Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 0 Revision No. 1.11 Revision Date: 7/29/09 Page 1 of 4



# POINT SOURCE, ON-ROAD, AND FIRE BASE YEAR, FUTURE YEAR, AND CONTROL STRATEGY EMISSIONS INVENTORIES

DRAFT QUALITY ASSURANCE PROJECT PLAN

for

CONTRACT #: S-2009-06-02 EPA Grant XA-95411009 EPA Grant XA-96431505

Effective Date: August 2009Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 0 Revision No

. 1.11 Revision Date: 7 / 29 / 09 Page 2 of4



## SOUTHEASTERN STATES AIR RESOURCE MANAGERS, INC.

POINT SOURCE, ON-ROAD, AND FIRE BASE YEAR, FUTURE YEAR, AND CONTROL STRATEGY EMISSIONS INVENTORIES

QUALITY ASSURANCE PROJECT PLAN

Effective Date: August 2009

APPROVED BY

Date

(MACTEC Task Manager

, William Barnard) 

## c:____Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 0 Revision No. 1.11 Revision Date: 7/29/09 Page 3 of 4



### Table of Contents

POINT SOURCE, ON-R OAD, AND FIRE BASE YEAR, FUTURE YEAR, A ND CONTROL STRATEGY EMISSIONS INVENTORIES QA PROJECT PLAN

1.0 PROJECT OVERVIEW .............................................................................................. 1-1

1.1 Project/Task Organization ....................................................................................... 1-1 1.2 Problem Definition/Background .............................................................................. 1-3 1.3 Project/Task Description .......................................................................................... 1-4 1.4 Quality Objectives and Criteria for Measurement Data ..................................... 1-11 1.5 Special Training Requirements / Certification Listed ......................................... 1-11 1.6 Documentation and Records .................................................................................. 1-11

2.0 SAMPLING ................................................................................................................... 2- 1

2.1 Sampling Process Design (Experimental Design) ................................................... 2-1 2.2 Sampling Methods Requirements ............................................................................ 2-1 2.3 Sample Handling and Custody Requirements........................................................ 2-1 2.4 Analytical Methods Requirements .......................................................................... 2-1 2.5 Quality Control Requirements ................................................................................. 2-1 2.6 Instrument / Equipment Testing Inspectio n, and Maintenance Requirements .. 2-1 2.7 Instrument Calibration and Frequency .................................................................. 2-1 2.8 Inspection / Acceptance Requirements for Supplies and Consumables .............. 2-1 2.9 Data Acquisition Requirements for Non-direct Measurements ........................... 2-2 2.10 Data Management ..................................................................................................... 2-5

3.0 REPORTS TO MANAGEMENT ............................................................................... 3-1

3.1 Project Status Reports .............................................................................................. 3-1 3.2 Results of Performance Evaluations and Audits .................................................... 3-1 3.3 Results of Periodic Data Quality Assessments ........................................................ 3-1

4.0 DATA REVIEW AND VALIDATION ....................................................................... 4-1

4.1 Data Review, Validation, and Verification ............................................................. 4-1 4.2 Validation Methods and Verification Methods ...................................................... 4-1 4.3 Reconciliation with User Requirements .................................................................. 4-1 4.4 Representativeness Assessment ................................................................................ 4-1

5.0 REFERENCES ............................................................................................................. 5- 1

Appendix A Memorandum of UnderstandingProject: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 0 Revision No. 1.11 Revision Date: 7/29/09 Page 4 of 4

TABLES AND FIGURES

Figure 1. Project Organizati on Chart Section1 Page 2 Figure 2. Audit Check Form Section 3 Page 2

Table 1. Data Quality Objectives, Proce dures, and Indicators Section1 Page 12

Distribution List:

John Hornback, SESARM (Executive Director)
Ron Methier, SESARM (SES ARM Project Coordinator) Brenda Johnson, EPA (Region 4 Technical Project Officer, Fine Particles/Ozone) Michele Notarianni, EPA (Region 4 Tec hnical Project Offi cer, Regional Haze) Danny France, EPA (Region 4 QA Manager) William Barnard, MACTEC (Program Manager, Fire Source Task Leader)
Edward Sabo, MACTEC (Point Source Task Leader) Dan Meszler, MESZLER Engineering Services, Inc. (On-road Mobile Source Task Leader) Gregory Stella, Alpine Geophysics, LLC . (Quality Assurance Coordinator)Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 1 Revision No. 1.11 Revision Date: 7/29/09 Page 1 of 14

1.0 PROJECT OVERVIEW
1.1 Project/Task Organization Figure 1 identifies the individuals and organizations participating in the project. Their specific roles and responsibilities include:

 Mr. John Hornback, SESARM Contract Officer ( hornback@metro4-sesarm.org , 404- 361-4000), will oversee all activity on the cont ract, and supervise managerial aspects of the project. He will he lp facilitate communications among State/local agencies, MACTEC, and the SESARM Project Coordinator.

 Mr. Ron Methier, SESARM Project Coordinator ( ronmethier@comcast.net , 770-785- 7978), will work with the SESARM Contr act Officer and State/local Agency Coordinators to define the emission inve ntory development activities needed to support regional haze modeling and planning activities.

 State/local Agency Coordinators will compile and submit data to MACTEC, participate in QA/QC reviews, and help re vise, update, and correct the inventory.

 William Barnard, MACTEC Program Manager and Fire Task Leader ( wrbarnard@mactec.com , 352-333-6617), will direct and monitor technical and financial performance throughout the projec t and will serve as a senior primary contact with SESARM on c ontract and project management issues. Mr. Barnard will also direct aspects of the projection invent ory development related to fire and mobile sources. He will plan and conduct the technical aspects of the development of the fire and mobile source inventories, supervise daily activities, identify effective QC procedures and make recommenda tions on needed QC procedures.

 Edward Sabo, MACTEC Point Source Task Leader ( ejsabo@mactec.com , 703- 471- 8383), will plan and manage all point source activities. He will plan and conduct the technical aspects of the development of the point source inventory, supervise daily activities, identify effective QC procedur es and make recommendations on needed QC procedures.

 Dan Meszler, MACTEC Mobile Source Task Leader ( dan@meszler.com , 410- 569- 0599), will plan and manage all mobile sour ce activities. He will plan and conduct the technical aspects of the development of input files for the MOBILE/MOVES models. He will help identify effective QC procedures and make recommendations on needed QC procedures.

