Technical Support Document (TSD) for the Redesignation Request and Maintenance Plan Forthe PennsylvaniaPortion ofthe Philadelphia-Wilmington, PA-NJ-DE 2006 PM2 

### sNonattainment Area

Submitted by PennsylvaniaDepartment ofEnvironmental Protection
TSD Prepared December 2014 by Jessica L. Fry Office ofAirMonitoring and Analysis, 3AP40 U.S. Environmental Protection Agency, Region 3 1650 Arch Street Philadelphia, Pennsylvania 19103

Reviewed by Alice

. Chow, Associate Director Office ofAir Monitoring and Analysis (3AP40)

### I. Introduction
The purpose ofthis document is to provide a technical summary ofthe Office ofAir Monitoring and Analysis (OAMA) review ofthe emissions inventories submitted with the Redesignation Request and Maintenance Plan for the Pennsylvania portion ofthe Philadelphia-Wilmington, PA-NJ-DE 2006 

### PM2.s Nonattainment Area (NAA) by the Pennsylvania Department of Environmental Protection (PADEP). The Pennsylvaniaportion ofthe NAA consists ofBucks, Chester, Delaware, Montgomery, and Philadelphiacounties. This review does not determine the approvability ofthe redesignation request or maintenance plan. Emissions inventories in a redesignationrequest are used to showpermanent and enforceable emission reductions between the year the area was designated as a nonattainment area and the year the area came into attainment. In a maintenance plan, the emissions inventories are used to reflect the emissions during the time the area came into attainment and are then projected to show that the area will remain in attainment. Any questions pertaining to this technical summary should be directed to Alice H. Chow, Associate Director, Office ofAir Monitoring and Analysis, at**215-814~2144** or viaemail at chow.alice@epa.gov.


### II. Emissions Inventories for Redesignation Request
2002Base YearInventory

In aredesignation request, emissions inventories are used to supportthe States claim that the areahas permanent and enforceable emissions reductions. In orderto do this, the state should estimate the percentreduction achieved from federal and state control measures (typically from the year that was used to determine the design value for designation and classification); this is usually termed as the nonattainment year inventory. The 2002 nonattainment year inventory contains primary 

### PM2

.semissions (including condensibles), S02,NOx,NH3, and VOC. PADEP submittedtheir 2002 Base Year Inventory to EPA as a State Implementation Plan (SIP) revision. The inventory was approved by EPA and the rule became effective August 28, 2012 (77 FR 51930). Documentation for this inventory can be found in the Federal Registrar Notice.


### III. Emissions Inventories for Maintenance Plan
2007Attainment YearInventory andMaintenancePlan Base YearInventory
Under section 172(c)(3) states are required to submit a comprehensive, accurate, current accounting ofactual emissions from all sources (point, nonpoint, nomoad, and omoad) inthe nonattainment area. This inventory contains primary PM2.s emissions (including condensibles), S02,NOx, VOC, and NHJ. In a Maintenance Plan, states are required to submit an inventory used for the year ofattainment, which is called the attainment year inventory and can also be referred to as the maintenance planbase year inventory. This inventory is used as the basis for the projected inventories that are used to showthe area will remain in attainment. The attainment year inventory contains primary**P~v'12 s**  emissions (including condensibles), 

### S02,**!'-~Ox, l'-~H3,**  and VOC. PADEP is using emissions from 2007 as a surrogate attainment year inventory. Acomparison ofthe 2007 and 2008 emissions was submitted to showthat this is a conservative approach. This section will discuss the 2007 attainment year inventory that was used in the Pennsylvaniaportion ofthe Philadelphia-Wilmington, PA-NJ-DE Redesignation Request and Maintenance Plan submittedby PADEP in orderto fulfill the 172(c)(3) and attainment year emissions inventory requirements.

