jACK A. MARK E LL

GovERNOR



### Mr. Shawn Garvin (3RAOO), STATE OF DELAW ARE

OFFICE OF THE GOVERNOR

TATNALL BUILDING, SECOND FLOOR

WILLIAM PENN STREET, DOVER, DE 19901



### November 21,2013

Regional Administrator, Region III

U.S. Environmental Protection Agency

1650 Arch Street

Philadelphia, PA, 19103-2029

Dear Mr. Garvin: 

### RECEIVED



# r

. r:c**~** 1 

# 7013**,,J ~(.** 

EPA, RCG;\}N 10

01T!C6 OF REGIONAL ADMINISTR/·,TOR



# 3 PI

- lONE: 302-7 44-4101

E\X: 302-739

- 2775



### On December 14, 2012 the U.S. Environmental Protection Agency (EPA) strengthened the

National Ambient Air Quality Standards (NAAQS) for fine particulate matter (PM

2

. 5 ) 

### by lowering

the annual primary standard from 15 micrograms per cubic meter (1-!g/m 3 ) 

### to12 11-g/m 3

. 

### Section

107 (d) of the Clean 

### Air Act (CAA) requires the Governor of each State to submit to the EPA a list

of all areas (or portions thereof) in the State, designating each as nonattainment, attainment, or

unclassifiable

. This letter fulfills Delaware's obligations under Section 107 (d) of the CAA.



### Area Description and Monitoring Data

Delaware is composed of three counties, namely New Casde, Kent and Sussex, laying from

north to south. The northern portion of New Casde County lies above the Chesapeake and

Delaware Canal, a waterway that connects the Chesapeake Bay with the Delaware Bay. This part of

New Cas de County is more metropolitan and industrialized than the remainder of Delaware. The

remainder of Delaware lies south of the Chesapeake and Delaware Canal, and comprises the

soud1ern portion of New Casde County, and all of Kent and Sussex Counties.

Delaware currendy monitors PM

2

. 5 

### at seven locations throughout the State. The design

values based upon 2010 through 2012 complete and certified monitoring data are 10.4 11-g/m 3

, 

### 9.0f-lg/m 3 

### and 8.9 11-g/m 3 

### for New Casde, Kent and Sussex County, respectively. This monitoring

data indicates that PM

2

. 5 

### concentrations in Delaware's air are well below the 12 11-g/m 3 

### NAAQS

throughout the State.



### Attainment/N onattainment Recommendation

Section 107 (d) of the CAA requires the EPA to designate an area "nonattainment" if it is

violating the NAAQS, or if it is contributing to a nearby area where a violation of the NAAQS

occurs. 

## RECEIVED



# DEC 1 7 2013

3AP30

### Mr. Shawn Garvin

November 21,2013

Page2 

## RECEIVED

## D~C 

# 11 2013

EPA,**f;.EG!G!~** !E

1

• • 1::01-**!t!~Giull!** .. L AD,vlfNISTR. cl I'C 

### Delaware has controlled every non-trivial source of PM

2

_ 5 

### and its precur or

, and all

- --- ·

Delaware emission sources are now well controlled. This is demonstrated by our emissions

inventory- between 2002 and 2012 Delaware implemented control strategies that reduced its overall

emissions of direct PM

2

_ 5 

### by 46%, and precursor's sulfur dioxide by 95%, nitrogen oxides by 47%,

volatile organic compounds by 42% and ammonia by 52%. Monitoring data conftrms the

effectiveness of these control strategies- in 2002 the PM

2

. 5 

### design value in New Casde County was

16.2 f.-lg/m 3

, 

### and the emission reductions between 2002 and 2012 have reduced the design value to

10.4 f.-lg/m 3

.



### Because PM

2

_ 5 

### concentrations throughout Delaware are well below the 2012 PM

2

_ 5 

### NAAQS,

and because every non-trivial source of PMz.

5 

### and its precursors are well controlled, emissions from

Delaware do not contribute to the nonattainment of the PM

2

_ 5 

### NAAQS in any area. Given this,

each of Delaware's three counties should be designated as attainment for the annual PM

2

_ 5 

### NAAQS.

Additional documentation and analysis to support a designation of attainment is provided in the

enclosed technical support document which address each of the ftve factors that the EPA has

suggested in guidance (i.e., air quality data, emissions and emissions-related data, meteorology,

geography/topography, and jurisdictional boundaries).

Thank you for your consideration of these recommendations. 

### If you have any questions

concerning this submittal or would like to discuss it further, please contact Mr. Ali Mirzakhalili,

Director of the Division of 

### Air Quality at (302) 739-9402.

Enclosure

cc: Collin P. 

### O'Mara, DNREC

Dave Small, DNREC

Ali Mirzakhalili, DNREC

Diana Esher, EPA, Region III Sincerely,

# 5~**f()~**

Jack 

### A. Markell

Governor

# State of Delaware

Department of Natural Resources and

Environmental Control

Division of Air Quality

Technical Support Document to Support a

Designation of Attainment of the 2012

Fine Particle (PM 2 .5 

# ) NAAQS

November 21 , 2013

### 2 Table of Contents

1 INTRODUCTION

................................ ................................ ................................ ................................ . 5

2 AIR QUALITY DATA IN THE REGION

................................ ................................ ............................ 6

2.1 Delaware PM 2.5 

### Monitoring Network and Data

................................ ................................ .............. 6

2.2 Delaware, Maryland, New Jersey and Pennsylvania Annual PM 2.5 

### Design Values

....................... 8

2.3 Philadelphia County Monitoring Data for the “LAB” (ID 421010004)

................................ ........ 10

2.4 Air Quality Rankings in the Philadelphia CBSA and Surrounding Counties (CBSA+)

............... 11

2.5 Philadelphia CBSA Trends, Seasonal and Wind Patterns

................................ ............................. 14

2.6 Speciation and “SANDWICH” Analysis

................................ ................................ ...................... 20

2.7 Chester Monitor (Delaware County, PA)

................................ ................................ ...................... 24

2.8 Summary of Air Quality Analysis

................................ ................................ ................................ . 25

3 METEOROLOGY (WEATHER/TRANSPORT PATTERNS)

................................ .......................... 27

3.1 General Comments

................................ ................................ ................................ ........................ 27

3.2 Trajectory Cluster Analysis

................................ ................................ ................................ ........... 27

3.3 Summary of Trajectory Cluster Analysis

................................ ................................ ...................... 33

4 EMISSIONS AND EMISSIONS

- RELATED DATA

................................ ................................ ......... 34

4.1 2011 EPA National Emissions Inventory

................................ ................................ ...................... 34

4.2 Emissions Related Data

................................ ................................ ................................ ................. 35

4.2.1 Population

................................ ................................ ................................ .............................. 35

4.2.2 Expected growth

................................ ................................ ................................ ..................... 39

4.2.3 Traffic and commuting patterns

................................ ................................ ............................. 40

4.2.4 Vehicle Miles Traveled

................................ ................................ ................................ .......... 41

4.3 Emission Reductions

................................ ................................ ................................ ..................... 42

4.3.1 General Discussion

................................ ................................ ................................ ................. 42

4.3.2 Delaware’s 2012 Point Source Reductions Since 2002

................................ ......................... 43

4.3.3 CBSA Emission Reductions between 2002 and 2011

................................ ........................... 43

4.3.4 Philadelphia CBSA and CBSA+ 2002 and 2011 Emissions and Reductions

........................ 47

4.4 Control Measure Analysis for PM 2 .5



### - Related Pollutants

................................ ............................... 50

4.4.1 Sulfur Dioxide (SO 2 

### )

................................ ................................ ................................ .............. 50

4.4.2 Oxides of Nitrogen (NOx)

................................ ................................ ................................ ..... 51

4. 4.3 Direct PM 2.5



### ................................ ................................ ................................ ............................ 52

4.4.4 Volatile Organic Compounds (VOC)

................................ ................................ .................... 52

4.4.5 Ammonia (NH 3 

### )

................................ ................................ ................................ ..................... 52

4.5 Summary of Emissions and Control Measure Analysis

................................ ................................ 53

5 GEOGRAPHY/TOPOGRAPHY

................................ ................................ ................................ ......... 53

6 JURISDICTIONAL BOUNDARIES

................................ ................................ ................................ .. 53

7 CO NCLUSIONS

................................ ................................ ................................ ................................ .. 54

### 3 List of Figures

Figure 2.1: Delaware PM 2.5 

### Air Monitoring Locations

................................ ................................ ................ 7

Figure 2.2: CBSA+ Violating Counties and Color

- Coded Design Values per County

............................... 10

Figure 2.3: Philadelphia County 2010

- 2012 PM 2.5 

### annual averages

................................ .......................... 11

Figure 2.4: Trends in annual average design values

................................ ................................ ................... 14

Figure 2.5: Average DV Trends for New Castle, Chester and Delaware Counties

................................ .... 15

Figure 2.6: MLK, Chester and New Garden Cool vs. Warm Season

................................ ......................... 16

Figure 2.7: MLK, Chester and New Garden No. of High Days

................................ ................................ .. 16

Figure 2.8: MLK/Chester High Concentration Days

................................ ................................ .................. 17

Figure 2.9: MLK/Chester High Day Difference

................................ ................................ ......................... 18

Figure 2.10: Chester PM 2.5 

### Concentrations by Wind Direction (WD) Radar Plot

................................ ..... 19

Figure 2.11: Chester PM 2.5 

### Concentrations by Wind Direction Bar Chart

................................ ................. 19

Figure 2.12: MLK PM 2.5 

### Concentrations by Wind Direction (WD) Radar Plot

................................ ......... 19

Figure 2.13: MLK PM 2.5 

### Concentrations by Wind Direction (WD) Bar Chart

................................ .......... 20

Figure 2.14: Brigantine Speciated SANDWICH

................................ ................................ ........................ 21

Figure 2.15: MLK Speciated SANDWICH

................................ ................................ ................................ 21

Figure 2.16: Chester Speciated SANDWICH

................................ ................................ ............................. 22

Figure 2.17: MLK and Chester vs. Brigantine Urban Excess

................................ ................................ ..... 23

Figure 2.18: MLK non

- SANDWICH data

................................ ................................ ................................ .. 23

Figure 2.19: 2011 Points Source Emissions vs. Distance from Chester Monitor

................................ ....... 24

Figure 3.1: 24

- hour HYSPLIT back trajectories originated at 2:00 pm from MLK DE (top) and Chester

PA (bottom) monitors for 2010

- 2012 colored by PM 2.5 

### concentra tion (μg/m 3 

### )

................................ .......... 28

Figure 3.2: Six clusters to b ack trajectories at MLK DE (top) and Chester PA (bottom) monitors for

2010

- 2012 showin g the mean trajectory for each cluster

................................ ................................ ............ 29

Figure 3.3: Variation of PM 2.5 

### by month and hour of the day by wind direction cluster at MLK DE (top)

and Chester PA (bottom) monitors for 2010

................................ ................................ ................................ 31

Figure 3.4: Variation of PM 2.5 

### by month and hour of the day by wind direc tion cluster at MLK DE (top)

and Chester PA (bottom) monitors for 2011

................................ ................................ ................................ 32

Figure 3.5: Variation of PM 2.5 

### by month and hour of the d ay by wind direction cluster at MLK DE (top)

and Chester PA (bottom) monitors for 2012

................................ ................................ ................................ 33

Figure 4.1: NCC 3

- year Rolling DVs vs. NC C Population (over 10 years)

................................ ............... 38

Figure 4.2: Philadelphia CBSA 2002

- 2011 Reductions and Rankings

................................ ...................... 45

Figure 4.3: Philadelphia CBSA 2002

- 2011 Percent Reductions

................................ ................................ 46

### 4 List of Tables

Table 2.1: Delaware PM 2.5 

### Annual Mean Concentrations; NAAQS = 12 μg/m 3



### , 3

- year average

.............. 8

Table 2.2: 2010

- 2012 DV for the Philadelphia CBSA+

................................ ................................ ............... 8

Table 2.3: Philadelphia CBSA Monitors: annual PM 2.5 

### mean and 2010

- 2012 DVs

................................ .. 12

Table 2.4: Philadelphia 2010

- 2012 DVs (Spatial Averaging)

................................ ................................ .... 12

Table 2.5: New Castle and Adjacent Counties’ 2010

- 2012 Design Values (ranked low

- to

- high)

............. 13

Table 2.6: 2009 Speciated SANDWICH Data

................................ ................................ ............................ 20

Table 2.7: MLK and Chester vs. Brigantine Urban Excess

................................ ................................ ........ 22

Table 3.1: Numbers of Each Cluster by Monitor

................................ ................................ ........................ 30

Table 4.1: 2011 NEI Philadelphia CBSA+

................................ ................................ ................................ . 34

Table 4.2: 2011 NEI Philadelphia CBSA

................................ ................................ ................................ ... 35

Table 4.3: 2000

- 2010 Population Statistics

- Philadelphia CBSA+

................................ ........................... 36

Table 4.4: Top 25 CBSA

- Attainment Status (2009

- 2011 DVs)

................................ ............................... 37

Table 4.5: 2010

- 2035 Population, Gr owth and Rankings

– Philadelphia CBSA+

................................ ..... 39

Table 4.6: CBSA+ Commuting Patterns

................................ ................................ ................................ ..... 40

Table 4.7: CBSA+ 2002

- 2010 Vehicle Miles Traveled and Rankings

................................ ....................... 41

Table 4.8: New Castle County

- Top Point Source Emitters in 2002 and 2012

................................ ......... 43

Table 4.9: Philadelph ia CBSA 2002 Emissions and Rank

................................ ................................ ......... 44

Table 4.10: Philadelphia CBSA 2011 Emissions and Rank

................................ ................................ ....... 44

Table 4.11: Philadelphia CBSA 2002

- 2011 Reductions and Rankings

................................ ...................... 45

Table 4.12: Philadelphia CBSA 2002

- 2011 Percent Reductions

................................ ................................ 46

Table 4.13: Philadelphia CBSA+ 2002 Emissions and Total Rank

................................ ............................ 47

Table 4.14: Philadelphia CBSA+ 2011 E missions and Rankings

................................ .............................. 48

Table 4.15: Philadelphia CBSA+ 2002

- 2011 Emission Reductions and Rankings

................................ .... 49

Table 4.16: Philadelphia CBSA+ 2002

- 2011 Percent Reductions and Rankings

................................ ....... 49

### 5 1 INTRODUCTION

On December 14, 2012 the U.S. Environmental Protection Agency (EPA) strengthened the National

Ambient Air Quality Standards (NAAQS) for fine particulate matter (PM 2.5 

### ) by lowering the annual

primary standard from 15 micrograms per cubic meter (μg/m 3 

### ) to 12 μg/m 3



### . Section 107(d) of the Clean

Air Act (CAA) requires “... not later than 1 year after promulgation of a new or revised national ambient

air quality standard ... the Governor of each State shall ... submit to the Administrator a list of all areas

(or portions thereof) in the State, designating as

— (i) nonattainment, any area that does not meet (or that

contributes to ambient air quality in a nearby area that does not me et) the national primary or secondary

ambient air quality standard for the pollutant...”

The CAA uses the nonattainment designation to establish the area where CAA control requirements are

applied. Both areas that do not meet a NAAQS , and areas that contri bute to air quality in a nearby area

that does not meet a NAAQS are required to apply the CAA control requirements. The CAA clearly and

completely sets a path that leads to attainment

-- requiring controls, in both the area with bad air quality

and the ne arby areas that are causing the bad air quality, will lead to clean air; while controlling only one

area but not the other may not.

Regarding air quality in Delaware, Delaware currently monitors PM 2.5 

### at seven locations throughout the

State. The design values based upon 2010 through 2012 complete and certified monitoring data are 10.4

μg/m 3 

### , 9.0 μg/m 3 

### and 8.9 μg/m 3 

### for New Castle, Kent and Sussex County, respectively. This monitoring

data indicates t hat PM 2.5 

### concentrations in Delaware’s air are well below the 12 μg/m 3 

### NAAQS

throughout the State.

Regarding Delaware’s contribution to air quality in any nearby area, the word “contributes” in context of

CAA 107 does not necessarily mean “any contribut ion,” but rather a degree of contribution sufficient to

deem an area nonattainment. Given that the purpose of a nonattainment designation is to establish the

area where the CAA control requirements are to be applied, it is reasonable to conclude that an a rea

contributes if the application of CAA control requirements in that area would result in emission

reductions that will help the nearby area meet a NAAQS. Conversely, if the application of CAA control

requirements will not result in emission reductions in the area, then that area does not contribute to the air

quality and would not be designated nonattainment.

This document presents Delaware data and analysis relevant to five factors EPA outlin es in their April

2013 guidance 1 

### which they believe are appr opriate to consider when making nonattainment boundary

recommendations (i.e., air quality data, emissions and emissions

- related data, meteorology,

geography/topography, and jurisdictional boundaries). This technical analysis focuses on the

Philadelphia

- Ca mden

- Wilmington, PA

- NJ

- DE

- MD Combined Statistical Area (CBSA) area and a ring of

counties surrounding that area (hereafter referred to as the “CBSA+”). The data and analysis in this

document indicate that Delaware does contribute a small amount to air qua lity in nearby areas that do not

meet the PM 2.5 

### NAAQS, and that 1) the air quality in those areas is impacted by a different set of sources,

and is otherwise different than the air quality in Delaware, and 2) Delaware PM 2.5 

### and PM 2.5 

### precursor

emission sou rces are currently well controlled, and the application of CAA control requirements in

Delaware would result in no additional emission reductions. Delaware concludes based on this data and

analysis that Delaware emissions do not contribute a sufficient am ount to any area to deem any part of

Delaware nonattainment for PM 2.5



### .

1 “Designations for the Fine Particle National Ambient Air Quality Standards,” April 2013

### 6 2 AIR QUALITY DATA IN THE REGION

EPA recommends that states consider the air quality in areas included versus excluded from the

nonattainment area as one of the factors in determining appropriate nonattainment area boundaries. Given

that monitoring data indicates all areas of Delaware are attaining the PM 2.5 

### standard, this analysis focuses

on how the air quality in Delaware compares to the air quality in any nearby area that the EPA m ay

associate with Delaware. In this Section Delaware evaluates the air quality within the Philadelphia CBSA

and CBSA+ , and demonstrates that the New Castle County attainment area is separate and distinct from

any nonattainment problems in the CBSA.

2.1 Delaware PM 2.5 

### Monitor ing Network and Data

D elaware began official PM 2.5 

### monitoring in 1999. Delaware’s PM 2.5 

### network consists of seven (7)

monitoring sites. There are four (4) sites in New Castle County, two (2) in Kent County and one (1) in

Sussex Cou nty.

The primary goal of the PM 2.5 

### monitoring network in Delaware is to determine the status of the ambient

air with respect to the 24

- hour and annual average PM 2.5 

### NAAQS. In accordance with federal regulations,

s tate agencies must operate at least the minimum number of required PM 2.5 

### sites listed in 40 CFR Part 58

Appendix D Table D

- 5. These required monitoring stations or sites must be sited to represent

community

- wide air quality. In addition, the following specific criteria also apply:

(1) At least o ne monitoring station is to be sited in a population

- oriented area of expected maximum

concentration.

(2) For areas with more than one required station, a monitoring station is to be sited in an area of poor

air quality.

(3) Each State shall install and operate at least one PM 2.5 

### site to monitor for regional background and

at least one PM 2.5 

### site to monitor regional transport.

Figure 2.1 shows the locations of Delaware’s PM 2.5 

### monitors. All data from these monitors are measured

using EPA approved federal reference methods (FRM). All PM 2.5 

### monitoring sites are located

appropriately and are eligible for comparison to the annual and daily PM 2.5 

### NAAQS. The standard

monitoring schedule is one in three days

, with one site , Martin Luther King (MLK) in Wilmington,

monitoring every day. MLK is also designated a collocated site, with the collocated monitor designated

as MLK

- b operating on a one in six day schedule. A ll data are submitted to EPA’s Air Quality System

(AQS) in a timely manner in ac cordance with the schedule prescribed by EPA.

Chemical speciation is encouraged at sites where the chemically resolved data would be useful in

developing SIPs and supporting atmospheric or health effects related studies. Chemical speciation is

conducted at MLK in Wilmi ngton and Dover in Kent County. The PM 2.5 

### chemical speciation sites

include analysis for elements, selected anions and cations, and carbon.

### 7 F igure 2

. 1 : Delaware PM 2.5 

### Air Monitoring Lo cations

Delaware’s original PM 2.5 

### monitoring network design and monitor siting were completed in accordance

with EPA requirements and guidance as stated in 40 CFR Part 58 Appendices D and E, and the EPA

Office of Air Quality Planning & Standards (OAQPS) document “ Guidance for Network Design and

Optimum Site Exposure for PM 2.5 

### and PM 10 

### ” ( EPA 1997a). Final network documents were submitted to

EPA Region 3 in June 1998, and EPA approved Delaware’s PM 2.5 

### monitoring network.

Delaware Annu al Ambient Air Monitoring Network Reviews , including PM 2.5 

### , have been completed each

year in accordance with 40 CFR Part 58 Appendix D and subsequently submitted to EPA Region 3 for

approval.

In fulfillment of the federal CAA 103 g rant r equirements, Delaw are submits annual Delaware Data

Quality Assessments for PM 2.5 

### speciation data and PM 2.5 

### FRM data t o EPA Region 3. All data complies

with appropriate federal and state requirements, including 40 CFR Part 50 Appendices L and N, and 40

CFR Part 58 Appendix A.

In fulfillment of the federal CAA 103 g rant r equirements, Delaware also submits annual PM 2.5 

### Speciation

Monitoring Network Review and Monitoring Strategy reports to EPA Region 3. The PM 2.5 

### speciation

network design and monitor siting follows EPA requi rements and guidance as stated in 40 CFR Part 58

Appendices D and E, and the documents “ Guidance for Network Design and Optimum Site Exposure for

PM 2.5 

### and PM 10 

### " ( EPA 1997a), “ Particulate Matter (PM 2.5 

### ) Speciation Guidance ” ( EPA 1999), and

“ Guideline on S peciated Particulate Monitoring ” ( EPA 1999a).

