MARYLAND DEPARTMENT OF THE ENVIRONMENT

1800 Washington Boulevard (	Baltimore MD  21230

410-537-3000  ( 1-800-633-6101

Cecil County, Maryland

8-Hour Ozone

State Implementation Plan

and Base Year Inventory

SIP Revision:

07-05

June 15, 2007

Prepared for:

U.S. Environmental Protection Agency

Prepared by:

Maryland Department of the Environment

This Page Left Intentionally Blank

TABLE OF CONTENTS

  TOC \o "1-3" \h \z    HYPERLINK \l "_Toc164568644"  1.0  Executive
Summary	  PAGEREF _Toc164568644 \h  8

  HYPERLINK \l "_Toc164568645"  2.0  Introduction and Background
PAGEREF _Toc164568645 \h  12

  HYPERLINK \l "_Toc164568646"  2.1  State Implementation Plans
PAGEREF _Toc164568646 \h  12

  HYPERLINK \l "_Toc164568647"  2.2  Clean Air Act	  PAGEREF
_Toc164568647 \h  13

  HYPERLINK \l "_Toc164568648"  2.3  SIP Requirements for Moderate
Nonattainment Areas	  PAGEREF _Toc164568648 \h  14

  HYPERLINK \l "_Toc164568649"  2.4  Eight-Hour Ozone Standard	  PAGEREF
_Toc164568649 \h  15

  HYPERLINK \l "_Toc164568650"  2.5  Ground Level Ozone	  PAGEREF
_Toc164568650 \h  15

  HYPERLINK \l "_Toc164568651"  2.6  Air Pollution and the Chesapeake
Bay	  PAGEREF _Toc164568651 \h  16

  HYPERLINK \l "_Toc164568652"  2.7  Health Effects	  PAGEREF
_Toc164568652 \h  17

  HYPERLINK \l "_Toc164568653"  2.8  Maryland Specific Health Effects
PAGEREF _Toc164568653 \h  18

  HYPERLINK \l "_Toc164568654"  2.9  The Impact of Ozone on Agriculture
 PAGEREF _Toc164568654 \h  19

  HYPERLINK \l "_Toc164568655"  2.10  The Air Quality Index (AQI)
PAGEREF _Toc164568655 \h  19

  HYPERLINK \l "_Toc164568656"  2.11  Sources of Ozone Pollution in the
Cecil County Area	  PAGEREF _Toc164568656 \h  21

  HYPERLINK \l "_Toc164568657"  2.12  Frequency of Violation of Federal
Health Standard for Ozone	  PAGEREF _Toc164568657 \h  23

  HYPERLINK \l "_Toc164568658"  2.13  Required SIP Principles	  PAGEREF
_Toc164568658 \h  24

  HYPERLINK \l "_Toc164568659"  2.14  Sanctions	  PAGEREF _Toc164568659
\h  25

  HYPERLINK \l "_Toc164568660"  2.15  Reasonable Further Progress
PAGEREF _Toc164568660 \h  25

  HYPERLINK \l "_Toc164568661"  2.16  Analysis of Reasonably Available
Control Measures (RACM)	  PAGEREF _Toc164568661 \h  25

  HYPERLINK \l "_Toc164568662"  2.17  Contingency Measures	  PAGEREF
_Toc164568662 \h  26

  HYPERLINK \l "_Toc164568663"  3.0  The 2002 Base-Year Inventory
PAGEREF _Toc164568663 \h  27

  HYPERLINK \l "_Toc164568664"  3.1  Background and requirements
PAGEREF _Toc164568664 \h  27

  HYPERLINK \l "_Toc164568665"  3.2  Total Emissions by Source	  PAGEREF
_Toc164568665 \h  28

  HYPERLINK \l "_Toc164568666"  Point Sources	  PAGEREF _Toc164568666 \h
 28

  HYPERLINK \l "_Toc164568667"  Quasi-Point Sources	  PAGEREF
_Toc164568667 \h  28

  HYPERLINK \l "_Toc164568668"  Area Sources	  PAGEREF _Toc164568668 \h
29

  HYPERLINK \l "_Toc164568669"  Mobile Sources	  PAGEREF _Toc164568669
\h  29

  HYPERLINK \l "_Toc164568670"  Nonroad Sources	  PAGEREF _Toc164568670
\h  31

  HYPERLINK \l "_Toc164568671"  Biogenic Emissions	  PAGEREF
_Toc164568671 \h  32

  HYPERLINK \l "_Toc164568672"  3.3 Emissions Trends	  PAGEREF
_Toc164568672 \h  32

  HYPERLINK \l "_Toc164568673"  4.0  The 2008 and 2009 Projected
Inventories	  PAGEREF _Toc164568673 \h  36

  HYPERLINK \l "_Toc164568674"  4.1  Growth Projection Methodology
PAGEREF _Toc164568674 \h  36

  HYPERLINK \l "_Toc164568675"  Growth Projection Methodology for Point
Sources: EGAS	  PAGEREF _Toc164568675 \h  36

  HYPERLINK \l "_Toc164568676"  Growth Projection Methodology for
Quasi-Point Sources	  PAGEREF _Toc164568676 \h  37

  HYPERLINK \l "_Toc164568677"  Growth Projection Methodology: Area
Sources	  PAGEREF _Toc164568677 \h  37

  HYPERLINK \l "_Toc164568678"  Growth Projection Methodology: Nonroad
Sources	  PAGEREF _Toc164568678 \h  39

  HYPERLINK \l "_Toc164568679"  Growth Projection Methodology: Onroad
Sources	  PAGEREF _Toc164568679 \h  41

  HYPERLINK \l "_Toc164568680"  Biogenic Emission Projections	  PAGEREF
_Toc164568680 \h  41

  HYPERLINK \l "_Toc164568681"  4.2  Offset Provisions, Emission
Reduction Credits and Point Source Growth	  PAGEREF _Toc164568681 \h  41

  HYPERLINK \l "_Toc164568682"  4.3  Actual vs. Allowable Emissions in
Development of the 2008 and 2009 Projected Emissions Inventories
PAGEREF _Toc164568682 \h  43

  HYPERLINK \l "_Toc164568683"  4.4  Projection Inventory Results
PAGEREF _Toc164568683 \h  44

  HYPERLINK \l "_Toc164568684"  4.5  2008 Controlled Emissions for
Rate-of-Progress	  PAGEREF _Toc164568684 \h  44

  HYPERLINK \l "_Toc164568685"  4.6  2009 Controlled Emissions for
Attainment	  PAGEREF _Toc164568685 \h  46

  HYPERLINK \l "_Toc164568686"  5.0 2008 Reasonable Further Progress
Requirements	  PAGEREF _Toc164568686 \h  47

  HYPERLINK \l "_Toc164568687"  5.1  Introduction	  PAGEREF
_Toc164568687 \h  47

  HYPERLINK \l "_Toc164568688"  Rate of Progress Demonstrated in
Previous State Implementation Plans	  PAGEREF _Toc164568688 \h  47

  HYPERLINK \l "_Toc164568689"  5.2  Guidance for Calculating Reasonable
Further Progress (RFP) Emission Target Levels	  PAGEREF _Toc164568689 \h
 48

  HYPERLINK \l "_Toc164568690"  2008 VOC and NOx Target Levels	  PAGEREF
_Toc164568690 \h  49

  HYPERLINK \l "_Toc164568691"  Calculation of 2008 Target Levels
PAGEREF _Toc164568691 \h  49

  HYPERLINK \l "_Toc164568692"  5.3  Compliance with 2008 Reasonable
Further Progress Requirements	  PAGEREF _Toc164568692 \h  53

  HYPERLINK \l "_Toc164568693"  6.0  Control Measures	  PAGEREF
_Toc164568693 \h  55

  HYPERLINK \l "_Toc164568694"  6.1  1-Hour Ozone Control Measures
PAGEREF _Toc164568694 \h  55

  HYPERLINK \l "_Toc164568695"  On-Road Mobile Measures	  PAGEREF
_Toc164568695 \h  55

  HYPERLINK \l "_Toc164568696"  Area Source Measures	  PAGEREF
_Toc164568696 \h  57

  HYPERLINK \l "_Toc164568697"  Non-Road Measures	  PAGEREF
_Toc164568697 \h  60

  HYPERLINK \l "_Toc164568698"  Point Source Measures	  PAGEREF
_Toc164568698 \h  61

  HYPERLINK \l "_Toc164568699"  6.2  8-Hour Ozone Control Measures
PAGEREF _Toc164568699 \h  63

  HYPERLINK \l "_Toc164568700"  The Maryland Healthy Air Act (HAA)
PAGEREF _Toc164568700 \h  63

  HYPERLINK \l "_Toc164568701"  Architectural and Industrial Maintenance
Coatings Rule	  PAGEREF _Toc164568701 \h  66

  HYPERLINK \l "_Toc164568702"  Industrial Adhesives and Sealants Rule
PAGEREF _Toc164568702 \h  68

  HYPERLINK \l "_Toc164568703"  Portable Fuel Containers Rule:  Phase II
  PAGEREF _Toc164568703 \h  68

  HYPERLINK \l "_Toc164568704"  Consumer Products Rule:  Phase II
PAGEREF _Toc164568704 \h  69

  HYPERLINK \l "_Toc164568705"  6.3  Voluntary and Innovative Measures
PAGEREF _Toc164568705 \h  70

  HYPERLINK \l "_Toc164568706"  Regional Forest Canopy Program:
Conservation, Restoration, and Expansion	  PAGEREF _Toc164568706 \h  71

  HYPERLINK \l "_Toc164568707"  Clean Air Teleworking Initiative
PAGEREF _Toc164568707 \h  73

  HYPERLINK \l "_Toc164568708"  High Electricity Demand Day (HEDD)
Initiative	  PAGEREF _Toc164568708 \h  78

  HYPERLINK \l "_Toc164568709"  Emission Reductions from Transportation
Measures	  PAGEREF _Toc164568709 \h  78

  HYPERLINK \l "_Toc164568710"  7.0  Reasonably Available Control
Measure (RACM) Analysis	  PAGEREF _Toc164568710 \h  81

  HYPERLINK \l "_Toc164568711"  7.1 Analysis Overview and Criteria
PAGEREF _Toc164568711 \h  81

  HYPERLINK \l "_Toc164568712"  Implementation Date	  PAGEREF
_Toc164568712 \h  82

  HYPERLINK \l "_Toc164568713"  Enforceability	  PAGEREF _Toc164568713
\h  82

  HYPERLINK \l "_Toc164568714"  Technological Feasibility	  PAGEREF
_Toc164568714 \h  83

  HYPERLINK \l "_Toc164568715"  Economic Feasibility and Cost
Effectiveness	  PAGEREF _Toc164568715 \h  83

  HYPERLINK \l "_Toc164568716"  Substantial and Widespread Adverse
Impacts	  PAGEREF _Toc164568716 \h  83

  HYPERLINK \l "_Toc164568717"  De Minimis Threshold	  PAGEREF
_Toc164568717 \h  83

  HYPERLINK \l "_Toc164568718"  Advancing Achievement of 84 ppb Standard
  PAGEREF _Toc164568718 \h  84

  HYPERLINK \l "_Toc164568719"  Intensive and Costly Effort	  PAGEREF
_Toc164568719 \h  84

  HYPERLINK \l "_Toc164568720"  7.2 RACM Measure Analysis	  PAGEREF
_Toc164568720 \h  84

  HYPERLINK \l "_Toc164568721"  Analysis Methodology	  PAGEREF
_Toc164568721 \h  84

  HYPERLINK \l "_Toc164568722"  Analysis Results	  PAGEREF _Toc164568722
\h  84

  HYPERLINK \l "_Toc164568723"  7.3 RACM Determination	  PAGEREF
_Toc164568723 \h  84

  HYPERLINK \l "_Toc164568724"  8.0 Mobile Source Conformity	  PAGEREF
_Toc164568724 \h  86

  HYPERLINK \l "_Toc164568725"  8.1 Mobile Emissions Budget and the
Wilmington Region Transportation Conformity Process (includes Cecil
County)	  PAGEREF _Toc164568725 \h  87

  HYPERLINK \l "_Toc164568726"  8.2 Budget Level for On-Road Mobile
Source Emissions	  PAGEREF _Toc164568726 \h  87

  HYPERLINK \l "_Toc164568727"  Reasonable Further Progress Mobile
Budgets	  PAGEREF _Toc164568727 \h  88

  HYPERLINK \l "_Toc164568728"  Attainment Year Mobile Budgets	  PAGEREF
_Toc164568728 \h  88

  HYPERLINK \l "_Toc164568729"  8.3 Trends in Mobile Emissions	  PAGEREF
_Toc164568729 \h  89

  HYPERLINK \l "_Toc164568730"  9.0  Moderate Area Plan Commitments
PAGEREF _Toc164568730 \h  90

  HYPERLINK \l "_Toc164568731"  9.1 Schedules of Adopted Control
Measures	  PAGEREF _Toc164568731 \h  90

  HYPERLINK \l "_Toc164568732"  9.2 Stationary Source Thresholds
PAGEREF _Toc164568732 \h  93

  HYPERLINK \l "_Toc164568733"  10.0  Contingency Measures	  PAGEREF
_Toc164568733 \h  94

  HYPERLINK \l "_Toc164568734"  10.1  Contingency Overview	  PAGEREF
_Toc164568734 \h  94

  HYPERLINK \l "_Toc164568735"  10.2  Contingency Emission Reductions
for RFP Demonstration	  PAGEREF _Toc164568735 \h  94

  HYPERLINK \l "_Toc164568736"  Surplus Reductions from Existing
Measures	  PAGEREF _Toc164568736 \h  95

  HYPERLINK \l "_Toc164568737"  10.3  Contingency Emission Reductions
for Failure to Attain	  PAGEREF _Toc164568737 \h  96

  HYPERLINK \l "_Toc164568738"  11.0 Weight of Evidence Attainment
Demonstration	  PAGEREF _Toc164568738 \h  98

  HYPERLINK \l "_Toc164568739"  11.1  Ambient Air Monitoring
Measurements and Trends	  PAGEREF _Toc164568739 \h  99

  HYPERLINK \l "_Toc164568740"  The Ambient Monitoring Network	  PAGEREF
_Toc164568740 \h  99

  HYPERLINK \l "_Toc164568741"  Ozone Trends	  PAGEREF _Toc164568741 \h
100

  HYPERLINK \l "_Toc164568742"  Temperature Adjusted Ozone Trend
PAGEREF _Toc164568742 \h  107

  HYPERLINK \l "_Toc164568743"  Ambient Ozone Precursor Trend	  PAGEREF
_Toc164568743 \h  108

  HYPERLINK \l "_Toc164568744"  Supplemental Monitoring Initiatives
PAGEREF _Toc164568744 \h  109

  HYPERLINK \l "_Toc164568745"  11.2  The Challenge of Interstate
Transport	  PAGEREF _Toc164568745 \h  111

  HYPERLINK \l "_Toc164568746"  Westerly Transport	  PAGEREF
_Toc164568746 \h  113

  HYPERLINK \l "_Toc164568747"  Nocturnal Low Level Jet Transport
PAGEREF _Toc164568747 \h  119

