Technical Support Document (TSD) For Pennsy lvania Portion of the Philadelphia

- Wilmington, PA

- NJ
- DE

PM 2.5 Nonattainment Area: State Implementation Plan (SI P) Attainment Demonstration

and Base Year Inventory
Submitted April 2010 by

the Pennsy lvani a Department of Environmental Protection TSD Prepared October 2011 by Alice H. Chow Office of Air Monitoring and Anal ys is, 3AP 40 U.S. Environmental Protection Agency , Region 3

1650 Arch Street Philadelphia, Pennsylvania 19103

/s/

___________________

_________________________ Reviewed b y Andrew Hass , Acting Director Office of Air Monitoring and Anal ys is (3AP40)

October 11, 2011

_________________ Dat e Signed**I. Introduction**  The purpose of this document is to provide a technical s ummary of the Office o f Air Monitoring and Analy sis (OAMA) review of the emiss ions inventories submitted with the Pennsylvania Portion of the Philadelphia

- Wilmington PM 2.5 Nonattainment Area State Implementation Plan (SI P) , by the Penns yl vania Department o f Environment al Protection (PADEP) . This review determines the approvability of the SI P Base Year Inventory and an evaluation of the methods used. A SI P Base Year Inventory is the starting point from which other SI P inventories are derived as well as ser ving as the benchmark for other SIP planning activities, such as the establishment of an emissions reduction credit program

. On January 5, 2005 the Pennsy lvania Portion of the Philadelphia

- Wilmington area, comprised of Bucks, Chester, Delaware, Montgomery and Philadelphia counties, was designated as nonattainment for the PM2.5 NAAQS. Any questions pertaining to this technical summary should be directed to Andrew Hass , Acting Director, Office of Air Monitoring and Analy sis, at 215

- 814

- 2049 or via email at hass.andrew@epa.gov

. **II. 2002 SIP Base Year**  **Inventory** The SI P base y ear inventory is the primary

inventory

from which other inventories (3

- ye ar cy cle 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 s tationary point and nonpoint sources, onroad mobile sources, and nonroad mobile sources. For the PM 2.5 NAAQS, the poll utants to be inventoried are PM 10 , PM 2.5 , VOC, NOx, SO 2 and NH 3 . For the NAAQS, emissions should be reported as actual annual emissions. The Point Source data for 2002 is derived from the Air Information Management Sy stem / environment, Facility , Application, Compliance Tracking Sy stem (AIMS/eFACTS). The AIMS /eFACTS database is comprised of sources identified and inventoried by

PADEP’s re gional and central offices through permitting, field inspections, and survey s. Survey s are conducted annually as facilities must submit emission estimates for various operations, throughputs, work hours, as well as process data, such as combustion unit data and fuel characteristics. In2002, PADEP noted that many fac ilities did not include condensa ble PM in their estimates of direct PM emissions. MANE

- VU included both filterable and condens able PM estimates for their regional modeling efforts. For the 2002 Nonpoint Source emissions, also known as “area sources,” PADEP provided an inventory

that contained estimations of emissions by multiplying an emission

1 “ Emissions Inventory Guida nce 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.factor b y some known indicator or activity level for each category at the county

level. These emis sions are t ypi cally calculated on an annual basis because the activity data are generall y onl y available on an annual basis

. Nonpoint source estimates were provided by SCC. The Nonroad Mobile Source 2002 inventory was prepared with EPA’s NONROAD2005 mod el. NONROAD estimates fuel consumption and emissions of total volatile organic compounds (VOCs), oxides of nitrogen (NOx), carbon monoxide (CO), particulate matter (PM 10 ), fine particulate matter (PM 2.5 ) and sulfur dioxide (SO 2 ) for all nonroad mobile source categories except for aircraft, locomotives, and commercial marine vessels **.** Revised allocation geographic files for NONROAD2005 model option files (average temperature, Reid Vapor Pressure) and revised housing unit data used for the model runs (to all ocate residential lawn and garden equipment) were also discussed

. The National Mobile Inventory Model (NMIM) was used to e stimate emissions of ammonia from sources contained in the NONROAD model. PADEP provided emission estimates for locomotive engines and aircraft emissions separatel y. For locomotive engine emissions, PADEP obtained fuel usage from Norfolk Southern and Conrail for 2002; emissions from all other railroad companies were projected emissions from a 1999 survey using national fuel consumpti on information and EPA emission and conversion factors. Emissions from commercial aircraft and small airport operations for 2002 were estimated with the following methodologies: Small airports : PADEP used the EPA

- approved Emissions and Dispersion Mode ling S ys tem (EDMS) 4.20, the latest version available at the time the inventory was developed. PADEP estimated emissions using operations data obtained from the United States Department of Transportation, Federal Aviation Administration’s (FAA) Terminal Area Forecast for commercial aircraft op erations

. Using this operations data, emissions were modeled directly using the EDMS. Finally , Willow Grove Naval Air Station in Bucks County is a significant source of NOx but since the terrorist activity in Septemb er 2001, the Nav y has not released an y operations data to PADEP, therefore, its emissions were not included in the inventory

. Philadelphia International Airport : As part of the City of Philadelphia’s commitment to reduce delay s at the Philadelphia Intern ational Airport (PHL) , a major long

- term project known as the Capacity Enhancement Program (CEP) was proposed to redesign runway s, taxiway s and terminals. This construction project would generate a large amount of direct and indirect emissions over time f rom ex cavation activities as well as less efficient aircraft operations (due to fe wer runway s). PADEP worked closel y with the Philadelphia Division of Aviation to establish the 2002 base year using historical data and the most accurate operation data for emissions sources (aircraft t ype, arrivals, departures, etc.) for modeling with EDMS

. Commercial marine vessels emissions from the Port of P hiladelphia were estimated using EPA’s “Commercial Marine Activity for Deep Sea Ports in the United States , Final R eport,” as well as ship arrival information supplied by the Maritime Exchange for the Delaware River and Bay

. By mutual agreement between Pennsylvania and New Jersey , downbound traffic north of the Pennsylvania

- Delaware border isincluded in the Pennsylvania inventory and the upbound emissions traffic north of the border is in New Jersey ’s inventory

. In addition, hotelling emissions (emissions from auxiliary engines when docked) from larger vessels (tankers, cruise ships, etc.) , ferries, and tugboat emiss ions are included. All Nonroad mobile source emissions were provided by SCC and classification. The Onroad Mobile Source 2002 emissions inventory was developed using the most current version of EPA’s highway mobile source emissions model MOBILE 6.2. PAD EP also used PPSUITE, an enhanced version of the Post Processor for Air Quality software s ys tems used for previous inventory submissions in Pennsylvania. The Pennsy lvania Department of Transportation (PennDOT) provided estimates of vehicle miles traveled (VMT) by vehicle t ype and roadway t ype. PADEP provided sample Mobile6.2 input files and estimate results for review. OAMA staff reviewed the files and the emission results provided by PADEP and found them to be approvable

.