DATE:

SUBJECT: Technical Support Document for the Delaware State Implementation Plan for

Regional Haze

FROM: Jacqueline Lewis, Environmental Engineer

Todd A. Ellsworth, Senior Air Modeler

TO: File

( /I”

THRU: Cristina Fernandez, As i t Director

sralter Wilkie, Associate Director

Office of Air Monitoring and Analysis

A. BACKGROUND

On September 25, 2008, the Delaware Department of Natural Resources and Environmental

Control (DNREC) submitted a State Implementation Plan (SIP) revision that addresses regional

haze for the first implementation period. Regional haze is visibility impairment that is producedby a multitude ofsources and activities which are located across a broad geographic area and

emit fine particles (PM25)(e.g., sulfates, nitrates, organic carbon, elemental carbon, and soildust) and their precursors (e.g., sulfur dioxide (SO 2),nitrogen oxides (NO), and in some cases,ammonia (NH 3)and volatile organic compounds (VOC)). Fine particle precursors react in the

atmosphere to form fine particulate matter which impairs visibility by scattering and absorbing

light. Visibility impairment reduces the clarity, color, and visible distance that one can see.PM25 can also cause serious health effects and mortality in humans and contributes to

environmental effects such as acid deposition and eutrophication.

The average visual range’ in many Class I areas (i.e., national parks and memorial parks,

wilderness areas, and international parks meeting certain size criteria) in the western United

States is 100-150 kilometers or about one-halfto two-thirds ofthe visual range that would exist

without anthropogenic air pollution. In most of the eastern Class I areas ofthe United States, the

average visual range is less than 30 kilometers or about one-fifth of the visual range that wouldexist under estimated natural conditions (64 FR 35714, July 1, 1999). In section 169A ofthe

‘Visual range is the greatest distance, in kilometers or miles, at which a dark object can be viewed against the sky.
impairment

(45 FR 80084). These regulations represented the first phase in addressing

visibility impairment.

The requirement to submit a regional haze SIP applies to all 50 states, the District of Columbia,

and the Virgin Islands. 3 Section 51.308(b) requires states to submit the first implementation plan

addressing regional haze visibility impairment no later than December 17, 2007. Regional haze

SIPs must assure reasonable progress towards the national goal of achieving natural visibilityconditions in Class I areas. Section 169A of the CAA and EPA’s implementing regulations

require states to establish long-term strategies for making reasonable progress toward meetingthis goal. Implementation plans must also give specific attention to certain stationary sources

that were in existence on August 7, 1977, but were not in operation before August 7, 1962, andrequire these sources, where appropriate, to install Best Available Retrofit Technology (BART)

controls for the purpose of eliminating or reducing visibility impairment.

B. STATE’S SUBMITTAL

The SIP revision addresses regional haze for the first implementation period. Delaware has no

Class I areas within its borders, but has been identified as influencing the visibility impairment of

the Brigantine National Wildlife Refuge Class I area, located in the State of New Jersey.

Delaware is responsible for developing a regional haze SIP that addresses this Class I area, thatdescribes its long-term emission strategy, its role in the consultation processes, and how the SIP

meets the other requirements in EPA’s regional haze regulations. However, since Delaware has

no Class I areas within its borders, Delaware is not required to address the following Regional

Haze SIP elements: a) calculation of baseline and natural visibility conditions, b) establishment

of reasonable progress goals, c) monitoring requirements, and d) RAVI requirements.

2Areas designated as mandatory Class I Federal areas consist of national parks exceeding 6000 acres, wilderness

areas and national memorial parks exceeding 5000 acres, and all international parks that were in existence on

August 7, 1977. 42 U.S.C. 7472(a). In accordance with section 169A of the CAA, EPA, in consultation with the

Department of Interior, promulgated a list of 156 areas where visibility is identified as an important value (44 FR

69122, November 30, 1979). The extent of a mandatory Class I area includes subsequent changes in boundaries,

such as park expansions. 42 U.S.C. 7472(a). Although states and tribes may designate as Class I additional areas

which they consider to have visibility as an important value, the requirements of the visibility program set forth insection 169A of the CAA apply only to “mandatory Class I Federal areas.” Each mandatory Class I Federal area is

the responsibility of a “Federal Land Manager.” 42 U.S.C. 7602(i). When we use the term “Class I area” in this

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action, we mean a “mandatory Class I Federal area.”

Albuquerque/Bernalillo County in New Mexico must also submit a regional haze SIP to completely satisfr the

requirements of section 11 0(a)(2)(D) of the CAA for the entire State of New Mexico under the New Mexico Air

Quality Control Act (section 74-2-4).

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The LTS was developed by Delaware, in coordination with MANE-VU, identifying the

emissions units within Delaware that likely have the largest impacts currently on visibility at the

Brigantine National Wildlife Refuge Class I area, estimating emissions reductions for 2018,

based on all controls required under federal and state regulations for the 2002-2018 period

(including BART), and comparing projected visibility improvement with the uniform rate of

progress for the Brigantine National Wildlife Refuge Class I area.

Delaware’s LTS includes measures needed to achieve its share of emissions reductions agreedupon through the consultation process with New Jersey and includes enforceable emissions

limitations, compliance schedules, and other measures necessary to achieve the reasonable

progress goals established by New Jersey for the Brigantine National Wildlife Refuge Class I

area.

Emissions Inventory for 2018 with Federal and State Control Requirements

The emissions inventory used in the regional haze technical analyses was developed by MidAtlantic Regional Air Management Association (MARAMA) for MANE-VU with assistance

from Delaware. The 2018 emissions inventory was developed by projecting 2002 emissions, andassuming emissions growth due to projected increases in economic activity as well as applying

reductions expected from federal and state regulations affecting the emissions of VOC and thevisibility-impairing pollutants NON, PM10 PM25,and SO2. The BART guidelines direct states to

exercise judgment in deciding whether VOC and NH3impair visibility in their Class I area(s).

MANE-VU demonstrated that anthropogenic emissions ofsulfates are the major contributor toPM25mass and visibility impairment at Class I areas in the Northeast and Mid-Atlantic region.

It was also determined that the total ammonia emissions in the MANE-VU region are extremelysmall. In addition, since VOC emissions are aggressively controlled through Delaware’s SIP, the

pollutants Delaware considered under BART are NON, PM10 PM25,and SO2.

