## Final Submittal

DELAWARE STATE IMPLEMENTATION PLAN

FOR ATTAINMENT OF TH E 8-HOUR OZONE NATIONAL AMBIENT AIR QUALITY STANDARD

Reasonable Further Progress and

Attainment Demonstration

Submitted To U.S. Environmental Protection agency

By

Delaware Department of Natural Resources and

Environmental Control



## June 2007ii [This page is intentionally left blank]iii Table of Contents

Executive Summary

---------------- ----------------- --------------------------------- ----------- v Acronym List

----------------- ----------------- --------------------------------------------- ------ vi

List of Tables ------------------------------------------------------------------------------------- viii List of Figures

---------------- ------------------------------------------------------------ -------- x List of Appendixes

------------------ ----------------- ------------------------------------ -------- xi

1. Introduction and Background

--------------- ----------------- ------------------ ----------- 1 1.1 Background and Requirements ---------------

------------------------------ ------------ 1 1.2 Responsibilities -----------

----------------- ------------------ ----------------- ------------ 4

2. Ozone Air Quality Status a nd Trend Analysis ------------------ ------------ ----------- 5 2.1 Delaware Ozone Monitoring Network

------------------------------ ----------- 5

2.2 Attainment of 1-Hour Ozone Standard

------------------ ----------------- ------------- 5 2.3 Delaware 8-hour Ozone Design Values --

----------------- --------------- ------------- 7

2.4 Ozone Exceedances at Delaware Monitors

-------------- ----------------- ------------ 7

2.5 Monitored Ambient Ozone Concentration Trends ---------------

------------ -------- 9 2.6 Meteorological Analysis -

---------------------------------- ----------------- ------------ 10 2.7 General Trend of Ambient Air Quality Re garding 8-Hour Ozone ---------------- 11

3. Delaware 2002 Base Year Emissi on Inventory

------------------- ------------- ---------13 3.1 Point Sources Inventory

------------------------------------------------ ----------- 13 3.2 Area Sources Inventory ---

--------------------------------------------- ------------17 3.3 Non-Road Mobile Sources Inventory ---

------------------ ----------------- ------------ 18 3.4 On-Road Mobile Sources Inventory ------

---------------- ------------------ ----------18

3.5 Delaware 2002 Base Year Emission Inve ntory Summary ------

------------ ------19

4. Emission Reduction Requirements for Attainment

------------------ -------------- 20 4.1 Adjustment of 2002 Base Year Emission Inventory ----------------- ---------------- 20

4.2 Emission Reductions for 2003-2008 ----------

------------------------------ ----------- 22

4.3 Emission Reductions for Attainment Y ear-----------------

------------------ ---------- 23

5. Control Measures and Emission Reductions for 2003-2008 RFP ------------------ 24

5.1 Point Source Control Measures and Reduc tion Estimates --------

------------- ----- 24

5.2 Area Source Control Measures and Reductio n Estimates ----------- ---------------- 27

5.3 Non-Road Mobile Sources Control Meas ures and Reduction Estimates ---------- 27

5.4 On-Road Mobile Source Control Measures and Reduction Estimat es ------------- 28

5.5 Total Reductions for RFP and Attainment Requirements --------

------------ ------- 29

6. Control Measures and Emission Reductions for Attainment ------------------------ 30 6.1 Point Source Projection Inventory --------

------------------ ----------------- ----------- 31 6.2 Stationary Area Source Projection Inventor y ----------------------

------------- ------ 41 6.3 Non-Road Mobile Source Projection Inventory ------------

------------------ --------- 51 6.4 On-Road Mobile Source Projection I nventory -------------

------------- ------- 54 6.5 Delaware 2009 Emission Projections for A ll Source Sectors ---- ------------------- 54

7. Attainment Demonstration Mode ling and Weight-of-Evidence Analysis ----------57 7.1. Background and Objectives

--------------------------------------------------- ---------- 57 7.2. Photochemical Modeling System ----------

----------------- --------------- -------------58iv 7.3. Ozone Episode Selection --

-- ------------- ----------------- ------------------ -------------59 7.4. Meteorological Fields -----

--------------------------------------------------- -------------60

7.5. Model Performance Evalua tion ------------------

------------------------------ ----------60

7.6. Emissions Inventories -----

------------------ ---------------------------------- ------------60 7.7. Conceptual Model ----------

------------------ ----------------- --------------- ------------ 61

7.8. Attainment Demonstration of the 8- hour ozone NAAQS --------

------------ ------- 61

7.9. Conclusions ------- -------------------------------------------------------------------------79

8. Reasonably Available Control Measure (RACM) Analysis --

--------------- --------- 82 8.1 RACM Analysis Requirement s---------------

----------------- --------------- ------------82

8.2 RACM Determination --------

------------------ ----------------- --------------- ----------- 82

9. Mobile Budgets for Transportation Conformity ----------------------------------------85 9.1 Introduction to Transportati on Conformity ---------------

----------------- ------------ 85 9.2 Mobile Budgets for 2008 and Attainment Y ear ------------

------------------ --------- 85

10. Contingency Measures

------------------ --------------------------------------------- --------87 10.1 Requirements on Contingency Measures -

----------------- ------------------ --------- 87 10.2 Contingency Measures for 2008 Milestone Year ----------------

------------- ------- 87 10.3 Contingency Measures for 2009 Attainment Year -------------

------------ ----------88

11. Appendixes

--------------------------------------------------------------------------- ----------90v Executive Summary

In April 2004, the Environmental Protec tion Agency (EPA) designated 126 areas of the country as “non-attain ment” under the 8-hour ozone National Ambient Air Quality Standard (NAAQS). Among those non-attainme nt areas is the Philadelphia-WilmingtonAtlantic City (PA-NJ-MD-DE) Moderate Non-Attainment Area (NAA). This NAA includes three counties in Delaware, five coun ties in eastern Pennsylvania, one county in Maryland and eight counties in southern New Je rsey. According to the federal Clean Air Act (CAA), this entire NAA must a ttain the 8-hour ozone NAAQS by 2010.

Ground level ozone, one of the principal co mponents of “smog,” is a serious air pollutant that harms human health and the envi ronment. High levels of ozone can damage the respiratory system and cause breathing problems, throat irritation, coughing, chest pains, and greater susceptibility to respirator y infection. High levels of ozone also cause serious damage to forests and agricultural cr ops, resulting in ec onomic losses to logging and farming operations.

This document contains Delaware’s Stat e Implementation Plan (SIP) revision for meeting the requirements associated with th e 8-hour ozone NAAQS. Specifically, this

SIP revision:

• Fulfills the federal Clean Air Act’s requirements for Reasonable Further Progress (RFP) and Attainment Demonstratio n (AD) under the 8-hour ozone NAAQS.

• Builds on, and strengthens control measures that were adopted and implemented under the 1-hour ozone NAAQS, which also serve as maintenance measures for maintaining the attainment status of the 1-hour ozone NAAQS in Delaware.

• Demonstrates that with all existing and propos ed controls, Delaware will meet the RFP requirements on VOC and NOx emission reduc tions in 2008, and AD requirements on

VOC and NOx emission reductions in 2009. In particular, all Delaware’s ozone

monitors will show attainment in 2009.

• Demonstrates that the entire Philadelphia-Wilmington-Atlantic City, PA-NJ-DE-MD

moderate non-attainment area will at tain the 8-hour ozone NAAQS in 2009.

• Confirms Delaware’s 2008 and 2009 mobile source budgets fo r transportation conformity determination.

• Treats emission reduction cr edits (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 pr ovision of this SIP.vi Acronym List

ACT - Alternative Control Techniques

ALAPCO - Association of Local Air Pollution Control Officials AQMS - Air Quality Management Section of DNREC BEA - Bureau of Economic Analysis BOTW - Beyond-on-the-way

CAAA - Clean Air Act Amendments of 1990

CAIR - Clean Air Interstate Rule

CEM - Continuous Emission Monitor CMSA - Consolidated Metropolitan Statistical Area

CO - Carbon Monoxide CTG - Control Technology Guidance DelDOT - Delaware Depart ment of Transportation DNREC - Delaware Department of Na tural 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

ERC - Emission Reduction Credit FIP - Federal Implementation Plan FMVCP - Federal Motor Vehicle Control Program HPMS - Highway Performance Monitoring System I/M - Inspection and Maintenance Program IPM - Integrated Planning Model

LEV - Low Emission Vehicle MANE_VU - Mid-Atlantic and Northeast Visibility Union MARAMA - Mid-Atlantic Regiona l Air Management Association MPO - Metropolitan Planning Organization

mmBTU - Million British Thermal Unit

NAA - Non-Attainment Area NAAQS - National Ambient Air Quality Standard NACCA - National Association of Clean Air Agencies NEI - National Emission Inventory

NESCAUM - North-East Stats for Coordinated Air Use Management\

NIF - National emission inventory Input Format

NLEV - National Low Emission Vehicle NOx - Oxides of Nitrogen OTAG - Ozone Transport Assessment Group

OTB - On-the-book OTC - Ozone Transport Commission OTR - Ozone Transport Region OTW - On-the-way

PM - Particulate Matter POTW - Publicly Owned Treatment Works QA-QC - Quality Assurance-Quality Control RACM - Reasonably Ava ilable Control Measurevii RACT - Reasonably Ava ilable Control Technology RFP - Reasonable Further Progress RPO - Regional Planning Organization RRF - Relative Response Factor RVP - Reid Vapor Pressure

SCC - Source Classification Code

SIC - Standard Industrial Classification SIP - State Implementation Plan

STAPPA - State and Territorial Ai r Pollution Program Administrators TIP - Transportation Improvement Program TSD - Technical Supporting Document

VMT - Vehicle Miles Traveled VOC - Volatile Organic Compoundviii List of Tables

Table 2-1. Number of Days with Exceedance of 1-Hour Ozone Standard ------------------ 6 Table 2-2. The 1-Hour Ozone Design Values (ppm) of Delaware’s Counties --------------6 Table 2-3. The 1-Hour Ozone Design Values (ppm) of Maryland County in Philadelphia CMSA ----------- ---------------------------------------------------------6 Table 2-4. The 1-Hour Ozone Design Valu es (ppm) of New Je rsey Counties in Philadelphia CMSA ----------- ---------------------------------------------------------7 Table 2-5. The 1-Hour Ozone Design Valu es (ppm) of Pennsylvania Counties in Philadelphia CMSA ----------- ---------------------------------------------------------7 Table 2-6. Delaware 8-Hour Ozone Design Va lues by County ----------

------------- --------7 Table 2-7. Number of Days Exceedi ng 8-hour Ozone NAAQS at Individual

Monitors -----------

------------------------------------------------------------ -----------8 Table 2-8. The 8-hour Ozone Design Values for All Delaware Monitors from 1994 to

2006-----------------

------------------------------------------------------------ -----------9 Table 2-9. Delaware 8-Hour NAAQS Ozone Exceedances with Respect to Hot Summer Days------------------------------------------------------

------------------ --------------11

Table 3-1. Point Source Facilities in Dela ware 2002 Base Year Inve ntory ------- ----------14 Table 3-2. Non-Point Source Categories in Delaware 2002 Base Year Inventory ---------17

Table 3-3. Delaware 2002 Base Year VOC Emis sions in Tons per Da y ---------- ---------19

Table 3-4. Delaware 2002 Base Year NOx Emis sions in Tons per Da y ----------- ---------19 Table 4-1. Mobile Source FMVCP/RVP Adju stments for Sussex County -----------------21

Table 4-2. Mobile Source FMVCP/RVP Adjustments for Kent/New Castle

Counties --------------

---------------------------------- ---------------------------------21 Table 4-3. The 2002 Adjusted Baseline Invent ory for Sussex County

-------------- --------22 Table 4-4. The 2002 Adjusted Baseline Inventor y for Kent/New Castle Counties --------22

Table 5-1. Emission Reductions from Facilit ies Shutdown after 2002

------------ ----------25

Table 5-2. Emission Reduction Credits and Hold ing Facilities/Agency

------------ --------26

Table 6-1. Delaware 2009 VOC and NOx Em ission Projections (TPD) for Electric Generating Units (EGUs) --

---------------------------------------------- ------------ 33

Table 6-2. Delaware 2009 VOC Emission Projections (TPD) for Non-EGU Point

Sources Revised from MACTEC’s Projec tions ---------------

------------- -------35 Table 6-3. Table 6-3. Delaware 2009 NOx Emission Projections (TPD) for

Non-EGU Point Sources Revised from MACTECs Projections --------------- 39

Table 6-4. Delaware 2009 VOC and NOx Emission Projections (TPD) for

Non-EGU Point Sources Not Revised from MACTEC’s Projections ----------41

Table 6-5. Delaware 2009 VOC and NOx Emission Projections (TPD) for

All Point Sources --------

------------------ ----------------- ---------------------------41

Table 6-6. Delaware 2009 VOC Emissi on Projections (TPD) for Non-Point Sources Revised from MACTECs Project ions ---------------

------------- ------43

Table 6-7. Delaware 2009 NOx Emissi on Projections (TPD) for Non-Point Sources Revised from MACTEC’s Projec tions ---------------

------------- ------49

Table 6-8. Delaware 2009 VOC and NOx Emission Projections (TPD) for

Non-Point Sources Not Revised from MA CTEC’s Projections -----------------51

Table 6-9. Delaware 2009 VOC and NOx Emission Projections (TPD) for

All Non-Point Sources -----

------------------------------------------------ -----------51

Table 6-10. Delaware 2009 Non-Road Mobile Source Emission Projection Summary ---------------

----------------- ------------------------------------------------53

Table 6-11. Delaware 2009 On-Road M obile Source Emission Projection Summary ---------------

----------------- ------------------------------------------------54ix Table 6-12. Delaware 2009 All-Source Emissi on Projection Summary

--------------- ------54 Table 7-1. Summary of Model Attainment Test Re sults ---------------- ----------------------62 Table 7-2. Guidelines for Supplemental Analyses and Weight of

Evidence Determinations --- ----------------------------------------------------------65 Table 7-3. Comparison of Modele d 2009 and Projected 2006 Ozone Design Values ---------------

------------------------------------------------ -----------66

Table 7-4. Alternative Baseline Concentration Analysis ---------------

--------------- --------70 Table 7-5. Alternative RRF Calculation Analys is ---------------

------------------ -------------71 Table 7-6. Alternative Projected 2009 Mode led Values Using Alternative RRFs ---------71

Table 7-7. Combined Affects of Altern ative Baseline Concentrations and

Alternative RRFs ------

----------------- ------------------ ----------------- ------------72 Table 7-8. Methodist Hill Statistics, Proxy fo r Regional Transport --- ----------------------72 Table 7-9. Modeled 2009 Ozone Design Values at Methodist Hill --- ----------------------73 Table 7-10. Recent 8-Hour Ozone Design Value Trends----------

------------------ ---------- 75 Table 7-11. Alternative Methods WOE Summary

------------- ------------------ --------------- 75 Table 7-12. Adjustments in DVF Due To Model Under-prediction of

NOx SIP Call Benefits -----

------------------------------------------------ -----------76 Table 7-13. Adjustments in DVF Due To Model Underprediction of Be nefits ------------ 76

Table 7-14. Potential Emission Reductions (tons/day) from Delaware-Specific

Measures Not Modeled ------ ---------------------------------------------------------77

Table 9-1. On-Road Mobile Source Emissi on Projections for 2008 --- ----------------------85

Table 9-2. On-Road Mobile Source Emissi on Projections for 2009 --- ----------------------86x List of Figures

Figure 1-1. Philadelphia-Wilmingt on-Atlantic City, PA-DE-MD-NJ

Moderate Non-Attainment Area for th e 8-Hour Ozone NAAQS -------------- 2 Figure 2-1. Delaware Ozone Monitoring Ne twork for 8-Hour Ozone NAAQS ----------- 5 Figure 2-2. Number of 8-hour Ozone Exceedance Days at Monitors

--------------- -------- 9 Figure 2-3. Ozone 8-hour Design Values for In dividual Monitors -----

------------ -------- 10

Figure 7-1. The 8-Hour Ozone CMAQ Mode ling Domains at 36-km and 12-km --------59 Figure 7-2: Predicted Ozone Design Values for Entire NAA

------------------ ------------- 64 Figure 7-3. The 8-Hour Ozone 2002-2006 Design Value Trends

---------------- ---------- 68 Figure 7-4. Long-term trends of ozone summer values in Kent County (1996-2006) ------------

----------------- ------------------------------------ --------- 68 Figure 7-5. Long-term trends of ozone summer values in New Castle County (1996-2006) ------------

----------------- ------------------------------------ --------- 69 Figure 7-6. Long-term trends of Ozone summer values in Sussex County (1996-2006) ------------

----------------- ------------------------------------ --------- 69 Figure 7-7. Density Plots of Log CM AQ Concentrations for 2002 Base and

2009 Cases -------------

----------------- ------------------------------------ ---------- 78 Figure 7-8. Frequency Distributio ns of 2002 Base and 2009 CMAQ Ozone Concentrations (log-log Plot) ---

--------------------------------- ---------- 79 Figure 8-1. Figure 8-1. Delaware Zero-O ut Modeling Results For Estimating

Contribution to Ozone Concentration ---

----------------- --------------- ---------- 83xi List of Appendixes

Appendix 4-1 Part 1: MOBILE6.2 Input and Output F iles for Delaware 2002, 2008 and 2009 Mobile Source Emission Adjustments

. Part 2: Calculations of the Adjusted 2002, 2008 and 2009 On-Road Mobile Source Emission Projections. Appendix 6-1 Development of Emission Projections for 2009, 2012, and 2018 for Non-EGU Point, Area, and Non-road Sources in the MANE-V U Region, Draft Final Technical Support

Document , Prepared for Mid-Atlantic Regi onal Air Management Association (MARAMA) by MACTEC Federal Programs, Inc., December 7, 2006. Appendix 6-2 The 2009 Emission Projections of Delawa re Non-EGU, Non-Point and Non-Road

Mobile Sources. Appendix 6-3 Part 1: MOBILE6.2 Input and Output Files for Delaware 2008 and 2009 Mobile Source Emission Projections

. Part 2: Calculations of 2008 and 2009 On -Road Mobile Source Emission Projections. Appendix 7-1 A Modeling Protocol for the OTC SIP Quality Modeling System for Assessment of the Ozone National Ambient Air Quality Standard in the Ozone Transport Region , The Modeling Committee of the Ozone Tr ansport Commission (OTC), OTC, 2000. Appendix 7-2 Technical Supporting Document 1d: Th e 8-hour Ozone Modeling Using the SMOKE/CMAQ System , Bureau of Air Quality Analysis and Research, Division of Air Resources, New York State De partment of Environmenta l Conservation, Albany, NY, February 2006. Appendix 7-3 Determination of Repres entativeness of 2002 Ozone Season for Ozone Transport Region SIP Modeling , Prepared for OTC, Prepared by Environ, June 2005. Appendix 7-4 Qualitative Episode Analysis of the 2002 Ozone Season, William F. Ryan, Department of Meteorology, Pennsylvania State Univers ity, and Charles Piety, Department of Atmospheric and Oceanic Science, University of Maryland, 2002. Appendix 7-5 Technical Supporting Document 1a: Meteorol ogical Modeling us ing Penn State/NCAR

5 th Generation Mesoscale Model (MMV) , Bureau of Air Quality Analysis and

Research Division of Air Re sources, New York State Department of Environmental Conservation Albany, NY, February 2006. Appendix 7-6 Technical Supporting Document 1e: CMAQ Model Performance and Assessment- 8- Hour Ozone Modeling , Bureau of Air Quality Analysis and Research, Division of Air Resources, New York State Department of Environment, Albany, NY, February 2006. Appendix 7-7 Technical Supporting Document 1b: Pr ocessing of Biogenic Emissions for OTC/MANE_VU Modeling , Bureau of Air Quality Analys is and Research, Division of Air Resources, New York State Department of Environment, Albany, NY, September

2006. Appendix 7-8xii Technical Supporting Document 1c: Emi ssion Processing for the Revised 2002 OTC Regional and Urban 12 km Base Case Simulations , Bureau of Air Quality Analysis and Research, Division of Air Resour ces, New York State Department of Environment, Albany, NY, September 2006. Appendix 7-9 Technical Supporting Document 1f: Future Year Emissions Inven tory for 8-Hr OTC Ozone Modeling , Bureau of Air Quality Analysis and Research, Division of Air Resources, New York State Department of Environment, Albany, NY, February 2007. Appendix 7-10 The Nature of the Ozone Air Quality Problem in the Ozone Transport Region: A Conceptual Description , NESCAUM, October 2006. Appendix 7-11 A Conceptual Model for Ozone Transport

, Prepared by Dr. Robert Hudson, Department of Atmospheric & Science, University of Maryland, January 2006. Appendix 7-12 A Guide to Mid-Atlantic Regional Air Quality

, Mid-Atlantic Regional Air Management Association (MARAMA), October 2005. Appendix 7-13 Technical Supporting Document aa: Trends in Measured 1-hour Ozone Concentrations over the OTR modeling domain

, Bureau of Air Quality Analysis and Research, Division of Air Resources, New Yo rk State Department of Environment, Albany, NY, September 2006. Appendix 8-1 CALGRID Zero Out Modeling Analysis, Mo hammed A. Majeed, Ph.D. and P.E., Air Quality Management Section, Delaware Department of natural Resources and Environmental Control, Dover, DE, May 2007 Appendix 9-1 Delaware State Implementation Plan for Attainment of the 8-Hour Ozone National Ambient Air Quality Standard, Revision for Establishment of 2008 and 2009 Mobile Source Emission Budgets , Delaware Department of Natural Resources and Environmental Control, Air Quality Mana gement Section, Dover, Delaware, May

2007. Appendix 10-1 Identification and Evaluation of Candidate Control Measures, Draft Final Technical Support Document , Prepared for Ozone Transport Commission (OTC), Prepared by MACTEC Federal Programs, Inc ., Herndon, Virginia, February 20071 1. Introduction and Background

This document contains Delaware’s Stat e Implementation Plan (SIP) revision for meeting the requirements of Reasonable Furthe r Progress (RFP) toward attainment of the 8-hour ozone National Ambient Air Quality Standard (NAAQS), which was set at 0.08 parts per million (ppm) by US Environmenta l Protection Agency (EPA) in 1997. The

document also demonstrates that Delawa re, and the entire Philadelphia-WilmingtonAtlantic City (i.e., PA-NJ-MD-DE) moderate non-attainment area will attain compliance with the 8-hour ozone standard by 2010. Th e document is hereafter referred to as

“Delaware’s 8-hour ozone SI P revision,” or simply as “the ozone SIP.”

1.1 Background and Requirements

Ground level ozone, one of the principal co mponents of “smog,” is a serious air pollutant that harms human health and the envi ronment. High levels of ozone can damage the respiratory system and cause breathing problems, throat irritation, coughing, chest pains, and greater susceptibility to respirator y infection. High levels of ozone also cause serious damage to forests and agricultural cr ops, resulting in ec onomic losses to logging and farming operations. In April 2004, EPA de signated 126 areas of th e country as “nonattainment” under the 8-hour ozone NAAQS ( 69 FR 23858 ). Among those nonattainment areas is the Philadelphia-Wilmington-Atlantic City (PA-NJ-MD-DE) Moderate Non-Attainment Area (NAA) that includes thre e counties in Delaware, five counties in eastern Pennsylvania, one count y in Maryland, and eight coun ties in southern New Jersey, as shown in Figure 1-1. Since this moderate NAA is centered by Philadelphia, it is often referred to as “Philadelphia NAA.” According to the CAAA, the entire Philadelphia NAA must attain the 8-hour ozone NAAQS by 2010, the attainment year.

Ozone is generally not directly emitted to th e atmosphere; rather it is formed in the atmosphere by photochemical reactions be tween volatile organic compounds (VOC), oxides of nitrogen (NO X ), and carbon monoxide (CO) in the presence of sunlight. Consequently, in order to reduce ozone concen trations in the ambient air, the Clean Air Act Amendments of 1990 (CAAA) requires all non-attainment areas to apply controls on

VOC and NO X emission sources to achieve emission reductions. 1

Among effective control measures, the R easonably Available Control Technology (RACT) controls are a majo r group for reducing VOC and NO X emissions from stationary

sources. Section 182 of the CAAA sets fort h two separate RACT requirements for ozone non-attainment areas. The first requirement, contained in section 182(a)(2)(A) of the CAAA, and referred to as RACT fix-up, requires the correcti on of RACT rules for which

EPA identified deficiencies before the Act was amended in 1990. The second requirement, set forth in section 182(b)(2) of the CAAA, applies to moderate or worse ozone non-attainment areas as well as to margin al and attainment areas in ozone transport regions (OTRs) established pursuant to s ection 184 of the CAAA, and requires these nonattainment areas to implement RACT cont rols on all major stationary VOC and NO X emission sources and on all sources and sour ce categories covered by Control Technique Guidelines (CTGs) or Alternate Control Techniques (ACTs) issued by EPA.

1 Since CO’s role in forming ozone is relatively insignificant, the CAAA does not specify requirements on CO emission reductions regarding attainment of the ozone standard.2 Figure 1-1. Philadelphia-Wilmingt on-Atlantic City, PA-DE-MD-NJ Moderate Non-Attainment Area for the 8-Hour Ozone NAAQS

Under the 8-hour ozone NAAQS, the entire state of Delaware (i.e., all three counties) is a part of the Philadelphia moderate NAA, a nd is therefore subject to the CAAA’s RACT control requirements. De laware has addressed all these RACT requirements in its RACT SIP revision, which was submitted to EPA in September 2006, and is pending EPA review and approval (Reference 1-1).

In addition, Section 182( b)(1) of the CAAA require s that all moderate nonattainment areas for ozone achieve “Reas onable Further Progress (RFP)” toward attainment of the ozone NAAQS. In Se ptember 2005, EPA issued “Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard-Phase 2” ( 70 FR

71612 , hereafter referred to as the Phase 2 Rule) 2 . The Phase 2 Rule specifies the requirements for a non-attainment area to m eet the CAAA’s RFP provisions. For the moderate non-attainment areas, such as Delaware within the Philadelphia NAA, the requirements include:

(1) Between 2003 and 2008, to implement adequate emission controls th at will lead to

a total of 15% reduction in VOC emissions from the 2002 levels.