Delaware has quality assured all data in accordance with 40 CFR 58.10 an d all other federal requirements.

Delaware has recorded the data in the AQS database and, therefore, the data are available to the publ ic

.

### 8 The Delaware

- monitored annual mean PM 2.5 

### concentrations and site information for 2010

- 2012 are

provided in Table 2

. 1 , and show that all sites are monitoring PM 2.5 

### concentrations that are well below the

2012 PM 2.5 

### NAAQS

.



### Table 2

. 1 : Delaware PM 2.5 

### Annual Mean Concentrations; NAAQS = 12 μg/m 3



### , 3

-

year average

County Site Name and ID Number 2010 2011 2012 3

- year Average

New Castle Bellefonte 10

- 003

- 1003 10.2 9.4 9.3 9.6

MLK 10

- 003

- 2004 10.6 10.3 10.3 10.4

Newark 10

- 003

- 1012 10.4 10.4 9.4 10.1

Lums Pond 10

- 003

- 1007 10. 0 8.8 8.5 9.1

Kent Dover 10

- 001

- 0003 9.7 9.1 8.1 9.0

Killens Pond 10

- 001

- 0002 9.3 8.6 8.1 8.7

Sussex Seaford 10

- 005

- 1002 9.9 8.7 8.2 8.9

2.2 Delaware, Maryland, New Jersey an d Pennsylvania Annual PM 2.5 

### D esign Values

Table 2

. 2 shows the 2010

- 2012 annual PM 2.5 

### design values (DV) and rankings for counties within the

CBSA+

.

Table 2

. 2 : 2010

- 2012 DV for the Philadelphia CBSA +

State County ** CBSA Site 2010

- 2012

Annual

DV

(μg/m3) Rank

PA Philadelphia Philadelphia

- Camden

Wilmington, PA

- NJ

- DE

- MD 421010004 13.5 NA 1.

PA Northampton Allentown

- Bethlehem

- Easton,

PA

- NJ 420950025 13.2 1

PA Delaware Philadelphia

- Camden

Wilmington, PA

- NJ

- DE

- MD 420450002 13.1 2

PA Chester Philadelphia

- Camden

Wilmington, PA

- NJ

- DE

- MD 420290100 12.3 3

PA Lancaster Lancaster, PA 420710007 12.1 4

PA York York

- Hanover, PA 421330008 11.7 5

PA Philadelphia Philadelphia

- Camden

Wilmington, PA

- NJ

- DE

- MD 421010055 11.0 6

PA Berks Reading, PA 420110011 10.9 7

PA Bucks Philadelphia

- Camden

Wilmington, PA

- NJ

- DE

- MD 420170012 10.9 8

PA Philadelphia Philadelphia

- Camden

Wilmington, PA

- NJ

- DE

- MD 421010047 10.9 8

PA Philadelphia Philadelphia

- Camden

Wilmington, PA

- NJ

- DE

- MD 421010057 10.8 9

### 9 State County ** CBSA Site 2010

- 2012

Annual

DV

(μg/m3) Rank

MD Cecil Philadelphia

- Camden

Wilmington, PA

- NJ

- DE

- MD 240150003 10.4 10

DE New Castle Philadelphia

- Camden

Wilmington, PA

- NJ

- DE

- MD 100032004 10.4 10

MD Kent Not Applicable 240290002 10.3 11

DE New Castle Philadelphia

- Camden

Wilmington, PA

- NJ

- DE

- MD 100031012 10.1 12

PA Montgomery Philadelphia

- Camden

Wilmington, PA

- NJ

- DE

- MD 420910013 9.8 13

NJ Camden Philadelphia

- Camden

Wilmington, PA

- NJ

- DE

- MD 340070002 9.7 14

DE New Castle Philadelphia

- Camden

Wilmington, PA

- NJ

- DE

- MD 100031003 9.6 15

PA Philadelphia Philadelphia

- Camden

Wilmington, PA

- NJ

- DE

- MD 421010024 9.6 15

PA Philadelphia Philadelphia

- Camden

Wilmington, PA

- NJ

- DE

- MD 421011002 9.6 15

NJ Camden Philadelphia

- Camden

Wilmington, PA

- NJ

- DE

- MD 340071007 9.5 16

NJ Mercer Trenton, NJ 340210008 9.5 17

NJ Warren Allentown

- Bethlehem

- Easton,

PA

- NJ 340410006 9.4 18

NJ Gloucester Philadelphia

- Camden

Wilmington, PA

- NJ

- DE

- MD 340150004 9.3 19

DE New Castle Philadelphia

- Camden

Wilmington, PA

- NJ

- DE

- MD 100031007 9.1 20

DE Kent Dover, DE 100010003 9.0 21

NJ Atlantic Atlantic City

- Hammonton, NJ 340011006 8.9 22

DE Kent Felton , DE 100010002 8.7 23

NJ Warren Allentown

- Bethlehem

- Easton,

PA

- NJ 340410007 8.6 24

NJ Ocean New York

- Newark

- Jersey City,

NY

- NJ

- PA 340292002 8.5 25

NJ Atlantic Atlantic City

- Hammonton, NJ 340010006 8.2 26

NJ Mercer Trenton, NJ 340218001 8.2 26

NJ Middlesex New York

- Newark

- Jersey City,

NY

- NJ

- PA 340230006 8.0 27

* * Counties with in the Philadelphia CBSA are in bold font

NA = Not applicable

1. Philadelphia monitor ID 421010024 (LAB) is only included in this table for completeness (i.e., to show all monitors in the

CBSA+ )

. Delaware agrees with the City of Philadelphia that this monitor is not appropriate for comparison to the 2012 PM 2.5 NAAQS designations, for reasons discussed in S ection 2.3.



### As can be seen in Table 2.2, four counties in the CBSA+, all in Pennsylvania, have 2010

- 2012 DV’s that

exceed the NAAQS, and design values outside of these four counties are well in compliance with the

NAAQS. The highest monitor in Delaware’s New Castle County (i.e., the MLK monitor in downtown

Wilmington) ranks 1 0 th 

### out of the 33 monitors i n the CBSA+ (tied with the rural Cecil County, MD

### 10 monitor ) , and the lowest monitor in New Castle County ranks 2 0 th 

### . Th ese data indicate that the air quality

in the CBSA+ is well below the NAAQS except for the four, non

- contiguous Pennsylvania counties.

Figure 2.2 illustrates the color

- coded DVs in one μg/m3 increments using 2010

- 2012 PM 2.5 

### data for each

county in the CBSA+

. 2 

### The map also shows the violating monitors/DVs in southeast PA

, and also

demonstrates the relatively low DVs for those counties encircling the violating monitors.

Figure 2

. 2 : CBSA+ Violating Counties and Color

- Coded Design Values per County

2.3 Philadelphia County Monitoring Data for the “LAB” (ID 421010004)

In accordance with the PM 2.5 

### NAAQS rule published on January 15 th 

### , 2013 (78 FR 3086), and specific to

the provisions detailed in §58.10 (b)(13) and §58.11(e), the City of Philadelphia Air Management

Services (AMS) requested EPA not use the Federal Equivalent Method (FEM) data from the “LAB” (ID

2 See map legend for description of the incremental maximum (Max) DV.

### 11 421010004) for NAAQS desi gnation purposes for the years 2011

– 2013, Quarter 1. 3 

### I n 2011 this

monitor was switched from Federal Reference Method (FRM) to FEM. Delaware agrees with

Philadelphia’s rationale for this request. Figure 2

. 3 provides annual means for 2010, 2011 and 2012 and

demonstrates how the other Philadelphia county monitors are tren ding downward , while the LAB’s PM 2.5 

### values show an unusually sharp rise beginning in 2011 with t he installation of the FEM monitor

. 4 

### Th e

LAB FEM monitor annual mean is ≥ 60% higher than the other monitors in the same county.

Figure 2

. 3 : Philadelphia County 2010

- 2012 PM 2.5 

### annual averages

Delaware does not consider the Philadelphia LAB station to be reflective of the PM 2.5 

### NAAQS regional

contributions , and does not consider it suitable for comparison to the NAAQS. Delaware will not include

this monitor further in this document

.

2.4 Air Qual ity Rankings in the Philadelphia CBSA and Surrounding Counties (CBSA+)

Table 2

. 3 shows the 2010

- 2012 monitoring data for all of the monitors in the Philadelphia CBSA

.

3 40 CFR Part 58.11(e) documents the process for excluding PM 2.5 FEM data from comparis on to the NAAQS and/or AQI if

the performance criteria described in Table C

- 4 of Subpart C are not met when assessed with a collocated FRM monitor. In

their 2013

- 2014 Air Monitoring Network Plan , the City of Philadelphia AMS requested PM 2.5 FEM data from 2011 through the

first quarter of 2013 at the LAB monitoring site (AQS ID 421010004) be excluded from comparison to the NAAQS and A ir

Q uality I ndex

. The request to exclude data and the assessment generated to determine FEM incomparability t o a collocat ed

Federal Reference Method is located in Appendix B of their report located at:

http://www.phila.gov/health/pdfs/2013_14AMNPFinalwAppendices__20130628. pdf

4 421010024 was shutdown in 2011 and 421011002 begin operations in 2011. 8.0 9.0 10.0 11.0 12.0 13.0 14.0 15.0 16.0 17.0μg/m3

Philadelphia Monitor ID 2010

2011

2012

### 12 Table 2

. 3 : Philadelphia CBSA Monitors: annual PM 2.5 

### mean and 2010

- 2012 DVs

State County Site ID 2010 2011 2012 2010

-

2012 DV Rank

PA Delaware 420450002 13.5 12.9 12.8 13.1 1

PA Chester 420290100 13.8 13.3 9.8 12.3 2

PA Philadelphia 421010055 11.3 11.4 10.3 11 .0 3

PA Bucks 420170012 10.5 11.5 10.7 10.9 4

PA Philadelphia 421010047 10.9 11.3 10.2 10.8 5

PA Philadelphia 421010057 10.9 11.4 10.1 10.8 6

MD Cecil 240150003 11 10.9 9.3 10.4 7

DE New Castle 100032004 10.6 10.3 10.3 10.4 7

DE New Castle 100031012 10.4 10.4 9.4 10.1 8

PA Montgomery 420910013 9.5 10.3 9.7 9.8 9

NJ Camden 340070002 * * 9.7 9.7 10

PA Philadelphia 421011002 * 9 10.3 9.7 1 0

DE New Castle 100031003 10.2 9.4 9.3 9.6 1 1

PA Philadelphia 421010024 9.6 * * 9.6 1 1

NJ Camden 340071007 9.5 10.1 9 9.5 1 2

NJ Gloucester 340150004 9.1 9.4 9.4 9.3 1 3

DE New Castle 100031007 10 8.8 8.5 9.1 14



### Table 2.3 shows that the air quality in two Pennsylvania CBSA counties exceed the NAAQS, and that the

air quality in New Castle County is significantly better. The air quality in New Castle County ranks 7 th



### (tied with Cecil County, MD) at its worst monitor, and has the best air quality in the entire CBSA at its

lowest monitor. 5



### I n order to better illustrate county

- wide air quality Delaware incorporated spatial averaging for those

Philadelp hia CBSA counties that have more than one monitor ing site

. Table 2

. 4 presents the resultant

DVs.

Table 2

. 4 : Philadelphia 2010

- 2012 DVs ( Spatial Averaging )

State County Site ID 2010

- 2012 AVG

. Rank

PA Delaware 420450002 13.1 1

PA Chester 420290100 12.3 2

PA Bucks 420170012 10.9 3

MD Cecil 240150003 10.4 4

PA Philadelphia AVERAGE 10.4 5

PA Montgomery 420910013 9.8 6

DE New Castle AVERAGE 9.8 6

NJ Camden AVERAGE 9.6 7

NJ Gloucester 340150004 9.3 8

5 Note that New Castle County ranked 2 nd highest DV in the Philadelphia CBSA under the previous 1997 annual NAAQS

, which shows that Delaware’s PM 2.5 control strategies have been effective. This is discussed in detail in Section 4.4 of this

document.

### 13 Note that only two counties in Pennsylvania exceed the NAAQS, and that the air quality in the other

CBSA counties is significantly cleaner. Of the 8 CBSA counties New Castle County is tied at 6 th 

### place

with Montgomery County at 9.8 μg/m 3



### . 6



### Relative to New Castle County, Delaware t here are five CBSA counties in four states which encircle and

are adjacent to New Castle County , Delaware

. The 2010

- 2012 DVs f or each of these counties , and the

percentage the DV is above or below the NAAQS, is shown in Table 2

. 5

.

Table 2

. 5 : New Castle and Adjacent Counties’ 2010

- 2012 Design Values ( ranked low

- to

- high)

County/State Site Name and ID Number 2010

- 2012

Design Value Percent

Below/Above NAAQS

Gloucester, NJ Gibbstown Municipal Bldg.

34

- 015

- 5001 9.7

- 19%

New Castle, DE MLK (highest of 4 monitors in New

Castle County)

,

10

- 003

- 2004 10.4

- 13%

Cecil, MD Fair Hill

24

- 015

- 0003 10.4

- 13%

Philadelphia, PA RIT (24 th 

### and Ratner)

42

- 101

- 0055 11.0

- 8%

Chester, PA New Garden Airport

42

- 029

- 0100 12.3 +2 %

Delaware, PA Front St & Norris St

42

- 045

- 0002 13.1 +8 %

Table 2

. 5 shows there are two violations of the 2012 PM 2.5 

### NAAQS which are occurring solely in the

Pennsylvania Counties (assuming EPA will exclude the Philadelphia “ LAB ” for designation purposes).

Based on the data in Table 2

. 4 and Table 2

. 5 it is evident that; 1 ) Delaware county is significant ly above

the NAAQS, 2) Chester county is slightly above the NAAQS, 3) New Castle County is s ignificantly

below the NAAQS, and 4) New Castle County’s highest DV (of 4 monitors) is 21% lower than the

Chester monitor DV

.

6 Note t hat the average of New Castle County’s four monitors is below that of Cecil County MD

, which EPA excluded from

the Philadelphia based non

- attainment boundaries under the 1997 and 2006 PM 2.5 NAAQS due to low DVs , and because it was

not as “ industrialized ” as the rest of the CBSA. Delaware believes this low New Castle County averaged DV is a direct result

of Delaware’s control strat egies implemented under the l ast two rounds of PM 2.5 standards.

### 14 2.5 Philadelphia CBSA Trends, Seasonal and Wind Patterns

Air quality in the Philadelphia CBSA has shown significant improvement in relation to PM 2.5



### concentrations. Trends in annual average design values are shown in Figure 2

. 4 , which for clarity

includes only those sites in the CBSA with data through 2012. The dashed line indicates the PM 2.5 

### national ambient air quality standard for the annual average. Only two sites in New Castle County (the

highest concentration site at MLK in downtown Wilmington and the Bellefonte site located between

MLK and the Delaware County

, PA monitoring site in Chester) are shown.

Figure 2

. 4 : Trends in annual average design values

Figure 2

. 4 demonstrates the continued improvement in air quality as shown by the decreasing trends in

annual average desig n values. It should be noted that in the 2007

– 2009 time frame two sites began to

show somewhat different trends

– New Garden in Chester County PA and Chester in Delaware County PA

which are the only two sites in the CBSA that are currently monitoring non attainment for the 2012

NAAQS . The New Garden site changed methods from FRM to FEM in 2009 , which has a possible high

bias in comparison to the FRM. Acco rding to data submitted to EPA AQS, the FRM resu med sampling at

New Garden in 2012 , and there was a c orresponding drop in design value (see Table 2

. 3 , Site ID

420290100 ); which is more in line with other regional sites. It is likely that considering the past trend

w hen the FRM monitor was in use at this site, in the future when additional years of data from the FRM

monitor are incorporated we will see that PM 2.5 

### concentrations do actually trend with the other CBSA

sites, and that the design value at New Garden will be below the annual NAAQS.

The Chester site in Delaware County PA showed a slower rate of improvement beginning in 2007

- 2009,

and slight ly increase d in annual average design value concentrations in the most recent three year period

(201 0

- 2012). As trends in other regional monitors indicate, as regional PM 2.5 

### ambient concentrations and

transport levels continue to improve, nearby local sources may become relatively more significant . It is 8.0 9.0 10.0 11.0 12.0 13.0 14.0 15.0 16.0 17.0 

# Phila. Area Design Values Fair Hill MD

Bellefonte DE

MLK DE

New Garden PA

Chester PA

Bristol PA

Lycoming PA*

Norristown PA

S. Broad PA

Ritner PA

Sp. Grdn PA

Camden NJ

Gloucester NJ

### 15 likely that local sources have a significant inf luence on the Chester PA monitor and that local sources are

the reason the Chester PA monitor does not follow the trend of the other CBSA monitors . The siting of

the Chester monitor is discussed in detail in section 2.7 of this document

.

Figure 2

. 5 shows annual average design value trends for PM 2.5 

### sites in New Castle County D E along with

the New Garden and Chester monitors in the adjoining PA counties (Chester and Delaware Counties,

respectively). The same trends discussed above are more clearly seen in this chart with the PA monitors

showing clear differences compared to the New Castle County DE monitors.

Figure 2

. 5 : Average DV Trends for New Castle, Chester a nd Delaware Counties

To further examine similarities and differences in the PM 2.5 

### concentrations and trends among the sites, the

highest concentration monitoring site in New Castle County (MLK in Wilmington) DE was compared to

the New Garden PA (Chester County) and Chester PA (Delaware County) monitoring sites. Following

EPA guidance as contained in the April 13, 2013 PM 2.5 

### Designation Guidance Memo to EPA Regional

Administrators, high concentration days were identified and assessed for each monitoring site by

occurrences in warm or cool season as well as by month.

For each site, the 95 th 

### percentile was calculated for the three year period of 2010

- 2012 as per EPA

guidance, and high concentration days were defined as exceeding that concentration. Cool and warm

seasons were defined as per EPA guidance as cool season equal to October thr ough December and

January through April, and warm season as May through September for each calendar year.

Figure 2

. 6 shows that both MLK in DE and Chester in PA have more high concentration days in the cool

season while New Garden has more high concentration days in the warm season. 8.0 9.0 10.0 11.0 12.0 13.0 14.0 15.0 16.0 17.0ug/m3 

# Annual Standard Design Value Trends

New Garden. PA Chester, PA MLK, DE

Bellefonte, DE Newark, DE Lums Pond, DE

### 16 Figure 2

. 6 : MLK, Chester and New Garden Cool vs. Warm Season

Further breakdown of high concentration days by month in Figure 2

. 7 confi rms this pattern.

Figure 2

. 7 : MLK, Chester and New Garden No. of High Days 0 5 10 15 20 25 30 35

Cool Warm 

# Number high days by cool or warm season

2010

- 2012

MLK Chester New Garden

0 2 4 6 8 10 12 14

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 

# Number high days per month 2010

- 2012

MLK Chester New Garden

### 17 In the warm season, sulfates dominate the composition of PM 2.5 

### and are generally an indication of

regional transport; high concentrations in the cool season are dominated by shorter range components and

are generally more indicative of local source impacts. More information on PM 2.5 

### composition is

presented in secti on 2.6

.

The seasonal breakdown and design value trends indicate that the New Garden monitor in Chester

County, PA is not representative of PM 2.5 

### concentrations or trends in the New Castle County , DE or

Delaware County, PA areas. Since the ambient data from the New Garden site is only slightly above the

annual average NAAQS and shows decreasing concentrations, and given the likely problem with the FEM

monitor discus sed above, further detailed analysis of the data from this site is not included in the

following analyses which focus on identifying characteristics of the PM 2.5 

### data from the highest

Philadelphia CBSA design value site at Chester (Delaware County, PA) and the MLK site which is the

highest concentration monitor in New Castle County , DE.

Because the Chester PA site is similar in seasonal pattern to the MLK DE site, same day high

concentrations for both sites were compared and the difference in concentration plotted as time series

graphs as seen in Figure 2

. 8 and Figure 2

. 9

.

Figure 2

. 8 : MLK/Chester High Concentration Days

0.0 5.0 10.0 15.0 20.0 25.0 30.0 35.0 40.0 45.01/14/20102/2/20103/11/20106/27/20107/6/20108/10/20109/24/201012/17/201012/19/201012/30/20101/1/20116/1/20117/20/20117/22/201112/13/20116/22/201211/10/201212/15/2012ug/m3 

# 2010

- 2012 High Concentration Days

MLK and Chester

MLK

- a Chester

### 18 Figure 2

. 9 : MLK/Chester High Day Difference

Figure 2

. 9 shows an increasing difference with time between concentrations at MLK and Chester, which

is in agreement with the decreasing trend in average concentrations at MLK and a flat or slightly

inc reasing trend at Chester. All other monitoring sites in the Philadelphia CBSA also show the decreasing

trend similar to MLK ( Figure 2

. 5 ). This data supports the int erpretation that as regional transport PM 2.5 

### contributions decrease, local sources are becoming more significant at the Chester PA site. As the

Chester site is becoming dominated by local source influences, it can therefore no longer be considered as

repr esentative of the wider Philadelphia CBSA

To further examine local versus regional influences on PM 2.5 

### concentrations, analysis of wind directions

associated with PM 2.5 

### concentrations is useful. Both MLK and Chester have continuous PM 2.5 

### FEM

monitor data , which is more meaningful for comparison with wind direction data than 24

- hour average

PM 2.5 

### data. The hourly PM 2.5 

### FEM concentrations at MLK DE and Chester PA for 2010 through 2012

were plotted by hourly average wind direction as shown in the following figures. Both radar plots and bar

charts are shown as different ways to visualize the same data.