 Mr. Gregory Stella , QA Coordinator ( gms@alpinegeophysics.com , 828- 675-9045), will help ensure that adequate QA/QC proce dures are incorporated into the inventory development process. He will work indepe ndent of the inventory development Task Leaders to assist in the conduct of project QA/QC assessments.Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 1 Revision No. 1.11 Revision Date: 7/29/09 Page 2 of 14

SESARM Project Coordinator
Ron Methier SESARM State & Local Coordinators

Program Manager

William Barnard
MACTEC SESARM Contract Officer

John Hornback

Fire Source Task Manager
William Barnard Mobile Source Task Manager
Dan Meszler Point Source Task Manager
Edward Sabo QA Coordinator Gregory Stella
Alpine Geophysics

FIGURE 1 – PROJECT ORGANIZATION CHARTProject: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 1 Revision No. 1.11 Revision Date: 7/29/09 Page 3 of 14

1.2 Problem Definition/Background
Southeastern States Air Resource Managers Inc. (SESARM) is a corporation registered in the state of Georgia and organized under the nonprof it provisions of the Internal Revenue Code, Title 26, Subtitle A, Chapter 1, Subchapter F, Part I, Section 501 (c)(3). It was formed by, and serves the needs of, the air pollution control agen cies located in the southeastern region of the United States, to which the Environmental Protec tion Agency (EPA) refers as Region 4. Eight states are members of SESARM – Alabama, Fl orida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, and Tennessee. SESARM maintains its corporate office in Forest Park, Georgia.

The United States Environmental Protection Agency (EPA) designated SESARM as the organization responsible for conducting regiona l air quality planning in the Southeast, specifically for regional haze. SESARM created a collaborat ive effort called Visibility Improvement – State and Tribal Association of the Southeast, al so known as VISTAS.

In 2001, SESARM invited the contiguous states of Virginia and West Virginia to join the regional haze effort. SESARM al so invited the local agencies in the Southeast to be represented by the Knox County, Tennessee air pollution contro l program. Though south eastern tribes are not required to develop and submit tribal impl ementation plans, SESARM invited the Eastern Band of Cherokee Indians to represent the six federally-recognized Southeastern tribes.

The participating state agencies have obligations to protect human health and the environment from the impacts of air pollutants. They are responsible for air quality planning efforts and have primary authority and responsibility to deve lop, adopt, and implement state implementation plans (SIPs) for all air pollutants and aesthetic concerns including fine particles, ozone, and regional haze.

A memorandum of understanding was develo ped in 2001 by SESARM and executed among the participating agencies to forma lize their regional haze project commitment as well as to establish formal goals and procedures for technical ai r quality analyses. An unsigned copy of the memorandum is provided in Appendix A. A polic y board (the STAD), a day-to-day operations group (the Coordinating Committ ee), and three work groups (Data, Planning, and Technical Analysis) were created to oversee, guide, and conduct the collaborative work within SESARM’s structure. The projects continue to be managed in this manner. Later, fine particle and ozone SIP support was identified as an additional cr itical opportunity for SESARM to assist the participating state agencies in managi ng, improving, and maintaining air quality.

The work of SESARM and the in-kind services of the participating agencies are designed to produce technical analyses to aid the participati ng agencies in developing SIPs required by the Clean Air Act. SESARM solicits input from various stakeholders to the fi ne particle, ozone, and regional haze projects. Participa tion is also encouraged from repr esentatives of federal agencies including EPA, the Department of Agriculture’s Forest Service, and the Department of Interior’s National Park Service and Fish and Wildlife Service; the regulated community; academia; environmental groups; and the general public.Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 1 Revision No. 1.11 Revision Date: 7/29/09 Page 4 of 14

The project supported by this contract shall c onsist of development of a comprehensive annual emissions inventory for the Southeast to suppor t modeling and assessment of the emissions and atmospheric processes that result in fine particles, ozone, and regional haze. This work shall include development of at least one base year inventory consistent with the Environmental Protection Agency’s (EPA’s) crite ria for emission reporting. Candi date modeling base years for inventory development are 2005 and 2008. States ar e also considering whether meteorological conditions in 2006 or 2007 would be more repres entative as the modeling base year. In consultation with its participating agencies and EPA, SESARM will decide which year to use as the base year before th e inventory work begins.

This project shall include deve loping emissions inventories for at least one future year for emissions and air quality modeling purposes. SESARM will select the future modeling year or years as appropriate to support fine part icle, ozone, and regional haze objectives.

Finally, this project shall also include development of emissions inventories for future year control strategies that will s upport modeling and assessment of c ontrols necessary to assess the extent of NAAQS attainment and regional haze.

The purpose of this Quality Assurance Project Plan (QAPP) is to outline and guide the process for quality assuring the inventory development to ensure the development of complete, accurate, and consistent emission inventor ies. The QAPP is consistent w ith the recommendations in the EPA quality assurance requirements 1 and the Emission Inventory Improvement Program’s QA guidance 2 . The QAPP includes tasks associated w ith obtaining State data, merging and augmenting State submittals with available EP A databases, improving the activity data and emission factors for important source categorie s, obtaining and developi ng growth and control factors, obtaining State and st akeholder review of the emi ssion inventory, and providing documentation of the maintenance (revisions, updates, corrections) of the inventory.

1.3 Project/Task Description MACTEC will produce preliminary and final sets of comprehensive annual base year and future year emissions inventories for point sources, on-road mobile s ources, and fire sources for the participating states to support re gional air quality m odeling and assessment of fine particles, ozone, and regional haze. Emissions shall be re ported by source category (i.e., point, on-road mobile, fire) by county for each county in Alabam a, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee, Virginia, and West Virginia. The emissions inventory development shall be specific to th ese states only. SESARM shall obtain emissions inventories for other states directly from those states or their respectiv e regional organizations. Additional reporting requirements for the majo r source categories are discussed below.

The emissions inventories shall consist of all primary and precursor emissions necessary to accurately model fine particles and ozone including ammonia (NH 3 ), carbon monoxide (CO), nitrogen oxides (NO x ), particles with a diameter less than 2.5 micrometers (PM 2.5 ), particles with a diameter less than 10 micrometers (PM 10 ), sulfur dioxide (SO 2 ), and volatile organic compounds (VOCs) for point sources, on-road mobile sources, and fire sources.Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 1 Revision No. 1.11 Revision Date: 7/29/09 Page 5 of 14

To project emissions from the base year to fu ture years, MACTEC will review, summarize, and recommend methods and growth and control fact ors consistent with SESARM’s objective to develop future year base case a nd control strategies for demonstrating attainment with the PM 2.5 and ozone National Ambient Air Quality Standa rds (NAAQS) and to meet reasonable progress obligations for improving visibility. These me thods and factors shal l include the control technologies and associated percen tage reductions, rule effectiven ess, rule penetration values, growth rates, and energy efficiency factors used to generate the future year base case and control strategy emissions inventories.

The emission inventories shall be delivered in el ectronic format consistent with the requirements for conducting regional emissions and air quality modeling. The emission model input formats shall be defined once the emissions model has been selected. Inventories shall also be provided consistent with EPA’s current emissions i nventory reporting requirements. The SESARM Project Coordinator shall provide more specific di rection on inventory format s, if clarification is needed, after development of a detailed work plan is initiated. Current emission inventory reporting requirement s can be found in a variety of documents available on EPA’s website. Links to some of these documents include sections 6, 7, 9, 10 and 11 of the 2008 NEI/EIS implementation plan found at http://www.epa.gov/ttn/chief/net/neip/index.html , as well as more general guidance documents which can be found at http://www.epa.gov/ttn/chief/publications.html . Finally aspects of both the Air Emissions Reporting Rule (AERR) and Consolidate Emissions Reporting Rule (CERR) will be employed in developing inventories for this project. Documents detailing emission reporting requirements under thes e two rules can be found at http://www.epa.gov/ttn/chief/aerr/ and http://www.epa.gov/ttn/chief/cerr/index.html , respectively.

