UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

	1650 Arch Street

	Philadelphia, Pennsylvania  19103

DATE:	October 24, 2011

SUBJECT:	   Technical Support Document -  Pennsylvania; Attainment Plan
for the     Pennsylvania Portion of the Philadelphia-Wilmington,
Pennsylvania-New Jersey- Delaware 1997 Fine Particulate Matter
Nonattainment Area

				/s/

FROM:	Rose Quinto, Environmental Engineer

Office of Air Program Planning 

TO:		File

			 	/s/

THRU: 	Cristina Fernandez, Associate Director

		Office of Air Program Planning

This document provides a technical review of a revision to the
Pennsylvania State Implementation Plan (SIP) submitted by the
Pennsylvania Department of the Environmental Protection (PADEP) on April
12, 2010.  This SIP revision addresses the attainment plan of the 1997
annual fine particulate matter (PM2.5) national ambient air quality
standard (NAAQS) for the Pennsylvania portion of the
Philadelphia-Wilmington, Pennsylvania-New Jersey-Delaware (PA-NJ-DE)
nonattainment area (Philadelphia area).  The attainment plan includes
Philadelphia area’s attainment demonstration, motor vehicle emission
budgets (MVEBs) used for transportation conformity purposes, an analysis
of reasonably available control measures (RACM) and reasonably available
control technology (RACT), base year emissions inventory, and
contingency measures.  

A.  BACKGROUND

I.  Designation History

	On July 18, 1997 (62 FR 36852), the Environmental Protection Agency
(EPA) established the 1997 PM2.5 NAAQS, including an annual standard of
15.0 micrograms per cubic meter (g/m3) based on a 3-year average of
annual mean PM2.5 concentrations and a 24-hour (or daily) standard of 65
g/m3 based on a 3-year average of the 98th percentile of 24-hour
concentrations.  EPA established the standards based on significant
evidence and numerous health studies demonstrating that serious health
effects are associated with exposures to PM2.5. 

	

Following promulgation of a new or revised NAAQS, EPA is required by the
Clean Air Act (CAA) to designate areas throughout the United States as
attaining or not attaining the NAAQS;  this designation process is
described in section 107(d)(1) of the CAA.  In 1999, EPA and State Air
Quality Agencies initiated the monitoring process for the 1997 PM2.5
NAAQS and by January 2001, established a complete set of air quality
monitors.  On January 5, 2005 (70 FR 944), EPA promulgated initial air
quality designations for the 1997 PM2.5 NAAQS based on air quality
monitoring data for calendar years 2001-2003.

On April 14, 2005 (70 FR 19844), EPA promulgated a supplemental rule
amending the Agency’s initial designations, with the same effective
date (April 15, 2005) as 70 FR 944.  As a result of this supplemental
rule, PM2.5 nonattainment designations are in effect for 39 areas,
comprising 208 counties within 20 States (and the District of Columbia)
nationwide, with a combined population of about 88 million.  The
Pennsylvania portion of the Philadelphia area is included in the list of
areas not attaining the 1997 PM2.5 NAAQS.  The Pennsylvania portion of
the Philadelphia area consists of the following counties:  Bucks,
Chester, Delaware, Montgomery, and Philadelphia.

	It should be noted that on November 13, 2009 (74 FR 58688), EPA revised
the existing designation tables in 40 CFR part 81.339 to clarify that
the 1997 designations were for both the annual PM2.5 NAAQS and the
24-hour PM2.5 NAAQS.  The Pennsylvania portion of the Philadelphia area
was designated unclassifiable/attainment for the 24-hour PM2.5 NAAQS.

		

II.  Clean Air Fine Particle Implementation Rule

	On April 25, 2007 (72 FR 20586), EPA issued the Clean Air Fine Particle
Implementation Rule for the 1997 PM2.5 NAAQS.  The “PM2.5
Implementation Rule” describes the CAA framework and requirements for
developing SIPs for areas designated nonattainment for the 1997 PM2.5
NAAQS (attainment plans).  An attainment plan must include a
demonstration that a nonattainment area will meet the applicable NAAQS
within the time provided in the statute.  This demonstration must
include modeling (40 CFR 51.1007) that is performed in accordance with
EPA modeling guidance (EPA-454/B-07-002, April 2007).  It must also
include supporting technical analyses and descriptions of all relevant
adopted Federal, state, and local regulations and control measures that
have been adopted in order to provide attainment by the proposed
attainment date.  

	For the 1997 PM2.5 NAAQS, an attainment plan must show that a
nonattainment area will attain the 1997 PM2.5 NAAQS as expeditiously as
practicable, but within five years of designation (i.e. attainment date
of April 2010 based on air quality data for 2007-2009).  If the area is
not expected to meet the NAAQS by April 2010, a state may request to
extent the attainment date by one to five years based on the severity of
the nonattainment problem or the feasibility of implementing control
measures (CAA section 172(a)(2)) in the specific area.  For EPA to
approve an extension of the attainment date beyond 2010, the state must
provide an analysis to support the request and demonstrate that the
attainment date is as expeditious as practicable for the area given the
facts and circumstances of the area and consistent with the statutory
criteria for an extension.

	For each nonattainment area, the state must demonstrate that it has
adopted all RACM, including all RACT as needed to provide for attainment
of the PM2.5 standards in the area “as expeditiously as
practicable.”  The PM2.5 Implementation Rule provides guidance for
making these RACM and RACT determinations.  Any measures that are
necessary to meet these requirements which are not already either
Federally promulgated or in an EPA-approved part of the SIP must be
submitted as part of the state’s attainment plan.  Any state measures
must meet the applicable statutory and regulatory requirements, and in
particular, must be Federally enforceable.

	The PM2.5 Implementation Rule also includes guidance on pollutants that
states must address in their attainment demonstrations.  Section 302(g)
of the CAA authorizes EPA to regulate criteria pollutants and their
precursors.  In the case of PM2.5, the main chemical precursors are
sulfur dioxide (SO2), nitrogen oxides (NOx), ammonia (NH3), and volatile
organic compounds (VOCs).  The effect of reducing emissions of precursor
pollutants that contribute to PM2.5 concentrations varies by area,
however, depending on PM2.5 composition, emission levels, and other
area-specific factors.  For this reason, the PM2.5 Implementation Rule
provided guidance recommending that states elect direct PM2.5 emissions
and the precursor that would be most effective for attaining the NAAQS
within the specific area, based upon an appropriate technical
demonstration.

	In accordance with the PM2.5 Implementation Rule, direct PM2.5
emissions means “solid particles emitted directly from an air
emissions source or activity, or gaseous emissions or liquid droplets
from an air emissions source or activity which condense to form
particulate matter at ambient temperatures.  Direct PM2.5 emissions
include elemental carbon, directly emitted organic carbon, directly
emitted sulfate, directly emitted nitrate, and other inorganic particles
(including but not limited to crustal material, metals, and sea
salt).”

The PM2.5 Implementation Rule requires all states to address SO2 as a
PM2.5 attainment plan precursor and to evaluate SO2 for possible control
measures in all PM2.5 nonattainment areas.  States are also required to
address NOX as a PM2.5 attainment plan precursor and evaluate reasonable
controls for NOX in PM2.5 attainment plans, unless the state and EPA
make a finding that NOX emissions from sources in the state do not
significantly contribute to PM2.5 concentrations in the relevant
nonattainment area.

Although current scientific information shows that certain VOC emissions
are precursors to the formation of secondary organic aerosol, and
significant progress has been made in understanding the role of gaseous
organic material in the formation of organic PM, this relationship
remains complex.  Further research and technical tools are needed to
better characterize emissions inventories for specific VOC compounds and
to determine the extent of the contribution of specific VOC compounds to
organic PM mass.  Because of these factors, the PM2.5 Implementation
Rule did not require states to address VOCs as PM2.5 attainment plan
precursors and evaluate them for control measures, unless the State or
EPA makes a finding that VOCs significantly contribute to a PM2.5
nonattainment problem in the state or to other downwind air quality
concerns.

The PM2.5 Implementation Rule describes the formation of particles
related to NH3 emissions, which is a complex, nonlinear process.  Though
recent studies have improved our understanding of the role of NH3 in
aerosol formation, ongoing research is needed to better describe the
relationships between NH3 emissions, particulate matter concentrations,
and related impacts. Also, area specific data are needed to evaluate the
effectiveness of reducing NH3 emissions on reducing PM2.5 concentrations
in different areas, and to determine where NH3 decreases may increase
the acidity of particles and precipitation.  For these reasons, in the
PM2.5 Implementation Rule, NH3 is presumed not to be a PM2.5 attainment
plan precursor, meaning that the state is not required to address NH3 in
its attainment plan or evaluate sources of NH3 emissions for reduction
measures, unless the state or EPA makes a finding that NH3 significantly
contributes to a PM2.5 nonattainment problem in the area or to other
downwind air quality concerns.

The presumptive inclusion of NOX and the presumptive exclusion of VOC
and NH3 as attainment plan precursors can be reversed based on an
acceptable technical demonstration for a particular area by the state or
EPA.  Such a demonstration should include information from multiple
sources, including results of speciation data analyses, air quality
modeling studies, chemical tracer studies, emission inventories, or
special intensive measurement studies to evaluate specific atmospheric
chemistry in an area (See PM2.5 Implementation Rule for more
information).

