## 200 8 Attainment Year State Implementation Plan Emissions Inventory for PM 2.5 

## , SO 2 

## and NO
x



## New Castle County, Delaware



# F I N A L R E P O R T

Submitted to:

U.S. Environmental Protection Agency

Region 3

– Philadelphia, PA

Prepared by:

Departme nt of Natural Resource s & Environmental Control

Division of Air Quality

Emission Inventory Development Program

655 S. Bay Road Dover, DE 19901

October 2 , 20 122008 N EW C ASTL E C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

ii ACKNOWLEDGEMENTS

Co l lin O’Mara Secretary, Department of Natural Resources and Env ironmental Control

Ali Mirzakhalili, P.E.

Director

, Division of Air Quality

Ronald A. Amirikian Program Manager, Air Quality Planning Branch

Project Manager & Editor

David F. Fees, P.E. Manager, Emission Inventory Development (EID) Program

Principa l Contributors (EID Program)

Marian A. Hitch

Senior Environmental C ompliance Specialist

John L. Outten

Senior Environmental Scientist

Jeffrey P. Bendelewski Engineer

Mark A. Prettyman

Senior Environmental Scientist

The EID Program wishes to acknowledge the assistance o f the staff of the Engineering and Compliance Branch within the Delaware Division of Air Quality for their assistance in review of emissions data reported by permitted facilities.2008 N EW C ASTL E C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

iii TABLE OF CONTENTS Page

Acknowledg ements

................................................................................ ii

List of Tables

......................................................................................... v List of Figures

......................................................................................... v i Acronyms & Abbreviations

... .................................................................... vii

SECTION 1

– OVERVIEW AND SUMMARY

1.1 Project Ma nagement

..................................................................... .. 1

- 2

1.1.1 Project Manager

.............................................................. 1

- 2

1.1.2 Point Sources Technical Lead

............................................ 1

- 2

1.1.3 Point Sources Support

..................................................... 1

- 2

1.1. 4 Non

- point and Off

- road Sources

... ....................................... ........ 1

- 2

1.1. 5 On

- road Mobile Sources

......... ............................................ 1

- 3

1.2 Inventory Planning

....................................................................... 1

- 3

1.2. 1 Inventory Parameters

.............................................................. 1

- 3

1.2. 2 Data Collection and Management

............................................ 1

- 4

1.3 Inventory Development

... ........................................................... 1

- 4

1.4 Emissions Summary

........................................................................ 1

- 5

1.5 References

................................................................................. 1

- 7

SECTION 2

– STATIONARY POINT SOURCES

2.1 Reporting Criteria

........................................................................ 2

- 1

2.2 Initial List of Facilities

............ ................................................... 2

- 2

2.3 Facilities Inventoried

........................................................................ 2

- 2

2.4 Survey Methods

........................................................................ 2

- 3

2.4.1 Electronic Reporting

............................................................... 2

- 4

2.4.2 Activity Data Reporting Forms

............................................. 2

- 4

2.4.3 Other Methods

............................................................... 2

- 4

2.5 Data Collection

........................................................................ 2

- 4

2.5.1 On

- line Reporting

............................................................... 2

- 5

2.5.2 Activity Data Reporting Forms

............................................. 2

- 7

2.6 Inventory Tracking

.................................... .................................... 2

- 7

2.7 Administrative Review

............................................................... 2

- 8

2.7.1 Administrative Review of On

- line Submissions

............ ............... 2

- 8

2.7.2 Administrative Review of Activity Data R eporting Forms

.................. 2

- 9

2.8 Reported Data and Estimating Emissions

............................................. 2

- 9

2.8.1 Emission Estimation Methods

............................................. 2

- 1 0

2.9 Technical R eview of Submitted Data and Information

........................ 2

- 1 1

2.9.1 Facility General

............................................................... 2

- 1 2

2.9.2 Group/Point (Emissions Unit)

..................... ........................ 2

- 1 2

2.9.3 Process Unit

........................................................................ 2

- 1 2

2.9.4 Stack Parameters

............................................................... 2

- 1 32008 N EW C ASTL E C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

iv TABLE OF CONTENTS

– continued Page

2.9.5 Process Unit Control Equipment

............................................. 2

- 1 3

2.9.6 Process Unit Emissi ons

...................................................... 2

- 1 4

2.9.7 A Multi

- year Comparison of Facility Level Emissions

.................. 2

- 1 4

2.10 Technical Review Using Database Queries, Repor ts and Spreadsheets

......... 2

- 1 4

2.11 PM 2.5 Augmentation of Facility Reported Emissions

.................. .................. 2

- 1 4

2.12 Review of NO

x and SO 2 Emissions from EG Us and Other Large Sources

......... 2

- 1 5

2.1 3 Methods for Correcting Erroneous Data

............................................. 2

- 1 6

2.1 4 Facility Site and Stack Coordinates

...................................................... 2

- 16

2.1 5 Database Management

.................................... ........................... 2

- 1 6

2.1 6 Data Submission to EPA’s Emission Inventory System

........................... 2

- 17

2.1 7 Source Sector Discussions

............................................................... 2

- 1 7

2.1 7 .1 Hot

- mix Asphalt Plants

...................................................... 2

- 1 7

2.1 7

. 2 Electricity Generating Units

.................................... .................. 2

- 18

2.1 7

. 3 Emissions by Source Sector

...................................................... 2

- 1 9

2.1 8 Emissions by Facility

........................................................................ 2

- 1 9

2.1 8 .1 Sources of PM 2.5 Emissions

...................................................... 2

- 2 1

2.1 8 .2 Sources of S O 2 Emissions

...................................................... 2

- 2 2

2 .1 8

. 3 Sources of N O

x Emissions

...................................................... 2

- 2 3

2. 19 Closed Facilities

......... ............................................................... 2

- 2 3

2. 2 0 References

................................................................................. 2

