1 EMISSIONS INVENTORY BASE YEAR FOR NO x and VOC FOR THE BATON ROUGE
NONATTAINMENT AREA UNDER THE 2008 EIGHT

- HOUR OZONE NAAQS

This document provides a technical review of a revision to the Louisiana State Implementation Plan (SIP) to meet Clean Air Act (CAA) Base Year Emission Inventory (EI) for the Baton Rouge Nonattainment Area (BRNA) under Clean Air Act section 182(a)(1) and 40 CFR 51.1115 for the 2008 eight

- hour ozone standards submitted by the Louisiana Department of Environmental Quality (LDEQ) on May 2, 2015.

A. General Requirements

Under the CAA sections 172(c)(3) and 182 (a)( 1 ), states are required to submit emissions inventory (EI) information for all relevant sources for areas that are designated nonattainment for any of the National
Ambient Air Quality Standards (NAAQS). On March 27, 2008, the United States Environmental Protection Agency (EPA) lowered the primary and secondary eight

- hour ozone NAAQS to 0.075 parts per million (ppm) ( 73 FR 16436 )

. 1 On May 21, 2012, the EPA published in the Federal Register ( 77 FR 30088 ) final designations for the 2008 Ozone standard

. The BRNA consists of five parishes: Ascension, East Baton Rouge, Iberville, Livingston, and West Baton Rouge and was designated and classified as marginal nonattainment. The effective date of the final rule is July 20, 2012.

The EPA published the final 2008 ozone s tandard SIP requirements rule on March 6, 2015, which specified that states use 2011 as a base year to address EI requirements. ( 80 FR 12264 )

. The nonattainment area base year EI emission is due no later than 24 months from the July 20, 2012 effective date

. Id

. An emissions inventory is an estimation of actual emissions of air pollutants in an area. Volatile organic compounds (VOCs) and oxides of nitrogen ( NO x ) are known as “ozone precursors”, as they react with oxygen and sunlight to form ozone. Motor vehicle exhaust

, industrial emissions, gasoline vapors and
chemical solvents emit NO x and VOCs. Controlling sources of NO x and VOC emissions can lower ozone levels in the ambient air. Thus, the emissions inventory for an ozone nonattainment area contains V OC and
NO x emissions. The EIs provide data for a variety of air quality planning tasks including : establishing
baseline emission levels

, calculating federally required emission reduction targets, emission inputs into air quality simulation models, and trac king emissions over time. The total EI of VOC and NO x for an area are summarized from the estimates developed for four general classes of anthropogenic emissions sources: stationary sources; on

- road mobile sources; and off

- road mobile sources , area, mobile , and biogenic

. 2

B. Background

The majority of NO x emissions in the BRNA come from point sources. Point sources are large, stationary, emissions sources that release pollutants into the atmosphere. These sources could include refineries, chemical plants, bulk terminals, and utilities. Area sources, also called nonpoint sources, are the second largest contributor of NO x emissions, and are the largest contributor for VOC emissions. Area sources

1 We refer to this NAAQS as the 2008 ozone NAAQS or standard.

2 Biogenic emissions are produced by living organisms and are typically not included in the base year emission inventories, but are considered in ozone modeling analyses, which must consider all emissions in a modeled area.2 consist of small

- scale industrial, commercial, and residential sources that use materials or perform processes tha t generate emissions.

Eight

- Hour Ozone Standard in BRNA

In July 1997, the EPA announced a revised NAAQS for ground

- level ozone. (62 FR 38856, July 18, 1997). The EPA phased out and replaced the previous one

- hour standard with an eight

- hour standard set at 0.08 ppm to protect the public health against longer exposure to this air pollutant. Id. The eight

- hour ozone standard became effective on September 16, 1997. Id

. In a final rule signed April 15, 2004, EPA designated the BRNA as nonattainment and classified the area as marginal (69 FR 23858, April 30, 2004). This rule was effective June 15, 2004 and the BRNA was required to reach attainment by June 15, 2007.

The BRNA monitored attainment with the 1997 8

- Hour NAAQS for ozone on December 31, 2008.
Ac cordingly, LDEQ submitted a request for determination of attainment based on EPA’s Clean Data Regulation (40 CFR 51.918). On June 25, 2010, EPA proposed a determination of attainment of the 1997
8

- Hour Ozone standard for the BRNA. (75 FR 36316). A final de termination was published in the Federal Register on September 9, 2010. (75 FR 54778).

At the request of the state, EPA proposed to re

- designate the BRNA to attainment on August 30, 2011. (76 FR 53852). The request was published for final approval on Novem ber 30, 2011. (76 FR 74000).

