SUBJECT:

FROM:

TO:

THRU: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103

Technical Support Document (TSD)- Adequacy Findings for the Motor Vehicle Emissions Budgets in the Maintenance Plans for the Delaware Portion ofthe Philadelphia-Wilmington PA-NJ-DE 1997 and 2006 Fine Particulate (PM2 .5) National Ambient Air Quality Standards (NAAQS) Noriattainment Area Asrah Khadr, Environmental Engineer, EIT ;'/ 

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# P**~** Administrative Record for the Adequacy Findings for the Motor Vehicle Emissions Budgets in the Maintenance Plan for the Delaware Portion ofthe Philadelphia-Wilmington PA-NJ-DE 1997 and 2006 PM2 .5NAAQS Nonattainment Area

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. na Fernandez, As ociate Director Office ofAir Program Planning (3AP30)

I. Background On January 5, 2005, New Castle County was designated as nonattainment for the 1997 PM2
.5 NAAQS as the Delaware portion ofthe Philadelphia-WilmingtonPA-NJ-DE 1997 PM2 .5NAAQS Nonattainment Area. On November 13, 2009, New Castle County was designated as nonattainment for the 2006 PM2 . 5NAAQS as the Delaware portion ofthe PhiladelphiaWilmington PA-NJ-DE 2006 PM2 .5NAAQS Nonattainment Area. The Philadelphia-Wilmington PA-NJ-DE 1997 and 2006 PM2
.5NAAQS Nonattainment Areas both consist ofthe following Pennsylvania, NewJersey and Delaware Counties respectively: Bucks County, Montgomery County, Chester County, Delaware County, Philadelphia County, Gloucester County, Burlington County, Camden County, and New Castle County. The air quality data submitted by the State of Delaware shows that Delaware attained the 1997 and 2006 PM2 .5NAAQS. On May 16, 2012 (77 FR 28782), EPA determined the Delaware portion ofthe Philadelphia-Wilmington PA-NJ-DE 1997 PM2 .5NAAQS Nonattainment Area had air quality data demonstrating that Delaware attained the 1997 PM2
.5NAAQS. On January 7, 2013 (78 FR 882), EPA determined the Delaware portion ofthe Philadelphia-Wilmington PA-NJ-DE 2006 PM2 .5 NAAQS Nonattainment Areahad air quality data demonstrating that Delaware attained the 2006 PM2 .5NAAQS. Additional background information aboutthe Delaware Portion ofthe Philadelphia-Wilmington PA-NJ-DE 1997 and 2006 PM2.s NAAQS Nonattainment Areas is available in the notice ofproposed rulemaking (NPR) in this docket. On December 12, 2012, the Delaware Department ofNatural Resources and Environmental Control (DNREC) formally submitted State Implementation Plan (SIP) revisions to satisfy the redesignation requirements ofthe Clean Air Act (CAA) for the 1997and 2006 PM2

.sNAAQS for the Philadelphia-Wilmington PA-NJ-DE 1997 PM2 .5NAAQS Nonattainment Area and the Philadelphia-Wilmington PA-NJ-DE 2006 PM2 .5NAAQS Nonattainment Area. On September 13,2013, DNREC submitted a formal supplement to the SIP revisions that were submitted on December 12, 2012, in order to clarify the modeled motor vehicle emiSSlOnS.



### II. Transportation Conformity Requirements Under section 176(c) ofthe CAA, new transportation plans, programs, and projects, such as the construction ofnew highways, must "conform" to (i.e., be consistent with) the part ofthe state's air quality plan that addresses pollution from cars andtrucks. The CAA requires federal actions in nonattainment and maintenance areas to "conform to" the goals ofthe SIP. This means that such actions will not cause or contribute to violations ofNAAQS; worsen the severity ofan existing violation; or delay timely attainment ofany NAAQS or any interim milestone. For motor vehicle emissions budgets (MVEBs) to be approvable, they must meet, at a minimum, EPA's adequacy criteria found at 40 CFR 93.118(e)(4). EPA's adequacy criteria are: (1) the submitted control strategy implementationplan was endorsed by the Governor or designee and was subject to a State public hearing; (2) consultation among Federal, State, and local agencies occurred; full implementationplan documentation was provided to EPA; and EPA's stated concerns, ifany, were addressed before the control strategy implementationplan was submitted; (3) the MVEBs are clearly identified and precisely quantified; (4) the MVEBs, when considered together with all other emissions sources, are consistent with applicable requirements for maintenance; (5) the MVEBs are consistent with and clearly related to the emissions inventory and the coptrol measures inthe submitted control strategy implementationplan; and (6) revisions to previously submitted maintenance plans explain and document any changes to previously submitted budgets and control measures; impacts on point and area source emissions; any changes to established safety margins; and reasons for the changes (including the basis for any changes related to emission factors or estimates ofvehicle miles traveled).



