Final Submittal

DELAWARE STATE IMPLEMENTATION PLAN 

FOR ATTAINMENT OF THE 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 2007 
ii 

[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 and 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 Regarding 8-Hour Ozone ---------------- 11 

3. Delaware 2002 Base Year Emission 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 Inventory 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 Year--------------------------------------------- 23 

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

5.1 Point Source Control Measures and Reduction Estimates -------------------------- 24 

5.2 Area Source Control Measures and Reduction Estimates --------------------------- 27 

5.3 Non-Road Mobile Sources Control Measures and Reduction Estimates ---------- 27 

5.4 On-Road Mobile Source Control Measures and Reduction Estimates ------------- 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 Inventory ----------------------------------------- 41 

6.3 Non-Road Mobile Source Projection Inventory --------------------------------------- 51 

6.4 On-Road Mobile Source Projection Inventory --------------------------------- 54 

6.5 Delaware 2009 Emission Projections for All Source Sectors ----------------------- 54 

7. Attainment Demonstration Modeling and Weight-of-Evidence Analysis ----------57 

7.1. Background and Objectives ------------------------------------------------------------- 57 

7.2. Photochemical Modeling System -------------------------------------------------------58 
iv 

7.3. Ozone Episode Selection ---- -------------------------------------------------------------59 

7.4. Meteorological Fields ---------------------------------------------------------------------60 

7.5. Model Performance Evaluation ----------------------------------------------------------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 Requirements-----------------------------------------------------------82 

8.2 RACM Determination --------------------------------------------------------------------- 82 

9. Mobile Budgets for Transportation Conformity ----------------------------------------85 

9.1 Introduction to Transportation Conformity -------------------------------------------- 85 

9.2 Mobile Budgets for 2008 and Attainment Year --------------------------------------- 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 -------------------------------------------------------------------------------------90
v 

Executive Summary 

 

In April 2004, the Environmental Protection Agency (EPA) designated 126 areas 

of the country as “non-attainment” under the 8-hour ozone National Ambient Air Quality 

Standard (NAAQS). Among those non-attainment areas is the Philadelphia-WilmingtonAtlantic City (PA-NJ-MD-DE) Moderate Non-Attainment Area (NAA). This NAA 

includes three counties in Delaware, five counties in eastern Pennsylvania, one county in 

Maryland and eight counties in southern New Jersey. According to the federal Clean Air 

Act (CAA), this entire NAA must attain the 8-hour ozone NAAQS by 2010. 

Ground level ozone, one of the principal components of “smog,” is a serious air 

pollutant that harms human health and the environment. High levels of ozone can damage 

the respiratory system and cause breathing problems, throat irritation, coughing, chest 

pains, and greater susceptibility to respiratory infection. High levels of ozone also cause 

serious damage to forests and agricultural crops, resulting in economic losses to logging 

and farming operations. 

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

meeting the requirements associated with the 8-hour ozone NAAQS. Specifically, this 

SIP revision: 

• Fulfills the federal Clean Air Act’s requirements for Reasonable Further Progress 

(RFP) and Attainment Demonstration (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 proposed controls, Delaware will meet the RFP 

requirements on VOC and NOx emission reductions 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 attain the 8-hour ozone NAAQS in 2009. 

• Confirms Delaware’s 2008 and 2009 mobile source budgets for transportation 

conformity determination. 

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

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

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

DNREC - Delaware Department of Natural Resources and Environmental 

 Control 

DOE - US Department of Energy 

EGAS - Economic Growth Analysis System 

EGU - Electric Generating Unit 

EIA - Energy Information Administration 

EID - Emission Inventory Development Program of AQMS 

EPA - United States Environmental Protection Agency 

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 Regional 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 Available Control Measure 
vii 

RACT - Reasonably Available 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 Air Pollution Program Administrators 

TIP - Transportation Improvement Program 

TSD - Technical Supporting Document 

VMT - Vehicle Miles Traveled 

VOC - Volatile Organic Compound 
viii 

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 Values (ppm) of New Jersey Counties in 

Philadelphia CMSA --------------------------------------------------------------------7 

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

Philadelphia CMSA --------------------------------------------------------------------7 

Table 2-6. Delaware 8-Hour Ozone Design Values by County -------------------------------7 

Table 2-7. Number of Days Exceeding 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 Delaware 2002 Base Year Inventory -----------------14 

Table 3-2. Non-Point Source Categories in Delaware 2002 Base Year Inventory ---------17 

Table 3-3. Delaware 2002 Base Year VOC Emissions in Tons per Day -------------------19 

Table 3-4. Delaware 2002 Base Year NOx Emissions in Tons per Day --------------------19 

Table 4-1. Mobile Source FMVCP/RVP Adjustments 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 Inventory for Sussex County ----------------------22 

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

Table 5-1. Emission Reductions from Facilities Shutdown after 2002 ----------------------25 

Table 5-2. Emission Reduction Credits and Holding Facilities/Agency --------------------26 

Table 6-1. Delaware 2009 VOC and NOx Emission 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 Projections -----------------------------------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 Emission Projections (TPD) for Non-Point 

Sources Revised from MACTECs Projections ----------------------------------43 

Table 6-7. Delaware 2009 NOx Emission Projections (TPD) for Non-Point 

Sources Revised from MACTEC’s Projections ----------------------------------49 

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

Non-Point Sources Not Revised from MACTEC’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 Mobile Source Emission Projection 

Summary --------------------------------------------------------------------------------54 
ix 

Table 6-12. Delaware 2009 All-Source Emission Projection Summary ---------------------54 

Table 7-1. Summary of Model Attainment Test Results --------------------------------------62 

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

Evidence Determinations -------------------------------------------------------------65 

Table 7-3. Comparison of Modeled 2009 and Projected 2006 Ozone 

Design Values --------------------------------------------------------------------------66 

Table 7-4. Alternative Baseline Concentration Analysis --------------------------------------70 

Table 7-5. Alternative RRF Calculation Analysis ----------------------------------------------71 

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

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

Alternative RRFs ----------------------------------------------------------------------72 

Table 7-8. Methodist Hill Statistics, Proxy for 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 Benefits ------------ 76 

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

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

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

Table 9-2. On-Road Mobile Source Emission Projections for 2009 -------------------------86 
x 

List of Figures 

 

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

Moderate Non-Attainment Area for the 8-Hour Ozone NAAQS -------------- 2 

Figure 2-1. Delaware Ozone Monitoring Network 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 Individual Monitors ------------------------- 10 

Figure 7-1. The 8-Hour Ozone CMAQ Modeling 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 CMAQ Concentrations for 2002 Base and 

2009 Cases ---------------------------------------------------------------------------- 78 

Figure 7-8. Frequency Distributions of 2002 Base and 2009 CMAQ 

Ozone Concentrations (log-log Plot) ---------------------------------------------- 79 

Figure 8-1. Figure 8-1. Delaware Zero-Out Modeling Results For Estimating 

Contribution to Ozone Concentration --------------------------------------------- 83 
xi 

List of Appendixes 

 

Appendix 4-1 

Part 1: MOBILE6.2 Input and Output Files 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-VU Region, Draft Final Technical Support 

Document, Prepared for Mid-Atlantic Regional Air Management Association 

(MARAMA) by MACTEC Federal Programs, Inc., December 7, 2006. 

Appendix 6-2 

The 2009 Emission Projections of Delaware 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 Transport Commission (OTC), OTC, 2000. 

Appendix 7-2 

Technical Supporting Document 1d: The 8-hour Ozone Modeling Using the 

SMOKE/CMAQ System, Bureau of Air Quality Analysis and Research, Division of Air 

Resources, New York State Department of Environmental Conservation, Albany, NY, 

February 2006. 

Appendix 7-3 

 Determination of Representativeness 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 University, and Charles Piety, Department of 

Atmospheric and Oceanic Science, University of Maryland, 2002. 

Appendix 7-5 

Technical Supporting Document 1a: Meteorological Modeling using Penn State/NCAR 

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

Research Division of Air Resources, 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: Processing of Biogenic Emissions for 

OTC/MANE_VU Modeling, Bureau of Air Quality Analysis and Research, Division of 

Air Resources, New York State Department of Environment, Albany, NY, September 

2006. 

Appendix 7-8 
xii 

Technical Supporting Document 1c: Emission Processing for the Revised 2002 OTC 

Regional and Urban 12 km Base Case Simulations, Bureau of Air Quality Analysis 

and Research, Division of Air Resources, New York State Department of 

Environment, Albany, NY, September 2006. 

Appendix 7-9 

Technical Supporting Document 1f: Future Year Emissions Inventory 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 York State Department of Environment, 

Albany, NY, September 2006. 

Appendix 8-1 

 CALGRID Zero Out Modeling Analysis, Mohammed 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 Management 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 
1 

1. Introduction and Background 

 

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

meeting the requirements of Reasonable Further 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 Environmental Protection Agency (EPA) in 1997. The 

document also demonstrates that Delaware, 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. The document is hereafter referred to as 

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

1.1 Background and Requirements 

Ground level ozone, one of the principal components of “smog,” is a serious air 

pollutant that harms human health and the environment. High levels of ozone can damage 

the respiratory system and cause breathing problems, throat irritation, coughing, chest 

pains, and greater susceptibility to respiratory infection. High levels of ozone also cause 

serious damage to forests and agricultural crops, resulting in economic losses to logging 

and farming operations. In April 2004, EPA designated 126 areas of the 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 three counties in Delaware, five counties in 

eastern Pennsylvania, one county in Maryland, and eight counties 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 the atmosphere; rather it is formed in the 

atmosphere by photochemical reactions between volatile organic compounds (VOC), 

oxides of nitrogen (NOX), and carbon monoxide (CO) in the presence of sunlight. 

Consequently, in order to reduce ozone concentrations in the ambient air, the Clean Air 

Act Amendments of 1990 (CAAA) requires all non-attainment areas to apply controls on 

VOC and NOX emission sources to achieve emission reductions.1 

Among effective control measures, the Reasonably Available Control Technology 

(RACT) controls are a major group for reducing VOC and NOX emissions from stationary 

sources. Section 182 of the CAAA sets forth 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 correction 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 marginal and attainment areas in ozone transport 

regions (OTRs) established pursuant to section 184 of the CAAA, and requires these nonattainment areas to implement RACT controls on all major stationary VOC and NOX

emission sources and on all sources and source 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-Wilmington-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, and is therefore subject to the 

CAAA’s RACT control requirements. Delaware 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 requires that all moderate nonattainment areas for ozone achieve “Reasonable Further Progress (RFP)” toward 

attainment of the ozone NAAQS. In September 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 meet 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 that 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 Columbia 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 achieved prior to the ozone season of 2009 

(i.e., before May 1, 2009). 

(3) The NAA must demonstrate, through regional air quality modeling and weight-ofevidence analysis, that with the emission reductions meeting the above 2 

requirements the NAA will successfully attain 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 requirements 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 measures in this ozone SIP revision also serve as 

maintenance measures for maintaining the attainment 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 were 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 planning requirements that are more stringent 

than those required for moderate non-attainment areas. For Kent and New Castle 

Counties, the more stringent requirements that remain in force under the 8-hour ozone 

standard include: 

(1) A lower major source NOX and VOC threshold for point sources of 25 tons per 

year (TPY). 