The PM2.5 Implementation Rule also provided guidance on other elements
of a state’s attainment plan, including, but not limited to,
consideration of emission inventories, contingency measures, and MVEBs
used for transportation conformity purposes.

There are, however, three aspects of the PM2.5 Implementation Rule for
which EPA received petitions requesting reconsideration.  These pertain
to the presumption or advance determination that compliance with the
requirements of the Clean Air Interstate Rule (CAIR) automatically
satisfies the requirements for RACT or RACM for NOx or SO2 emissions
from electric generating unit (EGU) sources participating in regional
cap and trade programs; the suggestion in the preamble that the economic
feasibility element of a RACT determination for EGUs should include
consideration of  whether the cost of a measure is reasonable in light
of the benefits; and the policy described in the preamble of allowing
certain emissions reductions from outside the nonattainment area to be
credited as meeting the RFP requirement.  EPA is granting these
petitions and intends to undertake rulemaking to change these aspects of
the PM2.5 Implementation Rule.  The attainment plan for the Pennsylvania
portion of the Philadelphia area did not rely on any of these aspects of
the rule.

III.  Attaining Data Determination and Finding of Attainment

The data in Table 1 indicates that the Pennsylvania portion of the
Philadelphia area is meeting the 1997 annual PM2.5 NAAQS.  In addition,
Table 2 shows that the Philadelphia area continues to attain the 1997
annual PM2.5 NAAQS by 2010.  More detailed information can be found in a
technical support document (TSD), entitled “Technical Support Document
for the Modeling Portion of the Commonwealth of Pennsylvania’s Fine
Particulate Matter State Implementation Plan,” dated October 11, 2011,
available on line at   HYPERLINK "http://www.regulations.gov" 
www.regulations.gov , Docket No. EPA-R03-OAR-2010-0391.  However, this
action does not determine that the Pennsylvania portion of the
Philadelphia area has attained the 1997 annual PM2.5 NAAQS and the
information is included here only to support the Pennsylvania’s
demonstration that the Pennsylvania portion of the Philadelphia area
could meet the attainment date of April 5, 2010, and continues to attain
based on the most recent data available.  EPA plans to take action to
formally determine the Pennsylvania portion of the Philadelphia area’s
attainment of the 1997 annual PM2.5 NAAQS in a separate action.

Table 1.  2009 Annual Averaged PM2.5 Design Value

County	Site Name	Site Number	Design Value (µg/m3)

Bucks	Bristol	420170012	12.1

Chester	New Garden	420290100	12.4

Delaware	Chester	420450002	13.3

Montgomery	Norristown	420910013	11.3

Philadelphia	AMS Lab	421010004	12.9

Philadelphia	NE Airport	421010024	11.9

Philadelphia	Broad Street	421010047	13.5

Philadelphia	Elmwood	421010136	12.7



Table 2.  2008-2010 Monitored Annual Design Values

County	Site Name	Site Number	Design Value (µg/m3)



	2008	2009	2010

Bucks	Bristol	420170012	12.6	12.2	11.3

Chester	New Garden	420290100	13.4	13.9	13.8

Delaware	Chester	420450002	14.1	13.7	13.1

Montgomery	Norristown	420910013	12.3	11.7	10.5

Philadelphia	AMS Lab	421010004	13.4 	12.5	11.5

Philadelphia	NE Airport	421010024	12.4	11.5	10.5

Philadelphia	Broad Street	421010047	14.5 	13.0	11.9

Philadelphia	Elmwood	421010136	13.2	13.3

	

B.  COMPONENTS OF PENNSYLVANIA’S ATTAINMENT PLAN

	In accordance with section 172(c) of the CAA and the PM2.5
Implementation Rule, the attainment plan submitted on April 12, 2010 by
PADEP for the Pennsylvania portion of the Philadelphia area included: 
(1) an emissions inventory for the plan’s base year (2002); (2) an
attainment demonstration; and (3) MVEBs for the attainment year.  The
attainment demonstration includes:  (a) technical analyses that locate,
identify, and quantify sources of emissions contributing to violations
of the 1997 annual PM2.5 NAAQS; (b) analyses of future year emissions
reductions and air quality improvements expected to result from national
and local programs from new measures to meet RACM/RACT; (c) adopted
emission reduction measures with schedules for implementation; and (d)
contingency measures for NOx and SO2 to be implemented if the area did
not meet RFP or did not attain the standard by the attainment date.  

	To analyze future year emissions reductions and air quality
improvements, Pennsylvania used local, regional, and national modeling
analyses that have been developed to support Federal and local emission
reduction programs.  This modeling was performed in accordance with
EPA’s “Guidance on the Use of Models and Other Analyses for
Determining Attainment of Air Quality Goals for Ozone, PM2.5, and
Regional Haze” (EPA-454/B-07-002, April 2007).  

C.  EPA’S REVIEW AND TECHNICAL INFORMATION

The following EPA analysis of the PM2.5 attainment plan for the
Pennsylvania portion of the Philadelphia area, addresses all required
elements of a PM2.5 attainment plan as described in the PM2.5
Implementation Rule (72 FR 20586). 

  

I.  Pollutants Addressed 

In accordance with policies described in the PM2.5 Implementation Rule,
Pennsylvania’s PM2.5 attainment plan evaluates emissions of direct
PM2.5, SO2, and NOx in the Pennsylvania portion of the Philadelphia
area.  Because of uncertainties regarding NH3 emission inventories and
the efficacy of ammonia control technologies as noted earlier in this
notice, the final rule sets forth the presumption that NH3 is not a
PM2.5 precursor and that the states are not required to address NH3 in
their attainment plan.  Similarly, VOC emissions are presumed not to be
an attainment plan precursor because of uncertainties regarding the role
of VOC in secondary organic aerosol formation.  Pennsylvania’s
attainment plan does not reverse this presumption.

II.  Emissions Inventory Requirements

Section 172(c)(3) of the CAA requires states to develop emissions
inventories of point, area, onroad mobile, and nonroad mobile sources
for their attainment demonstrations.  These inventories provide a
detailed accounting of all emissions and emissions sources by precursor
or pollutant.  In addition, inventories are used to model air quality to
demonstrate that attainment of the 1997 PM2.5 NAAQS as expeditiously as
practicable, and if an attainment extension beyond 2010 is needed to
support the need for such an extension.  Emissions inventory guidance
was provided in the April 1999 document “Emissions Inventory Guidance
for Implementation of Ozone and Particulate Matter NAAQS and Regional
Haze Regulations,” (EPA–454/R–99–006), which was updated in
November 2005 (EPA–454/R–05–001).  Emissions reporting
requirements were provided in the 2002 Consolidated Emissions Reporting
Rule (CERR) (67 FR 39602).  On December 17, 2008 (73 FR 76539), EPA
promulgated the Air Emissions Reporting Requirements (AERR) to update
emissions reporting requirements in the CERR, and to harmonize,
consolidate and simplify data reporting by states.

In accordance with the AERR and the November 2005 guidance, the PM2.5
Implementation Rule required states to submit inventory information on
directly emitted PM2.5 and PM2.5 precursors and any additional inventory
information needed to support an attainment demonstration.

PM2.5 is comprised of filterable and condensable emissions.  Condensable
particulate matter (CPM) can comprise a significant percentage of direct
PM2.5 emissions from certain sources, and are required to be included in
national emission inventories based on emission factors.  Test Methods
201A and 202 are available for source-specific measurement of
condensable emissions.  However, the PM2.5 Implementation Rule
acknowledged that there were issues and concerns related to availability
and implementation of these test methods as well as uncertainties in
existing data for condensable PM2.5.  In recognition of these concerns,
EPA established a transition period during which EPA could assess
possible revisions to available test methods and to allow time for
States to update emissions inventories as needed to address direct
PM2.5, including condensable emissions.  Because of the time required
for this assessment, EPA recognized that States would be limited in how
to effectively address CPM emissions, and established a period of
transition, up to January 1, 2011, during which State submissions for
PM2.5 were not required to address CPM emissions.  Amendments to these
test methods were proposed on March 25, 2009 (74 FR 12969), and
finalized on December 21, 2010 (75 FR 80118).  The amendments to Method
201A added a particle-sizing device for PM2.5 sampling, and the
amendments to Method 202 revised the sample collection and recovery
procedures of the method to reduce the formation of reaction artifacts
that could lead to inaccurate measurements of CPM emissions.   

	The period of transition for establishing emissions limits for
condensable direct PM2.5 ended on January 1, 2011.  PM2.5 submissions
made during the transition period are not required to address CPM
emissions; however, States must address the control of direct PM2.5
emissions, including condensable emissions, with any new action taken
after this January 1, 2011.  Pennsylvania submitted the Pennsylvania
portion of the Philadelphia area attainment plan prior to January 1,
2011 and did not consider condensables. 

