## Delaware Redesignation Request and Maintenance Plan

Under the 1997 Annual 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

Fi na l

November 27 , 2012Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

2 

### Table of Contents

Acronym List

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

List of Tables

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

List of Figures

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

EXECUTIVE SUMMARY

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

1 Introduction

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

1.1 Documentation Organization

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

2 Background

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

2.1 Health Effects

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

2.2 Philadelphia

- Wilmington, PA

- NJ

- DE Nonattainment Area Designation

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

3 EPA Requirements for Redesigna tion

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

3.1 NAAQS Compliance

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

3.1.1 EPA Requirements

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

3.1.2 Delaware Approach

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

3.2 Demonstration that the NAAQS for annual PM 2.5 , as published in 40 CFR 50.7, has been attained (requirement 1 of 3)

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

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

monitorin g 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 EPA Requirements

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

4.2 Delaware Approach

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

4.2.1 Economic Conditions

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

4.2.2 Meteorology

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

4.2.3 Emission Inventory I m p r ov e m e n t s from 2002 to 2007

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

4.3 Enforceable and Permanent PM 2.5 , NOx and SO 2 Measures that Contributed to Improved Air Quality after 2002 and through 2007

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

4.3.1 Delaware

- specific Control Measures

................................ ................................ ........ 28Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

3 4.3.2 Federal Control Measures

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

5 SIP Completeness

- Fully Approved SIP, Section 110 and Part D Requirements

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

5.1 EPA Requirements

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

5.2 Delaware Approach

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

5.3 Part D Plan Requirements for Nonattainment Areas

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

6 Maintenance Plan

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

6.1 EPA Requirements

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

6.2 Delaware Approach

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

7 Attainme nt Inventory

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

7.1 EPA Requirements

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

7.2 Delaware Approach

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

7.3 2007 Att a inm e nt Y ea r I nv e nt or y

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

8 Maintenance Demonstration

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

8.1 EPA Requirements

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

8.2 Delaware Approach

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

8.2.1 2017 and 2025 Projection Inventories

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

8.2.2 2017 and 2025 Mobile Source Emissions Budgets

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

8.2.3 Control Measures for Maintenance of Good Air Quality

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

8.2.4 Delaware

- specific NOx, PM2.5 or SO2 Control Measures (Effective Post 2007)

... 48

8.2.5 Federal Control Measures (Effective or Phased

- in Post 2007)

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

8.2.6 Future Emissions Reductions Programs

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

8.2.7 C ont r ols to R e m a in in E ffec t

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

9 Verify Continued Attainment

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

9.1 EPA Requirements

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

9.2 Delaware Approach

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

10 Contingency Measures

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

10.1 EPA Requirements

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

10.2 Delaware Approach

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

11 Other D elaware Commitments

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

11.1 C ommitm e nt to R e vise P l a n

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

11.2 P ublic P ar ti c ip a tion

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

12 Conc l u s ions

................................ ................................ ................................ ........................... 56Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

4 

### Acronym List

AQS

- EPA ’s Air Quality System

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

dv

- Design Value

DNREC

- Delaware Department of Natural Resources and Environmental

Con trol

EGU

- Electric Generating Unit

GDP

- Gross Domestic Product

EPA

- United States Environmental Protection Agency

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

NESCUAM

- Northeast States for Coordinated Air Use Management

LRTP

- Long Range Transportat ion 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 Technology

RPO

- Reg ional 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

tpy

- Tons per Year

TS D

- Technical Supporting Document

VOC

- Volatile Organic Compound

WILMAPCO

- Wilmington Area Planning CouncilDelaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

5 

### List of Tables

Table 3

- 1 2007

- 2012 Annual Means (ug/m 3 )

Table 3

- 2 Design Values: 2007

- 2009, 2008

- 2010 and 2009

- 2011

Table 3

- 3 PM 2.5 Monitoring Site General Information

Table 3

- 4 PM 2.5 Monitor Site Specific Information

Table 4

- 1 Monthly Average Min, Max and Mean Temperatures and

Precipitation, including Total Precipitation

Table 4

- 2 Philadelphia NAA annual PM 2.5 average s

- 2001

- 2011

Table 4

- 3 New Castle County 2002

- 2007 Emission Changes

T a b le 4

- 4 New Castle County 2002

- 2007 E m issio n s Comparison

T ab l e 7

- 1 2007 New Castle County Emissions (tpy )

T a ble 8

- 1 Co m p ar ison of e missions f or t he y e ar s 2007, 2017 a nd 2025

T a ble 8

- 2 Reductions and % Change of NOx e missions f or t he y e ar s 2007, 2017 a nd 2025

T a ble 8

- 3 Reductions and % Change of PM 2.5 e missions f or t he y e ar s 2007, 2017 a nd 2025

T a ble 8

- 4 Reductions and % Change of SO 2 e missions f or t he y e ar s 2007, 2017 a nd 2025

Table 8

- 5 Growth Assumptions Used in Emission Inventory Projections

Table 8

- 6 New Castle County Maintenance Plan On

- Road Mobile Source

Emissions Budgets

Table 8

- 7 Post

- 2007 Emission Reductions due to Control Measures

Table 10

- 1 S chedule for Permit Revisions or Rule Revisions for Contingency Measures



### List of Figures

Fig ure 2

- 1 Philadelphia PM 2.5 Nonattainment Area Boundaries

Figure 3

- 1 Delaware’s PM 2.5 Monitoring Site Locations

Figure 4

- 1 2002

– 2011 Delaware Gross Domestic Product

– All Industry

F igure 4

- 2 Philadelphia NAA

– 2001 to 2011 annual PM 2.5 trends

F igure 4

- 3 Philadelphia NAA

– annual PM 2.5 trends (avg. all monitors)

Figure 4

- 4 Philadelphia NAA

– 2003 to 2011 PM 2.5 3

- Year Rolling AveragesDelaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

6 EXECUTIVE SUMMARY

This request for 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 ) non attainment area ( Philadelphia NAA )

. This area was designated as a nonattainment area on January 5, 2005 ( 70 FR 944 )

, with an effective date of April 5, 2005.

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

. Section 107 includes a requirement for a n approved Maintenance Plan before an area can be redesignated from nonattainment to attainment of a National Ambient Air Quality Standard (NAAQS). This redesignation request and maintenance plan SIP revi sion provides technical information that

support s this request to redesignate the Delaware portion of the Philadelphia NAA area to

attainment of the 1997 annual PM 2.5 NAAQS.

PM 2.5 air quality has improved in New Castle County as a result of the impleme ntation 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 period s 2007

- 2009 , 2008

- 2010

and 2009

- 2011 that all demonstrate attainment of the 1997 PM 2.5 NAAQS. Th e purpose of th is

redes i g na tion request and m aintenance p lan is to request that the 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). I n summary, the plan includes:

 A demonstration that attainment of t he 1997 PM 2.5 air quality standards for the Philadelphia NAA will continue through 2025.

 A n attainment emissions inventory that identifies the level of emissions in the area that is sufficient to attain the NAAQS

, and projected future emissions inventori es 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 unlikely 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 emiss ions budgets for 2017 and 2025 for use in transportation conformity determinations to assure that any increases in emissions from this sector do not jeopardize continued attainment of the 1997 annual PM 2.5 standards during the maintenance period.

Based o n this presentation, New Castle County, Delaware meets the requirements for redesignation under the CAA (Section 107(d)(3)) and EPA guidance for fine particles.

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

– 1997 Annual PM 2.5 NAAQS

7 Consistent with the authority granted to EPA , the State of Delaware requests that New Castle

Co unty, Delaware be redesignated to attainment for the 1997 annual fine particles standard simultaneously with EPA approval of this Delaware State redesignation request and Maintenance Plan for the New Castle County portion of the Philadelphia NAA.Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

8 1 Intr oduction

The State of Delaware request s that the EPA redesignate the Delaware portion of Philadelphia NAA to attainment for the 1997 annual PM 2.5 NAAQS pursuant to the provisions

Section 107 of the CAA (42 U.S.C. 7407)

. 2 Since the designations for the 1997 NAAQS for 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 quality in the Philadelphia area will remain compliant with the 1997 annual 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 Delaware 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 201 7 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 1997 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 1997

annual 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 enclose d with this redesignation request and maintenance 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

ar e available for review upon request by the public.

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 r eference, 2.5 micrometers is 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 power plants and other combustion sources, fires, emissions from motor vehicles, windblown dust, and

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

2 After EPA redesignates the Philadelphia no nattainment area to attainment, it will be known as the Philadelphia
Maintenance Area, or Philadelphia MA

.Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

9 sources ; primary and secondary. Primary sources directly emit 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 ar e 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 are 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 heartbeat

, and premature death in individuals with pulmonary or cardiac disease

.

2.2 Philadelph ia

- Wilmington, PA

- NJ

- DE Nonattainment Area Designation

On July 18, 1997, EPA established a health

- based PM 2.5 NAAQS at 15.0 micrograms per cubic meter ( μ g/m 3 ) based on a 3

- year average of annual mean PM 2.5 concentrations (‘‘the

annual PM 2.5 NAAQS’’ or ‘‘ the annual standard’’) (62 FR 36852). At that time, EPA also

estab lished a 24

- hour standard of 65 μg/m3 ( ‘‘1997 24

- hour standard’’). See, 40 CFR 50.7. EPA established these standards based on significant evidence and numerous health studies demonstrating that serious health effects are associated with exposures to PM 2.5

. In 1999, EPA and State Air Quality Agencies initiated the monitoring process for the 1997 PM 2.5 NAAQS and by January 2001, established a complete set of air quality monitor s.