(2) A requirement for new or expanding major 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 under 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-attainment new source review requirements of the 

CAA are met for Delaware through the requirements of existing Delaware Air Pollution 

Control Regulation No. 25 (Preconstruction Review, Reference 1-2). 

It should be pointed out that while only the control measures that produce post2002 emission reductions are specifically creditable towards 8-hour ozone reasonable 

further progress (RFP) and attainment demonstration (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 revisions under the 1-hour ozone standard will remain as valid 

and necessary measures to aid in the attainment and maintenance of both the 1-hour and 

the 8-hour ozone NAAQS. For a complete review of the 1-hour ozone control measure, 

please see References 2-1, 2-2 and 2-3. 

To prevent significant contribution to the ozone non-attainment or interference 

with maintenance of the ozone standard in downwind states, Delaware has adequate 

provisions in its ozone SIP revisions and regulations, including both pre- and post-2002 
4 

measures, and under the Federal Implementation Plan (FIP). For a complete review of the 

relevant provisions, please see References 2-1, 2-2 and 2-3. 

In addition, both Delaware’s air permitting regulations (e.g., Regulations #2, #25 

and #30, Reference 1-2) and Delaware state law (7 Del. Code, Chapter 60) provide the 

Secretary of the Department of Natural Resources 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 Resources and Environmental Control (DNREC), 

Division of Air and Waste Management, Air Quality Management Section (AQMS), under 

the Section Administrator, Ali Mirzakhalili. The working responsibility 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 completing 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 Inventory Program, is the 

supporting lead for the 2002 base year emission inventory; 

• Betsy Frey, Scientist, is the supporting lead for ozone monitoring data and trend 

analysis; 

• Phillip A. Wheeler, Planner, is the supporting lead for the on-road mobile source 

emission projections, and in charge of transportation conformity part; 

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

staff for future-year emission projection inventories. 

 

Specific responsibilities of other programs, agencies and contractors will be 

explained in the relevant sections of this document. 

References 

1-1. Delaware Reasonably Available Control Technology (RACT) State Implementation 

Plan (SIP) under the 8-Hour Ozone National Ambient Air Quality Standard 

(NAAQS), Delaware Department of Natural Resources 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 and 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 monitoring network in late 1980s under the 1-

hour ozone standard. The network was modified and approved by EPA in 1995 for 

meeting the then-upcoming 8-hour ozone standard. 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-attainment areas, while Sussex County was a 

marginal non-attainment area; and the whole state was a part of an ozone transport region 

established under Section 184 of the CAAA. Section 181 of CAAA required Delaware to 
6 

attain the 1-hour ozone standard in Sussex County by 1993 and in Kent and New Castle 

Counties by 2005. To meet this requirement, Delaware implemented 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 measures, measures implemented nationally by 

EPA, and measures taken by upwind states, Delaware’ 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. According 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 Exceedance 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 database for air monitoring data, Air Quality 

System (AQS), indicates that other counties 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 Philadelphia CMSA, Table 2-4 presents the 1-hour 

ozone design values for counties in Pennsylvania within the Philadelphia CMSA, and 

Table 2-5 presents the 1-hour ozone design values for counties in New Jersey within the 

Philadelphia CMSA. Data in Tables 2-1 through Table 2-5 indicate clearly that the entire 

Philadelphia CMSA attained the 1-hour ozone standard in 2005, and 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 0.101 
7 

Table 2-4. The 1-Hour Ozone Design Values (ppm) of New Jersey Counties in 

Philadelphia CMSA 

Period Camden Cumberland Gloucester 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 counties within each area. Under the 8-hour ozone standard 

(0.08 ppm), the design value of a specific county is defined as the highest three-year 

average of the 4th highest daily 8-hour maximum. The average is calculated as a ppm 

value truncated at three decimal places. Where 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-attainment areas in April 2004 were based 

on individual counties’ 2001-2003 design values. 

 In the early 2000’s Delaware’s ozone monitoring data indicated 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 Delaware 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-hour ozone NAAQS, within the PhiladelphiaWilmington-Atlantic City, 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 Monitors 
8 

 Delaware began recording the 8-hour ozone exceedances at its ambient 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), which clearly shows a decreasing 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 the 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 year. In addition, the EPA NOx SIP call went 

into effect in 2003, and resulted in significant reduction in NOx emissions 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 seen that the numbers of ozone 

exceedances in Delaware have shown a decreasing 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 concentrations monitored at 

individual Delaware monitors from 1996 to 2006. The data in Table 2-8 are presented in 

terms of design values (i.e., three-year averages of annual 4th 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 detecting general trends in ambient ozone concentrations. Second, since 

attainment or non-attainment status will be determined by the design values, the trend of 

the design values can represent a direction towards future attainment status. Figure 2-3 is 

a graphical representation of the data in Table 2-8. The data in Table 2-8 and Figure 2-3 

shows a trend in the ozone design values approaching 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 Lewes
10 

New Castle County Kent County Sussex County 

Years Brandywine Bellefonte Lums Pond 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 temperature during the ozone season. One way of 

incorporating meteorology in evaluating trends in ozone concentrations is to analyze the 

number of ozone exceedances, the number of days 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 Lewes
11 

from New Castle County only (Data from New 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 temperature 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 Table 2-9 can be seen as one type of index 

of a direct relationship between temperature and ozone exceedances in the long term. This 

relationship indicates that more ozone exceedances usually occur in years with more hot 

summer days, such as 1997, 1998, 1999, and 2002 where both exceedance numbers and 

hot-day numbers are in the double digits (≥10). Similarly, fewer ozone exceedances occur 

in years with fewer hot summer days, such as 1996, 2000, and 2004, where both 

exceedance numbers and hot-day numbers are single 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-favoring 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 concentrations of ozone 

forming precursors (i.e., VOC and/or NOx) in the ambient air. 

2.7 General Trend of Ambient Air Quality Regarding 8-Hour Ozone 

From the data presented in this section, it is clear that the general 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 the Control of Air Pollution, Air Quality Management 

Section, Division of Air and 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 Shortfalls in the Delaware Phase II Attainment 

Demonstration for the Philadelphia-Wilmington-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/airs/airsaqs/index.htm. 
13 

3. Delaware 2002 Base Year Emissions Inventory 

 Under the 8-hour ozone NAAQS, EPA requires the non-attainment areas to 

compile a 2002 base year VOC/NOx emission inventory as the baseline 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 year emission inventory was conducted by 

AQMS’ Emission Inventory Development (EID) 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 shortage of the EID group, AQMS contracted 

with E.H. Pechan and Associates (hereafter referred 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 developing the 2002 base year inventory are briefly 

described herein, while details are presented in the QAPP and Delaware 2002 Base Year 

Emission Inventory (Reference 3-2). 

It should be pointed out: (1) The 2002 base 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 (SO2), ammonia (NH3) and all Hazardous Air Pollutants (HAPs). 

Since this document is solely an ozone SIP revision, it will discuss only the two major 

ozone precursors, i.e., VOC and NOx. (2) Although 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 SIP 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 supporting 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 facilities, (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 electric generating facilities. For consistency, 

however, Delaware has modified criteria (2) and (3) by setting 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 

ROAD 
15 

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 CHEMICAL 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 MATERIALS 
16 

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-related information for all emission-making 

processes within the facility’s boundary. The required information includes emissions 

directly measured by continuous emission monitors (CEMs), or activity data that can be 

used to calculate emissions. The report includes also all information regarding control 
17 

measures currently (as of 2002) installed on the relevant processes. After quality control 

and quality assurance (QC-QA) review and necessary 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 SIP 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 individual emission source categories. A non-point 

source category is either 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 cleaning solvents. The distinction between point and 

non-point sources is defined by an annual emission threshold as described in Subsection 

3.1 above. Table 3-2 presents a list of all stationary non-point source 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 NOx

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) Marketing** 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 and evaporative emissions from transport of petroleum 

products by commercial marine vessels. 

Inventory work in this sector started with collecting relevant activity data by the 

EID staff members and providing them to Pechan. Pechan’s staff in the non-point sector 

selected appropriate methods, with consultation of the EID manager and supporting staff, 

for emission calculations. After two rounds of QC-QA reviews and revision by Pechan’s 
18 

staff and EID staff, the emission data were finalized, and included 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 staff. 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) – Various types of vessels that navigate the 

Delaware Bay and River and the Chesapeake 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 sector started with collecting relevant activity data by the 

EID staff members and providing them to Pechan. Pechan’s staff in the non-road sector 

selected appropriate methods, with consultation of the EID manager and supporting staff, 

for emission calculations. 

Emissions from aircraft, locomotives, and CMVs were calculated 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 model, which further 

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

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

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

data were finalized, and included in the final SIP submission to EPA (Reference 3-2). 

3.4 On-Road Mobile Source Sector 

The emission inventory of on-road mobile source sector has been conducted by 

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

highway vehicles including passenger cars, light-duty trucks, sport utility vehicles, 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), and summarized all information about control 

measures effective in 2002. With the vehicle mix data and control information, Pechan 

used EPA’s MOBILE6.2 model to generate emission factors for each vehicle type 

traveling on each of the 11 functional road classes. The emission factors and the VMT 

data were then used to calculate VOC and NOx emissions for each vehicle type on each 

road class. The end products of the calculations are sums of VOC and NOx emissions for 

all vehicles on all road classes in each of the three counties in Delaware. After two rounds 

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

finalized, and included in the final SIP submission to EPA (Reference 3-2). 

3.5 Delaware 2002 Base Year Emission Inventory Summary 

Table 3-3 and Table 3-4 present a summary of Delaware 2002 base year VOC and 

NOx emissions. Since biogenic source emissions are not required in the ozone RFP 

planning, they are not included 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 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 

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 Management 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 document, 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 standard. 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 reductions 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 defined as an inventory accounting for only 

anthropogenic emissions within Delaware state boundaries. This baseline inventory shall 

not include, (1) natural emissions, (2) any emissions from sources outside Delaware, and 

(3) the non-reactive perchloroethylene (PERC) emissions (for VOC inventory only). 

From the discussion in Section 3 of this document, 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 Program (FMVCP) and Reid Vapor Pressure 

(RVP) rules promulgated prior to 1990 are not creditable for achieving RFP emission 

reductions. Therefore, the 2002 Baseline Inventory needs to be adjusted by subtracting the 

VOC and NOx emission reductions that are expected to occur between 2002 and future 

milestone years due to the FMVCP and RVP rules. 