- 25

SECTION 3

– STATIONARY NON

- POINT SOURCES

3.1 Source Categories

........................................................................ 3

- 1

3.2 Emission Estimation Methodologies and Activity Data

........................... 3

- 2

3.3 Emissions Summary

........................................................................ 3

- 3

SECTION 4

– NON

- ROAD MOBILE SOURCES

4.1 Source Categories

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

- 1

4.2 Emission Estimation Meth odologies

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

- 1

4.2.1 NONROAD Model Equipment

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

- 2

4.2.2 Aircraft

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

- 4

4.2.3 Locomotives

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

- 6

4. 2. 4 Commercial Marine Vessels

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

- 8

4.3 2008 Emissions Summary

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

- 14

4. 4 References

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

- 14

SECTION 5

– ON

- ROAD MOBILE SOURCES

5.1 Input Data Specific to New Castle County fo r 2008

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

- 2

5.1.1 Vehicle Miles Traveled (VMT) Data

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

- 2

5.1.2 Meteorological Data

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

- 42008 N EW C ASTL E C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
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v TABLE OF CONTENTS

– continued

P age

5.2. 3 Fuel Data

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

- 4

5.2. 4 Vehicle Populations and Age Distributions

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

- 5

5.2. 5 Vehicle Speeds

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

- 5

5.2.6 Northeast Ozone Transport Region Low Emission Vehicle Program ........ 5

- 6

5.2.7 Inspection and Maintenance (I/M) .............................................. 5

- 6

5. 2 Running the MOVES Model

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

- 7

5. 3 Controls

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

- 8

5. 4 Results

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

- 8

5. 5 References

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

- 9

LIST OF TABLES Page

SECTION 1

Table 1

- 1 200 8 Demographic Data for New Castle County

........................... 1

- 4

Table 1

- 2 200 8 PM 2.5 , SO 2 , and NO

x Emissions by Source Sector

....................... 1

- 5

SECTION 2

Table 2

- 1 Inventory Methods

............................................................... 2

- 5

Table 2

- 2 i

- STEPS ® Emission Estimation Methods

.................................... 2

- 1 0

Table 2

- 3 200 8 PM 2.5 and Precursor Emissions for New Castle County EGUs

......... 2

- 1 8

Table 2

- 4 200 8 PM 2.5 and Precursor Emissions by Industry Sector

....... .. ............ 2

- 19

Table 2

- 5 200 8 PM 2.5 and Precursor Emissions for New Castle County Facilities ..... 2

- 2 0

Table 2

- 6 200 8 New Castle County Facility Ranking of PM 2.5 Annual Emissions

..... 2

- 2 1

Table 2

- 7 200 8 New Castle County Facility Ranking of S O 2 Annual Emissions

...... 2

- 2 2

Table 2

- 8 200 8 New Castle County Facility Ranking of N O

x Annual Emissions

...... 2

- 24

Table 2

- 9 Reporting Facilities That Have Ceased Operations ........................... 2

- 25

SECTION 3

Table 3

- 1 Non

- point Source Categories Inventoried

.................................... 3

- 1

Table 3

- 2 Summary of 200 8 Non

- point Source Activity Data

.................. ......... 3

- 4

Table 3

- 3 Summary of 2008 New castle County Emissions from Non

- point Sources

.. 3

- 7

SECTION 4

Table 4

- 1 SCCs Addressed by the NONROAD Model

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

- 2

Table 4

- 2 NONROA D Model Temperature and Fuel Characteristic Input Values by Season for 2008

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

- 3

Table 4

- 3 200 8 Delaware

- specific Geographic Allocation Factors

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

- 4

Table 4

- 4 SCCs for Aircraft

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

- 5

Table 4

- 5 200 8 LTO D ata for New Castle County

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

- 6

Table 4

- 6 SCC s for Locom otives

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

- 72008 N EW C ASTL E C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

vi LIST OF TABLES continued Page

Table 4

- 7 200 8 New Castle County Locomotive Fuel Consumption Data

for Class I Lin e Haul Operations

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

- 7

Table 4

- 8 200 8 Switchyard Activity and Estimated Fuel Consumption

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

- 8

Table 4

- 9 U.S. EPA Marine Engine Category Definitions

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

- 8

Table 4

- 1 0 SCCs for Commercial Ma rine Vessels

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

- 8

Table 4

- 1 1 Waterway Segment Distances for the Delaware River Area

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

- 10

Table 4

- 12 Vessel Types Calling on Delaware River Area Ports in 2008

......... 4

- 11

Table 4

- 13 Average Propulsion E ngine Power and the 200 8 Number of Calls for OGVs Calling on the Delaware River Ar ea (DE, NJ, and PA) ...... 4

- 1 2

Table 4

- 14 Material Dredged in the New Castle County Portion

of the Delaware River Area during 200 8

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

- 13

Table 4

- 15 Summary of 2008 New Castle County Emissions

from Non

- road Sources in tons/year

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

- 14

SECTION 5

Table 5

- 1 SCC Included in On

- road Mobile Inventory

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

- 1

Table 5

- 2 New Castle County VMT Fractions by Road Type

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

- 3

Table 5

- 3 New Castle County VMT Fractions by Vehicle Type

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

- 3

Table 5

- 4 Monthly VMT Allocation Fractions

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

- 4

Table 5

- 5 2008 Gasoline Fuel Parameters for New Castle County

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

- 5

Table 5

- 6 2008 Vehicle Populations for New Castle County

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

- 5

Table 5

- 7 2008 Average Speed Matrix

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

- 6

Table 5

- 8 LEV Implementation Schedule in the Northeast OTR

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

- 6

Table 5

- 9 New Castle County I/M Program Parameters

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

- 7

Table 5

- 1 0 200 8 Annual On

- road Mobile Emissions by Vehicle Type for New Castle County

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

- 8

LIST OF FIGUR ES Page

Figure 1

- 1 PM 2.5 Emissions by Source Sector

........................... ........................ 1

- 5 Figure 1

- 2 SO 2 Emissions by Source Sector

........................... ........................ 1

- 6 Figure 1

- 3 NO

x Emissions by Source Sector

........................... ........................ 1

- 6

Figure 2

- 1 200 8 PM 2.5 Annual Emissions by Facility

.................................... 2

- 22 Figure 2

- 2 200 8 S O 2 Annual Emissions by Facility

.............................. ...... 2

- 23 Figure 2

- 3 200 8 NO

x Annua l Emissions by Facility

.................................... 2

- 24

Figure 3

- 1 200 New Castle County PM 2.5 Emissions by Non

- point Source Category

... 3

- 42008 N EW C ASTL E C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

vii ACRONYMS & ABBREVIATIONS

ACD administrative completeness determination

AERR Air Emissions Reporting Requirements

AMPD Air Ma rkets Program Data (EPA)

