## Delaware Redesignation Request and Maintenance Plan Under the 2006 Daily PM 2.5 

## National Ambient Air Quality Standard

State Implementation Plan

For the New Castle County Portion of the



### Philadelphia

- Wilmington, PA

- NJ

- DE

Nonattainment Area for Fine Particles

Final

November 27 , 2012Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

2 

### Table of Contents

Acronym List

................................ ................................ ................................ ................................ .. 4

List of Tables

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

List of Figures

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

EXECUTIVE SUMMARY

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

1 Introduction

................................ ................................ ................................ ............................. 9

1.1 Documentation Organization

................................ ................................ .......................... 9

2 Background

................................ ................................ ................................ ............................. 9

2.1 Health Effects

................................ ................................ ................................ .................. 9

2.2 Philadelphia

- Wilmington, PA

- NJ

- DE Nonattainment Area Designation

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

3 EPA Requirements for Redesignation

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

3.1 NAAQS Compliance

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

3.1.1 EPA Requirements

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

3.1.2 Delaware Approach

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

3.2 Demo nstration that the NAAQS for daily PM 2.5 , as published in 40 CFR 50.13, has been attained (requirement 1 of 3)

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

3.3 Ambient monitoring data quality assured in accordance with 40 CFR 58.10, recorded in the EPA air quality system (AQS) database, and available for public view (requirement 2 of 3)

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

3.4 A commitment that once redesignated, the state will continue to operate an appropriate monitoring network to verify the maintenance of the attainment status (requirement 3 of 3)

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

3.4.1 EPA Requirements

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

3.4.2 Delaware Approach

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

4 Permanent and Enforceable Emission Reductions

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

4.1 U. S. EPA Requirements

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

4.2 Delaware Approach

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

4.2.1 Economic Conditions

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

4.2.2 Meteorology

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

4.2.3 Emission Inventory Improvements from 2007 base year to the 2008 attainment

year

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

4.3 Enforceable and Permanent PM 2.5 , NOx and SO 2 Measures that Contributed to Improved Air Quality between 2007 and 2008

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

4.3.1 Delaware

- specific Control Measures

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

4.3.2 Federal Control Measures

................................ ................................ ......................... 29Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

3 5 SIP Completeness

- Fully Approved SIP, Section 110 and Part D Requirements

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

5.1 EPA Requirements

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

5.2 Delaware Approach

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

5.3 Part D Plan Requirements for Nonattainment Areas

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

6 Maintenance Plan

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

6.1 EPA Requirements

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

6.2 Delaware Approach

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

7 Attainment Inventory

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

7.1 EPA Requirements

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

7.2 Delaware Approach

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

7.3 2008 Att a inm e nt Y ea r I nv e nt or y

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

8 Maintenance Demonstration

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

8.1 EPA Requirements

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

8.2 Delaware Approach

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

8.2.1 2017 and 2025 Projection Inventories

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

8.2.2 2017 and 2025 Mobile Source Emissions Budgets

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

8.2.3 Control Measures for Maintenance of Good Air Quality

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

8.2.4 Delaware

- specific NOx, PM2.5 or SO2 Control Measures (Effective Post 2008)

... 55

8.2.5 Federal Control Measures (Effective or Phased

- in Post 2008)

................................ . 56

8.2.6 Future Point Source Emissions Reductions Programs

................................ .............. 56

8.2.7 Controls to Remain in Effect

................................ ................................ .................... 58

9 Verify Continued Attainment

................................ ................................ ............................... 58

9.1 EPA Requirements

................................ ................................ ................................ ........ 58

9.2 Delaware Approach

................................ ................................ ................................ ...... 58

10 Contingency Measures

................................ ................................ ................................ .......... 59

10.1 EPA Requirements

................................ ................................ ................................ ........ 59

10.2 Delaware Approach

................................ ................................ ................................ ...... 59

11 Other Delaware Commitments

................................ ................................ ............................. 63

11 .1 C ommitm e nt to R e vise P l a n

................................ ................................ ......................... 63

11.2 P ublic P ar ti c ip a tion

................................ ................................ ................................ ....... 63

12 C onclusions

................................ ................................ ................................ ........................... 64Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

4 

### Acronym List

AQS

- EPA ’s Air Quality System

BYR

- Base Year

CAA

- Federal Clean Air Act

CAA A

- Clean Air Act Amendments of 1990

CFR

- Code of Federal Regulations (of the United States)

CSAPR

- Cross

- State Air Pollution Rule DAQ

- DNREC Division of Air Quality

DelDOT

- Delaware Department of Transportation

DNREC

- Delaware Department of Natural Resources and Environmental

Control

EGU

- Electric Generating Unit

GDP

- Gross Domestic Product

EPA

- United States Environmental Protection Agency

FYR

- Future Year

FHWA

- Federal Highway Administration

FR

- United States Federal Register

FRM

- Federal Reference Method

FTA

- Federal Transit Authority

I/M

- Inspection and Maintenance Program

MANE VU

- Mid

- Atlantic and Northeast Visibility Union

MARAMA

- Mid

- Atlantic Regional Air Management Association

NESC AU M

- Northeast States for Coordinated Air Use Management

LRTP

- Long Range Transportation Plan

MLK

- Martin Luther King Blvd. monitor in Wilmington, Delaware

MPO

- Metropolitan Planning Organization

mmBTU

- Million British Thermal Unit

NAA

- Non

- Attainment Area NAAQS

- National Ambient Air Quality Standard

NEI

- National Emission Inventory

NOx

- Oxides of Nitrogen

NAA

- N on

- attainment area

PM 2.5 - Particulate Matter with an aerodynamic diameter of 2.5 microns or less

RACM

- Reasonably Available Control Measure

RACT

- Reasonably Available Control Tech nology

RPO

- Regional Planning Organization

SIP

- State Implementation Plan (SAFETEA

- LU)

- Safe, Accountable, Flexible, Efficient Transportation Equity Act

– A

Legacy for Users

SO 2 - Sulfur Dioxide

TIP

- Transportation Improvement Program

t py

- Tons per Year

TSD

- Technical Supporting Document

VOC

- Volatile Organic Compound

WILMAPCO

- Wilmington Area Planning CouncilDelaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

5 

### List of Tables

Table 3

- 1 Philadelphia NAA 98th percentiles and Design Values (2008

- 2011)

Table 3

- 2 PM 2.5 Monitoring Site General Information

Table 3

- 3 PM 2.5 Monitor Site Specific Information

Table 4.1 Min, Max and Mean Temperatures and Total Precipitation (200 6

-

200 8 vs. 200 8

- 20 10 )

Table 4

- 2 Philadelphia NAA 2006

- 2011 daily NAAQS (98th percentiles)

Table 4

- 3 New Castle County 2007

- 2008 Emission Changes

Table 7

- 1 Summer vs. Winter

– Regional Consistency

Table 7

- 2 2006

- 2010 Seasonal PM 2.5 Average Percentages

Table 7

- 3 2008 New Castle County Emissions (tpy)

Table 8

- 1 Comparison of emissions for the years 2008, 2017 and 2025

Table 8

- 2 Reductions and % Change of NOx emissions for the years 2008, 2017 and 2025

Table 8

- 3 Reductions and % Change of PM 2.5 emissions for the years 2008, 2017 and 2025

Table 8

- 4 Reductions and % Change of SO 2 emissions for the years 2008, 2017 and 2025

Ta ble 8

- 5 New Castle County Mobile Source Emissions Budgets

Table 8

- 6 Post

- 2008 Emission Reductions due to Control Measures

Table 10

- 1 Schedule for Permit Revisions or Rule Revisions for Contingency MeasuresDelaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

6 

### List of Figures

Figure 2

- 1 Philadelphia Nonattainment Area Boundaries

- 2006 PM 2.5 NAAQS

Figure 3

- 1 Delaware’s PM 2.5 Monitoring Site Locations

Figure 4

- 1 2006

- 2011 Delaware Gross Domestic Product

– All Industry

Figure 4

- 2 Philadelphia NAA

– 2006 to 2011 daily PM 2.5 trends

Figure 4

- 3 Philadelphia NAA

– daily PM 2.5 trends (avg. all monitors)

Figure 4

- 4 Philadelphia NAA

– 2006 to 2011 PM 2.5 3

- Year Rolling Averages

Figure 4.5 Philadelphia NAA

– daily PM 2.5 tren ds (avg. all monitors)

Figure 7

- 1 Number of Winter vs. Summer ExceedancesDelaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

7 EXECUTIVE SUMMARY

This request f

or redesignation to attainment and maintenance plan is a State Implementation Plan (SIP) revision for the Delaware portion 1 of the Philadelphia

- Wilmington,

PA

- NJ

- DE fine particulate matter (PM 2.5 ) nonattainment area (Philadelphia NAA).

On November 13, 2009, EPA published the area designations for the 2006 24

- hour standard (74 FR 58688). That action, effective on December 14, 2009, designated the Philadelphia NAA as nonattainment for the 2006 24

- hour standard, based on 2006

- 2008 monitoring data. The Philadelphia NAA includes New Castle Co unty in Delaware; Burlington, Camden, and Gl oucester Counties in New Jersey; and Bucks, Chester, Delaware, Montgomery, and Philadelphia Counties in Pennsylvania

. CAA Section 107 establishes specific requirements to be met in order for a nonattainment area to be considered for redesignation

. This redesignation request and maintena nce plan SIP revision addresses all of the CAA Section 107 requirements, and provides technical information that support s a request to redesignate the Philadelphia NAA area to attainment of the 2006 daily PM 2.5 NAAQS.

PM 2.5 air quality has improved in New Castle County as a result of the implementation of

State and Federal emissions control measures

. The air quality improvement is due to permanent and enforceable emissions control measures. The entire Philadelphia NAA has certified and quality assured ambient air quality monitoring data for the 3

- year periods 2008

- 2010 and 2009

- 20 11 that all demonstrates attainment of the 2006 PM 2.5 NAAQS

. Th e purpose of th is redesignation request and m aintenance p lan is to request that th e United States Environmental Protection Agency ( EPA ) redesignate the Delaware portion of the Philadelphia NAA to attainment for this standard pursuant to the provisions of Section 107 of the federal Clean Air Act (CAA) (42 U.S.C. 7407). In summary, the plan includes :



###  A demonstration that attainment of the 2006 PM 2.5 air quality st andards for the Philadelphia NAA will continue through 2025

.



###  A n attainment emissions inventory t hat identifies the level of emissions in the area that

is su fficient to attain the NAAQS and projected future emissions inventories showing

that future emissions in the area will not exceed the level of the attainment inventory

over the 10

- year maintenance period.



###  C ontingency measures to be implemented in the unl ikely event of a subsequent violation of the air quality standard . The contingency measures listed in the Plan will be triggered

to expeditiously correct any future exceedances

.



###  O n

- road motor vehicle emissions budgets for 2017 and 2025 for use in transp ortation conformity determinations to assure that any increases in emissions from this sector do not jeopardize continued attainment of the 2006 daily PM 2.5 standards during the maintenance period.

1 Pennsylvania and New Jersey Departments of Environmental Protection are responsible for developing similar
plans for their portion of the Philadelphia NAA.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

8 Based on this presentation, New Castle County, Delaware meets the requirements for redesignation under the CAA (Section 107(d)(3)) and EPA guidance for fine particles. Consistent with the authority granted to EPA , the State of Delaware requests that New Castle County, Delaware be redesignated to attainment for the 2006 daily fine particles standard simultaneously with EPA approval of this Delaware State redesignation request and PM 2.5 Maintenance Plan for the New Castle County portion of the Philadelphia NAA.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

9 1 Introduction

The State of Delaware requests that the EPA redesignate the Delaware portion of Philadelphia NAA to attainment for the 2006 daily PM 2.5 NAAQS pursuant to the provisions Section 107 of the CAA (42 U.S.C. 7407). 2 Since the designations for the 2006 NAAQS fo r this pollutant were published, the area’s PM 2.5 air quality has improved due to permanent and enforceable emission reductions. Air quality in the area is significantly better than required by

this standard. This document demonstrates that PM 2.5 air qua lity in the Philadelphia area will remain compliant with the 2006 daily PM 2.5 NAAQS, as measured by a monitoring network that meets all federal requirements, through 2025.

Delaware is also requesting that EPA concurrently approve, as a revision to the D elaware state implementation plan (SIP), the related Section 175A maintenance plan, as described in

Sections 6

- 8 of this document . This plan includes mobile vehicle emissions budgets for the interim year of 2017 and the out year of 2025. It also contains contingency measures that will be implemented in the unlikely event that the area experiences an exceedance of the 2006 PM 2.5 NAAQS. The maintenance plan ensures that good PM 2.5 air quality will be maintained through

2025.

1.1 Documentation Organization

This document presents Delaware’s discussions and analysis of summarized air quality data and emission inventories, PM 2.5 control measures and applicable CAA and EPA requirements in support of Delaware’s request for redesignation to attainment under the 20 06 daily PM 2.5 NAAQS. Supporting documentation and data, such as Technical Support Documents (TSD), calculation spreadsheets, model input and output files, and other related data are available on the CD enclosed with this redesignation request and mainten ance plan. Much of the documentation that is referenced in the report, but not contained on the CD, has been compiled in electronic files located at the Division of Air Quality offices in Dover, Delaware and are available for review upon request by the pu blic.

2 Background

2.1 Health Effects

PM 2.5 , also known as f

ine particulate matter or fine particles, is defined as any airborne particle of solid or liquid matter that is less than or equal to 2.5 micrometers in diameter. PM 2.5 is not a single pollutant, but is a sum of all pollutants that have diameters less than 2.5

micrometers

. For reference, 2.5 micrometers i s about 1/30 th the diameter of a human hair.

Sources of PM 2.5 and PM 2.5 precursors include, most significantly, coal

- fired po wer plants and other combustion sources, fires, emissions from motor vehicles, windblown dust, and

natural emissions from trees and the oceans. These sources can be divided up into two types of

2 After EPA redesignates the Philadelphia nonattainment area to attainment, it will be known as the Philadelphia
Maintenance Area, or Philadelphia MADelaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

10 sources, primary and secondary. Primary sources directly emi t fine particulate matter into the atmosphere without any chemical change occurring to the pollutant. Secondary sources are sources from which precursor chemical species are released into the atmosphere , which then react with other chemical species in the atmosphere to create fine particulate matter. Some species which comprise fine particulate matter are sulfates

, ammonium nitrate , soot, sea salt, organic carbon

, elemental carbon and metals (crustal metals, transitional metals, and potassium ).

E xposure to high levels of PM 2.5 adversely affects human health. The main impacts of

PM 2.5 on human health are on the respiratory system and the cardiovascular system. Children, the elderly, and individuals with pre

- existing pulmonary or cardiac disease a re the most susceptible to PM 2.5 pollution. C omplications that can arise from exposure to PM 2.5 include decreased lung function

, chronic bronchitis; respiratory symptoms such as asthma attacks and difficulty breathing

, nonfatal heart attacks

, irregular hea rtbeat

, and premature death in individuals with pulmonary or cardiac disease

.

2.2 Philadelphia

- Wilmington, PA

- NJ

- DE Nonattainment Area Designation

Following promulgation of a new or revised NAAQS, EPA is required by the CAA to designate areas throughout the United States as attaining or not attaining the NAAQS; this designation process is described in S ection 107(d)(1) of the CAA. On October 17, 2006, EPA

retained the 1997 annual PM 2.5 NAAQS at 15 μg/m 3 based on a 3

- year average of annual mean

PM 2.5 concentrations, and promulgated a 24

- hour standard of 35 μg/m 3 based on a 3

- year average of the 98th percentile of 24

- hour concentrations (71 FR 61144), also known as the 2006

24

- hr NAAQS

. 3

On November 13, 2009, EPA published the area designations for the 2006 24

- hour standard (74 FR 58688). That action, effective on December 14, 2009, designated the same Philadelphia Area as nonattainment for the 2006 24

- hour standard, based on 200 6

- 200 8 monitoring data. The Philadelphia Area includes New Castle Cou nty in Delaware; Burlington, Camden, and Gloucester Counties in New Jersey; and Bucks, Chester, Delaware, Montgomery, and Philadelphia Counties in Pennsylvania (see Figure 2

- 1)

.

CAA Title I, Part D, Subpart 1 sets forth the basic nonattainment requiremen ts applicable

to all nonattainment areas. For the 2006 PM 2.5 daily NAAQS, these requirements are required to be met by December 14

, 2012. However, as stipulated in 40 CFR 51.1004(c), a “clean data

determination ” (CDD) by the EPA suspends the requirements to submit an attainment demonstration and associated reasonably available control measure s (RACM) (CAA Section 172(c)(1) and (c)(6)), reasonable further progress (RFP) requirements (CAA Section 172(c)(2)), contingency measures (C AA Section 172(c)(9)), and other planning SIP elements related to attainment for so long as the area continues to attain the NAAQS. EPA proposed the determination of attainment or “clean data determination” (CDD) for the 2006 annual PM 2.5

3 The terms “24

- hr” and daily are used interchangeably throughout this document.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

11 standard for the Philadelphia

- Wilmington, PA

- NJ

- DE nonattainment area on October 2, 2012 (77 FR 60089).

Figure 2

- 1 Philadelphia Nonattainment Area Boundaries

- 2006 PM 2.5 NAAQS

3 EPA Requirements for Redesignation

Section 107(d)(3)(E) of the CAA allows states to request nonattainment areas to be redesignated to attainment provided certain criteria are met. The criteria for redesignating a

nonattainment area to attainment are as follows:

 EPA has determined that the area attained the NAAQS. For the 2006 PM 2.5 NAAQS, the

areas must show that the 3

- year average of the 98 th percentile of 24

- hour concentrations from three (3) consecutive calendar years of quality

- assured air quality monitoring data

is 35 μg/m 3

, or lower (71 FR 61144)

.

 The request must contain a showing that the improvement in air quality is due to permanent and enfo rceable reductions in emissions resulting from the implementation of the applicable SIP

.