2 On December 22, 2006, the US Court of Appeals for the District of Colu mbia Circuit ordered EPA to come up with new enforcement plan for implementing the 8-hour ozone standard. It should be pointed out that this SIP revision is to follow the relevant CAA provisions and to meet the minimum CAA requirements for attaining the 8-hour ozone standard. This SIP revision may need to be updated, depending on how the EPA responds to the court decision.3 (2) In 2009-2010, to implement adequate emission controls that will lead to additional

emission reductions to be needed for attainment. Based on the definition of attainment year and its ozone season under the 8-hour ozone standard, these

additional emission reductions must be ach ieved prior to the ozone season of 2009 (i.e., before May 1, 2009). (3) The NAA must demonstrate, through regi onal air quality modeling and weight-ofevidence analysis, that with the em ission reductions meeting the above 2 requirements the NAA will successfully atta in the 8-hour ozone standard in the attainment year.

This document demonstrates how Delaware plans to meet the RFP requirements in (1) and (2) above, and the attainment require ments in (3) above. In addition, Delaware ozone monitoring data in 2003, 2004, 2005 and 2006 have shown that the entire state of Delaware, and the entire Philadelphia NAA, has attained the 1-hour ozone NAAQS (see Section 2 of this document). The control measur es in this ozone SIP revision also serve as maintenance measures for maintaining the atta inment status of the 1-hour ozone standard

in Delaware.

Also, before designation as a moderate nonattainment area for the 8-hour standard,

Kent and New Castle Counties in Delaware we re classified as a “severe” nonattainment

area for the 1-hour ozone standard. Clean Air Act Section 182( d) requires severe nonattainment areas to include a number of pl anning requirements that are more stringent than those required for moderate non-attain ment areas. For Kent and New Castle Counties, the more stringent requirements th at remain in force under the 8- hour ozone

standard include:

(1) A lower major source NOX and VOC thre shold for point sources of 25 tons per year (TPY). (2) A requirement for new or expanding ma jor sources to offset increased emissions by 1.3-to-1.

In addition, under Section 184 of the CAAA, Sussex County was treated as a

moderate nonattainment area und er the 1-hour ozone standard. As such the major source threshold for VOC is 50 TPY, for NOX is 100 TPY, and an offset requirement of 1.15-to1 is in place. Based on this, the non-atta inment new source review requirements of the CAA are met for Delaware through the requirements of existing Delaware Air Pollution Control Regulation No. 25 (Precons truction Review, Reference 1-2).

It should be pointed out that while only the control measures that produce post2002 emission reductions are spec ifically creditable towards 8-hour ozone reasonable further progress (RFP) and attainment demonstr ation (AD), and thus included in this SIP revision (see Section 6 of this document), all of the control measures identified in Delaware’s previous SIP revi sions under the 1-hour ozone sta ndard will remain as valid and necessary measures to aid in the attain ment and maintenance of both the 1-hour and the 8-hour ozone NAAQS. For a complete revi ew of the 1-hour ozone control measure, please see References 2-1, 2-2 and 2-3.

To prevent significant contribution to th e ozone non-attainment or interference

with maintenance of the ozone standard in downwind states, Delaware has adequate provisions in its ozone SIP revisions and re gulations, including bot h pre- and post-20024 measures, and under the Federal Implementation Pl an (FIP). For a complete review of the relevant provisions, please s ee References 2-1, 2-2 and 2-3.

In addition, both Delaware’s air permitti ng regulations (e.g., Regulations #2, #25 and #30, Reference 1-2) and Dela ware state law (7 Del. C ode, Chapter 60) provide the Secretary of the Department of Natural Re sources and Environmental Control (DNREC) with the authority to take enforcement action, and to issue orders to any person violating any rule, regulation or order or permit condition or provision of the statue to cease and

desist from such violation.

1.2 Responsibility

The agency with direct responsibility for preparing and submitting this document is Delaware Department of Natural Resour ces and Environmental Control (DNREC), Division of Air and Waste Management, Air Quality Management Section (AQMS), under the Section Administrator, Ali Mirzakhalili. The working res ponsibility for Delaware’s air quality planning falls within AQM’s Planning Branch, under the Program Manager,

Ronald Amirikian. The Air-Shed Evaluation and Planning (AEP) Program within the Planning Branch is instrumental in completi ng this document, with supporting staff from other branches of AQM. Specifically,

• Frank F. Gao, Ph. D., and P.E., Engineer, is the project leader, and principal author of this SIP revision;

• Mohammed A. Majeed, Ph.D. and P.E., Engineer, is the principal author of Section 7 of this SIP revision;

• David F. Fees, P.E., Program Manager, AQMS Emission Inventor y Program, is the supporting lead for the 2002 base year emission inventory;

• Betsy Frey, Scientist, is the supporting lead for ozone monito ring data and trend analysis;

• Phillip A. Wheeler, Planner, is the suppor ting lead for the on-road mobile source emission projections, and in charge of transportation conformity part;

• Jack L. Sipple and Mark Prettyman, Scie ntists, are the coor dinator and supporting staff for future-year emission projection inventories.

Specific responsibilities of other program s, agencies and contractors will be explained in the relevant sections of this document.

References

1-1. Delaware Reasonably Available Control T echnology (RACT) State Implementation Plan (SIP) under the 8-Hour Ozone National Ambient Air Quality Standard (NAAQS) , Delaware Department of Natural Re sources and Environmental Control, Air Quality Management Section, Dover, Delaware, September 2006.

1-2. Regulations Governing the Control of Air Pollution , Air Quality Management Section, Division of Air a nd Waste Management, Delaware Department of Natural Resources and Environmental Control, Dover, Delaware, as of December 2006.5 2. Ozone Air Quality Status and Trends Analysis

2.1 Delaware Ozone Monitoring Network

Delaware set up its ambient ozone mon itoring network in late 1980s under the 1-

hour ozone standard. The network was mo dified and approved by EPA in 1995 for meeting the then-upcoming 8-hour ozone stan dard. The current network for monitoring

ambient ozone concentrations under the 8-hour ozone NAAQS contains 6 monitors, with 3 monitors in New Castle County, 1 monitor in Kent County and 2 monitors in Sussex County. Figure 2-1 shows the locations of these monitors. Delaware maintains and operates the network to measure ambient ozone levels within Delaware for comparison to NAAQS. All data is measured using U.S. EPA approved methods. The data is submitted to EPA’s Air Quality System (AQS) in a timely manner in accordance to the schedule prescribed by EPA.

Figure 2-1. Delaware Ozone Monitoring Network for 8-Hour Ozone NAAQS

2.2 Attainment of 1-Hour Ozone Standard

Under the previous 1-hour ozone NAAQS , Delaware’s Kent and New Castle Counties were designated as severe non-atta inment areas, while Sussex County was a marginal non-attainment area; and the whole st ate was a part of an ozone transport region established under Section 184 of the CAAA. Section 181 of CAAA required Delaware to6 attain the 1-hour ozone standard in Susse x County by 1993 and in Kent and New Castle Counties by 2005. To meet this requirement, Delaware im plemented numerous controls to

reduce VOC and NOx emissions from all sources sectors in Delaware (References 2-1, 2-2 and 2-3). As a result of those control m easures, measures implemented nationally by EPA, and measures taken by upwind states, De laware’ ambient air quality relative to ozone has improved significantly.

Table 2-1 shows the number of exceedance days of the 1-hour ozone standard for

all three counties in Delaware from 2004 to 2006. Table 2-2 presents the 1-hour ozone design values for all three counties. Data in Table 2-1 and Table 2-2 are based on actual monitoring records. Accord ing to CAAA’s definition of 1-hour design values and requirement for attaining the 1-hour ozone standard, data in Table 2-1 and Table 2-2 indicate clearly that Delaware’s three counties attained the 1-hour ozone standard in 2005,

and maintained the 1-hour standard in 2006.

Table 2-1. Number of Days with Ex ceedance of 1-Hour Ozone Standard

Year Kent New Castle Sussex

2003 1 1 2

2004 0 0 0

2005 0 2 0

2006 0 0 0

Table 2-2. The 1-Hour Ozone Design Values (ppm) of Delaware’s Counties

Period Kent New Castle Sussex

2003-2005 0.107 0.109 0.112

2004-2006 0.101 0.104 0.103

Data obtained from EPA’s national databa se for air monitoring data, Air Quality System (AQS), indicates that other c ounties within Philadelphia Consolidated Metropolitan Statistical Area (CMSA) are in the same attainment status with respect to the 1-hour ozone standard (Reference 2-4). Table 2-3 presents the 1-hour ozone design values for counties in Maryland within the Philade lphia CMSA, Table 2-4 presents the 1-hour ozone design values for counties in Penns ylvania within the Philadelphia CMSA, and Table 2-5 presents the 1-hour ozone design valu es for counties in New Jersey within the Philadelphia CMSA. Data in Tables 2-1 throug h Table 2-5 indicate cl early that the entire Philadelphia CMSA attained the 1-hour ozone standard in 2005, a nd maintained the 1-

hour standard in 2006.

Table 2-3. The 1-Hour Ozone Design Values (ppm) of Maryland County in Philadelphia CMSA

Period Cecil

2003-2005 0.107

2004-2006 0.1017 Table 2-4. The 1-Hour Ozone Design Values (ppm) of New Jersey Counties in Philadelphia CMSA

Period Camden Cumberland Glou cester Mercer Burlington Salem

2003-2005 0.107 0.109 0.112 0.107 0.109 0.112

2004-2006 0.101 0.104 0.103 0.101 0.104 0.103

Table 2-5. The 1-Hour Ozone Design Values (ppm) of Pennsylvania Counties in Philadelphia CMSA

Period Bucks Chester Delaware Montgomery Philadelphia

2003-2005 0.109 0.112 0.107 0.109 0.112

2004-2006 0.104 0.103 0.101 0.104 0.103

2.3 Delaware 8-Hour Ozone Design Values

In April 2004, EPA designated the 8-hour ozone non-attainment areas based on design values of individual c ounties within each area. Under the 8-hour ozone standard (0.08 ppm), the design value of a specific co unty is defined as th e highest three-year average of the 4 th highest daily 8-hour maximum. The average is calculated as a ppm value truncated at three decimal places. Wh ere there is more than one monitor in a county, the highest calculated value becomes the design value for that county. The EPA’s designations for the 8-hour ozone NAAQS non-a ttainment areas in April 2004 were based

on individual counties’ 2001-2003 design values.

In the early 2000’s Delaware’s oz one monitoring data indica ted that Delaware’s air quality did not meet the 8- hour ozone NAAQS. Table 2-6 summaries the 8-hour ozone design values of the three counties in Dela ware starting with the 2000-2002 period. Based on the 2001-2003 design values, EPA designated in 2004 all three counties in Delaware as

moderate non-attainment for the 8-hourozone NAAQS, within the PhiladelphiaWilmington-Atlantic Cit y, PA-NJ-MD-DE moderate non-attainment area.

Table 2-6. Delaware 8-Hour Ozone Design Values by County

Years New Castle Kent Sussex

2000 - 2002 0.096 0.092 0.094

2001 - 2003* 0.094 0.089 0.091

2002 - 2004 0.089 0.084 0.085

2003 - 2005 0.082 0.080 0.084

2004 - 2006 0.082 0.080 0.084

*Design values used by EPA in April 2004 non-attainment designation.

2.4 Ozone Exceedances at Delaware Monitors8 Delaware began recording the 8-hour ozone exceedances at its am bient monitors in 1996 (1997 at the monitor at Lewes station). An exceedance is recorded at a monitoring site when the daily maximum 8-hour average, rounded to two decimals, is greater than the standard of 0.08 ppm. Table 2-7 summarizes the number of exceedances at all Delaware monitors from 1996 to 2006. Figure 2-2 is graphical representation of the ozone exceedances (i.e., the data in Table 2-7), wh ich clearly shows a d ecreasing trend. Since there is no averaging across years, it also shows the variability between years, likely due to variation in both emissions and meteorological conditions. For example, there are a lower

number of exceedances associated with th e cooler and/or wetter summers of 1996, 2000 and 2004. On contrast, a higher number of exceedances in 2002 were likely associated with a hotter-than-average summer in that y ear. In addition, the EPA NOx SIP call went into effect in 2003, and resulted in signifi cant reduction in NOx em issions from upwind power plants.

Table 2-7. Number of Days Exceeding 8-hour Ozone NAAQS at Individual Monitors

New Castle County Kent County Sussex County

Year Brandywine Bellefonte Lums Pond Killens Pond Seaford Lewes

1996 4 3 5 8 5 -*

1997 17 6 15 14 14 14

1998 17 8 12 17 16 17

1999 16 10 12 13 17 17

2000 7 4 5 5 5 6

2001 15 7 9 8 4 10

2002 18 14 9 10 10 14

2003 3 3 4 3 4 4

2004 3 1 0** 0 0 2

2005 3 4 6 2 3 7

2006 2 1 2 4 1 3
*Not monitored in 1996; **No data recorded in July 2004.9 Figure 2-2. Number of 8-hour Ozone Exceedance Days at Monitors

From Table 2-7 and Figure 2-2, it can be s een that the numbers of ozone

exceedances in Delaware have shown a decreasi ng trend in the past decade. In the late 1990s and early 2000s, a majority of Delaware monitors showed a double-digit number of ozone exceedance days. In the last four years, however, all monitors showed a single-digit number of exceedance days.

2.5 Monitored Ambient Ozone Concentration Trends

Table 2-8 provides a summary of the ambient ozone con centrations monitored at

individual Delaware monitors from 1996 to 200 6. The data in Table 2-8 are presented in terms of design values (i.e., th ree-year averages of annual 4 th highest 8-hour daily concentrations). Using design values has some advantages. First, the three-year average values account for some of the meteorological variability between individual years, which

are thus useful in detec ting general trends in am bient ozone concentrations

. Second, since

attainment or non-attainment st atus will be determined by th e design values, the trend of the design values can represent a direction towards future atta inment status. Figure 2-3 is a graphical representation of the data in Ta ble 2-8. The data in Table 2-8 and Figure 2-3 shows a trend in the ozone design values appro aching attainment at all Delaware monitors, in particular, after 2001-2003 period.

Table 2-8. The 8-Hour Ozone Design Values for All Delaware Monitors from 1994 to

2006 0 5 10 15 20 25

1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006

Year Num. Days

Brandywine Bellefonte Lums Pond Killens Seaford Lewes10 New Castle County Kent County Sussex County

Years Brandywine Bellefonte Lums Po nd Killens Pond Seaford Lewes

1994 - 1996 -* 0.094 0.098 -* 0.088 -*

1995 - 1997 0.093 0.094 0.099 0.094 0.093 -*

1996 - 1998 0.094 0.084 0.094 0.096 0.097 -*

1997 - 1999 0.099 0.089 0.099 0.099 0.099 0.099

1998 - 2000 0.096 0.090 0.097 0.097 0.098 0.095

1999 - 2001 0.095 0.091 0.097 0.093 0.095 0.090

2000 - 2002 0.096 0.092 0.096 0.092 0.094 0.087

2001 - 2003 0.093 0.094 0.093 0.089 0.091 0.088

2002 - 2004 0.089 0.085 0.084** 0.084 0.085 0.085

2003 - 2005 0.082 0.082 0.080** 0.080 0.082 0.084

2004 - 2006 0.082 0.081 0.078** 0.080 0.080 0.082
*Data not enough for calculating design values; **No data recorded in July 2004.

Figure 2-3. Ozone 8-hour Design Values for Individual Monitors

2.6 Meteorological Analysis

Many meteorological factors affect the formation of ground level ozone. One major factor is the ambient temperatur e during the ozone season. One way of incorporating meteorolo gy in evaluating trends in ozone concentrations is to analyze the number of ozone exceedances, the number of da ys with temperatures equal to or greater

than 90 ° F, and the ratio of the two numbers. Table 2-9 shows this set of data for Delaware from 1996 through 2006. It should be noted that the temperature data in Table 2-9 are 0.06 0.07 0.08 0.09 0.10 0.11 0.12

94-96 95-97 96-98 97-99 98-00 99-01 00-02 01-03 02-04 03-05 04-06

Years ppm Brandywine Bellefonte Lums Pond Killens Pond Seaford Lewes11 from New Castle County only (Data from Ne w Castle Municipal Airport), while the number of exceedance days are for the entire state (i.e., all three counties). It can be reasonably assumed that the temp erature profile for the entire state be similar to that of New Castle County.

Table 2-9. Delaware 8-Hour Ozone NAAQS Exceedances with Respect to Hot Summer Days

# Day # Days

Year Temp. >= 90°F Exceedances Ratio

1996 7 6 0.86

1997 20 19 0.95

1998 16 21 1.31

1999 35 18 0.51

2000 8 8 1.00

2001 9 18 2.00

2002 32 18 0.56

2003 10 5 0.50

2004 1 3 3.00

2005 20 8 0.40

2006 21 2 0.10

Average Ratio 1.02

An average ratio that is close to one in Ta ble 2-9 can be seen as one type of index of a direct relationship between temperature a nd ozone exceedances in the long term. This relationship indicates that more ozone exceedan ces usually occur in years with more hot summer days, such as 1997, 1998, 1999, and 2 002 where both exceedance numbers and hot-day numbers are in the double digits ( ≥ 10). Similarly, fewer oz one exceedances occur in years with fewer hot summer days , such as 1996, 2000, and 2004, where both exceedance numbers and hot-day numbers are si ngle digits (<10). In contrast to this general relation, both 2005 and 2006 have high numbers of hot summer days but low numbers of ozone exceedances, making their ratios very low. One explanation for these

low ratios is that under the same ozone-f avoring meteorological conditions (i.e., high ambient temperatures), recent changes in other conditions have occurred that work against ozone formation. One likely change would be a decrease in con centrations of ozone forming precursors (i.e., VOC and/ or NOx) in the ambient air.

2.7 General Trend of Ambient Air Qu ality Regarding 8-Hour Ozone

From the data presented in this section, it is clear that the gene ral trend of ambient ozone air quality in Delaware is continuously improving, especially in the past 3 years. In

summary:

(1) Numbers of the 8-hour ozone exceedances at all Delaware monitors show a clear decreasing trend (Table 2-7 and Figure 2-2); (2) Ambient ozone concentrations recorded at all Delaware monitors show a clear downward trend (Table 2-8 and Figure 2-3);12 (3) Ratios of ozone exceedances versus hot summer days in 2005 and 2006 lead to an apparent downward trend in the future years (Table 2-9).

References

2-1. Regulations Governing th e Control of Air Pollution , Air Quality Management Section, Division of Air a nd Waste Management, Delaware Department of Natural Resources and Environmental Control, Dover, Delaware, as of December 2006.

2-2. Delaware 2005 Rate-of-Progress Plan for Kent and New Castle Counties

, For Demonstrating Progress toward Attainment of the 1-Hour National Ambient Air Quality Standard for Ground-Level Ozone , Department of Natural Resources and Environmental Control, Dover, DE, December 2000.

2-3. Measures to Meet the EPA-Identified Shortf alls in the Delaware Phase II Attainment Demonstration for the Philadelphia-Wilm ington-Trenton Ozone Non-Attainment

Area , Department of Natural Resources and Environmental Control, Dover, DE, July

2001.

2-4. Air Quality System, National Database for Air Monitoring Data , US Environmental Protection Agency, at http://www.epa.gov/ttn/ai rs/airsaqs/index.htm

.13 3. Delaware 2002 Base Year Emissions Inventory

Under the 8-hour ozone NAAQS, EPA requ ires the non-attainment areas to compile a 2002 base year VOC/NOx emission i nventory as the baselin e for RFP emission reduction analysis toward attainment, but allows states the option of justifying the use of an alternative base year (Phase 2 Rule, 70 FR 71612 ). Delaware has used the year 2002 as its base year.

Compilation of Delaware’s 2002 base ye ar emission inventor y was conducted by AQMS’ Emission Inventory Development (E ID) Program. The development of the 2002 emission inventory was governed by a Quality Assurance Project Plan (QAPP) prepared by EID (Reference 3-1). Due to a staffing s hortage of the EID group, AQMS contracted with E.H. Pechan and Associates (hereafter re ferred to as Pechan) based in Durham, North Carolina, to develop portions of the 2002 base year inventory, under close direction of the EID program manager. Methods of developi ng the 2002 base year inventory are briefly described herein, while details are presente d in the QAPP and Delaware 2002 Base Year Emission Inventory (Reference 3-2).

It should be pointed out: (1) The 2002 ba se year emission inventory has been compiled to serve Delaware for this ozone SIP, for a particulate matter (PM) attainment demonstration SIP and a regional haze SIP that are now under development, and for air toxics assessments; therefore contains emissions data for VOC, NOx, carbon monoxide (CO), PM, sulfur dioxide (SO 2 ), ammonia (NH 3 ) and all Hazardous Air Pollutants (HAPs). Since this document is solely an ozone SIP revision, it will discus s only the two major ozone precursors, i.e., VOC and NOx. (2) Alth ough CO is considered an ozone precursor,

its contribution to ozone formation is believed to be insignificant, and the CAAA does not require consideration of CO emissions in the ozone attainment planning process. Therefore, CO emission data will not be discussed in this document. (3) Although biogenic source emissions (VOC and NOx) and NOx emissions due to lightning are included in the 2002 base year inventory, the CAAA does not require inclusion of these

natural sources of emissions in the ozone SI P development. Therefore, these natural emissions are not discussed in this document. (4) The 2002 base year VOC emissions do not contain emissions of pollutants that are defined by EPA as non-reactive in ozone formation (e.g., perchloroethylene (PERC)).

3.1 Point Source Sector

The emission inventory of this sector has been developed by the EID’s point

source technical lead and s upporting staff. Under CAAA and EPA’s Phase 2 Rule ( 70 FR

71612 ), the minimum requirements for Delaware to include in the point source sector are (1) all Title V permitted facili ties, (2) in Kent County and New Castle County, facilities that have a facility-wide annual VOC emission of 25 tons or greater, or a facility-wide annual NOx emission of 25 tons or greater, (3 ) in Sussex County, facilities that have a facility-wide annual VOC emission of 100 tons or greater, or a facility-wide annual NOx emission of 100 tons or greater, and (4) all elec tric generating facilitie s. For consistency, however, Delaware has modified criteria (2) and (3) by set ting lower thresholds for VOC and NOx sources as follows: 5 tons per year (TPY) or greater for VOC emission sources, and 25 TPY or greater for NOx emission sources. A list of all point source facilities in the 2002 base year inventory is presented in Table 3-1.14 Table 3-1. Point Source Facilities in Delaware 2002 Base Year Inventory

# Facility Location Facility

ID Facility Name

1 Kent County, DE 00026 BAYHEALTH MED CENTER KENT GENERAL

HOSP

2 00099 CAMDEL METALS CORPORATION

3 00002 CITY OF DOVER - MCKEE RUN GENERATING

STA

4 00076 CITY OF DOVER VAN SANT GENERATING

STA

5 00121 COLOR-BOX LLC

6 00068 DE SOLID WASTE AUTHORITY SANDTOWN

7 00066 DELAWARE STATE UNIVERSITY

8 00001 DOVER AIR FORCE BASE

9 00016 DOW REICHHOLD SPECIALTY LATEX LLC

10 00024 HANOVER FOODS CORPORATION

11 00012 HARRIS MANUFACTURING CO INC

12 00067 HIRSH INDUSTRIES

13 00011 ILC DOVER INC.

14 00007 KRAFT FOODS NORTH AMERICA

15 00127 NRG ENERGY CENTER DOVER LLC

16 00075 PERDUE FARMS INC - MILFORD

17 00004 PROCTOR AND GAMBLE DOVER WIPES

COMPANY

18 00006 TILCON DELAWARE - BAY ROAD

19 00014 TILCON DELAWARE - HORSEPOND ROAD

20 00152 WARREN F BEASLEY POWER STATION

21 New Castle County, DE 00377 AGILENT TECHNOILOGIES

22 00064 AIR LIQUIDE AMERICA L P

23 00131 ALFRED I DUPONT HOSPITAL FOR CHILDREN

24 00029 AMETEK INC CHEMICAL PRODUCTS

DIVISION

25 00288 AMI ASSET ACQUISITION CO

26 00023 AMTRAK WILMINGTON MAINTENANCE

FACILITY

27 00059 ARLON, INC.

28 00106 ASTRAZENECA PHARMACEUTICALS LPFAIRFAX

29 00080 CHRISTIANA CARE - CHRISTIANA HOSPITAL

30 00024 CHRISTIANA CARE - WILMINGTON

HOSPITAL

31 00068 CHRISTIANA MATERIALS

32 00003 CIBA SPECIALTY CHEMICALS CORP

33 00063 CLAYMONT STEEL

34 00290 CLEAN EARTH OF NEW CASTLE

35 00317 CONECTIV DELMARVA GENERATIONCHRISTIANA

36 00005 CONECTIV DELMARVA GENERATION-DEL

CITY

37 00007 CONECTIV DELMARVA GENERATION-EDGE

MOOR

38 00388 CONECTIV DELMARVA GENERATION-HAY

ROAD15 39 00046 CONECTIV DELMARVA GENERATIONMADISON ST

40 00006 CONECTIV DELMARVA GENERATIONWEST_SUBST

41 00066 CONTRACTORS MATERIALS LLC HOT MIX

PLT

42 00128 DAIMLERCHRYSLER CORPORATION

43 00365 DASSAULT FALCON JET-WILMINGTON CORP

44 00111 DE SOLID WASTE AUTHORITY CHERRY

ISLAND

45 00086 DE SOLID WASTE AUTHORITY PIGEON

POINT

46 00090 DELAWARE CORRECTIONAL CENTER -

SMYRNA

47 00415 DELAWARE RECYCLABLE PRODUCTS INC

48 00077 DEPT OF VETERANS AFFAIRS MEDICAL

CENTER

49 00069 DIAMOND MATERIALS LLC

50 00126 DUPONT CHESTNUT RUN

51 00010 DUPONT EDGEMOOR

52 00011 DUPONT EXPERIMENTAL STATION

53 00279 DUPONT STINE - HASKELL LABORATORY

54 00049 DUPONT WILMINGTON OFFICE BUILDING

55 00073 E-A-R SPECIALTY COMPOSITES S B U AEARO

56 00040 EDGEMOOR MATERIALS INC

57 00051 FMC BIOPOLYMER

58 00027 FORMOSA PLASTICS CORPORATION

59 00037 FP INTERNATIONAL INC

60 00500 GE ENERGY (USA) LLC

61 00032 GENERAL CHEMICAL CORPORATION

62 00015 GENERAL MOTORS CORPORATION

63 00513 HARDCORE COMPOSITES, DIV. OF HARRIS

SPEC

64 00017 HERCULES INCORPORATED RESEARCH

CENTER

65 00038 HONEYWELL INTERNATIONAL INC

66 00367 INTERNATIONAL PETROLEUM CORP OF

DELAWARE

67 00350 KANEKA DELAWARE CORPORATION

68 00129 LAFARGE NORTH AMERICA INC

69 00028 LAIDLAW CORPORATION

70 00104 MACDERMID INC

71 00291 MAGELLAN TERMINALS HOLDINGS, L.P.

