1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street Philadelphia, Pennsylvania 19103

January 28, 2014

SUB JECT : Technical Support Document (TSD)

- Adequacy Findings for the Motor Vehicle

Emissions Budgets in the Maintenance Plan f or the West Virginia Portion of the Martinsburg

- Hagerstown WV

- MD 1997 Fine Particulate (PM 2.5 ) Nation al Ambient Air Quality Standar d (NAAQS) Nonattainment Area

FROM: /s/

Asrah Khadr, Environmental Engineer, E ngineer in T raining (EIT) Office of Air Program Planning (3AP30)

TO: Administrative Record for the Adequacy Findings for the Motor Vehicle

Emissions Budgets in the Maintenance Plan for the West Vir g i nia Portion of the Martinsburg

- Hagerstown WV

- MD 1997 PM 2.5 NAAQS Nonattainment Area

/ s /

THRU: Cristina Fe rnandez, Associate Director

Office of Air Program Planning (3AP30)

I. Background

On January 5, 2005, Berkeley County was designated as nonattainment for the 1997 PM 2.5 NAAQS as the West Virginia portion of the Martinsburg

- Hagerstown 1 997 PM 2.5 NAAQS

Nonattainment Area . On November 20 , 2009 (74 FR 60199)

, it was determined that the Martinsburg

- Hagerstown WV

- MD 1997 PM 2.5 NAAQS Nonattainment Area had air quality data showing the 1997 PM 2.5 NAAQS was attained. Additional background information about the West Virginia portion of the Martinsburg

- Hagerstown WV

- MD 1997 PM 2.5 NAAQ S

N onattainment A rea is available in the notice of proposed rulemaking (NPR) in this docket. On August 5, 201 3 , the West Virginia Department of Environmental Protection (WVDEP) formally

submitted a State Implementation Plan (SIP) revision to sati sfy the r edesignation requirements of

the Cle an Air Act (CAA) for the 1997 PM 2.5 NAAQS for the West Virginia Portion of the Martinsburg

- Hagerstown WV

- MD 1997 PM 2.5 NAAQS Nonattainment Area

.

I I

. Transportation Conformity Requirements

Under section 176(c) of the CAA, new transportation plans, programs, and projects, such as the construction of new highways, must “conform” to (i.e., be consistent with) the part of the state’s air quality plan that addresses pollution from cars and trucks. The CAA requires fede ral actions in nonattainment and maintenance areas to “conform to” the goals of the SIP. This means that such actions will not cause or contribute to violations of NAAQS; worsen the severity of an existing violation; or delay timely attainment of any NAAQ S or any interim milestone.2

For motor vehicle emissions budgets (MVEBs) to be approvable, they must meet, at a minimum, EPA’s adequacy criteria found at 40 CFR 93.118(e)(4). EPA’s adequacy criteria are: (1) the

submitted control strategy implementati on plan was endorsed by the Governor or designee and was subject to a State public hearing; (2) con sultation among F ederal, State, and local agencies occurred; full implementation plan documentation was provided to EPA; and EPA's stated concerns, if any, w ere addressed before the control strategy implementation plan was su bmitted ; (3) the MVEBs are clearly identified and precisely quantified; (4) the MVEBs, when considered together wit h all other emissions sources, are consistent with applicable requirement s for maintenance; (5) the MVEBs are consistent with and clearly related to the emissions inventory and

the control measures in the submitted control strategy implementation plan; and (6) revisions to previously submitted maintenance plans explain and docu ment any changes to previously submitted budgets and control measures; impacts on point and area source emissions; any changes to established safety margins; and reasons for the changes (including the basis for any changes

related to emission factors or es tim ates of vehicle miles traveled).