 The applicable implementation plan must be fully approved by EPA under Section 110(k) of the CAA, and the redesignation request must contain a determination that the state meets all applicable requirements for the area under Section 110 and Part D.

 A full y approve d maintenance plan, including contingency measures, for the area under

Section 175A of the Act. Section 175A requires demonstrating that the area willDelaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

12 maintain (continue to attain) the standard for at least ten years after redesignation to

attain ment, and that contingency measures be implemented if a violation is monitored at any time during the ten

- year maintenance period.

This document addresses each of these requirements. EPA has published applicable guidance in a memorandum from John Calcagni, Director, Air Quality Management Division,

entitled Procedures for Processing Requests to Redesignate Areas to Attainment (redesignation guidance), issued September 4, 1992, to Regional Air Directors. 40 CFR Pa rt 51, Subpart Z,

entitled Provisions for Implementation of PM 2.5 National Ambient Air Quality Standards (implementation rule) provides additional information

. The State of Delaware has based this redesignation request and maintenance plan on the redesignation guidance and the implementation rule, supplemented with additional guidance receiv ed through coordination with

EPA Region 3 staff

.

3.1 NAAQS Compliance

3.1.1 EPA Requirements

CAA Section 107(d)(3)(E)(i) addresses attaining the standard. This Sectio n states that

the demonstration should rely upon ambient air quality data. The data that are used to demonstrate attainment should be the product of ambient monitoring that is representative of the area of highest concentration. Additionally, the data sh ould be collected and quality

- assured in

accordance with 40 CFR Part 58 and recorded in the Air Quality System (AQS) in order for it to be available to the public for review.

3.1.2 Delaware Approach

EPA ’s published guidance document, Procedures for Processing Requests to Redesignate

Areas to Attainment (September 4, 1992), which details specific requirements regarding the collection and use of ambient air monitoring data needed to support a redesignation request. Before the Philadelphia NAA can be r edesignated to attainment for the 2006 daily PM 2.5 NAAQS , the City of Philadelphia, Delaware Department of Natural Resources and Environmental Control (DNREC), Division of Air Quality (DAQ), the New Jersey Department

of Environmental Protection and the Pen nsylvania Department of Environmental Quality must

each demonstrate that the daily PM 2.5 NAAQS has been attained in their respective jurisdictions of the Philadelphia NAA. PM 2.5 monitoring data must show that violations of the NAAQS are no longer occurrin g within the NAA.

This showing must rely on three complete, consecutive calendar years of quality assured data. Further, the air monitoring data must be quality assured in accordance with 40 CFR 58.10,

recorded in EPA ’s Air Quality System (AQS) database, and made available to the public. Finally, Delaware DAQ must commit to continue to operate an appropriate monitoring network to verify the maintenance of the attainment status, once the area has been redesignated to
attainment

. T aken together there are three primary requirements:Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

13 1) A demonstration that the NAAQS for daily PM 2.5 , as published in 40 CFR 50. 13 , has

been attained.

2) Ambient monitoring data quality assured in accordance with 40 CFR 58.10, recorded in

the EPA air quality system (AQS) database, and available for public view.

3) A commitment that once redesignated, the state will continue to operate an appropriate monitoring network to verify the maintenance of the attainment status.

3.2 Demonstration that the NAAQS fo r daily PM 2.5 , as published in 40 CFR 50. 13

, has been attained (requirement 1 of 3)

The City of Philadelphia, and the States of Delaware and New Jersey, and the Commonwealth of Pennsylvania

, (‘‘the States’’) submitted quality assured air quality monitoring

data into the EPA Air Quality System (AQS) database for the 2008

– 201 0 and 2009

- 2011 monitoring periods. The States then certified that data. The criteria for determining if an area is

att aining the 2006 daily PM 2.5 NAAQS are set out in 40 CFR 50 and appendix N. The 24

- hour primary and secondary PM 2.5 standards are met when the 98th percentile 24

- hour concentration is less than or equal to 35 μg/m 3

. Three years of valid daily means are required to produce a valid daily standard design value. A year meets data completeness requirements when at least 75 percent of the scheduled sampling days for each quarter have valid data. The use of less than complete data is subject to the approval of EPA , which may consider factors such as monitoring site closures/moves, monitoring diligence, and nearby concentrations in determining whether to

use such data.

While most of the monitoring data submitted by the States was complete, several monitors in the Philadelphia NAA had less than four quarters of complete data for one or more years during the 2008

– 2010 and 2009

- 2011 monitoring periods. For these monitors, EPA applied the data substitution test set out in the April 1999 EPA guidance do cument ‘‘ Guideline on Data Handling Conventions for the PM NAAQS ”. The ‘‘maximum quarter’’ substitution test (Max

- Q) identified in the guidance document is used for monitors with missing data. Maximum recorded values are substituted for the missing data. The resulting design value is compared to

the standard. The monitor passes if the design value with maximum values substituted meets the

standard. If the monitor does not pass using the Max

- Q Sub test, then another statistical method was required. Th e statistical method used to determine whether an incomplete monitor would have met the NAAQS, is to first establish a linear regression relationship between the target monitor and another monitor in or close to the nonattainment area. The linear regressio n would then be used to fill in the missing data for the target monitor. The results are checked with an additional statistical procedure (“bootstrapping”) to give a “diagnostic” design value verifying if

the conclusion of attainment is correct.

2008

- 2 010 data

The Max

- Q test could not be used to show attainment, considering 200 8

– 20 10 data, for one monitor located in Chester County, Pennsylvania ( “ New Garden ” monitor : ID 420290100 )

. For this monitor, EPA performed a linear regression between the site with incomplete data and a nearby site ( “ Newark ” monitor : ID 100031012 )

, which has more complete data in the period inDelaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

14 which the incomplete site is missing data. The equation developed from the relationship

between the monitors was used to fill in missing data for the New Garden monitor, so that the normal data completeness requirement of 75 percent of data in each quarter of the three years

was met. After the missing data for the site was filled in, the res ults were verified through bootstrapping

. The results of EPA ’s statistical analysis indicated that while the Chester County, Pennsylvania monitor had less than complete data, the data is sufficient to demonstrate that the NAAQS has been met for 2008

- 2010 design values

. Therefore, all monitors in the Philadelphia NAA meet the 2006 daily PM 2.5 NAAQS based on certified, quality assure d and complete 2008

- 2010 monitoring data.

2009

- 2011 data

Al though the Philade l phia NAA initially came into attainment considering 2008

- 2010

, this redesignation request is being submitted in late 2012. Therefore, more recent monitoring data is available (e.g., 2011 and preliminary 2012). However, t he Philadelphia Area had three incomplete monitors for 2009

- 2011. 4 Monito ring site 42

- 101

- 0024 was shutdown on Jan 2011,

and site 42

- 101

- 1002 started operating in Jan uary 2011

. EPA applied linear regression analysis, followed by bootstrap runs for the third incomplete monitor: the New Garden monitor at site 42

- 029

- 0100 located in Chester, PA, which had missing data due to power failures in 2011. The results of EPA’s analysis show that the "diagnostic design value ” computed from EPA 's

statistical procedure is 33 μg/m 3 for the New Garden monitor

. 5 , 6 EPA’s analysis may be found in this Plan’s supporting documentation, “ B2

- Statistical Results for 2009

- 2011 Design Values ”

.

Summary

As shown in Table 3

- 1, t he highest 3

- year design value for the daily NAAQS, based on

2008

- 2010 and 2009

- 2011 data is 33 μg/m 3

, which is less than the level of the daily PM 2.5 NAAQS of 35 μg/m 3

. In addition, preliminary 2012 data from AQS, the 1 st quarter values

continue to show attainment with the high est value of 35 μg/m 3 ( “ Bucks County ” : monitor ID

420170012 )

. Therefore, certified and quality

- assured ambient air quality monitoring data

demonstrate s that the air quality has met the 2006 NAAQS for daily PM 2.5 in the Philadelphia

NAA for the 2008

- 2010, and 2009

- 2011 timeframes. T he 2006 daily PM 2.5 NAAQS attainmen t, accompanied by decreases in emission levels discussed in Section 3.3.1, supports a redesignation to attainment for the New Castle County, Delaware portion of the Philadelphia NAA based on the requirements in Section 107(d)(3)(E) of the CAA as amended.

4 As of July, 2012 the 2011 AQS monitoring data showed one quarter of missing data for each of the following monitor sites: Newark, ID 100031012, Bellefonte, ID 100031003 and New Garden, ID 420290100. Delaware’s incomplete 2011 data has since been deemed valid because it passed the Max Q test.

5 E. V. Rosa, EPA Region 3 (August 27, 2012)

. 6 Chester County PA monitor had incomplete data in 2011. However, the EPA " Statistical Results for Computation

of 2009

- 2011 Diagnostic 24

- hour PM 2.5 Design Values of Monitoring Site 42

- 029

- 0100 in the Philadelphia

Wilmington Nonattainment Area” demonstrat es 2009

- 2011 “Clean Data” for the Philadelphia NAA

.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

15 Table 3

- 1 Philadelphia NAA 98 th percentiles and Design Values (2008

- 2011)

98 th Percentile Value 1 2008

- 2010 Design

Value 2008

-

2010

Status 2 2009

-

2011 Design

Value 2009

-

2011

Status 2 State County Monitor

ID 2008 2009 2010 2011 Pre

Lim.

2012 6

DE Bellefonte 100031003 28.0 23.2 24.3 22.4* 17.5 25 C 23 Max

- Q

Lums 100031007 23.9 20.6* 27.5 21.0 21.8 22 C 23 Max

- Q

Newark 100031012 31.6 23.4 24.9 22.2* 20.2 26 Max

- Q 24 Max

- Q

MLK 100032004 28.1 28.4 27.9 24.7 22.7 25 Max

- Q 27 C

NJ Camden 340071007 28.6 25.0 23.4 24.3 22.0 26 C 24 C

Gloucester 340150004 34.8 21.9 21.6* 22.2 23.9 30 C 22 Max

- Q

PA Bucks 420170012 30.9 25.8 28.3 29.7 34.9 28 C 28 C

Chester 420290100 32.0 31.1 35.1 33.8* 21.0 33 Bootstrap 33 Inc

. (3)

Delaware 420450002 28.6 27.9 32.8 28.6 23.9 30 C 30 C

Montgomery 420910013 23.7 27.2 25.9 27.6 21.1 26 C 27 C

Philadelphia 421010004 34.5 25.9 27.6 29.6 27.9 29 C 28 C

Philadelphia 421010024 30.5 25.5 25.2

- - 27 C 25 Inc

. (4)

Philadelphia 421010047 32.8 27.2 27.6 27.5 20.0 29 C 27 C

Philadelphia 421010055 34.5 28.6 28.9 30.6 19.6 31 C 29 C

Philadelphia 421010057 32.8 28.3 27.9 30.5 20.6 30 C 29 C

Philadelphia 421011002

- - - 27.5 23.4 NA NA 27 Inc

. (5)

NAA Avg. (all monitors) 30.4 26.0 27.3 26.8 22.7 27.8 26.6 30.4

NOTES :

2009

- 2011 data sour ce: E. V. Rosa, EPA Region 3 ( August 27, 2012)

. 2008 data source: EPA AQS (as of July, 2012)

. 1

. Yearly 98th percentile values initially not meeting the completeness criteria are marked with an asterisk (*). The dash (

- ) indicates that no data was collected during this time.

2

. This column indicates whether the monitoring data from the monitor meet the completeness requirement (C) or not (Inc

. ) for each quarter of the 3

- year period. “Max

- Q” denotes that the monitor has incomplete data, but passed the maximum quarter substitution test.

3. “ EPA only applied its statistical procedure (a.k.a. boo t strapping) for the 2011 third incomplete monitor for : the

New Garden monitor ( 420290100 loc ated in Chester, PA, which had missing data due to power failures

in 2011. The "diagnostic" design value computed from EPA's procedure was 33 μg/m 3 ”

, (see footnote 6 )

. 4

. Monitoring site was shut down on January 1, 2011.

5

. Monitoring site commenced operation on June 1, 2010

. 6. Preliminary 2012 data is 1 st quarter only, obtained from AQS in July, 2012

.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

16 3.3 Ambient monitoring data quality assured in a ccordance with 40 CFR 58.10,

recorded in the EPA air quality system (AQS) database, and available for public view ( r equirement 2 of 3)

Delaware DAQ has quality assured all data in accordance with 40 CFR 58.10 and all other federal requirements. Delaware DAQ has recorded the data in the AQS database and, therefore, the data are available to the public.

Delaware began official PM 2.5 monitoring in 1999. Delaware’s PM 2.5 network consists of seven (7) monitoring sites, one of which employs a collocated monitor. There are four (4) sites in New Castle County, two (2) in Kent County and one (1) in Sussex County. Tab le 3

- 2 lists the

PM 2.5 sites in New Castle C ounty (the only nonattainment county), including the nature of the area, and gene ral site descriptions. Table 3

- 3 contains more specific information for each PM 2.5 monitoring site in New Ca stle County.

Table 3

- 2 PM 2.5 Monitoring Site General Information

Site Name & AQS ID Land Use Setting Metropolitan Statistical Area

Bellefonte

10

- 003

- 1003 Residential Suburban Philadelphia

- Wilmington

MLK

10

- 003

- 2004 Commercial Urban Philadelphia

- Wilmington

Newark

10

- 003

- 1012 Residential Suburban Philadelphia

- Wilmington

Lums Pond

10

- 003

- 1007 Agricultural Rural Philadelphia

- Wilmington

Table 3

- 3 PM 2.5 Monitor Site Specific Information

Site Name & AQS ID Parameter Start Date Objective

Bellefonte

10

- 003

- 1003 PM 2.5 1/1/1999 Population Exposure,

Attainment Status

MLK

10

- 003

- 2004 PM 2.5 1/1/1999 Maximum concentration,

Attainment Status

PM 2.5 speciation 6/1/2001 PM 2.5 Characterization

Black Carbon 1/1/2001 Diesel PM 2.5 Indicator

Newark

10

- 003

- 1012 PM 2.5 12/15/1999 Population Exposure,

Attainment Status

Lums Pond

10

- 003

- 1007 PM 2.5 1/1/1999 Transport/Background,

Attainment StatusDelaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

17 The primary goal of the PM 2.5 monitoring network in Delaware is to determine the status

of the ambient air with respect to the 24

- hour and annual average PM 2.5 NAAQS. In accordance with federal regulations, s tate agencies must operate at least the minimum number of required

PM 2.5 sites listed in 40 CFR Part 58 Appendix D Table D

- 5. These required monitoring s tations or sites must be sited to represent community

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

1) At least one monitoring station is to be sited in a population

- oriented area of expected

maximum concentration. 2) For areas wi th more than one required station, a monitoring station is to be sited in an area of poor air quality. 3) Each State shall install and operate at least one PM 2.5 site to monitor for regional background and at least one PM 2.5 site to monitor regional transport

.

Figure 3

- 1 shows the locations of Delaware’s PM 2.5 monitors. All data from these

monitors are measured using EPA approved federal reference methods (FRM). All PM 2.5 monitoring sites are located appropriately and are eligible for comparison to the an nual and daily

PM 2.5 NAAQS.

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

- Wilmington) monitoring every day. MLK is also the designated collocated site, with the collocated monitor designated as MLK

- b operating on a one in six day schedule. A ll data were submitted to EPA’s Air Quality System (AQS) in a timely manner in accordance with the schedule prescribed by

EPA.

Chemical speciation is encouraged at sites where the chemically resolved data would be useful in developing SIPs and supporting atmospheric or health effects related studies. Chemical speciation is conducted at MLK in Wilmington and Dover in Kent County. The PM 2.5 chemical speciation sites include analysis for elements, selected anions and cations, and carbon.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

18 Figure 3

- 1 Delaware’s PM 2.5 Monitoring Site Locations

Delaware’s original PM 2.5 monitoring network design and monitor siting were completed

in accordance with EPA requirements and guidance as stated in 40 CFR Part 58 Appendices D and E, and the EPA Office of Air Quality Planning & Standards ( OAQPS ) document “Guidance for Network Desi

gn and Optimum Site Exposure for PM 2.5 and PM

10 ” ( EPA 1997a). Final

network documents were submitted to EPA Region 3 in June 1998, and EPA approved

Delaware’s PM 2.5 monitoring network.

Delaware Annual Ambient Air Monitoring Network Reviews , including PM 2.5 , have been completed each year in accordance with 40 CFR Part 58 Appendix D and subsequently submitted to EPA Region 3 for approval.

In fulfillment of the federal 103 g rant r equirements, Delaware submits annual Delaware Data Quality Assessments for PM 2.5 speciation data and PM 2.5 FRM data to EPA Region 3. All data comply with appropriate federal and state requirements, including 40 CFR Part 50 Appendices L and N, and 40 CFR Part 58 Appendix A.

In fulfillment of the federal 103 g rant r equireme nts, Delaware also submits annual PM 2.5 Speciation Monitoring Network Review and Monitoring Strategy reports to EPA Region 3. The

PM 2.5 speciation network design and monitor siting follows EPA requirements and guidance as stated in 40 CFR Part 58 Appendic es D and E, and the documents “ Guidance for Network Design and Optimum Site Exposure for PM 2.5 and PM

10 " ( EPA 1997a), “ Particulate MatterDelaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

19 (PM 2.5 ) Speciation Guidance ” ( EPA 1999), and “ Guideline on Speciated Particulate Monitoring ” ( EPA 1999a).

3.4 A commitme nt that once redesignated, the state will continue to operate an appropriate monitoring network to verify the m aintenance of the attainment status (requirement 3 of 3)

3.4.1 EPA Requirements

Once an area has been redesignated, the states must continue to operate an appropriate air quality monitoring network in accordance with 40 CFR Part 58, to verify the area's attainment

status. In cases where measured mobile source parameters (for example , vehicle miles traveled) have changed over time, a state may also need to perform a saturation monitoring study to

determine the need for

, and location of

, additional permanent monitors.