MACTEC will work consistent w ith Contract provisions, federal grant and project requirements, and the final project work plan to coll ect, quality assure, document, and prepare recommendations for the use or revision of these data for the purposes of developing base year and future year inventories. MACTEC will par ticipate in meetings and conference calls and provide insight, background, and suggestions within their areas of exper tise. Further, MACTEC will provide upon request written reports and/or an alyses of certain aspects of the inventory development work. The methods used to deve lop the inventories shall be documented in technical reports for purposes of supporting state implementation plan s (SIPs) for fine particles, ozone, and regional haze. All revisions to inventor ies and the sources of the revisions shall be clearly documented. The Project Coordinator shall provide overa ll SESARM program management and specific technical direction to this project. This QAPP focuses on the tasks associated with developing th ese inventories.

Base Year Inventory Activities. The effort includes the following point, on-road and fire emission activities:

EGU Point Source Activities. For point sources, the following tasks will be performed:Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 1 Revision No. 1.11 Revision Date: 7/29/09 Page 6 of 14

1. Obtain State/local 2005 CERR submittals from EPA’s ftp site (or directly from the State/local agency if the State/local agency has updated the 2005 inventory since submittal to EPA). Version 3 of the 2005 NEI (containing the 2005 CERR submittals) will be the primary source of this data.

2. Obtain unit-level 2005 EGU annual emissions and other data from CAMD’s eGRID database.

3. Obtain 2005 EGU hourly CEM data from CAMD website; determine whether State/local agencies have CEM data that differs from or is in addition to th e CAMD data; perform QA/QC checks of CEM data to identify missing data or po tential outliers.

4. Develop a cross-reference file from the above th ree data sets to rela te unit identifiers in the CERR submittals with the CAMD unit iden tifiers; coordinate with State/local agencies in resolving inconsistencies.

5. Compare the 2005 data to SESARM’s 2002 Be st and Final Invent ory and identify any unmatched units or large changes in emissions.

6. Analyze the PM emissions in the CERR submittal and determine which PM species are present (i.e. PM 10 vs. PM 2.5 , filterable vs. condensable); augment data as necessary using EPA’s NEI PM data augmentation procedures or recently developed PM condensable emission factors for EGUs.

7. Prepare an easily reviewable master EGU cr oss-reference table for 2005 that includes the following elements: CERR and CAMD unit identifiers; annual NO x and SO 2 emissions, heat input, and base year air pollution c ontrol systems from the three data sources (CERR, CAMD annual, CAMD hourly); PM emissions as reported in the CERR along with any adjustments resulting from the PM augmentation procedure; emissions of other criteria pollutants; and stack para meters and location coordinates.

8. Provide the EGU table for re view and verification by th e State/local agencies.

9. Determine which source of emissions data is preferred for use in the base year file, either for the SESARM region as a whole or on a case-by-case basis as directed by SESARM or the State/local agencies.

10. Perform QA/QC checks on stack and location da ta to identify missing data or potential outliers.

11. Prepare electronic data files in NIF output format, maintaining data fields to clearly document the source of data used for each emission value.

12. Execute EPA’s Basic Format and Content Checke r tool to verify referential integrity of the database. The above items assume a 2005 base year. If an alte rnative base year is se lected the methods will be revised to reflect the change in base year. In some cases this will result in elimination of some items and in others the comparisons made will di ffer. For example if 2008 is chosen as the base year the 2008 inventory developed will use updated data from the States on the EGUs and willProject: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 1 Revision No. 1.11 Revision Date: 7/29/09 Page 7 of 14

be compared to the 2005 CERR submittals rather than to 2002 Best and Final Inventory (or a comparison of all three inve ntories may be made).

In addition to the actual emission base year i nventory, MACTEC will prepare a typical base year inventory for EGUs to correct for possible non-typical operating conditions during the modeling base year. We will obtain and review any exis ting ERTAC EGU Temporal and CEM Data Work Group methods or recommendations , and provide any additional recommendations to SESARM. We will obtain CEM data for EGUs for the 2001-2005 (and additionally 2006-2008, if directed by SESARM) so that we have five years of data corresponding to the five years that contribute to the base year design value. Previously, MACT EC used the average heat input from the contributing years to define heat input and emi ssions for the typical EGU inventory. The specific methods and years to be used for typical EGU em issions will be determined in consultation with SESARM.

Non-EGU Point Source Activities. For non-EGU point sources, the following tasks will be performed:

1. Obtain State/local 2005 CERR sub mittals from EPA’s file transf er protocol (ftp) site (or directly from the State/local agency if the State/local agency has updated the 2005 inventory since submittal to EPA). Versi on 3 of the 2005 NEI (containing the 2005 CERR submittals) will be the primary source of this data.

2. Remove any units from the CERR file that have already been accounted for in the EGU file developed above to ensure that no double- counting of emissions occurs, particularly for co-generation plants where double-counti ng was a concern during the development of the 2002 Best and Final Inventory.

3. Execute EPA’s Basic Format and Content Checker to identify errors or anomalies in the 2005 CERR data; coordinate with State/loca l agencies in resolving any issues.

4. Determine whether State/local agencies have hourly CEM data for non-EGU sources that are not in the CAMD database ; obtain CEM data and perform QA/QC checks to identify missing data or pot ential outliers.

5. Compare the 2005 data to the SESARM’s 2002 Be st and Final Inventory and identify any unmatched facilities or facilities with la rge differences in emissions between 2002 and 2005; provide comparison to State/lo cal agencies for verification.

6. Analyze the particulate matter (PM) emissions in the CERR submittal and determine which PM species are present (i.e. PM 10 vs. PM 2.5 , filterable vs. condensable); augment data as necessary using EPA’s NEI PM da ta augmentation procedures or recently developed PM condensable emi ssion factors for non-EGUs.

7. Perform QA/QC checks on stack and location da ta to identify missing data or potential outliers, focusing review on the larger non-EGU sources.

8. Prepare electronic data files in NIF output format, maintaining data fields to clearly identify the source of data us ed for each emission value.Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 1 Revision No. 1.11 Revision Date: 7/29/09 Page 8 of 14

9. Re-execute EPA’s Basic Format and Content Ch ecker tool to verify referential integrity of the database.

As with EGU sources, if a different base year from 2005 is chosen the methods listed will be modified to work with the year chosen.

Fire Emission Activities. For fire emissions, the following tasks will be performed:

1. Data collection and data entry - available elect ronic fire activity data will be collected for at least for one year from 2005 to 2008, from st ate and federal forestry agencies in the Southeast all available electronic records of fire activity for wild fire, prescribed fire, land clearing, and agricultural bur ning. If states do not have an electronic version of prescribed fire records, MACTEC will consult with SESARM to receive further direction. MACTEC will review all submitted electronic re cords and shall identify to state and federal forestry agencies missing data records. An important aspect of this work is to identify duplicate records since activit y data received from State and Federal agencies may contain overlapping records. MACTEC will use comparisons of time, date, latitude and longitude and othe r identification tools to assist in indentifying the duplicate records. Data for land clearing and agricu ltural burning will also be collected.