Forthe 2007 attainment year inventory for point, nonpoint, and nonroad categories, PADEP submitted the 2007 Version 3 Emissions Inventory developed through the Mid-Atlantic Regional AirManagement Association (MARAMA) regional planning process. A comprehensive county level inventory for the Philadelphianonattainment area (NAA) was developed by PADEP in coordinationwith MARAMA, NewJersey Department of Environmental Protection (NJDEP), and Delaware Department ofNatural Resources and Environmental Control (DNREC). Documentation ofthe development ofthe inventory can be found in Technical SupportDocument for the Development of the 2007Emission Inventoryfor the RegionalAir QualityModeling in the NortheastIMid-Atlantic Region Version 3. 3. January 23, 2012.
The 2007 point source inventory contained emissions for electric generating units (EGUs) and Non-EGU sources in Bucks, Chester, Delaware, Montgomery, and Philadelphia counties. EPA guidance for emissions inventory developmentprovides that actual emissions should be used for purposes ofthe base year inventory. The point source inventory submitted
was developedby MARAMA in consultation with PADEP using information compiled from 2007 Annual Emissions Reports submitted to Pennsylvania from facilities in the state. In order to account for missing condensable PM emissions from EGUs the data was augmented using emissionfactors developed for MARAMA.
The nonpoint source emissions inventory for 2007 was developed using 2007 specific activity data along with EPA emission factors and the most recently available emission calculationmethodologies.

For 2007 nonroad mobile sources, PADEP generated the emissions using EPA's NMIM2008 model. Since marine, air and rail/locomotive (MAR) emissions are not part ofthe NONROAD model, they were calculated separately outside ofthe NONROAD model. Aircraft emissions were developed using EPA's database to the supportthe 2008 NEI. PADEP used railroad emissions developed by the Eastern Regional Technical Advisory Committee (ERTAC).
The 2007 onroad mobile source inventory was developed using EPA's highway mobile
source emissions model MOVES2010a. PADEP used local activity to replace default inputs in the model where appropriate.

OAMA staffreviewed the files and the emission results provided by PADEP and found themto be acceptable.

### III. Projection Emissions Inventories for Maintenance Plan
2017and2025Projection EmissionInventories Projection inventories are used to showthat the area will remain in attainment. PADEP used 2017 and 2025 emission projections developed through the MARAMA regional planning process for the interim and maintenance plan end year, respectively. Emission projections, emissionmethodologies and growth factors for 2017 and 2025 can be found in the Technical SupportDocument for the Development of the 20131201712020EmissionInventoriesfor RegionalAir QualityModeling in the Northeast /

Mid-Atlantic Region (MARAMA 2017 TSD) and the Technical Support Document for the Development of the 2025 Emission Inventory for P

M2.s Nonattainment Counties in the MANE- VURegion, January 2012 (MARAMA 2025 TSD), respectively.

ForEGU emissions, PADEP used growth factors based on the Annual Energy Outlook (AE02011) and applied them to the 2007 inventory. Non-EGU emissions projections were based on Version 3.3 ofthe 2007 MANE-VU+VA inventory. MARAMA growth factors were developed using AEO fuel consumption forecasts, state-level employment projections, and other state-specific emission projection data. Nonpoint source emissions for 2017 and 2025 were developed similarly to the non-EGU point sources. Emissionprojections were based on Version 3.3 ofthe 2007 MANE-VU+VA inventory. MARAMA growth factors were developed using AEO fuel consumption forecasts, state-level employment projections, and other state-specific emission projection data

. Nonroad source emissions for 2017 and 2025 were developed using NMIM model runs which contain default assumptions for projected years. Aircraft emissions were projected by applying activity growth data reported in the Federal Aviation Administration's (FAA's) Terminal AreaForecast (TAF) system for 2009-2030 (FAA2010). Railroad emissions were based onthe MARAMA MANE-VU+Va inventory.
The 2017 and 2025 onroad mobile source inventory was developed using EPA's highway mobile source emissions model MOVES2010

. PADEP used local activity to replace default inputs inthe model where appropriate
OAMA staffreviewed the methodologies provided by PADEP and found them to be acceptable.