3.4.2 Delaware Approach

The State of Delaware operates a monitoring net work that is significantly more robust than required by federal regulation. New Castle County is nonattainment for the 1997 PM 2.5 annual standard and the 2006 daily PM 2.5 standard. Accordingly, Delaware is required to maintain its current monitoring network.

As mentioned in above, states must continue to operate an appropriate air quality monitoring network in accordance with 40 CFR Part 58, to verify the area's attainm ent status. Information on Delaware’s monitoring netwo rk was discussed in Section 3.3.

The State of Delaware commits to operating and maintaining an air quality network for

PM 2.5 monitoring that meets all federal requirements. However, should changes be come necessary in the future Delaware DAQ will consult with EPA Region 3 prior to making changes

to the existing monitoring network. Delaware DAQ will continue to quality assure the monitoring data to meet the requirements of 40 CFR 58 and all other feder al requirements. Delaware DAQ will enter all data into AQS on a timely basis in accordance with federal guidelines.

4 Permanent and Enforceable Emission Reductions

4.1 U. S. EPA Requirements

As noted in Section 107(d)(3)(E)(iii) and in the redesignation gui dance, state s must be able to reasonably attribute its air quality improvements to emission reductions of precursors or

direct PM 2.5 that are permanent and enforceable. Attainment resulting from temporary reductions in emission rates (such as reduced prod uction or shutdown due to temporary adverse economic conditions) or unusually favorable meteorological conditions does not qualify.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

20 4.2 Delaware Approach

Delaware will demonstrate the improvement in air quality described in 3.2 of this document was not a result of temporary adverse economic conditions (4.2.1) or unusually favorable meteorology (4.2.2). Delaware then demonstrates that the improvements in a ir quality described in 3.2 of this document are reasonably attributable to permanent and enforceable

emission reductions of direct PM 2.5 and PM 2.5 precursors (4.2.3 and 4.3).

4.2.1 Economic Conditions

Delaware evaluated the role economic conditions may have played in the imp r ov e m e nt
in a ir qu a li t y described in 3.2 of this document by evaluating the Gro ss D omestic Product (GDP) growth rate. The GDP growth rate is an indicator of economic health. If the GDP growth rate is increasing, it is an indication that the activity of emitting sources are increasing. Conversely, i f the GDP is declining it is an indication that the activity of emitting sources may

be reduced because of economic conditions.

Delaware specific GDP for all industries, obtained from the U.S. Bureau of Economic Analysis (BEA), is presented in Figure 4

- 1.

Figure 4

- 1 200 6

– 2011 Delaware Gross Domestic Product

– All Industry

Figure 4

- 1 shows that except for a decline betwee n 2007 and 2008, 7 all industries increased GDP in every year from 200 6 through 2011. Of specific relevance to air quality is the comparison between the time when Delaware’s air quality did not meet the PM 2.5 daily NAAQS (2 006

- 2008 design value ) and the t ime when it did meet the NAAQS (2008

- 201 0 and 2009

- 2011

7 According to the Delaware Department of Labor the reason for the decline between 2007 and 2008 was an
economic recession that began in Delaware in December 2007.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

21 design values ). Th e GDP in every year between 200 9 and 2011 is greater than every year

between 200 6 and 2008 . This analysis of GDP indicates that economic conditions did not contribute to the improv ement in air quality.

4.2.2 Meteorology

Delaware evaluated the role meteorology may have played in the imp r ov e m e nt in a ir

qu a li t y described in 3.2 of this document by evaluating temperature and precipitation data

. Temperature and precipitation are the primary meteorological variables that impact the

formation of PM 2.5

. Temperature and precipitation impact both the emission from sources (e.g., power plant emissions are highest during very hot and cold weather), and ambient PM 2.5 concentrations (e.g., precipitation removes PM 2.5 from the air through deposition).

Delaware analyzed historical meteorological data for Wilmington, Delaware, which is the

location where Delaware’s highest PM 2.5 concentrations are recorded (monitor ID = 1000 3 2004).

Table 4

- 1 shows 3

- year monthly averages for : minimum, maximum and means temperatures (in degrees Fahrenheit) , as well as total precipitation by monthly average and for the entire 3

- year periods 2006

- 2008 and 2008

- 2010

. 8

8 Recall that 2006

- 2008 average PM2.5 concentration was used to calculate the final Philadelphia NAA design
values causing nonattainment, and the 2008

- 2010 average PM2.5 concentration was when the Philadelphia NAA
initially came into attainment. Therefore, by comparing the meteorology between these two 3

- year periods we can
evaluate the effect that meteorology had on PM2.5 concentrations during a time when the air quality was

nonattainment and a time when it was attainment.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

22 Table 4

- 1 Min, Max and Mean Temperatures and Total Precipitation (200 6

-

2008 vs. 2008

- 2010 )

2006

- 2008 2008

-

2010 2006

-

2008 2008

-

2010 2006

- 2008 2008

- 2010 2006

-

2008 2008

- 2010

3

- yr AVG

Min. Temp ( o F) 3

- yr

AVG

Min. Temp ( o F) 3

- yr

AVG

Max. Temp ( o F) 3

- yr

AVG

Max. Temp ( o F) 3

- yr
Mean Temp ( o F) 3

- yr
Mean Temp ( o F) Total Precip (in) Total Precip (in)

Jan 29.6 24.7 46.2 39.6 37.9 32.2 9.2 7.0

Feb 25.0 26.4 41.6 43.1 33.3 34.8 8.6 10.5

Mar 33.9 35.4 54.2 54.4 44.1 44.9 8.9 11.3

Apr 43.4 44.8 63.8 65.5 53.6 55.2 14.9 8.4

May 51.3 52.9 73.7 73.1 62.5 63.0 8.4 11.3

Jun 63.7 64.4 82.6 83.7 73.2 74.1 14.8 11.2

Jul 67.9 67.0 87.2 87.0 77.6 77.1 13.9 14.8

Aug 65.9 66.4 85.0 84.9 75.4 75.6 7.1 9.2

Sep 58.9 59.6 78.2 78.4 68.5 69.0 11.9 16.1

Oct 47.8 46.1 68.2 65.9 58.0 56.0 13.3 13.2

Nov 38.7 38.9 54.8 55.4 46.8 47.1 9.5 8.1

Dec 31.0 27.5 47.3 42.6 39.1 35.0 11.1 15.4

Annual average 3

- Yr Average Temp., and 3

- Yr Total Precipitation 46.4 46.2 65.2 64.5 55.8 55.3 131.7 136.5

From Table 4

- 1, we see that the annual average 3

- year monthly averages for minimum, maximum, and mean temperatures for 200 6

- 20 08 are slightly higher than those temperatures during the years 200 8

- 20 10 (e.g., the 2006

- 200 8 annual average mean temperature wa s 55

. 8 degrees while the 2008

- 2010 annual a verage mean temperature was 55.3 degrees). Because
temperatures were only slightly lower during the years showing attainment (200 8

- 20 10 ),

de creased temperatures did not likely contribute to the improved air quali ty.

From Table 4

- 1, we see that 3

- year total precipitation was about 3.5 % higher in 200 8

- 20 10 compared to 200 6

- 20 10 (13 6.5 in. and 131.7 in. respectively). Increased precipitation

disfavors PM 2.5 formation, because it results in deposition of existing ambient PM 2.5 and precursors. Because total precipitation was only slightly higher during the years showing attainment (200 8

- 20 10 ), increased precipitation did not likely contribute to the improved air quality.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

23 In summary, 1) the annual average 3

- year monthly min, max, and mean temperatures are very similar between the nonattainment timeframe (200 6

- 200 8 ) and the attainment timeframe (200 8

- 20 10 ), and 2) the total precipitation is also very similar between those two periods. Therefore, although Meteorology will always play a role in the formation of PM 2.5 , DAQ concludes that meteorology did not play a significant role in air quality improvements for redesignation purposes under the 2006 daily PM 2.5 NAAQS.

4.2.3 Emission Inventory Improvements from 200 7 base year to the 2008 attainment year

It was demonstrated in 4.2.1 and 4.2.2 that neither economic conditions nor meteorology significantly contributed to the improved air quality. Given this, it follo ws that permanent and

enforceable reductions of PM 2.5 , NO X and SO 2 , 9 from a variety of state and federal measures are the primary reason for the improved air quality and attainment of the standard for fine particles.

As discussed previously, i n November , 2009 (effective December 14, 2009 )

, EPA published its air quality designations for the 2006 PM 2.5 NAAQS based upon air quality

monitor ing data for calendar years 2006

– 2008 ( 74 FR 8688 ). Since 2007

, permanent and enforceable reductions of primary PM 2.5 a nd secondary PM 2.5 precursor emissions have contributed to improvements in PM 2.5 air quality and to the attainment of the daily PM 2.5 NAAQS. To help demonstrate how emission reductions have improved air quality, we evaluate air quality trends , which can be seen in Table 4

- 2 and Figures 4

- 2 and 4

- 3

, and discuss emission

reductions due to permanent and enforceable control measures

.

The Table values r epresent the daily average concentration s as calculated from the four calendar quarterly averages at each monitoring site

, and th e 3

- year design values from 2006

- 2011

. As Table 4

- 2 shows, the highest annual value in the Philadelphia NAA nonattainment

area has decreased from 39.0 μg/m 3 in 200 6 (m onitor ID 421010047 ) to 34.0 μg/m 3 in 2011 (monitor ID 420290100 ) , or 5.0 μg/m 3 , which represents a 12.8 % drop. This daily average is the basic statistic used in determining trends and compliance with the daily average NAAQS.

9 Ammonia and volatile organic compounds (VOC) are contributors to PM 2.5 formation; however, they are not considered significant overall contributors in the Philadelphia NAA. Therefore, this demonstration of air quality improvements due to permanent and enforceable emission reductions of precursors or di rect PM 2.5 focuses on SO 2 , PM 2.5 , and NO X

.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

24 Table 4

- 2 Philadelphia NAA 2006

- 2011 daily NAAQS ( 98 th percentiles )

State County and DE sites Monitor ID 2006 2007 2008 2009 2010 2011

DE New Castle (Bellefonte) 100031003 31 32 36 23 24 22

New Castle (Lums) 100031007 28 30 28 21 28 21

New Castle (Newark) 100031012 31 31 29 23 25 22

New Castle (MLK) 100032004 38 34 35 28 28 25

NJ Camden 340071007 38 35 28 25 23 24

Gloucester 340150004

- 31 24 22 22 22

PA Bucks 420170012 34 35 31 26 28 30

Chester 420290100 38 38 32 31 35 34

Delaware 420450002 37 34 29 28 33 29

Montgomery 420910013 36 30 24 27 26 28

Philadelphia 421010004 38 35 35 26 28 30

Philadelphia 421010024 35 33 31 26 25

-

Philadelphia 421010047 39 35 33 27 28 28

Philadelphia 421010055*

- - 35 29 29 31

Philadelphia 421010057

- - 33 28 28 31

Philadelphia 421011002

- - - - - 28

Philadelphia NAA Average μg/m3 (all monitors) 35 33 31 26 27 27

 Camden 340070003 was shutdown in 20 08 ; therefor e not included for this 2006

- 2010 trend analysis

 Gibbstown (Gloucester) monitor: On February 2, 2007, a PM 2.5 monitor (0004) began sampling at the Gibbstown site which was the replacement for a site discontinued in 2006 (5001) in a different area of

Gibbstown.

 Monitor 421010055 in Philadelphia County, Pennsylvania, sta rted operating in 2008.

 Monitor 4210010057 started operating in the 3rd Quarter, 2007

.

 Monitor 421011002 started operating in January, 2011.

 ND = monitor did not operate or was no t in existence in that year.

As T able 4

- 2 shows, the daily mean for the Philadelphia NAA decreased from a high of

39 μg/m 3 in 2006

, to 34 μg/m 3 in 201 1 , or 5 μg/m 3

, t his equa tes to a 13 % drop in the daily mean value. Figure 4

- 2 illustrates the trends of the yearly 98 th percentile PM 2.5 concentrations of each

NAA monitor since 2006 , which are generally decreasing

. Figure 4

- 3 also shows 2006

- 2011 yearly 98 th percentiles, but instead of showing a trend for each monitor, all the monitors in the Philadelphia NAA were averaged . This helped eliminate some v ariability between monitors in order to get a NAA

- wide overall trend. Figure 4

- 4 shows the downward trends since 200 6 using

3

- year rolling

- averages , which smoothes out inter

- monitor variability yet uses actual design values for each monitor. Figure 4

- 5 is a variation on Figure 4

- 4 by plotting the average design values per year, calculated from all monitors in the Philadelphia NAA.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

25 Figure 4

- 2 Philadelphia NAA

– 2006 to 2011 daily PM 2.5 trends

Figure 4

- 3 Philadelphia NAA

– daily PM 2.5 trends (avg. all monitors)Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

26 Figure 4 Philadelphia NAA

– 2006 to 2011 PM 2.5 3

- Year Rolling Averages

Figure 4.5 Philadelphia NAA

– daily PM 2.5 trends (avg. all monitors)

Some of these air quality improvements were a result of emissions reductions which were due to the application of tighter federal emission standards on motor vehicles and fuels, and some due to the requirements of the federal NOx SIP Call. Others were due to Delaware

-Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

27 specific control measures. Section 4 of this plan describes the se reductions in more detail, along with an explanation of their regulatory status.

One of the ways states have demonstrated how controls have contributed to reductions is by comparing a base year emission inventory to the attainment year emission inventory . The

EPA ’s PM 2.5 Emissions Inventory Guidance required that states with PM 2.5 NAAQS nonattainment areas prepare and submit a base year inventory of anthropogenic sources of direct

PM 2.5 and precursors of secondary PM 2.5 emissions, namely NOx and SO 2

. The 200 7 base year inventory included emissions from point, non

- point, on

- road mobile and non

- road mobile emissions. It was picked as the base year for the daily redesignation request and maintenance plan because it reflects one of the years in whi ch Delaware was desi gnated nonattainment (e.g.,

2006

- 2008 ).

The 2007 inventory was developed through the MARAMA regional planning process. Documentation of how the 2007 attainment year was developed can be found in Technical Support Document for the Dev elopment of the 2007 Emission Inventory for Regional Air Quality Modeling in the Northeast / Mid

- A tlantic Region Version 3.3 January 23, 2012 . The MARAMA 2007 TSD includes annual emissions for carbon monoxide (CO), ammonia (NH3), oxides of nitrogen (NOx), particulate matter (PM), sulfur dioxide (SO 2 ), and volatile organic compounds (VOC). The PM species in th e inventory are categorized as: filterable and condensable particles with an aerodynamic diameter less than or equal to a nominal 10 and 2.5 micromet ers (i.e.,

PM10

- PRI and PM25

- PRI); filterable particles with an aerodynamic diameter less than or equal to a nominal 10 and 2.5 micrometers (i.e., PM10

- FIL and PM25

- FIL); and condensable particles (PM

- CON). Note that PM10

- PRI equals the sum of PM10

- FIL an d PM

- CON, and PM25

- PRI equals the sum of PM25

- FIL and PM

- CON.

The Philadelphia NAA first came into attainment for the 2006 daily PM 2.5 NAAQS based

on 2008

- 20 10 data. Delaware is using 2008 as the attainment year (e.g., one of the three years during which the area attained the standard as the attainment year inventory), from which future inventories are projected in the maintenance plan. Documentation of how the 2008 attainment year was dev eloped can be found in the 2008 Attainment Year State Implementation Plan Emissions Inventory f

or PM 2.5 , SO 2 , a nd N

O

x .Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

28 T a ble 4

- 3 s u mm ar i z e s 200 7 and 2008 e missio n s b y m a jor sou r c e ca t e g or y a nd b y pollut a nt f

or New Castle County , as well as the change in terms of tons per year (tpy) and percent decrease/increase

.

T a b le 4

- 3 New Castle County 200 7

- 2008 E m issio n Changes

Source

Sector NOx PM 2.5 SO 2

2007 2008 Δ

(tpy) Δ (%) 2007 2008 Δ

(tpy) Δ (% ) 2007 2008 Δ (tpy) Δ (% )

Point 6,635 5,589 1,046 16% 1,335 1,109 226 17% 13,380 10,576 2,805 21%

Non

- point 1,293 1,287 6 0% 1,207 1,191 16 1% 630 402 228 36%

On

- road 10,577 9,311 1,266 12% 324 283 42 13% 100 94 6 6 %

Non

- road 4,580 4,317 263 6% 327 312 15 5% 1,118 1,067 51 5%

All Sectors 23,084 20,504 2,580 11% 3,193 2, 894 300 9% 15,228 12, 139 3, 089 20%

By c omp ar ing the 2007 and 2008 inventories, we see that tot a l di rec t PM 2.5 em issions

w e r e re d u ce d b y 300 tons p e r y ea r, and that NOx e missions d e cr e a s e d b y 2,580 tons p e r y ea r

. Th e se re du c tions w er e p r im ar i l y fr om on

- road and non

- r o a d mobile sou rce s.

4.3 Enforceable and Permanent PM 2.5 , NOx and SO 2 Measures that Contributed to Improved Air Quality between 2007 and 200 8

4.3.1 Delaware

- specific Control Measures

 7 DE Admin. Code 1144, Control of Stationary Generator Emissions, SO 2 , PM, VOC and

NO X emission control, Stat e

- wide, Effective January 2006; EPA SIP approval date 08/11/2010 (75 FR 48566).

 7 DE Admin. Code 1148, Control of Stationary Combustion Turbine Electric Generating Unit Emissions, NO X emissio n control, State

- wide, Effective July , 2007. This regulation was approved into the Delaware SIP by EPA on 08/11/2010. (75 FR 48566).

 7 DE Admin. Code 1142, Section 1, Control of NO X Emissions from Industrial Boilers,

NO X emission control, Effective Dece mber 2001. This regulation was approved into the Delaware SIP by EPA on 11/22/01 (67 FR 70315) Section 2, Control of NO X Emissions from Industrial Boilers and Process Heaters at Petroleum Refineries, NO X emission control, New Castle County, Effective July 2007. This regulation was revised and approved into the Delaware SIP by EPA on 5/15/12 (77 FR 28489).