2. Development of an initial fire inventory for the modeling base year – MACTEC will work with State and Federal forestry ag encies to modify or update the existing CONSUME database if necessary to calcu late emissions consistent with fire characteristics in the Southeast. Informati on updated will include methods to define acreage and parameters for calculating emissions for wild land fires, prescribed fires, land clearing, and agricultural burning. Because fuel loading is one of the keys to assessing fire emissions, MACTEC will use a reasona ble fuel loading model. Data for daily emissions shall be collected and summarized monthly by county, stat e, fire type, and pollutant.

3. Evaluation and merger of sate llite and ground-based fire acti vity data - the ground-based fire activity data collected from the State a nd Federal forestry agencies will be compared to the SMARTFIRE activity data based on satellite records of fire occurrence. Depending upon funding availability, the efficiency of SM ARTFIRE in merging the two fire activity data sets will be evaluated for a single modeling year. MACTEC will compare, for the modeling base year only, the ground-based fire activity record s developed and the merged satellite and ground-based fire activ ity records from SMARTFIRE and provide a technical assessment of SMARTFIRE’s pe rformance in identifying and merging corresponding fire events. MACTEC will r ecommend methods that might improve the merged satellite and ground-based data for the modeling year and secondarily, for an average of the period 2005-2008. MACTEC will then provide methods and costs to complete this evaluation and recommendations including options to review records for a single state rather than ten stat es as an approach to reduce the costs of the evaluation. The State and Federal forestry and air quality agencies will review these recommendations and available funding to determine the level of effort that will be authorized to expand onProject: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 1 Revision No. 1.11 Revision Date: 7/29/09 Page 9 of 14

merging SMARTFIRE and SESARM ground based fi re activity data. If authorized by the SESARM Project Coordinator, MACTEC w ill implement the methods approved by state and federal agencies for merging the satellite and ground-based data.

4. Apply approved fire inventory development methods to merged fire activity data and electronically archive – MACTEC will work with all parties to finalize the methods to be used for the Southeast to develop a base y ear fire emissions inventory for SESARM’s regional air quality modeling purposes. MAC TEC will apply approved fire inventory development methods to merged satellite and ground-based fire activity data

5. Document fire inventory - the fire inventory methods and resu lts will be summarized in a report. A draft report will be delivered with th e initial fire inventor y. That report will be revised to reflect the methods and results arising from later tasks (e.g., the SMARTFIRE comparison).

6. Develop typical modeling base year fire in ventory - a typical fi re inventory will be developed and reported consistent with emi ssions and air quality modeling requirements. To correct for possible non-typical fire act ivity during the modeling base year for purposes of future year inventory projections for each county and/or state, MACTEC will develop average activity data for 2005-2008 for w ild fire and prescribed fires. MACTEC will adjust acreage for individual fires in the modeling year by the average acreage for the county or state over the period 2005-2008. The specific methods applied shall be resolved in consultation with SESARM and federal forestry and air quality agencies.

On-road Mobile Source Emission Activities. For on-road mobile sour ce emission sources, the following tasks will be performed:

1. MACTEC will collect th e latest available on-road mobile data from southeastern agencies and EPA for the selected modeling ba se year. Southeastern air quality agencies shall coordinate with local air agencies, state transportation agencies, and/or local planning organizations as necessary to obtain relevant mobile model input data for the base year. Link-level mobile activity data sha ll be obtained for those states that request that link data be used in mobile modeling. At this time, Georgia is on-record with such a request.
2. Currently, on-road emissions are calculated using the MOBILE6 emissions model. EPA is developing a new model called MOVES (M otor Vehicle Emission Simulator) that will eventually replace the MO BILE and NONROAD models, and that states may soon be required to use for on-road and/or non-road mobile emissions calculations.. EPA released a draft version of MOVES on April 9, 2009, requested comments on "Draft MOVES2009" by July 2009, and plans to rel ease a "final" versi on of MOVES (for onroad sources; draft for nonr oad) by the end of 2009. The final version of MOVES is expected to be functional for emissions mode ling, but it is unclear how/if it will interface with air quality modeling emissions processors (e.g., SMOKE). MACTEC will process local and state data and provide model inputs to the southeas tern agencies for review and confirmation. Upon direction from the SESARM Project Coordinator, the Contractor mayProject: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 1 Revision No. 1.11 Revision Date: 7/29/09 Page 10 of 14

be requested to run MOBILE6/SMOKE or M OVES to produce mobile emissions that are consistent with relevant EPA emission inve ntory reporting requirements. For emissions modeling purposes, MACTEC will provide the approved model inputs to the emissions and air quality modeling contractor to proce ss the mobile emissions. As the status of MOVES becomes more certain, MACTEC will, at SESARM’s request, prepare a specific scope of work revision and cost estimate for wo rk resulting from this transition that is not reflected in this Contract. MA CTEC will initiate and complete work consistent with the revised scope of work upon direction from SESARM.

3. SESARM is participating in a national proj ect to evaluate particulate matter emission profiles for highway vehicles using result s of an emission measurement study for gasoline and diesel vehicles in Kansas City , Kansas. The current project will develop revised mobile emissions profiles for two nor thern cities, Detroit, Michigan and New York, New York and compare these revise d profiles to those currently used in MOBILE6. MACTEC will review these findings and recomme nd modifications, if any, to mobile emissions profile s for southeastern states. In addition to developing a base year inventor y, MACTEC will also be developing projection year inventories. The projecti on year is anticipated to be either 2012 or 2013. Projection inventory activities are listed below.

Projection Inventory Activities. The effort includes the following activities:

1. Assemble preliminary “b ase case” data for 2012/2013.

2. Prepare the draft “base case” inventory for 2012/2013.

3. Growth and control factor review and assessm ent. Growth and control factors available for use in developing the draft and final 2012/2013 inventory will be reviewed, assessed and recommendations which factors to use will be made to SESARM. Any required changes will be made and applied to the fina l inventory. This will include an evaluation of preparation of EGU projec tions both with and without pr oprietary projection models (e.g., IPM).

4. Assemble the final 2012/2013 “base case” invent ory. This inventory will be based off of the latest revision to the ba se year inventory, revised c ontrol information and revised growth factors.

5. Recommend methods for control strategies.

6. Prepare control strategy inventories (if funded).

7. Develop a projection inventory for an alternative future year (if funded).

8. Develop a “typical year” inventory for electric generating units (EGUs)

9. Develop a “typical year” inventory for wild and prescribed fires.Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 1 Revision No. 1.11 Revision Date: 7/29/09 Page 11 of 14

Other Activities. In addition to the above tasks related to base and projection year inventories, the following tasks will be performed:

1. Contingencies related to other work tasks.

2. Preparation of reports.

3. Data display and archive.

1.4 Quality Objectives and Crit eria for Measurement Data The goal of the inventory process is to provide the best possibl e inventory under given resource constraints. Data Quality Obj ectives (DQO) are statements about the level of acceptable uncertainty or error. Their purpose is to ensure that the final data will be sufficient for the intended use of the inventory. A well develope d and implemented quality assurance program fosters confidence in the invent ory and any resulting regulatory program. It also gives the end user important information about the limitations of the emission estimates in order to avoid misuse of data.