III. Review of the Submitted Modeling Utilizing the Motor Vehicle Emission Simulator (MOVES2010)

To run the MOVES2010 model, a run specification (hereafter referred to as “RunSpec ”) must be created so the appropriate parameters are selected for the modeling run. The RunSpecs were reviewed against the following EPA document: Technical Guidance on the use of MOVES2010 for Emission Inventory Preparation in State Implementation Plans and Transportation Conformity. This guidance document provides guidance on the use of the MOVES model to develop inventories for SIPs as well as analysis of emissions for transportation conformity determinations.

WVDEP submitted MVEBs for the y ears 2017 and 2025 for the 1997 PM 2.5 NAAQS. The RunSpecs, input files and output files were reviewed and found to have followed the applicable EPA guidance provided in the Technical Guidance on the use of MOVES2010 for Emission Inventory Preparation in State Impl ementation Plans and Transportation Conformity . Table 1
present s the RunSpec parameters that were reviewed and each paramet er ’s respective component

in WVDEP ’s submittal.

Table 1. RunSpec Reviews for the 1997 PM 2.5 NAAQS for Years 2017 and 2025

Domain/Scale County scale was selected. This is acceptable for this air quality analysis. Calculation Type Inventory was selected which is acceptable for this analysis. Time Aggregation Level Hour ly time aggregation was selected. Selection of hourly time aggregation level is acceptable for this analysis

. Calendar Year Of

Evaluation The appropriate calendar year was selected. MOVES2010b can

m odel years 1990 and 1999

- 2050.

Month of Evaluation All 12 months were sel ected for evaluation. Type of Day of

Evaluation W eekdays and weekends were selected.3

Hours of Evaluation S tarting and ending hours create a whole day (from 0

- 24 hours)

. Geographic Bounds Berkeley County was selected.
Vehicles/Equipment: On

Road Vehicle Equipment A ppropriate combinations of fuels and source use types were made

.

Road Type Selection i ncluded all necessary road types

. Pollutants and Processes Nitrogen oxides (NO
x ), sulfur dioxide (SO 2 ), ammonia (NH 3 )

, volatile organic compounds (VOCs) total gaseous hydrocarbons,

non

- methane hydrocarbons and all forms of primary PM 2.5 were selected, which is acceptable for this analysis.

On

- Road Retrofits N/A

ROP N/A Output Database/Unit

Selection Mass units selected to be gram s; energy units selected to be m illion British Thermal Units (BTU); distance units selected to be miles

. Output Emission Detail in

Emission Rate

Calculations Emission detail was selected via user preference.

Advanced Performance

Feat ures N/A

I V

. Administrative Requirements for Making Adequacy Findings

EPA followed the process for determining the adequacy of the submitted SIP MVEBs in

accordance with the procedures listed in the January 2008 Conformity Regulations contained in 40 CFR part 93, 118(f) “ Adequacy review process for implementation plan submissions .” EPA will be issuing an NPR for a 30

- day public comment period soliciting public comment for the approvability of West Virginia ’s SIP submission. The NPR also proposes approval of the MVEBs for milestone year 2017 and the out

- year 2025 for Berkeley County for PM 2.5 and NO
x . The MVEBs are presented below in Table 2. On December 20 , 2013, a notice w as posted on EPA’s

website at http://www.epa.gov/otaq/stateresources/transconf/currsips.htm for the purpose of opening EPA’s 30

- day public comment period on the adequacy/approvability of the budgets in the SIP revision. The notice informed the public of t he availability of the West Virginia SIP revision

on its own webs ite. EPA’s website notice provide s a link where interested members of the public could access the SIP revision. Following EPA’s public comment period, responses to any

comments received on the proposed mobile budgets will be addressed in an amendment to this

TSD.

