# Revision to the

Allegheny County Portion of the Pennsylvania State Implementation Plan

Supplement to the

Attainment Demonstration for the Liberty

- Clairton

PM 2.5 

# Nonattainment Area

2006 Standards

Allegheny County Health Department Air Quality Program

May 13

, 201 4Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds, Supp. May 201 4 Page

- 2

- {This page left blank for printing purposes}Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds, Supp. May 201 4 Page i 

## TABLE OF CONTENTS

1 Executive Summary

................................ ................................ ................................ .............. 1

2 Transportation Conformity Analysis

................................ ................................ .................. 3

2.1 Problem Statement

................................ ................................ ................................ ........... 3

2.2 Insignificance Statement

................................ ................................ ................................ .. 3

2.3 Onroad Mobile Source Inventory Development

................................ .............................. 4

2.3.1 Model

................................ ................................ ................................ ........................ 4

2.3.2 Emissions/Modeling Assistance

................................ ................................ ............... 6

2.3.3 Interagency Consultation

................................ ................................ .......................... 6

2.3.4 Methodology

................................ ................................ ................................ ............. 7

2.4 Insignifican ce Finding Factor 1: Motor Vehicle Emissions Constitute a Low Percentage of Total SIP Inventory

................................ ................................ ............................ 19

2.5 Insignificance Finding Facto r 2: Current State of Air Quality as Determined by Monitoring Data for PM 2.5 in the Liberty

- Clairton Area

................................ .......................... 22

2.6 Insignificance Finding Factor 3: Absence of SIP Motor Vehicle Control Measures

.... 26

2.6.1 Transportation Control Measures

................................ ................................ ........... 2 6

2.6.2 Current Control Requirements

................................ ................................ ................ 26

2.6.3 Review of RACM

................................ ................................ ................................ ... 26

2.7 Insignificance Finding Factor 4: Historical Trends and Future Projections of the

Growth of Motor Vehicle Emissions

................................ ................................ ........................ 28

2.8 Motor Vehicle Emissions Insignificance Findings Conclusions

................................ ... 30

3 Projected Electric Generating Unit Emissions

................................ ................................ . 31

4 Legal Documents

................................ ................................ ................................ ................. 39

4.1 Notice of Public Hearing and Comment Period

................................ ............................. 39

4.2 Transmittals of Hearing Notice to PA DEP and EPA

................................ .................... 40

4.3 Proof of Publication and Certification of Public Hearing

................................ .............. 42

4.4 Summary of Public Comments and Res ponses

................................ .............................. 44

4.5 Certification of Adoption

................................ ................................ ............................... 49

References

................................ ................................ ................................ ................................ .... 50Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds, Supp. May 201 4 Page ii

List of Tables

................................ ................................ ................................ ................................ . ii

List of Figures

................................ ................................ ................................ ............................... i ii

List of Appendices

................................ ................................ ................................ ........................ i ii

Acronyms and Abbreviations

................................ ................................ ................................ ..... i v



### LIST OF TABLES

Table 2

- 1. Summary of Analysis Tools

................................ ................................ ...................... 8

Table 2

- 2. Summary of Mobile Source Data Parameters for Liberty

- Clairton

..................... 9

Table 2

- 3. Base and Forecasted Vehicle Miles of Travel (Millions)

................................ ...... 15

Table 2

- 4. Vehicle Population Estimated Classified by MOVES Source Type

.................... 16

Table 2

- 5. Liberty

- Clairton PM 2.5 NAA Onroad Emissions Summary by Road Type

(Tons/Year)

................................ ................................ ................................ ............... 17

Table 2

- 6. Liberty

- Clairton PM 2.5 NAA Onroad Emissions Summary by Fuel Type*

(Tons/Year)

................................ ................................ ................................ ............... 17

Table 2

- 7. Baseline 2007 Emissions (T ons/Year)

................................ ................................ .... 20

Table 2

- 8. Future Projected 2014 Emissions (Tons/Year)

................................ ..................... 20

Table 2

- 9. Onroad Highway Mobile Sources RACM Analysis Summary

............................ 26

Table 3

- 1. PJM Unit Deactivations by Plant Capacity, 2012

- 2015

................................ ........ 33

Table 3

- 2. CAMD Reported 2012 S O 2 and NO

x Emissions (with Expected Reductions in

PJM Territory for 2013

- 2015) and Interstate Transport Rules Projected Emissions, CSAPR States

................................ ................................ ........................ 34

Table 3

- 3. Federal Consent Decrees for Units in PJM states

................................ ................. 36Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds, Supp. May 201 4 Page iii 

### LIST OF FIGURES

Figure 1

- 1. Map of the Liberty

- Clairton Area within the Pittsburgh

- Beaver Valley Area

.. 1

Figure 2

- 1. PM 2.5 FRM Annual Design Values, Allegheny County, 2000

- 2012

................... 23

Figure 2

- 2. PM 2.5 FRM 24

- Hour Design Values, Allegheny County, 2000

- 2012

.................. 23

Figure 2

- 3. Liberty and Clairton FRM Annual Design Values with Projected to 2014

...... 24

Figure 2

- 4. Liberty and Clairton FRM 24

- Hour Design Values with Projected to 2014

.... 24

Figure 2

- 5. Population Trends for Allegheny County, 2000

- 2010

................................ ......... 28

Figure 3

- 1. CSAPR States

................................ ................................ ................................ ......... 32

Figure 3

- 2. PJM Interconnection Territory

................................ ................................ ............ 32

Figure 3

- 3. Long

- Term Reported and Expected/Projected SO 2 (tons), CSAPR States

...... 35

Figure 3

- 4. Long

- Term Reported and Expected/Projected NO

x (tons), CSAPR States

...... 35



### LIST OF APPENDICES

Appendix A. Detailed EGU Data by State/Unit

Appendix B. Supporting EGU Documentation

B

- 1

. Homer City Plan Approval

B

- 2

. PJM Deactivations

B

- 3

. Consent Decrees

Appendix C . Back

- Trajectory AnalysisLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds, Supp. May 201 4 Page iv



### ACRONYMS AND ABBREVIATIONS

ACHD Allegheny County Health Department

BHSTE Bureau of Highway Safety and Traffic Engineering

BPR Bureau of Public Roads

CAIR Clean Air Interstate Rule

CA LEV II California Low Emission Vehicle II Program

CAMD Clean Air Markets Division

CFR Code of Federal Regulations

CSAPR Cross

- State Air Pollution Rule

DSI Dry Sorbent Injection

ECO Electro

- Catalytic Oxidation

EGU Electric Generating Unit

EPA The United Sta tes Environmental Protection Agency

FHWA Federal Highway Administration

FR Federal Register

F E M Federal Equivalent Method monitor

FGD Flue Gas Desulfurization

FRM Federal Reference Method m onitor

GHG Greenhouse Gas

GVWR G ross V ehicle W eight R ating

HPMS Highway Performance Monitoring System

I/M Inspection and Maintenance Program

MANE

- VU Mid

- Atlantic/Northeast Visibility Union

MOVES Motor Vehicle Emission Simulator model

MPO Metropolitan Planning Organization

MSA Metropolitan Statistical Area

MVEB Motor Vehicle Emissions Budget

μ g/m3 Microgram per cubic meter

μm Micrometer, or micron NAAQS National Ambient Air Quality Standard

NAA Nonattainment Area

NEI National Emission Inventory (EPA database)

NH 3 Ammonia

NLEV National Low Emission Vehicle Program

NO

x Oxides of N itrogen

NTD National Transit Database

OBD II On

- Board Diagnostics

PA DEP Pennsylvania Department of Environmental Protection

PCV Pennsylvania Clean Vehicles Program

PennD OT Pennsylvania Department of Transportation

PM Particulate Matter (airborne) of any size

PM 2.5 Particulate Matter less than or equal to a nominal 2.5 microns in aerodynamic

diameter, also referred to as fine particulates

PM 10 Particulate Matter less than or equal to a nominal 10 microns in aerodynami c

diameterLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds, Supp. May 201 4 Page v

RACM Reasonably Available Control Measure

RACT Reasonably Available Control Technology

RMS Roadway Management System

RPO Regional Planning Organization

RTO Regional Transmission Organization

RVP Reid Vapor Pressure

SIP State Implementation Plan

SO 2 Sulfur Dioxide

SO

x Sulfur Oxides

SPC Southwestern Pennsylvania Commission

SWPA Southwestern Pennsylvania

TC M Transportation Control Measure

TIGER Topologically Integrated Geographic Encoding and Referencing

TR Transport Rule TS|Pechan TranSystems|E.H. Pechan & Associates

VMT Vehicle M iles T raveled

VOC Volatile Organic Compound{This page left blank for printing purposes}Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 1



## 1 Executive Summary

On June 21, 2013, the Pennsylva n ia Department of Environmental P rotection (PA DEP)

submitted to the United States Environmental Protection Agency ( EPA ) Region III a revision to the State Implementation Plan (SIP) pertaining to the attainment demonstration for the 2006

PM 2.5 N ational A mbient A ir Q uality S tandards (NAAQS) for the Liberty

- Clairton nonattainment

area. T his SIP revision is a supplement to that submittal and the Allegheny County Health Department (ACHD) SIP document dated May 10, 2013.

PM 2.5 describes particulate matter that is less than or e qual to 2.5 micrometer s (μm, or micron)

. In 1997, EPA promulgated the PM 2.5 NAAQS of 15 .0 μ g/m 3 on an annual basis and 65 μ g/m 3 on a 24

- hour basis. In 2006

, the 24

- hour PM 2.5 standard was lowered to 3 5 μg/m3

. 1

Most of the Pittsburgh Metropolitan Statistical Area (MSA) was designated as an 8

- county
nonattainment area for the 1997 and 2006 PM 2.5 NAAQS

, called the Pittsburgh

- Beaver Valley

a rea

. A portion of southeastern Allegheny County, the Liberty

- Clairton area, was designated as

a separate nonatt ainment area within the larger Pittsburgh

- Beaver Valley area (areas shown in Figure 1

- 1 below).

Figure 1

- 1

. Map of the Liberty

- Clairton Area within the Pittsburgh

- Beaver Valley Area

1 EPA NAAQS: http://www.epa.gov/air/criteria.htmlLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 2

The June 21, 2013 SIP submittal provide d a control strategy and attainment demonstration for

the 2006 PM 2.5 NAAQS for the Liberty

- Clairton nonattainment area

. Using emissions

inventories and modeling al ready included as part of th e June 21, 2013 SIP submittal, t his supplem ental SIP revision demonstrates that motor vehicle emissions for direct PM 2.5 and NO

x are insignificant contributor s to the air quality problem in the Liberty Clairton nonattainment

area for both the 1997 and 2006 PM 2.5 NAAQS

. As a result , in accordance with the rules

established in 40 CFR 93.109 ( f ) and under EPA approval of the insignificance findings

, the area

would not be required to submit motor vehicle emissions budget s (MVEB s ) for direct PM 2.5 and

NO

x or satisfy the emissions analysi s for 40 CFR 93.118 or 40 CFR 93.119 for either the 1997 or

2006 PM 2.5 NAAQS.

Additionally, pursuant to 40 CFR 93.102( b )(2)(v)

, the area is not required to satisfy the emissions analysis requirements of either 40 CFR 93.118 or 93.119 for SO 2 , VOC

, or NH 3 because the submitted SIP did not establish motor vehicle emissions budge t s for any of these

precursors as part of an attainment strategy

.

