RECE!VED

April 3, 2008 APR 8 2008

RECEflrEI) ion Uirectoi (3tPUO)

Mr. Donald S. Welsh (3RAOO)Regional Administrator o 8 2008 U. S. Environmental Protection Agency ‘ IRegion III EPA. REGION III

1650 Arch Street )CEOF REGIONAL ADMINISTRA1

Philadelphia, PA 19103-2029Dear Mr. Welsh:

I am pleased to submit the enclosed revision to the State of Delaware State

Implementation Plan (SIP) for the Attainment ofthe Fine Particle (PM25)National Ambient Air

Quality Standard (NAAQS). This revision is in response to EPA’s April, 2005 non-attainment

designation for the Philadelphia-Wilmington, PA-NJ-DE Metropolitan Statistical Area, which

includes New Castle County, Delaware, under the PM25 NAAQS. The effective date ofthisrevision is April 1, 2008.

Delaware’s proposed SIP for Attainment ofthe PM2.5National Ambient Air Quality

Standard will do the following: 1) Demonstrate that with all existing and proposed controls, all of

Delaware’s PM25 monitors will show attainment by 2010; 2) Demonstrate that the entirePhiladelphia-Wilmington, PA-NJ-DE nonattainment area will attain the PM25 NAAQS in 2009; 3)

Establish Delaware’s 2009 mobile source budgets for transportation conformity determinationsunder Regulation No. 1132, Transportation Conformity; and 4) Treat emission reduction creditsbanked under Regulation No. 34, Emissions Banking and Trading Program, as “emitted.”

The requirements of the CAA Section 11 0(a)(2)(A) have been met through the normal

public hearing process established by the State of Delaware with proper notification (30 days)

prior to the convening of the public hearing. A public hearing was held on March 4, 2008.

Attachments A and B are copies of affidavits as proof of proper notification. It is the position of

the State of Delaware that all minimum requirements set forth in the 1990 Clean Air Act

Amendments have been met.

Ve€aa 4vie‘4 9ood tazcie defteid4 ot øaf
Sincerely, /

I John A. Hugh’e

Secretary

Enclosurecc: Judy Katz, EPA w/encl.

Ali Mirzakhalili
DELAWARE 

STATE IMPLEMENTATION PLAN 

FOR ATTAINMENT OF THE PM2.5

NATIONAL AMBIENT AIR QUALITY STANDARD 

Attainment Demonstration 

March 20, 2008 
Table of Contents 

Executive Summary --------------------------------------------------------------------------- 4

Acronym List ----------------------------------------------------------------------------------- 6 

List of Tables ----------------------------------------------------------------------------------- 8 

List of Figures ---------------------------------------------------------------------------------- 10 

List of Appendixes ---------------------------------------------------------------------------- 11 

1. Introduction and Background

1.1 Purpose of this document ------------------------------------------------------------- 12 

1.2 What is PM2.5? -------------------------------------------------------------------------- 12 

1.3 Health effects and welfare impacts of PM2.5 ---------------------------------------- 13 

1.4 Emissions Addressed in this SIP: Direct PM2.5 and Precursors ---------------- 14 

1.5 Identification of Non-attainment Areas ---------------------------------------------- 16 

1.6 Responsibilities ------------------------------------------------------------------------- 17 

2. PM2.5 Air Quality Status and Trend Analysis 

2.1 Delaware PM2.5 Federal Reference Method (FRM) Monitoring Network ------- 18 

2.2 Delaware PM2.5 Design Values -------------------------------------------------------- 20 

2.3 Ambient PM2.5 Concentration Trends------------------------------------------------- 21 

2.4 Speciation Data -------------------------------------------------------------------------- 25 

2.5 Other monitors in the Philadelphia Non-attainment area -------------------------- 32

3. Delaware 2002 Base Year Emission Inventory 

3.1 2002 PM2.5 and Precursor Inventory Overview ------------------------------------ 34 

3.2 Emissions Summary--------------------------------------------------------------------- 34 

3.3 Stationary Point Sources---------------------------------------------------------------- 39 

3.4 Stationary Non-Point Sources---------------------------------------------------------- 43 

3.5 On-Road Mobile Sources--------------------------------------------------------------- 47 

3.6 Non-Road Mobile Sources-------------------------------------------------------------- 48 

3.7 Natural Sources--------------------------------------------------------------------------- 50 

4. Control Measures and 2009 Emission Projections for Attainment 

4.1 Point Source Controls and 2009 Projection Inventory ------------------------------ 52 

4.2 Non-Point Source Controls and 2009 Emission Projections------------------------ 57 

4.3 Non-Road Mobile Source Controls and 2009 Emission Projections--------------- 59 

4.4 On-Road Mobile Source Controls and 2009 Emission Projections ---------------- 62 

4.5 Summary of Delaware’s Overall Projected 2009 Inventory ------------------------- 63 

5. 2009 Emissions Attainment Targets------------------------------------------------------- 64 

6. Attainment Demonstration 

6.1 Background and Objectives------------------------------------------------------------ 66 

6.2 Conceptual Model ----------------------------------------------------------------------- 68 

6.3 Modeling Domain and Photochemical Modeling System-------------------------- 69 

6.4 Model Performance Evaluation-------------------------------------------------------- 71 

2
6.5 Attainment Demonstration------------------------------------------------------------- 80 

6.6 Unmonitored Area Analysis----------------------------------------------------------- 85 

6.7 Local Area Analysis-------------------------------------------------------------------- 90 

6.8 Supplemental Analyses and Weight of Evidence Determination----------------- 91 

6.9 Conclusions------------------------------------------------------------------------------ 92 

7. Reasonably Available Control Measures (RACM) and Reasonably Available Control 

Technology (RACT) 

7.1 Background and Requirements --------------------------------------------------------- 93 

7.2 Post 2002 RACT and RACM Measures ----------------------------------------------- 93 

7.3 Additional RACM/RACT Evaluation -------------------------------------------------- 96 

8. Mobile Budgets for Transportation Conformity 

8.1 Introduction to Transportation Conformity -------------------------------------------- 100 

8.2 Mobile Budgets for 2009, the Attainment Year --------------------------------------- 100 

9. Contingency Measures 

9.1 Quantification of Contingency Reductions Required--------------------------------- 102 

9.2 Demonstration that Contingency Requirement is Met-------------------------------- 103 

10. Appendices ------------------------------------------------------------------------------------ 105 

 

 

3
Executive Summary 

 

In April 2005 the Environmental Protection Agency (EPA) designated 126 areas of the 

country as “non-attainment” under the fine particle (PM2.5) National Ambient Air Quality 

Standard (NAAQS). Among those non-attainment areas is the Philadelphia-Wilmington, PA-NJDE Non-Attainment Area (NAA). This NAA includes one county in Delaware, five counties in 

southeastern Pennsylvania, and three counties in New Jersey. 1 According to the federal Clean 

Air Act (CAA) and the EPA Implementation Rule2, this entire NAA must attain compliance with 

the PM2.5 NAAQS by 2010. 

Particle pollution, especially fine particles, contains microscopic solids or liquid droplets 

that are so small that they can get deep into the lungs and cause serious health problems. 

Numerous scientific studies have linked particle pollution exposure to a variety of problems, 

including: 

• increased respiratory symptoms, such as irritation of the airways, coughing, or difficulty 

breathing; 

• decreased lung function; 

• aggravated asthma; 

• development of chronic bronchitis; 

• irregular heartbeat; 

• non-fatal heart attacks and premature death in people with heart or lung disease. 

People with heart or lung diseases, children and older adults are the most likely to be 

affected by exposure to particle pollution. However, even healthy individuals may experience 

temporary symptoms from exposure to elevated levels of particle pollution. 

In addition to these public health impacts, fine particles are the major cause of reduced 

visibility in parts of the United States, including many of our treasured national parks and 

wilderness areas. Also, particles are transported over long distances by wind and then settle on 

the ground or water. The effects of this settling include making lakes and streams acidic, 

changing the nutrient balance in coastal waters and large river basins, depleting the nutrients in 

soil, damaging sensitive forests and farm crops, and affecting the diversity of ecosystems. 

In response to the April 2005 non-attainment designation Delaware has developed this 

State Implementation Plan (SIP) revision. This SIP: 

• Demonstrates that with all existing and proposed controls, all of Delaware’s PM2.5 monitors 

will show attainment in 2009. 

• Demonstrates that the entire Philadelphia-Wilmington, PA-NJ-DE non-attainment area will 

attain the PM2.5 NAAQS in 2009. 

 

1 See Figure 1-1. 

2 Environmental Protection Agency, Clean Air Fine Particle Implementation Rule, 40 CFR Part 51, March 29, 

2007. 

 

4
• Establishes Delaware’s 2009 mobile source budgets for transportation conformity 

determinations under Regulation No. 1132, Transportation Conformity. 

• Treats emission reduction credits (ERCs) banked under Regulation No. 34, Emissions 

Banking and Trading Program, as “emitted.” As such, the future use of these credits is 

consistent with, and will not interfere with any calculation or provision of this SIP. 

5
Acronym List 

AQMS - Air Quality Management Section of DNREC 

BOTW - Beyond-on-the-way 

CAAA - Clean Air Act Amendments of 1990 

CAIR - Clean Air Interstate Rule 

CMSA - Consolidated Metropolitan Statistical Area 

DelDOT - Delaware Department of Transportation 

DNREC - Delaware Department of Natural Resources and Environmental 

 Control 

DOE - US Department of Energy 

EGAS - Economic Growth Analysis System 

EGU - Electric Generating Unit 

EIA - Energy Information Administration 

EID - Emission Inventory Development Program of AQMS 

EPA - United States Environmental Protection Agency 

I/M - Inspection and Maintenance Program 

IPM - Integrated Planning Model 

MANE_VU - Mid-Atlantic and Northeast Visibility Union 

MARAMA - Mid-Atlantic Regional Air Management Association 

NESCUAM - Northeast States for Coordinated Air Use Management 

MPO - Metropolitan Planning Organization 

mmBTU - Million British Thermal Unit 

NAA - Non-Attainment Area 

NAAQS - National Ambient Air Quality Standard 

NEI - National Emission Inventory 

NIF - National emission inventory Input Format 

NLEV - National Low Emission Vehicle 

NOx - Oxides of Nitrogen 

OTB - On-the-book 

OTW - On-the-way 

PM2.5 - Particulate Matter with an aerodynamic diameter of 2.5 microns or less 

PM10 - Particulate Matter with an aerodynamic diameter of 10 microns or less 

POTW - Publicly Owned Treatment Works 

QA-QC - Quality Assurance-Quality Control 

RACM - Reasonably Available Control Measure 

RACT - Reasonably Available Control Technology 

RFP - Reasonable Further Progress 

RPO - Regional Planning Organization 

RRF - Relative Response Factor 

RVP - Reid Vapor Pressure 

SANDWICH - Sulfate, Adjusted Nitrate, Derived Water, Inferred Carbonaceous Material 

Balance 

SCC - Source Classification Code 

SIC - Standard Industrial Classification 

SIP - State Implementation Plan 

6
SMOKE - Sparse Matrix Operator Kernel Emissions (SMOKE) Modeling System 

SO2 - Sulfur Dioxide 

TIP - Transportation Improvement Program 

TSD - Technical Supporting Document 

VMT - Vehicle Miles Traveled 

VOC - Volatile Organic Compound 

7
List of Tables 

Table 2-1 Delaware’s PM2.5 Monitoring Site General Information 

Table 2-2 Delaware’s PM2.5 Monitor Site Specific Information 

Table 2-3 Delaware Monitors - Three-year PM2.5 average of annual averages 

Table 2-4 Delaware Monitors - Three-year PM2.5 average 98th percentiles 

Table 2-5 Annual Average PM2.5 Concentrations, All Sites 

Table 2-6 98th Percentiles 

Table 2-7 PM2.5 Speciation – Annual average component mass, ug/m3 

Table 2-8 PM2.5 Speciation – Annual average as percent of total mass 

Table 2-9 Philadelphia CMSA estimated design values (three-year averages), excluding 

Delaware 

Table 3-1 2002 PM2.5 and Precursor Emissions by County 

Table 3-2 2002 Statewide Emissions by Source Sector 

Table 3-3 2002 New Castle County Emissions by Source Sector 

Table 3-4 Point Source Facilities in Delaware 2002 Base Year Inventory 

Table 3-5 Non-Point Sources in Delaware 2002 Base Year Inventory 

Table 3-6 Summary of 2002 Statewide Emissions from Non-point Sources 

Table 3-7 Summary of 2002 Non-point Emissions for New Castle County 

Table 3-8 2002 Annual Emissions and VMT for On-road Mobile Sources by County 

Table 3-9 2002 Annual PM Exhaust, Brake Wear, and Tire Wear Emissions by County 

Table 3-10 2002 Statewide Annual Emissions and VMT for On-road Mobile Sources by 

Vehicle Type 

Table 3-11 2002 Statewide Emissions from Non-road Sources 

Table 3-12 2002 Statewide Annual Emissions for NONROAD Equipment 

Table 3-13 2002 Emissions for Natural Sources by County 

Table 4-1 EGU emission projections calculated by the Integrated Planning Model (IPM) 

Table 4-2 2009 EGU emissions – Delaware calculated 

Table 4-3 Facility and Unit shutdowns 

Table 4-4 Emission Reduction Credits and Holding Facilities/Agency 

Table 4-5 Summary of the MACTEC 2009 Non-EGU Point Source Projection 

Table 4-6 Summary of the Un-Revised Portion of the MACTEC 2009 Non-EGU Point 

Source Projection 

Table 4-7 Summary of the Revised Portion of the MACTEC 2009 Non-EGU Point Source 

Projection 

Table 4-8 Summary of the Delaware Non-EGU Point Source Projection 

Table 4-9 Summary of Delaware 2009 EGUs and non-EGUs Point Source Projection 

Table 4-10 Summary of the MACTEC 2009 Non-Point Source Projection 

Table 4-11 Summary of the Un-Revised Portion of the MACTEC 2009 Non-Point Source 

Projection 

Table 4-12 Summary of the Revised Portion of the MACTEC 2009 Non-Point Source 

Projection 

Table 4-13 Summary of the Delaware Non-Point Source Projections 

Table 4-14 Summary of the MACTEC 2009 Non-Road Mobile Source Projection 

8
Table 4-15 Summary of the Un-Revised Portion of the MACTEC 2009 Non-Road Mobile 

Source Projection 

Table 4-16 Summary of the Revised Portion of the MACTEC 2009 Non-Road Mobile Source 

Projection 

Table 4-17 Summary of the Delaware Non-Road Mobile Source Projection 

Table 4-18 (NESCAUM/NY) 2009 Mobile Projections 

Table 4-19 Delaware 2009 Mobile projections using the most up-to-date VMT and speeds 

Table 4-20 2009 projections – all sectors – MANEVU 

Table 4-21 2009 projections – all sectors – Delaware 

Table 5-1 CMAQ Modeled 2009 Emissions, i.e. Attainment Targets 

Table 5-2 DE Projected 2009 Emissions (Control Strategy Emissions) 

Table 5-3 Attainment Demonstration (CMAQ Modeled 2009 Emissions minus DE Projected 

2009 Emissions) 

Table 5-4 SO2 “surplus/shortfall” 

Table 6-1 PA-NJ-DE Designations for the PM2.5 NAAQS 

Table 6-2 EPA PM2.5 Modeling Performance Goals 

Table 6-3 MANE-VU PM2.5 Modeling Performance Goals 

Table 6-4 Annual SMAT Results for PA-NJ-DE Nonattainment Area 2009 On-The-BooksOn-The-Way Control Measures 

Table 6-5: 24-Hour Modeling Attainment Test Using EPA SMAT Methodology 2009 OnThe-Books/On-The-Way Control Measures

Table 7-1 DE 2002 and Projected 2009 Emissions

Table 7-2 CMAQ Modeled 2009 Emissions, Delaware

Table 7-3 2009 Statewide Emission Reductions attributable to Delaware Reg. 1146 (TPY) 

Table 7-4 2009 Emissions Projection, Conservatively Low Estimate

Table 7-5 Delaware SO2 Emissions, Source Categories Covering 95% of Total Emissions 

Table 8-1 On-Road Mobile primary and Precursor PM2.5 Emissions as a Percent of Total 

Projected Inventory New Castle County 

Table 8-2 On-Road Mobile Source Emission Projections for 2009Tons/Year 

Table 9-1 Attainment Targets 

Table 9-2 Delaware 2002 Base Year 

Table 9-3 Contingency Requirement 

Table 9-4 Delaware 2009 Projection 

Table 9-5 Contingency – SO2 “surplus and shortfalls” 

9
List of Figures 

Figure 1-1 Philadelphia-Wilmington, PA-DE-NJ Non-attainment Area 

Figure 2-1 Delaware’s PM2.5 Monitoring Site Locations 

Figure 2-2 Annual Average PM2.5 Concentrations, All Sites 

Figure 2-3 Design value – 3-year average of annual average PM2.5 Concentrations 

Figure 2-4 98th Percentile Trends 

Figure 2-6 Three-year average 98th percentile - design values 

Figure 2-7 2006 Annual Average Concentrations, Percent of Total Mass 

Figure 2-8 Major component trends 

Figure 2-9 Seasonal Components of PM2.5

Figure 2-10 Estimated design values for Philadelphia CMSA monitors 

Figure 3-1 PM2.5 Emissions by County 

Figure 3-2 SO2 Emissions by County 

Figure 3-3 NOx Emissions by County 

Figure 3-4 NH3 Emissions by County 

Figure 3-5 PM2.5 Emissions by Source Sector 

Figure 3-6 SO2 Emissions by Source Sector 

Figure 3-7 NOx Emissions by Source Sector 

Figure 3-8 NH3 Emissions by Source Sector 

Figure 6-1 The Philadelphia-Wilmington (PA-NJ-DE) nonattainment area 

Figure 6-2 PM2.5 Modeling Domains at 36- and 12-km for the OTR 

Figure 6-3 FRM Locations Used for the Model Evaluation Across the OTR+ Region 

Figure 6-4 Composite FRM Time Series across the OTR+ Region (264 monitors) 

Figure 6-5 MFE and MFB Time Series for FRM PM2.5 across the OTR+ Region 

Figure 6-6 MFE Bugle Plot for FRM PM2.5 across OTR+ Region 

Figure 6-7 MFE Bugle Plot for SO4 across OTR+ Region 

Figure 6-8 MFE Bugle Plot for NO3 SO4 across OTR+ Region 

Figure 6-9 MFE Bugle Plot for NH4 across OTR+ Region 

Figure 6-10 MFE Bugle Plot for ECacross OTR+ Region 

Figure 6-11 MFE Bugle Plot for OM across OTR+ Region 

Figure 6-12 MFE Bugle Plot for Soil/Crustal across OTR+ Region 

Figure 6-13 Empirical variogram fitted with different models for the annual standard 

Figure 6-14 Map of kriging estimates for the annual standard fitted with weighted least 

squares model and nugget set to 0.15 

Figure 6-15 Empirical variogram fitted with different models for the daily standard 

Figure 6-16 Map of kriging estimates for the daily standard fitted with weighted least squares 

model and nugget set to 0.15 

Figure 6-17 Trend in Annual PM2.5 Design Values (2000 through 2006) 

Figure 6-18 Trend in Daily PM2.5 Design Values (2000 through 2006) 

10
List of Appendices 

A collection of the listed appendixes, stored on CD, is available upon request. Contact 

Delaware’s Air Quality Management Section at 156 South State Street, Dover, DE 19901. 

Appendix 4-1 Development of Emission Projections for 2009, 2012, and 2018 for Non-EGU 

Point, Area, and Non-road Sources in the MANE-VU Region, Draft Final 

Technical Support Document, Prepared for Mid-Atlantic Regional Air 

Management Association (MARAMA) by MACTEC Federal Programs, Inc., 

December 7, 2006. 

Appendix 4-2 The 2009 Corrected Emission Projections of Delaware EGU, Non-EGU, NonPoint and Non-Road Mobile Sources. 

Appendix 4-3 The 2009 Emission Projections for Delaware’s Point, Non-Point, Onroad, and 

Non-Road Mobile Sources. 

Appendix 4-4 Part 1: MOBILE6.2 Input and Output Files for Delaware 2009 Mobile Source 

Emission 

Part 2: Calculations of 2008 and 2009 On-Road Mobile Source Emission 

Projections 

Appendix 6-1 The Nature of the Fine Particle and Regional Haze Air Quality Problems in 

the MANE-VU Region: A Conceptual Description (NESCAUM, November 

2006) and 

Appendix 6-2 The Development of PM2.5 Forecasting Tools for Selected Cities in the 

MARAMA Region (ICF, September 2004) 

Appendix 6-3 The New York State DEC, Division of Air Resources, performance evaluation 

of the 2002 base case CMAQ simulation 

Appendix 6-4/a SANDWICH Method 

Appendix 7-1 EPA List of Control Measures 

Appendix 8-1 Example 2009 Mobile Emission Projection Calculations 

11
Section 1 - Introduction & Background

 

On July 18, 1997 the US Environmental Protection Agency (EPA) established a health 

based fine particulate matter (PM2.5) National Ambient Air Quality Standard (NAAQS) at 15.0 

micrograms per cubic meter (μg/m3), annual average.3 New Castle County, Delaware was 

designated by the EPA as being in non-attainment for the PM2.5 NAAQS in April 20054. Kent 

and Sussex Counties were designated as attainment; however, sources within these counties emit 

PM2.5 and PM2.5 precursors which contribute to PM2.5 non-attainment in New Castle County. 

This document contains Delaware’s State Implementation Plan (SIP) revision for meeting 

attainment of the PM2.5 NAAQS, and is hereafter referred to as “Delaware’s PM2.5 SIP revision,” 

or simply as “the PM2.5 SIP.” 

1.1 Purpose of this document 

Once an area is designated as non-attainment, the Clean Air Act (CAA) requires that area 

to, within three years of the designation effective date, submit to the EPA a SIP which 

demonstrates how that area will attain compliance with the NAAQS. This SIP is due to the EPA 

in April 2008, and attainment of the PM2.5 NAAQS must be demonstrated by 2010. 

On March 30, 2007, the EPA finalized a PM2.5 Implementation Rule (hereafter referred to 

as the “Rule”), which sets forth the requirements that SIPs must meet to satisfy CAA 

requirements. The Rule requires: 

o an attainment demonstration (which includes associated air quality modeling), 

o adopted State regulations that are relied upon to reduce emissions of PM2.5 and PM2.5

precursors, and 

o a demonstration that the area will attain the standards as expeditiously as practicable. 

This document demonstrates that all of the CAA and Rule requirements associated with 

the PM2.5 NAAQS have been met; and that Delaware and the entire Philadelphia-WilmingtonDE-PA-NJ non-attainment area will attain compliance with the 1997 PM2.5 NAAQS as 

expeditiously as practicable, and not later than 2010. 

1.2 What is PM2.5? 

PM2.5 is defined as those particles with a nominal aerodynamic diameter of two and one 

half (21⁄2) micrometers or less. PM2.5 is composed of a complex mixture of particles: sulfate 

(SO4), nitrate (NO3) and ammonium (NH4) particles; particle-bound water; black carbon (also 

 

3 The annual PM2.5 NAAQS is set at a level of 15.0 micrograms per cubic meter (μ/m3

), based on a 3-year 

average of annual mean PM2.5 concentrations. Recently, the 24-hour NAAQS was lowered to 35μ/m3

, and 

under this lowered NAAQS attainment/non-attainment recommendations will be submitted to the EPA by states 

in late 2008, or possibly early 2009. Because Delaware has not yet been designated under this new NAAQS, 

this new NAAQS is not addressed in this SIP. 

4 70 FR 944, January 5, 2005 

12
known as elemental carbon); a great variety of organic compounds (or VOCs); and crustal 

materials. PM2.5 is broadly categorized as primary PM2.5 and secondary PM2.5: 

• Primary: PM2.5 is referred to as “primary” if it is directly emitted into the air as a solid or 

liquid particle and its chemical form is stable. PM2.5 formed near its source by 

condensation processes in the atmosphere is also considered primary PM2.5. 

Primary fine particles include soot from diesel engines, a wide variety of organic 

compounds condensed from incomplete combustion or cooking operations, and 

compounds such as arsenic, selenium, and zinc that condense from vapor formed during 

combustion or smelting. The metals are a subset of crustal materials. The concentration 

of primary PM2.5 in the air depends on source emission rates, transport and dispersion, 

and removal rate from the atmosphere. Primary PM2.5 is considered the "local" 

component of Delaware's PM2.5 problem, meaning that it is the portion of the PM2.5 levels 

produced locally that contribute to monitored violations of the standard in Delaware. 

• Secondary: PM2.5 that is formed by chemical reactions of gases in the atmosphere is 

referred to as "secondary" PM2.5. These reactions form condensable vapors that either 

generate new particles or condense onto other particles in the air. Most of the sulfate, 

nitrate and a portion of the organic compounds in the atmosphere are formed by such 

chemical reactions. As such, these compounds are known as PM2.5 precursors. 

Secondary PM2.5 formation depends on numerous factors including the concentrations of 

precursors and other gaseous reactive species such as ozone, hydroxyl radicals, peroxy 

radicals, or hydrogen peroxide. Contributing atmospheric conditions include solar 

radiation and relative humidity, along with the interactions of the precursors and preexisting particles with cloud or fog droplets or in the liquid film on solid particles. 

Depending on the PM2.5 precursor, they can have either a "local" or "regional" impact, or 

some combination, on PM2.5 concentrations. A regional impact means that the emissions 

produced locally form secondary PM2.5 emissions over time as they are transported 

through the atmosphere, and by the time those secondary particles are fully formed, they 

no longer contribute to the monitored violations of the standard in the State where the 

precursors were initially emitted. However, they will have an impact on the monitored 

violations in other states downwind. 

1.3 Health effects and welfare impacts of PM2.5. 

The PM2.5 NAAQS were established by the EPA based on evidence from numerous 

health studies demonstrating that serious health effects are associated with exposure to elevated 

levels of PM2.5. Epidemiological studies have shown statistically significant correlations 

between elevated PM2.5 levels and premature mortality. Other important effects associated with 

PM2.5 exposure include aggravation of respiratory and cardiovascular diseases (as indicated by 

increased hospital admissions, emergency room visits, absences from school or work, and 

restricted activity days), changes in lung function and increased respiratory symptoms, as well as 

new evidence for more subtle indicators of cardiovascular health. Individuals particularly 

13
sensitive to PM2.5 exposure include older adults, people with heart and lung disease, and 

children. 

Even small reductions in PM2.5 levels have been demonstrated to yield substantial health 

benefits on a population level. For example, in a moderate-sized metropolitan area with a design 

value of 15.5 ug/m3, efforts to improve annual average air quality down to the level of the 

standard (15.0 ug/m3) are estimated to result in as many as 25-50 fewer mortalities per year due 

to air pollution exposure. In a smaller city, the same air quality improvements from 15.5 to 15.0 

ug/m3 are estimated to result in a number of avoided mortalities per year. 

In both 1997 and 2006 EPA established welfare-based (secondary) standards identical to 

the levels of the primary standards. The secondary standards are designed to protect against 

major environmental effects of PM2.5 such as visibility impairment, crop damage, soil and water 

quality impacts from deposition, and materials damage. 

 1.4 Emissions Addressed in this SIP: Direct PM2.5 and Precursors. 

The Rule requires non-attainment areas to evaluate and consider, at a minimum, control 

strategies for sources of direct PM2.5 emissions, and for sources of the precursor sulfur dioxide 

(SO2). As such, both of these two pollutants are regulated pollutants under this SIP. In addition, 

consistent with EPA presumption in the Rule, and as explained in subsections 1.4.1 through 1.4.3 

below, nitrogen oxide (NOX) is also a regulated pollutant under this SIP, while volatile organic 

compounds (VOC) and ammonia (NH3) are not 5. 

1.4.1 Nitrogen Oxides (NOX). 

 For the precursor NOX the Rule makes the presumption that NOX emission must be 

addressed in the SIP, and that this presumption is valid unless a technical demonstration to the 

contrary is made by the State or EPA. Consistent with the Rule presumption, and because 

nitrates make up a significant percentage of PM2.5 concentrations in Delaware (see Section 2 of 

this Document for a detailed discussion), NOX is specifically addressed in this SIP, and is a 

regulated pollutant under this SIP. 

1.4.2. Volatile Organic Compounds (VOC). 

For the precursor VOC, the Rule presumptively requires that VOC emissions do not need 

to be regulated pollutants under this SIP. This presumption is valid unless a technical 

demonstration to the contrary is made by the State or EPA. The organic component of ambient 

particles is a complex mixture of hundreds or even thousands of organic compounds. These 

organic compounds are either emitted directly from sources (i.e., primary organic aerosol) or are 

formed by reactions in the ambient air (i.e., secondary organic aerosol, or SOA). VOCs are key 

precursors in the formation processes for both SOA and ozone. The relative importance of 

organic compounds in the formation of secondary organic particles varies from area to area, 

 

5 While VOC and NH3 are not specifically regulated under this SIP, certain VOC and NH3 emission control 

measures are included in the attainment modeling which is part of this SIP. As such, emissions of these 

pollutants and the associated control measures are discussed in this SIP. 

14
depending upon factors such as local emissions sources, atmospheric chemistry, and the season 

of the year. 

Despite significant advances in understanding the origins and properties of SOA, it 

remains probably the least understood component of PM2.5. The reactions forming secondary 

organics are complex, and the number of intermediate and final compounds formed is 

voluminous. Some of the best efforts to unravel the chemical composition of ambient organic 

aerosol matter have been able to quantify the concentrations of hundreds of organic compounds 

representing only 10–20 percent of the total organic aerosol mass. For this reason, SOA 

continues to be a significant topic of research and investigation. 

Current scientific and technical information clearly shows that carbonaceous material is a 

significant fraction of total PM2.5 mass in most areas, that certain VOC emissions are precursors 

to the formation of SOA, and that a considerable fraction of the total carbonaceous material is 

likely from local as opposed to regional sources. However, while significant progress has been 

made in understanding the role of gaseous organic material in the formation of organic 

particulate matter, this relationship remains complex. The Department recognizes that further 

research and technical tools are needed to better characterize emissions inventories for specific 

VOC compounds, and to determine the extent of the contribution of specific VOC compounds to 

organic particulate matter mass. 

In light of these factors Delaware is not regulating VOC emissions as PM2.5 precursors 

under this SIP. However, since all of Delaware is currently designated as being in nonattainment for the 8-hour ozone NAAQS, and since VOC emissions are a precursor regulated 

under the 8-hour ozone NAAQS, emission control measures for VOCs that have and are being 

implemented throughout the state will provide a PM2.5 benefit. 

1.4.3 Ammonia (NH3). 

The Rule presumptively requires that ammonia emissions do not need to be addressed as 

a PM2.5 precursor. This presumption is valid unless a technical demonstration to the contrary is 

made by the State or EPA. 

Ammonia (NH3) is a gaseous pollutant that is emitted by natural and anthropogenic 

sources. Ammonia serves an important role in neutralizing acids in clouds, precipitation and 

particles. In particular, ammonia neutralizes sulfuric acid and nitric acid, the two key 

contributors to acid deposition (acid rain). However, despite this benefit, deposited ammonia 

contributes to problems of eutrophication in water bodies, and deposition of ammonium particles 

may effectively result in acidification of soil as ammonia is taken up by plants. The NARSTO 

Fine Particle Assessment6 indicates that reducing ammonia emissions where sulfate 

concentrations are high may reduce PM2.5 mass concentrations, but may also increase the acidity 

of particles and precipitation. An increase in particle acidity is suspected to be linked with 

human health effects and with an increase in the formation of secondary organic compounds. 