  HYPERLINK \l "_Toc164568748"  Apportionment of Ozone Transport
PAGEREF _Toc164568748 \h  123

  HYPERLINK \l "_Toc164568749"  11.3  Modeled and Probable Range
Attainment Demonstration	  PAGEREF _Toc164568749 \h  125

  HYPERLINK \l "_Toc164568750"  Evaluation of Model Abilities	  PAGEREF
_Toc164568750 \h  125

  HYPERLINK \l "_Toc164568751"  Base Case and Future Year Modeling
PAGEREF _Toc164568751 \h  134

  HYPERLINK \l "_Toc164568752"  Probable Ranges	  PAGEREF _Toc164568752
\h  134

  HYPERLINK \l "_Toc164568753"  Alternative Control Strategies	  PAGEREF
_Toc164568753 \h  139

  HYPERLINK \l "_Toc164568754"  12.0 Attainment Demonstration	  PAGEREF
_Toc164568754 \h  143

  HYPERLINK \l "_Toc164568755"  12.1  Modeling Study Overview	  PAGEREF
_Toc164568755 \h  143

  HYPERLINK \l "_Toc164568756"  Background and Objectives	  PAGEREF
_Toc164568756 \h  143

  HYPERLINK \l "_Toc164568757"  Relationship to Regional Modeling
Protocols	  PAGEREF _Toc164568757 \h  146

  HYPERLINK \l "_Toc164568758"  Conceptual Description	  PAGEREF
_Toc164568758 \h  146

  HYPERLINK \l "_Toc164568759"  12.2	Domain and Data Base Issues
PAGEREF _Toc164568759 \h  147

  HYPERLINK \l "_Toc164568760"  Episode Selection	  PAGEREF
_Toc164568760 \h  147

  HYPERLINK \l "_Toc164568761"  Size of the Modeling Domain	  PAGEREF
_Toc164568761 \h  147

  HYPERLINK \l "_Toc164568762"  Horizontal Grid Size	  PAGEREF
_Toc164568762 \h  147

  HYPERLINK \l "_Toc164568763"  Vertical Resolution	  PAGEREF
_Toc164568763 \h  148

  HYPERLINK \l "_Toc164568764"  Initial and Boundary Conditions
PAGEREF _Toc164568764 \h  148

  HYPERLINK \l "_Toc164568765"  Meteorological Model Selection and
Configuration	  PAGEREF _Toc164568765 \h  149

  HYPERLINK \l "_Toc164568766"  Emissions Model Selection and
Configuration	  PAGEREF _Toc164568766 \h  149

  HYPERLINK \l "_Toc164568767"  Air Quality Model Selection and
Configuration	  PAGEREF _Toc164568767 \h  150

  HYPERLINK \l "_Toc164568768"  Quality Assurance	  PAGEREF
_Toc164568768 \h  150

  HYPERLINK \l "_Toc164568769"  12.3	Model Performance Evaluation
PAGEREF _Toc164568769 \h  151

  HYPERLINK \l "_Toc164568770"  Overview	  PAGEREF _Toc164568770 \h  151

  HYPERLINK \l "_Toc164568771"  Diagnostic and Operational Evaluation
PAGEREF _Toc164568771 \h  151

  HYPERLINK \l "_Toc164568772"  Summary of Model Performance	  PAGEREF
_Toc164568772 \h  155

  HYPERLINK \l "_Toc164568773"  12.4	Attainment Demonstration	  PAGEREF
_Toc164568773 \h  157

  HYPERLINK \l "_Toc164568774"  Overview	  PAGEREF _Toc164568774 \h  157

  HYPERLINK \l "_Toc164568775"  Modeling Attainment Test	  PAGEREF
_Toc164568775 \h  157

  HYPERLINK \l "_Toc164568776"  Unmonitored Area Analysis	  PAGEREF
_Toc164568776 \h  161

  HYPERLINK \l "_Toc164568777"  Emissions Inventories	  PAGEREF
_Toc164568777 \h  162

  HYPERLINK \l "_Toc164568778"  Summary and Conclusions of Attainment
Demonstration	  PAGEREF _Toc164568778 \h  162

  HYPERLINK \l "_Toc164568779"  12.5	Procedural Requirements	  PAGEREF
_Toc164568779 \h  168

  HYPERLINK \l "_Toc164568780"  Reporting	  PAGEREF _Toc164568780 \h
168

  HYPERLINK \l "_Toc164568781"  Data Archival and Transfer of Modeling
Files	  PAGEREF _Toc164568781 \h  168

Appendix A – (Chapter 3) Base Year Emission Inventory

Appendix A-1: Base Year Emission Inventory Methodologies

Appendix A-2: Point Source Base Year Inventory

Appendix A-3: Quasi-Point Source Base Year Inventory

Appendix A-4: Area Source Base Year Inventory

Appendix A-5: Mobile Source Base Year Inventory

Appendix A-6: Nonroad Source Base Year Inventory

Appendix B – (Chapter 4) Projection Year Methodologies

Appendix C – (Chapter 5) RFP Calculations

Appendix D – (Chapter 6) Regulatory Support Information

Appendix E – (Chapter 7) RACM Measures List

Appendix F – (Chapter 8) Mobile Budget Documentation

Appendix G – (Chapter 11) WOE Documentation

Appendix H – (Chapter12) Attainment Demonstration Modeling
Documentation

Appendix G – (Chapter 11) WOE Documentation

Appendix G-1:	Ozone Sensitivity to NOx Emissions

Appendix G-2:	Animated Google Earth Movie of Westerly Transport [DVD]

Appendix G-3:	Animated Google Earth Movie of Nocturnal Low Level Jet
Transport [DVD]

Appendix G-4:	Radar Wind Profiler Observations in Maryland:  A
Preliminary Climatology of the Low Level Jet

Appendix G-5:	The Low Level Jet in Maryland:  Profiler Observations and
Preliminary Climatology

Appendix G-6:	Characterizing Maryland Ozone by Meteorological Regime

Appendix G-7:	Regional Nature of Ozone Transport

Appendix G-8:	Comparison of CMAQ-calculated ozone to surface and aloft
measurements

Appendix G-9:	Uncertainty in CMAQ and Over-predictions of Future Year
Ozone Design Values

Appendix G-10:	Analysis of the Details of CMAQ 4.5.1 Chemistry

Appendix G-11:	The Role of Land-Sea Interactions on Ozone Concentrations
at the Edgewood, Maryland Monitoring Site

Appendix G-12:	A Summary of the 2002 Base Case and 2009 Future Base Case
CMAQ Runs

Appendix G-13:	The Relationship between Urban Tree Cover and Ground
Level Ozone

Appendix G-14:	Air Quality Benefits of an Aggressive Telecommute
Strategy

Appendix G-15:	WOE Probable Range With Voluntary Measures

1.0  Executive Summary

Introduction

Ground level ozone is considered a significant health based pollutant
and the US Environmental Protection Agency (EPA) has set a specific
national ambient air quality standard for ozone to best protect public
health.  This standard, known as the 8-Hour Ozone standard, is
implemented under the federal Clean Air Act (CAA).  Areas of the county
that monitor air pollution above the federal standard are designated
“nonattainment” and are therefore required to develop and implement
air quality plans called State Implementation Plans or SIPs that show
how a particular region will reduce pollution to the point where the
region meets the federal standards.

The Philadelphia Nonattainment Area (Philadelphia - Wilmington -
Atlantic City, PA - DE - MD - NJ ozone nonattainment region), which
includes Cecil County, Maryland, has been designated nonattainment under
the 8-Hour Ozone standard.  The following document explains the process
by which Cecil County and the region will reduce pollution and meet the
federal ozone standard by June 15th 2010, which is the designated
attainment date for the region.

This is a substantial good news story regarding Maryland’s improving
air quality.  The Maryland Department of the Environment (MDE) is very
proud of this SIP document as it shows, based on significant modeling
and weight of evidence analysis, that Cecil County will indeed attain
the ozone standard during the 2009 ozone season.

Emissions

A significant portion of this document is related to emissions.
Nitrogen Oxides (NOx) and Volatile Organic Compounds (VOC) emissions
create ozone under heat and sunlight.  Reductions in these precursor
emissions are a necessity to reduce ozone pollution.  MDE is responsible
for creating an emissions inventory for NOx and VOC that estimates the
actual emissions created by all the different emission sources in our
state.  Emissions come from a variety of sources including mobile
sources like cars and trucks, point sources like power plants, area
sources like lawnmowers, and non-road sources like construction
equipment and all terrain vehicles.

This document details the current emission inventory for NOx and VOC and
predicted emissions for the future.  It is important to predict
emissions in the future to track progress from emission reduction
programs and for incorporation into attainment analyses that predict
whether a region will meet the air quality standard or not.

The good news exhibited by this document is that NOx and VOC emissions
are going down in Cecil County and the region.  Control programs aimed
at reducing emissions have been developed and implemented and the
reductions required by these programs are significant.  Population
growth, economic growth, and the public need tend to tax the emission
reductions that come from control programs.  Despite these obstacles,
the overall trend in ozone forming emissions is downward and MDE
predicts that with additional reductions will come even cleaner air.

Control Programs

Over the past several decades MDE has adopted and implemented numerous
control programs (laws, regulations, voluntary measures) that reduce NOx
and VOC emissions in Maryland.  In addition, several new control
measures are being adopted specifically to help Maryland attain the
federal ozone standard.  The programs, in addition to the existing
control programs that continue to be implemented and enforced, allow
Maryland to develop an attainment demonstration that shows how Maryland
will meet the federal ozone standard.

The most significant new control program is the Maryland Healthy Air Act
(HAA), which significantly reduces NOx from Maryland’s older coal
burning power plants.  The HAA is more stringent than the parallel
federal rule called the Clean Air Interstate Rule and is the most
substantial emission control program ever adopted in Maryland.  The HAA
is the most aggressive power plant control program on the east coast.
Overall, the HAA will reduce Maryland power plant NOx emissions by 70%
(compared to 2002 levels) in 2009 and by 75% by 2012.  The 2009
reductions are a significant part of the attainment scheme developed by
MDE to meet the federal ozone standard.

Additional control programs being implemented to help Maryland meet the
federal ozone standard include several VOC rules targeted at adhesives
and sealants, lower VOC portable fuel containers, and lower VOC consumer
products.  Other non-traditional measures include an aggressive telework
program and a tree canopy program.

The following is a brief summary of new control measures being
implemented to assist Cecil County with attaining the 8-hour Ozone
standard.

Control Measures Summary*

2009

Control Measure

VOC

(tpd)	NOx

(tpd)

On Road Mobile Measures

1.85	3.78

Stage II/Refuel

0.00	0.00

OTC - Consumer Products Phase 1

0.14	0.00

OTC - Consumer Products Phase 2

0.02	0.00

OTC –  Low VOC Paints - AIM

0.39	0.00

OTC - PFC Phase 1

0.32	0.00

OTC - PFC Phase 2

0.03	0.00

OTC - Industrial Adhesives

0.10	0.00

Open Burning

0.00	0.00

Nonroad Model

1.50	0.36

Railroads (Tier 2)

0.00	0.16

Healthy Air Act (HAA)

0.00	0.00

Total

4.35	4.30

* All control level totals are rounded

Modeling

A significant part of the attainment demonstration for Maryland consists
of air quality modeling analysis.  Required by the CAA, air quality
models are run to examine what future air quality conditions will be and
whether a region will attain the standard or not by their designated
attainment date.  The models are not relied upon as the only attainment
test, but are an important part of the attainment demonstration for
Maryland.

The air quality modeling analysis completed for this SIP shows that
Cecil County, Maryland will attain the 8-hour ozone standard during the
2009 ozone season.  The predicted ozone level for the Fair Hill Monitor
in Cecil County for the summer of 2009 is 81 ppb, lower than the
standard of 85 ppb.  Other locations in the larger Philadelphia
Nonattainment area are not showing such robust improvements in overall
air quality and the direct modeling completed for this SIP does not show
predicted air quality levels below 85 ppb.  However, using other
analytical methods under an approach called weight of evidence, Maryland
believes that the entire region will indeed attain the 8-hour ozone
standard.

Weight of Evidence

As mentioned above, air quality models are not the only tool available
that can be used to predict attainment of the federal ozone standard.  A
weight of evidence approach can be used to further analyze air quality
data, trends, meteorology, model performance and model chemistry.  The
MDE has developed a significant weight of evidence that Cecil County and
the Philadelphia Nonattainment area will indeed meet the federal ozone
standard during the 2009 ozone season.

Some of the weight of evidence analyses utilized for the region
includes:

an analysis of the chemistry component of the Community Multi-scale Air
Quality (CMAQ) model

an analysis to the ozone sensitivity to NOx emission reductions

the effect of land-sea interactions on ozone at the Edgewood air quality
monitor

an analysis of the regional nature of ozone transport

an analysis of the potential benefits of an aggressive telecommuting
strategy

an analysis of the uncertainty in the CMAQ air quality model and the
over-prediction of ozone design values

an analysis of the effects of urban tree canopy cover on temperature and
ozone levels

In addition, other states in the nonattainment area are providing other
substantial weight of evidence analysis that lead to an attainment
demonstration for the region.  These additional weight of evidence
chapters from other states were not available in time for inclusion in
this SIP document.

Based on all of the above analysis and the air quality modeling
performed for Cecil County and the Philadelphia Nonattainment area,
there is a dramatic weight of evidence available that shows the region
will attain the 8-hour ozone standard.  The chart below shows a summary
of the Maryland ozone monitor design value ranges expected in the region
based on the modeling/ weight of evidence analysis.  All of the air
quality monitors in the region are predicted to be well below the 85ppb
8-hour ozone standard.

2.0  Introduction and Background

This document, entitled Cecil County, Maryland / Philadelphia
Nonattainment Area 8-Hour Ground Level Ozone State Implementation Plan,
presents the Maryland Department of the Environment's (MDE's) progress
in adopting and implementing air pollution control programs needed to
attain the 8-hour ozone standard by 2010 in Cecil County, Maryland.

2.1  State Implementation Plans

The State Implementation Plan (SIP) is a detailed document required for
states or regions that do not meet air quality levels set by the federal
government.  The Plan identifies how that State will attain and/or
maintain the primary and secondary National Ambient Air Quality
Standards (NAAQS) set forth in section 109 of the Clean Air Act ("the
Act") and 40 Code of Federal Regulations 50.4 through 50.12 and which
includes federally-enforceable requirements.  Each State is required to
have a SIP that contains control measures and strategies that
demonstrate how each area will attain and maintain the NAAQS.  These
plans are developed through a public process, formally adopted by the
State, and submitted by the Governor's designee to EPA. The Clean Air
Act requires EPA to review each plan and any plan revisions and to
approve the plan or plan revisions if consistent with the Clean Air Act.

SIP requirements applicable to all areas are provided in section 110 of
the Act.  Part D of Title I of the Act specifies additional requirements
applicable to nonattainment areas. Section 110 and part D describe the
elements of a SIP and include, among other things, emission inventories,
a monitoring network, an air quality analysis, modeling, attainment
demonstrations, enforcement mechanisms, and regulations which have been
adopted by the State to attain or maintain NAAQS. EPA has adopted
regulatory requirements which spell out the procedures for preparing,
adopting and submitting SIPs and SIP revisions that are codified in 40
CFR part 51.  EPA's action on each State's SIP is promulgated in 40 CFR
part 52.