The modeling demonstration for mobile sources was perfor med using the Motor Vehicle Emissions Simulator (MOVES) mod el

. Years included in the inventory and modeling were 2007

for the baseline case

, and 2014 for the future projected case.

This supplemental SIP revision also updates and revises the projected electric generating unit (EGU) emissions analysis included in the June 21, 2013 SIP submittal

. Although t he Clean Air Interstate Rule (CAIR) remains in place for EGU emissions allocations, the future case 2014

Cross

- State Air Pollution Rule (CSAPR) inventory was used for the modeling demonstration

since it reflected a more representative inventory. This supplemental SIP revision provides an updated and more detailed analysis of current and expected EGU emissions to support the use of

CSAPR in the modeling demonstration

.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 3



## 2 Transportation Conformity Analysis

2.1 Problem Statement

Section 176 of the Clean Air Act ( CAA ) provides a mechanism by which federally funded or approved highway and transit plans, programs, and projects are determined not to produce new air quality violations, worsen existing violations, or delay timely attainment of the NAAQS or delay any interim milestones . EPA regulations in 40 CFR P art 93 pertaining to transportation conformity provide that motor vehicle emission “budgets” establish caps of these emissions that cannot be exceeded by the predicted transportation s ystem emissions in the future.

Transportation agencies in Pennsylvania are responsible for making timely transportation conformity determinations. The responsible agency in the Pittsburgh a rea is the Southwestern Pennsylvania Co mmission (SPC) , the designated Metropolitan Planning Organization (MPO) under federal transportation planning requirements.

40 CFR 93.102 requires conformity determinations to be applicable to direct emissions of PM 2.5 and NO

x ( unless a determination is m ade that transportation

- related emissions are not significant

contributors to PM 2.5 )

, and to emissions of SO 2 , VOC, and NH 3 only if the applicable SIP or SIP submittal establishes an approved or adequate motor vehicle emissions budget as part of a reasonab le further progress, attainment

, or maintenance strategy

.

The June 21, 2013 SIP submittal showed that controls for VOC and NH 3 contributed minimally

to modeled reductions and that SO 2 emissions from mobile sources are very small in comparison to those from stationary sources. Therefore, MVEBs were not established for these precursors.



### 2.2 Insignificance Statement

F ederal t ransportation c onformity requirements in 40 CFR Part 93.109 allow for pollu tants/precursors to be exempt from conformity analysis under certain circumstances.

40 CFR 93.109 (f) Areas with insignificant motor vehicle emissions

. Notwithstanding the other paragraphs in this section, an area is not required to satisfy a regional emissions analysis for §93.118 and/or §93.119 for a given pollutant/precursor and NAAQS, if EPA finds through the adequacy or approval process that a SIP demonstrates that regional motor vehicle emissions are an insignificant contributor to the air quality problem for that pollutant/precursor and NAAQS. The SIP would have to

demonstrate that it would be unreasonable to expect that such an area would experience enough motor vehicle emissions growth in that pollutant/precursor for a NAAQS

violation to occur. Such a finding would be based on a number of factors, including the percentage of motor vehicle emissions in the context of the total SIP inventory, the current state of air quality as determined by monitoring data for that NAAQS, the

absence of SIP moto r vehicle control measures, and historical trends and future projections of the growth of motor vehicle emissions

. . . { emphasis added }Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 4

For the reasons outlined in Sections 2.4 through 2.7 of this document, ACHD has determined that highway emissions of d irect P M 2.5 and N O

x are insignificant contributors to the

nonattainment of the 1997 and 2006 PM 2.5 NAAQS for the Liberty

- Clairton area and that no

m otor v ehicle e missions b udgets are required for this nonattainment area and that the area should not be required by EPA to satisfy a regional emissions analysis for § 93.118 or § 93.119 for direct

PM 2.5 and NO

x .



### 2.3 Onr oad Mobile Source Inventory Development

This section describes the approach used to develop the on road mobile source inventory for the Liberty

- Clairton area , including a discussion of the data sources, param e ters, and overall analysis approach. The highway inventory utilizes EPA’s new emission model, the Moto r Vehicle Emissions Simulator ( MOVES )

. The analysis ap proach and data assumptions were consistent with EPA technical guidance and other statewide inventories conducted by PA DEP. This

include d the use of roadway and traffic count data from the Pennsylvania Department of Transportation (PennDOT), accepted pos t processing software to estimate hourly speeds, and traffic and vehicle population growth rates utilizing available PennDOT and regional data sources. Other traffic, environmental, vehicle fleet, fuel

, and control strategy inputs have been prepared using the latest local

- specific planning assumptions.



### 2.3.1 Model

MOVES2010a was used as the most recent version of the MOVES software. MOVES2010a represents a significant departure from the previous MOBILE6.2 model , including new vehicle

emission rates reflectin g the latest regulations pertaining to fuel efficiency and vehicle emission

standards

.

MOVES2010a results can depend upon the unique circumstances of each nonattainment or

maintenance area. The emission comparisons to MOBILE6.2 depend very heavily on the pollutants of concern, the dates of concern, and on existing local control measures, traffic patterns, fleet age, and the mix of cars and trucks. In some cases, a change from MOBILE6.2 to MOVES2010/MOVES2010a may result in increased emissions estimates, while in other cases it may result in decreased emissions estimates for various time periods. 2

Over the last ten years, EPA’s in

- use data about technologies such as Tier 2, second

- generation onboard diagnostics (OBD II), and enhanced evaporative emission control systems have dramatically improved. For MOVES2010, EPA has been able to carefully study these newer technologies, examining millions of results for light

- duty vehicles. A detailed analysis of 70,000

vehicles in Arizona’s Inspection and Maintenanc e ( I/M ) program provided information on how

vehicles from the late

- 1990’s and early 2000’s age. Other I/M and remote sensing data and special purpose studies helped EPA to better understand trends in VOC, CO, and NO

x emissions for light

- duty cars and truc ks. In reviewing these data, EPA found little change in CO from the

2 EPA MOVES web site: http://moves.supportportal.com/link/portal/23002/23024/Article/32 004/How

are

- the

- changes

- in

- emission

- rates

- in

- MOVES2010

- or

- MOVES2010a

- expected

- to

- affect

- attainment

demonstrationsLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 5

original MOBILE6.2 projections, lower VOC emissions, and a noticeable increase in NO

x emissions.

Also in support of MOVES2010 development, EPA conducted a landmark study of PM

emissions , testing nearly 500 gasoline

- fueled light

- duty cars and trucks in Kansas City, MO. Due to the technical difficulties associated with measuring PM emi ssions, the Kansas City study

– a collaborative effort including EPA, DOT, the Department of Energy (DOE) , and the automotive and petroleum industries

– was the largest such study ever conducted. The Kansas City study confirmed that PM emissions from light

- duty gasoline

- fueled vehicles are higher than earlier predicted, and clearly showed that cold ambient t emperatures can dramatically increase

PM start emissions. The MOVES2010 model includes these increases in PM start emissions at low temperatures.

EPA’s understanding of emissions from heavy

- duty vehicles has continued to improve since

MOBILE6.2 was issu ed. Most earlier heavy

- duty emission rates were based on certification

tests of then

- new, mid

- 1990’s engines. For MOVES2010, EPA has been able to analyze data on

more than 400 in

- use trucks, some in the laboratory and some with on

- road measurement equipm ent. This allowed EPA to understand how real trucks pollute at a range of speeds and driving conditions. EPA also has been able to better incorporate emissions from heavy

- duty diesel crankcase ventilation and from extended idling (also known as “hotellin g”)

– two emission processes that were relatively unstudied at the time MOBILE6.2 was developed. The incorporation of this additional data accounts for the increases in heavy

- duty NO

x and PM

emissions reflected in MOVES2010. Emission differences in MOVES2010 are especially large for heavy

- duty PM emissions because they reflect updated data on the effects of both speed and vehicle deterioration not previously available. 3

In MOBILE6 .2 , PM emission rates had little or no variation due to vehicle speed, deterioration or aging effects, or ambient temperature. T he development of MOVES included the incorporation of the results of significant amounts of vehicle testing that was not included in

MOBILE6 .2 . Thus, within MOVES, the PM emission rates now vary d epending on the temperature, speed, and age of vehicles. The relative effect of each of these factors will also differ from year to year, as different emission standards are phased into the fleet, since the percentage change from the base MOBILE6.2 PM emi ssion s rates to the MOVES base emission rates varies by model year.

3 Taken from “ EPA Releases MOVES2010 Mobile Source Emissions Model: Questions and Answers,”

EPA

- 420

- F

- 09

- 073, U.S. EPA, Office of Transportat ion and Air Quality, December 2009 : http://www.epa.gov/otaq/models/moves/420f09073.pdfLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 6



### 2.3.2 Emissions/Modeling Assistance

As described in the SIP submittal of June 21, 2013

, ACHD contracted TranSystems|E.H. Pechan

& Associates (TS|Pechan) to conduct an in

- depth investigation of transportation sources of PM 2.5 in southern Allegheny County

. 4

Specifically, TS|Pechan reviewed existing PM 2.5 inventories and related documents for local mobile sources. The review included field work, records and data sear ches, and calculations

necessary to develop 2007 and projected 2014 mobile source inventories . Furthermore, TS|Pechan performed a reasonably available control measures (RACM) analysis, which included examining reasonably available control technology (RACT ), on all mobile sources listed in the revised 2007 SIP emissions inventory.



### 2.3.3 Interagency Consultation

The analysis methodologies and data sources have undergone review from multiple agencies. The Pennsylvania Transportation Air Quality Work ing G roup
, a state

- wide interagenc y consultation group including f ederal (EPA, Federal Highway Administration ( FHWA ) ), state (PennDOT, PA DEP), and regional (MPOs) agencies

, has played a key role in reviewing the MOVES emission calculation process, local data sources , and methods in determining future growth for vehicle miles of travel (VMT) and vehicle population.

4 ACHD contract title Consultant Technical Support for Air Pollutant Area and Mobile Sources Analyses

.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 7



### 2.3.4 Methodology

Guidance documents from EPA were used to develop the base and future year emissions inventories for the Liberty

- Clairton 2006 PM 2.5 NAAQS nonattainment area ( N AA) and include:

 Policy Guidance on the Use of MOVES2010 for SIP Development, Transportation Conformity, and Other Purposes, EPA Office of Air and Radiation, EPA

- 420

- B

- 09

- 046,

December 2009 (EPA, 2009)

 Technical Guidance on the Use of MOVES2010 for Emission Inventory Preparation in State Implementation Plans and Transportation Conformity, EPA Office of Air and Radiation, and Office of Transportation and Air Quality, EPA

- 420

- B

- 10

- 023, April 2010 (EPA, 2010a)

 Motor Vehicle Emission Simu lator, User Guide for MOVES2010a , EPA

- 420

- B

- 10

- 036, August 2010 (EPA, 2010b)

The highway mobile source emission inventory was developed using available travel data and

EPA’s MOVES2010a emission model. The methodologies us ed in the development of this

inv entory conform to the recommendations provided in EPA’s Technical Guidance , cited above

. A mix of local data and national data (internal to MOVES2010a) has been used for this

submission. Local data was used for the more significant inputs into the proces s and include:

 Vehicle miles traveled by vehicle type ( VMT )

 Average speed distribution

 Vehicle type mixes

 Source type popu lation (for light

- duty vehicles)

 Vehicle age distribution

 Hourly distributions

 Meteorology data

 Inspection/Maintenance (I/M) program

 Fuel supply

The data used reflect s the latest planning assumptions and is primarily based on data assembled

from PennDOT’s Bureau of Motor Vehicles , the local MPO (SPC) and other local/national

sources. Where available

, 2007 data was used, however

, 2008 data (projected back to 2007) that

had already been vetted by stakeholders was also used as appropriate.

