Technical Support Document (TSD) for the Redesignation Request and Maintenance Plan For the PennsylvaniaPortion ofthe Philadelphia-Wilmington, PA-NJ-DE 1997 PM2

.sNonattainment Area

Submitted by Pennsylvania Department ofEnvironmental Protection
TSD Prepared December 2014 by Jessica L. Fry Office ofAir Monitoring and Analysis, 3AP40 U.S. Environmental Protection Agency, Region 3 1650 Arch Street Philadelphia, Pennsylvania 19103

Reviewed by Alice H. Chow, Associate Director Office ofAir Monitoring and Analysis (3AP40)

### I. Introduction
The purpose ofthis document is to provide a technical summary ofthe Office ofAir Monitoring and Analysis (OAMA) review ofthe emissions inventories submitted with the Redesignation Request and Maintenance Plan for the Pennsylvaniaportion ofthe Philadelphia-Wilmington, PA-NJ-DE 1997 PM2.s Nonattainment Area (NAA) bythe PennsylvaniaDepartment of Environmental Protection (PADEP). The Pennsylvaniaportion oftheNAA consists ofBucks, Chester, Delaware, Montgomery, and Philadelphiacounties. This review does not determine the approvability ofthe redesignation request or maintenance plan. Emissions inventories in a redesignation request are used to show permanent and enforceable emission reductions between the yearthe areawas 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 showthat the area will remain in attainment. Any questions pertaining to this technical summary should be directed to Alice H. Chow, Associate Director, Office ofAir Monitoring and Analysis, at 215-814-2144 or via email at chow.alice@epa.gov.


### II. Emissions Inventories for Redesignation Request
2002Base YearInventory
In a redesignation request, emissions inventories are used to support the States claim that the areahas permanent and enforceable emissions reductions. In order to do this, the state should estimate the percent reduction (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 year inventory orbaseline inventory. Under section 172(c)(3) states are required to submit a comprehensive, accurate, current accounting ofactual emissions from all sources (point, nonpoint, nonroad, and onroad) in the nonattainment area. This inventory contains primary PM2

.semissions (including condensable PM), S02, NOx, VOC, and NH3. PADEP submitted their 2002 Base Year Inventory to EPA as a State Implementation Plan (SIP) revision. The 2002 inventory fulfills both ofthese requirements and was approved by EPA with an effective date ofAugust 28, 2012 (77 FR 51930).


### III. Emissions Inventories for Maintenance Plan


### 2007Attainment YearInventory andMaintenance Plan Base Year Inventory
The inventory used for the year ofattainment is called the attainment year inventory and also is 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 contains primary PM2.s emissions (including condensibles), S02,NOx, NH3, and VOC. This section will discuss the 2007 attainment year inventory that was used in the Pennsylvaniaportion ofthe Philadelphia-Wilmington, PA-NJ-DE Redesignation Request and Maintenance Plan submitted by PADEP.For the 2007 attainment year inventory for point, nonpoint, and nonroad categories, PADEP submitted the 2007 Version 3 Emissions Inventory developed through the Mid-Atlantic Regional Air Management Association (MARAMA) regional planning process. A comprehensive county level inventory for the Philadelphianonattainment area (NAA) was developed byPADEP in coordination with MARAMA, NewJersey Department of Environmental Protection (NJDEP), and Delaware Department ofNatural Resources and Environmental Control (DNREC). Documentation ofthe development ofthe inventory can be found in Technical Support Document for the Development of the 2007Emission Inventory for the RegionalAir QualityModeling in the NortheastIMid-Atlantic Region Version 3.3. January 23, 2012.
The 2007 point source inventory contained emissions for electric generating units (EGUs) and Non-EGU sources in Bucks, Chester, Delaware, Montgomery, and Philadelphia counties. EPA guidance for emissions inventory development provides that actual emissions shouldbe used for purposes ofthe base year inventory. The point source inventory submitted was developed by MARAMA in consultation with PADEP using information compiled from 2007 Annual Emissions Reports submitted to Pennsylvania from facilities in the state. In order to account for missing condensable PM emissions from EGUs the data was augmented using emissionfactors developed for MARAMA.
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.
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 ofthe NONROAD model, they were calculated separately outside ofthe NONROAD model. Aircraft emissions were developed using EPA's database to the support the 2008 NEI. PADEP used railroad emissions developed bythe Eastern Regional Technical Advisory Committee (ERTAC)

. The 2007 onroad mobile source inventory was developed using EPA's highway mobile source emissions model MOVES201 Oa. PADEP used local activity to replace default inputs in the model where appropriate.
OAMA staffreviewed the files and the emission results provided by PADEP and found them to be acceptable.


### III. Projection Emissions Inventories for Maintenance Plan
2017and2025Projection Emission Inventories Projection inventories are used to showthat 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 TechnicalSupportDocument for the Development of the 2013/201712020 Emission Inventoriesfor RegionalAir QualityModeling in the Northeast/Mid-Atlantic Region (MARAMA 2017 TSD) and the Technical SupportDocument for the Development of the 2025 Emission Inventory for PM2.5Nonattainment Counties in the MANE-VURegion, January 2012 (MARAMA 2025 TSD), respectively.
ForEGU emissions, PADEP used growth factors based on the Annual Energy Outlook (AE02011) and applied them to the 2007 inventory. Non-EGU emissions projections were based onVersion 3.3 ofthe 2007 MANE-VU+VA inventory. MARAMA growth factors were developed using AEO fuel consumption forecasts, state-level employment projections, and other state-specific emissionprojection data. Nonpoint source emissions for 2017 and 2025 were developed similarly to the non-EGU point sources. Emissionprojections were based on Version 3.3 ofthe 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 AreaForecast (TAF) system for 2009-2030 (FAA201 0). Railroad emissions were based on the MARAMA MANE-VU+Vainventory.
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 inthe model where appropriate
OAMA staffreviewed the methodologies provided by PADEP and found them to be acceptable.