 

6 P. McMurry, M.Shepherd, and J. Vickery, eds., Particulate Matter Assessment for Policy Makers: A NARSTO 

Assessment. Cambridge University Press, Cambridge, England. ISBN 0 52 184287 5 NARSTO (2004) 

15
Based on the above information, and further insights gained from the NARSTO Fine 

Particle Assessment, it is apparent that the role of ammonia emissions in the formation of 

particles is complex and nonlinear. Though recent studies have improved our understanding of 

the role of ammonia in aerosol formation, ongoing research is required to better determine the 

relationships between ammonia emissions and particulate matter concentrations. Techniques and 

analytical tools to quantify the impact of reducing ammonia emissions on atmospheric aerosol 

formation are evolving. Area-specific data is needed to evaluate the effectiveness of reducing 

ammonia emissions on lowering the PM2.5 concentrations in different areas, and to determine 

where ammonia reduction may increase the acidity of particles and precipitation. 

Also, emissions inventories for ammonia are considered to be among the most uncertain 

of any species related to PM. This further complicates the task of assessing the potential impacts 

of ammonia emissions reductions on particulate matter concentrations. In addition, data 

necessary to understand the atmospheric composition and balance of ammonia and nitric acid in 

an area are not widely available across PM2.5 non-attainment areas, making it difficult to predict 

the results of potential ammonia emission reductions. Ammonia reductions may be effective and 

appropriate for reducing PM2.5 concentrations in selected locations, but in other locations such 

reductions may lead to minimal reductions in PM2.5 concentrations and increased atmospheric 

acidity. 

Because ammonia emission inventories and the other “tools” discussed above need much 

more refinement, Delaware is not regulating ammonia as a PM2.5 precursor under this SIP. 

1.5 Identification of Non-attainment Areas. 

Effective April 5, 2005 the EPA designated 47 areas, composed of 224 counties and the 

District of Columbia as “non-attainment” under the PM2.5 NAAQS (70 FR 944, January 5, 

2005). Among those non-attainment areas is the Philadelphia-Wilmington-PA-DE-NJ NonAttainment Area (NAA) that includes one county in Delaware, five counties in southeastern 

Pennsylvania and three counties in New Jersey, as shown in Figure 1-1. Since the NAA is 

centered on Philadelphia, it is referred to as “Philadelphia NAA.” According to the CAA, the 

entire Philadelphia NAA must attain the PM2.5 NAAQS as expeditiously as practicable, and not 

later than 2010. 

16
Figure 1-1. Philadelphia-Wilmington, PA-DE-NJ Non-attainment Area 

1.6 Responsibilities. 

The agency with direct responsibility for preparing and submitting this document is 

Delaware Department of Natural Resources and Environmental Control (DNREC), Division of 

Air and Waste Management, Air Quality Management Section (AQMS), under the Section 

Administrator, Ali Mirzakhalili, P.E. The working responsibility for Delaware’s air quality 

planning falls within AQM’s Planning Branch, under the Program Manager, Ronald Amirikian. 

The Planning Branch is instrumental in completing this document. Specifically, 

• John L. Sipple, M.S., is the project leader, and principal author of this SIP revision; 

• Mohammed A. Majeed, Ph.D. and P.E., is the modeling and weight of evidence analysis 

lead, and the principal author of Section 6 of this SIP revision; 

• David F. Fees, P.E., Program Manager, AQMS Emission Inventory Program, is the 

supporting lead for the 2002 base year emission inventory; 

• Betsy Frey, M.S., is the supporting lead for PM2.5 monitoring data and trend analysis; 

• Phillip A. Wheeler, Planner and Deanna Morozowich, Engineer, are the supporting leads 

for the on-road mobile source emission projections; 

• John L. Sipple and Mark Prettyman, Scientists, are the coordinator and supporting staff 

for future-year emission projection inventories. 

 

Specific responsibilities of other programs, agencies and contractors are discussed in the 

relevant sections of this document. 

17
Section 2 - PM2.5 Air Quality Status and Trend Analysis 

2.1 Delaware PM2.5 Federal Reference Method (FRM) Monitoring Network.

Delaware began official PM2.5 monitoring in 1999. Delaware’s PM2.5 network consists of 

seven (7) monitoring sites, one of which employs a collocated monitor. There are four (4) sites 

in New Castle County, two (2) in Kent County and one (1) in Sussex County. Table 2.1 lists the 

PM2.5 sites in Delaware, including the nature of the area, and general site descriptions. Table 2.2 

contains more specific information for each PM2.5 monitoring site. 

The primary goal of the PM2.5 monitoring network in Delaware is to determine the status of 

the ambient air with respect to the 24-hour and annual average PM2.5 NAAQS. In accordance 

with federal regulations, state agencies must operate at least the minimum number of required 

PM2.5 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 one 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 PM2.5 site to monitor for regional 

background and at least one PM2.5 site to monitor regional transport. 

Figure 2.1 shows the locations of Delaware’s PM2.5 monitors. All data from these monitors 

is measured using U.S. EPA approved federal reference methods. All PM2.5 sites are sited 

appropriately and are eligible for comparison to the annual NAAQS of 15.0 ug/m3. 

The standard monitoring schedule is one in three days, with one site (MLK-Wilmington) 

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

designated as MLK-b operating on a one in six day schedule. All data is submitted to EPA’s Air 

Quality System (AQS) in a timely manner in accordance to the schedule prescribed by EPA. 

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

useful in developing State implementation plans and supporting atmospheric or health effects 

related studies. These sites in Delaware are MLK in Wilmington and Dover in Kent County. 

The PM2.5 chemical speciation sites include analysis for elements, selected anions and cations, 

and carbon. 

18
Figure 2.1 Delaware’s PM2.5 Monitoring Site Locations 

Table 2.1 Delaware’s PM2.5 Monitoring Site General Information 

Site Name & AQS ID Land Use Setting Metropolitan Statistical Area 

Killens Pond 

10-001-0002 Agricultural Rural NA 

Dover 

10-001-0003 Residential Suburban Dover 

Bellefonte 

10-003-1003 Residential Suburban Philadelphia - Wilmington 

MLK 

10-003-2004 Commercial Urban Philadelphia - Wilmington 

Newark 

10-003-1012 Residential Suburban Philadelphia - Wilmington 

Lums Pond 

10-003-1007 Agricultural Rural Philadelphia - Wilmington 

Seaford 

10-005-1002 Residential Suburban Seaford - Micropolitan 

19
Table 2.2 Delaware’s PM2.5 Monitor Site Specific Information 

Site Name & AQS ID Parameter Start Date Objective 

Killens Pond 

10-001-0002 PM2.5 1/1/1999 

General/Background. 

Attainment Status 

PM2.5 1/1/1999 

Population Exposure, 

Attainment Status 

Dover 

10-001-0003 

PM2.5 speciation 6/1/2001 PM2.5 Characterization 

Bellefonte 

10-003-1003 PM2.5 1/1/1999 

Population Exposure, 

Attainment Status 

PM2.5 1/1/1999 

Maximum concentration, 

Attainment Status 

PM2.5 speciation 6/1/2001 PM2.5 Characterization 

MLK 

10-003-2004 

Black Carbon 1/1/2001 Diesel PM2.5 Indicator 

Newark 

10-003-1012 PM2.5 12/15/1999 

Population Exposure, 

Attainment Status 

Lums Pond 

10-003-1007 PM2.5 1/1/1999 

Transport/Background, 

Attainment Status 

Seaford 

10-005-1002 PM2.5 1/1/1999 

Population Exposure, 

Attainment Status 

2.2 Delaware PM2.5 Design Values. 

Under the PM2.5 annual average NAAQS, Delaware’s New Castle County was designated 

as a non-attainment area based on its three-year annual average data (2001 – 2003). New Castle 

County is also considered part of the greater Philadelphia CMSA which has been designated 

non-attainment for PM2.5. 7

Table 2.3 shows the three-year average of the annual average PM2.5 concentration for 

each monitoring site in all three counties in Delaware from 1999 through 2006. This is the value 

that is comparable to the annual average NAAQS and is referred to as the Design Value. 

 

7 See Section 1 of this document for additional discussion. 

20
Table 2.3 Delaware Monitors - Three-year PM2.5 average of annual averages 

Annual Average NAAQS = 15 ug/m3 3-year average 

New Castle County Kent County 

Sussex 

County 

Years Bllfte MLK-a Nwrk-a Lums Dover Killens Seaford 

1999-2001 15.1 16.5 15.1 14.1 13.5 12.8 14.5

2000-2002 15.0 16.3 15.2 13.9 13.1 12.9 14.0

2001-2003 14.8 16.0 15.0 13.6 12.9 12.7 13.4

2002-2004 14.2 15.0 14.6 13.2 12.4 12.6 13.0

2003-2005 14.3 15.1 14.6 13.4 12.7 12.8 13.3

2004-2006 13.5 14.8 13.9 12.8 12.5 12.6 13.5

Table 2.4 shows the three-year average of the annual 98th percentiles for each monitoring site, 

which is the value that is comparable to the 98th percentile NAAQS. 

Table 2.4 Delaware Monitors - Three-year PM2.5 average 98th percentiles 

98th percentile NAAQS = 65 ug/m3 3-year average (modified in 2007 to 35 ug/m3) 

New Castle County Kent County 

Sussex 

County 

Bllfte MLK-a Nwrk-a Lums Dover Killens Seaford 

1999-2001 37.3 40.0 38.2 35.3 34.0 32.4 37.5 

2000-2002 37.6 41.0 40.3 34.3 33.9 35.3 40.5 

2001-2003 36.8 40.4 39.1 34.3 36.2 34.2 38.8 

2002-2004 34.0 37.4 35.7 32.6 33.1 33.1 36.6 

2003-2005 34.4 36.3 33.5 34.5 32.5 32.3 33.5 

2004-2006 32.7 36.4 31.5 31.9 30.8 32.1 34.4 

 

2.3 Ambient PM2.5 Concentration Trends. 

2.3.1 Annual Averages 

The annual average concentration is calculated from the four calendar quarterly averages 

at each monitoring site. This annual average is the basic statistic used in determining trends and 

compliance with the annual average NAAQS. 

Table 2.5 shows the annual average PM2.5 concentration at each monitoring site. Figure 

2.2 is a graph of that same data, which shows trends over the eight years of monitoring that have 

been conducted. 

21
Table 2.5 Annual Average PM2.5 Concentrations, All Sites 

Annual Average NAAQS = 15 ug/m3

New Castle County Kent County 

Sussex 

County 

Year Bllfte MLK-a Nwrk-a Lums Dover Killens Seaford 

1999 14.2 15.6 14.3 13.6 13.5 12.3 14.6

2000 15.4 16.4 15.4 14.2 12.9 13.2 14.3

2001 15.6 17.6 15.8 14.5 14.0 13.0 14.4

2002 14.0 14.8 14.3 13.0 12.4 12.4 13.2

2003 14.8 15.5 14.8 13.3 12.3 12.7 12.5

2004 13.9 14.9 14.5 13.2 12.6 12.6 13.4

2005 14.3 15.0 14.4 13.8 13.1 13.2 14.1

2006 12.3 14.7 12.7 11.4 11.8 11.8 12.8

Figure 2.2 Annual Average PM2.5 Concentrations, All Sites 

PM2.5 Annual Avgerages

0.0

2.0

4.0

6.0

8.0

10.0

12.0

14.0

16.0

18.0

20.0

1999 2000 2001 2002 2003 2004 2005 2006

Years

ug/m3

Bllfte MLK-a Nwrk-a Lums Dover Killens Seaford

Using the 3-year average of the annual averages, the trend in annual PM2.5 NAAQS compliance 

is seen in Figure 2.3. 

22
Figure 2.3 Design value – 3-year average of annual average PM2.5 Concentrations 

have declined 

since th

.3.2 98 Percentile NAAQS 

The 98 percentile value is calculated from the total number of daily samples in a 

calenda

able 2.6 98 Percentiles 

98th percentiles 

PM2.5 Design Values - 3-year Avg Ann Avg

10.0

11.0

12.0

13.0

14.0

15.0

16.0

17.0

1999-2001 2000-2002 2001-2003 2002-2004 2003-2005 2004-2006

Years

ug/m3

Bllfte MLK-a Nwrk-a Lums Dover Killens Seaford NAAQS

Overall, annual averages showed the highest concentrations in 2001 and 

en. The trends are clearer in Figure 2.3 which shows the design value concentrations for 

each site. The only exception to the downward trend may be Seaford in Sussex County, which 

appears to show an increase in the most recent two 3-year periods (2003-2005 and 2004-2006). 

However, the long term trend remains downward, and a downward trend is anticipated to 

continue based on yet to be implemented statewide and regional control strategies discussed in 

Section 4 of this SIP. 

th 2

th

r year. Table 2.6 shows the 98th percentile value for each monitoring site for each year. 

th T

New Castle County Kent County 

Sussex 

County 

Bllfte MLK-a Nwrk-a Lums Dover Killens Seaford

1999 33.1 37.5 35.4 33.5 36.0 28.5 35.0

2000 38.2 39.3 39.8 36.4 27.8 34.4 36.0

2001 40.7 43.2 39.5 35.9 38.3 34.4 41.6

23
2002 33.8 40.6 41.5 30.6 35.5 37.1 44.0

2003 35.8 37.4 36.4 36.5 34.9 31.2 30.7

2004 32.5 34.1 29.1 30.8 28.9 31.0 35.1

2005 34.8 37.4 35.0 36.2 33.6 34.6 34.7

2006 30.9 37.7 30.5 28.8 29.9 30.7 33.3

igure 2.4 shows the data that was presented in Table2.6 in graphic format. 

igure 2.4 98 Percentile Trends 

F

th F

PM2.5 Design Values - 98th Percentiles

20.0

25.0

30.0

35.0

40.0

45.0

50.0

55.0

60.0

65.0

70.0

1999 2000 2001 2002 2003 2004 2005 2006

Years

ug/m3

Bllfte

MLK-a

Nwrk-a

Lums

Dover

Killens

Seaford

NAAQS

NAAQS new

The 98th percentile NAAQS is a 3-year average concentration. The original PM2.5

NAAQ

 

S promulgated in 1999 was 65 ug/m3. All monitoring sites in Delaware indicate 

compliance with this NAAQS. As indicted in Section 1 of this document, in December 2006 this 

NAAQS was revised from 65 ug/m3

 down to 35 ug/m3. Figure 2.6 shows the trends in the 3-year 

average 98th percentile values for each monitoring site in Delaware. The most recent 3-year 

average shows the MLK site in Wilmington exceeds the 98th percentile NAAQS. 8

8 This data is provided for information only. Because Delaware has not been designated relative to the new 35 

ug/m3

 NAAQS, this SIP does not address that NAAQS. However, control measures and strategies described in 

this SIP will reduce ambient PM2.5 concentrations relative to this new NAAQS. 

24
Figure 2.6 Three-year average 98th percentile - design values 

PM2.5 Design Values - 3-year AVg 98th Percentiles

20

25

30

35

40

45

50

55

60

65

70

99-01 00-02 01-03 02-04 03-05 04-06

Years

ug/m3

Bllfte

MLK-a

Nwrk-a

Lums

Dover

Killens

Seaford

NAAQS

NAAQS new

Using a 3-year average value smoothes out some of the year to year variability of the 

daily c

.4 Speciation Data. 

When EPA revised and promulgated the standards for PM2.5 they also included regulatory 

require

The programmatic objectives of the speciation network are to: 

• Identify annual and seasonal spatial characterization of aerosols 

ms 

ols and the application of source 

• isibility 

oncentrations and can make trends easier to detect. Figure 2.6 shows that Delaware’s 

monitors have generally decreasing concentrations since monitoring began in 1999. The most 

recent 3-year periods (2003–2005 and 2004–2006) may show a leveling off or slight increase in 

daily concentrations, but more data will be needed to determine the validity of this change. 

2

ments for monitoring the chemical composition or speciation of these particles. The 

monitors used for this purpose are referred to as speciation monitors.

• Identify air quality trends and track the progress of control progra

• Aid in the development of emission control strategies 

• Support the development of predictive modeling to

apportionment modeling for control strategy development (e.g., SIPs) 

Support programs aimed at improving environmental welfare, such as v

• Support health effects and exposure research studies 

25
The PM2.5 Speciation program incorporates National Speciation Trends Network (STN) 

sites as

The speciation samplers collect 24-hour integrated samples. The samplers use TeflonTM, 

nylon, 

The state/local agencies are responsible for siting and operations of the field monitors. 

Analys

.4.1 PM2.5 Speciation Data 

Delaware began the speciation monitoring in 2001, with the first full year of data being 

collecte

able 2.7 PM2.5 Speciation – Annual average component mass, ug/m3 

Site/Year Nitrate Sulfate Ammonium 

Organic Elemental Crustal 

com

 well as supplemental sites. The supplemental sites are State and Local Air Monitoring 

Sites (SLAMS) deployed by State, Local and Tribal agencies to allow flexibility in meeting local 

air monitoring needs. Both types of speciation sites are located primarily in urban areas with 

expected high PM2.5 concentrations, and a smaller number of sites located in more rural or 

transport areas. In Delaware, there are two supplemental SLAMS speciation sites: MLK and 

Dover. 

and quartz filter media for the collection of target analytes. The TeflonTM filter is used to 

collect particles for the analysis of mass and metals composition, samples analyzed for carbon 

components of particles are collected on the quartz filters, and samples for ion analysis are 

collected on nylon filters. 

is of the samples for the target analytes is performed by a contract laboratory. All valid 

data from the speciation samplers is submitted to the national ambient air quality system (AQS) 

database.

2

d in 2002. The following tables show the results for Delaware’s PM2.5 speciation 

program from 2002 through 2006. 

T

carbon carbon ponent

2002 2.399 4.942 2.278 5.443 0.772 0.509

2003 2.529 5.004 2.327 4.212 0.793 0.547

2004 2.164 4.454 2.107 3.475 0.655 0.684

2005 2.395 4.741 2.238 4.105 0.799 0.957

MLK 

MLK 

MLK 

MLK 

MLK 2006 2.118 4.391 2.081 4.053 0.799 1.333

Dover 2002 1.881 4.747 1.983 4.701 0.506 0.430

Dover 2003 1.762 4.205 1.720 3.076 0.436 0.392

Dover 2004 1.704 4.281 1.773 2.986 0.365 0.327

Dover 2005 1.967 4.207 1.903 3.398 0.459 0.316

Dover 2006 1.542 4.098 1.738 3.072 0.375 0.351

26
Table 2.8 PM2.5 Speciation – Annual average as percent of total mass 

Site/Year Nitrate Sulfate Ammonium 

Organic Elemental Crustal 

carbon carbon component 

MLK 2002 15% 30% 14% 33% 5% 3%

MLK 2003 16% 32% 15% 27% 5% 4%

MLK 2004 16% 33% 16% 26% 5% 5%

MLK 2005 16% 31% 15% 27% 5% 6%

MLK 2006 14% 30% 14% 27% 5% 9%

Dover 2002 13% 33% 14% 33% 4% 3%

Dover 2003 15% 36% 15% 27% 4% 3%

Dover 2004 15% 37% 16% 26% 3% 3%

Dover 2005 16% 34% 16% 28% 4% 3%

Dover 2006 14% 37% 16% 27% 3% 3%

Most eastern US speciation sites are dominated by sulfate, which is also the dominant 

species

Figure 2.7 2006 Annual Average Concentrations, Percent of Total Mass 

 at both MLK and Dover as shown in Figure 2.7. At MLK, the crustal component is 

elevated in 2006 due to nearby construction activities. Otherwise, annual component 

percentages of total mass are similar at both MLK and Dover. 

MLK

2006

Average Concentration (μg/m3)

Nitrate

14%

Sulfate

31%

Ammonium

14%

Organic carbon

27%

Elemental carbon

5%

Crustal component

9%

27
Dover

2006

Average Concentration (μg/m3)

Nitrate

14%

Sulfate

37%

Ammonium

16%

Organic carbon

27%

Elemental carbon

3%

Crustal component

3%

28
2.4.2 Speciation trends and seasonal patterns 

 in figure 2.8. Overall, there is a slight downward 

end in sulfates, nitrates, and organic carbon at both MLK and Dover. There is an increase in 

the cru

Seasonal patterns are also a characteristic of PM2.5 speciation data. As with most eastern 

US cities, sulfate is highest in the summer and nitrate is highest in the winter at both MLK and 

Dover. 

2.9. 

M2.5 is provided in Section 6-7 of this Document, which presents a conceptual model for the 

regiona

Trends in major components are shown

tr

stal component at MLK due to nearby construction.

Figure 2.8 Major component trends 

Annual Avg PM2.5 Sulfate

 Organic carbon is highest in the summer and fairly constant in other seasons at both 

sites. In general, relative composition of PM2.5 is similar at both MLK and Dover. Seasonal 

average major components as percent total mass at the MLK monitor are presented in Figure 

Additional information and discussion on the major components and characteristics of 

P

l and local particulate matter sources. 

Annual Avg PM2.5 Organic Carbon (unadjusted)

0.0

0.5

1.0

1.5

2.0

2.5

3.0

3.5

4.0

4.5

5.0

2002 2003 2004 2005 2006

Year

ug/m3

MLK Dover

Annual Avg PM2.5 Nitrate

0.0

0.5

1.0

1.5

2.0

2.5

3.0

2002 2003 2004 2005 2006

Year

ug/m3

MLK Dover MLK Dover

0.0

1.0

2.0

3.0

4.0

5.0

6.0

2002 2003 2004 2005 2006

Year

ug/m3

Annual Average PM2.5 Crustal Component

0.0

0.4

0.8

1.2

1.6

2.0

2002 2003 2004 2005 2006

Year

Average ug/m3

MLK Dover

29
Figure 2.9 Seasonal Components of PM2.5

Average Winter Sulfate Concentration at MLK

Sulfate 

21%

Nitrate

24%

Ammonium

14%

EC

7%

OC

30%

Crustal

4%

Average Spring Sulfate Concentrations at MLK

Sulfate

31%

Nitrate

19%

Ammonium

16%

EC

5%

OC

24%

Crustal

5%

30
Average Fall Sulfate Concentrations at MLK

Sulfate

29%

Nitrate

15

%

Ammonium

13

%

EC

6%

OC

31%

Crustal

6%

Average Summer Sulfate Concentrations at MLK

Sulfate

43%

Nitrate

7%

Ammonium

16%

EC

4%

OC

27%

Crustal

3%

31
2.5 Other monitors in the Philadelphia Non-attainment Area 

As stated previously, Delaware is part of the Philadelphia based PM2.5 non-attainment 

area. To compare Delaware’s monitors with others in the CMSA, the estimated design values 

(three-year averages of the annual averages) were calculated using data from the national AQS 

database. The data was not adjusted for missing data, so the values listed are estimates only and 

not official design values. The three-year average design values were then plotted in Figure 2.10 

for each individual monitor. 

Table 2.9 Philadelphia CMSA estimated design values (three-year averages), excluding 

Delaware 

Years 

Fairhill 

Atl. City 

Camden 

M-D WTP 

Gibbstown 

Bristol 

Ches-ter 

Norristown 

AMS lab 

Belmont Ave 

WTP 

NE Airport 

S.Broad St. 

Amtrak/ 

Elmwood 

2000-2002 13.4 11.4 14.5 14.8 14.2 14.1 15.5 14.0 15.3 14.6 14.3 16.6 15.2

2001-2003 13.0 11.6 14.9 14.3 13.8 14.3 15.3 14.1 15.2 14.3 13.8 16.2 14.9

2002-2004 12.8 11.4 14.5 13.9 13.1 13.9 15.0 13.2 14.4 13.8 13.2 15.4 13.6

2003-2005 13.2 11.5 14.7 13.8 13.5 13.9 15.6 12.8 14.3 14.4 13.0 15.2 13.7

2004-2006 12.8 11.6 13.3 13.3 13.3 13.2 15.2 12.2 13.9 14.7 12.7 15.0 13.4

32
33

Figure 2.10 Estimated design values for Philadelphia CMSA monitors 

ture rate, and do not 

Design Values: 3-Year Averages All Monitors Philadelphia CMSA

10

11

12

13

14

15

16

17

18

2000-2002 2001-2003 2002-2004 2003-2005 2004-2006

ug/m3

Fairhill

Atlantic City

Camden

Morris-Delair WTP

Gibbstown

Bristol

Chester

Norristown

AMS lab

Belmont Ave WTP

NE Airport

South Broad St.

Amtrak/Elmwood

Bellefonte

MLK

Newark

Lums Pond

Dover

Killens Pond

Seaford

Note: Design values were calculated for each site regardless of data cap

represent final or official design values and are shown for comparison purposes only. 
Section 3 - Delaware 2002 Base Year Emission Inventory 

3.1 2002 PM2.5 and Precursor Inventory Overview. 

EPA established calendar year 2002 as the base year inventory for the PM2.5 standard. 

This requires states with PM2.5 non-attainment areas to submit to the EPA no later than three 

years after designation, as part of their State Implementation Plan (SIP), a statewide 

comprehensive, accurate, and current base year inventory of actual emissions of PM2.5 and its 

precursors. 

This section summarizes Delaware’s 2002 statewide inventory of PM2.5 and PM2.5

precursors for all sources, which are categorized into the following five major source sectors: 

stationary point, stationary non-point, on-road mobile, non-road mobile, and natural. For 

additional information on methods, data collection and QA procedures, refer to 2002 Base Year 

State Implementation Plan Emissions Inventory for PM2.5 and Precursors, Delaware Department 

of Natural Resources and Environmental Control, Air Quality Management Section, Dover, 

Delaware, April 2007; hereafter referred to as the “2002 base year inventory.” 

 

The parameters defined by the 2002 base year inventory included the following: 

• Inventory year – calendar year 2002; 

• Pollutants – particulate matter and particulate matter precursors, which include PM10, 

PM2.5, SO2, NOx, NH3, and VOCs; 

• Source coverage – all sources, including point, stationary non-point, on-road mobile, 

non-road, and natural sources; 

• Geographic coverage – entire State of Delaware; 

• Temporal resolution – annual emissions. 

3.2 Emissions Summary. 

 

The following emission summaries present the entire 2002 emission inventory for PM10, 

PM2.5, SO2, NOx, NH3, and VOCs, broken down by county and source sector. Natural sources of 

emissions are presented separately from anthropogenic sources of emissions. Throughout this 

document, annual emissions are reported in tons per year (TPY). 9 

Table 3-1 2002 PM2.5 and Precursor Emissions by County 

Annual Emissions (TPY) 

County PM10 PM2.5 SO2 NOx NH3 VOC 

Kent 3,991 1,097 4,062 10,314 2,841 5,296 

New Castle 8,604 3,430 50,237 30,748 1,384 18,062 

Sussex 6,758 2,575 25,552 16,060 10,057 10,251 

Statewide 19,353 7,102 79,852 57,122 14,284 33,610 

 

9 Note that the totals may not match the sum of the individual values due to independent rounding 

34
Table 3-2 2002 Statewide Emissions by Source Sector 

Annual Emissions (TPY) 

Source Sector PM10 PM2.5 SO2 NOx NH3 VOC 

Point 3,859 3,161 73,708 16,372 179 4,773 

Non-point 13,870 2,580 1,330 2,427 13,194 10,254 

On-road 581 415 584 21,341 903 10,564 

Non-road 1,043 946 4,230 16,982 8 8,019 

All Sectors 19,353 7,102 79,852 57,122 14,284 33,610 

Table 3-3. 2002 New Castle County Emissions by Source Sector 

Annual Emissions (TPY) 

Source Sector PM10 PM2.5 SO2 NOx NH3 VOC 

Point 2,168 1,733 47,070 9,157 118 2,687 

Non-point 5,674 1,073 780 1,513 710 6,198 

On-road 304 209 326 11,799 552 5,762 

Non-road 458 415 2,061 8,279 4 3,415 

All Sectors 8,604 3,430 50,237 30,748 1,384 18,062 

Figure 3-1. PM2.5 Emissions by County

Kent

15%

New Castle

49%

Sussex

36%

35
Figure 3-2. SO2 Emissions by County

Kent

5%

New Castle

63%

Sussex

32%

Figure 3-3. NOx Emissions by County

Kent

18%

New Castle

54%

Sussex

28%

36
Figure 3-4. NH3 Emissions by County

Kent

20%

New Castle

10%

Sussex

70%

Figure 3-5. PM2.5 Emissions by Source Sector

Point

45%

Non-point

36%

On-road

6%

Non-road

13%

37
Figure 3-6. SO2 Emissions by Source Sector

Point

92%

Non-road

5%

Non-point

2%

On-road

1%

Figure 3-7. NOx Emissions by Source Sector

Point

29%

Non-point

4%

On-road

37%

Non-road

30%

38
Figure 3-8. NH3 Emissions by Source Sector

Non-point

93%

Point

1%

Non-road

< 1%

On-road

6%

3.3 Stationary Point Sources. 

The point source inventory represents facility-specific data for Delaware’s larger 

stationary sources. Point sources typically include large industrial, commercial and institutional 

facilities. Manufacturing facilities, within the industrial sector, comprise the majority of all 

reporting point sources. The institutional sector includes hospitals, universities, prisons, military 

bases, landfills, and wastewater treatment plants. Table 3-4 presents a listing of Delaware’s 136 

point sources. 

Table 3-4 Point Source Facilities in Delaware 2002 Base Year Inventory 

# Facility Location Facility ID Facility Name 

1 Kent County, DE 1000100026 BAYHEALTH MED CENTER KENT GENERAL HOSP 

2 1000100154 BURRIS LOGISTICS HARRINGTON 

3 1000100099 CAMDEL METALS CORPORATION 

4 1000100002 CITY OF DOVER - MCKEE RUN GENERATING STA 

5 1000100076 CITY OF DOVER VAN SANT GENERATING STA 

6 1000100121 COLOR-BOX LLC 

7 1000100068 DE SOLID WASTE AUTHORITY SANDTOWN 

8 1000100066 DELAWARE STATE UNIVERSITY 

9 1000100001 DOVER AIR FORCE BASE 

10 1000100016 DOW REICHHOLD SPECIALTY LATEX LLC 

39
11 1000100024 HANOVER FOODS CORPORATION 

12 1000100012 HARRIS MANUFACTURING CO INC 

13 1000100067 HIRSH INDUSTRIES 

14 1000100011 ILC DOVER INC. 

15 1000100007 KRAFT FOODS NORTH AMERICA 

16 1000100178 LEHIGH VALLEY DAIRY 

17 1000100127 NRG ENERGY CENTER DOVER LLC 

18 1000100075 PERDUE FARMS INC - MILFORD 

19 1000100004 PROCTOR AND GAMBLE DOVER WIPES COMPANY 

20 1000100157 QUALITY KITCHEN CORP 

21 1000100006 TILCON DELAWARE - BAY ROAD 

22 1000100014 TILCON DELAWARE - HORSEPOND ROAD 

23 1000100087 TRAPPE PACKING CORPORATION 

24 1000100161 UNITED STATES COLD STORAGE 

25 1000100152 WARREN F BEASLEY POWER STATION 

26 New Castle County, DE 1000300377 AGILENT TECHNOILOGIES 

27 1000300064 AIR LIQUIDE AMERICA L P 

28 1000300131 ALFRED I DUPONT HOSPITAL FOR CHILDREN 

29 1000300029 AMETEK INC CHEMICAL PRODUCTS DIVISION 

30 1000300288 AMI ASSET ACQUISITION CO 

31 1000300023 AMTRAK WILMINGTON MAINTENANCE FACILITY 

32 1000300059 ARLON, INC. 