Table 2. MVEBs Co ntained in the Maintenance Plan for the 1997 PM 2.5 NAAQS

Year Motor Vehicle Emissions Budget for Direct PM

- Tons

Per Year Mobile Vehicle Emissions Budget for NO
x - Tons Per

Year

2017 83 2,621

2025 50 1,6604

V

. Evaluation of t he Adequacy of the MVEBs in the Maintenance Plan for the 1997 PM 2.5 NAAQS

In this TSD, we are evaluating the MVEBs associated with the maintenance plan contained in the August 5, 2013 SIP revision , for conformity purposes. We are using the e valuation criteria detailed in the Transportation Conformity Rule, 40 CFR part 93.102(b)(2)(v), 93.102(b)(2)(v), 93.102(b)(3), and part 93, 93.118(e) 4 through 93.118(e)5. The evaluation is presented in Table

3 , below.

Table 3

. Adequacy of the MVEBs Co ntained in the Maintenance Plan for the 1997 PM 2.5 NAAQS

Transportation Conformity

Rule 40 CFR Part 93, 93.118 Review Criteria Was the Criterion Satisfied?

If Yes How was this Criteria

Satisfied?

93.102(b)(2)(iv) Have EPA and the State made a finding that NO
x is an insignificant contributor

to the direct mobile PM

emissions? Neither EPA nor the State

ha s made such a finding.

93.102(b)(2)(v) Has EPA or State made a finding that VOCs, Sulf

u r Oxides (SO
x ) or Ammonia (NH 3 ) as precursors to be a significant contributor to the

mobile PM 2.5 emissions? Neither EPA nor the State

has made such a finding.

93.102(b)(3) Has the EPA or the State

made a finding that re

entrained road dust is a significant contributor to the

PM mobile emissions? Neither EPA nor the State

has made such a finding.

Sec. 93.118(e)(4)(i) Was the submitted revised plan endorsed by the Governor (or his or her designee) and subject to a State public hearing? Yes, t he su bmitted maintenance plan was endorsed and submitted as a SIP revision by the Governor’s designee, the Secretary of WVDEP

, and a

notice of public hearing was published in the West Virginia Register, the5 Char leston Gazette and the Martinsburg Journal on June 14, 2013. Sec. 93.118(e)(4)(ii) Before the attainment

demonstration was submitted to EPA, did consultation between federal, State and local agencies occur; was full implementation plan documentation prov ided to EPA, and was EPA ’ s stated concerns, if any, addressed? Yes. Consultation has occurred among all required federal, state and local agencies.

Sec. 93.118(e)(4)(iii) Was the motor vehicle emissions budget(s) clearly identified and precisely quantified? Yes, the budgets are clearly identified on page s 41

- 42 in the maintenance plan.

Sec. 93.118(e)(4)(iv) Is the motor vehicle emissions budget(s), when considered together with all other emission reductions, consistent with applicable requiremen ts for attainment

demonstrations? EPA believes the budgets can be declared adequate because in conjunction with the other emission reductions, they

demonstrate attainment for years 2017 and 2025.

Sec. 93.118(e)(4)(v) Is the motor vehicle

emissions budget(s) consistent with and clearly

related to the emissions inventory and the control

measures in the Plan? EPA believes that the budgets are clearly related to the emissions inventory and the

control measures in the SIP

submittal.

Sec. 93.118(e)(4)(vi) Revisions to previously

submitted attainment demonstrations: explain and document any changes to previously submitted budgets and control measures; impacts on point and area source emissions; any changes to established safety margins (see Sec. 93.101 for definition); and reasons for the changes (including the Yes, the maintenance plan provides new MVEBs for years 2017 and 2025. The

addition of safety margins to

the MVEBs is consistent with

continued attainment.6 basis for any changes related

to emission factors or

estimates of vehicle miles traveled).

Sec. 93.118(e)(5) Did they provide and we review public comments and

the State ’ s responses to those

comments with the submitted control strategy SIP? Yes

VI. Findings

Based upon our review and evaluation of the MVEBs contained in WVDEP’s August 5, 201 3

submittal of the maintenance plan to satisfy the requirements of the 1997 PM 2.5 NAAQS , we find

the MVEBs to be a dequate for conformity purposes and recommend that the MVEBs be SIP approved.

c