MANE-VU developed emissions inventories for four inventory source classifications: 1)

stationary point sources, 2) area sources, 3) off-road mobile sources, and 4) on-road mobile

sources. The New York Department of Environmental Conservation also developed aninventory of biogenic emissions for the entire MANE-VU region. Stationary point sources are

those sources that emit greater than a specified tonnage per year, depending on the pollutant,with data provided at the facility level. Stationary area sources are those sources whose

individual emissions are relatively small, but due to the large number ofthese sources, the •collective emissions from the source category could be significant. Off-road mobile sources areequipment that can move but do not use the roadways. On-road mobile source emissions are

automobiles, trucks, and motorcycles that use the roadway system. The emissions from these

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improvement by 2018 in the Brigantine National Wildlife Refuge. To assess emissions

reductions from ongoing air pollution control programs, BART, and reasonable progress goals

MANE-VU developed 2018 emissions projections called Best and Final. The emissionsinventory provided by the State of Delaware for the Best and Final 2018 projections is based on

adopted and enforceable requirements.

The ongoing air pollution control programs relied upon by Delaware for the Best and Finalprojections include the Valero Refinery consent decree # H-01-0978; Delaware’s Regulation

1144 -Control of Stationary Generator Emissions; Regulation 1146 -Electric Generating Unit

Multi-Pollutant Regulation; Regulation 1148 -Control of Stationary Combustion TurbineElectric Generating Unit Emissions; Regulation 1142, Section 1 -Control ofNO Emissions

from Industrial Boilers; Regulation 1142, Section 2 -Control ofNO Emissions from IndustrialBoilers and Process Heaters at Petroleum Refineries; Regulation 1124, Section 46 -Crude OilLightering Operations; the NO SIP Call; NO and/or VOC reductions from the control rules in

the 1-hour and 8-hour ozone SIPs for Delaware; NO Ozone Transport Commission (OTC) 2001

Model Rule for Industrial, Commercial, and Institutional (ICI) Boilers; federal 2007 heavy duty

diesel engine standards for non-road trucks and buses; federal Tier 2 tailpipe controls for the onroad vehicles; federal large spark ignition and recreational vehicle controls; and EPA’s non-road

diesel rules. The estimated emissions reductions resulting from Delaware’s EGU Regulations

1144, 1146, and 1148 are 75% for SO2and 57% for NO from 2002 base year.

Delaware also relied on emission reductions from various federal Maximum Achievable Control

Technology (MACT) rules in the development ofthe 2018 emission inventory projections.These MACT rules include the combustion turbine and reciprocating internal combustion

engines MACT, the industrial boiler and process heaters MACT and the 2, 4, 7, and 10 yearMACT standards.

On July 30, 2007, the U.S. District Court of Appeals mandated the vacatur and remand of theIndustrial Boiler MACT Rule. 4 This MACT was vacated since it was directly affected by the

vacatur and remand ofthe Commercial and Industrial Solid Waste Incinerator (CISWI)

Definition Rule. EPA proposed a new Industrial Boiler MACT rule to address the vacatur on

June 4, 2010, (75 FR 32006) and issued a final rule on March 21, 2011(76 FR 15608).

Delaware’s modeling included emission reductions from the vacated Industrial Boiler MACT

rule. Delaware did not redo its modeling analysis when the rule was re-issued. However, the

expected reductions in SO2and PM are small relative to the Delaware inventory. Therefore,

EPA finds the expected reductions of the new rule acceptable since the final rule requires

compliance by 2014, it provides Delaware time to assure the required controls are in place prior

NRDC v. EPA, 489F.3d 1250.

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Table 1. 2002 Emission Inventory Summary for Delaware in Tons per Year

VOC NO, PM2.5 PM10 NH3 SO2

Point 4,755 16,345 3,666 4,217 196 73,744

Area 15,519 2,608 3,204 13,039 13,279 1,588

On-Road Mobile 10,564 21,341 415 581 903 584Off-Road Mobile 8,010 16,227 926 1,021 5 3,983

Biogenic 46,343 990 0 0 0 0

Total 85,191 57,511 8,211 18,858 14,383 79,899

Table 2. 2018 Emission Summary for Delaware “Best and Final” in Tons per Year

VOC NO, PM2.5 PM10 NH3 SO2

Point 2,104 16,587 3,692 4,437 210 16,707

Area 13,066 3,014 3,073 10,500 13,342 380

On-Road Mobile 5,037 5,917 191 202 1,328 128Off-Road Mobile 5,652 14,631 808 896 6 3,296

Biogenic 46,343 990 0 0 0 0Total 72,202 41,139 7,764 16,035 14,886 20,511

Modeling to Support the LTS and Determine Visibility Improvement for Uniform Rate of

Progress

MANE-VU performed modeling for the regional haze LTS for the 11 Mid-Atlantic and

Northeast states and the District of Columbia. The modeling analysis is a complex technical

evaluation that began with selection of the modeling system. MANE-VU used the following

modeling system:

• Meteorological Model: The Fifth-Generation Pennsylvania State University/National

Center for Atmospheric Research (NCAR) Mesoscale Meteorological Model (MM5)

version 3.6 is a nonhydrostatic, prognostic meteorological model routinely used for

urban- and regional- scale photochemical, PM2.5and regional haze regulatory modeling

studies.

• Emissions Model: The Sparse Matrix Operator Kernel Emissions (SMOKE) version 2.1

modeling system is an emissions modeling system that generates hourly gridded

speciated emission inputs ofmobile, non-road mobile, area, point, fire and biogenicemission sources for photochemical grid models.

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emissions to sulfate levels at selected Class I receptor sites.

The MANE-VU was tasked with the assignment of preparing a PM2.5modeling platform that all

member states could use to model their LTSs to demonstrate reasonable progress by 2018 in

meeting the ultimate goal of natural visibility conditions by 2064. The New York State

Department of Environmental Conservation (NYSDEC) was the lead agency for coordinating

and running the modeling platform used by the MANE-VU RPO. Modeling centers responsible

for running the platform included the NYSDEC, the University of Maryland at College Park

(UMD), the Northeast States for Coordinated Air Use Management (NESCAUM), the New

Jersey Department of Environmental Protection (NJ DEP), and the Virginia Department of

Environmental Quality (VA DEQ). Each modeling center was responsible for installing the

modeling platform, conducting diagnostic tests and completing a benchmark run to ensure

accurate results.

MANE-VU used the CMAQ version 4.5.1 as its photochemical grid model. The model uses

simulations of chemical reactions, emission ofPM2.5 and PM2.5precursors and a sophisticated

meteorological model (The Pennsylvania State University/National Center for Atmospheric

Research Mesoscale Meteorological Model) to produce speciated PM2.5concentrations over the

eastern United States. The meteorological data used in the meteorological model was for the

2002 base year. The photochemical grid model was run with the base year meteorology and base

year emissions to determine ifthe model performance was satisfactory. Once the model

performance was determined to be adequate, PM 2.5 concentrations were modeled by running the

model with projected emissions for 2018 and the original 2002 meteorology. The meteorology

was held constant so that the results of changing the emissions would not be influenced by

changing meteorology.