72 00383 MEDAL A DIV OF AIR LIQUIDE ADV TECH US

73 00074 METACHEM PRODUCTS LLC

74 00324 NORAMCO INC

75 00018 NVF COMPANY INC - YORKLYN FACILITY

76 00030 OCCIDENTAL CH EMICAL CORPORATION

77 00016 PREMCOR DELAWARE CITY REFINERY

78 00404 PREMCOR TERMINAL

79 00093 PRINTPACK INC

80 00382 PTFE COMPOUNDS INC

81 00463 PURE GREEN INDUSTRIES INC

82 00033 ROHM & HAAS ELECTRONIC MATERIALS16 CMP TE

83 00381 SPATZ FIBERGLASS PRODUCTS

84 00426 SPI POLYOLS INC

85 00133 ST. FRANCIS HOSPITAL

86 00021 SUNOCO INC MARCUS HOOK REFINERY

87 00092 THE CROWELL CORPORATION

88 00048 TILCON DELAWARE - TERMINAL AVENUE

89 00058 UNIQEMA

90 00067 UNISOURCE WORLDWIDE INC

91 00022 UNIVERSITY OF DELAWARE NEWARK

92 00127 VPI FILM LLC

93 00121 WESTVACO CORPORATION

94 00004 WILMINGTON PIECE DYE CO

95 00389 WILMINGTON WASTEWATER TREATMENT

PLANT

96 Sussex County, DE 00013 ALLEN FAMILY FOODS INC

97 00016 ALLEN'S HATCHERY INC ALLEN'S MILLING

98 00036 BAYHEALTH MEDICAL CTR - MILFORD

MEMORIAL

99 00029 CITY OF LEWES POWER PLANT

100 00108 CITY OF SEAFORD-ELECTRIC POWER PLANT

101 00099 DE SOLID WASTE AUTHORITY SOUTHERN

102 00120 EDWARD J. KAYE CONSTRUCTION

103 00001 INDIAN RIVER GENERATING STATION

104 00002 INVISTA

105 00006 JOHNSON POLYMER INC

106 00066 JUSTIN TANKS LLC

107 00093 MARITRANS

108 00028 MIL-DEL CORPORATION

109 00004 MOUNTAIRE FARMS OF DELAWARE INCMILLSBOR

110 00073 MOUNTAIRE FARMS OF DELMARVA –

SELBYVILLE

111 00012 MOUNTAIRE FARMS OF DELMARVA

FRANKFORD

112 00121 MULTI-TECH INC

113 00011 ORIENT CORPORATION OF AMERICA

114 00003 PERDUE FARMS – BRIDGEVILLE

115 00075 PERDUE FARMS INC – GEORGETOWN

116 00146 PERDUE-AGRIRECYCLE LLC

117 00071 PINNACLE FOODS CORPORATION - VLASIC

PLNT

118 00009 SEA WATCH INTERNATIONAL LTD

119 00196 THE MARBLE WORKS

120 00130 TILCON DELAWARE – GEORGETOWN

121 00026 TILCON DELAWARE GUMBORO

Each point source facility is required to submit to the EID group a detailed report, which contains all necessary emission-rela ted information for all emission-making processes within the facility ’s boundary. The required in formation includes emissions directly measured by continuous emission monitors (CEMs), or activity data that can be used to calculate emissions. The report incl udes also all informa tion regarding control17 measures currently (as of 2002) installed on the relevant processes. After quality control and quality assurance (QC-QA) review and nece ssary revision, EID verifies or determines the annual emissions and summer ozone season daily emissions for each process within a facility. Then, all the process-level emissions are summed up to the facility’s total

emissions. The final emission data were included in the SI P submission to EPA (Reference 3-2).

3.2 Stationary Non-Point Source Sector

The emission inventory of stationary non- point (or area) source sector has been conducted by Pechan, with technical support from the EID group. This source sector represents a large and diverse set of indi vidual emission source categories. A non-point source category is eith er represented by small facilities too numerous to individually inventory, such as gasoline stations or print shops, or is a common emission-making activity, such as the use of paints or cleani ng solvents. The distinction between point and non-point sources is defined by an annual emi ssion threshold as described in Subsection 3.1 above. Table 3-2 presents a list of all stationary non-point s ource categories included in Delaware 2002 base year inventory.

Table 3-2. Non-Point Source Categories in Delaware 2002 Base Year Inventory

SCC* VOC Emissions Only SCC* Emissions of VOC and NO

x 2461 Agricultural Pesticides 2830 Catastrophic/Accidental Releases
2401 AIM Coatings 2302 Commercial Cooking
2461 Asphalt Paving 2103 Commercial Fuel Combustion
2401 Auto Refinishing 2102 Industrial Fuel Combustion

2302 Bakeries 2302 Land Clearing Debris Burning
2460 Commercial & Consumer Products 2810 Prescribed Burning
2420 Dry Cleaning 2104 Residential Fuel Combustion
2501 Gasoline (Petroleum) Marketing 2610 Residential Open Burning

2505 Gasoline (Petroleum) Marketi ng** 2104 Residential Wood Combustion
2425 Graphic Arts 2810 Structure Fires

2440 Industrial Adhesives 2810 Vehicle Fires
2401 Industrial Surface Coatings 2810 Wildfires

2620 Landfills (Inactive)
2660 Leaking Underground Storage Tanks
2630 Publicly-Owned Treatment Works
2415 Solvent Cleaning
2401 Traffic Markings

*A complete SCC code has 10 digits, with the last 6 digits specifying subcategories. **For two subcategories, tank trucks in transit an d evaporative emissions from transport of petroleum products by commercial marine vessels.

Inventory work in this sect or started with collecting relevant activity data by the EID staff members and providing them to Pech an. Pechan’s staff in the non-point sector selected appropriate methods, with consulta tion of the EID manager and supporting staff,

for emission calculations. Af ter two rounds of QC-QA revi ews and revision by Pechan’s18 staff and EID staff, the emission data were finalized, and include d in the final SIP submission to EPA (Reference 3-2).

3.3 Non-Road Mobile Source Sector

The emission inventory of the non-road mobile source sector has been conducted by Pechan, with technical support from the EID st aff. This sector includes (1) non-road vehicles that are not covered by on-road mobile sector (as described in Section 3.4 of this document), and (2) moving equipment. The non-road vehicles and equipment are grouped into the following four subcategories for the purpose of developing emission estimates:

(1) Aircraft – Commercial, military, and private aircrafts; (2) Locomotives – Commercial line haul and yard locomotives; (3) Commercial Marine Vessels (CMVs) – Va rious types of vessels that navigate the Delaware Bay and River and the Ch esapeake and Delaware Canal (this subcategory does not include recreational boats); (4) Other Off-road Vehicles and Equipment – including the following:

• Recreational (land-based);

• Construction and Mining;

• Industrial;

• Lawn and Garden;

• Agricultural;

• Commercial;

• Logging;

• Airport Ground Support;

• Recreational Marine; and

• Railway Maintenance.

Inventory work in this sect or started with collecting relevant activity data by the EID staff members and providing them to Pech an. Pechan’s staff in the non-road sector selected appropriate methods, with consulta tion of the EID manager and supporting staff,

for emission calculations.

Emissions from aircraft, locomotives, and CMVs were calculate d using appropriate

emission factors and controls as effective in 2002. Emissions of all other non-road sources in subcategory (4) above were estimated using EPA’s NONROAD m odel, 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 an d revision by Pechan’s staff and EID staff, the emission data were finalized, and included in the fi nal SIP submission to EPA (Reference 3-2).

3.4 On-Road Mobile Source Sector

The emission inventory of on-road mob ile source sector has been conducted by Pechan, with technical support from the EID staff. The on-road mobile sources cover all highway vehicles including pass enger cars, light-duty trucks, sport utility ve hicles, heavyduty trucks, buses, and motorcycles, which traveled on Delaware’s roadways in 2002.19 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), a nd summarized all information about control

measures effective in 2002. With the vehicl e 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 VOC and NOx emissions for each vehicle type on each road class. The end products of the calcula tions are sums of VOC and NOx emissions for

all vehicles on all road classe s in each of the thre e counties in Delaware . After two rounds of QC/QA reviews and revision by Pechan’s st aff and EID staff, the emission data were finalized, and included in the final SI P submission to EPA (Reference 3-2).

3.5 Delaware 2002 Base Year Emission Inventory Summary

Table 3-3 and Table 3-4 present a summar y of Delaware 2002 base year VOC and NOx emissions. Since biogenic source emi ssions are not required in the ozone RFP planning, they are not in cluded in the tables.

Table 3-3. Delaware 2002 Base Year VOC Emissions in Tons per Day

Source Sector Kent New Castle Sussex State Total

Point 0.49 9.42 13.35 23.26
Stationary Area 5.75 20.02 7.31 33.08

Non-Road Mobile 5.17 12.24 9.36 26.77

On-Road Mobile 5.45 16.98 9.95 32.38

Total Emissions 16.86 58.66 39.97 115.49

Table 3-4. Delaware 2002 Base Year NOx Emissions in Tons per Day

Source Sector Kent New Castle Sussex State Total

Point 5.06 44.09 24.95 74.10
Stationary Area 0.45 1.95 0.77 3.17

Non-Road Mobile 15.02 24.62 13.15 52.79

On-Road Mobile 13.97 36.56 18.50 69.03

Total Emissions 34.50 107.22 57.37 199.09

References

3-1. Quality Assurance Project Plan for 2002 Ba se Year Ozone State Implementation Plan Emission Inventory for VOCs, NOx, and CO for the State of Delaware

, Delaware Department of Natural Resources and Environmental C ontrol, Air Quality Management Section, Dover, Delaware, January 2007.

3-2. The 2002 Base Year Ozone State Implementation Plan Emission Inventory for VOCs, NOx, and CO for the State of Delaware , Delaware Department of Natural Resources and Environmental Control, Air Quality Ma nagement Section, Dover, Delaware, June

2007.20 4. Emission Reduction Requirements for RFP and Attainment

4.1 Adjustments of 2002 Base Year Emission Inventory

As mentioned in Section 1 of this doc ument, Delaware must achieve specific emission reductions in the period of 2003-2008 and 2009-2010 to meet the CAAA RFP requirements and to demonstrate attainment of the 8-hour ozone sta ndard. According to EPA’s guidance (Reference 4-1) and the Phase 2 Rule ( 70 FR 71612 ), the 2002 base year inventory must be adjusted for non-creditable emission re ductions before the required

emission reductions are calculated. Details of this adjustment are described below.

Step 1. Development of 2002 Baseline Inventory

The 2002 Baseline Inventory is define d as an inventory accounting for only anthropogenic emissions within Delaware stat e boundaries. This base line inventory shall not include, (1) natural emissions, (2) any em issions from sources outside Delaware, and (3) the non-reactive perchloroethylene (PERC) emissions (for VOC inventory only).

From the discussion in Section 3 of this do cument, it can be seen that Delaware’s 2002 Base Year VOC and NOx emissions (Table 3-3 and Table 3-4) meet the condition of baseline inventory. Therefore, the 2002 Base Year anthropogenic Inventory is the 2002 Baseline Inventory

Step 2. Calculations of Mobile Source Adjustments

According to Section 182(b)(1)(D) of the CAAA, emission reductions that resulted

from the Federal Motor Vehicle Control Pr ogram (FMVCP) and Reid Vapor Pressure (RVP) rules promulgated prio r to 1990 are not creditable for achieving RFP emission reductions. Therefore, the 2002 Baseline Inventor y needs to be adjusted by subtracting the

VOC and NOx emission reductions that are ex pected to occur between 2002 and future milestone years due to the FMVCP and RVP rules.

The FMVCP/RVP VOC and NOx emission re ductions that are expected to occur between 2002 and 2008 were determined using EPA's MOBILE6.2 model. Based on the Phase 2 Rule and the guidance from EPA Re gion 3 Office (Christ opher Cripps, personal correspondence), AQM’s mobile source staff members conducted two MOBILE6.2 runs

as follows:

(1) Running MOBILE6.2 with 2002 as evaluati on year and the adjusted input conditions with: 1990 I/M programs (as they were in 1990 if any), without using “fuel program” command to turn-on th e appropriate RFG program, setting the RVP to the same value used for the 1-hour plans (i.e., 9.0 psi, as required by the June 1990 rule, 40 CFR 80.27(a)(2)), us ing NO TIER 2, NO 2007 HDDV RULE

and NO CLEAN AIR ACT commands. Then, using the obtained emission factors and the 2002 VMTs to compute an “adjusted 2002 on-road inventory.” (2) Running MOBILE6.2 with 2008 as evaluation year and the same adjusted input conditions as in (1). Then, using the obtained emission factors and the 2002 VMTs to compute an “adjusted 2008 on-road inventory.” (3) Computing the difference between the above two “adjusted on-road inventory” to obtain the mobile source 2008 adjustment to the 2002 baseline inventory.21 The input and output files of the MOBILE 6.2 runs for the above adjustments, the emission factors generated and relevant calculations for emission projections are presented in Appendix 4-1.

For the period between 2002 and the 2010 atta inment year, steps (2) and (3) above

were conducted. Accord ing to EPA’s Final Ru le to Implement the 8-Hour Ozone National Ambient Air Quality Standard-Phase 1 ( 69 FR 23951 , hereafter referred to as the Phase 1 Rule), emission reductions for the 2010 attain ment year must be implemented by the beginning of the ozone season immediately preced ing the attainment year. In other words,

emission reductions for the attainment must be achieved before May of 2009. Therefore, instead of using 2010 as the evaluation year in step (2) above, the year 2009 was used.

The results of MOBILE6.2 runs for the a bove adjustments are presented in Table 4-1 for Sussex County and in Table 4-2 for Kent and New Castle Counties. The fleet

turnover corrections between 2008 and 2009 are al so calculated in Table 4-1 and Table 4-

2.

Table 4-1. Mobile Source FMVCP/RVP Adjustments for Sussex County

Adjusted On-Road Mobile Source Emissions VOC NOx Note
Adjusted for 2002 16.66 20.24 A

Adjusted for 2008 15.51 18.81 B 2008 Adjusted for 2009 15.48 18.71 B 2009 Mobile Source Adjustments for 2002 Baseline

For 2002-2008 1.15 1.42 C 2008 = A-B 2008

For 2002-2009 1.18 1.53 C 2009 = A-B 2009

Fleet Turnover Corrections for 2008-2009 0.03 0.10 D = C 2009 -C 2008

Table 4-2. Mobile Source FMVCP/RVP Adju stments for Kent/New Castle Counties

Adjusted On-Road Mobile Source Emissions VOC NOx Note

Adjusted for 2002 42.16 56.02 a

Adjusted for 2008 39.18 51.64 b 2008 Adjusted for 2009 39.13 51.40 b 2009 Mobile Source Adjustments for 2002 Baseline

For 2002-2008 2.98 4.38 c 2008 = a-b 2008

For 2002-2009 3.03 4.62 c 2009 = a-b 2009

Fleet Turnover Corrections for 2008-2009 0.05 0.24 d = c 2009 -c 2008

Step 3. Development of 2002 Adjusted Baseline Inventory

As explained in Step 2 above, the mobile source adjustments in Tables 4-1 and 4-2

are the non-creditable emission reductions due to the pre-1990 FMVCP and RVP rules. Subtracting these adjustments from the 2002 baseline inventory (i.e., the state total emissions in Table 3-3 and Table 3-4) will give the “the 2002 adjusted baseline inventory22 relative to the subject mileston e year,” as presented in Tabl e 4-3 for Sussex County and in

Table 4-4 for Kent and New Counties.

Table 4-3. The 2002 Adjusted Baseline Inventory for Sussex County

VOC NOx Note

2002 Baseline Emission Inventory 39.97 57.37 E

Mobile Source Adjustments for 2002-2008 1.15 1.42 C 2008 Mobile Source Adjustments for 2002-2009 1.18 1.53 C 2009

2002 Adjusted Baseline Relative to 2008 38.82 55.95 F 2008 = E-C 2008 2002 Adjusted Baseline Relative to 2009 38.79 55.84 F 2009 = E-C 2009

Table 4-4. The 2002 Adjusted Baseline Inventory for Kent/New Castle Counties

VOC NOx Note

2002 Baseline Emission Inventory 75.52 141.72 e

Mobile Source Adjustments for 2002-2008 2.98 4.38 c 2008 Mobile Source Adjustments for 2002-2009 3.03 4.62 c 2009

2002 Adjusted Baseline Relative to 2008 72.54 137.34 f 2008 = e-c 2008 2002 Adjusted Baseline Relative to 2009 72.49 137.10 f 2009 = e-c 2009

4.2 Emissions Reductions for 2003-2008 RFP

By the end of 2008, Delaware is requir ed to reduce 15% in its 2002 adjusted baseline emissions. According to the Phase 2 Rule ( 70 FR 71612 ), Sussex County must

achieve this 15% reduction in its VOC emissi on, since it did not have a 15% VOC Rateof-Progress (ROP) plan approve d by EPA under the 1-hour ozone standard. For Kent and New Castle Counties, their 15% emissi on reductions can be achieved from VOC

emissions and/or from NOx emissions.

(1) 15% VOC Emission Reduction in Sussex County

The 15% VOC emission reduction and emi ssion target in 2008 in Sussex County

are calculated as follows.

Sussex 2002 Adjusted VOC Baseline Relative to 2008: 38.82 TPD Required 15% Emission Reduction: 38.82 x 15% = 5.82 TPD 2008 VOC Emission Target: 38.82 – 5.82 = 33.00 TPD23 The next section (Section 5) demonstr ates that Sussex County meets this VOC target in 2008.

(2) 15% VOC Emission Reductions in Kent/New Castle Counties

The 15% VOC emission reduction and emi ssion target in 2008 in Kent and New

Castle Counties are calculated as follows.

Kent/New Castle 2002 Adjusted VOC Baseline Relative to 2008: 72.54 TPD Required 15% Emission Reduction: 72.54 x 15% = 10.88 TPD 2008 VOC Emission Target: 72.54 – 10.88 = 61.66 TPD

The next section (Section 5) demonstrates that Kent and New Castle Counties meet this VOC target.

4.3 Emissions Reductions for Attainment Year

According to the Phase 2 Rule ( 70 FR 71612 ), all VOC and/or NOx emission

reductions for attainment must be achieved prior to the ozone seas on of 2009, instead of 2010. In addition, both VOC and NOx emission re ductions can be used in the entire state to meet the reduction requirements. Section 7 of this document discusses reductions needed for attainment. According to Sectio n 7 of this document, the modeling performed by NY DEC of a 2009 MANE-V U OTB/OTW inventory, and a WOE analysis shows that

attainment will be reached both in Delaware and in the entire PA-NJ-DE-MD area in 2009. That modeling and WOE analysis in Section 7 included MANE_VU 2009 emission projections from Delaware at the following levels, which are therefore the emission targets

in 2009 to attain the 8-hour ozone standard:

Delaware VOC Emission Target in 2009: 85.04 TPD Delaware NOx Emission Target in 2009: 147.64 TPD

Reference

4-1. Guidance on the Adjusted Base Year Em issions Inventory and the 1996 Target for the 15 Percent Rate-of-Progress Plans , EPA-452/R-92-005, U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina, October 1992.24 5. Control Measures and Emission Reductions for 2003-2008 RFP

According to EPA’s Phase 2 Implementation Rule ( 70 FR 71612 ), Delaware must

achieve 15% VOC emission reduction in Susse x County from its 2002 baseline level, and

15% VOC and/or NOx emission reduction in Ke nt and New Castle Counties from their combined 2002 baseline level, before the end of 2008. Section 6 of this document presents details of control measures that Delaware has adopted and the 2009 emission projections under those controls. In general, because the 2008 milestone year is so close to the 2009 attainment year, the 2008 emission pr ojections in this se ction are obtained by linear interpolating of the 2002 base year emissions and the 2009 projections, unless otherwise explained. This interpolation method assumes a linear growth in emission between 2002 and 2009, wherever a growth factor is applied for the 2009 projection (See Section 6 of this document), and the same cont rol efficiency (CE), rule effectiveness (RE) and rule penetration (RP) in 2008 and 2009 for the relevant controls.

5.1 Point Source VOC Control Measures and Emission Reductions

5.1.1 Sussex County Point Source Contro ls and Emission Reductions

The only post-2002 point source VOC control in Sussex County is Regulation No. 24, Section 46, Control of Crude Oil Light ering Operations. The 2008 lightering emissions are projected based on the requireme nts of Reg. 24, Section 46. Emissions from all other point sources are estimated based on their 2009 projection (see Section 6) and interpolated to 2008 levels.

A. Crude Oil Lighter ing Operations

Delaware air pollution control Regulati on 1124 Section 46 was finalized in May 2007. Table 46-1 of Reg. 1124 Sec. 46 specifi es the following allowable uncontrolled VOC emissions from lightering operations:

Beginning on Maximum allowabl e uncontrolled lightering volume, expressed as a percentage of a fixed baseline volume, for prior 12-months (rolling total) May 1, 2008 80 % May 1, 2010 61 % May 1, 2012 43%

Assuming a 100% control efficiency (based on vapor balancing control), the above table requires that each lightering operation must achieve VOC emission reductions of 20%, 39%, and 57% by May 1 of 2007, 2009, and 2011, respectiv ely, from its baseline

level.

2002 Emission from lightering = 12.90 TPD

2003-2008 reduction = 12.90 x 20% = 2.58 TPD 2008 Projection = 12.90 – 2.58 = 10.32 TPD

B. All Other Sussex Point Sour ces except Lightering Operation25 Since there will be no new VOC controls for these point sources between 2008 and 2009, their 2008 emission reductions and projections are estimated by interpolating the 2002 base year emissions and the 20 09 projections, as shown below.

2009 All-point source emi ssion projection = 7.64 TPD 2009 Lightering emission projection = 7.26 TPD 2009 All other-point source emission less lightering operation = 7.64 – 7.26 = 0.38 TPD

2002 All point source emission = 13.35 TPD 2002 All other-point source emission less lightering operation = 13.35 – 12.90 = 0.45 TPD 2003-2008 Reduction from other sources = (0.45 – 0.38) x 6/7 = 0.06 TPD 2008 All other-point source projection = 0.45 – 0.06 = 0.39 TPD

C. All point sources

2003-2008 Reduction = 2.58 + 0.06 = 2.64 TPD 2008 All point source projection = 13.35 – 2.64 = 10.71 TPD

5.1.2 Kent and New Castle Counties Point S ource Controls and Emission Reductions

A. Facility and unit shutdow n/modification reductions

Emission reduction credits from shutdown f acilities and/or units are identical in

2008 and 2009. Table 5-1 is a list of the facilities and/or units that were shutdown after 2002 and by the end of 2008.

Table 5-1. Emission Reductions fr om Facilities Shutdown after 2002

NOX NOX VOC VOC

Facility Name County 2002

Total 2009

Total 2002

Total 2009

Total

TILCON DELAWARE - HORSEPOND ROAD Kent 0.04 0.00 0.00 0.00

AMETEK INC CHEMICAL PRODUCTS

DIVISION New Castle 0.00 0.00 0.00 0.00

CONECTIV DELMARVA GENERATIONMADISON ST New Castle 0.23 0.00 0.00 0.00

GENERAL CHEMICAL CORPORATION New Castle 0.38 0.00 0.00 0.00
HARDCORE COMPOSITES, DIV. OF HARRIS

SPEC New Castle 0.00 0.00 0.00 0.00

KANEKA DELAWARE CORPORATION New Castle 0.01 0.00 0.05 0.00

LAFARGE NORTH AMERICA INC New Castle 0.32 0.00 0.05 0.00

LAIDLAW CORPORATION New Castle 0.00 0.00 0.14 0.00

METACHEM PRODUCTS LLC New Castle 0.00 0.00 0.00 0.00

OCCIDENTAL CHEMICAL CORPORATION New Castle 0.25 0.00 0.01 0.00

VPI FILM LLC New Castle 0.01 0.00 0.06 0.00

WESTVACO CORPORATION New Castle 0.00 0.00 0.03 0.00

WILMINGTON PIECE DYE CO New Castle 0.01 0.00 0.10 0.00

CITY OF LEWES POWER PLANT Sussex 0.21 0.00 0.01 0.0026 Total = 1.46 0.00 0.44 0.00

Among the above shutdown facilities, some have applie d for and obtained emission reduction credits (ERCs) pursuant to Regulation No. 34, Emission Banking and Trading Program. In addition, where ERCs are certified from a shutdown source Reg. 34 provides for the Delaware Economic Developm ent Office (DEDO) to receive 50% of the credits to use for initiatives to replace lost jobs that occurred due to the shutdown facility (Regulation No. 34, Reference 5-1) . Table 5-2 is a list of th e facilities/agency that hold

ERCs.

Table 5-2. Emission Reduction Cred its and Holding Facilities/Agency

VOC (Tons) NO X (Tons)

ERC Holding Facility/Agency Ozone

Season Non-Ozone

Season Ozone

Season Non-Ozone

Season

Delaware City Industries

DuPont Lafarge Delaware Economic Development

Office (DEDO)

VPI Film LLC

Total 4

0

3

27

6

40 2

0

2

19

4

27 1

7

23

42

1

74 1

5

14

29

1

50

Using 7-month (or 214 days) for the oz one season from April to October as defined in Regulation No. 34 (Reference 5-1), th e credits in Table 5-2 can be converted to ozone-season-daily emissions, as shown below:

Total VOC ERCs (TPD) = 40/214 = 0.19 TPD Total NOx ERCs (TPD) = 74/214 = 0.35 TPD

In addition, the NOx emission rate shall be reduced to 20 ppm for the Cracker Carbon Monoxide Boiler at Premcor Refinery (formerly Motiva Enterp rises) in Delaware City under a Consent Agreement (Reference 5-2) . This consent agreement indicates that

250 TPY of the resultant NOx reductions will remain available for Premcor Refinery to

use as emissions offsets. This results in 250/365 = 0.68 TPD NOx emission credit for Premcor Refinery.