The contents of a typical SIP fall into several categories: (1)
State-adopted control measures which consists of either
rules/regulations or source-specific requirements (e.g., orders and
consent decrees); (2) State-submitted comprehensive air quality plans,
such as attainment plans, maintenance plans rate of progress plans, and
transportation control plans demonstrating how these state regulatory
and source-specific controls, in conjunction with federal programs, will
bring and/or keep air quality in compliance with federal air quality
standards; (3) State- submitted "non-regulatory" requirements, such as
emission inventories, small business compliance assistance programs;
statutes demonstrating legal authority, monitoring networks, etc.); and
(4) additional requirements promulgated by EPA (in the absence of a
commensurate State provision) to satisfy a mandatory section 110 or part
D (Clean Air Act) requirement.

Once the Administrator of the EPA approves a state plan, the plan is
enforceable as a state law and as federal law under Section 113 of the
Act. If the SIP is found to be inadequate in EPA's judgment to attain
the NAAQS in all or any region of the state, and if the state fails to
make the requisite amendments, under Section110(c)(1), the EPA
Administrator may issue amendments to the SIP that are binding.  EPA is
required to impose severe sanctions on the states under three
circumstances: the state's failure to submit a SIP revision; on the
finding of the inadequacy of the SIP to meet prescribed air quality
requirements; and the state's failure to enforce the control strategies
that are contained in the SIP.  Sanctions include: withholding federal
funds for highway projects other than those for safety, mass transit, or
transportation improvement projects related to air quality improvement
or maintenance beginning 24 months after EPA announcement. No federal
agency or department will be able to award a grant or fund, license, or
permit any transportation activity that does not conform to the most
recently approved SIP.

2.2  Clean Air Act

The Clean Air Act was passed in 1970 to protect public health and
welfare. Congress amended the Act in 1990 to establish requirements for
areas not meeting the National Ambient Air Quality Standards. The Clean
Air Act Amendments of 1990 (CAAA) established a process for evaluating
air quality in each region and identifying and classifying nonattainment
areas according to the severity of its air pollution problem.  The CAAA
defines ground-level ozone as a criteria pollutant. In 1979 EPA
promulgated the 0.12 parts per million (ppm) 1-hour ozone standard.  In
1997, EPA issued a revised and stricter ozone standard of 0.08 ppm, or
85 parts per billion (ppb), measured over an eight-hour period. The
one-hour ozone standard was consequently revoked in June 2005. The Clean
Air Act also sets National Ambient Air Quality Standards for five other
criteria pollutants; carbon monoxide, particulate matter, lead, sulfur
dioxide and nitrogen dioxide.

In April 2004, EPA designated the Philadelphia - Wilmington - Atlantic
City, PA - DE - MD - NJ ozone nonattainment region as a “moderate”
nonattainment area for the eight-hour ozone standard under Subpart 2
area of Section 182 part b.  Cecil County is the Maryland portion of the
Philadelphia - Wilmington - Atlantic City, PA - DE - MD - NJ ozone
nonattainment region.  A map of the nonattainment area is shown in
Figure 2.1.

Figure 2.1 - Map of the Philadelphia - Wilmington - Atlantic City, PA -
DE - MD - NJ ozone nonattainment region

To meet the federal 8-hour standard for ozone, nonattainment areas are
required to develop their SIP documents to reduce ozone-forming
emissions of volatile organic compounds (VOCs) by at least 15 percent
between 2002-2008, and to reduce all ozone precursor emissions to a
level sufficient to attain the federal eight-hour standard by June 15,
2010. However, the region is required to demonstrate attainment of the
standard by the end of the last ozone season before that date, which is
September 2009.

2.3  SIP Requirements for Moderate Nonattainment Areas

The Clean Air Act Section 182 sets requirements for nonattainment areas
based on their classification.  Under the 1hr Ozone Standard, Cecil
County was classified as severe.  Under the 8-hour Ozone Standard Cecil
County was reevaluated and classified as moderate.

Based on the Severe 1hr Ozone Standard classification very stringent
measures were required in Cecil County:

Low new source review threshold for point sources at 25 tons per year;

Low threshold for definition of “Major” source requiring controls to
25 tons per year;

New Source Review offsets at 1.3 to 1

Enhanced I&M

Maryland will continue to implement the above listed 1hr ozone
requirements.  In addition to these restrictive severe area
requirements, Maryland will also implement the necessary moderate area
requirements listed below.

Reasonable Further Progress: 15% emission reduction from baseline

Attainment demonstration: Due 3 years from designation

NSR permits: required for new or modified major stationary sources

NOx control for RACT: requirement for major stationary VOC sources also
applies to major NOx sources

RACM/RACT: RACT required for all Control Technique Guideline (CTG)
sources and all other major sources

Stage II vapor recovery: required for all gas stations

Contingency measures: required for failure to meet Reasonable Further
Progress (RFP) milestones or attain

2.4  Eight-Hour Ozone Standard

In 1997, EPA issued a revised ozone health standard based on an 8-hour
measurement to protect human health against longer exposure periods.
Since the late 1980’s, more than 3,000 published health studies
indicated that health effects occur at levels lower than the previous
standard and that exposure times longer than one hour are of concern.
EPA established an 8-hour standard at 0.08 ppm / 85 ppb and defined the
new standard as a “concentration-based” form, specifically the
3-year average of the 4th highest daily maximum 8-hour ozone
concentration.

EPA changed the form of the standard to a concentration-based form
because it more accurately reflects actual human exposure and related
health effects. Even at relatively low levels, ozone may cause
inflammation and irritation of the respiratory tract, particularly
during physical activity. The resulting symptoms can include breathing
difficulty, coughing, and throat irritation. Breathing ozone can affect
lung function and worsen asthma attacks. Ozone can increase the
susceptibility of the lungs to infections, allergens, and other air
pollutants. Medical studies have shown that ozone damages lung tissue
and complete recovery may take several days after exposure has ended.

2.5  Ground Level Ozone

Ground-level ozone is an extremely reactive gas comprised of three atoms
of oxygen. Ozone (the primary constituent of smog) continues to be a
pollution problem throughout many areas of the United States. Unlike
many other pollutants, ground-level ozone is not directly emitted into
the atmosphere from a specific source. Instead, ground-level ozone is
formed when nitrogen oxides (NOx) chemically react with volatile organic
compounds (VOCs) through a series of complicated chemical reactions in
the presence of strong sunshine (ultraviolet light).

Because ozone formation is greatest when the sunlight is most intense,
the peak ozone levels typically occur in Maryland during hot, dry,
stagnant summertime conditions generally referred to as the ozone season
(May 1 to September 30). Peak Ozone concentrations exhibit a clear
seasonal cycle, with concentrations rising with the onset of warmer
weather in the spring and declining again as the autumn approaches.
Changing weather patterns can significantly contribute to yearly
differences in ozone concentrations. Years with summertime weather
conditions that are hot and dry will generally result in many more days
of poor air quality than cool and wet summers.

Figure 2.2 Formation of Ground Level Ozone

The formation of ozone is not an instantaneous process, nor is it
limited in geographical scope.  While many urban areas tend to have high
levels of ozone, even rural areas are subject to increased ozone levels
because wind carries ozone, and pollutants that form it, hundreds of
miles from their original sources. Numerous studies and modeling data
show compelling evidence that weather patterns often transport ozone,
and the pollutants responsible for ozone formation, well beyond the
locality that produced the emissions. In many cases, unhealthy days of
air pollution experienced in Maryland are exacerbated by pollutants
transported into Maryland from neighboring states.

2.6  Air Pollution and the Chesapeake Bay

Typically, air pollution is thought of as smog that affects people’s
health and reduces visibility. However, air pollution also contributes
to land and water pollution that affects the health of the Chesapeake
Bay’s resources - its fish, shellfish, and other animals. Over the
last thirty years, research has provided us with more knowledge on how
air pollution can directly affect the Bay.

Pollutants released into the air will eventually make their way back
down to the earth’s surface. Some of the factors that determine how
far pollutants can travel through the air include, the makeup of the
pollutant, weather conditions (wind, temperature, humidity), type and
height of the emission source (smokestack, automobile tail pipe), and
the presence of other chemicals in the air. Airborne pollutants fall to
the earth’s surface by wet deposition (precipitation), or dry
deposition (settling or adsorption). Airborne pollutants that deposit on
the landscape can be transported into streams, rivers, and the Bay by
runoff or through groundwater flow.

Excess nitrogen and chemical contaminants from atmospheric deposition
impact the Chesapeake Bay and its watershed. Too much nitrogen entering
the Chesapeake Bay leads to eutrophication; a process that causes an
accelerated growth of algae. Too much algae in the Bay blocks sunlight
needed for submerged aquatic vegetation to grow. Also, when the algae
dies it sinks to the bottom and decomposes in a process that depletes

the oxygen in the water.

The effects of nitrogen can also be seen in acid rain. Nitrogen oxides
(NOx) are one of the key air pollutants that cause acid deposition, and
results in adverse effects on aquatic and terrestrial ecosystems. Acid
deposition increases the acidity of water and soils. Increases in water
acidity can impair the ability of certain fish and aquatic life to grow,
reproduce, and survive. Increases in soil acidity can impair the ability
of some types of trees to grow and resist disease.

2.7  Health Effects

Ozone is a highly reactive gas that reacts strongly with living tissues,
as well as many man-made substances. Ninety percent of the ozone
breathed into the lungs is never exhaled, ozone molecules react with
lung tissue to cause several health consequences. Too much ozone in the
air we breathe can be harmful to people who work or exercise outdoors
regularly, anyone with respiratory difficulties, and especially to our
children. The most common symptom that people have when exposed to ozone
is pain when taking a deep breath.  Exposure to ozone can result in both
long-term and short-term effects in healthy individuals as well as those
who are already sensitive to air pollution, such as children, asthmatics
and the elderly.

Ozone long-term effects may include reduced lung function, scarring of
lung tissue, and even premature death.    Research suggests that
repeated exposure to ozone may cause damage to lung tissue, thereby
reducing lung function.  According to EPA, “Long-term exposures to
ozone can cause repeated inflammation of the lung, impairment of lung
defense mechanisms, and irreversible changes in lung structure, which
could lead to premature aging of the lungs and/or chronic respiratory
illnesses such as emphysema and chronic bronchitis.”

Children are at greater risk for ozone-related respiratory problems
because their lungs are still developing, they breathe more rapidly, and
they play outside during the afternoons when ozone is at its highest
levels. Children also inhale more air, hence more pollution per pound of
body weight than adults do.   Additionally, anyone suffering from lung
disease has even more trouble breathing when air is polluted with high
levels of ozone. Prolonged exposure, even to relatively low levels of
ozone, can even significantly reduce a healthy adult’s lung function.

Short-term effects among healthy populations include impaired lung
function and reduced ability to perform physical exercise.  For example,
healthy young people developed significant reduction of lung function,
additional coughing and breathing pains, and enhanced airway reactivity
to irritants when exposed to ozone at concentrations between 80-120
parts per billion (ppb) for 6.6 to 7.0 hours while moderately
exercising.  For reference, the new ozone standard issued by EPA in 1997
is a concentration of 0.08 ppm averaged over an eight-hour time period.
The Philadelphia Nonattainment Area does not currently achieve this
standard.  Among people who are especially sensitive to ozone pollution,
short-term effects include increased hospital admissions and emergency
room visits for respiratory diseases, like asthma.

In sum, health effects from exposure to ozone can include any or all of
the following:

(	Increased susceptibility to respiratory infection.

(	Impaired lung function and reduced ability to perform physical
exercise.

(	Severe lung swelling and death, due to short-term exposures greater
than

300 ppb.

Increased hospital admissions and emergency room visits from respiratory

            diseases.

Ozone also poses a threat to the health of natural ecosystems.
Scientific evidence suggests that air pollution weakens the immune
systems of many types of vegetation and can cause significant crop
damage.  In addition, rain and snow wash air pollution deposited on
vegetation and architectural surfaces into the streams and rivers of the
region and finally into the Chesapeake Bay.

2.8  Maryland Specific Health Effects

According to the U.S. Census Bureau, Census 2000 data, there are
5,296,486 people living in Maryland, of whom 1,136,846 were under 15
years of age, and of whom 599,307 were 65 or over.  This means that the
total number of children and elderly in Maryland was 1,736,153.
Approximately one third of Maryland’s population is more likely to
suffer the adverse effects of air pollution simply as a result of their
age.

According to an April 2006 report from the American Lung Association,
the group of people with respiratory disease in the state of Maryland
includes:

274,967 adult asthmatics and 100,370 child asthmatics;

147,226 residents with chronic bronchitis; and

57,310 residents with emphysema.

2.9  The Impact of Ozone on Agriculture

Because ozone formation requires sunlight, periods of high ozone
concentration coincide with the agriculture growing season in Maryland.
Ozone damage to plants can occur with or without any visible signs.
Consequently, many farmers are unaware that ozone is reducing their
yields. Ozone enters the plant’s leaves through its gas exchange pores
(stomata), just as other atmospheric gases do in normal gas exchange.
The ozone then dissolves in the water within the plant and reacts with
other chemicals, causing a variety of problems.

Ozone damage in the plant causes photosynthesis to slow, resulting in
slower plant growth. Such ozone induced problems also decrease the
numbers of flowers and fruits a plant will produce, and impair water use
efficiency and other functions. Plants weakened by ozone may be more
susceptible to pests, disease, and drought.

Most studies of the economic impact of air pollution on agriculture have
found that a 25 percent reduction in ambient ozone would provide
benefits of at least $1-2 billion annually in the United States.
Studies of soybean yields at the University of Maryland found a 10
percent loss of the soybean crop due to current levels of ozone in the
state. The same study showed that ozone exposure causes the loss of 6-8
percent of winter wheat and 5 percent of the corn crop yields to
Maryland farmers.

2.10  The Air Quality Index (AQI)

The AQI is an index used for reporting forecasted and daily air quality.
The AQI uses both a color-coded and numerical scale to report how clean
or polluted the air is and what associated health effects might be of
concern. The AQI focuses on health effects people may experience within
a few hours or days after breathing polluted air. The AQI is calculated
for five major pollutants regulated by the Clean Air Act: particulate
matter, ozone, carbon monoxide, sulfur dioxide, and nitrogen dioxide.

Figure 2.3 The Air Quality Index and Action Guide

Using the Air Quality Index, the Maryland Department of the Environment
and the Metropolitan Washington Council of Governments (COG) issue daily
air quality forecasts for the Baltimore metropolitan area (including
Cecil County), Washington metropolitan area, Western Maryland, and the
Eastern Shore. Extended range forecasts provide a three-day forecast so
people can better plan their week and take the opportunity to arrange
car pools, take mass transit, or take other actions to limit pollution
when air quality is predicted to be unhealthful.