In July 2008, EarthJustice filed a petition requesting reconsideration
of EPA's transition period for CPM emissions provided in the PM2.5
Implementation Rule.  In January 2009, EPA decided to allow states that
have not previously addressed CPM to continue to exclude CPM for PSD
permitting during the transition period.  Today’s action reflects a
review of Pennsylvania’s submittal based on current EPA guidance as
described in the PM2.5 Implementation Rule.  More information and the
review and evaluation of the methods used for the emissions inventory
submitted by Pennsylvania are found in section III of Pennsylvania’s
attainment plan submittal and a TSD entitled, “Technical Support
Document for the Pennsylvania Portion of the Philadelphia-Wilmington,
PA-NJ-DE PM2.5 Noanattainment Area:  State Implementation Plan
Attainment Demonstration and Base Year Inventory,” dated October 11,
2011.

2002 Base Year Emission Inventories

An emission inventory is an estimate of the emissions from sources in a
particular area.  PADEP developed an emission inventory for 2002, which
is the base year for attainment planning purposes with respect to 8-hour
ozone and PM2.5 SIPs and for planning purposes with respect to the
regional haze SIPs.  The 2002 base year inventory includes the
pollutants PM10, PM2.5, SO2, NOx, VOC, and NH3.  The inventory consists
of four sectors:  stationary point sources, stationary area sources,
highway vehicle sources and nonroad sources.  The Mid-Atlantic/Northeast
Visibility Union (MANE-VU) compiled a regional inventory from the
emission inventories of the Northeastern and Mid-Atlantic states.  This
regional inventory was used to perform the regional modeling analysis
used in the Pennsylvania’s air quality management effort to attain the
8-hour ozone NAAQS and the PM2.5 NAAQS, and to prepare the regional haze
plan.

Stationary sources (or point sources) are sources for which PADEP
collects individual emissions-related information.  They generally
represent major stationary sources but may be smaller.   The point
source data for 2002 is derived from the Air Information Management
System/environment, Facility, Application, Compliance Tracking System
(AIMS/eFACTS).  The  AIMS/eFACTS database is comprised of sources
identified and inventoried by PADEP’s

regional and central offices through permitting, field inspections, and
surveys.  More information is found in Appendix B-1 of Pennsylvania’s
attainment plan that includes information on stationary point source
emission methodology, and Appendix B-2 is the data that set for facility
2002 annual emissions.  Appendix B-3 is a table documenting banked
emission reduction credits for the Pennsylvania portion of the
Philadelphia area (5 counties) in the 2009 emission projection.

Area sources are industrial, commercial, and residential sources too
small or too numerous to be handled individually.  These include but are
not limited to commercial and residential open burning architectural and
industrial maintenance coatings applications and clean-up, consumer
product use, and vehicle refueling at service stations.  Where there is
overlap between stationary point sources and stationary area sources,
the area source values are adjusted to remove any double counting. 
PADEP’s inventory contained estimations of emissions by multiplying an
emission factor by an indicator or activity level for each category at
the county level.  These emissions are calculated on an annual basis
since the activity data are generally available on an annual basis. 
Area source estimates were provided by source classification code (SCC).
 More information is found in Appendix C-1 of Pennsylvania’s
attainment plan where specific information on the procedure used for
each industry type is contained and Appendix C-2 is a table containing
stationary area source emissions data for the Pennsylvania portion of
the Philadelphia area (5 counties).

Highway vehicles, which include passenger cars and light-duty trucks,
other trucks, buses and motorcycles.  Onroad mobile source emissions
inventory was developed using the most current version of EPA’s
highway mobile source emissions model MOBILE6.2.  PADEP also used
PPSUITE, an enhanced version of the Post Processor for Air Quality
software systems used for previous inventory submissions in
Pennsylvania.  The Pennsylvania Department of Transportation (PennDOT)
provided estimates of vehicles miles traveled (VMT) by vehicle type and
roadway type.  Pennsylvania’s methodology is consistent with the
January 2002 guidance published by EPA’s Office of Transportation and
Air Quality (OTAG) entitled, “Technical Guidance on the Use of MOBILE6
for Emissions Inventory Preparation.”

 	More information on highway emission methodology is available in
Appendix E of the Pennsylvania’s attainment plan.  Appendix E-1
provides the 2002 base year and 2009 projections of mobile (highway) VMT
and annual PM2.5 direct and precursor emissions.  The document
summarizes the methodology and data inputs used to produce the mobile
emissions inventory.  Appendix E-2 is a table of 2009 five-county
Philadelphia area annual highway emissions listed by SCC.  Appendix E-3
describes the inputs to MOBILE6.2 used to generate emission factors for
a specific area.  Some examples of the inputs described in Appendix E-3
are the type and frequency of vehicle emission testing, the fuel types
required in the area, temperatures by month, and fleet age.  The summary
in Appendix E-3 indicates when default information contained in the
model is used rather than specific area information. Appendix E-4 is an
electronic file that provides all of the input coding for a sample
segment and scenario used in Pennsylvania’s MOBILE6.2 modeling system.


	

Nonroad sources encompass a diverse collection of engines, including but
not limited to outdoor power equipment, recreational vehicles, farm and
construction machinery, lawn and garden equipment, industrial equipment,
recreational marine vessels, commercial marine vessels, locomotives,
ships, and aircraft.  The majority of nonroad emission source categories
were estimated using the EPA NONROAD 2005 model.  The NONROAD model
estimates emissions for diesel, gasoline, liquefied petroleum gasoline,
and compressed natural gas-fueled nonroad equipment types and includes
growth factors. The NONROAD model does not estimate emissions from
aircraft, locomotives or commercial marine vessels.  Emissions from
aircraft, locomotives or commercial marine vessels were estimated using
EPA guidance and best available information.  

More information on nonroad sources is found in Appendix F of the
Pennsylvania’s attainment plan. Appendix F-1 is the technical document
providing the methodology and description of the procedures used to
generate 2002 and 2009 county-level pollutant emission estimates for
nonroad mobile engines included in EPA’s NONROAD 2005 model,
locomotive engines and aircraft operations.  Appendix F-2 is a table of
the specific emissions data used to calculate the nonroad emissions
sorted by source category.  Appendix F-3 contains the 2002 Philadelphia
International Airport (PHL) inventory that includes aircraft and
aircraft-related equipment from the EPA-approved model, “Emissions and
Dispersion Modeling System (EDMS),” and also additional on-airport
highway, stationary and area source emissions.  

The emissions inventory for the base year, 2002, was developed in
accordance with EPA guidance, “Emissions Inventory Guidance for
Implementation of Ozone and Particulate Matter National Ambient Air
Quality Standards and Regional Haze Regulations, EPA-454/R-05-001,
August 2005, updated November 2005.”  Table 3 summarizes the emissions
for 2002.

 Table 3.  2002 Annual Emissions (Tons per Year)

Philadelphia area 2002	PM2.5	PM10	SO2	NOx	VOC	NH3

Stationary Point Sources	  2139	  3430	23745	  22124	    8183	  256

Area Sources	10020	55224	13153	  13029	  59227	4821

Highway Vehicle Sources	  1033	  1492	  1920	  63476	  33974	2614

Nonroad Sources	  1535	  1611	  1640	  21619	  21589	    14

Total	14727	61758	40459	120248	122973	7705

	

2009 Projected Emission Inventories	

Table 4 summarizes the emissions expected in 2009.  These emissions take
activity and emissions growth and/or controls from 2002 into account. 
Appendix D of the Pennsylvania’s attainment plan, relating to
emissions projections, contains documents that describe the
methodologies used to project the 2002 baseline emissions to 2009.

 Table 4.  2009 Projected Emissions (Tons per Year)

Philadelphia area 2009	PM2.5	PM10	SO2	NOx	VOC	NH3

Stationary Point Sources	  2817	  3840	12658	22252	   7881	  357

Area Sources	10324	59533	13972	13755	 55868	5749

Highway Vehicle Sources	    699	  1193	    327	36318	 20298	3118

Nonroad Sources	  1356	  1428	    800	18874	 15971	    16

PHL Capacity Enhancement Program	        0	       0	        0	        0	
    254	      0

Emission Reduction Credits Banked	      23	     32	    442	    432	   
1561	      0

Totals	15219	66035	28200	91651	101834	9239



Sulfur and nitrogen are major contributors to the Pennsylvania portion
of Philadelphia area’s PM2.5 nonattainment problem.  Therefore, even
though the direct PM2.5 emissions increase in 2009, the reductions of
PM2.5 precursors, SO2 and NOx, ensures that the Philadelphia area
attains the PM2.5 NAAQS by 2010.

Growth Projections Methodologies

Growth projections methodologies describe the data, methods and
assumptions utilize in developing estimates of emissions changes between
2002 and the milestone year 2009.  Appendix D-1 of the Pennsylvania’s
attainment plan contains the technical support document entitled,
“Development of Emission Projections for 2009, 2012, and 2018 for
Non-EGU Point, Area, and Nonroad Sources in the MANE-VU Region,”
developed by the Mid-Atlantic Regional Air Management Association
(MARAMA).  This document provides detail on the specific factors,
control assumptions, and implementation schedules used in the emission
projection calculations for each source category.