 The FMVCP/RVP VOC and NOx emission reductions 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 Region 3 Office (Christopher Cripps, personal 

correspondence), AQM’s mobile source staff members conducted two MOBILE6.2 runs 

as follows: 

(1) Running MOBILE6.2 with 2002 as evaluation 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 the 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)), using 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 MOBILE6.2 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 attainment year, steps (2) and (3) above 

were conducted. According to EPA’s Final Rule 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 attainment year must be implemented by the 

beginning of the ozone season immediately preceding 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 above 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 also 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 B2008

 Adjusted for 2009 15.48 18.71 B2009

Mobile Source Adjustments for 2002 Baseline 

 For 2002-2008 1.15 1.42 C2008 = A-B2008

 For 2002-2009 1.18 1.53 C2009 = A-B2009

Fleet Turnover Corrections for 2008-2009 0.03 0.10 D = C2009-C2008

Table 4-2. Mobile Source FMVCP/RVP Adjustments 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 b2008

 Adjusted for 2009 39.13 51.40 b2009

Mobile Source Adjustments for 2002 Baseline 

 For 2002-2008 2.98 4.38 c2008 = a-b2008

 For 2002-2009 3.03 4.62 c2009 = a-b2009

Fleet Turnover Corrections for 2008-2009 0.05 0.24 d = c2009-c2008

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 inventory 
22 

relative to the subject milestone year,” as presented in Table 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 C2008

 Mobile Source Adjustments for 2002-2009 1.18 1.53 C2009

 

2002 Adjusted Baseline Relative to 2008 38.82 55.95 F2008 = E-C2008

2002 Adjusted Baseline Relative to 2009 38.79 55.84 F2009 = E-C2009

 

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 c2008

 Mobile Source Adjustments for 2002-2009 3.03 4.62 c2009

 

2002 Adjusted Baseline Relative to 2008 72.54 137.34 f2008 = e-c2008

2002 Adjusted Baseline Relative to 2009 72.49 137.10 f2009 = e-c2009

4.2 Emissions Reductions for 2003-2008 RFP 

 By the end of 2008, Delaware is required 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 emission, since it did not have a 15% VOC Rateof-Progress (ROP) plan approved by EPA under the 1-hour ozone standard. For Kent and 

New Castle Counties, their 15% emission 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 emission 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 TPD 
23 

 The next section (Section 5) demonstrates 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 emission 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 season of 2009, instead of 

2010. In addition, both VOC and NOx emission reductions can be used in the entire state 

to meet the reduction requirements. Section 7 of this document discusses reductions 

needed for attainment. According to Section 7 of this document, the modeling performed 

by NY DEC of a 2009 MANE-VU 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 Emissions 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 Sussex County from its 2002 baseline level, and 

15% VOC and/or NOx emission reduction in Kent 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 projections in this section 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 control 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 Controls and Emission Reductions 

The only post-2002 point source VOC control in Sussex County is Regulation No. 

24, Section 46, Control of Crude Oil Lightering Operations. The 2008 lightering 

emissions are projected based on the requirements 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 Lightering Operations 

Delaware air pollution control Regulation 1124 Section 46 was finalized in May 

2007. Table 46-1 of Reg. 1124 Sec. 46 specifies the following allowable uncontrolled 

VOC emissions from lightering operations: 

Beginning on Maximum allowable 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, respectively, 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 Sources except Lightering Operation 
25 

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 2009 projections, as shown below. 

 2009 All-point source emission 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 Source Controls and Emission Reductions 

A. Facility and unit shutdown/modification reductions 

 Emission reduction credits from shutdown facilities 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 from 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 0.00
26 

Total = 1.46 0.00 0.44 0.00

 Among the above shutdown facilities, some have applied for and obtained 

emission reduction credits (ERCs) pursuant to Regulation No. 34, Emission Banking and 

Trading Program. In addition, where ERCs are certified from a shutdown source Reg. 34 

provides for the Delaware Economic Development 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 the facilities/agency that hold 

ERCs. 

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

VOC 

(Tons) 

NOX 

(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 ozone season from April to October as 

defined in Regulation No. 34 (Reference 5-1), the 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 Enterprises) 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 revision. As such, the future use of these credits is consistent 

with, and will not interfere with any calculation or provision of this SIP document. 
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 2009 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 emission = 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 point sources = (9.47 – 10.46) x 6/7 = -0.85 TPD 

 2008 All other-point source projection = 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 projection = 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 emission reductions and projections for the 

non-point sources are estimated by interpolating the 2002 base year emissions and the 

2009 projections, as shown below. 

5.2.1 Sussex County Area Source Controls 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 Source 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 the non-road mobile source sector for VOC 

emissions between 2008 and 2009, the 2008 emission reductions and projections for the 

non-road mobile sources are estimated by interpolating the 2002 base year emissions and 

the 2009 projections, as shown below. 
28 

5.3.1 Sussex County Non-Road Mobile Source 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 emissions were projected using EPA’s 

MOBILE6.2 for obtaining emission factors and 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 recent available vehicle registration data and 

speed estimates (2005). The PTDM runs were conducted by staff of Delaware Department 

of Transportation (DelDOT). Details of the relevant 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 Emission 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 TPD 
29 

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 Subsection 10.1 of this SIP revision. 

 

5.5 Total VOC Emission Reductions 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 target under the 15% 

RFP requirements (33.00 TPD). Therefore, 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 target 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 Section, 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 the Southern District of Texas, 

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

Consent Decree, December 2003 and June 2004 
30 

6. Control Measures and Emission Projections for Attainment 

In Section 5 of this document, Delaware demonstrates that post-2002 emission 

controls will satisfy 2003-2008 RFP requirements. 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 variety of NOx emission sources prior to the ozone season of 

2009 to ensure attainment. 

The 2009 emission projections for non-EGU point sources, non-point sources 

(formerly termed as “area sources”), and non-road mobile sources have been conducted by 

MACTEC Federal Programs, Inc. (hereafter referred to as MACTEC). The 2009 emission 

projections are explained in MACTEC’s technical 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 becomes valid, Delaware amended the 2009 

projection(s) for the involved sources or source category, calculated its specific 

projections, and provides immediate or documentary explanations 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 BLRID emission unit code) to MANE-VU NIF 

emission unit identifiers (FIPSST state code, 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 components. When there was a match between the 

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

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

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

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

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

inventories: 

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

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

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

non-EGU inventory. 

• The non-EGU inventory was reviewed to identify remaining emission units with 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 meeting these selection criteria was then 
31 

compared 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 point 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 original 2002 point source file.

As a result of this procedure, MACTEC created 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 subsequent projections for 2009/2012/2018. 

After reviewing the IPM results, AQMS found that the projections were 

unrealistic. For instance, IPM predicted all oil-burning EGUs would have no emissions in 

2009. We know from regular interaction 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 regulations were applied. The source of data 

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

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

2005). Using 2002 as the baseline, 2009 growth factors were derived by taking 2009 

projected energy consumption by sector and source (quadrillion 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 Section 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 therefore will lead to VOC and/or NOx emission 

reduction prior to the 2009 ozone season: 

(1). Reg. 24. Sec. 46, Crude Oil Lightering 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, State-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 Refineries, 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, Control of NOx Emission from Boilers and 

Heaters, Effective 2008. 

(8) Control of NOx Emissions from Large Industrial Boilers and Process Heaters at 

Non-Refinery Facilities, NOx emission control, State-wide, under development 

and to be adopted in May 2008 with 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 have 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 controls (Reference 6-1). 

• Table 6-2 is a summary of Delaware 2009 VOC 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 6-2. 

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 provided 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 projections 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. 
33 

Table 6-1. Delaware 2009 VOC and NOx Emission Projections (TPD) for Electric Generating Units (EG

Facility Name Unit Description Post 2002 Regulation CITY OF DOVER - MCKEE RUN GENERATING STA BOILER #1 None* CITY OF DOVER - MCKEE RUN GENERATING STA BOILER #2 None CITY OF DOVER - MCKEE RUN GENERATING STA BOILER #3 

Regulation No. 1146 (Ef12/11/07) 

CITY OF DOVER VAN SANT GENERATING STA UNIT #11 GAS TURBINE None NRG ENERGY CENTER DOVER LLC COGENERATION BOILER None NRG ENERGY CENTER DOVER LLC TURBINE #1 None NRG ENERGY CENTER DOVER LLC TURBINE #2 None WARREN F BEASLEY POWER STATION COMBUSTION TURBINE None CONECTIV DELMARVA GENERATION-DEL CITY TURBINE #10 Regulation No. 1148 (PrCONECTIV DELMARVA GENERATION-WEST_SUBST TURBINE Regulation No. 1148 (PrCONECTIV DELMARVA GENERATION-EDGE MOOR GAS TURBINE Regulation No. 1148 (PrCONECTIV DELMARVA GENERATION-EDGE MOOR BOILER #3 

Regulation No. 1146 (Ef12/11/07) 

CONECTIV DELMARVA GENERATION-EDGE MOOR BOILER # 4 

Regulation No. 1146 (Ef12/11/07) 

CONECTIV DELMARVA GENERATION-EDGE MOOR BOILER # 5 

Regulation No. 1146 (Ef12/11/07) 

MOTIVA ENTERPRISES LLC - DELAWARE CITY BOILER 4 

Regulation No. 1142, Se(Proposed) 

MOTIVA ENTERPRISES LLC - DELAWARE CITY BOILER 1 

Regulation No. 1142, Se(Proposed) 

MOTIVA ENTERPRISES LLC - DELAWARE CITY BOILER 2 

Regulation No. 1142, Se(Proposed) 

MOTIVA ENTERPRISES LLC - DELAWARE CITY BOILER 3 

Regulation No. 1142, Se(Proposed) 

MOTIVA ENTERPRISES LLC - DELAWARE CITY REPOWERING CT1 None MOTIVA ENTERPRISES LLC - DELAWARE CITY REPOWERING CT2 None CONECTIV DELMARVA GENERATION-CHRISTIANA TURBINE #11 Regulation No. 1148 (prCONECTIV DELMARVA GENERATION-CHRISTIANA TURBINE #14 Regulation No. 1148 (prCONECTIV DELMARVA GENERATION-HAY ROAD COMBUSTION TURBINE #1 None CONECTIV DELMARVA GENERATION-HAY ROAD COMBUSTION TURBINE #2 None 
34 

CONECTIV DELMARVA GENERATION-HAY ROAD COMBUSTION TURBINE #3 None CONECTIV DELMARVA GENERATION-HAY ROAD COMBUSTION TURBINE #5 None CONECTIV DELMARVA GENERATION-HAY ROAD COMBUSTION TURBINE #6 None CONECTIV DELMARVA GENERATION-HAY ROAD COMBUSTION TURBINE #7 None INDIAN RIVER GENERATING STATION BOILER #1 

Regulation No. 1146 (Ef12/11/07) 

INDIAN RIVER GENERATING STATION BOILER # 2 

Regulation No. 1146 (Ef12/11/07) 

INDIAN RIVER GENERATING STATION BOILER # 3 

Regulation No. 1146 (Ef12/11/07) 

INDIAN RIVER GENERATING STATION BOILER # 4 

Regulation No. 1146 (Ef12/11/07) 

INDIAN RIVER GENERATING STATION TURBINE #10 None INVISTA BOILER #1 None INVISTA BOILER #2 None INVISTA BOILER #3 None CITY OF LEWES POWER PLANT CATERPILLER ELEC PK #1 

Regulation No. 1144 (Ef1/11/06) 

CITY OF LEWES POWER PLANT CATERPILLER ELEC PK #2 

Regulation No. 1144 (Ef1/11/06) 

CITY OF SEAFORD-ELECTRIC POWER PLANT GENERATOR #1 

Regulation No. 1144 (Ef1/11/06) 

CITY OF SEAFORD-ELECTRIC POWER PLANT GENERATOR #2 

Regulation No. 1144 (Ef1/11/06) 

CITY OF SEAFORD-ELECTRIC POWER PLANT GENERATOR #3 

Regulation No. 1144 (Ef1/11/06) 