MDE and COG issue the air quality forecasts to local media and hundreds
of businesses and individuals throughout the region. Anyone can sign up
to receive the free, daily email by visiting the AirWatch web site at
www.air-watch.net. The AirWatch web site provides the public with easy
access local and national air quality information. AirWatch offers daily
AQI forecasts and real-time AQI conditions throughout most of Maryland,
the District of Columbia, and Northern Virginia. Users of AirWatch may
also sign-up for AirAlerts to receive real-time email notifications for
when air quality reaches unhealthy levels in the region.

Figure 2.4 Air-Watch.net Real-time air quality data and Forecasts

2.11  Sources of Ozone Pollution in the Cecil County Area

There are a number of diverse sources that discharge VOCs and NOx, the
two primary pollutants responsible for ozone formation.  Human made
sources, called anthropogenic sources, are divided into four categories:
 point, area, on-road mobile and non-road mobile sources.  A fifth
category, "biogenic" emissions, includes all naturally occurring sources
of VOC emissions from trees, crops and other forms of vegetation.

Point sources are primarily manufacturing businesses that produce
emissions equal to or greater than 10 tons per year (tpy) of VOCs or 25
tpy of NOx.  Large industrial plants such as power plants and chemical
manufacturers are examples of point sources.

Area sources are smaller sources of air pollution whose emissions are
too small to be measured individually.  Examples of area sources include
commercial and consumer products (such as paints and hairspray),
bakeries, gasoline refueling stations, printing facilities, and autobody
refinishing shops.

Sources of air pollution that are not stationary are referred to as
mobile sources and are broken down into two categories:  on-road mobile
sources and non-road mobile sources.  The former include cars, vans,
trucks and buses (i.e. vehicles that operate on highways).  Non-road
mobile sources include boats, lawn and garden equipment, construction
equipment and locomotives.

Table 2-1

TOP TEN SOURCES OF MAN-MADE VOLATILE ORGANIC COMPOUNDS (VOCs) IN THE
CECIL COUNTY AREA FOR 2002 and 2009

	VOC

(Tons/Day)

Rank	Source Category	Source	2002	2009

1	Nonroad	Pleasure Craft Total	5.55	3.98

2	On-Road Mobile	Cars, Buses, Trucks	4.00	2.16

3	Nonroad	Recreational Equipment Total	1.68	2.45

4	Area	Architectural Surface Coatings	1.12	0.88

5	Area	Commercial & Consumer Solvents	0.87	0.83

4	Nonroad	Lawn and Garden Total	0.72	0.51

5	Area	Portable Fuel Containers	0.70	0.41

7	Area	Industrial Surface Coating	0.54	0.68

8	Area	Pesticide Application	0.37	0.37

9	Area	Residential Fuel Combustion	0.34	0.38

10	Area	Gasoline Marketing	0.31	0.35

	16.20	12.98

*The emissions estimates above are rounded to the nearest whole number.
The figures are MDE’s best estimates.  Total anthropogenic VOC
emissions in the Cecil County area were 17.58 tons per day in 2002 and
14.36 tons per day in 2009.

Table 2-2

TOP TEN SOURCES OF MAN-MADE NITROGEN OXIDES (NOx) IN THE CECIL COUNTY
AREA IN 2002 and 2009

	NOx

(Tons/Day)

Rank	Source Category	Source	2002	2009

1	On-Road Mobile	Cars, Buses, Trucks	14.21	7.23

2	Nonroad	Construction and Mining	1.02	0.85

3	Nonroad	Railroad-Line Haul	0.59	0.43

4	Nonroad	Pleasure Craft	0.44	0.58

5	Nonroad	Agricultural	0.37	0.32

6	Nonroad	Industrial	0.27	0.17

7	Area	Residential Fuel Combustion	0.10	0.11

8	Nonroad	Lawn and Garden	0.09	0.08

9	Nonroad	Recreational	0.06	0.08

10	Nonroad	Marine Vessels	0.06	0.08

	17.22	9.93

*The emissions estimates above are rounded to the nearest whole number.
The figures are MDE's best estimates.  Total anthropogenic NOx emissions
in the Cecil County area were 17.40 tons per day in 2002 and 10.29 tons
per day in 2009

2.12  Frequency of Violation of Federal Health Standard for Ozone

Since the Clean Air Act Amendments of 1990, Maryland has made
significant improvements in the quality of air. National, State, and
Local programs have all contributed to dramatically limit the amount of
pollution that is generated, which has reduced the number of days that
unhealthful air is experienced throughout the region. Mandated
reductions in emissions from businesses and industries, and
technological improvements in automobiles have brought about a steady
progress in air quality.

The federal 8-hour ozone standard is set at 0.08 parts per million (85
parts per billion) of ozone averaged over an eight hour period. Figure
2.5 applies the eight-hour standard to historic data and shows the
number of days that exceeded levels under the new standard.  The figure
also clearly shows an improving trend for Maryland’s air quality since
1980. While annual fluctuations can be attributed to weather (hot,
stagnant summers are favorable for ozone formation), the downward trend
is indicative of controls on sources of air pollution and the resulting
levels of ozone precursors present in the ambient air.

Figure 2.5 Maryland 8-Hour Ozone Exceedance Days per Year

2.13  Required SIP Principles

Section 110 of the 1990 CAAA specifies the conditions under which EPA
approves SIP submissions. These requirements are being followed by the
Maryland Department of the Environment in developing this air quality
plan or SIP. In order to develop effective control strategies, EPA has
identified four fundamental principles that SIP control strategies must
adhere to in order to achieve the desired emissions reductions. These
four fundamental principles are outlined in the General Preamble to
Title I of the Clean Air Act Amendments of 1990 at Federal Register
13567 (EPA, 1992a). The four fundamental principles are:

emissions reductions ascribed to the control measure must be
quantifiable and    measurable;

the control measures must be enforceable, in that the state must show
that they have adopted legal means for ensuring that sources are in
compliance with the control measure;

measures are replicable; and

the control strategy be accountable in that the SIP must contain
provisions to track emissions changes at sources and to provide for
corrective actions if the emissions reductions are not achieved
according to the plan.

2.14  Sanctions

EPA must impose various sanctions if the State does not submit a plan;
or

submits a plan that the EPA does not approve; or fails to implement the
plan. These sanctions include: withholding federal highway funding;
withholding air quality planning grants; and imposing a federal plan
(“federal implementation plan.”). Failure to submit or implement a
plan will have significant consequences for compliance with conformity
requirements.

2.15  Reasonable Further Progress

As a moderate area, EPA requires the Philadelphia - Wilmington -
Atlantic City, PA - DE - MD - NJ ozone nonattainment area (Philadelphia
NAA) to demonstrate Reasonable Further Progress towards attainment by
2008.  Each state in the Philadelphia NAA is responsible for meeting
this requirements for the counties from each state connected to the
nonattainment area.

EPA’s implementation guidance requires that a state’s moderate ozone
nonattainment areas, such as Cecil County, MD, with an approved 15% VOC
reduction plan for the period 1990-1996 (required for former 1-hour
ozone non-attainment areas) demonstrate a 15% Reasonable Further
Progress by 2008.  Chapter 5 contains Cecil County’s reasonable
further progress demonstration for the years 2002-2008. The region will
need to fulfill the 2002-2008 reasonable further progress requirements
by January 1, 2009.

In order to demonstrate reasonable further progress, a region must show
that its expected emissions, termed controlled inventories, of NOx and
VOC will be less than or equal to the target levels set for the end of
the reasonable further progress period, or “milestone year”. For the
RFP period 2002-2008, the “target inventories” of emissions are the
maximum quantity of anthropogenic emissions permissible during the 2008
milestone year.

2.16  Analysis of Reasonably Available Control Measures (RACM)

An extensive list of potential control measures was analyzed and
evaluated against criteria used for potential RACM measures. Individual
measures must meet the following criteria: will reduce emissions in
Cecil County by the beginning of the 2008 ozone season (May 1, 2008);
are enforceable; are technically feasible; are economically feasible,
defined as a cost of $3,500 to $5,000 per ton or less; would not create
substantial or widespread adverse impacts within the region; and do the
emissions from the source being controlled exceed a de minimus
threshold, defined as 0.1 tons per day.  Based on the analysis completed
for Cecil County which relied heavily upon a very formal RACM analysis
completed for the Washington DC Nonattainment area (where MDE actively
participated in a RACM workgroup) there were no identified RACM measures
that if implemented would advance attainment in Cecil County.

2.17  Contingency Measures

In the event that the reductions anticipated in the 2008 Reasonable
Further Progress demonstrations or the 2009 attainment demonstration are
not realized within the timeframes specified, there must be contingency
measures ready for implementation. EPA issued guidance says that
contingency measures must provide for a 3% reduction in adjusted 2002
base year inventory for both Reasonable Further Progress and attainment.
A minimum of 0.3 % VOC must be included. The total reductions required
for RFP contingency are 0.51 tons per day of VOC, which Cecil County
meets  The measures proposed as contingency measures are listed in
Chapter 10.  Chapter 10 contains detail on these measures, how they
would be implemented, enforced, and the amount of reduction benefit
expected.

3.0  The 2002 Base-Year Inventory

3.1  Background and requirements

The 2002 Base-Year Inventory is published in a separate document, "2002
Base Year Emissions Inventory & QA/QC Plan Maryland," (June 15, 2006).
This document was submitted to EPA Region III.  This document was
prepared the Maryland Department of the Environment.  It is available
for inspection at the Air and Radiation Management Administration, 1800
Washington Boulevard, Suite 730, Baltimore, Maryland 21230.  Relevant
portions of this document including, source category listings and
descriptions, methods and data sources, emission factors, controls,
spatial and temporal allocations, and example calculations are included
in Appendix A1.  The full base year inventory document is attached to
this SIP in Appendix A.

This emissions inventory covers Cecil County Maryland, which is
classified as a moderate nonattainment areas (part of the larger
Philadelphia NAA) for ozone by the U.S. Environmental Protection Agency
(EPA).  The 2002 emissions inventory is the starting point for
calculating the emissions reduction requirement needed to meet the 15%
VOC/NOx emissions (for man-made sources of emissions) reduction goal by
2008 to meet reasonable further progress requirements prescribed for
moderate nonattainment areas by the Clean Air Act Amendments and EPA.

This separately published document, which was previously submitted to
EPA, addresses emissions of volatile organic compounds (VOCs), oxides of
nitrogen (NOx), and carbon monoxide (CO) on a typical summer ozone
season day and annual basis.  Included in the inventory are stationary
anthropogenic (man-made), biogenic (naturally occurring), and non-road
and on-road mobile sources of ozone precursors.

Table 3-1

2002 Base-Year Inventory - Cecil County, MD

Philadelphia - Wilmington - Atlantic City, PA - DE - MD - NJ
Nonattainment Area

 (Tons/Day)

Source Category	VOC 	NOx 10

Point	0.28	0.02

Area	4.93	0.20

Non-Road	8.37	2.97

On-Road Mobile	4.00	14.22

Biogenics	42.94	0

Total (excluding Biogenics)	17.58	17.40

3.2  Total Emissions by Source

 Point Sources

For emissions inventory purposes, point sources are defined as
stationary, commercial, or industrial operations that emit more than 10
tons per year (tons/year) of VOCs or 25 tons/year or more of NOx or CO.
The point source inventory consists of actual emissions for the
base-year 2002 and includes sources within the geographical area of the
Maryland portion of the Philadelphia - Wilmington - Atlantic City, PA -
DE - MD - NJ ozone nonattainment area.

For source category listings and descriptions, methods and data sources,
emission factors, controls, spatial and temporal allocations, and
example calculations please refer to Appendix A1.

For Base-Year Emission Inventory data please refer to Appendix A2.

Quasi-Point Sources

The Maryland Department of the Environment Air and Radiation Management
has identified several facilities that due to size and/or function are
not considered point sources. The MDE has established quasi-point source
emissions to simplify the data collection process and the inventory
summary process.  These establishments contain a wide variety of air
emission sources, including traditional point sources, on-road mobile
sources, off-road mobile sources and area sources.  For each particular
establishment, the emissions from these sources are totaled under a
single point source and summary documents include these
“quasi-point” sources as point sources.

Quasi-point sources will include all emissions at the facility
regardless of whether they are classified as point, area, nonroad, or
mobile source emissions.  These emissions are actual emissions reported
for the facilities.  No quasi-point sources were identified within the
Maryland portion of the Philadelphia - Wilmington - Atlantic City, PA -
DE - MD - NJ ozone nonattainment area.

For source category listings and descriptions, methods and data sources,
emission factors, controls, spatial and temporal allocations, and
example calculations please refer to Appendix A1.

For Base-Year Emission Inventory data please refer to Appendix A3.

Area Sources

Area sources are sources of emissions too small to be inventoried
individually and which collectively contribute significant emissions.
Area sources include smaller stationary point sources not included in
the states' point source inventories such as printing establishments,
dry cleaners, and auto refinishing companies, as well as small
stationary sources.

Area source emissions typically are estimated by multiplying an emission
factor by some known indicator of collective activity for each source
category at the county (or county-equivalent) level.  An activity level
is any parameter associated with the activity of a source, such as
production rate or fuel consumption that may be correlated with the air
pollutant emissions from that source.  For example, the total amount of
VOC emissions emitted by commercial aircraft can be calculated by
multiplying the number of landing and takeoff cycles (LTOs) by an
EPA-approved emission factor per LTO cycle for each specific aircraft
type.

Several approaches are available for estimating area source activity
levels and emissions.  These include apportioning statewide activity
totals to the local inventory area and using emissions per employee (or
other unit) factors.  For example, solvent evaporation from consumer and
commercial products such as waxes, aerosol products, and window cleaners
cannot be routinely determined for many local sources.  The per capita
emission factor assumes that emissions in a given area can be reasonably
associated with population.  This assumption is valid over broad areas
for certain activities such as dry cleaning and small degreasing
operations.  For some other sources an employment based factor is more
appropriate as an activity surrogate.

For source category listings and descriptions, methods and data sources,
emission factors, controls, spatial and temporal allocations, and
example calculations please refer to Appendix A1.

For Base-Year Emission Inventory data please refer to Appendix A4.

Mobile Sources

On-road mobile sources include all vehicles registered to use the public
roadways.  The predominant emission source in this category is the
automobiles, although trucks and buses are also significant sources of
emissions.

The computation of highway vehicle emissions required two primary
entities: a) vehicle emission factors and b) vehicle activity.

The Emission factors are generated by using the latest version of U.S.
EPA’s emission factor model MOBILE6.2. Vehicle activity (vehicle miles
traveled – termed VMT for short) was obtained from the Maryland State
Highway Administration (SHA) and the Maryland Department of
Transportation. VMT data from SHA, based on vehicle traffic counts on
the roadway system, is mainly used for rural counties.

In a simple modeling scenario, the product of emission factor and
vehicle miles traveled should yield emission levels for that scenario.
Proper units and conversion are used to arrive at reasonable emission
estimates.

In a complex modeling scenario many types of emissions such as exhaust,
evaporative, diurnal, crankcase, refueling, etc., emissions are computed
separately and treated with the appropriate activity levels to yield a
complex model result.

MOBILE6 expects enormous amount of local data input such as the fleet
characteristics, fleet mileage accrual rates, speed, fuel parameters,
inspection and maintenance (I/M) program in place, weather data, and so
on.