On July 11, 2007, EPA proposed the second NAAQS revision for ozone. (72 FR 37818). In the final rule published on March 27, 2008, the primary and secondary standards were set at 0.075 ppm. (73 FR 16436). Effective July 20, 2012 , Louisiana was designated nonattainment and classified as marginal when nonattainment designations for the 2008 ozone NAAQS were published in the Federal Register on May 21, 2012. As such, the state was required to meet an attainment date of December 31, 2015. (77 FR 30087). A s of December 31, 2013, and based upon complete, quality assured, certified ambient air monitoring data
that showed the area monitored attainment for the 2008 8

- hour Ozone NAAQS during the 2011

- 2013 monitoring period, the Department s ubmitted a request for determination of attainment based on US EPA’s Clean Data Policy ( www.epa.gov/ttn/oarpg/t1/memoranda/clean15.pdf )

. 3 In concurrence, US EPA proposed and granted final approval on April 15, 2014

. (79 FR 21139, 79 FR 21178). On May 21, 2012, BRNA was designated as a marginal nonattainment area with monitored design values ranging from 0.077 to 0.083 ppm based on ozone mon itoring data from the period of 2006 to 2008. (77 FR 30088). EPA later determined that the area and 16 other marginal nonattainment areas attained the NAAQS by the attainment deadline (81 FR 26697, May 4, 2016).

C . EPA’s Analysis

The EPA reviewed the Lo uisiana’s submittal for consistency with the EPA regulations. The following is a summary of the analysis based on the information provided by Louisiana.

The 2011 Base Year Inventory is the starting point for calculating the reductions necessary to meet the requirements of the CAA. Sections 172 (c)(3) and 182(b)(1) of the CAA require that nonattainment plan provisions include an inventory of actual emissions from all sources of relevant pollutants in the nonattainment area. On August 28, 2015, the LDEQ submi tted the 2011 base year inventory to the EPA as part of the LDEQ’s draft proposal for re

- designation to attainment for the 2008 eight hour Ozone NAAQS

3 At the time EPA had not finalized the Clean Data Regulation for the 2008 ozone NAAQS at 40 CFR 51.1118.3 for the 5

- parish Baton Rouge Nonattainment area. In response to comments received from the EPA, Region 6, the LDEQ submitted a revised proposal to EPA in a letter dated March 18, 2016. The LDEQ’s revised proposal refined the point and nonpoint source growth projections originally presented in the proposal. LDEQ then submitted the final 2011 base year inventor y as part of the BRNA re

- designation request and maintenance plan in a letter dated May 2, 2016.

The EPA reviewed the 2011 base year inventory and determined that it was developed in accordance with EPA guidelines. The inventory includes all area, point, non

- road mobile, and on

- road mobile source emissions in the BRNA. The inventory also includes a de scription of the methods used to estimate
emissions:

Point Source Emissions : Industrial sources are required to submit emissions data to the LDEQ annually and certify that the data reported is accurate to the best of their knowledge. For the purpose of EI , point sources that emit 100 tons or more per year of a criteria pollutant meet the reporting threshold (40 CFR 51 Subpart A). In the BRNA all sources that emit 25 tons of NO x or 10 tons of VOC are required to report. Each of the facilities meeting these emissions criteria submit complete EI reports which contain site

- specific data in conformance with USEPA guidance for ozone maintenance areas. A list of the 230 point sources located in the BRNA as of May 15, 2015, is included in Appendix G of the state su bmittal.

The reporting requirements for the nonattainment areas are in accordance with those of the CAA and LAC
33:III.918 and 919

– Recordkeeping and Annual Reporting and Emissions Inventory. Emissions data provided by the facilities are estimates of ac tual emissions for the facility during the previous calendar year. Actual measurement with continuous emissions monitoring systems (CEMS) or approved stack testing shall be used for reporting of emissions from an emissions point when such data exists. In a bsence of CEMS or stack test data, emissions are calculated using methods found in the most recent editions as of December 31 of the current reporting year, of US EPA’s compilation of Air Pollution Emission Factors (AP

- 42), calculations published in engine ering journals, and/or US EPA or department approved estimation methodologies.

LDEQ submits annual updates to USEPA for point sources and triennial updates for all sources in accordance with 40 CFR Part 51 Subpart A

– Air Emissions Reporting Requirements (AERR).