Table 1 summarizes the Data Quality Objectiv es for the SESARM inventories that will be compiled for this contract. The first column of Table 1 defines four data quality objectives: accuracy, completeness, comparability and represen tativeness. The second column identifies the procedures that will used to achieve each obj ective. The third column identifies Data Quality Indicators (DQI), which are qualitative and qua ntitative descriptors used in interpreting the degree of acceptability or utility of data.

1.5 Special Training Requiremen ts / Certification Listed All staff performing data review and analysis ar e air quality professiona ls and have sufficient education/experience to perfor m emission estimation calculations and work with emission inventory databases. Most sta ff have received specific emi ssion inventory training through conferences, workshops, self-study programs, an d on-the-job work experiences. There are no specifically mandated training requirements for work performed on this project.

1.6 Documentation and Records QAPP Control. Any changes to this QAPP will be initia ted either by the Program Manager, the Task Leaders, or the QA coordinator. Each change will be given a revision number and date in the document control block in the upper corner of the affected pages. It will be the responsibility of the initiating person to dist ribute copies of the changed pa ges to all the persons on the Distribution List and to the appr opriate project team members.

Data Collection Records. Clear documentation of the data collected from the State/local agencies, EPA, and other agencies is integral to the quality analysis review. Records will be maintained containing a description of the data received, the name of the person and agency submitting the data, the date of the submission, a nd other relevant information about the data submission. The following types of data wi ll be collected during this project:Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 1 Revision No. 1.11 Revision Date: 7/29/09 Page 12 of 14

 EPA’s 2005 National Emission Inventory (version 3)

 State CERR submittals

 State/local agency data submittals in NIF 3.0 format

 Forestry officials data submittals for wild and prescribed fires

 Mobile source input files provided by State/local air agencies or EPA

 EPA’s Final Summary Emission Reports for CEM information for electric utilities regulated by the Acid Rain Program

 EPA’s Toxic Release Inventory for ammonia emissions data

 State agency submittals of information necessary to calculate fire emissions and geographically locate where these fi res occurred in the base year.

 State/local agency revisions, updates, co rrections in response to various QA/QC checks. These may be provided in a variety of formats depending on the nature of the
response.

 Department of Energy fu el efficiency data

 EGAS or other growth factors availa ble from EPA, DOE, or the States

 VMT dataProject: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 1 Revision No. 1.11 Revision Date: 7/29/09 Page 13 of 14

TABLE 1 DATA QUALITY OBJECTIVES, PR OCEDURES, AND INDICATORS

Data Quality Objective Pro cedures Example Indicators Accuracy - reduce uncertainty in emission estimates where possible, validate that data elements needed for modeling are within accepted parameters, and verify that emission estimates agree with accepted reference values. 1. Identify weaknesses in existing inventories, identify new methods/data to reduce uncertainty, and obtain new activity/emission factor data where available.2. Use EPA’s NIF QA tool and adhoc reports to perform computerized checks of valid codes/data ranges and to identify outliers. 3. Conduct senior technical review of pollutant totals by facility, source category, state, and region. 4. Compare to other published data. 1. Qualitative assessment of the inventory’s strengths and weaknesses. 2. 100% of stack data and temporal

factors in valid ranges for > 100 tpy sources. 3. 100% of sources have valid

geographic coordinates. 4. 100% correction of significant

outliers. 5. Agreement of SESARM

emissions and EPA CEM data and EPA TRI data. 6. Compare projection emissions to

base year emissions to ensure that values are within expected ranges. Completeness – include all major point sources, include emission estimates for PM 2.5 and ammonia, verify that all on-road mobile source categories and fire sources are accounted for. 1. Compare SESARM utility data to EPA CEM data. 2. Compare SESARM point source ammonia data to EPA TRI data. 3. State/local agencies compare facility list to their Title V permit lists. 4. Compare small point source emissions to area source emissions. 5. Compare PM 10 and PM 2.5 emissions. 6. Plot fire sources by type. 1. 100% of all utilities accounted for in database. 2. 100% of large ammonia sources

in TRI accounted for in database. 3. 100% of Title V sources

accounted for in database 4. Small point sources included as

either small point sources or as

area sources. 5. PM 2.5 and ammonia emissions

included in inventory 6. Fire emissions for all counties in

region accounted for. 7. All mobile sources accounted for. 8. Explanation of any missing data

or sources. Comparability – verify that emission estimates are similar to other peer-reviewed inventories and that any major deviations are explained. 1. Compare emission totals by source category, pollutant, geographic region, and year with previous emission inventories. 1. Explanation for large discrepancies in emissions

Representativeness – use emission estimation methods that reflect local conditions and the time period of interest. 1. Identify where national defaults used instead of local activity data. 2. Identify where emissions were grown for base year 2002 data were not available. 3. Identify growth factors for projection years. 1. Explanation for use of national defaults. 2. Determination of representative

values for “typical years” for some sources for projections (i.e., fires, utility emissions).Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 1 Revision No. 1.11 Revision Date: 7/29/09 Page 14 of 14

Data Handling Records. Another key element of the QA pr ogram is maintaining written documentation of calculations, assumptions, and all other activities associated with incorporating the State/local agency submittals and other da ta with the EPA’s National Emission Inventory. Nearly all data being developed and/or comp iled will use computerized databases or other electronic files. For many of these databases, we will use blank fields in the database tables to keep track of the source of the data. We will al so maintain a log of activities to document how the data described above were incorporated to create the SESARM inventories. The log will include complete descriptions of the data sources used, the pro cedures used to incorporate the data, the approach used to determine the comp leteness, and any contacts made with data submitters to resolve questions. A file will be main tained to ensure that the data handling records are retained and easily located.

QA/QC Records. We will perform a variety of quality control reviews of the inventory. For example, we will check stack parameters, source classification codes, and geographic coordinates for point sources th at emit at least 100 tons of any pollutant per year. Reports containing the results of these checks will be transmitted to the State/local agencies for investigation and correction. Documentation of each finding will include a description of the action or data reviewed that led to the quali ty concern and will provide recommendations for corrective actions.

Corrective Action Records. Records of corrective and follow- up actions identified during the quality review process will be maintained. Both the corrective action identified and the results of the actions taken in response will be documented fo r inclusion in the final report. If no corrective action can be made, we will document the implica tions on the overall quality of the inventory.