In MOBILE6 emission factor model, the total highway vehicle population
is characterized by the following 16 composite vehicle type categories:

LDV	- Light-Duty Vehicles (Passenger Cars)

LDT1	- Light-Duty Trucks 1

LDT2	- Light-Duty Trucks 2

LDT3	- Light-Duty Trucks 3

LDT4	- Light-Duty Trucks 4

HDV2B- Class 2b Heavy Duty Vehicles

HDV3	- Class 3 Heavy Duty Vehicles

HDV4	- Class 4 Heavy Duty Vehicles

HDV5	- Class 5 Heavy Duty Vehicles

HDV6	- Class 6 Heavy Duty Vehicles

HDV7	- Class 7 Heavy Duty Vehicles

HDV8A- Class 8a Heavy Duty Vehicles

HDV8B- Class 8b Heavy Duty Vehicles

HDBS	- School Buses

HDBT	- Transit and Urban Buses

MC	- Motorcycles

These composite vehicle types are further classified into 28 vehicle
types - gasoline or diesel vehicles depending on the vehicle types. All
motorcycles are gasoline based and transit and urban buses are diesels.
The category of  “School Bus” can be either a gasoline or diesel
powered vehicle.

MOBILE6 also allows for the modeling of other fuel type vehicle such as
hybrids and alternate fuel vehicles (AFV) as a special case in a complex
modeling initiative.

MOBILE6 model produces emission factors, for each of the 28 vehicle
types, and one composite factor for all vehicle types.

A post-processing system takes care of all emission computations of the
modeling domain by aggregating the emissions from roads/links
appropriate to the area and produces meaningful reports by area, by
vehicle type and by roadway type.

For source category listings and descriptions, methods and data sources,
emission factors, controls, spatial and temporal allocations, and
example calculations please refer to Appendix A1.

For Base-Year Emission Inventory data please refer to Appendix A5.

Nonroad Sources

Emissions for all nonroad vehicles and engines except airport (aircraft,
ground support equipment (GSE) and, auxiliary power units (APU)),
locomotives, and diesel marine vessels were calculated using EPA’s
NONROAD2005.0.0 (dt. 12/02/2005) model. Since the time it was first
issued on 12/02/2005, this model version underwent several corrections.
The base year nonroad inventory was created using the version current as
of 3/21/2006.

Emissions from the “nonroad vehicles and engines” category result
from the use of fuel in a diverse collection of vehicles and equipment,
including vehicles and equipment in the following categories:

Recreational vehicles, such as all-terrain vehicles and off-road
motorcycles;

Logging equipment, such as chain saws;

Agricultural equipment, such as tractors;

Construction equipment, such as graders and back hoes;

Industrial equipment, such as fork lifts and sweepers;

Residential and commercial lawn and garden equipment, such as leaf and
snow blowers.

Aircraft ground support equipment.

The nonroad model estimates emissions for each specific type of nonroad
equipment by multiplying the following input data estimates:

Equipment population for base year (or base year population grown to a
future year), distributed by age, power, fuel type, and application;

Average load factor expressed as average fraction of available power;

Available power in horsepower;

Activity in hours of use per year; and

Emission factor with deterioration and/or new standards.

The emissions are then temporally and geographically allocated using
appropriate allocation factors.

Aircraft (military, commercial, general aviation, and air taxi) and
auxiliary power units (APU) operated at airports along with locomotives
and diesel marine vessels are also considered nonroad sources and are
included in the nonroad category.

For source category listings and descriptions, methods and data sources,
emission factors, controls, spatial and temporal allocations, and
example calculations please refer to Appendix A1.

For Base-Year Emission Inventory data please refer to Appendix A6.

Biogenic Emissions

An important component of the inventory is biogenic emissions.  Biogenic
emissions are those resulting from natural sources. Biogenic emissions
are primarily VOCs that are released from vegetation throughout the day.
 Biogenic emissions of NOx include lightning and forest fires. EPA used
a biogenic computer model (BEIS3.12) to estimate biogenic emissions for
each county in the country for all twelve months of the year 2002.

Emissions data for Cecil County, MD ozone non-attainment area counties
were acquired from the EPA website
(ftp://ftp.epa.gov/EmisInventory/2002finalnei/biogenic_sector_data/).
EPA has recommended that states use these emissions in case they do not
have their own estimated biogenic emissions. Cecil County, MD portion of
the Philadelphia - Wilmington - Atlantic City, PA - DE - MD - NJ ozone
nonattainment area decided to use the inventories provided by the EPA.

For Base-Year Emission Inventory data please refer to Appendix C1.

3.3 Emissions Trends

Reviewing emissions trends is an excellent way of tracking air quality
progress and control measure progress.  The difficulties in trending
emissions are however significant.  Emission estimating methodologies
and emission estimating models change constantly and it is difficult to
compare decades worth of emissions data.  As these emission estimating
methodologies become more specific and more accurate emissions may go up
or down depending on the methodology.  In addition, increases in
population and economic growth tend to make trending difficult.  It is
important to note these issues when reviewing emissions trends over long
time periods.

The following emissions trends have been prepared to examine the
Maryland portion of the Philadelphia - Wilmington - Atlantic City, PA -
DE - MD - NJ ozone nonattainment area emissions over the past 30 years.
The 1970’s and 1980’s data was extracted from the 1-hr ozone SIPs
developed in the 1990’s.

 Figure 3.1 Point Source Emission Trends in Tons Per Day*

*As point source data became increasingly important in the 1990’s, the
data collection process for these sources became more rigid.  Overall
trends in point sources are difficult to gauge, as historic data was not
provided in detail to MDE.

  Figure 3.2 Area Source Emission Trends in Tons Per Day

Figure 3.3 Mobile Source Emission Trends in Tons Per Day

  Figure 3.4 Nonroad Source Emission Trends in Tons Per Day

    Figure 3.5 All Sources Emission Trends in Tons Per Day

4.0  The 2008 and 2009 Projected Inventories

Part II of EPA’s rule to implement the 8-hour NAAQS requires that
Cecil County achieve a 15% reduction by 2008 using reductions in either
VOC or NOx emissions or with any combination of the two.  Also an
inventory for the attainment year 2009 is required for the region.  The
reduction must be calculated from the anthropogenic emissions levels
reported in the 2002 Base-Year Inventory after those levels have been
adjusted to reflect the expected growth in emissions between 2002 and
2008.  The 2002 Base-Year Inventory is described in Chapter 3. This
chapter presents the 2008 and 2009 Projection Inventories, the
estimation of the levels of emissions to be expected in those years
before the consideration of emission controls.

The 2008 and 2009 projected inventories are derived by applying the
appropriate growth factors to the 2002 Base-Year Emissions Inventory.
EPA guidance describes four typical indicators of growth.  In order of
priority, these are product output, value added, earnings, and
employment. Surrogate indicators of activity, for example population
growth, are also acceptable methods.

Maryland Department of Planning, Planning Data Services employment
projections and Cooperative Forecasting results (population and housing
projections), prepared and officially adopted by the Baltimore
Metropolitan Council (BMC) were used to project emissions from area
sources.  Projections for onroad emissions were developed using
MOBILE6.2 (January 2003) model (please see Appendix F for information on
mobile source emissions).

EPA’s nonroad model, NONROAD2005, was used for developing both 2008
and 2009 nonroad model inventories. BMC’s Round 6A Cooperative
Forecasting results, Maryland Department of Planning, Planning Data
Services projections and the Economic Growth Analysis System (EGAS)
model were used to project growth in the additional nonroad source
categories such as railroad locomotives, marine vessels and airports.
The Economic Growth Analysis System (EGAS) model was used to project
growth in point source emissions.

4.1  Growth Projection Methodology

The following sections describe the method followed to determine the
projected inventories for 2008 and 2009.

Growth Projection Methodology for Point Sources: EGAS

The growth in point source emissions is projected using EGAS version
5.0.  Point source emissions for 2002 are provided from the state data
sources and the model is run with the following options selected:
projections are run by Source Classification Code; the Bureau of Labor
Statistics national economic forecast; and the baseline regional
economic forecast.

For source category listings and descriptions, projection methods and
data sources, and surrogate growth indicators please refer to Appendix
B1.

Point source emission projection data is contained in Appendix A2

Growth Projection Methodology for Quasi-Point Sources

Quasi-point sources will include all emissions at the facility
regardless of whether they are classified as point, area, nonroad, or
mobile source emissions.  These emissions are actual emissions reported
for the facilities.

No quasi-point sources are located in Cecil County, MD.

Growth Projection Methodology: Area Sources

Base-year area source surrogate growth factors for 2002 were calculated
using 2002 population, household, and employment data.  Linearly
interpolating between 2000 and 2005 data produced the 2002 data.
Dividing Round 6A population, household, and employment forecasts for
the analysis year by the derived 2002 values for the region produced the
growth factors for the periods of 2002 to 2008 and 2002 to 2009.
Categories related to transport and storage of gasoline were grown using
projected vehicle miles traveled (VMT) for analyses years. Area
projection inventories are contained in Appendix B. The growth factors
used for the 2008 and 2009 projection years are presented in Tables 4-1
and 4-2.  The growth factors were applied to emissions categories by
specific jurisdictions.

Table 4-1:  2002-2008 Growth Factors

Jurisdiction

Employment

Population

Household13

VMT

 Cecil County 	1.2247	1.0957	1.1181	1.1189

Table 4-2:  2002-2009 Growth Factors

Jurisdiction

Employment 12

Population13

Household 13

VMT 14

 Cecil County	1.2636	1.1080	1.1359	1.1431

The 2008 and 2009 emissions for area sources are calculated by
multiplying the 2002 base-year area emissions by the above growth
factors for the appropriate year for each jurisdiction.  Each area
source category was matched to an appropriate growth surrogate based on
the activity used to generate the base-year emission estimates.
Surrogates were chosen as follows:

Surface Coating – depending on whether emission factors were based on
employment or population, surrogate chosen varied with individual
sub-categories. For example, automobile refinishing category was grown
using employment as the emission factor was based on it, but population
was chosen for growing traffic markings as its emission factor was based
on population.

Commercial/Consumer Solvent Use - population was chosen as the growth
surrogate since 2002 emissions are based on per capita emission factors.

Residential Fuel Combustion – households was chosen as the growth
surrogate.

Industrial/Commercial/Institutional Fuel Combustion - employment was
chosen as the growth surrogate except for the commercial/institutional
coal combustion category, where no growth was assumed.

Vehicle Fueling (Stage II) and Underground Tank Breathing - all gasoline
marketing categories were based on vehicle miles traveled (VMT) data
since VMT is an appropriate surrogate for gasoline sales. Emission
factors for these categories are based on gasoline sales.

Open Burning - population was chosen as the growth surrogate as yard
wastes, land debris, etc. increase with population.

Structural Fires, Motor Vehicle Fires – population was chosen as the
growth surrogate.

Publicly Owned Treatment Works (POTW) – households was chosen as the
growth surrogate.

Dry Cleaning - population was chosen as the surrogate.

Graphic Arts - population was used to estimate growth since emissions
are based on per capita emission factors.

Surface Cleaning - employment growth was used as the surrogate.

Tank Truck Unloading –growth in VMT was applied to this category since
base-year emissions are calculated using gasoline sales.

Municipal Landfills - Base-year emissions are estimated using data on
total refuse deposited.  Population was chosen as a surrogate since
deposited waste is from the general population rather than industrial
facilities.

Asphalt Paving - population was chosen as the surrogate since base-year
emissions are calculated using per capita emission factors.

Bakeries, Breweries - population was chosen as the surrogate.

Soil/Groundwater Remediation - zero growth was applied to this category.
 The number of remediations during the ozone season, used to generate
base-year emissions, does not directly correlate to population,
households, or employment growth.

General Aviation and Air Taxi Emissions - Emissions from small airports
were projected using the EGAS 5.0 model.

Aircraft Refueling Emissions - emissions from refueling of aircrafts was
projected based on employment.

Portable Fuel Container Emissions - emissions from portable fuel
containers were grown based on population.

Railroad Locomotives - employment growth was used as the surrogate.

Forest Fires, Slash Burning, Prescribed Burning – zero growth was
applied to this category.

Accidental Oil Spills - zero growth was applied to this category.

Incineration– zero growth was applied to this category.

Pesticide Application - zero growth was applied to this category.

For source category listings and descriptions, projection methods and
data sources, and surrogate growth indicators please refer to Appendix
B1.

Area source emission projection data is contained in Appendix A4.

Growth Projection Methodology: Nonroad Sources

The 2008 and 2009 nonroad source inventories were created through the
use of EPA’s NONROAD2005.1.0 model (dt. 06/12/2006), except for
locomotives, marine diesel vessels, and aircrafts. The base year 2002
nonroad source inventory was created using NONROAD2005.0.0 model (dt.
12/02/2005). Since the time it was first issued on 12/02/2005, this
model version underwent several corrections. The base year nonroad
inventory was created using the version current as of 3/21/2006.

The two model versions (NONROAD2005.0.0 and NONROAD2005.1.0) differ only
in the options provided in their graphic user interfaces (GUI) and not
in emission factors, base year equipment population, activity, load
factor, average lifetime, scrappage function, growth estimates, and
geographic and temporal allocation for any nonroad equipment and engine.
Therefore, emissions produced by the two versions for a particular
county, month, season, or year are the same.

Nonroad model runs were made Cecil County, Maryland for an average ozone
season day. First the model was run for the entire summer season
(June-August) and then total emissions calculated this way was divided
by the total number of days (92) in the season to get an average ozone
season day emissions. Since ozone season extends from May through
September, monthly fuel data was averaged for this period to get fuel
parameters reflecting the ozone season period. These ozone season
averaged fuel parameters were then used in the above mentioned ozone
season runs for the region.

Methodology to prepare inputs for the ozone season day is provided
below.

Temperature:

Temperature data was acquired from the National Climatic Data Center
(NCDC). Hourly average temperature data were collected for Baltimore
Washington International (BWI) station for the top ten 8-hour maximum
ozone days between 2002-2004. Then minimum, maximum, and average
temperatures were computed from this hourly temperature dataset.

Fuel inputs:

Month specific data for fuel RVP and oxygen weight percent were
collected from the MDE Mobile Source Division. The data was averaged for
the period May through September to get ozone season average inputs.
Model defaults were used for gas, diesel, marine diesel, and CNG/LPG
sulfur percent.  Stage II controls of zero percent was assumed for the
model runs.

Model inputs (temperature, fuel, and other parameters) for both 2008 and
2009 are listed below:

NONROAD Model Inputs

Parameters 	2008 Values 	2009 Values

Min. Temperature 	65.55	65.55

Max. Temperature 	87.6	87.6

Avg. Temperature 	76.8	76.8

Reid Vapor Pressure (RVP) 	6.6	6.6

Gas Sulfur (%) 	0.003	0.003

Diesel Sulfur (%) 	0.0348	0.0348

Marine Diesel Sulfur (%) 	0.0408	0.0408

CNG/LPG Sulfur (%) 	0.003	0.003

Oxygen Weight (%) 	2.0	2.0

Stage II Control (%) 	0	0

Since the nonroad model does not generate emissions for aircraft, APU,
locomotives, and commercial diesel marine vessels, these were either
projected from the base year emissions using the BMC Round 6A
Cooperative Forecast or the EGAS model. Below are the details for
projecting emissions for the above mentioned individual nonroad
categories.