The Delaware Visibility SIP addresses each ofthe required elements of a modeling analysis used

to predict visibility improvement that is expected by 2018.

Conceptual Description of the Problem

A conceptual model describes how weather patterns affect the formation and transport ofPM2.5,

accounting for emissions and photochemistry.

The conceptual model for the Delaware SIP is described in the Attachment 1 entitled: The

Nature ofthe Fine Particle and Regional Haze Air Quality Problems in the Mid-Atlantic

Northeast Visibility Union (MANE- VU) Region: A Conceptual Description (NESCA UM),November 2006. This document was prepared by Northeast States for Coordinated Air Use

Management (NESCAUM) for use by the OTC member States, and it provides the conceptual

description ofthe fine particle issues in the OTC states, consistent with the EPA’s guidance.

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PA

NJ

DE PM2.5nonattainment area and the accumulation of airborne sulfate (via atmospheric

oxidation of SO2)followed by long-range transport of sulfur emissions from industrialized areas

within and outside the area. National assessments have indicated that in the winter, sulfate levelsin urban areas are higher than background sulfate levels across the eastern U.S., indicating thatthe local urban contribution to wintertime sulfate levels is significant relative to the regional

sulfate contribution from long-range transport. A network analysis for the winter of 2002suggests that the local enhancement ofsulfate in urban areas of the MANE-VU region ranges

from 25 to 40% and that the long-range transport component ofPM2.5sulfate is still the dominantcontributor in most eastern cities.

In the winter, urban organic carbon and sulfate each account for about a third of the overall PM2.5

mass concentration observed in Philadelphia and New York City areas. Nitrate also makes a

significant contribution to urban PM2.5levels observed in the northeastern United States during

the winter months. Wintertime concentrations of OC and nitrate in urban areas can be twice the

average regional concentrations of these pollutants, indicating the importance of local source

contributions. This is likely because winter conditions are more conducive to the formation of

local inversion layers which prevent vertical mixing. Under these conditions, emissions from

tailpipe, industrial and other local sources become concentrated near the Earth’s surface, addingto background pollution levels associated with regionally transported emissions.

In summary, the presence of fine particulate matter in ambient air significantly obscures

visibility during most parts ofthe year at sites across the MANE-VU region. Particle pollution

generally, and its sulfate component specifically, constitute the principle driver for regional

visibility impacts. While the broad region experiences visibility impairment, it is most severe in

the southern and western portions of MANE-VU that are closest to large power plant SO2

sources in the Ohio River and Tennessee Valleys.

The presence or absence ofregional sulfate almost exclusively drives summer visibility

impairment, whereas winter visibility depends on a combination of regional and local influencescoupled with local meteorological conditions (inversions) that lead to the concentrated build-upof pollution.

Sulfate is the key particle constituent from the standpoint of designing control strategies to

improve visibility conditions in the northeastern United States. Significant further reductions in

ambient sulfate levels are achievable, though they will require more than proportional reductions

in SO2emissions.

Long-range pollutant transport and local pollutant emissions are important, especially along theeastern seaboard, so one must also look beyond the achievement of further sulfate reductions.

During the winter months, in particular, consideration also needs to be given to reducing urbansources of SO2,as well as NOx and OC (NARSTO, 2003).

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developed by ICF Consulting/Systems Applications International (ICF/SAI) with EPA support.CMAQ has undergone extensive community development and peer review (Amar et al., 2005)

and has been successfully used in a number ofregional air quality studies (Bell and Ellis, 2003;Hogrefe et al., 2004; Jimenez and Baldasano, 2004; Mao and Talbot, 2003; Mebust et al., 2003).

REMSAD has also has been peer reviewed (Seigneur et al., 1999) and used by EPA for

regulatory applications (www.epa.gov/otaq/regs/hd2007/frm/r00028.pdf and

www.epa.gov/clearskies/airgualitytech.html) to study ambient concentrations and deposition

ofsulfate and other PM species.

Five modeling centers, worked collectively to maximize efficiency of computing resources inMANE-VU for SIP modeling. These centers include NY DEC, NJ DEP/Rutgers, VA DEQ,

UMD, and NESCAUM.

Meteorological Time Periods Used in the Modeling

All of 2002, which represents the baseline period from 2000 to 2004, was included in CMAQ

modeling. 2002 was divided into five periods. UMD is responsible for modeling the period from

January 1 to February 28; NJ DEP/Rutgers are responsible for the period from March 1 to May

14; NY DEC is responsible for the period from May 15 to September 30; VA DEQ is responsible

for the period from October 1 to October 31; and NESCAUM is responsible for the period from

November 1 to December 31. Each period uses a 15 day spin up run to minimize the impact of

the default initial concentration fields. Each group performs CMAQ simulations on its period for

a series ofscenarios including 2002 Base Case, 2009 Base Case, 2018 Base Case, 2009 ControlCase, and 2018 Control Case. All scenarios adopt the same meteorological field (2002) and

boundary conditions, varying only emission inputs. To ensure consistency between modeling

groups, a benchmark test was conducted by each group.

Meteorological Data Used in the Air Quality Model

The MANE-VU states decided to use a prognostic meteorological model that provides life-like

meteorological inputs to the photochemical grid model. The Pennsylvania State

University/National Center for Atmospheric Research Mesoscale Meteorological Model version3.6 was chosen for the modeling analysis. The MM5 model provides a reasonable representationof weather conditions at the surface and aloft.

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directions, respectively. A 1 2

km inner domain was selected to better characterize air quality in

MANE-VU and surrounding RPO regions. This domain covers the eastern region, which

includes the northeastern, central, and southeastern U.S., as well as southeastern Canada. It

extends from 66oW94oW in longitude and 29oN’—5OoN in latitude with 172 x 172 grid cells

(Figure 1).

I

Vertical resolution is the number of layers and the size of each layer in the model. The layers inthe photochemical grid model were set up to be compatible with the model that produced

weather conditions for the photochemical grid model. The vertical resolution used in themodeling exercise followed EPA’s modeling guidance and therefore adequately represents the

atmosphere where PM2.5is emitted, forms and is transported.

Figure 1 -Modeling domains used in MANE-VU air quality modeling studies with

CMAQ. Outer (blue) domain grid is 36 km and inner (red) domain is 12 km grid.

The gridlines are shown at 180 km intervals (5 X 5 36 km cells/iS x 15 12 km cells).

102

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haze, MANE

VU and the State of Delaware are using 2002 as the baseline year. Future year

inventories were developed for the years 2009, 2012 and 2018 based on the 2002 base year.