III.  Attainment Demonstration - Modeling

All attainment demonstrations must include modeling that is performed in
accordance with EPA’s “Guidance on the Use of Models and Other
Analyses for Demonstrating Attainment of Air Quality Goals for Ozone,
PM2.5, and Regional Haze” (EPA-454/B-07-002, April 2007).  Modeling
may be based on national (e.g., EPA), regional (e.g., Ozone Transport
Commission), local modeling, or a combination thereof, if appropriate. 
A description of modeling used to support Philadelphia’s attainment
demonstration follows.  More detailed information on the modeling is
discussed in a TSD entitled, “Technical Support Document for the
Modeling Portion of the Commonwealth of Pennsylvania’s Fine
Particulate Matter State Implementation Plan,” dated October 11, 2011
and section V of the Pennsylvania’s attainment plan.

 standard (15.0 μg/m3).  The Philadelphia area’s maximum 2008 annual
design value of 14.5 μg/m3 was observed at the Broad Street monitor. 
Based on 2006 – 2008 monitoring data, all monitors within the
Philadelphia area are monitoring attainment of the 1997 24-hour PM2.5
standard (65 μg/m3).  The maximum 2008 24-hour design value in the
Philadelphia area was 36 μg/m3, observed at the New Garden monitor. 
The Philadelphia area is required to attain the PM2.5 standard no later
than five years from the effective date of designation of April 5, 2005
(April, 2010).

The purpose of the attainment demonstration is to ensure, through grid
modeling, that projected emissions (with controls) will not cause the
nonattainment area to exceed the 1997 PM2.5 NAAQS.  A complex grid model
was run and processed over the entire Northeast to determine if the
Philadelphia area would attain the PM2.5 standard by April 5, 2010. 

Philadelphia Area Conceptual Model Description

A conceptual model describes how weather patterns affect the formation
and transport of PM2.5, accounting for emissions and photochemistry.

The conceptual model for the Philadelphia area was based on information
from the Northeast States for Coordinated Air-Use Management (NESCAUM)
final report entitled, “The Nature of the Fine Particle and Regional
Haze Air Quality Problems in the MANE-VU Region:  A Conceptual
Description (2006)” and PADEP’s modeling protocol documentation
(October 2007).

The NESCAUM document contains a conceptual description that explains how
elevated regional PM2.5 peak concentrations in the summer differ
significantly from the largely urban peak concentrations observed during
winter.  On average, summertime concentrations of sulfate in the
northeastern United States are more than twice that of the next most
important fine particle constituent, organic carbon (OC), and more than
four times the combined concentration of nitrate and black carbon (BC)
constituents.  Episodes of high summertime sulfate concentrations are
consistent with stagnant meteorological flow conditions upwind of the
Pennsylvania portion of the Philadelphia area and the accumulation of
airborne sulfate (via atmospheric oxidation of SO2) followed by
long-range transport of sulfur emissions from industrialized areas
within and outside the area.  National assessments have indicated that
in the winter, sulfate levels in urban areas are higher than background
sulfate levels across the eastern U.S., indicating that the local urban
contribution to wintertime sulfate levels is significant relative to the
regional sulfate contribution from long-range transport.  A network
analysis for the winter of 2002 suggests that the local enhancement of
sulfate in urban areas of the MANE-VU region ranges from 25 to 40% and
that the long-range transport component of PM2.5 sulfate is still the
dominant contributor in most eastern cities.

In the winter, urban organic carbon (OC) and sulfate each account for
about a third of the overall PM2.5 mass concentration observed in
Philadelphia and New York City areas.  Nitrate also makes a significant
contribution to urban PM2.5 levels observed in the northeastern United
States during the winter months.  Wintertime concentrations of OC and
nitrate in urban areas can be twice the average regional concentrations
of these pollutants, indicating the importance of local source
contributions.  This is likely because winter conditions are more
conducive to the formation of local inversion layers which prevent
vertical mixing.  Under these conditions, emissions from tailpipe,
industrial and other local sources become concentrated near the
Earth’s surface, adding to background pollution levels associated with
regionally transported emissions. 

The Model Used in the Attainment Demonstration  

By agreement of OTC, the New York State Department of Environmental
Conservation (NYSDEC) ran the Community Multi-scale Air Quality Model
(CMAQ) for the states in the northeast ozone transport region that
includes Pennsylvania.  EPA agrees CMAQ is appropriate for this modeling
demonstration.  The inputs of the model are described in section V of
the attainment plan submittal.  

Meteorological Time Periods Used in the Modeling

Since the Philadelphia area’s attainment demonstration used a resource
intensive photochemical grid model, EPA accepts the use of single,
recent representative year to be used for an annual simulation.  Two
factors were used in selecting 2002 as the representative year:  the
observed annual mean concentrations of PM2.5 are close to the 3-year
observed design value at all, or most monitoring sites, and the pattern
of quarterly mean values is similar to the pattern of quarterly mean
concentrations averaged over 3 years.

Meteorological Data Used in the Air Quality Model  

The OTC modeling committee decided to use a prognostic meteorological
model that provides life-like meteorological inputs to the photochemical
grid model.  The Pennsylvania State University/National Center for
Atmospheric Research Mesoscale Meteorological Model (MM5) version 3.6
was chosen for the modeling analysis.  The MM5 model provides a
reasonable representation of weather conditions at the surface and
aloft. 

Domain of the Model, Horizontal/Vertical Resolution and the Initial and
Boundary Conditions  

The modeling domain extends from Maine to Florida and out in the
Atlantic Ocean on the east and west to the Mississippi River.  The size
of the modeling domain was made large enough to include all emission
sources that affect PM2.5 concentration in the northeastern United
States.  Even this boundary is defined by a larger photochemical
modeling domain that covers much of North America.  Over the
northeastern United States, the model used 12 kilometer grid cells.  The
Pennsylvania portion of the Philadelphia area is included in the 12
kilometer grid cell area.  The OTC Modeling Committee used a
12-kilometer grid size for the areas in and near its states to provide a
fine enough grid resolution to adequately capture the PM patterns
experienced in the ozone transport region (OTR).  Outside the local
areas the grid resolution used in the modeling is 36 kilometers.  The
selection of model domains and horizontal grid resolution was deemed
acceptable to EPA.  

Vertical resolution is the number of layers and the size of each layer
in the model.  The layers in the photochemical grid model were set up to
be compatible with the model that produced weather conditions for the
photochemical grid model.  The vertical resolution used in the modeling
exercise followed EPA’s modeling guidance and therefore adequately
represents the atmosphere where PM2.5 is emitted, forms and is
transported.  

Emissions Used in the Air Quality Model  

The emissions data for 2002 were generated by individual states within
the OTR and assembled and processed through Mid-Atlantic Northeast
Visibility Union (MANE-VU), a Regional Planning Organization (RPO). 
These emissions were then processed by NYSDEC using the sparse matrix
operator kernel emissions (SMOKE) emissions processor to provide CMAQ
compatible inputs.  The 2002 emissions for the non-OTR areas within the
modeling domain were obtained from the corresponding RPOs and were
processed using SMOKE, in manner similar to that of the OTR emissions. 
The OTR states, through MANE-VU, contracted MACTEC Federal Programs
(called Contractor) to develop 2009, 2012 and 2018 inventories based on
2002 inventories that the states had previously developed for the
base-year model work. The Contractor, in consultation with the states,
developed the necessary growth and control factors and applied to the
2002 inventory.  

Base Case Run Model Performance Evaluation  

NYSDEC performed a model evaluation for the OTC to determine how well
CMAQ reproduced the 2002 PM2.5 concentrations.  CMAQ was employed to
simulate PM2.5 for the calendar year 2002.  A review of PM2.5 and its
individual species was conducted for the study domain.  Several
observations were made with respect to model performance: 1)
approximately 80 – 90 percent of organic mass (OM) is in the primary
fraction; 2) CMAQ captures seasonal variation in SO4 well; 3) CMAQ
appears to overestimate primary PM2.5 components, especially during
colder months; and CMAQ appears to underestimate secondary OM during the
summer.

These issues are not of great regulatory concern since attainment tests
are based on the application of relative response factors.  Therefore,
the regional and local model performance is acceptable for PM2.5.  While
there are some differences between the spatial data between sub-regions,
there is nothing to suggest a tendency for the model to respond in a
systematically different manner between regions.  Examination of the
statistical metrics by sub-region confirms the absence of significant
performance problems arising in one area but not in another, building
confidence that the CMAQ modeling system is operating consistently
across the full OTC domain.  This confidence in the modeling results
allows for the modeling system to be used to support the attainment plan
to meet the 1997 annual PM2.5 NAAQS.

2009 Control Case Modeling and Modeled Attainment Test  

As previously mentioned, the Pennsylvania portion of the Philadelphia
area has an attainment date of April 5, 2010.  The PM2.5 NAAQS include
an annual standard of 15 μg/m3 based on the 3-year average of annual
mean PM2.5 concentrations.

The purpose of a modeling assessment is to determine if control
strategies currently being implemented (“on the books”) will lead to
attainment of the annual average NAAQS for PM2.5 by 2009.  The modeling
is applied in a relative sense, similar to the 8-hour ozone attainment
test.  However, the PM2.5 attainment test is more complicated and
reflects the fact that PM2.5 is a mixture.  In the test, ambient PM2.5
is divided into major components, with a separate relative response
factor (RRF) and future design value (DVF) calculated for each of the
PM2.5 components.  Since the attainment test is calculated on a per
species basis, the attainment test for PM2.5 is referred to as the
Speciated Modeled Attainment Test (SMAT).

