                EPA Region 2 Technical Support Document for the
                                       
           Approval of Air Quality Implementation Plans; New Jersey,
                       Carbon Monoxide Maintenance Plan
                [Docket No. EPA-R02-OAR-2016-0059; FRL-    ]
(Including the Shutdown of the CO Maintenance Area Monitors in Burlington, Freehold, Morristown, Perth Amboy, and East Orange, New Jersey)





















                                 February 2016
                   US Environmental Protection Agency (EPA)
                                   Region 2
               Division of Environmental Planning and Protection
                              Air Programs Branch
                               Table of Contents
                                                                           Page

 Carbon Monoxide Attainment Inventory and Limited
         Maintenance Plan (LMP) Requirements for the NJ Portion 
         of the New York-Northern New Jersey-Long Island 5-County
         CO Nonattainment Areas ...................................................... 4
   
   
 New Jersey 2007 CO Base Year Emissions Inventory SIP 
         for the NJ Portion of the New York-Northern New Jersey-
         Long Island 5-County CO Nonattainment Areas ........................ 9

 
 CO Maintenance Area Monitor shutdowns .............................. 17
         
			Attachments ................................................................... 22

			CO Maintenance Area Monitors to be shut down and
			their surrogate sites ......................................................... 23

			All NJ CO Monitor Sites ................................................. 24

			Camden CO site surrogate for Burlington CO site ................. 25 				
			Elizabeth Lab CO site surrogate for Freehold CO site ............ 26

			Elizabeth Lab CO site surrogate for Morristown CO site ........ 27

			Elizabeth Lab CO site surrogate for Perth Amboy CO site ...... 28

            Elizabeth Lab CO site surrogate for East Orange CO site ....... 29

			Carbon Monoxide Emissions from Mobile Sources ................ 30

       Carbon Monoxide Attainment Inventory and Limited Maintenance Plan (LMP) Requirements for the NJ Portion of the New York-Northern New Jersey-Long Island 5-County CO Nonattainment Areas


PREFACE

This document is to support EPA's approval of a revision to the New Jersey State Implementation Plan (SIP) which pertains to the following: The Carbon Monoxide Attainment Inventory and Limited Maintenance Plan (LMP) requirements for the NJ Portion of the New York-Northern New Jersey-Long Island 5-County CO Nonattainment Areas.

This TSD contains a detailed review of New Jersey CO Attainment Inventory and inventory portion of the LMP submittals.  Among the topics discussed below are the recent history and criteria for approval and EPA's final recommendations.

 Attainment Year Inventory Requirements

2007 CO Attainment Year Inventory
Page 3, of the October 6, 1995, memorandum from Joseph W. Paisie, Group Leader, Integrated Policy and Strategies Group to Regional Air Branch Chiefs entitled Limited Maintenance Plan Options for non-classifiable CO Nonattainment Areas, states that for inventory purposes, the State is only required to submit an attainment inventory to EPA that is based on monitoring data which shows attainment.  There is no requirement to project emissions over the maintenance period.  This means if 2007 is a calendar year which has monitoring data which demonstrates attainment, the 2007 base year inventory can be used as the attainment year inventory and no projection inventories are required over the years of the maintenance period.  Only calendar year 2007 summary emissions data (based on winter season day) are required. In addition, this inventory should be consistent with EPA's most recent guidance on emission inventories for nonattainment areas available at the time and should include emissions during the time period associated with the monitoring data showing attainment.

New Jersey submitted a limited maintenance plan (LMP) which included calendar year 2007 emissions inventory.  The 2007 emissions inventory is also classified as the attainment year inventory for the LMP.  New Jersey has elected 2007 because it is the attainment year base year that will be used for LMP and 2007 represents the one of the years of violation-free monitored data in the area.  The inventory included peak wintertime daily emissions from stationary point, stationary area, off-highway mobile, and highway mobile sources of CO.  These emission estimates were prepared in accordance with EPA guidance.

 CO Limited Maintenance Plan Requirements 

 Select a calendar year which shows violation-free data and develop an emissions inventory based on that year for the CO nonattainment area.  This is considered as the attainment year inventory.
       
 Yes, NJ selected calendar year 2007.  See Section IV of Final SIP Revisions for the Attainment and Maintenance of the 8-Hour CO NAAQS CO Maintenance and Monitoring Plan, June 2015 hereafter referred to as "NJ SIP 2015."

 Emissions are based on winter season daily emissions for CO. 
 