The Chester site shows higher average concentrations when winds are from the Northeast (40 to 80

degrees) and Southwest (200 to 280 degrees) as shown in Figure 2

. 10 and Figure 2

. 11

, while the MLK

DE site shows a less pronounced broader range of high concentrations associated with winds from

Southeast through Southwe st (100 degrees to 240 degrees), as shown in Figure 2

. 12 and Figure 2

. 13

. - 4.0 - 2.0 0.0 2.0 4.0 6.0 8.0 10.0 12.01/14/20102/2/20103/11/20106/27/20107/6/20108/10/20109/24/201012/17/201012/19/201012/30/20101/1/20116/1/20117/20/20117/22/201112/13/20116/22/201211/10/201212/15/2012ug/m3 

# Chester

- MLK Difference

high concentration days 2010

- 2012

### 19 Figure 2

. 10 : Chester PM 2.5 

### Concentrations by Wind Direction (WD) Radar Plot

Figure 2

. 11 : Chester PM 2.5 

### Concentrations by Wind Direction Bar Chart

Figure 2

. 12 : MLK PM 2.5 

### Concentrations by Wind Direction (WD) Radar Plot 0.00 5.00 10.00 15.00 20.00 0

20

40

60

80

100

120

140

160

180 200 220 240 260 280

300 320 340 

### Chester PM2.5 FEM by WD

PM2.5

Avg

0.00 5.00 10.00 15.00 20.000-2021-4041-6061-8081-100101-120121-140141-160161-180181-200201-220221-240241-260261-280281-300301-320321-340341-360 

### Chester PM2.5 FEM by WD

PM2.5 Avg

0.00 5.00 10.00 15.00 0

20

40

60

80

100

120

140

160

180 200 220 240 260 280

300 320 340 

### MLK PM2.5 FEM by WD

PM2.5

Avg PM2.5

### 20 Figure 2

. 13 : MLK PM 2.5 

### Concentrations by Wind Direction (WD) Bar Chart

This supports the interpretation that while both MLK and Chester are impacted by regional transport

(southwest), Chester also shows significant impact from the northeast, probably reflecting local sources.

Further examination of transport and trajectorie s are discussed in section 3.

2.6 Speciation and “SANDWICH” Analysis

EPA guidance also discusses the use of PM 2.5 

### compositional analysis th r ough use of speciated data from

the chemical speciation network (CSN) and Improve networks. While MLK has CSN speciation data

from 2002 through 2012, the Chester PA CSN speciation monitoring ended after 2009. Therefore, only

2009 speciated data was used to examine similarities and differences between the two sites as well as a

regional background at Brigantine NJ ’s IMPROVE site (Interagency Monitoring of Protected Visual

Environments) . The EPA also recommends the use of the SANDWICH method to compare CSN and

IMPROVE data.

Table 2

. 6 shows the 2009 speciated SANDWICH (Sulfate, Adjusted Nitrate, Derived Water, Inferred

Carbon Hybrid) data for each site as average μg/ m3 mass concentrations.

Table 2

. 6 : 2009 S peciated SANDWICH Data

Year Site Name SANDWICH

Sulfate SANDWICH

Nitrate SANDWICH

Organic

Carbon SANDWICH

Elemental

Carbon SANDWICH

Crustal

2009 Chester 3.3 2.2 2.6 0.9 0.4

2009 MLK 5.4 1.4 2.9 0.7 0.5

2009 Brigantine 3.8 0.4 1.7 0.3 0.5



### Figure 2

. 14

, Figure 2

. 15

, and Figure 2

. 16 are pie charts with the data in Table 2

. 6 shown as percentages of

total PM 2.5 

### mass. The rural Brigantine background site is dominated by transport as shown by the high

percentage of sulfates. The MLK site shows a combination of transport and local s ources as shown by the

slightly lower percentage of sulfates and higher percentage of nitrates and organic carbon, while the

Chester site shows even stronger local source impact as seen by the lower sulfate and higher nitrate,

organic carbon and elemental carbon components. 0.00 5.00 10.00 15.00 20.000-2021-4041-6061-8081-100101-120121-140141-160161-180181-200201-220221-240241-260261-280281-300301-320321-340341-360 

### MLK PM2.5 FEM by WD

PM2.5 Avg PM2.5

### 21 Figure 2

. 14 : Brigantine Speciated SANDWICH

Figure 2

. 15 : MLK Speciated SANDWICH 57%

6% 25% 5% 7% 

# Brigantine 2009 SANDWICH

Sulfates

Nitrates

Organic Carbon

Elemental Carbon

Crustal

49%

13% 27% 6% 5% 

# MLK 2009 SANDWICH

Sulfates

Nitrates

Organic Carbon

Elemental Carbon

Crustal

### 22 Figure 2

. 16 : Chester Speciated SANDWICH

EPA guidance also discusses the use of this SANDWICH data to estimate the urban excess by subtracting

the rural site background concentrations (Brigantine) from the urban site concentrations (MLK and

Chester). Table 2

. 7 shows the urban excess calculated values for MLK and Chester for 2009.

Table 2

. 7 : MLK and Chester vs. Brigantine Urban Excess

Sulfates Nitra tes Organic

Carbon Elemental

Carbon Crustal

MLK

– Brigantine 1.6 1.0 1.2 0.4 0.0

Chester

- Brigantine

- 0.5 1.8 0.9 0.6

- 0.1



### Figure 2

. 17 is a graphical presentation of the data in Table 2

. 7 , which shows t he speciated data and urban

excess calculations support the different nature of the PM 2.5 

### concentrations between MLK and Chester ;

the Chester site shows more local source influe nce (greater excess in the nitrate and elemental carbon

fractions) compared to MLK urban excess (sulfates and organic carbon). 35%

23% 28% 10% 4% 

# Chester 2009 SANDWICH

Sulfates

Nitrates

Organic Carbon

Elemental Carbon

Crustal

### 23 Figure 2

. 17 : MLK and Chester vs. Brigantine Urban Excess

Trends in PM 2.5 

### composition at the MLK DE site are shown in Figure 2

. 18 using speciation data (non

SANDWICH). The most significant decrease over time is shown in the sulfate component (associated

with regional transport) followed by the organic carbon, ammonium and nitrate fractions. Equivalent data

from the Chester site was not available after 2009 and is therefore not included here.

Figure 2

. 18 : MLK non

- SANDWICH data - 1.0 - 0.5 0.0 0.5 1.0 1.5 2.0

Sulfates Nitrates Organic

Carbon Elemental

Carbon CrustalDiff in ug/m3 

# 2009 SANDWICH

- Calculated Urban

Excess

Chester MLK

0.00 2.00 4.00 6.00 8.00 10.00 12.00 14.00 16.00 18.00

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012ug/m3 

# MLK PM2.5 Speciation Trends

Sulfate Nitrate Ammonium EC OC Crustal

### 24 2.7 Chester Monitor (Delaware County, P A)

As discussed previously, t he ambient data analyses indicate that the Chester monitoring site likely has

significant impact from local sources. Local impact was indic a ted by 1) the Chester monitor deviating

significantly from the downward trend of the other CBSA monitors, 2) the increasing difference with time

between concentrations at MLK and Chester , 3) the more pronounced h igher average concentrations when

winds are from specific directions, and 4) the analysis of spec i ated data.

Delaware notes t hat the Chester monitor is located near the Delaware River waterfront in a heavily

industrialized area. About 2

- miles to the southwest is the Marcus Hook Petroleum refinery, and about 3

- miles to the northeast is Exelon’s Eddystone Generating Station, and there are many other heavy

industrial sources in this 5

- mile stretch between this refinery and power plant.

Figure 2

. 19 illustrates the magnitude of the point sources within 0

- 10 km of the Chester monitor . Figure

2.19 shows that there are significant point source emissions close to the Chester monitor, and th at

emissions decrease significantly with distance from the Chester monitor, based upon 5 kilometer

increment s

. 7

, 8



### Figure 2

. 19 : 2011 Points Source Emissions vs. Distance from Chester Monitor

Delaware also notes that t he Chester monitor is located on an unpaved area within the fence line of t he

Evonik Corporation ( see Picture 1). Evonik manufactures silica from sodium silicate using spray dryers,

silos, granulator system, and packaging system

, and is a significant source of direct PM 2.5 

### emissions.

7 DAQ believes regional factors play a bigger role beyond 15 km, so the evaluation only involved 0

- 15 km.

8 The 5 km cutoff captured only facilities located in Delaware County, PA. 0 500 1,000 1,500 2,000 2,500 3,000 3,500 4,000 4,500

NOX SO2 PM25 VOC NH3TPY 5 km

>5

- 10 km

>10

- 15 km

### 25 Picture 1 : Chester Monitor Locat ed Within the Fence Line of Evonik Corporation

Given that the air quality analysis and a physical evaluation of the Chester monitor indicates that the

monitor is significantly influenced by local sources, Delaware does not believe that data from this monitor

is appropriate for use in setting nonattainment boundaries that encompass any area broader than the

footprint of such local sources.

2.8 Summary of Air Quality An alysis

In summary, this ambient air quality analysis indicates that all areas of Delaware are monitoring PM 2.5



### concentrations that are well below the NAAQS, and that two nearby sites in Pennsylvania are currently

monitoring PM2.5 concentrations that exceed the annual average PM 2.5 

### NAAQS

. This analysis indicates

that the air quality in New Castle County is different than the air quality at the two Pennsylvania sites, and

the air quality analysis supports not associating any part of Delaware with thos e two areas.

• The New Garden site in Chester County data is typical of a site dominated by regional transport as

shown by the seasonal and annual trends analysis . The change in monitoring method from the

FRM to an FEM appears to have introduced a high bia s into recent design values. Returning that

site to the FRM appears to be returning data from that site to trends that are expected, and that

follow the trends of other sites within the Philadelphia CBSA that are below the annual average

NAAQS.

• The Chester site in Delaware County is significantly impacted by local sources as shown by

ambient air quality trends and seasonal patterns, evaluation of high concentration days, speciation

data analysis (SANDWICH and urban excess calculations) , and emissions vs. distance ( Figure

2

. 19 ) . The Chester site is therefore not representative of the larger Philadelphia CBSA.

### 26 Examination of the specific site characteristics also indicates high potential for nearby source

impact.

Delaware concludes from this ambient air quality analysis that the New Garden and Chester monitoring

site s are not representative of the larger Philadelphia CBSA, and that no part of Delaware, including New

Castle County , should be designated as nonattainment due to the air quality in any nearby area.

### 27 3 METEOROLOGY (WEATHER /TRANSPORT PATTERNS)

3.1 General Comments

EPA recommends that states consider meteorology in areas included versus excluded from the

nonattainment area

, as one of the factors in determining appropriate nonattainment area boundaries.

Given that monitoring data indicates all areas of Delaware are a ttaining the PM 2.5 

### standard, this analysis

focuses on how meteorology may link Delaware to any nearby nonattainment area that the EPA may

associate with Delaware.

3.2 Trajectory Cluster Analysis

Back trajectories provide information on the origins of a ir mass and often used in air pollution analysis.

Cluster analysis groups similar air masses originat ing from similar geographic region s, and it can provide

information on pollution species with similar chemical histories. They are useful in evaluating t rends in

concentrations by air mass. Delaware perform ed back trajectory cluster analys e s for its MLK site in

Wilmington, and the Chester monitoring site in Pennsylvania

, and evaluate d if the two sites are impacted

differently.

Back trajectories needed fo r the cluster analysis are generated for these two locations with the Hybrid

Single Particle Lagrangian Integra ted Trajectory Model (HYSPLIT). 9 

### We limit the analysis to the most

recent three years of meteorological data

– 2010 to 2012. For our initial analysis we generated 24

- hour

back trajectories for these two locations at 2:00 pm using the EDAS (Eta Data Assimilation System) data

archives produced by the National Weather Serv ice's National Centers for Environmental Prediction

(NCEP).

Additional information on this model can be found on NCEP's website. 10 

### The tools that we used in the

trajectory cluster analysis are R 11 

### (A Language and Environment for Statistical Computing )

, an d openair

package f or R 12

, 13



### .

For our initial analysis we plot ted back trajectories colored by the PM 2.5 

### concentrations observed at MLK

DE and Chester PA monitors shown in Figure 3

. 1 . From this figure we can make out that MLK DE and

Chester PA monitors are impacted differently, that is ; different air masses are bringing different levels of

PM 2.5 

### to these two monitors. Without further analysis, however, we cannot make ou t what these

differences are.

9 http://ready.arl.noaa.gov/HYSPLIT.php

10 http://www.nco.ncep.noaa.gov/pmb/products/

11 http://www.R

- project.org

12 Ca rslaw, D.C. and K. Ropkins, (2012). Open air

— an R package for air quality data analysis. Environmental Modelling &

Software. Volume 27

- 28, 52

- 61.

Carslaw, D.C. (2013). The open air manual

— open

- source tools for analyzing air pollution data. Manual for version 0.8

- 0,

King’s College London.

13 http://www.openair

- project.org

### 28 Figure 3

. 1 : 24

- hour HYSPLIT back trajectories originated at 2:00 pm from MLK DE (top) and

Chester PA (bottom) monitors for 2010

- 2012 colored by PM 2.5 

### concentration (μg/m 3 

### )

Back trajectory cluster analysis is likely to explain the differences in impacts at these monitors. For this

analysis we generated 24

- hour back trajectories at 3

- hour intervals starting at hour 0. We chose to lump

the trajectories into six clusters. To simplify the analysis we chose to display the mean trajectories for

each of the clusters, and they are shown in Figure 3

. 2 . In general, clusters 1 through 4 seem t o represent

flows from west, south

- west or north

- west directions, whereas clusters 5 and 6 from north

- east/east and

east. The directions of the clusters can change significantly from year to year as noticed in Figure 3

. 2

. The mean cluster paths, although they can explain the origins of the clusters, cannot explain how the

PM 2.5 

### concentrations vary from cluster to cluster and how they vary temporally.

### 29 Figure 3

. 2 : Six clusters to b ack trajectories at MLK DE (top) and Chester PA (bottom) monitors

for 2010

- 2012 showing the mean trajectory for each cluster

To further explain the differences in the mean cluster paths, w e analyze d how the PM 2.5 

### concentrations

vary by cluster and by month. In order to accomplish this, we merge d the cluster data with 24

- hour PM 2.5 

### measurements at MLK DE and Chester PA; this makes it possible to identify the data by cluster size. In

merging the two datasets it is not necessary to retain information for all 24 back trajectory hours;

therefore we extrac ted the cluster size for the fi rst hour, which provides PM 2.5 

### data identified by cluster.

The numbers of trajectories in each cluster by monitor are summarized in Table 3

. 1

.

### 30 Table 3

. 1 : Numbers of Each Cluster by Monitor

Monitor Year C1 C2 C3 C4 C5 C6

MLK DE 2010 585 558 494 306 429 298

2011 715 700 520 357 302 295

2012 584 448 718 529 339 300

Chester PA 2010 585 581 483 298 433 289

2011 693 685 549 350 315 297

2012 557 438 738 543 343 300

We notice that for the MLK DE monitor the sequence of dominant clusters in 2010 is 1, 2, 3, 5, 4, and 6;

in 2011 it is 1, 2, 3, 4, 5, and 6; in 2012 it is 3, 1, 4, and 2, followed by 5 and 6. We also notice the same

behavior at the Chester PA monitor. Although the dominant clusters vary from year to year (from west,

north

- west, south

- west, and south), they are the same for both the monitors.

The analysi s of how the PM 2.5 

### concentrations vary temporally by cluster is more meaningful. A graphical

representation of the variation in the mean PM 2.5 

### concentrations by month and hour of the day at both the

monitors is displayed in Figure 3

. 3

, Figure 3

. 4 , and Figure 3

. 5

.

Although the dominant clusters are the same for both the monitors, the differences in temporal behavior

are clearly evident in these figures. For example, in year 2010 clus ter 1 (north

- west) at MLK DE is

impacted more in the winter and summer months while cluster 1 at Chester PA monitor is impacted more

in the winter months; furthermore

, morning and afternoon differences in PM 2.5 

### variations are also evident,

which is a sign of local

, rather than regional

, impacts at the Chester PA monitor. Similar temporal

differences are also observed in clusters 3, 4 and 5

. C lusters 5 and 6 (easterly flows) show somewhat

different behavior; in winter the Chester PA monitor is impacted mor e than the MLK DE monitor. In

general in winter months the Chester PA monitor shows more variation in PM 2.5 

### concentrations in all the

clusters , which is a sign of local impacts.

### 31 Figure 3

. 3 : Variation of PM 2.5 

### by month and hour of the day by wind direction cluster at MLK DE

(top) and Chester PA (bottom) monitors for 2010

The sequence of dominant clusters at both the monitors in 2011 is the same. The behavior in variation of

PM

- 2.5 

### concentrations by cluster in 2011 is similar to that observed for 2010.

### 32 Figure 3

. 4 : Variation of PM 2.5 

### by month and hour of the day by wind direction cluster at MLK DE

(top) and Chester PA (bottom) monito rs for 2011

The sequence of dominant clusters in 2012 is the same at both the monitors. The behavior in variation of

PM

- 2.5 

### concentrations by cluster in 201 2 is similar to that observed in 2010 and 2011.

### 33 Figure 3

. 5 : Variation of PM 2.5 

### by month and hour of the day by wind direction cluster at MLK DE

(top) and Chester PA (bottom) monitors for 2012

3.3 Summary of Trajectory Cluster Analysis

In this analysis for three years of meteorology , we noticed that the dominant clusters are the same for both

the monitors. Between the two monitors, we witnessed temporal differences in PM 2.5 

### concentrations from

cluster to cluster. In the morning hours the Chester PA monitor shows higher PM 2.5 

### concen trations than

the MLK DE monitor, and also in winter months the Chester PA monitor shows more variation in PM 2.5



### concentrations in all the clusters. These observations demonstrate that while both the monitors are

impacted by regional sources, the Chester PA monitor is impacted more by local sources when compared

to the MLK DE monitor.

### 34 4 EMISSIONS AND EMISSI ONS

- RELATED DATA

As in past PM 2.5 

### designations, EPA will be evaluating the entire Philadelphia C B SA, plus adjacent

counties (CBSA+) that may contribute to a violation. Thus, EPA recommends that states consider

emissions potentially included versus excluded from the C B SA nonattainment area as one of the factors in

determining appropriate nonattainment area boundaries.

4.1 2011 EPA National Emiss ions Inventory

The latest inventory available is the 2011 National Emissions Inventory (NEI)

, version 1

. The 2011 NEI

tons per year (tpy) emission data for counties in the Philadelphia CBSA+ are provided below in Table

4

. 1

. 14 

### The data shows that in 2011, New Castle County total PM 2.5



### - related pollutant emissions were

ranked 10 th



### . 15



### Table 4

. 1 : 2011 NEI Philadelphia CBSA +

State County NH3 NH3

Rank NOX NOX

Rank PM25 PM25

Rank SO2 SO2

Rank VOC VOC

Rank SUM SUM

Rank

PA York 3495 3 33810 1 3758 2 26590 1 14024 5 81677 1

PA Lancas ter 15753 1 13881 9 4107 1 1802 11 13584 6 49127 2

PA Philad elphia 801 9 22394 2 2722 4 2788 5 17548 1 46254 3

PA Northa mpton 614 17 14074 8 2274 7 20024 2 5404 20 42390 4

PA Berks 4095 2 14390 7 3023 3 6140 4 12848 8 40495 5

PA Montgomery 779 10 17275 4 2508 6 2522 6 15308 4 38393 6

PA Delaware 595 18 17964 3 2579 5 6559 3 10166 12 37863 7

NJ Middle sex 526 20 14766 6 1843 11 771 17 16651 2 34558 8

PA Bucks 1024 7 13277 10 1965 10 2040 9 15477 3 33783 9

DE New Ca stle 922 8 15866 5 2099 8 2383 7 11469 10 32739 10

PA Cheste r 1906 5 12177 11 2002 9 2178 8 10454 11 28717 11

NJ Monmouth 740 12 10365 12 1307 16 670 18 12541 9 25624 12

NJ Ocean 335 25 7972 17 1397 15 479 22 13185 7 23367 13

PA Lehigh 620 16 8921 13 1398 14 1323 14 9748 14 22010 14

NJ Burlin gton 556 19 8448 15 1405 13 525 21 9981 13 20915 15

NJ Camden 244 28 8660 14 1772 12 611 19 9203 15 20490 16

NJ Gloucester 362 24 8015 16 1113 18 1366 13 8940 16 19796 17

NJ Mercer 254 27 7513 18 1260 17 948 15 7560 17 17535 18

DE Kent 2462 4 5673 21 922 21 1839 10 4298 23 15193 19

NJ Somers et 264 26 5960 20 665 23 241 28 7015 19 14145 20

NJ Atlant ic 241 29 4905 22 900 22 425 24 7062 18 13534 21

MD Harford 495 21 6169 19 945 20 525 20 5163 21 13298 22

14 Paved road dust emissions were not included in the summaries due to inconsistencies in data (e.g. Philadelphia County had

2011 NEI emissi ons of 17 tpy of PM 2.5 from paved road dust while New Castle County had 408 tpy). Wildfires were also

removed, since they are not an anthropogenic source and uncontrollable. They were also calculated by EPA using satellites,

which do not match DAQ’s esti mates (EPA 502 tpy vs. DE 20 tpy of PM 2.5 ). Biogenic emissions are also not included in any

of the emission tables in this TSD.

15 Due to the EME Homer City vs. EPA court decision, VOC and ammonia are required to be considered as precursors.

Henceforth, t he “SUM” of all PM 2.5 - related pollutants will be used as the final indicator of relative rankings (NOTE: Delaware

could not perform a weighted emissions score due to lack of recent speciated data for each county in the CBSA).