Annual SMAT Results

Table 4 presents the results of the annual SMAT results for the
Philadelphia area.  The SMAT results demonstrate that the projected
average annual arithmetic mean PM2.5 concentration calculated at each
Federal Reference Method (FRM) monitor attains the annual PM2.5 NAAQS. 
Specifically, all calculations are less than15 μg/m3.   Table 4
presents the results of the annual SMAT results for a suite of regional
modeling runs conducted by OTC each representing OTB/OTW – “On the
Books, On the Way” control measures.  All runs demonstrate compliance
with the annual PM2.5 NAAQS.

Table 4.  Annual SMAT Results for Philadelphia-Wilmington, PA-NJ-DE
PM2.5 Nonattainment Area On-The-Books-On-The-Way Control Measures

AIRS ID	Site Name	County	State	2000-2004 Baseline Design Value	2009





Q1	Q2	Q3	Q4	DVF

420170012	Bristol	Bucks	PA	14.14	13.69	14.73	13.85	12.1

420290100	New Garden	Chester	PA	14.39	14.73	16.36	13.76	12.4

420450002	Chester	Delaware	PA	15.07	15.96	16.34	13.74	13.3

420910013	Norristown	Montgomery	PA	12.68	13.62	13.96	12.34	11.3

421010004	AMS Lab	Philadelphia	PA	15.99	14.01	15.95	13.82	12.9

421010024	NE Airport	Philadelphia	PA	13.58	13.63	14.95	12.96	11.9

421010047	Broad Street	Philadelphia	PA	16.59	16.45	15.80	15.37	13.5

421010136	Elmwood	Philadelphia	PA	15.70	14.20	15.27	12.99	12.7

100031003	Bellefonte	New Castle	DE	14.87	15.16	15.50	13.13	12.6

100031007	Lums Pond	New Castle	DE	13.16	14.37	16.05	10.66	11.3

100031012	Newark	New Castle	DE	15.27	14.91	16.53	13.14	12.6

100032004	MLK	New Castle	DE	16.41	15.40	17.61	14.04	13.3

340070003	Camden	Camden	NJ	13.99	14.54	15.76	12.47	12.3

340071007	Pennsauken	Camden	NJ	13.99	14.00	14.75	13.59	12.3

340155001	Gibbstown	Gloucester	NJ	13.92	13.43	15.08	11.39	11.7



 design value is predicted to be 13.5μg/m3 in the Philadelphia area. 
Therefore, based on EPA’s modeled attainment test, the Pennsylvania
portion of the Philadelphia area reached attainment of the annual
average PM2.5 standard in 2009 before the attainment date of April 5,
2010. 	

Supplemental Analyses and Weight of Evidence (WOE) Determination

EPA’s modeling guidance states that additional analyses are
recommended to determine if attainment will be likely, even if the
modeled attainment test is “passed.”  The guidance recommends
supplementary analyses in all cases.  EPA’s modeling guidance
describes how to use a photochemical grid model and additional
analytical methods to complete a WOE analysis to estimate if emissions
control strategies will lead to attainment.  A WOE analysis is a
supporting analysis that helps to determine if the results of the
photochemical modeling system are correctly (or not correctly)
predicting future air quality. 

μg/m3 for annual PM2.5 and 62 μg/m3 for 24-hour PM2.5) need more
limited supporting material. 

Due to the fact that the modeling results presented in Table 4 fall
below the aforementioned “weight of evidence” thresholds established
by EPA, a limited supplemental analysis was deemed necessary to support
the 2009 attainment demonstration.  PADEP’s supporting evidence
includes a brief summary of the modeling demonstration, recent trends in
the Philadelphia area’s monitoring data and a brief analysis of some
of the largest SO2 sources within the nonattainment area (section V of
Pennsylvania’s attainment plan). 

IV.  Reasonably Available Control Measures/Reasonably Available Control
Technology

1.  Requirements for RACM/RACT

CAA section 172(c) (1) requires that each attainment plan “provide for
the implementation of all RACM as expeditiously as practicable,
including such reductions in emissions from the existing sources in the
area as may be obtained through the adoption, at a minimum, of RACT, and
shall provide for attainment of the national primary ambient air quality
standards.”  EPA interprets RACM including RACT under section 172 as
measures that a state finds are both reasonably available and contribute
to attainment as expeditiously are practicable in the nonattainment
area.  Thus, what constitutes RACM or RACT in a PM2.5 nonattainment area
is closely tied to the expeditious attainment demonstration of the plan.
 See 40 CFR section 51.1010; 72 FR 20586 at 20612.  

States are required to evaluate RACM/RACT for direct PM2.5 emissions and
all of the area’s attainment plan precursors.  See 40 CFR section
51.1002 (c); 72 FR 20586 at 20589 - 97.  Consistent with the guidance
provided for the PM2.5 Implementation Rule, a state initially must
evaluate RACM/RACT for sources that emit direct PM2.5, SO2, and NOx.  A
state may establish with an appropriate demonstration that it should not
regulate NOx in the specific nonattainment area, so it could thereby
forgo evaluation of RACM/RACT for NOx.  Because EPA concluded that VOC
and NH3 are presumptively not regulatory precursors for PM2.5, unless
the state or EPA determines that it is necessary to regulate them in a
specific nonattainment area, the state is not required to evaluate
RACM/RACT for sources of VOC or NH3 unless there is a determination
supported by an appropriate demonstration that such emissions need to be
regulated for expeditious attainment of the NAAQS in the specific area.

For PM2.5 attainment plans, the PM2.5 Implementation Rule requires a
combined approach to RACM and RACT under subpart 1 of Part D of the CAA.
 Subpart 1, unlike subparts 2 and 4, does not identify specific source
categories for which EPA must issue control technique documents or
guidelines, or identify specific source categories for state and EPA
evaluation during attainment plan development.  See 72 FR 20586 at
20610.  Rather, under subpart 1, EPA considers RACT to be part of an
area’s overall RACM obligation consistent with the section 172
definition.  Because of the variable nature of the PM2.5 problem in
different nonattainment areas which may require states to develop
attainment plans that address widely disparate circumstances, EPA
determined not only that states should have flexibility with respect to
RACM/RACT controls but also that in areas needing significant emission
reductions, RACM/RACT controls on smaller sources may be necessary to
reach attainment as expeditiously as practicable.  See 72 FR 20586 at
20612, 20615.  Thus, under the PM2.5 Implementation Rule, RACM and RACT
are those reasonably available measures that contribute to attainment as
expeditiously as practicable in the specific nonattainment area.  See 40
CFR section 51.1010; 72 FR 20586 at 20612.

Specifically, the PM2.5 Implementation Rule requires that attainment
plans include the list of measures that a state considered and
information sufficient to show that the state met all requirements for
the determination of what constitutes RACM/RACT in a specific
nonattainment area.  See 40 CFR section 51.1010(a).  In addition, the
PM2.5 Implementation Rule requires that the state, in determining
whether a particular emissions reduction measure or set of measures must
be adopted as RACM/RACT, consider the cumulative impact of implementing
the available measures and to adopt as RACM/RACT any potential measures
that are reasonably available considering technological and economic
feasibility if, considered collectively, they would advance the
attainment date by one year or more.  If a measure or measures is not
necessary for expeditious attainment of the NAAQS in the area, then by
definition that measure is not RACM/RACT for purposes of the 1997 PM2.5
NAAQS in that area.  Any measures that are necessary to meet these
requirements which are not already either Federally promulgated, part of
the state’s SIP, or otherwise creditable in SIPs must be submitted in
enforceable form as part of a state’s attainment plan for the area. 
See 72 FR 20586 at 20614.  

Guidance provided in the PM2.5 Implementation Rule for evaluating
RACM/RACT level controls for an area also indicated that there could be
flexibility with respect to those areas that were predicted to attain
the 1997 PM2.5 NAAQS within five years of designation as a result of
existing national or local measures.  See 72 FR 20586 at 20612.  In such
circumstances, EPA indicated that the state may conduct a more limited
RACM/RACT analysis that does not involve additional air quality
modeling.  Moreover, the RACM/RACT analysis for such area would focus on
a review of reasonably available measures, the estimation of potential
emissions reductions, and the evaluation of the time needed to implement
the measures.  Thus, the PM2.5 Implementation Rule guidance recommended
that not all areas would need to conduct as rigorous an analysis, and
suggested that a less rigorous analysis would be needed for those areas
expected to attain within the initial five years from designation as a
nonattainment area for the 1997 PM2.5 NAAQS. 

A more comprehensive discussion of the RACM/RACT requirement for PM2.5
attainment plans and EPA’s guidance for it can be found in the PM2.5
Implementation Rule preamble.  See 72 FR 20586 at 20609 – 20633.

2.  Pennsylvania’s Analysis of Pollutants and Sources Pennsylvania
Portion of the Philadelphia Area.

Pennsylvania’s analysis appears in section IV.B, page 29 and
Appendices G-1, G-2 and G-3 of the attainment plan submission.  Based
upon the emissions inventory for the area, Pennsylvania determined that
it would be appropriate to evaluate sources of PM2.5, SO2, and NOx
located in the nonattainment area for potential control as RACM/RACT. 
Pennsylvania did not determine that controls of sources of VOC or NH3
would be necessary for expeditious attainment of the NAAQS in this area,
nor does EPA believe that there is a need to do so.  Pennsylvania’s
determination with respect to which pollutants the plan should evaluate
is at section I.B, page 1 of the attainment plan submittal. 