The analysis methodology is consistent with past statewide inventory efforts

, including the 2008 National Emissions Inventory ( NEI ) submission. This includes the use of custom post processing software to calculate hourly speeds and prepare key traffic input files to the

MOVES2010a emission model.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 8

Analysis Tools

The mobile vehicle emissions inventory analysis utilizes several key software/programs for producing the county emissions totals. These tools are outl ined in Table 2

- 1

.

Table 2

- 1

. Summary of Analysis Tools

Tool Purpose

MOVES2010a Produces emission rates for each PM 2.5 precursor

PPSUITE Processes the highway data; calculates hourly congested speeds for each state

roadway segment; prepares MOVES2010a input files; processes MOVES2010a output files into a summary report.

CENTRAL Provides a batch menu driven process to execute PPSUITE, MOVES2010a, and

other MYSQL steps.

T he Liberty

- Clairton PM 2.5 on road inventory was developed using EPA’s MOVES2010a emission model. EPA’s MOVES model was officially released on March 2, 2010 and was followed with a revised version (MOVE S2010a) in August 2010. The MOVES2010a model provides a more robust estimate of emissions as compared to its predecessor MOBILE6.2. MOVES2010a has been integrated with local traffic, vehicle fleet, environmental, fuel, and control strategy data to estima te emissions.

PPSUITE is an enhanced version of the Post Processor for Air Quality software system that has been used for previous inventory and conformity submissions in Pennsylvania. The software has undergone significant revisions to ensure consistenc y with the MOVES2010a. PPSUITE was used to calculate hourly congested speeds for each roadway link, apply vehicle type fractions, aggregate VMT, prepare MOVES2010a traffic

- related input files

, a nd process MOVES2010a

outputs. The PPSUITE software and proc ess methodologies are consistent with that used for state inventories and transportation conformity analyses throughout Pennsylvania.

CENTRAL is a menu

- driven software platform that executes the PPSUITE and MOVES2010a processes in batch mode. The softw are allows users to execute runs with a variety of input options and integrates custom MYSQL steps into the process. CENTRAL provides important quality control and assurance steps including file naming and storage automation.

Data Sources

The latest planning assumptions were used in preparing inputs to the MOVES emission model. The data includes Allegheny County specific parameters regarding temperatures, fuel, and fleet age. Specific traffic conditions and vehicle population have been prepared for the Liberty

Clairton nonattainment area. Much of the data has been prepared as part of inventory efforts in support of st atewide analyses for the PA DEP, and has undergone review and acceptance by the Pennsylvania Transportation Air Quality Work ing G roup, the interagency consultation group that consists of EPA, FHWA, PennDOT, PA DEP, and MPOs (SPC in this case).Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 9

T able 2

- 2 outlines all of the major data sources and processes proposed for this effort. The subsequent sections expand on these in greater deta il.

Table 2

- 2

. Summary of Mobile Source Data Parameters for Liberty

- Clairton

Parameter Source

Analysis Years 2007, 2014

Season Annual

– 12 Month Approach

– 1 representative day per month

MOVES Domain / Calculation

type County / Inventory Mode

Pollutants PM 2.5 , NO

x , SO 2 , NH 3 , VOC

Emission Calculation Method Inventory Mode

Area Liberty Clairton Traffic Inputs

VMT Data Source 2008 PennDOT R oadway M anagement S ystem ( RMS ) “Snapshot” Integrated with PennDOT BHSTE GIS Signal Locations VMT Adjustments For 2008

- 2007 : Highway Performance Monitoring System ( HPMS ) County by

Functional Class VMT

For 2008

- 20 14: Functional Class VMT & Growth Rates based on SPC Regional Travel Demand Model Local VMT Adjustments Using GIS, t he portion of TIGER local roadway mileage in the nonattainment

maintenance area vs. county total

– Appl y ratio to the total HPMS local VMT reported for the county Seasonal Adjustments Traffic Data Report PennDOT Bureau o f Public Roads ( BPR ) (2008 Data) Hourly Patterns Traffic Data Report PennDOT BPR (2008 Data)

Annual VMT Calculated by PPSUITE Hourly Speeds Calculated by PPSUITE (Minimum Speed = 2.5 miles per hour ) Road Type Distribution Calculated by PPSUITE; User assigned Road Type to RMS links MOVES Inputs Vehicle Age Distribution 2010 registration data for light

- duty vehicles from PennDOT’s Bureau of Motor Vehicles Registration Database; MOVES Defaults for Heavy

- Duty

Vehicles

Fuel Parameters (Gasoline/Diesel) MOVES2010a default data (except for gasohol market penetration and Reid vapor pressure ( RVP ) values

, which were updated)

I/M Parameters PA OBD II & Idle (Changes made to default I/M Program Parameters) Temperatures 10

- year monthly average hourly airport temperatures

- humidity from WeatherBank, Inc. ( www.weatherbank.com )

Month VMT Fractions Calculated based on seasonal adjustment factors Day VMT Fractions Calculated based on seasonal adjustment factors

Hour VMT Fractions Calculated by PPSUITE Ramp Fraction MOVES Defaults (8% of vehicle hours traveled ) Source Type Population 2007

- Based on 200 8 registration data and MOVES default VMT and population. 2014

- Based on projected household gr owth from Woods and

Poole Inc. ( M ethodology approved by PA Transportation Air Quality Work ing Group

, consisting of EPA, FHWA, DEP, Penn DOT

. ) Early NLEV/PCV/CA LEV II EPA provided MOVES override database files

Stage II MOVES Default Process Alternative Vehicle Technology MOVES Default (no input file provided)Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 10

Base Traffic Data/Fleet Data Inputs

a. Baseline Traffic Volumes

The 2008 PennDOT RMS data base serves as the primary source for the county and

functional class VMT estimates and roadway volumes for the baseline traffic data . The

RMS has been updated to provide a “snapshot” of the regional roadway system and

traffic volumes in 2008 and also inc ludes traffic signal locations. As 2007 RMS data was not readily available, HPMS data was used to factor the 200 8 volumes back to 2007

levels

, with individual adjustment factors calculated for each of the functional classes as they exist in the RMS database and are represented in the NAA. This procedure applies to all VMT, gasoline and diesel. Note that there are no limited access freeways or expressways within the Liberty

- Clairton NAA and

, as a result, growth factors were not developed for these roadway classifications.

The RMS database only includes roadways maintained by PennDOT. As a result, a significant number of local roadways are not fully represented in the database. PennDOT has procedures to estimate county local VMT as part of the HPMS reporting system. For the Liberty

- Clairton inventory, local VMT was estimated as a percentage of the Allegheny County total. Using GIS, the portio n of Topologically Integrated Geographic Encoding and Referencing ( TIGER ) local roadway mileage in the nonattainment area was calculated and compared to the total county mileage to estimate the relative portion.

The local VMT estimation for the nonattainm ent area was first derived using 3 different methods: 1) The PennDOT maintained Road Management System (RMS) was queried. GIS software was used to determine all local roadways within the nonattainment area, with VMT calculated directly from the data in t hat dataset. 2) The Census TIGER GIS file was used to determine the total roadway centerline mileage both within the nonattainment area and within the county as a whole. The ratio of the mileage within the nonattainment area to the total county mileage w as use to allocate the total local roadway VMT as reported in the Federal HPMS for Allegheny County. 3) The percent of population (residents) within both the nonattainment area and the county as a whole was determined using census data. The ratio of thes e values was then applied to the local roadway VMT reported in the Federal HPMS database to obtain an estimate.

The method reporting the greatest local roadway VMT, used to be conservative, was the second method using roadway centerline mileage. The rati o was 1.76% of the total Allegheny County local VMT falling within the nonattainment area boundaries.

b. Seasonal Adjustments

The PPSUITE framework developed for this analysis calculates annual emissions by running MOVES for a single representative day f or each month of the year (12 runs). Per

the MOVES T echnical G uidance option, monthly analyses were conducted only for the weekday option and factored to represent monthly/annual totals. The daily and monthly

seasonal adjustment factors were developed fr om data contained in the document: 2008Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 11

Pennsylvania Traffic Data Report

, prepared by PennDOT’s Bureau of Public Records (BPR, PennDOT, 2008) . The seasonal and daily factors are based on statistical analyses of 2008 traffic counts taken at permanent and i n

- pavement automatic traffic recorder s.

c. Congested Speeds

PPSUITE calculates congested speeds by hour of the day for each roadway segment and provides the information as input to the MOVES2010a software. The speed calculations

found in PPSUITE are a v ariation of the BPR speed

- flow formula and are fully consistent with the guidance provided by EPA and FHWA. To disaggregate the daily RMS volumes to hourly v alues , auto and truck hourly pattern data from PennDOT’s 2008 Pennsylvania Traffic Data Report w ere used to develop distributions of traffic by hour,

which in turn were used to create an input file used by PPSUITE in its internal

calculations.

d. Vehicle Population

Vehicle population is a key component in the calculation of start and evaporative

e missions. MOVES2010a requires vehicle population by 13 source types in order to determine evaporative emissions. Data from PennDOT registrations w ere first used to estimate county

- specific values. Allegheny County 2008 vehicle registration data was used to estimate vehicle population for light

- duty vehicles and school buses. For transit buses, data from PennDOT and the National Transit Database (NTD) w ere used to estimate transit bus populations for the county

. Next, the county information was

factored to represent the Liberty

- Clairton portion of the region. These adjustment factors were based on the proportion of population in the nonattainment area as compared to the county total. For all other heavy

- duty vehicles, M OVES2010a national default vehicl e mileage accumulation rates were applied to regional heavy

- duty VMT to estimate heavy

duty vehicle population. This methodology is consistent with the approach used in other areas in PA with nonattainment areas that do not constitute an entire county. T he approach is also consistent with EPA recommended practice. No other sufficiently vetted

data source was identified that would allow for additional refinement and meet the minimum requirements for data robustness.