 Yes, See Section IV of NJ SIP 2015.
       

 Inventory must be reported in the prescribed format as indicated in the most recent inventory guidance. (For details, see Section C.)

 Provide an explanation on how the point, area, nonroad mobile and onroad mobile source inventory are developed. 

 See Yes, see Appendix III, Attachment 3, of NJ SIP 2015.

       

 Essential Summary Tables for Attainment Year Inventory 

For clarity, please provide the following emission summary tables for the Attainment and End Year Inventories.   
  
  
                              Emission Inventory 
                      Electronic Reporting Documentation 
                      CO Attainment/Nonattainment Areas 
  
At a minimum, states should ensure that the following is reported to the EPA Regional office.   Unless otherwise noted, in each of the following cases we refer the State to pages in the document entitled, Example Documentation Report for 1990 Base Year Ozone and Carbon Monoxide State Implementation Plan Emission Inventories, March 1992 located at the following website address: http://www.epa.gov/ttn/chief/publications.html#general   
  
  
1.          STATIONARY POINT SOURCES 
  
      -            Total winter season daily CO emissions from point sources, by county, by nonattainment area (see Table 4-3 on page 4-11) 
   
 Yes, see Appendix III, Attachment 4 of NJ SIP 2015..

      -            Summary listing of winter season daily CO point sources emissions by county, by nonattainment area.   This listing should include plant name, address, county, control efficiency, SIC code and annual emissions e (see Table 4-3 on page 4-11) 
  
See Excel file 2007 Point by Faclity.xlsx 

2.          STATIONARY AREA SOURCES 
  
      -            Summary of winter season daily CO emissions by area source category, by county, by nonattainment area (see pages 5-4 thru 5-9) 
 
 Yes, see Appendix III, Attachment 6 of NJ SIP 2015..

  
3.          ON-ROAD MOBILE SOURCES 
  
      -          Summary of winter season daily CO on-road mobile source emissions by MOVES Source Type (for Source Types, see Table 2 of the document Using MOVES to Prepare Emission Inventories in State Implementation Plans and Transportation Conformity: Technical Guidance for MOVES2010, 2010a and 2010b, April 2012) by county, by nonattainment area (see pages 7-2 and 7-19) 
      
      -	MOVES model inputs (as either Excel file(s) or MySQL database(s)) outlining current program parameters
      
      -	MOVES model outputs: 
      
 If MOVES is run in "Inventory" mode, supply a copy of the MySQL output database(s)
 If MOVES is run in "Emission Rate" mode, supply a copy of the MySQL output database(s) along with post-processing files
   
 Yes, see Appendix III, Attachment 3, page 15, Table 2, Attachment 7, and Attachment 8, NJ SIP 2015.

  
4.                   NON-ROAD MOBILE SOURCES 
  
      -            Summary of winter season daily CO non-road mobile source emissions by non-road category (for a list of the 14 nonroad categories see Section 5.5.2 of  Emission Inventory Guidance for Implementation of ozone and Particulate Matter NAAQS and Regional Haze Regulation , dated August 2005), by county, by nonattainment area (see page 5-6) 
  
      -            The summary reports mentioned should be submitted in Microsoft Spreadsheet formats. 
  
 Yes, see Appendix III, Attachment 3, pages 16-25 and Attachment 9A NJ SIP 2015.


 Provide an explanation on how the point, area, nonroad mobile and onroad mobile source inventory are developed. 
 
 
 Yes, see Appendix III, Attachment 3 of NJ SIP 2015.
 
 
IV.		EPA RECOMMENDATIONS

EPA is approving the inventory portion of the CO Limited Maintenance Plan inventory for the counties of Bergen, Essex, Hudson, Union and Passaic counties.  A more detailed discussion of how the emission inventory was reviewed and the results are presented in Section II of the technical support document (TSD).

The following table presents a summary of the 2007 CO winter season daily emissions estimates in tons per winter day for the counties of Bergen, Essex, Hudson, Union and Passaic counties.  See table below.