33 1000300106 ASTRAZENECA PHARMACEUTICALS LP-FAIRFAX 

34 1000300612 BURRIS LOGISTICS - NEW CASTLE 

35 1000300080 CHRISTIANA CARE - CHRISTIANA HOSPITAL 

36 1000300024 CHRISTIANA CARE - WILMINGTON HOSPITAL 

37 1000300068 CHRISTIANA MATERIALS 

38 1000300003 CIBA SPECIALTY CHEMICALS CORP 

39 1000300063 CLAYMONT STEEL 

40 1000300290 CLEAN EARTH OF NEW CASTLE 

41 1000300317 CONECTIV DELMARVA GENERATION-CHRISTIANA 

42 1000300005 CONECTIV DELMARVA GENERATION-DEL CITY 

43 1000300007 CONECTIV DELMARVA GENERATION-EDGE MOOR 

44 1000300388 CONECTIV DELMARVA GENERATION-HAY ROAD 

45 1000300046 CONECTIV DELMARVA GENERATION-MADISON ST 

46 1000300006 CONECTIV DELMARVA GENERATION-WEST_SUBST 

47 1000300066 CONTRACTORS MATERIALS LLC HOT MIX PLT 

48 1000300128 DAIMLERCHRYSLER CORPORATION 

49 1000300365 DASSAULT FALCON JET-WILMINGTON CORP 

50 1000300111 DE SOLID WASTE AUTHORITY CHERRY ISLAND 

51 1000300086 DE SOLID WASTE AUTHORITY PIGEON POINT 

52 1000300090 DELAWARE CORRECTIONAL CENTER - SMYRNA 

53 1000300415 DELAWARE RECYCLABLE PRODUCTS INC 

40
54 1000300613 DELAWARE REFRIGERATED SERVICES 

55 1000300077 DEPT OF VETERANS AFFAIRS MEDICAL CENTER 

56 1000300069 DIAMOND MATERIALS LLC 

57 1000300126 DUPONT CHESTNUT RUN 

58 1000300010 DUPONT EDGEMOOR 

59 1000300011 DUPONT EXPERIMENTAL STATION 

60 1000300279 DUPONT STINE - HASKELL LABORATORY 

61 1000300049 DUPONT WILMINGTON OFFICE BUILDING 

62 1000300073 E-A-R SPECIALTY COMPOSITES 

63 1000300040 EDGEMOOR MATERIALS INC 

64 1000300051 FMC BIOPOLYMER 

65 1000300027 FORMOSA PLASTICS CORPORATION 

66 1000300037 FP INTERNATIONAL INC 

67 1000300500 GE ENERGY (USA) LLC 

68 1000300032 GENERAL CHEMICAL CORPORATION 

69 1000300015 GENERAL MOTORS CORPORATION 

70 1000300513 HARDCORE COMPOSITES, DIV. OF HARRIS SPEC 

71 1000300017 HERCULES INCORPORATED RESEARCH CENTER 

72 1000300038 HONEYWELL INTERNATIONAL INC 

73 1000300367 INTERNATIONAL PETROLEUM CORP OF DELAWARE 

74 1000300102 JOHNSON CONTROLS BATTERY GROUP INC 

75 1000300350 KANEKA DELAWARE CORPORATION 

76 1000300129 LAFARGE NORTH AMERICA INC 

77 1000300028 LAIDLAW CORPORATION 

78 1000300104 MACDERMID INC 

79 1000300291 MAGELLAN TERMINALS HOLDINGS, L.P. 

80 1000300383 MEDAL A DIV OF AIR LIQUIDE ADV TECH US 

81 1000300074 METACHEM PRODUCTS LLC 

82 1000300324 NORAMCO INC 

83 1000300018 NVF COMPANY INC - YORKLYN FACILITY 

84 1000300030 OCCIDENTAL CHEMICAL CORPORATION 

85 1000300282 PEPSI COLA BOTTLING COMPANY 

86 1000300016 PREMCOR DELAWARE CITY REFINERY 

87 1000300404 PREMCOR TERMINAL 

88 1000300093 PRINTPACK INC 

89 1000300382 PTFE COMPOUNDS INC 

90 1000300463 PURE GREEN INDUSTRIES INC 

91 1000300033 ROHM & HAAS ELECTRONIC MATERIALS CMP TE 

92 1000300381 SPATZ FIBERGLASS PRODUCTS 

93 1000300426 SPI POLYOLS INC 

94 1000300133 ST. FRANCIS HOSPITAL 

95 1000300021 SUNOCO INC MARCUS HOOK REFINERY 

96 1000300092 THE CROWELL CORPORATION 

41
97 1000300696 THE POND ICE ARENA 

98 1000300048 TILCON DELAWARE - TERMINAL AVENUE 

99 1000300058 UNIQEMA 

100 1000300067 UNISOURCE WORLDWIDE INC 

101 1000300022 UNIVERSITY OF DELAWARE NEWARK 

102 1000300127 VPI FILM LLC 

103 1000300121 WESTVACO CORPORATION 

104 1000300004 WILMINGTON PIECE DYE CO 

105 1000300389 WILMINGTON WASTEWATER TREATMENT PLANT 

106 Sussex County, DE 1000500013 ALLEN FAMILY FOODS INC 

107 1000500016 ALLEN'S HATCHERY INC ALLEN'S MILLING 

108 1000500036 BAYHEALTH MEDICAL CTR - MILFORD MEMORIAL 

109 1000500187 CANNON COLD STORAGE 

110 1000500029 CITY OF LEWES POWER PLANT 

111 1000500108 CITY OF SEAFORD-ELECTRIC POWER PLANT 

112 1000500099 DE SOLID WASTE AUTHORITY SOUTHERN 

113 1000500120 EDWARD J. KAYE CONSTRUCTION 

114 1000500001 INDIAN RIVER GENERATING STATION 

115 1000500002 INVISTA 

116 1000500183 J G TOWNSEND 

117 1000500006 JOHNSON POLYMER INC 

118 1000500066 JUSTIN TANKS LLC 

119 1000500027 LEWES DAIRY INC 

120 1000500093 MARITRANS 

121 1000500028 MIL-DEL CORPORATION 

122 1000500004 MOUNTAIRE FARMS OF DELAWARE INC-MILLSBOR 

123 1000500073 MOUNTAIRE FARMS OF DELMARVA - SELBYVILLE 

124 1000500012 MOUNTAIRE FARMS OF DELMARVA FRANKFORD 

125 1000500121 MULTI-TECH INC 

126 1000500011 ORIENT CORPORATION OF AMERICA 

127 1000500003 PERDUE FARMS - BRIDGEVILLE 

128 1000500075 PERDUE FARMS INC - GEORGETOWN 

129 1000500146 PERDUE-AGRIRECYCLE LLC 

130 1000500025 PICTSWEET COMPANY 

131 1000500071 PINNACLE FOODS CORPORATION - VLASIC PLNT 

132 1000500009 SEA WATCH INTERNATIONAL LTD 

133 1000500188 SEAFORD ICE INC 

134 1000500196 THE MARBLE WORKS 

135 1000500130 TILCON DELAWARE - GEORGETOWN 

136 1000500026 TILCON DELAWARE GUMBORO 

42
3.4 Stationary Non-Point Sources. 

Stationary non-point sources10 represent a large and diverse set of individual emission 

source categories. A non-point source category is either represented by small facilities too 

numerous to individually inventory, such as restaurants (commercial cooking), or is a common 

activity, such as fugitive dust from construction and agricultural production. Emissions from the 

non-point source categories were estimated at the county level. 

There are many stationary non-point source categories which emit fine particulate (PM2.5) 

and/or PM2.5 precursors. These are grouped into the following category types: 

• Fuel Combustion – The combustion of fuels in industrial, commercial, institutional, 

and residential furnaces, engines, boilers, wood stoves, and fireplaces create emissions 

of PM2.5 and precursors. 

• Open Burning – Open burning creates emissions of PM2.5 and precursors. “Open 

burning” loosely refers to trash burning, prescribed burning, burning of land clearing 

material, wildfires, and house and vehicle fires. 

• Fugitive Dust – Primary crustal particulate is created from construction activities, 

agricultural production, and as a result of vehicle traffic. Fugitive dust is largely 

coarse material, with only a small percentage being fine particulate. 

• Ammonia Sources – Several categories contribute ammonia emissions, including 

agricultural fertilizer application, animal husbandry, and wastewater treatment plants. 

• VOC Sources – Many products used by homeowners and businesses contain VOC 

solvents. Paints, cleaners, pesticides, personal care products, and inks are a few 

examples of products that contain VOC solvents. The distribution and use of gasoline 

in vehicles and other gasoline-powered engines is another large source of VOC 

emissions. 

Table 3-5 presents a listing of Delaware’s stationary non-point source categories. Note that there 

were several source categories evaluated, but not included, in the stationary non-point source 

inventory. These source categories, and the reason for not including them, are: 

• Agricultural Burning – No activity for the burning of either crop residue was 

identified. The Delaware Department of Agriculture has indicated this activity is not 

practiced in Delaware. Crop residues are left to biodegrade in place or are tilled under 

at the time of planting of the next crop. 

• Breweries, Wineries, and Distilleries – Delaware is home to only a few very small 

wineries and several microbreweries. There are no distilleries in Delaware. Since 

emission estimates for this source category in past inventories have been negligible 

 

10 Stationary Non-Point Sources have formerly been termed as “area sources.”

43
(less than one ton of VOCs per year), the category was eliminated from further 

consideration. 

• Crematories – While there are at least a dozen human/pet crematories and several 

laboratory animal incinerators in Delaware, AQMS was unable to locate emission 

factors for PM2.5 and precursors. Emissions from fuels used at these facilities are 

included in the commercial fuel combustion category. 

• Dover Speedway – An attempt was made to quantify emissions from racing vehicles 

participating in the two major race weekends that are held at the speedway each year. 

However, there were no emission factors associated with the unique engines, fuels, 

and operating conditions associated with racing vehicles. Applying uncontrolled (i.e., 

non-catalyst) light-duty truck emission factors yielded negligible emissions for the 

four races performed each year. 

• Feed Mills and Concrete Plants - These industry sectors were considered a source of 

particulate matter, both from material handling processes and fugitive dust (i.e., 

storage piles). Several large feed mills in Delaware already met the criteria for 

reporting as a Title V facility due to combustion emissions from process boilers and 

grain dryers, and are included in the point source portion of the 2002 BY. The lack of 

quality emissions data (i.e., emission factors) for feed mills persuaded AQMS to not 

specifically inventory smaller feed mills. Lack of data was also the reason for not 

further considering concrete plants. 

• Slash Burning - No activity for the burning of slash from logging for future 

silvicultural operations was identified. This was confirmed by the Delaware Division 

of Forestry. However, recently logged lands are occasionally converted to agriculture. 

This activity, previously reported as slash burning, is now reported under the land 

clearing debris burning category. 

Table 3-5. Non-Point Sources in Delaware 2002 Base Year Inventory 

Agricultural Fertilizer Application Industrial Surface Coatings 

Agricultural Pesticides Land Clearing Debris Burning 

Agricultural Production Leaking Underground Storage Tanks 

AIM Coatings Miscellaneous Ammonia Source 

Animal Husbandry Paved & Unpaved Road Dust 

Asphalt Paving Prescribed Burning 

Auto Refinishing Publicly-Owned Treatment Works 

Bakeries Residential Construction 

Catastrophic/Accidental Releases Residential Fuel Combustion 

Commercial Construction Residential Open Burning 

Commercial Cooking Residential Wood Combustion 

Commercial & Consumer Products Road Construction 

Commercial Fuel Combustion Sand & Gravel Operations 

44
Dry Cleaning Solvent Cleaning 

Gasoline (Petroleum) Marketing Structure Fires 

Graphic Arts Traffic Markings 

Inactive Landfill Vehicle Fires 

Industrial Adhesives Wildfires 

Industrial Fuel Combustion 

Table 3-6 provides a statewide summary of the 2002 annual (tons per year, TPY) emissions for 

each non-point source category, and Table 3-7 provides this information for New Castle County. 

Table 3-6. Summary of 2002 Statewide Emissions from Non-point Sources 

PM10 PM2.5 SO2 NOX NH3 VOC 

Source Categories TPY TPY TPY TPY TPY TPY 

FUEL COMBUSTION 

Commercial/Institutional 15 14 233 405 25 19 

Industrial 9 7 122 715 40 28 

Residential Fossil Fuel 66 58 946 1,140 118 52 

Residential Wood 796 796 11 75 42 679 

Fuel Combustion Total 886 874 1,313 2,335 225 777 

OPEN BURNING 

Residential Open Burning 48 42 3 14 1 27 

Land Clearing Debris Burning 74 74 --- 22 --- 51 

Prescribed Burning 139 119 8 31 6 67 

Structure Fires 24 22 --- 3 --- 25 

Vehicle Fires 6 6 --- < 1 --- 2 

Wildfires 99 85 6 22 5 48 

Open Burning Total 390 349 17 92 12 219 

FUGITIVE DUST 

Agricultural Production 1,670 370 --- --- --- --- 

Commercial Construction 810 81 --- --- --- --- 

Paved and Unpaved Road Dust 7,951 499 --- --- --- --- 

Residential Construction 246 25 --- --- --- --- 

Road Construction 1,635 163 --- --- --- --- 

Sand & Gravel Operations 62 15 --- --- --- --- 

Fugitive Dust Total 12,374 1,154 --- --- --- --- 

AMMONIA SOURCES 

Agricultural Fertilizer Application --- --- --- --- 1,247 --- 

Animal Husbandry --- --- --- --- 11,662 --- 

Miscellaneous Ammonia Sources --- --- --- --- 41 --- 

45
Ammonia Sources Total --- --- --- --- 12,950 --- 

OTHER SOURCES 

Bakeries --- --- --- --- --- 1 

Catastrophic/Accidental Releases --- --- --- < 1 < 1 1 

Commercial Cooking 219 203 --- --- --- 30 

Gasoline Marketing -- --- --- --- --- 2,116 

Landfills (Inactive) -- --- --- --- --- 42 

Leaking UST Remediations -- --- --- --- --- 13 

POTWs -- --- --- --- 7 1 

Solvent Use -- --- --- --- --- 7,054 

Other Sources Total 219 203 --- < 1 7 9,258 

NON-POINT SECTOR TOTAL 13,870 2,580 1,330 2,427 13,194 10,254 

Table 3-7. Summary of 2002 Non-point Emissions for New Castle County 

PM10 PM2.5 SO2 NOX NH3 VOC 

Source Categories TPY TPY TPY TPY TPY TPY 

FUEL COMBUSTION 

Commercial/Institutional 9 8 136 298 20 14 

Industrial 6 4 79 465 21 18 

Residential Fossil Fuel 35 31 550 679 94 34 

Residential Wood 446 446 7 41 24 364 

Fuel Combustion Total 496 489 772 1,484 158 430 

OPEN BURNING 

Residential Open Burning 13 12 1 4 < 1 8 

Land Clearing Debris Burning 0 0 --- 0 --- 0 

Prescribed Burning 109 94 7 24 5 53 

Structure Fires 8 7 --- 1 --- 8 

Vehicle Fires 3 3 --- < 1 --- 1 

Wildfires < 1 < 1 < 1 < 1 < 1 < 1 

Open Burning Total 134 116 7 29 5 70 

FUGITIVE DUST 

Agricultural Production 238 53 --- --- --- --- 

Commercial Construction 607 61 --- --- --- --- 

Paved and Unpaved Road Dust 3,380 158 --- --- --- --- 

Residential Construction 91 9 --- --- --- --- 

Road Construction 570 57 --- --- --- --- 

Sand & Gravel Operations 22 4 --- --- --- --- 

Fugitive Dust Total 4,908 341 --- --- --- --- 

AMMONIA SOURCES 

Agricultural Fertilizer Application --- --- --- --- 158 --- 

46
Animal Husbandry --- --- --- --- 362 --- 

Miscellaneous Ammonia Sources --- --- --- --- 26 --- 

Ammonia Sources Total --- --- --- --- 546 --- 

OTHER SOURCES 

Bakeries --- --- --- --- --- 1 

Catastrophic/Accidental Releases --- --- --- < 1 --- 1 

Commercial Cooking 137 127 --- --- --- 19 

Gasoline Marketing -- --- --- --- --- 1,145 

Landfills (Inactive) -- --- --- --- --- 2 

Leaking UST Remediations -- --- --- --- --- 2 

POTWs -- --- --- --- < 1 < 1 

Solvent Use -- --- --- --- --- 4,529 

Other Sources Total 137 127 --- < 1 < 1 5,698 

NON-POINT SECTOR TOTAL 5,674 1,073 780 1,513 710 6,198 

3.5 On-Road Mobile Sources. 

The 2002 base year emission inventory of the on-road mobile source sector was 

conducted by Pechan, with technical support from the EID staff. The on-road mobile sources 

cover all highway vehicles including passenger cars, light-duty trucks, sport utility vehicles, 

heavy-duty trucks, buses, and motorcycles, which traveled on Delaware’s roadways in 2002. 

The AQM mobile sources lead and EID staff gathered the actual vehicle miles traveled 

(VMT) on Delaware’s roadways and vehicle mix data from the Delaware Department of 

Transportation (DelDOT), and evaluated all information about control measures effective in 

2002. With the vehicle mix data and control information, Pechan used EPA’s MOBILE6.2 

model to generate emission factors for each vehicle type traveling on each of the 11 functional 

road classes. The emission factors and the VMT data were then used to calculate PM2.5 and 

precursor emissions for each vehicle type on each road class. The end products of the 

calculations were sums of PM2.5 and precursor emissions for all vehicles on all road classes in 

each of the three counties in Delaware. After two rounds of QC/QA reviews and revision by 

Pechan’s staff and EID staff, the emission data was finalized, and included in the final 2007 base 

year inventory. 

On-road mobile source inventory information is presented in Table 3-8, Table 3-9, and 

Table 3-10. 

47
Table 3-8. 2002 Annual Emissions and VMT for On-road Mobile Sources by County

Annual Emissions (TPY) 

County PM10 PM2.5 SO2 NOx NH3 VOC 106 miles 

Kent 118 89 105 4,182 139 1,737 1,406

New Castle 304 209 326 11,799 552 5,762 5,338

Sussex 159 117 152 5,360 211 3,065 2,091

Total 581 415 584 21,341 903 10,564 8,835

Table 3-9. 2002 Annual PM Exhaust, Brake Wear, and Tire Wear Emissions by County 

PM10 Emissions (TPY) PM2.5 Emissions (TPY) 

County Exhaust 

Brake 

Wear 

Tire 

Wear Total Exhaust 

Brake 

Wear 

Tire 

Wear Total 

Kent 84 19 15 118 77 8 4 89

New Castle 179 74 52 304 164 31 13 209

Sussex 109 29 21 159 100 12 5 117

Total 371 122 88 581 341 52 22 415

Table 3-10 2002 Statewide Annual Emissions and VMT for On-road Mobile Sources by Vehicle 

Type 

Annual Emissions (TPY) 

Vehicle Type PM10 PM2.5 SO2 NOx NH3 VOC 

Light-duty Gasoline Vehicles 129 63 167 5,789 484 5,538

Light-duty Gasoline Trucks 111 57 187 5,028 386 4,195

Heavy-duty Gasoline Vehicles 28 20 25 1,423 13 319

Motorcycles 2 1 1 71 1 116

Light-duty Diesel Vehicles 2 2 < 1 9 < 1 5

Light-duty Diesel Trucks 3 3 2 23 < 1 11

Heavy-duty Diesel Vehicles 307 269 201 8,996 18 379

Total 581 415 584 21,341 903 10,564

3.6 Non-Road Mobile Sources. 

Non-road mobile sources include a large and diverse set of off-road vehicles and nonstationary equipment. Non-road vehicles and equipment were grouped into four source category 

types for the purpose of developing emission estimates. These groups are: 

1. Aircraft – Commercial, military, and private aircraft are considered under this source 

category. 

48
2. Locomotives – Commercial line haul and yard locomotives are considered under this 

source category. 

3. Commercial Marine Vessels (CMVs) – Various types of vessels that navigate the 

Delaware Bay and River and the Chesapeake and Delaware Canal are included under 

this source category. Recreational boats were included in the next category. 

4. Other Off-road Vehicles and Equipment – All other off-road emission sources were 

accounted for through the use of EPA’s NONROAD model. The NONROAD model 

compiles off-road equipment pertinent to Delaware into the following subcategories: 

o Recreational (land-based); 

o Construction and Mining; 

o Industrial; 

o Lawn and Garden; 

o Agricultural; 

o Commercial; 

o Logging; 

o Airport Ground Support; 

o Recreational Marine; and 

o Railway Maintenance. 

Emissions from aircraft, locomotives, and CMVs were calculated using appropriate 

emission factors and emission controls in effect in 2002. Emissions of all other non-road sources 

(i.e., the 4th group in the list above) were estimated using EPA’s NONROAD model, which 

further divided these vehicles and equipment by fuel types, including 2-stroke gasoline, 4-stroke 

gasoline, diesel, liquefied petroleum gas (LPG), and compressed natural gas (CNG). After two 

rounds of QC/QA reviews and revision by Pechan’s staff and EID staff, the emission data were 

finalized, and included in the final SIP 2002 base year inventory. 

Table 3-11 and Table 3-12 present a summary of Delaware’s 2002 base year inventory 

for the non-road mobile source sector. 

Table 3-11. 2002 Statewide Emissions from Non-road Sources 

Source Categories PM10 PM2.5 SO2 NOx NH3 VOC 

NONROAD Model Equipment 570 525 513 5,798 5 7,531

Aircraft 28 20 30 970 --- 291

Locomotives 29 26 63 1,097 < 1 57

Commercial Marine Vessels 415 374 3,624 9,118 3 140

NON-ROAD SECTOR TOTAL 1,043 946 4,230 16,982 8 8,019

49
Table 3-12. 2002 Statewide Annual Emissions for NONROAD Equipment 

Annual Emissions (TPY) 

 Fuel Type Equipment Category PM10 PM2.5 SO2 NOx NH3 VOC 

Recreational 19 17 1 23 < 1 612 

Construction 7 6 < 1 24 < 1 166 

Industrial 1 1 < 1 54 < 1 58 

Lawn & Garden 75 69 6 330 1 2,805 

Agriculture < 1 < 1 < 1 8 < 1 18 

Light Commercial 5 5 2 96 < 1 413 

Logging < 1 < 1 < 1 < 1 < 1 3 

Airport Support < 1 < 1 < 1 < 1 < 1 < 1 

Railway Maintenance < 1 < 1 < 1 < 1 < 1 1 

Gasoline 

Recreational Marine 44 40 4 201 1 2,726 

Recreational 1 1 < 1 3 < 1 1 

Construction 234 215 299 2,415 2 279 

Industrial 41 37 56 403 < 1 44 

Lawn & Garden 12 11 13 108 < 1 16 

Agriculture 102 94 92 828 < 1 101 

Light Commercial 21 19 21 167 < 1 29 

Logging < 1 < 1 1 6 < 1 <1 

Airport Support 1 1 1 8 < 1 1 

Railway Maintenance 1 1 1 8 < 1 2 

Diesel 

Recreational Marine 3 3 14 108 < 1 4 

LPG All Equipment 4 4 1 920 0 249 

CNG All Equipment < 1 < 1 < 1 87 0 1 

All Fuels Total 570 525 513 5,798 5 7,531 

3.7 Natural Sources. 

Natural sources of emissions of primary particulate matter and particulate matter 

precursors were included in the 2002 inventory to gain a more complete picture of fine 

particulate emissions. For Delaware, natural sources include biogenic source emissions (VOCs 

and NOx), NOx emissions due to lightning, and PM10 and PM2.5-PRI from wind-blown dust. 

Note that the wildfire category was not included as a natural source, but was instead included in 

the non-point section because the few wildfires in Delaware are a result of human activities (i.e., 

untended fire, discarded cigarette butt, arson). Emissions for natural sources are reported for the 

following activities: 

• Biogenic source emissions resulting from biological activity represent a significant 

portion of the natural source emissions. The biological activity of plants, especially 

50
trees, emit a significant amount of VOCs in Delaware, which can react to form 

secondary organic aerosols. Microbial activity within soil is responsible for 

emissions of nitrogen-containing compounds, including nitrogen oxides (NOx). 

• Lightning is a source of nitric oxide (NO). Lightning forms NO through a high 

temperature reaction from the energy released during a lightning flash. Lightning can 

release about 105 Joules per meter (J/m), and produce temperatures of about 30,000 

degrees Kelvin (°K). NO is in thermodynamic equilibrium with nitrogen and oxygen 

at temperatures above 2300°K, and as the heated air rapidly cools below 2000°K, NO 

becomes a steady-state species. 

• Particulate emissions also result from wind erosion of vacant lands, such as tilled 

agricultural land and other disturbed land without vegetative cover. Wind-blown dust 

emissions from vacant agricultural lands are believed to be the only significant 

natural source in Delaware. Therefore, this is the only type of land use that was 

covered. Emissions were calculated at the county level using crop acreage data from 

the Delaware Agricultural Statistics Service (DASS). 

Table 3-13 provides a summary of Delaware’s 2002 emission from natural sources, by 

county. 

Table 3-13. 2002 Emissions for Natural Sources by County 

Annual Emissions (TPY) 

County PM10 PM2.5 SO2 NOx NH3 VOC 

Kent 7,457 1,119 --- 251 --- 9,139 

New Castle 3,007 451 --- 159 --- 6,332 

Sussex 10,218 1,439 --- 354 --- 11,109 

Statewide 20,682 3,009 --- 764 --- 26,580 

References 

3-1. 2002 Base Year State Implementation Plan Emissions Inventory for PM2.5 and 

Precursors, Delaware Department of Natural Resources and Environmental Control, Air 

Quality Management Section, Dover, Delaware, December 15, 2007

51
Section 4 - Control Measures and 2009 Emission Projections 

As indicted in Section 1 of this Document, Delaware and the entire Philadelphia NAA are 

required to attain compliance with the PM2.5 NAAQS by April 2010. Since the PM2.5 NAAQS is 

both an annual and a 24-hr standard, this effectively requires Delaware and the Philadelphia 

NAA to attain the PM2.5 NAAQS in 2009 (i.e., 2009 is the last full year prior to the April 2010 

attainment date). 

This Section presents a projection of the level Delaware expects emissions of PM2.5 and 

PM2.5 precursors to be in 2009. This projection gives consideration to factors such as growth 

that will occur between 2002 (i.e., Delaware base year) and control strategies that Delaware and 

the EPA have adopted which are not included in the 2002 base year, and which will reduce 

emissions in 2009. This 2009 projection will be evaluated in Sections 5 and 6 of this document 

to show that emission levels will be sufficiently low in 2009 to yield attainment of the PM2.5

NAAQS. 

A complete 2009 projection inventory was coordinated by MANEVU in 2005. This 

included 2009 emissions projections: 

• For non-EGU point sources, non-point sources, and non-road mobile sources, 

which were conducted under contract by MACTEC Federal Programs, Inc. 

(hereafter referred to as MACTEC). 11

• For EGU emissions, which were projected under contract by ICF, Inc. using the 

Integrated Planning Model (IPM). 12

• For on-road mobile emissions, which were projected by NESCAUM and New 

York via SMOKE, using state specific inputs, to include Delaware Department of 

Transportation VMT and speed data. 12

Delaware is basing its 2009 emission projection for this SIP on this work that was coordinated by 

MANEVU, except as described in this Section. 

4.1 Point Source Controls and 2009 Projection Inventory. 

4.1.1. Electric Generating Unit (EGU) Emission Projections 

The MANE-VU 2002 point source inventory contains a cross-reference table that 

matches IPM emission unit identifiers (ORISPL plant code and BLRID emission unit code) to 

MANE-VU NIF emission unit identifiers (FIPSST state code, FIPSCNTY county code, State 

 

11 The MACTEC 2009 emission projections are explained in detail in the technical support document at Appendix 

4-1 to this document. 

12 Note that while these projections were used in the modeling that was relied upon in this SIP, they were 

determined to not be the best estimates of 2009 emission available. The 2009 Electric Generating Unit (EGU) 

and mobile source emission projections that Delaware has used in this SIP are discussed in detail in Section 4.1 

and 4.4 of this document, respectively. The impact of the difference between the modeled emission levels and 

Delaware’s projected 2009 emission levels are discussed in Sections 4 and 5 of this document. 

52
Plant ID, State Point ID). Initially, MACTEC used this cross-reference table to split the point 

source file into the EGU and non-EGU components. When there was a match between the IPM 

ORISPL/BLRID and the MANE-VU emission unit ID, the unit was assigned to the EGU 

inventory; all other emission units were assigned to the non-EGU inventory. 

After performing this initial splitting of the MANE-VU 2002 point source inventory into 

EGU and non-EGU components, MACTEC prepared several ad-hoc QA-QC queries to verify 

that there was no double-counting of emissions in the EGU and non-EGU inventories: 

• The IPM parsed files to identify EGUs accounted for in IPM. This list of emission units 

to the non-EGU inventory derived from the MANE-VU cross-reference table was 

verified so that units accounted for in IPM were not double-counted in the non-EGU 

inventory. 

• The non-EGU inventory was reviewed to identify remaining emission units with a 

Standard Industrial Classification (SIC) code of “4911 Electrical Services” or Source 

Classification Code of “1-01-xxx-xx External Combustion Boiler, Electric Generation”. 

The list of sources meeting these selection criteria was then compared to the IPM parsed 

file to ensure that these units were not double-counted. 

• The number of records for each NIF table in the original 2002 point source file was 

verified to equal the 2002 EGU and 2002 non-EGU files. The sum of the number of 

records in the EGU file and the number of records in the non-EGU file were then verified 

to equal the number of records in the original 2002 point source file.

• The emissions by pollutant in the original 2002 point source file were compared to the 

2002 EGU file and 2002 non-EGU files. The sum of the emissions in the EGU file and 

the emissions in the non-EGU file were verified to equal that of the original 2002 point 

source file.

As a result of this procedure, MACTEC created separate sets of NIF tables for 2002 

EGUs: units accounted for in IPM (i.e., EGUs), and non-EGUs. 

The non-EGU set of 2002 NIF tables are used in this SIP to project 2009 Delaware nonEGU point source emissions. This is discussed in detail in Section 4.1.2 of this document. 

However, after reviewing the IPM results, AQMS found that EGU projections were unrealistic. 

For example, IPM predicted all of Delaware’s oil-burning EGUs would have no emissions in 

2009. Contrary to this, Delaware’s oil-burning EGUs have indicted to the Department that that 

the oil-burning units will be operating for the foreseeable future. Therefore, Delaware 

determined that the IPM method was not an accurate method of projected future emissions from 

EGUs in Delaware, and re-projected EGU emissions using Department of Energy growth 

factors. Afterwards, Delaware-specific controls from post-2002 regulations were applied. The 

source of data for determining growth was: Energy Information Administration (EIA), Annual 

Energy Review 2004 (mid-Atlantic), DOE/EIA-0384 (2004) (Washington, DC, August 2005). 

Using 2002 as the baseline, 2009 growth factors were derived by taking 2009 projected energy 

53
consumption by sector (Energy Consumption) and source (fuel type-quadrillion Btu), and then 

dividing that by 2003 growth rates. 

