Technical Support Document (TSD) For Emissions Inventories for the Delaware Nonattainment Area 8 Hour Ozone State Implementation Plan (SIP) Base Year Inventory

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Submitted June 2007 bythe Delaware Department ofNatural Resources And Environmental Control TSD Prepared December, 2008 Janet C. Kremer Air QualityAnalysis Branch, 3AP22 U.S. Environmental Protection Agency, Region 3 1650 Arch Street Philadelphia, Pennsylvania 19103

Reviewed byWalter Wilkie, Chief Air QualityAnalysis Branch (3AP22) 

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### II I. Introduction The purpose ofthis document is to provide a technical summary ofthe Air Quality Analysis Branch's (AQAB) review ofthe emissions inventories submitted with the Delaware NonattainmentArea 8 Hour Ozone State hnplementationPlan (SIP) bythe Delaware Department o{Natural Resources and Environmental Control (DNREC). This review determines the approvability ofthe SIP Base Year Inventory and an evaluation of the methods used for projection year inventories. A SIP Base Year Inventoryis 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 ofan emissions reduction creditprogram. Projection year inventories are essentiallyused to track progress; the purpose ofwhich is to demonstrate a reduction in emissions ofregulated sources from the BaseYearto a projected year. The DelawareNonattainment Areawas 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 EPAbyJune 15,2006; with the final Base Year inventory due with the SIP to EPAbyJune 15,2007. DNREC has submittedthe Delaware 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 QualityAnalysis Branch, at 215-814-2150 or via email at wilkie.walter@epa.gov. 

### 2002 SIPBase Year Inventory The SIP base year inventory is the primaryinventory 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.! The base year inventoryincludes emissions estimates from stationarypoint and nonpoint sources, onroad mobile sources, and nonroad mobile sources. Forthe 8­ hour ozone NAAQS, the pollutants to be inventoried are VOC, NOx and CO (carbon monoxide). Forthe 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 duringthe ozone season). DNREC'sbase year inventory is for 2002. For the Delaware SIP, the geographic coverage includes sources in New Castle County, Kent County and Sussex County. A significant amount of documentation is required for these SIP base year estimates whichDNREC has provided. DNREC's Emission Inventory Development (EID) Program (which resides within the Air QualityManagement Section (AQMS)) was primarilyresponsible for preparing the 2002 base year ozone precursor inventory. Thepoint source inventoryrepresents facility-specific data for larger stationary sources. Point source emissions data are submitted to AQMS bythe facilities using Terminal Server Satellite i-STEPS software. iI "Emissions Inventory Guidance/orImplementation o/Ozone andParticulateMatter NationalAmbient Air Quality Standards (NAAQS) andRegionalHaze Regulations" EPA-4541R-05-001, August 2005STEPS is the point source emission inventory electronic data management system. The criteria used to detennine ifa source wouldbe a part ofthe point source inventory was as follows: • AnyTitle V pennitted facilities • In Kent County and New Castle County, any facility with emissions ofVOCs greater than 5 Tons PerYear (TPY) and 25 TPY or greater for NOx • In Sussex County, any facility that with emissions of 100 TPY orgreater ofNOx orVOC • all electric generating facilities DNREC provided its 2002 actual annual emissions and actual emissions for typical summer season(duringpeak ozone season-June, July, August) weekday emissions (SSWD) for NOx and VOC at the facility level and at the process-level. Forthe 2002 Nonpoint Source emissions, also known as "area sources," DNREC provided an inventory that contained estimations ofemissions bymultiplying an emission factor by some known indicator or activity level for each category at the county level. These emissions are calculated on an annual basis. Summer season weekday daily emissions were developed through the use ofa temporal allocation factor (TAF) applied to the annual emissions. DNREC 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 ofemission factors ormethodologies were used, including EPA's AP-42, the FactorInfonnationRetrieval System (FIRE), EPA's Emissions InventoryhnprovementProgram, Volume III, documented projects perfonned bythe California AirResource Board, and projects perfonnedbythe Mid-Atlantic Regional Air Management Association (MARAMA). Nonpoint source estimates were provided by SCC. The Nonroad Mobile Source 2002 annual inventorywas prepared with EPA's NONROAD2005 model byE.H. Pechan and Associates under contract from the Mid AtlanticlNortheast VisibilityUnion (MANE-VU) using Delaware specific inputs. SSWD values were developed by summing the NONROAD2005 monthly emissions for June, July, and August and applying weekly allocationprofiles. 'NONROAD estimates fuel consumption and emissions oftotal hydrocarbons, carbon monoxide, nitrogen oxides, sulfur dioxide, and particulate matter for all nonroad mobile source categories except for aircraft, locomotives, and commercialmarine vessels. DNREC provided emission estimates for locomotive engines, aircraft emissions and commercial marine vessels separately. For line haul locomotive and yard locomotive emissions, DNREC requested and received estimates offuel consumption or data to calculate fuel consumption. Some infonnation was provided at county level for each county in Delaware, while some was provided system-wide and needed to be allocated to Delaware. Track miles within each county were used to allocate statewide fuel consumption to each county. Paired withEPA emission and conversion factors, DNREC calculated locomotive annual emissions for the base year. To estimate SSWD emissions, DNREC assumed that locomotives operate evenly seven days a week. For aircraft emissions, DNREC took airport-specific emissions for all aircraft sub-categories and allocated them to the county in which each airport is located. DNREC estimated annual aircraft emissions using a combination of airport-specific activity data and Federal Aviation Administration (FAA)IEPA emission factors. DNREC requested landing and take-offdata from the Delaware AeronauticsAdministration and from individual airports, for each sub-category ofaircraft. DNREC used these airport-specific LTO data to estimate emissions using FAA's Emissions and Dispersion Modeling System (EDMS)