                                       
                       2007 Attainment Inventory for the
     NJ Portion of the New York-Northern New Jersey-Long Island 5-County 
                            CO Nonattainment Area 
                         (Tons/Peak Winter Season Day)
County
                                 Point Sources
                                 Area Sources
                             Onroad Mobile Sources
                            Nonroad Mobile Sources
                                    TO TAL
Bergen
                                     1.82
                                    14 .7 5
                                    34 6.29
                                    13 9.60
                                    50 2.47
Essex
                                     5.5 2
                                    12 .9 3
                                    19 8.99
                                     75.20
                                    29 2.64
Hudson
                                     2.4 6
                                    10 .0 5
                                    11 1.77
                                     35.70
                                    15 9.97
Passaic
                                     0.3 2
                                     6.52
                                    14 4.70
                                     42.30
                                    19 3.84
Un ion
                                     4.1 8
                                     8.31
                                    16 9.18
                                     53.60
                                    23 5.27
Total
                                     14.30
                                    52 .5 6
                                    97 0.93
                                    34 6.50
                                   1,38 4.19


II.	New Jersey 2007 CO Base Year Emissions Inventory SIP for the NJ Portion of the New York-Northern New Jersey-Long Island 5-County CO Nonattainment Areas
 PREFACE

This document is to support EPA's approval of a revision to the New Jersey State Implementation Plan (SIP) which pertains to the following: 

Where applicable, 2007 base year inventory winter season daily emissions for CO for the NJ Portion of the New York-Northern New Jersey-Long Island area which includes the following counties: Bergen, Essex, Hudson, Union and Passaic counties.

This TSD contains a detailed review of New Jersey's 2007 CO base year emission inventory submittal. Among the topics discussed below are the recent history and criteria for approval and EPA's final recommendations.


 BACKGROUND 

Sections 182(a) (1) and (2) of the Clean Air Act require the periodic submission of base inventory for SIP planning purposes to address the pollutants for the eight hour-ozone, PM2.5 and CO National Ambient Air Quality Standards (NAAQS.).  Identifying the base year gives certainty to states that are required to submit of the ozone, PM2.5 and CO emission inventories periodically.  These requirements allow the EPA, based on the states' progress in reducing emissions, to periodically reassess its policies and air quality standards and revise them as necessary.  Most important, the ozone, PM2.5 and CO inventories will be used to develop and assess new control strategies that the states will need to submit in their attainment demonstration SIPs for the new NAAQS for ozone, PM2.5 and for CO.  The base year inventory may also serve as part of statewide inventories for purposes of regional modeling in transport areas.  The base year inventory plays an important role in modeling demonstrations for areas classified as nonattainment and outside transport regions.  For the reasons stated above, ideally EPA would therefore emphasize the importance and benefits of developing a comprehensive, current, and accurate ozone, PM2.5 and CO emission inventory (similar to the 1990 base year inventory effort).  In this case, the 2007 base year has been selected as the inventory that will be used for planning purposes for the NJ Portion of the New York-Northern New Jersey-Long Island CO nonattainment area. 



 CRITERIA FOR APPROVAL

There are general and specific components of an acceptable emission inventory.  In general, the State must submit a revision to its SIP and the emission inventory must meet the minimum requirements for reporting by source category.  Specifically, the source requirements are detailed below.

The Level I and II review process is used to determine that all components of the base year inventory are present.  The review also evaluates the level of supporting documentation provided by the State and assesses whether the emissions were developed according to current EPA or acceptable alternative guidance.  The data quality is also evaluated. 

The Level III review process is outlined here and consists of points that the inventory must adequately address.  For a base year emission inventory to be acceptable it must pass all of the following acceptance criteria: 

 Adequate documentation must be provided that enabled the reviewer to determine the	emission estimation procedures and the data sources used to develop the inventory.

 Evidence that the inventory was quality assured by the state and its implementation documented.

 The point source inventory must be complete.

 Point source emissions must have been prepared or calculated according to the current EPA guidance.

 The area source inventory must be complete.

 The area source emissions must have been prepared or calculated according to the current EPA guidance.

 Non-road mobile emissions were prepared according to current EPA guidance for all of the source categories.

 The method (e.g., HPMS or a network transportation planning model) used to develop VMT estimates must follow EPA guidance.  The VMT development methods must be adequately described and documented in the inventory report.


 The MOVES model must be correctly used to produce the on-road emission inventory.


 DETAILED ACTION AND EVALUATION


This TSD contains a detail discussion and summary of the review conducted by EPA for, where applicable, the 2007 base year inventory winter season daily emissions for CO for the NJ Portion of the New York-Northern New Jersey-Long Island CO nonattainment area.



