Technical Support Document (TSD) For 

Emissions Inventories for the Richmond, Virginia  

8 Hour Ozone Redesignation Request, Maintenance Plan, and,

State Implementation Plan (SIP) Base Year Inventory.

	

Submitted September 2006 by the Virginia

Department of Environmental Quality

TSD Prepared February 2007 by

Janet C. Kremer

Air Quality Analysis Branch, 3AP22

U.S. Environmental Protection Agency, Region 3

1650 Arch Street

Philadelphia, Pennsylvania 19103

					/s/

____________________________________________

Reviewed by Walter Wilkie, Chief

Air Quality Analysis Branch (3AP22)

2/28/07

_________________

Date Signed

I	Introduction

The purpose of this document is to provide a technical summary of the
Air Quality Analysis Branch’s (AQAB) review of the emissions
inventories submitted with the Richmond, Virginia 8 Hour Ozone
Redesignation Request, Maintenance Plan and State Implementation Plan
(SIP) Base Year Inventory by the Commonwealth of Virginia Department of
Environmental Quality (VaDEQ).  This review does not determine the
approvability of the Redesignation Request or Maintenance Plan; but it
does determine the approvability of the SIP Base Year Inventory. 
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. 
A SIP Base Year Inventory is 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 of an emissions
reduction credit program.  The Richmond area was designated as an 8 hour
ozone nonattainment area with a Subpart 2 classification.  Subpart 2
areas were required to submit SIP base year inventories to EPA as of
June 15, 2006.  It is for this reason that VaDEQ included this SIP base
year submission with the redesignation request and maintenance plan
package and has requested EPA’s approval.

Any questions pertaining to this technical summary should be directed to
Walter K. Wilkie, Chief, Air Quality Analysis Branch, at 215-814-2150 or
via email at   HYPERLINK "mailto:wilkie.walter@epa.gov" 
wilkie.walter@epa.gov . 

II 	Emissions Inventories for Redesignation Request (Base Year
Inventory)

	In a redesignation request, emissions inventories are used to support
the States claim that the area has 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 “base year” inventory. The
base year inventory contains VOC and NOx emissions for all source
categories, which includes point, area, onroad mobile, and nonroad
mobile for the ozone season.

In the Richmond redesignation request, the base year used was 2002.  The
Point Source data for 2002 is obtained from the VaDEQ’s Comprehensive
Environmental Data System (CEDS).  The CEDS is comprised of sources
permitted and/or registered with the VaDEQ.  The emissions for these
sources are updated annually by collecting year-specific emissions
and/or activity level information.  Data collected from the sources
involved is entered into the agency data system as annual air pollutant
emissions estimates.  These estimates are based on a number of
acceptable estimation methods including continuous emissions monitors
(CEM), source specific testing, emissions factors, and other methods. 
The annual estimates are converted into typical summer weekday emissions
using standard internal calculation routines in the CEDS system.  For
its redesignation request, VaDEQ provided its 2002 actual summer weekday
emissions for NOx, VOC, and CO at the facility level and by Source
Identification Codes (SICs).  

For the 2002 Nonpoint Source emissions, also known as “area
sources”, VaDEQ provided emissions estimates for each source category
at the county level.  For each source category Virginia DEQ obtained
activity data, and then applied appropriate emission factors, fuel
loading factors, and other factors and adjustments as necessary.  

The Nonroad Mobile Source 2002 inventory was prepared with EPA’s
NONROAD2005 model.  NONROAD estimates fuel consumption and emissions of
total hydrocarbons, carbon monoxide, nitrogen oxides, sulfur dioxide,
and particulate matter for all nonroad mobile source categories except
for aircraft, locomotives, and commercial marine vessels (CMV).  VaDEQ
provided a list of the inputs used in their Nonroad model runs.  VaDEQ
provided emission estimates for locomotive engines and aircraft
emissions separately.  Locomotive engine emissions are based on the
amount of fuel consumed in an inventory area and an emission factor for
the pollutant being inventoried.  For aircraft emissions, VaDEQ obtained
2002 activity data for Virginia airports from the Virginia Department of
Aviation, the Federal Aviation Administration and in some cases, from
certain individual airports. The number of Landing/Takeoff cycles was
multiplied by a per/LTO emission factors.  Nonroad mobile source
emissions were provided for a typical summer weekday by SCC and
classification.

