T ec hnic a l S uppo r t D o c u ment

f or the

Bay Area Winter Emission Inventory

for

Primary PM 2.5 & PM Precursors: Year 2010

Adopted by the Bay Area Air Quality Management District on November 7, 2012

S ubm i t t e d to EPA on January 14, 2013 b y the California Air Resources Board

December 20

, 20131

I. Introduction

The pur p ose o f this doc u ment is to supplement the technical information provided in the direct final federal register notice approving the 2010 PM 2.5 Emissions Inventory for the San Francisco Bay
Area (Bay Area emissions inventory), 1 adopted by the Bay Area Air Quality Management District (District or BAAQMD) on November 7, 2012, and sub m i t ted by the California Air Resources Board ( C ARB) on behalf of the District to EPA on January 14, 2013

. A n y q u e st i ons p e rt a in i ng to t his technical support document (TSD) should be d i r ec ted to Nancy Levin at 415

- 972

- 3848 or levin.nancy@epa.gov

.

II. Procedural Requirements for Adoption and Submittal of SIP Revisions

Sections 110(a)(1) and 110(l) of the Act require states to provide reasonable notice and public hearing prior to adoption of SIP revisions. Section 110(k)(1)(B) requires EPA to determine whether a SIP submittal is complete within 60 days of receipt. Any plan that we have not affirmatively determined
to b e complete or incomplete will become complete six months after the day of submittal by operation of law. A finding of completeness does not approve the submittal as part of the SIP nor does it indicate that the submittal is approvable. It does start a 12

- m onth clock for EPA to act on the SIP submittal. See CAA section 110(k)(2).

a. Reasonable notice and public hearing

CARB’s submittal to EPA documents the public review process followed by San Francisco Bay Area Air Quality Management District (BAAQMD) and CARB in adopting the Bay Area emissions inventory prior to submittal to EPA as a revision to the SIP.

The documentation provides evidence t hat reasonable notice of a public hearing was provided to the public and that a public hearing was conducted prior to adoption. 2 CARB’s submittal includes a copy of the notice to the public published on September 26, 2012, announcing a public hearing to be held on November 7, 2012. The notice for the public hearing was published in the San Francisco Chronicle and the San Jose Mercury News, newspapers of general circulation, on September 26, 2012. The Bay Area Emissions Inventory was also made available fo r viewing on the District's website and at the District office on and after September 26, 2012. CARB’s submittal includes a memorandum dated October 25, 2012 from Jack P. Broadbent, Executive Director/Air Pollution Control Officer to the Chairperson and me mbers of the Board of Directors recommending that at the upcoming public hearing the Board adopt the 2010 PM 2.5 emissions inventory for transmittal to CARB. These materials document the public review process followed by BAAQMD in adopting the Bay Area Emis sions Inventory prior to transmittal to CARB and provide evidence that reasonable notice of a public hearing was provided to the public and that a public hearing was conducted prior to adoption.

1 CARB adopted the 2010 PM 2.5 Emission Inve ntory for the Bay Area in 2012 and refers to the submittal as the “2012 PM2.5 Emission Inventory to the State Implementation Plan for the San Francisco Bay Area.” However, the actual inventory in the 2012 CARB su bmittal (Appendix D) is the “Bay Area Winter Emissions Inventory for Primary PM 2.5 & PM Precursors: Ye ar 2010.” For purposes of this action, any reference to the 2012 PM2.5 Emissions Inventory is equivalent to the Bay Area 2010 winter

- time PM 2.5 emission inventory.

2 BAAQMD Board of Directors Regular Meeting Approved Minutes, November 7, 2012 http://www.ba aqmd.gov/~/media/Files/Board%20of%20Directors/2012/brd_min_110712.ashx?la=en2

CARB’s submittal documents the adoption of the Bay Area Emissions Inventory by the BAAQMD Board of Directors. On November 7, 2012, the BAAQMD Board of Directors approved the Bay Area Emissions Inventory and directed BAAQMD staff to forward the inventory to CARB, the Governor of California’s designee for SIP mat ters. 3 CARB’s submittal documents the adoption of the Bay Area Emissions Inventory by the BAAQMD Board of Directors.

The submittal also includes CARB’s public hearing notice

, 4 transcript, 5 and December 6, 2012 Board resolution approving the Bay Area emis sions inventory. 6 On January 14, 2013, CARB submitted the Bay Area emissions inventory to EPA for approval as a revision to the California SIP.