 Details on How New Jersey Meets Criteria 1 for the Quality Assurance Plan

Quality Assurance Plan Implementation

The Quality Assurance (QA) plan was implemented for all portions of the inventory.  The QA plan included a QA/Quality control (QC) program for assessing data completeness and standard range checking.  Critical data elements relative to the inventory sources were assessed for completeness.  QA checks were performed relative to data collection and analysis, and double counting of emissions from point, area and mobile sources.  QA/QC checks were conducted to ensure accuracy of units, unit conversions, transposition of figures, and calculations. The QA plan for the inventory was performed in accordance with section 6.0 of Emission Inventory Guidance for Implementation of ozone and Particulate Matter NAAQS and Regional Haze Regulation, dated August 2005 and Example Documentation Report for 1990 Base Year for ozone and CO SIP Emissions Inventories, March 1992. 


See Appendix III, Attachment 3 of Section VI of Final SIP Revisions for the Attainment and Maintenance of the 8-Hour CO NAAQS CO Maintenance and Monitoring Plan, June 2015 hereafter referred to as "NJ SIP 2015."


  Details on How New Jersey Meets Criteria 2 and 3 for the Point Source Inventory

Point Source Inventory
New Jersey's inventory includes major point sources based on the following thresholds for each pollutant in tons per year (tpy): 100 tpy or more of CO.  The inventory report describes how point source activity levels and their associated parameters were developed, and how the data were used to calculate emission estimates.  The report provides referenced documents for activity level and emission factors used.  Information on how rule effectiveness and control efficiencies were derived (with the associated sample calculations) is also provided.  Plant summary information on detailed, plant, county and nonattainment area levels, are included in the inventory.  Where applicable, winter season daily emissions are provided for the CO nonattainment area.  The inventory was developed in accordance with section 5.3 of Emission Inventory Guidance for Implementation of ozone and Particulate Matter NAAQS and Regional Haze Regulation, dated August 2005 and Example Documentation Report for 1990 Base Year for ozone and CO SIP Emissions Inventories, March 1992, 

See Appendix III, Attachment 3 of NJ SIP 2015.

 Details on How New Jersey Meets Criteria 4 and 5 for the Area Source Inventory

Area Source Inventory
The inventory lists the source categories that are included in (and excluded from) from the area source inventory.  The inventory documentation includes emissions factors, activity levels, seasonal adjustment factors, and sample calculations.  Referenced information for the input values to equations is included.  Point source contributions have been correctly factored out of the area source category totals where appropriate.  Rule effectiveness, control efficiency and rule penetration were correctly applied for several source categories and a discussion as to the basis for application is provided.  Area source emissions are presented on a source category, county basis.  Where applicable, winter season daily emissions are provided for CO nonattainment areas.  The inventory was developed in accordance with section 5.4 of Emission Inventory Guidance for Implementation of ozone and Particulate Matter NAAQS and Regional Haze Regulation, dated August 2005 and Example Documentation Report for 1990 Base Year for ozone and CO SIP Emissions Inventories, March 1992, 

See Appendix III, Attachment 3 of NJ SIP 2015.


 Details on How New Jersey Meets Criteria 7 for Non Road Mobile Source Inventory

Nonroad Mobile Source Inventory
For the New Jersey, the predominant non-road mobile source categories (i.e., agricultural equipment, construction equipment, industrial equipment, airport service equipment, light commercial equipment, lawn and garden equipment...etc.) were developed by the Nonroad Emissions Equipment Model 2008 (Nonroad2008, July 2009 version) released by EPA's Office of Transportation and Air Quality (OTAQ).  Nonroad mobile source emissions are presented on a source category, county basis. Where applicable, winter season daily emissions are provided for CO nonattainment areas. The inventory was developed in accordance with section 5.5.2 of Emission Inventory Guidance for Implementation of ozone and Particulate Matter NAAQS and Regional Haze Regulation, dated August 2005 and Example Documentation Report for 1990 Base Year for ozone and CO SIP Emissions Inventories, March 1992, 

See Appendix III, Attachment 3 and Attachments 9a/9b of NJ SIP 2015.

Aircraft Emissions
Aircraft emissions for are provided for CO were calculated based on the number of landing and takeoffs (LTO) cycles generated at each airport.  These values were used as inputs to the Emissions and Dispersion Modeling System, the Federal Aviation Agency modeling tool.  Aircraft source emissions are presented on a source category, county basis. Where applicable, winter season daily emissions are provided for CO nonattainment areas. The inventory was developed in accordance with section 5.5.2 of Emission Inventory Guidance for Implementation of ozone and Particulate Matter NAAQS and Regional Haze Regulation, dated August 2005 and Example Documentation Report for 1990 Base Year for ozone and CO SIP Emissions Inventories, March 1992, 

See Appendix III, Attachment 3 and Attachments 9a/9b of NJ SIP 2015.