Data Reporting Package. The final data reporting package will contain four elements:

 An emission summary report that describes the emissions inventory by pollutant and source category, summarizes the methods and data used to compile the inventory, assesses the limitations and appropriate uses of the inventory data, and contains any other information pertinent to the invent ory (including emission density maps);

 A quality assurance summary report that describes the quality assurance efforts completed, summarizes the corrective actio ns taken, and provide s suggestions for further inventory improvement based on the re sults of the quality assurance process;

 Electronic data files containing the SESARM inventories in NIF 3.0 format as well as SMOKE or other specified format (includi ng GIS shape files where applicable); and

 Electronic and paper files containing all original data submittals and all backup documentation will be stored on file at MACTEC for a period of no less than three
years.Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 2 Revision No. 1.11 Revision Date: 7/29/09 Page 1 of 5

2.0 SAMPLING This section describes any sample handling, sampling methods, analytical methods, quality control requirements as they re late to samples, instrumentatio n testing, inspection, maintenance and calibration, consumable inspection and acceptan ce criteria, data acqui sition requirements for non-direct measurements and data management operations. Since this project is an emissi on inventory development effort mo st of the sampling areas are not applicable to this work.
2.1 Sampling Process Design (Experimental Design) No sampling will be performed as part of this work, thus this section does not apply to this work effort.
2.2 Sampling Methods Requirements No sampling will be performed as part of this work, thus this section does not apply to this work effort.
2.3 Sample Handling and Custody Requirements No sampling will be performed as part of this work, thus this section does not apply to this work effort.
2.4 Analytical Methods Requirements No sampling will be performed as part of this wo rk, thus no analyses will be performed so this section does not apply to this work effort.
2.5 Quality Control Requirements No sampling will be performed as part of this work, thus this section does not apply to this work effort.
2.6 Instrument / Equipment Testing In spection, and Maintenance Requirements No sampling will be performed as part of this work, thus this section does not apply to this work effort.
2.7 Instrument Calibration and Frequency No sampling will be performed as part of this work, thus this section does not apply to this work effort.
2.8 Inspection / Acceptance Requirements for Supplies and Consumables No supplies or consumables affecting quality will be acquired as part of this work effort thus this section is not applicable.Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 2 Revision No. 1.11 Revision Date: 7/29/09 Page 2 of 5

2.9 Data Acquisition Requirements for Non-direct Measurements The base year and projection year SESARM in ventories will rely primarily on air emission information from existing databases. The data collection, handling, and management process is described below, along with the associated qua lity control procedures and methods. The QC system is designed to:

 Provide routine and consistent checks a nd documentation point s in the inventory development process to verify data in tegrity, correctness, and completeness;

 Identify and reduce errors and omissions;

 Maximize consistency within the inventor y preparation and documentation process;

 Facilitate internal and external inventory review processes. The data acquisition process should be viewed as an iterative process. As decisions are made, new questions will surface that require solu tions, until the iterations are complete.

2.9.1 Base Year Inventory Update Procedures For the base year inventory update, the following procedures will be used to compile and quality assure the revised base year SESARM emission inventory:

1. Discuss with States what information was s ubmitted to EPA as part of the CERR process to determine where differences are between CERR and SESARM ba se year inventory

2. For those States that indicate that CERR su bmittals should be used, obtain State CERR inventory submittals

a. Download State files from EPA ftp site or EPA NEI version 3 files b. Prepare and review emission summaries at the SCC level to verify that emissions by source category, geographic region, and po llutant are complete and reasonable.

c. Maintain log of data rece ived and identify format. d. Compare facility level emissions from State/local agency submittal with CERR, identify significant discrepancies in emissions (especially PM 2.5 and ammonia), identify potentially missing facilities.

e. Provide State/local agencies with results of 2(b) and 2(d) and ask for State/local agency assistance in resolving any problems/issues that have been identified f. Obtain and process State/local agen cy corrections/updates as required

3. Augment with PM 2.5 data if State/local submittal did not include PM 2.5 using EPA NEI augmentation methodology

4. Augment with ammonia emissions data if St ate/local submittal di d not include ammonia using EPA NEI augmentation methodology or possibly augment with ammonia emission data from the EPA TRI database (point sources only).

5. Assess the procedures used to evaluate and to account for potential double counting.Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 2 Revision No. 1.11 Revision Date: 7/29/09 Page 3 of 5

6. Compare and augment (if necessary ) with base year specific NO x and SO 2 emissions data collected by ETS/CEM procedures by EPA’s Clean Air Market Division

7. Track comments/concerns received and corrective actions taken

8. Provide inventory for review by State/local agencies

a. Prepare an emission summary report that describes the emissions inventory by pollutant and source category, summarizes the methods and data used to compile the inventory, assesses the limitations and appropriate uses of the inventory data, and contains any other informa tion pertinent to the inventory b. Prepare a QA/QC summary report that describes the efforts completed, summarizes the corrective actions taken, and provides suggestions for further inventory improvement based on the resu lts of the quality assurance process

c. Provide data files containi ng the base year SESARM inventory in NIF 3.0 or other specified format d. Provide electronic data files in SMOKE or other specified format

e. Track comments/concerns received and corrective actions taken

9. Incorporate feedback from stakeholders and prepare final reports and electronic files.

2.9.2 Projection Year Inventory Procedures For the projection inventories, the following procedures will be used to compile and quality assure the inventory:

1. Prepare Base Growth Inventory

a. Use the final version of the SESA RM Base/Typical Year inventory b. Back calculate uncontrolled em issions for Base/Typical Ye ar inventory to use as starting point for sources that will be grown for th e projection inventory.

2. Prepare/Obtain Growth and Control files

a. Obtain growth factor files from EGAS or other appropriate gr owth factor source for use with categories that will be grown with growth factors. b. Obtain control factors for “on-the-book” a nd “on-the-way” controls as well as any controls for control strategy evaluations. C ontrols will be obtained from recent EPA rulemakings, proposed rules, and State SIPs.

c. Obtain and calculate DOE energy effici ency factors for use with combustion

sources. d. Determine/obtain growth factors for non-E GAS sources. Growth factors for these sources will be calculated from existing projection inventorie s prepared by EPA. Growth factors will be calculated using lin ear interpolation of projected emissions if the actual year is not available.

3. Project sources using growth and control factors

a. For sources to be grown using growth fact ors, apply growth a nd control factors. b. For combustion sources apply energy efficiency factor.Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 2 Revision No. 1.11 Revision Date: 7/29/09 Page 4 of 5

c. Identify and resolve any errors/discrepan cies from the use of growth factors or other growth factor data d. Track comments/concerns received and corrective actions taken

4. Determine emissions for sources re quiring “typical” year emissions.

a. These sources include EGUs and fires b. For fires obtain long term estimates of acres burned. Determine average fire emissions across the period that the data cover. Estimate “typical” emissions based on either average spatial distributi on or random selection of fires across time period.

c. Obtain typical year emission data from EGU sources coupled with long term reported CEM data. d. Alternatively use IPM projection inventories for projection years. If this approach is taken, review by stakeholders prior to final inventory.

5. Develop mobile source emission inventories

a. Prepare projected VMT for review by St ates/stakeholders for onroad mobile

sources.
b. Prepare MOBILE or MOVES input files for review by States/stakeholders. MOBILE/MOVES input files will contain re quired control programs either “on- -the-books” or “on-the-way”.