 7 DE Admin

. Code 1131

- Low Enhanced Inspection and Maintenance. Delaware’s enhanced I/M program was approved into the Delaware SIP by EPA on September 30, 1999 (64 FR 52657 ). Revisions to the enhanced I/M program were approved by EPA on 11/26/2003 (68 FR 228).Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

29 4.3.2 Federal Control Measures

Area Sources

EPA ’s New Source Performance Standards for Woodstoves (NSPS). These standards are

codifi ed at 40 CFR P art 60, subpart AAA. The final standards were promulgated in 1988 (53 FR 5860). The rule requires manufacturers of new residential wood heaters (e.g., wood stoves) to design heaters to meet particulate emission (PM) limits, have representat ive model lines tested by EPA

- accredited labs, and attach EPA labels and hangtags after EPA approval

.

Control Programs Included in the NMIM/NONROAD Model

Under 40 CFR Part 89, EPA adopted standards for emissions of NO X , hydrocarbons (HC) , and carbon monoxide (CO) from several groups of nonroad engines, including industrial spark

- ignition engines and recreational nonroad vehicles. Industrial spark

- ignition engines power commercial and industrial applications and include forklifts, electric generators, airport baggage transport vehicles, and a variety of farm and construction applications. Nonroad recreational vehicles include snowmobiles, off

- highway motorcycles, and all

- terrain vehicles. These rules were initially effective in 2004 and will be fully phased in by 2012.

Control of Air Pollution; Determination of Significance for Nonroad Sources and Emission Standards for New Nonroad Compression Ignition Engines at or Above 37 Kilowatts
59 FR 31036, June 17, 1994. This rule establishes Tier 1 exhaust emission standards for HC, NOx, CO, and PM for nonroad compression

- ignition (CI) engines ≥37kW (≥50hp). Marine engines are not included in this rule. The start dates and pollutants affected vary by hp category

as follows:

 50

- 100 hp: Tier 1,1998; NOx on ly

 100

- 175 hp: Tier 1, 1997; NOx only

 175

- 750 hp: Tier 1, 1996; HC, CO, NOx, PM

 >750 hp: Tier 1, 2000; HC, CO, NOx, PM

Emissions for New Non

- road Spark

- Ignition Engines At or Below 19 Kilowatts; Final

Rule 60 FR 34581. July 3, 1995. This rule establishes Phase 1 exhaust emission standards for HC, NOx, and CO for nonroad spark

- ignition engines ≤19kW (≤25hp). This rule includes both handheld (HH) and non

- handheld (NHH) engines. The Phase 1 standards bec a me effective in

1997 for:

 Class I NHH engines (<2 25cc),

 Class II NHH engines (≥225cc),

 Cla ss III HH engines (<20cc), and

 Class IV HH engines (≥20cc and <50cc).

The Phase 1 standards become effective in 1998 for: Class V HH engines (≥50cc)

.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

30 Final Rule for New Gasoline Spark

- Ignition Marine Engines; Exemptions for New Nonroad Compression

- Ignition Engines at or Above 37 Kilowatts and New Nonroad Spark

Ignition Engines at or Below 19 Kilowatts 61 FR 52088. October 4, 1996. This rule establishes exhaust emission standards for HC+NOx for personal watercraft and outboard (PWC/OB)

marine spark

- ignited ( SI ) engines. The standards are phased in from 1998

- 2006.

Control of Emissions of Air Pollution from Nonroad Diesel Engines 63 FR 56967 October 23, 1998. This final rule sets Tier 1 standards for engines under 50 hp, phasing in from

1999 to 2000. The rule also phases in more stringent Tier 2 standards for all engine sizes from 2001 to 2006, and yet more stringent Tier 3 stand ards for engines rated over 50 hp from 2006 to

2008. The Tier 2 and Tier 3 standards apply to NMHC+NOx, CO, and PM. The start dates by hp category and tier are as follows:

 hp: < 8kW and 8

- 19kW : Tier 1, 2000; Tier 2, 2005; no Tier 3

 19

- 37kW : Tier 1, 19 99; Tier 2, 2004; no Tier 3

 37

- 75kW : Tier 2, 2004; Tier 3, 2008

 75

- 130kW : Tier 2, 2003; Tier 3, 2007

 130

- 225kW : Tier 2, 2003; Tier 3, 2006

 225

- 450kW : Tier 2, 2001, Tier 3, 2006

 450

- 560kW : Tier 2, 2002; Tier 3, 2006

 > 560kW : Tier 2, 2006, no Tier 3

Th is rule does not apply to marine diesel engines above 50 hp.

Phase 2: Emission Standards for New Nonroad Non

- handheld Spark Ignition Engines At

or Below 19 Kilowatts 64 FR 15207. March 30, 1999. This rule establishes Phase 2 exhaust

emission standards for HC+NOx for nonroad non

- handheld (NHH) spark

- ignition engines ≤19kW (≤25hp). The Phase 2 standards for Class I NHH engines (<225cc) become effective on August 1, 200 7 (or August 1, 2003 for any engine initially produced on or after that date). The Phase 2 standards for Class II NHH engines (≥225cc) were phased in from 2001

- 2005.

Phase 2: Emission Standards for New Nonroad Spark

- Ignition Handheld Engines At or

Below 19 Kilowatts and Minor Amendments to Emission Requirements Applicable to Small Spark

- Ignition Engines and Marine Spark

- Ignition Engines ; Final Rule 65 FR 24268 April 25,

2000. This rule establishes Phase 2 exhaust emission standards for HC+NOx for nonroad handheld (HH) spark

- ignition engines ≤19kW (≤25hp). The Phase 2 standards were phased in

from 2002

- 2005 for Class III and Class IV engines and were phased in from 2004

- 2007 for Class V engines.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

31 Control of Emissions From Nonroad Large Spark

- Ignition Engines and Recreational Engines (Marine and Land

- Based ); Final Rule 67 FR 68241. November 8, 2002. This rule establishes exhaust and evaporative standards for several nonroad categories:

1) Two tiers of emission standards are established for large spa rk

- ignition engines over 19

kW. Tier 1 includes exhaust standards for HC+NOx and CO and was phased in from

2004

- 2006. Tier 2 bec a me effective in 2007 and includes exhaust standards for HC+NOx and CO as well as evaporative controls affecting fuel line per meation, diurnal emissions and running loss emissions.

2) Exhaust and evaporative emission standards are established for recreational vehicles, which include snowmobiles, off

- highway motorcycles, and all

- terrain vehicles (ATVs). For snowmobiles, HC and C O exhaust standards are phased

- in from 2006

- 2012. For off

highway motorcycles, HC+NOx and CO exhaust emission standards are phased in from

2006

- 2007. For ATVs, HC+NOx and CO exhaust emission standards are phased in from

2006

- 2007. Evaporative emission s tandards for fuel tank and hose permeation apply to all recreational vehicles beginning in 2008.

3) Exhaust emission standards for HC+NOx, CO, and PM for recreational marine diesel engines over 50 hp begin in 2006

- 2009, depending on the engine displacemen t. These are “Tier 2” equivalent standards.

Control of Emissions of Air Pollution from Nonroad Diesel Engines and Fuel; Final Rule (Clean Air Nonroad Diesel Rule

– Tier 4) 69 FR 38958

, June 29, 2004. This final rule sets Tier 4

exhaust standards for CI e ngines covering all hp categories (except marine and locomotives), and also regulates nonroad diesel fuel sulfur content.

1) The Tier 4 start dates and pollutants affected vary by hp and tier as follows:

Rated Power First Year that

Standards Apply PM

(g/hp

- hr) NOx

(g/hp

- hr)

hp < 25 2008 0.30

-

25 ≤ hp < 75 2013 0.02 3.5*

75 ≤ hp < 175 2012

- 2013 0.01 0.30

175 ≤ hp < 750 2011

- 2013 0.01 0.30

hp ≥ 750 2011

- 2014

2015 0.075

0.02/0.03** 2.6/0.50†

0.50††

* The 3.5 g/hp

- hr standard includes both NOx and nonmethane hydrocarbons. † The 0.50 g/hp

- hr standard applies to gensets over 1200 hp.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

32 ** The 0.02 g/hp

- hr standard applies to gensets; the 0.03 g/hp

- hr standard applies to other engines. †† Applies to all gensets only.

2) This rule will reduce nonroad diesel fuel sulfur levels in two steps. First, starting in 2007, fuel sulfur levels in nonroad diesel fuel will be limited to a maximum of 500 ppm, the same as for current highway diesel fuel. Second, starti ng in 2010, fuel sulfur levels in most nonroad diesel fuel will be reduced to 15 ppm.

Control of Emissions from Nonroad Spark

- Ignition Engines and Equipment; Final Rule (Bond Rule)

, 73 FR 59034 October 8, 2008. This rule establishes exhaust and evaporati ve standards for small SI engines and marine SI engines:

1) Phase 3 HC+NOx exhaust emission standards are established for Class I NHH engines starting in 2012 and for Class II NHH engines starting in 2011. There are no new exhaust emission standards for handheld engines. New evaporative standards are adopted for

both handheld and non

- handheld equipment. The new evaporative standards control fuel tank permeation, fuel hose permeation, and diffusion losses. The evaporative standards begin in 2012 for Class I NHH engines and 2011 for Class II NHH engines. For

hand held engines, the evaporative standards are phased

- in from 2012

- 2016.

2) More stringent HC+NOx and CO standards are established for marine SI PWC/OB engines beginning in 2010. In addition, new exhaust HC+NOx and CO standards are

established for stern

- dri ve and inboard (SD/I) marine SI engines also beginning in 2010. High performance SD/I engines are subject to separate HC+NOx and CO exhaust

standards that are phased

- in from 2010

- 2011.

On

- Road Emissions Programs

In the 2007 heavy

- duty highway rule, which is codified in 40 CFR Part 86, Subpart P,

EPA set a PM emission standard for new heavy

- duty engines of 0.01 grams per brake horsepower

- hour (g/bhp

- hr). This standard took full effect for diesel engines in the 200 7 model

year. This rule included standards for NO X and non

- methane hydrocarbons (NMHC) of 0.20 g/bhp

- hr and 0.14 g/bhp

- hr, respectively. These diesel engine NO X and NMHC standards were successfully phased in together between 2007 and 2010. The rule also required that sulfur in diesel fuel be reduced to facilitate the use of modern pollution control technology on these trucks

and buses. EPA required a 97% reduction in the sulfur content of highway diesel fuel

-- from levels of 500 parts per million (ppm) for low sulfur diesel to 15 ppm for ultra

- low sulfur diesel. The reductions in sulfur content engendered similar reductions in SO 2 emissions. These requirements were successfully implemented on the timeline in the regulation.

Federal Tier 1 New Vehicle Emission and New Federal Evaporative Emission Standards: Under CAA Section 202, EPA established federal motor vehicle emission standards (Tier I standards), which were phased in beginning with model year 1994. The benefits of this program

are reflected in the 2007 base year inventory and the 2008 attainment year inventory. This federally implemented program affects light duty vehicles and light duty trucks. The regulationsDelaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

33 require more stringent exhaust emission standards as well as a uniform level of evaporative

emission controls.

The Tier 2 vehicle and gasoline sulfur program, as codified in Subpart H of 40 CFR Part 80, 40 CFR Part 85, and 40 CFR Part 86, became effective in the 2005 model year. This program for fleet averaging of on

- road vehicles i s modeled after the California LEV II

standards. The Tier 2 program allows manufacturers to produce vehicles with emissions ranging from relatively dirty to very clean, but the mix of vehicles a manufacturer sells each year must have average NO X emissions below a specified value. Mobile emissions continue to benefit from this program as motorists replace older, more polluting vehicles, with cleaner vehicles.

Delaware participated in the Ozone Transport Commission (OTC) National Low Emission Vehicle Prog ram: Under the OTC National Low Emission Vehicle (NLEV) program, automobile manufacturers agreed to comply with tailpipe standards that were more stringent than

EPA could mandate prior to model year 2004. For the OTC states, starting with the model year

1 999 all new vehicles sold in the region must comply with the more stringent LEV standards. Once manufacturers committed to the program, the standards became enforceable in the same manner in which other federal motor vehicle emission control requirements w ere enforceable. The program was in place nationwide for model year 2001, and the benefits of this program are reflected in the 2007 base year inventory and the 2008 attainment year inventory.

In addition to the federal Tier 1 and 2 program s , NLEV, and t he federal 2007 heavy duty highway rule, Delaware has instituted enhanced vehicle emissions inspection and maintenance (DE Admin Code 1131

- Low Enhanced Inspection and Maintenance) requirements in New Castle County and Kent County. The requirements involve mandating regional vehicle emission I/M programs that are stricter than basic programs, as required under Section182 and 202 of the

CAA. Before 1994, basic automobile emissions testing checked only tailpipe emissions while idling and sometimes at 2,500 r pm. For Delaware, the Low Enhanced I/M procedures include the use of On Board Diagnostic (OBD) system evaluations, fuel system pressure test and a gas cap test. The procedures also include anti

- tampering inspections of the catalytic converter, gas cap

and fuel inlet restrictor. The OBD evaluations provide a more complete inspection, checking for excess evaporative emissions and other issues that might affect emissions from the vehicle.

5 SIP Completeness

- Fully Approved SIP, Section 110 and Part D Requirem ents

5.1 EPA Requirements

States must provide assurances that the applicable implementation plan has been fully approved by EPA under Section 110(k) and must satisfy all requirements that apply to the area. An area cannot be redesignated if a required element of its plan is the subject of disapproval; a finding of failure to submit or to implement the SIP; or partial, conditional, or limited a pproval.

For purposes of redesignation, states must also meet all requirements of Section 110 and Part D of the CAA that were applicable prior to submittal of the complete redesignation request. The general elements required in a SIP are listed in Sect ion 110(a). These elements include procedures for air quality monitoring and modeling; criteria for establishing stationary sourceDelaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

34 controls, monitoring and reporting; implementation of permitting programs under Part C (Prevention of Significant Deteriorat ion or PSD) and Part D (New Source Review or NSR); and provisions for public involvement. Subpart 1 of Part D consists of general requirements applicable to all areas which are designated nonattainment based on a violation of the NAAQS. Subpart 4 of Part D consists of more specific requirements applicable to particulate matter (specifically to address PM 10 ).

5.2 Delaware Approach

Section 110(a) of the CAA contains the general requirements for a SIP. Delaware concludes that, as EPA has stated in previous rulemaking, 10 only the section 110 and part D requirements that are linked with a particular area’s designation are the relevant measures which DAQ may consider in evaluating a redesignation request. Further, DAQ believes that the other section 110 elements that are not connected with nonattainment plan submissions and not linked with an area’s attainment status are also not applicable requirements for purposes of redesig nation. DAQ understands that a state remains subject to these requi rements after an area is redesignated to attainment.

The requirements of section 110(a)(2) are statewide requirements that are not linked to

the PM 2.5 nonattainment status of the Phi ladelphia NAA. Therefore, DAQ believes that these

SIP elements are not a pplicable requirements for purposes of review of the state’s PM 2.5 redesignation request.

5.3 Part D Plan Requirements for Nonattainment Areas

Nonattainment Areas in General

CAA Section 172(c)

– In accordance with EPA ’s applicable PM 2.5 implementation rule,

EPA ’s planned Rulemaking by December, 2012 on Philadelphia ’s Clean Data Determination will suspend the attainment demonstration, reasonably available control measures/reasonably available control technology (RACM/RACT), reasonable further progress (R FP)

, and contingency measure requirements under 172(c) related to attainment of the 2006 daily PM 2.5 NAAQS

, for so long as the area continues to attain the 2006 daily PM 2.5 NAAQS . Therefore

, EPA will not consider those SIP requirements for the purposes of redesignation. However, the base year inventory requirement under 172(c)(3) is not suspended. Delaware will meet this requirement when EPA fully approves the 2007 base year inventory submitted with this daily

PM 2.5 NAAQS redesignation and maintenance SIP. 11

10 See EPA’s proposed approval of Ohio’s redesignation request for the Ohio portion of the Huntington

- Ashland

nonat tainment area for the 1997 PM 2.5 NAAQS, (76 FR 79593)

.

11 The inventory required under CAA Section 172(c)(3) must be a comprehensive, accurate, and current inventory.
EPA stated in their October 22, 2012 comments on this Plan that Delaware has the “option” of submitting its 2008
or 2007 inventory to meet the re quirements of sections 172(c)(3). In order to maintain consistency in this Plan (i.e.
“base year” = 2007) and to avoid possible confusion, Delaware has elected to use the 2007 inventory to meet CAA
Section 172(c)(3).Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

35 CAA Section 176 (c) was established under the CAA to address conformity. C onformity plays an important role in helping states and tribal regions improve air quality in those areas that do not meet the NAAQS. Und er the separate general and transportation conformity rules, federal agencies must work with s tate, t ribal

, and local governments in nonattainment and maintenance areas to ensure that federal actions, including highway and transit projects, conform to the initiatives established in the applicable state or tribal implementation plan.

General Conformity

On November 30, 1993, EPA promulgated a set of regulations, known as the General Conformity Regulations, which apply to non

- transportation projects (i.e., projects not adding or expanding highways and transit). These regulations ensured that these types of federal actions

also co nformed to the SIPs ( 58 FR 63214 ). The purpose of the General Conformity Rule is to:

 Ensure that federal activities do not interfere with the budgets in the state implementation plans (SIPs);

 Ensure the attainment and maintenance of the national ambient air quality standards (NAAQS); and

 Ensure that actions do not cause or contribute to new violations of a NAAQS

.

General conformity must be met for any federal action, defined as an activity en gaged in by a department or agency of the federal government, or supported in any way by the federal government (including via financial assistance, licenses, permits, or approvals). The Federal Agency must make a determination that the activity conforms to the applicable State Implementation Plan before commencing the activity.