Locomotive Emissions
Locomotives emissions for CO were calculated based on the estimated fuel consumption for individual railroad systems operating in New Jersey.  NJDEP received specific fuel use data from Class II and III, yard/switch, freight and commuter locomotive railroads.  An estimation of fuel consumption based on gross ton miles and fuel consumption indexes were prepared for those railroads that did not submit statewide fuel data.  For Class I line haul locomotives, NJ used Class I line haul county level emissions used from the ERTAC 2008 inventory that was developed for the MARAMA States.  Annual emissions were estimated and then divided by 365 days. Locomotive source emissions are presented on a source category, county basis. Where applicable, CO winter season emissions are provided for CO nonattainment areas. The inventory was developed in accordance with section 5.5.2 Emission Inventory Guidance for Implementation of ozone and Particulate Matter NAAQS and Regional Haze Regulation, dated August 2005 and Example Documentation Report for 1990 Base Year for ozone and CO SIP Emissions Inventories, March 1992, 

See Appendix III, Attachment 3 and Attachments 9a/9b of NJ SIP 2015.

Commercial Marine Vessel Emissions
Commercial marine vessel (CMV) emissions for CO for the Northern New Jersey area were taken from the CMV emissions inventory report prepared by Starcrest Consulting Group, LLC.  The inventory report relied on actual operational data and then used local activity parameters to extend emission estimates to those portions of the CMV not directly inventoried.  From this information, emission estimates were prepared based on estimated horsepower demand.  The inventory is based on calendar year 2000.  NJ projected these emissions from 2000 to 2007 using NJ/NJ Port Authority trade statistics.  CMV source emissions are presented on a source category, county basis. Annual emissions were estimated and then divided by 365 days. Where applicable, winter season daily emissions are provided for CO 5 nonattainment areas. The inventory was developed in accordance with section 5.5.2 Emission Inventory Guidance for Implementation of ozone and Particulate Matter NAAQS and Regional Haze Regulation, dated August 2005 and Example Documentation Report for 1990 Base Year for ozone and CO SIP Emissions Inventories, March 1992, 

See Appendix III, Attachment 3 and Attachments 9a/9b of NJ SIP 2015.


 Details on How New Jersey Meets Criteria 8 and 9 for the Onroad Source Inventory

Onroad Mobile Source Inventory
New Jersey's mobile source inventory was developed by first using the North Jersey Transportation Planning Authority's North Jersey Regional Transportation Model-Enhanced travel demand model (TDM) as the basis for estimating county level vehicle miles traveled (VMT) and speeds.  New Jersey then used the PPSUITE custom pre-processing software to prepare the VMT and other required inputs, and to run the MOVES2010a model to generate the on-road emission inventory.

This method used to determine on-road emission estimates has been explained in the report. The report describes how the following key MOVES inputs were developed:

 Source type age distribution
 Distribution of VMT by road type
 Fraction of vehicle hours travelled (VHT) on highway ramps
 Source type population
 Inspection and maintenance program
 NJ Low-emission vehicle program
 Distribution of average speeds by source type and road type
 Meteorology
 Fuel parameters

On-road CO emissions are presented by county and source type. The inventory was developed in accordance with Using MOVES to Prepare Emission Inventories in State Implementation Plans and Transportation Conformity: Technical Guidance for MOVES2010, 2010a and 2010b, dated April 2012 and Example Documentation Report for 1990 Base Year for ozone and CO SIP Emissions Inventories, March 1992. The use of MOVES2010a is appropriate as this SIP was developed prior to the release of MOVES2014.

See Appendix III, Attachment 3, Attachment 7, and Attachment 8 of NJ SIP 2015.


EPA RECOMMENDATION

New Jersey has a SIP that will ensure that the requirements of emission inventory measures and reporting are adequately met.  To comply with the emission inventory requirements, the State submitted a complete inventory containing point, area, on-road, and non-road mobile source data, and accompanying documentation. The SIP submittal does not present any particular issues associated with enforceability. 

EPA is approving this SIP submittal as meeting the essential reporting requirements for an Emission Inventory.  The following table presents a summary of the 2007 CO winter season daily emissions estimates in tons per winter day for the counties of Bergen, Essex, Hudson, Union and Passaic counties. See table below.