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 section 107(d)(1) of the CAA. On January 5, 2005, EPA published its air quality designations for the 1997 PM 2.5 NAAQS based upon air quality monitoring data for calendar years 2001

– 2003 (70 FR 944). These designations became effective on April 5, 2005. The Philadelphia Area, which includes New Ca stle County in Delaware; Burlington, Camden, and Gloucester Counties in New Jersey; and Bucks, Chester, Delaware, Montgomery, and Philadelphia Counties in Pennsylvania (see Figure 2

- 1)

, was designated nonattainment for the 1997 annual PM 2.5 NAAQS during th is designations process (40 CFR 81.308, 81.832, and 81.339). The attainment date for the 1997 annual PM 2.5 NAAQS is as expeditiously as practicable, but no more than five year s from the date of designation. See, 40 CFR 51.1004(a) ) . Therefore, the attain ment date for the Philadelphia Area was April 5, 2010.

On October 17, 2006 (71 FR 61144), EPA retained the 1997 annual PM 2.5 NAAQS at 15 μg/m3 based on a 3

- year average of annual mean PM 2.5 concentrations, and promu lgated a 24

- hour standard of 35 μg/m3 based on a 3

- year average of the 98th percentile of 24

- hour concentrations (the ‘‘2006 24

- hour standard’’). 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 and clarified that the Philadelphia Area is designated as unclassifiable/attainment for the 1997Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

10 24

- hour PM 2.5 standard. This redesignation request addresses the 1997 a nnual PM 2.5 standard

. The 2006 24

- hour PM 2.5 standard will be addressed in a separate document

.

In response to legal challenges of the 2006 annual standard, the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) remanded this standard to EPA for further

consideration. See, American Farm Bureau Federation and National Pork Producers Council,

et al. v. EPA, 559 F.3d 512

, (D.C. Circuit 2009). However, given that the 1997 and 2006 annual

PM 2.5 standards are identical, attainment of the 1997 annual standard would also indicate

attainment of the remanded 2006 annual standard.

Figure 2

- 1 Philadelphia PM 2.5 Nonattainment Area Boundaries

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 1997 PM 2.5 NAAQS, the areas must show that the average of the annual average values from three (3) consecutive calendar years of quality

- assured air quali ty monitoring data is 15.0 μg/m 3 or lower.

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

.Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

11  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.

 EPA has fully approve d a maintenance plan, including contingency measures, for the ar ea under Section 175A of the Act. Section 175A requires de monstrating that the area will maintain (continue to attain) the standard for at least ten years after redesignation to attainment, and that contingency measures be implemented if a violation is mo nitored 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 Part 51, Subpart Z,

entitled Provisions for Implementation of PM 2.5 National Ambient Air Quality Standards (implem entation 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 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 should be colle cted 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 redesignated to atta inment for the 1997 annual 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 Pennsylvania Department of Environmental Quality must

each demonstrate that the annual 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 occurring within the NAA.

Thi s 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,Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

12 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 require ments:

1. A demonstration that the NAAQS for annual 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 pub lic 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 for annual PM 2.5 , as published in 40 CFR 50.7, has

been attained (requirement 1 of 3)

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

, and

the City of Philadelphia (‘‘the States’’), submitted complete quality assured air quality monitoring data into the EPA Air Quality System (AQS) database for the 2007

– 2011 monitoring periods. The States then certified that data. DAQ has also obtained preliminary 2012 monitoring data

. The criteria for determining if an area is attaining the 1997 annual P M 2.5 NAAQS are set out in 40 CFR 50. 13 and A ppendix N of 40 CFR 50

. The annual PM 2.5 NAAQS is met when the annual design value (dv) is less than or equal to 15.0 micrograms per cubic meter ( μ g/m 3 ). Three years of valid annual means are required to produce a valid annual 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, whic h 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 Phila delphia NAA had less than four quarters of complete data for one or more

year s during the 2007

– 2009

, 2008

– 2010 and 2009

- 2011 monitoring periods. For these monitors, EPA applied the data substitution test set out in the April 1999 EPA guidance document

‘‘ G uideline on Data Handling Conventions for the PM NAAQS

. ” Th e ‘‘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 resu lting 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. The 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 regre ssion 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.Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

13 2007

- 2009 and 2008

- 2010 monitoring data

Considering 2007

– 2009 data, six monito rs had less than complete data, with five of those

monitors passing the Max

- Q Sub test. However, the New Garden, PA monitor’s missing data could not be evaluated using the Max

- Q test. Therefore, EPA performed a linear regression analysis and bootstrapping to show that the New Garden monitor also met the 1 997 annual NAAQS. In summary, all Philadelphia NAA monitors meet the 1997 annual NAAQS for the

2007

- 2009 and 2008

- 2010 monitoring periods

. More d etails of EPA’s analysis can be found in

the EPA T echnical S upport D ocument s (TSD )

. 3

, 4

2009

- 2011 monitoring data

Considering 2009

– 2011 data, three monitors had less than complete data (New Garde n, PA, and Bellefonte and Newark in Delaware

- monitor IDs 420290100

, 100031003 and

100031012 ). However, based on email correspondence with EPA Region 3, all of the 2009

- 2011 monitoring data passed the m ax

- Q substitution test , and the 2009

- 2011 monitoring values

as received from EPA are included in the air quality tables within this plan (see table 3

- 1)

. 5

Furthermore

, a ccording to the PM 2.5 implementation rule, the attainment date for the Philadelphia Area is April 5, 2010, a nd monitoring data from the period 2007

– 2009 is used to determine if the area attained by April 5, 2010.

Table 3

- 1 shows the PM 2.5 200 7

- 201 1 quality assured and certified annual means for each monitor in the Philadelphia NAA for the years 2007

– 20 11

. Ta ble 3

- 2 shows the 3

- year design

values for the 2007

- 2009, 2008

- 2010, and 2009

- 2011 . The highest 3

- year design values based

on 2007

- 2009, 2008

- 2010, and 2009

- 2011 data are 13.9 μg/m 3 , 13.8 μg/m 3 and 13.7 μg/m 3

, all of

which are less than the level of the annual PM 2.5 NAAQS of 15.0 μg/m3. Based on preliminary 2012 data from AQS, the 1 st quarter values also continue to show attainment based on the highest

value of 14.6 μg/m 3 in Philadelphia

, (monitor ID 421010004 )

.

Therefore, complete quality

- assured and certified ambient air quality monitoring data demonstrate that the air quality has met the 1997 NAAQS for annual PM 2.5 in the Philadelphia

NAA. The NAAQS attainment, accompanied by decreases in emission levels discussed in

Section 7 , 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.

3 77 FR 3223 (January 23, 2012).

4 77 FR 28782 (May 16, 2012).

5 E. V. Rosa, EPA Region 3, August 27, 2012Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

14 Table 3

- 1 2007

- 2012 Annual Mean s (ug/m 3 )

09

- 11 Completeness (5)

State County Monitor ID 2007 2008 2009 2010 2011 Statu s ( 3 ) Data

Substitution ( 4 ) Pre

L im

. 2012

DE Bellefonte 100031003 13.4 13.0 10.2 10.2 9.4 C Max

- Q 8.5

Lums 100031007 12.5 11.5 10.0 10.0 8.8 C Max

- Q 8.0

Newark 100031012 13.4 12.5 10.6 10.4 10.4 C Max

- Q 8.8

MLK 100032004 14.4 13.5 11.2 10.6 10.3 C 9.7

NJ Camden 340071007 13.8 11.9 9.5 9.5 10.1 C 8.6

Gloucester 340150004 13.3 11.5 9.3 9.1 9.4 C Max

- Q 9.3

PA Bucks 420170012 13.0 12.7 10.8 10.5 11.5 C 10.6

Chester 420290100 14.1 13.7 14.1 13.8 13.3 C Max

- Q 8.9

Delaware 420450002 14.7 13.9 12.4 13.5 12.6 C 10.7

Montgomery 420910013 13.1 11.7 10.4 9.5 10.3 C 8.6

Philadelphia 421010004 13.7 13.0 10.8 10.7 13.2 C 14.6

Philadelphia 421010024 (1) 12.9 12.0 9.9 9.6

- Inc

-

Philadelphia 421010047 14.3 13.5 11.1 11.0 11.4 C 9.9

Philadelphia 421010055 (6) 13.5 11.3 11.3 11.4 C 9.8

Philadelphia 421010057 12.0 13.3 11.1 10.9 11.4 C 10.0

Philadelphia 421011002 (2)

- - 9.0 Inc 13.4

NAA Avg

. (all monitors) 13.5 12.7 10.8 10.7 10.8 10.8

Notes : Data Source :

 2007

- 2010 annual means : 77 FR 3147

 2011 annual means: EPA Region 3 (see footnote 5 )

 2012 preliminary data was obtained from AQS (as of July 31, 2012)

1

. Monitoring site was shutdown on January 1, 2011.