6. Conduct QA/QC to identify e rrors and inconsistencies

a. Prepare emission density maps and ad-hoc reports to identify gaps and logical inconsistencies. b. Ask States/local agencies to provide feedback on large scale inconsistencies and on missing sources.

c. Update database with Stat e/local supplied revisions. d. Track comments/concerns received and corrective actions taken

7. Provide inventory for review by State/local agencies

a. Prepare an emission summary report that describes the emissions inventory by pollutant and source category, summarizes the methods and data used to compile the inventory, assesses the limitations and appropriate uses of the inventory data, and contains any other information pertinen t to the inventory (i ncluding emission density maps for all source categories) b. Prepare a quality assurance summary report that describes the quality assurance efforts completed, summarizes the co rrective actions taken, and provides suggestions for further inventory improveme nt based on the resu lts of the quality
assurance process

c. Provide electronic data files containing the SESARM inventories in NIF 3.0 or other appropriate format d. Provide electronic data files in SMOKE or other appropriate format (including GIS shape files)

e. Track comments/concerns received and corrective actions takenProject: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 2 Revision No. 1.11 Revision Date: 7/29/09 Page 5 of 5

8. Incorporate feedback from stakeholders a nd prepare final report s and electronic files

2.10 Data Management MACTEC will provide to SESARM at least one electroni c copy of all input files and output files for emissions models used to develop the emissions inventories (e.g., MOBILE/SMOKE or MOVES) and any supporting techni cal analyses to the SESARM Project Coordinator and State and Local Agencies in accordance w ith SESARM’s prescribed schedule.

Inventory data shall be designed for archiv al on a common SESARM data website. MACTEC will promptly post the electronic inventory data on an interim web site. When a new version of the inventory is developed, previous versions of inventory shall be moved to an archive section of the website so that it is clear which data sets are the most recent. Some data may be kept on a password protected website. MACTEC will keep the website up-to-date. The procedures for data archival will be clearly described in the draft and final reports. At the c onclusion of the project, MACTEC will provide the interim and final pro ducts in a format prescribed by SESARM to SESARM’s webmaster for permanent posting.

Data storage and retrieval will be performed using MACTEC’s computer and Microsoft Access database management software. Some data may be stored in MySQL files (if MOVES is used to prepare the on-road emission estimates).

Data file storage will be on MA CTEC’s servers. The data on thes e servers is backed up nightly to a tape backup system. Restoration of lost or damaged files can be accomplished in a matter of hours. All data on MACTEC’s servers ar e limited access using password protected user profiles and storage spaces. Delivered files can be password protected or delivered in an uneditable format (e.g., locked PDF files). Spread sheets will be protected to mitigate changes to any data submitted.Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 3 Revision No. 1.11 Revision Date: 7/29/09 Page 1 of 3

3.0 REPORTS TO MANAGEMENT The subsections in this group address the activit ies for assessing the e ffectiveness of project implementation and associated QA and QC activities. The purpose of the a ssessment is to ensure that the QA Project Plan is implemented as pr escribed. The assessment consists of external activities that include a planned system of revi ew and audit procedures by personnel not actively involved in the inventory development proces s. The key concept of this component is independent objective review by a third party to access the effectiveness of the internal Quality Control program and the quality of the inventory, and to reduce or eliminate any inherent bias in the inventory process.
3.1 Project Status Reports Monthly project status reports will be delivered via te lephone by the MACTEC Program Manager to the SESARM Technical Coordinator. The monthly status reports will include a discussion of any QA issues arising from either scheduled audits or interim findings as a result of on-going QA procedures.

3.2 Results of Performance Evaluations and Audits The MACTEC Quality Assurance Coordinator will conduct techni cal systems audits throughout the project. Audits are managerial tools used to evaluate how effectivel y the emission inventory team complies with predetermined specifications for developing an accurate and complete inventory. The MACTEC QAC will conduct audits at the initiation of each project to review the Work Plan and QAPP, at the 50% complete and 75% complete levels to review the technical aspects of each project and at the 95% completio n level to review the data submittal package. This provides assessment of the project during the planning stage, the data collection stage, the emissions calculations stage, a nd the report preparation stage. An example audit checklist for point sources is presented in Figure 2.
3.3 Results of Periodic Data Quality Assessments Audit reports will be distributed within two weeks of the conduc t of each audit to the persons interviewed and the MACTEC Task Leaders. A su mmary of the types of quality concerns found will be periodically forwarded to the MACTEC Program Manager to keep him informed of the quality issues found and actions being taken to re solve them. Audit reports will be retained in a file and used to conduct subseque nt audits and plan follow-up activities. When an audit team finds items that require immediate action, they will inform the MACTEC Program Manager of the necessary corrective actions.Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 3 Revision No. 1.11 Revision Date: 7/29/09 Page 2 of 3

AUDIT CHECKLIST

Auditor:

______________________________________ Date:

_________________________________________ Data/Procedure Reviewed:

_____________________________________________________________

___________________________________________________________________________________ Project Personnel Involved in Work:

_____________________________________________________

____________________________________________________________________________________ Instructions: Select a facility or source category with high emissions and evaluate the quality of the data and adequacy of the data handling procedures. R ecord the findings and recommendations for corrective actions, if any, on this checklist and comment sheet. If recommendations for corrective actions are made, discuss them with the Project Manager immediately following the audit. Conduct follow-up activities to determine if the actions taken in response to th e recommendations appropriately resolved the quality issues identified.

I. DATA

A. Identify the source category evaluated: _____________________________________________ B. Describe the data included in the master file for the facility or source category.

_____________________________________________________________________________

_____________________________________________________________________________ C. Are the data documented in a manner that will not have the potential to be misinterpreted? Y/N Were the instructions for docu menting the data followed? ................................................. Y/N D. Are there missing data fields? ........................................................................................... ......... Y/N What procedures are taken by the Task Leaders to ascertain missing?

___________________________________________________________________________

___________________________________________________________________________ At what point in th e inventory process are requests for missing data made?

___________________________________________________________________________

___________________________________________________________________________ How is the receipt of the missing data handled?

___________________________________________________________________________

___________________________________________________________________________ Is the procedure followed to ascertain mi ssing data efficient and adequate? ............................ Y/N E. How do emissions compare to other inventories? 2005 NEI ________________________________________________________ 2005 TRI _____________________________________________________________________ 2005 ETS/CEM ___________

__________________ ____________________ _______________ Are differences in emissions understa ndable and explainable? ................................................. Y/N If any of the values are incorrect, explain how the emissions data were corrected.