These future year emission inventories include emissions growth due to projected increases in

economic activity as well as the emissions reductions due to the implementation of control

measures.

The 2002 emissions were first generated by the individual states in the MANE-VU area.

MARAMA then coordinated and quality assured the 2002 inventory data. The 2002 emissionsfrom non-MANE-VU areas within the modeling domain were obtained from other Regional

Planning Organizations for their corresponding areas. These Regional Plaiming Organizations

included the Visibility Improvement State and Tribal Association of the Southeast (VISTAS),

the Midwest Regional Planning Organization and the Central Regional Air Planning Association.

Version 3 ofthe 2002 base year emission inventory was used in the regional modeling exercise.

Technical support documentation for the MANE-VU 2002 base inventory is presented inAppendix 7-1 of the Delaware Visibility SIP. This document explains the data sources, methods,

and results for preparing this version of the 2002 base year criteria air pollutant and ammonia

emissions inventory. Documentation for the future year estimations of EGUs is presented in

Appendix 7-3 of the Delaware Visibility SIP. Documentation for the future year estimations of

the remaining source sectors (non-EGU sectors) is presented in Appendix 7-4 of the DelawareVisibility SIP.

Model Performance Evaluation

NESCAUM evaluated the 2002 annual 12 km resolution meteorological fields generated by

MM5 using ENVIRON’s METSTAT program. Model results of surface wind speed, winddirection, temperature, and humidity were paired with measurements from EPA’s Clean Air

Status and Trends Network (CASTNET) and National Center for Atmospheric Research’s

Techniques Data Laboratory (TDL) network by hour and by location and then statistically

compared. Based on this statistical comparison between model prediction and data from the two

networks for wind speed, wind direction, temperature, and humidity, MM5 performs well. An

acceptable small bias, high index of agreement and strong correlation with CASTNET and TDL

data are shown. Since MM5 uses TDL data for nudging, the model predictions are in betteragreement with TDL data than with CASTNET data. MM5 performs better in Midwest and

Northeast than Southeastern US.

CMAQ modeling was conducted for year 2002 by cooperative modeling efforts from NYDEC,

UMD, NJDEP, Rutgers, VADEP, and NESCAUM. CMAQ Performance for PM2.5species and

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statistically analyzed to generate MFE and MFB values. Considering CMAQ performance in

terms of MFE and MFB goals, sulfate, nitrate, OC, EC, and PM2.5all had the majority of data

points within the goal curve, some were between the goal and acceptable criteria, and only a few

were outside the criteria curve. Only fine soil has the majority of points outside the criteria curve,

but there were some sites still within the goal. For the MANE-VU region, CMAQ performs best

for PM2.5sulfate, followed by PM25,EC, nitrate, OC, and then fine soil. Regional haze modeling

also requires CMAQ performance evaluation for aerosol extinction coefficient (Bext) and the

haze index. Modeled daily aerosol extinction at each improve site was calculated following the

IMPROVE formula with modeled daily PM2.5species concentration and relative humidityfactors from IMPROVE. The approach used natural background visibility estimates and the haze

index following EPA Guidance. The modeled Bext showed a near I :1 linear relationship (slope of0.78 and r2 of 0.46) with IMPROVE observed Bext. The regression excluded three points from

July 7, 2002; the monitors were directly impacted by Canadian fires whose emissions were not

modeled.

Uniform Rate of Progress Goals

The key difference between SIPs from States with Class I areas and those States without Class I

areas, but may have sources that impact visibility on Class I areas, is the calculation of the

baseline and natural visibility for their Class I areas and the determination of uniform rate ofprogress goals - expressed in deciviews - that provide for reasonable progress towards achieving

natural visibility by 2064. It is the Class I states responsibility assess these calculations. The

Class I States must also consult with those States, which may reasonably be anticipated to causeor contribute to visibility impairment in their Class I areas (40 CFR 51.308 (d)( 1 )(i-vi)).

The baseline visibility conditions are calculated for the baseline period between 2002 and 2004.The average impairment for the 20 most and 20 least impaired days are determined for each

calendar year and compiled into the average ofthree annual averages (40 CFR 51.308 (d)(2)(i)).

The natural visibility conditions are determined for the same baseline period with the most andleast impaired days determined by available monitoring data or an appropriate data analysis

technique (40 CFR 5 1.308 (d)(iii-iv)).

EPA released guidance on June 7, 2007 to use in setting reasonable progress goals. The goals

must provide improvement in visibility for the most impaired days, and ensure no degradation in

visibility for the least impaired days over the SIP period. The State must also provide an

assessment of the number of years it would take to attain natural visibility condition if

improvement continues at the rate represented by the reasonable progress goal. Figure 2

illustrates an example of how Uniform Rate of Progress is calculated.

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Baseline

He Index(deciviews)

Natural

Conditions

ID

2064

Modeled Visibility Projections for 2018

The CMAQ air quality model was used to simulate base period emissions and future emissions.

The modeling results for the base year period (2002) and the year representing the end ofthe first

planning period (2018) are used to develop relative response factors (RRF) for each component

of particulate matter identified previously in this TSD. The relative response factors are

multiplied by the measured species concentration data during the base period (for the measured20% best and worst days). This results in daily future year species concentrations data. Theprojected concentrations are then used to derive daily visibility in deciviews and are averaged

across all best and worst days to create the projected future visibility. The results of this

procedure are plotted along with the uniform progress glide slope in Figure 3-1 through Figure 3-

7 in Appendix 9.7 ofthe Delaware Visibility SIP.

The modeling results presented in Appendix 9.7 ofthe Delaware Visibility SIP show all MANEVU sites are projected to meet or exceed the uniform rate of progress goals for 2018 on the 20

percent worst days. In addition, no site anticipates increases in visibility impairment relative tothe baseline on the 20 percent best days.

2004 2014 2024 204 2044 2054

Year

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Contribution Assessment

The 1999 Regional Haze Rule requires States and Tribes to submit State Implementation Plans to

EPA for approval by January 2008 at the latest. The haze SIPs must include a “contribution

assessment” to identify those states or regions that may be influencing specially protected federal

lands known as Federal Class I areas. 5These states or regions would then be subject to theconsultation provisions of the Haze Rule. The Haze Rule also requires a “pollution

apportionment” analysis as part of the long-term emissions management strategy for each site.

As described in the Conceptual Description portion of this TSD, sulfate alone accounts for

anywhere from one-halfto two-thirds oftotal fine particle mass on the 20 percent haziest days at

MANE-VU Class I sites. As a result ofthe dominant role ofsulfate in the formation of regional

haze in the Northeast and Mid-Atlantic region, MANE-VU concluded that an effective emissionsmanagement approach would rely heavily on broad-based regional SO2control efforts in the

eastern United States.