After evaluating which pollutants should be addressed in the attainment
plan, Pennsylvania identified all source categories of those emissions
located within the nonattainment area to determine available controls
that could bring the area into attainment as expeditiously as possible. 
See section IV.B of the attainment plan submittal.  Based on the
emissions inventory and other information, Pennsylvania identified the
following source categories as sources that should be evaluated for
controls:  

Consumer Products

Portable Fuel Containers

Adhesives and Sealants Application

Diesel Engine Chip Reflash

Cutback and Emulsified Asphalt Paving

Cement Kilns

Glass Furnaces

Industrial, Commercial, and Institutional (ICI) Boilers

Regional Fuels

Electric Generating Units (EGUs)

Appendix G-1 of the attainment plan submittal contains the Ozone
Transport Commission (OTC) report entitled, “Identification and
Evaluation of Candidate Control Measures, Final Technical Support
Document (MACTEC, February 2007).”  This final report contains
detailed information about the process and includes tables summarizing
the emission reduction potential of each control measure by source
category and projection year.  

Pennsylvania also participated in an assessment of control measures for
pollutants and sources affecting visibility though the MANE-VU regional
haze process.  MANE-VU developed a list of control measures for
consideration and analysis:

Coal and oil-fired EGUs

Point and area source industrial, commercial and institutional boilers

Cement kilns

Lime kilns

The use of heating oil

Residential wood combustion and open burning

Appendix G-3 of the attainment plan submittal, contains the final report
entitled, “Assessment of Reasonable Progress for Regional Haze in
MANE-VU Class I Areas (MACTEC, July 2000),” from the MANE-VU control
measure assessment project.  This report presents the results of an
analysis of the economic and environmental impacts of the potential
scenarios that could be implemented by MANE-VU states to reduce
emissions from selected source categories in order to make reasonable
progress toward meeting visibility improvement goals.

In accordance with 40 CFR 51.1010, a SIP revision for a PM2.5
nonattainment area is required to demonstrate that all RACM, including
RACT stationary sources necessary to demonstrate attainment as
expeditiously as practicable have been adopted.  The cumulative impact
of implementing available measures must be considered in determining
whether a particular emission reduction measure or set of measures is
required to be adopted as RACM.  Potential measures that are reasonably
available considering technical and economic feasibility must be adopted
as RACM if, considered collectively, they would advance the attainment
date by one year or more.  Since the Pennsylvania portion of the
Philadelphia area attained at the end of 2009, any RACM measures need to
be in effect in 2008.  PADEP determined that there are no additional
control measures that could be adopted by January 1, 2008.  In addition,
existing measures and measures planned for implementation by 2009,
enables the Philadelphia area to attain the 1997 PM2.5 NAAQS. 
Therefore, no further actions on RACM or RACT are warranted.

3.  Pennsylvania’s evaluation of RACM/RACT control measures for the
Pennsylvania Portion of the Philadelphia Area.

In accordance with section 172 of the CAA, the Pennsylvania portion of
the Philadelphia area has adopted all RACM, including RACT, needed to
attain the standards “as expeditiously as practicable.” 
Pennsylvania’s demonstration for attaining the 1997 annual PM2.5 NAAQS
in the Pennsylvania portion of the Philadelphia area is based on
enforceable measures.

 STATIONARY POINT SOURCES

Small Sources of NOx, Cement Kilns and Large Stationary Internal
Combustion Engines

PADEP established additional ozone season requirements for small sources
of NOx in the counties of Bucks, Chester, Delaware, Montgomery, and
Philadelphia in regulations that were adopted on December 11, 2004 and
approved by EPA on September 29, 2006 (71 FR 57428).

New Source Review Programs

The Federal New Source Review (NSR) programs are preconstruction review
and permitting programs applicable to new or modified major stationary
sources subject to Title I, Parts C and D of the CAA.  The programs
consist of the Prevention of Significant Deterioration (PSD)
requirements applicable in areas attaining the NAAQS, and the
nonattainment NSR requirements applicable in geographic areas not
attaining and maintaining the NAAQS.  PADEP’s PSD regulations (25 Pa.
Code Chapter 127, Subchapter D, were approved by EPA on August 21, 1984
(49 FR 33128) codified at 40 CFR 52.2058.  The Federal PSD regulations
codified in 40 CFR 52 are incorporated by reference in 25 Pa. Code
127.83.  The PSD program requires any new source to implement best
available control technology (BACT) and limits new source’s allowable
impact on the environment.

Federal Standards for Hazardous Air Pollutants

Federal standards to control hazardous air pollutants (HAPs) require
maximum available control technology (MACT) at units located at major
sources of HAPs.  EPA has issued a series of regulations that are
applicable to sources in Pennsylvania.  These MACT standards are adopted
and incorporated by reference in Section 6.6 of the Pennsylvania’s Air
Pollution Control Act, implementing regulations and also included as
Federally enforceable permits issued by PADEP for affected sources.

Source Surveillance

PADEP’s rules and regulations for stationary sources, which are part
of the control strategy for attaining the PM2.5 NAAQS, as well as
PADEP’s comprehensive permitting program requirements in 25 Pa. Code
Chapter 127 and Pennsylvania’s SIP in 40 CFR 52.2020, meet the
requirements of 40 CFR Part 51, subpart K (relating to source
surveillance).  Pursuant to 40 CFR Part 51, subpart K, a SIP revision is
required to provide for monitoring the status of compliance with rules
and regulations set forth any portion of the control strategy. These
include provisions, as applicable for:  (1) emission reports and
recordkeeping for stationary sources; (2) periodic testing and
inspection of stationary sources; (3) enforcement and complaint
investigation of visible emission limitations; (4) enforceable test
methods for emission limits; and (5) continuous emission monitoring for
stationary sources.

HIGHWAY VEHICLES

Even with increases in vehicles miles traveled (VMT) that occur from
2002 through 2009. Highway vehicle emissions will continue to decrease. 
As more vehicles subject to cleaner new car standards replace older
vehicles subject to less stringent new vehicle standards, the fleet as a
whole emit fewer emissions, compensating for the increase in VMT. These
decreases are attributed to the programs described below.

Federal Motor Vehicle Control Programs and Pennsylvania Clean Vehicle
Program for Passenger Vehicles and Light-Duty Trucks and Cleaner
Gasoline

Tier 1 tailpipe standards established by the CAA include NOx and VOC
limits for light-duty gasoline vehicles (LDGVs) and light-duty gasoline
trucks (LDGTs).  These standards began to be phased in 1994. 
Evaporative VOC emissions were reduced in gasoline-powered cars starting
with Model Year (MY) 1998.

In 1998, under the authority of section 177 of the CAA, PADEP adopted
the Pennsylvania Clean Vehicles Program (28 Pa. B. 5873, Dec. 5, 1998). 
The Pennsylvania Clean Vehicles Program incorporates by reference
certain California Low Emission Vehicle (CA LEV) emission standards for
passenger cars and light-duty trucks.  As required under Section 177 of
the CAA, these provisions are identical to the low emission standards
adopted by California.  The regulation does not incorporate by reference
the California zero emissions vehicle (ZEV) or emissions control
warranty systems statement provisions.

PADEP adopted the National Low Emission Vehicle (NLEV) program as a
compliance alternative to the Pennsylvania Clean Vehicles Program.  The
NLEV program became effective in the Ozone Transport Region (OTR) in
1999.  Pennsylvania’s New Motor Vehicle Emissions Control Program
regulations in 25 Pa. Code Sections 126.401-126.441 allowed automobile
manufacturers to comply with NLEV instead of the CA LEV program through
MY 2005.  These regulations affected vehicles 6,000 pounds and less and
were the regulations in effect for new motor vehicles in the baseline
year, 2002.  

In 1999, EPA promulgated regulations more stringent than NLEV (Tier 2),
starting with MY 2004.  In order to participate in NLEV, Pennsylvania
had been required to adopt language that extended its “commitment”
to NLEV until MY 2006.  In practical terms, the NLEV program was
replaced for MY 2004 and later by the more stringent Federal “Tier
2” vehicle emissions regulations, 65 FR 6698 (Feb. 10, 2000), and
vehicle manufacturers operating under the NLEV program became subject to
the Tier 2 requirements. 

 

		Pennsylvania amended the former New Motor Vehicle Control Program
(which included the Pennsylvania Clean Vehicles Program) in 2006.  The
Clean Vehicles Program continues to incorporate the California Low
Emission Vehicle Program (CA LEV II) by reference.  As amended, the
program affects MY 2008 and newer passenger cars and light-duty trucks
vehicles.  36 Pa. B. 7424 (Dec. 9, 2006). 