The following is a list of controls for EGUs, which Delaware has adopted, and which will 

reduce emissions after 2002 and by 2009. Table 4-1 presents EGU emissions that are calculated 

by the IPM model.: 

(1). Reg. 1144, Control of Stationary Generator Emissions, SO2, PM, VOC and NOX

emission control, State-wide, Effective January 2006; 

(2). Reg. 1146, EGUs, Electric Generating Unit (EGU) Multi-Pollutant Regulation, SO2

and NOX emission control, State-wide, Effective December 2007; 

(3). Regulation No. 1148, Control of Stationary Combustion Turbine Electric Generating 

Unit Emissions, NOX emission control, State-wide, Effective January, 2007. 

 

Table 4-1 EGU emission projections calculated by the Integrated Planning Model (IPM) 

County NH3 NOx PM10 PM2.5 SO2 VOC 

Kent 1 474 123 117 1106 3 

New Castle 15 1871 475 357 4056 24 

Sussex 38 8758 2078 1733 25733 75 

Totals 54 11103 2677 2208 30895 102 

Table 4-2 is a summary of Delaware 2009 projection of emissions from EGUs, projected 

by AQMS staff using the procedure detailed above and applying reductions realized by 

Regulations 1144, 1146, and 1148. 

Table 4-2 2009 EGU emissions – Delaware calculated 

County NH3 NOx PM10 PM2.5 SO2 VOC 

Kent 5 803 171 153 2628 7 

New Castle 39 3590 781 632 6146 65 

Sussex 10 4119 1556 1379 9282 43 

Totals 54 8512 2508 2164 18056 115 

4.1.2 Non-EGU Point Source Controls and 2009 Emission Projections 

 The following is a list of point source controls that Delaware has adopted, and which will 

reduce emissions after 2002 and by 2009: 

(1). Reg. 24. Sec. 46, Crude Oil Lightering Operations, VOC emission control, Sussex 

County, Effective May 2007; 

 (2) Regulation 1142, Section 1, Control of NOX Emissions from Industrial Boilers, NOX

emission control, Effective December 2001. 

(3). Regulation 1142, Section 2, Control of NOX Emissions From Industrial Boilers and 

Process Heaters at Petroleum Refineries, NOX emission control, New Castle County, 

Effective July 2007. 

54
(4) Consent Decree with Premcor Refinery at Delaware City (formerly Motiva 

Enterprises), New Castle County, Control of SO2, and NOX Emission from Boilers 

and Heaters, Effective 2008. 

 (5) Facility and Unit shutdowns, as shown in Table 4-3 

 

Table 4-3 Facility and Unit shutdowns 

 NOx PM2.5 SO2

County Facility Name 2002 2009 2002 2009 2002 2009

Kent TILCON DELAWARE - HORSEPOND ROAD 8 0 4 0 5 0 

New Castle AMETEK INC CHEMICAL PRODUCTS DIVISION 2 0 0 0 0 0 

New Castle CONECTIV DELMARVA GENERATION-MADISON ST 1 0 0 0 0 

New Castle GENERAL CHEMICAL CORPORATION 91 0 17 0 340 0 

New Castle KANEKA DELAWARE CORPORATION 5 0 6 0 4 0 

New Castle LAFARGE NORTH AMERICA INC 69 0 11 0 1 0 

New Castle METACHEM PRODUCTS LLC 0 0 0 0 0 0 

New Castle VPI FILM LLC 5 0 1 0 0 0 

New Castle WESTVACO CORPORATION 0 0 0 0 0 0 

New Castle WILMINGTON PIECE DYE CO 2 0 0 0 0 0 

Sussex CITY OF LEWES POWER PLANT 3 0 0 0 0 0 

TOTALS = 186 0 40 0 350 0 

Among the above shutdown facilities, some have applied for and obtained emission 

reduction credits (ERCs) pursuant to Regulation No. 34, Emission Banking and Trading 

Program. Table 4-4 is a list of the facilities/agency that hold ERCs. 

 Table 4-4 Emission Reduction Credits and Holding Facilities/Agency 

ERC Holding Facility/Agency NOx (TPY) 

Kaneka Shutdown 2 

Lafarge Shutdown 37 

VPI Mirrex Shutdown 2 

Delaware Economic Development Office 72 

Total 113 

In addition, Premcor Refinery (formerly Motiva Enterprises) is under a Consent 

Agreement that indicates that 250 TPY of NOx reductions will remain available for Premcor 

Refinery to use as emissions offsets. Thus, the total NOx emission reductions from a facility/unit 

shutdown, modification and the Premcor Consent Decree that are available for the SIP planning 

are: (113 + 250) = 363 TPY 

These 363 TPY NOx ERCs were added back into the Delaware-adjusted 2009 tables and 

calculations, since the banked or authorized ERCs are treated as “emitted emissions” in the 

55
context of this SIP revision. As such, the future use of these credits is consistent with, and will 

not interfere with any calculation or provision of this SIP document. 

For the non-EGU point source sector Delaware has substantially relied upon the 2009 

projection of emissions done by MACTEC. This projection is summarized earlier in this 

document, and a detailed description is provided in Appendix 4-1 to this document. However, 

there are several instances where MACTEC’s projections have been revised by AQMS staff. 

The reasons for each such revision are provided in Appendix 4-2 of this document. The final 

2009 projections are detailed in Appendix 4-3. 

Table 4-5 provides a summary of the 2009 MACTEC non-EGU point source projection. 

Table 4-5 Summary of the MACTEC 2009 Non-EGU Point Source Projection 

County NH3 NOx PM10 PM2.5 SO2 VOC 

Kent 18 184 52 32 170 105 

New Castle 71 3566 1270 1138 5787 1718 

Sussex 56 326 163 86 1160 1164 

Totals 145 4076 1485 1256 7117 2987 

Table 4-6 provides a summary of the non-EGU point source emissions where 

MACTEC’s projections are not revised by the Department. 

Table 4-6 Summary of the Un-Revised Portion of the MACTEC 2009 Non-EGU 

Point Source Projection 

County NH3 NOx PM10 PM2.5 SO2 VOC 

Kent 18 170 44 25 154 96 

New Castle 71 3355 493 361 5782 1404 

Sussex 26 324 162 85 1160 60 

Totals 115 3849 699 471 7096 1560 

 Table 4-7 is a summary of Delaware 2009 projection of emissions from non-EGU point 

sources, where MACTEC’s projections are revised by AQMS staff. Reasons for each such 

revision are provided in Appendix 4-2. 

Table 4-7 Summary of the Revised Portion of the MACTEC 2009 Non-EGU Point 

Source Projection 

County NH3 NOx PM10 PM2.5 SO2 VOC 

Kent 0 8 2 1 0 6 

New Castle 0 113 573 476 28 1311 

Sussex 1 1 1 0 0 1034 

Totals 1 122 576 477 28 2351 

56
Table 4-8 provides a summary of Delaware’s projected 2009 emissions from non-EGUs 

(i.e., the sum of Table 4-6 and Table 4-7). 

Table 4-8 Summary of the Delaware Non-EGU Point Source Projection 

County NH3 NOx PM10 PM2.5 SO2 VOC 

Kent 18 177 46 26 154 102 

New Castle 71 3467 1066 837 5811 2715 

Sussex 28 325 163 85 1160 1094 

Totals 117 3969 1275 949 7125 3911 

4.1.3 EGU and Non-EGU Point Source 2009 Emission Projections Summary 

Delaware’s total projected 2009 point source emissions are the sum of the EGU point 

source projections (i.e., Table 4-2), the non-EGU point source projections(i.e., Table 4-8) and the 

ERCs (363 TPY NOx). This summation is presented in Table 4-9. 

Table 4-9 Summary of Delaware 2009 EGUs and non-EGUs Point Source Projection 

County NH3 NOx PM10 PM2.5 SO2 VOC 

Kent 22 981 217 178 2782 110 

New Castle 110 *7420 1847 1469 11957 2780 

Sussex 38 4444 1719 1465 10442 1138 

Totals 170 12845 3783 3112 25181 4028 

 * Includes ERC adjusted emissions 

4.2 Non-Point Source Controls and 2009 Emission Projections 

The following is a list of non-point source controls that Delaware has adopted, and which 

will reduce emissions after 2002 and by 2009: 

(1). Reg. 24 Sec. 33, Solvent Cleaning and Drying, VOC emission control, Statewide, 

Effective November, 2002. 

(2). Reg. 24 Sec. 11, Mobile Equipment Repair and Refinishing, VOC emission control, 

State-wide, Effective October, 2003. 

(3). Reg. 41 Sec. 3, Portable Fuel Containers, VOC emission control, State-wide, 

Effective January 2003. 

(4). Reg. 41 Sec. 2, Consumer Products, VOC emission control, State-wide, Effective 

January 2005. 

(5). Reg. 41 Sec 1, Architectural and Industrial Maintenance Coatings, VOC emission 

control, State-wide, Effective January 2005. 

(7). Federal Residential Woodstove NSPS, VOC, PM and NOx emission control. 

(8). Reg. 1113, Open Burning, PM, VOC and NOx emission control, State-wide, Revised 

and Effective April 2007. 

57
For the non-point source sector Delaware has substantially relied upon the 2009 

projection of emissions done by MACTEC. This projection is summarized earlier in this 

document, and a detailed description is provided in Appendix 4-1 to this document. However, 

there are several instances where MACTEC’s projections have been revised by AQMS staff. 

The reasons for each such revisions are provided in Appendix 4-2 of this document. Final 2009 

projections are detailed in Appendix 4-3. 

Table 4-10 is a summary of MACTEC’s 2009 Emissions from All Non-Point Sources. 

Table 4-10 Summary of the MACTEC 2009 Non-Point Source Projection 

County NH3 NOx PM10 PM2.5 SO2 VOC 

Kent 2033 439 3429 774 289 2660 

New Castle 1312 1313 4847 1208 796 7338 

Sussex 9971 1069 5652 1405 513 4245 

Totals 13316 2821 13928 3387 1598 14243 

Table 4-11 provides a summary of the non-point source emissions where MACTEC’s 

projections are not revised by the Department. 

Table 4-11 Summary of the Un-Revised Portion of the MACTEC 2009 Non-Point 

Source Projection 

County NH3 NOx PM10 PM2.5 SO2 VOC 

Kent 28 62 152 112 20 779 

New Castle 78 78 472 411 67 2996 

Sussex 33 45 109 96 21 915 

Totals 139 185 733 619 108 4690 

Table 4-12 is a summary of Delaware 2009 projection of emissions from non-point 

sources, where MACTEC’s projections are revised by AQMS staff. Reasons for each such 

revision is are provided in Appendix 4-2. 

Table 4-12 Summary of the Revised Portion of the MACTEC 2009 Non-Point 

Source Projection 

County NH3 NOx PM10 PM2.5 SO2 VOC 

Kent 2657 326 2595 461 211 722 

New Castle 666 1616 3111 654 716 2096 

Sussex 9777 518 3520 693 296 1013 

Totals 13100 2460 9226 1808 1223 3831 

Table 4-13 provides a summary of Delaware’s projected 2009 emissions from non-point 

sources (i.e., the sum of Table 4-11 and Table 4-12). 

58
Table 4-13 Summary of the Delaware Non-Point Source Projection 

County NH3 NOx PM10 PM2.5 SO2 VOC 

Kent 2685 388 2747 573 231 1501 

New Castle 743 1694 3583 1065 782 5092 

Sussex 9810 564 3629 789 316 1928 

Totals 13238 2646 9959 2427 1329 8521 

4.3 Non-Road Mobile Source Controls and 2009 Emission Projections 

 The controls for non-road mobile engines (except aircraft, locomotives, and marine 

vessels) that were applied when projecting their 2009 emissions include all relevant federal rules, 

such as fuel sulfur content rule, gasoline Reid Vapor Pressure (RVP) requirements, and 

reformulated fuel programs. MACTEC used EPA’s NMIM2005 model and NONROAD2005 

model to estimate annual emission projections of non-road engines in all MANE_VU states, 

including Delaware (see MACTEC’s TSD, Appendix 4-1). 

 In addition to the non-road engines, MACTEC also conducted 2009 annual emission 

projections for aircraft, locomotives and marine vessels for all MANE-VU states. Controls for 

the 2009 emissions include all relevant federal rules and requirements, as outlined below. 

(1) Phase I and Phase II Emissions Standards for Gasoline-Powered Non-Road Utility 

Engines, Federal Rule 

This standard promulgated by the EPA applies to VOC emissions from small nonroad, spark-ignition (i.e., gasoline-powered) utility engines, as authorized under 42 

U.S.C. §7547. The measure affects gasoline-powered (or other spark-ignition) lawn 

and garden equipment, construction equipment, chain saws, and other such utility 

equipment as chippers and stump grinders, wood splitters, etc., rated at or below 19 

kilowatts (an equivalent of 25 or fewer horsepower). Phase 2 of the rule applied 

further controls on handheld and non-handheld outdoor equipment. See References 4-

2, 4-3, and 4-4. 

(2) Emissions Standards for Diesel-Powered Non-Road Utility Engines of 50 or More 

Horsepower, Federal Rule 

This standard promulgated by the EPA applies to VOC and NOX emissions from 

non-road, compression-ignition (i.e., diesel-powered) utility engines, as authorized 

under 42 U.S.C. § 7547. The measure affects diesel-powered (or other compressionignition) construction equipment, industrial equipment, etc., rated at or above 37 

kilowatts (37 kilowatts is approximately equal to 50 horsepower). See References 4-

5, 4-6, and 4-7. 

59
(3) Emissions Standards for Spark Ignition (SI) Marine Engines, Federal Rule 

 

This standard promulgated by the EPA applies to exhaust PM, VOC and NOx 

emissions from new spark-ignition (SI) gasoline marine engines, including outboard 

engines, personal watercraft engines, and jet boat engines. Of nonroad sources 

studied by EPA, gasoline marine engines were found to be one of the largest 

contributors of hydrocarbon (HC) emissions (30 percent of the nationwide nonroad 

total). 

(4) Emissions Standards for Large Spark Ignition Engines, Federal Rule 

This EPA measure controls VOC and NOx emissions from several groups of 

previously unregulated nonroad engines, including large industrial spark-ignition 

engines. 

Since emissions from aircraft, commercial marine vessels, and locomotives are not 

projected by the NONROAD model, emission projections for these sources were developed 

separately. The starting point for the emission projections was Version 3 of the MANE_VU 

2002 Nonroad emission inventory (Documentation of the MANE-VU 2002 Nonroad Sector 

Emission Inventory, Version 3, Draft Technical Memorandum, March 2006). MACTEC’s 

approach to developing emission projections for these sources was to use combined growth and 

control factors developed from emission projections for U.S. EPA’s Clean Air Interstate Rule 

(CAIR) development effort. MACTEC obtained emission projections developed for the CAIR 

rule. MACTEC then calculated the combined growth and control factors by determining the 

ratio of emissions between 2002 and each of the MANE-VU projection years (2009, 2012, and 

2018). The CAIR emissions were available for 2001, 2010, 2015 and 2020. Thus, they 

developed intermediate year estimates using linear interpolation between the actual CAIR years 

and the MANE-VU years. 

Using this approach MACTEC developed State/county/SCC/pollutant growth/control 

factors for use in projecting the MANE-VU base year data to 2009. These values were then used 

to multiply times the base year value to obtain the projected values. Since the development of 

the CAIR factors included both growth and controls, no separate control factors were developed 

for these sources except where exceptions to this method were used for States that requested 

alternative growth/control methods (see below). 

Once the CAIR factors were developed, MACTEC compared the SCCs contained in the 

CAIR inventory with those used in MANE-VU. In some cases there were differences. In cases 

where a similar SCC in the CAIR inventory could be assigned to the SCC in the MANE-VU 

inventory the State/County/SCC/pollutant growth and control factor for the substitute was 

assigned to the MANE-VU SCC. If no corresponding county SCC substitution could be found, a 

State or MANE-VU regional average value for the substitute SCC was developed and assigned 

for use in projecting emissions. The substitution scheme was to use State values first, then 

MANE-VU regional values if the State value couldn’t be used. 

60
For the non-road mobile source sector Delaware has substantially relied upon the 2009 

projection of emissions done by MACTEC, as described above. However, there are several 

instances where MACTEC’s projections have been revised by AQMS staff. The reasons for 

each such revision are provided in Appendix 4-2 of this document. 

Table 4-14 is a summary of MANEVU 2009 Emissions from All Non-road Sources. 

Table 4-14 Summary of the MACTEC 2009 Non-Road Mobile Source Projection 

County NH3 NOx PM10 PM2.5 SO2 VOC 

Kent 1 4251 223 201 618 1394 

New Castle 2 7436 423 382 1297 2543 

Sussex 2 3752 301 274 935 2503 

Totals 5 15439 947 857 2850 6440 

Table 4-15 provides a summary of the non-road mobile source emissions where 

MACTEC projections are not revised by the Department. 

Table 4-15 Summary of the Un-Revised Portion of the MACTEC 2009 Non-Road 

Mobile Source Projection 

County NH3 NOx PM10 PM2.5 SO2 VOC 

Kent 1 3272 201 181 556 1383 

New Castle 2 3131 249 225 294 2486 

Sussex 2 3123 290 264 901 2498 

Totals 5 9526 740 670 1751 6367 

Table 4-16 is a summary of Delaware 2009 projection of emissions from non-road 

mobile sources, where MACTEC’s projections are revised by AQMS staff. Reasons for each 

such revision is are provided in Appendix 4-2. 

Table 4-16 Summary of the Revised Portion of the MACTEC 2009 Non-Road 

Source Projection 

County NH3 NOx PM10 PM2.5 SO2 VOC 

Kent 0 1235 28 25 79 13 

New Castle 1 4658 186 169 1052 63 

Sussex 0 753 13 11 42 6 

Totals 1 6646 227 205 1173 82 

Table 4-17 provides a summary of Delaware’s projected 2009 emissions from non-road 

mobile sources (i.e., the sum of Table 4-15 and Table 4-16). 

61
Table 4-17 Summary of the Delaware Non-Road Mobile Source Projection 

County 

NH3 NOx PM10 PM2.5 SO2 VOC 

Kent 2 4508 229 206 635 1396 

New Castle 3 7789 435 394 1345 2549 

Sussex 2 3876 304 276 943 2504 

Totals 7 16173 968 876 2923 6449 

4.4 On-Road Mobile Source Controls and 2009 Emission Projections 

The on-road mobile source emission projections have been conducted by AQM staff 

members using EPA’s MOBILE6.2 model. Delaware Department of Transportation (DelDOT) 

provided vehicle miles traveled (VMT) on Delaware’s roadways and vehicle mix data for 2009. 

The on-road mobile source controls in the input files for the 2009 MOBILE6.2 runs include the 

following: 

(1) Low enhanced I/M program of model years 1968 and newer, Kent and New Castle. 

(2) On-Board Diagnostic checks of model years 1996 and newer, statewide. 

(3) Anti-tampering program of model years of 1975 and newer, statewide. 

(4) NLEV program, statewide. 

(5) Low emission vehicle program/Tier 2 emission standards/low sulfur rule, statewide. 

(6) Heavy Duty Diesel Rule/low Sulfur rule, statewide. 

 Table 4-18 is a summary of on-road mobile emissions calculated by NESCAUM and 

New York using the SMOKE model. 

 

Table 4-18 (NESCAUM/NY) 2009 Mobile Projections 

County NH3 NOx PM10 PM2.5 SO2 VOC 

Kent 179 3206 93 61 17 1426 

New Castle 711 8862 278 163 63 4854 

Sussex 281 4096 131 83 27 2512 

Totals 1171 16164 502 307 107 8792 

 The above emissions were calculated with data the Department submitted to MANVU in 

October, 2006. Projected VMT and vehicle speed data for 2009 were prepared by the Delaware 

Department of Transportation in July, 2005 for the NESCAUM and New York using the 

SMOKE model. 

The Department recalculated 2009 on-road mobile source emission projections, using 

updated VMT and speeds provided by DELDOT that the Department received in the spring of 

62
2007. The input files of the 2009 MOBILE6.2 runs, the emission factors generated and relevant 

calculations for emission projections are presented in Appendices 4-4. Sample calculations are 

provided in Appendix 8-1. The updated VMT and speeds data accounts for the differences in the 

two tables. 

Table 4-19 Delaware 2009 Mobile projections using the most up-to-date VMT and 

speeds 

County NH3 NOx PM10 PM2.5 SO2 VOC 

Kent 178 1922 60 32 16 1223 

New Castle 610 4904 174 87 51 3466 

Sussex 256 2707 79 41 23 1988 

Totals 1044 9533 313 160 90 6677 

Section 4.5 Summary of Delaware’s Overall Projected 2009 Inventory 

Tables 4-20 and 4-21 are the sum of 2009 projections that were coordinated by MANEVU and 

the result of the revisions made by Delaware, as explained above, respectively. 

Table 4-20 2009 projections – all sectors – MANEVU 

County NH3 NOx PM10 PM2.5 SO2 VOC 

Kent 2233 8554 3448 1185 2201 5587 

New Castle 2112 23048 6379 3249 12001 16478 

Sussex 10347 18001 5756 3581 28368 10499 

 Totals 14691 49602 15583 8014 42569 32564 

Table 4-21 2009 projections – all sectors – Delaware 

County NH3 NOx PM10 PM2.5 SO2 VOC 

Kent 2887 7799 3253 989 3664 4230 

New Castle 1466 21807 6039 3015 14135 13887 

Sussex 10106 11591 5731 2571 11724 7558 

 Totals 14459 41197 15023 6575 29523 25675 

63
Section 5 – 2009 Emissions Attainment Targets 

Delaware is required by the CAA and the March 30, 2007 PM2.5 Implementation Rule to 

demonstrate how it, and the associated non-attainment area, will attain compliance with PM2.5

NAAQS by 2010. This demonstration is substantially discussed in Section 6 of this document. 

Section 6 of this document presents a detailed Weight of Evidence (WOE) analysis, which 

includes CMAQ modeling. This CMAQ modeling is a core component of the WOE analysis, 

and a significant input to the model is 2009 emission levels. 

The 2009 modeling inventory is the 2009 projection inventory that was coordinated by 

MANEVU in 2005. This 2009 projection inventory was discussed in Section 4 of this document, 

and is presented in detail in Appendix 4-3 to this document. Table 4-20, 2009 projections – all 

sectors – MANEVU, shows the New Castle County emission levels that were modeled with 

CMAQ for 2010. For convenience, the information from Table 4-20 has been copied to this 

section and named table 5-1. 

Table 5-1 CMAQ Modeled 2009 Emissions, i.e. Attainment Targets 

County NH3 NOx PM10 PM2.5 SO2 VOC 

New Castle 2112 23048 7294 3249 12001 16478 

The Departments WOE analysis, which includes CMAQ using the emission levels in 

Table 5-1, demonstrates that both Delaware and the entire Philadelphia Non-attainment area will 

be in attainment with the PM2.5 NAAQS in 2010. Therefore, the emission levels in Table 5-1 are 

the targeted level of emissions needed for attainment. 

As discussed in Section 4 of this document, Delaware has updated MACTEC’s 2009 

projection inventory based on the latest information available. Table 4-21, 2009 projections – all 

sectors – Delaware, shows the emission levels that are projected for 2009. For convenience, the 

information from Table 4-21 has been copied to this section and named table 5-2. 

Table 5-2 New Castle Projected 2009 Emissions (Control Strategy Emissions) 

County NH3 NOx PM10 PM2.5 SO2 VOC 

New Castle 1466 21807 6039 3015 14135 13887 

Table 5-3 below presents the Attainment Targets (i.e., Table 5-1) minus the DE Control 

Strategy Emissions (i.e., Table 5-2). Positive values indicated that DE projects emissions in 

2009 to be lower than the levels that are needed for attainment. Conversely, negative values 

indicate that DE projects emissions in 2009 to be higher than levels that are needed for 

attainment.

64
Table 5-3 Attainment Demonstration (CMAQ Modeled 2009 Emissions minus DE 

Projected 2009 Emissions) 

 County NH3 NOx PM10 PM2.5 SO2 VOC 

New Castle 646 1,241 1255 234 -2134 2591 

 Table 5-3 indicates that emission levels in New Castle County for all pollutants except 

for SO2 are projected to be below the levels that are necessary for attainment. Relative to SO2

there is a projected 2,134 TPY shortfall. 

Because of the regional nature of secondarily-formed sulfate and nitrate, and the broad 

modeling domain of the CMAQ modeling, which included all of Delaware, emission reductions 

from Kent and Sussex counties will contribute to attainment within New Castle County and the 

Philadelphia NAA. Kent and Sussex counties are within the State of Delaware, contiguous to 

New Castle County, and are less than 200 kilometers away. The PM2.5 Implementation Rule 

allows states to consider in-state NOX and SO2 credits in their SIPs from sources up to 200 

kilometers away from the non-attainment area.13

Table 5-4 shows that there is a statewide SO2 “surplus” of 13,047 TPY relative to the 

emission levels that are consistent with attainment. This indicates that while New Castle County 

(i.e., Delaware’s only area designated non-attainment with respect to the annual PM2.5 NAAQS) 

is not projected to have reductions in SO2 consistent with attainment (i.e., 2,134 shortfall based 

on CMAQ modeling), overall DE SO2 emissions levels are consistent with attainment.. 

Table 5-4 SO2 “surplus/shortfall” 

CMAQ 2009 

Modeled SO2

Inventory (TPY) 

DE 2009 Projected 

SO2 Emissions 

(TPY) 

Surplus/ 

Shortfall 

(TPY) 

Kent 2201 3664 -1463 

New Castle 12001 14135 -2134 

Sussex 28368 11724 16644 

Total 42569 29523 13047 

 In summary, Delaware projects that its 2009 emission levels of all pollutants considered 

in its attainment demonstration and WOE analysis, which is discussed in detail in Section 6 of 

this document, will be below the levels necessary for attainment. 

 13 PM2.5 Implementation Rule, pp. 300-301 

65
Section 6: Attainment Demonstration 

6.1 Background and Objectives 

The Clean Air Act requires the U.S. Environmental Protection Agency (EPA) to establish 

National Ambient Air Quality Standards (NAAQS) that adequately protect the public health. In 

1997, EPA established new standards for fine particulate matter (PM2.5), which include an annual 

standard of 15 micrograms per cubic meter (μg/m3) based on the 3-year average of annual mean 

PM2.5 concentrations, and a 24-hour standard of 65 μg/m3 based on the 3-year average of the 

98th percentile of 24-hour concentrations. 

On December 17, 2004, the EPA designated areas for the PM2.5 NAAQS. The 

Philadelphia-Wilmington (PA-NJ-DE) nonattainment area (NAA) has been classified as a 

nonattainment area for PM2.5 with an attainment date of April 5, 2010. The PA-NJ-DE 

nonattainment area for PM2.5 includes one county in Delaware, five counties in Pennsylvania, 

and three counties in New Jersey being in nonattainment for the PM2.5 NAAQS. Table 6-1 

identifies all jurisdictions that EPA has designated as nonattainment for PM2.5 within the PA-NJDE NAA. 

Table 6-1: PA-NJ-DE Designations for the PM2.5 NAAQS 

Jurisdiction Counties Classification Maximum 

Attainment Date

Delaware New Castle 

Pennsylvania 

Bucks 

Chester 

Delaware 

Montgomery 

Philadelphia 

New Jersey Burlington 

Camden 

Gloucester

Nonattainment April 5, 2010 

Once an area is designated as nonattainment, the Clean Air Act requires the submittal of 

an implementation plan to EPA within three years. State Implementation Plans (SIPs) are due in 

April 2008. States may also propose an attainment date extension for up to five years. Those 

areas for which EPA approves an extension must achieve clean air as soon as possible, but no 

later than April 5, 2015. 

Figure 6-1 provides a graphical representation of the Philadelphia-Wilmington (PA-NJ-DE) 

nonattainment area. 

66
Figure 6-1: The Philadelphia-Wilmington (PA-NJ-DE) nonattainment area 

The Agencies responsible for making the attainment demonstration for the PhiladelphiaWilmington (PA-NJ-DE) nonattainment area are the Delaware Department of Natural Resources 

and Environmental Control (DNREC), the Pennsylvania Department of the Environment 

67
(PADEP), and the New Jersey Department of the Environment (NJDEP). These agencies are 

responsible for preparing and submitting their SIPS to the EPA. 

This modeling study demonstrates that the PA-NJ-DE nonattainment area attains the 

PM2.5 standards by April 5, 2010. The procedures followed in this modeling study are in 

accordance with the EPA’s Guidance on the Use of Models and Other Analyses for 

Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5, and Regional Haze (EPA454/B-07-002, April 2007). 

 The State Agencies (DNREC, PADEP, NJDEP) are also members of the Ozone 

Transport Commission (OTC) modeling committee. The OTC modeling centers, which include 

New York State Department of Environmental Conservation (NYSDEC), the University of 

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

the Virginia Department of Environmental Quality (VADEQ), performed the modeling. 

Modeling inventories were developed, updated and shared among the regional modeling centers 

and provided by the Mid-Atlantic Regional Air Management Association (MARAMA) and MidAtlantic North East Visibility Union (MANE-VU) Regional Planning Organization (RPO). The 

Policy and Technical Advisory Committees oversaw the modeling work. These Committees 

provided reports through regular briefings and offered information in cases where specific 

technical decisions had policy implications. 

6.2 Conceptual Model 

 EPA recommends that a conceptual description of the area’s PM2.5 problem be developed 

prior to the initiation of any air quality modeling study. A “conceptual description” is a 

qualitative way of characterizing the nature of an area’s nonattainment problem. Within the 

conceptual description of a particular modeling exercise, it is recommended that the specific 

meteorological parameters that influence air quality be identified and qualitatively ranked in 

importance. 

 The conceptual model for this study consists of two documents - The Nature of the Fine 

Particle and Regional Haze Air Quality Problems in the MANE-VU Region: A Conceptual 

Description (NESCAUM, November 2006) and The Development of PM2.5 Forecasting Tools for 

Selected Cities in the MARAMA Region (ICF, September 2004). The first document was 

prepared by NESCAUM for use by the OTC member States, and it provides the conceptual 

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

second document is prepared by ICF for MARAMA and is the basis of the MARAMA PM2.5

forecasting tool for nine cities in the MARAMA region. The nine cities for which the PM2.5

forecasting tool was developed are - Charlotte, North Carolina; Bristol, Roanoke, and Richmond, 

Virginia; Washington, D.C.; Baltimore, Maryland; Philadelphia, Pennsylvania; Wilmington, 

Delaware; and Newark/Elizabeth, New Jersey. The study included the analysis of PM2.5 and 

meteorological data using Classification and Regression Tree (CART) analysis software and the 

development, testing, and evaluation of interactive forecasting tools for each area. Data and 

information gathered throughout the course of the project were used, together with the CART 

analysis results, to describe the relationships between meteorology, and PM2.5 concentration and 

specifically, the conditions associated with high PM2.5 events in each forecast area. Both of these 

documents are provided in Appendices 6-1 and 6-2. 

68
6.3 Modeling Domain and Photochemical Modeling System 

6.3.1 Episode Selection 

 Due to the fact that the attainment demonstration is being conducted using a resource 

intensive photochemical grid model, EPA accepts the use of a single, recent “representative” 

year to be used for an annual model simulation. Two factors were used in selecting 2002 as the 

“representative” year - the observed annual mean concentrations of PM2.5 are close to the 3-year 

observed design value at all, or most monitoring sites, and the pattern of quarterly mean values is 

similar to the pattern of quarterly mean concentrations averaged over 3 years. 