Vehicle mileage accumulation by age is accounted for internally in the MOVES model. The MOVES table SourceTypeAge lists for each source type by age the relative annual mileage accumulation rate, the annual per vehicle mileage accumulation for a given MOVES SourceUseType and age, relative to t he highest annual mileage accumulation rate within the HPMS Vtype. This is a national default MOVES table, not typically modified by MOVES users. The relative mileage accumulation rates are used to weight the age distribution data, essentially yielding a VMT

- based age distribution. As an example, a 5

- year old single unit short

- haul truck has a relative mileage accumulation

rate of 0.306 while a 10

- year old single unit short

- haul truck has a relative mileage accumulation rate of 0.187. Thus, the MOVES mo del assumes that each 5

- year old single

- unit short haul truck is being driven about 64% more than a comparable 10

- year old truck per year. These mileage accumulation rates are used in combination with theLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 12

age distribution data to determine the by

- model

- ye ar weight of the by

- model

- year emission rates.

Only a single relative mileage accumulation rate is used for each model year and source use type combination. Therefore, data on the mileage accumulation rates of all 5

- year

old trucks (of a given source use type) would be considered to determine the weighted average accumulation rate of 5

- year

- old trucks.

e. VMT by Source Type

For input to the MOVES model, t otal VMT must be disaggregated in to the six HPMS vehicle groups (passenger cars, other 2

- axle light trucks, buses, single

- unit trucks, combination trucks, motorcycles)

. This input is done internally by PPSUITE based on the vehicle mix patterns provided as input to the software. For this inventory

, the vehicle mix patterns were calculated utilizing a co mbination of the following sources:

 2008 RMS truck percentages

 PennDOT and 2008 NTD transit data

 2008 school bus registration data

 EPA’s MOVES2010a default distribution for all other source type s

The functional class groupings used in PPSUITE are necessary for HPMS reporting,

however

, they are not compatible with MOVES2010a. As a final step, PPSUITE re

aggregates the VMT into MOVES2010a’s roadway classifications. This step is somewhat redundant as all roadways in the Liberty

- Clairton PM 2.5 NAA a re classified in MOVES2010a as urban, non

- restricted.

f. Vehicle Age Distribution

Vehicle age distributions for each of the 13 source types are a required input into

MOVES2010a and PPSUITE . The distributions reflect the percentage of vehicles in the

fle et up to 31 years old and must total 100 percent

. R ecent 2010 registration data f rom PennDOT’s motor v ehicles r egistration d atabase has indicated a substantially older fleet

than recorded in the 2002

- 2008 period. As such

, the 2010 vehicle age distributio ns have been used for this inventory. Due to insufficient data, only data for light

- duty vehicles

are used ; heavy

- duty vehicle age distributions are based on the MOVES2010a defaults

for Allegheny County. As the registration data download ed wa s based on M OBILE6.2 vehicle categories, t he data was converted to source types using the EPA convertor spreadsheets provided with the MOVES2010a emission model.

The MOVES 2010a registration data defaults for Allegheny County are national defaults for heavy

- duty vehi cles, relative to the calendar year being modeled. This is appropriate for heavy

- duty vehicles, per the EPA guidance, as heavy

- duty vehicles frequently operate in areas outside of the area in which they are registered.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 13

I/M and Fuel Parameters

a. I/M Pr ogram

The I/M program inputs to the MOVES2010a model are based on past and current

pro grams at the county level (all Pennsylvania I/M programs are based on county boundaries). The MOVES2010a model has simplified the I/M program input parameters compared to MOBILE6.2. The default I/M program parameters included in

MOVES2010a were examined and changes made to the defaults to match the actual local

program.

The Pennsylvania I/M program was upgraded and expanded throughout the state with a phase

- in period s tarting in September 2003 and was f ully implemented by June 2004. The program requirem ents vary by region and include on

- board diagnostics (OBD) technology. The program, named PA OBD II, has been implemented in the Pittsburgh Region

, including Allegheny County. The program consists of the OBD II program, along with tailpipe tests (idle in t his region) and gas cap tests.

b. Fuel Assumptions

The MOVES2010a default fuel formu lation and fuel supply data was reviewed and updated based on available local volumetric fuel property information provided by PA

DEP . The gasohol market penetration and RVP values w as also updated , with MOVES2010a default data used for the remaining parameters. Updated assumptions

included:

 0.00 percent ethano l (for summer RVP months)

 6.78 percent ethanol (for winter months)

 7.8 RVP during summer months

Meteorology Data

Updated weather information was obtained from WeatherBank, Inc. ( www.weatherbank.com ) using the 10

- year average minimum and maximum monthly temperature and relative humidity

values obtained at the Pittsburgh International Airport (PIT)

. The MOVES2010a model requires temperature and relative humidity data for each hour of the day. EPA’s data converters were used to convert minimum and maximum daily temperatures to an hourly temperature profile that could be input to MOVES2010a. These assumptions are consistent with recent inventory efforts

.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 14

Vehicle Technology/Programs

a. Federal Programs

Current f ederal vehicle emissions control and fuel programs are incorporated into the

MOVES2010a software. These include the National Program standards covering model year vehicles through 2016. Modifications of default emission rates were required to

reflect th e early implementation of the National Low Emission Vehicle Program (NLEV) program in Pennsylvania. To reflect these impacts, EPA has released instructions and input files that can be used to model these impacts (EPA, 2010c). This inventory utilized

the August 2010 version of the files ( http://www.epa.gov/oms/models/moves/tools.htm ).

b. State Programs

The Pennsylvania Clean Vehicles (PCV) Program, adopted in 1998, incorporated the

California Lo w Emission Vehicle (CA LEV II ) Program by reference, although it allowed automakers to comply with the NLEV program as an alternative to this Pennsylvania program until model year 2008 . Beginning with model year 2008, “new” passenger cars and light

- duty t rucks with a gross vehicle weight rating (GVWR) of 8,500 pounds or less

, that are sold or leased and titled in Pennsylvania

, must be certified by the

California Air Resources Board or be certified for sale in all 50 states. For this program,

a “new” vehic le is a qualified vehicle with an odometer reading less than 7,500 miles.

PA DEP and PennDOT worked with the automobile manufacturers, dealers and other interested business partners and finalized procedures for complying with these new requirements

.

The impacts of this program were modeled for all analysis years beyond 2008 using the

same EPA guidance and tools as downloaded for the early NLEV analysis. EPA has also provided input files that reflect the CAL LEV II program

. Modifications were made to
th e se files to reflect the 2008 start date in Pennsylvania.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 15

Traffic Growth Assumptions

Traffic growth forecasting plays a pivotal role in estimating future year emissions for the region. There are many uncertainties affecting projections of traffic growth

, including the current

economic conditions

, future growth in population and employment , etc . Growth rates for this emissions inventory were based on an assessm ent of available data sources.

All SIP mobile source highway inventories include the rev iew and assessment of county

- specific growth rates from a PennDOT study originally completed in 2005 and documented in the report, Statistical Evaluation of Projected Traffic Growth, Traffic Growth Forecasting System: Final Report, March 14, 2005 (Baker, 2005) . As part of that study, a statewide traffic growth forecasting system was developed that incorporates traffic data from PennDOT’s Traffic Information System and socioeconomic forecasts. That forecasting system is maintained by the

PennDOT BPR and i s updated on a periodic basis. This system was last updated in December of 2009 to develop new statistical relationships between historic VMT growth and population (thr ough 2008). The forecast population was estimated from the Woods and Poole data “2010

State Profile. ” The results of the study have been shared between PennDOT, PA DEP, and other Pennsylvania Transportation Air Quality Working Group members

.

T he growth rates from the PennDOT BPR forecasting system were evaluated against other

available da ta including the SPC travel model . For the development of motor vehicle emissions budgets (MVEBs) , upper estimates of the VMT growth range are used for the forecast analyses. From an air quality perspective, the use of the upper boundary is conservative, and provides for factors outside the agency’s control (e.g., potential socio

- economic growth above current forecasts, fleet age distributions, vehicle type distribution) that infl uence motor vehicle

emissions.

For the Liberty

- Clairton PM 2.5 N AA , the Penn DOT BPR Growth Rate forecasting system was used to convert 2008 volumes to 2007, while growth rates from 2007

- 2014 are based on the SPC regional travel demand model

. Of the multiple sources reviewed, these yielded the highest

estimates of traffic volumes and

, in turn

, the highest estimate of the on road emissions. Base and

forecasted VMT estimates are shown in Table 2

- 3

.

Table 2

- 3

. Base and Forecasted Vehicle Miles of Travel (Millions)

VMT (Millions)* %

Change 2007 2014

94.701 107.171 13.2%

* All VMT is classified as Urban, Unrestricted in MOVES for Liberty

- Clairton.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 16

Vehicle Population Growth Assumption

Vehicle populat ion growth forecasting plays a key role in determining emissions for future years for the region. For this inventory, the vehicle population was forecasted by considering county

specific household and population growth. Liberty

- Clairton area vehicle population estimates by

MOVES s ourc e types are shown in Table 2

- 4

.

The household and population data was obtained from the PennDOT study documented in the

report s discussed above

, as well as the Statistical Evaluation of Projected Traffic Growth, Traffic Growth Forecasting System: Final Re port, March 14, 2005 . The forecast household and population were estimated from the Woods and Poole data “2010 State Profile

. ” The highest growth for household and population data was obtained for the county. The household growth rate yielded the higher value and did not exceed VMT growth. This value was ultimately used to project the 2007 vehicle population to 2014.

Table 2

- 4

. Vehicle Population Estimated Classified by MOVES Source Type

MOVES Source Typ e ID Vehicle

Population

2007 2014

11 443 488

21 6,572 6,626

31 4,625 4,749

32 1,545 1,586

41 2 3

42 14 14

43 20 21

51 1 2

52 94 105

53 11 13

54 21 24

61 23 25

62 26 29

Total 13,397 13,685Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 17

Final Results

Table 2

- 5 summarizes the 2007 and 2014 on road vehicle estimates for the Liberty

- Clairton NAA by MOVES road type.

Table 2

- 5

. Liberty

- Clairton PM 2.5 NAA Onr oad E missions Summary by Road Type (Tons/Y ear)

Table 2

- 6 provides an on road emissions summary by fuel type for the Liberty

- Clairton NAA

, as well as the expected change in VMT and emissions between 2007 and 2014.