		Emissions for milestone years were estimated based on compliance with
the Pennsylvania Clean Vehicles Program according to the methodology
described in section 7.4.1 of the “Technical Guidance on the Use of
MOBILE6.2 for Emissions Inventory Preparation,” published by the
EPA’s OTAQ in January 2002.  This methodology is further explained in
Appendix E of Pennsylvania’s attainment plan.  PADEP’s MOBILE
modeling of the Federal Tier 2 program applies to subject vehicles sold
in Pennsylvania from MY 2004 through MY 2007 and the Pennsylvania Clean
Vehicles Program applies to subject vehicles sold in MY 2008 and beyond.

Reformulated gasoline

	     Gasoline sold in the Philadelphia area is required by the CAA to
be the cleaner-burning reformulated gasoline meeting standards
established in section 211 of the CAA.  This federally-enforced program
has been in place since January 1995.  

Heavy-Duty Diesel Control Programs

	     EPA promulgated more stringent national regulations for heavy-duty
engines and vehicles (over 14,000 pounds) starting with MY 2004.  In
addition, consent decrees with seven of the largest heavy-duty engine
manufacturers required, among other terms, that diesel engines made by
these companies comply with these 2004 standards two model years early,
in MY 2002.  Pennsylvania includes these programs as provided in the
MOBILE model. 

Vehicle Emission Inspection/Maintenance Program

		The Philadelphia area has had a vehicle emissions inspection program
since 1984.  In early 2004, Pennsylvania revised the implementation of
its Vehicle Emission Inspection/Maintenance (I/M) Program in the
five-county Philadelphia area.  The program applies to gasoline-powered
vehicles 9,000 pounds and under, MY 1975 and newer.  For vehicles MY
1996 and newer, the program consists of an annual on-board diagnostics
test and a gas cap pressure test.  For subject vehicles MY 1995 and
older, the program consists of an annual tailpipe test, visual
inspection of pollution control devices to ensure they are present,
connected and the proper type for the vehicle and a gas cap pressure
test.  For vehicles older than 25 years, the program is a visual
inspection and gas cap test. These regulations can be found in 67 Pa.
Code Chapter 177.  Pennsylvania submitted the revised emissions program
as a SIP revision on December 1, 2003 which EPA approved on October 6,
2005 (70 FR 58313).

Low sulfur gasoline

		Simultaneously with the Tier 2 program, EPA published a regulation
requiring the reduction of sulfur in gasoline beginning in 2004, with
full implementation in 2006.  Sulfur levels are capped at 80 ppm per
gallon and annual refinery averages must be no more than 30 ppm.  The
emission reduction analysis uses the default assumptions provided in
MOBILE6 to account for the implementation of the Federal sulfur standard
rule.   

Diesel Vehicle Idling Restrictions

On October 9, 2008, Governor Rendell signed the Diesel-Powered
Commercial Motor Vehicle Idling Act (Act 124 of 2008).  Act 124 of 2008
went into effect on February 6, 2009.  This Act restricts subject
drivers and owners statewide from idling a diesel-powered motor vehicle
engaged in commerce with a gross vehicle weight of 10,001 pounds or more
for more than five minutes in any continuous 60-minute period.  Also, no
owner or operator of a location where the aforementioned vehicles load,
unload or park may allow the vehicles to idle for more than 5 minutes in
a 60-minute continuous period.  

NONROAD SOURCES

EPA adopted a series of regulations affecting new diesel-powered
(“compression ignition”) and gasoline-powered (“spark ignition”)
nonroad engines of various sizes (horsepower) and applications. 
Information on these Federal rules, including their implementation
dates, can be found at www.epa.gov/nonroad. PADEP used the assumptions
built into the nonroad model (NONROAD2005) to estimate emissions for all
milestone years.

			

EPA will also require diesel fuel used in most nonroad applications to
contain less sulfur.  The sulfur will prevent damage to the more
advanced emission control systems needed to meet the engine standards;
it will also reduce fine particulate emissions from diesel engines.  In
2007, fuel sulfur levels were limited to 500 parts per million (ppm) for
nonroad applications other than ocean-going marine vessels.  In 2010,
fuel sulfur levels will be reduced to the same sulfur concentration as
in highway fuel, 15 ppm; this requirement applies in 2012 to locomotive
and marine diesel fuel.

VOC SOURCES

Although VOC is not a regulated PM2.5 precursor for the Philadelphia
area, VOC control measures approved by EPA were included in the modeling
associated with this attainment plan:  portable fuel containers
(December 8, 2004, 69 FR 70893); consumer products (December 8, 2004, 69
FR 70895); and architectural and industrial maintenance (AIM) coatings
(November 23, 2004, 69 FR 69080).

4.  RACM/RACT Demonstration and Control Strategy

Pennsylvania’s evaluation of RACM/RACT control measures for the
Pennsylvania portion of the Philadelphia area is approvable.  As noted
above, the most current monitoring data for this area indicates that it
is attaining the 1997 PM2.5 NAAQS.  EPA’s guidance for the PM2.5
Implementation Rule recommended that if an area was predicted through
the attainment plan to attain the standards within five years after
designation, then the State could submit a more limited RACM/RACT
analysis and the State could elect not to do additional modeling.  

In light of the fact that the Pennsylvania portion of the Philadelphia
area is now attaining the standards, the attainment plan meets the
RACM/RACT requirements of the PM2.5 Implementation Rule, and that the
level of control in the State’s attainment plan constitutes RACM/RACT
for purposes of the 1997 PM2.5 NAAQS.  Because the PM2.5 Implementation
Rule defines RACM/RACT as that level of control that is necessary to
bring the area into attainment, the current level of Federally
enforceable controls on sources located within the Philadelphia area is
by definition RACM/RACT for this area for this purpose.  

VI.  Contingency Measures

In accordance with Section 172(c)(9) of the CAA, the PM2.5
Implementation Rule requires that PM2.5 attainment plans include
contingency measures.  These measures must be fully adopted and should
contain trigger mechanisms and an implementation schedule.  In addition,
they should be measures not already included in the SIP control strategy
and should provide for emission reductions equivalent to one year of
RFP.  Contingency measures are implemented if RFP targets are not
achieved, or if attainment is not realized by the attainment date. 
Where an area has already achieved attainment by the attainment date, it
has no need to rely on contingency measures to come into attainment or
to make further progress to attainment.  However, in accordance with
section 110(k)(2) of the CAA, EPA must take action on the contingency
measures that were submitted by Pennsylvania.

The PM2.5 Implementation Rule requires that quantity of emission
reductions needed to satisfy contingency requirements is an amount equal
to one’s year worth of required reductions.  Required reductions are
the amount of reductions needed to attain compliance with the PM2.5
NAAQS.  By 2009, emissions of SO2 and NOx in the Pennsylvania portion of
the Philadelphia area are projected to decrease by 12,259 tons and 28597
tons, respectively.  Based on modeling of the projected 2009 emissions,
the Philadelphia area is predicted to have a design value of 13.5 
g/m3, which is lower than the 15 g/m3 required for the attainment
of the PM2.5 NAAQS.  Calculations were made to estimate the portion of
the emission reduction that is necessary to reach the attainment
concentration of 15 g/m3 and the portion of the emission reduction
that reduces the design value below 15 g/m3 and is therefore, excess.

Table 5 displays the 2002 actual and 2009 modeled design values and the
2002 actual and 2009 projected emissions of SO2 and NOx.

Table 5.  Design Value and Emissions Expected by 2009 

Philadelphia area	Design Value (g/m3)	SO2 (tons/year)	NOx (tons/year)

2002	16.6	40459	120348

2009 (Modeled/Projected)	13.5	28200	  91651

Change from 2002-2009	 3.1	12259	  28597



Table 6 shows that for each pollutant, the change in pollutant emissions
was divided by the change in design value to yield the value reduction
rate.  Then, the change in design value necessary to attain the standard
(16.6 g/m3 – 15 g/m3 = 1.6 g/m3) was multiplied by the design
value reduction rate to estimate the target emissions reduction.  This
represents the portion of emission reduction necessary to attain the
standard.  The rest of the emissions reduction is beyond what is
necessary for attainment and is therefore, considered to be “excess”
reduction.

Table 6.  Calculation of Required and Excess Emissions Reductions

g/m3)	SO2 (tons/year)	NOx (tons/year)

Change from 2002-2009	3.1	12259	28597

Design Value Reduction Rate (tons/g/m3)

3955	9225

Target Reductions for Attainment	1.6	6327	14760

Calculated Excess Reductions	1.5	5932	13837



The contingency requirement is calculated by dividing the target
emissions reduction by seven, which is the number of years between 2002
and 2009.  Table 7 shows the calculation of the contingency requirement
reduction and demonstrates that the calculated excess reduction exceeds
the amount of reduction necessary for the contingency plan.

Table 7.   Calculation of Required Contingency Plan Reductions

Philadelphia area	SO2 (tons/year)	NOx (tons/year)

Target Reductions for Attainment	6327	14760

Calculated Excess Reductions	5932	13837

Contingency Requirement	  904	 2109

Excess Reductions Satisfy Contingency Requirement	Yes	Yes

 

The attainment plan for the Pennsylvania portion of the Philadelphia
area includes contingency measures to be implemented if the area fails
to attain by its attainment date.  The following describes the specific
control measures that are anticipated to be in place in order to bring
the area back into attainment should a violation occur.  