AP

- 42 Compilation of Air Pollution Emission Factors (EPA)

ARP Delaware Accidental Release Prevention Program (DNREC)

ATP Anti

- tampering Program

BOC Bureau of Census

C&D Chesapeake and Delaware

CARB California Air Resources Board

CB P County Business Patterns

CD compact disk

CDM county data manager

CD X central data exchange

CE control efficiency

CEM continuous emission monitor

CERS consolidated emissions reporting schema

CFR Code of Federal Register

CMV commercial marine vessel

CNG co mpressed natural gas

CO carbon monoxide

CROMERR Cross

- media Electronic Reporting Rule DAQ Delaware Division of Air Quality

DE Delaware

DE ANG Delaware Air National Guard

DE ARNG Delaware Army National Guard

DE DOL Delaware Department of Labor

DelDOT Delawa re Department of Transportation

DMV Delaware Division of Motor Vehicles (DelDOT)

DNREC Department of Natural Resources and Environmental Control

DOE U.S. Department of Energy

DPC Delaware Population Consortium

DRBA Delaware River and Bay Authority

DSWC Div ision of Soil and Water Conservation (DNREC)

DVD digital video disk

DWT dead weight tonnage

E&C Engineering and Compliance Branch (DNREC

- D AQ)

EDMS Emissions and Dispersion Modeling System (FAA)

EF emission factor

EGU electric generating unit

EIA Energy Inf ormation Administration (DOE)

EID Delaware Emission Inventory Development Program (DNREC

- D AQ)

EIIP Emission Inventory Improvement Program

EIS Emission Inventory System

EPA U.S. Environmental Protection Agency2008 N EW C ASTL E C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

viii ACRONYMS & ABBREVIATIONS continued

ERTAC Easte rn Regional Technical Advisory Committee

FAA Federal Aviation Administration

FHWA Federal Highway Administration

FIRE Factor Information Retrieval System

FP & GC fuel pressure and gas cap test

GAF geographic allocation factor

GHG greenhouse gas

GIS geograp hic information system

GSE ground support equipment

GTM gross ton

- miles

GVWR gross vehicle weight rating

HAP hazardous air pollutant hp horsepower

HPMS Highway Performance Monitoring System

IFO i ntermediate f uel o il

I/M Inspection and Maintenance

LEV l ow

- emission vehicle

LPG liquefied petroleum gas

LTO landing/takeoff

MARAMA Mid

- Atlantic Regional Air Management Association

MC method code ( i

- STEPS)

MMBtu million British thermal units

MOVES motor vehicle emission simulator mph miles per hour

MY model year NAAQS National Ambient Air Quality Standard

NAICS North American Industry Classification System

NCC New Castle County (Delaware)

NCDC National Climatic Data Center

NEI National Emissions Inventory

NH 3 ammonia

NLEV national low emission vehicle

NO

x oxides of nitrogen

OBD o n

- board d iagnostics

OGV ocean

- going vessel

OIT Office of Information Technology (DNREC)

OTR Ozone Transport Region pdf portable document format

PEI Periodic Emissions Inventory

PM

- CON condensable particulate matter

PM 10 - FIL filterable port ion of PM 10 - PRI

PM 2.5 - FIL filterable portion of PM 2.5 - PRI

PM 2.5 - PRI particles with an aerodynamic diameter less than or equal to a nominal

2.5 micrometers2008 N EW C ASTL E C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

ix ACRONYMS & ABBREVIATIONS continued

PM 10 - PRI particles with an aerodynamic diameter less than or equa l to a nominal

10 micrometers

ppm parts per million

POW Port of Wilmington psi pounds per square inch QA quality assurance QC quality control

R&D research and development

RE rule effectiveness

RP rule penetration

rpm revolutions per minute

RSZ reduced spee d zone

RVP Reid vapor pressure

SARA Superfund Amendments and Reauthorization Act

SCC source classification code

SEPTA Southeast Pennsylvania Transportation Authority

SIP State Implementation Plan

SO 2 sulfur dioxide SQL structured query language

TIM time

- in

- mode

TPY tons per year

TRI Toxics Release Inventory

TV Title V permit classification

US United States

USACE U.S. Army Corps of Engineers

VMT vehicle miles traveled

VOC volatile organic compound

XML extensible markup language2008 A TTAINMENT Y EAR S TATE I MPLEMENTATION P LAN E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

1

- 1 

### S ECTION 

### 1

200 8 PM 2.5 

### , SO 2 

### , AND 

### NO
X 

### I NVENTORY 

### O VERVIEW AND 

### S UMMARY

In 2006 , the U.S. Environmental Protection Agency ( EPA ) promulgated a new 24

- hour National Ambient Air Quality Standard (NAAQS) for particulate matter with an aerodynamic diameter less than or equal to a nominal 2.5 micrometers (PM 2.5 )

. Particles of this size are know n as fine particulate matter

. EPA established the standard at 35 μ g/m 3 . T he previous 24

- hour standard established by EPA in 1997 was set at 65 μ g/m 3

.

New Castle County was designated non

- attainment for the daily PM 2.5 standard based on 200 6

- 200 8 monitoring data. The 35 μ g/m 3 24

- hour standard went into effect on December 14, 2009

, following final non

- attainment area boundary designations ( EPA, 200 9 )

. New Castle County was included in the Philadelphia

- Wilmington , PA

- NJ

- DE non

- attainment area with an attainment

date of December 14, 2012

.