Table 2

- 6

. Liberty

- Clairton PM 2.5 NAA Onr oad Emissions Summary by Fuel Type * (Tons/Y ear)

2007

Fuel Type Annual VMT (millions) Speed

( miles/hour ) PM 2.5 VOC NO

x SO 2 NH 3 Gasoline 88.717 29.1 4.17 164.42 175.63 1.80 4.51

Diesel Fuel 5.985 29.1 5.74 8.10 98.66 0.35 0.15

Area Total 94.701 29.1 9.91 172.52 274.29 2.15 4.66

2014

Fuel Type Annual VMT (millions) Speed

( miles/hour ) PM 2.5 VOC NO

x SO 2 NH 3 Gasoline 100.203 29.1 3.34 89.91 93.23 0.81 3.18

Diesel Fuel 6.968 29.1 2.84 5.15 57.80 0.09 0.18

Area Total 107.171 29.1 6.18 95.06 151.03 0.90 3.36 Change in VMT and Total Emissions: 2007

- 2014

Fuel Type Annual VMT (millions) Speed

( miles/hour ) PM 2.5 VOC NO

x SO 2 NH 3 Gasoline 11.486

- - 0.83

- 74.51

- 82.39

- 0.99

- 1.33

Diesel Fuel 0.983

- - 2.89

- 2.95

- 40.86

- 0.26 0.02

Area Total 12.469

- - 3.73

- 77.46

- 123.26

- 1.24

- 1.31 2007

Road Type Annual VMT

(millions) Speed

(miles/hour) PM 2.5 VOC NO

x SO 2 NH 3 Off

- Road

- - 1.82 121.60 75.43 0.16 0.00

Urban Unrestricted 94.701 29.1 8.09 50.92 198.86 1.99 4.66

Area Total 94.701

- 9.91 172.52 274.29 2.15 4.66

2014

Road Type Annual VMT

(millions) Speed

(miles/hour) PM 2.5 VOC NO

x SO 2 NH 3 Off

- Road

- - 1.16 72.74 51.72 0.07 0.00

Urban Unrestricted 107.171 29.1 5.02 22.32 99.31 0.84 3.36

Area Total 107.171

- 6.18 95.06 151.03 0.90 3.36Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 18

The speed given in Tables 2

- 5 and 2

- 6 is calculated by the internal processes within the PPSUITE software. PPSUITE uses a combination of “Best Practices Methods (BPM) speed curves” similar to those typically found in regional travel demand models, al ong with adjustments as found in the TRB Highway Capacity Manual to account for roadway geometry. This approach is based on common industry practice and is consistent with the approach used in other regional air quality planning analyses.

All input data was at a minimum coded to the first decimal place. PPSUITE internally uses floating point calculations which retain accuracy to 16 decimal places. While the table reports average vehicle speed to the first decimal place, that model

- estimated value is mor e precise than the model’s ability to estimate such speeds

.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 19



### 2.4 Insignificance Finding Factor 1 : Motor Vehicle Emissions Constitute a Low Percentage of Total SIP Inventory

As specified by EPA guid a nce , pollutants inventoried as part of the June 21, 2013 SIP submittal for the Liberty

- Clairton PM 2.5 nonattainment area include d PM 10 and PM 2.5 along with

precursors SO 2 , NO

x , VOC, and NH 3

. The emissions inventory included in the plan w as compiled for sources within the nonattainment area (City of Clairt on, Glassport Borough, Liberty Borough, Lincoln Borough, Port Vue Borough). Sources in the emissions inventory include stationary point sources, area sources, nonroad sources, and onroad sources.

In the June 21, 2013 SIP submittal, y ear 2007 was used f or baseline emissions inventory and year 2014 was used for the projected inventory. The 2007 inventory provided actual emissions of a year when the Liberty

- Clairton area was not attaining either the 1997 or the 2006 PM 2.5 standards, and t he SIP submittal showed project ed attainment of the 2006 PM 2.5 NAAQS by 2014. The Liberty

- Clairton area attained the 1997 PM 2.5 NAAQS in 2011 and is currently attaining these standard s . The SIP submittal included additional controls that will be implemented by 2014 to at tain the 24

- hour 2006 PM 2.5 NAAQS and will also result in further

reductions of annual PM 2.5 concentrations. Therefore, these inventories are consistent with

attainment of both the 1997 and 2006 PM 2.5 NAAQS

.

E missions inventories for all source classific ations were developed for the Mid

- Atlantic / Northeast Visibility Union (MANE

- VU) for use in regional analyses and SIPs by states in the

Northeast ern region of the United States

. As described in the June 21 , 2013 SIP submittal, t he Liberty

- Clairton emissi ons inventory was developed from t he regional MANE

- VU inventories with revisions by TranSystems|E.H. Pechan (TS|Pechan) for area, nonroad , and mobile sources and by ACHD for stationary point sources. Emissions given are “actual” values based on pollutant emission factors and throughputs or capacities of each emission source . E missions do not represent permitted or “allowable” limits.

Source categories used for the emissions inventory are described below. The inventory listings are included in Appendix D of the June 21, 2013 SIP submittal , and information on the development of the baseline and projected emissions and modeling inventories are given in Appendices E and F of that same submittal

.

 Stationary point sources are sources for which ACHD collect s i ndividual emissions

related information.

 Area sources are industrial, commercial, and residential sources too small or too numerous to be handled individually. These include but are not limited to commercial and residential open burning, architectural and industrial maintenance coatings application and clean

- up, consumer product use, and vehicle refueling at service stations.

 Nonroad sources encompass a diverse collection of engines, including but not limited to outdoor power equipment, recreational vehicl es, farm and construction machinery, lawn and garden equipment, industrial equipment, recreational marine vessels, commercial marine vessels, locomotives, ships, and aircraft.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 20

 Onroad sources include passenger cars and light

- duty trucks, medium and heavy du ty trucks, buses and motorcycles. T he Motor Vehicle Emissions Simulator (MOVES)

model was utilized to generate emissions based on traffic counts, vehicle speeds, vehicle population growth, and other factors. Mobile source emissions for the Liberty

- Clairt on

area were developed by T S |Pechan

.

Emissions inventory summaries of PM 2.5 and NO

x for baseline and future projected cases are

shown in Tables 2

- 7 and 2

- 8 below

. 5 These emissions represent those from sources only within

the 5

- mun icipality Liberty

- Clairton area and not the surrounding area.

Table 2

- 7

. Baseline 2007 Emissions (Tons/Year)

Liberty

- Clairton Area (2007) PM 2.5 NO

x Stationary Point Sources 946.6 4841.9

Area Sources 26.3 38.8

Nonroad Sources 15.0 437.9

Onroad Sources 9.9 274.3

Totals 997.8 5592.9

Onroad Percentages 0.99% 4.90%

Table 2

- 8

. Future Projected 2014 Emissions (Tons/Year)

Liberty

- Clairton Area (2014) PM 2.5 NO

x Stationary Point Sources 662.7 4349.3

Area Sources 25.6 38.5

Nonroad Sources 12.4 387.1

Onroad Sources 6.2 151.0

Totals 706.8 4925.9

Onroad Percentages 0.88% 3.07%

5 E missions of SO 2 , VOC, and NH 3

. are not shown since onroad b udgets for these precursors are only required if it is determined that budgets are necessary in order for the SIP to achieve its purpose of achieving reasonable further progress, attainment, or p rovide for maintenance of the given NAAQS. The June 21, 2013 SIP submittal does not rely on reductions of VOC or NH 3 from any sources in the area in

order to demonstrate attainment. The SIP submittal does rely on SO 2 emissions reductions from point

sourc es; however, it does not rely on reductions from on road SO 2 sources, which represented less than

0. 2 % of the total SO 2 inventory for the area.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 21

Based on the emissions inventories in Tables 2

- 7 and 2

- 8 , it can be concluded that:

 Onroad mobile source PM 2.5 constitutes less than one percent (1 %) of the area’s total

2007 P M 2.5 emissions and the area’s total projected 2014 PM 2.5 emissions.

 Onroad mobile source N O

x constitutes less than five percent (5 %) of the area’s total N O

x emissions in 2007 and less than four percent (4 %) of the area’s total projected 2014 N O

x emissions

.

Therefore, with regard to the first factor to be considered by this SIP submittal for determining an insignificance finding, ACHD asserts that the low mobile source contribution of direct PM 2.5 and NO

x , in concert with their continuing decline

, both in absolute emissions and relative to other source categories ( as documented in Tables 2

- 7 and 2

- 8 )

, war rants an insignificance finding for both the 1997 ann ual and 2006 24

- hour PM 2.5 standards. 6

6 This conclusion would be consistent with EPA’s past actions on requests to find direct PM 2.5 and NO

x emissions to be insignificant for transportation conformity purposes. Generally, EPA has proposed to approve insignificance findings if onroad N O

x emissions are less than 10% of an area’s inventory and

onroad direct PM 2.5 emissions are less than 3% of an area’s tot al direct PM 2.5 emissions inventory. (Percentage guidelines as provided by EPA’s Office of Transportation and Air Quality.)Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 22



### 2.5 In significance Finding Factor 2 : C urrent State of Air Quality as Determined by Monitoring Data for PM 2 .5 

### in the Liberty

- Clairton Area

PM 2.5 monitors are currently located at eight different monitoring locations throughout Allegheny County. Two Federal Reference Method ( FRM ) PM 2.5 monitors are located in the Liberty

- Clairton area. The FRM monitor at Liberty is located atop a school at high elevation near the center of the Liberty

- Clairton area. The FRM monitor at Clairton is located atop a school at low elevation in the western portion of the area. Appendix B of the June 21 , 2013 SIP

submittal contains detailed monitored data and EPA Air Quality System (AQS) reports.

Currently, monitoring data shows that the Liberty

- Clairton area is attaining the 1997 annual

PM 2.5 standard. EPA has made two determinations of attainment for the 1997 PM 2.5 standard for the Liberty

- Clairton area : 7

1. T he area has attained the 1997 NAAQS by its attain ment date, based on 2009

- 2011 monitoring data

.

2. Second, the area has continued to attain the 1997 NAAQS, based on 2010

- 2012 monitoring data.

The Liberty

- Clairton area is currently not attaining the 24

- hour 2006 NAAQS. However, the June 21, 2013 attainmen t demonstration addressed regional and local controls needed to bring the area into attainment for the 2006 NAAQS by 2014. Since the nonattainment problem of

PM 2.5 is primarily stationary source

- based, the controls for Liberty

- Clairton corresponded to

sta tionary source controls.

All A llegheny County FRM 8 PM 2.5 annual and 24

- hour design values (3

- year averages of annual

and 24

- hour 98 th

- percentiles, respectiv ely) for the timeframe 2000

- 2012 are shown in Figures 2

- 1

and 2

- 2

. 9

7 Final rule published in the FR on October 25, 2013, with an effective date of November 25, 2013.

8 Initial Avalon monitored data for the period Jan. 2010

– May 2011was Federal Equivalent Method (FEM) before switching to FRM in June 2011.

9 Figures 2

- 1 and 2

- 2 include some 3

- year periods with low recovery quarters (i.e., less than 75% valid data per quarter) as noted in Appendix B of the June 21, 2013 SIP submittal in regard to design values through 2011. Additionally, in 2012, one calendar quarter was below 75% dat a recovery for North

Braddock . The technical support document for the determination of attainmen t for Liberty

- Clairton for

the 1997 PM 2.5 NAAQS further addresses data completeness for the Liberty and Clairton monitors for

2010

- 2012.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 23

Figure 2

- 1

. PM 2.5 FRM Annual Design Values, Allegheny County, 2000

- 201 2

Figure 2

- 2

. PM 2.5 FRM 24

- Hour Design Val ues, Allegheny County, 2000

- 2012

Figures 2

- 1 and 2

- 2 show that a ll Allegheny County sites have shown decreasing design values

for both annual and 24

- hour PM 2.5 NAAQS since 2000, with only the Liberty monitor showing a

24

- hour design value above the NAAQS for the 2010

- 2012 period

.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 24

Figure s 2

- 3 and 2

- 4 show annual and 24

- hour design values for the Liberty and Clairton

monitors over a 10

- year timeframe from 2005 to the projected year 2014 (projected design

values were taken from the attainment tests in the June 21, 2013 SIP submittal)

.

