Technical Support Document (TSD) For 

Pennsylvania Portion of the Philadelphia-Wilmington, PA-NJ-DE

PM2.5 Nonattainment Area:

State Implementation Plan (SIP) Attainment Demonstration

and Base Year Inventory

Submitted April 2010 by the Pennsylvania 

Department of Environmental Protection 

TSD Prepared October 2011 by

Alice H. Chow

Office of Air Monitoring and Analysis, 3AP40

U.S. Environmental Protection Agency, Region 3

1650 Arch Street

Philadelphia, Pennsylvania 19103

/s/

____________________________________________

Reviewed by Andrew Hass, Acting Director

Office of Air Monitoring and Analysis (3AP40)

October 11, 2011

_________________

Date Signed

        

Introduction

The purpose of this document is to provide a technical summary of the
Office of Air Monitoring and Analysis (OAMA) review of the emissions
inventories submitted with the Pennsylvania Portion of the
Philadelphia-Wilmington PM2.5 Nonattainment Area State Implementation
Plan (SIP), by the Pennsylvania Department of Environmental Protection
(PADEP).  This review determines the approvability of the SIP Base Year
Inventory and an evaluation of the methods used.  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. On January 5, 2005 the Pennsylvania Portion of the
Philadelphia-Wilmington area, comprised of Bucks, Chester, Delaware,
Montgomery and Philadelphia counties, was designated as nonattainment
for the PM2.5 NAAQS. Any questions pertaining to this technical summary
should be directed to Andrew Hass, Acting Director, Office of Air
Monitoring and Analysis, at 215-814-2049 or via email at  HYPERLINK
"mailto:hass.andrew@epa.gov" hass.andrew@epa.gov . 

II.	2002 SIP Base Year Inventory

	The SIP 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 PM2.5 NAAQS, the pollutants to be
inventoried are PM10, PM2.5, VOC, NOx, SO2 and NH3.  For the NAAQS,
emissions should be reported as actual annual emissions. 

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.  Surveys are
conducted annually as facilities must submit emission estimates for
various operations, throughputs, work hours, as well as process data,
such as combustion unit data and fuel characteristics.  In 2002, PADEP
noted that many facilities did not include condensable PM in their
estimates of direct PM emissions.  MANE-VU included both filterable and
condensable PM estimates for their regional modeling efforts.

	For the 2002 Nonpoint Source emissions, also known as “area
sources,” PADEP provided an inventory that contained estimations of
emissions by multiplying an emission factor by some known indicator or
activity level for each category at the county level.  These emissions
are typically calculated on an annual basis because the activity data
are generally only available on an annual basis.  Nonpoint source
estimates were provided by SCC.

	The Nonroad Mobile Source 2002 inventory was prepared with EPA’s
NONROAD2005 model.  NONROAD estimates fuel consumption and emissions of
total volatile organic compounds (VOCs), oxides of nitrogen (NOx),
carbon monoxide (CO), particulate matter (PM10), fine particulate matter
(PM2.5) and sulfur dioxide (SO2) for all nonroad mobile source
categories except for aircraft, locomotives, and commercial marine
vessels.  Revised allocation geographic files for NONROAD2005 model
option files (average temperature, Reid Vapor Pressure) and revised
housing unit data used for the model runs (to allocate residential lawn
and garden equipment) were also discussed.  The National Mobile
Inventory Model (NMIM) was used to estimate emissions of ammonia from
sources contained in the NONROAD model.   PADEP provided emission
estimates for locomotive engines and aircraft emissions separately.  For
locomotive engine emissions, PADEP obtained fuel usage from Norfolk
Southern and Conrail for 2002; emissions from all other railroad
companies were projected emissions from a 1999 survey using national
fuel consumption information and EPA emission and conversion factors.  

Emissions from commercial aircraft and small airport operations for 2002
were estimated with the following methodologies:  

Small airports: PADEP used the EPA-approved Emissions and Dispersion
Modeling System (EDMS) 4.20, the latest version available at the time
the inventory was developed.  PADEP estimated emissions using operations
data obtained from the United States Department of Transportation,
Federal Aviation Administration’s (FAA) Terminal Area Forecast for
commercial aircraft operations. Using this operations data, emissions
were modeled directly using the EDMS.  Finally, Willow Grove Naval Air
Station in Bucks County is a significant source of NOx but since the
terrorist activity in September 2001, the Navy has not released any
operations data to PADEP, therefore, its emissions were not included in
the inventory. 

Philadelphia International Airport:  As part of the City of
Philadelphia’s commitment to reduce delays at the Philadelphia
International Airport (PHL), a major long-term project known as the
Capacity Enhancement Program (CEP) was proposed to redesign runways,
taxiways and terminals.  This construction project would generate a
large amount of direct and indirect emissions over time from excavation
activities as well as less efficient aircraft operations (due to fewer
runways).  PADEP worked closely with the Philadelphia Division of
Aviation to establish the 2002 base year using historical data and the
most accurate operation data for emissions sources (aircraft type,
arrivals, departures, etc.) for modeling with EDMS.

Commercial marine vessels emissions from the Port of Philadelphia were
estimated using EPA’s “Commercial Marine Activity for Deep Sea Ports
in the United States, Final Report,” as well as ship arrival
information supplied by the Maritime Exchange for the Delaware River and
Bay.  By mutual agreement between Pennsylvania and New Jersey, downbound
traffic north of the Pennsylvania-Delaware border is included in the
Pennsylvania inventory and the upbound emissions traffic north of the
border is in New Jersey’s inventory.  In addition, hotelling emissions
(emissions from auxiliary engines when docked) from larger vessels
(tankers, cruise ships, etc.), ferries, and tugboat emissions are
included.  All Nonroad mobile source emissions were provided 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. 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 vehicle miles traveled
(VMT) by vehicle type and roadway type.  PADEP provided sample Mobile6.2
input files and estimate results for review.  

OAMA staff reviewed the files and the emission results provided by PADEP
and found them to be approvable.

 “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, updated
November 2005.