Non

- Point (Area) Source Emissions : Area sources are represented as many small, individually unidentified points of air pollution emissions within a specified geographical area. These small

- scale industrial, commercial, and residential sources that generate emissions are too numerous or too small to be addressed individually and include but not limited to, activities such as fuel combustion, dry cleaning bakeries, graphic arts, auto refinishing, product storage, agriculture activities, and consumer p roduct usage. Emission factors used to estimated emissions are developed and applied for the aggregate source categories. LDEQ developed the 2011 area source emission inventory in according to the AERR reporting requirements, using
a combination of methodo logies and data: EPA

- generated EIs, LDEQ

- contracted projects, LDEQ staff projects. EPA developed EIs for states for use for many source categories as part of the NEI. For some source categories, the LDEQ developed state

- specific emissions estimates by acqu iring state

- specific activity data and applying appropriate emissions factors. These source categories include, but are not limited to: storage tanks, structural fires, dry cleaners, automobile fires and oil and gas.

We have reviewed these approaches and have determined that they are acceptable.4 Non

- road Emissions Inventory Non

- road mobile sources are often included as nonpoint so urces because of
the number and size of sources. Non

- road mobile sources include, but are not limited to, railroad
locomotiv es, aircraft and airport support equipment, commercial and recreational marine vessels, construction equipment, agricultural equipment, commercial and residential lawn equipment, and
recreational vehicles. We find the approa ch and methodology used by the L DEQ acceptable.

On

- road Emission Inventory On

- road emission sources consist of light and heavy duty, gasoline and diesel automobiles and trucks that travel primarily on public highways. On

- road mobile emissions are pollutants emitted from vehicles during driving operations and while parked. Emissions from the refueling of motor vehicles at service stations, Stage 2 refueling are included under non

- point source emissions. One

- road
mobile emissions estimates within the nonattainment area were developed based on parish

- specific inputs provided by the Department of Tr ansportations and Development a nd the Capitol Region Planning
commission. The EPA reviewed the on

- road emission estimates approach and methodology and determined that they are accept able.

Louisiana emissions for the 2011 were extracted from the US EPA 2011 National Emissions Inventory (NEI), version 2. The Table below summarizes the 2011 NOx and VOC emission totals by source category which comprises the baseline inventory for the BRNA. The 2011 base year emissions data for the BRNA are provided in Table 1 below.

T able 1

- 5

- Parish BRNA 2011Base Year Emissions Inventory

N onpo i n t NO x N on - r o a d O n - r o a d P o i n t Em i s s i o n T o t a l

Ascens i o n 3.1 5.5 5.2 20.9 3 4 .7

East B a t o n Rouge 7.8 8.6 18.6 24.8 5 9

. 9

I b er v i l le 2.9 7.7 2.7 25.6 3 8 .9

Livin g s t o n 1.5 1.0 8.4 0.2 1 1 .0

West Ba t o n Rouge 1.9 4.5 3.5 2.7 1 2 .5

B R NA T o t a l 1 7 .1 2 7 .3 3 8 .4 7 4 .2 1 5 7

. 0

N onpo i n t N on - r o a d VOC O n - r o a d P o i n t Em i s s i o n T o t a l

Ascens i o n 20.7 1.0 2.8 8.5 3 2 .9

East B a t o n Rouge 30.8 3.4 10.2 15.1 5 9 .4

I b er v i l le 18.5 0.9 1.1 7.2 2 7 .7

Livin g s t o n 8.5 2.1 4.1 0.9 1 5 .7

West Ba t o n R o ug e 4.1 1.2 1.0 2.0 8

. 3

B R NA T o t a l 8 2 .6 8

. 7 1 9 .2 3 3 .6 1 4 4

. 05 D. Summary and Recommendations:

Pursuant to Title 40 Code of Federal Regulations Part 51.102 and after proper notice, the LDEQ conducted a public hearing to consider the EI revision to the SIP. Proper notice included prominent advertisement in the areas affected at least 30 days prior to the date of the hearing. The Department has included revisions to the document based on comment and review. Public notice of this revision was published on March 20, 2016, in the Louisiana Register (Vol. 41, No. 6 page 1163). The comment period ended on A pril 29, 2016; no adverse comments were received. A copy of the notice and comments is included in Appendix B.5 of LDEQ’s submittal.

The LDEQ has used acceptable techniques and methodologies to develop the 2011

- base year emission inventories for the 2008 ozone NAAQS for the BRNA to satisfy sections 172 and 182 of the CAA.

Therefore we recommend approval of the Louisiana State Implementation Plan (SIP) revisions to meet the CAA EI reporting requirements for the BRNA under the 2008 ozone NAAQS, submitted by the LDEQ on May 2, 2016.