                                       
                       2007 Attainment Inventory for the
     NJ Portion of the New York-Northern New Jersey-Long Island 5-County 
                            CO Nonattainment Area 
                         (Tons/Peak Winter Season Day)
County
                                 Point Sources
                                 Area Sources
                             Onroad Mobile Sources
                            Nonroad Mobile Sources
                                    TO TAL
Bergen
                                     1.82
                                     14.75
                                    346.29
                                    139.60
                                    502.47
Essex
                                     5.52
                                     12.93
                                    198.99
                                     75.20
                                    292.64
Hudson
                                     2.46
                                     10.05
                                    111.77
                                     35.70
                                    159.97
Passaic
                                     0.32
                                     6.52
                                    144.70
                                     42.30
                                    193.84
Union
                                     4.18
                                     8.31
                                    169.18
                                     53.60
                                    235.27
Total
                                     14.30
                                     52.56
                                    970.93
                                    346.50
                                   1,384.19


III.	CO Maintenance Area Monitor shut downs

INTRODUCTION

This Technical Support Document evaluates the State of New Jersey's formal revision to its carbon monoxide (CO) maintenance plan, in which New Jersey proposes to revise its State Implementation Plan (SIP) to permit the shutdown of the Burlington, Freehold, Morristown, Perth Amboy, and East Orange CO monitoring sites.  

BACKGROUND

On September 28, 1995, the State of New Jersey submitted a formal CO redesignation request for Camden County and the nine Not-Classified Areas in the State (the City of Atlantic City, the City of Burlington, the Borough of Freehold, the Town of Morristown, the Borough of Penns Grove, the City of Perth Amboy, the Borough of Somerville, the Toms River Area, and the City of Trenton).  On February 5, 1996 the U.S. EPA redesignated these areas to attainment for the CO NAAQS and approved New Jersey's 10 year maintenance plan for these areas (61 FR 33678).  In 2006, New Jersey submitted a second 10 year maintenance plan to show how these areas would continue to attain the CO standard for an additional 10 years.  This maintenance plan was a Limited Maintenance Plan.  This is a less restrictive plan since the areas met the requirement of having a CO design value equal to or less than 85% of the CO standard.  For additional information, the reader is referred to 71 FR 26895 and 71 FR 38770.  Since that time, there have been no violations of the CO NAAQS of 9 ppm (8 hour average) or 35 ppm (1 hour average) in these areas, and CO is trending downward to a level less than 1/3 the NAAQS (see Graph 1.)

In addition, on January 15, 2002, the State of New Jersey submitted a formal CO redesignation request for the New Jersey portion of the New York-Northern New Jersey-Long Island (NYNNJLI) CO area.  On October 22, 2002 the U.S. EPA redesignated this area to attainment for the CO NAAQS and approved New Jersey's 10 year maintenance plan for the area.  For additional information, the reader is referred to 67 FR 54601 and 67 FR 54574.  The accompanying Federal Register notice proposes to approve New Jersey's second 10 year maintenance plan showing how this area would continue to attain the CO standard for an additional 10 years.  This maintenance plan is a Limited Maintenance Plan.  This is a less restrictive plan since the areas met the requirement of having a CO design value equal to or less than 85% of the CO standard.  Since that first maintenance plan, there have been no violations of the CO NAAQS of 9 ppm (8 hour average) or 35 ppm (1 hour average) in that area, and CO is trending downward to a level less than 1/3 the NAAQS (see Graph 1).

On August 2, 2010, New Jersey submitted their "New Jersey Ambient Air Monitoring Network Assessment 2010" to EPA.  This document described New Jersey's ambient air monitoring network and also detailed proposed changes and the rationale for them.  In this document, New Jersey provided a site-by-site analysis used in order to perform their network assessment.  A scoring scheme and final network rankings were used to help New Jersey make modifications to their ambient air monitoring network. The reasoning behind these requested CO monitor shutdowns are included in that submittal.  On February 8, 2016, New Jersey submitted an addendum to their 2[nd] CO maintenance plan SIP requesting to also shut down their East Orange CO monitoring site.
EVALUATION OF NEW JERSEY'S SUBMITTAL

On June 11, 2015, the State of New Jersey submitted a formal revision to its SIP to shut down the Burlington, Freehold, Morristown, and Perth Amboy CO monitoring sites (see Figure 1).  These are "sole pollutant" sites, monitoring only CO.  The SIP revision consists of a modification to New Jersey's CO maintenance plan for these CO monitoring sites.  On February 8, 2016, the State of New Jersey submitted an addendum to their 2[nd] CO maintenance plan SIP requesting the shutdown of their East Orange CO monitoring site.