2

. Monitoring site commenced operation on June 1, 2010. However, as of July 30, 2012

, AQS 2010 data for this

monitor was not a vailable. (see footnote 5)

3

. This column indicates whether the monitoring data from the monitor meet the completeness requirem ent (C) or not (Inc) for each quarter of the 3

- year period.

4

. This column identifies the data substitution technique utilized to deem 'complete' the annual design value of the incomplete monitors. “Max

- Q ” denotes that the monitor passed the maximum quarter substitution test.

5. As det ermined by EPA (see footnote 5 )

6

. Monitor started operating 2008 2012 is Preliminary and not certified

– only the 1 st quarter was available from AQS (as of July 31, 2012)Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

15 Table 3

- 2 Design Values : 2007

- 2009, 2008

- 2010 and 2009

- 2011

State County Monitor ID 07

- 09

DV US EPA Analysis (3) 08

- 10

DV US EPA Analysis (3) 09

- 11

DV US EPA Analysis (3)

DE Bellefonte 100031003 12.2 C 11.1 C 9.9 Max Q

Lums 100031007 11.3 Max Q 10.5 C 9.6 Max Q

Newark 100031012 12.2 Max Q 11.2 Max Q 10.5 Max Q

MLK 100032004 13.0 Max Q 11.7 Max Q 10.7 C

NJ Camden 340071007 11.7 C 10.3 C 9.7 C

Gloucester 340150004 11.4 C 10.0 C 9.3 Max Q

PA Bucks 420170012 12.2 C 11.3 C 10.9 C

Chester 420290100 13.9 Bootstrap 13.8 Max Q 13.7 Max Q

Delaware 420450002 13.7 C 13.3 C 12.7 C

Montgomery 420910013 11.7 C 10.5 C 10.1 C

Philadelphia 421010004 12.5 C 11.5 C 11.6 C

Philadelphia 421010024 11.6 Max Q 10.5 C 9.8 Inc (1)

Philadelphia 421010047 13.0 Max Q 11.9 C 11.2 C

Philadelphia 421010055 12.4 C 12.0 C 11.4 C

Philadelphia 421010057 12.1 C 11.7 C 11.1 C

Philadelphia 421011002

- - - 9 Inc (2)

Philadelphia NAA Average μg/m3

(all monitors) 12.3 11.4 10.8

Notes : Sources of data:

o 2007

- 200 9 and 2008

- 2010 d esign values: 77 FR 3147

o 2009

- 2011 design values : EPA Region 3 ( EPA, footnote 5 )

o 2012 preliminary data was obtained from AQ S (as of July 31, 2012)

1

. Monitoring site was shutdown on January 1, 2011.

2

. Monitoring site commenced operation on June 1, 2010.

3

. 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. This also column identifies the data s ubstitution technique utilized to deem 'complete' the annual design value of the incomplete monitors. “Max Q Sub ” denotes that the monitor passed the maximum quarter substitution test. (EPA, footnote 5)Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

16 3.3 Ambient monitoring data quality assured in accorda nce with 40 CFR 58.10,

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

Delaware DAQ has quality assured all data in accordance with 40 CFR 58.10 and all other federal requirements. Delaware DAQ h as 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. Table 3

- 3 lists the

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

- 4 contains more specific information for each PM 2.5 monitoring site in New Castle County.

Table 3

- 3 PM 2.5 Monitoring Site General Information

Site Name & AQ S 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

- 4 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

– 1997 Annual 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 stations or sites must be sited to represent communit y

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

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

- oriented area of expected

maximum concentration. (2) For areas with more than one required station, a monitoring stat ion 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 annual 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 submitted to EPA’s Air Quality System (AQS) in a timely manner in accordance to the schedule prescribed by EPA.

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

– 1997 Annual 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 Plannin g & Standards ( OAQPS ) document “ Guidance for Network Design and Optimum Site Exposure for PM 2.5 and PM

10 ” ( EPA 1997a). Final network documents were submitted to EPA Region 3 in June 1998, and EPA approved

Delaware’s PM 2.5 monitoring network.

Delaware 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 t o EPA Region 3. All data complies with appropriate federal and state requirements, including 40 CFR Part 50 Appendices L and N, and 40 CFR Part 58 Appendix A.

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

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

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

– 1997 Annual PM 2.5 NAAQS

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

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)

.

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 paramete rs (for example, vehicle miles traveled) have changed over time, the 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 network 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 above, 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 formation on Delaware’s monitoring network was discusse d 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 become necessary in the future Delaware DAQ will consult with EPA Regio n 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 federal requirements. Delaware DAQ will enter all data into AQS on a time ly basis in accordance with federal guidelines.

4 Permanent and Enforceable Emission Reductions

4.1 EPA Requirements

As required by Section 107(d)(3)(E)(iii) and in EPA redesignation guidance, states 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 (su ch as reduced production or shutdown due to temporary adverse economic conditions) or unusually favorable meteorological conditions does not qualify.Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

20 4.2 Delaware Approach

Delaware demonstrate s the i mp r ov e m e nt in a ir qu a li t y described in 3.2 of this docum ent

was n ot a result of temporary adverse economic conditions (4.2.1) or unusually favorable meteorology (4.2.2). Delaware then demonstrates that the i mp r ov e m e nt s in air quality described

in 3.2 of this document are reasonably attribut able 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.

Convers ely, 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 Fig ure 4

- 1.

Figure 4

- 1 2002

– 2011 Delaware Gross Domestic Product

– All Industry

0 10000 20000 30000 40000 50000 60000 70000

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011



## GDP all industry (mil $)Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

21 Figure 4

- 1 shows that except for a decline between 2007 and 2008 6 , all industries increased GDP in every year from 2002 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 standard (i.e.,

2002

- 2006) and the time when it did (i.e., 2007

- 2011). The GDP in every year between 2007 and 2011 is greater than every year between 2002 an d 2006. This analysis of GDP indicates that economic conditions did not contribute to the improvement in air quality.

4.2.2 Meteorology

Delaware evaluated the role meteorology may have played in the improvement in air quality described in 3.2 of this documen t 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 emission s 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 D elaware’s highest PM 2.5 concentrations are recorded (monitor ID = 100032004). 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 2001

- 2003 and 2007

- 2009. 7

6 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.

7 Recall that 2001

- 2003 average PM 2.5 concentration was used to calculate the initial Philadelphia NAA design

values causing nonattainment , and the 2007

- 2009 average PM 2.5 concentration was used to calculate design values

which demonstrate attainment. Therefore, by comparing the meteorology between these two 3

- y ea r periods we can evaluate the effect that meteorology had on PM 2.5 concentrations during a time when the air quality was

nonattainment and a time when it was attainment

.Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

22 Table 4

- 1 Monthly Average Min, Max and Mean Temperatures and

Precipitation, including Total Precipitation

2001

- 2003 2007

-

2009 2001

-

2003 2007

-

2009 2001

-

2003 2007

-

2009 2001

-

2003 2007

-

2009

Month 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 25.2 26.5 40.1 41.8 32.7 34.2 7.6 8.0

Feb 26.3 25.1 43.2 42.5 34.8 33.8 8.5 6.6

Mar 33.1 33.6 51.5 53.3 42.2 43.5 14.4 10.5

Apr 43.0 43.4 63.6 63.1 53.3 53.3 6.3 14.6

May 51.2 52.1 70.2 73.5 60.7 62.8 12.7 10.0

Jun 62.1 63.5 80.3 82.3 71.2 72.9 19.1 12.1

Jul 66.0 66.1 84.6 86.0 75.2 76.1 6.6 11.8

Aug 68.1 66.2 86.3 84.6 77.2 75.4 8.9 11.3

Sep 58.2 59.3 77.4 78.5 67.8 68.9 13.4 10.6

Oct 45.6 48.3 65.3 68.0 55.4 58.1 11.3 13.6

Nov 38.2 38.7 57.6 54.9 47.9 46.8 8.8 7.5

Dec 29.6 29.6 45.4 44.5 37.5 37.0 11.4 17.8

Annual

average 3

- Yr Average Temp., and

3

- Yr Total Precipitation 45.5 46.0 63.8 64.4 54.7 55.2 129 134.3

From Table 4

- 1, we see that the annual average 3

- year monthly averages for minimum, maximum, and mean temperatures for 2007

- 2009 are slightly higher than those temperatures during the years 2001

- 2003 (e.g., the 2001

- 2003 annual average mean temperature was 54.7 degrees while the 2007

- 2009 annual average mean temperature was 55.2 degrees). Higher temperatures typically correlate with higher ambient PM 2.5 concentr ations, which indicate temperature is a factor that negatively impacted air quality.

From Table 4

- 1, we see that 3

- year total precipitation was about 4.3% higher in 2007

- 2009 compared to 2001

- 2003 (134.8 in. and 129 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 7

- 2009), increased precipitation did not likel y contribute to the improved air quality.

In summary, 1) the annual average 3

- year monthly min, max, and mean temperatures are very similar between the nonattainment timeframe (2001

- 2003) and the attainment timeframe (2007

- 2009), and 2) the total pre cipitation is also very similar between those two periods.Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

23 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 purp oses under the 1997 annual PM 2.5 NAAQS.

