Technical Support Document (TSD) For

Bucks, Chester, Delaware, Montgomery, and Philadelphia Counties located in the

Philadelphia-Wilmington-Atlantic City, PA-NJ-DE

8 Hour Ozone Nonattainment Area:

State Implementation Plan (SIP) Attainment Demonstration

and Base Year Inventory

Revision Submitted August 2007 by the Bureau of Air Quality,

Pennsylvania Department of Environmental Protection;

Resubmitted on December 10, 2009 and on April 10, 2010

TSD Prepared April 2010 by

Alice H. Chow

Air Quality Analysis Branch, 3AP40

U.S. Environmental Protection Agency, Region 3

1650 Arch Street

Philadelphia, Pennsylvania 1 gi 03

Reviewed by Walter Wilkie, Director

Office ofAir Monitoring and Analysis (3AP40)

Dat$igne
The purpose of this document is to provide a technical summary of the Air

Quality Analysis Branch’s (AQAB) review ofthe emissions inventories submitted with

the Philadelphia Nonattainment Area 8 Hour Ozone State Implementation Plan (SIP) bythe Pennsylvania Department of Environmental Protection (PADEP). This reviewdetermines the approvability ofthe SIP Base Year Inventory and an evaluation ofthe

methods used for projection year 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 emissions reductioncredit program. Projection year inventories are essentially used to track progress; the

purpose of which is to demonstrate a reduction in emissions ofregulated sources from the

Base Year to a projected year. Bucks, Chester, Delaware, Montgomery, and Philadelphia

Counties are located in the Philadelphia Nonattainment Area and as such, were

designated as an 8 hour ozone nonattainment area with a Subpart 2 classification.

Subpart 2 area(s) are required to submit initial SIP base year inventories to EPA by June

15, 2006; with the final Base Year inventory due with the SIP to EPA by June 15, 2007.

Pennsylvania Department of Environmental Protection originally submitted Philadelphia

Nonattainment Area 8 Hour Ozone SIP and requested EPA’s approval on August 29,

2007. Errors were identified in the August 2007 submission for stationary point sources

due to facilities being counted multiple times as well as an error in calculation was foundfor projected 2008 emissions for area sources. PADEP has now revised and corrected the2002 Base Year Inventory with revised appendices for EPA approval.

Any questions pertaining to this technical summary should be directed to Walter

K. Wilkie, Associate Director, Office of Air Monitoring and Analysis, at 215-814-2150or via email at wilkie.walter(epa.gov.II. 2002 SIP Base Year Inventory

The SIP base year inventory is the primary inventory from which other

inventories (3-year cycle inventories, reasonable further progress inventories, modelinginventories) are derived. The Clean Air Act calls for State, local, and Tribal agencies to

ensure that the base year inventory is comprehensive, accurate, and current for all actualemissions. 1The base year inventory includes emissions estimates from stationary point

and nonpoint sources, onroad mobile sources, and nonroad mobile sources. For the 8-

hour ozone NAAQS, the pollutants to be inventoried are VOC, NOx and CO (carbonmonoxide). For the 8-hour ozone NAAQS, VOC, NOx and CO emissions should bereported as actual annual and actual summer weekday emissions (defined as an average

day’s emissions for a typical summer day during the ozone season). PADEP’s base year

“Emissions Inventory Guidance for Implementation ofOzone and Particulate Matter National Ambient

Air Quality Standards (NAAQS) and Regional Haze Regulations” EPA-454/R-05-00 1, August 2005
emission estimates for various operations, throughputs, work hours, as well as process

data, such as combustion unit data and fuel characteristics. PADEP provided its 2002actual summer weekday emissions for NOx and VOC at the facility level and by SourceClassification Codes (SCCs). “Summer weekday emissions” is defined by PADEP as an

average day’s emissions for a typical summer day during the ozone season.

For the 2002 Nonpoint Source emissions, also known as “area sources,” PADEP

provided an inventory that contained estimations of emissions by multiplying an emission

factor by some known indicator or activity level for each category at the county level.

These emissions are typically calculated on an annual basis because the activity data aregenerally only available on an annual basis. PADEP further converted these annualemissions to seasonal emissions, for ozone, the summer season is defined as peak ozoneseason months ofJune, July, and August. Seasonal estimates were calculated using

default monthly and weekly profiles from EPA’s Emissions Modeling Clearing House(EMCH). Nonpoint source estimates were provided by SCC.