The New Jersey Department of Environmental Protection submittal explains that considerable resources are utilized each year to cover the lease agreements with the property owners, maintenance of the monitoring site and equipment, phone, electricity, travel to and from the sites from the main office in Trenton, and staff time to conduct routine and emergency maintenance.  The New Jersey Department of Environmental Protection asserts and EPA agrees that all of these resources could better be used elsewhere in the state's monitoring program. 

CO levels have been falling in Burlington, Freehold, Morristown, Perth Amboy, and East Orange since the early 1980s (see Figures 2  -  7.)  The NAAQS of 9 ppm (8 hour average) has not been violated since 1986, and current readings of the design value are in the 2 to 3 ppm range, and have been for the past three (3) years. Most of the CO reduction has been due to "fleet turnover," with newer, cleaner motor vehicles making up an increasing share of the fleet, and this trend is likely to continue in the future.

In addition to the downward trend shown by the monitoring data, the state performed mobile source modeling and conformity analyses which predict that winter time CO concentrations in Burlington, Freehold, Morristown, Perth Amboy, and East Orange will remain below the CO Conformity Budget levels out into the future (See Table 1).  The Burlington analysis extends to 2020 while the Freehold, Morristown, and Perth Amboy analysis extends to 2014.  In their addendum on February 8, 2016, New Jersey provided mobile source emission modeling and conformity analyses performed by the North Jersey Transportation Planning Authority which predicted that CO emissions in Bergen, Essex, Hudson, Passaic and Union counties will remain below the approved CO Conformity Budgets through 2040. (See Table 2).

To use its resources more prudently, and because of the low concentrations and downward CO trend, the state requests permission to cease monitoring for CO in Burlington, Freehold, Morristown, and Perth Amboy.  New Jersey DEP will continue monitoring for CO at the nearby Camden and Elizabeth Lab sites.  New Jersey DEP will use the Camden CO data as a surrogate for Burlington and will use the Elizabeth Lab CO data as a surrogate for Freehold, Morristown, Perth Amboy, and East Orange (See Figures 2  -  7 comparing CO levels in those groups of cities.  EPA notes that the five (5) other CO not classified maintenance areas (Somerville, Trenton, Penns Grove, Toms River, and Atlantic City) currently do not have CO monitoring sites.

In this SIP submittal, NJ is requesting that EPA modify a portion of the federally approved New Jersey CO maintenance plan.  That approved maintenance plan obligates the State to select a contingency threshold or `trigger,' such as a monitored CO exceedance or violation, and commit to implementing the appropriate contingency measure once the threshold is exceeded.  This modification is an additional trigger that will cause NJ to re-establish their shutdown sites in the event that a surrogate site exceeds 75% of either of the CO standards twice in 1 calendar year, as outlined below.

What happens if the modified (75%) contingency trigger is exceeded at a surrogate site?

 In the event the second-highest CO concentration in any calendar year, as monitored at the Camden site, reaches 75 percent of either the federal 1-hour or 8-hour NAAQS for CO, New Jersey will, within 9 months of recording such concentrations, re-establish a CO monitoring site in Burlington consistent with EPA siting criteria, and resume analyzing and reporting those data.

 In the event the second-highest CO concentration in any calendar year, as monitored at the Elizabeth Lab site, reaches 75 percent of either the federal 1-hour or 8-hour NAAQS for CO, New Jersey will, within 9 months of recording such concentrations, re-establish CO monitoring sites in Freehold, Morristown, Perth Amboy, and East Orange consistent with EPA siting criteria, and resume analyzing and reporting those data.

What happens is there is a violation of the CO standard at any site?

In addition to the re-establishing of the shutdown sites:

 New Jersey is proposing to implement its contingency program for Burlington in the event that a CO violation of either the federal 1-hour or 8-hour NAAQS is monitored at the Camden site in any year during the 1996  -  2016 maintenance period and to consider one or more of the other EPA-approved measures if necessary.

 New Jersey is proposing to implement its contingency program for Freehold, Morristown, Perth Amboy, and East Orange in the event that a CO violation of either the federal 1-hour or 8-hour NAAQS is monitored at the Elizabeth Lab site in any year during the 1996  -  2016 maintenance period and to consider one or more of the other EPA-approved measures if necessary.