4.2.3 Emission Inventory I m p r ov e m e n t s from 2002 to 2007

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 follows that permanent and

enforceable reductions of PM 2.5 , NO X and SO 2 , 8 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, EPA published its air quality designations for the 1997 PM 2.5 NAAQS based upon air quality monitoring data for calendar years 2001

– 2003 (70 FR 944).

S in c e 2001 , p er

m a n e nt a nd e n f

o r cea b l e re d u c tions of p r im a r y PM 2.5 a nd s ec ond a r y PM 2.5
p rec u r sor e missions h a ve c ont r ibut e d to im p r ov e m e nts in PM 2.5 a ir qu a li t y a nd to the a tt a inm e nt
of the PM 2.5 NAAQ S . To help demonstrate how emission reductions have improved air quality,

we evaluate air quality trends, which can be seen in Table 4

- 2 and Figure s 4

- 2 and 4

- 3, and

discuss emission reductions due to permanent and enforceable control measures.

The values in Table 4

- 2 and Figure 4

- 2 represent the annual average concentration as calculated from the four calendar quarterly averages at each monitoring site

. As T able 4

- 2 shows, the highest annual value in the Philadelphia NAA nonattainme nt area has decreased from

17.6 μg/m 3 in 2001 (monitor ID 100032004) to 13.3 μg/m 3 in 2011, or 4.3 μg/m 3 , which represents a 24% drop

. Th e annual average is the basic statistic us ed in determining trends and compliance with the annual average NAAQS.

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

.Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

24 Table 4

- 2 Philadelphia NAA annual averages

- 2001

- 2011

State Monitor ID County 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

DE 100031003 Bellefonte 15.6 14.0 14.8 13.9 14.3 12.3 13.4 13.0 10.2 10.2 9.4

100031007 Lums 14.5 13.0 13.3 13.2 13.8 11.4 12.5 11.5 10.0 10.0 8.8

100031012 Newark 15.8 14.3 14.8 14.5 14.4 12.7 13.4 12.5 10.6 10.4 10.4

100032004 MLK 17.6 14.8 15.5 14.9 15.0 14.7 14.4 13.5 11.2 10.6 10.3

NJ 340071007 Camden 14.2 13.9 13.9 13.2 14.3 12.4 13.8 11.9 9.5 9.5 10.1

340150004 Gloucester 14.5 12.3 13.8 12.4 14.2 9.3 13.3 11.5 9.3 9.1 9.4

PA 420170012 Bucks 14.5 14.2 14.4 13.0 14.3 12.2 13.0 12.7 10.8 10.5 11.5

420290100 Chester ND ND 15.6 14.3 15.9 12.6 14.1 13.7 14.1 13.8 13.3

420450002 Delaware 15.9 14.7 15.3 15.0 16.9 14.2 14.7 13.9 12.4 13.5 12.6

420910013 Montgomery 14.9 13.6 13.9 12.0 12.5 12.1 13.1 11.7 10.4 9.5 10.3

421010004 Philadelphia 16.5 14.4 14.8 13.9 14.2 13.5 13.7 13.0 10.8 10.7 13.2

421010024 Philadelphia 14.6 13.7 13.2 12.8 12.9 12.4 12.9 12.0 9.9 9.6

-

421010047 Philadelphia 17.0 15.6 16.1 14.4 15.1 15.4 14.3 13.5 11.1 11.0 11.4

421010055 Philadelphia ND ND ND ND ND ND ND 13.5 11.3 11.3 11.4

421010057 Philadelphia ND ND ND ND ND ND 12.0 13.3 11.1 10.9 11.4

421011002 Philadelphia ND ND ND ND ND ND ND ND ND ND 9.0

NAA Av e rage

- all monitors 15.5 14.0 14.6 13.7 14.4 12.7 13.5 12.7 10.8 10.7 10.8

 Monitor 421010055 in Philadelphia County, Pennsylvania, started operating in 2008.

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

 Monitor ID 421011002 started operating in January, 2011.

 ND = m onitor did not operate or was not in existence in that year.Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

25 Figure 4.2 Philadelphia NAA

– 2001 to 2011 annual PM 2.5 trends

Figure 4

- 3 also shows 2001

- 2011 monitoring data, but instead of showing each monitor trend, all the monitors in the Philadelphia NAA were averaged together, by year to give a “summary

- view

. ”

Figure 4. 3 Philadelphia NAA

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

– 1997 Annual PM 2.5 NAAQS

26 Figure 4

- 4 shows the downward trends since 2001 using 3

- year rolling

- average s ( i.e., design values )

.

Figure 4. 4 Philadelphia N AA

– 2003 to 2011 PM 2.5 3

- Year Rolling Averages

Figure 4

- 5 is a variation on Figure 4

- 4 and plots the average design values per year, calculated from all monitors in the Philadelphia NAA.

Figure 4

. 5 Philadelphia NAA

– Average of Design Values (all monitors )Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

27 S ome of th e se air quality improvements were a result of e missions re du c tions which w er e d u e to the a

ppli ca tion of ti g ht e r fe d era l e mission st a nd ar ds on motor v e hi c l e s a nd f u e ls, a nd

some due to the re qui r e m e nts of the fe d era l NOx S I P Ca ll. Others were due to Delaware

specific control measures. S ec tion 4.3 of this plan d e s cr ib e s th e se re d u c tions in mo r e d e t a il,

a long with a n e x pl a n a tion of th e ir r e g ul a to r y st a tus.

One of the way s s tates 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 E missions I n v e nto r y Gui d a n c e r e qui re d th a t st a t e s with PM 2.5 NAA QS

nonattainment area s p re p ar e a nd submit a 2002 b a se y e a r in v e nto r y of a nt h r opog e nic sou rce s of

di r ec t PM 2.5 a nd precursors of s e c ond a r y PM 2.5 e missions, n a m e l y N O

x a nd S O 2

. The 2002 b a se

y e a r inv e nto r y in c lud e d e missions fr om point, non

- point , o n

- r o a d mobile a nd non

- r o a d mobile

e missions. The 2002 base year was used in Delaware’s A nnual PM 2.5 A ttainment D emonstration

SIP (submitted to EPA in April, 2008 ) . It was picked as the base year for th is annual redesignation request because it reflects one of the years in which Delaware was designated nonattainment (e.g., 2001

- 2003).

The Philadelphia NAA came into attainment for the 1997 annual PM 2.5 NAAQS based on

2007

- 2009 monitoring data. Delaware chose to use 2007 as the attainment year (e.g., o ne of the three years during which the area attained the standard ) , from which future inventories are projected in the accompanying maintenance plan.

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 Development of the 2007 Emission Inventory for Regional Air Quality Modeling in the Northeast / M id

- Atlantic Region Version 3.3. January 23, 2012

. The

MARAMA 2007 TSD includes annual emissions for carbon monoxide (CO), ammonia (NH 3 ), 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: fi lterable and condensable particles with an aerodynamic diameter less than or equal to a nominal 10 and 2.5 micrometers (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 and PM

CON, and PM25

- PRI equals the sum of PM25

- FIL and PM

- CON.

However, for purposes of this plan , Delaware only provides NO

x , PM 2.5 and SO 2 , because

as Delaware determined in its 2008 PM 2.5 Attainment Demonstration , only those pollutants are regulated as PM 2.5 and PM 2.5 precursors.Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

28 T a ble 4

- 3 s u mm ar i z e s 2002 9 and 2007 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

. 10

T a b le 4

- 3 New Castle County 2002

- 2007 E m issio n Changes

Source

Sector NOx PM 2.5 SO 2

2002 2007 Δ

(tpy) Δ (%) 2002 2007 Δ

(tpy) Δ (% ) 2002 2007 Δ (tpy) Δ (% )

Point 9,157 6,635 2,522 28% 1,733 1,335 398 23% 47,070 13,380 33,690 72%

Non

- point 1,513 1,293 220 15% 1,073 1,207

- 134

- 12% 780 630 150 19%

On

- road 11,799 10,577 1,222 10% 209 324

- 115

- 55% 326 100 226 69%

Non

- road 8,279 4,580 3,699 45% 415 327 88 21% 2,061 1,118 943 46%

All Sectors 30,748 23,084 7,664 25% 3,430 3,193 237 7% 50,237 15,228 35,009 70%

By c omp ar ing the 2002 and 2007 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 237 tons p e r y ea r, and that NOx e missions d e cr e a s e d b y 7,664 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 point and non

- r o a d mobile sou rce s. S O 2 e missions

d e c rea s e d much more significantly

- b y 35,00 9 tons p e r y ea r

- l a r g e l y due to re du c tions fr om the Delaware City Refinery controls put into effect in 2006 as a result of a Federal Consent decree.

Th e s e si z ea

ble e m issions re du c tions, a s w e ll a s c o r re spon d ing re d u c tions in upwind area s a nd

oth e r n e ar b y st a t e s , re sult e d in a subst a nti a l imp r ov e m e nt in PM 2.5 a ir qu a li t y in the Philadelphia

NAA , ultim a t e l y re sulting in a tt a inm e nt o f the 1997 PM 2.5 NAAQ S

.

4.3 Enforceable and Permanent PM 2.5 , NOx and SO 2 Measures that Contributed to Improved Air Quality after 2002 and through 200 7

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, State

- 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 emission control, State

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

9 The 2002 annual PM 2.5 bas e year and emission controls are discussed in more detailed in Delaware’s PM 2.5 Attainment Demonstration , submitted to EPA in April, 2008.