Figure 2

- 3

. Liberty and Cla irton FRM Annual Design Values with Projected to 2014

Figure 2

- 4

. Liberty and Clairton FRM 24

- Hour Design Values with Projected to 2014Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 25

The attainment demonstration showed that the Liberty

- Clairton area will continue to attain the

1997 PM 2.5 NAAQS based on decreasing annual design values and will attain the 2006 PM 2.5 NAAQS by 2014 based on projected 24

- hour design values. Figure s 2

- 3 and 2

- 4 show that the decreasing trends in the modeled projections are similar and consistent with the actual monitored data, indicating that the projections are adequate to represent expected air quality monitoring

data after the implementation of control measures

. (For the projections, averaging periods 2006

- 2008 and 2013

- 2015 were used to represent the weighted 2007 baseline and 2014 future projected design values , respectively .)

Therefore, with regard to the second factor to be considered by this SIP submittal for determining the acceptability of an insignificance finding, ACHD asserts that attainment of the

1997 annual PM 2.5 NAAQS beginning in 2011 and the continuing monitored and modeled

downward trend s in concentrations support an insignificance fin ding for that NAAQS. With regard to the 2006 24

- hour PM 2.5 NAAQS

, the continuing downward trend s in monitored concentrations and the projected attainment of the NAAQS in 2014 based on control measures in the June 21, 2013 SIP submittal support an insignif icance finding for the 2006 24

- hour PM 2.5 NAAQS

.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 26



### 2.6 In significance Finding Factor 3 : Absence of SIP M otor V ehicle C ontrol

M easures

2.6.1 Transportation Control Measures

Historically, there have been no Allegheny County SIP requirements for Transportation Control Measures (TCMs). TCMs are strategies that reduce transportation

- related air pollution, greenhouse gas ( GHG ) emissions, and fuel use by reducing vehicle miles tra veled and improving roadway operations.

Vehicle use can be reduced through less

- polluting transportation alternatives, such as public transit, and strategies that decrease the need for vehicle trips, such as telecommuting. TCMs may also focus on making t ravel more efficient by carefully managing the transportation system.



### 2.6.2 Current Control Requirements

Onroad vehicles are subject to federal emission standards. In addition, a vehicle inspection and

maintenance program is in place in the area, as well as vehicle idling restrictions, and low vapor pressure gasoline requirements during the ozone season. These controls were either required or selected for implementation in order to reduce emissions and to bring the larger Pittsburgh MSA

into attainment of th e ozone NAAQS

.



### 2.6.3 Review of RACM

TranSystems|E.H. Pechan (TS|Pechan), along with KB Environmental Sciences, Inc., examined several RACM options for onroa d mobile sources in the Liberty Clai rton area, as shown in Table

2

- 9 below for highway sources

. Additional details of the RACM analysis can be found in Appendix I of the June 21, 2013 SIP submittal

.

Table 2

- 9 . Onroad Highway Mobile Sources RACM Analysis SummaryLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 27

The TS | Pech an RACM analysi s for th e Liberty

- Clairton area included consideration of the

e stablish ment of an Employer Rideshare Program as a SIP Motor Vehicle Control Measure. It

would provide incentives or encouragement for employers to offer a carpool/ridesharing program to employees. C ontrol efficiencies for a commuter benefit program involve a reduction in the total vehicle miles traveled (VMT) by individuals participating in the program. T he annualized

cost

- effectiveness of the proposed program is $8,542,879 per ton of PM 2.5

.

EPA interprets RACM as a collection of measures that, taken as a group, advance the NAAQS attainment date by at least one year. In this instance , the finding of the analysis performed as part of the June 21, 2013 SIP submittal was that the set of RACMs that h ave been identified for the Liberty

- Clairton PM 2.5 NAA are not likely to advance the atta inment date by one year or

more. Consequently, none, including the TCM, will be implemented.

Therefore, with regard to the third factor to be considered by this SIP submittal for determining an insignificance finding, ACHD asserts that the absence of new motor vehicle control measures in the June 21, 2013 SIP submittal warrants an insignificance finding for both the 1997 and 2006

PM 2.5 NAAQS

.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 28



### 2.7 In significance Finding Factor 4 : Historical Trends and Future Projections of

the Growth of Motor Vehicle Emissions

Allegheny County is unique in the fact that the population has been declining since the 1960s. Localized regions of population growth are occurring, but the general trend for the county is one of negative growth. T he 2010 census shows continued decrease in population in the five municipalities of the Liberty

- Clairton area as well

. According to the U.S. Census Bureau, from 2000 to 2010, the City of Clairt on had a decrease in population of about 20%, the largest population decr ease in the nonattainment area. (S ee Figure 2

- 5 below .)

Figure 2

- 5

. Population Trend s for Allegheny County, 2000

- 20 10

Population decreases were also seen in the remaining nonattainment area boroughs. Glassport saw a population change of

- 10.2%, Liberty

- 4.5%, Lincoln

- 12.0%, and Port Vue

- 10.2%. In total, the five nonattainment area municipalities decreased in populatio n by 2,900 people, or

- 13.4% from 2000 to 2010. This continues a trend of decline from the 1990

- 2000 period, which

saw an average change in population of

- 6.6% in the nonattainment area

. Decreasing populations signal less use of cars and a lesser need fo r school buses and other diesel

- engine

vehicles

.

Section 2.3.4 above corroborates the expected slow growth in vehicle population. Table 2

- 4 indicates an increase of only 288 vehicles between the years 2007 and 2014. Also, as discussedLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 29

in Section 2.4 abo ve, the attainment demonstration projects that both annual and 24

- hour onroad

emissions of direct PM 2.5 and NO

x will decrease from the 2007 base year through 2014.

While not a part of the June 21, 2013 SIP submittal, the most recent Southwestern Planning Commission (SPC) air quality conformity determination for the Pittsburgh transportation

management area 10 shows similar trends for VMT and onroad emissions . Th e SPC conformity determination projected a slow growth in VMT in the area through 2040 and a downward trend

in on road emissions of direct PM 2.5 and NO

x throug hout the assessment period.

Therefore, with regard to the fourth factor to be considered by this SIP submittal for determining the acceptability of an insignificance finding, ACH D asserts that available data does not indicate highway motor vehicle emissions growth that would lead to a violation of the 1997 or 2006

PM 2.5 NAAQS

, and th u s warra nts an insignificance finding for both the 1997 and 2006 PM 2.5 NAAQS

.

10 SPC Air Quality Conformity Determination, July 2012: htt p://www.spcregion.org/trans_airreport.shtmlLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 30



### 2.8 Motor Vehicle Emis sions Insignificance Finding s Conclusions

For the reasons set forth in Sections 2.4 through 2.7 of this document , ACHD concludes that Liberty Clairton area onroad emissions of PM 2.5 and NO

x are insignificant contributors to the

nonattainment of the 1997 and 2006 PM 2.5 NAAQS for the Liberty

- Clairton area

.

U pon a positive adequacy review and approval of the information included in this SIP submittal for transportation conformity , no highway emissions analy sis will be required for direct PM 2.5 or NO

x . PM 2.5 hot

- spot analyses would continue to apply for required projects under 40 CFR 93.116 and 93.123(b) of the transportation conformity rule.

The Liberty

- Clairton area is also subject to transportation conformity requirements for the 8

- hour

ozone standa rd, with SIP

- approved MVEB s for NO

x and VOC. Highway analysis of seasonal ozone precursors would continue to be mandatory.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 31



## 3 Projected Electric Generating Unit Emissions

This section updates and revises the projected electric generating unit (EGU) emissions analysis previously given in the June 21, 2013 SIP submittal, specifically the information provided in

S ection 5.3.5 and Appendix E

- 6.

As specified in the June 21, 2013 SIP submittal

, the Cross

- State Air Pollution Rule ( CSAPR ) 11

future case 2014 inventory was used for projected EGU emissions in the modeling

demonstration . The Clean Air Interstate Rule ( CAIR ) 12 future case 2015 inventory, developed in 2005, is an outdated inventory that may not adequately represent expected EGU emissions. The

CSAPR future case 2014 inventory , developed in 2011, was therefore used as the more recent and realistic dataset for exp ected EGU emissions. (At the time of this supplemental SIP revision, CSAPR was under review by the U.S. Supreme Court.)

In addition, EGU projections have changed since development of the CSAPR inventory in 2011.

Several units have been modified or d eact ivat ed (or proposed for deactivation) due to compliance issues, incr eased natural gas production, economic factors, and/or other reasons

. Reductions from these controls or deactivations were not included in the SIP modeling

demonstration.

For a look at t he appropriateness of the CAIR and CSAPR inventories in relation to more recent data, reported 2012 SO 2 and NO

x emissions from EPA’s Clean Air Markets Division (CAMD) 13

were examined for the CSAPR

- controlled states. (Note: CAIR states are similar to CSAPR but do not include MN, KS, NE, OK and include MA, CT, DE.) Current or expected reductions were also used to extrapolate the reported the 2012 data to years 2013

- 2015. PA and surrounding states within the PJM Interconnection Regional Transmission Organiza tion (RTO) territory were the focus for expected reductions.

Reductions for PA and the surrounding PJM territory include current and proposed PJM

deactivations 14 and state

- permitted modifications. Some of the deactivations include units that are subject t o federal consent decrees. Details of expected reductions withi n the PJM territory are given by state and unit in Appendix A, while s upporting permits, deactivation requests, and

consent de crees are included in Appendix B

.

11 CSAPR information: http://www.epa.gov/airtransport/CSAPR/index.html 2014 CSAPR TR1 Remedy files: ftp://ftp.epa.gov/EmisInventory/2005v4_2/2014emis

12 CAIR information: http://www.epa.gov/airmarkets/progsregs/cair/index.ht ml 2015 Final CAIR Modeling: http://www.epa.gov/airmarkets/progsregs/epa

- ipm/cair/index.html

13 CAMD database: http://ampd.epa.gov/amp d/ (accessed 8/21/2013)

14 PJM Interconnection: http://www.pjm.com/planning/generation

- deactivation/gd

- summaries.aspx (accessed 9/12 /2013) . Note that a deactivation is proposed until actual deactivation date and does not constitute permanent retirement of a unit without further analysis

. The deactivation process is explained

in more d etail in PJM Manual 14D: http://www.pjm.com/~/media/documents/manuals/m14d.ashxLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 32

Maps of CSAPR states and the PJ M Interconnection territory are shown in Figures 3

- 1

- and 3

- 2

below. Appendix C contains back

- trajectory data indicating the possible influence of upwind and surrounding states on pollution in SWPA.

Figure 3

- 1

. CSAPR States

Figure 3

- 2 . PJM Interconnection TerritoryLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 33

Table 3

- 1 below shows a summary of the actual/expected unit deactivations by plant capacity (in MW) for 2012

- 201 5 in the PJM territory. These plants were included in the SIP modeling

demonstration with CSAPR

- allocated emissions levels for 2014. E miss ions reductions per year from these deactivations are given in Appendix A ; deactivation worksheets from the PJM web

site are given in Appendix B

- 2

.