Thus, the total emission reductions from facility/unit shutdown or modification that are available for the SIP planning are:

VOC emission reduction = 0.44 – 0.19 = 0.25 TPD

NOx emission reduction = 1.46 – 0.35-0.68 = 0.43 TPD

The above calculation treats the banked or authorized ERCs as “emitted emissions”

in the context of this SIP revi sion. As such, the future use of these credits is consistent with, and will not interfere with any calculation or provi sion of this SIP document.27 B. All other point sources.

Since there will be no new VOC controls for these point sources between 2008 and 2009, their 2008 emission reductions and projections are estimated by interpolating the 2002 base year emissions and the 20 09 projections, as shown below.

2009 All-point source emission projection = 10.65 TPD 2009 Shutdown facility emissions (ERCs) = 0.19 TPD 2009 All other-point source emission

less shutdown facilities’ emission = 10.65 – 0.19 = 10.46 TPD

2002 All point source em ission = 9.91 TPD 2002 All other-point source emission

less shutdown facilities’ emission = 9.91 – 0.44 = 9.47 TPD 2003-2008 Reduction from other poi nt sources = (9.47 – 10.46) x 6/7 = -0.85 TPD 2008 All other-point source proj ection = 9.47 – (-0.85) = 10.32 TPD

C. All point sources

2003-2008 Reduction = 0.25 + (-0.85) = (-0.60) TPD 2008 All point source project ion = 9.91– (-0.60) = 10.51 TPD

5.2 Non-Point Source VOC Control Measures and Reduction Estimates

Since there will be no new controls in the non-point source sector for VOC emissions between 2008 and 2009, the 2008 emi ssion reductions and projections for the non-point sources are estimated by interpol ating the 2002 base year emissions and the 2009 projections, as shown below.

5.2.1 Sussex County Area Source Cont rols and Emission Reductions

2009 Projection = 6.15 TPD

2002 Emission = 7.31 TPD 2003-2008 Reduction = (7.31 – 6.15) x 6/7 = 0.99 TPD 2008 Projection = 7.31 – 0.99 = 6.32 TPD

5.2.2 Kent and New Castle Counties Area S ource Controls and Emission Reductions

2009 Projection = 20.95 TPD

2002 Emission = 25.77 TPD 2003-2008 Reduction = (25.77 – 20.95) x 6/7 = 4.13 TPD 2008 Projection = 25.77 – 4.13 = 21.64 TPD

5.3 Non-Road Mobile Sources VOC Control Measures and Reduction Estimates

Since there will be no new controls in th e non-road mobile source sector for VOC emissions between 2008 and 2009, the 2008 emi ssion reductions and projections for the non-road mobile sources are estimated by inte rpolating the 2002 base year emissions and the 2009 projections, as shown below.28 5.3.1 Sussex County Non-Road Mobile Sour ce Controls and Emission Reductions

2009 Projection = 7.78 TPD

2002 Emission = 9.36 TPD 2003-2008 Reduction = (9.36 – 7.78) x 6/7 = 1.35 TPD 2008 Projection = 9.36 – 1.35 = 8.01 TPD

5.3.2 Kent and New Castle Counties Non-Road Mobile Source Controls and Emission

Reductions

2009 Projection = 13.21 TPD

2002 Emission = 17.41 TPD 2003-2008 Reduction = (17.41 – 13.21) x 6/7 = 3.60 TPD 2008 Projection = 17.41 – 3.60 = 13.81 TPD

5.4 On-Road Mobile Source VOC Control Measures and Reduction Estimates

The 2008 on-road mobile source VOC em issions were projected using EPA’s MOBILE6.2 for obtaining emission factors an d the “Peninsula Travel Demand Model (PTDM)” for predicting future vehicle miles traveled (VMT). The MOBILE6.2 runs were conducted by AQM’s staff using the most rece nt available vehicle registration data and speed estimates (2005). The PTDM runs were conducted by staff of Delaware Department of Transportation (DelDOT). Details of the rele vant model runs are presented in Section 9 and Appendix 9-1of this document.

5.4.1 Sussex County On-Road Mobile Source Emission Projections and Reductions

2002 Emission = 9.95 TPD 2008 MOBILE6.2 Projection = 7.09 TPD

2003-2008 Reduction = 9.95 – 7.09 = 2.86 TPD

5.4.2 Kent and New Castle Counties On-Road Mobile Source Emi ssion Projections and

Reductions

2002 Emission = 22.43 TPD 2008 MOBILE6.2 Projection = 14.75 TPD

2003-2008 Reduction = 22.43 – 14.75 = 7.68 TPD

5.4.3 Delaware 2008 On-Road Mobile Source NOx Emission Projections and Reductions

The 2008 on-road mobile source NOx emissions were projected using the same methods as for the VOC projections. The results are summarized below:

Sussex County

2002 NOx Emission = 18.59 TPD 2008 MOBILE6.2 Projection = 12.86 TPD

2003-2008 Reduction = 18.95 – 12.86 = 6.09 TPD

Kent and New Castle Counties

2002 NOx Emission = 50.53 TPD29 2008 MOBILE6.2 Projection = 31.03 TPD

2003-2008 Reduction = 50.53 – 31.03 = 19.50 TPD

The above NOx reduction estimates for 2008 will serve for the 2008 contingency purpose, as discussed in Subsec tion 10.1 of this SIP revision.

5.5 Total VOC Emission Reducti ons for 2003-2008 RFP Requirements

5.5.1 Sussex County Total 2008 VOC Emission Projection

Point Source Sector = 10.71 TPD

Area Source Sector = 6.32 TPD

Non-Road Mobile Sector = 8.01 TPD

On-Road Mobile Sector = 7.09 TPD Total 2008 Emission Projection 32.13 TPD

The total VOC emission projection meets the 2008 emission targ et under the 15% RFP requirements (33.00 TPD). Therefor e, the 2008 RFP in Sussex County is

demonstrated.

5.5.2 Kent and New Castle Counties Total VOC Emission Reductions

Point Source Sector = 10.51 TPD

Area Source Sector = 21.64 TPD

Non-Road Mobile Sector = 13.81 TPD

On-Road Mobile Sector = 14.75 TPD Total 2008 Emission Projection 60.71 TPD

The total VOC emission projection meets the 2008 emission targ et under the 15% RFP requirements (61.66 TPD). Therefore, the 2008 RFP in Kent and New Castle

Counties is demonstrated.

References

5-1. Regulations Governing the Control of Air Pollution No. 34 Emission Banking and Trading Program , Air Quality Management Secti on, Division of Air and Waste Management, Delaware Department of Natural Resources and Environmental Control, Dover, Delaware, October 1997.

5-2. Consent Decree, United States District Court for th e Southern District of Texas,

Delaware/Louisiana v. Motiva Ente rprises, LLC, March 2001, and Addendums to the

Consent Decree , December 2003 and June 200430 6. Control Measures and Emission Projections for Attainment

In Section 5 of this document, Delawa re demonstrates that post-2002 emission controls will satisfy 2003-2008 RFP requireme nts. However, reductions in VOC

emissions alone do not result in attainment of the ground level ozone NAAQS. Emissions of another major precursor, i.e ., NOx, must also be reduced. For this reason, Delaware has implemented controls over a va riety of NOx emission sources prior to the ozone season of

2009 to ensure attainment.

The 2009 emission projections for non-EG U point sources, non-point sources (formerly termed as “area sources”), and non-ro ad mobile sources have been conducted by MACTEC Federal Programs, In c. (hereafter referred to as MACTEC). The 2009 emission projections are explained in MACTEC’s t echnical supporting document (Appendix 6-1). Delaware is basing its 2009 emission projection on this work conducted by MACTEC. However, the 2009 projections made by MACTEC have been updated in some cases for the following reasons:

(1) Delaware 2002 base year emission updates; (2) Delaware specific growth factors; (3) Control factor (CE, RE, etc) updates; (4) Additional controls.

When any of the above reasons beco mes valid, Delaware amended the 2009 projection(s) for the involved sources or source category, calcu lated its specific projections, and provides immedi ate or documentary explanati ons at appropriate locations

in this document.

Delaware projected 2009 EGU emission as follows. The MANE-VU 2002 point source inventory contains a cross-reference table that matches IPM emission unit identifiers (ORISPL plant code and BL RID emission unit code) to MANE-VU NIF emission unit identifiers (FIPSST state co de, FIPSCNTY county code, State Plant ID, State Point ID). Initially, MACTEC used this cross-reference table to split the point source file into the EGU and non-EGU componen ts. When there was a match between the

IPM ORISPL/BLRID and the MANE-VU emissi on unit ID, the unit wa s assigned to the EGU inventory; all other emission units were assigned to th e non-EGU inventory.

After performing this initial splitting of the MANE-VU point source inventory into EGU and non-EGU components, MACTEC prep ared 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 acc ounted for in IPM. This list of emission units to the non-EGU inventory derived fr om the MANE-VU cross-reference table

was verified so that units accounted fo r in IPM were not double-counted in the non-EGU inventory.

• The non-EGU inventory was reviewed to iden tify remaining emission units with an 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 mee ting these selection criteria was then31compared to the IPM parsed file to ensure that these units were not doublecounted.

• 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. We determined that the

sum of the number of records in the EGU file and the number of records in the non-EGU file equaled the number of records in the original 2002 point source file.

• We compared the emissions by pollutant in the original 2002 poi nt source file to

the 2002 EGU file and 2002 non-EGU files. We determined that the sum of the emissions in the EGU file and the emissions in the non-EGU file equaled the emissions in the origin al 2002 point source file.

As a result of this procedure, MACTEC cr eated separate sets of NIF tables for 2002 for EGUs (i.e., units accounted for in IPM) and non-EGUs. The non-EGU set of

2002 NIF tables were used in all su bsequent projections for 2009/2012/2018.

After reviewing the IPM results, AQM S found that the projections were unrealistic. For instance, IPM predicted all oil-burning EGUs would have no emissions in 2009. We know from regular inte raction with these facilities that those units will be operating for the foreseeable future. Therefore, we discarded the IPM method and reprojected EGU emissions using Department of Energy growth factors. Afterwards, Delaware-specific controls from post-2002 regula tions were applied. The source of data for determining growth was: Energy Info rmation Administration (EIA), Annual Energy Review 2004 (mid-Atlantic), DOE /EIA-0384 (2004) (Washington, DC, August 2005). Using 2002 as the baseline, 2009 grow th factors were derived by taking 2009 projected energy consumption by sector and source (quadrilli on Btu), and then dividing that by 2003 growth rates. Controls were applied on a unit by unit basis, via the regulations listed in Table 6.1.

Finally, the 2009 mobile source emission projections were conducted by AQMS

staff. The methods are discussed in S ection 6.4 and Section 9 of this document.

6.1 Point Source Controls and 2009 Emission Projections

The following is a list of controls that Delaware has adopted or proposed to adopt prior to the 2009 ozone season, and therefor e will lead to VOC and/or NOx emission reduction prior to the 2009 ozone season:

(1). Reg. 24. Sec. 46, Crude Oil Lighte ring Operations, VOC emission control, Sussex County, Effective May 2007; (2). Reg. 1144, Control of Stationary Generator Emissions, VOC and NOx emission control, State-wide, Effective January 2006; (3). Reg. 1146, EGUs, Electric Generating Unit (EGU) Multi-Pollutant Regulation, NOx emission control, Stat e-wide, Effective 12/11/07; (4). Regulation No. 1148, Control of Stationary Combustion Turbine Electric Generating Unit Emissions, NOx emission control, State-wide, Proposed rule. (5) Regulation 1142, Section 1, Control of NOx Emissions From Industrial Boilers, NOX emission control, Effective December 2001. (6). Regulation 1142, Section 2, Control of NOx Emissions From Industrial Boilers

and Process Heaters at Petroleum Re fineries, NOx emission control, New Castle County, to be effective July 2007.32 (7) Consent Decree with Premcor Refinery at Delaware City (formerly Motiva Enterprises), New Castle County, Contro l of NOx Emission from Boilers and Heaters, Effective 2008. (8) Control of NOx Emissions from Large Industrial Boile rs and Process Heaters at Non-Refinery Facilities, NOx emission control, State-wide, under development and to be adopted in May 2008 w ith compliance date of May 1, 2009.

In addition to the above controls and rules, a number of point source facilities or

units in those facilities ha ve been shutdown after 2002, as indicated in Table 5-1 in Section 5. Also, the Cracker Carbon Monoxide Boiler at Premcor Refinery in Delaware City will be modified to a NOx emission rate limit of 20 ppm. The shutdowns and

modification will lead to 0.25 TPD VOC reductions and 0.43 TPD NOx reductions, as

indicated in Subsection 5.1 of this document.

The following tables are summaries of Delaware 2009 EGU and non-EGU emission projections:

• Table 6-1 is a summery of Delaware 2009 projection of emissions from electric generating units (EGUs), projected by AQMS staff using the procedure

detailed in the above introduction to Section 6 of this document, and Regulations 1144, 1146, and 1148 as c ontrols (Reference 6-1).

• Table 6-2 is a summary of Delawa re 2009 VOC emissions from non-EGU point sources, where MACTEC’s proj ections are revise d by AQMS staff. Reasons for such revisions are provided in the footnotes of Table 6-2. Projections that are not changed are provided in Appendix 6-2, documented in MACTECs final report (Appendix 6-1).

• Table 6-3 is a summary of Delaware 2009 NOx emissions from non-EGU point sources, where MACTEC’s projections are revised by AQMS staff. Reasons for such revisions are provided in the footnotes of Table 6-3. Projections that are not changed are provid ed in Appendix 6-2, documented in MACTECs final report (Appendix 6-1).

• Table 6-4 is a summary of Delaware 2009 VOC and NOx emissions from nonEGU point sources, where MACTEC’s proj ections are not revised. Details of emission projections are provided in Appendix 6-1 and Appendix 6-2.

• Table 6-5 is a summary of Delaware 2009 VOC and NOx Emissions from All

Point Sources.33Table 6-1. Delaware 2009 VOC and NOxEmission Projections (TPD) for Electric Generating Units (EGUs)Facility NameUnit DescriptionPost 2002 RegulationNOX VOCCITY OF DOVER - MCKEE RUN GENERATING STA BOILER #1None*0.427 0.006CITY OF DOVER - MCKEE RUN GENERATING STA BOILER #2None0.364 0.006CITY OF DOVER - MCKEE RUN GENERATING STA BOILER #3Regulation No. 1146 (Effective12/11/07) 0.896 0.022CITY OF DOVER VAN SANT GENERATING STA UNIT #11 GAS TURBINENone0.081 0.001NRG ENERGY CENTER DOVER LLCCOGENERATION BOILERNone1.607 0.000NRG ENERGY CENTER DOVER LLCTURBINE #1None0.147 0.000NRG ENERGY CENTER DOVER LLCTURBINE #2None0.112 0.000WARREN F BEASLEY POWER STATIONCOMBUSTION TURBINENone0.050 0.002CONECTIV DELMARVA GENERATION-DEL CITY TURBINE #10Regulation No. 1148 (Proposed) 0.092 0.000CONECTIV DELMARVA GENERATION-WEST_SUBST TURBINERegulation No. 1148 (Proposed) 0.066 0.000CONECTIV DELMARVA GENERATION-EDGE MOOR GAS TURBINERegulation No. 1148 (Proposed) 0.091 0.000CONECTIV DELMARVA GENERATION-EDGE MOOR BOILER #3Regulation No. 1146 (Effective12/11/07)1.633 0.029CONECTIV DELMARVA GENERATION-EDGE MOOR BOILER # 4Regulation No. 1146 (Effective12/11/07) 2.731 0.040CONECTIV DELMARVA GENERATION-EDGE MOOR BOILER # 5Regulation No. 1146 (Effective12/11/07) 6.529 0.188MOTIVA ENTERPRISES LLC - DELAWARE CITY BOILER 4Regulation No. 1142, Section 2.0(Proposed)0.862 0.009MOTIVA ENTERPRISES LLC - DELAWARE CITY BOILER 1Regulation No. 1142, Section 2.0(Proposed) 0.171 0.000MOTIVA ENTERPRISES LLC - DELAWARE CITY BOILER 2Regulation No. 1142, Section 2.0(Proposed) 0.133 0.010MOTIVA ENTERPRISES LLC - DELAWARE CITY BOILER 3Regulation No. 1142, Section 2.0(Proposed)0.819 0.000MOTIVA ENTERPRISES LLC - DELAWARE CITY REPOWERING CT1None0.618 0.042MOTIVA ENTERPRISES LLC - DELAWARE CITY REPOWERING CT2None0.224 0.011CONECTIV DELMARVA GENERATION-CHRISTIANA TURBINE #11Regulation No. 1148 (proposed) 0.150 0.000CONECTIV DELMARVA GENERATION-CHRISTIANA TURBINE #14Regulation No. 1148 (proposed) 0.155 0.000CONECTIV DELMARVA GENERATION-HAY ROAD COMBUSTION TURBINE #1None0.594 0.019CONECTIV DELMARVA GENERATION-HAY ROAD COMBUSTION TURBINE #2None0.858 0.02034CONECTIV DELMARVA GENERATION-HAY ROAD COMBUSTION TURBINE #3None1.289 0.020CONECTIV DELMARVA GENERATION-HAY ROAD COMBUSTION TURBINE #5None0.246 0.001CONECTIV DELMARVA GENERATION-HAY ROAD COMBUSTION TURBINE #6None0.502 0.001CONECTIV DELMARVA GENERATION-HAY ROAD COMBUSTION TURBINE #7None0.356 0.001INDIAN RIVER GENERATING STATIONBOILER #1Regulation No. 1146 (Effective12/11/07) 1.0380.020INDIAN RIVER GENERATING STATIONBOILER # 2Regulation No. 1146 (Effective12/11/07) 1.1830.021INDIAN RIVER GENERATING STATIONBOILER # 3Regulation No. 1146 (Effective12/11/07)1.966 0.038INDIAN RIVER GENERATING STATIONBOILER # 4Regulation No. 1146 (Effective12/11/07) 4.8600.079INDIAN RIVER GENERATING STATIONTURBINE #10None0.096 0.000INVISTA BOILER#1None1.741 0.005INVISTA BOILER#2None2.358 0.005INVISTA BOILER#3None2.226 0.005CITY OF LEWES POWER PLANTCATERPILLER ELEC PK #1Regulation No. 1144 (Effective1/11/06) 0.0000.000CITY OF LEWES POWER PLANTCATERPILLER ELEC PK #2Regulation No. 1144 (Effective1/11/06)0.000 0.000CITY OF SEAFORD-ELECTRIC POWER PLANTGENERATOR #1Regulation No. 1144 (Effective1/11/06) 0.0000.000CITY OF SEAFORD-ELECTRIC POWER PLANTGENERATOR #2Regulation No. 1144 (Effective1/11/06) 0.0000.000CITY OF SEAFORD-ELECTRIC POWER PLANTGENERATOR #3Regulation No. 1144 (Effective1/11/06)0.000 0.000CITY OF SEAFORD-ELECTRIC POWER PLANTGENERATOR #4Regulation No. 1144 (Effective1/11/06) 0.0000.000CITY OF SEAFORD-ELECTRIC POWER PLANTGENERATOR #6Regulation No. 1144 (Effective1/11/06) 0.0000.000Total 37.27 0.61* Indicating that the unit was not affected by post-2002 control or rule when calculating 2009 projection.35Table 6-2. Delaware 2009 VOC Emission Projections (TPD) forNon-EGU Point Sources Revisedfrom MACTEC’s ProjectionsCounty Facility NameUnit DescriptionReason (See Notes) VOC TPDKentDOVER AIR FORCE BASEBOILER #1/CENT HTNG PLANT I0.00PROCTOR AND GAMBLE DOVER WIPES COMPANY BOILER #1VIII0.00TILCON DELAWARE - HORSEPOND ROADASPHALT HOT MIX PLANTIII0.00BAYHEALTH MED CENTER KENT GENERAL HOSP 1275 KW EMERENCY GENERVI0.00DE SOLID WASTE AUTHORITY SANDTOWNLANDFILLI0.02New Castle DUPONT EXPERIMENTAL STATION ELECTRICALGENERATOR VI 0.01DUPONT EXPERIMENTAL STATION3 CATALYTIC CONVERTERSIX0.00GENERAL MOTORS CORPORATIONBOILER #1X0.00GENERAL MOTORS CORPORATIONBOILER #5X0.00GENERAL MOTORS CORPORATIONELPO BATHV0.04GENERAL MOTORS CORPORATIONELPO PRIM. OVENS & HTRSX0.02GENERAL MOTORS CORPORATIONPRIMER SURFACER BOOTHX0.00GENERAL MOTORS CORPORATIONPRIMER SURFACER BOOTHV0.17GENERAL MOTORS CORPORATIONPRIMER SURFACER OVENX0.01GENERAL MOTORS CORPORATIONMOD SHOP BOOTHSX1.98GENERAL MOTORS CORPORATIONMOD SHOP BOOTHSV0.00GENERAL MOTORS CORPORATIONMOD SHOP OVENSX0.04GENERAL MOTORS CORPORATIONDEADNER BOOTHX0.00GENERAL MOTORS CORPORATIONFINAL REPAIR AREAX0.00GENERAL MOTORS CORPORATIONFINAL REPAIR AREAV0.03GENERAL MOTORS CORPORATIONMISC. SOURCESX0.00GENERAL MOTORS CORPORATIONMISC. SOURCESV1.19GENERAL MOTORS CORPORATION40,000 GAL GASOLINE TANKX0.02GENERAL MOTORS CORPORATIONELPO/TOPCOAT RTOX0.00GENERAL MOTORS CORPORATION PRIMER/SRUFACERRTO X 0.00GENERAL MOTORS CORPORATIONSEALER CURE OVENX0.03GENERAL MOTORS CORPORATIONBODY WASHER OVEN #1X0.00GENERAL MOTORS CORPORATIONBODY WASHER OVEN #2X0.00SUNCO INC R MBOILER #2I0.00CHRISTIANA CARE - WILMINGTON HOSPITALPEAKING UNIT #1IX0.0036FORMOSA PLASTICS CORPORATION INCINERATORSWB710/711 I 0.04LAIDLAW CORPORATIONCAPING MACHINE # 1III0.00LAIDLAW CORPORATIONLATEX APPPLN ON TUBESIII0.00LAIDLAW CORPORATIONTUBE LAMINATINGIII0.00LAIDLAW CORPORATION3 LANE HANGER LINEIII0.00LAIDLAW CORPORATIONSTRAIGHT & CUT (S&C) # 1III0.00AMETEK INC CHEMICAL PRODUCTS DIVISIONBOILER 2III0.00AMETEK INC CHEMICAL PRODUCTS DIVISIONRESIN MANUFACTURINGIII0.00AMETEK INC CHEMICAL PRODUCTS DIVISIONHAVEG 41/61 TANK MANUFACT III0.00AMETEK INC CHEMICAL PRODUCTS DIVISIONPHENOL TANKIII0.00AMETEK INC CHEMICAL PRODUCTS DIVISION SILTEMP-WEBCOATER III 0.00AMETEK INC CHEMICAL PRODUCTS DIVISIONDEGREASERIII0.00AMETEK INC CHEMICAL PRODUCTS DIVISIONSILTEMP - HCL FILL TANKSIII0.00AMETEK INC CHEMICAL PRODUCTS DIVISIONSILTEMP - ACID DIGESTERSIII0.00AMETEK INC CHEMICAL PRODUCTS DIVISIONHCL MIX TANK/NEUT. TANKIII0.00AMETEK INC CHEMICAL PRODUCTS DIVISIONOBNOXIOUS FUME SCRUBBER III0.00OCCIDENTAL CHEMICAL CORPORATIONBOILER #2VIII0.00OCCIDENTAL CHEMICAL CORPORATIONBOILER #5VIII0.00OCCIDENTAL CHEMICAL CORPORATIONCHLORINE LIQUIFICATIONVIII0.00ROHM & HAAS ELECTRONIC MATERIALSCMP TE B2 EMERGENCY GENERATOR VI0.00ROHM & HAAS ELECTRONIC MATERIALSCMP TE B5 EMERGENCY GENERATOR VI0.00FP INTERNATIONAL INCEXTRUDER LINE #1I0.10FP INTERNATIONAL INCEXTRUDER RECYCLE LINE #3 I0.00VETERANS ADMINISTRATION HOSPSITAL BOILER#1I 0.00VETERANS ADMINISTRATION HOSPSITAL5 DIESEL GENERATORSVI0.00CHRISTIANA CARE - CHRISTIANA HOSPITALPEAKING UNIT #1II0.23DE SOLID WASTE AUTHORITY PIGEON POINTLANDFILLI0.01DE SOLID WASTE AUTHORITY CHERRY ISLAND FUGITIVE VOCS - LANDFILLI0.04WESTVACO CORPORATIONWEB OFF-SET PRINTINGIII0.00WESTVACO CORPORATIONPARTS WASHERSIII0.00DAIMLERCHRYSLER CORPORATIONECOAT PRIMER BOOTHXI0.03DAIMLERCHRYSLER CORPORATIONMISC. PRODUCTIVE ITEMSXI0.2237DAIMLERCHRYSLER CORPORATIONPOWER ANTI CHIP BOOTHXI0.00DAIMLERCHRYSLER CORPORATIONCOLOR 1&2 TOP COAT BOOTHS XI0.86DAIMLERCHRYSLER CORPORATIONLO BAKE REPAIR BOOTHXI0.03DAIMLERCHRYSLER CORPORATIONTOUCH UP AREAXI0.00DAIMLERCHRYSLER CORPORATIONNON-PRODUCTIVEXI0.56DAIMLERCHRYSLER CORPORATIONPH EMERG DIESEL GEN 1VI0.00DAIMLERCHRYSLER CORPORATIONPH EMERG. DIESEL GEN 2VI0.00DUPONT STINE - HASKELL LABORATORYEMERGENCY DIESEL GEN. #1VI0.00DUPONT STINE - HASKELL LABORATORYEMERGENCY DIESEL GEN. #2VI0.00SPATZ FIBERGLASS PRODUCTSMANUFACTURING OF PLASTIC I0.00DELAWARE RECYCLABLE PRODUCTS INCLANDFILL WASTE GASI0.01PURE GREEN INDUSTRIESINC DIESELGENERATOR VI 0.00GE ENERGY (USA) LLCSINGLE CRYSTAL LINEI0.01HARDCORE COMPOSITES, DIV. OF HARRIS SPEC DATASIII0.00Sussex ORIENT CORPORATION OF AMERICAFACILITY FUGITIVESI0.01BAYHEALTH MEDICAL CTR - MILFORD MEMORIAL 600 KW EMERCENCY GENVI0.00PERDUE FARMS INC - GEORGETOWNEMERGENCY GENERATORVI0.00MARITRANSLIGHTERING OPERATIONIV7.26EDWARD J. KAYE CONSTRUCTIONCRUSHER DIESEL ENGINEI0.00Total State Projection12.98Notes:I.Delaware’s 2002 emissions for this individual record were different than the MACTEC 2002 emissions. To obtain a Delaware-specific projected 2009 emission,Delaware’s actual 2002 emissions for this individual record were grown and controlled using the same methodology as MACTEC in its 2009 projection for thisrecord.II.These units will be retrofitted by 2009 to be bi-fuel operated onnatural gas and diesel fuel. Thus, Delaware has projected these unit’s 2009 emissions using the samegrowth factor as used by MACTEC, and controls based upon the emission standards required by Reg. 1144.III.This facility was shutdown after 2002, and its emissions werezeroed out, since the MACTEC 2009 projection inventory did not include this facility as beingshutdown.IV.Delaware reevaluated the VOC emission reductions due to adopting a regulation to control lightering, and estimated that a control efficiency of 39% would be moreaccurate. Thus, Delaware has projected the 2009 VOC emissions from lightering using the same growth factor as used by MACTEC and this new control efficiency.V.The MACTEC 2009 projected emissions for this unit include a reduction due to MACT controls. Delaware does not believe that MACT controls are installed on thisunit. Additionally, the facility operated well below its capacityin 2002. Thus, Delaware has projected this unit’s 2009 emissions using a growth factor estimated byDelaware, and without assuming any MACT controls.38VI.Due to the requirements of Regulation No. 1144, Delaware assumes no growth or control of the emissions of this unit, and assumes its projected 2009 emissions to beequal to its 2002 emissions.VIII.This unit was shutdown after 2002, and its emissions were zeroed out, since the MACTEC 2009 projection inventory did not include this unit as being shutdown.IX.This unit was classified as a “distributed generator,” and was subject to emission controls, under Regulation No. 1144. However, the facility chose to reclassify theunit as an “emergency generator” instead of installing controls. Thus, Delaware has zeroed out its projected 2009 emissions since its expected operation as anemergency generator shall yield few, if any, ozone season emissions.X.The facility operated well below its capacity in 2002. Thus,Delaware has projected this unit’s 2009 emissions using a growthfactor estimated by Delaware.XI.The MACTEC 2009 projected emissions for this unit include a reduction due to MACT controls. Delaware does not believe that MACT controls are installed on thisunit. Thus, Delaware has projected this unit’s 2009 emissions using the same growth factor as used by MACTEC, but without assuming any MACT controls.39Table 6-3. Delaware 2009 NOx Emission Projections (TPD) forNon-EGU Point Sources Revised from MACTECs ProjectionsCountyFacility NameUnit Desc.Reason (See Notes) NOx TPDKentDOVER AIR FORCE BASEBOILER #1/CENT HTNG PLANT I0.00PROCTOR AND GAMBLE DOVER WIPES COMPANYBOILER #1VIII0.00TILCON DELAWARE - HORSEPOND ROADASPHALT HOT MIX PLANT III0.00BAYHEALTH MED CENTER KENT GENERAL HOSP1275 KW EMERENCY GENER VI0.01New Castle DUPONT EXPERIMENTAL STATION ELECTRICALGENERATOR VI0.11DUPONT EXPERIMENTAL STATION3 CATALYTIC CONVERTERS IX0.00GENERAL MOTORS CORPORATIONBOILER #1X0.05GENERAL MOTORS CORPORATIONBOILER #5X0.03GENERAL MOTORS CORPORATIONELPO PRIM. OVENS & HTRS X0.02GENERAL MOTORS CORPORATIONPRIMER SURFACER BOOTH X0.01GENERAL MOTORS CORPORATIONPRIMER SURFACER OVEN X0.00GENERAL MOTORS CORPORATIONMOD SHOP BOOTHSX0.03GENERAL MOTORS CORPORATIONMOD SHOP OVENSX0.01GENERAL MOTORS CORPORATIONDEADNER BOOTHX0.01GENERAL MOTORS CORPORATIONFINAL REPAIR AREAX0.02GENERAL MOTORS CORPORATIONMISC. SOURCESX0.01GENERAL MOTORS CORPORATIONELPO/TOPCOAT RTOX0.03GENERAL MOTORS CORPORATION PRIMER/SRUFACERRTOX 0.02GENERAL MOTORS CORPORATIONSEALER CURE OVENX0.00GENERAL MOTORS CORPORATIONBODY WASHER OVEN #1 X0.00GENERAL MOTORS CORPORATIONBODY WASHER OVEN #2 X0.00MOTIVA ENTERPRISES LLC - DELAWARE CITYHEATER #2 FOR UNIT 21-H-2 VII0.06MOTIVA ENTERPRISES LLC - DELAWARECITYREPOWER - CLEAN GAS FLARE I0.42CHRISTIANA CARE - WILMINGTON HOSPITALPEAKING UNIT #1IX0.00AMETEK INC CHEMICAL PRODUCTS DIVISIONBOILER 2III0.00OCCIDENTAL CHEMICAL CORPORATIONBOILER #2VIII0.00OCCIDENTAL CHEMICAL CORPORATIONBOILER #5VIII0.00GENERAL CHEMICAL CORPORATIONNITRITES PRODUCTION I0.00ROHM & HAAS ELECTRONIC MATERIALSCMP TEB2 EMERGENCY GENERATOR VI0.00ROHM & HAAS ELECTRONIC MATERIALSCMP TEB5 EMERGENCY GENERATOR VI0.0640CONECTIV DELMARVA GENERATION-MADISON STGAS TURBINEIII0.00VETERANS ADMINISTRATION HOSPSITAL BOILER#1 I 0.00VETERANS ADMINISTRATION HOSPSITAL5 DIESEL GENERATORS VI0.01CHRISTIANA CARE - CHRISTIANA HOSPITALPEAKING UNIT #1II0.43DE SOLID WASTE AUTHORITY PIGEON POINTLANDFILLI0.00MACDERMID INCCOATING LINEI0.00DAIMLERCHRYSLER CORPORATIONPH EMERG DIESEL GEN 1 VI0.01DAIMLERCHRYSLER CORPORATIONPH EMERG. DIESEL GEN 2 VI0.01DUPONT STINE - HASKELL LABORATORYEMERGENCY DIESEL GEN. #1 VI0.05DUPONT STINE - HASKELL LABORATORYEMERGENCY DIESEL GEN. #2 VI0.06PURE GREEN INDUSTRIESINC DIESELGENERATORVI0.04SussexBAYHEALTH MEDICAL CTR - MILFORD MEMORIAL600 KW EMERCENCY GEN VI0.03PERDUE FARMS INC - GEORGETOWNEMERGENCY GENERATOR VI0.00EDWARD J. KAYE CONSTRUCTIONCRUSHER DIESEL ENGINE I0.02Total State Projection1.60Notes:I.Delaware’s 2002 emissions for this individual record were different than the MACTEC 2002 emissions. To obtain a Delaware-specific projected 2009 emission,Delaware’s actual 2002 emissions for this individual record were grown and controlled using the same methodology as MACTEC in its 2009 projection for this record.II.These units will be retrofitted by 2009 to be bi-fuel operated onnatural gas and diesel fuel. Thus, Delaware has projected these unit’s 2009 emissions using the samegrowth factor as used by MACTEC, and controls based upon the emission standards required by Reg. 1144.III.This facility was shutdown after 2002, and its emissions werezeroed out, since the MACTEC 2009 projection inventory did not include this facility as being shutdown.VI.Due to the requirements of Regulation No. 1144, Delaware assumes no growth or control of the emissions of this unit, and assumes its projected 2009 emissions to beequal to its 2002 emissions.VII.Delaware’s proposed amendments to Regulation No. 1142, Section 2.0 will control the emissions from this unit once adopted. Thus, Delaware has projected this unit’s2009 emissions using the same growth factor as used by MACTEC, and an assumed 80% reduction in NOx from the unit’s current permit limits.VIII.This unit was shutdown after 2002, and its emissions were zeroed out, since the MACTEC 2009 projection inventory did not include this unit as being shutdown.IX.This unit was classified as a “distributed generator,” and was subject to emission controls, under Regulation No. 1144. However, the facility chose to reclassify the unitas an “emergency generator” instead of installing controls. Thus, Delaware has zeroed out its projected 2009 emissions since its expected operation as an emergencygenerator shall yield few, if any, ozone season emissions.X.The facility operated well below its capacity in 2002. Thus,Delaware has projected this unit’s 2009 emissions using a growthfactor estimated by Delaware.41 Table 6-4. Delaware 2009 VOC and NOx Emi ssion Projections (TPD) for Non-EGU Point Sources Not Revised from MACTEC’s Projections