Aircraft emissions (military, commercial, general aviation, air taxi)

Aviation emissions from small airports were projected using the EGAS 5.0
model.

Ground support equipment emissions

The NONROAD2005.1.0 model generated these emissions for small airports.
The Nonroad model calculates emissions based on GSE population only.

Commercial Diesel Marine Vessels

Base year emissions from commercial diesel marine vessels were grown to
future years using employment as the surrogate.

Railroad

Railroad or locomotive emissions were grown using employment as the
surrogate.

For source category listings and descriptions, projection methods and
data sources, and surrogate growth indicators please refer to Appendix
B1.

Nonroad mobile source emission projection data is contained in Appendix
A6.

Growth Projection Methodology: Onroad Sources

The 2008 and 2009 mobile source inventories were created through the use
of several models including Mobile6.2, the Highway Performance
Monitoring System (HPMS), and a transportation model described in the
appendix of this report.  A full description of this mobile emission
estimating process can be found in Appendix F of this report.

Biogenic Emission Projections

Biogenic emission inventories for 2009 are the same as those used for
the 2002 base year for Cecil County. Year specific biogenic inventories
for 2009 were not estimated. 2002 base year emissions were estimated by
EPA using BEIS3.12 model. No 2008 biogenic inventories were prepared as
they are not used to determine rate of progress.

4.2  Offset Provisions, Emission Reduction Credits and Point Source
Growth

The Act requires that emission growth from major stationary sources in
nonattainment areas be offset by reductions that would not otherwise be
achieved by other mandated controls.  The offset requirement applies to
all new major stationary sources and existing major stationary sources
that have undergone major modifications.  Increases in emissions from
existing sources resulting from increases in capacity utilization are
not subject to the offset requirement.  For the purposes of the offset
requirement, major stationary sources include all stationary sources
exceeding an applicable size cutoff.  The NSR thresholds for Cecil
County are 25 tpy VOC and 25 tpy NOx.

EPA has issued guidance on the inclusion of emission reduction credits
in the projected emissions inventory.  The guidance states “The base
year inventory includes actual emissions from existing sources and would
not normally reflect emissions from units that were shutdown or
curtailed before the base year (2002), as these emissions are not “in
the air” for purposes of demonstrating attainment, they must be
specifically included in the projected emissions inventory used in the
attainment demonstration along with other growth in emission over the
base year inventory.  This step assures that emissions from shutdown and
curtailed units are accounted for in attainment planning.”   Emission
reduction credits are included in a revised attainment demonstration
projected inventory.  A list of these emission reduction credits and
associated facilities is shown in Table 4.2.1.

Table 4.2.1 Emission Reduction Credits

Facility Name	State

Facility Identifier	Pollutant Code	Emission Reduction Credits (TPY)

Bethlehem Steel	005-0147	NOX	701

Pulaski Incinerator	510-0498	NOX	302

Quebecor Printing	003-0274	NOX	2

G. Heileman Brewing (Strohs)	005-0129	NOX	24

Grief Brothers Corp.	005-0134	NOX	1

U.S.Can - Sparrows Pt. (Amer Nat)	005-0183	NOX	7

TPS Technologies, Inc. -Todd's La.	005-2131	NOX	16

Simpkins Industries - River Rd	027-0005	NOX	87

General Electric	027-0020	NOX	82

Alltrista Metal Services	510-0508	NOX	2

Trigen (Leadenhall St)	510-2796	NOX	33

Chevron Asphalt	510-0072	NOX	49

Coca Cola	510-0242	NOX	5

Crown Cork & Seal - Duncanwood	510-0320	NOX	10

Gordon D. Garratt	510-0360	NOX	1

Proctor & Gamble	510-0185	NOX	12

Schluderberg-Kurdle	510-0283	NOX	19

(Westport 510-0006 & Riverside 005-0078)	510-0006	NOX	1480

Giant - Bakery  (930 King St)	031-0224 	NOX	2

Armco Stainless/	510-0340	NOX	16

Bausch & Lomb	023-0019	NOX	1

Rohr Industries	043-0104	NOX	6

Showell Farms	047-0036	NOX	8

WR Grace	510-0076	NOX	17

General Motors - Truck & Bus	510-0354	NOX	119

Andrews Air Force Base	033-0655	NOX	15

Millenium Inorganic Chemicals	510-0109	NOX	30

Quebecor Printing 	003-0274	VOC	322

Bethlehem Steel	005-0147	VOC	0

Pulaski Incinerator	510-0498	VOC	11

BARCO - Fairlawn	510-2854	VOC	5

Crown Cork & Seal - Duncanwood	510-0320	VOC	13

Giant - Bakery  - 930 King St	031-0224  	VOC	0

Cello Professional Products	025-0145	VOC	0

Grief Brothers Corporation	005-0134	VOC	0

General Motors - Truck & Bus	510-0354	VOC	0

General Motors - Electromotive	005-0692	VOC	15

Crown Central Petroleum	003-0234	VOC	21

BGE - SNG Plant	005-1054	VOC	7

Ecko-Glaco Ltd.	005-0310	VOC	27

G. Heileman Brewing Co. (Strohs)	005-0129      	VOC	48

Maryland Paper Box	005-2220	VOC	15

Schlumberger Malco, Inc.	005-1614	VOC	12

U.S.Can-Sparrows Pt. (Amer Nat)	005-0183	VOC	90

TPS Technologies (Todd's La.)	005-2131	VOC	4

Simpkins Industries  (River Rd)	027-0005	VOC	7

3M Commercial Graphics	013-0052	VOC	30

Blue Chip Products	015-0058	VOC	35

Baycraft Fiberglass Engineering	025-0231	VOC	10

Alltrista Metal Services	510-00508	VOC	11

Armco/Balto. Specialty Steel	510-0340	VOC	11

CE Stevens Packaging  (printer)	510-2900	VOC	10

Chevron Asphalt	510-0072	VOC	2

Conoco Sun Gasoline Terminal	510-0676	VOC	27

Bata Shoe 	025-0003	VOC	18

Cherokee Sanford	033-0565	VOC	0

PPG Industries	001-0005	VOC	28

Tidewater Industrial Corp.	011-0039	VOC	11

Crown Cork & Seal - Hurlock	019-0073	VOC	96

Mail-Weil Graphics	019-0097	VOC	8

Metalfab - Grove Road	021-0317	VOC	11

Bausch & Lomb	023-0019	VOC	16

American Mouldings	043-0191	VOC	69

Carpenter Insulation	043-0189	VOC	146

CSX Minerals	043-0110	VOC	10

Rohr Industries	043-0104	VOC	4

Constellation - Westport 510-0006 & Riverside 005-0078	510-0006	VOC	23

Thomas Mfg.	005-0240	VOC	22

LeSaffre Yeast	510-0191	VOC	179

4.3  Actual vs. Allowable Emissions in Development of the 2008 and 2009
Projected Emissions Inventories

To simplify comparisons between the base-year and the projected year,
EPA guidance states that comparison should be made only between like
emissions:  actual to actual, or allowable to allowable, not actual to
allowable.  Therefore, all base-year and all projection-year emissions
estimates are based on actual emissions.

The term "actual emissions" means the data was directly provided by the
registered sources via annual emission certification reports.  Actual
emissions are calculated using the source's operating hours, production
rates, and types of material processed, stored, or combusted during the
selected time period.

"Allowable emissions" are defined as the maximum emissions a source or
installation is capable of discharging after consideration of any
physical, operations, or emissions limitations required by state
regulations or by federally enforceable conditions, which restrict
operations and which are included in an applicable air quality permit to
construct or permit to operate, secretarial order, plan for compliance,
consent agreement, court order, or applicable federal requirement.

4.4  Projection Inventory Results

Chapter 6 of this SIP describes the control measures that have been or
will be implemented by 2008 and 2009 that will reduce emissions.  Most
control measures are required by federal or state regulations.
Projected controlled inventories for 2008 and 2009 assume a number of
control measures to be in place by these years as identified in Chapter
6.

Tables 4-3 and 4-4 present the projected controlled emissions for the
2008 rate-of-progress and 2009 attainment years resulting from
implementation of the control measures.

4.5  2008 Controlled Emissions for Rate-of-Progress

The projection of 2008 controlled emissions is simply the 2008
uncontrolled emissions minus the emission reductions achieved from the
federal control measures and the rate-of-progress control measures
implemented by states for the 8-hour ozone plan. This information is
presented in Tables 4-3 and 4-4. Controlled inventories are contained in
Appendix C1.  Details on mobile source emissions can be found in
Appendix F.

Table 4-3:

2008 Projected Controlled VOC & NOx Emissions (tons/day)

MD Portion of the Philadelphia - Wilmington - Atlantic City, PA - DE -
MD - NJ Area

Emission Source

Category	Cecil County

VOC Emissions

(tons per day)	Cecil County

NOx Emissions

(tons per day)

Point	0.39	0.02

Area	4.75	0.23

Non-road	7.23	2.87

Mobile	2.29	7.93

Total	14.65	11.05

4.6  2009 Controlled Emissions for Attainment

The projection of 2009 controlled emissions is simply the 2009
uncontrolled emissions minus the emission reductions achieved from the
federal control measures and the rate-of-progress control measures
implemented by states for the 8-hour ozone plan.

Table 4-4:

2009 Projected Controlled VOC & NOx Emissions (tons/day)

MD Portion of the Philadelphia - Wilmington - Atlantic City, PA - DE -
MD - NJ Area

Emission Source

Category	Cecil County

VOC Emissions

(tons per day) 7	Cecil County

NOx Emissions

(tons per day) 8

Point	0.40	0.02

Area	4.57	0.24

Non-road	7.23	2.81

Mobile	2.20	7.6

Total	14.40	10.66

5.0 2008 Reasonable Further Progress Requirements

5.1  Introduction

In June 2005 EPA revoked the 1-hour ozone standard and published
implementation guidance for the 8-hour ozone standard. Cecil County was
classified as a moderate nonattainment of the 8-hour ozone standard. EPA
classified the Philadelphia - Wilmington - Atlantic City, PA - DE - MD -
NJ ozone nonattainment area (Philadelphia NAA) as a moderate area under
Subpart 2 area of Section 182 part b.

As part of a moderate nonattainment area, EPA requires Cecil County to
demonstrate Reasonable Further Progress towards attainment by 2008.
EPA’s implementation guidance requires that a moderate ozone
nonattainment areas, such as Cecil County, with an approved 15% VOC
reduction plan for the period 1990-1996 (required for former 1-hour
ozone non-attainment areas) demonstrate a 15% Reasonable Further
Progress for VOC and NOx by 2008. This chapter contains Cecil County’s
reasonable further progress demonstration for the years 2002-2008. Cecil
County will need to fulfill the 2002-2008 reasonable further progress
requirements by January 1, 2009.

In order to demonstrate reasonable further progress, a region must show
that its expected emissions, termed controlled inventories, of NOx and
VOC will be less than or equal to the target levels set for the end of
the reasonable further progress period, or “milestone year”.  For
the RFP period 2002-2008, the “target inventories” of emissions are
the maximum quantity of anthropogenic emissions permissible during the
2008 milestone year.

This section describes the methodology used to establish the regional
target inventories and controlled inventories for 2008.  Because the
expected NOx and VOC emissions will be less than or equal to the target
levels, Cecil County will meet the reasonable further progress
requirements for 2008.

Rate of Progress Demonstrated in Previous State Implementation Plans

Since 1990, the Clean Air Act has required ozone nonattainment areas to
demonstrate progress towards attaining the ozone standard. This
requirement is referred to as the reasonable further progress (RFP) or
reasonable further progress requirement. During the period 1990-1996,
areas in nonattainment for the one-hour ozone standard were required to
reduce VOC emissions by 15%. Since 1996, regions have been required to
demonstrate a 9% rate of progress every three years until the region’s
attainment date.

The CAA included restrictions on the use of control measures to meet the
15% requirements. Reductions in ozone precursors resulting from four
types of federal and state regulations could not be used to meet rate of
progress. These four types of programs are:

(1) 	Federal Motor Vehicle Control Program (FMVCP) tailpipe and
evaporative standards issued in January 1, 1990,

(2) 	Federal regulations limiting the Reid Vapor Pressure (RVP) of
gasoline in ozone nonattainment areas issued by June 15, 1990;

(3)	State regulations correcting deficiencies in reasonably available
control technology (RACT) rules

(4) 	State regulations establishing or correcting inspection and
maintenance (I/M) programs for on-road vehicles.

The basic procedures of developing target levels for the 15% Plan are
describe in EPA’s guidance on the Adjusted Base Year Emissions
Inventory and the 1996 Target for the 15% Rate of Progress Plans.

5.2  Guidance for Calculating Reasonable Further Progress (RFP) Emission
Target Levels

The Clean Air Act Amendments (CAAA) of 1990 provide the primary guidance
for calculating the VOC and NOx target levels used in a region’s
reasonable further progress (RFP) plans. In November 2005 as part of its
final implementation rule for the 8-hour ozone standard, EPA issued
guidance to assist the states in RFP development.

The guidance that applies to the Cecil County, Maryland area is guidance
for previously severe 1-hour ozone nonattainment areas with an approved
15% Reasonable further progress plan for the period 1990-1996. Since the
Cecil County, Maryland region is a former severe 1-hour ozone
nonattainment area and has an approved 15% ROP plan for the above
period, “Method 2” of the guidance applies to the region.   The
region is required to reduce emissions by 15% from 2002-2008 to
demonstrate Reasonable Further Progress, according to Method 2.

EPA’s guidance (Method 2) states that the target level of VOC and NOx
emissions in 2008 needed to meet the 2008 ROP requirement is any
combination of VOC and NOx reductions from the adjusted base year 2002
inventories (base year 2002 emissions less non-creditable emissions
reduction occurring between 2002 and 2008) that total 15%. For example,
the target level of VOC emissions in 2008 could be a 10% reduction from
the adjusted base year 2002 VOC inventory and a 5% reduction from the
adjusted NOx inventory. The actual projected 2008 VOC and NOx
inventories for all sources with all control measures in place and
including projected 2008 growth in activity must be at or lower than the
target levels of VOC and NOx emissions. The actual projected 2008 VOC
and NOx inventories for all sources with all control measures in place
and including projected 2008 growth in activity must be at or lower than
the target levels of VOC and NOx emissions.

This section briefly summarizes the requirements and procedures for
calculating the target emission levels required for a RFP demonstration.
RFP demonstrations build upon each other, starting from the base year of
2002.

2008 VOC and NOx Target Levels

EPA’s Final Rule To Implement the 8-Hour Ozone National Ambient Air
Quality Standard – Phase II mandates that to meet the reasonable
further progress requirement, the Cecil County, MD portion of the
Philadelphia - Wilmington - Atlantic City, PA - DE - MD - NJ ozone
nonattainment area ozone nonattainment area needs to reduce its
emissions by 15% between 2002 and 2008 using either reduction in VOC or
NOx or any combination of the two.  The Cecil County, MD portion of the
Philadelphia - Wilmington - Atlantic City, PA - DE - MD - NJ ozone
nonattainment area is able to demonstrate reasonable further progress
for the period 2002-2008 using 15% VOC reduction.

