Technical Support Document (TSD) for the Redesignation Request and Maintenance Plan Forthe Allentown, PA 2006 PM2

.sNonattainment Area

Submitted by the Pennsylvania Department ofEnvironmental Protection TSD Prepared December 2014 by Jessica 

### L. Fry Office ofAir Monitoring and Analysis, 3AP40 U.S. Environmental Protection Agency, Region 3 1650 Arch Street Philadelphia, Pennsylvania 19103

Reviewed by Altce H. Chow, Associate Director Office ofAir Monitoring and Analysis (3AP40)

### I. Introduction The purpose ofthis document is to provide atechnical summary ofthe Office ofAir Monitoring and Analysis (OAMA) review ofthe emissions inventories submitted with the Redesignation Request and Maintenance Plan for the Allentown, PA 2006 PM2

.sNonattainment Area (NAA) bythe PennsylvaniaDepartment ofEnvironmental Protection (PADEP). The NAA consists ofLehigh andNorthampton counties in Pennsylvania. This review does not determine the approvability ofthe redesignation request or maintenance plan. Emissions inventories in a redesignationrequest are used to show permanent and enforceable emissionreductions between the yearthe 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 area came into attainment and are then projected to show that the area will remain in attainment. Any questions pertaining to this technical summary should be directed to Alice H. Chow, Associate Director, Office ofAir Monitoring and Analysis, at 215-814-2144 or via email at chow.alice@epa.gov. 

### II. Emissions Inventories for Redesignation Request 2005Nonattainment YearInventory
In a redesignation request, emissions inventories are used to support the State's claim that the areahas permanent and enforceable emissions reductions. In order to do this, the state should estimate the percentreduction (from the year that was usedto determine the design value for designation and classification) achieved from federal and state control measures; this is usually termed as the nonattainment or baseline year inventory. For the purpose ofthis plan the year 2005 was used the nonattainment year inventory. The 2005 nonattainment year inventory contains primary PM2.s emissions (including condensibles), S02,NOx, VOC, and NH3 emissions. This section will discuss the 2005 nonattainment year inventory that was used in the Allentown, PA Redesignation Request and Maintenance Plan submitted by PADEP. PADEP used emissions from EPA's 2005 NEI for theirpoint, nonpoint, nonroad, and onroad nonattainment year inventory. OAMA staffreviewed the files and the emission results provided by PADEP and found themto be acceptable. 

### III. Emissions Inventories for Maintenance Plan 2007Attainment YearInventory andMaintenance Plan Base YearInventory Under section 172(c)(3) states are required to submit a comprehensive, accurate, current accounting ofactual emissions from all sources (point, nonpoint, nonroad, and onroad) inthe nonattainment area. This inventory contains primary PM2

.semissions (including condensibles), S02, NOx, VOC, and NH3 In a Maintenance Plan, states are required to submit an inventory used for the year ofattainment, which is called the attainment year inventory and can also be referredto as the maintenance planbase year inventory. This inventory is used as the basis for the projected inventories that are used to showthe area will remain in attainment. The base year inventory submitted by PADEP contains primary PM2.s emissions (including condensibles), S02, NOx, VOC, andNH3 emissions. This section will discuss the 2007 emissions inventorythat was used in the Allentown Redesignation Request and Maintenance Plan in order to fulfill the 172(c)(3) and attainment year emissions inventory requirements.
Forthe 2007 base year inventory, PADEP submitted the 2007 Version 3 Emissions Inventory developedthrough the**~id-Atlantic** Regional AirManagement Association (MARAMA) regional planning process for the point, nonpoint, and nonroad source categories. Documentation ofthe development ofthe inventory can be found in Technical Support Document for the Development of the 2007Emission Inventoryfor the RegionalAir Quality Modeling in the NortheastIMid-Atlantic Region Version 3.3. January 23, 2012. The 2007 point source inventory contained emissions for EGU and Non-EGU sources in the NAA. EPA guidance for emissions inventory developmentprovides that actual emissions should beused for purposes ofthe base year inventory. PADEP developed their 2007 inventory by using emissions directly reported by the facilities. The EGU inventory was augmented and missing condensable PM emissions were supplemented using emission factors developed for MARAMA in2008. 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 calculationmethodologies. PADEP used 2008 NEI data to fill in any missing categories in the 2007 inventory.
For 2007 nonroad mobile sources, PADEP generatedthe emissions using EPA's NMIM2008 model. Since marine, air and rail/locomotive (MAR) emissions are not part ofthe NONROAD model, they were calculated separately outside ofthe NONROAD model. Aircraft emissions were developed using EPA's database to the supportthe 2008 NEI. PADEP used railroad emissions developed by the Eastern Regional Technical Advisory Committee (ERTAC). The 2007 onroad mobile source inventory was developed using EPA'shighway mobile source emissions model MOVES2010. PADEP used local activity to replace default inputs in the model where appropriate.
OAMA staffreviewed the files and the emission results provided by PADEP and found themto be acceptable.
2017and2025Projection Emission Inventories Projection inventories are used to show that the area will remain in attainment. PADEP used 2017 and 2025 emissionprojections developed through the MARAMA regional planning process for the interim and maintenance plan end year, respectively. Emission projections, emissionmethodologies and growth factors for 2017 and 2025 can be found in the Technical SupportDocument for the Developmentof the 2013/201712020 Emission InventoriesforRegionalAir QualityModeling in the Northeast/Mid-Atlantic Region (MARAMA 2017 TSD) andthe Technical SupportDocument for the Developmentof the 2025 Emission Inventory for PM2.s Nonattainment Counties in the MANE-VURegion, January 2012 (MARAMA 2025 TSD), respectively.
ForEGU emissions, PADEP used growth factors based on the Annual Energy Outlook (AE02011) and appliedthem to the 2007 inventory. Non-EGU emissions projections were based onVersion 3.3 ofthe 2007 MANE-VU+VA inventory. MARAMA growth factors were developed using AEO fuel consumption forecasts, state-level employment projections, and other state-specific emissionprojection data. Nonpoint source emissions for 2017 and 2025 were developed similarly to the non-EGU point sources. Emissionprojections were based onVersion 3.3 ofthe 2007 MANE-VU+VA inventory. MARAMA growth factors were developed using AEO fuel consumption forecasts, state-level employmentprojections, and other state-specific emission projection data. Nonroad source emissions for 2017 and 2025 were developed using NMIM model runs which containdefault assumptions for projected years. Aircraft emissions were projectedby applying activity growth datareported inthe Federal Aviation Administration's (FAA's) Terminal AreaForecast (TAF) system for 2009-2030 (FAA2010). Railroad emissions were based onthe MARAMA MANE-VU+Vainventory. The 2017 and 2025 onroad mobile source inventory was developed using EPA'shighway mobile source emissions model MOVES2010. PADEP used local activity to replace default inputs inthe model where appropriate OAMA staffreviewed the methodologies provided by PADEP and found them to be acceptable.