Based on the documentation included in CARB’s submittal, we find that the submittal of the Bay
Area emissions i nventory, as a SIP revision, satisfies the procedural requirements of sections 110(l) of the Act for revising SIPs.

b. Completeness review

A completeness review allows us to determine if the submittal includes all the necessary items and
information we need to act on it. We make completeness determinations using criteria we have established in 40 CFR part 51, Appendix V. These criteria fall into two categories: administrative information and technical support information. The administrative information provid es documentation that the State has followed basic administrative procedures during the SIP

- adoption process and thus we have a legally

- adopted SIP revision in front of us. The technical support information provides us the
information we need to determine the impact of the proposed revision on attainment and maintenance of the air quality standards. We notify a state of our completeness determination by letter unless the submittal becomes complete by operation of law. The Bay Area Emissions Inventory became complete by operation of law on July 14, 2013.

III. Summary of SIP Revisions

The emission inventory for the San Francisco Bay Area nonattainment area submitted by CARB on January 14, 2013 provides a 2010 inventory in tons per day (tpd) winter

- time emissio n estimates for

PM 2.5 and PM 2.5 precursors (i.e., nitrogen oxides (NO x ), volatile organic compounds (VOCs), 7
ammonia (NH 3 ) and sulfur dioxide (SO 2 )). The Bay Area Winter Emissions Inventory for Primary

PM 2.5 and PM Precursors: Year 2010 is attached. The federal register notice approving this inventory provides a summary of the inventory and the procedural and technical basis for approval

. In addition to the information provided in the federal register notice, we provide information in the following secti ons IV and V.

3 BAAQMD Resolution No. 2012

- 11, November 7, 2012

. 4 CARB Notice of Public Meeting to Consider Approval of the 2012 PM 2.5 Emission Inventory Submittal to the State Implementation Plan fo the San Francisco Bay Area, November 13, 2012.

5 Meeting, State of California, Air Resource Board, South Coast Air Quality Management District Auditorium, Diamond Bar, Califo rnia, December 6, 2012.

6 CARB Resolution 12

- 37, December 6, 2012.

7 BAAQ MD uses the term Reactive Organic Gas (ROG) rather than VOC. EPA formerly defined the regulated organic compounds in outdoor air as ROG. However, EPA later changed that terminology to “VOC.”3

IV

. Clarification Regarding Calculation of PM 2.5 Emissions from Paved Roads

The 2010 emissions inventory for the San Francisco Bay Area nonattainment area submitted by
CARB estimates PM 2.5 emissions from paved roads to be approximately 3.5 tons per day. CARB
estimated annual PM 10 emissions using the Jan uary 2011 AP

- 42 paved road dust emission factor equation with California

- specific silt loadings. Historical days of rain were used for the rainfall adjustment factor. CARB us ed California spec iation profile #471 to calculate PM 2.5 from PM 10 ( PM 2.5 = 0.15 * PM 10 ). http://www.arb.ca.gov/ei/speciate/dnldoptvv10001.php#specprof

. This differs from the 25% particle size fraction for PM 2.5 / PM 10 given in the AP

- 42. Emissions estimates used 2008 annualized VMT per average weekday from EMFAC

- 2011SG, apportioned to road category using 2008
Caltrans HPMS travel fractions. 2008 base year emissions for the San Francisco Bay Area were projected to 201 0 using centerline miles. 8

EPA has reviewed CARB’s methodology for estimating PM 2.5 emissions from paved roads and determined that the methodology used for calculat ing the 2008 base year is acceptable ; however, use of centerline miles to project the 201 0 inv entory has not been approved by EPA. Because the paved road emissions estimate is not being used to create a motor vehicle emissions budget (MVEB) for the San Francisco Bay Area PM 2.5 nonattainment area and because the difference in emissions between 2008 and 2010 is expected to not be significant , EPA is not requiring at this time that CARB revise the PM 2.5 emissions es timate for paved roads . If in the future a MVEB and a maintenance plan for the area are submitted to EPA, the paved road PM 2.5 emissions es timate would need to be derived by a method approved by EPA.

V. Attachment

Bay Area Winter Emissions Inventory for Primary PM 2.5 and PM Precursors: Year 201 0 , Attachment 1.

8 December 11 and 12, 2013 emails from Janet Spencer, CARB, to J ohn Ungvarsky, EPA Region 9

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