10 The 2002 emission summary has not been revised to incorporate the higher emissions estimates for on

- road mobile sources using the new EPA ’s MOVES model, and from the new paved road dust equation

. The 2007 emissions inventory does include the higher emission factors for NOx and PM 2.5 from the EPA MOVES model and

from the new pa ved road dust equation. This makes the 2002 base year NOx and PM 2.5 emissions lower than they would be if using the 2007 methodologies; and the actual emission reductions between 2002 and 2007 are greater
than what is shown in Table 4

- 3.Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

29  7 DE Admin. Code 1142

. Section 1, Control of NO X Emissions from Industrial Boilers,

NO X emission control, Effe ctive December 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 ).

 Consent Decree with Premcor Refinery at Delaware City (formerly Motiva Enterprises),

New Castle Cou nty, Control of SO 2 , and NO X Emission s from Boilers and Heaters,

Effective 2006

, Civil Action No. H

- 01

- 0978 lodged in the United States Court for the Southern District of Texas on March 21, 2001 (the federal consent decree )

.

 7 DE Admin

. Code 1131, Low Enh an ced 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).

4.3.2 Federal Control Measures

Area sources

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

codified 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 representative model lines tested by EPA

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

. For the general woodstoves and f ireplaces category (SCC 2104008000) USEPA computed a weighted average distribution based on 19.4% fireplaces, 71.6% old woodstoves, 9.1% new woodstoves using 2002 Platform emissions for PM 2.5 . These fractions are based on the fraction of emissions from these processes in the states that did not have the “general woodstoves and fireplaces” SCC

in the 2002 NEI.

Control Programs Included in the NMIM/NONROAD Model

Under 40 CFR Part 89, EPA a dopted 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 an d 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 vehi cles. 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 Kilowa ttsDelaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

30 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 af fected vary by hp category

as follows:

 50

- 100 hp: Tier 1,1998; NOx only

 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 Nonroad 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) engi nes. The Pha se 1 standards beca me effective in

1997 for:

 Class I NHH engines (<225cc),

 Class II NHH engines (≥225cc),

 Cla ss III HH engines (<20cc), and

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

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

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. Octob er 4, 1996. This rule establishes exhaust emission standards for HC+NOx for personal watercraft and outboard (PWC/OB)

marin e SI engines. The standards were phased in from 1998

- 2006.

Control of Emissions of Air Pollution from Nonroad Diesel Engines 63 F R 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 even more stringent Tier 3 standard s 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

 25

- 50 hp: Tier 1 , 1999; T ier 2, 2004; no Tier 3

 50

- 100 hp: Tier 2, 2004; Tier 3, 2008

 100

- 175 hp: Tier 2, 2003; Tier 3, 2007

 175

- 300 hp: Tier 2, 2003; Tier 3, 2006

 300

- 600 hp: Tier 2, 2001 , Tier 3, 2006

 600

- 750 hp: Tier 2, 2002; Tier 3, 2006

 >750 hp: Tier 2, 2006, no Tier 3Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

31 This 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) bec a me effective on August 1, 2007 (or August 1, 2003 for any engine initially produced on or after that date). The

Phase 2 standards fo r 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

- Igni tion 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 i n from 2002

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

- 2007 for Class V engines.

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 spark

- 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 permeation, diurnal emissions and running loss emissions.

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

- highway motorcycles, and all

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

- in from 2006

- 2012.

For off

- highway motorcycles, HC +NOx and C O exhaust emission standards were phased

in from 2006

- 2007. For ATVs, HC+NOx and C O exhaust emission standards were phased in from 2006

- 2007. Evaporative emission standards for fuel tank and hose permeation apply to all recreational vehicles be ginning in 2008.

3) Exhaust emission standards for HC+NOx, CO, and PM for recreational marin e diesel engines over 50 hp during 2006

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

Control of Emissions of Air Pollut ion 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 engines covering all hp categories (except marine and locomotives), and also reg ulates nonroad diesel fuel sulfur content.

1) The Tier 4 start dates and pollutants affected vary by hp and tier as follows:Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

32 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. ** 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 f

or current highway diesel fuel. Second, starting in 2010, fuel sulfur levels in

most nonroad diesel fuel will be reduce d to 15 ppm.

Control of Emissions from Nonroad Spark

- Ignition Engines and E quipment; Final Rule (Bond Rule), 73 FR 59034 October 8, 2008. This rule establishes exhaust and evaporative

standards for small S I 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

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

standards that were phased

- in from 2010

- 2011. New evaporative standards were also adopted for all marine SI engin es that control fuel hose permeation, diurnal emissions, and fuel tank permeation emissions. The hose permeation, diurnal, and tank permeation standards take effect in 2009, 2010, and 2011, respectively

.Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

33 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 2007 model

year. This ru le included standards for NO X and non

- methane hydrocarbons ( NMHC) of 0.20g/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% reduct ion in the sulfur content of highway diesel fuel

-- from levels of 500 parts per million (p pm) 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 p rogram are reflected in the 2002 base year inventory and the 2007 attainment year inventory. This

federal ly implemented program affects light duty vehicles and light duty trucks. The regulations 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 co dified 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 is modeled after the California LEV II

standards. The Tier 2 program allows manufactu rers 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 Program: Under the OTC National Low Emission Vehicle (NLEV) program,

automobile manufact urers 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 1999 all new vehicles sold in the region must comply with the more stringent LEV stan dards. Once manufacturers committed to the program, the standards became enforceable in the same

manner in which other federal motor vehicle emission control requirements were enforceable. The program was in place nationwide for model year 2001, and the benefits of this program are

reflected in the 200 2 base year inventory and the 200 7 attainment year inventory.

In addition al to the federal Tier 1 and 2 p rogram s , NLEV, and the 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 pr ograms, as required under Section182 and

202 of the CAA. Before 1994, basic automobile emissions testing checked only tailpipeDelaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

34 emissions while idling and sometimes at 2,500 rpm. For Delaware, the Low Enhanced I/M procedures includes the use of On Board D iagnostic (OBD) system evaluations, fuel system pressure test and a gas cap test. The procedures also inclu de an anti

- tampering inspection of the catalytic converter, gas cap and fuel inlet restrictor. The OBD evaluations provide a more complete inspecti on, 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 Requirements

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 su bject of disapproval ; a finding of failure to submit or to implement the SIP; or partial, conditional, or limited approval.

For purposes of redesignation, state s must also meet all requirements of Section 110 and Part D of the CAA that were applicable p rior to submittal of the complete redesignation request. The general elements required in a SIP are listed in Section 110(a). These elements include procedures for air quality monitoring and modeling; criteria for establishing stationary source controls, monitoring and reporting; implementation of permitting programs under Part C (Prevention of Significant Deterioration or PSD) and Part D (New Source Review or NSR); and provisions for public involvement. Subpart 1 of Part D consists of general requirement s 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 ). However, for the purpose of impleme nting the 1997 PM 2.5 standard, the EPA ’s Implementation Rule stated Subpart 1, rather than Subpart 4, is appropriate for the purpose of implementing PM 2.5 (72 FR 20589).

5.2 Delaware Approach

Delaware submitted its annual PM 2.5 attainment demonstration to EPA on April 5, 2008. It was subsequently revised to update onroad mobile emissions based on the MOVES model, and

submitted to EPA on May 3, 2012. EPA has not complete d rulemaking on the 2008 SIP or the May 3, 2012 Revision to the 2008 PM 2.5 SIP

. However, EPA Region 3 has informed D AQ that they have a Consent Decree which requires final action on Delaware’s attainment plan by March 29, 2013

. 11 Therefore, Delaware expects that the 2008 attainment demonstration and its May 3,

20 12 revision will be fully approved by the EPA as required under Section 110(k ).

Section 110(a) of the CAA contains the general requirements for a SIP. Delaware concludes that, as EPA has stated in previous rulemaking

, 12 only the section 110 and part D

requ irements that are linked with a particular area’s designation are the relevant measures which

11 EPA Region 3 comments, M. Pino (October 22, 2012)

12 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)Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

35 DAQ may consider in evaluating a redesignation request. Further, DAQ believe s 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 redesignation. DAQ understands that a state remains subje ct to these requirements 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 Philadelphia NAA. Therefore, DAQ believes that these

SIP e lements are not applicable 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 April of 2008

, DAQ submitted to EPA the Delaware State Impl ementation Plan for Attainment of t he PM 2.5 Annual National Ambient Air Quality Standard

- Attainment Demonstration . Mobile budgets in the 2008 SIP were revised in January of 2012 in the SIP entitled, Proposed R evision to Delaware’s 2008 State Implementation Plan f or Attainment of the PM 2.5 Annual National Ambient Air Quality Standard

- Attainment

Demonstration

, to account fo r changes in the new EPA model

, MOVES . This plan demo nstrated

attainment of the annu al P M 2.5 NAAQS by 2010 based on implementation of a combination of federal measures, other regional controls, mobile source controls and local controls on industrial

sources of direct PM 2.5 , NOx and SO 2

. In addition, t he base year inventory requirement under

CAA 172(c)(3) will be met when EPA fully approv es the 2002 base year inventory submitted

with the Delaware 2008 State Implementation Plan for Attainment of the PM 2.5 Annual National Ambient Air Quality Standard

- Attainment Demonstration

. and the 2012 Prop osed Revision to

Delaware’s 2008 State Implementation Plan f or Attainment of the PM 2.5 Annual National Ambient Air Quality Stan dard

- Attainment Demonstration.