A conformity analysis must be conducted by the lead Federal Agency if a federal action would result in the generation of air emissions that would exceed conformity threshold leve ls of pollutants for which an air basin that is designated as a nonattainment or maintenance area under the NAAQS, or if emissions from the action are deemed regionally significant. A conformity analysis must demonstrate that the project emissions would c onform, and thus would not degrade air quality in the impacted air basin. Conformity can be demonstrated via emission offsets, SIP provisions, or air quality modeling. The EPA is responsible for reviewing and approving SIPs, which are prepared and submit ted to EPA by state environmental agencies.

Transportation Conformity

Transportation conformity is a provision in the CAA , which requires that a conformity demonstration be performed by either Federal Highway Administration (FHWA) or Federal

Transit Ad ministration (FTA) demonstrating that transportation

- related highway construction will not interfere with achieving NAAQS

. The concept of transportation conformity was introduced in the Clean Air Act of 1977, but the requirements became substantially more rigorous in the Amendments of 1990. The CAA and the Safe, Accountable, Flexible, Efficient Transportation Equity Act

– A L egacy for Users (SAFETEA

- LU) define the framework for effective integration of transportation and air quality planning.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

36 Transportation conformity is a process by which it is determined that on

- road mobile (highway) source emissions evaluated from the Tr ansportation Improvement Program (TIP) and/or Long Range Transportation Plan (LRTP) will not adversely impact air quality in a

determined area of nonattainment. Federal funding and approval are given to transportation

activities that are consistent with a ir quality goals.

As discussed in more detail in Section 8 of this plan

, Delaware revised its 2008 Annual

PM 2.5 Attainment Demonstration SIP in 2012

, to address the emission factor changes in the new

EPA MOVES model, and to establish new budgets for the purposes of addressing transportation conformity. D evelopment of t h e 2008 Annual PM 2.5 SIP involved the interagency consultative process between EPA

, DNREC, Delaware Department of Transportation and local transportation agencies such as the Wilmington Area Planning Council ( WILMAPCO ). WILMAPCO is the

m etropolitan p lanning o rganization for New Castle County, Delaware and Cecil County, Maryland

, and also facilitates the public participation process for stakeholders and citizens in the

State of Delaware. The 2012 SIP revision to the April 2008 PM 2.5 Attainment Demonstration SIP was a change to Delaware’s motor vehicle emissions budgets under the PM 2.5 annual NAAQS, and was submitted to EPA on May 3, 2012

. 12 However, EPA has not com pleted rulemaking on the 2008 SIP and the May 3, 2012 Revision.

Delaware’s SIP contains provisions that are consistent with the Section 176(c) conformity requirements. In Delaware’s SIP, general conformity requirements are contained in 7 DE

Admin. Code 11 35

, Conformity of General Federal Actions to the State Implementation Plans (Regulation for General Conformity) which was a pproved into the Delaware SIP by EPA on 08/11/2010 ( 75 FR 48566 ) . Transportation conformity requirements are contained in 7 DE

Admin. Code 1132

, Transportation Conformity which w as approved into the Delaware SIP by

EPA on 08/11/2010

, (75 FR 48566)

.

6 Maintenance Plan

6.1 EPA Requirements

Section 107(d)(3)(E) of the CAA requires a maintenance plan to meet the requirements of Section 175(A). The maintenance plan constitutes a SIP revision and must provide for maintenance of the relevant NAAQS in the area for at least 10 years after redesign ation, including contingency measures to ensure prompt correction of any violation of the NAAQS. Section 175(A) further states that the plan shall contain such additional measures, if any, as may be necessary to ensure such maintenance. M obile vehicle em ission budgets for transportation conformity purposes are also established within the maintenance plans . States must submit a SIP revision eight years after the original redesignation request is approved to provide for maintenance of the NAAQS for an addi tional 10 years following the first 10

- year period.

12 This daily maintenance plan SIP re vision will establish motor vehicle emission budgets for NOx and primary

PM 2.5 for the interim year 2017, and the final year of the maintenance plan, which is 2025. These budgets are adopted from the 2008 PM 2.5 SIP revision, submitted to EPA in May, 2012.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

37 EPA provided guidance dated September 4, 1992 on the redesignation request and maintenance plan process in the memorandum from John Calcagni, Director, Air Quality Management Division to Regional Air Di rections entitled Procedures for Processing Requests to Redesignate Areas to Attainment (redesignation and maintenance plan guidance). Other requirements are provided in 40 CFR 51 Subpart Z, entitled Provisions for Implementation of

PM 2.5 National Ambient Air Quality Standards (PM 2.5 implementation rule). Additional guidance was received from EPA regional staff in the development of this maintenance plan through participation in the Mid

- Atlantic Regional Air Management Association (MARAMA)

PM 2.5 workgroup, emails and conference calls, as well as reviewing and providing comments on

several t echnical s upport d ocuments developed through the regional modeling efforts.

EPA requires the following provisions to ensure maintenance of the NAAQS:

 The sta te must develop an attainment emissions inventory to identify the level of emissions in the area which is sufficient to attain the NAAQS.

 A state may generally demonstrate maintenance by showing that future emissions of a pollutant or its precursors will not exceed the level of the attainment inventory over the

10

- year period following redesignation.

 Once an area has been redesignated, the state must continue to operate an appropriate air quality monitoring network in order to verify the area's attainment status.

 The state must ensure that it has the legal authority to implement and enforce all measures necessary to attain and maintain the NAAQS. Continued attainment must be verified by the state by indicating how maintenance plan progress will be tracke d.

 Contingency measures must be available to promptly correct any NAAQS violation. At a minimum, the contingency measures must include a requirement that the state will implement all measures contained in the nonattainment SIP prior to redesignation.

6.2 Delaware Approach

The State of Delaware has developed this maintenance plan which meets all of EPA requirements and demonstrates that because of permanent and enforceable measures, emissions

will remain below the 2008 attainment year levels over the 10 ye ars following redesignation approval will while allowing for growth in population and vehicle miles traveled. The period

covered by this maintenance plan is 2008 through 2025 , with an interim year of 2017

.

Delaware has developed an emissions inventory in accordance with EPA guidance that

identifies the level of emissions sufficient to achieve the 2006 PM 2.5 NAAQS. This attainment inventory consists of the actual 200 8 emissions ( i.e.

, a year during the three

- year period

associated with the 2008

- 2010 monitoring data showing attainment of the 2006 PM 2.5 NAAQS )

. The plan includes a demonstration that emissions will remain beneath the 200 8 levels for a 10

- year period following redesignation, by keeping in place all elements of the current federal and

sta te regulatory programs and putting in place additional controls.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

38 As discussed in Section 3.5.1 , t he State of Delaware will continue to operate and maintain its air quality monitoring network. D elaware has the legal authority to implement and enforce sp ecified measures necessary to attain and maintain the NAAQS.

In addition to maintaining key elements of its regulatory program, the State of Delaware will acquire air quality monitoring and source emissions data to track attainment and

maintenance. The m aintenance plan includes contingency measures, as necessary, to promptly correct any NAAQS violation that occurs after redesignation of the area.

The following sections provide detail on each of the above requirements, and the State of

Delaware approach to meeting each requirement.

7 Attainment Inventory

7.1 EPA Requirements

The State of Delaware must develop an attainment year emissions inventory to identify the level of emissions sufficient to achieve the NAAQS. This inventory should be consistent with

E PA 's most recent guidance on emission inventories for nonattainment areas available at the time, and should include emissions during the time period associated with the monitoring data showing attainment of the 2006 PM 2.5 NAAQS. Where a state has made an adequate demonstration that air quality has improved as a result of the ir State Implementation Plan ( SIP )

, the attainment inventory will generally be the actual inventory during the time period the area

attained the standard. The inventory should be based on emissions of SO 2 , NO X , and primary

PM 2.5 in units of tons per year (tpy) during the attainment year.

In March, 2012 EPA released guidance addressing Implementation of the 2006 24

- hr PM2.5 NAAQS. 13 The guidance states:

“Statewide annual em ission inventories are required under 40 CFR Part 51, Subpart A. [ EPA ] expect that for many nonattainment areas, these annual inventories will serve as an appropriate starting point for the emissions inventories used for SIP development. In

contrast with the 1997 annual PM 2. 5 NAAQS, where states rely only on annual inventories in the implementation process, the 2006 24

- hour PM 2. 5 NAAQS is designed to protect against peak exposures. Thus, for the 2006 24

- hour PM 2.5 NAAQS, there are some

circumstances in whi ch the EPA believes that seasonal inventories may be useful for SIP planning purposes. For example, we have observed that in some nonattainment areas, all of the highes t fine particle concentrations over the course of a year occur in one season. If

exceed ances occur during only one season for each of the years on which the nonattainment designation is based, and this is the case for all subsequent years, [ EPA ] recommends that states develop a seasonal inventory and that they use this inventory for SIP plan ning purposes.... [ EPA ] also observed that some areas in the northern states

13 Memorandum from Stephen Page, OAQPS to Regional Air Directors entitled

, Implementation Guidance for the

2006 24

- Hour Fine Particulate National Ambient Air Quality Standard (NAAQS )

.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

39 have elevated ammonium nitrate levels in the winter, as nitrate remains in particle form and does not volatilize at lower temperatures.

7.2 Delaware Approach

Seasonal Versus Annual Inventories

The State of Delaware developed an attainment year emissions inventory that identifies the

level of emissions sufficient to achieve the 2006 daily PM 2.5 NAAQS. The attainment inventory

consists of actual emissions for a year during the three

- year period associated with the monitoring data showing attainment of the PM 2.5 standard, that is, 2008 for the daily NAAQS maintenance plan . The 200 8 inventory is appropriate to use because it represents the typical inventory for th e first three

- year period demonstrating attainment of the standard (2008

- 2010).

The 2008 inventory is consistent with EPA inventory guidance; is based on annual emissions of

SO 2 , NO X , and primary PM 2.5 during 200 8 ; and contains a list of sources and emiss ions in tpy.

The following analysis describes Delaware’s rationale for using annual emissions instead of daily emissions

.

Analysis of Top 10 Days per Year

- Seasonal Percentages

States and the City of Philadelphia in the Philadelphia NAA were asked by the

MA RAMA PM 2.5 redesignatio ns workgroup to provide the t op 10 percent of values for each monitor. Specifically, the following monitor attributes were requested of each State/City (via spreadsheet template): Year, Season, Month, Date, Rank and Sample Value.

Data Completeness & Consistency

For the Gibbstown, NJ monitor, 2006 data was not included in the analysis since only January through March readings were recorded for that year. The Camden, NJ monitor for 2008 has no readings after 9/19/2008. In reviewing the data from the other monitors in the NAA area for the time period in 2008 that Camden had no readings, there is only one reading (24.4 μg/m 3
at Bristol, PA) that makes the top 10. Based on data from the other monitors, we did not see a

l oss of data that would affect the seasonality analysis, so we included Camden’s 2008 data. The Camden monitor did not operate in 2009 or 2010, so data from Camden biases the earlier evaluation years.

The City of Philadelphia has several monitors that di d not operate throughout the 2006

- 2010 timeframe. Elmwood Avenue (ELM

- FD) did not operate in 2008, 2009 and 2010. FAB

- F did not operate during 2006 and 2007. Normalizing the dataset due to lack of data for those years was not taken into account for thi s analysis due to time constraints. Furthermore, for purposes of this assessment on whether to use summer or winter, or neither ; it was decided that because fourteen of the seventeen monitors operated continuously, their large dataset provides enough info rmation to make a good decision.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

40 Regional Consistency

Table 7

- 1 shows the total number of exceedances between 2006 and 2010, and the number of times four or more monitors in the Philadelphia NAA exceeded the standard on the same day (if we looked at two or more monitors, the percent of dates would rise to 82%). There is good consistency between monitors, including across states, for many of the high reading episodes, in the summer and the other seasons because in 73% of the exceedances, four or more monitors exceeded the same day

.

Table 7

- 1 Summer vs. Winter

– Reg ional Consistency

Date # of Monitors Exceeding NAAQS

8/7/2007 14

7/29/2008 11

6/19/2006 10

12/30/2010 9

11/28/2006 8

8/3/2006 8

1/19/2009 8

6/7/2008 7

1/29/2008 6

3/15/2009 6

7/12/2006 5

6/26/2007 5

8/8/2007 5

7/18/2008 5

7/11/2006 4

8/6/2007 4

11/9/2009 4

7/10/2007 4

7/9/2007 4

Sum 127

Total Exceed 173

% of dates more than 4 monitors exceeded NAAQS 73%Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

41 The next step was to tabulate a summary table of all monitors in the NAA for a given time period (ex. 2006

- 2010), and average the percentage per season of the top 10 values. Table

7

- 2 provides percentages by season

. It is evident from looking at Table 7

- 2 both su mmer and

winter are dominant seasons for PM 2.5

.

Table 7

- 2 2006

- 2010 Seasonal PM 2.5 Average Percentages

Season Philadelphia NAA Average

2006

- 2010

Summer 43%

Fall 9%

Winter 38%

Spring 10%

Analysis of Top 10 Days per Year

– Number of Exceedances

As the previous section showed, the top 10 monitored values were dominant during summer and winter, based on percentages. However, the percentages included many values

below the standard. With this in mind, AQM analyze d the data based on the number of exceedance readings to see if the summer vs. winter relationships would change. DAQ assessed rolling three

- year exceedances for 2006

- 2008, 2007

- 2009, 2008

- 2010 and finally all years (2006

- 2010).

When looking at the win ter to summer relationships over the course of the years 2006 to 2008, summer exceedances dominate (79% summer: 11% winter), but becomes more in line with winter when looking at 2008

- 2010 data (42% summer: 41% winter). Figure 7

- 1 illustrates the

winter v s. summer relationship over time (fall and spring are relatively insignificant and removed for contrast purposes).Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

42 Figure 7

- 1 Number of Winter vs. Summer Exceedances

In summary, exceedances of the daily PM 2.5 standard can and do occur in all four seasons of the year, with the summer and winter seasons dominating. Therefore, Delaware believes an

annual inventory of emissions for the 2008 attainment year a nd future years adequately addresses emissions of PM2.5 and its precursors for purposes of maintaining the daily PM2.5 NAAQS. In support of this determination, PM control measures implemented by Delaware are effective throughout the calendar year.

7.3 2008 Att a inm e nt Y ea r I nv e nt or y

The Del aware DAQ p r e p are d a c omp re h e nsive e missions inv e nto r y f or New Castle County (which represents Delaware’s portion of t h e Philadelphia NAA ) , in c luding point, ar e a ,

a n d on

- r o a d a nd o ff

- r o a d m obile sou rce s f

or p r im a r y PM 2.5 a s w e ll a s p rec u r s o r s of PM 2.5 ( NOx

a nd S O 2 ) f

or the y e a r 200 8

. EPA guidance requires the “a tt a inm e nt y e a r ” fall within t h e 3

- y ea r

p e r iod ( 200 8

- 2010 ) whi c h d e monst ra t e s mo n ito re d a tt a inm e nt

.

This inv e nto r y is b a s e d on a c tu a l ac t i vi t y l e v e ls and was developed in

- house by the Delaware DAQ Inventory Group

. P oint sou rc e in f o r m a tion w a s collected from Delaware industrial, commercial and institutional sources. Non

- point (a re a ) sou r c e e missions w er e

ca l c ul a t e d using t h e most rece nt l y a v a il a ble m e th o dolo g i e s a nd e missions fac to r s fr om EPA

a l o ng with ac tivi t y d a ta ( t y pi ca l l y p opul a tion, e mpl o y m e nt, f u e l us e , e t c .) s p ec i f

ic to 2 00 8 . On

r o a d mobile sou rc e e missions w er e ca l c ul a t e d using EPA ’ s Motor Vehicle Emission Simulator ( MOVES ) mod e l with 200 8 v e hi c le mil e s t ra v e l e d ( VMT) d a t a p r o v id e d b y the Delaware

D e p a r tm e nt of T ra nspo r t a tion ( Del D OT )

. O ff

- r o a d mobile sou r c e e x h a ust e missions, su c h a s those fr om l a wn a nd g ar d e n e quip m e nt, a g r i c ultu ra l e quipm e nt, a nd c onst r u c tion e qu i pm e nt w er e

ca l c ul a t e d f

or 2 0 0 8 using the EPA ’s NONROAD e missions mod e l. Emissions sou rce s su c h a s

2006

- 2008 2007

- 2009 2008

- 2010 2006

- 2010

Summer 106 67 33 110

Winter 15 22 32 36 0 20 40 60 80 100 120 Exceedances 

# Summer vs. WinterDelaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

43 c omm e r c i a l m ar ine v e ss e ls, aircraft and lo c o m otiv e s (MAR) are n ot modeled by NONROAD

a nd thus w er e ca l c ul a t e d s e p a r a t e l y

.

The details of the 2008 emissions inventory are presented in “ 2008 Attainment Y ear S tate

I mplementation P lan E

missions I

nventory for PM 2.5 , SO 2 , and NO

x ” provided in the supporting

documentation. T a

ble 7

- 3 summ ar i z e s the 200 8 e missions e stim a t e s f or New Castle County

.

T ab l e 7

- 3 2008 New Castle County Emissions (tpy )

2008

Sector NOx PM2.5 SO2

Point 5,589 1,109 10,576

Non

- point 1,287 1,191 402

On

- road 9,311 282 94

Non

- road 4,317 312 1,067

All Sectors 20,504 2, 894 12, 139

Note: sum of emissions may not match the total due to independent rounding

.

8 Maintenance Demonstration

8.1 EPA Requirements

The 1992 EPA Calcagni Memo 14 , entitled Procedures for Processing Requests to Redesignate Areas to Attainment , discusses how s tates may demonstrate maintenance of the NAAQS by showing that future emissions of a pollutant or its precursors will not exceed the level of the attainment inventory. The demonstration should be for a period of 10 years following the redesignation. The projected inventory should consider future growth, including population and industry. It should also be consistent with the attainment inventory, and it should document data inputs and assumptions. All elements of the demonstration should be consistent

wi th current EPA guidance. Enforceability through regulations must also be demonstrated.