Non-EGU Emissions County FIPS VOC NOx

Kent 10001 0.34 0.53

New Castle 10003 4.17 9.91

Sussex 10005 0.20 1.02

State-Total 4.70 11.46

Table 6-5. Delaware 2009 VOC and NOx Emission Projections (TPD) for All Point

Sources

EGU Emissions Non-EGU Emissions Total Emission County FIPS VOC NOx VOC NOx VOC NOx

Kent 10001 0.04 3.68 0.36 0.55 0.39 4.23

New Castle 10003 0.39 18.12 9.86 11.44 10.25 29.57

Sussex 10005 0.17 15.47 7.47 1.08 7.64 16.54

State-Total 0.61 37.27 17.68 13.07 18.28 50.34

6.2 Non-Point Source Controls and 2009 Emission Projections

The following is a list of non-point source controls that Delaware has adopted or proposed to adopt prior to the 2009 ozone seas on, and therefore will lead to VOC and/or NOx emission reduction prior to the 2009 ozone season:

(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 Contai ners, 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. (6) Reg. 24 Sec. 36, Stage II Vapor Recove ry, VOC Emission control, State-wide, Effective January 2002. (7) Federal Residential Woodstove N SPS, VOC and NOx emission control. (8) Reg. 1113, Open Burning, VOC and NOx emission control, State-wide, Revised and Effective April 2007.

The following tables are summaries of Delaware 2009 emission projections for non-point sources:

• Table 6-6 is a summary of Delaware 2009 VOC emissions from non-point sources, where MACTEC’s projections ar e revised by AQM staff. Reasons for such revisions are provided in the footnotes of Table 6-6.42 • Table 6-7 is a summary of Delaware 2009 NOx emissions from non-point sources, where MACTEC’s projections are revised by AQMS staff. Reasons for such revisions are provided in the footnotes of Table 6-7.

• Table 6-8 is a summary of Delaware 2009 VOC and NOx emissions from nonpoint sources, where MACTEC’s proj ections are not revised. Details of emission projections are provided in Appendix 6-1 and Appendix 6-2.

• Table 6-9 is a summary of Delaware 2009 VOC and NOx Emissions from All

Point Sources.43Table 6-6. Delaware 2009 VOC Emission Projections (TPD) for Non-Point Sources Revised from MACTECs Projections2009 VOC Emissions(TPD)SCC SCC_L1 SCC_L2SCC_L3 SCC_L4Reason(See Notes)KentNewCastleSussex2102002000Stationary Source FuelCombustion IndustrialBituminous/SubbituminousCoal Total: All Boiler Types I 0.00 0.00 0.002102004000Stationary Source FuelCombustion Industrial Distillate OilTotal: Boilers and ICEngines I 0.00 0.00 0.002102006000Stationary Source FuelCombustionIndustrial Natural GasTotal: Boilers and ICEnginesI 0.01 0.04 0.022102007000Stationary Source FuelCombustion IndustrialLiquified Petroleum Gas(LPG) Total: All Boiler Types I 0.00 0.00 0.002103001000Stationary Source FuelCombustionCommercial/Institutional Anthracite Coal Total: All Boiler Types I 0.00 0.00 0.002103004000Stationary Source FuelCombustion Commercial/Institutional Distillate OilTotal: Boilers and ICEngines I 0.00 0.00 0.002103006000Stationary Source FuelCombustion Commercial/Institutional Natural GasTotal: Boilers and ICEngines I 0.00 0.02 0.002103007000Stationary Source FuelCombustionCommercial/InstitutionalLiquified Petroleum Gas(LPG)Total: All CombustorTypesI 0.00 0.00 0.002104002000Stationary Source FuelCombustion ResidentialBituminous/SubbituminousCoalTotal: All CombustorTypes I 0.00 0.00 0.002104004000Stationary Source FuelCombustion Residential Distillate OilTotal: All CombustorTypes I 0.00 0.01 0.002104006000Stationary Source FuelCombustionResidential Natural GasTotal: All CombustorTypesI 0.00 0.02 0.002104007000Stationary Source FuelCombustion ResidentialLiquified Petroleum Gas(LPG)Total: All CombustorTypes I 0.00 0.00 0.012104008000Stationary Source FuelCombustion Residential WoodTotal: Woodstoves andFireplaces IV0.02 0.04 0.032104008070Stationary Source FuelCombustion Residential WoodOutdoor Wood BurningEquipment IV 0.02 0.05 0.032104011000Stationary Source FuelCombustion Residential Kerosene Total: All Heater Types I 0.00 0.00 0.002401005500 Solvent Utilization Surface Coating Auto Refinishing:SIC Surface Preparation IX 0.00 0.01 0.00447532 Solvents2401005600 Solvent Utilization Surface CoatingAuto Refinishing: SIC7532Primers IX 0.02 0.16 0.052401005700 Solvent Utilization Surface CoatingAuto Refinishing: SIC7532 Top Coats IX 0.04 0.29 0.072401005800 Solvent Utilization Surface CoatingAuto Refinishing: SIC7532 Clean-up Solvents IX 0.00 0.04 0.012401008000 Solvent Utilization Surface Coating Traffic MarkingsTotal: All SolventTypesI 0.12 0.212401045000 Solvent Utilization Surface Coating Metal Coils: SIC 3498Total: All SolventTypes I 0.032401075000 Solvent Utilization Surface Coating Aircraft: SIC 372Total: All SolventTypes I 0.002415100000 Solvent Utilization DegreasingAll Industries: Open TopDegreasingTotal: All SolventTypesI 0.01 0.09 0.022415130000 Solvent Utilization DegreasingElectronic and Other Elec.(SIC 36): Open TopDegreasingTotal: All SolventTypes I 0.00 0.012415300000 Solvent Utilization DegreasingAll Industries: ColdCleaningTotal: All SolventTypesV 0.00 0.10 0.012415360000 Solvent Utilization DegreasingAuto Repair Services (SIC75): Cold CleaningTotal: All SolventTypes V 0.33 1.06 0.362425010000 Solvent Utilization Graphic Arts LithographyTotal: All SolventTypesI 0.08 1.09 0.042425020000 Solvent Utilization Graphic Arts LetterpressTotal: All SolventTypes I 0.02 0.20 0.012440020000 Solvent Utilization Miscellaneous IndustrialAdhesive (Industrial)ApplicationTotal: All SolventTypes III 0.51 1.57 0.272461021000 Solvent UtilizationMiscellaneous Nonindustrial: CommercialCutback AsphaltTotal: All SolventTypesI 0.072461850001 Solvent UtilizationMiscellaneous Nonindustrial: CommercialPesticide Application:Agricultural Herbicides, Corn I 0.252461850006 Solvent UtilizationMiscellaneous Nonindustrial: CommercialPesticide Application:AgriculturalHerbicides, Hay &Grains I 0.00 0.00 0.002461850009 Solvent UtilizationMiscellaneous Nonindustrial: CommercialPesticide Application:AgriculturalHerbicides, NotElsewhere ClassifiedII 0.06 0.03 0.11452461850056 Solvent UtilizationMiscellaneous Nonindustrial: CommercialPesticide Application:AgriculturalOther Pesticides, Hay& Grains I 0.01 0.01 0.012461850099 Solvent UtilizationMiscellaneous Nonindustrial: CommercialPesticide Application:AgriculturalOther Pesticides, NotElsewhere ClassifiedII 0.01 0.00 0.012501010050 Storage and TransportPetroleum and PetroleumProduct Storage Marinas: Gasoline Stage 1: Total II 0.07 0.072501010102 Storage and TransportPetroleum and PetroleumProduct Storage Marinas: GasolineStage 2: DisplacementLoss I 0.01 0.012501010103 Storage and TransportPetroleum and PetroleumProduct StorageMarinas: Gasoline Stage 2: Spillage I 0.00 0.002501010201 Storage and TransportPetroleum and PetroleumProduct Storage Marinas: GasolineUnderground Tank:Emptying andBreathingI 0.01 0.012501011010 Storage and TransportPetroleum and PetroleumProduct StoragePortable Containers:Residential Vapor Losses I 0.00 0.00 0.002501011011 Storage and TransportPetroleum and PetroleumProduct StoragePortable Containers:Residential Permeation I 0.02 0.09 0.032501011012 Storage and TransportPetroleum and PetroleumProduct StoragePortable Containers:ResidentialDiurnal I 0.20 0.78 0.282501011015 Storage and TransportPetroleum and PetroleumProduct StoragePortable Containers:Residential Spillage I 0.00 0.00 0.002501011016 Storage and TransportPetroleum and PetroleumProduct StoragePortable Containers:Residential Transport I 0.01 0.04 0.022501012010 Storage and TransportPetroleum and PetroleumProduct StoragePortable Containers:CommercialVapor Losses I 0.00 0.00 0.002501012011 Storage and TransportPetroleum and PetroleumProduct StoragePortable Containers:Commercial Permeation I 0.00 0.00 0.002501012012 Storage and TransportPetroleum and PetroleumProduct StoragePortable Containers:Commercial Diurnal I 0.01 0.04 0.022501012015 Storage and TransportPetroleum and PetroleumProduct StoragePortable Containers:CommercialSpillage I 0.00 0.00 0.002501012016 Storage and TransportPetroleum and PetroleumProduct StoragePortable Containers:Commercial Transport I 0.01 0.03 0.022501060051 Storage and TransportPetroleum and PetroleumProduct StorageGasoline Service StationsStage 1: SubmergedFillingI 0.01 0.02 0.032501060053 Storage and TransportPetroleum and PetroleumProduct Storage Gasoline Service StationsStage 1: BalancedSubmerged Filling I 0.15 0.42 0.19462501060100 Storage and TransportPetroleum and PetroleumProduct Storage Gasoline Service Stations Stage 2: Total VIII 0.14 0.40 0.182501060201 Storage and TransportPetroleum and PetroleumProduct StorageGasoline Service StationsUnderground Tank:Breathing andEmptyingI 0.03 0.10 0.052501060204 Storage and TransportPetroleum and PetroleumProduct StorageGasoline Service StationsStage 2: Off-HighwayEquipmentDisplacementLoss/Controlled I 0.01 0.02 0.012501060205 Storage and TransportPetroleum and PetroleumProduct Storage Gasoline Service StationsStage 2: Off-HighwayEquipment Spillage I 0.01 0.02 0.012501080050 Storage and TransportPetroleum and PetroleumProduct StorageAirports : AviationGasoline Stage 1: Total I 0.01 0.05 0.012501080102 Storage and TransportPetroleum and PetroleumProduct StorageAirports: AviationGasolineStage 2: DisplacementLoss I 0.062501080201 Storage and TransportPetroleum and PetroleumProduct StorageAirports: AviationGasolineUnderground Tank:Breathing andEmptyingI 0.032501090050 Storage and TransportPetroleum and PetroleumProduct Storage Airports: Jet A or JP-8 Stage 1: Total I 0.00 0.002501090101 Storage and TransportPetroleum and PetroleumProduct StorageAirports: Jet A or JP-8 Stage 2: Total I 0.00 0.002505020030 Storage and TransportPetroleum and PetroleumProduct Transport Marine Vessel Crude Oil I 0.21 0.34 0.372505020060 Storage and TransportPetroleum and PetroleumProduct Transport Marine Vessel Residual Oil I 0.00 0.00 0.002505020090 Storage and TransportPetroleum and PetroleumProduct TransportMarine Vessel Distillate Oil I 0.00 0.00 0.002505020120 Storage and TransportPetroleum and PetroleumProduct Transport Marine Vessel Gasoline I 0.04 0.09 0.052505020150 Storage and TransportPetroleum and PetroleumProduct TransportMarine Vessel Jet Naphtha I 0.00 0.01 0.002505030120 Storage and TransportPetroleum and PetroleumProduct Transport Truck Gasoline I 0.01 0.03 0.012610000400Waste Disposal,Treatment, andRecoveryOpen Burning All CategoriesYard Waste - BrushSpecies Unspecified VI 0.00472610000500Waste Disposal,Treatment, andRecovery Open Burning All CategoriesLand Clearing Debris(use 28-10-005-000 forLogging DebrisBurning) VII 0.062630020000Waste Disposal,Treatment, andRecoveryWastewater Treatment Public Owned Total Processed I 0.00 0.00 0.002660000000Waste Disposal,Treatment, andRecoveryLeaking UndergroundStorage TanksLeaking UndergroundStorage TanksTotal: All StorageTypes II 0.002810001000Miscellaneous AreaSourcesOther Combustion Forest Wildfires Total I 0.07 0.00 0.002810035000Miscellaneous AreaSources Other Combustion Firefighting Training Total X 0.00 0.00 0.00County Totals2.49 7.75 2.57Total State Projection12.81Notes:I.Delaware’s 2002 emissions for this individual record were different than the MACTEC 2002 emissions. To obtain a Delaware-specific projected 2009 emission,Delaware’s actual 2002 emissions for this individual record were grown and controlled using the same methodology as MACTEC in its 2009 projection for thisrecord.II.The MACTEC projected 2009 inventory did not include any emissions for this SCC. Thus, Delaware’s 2002 tons per day emissionsfor this SCC were projected to2009 using growth factors supplied by MACTEC.III.The MACTEC projected 2009 inventory did not include ozone season tons per day emissions for the SCC of 2440020000. Thus, Delaware’s 2002 tons per dayemissions for this SCC were projected to 2009 using the same methodology as MACTEC applied to the annual emissions for this SCC.IV.Since Delaware adjusted its 2002 emissions for residential wood combustion based on a new report by OMNI, 2009 emissions had to be re-projected. Thus,Delaware’s corrected 2002 emissions were projected to 2009 to 2009 using growth factors supplied by MACTEC.V.Delaware’s 2002 inventory only reflects partial controls due to OTC 2001 VOC Model Rules for Solvent Cleaning Operations. Thus, Delaware has projected the2009 emission for these SCCs by first recalculating the 2002 emissions as if 100% ruleeffectiveness were applied, and then applying the same growth factors used byMACTEC.VI.Due to Delaware’s amendments to its open burning regulation,it is expected that emissions due to yard waste burning will decrease. Thus, Delaware has projectedthe 2009 emission for the SCC of 2610000500 by first recalculating the 2002 emissions as if the same control efficiency, rule effectiveness, and rule penetration usedfor Kent and New Castle counties were applied, and then applying the same growth factors used by MACTEC.VII.Due to Delaware’s amendments to its open burning regulation, itis expected that emissions dueto land clearing debris burningwill decrease. Thus, Delaware hasprojected the 2009 emission for the SCC of2610000500 by first recalculating the 2002 emissions asif 90% rule effectiveness were applied, and then applying thesame growth factors used by MACTEC.VIII.The MACTEC projected 2009 emissions from Stage II vapor recovery for SCC 2501060100 were based upon Delaware’s 2002 emissionswhich did not include a100% rule effectiveness for the controls. Delaware amended itsrequirements for Stage II vapor recovery in 2002, which resulted in 100% rule effectiveness for48controls after 2002. Thus, Delaware calculated its emissions from Stage II vapor recovery in 2003 using 100% rule effectiveness, and then projected those emissionsto 2009 using a six-year growth factor from 2003 to 2009, which was based upon MACTEC’s growth factor from 2002 to 2009.IX.Delaware’s 2002 inventory already reflects controls for the OTC 2001 VOC Model Rules Mobile Equipment Repair and Refinishing.Thus, Delaware has projectedthe 2009 emissions for these SCCs using the same growth factor as used by MACTEC, but with no further controls.X.Delaware recently amended its regulation pertaining to open burning, which extended the ozone season open burning prohibitionout to May through September, andapplies the prohibition to all counties in the state. Due to the regulation’s amendment, there will be no approvals issued forfirefighting training in any county; thus,Delaware has zeroed out those emissions.49Table 6-7. Delaware 2009 NOx Emission Projections (TPD) forNon-Point Sources Revised from MACTEC’s Projections2009 NOx Emissions(TPD)SCC SCC_L1 SCC_L2SCC_L3 SCC_L4Reason(See Notes)KentNewCastleSussex2102002000Stationary SourceFuel Combustion IndustrialBituminous/SubbituminousCoal Total: All Boiler Types I 0.01 0.02 0.002102004000Stationary SourceFuel Combustion Industrial Distillate OilTotal: Boilers and ICEngines I 0.00 0.03 0.012102006000Stationary SourceFuel CombustionIndustrial Natural GasTotal: Boilers and ICEnginesI 0.13 0.99 0.402102007000Stationary SourceFuel Combustion IndustrialLiquified Petroleum Gas(LPG) Total: All Boiler Types I 0.00 0.00 0.002103001000Stationary SourceFuel CombustionCommercial/Institutional Anthracite Coal Total: All Boiler Types I 0.00 0.00 0.002103004000Stationary SourceFuel Combustion Commercial/Institutional Distillate OilTotal: Boilers and ICEngines I 0.02 0.06 0.032103006000Stationary SourceFuel Combustion Commercial/Institutional Natural GasTotal: Boilers and ICEngines I 0.06 0.38 0.012103007000Stationary SourceFuel CombustionCommercial/InstitutionalLiquified Petroleum Gas(LPG)Total: All CombustorTypesI 0.01 0.01 0.032104002000Stationary SourceFuel Combustion ResidentialBituminous/SubbituminousCoalTotal: All CombustorTypes I 0.00 0.00 0.002104004000Stationary SourceFuel Combustion Residential Distillate OilTotal: All CombustorTypes I 0.04 0.14 0.062104006000Stationary SourceFuel CombustionResidential Natural GasTotal: All CombustorTypesI 0.05 0.37 0.012104007000Stationary SourceFuel Combustion ResidentialLiquified Petroleum Gas(LPG)Total: All CombustorTypes I 0.08 0.07 0.172104008000Stationary SourceFuel Combustion Residential WoodTotal: Woodstoves andFireplaces IV0.00 0.00 0.002104008070Stationary SourceFuel Combustion Residential WoodOutdoor Wood BurningEquipment IV 0.00 0.01 0.002104011000Stationary SourceFuel Combustion Residential Kerosene Total: All Heater Types I 0.00 0.00 0.002610000400 Waste Disposal, Open BurningAll CategoriesYard Waste - Brush VI 0.0050Treatment, andRecoverySpecies Unspecified2610000500Waste Disposal,Treatment, andRecovery Open Burning All CategoriesLand Clearing Debris(use 28-10-005-000 forLogging DebrisBurning) VII 0.022810001000Miscellaneous AreaSourcesOther Combustion Forest Wildfires Total I 0.03 0.00 0.002810035000Miscellaneous AreaSources Other Combustion Firefighting Training Total X 0.00 0.00 0.00County Totals0.45 2.09 0.75Total State Projection3.28Notes:I.Delaware’s 2002 emissions for this individual record were different than the MACTEC 2002 emissions. To obtain a Delaware-specific projected 2009 emission,Delaware’s actual 2002 emissions for this individual record were grown and controlled using the same methodology as MACTEC in its 2009 projection for thisrecord.IV.Since Delaware adjusted its 2002 emissions for residential wood combustion based on a new report by OMNI, 2009 emissions had to be re-projected. Thus,Delaware’s corrected 2002 emissions were projected to 2009 to 2009 using growth factors supplied by MACTEC.VI.Due to Delaware’s amendments to its open burning regulation,it is expected that emissions due to yard waste burning will decrease. Thus, Delaware has projectedthe 2009 emission for the SCC of 2610000500 by first recalculating the 2002 emissions as if the same control efficiency, rule effectiveness, and rule penetration usedfor Kent and New Castle counties were applied, and then applying the same growth factors used by MACTEC.VII.Due to Delaware’s amendments to its open burning regulation, itis expected that emissions dueto land clearing debris burningwill decrease. Thus, Delaware hasprojected the 2009 emission for the SCC of2610000500 by first recalculating the 2002 emissions asif 90% rule effectiveness were applied, and then applying thesame growth factors used by MACTEC.X.Delaware recently amended its regulation pertaining to open burning, which extended the ozone season open burning prohibitionout to May through September, andapplies the prohibition to all counties in the state. Due to the regulation’s amendment, there will be no approvals issued forfirefighting training in any county; thus,Delaware has zeroed out those emissions.51 Table 6-8. Delaware 2009 VOC and NOx Emi ssion Projections (TPD) for Non-Point Sources Not Revised from MACTEC’s Projections

Non-Point Emissions County FIPS VOC NOx

Kent 10001 2.25 0.02

New Castle 10003 8.46 0.01

Sussex 10005 3.58 0.01

State-Total 14.29 0.05

Table 6-9. Delaware 2009 VOC and NOx Emi ssion Projections (TPD) for All NonPoint Sources

Non-Point Emissions

County FIPS VOC NOx

Kent 10001 4.75 0.47

New Castle 10003 16.21 2.10

Sussex 10005 6.15 0.76

State-Total 27.11 3.33

6.3 Non-Road Mobile Source Controls and 2009 Emission Projections

The controls for non-road mobile engi nes (except aircrafts, locomotives, and marine vessels) for their 2009 em issions include all re levant federal rules, such as fuel sulfur content rule, gasoline Reid Vapor Pressure (RVP) re quirements, 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 MAC TEC’s TSD, Appendix 6-1).

