# Proposed Revision to

Delaware ’s 2008 State Implementation Plan

For Attainment of the PM 2.5 

# Annual National Ambient Air Quality Standard

- Attainment

Demonstration

October 201 1Section 1. Introduction

In Ap ril, 2008 Delaware submitted to the EPA its “ State Implementation Plan for Attainment of

the PM

2.5 Annual National Ambient Air Quality Standard

- Attainment Demonstration ” (the

“2008 PM 2.5 SIP”). 1 The 2008 PM 2.5 SIP set out to accomplish four primary goals:

 Demonstrate th at with all existing and proposed controls, all of Delaware’s PM 2.5 monitors will show attainment in 2009.

 Demonstrate that the entire Philadelphia

- Wilmington, PA

- NJ

- DE non

- attainment area

will attain the annual PM 2.5 NAAQS in 2009.

 Establish Delaware’s 2009 mobile source budgets for transportation conformity determinations under Regulation No. 1132, Transportation Conformity.

 Treat emission reduction credits (ERCs) banked under 7 DE Admin. Code 11 34, Emissions Banking and Trading Program, as “emitted.” As such, the future use of these credits is consistent with, and will not interfere with any calculation or provision of this SIP.

This SIP revision is related to the PM 2.5 and NOx on

- road mobile source budgets that were established in the 2008 PM 2.5 SIP . Th o se SIP budgets were established using EPA’s

MOBILE6.2 model. 2 However, e ffective March 2012 3 a new on

- road mob i le emission s model

– Motor Vehicle Emissions Simulator ( MOVES )

– is required to be used in all planning and transportation conformity det erminations.

Th e purpose of th is SIP revision is to 1) re pl ace the on

- road mobile emissions budget in the 2008

PM 2.5 SIP with a budget that is based on the MOVES model

, 2) demonstrat e that the MOVES

based mobile source b udget is c onsistent with attainment of the PM 2.5 NAAQS by 2010, and 3)

demonstrate that the contingency requirements of the Clean Air Act ( CAA ) are met

. No other changes or revisions to the 2008 PM 2.5 SIP are proposed.

Note that t his SIP revision impacts only PM 2.5 and NOx emiss ions and calculations

. While sulfur dioxide ( SO 2 ) is a pollutant of concern relative to PM 2.5 it is not a pollutant of concern for mobile budgets, and therefore no SO 2 changes are proposed as part of this SIP revision . The

treatment of SO 2 emissions in t he 2008 PM 2.5 SIP is unchanged.

Questions or comments regarding this SIP revision should be addressed to Phil Wheeler, M.S. Project Leader for Transportation Conformit y, Planning Branch, Division of Air Quality, Delaware Department of Natural Resources and Environmental Control, at philip.wheeler@state.de.us

.

1 http://www.awm.delaware.gov/Info/Regs/Documents/DE_PM25_SIP_AD_fnl.pdf

2 Details of the MOBILE6 budget calculations are included in Section 8.2 of the 2008 PM 2.5 SIP.

3 EPA has proposed to extend this date by one year; to March 2013.Section 2

. Revised On

- Road Mobile Source Budget s

T his SIP revision establishes on

- road mobile emissions budget for New Castle County for PM 2.5 and NOx. When approved by the EPA, all subsequent PM 2.5 conformity analyses will test future

on

- road mobile emissions calculated for transportation pla ns in New Castle Co unty with this new budget.

2 .1 EPA’s MOVES model was used to quantify PM 2.5 and NOx emission from on

- road

mobile sources. These emissions are shown in Table 2

- 1 below. The associated 2012
MOVES input and output files are included in Appendix A of this SIP revision.

Table 2

- 1 On

- Road Mobile Emission Budget ( Tons per Year (tpy) )

County Emissions Budget

New Castle NOx PM 2.5

6,273 199

2 .2 T his SIP revision establishes the emission levels identified in Table 2

- 1 as the on

- road
mobile emissions budget for New Castle County for PM 2.5 and NOx.

S ection 3

. Demonstrat ion that 2009 MOVES based On

- Road M obile S ource Emissions

are Co nsistent with A ttainment of the PM 2.5 NAAQS by 2010

Delaware demonstrated attainment of the annual PM 2.5 NAAQS in its 2008 PM 2.5 SIP by showing that Projected 2009 Emissions (i.e., the 2009 emission levels after the implementation of all state and federal control requirements) were less than the Attainment T argets (i.e., the

emission levels neede d for attainment based on modeling)

. This same methodology is used below to demonstrate that the MOVES based mobile budgets presented in Section 2 above are

consistent with attainment of the PM 2.5 NAAQS.