The target levels for 2008 reasonable further progress plans are
calculated according to the EPA’s final rule mentioned above. The
general formula for calculation of 2008 target levels is as follows:

Equation: 5-6

Target Level	=	RFP base year emissions	-	reductions required to meet the
reasonable further progress requirement	-	non-creditable emissions
reduction between 2002 and 2008

Calculation of 2008 Target Levels

Equation 5-6 gives the general formula for calculating post-1996 target
levels. Since the region has chosen to demonstrate the 2008 reasonable
further progress using 15% VOC reduction, the 2008 VOC target level
becomes:

Equation: 5-7

2008 VOC Target Level	=	2002 RFP Base-Year emissions	-	7.5% VOC
Reduction	-	non-creditable emissions reduction between 2002 and 2008

Equation: 5-8

2008 NOx Target Level	=	2002 RFP Base-Year emissions	-	7.5% NOx
Reduction	-	non-creditable emissions reduction between 2002 and 2008

Step 1  Develop 2002 Base Year Inventories and 2002 Reasonable Further
Progress Base Year Inventories

The 2002 base year inventory is an inventory of actual anthropogenic and
biogenic VOC emissions on a typical weekday during peak ozone season.
The inventory was calculated as described in Chapter 3 and is presented
in Table 3-1. The reasonable further progress base-year inventory
includes only anthropogenic emissions generated within the Cecil County,
MD portion of the Philadelphia - Wilmington - Atlantic City, PA - DE -
MD - NJ ozone nonattainment area. As the 2002 base-year inventory
included no emissions generated outside the Cecil County, MD area, the
only difference between the base year inventory and the reasonable
further progress base year inventory is the removal of biogenic
emissions. The reasonable further progress base year VOC inventory is
presented in Table 5-1.

Table 5-1

2002 Reasonable Further Progress Base-Year Inventory

(Ozone Season tons per day)

Source	VOC	NOx

Point 	0.28	0.02

Area 	4.93	0.20

Non-Road 	8.37	2.97

On-Road 	4.00	14.22

TOTAL 	17.58	17.40

Note: Small discrepancies may result due to rounding

Step 2 Develop 2002 and 2008 Reasonable Further Progress Adjusted Year
Inventories

According to the 1990 CAAA, reductions necessary to meet the reasonable
further progress requirement must be calculated from an emission
baseline that excludes the effects of the non-creditable Federal Motor
Vehicle Control Program (FMVCP) and Reid Vapor Pressure (RVP) programs
described in Section 5.2. Therefore the 2002 baseline must be adjusted
by subtracting the VOC and NOx reductions that will result from these
two programs between 2002 and 2008. The resulting inventory is referred
to as the 2002 Adjusted Base Year Inventory.

In order to calculate the non-creditable emissions reductions, which
occur between 2002 and 2008, the following two mobile inventories are
needed:

1) 2002 Reasonable Further Progress Adjusted-Year Inventory

2) 2008 Reasonable Further Progress Adjusted-Year Inventory

Both of these mobile inventories were created using the same inputs
(listed below), with the only difference between them being the
automobile model year (inventory #1 and #2 were created for 2002 and
2008 respectively).

a) 1990 I/M Program

b) RVP = 7.8 psi (RVP required according to June 1990 fuel RVP
regulations)

c) No Post-1990 Clean Air Act Measures

d) 2002 Vehicle Activity Inputs

e) 2002 Vehicle Miles Traveled (VMT)

The MOBILE6 input files are included in Appendix F. Table 5-2 & 5-3 show
RFP adjusted-year inventories for 2002 and 2008 respectively.

Table 5-2

2002 Reasonable Further Progress Adjusted-Year Inventory

(Ozone Season tons per day)

Source	VOC	NOx

Point 	0.28	0.02

Area 	4.93	0.20

Non-Road 	8.37	2.97

On-Road 	5.42	16.09

TOTAL 	19.00	19.28

Note: Small discrepancies may result due to rounding

Table 5-3

2008 Reasonable Further Progress Adjusted-Year Inventory

(Ozone Season tons per day)

Source	VOC	NOx

Point 	0.28	0.02

Area 	4.93	0.20

Non-Road 	8.37	2.97

On-Road 	4.73	13.90

TOTAL	  =SUM(ABOVE) \# "#,##0.00"    18.31 	  =SUM(ABOVE) \# "#,##0.00"
  17.09

Note: Small discrepancies may result due to rounding

Step 3  Non-creditable Emissions Reductions

The non-creditable emissions reductions that occur in absence of any
post-1990 CAA measures during a reasonable further progress period can
be determined by taking the difference between the RFP adjusted-year
inventories for the relevant milestone years. For VOC and NOx, the
relevant milestone years are 2002 and 2008.

Equation: 5-9

Non-creditable Emissions Reductions	=	2002 RFP Adjusted Year Inventory	-
2008 RFP Adjusted Year Inventory

Table 5-3

Calculation of Non-creditable Emissions Reductions

(Ozone Season tons per day)

Description 	VOC	NOx

2002 Adjusted Year Inventory (a) 	5.42	16.09

2008 Adjusted Year Inventory (b) 	4.73	13.90

Non-creditable Emissions Reduction (a-b)	  =B2-B3 \# "#,##0.00"     0.69
	  =C2-C3 \# "#,##0.00"     2.19

Step 4  Calculation of 2008 Target Levels

Following Equations 5-7, 5-8 and 5-9, the VOC and NOx target levels for
2008 are calculated in Table 5-4 below:

Table 5-4

Calculation of VOC and NOx Target Levels for 2008

(Ozone Season tons per day)

 	 Description	Formula	VOC	NOx

A	2002 Base Year Inventory

60.52	17.40

B	Biogenic Emissions

42.94	0.00

C	2002 Rate-of Progress Base Year Inventory	A - B	17.58	17.40

D	FMVCP/RVP Reductions Between 2002 and 2008

0.69	2.19

E	2002 Adjusted Base Year Inventory Calculated Relative to 2008	C - D
16.89	15.21

F	Ratio

0.07	0.08

G	Emissions Reductions Required Between 2002 and 2008	E * F	1.18	1.22

H	Target Level for 2008  [TL(2008)]	C - D - G	15.71	13.99

5.3  Compliance with 2008 Reasonable Further Progress Requirements

In order to demonstrate reasonable further progress for the period
2002-2008, the Cecil County, MD portion of the Philadelphia - Wilmington
- Atlantic City, PA - DE - MD - NJ ozone nonattainment area must show
that expected emissions in 2008 are equal to or less than the 2008
target levels presented in Table 5-4.

The 2008 controlled inventories are inventories of all anthropogenic VOC
and NOx emissions expected to occur in Cecil County, MD during 2008. The
inventories were developed as described in Chapter 4 and are displayed
in Tables 4-3 and 4-4. As summarized in Table 5-5, the 2008 controlled
VOC and NOx inventories are less than the 2008 target inventories. Table
5-5 demonstrates that the Cecil County, MD area of the Philadelphia -
Wilmington - Atlantic City, PA - DE - MD - NJ ozone nonattainment area
fulfills the 2002-2008 reasonable further progress requirements.

Table 5-5

Comparison of 2008 Controlled and Target Inventories

Ozone Season Daily Emissions (tons per day)

Description 	VOC	NOx

2008 Target Levels 	15.71	13.99

2008 Controlled Emissions 	14.59	11.05

References

U.S. EPA, “Guidance on the Adjusted Base Year Emissions Inventory and
the 1996 Target for the 15% Rate of Progress Plans”

U.S. EPA, “Guidance on the Post-1996 Reasonable Further Progress Plan
and the Attainment Demonstration”, February 18, 1994.

U.S. EPA, “NOx Substitution Guidance”, December 1993.

6.0  Control Measures

This chapter is divided into three sections.  Section 6.1 identifies the
control measures that were part of the 1-Hour Ozone SIP for Cecil
County, Maryland.  These regulations/ control measures continue to be in
existence and continue to reduce emissions in the region.  All of the
emission reductions from the measures identified in Section 6.1 were
part of the baseline emission inventory for Cecil County, Maryland.

Section 6.2 of this chapter identifies measures implemented after 2002
that were not part of the baseline inventory and are giving specific
emission reductions to the region’s 8-hour Ozone reasonable further
progress demonstration.

Section 6.3 identified voluntary/ innovative measures that the Maryland
is not taking formal credit for in the SIP.  These measures are not
commitments to programs but present information on programs that are
directionally correct and could provide ozone benefits.

6.1  1-Hour Ozone Control Measures

On-Road Mobile Measures

Enhanced Vehicle Inspection and Maintenance (Enhanced I/M)

The Clean Air Act requires enhanced motor vehicle inspection and
maintenance (I/M) programs in serious, severe, and extreme ozone
nonattainment areas and MSA/CMSA portions of the OTR with urbanized
populations over 200,000.  In Maryland, this required enhanced I/M
program in the eight jurisdictions operating a basic I/M program as well
as six new jurisdictions, for a total of 14 of the 23 jurisdictions in
the state.   Tailpipe emissions are measured over a transient driving
cycle conducted on a dynamometer, which provides a much better
indication of actual on-road vehicle performance than the existing idle
test.

Tier I Vehicle Emission Standards and New Federal Evaporative Test
Procedures

The Act requires a new and cleaner set of federal motor vehicle
emissions standards (Tier I standards) beginning with model year 1994.
The Act also requires a uniform level of evaporative emission controls,
which are more stringent than most evaporative controls used in existing
vehicles. These federally implemented programs affect light duty
vehicles and trucks.

Reformulated Gasoline in On-road Vehicles

All gasoline-powered vehicles are affected by this control measure.
Vehicle refueling emissions at service stations are also reduced.  In
addition, emissions from gasoline powered nonroad vehicles and equipment
will be reduced by this control strategy.  Since January of 1995, only
gasoline that the EPA has certified as reformulated may be sold to
consumers in the nine worst ozone nonattainment areas with populations
exceeding 250,000.

National Low Emission Vehicle Program

The NLEV program is a vehicle technology program that provides light
duty vehicles and trucks that are significantly cleaner than pre-1998
models. The National LEV program was developed through an unprecedented,
cooperative effort by the northeastern states, auto manufacturers,
environmentalists, fuel providers, U.S. EPA and other interested
parties.  National LEV vehicles are 70% cleaner than 1998 models. The
National LEV program will result in substantial reductions in volatile
organic compounds (VOCs) and oxides of nitrogen (NOx), which contribute
to unhealthy levels of smog in many areas across the country.

Tier 2 Vehicle Emission Standards

In 1999, EPA proposed more stringent tailpipe emissions standards for
cars and light trucks weighing up to 8,500 pounds.  Commonly referred to
as Tier 2, these standards take effect beginning in 2004 when
manufacturers start producing passenger cars that are 77 percent cleaner
than those on the road today.  Light-duty trucks, such as SUVs, which
are subject to standards that are less protective than those for cars,
would be as much as 95 percent cleaner under the new standards.

Federal Heavy-Duty Diesel Engine Rule

EPA’s heavy-duty engines rule will address diesel vehicles weighing
more than 8,500 pounds, These standards will take effect in 2007 and
reduce emissions from new HDDEs by 95%.  In order to achieve the new
standards, ultra-low sulfur diesel fuel will be needed.

Stage II Recovery Systems

This measure required the installation of Stage II vapor recovery
nozzles at gasoline pumps.  Maryland adopted Stage II vapor recovery
regulations for the Baltimore and Washington nonattainment areas and
Cecil County in January of 1993. The Stage II vapor recovery regulation
requires that the dispensing system be equipped with nozzles that are
designed to return the vapors through a vapor line into the gasoline
tank.

 New Vehicle On-Board Vapor Recovery Systems

This measure required the installation of onboard refueling emissions
controls for new passenger cars and light trucks beginning in the 1998
model year.  The onboard refueling vapor recovery (ORVR) system was
required for new passenger cars and light trucks beginning in model
1998.

Area Source Measures

VOC Controls in Maryland

Automotive and Light-Duty Truck Coating

Can Coating

Coil Coating

Large Appliance Coating

Paper, Fabric, Vinyl, and Other Plastic Parts Coating

Control of VOC Emissions from Solid Resin Decorative Surface
Manufacturing

Metal Furniture Coating

Control of VOC Emissions from Cold and Vapor Degreasing

Flexographic and Rotogravure Printing

Lithographic Printing

Dry Cleaning Installations

Miscellaneous Metal Coating

Aerospace Coating Operations

Brake Shoe Coating Operations

Control of Volatile Organic Compounds from Structural Steel Coating
Operations

Manufacture of Synthesized Pharmaceutical Products

Paint, Resin and Adhesive Manufacturing and Adhesive Application

Control of VOC Equipment Leaks

Control of Volatile Organic Compound (VOC) Emissions from Yeast
Manufacturing

Control of Volatile Organic Compound Emissions from Screen Printing and
Digital Imaging

Control of Volatile Organic Compounds (VOC) Emissions from Expandable
Polystyrene Operations

Control of Landfill Gas Emissions from Municipal Solid Waste Landfills

Control of Volatile Organic Compounds (VOC) Emissions from Commercial
Bakery Ovens

Control of Volatile Organic Compounds (VOC) from Vinegar Generators

Control of VOC Emissions from Vehicle Refinishing

Control of VOC Emissions from Leather Coating

Control of Volatile Organic Compounds from Explosives and Propellant
Manufacturing

Control of Volatile Organic Compound Emissions from Reinforced Plastic
Manufacturing

Control of Volatile Organic Compounds from Marine Vessel Coating
Operations

Control of Volatile Organic Compounds from Bread and Snack Food Drying
Operations

Control of Volatile Organic Compounds from Distilled Facilities

Control of Volatile Organic Compounds from Organic Chemical Production

Iron and Steel Production Installations

Control of Kraft Pulp Mill Emissions

Municipal Landfills

A municipal solid waste landfill is a disposal facility where household
waste is placed and periodically covered with inert material.  Landfill
gases are produced from the decomposition and chemical reactions of the
refuse in the landfill.  They consist primarily of methane and carbon
dioxide, with volatile organic compounds making up less than one percent
of the total emissions. The control strategy for this source category is
based upon federal rules.

Burning Ban

August).  There are exemptions for agricultural burning, fire training
and recreational activities.

Surface Cleaning/Degreasing

Cold degreasing is an operation that uses solvents and other materials
to remove oils and grease from metal parts including automotive parts,
machined products, and fabricated metal components.  MDE adopted
regulations in 1995 to require small degreasing operations such as
gasoline stations, autobody paint shops, and machine shops to use less
polluting degreasing solvents in serious and severe ozone nonattainment
areas. Also, solvent baths and rags soaked with solvents must be covered
under this regulation.