CITY OF SEAFORD-ELECTRIC POWER PLANT GENERATOR #4 

Regulation No. 1144 (Ef1/11/06) 

CITY OF SEAFORD-ELECTRIC POWER PLANT GENERATOR #6 

Regulation No. 1144 (Ef1/11/06) 

* Indicating that the unit was not affected by post-2002 control or rule when calculating 2009 projection.
35 

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

County Facility Name Unit Description Kent DOVER AIR FORCE BASE BOILER #1/CENT HTNG PLANT 

PROCTOR AND GAMBLE DOVER WIPES COMPANY BOILER #1 TILCON DELAWARE - HORSEPOND ROAD ASPHALT HOT MIX PLANT BAYHEALTH MED CENTER KENT GENERAL HOSP 1275 KW EMERENCY GENER DE SOLID WASTE AUTHORITY SANDTOWN LANDFILL 

New Castle DUPONT EXPERIMENTAL STATION ELECTRICAL GENERATOR 

DUPONT EXPERIMENTAL STATION 3 CATALYTIC CONVERTERS GENERAL MOTORS CORPORATION BOILER #1 GENERAL MOTORS CORPORATION BOILER #5 GENERAL MOTORS CORPORATION ELPO BATH GENERAL MOTORS CORPORATION ELPO PRIM. OVENS & HTRS GENERAL MOTORS CORPORATION PRIMER SURFACER BOOTH GENERAL MOTORS CORPORATION PRIMER SURFACER BOOTH GENERAL MOTORS CORPORATION PRIMER SURFACER OVEN GENERAL MOTORS CORPORATION MOD SHOP BOOTHS GENERAL MOTORS CORPORATION MOD SHOP BOOTHS GENERAL MOTORS CORPORATION MOD SHOP OVENS GENERAL MOTORS CORPORATION DEADNER BOOTH GENERAL MOTORS CORPORATION FINAL REPAIR AREA GENERAL MOTORS CORPORATION FINAL REPAIR AREA GENERAL MOTORS CORPORATION MISC. SOURCES GENERAL MOTORS CORPORATION MISC. SOURCES GENERAL MOTORS CORPORATION 40,000 GAL GASOLINE TANK GENERAL MOTORS CORPORATION ELPO/TOPCOAT RTO GENERAL MOTORS CORPORATION PRIMER/SRUFACER RTO GENERAL MOTORS CORPORATION SEALER CURE OVEN GENERAL MOTORS CORPORATION BODY WASHER OVEN #1 GENERAL MOTORS CORPORATION BODY WASHER OVEN #2 SUNCO INC R M BOILER #2 CHRISTIANA CARE - WILMINGTON HOSPITAL PEAKING UNIT #1 
36 

FORMOSA PLASTICS CORPORATION INCINERATORS WB710/711 LAIDLAW CORPORATION CAPING MACHINE # 1 LAIDLAW CORPORATION LATEX APPPLN ON TUBES LAIDLAW CORPORATION TUBE LAMINATING LAIDLAW CORPORATION 3 LANE HANGER LINE LAIDLAW CORPORATION STRAIGHT & CUT (S&C) # 1 AMETEK INC CHEMICAL PRODUCTS DIVISION BOILER 2 AMETEK INC CHEMICAL PRODUCTS DIVISION RESIN MANUFACTURING AMETEK INC CHEMICAL PRODUCTS DIVISION HAVEG 41/61 TANK MANUFACT AMETEK INC CHEMICAL PRODUCTS DIVISION PHENOL TANK AMETEK INC CHEMICAL PRODUCTS DIVISION SILTEMP - WEB COATER AMETEK INC CHEMICAL PRODUCTS DIVISION DEGREASER AMETEK INC CHEMICAL PRODUCTS DIVISION SILTEMP - HCL FILL TANKS AMETEK INC CHEMICAL PRODUCTS DIVISION SILTEMP - ACID DIGESTERS AMETEK INC CHEMICAL PRODUCTS DIVISION HCL MIX TANK/NEUT. TANK AMETEK INC CHEMICAL PRODUCTS DIVISION OBNOXIOUS FUME SCRUBBER OCCIDENTAL CHEMICAL CORPORATION BOILER #2 OCCIDENTAL CHEMICAL CORPORATION BOILER #5 OCCIDENTAL CHEMICAL CORPORATION CHLORINE LIQUIFICATION ROHM & HAAS ELECTRONIC MATERIALS CMP TE B2 EMERGENCY GENERATOR ROHM & HAAS ELECTRONIC MATERIALS CMP TE B5 EMERGENCY GENERATOR FP INTERNATIONAL INC EXTRUDER LINE #1 FP INTERNATIONAL INC EXTRUDER RECYCLE LINE #3 VETERANS ADMINISTRATION HOSPSITAL BOILER #1 VETERANS ADMINISTRATION HOSPSITAL 5 DIESEL GENERATORS CHRISTIANA CARE - CHRISTIANA HOSPITAL PEAKING UNIT #1 DE SOLID WASTE AUTHORITY PIGEON POINT LANDFILL DE SOLID WASTE AUTHORITY CHERRY ISLAND FUGITIVE VOCS - LANDFILL WESTVACO CORPORATION WEB OFF-SET PRINTING WESTVACO CORPORATION PARTS WASHERS DAIMLERCHRYSLER CORPORATION ECOAT PRIMER BOOTH DAIMLERCHRYSLER CORPORATION MISC. PRODUCTIVE ITEMS 
37 

DAIMLERCHRYSLER CORPORATION POWER ANTI CHIP BOOTH DAIMLERCHRYSLER CORPORATION COLOR 1&2 TOP COAT BOOTHS DAIMLERCHRYSLER CORPORATION LO BAKE REPAIR BOOTH DAIMLERCHRYSLER CORPORATION TOUCH UP AREA DAIMLERCHRYSLER CORPORATION NON-PRODUCTIVE DAIMLERCHRYSLER CORPORATION PH EMERG DIESEL GEN 1 DAIMLERCHRYSLER CORPORATION PH EMERG. DIESEL GEN 2 DUPONT STINE - HASKELL LABORATORY EMERGENCY DIESEL GEN. #1 DUPONT STINE - HASKELL LABORATORY EMERGENCY DIESEL GEN. #2 SPATZ FIBERGLASS PRODUCTS MANUFACTURING OF PLASTIC DELAWARE RECYCLABLE PRODUCTS INC LANDFILL WASTE GAS PURE GREEN INDUSTRIES INC DIESEL GENERATOR GE ENERGY (USA) LLC SINGLE CRYSTAL LINE HARDCORE COMPOSITES, DIV. OF HARRIS SPEC DATAS 

Sussex ORIENT CORPORATION OF AMERICA FACILITY FUGITIVES 

BAYHEALTH MEDICAL CTR - MILFORD MEMORIAL 600 KW EMERCENCY GEN PERDUE FARMS INC - GEORGETOWN EMERGENCY GENERATOR MARITRANS LIGHTERING OPERATION EDWARD J. KAYE CONSTRUCTION CRUSHER DIESEL ENGINE 

Total State Projection 

Notes: I. Delaware’s 2002 emissions for this individual record were different than the MACTEC 2002 emissions. To obtain a Delaw

Delaware’s actual 2002 emissions for this individual record were grown and controlled using the same methodology as MArecord. 

II. These units will be retrofitted by 2009 to be bi-fuel operated on natural gas and diesel fuel. Thus, Delaware has projected th

growth 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 were zeroed out, since the MACTEC 2009 projection inventory did 

shutdown. 

IV. Delaware reevaluated the VOC emission reductions due to adopting a regulation to control lightering, and estimated that a c

accurate. Thus, Delaware has projected the 2009 VOC emissions from lightering using the same growth factor as used by M

V. The MACTEC 2009 projected emissions for this unit include a reduction due to MACT controls. Delaware does not believ

unit. Additionally, the facility operated well below its capacity in 2002. Thus, Delaware has projected this unit’s 2009 emi

Delaware, and without assuming any MACT controls. 
38 

VI. Due to the requirements of Regulation No. 1144, Delaware assumes no growth or control of the emissions of this unit, and a

equal to its 2002 emissions. 

VIII. This unit was shutdown after 2002, and its emissions were zeroed out, since the MACTEC 2009 projection inventory did no

IX. This unit was classified as a “distributed generator,” and was subject to emission controls, under Regulation No. 1144. How

unit as an “emergency generator” instead of installing controls. Thus, Delaware has zeroed out its projected 2009 emissionemergency 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 grow

XI. The MACTEC 2009 projected emissions for this unit include a reduction due to MACT controls. Delaware does not believ

unit. Thus, Delaware has projected this unit’s 2009 emissions using the same growth factor as used by MACTEC, but with
39 

Table 6-3. Delaware 2009 NOx Emission Projections (TPD) for Non-EGU Point Sources Revised from M

County Facility Name Unit Desc. Kent DOVER AIR FORCE BASE BOILER #1/CENT HTNG PLA

PROCTOR AND GAMBLE DOVER WIPES COMPANY BOILER #1 TILCON DELAWARE - HORSEPOND ROAD ASPHALT HOT MIX PLANT BAYHEALTH MED CENTER KENT GENERAL HOSP 1275 KW EMERENCY GENE

New Castle DUPONT EXPERIMENTAL STATION ELECTRICAL GENERATOR 

DUPONT EXPERIMENTAL STATION 3 CATALYTIC CONVERTERGENERAL MOTORS CORPORATION BOILER #1 GENERAL MOTORS CORPORATION BOILER #5 GENERAL MOTORS CORPORATION ELPO PRIM. OVENS & HTRGENERAL MOTORS CORPORATION PRIMER SURFACER BOOTH GENERAL MOTORS CORPORATION PRIMER SURFACER OVEN GENERAL MOTORS CORPORATION MOD SHOP BOOTHS GENERAL MOTORS CORPORATION MOD SHOP OVENS GENERAL MOTORS CORPORATION DEADNER BOOTH GENERAL MOTORS CORPORATION FINAL REPAIR AREA GENERAL MOTORS CORPORATION MISC. SOURCES GENERAL MOTORS CORPORATION ELPO/TOPCOAT RTO GENERAL MOTORS CORPORATION PRIMER/SRUFACER RTO GENERAL MOTORS CORPORATION SEALER CURE OVEN GENERAL MOTORS CORPORATION BODY WASHER OVEN #1 GENERAL MOTORS CORPORATION BODY WASHER OVEN #2 MOTIVA ENTERPRISES LLC - DELAWARE CITY HEATER #2 FOR UNIT 21-HMOTIVA ENTERPRISES LLC - DELAWARE CITY REPOWER - CLEAN GAS FLCHRISTIANA CARE - WILMINGTON HOSPITAL PEAKING UNIT #1 AMETEK INC CHEMICAL PRODUCTS DIVISION BOILER 2 OCCIDENTAL CHEMICAL CORPORATION BOILER #2 OCCIDENTAL CHEMICAL CORPORATION BOILER #5 GENERAL CHEMICAL CORPORATION NITRITES PRODUCTION ROHM & HAAS ELECTRONIC MATERIALS CMP TE B2 EMERGENCY GENERATROHM & HAAS ELECTRONIC MATERIALS CMP TE B5 EMERGENCY GENERAT
40 

CONECTIV DELMARVA GENERATION-MADISON ST GAS TURBINE VETERANS ADMINISTRATION HOSPSITAL BOILER #1 VETERANS ADMINISTRATION HOSPSITAL 5 DIESEL GENERATORS CHRISTIANA CARE - CHRISTIANA HOSPITAL PEAKING UNIT #1 DE SOLID WASTE AUTHORITY PIGEON POINT LANDFILL MACDERMID INC COATING LINE DAIMLERCHRYSLER CORPORATION PH EMERG DIESEL GEN 1 DAIMLERCHRYSLER CORPORATION PH EMERG. DIESEL GEN 2 DUPONT STINE - HASKELL LABORATORY EMERGENCY DIESEL GENDUPONT STINE - HASKELL LABORATORY EMERGENCY DIESEL GENPURE GREEN INDUSTRIES INC DIESEL GENERATOR 

Sussex BAYHEALTH MEDICAL CTR - MILFORD MEMORIAL 600 KW EMERCENCY GEN 

PERDUE FARMS INC - GEORGETOWN EMERGENCY GENERATOR EDWARD J. KAYE CONSTRUCTION CRUSHER DIESEL ENGINE 

Total State Projection 

Notes: I. Delaware’s 2002 emissions for this individual record were different than the MACTEC 2002 emissions. To obtain a Delaware

Delaware’s actual 2002 emissions for this individual record were grown and controlled using the same methodology as MACT

II. These units will be retrofitted by 2009 to be bi-fuel operated on natural gas and diesel fuel. Thus, Delaware has projected thes

growth 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 were zeroed out, since the MACTEC 2009 projection inventory did no

VI. Due to the requirements of Regulation No. 1144, Delaware assumes no growth or control of the emissions of this unit, and assu

equal 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. 