P articulate matter emitted from sources is known as primary particulate emissions. Primary

emissions include filterable (PMx

- FIL) and condensable (PM

- CON) material

. Filterable matter can be designated as PM

- FIL, PM 10 - FIL

, or PM 2.5 - FIL depending on particle size cut points.

PM

- CON is always con sidered smaller than 2.5 micrometers in diameter. The combination of

PMx

- FIL and PM

- CON is known as primary particulate matter, or PMx

- PRI. Throughout this report, the use of PM 2.5 refers to primary fine particulate emissions. Particulate matter is also

fo rmed in the atmosphere through reactions that form sulfates and nitrates . Th ese emissions are considered secondary emissions of particulate matter. Sulfur dioxide (SO 2 ) and oxides of nitrogen (NO

x ) contribute to the formation of secondary PM emissions.

The Division of Air Quality (DAQ), within the Delaware Department of Natural Resources and Environmental Control (DNREC) established calendar year 200 7 as the base year inventory for

the 24

- hour PM 2.5 because (1) 2007 coincides with the three years of ambi ent monitoring data used to designate New Castle County as part of the Philadelphia non

- attainment area, and (2) a 2007 regional inventory had already been prepared for modeling and State Implementation Plan (SIP) purposes. This regional inventory, for whi ch Delaware supplied Delaware

- specific data for all source sectors, has undergone extensive quality assurance

. Details of how the inventory was developed can be found in the regional report

, Technical Support Document for the Development of the 2007 Emissi on Inventory for Regional Air Quality Modeling in the Northeast/Mid

- Atlantic Region (MARAMA, 2007)

.

The DAQ established calendar year 2008 as the attainment year inventory for the 24

- hour PM 2.5 because (1) 2008 coincides with the three years of ambient mo nitoring data used to demonstrate that New Castle County now attains the 24

- hour PM2.5 standard, and (2) 2008 represents a Periodic Emissions Inventory (PEI) reporting year, for which Delaware has prepared a SIP quality inventory based on Delaware

- specific data for all sources of criteria pollutants to include

PM 2.5 emissions and emissions of NO

x and SO 2 as precursors to PM 2.5

.

Th is report documents Delaware’s completed 200 8 inventory of PM 2.5 SO2, and NO

x for New Castle County for all sources including the following four major source sectors: stationary point, stationary non

- point, on

- roa d mobile, and off

- road mobile

.2008 A TTAINMENT Y EAR S TATE I MPLEMENTATION P LAN E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

1

- 2 

### 1. 1 Project Management

The Emission Inventory Development (EID) Program within the Planning Branch of DAQ was responsible for preparing the 200 8 PEI for criteria pollutants to include emissions PM 2.5 , SO 2 , and NO

x summarized in this report

. Internal planning began in September 200 8 , with focus on

the 200 8 point source inventory reporting cycle taking place in March/April of 200 9

.

1. 1 .1 Project Manager

The overall project manager was David Fees, Manag ing Engineer for the EID Program.

R esponsibilities included i dentify ing overall inventory goals, objectives, and deadlines , initiating inventory planning, a pprov ing estimation methodologies recommended by staff , reviewing emissions development work, and preparing inventory reports and documentation.

1. 1 .2 Point Source s Technical Lead

The point source technical planning and review was performed by John Outten, a senior

e nvironmental s cientis t for the EID Program

. R esponsibilities included:

• Identify ing point source inventory goals, objectives, and deadlines ;

• Establish ing the universe of facilities to inventory ;

• Oversee ing the development of the survey forms and instructions ;

• Provid ing training and guidance to industry representatives ;

• Set ting up the on

- line electronic reporting system and work ing with DNREC’s Office of Information Technology in preparing the on

- line reporting capabilities ;

• Performing a technical review of emissions da ta submitted by facilities ;

• Work ing with facility representatives to correct errors ;

• Manag ing the point source inventory database ; and

• Oversee ing quality control of point sources data

.

1. 1 .3 Point Sources Support

Support of the point source inventory wa s performed by Marian Hitch, a senior e nvironmental compliance specialist for the EID Program

. R esponsibilities included:

• Gather ing facility general information on facilities to be surveyed ;

• Assist ing in developing survey forms and instructions ;

• Prepar ing and mail ing reporting packages ;

• Receiv ing and organiz ing reports submitted by facilities ;

• Perform ing an administrative review of all reports received ;

• Track ing reporting status of each facility ; and

• Prepar ing and organiz ing documentation for the point sou rce inventory

.

1. 1 .4 Non

- point and Off

- road Sources

Emission estimates of the many non

- point and off

- road source categories were prepared jointly by Jeffrey Bendelewski, an engineer for the EID program, and Mark Prettyman, a senior

environmental scientis t for the Planning Branch of DAQ. Their r esponsibilities included :2008 A TTAINMENT Y EAR S TATE I MPLEMENTATION P LAN E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

1

- 3 • Researching and recommending emission estimation methodologies;

• Defining all simplifying assumptions;

• O btain ing 2008 activity data

, current emission factors, and applicable control information

• Using spreadsheets to calculate emissions;

• Downloading and using the EDMS model for developing aircraft emissions;

• Downloading and using the NONROAD model;

• R eviewing emission calculations for accuracy and completeness ;

• Preparing report document s; and

• Compiling supporting documentation

.

1.1.5 On

- road Mobile Sources

Emission estimates of on

- road mobile source s were prepared by John Outten, a senior

e nvironmental s cientist for the EID program. Responsibilities included:

• Downloading the MOVES model;

• Obtaining 2008 vehicle miles traveled (VMT), vehicle registration, and other mobile input data from the Delaware Department of Transportation;

• Obtaining other data for inclusion in the model inputs;

• Preparing the input files for running MOVES ;

• Runni ng MOVES and summarizing the model outputs;

• Reviewing emissions for accuracy and completeness;

• Preparing report documents; and

• Compiling supporting documentation.