6.3.2 Photochemical Modeling Domain 

 The Ozone Transport Commission (OTC) modeling committee selected the EPA’s 

Community Multi-Scale Air Quality (CMAQ) model for this modeling effort. The CMAQ 

model is also recommended by the Guidance on the Use of Models and Other Analyses for 

Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5, and Regional Haze (EPA454/B-07-002, April 2007). Two CMAQ modeling domains were defined - the outer domain at 

a 36-km horizontal grid resolution covering the continental U.S. and the inner domain at 12-km 

horizontal grid resolution covering the OTR (see Figure 6-2). The outer domain with 36-km 

horizontal grid resolution is the same national grid adopted by the Regional Planning 

Organizations (RPOs) for the original purpose of modeling regional haze SIP demonstrations but 

also serves the purpose of ozone evaluation. However, the inner domain, with 12-km horizontal 

grid resolution in the northeastern U.S., is the focus of and the justification for all activities 

pursuant to demonstrating attainment of the PM2.5 NAAQS. The CMAQ domain is nested in the 

Mesoscale Meteorological Model (MM5) domain. A larger MM5 domain was selected for both 

MM5 simulations to provide a buffer of several grid cells around each boundary of the CMAQ 

36-km domain. This was designed to eliminate any errors in the meteorology from boundary 

effects in the MM5 simulation at the interface of the MM5 model. The CMAQ vertical structure 

is primarily defined by the vertical grid used in the MM5 modeling. 

69
Figure 6-2: PM2.5 Modeling Domains at 36- and 12-km for the OTR 

6.3.3 Initial and Boundary Conditions 

 The objective of a photochemical grid model is to estimate the air quality given a set of 

meteorological and emissions conditions. When initializing a modeling simulation, the exact 

concentration fields are unknown in every grid cell for the start time. Therefore, typically 

photochemical grid models are started with clean conditions within the domain and allowed to 

stabilize before the period of interest is simulated. In practice this is accomplished by starting the 

model several days prior to the period of interest. 

 The winds move pollutants into, out of, and within the domain. The model handles the 

movement of pollutants within the domain and out of the domain. An estimate of the quantity of 

pollutants moving into the domain is needed. These are called boundary conditions. To estimate 

the boundary conditions for the modeling study, three-hourly boundary conditions for the outer 

36-km domain were derived from an annual model run performed by researchers at Harvard 

University using the GEOS-CHEM global chemistry transport model. The influence of 

boundary conditions was minimized by using a 15-day ramp-up period which is sufficient to 

establish pollutant levels that are encountered in the beginning of an air pollution episode. 

70
6.3.4 Meteorological Model Selection 

 The Pennsylvania State University/National Center for Atmospheric Research 

(PSU/NCAR) Mesoscale Meteorological Model (MM5) was selected for application in the 

modeling analysis. MM5 is a non-hydrostatic, prognostic meteorological model routinely used 

for urban- and regional-scale photochemical regulatory modeling studies. 

6.3.5 Emissions Inventories 

Emissions processing necessary for the 2002 base case and 2009 future case modeling 

required coordination amongst the Regional Planning Organizations (RPOs). Each RPO was 

responsible for processing of both its anthropogenic and biogenic emissions. The emissions data 

for 2002 was generated by individual states within the OTR and then assembled and processed 

through the MANE-VU. These emissions were then processed by the NYSDEC using Sparse 

Matrix Operator Kernel Emissions (SMOKE) modeling system, an emissions processor for 

CMAQ, to provide model-ready inputs. The 2002 emissions for the non-OTR areas within the 

modeling domain were obtained from the corresponding RPOs and were processed using 

SMOKE. 

Emissions inventories for 2009 needed for the MANE-VU RPO are developed by a 

number of entities. A contractor (MACTEC) in consultation with the states developed the 

necessary growth and control factors and applied them to the 2002 inventory. Mobile source 

emissions are developed by VADEQ and NESCAUM. The inter-RPO workgroup developed the 

state and unit-level emissions by utilizing the Integrated Planning Model (IPM). The 2009 

emissions inventories utilized in modeled attainment demonstrations are identified as 2009 onthe-books/on-the-way (2009OTB/OTW) inventories as they represent all control measures that 

were promulgated or would become effective on or before 2009. 

6.4 Model Performance Evaluation 

6.4.1 Overview 

 A critical component of every air quality modeling study is the model performance 

evaluation where the modeled estimates for the current year base case are compared against 

observed values to assess the model’s accuracy and provide an indication of its reliability. This 

section lays out the procedures and results of the evaluation. It should be noted that the other 

parts of the modeling process, the emissions and meteorology, also undergo an evaluation. It is 

with this knowledge and the desire to keep the report concise, that the air quality model became 

the primary focus of this section. 

 The first step in the modeling process is to verify the model’s performance in terms of its 

ability to predict the PM2.5 and its individual components (i.e., sulfate, nitrate, ammonium, 

organic carbon, elemental carbon and other PM2.5) in the right locations and at the right levels. 

To do this, the model predictions for the base year simulation are compared to the ambient data 

observed in the historical episode. This verification is a combination of statistical and graphical 

evaluations. If the model appears to be producing PM2.5 in the right locations for the right 

reasons, then the model can be used as a predictive tool to evaluate various control strategies and 

their effects on PM2.5. 

71
 The results of a model performance evaluation were reviewed prior to using modeling to 

support the attainment demonstration. The New York State DEC, Division of Air Resources, 

conducted a performance evaluation of the 2002 base case CMAQ simulation on behalf of the 

OTC member States. Appendix 6-3 provides comprehensive operational and diagnostic 

evaluation results, including spreadsheets containing the assumptions made to compute statistics. 

Highlights of this evaluation are provided in the following sections. 

6.4.2 Diagnostic and Operational Evaluation 

 The issue of model performance goals for PM2.5 is an area of ongoing research and 

debate. To evaluate model performance, EPA recommends that several statistical metrics be 

developed for air quality modeling. Performance goals refer to targets that a good performing 

model should achieve, whereas performance benchmarks are based on historical model 

performance measures for the best performing simulations. Performance goals are necessary in 

order to provide consistency in model applications and expectations across the country and to 

provide standardization in how much weight may be accorded modeling study results in the 

decision-making process. 

When EPA’s guidance was first developed nearly four (4) years ago, an interim set of fine 

particulate modeling performance goals were suggested for aggregated mean normalized gross 

error and mean normalized bias as defined in Table 6-2: 

Table 6-2: EPA PM2.5 Modeling Performance Goals 

Pollutant Gross Error Normalized Bias 

PM2.5 ~30-50% ~10% 

Sulfate ~30-50% ~20-30% 

Nitrate ~20-70% ~15-50% 

EC ~15-60% NA 

OC ~40-50% ~38% 

Because regional-scale PM2.5 modeling is an evolving science, and considerable practical 

application and performance testing has transpired in the intervening years since these goals 

were postulated, they are considered as general guidelines. It may also be possible to adopt 

levels of model performance goals for bias and gross error as listed in Table 6-3 to help evaluate 

model performance. 

Table 6-3: MANE-VU PM2.5 Modeling Performance Goals 

Fractional Bias Fractional Error Comment 

≤±15% ≤35% Ozone model performance goal for which PM2.5 model 

performance would be considered good. 

≤±30% ≤50% A level of model performance that we would hope 

each PM2.5 species could meet. 

≤±60% ≤75% At or above this level of performance indicates 

fundamental problems with the modeling system. 

72
It does not mean that these performance goals should be generally adopted or that they are the 

most appropriate goals to use. Rather, the goals are being used to frame and put the PM2.5 model 

performance into context and to facilitate model performance across episodes, species, models 

and sensitivity tests. 

As noted in EPA’s PM2.5 modeling guidance, less abundant PM2.5 species should have 

less stringent performance goals. Accordingly, performance goals that are a continuous function 

of average observed concentrations such as those proposed by Dr. James Boylan at the Georgia 

Department of Natural Resources have the following features: 

• Asymptotically approaching proposed performance goals or criteria when the mean of 

the observed concentrations are greater than 2.5 ug/m3

. 

• Approaching 200% error and ±200% bias when the mean of the observed 

concentrations are extremely small. 

The above goals and criteria are not regarded as a pass/fail test, but rather as a basis of intercomparing model performance across studies, sensitivity tests and models. 

The OTC model performance evaluation was initially conducted by NYSDEC on the 

summer ozone season data only. VADEQ has extended the evaluation to include the entire year 

of 2002 observations. Four statistical parameters, two recommended by EPA (Table 6.2) and 

two adopted by VISTAS (Table 6.3), pertinent to model performance evaluation were computed 

for FRM PM2.5 mass and for individual species of SO4, NO3, NH4, EC, OM (1.8* blankcorrected OC), soil or crustal material (sum of oxides of Ca, Fe, Si, and Ti). The statistics were 

organized into two categories: a) by date and b) by site. 

For statistics by date, the parameters were calculated on a given day for any valid pairs of 

observed/predicted data across all FRM and speciation monitors that fall within the OTR 

modeling domain plus all of Virginia monitors (referred to as OTR+). Data collected from three 

different monitoring networks, FRM, STN, and IMPROVE, were used in the statistics. It is 

important to note that predicted data used for the model performance evaluation were extracted 

from CMAQ outputs at the exact grid cells where monitors are located. This is in contrast to the 

design value calculations where predictions are based on the average of the surrounding nine grid 

cells (see Section 6.5). 

For statistics by site, parameters were computed at a given FRM, STN, or IMPROVE 

monitor for any valid pairs of observed/predicted data over a period of one calendar year. Again, 

the full year of 2002 data was used in this “monitor-based composite period" analysis, except for 

the dates between July 6 and July 9 due to the exceptional event caused by the Quebec forest 

fires. 

Figure 6-3 depicts the location of the FRM, STN and IMPROVE monitor locations used 

for the model evaluation across the OTR+ region. 

73
Figure 6-3: FRM (●, 264), STN (■, 50), and IMPROVE (▲, 21) 

Locations Used for the Model Evaluation Across the OTR+ Region

A composite FRM time series across the OTR+ region (264 monitors) is provided in Figure 6-4. 

This figure indicates that there is an overall mean bias of approximately 4 μg/m3. There is a 

general over-prediction during winter months and an under-prediction during summer months. 

There is excellent agreement during the mid-August air pollution episode. 

74
Figure 6-4: Composite FRM Time Series across the OTR+ Region (264 monitors) 

 Figure 6-5 is a plot of the FRM mean fractional error (MFE) and mean fractional bias 

(MFB) across the OTR+ region. MFE ranges from 17% to 88% with an average of 

approximately 45%. MFB ranges from -82% to +88% with an average of approximately +24%. 

These values are generally consistent with similar studies listed in the Guidance on the Use of 

Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, 

PM2.5, and Regional Haze (EPA-454/B-07-002, April 2007). 

Figure 6-5: MFE and MFB Time Series for FRM PM2.5 across the OTR+ Region 

Figure 3-3: FRM MFE and MFB across the OTR+ Region 

An MFE bugle plot for FRM PM2.5 across OTR+ region is provided in Figure 3-4. “Goal” curves 

are the best a model can be expected to achieve while the “criteria” curves are considered 

acceptable for model performance. 258 of 264 sites satisfy “criteria” restriction on an annual 

average basis. 

Mean fractional error & Mean fractional bias

-90

-7

-6

-4

-1

20020

0112

0020123

20020 03

2002

214

20020225

0020308

20020 19

20020330

0020410

20020421

20020 02

20020513

0020524

20020604

20020615

20020626

0020707

20020718

20020729

20020809

0020820

20020 31

2002

91

5

0

5

-30

5

0

15

30

45

60

75

90

101

2002

2

2

0

2

3

2

5

2

2

2

8

0 1

2

0

1

20

2

020922

0021003

20021 14

2002

025

0021105

20021116

200211

2002

2002

%

27

20021208

1219

1230

MFE MFB

75
 An MFE bugle plot for FRM PM2.5 across OTR+ region is provided in Figure 6-6. 

“Goal” curves are the best a model can be expected to achieve while the “criteria” curves are 

considered acceptable for model performance. 258 of 264 sites satisfy “criteria” restriction on an 

annual average basis. 

Figure 6-6: MFE Bugle Plot for FRM PM2.5 across OTR+ Region 

 

FRM PM2.5

0

20

40

60

80

100

120

140

160

180

200

0 3 6 9 12 15 18 21

Observed, μg/m3

MFE, %

FRM Goal Criteria

 MFE bugle plots were also generated for SO4, NO3, and NH4, EC, OM, and soil/crustal 

across OTR+ region and are provided in Figures 6-7 through 6-12. As can be seen from the 

results, the performance for individual species is generally consistent with the criteria necessary 

for acceptable model performance. 

 

Figure 6-7: MFE Bugle Plot for SO4 across OTR+ Region 

Figure 6-8: MFE Bugle Plot for NO3 across OTR+ Region 

Sulfate

0

20

40

60

80

100

120

140

160

180

200

0 1 2 3 4 5 6 7 8 9 10

Observed, μg/m3

MFE, %

STN IMPROVE Goal Criteria

76
Figure 6-8: MFE Bugle Plot for NO3 SO4 across OTR+ Region 

Nitrate

0

20

40

60

80

100

120

140

160

180

200

0 0.4 0.8 1.2 1.6 2 2.4 2.8 3.2 3.6 4

Observed, μg/m3

MFE, %

STN IMPROVE Goal Criteria

Figure 6-9: MFE Bugle Plot for NH4 across OTR+ Region 

Ammonium

0

20

40

60

80

100

120

140

160

180

200

0 0.4 0.8 1.2 1.6 2 2.4 2.8 3.2 3.6 4

Observed, μg/m3

MFE, %

STN IMPROVE Goal Criteria

77
Figure 6-10: MFE Bugle Plot for ECacross OTR+ Region 

Elemental Carbon

0

20

40

60

80

100

120

140

160

180

200

0 0.3 0.6 0.9 1.2 1.5 1.8 2.1 2.4

Observed, μg/m3

MFE, %

STN IMPROVE Goal Criteria

Figure 6-11: MFE Bugle Plot for OM across OTR+ Region 

Organic Mass

0

20

40

60

80

100

120

140

160

180

200

0 1 2 3 4 5 6 7 8 9 10

Observed, μg/m3

MFE, %

STN IMPROVE Goal Criteria

78
Figure 6-12: MFE Bugle Plot for Soil/Crustal across OTR+ Region 

Soil/crustal

0

20

40

60

80

100

120

140

160

180

200

0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1

Observed, μg/m3

MFE, %

STN IMPROVE Goal Criteria

The following is a list of several PM2.5 statistics for the OTC domain that have also been 

provided in Appendix 6-4 and 6-4a. 

1. Statistical evaluation of daily average PM2.5 mass from FRM sites across the OTR+ 

domain. Statistics are computed by date and by site (across the OTR+). [Figure 6-4, 

Figure 6-5 (by date). Figure 6-6 (by site).] 

2. Statistical evaluation of daily average PM2.5, SO4, NO3, NH4, EC, OM, and 

crustal/soil mass at EPA STN sites. Statistics are computed by date and by site 

(across the OTR+). [Figure 6-7 to Figure 6-12 (by site).] 

3. Statistical evaluation of daily average PM2.5, SO4, NO3, EC, OM, and crustal/soil 

mass at IMPROVE sites. Statistics are computed by date and by site (across the 

OTR+). [Figure 6-7 to Figure 6-12 (by site).] 

4. Statistical evaluation of daily average PM2.5 mass from FRM sites. Statistics are 

computed by date and by site. 

6.4.3 Summary of Model Performance 

CMAQ was employed to simulate PM2.5 for the calendar year 2002. A review of PM2.5 

and its individual species was conducted for the study domain. 

The CMAQ model performance for surface PM2.5 is good with acceptable bias and error. 

Several observations can be made with respect to model performance, including the following: 

1. Approximately 80-90% of OM is in the primary fraction. Observed OM has distinct 

maximum during summer when secondary formation is highest; CMAQ exhibits 

substantial under-prediction in secondary organic aerosols (SOA). The predicted 

primary OM is highest during the winter. 

2. CMAQ captures seasonal variation in SO4 well. 

79
3. CMAQ appears to overestimate primary PM2.5 components (EC, soil, primary OM), 

especially during colder months. 

4. CMAQ appears to underestimate secondary OM during the summer. 

These issues are not of great regulatory concern since attainment tests are based on the 

application of relative response factors. In summary, the regional and local model performance 

is acceptable for PM2.5. While there are some differences between the spatial data between subregions, there is nothing to suggest a tendency for the model to respond in a systematically 

different manner between regions. Examination of the statistical metrics by sub-region confirms 

the absence of significant performance problems arising in one area but not in another, building 

confidence that the CMAQ modeling system is operating consistently across the full OTC 

domain. This confidence in the modeling results allows for the modeling system to be used to 

support the State Implementation Plan to meet the 24-hour and annual PM2.5 NAAQS. 

6.5 Attainment Demonstration 

6.5.1 Overview 

As previously mentioned, the PA-NJ-DE PM2.5 nonattainment area has an attainment date 

of April 5, 2010. The PM2.5 NAAQS include an annual standard of 15 μg/m3 based on the 3-year 

average of annual mean PM2.5 concentrations, and a 24-hour standard of 65 μg/m3 based on the 

3-year average of the 98th percentile of 24-hour concentrations. 

This section summarizes the procedures that are used to demonstrate attainment of the 

PM2.5 NAAQS. As described in EPA’s Guidance on the Use of Models and Other Analyses for 

Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5, and Regional Haze (EPA454/B-07-002, April 2007), an attainment demonstration consists of (a) analyses which estimate 

whether selected emissions reductions will result in ambient concentrations that meet the 

NAAQS, and (b) an identified set of control measures which will result in the required emissions 

reductions. The necessary emission reductions for both of these attainment demonstration 

components may be determined by relying on results obtained with air quality models. 

EPA guidance recommends applying a modeled attainment test to the air quality 

modeling results to determine if the PM2.5 NAAQS will be met. Additional technical or 

corroboratory analyses may also be used as part of a “supplemental analysis” or a more stringent 

“weight of evidence” determination to supplement the modeled attainment test and to further 

support a demonstration of attainment of the NAAQS. 

The modeled attainment test and additional corroborative analyses are described in 

further detail in the remaining portions of this section. 

6.5.2 Model Attainment Test 

The purpose of a modeling assessment is to determine if control strategies currently being 

implemented (“on the books”) and proposed control strategies will lead to attainment of the 

NAAQS for PM2.5 by the attainment year of 2009. The modeling is applied in a relative sense, 

similar to the 8-hour ozone attainment test. However, The PM2.5 attainment test is more 

80
complicated and reflects the fact that PM2.5 is a mixture. In the test, ambient PM2.5 is divided into 

major components, with a separate relative response factor (RRF) and future design value (DVF) 

calculated for each of the PM2.5 components. Since the attainment test is calculated on a per 

species basis, the attainment test for PM2.5 is referred to as the Speciated Modeled Attainment 

Test (SMAT). The following sections outline the process to determine that 2009 projections of 

PM2.5 will meet the NAAQS from regional modeling, as suggested in EPA’s modeling guidance. 

6.5.2.1 Determine Baseline Design Values 

The first step in any attainment test process is to determine the baseline design value 

(DVB). EPA guidance recommends using a DVB that is the average of the three design value 

periods that straddle the baseline inventory year (i.e., the average of the 2000-2002, 2001-2003, 

and 2002-2004 design value periods for a 2002 baseline inventory year). This works out to a 5-

year weighted average, with the baseline year having the heaviest weight (i.e., {[2000] + 

2*[2001] + 3*[2002] + 2*[2003] + [2004]}/9). 

For the SMAT process, a mean PM2.5 DVB is determined, as well as component specific 

DVB for each quarter. The following section will detail the calculation of baseline design values 

needed for the PM2.5 attainment test. 

Mean PM2.5 Baseline Design Values 

To begin the SMAT process, a mean PM2.5 DVB is calculated on a quarterly basis for 

each Federal Reference Method (FRM) monitor in the PM2.5 nonattainment areas. 

Concentrations are calculated based on calendar quarters (Q1: January - March; Q2: April - June; 

etc.) as the NAAQS is calculated for a calendar year, and the quarters need to fit evenly within a 

year. Also, calculating the attainment test on a quarterly basis allows states to examine the 

differences in PM2.5 composition that occur during the different seasons. 

Speciated Baseline Conditions 

The monitored attainment test for PM2.5 utilizes both PM2.5 and individual PM2.5 component 

species. A separate RRF is calculated for each PM2.5 species. In order to perform the 

recommended modeled attainment test, States should divide observed mass concentrations of 

PM2.5 into 7 components (plus passive mass): 

1. Mass associated with sulfates (SO4) 

2. Mass associated with nitrates (NO3) 

3. Mass associated with ammonium (NH4) 

4. Mass associated with organic carbon (OC) 

5. Mass associated with elemental carbon (EC) 

6. Mass associated with particle bound water (PBW) 

7. Mass associated with “other” primary inorganic particulate matter (Crustal) 

8. And passively collected mass or the mass of the blank filter 

The second part of the process is to use the quarterly mean PM2.5 DVBs with speciated data 

to calculate the quarterly mean concentrations of these 7 components at the FRM sites. This 

need to speciate the FRM data presents two issues: 

81
1. FRM measurements and speciated PM2.5 measurements do not always measure the same 

mass. 

2. Not all FRM monitoring sites have co-located STN speciation monitors. 

The following sections will explain how these issues were overcome to produce the speciated 

values needed for this attainment demonstration. 

SANDWICH 

As EPA guidance notes, recent data analyses have noted that the FRM monitors do not 

measure the same components and do not retain all of the PM2.5 that is measured by routine 

speciation samplers and therefore cannot be directly compared to speciation measurements from 

the Speciation Trends Network (STN). By design, the FRM mass measurement does not retain 

all ammonium nitrate and other semi-volatile materials (negative sampling artifacts) and includes 

particle bound water associated with sulfates, nitrates and other hygroscopic species (positive 

sampling artifacts). This results in concentrations (and percent contributions to PM2.5 mass), 

which may be different than the ambient levels of some PM2.5 chemical constituents. 

To resolve the differences between FRM and STN total mass, EPA recommends using 

the “sulfate, adjusted nitrate, derived water, inferred carbonaceous material balance approach” or 

SANDWICH approach. With the SANDWICH approach, nitrate mass is adjusted to account for 

volatilization based on hourly meteorology parameters. Subsequently, quarterly average nitrate, 

sulfate, elemental carbon, and crustal mass can be calculated, as well as the Degree of 

Neutralization (DON) of sulfates. Quarterly average NH4 can then be calculated from the 

adjusted nitrate mass, sulfate mass, and DON of sulfate. Next the mass of particle bound water 

can be calculated from the previously obtained DON, sulfate, nitrate, and ammonium values. 

Finally, organic carbon is calculated by taking the difference between the total PM2.5 mass as 

measured at the FRM monitor, and the calculated component mass (i.e., OC from mass balance 

([OCMmb] = PM2.5FRM:{[EC] + [SO4] + [NO3] + [NH4] + [water] + [crustal material] + 

[passive mass]}), where the passive mass is the FRM sampling artifact normally set equal to 

0.5}. 

To allow for simple presentations and analyses, however, SANDWICH data can also be 

presented by major components of PM2.5 mass. In this approach, water and nitrates are 

combined with [SO4] and [NO3]. Then the FRM and STN masses are reconciled by: PM2.5= 

[SANDWICH sulfate mass] + [SANDWICH nitrate mass] + [SANDWICH TCMmb] + 

[SANDWICH Crustal Mass] + [Passive mass]. EPA Region 3 office provided SANDWICHed 

data for all monitors in the PA-NJ-DE PM2.5 nonattainment area. For a description and use of 

the SANDWICH method see the EPA documents (Appendix C). 

Speciated Profiles

While the SANDWICH method reconciles the differences between FRM and STN, a 

lingering issue is that not all FRM monitoring sites have co-located STN monitors to provide 

speciated data. EPA guidance suggests four measures that can be taken to resolve the lack of 

speciated data: 

82
1. Use of concurrent data from a near by speciated monitor 

2. Use of representative data (from a different time period) 

3. Use of interpolation techniques to create a spatial field using ambient speciation data 

4. Use of interpolation techniques to create spatial fields, and gridded modeling outputs to 

adjust the species concentrations 

Of the four methodologies, the EPA recommends using one of the spatial interpolation 

techniques to estimate species concentrations at FRM sites that do not have speciation data 

(numbers 3 and 4 above). To assist in this task, the EPA is developing a software tool called 

“Modeled Attainment Test Software” (or MATS) that will perform the spatial analysis of 

described options number 3 and 4. However, the MATS tool is not available at this time. In 

trying to pursue the EPA recommended course of action, option 1, that is, use of concurrent data 

from a nearby speciated monitor is utilized. 

6.5.2 Relative Response Factor Calculations 

 The calculation of relative response factors (RRFs) for this study was performed using 

the EPA recommended method for “nearby” grid cells for a 12-kilometer horizontal grid 

resolution, with a 3x3 grid cell array for 12-km resolution modeling. The relative response factor 

used in the modeled attainment test is computed by taking the ratio of the mean of the 

predictions in the future to the mean predictions with baseline emissions, over all relevant days. 

 For the 24-hour and annual PM2.5 NAAQS, the spatially averaged value of the nearby 

predictions (mean value of the grid cell array) was used. Each component-specific RRF was used 

in the modeled attainment test by taking the ratio of the mean of the spatially averaged daily 

predictions in the future to the mean of the spatially averaged daily predictions with current 

emissions. 

The basis for this approach is as follows: 

1. Consequence of a control strategy may be “migration” of a predicted peak. If a State were 

to confine its attention only to the cell containing a monitor, it might underestimate the 

RRF (i.e., overestimate the effects of a control strategy). 

2. Uncertainty in the formulation of the model and the model inputs is consistent with 

recognizing some leeway in the precision of the predicted location of concentrations. 

3. Standard practice in defining a gridded modeling domain is to start in the southwest 

corner of the domain, and determine grid cell location from there. Considering several 

cells “near” a monitor rather than the single cell containing the monitor diminishes the 

likelihood of inappropriate results which may occur from the geometry of the 

superimposed grid system. 

4. The area does not exhibit strong spatial concentration gradients of observed primary 

PM2.5. 

83
6.5.3 Annual SMAT Results 

Table 6-4 presents the results of the annual SMAT results for the PA-NJ-DE 

nonattainment area. The SMAT results demonstrate that the projected average annual arithmetic 

mean PM2.5 concentration calculated at each FRM monitor attains the annual PM2.5 NAAQS. 

Specifically, all future design value (DVF) calculations are less than15 μg/m3

. Table 6-4 

presents the results of the annual SMAT results for a suite of regional modeling runs conducted 

by OTC each representing OTB/OTW – “On the Books, On the Way” control measures. All 

runs demonstrate compliance with the annual NAAQS. 

 Table 6-4: Annual SMAT Results for PA-NJ-DE Nonattainment Area 

2009 On-The-Books-On-The-Way Control Measures 

2000-2004 DVB 2009 

AIRS ID Site Name County State Q1 Q2 Q3 Q4 DVF 

10-003-1003 Bellefonte New Castle DE 14.91 15.54 15.45 13.02 12.3 

10-003-1007 Lums Pond New Castle DE 13.30 14.49 15.69 11.10 11.4 

10-003-1012 Newark New Castle DE 15.56 15.00 15.75 13.57 12.5 

10-003-2004 MLK New Castle DE 16.79 15.60 16.66 14.26 13.3 

34-007-0003 Copewood E Davis Camden NJ 13.5 14.3 16.6 12.7 12.1 

34-007-1007 Pennsauken TWP Camden NJ 14.0 14.0 15.7 13.6 12.2 

34-015-0001 Gibbstown Municipal Bldg. Gloucester NJ 13.9 13.4 16.0 11.4 11.7 

42-017-0012 Bristol Bucks PA 14.14 13.68 14.70 13.82 12.4 

42-029-0100 Belmont Avenue Chester PA 14.44 14.07 16.72 14.12 12.8 

42-045-0002 Chester Delaware PA 15.07 15.96 16.35 12.63 13.3 

42-091-0013 Norristown Montgomery PA 13.61 13.77 14.90 12.71 12.0 

42-101-0004 Philadelphia AMS Philadelphia PA 14.13 13.86 16.20 12.83 12.5 

42-101-0020 Philadelphia Belmont Ave Philadelphia PA 14.0 14.4 15.4 13.1 12.0 

42-101-0024 Philadelphia North East Philadelphia PA 12.43 12.37 15.56 11.45 11.0 

42-101-0047 Philadelphia Broad Street Philadelphia PA 15.54 14.88 16.89 13.25 12.8 

42-101-0136 Philadelphia Elmwood Philadelphia PA 13.75 13.04 15.75 11.93 11.5 

6.5.4 24-Hour SMAT Results 

Table 6-5 presents the results of the 24-hour SMAT results for the PA-NJ-DE nonattainment 

area. Some difficulties presented in estimating the future design values include - missing FRM 

data for 2000 and 2001 at some monitors and the limitation of the SANDWICH data provided by 

Region 3 office to the period 2002–2004. Therefore, the 2009 projected design values are for the 

period 2002-2004. The SMAT results demonstrate that the projected average annual arithmetic 

mean PM2.5 concentration calculated at each FRM monitor attains the 24-hour PM2.5 NAAQS. 

All future design value (DVF) calculations are well below 65 μg/m3

. 

84
Table 6-5: 24-Hour Modeling Attainment Test Using EPA SMAT Methodology 

2009 On-The-Books/On-The-Way Control Measures 

24-Hour 98th Percentile DVB 2009 

AIRS ID Site Name County State 2000 2001 2002 2003 2004 DVF 

10-003-1003 Bellefonte New Castle DE 32.4 38.7 33.3 35.7 29.7 25.2 

10-003-1007 Lums Pond New Castle DE 31.7 35.1 28.2 32.6 30.6 22.8 

10-003-1012 Newark New Castle DE 37.2 39.3 38.0 35.5 28.8 26.3 

10-003-2004 MLK New Castle DE 38.4 40.5 35.6 37.4 32.4 28.4 

34-007-0003 Copewood E Davis Camden NJ 31.0 36.7 35.3 42.8 34.2 26.3 

34-007-1007 Pennsauken TWP Camden NJ 32.8 37.6 34.8 35.7 32.0 25.6 

34-015-0001 Gibbstown Municipal Bldg. Gloucester NJ 31.8 36.3 28.0 32.7 27.6 23.4 

42-017-0012 Bristol Bucks PA 36.6 33.2 37.0 37.4 28.7 26.4 

42-029-0100 Belmont Avenue Chester PA NA NA 33.7 37.7 32.7 26.5 

42-045-0002 Chester Delaware PA 34.2 38.8 30.7 37.0 30.5 26.5 

42-091-0013 Norristown Montgomery PA 30.0 38.0 33.6 33.6 27.0 24.1 

42-101-0004 Philadelphia AMS Philadelphia PA 39.6 39.3 37.1 39.5 32.3 29.5 

42-101-0020 Philadelphia Belmont Ave Philadelphia PA 26.9 34.3 31.6 35.1 29.1 25.7 

42-101-0024 Philadelphia North East Philadelphia PA 32.2 35.1 33.7 32.8 32.0 26.3 

42-101-0047 Philadelphia Broad Street Philadelphia PA 34.2 37.1 34.5 38.3 30.1 26.7 

42-101-0136 Philadelphia Elmwood Philadelphia PA 36.0 42.9 35.2 34.7 29.3 26.7 

6.6 Unmonitored Area Analysis 

The modeled attainment test does not address future air quality at locations where there is 

not a PM2.5 monitor nearby. To guard against the possibility that air quality levels could exceed 

the standard in areas with limited monitoring, EPA suggests that additional review is necessary, 

particularly in nonattainment areas where the PM2.5 monitoring network just meets or minimally 

exceeds the size of the network required to report data to Air Quality System (AQS). This 

review is intended to ensure that a control strategy leads to reductions in PM2.5 and its constituent 

pollutants at other locations that could have baseline (and future) design values exceeding the 

NAAQS were a monitor deployed there. The test is called an “unmonitored area analysis”. The 

purpose of the analysis is to use a combination of model output and ambient data to identify 

areas that might exceed the NAAQS if monitors were located there. 