2009 emissions using the same growth factor as used by MACTEC, and an assumed 80% reduction in NOx from the unit’s cur

VIII. This unit was shutdown after 2002, and its emissions were zeroed out, since the MACTEC 2009 projection inventory did nIX. This unit was classified as a “distributed generator,” and was subject to emission controls, under Regulation No. 1144. Howev

as an “emergency generator” instead of installing controls. Thus, Delaware has zeroed out its projected 2009 emissions since i

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 growth 
41 

Table 6-4. Delaware 2009 VOC and NOx Emission 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 season, 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 Containers, VOC emission control, State-wide, 

Effective January 2003. 

(4). Reg. 41 Sec. 2, Consumer Products, VOC emission control, State-wide, 

Effective January 2005. 

(5). Reg. 41 Sec 1, Architectural and Industrial Maintenance Coatings, VOC 

emission control, State-wide, Effective January 2005. 

(6) Reg. 24 Sec. 36, Stage II Vapor Recovery, VOC Emission control, State-wide, 

Effective January 2002. 

(7) Federal Residential Woodstove NSPS, 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 are 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 projections 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. 
43 

Table 6-6. Delaware 2009 VOC Emission Projections (TPD) for Non-Point Sources Revised from MAC

SCC SCC_L1 SCC_L2 SCC_L3 SCC_L4 2102002000 

Stationary Source Fuel Combustion Industrial 

Bituminous/Subbituminous Coal Total: All Boiler Types 

2102004000 

Stationary Source Fuel Combustion Industrial Distillate Oil 

Total: Boilers and IC Engines 

2102006000 

Stationary Source Fuel Combustion Industrial Natural Gas 

Total: Boilers and IC Engines 

2102007000 

Stationary Source Fuel Combustion Industrial 

Liquified Petroleum Gas (LPG) Total: All Boiler Types 

2103001000 

Stationary Source Fuel Combustion Commercial/Institutional Anthracite Coal Total: All Boiler Types 

2103004000 

Stationary Source Fuel Combustion Commercial/Institutional Distillate Oil 

Total: Boilers and IC Engines 

2103006000 

Stationary Source Fuel Combustion Commercial/Institutional Natural Gas 

Total: Boilers and IC Engines 

2103007000 

Stationary Source Fuel Combustion Commercial/Institutional 

Liquified Petroleum Gas (LPG) 

Total: All Combustor Types 

2104002000 

Stationary Source Fuel Combustion Residential 

Bituminous/Subbituminous Coal 

Total: All Combustor Types 

2104004000 

Stationary Source Fuel Combustion Residential Distillate Oil 

Total: All Combustor Types 

2104006000 

Stationary Source Fuel Combustion Residential Natural Gas 

Total: All Combustor Types 

2104007000 

Stationary Source Fuel Combustion Residential 

Liquified Petroleum Gas (LPG) 

Total: All Combustor Types 

2104008000 

Stationary Source Fuel Combustion Residential Wood 

Total: Woodstoves and Fireplaces 

2104008070 

Stationary Source Fuel Combustion Residential Wood 

Outdoor Wood Burning Equipment 

2104011000 

Stationary Source Fuel Combustion Residential Kerosene Total: All Heater Types 

2401005500 Solvent Utilization Surface Coating Auto Refinishing: SIC Surface Preparation 
44 

7532 Solvents 

2401005600 Solvent Utilization Surface Coating 

Auto Refinishing: SIC 7532 Primers 

2401005700 Solvent Utilization Surface Coating 

Auto Refinishing: SIC 7532 Top Coats 

2401005800 Solvent Utilization Surface Coating 

Auto Refinishing: SIC 7532 Clean-up Solvents 

2401008000 Solvent Utilization Surface Coating Traffic Markings 

Total: All Solvent Types 

2401045000 Solvent Utilization Surface Coating Metal Coils: SIC 3498 

Total: All Solvent Types 

2401075000 Solvent Utilization Surface Coating Aircraft: SIC 372 

Total: All Solvent Types 

2415100000 Solvent Utilization Degreasing 

All Industries: Open Top Degreasing 

Total: All Solvent Types 

2415130000 Solvent Utilization Degreasing 

Electronic and Other Elec. (SIC 36): Open Top Degreasing 

Total: All Solvent Types 

2415300000 Solvent Utilization Degreasing 

All Industries: Cold Cleaning 

Total: All Solvent Types 

2415360000 Solvent Utilization Degreasing 

Auto Repair Services (SIC 75): Cold Cleaning 

Total: All Solvent Types 

2425010000 Solvent Utilization Graphic Arts Lithography 

Total: All Solvent Types 

2425020000 Solvent Utilization Graphic Arts Letterpress 

Total: All Solvent Types 

2440020000 Solvent Utilization Miscellaneous Industrial 

Adhesive (Industrial) Application 

Total: All Solvent Types 

2461021000 Solvent Utilization 

Miscellaneous Nonindustrial: Commercial Cutback Asphalt Total: All Solvent Types 

2461850001 Solvent Utilization 

Miscellaneous Nonindustrial: Commercial Pesticide Application: Agricultural Herbicides, Corn 

2461850006 Solvent Utilization 

Miscellaneous Nonindustrial: Commercial Pesticide Application: Agricultural Herbicides, Hay & Grains 

2461850009 Solvent Utilization 

Miscellaneous Nonindustrial: Commercial Pesticide Application: Agricultural Herbicides, Not Elsewhere Classified 
45 

2461850056 Solvent Utilization 

Miscellaneous Nonindustrial: Commercial Pesticide Application: Agricultural Other Pesticides, Hay & Grains 

2461850099 Solvent Utilization 

Miscellaneous Nonindustrial: Commercial Pesticide Application: Agricultural Other Pesticides, Not Elsewhere Classified 

2501010050 Storage and Transport 

Petroleum and Petroleum Product Storage Marinas: Gasoline Stage 1: Total 

2501010102 Storage and Transport 

Petroleum and Petroleum Product Storage Marinas: Gasoline 

Stage 2: Displacement Loss 

2501010103 Storage and Transport 

Petroleum and Petroleum Product Storage Marinas: Gasoline Stage 2: Spillage 

2501010201 Storage and Transport 

Petroleum and Petroleum Product Storage Marinas: Gasoline 

Underground Tank: Emptying and Breathing 

2501011010 Storage and Transport 

Petroleum and Petroleum Product Storage 

Portable Containers: Residential Vapor Losses 

2501011011 Storage and Transport 

Petroleum and Petroleum Product Storage 

Portable Containers: Residential Permeation 

2501011012 Storage and Transport 

Petroleum and Petroleum Product Storage 

Portable Containers: Residential Diurnal 

2501011015 Storage and Transport 

Petroleum and Petroleum Product Storage 

Portable Containers: Residential Spillage 

2501011016 Storage and Transport 

Petroleum and Petroleum Product Storage 

Portable Containers: Residential Transport 

2501012010 Storage and Transport 

Petroleum and Petroleum Product Storage 

Portable Containers: Commercial Vapor Losses 

2501012011 Storage and Transport 

Petroleum and Petroleum Product Storage 

Portable Containers: Commercial Permeation 

2501012012 Storage and Transport 

Petroleum and Petroleum Product Storage 

Portable Containers: Commercial Diurnal 

2501012015 Storage and Transport 

Petroleum and Petroleum Product Storage 

Portable Containers: Commercial Spillage 

2501012016 Storage and Transport 

Petroleum and Petroleum Product Storage 

Portable Containers: Commercial Transport 

2501060051 Storage and Transport 

Petroleum and Petroleum Product Storage Gasoline Service Stations 

Stage 1: Submerged Filling 

2501060053 Storage and Transport 

Petroleum and Petroleum Product Storage Gasoline Service Stations 

Stage 1: Balanced Submerged Filling 
46 

2501060100 Storage and Transport 

Petroleum and Petroleum Product Storage Gasoline Service Stations Stage 2: Total 

2501060201 Storage and Transport 

Petroleum and Petroleum Product Storage Gasoline Service Stations 

Underground Tank: Breathing and Emptying 

2501060204 Storage and Transport 

Petroleum and Petroleum Product Storage Gasoline Service Stations 

Stage 2: Off-Highway Equipment Displacement Loss/Controlled 

2501060205 Storage and Transport 

Petroleum and Petroleum Product Storage Gasoline Service Stations 

Stage 2: Off-Highway Equipment Spillage 

2501080050 Storage and Transport 

Petroleum and Petroleum Product Storage 

Airports : Aviation Gasoline Stage 1: Total 

2501080102 Storage and Transport 

Petroleum and Petroleum Product Storage 

Airports: Aviation Gasoline 

Stage 2: Displacement Loss 

2501080201 Storage and Transport 

Petroleum and Petroleum Product Storage 

Airports: Aviation Gasoline 

Underground Tank: Breathing and Emptying 

2501090050 Storage and Transport 

Petroleum and Petroleum Product Storage Airports: Jet A or JP-8 Stage 1: Total 

2501090101 Storage and Transport 

Petroleum and Petroleum Product Storage Airports: Jet A or JP-8 Stage 2: Total 

2505020030 Storage and Transport 

Petroleum and Petroleum Product Transport Marine Vessel Crude Oil 

2505020060 Storage and Transport 

Petroleum and Petroleum Product Transport Marine Vessel Residual Oil 

2505020090 Storage and Transport 

Petroleum and Petroleum Product Transport Marine Vessel Distillate Oil 

2505020120 Storage and Transport 

Petroleum and Petroleum Product Transport Marine Vessel Gasoline 

2505020150 Storage and Transport 

Petroleum and Petroleum Product Transport Marine Vessel Jet Naphtha 

2505030120 Storage and Transport 

Petroleum and Petroleum Product Transport Truck Gasoline 

2610000400 

Waste Disposal, Treatment, and Recovery Open Burning All Categories 

Yard Waste - Brush Species Unspecified 
47 

2610000500 

Waste Disposal, Treatment, and Recovery Open Burning All Categories 

Land Clearing Debris (use 28-10-005-000 for Logging Debris Burning) 

2630020000 

Waste Disposal, Treatment, and Recovery Wastewater Treatment Public Owned Total Processed 

2660000000 

Waste Disposal, Treatment, and Recovery 

Leaking Underground Storage Tanks 

Leaking Underground Storage Tanks 

Total: All Storage Types 

2810001000 

Miscellaneous Area Sources Other Combustion Forest Wildfires Total 

2810035000 

Miscellaneous Area Sources Other Combustion Firefighting Training Total 

County Totals Total State Projection 

Notes: I. Delaware’s 2002 emissions for this individual record were different than the MACTEC 2002 emissions. To obtain a Delaw

Delaware’s actual 2002 emissions for this individual record were grown and controlled using the same methodology as MArecord. 