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. Under the separate general and transportation conformity rules, federal agencies must work with State, 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 conformed 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);Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

36  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 engaged 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 t hat would exceed conformity threshold levels 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 demo nstrate that the project emissions would conform, 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 app roving SIPs, which are prepared and submitted to EPA by state environmental agencies.

Transportation Conformity

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

- related highway construction will not interfere with achieving NAAQS

. The concept of transportat ion 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 Legacy for Users (SAFETEA

- L U)

, define the framework for effective integration of transportation and air quality planning.

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

- road mobile (highway) source emissions evaluated from the Transportation 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 air quality goals.

As d iscussed in more detail in Section 8 of this plan, Delaware revised its 2008 A nnual

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 t ransportation conformity. D evelopment of the 2008 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 Metropolitan Planning Organization 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 Apri l 2008 PM 2.5 Attainment DemonstrationDelaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

37 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

. 13 However, EPA has not completed rulemaking on the 2008 SIP and the May 3, 2012 Revi sion.

Delaware’s SIP contain s 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 1135

, Conformity of General Federal Actions to the State Implementation Plans

, (Regulation for General Conformity) , w hich was a pproved into the Delaware SIP by EPA on 08/11/2010. ( 75 FR 48566 ) Transportation conformity requirements ar e contained in 7 DE

Admin. Code 1132

, Transportation Conformity

, which was 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 e mission 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 add itional 10 years following the first 10

- year period.

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 Directions 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 Ambie nt 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 workgro up, emails and conference calls, as well as reviewing and providing comments on the Technical Support Documents developed through the regional modeling efforts. EPA requires the following provisions to ensure maintenance of the NAAQS:

 The state must deve lop 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

13 This annual maintenance plan SIP revision 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, submit ted to EPA in May, 2012.Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

38 pollutant or its precursors will not exceed t he 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 tracked.

 Contin gency 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 A pproach

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 over the 10 years following redesignation approval will remain below the 2007 attainment year levels while allowing for growth in population and vehicle miles trav eled. The period covered by this maintenance plan is 2007 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 1997 PM 2. 5 NAAQS. This attainment inventory consists of the actual 2007 emissions , i.e. a year during the three

- year period

associated with the 2007

- 2009 monitoring data showing attainment of the 1997 PM 2.5 NAAQS. The plan includes a demonstration that emissions will remain beneath the 2007 levels for a 10

- year period following redesignation, by keeping in place key elements of the current federal and state regulatory programs and putting in place additional controls.

As d iscussed in Section 3.5.1 , t he State of Delaware will continue to operate and maintain its air quality monitoring network. Delaware has the legal authority to implement and enforce specified measures necessary to attain and maintain the NAAQS.

In addition to maintaining key elements of its re gulatory program, the State of Delaware will acquire air quality monitoring and source emissions data to track attainment and maintenance. The maintenance plan includes contingency measures, as necessary, to promptly correct any NAAQS violation that occur s 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.Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

39 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 EPA 's most recent guidance on emission inventories for nonattainment areas available at the

ti me, and should include emissions during the time period associated with the monitoring data showing attainment of the 1997 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 annual emissions of SO 2 , NO X , and primary PM 2.5 in units of tons per year (t py) during the attainment year.

7.2 Delaware Approach

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

the level of emissions sufficient to achieve the 1997 PM 2.5 NAAQS. The attainment inventory

consists of actual emiss ions for a year during the three

- year period associated with the monitoring data showing attainment of the PM 2.5 standard, that is, 2007 for the annual NAAQS maintenance plan . The 2007 inventory is appropriate to use because it represents the typical

inve ntory for the three

- year period demonstrating attainment of the standard. The 2007 inventory is consistent with EPA inventory guidance; is based on annual emissions of SO 2 , NO X , and primary PM 2.5 during 2007; and contains a list of sources and emissions i n tpy.

7.3 2007 Att a inm e nt Y ea r I nv e nt or y

The Delaware DAQ , in conjunction with MARAMA, New Jersey and Pennsylvania DEQs

p r e p are d a c omp re h e nsive e missions inv e nto r y f or each county in 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 2007

. MARAMA and the Philadelphia NAA air control agencies s e l ec t e d 20 0 7 e missions d a ta to re p r e s e nt the “a tt a inm e nt y e a r ” sin c e it falls

within t h e 3

- y ea r p e r iod ( 2007

- 200 9 ) whi c h d e monst ra t e s mo n ito re d a tt a inm e nt . Furthermore,

2007 was planned as the base year for the Ozone Transport Commission’s (OTC) modeling work for ozone State Implementation Plans (SIP), and as such has undergone extensive quality

assurance

.

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. P oint sou rc e in f o r m a tion w a s c ompil e d

fr om 200 7 Annu a l Emissions R e po r ts ( AE R s) submitt e d to t h e Delaware DAQ b y e missions

sou rc e s. 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 2 007 . 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 2007 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 07 using EPA ’ s National Mobile Inventory ModelDelaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

40 (NMIM) e missions mod e l. Emissions sou rce s su c h a s 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) w er e n ot in c lud e d in the N MIM mod e l a nd w er e ca l c ul a t e d s e p a r a t e l y

. B i o g e nic e missions w er e not in c lud e d in th e se summ a r i e s. Details of how the inventory was developed can be found in following document: Technical Support Document for the Development of the 2007 Emission Inventory for Regional Air Quality Modeling in the Northeast

/ Mid

- Atlantic Region

.

T a ble 7

- 1 S umm ar i z e s the 2007 e missions e stim a t e s f or the New Castle County portion of

the Philadelphia NAA

.

T ab l e 7

- 1 2007 New Castle County Emissions (tpy )

Source Sector 2007 Annual Emissions (TPY)

NOx PM25 SO2

Area 1,293 1,207 630

Nonroad MAR 2,825 171 1,027

Nonroad NMIM 1,755 156 91

Onroad MOVES 10,577 324 100

Point EGU 2,865 519 9,119

Point nonEGU 3,770 816 4,261

All Sectors 23,084 3,193 15,228

Note: due to rounding, total tpy may be off by 1 ton

.

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 states 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

with current EPA guidance. Enforceability through regulations must also be demonstrat ed.

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 r eductions are otherwise

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

– 1997 Annual PM 2.5 NAAQS

41 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 reflected in the SIP and all applicable permits have been modified accordingly.

8.2 Delawar e 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 intends to submit this Plan in 2012, and EPA has a maximum of 18 months to approve it, 15 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 , D AQ p r oj ec t e d PM 2.5 , NO x , a nd S O 2 e mis s ions f

or
2025 to represent the end year of the maintenance plan

. DAQ 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 2007 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 2007

.

8.2.1 2017 and 2025 Projection Inventories

As was done with the 2007 attainment year, 2017 and 2025 projection inventories were develop through the MARAMA regional planning process. For 2025 emi ssion projections, the emission methodologies and growth factors can be found in the Technical Support Document for the Development of the 2025 Emission Inventory for PM 2.5 Nonattainment Counties in the MANE

- V U 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).

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 2007 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

. EGU emissions were projected using Department of Energy 2011 Annual Energy Outlook growth factors, with control factors applied due to Delaware’s EGU regulation s ( 7 DE

Admin Code 1146 Electric Generating Unit Multi

- Pollutant Regulation , and 7 DE Admin

Code 1148 Control of Stationary Combustion Turbine Ele ctric Generating Unit Emissions )

. O ff

- r o a d e mis s ions p r oj ec tions w er e d e v e lop e d using the g r owth fac to r s c ont a in e d in EPA ’ s
N MIM mod e l.

For mobile budget purposes Delaware is using the 2012 mobile emissions from its PM2.5 Attainment Demonstration Revision, submitted to EPA on May 3 , 2012

. Delaware used 2012 mobile emissions in lieu of projected mobile emissions because:

15 CAA Section 107 (d)(3)(D)Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

42 1. The y are based on the most up

- to

- date mobile source assumptions available.

2. 2012 emission budgets are 41% and 39% less than the onroad NOx and PM 2.5 found in

the 2007 attainment year

. (see table 8

- 2 and 8

- 3)

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

The 2012 emissi on inventory modeling of the on

- road mobile sou rce 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

- road 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 provided 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 generate monthly emissions for PM 2. 5 , oxides of nitrogen and SO 2

. After QC/QA reviews and revision by DAQ staff the emission data were finalized, and included in the final inventory. The on

- road mobile source controls for New Castle County in the input files for the 2012 MOVES model runs i nclude 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.