 It is important to note that Delaware currently operates a network of seven PM2.5

monitors. Four of these monitors are in New Castle County, which is part of the PA-NJ-DE 

nonattainment area. Some of these monitors were established as State and Local Air Monitoring 

Stations (SLAMS). These SLAMS monitors were selected based on specific monitoring 

objectives (background concentration, area of highest concentration, high population, source 

impact, transport, and rural impact) as required by EPA and siting scales (micro, middle, 

neighborhood, urban, and regional) established by EPA. 

It is believed that the density of the monitoring network in New Castle County relieves 

the necessity of applying this additional analysis. Despite being confident the monitoring 

network is robust enough to cover the New Castle County, once the final version of the MATS 

tool has been released, and after sufficient peer review and proper guidance documentation for 

the analysis of the results is provided, the TAC Modeling Committee will evaluate the MATS 

85
tool output. However, we present here a geostatistical spatial analysis that shows attainment of 

the PM2.5 NAAQS for the entire PA-NJ-DE nonattainment area. 

The geostatistical spatial analysis extends the projected design values at the monitors by 

interpolating them to provide spatial fields in the monitored and unmonitored areas. The spatial 

fields will provide an indication of concentrations in monitored and unmonitored areas. But a 

simple interpolation of the data cannot identify unmonitored areas with higher concentrations 

than those projected at the monitors. The interpolated concentration between monitors will 

generally be the same or lower than the projected concentration at the monitors unless more 

sophisticated statistical techniques, such as adding a nugget effect or a trend surface, are used. 

The geostatistical spatial analysis that we adopted here calculates empirical variograms 

that provide distances and the estimated semi-variances. Theoretical and empirical variograms 

can be plotted and visually compared. Theoretical variograms are computed by parameter 

estimation by some methods, such as the maximum likelihood (ML), restricted maximum 

likelihood (REML), ordinary and weighted least squares (OLS & WLS), Bayesian kriging, etc. 

When using the parameter estimation the nugget effect can either be estimated or set to a fixed 

value. The same applies to smoothness, anisotropy and transformation parameters. Options for 

taking trends into account are also accounted for by specifying polynomial functions of the 

coordinates and/or linear functions of given covariates. Conventional spatial interpolation, i.e. 

kriging, can be performed with options for – simple kriginng, ordinary kriging, trend (universal) 

kriging, external trend kriging, etc. Additional options can be provided by Box-Cox 

transformation, back transformation of the results, and anisotropic models. Simulations can be 

drawn from the resulting predictive distributions covering the domain. Bayesian analysis for 

Gaussian models can be performed for different degrees of uncertainty. 

First, we present here geostatistical spatial analysis for the annual standard and show that 

the standard is met everywhere in the nonattainment area. Projected design values at the 

monitors in the PA-NJ-DE nonattainment area form the basis of this analysis. Theoretical and 

empirical variograms can be plotted and visually compared. When using the parameter 

estimation for the theoretical variograms, the nugget effect can either be fixed or estimated. 

Figure 6-13 shows how empirical variograms can be fitted with different models with the options 

of fixed or estimated nugget parameter. Next a model that fits the data can be chosen to predict 

on a grid covering the area that may or may not include the nugget effect. However, ordinary 

kriging, without the sophisticated statistical techniques such as adding the nugget effect or a 

trend surface, would interpolate the concentrations between the monitors to generally lower or 

the same as projected design values at the monitors. Therefore, we performed the prediction 

with the nugget effect set to 0.15 and the weighted least squares (WLS) model. The resulting 

map Figure 6-14 shows that the entire PA-NJ-DE nonattainment area will attain the annual 

standard; furthermore, it shows somewhat elevated concentrations in the northern portion of the 

PA-NJ-DE nonattainment area than the southern portion; this is in agreement with the 

monitoring data in the PA-NJ-DE NAA. 

86
0.0 0.2 0.4 0.6 0.8 1.0

0.0 0.2 0.4 0.6 0.8

fixed τ

2 = 0

Distance

Semi-variance

ML

REML

OLS

WLS

0.0 0.2 0.4 0.6 0.8 1.0

0.0 0.2 0.4 0.6 0.8

fixed τ

2 = 0.15

Distance

Semi-variance

ML

REML

OLS

WLS

0.0 0.2 0.4 0.6 0.8 1.0

0.0 0.2 0.4 0.6 0.8

estimated τ

2

Distance

Semi-variance

ML

REML

OLS

WLS

Figure 6-13: Empirical variogram fitted with different models for the annual standard 

87
-76.0 -75.8 -75.6 -75.4 -75.2 -75.0 -74.8 -74.6

38.8 39.0 39.2 39.4 39.6 39.8 40.0

Lon

Lat

Figure 6-14: Map of kriging estimates for the annual standard fitted with weighted least 

squares model and nugget set to 0.15 

Next, we consider the same approach for the daily standard and show that the standard is 

met everywhere in the PA-NJ-DE nonattainment area. Figure 6-15 shows the effect of fitting 

the empirical variogram with different models with the options of fixed or estimated nugget 

parameter. Figure 6-16 shows a map for the entire PA-NJ-DE NAA for the daily standard that 

results from predicting with the WLS model and nugget effect set to 0.15. The figure shows the 

entire PA-NJ-DE NAA will attain the daily standard. 

88
0.0 0.2 0.4 0.6 0.8 1.0

01234567

fixed τ

2 = 0

Distance

Semi-variance

ML

REML

OLS

WLS

0.0 0.2 0.4 0.6 0.8 1.0

01234567

fixed τ

2 = 0.15

Distance

Semi-variance

ML

REML

OLS

WLS

0.0 0.2 0.4 0.6 0.8 1.0

01234567

estimated τ

2

Distance

Semi-variance

ML

REML

OLS

WLS

Figure 6-15: Empirical variogram fitted with different models for the daily standard 

89
-76.0 -75.5 -75.0 -74.5

38.8 39.0 39.2 39.4 39.6 39.8 40.0

Lon

Lat

Figure 6-16: Map of kriging estimates for the daily standard fitted with weighted least 

squares model and nugget set to 0.15 

6.7 Local Area Analysis 

 Base on review of final EPA modeling guidance, the local area analysis is designed to 

identify local primary PM2.5 sources that are thought to be contributing to a monitor and causing 

non-attainment of the NAAQS. At this time, no monitors within the PA-NJ-DE nonattainment 

area are projected to exceed the NAAQS so it does not appear to be a necessary requirement in 

this circumstance to conduct the local area analysis. Furthermore, existing monitoring data 

suggests a uniform regional pattern with respect to PM2.5 concentrations rather than any “hot 

spot” monitor. 

90
6.8 Supplemental Analyses and Weight of Evidence Determination 

 All models, including the CMAQ, model have inherent uncertainties. Over or under 

prediction may result from uncertainties associated with emission inventories, meteorological 

data, and representation of PM2.5 chemistry in the model. Therefore, EPA modeling guidance 

provides for other evidence to address these model uncertainties so that proper assessment of the 

probability to attain the applicable standards can be made. 

 EPA modeling guidance states that those modeling analyses that show that attainment 

with the NAAQS will be reached in the future with some margin of safety (i.e., estimated 

concentrations below 14.5 μg/m3

 for annual PM2.5 and 62 μg/m3 for 24-hour PM2.5) need more 

limited supporting material. 

Due to the fact that the modeling results presented in Tables 6-4 and 6-5 fall well below 

the aforementioned “weight of evidence” thresholds established by EPA, a limited supplemental 

analysis was deemed necessary to support the 2009 attainment demonstration. 

 

Trends in PM2.5 Design Values

Figure 6-17 below show trends for the period 2000-2006 in annual PM2.5 design value 

for all monitors in the PA-NJ-DE NAA including the monitors in Kent and Sussex Counties. It 

is clear from this figure that all the monitors show a downward trend in the annual PM2.5 design 

value. It is noteworthy that 2004-2006 design values at all monitors, with the exception of 

Chester monitor, already met the annual PM2.5 standard. 

Design Values: 3-Year Averages All Monitors Philadelphia CMSA

11

13

15

17

2000-2002 2001-2003 2002-2004 2003-2005 2004-2006

ug/m3

Camden Bristol Chester Norristown AMS lab Belmont Ave WTP

NE Airport South Broad St. Amtrak/Elmwood Bellefonte MLK Newark

Lums Pond Dover Killens Pond Seaford

91
Figure 6-17. Trend in Annual PM2.5 Design Values (2000 through 2006) 

Figure 6-18 below show trends for the period 2000 - 2006 in daily PM2.5 design value 

for all monitors in Delaware nonattainment area including the monitors in Kent and Sussex 

Counties. It is clear from this figure that all the monitors show a downward trend in the daily 

PM2.5 design value. It is noteworthy that the at all monitors already met the daily standard in 

2006; they also met the new daily PM2.5 standard (35 μg/m3) with the exception of Camden, 

South Broad Street, and MLK. 

A downward trend in both annual and daily PM2.5 design values indicate that the control 

measures implemented during this period have been providing PM2.5 reduction benefits. With 

more controls anticipated in coming years, this trend is expected to continue. 

PM2.5 Daily Design Values for monitors in PA-NJ-DE NAA

30.0

35.0

40.0

45.0

2000 - 2002 2001 - 2003 2002 - 2004 2003 - 2005 2004 - 2006

PM2.5 (ug/m^3)

Camden Bristol Chester Norristown AMS lab Belmont Ave WTP

NE Airport South Broad St. Amtrak/Elmwood Bllfte MLK-a Nwrk-a

Lums Dover Killens Seaford

Figure 6-18. Trend in Daily PM2.5 Design Values (2000 through 2006) 

6.9 Conclusions 

The results from the modeling as well as the supplemental analyses present 

overwhelming evidence that the PA-NJ-DE nonattainment area will attain the 24-hour and 

annual PM2.5 NAAQS by April 5, 2010. Based on air quality measurements and future predicted 

air quality modeling results the projected design values are below the NAAQS attainment criteria 

of 15.0 μg/m3 for annual PM2.5 and 65 μg/m3 for 24-hour PM2.5. 

92
Section 7 - Reasonably Available Control Measures (RACM) and Reasonably Available 

Control Technology (RACT) 

7.1 Background and Requirements 

This section discusses Reasonably Available Control Measures (RACM) and Reasonably 

Available Control Technology (RACT) for sources of pollutants regulated under this SIP (i.e., 

primary fine particulate matter (PM2.5), nitrogen oxides (NOx) and sulfur dioxide (SO2))14. 

In accordance with Section 51.1010 of the PM2.5 Implementation Rule15, “the State shall 

submit with the attainment demonstration a SIP revision demonstrating that it has adopted all 

reasonably available control measures (including RACT for stationary sources) necessary to 

demonstrate attainment as expeditiously as practicable and to meet any RFP requirements. The 

SIP revision shall contain the list of the potential measures considered by the State, and 

information and analysis sufficient to support the State’s judgment that it has adopted all 

RACM, including RACT.” 

For primary PM2.5 RACM, the Department evaluated measures which would be limited 

to the boundaries of the non-attainment area, i.e. New Castle County. However, because SO2

and NOx can be transported over considerable distances to form PM2.5, they were assessed on a 

state-wide basis (see Appendix 7-1 for EPA List of Control Measures evaluated). Also, while 

not specifically regulated under this SIP, several VOC measures are discussed in this section, as 

they are included in the modeling associated with this attainment demonstration. 

7.2 Post-2002 RACT and RACM Measures 

Since 2002, Delaware and EPA have implemented numerous measures that have resulted 

in NOx, SO2 and PM2.5 reductions throughout the State. These measures represent 

RACM/RACT, and in some cases, requirements that go beyond RACM/RACT requirements, 

and will result in more than a 50% reduction in overall emissions between 2002 and 2009. Years 

2002 and 2009 are compared, by county, in Table 7-1 below. 

Table 7-1 DE 2002 and Projected 2009 Emissions 

County NOx PM2.5 SO2

2002 2009 2002 2009 2002 2009 

Kent 10,314 7799 1097 989 4,062 3664 

New Castle 30,748 21,807 3430 3015 50,237 14135 

Sussex 16060 11591 2575 2571 25,552 11724 

 Totals 57,122 41,197 7,102 6,575 79,852 29,523 

Sections 7.2.1 through 7.2.5 present a listing of these post-2002/pre-2010 state and 

federal measures that fulfill Delaware’s RACT/RACM obligations. 

 

14 See Section 1.4 of this SIP for a discussion of the pollutants that are regulated under this SIP. 

15 Environmental Protection Agency, Clean Air Fine Particle Implementation Rule, 40 CFR Part 51, March 29, 2007 

93
7.2.1 Point Sources: 

 40 CFR Parts 51, 72, et al. Rule to Reduce Interstate Transport of Fine Particulate Matter 

and Ozone (Clean Air Interstate Rule) 

 “Inclusion of Delaware and New Jersey in the Clean Air Interstate Rule” 71 Fed. Reg. 

25288 April 28, 2006. 

 Consent Decree. Premcor Refinery, Delaware City (formerly Motiva Enterprises) New 

Castle County. Control of SO2, and NOX Emission from Boilers and Heaters 

 Regulation 1146, EGUs, Electric Generating Unit (EGU) Multi-Pollutant Regulation, 

SO2 and NOx emission control (effective December 11, 2006) 

 Regulation No. 1148, Control of Stationary Combustion Turbine Electric Generating Unit 

Emissions, NOx emission control 

 Regulation 1144, Control of Stationary Generator Emissions, SO2, PM, VOC and NOx 

emission control 

 Regulation 1142, Section 1, Control of NOx Emissions from Industrial Boilers, NOx 

Emission Control 

 Regulation 1142, Section 2, Control of NOx Emissions from Industrial Boilers and 

Process Heaters at Petroleum Refineries, NOx emission control, New Castle County 

 Regulation 24 Sec. 46, Crude Oil Lightering Operations, VOC emission control, 

 Facility and Unit shutdowns (see Table 4-3) 

7.2.2 Non-Point Sources: 

 Regulation 24 Sec. 33, Solvent Cleaning and Drying, VOC emission control 

 Regulation 24 Sec. 11, Mobile Equipment Repair and Refinishing, VOC emission control

 Regulation 41 Sec. 3, Portable Fuel Containers, VOC emission control 

 Regulation 41 Sec. 2, Consumer Products, VOC emission control

 Regulation 41 Sec 1, Architectural and Industrial Maintenance Coatings, VOC emission 

control 

 Regulation 24 Sec. 36, Stage II Vapor Recovery, VOC Emission control

94
 Residential Woodstoves 40 C.F.R. Part 60 Subpart AAA New Source Performance 

Standards (“NSPS”) for PM, VOC and NOx emission control. 

 Regulation 1113, Open Burning, PM, VOC and NOx emission control

7.2.3 Non-Road Sources: 

 Phase I and Phase II Emissions Standards for Gasoline-Powered Non-Road Utility 

Engines, Federal Rule 

 Emissions Standards for Diesel-Powered Non-Road Utility Engines of 50 or More 

Horsepower, Federal Rule 

 Emissions Standards for Spark Ignition (SI) Marine Engines, Federal Rule 

 Emissions Standards for Large Spark Ignition Engines, Federal Rule 

 Reformulated Gasoline Use in Non-Road Motor Vehicles and Equipment, Federal Rule, 

“Control of Emissions from New Marine Compression-Ignition Engines at or above 30 

liters per Cylinder; Final Rule,” 68 Fed. Reg. 9746 (February 28, 2003), at pp.9755-56 

(hereinafter “EPA C3 Rule”) 

7.2.4 On-Road Mobile 

 Regulation No. 31, Low Enhanced Inspection and Maintenance Program 

 Regulation No. 1132, Transportation Conformity Regulation 

 40 CFR Parts 80, 85, and 86 Control of Air Pollution from New Motor Vehicles: Tier 2 

Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements; Final 

Rule 

 40 CFR Parts 69, 80, and 86 Control of Air Pollution from New Motor Vehicles: HeavyDuty Engine and Vehicle Standards and Highway Diesel Fuel Sulfur Control 

Requirements; Final Rule. 

 Regulation 1145, Excessive Idling of Heavy Duty Vehicles 

 Regulation No. 40, NLEV Program 

7.2.5 Other Measures 

Delaware has implemented many other SO2, NOx, VOC and PM2.5 control measures. These 

measures include mandatory episodic prohibition of lightering on ozone action days (Reg. 1124, 

Section 36), and reduction of emissions from high electric demand day electric generation (Reg. 

1146 and Reg. 1148). Other voluntary measures that will take effect by 2010 include:

95
• Brandywine School District Bus Retrofits 

• Delaware Ride Share 

• Ozone Action Days (voluntary curtailment of activities that contribute to air pollution) 

• Use Biodiesel (B20) in state-run equipment 

• Best Workplaces for Commuters and SmartWay Transport programs. 

• Implement an anti-idling outreach programs for schools and school districts 

• Clean State Program – focusing on greater use of alternative transportation fuels 

• Installation of E85 station in Delaware 

• Continue to identify and implement energy efficiency programs for the residential and 

commercial sectors. Energy efficiency programs include: 

o Energy efficiency/conservation education, outreach, technical assistance. 

o Energy An$wers Program 

o Home Appliances 

o Business 

o Home Performance 

o Energy Star Program 

o Sustainable Energy Utility (SEU) 

7.3 Additional RACM/RACT Evaluation 

Delaware’s attainment date for the NAAQS is April 201016. However, states are required 

to demonstrate attainment as expeditiously as practicable, which would be at least one year 

earlier than the attainment year, e.g. April, 2009. Attainment by April 2009 would be based on 

ambient air PM2.5 concentrations in calendar years 2006, 2007, and 2008, so in order to attain at 

least one year early adequate emission reductions would need to occur, at the latest, by January, 

2008. 

Section 6 of this SIP demonstrates the CMAQ modeled emission levels that are 

consistent with attainment; emission levels higher than these levels are not adequate to attain. 

Statewide CMAQ modeled Delaware emissions levels for the pollutants regulated under this SIP 

are: 

Table 7-2 CMAQ Modeled 2009 Emissions, Delaware 

SO2 PM2.5 NOx 

42,569 8,014 49,602 

 

16 See Section 1.1 for a detailed discussion. 

96
In order to demonstrate attainment in 2009, Delaware’s 2008 emissions would need to be 

at or below the levels specified in Table 7-1. The following analysis demonstrates that Delaware 

has adopted RACT/RACM and beyond RACT/RACT measures (i.e., the measures identified in 

Section 7.2 above) that demonstrate attainment as expeditiously as practicable, and that 

advancement of the attainment date to April 2009 or earlier is not feasible.

1.) Many of the adopted control measures detailed in 7.2 above do not go into full effect 

until 2009. One significant Delaware measure is Regulation No. 1146, EGU Multipollutant Regulation. The approximate quantity of Delaware 2009 reductions that will 

not occur in 200817 as a result of Reg. 1146 not being effective in 2008 are detailed in 

Table 7-3: 

Table 7-3 2009 Statewide Emission Reductions attributable to Delaware Reg. 1146 (TPY) 

SO2 PM2.5 NOx 

19,229 -21818 3,147 

2.) As indicated in table 7-3, Regulation No. 1146 is a significant control measure for SO2

and NOx. It is not possible to advance the compliance date of Regulation No. 1146 from 

2009 to 2008; it was determined during the regulatory adoption process that the earliest 

feasible compliance date of Reg. 1146 was 2009. Conservatively assuming that all other 

planned 2009 reductions, other than Reg. 1146, would occur by 2008 Delaware’s 200819

emission projection would be: 

Table 7-4 2008 Emissions Projection**, Conservatively Low Estimate 

SO2 PM2.5 NOx 

48,752 6,357 44,344 

 ** Sum of Table 7-1 and 7-3. 

3.) Comparison of Tables 7-2 and 7-4 indicates that implementation of RACT/RACM and 

beyond RACT/RACM controls in Delaware may result in Delaware’s 2008 emission 

levels being below the levels that are consistent with attainment relative to both direct 

PM2.5 and NOX, but that they will be at least 6,183 TPY high relative to SO2 . 

4.) Step 3 above indicates that in order for Delaware to do its part in advancing the 

attainment date to April 2009 it would need to further reduce SO2 emissions by at least 

6,183 TPY by the beginning of 2008. To determine if this was possible, Delaware sorted 

 

17 Delaware’s Multi-Pollutant regulation (Reg. 1146) does not go into effect until 2009 

18 Reg. 1146 did not specifically address direct PM2.5 emissions, so 2009 PM2.5 emissions are projected to increase 

between 2002 and 2009 due to growth. Actual control technology installed to meet Reg. 1146 NOX, SO2, and Hg 

emission limitations may result in changes in PM2.5 emission rates, but such changes are not required by Reg. 1146 

19 This is a conservatively low estimate, as many measures (e.g., on-road mobile) gain reductions as time goes 

forward due to factors such as fleet turnover. Delaware’s actual 2008 emissions would likely be higher than this 

estimate. 

97
its entire SO2 inventory from highest emitting source to lowest emitting source, and 

developed a list that identifies the source categories that cover 95% of Delaware’s overall 

SO2 emissions. That list is presented in Table 7-5. 

Table 7-5 Delaware SO2 Emissions, Source Categories Covering 95% of 

Total Emissions 

Source Description Source Sector 2002 2009 

Combined Distillate Oil Combustion Total Point & Nonpoint 1,333 1,288

EGU Boiler - Bituminous/Subbituminous Coal 

Total Point 27,712 8,954 

EGU Boiler - Residual Oil Total Point 5,280 3,270 

ICI Boiler - Bituminous/Subbituminous Coal 

Total Point 4,824 5,606

ICI Boiler - CO Boiler Total Point 29,748 537 

ICI Boiler - Residual Oil Total Point 2,891 3,846

Industrial Processes - Fluid Coking Unit 

Incinerator 20 Point 1,133 1,045

Marine Vessels, Commercial - Diesel - 

Underway emissions Total Nonroad 1,255 269 

Marine Vessels, Commercial - Residual - 

Underway emissions Total Nonroad 2,025 2,248 

Totals = 76,201 27,062 

Complete Inventory Totals = 79,852 29,525 

% of Complete Inventory = 95.4% 91.7% 

The four (4) source categories that are highlighted in Table 7-5 are those that have not 

been controlled, relative to SO2, by post-2002 control measures. These are the source 

categories, that are projected to emit 11,785 TPY of SO2 in 2009, which Delaware could 

theoretically control to advance the attainment date (i.e., Delaware would need to reduce 

this 11,785 TPY of SO2 by at least 53% by 2008). Delaware is currently evaluating and 

developing measures to reduce SO2 emissions from these three categories as regional 

measures, but such actions will not be complete by and effective by 2008. 

Further, Delaware does not believe advancement of the attainment date to April 2008 in 

the Philadelphia CMSA is possible for the following additional reasons: 

• Transport of SO2 and NOx from measures such as the Clean Air Interstate Rule will 

not be mitigated in 2008 

 

• Emission benefits from fleet turnovers (onroad, offroad, lawnmowers, etc.) will be 

less in 2008 than 2009 

• Significant requirements like Delaware Regulation 1142 (Refinery Boiler 

Regulation), and Regulation 1146 (EGU Multi-Pollutant Regulation) do not go into 

effect until 2009 

 

20 This is emission release point an incinerator, i.e. control device, which only emits when the scrubber on the CO 

Boiler shuts down (unplanned). 

98
In summary, Delaware’s Regulation No. 1146 is a significant control measure in this SIP. 

Regulation No. 1146 reductions will not occur until 2009, and while Delaware has, and 

continues to evaluate additional SO2, NOX, and PM2.5 control measures, there are not enough 

emissions under Delaware’s control to cover with early control requirements to compensate for 

Reg. 1146 not being effective until 2009. Further, the timing of the development of emission 

controls for these other categories is not consistent with early attainment (i.e., reductions are not 

possible in 2008). Based on this Delaware has demonstrated that attainment by April 2010 is as 

expeditiously as practical, and that it has implemented sufficient RACM/RACT control 

requirements. 

99
Section 8 - Mobile Budgets for Transportation Conformity 

8.1 Introduction to Transportation Conformity 

Section 176 of the Clean Air Act requires that highway transportation projects funded or 

approved by the federal government conform to any applicable State Implementation Plan (SIP) 

adopted to provide for the attainment of any National Ambient Air Quality Standard. In general, 

this requirement specifies that (1) states establish, in their SIP, mobile source emission budgets 

for the attainment year, and submit the mobile budgets to EPA for approval, (2) upon adequacy 

determination or approval of EPA, states must conduct transportation conformity analysis for 

their Transportation Improvement Programs (TIPs) and long range transportation plans to ensure 

that future highway vehicle emissions will not exceed relevant mobile budgets, and (3) failure of 

demonstrating such transportation conformity in TIPs and long range plans will lead to 

conformity lapse(s), resulting in freezing of federal highway funds and all federal highway 

projects in the lapsed area. 

8.2 Mobile Budgets for 2009, the Attainment Year 

The mobile emissions budget 2009 attainment is based on the projected 2009 mobile 

source emissions, accounting for all relevant mobile source controls including all federal controls 

and Delaware specific controls as described in Section 4. The 2009 mobile emissions were 

projected using EPA’s MOBILE6.2 for obtaining emission factors and the “Peninsula Travel 

Demand Model” for predicting future vehicle miles traveled (VMT). The MOBILE6.2 runs 

were conducted by AQM’s staff using the most recently available vehicle registration data 

(2007), and projected speed estimates (2009). Examples of how to calculate the 2009 mobile 

emission projections are presented in Appendix 8-1. 

8.2.1 Mobile Budgets for 2009 Attainment Year 

 Table 8-1 is a summary of 2009 mobile source emission projections for each pollutant, 

PM2.5 and NOx in New Castle County. PM2.5 is the criteria air pollutant that New Castle County 

is designated as being in non-attainment for. Pursuant to 40 CFR 93.102, a motor vehicle 

emission budget must be established for this pollutant. 

 In addition, precursor pollutants to PM2.5 must also be analyzed as to whether motor 

vehicle budgets must be established for these pollutants. These pollutants include volatile 

organic compounds, ammonia, sulfur dioxide, and nitrogen oxides. Table 8-1 illustrates the onroad mobile source fraction of the total 2009 inventory for each precursor pollutant. 

100
Table 8-1 On-Road Mobile primary and Precursor PM2.5 Emissions as a Percent of 

Total Projected Inventory New Castle County 

2009 NOx VOC NH3 PM2.5 SO2

On-Road Mobile 

Source Projected 

Inventory 

4904 3466 610 87 51 

Total Projected 

Emission 

Inventory 

21444 13887 1466 3015 14135

Percent of Total 

Projected 2009 

Inventory 

22.9% 25.0% 41.6% 2.9% 0.4% 

 NOx is the only precursor pollutant that must have a budget established, unless both the 

EPA Regional Administrator and the director of the state air agency have determined that 

transportation-related emissions of NOx within the non-attainment area are not a significant 

contributor to the PM2.5 non-attainment problem, and so notified the MPO and DOT, that the 

applicable implementation plan (or implementation plan submission) does not establish an 

approved (or adequate) budget for such emissions as part of the reasonable further progress or 

attainment. 

 Pursuant to 72 FR 20595 states must demonstrate that on-road mobile SO2 emissions 

are not inhibiting the states’ ability to attain the PM2.5 applicable standard. As Table 8.1 indicates 

above, on-road mobile SO2 emissions only accounts for 0.4% of the total New Castle County 

2009 projected SO2 emissions. Except for NOx, the other precursor pollutants do not need a 

motor vehicle emissions budget unless either the state air agency director or the EPA Regional 

Administrator makes a finding that motor vehicle emissions budgets must be established in order 

to attain the NAAQS for PM2.5. No applicable finding has been made for any of the other 

precursor pollutants of PM2.5 and therefore the State Implementation Plan is only establishing 

motor vehicle emission budgets for PM2.5 and NOx. 

This summary herein establishes New Castle County PM2.5 and NOx emission budgets as 

specified in Table 8-2 for the attainment year 2009. 

Table 8-2 On-Road Mobile Source Emission Projections for 2009 

Tons/Year 

 2009 Emissions 

PM2.5 NOx 

New Castle 

87 4904 

101
Section 9 - Contingency Measures 

Under subpart 1 of the CAA, all PM2.5 non-attainment areas must include in their SIPs 

contingency measures consistent with section 172(c)(9). Contingency measures are additional 

control measures to be implemented in the event that an area fails to either meet RFP or attain 

the standards by its attainment date. 

These contingency measures must be fully adopted rules or control measures that are 

ready to be implemented quickly upon failure to meet RFP or failure of the area to meet the 

standard by its attainment date. States may also use as contingency measures one or more 

Federal or local measures that are in place and provide reductions that are in excess of the 

reductions required by the attainment demonstration or RFP plan. 

9.1 Quantification of Contingency Reductions Required 

The Rule requires that the quantity of emission reductions needed to satisfy contingency 

requirements is an amount equal to one year’s worth of required reductions. Required reductions 

are the amount of reductions needed to attain compliance with the PM2.5 NAAQS. 2002 

emissions are the base year emissions (see section 3 of this Document), and the CMAQ modeled 

2009 emissions are the emission levels that necessary for attainment (see Section 5 of this 

Document), so the difference between these emission levels is the total quantity of reductions 

required for attainment. Since there are seven years between 2002 and 2009, the total quantity of 

reductions required for attainment is divided by seven to determine 1-year’s worth of required 

reductions (i.e., the contingency requirement). 

9.1.1 CMAQ Modeled 2009 Emissions, i.e. Attainment Targets 

Table 5-1 shows the 2009 emission levels that are necessary for attainment (i.e., the 

attainment targets). The values of Table 5-1 are repeated in Table 9-1 below. These are the 

emission reductions accounted for in the CMAQ model, which showed attainment in 2010 for 

the Philadelphia CMSA (see Section 6 of this document for details). 

Table 9-1 Attainment Targets (TPY) 

Year County NOX PM2.5 SO2 

2009 New Castle 23048 3249 12001 

9.1.2 2002 Delaware Base Year 

Table 9-2 shows Delaware’s 2002 base year emissions (see Section 3 of this document 

for details). 

Table 9-2 Delaware 2002 Base Year 

County NOX PM2.5 SO2 

New Castle 30748 3430 50237

102
9.1.3 Contingency Requirement 

Table 9-3 shows one year’s worth of required emission reductions (i.e., the amount 

required for contingency). This was calculated by subtracting the attainment targets (Table 9-1) 

from the 2002 base year (Table 9-2), and dividing the difference by 7 years. 

Table 9-3 Contingency Requirement 

County NOX PM2.5 SO2

New Castle 1100 26 5462

9.2 Demonstration that Contingency Requirement is Met 

Table 9-4 shows Delaware’s projected 2009 emission levels for NOx and PM2.5 (see 

Section 4 of this document for details). 