### 35 State County NH3 NH3

Rank NOX NOX

Rank PM25 PM25

Rank SO2 SO2

Rank VOC VOC

Rank SUM SUM

Rank

NJ Cumber land 459 22 4078 23 1081 19 792 16 4888 22 11299 23

MD Cecil 651 15 3653 24 589 25 323 27 2788 26 8005 24

NJ Salem 708 14 3239 26 453 28 1405 12 2122 27 7926 25

NJ Hunter don 450 23 3446 25 434 29 328 25 3139 24 7797 26

MD Queen Anne's 1897 6 2943 27 626 24 449 23 1727 28 7643 27

NJ Warren 710 13 2622 28 521 26 328 26 3010 25 7192 28

MD Kent 744 11 1026 29 487 27 204 29 1215 29 3675 29

** Bold font indicates those counties which are part of the Philadelphia CBSA



### Table 4

. 2 shows only the Philadelphia CBSA counties, and that in 2011, New Castle Count y’s total

PM 2.5



### - related pollutant emissions were ranked No. 5 th 

### (down from 1 st 

### in 2002) and barely above

Delaware County. Furthermore, although New Castle’s emissions are about the same as Delaware

County, the closest DE monitor to the Chester monitor in Delaware County is Bellefonte (~8 mi.), with a

2010

- 2012 DV of only 9.8 μg/m 3 

### . This is significantly less than t he Chester DV of 13.1 μg/m 3



### , leading

Delaware to conclude that local emissions significantly influence the Chester monitor. Details on how

New Cast le compares with other counties’ emission reductions are discussed in s ection 4.3

.

Table 4

. 2 : 2011 NEI Philadelphia CBSA

State County NH3 NH3

Rank NOX NOX

Rank PM25 PM25

Rank SO2 SO2

Rank VOC VOC

Rank SUM SUM

Rank

PA Philadelphia County 801 4 22394 1 2722 1 2788 2 17548 1 46254 1

PA Montgomery County 779 5 17275 3 2508 3 2522 3 15308 3 38393 2

PA Delawar e County 595 7 17964 2 2579 2 6559 1 10166 6 37863 3

PA Bucks C ounty 1024 2 13277 5 1965 6 2040 6 15477 2 33783 4

DE New Cas tle County 922 3 15866 4 2099 4 2383 4 11469 4 32739 5

PA Chester County 1906 1 12177 6 2002 5 2178 5 10454 5 28717 6

NJ Burlington County 556 8 8448 8 1405 8 525 10 9981 7 20915 7

NJ Camden County 244 11 8660 7 1772 7 611 9 9203 8 20490 8

NJ Glouces ter County 362 10 8015 9 1113 9 1366 7 8940 9 19796 9

MD Cecil C ounty 651 6 3653 11 589 11 323 11 2788 11 8005 11



### 4.2 Emissions Related Data

4.2.1 Population

EPA recommends that states consider the population density and the degree of urbanization in areas

included versus excluded from the nonattainment area as one of the factors in determining appropriate

nonattainment area boundaries. Population, growth rates, population densities and rankings for the

Philadelphia CBSA and surrounding counties (CBSA+) are presented in Table 4

. 3

, and shows that New

Castle County ranks:

• 7 th 

### for 2010 population for the CBSA+

• 12 th 

### in population growth between 2000

- 2010 for the CBSA+

• 7 th 

### in 2010 population density CBSA+

### 36 • 5 th 

### for 2010 population for the CBSA

• 4 th 

### in population growth between 2000

- 2010 f or the CBSA

• 5 th 

### in 2010 population density CBSA

Table 4

. 3 : 2000

- 2010 Population Statistics

- Philadelphia CBSA +

State County 2000 1 2010 2 2010

Rank CBSA

Rank %

Growth CBSA+

Rank CBSA

Rank Sq.

Miles Pop.

Density CBSA+

Rank CBSA

Rank

PA Philadelphia 1,517,562 1,526,006 1 1 1% 25 8 135 11,304 1 1

PA Montgomery 749,409 799,874 2 2 7% 14 5 483 1,656 4 4

NJ Monmouth 615,253 630,380 3 2% 22 472 1,336 6

PA Bucks 597,548 625,249 4 3 5% 19 7 607 1,030 8 6

NJ Ocean 510,950 576,567 5 13% 4 636 907 10

PA Delaware 551,722 558,979 6 4 1% 23 8 184 3,038 2 2

DE New Castle 500,294 538,479 7 5 8% 12 4 426 1,264 7 5

PA Lancaster 470,783 519,445 8 10% 9 949 547 16

NJ Camden 507,075 513,657 9 6 1% 24 222 2,314 3 3

PA Chester 433,208 498,886 10 7 15% 3 2 756 660 13 8

NJ Burlington 423,329 448,734 11 8 6% 16 6 805 557 14 9

PA Berks 373,712 411,442 12 10% 10 859 479 18

NJ Mercer 350,773 366,513 13 4% 20 226 1,622 5

PA Lehigh 311,746 349,497 14 12% 6 347 1,007 9

PA Northampton 267,446 297,735 15 11% 8 374 796 12

NJ Gloucester 255,946 288,288 16 9 13% 5 3 325 887 11 7

NJ Atlantic 253,210 274,549 17 8% 11 561 489 17

MD Harford 218,914 244,826 18 12% 7 440 556 15

DE Kent 126,771 162,310 19 28% 1 591 275 24

NJ Cumberland 146,454 156,898 20 7% 13 489 321 20

NJ Hunterdon 122,110 128,349 21 5% 18 430 298 22

NJ Warren 102,383 108,692 22 6% 15 358 304 21

MD Cecil 85,964 101,108 23 10 18% 2 1 348 291 23 10

NJ Cape May 102,323 97,265 24

- 5% 26 255 381 19

NJ Salem 64,272 66,083 25 3% 21 338 196 25

MD Kent 19,201 20,197 26 5% 17 279 72 26

1 The April 1, 2000 Population Estimates base reflects changes to the Census 2000 population from the Count Question Resolut ion program,

legal boundary updates, and other geographic program revisions."

2 The data source for April 1, 2010 is the 2010 Census count. Note: All geographic boundaries for the 2000

- 2010 intercensal estimates are

defined as of January 1, 2010.

Citation 2000

- 2010 data : Table 1. Intercensal Estimates of the Resident Populat ion for Counties of Delaware: April 1, 2000 to July 1,

2010 (CO

- EST00INT

- 01

- 10). Source: U.S. Census Bureau, Population Division, Release Date: September 2011

http://www.census.gov/popest/data/intercensal/county/CO

- EST00INT

- 01.html

** Bold font indicates those counties which are part of the Philadelphia CBSA



### Based on population vs. air quality data, Delaware believes that ambient concentrations of PM 2.5 

### do not

necessarily correlate with population parameters. For instance, Philadelphia County i s not violating the

NAAQS, while its population and population density is almost three and four times greater, respectively,

than Delaware County (nonattainment). Furthermore, the highest Philadelphia County design value is

only 11.0 μg/m 3 

### while Delaware County’s is 13.1 μg/m 3 

### , a difference of 3.1 μg/m 3 

### ; or about 25% of the

NAAQS. Similarly, Camden County NJ has almost twice the population density as New Castle, DE yet

Camden’s 2012 DVs is only 9.5 μg/m 3 

### , compared to New Castle’s highest DV of 10.4 μg/m 3



### .

### 37 To further evaluate the relationship of population vs. DVs, Delaware obtained a listing of the top 25

CBSAs by population from EPA’s website, and then looked at the attainment status using 2009

- 2011

DVs. D elaware performed a statistical analysis of popu lation vs. design values and found insignificant

correlation between the two datasets (r = 0.31)

. 16 

### Table 4

. 4 ranks the top CBSAs by population with

their corresponding 2009

- 2011 DVs.

Table 4

. 4 : Top 25 CBSA 17



### - Attainment Status (2009

- 2011 DVs)

CBSA Name Population 2010 2009

- 2011 DV

New York

- Northern New Jersey

- Long Island, NY

- NJ

- PA 18,919,649 11.9

Los Angeles

- Long Beach

- Santa Ana, CA 12,844,371 13.9

Chicago

- Joliet

- Naperville, IL

- IN

- WI 9,472,584 12.7

Dallas

- Fort Worth

- Arlington, TX 6,400,511 10.6

Houston

- Sugar Land

- Baytown, TX 5,976,470 12.4

Philadelphia

- Camden

- Wilmington, PA

- NJ

- DE

- MD 5,971,589 13.1

Washington

- Arlington

- Alexandria, DC

- VA

- MD

- WV 5,609,150 10.8

Miami

- Fort Lauderdale

- Pompano Beach, FL 5,578,080 7.5

Atlanta

- Sandy Springs

- Marietta, GA 5,286,296 13.2

Boston

- Cambridge

- Quincy, MA

- NH 4,559,372 10.2

San Francisco

- Oakland

- Fremont, CA 4,343,381 9.9

Detroit

- Warren

- Livonia, MI 4,290,722 11.6

Riverside

- San Bernardino

- Ontario, CA 4,245,005 16.2

Phoenix

- Mesa

- Glendale, AZ 4,209,070 9.9

Seattle

- Tacoma

- Bellevue, WA 3,447,886 8.3

Minneapolis

- St. Paul

- Bloomington, MN

- WI 3,285,913 9.7

San Diego

- Carlsbad

- San Marcos, CA 3,105,115 13.1

St. Louis, MO

- IL 2,814,722 13.1

Tampa

- St. Petersburg

- Clearwater, FL 2,788,151 7.8

Baltimore

- Towson, MD 2,714,546 11.1

Denver

- Aurora

- Broomfield, CO 2,554,569 8.1

Pittsburgh, PA 2,357,951 13.7

Portland

- Vancouver

- Hillsboro, OR

- WA 2,232,896 7.9

Sacramento

-- Arden

- Arcade

-- Roseville, CA 2,154,583 10

San Antonio

- New Braunfels, TX 2,153,891 9.2

Correlation of Population vs. Design Values 0.31



### Setting the low correlation score of 0.31 (population vs. DV) aside for the moment, Delaware is well

aware that some source categories utilize population as the activity data in non

- point (area) source

emission calculations. Based on previous EPA designation letters to Delaware, t his is one of the main

reasons EPA includes population as one of th e 5

- factor analysis. However, in the case of Delaware

emissions, the only area source categories in the 2011 NEI that are strictly population

- dependent are:

16 An r score of 0.75 or hig her would suggest a correlation, therefore a score of 0.31 is highly non

- correlated.

17 http://www.city

- data.com/top1.html

### 38 • Consumer and Commercial Products,

• Industrial Adhesives,

• AIM Coatings, and

• Commercial Cooking

• Stage I and Stage 2

• Dry C leaning

Of these source categories, all but commercial cooking exclusively emits VOC, which are already strictly

controlled via reasonably available control technology (RACT) under 7 DE Admin

. Code 1124. The

commercial cooking c ategory includes both PM 2.5 

### and VOC which are not economically conducive to

emission control ( discussed in more detail in Section 4.4 ). Furthermore, due to low stack heights and

flow rates, D elaware considers VOC and PM 2.5 

### from commercial cooking to be localized, and not a

regional contributor.

There are also some categories that rely on occupied housing numbers, which are indirectly related to

human population. The residential open burning category and residential wood combustion are the two

categories which use housing data. Delaware already strictly regulates open burning through 7 DE

Admin

. Code 1113, and woodstoves are regulated by the EPA under New Source Performance Standards

. Either way, due to low stack height s and flow rates from fireplaces and ground

- level open burning,

D elaware considers emission contribution from these categories to be localized and not contributors to

PM 2.5 

### concentrations at the Chester monitor

.

Figure 4

. 1 plots New Castle County ’s population against New Castle DVs. This figure illustrates that

population is not well correlated with air quality data.

Figure 4

. 1 : N CC 3

- year Rolling DVs vs. NCC Population ( over 10 years )

In summary, Delaware believes population and related criteria are not suitable as a tool in making

boundary determinations for New Castle County

, or at the very least should be low priority in EPA

boundary considerations

. 490,000 500,000 510,000 520,000 530,000 540,000 550,000

10 11 12 13 14 15 16 17

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012ug/m3

YEAR 

## Population vs. PM25 DVs

New Castle DV (μg/m3) Population

### 39 4.2.2 Expected growth

Growth in New Castle County is likely to be regulated beyond most other areas because of Delaware’s

existing environmentally protective programs. These include Delaware’s New Source Review (NSR)

program, Delaware’s Coastal Zone Program, where offsets are required for any increase i n emission s (no

de minimis), and the Livable Delaware initiative which is designed to promote smart growth principles.

Table 4

. 5 shows the 2010 and 2035 18 

### population s, rankings and growth rates of counties within the

CBSA/ CBSA + . It can be seen that of the CBSA+ nonattaining counties, Chester and Delaware are

ranked 8 th 

### and 10 th 

### for population growth in 2035, and 7 th 

### and 25 th 

### for growth rate rankings, respectively.

Meanwhile, New Castle County ranks 9 th 

### and 21 st 

### for 2035 population and 2035 growth rate, respectively.

Thus, while all three nearby counties have similar rankings in 2010, New Castle County has one of the

lowest projected growth rates for 2035. Note th at in the CBSA, New Castle is ranked 7 th 

### out of 10

counties. Consequently, New Castle future emission increases due to population can reasonably be

expected to be minimal.

Table 4

. 5 : 2010

- 2035 Population, G rowth and Rankings

– Philadelphia CBSA +

State County ** 2010 2035 (1) CBSA+

Rank Absolute

Change 2035

Growth

Rate CBSA+

Rank CBSA

Rank

PA Lehigh 349,497 833,441 3 483,944 58% 1

MD Cecil 101,108 156,133 21 55,025 35% 2 1

NJ Ocean 576,567 776,300 4 199,733 26% 3

NJ Atlantic 274,549 357,570 17 83,021 23% 4

PA Northampton 297,735 384,873 15 87,138 23% 5

NJ Gloucester 288,288 369,370 16 81,082 22% 6 2

PA Chester 498,886 622,500 8 123,614 20% 7 3

NJ Warren 108,692 134,200 23 25,508 19% 8

DE Kent 162,310 199,065 19 36,755 18% 9

PA Lancaster 519,445 632,595 7 113,150 18% 10

NJ Burlington 448,734 541,200 11 92,466 17% 11 4

PA Bucks 625,249 753,780 5 128,531 17% 12 5

MD Harford 244,826 292,620 18 47,794 16% 13

NJ Cape May 97,265 116,010 24 18,745 16% 14

MD Kent 20,197 23,850 26 3,653 15% 15

NJ Hunterdon 128,349 147,800 22 19,451 13% 16

NJ Monmouth 630,380 717,900 6 87,520 12% 17

NJ Cumberland 156,898 176,060 20 19,162 11% 18

PA Montgomery 799,874 894,140 2 94,266 11% 19 6

PA Berks 411,442 459,221 13 47,779 10% 20

DE New Castle 538,479 598,312 9 59,833 10% 21 7

NJ Mercer 366,513 403,980 14 37,467 9% 22

NJ Salem 66,083 72,710 25 6,627 9% 23

NJ Camden 513,657 524,680 12 11,023 2% 24 8

18 The year 2035 was chosen because States have at least until 2020 to achieve compli ance with the 2012 NAAQS, and

subsequent maintenance plans typically address emissions and control measures, such as mobile budgets maintenance at least

15 years later or more.

### 40 State County ** 2010 2035 (1) CBSA+

Rank Absolute

Change 2035

Growth

Rate CBSA+

Rank CBSA

Rank

PA Delaware 558,979 559,960 10 981 0% 25 9

PA Philadelphia 1,526,006 1,480,000 1

- 46,006

- 3% 26 10

Delaware 2010

- 2035 projections data: Wilmington Area Planning Council, WILMAPCO 2012 Inter

- Regional Report

. http://www.wilmapco.org/wilmapco

- council/

** Bold font indicates those counties which are part of the Philadelphia CBSA



### 4.2.3 Traffic and commuting patterns

Table 4

. 6 shows that New Castle County ranks 5 th 

### (on average ) for 1) Number of residents commuting to

any violating counties, 2) Percent Commuting to any violating counties, 3) Number commuting into an d

within the CBSA /CBSA+ and 4) Percent commuting into and within CBSA. Of particular importance is

the data showing only 6.2% of Delaware commuters going to either Delaware or Chester Counties. And,

although this presents evidence that Delaware citizens /commuters contribute some pollution via cars to air

quality monitored in each of those Counties, it is small in relation to the previously discussed

contributions of local point sources, particularly the Chester monitor in Delaware County 19 

### as discussed

in section 2.7

.

Table 4

. 6 : CBSA+ C ommuting P atterns

State County** Number

commuting

to any

violating

counties CBSA+

Rank Percent

Commuting

to any

violating

counties CBSA+

Rank Number

commuting

into and

within

CBSA+ CBSA+

Rank Percent

commuting

into and

within

CBSA+ CBSA+

Rank CBSA

Rank

PA Chester 172,644 1 70.9% 1 232,571 6 95.6% 4 1

PA Delaware 157,218 2 60.9% 2 254,548 4 98.6% 1 2

PA Montgomery 37,819 3 9.4% 3 387,702 2 96.9% 3 3

PA Philadelphia 25,038 4 4.2% 6 588,694 1 98.4% 2 4

DE New Castle 15,794 5 6.2% 4 243,130 5 94.7% 5 5

PA Berks 8,687 6 4.6% 5 26,410 10 13.9% 12

PA Lancaster 8,421 7 3.4% 7 11,661 14 4.8% 19

PA Bucks 5,177 8 1.7% 11 270,365 3 87.5% 8 6

NJ Gloucester 4,226 9 3.1% 8 123,031 9 89.8% 7 7

NJ Camden 2,922 10 1.2% 12 222,034 7 93.4% 6 8

NJ Burlington 1,751 11 0.8% 13 174,516 8 81.5% 9 9

MD Cecil 1,363 12 2.9% 9 14,359 11 30.2% 11 10

PA Lehigh 706 13 0.4% 14 12,057 13 7.6% 16

NJ Salem 604 14 2.1% 10 10,736 15 37.1% 10

PA Northampton 359 15 0.3% 18 4,813 20 3.6% 20

NJ Mercer 309 16 0.2% 20 13,545 12 8.3% 15

DE Kent 294 17 0.4% 16 9,635 16 13.8% 13

19 Based on trends and changing their monitor from FEM to FRM, DAQ believes the New Garden monitor in Chester County

PA is likely to be attainment based upon 2011

- 2013 data.

### 41 State County** Number

commuting

to any

violating

counties CBSA+

Rank Percent

Commuting

to any

violating

counties CBSA+

Rank Number

commuting

into and

within

CBSA+ CBSA+

Rank Percent

commuting

into and

within

CBSA+ CBSA+

Rank CBSA

Rank

NJ Atlantic 265 18 0.2% 19 8,953 17 7.2% 17

MD Harford 231 19 0.2% 21 1,764 23 1.4% 23

NJ Cumberland 213 20 0.3% 17 6,522 19 10.6% 14

NJ Monmouth 196 21 0.1% 23 2,842 21 1.1% 24

NJ Ocean 145 22 0.1% 24 6,902 18 3.0% 22

NJ Warren 71 23 0.1% 22 430 25 0.8% 25

MD Kent 40 24 0.4% 15 670 24 7.1% 18

NJ Hunterdon 21 25 0.0% 25 2,012 22 3.3% 21

MD Queen Anne's 0 26 0.0% 26 0 26 0.0% 26

NJ Middlesex 0 26 0.0% 27 0 26 0.0% 26

NJ Somerset 0 26 0.0% 28 0 26 0.0% 26

PA York 0 26 0.0% 29 0 26 0.0% 26

** Bold font indicates those counties which are part of the Philadelphia CBSA



### 4.2.4 Vehicle Miles Traveled

Table 4

. 7 show s that while New Castle County is ranked 4 th 

### in the CBSA+ for 2010 vehicle miles

traveled (VMT), relative to 2002 vehicle miles traveled (VMT), New Castle County had the 18 th 

### lowest

growt h rate at negative 3% , and was ranked 8 th 

### out of 10 Counties in the Philadelphia CBSA.

Table 4

. 7 : CBSA+ 2 002

- 2010 Vehicle Miles Traveled and Rankings

State County ** 2002 (million

VMT) 2010 (million

VMT) CBSA+

Rank %

Growth CBSA+

Rank CBSA

Rank

PA Montgomery 4,677 6,452 1 38% 1 1

NJ Salem 734 977 25 33% 2

PA Chester 3,128 4,134 7 32% 3 2

NJ Cape May 749 987 24 32% 4

NJ Atlantic 2,236 2,766 14 24% 5

PA Bucks 3,830 4,686 5 22% 6 3

NJ Burlington 3,748 4,449 6 19% 7 4

NJ Monmouth 5,146 6,098 2 18% 8

NJ Gloucester 2,312 2,610 16 13% 9 5

NJ Warren 1,473 1,556 21 6% 10

MD Harford 2,208 2,322 17 5% 11

NJ Ocean 3,641 3,705 10 2% 12

PA Delaware 3,513 3,545 11 1% 13 6

PA Cecil 1,340 1,350 22 1% 14 7

PA Lehigh 2,738 2,720 15

- 1% 15

DE Kent 1,633 1,620 20

- 1% 16

### 42 State County ** 2002 (million

VMT) 2010 (million

VMT) CBSA+

Rank %

Growth CBSA+

Rank CBSA

Rank

PA Lancaster 4,004 3,964 8

- 1% 17

DE New Castle 5,338 5,201 4

- 3% 18 8

NJ Hunterdon 1,893 1,843 19

- 3% 19

NJ Cumberland 1,166 1,115 23

- 4% 20

NJ Camden 4,332 3,880 9

- 10% 21 9

PA Northampton 2,132 1,871 18

- 12% 22

NJ Mercer 3,869 3,286 12

- 15% 23

PA Berks 3,952 3,128 13

- 21% 24

PA Philadelphia 10,213 5,579 3

- 45% 25 10

Data sources :

2010 non

- DE VMT

- http://www.epa.gov/airquality/particlepollution/designations/2012standards/techinfo.htm

2002 and 2010 Delaware VMT : http://www.deldot.gov/information/projects/hpms/pages/hp ms_2011.shtml

** Bold font indicates those counties which are part of the Philadelphia CBSA



### R egardless of the fact that Montgomery County, PA rank s 1 st 

### in 2010 VMT, and also 1 st 

### in 2002

- 2010

VMT growth

, the Montgomery County, PA 2012 DV is only 9.8 μg/m 3 

### . And, although Delaware county

VMT has stayed relatively the same since 2002, its 2010

- 2012 DV remains the highest in the CBSA.

Therefore, if increasing levels of VMT can result in non

- violations

, and New Castle VMT growth has

been negative

, Delaware believes EPA should not consider VMT (and thus commuting) as a possible

reason to include New Castle County in any nonattainment area.