The Calcagni Memo goes on to say that a ny assumptions concerning emission rates must reflect permanent, enforceable measures. States generally cannot take credit for reductions unless there are regulations in place requiring those reductions or the reductions are otherwise shown to be permanent. Therefore, states are expected to maintain the implemented control strategy despite redesignation to attainment, unless such measures are shown to be unnecessary for maintenance or are replaced with measures that achieve equivalent reductions. Emission reductions from source shutdowns can be considered permanent and enforceable to the extent

that those shutdowns have been refl ected in the SIP and all applicable permits have been modified accordingly.

14 http://www.epa.gov/ttn/oarpg/t5/memoranda/redesignmem090492.pdfDelaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

44 8.2 Delaware Approach

A M a int e n a n c e P l a n must c ont a in a d e monst ra tion th a t the l e v e l of e missions p r oj ec t e d

f or the t e n

- y e a r p er iod f

o llowing re d e si g n a tion is su ff i c i e nt to m a int a in the NAAQ S

. Because

Delaware is submit ting this Plan in 2012, and EPA has a maximum of 18 months to approve it,

the EPA approval date for redesignation is expected to be before 2015, and ten (10) years after

that is 2025. A cc o r di n g l y , the State of Delaware p r oj ec t e d 2008 PM 2.5 , NO x , a nd S O 2

e mis s ions f

or the Delaware portion of the Philadelphia NAA f or 2025 to represent the end year of the maintenance plan

. Delaware a lso p r oj ec t e d e missions to 201 7 to re p re s e nt an interim

y ea r du r i n g t h e m a int e n a n c e p er iod. E missions f or the 2017 and 2025 p r oj e c tion y e a r s a r e

c omp are d to e missions l e v e ls in 200 8 to d e t er mine if e missions ar e su ff i c i e nt to m a int a in the NAAQS du r i n g this p er iod ( i.e. they must be lower than 200 8 )

.

8.2.1 2017 and 2025 Projection Inventories

New Castle County point a nd a re a sou r c e e missions f or 2017 a nd 2025 w e r e e stim a t ed using the 200 8 attainment inv e nto r y a nd g r owth/control f a c to r s a pp r op r i a te f

or eac h sou rc e

ca t e g o r y

. DAQ adjusted the 2007 future year growth factors to a 2008 base year by using the same methodologies as those found in the Technical Support Document for the Development of the 2025 Emission Inventory for PM 2.5 Nonattainment Counties in the MANE

- VU Region, January 2012 (MARAMA 2025 TSD). For 2017 emission projections, the emission methodologies and growth factors can be found in the Technical Support Document for the Development of the 2013/2017/2020 Emission Inventories for Regional Air Quality Modeling

in the Northeast/Mid

- Atlantic Region (MARAMA 2017 TSD)

. T he follow ing Delaware

adjusted growth factor methods were applied per sector.

Commercial Marine, Aircraft and Railroad Projections

 Aircraft

o Per MARAMA 2025 TSD, airport/airplane growth factors are based upon 2009 FAA Terminal Area Forecast (TAF) data.

o The 2009 FAA TAF data is sorted for New Castle County data, using the same criteria as used by MARAMA.

o Growth factors for 2017 and 2025 were calculated by dividing the projection year flight data by 2008 base year data.

 Rail & Commercial Marine

o Per MARAMA TSD, rail and marine growth factors are based upon Table 7 “Transportation Sector Key Indicators and Delivered Energy Consumption” of the AEO 2010 data for energy consumption.

o Growth factors for 2017 and 2025 were calculated by dividing the projection

year ener gy use data by 2008 base year data.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

45 EGU Projections

o Per MARAMA TSD, EGU growth factors are based upon 2011 AEO electricity generation data, by various regions.

o For Delaware, it was determined that the best data to use was from the Reliability Firs t Corporation / East (RFCE) region.

o Growth factors for 2017 and 2025 were calculated by dividing the amount of electricity generated in the projection years by 2008 base year data.

Non

- EGU Projections

o Non

- EGU growth factors are based solely on Delaware e mployment data.

o The Delaware Department of Labor provided employment data, by NAICS from 2007 through 2018.

o Following guidance by the MARAMA TSD, Delaware employment data was calculated for 2019 through 2025.

o Growth factors for 2017 and 2025 were calculate d by dividing the number of employees, by NAICS, in the projection years by 2008 base year data.

Area Projections

 If original growth factors for projecting 2007 emissions to 2017 and 2025 are 1.0, the growth factors for projecting 2008 emissions are kep t as 1.0.

o Fuel Combustion

 Per MARAMA TSD, growth factors for area source fuel combustion categories are based upon 2010 AEO energy consumption data, by various regions.

 For Delaware it was determined that the best data to use was for the

South Atlantic Region.

 Growth factors for 2017 and 2025 were calculated by dividing the energy consumption in the projection years by the 2008 base year data.

 Industrial Fuel Combustion

– Natural Gas

 Per MARAMA TSD, one exemption to using 2010 AEO energy consumption data was when there was a difference of greater than 1% between the energy consumption data of 2010

and 2011.

 Since there was such a difference in the natural gas consumption data for natural gas in 2011, the 2011 AEO data

was determined to be the best data fo r Delaware for Industrial Fuel Combustion of natural gas.

 Growth factors for 2017 and 2025 were calculated by dividing the energy consumption in the projection years by the 2008 base year data.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

46  Residential Wood Combustion

o Per MARAMA TSD, residential wood combustion growth factors are based

upon EPA emission projection parameters.

o Growth factors for 2017 and 2025 were calculated by inserting the appropriate base year (BYR) and future (i.e., projection ) year (FYR) into the EPA developed equations of (Formula =1 + 0.01*( FYR

- BYR )), (Formula=1

- 0.02*( FYR

- BYR )), or (Formula=1 + 0.02*( FYR

- BYR )), depending on the equipment type.

 Residential Fuel Combustion

– Kerosene

o Per MARAMA TSD, growth factors for residential fuel combustion equipment using kerose ne are based upon 2010 AEO energy consumption data, by various regions.

o For Delaware it was determined that the best data to use was for the South Atlantic Region.

o Growth factors for 2017 and 2025 were calculated by dividing the energy consumption in the projection years by the 2008 base year data.

 Paved Roads

o Per MARAMA 2025 TSD, growth factors for paved roads are based upon county specific VMT used in MOVES.

o Growth factors for 2017 and 2025 were calculated by dividing the VMT of the projection years by the VMT of the 2008 base year.

 Commercial Cooking

o The Delaware Department of Labor provided employment data, by NAICS from 2007 through 2018.

o Following guidance by the MARAMA 2025 TSD, Delaware employment data was calculated for 2019 through 2025.

o Growt h factors for 2017 and 2025 were calculated by dividing the number of employees, by NAICS, in the projection years by 2008 base year data.

 Construction

o The Delaware Department of Labor provided employment data, by NAICS from 2007 through 2018.

o Following guidance by the MARAMA TSD, Delaware employment data was calculated for 2019 through 2025.

o Growth factors for 2017 and 2025 were calculated by dividing the number of employees, by NAICS, in the projection years by 2008 base year data.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

47 NMIM/NONROAD Growth a nd Control Information

In estimating future year emissions, the EPA NMIM/ NONROAD model includes growth and scrappage rates for equipment in addition to a variety of control programs. It is not possible to separate out the future year emissions due to “growth only” or “control only” in a single run. That is, the model run provides a single future year estimate that is a “growth and control”

scenario.

The growth data used in the NMIM/NONROAD model is documented in a n EPA
report

. 15 The GROWTH packet of the NONROAD model cross

- references each SCC to a growth indicator code. The indicator is an arbitrary code that identifies an actual predicted value such as human population or employment that is used to estimate the future year equ ipment population. The GROWTH packet also defines the scrappage curves used to estimate the future year model year distribution.

The NMIM/NONROAD model also accounts for all EPA emission standards for nonroad equipment. There are multiple standards tha t vary by equipment type, rated power, model year, and pollutant. A summary of the nonroad equipment emission standards can be found in Section 4.3.2, Control Programs Included in the NMIM/NONROAD Model

.

ONROAD

For mobile projections and mobile budget purposes , Delaware is using the 2012 mobile

emissions from its PM 2.5 Attainment Demonstration Revision, submitted to EPA on May 3, 2012. Delaware used 2012 mobile emissions in lieu of projected mobile emissions because:

1) They are based on the most up

- to

- date mobile source assumptions available.

2) 2012 emission budgets are 33% and 35 % less than the onroad NOx and PM 2.5 , respectively, found in the 2008 attainment year . (see table 8

- 2 and 8

- 3)

3) Additional reductions are not necessary in the context of this maintenance plan.

The 2012 emission inventory modeling of the on

- road mobile source sector was performed by WRA Associates LLP, Wilmington, Delaware, under contract to DelDOT with technical support from the Division of Air Quality (DAQ) staff. The on

- roa d mobile sources cover all highway vehicles including passenger cars, light

- duty trucks, sport utility vehicles, heavy

- duty trucks, buses, and motorcycles, which travel on Delaware’s roadways in 2012. Delaware Department of Transportation (DelDOT) staff pr ovided the vehicle miles traveled (VMT) on Delaware’s roadways. DAQ staff also evaluated all information concerning control

measures that would be effective in 2012. With the vehicle mix data and control information, the EPA’s MOVES model was used to gene rate monthly emissions for PM 2.5 , NOx and SO 2

. After QC/QA reviews and revision by DAQ staff the emission data were finalized, and

15 U.S. Environmenta l Protection Agency. Nonroad Engine Growth Estimates

, EPA

- 420/P

- 04

- 08

, April 2004.

Also available at: http://www.epa.gov/otaq/models/nonrdmdl/nonrdmdl2004/420p04008.pdfDelaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

48 included in the final inventory. The on

- road mobile source controls for New Castle County in the input files for the 2012 MO VES mod el runs include the following:

1) Low enhanced I/M program of model years 1968 through 1995

, 2) On

- Board Diagnostic checks of model years 1996 and newer

, 3) National Low Emission Vehicle program

, 4) Tier 2 emission standards/low sulfur rule , and 5) Heavy Duty Diesel Rule/low s ulfur rule.

Table 8

- 1 p r ovid e s a c o m p ar ison of e missions f or t he y e ar s 200 8 , 2017 a nd 2025. The

t a ble d e monst ra t e s th a t the l e v e l of e missions p r oj ec t e d th r o u g h the m a int e n a n c e p er iod a r e l e ss th a n e mi s sions e stim a t e d f or the a t t a inm e nt y e a r a nd are , t h eref o re , su ff i c i e nt to m a int a in

the PM 2.5 NAAQ S

. Tables 8

- 2 through 8

- 4 show NOx, PM 2.5 and SO 2 reductions (tpy)

between 200 8 and 2017 and 2025. The tables also provide the percent reduction of NOx,

PM 2.5 and SO 2 by sector for those same years. It is readily apparent from these t a bl e s that S O 2

a nd NOx e missions a r e e x p e c t e d to d ecr e a se s i g ni f i c a n t l y b e tw e en 2008 a nd 2025 ( i.e.

, 38 %

and 61 % for NOx and SO 2 , respectively )

. PM 2.5 d ecrea s es less significantly (14%)

, primarily

due to increased road dust from increased VMT

. P r oj ec t e d e missions of those pollut a nts f or the

mid

- point y e ar o f 201 7 a r e a lso significantly l e ss th a n th e ir re sp e c tive e missions l e v e ls in

200 8

. B a s e d on th e se e missions t re nds it is e x p ec t e d th a t a ir qu a li t y will c ontinue to m ee t the

PM 2.5 NAAQS th r ou g hout the m a int e n a n c e p er iod.

T a ble 8

- 1 Co m p ar ison of e missions f or t he y e ar s 2008 , 2017 a nd 2025

Sector NOx PM25 SO2

2008 2017 2025 200 8 2017 2025 2008 2017 2025

Area 1,287 1,299 1,297 1,191 1,247 1,327 402 336 286

Nonroad MAR 2,641 1,760 1,247 164 59 42 1,039 120 39

Nonroad

- NMIM 1,676 997 837 148 106 103 28 2 3

Onroad MOVES 9,311 6,273 6,273 282 199 199 94 98 98

Point

– EGU 2,185 1,629 1,707 396 410 427 7,122 2,017 2,161

Point

- nonEGU 3,404 1,724 1,421 713 504 398 3,454 2,559 2,096

All Sectors 20,504 13,682 12,782 2, 894 2,524 2,497 12, 139 5, 132 4, 683Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

49 T a ble 8

- 2 Reductions and % Change of NOx e missions f or t he y e ar s 2008 , 2017 a nd 2025

NOx Reduction (tpy) Change

(%) Reduction

(tpy) Change

(%)

Sector 2008 2017 2025 2008

- 2017 2008 to

2017 2008 to 2025 2008 to

2025

Area 1,287 1,299 1,297

- 12 0.9%

- 10 0.8%

Nonroad MAR 2,641 1,760 1,247 881

- 33.3% 1,394

- 52.8%

Nonroad

- NMIM 1,676 997 837 679

- 40.5% 840

- 50.1%

Onroad MOVES 9,311 6,273 6,273 3,038

- 32.6% 3,038

- 32.6%

Point

- EGU 2,185 1,629 1,707 556

- 25.4% 478

- 21.9%

Point

- nonEGU 3,404 1,724 1,421 1,680

- 49.4% 1,983

- 58.3%

Total tpy 20,504 13,682 12,782 6,822

- 33% 7,722

- 38%

T a ble 8

- 3 Reductions and % Change of PM 2.5 e missions f or t he y e ar s 2008 , 2017 a nd 2025

PM25 Reduction (tpy) Change

(%) Reduction

(tpy) Change

(%)

Sector 2008 2017 2025 2008

- 2017 2008 to

2017 2008 to 2025 2008 to

2025

Area 1,191 1,247 1,327

- 56 4.7%

- 136 11.4%

Nonroad MAR 164 59 42 106

- 64.3% 122

- 74.3%

Nonroad

- NMIM 148 106 103 42

- 28.6% 45

- 30.2%

Onroad MOVES 282 199 199 83

- 29. 4 % 83

- 29. 4 %

Point

- EGU 396 410 427

- 14 3.5%

- 32 8.0%

Point

- nonEGU 713 504 398 209

- 29.3% 315

- 44.1%

Total tpy 2, 894 2,524 2,497 370

- 13% 396

- 14%Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

50 T a ble 8

- 4 Reductions and % Change of SO 2 e missions f or t he y e ar s 200 8 , 2017 a nd 2025

SO2 Reduction (tpy) Change

(%) Reduction

(tpy) Change

(%)

Sector 2008 2017 2025 2008

- 2017 2008 to

2017 2008 to 2025 2008 to

2025

Area 402 336 286 66

- 16.5% 116

- 28.8%

Nonroad MAR 1,039 120 39 919

- 88.4% 1,000

- 96.2%

Nonroad

- NMIM 28 2 3 25

- 91.0% 25

- 88.4%

Onroad MOVES 94 98 98

- 3 3. 4 %

- 3 3.4 %

Point

- EGU 7,122 2,017 2,161 5,104

- 71.7% 4,960

- 69.7%

Point

- nonEGU 3,454 2,559 2,096 895

- 25.9% 1,358

- 39.3%

Total tpy 12, 139 5,132 4, 683 7,007

- 58% 7,456

- 61%

8.2.2 2017 and 2025 Mobile Source Emissions Budgets

Transportation conformity is a way to ensure that federal funding and approval are given to those transportation activities that are consistent with air quality goals. Transportation activities should not worsen air quality or interfere with an area’s con tinued compliance in regards to the 2006 PM 2.5 NAAQS. The federal transportation conformity rule is codified in 40 CFR Part 93, S ubpart A, titled Determining Conformity of Federal Actions to State or Federal Implementation Plans (transportation conformity rule). This rule applies to areas designated as nonattainment for one or more NAAQS or that have been redesignated to attainment with federally approved air quality maintenance plans. The responsible transportation planning

ent it ies for the New Castle County, Delaware po r tion of the Philadelphia 2006 PM 2.5 NAA is the Delaware Department of Transportation (DelDOT) and the Wilmington Area Planning Council (WILMAPCO). In the transportation conformity process, overall emissions est imates by analysis year that take into account future traffic activity and projects expected to be completed are compared to a base year, a no build scenario, or emission budgets. Emission budgets are

used in this maintenance plan only if EPA has approved or found adequate emissions budgets

that have been submitted as a SIP revision.

The pu r pose of this s e c tion is to d e s cr ibe a nd e s t a blish the New Castle County motor

v e hi c le e missions bud g e ts a ss o c i a t e d with t he PM 2.5 M a int e n a n c e P l a n S I P . Annu a l motor

v e hi c le e m issions bud g e ts a r e b e i n g p r opos e d f or the f in a l y e a r of the M a int e n a n c e P l a n, which

is 2025. The M a int e n a n c e P l a n a lso in c lud e s motor v e hi c le e missions budgets f or the int er im

y ea r 2017

.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

51 Delaware is proposing to establish mobile budgets for PM 2.5 and NOx. 16 Ammonia and volatile organic compounds (VOC) are precursors ; however, they are not considered significant

overall contributors to PM 2.5 air quality issues, as noted in the PM 2.5 implementation rule at 40 CFR 51.1002(c)(3). For o ther pollu tants such as SO 2 , the highway contribution to those

emissions may be insignificant. In that case, the transportation conformity rule allows such pollutants and precursors to be exempt from conformity analysis under certain circumstances:

40 CFR 93.109 ( k)

, Areas with insign ificant motor vehicle emissions

Notwithstanding the other paragraphs in this section, an area is not required to satisfy regional emissions analysis for §93.118 and/or §93.119 for a given pollutant/precursor and NAAQS, if EPA finds t hrough the adequacy or approval process that a SIP demonstrates that regional motor vehicle emissions are an insignificant contributor to the air quality problem for that pollutant/precursor and NAAQS. The SIP would have to

demonstrate that it would be unr easonable to expect that such an area would experience enough motor vehicle emissions growth in that pollutant/precursor for a NAAQS violation to occur. Such a finding would be based on a number of factors, including the percentage of motor vehicle emissio ns in the context of the total SIP inventory, the current state of air quality as determined by monitoring data for that NAAQS, the absence of SIP motor vehicle control measures, and historical trends and future projections of the grow th of motor vehicle e missions.

