Technical Support Document (TSD) For

the Baltimore Nonattainment Area:

8 Hour Ozone State Implementation Plan (SIP) Attainment Demonstration

and Base Year Inventory.

Submitted June 15, 2007 by the

Maryland Department ofthe Environment

TSD Prepared December, 2008

Alice H. Chow

Air Quality Analysis Branch, 3AP22

U.S. Environmental Protection Agency, Region 3

1650 Arch Street

Philadelphia, Pennsylvania 19103

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Reviewed

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by Walter Wilkie, Chief

Air Quality Analysis Branch (3AP22)

7//9

Date Signed

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tment of the Environment (MDE). This review determines the

approvability of the SIP Base Year Inventory and an evaluation of the methods used for

projection year inventories.

A SIP Base Year Inventory is the starting point from which other SIP inventories are derived as well as serving as the benchmark for other SIP

planning activities, such as the establishment of an emissions reduction credit program. Projection year inventories are essentially used to track progress; the purpose of which is

to demonstrate a reduction in emissions ofregulated sources from the Base Year to a

projected year. The Baltimore Nonattainment Area was designated as an 8 hour ozone nonattainment area with a Subpart

2 classification. Subpart 2 area(s) are required to submit initial SIP base year inventories to EPA by June 15, 2006; with the final Base

Year inventory due with the SIP to EPA by June 15, 2007. Maryland Department ofthe Environment has submitted Baltimore Nonattainment Area 8 Hour Ozone SIP and has

requested EPA’s approval.

Any questions pertaining to this technical summary should be directed to Walter

K. Wilkie, Chief, Air Quality Analysis Branch, at 215-814-2150 or via email at

wilkie.walter(epa.gov.

II 2002 SIP Base Year Inventory

The SIP base year inventory is the primary inventory from which other

inventories (3-year cycle inventories, reasonable further progress inventories, modeling inventories) are derived. The Clean Air Act calls for State, local, and Tribal agencies to

ensure that the base year inventory is comprehensive, accurate, and current for all actual

emissions. 1The base year inventory includes emissions estimates from stationary point and nonpoirit sources, onroad mobile sources, and nonroad mobile sources. For the 8-

hour ozone NAAQS, the pollutants to be inventoried are VOC, NOx and CO (carbon monoxide). For the 8-hour ozone NAAQS, VOC, NOx and CO emissions should be

reported as actual annual and actual summer weekday emissions (defined as an average day’s emissions for a typical summer day during the ozone season). MDE’s base year inventory is for 2002. For the Baltimore SIP, the geographic coverage includes sources in Anne Arundel County, Baltimore County, Baltimore City, Carroll County, Harford County, and Howard County.

A significant amount of documentation is required for these SIP base year estimates which MDE has provided.

In the MDE request, the base year used was 2002. MDE’s Air and Radiation

Management Administration (ARMA) is primarily responsible for compiling the Point Source data for 2002. ARMA uses several forms ofsource identification. The state’s

primary data source is from its permitting program, which includes permit applications

“Emissions Inventoty Guidancefor Implementation ofOzone and Particulate Matter National Ambient

Air Quality Standards (NAAQS) and Regional Haze Regulations” EPA-454/R-05-001, August 2005
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activity level for each category at the county level. These emissions are typically calculated on an annual basis because the activity data are generally only available on an annual basis. ARMA further converted these annual

emissions to seasonal emissions, for ozone, the summer season is defined as peak ozone

season months ofJune, July, and August. Various sources of emission factors or

methodologies were used, including EPA’s AP-42, EPA’s Emissions Inventory Improvement Program, and EPA mobile source model. Nonpoint source estimates were provided by SCC.

The Nonroad Mobile Source 2002 inventory was prepared with EPA’s NONROAD2005 model, version as of 03/21/2006, and EPA emission factors.

NONROAD estimates fuel consumption and emissions of total hydrocarbons, carbon monoxide, nitrogen oxides, sulfur dioxide, and particulate matter for all nonroad mobile

source categories except for aircraft, locomotives, and commercial marine vessels.

ARMA provided emission estimates for locomotive engines, aircraft emissions and commercial marine vessels separately. For locomotive engine and line haul emissions, ARMA requested and received fuel usage and track mileage data from all 13 railroads operating in the Baltimore NAA. Paired with EPA emission and conversion factors, ARMA calculated locomotive emissions for the base year. For aircraft emissions, ARMA used several sources of information: Federal Aviation Administration’s (FAA) Airport Activity Statistics of Certificated Route Air Carriers; landing and takeoff cycle information by airport in Maryland; Aviation Administration and the Federal Aviation Administration Airport License Renewal Applications; and FAA’s Emissions

&

Dispersion Modeling System (EDMS). For commercial marine vessels, ARMA used the emission inventory prepared for the Maryland Port Administration by Edwards and Kelcey (E&K). E&K analyzed the major categories of air emissions associated with ship and port operations and their relationship to air quality issues in the Baltimore NAA. E&K also used EPA’s guidance, Analysis of Commercial Marine Vessels Emissions and Fuel Consumption Data, (EPA-450-R-00-002), February 2000, to calculate emissions. All Nonroad mobile source emissions were provided by SCC.

The Onroad Mobile Source 2002 emissions inventory was developed using the most current version of EPA’s highway mobile source emissions model MOBILE 6.2 and traffic activity data from the Maryland State Highway Administration. ARMA also used PPSUITE, an enhanced version of the Post Processor for Air Quality software systems. ARMA provided Mobile6.2 input and output files for review. Mobile emissions values

were given in units oftons per summer day and were provided by SCC.

ARMA also applied rule effectiveness and rule penetration for its 2002 8-hour

ozone SIP base year inventories. Rule effectiveness reflects the actual ability of a regulatory program to achieve the emission reductions required by regulation (or perhaps voluntarily adopted). ARMA applied rule effectiveness and where applicable, provided a
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III. 2008 and 2009 Projection Emission Inventories

Projection inventories are used to show that the area will remain in attainment.

Projection inventories for the years 2008 and 2009 were used for the Baltimore NAA

SIP. The 2008 projected inventory is required for reasonable further progress (RFP) and the 2009 projected inventory is required for the attainment year. Inventories were developed for all emission sources for both years.

The Point Source emissions for 2008 and 2009 were projected, using growth surrogates from EPA’s Economic Growth and Analysis System, Version 5.0 (EGAS 5.0).

The Nonpoint Source emissions for 2008 and 2009 were projected using growth factors to account for population, household and employment data from the Baltimore Metropolitan Council.

For the 2008 and 2009 Nonroad Mobile Source inventories, ARMA used EPA’s

NONROAD2005 model to generate these future inventories. The NONROAD model

allows for the calculation of past year, present year, and future year inventories (up to the

year 2050) to be generated. Growth for locomotives and commercial marine vessels

came from employment data as surrogates; and, aircraft growth was estimated from Maryland Aviation Administration activity data and the Federal Aviation

Administration’s Terminal Area Forecast Detailed Report.

The 2008 and 2009 Onroad Mobile Source inventories were generated using EPA’s MOBILE6.2 and the Highway Performance Monitoring System (HPMS) vehicle miles traveled growth rates. Input data was provided by the Baltimore Regional Transit Board and Baltimore Metropolitan Council. ARMA then ran PPSUITE to calculate

VMT and speeds; the output is then run in MOBILE6.2 to calculate emissions.

AQAB staff reviewed the procedures, and found them to be reasonable for

development of these inventories.