4.3 Emission Reductions

4.3.1 General Discussion

Over the past decade Delaware and Regional Planning Organizations have condu cted many studies

relative to visibility and fine particulate matter (PM 2.5 

### ) concerns. 20

, 21

, 22

, 23 

### The studies included modeling,

emissions analysis and source contribution assessments. As a result, Delaware learned that sulfate was

the largest contributor to PM 2.5 

### nonattainment in the eastern United States, followed by nitrates, organic

compounds and

, depending on the location of the monitor to highways and/or point sources

, direct PM 2.5



### .

These studies also reveal that the previous PM 2.5 

### nonattainment status for both Delaware and the

Philadelphia Combined Statistical Area CSA (Philadelphia

- Camden

- Wilmington, PA

- NJ

- DE

- MD) was

caused primarily by a combination of underlying long

- range interstate transport of sulfate and nitrates

from power plants in the Ohio River valley, and local sources of direct PM 2.5 

### (mobile and point)

. Since

sulfur dioxide ( SO 2 

### ) and oxides of nitrogen ( NOx ) are precursors to sulfate and nitrate; SO 2 

### and NOx are

20 Contributions to Regional Haze in the Northeast and Mid

- Atlantic United States Mid

- Atlantic/Northeast Visibility Union

(MANE

- VU) Contribution Assessment, Prepar ed by NESCAUM for the Mid

- Atlantic/Northeast Visibility Union (MANE

VU), August 2006

21 A Guide to Mid

- Atlantic Regional Air Quality

, Mid

- Atlantic Regional Air Management Association, October 2005

22 The Nature of the Fine Particle and Regional Haze Air Quality Problems in the MANE

- VU Region: A Conceptual

Description, by NESCAUM Boston, MA November 2, 2006

23 Philip K. Hopke and Eugene Kim, Analysis of Speciation Trends Network Data Measured at the State of Delawar e, Center

for Air Resources Engineering an d Science Clarkson University, Potsdam, NY

, January 20, 2005

### 43 the largest pollutants of concern due to regional and lon g

- range transport, while emissions of direct PM 2.5 

### and certain carbonaceous compounds tend to affect air quality more on a local level, particularly onroad

mobile sources. Thus, it is generally understood that sulfates and nitrates are more regional in na ture,

while direct PM 2.5 

### and volatile organic compounds (V OC ) are more locally

- oriented.

All non

- trivial Delaware sources of PM 2.5



### - related pollutants are currently well controlled.

4.3.2 Delaware’s 2012 Point Source Reductions Since 2002

As can be seen in Table 4

. 8 , total 2012 emissions of direct PM 2.5 

### and its precursors from New Castle

County ’s largest point sources 24 

### decreased 87% between 2002 and 2012. This included a massive 99%

reduction in SO 2 

### , followed by a 65% reduction in direct PM 2.5 

### , and a 52% decrease of NOx . VOC

reductions of 54% have tak en place since the early 1990s due to Delaware’s ozone nonattainment issues

over the years. NH 3 

### emissions have been reduced 52%, even though New Castle County emissions of

ammonia in 2002 from these largest point sources were only 82 tons per year (tpy).

Table 4

. 8 : New Castle County

- Top Point Source Emitters in 2002 and 2012

New Castle Top

Emitting Facilities NH3 NOx SO2 PM2.5 VOC Sum of PM2.5

related Pollutants

2002 2012 2002 2012 2002 2012 2002 2012 2002 2012 2002 2012

Calpine Edge Moor 30 16 3,138 463 9,854 48 517 4 36 33 13,575 564

Calpine Hay Road 0 1 566 696 11 13 3 142 10 45 590 897

DE City Refinery 43 12 3,555 2,083 34,096 304 905 312 829 208 39,428 2,919

DuPont Edgemoor 1 1 35 29 92 21 27 1 83 98 239 150

DuPont Experimental

Station 3 3 208 176 593 226 37 18 8 11 849 434

Evraz Steel 0 0 125 227 11 40 45 59 67 67 248 393

Formosa 4 6 31 31 0 1 35 15 124 69 194 122

TOTALS 82 39 7,658 3,705 44,658 653 1,569 551 1,157 531 57,126 7,491

2002

- 2012 % Reduction 52% 52% 99% 65% 54% 87%



### 4.3.3 CBSA Emission Reductions between 2002 and 2011

Table 4

. 9

, Table 4

. 10 , and Table 4

. 11 contain emissions data showing the Philadelphia CBSA emissions

in 2002 and 2011, along with the corresponding emission reductions and rankings. As can be seen from

the t ables, New Castle ranked 1 st 

### of the 10 counties in total PM 2.5



### - relat ed emissions during 2002. On the

other hand, due to the significant control measures Delaware has implemented since 2002 , New Castle

now ranks 5 th 

### in total emissions, and more importantly, ranks 1 st 

### in total emission reductions.

24 2012 emissions ≥ 50 tpy for any PM2.5

- related pollutant

### 44 Table 4

. 9 : Philadelphia CBSA 2002 Emissions and Rank

State County NH3 NOX PM25 SO2 VOC SUM SUM

Rank

DE New Castle 1940 29995 3920 50155 19917 105926 1

PA Philadelphia 1084 30595 2988 9508 35725 79900 2

PA Montgomery 1450 25686 3642 5171 29971 65920 3

PA Delaware 870 23699 2292 16028 17287 60175 4

PA Bucks 1774 19800 2881 3825 23218 51497 5

PA Chester 2521 18476 3075 5507 17853 47432 6

NJ Burlington 1524 17832 2102 3429 18599 43486 7

NJ Gloucester 1003 14106 1411 7169 16008 39696 8

NJ Camden 1207 14785 1461 1909 16352 35713 9

MD Cecil 530 4669 1019 640 6050 12908 11

Table 4

. 10 : Philadelphia CBSA 2011 Emissions and Rank

State County NH3 NOX PM25 SO2 VOC SUM Rank

PA Philadelphia 801 22394 2722 2788 17548 46254 1

PA Montgomery 779 17275 2508 2522 15308 38393 2

PA Delaware 595 17964 2579 6559 10166 37863 3

PA Bucks 1024 13277 1965 2040 15477 33783 4

DE New Castle 922 15866 2099 2383 11469 32739 5

PA Chester 1906 12177 2002 2178 10454 28717 6

NJ Burlington 556 8448 1405 525 9981 20915 7

NJ Camden 244 8660 1772 611 9203 20490 8

NJ Gloucester 362 8015 1113 1366 8940 19796 9

MD Cecil 651 3653 589 323 2788 8005 11

### 45 Table 4

. 11 : Philadelphia CBSA 2002

- 2011 Reductions and Rankings

State County NH3 NH3

Rank NOX NOX

Rank PM25 PM25

Rank SO2 SO2

Rank VOC VOC

Rank SUM SUM

Rank

DE New Castle 1018 1 14129 1 1821 1 47772 1 8448 4 73188 1

PA Philadelphia 283 8 8201 4 266 8 6720 3 18177 1 33646 2

PA Montgomery 671 5 8411 3 1134 2 2649 7 14663 2 27527 3

NJ Burlington 968 2 9384 2 697 5 2904 6 8618 3 22571 4

PA Delaware 275 9 5735 9

- 287 10 9469 2 7121 8 22313 5

NJ Gloucester 641 6 6091 8 298 7 5803 4 7068 9 19901 6

PA Chester 615 7 6299 6 1073 3 3329 5 7399 6 18715 7

PA Bucks 750 4 6523 5 916 4 1785 9 7741 5 17715 8

NJ Camden 963 3 6125 7

- 311 11 1298 10 7149 7 15224 9

MD Cecil

- 121 11 1016 11 430 6 317 11 3262 10 4903 11



### Figure 4

. 2 illustrates the emission reductions (“SUM”) from Table 4

. 11 , and it is important to note that

New Castle County obtained more than double the reductions than the next highest ranking County

– Philadelphia County

– and over three times more than Delaware County.

Figure 4

. 2 : Philadelphia CBSA 2002

- 2011 Reductions and Rankings

0 10000 20000 30000 40000 50000 60000 70000 80000tons per year

### 46 Table 4

. 12 shows the data in Table 4

. 11 in terms of percent reductions, with New Castle County being

number one with a 6 9 % reduction of PM2.5

- related pollutants. Again, it is noteworthy that the next

highest County (Philadelphia) has comparati ve 42% reductions , and the two nonattaining CBSA counties

of Chester and Delaware both have only 3 9 % and 37% reductions, respectively.

Table 4

. 12 : Philadelphia CBSA 2002

- 2011 Percent Reductions

State County NH3 NOX PM25 SO2 VOC SUM

DE New Castle 52% 47% 46% 95% 42% 69%

NJ Burlington 64% 53% 33% 85% 46% 52%

NJ Gloucester 64% 43% 21% 81% 44% 50%

NJ Camden 80% 41%

- 21% 68% 44% 43%

PA Philadelphia 26% 27% 9% 71% 51% 42%

PA Montgomery 46% 33% 31% 51% 49% 42%

PA Chester 24% 34% 35% 60% 41% 39%

MD Cecil

- 23% 22% 42% 49% 54% 38%

PA Delaware 32% 24%

- 13% 59% 41% 37%

PA Bucks 42% 33% 32% 47% 33% 34%

Figure 4.3 illustrates the data in Table 4

. 12

Figure 4

. 3 : Phila delphia CBSA 2002

- 2011 Percent Reductions

0% 10% 20% 30% 40% 50% 60% 70%

### 47 4.3.4 Philadelphia CBSA and CBSA+ 2002 and 2011 Emissions and Reductions

Table 4

. 13

, Table 4

. 14

, Table 4

. 15 , and Table 4

. 16 contain emissions data showing the Philadelphia

CBSA+ emissions in 2002 and 2011, along with the corresponding emission reductions

, ranki ngs and

percent reductions . As can be seen fr om tables, New Castle ranked 2 nd 

### of the 29 counties in total PM 2.5



### - related emissions during 2002. However , due to the significant control measures Delaware has

implemented since 2002, New Castle now ranks 1 0 th in total CBSA+ emissions, and again ranks 1st in

total emission reductions , as well as in terms of total percent reductions (out of 29 counties)

. This data

shows that Delaware has led the Philadelphia CBSA and surrounding counties in developing post

- 20 02

control measures

. As discussed in the next s ection, either EPA or Delaware has already regulated every

non

- trivial source with reasonable available control technology

.

Table 4

. 13 : Philadelphia CBSA + 2002 Emissions and Total Rank

State County FIPS NH3 NOX PM25 SO2 VOC SUM

Rank

PA York 42133 3862 37634 5647 82669 20079 149891 1

DE New Castle 10003 1940 29995 3920 50155 19917 105926 2

PA Northampton 42095 722 24212 3473 58764 10648 97819 3

PA Philadelphia 42101 1084 30595 2988 9508 35725 79900 4

PA Lancaster 42071 16400 19652 4529 3974 25647 70203 5

PA Berks 42011 4610 21748 3585 17595 19341 66880 6

PA Montgomery 42091 1450 25686 3642 5171 29971 65920 7

NJ Middlesex 34023 2032 25931 2193 2117 30993 63267 8

PA Delaware 42045 870 23699 2292 16028 17287 60175 9

NJ Mercer 34021 1012 24978 1369 15508 12719 55585 10

PA Bucks 42017 1774 19800 2881 3825 23218 51497 11

PA Chester 42029 2521 18476 3075 5507 17853 47432 12

NJ Monmouth 34025 1714 17316 1722 1670 24780 47200 13

NJ Burlington 34005 1524 17832 2102 3429 18599 43486 14

NJ Ocean 34029 1214 10120 2363 1074 27598 42369 15

NJ Gloucester 34015 1003 14106 1411 7169 16008 39696 16

NJ Camden 34007 1207 14785 1461 1909 16352 35713 17

PA Lehigh 42077 825 14203 1893 3764 13855 34541 18

NJ Somerset 34035 1100 9970 1732 637 15032 28472 19

NJ Atlantic 34001 832 8152 1080 885 15277 26226 20

DE Kent 10001 2191 10095 1228 4039 6384 23937 21

MD Harford 24025 980 8218 1738 1205 10200 22341 22

NJ Cumberland 34011 644 6865 927 3217 8077 19730 23

NJ Hunterdon 34019 962 6323 1270 613 9024 18193 24

NJ Salem 34033 656 6498 784 5452 4736 18127 25

NJ Warren 34041 706 5006 1119 565 7284 14679 26

MD Cecil 24015 530 4669 1019 640 6050 12908 27

MD Queen Anne's 24035 1550 2780 946 551 3864 9691 28

MD Kent 24029 719 1166 594 386 2356 5221 29

### 48 ** Bold font indicates those counties which are part of the Philadelphia CBSA



### Table 4

. 14 : Philadelphia CBSA+ 2011 Emissions and Rankings

State County FIPS NH3 NOX PM25 SO2 VOC SUM Rank

PA York County 42133 3495 33810 3758 26590 14024 81677 1

PA Lancaster 42071 15753 13881 4107 1802 13584 49127 2

PA Philadelphia 42101 801 22394 2722 2788 17548 46254 3

PA Northampton 42095 614 14074 2274 20024 5404 42390 4

PA Berks 42011 4095 14390 3023 6140 12848 40495 5

PA Montgomery 42091 779 17275 2508 2522 15308 38393 6

PA Delaware 42045 595 17964 2579 6559 10166 37863 7

NJ Middlesex 34023 526 14766 1843 771 16651 34558 8

PA Bucks 42017 1024 13277 1965 2040 15477 33783 9

DE New Castle 10003 922 15866 2099 2383 11469 32739 10

PA Chester 42029 1906 12177 2002 2178 10454 28717 11

NJ Monmouth 34025 740 10365 1307 670 12541 25624 12

NJ Ocean 34029 335 7972 1397 479 13185 23367 13

PA Lehigh 42077 620 8921 1398 1323 9748 22010 14

NJ Burlington 34005 556 8448 1405 525 9981 20915 15

NJ Camden 34007 244 8660 1772 611 9203 20490 16

NJ Gloucester 34015 362 8015 1113 1366 8940 19796 17

NJ Mercer 34021 254 7513 1260 948 7560 17535 18

DE Kent 10001 2462 5673 922 1839 4298 15193 19

NJ Somerset 34035 264 5960 665 241 7015 14145 20

NJ Atlantic 34001 241 4905 900 425 7062 13534 21

MD Harford 24025 495 6169 945 525 5163 13298 22

NJ Cumberland 34011 459 4078 1081 792 4888 11299 23

MD Cecil 24015 651 3653 589 323 2788 8005 24

NJ Salem 34033 708 3239 453 1405 2122 7926 25

NJ Hunterdon 34019 450 3446 434 328 3139 7797 26

MD Queen Anne's 24035 1897 2943 626 449 1727 7643 27

NJ Warren 34041 710 2622 521 328 3010 7192 28

MD Kent 24029 744 1026 487 204 1215 3675 29

** Bold font indicates those counties which are part of the Philadelphia CBSA

### 49 Table 4

. 15 : Philadelphia CB SA + 2002

- 2011 Emission Reductions and Rankings

State County FIPS NH3 NOX PM25 SO2 VOC SUM Rank

DE New Castle 10003 1018 14129 1821 47772 8448 73187 1

PA York 42133 367 3824 1889 56079 6055 68214 2

PA Northampton 42095 108 10138 1199 38740 5244 55429 3

NJ Mercer 34021 758 17465 109 14560 5159 38050 4

PA Philadelphia 42101 283 8201 266 6720 18177 33646 5

NJ Middlesex 34023 1506 11165 350 1346 14342 28709 6

PA Montgomery 42091 671 8411 1134 2649 14663 27527 7

PA Berks 42011 515 7358 562 11455 6493 26385 8

NJ Burlington 34005 968 9384 697 2904 8618 22571 9

PA Delaware 42045 275 5735

- 287 9469 7121 22312 10

NJ Monmouth 34025 974 6951 415 1000 12239 21576 11

PA Lancaster 42071 647 5771 422 2172 12063 21076 12

NJ Gloucester 34015 641 6091 298 5803 7068 19900 13

NJ Ocean 34029 879 2148 966 595 14413 19002 14

PA Chester 42029 615 6299 1073 3329 7399 18715 15

PA Bucks 42017 750 6523 916 1785 7741 17714 16

NJ Camden 34007 963 6125

- 311 1298 7149 15223 17

NJ Somerset 34035 836 4010 1067 396 8017 14327 18

NJ Atlantic 34001 591 3247 180 460 8215 12692 19

PA Lehigh 42077 205 5282 495 2441 4107 12531 20

NJ Hunterdon 34019 512 2877 836 285 5885 10396 21

NJ Salem 34033

- 52 3259 331 4047 2614 10201 22

MD Harford 24025 485 2049 793 680 5037 9043 23

DE Kent 10001

- 271 4422 306 2200 2086 8744 24

NJ Cumberland 34011 185 2787

- 154 2425 3189 8431 25

NJ Warren 34041

- 4 2384 598 237 4274 7487 26

MD Cecil 24015

- 121 1016 430 317 3262 4903 27

MD Queen Anne's 24035

- 347

- 163 320 102 2137 2048 28

MD Kent 24029

- 25 140 107 182 1141 1546 29

** Bold font indicates those counties which are part of the Philadelphia CBSA



### Table 4

. 16 : Philadelphia CBSA + 2002

- 2011 Percent Reductions and Rankings

State County FIPS NH3 NOX PM25 SO2 VOC SUM Rank

DE New Castle 10003 52% 47% 46% 95% 42% 69% 1

NJ Mercer 34021 75% 70% 8% 94% 41% 68% 2

NJ Hunterdon 34019 53% 46% 66% 46% 65% 57% 3

PA Northampton 42095 15% 42% 35% 66% 49% 57% 4

NJ Salem 34033

- 8% 50% 42% 74% 55% 56% 5

NJ Burlington 34005 64% 53% 33% 85% 46% 52% 6

NJ Warren 34041

- 1% 48% 53% 42% 59% 51% 7

NJ Somerset 34035 76% 40% 62% 62% 53% 50% 8

NJ Gloucester 34015 64% 43% 21% 81% 44% 50% 9

NJ Atlantic 34001 71% 40% 17% 52% 54% 48% 10

NJ Monmouth 34025 57% 40% 24% 60% 49% 46% 11

PA York 42133 10% 10% 33% 68% 30% 46% 12

NJ Middlesex 34023 74% 43% 16% 64% 46% 45% 13

### 50 State County FIPS NH3 NOX PM25 SO2 VOC SUM Rank

NJ Ocean 34029 72% 21% 41% 55% 52% 45% 14

NJ Cumberland 34011 29% 41%

- 17% 75% 39% 43% 15

NJ Camden 34007 80% 41%

- 21% 68% 44% 43% 16

PA Philadelphia 42101 26% 27% 9% 71% 51% 42% 17

PA Montgomery 42091 46% 33% 31% 51% 49% 42% 18

MD Harford 24025 49% 25% 46% 56% 49% 40% 19

PA Chester 42029 24% 34% 35% 60% 41% 39% 20

PA Berks 42011 11% 34% 16% 65% 34% 39% 21

MD Cecil 24015

- 23% 22% 42% 49% 54% 38% 22

PA Delaware 42045 32% 24%

- 13% 59% 41% 37% 23

DE Kent 10001

- 12% 44% 25% 54% 33% 37% 24

PA Lehigh 42077 25% 37% 26% 65% 30% 36% 25

PA Bucks 42017 42% 33% 32% 47% 33% 34% 26

PA Lancaster 42071 4% 29% 9% 55% 47% 30% 27

MD Kent 24029

- 3% 12% 18% 47% 48% 30% 28

MD Queen Anne's 24035

- 22%

- 6% 34% 19% 55% 21% 29

** Bold font indicates those counties which are part of the Philadelphia CBSA



### 4.4 Control Measure Analysis for PM 2.5 

### - Related Pollutants

Delaware’s 2011 NEI encompasses all emissions that could contribute to downwind areas. Delaware has

used this inventory for a control measure analysis. The sections that follow present Delaware ’s analyses

of federal and Delaware control measures on a pollutant

- by

- pollutant basis, demonstrating th at Delaware

has controlled emission sources causing local ambient PM 2.5 

### issues, and that may contribute to

nonattainment and/or maintenance areas downwind. The analysis includes every source for each pollutant

that is ≥ 25 tpy or ≥ 95% of all sources , and shows that all non

- trivial sources are already controlled

.

Including New Castle in a nonattainment area under CAA 107(d)(1) would result in no additional

emission reductions in New Castle County

.

4.4.1 Sulfur Dioxide (SO 2 

### )

Because sulfates were determined to be the largest contributor to PM 2.5 

### nonattainment in the northeast,

Delaware adopted and implemented SIP provisions that cover all SO 2 

### emitting sources and source

categories and all such emissions in Delaware are now well controlled.

In June 2013, Delaware submitted a technical support document to EPA, which presented a combination

of ambient monitoring data analysis and conservative source

- specific mo deling to support a designation

of attainment for the 2010 1

- hour SO 2 

### NAAQS for the entire state of Delaware. In summary, Delaware’s

SO 2 

### control efforts have focused primarily on requiring advanced SO 2 

### emission controls on its largest

point sources, and l owering the sulfur content of fuel used by all in

- state sources, e.g.:

• Recent amendments to 7 DE Admin. Code 1108 will reduce the sulfur limit for residual oil to

0.5%, statewide, for all source sectors.

• As of 12/31/2012, New Castle County ’s two coal

- fired EGUs, switched to natural gas, with one

using residual oil. SO 2 

### emission rates have been set at or below 0.26 lb/mmbtu since 2006 (7 DE

Admin. Code 1146).

### 51 • The allowable sulfur content of residual oil fired EGUs was reduced to an allowable level of 0.5%

in 2006 (7 DE Admin. Code 1146).