Delaware is herein making a finding that highway emissions of SO 2 are insignificant

contributors to the PM 2.5 air quality of the New Castle County portion of the Philadelphia NAA. This finding is due to the fact that the SO 2 emissions inventory constit utes a very small fraction (less than 1.5 percent) of the overall SO 2 in the 200 8 , 2017 and 2025 emissions inventories. The finding will become final if EPA concurs and approves this maintenance plan.

A motor v e hi c le e missi ons bud g e t is th a t po r tion of the tot a l a llow a ble e m i ssions

a llo ca t e d to h i g hw a y a nd t ra nsit v e hi c le use th a t a r e d ef i n e d in the S I

P f o r a cer t a in y ea r . The

r ul e s g ov e r

ning t r a n spo r t a tion c on f

o r mi t y re q ui r e c e r t a in t ra nspo r t a ti o n ac tiviti e s to be c onsist e nt
with motor v e hi c le e missions budg e ts c ont a in e d in c ont r ol st r a t e g y impl e m e nt a tion pl a ns ( 40

C F R § 93.118 )

. S ec tion 93.101 of the r ule d e f in e s a “c ont r ol st ra t e g y [ S t a t e ] impl e m e nt a tion pl a n re vision” a s a “ pl a

n whi c h c ont a ins s p ec i f

ic st ra t e g i e s f

or c ont r olling the e missions a nd

re du c i ng a mbi e nt l e v e ls of pollut a nts in o r d e r to s a tis f y C AA r e qui re m e nts of rea so n a ble f u r th e r

p r og re ss a nd a tt a inm e nt.” I n o r d e r to d e monst ra te c on f o r mi t y t o the motor v e hi c le e mi s sions

bud g e t, e missions f

r om the impl e m e nt a tion of a t ra n spo r t a tion pl a n or a t ra n s po r t a tion imp r ov e m e nt p r og ra m (TIP) must be l e ss th a n or e q u a l to the budg e t l e v e l ( 40 C F R § 93.118 (a))

.

Delaware ’s proposed 2012 NOx and PM 2.5 budgets in its Proposed Revision to

Delaware’s 2008 State Implementation Plan f or Attainment of the PM 2.5 Annual National

16 As discussed in Delaware’s 2008 Annual PM 2.5 Attainment Demonstration, and revised in Delaware’s Proposed Revision to Delaware’s 2008 State Implementation Plan For Attainment of the PM 2.5 Annual National Ambient Air Quality Standard

- Attainment Demonstration, submitted to EPA May 3, 2012.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

52 Ambient Air Quality Standard

- Attainment Demonstration (submitted to EPA on May 3, 2012 )

. These budgets represent a level of mobile emissions lower than what existed during the years

at tainment was reached (i.e., 2008

- 20 10 and 2009

- 2011 ). Furthermore , because of significant reductions in other source categories, mobile reductions are not necessary to demonstrate

maintenance ( i.e., the 2025 NOx PM 2.5 and SO 2 emissions are well below 200 8 levels ) , t here is no need to develop new mobile budgets as this time. 17 Therefore, Delaware proposes to use existing 2012 budgets for the 2017 interim year, as well as the end year, 2025

. 18

Table 8

- 6 summarizes the budgets for each relevant year.

Tabl e 8

- 5 New Castle County Mobile Source Emissions Budgets

Year NO X On

- Road Emissions (tpy) PM 2.5 On

- Road Emissions (tpy)

2012 Attainment SIP

Revision

– Mobile Budgets 6,273 199

2017 Interim Budget 6,273 199

2025 Final Budget 6,273 199

8.2.3 Control Measures for Maintenance of Good Air Quality

Point, area, non

- road and on

- road emission projections for 2017 and 2025 include a variety of control strategies that will reduce emissions of PM 2.5 , NO X , and SO 2 in the future years. The sections below describe the major control programs in each category. Many of these programs are federal programs that are enforced on a regional or national level. In cases where the programs are delegated programs or state pro grams, EPA has approved these programs into

the Delaware SIP. T he State of Delaware commit s to the continuation of these program s , to include compliance and enforcement mechanisms as appropriate to ensure that reductions

assumed in 2017 and 2025 will be a chieved.

Tables 8

- 2 through 8

- 4 show that that projected 2008 to 2025 reductions are 7,722 tpy for NOx, 396 tpy for PM 2.5 and 7, 456 tpy for SO 2 . In terms of percen t reductions, this equates to

38 %, 14% and 61 % reductions of NOx, PM 2.5 and SO 2 , respecti vely. The same tables show projections from 200 8 to the 2017 interim year. 200 8

- 2017 reductions are 6,822 tpy for NOx,

370 tpy for PM 2.5 and 7,007 tpy for SO 2

. In terms of percent reductions, this equates to 33 %,

13% and 58 % reductions of NOx, PM 2.5 and SO 2 , respectively.

However, not all of these reductions are due to control measures. Projected emissions can be higher or lower due to growth factors alone, or in combination with controls (assuming

17 DAQ ma y require new budgets should the Philadelphia maintenance area lapse into nonattainment

, (see Section 10)

. 18 New Castle County has been designated as nonattainment under the new ozone NAAQS. Therefore, new and stricter budgets for NOx wil l be included in the ozone attainment demonstration and/or reasonable progress SIP(s). The stricter budgets will require mobile control measures and reduced VMT. Consequently, there will be a

collateral benefit in the form of PM 2.5 reductions.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

53 controls exist for a certain source category). DAQ calculated reductions that will occur after

200 8 due only to control measures, (no growth), for EGUs, non

- EGU point sources, area and “marine, aircraft and locomotive” (MAR) sources. Because onroad and non

- MAR off

- road sources are estimated using EPA models (MOVES and NMIM), and inherently include growth in the form of fleet turnover, equipment turnover, ex. lawnmowers, etc., it is not feasible to break

out onroad and non

- MAR off

- road reductions due exclusively to controls.

Looking at Table 8

- 6 , it is evident that all but the area source sectors had significant decreases for NOx (particularly onroad), SO 2 and/or PM 2.5 due to control measures.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

54 Table 8

- 6 2008 to 2025 Emission Reductions due to Control Measures

2008

- 2025 Reductions due to controls only (no growth)

NOx PM2.5 SO2

EGUs

DE Admin Code 1146 (Multi

- Pollutant

Regulation) 953.4 3.5 5,171.1

nonEGU

Delaware City Refinery NOx CAP (1650 tpy) post

- 2015 874.7 0.0 0.0

Reciprocating Internal Combustion

Engines

- 0.0 0.1 0.0

Maximum Achievable Control Technology

(RICE MACT) (76 FR 12863)

Ch r ysler Plant Shutdown 8.4 0.7 6.0

AREA

2010 RICE MACT 42.5 0.3 0.3

EPA New Source Performance Standards for Woodstoves (NSPS).

These standards are codified at 40 CFR part 60, subpart AAA. The final standards were promulgated in 1988

(53 FR 5860). 4.9 74.1 0.8

NMIN 840 45 25

ONROAD 3,038 83

- 3

Marine Vessels, Aircraft and Locomotives (MAR)

Control of Emissions of Air Pollution From Locomotive Engines and Marine Compression

- Ignition Engines Less Than 30 Liters per Cylinder; Republication; Final Rule. (73 FR

37096) 862.3 32.9 150.1

Control of Emissions From New Marine Compression

- Ignition Engines

at or Above 30 Liters per Cylinder(75

FR 22895) 597.3 90.7 850.7

TOTALS 7, 221 330 6,200Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

55 8.2.4 Delaware

- specific NOx, PM2.5 or SO2 Control Measures (Effective Post 200 8 )

 7 DE Admin. Code 1146, EGUs, Electric Generating Unit (EGU) Multi

- Pollutant Regulation, SO 2 and NO X emission control, State

- wide, Effective December 2006 19

, approved into Delaware’s SIP August 28, 2008 ( 73 FR 50723 ) , March 16, 2010 ( 75 FR

12449 ) , and August 11, 2010 ( 75 FR 48566 )

.

 7 DE Admin. Code 1142, Section 2, Control of NO X Emissions from Industri al Boilers and Process Heaters at Petroleum Refineries, NO X emission control, New Castle County, Effective July 2007; approved into Delaware’s SIP June 4, 2010 ( 75 FR 31711 ) and August 11, 2010 ( 75 FR 48566 ) ; revisions approved May 15, 2012 ( 77 FR 28489 )

.

 7 DE Admin. Code 1148

, Control of Stationary Combustion Turbine Electric Generating

Unit Emissions , approved into Delaware’s SIP on November 10, 2008 (73 FR 66554) and August 11, 2010 ( 75 FR 48566 )

.

EGU reductions

EGUs are a subset of point source emissions and include the following New Castle County facilities:

 Conectiv Delmarva Generation

- Del City

 Conectiv Delmarva Generation

- West Substation

 Conectiv Delmarva Generation

- Edge Moor

 Conectiv Delmarva Generation

- Chr istiana

 Conectiv Delmarva Generation

- Hay Road

Edge Moor is the only New Castle EGU which burned coal and residual o il in 2008 . The

rest fired natural gas or distillate oil, and thus had insignificant PM 2.5 and SO 2 emissions in 2008 and are projected to h ave insignificant emissions in PM 2.5 and SO2 emissions in 2025. In 2008, total EGU emissions of NOx, PM 2.5 and SO 2 were 2,185 tpy, 396 tpy and 7122 tpy, respectively. Of this amount, Edge Moor’s NOx, PM 2.5 and SO 2 emissions were 1,980 tpy, 360 tpy and 7,110
tpy , respectively. Consequently, Edge Moor was the largest EGU emitter, e.g. its 2008

emissions r epresented 99 % of NOx, PM 2.5 and SO 2 , respectively for all New Castle C ounty

EGU s . Because Units 3 and 4 were coal

- fired in 2008 , and Unit 5 operates primarily on residual oil, it is subject to 7 DE Admin Code 1146, which is Delaware’s EGU Multi

- pollutant Regulation. 7 DE Admin Code 1146 is a non

- trading program/regulation that was established primarily as a measure to aid in the attainment of the ozon e and fine particulate matter ambient air quality standards. As Tables 8

- 2 through 8

- 4 show, 7 DE Admin Code 1146 will reduce

EGU emissions in 2025 by 22 % for NOx, and 70 % for SO 2 . PM 2.5 emission controls are not part

19 Although effective in 2006, NOx controls were not required until January 1, 2009 and SO 2 controls were not required until January 1, 2012

.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

56 of Regulation 1146, but there were some co

- benefits by requiring 0.5% by weight low

- sulfur

residual oil on Unit 5 , which will yield 8% reductions

. Non

- EGU reductions

Delaware Source Shutdowns (post

- 200 8 )

The Chrysler automotive plant ceased commercial operation in January, 2009. Howe ver, only a 25% reduction was applied, since Chrysler maintains 50% of the emission credits and Delaware Economic Development Office retains the remaining 25%. Reductions are shown in

Table 8

- 6

.

Delaware On

- road

In additional to the federal Tier 1 and 2 program, NLEV, and the federal 2007 heavy duty highway rule, Delaware has instituted Enhanced Vehicle Emissions Inspection And Maintenance (enhanced I/M) requirements in New Castle County. The requirements involve mandating regional vehicle emission I/M programs that are stricter than basic programs, as required under §§182 and 202 of the CAA. Before 1994, basic automobile emissions testing checked only tailpipe emissions while idling and sometimes at 2,500 rpm. Enhanced I/M procedures include the use of On Board Diagnostic (OBD) system evaluations, a wider range of vehicles tested, and may include a dynamometer (treadmill) test that checks the car’s emissions under driving

conditions. The OBD evaluations provide a more complete inspection, checking for excess evaporative emissions and other issues that might affect emissions from the vehicle. Delaware’s enhanced I/M program was approved into the Delaware SIP by EPA on September 30, 1999 (64

FR 52657 ). Revisions to the enhanced I/M program were approved by EPA on 11/26/2003 (68 FR 228).

8.2.5 Federal Control Measures ( Effective or Phased

- in Post 2008 )

Because federal control measures that are either e ffective or phased in after 2008 are the same as those discussed in Section 4.3.2, please refer to that Section. Note that the Woodstove

NSPS and m any of the non

- road and on

- road federal control measures have effec tive dates prior to, during

, or after 2008 . However, other than fuel standards; all of the measures are phased in

over many years through fleet or equipment “ turnover.” For example, i n the case of non

- road sources, fleet turnover includes sales of new engines replacing older ones over the years. Therefore, it is expected that reductions will continue well past the 200 8 attainment year.

8.2.6 Future Point Source Emissions Reductions Programs

Delaware

New Delaware regulations and federally enforceable permit changes will reduce emissions of NOx, PM 2.5 and SO 2 even further, al though these rules are not yet finalized and

therefore were not considered in the 2017 and 2025 estimates included in this document. Under development are:Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

57  Low

- sulf

ur distillate and residual fuel regulation

 Calpine

- Edge Moor Power Plant (fuel switch from coal to natural gas)

Federal

Three new federal regulations will reduce emissions of SO 2 even further , although t hese rules are not yet finalized and therefore were not considered in the 2017 and 2025 estimates

included in this do cument. If these regulations are finalized, each should instigate significant further reductions, both within and outside the Philadelphia NAA.

 Mercury and Air Toxics Rule: On March 16, 2011, EPA proposed the Mercury and Air Toxics Rule to reduce emissions of toxic air pollutants from new and existing coal and

oil

- fired EGUs. The proposed rule would establish numerical emission limits for hydrogen chloride (HCl) as a surrogate for toxic acid gase s, or alternative standards for

SO 2

. EPA estimates that this rule would affect approximately 1,200 coal

- fired units

nationwide and would reduce SO 2 emissions from power plants by 55%. The final rule is expected to be published in 2012 so that existing so urces may be required to demonstrate compliance with applicable standards by 2015. National Emission Standards for

Hazardous Air Pollutants From Coal and Oil

- Fired Electric Utility Steam Generating

Units and Standards of Performance for Fossil

- Fuel

- Fired Electric Utility, Industrial

Commercial

- Institutional, and Small Industrial

- Commercial

- Institutional Steam Generating Units, Final R ule published February 16, 2012 (77 FR 9304); Correction published April 19, 2012 (77 FR 23399)

. 20

 2010 SO 2 NAAQS: On June 2, 2010, EPA strengthened the primary NAAQS for SO 2 by revising the primary SO 2 standard to 75 ppb averaged over one hour. This short term standard is significantly more stringent than the revoked standards of 140 ppb averaged

over 24 hour s and 30 ppb averaged over a year. Under the new standard’s proposed guidance, facilities emitting more than 100 tpy of SO 2 , many of which are EGUs, will be required to demonstrate compliance with the standard no later than 2017.

 Industrial/Commercial/ Institutional (ICI) Boiler Maximum Achievable Control Technology (MACT) Standard: EPA finalized the revised ICI Boiler MACT on February 21, 2011, although portions of the rule are under reconsideration. EPA estimates that implementation of the revised ru lemaking will reduce emissions nationwide from major source boilers and process heaters by 47,000 tpy of PM, 440,000 tpy of SO 2 , and 7,000 tpy of VOCs.

 Tier 4 Standards: On May 11, 2004, the EPA signed the final rule introducing Tier 4

emission standards , which are to be phased

- in over the period of 2008

- 2015 [69 FR

38957

- 39273, 29 Jun 2004]

. The Tier 4 standards require that emissions of PM and NOx be further reduced by about 9 0%. Such emission reductions will be achieved through the

20 This rule is under reconsideration. EPA expects to complete ruling

- making in March, 2013 (July 20, 2012 letter

fr om Gina Mcarthy, EPA Admin i strator, to Patricia T. Barmeyer)

.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

58 use of control tech nologies

— including advanced exhaust gas after

- treatment.

8.2.7 Controls to Remain in Effect

Delaware will m a int a in a ll of the c ont r ol m ea s u re s list e d in this S ec tion to e n s u r e

m a int e n a n c e o f the daily PM 2.5 NAAQ S . A n y r e visions to the c ont r ol m ea su re s in c lud e d a s p ar t
of t h e M a int e n a n c e P l a n will be submitt e d a s a S I P re visi o n to EPA f

or a pp r o v a l, a nd will be

acc omp a n i e d b y a show i ng th a t su c h c h a n g e s will not int erfer e with m a int e n a n c e of t h e NAAQ S

. The Delaware DAQ h a s the n ece ss a r y re so u rce s to e n f o rc e a n y viol a tions of its r ul e s or p er

mit

p r ovisions. A f

t e r re d e s i g n a tion, it int e nds to c ontinue e n f o r c i n g a ll r ul e s th a t re l a te to the

e missions of p r im a r y PM 2.5 and p rec u r so r s to s ec ond a r y PM 2.5 which may impact New Castle County ambient PM2.5 concentrations.

Although Delaware b e li e v e s th a t c ont r ol of o r g a nic c o mpounds and ammonia m a y h e lp imp r ove P M a ir qu a li t y , we h a ve not r e li e d on the c ont r ol of o r g a n i c s or ammonia, c onsist e nt
with the PM 2.5 I

mpl e m e n t a tion R

ul e

.

9 Verify Continued Attainment

9.1 EPA Requirements

States must ensure that they have the legal authority to implement and enforce all measures necessary to attain and maintain the NAAQS. Sections 110(a)(2)(B) and (F) of the CAA suggest that one such measure is the acquisition of air quality and source emi ssion data to

demonstrate attainment and maintenance.