 New Jersey will also continue to commit to implement its contingency program at the surrogate sites in the event that a CO violation is monitored at any of the re-established monitoring sites at any time during the 1996  -  2016 maintenance period, and to consider one or more of the other EPA-approved measures listed in their contingency plan if necessary to reduce CO levels.

When implementing contingency measures, New Jersey will review and implement the measures necessary to remedy the violation, including transportation control measures (TCM), and other additional vehicle or fuel controls.  These measures will remain in effect until the CO monitors in question show that the areas are in attainment of the CO standards.

 CONCLUSION

The State of New Jersey submitted a formal revision to its SIP to shut down the Burlington, Freehold, Morristown, and Perth Amboy CO monitoring sites.  These sites only monitor CO.  The State also submitted a formal revision to its 2[nd] maintenance plan SIP to shut down the East Orange CO monitoring site.  These SIP revisions consist of a modification to New Jersey's CO maintenance plan for these CO monitoring sites.  EPA concurs that NJDEP's proposal to shutdown CO monitors in certain CO maintenance areas is sufficiently supported by the following reasons:
 CO concentrations have continuously decreased over the past 25 years,
 Mobile source emissions, the major contributor to ambient concentrations of CO, are projected to continue to decrease as cleaner cars replace older vehicles, and
 New Jersey committed to reestablish these monitoring sites if CO concentrations are measured at concentrations over 75% of the existing standard.

EPA agrees that New Jersey DEP's proposal represents a reasonable plan modification and approach for shutting down specific CO monitors that are currently measuring concentrations well below the existing 1- hour and 8- hour CO NAAQS.  The alternative method that New Jersey adopted as a contingency triggering mechanism is an appropriate part of its CO maintenance plan.  Under these revised plans, EPA believes air quality goals will be maintained, and State monitoring resources conserved.

SIP Revision Recommendation:  Approval

                                  ATTACHMENTS

                                   Figure 1.


                                   Figure 2.
                                       
                            All NJ CO Monitor Sites




                                   Figure 3.
                                       
                Camden CO site surrogate for Burlington CO site





                                   Figure 4.
                                       
             Elizabeth Lab CO site surrogate for Freehold CO site






                                   Figure 5.
                                       
            Elizabeth Lab CO site surrogate for Morristown CO site






                                   Figure 6.
                                       
            Elizabeth Lab CO site surrogate for Perth Amboy CO site






                                   Figure 7.
                                       
                                       

                                       
                                       


                                   Table 1.
                                       
                 Carbon Monoxide Emissions from Mobile Sources
                                       
The following CO budgets were approved on February 5, 1996 when the U.S. EPA redesignated these areas to attainment for the CO NAAQS and approved New Jersey's 10 year maintenance plan for these areas (61 FR 33678).


                                Burlington City
Year
VMT
CO Emissions (tons/day)
CO Budget (tons/day)
2007
12,209,000
154.90
170.43
2010
12,540,100
135.93
170.43
2020
13,788,500
119.12
170.43

Source: Transportation Conformity of the DVRPC FY 2007 Transportation Improvement Programs and the Destination 2030 Long Range Transportation Plan, May 2006


                                  Perth Amboy
Year
VMT
CO Emissions (tons/day)
CO Budget (tons/day)
2007
17,485,354
244.59
244.99
2014
19,814,012
203.95
244.99

                                   Freehold
Year
VMT
CO Emissions (tons/day)
CO Budget (tons/day)
2007
15,703,237
219.68
231.55
2014
16,418,941
169.52
231.55

                                  Morristown
Year
VMT
CO Emissions (tons/day)
CO Budget (tons/day)
2007
14,735,071
209.88
244.05
2014
15,591,325
162.57
244.05

Source: The Northern New Jersey Air Quality Conformity Determination of the 2005 Regional Transportation Plan and the FY 2007-2010 Transportation Improvement Program, June 2006






                                   Table 2.
                                       
      Carbon Monoxide (CO) Budget for Bergen, Essex, Hudson, Passaic, and
                                 Union Counties

YEAR
PROJECTED DAILY VMT
PROJECTED CO EMISSIONS (tons/day)
CO BUDGET (tons/day)
2015
59,953,733
362
899
2025
64,285,191
204
899
2030
66,566,894
160
899
2040
71,376,130
131
899