• The carbon monoxide (CO) boilers at the Delaware City Refinery, historically the largest SO 2 

### emitters in the state, were controlled with scrubbers in 2007/8 (Consent Decree).

• Distillate oil has been regulated statew ide at a level of 3000 ppm since 1971 (7 DE Admin. Code

1108), and recent amendments to this regulation effective 07/2013 reduce the allowable limit to 15

ppm.

These controls, along with federal on

- and

- off

- road fuel sulfur limits, have dramatically redu ced New

Castle’s SO 2 

### emissions inventory. Delaware’s first SO 2 

### SIP from 1970 indicates that statewide 1970 SO 2 

### emissions were 232,000 tons per year, and in 2011 they have been reduced to 14,273 tons (a 9 4 %

reduction). This indicates that Delaware’s SO 2 

### c ontrol strategy has been very effective. Appendix A,

Table 1 discusses the emission sources and federal and Delaware controls that have been impl emented for

those sources.

4.4.2 Oxides of Nitrogen (NOx)

Delaware has been nonattainment for the pollutant ozone since a standard was first established in 1971.

Over the past 40 years Delaware has learned that transport is very significant relative to ozone, and that

the only way to reduce ozone concentrations is to reduce the volatile organ ic compound (VOC) and

nitrogen oxides (NOx) emissions that are causing them. As discussed above, VOC and NOx are also

precursors to PM 2.5 

### . Over the last twenty years Delaware has adopted and implemented SIP provisions

that cover all NOx emitting sources and source categories, and all such emissions in Delaware are now

well controlled.

Appendix A, Table 2 demonstrates 1) that the Delaware SIP contains measures that cover every non

trivial NOx emitting source and source category in the State. Thus, Dela ware concludes that the

Delaware emissions that would contribute to nonattainment and maintenance in downwind areas are those

NOx emissions that are already reduced by the following adequate measures in Delaware’s SIP:

• Vehicle I/M requirements, which is o ne of the few cost effective means available to States to

significantly reduce on

- road mobile emissions (7 DE Admin. Code 1126 and 1136)

• RACT on all major NOx stationary sources, which establishes a baseline level of control and

achieves large, cost effect ive reductions (7 DE Admin. Code 1112 and 1125).

• BACT on all coal and residual oil fired EGUs, and large industrial boilers, which ensure the

largest emitters are well controlled (7 DE Admin. Code 1142 and 1146)

• BACT on all sources with high daily emission s, despite low annual emissions, which ensure all

emissions on high PM 2.5 

### days are controlled (7 DE Admin. Code 1144 and 1148.)

• Adoption of available regional measures to reduce emission from large non

- point source

categories (7 DE Admin. Code 1141, Sections 1, 2 and 4)

• Major and minor new source review, which ensures new units are well controlled (7 DE Admin.

Code 1125)

### 52 4.4.3 Direct PM 2.5



### Delaware has been nonattainment for the pollutant PM 2.5 

### since 2005 under the 1997 annual PM 2.5 

### NAAQS, and since 200 9 under the 2006 daily PM 2.5 

### NAAQS. In November, 2012 EPA proposed a rule

approving Delaware’s 2008 PM 2.5 

### Attainment Demonstration and a 2012 revision to that SIP to address

MOVES. 25 

### Since then, Delaware ’s monitors are showing attainment and Delaware has s ubmitted a

redesignation request and maintenance plan to EPA under the annual and daily PM 2.5 

### NAAQS. Appendix

A, Table 3 discusses the emission sources and federal and Delaware controls that have been impl eme nted

for those PM 2.5 

### sources.

4.4.4 Volatile Organic Compounds (VOC)

Delaware has been nonattainment for the pollutant ozone since a standard was first established in 1971.

Appendix A, Table 4 demonstrate s that the Delaware SIP contains measures that cover every non

- trivial

VOC emitting source and source category in the State. Thus, Delaware concludes that the Delaware

emissions that would contribute to nonattainment and maintenance in downwind areas are those VOC

emissions that are already significantly controlled by the following measures in Delaware’s S IP:

• Vehicle I/M requirements, which is one of the few cost effective means available to States to

significantly reduce on

- road mobile emissions (7 DE Admin. Code 1126 and 1136)

• RACT on all major NOx and VOC stationary sources, which establishes a baseline level of control

and achieves large, cost effective reductions (7 DE Admin. Code 1112 and 1125).

• BACT on all coal and residual oil fired EGUs, and large industrial boilers, which ensure the

largest emitters are well controlled (7 DE Admin. Code 1142 and 1 146)

• BACT on all sources with high daily emissions, despite low annual emissions, which ensure all

emissions on high PM 2.5 

### days are controlled (7 DE Admin. Code 1144 and 1148.)

• Adoption of available regional measures to reduce emission from large non

- point source

categories (7 DE Admin. Code 1141, Sections 1, 2 and 4)

• Adopting all federal Control Techniques Guidelines (CTGs) or issuance of a negative declaration

• Major and minor new source review, w hich ensures new units are well

- controlled (7 DE Admin.

Code 1125)

• VOC Control Measures on numerous area sources (7 DE Admin. Code 1124)

4.4.5 Ammonia (NH 3 

### )

Due to the lack of quality emission factors

, effective control measures and relatively low emissions in

New Castle County , Delaware has not focused on controlling ammonia emissions. Nonetheless, 2011

emissions of ammonia have decreased 1,018 tpy from 2002 levels (1,940 vs. 922 ), or a 52 percent

reduction. Appendix A, Table 5 discusses Delaware ’s ammonia analysis.

25 The Homer vs. EPA ruling has held up final approval of this SIP but DNREC and EPA expect it to be approved.

### 53 4.5 Summary of Emissions and Control Measure Analysis

The previous discussions in Section 4 , as well as Appendix A demonstrate that :

1. the Delaware SIP contains measures that cover every non

- trivial PM 2.5



### - related pollutant emitting

source and source category in the State, and

2. that implemen tation of these measures has resulted in significant emission reductions in New

Castle County (and Delaware has achieved more reductions than any other county since 2002)

Thus, Delaware concludes based on this analysis of emissions and emissions related data that no part of

Delaware should be designated as nonattainment due to the air quality in any nearby area.

5 GEOGRAPHY/TOPOGRAPHY

Not applicable to Delaware and surrounding counties. The terrain is relatively flat.

6 JURISDICTIONAL BOUND ARIES

All of New Castle Count y’s air quality management is under the jurisdictional authority of the State of

Delaware. Air quality issues are handled by a single agency, the Delaware Department of Natural

Resources and Environmental Control.

Delaware does not participate as a member of Delaware Valley Regional Planning Commission, which

serves PA and NJ mobile planning efforts. As such, there have been no coordinated planning efforts for

mobile control measures between Delaware, NJ and PA for PM 2.5 

### . Mobil e source controls are planned

and implemented exclusively through DNREC, DELDOT and the Kent and Wilmington Area Planning

Councils. In addition, since 2002 when Delaware was first designated nonattainment under the 1997

annual NAAQS, no coordination of co ntrol measures occurred between Delaware and Pennsylvania for

the other sources sectors (this included ozone control coordination as well). Furthermore, given that New

Castle County ambient concentrations are well below the 2012 annual standard, DNREC do es not foresee

any multi

- jurisdictional controls as a viable option. And finally, Delaware believes that 1) since the

violations in PA appear to be highly influence by local emissions, and 2) the dominant boundary is the

state lines and not the CBSA, then 3) it is impractical for Delaware to coordinate with PA on their local

control measures

, in order to bring PA violating monitors into attainment (e.g. Delaware has no influence

on PA’s regulation determinations ).

Designating New Castle County as a stand

- alone attainment area, separate from the Philadelphia CBSA,

will continue to simplify administrative and legal authorities relative to nonattainment requirements.

Delaware will continue to actively interact with EPA and the regional planning organizations (OTC,

MANEVU).

### 54 7 CONCLUSIONS

• All of Delaware’s monitors are recording PM 2.5 

### concentrations that are significantly below the

2012 NAAQS

. In the Philadelphia CBSA, only Delaware and Chester Counties in Pennsylvania

are monitoring concentrations that are above the 2012 NAAQS

.

• A mbient air quality analysis indicates that the nearby sites in Pennsylvania currently exceeding the

annual average PM 2.5 

### NAAQS are not representative of air quality in New Castle County,

Delaware, and the air quality analysis supports not associating any part of Delaware with those

two areas for the following reasons.

o The New Garden site in Chester County data is typical of a site dominated by regional

transport as shown by the seasonal and annual trends analysis . The chang e in monitoring

method from the FRM to an FEM appears to have introduced a high bias into recent design

values. Returning that site to the FRM appears to be returning data from that site to trends

that are expected, and that follow the trends of other sit es within the Philadelphia CBSA

that are below the annual average NAAQS.

o The Chester site in Delaware County is significantly impacted by local sources as shown

by ambient air quality trends and seasonal patterns, evaluation of high concentration days,

sp eciation data analysis (SANDWICH and urban excess calculations) , and emissions vs.

distance . The Chester site is therefore not representative of the larger Philadelphia CBSA.

Examination of the specific site characteristics also indicates high potential for nearby

source impact. The Chester monitor is located within the fence line of a point source which

manufactures sodium silicate and is also installed in an unpaved area.

• Analysis of t hree years of meteorology indicates that while both Delaware’s MLK monitor and

Pennsylvania’s Chester monitor are impacted by regional sources, the Chester monitor is impacted

more by local sources when compared to the MLK monitor.

• In 20 02 , New Castle Count y’s total PM 2.5



### - related pollutant emissions were ranked 1 st 

### in the

CBSA . In 2011 New Castle ranked 5 th 

### in the CBSA

– with approximately 5,000 tpy less than

Delaware County’s total PM2.5

- related emissions.

• Although New Castle’s emissions are only two ranks below only two ranks below Delaware

County, the closest DE monitor to the Chester monitor in Delaware County is Bellefonte (~8 mi.),

with a 2010

- 2012 DV of only 9.8 μg/m 3 

### . This is significantly less than the Chester DV (13.1

μg/m 3 

### ), leading Delaware to conclude local emissions play a major role in violations at the Chester

monitor.

• Based on population vs. DVs over the years, Delaware believes population is not suitable as a tool

in making boundary determinations for New Castle County because they are in fact inversely

related

. Since increase d VMT and commuting are related to population, and Delaware statewide

VMT does not correlate with air quality data, it also follows that these parameters should not be

used in boundary designations. Also, r elative to 2002 vehicle miles traveled (VMT), New Castle

2010 VMT gro wth was negative 3 %, the 18 th 

### l owest growth rate in the CBSA+ and ranked 8 th 

### in

the CBSA.

### 55 • T otal 2012 emissions of direct PM 2.5 

### and its precursors from Delaware’s largest point sources

decreased 87% between 2002 and 2012. This included a massive 99% reduc tion in SO 2 

### , followed

by a 65% reduction in direct PM 2.5 

### , and NOx with a 52% decrease. VOC reductions of 54% have

been taking place since the early 1990s due to Delaware’s ozone nonattainment issues over the

years. Although NH 3 

### has been reduced around 52%, this is still a significant reduction , since total

New Castle County 2002 point source emissions were only 82 tons per year (tpy).

• Based on 2002 emission inventories, New Castle ranked as the highest emitter in the Philadel phia

CBSA of all PM 2.5



### - related pollutants

. However, d ue to the significant control measures Delaware

has implemented since 2002, New Castle now ranks the highest in total emission reductions

, both for the CBSA and CBSA+

.

• In terms of percent reductions between 2002 and 2011 in the CBSA , New Castle County is

number one with a 69 % overall reduction of PM 2.5



### - related pollutants. T he 2 nd 

### ranking County has

a 5 2% overall reduction , and the two nonattaining counties Chester and Delaware ha ve 39 % and

37% reduc tions, respectively. This demonstrates that Delaware emission sources are well

controlled

.

Based on this analysis Delaware concludes that the air quality in all of Delaware is below the 2012

NAAQS, and that emissions from Delaware do not contribut e to violations of the NAAQS in any nearby

area, and that no part of Delaware, including New Castle County, should be designated as nonattainment