3 .1 Community Multi

- scale Air Quality Model ( CMAQ ) modeling was conducted in the

2008 PM 2.5 SIP to demonstrate that Delaware and the entire Philadelphia based non

attainment area would attain the PM 2.5 NAAQS in 2010 4 . CMAQ modeling

demonstrated that the Delaware emission levels shown in Table 3

- 1 are th e levels that are

necessary for, and consistent with attainment of the annual PM 2.5 NAAQS . These emission levels reflect the level of emissions needed for attainment, and are therefore

referred to as the “ 2009 Attainment Target. ” 5

, 6

4 A detailed discussion of the CMAQ modeling and modeling results can be found in Section 6 of the 2008 PM 2.5 SIP.

5 Although New Castle County is the only nonattainment county, emission levels of all three counties are used in the

attainment demonstration. This is discussed in Sections 3 and 4 of this SIP revision.

6 A detailed discuss ion of the emission inventories a ssociated with the Attainment Target can be found in Section 5

of the 2008 PM 2.5 SIP.Table 3

- 1 2009 A ttainment Target ( tpy )
County NOx PM 2.5
Kent 8,554 1,185

New Castle 23,048 3,249

Sussex 18,001 3,581

Statewide Total 49,603 8,015

3 .2 Attainment year (i.e., 2009 ) emission levels were projected in the 2008 PM 2.5 SIP based

on final and enforceable State and Federal emission control requirements. 7 These projected 2009 emission levels, which are referred to as the “ Delaware Projected 2009
Emissions, ” are shown in Table 3

- 2.

Table 3

- 2 Delaware Projected 2009 E mission s (tpy)

County NOx PM 2.5
Kent 7,799 989

New Castle 21,807 3,015

Sussex 11,591 2,571

Statewide Total 41,197 6,575

3

. 4 T able 3

- 3 compares the 2009 mobile emissions calculated using MOBILE6 and MOVES

. The associated 2009 MOBILE6 and MOVES input and output files are included in Appendix B of this SIP revision.

Table 3

- 3 2009 M OBILE 6 , MOVES and I ncrease due to MOVES ( tpy )

2009 Mobile6 2009 MOVES MOVES Increase

County NOx PM 2.5 NOx PM 2.5 NOx PM 2.5 Kent 1,922 32 3,488 109 1,566 77

New Castle 4,904 87 8,448 257 3,544 170

Sussex 2,707 41 4,764 147 2,057 106

Totals 9,533 160 16,700 51 3 7,167 35 3

3

. 5 A dding the “MOVES Increase ” emissions from Table 3

- 3 to the “ Delaware Projected

2009 E missions ” from Table 3

- 2 yields a projected Delaware 2009 Emission level that

reflect s the use of the M OVES model instead of the MOBILE6 model. This revised

emissions projection is s ho w n in Ta ble 3

- 4 , and is refe r

red to as the “ Revised Delaware Projected 2009 Emissions .”

7 A deta iled discussion of Delaware’s projected 2009 emission levels can be found in Section 4 of the 2008 PM 2.5 SIP.Table 3

- 4 Revised Delaware Projected 2009 Emissions (tpy)

County NOx PM 2.5 Kent 9,365 1,066

New Castle 25,351 3,185

Sussex 13,648 2,677

Statewide Total 48,364 6,92 8

3.5 The “Revised Delaware Projected 2009 Emissions” (i.e., Table 3

- 4) are demonstrated to

be consistent with att ainment if they are equal to or lower than the “ 2009 Attainment Target ” (i.e., Table 3

- 1). T he “ Revised Delaware Projected 2009 em issions ” are compared to the “

A ttainment T

arget ” in Table 3

- 5 below.

Table 3

- 5 Shortfall and Surplus by County and State wide ( tpy )

County Attainment Target Revised Delaware Projected

2009 Emissions Surplus / Shortfall

NOx PM

2.5 NOx PM2.5 NOx PM 2.5

Kent 8,554 1,185 9,365 1,066

- 811 119

New Castle 23,048 3,249 25,351 3,185

- 2,303 64

Sussex 18,001 3,581 13,648 2,677 4,353 904

Statewide 49,603 8,01 5 48,364 6,92 8 1,239 1,08 7

This comparison shows that there is a 64 tpy PM 2.5 surplus in New Castle County, and a 2,303 tpy NOx shortfall for New Castle County. This demonstrates that, relative to dir e ct

PM 2.5 , the MOVES based mob i le budgets are consistent with attainment. These results

also indicate that NOx requires further analysis.

