epa.gov
. **II. 2002**  **SIP Base Year Inventory**  The SIP base y ear inventory is the primary

inventory

from which other inventories (3
- y ear cycle inventories, reasonable further progress inventories, modeling inventories) are derived. The Clean Air Act calls for State, local, and Tribal agencies to ensure that the base ye ar inventory is comprehensive, accurate, and current for all actual emissions. 1 The base year inventory includes emissions estimates from stationary point and nonpoint sources, onroad mobile sources, and nonroad mobile sources. For the PM 2.5 NAAQS, the pollutants to be inventoried are NH 3 , PM 10 , PM 2.5 , VOC, NOx and S O 2 . For the NAAQS, NH 3 , PM 10 , PM 2.5 , VOC, NOx and SO 2 emissions should be reported as actual annual emissions . DNREC ’s base ye ar inventory is for 2002. For the Delaware S IP , the geographic coverage includes sources in New Castle County
. A significant amount of documentation is required for these SIP base y ear estimates which DNREC has provided. DNREC ’s Emission Inventory Development (EID) Program (which resides within the Air Quality

Management Section (AQMS)) was primaril y responsible for pr eparing the 2002 base ye ar PM 2.5 precursor inventory . The point source inventory represents facility
- specific data for larger stationary sources. Point source emissions data are submitted to AQMS by

the facilities using Terminal Server Satellite **i**
- STEPS software. **i**
- STEPS are the point source emission inventory electronic data management sy stem. The criteria used to determine if a source would be a part of the point source inventory was as follows:

1 “ 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 20053  Facilities that held a Title V permit in 2002;  Any f acility w ith e missions of VOCs greater than 5 TPY for an y of the ye ars 1999, 2000, or 2001, as previously r eported to the AQMS inventory program;  Any facility falling into one of the following industry sectors: o Hot - mix asphalt plants, o Hospitals that use ethylene oxid e for sterilization, o Electric generating units (EGUs); and o Facilities using anh ydrous ammonia as a refrigerant;  Any f acility f or which AQMS does not have previous inventory d ata that appears may

be a significant source. DNREC provided its 2002 actual annual emissions at the facilit y level and at the process
level. For the 2002 Nonpoint Source emissions, al so known as “area sources,” DNREC provided an inventory

that contained estimations of emissions by multiplying an emission factor b y some known i ndicator or activity level for each category

at the county

level. These emissions are calculated on an annual basis. Various sources of emission factors or methodologies were used, including EPA’s AP
- 42, the Factor Information Retrieval Sy stem (FIRE), EP A’s Emissions Inventory Improvement Program , Volume III , documented projects performed by the California Air Resource Board, and projects performed b y the Mid
- Atlantic Regional Air Management Association (MARAMA)
. Nonpoint source estimates were provided b y SCC. The Nonroad Mobile Source 2002 annual inventory was prepare d with EPA’s NONROAD2005 model by E.H. Pechan and Associates under contract from the Mid Atlantic/Northeast Visibility Union (MANE
- VU) using Delaware specific inputs
. NONROAD estimates fuel consumption and emissions of total hydrocarbons, carbon monoxide, nitrogen oxides, sulfur dioxide, and particulate matter for all nonroad mobile source categories except for aircraft, locomotives, and commercial marine vessels**.** DNREC provided emission es timates for locomotive engines, aircraft emissions and commercial marine vessels separatel y. For line haul locomotive and yard locomotive emissions, DNREC requested and received estimates of fuel consumption or data to calculate fuel consumption. Some in formation was provided at count y level for each county in Delaware, while some was provided sy stem - wide and needed to be allocated to Delaware. Track miles within each count y were used to allocate statewide fuel consumption to each county
. Paired with EP A emiss ion and conversion factors, DNREC calculated locomotive annual emissions for the base y ear. For aircraft emissions, DNREC took airport
- specific emissions for all aircraft sub
- categories and allocated them to the county

in which each airport is located
. DNREC estimated annual aircraft emissions using a combination of airport
- specific activity data and Federal Aviation Administration (FAA)/EPA emission factors. DNREC requested landing and take
- off data from the Delaware Aeronautics Administration an d from individual airports, for each sub
- category

of aircraft. DNREC used these airport
- specific LTO data to estimate emissions using FAA’s Emissions and Dispersion Modeling S ys tem (EDMS). EDMS does not estimate particulate emissions by aircraft/engine type. DNREC used fleet average4

PM 10 emission rates applied to total LTOs outside EDMS. For commercial marine vessels, there are man y t ypes of vessels that engage in many different modes of activity , therefore DNREC used several different sources to o btain data for each vessel t ype and activity. Some of these sources included the Marine Exchange of the Delaware River (ME, 2004), the Commercial Marine Activity for Deep Sea Ports in the United States (EPA, 1999), and the Waterborne Commerce of the Unite d States (USACE, 2004a). Annual emissions were calculated b y vessel type, engine t ype, and mode of operation using county level activity data. All Nonroad mobile source emissions were provided b y SCC. The Onroad Mobile Source 2002 emissions inventory w as developed using the most current version of EPA’s highway mobile source emissions model MOBILE 6.2 (M6.2) and link
- level vehicle miles traveled (VMT) data for each count y from the Delaware Department of Transportation ( DelDOT) . The emission factors dev eloped using M6.2, were b y month, using monthly temperature and fuel propert y data. DNREC provided Mobile6.2 input and output files for review
. DNREC provided annual m obile emissions values in T ons P er Year ( TPY ) and were provided b y SCC. DNREC also ap plied rule effectiveness and rule penetration for its 2002 PM2.5 SIP base ye ar inventories. Rule effectiveness reflects the actual abilit y of a regulatory program to achieve the emission reductions required by regulation (or perhaps voluntarily adopted). DNREC applied rule effectiveness and where applicable , provided a justification of a higher percentage than EPA’s previous policy ( which assumed an 80% rule effectiveness for applicable sources unless otherwise specified) . Rule penetration is an estimate of percentage of emissions in a source category that are emitted at facilities subject to the requirements of a rule. DNREC applied rule penetration for its nonpoint sources where applicable. OAMA staff reviewed the results, procedures, and methodologie s for the SIP base ye ar, and found them to be approvable.