under CAA 107(d).APPENDIX ACONTROL MEASURE ANALYSISFOR PM2.5-RELATED POLLUTANTS2Table 1: SO2Emission and Control Analysis –NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY % of 2011 NEIDescription of Federal Control Measures andMeasures in Delaware's SIP Potential Additional Control MeasuresCommercial Marine Vessels(primarily in-transit emissions fromresidual oil combustion)972 40.8% Commercial Marine Vessels include ocean-goingships and other large craft.This category is subject toapplicable federal measures such as the EPA C-3Marine Engine Rule, and the Emission Control Areasestablished by the IMO, which require usage of≤10,000 ppm sulfur residual fuel beginning in 2011,and≤1,000 ppm beginning in 2017.Delaware has limited authority under the CAAto regulate off-road mobile sources.Commercial/Industrial/ResidentialCombustion fired on Oil441 18.5% The commercial/institutional fuel combustioncategory includes small boilers, furnaces, heaters, andother heating units too small to be considered pointsources. The commercial/institutional sector includeswholesale and retail businesses; health institutions;social and educational institutions; and federal, state,and local governments (i.e., prisons, office buildings)and are defined by SIC codes 50-99. The fuel typesincluded in this source category are coal (SCC2103002000), distillate oil (SCC 2103004000),residual oil (SCC 2103005000), natural gas (SCC2103006000), and liquefied petroleum gas (LPG)(SCC 2103007000). Uses of distillate oil andkerosene include space and water heating.Emissions in this category are from many small unitsthroughout the State.Recent amendments to 7DE Admin. Code 1108reduced the sulfur limit for residual oil to 0.5%,statewide, for all source sectors.Distillate oil has been regulated statewide at a level of3,000 ppm since 1971 (7 DE Admin. Code 1108), andrecent amendments to this regulation reduced theallowable limit to 15 ppm.This source category is well controlled by thestringent allowable sulfur content limits in 7DE Admin. Code 1108. No economicallyfeasible additional control measures have beenidentified.3Table 1: SO2Emission and Control Analysis –NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY % of 2011 NEIDescription of Federal Control Measures andMeasures in Delaware's SIP Potential Additional Control MeasuresDelaware City Refinery (Premcor)333 14.0% The main SO2emission sources at the refinery are theCoker and Cracker CO boilers. Both of these unitsare well controlled with scrubbers that were installedunder a federal consent decree. 2005 emissions fromthese two units were > 29,000 tpy, and 2012emissions were less than 304 tpy.No strategies have been identified to furtherreduce SO2emissions from the refinery.DuPont Experimental Station248 10.4% This facility has four (4) residual oil fired boilers andone (1) gas fired boiler, all rated at 96 mmBTU/hreach.All four oil fired boilers are currently permitted to useresidual oil with a sulfur content not to exceed 0.5%.DuPont Experimental Station is currently paying forthe installation of a natural gas line to the facility,after which all boilers will operate using natural gas.The goal is to have all boilers converted to natural gasby mid-2017.No strategies have been identified to furtherreduce SO2emissions from this facility.Calpine - Edge Moor (Conectiv)83 3.5% This facility is a power plant that consists of threegas/oil fired EGUs. (i.e., 86 MW, 174 MW, and 450MW).All of Delaware EGUs 25MW and greater are subjectto 7 DE Admin. Code 1146, Electric Generating Unit(EGU) Multi-Pollutant Regulation. 1146 limits SO2emissions fromoil fired EGUs to a rate resulting fromcombusting 0.5% sulfur oil.Unit 3 fires gas as a primary fuel, with oil as abackup. Unit 3 has taken permit (permit AQM003/00007) conditions that include a restriction on theannual total hours of operation on residual fuel oil (nogreater than 876 hrs/yr) and a restriction on totalannual operating hours tonot exceed 59% capacityNo additional economically feasible SO2control measures have been identified.4Table 1: SO2Emission and Control Analysis –NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY % of 2011 NEIDescription of Federal Control Measures andMeasures in Delaware's SIP Potential Additional Control Measuresfactor. The 0.5% sulfur in fuel limit of 7 DE AdminCode 1146 and these operating limits effectively capthe annual SO2mass emissions levels below thoseincluded in 7 DE Admin Code 1146.Unit 4 fires gas as a primary fuel, with oil as abackup. Unit 4 has taken permit (permit AQM003/00007) conditions that include a restriction on theannual total hours of operation on residual fuel oil (nogreater than 876 hrs/yr) and a restriction on totalannual operating hours tonot exceed 59% capacityfactor. The 0.5% sulfur in fuel limit of 7 DE AdminCode 1146 and these operating limits effectively capthe annual SO2mass emissions levels below thoseincluded in 7 DE Admin Code 1146.Unit 5, using residual fuel oil as primary fuel, issubject to the 0.5% sulfur in fuel limit of 7 DE AdminCode 1146, and the associated annual SO2massemissions cap.DuPont - Chestnut Run67 2.8% SO2emissions are from a 48 mmbtu/hr boiler and a 96mmbtu/hr boiler. Both boilers converted to gas in2011, and are no longer allowed to fire oil. The firingof gas itself ensures these units are well controlled forSO2.No additional strategies have been identified tofurther reduce SO2emissions from this facility.5Table 1: SO2Emission and Control Analysis –NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY % of 2011 NEIDescription of Federal Control Measures andMeasures in Delaware's SIP Potential Additional Control MeasuresOn-Road Mobile48 2.0% New vehicles must meet California vehicle emissionstandards (CA LEV 3) under 7 DE Admin. Code1140.New and existing vehicles must be maintained underDelaware’s vehicle Inspection and Maintenanceprogram, 7 DE Admin. Code 1126 and 1131.Extended idling of heavy duty vehicles is prohibitedunder 7 DE Admin Code 1145.EPA 2007 Heavy-Duty Highway Rule (40 CFR Part86, Subpart P) limits the sulfur content in on-roaddiesel to 15ppm.No additional strategies have been identified tofurther reduce SO2emissions from this sourcecategory.DuPont - Red Lion46 1.9% This facility is a Sulfuric Acid Plant. The emissionsfrom this facility are primarily from the flare. Theflare is the control device, and at this time noreasonable control measures to reduce flaredemissions have been identified.No additional strategies have been identified tofurther reduce SO2emissions from this facility.Evraz Claymont Steel42 1.8% This facility ceased operations beginning December,2013.Not ApplicableTotal - categories covering all 2011NEI sources that emit more than25 TPY and≥95% of SO22280 95.7%Total - all other 2011 NEI facilitiesand source categories not includedabove102 4.3% This SO2quantity also includes many combustionturbines and diesel generators with very low TPYemissions. These units’ fuel sulfur limits areregulated under 7 DE Admin. Code 1108.Total 2011 AnthropogenicEmissions (TPY)2,383 100%6Table 2: NOx Emission and Control Analysis – NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY% of2011 NEIDescription of Federal Control Measures andMeasures in Delaware's SIP Potential Additional Control MeasuresOn-Road Mobile7,495 47.2% New vehicles must meet California vehicle emissionstandards (CA LEV 3) under 7 DE Admin. Code1140.New and existing vehicles must be maintained underDelaware’s vehicle Inspection and Maintenanceprogram, 7 DE Admin. Code 1126 and 1131.Extended idling of heavy duty vehicles is prohibitedunder 7 DE Admin Code 1145.Overall on-road mobile NOx emissions are capped ineach of Delaware’s three counties by ozone SIPbudgets, which are managed under 7 DE Admin.Code 1132, transportation conformity.Delaware has no authority under the CAA tofurther regulate tailpipe emissions.Aside from I/M program upgrades, all otheridentified measures are in the form oftransportation control measures (TCMs), whichgenerally gain small incremental reductions(i.e., on the order of tons per year, not hundredsof tons per year), and that have a $/ton cost of$50,000 to over $1 million.Commercial Marine Vessels2,256 14.2% Commercial Marine Vessels include ocean-goingships and other large craft.This category is subject toapplicable federal measures such as the EPA C-3Marine Engine Rule, which specifically regulatesNOx emissions from new engines.Delaware has limited authority under the CAAto regulate off-road mobile sources.Non-Road equipment1,659 10.5% These categories aresubject to applicable federalmeasures only.Delaware has limited authority under the CAAto regulate off-road mobile sources.Delaware, as part of the Ozone TransportCommission (OTC), is currently evaluating thefeasibility of an off-road anti-idling regulation.Other potential measures include programssuch as lawn-mower trade-in programs whichgenerally gain small incremental reductions(i.e., on the order of tenths of a ton to severaltons per year), and that have a $/ton cost of7Table 2: NOx Emission and Control Analysis – NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY% of2011 NEIDescription of Federal Control Measures andMeasures in Delaware's SIP Potential Additional Control Measures$50,000 to over $1 million.Commercial/Industrial/Residential Combustion fired onGas1,177 7.4% The commercial/institutional fuel combustioncategory includes small boilers, furnaces, heaters, andother heating units too small to be considered pointsources. The commercial/institutional sector includeswholesale and retail businesses; health institutions;social and educational institutions; and federal, state,and local governments (i.e., prisons, office buildings)and are defined by SIC codes 50-99. The fuel typesincluded in this source category are coal (SCC2103002000), distillate oil (SCC 2103004000),residual oil (SCC 2103005000), natural gas (SCC2103006000), and liquefied petroleum gas (LPG)(SCC 2103007000). Uses of natural gas and LPG inthis sector include space heating, water heating, andcooking. Uses of distillate oil and kerosene includespace and water heating.Emissions in this category are from many small unitsthroughout the State, where facility-wide NOxemissions are generally less than 25 TPY (i.e., thosenot covered in the point source inventory).7 DE Admin Code 1112 requires the control of NOxemissions from fuel burning equipment. Under 1112,units with maximum rated heat input capacities equalto or larger than 50 MMBtu/hr must be controlled byinstallation of either low excess air and low NOxburner technology or flue gas recirculationtechnology. Units between 15 and 50 MMBtu/hrmust receive an annual tune up performed byqualified personnel to minimize NOx emissions.Most commercial/institutional combustion units aresubject to the annual tune-up requirements, or are lessthan 15MMBtu/hr and are exempt from therequirements of 1112.Additional control measures for this categoryare possible. 7 DE Admin. Code 1112 couldbe revised to achieve some additional NOxreductions:1112 could be revised such that it isapplicable to combustion units at facilitieswith the potential to emit less than majorthresholds; and the low-end exemption of1112 could be revised from 15MMBTU/hrto 5MMBTU/hr. Covered units would bepredominately small units subject toannual tune-ups, and a NOx reduction ofabout 5% from eachsubject unit.1112 could be revised to require boilers inthe 25 MMBTU/hr – 50 MMBTU/hr sizerange to install either low excess air andlow NOxburnertechnology or flue gasrecirculation technology. This wouldreduce NOx by up to50% for each subjectunitOther measures could likely be identified atsimilar reductions and cost effectiveness.Given the high control costs, and the largenumber of very small sources in this category,this category is best regulated through turnoverof equipment (Note that section 4.0 of 7 DEAdmin. Code 1125 requires BACT for any newsource that emits greater than 5 TPY of NOx).8Table 2: NOx Emission and Control Analysis – NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY% of2011 NEIDescription of Federal Control Measures andMeasures in Delaware's SIP Potential Additional Control MeasuresDelaware City Refinery1,072 6.8% The Delaware City Refinery is a petroleum refinery.NOx emissions are controlled under 7 DE AdminCode 1112 (NOx RACT), and also under a NOxcap/PAL established pursuant to Section 2.0 of 7 DEAdmin Code 1142 and 1125. The NOx cap began in2011 at 2,525 TPY (i.e., actual 2008 emission levels),and decreases to 1,650 TPY beginning 2015.Delaware’s March 15, 2011 SIP revision,“Demonstration that Amendments to Section 2.0 of 7DE Admin Code 1142,Control of NOxEmissions fromIndustrial Boilers and Process Heaters at PetroleumRefineriesDo not Interfere with Any ApplicableRequirement of the Clean Air Act” provides a detaileddiscussion of the facility-wide NOx cap.The following information demonstrates thestringency of the facility-wide NOx cap:Thirteen of the refinery’s industrial boilers weresubject to the EPA NOx SIP Call, which wasimplemented in Delaware under 7 DE AdminCode 1139.The initial 2,525 TPY NOx cap is significantlyless than the annualized NOx SIP Call cap1, 3,333TPY, which indicates that implementation ofRACT and NSR at the refinery have resulted inthe implementation of NOx controls at therefinery.The 1,650 TPY NOx cap represents a 35%Delaware concludes that it is not feasible tolower the NOx cap at this time, and noadditional control measures have beenidentified that would significantly reduce NOxlevels below the refinery NOx cap.1The referenced SIP revision includes a demonstration that the refinery emissions are uniform across the year, and regulation on a TPY basis and not on an ozone seasonbasis is acceptable. Based on this the 1139 budgets were annualized by multiplying by 12/5.9Table 2: NOx Emission and Control Analysis – NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY% of2011 NEIDescription of Federal Control Measures andMeasures in Delaware's SIP Potential Additional Control Measuresreduction beyond RACT limits (i.e., actual 2008levels), and more than an additional 50%reduction below NOx SIP Call levels. Inaddition, all future growth at the refinery mustoccur under this NOx cap.Calpine - Hay Road (Conectiv)602 3.8% This facility is a power plant that consists of sixcombined cycle gas-fired (oil backup) EGUs.Units 1-3 are subject to 7 DE Admin Code 1112 (NOxRACT) limits of 25 to 88 ppm, 1-hour average,depending on fuel and firing mode. Units 5-7 aresubject to 7 DE Admin. Code 1112, plus they arecontrolled by SCR as required by 7 DE Admin. Code1125 (NOx LAER plus offsets).SCR is the most effective commerciallyavailable NOx emission control technologycommercially available for combustion turbineand combined cycle electric generating unitssuch as those installed at Hay Road.Hay Road units 5, 6 and 7 already incorporateSCR.It is technically feasible to retrofit SCR on theHay Road units 1, 2, and 3 that do notpresently incorporate SCR. Assuming a 10-year life and using the 2011 annual heat input,it is estimated that the incremental cost ofreducing NOx for Hay Road units 1, 2, and 3collectively is approximately $8,800 perincremental ton of NOx reduced. This wouldreduce NOx mass emissions by approximately72% (or 433 TPY based on actual 2011 data).Calpine - Edge Moor (Conectiv)346 2.2% This facility is a power plant that consists of threegas/oil fired EGUs. (i.e., 86 MW, 174 MW, and 450MW).NOx emissions are regulated under 7 DE Admin Code1112, NOx RACT, and 7 DE Admin Code 1146Electric Generating Unit (EGU) Multi-PollutantRegulation. All units complied with 1112 through theinstallation of low NOx burners. 1146 imposes both aunit specific annual NOx cap, and a 0.125lb/MMBTU emission limitation, demonstrated on aSCR is the most effective commerciallyavailable NOx emissions control technologyfor a gas/oil fired steam generating units suchas these at the Calpine-Edge Moor facility.Additional control is possible by replacing theexisting low NOx burner and SNCRtechnology with SCR technology on each ofthe following two EGUs:10Table 2: NOx Emission and Control Analysis – NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY% of2011 NEIDescription of Federal Control Measures andMeasures in Delaware's SIP Potential Additional Control Measuresrolling 24-hour average basis.Unit 3 fires gas as a primary fuel, with oil as abackup. Unit 3 NOx emissions are controlled by:low-NOx burners, overfire air, and SNCR. Unit 3 hastaken permit (permit AQM-003/00007) conditionsthat include a restriction on the annual total hours ofoperation on residual fuel oil (no greater than 876hrs/yr) and a restriction on total annual operatinghours to not exceed 59% capacity factor. The use ofgas as a primary fuel, and the 0.125 lb/MMBTU limitof 7 DE Admin Code 1146 and these operating limitseffectively cap the annual NOx mass emissions levelsbelow those included in 7 DE Admin Code 1146.Unit 4 fires gas as a primary fuel, with oil as abackup. Unit 4 has taken permit (permit AQM003/00007) conditions that include a restriction on theannual total hours of operation on residual fuel oil (nogreater than 876 hrs/yr) and a restriction on totalannual operating hours tonot exceed 59% capacityfactor. The use of gas as a primary fuel, and the0.125 lb/MMBTU limit of 7 DE Admin Code 1146and these operating limitseffectively cap the annualNOx mass emissions levels below those included in 7DE Admin Code 1146.Unit 5’s primary fuel is residual fuel oil, andincorporates low-NOx burners, overfire air, andSNCR for NOx emissions rate reduction. Unit 5 issubject to the 0.125 lb/MMBTU limit of 7 DE AdminCode 1146 and the associated annual NOx mass capin 7 DE Admin Code 1146.Unit 3: The estimated incremental cost ofreducing the NOx emission rate lower thanthe unit’s 2011 annual average value(assuming a 10 year life, using the 2011annual heat input, and using a 0.04lb/MMBTU attainable NOx emissions ratebasement) is $26,348 per incremental tonof NOx reduced. This would reduce massemissions by 32% (37 TPY based onactual 2011 data).Unit 4: The estimated incremental cost ofreducing the NOx emission rate lower thanthe unit’s 2011 annual average value(assuming a 10 year life, using the 2011annual heat input, and using a 0.04lb/MMBTU attainable NOx emissions ratebasement) is $37,277 per incremental tonof NOx reduced. This would reduce massemissions by 57% (50 TPY based onactual 2011 data).11Table 2: NOx Emission and Control Analysis – NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY% of2011 NEIDescription of Federal Control Measures andMeasures in Delaware's SIP Potential Additional Control MeasuresLocomotives272 1.7% These categories are subject to applicable federalmeasures only.Delaware has limited authority under the CAAto regulate off-road mobile sources.DuPont Experimental Station180 1.1% This facility has four (4) residual oil fired boilers andone gas fired boiler, each rated at 96 mmBTU/hr each.Each boiler is equipped with low NOx burner and lowexcess air technology under 7 DE Admin Code 1112(NOx RACT).DuPont Experimental Station is currently paying forthe installation of a natural gas line to the facility,after which all boilers will operate using natural gas.The goal is to have all boilers converted to natural gasby mid-2017.SNCR and SCR are technically feasible postcombustion NOx reduction technologiesapplicable to gas-fired boilers. Incrementalcosts would be relatively high for these gasboilers.Commercial/Industrial/Residential Combustion fired onOil175 1.1% The commercial/institutional fuel combustioncategory includes small boilers, furnaces, heaters, andother heating units too small to be considered pointsources. The commercial/institutional sector includeswholesale and retail businesses; health institutions;social and educational institutions; and federal, state,and local governments (i.e., prisons, office buildings)and are defined by SIC codes 50-99. The fuel typesincluded in this source category are coal (SCC2103002000), distillate oil (SCC 2103004000),residual oil (SCC 2103005000), natural gas (SCC2103006000), and liquefied petroleum gas (LPG)(SCC 2103007000). Uses of natural gas and LPG inthis sector include space heating, water heating, andcooking. Uses of distillate oil and kerosene includespace and water heating.Emissions in this category are from many small unitsAdditional control measures for this categoryare possible. 7 DE Admin. Code 1112 couldbe revised to achieve some additional NOxreductions:1112 could be revised such that it isapplicable to combustion units at facilitieswith the potential to emit less than majorthresholds; and the low-end exemption of1112 could be revised from 15MMBTU/hrto 5MMBTU/hr. Covered units would bepredominately small units subject toannual tune-ups, and a NOx reduction ofabout 5% from eachsubject unit.1112 could be revised to require boilers inthe 25 MMBTU/hr – 50 MMBTU/hr sizerange to install low excess air and lowNOxburnertechnology or flue gas12Table 2: NOx Emission and Control Analysis – NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY% of2011 NEIDescription of Federal Control Measures andMeasures in Delaware's SIP Potential Additional Control Measuresthroughout the State, where facility-wide NOxemissions are generally less than 25 TPY (i.e., thosenot covered in the point source inventory).Most commercial/institutional combustion units aresubject to the annual tune-up requirements, or are lessthan 15MMBtu/hr and are exempt from therequirements of 1112.recirculation technology. This wouldreduce NOx by up to50% for each subjectunit. Other measures could likely beidentified at similar reductions and costeffectiveness.Given the high control costs, and the largenumber of very small sources in this category,this category is best regulated through turnoverof equipment (Note that section 4.0 of 7 DEAdmin. Code 1125 requires BACT for any newsource that emits greater than 5 TPY of NOx).Evraz Claymont Steel166 1.0% This facility ceased operations beginning December,2013.Not ApplicableResidential Wood Combustion60 0.4% This category is regulated under 40 C.F.R. Part 60Subpart AAA New Source Performance Standards(“NSPS”)No economically feasible NOx emissioncontrol strategies for this source category havebeen identified.Sunoco54 0.3% This facility was subject to 7 DE Admin. Code 1112(NOx RACT). It was subject to beyond-RACT NOxcontrol under Section 1 of 7 DE Admin. Code 1142.The facility is now shutdown.DuPont - Chestnut Run48 0.3% 48 mmbtu/hr boiler subject to annual tune-up tominimize NOx emission under 7 DE Admin Code1112 (NOx RACT).96 mmbtu/hr boiler equipped with low NOx burnerand low excess air technology under 7 DE AdminCode 1112 (NOx RACT).All boilers at this facility converted to gas in 2011,and are no longer allowedto fire oil.SNCR and SCR are technically feasible postcombustion NOx reduction technologiesapplicable to oil fired boilers. Incrementalcosts would be relatively high for these gasfired boilers.13Table 2: NOx Emission and Control Analysis – NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY% of2011 NEIDescription of Federal Control Measures andMeasures in Delaware's SIP Potential Additional Control MeasuresFormosa Plastics32 0.2% This facility produces vinyl chloride monomer.NOx emissions are froma 30 and a 40 mmBTU/hrboiler, subject to annual tune-up requirements tominimize NOx emissions under 7 DE Admin Code1112 (NOx RACT).SNCR and SCR are technically feasible postcombustion NOx reduction technologiesapplicable to oil and gas fired boilers.The estimated costeffectiveness forretrofit of SNCR onthese boilers rangesfrom $5,540 per incremental ton of NOxreduction to $19,450 per incremental tonof NOx reduction to achieve an overallreduction of 40% in NOx emissions.The estimated costeffectiveness forretrofit of SCR on these boilers rangesfrom $12,100 per incremental ton of NOxreduction to $15,900 per incremental tonof NOx reduction to achieve an overallreduction of 80% in NOx emissions.Given that these units are already controlled,and that emissions are projected to continue tobe low in the future, additional control beyondRACT is not warranted.FMC31 0.2% NOx emissions from two 25 mmBTU/hr boilers andthree small spray dryers. Annual tune-ups tominimize NOx emissions on all NOx emitting units isrequired by 7 DE Admin. Code 1112 (NOx RACT).No control measures to further reduce emissionfrom this facility have been identified.Given that these units are already controlled,and that emissions are projected to continue tobe low in the future, additional control beyondRACT is not warranted.14Table 2: NOx Emission and Control Analysis – NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY% of2011 NEIDescription of Federal Control Measures andMeasures in Delaware's SIP Potential Additional Control MeasuresDuPont - Edge Moor27 0.2% NOx emissions are from small (<50 mmBTU/hr)combustion units, which are subject to annual tune-uprequirements to minimize NOx under 7 DE AdminCode 1112 (NOx RACT).No control measures to further reduce emissionfrom this facility have been identified.Given that these units are already controlled,and that emissions are projected to continue tobe low in the future, additional control beyondRACT is not warrantedTotal - categories covering all2011 NEI sources that emit morethan 25 TPY and≥95% of NOx.15,654 98.7%Total - all other 2011 NEI facilitiesand source categories not includedabove.212 1.3% Many of these small sources are also controlled underthe measures in Delaware's SIP. This includes smallsources covered by 7 DE Admin. Code 1112, 1144and 1148.Total 2011 AnthropogenicEmissions (TPY)15,866 10015Table 3: PM2.5Emission and Control Analysis – NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY% of2011 NEIDescription of Federal Control Measures andControl Measures in Delaware's SIP Potential Additional Control MeasuresResidential Wood Combustion521 20.8% This category is regulated under 40 C.F.R. Part 60Subpart AAA New Source Performance Standards(“NSPS”) and 7 DE Admin. Code 1114 and 7 DEAdmin. Code 1114, Visible Emissions.The NSPS covers new wood stoves only. Apotential additional measure is the adoption of awood stove change-out program. Based on astudy done by New Hampshire DES2, the cost oftheir change-out program was $35,250- 47,000 perton of PM2.5reduced, and which realized 3-4 tpyreductions of PM2.5.Paved Road Dust408 16.3% This is an on-road category and no reasonablemeasures have been identified to reduce theseemissions. Delaware does not regulate thiscategory in its SIP. Note: these emissions do nottake into account the transport fraction.NoneDelaware City Refinery(Premcor)281 11.2% The main PM2.5emission sources at the refineryare the Coker and Catalytic Cracker CO boilers.Both of these units are well controlled withscrubbers that were installed under a federalconsent decree. 2002 emissions from these twounits were 1,241 tpy and total 2012 PM2.5from theentire refinery was 312 TPY.No economically feasible additional controlmeasures have been identified to further reducePM2.5emissions from the refinery.On-road Mobile241 9.6%New vehicles must meet California vehicle emissionstandards (CA LEV 3) under 7 DE Admin. Code1140.New and existing vehicles must be maintainedunder Delaware’s vehicle Inspection andMaintenance program, 7 DE Admin. Code 1126 and1131.Extended idling of heavy duty vehicles is prohibitedunder 7 DE Admin Code 1145.Delaware has no authority under the CAA tofurther regulate tailpipe emissions.Aside from I/M program upgrades, all otheridentified measures are in the form oftransportation control measures (TCMs), whichgenerally gain small incremental reductions (i.e.,on the order of tons per year, not hundreds of tonsper year), and that have a $/ton cost of $50,000 toover $1 million.2Keene Woodstove Changeout Campaign 2009-2010, Final Report. New Hampshire Department of Environmental Services, September 2010. .16Table 3: PM2.5Emission and Control Analysis – NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY% of2011 NEIDescription of Federal Control Measures andControl Measures in Delaware's SIP Potential Additional Control MeasuresOverall on-road mobile emissions are capped inNew Castle County by PM2.5SIP budgets, whichare managed under 7 DE Admin. Code 1132,transportation conformity.Construction Dust (road,residential and commercial)174 6.9% Delaware Admin Code 1106 - ParticulateEmissions from Construction and MaterialsHandling (effective 2/01/1981, administrativelyrevised 9/01/2008). In summary, regulation 1106states that any persons doing demolition, landclearing, land grading (including grading forroads), excavation, material transport, or the use ofnon-paved roads on private property are requiredto employ control dust control measures, when theDepartment determines that such activities couldemit dust in quantities sufficient to cause airpollution.EPA’s Menu of Options states that “The dustcontrol plan includes chemical suppression andwater treatment of disturbed soil at constructionsites.” However, it says this option is “mainly forPM10” and DNREC is notaware of alternativecontrol measures for direct PM2.5. [Note thattransport fraction not yet applied]Non-Road Equipment161 6.4% These categories are subject to applicable federalmeasures only.Delaware has limited authority under the CAA toregulate off-road mobile sources.Delaware, as part of the Ozone TransportCommission (OTC), is currently evaluating thefeasibility of an off-road anti-idling regulation.Other potential measures include programs such aslawn-mower trade-in programs which generallygain small incremental reductions (i.e., on theorder of tenths of a ton to several tons per year).Commercial Marine Vessels(primarily in-transit emissionsfrom residual oil combustion)138 5.5% Commercial Marine Vessels include ocean-goingships and other large craft. This category issubject to applicable federal measures only,suchas the EPA C-3 Marine Engine Rule.Delaware has limited authority under the CAA toregulate off-road mobile sources.Commercial Cooking135 5.4% 7 DE Admin. Code 1114, Visible Emissions,applies to this source category.Additional control is possible. EPA’s 2012 Menuof Options lists only chain driven emissions ascontrollable. Chain driven emissions were17Table 3: PM2.5Emission and Control Analysis – NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY% of2011 NEIDescription of Federal Control Measures andControl Measures in Delaware's SIP Potential Additional Control Measuresestimated at 1.8 tpy PM2.5in Delaware’s 2008emissions inventory. Given the low level ofoverall emissions that can be controlled, potentialreductions are small.Calpine - Hay Road (Conectiv)106 4.2% The Hay Road EGUs are fired on natural gas anddistillate oil. Much of the PM2.5emissions arecondensable.Direct PM2.5emissions are limited to 0.3 lb/mmbtuunder 7 DE Admin. Code 1104, ParticulateEmissions From Fuel Burning Equipment.No economically feasible emission controltechnology to reduce direct PM2.5emissions fromthis facility has been identified. 