5. Heavy Duty Diesel Rule/low Sulfur 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 7, 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 2007 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 2007 a nd 2025 , i.e. 40% and 54% for NOx and SO2, respectively. PM 2.5 d ecrea s es less significantly (14%). 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 2007

. 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.Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

43 T a ble 8

- 1 Co m p ar ison of e missions f or t he y e ar s 2007, 2017 a nd 2025

SECTOR NO X PM 2.5 SO 2

2007 2017 2025 2007 2017 2025 2007 2017 2025

Area 1,293 1,295 1,296 1,207 1,235 1,310 630 521 469

Nonroad MAR 2,825 1,810 1,279 171 61 44 1,027 112 37

Nonroad

- NMIM 1,755 997 837 156 106 103 91 2 3

Onroad MOVES 10,577 6,273 6,273 324 199 199 100 98 98

Point

– EGU 2,865 1,698 1,758 519 502 520 9,119 2,419 2,572

Point

- nonEGU 3,770 2,402 2,355 816 742 716 4,261 3,843 3,780

All Sectors 23,084 14,475 13,797 3,193 2,844 2,893 15,228 6,995 6,958

T a ble 8

- 2 Reductions and % Change of NOx e missions f or t he y e ar s 2007, 2017 a nd 2025

NOx Reduction (tpy) Change (%) Reduction (tpy) Change (%)

Sector 2007 2017 2025 2007

- 2017 2007 to 2017 2007 to 2025 2007 to 2025

Area 1,293 1,295 1,296

- 3 0.2%

- 3 0.2%

Nonroad MAR 2,825 1,810 1,279 1,015

- 35.9% 1,546

- 54.7%

Nonroad

- NMIM 1,755 997 837 758

- 43.2% 918

- 52.3%

Onroad MOVES 10,577 6,273 6,273 4,304

- 40.7% 4,304

- 40.7%

Point

– EGU 2,865 1,698 1,758 1,167

- 40.7% 1,107

- 38.7%

Point

- nonEGU 3,770 2,402 2,355 1,368

- 36.3% 1,415

- 37.5%

Total tpy 23,084 14,475 13,797 8,609

- 37% 9,287

- 40%Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

44 T a ble 8

- 3 Reductions and % Change of PM 2.5 e missions f or t he y e ar s 2007, 2017 a nd 2025

PM2.5 Reduction (tpy) Change (%) Reduction (tpy) Change (%)

Sector 2007 2017 2025 2007 to 2017 2007

- 2017 2007 to 2025 2007 to

2025

Area 1,207 1,235 1,310

- 28 2.3%

- 103 8.5%

Nonroad MAR 171 61 44 110

- 64.2% 126

- 74.0%

Nonroad

- NMIM 156 106 103 51

- 32.5% 53

- 34.0%

Onroad MOVES 324 199 199 125

- 38.6% 125

- 38.6%

Point

– EGU 519 502 520 17

- 3.2%

- 1 0.2%

Point

- nonEGU 816 742 716 75

- 9.1% 100

- 12.2%

Total tpy 3,193 2,844 2,893 349

- 11% 301

- 9%

T a ble 8

- 4 Reductions and % Change of SO 2 e missions f or t he y e ar s 2007, 2017 a nd 2025

SO2 Reduction (tpy) Change (%) Reduction (tpy) Change (%)

Sector 2007 2017 2025 2007 to 2017 2007

- 2017 2007 to 2025 2007 to 2025

Area 630 521 469 109

- 17.4% 161

- 25.6%

Nonroad MAR 1,027 112 37 915

- 89.1% 990

- 96.4%

Nonroad

- NMIM 91 2 3 89

- 97.3% 88

- 96.5%

Onroad MOVES 100 98 98 2 2.4% 2 2.4%

Point

- EGU 9,119 2,419 2,572 6,700

- 73.5% 6,547

- 71.8%

Point

- nonEGU 4,261 3,843 3,780 418

- 9.8% 482

- 11.3%

Total tpy 15,228 6, 995 6,958 8,234

- 54% 8,271

- 54%

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 wo rsen air quality or interfere with an area’s continued compliance in regards to the 1997 PM 2.5 NAAQS. The federal transportation conformity rule is codif ied in 40 CFR Part 93, subpart a , entitled Determining Conformity of Federal Actions to State or Feder al 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 withDelaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

45 federally approved air quality maintenance plans. The responsible tra nsportation planning

entit ies for the New Castle County, Delaware potion of the Philadelphia 1997 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 estimates 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 determination 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 P M 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, 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 is establish ing 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 pollutants 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 circumstanc es:

40 CFR93.109 (k) Areas with insig nificant motor vehicle emission

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 through the adequacy or approval process that a SIP

demo nstrates 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 unreasonable 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 emissions in the context of the total SIP inventory, the

curr ent 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 growth of motor vehicle emissions

.

A motor v e hi c le e missions bud g e t is th a t p o 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

16 As discussed in Delaware’s 2008 Annual PM 2.5 Attainment Demonstration, and revised in Delaware’s Final

Revision to Delaware’s 2008 State Implementation Plan f or 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

– 1997 Annual PM 2.5 NAAQS

46 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))

.

The 2012 budgets established in Delaware’s May 3, 2012 PM 2.5 Attainment

Demonstration SIP revision (submitted to EPA on 5/ 3 /2 0 12) represent a level of mobile emissions lower than what existed during the years attainment was reached (i.e., 2007

- 2009 and

2008

- 2010). Further, mobile reductions are not necessary to demonstrate maintenance, and the

2025 NOx and PM 2.5 emissions are well below 2007 levels. As such, t here is no need to develop new mobile budgets a t this time. Therefore, Delaware proposes to use existing 2012 budgets for the 2017 interim year, as well as the end year, 2025

. 17

Table 8

- 5 summarizes the budgets for ea ch relevant year.

Table 8

- 5 New Castle County Mainten ance Plan On

- Road 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

MOV E S mod e l 2012 inputs a nd outputs for NOx and PM 2.5 may be found in Delaware’s

final r evision to the 2008 State Implementation Plan f or Attainment of the PM 2.5 Annual

National Ambient Air Quality Standard

- Attainment Demonstration . Th at SIP revision was

submitted to EPA on May 3 , 2012

.

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 continue to 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 programs, EPA has approved these programs

into the Delaware SIP. The State of Delaware commits to continu e to implement and enforce

17 DAQ may r equire new budgets should the Philadelphia maintenance area lapse into nonattainment (see Section
10)Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

47 these program s as appropriate to ensure that r eductions assumed in 2017 and 2025 will be

achieved.

Tables 8

- 2 through 8

- 4 show that that projected 2007 to 2025 reductions are 9,287 tpy for NOx, 301 tpy for PM 2.5 and 8,2 7 1 tpy for SO 2 . In terms of percent reductions, this equates to 40%, 9% and 54 % reductions of NOx, PM 2.5 and SO 2 , respectively. The same tables show projections from 2007 to the 2017 inter im year. 2007

- 2017 reductions are 8,609 tpy for NOx, 349 tpy for PM 2.5 and 8,23 4 for SO 2

. In terms of percent reductions, this equates to 37 %, 11 % and 54% 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

controls ex ist for a certain source category). DAQ calculated reductions that will occur after

2007 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. The same rationale applies to residential wood combustion, which also relied on an EPA model. Table 8

- 6 shows the reduction due to controls and the control measure by source sector.

Looking at Table 8

- 6 , it is evident that all but the area source sectors had significant decreases for NOx, SO 2 and/or PM 2.5 due to control measures.

Table 8

- 6 2007 to 2025 Emission Reductions due to Control Measures

Source Sector NOx PM 2.5 SO 2

EGUs

DE Admin Code 1146 (Multi

- Pollutant Regulation) 1,240.8 10.5 6,562.4

nonEGU

Delaware City Refinery NOx CAP (1650 tpy) post

- 2015 1,157. 26 0.00 0.00

Reciprocating Internal Combustion Engines

- Maximum Achievable Control Technology, (RICE MACT) (76 FR 12863) 0.02 0.08 0.00

Ch r ysler Plant Shutdown /unit shutdown 6.50 0.89 16.64

AREA

RICE MACT 42.51 0.30 0.00

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). 5.00 76.6 4 0.8 4

Nonroad (NMI M model) 918 53 88Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

48 ONROAD (MOVES model) 4,304 125 2

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) 933 37 152

Control of Emissions From New Marine Compression

- Ignition Engines at or

Above 30 Liters per Cylinder(75 FR 22895) 631 90 836

TOTALS 9,241 394 7,660

8.2.4 Delaware

- specific NOx, PM2.5 or SO2 Control Measures (Effective Post 2007)

 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

, 18 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 Industrial 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 fo llowing New Castle County

facilities:

 Conectiv Delmarva Generation

- Del City

 Conectiv Delmarva Generation

- West Substation

 Conectiv Delmarva Generation

- Edge Moor

 Conectiv Delmarva Generation

- Christiana

 Conectiv Delmarva Generation

- Hay Road

Of these facilities, Edge Moor is the only one which had coal

- burning units and residual oil in 2007. The rest used either natural gas or distillate oil, and thus had small PM 2.5 and SO 2

18 Although effective in 2006, NOx controls were not required until January 1, 2009 and SO2 controls were not
required until January 1, 2012.Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

49 emissions in 2007 and are projected to have small emissions of PM 2.5 and SO 2 emissions in 2025. Consequently, Edge Moor was the largest EGU emitter, e.g. its 2007 emissions represented 90%, 92 % and 99.9% of NOx, PM 2.5 and SO 2 , respectively for all New Castle County EGUs. Because Units 3 and 4 were coal

- fired in 2007, and Unit 5 o perates primarily on residual oil, the Edge Moor facility is subject to 7 DE Admin. Code 1146, E GU Multi

- pollutant Regulation, 7 D E Admin. Code 1146

, is a non

- trading program/regulation that was established primarily as a measure to aid in the attainment o f the ozone and fine particulate matter ambient air quality standards.