Architectural and Industrial Maintenance Coatings

Architectural and industrial maintenance coatings are field-applied
coatings used by industry, contractors, and homeowners to coat houses,
buildings, highway surfaces, and industrial equipment for decorative or
protective purposes.  VOC emissions result from the evaporation of
solvents from the coatings during application and drying. A federal
measure requires reformulation of architectural and industrial
maintenance coatings. The users of these coatings are small and
widespread, making the use of add-on control devices technically and
economically infeasible.

Commercial and Consumer Products

Consumer and commercial products are items sold to retail customers for
household, personal or automotive use, along with the products marketed
by wholesale distributors for use in institutional or commercial
settings such as beauty shops, schools, and hospitals. VOC emissions
result from the evaporation of solvent contents in the products or
solvents used as propellants. This measure requires the reformulation of
certain consumer products to reduce their VOC content.  Product
reformulation can be accomplished by substituting water, other non-VOC
ingredients, or low-VOC solvents for VOCs in the product.

Automobile Refinishing

Automobile refinishing is the repainting of worn or damaged automobiles,
light trucks, and other vehicles.    Volatile organic compound emissions
result from the evaporation of solvents from the coatings during
application, drying and clean up techniques. This measure based on state
regulation requires large and small autobody refinishing operations to
use low VOC content materials in the refinishing process and cleanup,
and to use efficient spray guns to control application. The Department
adopted regulations in 1995 requiring the use of reformulated coatings.

Screen Printing

A screen-printing process is used to apply printing or an image to
virtually any substrate.  In the screen-printing operation, ink is
distributed through a porous screen mesh to which a stencil may have
been applied to define an image to be printed on a substrate.  VOC
emissions result from the evaporation of ink solvents and from the use
of solvents for cleaning. The major source of VOC emissions is the
printing process. This measure requires smaller printers to use water
based and/or low VOC materials to reduce VOC emissions. Because the
users of these coatings are relatively small, requiring the use of
add-on control devices is technically and economically infeasible.
Reductions in VOC emissions were obtained through the use of ink
reformulation, process printing modification, and material substitution
for cleaning operations. This regulation became effective on June 5,
1995.

Graphic Arts – Lithographic Printing

This source category consists of numerous small sheet-fed printers that
perform non-continuous printing and web printers that print on a
continuous web or roll.  Heat-set web printers use drying ovens to force
dry the printed matter.  Web printing sources perform high volume
printing on paper or paperboard.  VOC emissions to the air are caused by
evaporation of the ink solvents, alcohol in the fountain or dampening
solution, and equipment wash solvents.  These VOC discharges may also
cause visible emissions and nuisance odors. MDE adopted a regulation in
1995 to require printers to use control devices and/or low VOC materials
to reduce VOC emissions.

Graphic Arts – Flexographic and Rotogravure Printing

This source category consists of numerous small flexographic or
rotogravure printers that perform non-continuous sheet fed printing and
continuous web or roll printing.  MDE adopted a printing regulation in
1987 that requires smaller printers to use control devices and/or low
VOC materials to reduce VOC emissions. VOC emissions to the air are
caused almost entirely by evaporation of the ink solvents. Although
several control devices were evaluated over the years for rotogravure
and flexographic web printers, a catalytic oxidizer has proven to be
most successful.  A typical oxidizer yields 96-98 percent destruction of
VOC.  Most sources were in compliance with all requirements by early
1992.

Non-Road Measures

Nonroad Small Gasoline Engines

This measure requires small gasoline-powered engine equipment, such as
lawn and garden equipment, manufactured after August 1, 1996 to meet
federal emissions standards. Small gasoline-powered engine equipment
includes lawn mowers, trimmers, generators, compressors, etc. These
measures apply to equipment with engines of less than 25 horsepower.
VOC emissions result from combustion and evaporation of gasoline used to
power this equipment.

Non-Road Diesel Engines Tier I and Tier II

This measure takes credit for NOx emissions reductions from emissions
standards promulgated by the EPA for non-road, compression-ignition
(i.e., diesel-powered) utility engines.  The measure affects
diesel-powered (or other compression-ignition) heavy-duty farm,
construction equipment, industrial equipment, etc., rated at or above 37
kilowatts (37 kilowatts is approximately equal to 50 horsepower).
Heavy-duty farm and construction equipment includes asphalt pavers,
rollers, scrapers, rubber-tired dozers, agricultural tractors, combines,
balers, and harvesters.  This measure applies to all
compression-ignition engines except engines used in aircraft, marine
vessels, locomotives and underground mining activity.  NOx emissions
result from combustion of diesel fuel used to power this equipment.

Marine Engine Standards

Of the nonroad sources studied by EPA, gasoline marine engines were
found to be one of the largest contributors of hydrocarbon (HC)
emissions (30% of the nationwide nonroad total). This measure controls
exhaust emissions from new spark-ignition (SI) gasoline marine engines,
including outboard engines, personal watercraft engines, and jet boat
engines.

Emissions standards for large spark ignition engines

This EPA measure controls VOC and NOx emissions from several groups of
previously unregulated nonroad engines, including large industrial
spark-ignition engines, recreational vehicles, and diesel marine
engines.  The emission standards apply to all new engines sold in the
United States and any imported engines manufactured after these
standards begin. Controls on the category of large industrial
spark-ignition engines are first required in 2004.  Controls on the
other engine categories are required beginning in years after 2005.
Large industrial spark-ignition engines are those rated over 19 kW used
in a variety of commercial applications; most use liquefied petroleum
gas, with others operating on gasoline or natural gas.

Reformulated gasoline use in non-road motor vehicles and equipment

This federally mandated measure requires the use of lower polluting
"reformulated" gasoline in Cecil County.  The measure involves taking
credit for reductions due to the use of the reformulated gasoline in
non-road mobile sources.  Nonattainment areas classified as severe were
required to opt in on the delivery of reformulated gasoline.  This
measure affects the various non-road mobile sources that burn gasoline;
such as small gasoline-powered engine equipment includes lawn mowers,
trimmers, generators, compressors, etc.  VOC emissions result from
combustion and evaporation of gasoline used to power this equipment.

Railroad Engine Standards

This measure establishes emission standards for oxides of nitrogen
(NOx), hydrocarbons (HC), carbon monoxide (CO), particulate matter (PM),
and smoke for newly manufactured and remanufactured diesel-powered
locomotives and locomotive engines, which have previously been
unregulated. This regulation took effect in 2000 and affects railroad
manufacturers and locomotive re-manufacturers.  It involves adoption of
three separate sets of emission standards with applicability dependent
on the date a locomotive is first manufactured.

Point Source Measures

Expandable Polystyrene Products

These sources use expandable polystyrene beads that contain pentane, a
VOC, to manufacture foam products such as foam cups, board insulation,
and custom shapes. VOC emissions typically occur during storage and
pre-expansion of the beads, during manufacturing, and during "aging"
when the blowing agent (pentane) slowly diffuses from the foam before
shipping. This control measure requires RACT (Reasonably Available
Control Technologies) to be installed at operations that manufacture
foam cups, foam insulation and other foam products. The regulation
became effective in July 1995.

Yeast Manufacturing

Yeast is produced using an aerated fermentation process under controlled
conditions.  In June 1995, MDE required RACT to be installed at two
yeast-manufacturing operations in the Baltimore nonattainment area.  The
regulation results in an overall emission reduction of approximately 60
to 70 percent from the 1990 baseline by requiring affected sources to
meet specific VOC emission standards.

Commercial Bakery Ovens

This measure requires commercial bakeries using yeast to leaven bread
and bread products to install RACT.  Commercial bakeries generate VOC
emissions from the fermentation and baking processes used to produce
yeast-raised baked goods.  These emissions are primarily ethanol.  The
regulation requires control equipment dependent upon thresholds that are
based on cost effectiveness criteria.

Federal Air Toxics

This measure covers sources that are required to comply with Federal air
toxics requirements. The Department has delegation to implement Federal
air toxics rules that will achieve VOC emissions reductions.  Federal
rules that may achieve such reductions include Federal NESHAPs for vinyl
chloride production plants and benzene emissions from equipment leaks,
benzene storage vessels, coke by-product recovery plants, benzene
transfer operations and waste operations and the EPA Maximum Achievable
Control Technology (MACT) program.

Enhanced Rule Compliance

Enhanced Rule Compliance or rule effectiveness (RE) improvement refers
to an improvement in the implementation of and compliance with a
regulation.  These RE improvements may take several forms, ranging from
more frequent and in-depth training of inspectors to larger fines for
sources that do not comply with a given rule.

State Air Toxics

This measure addresses stationary sources that are covered by Maryland's
air toxics regulations that have achieved VOC reductions above and
beyond current federally enforceable limits.  In general, Maryland's air
toxics regulations cover any source required to obtain a permit to
construct or annually renewed state permit to operate. The Department
adopted the air toxics regulations in 1988.

NOx RACT -- Reasonably Available Control Technology

This measure requires control of nitrogen oxides (NOx) emissions by
installing RACT.  NOx RACT will apply to utility, industrial and
commercial fuel burning equipment and combustion installations. The
regulation established cost-effective controls on all installations
located at major NOx sources. This first phase of stationary source NOx
reductions resulted in an approximate 22% reduction in NOx emissions.

NOx Phase II/Phase III Ozone Transport Commission (OTC)/NOx Budget Rule
(Phase II) and NOx SIP Call (Phase III)

In 1994, the OTC member states signed a major agreement to reduce NOx
emissions from power plants and other major stationary sources of
pollution throughout the Northeast and Mid-Atlantic States.  The
agreement recognized that further reductions in NOx emissions are needed
to enable the entire Ozone Transport Region (OTR) to meet the NAAQS. The
Department adopted a “NOx Budget” rule to require a second phase of
stationary source NOx reductions as part of this regulatory initiative.
This regulation requires large stationary sources to reduce summertime
NOx emissions by approximately 65% from 1990 levels. The regulation also
includes provisions allowing sources to comply by trading
“allowances.” This regulation requires affected sources to have met
these requirements by May 2000.

In late 1998, the U.S. EPA adopted its “NOx SIP Call” to reduce
ozone transport in the Eastern United States. This regional NOx
reduction program requires 22 states, including Maryland, to submit
regulations and a revision to State Implementation Plans (SIPs) to
further reduce NOx emission by 2007. Maryland’s Phase III regulations
achieve approximately 23% additional reductions from large stationary
sources like power plants, cement kilns and large industrial boilers.
The regulations require affected sources to add specific control
equipment or to reduce emissions or trade to meet the allowable amount
("cap") of seasonal NOx emissions by 2003.

6.2  8-Hour Ozone Control Measures

The following measures have been implemented in Maryland since 2002 (the
baseline emissions inventory year for 8-Hour Ozone).  These measures
were not part of the baseline emissions inventory for the 8-Hour Ozone
SIP and emission reductions from these measures were forecasted for both
2008 (reasonable further progress calculation) and 2009 (attainment
inventory) for use in the reasonable further progress calculations for
Cecil County as well as the attainment modeling for the region.  A
summary of the control measures and their benefits is presented in Table
6.1 below.  The benefits below summarize the emission credits available
from the listed measures based on the difference between a 2008/2009
controlled and uncontrolled inventory.

Table 6.1: Control Measures Summary

	2008

2009

Control Measure	VOC

(tpd)	NOx

(tpd)

VOC

(tpd)	NOx

(tpd)

Enhanced I/M

	Tier I

	Reform Gas

	LEV

	HDDE

	Total Mobile	1.75	3.78

1.85	3.78

Stage II/Refuel	0.00	0.00

0.00	0.00

OTC - Consumer Products Phase 1	0.14	0.00

0.14	0.00

OTC - Consumer Products Phase 2	0.00	0.00

0.02	0.00

OTC – AIM	0.39	0.00

0.39	0.00

OTC - PFC Phase 1	0.26	0.00

0.32	0.00

OTC - PFC Phase 2	0.00	0.00

0.03	0.00

OTC - Industrial Adhesives	0.00	0.00

0.10	0.00

Open Burning	0.00	0.00

0.00	0.00

Nonroad Model	1.18	0.28

1.50	0.36

Railroads (Tier 2)	0.00	0.15

0.00	0.16

Healthy Air Act (HAA)	0.00	0.00

0.00	0.00

Total	3.71	4.21

4.35	4.30

The Maryland Healthy Air Act (HAA)

In April of 2006, the Maryland General Assembly enacted the Maryland
Healthy Air Act. The Maryland General Assembly record related to the HAA
and the final version of the Act itself can be found at:
http://mlis.state.md.us/2006rs/billfile/SB0154.htm

The MDE Regulations (Code of Maryland Regulations) can be found at:

http://www.mde.state.md.us/assets/document/CPR_12-26-06_Emergency_and_Pe
rmanent_HAA_Regs_for_AELR.pdf

The HAA is one of the most stringent power plant emission laws on the
east coast.  The HAA requires reductions in Nitrogen Oxide (NOx), Sulfur
Dioxide (SO2) and Mercury emissions from large coal burning power
plants.  The Healthy Air Act also requires that Maryland become involved
in the Regional Greenhouse Gas Initiative (RGGI) which is aimed at
reducing greenhouse gas emissions.

The Maryland Department of the Environment (MDE) has been charged with
implementing the HAA through regulations. As enacted, these regulations
constitute the most comprehensive air pollution emission reduction
measure proposed in Maryland history.

Affected Sources

These Healthy Air Act NOx reduction requirements affect the following
fossil fuel fired electric generating units (only the Constellation
Energy Group Systems are located in the Baltimore Nonattainment Area):

Constellation Energy Group System

Brandon Shores 1 & 2 Anne Arundel County

H. A. Wagner 2 & 3 Anne Arundel County

C. P. Crane 1 & 2 Baltimore County

Mirant System

Chalk Point 1 & 2 Prince George’s County

Dickerson 1, 2, & 3 Montgomery County

Morgantown 1 & 2 Charles County

Allegheny Energy Washington County

R. Paul Smith, 3 & 4

Overview of Expected Emission Reductions

While none of the HAA affected sources are located in Cecil County,
Maryland, the MDE lists this important regulation in the SIP as emission
reductions from these upwind facilities will have a substantial impact
on the air quality in Cecil County.

Over ninety-five percent of the air pollution emitted from Maryland’s
power plants comes from the largest and oldest coal burning plants.  The
emission reductions from the HAA come in two phases.  The first phase
requires reductions in the 2009/ 2010 timeframe and compared to a 2002
emissions baseline reduce NOx emissions by almost 70%, SO2 emissions by
80% and mercury emissions by 80%.

The second phase of emission control occurs in the 2012/ 2013 timeframe.
 At full implementation the HAA will reduce NOx emissions by
approximately 75% from 2002 levels, SO2 emissions will be reduced by
approximately 85% from 2002 levels, and mercury emissions will be
reduced by 90%.

Table 6.2 Annual Maryland Healthy Air Act NOx Emissions Reductions
(TPY):

Unit	2002 Emissions	Uncontrolled 2009 Emissions	2009 HAA Caps	2009 HAA
Emission Reductions	2009 HAA Emission Reduction %	2012 HAA Caps	2009
Uncontrolled Emissions - 2012 HAA Cap	2012 HAA Emission Reduction %

Brandon Shores 1	6329	7558	2927	4631	61.27	2414	5144	68.06

Brandon Shores 2	6034	7206	3055	4151	57.60	2519	4687	65.04