In addition to the non-road engine s, MACTEC also conducted 2009 annual emission projections for aircrafts, locomo tives and marine vessels for all MANE_VU

states. Controls for the 2009 VOC and NOx em issions include all relevant federal rules and requirements, as outline below.

(1) Phase I and Phase II Emissions Standards for Gasoline-Powered Non-Road Utility Engines, Federal Rule

This measure takes credit for VOC emissions reductions attributable to emissions standards promulgated by the EPA for small non-road, sparkignition (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 e quipment, chain saws, and other such utility equipment as chippers and stum p 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 6-2, 6-3, and 6-4. (2) Emissions Standards for Diesel-Powered Non-Road Utility Engines of 50 or More Horsepower, Federal Rule

This measure takes credit for NOx emissions reductions attributable toemissions standards promulgated by the EPA for non-road, compressionignition (i.e., diesel-power ed) utility engines, as au thorized under 42 U.S.C. §52 7547. The measure affects diesel-powered (or other compression-ignition) construction equipment, industrial equi pment, etc., rated at or above 37 kilowatts (37 kilowatts is approximately equal to 50 horsepower). See References 6-5, 6-6, and 6-7.

(3) Emissions Standards for Spark Igniti on (SI) Marine Engines, Federal Rule

This EPA measure controls exhaust VOC emissions from new spark-ignition (SI) gasoline marine engines, includi ng 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 nati onwide nonroad total). See Reference 6-

8.

(4) Emissions Standards for Large Spar k Ignition Engines, Federal Rule

This EPA measure controls VOC and NOx emissions from several groups of previously unregulated nonroad engine s, including large industrial sparkignition engines. See References 6-9 and 6-10.

(5) Reformulated Gasoline Use in Non- Road Motor Vehicles and Equipment,

Federal Rule This measure involves taking credit for reductions due to the use of federally reformulated gasoline in non-road mob ile sources. Reformulated gasoline is

available as a result of Delaware’s reformulated gasoline requirement. See

Reference 6-11.

Since aircraft, commercial marine vessels, and locomotives are not included in the NONROAD model, emission projections for these sources were developed separately. The starting point for the em ission 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 emi ssion projections for these sources was to use combined growth and control factors de veloped from emission projections for U.S. EPA’s Clean Air Interstate Rule (CAIR) development effort. MACTEC obtained emission projections developed for the CAIR rule. We then calculated the combined growth and control factors by determining th e 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, we developed intermediate year estimates using linear interpolation between the actua l CAIR years and the MANE-VU years.

Using this approach we developed Stat e/county/SCC/pollutant growth/control factors for use in projecting the MANE-VU base year data to the year of interest. These values were then used to multiply times th e base year value to obtain the projected values. Since the development of the CAIR factors included both gr owth and controls, no separate control factors were developed for these sources excep t where exceptions to this method were used for States that requested alternative growth/c ontrol 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 the53 SCC in the MANE-VU inventory the State/ County/SCC/pollutant growth and control

factor for the substitute wa s 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.

Since the ozone-season-daily emissions (tons per day, or TPD) are needed for the ozone SIP planning, Delaware us es its 2002 daily-emission to annual-emission ratios to calculate 2009 daily em issions from MANE_VU’s annual pr ojections (tons per year, or TPY), assuming the daily-to-annual emission rela tions in 2009 follows the same pattern in

2002. These calculations were done at the SCC level, by county, and by pollutant, in order to be as precise as possible. For a small subset of SCCs, where Delaware’s 2002 annual-emissions differed from MANE_V U’s 2002 annual-emissions, Delaware’s 2002 annual-emissions were first projected to 2009 annual-emissions using the ratio of MANE_VU’s 2002 to 2009 annual-emissions rati o, prior to calculating the 2009 daily

emissions. All calculations ar e presented in Appendix 6-2, w ith an example for each of

VOC and NO emissions as follows.

Example 1 Calculation of Kent County 2009 Daily VOC Emission for SCC 2260001010

2002 DE Ozone-Season Daily VOC Emission: 0.17 TPD

2002 DE Annual NOx Emission: 48.00 TPY Daily-to-Annual DE Emission Ratio: 0.17/48.00 2009 MANE_VU Annual VOC Projection: 63.99 TPY

2009 Daily VOC Emission: 63.99 x (0.17 /48.00) = 0.22 TPD

Example 2 Calculation for Kent County 2009 Daily NOx Emission for SCC 2280002100

2002 MANE_VU Annual Projection: 33.59 TPY 2009 MANE_VU Annual Projection: 32.53 TPY 2009-to-2002 MANE_VU Emission Ratio: 32.53/33.59 2002 DE Ozone-Season Daily NOx Emission: 0.07 TPD

2002 DE Annual NOx Emission: 26.48 TPY Daily-to-Annual DE Emission Ratio: 0.07/26.48 2009 MANE_VU Annual Projection: 32.53 TPY

2009 Daily NOx Emission: [(32.53/33.59) x 26.48] x (0.07/26.48) = 0.07 TPD

A summary of Delaware 2009 emission projections for all non-road mobile sources is presented in Table 6-10.

Table 6-10. Delaware 2009 Non-Road Mobile Source Emission Projection Summary

2009 Emissions County FIPs VOC NOx

Kent 10001 4.32 14.2154 New Castle 10003 8.89 22.89

Sussex 10005 7.78 12.50

State Total 20.98 49.59

6.4 On-Road Mobile Source Controls and 2009 Emission Projections

The on-road mobile source emission pr ojections have been conducted by AQM staff members using EPA’s MOBILE6.2 model. Delaware Department of Transportation (DelDOT) provided vehicle miles traveled (V MT) 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 mode l 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. (7) Stage II vapor recover y, statewide (This control was included in MOBILE6.2 model runs for obtaining emission factors to be used emission calculations in the non-point source sector).

Table 6-11 is a summary of Delaware 2009 on-road mobile source emission projections. The input files of the 2009 MO BILE6.2 runs, the emission factors generated and relevant calculations for emission projections are presented in Appendix 6-3.

Table 6-11. Delaware 2009 On-Road Mobile Source Emission Projection Summary

2009 Emissions
County FIPS VOC NOx

Kent 10001 3.95 9.04

New Castle 10003 9.89 19.23

Sussex 10005 7.05 11.93

State Total 20.89 40.20

6.5 Delaware 2009 Emission Projec tions for All Source Sectors

Table 6-12 is a summary of Delaware 2009 all-source emission projections.

Table 6-12. Delaware 2009 All-Source Emission Projection Summary

2009 Emissions County FIPS VOC NOx

Kent 10001 13.41 27.95

New Castle 10003 45.24 73.78

Sussex 10005 28.62 41.7355 State Total 87.27 143.46

The total VOC and NOx numbers in Table 6-12 do not include the banked emissions (See Subsection 5.1.2 of this documen t). Additionally, Delaware commits to adopt a regulation to control the NOx emissi ons from large boilers and heaters from nonrefinery facilities (see Subsection 6.1). This rule shall yield an approximate 3.74 TPD NOx reduction, which was not included in Su bsection 6-1. Therefore, the final 2009 emission projections shall be:

2009 VOC emission = 87.27 + 0.19 = 87.46 TPD

2009 NOx emission = 143.46 + 0.35 + 0.68 – 3.74 = 140.75 TPD

As indicated in Section 4 of this document, Delaware VOC and NOx emission targets in 2009 are 85.04 TPD and 147.64 TPD, respectively. From Table 6-12 and the above calculations, it can be seen that Delawa re’s adopted and proposed controls in this section will achieve a VOC emission level that is higher than the target level. The 2009

VOC emission reduction “shortfall” is:

VOC reduction shortfall = 85.04 – 87.46 = -2.42 TPD

Delaware’s 2002 VOC-to-NOx baselin e (with respect to 2009) ratio is (38.79+72.49):(55.84+137.10) = 111.28:192.94 = 1:1.73 (See Tables 4-3 and 4-4 in Section 4). Therefore, the above VOC reduction shortfall is equivalent to 2.42 x 1.73 =

4.19 TPD NOx reduction shortfall.

From Table 6-12 and emission projection calculations thereafter, it can be seen also that Delaware’s adopted and proposed co ntrols in this secti on will achieve a NOx emission level that is lower than the targ et level. The 2009 NOx emission reduction “surplus” is:

NOx reduction surplus = 147.64 – 140.75= 6.89 TPD

According to EPA’s guidance for NOx substitution (References 6-12 and 6-13),

Delaware decides to use 4.19 TPD NOx re duction surplus to offset the 2009 VOC reduction shortfall. Delaware plans to use th e leftover portion of NOx surplus, i.e., 6.89 – 4.19 = 2.70 TPD, for 2009 contingency purposes, as discussed in Subsection 10.3 of this

SIP revision.

References

6-1. 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, December 2006. 6-2. U.S. Environmental Protection Agency, “ Emission Standards for New Nonroad Spark-Ignition Engines at or Below 19 Kilowatts ”, Final Rule, 60 Federal Register 34581 (July 3, 1995). 6-3. U.S. Environmental Protection Agency, “ Phase 2 Emission Standards for New Nonroad Spark- Ignition Nonhandheld Engines At or Below 19 Kilowatts ”, Final56 Rule, 64 Federal Register 15207, (March 30, 1999); correction published 64 Federal Register 36423 (July 6, 1999) 6-4. U.S. Environmental Protection Agency, “ Phase 2 Emission Standards for New Nonroad Spark- Ignition Handheld Engines at or Below 19 Kilowatts ”, Final Rule, 65 Federal Register 24267 (April 25, 2000) 6-5. U.S. Environmental Protection Agency, “ Control of Emissions of Air Pollution from Nonroad Diesel Engines; Final Rule. ” 63 Federal Register 56967, October 23, 1998. 6-6. U.S. Environmental Protection Agency, “ Control of Emissions of Air Pollution from Nonroad Diesel Engines and Fuel; Final Rule .” 69 Federal Register Vol. 69, No. 124, June 29, 2004 6-7. U.S. Environmental Protection Agency, “ Determination of Si gnificance for Nonroad Sources and Emission Standards for New N onroad Compression-Ignition Engines at

or Above 37 Kilowatts ”, Final Rule, 59 Federal Register 31306 (June 17, 1994). 6-8. U.S. Environmental Protection Agency, “ Control of Air Pollution; Final Rule for New Gasoline Spark-Ignition Marine Engi nes; Exemptions for New Nonroad Compression-Ignition Engines at or A bove 37 Kilowatts and New Nonroad SparkIgnition Engines at or Below 19 Kilowatts ”, 61 Federal Register 52087, October 4,

1996. 6-9. U.S. Environmental Protection Agency, “ Control of Emissions from Nonroad Large Spark-Ignition Engines, and Recreational Engines (Marine and Land-Based) ,” Final Rule, 67 Federal Register 68241 (November 8, 2002). 6-10. U.S. Environmental Protection Agency, “ Final Regulatory Support Document: Control of Emissions from Unregulated Nonroad Engines ,” EPA420-R-02-022, September 2002. 6-11. U.S. Environmental Protection Agency, “ Regulation of Fuels and Fuel Additives: Standards for Reformulated Gasoline ”, Proposed Rule, 58 Federal Register 11722, February 26, 1993.

6-12. NOx Substitution Guidance , Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency, Res earch Triangle Park, North Carolina 27711,

December 1993.

6-13. Guidance on the Post-1996 Rate-o f-Progress Plan and the Attainment

Demonstration , Ozone/Carbon Monoxide Programs Branch, U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina 27711, February 18, 1994.57 7. Attainment Demonstration Modelin g and Weight-of-Evidence Analysis

7.1 Background and Objectives

As discussed in Section 1 of this docum ent, EPA designated all three counties in

Delaware as moderate non-attainment areas for the 8-hour ozone standard. These three Delaware counties are part ofa greater Philadelphia-Wilmington-Atlantic City (PA-NJDE-MD) moderate non-attainment area (NAA) for the 8-hour ozone standard. As shown in Figure 1-1 (Section 1 of th is document), the m oderate non-attainment counties within this area by the state are:

Delaware: Kent County, New Ca stle County, Sussex County; Maryland: Cecil County; New Jersey: Atlantic County, Burlington County, Camden County, Cape May County, Cumberland County, Gloucester County, Mercer County, Ocean County, Salem County; Pennsylvania: Bucks County, Cheste r County, Delaware County, Montgomery County, Philadelphia County.

Ozone has been a chronic problem, par ticularly along the I-95 corridor from Washington, DC to Boston, MA. The ozone non-attainment in the Northeast and MidAtlantic regions is a ttributed not only to the anthropoge nic emissions in the area but also to regional transport, which is a signifi cant portion of ozone observed. The Ozone Transport and Assessment Group (OTAG) addr essed the concerns related to ozone transport through modeling, which determined th at NOx emissions reductions are effective in reducing the ozone transpor t (Reference 7-1). Conseque ntly, the EPA issued the NOx SIP call in 1998 requiring twenty-two states and the Distri ct of Columbia to reduce their

NO

x emissions. The control programs for the NOx SIP Call were implemented in phases, with the full implementation occurring in 2005 (Reference 7-2). While the NOx SIP call measures helped mitigate the regional ozone transport along the I-95 corridor (References 7-2 and 7-3), regional transport is still a major contributor to the continuing ozone nonattainment in the Mid-Atlantic and Northeast.

The EPA requires that the areas in non- attainment for the 8-hour ozone NAAQS demonstrate, by the use of photochemical grid modeling and weight-of-evidence analyses, that they would attain the NAAQS by June 15, 2010 (Reference 7-4). The attainment demonstration assesses whether emissions reductions resulting from a set of selected

control measures will result in ambient concentr ations that meet the NAAQS. It predicts whether or not all estimated future 2009 design values will be less th an or equal to the concentration level specified for the 8-hour ozone NAAQS under meteorological

conditions similar to those which have been simulated for the 2002 base year modeling.

The objective of this section (i.e., Attainment Demonstration Modeling and Weight-of-Evidence Analysis) is to evalua te the efficacy of proposed/adopted control strategies, and to demonstrate that such meas ures will result in attainment of the ozone standard by June 15, 2010. This SIP shows th at progress is being made to improve air quality in the PA-NJ-DE-MD mo derate non-attainment area, that all necessary steps are being taken to attain the 8-hour ozone NAAQ S by 2009, and that the en tire non-attainment area will comply with the 8-hour ozone NAAQS by the June 15, 2010 attainment date.58 The basis for Delaware’s attainment demonstration for the 8-hour ozone standard is the Delaware modeling protocol (Refer ence 7-5) and Ozone Transport Commission’s (OTC) modeling for the State Implementation Pl an (SIP) in the 12-st ate Ozone Transport Region (OTR) (Appendix 7-1). The PA-NJ-DE -MD’s modeling runs were performed in coordination with the OTC modeling cente rs, which included the New York State Department of Environmental Conservation (NYSDEC), the University of Maryland, the

Northeast States for Coordinated Air Us e Management (NESCAUM) and Virginia Department of Environmental Quality (VADE Q). Modeling inventor ies were developed, updated and shared among the regional mode ling centers and provided by Mid-Atlantic Regional Air Management Association (MARAM A), Mid-Atlantic Nort h East Visibility Union (MANE-VU) and the Visibility Improveme nt State and Tribal Association of the Southeast (VISTAS).

7.2 Photochemical Modeling System

The OTC modeling committee selected the EPA’s Community Multi-Scale Air Quality (CMAQ) model for this modeling effort. Two CMAQ mo deling domains were

defined: the outer domain at a 36-km horizont al grid resolution covering the continental

U.S. and the inner domain at 12-km horizontal grid resolution coveri ng the OTR, as shown in Figure 7-1. 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 demonstr ations but also serv ing 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 th e justification for all activities pursuant to demonstrating attainment of the 8-hour ozone standard. The selection of the horizontal grid sizes and vertical layer st ructure are described in detail in the OTC Modeling Protocol (Appendix 7-1). A technical support documen t from NYSDEC (Appendix 7-2) provides information on air quality modeling domain definitions, CMAQ mode l options selected for modeling, and 36- and 12-km CMAQ domain simulations.59 Figure 7-1: The 8-Hour Ozone CMAQ Modeling Domains at 36-km and 12-km

7.3 Ozone Episode Selection

The EPA recommends modeling a group of ep isodes for the purposes of attainment demonstration. Taking the size of the m odeling domain into consideration, the OTC modeling committee simulated a major porti on of the 2002 ozone season with the OTC SIP modeling system. Such a selection is jus tified as a result of a special study by Environ (Appendix 7-3), which assesses the represen tativeness of the conditions in 2002 season with respect to exceedance events that have occurred in other years, and determines if there are any types of episodes that are not adequately represented within the 2002 season. The Environ study analyzed the ozone episode s and concluded that conditions during the 2002 exceedance events were, for the most part, very similar to those found in other years,

and that the 2002 season can be considered to be representative for purposes of photochemical modeling in support of SIP de velopment. Another study, a qualitative analysis by Ryan and Piety (A ppendix 7-4), provides the rati onale for the selection of 2002 meteorology.

Recent research has shown that model perf ormance evaluations and the response to emissions controls need to consider modeling results from long time periods, in particular full synoptic cycles or even full ozone seasons . Based on this factor the entire ozone

season was simulated for the 2002 and 2009 St ate Implementation Plan (SIP) modeling runs (May 1 to September 30). As a result, the total number of days examined for the60 complete ozone season far exceeds EPA recommendations, and provides for better assessment of the simulated pollutant fields.

7.4 Meteorological Fields

Meteorological fields needed for the OT C SIP modeling system are generated by the PSU/NCAR Mesoscale Meteorological M odel (MM5). The model setup and the procedures for quality assurance of the mete orological fields are described in the OTC Modeling Protocol (Appendix 7-1). Assessm ent of the MM5 modeling is described in Appendix 7-5.

7.5 Model Performance Evaluation

The purpose of the evaluation of model performance is to assess the model’s ability to reproduce the observati ons at all monitored locations. This is a required step in order to build confidence in the model prior to its use in control strategy evaluation and

modeled attainment demonstrations. The model performance evaluation focused on the magnitude, spatial and temporal patterns of the modeled and monitored concentrations of ozone and its precursors. The EPA procedur es are used to calculate the recommended performance measures (Appendix 7-1).

Various CMAQ model evaluation statistics for a variety of gaseous and aerosol species are assessed for many possible sources of measured data in the OTR. The CMAQ results were best for daily maximum (A ppendix 7-6). Our evaluation of model performance for monitored ozone concentrations in Delaware monitors satisfied the EPA

criteria.

7.6 Emissions Inventories

Emissions processing necessary for th e 2002 base case and 2009 future case modeling required coordination amongst the Re gional Planning Organizations (RPOs). Each RPO was responsible for processing of both its anthropogenic and biogenic emissions. The emissions data for 2002 were ge nerated by individual states within the OTR and were assembled and processed thr ough the MANE-VU. These emissions were then processed by the NYSDEC using Sparse Matrix Operator Kernel Emissions (SMOKE) modeling system, an emissions proc essor 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 a nd were processed using SMOKE.

Emissions inventories for 2009, 2012 a nd 2018 needed for the MANE-VU RPO were developed by a number of entities. A contractor (MACTEC, Inc.) in consultation with the states developed the necessary growth and control factors and applied them to the 2002 inventory. Mobile source emissions were developed by VADEQ and NESCAUM based on state supplied VMT and speeds data. Em issions for the electric generating units (EGUs) 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 identified as 2009 on-the-book/on-the-way (2009 OTB/OTW) inventories as they represent all control meas ures that were promulgated or would become effective on or before 2009. Details of emissions processing are provided in Appendices 7-7, 7-8 and 7-9.61 7.7 Conceptual Model

EPA recommends that a conceptual descri ption of the area’s ozone problem be developed prior to the init iation of any air quality mo deling study. A “conceptual description” is a qualitative wa y of characterizing the nature of an area’s non-attainment problem. Within the conceptual descripti on 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 that Delaware is using for this SIP revision is a report that was prepared by the NESCAUM for use by the OTC member States (Appendix 7-10). This document provides the conceptual description of the ozone problem in the OTR states, consistent with the EPA’s guidance.

There are a number of other studies that provide conceptual description for the ozone problem in the Northeast and Mid-Atlant ic regions. Some of them are provided as appendixes to this document (Appe ndixes 7-3, 7-4, 7-11, and 7-12).

7.8 Attainment Demonstration of 8-hour Ozone NAAQS

This subsection provides technical inform ation and rationale for demonstrating attainment of the 8-hour ozone NAAQS in the PA-NJ-DE-MD moderate non-attainment area by June 15, 2010. The demonstration is based on results of CMAQ modeling and the supporting weight-of-evidence (WOE) analyses , details of which are as follow.

7.8.1 Modeling Demonstration

Modeled attainment demonstration of the NAAQS is performed in two ways: by applying modeled attainment test for all mo nitors in the area, and by utilizing the “unmonitored area analysis” per the EPA Modeling Guidance document.

7.8.1.1 Model Results Summary

The modeled attainment test applied at each monitor is performed using the following equation:

I I I DVC RRF DVF × =

where DVC I = the baseline concentration monitored at site I, in ppb;

RRF I = the relative response fact or, calculated near site I ;

DVF I = the estimated future design value for the time attainment is required, in ppb.

Results for all monitors inside the PA -NJ-DE-MD moderate non-attainment area

are summarized in Table 7-1. This table in cludes baseline design values (DVC) for all

monitors. These values are based on the 8- hour ozone design values and relative response factors (RRFs) from the OTC SIP-quality m odeling. The projected design values for 2009 (DVF) represent the projected 2009 8-hour ozone design values. Highlighted values indicate the monitors projected to be above the 8-hour ozone standard at the end of the

2009 ozone season.62 Baseline design values (DVC) are calculated using the average of the three design value periods that include the baseline inventory year. Sp ecifically, the average design value is calculated using the 2000-2002, 2001-2003, and 2002-2004 periods.

In the event that there is less than five y ears of available data at a monitoring site the following procedure was used:

• 3 years of data: The current design valu e was based on a single design value.

• 4 years of data: The curren t design value was based on an average of two design

value periods.

• Less than 3 years of data: The site wa s not be used in the attainment test.

A 3x3 array of grid cells surrounding each monitor was used in the modeled attainment test as recommended for 12-km gr id resolution modeling to calculate RRFs.

The predicted eight-hour daily maximum c oncentrations from each modeled day is

used in the modeled attainment test with th e nearby grid cell with the highest predicted 8- hour daily maximum concentration with baseline emissions for each day considered in the test, and the grid cell with th e highest predicted 8-hour daily maximum concentration with the future emissions for each day in the test.