Area of Influence for MANE-VU Class I Areas

The key difference between SIPs from States with Class I areas and States without Class I areasis the calculation of the baseline and natural visibility for their Class I areas, and thedetermination ofreasonable progress goals. Class I States calculate baseline visibility conditionsfor the period between 2002 and 2004. The average impairment for the most and least impaired

days are determined for each calendar year and compiled into the average ofthree annual

averages (40 CFR 51.308 (d)(2)(i)). The natural visibility conditions are determined for the same

baseline period with the most and least impaired days determined by available monitoring data or

an appropriate data analysis technique (40 CFR 51.308 (d)(iii-iv)). In contrast, States withoutClass I areas are responsible for doing their fair share to help meet the reasonable progress goals

established by the impacted Class I States, and for maintaining their emissions monitoring

network.

Class I designation applies to national parks exceeding 6,000 acres, wilderness areas and national memorial

parks exceeding 5,000 acres, and all international parks that were in existence prior to 1977. In the MANE-VU area,

this includes: Acadia National Park, Maine; Brigantine Wilderness (within the Edwin Wilderness, Vermont;

Moosehorn Wilderness (within the Moosehorn National Wildlife Refuge), Maine; B. Forsythe National WildlifeRefuge), New Jersey; Great Gulf Wilderness, New Hampshire; Lye Brook Presidential Range — Dry River

Wilderness, New Hampshire; and Roosevelt Campobello International Park, New Brunswick.

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Based on that work, MANE-VU concluded that it was appropriate to define an “Area of

Influence” (AOl) including all ofthe states participating in MANE-VU piother states outsideMANE-VU for which modeling indicated they contributed at least two percent (2%) of the

sulfate ion in MANE-VU Class I areas in 2002. The Visibility Improvement State and Tribal

Association of the Southeast (VISTAS) 6also conducted an AOl analysis, which used a level of

one percent (1%) to assess whether an upwind state significantly contributed. The VISTAS AOl

did not show Delaware to be a contributor to any VISTAS Class I area.

•1

The primary contribution assessment tool used in the Delaware Visibility SIP was the RegionalModeling System for Aerosols and Deposition (REMSAD) (SAl, 2002). A significant feature of

the REMSAD work used to evaluate regional contributions is that NESCAUM reprocessed the

SO2emission data from each state to take advantage ofREMSAD’s tagging capabilities. Thus,

all SO2emissions included in the model for the eastern half of the country were tagged according

to state of origin, and emissions from Canada and the boundary conditions were also tagged.

This allowed for a rough estimation ofthe total contribution from elevated point sources in each

state to simulated sulfate concentrations at eastern receptor sites. Using identical emission and

meteorological inputs to those prepared for the CMAQ SIP modeling platform, described earlier

in this TSD, REMSAD was used to simulate the annual average impact of each state’s SO2emission sources on the sulfate fraction ofPM25 over the northeastern United States. A more indepth description ofthe REMSAD modeling used for contribution assessment can be found in

Appendix 1-la of the Delaware Visibility SIP.

The REMSAD contribution assessment modeling contained in the Delaware Visibility SIP

conforms to EPA modeling requirements and is acceptable to EPA.

REMSAD Contribution Assessment Results

MANE-VU States decided that any state or region that contributed at least 2 percent oftotal

sulfate observed on 20 percent worst visibility days in 2002 is contributing significantly to the

haze problem in that particular Class I area. Based on the MANE-VU Contribution Assessment

and the application of the “2% SO2rule,” emissions from Delaware were determined tocontribute to visibility degradation exclusively to the Brigantine Wilderness Class I area.

6 VISTAS is comprised of the following states: Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina,

South Carolina, Tennessee, Virginia, West Virginia, the Eastern Band of Cherokee Indians, and Knox County, TN

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The technical analyses and modeling used to assess uniform rate of progress and to support the

LTS were successfully developed consistent with EPA’s interim and final modeling guidance.

All MANE-VU sites are projected to meet or exceed the uniform rate of progress goal for 2018

on the 20 percent worst days. In addition, no site anticipates increases visibility impairment

relative to the baseline on the 20 percent best days. EPA finds the MANE-VU technical

modeling analyses presented in the Delaware Visibility SIP to be acceptable because the models

that were used were applied according to EPA modeling guidance.

Relative Contributions of Pollutants to Visibility Impairment

An important step toward identifying reasonable progress measures is to identify the keypollutants contributing to visibility impairment at each Class I area. To understand the relative

benefit of further reducing emissions from different pollutants, MANE-VU developed emission

sensitivity model runs using CMAQ to evaluate visibility and air quality impacts from various

groups of emissions and pollutant scenarios in the Class I areas on the 20 percent worst visibilitydays.

Regarding which pollutants are most significantly impacting visibility in the MANE-VU region,

MANE-VU’s contribution assessment, demonstrated that sulfate is the major contributor to

PM2.5mass and visibility impairment at Class I areas in the Northeast and Mid-Atlantic region.

Sulfate particles commonly account for more than 50 percent of particle-related light extinction

at northeastern Class I areas on the clearest days and for as much as or more than 80 percent on

the haziest days. In particular, for the Brigantine National Wildlife Refuge Class I area, on the 20percent worst visibility days in 2000 — 2004, sulfate accounted for 66 percent ofthe particle

extinction. After sulfate, organic carbon (OC) consistently accounts for the next largest fraction

of light extinction. Organic carbon accounted for 13 percent of light extinction on the 20 percent

worst visibility days for Brigantine, followed by nitrate that accounts for 9 percent oflight

extinction.

The emissions sensitivity analyses conducted by MANE-VU predict that reductions in SO2

emissions from EGU and non-EGU industrial point sources will result in the greatest

improvements in visibility in the Class I areas in the MANE-VU region, more than any other

visibility-impairing pollutant. As a result ofthe dominant role ofsulfate in the formation of

regional haze in the Northeast and Mid-Atlantic region, MANE-VU concluded that an effective

emissions management approach would rely heavily on broad-based regional SO2control efforts

in the eastern United States.

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implementation of BART requirements; (b) a 90 percent reduction in SO2emissions from each

of the EGU stacks identified by MANE-VU comprising a total of 167 stacks (5 are located inDelaware); (c) adoption of a low sulfur fuel oil strategy; and (d) continued evaluation of other

control measures to reduce SO2and NO emissions.

In order to address a timely implementation of BART, Delaware’s Regulation 1146 — Electric

Generating Unit Multi-Pollutant Regulation was determined to be BART for NO and SO2emissions. The first phase of the emission limits became effective in 2009 and second phase will

become effective in 2012. The BART limitation will become effective no later than January 1,

2013, for the PM control strategies.