II. The MACTEC projected 2009 inventory did not include any emissions for this SCC. Thus, Delaware’s 2002 tons per day e

2009 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. 

emissions for this SCC were projected to 2009 using the same methodology as MACTEC applied to the annual emissions fo

IV. Since Delaware adjusted its 2002 emissions for residential wood combustion based on a new report by OMNI, 2009 emissio

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 Operatio

2009 emission for these SCCs by first recalculating the 2002 emissions as if 100% rule effectiveness were applied, and then 

MACTEC. 

VI. Due to Delaware’s amendments to its open burning regulation, it is expected that emissions due to yard waste burning will 

the 2009 emission for the SCC of 2610000500 by first recalculating the 2002 emissions as if the same control efficiency, ru

for 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, it is expected that emissions due to land clearing debris burn

projected the 2009 emission for the SCC of 2610000500 by first recalculating the 2002 emissions as if 90% rule effectivene

same growth factors used by MACTEC. 

VIII. The MACTEC projected 2009 emissions from Stage II vapor recovery for SCC 2501060100 were based upon Delaware’s 2

100% rule effectiveness for the controls. Delaware amended its requirements for Stage II vapor recovery in 2002, which re
48 

controls after 2002. Thus, Delaware calculated its emissions from Stage II vapor recovery in 2003 using 100% rule effectivto 2009 using a six-year growth factor from 2003 to 2009, which was based upon MACTEC’s growth factor from 2002 to 2

IX. Delaware’s 2002 inventory already reflects controls for the OTC 2001 VOC Model Rules Mobile Equipment Repair and Re

the 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 prohib

applies the prohibition to all counties in the state. Due to the regulation’s amendment, there will be no approvals issued for 

Delaware has zeroed out those emissions. 
49 

Table 6-7. Delaware 2009 NOx Emission Projections (TPD) for Non-Point Sources Revised from MAC

SCC SCC_L1 SCC_L2 SCC_L3 SCC_L4 2102002000 

Stationary Source Fuel Combustion Industrial 

Bituminous/Subbituminous Coal Total: All Boiler Types 

2102004000 

Stationary Source Fuel Combustion Industrial Distillate Oil 

Total: Boilers and IC Engines 

2102006000 

Stationary Source Fuel Combustion Industrial Natural Gas 

Total: Boilers and IC Engines 

2102007000 

Stationary Source Fuel Combustion Industrial 

Liquified Petroleum Gas (LPG) Total: All Boiler Types 

2103001000 

Stationary Source Fuel Combustion Commercial/Institutional Anthracite Coal Total: All Boiler Types 

2103004000 

Stationary Source Fuel Combustion Commercial/Institutional Distillate Oil 

Total: Boilers and IC Engines 

2103006000 

Stationary Source Fuel Combustion Commercial/Institutional Natural Gas 

Total: Boilers and IC Engines 

2103007000 

Stationary Source Fuel Combustion Commercial/Institutional 

Liquified Petroleum Gas (LPG) 

Total: All Combustor Types 

2104002000 

Stationary Source Fuel Combustion Residential 

Bituminous/Subbituminous Coal 

Total: All Combustor Types 

2104004000 

Stationary Source Fuel Combustion Residential Distillate Oil 

Total: All Combustor Types 

2104006000 

Stationary Source Fuel Combustion Residential Natural Gas 

Total: All Combustor Types 

2104007000 

Stationary Source Fuel Combustion Residential 

Liquified Petroleum Gas (LPG) 

Total: All Combustor Types 

2104008000 

Stationary Source Fuel Combustion Residential Wood 

Total: Woodstoves and Fireplaces 

2104008070 

Stationary Source Fuel Combustion Residential Wood 

Outdoor Wood Burning Equipment 

2104011000 

Stationary Source Fuel Combustion Residential Kerosene Total: All Heater Types 

2610000400 Waste Disposal, Open Burning All Categories Yard Waste - Brush 
50 

Treatment, and Recovery 

Species Unspecified 

2610000500 

Waste Disposal, Treatment, and Recovery Open Burning All Categories 

Land Clearing Debris (use 28-10-005-000 for Logging Debris Burning) 

2810001000 

Miscellaneous Area Sources Other Combustion Forest Wildfires Total 

2810035000 

Miscellaneous Area Sources Other Combustion Firefighting Training Total 

County Totals Total State Projection 

Notes: I. Delaware’s 2002 emissions for this individual record were different than the MACTEC 2002 emissions. To obtain a Delaw

Delaware’s actual 2002 emissions for this individual record were grown and controlled using the same methodology as MArecord. 

IV. Since Delaware adjusted its 2002 emissions for residential wood combustion based on a new report by OMNI, 2009 emissio

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 

the 2009 emission for the SCC of 2610000500 by first recalculating the 2002 emissions as if the same control efficiency, ru

for 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, it is expected that emissions due to land clearing debris burn

projected the 2009 emission for the SCC of 2610000500 by first recalculating the 2002 emissions as if 90% rule effectivene

same growth factors used by MACTEC. 

X. Delaware recently amended its regulation pertaining to open burning, which extended the ozone season open burning prohib

applies the prohibition to all counties in the state. Due to the regulation’s amendment, there will be no approvals issued for 

Delaware has zeroed out those emissions. 
51 

Table 6-8. Delaware 2009 VOC and NOx Emission 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 Emission 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 engines (except aircrafts, locomotives, and 

marine vessels) for their 2009 emissions include all relevant federal rules, such as fuel 

sulfur content rule, gasoline Reid Vapor Pressure (RVP) requirements, and reformulated 

fuel programs. MACTEC used EPA’s NMIM2005 model and NONROAD2005 model to 

estimate annual emission projections of non-road engines in all MANE_VU states, 

including Delaware (see MACTEC’s TSD, Appendix 6-1). 

 In addition to the non-road engines, MACTEC also conducted 2009 annual 

emission projections for aircrafts, locomotives and marine vessels for all MANE_VU 

states. Controls for the 2009 VOC and NOx emissions 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 equipment, chain saws, and other such 

utility equipment as chippers and stump grinders, wood splitters, etc., rated at 

or below 19 kilowatts (an equivalent of 25 or fewer horsepower). Phase 2 of 

the rule applied further controls on handheld and non-handheld outdoor 

equipment. See References 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 to 

emissions standards promulgated by the EPA for non-road, compressionignition (i.e., diesel-powered) utility engines, as authorized under 42 U.S.C. § 
52 

7547. The measure affects diesel-powered (or other compression-ignition) 

construction equipment, industrial equipment, 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 Ignition (SI) Marine Engines, Federal Rule 

This EPA measure controls exhaust VOC emissions from new spark-ignition 

(SI) gasoline marine engines, including outboard engines, personal watercraft 

engines, and jet boat engines. Of nonroad sources studied by EPA, gasoline 

marine engines were found to be one of the largest contributors of hydrocarbon 

(HC) emissions (30 percent of the nationwide nonroad total). See Reference 6-

8. 

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

This EPA measure controls VOC and NOx emissions from several groups of 

previously unregulated nonroad engines, including large industrial 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 mobile 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 emission projections was Version 3 of the 

MANE_VU 2002 Nonroad emission inventory (Documentation of the MANE-VU 2002 

Nonroad Sector Emission Inventory, Version 3, Draft Technical Memorandum, March 

2006). MACTEC’s approach to developing emission projections for these sources was to 

use combined growth and control factors developed from emission projections for U.S. 

EPA’s Clean Air Interstate Rule (CAIR) development effort. MACTEC obtained 

emission projections developed for the CAIR rule. We then calculated the combined 

growth and control factors by determining the ratio of emissions between 2002 and each 

of the MANE-VU projection years (2009, 2012, and 2018). The CAIR emissions were 

available for 2001, 2010, 2015 and 2020. Thus, we developed intermediate year estimates 

using linear interpolation between the actual CAIR years and the MANE-VU years. 

Using this approach we developed State/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 the base year value to obtain the projected 

values. Since the development of the CAIR factors included both growth and controls, no 

separate control factors were developed for these sources except where exceptions to this 

method were used for States that requested alternative growth/control methods (see 

below). 

Once the CAIR factors were developed, MACTEC compared the SCCs contained 

in the CAIR inventory with those used in MANE-VU. In some cases there were 

differences. In cases where a similar SCC in the CAIR inventory could be assigned to the 
53 

SCC in the MANE-VU inventory the State/County/SCC/pollutant growth and control 

factor for the substitute was assigned to the MANE-VU SCC. If no corresponding county 

SCC substitution could be found, a State or MANE-VU regional average value for the 

substitute SCC was developed and assigned for use in projecting emissions. The 

substitution scheme was to use State values first, then MANE-VU regional values if the 

State value couldn’t be used. 

Since the ozone-season-daily emissions (tons per day, or TPD) are needed for the 

ozone SIP planning, Delaware uses its 2002 daily-emission to annual-emission ratios to 

calculate 2009 daily emissions from MANE_VU’s annual projections (tons per year, or 

TPY), assuming the daily-to-annual emission relations 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_VU’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 ratio, prior to calculating the 2009 daily 

emissions. All calculations are presented in Appendix 6-2, with 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 14.21 
54 

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 projections have been conducted by AQM 

staff members using EPA’s MOBILE6.2 model. Delaware Department of Transportation 

(DelDOT) provided vehicle miles traveled (VMT) on Delaware’s roadways and vehicle 

mix data for 2009. The on-road mobile source controls in the input files for the 2009 

MOBILE6.2 runs include the following: 

(1) Low enhanced I/M program of model years 1968 and newer, Kent and New 

Castle. 

(2) On-Board Diagnostic checks of model years 1996 and newer, statewide. 

(3) Anti-tampering program of model years of 1975 and newer, statewide. 

(4) NLEV program, statewide. 

(5) Low emission vehicle program/Tier 2 emission standards/low sulfur rule, 

statewide. 

(6) Heavy Duty Diesel Rule/low Sulfur rule, statewide. 