Table 3

- 1 . PJM Unit Deactivations by Plant Capacity, 2012

- 2015

Plant Year State Decrease in Capacity (MW) Plant Year State Decrease in Capacity (MW)

Albright 2012 WV 283 Riverside 2014 MD 118

Armstrong 2012 PA 343 Yorktown 2014 VA 324

Bay Shore 2012 OH 495 Ashtabula 2015 OH 244

Conesville 2012 OH 165 Bergen 2015 NJ 21

Crawford 2012 IL 532 Burlington 2015 NJ 205

Eastlake (2 units) 2012 OH 837 Clinch River 2015 VA 230

Elrama 2012 PA 460 Eastlake (3 units) 2015 OH 396

Fisk 2012 IL 326 Edison 2015 NJ 504

Kearny (2 units) 2012 NJ 250 Essex 2015 NJ 490

Niles 2012 OH 217 Gilbert 2015 NJ 188

Phil Sporn (1 unit) 2012 WV 440 Glen Lyn 2015 VA 235

Potomac River 2012 VA 482 Kammer 2015 WV 600

R. Paul Smith 2012 MD 115 Kanawha River 2015 WV 400

Rivesville 2012 WV 121 Kearny (1 unit) 2015 NJ 21

State Line 2012 IN 515 Lake Shore 2015 OH 245

W C Beckjord (1 unit) 2012 OH 94 Mercer 2015 NJ 115

Willow Island 2012 WV 189 Missouri Ave 2015 NJ 60

Hatfield's Ferry 2013 PA 1590 Muskingum River 2015 OH 790

Mitchell 2013 PA 359 O H Hutchings (5 units) 2015 OH 277

O H Hutchings (1 unit) 2013 OH 62 Phil Sporn (5 units) 2015 WV 580

Piney Creek 2013 PA 31 Picway 2015 OH 95

Schuylkill 2013 PA 166 Sewaren 2015 NJ 564

Titus 2013 PA 243 Shawville 2015 PA 597

W C Beckjord (2 units) 2013 OH 222 Tanners Creek 2015 IN 488

B L England 2014 NJ 129 W C Beckjord (3 units) 2015 OH 802

Chesapeake 2014 VA 576 Werner 2015 NJ 212

Portland 2014 PA 401Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 34

Table 3

- 2 below shows CAMD reported 2012 emissions for SO 2 and NO

x for CS A P R states along with extrapolated emissions for 2013

- 2015 based on expected controls and deactivations in

the PJM territory . Projected emissions for future case 2014 CSAPR and 2015 CAIR are shown for comparison.

Table 3

- 2 . CAMD Reported 2012 SO 2 and NO

x Emissions (with Expected Reductions in PJM Territory for 2013

- 2015) and Interstate Transport Rules Projected Emissions

, CSAPR States

CAMD Reported with Expected Reductions in PJM Territory (CSAPR States) 2012 Reported (tons) 2013

Expected (tons) 2014

Expe cted (tons) 2015

Expected (tons)
Reported (or Expected ) SO 2 3033582 2965809 2947442 2746660
Reported ( or Expected ) NO

x 1350962 1332804 1311874 1291816

Interstate Transport Rules (CSAPR States) 2014 CSAPR (tons) 2015 CAIR

(tons)
Projected SO 2 2919042 4618909
Projected NO

x 1428480 1561493

Table 3

- 2 shows that recent reported emissions for 2012 are already well below 2015 CAIR

levels for both SO 2 and NO

x , suggesting that the CAIR projections as developed in 2005 may be inaccurate. Additionally, 2012 NO

x emissions are already below the 2014 CSAPR projected

level.

Expected reductions through 2014 from the PJM territory alone (without additional reductions in other states) show that SO 2 is with in 1% of the 2014 CSAPR projection. Expected reductions through 2015 continue to decrease to below the 2014 CSAPR projection for SO 2

.

These reductions are also shown visually on the following page in Figures 3

- 3 and 3

- 4 , using long

- term trends for CAMD S O 2 and NO

x emissions over the timeframe 2007

- 2015. Year 2007 was used as the baseline year for the modeling demonstration with 2014 as the future projected year. Expected/projected years are shown indicated by dotted lines in the figures.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 35

Figure 3

- 3 . Long

- Term Reported and Expected/Projected SO 2 (tons), CSAPR States

Figure 3

- 4 . Long

- Term Reported and Expected/Projected NO

x (tons), CSAPR StatesLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 36

The long

- term trends in Figure s 3

- 3 and 3

- 4 show that reported CAMD emissions of SO 2 and

NO

x have decreased significantly in the U.S. in recent years. Reductions will continue through 2014 and 2015 using anticipated controls and deactivations for the PJM ter ritory . Controls, fuel switches, and deactivations from other states have been excluded from this analysis, r esulting in a potentially conserv ative approach for estimating future emissions.

Table 3

- 3 below shows a summary of the federal consent decrees a nd corresponding SO 2 actions

and limits that are applicable to units in PJM states

.

Table 3

- 3 . Federal Consent Decrees for Units in PJM states

Company State Plant Date of

Consent

Decree Action Required 15 System

- Wide SO 2 Limits

American

Electric Power (AEP) Corp. Ohio/ West

Virginia/

Indiana/ Kentucky/ Virginia Amos October

2007 Install FGD by 2011 2014: 340,000 tons/year

2019 (continuing in perpetuity): 174,000 tons/year Big Sandy Install FGD by 2016 (1 unit), meet coal sulfur content limit (1 unit)

Cardinal Install FGD by 2009 (2 units) and 2013 (1 unit)

Conesville Install/upgrade FGD by 2011 (3 units), retire/repower/retrofit by 2013 (3 units)

Gavin Install FGD by 2008 Glen Lyn Meet coal sulfur content limit by 2008

Kanawha Meet coal sulfur content limit by 2008

Mitchell Install FGD by 2008

Mountaineer Install FGD by 2008 Muskingum Retire/repower/retrofit by 2016 (4 units), install FGD by 2016 (1 unit) Rockport Install FGD by 2018 (1 unit) and 2020 (1 unit) Sporn Retire/repower/retrofit by 2014 (1 unit)

Tanners Creek Meet coal sulfur content limit by 2008 Various (for total of 600 MW) Retire/repower/retrofit by 2019 (for 600 MW

reduction from 13 units)

American Municipal

Power Ohio Gorsuch May 2010 Retire by 2013 n/a

Dominion Energy Illinois/

Indiana State Line April

2013 Retire (2 units) by mid

2012, retire (2 units) by

mid

- 2013 2014: 8,500 tons/year

15 FGD is Flue Gas Desulfurization; DSI is Dry Sorbent Injection; ECO is Electro

- Catalytic OxidationLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 37

Company State Plant Date of

Consent

Decree Action Required 15 System

- Wide SO 2 Limits

Brayton Point Meet emission rates for existing FGD by mid

2013

Kincaid Install DSI by 2014

Duke Energy Indiana Gallagher December

2009 Retire/repower by 2013

(2 units), install DSI by 2011 (2 units) n/a

Dynegy Illinois/

Indiana Baldwin March

2005 Install FGD by 2013 2013 (continuing in perpetuity): 29,000 tons/year Havana

Hennepin Reduce SO 2 emissions by

2006 Vermillion

Wood River East Kentucky

Power Cooperative Kentucky Cooper July 2007 Retire by 2013, repower by 2014, or install FGD by mid

- 2018 2013: 28,000 tons/year

Dale

Spurlock Install FGD by 2009 (1 unit) and 2011 (1 unit)

Hoosier Energy Rural

Electric Cooperative Indiana Merom July 2010 Upgrade FGD by mid

2012 (1 unit) and mid

2013 (1 unit) 2014: 26,000 tons/year

Ratts Retire/repower by 2017 or meet emission rates by

2016 Kentucky

Utilities Kentucky Brown February

2009 Install FGD by 2011 2011: 2,300 tons/year

Northern

Indiana Public

Service Company Indiana Bailly January

2011 Upgrade existing FGD by

2014 2019: 11,600 tons/year (if Michigan City unit gets FGD) or 10,200 tons/year (if Michigan City unit gets retired) Dean Mitchell Retire by 2010 Michigan City Retire or install FGD by

2019

Schahfer Install FGD (2 units) by 2014/2016 and upgrade FGD (2 units) by 2011

Ohio Edison/ FirstEnergy Corporation Ohio Burger March

2005 and August

2009 Retire by 2011 or repower

by 2013 2011: 29,900 tons/year (only for Sammis Plant)

Sammis Install FGD, Flash Dry

Absorber

, ECO , or Induct

Scrubber at various units by 2011

Mansfield Upgrade FGD by 2008

PSEG Fossil Corp. New Jersey Hudson January

2006 Install FGD by 2010 2010: 5,270 tons/year

Mercer

Tennessee Valley Authority Kentucky Paradise April

2011 Upgrade FGD (2 units) by

2013 and Install Wet FGD (1 unit) by mid

2011 2019: 110,000 tons/year

Shawnee Install FGD, repower to renewable biomass, or

retire by 2018Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 38

Supporting EGU documentation (permits, deactivation s , consent decrees) can be found in Appendix B.

Considering the comparisons to CAIR and reported /extrapolated CAMD data, the 2014 CSAPR remedy case is an adequate inventory of expected EGU em issions for modeling purposes.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 39



## 4 Legal Documents

4.1 Notice of Public Hearing and Comment PeriodLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 40



### 4.2 Transmittals of Hearing Notice to PA DEP and EPALiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 41Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 42



### 4.3 Proof of Publication and Certification of Public HearingLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 43Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 44



### 4.4 Summary of Public Comments and Responses

Comment and Response Document for the Proposed SIP Revision 75

Revision to State Implementation Plan for PM 2.5 for Allegheny County Supplement to the Liberty

- Clairton PM 2.5 Attainment Plan , 2006 NAAQS

December 18, 2013 Public Hearing Public Comment Period ending December 23, 2013

EGU ANALYSIS

Comments related to the projected emissions for electric generating units (EGUs)

.

1. Comment: ACHD cannot rely on controls and emission reductions anticipated from the implementation of the Cross

- State Air Pollution Rule (CSAPR). The Clean Air Act requires

that an attainment dem onstration contain specific, federally

- enforceable measures that will attain the NAAQS. The CSAPR future case inventory for 2014 assumes emission controls

and reductions associated with a vacated law that is under review by the U

. S

. Supreme Court ; CSAPR i s therefore not legally enforceable and not an appropriate inven tory for representative purposes . Any emission reductions, including those represented in future case modeling demonstrations, should instead be derived from the Clean Air Interstate R ule (CA IR) pending the final decision regarding CSAPR or promulgation of another replacement

rule.

Commenter : Clean Air Council, PennFuture, Clean Water Action.

Response : As noted in the May 10, 2013 SIP document, ACHD will rely on CAIR, state, and permit con trols until a final decision is made regarding CSAPR or until a replacement

rule is promulgated. However, ACHD believes that the inventory used in the CAIR modeling demonstration is an outdated inventory that does not adequately represent future

emissions fro m the electric generating unit (EGU ) sector for modeling purposes. T he CSAPR future case inventory was therefore used in the modeling demonstration. ACHD maintains that, in lieu of any additional inventory, the CSAPR inventory is an updated

version of the CAIR inventory that is best representa tive of expected EGU controls.