The Diesel-Powered Commercial Motor Vehicle Idling Act (Act 124) went
into effect on February 6, 2009.  PADEP estimates 50 percent of all long
duration idling for Class 8 trucks will be eliminated in 2010 when the
temperature exemption for sleeper truck rest expires.  Statewide
emission reductions are estimated to be 1610 tons, 45 tons and 30 tons
per year for NOx, VOC and PM2.5, respectively.  PADEP will also utilize
enhanced enforcement to obtain additional emission reductions.

Significant additional reductions in NOx, direct PM2.5 and SO2 emissions
will occur in emissions from highway and nonmobile sources after 2009. 
In addition, NOx controls for cement kilns and glass furnaces were
approved by EPA on July 19, 2011 (76 FR 42258) and August 22, 2011 (76
FR 52283), respectively.  Furthermore, PM2.5 control from the operation
of outdoor wood-fired boilers was approved by EPA on September 20, 2011
(76 FR 58114).  Sulfur limits for fuel oil (home heating oil and
residential oil) are anticipated to be adopted later.  Regulations to
reduce VOC emissions are also in development, including controls on the
manufacture and use of adhesives, primers and sealants and regulations
incorporating the Control Technique Guidelines issued by EPA in 2006,
2007 and 2008.    

As required, these measures were fully adopted rules or control measures
that were ready to be implemented quickly upon failure of the area to
attain, were in addition to those measures otherwise relied upon for
attainment, had trigger mechanisms and a schedule for implementation,
and were at the level of reductions equal to at least one year’s worth
of reductions needed for attainment in the area.   EPA finds that the
measures submitted by Pennsylvania have satisfied the requirements for
contingency purposes.  

EPA’s General Preamble interprets the control measure requirements of
sections 172(c)(9) and 182(c)(9) to allow states to implement measures
before they are triggered (57 FR 13498, 13511). EPA has previously
approved a number of SIPs under this interpretation (66 FR 15844, April
3, 1997; 62 FR 66279, December 18, 1997; 66 FR 30811, June 8, 2001; 66
FR 586, and 66 FR 634, January 3, 2001) and the Fifth Circuit has upheld
EPA’s interpretation.  Louisiana Environmental Action Network v. EPA,
382 F.3d 575 (Fifth Cir. 2004).  It does not matter whether or not a
specific contingency measure is already required by law, as long as the
emissions reductions that will result from the contingency measure have
not been relied upon in the attainment demonstration.

The contingency measures in Pennsylvania’s attainment demonstration
(described above) that are already implemented and provide reductions in
excess of those required by the attainment demonstration to attain the
standards.  The level of reductions provided is equal to at least one
year’s worth of reductions needed for attainment in the Pennsylvania
portion of the Philadelphia area.  One year’s worth of reductions
needed for attainment is determined by dividing the emissions from base
year levels that are needed for attainment by the number of years
between the base year and the attainment year. (See PM2.5 Implementation
Rule, page 20643).  Contingency measures are implemented in the event
that the Philadelphia area fails to attain the standards by its
attainment date.  Although the Philadelphia area, as indicated above,
met their attainment date of April 5, 2010 and thus is not required to
implement contingency measures, by relying on those measures that were
already in place, Pennsylvania effectively implemented their control
measures in advance.    

VIII.  Motor Vehicle Emission Budgets

The CAA requires Federal actions in nonattainment and maintenance areas
to “conform to” the goals of SIPs.  This means that such actions
will not:  (a) cause or contribute to violations of a NAAQS; (b) worsen
the severity of an existing violation; or (c) delay timely attainment of
any NAAQS.  Actions involving Federal Highway Administration (FHWA) or
Federal Transit Administration (FTA) funding or approval are subject to
the transportation conformity rule (40 CFR part 93, subpart A).  Under
this rule, metropolitan planning organizations (MPOs) in nonattainment
and maintenance areas coordinate with State Air Quality and
Transportation Agencies, EPA, and the FHWA and FTA to demonstrate that
their long range transportation plans (“plans”) and transportation
improvement programs (TIP) conform to applicable SIPs.  This is
typically determined by showing that estimated emissions from existing
and planned highway and transit projects are less than or equal to the
MVEBs contained in the SIP.

Section 176 (c) of the CAA requires Federal actions in nonattainment and
maintenance areas to “conform to” the goals of SIPs.  This means
that such actions will not: cause or contribute to violations of a
NAAQS, worsen the severity of an existing violation, or delay timely
attainment of any NAAQS.  Actions involving Federal Highway
Administration (FHWA) or Federal Transit Administration (FTA) funding or
approval are subject to the transportation conformity rule (40 CFR part
93, subpart A).  Under this rule, metropolitan planning organizations
(MPOs) in nonattainment and maintenance areas coordinate with State Air
Quality and Transportation Agencies, EPA, and the FHWA and FTA to
demonstrate that their long range transportation plans (“plans”) and
transportation improvement programs (TIP) conform to applicable SIPs. 
This is typically determined by showing that estimated emissions from
existing and planned highway and transit projects are less than or equal
to the MVEBs contained in the SIP.

The MVEBs for the 2009 attainment year are based on the projected 2009
on-road motor vehicle source emissions, accounting for the emission
reductions from on-road vehicle source control measures, including
transportation control measures and vehicle technology, fuel or
maintenance-based measures.  MVEBs for 2009 attainment year for the
Pennsylvania portion of the Philadelphia area are 699 tons per year for
PM2.5-direct and 36,318 tons per year for NOx as shown in Table 8.  More
detailed information can be found in the TSD entitled, “Adequacy
Findings for Motor Vehicle Emissions Budgets in the Attainment
Demonstration for the Pennsylvania Portion of the
Philadelphia-Wilmington-New Jersey City PM2.5 NAAQS Nonattainment
Area,” dated October 6, 2011.

Table 8.  Motor Vehicle Emission Budgets

2009	PM2.5	NOx

Tons per year	699	36318



 

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瑹֜ ؀y until the attainment plan and associated MVEBs are approved
in a final Federal Register notice, or EPA otherwise finds the budgets
adequate in a separate action following the comment period.  Our action
on the Pennsylvania portion of the Philadelphia area MVEBs will also be
announced on EPA’s conformity website:    HYPERLINK
"http://www.epa.gov/otaq/stateresources/transconf/index.htm" 
http://www.epa.gov/otaq/stateresources/transconf/index.htm , (once
there, click on “Adequacy Review of SIP Submissions).

The budgets that Pennsylvania submitted were calculated using the
MOBILE6.2 motor vehicle emissions model.  EPA is proposing to approve
the inventory and the conformity budgets calculated using this model
because this model was the most current model available at the time
Pennsylvania was performing its analysis.  Separate from the NPR, EPA
has issued an updated motor vehicle emissions model known as the Motor
Vehicle Emission Simulator or MOVES.  In its announcement of this model,
EPA established a grace period for continued use of MOBILE6.2 in
transportation conformity determinations for transportation plans and
TIPs, after which states and MPOs (other than California) must use MOVES
for transportation plan and TIP conformity determinations.  This grace
period will expire in March 2012 (or March 2013 once the extension
becomes official). 

Additional information on the use of MOVES in SIPs and conformity
determinations can be found in the December 2009, “Policy Guidance on
the Use of MOVES2010 for State Implementation Plan Development,
Transportation Conformity, and Other Purposes.”  This guidance
document is available at:   HYPERLINK
"http://www.epa.gov/otaq/models/moves/420b09046.pdf" 
http://www.epa.gov/otaq/models/moves/420b09046.pdf .

During the conformity grace period, the State and MPO(s) should use the
interagency consultation process to examine how MOVES2010a will impact
their future transportation plan and TIP conformity determinations,
including regional emissions analyses.  For example, an increase in
emission estimates due to the use of MOVES2010a may affect an area’s
ability to demonstrate conformity for its transportation plan and/or
TIP.  Therefore, state and local planners should carefully consider
whether the SIP and motor vehicle emissions budget(s) should be revised
with MOVES2010a or if transportation plans and TIPs should be revised
before the end of the conformity grace period, since doing so may be
necessary to ensure conformity determinations in the future.

We would expect that states and MPOs would work closely with EPA and the
local FHWA and FTA offices to determine an appropriate course of action
to address this type of situation if it is expected to occur.  If
Pennsylvania chooses to revise its PM2.5 attainment plan, it should
consult Question 7 of the December 2009, “Policy Guidance on the Use
of MOVES2010 for State Implementation Plan Development, Transportation
Conformity, and Other Purposes,” for information on requirements
related to such revisions.

 

D.  SUMMARY AND RECOMMENDATIONS:

	The PM2.5 attainment plan for the Pennsylvania portion of the
Philadelphia area meets the requirements of the CAA as described in the
Clean Air Fine Particle Implementation Rule (April 25, 2007, 72 FR
20586).  The attainment plan supports a determination that the
Pennsylvania portion of the Philadelphia area attains the 1997 annual
PM2.5 NAAQS.  The attainment plan includes an attainment demonstration,
MVEBs used for transportation conformity purposes, RACM/RACT analysis,
contingency measures, and the 2002 base year emission inventories. 
Therefore, we recommend approval of the PM2.5 attainment plan for the
Pennsylvania portion of the Philadelphia area.

	 

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