States were required to reduce SO2emissions from the highest emission stacks in the eastern

U.S. by 90 percent or ifit was infeasible to achieve that level ofreduction, an alternative had to

be identified which could include other point sources. Delaware’s Connective Edge Moor Unit 5

and NRG Indian River Units 1 - 4 are five of the 167 units identified by MANE-VU as having

the highest emissions in the eastern United States. The 2002 base year SO2emissions from thesefive units are 22,121 tons per year. A 90% SO2emission reduction ofthese five units would

result in 19,909 tons per year. However, the 2018 SO2emission reductions that resulted from the

implementation of Regulation 1146 for these five units are 16,662 tons per year. These

reductions are not enough to satisfy the 90% emission reduction from a 2002 baseline

requirements. However, Delaware considered all of the emission reductions from all the other

units obtained through the implementation ofRegulation 1146 — Electric Generating Unit MultiPollutant Regulation and this resulted in 23,826 tons per year, which produced a surplus of 3,917

tons per year of 502 emission reductions.

The low sulfur fuel oil strategy has four requirements for the State of Delaware. These

requirements are to reduce the distillate oil to 0.05% sulfur by weight (500 parts per million) nolater than 2012, #4 residual oil to 0.25 % sulfur by weight no later than 2012, #6 residual oil to

0.3 — 0.5 % sulfur by weight no later than 2012, and further reduce the sulfur content of distillate

oil to 15 ppm by 2016. Table 3 shows the SO2emission reductions that would result from theimplementation of a low sulfur fuel oil strategy in Delaware compared to the existing currently

implemented regulations.

Table 3. Reasonable Progress Goal - Low Sulfur Fuel Oil Strategy

Low Sulfur Fuel Oil Strategy 2018 SO2 Emissions 2018 SO2Emissions

Reductions (TPY) Increase/ReductionBased on the Low (TPY) Based on

Sulfur Fuel Oil Existing Control

Strategy Request Measure

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emission reductions needed to meet the requirements ofthe low sulfur fuel strategy.

Delaware identified two measures that demonstrate their efforts to continued evaluation of other

control measure to reduce SO2and NON. Delaware’s Executive Order 31 requires their Energy

Task Force to expand the diversity of fuels used to meet Delaware’s current and future energy

resources, develop conservation programs to reduce the need to build more electric generation

facilities, ensure that energy infrastructure will meet Delaware’s future needs for efficiently

transporting energy resources, and encourage producers of clean energy technologies andproducers of energy efficient products to locate their business operations in Delaware.

BART

BART is an element of Delaware’s LTS. The BART RH requirement consists ofthree

components: (a) identification of all the BART eligible sources; (b) an assessment of whether

the BART eligible sources are subject to BART; and (c) the determination of the BART controls.

BART Eligible Sources

The first component of a BART evaluation is to identify all the BART eligible sources. The

BART eligible sources were identified utilizing the criteria in the BART Guidelines as follows:

• Determine whether one or more emissions units at the facility fit within one ofthe 26

categories listed in the BART Guidelines (70 FR 39158-39159)

• Determine whether the emission unit(s) was in existence on August 7, 1977 and begun

operation after August 6, 1962;

• Determine whether potential emissions of SO2,NON, and PM10 from subject units are 250

tons or more per year.

The BART guidelines recommend addressing SO2,NON, and PM10 as visibility-impairmentpollutants and leave it up to the discretion of states to evaluate VOC or ammonia emissions.

Because of the lack of tools available to estimate emissions and subsequently model VOC and

ammonia effects on visibility, and because Delaware is aggressively addressing VOCs through

its ozone SIPs, Delaware determined that SO2,NO and PM1012 .5are the only reasonable

contributing visibility impairing pollutants to target under BART. Delaware identified four

BART eligible sources (consisting of five emission units). One of the four sources is a steel milland the other three sources are electric generating units as described in Table 4.

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Ezrac Claymont Steel — Electric Arc Not Not SO2,NON, PM Claymont

Furnace and Reheater Applicable Applicable

BART Subject Sources

The second component ofthe BART evaluation is to identify those BART eligible sources thatmay reasonably be anticipated to cause or contribute to visibility impairment at any Class I area

are subject to BART. As discussed in the BART guidelines, a state may choose to consider all

BART eligible sources to be subject to BART. (70 FR 39.16 1) Consistent with the MANE-VU

Board’s decision in June 2004 that because ofthe collective importance of BART sources BARTdetermination should be made by the MANE-VU states for each BART eligible source.

Delaware identified each ofits BART eligible sources as subject to BART.

One ofthe BART eligible facilities in Delaware the Ezrac Claymont Steel, is a relatively small

emissions source with potential emissions that exceeded the statutory threshold of 250 tons per

year or more, but the actual emissions of visibility impairing pollutants of well under 250 tonsper year. The steel mill requested a limit on its potential to emit, to bring its emissions under 250

tons per year threshold for BART sources. Delaware established federally enforceable terms and

conditions in a Title V permit for the Reheat Furnace and Electric Arc Furnace at Evraz

Claymont Steel Mill that limit the potential to emit for SO2,NON, and PM10 to less than 250 tons

per year.

Determination of BART

The final component of a BART evaluation is making BART determinations for all BART

subject sources. In making BART determinations, section 169A(g)(2) of the CAA requires that

States consider the following factors: (1) the costs of compliance; (2) the energy and non-air

quality environmental impacts of compliance; (3) any existing pollution control technology in

use at the source; (4) the remaining useful life of the source; and (5) the degree of improvement

in visibility which may reasonably be anticipated to result from the use ofsuch technology.

Section (e)(2) of the Regional Haze Rule provides that a State may opt to implement an

emissions trading program or other alternative measure rather than to require sources subject to

BART to install, operate, and maintain BART. To do so, the State must demonstrate that the

emissions trading program or other alternative measure will achieve greater reasonable progress

than would be achieved through the installation and operation of BART.
BART subject sources for PM.

Sulfur Dioxide and Nitrogen Oxide

In order to determine appropriate NO and SO2emission rates for inclusion in Regulation 1146,

Delaware collected guidance and information from a number of sources to assist in its evaluationof appropriate emissions limits. The methods Delaware used to develop Regulation 1146incorporate many of the criteria used in the 5 factor analyses required by the Regional Haze Rule

and included the following; (1) control technology effectiveness; (2) capital costs; (3) complexity

with regards to application on cycling units; (4) changes in plant auxiliary loads; (5) impact on

plant operations and flexibility (6) operation and maintenance costs; (7) size of the affected

units; and (8) expected remaining operating life of the affected units.