The Onroad Mobile Source 2002 emissions inventory was developed using
the most current version of EPA’s highway mobile source emissions
model MOBILE 6.2.  Up to date inputs for the model were used including
the following: The Virginia Department of Motor Vehicles (DMV) provided
statewide registration data and the Virginia Department of
Transportation (VDOT) provided VaDEQ with jurisdictional, road-specific,
average summer weekday VMT and speed data.  VaDEQ provided Mobile6.2
input and output files for review with the redesignation request. 
Mobile emissions values were given in units of tons per summer day.

AQAB staff reviewed the files and the emission results provided by VaDEQ
and found them to be reasonable for use in this redesignation request.

III.	Emissions Inventories for Maintenance Plan

2005 Attainment Year Inventory and Maintenance Plan Base Year Inventory

As stated earlier, emissions inventories are used to show emission
reductions for the area between the year of designation to nonattainment
and the year of attainment.  The inventory used for the year of
attainment 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.  This section will discuss the 2005
Attainment Year Inventory that was used in the Richmond Redesignation
Request and Maintenance Plan submitted by VaDEQ.

Since an actual 2005 emissions inventory for point sources had not been
completed at the time VaDEQ compiled the data for this request, the 2005
inventory was compiled using the following procedure.  Where available,
NOx emission values based on CEM data were used.  For all other
pollutants, the actual 2002 emissions inventory was used as a starting
point and then projected to 2005 using the latest versions of EPA’s
Economic Growth Analysis System (EGAS 5.0).  The model produces facility
or process (SCC) level emissions growth factors based on national and
regional economic models.  The 2005 growth factors derived from EGAS
were then applied to the 2002 emissions to come up with 2005 emissions. 
VaDEQ provided the 2005 point source inventory by SCC for a typical
summer day.

For the 2005 Nonpoint Source emissions, VaDEQ provided a projected
inventory based on the 2002 inventory.  Growth factors were developed
using EGAS 5.0 and applied to the 2002 Area Source inventory.  The
emissions were by SCC and the units were in tons per summer day.

For the 2005 NonRoad Mobile Source emissions, VaDEQ provided an
inventory that was developed using EPA’s NONROAD2005 model.    The
NONROAD model estimates fuel consumption and emissions of total
hydrocarbons, carbon monoxide, nitrogen oxides, sulfur dioxide, and
particulate matter for all nonroad mobile source categories except for
aircraft, locomotives, and commercial marine vessels (CMV).  VaDEQ
provided a list of the inputs used in their Nonroad model runs. All
nonroad mobile emissions were calculated for a typical summer weekday. 
For those categories not estimated in the NONROAD model, a different
approach was used.  The 2002 base year inventory was used to forcast the
2005 current attainment year emissions inventory using growth factors
generated by EGAS 5.0.  The growth factors generated are applied to the
2002 emissions inventory to develop 2005 emissions.  These emissions
were provided in units of tons per typical summer day. 

The Onroad Mobile Source 2005 emissions inventory was developed using
the most current version of EPA’s highway mobile source emissions
model MOBILE 6.2.  Up to date inputs for the model were used including
the following: The Virginia Department of Motor Vehicles (DMV) provided
statewide registration data for 2005 and the Virginia Department of
Transportation (VDOT) provided VaDEQ with jurisdictional, road-specific,
average summer weekday VMT and speed data for 2005.  VaDEQ provided
Mobile6.2 input and output files for review with the redesignation
request.  Mobile emissions values were given in units of tons per summer
day.

AQAB staff reviewed the files and the emission results provided by VaDEQ
and found them to be reasonable for use in this redesignation request.

2011 and 2018 Projection Emission Inventories

Projection inventories are used to show that the area will remain in
attainment.  Projection inventories for the years 2011 and 2018 were
used for the Richmond Maintenance Plan.  Inventories were developed for
all emission sources for both years.

Point source inventories for 2011 and 2018 were developed using EPA’s
EGAS 5.0 model.  Specific SCC level growth factors for the years 2011
and 2018 were derived with 2002 as the base year and then applied to the
2002 emissions inventory.  Growth factors were also developed with 2005
as the base year applicable to cases for which NOx emissions are
available for the year 2005.  VaDEQ provided emissions at SCC level in
units of tons per typical summer day.

For the 2011 and 2018 Nonpoint Source emissions, VaDEQ provided a
projected inventory based on the 2002 inventory.  Growth factors were
developed using EGAS 5.0 and applied to the 2002 Area Source inventory. 
The emissions were by SCC and the units were in tons per summer day.