### III. Review ofthe Submitted Modeling Utilizing the Motor Vehicle Emission Simulator (MOVES2010)

. To runthe MOVES2010 model, a run specification (hereafter referred to as "RunSpec") must be created so the appropriate parameters are selected for the modeling run. The RunSpecs were reviewed against the following EPA document: Technical Guidance on the use of MOVES2010 for Emission Inventory Preparation in State Implementation Plans and Transportation Conformity. This guidance document provides guidance on the use ofthe MOVES model to develop inventories for SIPs as well as analysis ofemissions for transportation conformity determinations. DNREC submitted MVEBs for the years 2017 and 2025 for the 1997 and 2006 PM2

.sNAAQS. The RunSpecs, input files and output files were reviewed and found to have followed the applicable EPA guidance provided in the Technical Guidance on the use of MOVES2010 for Emission Inventory Preparation in State Implementation Plans and Transportation Conformity. Table 1presents the RunSpec parameters that were reviewed and each parameter's respective 2component in DNREC's submittal.

Table 1. RunSpec Reviews for the 1997 and 2006 PM2.5NAAQS for Years 2017 and 2025 Domain /Scale County scale was selected. This is acceptable for this air quality analysis. Calculation Type Inventory was selected which is acceptable for this analysis. Time Aggregation Level Hourly time aggregation was selected. Selection ofhourly time aggregation level is acceptable for this analysis. Calendar Year Of The appropriate calendar year was selected. MOVES2010b can Evaluation model years 1990 and 1999-2050. Month ofEvaluation All 12 months were selected for evaluation. Type ofDay of Weekdays and weekends were selected. Evaluation Hours ofEvaluation Starting and ending hours create a whole day (from 0-24 hours). Geographic Bounds New Castle County was selected. Vehicles/Equipment: On- Appropriate combinations offuels and source use types were made. Road Vehicle Equipment Road Type Selection included all necessary road types. Pollutants and Processes Nitrogen oxides (NOx), sulfur dioxide (S02), and all forms of primary PM2 . 5were selected, which is acceptable for this analysis. On-Road Retrofits 

### N I A ROP 

### N I A Output Database/Unit Mass units selected to be grams; energy units selected to be million Selection British Thermal Units (BTU); distance units selected to be miles. Output Emission Detail in Emission detail was selected viauser preference. Emission Rate Calculations Advanced Performance 

### N I A Features



### IV. Administrative Requirements for Making Adequacy Findings EPA followed the process for determining the adequacy ofthe submitted SIP MVEBs in accordance with the procedures listed in the January 2008 Conformity Regulations contained in 40 CFRpart 93, 118(f) "Adequacy reviewprocess for implementation plan submissions." EPA will be issuing anNPRfor a 30-daypublic comment period soliciting public comment for the approvability ofDelaware's SIP submission. The NPR also proposes approval ofthe MVEBs for milestone year 2017 and the out-year 2025 forNew Castle County for PM2
.5and NOx

. The MVEBs are presented below in Table 2. On December 19, 2013, a notice was posted on EPA's website at**http://www.epa.gov/otag/stat~resources/transconf/currsips.htn1** for the purpose of opening EPA's 30-daypublic commentperiod on the adequacy/approvability ofthe budgets in the SIP revision. The notice informed the public ofthe availability ofthe Delaware SIP revision on its own website. EPA's website notice will provide a link where interested members ofthe public
3could access the SIP revision. Following EPA'spublic commentperiod, responses to any comments received on the proposed mobile budgets will be addressed in an amendment to this TSD.