The purpose of the additional analysis of projected EGU emissions in the supplemental SIP was to further clarify “real

- world” emissions reductions and how they compare to CSAPR

an d CAIR inventories. The analysis of recent emissions, including current and expected deactivations not included in the modeling, show that reported and expected emissions for CSAPR states are comparable to the emissions included in the CSAPR 2014 modeling . EGU deactivations/retirements that are federally

- enforceable have been noted in Table 3

- 3 and in Appendix A of the Supplemental SIP.

Furthermore, EPA modeling guidance outlined the methodology for the use of actual emissions with the intent of predicti ng realistic transformation of precursor emissions toLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 45

PM 2.5 concentrations from all emissions sectors. The CAIR emissions, while representing the current enforceable emissions allocations, would not lead to realistic estimations of future

PM 2.5 concentrat ions.

2. Comment: EGU emissions from CSAPR modeled in the attainment demonstration are smaller than those in the CAIR inventory. Table 3

- 2 of the November 2013 Supplement al

SIP indicates that total 2014 CSAPR

- modeled emissions for the CSAPR states are 2,9 19,042 tons of sulfur dioxide (SO 2 ) and 1,428,480 tons of nitrogen oxides (NO

x ). These CSAPR emissions are substantially lower than the 2015 CAIR emissions, namely 4,618,909 tons of

SO 2 and 1,561,493 tons of NO

x . Thus, SO 2 emissions from CSAPR are 37% lo wer than the

CAIR emissions. These CSAPR SO 2 emissions are also slightly smaller than the 2014 emissions (2,947,442 tons) that have been estimated from the CAMD database. NO

x emissions from CSAPR are 9% lower than the CAIR emissions. Thus, large differe nces in CAIR and CSAPR emissions, especially for SO 2 , raise serious questions about the validity of

the SIP attainment demonstration

.

Commenter : Clean Air Council, PennFuture, Clean Water Action.

Response : Similar to the response to comment 1, the purp ose of the EGU analysis in the Supplemental SIP was to provide a quantitative comparison of real

- world emissions to modeling inventory emissions. The large differences in the CAIR and CSAPR emissions support the circumvention of the CAIR inventory for the modeling demonstration. The

CSAPR 2014 SO 2 inventory is within 1% of the expected CAMD 2014 SO 2 inventory, while the CAIR 2015 inventory is 68% higher than the expected CAMD 2015 SO 2 inventory.

Additionally, reported NO

x emissions in 2012 were already lower than both 2014 CSAPR and 2015 CAIR. The expected emissions analysis also includes deactivations from PJM Interconnection states only and does not include unannounced controls, fuel switches,or deactivations, leading t o a potentially conservative approach to the emissions analysis. The CSAPR inventory therefore better represents actual emissions from the power sector than

CAIR.

3. Comment: CAIR projections (with higher EGU emissions) provide an additional safety margin for ambient standard attainment since the CAMx photochemical model is known to largely underestimate PM 2.5 concentrations and the 2014 CAMx

- projected concentrations (34

- 35 μg/m3 ) are barely below the a mbient 24

- hour stan dard of 35 μg/m3

.

Commenter : Clean Air Council, PennFuture, Clean Water Action.

Response : The CAM x model wa s sufficiently accurate for this type of demonstration

, achieving model performance goals for PM 2.5 for the baseline year

. Furthermore, EPA

reco gn izes limitations in air quality models, and pr ocedures in the EPA modeling guidance

delineated the use of r elative r esponse f actors (RRFs) in the attai nment tests in order to

minimize modeled uncertainties

. M odel ed results are used to scale the observed weightedLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 46

PM 2.5 species concentrations to project 2014 future year PM 2.5 concentrations. I f the model

underestimat es for the baseline year, it also underestimat es for the future projected year

. Thus, modeled underestimation or overesti mation bias does directly equate to projected

concentrations since the modeled results are used in the relative sense.

Additionally, preliminary monitored data for 2013 indicates that attainment of the 24

- hour standard may be occurring earlier than expect ed. Unofficial federal reference method (FRM) monitor results show that Liberty is below the 24

- hour standard for 2013 (98 th

- percentile conc. = 31.1 μg/m3). Thus, monitored data may be showing better results than as projected with the modeling, indicativ e of a conservative modeling effort.

4. Comment: SO 2 e missions from Pennsylvania EGUs in the CSAPR are lower than those in

the CAIR and CAMD inventories

. Appendix A of the November 2013 Supplement al SIP

shows that SO 2 emissions from EGUs located in Pennsy lvania are 125,545 tons for CSAPR

in 2014 , 150,093 tons for CAIR in 2015, and 225,612 tons for CAMD with expected

reductions in 2014 . Thus, the CSAPR SO 2 emissions that were modeled in the attainment demonstration are substantially lower than those from CAIR and CAMD. These EGUs are located closest to the Liberty

- Clairton area and, hence, are expected to heavily influence the

PM 2.5 concentrations in the a rea

.

Commenter : Clean Air Council, PennFuture, Clean Water Action.

Response : The discrepancy between PA CSAPR and expected CAMD SO 2 2014 emissions is largely due to Homer City power plant emissions, where the expected emissions are 82,439 tons higher t han modeled. Completion of installation of the pollution control equipment at Homer City has been extended to early 2015. While Homer City may contribute to background sulfate concentrations in Western PA, the back

- trajectory analysis in Appendix C

shows that the majority of the high sulfate concentrations at Liberty occur on days when transport is from the Midwest or the Ohio Valley. Additionally, local PM 2.5 impacts are highest when winds are from the southwest (upwind of the area). The Homer City pla nt lies 36 miles downwind (northeast) of the Liberty

- Clairton area and is unlikely to contribute to the high concentrations that are causing nonattainment in the Liberty

- Clairton area. The focus of the EGU analysis was reductions within the PJM territory as a whole, with the highest presumed contributions from upwind EGUs to the west and southwest.

5. Comment: High PM 2.5 concentrations are influenced by emissions in surrounding states

. Backward trajectories in Appendix C of the November 2013 Supplement al SIP indicate that high PM 2.5 concentrations observed in 2012 are heavily influenced by emission sources located in upwind/surrounding states. These emission sources are beyond the ACHD jurisdiction and are not subjected to ACHD control. This analysis pro vides additional strong evidence that higher emissions in the CAIR should be used in attainment demonstration

.

Commenter : Clean Air Council, PennFuture, Clean Water Action.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 47

Response : Similar to the response to comment 4, expected emissions from states within the PJM territory were the focus of the emissions analysis. (Note that PJM includes only portions of IN, IL, KY, and MI, so not all of the deactivations in these states have been accounted for in the analysis, leading to a conservative effort.) Th e reductions in these states, although outside of ACHD’s jurisdiction, were based on announced PJM deactivations and

federal consent decrees.

6. Comment: The CAMD data are biased by large reduction in electricity demand due to

economic recession

. Figures 3

- 3 and 3

- 4 of the November 2013 Supplement al SIP show large drops in SO 2 and NO

x emissions reported in the CAMD database between 2007 and 2012. These emission reductions are primarily due to the large reduction in power demand caused by the current econo mic recession starting in 2008. Power demand and emissions may increase again following the termination of the current recession. Thus, the CAMD emissions may not be reliable for making long

- term projections.

Commenter : Clean Air Council, PennFuture, C lean Water Action.

Response : As shown in Figure 5

- 7 of the May 10, 2013 SIP document, heat input data from CAMD show rather steady EGU production levels after the height of the low

- production

levels in 2009 due to the recession. Continued decreases in EGU emissions are more likely attributable to deactivations due to environmental compliance, increased natural gas production, and other factors. The known and expected reductions included in the EGU analysis were based on announced deactivations and fede ral consent decrees, irrespective of electricity demands.

7. Comment: It was discovered during the public comment period of th e supplemental SIP that the ethanol percentages in the model had not been revised to the newer methodology used by

PA DEP

. The fu el assumptions in the MOVES modeling used 0.00% ethanol in summer

RVP months and 6.78% ethanol in winter months for both baseline and future modeled cases.

The n ewer methodology, as recommended by EPA in mid

- 2012, uses 0.00% ethanol year

round for years u p through 2009 and 10% ethanol year

- round after 2009. However, considering the low mobile source emissions for the Liberty

- Clairton area, any revision in the baseline or future case ethanol percentages would show negligible changes in the overall insignif icance finding

.

Commenter : Jayme Graham, Allegheny County Health Department.

Response : No response necessary.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 48

Notes on commenters :

 Comments received jointly from Clean Air Council , Citizens for Pennsylvania’s Future (PennFuture), and Clean Water Action were signed by the following:

o Joseph Otis Minott, Esq., Executive Director, Clean Air Council

o Tom Hoffman, Western Pennsylvania Director, Clean Water Action

o Heather Langeland, Esq., Staff Attorney, PennFuture

C ontribut ing to these comments, on behalf of Clean Air Council, included the following:

o Khanh Tran, Principal, AMI Environmen tal

 Additional comment made by Jayme Graham, Acting Manager, Air Quality Program, Allegheny County Health Department.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 49



### 4.5 Certification of AdoptionLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds., Supp. May 201 4 Page 50



## References

Allegheny County Health Department (ACHD) (2013)

. Proposed Revision to the Allegheny County Portion of the Pennsylvania State Implementation Plan: Attainment Demonstration for the Liberty

- Clairton PM 2.5 Nonattainment Area 2006 Standards . ACHD: Pittsburgh, PA, May

10

. http://www.achd.net/air/pubs/SIPs/Liberty

- ClairtonPM25SIP2006Stds_FINAL.pdf

Michael Baker Jr., Inc. (2005). “Statistical Evaluatio n of Projected Traffic Growth, Traffic Growth Forecasting System: Final Report,” March 14, 2005

.

Page, S. D. (2012). “Implementation Guidance for the 2006 24

- Hour Fine Particle (PM 2.5 ) National Ambient Air Quality Standards (NAAQS).” Memorandum. U.S. EPA, Office of Air Quality Planning and Standards. March 2. Available at: http://www.epa.gov/ttn/naaqs/pm/pdfs/20120302_implement_guidance_24

- hr_pm2.5_na aqs.pdf

TranSystems|E.H. Pechan & Associates, Thompson G. Pace, and Michael Baker Jr. Inc. (2012). 2007 and 2014 Liberty

- Clairton PM 2.5 Nonattainment Area Emission Inventories and Source Assessment Analysis . Prepared for Allegheny County Health Department.

U.S. EPA (2006). Area Designations for 2006 24

- Hour PM 2.5 NAAQS

– Technical Information web page: http://www.epa.gov/ttn/naaqs/pm/pm25_2006_techinfo.html

U.S. EPA (2005). 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, updated November. Available at: http://www.epa.gov/ttnchie1/eidocs/eiguid/index.html

U.S. EPA (1992). “ State Implementation Plans; General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990, ” Proposed Rule, 57 Federal Regis ter 13,498. Information at: http://www.epa.gov/airquality/urbanair/sipstatus/index.html

U.S. EPA, Region III (2008). Designation Response Letter to the Honorable Edward G. Rendell

, and Addendum 2. Available at: http://www.epa.gov/pmdesignations/2006standards/rec/region3R.htm