For the 2011 and 2018 NonRoad Mobile Source emissions, VaDEQ provided an
inventory that was developed using EPA’s NONROAD2005 model.    The
NONROAD model estimates fuel consumption and emissions of total
hydrocarbons, carbon monoxide, nitrogen oxides, sulfur dioxide, and
particulate matter for all nonroad mobile source categories except for
aircraft, locomotives, and commercial marine vessels (CMV).  VaDEQ
provided a list of the inputs used in their Nonroad model runs. All
nonroad mobile emissions were calculated for a typical summer weekday. 
For those categories not estimated in the NONROAD model, a different
approach was used.  The 2002 base year inventory was used to forcast the
2011 and 2018 emissions inventories using growth factors generated by
EGAS 5.0.  The growth factors generated are applied to the 2002
emissions inventory to develop 2011 and 2018 emissions.  These emissions
were provided in units of tons per typical summer day. 

The Onroad Mobile Source 2011 and 2018 emissions inventories were
developed using the most current version of EPA’s highway mobile
source emissions model MOBILE 6.2.  Up to date inputs for the model were
used including the following:  2005 input parameters such as VMT,
speeds, and registration data were used to develop the 2011 and 2018
future year inventories.  VMT was grown for future year projections by
multiplying the 2005 attainment year VMT by the respective growth rate
compounded annually for each road type.  Mobile emissions values were
given in units of tons per summer day.

AQAB staff reviewed the files and the emission results provided by VaDEQ
and found them to be reasonable for use in this redesignation request.

IV.	2002 SIP Base Year Inventory

	The base year inventory is the primary inventory 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 inventory includes emissions estimates from
stationary point and nonpoint sources, onroad mobile sources, and
nonroad mobile sources.  For the 8-hour ozone NAAQS, the pollutants to
be inventoried are VOC, NOx and CO (carbon monoxide).  For the 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 during the ozone season). 
VADEQ’s base year inventory is for 2002.  A significant amount of
documentation is required for these SIP base year estimates which VaDEQ
has provided.  

In the case of the Richmond area, it was designated as an 8 hour ozone
nonattainment area with a Subpart 2 classification.  Subpart 2 areas
were required to submit SIP base year inventories to EPA as of June 15,
2006.  VaDEQ’s redesignation request and maintenance plan was
submitted to EPA after the June 15, 2006 deadline for the Subpart 2 SIP
base year inventory submittal.  It is for this reason that VaDEQ
included this SIP base year submission with its redesignation request
and maintenance plan package and has requested EPA’s approval.

	VaDEQ’s methodologies concerning the generation of point, nonpoint,
onroad mobile and nonroad mobile emissions for the SIP base year are the
same as for the 2002 base year redesignation request.  However, EPA
guidance required, in addition to the NOx and VOC summer day emissions,
annual emissions for NOx and VOCs.  Further, the EPA guidance required
annual and summer day estimates for CO.  

	VaDEQ also applied rule effectiveness (RE) for its 2002 8-hour ozone
SIP base year inventories.  Rule effectiveness reflects the actual
ability of a regulatory program to achieve the emission reductions
required by regulation (or perhaps voluntarily adopted).  VaDEQ’s
approach to RE for point sources in the collection of emissions
inventory data is to collect and utilize facility specific data to make
RE determinations.  In cases where sources have submitted one or more
deviation and/or malfunction reports, the RE of 80% is applied.  RE are
contained in source specific estimates of “actual” emissions and
certification process described in VaDEQs documentation.    

AQAB staff reviewed the results, procedures, and methodologies for the
SIP base year, and found them to be approvable.  The following table
summarizes VaDEQ’s 2002 SIP Base Year.

Richmond, 2002 SIP Base Year













 	VOC Emissions	NOx Emissions	CO Emissions

Source Type	Tons/yr	Tons/day	Tons/yr	Tons/day	Tons/year	Tons/day

Point Sources	8188	28	34664	121	6405	23

Nonpoint Sources	19538	51	7460	20	19402	20

Onroad Mobile Sources	18070	50	26777	74	263136	638

Nonroad Mobile Sources	6631	24	8415	25	78532	272

TOTAL Emissions	52427	159	77316	240	367475	967



 “Emissions Inventory Guidance for Implementation of Ozone and
Particulate Matter National Ambient Air Quality Standards (NAAQS) and
Regional Haze Regulations” EPA-454/R-05-001, August 2005