### 1. 2 Inventory Planning

Calendar year 200 8 is a Periodic Emissions Inventory (PEI) year as defined by the Air Emissions Reporting Requirements (AERR) (EPA, 2008) . The AERR specifies the emissions data for criteria pollutants that are required to be reported to EPA’s National Emission Inventory (NEI ). A PEI requires the development of emission estimates from all sources within a state or local

area for all criteria pollutants and their precursors. As such, the 2008 inventory can provide the necessary data for the PM 2.5 24

- hour NAAQS attainment year i nventory. While not required, t he DAQ also prepared 2008 emission estimates of air toxics and greenhouse gases from all sources

.

1.2.1 Inventory Parameters

The inventory parameters defined by the 2008 PM 2.5 A ttainment Y ear SIP inventory include the following:

• Inventory year

– 2008 ;

• Pollutants

– PM 2.5 , and SO 2 and NO

x as precursors to PM 2.5 (DNREC, 2012 a ) ;

• S ource coverage

– a ll sources, including point, non

- point , mobile, and non

- road sources ;

• Spatial resolution

– c ounty level emissions ;

• Geographic coverage

– New Castle County ; and

• Temporal resolution

– annual emissions (DNREC, 2012b)

.2008 A TTAINMENT Y EAR S TATE I MPLEMENTATION P LAN E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

1

- 4 1. 2

. 2 Data C ollection and Management

For all source categories t he gathering of local activity data represent ed a major task spread over many months. For point sources, most facilities reported their emissions through the use of an

on

- line reporting system. Data entered into the on

- line system were transferred to the DAQ i

STEPS ® database for review and correction

.

Microsoft Excel spreadsheets were employed for managing acti vity data and calculating emissions from stationary non

- point sources and some non

- road categories. A consistent set of

tabs w ithin each source category spreadsheet included activity data, point source data (if applicable, for backouts), emission factors, controls, emission calculations, National Emission Inventory (NEI) input formats, and notes on QA/QC procedures.

On

- road mobile source emissions were calculated using the MOVES2010a model . E missions for

most of the non

- road vehicles and equipment categor ies were calculated using the

NONROAD 2008a model.

Emissions data were transferred from i

- STEPS ® (point sources), from the non

- point and non

road spreadsheets, and from the model outputs to staging tables in Microsoft Access databases. These databases were then converted to XML files via the EIS bridge tool, and then transmitted

to the EIS via CDX web client by June 1, 20 10 to meet the reporting requirements of the A ERR.



### 1. 3 Inventory Deve lopment

For point sources, the EID Program developed a set of criteria to use in establishing the universe of facilities required to report. These criteria are presented in detail in the point source section of this report. Reporting packages were sent to each facility meeting one or more of the reporting

criteria. An extensive amount of review and follow up was performed on the point source data submitted by facilities.

For non

- point sources, the first main task involved gathering activity data for each source category. In many cases, these data were obtained from Delaware

- specific sources. In some cases the activity data were developed through the allocation of a portion of a national activity dataset (i.e., national off

- road equipment populations ) to D elaware. Basic demographic data were also used for some source categories and are presented in Table 1

- 1. Once activity data were obtained, spreadsheets were developed to manage the data and combine the activity data with the selected emission factors to obtain uncontrolled emissions. Finally, for those sources where controls applied, emissions were adjusted to account for control efficiency, rule effectiveness, and rule penetration.

Table 1

- 1. 200 8 Demographic Data for New Castle County

Demographic Parameter New Castle
Population a 528,536

Households a 204,630 Land Area (square miles) 439 Annual VMT (million miles) b 5,273

a DPC, 200 9 ; b DelDOT, 200 9

.2008 A TTAINMENT Y EAR S TATE I MPLEMENTATION P LAN E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

1

- 5 For on

- road mobile and off

- road equipment

, the MOVES and NONROAD models, respectively, were used to develop emissions from these sources . In the use of these models, activity data were included in the model input files. For any type of data used by the model for which Delaware

specific data did n ot exist, the model used the system defaults. Details about Delaware

- specific and default parameters are discussed in the on

- road and non

- road sections. The models account for controls, some of which reflect control s specific to Delaware.



### 1. 4 Emission s Summary

The following emission summaries present the entire 200 8 emission inventory for PM 2.5 , SO 2 , and NO

x , for New Castle County broken down by source sector. Throughout this document, annual emissions are reported in tons per year (TP Y ). The totals ma y not match the sum of the individual values due to independent rounding.

Table 1

- 2

. 200 8 PM 2.5 , SO 2 , and NO x Emissions by Source Sector

Source
Sector Annual Emissions (TPY)

PM 2.5 SO 2 NO
x
Point 1,109 10,576 5,589

Non

- point 1,191 402 1,287

Non

- road 312 1,067 4,317

On

- road 282 94 9,311

All Sectors 2,894 12,139 20,504

Point

38% Non

- point

41% On

- road

10%

Non

- road

11% Figure 1

- 1. PM 2.5 Emissions by Source Sector2008 A TTAINMENT Y EAR S TATE I MPLEMENTATION P LAN E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

1

- 6 Point

87% Non

- point

3%

On

- road

1%

Non

- road

9% Figure 1

- 2. SO 2 Emissions by Source Sector

Point

27%

Non

- point

6% On

- road

46% Non

- road

21% Figure 1

- 3. NO

x Emissions by Source Sector2008 A TTAINMENT Y EAR S TATE I MPLEMENTATION P LAN E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

1

- 7 

### 1.5 Referenc e s

DPC, 200 9

. Delaware Population Consortium Annual Population Projections, downloaded from http://stateplanning.delaware.gov/information/dpc_projections.shtml

, October 31, 2009.

DELDOT

, 2009

. 2008 Estimated VMT by County, by Functional Class, by Rural /Urban Designation

, accessed DelDOT website July 10, 2009, per June 29, 2009 e

- mail from Mike DuRoss, DelDOT Planning

.

DNREC, 2012 a

. “Delaware Redesignation Request and Maintenance Plan Under the 2006 Daily

PM 2.5 National Ambient Air Quality Standard”, Section 7.2.1, Delaware Department of Natural Resources and Environmental Control, Division of Air Quality

, September 2012

.