Table 7-1: Summary of Mode l Attainment Test Results

Monitor ID Site Name County State DVC RRF

OTB/OTW

V4 DVF

100010002 Killens Pond Kent DE 88 0.8934 78

100031007 Lums Pond New Castle DE 91 0.8462 77

100031010 Brandywine New Castle DE 93 0.8781 81

100031013 Bellefonte New Castle DE 89 0.8759 77

100051002 Seaford Sussex DE 90 0.8462 76

100051003 Lewes Sussex DE 86 0.8956 77

240150003 Fair Hill C ecil MD 98 0.8336 81

340010005 Nacote Creek Atlantic NJ 88 0.8762 77

340070003 Camden Camden NJ 98 0.8996 88

340071001 Ancora State Hospital Camden NJ 100 0.8733 87

340110007 Millville Cumber land NJ 94 0.8486 79

340150002 Clarksboro Glou cester NJ 98 0.9004 88

340210005 Rider College Mercer NJ 97 0.8908 86

340290006 Colliers Mills Ocean NJ 105 0.8703 91

420170012 Bristol Bucks PA 99 0.8976 88

420290100 New Garden Airport Chester PA 94 0.8387 7863 Monitor ID Site Name County State DVC RRF

OTB/OTW

V4 DVF

420450002 Chester Delaware PA 91 0.8705 79

420910013 Norristown Montgomer

y PA 92 0.8861 81

421010004 AMS Lab Philadelphia PA 72 0.9081 65

421010014 Roxboro Philadelphia PA 91 0.9070 82

421010024 NE Airport Philadelphia PA 97 0.9035 87

421010136 Elmwood Philadelphia PA 84 0.9070 76

The RRFs used in the modeled attainment test were computed by taking the ratio of the mean of the 8-hour daily maximum predic tions in the future to the mean of the 8- hour daily maximum predictions with baseli ne emissions, over all relevant days.

To avoid overestimates of future design values and provide for more robust RRFs and future design values, the following rules we re applied to determine the number of days

and the minimum threshold at each ozone monitor:

• If there are 10 or more days with daily maximum 8-hour average modeled ozone > 85 ppb an 85 ppb threshold was used.

• If there are less than 10 days with daily maximum 8-hour average modeled ozone > 85 ppb the threshold was reduced to as low as 70 ppb until there are 10 days in the mean RRF calculation.

• If there are less than 10 days with daily maximum 8-hour average modeled ozone > 70 ppb then all da ys > 70 ppb were used.

• No RRF calculations were performed fo r sites with less than 5 days > 70 ppb.

7.8.1.2 Unmonitored Area Analysis

The purpose of the unmonitored area analysis is to insure that there are no predicted violations of ambient air quality standards in the non- attainment area areas. This analysis was prepared in accordance with the EPA modeling guidance document (2005). For the purposes of this an alysis, all counties within the PA-NJ-DE-MD non-attainment area and all counties that bordering this area are considered.

The baseline data for this analysis is the ozone model data 2002 BaseB1 dataset, which contains the daily maxi mum 8-hour ozone concentrations, for each grid cell in the modeling domain, simulated by CMAQ for May 15 September 29 using 2002 BaseB1 emissions data. The projected data uses the ozone model data 2009 BaseB4 dataset, which

contains the for the 2009 BaseB4 BOTB/BOTW s cenario data for the same period. Both of these datasets were generated by the New York DEC using the SMOKE/CMAQ modeling system with MM5 meteorology.

Processing of the data was done with MATS version 1.1.043 (February 2007). This involved four steps:64 Step 1: Interpolating the base year ambient data to the spatial fields. Step 2: Adjusting the spatial fields us ing the base year gridded model output gradients. Step 3: Applying the gridded model Re lative Response Values to the gradient adjusted spatial fields. Step 4: Determining if any unmonitored areas exceed the NAAQS.

As shown in Figure 7-2, no grid cells in this analysis are predic ted to exceed the 8- hour ozone NAAQS.

Figure 7-2: Predicted ozone design values

7.8.2 Weight of Evidence Demonstration

In accordance with EPA guidance, corroboratory evidence shall accompany the

modeled attainment demonstrati on. This weight of evidence (WOE) analysis describes the analyses performed, databases used, key assump tions and outcomes of each analysis, and why the evidence, viewed as a whole, supports a conclusion that the non-attainment area65 will attain the NAAQS despite the model pred icting that some monitors’ future design values will exceed the 8-hour ozone standard (see Section 7.8.1 above).

Table 7-2 outlines under what circumstan ces a WOE demonstration is needed. Model-predicted design values ar e summarized in Table 7-1. Of the 22 ozone monitors in the PA-NJ-DE-MD non-attainment area only ei ght (8) exceed the threshold requiring a WOE demonstration. Four (4) of the monito rs fall within the 82-97 ppb threshold outlined in Table 7-2 and four (4) others fall within the last category listed in the WOE table included in the US EPA guidance. The Roxboro monitor has been excluded from the WOE analysis since its current design value is significantly below the 8-hour standard (modeled 82 ppb, actual 78 ppb).

Table 7-2 Guidelines for Supplemental Analyses and Weight of Evidence

Determinations

Results of Modeled Attainment Test Supplemental Analyses

Future Design Value < 82 ppb, all monitor

sites Basic supplemental analyses should be completed to confirm the outcome of the

modeled attainment test

Future Design Value 82 - 87 ppb, at one or more sites/grid cells A weight of evidence demonstration should be conducted to determine if aggregate supplemental analyses support the modeled

attainment test

Future Design Value > 88 ppb, at one or more sites/grid cells More qualitative results are unlikely to support a conclusion differing from the outcome of the

modeled attainment test.

The WOE analysis for the remaining seven monitors will include the following analyses:

• A comparison of predicted 2009 ozone de sign values and current projected design values for 2006 (Section 7.8.2.1, Over view of Modeled Concentrations and Current Design Values),

• An analysis of recent ozone trends in the PA-NJ-DE-MD non-attainment area (Section 7.8.2.2., Recent Ozone Trends),

• Alternative methods for calculating the 2009 ozone design value (Section 7.8.2.3., Alternative Approaches, and 7.8.2.4, Combining Alternative Baseline Concentrations and Alternative RRFs)

• An analysis of model-predicted re gional transport, (Section 7.8.2.5, Regional Transport Analysis)

• University of Maryland’s analysis of model sensitivity to emission changes. (Section 7.8.2.6)

• Effect of alternative methods and tr ansport on 2009 design values (Section 7.8.2.7)

• Delaware-specific control measures (Section 7.8.2.8)

• Statistical rollback to estimate RRFs (Section 7.7.2.10)66 7.8.2.1 Overview of Modeled Concentrations and Current Design Values

Table 7-3 lists the OTC modeled 2009 proj ected design values and the projected design values for 2006. Modeled 2009 and pr ojected 2006 design values are surprisingly

close to one another with most modeled concen trations slightly lower than the projected 2006 design values. This suggests that the significant additional VOC and NOX reductions projected to occur over the next thr ee years will likely br ing monitors currently recording ozone concentrations just over the 8-hour ozone st andard into compliance, and

indicates attainment will be achieved.

Table 7-3 Comparison of Modeled 2009 a nd Projected 2006 Ozone Design Values

AQS Code Site Name State Modeled 2009 Actual 2006

100010002 Killens Pond DE 78 80

100031007 Lums Pond DE 77 78

100031010 Brandywine Creek DE 81 82

100031013 Bellefonte DE 77 81

100051002 Seaford DE 76 80

100051003 Lewes DE 77 82

240150003 Fairhill MD 81 90

340010005 Nacote Creek NJ 77 79

340070003 Camden NJ 88 84

340071001 Ancora State Hospital NJ 87 89

340110007 Millville NJ 79 84

340150002 Clarksboro NJ 88 86

340210005 Rider NJ 86 87

340290006 Colliers Mills NJ 93 93

420170012 Bristol PA 88 86

420290100 New Garden PA 78 86

420450002 Chester PA 79 83

420910013 Norristown PA 81 85

421010004 Lab PA 65 63

421010014 Roxboro PA 82 78

421010024 Northeast Airport PA 87 90

421010136 Elmwood PA 76 74

7.8.2.2 Recent Ozone Trends67 Long-term trends in Delaware’s ozone desi gn values are discussed in Section 2 ofthis document. Similar to this DE data there have been significant declines in the PA-NJDE-MD non-attainment area’s 8-hour ozone desi gn values over the last several decades.

These declines are attr ibutable to such events as the RVP program in the early 1990’s and

the more recent enactment of the NO

x SIP Call.

It is interesting to note that ozone design values in the PA-NJ-DE-MD nonattainment area have fallen roughl y 14% since enactment of the NO

x SIP Call. Figure 7-3 shows the most recent design value trends in the PA-NJ-DE-MD non-attainment area. Nearly all of the monitors s how steady decline in ozone desi gn values since 2002 (the year prior to phased-in enactment of the NO

x SIP Call). Slight incr eases in design values between 2002 and 2003 occur at only a handful of monitors in the PA-NJ-DE-MD nonattainment area.

This indicates that reduction in NO

x emissions from upwind electric generating units (EGUs) have a dramatic effect on redu ction of ozone levels in the PA-NJ-DE-MD non-attainment area. By 2009 additio nal significant reductions in NO

x emissions are projected to occur due to in itiatives like CAIR and Delaware’s Regulation No. 1146. These reductions are greater than those attributable to the NO

x SIP Call, so this, coupled with the significant mobile source sector re ductions anticipated wi ll provide additional

reductions in the PA-NJ-DE-MD non-attainment ar ea’s design values. This should result

in attainment of the 8-hour ozone standa rd in the PA-NJ-DE-MD non-attainment area.

Figures 7-4, 7-5 and 7-6 provide additiona l information on the long-term trend of summer 1-hour ozone values (1996-2006) monitore d at different loca tions in Kent, New Castle and Sussex Counties. The long-term trends are obtained by filtering the high frequency and noise with the KZ365,3 filter of the log 1-hour ozone values (References 7- 6, 7-7, 7-8). This provides the raw ozone tr ends, which indicates th at the trend is of decreasing ozone at these three monitors. A comprehensive trends study of the 1-hour

ozone concentrations over the entire OT R modeling domain shows of decreasing ozone

trend at the monitors in the OTR region (Appendix 7-13).68 2002-2006 PA-NJ-DE-MD Nonattainmnet Area Design Value Trends

60 65 70 75 80 85 90 95 100 105 110 115

2002 2003 2004 2005 2006

YearConcentration (ppb) . DE - Brandywine Creek

DE - Bellefonte

DE - Killens Pond

DE - Lewes

DE - Lums Pond

DE - Seaford

MD - Fairhill

NJ - Ancora

NJ - Camden

NJ - Clarksboro

NJ - Colliers Mills

NJ - Millville

NJ - Nacote Creek

NJ - Rider

PA - Bristol

PA - Chester

PA - New Garden

PA - Norristown

PA - Elmwood

PA - Lab

PA - Northeast Airport

PA - Roxborough

Ozone 8-hr Standard

Figure 7-3. The 8-Hour Ozone 2002-2006 Design Value Trends

Figure 7-4. Long-term trends of ozone summer values in Kent County (1996-2006) 0 10000 20000 30000 40000 500000.032 0.033 0.034 0.035 0.036 0.037 0.038 Kent County (Killens) - 1996-2006

Sum

m er O

nl y - N

oise and hi g h fre

q uenc

y filtered H oursln Transformed O369 Figure 7-5. Long-term trends of Oz one Summer Values in New Castle County (1996-2006)

Figure 7-6. Long-term trends of Ozone summer values in Sussex County (1996-2006)

7.8.2.3 Alternative Approaches 0 10000 20000 30000 40000 500000.034 0.035 0.036 0.037 Sussex County (Seaford)- ln(O3) - 1996-2006

Sum

m er O

nl y - Noise and hi g h fre

q uenc

y filtered Hoursln Transformed O3 0 10000 20000 30000 40000 500000.031 0.032 0.033 0.034 0.035 0.036 0.037 New Castle County (Bellfonte)- 1996-2006

Sum

m er Onl y - Noise and hi g h fre

q uenc

y filtered Hoursln Transformed O370 Two alternatives to the US EPA’s standa rd method for estimating future monitor design values are examined in this secti on. One assesses an alternative method for calculating the baseline design value, and a nother assesses constructing an alternative

RRF. The effects of both methods are anal yzed separately and then analyzed and combined (see Section 7.8.2.4).

Alternative Baseline Design Value

Seven monitors within the PA-NJ-DE-M D non-attainment area are projected to exceed the current 8-hour ozone standard following the US EPA’s recommendations (See Section 7.8.1.1 above). The recommended baselin e concentration used in the attainment demonstration is the average of the 8-hour ozone design values that include in the emission base year (2002). Thus the base line concentration is the average of the 2002, 2003 and 2004 8-hour ozone design value.

Using the US EPA recommended method fo r calculating a monitor’s baseline concentration places undo weight on the 2002 ozone season, one of the worst ozone

seasons since the late 1990s. The 2002 ozone season contributes a third of the baseline concentration; 2001 and 2003 contribute 22% each, 2000 and 2004 contribute 11% each.

An alternative to the US EPA’s method of base line concentration calculation is to take the straight average of the 4 th highs over the same years (2000- 2004). This a pproach weighs each year equally. Table 7-4 lists the altern ative baseline value and the projected 2009

concentration for the seven monitors that are projected to exceed the current 8-hour ozone

standard in 2009. This reduces the modeled 2009 values slightly but still leaves them close to the projected 2006 de sign values. Only one mon itor (Colliers Mills) remains

above the most difficult concentrations listed in the US EPA’s WOE cut offs.

Table 7-4. Alternative Baseline Concentration Analysis

Site Name State Alternative

Baseline OTW/OTB V4

RRF Alternate

2009 2006 Design

Value

Camden NJ 94 0.8996 84 84

Ancora State Hospital NJ 98 0.8733 85 89

Clarksboro NJ 96 0.9004 86 86

Rider College NJ 95 0.8908 85 87

Colliers Mills NJ 105 0.8703 91 93

Bristol PA 96 0.8976 86 86

NE Philadelphia PA 94 0.9035 84 90

Alternative RRF

The OTC model data was reexamined to determine the variation in RRFs for the seven monitors in which modeled 2009 concentrations exceeded the current eight-hour

ozone standard. RRFs are recalculated for several different ozone levels; 2002 baseline71 model concentrations ≥ 85 ppb, 2002 baseline mode l concentrations ≥ 90 ppb and 2002

baseline model concentrations ≥ 95 ppb. The idea is to see if the air-quality model predicts more reductions on days with higher ozone concentrations (more benefit on the worst days). Table 7-5 lists the differe nt RRFs based on the 2002 baseline model

concentrations.

Recalculating the projected modeled 2009 design values usi ng the alternative RRFs lowered nearly all seven monitors by 1 ppb, except Bristol and Colliers Mills which were unchanged (Table 7-6). The Bristol a nd Colliers Mills monitors remained above the

most difficult concentrations listed in the US EPA’s WOE cut offs.

Table 7-5. Alternative RRF Calculation Analysis

Site RRF ≥ 95 ppb RRF ≥ 90 ppb RRF ≥ 85 ppb RRF ≥ 75 ppb Min

Camden 0.8915 0.8946 0.8996 0.9036 0.8915

Ancora State Hospital 0.8723 0.8749 0.8733 0.8760 0.8723

Clarksboro 0.8875 0.8894 0.9004 0.8953 0.8875

Rider 0.8914 0.8941 0.8908 0.9022 0.8908

Colliers Mills 0.8726 0. 8704 0.8703 0.8757 0.8703

Bristol 0.8892 0.8925 0.8976 0.9060 0.8892

NE Airport 0.8991 0.9031 0.9035 0.9108 0.8991

Table 7-6. Alternative Projected 2009 Mo deled Values Using Alternative RRFs

Site Alt RRF DV Base Alt Projected 2009 2006 Design Value

Camden 0.8915 98 87 84

Ancora S.H. 0.8723 100 87 89

Clarksboro 0.8875 98 86 86

Rider 0.8908 97 86 87

Colliers Mills 0.8703 105 91 93

Bristol 0.8892 99 88 86

NE Airport 0.8991 97 87 90

7.8.2.4 Combining Alternative Baseline Co ncentrations and Alternative RRFs

Table 7-7 lists the project ed 2009 modeled design valu es from combining the

alternative baseline concentra tions and the alternative RRF calculations described in the previous section. The combination of these two alternative approaches lowers the projected 2009-modeled concentrations signifi cantly, but still leaves the Colliers Mills

monitor above the most difficult concentrations listed in the US EPA’s WOE chart. The72 other six monitors are close to the current eight-hour ozone standard but for the most part not significantly different than the projected 2006 design values.

Table 7-7. Combined Affects of Alternativ e Baseline Concentrations and Alternative

RRFs

Site Alt RRF Alt DV Base Alt Projected 2009 2006 Design Value

Camden 0.8915 94 83 84

Ancora State Hospital 0.8723 98 85 89

Clarksboro 0.8875 96 85 86

Rider 0.8908 95 84 87

Colliers Mills 0.8703 105 91 93

Bristol 0.8892 96 85 86

NE Airport 0.8991 94 84 90

7.8.2.5 Regional Transport Analysis

The NO

x SIP Call reduced ozone precursor em issions over a large region of the eastern US. These reductions undoubtedly re duced regional transport from the large power plants along the Ohio River into the PA-NJ-DE-MD non-attainment area. Methodist Hill is an elevated monitoring site on South Mountain in south-central Pennsylvania approximately 40 m iles southwest of th e City of Harrisburg. Methodist Hill sits at approximately 1900ft above mean-sea level and is in a good position to sample ozone concentrations entering the eastern OTR.

A quick review of design value trends at Methodist Hill shows substantial

reductions in ozone levels sinc e full implementation of the NO

x SIP Call. Table 7-8 lists Methodist Hill’s eight-hour ozone design values, 4 th high eight-hour ozone concentrations and the number of days the monitor exceeded the current eight-hour ozone standard. All

of the values listed in the table have fallen since enactment of the NO

x SIP Call (2003 ozone season). Ozone design values have fallen ~15%, 4 th high values have fallen ~23%

and exceedances have fallen ~95% since 2003.

Table 7-8. Methodist Hill Statisti cs, Proxy for Regional Transport

Year Design Value (ppm) 4 th high (ppm) No. of Exceedances

1996 0.082 3

1997 0.091 7

1998 0.104 22

1999 0.097 0.098 20

2000 0.095 0.085 4

2001 0.092 0.095 1573 Year Design Value (ppm) 4 th high (ppm) No. of Exceedances

2002 0.094 0.104 27

2003 0.093 0.080 3

2004 0.085 0.071 0

2005 0.075 0.074 0

2006 0.070 0.066 0

One way to gauge how well the OTC air-quality model is simulating regional transport is to examine how well the mode led 2009 8-hour ozone design value compares to the actual 2006-design value. Table 7- 9 lists the US EPA derived modeled 2009

concentration and the actual 2006 ozone design value. The model appears to be significantly over predicting Met hodist Hill’s design value by approximately 6 ppb. This indicates the model is not adequately characterizing the effects of the NO

x SIP Call on upwind sources (under predicting the benefit). This suggest s modeled 2009 design values may be overestimated by as much as 6 ppb within the PA-NJ-DE-MD non-attainment area. The 6 ppb difference represents th e overestimation of background (regional) concentrations entering the eastern OTR.

Table 7-9 Modeled 2009 Ozone Design Values (ppb) at Methodist Hill

EPA Baseline RRF OTB/OTW V4 Modeled 2009 DV 2006

90 0.8488 76 70

Though ozone concentrations entering the eastern OTR are si gnificantly lower

since the NO

x SIP Call, they still represent a signi ficant portion of the current eight-hour standard; almost 80% on the worst ozone da ys within the non-attainment area.

7.8.2.6 Analysis of Air-Quality Model Sensitivity to Emission Changes

Recent work by the University of Maryla nd to estimate uncertainty in the CMAQ model has determined a tendency in the model to under predict emission reduction benefits (Reference 7-9). This conclusion is based on modeling work done to reproduce ozone concentrations during the August 2003 Northeast Blackout and ongoing studies by

the US EPA.

Modeling work to simulate the Augu st 2003 Northeast Blackout by Hu, Odman and Russell indicate that air-quality mode ls significantly under predicted ozone concentrations when compared to aircraft measurements made by the University of Maryland (Reference 7-10, Appendix 7-11). M odeled ozone reductions due to the large number of power plant shutdow ns during the blackout were on the order of 2.2 ppb while reductions of up to 7 ppb were noted in the aircraft data. The University of Maryland concluded air-quality models such as CMAQ might under predict ozone reductions due to control programs such as the NO

x SIP Call by up to a factor of two. To account for74 CMAQ’s resistance to change, CMAQ’s benefits could be increased by 50%; in other words a factor of 1.5 will provide a conser vative estimate of the WOE benefit.

Furthermore, two other sources of uncertain ty in future year projection years are considered. Variations in meteorology lead to substantive variations in year-to-year peak ozone values. Therefore, selection of one base year or any three-year period that is representative of overall conditi ons of one area is a source of uncertainty. Currently, most ozone monitoring locations throughout the Mi d-Atlantic and Northeast show improving

trends in ozone concentrations over the years that went into the 5-year weighted average, though the design values at some have risen modestly. The average difference between the highest and lowest 3-year desi gn values is 6 ppb. Similarly, th e average standard deviation

for each site over this time period is +/- 3 ppb. Both these measures suggest that variations in meteorology can reasonably be expected to produce substantial variability in the design

values themselves.

Another source of uncertainty is the sensitivity of the model to errors and

uncertainties in the emissions inventories. The scenarios used to examine this source of uncertainty were: OTC base A and base B modeling, and VISTAS model outputs at overlapping monitors. The average range ac ross the modeling domain is approximately +/- 0.8 ppb.

The two uncertainties above can be combin ed to give a conservative estimate of the uncertainty in future year projections. Standard error propagation techniques can be used, namely by squaring and adding the uncerta inties, and taking the square root of the sum to get the combined uncertainty. The combin ation gives an uncertainty in future year design values of 3.1 ppb.

7.8.2.7 Effect of Alternative Methods, Transport and Model Underpredictions on 2009 Design Values

Delaware has performed a WOE analysis fo r all of the monitors within the PA-NJDE-MD non-attainment area whose modeled 2009 8-hour ozone design values exceed 82 ppb. There are twenty-two (22) ozone monito rs currently operati ng in the PA-NJ-DE-MD non-attainment area. Of these monitors, only eight have modeled 2009 concentrations above 82 ppb. This by itself represents a significant improvement in air quality.

Of the eight monitors requiring a WO E analysis, two monitors (Roxboro and Camden) have 2006 design values less than 85 ppb. The Roxboro monitor is dropped from the WOE analysis since its 2006 design value is significantly below the current eight-hour ozone standard (78 ppb vs. 85 ppb sta ndard). For the remaining seven sites a number of analyses are undertaken to determin e if there is a reasonable chance these sites would meet the ozone standard by the June 2010 attainment date. These include a recent ozone trends analysis, alternative methods for developing baseline concentrations and RRFs, an analysis of regional transport and fina lly an assessment of the air-quality models response to emission changes.

Nearly all of the design values at the seve n monitors declined over the last several years. Only one, Rider College, had a slight increase. Table 7-10 s hows the last several years of design values at these seven monitors . It is expected that additional emission

reductions due to the NO

x SIP Call, mobile source reductio ns from fleet turnover as well

as additional measures will continue to lo wer monitor design values. If this trend75 continues, it is possible that mo st of these monitors will attain the standard in the next three to five years.

Table 7-10. Recent Design Value (ppb) Trends

Site 2003 2004 2005 2006

Camden 101 93 85 84

Ancora State Hospital 101 95 91 89

Clarksboro 98 94 88 86

Rider 99 91 86 87

Colliers Mills 106 99 94 93

Bristol 100 93 86 86

NE Airport 97 95 90 90

Note: Design values are in ppb.

Table 7-11 summarizes the results for the US EPA method as well as some alternative methods including alternative background concentrations calculations and

alternative RRF calculations as well as the results from em ploying both methods simultaneously. Descriptions of these alternative methods and the reasons for employing

them can be found in sections 7.8.2.3. Results from the alternative methods analysis indicate nearly all seven of the monitors will be near the standard by the projected

attainment date.

Table 7-11. Alternative Methods WOE

Modeled 2009

Site EPA Method Alt Baseline DV Alt RRF Both

Camden 88 83 87 83

Ancora State Hospital 87 85 87 85

Clarksboro 88 85 86 85

Rider 86 84 86 84

Colliers Mills 91 91 91 91

Bristol 88 85 88 85

NE Airport 87 84 84 84

Note: Design values are in ppb.

Regional transport is a significant contribu tor to the non-attainment problem in the PA-NJ-DE-MD region. An analysis of mode led ozone concentratio ns at the Methodist Hill site in south-central Pennsylvania, a hi gh elevation site, determined how well the76 OTC air-quality model simulated the region al transport component. The modeled 2009 concentration at Methodist Hill is approxima tely 6 ppb higher than the monitor’s current design value. This suggests the model is under predicting the benefits of the NO

x SIP Call in upwind regions. To counter this underestimation, a unifo rm reduction of 6 ppb could be

taken off the modeled 2009 concentrations at the seven monitors included in the WOE. This brings all values below the current eight -hour ozone standard (Colliers Mills adjusted to 85 ppb). The adjusted concentrations at the seven monitors are summarized in Table 7-

12.

Table 7-12. Adjustments in DVF Due To Model Under-prediction

of NOx SIP Call Benefits

Site 2009 DVF

w/Alt. baseline DV & RRF Adjustment 2009 DVF

w/Adjustment for NOx

SIP Call Benefits

Camden 83 76

Ancora State Hospital 85 78

Clarksboro 85 78

Rider 84 79

Colliers Mills 91 85

Bristol 85 79

NE Airport 84 78

Note: Design values are in ppb.

Now we take into consideration CMAQ’s underprediction of benefits from the Blackout Study and the affect of uncertainties as discussed previously. For the former, the modeled benefits are adjusted with a multipli cation factor of 1.5 and the latter by bounding the adjusted concentration with a 3.1 ppb. The ef fect of changes on future design values is

listed in Table 7-13.

Table 7-13. Adjustments in DVF Due To Model Underprediction of Benefits

Site Baseline

DV Modeled

2009 O3 Modeled

Benefit 1.5 x

Modeled

Benefit Adjusted

2009 DV Adjusted 2009 DV,

Lower Bound Adjusted 2009 DV,

Upper

Bound

Camden 98 88 10 15 83 79.9 86.1

Ancora

State Hospital 100 87 13 19.5 80 76.9 83.1

Clarksboro 98 88 10 15 83 79.9 86.1

Rider 97 87 10 15 82 78.9 85.1

Colliers 105 91 14 21 84 80.9 87.177 Site Baseline

DV Modeled

2009 O3 Modeled

Benefit 1.5 x

Modeled

Benefit Adjusted

2009 DV Adjusted 2009 DV,

Lower Bound Adjusted 2009 DV,

Upper

Bound

Mills

Bristol 99 88 11 16.5 82 78.9 85.1

NE Airport 97 87 10 15 82 78.9 85.1

Note: Design values are in ppb.

