Technical Support Document (TSD) for the 

Redesignation Request and Maintenance Plan 

For the Allentown, PA 2006 PM2.s Nonattainment Area 

Submitted by the 

Pennsylvania Department of Environmental Protection 

TSD Prepared December 2014 by 

Jessica L. Fry 

Office of Air Monitoring and Analysis, 3AP40 

U.S. Environmental Protection Agency, Region 3 

1650 Arch Street 

Philadelphia, Pennsylvania 191 03 

Reviewed by Altce H. Chow, Associate Director 

Office of Air Monitoring and Analysis (3AP40) 
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 Allentown, PA 2006 PM2.s Nonattainment 

Area (NAA) by the Pennsylvania Department of Environmental Protection (PADEP). The NAA 

consists of Lehigh and Northampton counties in Pennsylvania. 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 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 of Air Monitoring and Analysis, at 215-814-2144 or 

via email at chow.alice@epa.gov. 

II. Emissions Inventories for Redesignation Request 

2005 Nonattainment Year Inventory 

In a redesignation request, emissions inventories are used to support the State's claim that 

the area has permanent and enforceable emissions reductions. In order to do this, the state 

should estimate the percent reduction (from the year that was used to 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 of this 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 their point, nonpoint, nonroad, and 

onroad nonattainment year inventory. 

OAMA staff reviewed the files and the emission results provided by P ADEP and found 

them to be acceptable. 

III. Emissions Inventories for Maintenance Plan 

2007 Attainment Year Inventory and Maintenance Plan Base Year Inventory 

Under section 172(c)(3) 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. This inventory contains primary PM2.s emissions (including condensibles), 

S02, NOx, VOC, and NH3 In a Maintenance Plan, states are required to submit an inventory used 

for the year of attainment, which is called the attainment year inventory and can also be referred 
to as the maintenance plan base year inventory. This inventory is used as the basis for the 

projected inventories that are used to show the area will remain in attainment. The base year 

inventory submitted by PADEP contains primary PM2.s emissions (including condensibles), S02, 

NOx, VOC, and NH3 emissions. This section will discuss the 2007 emissions inventory that was 

used in the Allentown Redesignation Request and Maintenance Plan in order to fulfill the 

172(c)(3) and attainment year emissions inventory requirements. 

For the 2007 base year inventory, PADEP submitted the 2007 Version 3 Emissions 

Inventory developed through the ~id-Atlantic Regional Air Management Association 

(MARAMA) regional planning process for the point, nonpoint, and nonroad source categories. 

Documentation of the development of the inventory can be found in Technical Support 

Document for the Development of the 2007 Emission Inventory for the Regional Air Quality 

Modeling in the Northeast I Mid-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 development provides that actual emissions 

should be used for purposes of the 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 in 2008. 

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. PADEP used 2008 NEI data to fill in any missing categories in the 

2007 inventory. 

For 2007 nonroad mobile sources, PADEP generated the emissions using EPA's 

NMIM2008 model. Since marine, air and rail/locomotive (MAR) emissions are not part of the 

NONROAD model, they were calculated separately outside ofthe NONROAD model. Aircraft 

emissions were developed using EPA's database to the support the 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's highway 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 

them to be acceptable. 

2017 and 2025 Projection Emission Inventories 

Projection inventories are used to show that the area will remain in attainment. P ADEP 

used 2017 and 2025 emission projections developed through the MARAMA regional planning 

process for the interim and maintenance plan end year, respectively. Emission projections, 

emission methodologies and growth factors for 2017 and 2025 can be found in the Technical 

Support Document for the Development of the 2013/201712020 Emission Inventories for 
Regional Air Quality Modeling in the Northeast/Mid-Atlantic Region (MARAMA 2017 TSD) 

and the Technical Support Document for the Development of the 2025 Emission Inventory for 

PM2.s Nonattainment Counties in the MANE-VU Region, January 2012 (MARAMA 2025 TSD), 

respectively. 

For EGU emissions, PADEP used growth factors based on the Annual Energy Outlook 

(AE02011) and applied them to the 2007 inventory. Non-EGU emissions projections were 

based on Version 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 emission projection data. 

Nonpoint source emissions for 2017 and 2025 were developed similarly to the non-EGU 

point sources. Emission projections were based on Version 3.3 of the 2007 MANE-VU+VA 

inventory. MARAMA growth factors were developed using AEO fuel consumption forecasts, 

state-level employment projections, and other state-specific emission projection data. 

Nonroad source emissions for 2017 and 2025 were developed using NMIM model runs 

which contain default assumptions for projected years. Aircraft emissions were projected by 

applying activity growth data reported in the Federal Aviation Administration's (FAA's) 

Terminal Area Forecast (TAF) system for 2009-2030 (FAA2010). Railroad emissions were 

based on the MARAMA MANE-VU+Va inventory. 

The 2017 and 2025 onroad mobile source inventory was developed using EPA's highway 

mobile source emissions model MOVES2010. PADEP used local activity to replace default 

inputs in the model where appropriate 

OAMA staff reviewed the methodologies provided by PADEP and found them to be 

acceptable.