Table 9-4 Delaware 2009 Projection 

County NOX PM2.5

New Castle 21807 3015 

Delaware shows that it has met the contingency requirement if the projected 2009 

emission levels (Table 9-4) are lower than those needed for attainment (Table 9-1) by at least the 

amount of the contingency requirement (Table 9-3). Subtracting the amounts in Table 9-4 from 

the amounts in Table 9-1 shows that Delaware control measures have reduced NOx and primary 

PM2.5 by more than is necessary to attain compliance with the PM2.5 NAAQS. Specifically, 

emissions reductions of 1,241 NOx and 234 PM2.5 TPY have been made that are above and 

beyond that necessary for attainment. And, these excess reductions which are “in place and 

provide reductions that are in excess of the reductions required by the attainment demonstration 

or RFP plan” are greater than the contingency requirement of 1,100 NOx and 26 PM2.5 TPY 

(Table 9-3). This demonstrates that the contingency requirement has been met relative to the 

pollutants NOx and primary PM2.5. Specific contingency measures are: 

NOx – Delaware Reg. 114621: Delaware estimates that 2009 statewide EGU NOx 

emissions are 5,933 TPY less than the MANEVU IPM calculations, owing to Delaware 

Reg. 1146. Therefore, to meet the 1,100 TPY NOx required for contingency, we 

apportion 1,100 TPY for 2011 contingency measures from Delaware Reg. 1146 and the 

remaining 4,833 TPY back into the model. 

 

21 Regulations Governing the Control of Air Pollution No. 1146 Electric Generating Unit (EGU) Multi-Pollutant 

Regulation, Delaware Department of Natural Resources and Environmental Control, Dover, Delaware, Effective 

12/11/06. 

103
PM2.5 – Consent Decree with Premcor Refinery22: Delaware gains additional 

reductions in New Castle County beyond those modeled by MANEVU, of 234 TPY. 

This is partly due to the MANEVU 2009 projections over-estimating the 2009 PM2.5 

emissions from Coker Off-Gas at the Premcor Refinery by 233 TPY. The Unit is covered 

under a consent decree with Premcor Refinery, Delaware City (formerly Motiva 

Enterprises) New Castle County, Control of SO2, and NOx Emission from Boilers and 

Heaters. Therefore, to meet the 26 TPY PM2.5 required for contingency, from the Coker 

Off-Gas over-estimates, we apportion 26 TPY for 2011 contingency measures and the 

remaining 197 back into the model. 

The circumstances are dissimilar for SO2. Table 9-5 (taken from Table 5-4) indicates that 

there is an attainment shortfall of 2,134 TPY for SO2 in New Castle. However, because of 

several new regulations in place by 2010, and as discussed in Sections 4 and 6 of this document, 

Delaware has a statewide surplus 13,047 TPY of SO2. 

Table 9-5 Contingency – SO2 “surplus and shortfalls” 

CMAQ 

Modeled SO2

Inventory 

(TPY) 

DE 2009 

Projected SO2

Emissions 

(TPY) 

SO2 Surplus/ 

Shortfall 

(TPY) 

Kent 2201 3664 -1463 

New Castle 12001 14135 -2134 

Sussex 28368 11724 16644 

Total 42569 29525 13047 

The 13,047 TPY overall SO2 reductions are above and beyond those needed for 

attainment, e.g., since 13,047 TPY is greater than 5,462 TPY, Delaware has demonstrated that 

the contingency requirement relative to SO2 has been met, and will specifically implement 2011 

SO2 contingency measures as follows: 

SO2 – Delaware Reg. 1146: Delaware estimates that statewide 2009 EGU SO2

emissions are 18,476 TPY less than the MANEVU IPM calculations, owing to Delaware 

Reg. 1146. Therefore, to meet the 5,462 TPY SO2 required for contingency, we 

apportion 5,462 TPY for 2011 contingency measures from Regulation 1146, and the 

remaining 13,014 back into the model. 

 

22 Consent Decree with Premcor Refinery at Delaware City (formerly Motiva Enterprises), New Castle County, 

Control of NOx Emission from Boilers and Heaters, Effective 2008 

104
Section 10 - Appendices 

A collection of the listed appendixes, stored on CD, is available upon request. Contact Delaware 

Department of Natural Resources and Environmental Control - Air Quality Management Section 

at 156 South State Street, Dover, DE 19901. 

Appendix 4-1 Development of Emission Projections for 2009, 2012, and 2018 for Non-EGU 

Point, Area, and Non-road Sources in the MANE-VU Region, Draft Final 

Technical Support Document, Prepared for Mid-Atlantic Regional Air 

Management Association (MARAMA) by MACTEC Federal Programs, Inc., 

December 7, 2006. 

Appendix 4-2 The 2009 Corrected Emission Projections of Delaware EGU, Non-EGU, NonPoint and Non-Road Mobile Sources. 

Appendix 4-3 The 2009 Emission Projections for Delaware’s Point, Non-Point, Onroad, and 

Non-Road Mobile Sources. 

Appendix 4-4 Part 1: MOBILE6.2 Input and Output Files for Delaware 2009 Mobile Source 

Emission 

Part 2: Calculations of 2008 and 2009 On-Road Mobile Source Emission 

Projections 

Appendix 6-1 The Nature of the Fine Particle and Regional Haze Air Quality Problems in 

the MANE-VU Region: A Conceptual Description (NESCAUM, November 

2006) and 

Appendix 6-2 The Development of PM2.5 Forecasting Tools for Selected Cities in the 

MARAMA Region (ICF, September 2004) 

Appendix 6-3 The New York State DEC, Division of Air Resources, performance evaluation 

of the 2002 base case CMAQ simulation 

Appendix 6-4/a Sandwich Method 

Appendix 7-1 EPA List of Control Measures 

Appendix 8-1 Example 2009 Mobile Emission Projection Calculations 

105
Secretary’s Order No.: 2008-A-OO11

RE: Approval as Final Plan the Proposed Revisions to the

State Implementation Plan (SIP) for the Attainment of the Fine Particle

(PM2.5) National Ambient Air Quality Standard (NAAQS)

Date of Issuance: April 1, 2008

Effective Date of the Amendment: April 1, 2008 V

I. Background

On Tuesday, March 4, 2008, a public hearing was held in the

Priscilla Building Conference Room of DNREC in Dover to receive publiccomment on proposed revisions to the State Implementation Plan (SIP)for the Attainment of the Fine Particle (PM2.5) National Ambient AirQuality Standard (hereinafter referred to as “NAAQS”). The United StatesEnvironmental Protection Agency (“EPA”) delegated authority to the

Department to administer certain responsibilities in Delaware under the

federal Clean Air Act, as amended, 42 US.C.74O1 et seq. (“CAA”). The

delegation included preparing Delaware’s State Implementation Plan

(“SIP”), which is required by EPA’s regulations known as the National

Ambient Air Quality Standard (“NAAQS”).

De€a4iae 4 T’taaie dcfreü o
New Castle County in Delaware, and federal law requires the NAA to attainthe NAAQS by April, 2010. In response to the non-attainmentdesignation, Delaware has developed the SIP revision for Delaware’s

proposed plan for Attainment of the Fine Particle (PM2.5) NAAQS.

The purpose of this SIP is to: (1) demonstrate that with all existing

and proposed controls, all of Delaware’s PM2,5 monitors will showattainment in 2009; (2) demonstrate that the entire Philadelphia

Wilmington, PA-NJ-DE nonattainment area will attain the PM2.5 NAAQS in

2009; (3) establish Delaware’s 2009 mobile source budgets for

transportation conformity determinations under Regulation No. 1132,

Transportation Conformity; and (4) treat emission reduction credits banked

under Regulation No. 34, Emissions Banking and Trading Program, as

“emitted.”

Written comments regarding this proposed SIP revision were

received by the Department during the pre-hearing phase of this matter,as well as numerous written and verbal comments received at the time ofthe hearing itself. All public comments were thoroughly addressed in theDepartment’s Response Document, which was attached to the Hearing

Officer’s Report and expressly incorporated therein. As a result of some

2
Proper notice of the hearing was provided as required by law.

After the hearing, the Department performed an evaluation of the

evidence entered into the record in this matter. Thereafter, the HearingOfficer prepared her report and recommendation in. the form of a Hearing

Officer’s Report to the Secretary dated March 31, 2008, and that report is

expressly incorporated herein by reference.

II. Findings and Conclusions:

On the basis of the record developed in this matter, it appears that

AQM has provided a sound basis for the proposed revision to the State

Implementation Plan (SIP) with respect to State Implementation Plan

(SIP) for the Attainment of the Fine Particle (PM2.s) National Ambient Air

Quality Standard (NAAQS). Based upon the public record, I agree that

the proposed SIP revision should be approved as the Department’s final

plan and submitted to the EPA to comply with the CAA and EPA’s CAA

regulations.

Order

It is hereby ordered that AQM’s suggested revisions with respect to

the State Implementation Plan (“SIP”) for the Attainment of the FineParticle (PM2.5) National Ambient Air Quality Standard (NAAQS) be made,

3
This revision to the SIP will demonstrate that, with all existing

and proposed controls, all of Delaware’s PM2.5 monitors will showattainment in 2009, and will demonstrate that the entire Philadelphia

Wilmington, PA-NJ-DE nonattainment area will attain the PM2.5 NAAQS in

2009. Moreover, this SIP will establish Delaware’s 2009 mobile source

budgets for transportation conformity determinations under Regulation No.

1132, Transportation Conformity, and will treat emission reduction credits

banked under Regulation No. 34, Emissions Banking and Trading

Program, as “emitted”.

For all the reasons above, this SIP revision with respect to the

attainment of the Fine Particle (PM2.5) National Ambient Air Quality

Standard (NAAQS) demonstrates Delaware’s overall strategy for attaining

the NAAQS by the year 2009, in furtherance of the policy and purposes

of 7 Del. C., Ch. 60.

nA.Hug s

Secretary

Ahear\SIP.Attain.PM2. 5NAAQS.08.ORD

4
HEARING OFFICER’S REPORT

Regarding: Proposed Revisions to the

State Implementation Plan (SIP) for the Attainment of the

Fine Particle (PM2.5) National Ambient Air Quality Standard (NAAQS), and for Delaware’s 2002 Base Year PM2.5 SIP Emission Inventory

Lisa A. Vest

Hearing Officer

March 31, 2008
for the Attainment of the Fine Particle (PM2.5) National Ambient Air

Quality Standard (hereinafter referred to as “NAAQS”). In April of 2005,the Environmental Protection Agency (EPA) designated 126 areas of the

country as “non-attainment” under the PM2.5NAAQS. Among those nonattainment areas is the Philadelphia-Wilmington, PA-NJ-DE NonAttainment Area (NAA). This NAA includes New Castle County in

Delaware, and federal law requires the NAA to attain the NAAQS by April,2010. In response to the non-attainment designation, Delaware has

developed the SIP revision for Delaware’s proposed plan for Attainment of

the Fine Particle (PM2.5) NAAQS.

The purpose of this SIP is to: (1) demonstrate that with all existing

and proposed controls, all of Delaware’s PM2.5 monitors will show

attainment in 2009; (2) demonstrate that the entire Philadelphia

Wilmington, PA-NJ-DE nonattainment area will attain the PM2.s NAAQS in

2009; (3) establish Delaware’s 2009 mobile source budgets for

transportation conformity determinations under Regulation No. 1132,

Transportation Conformity; and (4) treat emission reduction credits banked

under Regulation No. 34, Emissions Banking and Trading Program, as“emitted.”

2
formation of PM2.5,including sulfur dioxide, oxides of nitrogen, volatile

organic compounds, and ammonia. It will also serve as the primary source

of data used in the projection of future year emissions.

Written comments regarding this proposed SIP revision were

received by the Department during the pre-hearing phase of this matter,

as well as numerous written and verbal comments received at the time of

the hearing itself, all of which will be addressed below in this report.

Proper notice of the hearing was provided as required by law.

II. Summary of Hearing Record:

A. Exhibits:

Exhibit No. 1: Copy of the Delaware State

Implementation Plan for attainment of the PM2.5 National

Ambient Air Quality Standard — Attainment Demonstration;

Exhibit No. 2: Copy of the Delaware StateImplementation Plan for attainment of the PM2.5 National

Ambient Air Quality Standard — 2002 Base Year SIP

Emissions Inventory for PM2.5 and precursors;

3
Delaware’s PM2.5 Attainment Demonstration SIP, and

Delaware’s 2002 base year PM2.5 SIP Inventory dated

February 1, 2008;

Exhibit No. 5: Copy of the News Journal Affidavit of the

notice of this public hearing published on January 27, 2008;

Exhibit No. 6: Copy of the Delaware State News Affidavitof the notice of this public hearing published on January 27,

2008;

Exhibit No. 7: Copy of the State of Delaware Public

Meeting Calendar notice of this public hearing for Delaware’s

PM2.5 Attainment Demonstration SIP, and Delaware’s 2002base year PM2.5 SIP inventory posted the week of January

28, 2008;

Exhibit No. 8: Copy of the News Journal Affidavit of

location change for this public hearing, published on

February 17, 2008; and

Exhibit No. 9: Copy of the Delaware State News Affidavit

of location change for this public hearing, published on

February 17, 2008.

4
Department read a statement summarizing the history behind

Delaware’s SIP process in an attempt to help those in attendance

understand better the subject matter and scope of the hearing that

evening. Following the reading of that statement, the opportunity

was given by the Department to go off the record, to give those in

attendance an opportunity to ask Department personnel present at

the hearing any questions they might have regarding air quality

matters and public concerns regarding the same which were

outside the scope of this hearing. Those in attendance did not

wish the hearing to go off the record, and so the Department

proceeded to submit the nine exhibits into the formal hearing

record as noted above.

For brevity’s sake, and for the Secretary’s understanding in

this matter, a transcript of that statement (which provides

extensive factual background information as to the history of the

development of Delaware’s SIP matters, as well as a specific

breakdown of exactly what the scope of this public hearing

concerned) is attached hereto as Attachment “A”, and is expressly

incorporated herein to this Hearing Officer’s report.

5
present at this hearing were numerous members of theDepartment, specifically, from the Department’s Air Quality

Management Section, all of whom offered detailed factual

responses to the public’s questions and concerns. It is true that

the scope of this hearing was very limited to the two SIP matters at

hand, to wit: (1) the SIP revision for Delaware’s proposed plan for

Attainment of the Fine Particle (PM2.5) NAAQS; and (2) revisions to

Delaware’s 2002 Base Year PM2.5 SIP Emission Inventory.

Nevertheless, due to the level of passion in the room with regard to

public concern over Delaware’s air quality matters, this Hearing

Officer allowed those in attendance to ask questions and offer

comments on the hearing record, even though most of the verbal

comments offered were outside the narrow scope of this hearing.

Subsequent to the conclusion of this hearing, Department

staff took great pains to scrutinize each and every question and/or

comment raised at the hearing, and provided this Hearing Officer

with a very detailed and thorough Response Document concerning

the same. AQM’s Response Document encompasses the full range of

all comments contained in the record, including those from the

6
issues should be resolved. In most instances, no changes were

warranted, in AQM’s view, but in a few other situations involving

EPA comments received by the Department, minor amendments

were desirable to reflect existing realities or to clarify wording. None

of these changes were deemed substantial, or -sufficient to require

another hearing.

After reviewing AQM’s Response Document, it is my view that

the Department has done an excellent job of identifying all of the

relevant issues and discussing them in a thorough and balanced

manner which accurately reflects the information in the record.

Therefore, the Secretary may get an in-depth understanding of this

record by reading AQM’s Response Document, which is attached

hereto as Attachment “B” and expressly incorporated into this

report. Lastly, attached hereto as Attachment “C” is the final SIP

revision document, reflecting the minor amendments made by the

Department as a result of EPA’s comments on the same, which is

also being expressly incorporated into this report at this time.

7
Department’s proposed SIP revisions which were the subject of the public

hearing held on March 4, 2008. I further find that AQM has provided a

sound basis for the proposed revisions to the State Implementation Plan

(SIP) with respect to the two SIP matters at hand, to wit: (1) the SIP

revision for Delaware’s proposed plan for Attainment of the Fine Particle

(PM2.5) NAAQS; and (2) revisions to Delaware’s 2002 Base Year PM2.5 SIP

Emission Inventory.

As noted earlier, the Response Document not only captures the

relevant aspects of the record generated in this matter, but also provides a

thorough discussion of the issues at hand, along with a recommended

resolution of each. This Hearing Officer found the dimensions of AQM’sResponse Document to be very rational and even-handed, and the

proposed resolutions to be reasonable and consistent with the record.Instead of repeating all of that information herein, I recommend that theDepartment’s proposed revisions to the State Implementation Plan be

made, and that the proposed amendments be promulgated in final form,

in accordance with the customary and established rule-makingprocedure required by law.

8
2. In April of 2005, the Environmental Protection Agency (EPA)

has designated 126 areas of the country as “non-attainment” under the

PM2.5 NAAQS. Among those non-attainment areas is the Philadelphia

Wilmington, PA-NJ-DE Non-Attainment Area (NAA). This NAA includes

New Castle County in Delaware, and federal law requires the NAA to attain

the NAAQS by April, 2010

3. In respbnse to the non-attainment designation, Delaware has

developed the SIP revision for Delaware’s proposed plan for Attainment of

the Fine Particle (PM2.5) NAAQS.

4. Adoption of the proposed revisions to the SIP revision for

Delaware’s proposed plan for Attainment of the Fine Particle (PM2.5)

NAAQS will (1) demonstrate that with all existing and proposed controls,

all of Delaware’s PM2.5 monitors will show attainment in 2009; (2)

demonstrate that the entire Philadelphia-Wilmington, PA-NJ-DEnonattainment area will attain the PM2.5 NAAQS in 2009; (3) establish

Delaware’s 2009 mobile source budgets for transportation conformity

determinations under Regulation No. 1132, Transportation Conformity;

and (4) treat emission reduction credits banked under Regulation No. 34,

Emissions Banking and Trading Program, as “emitted.”

9
formation of PM2.5,including sulfur dioxide, oxides of nitrogen, volatile

organic compounds, and ammonia. It will also serve as the primary sourceof data used in the projection of future year emissions.

6. The Response Document as provided by AQM provides a

through, accurate and balanced summary of the record, and has been

incorporated herein expressly for that purpose.

7. AQM’s recommended conclusions with respect to each issue

are well-reasoned and based on the record. As such, they are sufficient to

serve as specific findings for that purpose.

8. The proposed SIP revisions, as amended to reflect comments

in the record, should be issued in final form and adopted as theDepartment’s final action, and be published as a Notice in the Delaware

Register ofRegulations in the next available issue.

7’.

Lisa A. .Vt

Hearjng Officer

\ahear\SIP.Attain.PM2.5.NAAQS.and 02 Base Year PM2.5 SIP Emiss.Inv.08

10
ATTACHMENT “A”
• Department of Natural Resources and Environmental Control (DNREC)• State Implementation Plan (SIP)• Fine Particulate Matter (PM25)

• National Ambient Air Quality Standard (NAAQS).

On July 18, 1997 the Environmental Protection Agency established a health based fine

particulate matter, PM2.5,National Ambient Air Quality Standard, NAAQS, at 15.0micrograms per cubic meter, annual average. Then, effective April 5, 2005 the EPA

designated 126 areas of the country as “non-attainment” under this NAAQS. Amongthose non-attainment areas is the Philadelphia based non-attainment area. The

Philadelphia based non-attainment area includes New Castle County in Delaware, five

counties in southeastern Pennsylvania, and three counties in New Jersey. Kent and

Sussex County are not included in this area; only New Castle County. The federal clean

air act requires the area to attain compliance with the NAAQS by April, 2010.

Particle pollution, especially fine particles, contains microscopic solids or liquid droplets

that are so small that they can get deep into the lungs and cause serious health problems.

Numerous scientific studies have linked particle pollution exposure to a variety of

problems, including:

• Increased respiratory symptoms, such as irritation of the airways, coughing, or

difficulty breathing;

• Decreased lung function;• Aggravated asthma;• Development of chronic bronchitis;• Irregular heartbeat;• Non-fatal heart attacks and premature death in people with heart or lung disease.

People with heart or lung diseases, children and older adults are the most likely to be

affected by exposure to particle pollution. However, even healthy individuals mayexperience temporary symptoms from exposure to elevated levels of particle pollution.

In addition to these public health impacts, fine particles are the major cause of reducedvisibility in parts of the United States, including many national parks and wilderness

areas. Also, particles are transported over long distances by wind and then settle on theground or water. The effects of this settling include making lakes and streams acidic,changing the nutrient balance in coastal waters and large river basins, depleting the
The SIP is a complex, fluid document containing regulations, source-specific

requirements, and non-regulatory items such as plans and emission inventories.

Delaware’s initial SIP was approved by the EPA on May 31, 1972. Since this initial

approval, the Delaware SIP has been revised numerous times to address air quality nonattainment and maintenance issues. This was done by updating plans and inventories,

and adding new and revised regulatory control requirements. Delaware’s SIP is compiled

at 40 C.F.R. Part 52 Subpart I.

As indicted earlier, this SIP revision is to address the EPA non-nonattainment designation

of New Castle County. This SIP revision is due to the EPA in April 2008, and attainment

of the annual PM2.5NAAQS must be demonstrated by 2010.On March 30, 2007, the EPA finalized a PM2.5Implementation Rule which sets forth the

requirements that SIPs must meet to satisfy CAA requirements. The federal Rule is

prescriptive, and requires:

• An attainment demonstration (which includes associated air quality modeling),

• Adopted State regulations that are relied upon to reduce emissions of PM2.5and

PM2.5precursors, and

• A demonstration that the area will attain the standards as expeditiously as

practicable.

Tonight’s hearing is on two SIP documents that are proposed to be added to Delaware’s

SIP — an Attainment Demonstration for the Philadelphia based non-attainment area,

which includes New Castle County, Delaware, and Delaware’s 2002 base year inventory.

The first document that we are holding the hearing on tonight is Delaware’s PM25

Attainment Demonstration SIP for the Philadelphia based non-attainment area, which

demonstrates that all of the CAA and prescriptive federal Implementation Rule

requirements associated with the annual PM2.5 NAAQS have been met; and that New

Castle County and the rest of the Philadelphia based non-attainment area will attain

compliance with the annual PM2.5 NAAQS by 2010. As such, the SIP covers, and this

public hearing is to request comment on, the following topics:

1) Delaware’s 2002 base-year PM2,5 SIP inventory. The complete inventory

document is the second item that is being discussed tonight to be added to
3) CMAQ modeling and other analysis to estimate what 2009 PM2.5concentrations

will be in the Philadelphia based non-attainment area. This modeling analysisdemonstrates that with all existing and proposed controls, New Castle County andthe rest of the Philadelphia based non-attainment area PM2.5will attain the PM25

NAAQS in 2009;

4) Delaware’s 2009 mobile source budgets for transportation conformity

determinations under Regulation No. 1132, Transportation Conformity; and

5) NOx emission reduction credits banked under Regulation No. 34, Emissions

Banking and Trading Program, being treated as “emitted” to ensure that any

future use will not interfere with attainment of the PM25 NAAQS.

Note that this hearing is not on the topics such as the following:

• Comments dealing with the adequacy of Delaware’s monitoring network in Kent

and Sussex County, as these counties are not included in the EPA identified andestablished Philadelphia non-attainment area, which is the subject of this SIP.

• Comments dealing with cancer, as this SIP addresses compliance with the PM2.5

NAAQS in New Castle County and the Philadelphia based non-attainment area.

• Comments dealing with air pollutant emissions in Kent and Sussex County,

except to the extent that those emissions must be mitigated to ensure attainment of

the PM2.5 NAAQS in the Philadelphia non-attainment area, again, because the

purpose of the SIP is to demonstrate attainment of the EPA identified and

established Philadelphia based non-attainment area.

• Comments dealing with the adequacy of Delaware’s monitoring network in New

Castle County, to the extent that such monitoring is not adequate to identify non

attainment, as New Castle County is in its entirety has been designated by the

EPA as being in non-attainment relative to the PM2.5 NAAQS. However,

comments regarding whether or not any portion of the Philadelphia non

attainment area will attain the NAAQS by 2009 are the subject of this hearing.

The second document that we are holding the hearing on tonight is Delaware’s 2002 Base

Year PM2.5 SIP Emission Inventory SIP. This SIP revision provides a complete and
Sources.

ATTACHMENT “B”
attainment designation covered a Philadelphia based non-attainment area, which included

New Castle County, Delaware. This non-attainment area is fully described in the proposed

SIP (Department Exhibit 1) on pages 16 and 17.

The Department does not believe that all of the public comment received at the March 4,

2008 public hearing is germane to this SiP revision. Such areas are so noted in the AQMSresponses provided below. Note that despite this belief, AQMS does agree with many of thecomments that air pollution is a serious matter. While we may believe that some of theinformation presented in the public comment is not germane to this specific action we do not

necessarily disagree with the information presented, nor believe that the information is not

important. This response document is in no way intended to downplay or undermine theserious nature of the impact of PM2.5 air pollution, or air pollution in general, on public

health.

Commenter 1: Austin Exhibit #1 -Comments made by Mr. John Austin, representing

the Citizens for Clean Power (CCP).

Comment 1: Mr. Austin indicates that the Department did not conduct an Unmonitored

Area Analysis (UAA) or a Local Area Analysis (LAA), and that these analyses must be done.AOMS Response: The AQMS does not agree with Mr. Austin that the Department did notconduct an UAA. The AQMS agrees with Mr. Austin that the Department did not conduct aLAA, but disagrees that a LAA was necessary.

• UAA: The AQMS does not agree with Mr. Austin that the Department did not

conduct an UAA. The Department clearly presented an UAA on pages 86 through 90of the proposed SIP document.

The UAA covered the entire Philadelphia based non-attainment area relative to boththe annual and 24-hour PM2.5NAAQS, and even extended beyond the non-attainmentarea boundaries into Sussex County, Delaware. The analysis clearly indicted that allareas of the non-attainment area, and beyond, will attain (or remain in attainment) of

the PM2.5 NAAQS in 2010, with the highest concentrations in the covered domain

being on the order of 13.2 ug/m3 and 28.5 ug/m3 for annual and 24-hour PM2.5

NAAQS, respectively.

• LAA: The AQMS agrees with Mr. Austin that the Department did not conduct a

LAA in the proposed SIP. This analysis was not conducted because the conditionsthat trigger this type of analysis were not a result of the modeling.
to produce PM2.5concentrations consistent with attainment in 2010). Because of thisit is not necessary, or even possible, to conduct a LAA.

The AQMS recommends no changes to the proposed SIP based on this comment.

Comment 2: Mr. Austin presented an analysis where he compared the incidence of adverse

health effects associated with high PM2.5concentrations at a ZIP code level. Mr. Austin’s

analysis was based on historical health effect data for years 1992 through 2005. Mr. Austinindicated that a direct way in which to assess Delaware’s air monitoring network is to

examine Delaware’s monitoring network in relation to the occurrence of infant deaths, stroke,

heart disease, and heart attacks. After ranking the incidence of these diseases by ZIP code,

Mr. Austin hypothesized that areas with disease incidence above those in the ZIP code whichcontains Delaware’s Martin Luther King Boulevard (MLK) monitoring site are presumed to

be in more significant nonattainment for PM2.5than the air quality at the MLK site. Based on

this analysis Mr. Austin concluded that:

• PM2.5 concentrations at a number of areas in Delaware currently exceed the PM2.5

concentrations at Delaware’s PM2.5monitoring sites, and that these areas will continue to

remain in nonattainment despite the proposed SIP.

• Much of Sussex County is in non-attainment of the PM2.5 NAAQS, and in particular

much of Sussex downwind of the Indian River Power Plant.

• Additional PM2.5 monitoring sites are needed in Newport, Delaware City, Port Penn,

north of Dover Air Force Base, Frederica, Laurel, Long Neck and Ocean View, and

Lewes.

• The States highest priority should be to reduce emissions at the Invista facility, which are

needed for Sussex to attain compliance with the PM2.5NAAQS.

AQMS Response: It appears that this analysis presented by Mr. Austin was intended to be

an Unmonitored Area Analysis (UAA) (reference the lines I through 15 ofpage 22 of the

hearing transcript), which he conducted because he did not believe that the Department itself

had conducted an UAA.

First, the Department did conduct an UAA in its proposed SIP (see response to comment 1

above). Second, AQMS has reviewed Mr. Austin’s UAA and has reached the followingconclusions.

• Mr. Austin indicates that he believes that the Department must revise its proposed SIP

based on his analysis. The proposed SIP that Mr. Austin is referring to (i.e., the SIP
more than 74,541 tons per year of PM2.5and PM2.5precursor emission reductions that the

SIP projects will occur between 2002 and 2009. These emission reductions are verysignificant, as they represent a sixty-one (61) percent reduction from 2002 levels that will

occur as a result of enforceable state and federal control measures. As explained in the

proposed SIP, these emission reductions are central to the Department’s conclusion that

attainment will be realized in 2010, and the Department does not believe that it is possible

to predict 2010 PM2.5 concentrations without considering these significant emissions

reductions.

• Mr. Austin concludes that unmonitored areas in New Castle County, Delaware have

historically, and currently, exceed the PM2.5 NAAQS. The Department agrees with thisconclusion because New Castle County, in its entirety, has been designated by the EPA as

being in non-attainment relative to the PM2.5NAAQS. Note that while AQMS does agreewith Mr. Austin’s conclusion that unmonitored areas in New Castle County, Delaware

may have, or currently do exceed the PM2.5NAAQS, we do not necessarily agree with themethodology used by Mr. Austin to reach this conclusion. Areas are designated pursuantto EPA requirements that are based on census data and EPA approved ambientmonitoring networks. Mr. Austin’s methodology of directly relating health effects, such

as stroke and infant mortality, to the PM2.5status of an area relative to a federal ambientair quality standard is, to the AQMS’s knowledge, not a peer reviewed scientificapproach.

AQMS understands that the PM2.5concentrations in an area contribute to adverse health

effects, but looking at it the opposite way, as Mr. Austin is (i.e., concluding that a higher

occurrence of adverse health effects in one area compared to another means that PM2.5concentrations in that area are higher than the other) is not intuitive. The health impacts

noted by Mr. Austin have numerous causes, and the hypothesis that the entire deviation inhealth impact occurrence from one area to another is due to PM2.5concentrations does not

seem valid.

However, despite the above, significant reductions in PM5 and PM2.5 precursor

emissions are projected to be achieved by 2010 based on enforceable federal and State

emission control measures, and based on the Departments modeling analysis, which

includes an UAA, the entire Philadelphia based non-attainment area, which includes New

Castle County, Delaware is projected to attain compliance with the NAAQS by 2010.

• Mr. Austin also concluded from his analysis that areas of Kent and Sussex County,

Delaware are not in compliance with the PM25 NAAQS. These comments are not relatedto this public record, as this public record deals with a proposed attainment demonstration

SIP on the Philadelphia based non-attainment area, which does not include either Kent orSussex County; and in addition this public record does not deal with area designations.
• Regarding Mr. Austin’s recommendation that additional air monitors should be placed in

specified areas throughout the state, these comments are not germane to this public

record, as this public record deals with a proposed attainment demonstration SIP on the

Philadelphia based non-attainment area, and not on Delaware’s air monitoring networkdesign. Mr. Austin’s comments have been forwarded to the AQM Air Surveillance

Branch for consideration in the next monitoring plan update.

• The AQMS does not agree with Mr. Austin’s recommendation that it must reduce

emissions at the Invista facility in order for Sussex County to attain compliance with the

PM2.5NAAQS. First, emission reductions from the Invista facility are not demonstratedas being needed for any part of the Philadelphia based non-attainment area to attaincompliance with the PM2.5NAAQS by 2010, and because of this AQMS does not believe

that this comment is germane to this public record (i.e., this public record deals with a

proposed attainment demonstration SIP on the Philadelphia based non-attainment area).