7.8.2.8 Delaware-specific Additional Control Measures

Delaware is implementing several measures that are not modeled as part of the SIP attainment demonstration, and these measures yield significant VOC and NOx reductions. Two of these measures are anti-idling pr ohibitions (Delaware Regulation No. 1145) and ozone action days (voluntary program), and th e potential reductions from these measures

are summarized in Table 7-14. These two measur es will help attain the standard in 2009.

Table 7-14. Potential Emission Reductions (tons/day) from Delaware-specific Measures Not Modeled

Control Measures NOx VOC Anti-idling 4.0 0.10 Ozone action days 1.0 – 2.0 0.5 – 1.0

In addition, mandatory episodic contro ls that were not modeled, such as Delaware’s prohibition of li ghtering on ozone action days (Reg. 1124, Section 36), and reduction of emissions from high electric de mand day electric generation (Reg. 1146 and Reg. 1148) will also gain very significant VOC and NOX reductions, and will help reduce future exceedances of the ozone NAAQS.

7.8.2.9 Reserved.

7.8.2.10 Statistical Rollba ck to Estimate RRFs

Environmental data commonly exhibits as lognormal rather than a normal

distribution. The effect of control measures on the monitored is generally studied by combining the lognormal distribution with st atistical theory of rollback. Georgopoulos

and Seinfeld described the NO2 concentrations with a 2-parameter log-normal distribution and determined the post-control concentrations by this approach (R eference 7-11). The source control theory is applic able to any distribution (Reference 7-12). Delaware extends this approach to demonstrate that a range of RRFs can be derived from the CMAQ

modeled results.

Figure 7-7 shows the density plot of l og CMAQ concentrations for 2002 base case that exceed 70 ppb at the monitor; this also includes concentra tions within th e 3x3 cells of the monitor. The figure also shows the plot for the corresponding 2009 CMAQ concentrations. Cumulative frequencies are derived and plotted for both cases (Figure 7- 8). The effectiveness of contro ls on the base case can be read for any probability and then78 determine the corresponding RRF. For exampl e, for a cumulative probability of 1, modeled concentrations of the base case (red) and the future case (blue) can be read, and

the ratio of the two determines the RRF. It can also be seen that the control measures are

more effective at lower ozone levels than at upper extremes. The RRFs determined this way differ for every probability yielding a range of RRF numbers, upper bound of which is more protective of NAAQS. The upper bound of the RRF derived by this method (~0.7), yields the future design valu e at Colliers Mills to be 74 ppb.

4.2 4.3 4.4 4.5 4.6 4.7012345 Colliers Mills-2002-ln(O3) PDF

N = 256 Bandwidth = 0.02Density

3.2 3.4 3.6 3.8 4.0 4.2 4.401234 Colliers Mills-2009-ln(O3) PDF

N = 256 Bandwidth = 0.02Density

Figure 7-7. Density Plots of Log CM AQ Concentrations for 2002 Base

and 2009 Cases79 Figure 7-8. Frequency Distributions of 2002 Base and 2009 CMAQ Ozone Concentrations (log-log Plot)

7.9 Conclusions

The CMAQ modeling results presented above show that of the 22 monitors in the PA-NJ-DE-MD non-attainment area only 8 monitors have predicted 2009 modeled concentrations above 82 ppb. This represents in a significant improvement in air quality.

The WOE analyses presented above incl ude a recent ozone trends analysis,

alternative methods for devel oping baseline concentrations and RRFs, an analysis of regional transport, an assessment of the air- quality models response to emission changes, the identification of several Delaware-specific control measures that were not included in the modeling, and a statistical rollback approach analysis.

Of the WOE analyses presented above, th e alternative methods of developing baseline design values and RRFs indicate that 2009 projected design values will likely be below 85 ppb for all monitors except for Colliers Mills, whic h is projected at 91 ppb. Monitoring results at Method Hill monitor proved that the model is likely over predicting the concentrations by at least 6 ppb. Applying this correction to the 2009 design values indicates that all the monitors, including Co lliers Mills will likel y be below 85 ppb in 2009. Furthermore, the correction for CM AQ’s underprediction of benefits and uncertainties in outputs due to meteorology and emissions bounds the Colliers Mills design values in the range of [80.9, 87.1] ppb. In addition, the statistical rollback approach provided an indication that a range of RRFs is likely and that an upper bound at80 the Colliers Mills monitors would be at approximately 74 ppb, thus providing an

indication that all monitors in the non-attainment area are likely to attain the NAAQS.

The 2006 monitored design values are al ready at 2009 model predicted design values, with the trends analyses of the mon itored values giving a st rong indication that all

the monitors in the non-attainment area will attain the NAAQS in 2009. Additional Delaware-specific control measures, which are not part of the 2009 OTB/OTW measures, will prove beneficial in reducing the ozone conc entrations below the standard. It is also expected that additional emissi on reductions due to CAIR, mobile source reductions from

fleet turnover as well as other additional meas ures, will continue to lower monitor design values beyond 2009.

The photochemical grid modeling presente d above indicates that the control

measures will reduce the 8-hour ozone levels to below 85 ppb at most of the monitors in the non-attainment area, whereas the unmonitored area analys is provides evidence that all

unmonitored areas in the non-attainment area wi ll attain the 8-hour ozone levels in 2009.

Together, all of the WOE analyses disc ussed above provides a strong indication

that downward trend of ozone le vels will continue and all monitors will be below the 85 ppb 8-hour ozone standard in 2009.

References

7-1. Technical Supporting Document, Final Report , Ozone Transport Assessment Group (OTAG), Office of Air Quality Planning & Standards, U.S. Environmental Protection Agency, Technol ogy Transfer Network, 1997.

7-2. NOx Budget Trading Program Report: 2005 Program Compliance and

Environmental Results , U.S. Environmental Protection Agency, September 2006.

7-3. Evaluating Ozone Control Programs in the Eastern United States: Focus on the NOx Budget Trading Program, Air Trends Report , U.S. Environmental Protection Agency, 2004, http://www.epa.gov/airtrends/2005/ozonenbp/

. 7-4. Guidance on the Use of Models and Other A nalyses in Attainment Demonstrations for the 8-hour Ozone NAAQS (Final version) , U.S. Environm ental Protection Agency, 2005.

7-5. Delaware protocol for the modeled attain ment demonstration of the 8-hour ozone NAAQS , Air Quality Management Section, De partment of Natural Resources and Environmental Control, D over, Delaware, June 2006. 7-6. Zurbenko, I. G., 1986: The spectral Analysis of Time Series . North-Holland. 7-7. I. Zurbenko, P.S. Porter, S.T. Rao, J.Y. Ku, R. Gui, R.E. Eskridge, 1996: Detecting Discontinuities in Time Series of U pper-air Data: Development and Demonstration of an Adaptive Filter Technique . Journal of Climate, Vol. 9, No. 12, pp. 3548 3560. 7-8. Kevin L. Civerolo, Elvira Bra nkov, S. T. Rao, Igor Zurbenko, 2001: Assessing the impact of the acid de position control program . Atmospheric Environment, 35: 4135-

4148. 7-9. Jeffrey Stehr, Charles Piety, Dale Allen, 2007: Uncertainty in CMAQ and Overpredictions of Future Year Ozone Design Values

, WOE Chapter 9. 7-10. Hu, Y., M. T. Odman, and A. G. Russell, 2006: Re-examination of the 2003 North

American electrical blackout impacts on regional air quality , Geophys. Res. Lett

. , 33, L22810, doi:10.1029/2006GL027252.81 7-11. Georgopoulos, Panos G. and Seinfeld John H, 1982: Statistical Distribution of Air

Pollutant Concentrations , Environmental Science and Technology, 16(70):401A416A. 7-12. Wayne R Ott, 1995: Environmental Statistics and Data Analysis , CRC Press, Inc.82 8. Reasonably Available Control Measure (RACM) Analysis

8.1 RACM Analysis Requirements

The CAAA and 40 CFR 51.912(d) impose a Reasonably Available Control Measures (RACM) requirement for areas designated non-attainment for the 8-hour NAAQS. According to this requirement, Delawa re must demonstrate that it has adopted all RACM controls necessary to move toward attainment as expeditiously as practicable and to meet all RFP requirements.

8.2 RACM Determination

Sections 5, 6 and 7 of this document de monstrate that the RFP requirements for Delaware have been met, and that attain ment will be reached in 2009. The RFP and

attainment demonstration are based on the contro l measures identified in Sections 6 and 7

of this document. Additional RACM measures must be implemente d if such measures

will advance the attainment date to 2008.

Control measures under the Reasonably Available Control Technology (RACT) constitute a major group of RA CM control measures for sta tionary sources. To meet the CAA’s RACT requirements under the 8-hour ozone standard, Delaware has submitted to EPA a RACT SIP revision, which certifies in detail that a ll relevant RACT controls, except one control, have been implemented in Delaware for attaining the 8-hour ozone standard (Reference 8-1). The one excepti on, the VOC control for crude oil lightering operations, has been completed since the RA CT SIP revision was submitted to the EPA, and become effective in May 2007. A list of all these adopted RACT measures is extensive, and is detailed in th e RACT SIP revision (Reference 8-1).

In addition to the RACT control measures discussed above, De laware has adopted

a number of other VOC and NOx RACM m easures. These measures include the tightening of Delaware’s Open Burning Regulation (Delaware Air Pollution Control Regulation No. 1113), Control of Stationary Generator Emissions (Delaware Air Pollution Control Regulation No. 1144), restrictions on Excessive Idling of Heavy Duty Vehicles (Delaware Air Pollution Control Regulation No. 1145), Control of Stationary Combustion Turbine Emissions (proposed Regulation No. 1148) , and measures such as the Brandywine

School Districts Clean School Bus USA grant, and voluntary and mandatory Ozone Action Day initiatives.

Delaware believes that it has met the RACM requirements of the CAA. To

demonstrate that there are no additional RA CM measures, or group of RACM measures that DE could adopt to adva nce the attainment date from 2009 to 2008, Delaware analyzed zero out modeling using CALGRID (see Appendix 8-1). This modeling indicates that

Delaware’s total maximum contribution to the worst case monitor in the Philadelphia Nonattainment area (i.e., the Collars Mills mo nitor in Ocean County, NJ) is about 7 ppb (Figure 8-1).83 Figure 8-1. Delaware Zero-Out Modeling Results For Estimating

Contribution to Ozone Concentration

In its zero-out modeling for CAIR (usi ng CAMx), EPA assessed the impact of each upwind state on a number of downwin d counties, including Ocean County, NJ (Appendix G, Technical Supporting Document of Reference 8-2). The individual

maximum 8-hour ozone contributions from each upwind state PA, MD, VA, NC, DE, OH, WV, and MI are 31.6, 1.24, 11.6, 7.1, 6.5, 4.0, 3.6, and 3.5 ppb, respectively. It should be noted that (1) not all the impacting states are listed here, and (2) the total out-of-state

contribution to ozone concentrations in Ocea n County, NJ is predicted by CAIR modeling to be 86% of 95 ppb = 85 ppb (see below)). The CAMx zero-out c ontribution of 6.5 ppb

from Delaware is consistent with Delawa re’s 7 ppb estimate from CALGRID zero-out modeling.

Table VIII-11 of EPA’s Inte rstate Air Quality Rule technical supporting document (Reference 8-2) also lists the projected 8-hou r ozone design values and the percent total average contribution resulti ng from emissions in upwind states. For example, the projected 2010 design value for Ocean County, NJ is 99 ppb of which 86% (i.e., 85 ppbs) of ozone is due to out-of-state transport. Of these 85 ppbs, the maximum Delaware contribution is only 6.5 ppb or 4.2%.84 From Section 7 of this document, a ll local and regional emission reductions planned to occur by 200 9 project the entire Philadelphia no n-attainment area to attain by 2009, and project a reduction in Ocean County NJ (i.e., the location of the worst case monitor in the non-attainment area) ozone c oncentrations from 106 ppb to about 85 ppb (i.e., about 21 ppb reduction). Significant emission reductions occur between 2008 and 2009 due to Federal programs lik e CAIR, and mobile reductions from the penetration of federal rules due to fleet turnover. Therefore, even if Delaware were able to zero out its 7 ppb contribution, Ocean County will remain non- attainment unless a majority of these

other measures were also advanced to 2008. Since a large portion of these significant reductions cannot be advanced, as the CAIR and Federal mobile reduction compliance dates are set, and since Delaware’s overall impact is relatively small compared to the

benefit obtained from these measures whic h cannot be advanced from 2009 to 2008, there

are no additional RACM measures DE can take to advance the attainment date to 2008.

References

8-1. Delaware Reasonably Available Control Te chnology (RACT) State Implementation
Plan under the 8-Hour Ozone Natio nal Ambient Air Quality Standard

, Delaware Department of Natural Resources and Environmental Control, Air Quality Management Section, Dover, Delaware, submitted to EPA in September 2006.

8-2. Technical Support Document for the Inters tate Air Quality Rule: Air Quality Modeling Analyses , US EPA, January 2004

.85 9. Mobile Budgets for Transportation Conformity

9.1 Introduction to Transportation Conformity

Section 176 of the Clean Air Act requires that highway transpor tation activities in ozone non-attainment areas must not impair progress in air quality improvements. In general, this requirement specifies that (1) states establish, in their state implementation plans (SIP), mobile source VOC and NOx emission budgets for each of the milestone years up to 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 thei r 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 de monstrating such transportation conformity in TIPs and long range plans will lead to c onformity lapse(s), resu lting in freezing of federal highway funds and all federal hi ghway projects in th e lapsed area.

According to EPA’s Phase 2 Implementation Rule ( 70 FR 71612 ), Delaware is required to establish mobile budgets for th e year 2008 (the 15% RFP emission reduction milestone year) and the year 2009 (the attainment year). To meet this requirement, Delaware has developed a mobile budget SIP revision and submitted to EPA in May 2007 (need to revise to the final submittal date). The final submittal of that SIP revision is presented in Appendix 9-1 of this document.

This section is a summary of De laware’s mobile budget SIP revision.

9.2 Mobile Budgets for 2008 and Attainment Year

The mobile emissions budgets for 2008 RFP milestone and 2009 attainment are based on the projected 2008 and 2009 mobile s ource emissions, accounting for all relevant

mobile source controls includi ng all federal controls and Delaware specific controls as

described in Section 6. The 2008 and 2009 mob ile emissions are projected using EPA’s MOBILE6.2 for obtaining emissi on factors and the “Peninsula Travel Demand Model” for predicting future vehicle mile s traveled (VMT). The MOBI LE6.2 runs were conducted by AQM’s staff using the most recent available ve hicle registration data and speed estimates (2005). Details of how to calculate the 2008 and 2009 mobile emission projections are presented in Appendix 9-1.

9.2.1 Mobile Budgets for 2008 RFP Milestone Year

Table 9-1 is a summary of 2008 mobile sour ce emission projections for each of the

three counties in Delaware. Delaware herein establishes county-by-county VOC and NOx emission budgets for each county as specified in Table 9-1 for the milestone year 2008.

Table 9-1. On-Road Mobile Source Emission Projections for 2008

2008 Emissions
County FIPS VOC NOx

Kent 10001 4.14 9.68

New Castle 10003 10.61 21.35

Sussex 10005 7.09 12.8686 State Total 21.84 43.89

9.2.2 Mobile Budgets for 2009 Attainment Year

Table 9-2 is a summary of 2009 mobile sour ce emission projections for each of the

three counties in Delaware. Delaware herein establishes county-by-county VOC and NOx emission budgets for each county as specified in Table 9-2 for the a ttainment year 2009.

Table 9-2. On-Road Mobile Source Emission Projections for 2009

2009 Emissions
County FIPS VOC NOx

Kent 10001 3.95 9.04

New Castle 10003 9.89 19.23

Sussex 10005 7.05 11.93

State Total 20.89 40.2087 10. Contingency Measures

10.1 Requirements on Contingency Measures

The CAAA requires States with non-attainment areas to implement specific control

measures if the area fails to make reasonable fu rther progress, fails to meet any applicable milestone, or fails to attain the national ambi ent air quality standard s by the applicable attainment date. The EPA has interpreted this CAAA provision as a requirement for States

with moderate and above ozone non-attainme nt areas to include sufficient contingency

measures in their RFP and attainment demons tration so that, upon implementation of such measures, additional emission reductions of at least 3% of the adjusted 2002 baseline emissions would be achieved (Reference 10-1) . Under the same provision of the CAAA, EPA also requires that the contingency measur es must be fully-adopt ed control measures or rules, so that, upon failure to meet milestone requirements or to attain the standards, the contingency measures can be implemented w ithout any further rule making activities by

the States and/or EPA.

To meet the requirements for contingenc y emission reductions, EPA allows States

to use NOx emission reductions to substitute for VOC emission reductions in their contingency plans. The condition set forth by EPA for NOx substitution is that States

must achieve a minimum of 0.3% VOC reductions of the total 3% co ntingency reduction, and the remaining 2.7% reduction can be achieved through NOx emission controls (Reference 10-2). Delaware is including both VOC and NOx emission controls as contingency measures in this 8-hour oz one RFP and Attainment Demonstration SIP

revision.

10.2 Contingency Measures for 2008 Milestone Year

Based on CAAA and EPA requirements on co ntingency measures, the contingency

VOC reduction for Delaware for the 2008 milest one year can be estimated as follows:

The 2002 VOC baseline (state-wide) adjusted to 2008 (See Tables 4-3 and 4-4): 111.36 TPD Contingency VOC emission reduction in 2008: 111.36 x 3 % = 3.34 TPD

Analysis in Subsection 5.5 indicates that the three counties in Delaware together will have a VOC emission reduction surplus of 1.82 TPD in 2008 [i.e., (33.00 + 61.66) – (32.13 + 60.71) = (94.66 - 92.84) = 1.82]. Therefore, there is a 3.34 – 1.82 = 1.52 TPD contingency VOC reduction shortfall in 2008.

Delaware’s 2002 VOC-to-NOx baselin e (with respect to 2008) ratio is (38.82+72.54):(55.95+137.34) = 111.36:193.29 = 1:1.74 (See Tables 4-3 and 4-4 in Section 4). Therefore, the above contingenc y VOC reduction shortfa ll is equivalent to

1.52 x 1.74 = 2.64 TPD NOx reduction shortfall.

As discussed in Subsections 5.4 and 6.4, Delaware has implemented numerous controls, which will lead to NOx emission re ductions in 2008. For example, Subsection

5.4.3 indicates that all three c ounties in Delaware will achieve significant NOx emission reductions in 2008, which are greater than th e identified 2.64 contingency shortfall.88 Therefore, there is no need to specify a dditional contingency measures for the 2008 milestone year.

10.3 Contingency Measures for 2009 Attainment Year

In January 2007, Delaware participated with the OTC in proposing a list of

additional controls as model rule s to aid the OTR states to atta in the 8-hour ozone standard in 2009 (Appendix 10-1). As part of this c ontingency plan, Delaware commits to adopt the following model rules in May 2008 with a compliance date of May 1, 2009:

(1) Consumer Products. (2) Portable Fuel Containers. (3) Adhesives and Sealants Application.

According to OTC’s technical supporting document for (1), (2) and (3), adopting

these OTC model rules in Delaware w ill lead to 1.2 TPD VOC reduction in 2009 (Appendix 10-2). The percentage of these 3 c ontrols relative to the 2002 VOC baseline

can be estimated as follows:

The 2002 VOC baseline (state-wide) adjusted to 2009 (See Tables 4-3 and 4-4): 111.28 TPD VOC Reduction representing % of 2 002 Baseline: 1.2/111.28 = 1.1%

As indicated in Subsection 6.5 of this SIP revision, Delawa re has 2.70 TPD NOx emission surplus that will be used for cont ingency purposes. The pe rcentage of the NOx surplus relative to the 2002 VOC ba seline can be estimated as follows:

The 2002 NOx baseline (state-wide) adjusted to 2009 (See Tables 4-3 and 4-4): 192.94 TPD NOx surplus representing % of 2002 Baseline: 2.70/192.94 = 1.4%

As discussed in Subsection 7.8.2.8 of this document, Delaware has implemented “ozone action days” (also known as “air quality alert days”) as vol untary control during the ozone season. The program provides an estimated 0.5-1.0 TPD VOC reduction and 1.0-2.0 TPD NOx reduction. Using the lower ends of the reduction ranges for conservative estimates, the percentages are:

For VOC: 0.5/111.28 = 0.4%

For NOx: 1.0/192.94 = 0.5%

The total achievable contingency % relative to the 2002 baseline is: VOC% + NOx% = (1.1% + 0.4%) + (1.4% + 0.5%) = 3.4%, and therefore meets the CAAA and EPA emission reduction requirements for c ontingency in the 2009 attainment year.

References

10-1. Guidance for Growth Factors, Project ions, and Control Strategies for the 15 Percent Rate-of-Progress Plans , EPA-452/R-93-002, U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research89 Triangle Park, North Carolina, March 1993.

10-2. Guidance on the Post-1996 Rate-o f-Progress Plan and the Attainment

Demonstration , Ozone/Carbon Monoxide Programs Branch, U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina 27711, February 18, 1994.90 11. Appendices

A collection of the listed appendixes, stored on CD, will be available upon written request to AQM-DAWM-DNREC, 156 Sout h State Street, Dover, DE 19901.

Appendix 4-1 Part 1: MOBILE6.2 Input and Output F iles for Delaware 2002, 2008 and 2009 Mobile Source Emission Adjustments

. Part 2: Calculations of the Adjusted 2002, 2008 and 2009 On-Road Mobile Source Emission Projections. Appendix 6-1 Development of Emission Projections for 2009, 2012, and 2018 for Non-EGU Point, Area, and Non-road Sources in the MANE-V U Region, Draft Final Technical Support

Document , Prepared for Mid-Atlantic Regi onal Air Management Association (MARAMA) by MACTEC Federal Programs, Inc., December 7, 2006. Appendix 6-2 The 2009 Emission Projections of Delawa re Non-EGU, Non-Point and Non-Road

Mobile Sources. Appendix 6-3 Part 1: MOBILE6.2 Input and Output Files for Delaware 2008 and 2009 Mobile Source Emission Projections

. Part 2: Calculations of 2008 and 2009 On -Road Mobile Source Emission Projections Appendix 7-1 A Modeling Protocol for the OTC SIP Quality Modeling System for Assessment of the Ozone National Ambient Air Quality Standard in the Ozone Transport Region , The Modeling Committee of the Ozone Tr ansport Commission (OTC), OTC, 2000. Appendix 7-2 Technical Supporting Document 1d: Th e 8-hour Ozone Modeling Using the SMOKE/CMAQ System , Bureau of Air Quality Analysis and Research, Division of Air Resources, New York State De partment of Environmenta l Conservation, Albany, NY, February 2006. Appendix 7-3 Determination of Repres entativeness of 2002 Ozone Season for Ozone Transport Region SIP Modeling , Prepared for OTC, Prepared by Environ, June 2005. Appendix 7-4 Qualitative Episode Analysis of the 2002 Ozone Season, William F. Ryan, Department of Meteorology, Pennsylvania State Univers ity, and Charles Piety, Department of Atmospheric and Oceanic Science, University of Maryland, 2002. Appendix 7-5 Technical Supporting Document 1a: Meteorol ogical Modeling us ing Penn State/NCAR

5 th Generation Mesoscale Model (MMV) , Bureau of Air Quality Analysis and

Research Division of Air Re sources, New York State Department of Environmental Conservation Albany, NY, February 2006. Appendix 7-6 Technical Supporting Document 1e: CMAQ Model Performance and Assessment- 8- Hour Ozone Modeling , Bureau of Air Quality Analysis and Research, Division of Air Resources, New York State Department of Environment, Albany, NY, February 2006. Appendix 7-7 Technical Supporting Document 1b: Pr ocessing of Biogenic Emissions for OTC/MANE_VU Modeling , Bureau of Air Quality Analys is and Research, Division of91 Air Resources, New York State Department of Environment, Albany, NY, September

2006. Appendix 7-8 Technical Supporting Document 1c: Emi ssion Processing for the Revised 2002 OTC Regional and Urban 12 km Base Case Simulations , Bureau of Air Quality Analysis and Research, Division of Air Resour ces, New York State Department of Environment, Albany, NY, September 2006. Appendix 7-9 Technical Supporting Document 1f: Future Ye ar Emissions Invento ry for 8-Hr OTC Ozone Modeling , Bureau of Air Quality Analysis and Research, Division of Air Resources, New York State Department of Environment, Albany, NY, February 2007. Appendix 7-10 The Nature of the Ozone Air Quality Pr oblem in the Ozone Transport Region: A Conceptual Description , NESCAUM, October 2006. Appendix 7-11 A Conceptual Model for Ozone Transport

, Prepared by Dr. Robert Hudson, Department of Atmospheric & Science, University of Maryland, January 2006. Appendix 7-12 A Guide to Mid-Atlantic Regional Air Quality

, Mid-Atlantic Regional Air Management Association (MARAMA), October 2005. Appendix 7-13 Technical Supporting Document aa: Trends in Measured 1-hour Ozone Concentrations over the OTR modeling domain

, Bureau of Air Quality Analysis and Research, Division of Air Resources, New Yo rk State Department of Environment, Albany, NY, September 2006. Appendix 8-1 CALGRID Zero Out Modeling Analysis, Mo hammed A. Majeed, Ph.D. and P.E., Air Quality Management Section, Delaware Department of natural Resources and Environmental Control, Dover, DE, May 2007 Appendix 9-1 Delaware State Implementation Plan for Attainment of the 8-Hour Ozone National Ambient Air Quality Standard, Revision for Establishment of 2008 and 2009 Mobile Source Emission Budgets , Delaware Department of Natural Resources and Environmental Control, Air Quality Mana gement Section, Dover, Delaware, May

2007. Appendix 10-1 Identification and Evaluation of Candidate Control Measures, Draft Final Technical Support Document , Prepared for Ozone Transport Commission (OTC), Prepared by MACTEC Federal Programs, Inc ., Herndon, Virginia, February, 2007