. Temporal profiles were applied to get typical SSWD emissions

. For commercial marine vessels, there are manytypes ofvessels that engage in many different modes ofactivity, therefore DNREC used several different sources to obtain data for each vessel type and activity

. Some ofthese sources included the MarineExchange ofthe Delaware River (ME, 2004), the Commercial Marine Activity for Deep SeaPorts in the United States (EPA, 1999), and the Waterborne Commerce ofthe United States (USACE, 2004a). Annual emissions were calculated by vessel type, engine type, and mode ofoperationusing county level activity data. SSWD daily emissions were calculatedbymultiplying the annual emissions by a TAP

. All Nonroad mobile source emissions wereprovidedby SCC. The Onroad Mobile Source 2002 emissions inventorywas developed using the most current version ofEPA's highwaymobile source emissions model MOBILE 6.2 (M6.2) and link-level vehicle miles traveled (VMT) data for each county from the Delaware Department ofTransportation(DelDOT)

. The emission factors developed using M6.2, were bymonth, using monthly temperature and fuel property data

. Typical SSWD temporal adjustments were developed bycounty and roadway class. DNREC provided Mobile6

.2 input and output files for review

. DNREC provided annual mobile emissions values in Tons PerYear(TPY) and SSWD emissions in units oftons per summer day (TPD) and were providedby SCC. DNREC also applied rule effectiveness and rule penetration for its 2002 8-hour ozone SIP base yearinventories. Rule effectiveness reflects the actual ability ofa regulatoryprogram to achieve the emissionreductions required byregulation (orperhaps voluntarily adopted). DNREC applied rule effectiveness and where applicable, provided ajustification ofa higher percentagethan EPA's previous policy (which assumed an 80% rule effectiven' ess for applicable sources unless otherwise specified)

. Rule penetration is an estimate ofpercentage ofemissions in a source categorythat are emitted at facilities subject to the requirements ofa rule. DNREC applied rule penetration for its nonpoint sources where applicable. AQAB staffreviewed the results, procedures, and methodologies for the SIP base year, and found them to be approvable.

II. 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 Delaware NAA SIP. The 2008 projected inventoryis required for reasonable further progress (RFP) and the 2009 projected inventory is required for the attainment year. In general, because the 2008 milestone year is so close to the 2009 attainment year, the 2008 emission projections in this section are obtainedbylinear interpolating ofthe 2002 base year emissions and the 2009 projections, unless otherwise explained. This interpolation method assumes a linear growth in emissionbetween , 2002 and 2009, wherever a growth factor is applied for the 2009 projection, and the same control efficiency (CE), rule effectiveness (RE) and rule penetration (RP) in 2008 and 2009 for the relevant controls.The EGUpoint source emissions for 2009 were projected, using growth factors from the Department ofEnergy. The source ofdata for determining growth was the Annual EnergyReview 2004, and Energy Information Administration. Controls were applied on a unit byunit basis.

. The non-EGU point and area source emissions for 2009 were developed by MACTEC Federal Programs (MACTEC) under a contract with MANE-VU. Projections were base on applying growth and control factors to the 2002 base year inventory. However, the 2009 non-EGU projections made byMACTEC havebeen updated in some cases for the following reasons: • Delaware 2002 base year emission updates; • Delaware specific growth factors; • Control factor (CE, RE, etc.) updates; • Additional controls DNREC used 2009 nonroad mobile emissions developed byMACT ABC. MACTEC developed the 2009 Nonroad Mobile Source inventories using EPA'sNational Mobile Inventory Model 2005 whichincludes the NONROAD2005 model. The NONROAD2005 model allows for the calculation ofpast year, present year, and future year inventories (up to the year 2050) to be generated. MACTEC used combined growth and control factors developed from emission projections for EPA's Clean Interstate Rule development effort. Delaware determined SSWD emissions by applying 2002 dailyto annual emissionratios, assuming the daily to annual relations in 2009 will follow the same pattern as in 2002. These calculations were done by SCC, bycounty, andby pollutant. The 2008 2009 Onroad Mobile Source inventories were generated using EPA's MOBILE6.2 and 2009 VMT that was providedbyDelDOT. On-road mobile source controls for 2009 were taking into account in the input files for M6.2 AQAB staffreviewed the procedures, and found them to bereasonable for development ofthese inventories.