___________________________________________________________________________ Figure 2 Audit Check FormProject: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 3 Revision No. 1.11 Revision Date: 7/29/09 Page 3 of 3

II. EMISSIONS DATABASE

A. Who provided the data for incorporatio n into the database?

______________ ____________

_______________________________________________________________________ B. Was there evidence that the data were re viewed for accuracy and completeness prior to incorporation in the database? ........................................................................................... .... Y/N C. Were data logs maintained to descr ibe how the data was incorporated? ................................... Y/N D. Ask the data incorporation personnel to e xplain the QC procedures followed to ensure data quality. Do they agree with the procedures described in the QAPP? ................................. Y/N E. Does the computer system appear to be adequate for its intended use? (Ask the data processing personnel about the problems they have experienced with the system.) .......... Y/N F. Is the data entry progressing as expected and are the procedures followed adequate to ensure data quality? ..................................................................................................... .......... Y/N

III. RECOMMENDATIONS FOR CORRECTIVE ACTIONS

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________

IV. COMMENTS

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________

V. SIGNATURES

______________________________ ____________________________ (QA Auditor) (QA Coordinator)

______________________________ ____________________________ (Program Manager) (Task Manager)

______________________________ ____________________________ (Project Participant) (Project Participant)

Figure 2 Audit Check Form (Concluded)Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 4 Revision No. 1.11 Revision Date: 7/29/09 Page 1 of 1

4.0 DATA REVIEW AN D VALIDATION Section 4 addresses the QA activitie s that occur after the data coll ection phase of the project is completed. Implementation of these subsections de termines whether or not the data conform to the specified criteria, thus satisfying the project objectives.
4.1 Data Review, Validation, and Verification A qualitative discussion of accuracy will include an assessment of the extent to which the initially identified weaknesses in the inventory ha ve been remedied through the use of improved activity data, emission factors, or other source s of information. Remaining weaknesses will be assessed.

The accuracy assessment will include a summary of whether any data identified as outside of its valid range remained outside of the valid range in the final inventory. If any data remained outside of its valid range, an explanation will be given. The qualitative discussion will also include a summary of errors or discrepa ncies identified in the QA/QC process.

A final semi-quantitative discussion of accuracy will consist of pollutant summaries for individual facilities, industry types, source categories, and statewide totals. The SESARM inventory will be compared to other peer-revie wed inventories, and wh ere major discrepancies exist, we will provide an assessment of the r easons for the differences in emission estimates.

4.2 Validation Methods and Verification Methods A statement will be prepared assessing whethe r all required facilities, source categories, pollutants, and data elements were included in the invent ory. If any facilities or source categories were not included, an explanation of the omission will be provided. If any individual data elements were not provided, we will discuss th e elements, frequency of omissions, and overall impact on the quality of the inventory.
4.3 Reconciliation with User Requirements Several summations of emissions data will be made to address comparability. Overall percentage differences for individual facilities (current year to prior year), industry types, processes, and statewide inventory will be calcu lated. Explanations of any larg e differences will be made.
4.4 Representativeness Assessment A statement will be prepared describing where national defaults have been used instead of local activity data.Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Section: 5 Revision No. 1.11 Revision Date: 7/29/09 Page 1 of 1

5.0 REFERENCES

1. U.S. Environmental Protection Agency. March 2001. EPA Requirements for Quality Assurance Project Plans (EPA/240/B-01/003). http://www.epa.gov/quality/qs-docs/r5- final.pdf

2. Emission Inventory Improvement Program (EIIP ) Document Series - Volume VI Quality Assurance Procedures and DARS Software. EPA | TTN CHIEF | EIIP | Technical Reports | Volume VI Quality Assurance Procedures

3. U.S. Environmental Protection Agency. November 18, 2002. 2002 Base Year Emission Inventory SIP Planni ng: 8-hr Ozone, PM 2.5 and Regional Haze Programs. http://www.4cleanair.org/memb ers/committee/criteria/EPA200211181.pdfProject: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Appendix A Revision No. 1.11 Revision Date: 7/29/09 Page 1 of 6

Appendix A – Memorandum of UnderstandingProject: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Appendix A Revision No. 1.11 Revision Date: 7/29/09 Page 2 of 6

MEMORANDUM OF UNDERSTANDING VISIBILITY IM PROVEMENT - STATE AND TRIBAL ASSOCIATION OF THE SOUTHEAST (VISTAS)

WHEREAS, The national goal of the visibility program, as se t forth by Congress, is to remedy any existing impairment and prevent any future impairment in mandatory Class I Federal areas that are caused by human activity;

WHEREAS, The visibility program highlights the need to implement other regional planning processes to improve air quality in the geographic area located within the States of Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee, Virginia, and West Virginia;

WHEREAS, These States and Tribes, who have the author ity and responsibility to develop, adopt, and implement their individual State and Tribal air quality implementation plans, recognize the benefits of coordination on many of the projects relating to air quality that are underway in the region;

WHEREAS, The Southeastern States Air Resource Managers (SESARM) has been designated by the United States Environmental Protection Agency (EPA) as the entity responsible for coordinating and implementing regional planning for the eight SESARM states (Alabama, Florida, Kentucky, Georgia, Mississippi, North Carolina, South Carolina and Tennessee) plus Virgin ia, West Virginia, and Tribes.

NOW, THEREFORE, it is hereby agreed to by the signatories as follows:

1. The parties agree to collaborate in the initiation and coordination of planning activities associated with the management of regional haze, visibility, and other air quality issues. This collaboration shall be known as Visibility Improvement - State and Tribal Association of the Southeast (VISTAS).

2. The purposes of VISTAS are as follows:

To promote the coordinated efforts of St ates and Tribes in their efforts to a ddress federal regional haze and visibility requirements.
To identify regional or common air management issues.

To conduct research and undertake other activities to provide the membership with scientific and technological information which may be of value in development of agency strategies.
To develop strategies on regional haze and other air quali ty issues for use by member States and Tribes, where appropriate, in developing their implementation programs, regulations and laws.

4. VISTAS shall operate as described more fully in the attached Bylaws, which are hereby adopted by the parties to this Memorandum of Understanding (MOU).

5. SESARM shall continue to operate as the entity respons ible for applying for, receiving, and disbursing funds necessary for coordinating and implementing regional planning for the eight SESARM states plus Virginia, West Virginia, and Tribes.

6. VISTAS shall not apply for, receive, or disburse any f unds. In the Bylaws, “VISTAS funds”, “expenses of VISTAS”, and other such references shall mean SE SARM funds used for VISTAS purposes.

7. VISTAS has no independent regulatory authority and has no aut hority to direct or establish individual State or Tribal law or policy. Participants retain their own rights and legal authorities.

8. This MOU is not a binding agreement. It is a voluntary collaboration of the parties to aid in planning activities associated with the management of regional haze, visibility, and other air quality issues.Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Appendix A Revision No. 1.11 Revision Date: 7/29/09 Page 3 of 6

The Parties hereto have executed this MOU.

Agreed to this______ day of ______________, 2001:

For the Southeastern States Air Resource Managers (SESARM):

Executive DirectorProject: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Appendix A Revision No. 1.11 Revision Date: 7/29/09 Page 4 of 6

The Parties hereto have executed this MOU

Agreed to this______ day of ______________, 2001:

For The State of Virginia:

TitleProject: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Appendix A Revision No. 1.11 Revision Date: 7/29/09 Page 5 of 6

The Parties hereto have executed this MOU

Agreed to this______ day of ______________, 2001:

For the State of West Virginia:

TitleProject: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories Appendix A Revision No. 1.11 Revision Date: 7/29/09 Page 6 of 6

The Parties hereto have executed this MOU

Agreed to this______ day of ______________, 2001:

For the Eastern Band of Cherokee Indians:

Title