DNREC, 2012b

. “Delaware Redesignation Request and Maintenance Plan Under the 2006 Daily

PM 2.5 National Ambient Air Quality Standard ”, Section 4.1, Delaware Department of Natural Resources and Environmental Control, Division of Air Quality

, September 2012

.

EPA, 200 8

. Final Rule: “Air Emission Reporting Requirements” , Federal Register

– Vol. 73 No. 243 page 76539, December 17 , 200 8

.

EPA, 200 9

. Final Rule: “Air Quality Designations for the 2006 24

- Hour Fine Particle (PM2.5) National Ambient Air Quality Standard s”

, Federal Register

– Vol. 74 No. 218 page 58688

, November 13 , 200 9

.2

- 1 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X



### S ECTION 

### 2

S TATIONARY 

### P OINT 

### S OURCES

The p oint s ource inventory represents facility

- specific data for larger stationary sources. Emissions data for all other source categories are reported at the county level. Point sources typically include lar ge industrial, commercial and institutional facilities

. Industrial m anufacturing

facilities comprise the majority of all report ing point sources. The institutional sector includes hospitals, universities, prisons, military bases, landfills, and wastewater treatment plants.

Unlike other source sector emissions which are estimated by DAQ , point source emissions data

are submitted to DAQ by the facilit ies . Emissions are reported at the process level and include

both confined (stack) emission points as well a s unconfined ( fugitive ) emission sources. A key aspect of point source data is the inclusion of facility coordinates to accurately allocate emissions spatially within a county for purposes of performing air dispersion modeling.

The planning and execution of the point source inventory was accomplished in the following chronological order :

• Define the purpose of the inventory (defined in Section 1 of this report);

• E stablish the reporting criteria and list of facilities to survey;

• Obtain inventory data from facilities;

• Perform administrative and technical review of data received from facilities;

• Seek resubmissions/corrections from facilities based on data review;

• Perform internal data augmentation (for PM 2.5 ) ; and

• Prepare inventory data files, report, and sup porting documentation.

Quality control/assurance is not listed in the chronology above since these activities were performed throughout the point source inventory development process. Quality control/assurance efforts are presented throughout this section

.

Since there may be overlap between point sources and stationary non

- point source categories, one final activity required of the point source inventory staff is to provide point source back out data where appropriate. Point source back out data includes emissions, throughput, or employees, depending on the non

- point source category methodology.



### 2.1 Reporting Criteria

Based on the several purpose s of the 200 8 inventory (Ozone PEI

, PM 2.5 PEI, HAPs and GHG inventories, as well as the daily PM 2.5 Attainm ent Year SIP inventory) the following criteria were established for defining the universe of facilities to be surveyed:

• Facilities that held a Title V permit in 2008;

• Any facility falling into one of the following industry sectors;

o Hot

- mix asphalt plants

,2

- 2 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

o Electric generating units (EGUs);

o Facilities using anhydrous ammonia as a refrigerant; and

o Chrome p lating operations;

• Any facility with emissions greater than 5 TPY for VOCs or 25 TPY for NO

x in 2006

or 2007, as previously reported to the DAQ inventory program; and

• Any facility that may be a significant source of emissions but for which DAQ does not have previous inventory data

, or otherwise of particular interest

.



### 2. 2 Initial List of Facilities

Once the reporting criteria were establish ed

, D AQ point source inventory staff compiled an initial list of facilities to be compared against the reporting criteria. All 133 facilities reporting

statewide for the 2005 P eriodic E missions I nventory (PEI) were included in the initial list. All Title V (TV) permitt ed facilities are required to report emissions each year. The Engineering and Compliance Branch of DAQ provided a list of TV facilities as of the end of 2008, which contained one facility that had not reported for 2005.

The following additional data sourc es were reviewed to identify facilities that might have met one or more of the reporting criteria:

• Toxics Release Inventory (TRI, SARA 313)

– 2006 and 2007 data;

• Hazardous Chemical Inventory (Tier II, SARA 312)

– 2007 data;

• Accidental Release Prevention ( ARP) Program facility list.

D AQ inventory staff reviewed the two most recent years of TRI data, and found that all facilities within TRI with more than five tons per year air releases of VOC compounds were already

included in the initial list. The Tier II data and information from the ARP Program were reviewed mainly to identify facilities that used anhydrous ammonia ; however, no additional

facilities were added to the initial list as a result of this review.

Through a review of permit and compliance info rmation , and conversations with the permitting

group, one new asphalt plant and six other facilities of interest were added to the initial list . The

six facilities of interest were either new facilities needing baseline data

, or facilities not recent ly

inv entoried, but nonetheless with the potential of having significant PM emissions

.

The complete initial list included 14 2 facilities statewide

. A spreadsheet was developed by D AQ point source staff containing a record of every facility included on the initi al list of facilities. The spreadsheet includes the reason the facility was placed on the initial list. For facilities that were inventoried, the spreadsheet indicates which reporting criteri a were met

.



### 2.3 Facilities Inventoried

The facilities on the i nitial list were evaluated using the reporting criteria established in Section

2.1 . TV facilities are required to report regardless of the amount of emissions. Therefore, all 65 TV facilities were included in the final list of point sources. The remaining 7 7 of the 14 22

- 3 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

facilities were evaluated against the other reporting criteria. As a result, 20 facilities were dropped from further consideration since no criterion was met.

F our facilities were identified as being closed prior to calendar year 2008. They were City of

Lewes EGUs

, Industraplate, Spatz Fiberglass and Tilcon

- Horsepond Road. Prior to 2008, permits for the City of Seaford’s six EGUs had been modified to allow these units to operate only as emergency generators as defined by Delaware Regulation 1 144 (DNREC, 2006). Therefore, this facility is no longer included in the point source inventory. One facility, Tilcon

- Terminal Avenue, did not operate in 2008 , and has since closed permanently

.