9.2 Delaware Approach

The State of Delaware has the legal authority to implement and enforce specified measures necessary to attain and maintain the 2006 daily PM2.5 NAAQS. Delaware concludes that, as EPA has stated in previous rulemaking, 21 only the S ection 110 and P art D requirements that are linked with a particular area’s designation are the relevant measures which Delaware

must consider in evaluating a redesignation request. Further, DAQ believe s that the other

S ection 110 elements that are not connected with nonattainment plan submissions and not linked with an area’s attainment status are also not applicable requirements for purposes of redesignation. A state remains subject to these requirement s after an area is redesignated to

attainment.

The requirements of S ection 110(a)(2) are statewide requirements that are not linked to

the PM 2.5 nonattainment status of the Philadelphia NAA. Therefore, Delaware believes that these SIP elements are not ap plicable requirements for purposes of review of the state’s PM 2.5 redesignation request.

21 See EPA’s proposed approval of Ohio’s redesignation request for the Ohio portion of the Huntington

- Ashland

nonattainment area for the 1997 PM 2.5 NAAQS. (76 FR 79593)Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

59 In addition to maintaining key elements of its regulatory program in place in Delaware’s SIP, Delaware will acquire ambient monitoring and source emission data to tr ack attainment and maintenance as described in Sections 3 and 7. Delaware will also track the progress of the maintenance demonstration by periodically updating the emissions inventory as required by the

Air Emissions Reporting Requirements Rule, or as required by federal regulation during the maintenance plan period. This includes developing annual inventories for major point sources and a comprehensive periodic inventory covering all source categories every three years. Tracking will inc lude the evaluation of annual and periodic evaluations for any significant

emission increases above the 200 8 attainment year levels.

10 Contingency Measures

10.1 EPA Requirements

S ec tion 175 ( A) of the C AA sp ec i f i e s t h e re qui r e m e nts f

or M a int e n a

n c e P l a ns, i n c luding

p r ovisions f

or c onting e n c y m e a su re s 22 th a t will be i mpl e m e nt e d if viol a tions of the 2006 daily

PM 2.5 NAAQS ar e m ea s u re d af t e r r e d e s i g n a tion to a tt a inm e nt. A list of pot e nti a l c ontin g e n c y

m ea s u re s t

h a t would be impl e m e nt e d in su c h a n e v e nt should a lso be in c lud e d in the

M a int e n a n c e P l a n. F in a l l y , the pl a n should p r ovide a c om m itm e nt to submit a re vis e d

M a int e n a n c e P l a n e i g ht y e ar s a f t e r re d e s i g n a tion to e nsu r e c ontinu e d m a int e n a n c e f or the n e x t

t e n

- y ea r m a int e n a n c e p e r iod.

C ontin g e n c y m e a su re s a r e int e nd e d to p r ovide f u r th e r e missions re du c tions in the e v e nt
th a t viol a tions of the 2006 daily PM 2.5 NAAQS o cc ur af t e r r e d e s i g n a tion to a tt a inm e nt. W hile

th e se m ea su re s do not n ee d to be f ul l y a do p t e d b y the State of Delaware p r ior to the o cc u r re n c e of N AAQS viol a tions, the c ontin g e n c y p l a n should e nsu r e th a t the c onting e n c y m ea su r e s a r e

a dopt e d e x p e ditious l y on c e th e y a r e t r i g g e r e d. The M a int e n a n c e P l a n m ust id e nti f y the t r i g g e r s th a t d e t er mine w h e n c ont i n g e n c y m ea su re s will be a dop t e d

, a nd the m ea su r e s th a t the st a te will

c onsid er

. It should also include a schedule and procedures for adoption and implementation, and a specific time limit for action. Specific triggers that would put the plan into motion must be identified. This plan is considered to be an enforceable part of the SIP and should ensure that the contingency measures are adopted explicitly once they are triggered.

10.2 Delaware Approach

C onsist e nt with this p l a n, Delaware a g r e e s to a dopt a nd impl e m e nt the n e ce ss a r y

c o rr e c tive a c tions in the e v e nt th a t viol a tions of the 2006 daily PM 2.5 NAAQS o cc ur within the Philadelphia m a int e n a n c e ar e a af t e r its r e d e s i g n a t ion to a tt a inm e nt

. 23 As d e s cr ib e d in S ec tion 5

of this re po r t, EPA and Delaware h a ve a dopt e d a nd are c ontinuing to impl e m e nt a ra n g e o f

22 CAA Section 107(d)(3)(E) (v ).

23 NJ, DE and PA are each submitting their own redesignation requests and maintenance plans. After each State’s Plans are approved by EPA, the Philadelphia NAA will be re

- defined as the Philadelphia Maintenance Area, It is also possible that a portion of the area may be redesignated to attainment (i.e., a maintenance area) and a portion may still be nonattainment. Therefore, for the purposes of this maintenance plan, the “Philadelphia Maintenance Area” also includes any areas of the Philadelphia NAA t hat have not been redesignated to attainment.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

60 c ont r ol m e a su r e s th a t will g r ea t l y re d u c e p rec u r sor e missions

- lo ca l l y, st a t e wid e and nationwide

. Delaware c ommits to c ontinue to im p l e m e nt the id e nti f i e d statewide and local c ont r ol m ea su r e s.
T he Delaware DAQ a nti c ip a t e s th a t post

- 200 8 e missions re du c tions will be su ff i c i e nt to miti g a te

e x cee d a n c e s or viol a tions of the daily PM 2.5 N AAQS th a t m a y o cc ur in the c oming y ea r s without

f u r th e r r e gul a to r y ac tion

. However, i n the event of a future violation or exceedance of the daily

PM2.5 NAAQS

, t he Delaware DAQ will use the following triggers (determination of when to start an action) and perform the following actions in accordance with the described schedule, as its contingency plan:

1. Warning Level Response (one or both of the following events occur)

a. A warn ing level response shall be prompted whenever the 98th percentile 24

- hour

PM 2.5 concentration of 35.5 μg/m 3 or greater occurs at any monitoring site in a single calendar year within the Philadelphia maintenance area.

b. The New Castle County, Delaware maintenance area total P M 2.5 , NOx and SO 2 emissions increase more than 10% above the levels in the 2008 attainment year emissions inventory.

2. Action Level Response

An action level response shall be prompted whenever a two

- year average of the 98th percenti le 24

- hour PM 2.5 concentration of 35.5 μg/m 3 or greater occurs at any monitoring within the Philadelphia maintenance area. A violation of the standard (three

- year average of the 98th percentile of 35.5 μg/m 3 or greater)

, shall also prompt an action level r esponse.

3. Study and data analysis

In order to select appropriate corrective measures for warning or action level triggers, the Delaware DAQ will work independently, or in conjunction with the States of Pennsylvania and New Jersey, and the City of Philade lphia to conduct a comprehensive study to determine the causes of the violation and the control measures necessary to mitigate the problem. This analysis may include all or some of the following factors as necessary, to determine the cause of the

exceedan ce, emissions increase or violation:

• The location and severity of the ambient PM 2.5 exceedances;

• The weather patterns contributing to the elevated PM 2.5 levels;

• Potential contributing emissions sources;

• The geographic applicability of possible contingency measures;

• Emissions trends, including timeliness of implementation of scheduled control

measures;

• Current and recently identified control technologies;

• Air quality contributions from outside the maintenance area;Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

61 • Activity data for relevant sources;

• Inform ation on any unusual events (e.g. forest fires, natural disasters), transport from out of state sources;

• Violation of an existing rule or permit, and;

• Any other related data to try to determine the cause of the violation.

The study will evaluate whether the trend, if any, is likely to continue and if so, the control measures necessary to reverse the trend taking into consideration ease and timing for implementation as well as economic and social considerations. In the event that the trigger is not

found t o be due to an exceptional event, malfunction, or noncompliance with a permit condition or rule requirement, Delaware DAQ will work with the States of Pennsylvania and New Jersey, and the City of Philadelphia as necessary, to determine additional control m easures needed to

assure future attainment of the 2006 daily

, PM 2.5 NAAQS.

Based on the results of the analysis, contingency measures will be selected from those listed below, or from any other measure deemed appropriate and effective at the time the

selection is made. However, if a new measure or control is already promulgated a nd scheduled to be implemented at the federal or state level at such time after the exceedance, and that measure or control is determined to be sufficient to address the upward trend in air quality, additional local measures may be unnecessary . It is expec ted that implementation of only a few of these measures would be necessary. The selection between measures will be based upon cost

effectiveness, emissions reduction potential, ease and timing of implementation, and other appropriate factors. Delaware wi ll submit to EPA an analysis to demonstrate the proposed measures are adequate to return the area to attainment.

Adoption of additional control measures is subject to necessary administrative and legal processes. The Delaware DAQ will solicit input from all interested and affected persons in the area prior to selecting appropriate control measures. No contingency measure shall be implemented without providing the opportunity for full public participation during which the

relative costs and benefits of in dividual measures, at the time they are under consideration, can be fully evaluated. This process will include publication of notices, an opportunity for public hearing, and other measures required by Delaware law.

4. Timing of contingency measure impleme ntation

A timeline for the development of NO X , PM 2.5 and/or SO 2 regulations or permit conditions follows. This schedule initiates with certification of ambient air quality monitoring data indicating a violation of the daily PM 2.5 NAAQS:

a. Warning Level Response

Should a warning level response be triggered, measures that can be implemented in a short time will be selected in order to be in place within 18 months from the close of the calendar year that prompted the warning level.

b. Action Level ResponseDelaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

62 Sh ould an action level response be triggered, implementation of necessary control measures will take place as expeditiously as possible, but in no event later than 18

months after the Delaware D AQ makes a determination, based on quality

- assured ambient data, that a violation of the NAAQS has occurred.

Table 10

- 1 Schedule for Permit Revisions or Rule Rev isions for Contingency Measures 24

Identify and quantify the emissions reductions expected to result in the future from existing and future state and federal regulatory programs. 3 months

Use the best available air quality modeling to evaluate the air quality improvement expected to result in the Philadelphia MA from the programs and

emissions reductions identified in step 5 below. 6 months

Draft any needed permit conditions or SIP regulations. 3 months

Complete rulemaking or permit revision process and submit to EPA

. 6 months

Completion no later than 18 months

5. List of Potential Contingency Measures

 Lower particulate limits for No. 6 fuel oil

- fired boilers.

 Working with the local metropolitan planning agencies to implement transportation control measures such as: traffic flow improvements, transit improvements, trip reduction programs, arterial and signal improvement projects, bicycle projects, or ot her new transportation measures.

 Low

- sulfur distillate and residual fuels.

 Additional PM 2.5 controls for EGUs and large industrial boilers burning fuels other than distillate fuel or natural gas.

 Calpine Edge Moor power plant

– Units 3 and 4 fuel switch from coal to natural gas.

 Vehicle inspection and maintenance program enhancements (increase weight limit, addition of diesel vehicles, etc.).

 Alternative fuel and additional diesel retrofit programs for fleet vehicle operations.

 Require NOx or SO 2 emission offsets for new and modified major sources.

 Increase the ratio of emission offsets required for new sources.

24 This schedule initiates with certification of ambient air quality monitoring data indicating a violation of the 2006

24

- hour PM 2.5 NAAQS

. An action level response is triggered by a violation as well as when a two

- year average of

the annual PM 2.5 concentration is 15.1 μg/m 3 or greater.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

63  Require NOx or SO 2 controls on new minor sources (less than 100 tons).

 Require increased recovery efficiency at sulfur recovery plants.

 Broader geographic applicability of existing measures.

11 Other Delaware Commitments

11.1 C ommitm e nt to R e vise P l a n

Delaware DAQ c ommits to submit a second 10

- year M a int e n a n c e P l a n e i g ht y e ar s a f t e r

r e d e s i g n a tion, a s re qui re d b y Se c t ion 175 ( A)(b) of the C AA

. The M a int e n a n c e P l a n re vision is

int e nd e d to e nsu r e c o ntinu e d a tt a inm e nt of the 2006 daily PM 2.5 NAAQS f or a n a ddition a l t e n

y e a r p er iod.

11.2 P ublic P ar ti c ip a tion

I n acc o r d a n c e with S ec t i on 110 (a)( 2 ) of the C AA, Delaware is re qui re d to h a ve a public

c omm e nt p er iod a nd p r o vide the oppo r tuni t y f o r a public h ear i n g on the M a int e n a n c e P l a n p r ior

to a doption. P ublic p ar ti c ip a tion in the Delaware S I P p r o c e ss is required by Delaware law 25 a s f ollows:

 Noti c e of a v a il a

bili t y of t he SIP do c u m e nt a n d the time a nd d a te of the pub l ic h ear i n g are publish e d as a Legal Notice in the News Journal and Delaware State News, 30 days prior to the hearing, and is submitted along with this redesignation request and maintenance plan

 A public h ear i n g is required for all Delaware State Implementation Plans and Regulations

, and was held on October 23, 2012

.

 A 30

- d a y public c omm e n t p er iod is op e n before t h e public h ear i n g to r e c e ive c omm e nts
on the M a int e n a n c e P l a n. A summ a r y of any c omm e nts r e ce iv e d a nd Delaware DAQ ’ s

re spons e s is in c lud e d with this SIP submitt a l to the EPA

.

 The Legal Notices, Comments and other documentation as required by EPA and Delaware Law and DNREC policies will also be submitted to the EPA

.

25 TITLE 29, General Regulations for State Agencies, Chapter 101, Administ rative Procedures Subchapter II, Agency Regulations

.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

64 12 CONCLUSIONS

The Philadelphia non a tt a in m e nt ar e a h a s a tt a in e d t h e 2006 daily P M 2.5 NAAQS a nd h as

c ompli e d with the a

ppli ca ble p r ovisions of the C AA re qui r e d of the P M 2.5 N AAQS. Delaware

d e monst ra t e d th a t the Philadelphia NAA h a s a tt a in e d the 2006 daily P M 2.5 NAAQS a nd that the

a ir q u a li t y imp r ov e m e nts ar e d u e to p er m a n e nt a nd e n f

o r c e a ble c ont r ol m ea su re s.

The Delaware DAQ h a s p r e p are d a M a int e n a n c e P l a n th a t m ee ts the re qui r e m e nt of

175A of the C l ea n Air A c t. This M a i nt e n a n c e P l a n p r ovi d e s f or the c ontinu e d a tt a inm e nt of the 2006 daily P M 2.5 NAAQS f or a p er iod of a t l ea st t e n y ear s a f t e r EPA h a s f

o r m a l l y re d e s i g n a t e d

t h e a r e a to a tt a inm e nt. This M a int e n a n c e P l a n p r ovid e s a d e q u a te c ontin g e n c y m ea s u re s f o r pot e nti a l, a ddition a l e missions re du c tions in the e v e nt th a t f utu r e viol a tions of the 2006 daily

P M 2.5 NAAQS ar e obs er

v e d in the a r e a.

Delaware has performed an analysis that shows the air quality improvements are due to permanent and enforceable measures and that additional significant regional NOx and SO 2 reductions following implementation of federal and state measures will ensure continued compliance (maintenance) with the standard. Furthermore, emission projections in the Maintenance Plan indicate that NOx, PM 2.5 and SO 2 emissions will continue to decli ne, ensuring that the area continues to maintain compliance with the standard and provide for an increased margin of safety.

The Delaware DAQ h a s p r e p are d a c omp re h e nsive e missions inv e nto r y o f P M 2.5 a nd i ts

p rec u r s o r s f

or the “a tt a i n m e nt” y e ar , ( 2 008 )

, a nd h a s p re p a r e d p r oj e c tions of the e missions

inv e nto r y to 2017 a nd 2025. Th e se e missions p r oj ec tions indi ca te t h a t e missions l e v e ls in the New Castle portion of the Philadelphia NAA will c ontinue to re m a in mu c h low e r th a n e missions

fr om the a tt a inm e nt y e a r 200 8 l e v e ls, th ere b y m a int a ini n g the P M 2.5 NAAQS in f utu r e y e a r s. 26

The Delaware DAQ c ommits to c on t inue to op era te a n a pp r o p r i a te a ir qu a li t y monito r ing

n e tw o r k to v er i f y the m a int e n a n c e of the a tt a inm e nt st a tus on c e the are a h a s b e e n re d e si g n a t e d.

The Delaware DAQ h a s the l e g a l a utho r i t y to impl e m e nt a nd e n f o r c e a ll c ont r ol m e a s u re s.

The Delaware DAQ h a s p r e p are d a c omp re h e nsive e missions inv e nto r y o f P M 2.5 a nd i ts

p rec u r s o r s f

or the “base year” y e ar , 2007 to meet CAA 172(c)(3) requirements.

F in a l l y , t h e Delaware P M 2.5 M a int e n a n c e P l a n in c lud e s y e a r 2017 a nd 2025 on

- r o a d

motor v e hi c le e missions budg e ts f or P M 2.5 a nd NOx f

or use in t ra nspo r t a tion c on f o r mi t y d e t er min a tions to a ssu r e th a t a n y i n cr e a s e s in e m i ssions fr om this s ec tor do not j e op ar di z e

c ontinu e d a tt a inm e nt of the 2006 daily PM 2.5 NAAQS st a nd ar d du r ing the t e n

- y e a r m a int e n a n c e

p er iod. Delaware ’s M a int e n a n c e P l a n h a s b ee n p re p are d in a cc o r d a n ce with the re qui re m e nts

s p ec i f i e d in EPA ’ s g

u i d a n c e d o c um e nt, a nd a d d ition a l g uid a n c e r ece i v e d fr om EPA st aff

.

Based on this presentation, New Castle County, Delaware meets the requirements for redesignation under the CAA (Section 107(d)(3)) and EPA guidance for fine particles.

26 Based on MARAMA work, and consultation with PA and NJ, emissions for all of the Philadelphia NAA will decrease significantly by 2017 and 2025.Delaware Redesignation Request and Maintenance Plan

– 2006 Daily PM 2.5 NAAQS

65 Consistent with the authority granted to EPA, the State of Delaware req uests that New Castle County, Delaware be redesignated to attainment for the 2006 daily fine particles standard simultaneously with EPA approval of this Delaware State redesignation request and daily PM 2.5 Maintenance Plan for the New Castle County portion of the Philadelphia NAA.