### Table 2. 

### MVEBs Contained in the MaintenancePlans for the 1997 and 2006 

### PM2 .5 

### NAAQS Year Motor Vehicle Emissions Mobile Vehicle Emissions Budgetfor Direct PM-Tons Budget for NOx-Tons Per Per Year Year 2017 199 6,273 2025 199 6,273



### V. Evaluation ofthe Adequacy ofthe MVEBs in the Maintenance Plans for the 1997 and 2006 

### PM2.s NAAQS In this TSD, we are evaluating the MVEBs associated with the maintenance plans contained in the December 12, 2012 SIP revision, for confmmity purposes. We are using the evaluation criteria detailed in the Transportation Conformity Rule, 40 CFRpart 93.102(b)(2)(v), 93.102(b)(2)(v),93.102(b)(3), and part 93, 93.118(e)4 through 93.118(e)5. The evaluation is presented in Table 3, below.



### Table 3. Adequacy ofthe MVEBs Contained in the

. Maintenance'Plans for the 1997 and 2006 

### PM2.s NAAQS Transportation Conformity Review Criteria Was the Criterion Satisfied? Rule IfYes Howwas this Criteria 40 CFRPart 93, 93.118 Satisfied?
93.102(b)(2)(iv) Have EPA and the State NeitherEPA nor the State made a finding that NOx is has made such a finding. an insignificant contributor to the direct mobile PM emissions? 93.102(b)(2)(v) Has EPA or State made a Neither EPA nor the State finding that VOCs, Sulfur has made such a finding. Oxides (SOx) orAmmonia (NH3) as precursors to be a significant contributorto the mobile PM2.5 emissions?
93.102(b)(3) Has the EPA or the State Neither EPA nor the State
4made a finding that re- has made such a finding. entrained road dust is a significant contributor to the PM mobile emissions? Sec. 93.118(e)(4)(i) Was the submitted revised Yes, the submitted plan endorsed by the maintenance plans were Governor (or his or her endorsed and submitted as designee) and subject to a SIP revisions by the State public hearing? Governor's designee, the Secretary ofthe DNREC, and a public hearing was held on October 23, 2012. Sec. 93.118(e)(4)(ii) Before the attainment Yes. Consultationhas demonstration was submitted occurred among all required to EPA, did consultation federal, state and local between federal, State and agenc1es. local agencies occur; was full implementationplan documentation provided to EPA, and was EPA's stated concerns, ifany, addressed? Sec. 93.118(e)(4)(iii) Was the motor vehicle Yes, the budgets are clearly emissions budget(s) clearly identified on page46 ofthe identified and precisely maintenance plan for the quantified? 1997 PM2.5NAAQS and on page 51 ofthe maintenance plan for the 2006 

### PMz
.s NAAQS. Sec. 93.118(e)(4)(iv) Is the motor vehicle EPAbelieves the budgets can emissions budget(s), when be declared adequate because considered together with all in conjunction with the other other emission reductions, emissionreductions, they consistent with applicable demonstrate attainment for requirements for attainment years 2017 and 2025. demonstrations?

Sec. 93.118(e)(4)(v) Is the motor vehicle EPAbelieves that the budgets emissions budget(s) are clearly related to the consistent with and clearly emissions inventory and the related to the emissions control measures in the SIP inventory and the control submittal.
5measures in the Plan?

Sec. 93.118(e)(4)(vi) Revisions to previously Yes, the maintenance plans submitted attainment provide newMVEBs for demonstrations: explain and years 2017 and 2025. document any changes to previously submitted budgets and control measures; impacts onpoint and area source emissions; any changes to established safety margins (see Sec. 93.101 for definition); and reasons for the changes (including the basis for any changes related to emission factors or estimates ofvehicle miles traveled).

Sec. 93.118(e)(5) Did they provide and we Yes reviewpublic comments and the State's responses to those comments with the submitted control strategy SIP?

VI. Findings Based upon our review and evaluation ofthe MVEBs contained inDNREC's December 12, 2012 submittal ofthe maintenance plans to satisfy the requirements ofthe 1997 PM2.s NAAQS and the 2006 PM2 

### .s NAAQS, we find the MVEBs to be adequate for conformity purposes and recommend that the MVEBs be SIP approved.

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