Three facilities closed during 2008. Attempts were made to co ntact the companies. In phone

conversations with Perma

- Flex Rollers and PTFE Compounds , it was determined both facilities did not meet any of the reporting criteria for 2008. PTFE had closed after having minimal operations for the first six months of 2008. In July 2008 the facility moved their operations to New Jersey. The Perma

- Flex Rollers site was used primarily for storage and warehousing and had little or no production during 2008. The third facility that closed in 2008, Pepsi Cola Bottling Company , us ed ammonia refrigeration , which would require reporting; however DAQ was unable to obtain any information related to potential ammonia emissions.

Through a review of emissions data from 2006 and 2007, recently reported TRI air emissions, and inspection re ports

, eight facilities were determined to not meet either the VOC or NO

x emission thresholds, and thus were not included in the list of facilities to be inventoried

.

Two facilities (the Port of Wilmington and VFL Technologies) that were added to the init ial list

as facilities of interest were not inventoried due to staff resources. DAQ staff did spend considerable time working with t he Port of Wilmington to establish a set of stationary and mobile emission units, but due to time constraints, an inventory was not completed by the site. Due to limited resources VFL Technologies was not contacted and did not submit an emissions inventory. VFL closed in 2010.

Finally, in 2007 SPI Polyols was sold to Croda

- Uniqema , an adjacent and contiguous Synthetic Minor pe rmitted facility. Starting with 2008

, processes and emissions previously associated with

SPI Polyols were reported by Croda.

The final list included 12 2 facilities inventoried statewide . Of these

, 58 facilities in New Castle County reported emissions of p articulate matter and/or particulate precursors (SO 2 , and NO

x ) and

are included in the 2008 PM 2.5 Attainment Year SIP inventory.



### 2. 4 Survey Methods

In December 2008, the DAQ point source inventory staff began reviewing survey methods and preparing repo rting packages to be e

- mailed to each facility to be inventoried. DAQ used two primary methods to gather information from most facilities for the 2008 inventory

. Facilities

either used an on

- line reporting system or submitted activity data reporting forms by e

- mail or

fa csimile . These two methods are described in detail below.2

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X

2.4.1 Electronic Reporting

DAQ offer s electronic reporting of emissions data through the Internet. For the 2008 reporting cycle, t he Terminal Server Satellite i

- STEPS  application was upd ated with the latest FIRE and

AP

- 42 emission factors. Satellite i

- STEPS  is capable of calculating emissions based on information supplied on process throughput, operating schedule, and controls. A database specific to each facility was generated based on previously submitted inventories and other information (i.e., permitting files). Information expected to remain the same from year to year

was pre

- populated in the database, while throughput and emissions data were zeroed out. Facilities were expected to u pdate pre

- populated information as necessary and enter 2008 data

for fields that were zeroed out.

2.4.2 Activity Data Reporting Forms

Instead of requiring on

- line reporting for all facilities, DAQ provides smaller facilities with the option of completing fill able electronic activity data reporting forms that are e

- mailed to the facility that can be e

- mailed back to DAQ once completed

. DAQ use d these forms for 2008 to simplify the reporting process. The activity data supplied by facilities (i.e. operating sched ule, monthly throughputs), were used by DAQ staff to calculate emissions based on EPA’s FIRE emission factors or material balance methodologies.

A ctivity data report ing forms applicable to the 2008 Attainment Year SIP inventory were developed for the foll owing processes:

• B oilers ;

• S tationary d iesel engines ; and

• Hot

- mix asphalt production

.

For facilities that use d the activity data forms, DAQ already had detailed process and stack

information on file

.

2.4.3 Other Methods

In a limited number of cases where o n

- line reporting or the use of the activity data forms w as not appropriate or useful, information was obtained from facilities via telephone

, e

- mail or fa csimile

. Regardless of the survey methods used to obtain data from facilities, all data were entered i nto

one database within i

- STEPS 

.



### 2.5 Data Collection

Reporting packages were sent out in January and February 2009 to facilities identified as meeting one or more of the established reporting criteria.

Table 2.1 provides the number of facilities inv entoried by each survey method.2

- 5 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

Table 2

- 1. Inventory Methods

Inventory Method Used Number of

Facilities

On

- line reporting 71 Activity data report forms 48

Other methods 3

2.5.1 On

- line Reporting

Terminal Server Satellite i

- STEPS  software reporting pa ckages were e

- mailed to 7 1 facilities between February 10 and February 18

, 2009. The reporting package contained a cover letter,

instructions

, and an Optical Media Certification F orm. Two facilities (Micropore and CPI Packaging) that received reporting pac kages for on

- line submissions were subsequently handled directly through e

- mail and facsimile.

The instructions contained information on how to access the Terminal Server Satellite i

- STEPS 

, user initials and passwords, DAQ contact information, informatio n specific to the 200 8 inventory, and a DAQ web page address where additional inventory documents were available.

These documents included:

• Emission Inventory Definitions and Structure

• Common Errors

• Useful Web Pages

• Uncontrolled Coal PM

x Factors or For mula

• Calculating PM 10 and PM 2.5 Emissions f or #4, #5 and #6 Fuel Oils Using EPA FIRE 6.24

Formulas

• Regulated Pollutants

• Web FIRE (Factor Information Retrieval System)

• TANKS Software (EPA, 2005 a )

• Emissions Factors / AP 42

A database was customized fo r each facility based on the process structure previously established

for the facility

. For new facilities using Satellite i

- STEPS  , the reporting structure was created by DAQ point source inventory staff with input from the facility. The database was pre

- populated

with general information about the facility , as well as a few other data elements not expected to change from year to year, such as stack parameters and design capacity

. Other data elements were

left blank or zeroed out

, such as annual process r ate, percent sulfur and ash of fuel burned, operating schedule, throughputs, capture and control efficiencies , and emission estimates

.