(7) Stage II vapor recovery, 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 MOBILE6.2 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 Projections 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 41.73 
55 

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 document). Additionally, Delaware commits to 

adopt a regulation to control the NOx emissions 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 Subsection 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 Delaware’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 baseline (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 controls in this section will achieve a NOx 

emission level that is lower than the target 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 reduction surplus to offset the 2009 VOC 

reduction shortfall. Delaware plans to use the 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”, Final 
56 

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 Significance for Nonroad 

Sources and Emission Standards for New Nonroad 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 Engines; Exemptions for New Nonroad 

Compression-Ignition Engines at or Above 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, Research Triangle Park, North Carolina 27711, 

December 1993. 

6-13. Guidance on the Post-1996 Rate-of-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 Modeling and Weight-of-Evidence Analysis 

7.1 Background and Objectives 

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

Delaware as moderate non-attainment areas for the 8-hour ozone standard. These three 

Delaware counties are part of a 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 this document), the moderate non-attainment counties within 

this area by the state are: 

Delaware: Kent County, New Castle 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, Chester County, Delaware County, 

 Montgomery County, Philadelphia County. 

Ozone has been a chronic problem, particularly along the I-95 corridor from 

Washington, DC to Boston, MA. The ozone non-attainment in the Northeast and MidAtlantic regions is attributed not only to the anthropogenic emissions in the area but also 

to regional transport, which is a significant portion of ozone observed. The Ozone 

Transport and Assessment Group (OTAG) addressed the concerns related to ozone 

transport through modeling, which determined that NOx emissions reductions are effective 

in reducing the ozone transport (Reference 7-1). Consequently, the EPA issued the NOx 

SIP call in 1998 requiring twenty-two states and the District of Columbia to reduce their 

NOx 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 concentrations that meet the NAAQS. It predicts 

whether or not all estimated future 2009 design values will be less than 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 evaluate the efficacy of proposed/adopted control 

strategies, and to demonstrate that such measures will result in attainment of the ozone 

standard by June 15, 2010. This SIP shows that progress is being made to improve air 

quality in the PA-NJ-DE-MD moderate non-attainment area, that all necessary steps are 

being taken to attain the 8-hour ozone NAAQS by 2009, and that the entire 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 (Reference 7-5) and Ozone Transport Commission’s 

(OTC) modeling for the State Implementation Plan (SIP) in the 12-state Ozone Transport 

Region (OTR) (Appendix 7-1). The PA-NJ-DE-MD’s modeling runs were performed in 

coordination with the OTC modeling centers, which included the New York State 

Department of Environmental Conservation (NYSDEC), the University of Maryland, the 

Northeast States for Coordinated Air Use Management (NESCAUM) and Virginia 

Department of Environmental Quality (VADEQ). Modeling inventories were developed, 

updated and shared among the regional modeling centers and provided by Mid-Atlantic 

Regional Air Management Association (MARAMA), Mid-Atlantic North East Visibility 

Union (MANE-VU) and the Visibility Improvement 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 modeling domains were 

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

U.S. and the inner domain at 12-km horizontal grid resolution covering the OTR, 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 demonstrations but also serving the purpose of 

ozone evaluation. However, the inner domain, with 12-km horizontal grid resolution in 

the northeastern U.S., is the focus of and the justification for all activities pursuant to 

demonstrating attainment of the 8-hour ozone standard. The selection of the horizontal 

grid sizes and vertical layer structure are described in detail in the OTC Modeling Protocol 

(Appendix 7-1). A technical support document from NYSDEC (Appendix 7-2) provides 

information on air quality modeling domain definitions, CMAQ model 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 episodes for the purposes of attainment 

demonstration. Taking the size of the modeling domain into consideration, the OTC 

modeling committee simulated a major portion of the 2002 ozone season with the OTC 

SIP modeling system. Such a selection is justified as a result of a special study by Environ 

(Appendix 7-3), which assesses the representativeness 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 episodes 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 development. Another study, a qualitative 

analysis by Ryan and Piety (Appendix 7-4), provides the rationale for the selection of 

2002 meteorology. 

Recent research has shown that model performance 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 State Implementation Plan (SIP) modeling 

runs (May 1 to September 30). As a result, the total number of days examined for the 
60 

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 OTC SIP modeling system are generated by 

the PSU/NCAR Mesoscale Meteorological Model (MM5). The model setup and the 

procedures for quality assurance of the meteorological fields are described in the OTC 

Modeling Protocol (Appendix 7-1). Assessment 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 observations 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 procedures 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 (Appendix 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 the 2002 base case and 2009 future case 

modeling required coordination amongst the Regional Planning Organizations (RPOs). 

Each RPO was responsible for processing of both its anthropogenic and biogenic 

emissions. The emissions data for 2002 were generated by individual states within the 

OTR and were assembled and processed through the MANE-VU. These emissions were 

then processed by the NYSDEC using Sparse Matrix Operator Kernel Emissions 

(SMOKE) modeling system, an emissions processor for CMAQ, to provide model-ready 

inputs. The 2002 emissions for the non-OTR areas within the modeling domain were 

obtained from the corresponding RPOs and were processed using SMOKE. 

Emissions inventories for 2009, 2012 and 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. Emissions 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 measures 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 description of the area’s ozone problem be 

developed prior to the initiation of any air quality modeling study. A “conceptual 

description” is a qualitative way of characterizing the nature of an area’s non-attainment 

problem. Within the conceptual description of a particular modeling exercise, it is 

recommended that the specific meteorological parameters that influence air quality be 

identified and qualitatively ranked in importance. The conceptual model 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-Atlantic regions. Some of them are provided as 

appendixes to this document (Appendixes 7-3, 7-4, 7-11, and 7-12). 

7.8 Attainment Demonstration of 8-hour Ozone NAAQS 

This subsection provides technical information 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 monitors 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 × DVC RRF DVF I

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

RRFI = the relative response factor, calculated near site I ; 

DVFI = 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 includes 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 modeling. 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. Specifically, 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 years of available data at a monitoring site 

the following procedure was used: 

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

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

value periods. 

• Less than 3 years of data: The site was 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 grid resolution modeling to calculate RRFs. 

 

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

used in the modeled attainment test with the 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 the highest predicted 8-hour daily maximum concentration with 

the future emissions for each day in the test. 

Table 7-1: Summary of Model 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 Cecil 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 Cumberland NJ 94 0.8486 79 

340150002 Clarksboro Gloucester 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 78 
63 

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 predictions in the future to the mean of the 8-

hour daily maximum predictions with baseline 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 were 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 days > 70 ppb were used. 

• No RRF calculations were performed for 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 analysis, 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 maximum 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 scenario 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 using the base year gridded model output 

gradients. 

Step 3: Applying the gridded model Relative 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 predicted 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 demonstration. This weight of evidence (WOE) analysis describes the 

analyses performed, databases used, key assumptions and outcomes of each analysis, and 

why the evidence, viewed as a whole, supports a conclusion that the non-attainment area 
65 

will attain the NAAQS despite the model predicting 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 circumstances a WOE demonstration is needed. 

Model-predicted design values are summarized in Table 7-1. Of the 22 ozone monitors in 

the PA-NJ-DE-MD non-attainment area only eight (8) exceed the threshold requiring a 

WOE demonstration. Four (4) of the monitors 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 design values and current projected 

design values for 2006 (Section 7.8.2.1, Overview 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 regional 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 transport 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 projected design values and the projected 

design values for 2006. Modeled 2009 and projected 2006 design values are surprisingly 

close to one another with most modeled concentrations slightly lower than the projected 

2006 design values. This suggests that the significant additional VOC and NOX 

reductions projected to occur over the next three years will likely bring monitors currently 

recording ozone concentrations just over the 8-hour ozone standard into compliance, and 

indicates attainment will be achieved. 

Table 7-3 Comparison of Modeled 2009 and 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 Trends 
67 

Long-term trends in Delaware’s ozone design values are discussed in Section 2 of 

this document. Similar to this DE data there have been significant declines in the PA-NJDE-MD non-attainment area’s 8-hour ozone design values over the last several decades. 

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

the more recent enactment of the NOx SIP Call. 

It is interesting to note that ozone design values in the PA-NJ-DE-MD nonattainment area have fallen roughly 14% since enactment of the NOx 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 show steady decline in ozone design values since 2002 (the year 

prior to phased-in enactment of the NOx SIP Call). Slight increases 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 NOx emissions from upwind electric generating 

units (EGUs) have a dramatic effect on reduction of ozone levels in the PA-NJ-DE-MD 

non-attainment area. By 2009 additional significant reductions in NOx emissions are 

projected to occur due to initiatives like CAIR and Delaware’s Regulation No. 1146. 

These reductions are greater than those attributable to the NOx SIP Call, so this, coupled 

with the significant mobile source sector reductions anticipated will provide additional 

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

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

 

Figures 7-4, 7-5 and 7-6 provide additional information on the long-term trend of 

summer 1-hour ozone values (1996-2006) monitored at different locations 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 trends, which indicates that the trend is of 

decreasing ozone at these three monitors. A comprehensive trends study of the 1-hour 

ozone concentrations over the entire OTR 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

Year

Concentration (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 50000

0.032 0.033 0.034 0.035 0.036 0.037 0.038

Kent County (Killens) - 1996-2006

Summer Only - Noise and high frequency filtered

Hours

ln Transformed O3
69 

Figure 7-5. Long-term trends of Ozone 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 50000

0.034 0.035 0.036 0.037

Sussex County (Seaford)- ln(O3) - 1996-2006

Summer Only - Noise and high frequency filtered

Hours

ln Transformed O3

0 10000 20000 30000 40000 50000

0.031 0.032 0.033 0.034 0.035 0.036 0.037

New Castle County (Bellfonte)- 1996-2006

Summer Only - Noise and high frequency filtered

Hours

ln Transformed O3
70 

Two alternatives to the US EPA’s standard method for estimating future monitor 

design values are examined in this section. One assesses an alternative method for 

calculating the baseline design value, and another assesses constructing an alternative 

RRF. The effects of both methods are analyzed separately and then analyzed and 

combined (see Section 7.8.2.4). 

Alternative Baseline Design Value

Seven monitors within the PA-NJ-DE-MD 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 baseline 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 baseline concentration is the average of the 2002, 

2003 and 2004 8-hour ozone design value. 

Using the US EPA recommended method for 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 baseline concentration calculation is to take the 

straight average of the 4th highs over the same years (2000-2004). This approach weighs 

each year equally. Table 7-4 lists the alternative 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 design values. Only one monitor (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 baseline 
71 

model concentrations ≥ 85 ppb, 2002 baseline model 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 different RRFs based on the 2002 baseline model 

concentrations. 

Recalculating the projected modeled 2009 design values using the alternative 

RRFs lowered nearly all seven monitors by 1 ppb, except Bristol and Colliers Mills which 

were unchanged (Table 7-6). The Bristol and 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 Modeled 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 Concentrations and Alternative RRFs 

Table 7-7 lists the projected 2009 modeled design values from combining the 

alternative baseline concentrations and the alternative RRF calculations described in the 

previous section. The combination of these two alternative approaches lowers the 

projected 2009-modeled concentrations significantly, but still leaves the Colliers Mills 

monitor above the most difficult concentrations listed in the US EPA’s WOE chart. The 
72 

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 Alternative 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 NOx SIP Call reduced ozone precursor emissions over a large region of the 

eastern US. These reductions undoubtedly reduced 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 miles southwest of the 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 since full implementation of the NOx SIP Call. Table 7-8 lists 

Methodist Hill’s eight-hour ozone design values, 4th 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 NOx SIP Call (2003 

ozone season). Ozone design values have fallen ~15%, 4th high values have fallen ~23% 

and exceedances have fallen ~95% since 2003. 