7 DE Admin.Code 1108 and 1112 regulate the precursors SO2and NOx, and ensure this source category is wellcontrolled relative to its impact on ambient PM2.5concentrations.Evraz Claymont Steel63 2.5% This facility ceased operations beginningDecember, 2013.Not ApplicableCrop Production47 1.9% Delaware farmers employ crop rotation and no-tillpractices. [Note thattransport fraction not yetapplied]No additional control measures to reduce PM2.5due to farming have been identified.Formosa Plastics33 1.3% This facility produces vinyl chloride monomer.Emissions almost exclusively from polymer drying(presumable from VOC condensation). PM2.5iscontrolled by baghouses.No additional direct PM2.5control measures havebeen identified for this facility.Sunoco30 1.2% Not applicable – this facility is now closed. Not ApplicableCommercial/Industrial/Residential Combustion fired onOil21 0.8% The commercial/institutional fuel combustioncategory includes small boilers, furnaces, heaters,and other heating units too small to be consideredpoint sources. The commercial/institutional sectorincludes wholesale and retail businesses; healthinstitutions; social and educational institutions;and federal, state, and local governments (i.e.,prisons, office buildings) and are defined by SICcodes 50-99. The fuel types included in thissource category are coal (SCC 2103002000),distillate oil (SCC 2103004000), residual oil (SCC2103005000), natural gas (SCC 2103006000), andliquefied petroleum gas (LPG) (SCC2103007000). Uses of natural gas and LPG in thisNo economically feasible emission controltechnology to reduce direct PM2.5emissions fromthis source category has been identified. 7 DEAdmin. Code 1108 and 1112 regulate theprecursors SO2and NOx, and ensure this sourcecategory is well controlled relative to its impact onambient PM2.5concentrations.18Table 3: PM2.5Emission and Control Analysis – NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY% of2011 NEIDescription of Federal Control Measures andControl Measures in Delaware's SIP Potential Additional Control Measuressector include space heating, water heating, andcooking. Uses of distillate oil and kerosene includespace and water heating.Emissions in this category are from many smallunits throughout the State,.Direct PM2.5emissions are limited to 0.3 lb/mmbtuunder 7 DE Admin. Code 1104, ParticulateEmissions From Fuel Burning Equipment.FMC Biopolymer19 0.8% Emissions are primarily from the “Air Dryers”.Control device for PM is scrubbers.No economically feasible emission controltechnology to reduce direct PM2.5emissions fromthis facility has been identified.DuPont Experimental Station19 0.7% This facility has four (4) residual oil fired boilersand one gas fired boiler, each rated at 96mmBTU/hr each.Direct PM2.5emissions are limited to 0.3 lb/mmbtuunder 7 DE Admin. Code 1104, ParticulateEmissions From Fuel Burning Equipment.DuPont Experimental Station is currently payingfor the installation of a natural gas line to thefacility, after which all boilers will operate usingnatural gas. The goal is to have all boilersconverted to natural gas by mid-2017.No economically feasible emission controltechnology to reduce direct PM2.5emissions fromthese units has been identified. The precursorsSO2and NOx are well controlled, which ensuresthese units are well controlled relative to theirimpact on ambient PM2.5concentrations.Total - categories covering all2011 NEI sources that emit morethan 25 TPY and≥95% of PM2.52,396 95.6%Total - all other 2011 NEI facilitiesand source categories not includedabove112 4.4%19Table 3: PM2.5Emission and Control Analysis – NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY% of2011 NEIDescription of Federal Control Measures andControl Measures in Delaware's SIP Potential Additional Control MeasuresTotal 2011 AnthropogenicEmissions (TPY)2,507100%20Table 4: VOC Emission and Control Analysis - NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY % of 2011 InventoryDescription of Federal Control Measures andControl Measures in Delaware's SIP Potential Additional Control MeasuresOn-Road Mobile3,285 28.6% New vehicles must meet California vehicleemission standards (CA LEV 3) under 7 DEAdmin. Code 1140.New and existing vehicles must be maintainedunder Delaware’s vehicle Inspection andMaintenance program, 7 DE Admin. Code 1126and 1131.Extended idling of heavy duty vehicles isprohibited under 7 DE Admin Code 1145.Overall on-road mobile emissions are capped ineach of Delaware’s three counties by ozone SIPbudgets, which are managed under 7 DE Admin.Code 1132, transportation conformity.Delaware has no authority under the CAA tofurther regulate tailpipe emissions.Aside from I/M program upgrades, all otheridentified measures are in the form oftransportation control measures (TCMs), whichgenerally gain small incremental reductions (i.e.,on the order of tons per year, not hundreds of tonsper year), and that have a $/ton cost of $50,000 toover $1 million.Non-Road equipment2,094 18.3% These categories aresubject to applicable federalmeasures only.Delaware has limited authority under the CAA toregulate off-road mobile sources.Delaware, as part of the Ozone TransportCommission (OTC), is currently evaluating thefeasibility of an off-road anti-idling regulation.Other potential measures include programs suchas lawn-mower trade-in programs whichgenerally gain small incremental reductions (i.e.,on the order of tenths of a ton to several tons peryear), and that have a $/ton cost of $50,000 toover $1 million.Commercial/Consumer Products1,245 10.9% Commercial and consumer products are definedas non-industrial products used around the home,Delaware’s SIP currently contains the moststringent provisions feasible at this point (i.e.,21Table 4: VOC Emission and Control Analysis - NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY % of 2011 InventoryDescription of Federal Control Measures andControl Measures in Delaware's SIP Potential Additional Control Measuresoffice, institution, or similar settings. Includedare hundreds of individual products, includingpersonal care products (SCC 2460100000),household products (SCC 2460200000),automotive aftermarket products (SCC2460400000), coatings and related products(SCC 2460500000), adhesives and sealants (SCC2460600000), Federal Insecticide, Fungicide, andRodenticide Act (FIFRA) related products (SCC2460800000), and other miscellaneous products(SCC 2460900000). The VOCs in these productsmay act either as thecarriers for the activeproduct ingredients or as the active ingredientsthemselves.This category has undergone three rounds ofregulation in Delaware. First under a 1998National Rule (63 FR 48819), then under a morestringent 2002 Delaware regulation (Section 2.0of 7 DE Admin. Code 1141) which was based onan OTC model rule. Finally, under an update toSection 2.0 of 7 DE Admin. Code 1141 whichwas based on a 2006 revised OTC model rule,and which had a 2009 compliance date.those of the most recent OTC model rule adoptedby any state).3Delaware does not have the authority to directlyregulate manufacturers outside of the boundariesof the State of Delaware. Because of this, theonly means available to Delaware to regulateemission in this category is to regulate theallowable VOC content of products sold inDelaware.Delaware represents a very small market share tothese manufacturers and any attempt by Delawareto further reduce allowable VOC content on ourown would result in the manufacturers not sellingin Delaware, rather than having the desired effectof reformulation to lower VOC emitting products.In other words, Delaware’s market share alone isnot large enough for manufacturers to justify theexpense of reformulating their products. Separatefrom a national or regional rule, it is not feasiblefor Delaware to regulate this category further.4Residential Wood Combustion633 5.5% Delaware does not regulate this category in itsSIP. Woodstoves are regulated under 40 C.F.R.Part 60 Subpart AAA New Source PerformanceStandards (“NSPS”).No economically feasible VOC emission controlstrategies for this source category have beenidentified.Architectural and IndustrialMaintenance (AIM) Coatings619 5.4% Architectural surface coating operations consistof applying a thin layer of coating such as paint,Delaware’s SIP currently contains the moststringent provisions feasible at this point (i.e.,3The OTC commissioners approved an updated consumer products model rule in May 2012. Delaware plans to propose an update to its regulations based on this modelrule in the future4Note that the OTR states are currently considering an update totheir model rule. This is based on CARB 2006 amendments, pluspotential increased benefit by addingpaint thinner and multi-purpose solvents, and has the potential to reduce Delaware VOC emissions by 365 TPY.22Table 4: VOC Emission and Control Analysis - NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY % of 2011 InventoryDescription of Federal Control Measures andControl Measures in Delaware's SIP Potential Additional Control Measures(Area Source Category)paint primer, varnish, or lacquer to architecturalsurfaces, and the use of solvents as thinners andfor cleanup. Surface coatings include either awater-based or solvent-based liquid carrier thatgenerally evaporates in the curing process.Architectural surface coatings are applied toprotect the substrate and/or to increase theaesthetic value of a structure.Industrial maintenance coatings include primers,sealers, undercoats, and intermediate andtopcoats formulated for and applied to substratesin industrial, commercial, coastal, or institutionalsituations that are exposed to extremeenvironmental and physical conditions. Theseconditions include immersion in water, chemicalsolutions and corrosives, and exposures to hightemperatures.AIM coatings are regulated under Section 1 of 7DE Admin. Code 1141. This regulation is basedon an Ozone Transport Commission (OTC)model rule (which was based on Californiaregulations), and which is much more stringentthan the current federal rule. The compliancedate of this regulation was 1/1/2005.those of the most recent OTC model rule adoptedby any state)5.Delaware does not have the authority to directlyregulate manufacturers outside of the boundariesof the State of Delaware. Because of this, theonly means available to Delaware to regulateemission in this category is to regulate theallowable VOC content of products sold inDelaware.Delaware represents a very small market share tothese manufacturers and any attempt by Delawareto further reduce allowable VOC content on ourown would result in the manufacturers not sellingin Delaware, rather than having the desired effectof reformulation to lower VOC emitting products.In other words, Delaware’s market share alone isnot large enough for manufacturers to justify theexpense of reformulating their products. Separatefrom a national or regional rule, it is not feasiblefor Delaware to regulate this category further.Graphic Arts (Area SourceCategory)507 4.4% Printing operations are a source of VOCemissions due to the volatile organic content ofinks and thinners used in the industry. It isestimated that, on average, half of the graphicarts establishments are in-house printing servicesin non-printing industries. The remainingestablishments are located at businesses whoseDelaware’s SIP currently contains the moststringent identified provisions feasible at thispoint (i.e., those of the most recent EPA CTGs).5An update AIM model rule was approved by the OTC on June 3, 2010, which has not yet been adopted by any state. Delaware plansto propose an update to itsregulations based on this model rule in the future.23Table 4: VOC Emission and Control Analysis - NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY % of 2011 InventoryDescription of Federal Control Measures andControl Measures in Delaware's SIP Potential Additional Control Measuresmain function is printing or graphic arts. Largeprinting operations with VOC emissions of 10TPY or more are included in the point sourceinventory.All sources with maximum theoretical emissionsequal to or greater than 7.7 TPY are subject tothe CTG based requirements in Section 37 of 7DE Admin Code 1124 (VOC RACT).Offset lithographic and letterpress emissionsources with maximum theoretical emissionsequal to or greater than 15 pounds per day aresubject to the CTG based requirements in Section47 of 7 DE Admin Code 1124 (VOC RACT).Retail Gasoline Marketing –Stage I Vapor RecoveryStage II Vapor RecoveryTank BreathingTrucks in Transit442 3.9% Stage I emissions (i.e., tank truck refilling ofstorage tanks) are controlled by vapor balancingunder Section 26 of 7 DE Admin. Code 1124(VOC RACT).Stage II emissions (i.e., refueling of vehicles) arecontrolled by vapor balancing under Section 36of 7 DE Admin. Code 1124 (VOC RACT).Gasoline tank breathing emissions are subject toannual leak testing and permitting requirementsunder Section 36 of 7 DE Admin. Code 1124(VOC RACT)Gasoline tank truck emissions are subject toannual leak testing and permitting requirementsunder Section 27 of 7 DE Admin. Code 1124(VOC RACT).No control measures to further reduce emissionfrom Tank Breathing, and trucks in transit havebeen identified.Additional reductions could be achieved byrevising Stage I and Stage II requirements toCalifornia EVR requirements.Delaware has begun the process to revise itsStage I and Stage II requirements. This revisioncould yield VOC reductions of up to 100 TPY.Auto body Refinishing404 3.5% Auto refinishing is the repairing of worn ordamaged automobiles, light trucks, and othervehicles, and refers to any coating applicationsthat occur subsequent to those at originalDelaware’s SIP represents the current level oftechnology for thissource category.24Table 4: VOC Emission and Control Analysis - NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY % of 2011 InventoryDescription of Federal Control Measures andControl Measures in Delaware's SIP Potential Additional Control Measuresequipment manufacturer (OEM) assembly plants(i.e., coating of new cars is not included in thiscategory). The majority ofthese operations occurat small body shops that repair and refinishautomobiles. This category covers solventemissions from the refinishing of automobiles,including paint solvents, thinning solvents, andsolvents used for surface preparation andcleanup.Autobody refinishing is regulated under Section11 of 7 DE Admin Code 1124. This sourcecategory has undergone three rounds ofregulation in Delaware since 1990 (i.e., 1st CTGRACT, then OTC Model Rule 1 in 2002, andnow OTC Model Rule 2 which had a compliancedate of 1/1/2012).Gasoline Marketing - PortableFuel Containers374 3.3% Portable fuel containers are regulated nationallyby the EPA under 40 CFR Part 59, Subpart F.No control measures to further reduce emissionfrom this category have been identified.Industrial Adhesives (AreaSource Category)294 2.6% Regulated under Section 4.0 of 7 DE Admin.Code 1141. 1141 is much more stringent thanthe most recent EPA CTG, and has broadercoverage than the CTG (i.e., it covers fieldapplied roofing adhesives and sealants notcovered by the CTG). These requirements tookeffect on 5/1/2009.Delaware’s SIP represents the current level oftechnology for thissource category.Additional regulation of this category is notfeasible at this time.Degreasing (Area SourceCategory)191 1.7% Solvent cleaning is the process of using organicsolvents to remove grease, fats, oils, wax or soilfrom various metal, glass, or plastic items. Nonaqueous solvents such as petroleum distillates,chlorinated hydrocarbons, ketones, and alcoholshave been used historically; however, the use ofaqueous cleaning systems for some applicationshas recently gained acceptance.The types of equipment used in this method arecategorized as cold cleaners, open top vapordegreasers, or conveyorized degreasers.This category has undergone two rounds ofregulation in Delaware (i.e., 1st CTG RACT, thenOTC Model Rule 1 in 2002). This category isregulated much more stringently than required bythe CTG.DNREC has started working on a revision to DEAdmin Code 1124, Section 33.0 “SolventCleaning and Drying, which is estimated toreduce VOC emissions by an additional 1 TPD.25Table 4: VOC Emission and Control Analysis - NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY % of 2011 InventoryDescription of Federal Control Measures andControl Measures in Delaware's SIP Potential Additional Control MeasuresDegreasing is regulated under Section 33 of 7 DEAdmin. Code 1124.Gasoline Marketing –Commercial Marine VesselEvaporation Losses142 1.2% Not regulated beyond any applicable federalmeasures.No control measures to reduce emission from thiscategory have been identified.Delaware City Refinery139 1.2% The Delaware City Refinery is a petroleumrefinery.VOC emissions are subjectto 7 DE Admin Code1124 (VOC RACT). In addition, numeroussources at the facility are subject to emissionlimits established under 7 DE Admin. Code 1125(LAER plus offsets).The OTC finalized a model rule in 2010 toaddress VOC emissions from large abovegroundVOC storage tanks (ASTs). In June 2010,Delaware and other nine OTC member statessigned a MOU, which requested the undersignedOTC members to adopt the model rule, or torevise existing rule to reflect the model rule, byJanuary 2014 or as soonthereafter as practical.Delaware is pursuing adoption now.Industrial Surface Coatings(Area Source Category)139 1.2% This source category is covered under Section 1of 7 DE Admin. Code 1141 and several sectionsof 7 DE Admin. Code 1124, based on CTGs.Delaware’s SIP represents the current level oftechnology for thissource category.Additional regulation of this category is notfeasible at this time.Land application of AgricultureHerbicides & Pesticides114 1.0% None. Regulation of this category is not feasible by theState of Delaware.The only identified potential control measure forthis source category is to reduce the VOC contentof the herbicide or pesticide. Delaware does notcommand sufficient market share for this to befeasible. This category is best regulated by theEPA under a national rule.26Table 4: VOC Emission and Control Analysis - NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY % of 2011 InventoryDescription of Federal Control Measures andControl Measures in Delaware's SIP Potential Additional Control MeasuresDuPont - Edge Moor99 0.9% VOC emissions are subject to an 81% reductionunder Section 50 of 7 DE Admin Code 1124(VOC RACT).No control measures to further reduce emissionfrom this facility have been identified.Commercial Marine Vessels71 0.6% Commercial Marine Vessels include ocean-goingships and other large craft. This category issubject to the federal EPA C-3 Marine EngineRule, which established standards for emissionsof hydrocarbons from new Category 3 engines.Delaware has limited authority under the CAA toregulate off-road mobile sources.Evraz Claymont Steel69 0.6% This facility ceased operations beginningDecember, 2013.Not ApplicableFormosa Plastics59 0.5% This facility produces vinyl chloride monomer.This facility is subject to 7 DE Admin. Code1112 and 1124 (VOC RACT).No additional feasible controls have beenidentified to reduce VOC emissions from thisfacility.Commercial/Industrial/Residential Combustion fired onGas56 0.5% The commercial/institutional fuel combustioncategory includes small boilers, furnaces, heaters,and other heating units too small to be consideredpoint sources. The commercial/institutionalsector includes wholesale and retail businesses;health institutions; social and educationalinstitutions; and federal, state, and localgovernments (i.e., prisons, office buildings) andare defined by SIC codes 50-99. The fuel typesincluded in this source category are coal (SCC2103002000), distillate oil (SCC 2103004000),residual oil (SCC 2103005000), natural gas (SCC2103006000), and liquefied petroleum gas (LPG)(SCC 2103007000). Uses of natural gas andLPG in this sector include space heating, waterheating, and cooking. Uses of distillate oil andkerosene include space and water heating.No economically feasible emission controltechnology to reduce VOC emissions from thissource category has been identified. 7 DEAdmin. Code 1108 and 1112 regulate theprecursors SO2and NOx, and ensure this sourcecategory is well controlled relative to its impacton ambient PM2.5concentrations.27Table 4: VOC Emission and Control Analysis - NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY % of 2011 InventoryDescription of Federal Control Measures andControl Measures in Delaware's SIP Potential Additional Control MeasuresEmissions in this category are from many smallunits throughout the State, where facility-wideVOC emissions are generally less than 5 TPY(i.e., those not covered in the point sourceinventory).VOC emissions from this source category are notregulated.Prescribed Fires52 0.5% Open burning is restricted under 7 DE Admin.Code 1113.No economically feasible additional controlmeasures to reduce VOC emission from thissource category have been identified.Sunoco46 0.4% This facility was subject to 7 DE Admin. Code1112 and 1124 (VOC RACT).The facility is now shutdown.Printpack44 0.4% The emissions from the facility are from sevenflexographic printing presses, a photopolymerplate making system, and automatic parts washer,and a waste solvent tank.Emissions are controlled by a regenerativethermal oxidizer operated pursuant to 7 DEAdmin. Code 1124 (VOC RACT).No economically feasible control measures tofurther reduce VOC emissions from this facilityhave been identified.Magellan Terminals39 0.3% Magellan Terminals is a liquid fuels marketingand bulk fuels terminaland subject to 7 DEAdmin. Code 1124 (VOC RACT), Sections , 30,31, and 49.Magellan, to avoid Nonattainment New SourceReview, plans to keep their net emission increaseper unit below the significant emission rate of 25TPY.The OTC finalized a model rule in 2010 toaddress VOC emissions from large abovegroundVOC storage tanks (ASTs). In June 2010,Delaware and other nine OTC member statessigned a MOU, which requested the undersignedOTC members to adopt the model rule, or torevise existing rule to reflect the model rule, byJanuary 2014 or as soonthereafter as practical.Delaware is pursuing adoption now.28Table 4: VOC Emission and Control Analysis - NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY % of 2011 InventoryDescription of Federal Control Measures andControl Measures in Delaware's SIP Potential Additional Control MeasuresTraffic Markings (Area SourceCategory)37 0.3% The VOC of traffic marking coatings is limited to150 grams of VOC per liter of coating underSection 1 of 7 DE Admin. Code 1141,Architectural and Industrial MaintenanceCoatings.No feasible additional control measures havebeen identified to reduce VOC emissions fromthis source category.Calpine - Hay Road (Conectiv)33 0.3% This facility is a power plant that consists of sixcombined cycle gas fired (oil backup) EGUs.No feasible additional control measures havebeen identified to reduce VOC emissions fromgas-and oil-fired EGUs.Calpine - Edge Moor (Conectiv)25 0.2% This facility is a power plant that consists ofthree gas/oil fired EGUs. (i.e., 86 MW, 174 MW,and 450 MW).Calpine’s permit establishes a facility-wide VOClimit of 148 tpy.No feasible additional control measures havebeen identified to reduce VOC emissions fromgas-and oil-fired EGUs.Total - categories covering all2011 NEI sources that emit morethan 25 TPY and≥95% of VOC11,25498.1%Total - all other 2011 NEI facilitiesand source categories not includedabove215 1.9% Many of these small sources are also controlledunder the adequate measures in Delaware's SIP.This includes small sources covered by CTG andnon-CTG RACT that are established under 7 DEAdmin. Code 1124.Total 2011 AnthropogenicEmissions (TPY)11,469 100%29Table 5: NH3Emission and Control Analysis –NCC 2011 NEI (≥25 TPY and≥95%)Source Category2011TPY% of 2011 InventoryDescription of Federal Control Measures andControl Measures inDelaware's SIPPotential Additional Control MeasuresAnimal Husbandry230 25.0% Delaware regulates Concentrated Animal FeedingOperation (CAFO) underState regulations andpermitting program that meet the requirements ofthe federal Clean Water Act (§2202, Title 3 of theDelaware Code.No feasible additional control measures havebeen identified to reduce NH3emissions fromthis source category.Fertilizers22924.9% Not regulated. Regulation of this category is not feasible by theState of Delaware.The only identified potential control measure forthis source categoryis to reduce the NH3contentof the fertilizer. Delaware does not commandsufficient market share for this to be feasible.This category is best regulated by the EPA undera national rule.On-road Mobile18920.5% New vehicles must meet California vehicleemission standards (CA LEV 3) under 7 DEAdmin. Code 1140.New and existing vehicles must be maintainedunder Delaware’s vehicle Inspection andMaintenance program, 7 DE Admin. Code 1126and 1131.Extended idling of heavy duty vehicles isprohibited under 7 DE Admin Code 1145.Delaware has no authority under the CAA tofurther regulate tailpipe emissions.Aside from I/M program upgrades, all otheridentified measures are in the form oftransportation control measures (TCMs), whichgenerally gain small incremental reductions.Commercial/Industrial/ResidentialCombustion fired on Gas12213.2% The commercial/institutional fuel combustioncategory includes small boilers, furnaces, heaters,and other heating units too small to be consideredpoint sources. The commercial/institutional sectorincludes wholesale and retail businesses; healthinstitutions; social and educational institutions;and federal, state, and local governments (i.e.,prisons, office buildings) and are defined by SICNo additional economically feasible emissioncontrol technology to reduce NH3emissionsfrom this source category has been identified.30Table 5: NH3Emission and Control Analysis –NCC 2011 NEI (≥25 TPY and≥95%)codes 50-99. The fuel types included in thissource category are coal (SCC 2103002000),distillate oil (SCC 2103004000), residual oil (SCC2103005000), natural gas (SCC 2103006000), andliquefied petroleum gas (LPG) (SCC2103007000). Uses of distillate oil and keroseneinclude space and water heating.Emissions in this category are from many smallunits throughout the State.NH3 emissions for this source category are notregulated.Hay Road535.7% No known ammonia controls for fuel combustionNote: ammonia injection to reduce NOxcontributes to additional NH3 emissions, but thistrade-off is necessaryNot applicable.Residential WoodCombustion323.5%Delaware does not regulate this category in its SIP.It is regulated under 40 C.F.R. Part 60 SubpartAAA New Source Performance Standards(“NSPS”)Because all four New Castle County monitorsare significantly below the 2012 PM2.5NAAQS, economic and political obstacleswould have to be overcome before Delawarecould adopt measures to regulate this source,unless those measures are voluntary.Delaware is currently assessing EPA’s PM2.5Advance program6as a means of sources tovoluntarily reduce emissions from this and othercategories.Calpine - Edge Moor(Conectiv)111.2% This facility is a power plant that consists of threegas/oil fired EGUs. (i.e., 86 MW, 174 MW, and450 MW).Note: Calpine may use urea injection to reduceNOx, but urea contributes to additional NH3emissions. This trade-off is necessary to reduceNOx for helping meet the ozone NAAQS.No feasible additional control measures havebeen identified to reduce NH3emissions fromthese units.6http://epa.gov/ozonepmadvance/index.html31Table 5: NH3Emission and Control Analysis –NCC 2011 NEI (≥25 TPY and≥95%)However, the urea injection is not needed at thepresent time. NH3limits will be established onlyif urea is required to meet NOx emissionstandards.Formosa Plastics111.1% NH3emissions from this facility are not regulated.No feasible additional control measures havebeen identified to reduce NH3emissions fromthis facility.Total - categories covering all2011 NEI sources that emit morethan 25 TPY and≥95% of NH3876 95.1%Total - all other 2011 NEI facilitiesand source categories not includedabove45 4.9%Total 2011 AnthropogenicEmissions (TPY)922100%