Ofthe eight units subject to Delaware’s Regulation 1146, four have been identified as BART

units. Regulation 1146 incorporates emissions rate limitations based on a suite of emissionreduction technology capabilities, but did not specify or require the installation of any particular

emission reduction technology or suite oftechnologies. Table 5 shows Delaware promulgated

the emission rate limitations for NO and SO2the Delaware promulgation in Regulation 1146.

Table 5. Regulation 1146 Emission Rate Limitations

2009 2012

NO — Coal & Residual Oil Fired EGU’s 0.l5lb/MMBTU 0.125 lb/MMBTU

SO2 — Coal Fired EGU’s 0.37 lb/MMBTU 0.26 lb/MMBTUSO2 — Residual Oil Fired EGU’s 0.5% Sulfur Fuel Oil 0.5% Sulfur Fuel Oil

For the above rate limits, all lb/MMBTU limits are continuous and based on a rolling 24-hour

averaging period that began on May 1, 2009. For the sulfur in fuel oil limits, facilities are not

permitted to accept fuel oil with sulfur content greater than 0.5% by weight on or after January 1,

2009.

Delaware did a comparison of Regulation 1146 emission rate limits of all eight units regulated

by this rule to the BART presumptive limits for the four BART subject units. This comparison

shown in Tables 6 for SO2and Table 7 for NO demonstrates that because Regulation 1146

emissions rate limits are applicable to a fleet of units larger than the Delaware BART subject

units, the total emissions reductions achieved by Regulation 1146, greatly exceed that which

would be achieved through application of presumptive BART emissions rate limits on BART

subject units only.

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Table 7. Facility Emission Scenario for NO (tons)

Facility 2002 NO Mass 2012 Reg 1146 NO Presumptive BART NO

Edge Moor 3,307 1,464 3,570

Indian River 4,491 1,643 4,668McKee Run 345 120 345

Particulate Matter

Delaware required the BART facilities to conduct an analysis of potential BART control inaccordance with 40 CFR part 51.308 (e)(1)(ii). Each facility began by identifying all available

retrofit control technologies and then eliminating all technically infeasible options. For the two

EGUs that use oil as their primary fuel, Delaware considered wet electrostatic precipitators, dryelectrostatic precipitators, baghouses, and a switch to lower sulfur fuels and/or natural gas to be

technically feasible options. More detailed discuss of the BART analyses for each unit is

available in the SIP submittal.

All of Delaware’s BART sources used the California Puff Model (CALPUFF) to assess factor 5,the degree of visibility improvement that can be anticipated from installing various emission

controls for primary particulate matter. CALPUFF was promulgated by the USEPA on April 15,

2003 as a preferred dispersion model to assess long-range transport applications (i.e. transport

distances exceeding 50 km to approximately 300 km). Up to this distance, a non-steady-state

modeling approach which considers spatial and time variations in meteorological conditions,

such as CALPUFF, is appropriate. For this modeling demonstration, CALPUFF was used,

consistent with the approved BART version.

CALPUFF is a multi-layer, multi-species, non-steady state puff dispersion model which cansimulate the time and space varying meteorological conditions on pollutant transport,

transformation and removal. CALPUFF uses three dimensional meteorological fields developed

by the meteorological processing program CALMET.

CALPUFF contain algorithms for near source effects such as building downwash, traditional

plume rise, partial plume penetration, sub-grid scale terrain interactions, as well as long range

effects such as pollutant removal (dry and wet deposition), chemical transformation, vertical

wind shear, over-water transport, and coastal interaction effects.

The CALPUFF modeling performed for all of Delaware’s BART sources conforms to EPAmodeling guidance. A detailed description of the CALPUFF modeling can be found in

Appendix 8 ofthe Delaware Visibility SIP.

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emissions. The sulfur content of the No. 6 fuel oil is limited to no greater than 1.0 percent, which

restricts S02 and particulate matter emissions. The boiler exhausts through a stack 200 feet tall.The boiler produces steam to power a 102 MW electric generator.

Delaware reviewed the BART analysis performed by the City of Dover and established 0.5 %

sulfur as BART for PM since the residual fuel with a sulfur content of 0.5 percent is costeffective for purposes of improving visibility at Class I areas. No significant energy or non-air

quality environmental benefits or dis-benefits associated with using lower sulfur fuel wereidentified. 0.5% sulfur fuel will reduce PM emissions by approximately 50%. The remaining

useful life ofthe unit is expected to be greater than the life of the control options, no weight wasgiven to the remaining useful life parameter. Although there are small visibility incremental

benefits that could be reasonably anticipated as a result of installation of other control options

(<0.1 dv on the worst day impact), DNREC believes that the increased costs associated with

higher cost options are not justified by the minimal visibility improvement.

Edge Moor Unit 4 is a nominal 175 MW dry-bottom, pulverized coal (primary fuel),

tangentially-fired boiler equipped with low-NO coal burners (LNB) and overfire air (OFA) for

the control of NOx emissions and an electrostatic precipitator (ESP) for the control of filterable

particulate emissions. Unit 4 is currently permitted to burn coal with a sulfur content of up to

1.0%wt.

Delaware reviewed the BART analysis performed by the Connectiv for Unit 4 and determined

that addition of the dry sorbent injection system (DSI) is BART for PM since the addition of a

fabric filter was not cost- effective for purposes of improving visibility at Class I areas. Energy

or non-air quality environmental benefits or dis-benefits were not considered in ruling out any

control technology. The existing ESP is effective at reducing particulate matter emissions, and

the addition of the DSI system will reduce condensable emissions. The remaining useful life ofthe unit is expected to be greater than the life ofthe control options therefore, no weight was

given to the remaining useful life parameter. The incremental benefit in visibility that would

result from the installation of a fabric filter was small (comparable to 0.1 dv on the 8th highest

day impact).

Edge Moor Unit 5 is a nominal 445 MW residual oil-fired (primary fuel) boiler with oil LNB andOFA for the control of NOx emissions and a multicylone for the control of filterable particulates.

Unit 5 is currently permitted to bum oil with a sulfur content of up to 1.0% wt.

Delaware reviewed the BART analysis performed by Connectiv for Unit 5 and established 0.5

% sulfur as BART for PM since the residual fuel with a sulfur content of 0.5 percent is cost

effective for purposes of improving visibility at Class I areas. 0.5% sulfur would reduce PM

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The Department has reviewed NRG Indian River’s BART analysis and determined that existing

control for PM (i.e., ESP) is BART since additional PM control options for NRG Indian River,

were not cost-effective for purposes of improving visibility at Class I areas. The lowest costtechnology was shown to be $220,567,479 per change in dv. The existing ESP is effective at

reducing particulate matter emissions. There are no significant energy or non-air quality

environmental benefits or dis-benefits to be considered. The remaining useful life ofthe unit isexpected to be greater than the life ofthe control options, no weight was given to the remaining

useful life parameter. There are exceedingly small visibility incremental benefits that could bereasonably anticipated as a result of installation of the higher cost control options (<0.2 dv on the

worst day impact).