3.6 Because of the regional nature of secondarily

- formed sulfate and nitrate, and the broad

mode ling domain of the CMAQ modeling, which included all of Delaware, emission

reductions from Kent and Sussex counties will contribute to attainment within New Castle County and the Philadelphia based non

- attainment area. Kent and Sussex counties

are within the State of Delaware, contiguous to New Castle County, and are less than 200 kilometers away. EPA’s PM 2.5 Implementation Rule specifically provides for the

consideration of in

- state NO X and SO 2 reductions in their SIPs from sources up to 200

kilometers a way from the non

- attainment area boundaries

. 8

Consistent with this EPA rule, emissions from Kent and Sussex Counties were analyzed. Using the same methodology as above

, statewide em issions are calculated and presented

i n Table 3

- 5. These results indicate that while there is a 2 009 NOx shortfall of 2,303 tpy in New Castle County, there is a statewide NOx surplus of 1,239 tpy

. The analysis

8 PM2.5 Implementation Rule, April 25, 2007 (72 FR 20586 at 20636 )demonst rates that the 2009 MOVES based emission shown in Table 3

- 3 do not impair

Delaware’s ability to meet its SIP em issions targets or meeting EPA’s National Ambient Air Quality Standards f

or particulate matter. 9

Section 4

. Demonstration that the Contingency Measure Requirement s of the CAA are

Met

C ontingency measures are additional control measures to be implemented in the event that an

area fails to either meet “reasonable further progress” or attain the standards by its attainment

date. The quantity of emission reductions needed to satisfy contin gency requirements is an amount equal to one year’s worth of required reductions.

Delaware demonstrated that the contingency requirements of the CAA were met in Section 9 of

its 2008 PM 2.5 SIP by showing that the Delaware control measures have reduced N Ox and primary PM 2.5 by more than is necessary to attain compliance with the PM 2.5 NAAQS

. This same methodology is used below to demonstrate that the “ Revised Delaware Projected 2009

Emissions ” in Table 3

- 4 are low enough to satisfy contingency requirements.

4 .1 Quantification of the c ontingency r equirement is discussed in detail in Section 9.1 of the

2008 PM 2.5 SIP. The contingency requirement for NOx and PM 2.5 is presented in Table

9

- 3 of the 2008 PM 2.5 SIP, and shown below in Table 4

- 1.

Table 4

- 1 Contingency Requirement (tpy)
County NO X PM 2.5 New Castle 1,100 26

4 .2 Demonstration that c ontingency r equirement is met is shown if the “ Revised Delaware Projected 2009 Emissions ” shown in Table 3

- 4 are lower than the “ Attainment Target ”

shown in Table 3

- 1 by at least the amount of the amount of the contingency requirement

shown in Table 4

- 1. Table 3

- 5 shows this calculation.

Table 3

- 5 shows that a 6 4 tpy reduction of PM 2.5 emissions are above and beyond that necessary for attainment. Since 64 tpy is greater than the contingency requirement of 2 6
tpy PM 2.5 , the c ontingency requirement is demonstrated relative to the pollutant primary

PM 2.5. Table 3

- 5 also indicates that NOx requires further analysis

.

4.3 Because of the regional nature of secondarily

- formed sulfate and nitrate, and the broad

mode ling domain of the CMAQ modeling, which included all of Delaware, emission

reductions from Kent and Sussex counties will contribute to attainment within New Castle County and the Philadelphia based non

- attainment area. Kent and Sussex counties are within the State of Delaware, contiguous to New Castle County, and are less than 200 kilometers away. EPA’s PM 2.5 Implementation Rule spe cifically provides for the

9 Note that this is similar to the approach used in the 2008 PM 2.5 SIP to address SO 2 emissions

. See Section 5 (page 65) of the 2008 PM 2.5 SIP

.consideration of in

- state NO X and SO 2 reductions in their SIPs from sources up to 200

kilometers away from the non

- attainment area boundaries

.

Consistent with this EPA rule, emissions from Kent and Sussex Counties were analyzed. Using the same methodology as above , statewide em issions are calculated and presented

i n Table 3

- 5. This indicates that while there is a 2009 NOx shortfall of 2,303 tpy in New Castle County, there is a statewide NOx surplus of 1,239 tpy. Since 1,239 tpy is greater than the contingency requirement of 1,100 tpy NOx, the c ontingency requirement is

demonstrated as met relative to the pollutant NOx

.

Section 5

. Summary

The analysis in Section 3 and Section 4 above demonstrate s that 2009 MOVE S based emission

levels in table 3

- 3 are consistent with attainment and the contingency requirements of the CAA

. This SIP revision is anticipated to be approved by th e EPA in 2012. Because the 2012 based mobile budgets established in Section 2 of this SI P revision are less than the 2009 MOVES based

emission levels shown in Table 3

- 3, Section 3 and Section 4 above also demonstrate that mobile budgets established in Section 2 are consistent with attainment and contingency requirements of

the CAA.

Appendix A. 2012 MOVES input and output files

Appendix B. 2009 MOVES and 2009 MOBILE6 Input and Output Files