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

Year Design Value (ppm) 4th 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 15 
73 

Year Design Value (ppm) 4th 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 modeled 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 Methodist Hill’s design value by approximately 6 ppb. This 

indicates the model is not adequately characterizing the effects of the NOx SIP Call on 

upwind sources (under predicting the benefit). This suggests 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 the 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 significantly lower 

since the NOx SIP Call, they still represent a significant portion of the current eight-hour 

standard; almost 80% on the worst ozone days within the non-attainment area. 

7.8.2.6 Analysis of Air-Quality Model Sensitivity to Emission Changes 

Recent work by the University of Maryland 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 August 2003 Northeast Blackout by Hu, Odman 

and Russell indicate that air-quality models significantly under predicted ozone 

concentrations when compared to aircraft measurements made by the University of 

Maryland (Reference 7-10, Appendix 7-11). Modeled ozone reductions due to the large 

number of power plant shutdowns 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 NOx SIP Call by up to a factor of two. To account for 
74 

CMAQ’s resistance to change, CMAQ’s benefits could be increased by 50%; in other 

words a factor of 1.5 will provide a conservative estimate of the WOE benefit. 

Furthermore, two other sources of uncertainty 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 conditions of one area is a source of uncertainty. Currently, most 

ozone monitoring locations throughout the Mid-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 design values is 6 ppb. Similarly, the 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 across the modeling domain is approximately 

+/- 0.8 ppb. 

The two uncertainties above can be combined 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 uncertainties, and taking the square root of the 

sum to get the combined uncertainty. The combination 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 for 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 monitors currently operating 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 WOE 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 standard). For the remaining seven sites a 

number of analyses are undertaken to determine 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 finally an assessment of the air-quality models 

response to emission changes. 

Nearly all of the design values at the seven monitors declined over the last several 

years. Only one, Rider College, had a slight increase. Table 7-10 shows the last several 

years of design values at these seven monitors. It is expected that additional emission 

reductions due to the NOx SIP Call, mobile source reductions from fleet turnover as well 

as additional measures will continue to lower monitor design values. If this trend 
75 

continues, it is possible that most 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 employing 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 contributor to the non-attainment problem in the 

PA-NJ-DE-MD region. An analysis of modeled ozone concentrations at the Methodist 

Hill site in south-central Pennsylvania, a high elevation site, determined how well the 
76 

OTC air-quality model simulated the regional transport component. The modeled 2009 

concentration at Methodist Hill is approximately 6 ppb higher than the monitor’s current 

design value. This suggests the model is under predicting the benefits of the NOx SIP Call 

in upwind regions. To counter this underestimation, a uniform 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 multiplication factor of 1.5 and the latter by bounding 

the adjusted concentration with a 3.1 ppb. The effect 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 87.1 
77 

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 prohibitions (Delaware Regulation No. 1145) and 

ozone action days (voluntary program), and the potential reductions from these measures 

are summarized in Table 7-14. These two measures 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 controls that were not modeled, such as 

Delaware’s prohibition of lightering on ozone action days (Reg. 1124, Section 36), and 

reduction of emissions from high electric demand day electric generation (Reg. 1146 and 

Reg. 1148) 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 Rollback 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 statistical 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 (Reference 7-11). The 

source control theory is applicable 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 log CMAQ concentrations for 2002 base case 

that exceed 70 ppb at the monitor; this also includes concentrations within the 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 controls on the base case can be read for any probability and then 
78 

determine the corresponding RRF. For example, 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 value at Colliers Mills to be 74 ppb. 

4.2 4.3 4.4 4.5 4.6 4.7

012345

Colliers Mills-2002-ln(O3) PDF

N = 256 Bandwidth = 0.02

Density

3.2 3.4 3.6 3.8 4.0 4.2 4.4

01234

Colliers Mills-2009-ln(O3) PDF

N = 256 Bandwidth = 0.02

Density

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

and 2009 Cases 
79 

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 include a recent ozone trends analysis, 

alternative methods for developing 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, the 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, which 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 Colliers Mills will likely be below 85 ppb in 

2009. Furthermore, the correction for CMAQ’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 at 
80 

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 already at 2009 model predicted design 

values, with the trends analyses of the monitored values giving a strong 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 concentrations below the standard. It is also 

expected that additional emission reductions due to CAIR, mobile source reductions from 

fleet turnover as well as other additional measures, will continue to lower monitor design 

values beyond 2009. 

The photochemical grid modeling presented 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 analysis provides evidence that all 

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

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

that downward trend of ozone levels 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, Technology 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 Analyses in Attainment Demonstrations 

for the 8-hour Ozone NAAQS (Final version), U.S. Environmental Protection 

Agency, 2005. 

7-5. Delaware protocol for the modeled attainment demonstration of the 8-hour ozone 

NAAQS, Air Quality Management Section, Department of Natural Resources and 

Environmental Control, Dover, 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 Upper-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 Brankov, S. T. Rao, Igor Zurbenko, 2001: Assessing the 

impact of the acid deposition 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, Delaware 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 demonstrate that the RFP requirements for 

Delaware have been met, and that attainment will be reached in 2009. The RFP and 

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

of this document. Additional RACM measures must be implemented if such measures 

will advance the attainment date to 2008. 

Control measures under the Reasonably Available Control Technology (RACT) 

constitute a major group of RACM control measures for stationary 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 all relevant RACT controls, 

except one control, have been implemented in Delaware for attaining the 8-hour ozone 

standard (Reference 8-1). The one exception, the VOC control for crude oil lightering 

operations, has been completed since the RACT 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 the RACT SIP revision (Reference 8-1). 

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

a number of other VOC and NOx RACM measures. 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 RACM measures, or group of RACM measures 

that DE could adopt to advance 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 monitor 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 (using CAMx), EPA assessed the impact of 

each upwind state on a number of downwind 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 Ocean County, NJ is predicted by CAIR modeling 

to be 86% of 95 ppb = 85 ppb (see below)). The CAMx zero-out contribution of 6.5 ppb 

from Delaware is consistent with Delaware’s 7 ppb estimate from CALGRID zero-out 

modeling. 

Table VIII-11 of EPA’s Interstate Air Quality Rule technical supporting document 

(Reference 8-2) also lists the projected 8-hour ozone design values and the percent total 

average contribution resulting 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, all local and regional emission reductions 

planned to occur by 2009 project the entire Philadelphia non-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 concentrations 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 like 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 which 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 Technology (RACT) State Implementation 

Plan under the 8-Hour Ozone National 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 Interstate 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 transportation 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 their Transportation Improvement Programs (TIPs) and long range 

transportation plans to ensure that future highway vehicle emissions will not exceed 

relevant mobile budgets, and (3) failure of demonstrating such transportation conformity 

in TIPs and long range plans will lead to conformity lapse(s), resulting in freezing of 

federal highway funds and all federal highway projects in the lapsed area. 

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

required to establish mobile budgets for the 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 Delaware’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 source emissions, accounting for all relevant 

mobile source controls including all federal controls and Delaware specific controls as 

described in Section 6. The 2008 and 2009 mobile emissions are projected using EPA’s 

MOBILE6.2 for obtaining emission factors and the “Peninsula Travel Demand Model” for 

predicting future vehicle miles traveled (VMT). The MOBILE6.2 runs were conducted by 

AQM’s staff using the most recent available vehicle 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 source 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 12.86 
86 

State Total 21.84 43.89 

9.2.2 Mobile Budgets for 2009 Attainment Year 

Table 9-2 is a summary of 2009 mobile source 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 attainment 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 40.20 
87 

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 further progress, fails to meet any applicable 

milestone, or fails to attain the national ambient air quality standards by the applicable 

attainment date. The EPA has interpreted this CAAA provision as a requirement for States 

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

measures in their RFP and attainment demonstration 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 measures must be fully-adopted control measures 

or rules, so that, upon failure to meet milestone requirements or to attain the standards, the 

contingency measures can be implemented without any further rulemaking activities by 

the States and/or EPA. 

To meet the requirements for contingency 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% contingency 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 ozone RFP and Attainment Demonstration SIP 

revision. 

10.2 Contingency Measures for 2008 Milestone Year 

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

VOC reduction for Delaware for the 2008 milestone 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 baseline (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 contingency VOC reduction shortfall 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 reductions in 2008. For example, Subsection 

5.4.3 indicates that all three counties in Delaware will achieve significant NOx emission 

reductions in 2008, which are greater than the identified 2.64 contingency shortfall. 
88 

Therefore, there is no need to specify additional 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 rules to aid the OTR states to attain the 8-hour ozone standard 

in 2009 (Appendix 10-1). As part of this contingency 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 will lead to 1.2 TPD VOC reduction in 2009 

(Appendix 10-2). The percentage of these 3 controls 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 2002 Baseline: 1.2/111.28 = 1.1% 

As indicated in Subsection 6.5 of this SIP revision, Delaware has 2.70 TPD NOx 

emission surplus that will be used for contingency purposes. The percentage of the NOx 

surplus relative to the 2002 VOC baseline 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 voluntary 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 contingency in the 2009 attainment year. 

References 

10-1. Guidance for Growth Factors, Projections, 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, Research 
89 

Triangle Park, North Carolina, March 1993. 

10-2. Guidance on the Post-1996 Rate-of-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 South State Street, Dover, DE 19901. 

Appendix 4-1 

Part 1: MOBILE6.2 Input and Output Files 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-VU Region, Draft Final Technical Support 

Document, Prepared for Mid-Atlantic Regional Air Management Association 

(MARAMA) by MACTEC Federal Programs, Inc., December 7, 2006. 

Appendix 6-2 

The 2009 Emission Projections of Delaware 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 Transport Commission (OTC), OTC, 2000. 

Appendix 7-2 

Technical Supporting Document 1d: The 8-hour Ozone Modeling Using the 

SMOKE/CMAQ System, Bureau of Air Quality Analysis and Research, Division of Air 

Resources, New York State Department of Environmental Conservation, Albany, NY, 

February 2006. 

Appendix 7-3 

 Determination of Representativeness 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 University, and Charles Piety, Department of 

Atmospheric and Oceanic Science, University of Maryland, 2002. 

Appendix 7-5 

Technical Supporting Document 1a: Meteorological Modeling using Penn State/NCAR 

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

Research Division of Air Resources, 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: Processing of Biogenic Emissions for 

OTC/MANE_VU Modeling, Bureau of Air Quality Analysis and Research, Division of 
91 

Air Resources, New York State Department of Environment, Albany, NY, September 

2006. 

Appendix 7-8 

Technical Supporting Document 1c: Emission Processing for the Revised 2002 OTC 

Regional and Urban 12 km Base Case Simulations, Bureau of Air Quality Analysis 

and Research, Division of Air Resources, New York State Department of 

Environment, Albany, NY, September 2006. 

Appendix 7-9 

Technical Supporting Document 1f: Future Year Emissions Inventory 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 York State Department of Environment, 

Albany, NY, September 2006. 

Appendix 8-1 

 CALGRID Zero Out Modeling Analysis, Mohammed 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 Management 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