7 DE Admin. Code 1146 will reduce 2007 EGU emissions by 1,241 tpy NOx, 10.5 tpy

PM 2.5 and 6,562 tpy SO 2 in 2025 (see Table 8

- 7). PM 2.5 emission controls are not directly regulated under 7 DE Admin. Code 1146, but are a co

- benefit of the 0.5% by weight low

- sulfur

residual oil limit on Unit 5.

Non

- EGU reductions

 Delaware Source Shutdowns (post

- 2007)

The Chrysler automotive plant ceased commercial operation in January, 2009. However, only a 25% reduction was applied, since Chrysler maintains 50% of the emission credits

and the Delaware Economic Development Office retains the remaining 25%.

Delaware Onroad

In additional to the federal Tier 1 and 2 programs, 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. Th e 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 som etimes at 2,500 rpm. Enhanced I/M procedures include the use of On Board Diagnostic (OBD) system evaluations. The OBD evaluations provide a more complete inspection, checking for excess evaporative emissions and other issues that might affect emissions f rom 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 o r Phased

- in Post 2007)

F ederal c ontrol m easures that are either effective or phased in after 2007 are the same as

those discussed in Section 4.3.2. Note that the Woodstove NSPS and m any of the nonroad and

onroad federal control measures have effective dates prior to, during

, or after 2007 . 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 nonroad 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 2007 attainment year.Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

50 8.2.6 Future Emissions Reductions Programs

Delaware

New Delaware regulations will reduce emissions of NOx, PM 2.5 and SO 2 eve n further, although these rules are not yet finalized and therefore were not considered in the 2017 and 2025

estimates included in this document. Measures under development or consideration are:

 Edge Moor Power Plant (fuel switch from coal to natural ga s)

 Low

- sulfur fuels

– statewide

Federal

Three new federal regulations may reduce emissions of SO 2 even further . These rules

were not considered in the 2017 and 2025 estimates included in this document. However, t hese

rules and the new SO 2 NAAQS each should facilitate significant further reductions, both within and outside the Philadelphia maintenance area

.

 Mercury and Air Toxics Rule: On March 16, 2011, EPA proposed the Mercury and Air Toxics Rule to reduce emissions of toxic air pollutan ts 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 gases, or alternative standards for

SO 2

. EPA estimates that this rule would affect app roximately 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 sources 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

- Commerc ial

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

. 19

 2010 SO 2 NAAQS: On June 2, 2010, EPA strengthened the primary NAAQS for SO 2 by revising the primary SO 2 st andard 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 hours and 30 ppb averaged over a year. Under the new standard’s proposed guidance, facilities emittin g 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

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

- making in March, 2013 (letter from Gina
McCarthy, EPA to Patricia T. Barmeyer. July 20, 2012)Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

51 implementation of the revised rulemaking will reduce emissions nationwide from major source boilers and process heater s by 47,000 tpy of PM, 440,000 tpy of SO2, and 7,000 tpy of VOCs.

 Tier 4 Non

- Road Diesel Engine Standards: On May 11, 2004, the EPA signed the final rule introducing Tier 4 emission standards, which are be ing 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 use of control technologies including advanced exhaust gas

after

- treatment.

8.2.7 C on t r ols to R e m a in in E ffec t

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 a nn u a l 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 is 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 to attainment Delaware 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 PM 2.5 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 , reductions from the c ont r ol of o r g a n i c s or ammonia, have not been relied upon in this maintenance plan, 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 emission 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 ma intain the 1997 annual NAAQS. In addition to m aintaining key elements of its regulatory program in place in Delaware’s SIP, Delaware will acquire ambient monitoring and source emission data to track 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 Annual Air Emissions Reporting Requirements Rule, or as required by federal regulation during the maintenance plan period. This includes developing annual in ventories for major point sources and a comprehensive periodic inventory covering all source categories every three years. TrackingDelaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

52 will include the evaluation of annual and periodic evaluations for any significant emission

increases above the 2007 attain ment 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, in c luding

p r ovisions f

or c onting e n c y m e a su re s th a t will be i mpl e m e nt e d if viol a tions of the a nnu a l 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 a nnu a l 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 tr iggered.

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 a nnu a l 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. 20 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

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. The Delaware DAQ a nti c ip a t e s th a t post

- 2007 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 annual 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, in the event of a future violation or exceedance of

the annual PM 2.5 NAAQS, the Delaware DAQ will use the following triggers (determination of when to start an action) and perform the following actions in acco rdance with the described schedule, as its contingency plan:

20 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 stil l be nonattainment. Therefore, for the purposes of this maintenance plan, the “Philadelphia Maintenance Area” also includes any areas of the Philadelphia NAA that have not been redesignated to attainment.Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

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

a. A warning level response shall be prompted whenever the annual mean PM 2.5 concentration of 15.1 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 PM 2.5 , NOx and SO 2 emissions increase more than 10% above the levels in the 2007 attainment year

emissions invent ory.

2. Action Level Response

An action level response shall be prompted whenever a two

- year average of the annual

mean PM 2.5 concentration is 15.1 μg/m 3 or greater occurs at any monitoring site within the Philadelphia maintenance area. A violation of the s tandard (three

- year average of 15.1 μg/m 3
or greater) shall also prompt an action level response.

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 Philadelphia 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 exceedance, 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;

• Activity data for relevant sources;

• Information 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 ot her related data to try to determine the cause of the violation.Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

54 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 impleme ntation as well as economic and social considerations. In the event that the trigger is not found to be due to an exceptional event, malfunction, or noncompliance with a permit condition or rule requirement, Delaware DAQ will work with the States of Penns ylvania and New Jersey, and the City of Philadelphia as necessary, to determine additional control measures needed to

assure future attainment of the 1997 annual PM 2.5 NAAQS.

Based on the results of the analysis, contingency measures will be selected fr om 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 a lready promulgated and schedule d to be implemented at the federal or state level at such time aft er 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. The selection between measures will be based

upon cost

- effectiveness, emissions reducti on potential, ease and timing of implementation, and other appropriate factors. Delaware will submit to EPA an analysis to demonstrate the proposed measures are adequate to return the area to attainment.

Adoption of any additional control measures will be subject to the 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 individual 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 implementation

A timeline for the development of NOx, 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 annual 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 Response

Should an action level response be triggered, implementation of necessary controls measures will take place as expeditiously as possible, but in no event later than 18 months after the Delaware DAQ makes a determination, based on quality

- assured ambient data, that a violation of the NAAQS has occurred.Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

55 Table 10

- 1 Schedule for Permit Revisions or Rule Revisions for Contingency Measures 21

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 Phila delphia MA from the programs and

emissions reductions identified in 10.2.5 of this document. 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 other 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.

 Vehicle inspection and maintenance program enhancements, addition of diesel vehicles, etc.).

 Alternative fuel and additional diesel retrofit programs for fleet vehicle operations.

 Require N Ox or SO 2 emission offsets for new and modified major sources.

 Increase the ratio of emission offsets required for new sources.

 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.

21 This schedule initiates with certification of ambient air quality monitoring data indicating a violation of the 1997

annual 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

– 1997 Annual PM 2.5 NAAQS

56 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 to attainment, 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 a nnu a l 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 this 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 22 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

.

 A p ub l ic h e ar i n g is r e qu i r ed for th e a d opt i o n of all D el awar e S t at e Im p lem e nt a t ion P lans and Regu l ations, and was held on Oc tober 23, 2012.

 A 30

- day public co mm e n t p er iod w a s provided 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.

12 Conc l u s ions

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 1997 a nnu a l 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 1997 a nnu a l 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

1997 a nnu a l 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

22 TITLE 29, General Regulations For State Agencies, Chapter 101. Administrative Procedures, Subchapter

II, Agency Regulations

.Delaware Redesignation Request and Maintenance Plan

– 1997 Annual PM 2.5 NAAQS

57 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 1 997 a nnu a l

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 complia nce (maintenance), with the standard. Furthermore, emission projections in the Maintenance Plan indicate that NOx, PM 2.5 and SO 2 emissions will continue to decline, ensuring that the area continues to maintain compliance with the standard and provide for an increased margin of safety.

The Delaware DAQ has prepared a comprehensive emissions inventory of PM 2.5 and its precursors for the base year, 2002 to meet CAA 172(c)(3) requirements, as submitted to EPA April, 5 2008, in the Delaware State Implementati on Plan for Attainment of the PM 2.5 Annual National Ambient Air Quality Standard

- Attainment Demonstration

.

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 attainment year (2007), 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 2007 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. 23

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.

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 a nnu a l P M 2.5 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.

Consist ent with the authority granted to EPA , the State of Delaware requests that New Castle County, Delaware be redesignated to attainment for the 1997 annual fine particles standard simultaneously with EPA approval of this Delaware State redesignation request a nd annual PM 2.5 Maintenance Plan for the New Castle County portion of the Philadelphia NAA.

23 Based on MARAMA work, and consultation with PA and NJ, emissions for all of the Philadelphia NAA will
decrease significantly by 2 017 and 2025.