However, while outside of this public record, the AQMS notes that it is currently workingto reduce Invista emissions by 2009 under actions not related to this proposed SIP.

The AQMS recommends no changes to the proposed SIP based on this comment.Comment 3: Mr. Austin believes that more sophisticated particulate speciation analysis

needs to be performed in the areas of high cancer incidence, specifically the Valero Refinery

and the Indian River Power Plant to assess the carcinogenicity of particulate matter in theseareas.

AQMS Response: AQMS does not believe that this comment is germane to this publicrecord, as this public record deals with a proposed SIP document on attainment of the PM2.5NAAQS in the Philadelphia based non-attainment area, and not on monitoring to identify the

carcinogenicity of speciated particulate matter. However, the AQMS notes that it is currentlyinvolved in several state-wide cancer related initiatives, to include the Delaware Air Toxics

Assessment Study, and initiatives associated with the Delaware Cancer Consortium. Also, theAQMS developed a strategic planning process and continues to undertake activities to reducegaseous and particulate carcinogens and other air toxics emissions from both mobile and

stationary sources. In addition, Delaware does conduct limited monitoring of PM2.5

constituents or species in compliance with federal guidelines at its MLK and Dover sites.Research into the identification of carcinogenic PM2.5species is not a primary function of the

monitoring network and is not funded by EPA at this time.The AQMS recommends no changes to the proposed SIP based on this comment.

Comment 4: Mr. Austin believes that specific EPA monitoring requirements are not met.

He indicates that network design criteria require at least one monitoring station to be sited in
• Delaware’s original PM2.5monitoring 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 OAQPS document “Guidance for Network Design and

Optimum Site Exposure for PM2.5 and PM10” (U.S. EPA 1997a). Final network

documents were submitted to EPA Region 3 in June 1998, and EPA approved Delaware’s

PM2.5monitoring network.

• Annual Ambient Air Monitoring Network Reviews, including PM25, 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 103 Grant Requirements, Delaware submits annual Data

Quality Assessments for PM2.5speciation data and PM2.5FRM data to EPA Region 3. Alldata comply 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 103 Grant Requirements, Delaware also submits annual PM2.5

Speciation Monitoring Network Review and Monitoring Strategy reports to EPA Region3. The PM2.5speciation network design and monitor siting follows EPA requirements

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 PM2.5and PM10”(U.S.

EPA 1997a), “Particulate Matter (PM2.5)Speciation Guidance” (U.S. EPA 1999), and

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

Mr. Austin’s comments have been forwarded to the AQM Air Surveillance Branch forconsideration in the next monitoring plan update. In addition to the above, the AQMS notes

that its Air Surveillance Branch is currently conducting a special PM2.5monitoring study nearthe Indian River Power Plant to verify that PM2.5concentrations measured at the Seaford site

are representative of those in the Milisboro area.

The AQMS recommends no changes to the proposed SIP based on this comment.

Comment 5: Mr. Austin notes that it is Delaware’s obligation to insure that each of its

citizens has clean air to breathe, and that Delaware remains obligated to assure all Delaware

is in attainment of the NAAQS.

AQMS Response: The AQMS fully concurs with this comment, as this is a main reasonwhy it has developed this proposed SIP. The proposed SIP documents the significant

emission reductions that will occur throughout the State of Delaware, and projects that all

New Castle County and all areas of the Philadelphia based non-attainment area, bothmonitored and unmonitored, will attain the NAAQS in 2010.
Commenter 2: Comments made by Nancy Feichtl. Ms. Feichtl presents personalexperiences whereby she and others have experienced negative health effects. These include

personal and family experience with cancer, asthma, pacemaker and strokes. In addition, Ms.Feichtl cites increasing rates of respiratory diseases in the Cape Henlopen School District

since the 1 980s, which she attributed to ambient particulate matter concentrations. Ms.

Feichtl presented a cost analysis of the amount of money spent to help educate children withdisabilities, particularly severe disabilities such as autism, and her analysis indicated that $79

million a year could be saved if we just cleaned up our air. VAQMS Response: AQMS agrees that there are negative health effects associated withPM2.5non-attainment. Public health is the main reason why the Department developed thisproposed SIP. The proposed SIP documents the reduction of 74,541 tons per year of PM2.5

and PM2.5 precursor emissions by 2010, which corresponds to a sixty-one (61) percent

reduction from 2002 emission levels that will occur throughout the State of Delaware. Based

on these significant reductions, and the enforceable reductions from other areas in the

modeling domain, the proposed SIP projects that all New Castle County and all areas of thePhiladelphia based non-attainment area, both monitored and unmonitored, will attaincompliance with the NAAQS in 2010.

Although this public record does not deal with areas outside of the Philadelphia based nonattainment area, all areas of Delaware will benefit from the emission reductions upon whichthe proposed SIP is based. In addition, the AQMS notes that it is currently involved in

several cancer related initiatives, to include the Delaware Air Toxics Assessment Study, andinitiatives associated with the Delaware Cancer Consortium, and a special PM2.5monitoringstudy around the Indian River Power Plant to verify that PM2.5concentrations measured at theSeaford site are representative of those in the Millsboro area. Also, the AQMS developed a

strategic planning process and continues to undertake activities to reduce gaseous and

particulate carcinogens and other air toxics emissions from both mobile and stationary

sources.

The AQMS recommends no changes to the proposed SIP based on this comment.

Commenter 3: Comments made by Isabel Benson. Ms. Benson discussed the State of

Delaware’s high health care costs associated with cancer patient care, and indicated that it

would be cost effective for the State to invest in additional monitor(s) to help determine howmuch of an impact air quality is having on the quantity of cancer cases in the State.AQMS Response: Ms. Benson’s recommendations are not germane to this public record, asthis public record deals with a proposed attainment demonstration SIP for the Philadelphiabased non-attainment area, and not on Delaware’s air monitoring network design. However,Ms. Benson’s comments have been forwarded to the AQM Air Surveillance Branch for
Commenter 4: Comments made by Neil Kubala. Mr. Kubala is a cancer survivor and the

Radiology manager of Beebe Medical Center. Mr. Kubala stated that every week he sees

patients with cancer problems, and indicated that we must do something to stop cancer.

AOMS Response: AQMS agrees that cancer is a terrible disease. This public record dealswith a proposed attainment demonstration SIP on the Philadelphia based PM2.5 nonattainment area. While not part of this public record, the AQMS notes that it is currently

involved in several cancer related initiatives, to include the Delaware Air Toxics Assessment

Study, and initiatives associated with the Delaware Cancer Consortium. Also, the AQMS

developed a strategic planning process and continues to undertake activities to reducegaseous and particulate carcinogens and other air toxics emissions. from both mobile andstationary sources.

The AQMS recommends no changes to the proposed SIP based on this comment.Commenter 5: Comments made by Cherrie Rich. Ms. Rich has been the Director of the

Tunnel Cancer Center for the past eight years. Ms. Rich indicted that she has seen the

number of cancer cases increase significantly over the past eight years. Ms. Rich indicated

that although current treatments are very good we need better strategies for addressing

prevention. Ms. Rich recommended that AQMS install air monitors in areas with cancer

clusters to help in developing those strategies.

AQMS Response: Ms. Rich’s recommendations that additional air monitors be installed

as part of an overall strategy to reduce cancer are not related to this public record, as this

public record deals with a proposed attainment demonstration SIP for the Philadelphia based

non-attainment area, and not on Delaware’s air monitoring network design. However, Ms.Benson’s comments have been forwarded to the AQM Air Surveillance Branch for

consideration in the next monitoring plan update.The AQMS recommends no changes to the proposed SIP based on this comment.

Commenter 6: Prescott Exhibits. Comments made by James Prescott. Mr. Prescott

referenced an editorial written by Dr. Donald Kennedy. Mr. Prescott indicates that this

editorial concludes that the U.S. regulatory system for toxic industrial chemicals is noteffective and is a threat to public health, and Mr. Prescott indicated that he believes this

conclusion applies to the State of Delaware.

Mr. Prescott also discussed an article that discussed how the periods of embryonic, fetal and

infant development are very susceptible to toxic exposures. He indicted that the article

concluded that 1) the mother’s chemical body burden will be shared with her fetus, and thechild may be exposed to larger doses relative to body weight, 2) that susceptibility to a wide
Edgemoor Power Plants. Report consequences of toxic emissions by zip code for

health complications and deaths per below;

• Support legislative efforts to require the Division of Public Health to report infant

mortality rates, infant mortality rates, fetal and perinatal mortality rates; childmortality rates; infant and child hospitalizations; e.g. respiratory impairments; cancer

deaths and other health fatalities by zip code.

AOMS Response: AQMS fully agrees that toxic chemicals are bad for the environment and

public health, and that negative health impacts as a result of exposure may be realized

throughout one’s life. To this end DNREC has introduced and implemented many control

measures to reduce public exposure to air emissions. In fact, the reason for this SIP is to

analyze the many emission control measures that have reduced PM2.5and PM2.5prccursoremission, and to assess their impact on the New Castle County PM2.5 non-attainment

problem. Further, AQMS is currently involved in several cancer related initiatives, to

include the Delaware Air Toxics Assessment Study, and initiatives associated with the

Delaware Cancer Consortium, which include looking into the sources of and magnitude of

toxic chemicals from toxic emitters. Also, the AQMS developed a strategic planning process

and continues to undertake activities to reduce gaseous and particulate carcinogens and other

air toxics emissions from both mobile and stationary sources.

However, AQMS does not believe that Mr. Prescott’s recommendations that air monitors be

installed to measure toxic air pollutants by Indian River and Edgemoor Power Plants, or itssupport for future legislation are germane to this public record. This public record deals witha proposed attainment demonstration SIP of PM2.5on the Philadelphia based non-attainment

area, and is not on Delaware’s air monitoring network design. However, Mr. Prescott’s

comments have been forwarded to the AQM Air Surveillance Branch for consideration in the

next monitoring plan update.

The AQMS recommends no changes to the proposed SIP based on this comment.

Commenter 7: Gearity Exhibits. Comments made by Pat Gearity representing theCitizens for Clean Power.Comment 1: Ms. Gearity introduced into the public record a personal letter from Sylvia

Davis Pinkett, with the subject line: “Pollution ofthe Air and Water Surrounding the Indian

River Power Plant in Sussex County, DE.” The letter talks about how the air and water

quality in the Indian River area have deteriorated since the 1940’s, and lists many people thatshe recalls from the Indian River area as having died from, or survived cancer. Ms. Sylvia

Davis Pinketts’ letter indicated that her greatest concern now is pollution of the air by theIndian River Power plant.
The AQMS recommends no changes to the proposed SIP based on this comment.

Comment 2: As a result of seeing Mr. Austin’s data and attending public hearings Ms.

Gearity besieges the Department to do something about the air quality in the state. Ms.

Gearity indicated that she believes that areas around Wilmington, Delaware City and the areaaround Indian River merit emergency health measures to protect the people. Ms. Gearity

refers, to the impacts of pollution as expressed by other commenter’s at the March 4, 2008hearing, and asks the Department to bear in mind the deaths of infants and cancer patients as

we communicate with Public Health.AOMS Response: The purpose of this proposed SIP is to document the measures that arenecessary for New Castle County and the Philadelphia based PM2.5non-attainment area to

attain compliance with the PM2,5 NAAQS. The AQMS believes Section 7 of the proposedSIP documents some of the Departments efforts to clean the air in the state; as it lists twentynine (29) enforceable control measures since 2002 that will reduce statewide air pollution by74,541 tons per year of PM2.5and PM2.5precursor by 2009. This corresponds to a sixty-one(61) percent reduction from 2002 levels.

In addition, AQMS is currently involved in several cancer related initiatives, to include the

Delaware Air Toxics Assessment Study, and initiatives associated with the Delaware Cancer

Consortium, which include looking into the sources of and magnitude of toxic chemicals

from toxic emitters. Also, the AQMS developed a strategic planning process and continuesto undertake activities to reduce gaseous and particulate carcinogens and other air toxics

emissions from both mobile and stationary sources. And, many other regulatorydevelopment, permitting, compliance and enforcement activities are on-going separate from

the topic of this public record, to provide for clean air in the state.

The AQMS recommends no changes to the proposed SIP based on this comment.

Commenter 8: Furtado Exhibits. Comments made by Kim Furtado representing theCitizens for Clean Power.

Comment 1: Ms. Furtado indicated concern that the proposed SIP does not includeincreased air monitoring in Sussex County. Ms. Furtado noted that there are no speciation

monitors in Sussex, and no monitor near the largest point source polluter in Sussex. Ms.

Furtado recommended that the SIP be adjusted to expand the air monitoring network.

In support of this recommendation Ms. Furtado presented clinical body burden data and

information on clusters of cancer, infant death and heart disease near the Indian River Power

Plant. Ms. Furtado presented data which indicated heavy metal concentrations in individuals

that were above the reference range for a certain number of heavy metals that are combustion
The AQMS recommends no changes to the proposed SIP based on this comment.Comment 2: Ms. Furtad.o indicated that a properly designed multifactorial investigation of

the pollution burden in Sussex County is necessary. Ms. Furtado presented clinical body

burden data and information on clusters of cancer, infant death and heart disease to support

this recommendation. In addition, Ms. Furtado noted that gallium is a marker for coalcombustion, and that it could be included in our design, to aid in understanding what the

particulate matter is that is actually being affected onto the population.

In summary, Ms. Furtado indicated that bioburden data, compounded with ambient

monitoring data, to include speciation data, from multiple Sussex locations is an accurate,

scientific way to assess the particulate matter burden and public health risks.

AQMS Response: Regarding Ms. Furtado’s recommendation that the State undertake amultifactorial investigation of the pollution burden in Sussex County, these comments are not

related to this public record, as this public record deals with a proposed attainment

demonstration SIP on the Philadelphia based non-attainment area. Ms. Furtado indicated thatsimilar comments have already been made to the Department of Public Health, and AQMS

agrees that Public Health is the appropriate agency to address this issue.

The AQMS recommends no changes to the proposed SIP based on this comment.

Comment 3: Ms. Furtado indicated that the SIP is inadequate because it fails to recognize

the existence of a cancer cluster around the Indian River Power plant, and because it fails toaccount for the concern raised by disease clusters and presented body burden data. Sheindicated that particulate matter pollution impacts are well documented and deserve moreaction than are given in the proposed SIP.

AQMS Response: AQMS does not believe that these comments are germane to this publicrecord, as the public record deals with a proposed SIP document on attainment of the PM2.5NAAQS in the Philadelphia based non-attainment area, and not on the carcinogenicity of

speciated particulate matter. However, the AQMS notes that it is currently involved inseveral cancer related initiatives, to include the Delaware Air Toxics Assessment Study, and

initiatives associated with the Delaware Cancer Consortium, In addition, Delaware doesconduct limited monitoring of PM2.5 constituents or species in compliance with federalguidelines at two sites - MLK and Dover. Research into the identification of carcinogenic

PM2.5species is not a primary function of the monitoring network and is not funded by EPA

at this time.
Comment 4: Ms. Furtado indicated that she has considerable questions as to whether Sussex

County is in attainment. She indicated that she does not accept the computer modeling that

the SIP is based on.

AQMS Response: These comments are not related to this public record, as this public

record deals with a proposed attainment demonstration SIP on the Philadelphia based non

attainment area, which does not include either Kent or Sussex County; and in addition this

public record does not deal with area designations. While not related to this public record the

AQMS notes that area designations were completed by the EPA in 2005 based on approved

ambient monitoring networks and the procedures in 40 CFR Part 50, Appendix N, and the

monitoring data in Kent and Sussex County was at that time consistent with attainment of the

PM2.5NAAQS, and has remained at levels consistent with attainment since that time.The AQMS recommends no changes to the proposed SIP based on this comment.

Commenter 9: Comments made by Rose Quinto and Dennis Lohman, representing the

Region 3 Office (Philadelphia) of the U.S. Environmental Protection Agency (USEPA)

Comment 1: “The title for the SIP is misleading. The plan must be for attainment of the

PM2.5national ambient air quality standard (NAAQS), not just the annual standard. Thenonattainment designations were made for PM 2.5 and did not specify only the annual

standard. The PM Implementation Rule (72 FR 20600, April 25, 2007) explicitly refers todetermining attainment of the annual and 24-hour standards.”

AOMS Response: AQMS concurs with EPA, and the word “annual” will be removed from

the title.

Comment 2: The first sentence of the first paragraph of the Executive Summary incorrectly

states, “In April 2005 the Environmental Protection Agency (EPA) designated 126 areas ofthe country as “non-attainment” under the annual fine particle (PM2.5)National Ambient AirQuality Standard (NAAQS).” The areas were designated as nonattainment for PM2.5

NAAQS, not just the annual NAAQS.

AQMS Response: AQMS concurs with EPA, and the word “annual” will be removed from

the first sentence of the first paragraph of the Executive Summary title.

Comment 3: The 4th paragraph of the Executive Summary, 2’ bullet incorrectly states,“Demonstrates that the entire Philadelphia-Wilmington, PA-NJ-DE nonattainment area will

attain the annual PM2.5 NAAQS in 2009.” The areas were designated as nonattainment for

PM2.5NAAQS, not just the annual NAAQS.
AOMS Response: AQMS concurs with EPA, and the word “annual” will be removed from

the Section 1 statement: “New Castle County, Delaware was designated by the EPA as being

in non-attainmentfor this annual PM2.5NAAQS in April 2005.”

Comment 5: The concluding paragraph of section 1.1 is incomplete. The paragraph reads,

“This document demonstrates that all of the CAA and Rule requirements associated with the

annual PM2.5 NAAQS have been met; and that Delaware and the entire Philadelphia

Wilmington-DE-PA-NJ non-attainment area will attain compliance with the annual PM2.5

NAAQS as expeditiously as practicable, and not later than 2010. “ The document must, in

addition demonstrate that all of the CAA and Rule requirements associated with the 1997

PM2.5 NAAQS have been met; and that Delaware and the entire Philadelphia-Wilmington

DE-PA-NJ non-attainment area will attain compliance with the 1997 PM2.5 NAAQS as

expeditiously as practicable, and not later than 2010.

AOMS Response: AQMS concurs with EPA, and the word “annual” will be removed fromparagraph 1.1.

Comment 6: Section 1.5, paragraphs I and 3 are incomplete. The paragraphs read,

“Effective April 5, 2005 the EPA designated 47 areas, composed of 224 counties and theDistrict of Columbia as “nonattainment” under the PM2.5 annual NAAQS (70 FR 944,

January 5, 2005). ... “According to the CAA, the entire Philadelphia NAA must attain thePM2.5 annual NAAQS as expeditiously as practicable, and not later than 2010.” Thedocument must, in addition demonstrate that all of the CAA and Rule requirementsassociated with the 1997 PM25 NAAQS have been met; and that Delaware and the entire

Philadelphia-Wilmington-DE-PA-NJ non-attainment area will attain compliance with the

1997 PM2.5NAAQS as expeditiously as practicable, and not later than 2010.

AQMS Response: AQMS concurs with EPA, and the word “annual” will be removed

from Section 1.5, paragraphs 1 and 3.

Comment 7: The Attainment Demonstration as described in Section 6 satisfies EPA’s

requirements.

AQMS Response: AQMS agrees that Section 6 satisfies EPA’s requirements.

Comment 8: Has Regulation 1142, Section 2, Control of NOx Emissions from Industrial

Boilers and Process Heaters at petroleum Refineries, NOx emission control, New Castle

County been adopted by Delaware?
necessary to demonstrating attainment were exceeded, this SIP requirement was met.However, the AQMS does understand this EPA comment, and we have adjusted the languageaccordingly and listed the specific measures that satisfy this EPA request. Section 9 will be

updated by adding the following language:

Specific contingency measures are:

NOx Delaware Reg. 1146 Delaware estimates that 2009 statewide EGU NOx

emissions are 5,933 TPY less than the MANEVU 1PM calculations, owing toDelaware Reg. 1146. Therefore, to meet the 1,100 TPY NOx required forcontingency, we apportion 1,100 TPY for 2011 contingency measures from DelawareReg. 1146 and the remaining 4,833 TPY back into the model.

PM2.5 - Consent Decree with Premcor Refinery 2:Delaware gains additional

reductions in New Castle County beyond those modeled by MANEVU, of 234 TPY.This is partly due to the MANEVTJ 2009 projections over-estimating the 2009 PM2.5emissions from Coker Off-Gas at the Premcor Refinery by 223 TPY. The Unit iscovered under a Consent Decree with Premcor Refinery, Delaware City (formerly

Motiva Enterprises) New Castle County, Control of SO2, and NO Emission fromBoilers and Heaters. Therefore, to meet the 26 TPY PM2.5required for contingency,

from the Coker Off-Gas over-estimates, we apportion 26 TPY for 2011 contingency

measures and the remaining 197 back into the model.

“...will specifically implement 2011 SO2contingency measures as follows:S02 - Delaware Reg. 1146: Delaware estimates that statewide 2009 EGU SO2

emissions are 18,476 TPY less than the MANEVU 1PM calculations, owing toDelaware Reg. 1 146. Therefore, to meet the 5,463 TPY SO2required for contingency,

we apportion 5,463 TPY for 2011 contingency measures from Regulation 1146, and

the remaining 13,013 back into the model.

This is a non-substantive change, as it is consistent with information that was already in the

proposed SIP document.

Regulations Governing the Control ofAir Pollution No. 1146 Electric Generating Unit (EGU) Multi-Pollutant

Regulation, Delaware Department of Natural Resources and Environmental Control, Dover, Delaware, Effective

12/11/06.

2 Consent Decree with Premcor Refinery at Delaware City (formerly Motiva Enterprises), New Castle County,

Control of NOx Emission from Boilers and Heaters, Effective 2008
CERTIFICATION

April 2, 2008

I hereby certify that a public hearing was held March 4, 2008, on a proposed revision to the Stateof Delaware State Implementation Plan (SIP) for the Attainment of the Fine Particle (PM2.5)

National Ambient Air Quality Standard (NAAQS). This revision is in response to EPA’s April,

2005 non-attainment designation for the Philadelphia-Wilmington, PA-NJ-DE Metropolitan

Statistical Area, which includes New Castle County, Delaware, under the PM25 NAAQS. The

effective date of this revision is April 1, 2008.Delaware’s proposed SIP for Attainment ofthe PM2.5National Ambient Air Quality Standard willdo the following: 1) Demonstrate that with all existing and proposed controls, all of Delaware’s

PM2.5monitors will show attainment by 2010; 2) Demonstrate that the entire PhiladelphiaWilmington, PA-NJ-DE nonattainment area will attain the PM2.5NAAQS in 2009; 3) EstablishDelaware’s 2009 mobile source budgets for transportation conformity determinations underRegulation No. 1132, Transportation Conformity; and 4) Treat emission reduction credits banked

under Regulation No. 34, Emissions Banking and Trading Program, as “emitted.”

I further certify that the hearing was held in accordance with the notice required by Subsection

51.102 of 40 CFR 51.

Au Mirzakhäfili, P.E.

AdministratorAir Quality ManagementDivision of Air and Waste Management

PRINTED ON

Ve€a44e RECYCLED PAPER J taae Deftetd4 o oa1
State of Delaware:

ss.

Counties of Kent:

Before me, a Notary Public, for the County and State aforesaid, Wanda Ford-Waring, known to me to be such, who being sworn according to law deposes and says that she is

an officer of Independent Newspaper mc, the Publisher of the The Delaware State

News, a daily newspaper published at Dover, County of Kent, and State of Delaware, and that the notice, a copy of which is ereto attached, as ublished in the The Delaware

State News in its issue of (7

Sworn to and subscribed before me this /7

Day A.D.
State of Delaware:

:ss.

Counties of Kent:

Before me, a Notary Public, for the County and State aforesaid, Wanda Fond-Waring, known to me to be such, who being sworn according to law deposes and says that she is

an officer of Independent Newspaper mc, the Publisher of the The Delaware State

News, a daily newspaper published at Dover, County of Kent, and State of Delaware, and

that the notice, a copy of wli is hereto attached, as published in the The Delaware State News in its issue

Sworn to and subscribe efore me this

Day of VYUA WUrI A.D. fi(Jo

Independent News]

c7f

U a
The Department of Natural Resources and Environmental Control (DNREC), Air Quality Manage

n,ent Section will conduct a public hearing on proposed revisions to the State Implementation

Plan (SIP) for the Attainment of the Annual Fine Particle (PM2.5) National Ambient Air Quality

Standard (NAAQS).

In April 2005 the Environmental Protection Agency (EPA) designated 126 areas of the country as

non-attainment under the annual PM2.5NAAQS. Among those non-attainment areas is the

Philadelphia-Wilmington, PA-NJ-DE Non-Attainment Area (NAA). This NM includes New Casde

County in Delaware, and federal law requires the NAA to attain the NAAQS by April, 2010. In re

sponse to the non-attainment designation Delaware has developed this SIP revision.

* Delaware’s proposed SIP for Attainment of the Annual PM2.5 National Ambient Air

f1uality Standard

The purpose of this SIP is to: 1) Demonstrate that with all exisfing and proposed controls, all of

Delaware’s PM2.5 monitors will show attainment in 2009; 2) Demonstrate that the entire Phila

delphia-Wilmington, PA-NJ-DE nonattainment area will attain the annual PM2 5 NAAQS in 2009;

3) Establish Delaware’s 2009 mobile source budgets for transportahon conformity determina

tions under Regulabon No. 1132, Transportation Conformity; and 4) Treat emission reduction

credds banked under Regulation No. 34, Emissions Banking and Trading Program, as ernitted.

* Delaware’s 2002 Base Year PM2.5 SIP Emission Inventory

This SIP revision will provide a complete and accurate calendar year 2002 Base Year Emissions

Inventory for all Delaware counties of PM2,5 emissions and emissions of precursor pollutants

that contribute to the formaUon of PM2.5, including sulfur dioxide, oxides of nitrogen, volatile

organic compounds, and ammonia, And, it will serve as the primary source of data used in the

pro(ection of future year emissions. : -.

The public hearing will be held Tusday, March 4,2008, beginning at 6:00 p.m. in the DNREC

Auditorium, 89 Kings Highway, Dover, DE 19901.

The proposed amendment may be inspected atthe Department’s offices located at 156 S. State

Street, Dover and 715 Grantham Lane, New Castle or viewed on the Departments web site at

htto:/!www.awm.delaware.aov/lnfo/RegslAQMPlansReos.htm. For additional information on

the PM2.5 Attainment Sl please contact Jack Sipple, and the 2002 Base Year Emissions In

ventory, Dave Fees, in Dover at (302) 739-9402.

Statements and testimony may be presented either orally or in writing at the public hearing. Inter

ested parties may submit comments in writing to: DNREC Air Quality Management Section, 156

South State Street, Dover, Delaware 19901. .: ,-. . ,.,.

ONREC - Air Quality Management Section . ..-. :

156 South State Street

Dover, DE 19901

THIS IS THE fflY TIME THIS NOTICE WILL APPEAR.

258471 DSN 1/27/08
The News Journal

AFFIDAVIT OF PUBLICATION

STATE OF DELAWARE COUNTY OF NEW CASTLE

Personally appeared before me this 28 day of January, 2008:I, Kristin Segner, of the NEWS JOURNAL COMPANY, a daily newspaper printed and

published in the County of New Castle County, State of Delaware, who, being duly sworn states

that the advertisement of S/D DNREC Air Resource — Legal Notice — Public Hearing

was published in THE NEWS JOURNAL on N/A

and/or THE SUNDAY NEWS JOURNAL on January 27, 2008

Legal Coordinator

Name Title

Sworn to before me this 28th day of January, 2008

dtarub1ic
tederal law requires the NAA to attain the NAAQS by

April, 2010. In response to the non-attainment designa

tion Delaware has developed this SIP revision.

Delaware’s proposed SIP for Attainment of the An

nual PM National Ambient Air QualIty StandardThe purpose of this SIP is to: 1) Demonstrate that with

alt esisting and proposed controls, all of Delaware’s

PM , monitors will show attainment in 2009; 2) Dem onsrate that the entire Philadelphia-Wilmington, PANJ-BE nonattainmeni area wilt attain the annual PMNAAQS in 2009; 3) Establish Delaware’s 2009 mobi(e

source budgets for transportation conformity deter

minations under Regulation No. 1132, Transportation

Conformity; and 4) Treat emission reduction credits

banked under Regulation No. 34, Emissions Bankingand Trading Program, nittedY

Delaware s 2002 Base Year PM SIP Emission tnventory

This SIP revisionwill provide a complete and accurate

calendar year 2002 Ease Year Emissions Inventory forall Delaware counties of PM emissions and emissionsof precursor pollutants that bontribute to the lormation

of PM2,, including sulfur dioxide, oxides of nitrogeri

volatile organic compounds, and ammonia. And, it wilt

sense as the primary source oldata used in the projec

tion of future year emissions. ‘;Z iiN. -. -:‘. -

The pubic hearing will be held Tuesday, March 4, 2008,

beginning at 6.00 p.m. in the DNREC Auditorium, 89Kings Highway, Dover, DE 19901. . -

The proposed amendment thay inaeted at the Department’s offices located at(56:S. State Sireet, Dover

and 715 Qrantham Lane, New Castle, or,’4ewed on the

Department’s web site at http://wwwathm.delaware.

ooe/lnto/RegslAQMPlansReos.htm. For additional in

tormation on the PM Anainment SIP, please contact

Jack Sipple, and the lb02 Base Year Emissions Inventory, Dave Fees, in Dover at (302) 739-9402.

Statements nd testimony may’ be presented eilherorally or in writing at the public hearing. Interested par

ties may submit comments in writing to: DNREC Air

Quality Management Section, 156 South State Street,Dover, Delaware 19901. ‘ ‘:-•

0/27NJ ‘.*.

‘-

‘‘
The News Journal

AFFIDAVIT OF PUBLICATION

STATE OF DELAWARE COUNTY OF NEW CASTLE

Personally appeared before me this 18th day of February, 2008:

I, Kristin Segner, of the NEWS JOURNAL COMPANY, a daily newspaper printed and

published in the County of New Castle County, State of Delaware, who, being duly sworn states

that the advertisement of S/D DNREC Air Resource — Legal Notice — Location Change For

Public Hearingwas published in THE NEWS JOURNAL on N/A

andlor THE SUNDAY NEWS JOURNAL on February 17, 2008

1j1A4”t)t99’Zf Legal Coordinator Name Title

Sworn to before me this 18th day of February, 2008

DNREC - Air Quality :Mánagement Section..:. otaiy Uvilc

.LEGAL NOTICE

LOCATION CHANGE FOR PUBLIC HEARING

The Department of Natural Resources and Environ

mental Control (DNREC), Air Quality ManagementSections public hearing on propoaed revisions to theState Implementation Plan (SIP) for the Attainment ofthe Annual Fine Particle (PM2.5) National Ambient AirQuality Standard (NAAQS) and Delaware’s 2002 BaseYear M2.5 SIP Emission Inventory was scheduled to

be held Tuesday, March 4,2008, beginning at 6:00 p.m.in the DNREC Auditorium, 89 Kings Highway. Dover.

DE 19901. THE HEARING LOCATiON HAS BEEN

CHANGED TO AIR QUALITY MANAGEMENT’S OF

FICE AT 156 S. STATE STREET, DOVER.For further information contact Mr. Jack Sipple, in Do

ver at (302) 739 9402 /

Air Quality Management Section

156 South State Street

Dover DE 19901

2117-NJ (0-0110553428)