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

of the 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 ft‘ Reviewed
by Walter Wilkie, Chief Air Quality Analysis Branch (3AP22) 7//9 /O Date SignedI. Introduction The purpose of this document

is to provide

a technical summary
of the Air Quality Analysis Branch’s (AQAB) review of the emissions inventories submitted with the Baltimore Nonattainment Area

8 Hour Ozone State Implementation Plan (SIP) by the Maryland Department

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
of regulated 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

of the 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. 1 The 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 of source identification. The state’s primary data source
is from its permitting program, which includes permit applications “Emissions Inventoty Guidance for Implementation

of Ozone and Particulate Matter National Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations” EPA-454/R-05-001, August 2005and equipment registrations. ARMAalsorelies onitsthe compliance program,which involves using information gathered from inspections andcitizen complaints. ARMA provided
its2002 actual typical summer (during peakozoneseason—June, July, August) weekday emissions forNOxandVOCatthe facility levelandatthe process-level. Forthe2002 Nonpoint Source emissions, also known
as“area sources,” ARMA provided
aninventory that contained estimations
of emissions by multiplying

anemission factor bysomeknown indicator
oractivity levelforeach category

atthe countylevel. These emissions aretypically calculated
onanannual basis because the activity dataare generally only available
onanannual basis. ARMAfurther converted these annual emissions

toseasonal emissions, for ozone,the summerseason
is defined
aspeak ozone seasonmonthsof June, July,and August. Various sourcesof emission factorsor methodologies wereused, including EPA’s AP-42, EPA’s Emissions Inventory Improvement Program,andEPAmobile sourcemodel. Nonpoint sourceestimates were provided bySCC. TheNonroad Mobile Source 2002 inventory was prepared with EPA’s NONROAD2005 model, version
asof 03/21/2006, andEPA emission factors. NONROAD estimates fuel consumption and emissions
oftotal hydrocarbons, carbon monoxide, nitrogen oxides,sulfur dioxide, and particulate matterforall nonroad mobile source categories exceptfor aircraft, locomotives, and commercial marine vessels. ARMA provided emission estimates for locomotive engines, aircraft emissions and commercial marine vessels separately. For locomotive engine andlinehaul emissions, ARMA requested and received fuel usageandtrack mileage datafrom all13 railroads operating

inthe Baltimore NAA. Paired withEPA emission and conversion factors, ARMA calculated locomotive emissions forthebase year.Foraircraft emissions, ARMAused several sourcesof information: Federal Aviation Administration’s (FAA) Airport Activity Statisticsof Certificated RouteAir Carriers; landing and takeoff cycle information
by airportin Maryland; Aviation Administration
andthe Federal Aviation Administration Airport License Renewal Applications;
and FAA’s Emissions

& Dispersion Modeling System (EDMS). For commercial marine vessels, ARMAusedthe emission inventory prepared forthe Maryland Port Administration

by Edwards and Kelcey (E&K). E&K analyzed the major categories
ofair emissions associated with ship and port operations andtheir relationship

toair quality issuesinthe Baltimore NAA. E&Kalsoused EPA’s guidance, Analysisof Commercial Marine Vessels Emissions and Fuel Consumption Data, (EPA-450-R-00-002), February 2000,tocalculate emissions. All Nonroad mobile sourceemissions wereprovided bySCC. The Onroad Mobile Source 2002 emissions inventory was developed usingthe mostcurrentversion ofEPA’s highway mobile sourceemissions model MOBILE 6.2and traffic activitydata fromthe Maryland State Highway Administration. ARMA alsoused PPSUITE,
anenhanced versionofthePost ProcessorforAir Quality software systems. ARMA provided Mobile6.2 input and outputfilesfor review. Mobile emissions values weregiveninunitsoftons persummerdayandwere provided by SCC. ARMAalso applied rule effectiveness andrule penetration
forits 2002 8-hour ozoneSIPbase yearinventories. Rule effectiveness reflectstheactual ability ofa regulatory program

toachieve the emission reductions required by regulation (or perhaps voluntarily adopted). ARMA applied rule effectiveness and where applicable, provided

ajustification

of a higher percentage than EPA’s previous policy (which assumed
an 80% rule effectiveness
for applicable sources unless otherwise specified). Rule penetration

is an estimate of percentage
of emissions

in a source category that are emitted
at facilities subject
to the requirements

of a rule. ARMA applied rule penetration
for its nonpoint sources where applicable. AQAB staff reviewed the results, procedures, and methodologies

for the SIP base year, and found them to be approvable. 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.