The Nonroad Mobile Source 2002 inventory was prepared with EPA’s

NONROAD2005 model. NONROAD estimates fuel consumption and emissions oftotal

hydrocarbons, carbon monoxide, nitrogen oxides, sulfur dioxide, and particulate matter

for all nonroad mobile source categories except for aircraft, locomotives, and commercial

marine vessels. PADEP provided emission estimates for locomotive engines and aircraft

emissions separately. For locomotive engine emissions, PADEP projected emissionsfrom a 1999 survey using national fuel consumption information and EPA emission andconversion factors. For aircraft emissions, PADEP obtained operational information at

the Philadelphia International Airport (PHL) and the Federal Aviation Administration’s

(FAA) Terminal Area Forecast operations data for the Northeast Philadelphia Airport.Emission factors and operational characteristics in FAA’s Emissions and Dispersion

Modeling System (EDMS) were also generated. Commercial marine vessels emissions

from the Port of Philadelphia were estimated using EPA’s “Commercial Marine Activity

for Great Lakes and Inland River Ports in the United States, Final Report,” as well asdiscussions with tug boat operators. 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.

PADEP also used PPSUITE, an enhanced version ofthe Post Processor for Air Quality

software systems used for previous inventory and conformity submissions in

Pennsylvania. Traffic data source and fleet data inputs were supplied by the 2002PENNDOT Roadway Management System. PADEP provided Mobile6.2 input andoutput files for review. Mobile emissions values were given in units of tons per summerday and were provided by SCC.
Delaware, Montgomery, and Philadelphia Counties portion of the Philadelphia

Nonattainment Area. The 2008 projected inventory is required for reasonable further

progress (RFP) and the 2009 projected inventory is required for the attainment year.

Inventories were developed for all emission sources for both years.

PADEP used projection inventories for point and nonpoint sources prepared by

MACTEC Federal Programs, Inc., for the Mid-Atlantic Regional Air ManagementAssociation (MARAMA).

The Point Source emissions for 2008 and 2009 were projected, for both EGUs and

non EGUs, using growth factors from EPA’s Economic Growth and Analysis System,

Version 5.0 (EGAS 5.0) and the Department of Energy’s Annual Energy Outlook 2005

fuel consumption forecasts. In addition, for non-EGUs, state-supplied population,employment and other emission projection data were also applied to account for changes

in economic activity. Then, control factors were applied to account for future emission

reductions from on-the-books (OTB) control regulations and on-the-way (OTW) control

regulations.

The Nonpoint Source emissions for 2008 and 2009 were projected using growth

factors to account for population and economic activity. Then, as with point sources,control factors were used to account for future emission reductions from on-the-books

(OTB) control regulations and on-the-way (OTW) control regulations.

For the 2008 and 2009 Nonroad Mobile Source inventories, PADEP used EPA’s

NONROAD2005 model to generate these future inventories. The NONROAD model

allows for the calculation of past year, present year, and future year inventories (up to the

year 2050) to be generated. To estimate growth for locomotives, PADEP projected

emissions from a 1999 survey using national fuel consumption information and EPA

emission and conversion factors. Small aircraft growth was estimated from the Federal

Aviation Administration’s APO Terminal Area Forecast Detailed Report; for large airportgrowth, PADEP worked with the City of Philadelphia, Division of Aviation, and their

consultants (DMJM Aviation and Jacobs Consultancy, formerly known as Leigh-Fisher

Associates) to develop activity data required for modeling. For commercial marinevessels, PADEP used future fuel consumption growth and future emissions reductions to

calculate total future emissions, as contained in EPA’s “Final Regulatory Impact

Analysis: Control of Emissions from Marine Diesel Engines.”

The 2008 and 2009 Onroad Mobile Source inventories were generated using

EPA’s MOBILE6.2. In addition, PADEP used PEI’TNDOT’s Traffic Information System

and socioeconomic data. Specific growth rates for vehicle miles traveled (VMT) in the5-county Philadelphia area were from the Delaware Valley Regional PlanningCommission (DVRPC). The VMT growth inputs were incorporated with traffic data and