Table 8. Summary of BART Control Measures for PM

Facility and Unit Particulate Matter

NGR Indian River — Unit 3 Existing controls ESP

City of Dover, McKee Run — Unit 3 Low sulfur oilConectiv Edge Moor — Unit 4 Existing controls ESP and installation of DSI

Conectiv Edge Moor — Unit 5 Low sulfur oil

The technical analyses and modeling used in the Delaware SIP’s contribution assessment and

prediction of visibility impacts from BART controls comply with EPA modeling guidance and

recommendations. EPA finds the MANE-VU technical modeling analyses presented in the

Delaware Visibility SIP to be acceptable because the models that were used were applied

according to EPA modeling guidance.

Consultation with States and FLMsOn May 10, 2006, the MANE-VU State Air Directors adopted the Inter-RPO State/Tribal and

FLM Consultation Framework that documented the consultation process within the context of

regional phase planning, and was intended to create greater certainty and understanding amongRPOs. MANE-VU states held ten consultation meetings and/or conference calls from March 1,2007 through March 21, 2008. In addition to MANE-VU members attending these meetings and

conference calls participants from VISTAS, Midwest RPO and relevant Federal Land Managers

were also in attendance (at many ofthese meetings and conference calls).In addition to the conference calls and meeting the FLMs were given the opportunity to reviewand comment on each of the technical documents developed by MANE-VU and included as

appendices in Delaware’s SIP submittal.

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agreement with the proposed SIP. To

address the requirement for continuing consultation procedures with the FLMs under 40 CFR51 .308(i)(4), Delaware commits in the SIP to ongoing consultation with the FLMs on Regional

Haze issues throughout implementation.

Periodic SIP Revisions and Five-Year Progress Reports

Consistent with the requirements of 40 CFR 51308(g), Delaware has committed to submitting a

report on reasonable progress (in the form of a SIP revision) to the EPA every five years

following the initial submittal of its regional haze SIP. The reasonable progress report will

evaluate the progress made towards the RPGs for the Brigantine National Wildlife Refuge Class

I area, located in New Jersey.

Interstate Transport of VisibilityOn September 16, 2009, Delaware submitted revisions to their SIP to address the infrastructure

elements specified in the CAA section 110(a)(2), necessary to implement, maintain, and enforce the 1997

8-hour ozone and fine particulate matter (PM25)national ambient air quality standards (NAAQS) and the

2006 PM2.5NAAQS. Delaware indicated in these revisions that their Regional Haze SIP meets therequirements of CAA 11 0(a)(2)(D)(i)(II) regarding visibility for the 1997 8-hour ozone NAAQS

and the 1997 and 2006 PM2.5 National Ambient Air Quality Standards (NAAQS). It generallysets forth that “Delaware’s Regional Haze SIP assessed and demonstrated that Delaware has met

Best Available Retrofit Technology and Reasonable Further Progress goals, and thus did notinterfere with measures required to be included in the applicable implementation plan for anyother State to protect visibility.” Regarding 11 0(a)(2)(J), the 2006 infrastructure submittal states“Delaware’s plan.. .has met the applicable part C (relating to... visibility protection) in

Delaware’s Visibility SIP submitted to EPA “ Delaware’s infrastructure submittals andEPA’s 2009 guidance document on the 2006 PM2.5infrastructure submittals are contained in theelectronic Docket File EPA-R03-OAR-2010-0158 which is available at the website

www.regulations.gov.

Sections 1 10(a)(l) and 1 10(a)(2)(D)(i)(II) of the CAA require that, within three years of

promulgation of a NAAQS, a State must ensure that its State Implementation Plan, among otherrequirements, “contains adequate provisions. . . prohibiting. . . any source or other types of

emission activity within the State from emitting any air pollutant in amounts which will..interfere with measures required to be included in the applicable implementation plan for any

other State . . . to protect visibility.” Similarly, Section 1 10(a)(2)(J) requires that such SIP “meet

the applicable requirements of. . . part C of (Subchapter I) (relating to. . . visibility protection).”

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g 

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(

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) for the 8

Hour Ozone and PM25

National Ambient Air Quality Standards,” recognized the possibility that a state could potentially

meet the visibility portions ofsection 11 0(a)(2)(D)(i)(II) through its submission of a Regional

Haze SIP, as required by sections 169A and 169B ofthe CAA. In its 2009 guidance entitled

“Guidance on SIP Elements Required Under Sections ll0(a)(1) and (2) for the 2006 24-HourFine Particle (PM25 ) National Ambient Air Quality Standards (NAAQS),” EPA recommended

that a state could meet such visibility requirements through its regional haze SIP. EPA’s rational

supporting this recommendation was that the development ofthe regional haze SIPs was

intended to occur in a collaborative environment among the states, and that through this process

states would coordinate on emissions controls to protect visibility on an interstate basis.

The common understanding was that, as a result of this collaborative environment, each State

would take action to achieve the emissions reductions relied upon by other states in theirreasonable progress demonstrations under the RHR. This interpretation is consistent with therequirement in the RHR that a state participating in a regional plarming process must include “all

measures needed to achieve its apportionment of emission reduction obligations agreed upon

through that process.” 40 CFR 51.308(d)(3)(ii).

Through its involvement in MANE-VU, Delaware did in fact coordinate with other states on

emission controls to protect visibility on an interstate basis in the course of developing its

Regional Haze SIP. Section 9.13 of the Delaware’s Regional Haze SIP, explains the

consultation process which was followed by Delaware and its neighboring states. As a result of

such participation and its own evaluations in its Regional Haze SIP, Delaware’s Regional HazeSIP meets the obligations of 40 CFR 51.308(d)(3)(ii) and contains adequate provisions to prevent

interstate transport that would interfere with the measures required in other states to protectvisibility as required pursuant to CAA Sections 11 0(a)(2)(D)(i)(II) and 11 0(a)(2)(J).

C. EPA EVALUATION

This revision will reduce emissions of SO2,NO and PM25 from sources located throughout the

state of Delaware. Delaware has quantified it’s impact of visibility impairing pollutants at the

Brigantine Wildlife Refuge class I area and has included in its SIP enforceable emissionslimitations, compliance schedules, and all measures necessary to obtain its share of emissions

reductions needed to meet the RPGs of the Brigantine Wildlife Refuge class I area. Furthermore,the submittal at issue ensures that emissions from Delaware will not interfere with the reasonableprogress goals for neighboring states’ Class I areas.

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is recommended.

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