Technical Support Document (TSD) for the 

Redesignation Request and Maintenance Plan 

For the Lancaster, PA 1997 and 2006 PM2.s Nonattainment Area 

Submitted May 2014 by the 

Pennsylvania Department of Environmental Protection 

TSD Prepared February 2015 by 

Jessica L. Fry 

Office of Air Monitoring and Analysis, 3AP40 

U.S. Environmental Protection Agency, Region 3 

1650 Arch Street 

Philadelphia, Pennsylvania 191 03 

Reviewed by Alice H. Chow, Associate Director 

Office of Air Monitoring and Analysis (3AP40) 
I. Introduction 

The purpose of this document is to provide a technical summary of the Office of Air 

Monitoring and Analysis (OAMA) review of the emissions inventories submitted with the 

Redesignation Request and Maintenance Plan for the Lancaster, P A 1997 and 2006 PM2.s 

Nonattainment Area (NAA) by the Pennsylvania Department of Environmental Protection 

(P ADEP). The NAA consists of Lancaster County in Pennsylvania. This review does not 

determine the approvability of the redesignation request or maintenance plan. Emissions 

inventories in a redesignation request are used to show permanent 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 of Air Monitoring and Analysis, at 215-

814-2144 or via email at chow.alice@epa.gov. 

II. Emissions Inventories for Redesignation Request 

2002 Nonattainment Year Inventory 

In a redesignation request, emissions inventories are used to support the State's claim that 

the area has permanent and enforceable emissions reductions. In order to do this, the state 

should estimate the percent reduction (typically from the year that was used to determine the 

design value for designation and classification) achieved from federal and state control measures; 

this is usually termed as the nonattainment or baseline year inventory. For the purpose of this 

plan the year 2002 was used the nonattainment year inventory. The 2002 nonattainment year 

inventory contains primary PM2.s emissions (including condensibles), S02, NOx, VOC, and NH3 

emissions. This section will discuss the 2002 nonattainment year inventory that was used in the 

Lancaster, PA Redesignation Request and Maintenance Plan submitted by PADEP. 

The 2002 point source inventory contained emissions for electric generating units 

(EGUs) and non-EGU sources in the NAA. PADEP developed their 2002 inventory by using 

emissions directly reported by the facilities. For the 2002 reporting year, many facilities did not 

report condensable PM emissions to PADEP. While missing condensable PM emission 

estimates may have underreported total PM2.5 emissions for the base year, it did not have an 

impact when compared with the 2007 attainment year inventory (which included condensable 

PM) because the 2007 PM2.5 emissions were less than the 2002 estimates. 

The nonpoint source emissions inventory for 2002 was developed using 2002 specific 

activity data along with EPA emission factors and emission calculation methodologies. 

For 2002 nonroad mobile sources, PADEP generated the emissions using EPA's 

NONROAD 2005 model. Since marine, air and rail/locomotive (MAR) emissions are not part of 

the NONROAD model, they were calculated separately outside of the NONROAD model. 

Aircraft emissions were estimated using the Emissions and Dispersion Modeling System 
(EDMS) 4.20. Locomotive emissions were projected from a 1999 emissions survey of fuel use 

statistics from Class II and II railroads. 

The 2002 omoad mobile source inventory was developed using EPA's highway mobile 

source emissions model MOVES2010. PADEP used local activity to replace default inputs in 

the model where appropriate. 

OAMA staff reviewed the files and the emission results provided by P ADEP and found 

them to be acceptable. 

III. Emissions Inventories for Maintenance Plan 

2007 Attainment Year Inventory and Maintenance Plan Base Year Inventory 

Under section 172(c)(3) states are required to submit a comprehensive, accurate, current 

accounting of actual emissions from all sources (point, nonpoint, nomoad, and omoad) in the 

nonattainment area. This inventory contains primary PM2.s emissions (including condensibles ), 

S02, NOx, VOC, and NH3. In a Maintenance Plan, states are required to submit an inventory used · 

for the year of attainment, which is called the attainment year inventory and can also be referred 

to as the maintenance plan base year inventory. This inventory is used as the basis for the 

projected inventories that are used to show the area will remain in attainment. The base year 

inventory submitted by PADEP contains primary PM2.s emissions (including condensibles), S02, 

NOx, VOC, and NH3 emissions. This section will discuss the 2007 emissions inventory that was 

used in the Lancaster Redesignation Request and Maintenance Plan in order to fulfill the 

172(c)(3) and attainment year emissions inventory requirements. 

For the 2007 base year inventory for the point, nonpoint, and nomoad categories, PADEP 

submitted the 2007 Version 3 Emissions Inventory developed through the Mid-Atlantic Regional 

Air Management Association (MARAMA) regional planning process. Documentation of the 

development ofthe inventory can be found in Technical Support Document for the Development 

of the 2007 Emission Inventory for the Regional Air Quality Modeling in the Northeast I MidAtlantic Region Version 3.3. January 23, 2012. 

The 2007 point source inventory contained emissions for EGU and non-EGU sources in 

the NAA. EPA guidance for emissions inventory development provides that actual emissions 

should be used for purposes ofthe base year inventory. PADEP developed their 2007 inventory 

by using emissions directly reported by the facilities. The PM emissions for the 2007 point 

source inventory were augmented using condensable emission factors developed for MARAMA 

in 2008. This was done to fill in any missing condensable PM emissions from facilities. 

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 

calculation methodologies. P ADEP used 2008 NEI data to fill in any missing categories in the 

2007 inventory. · 
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 of the 

NONROAD model, they were calculated separately outside of the NONROAD model. Aircraft 

emissions were developed using EPA's database to the support the 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 MOVES201 0. PADEP used local activity to replace default inputs in 

the model where appropriate. 

OAMA staff reviewed the files and the emission results provided by P ADEP and found 

them to be acceptable. 

2017 and 2025 Projection Emission Inventories 

Projection inventories are used to show that 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, 

emission methodologies and growth factors for 2017 and 2025 can be found in the Technical 

Support Document for the Development of the 20131201712020 Emission Inventories for 

Regional Air Quality Modeling in the Northeast/Mid-Atlantic Region (MARAMA 2017 TSD) 

and the Technical Support Document for the Development of the 2025 Emission Inventory for 

PM2.5 Nonattainment Counties in the MANE- VURegion, January 2012 (MARAMA 2025 TSD), 

respectively. 

For EGU emissions, P ADEP 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 of the 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. Emission projections were based on Version 3.3 of the 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 Area Forecast (TAF) system for 2009-2030 (FAA2010). Railroad emissions were 

based on the 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 in the model where appropriate 
OAMA staff reviewed the methodologies provided by P ADEP and found them to be 

acceptable.