Generally

, it was the l arge
, complex facilities with multiple processes that reported on

- line

. For facility representati ves new to emissions inventory reporting or who had not reported in some

time

, DAQ inventory staff worked with them to understand the inventory structure . Assistance by phone or e

- mail in completing the inventory was offered on an on

- going basis for many f acilities

. Terminal Server Satellite i

- STEPS ® on

- line reporting allowed point source inventory staff to work with a facility simultaneously on

- line to resolve any issues a facility may have encountered.2

- 6 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

The inventory information requested from facilities f or the 200 8 inventory is described in several EPA publication s including Emission Inventory Requirements for Ozone State Implementation

Plans and Emissions Inventory Guidance (EPA, 1991 a ) and Emissions Inventory Improvement Program (EIIP), Volume II (EPA, 1997 )

. All emissions were reported at the process level. Facilities were required to provide e mission calculation s and documentation in the Notes window

within Terminal Server Satellite i

- STEPS  or in writing w hen submitting their certified

emiss i ons.

Ter minal Server Satellite i

- STEPS ® ha s built

- in system checks for out of range values as well as

relational errors. Field specific data entry checks were performed by the software at the time the

data w ere entered or when an attempt was made to save the data. The system prompted the user

to make the needed corrections. In most cases a record could not be saved until all edit checks

were satisfied. S ystem functions and checks includ e :

• D ata can be entered through the use of look

- up tables ;

• Data e ntered directl y must match information in the look

- up table;

• Total p ercent q uarterly throughputs must be between 95 and 101;

• Alpha

- numeric checks;

• Enforce d relational database integrity;

• Mandatory field alerts;

• Stack assignment check (each proce ss must have an assigned stack); and

• Automated emissions calculations

.

Once a facility completed entering its data and information, the user had the ability to run the following reports:

• Group level emissions (facility summary ) ;

• Process unit level emissions summary ; and

• Detaile d report ( contains all entered and calculated data)

.

Facilities used the three reports to verify data they entered and the emissions reported and/or calculated by the Terminal Server Satellite i

- STEPS  . Reports could be displayed to the screen or

created as an Adobe Acrobat pdf file which is then automatically e

- mailed to the user.

The p rocess s ummary r eport provided emissions of each criteria pollutant for each process within

an emissions unit. The d etail ed r eport lists the data following the Terminal Server Satellite i

STEPS  structure and contains all information that the faci lity entered as well as information the system used to organize the inventory information or calculate emissions.

The facility summary report tabulates criteria pollutant emis sions for each emission unit with a facility total at the bottom . This report also served as the emission certification page and thus

contains a signature area for the “Responsible Official ”. When DAQ received a signed copy of this report, indicating the f acility had completed the reporting process, DAQ set the Terminal

Server Satellite i

- STEPS  to read

- only for the facility.2

- 7 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

EPA’s Cross

- Media Electronic Reporting Rule (CROMERR), applies to s tates that choose to receive reports and documents from faciliti es through the Internet. The requirements of the rule provide for electronic reporting under authorized state and local government programs, apply to the governmental entities administering the authorized programs, and to facilities that submit data throug h the Internet to those governmental entities. If on

- line reporting is offered by the
state, an EPA

- approved electronic signature process must be in place. Alternatively, on

- line reporting can be followed up by the submission of a certified document (on di skette, compact

disk (CD) , digital video disk (DVD) , facsimile, or paper report) containing the same information

that was submitted on

- line.

Currently, the DAQ on

- line reporting system does not have an approved electronic signature system. Therefore, DAQ is required to receive from reporting facilities a certified document in

addition to the data submitted on

- line. DAQ has created a detailed report that can be easily created in pdf format for use by a facility as the certified document of their on

- line su bmission. The pdf file can be burned to a CD or DVD and sent to DAQ to meet the CROMERR requirements. A signed Optical Media Certification Form is mail ed with the CD or DVD to DAQ

.

2.5.2 Activity Data Reporting Forms

Activity data reporting form packages were e

- mailed to 48 facilities, from January 13 through January 15

, 2009. The reporting packages included a cover letter, general facility information page, and the appropriate activity data reporting form(s) for each facility. Reporting for m s were
in Mic rosoft  Word form at . The general facility information sheet contained pre

- printed general information about the facility. This information included facility name, mailing address, contact
name, NAICS codes

, and phone and fa csimile numbers. Facilities made corrections in the space provided on the facility general information page

, added activity information to the activity report

forms

, and returned these documents via e

- mail or fa csimile to DAQ

.

Assistance in completing the activity reports was offered on an on

- going basis. Assistance was provided by telephone and e

- mail.



### 2.6 Inventory Tracking

A log book was maintained to record and track the reporting status of the 119 facilities receiving a reporting package

. Th e log book contained the facility name and i dentification number, the facility contact, the date the reporting package was e

- mailed to the facility

, the original due date,

an extension date, if given

, the date the submission was received by DAQ , and notes regarding phone or e

- mail communications wit h the facility

.

In addition to the 200 8 inventory log book

, a Microsoft  Excel s preadsheet was maintained to
track each facility from the initial mailing through all tracking and review steps in cluding the

final QA/QC process. Communications with facili ties are noted in the spreadsheet, especially

when facilities failed to meet their deadlines

. All facilities receiving reporting packages supplied either complete on

- line submissions

, or submitted activity forms via e

- mail or fa csimile

.2

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X



### 2.7 Administrati ve Review

As soon as submissions were received, the review process began. The Administrative Completeness Determination (ACD) was performed as the first step in the review process. T he

ACD consisted of a one

- page checklist which begins the audit trail ass ociated with the review process. The ACD checklist was developed by the DAQ point source inventory staff over many years as a QA/QC tool for ozone SIP inventories. A checklist is completed and maintained in each facility file

. An ACD is prepared for all fa cilities, whether Terminal Server Satellite i

STEPS  or the activity data reporting forms were used to prepare their submission.

2.7.1 Administrative Review of On

- line Submissions

The ACD performed on on

- line submissions included the following steps :

Review c over letter

- Facilities were asked to identify in their cover letter any operational changes and the impact such changes ha d on emissions. DAQ staff reviewed t he cover letter noting any significant changes and highlight ed it for future reference.

Emissio ns comparison

- The 2 008 facility

- wide reported emissions for each criteria pollutant

were compared to the most recent periodic emission inventory year which in most cases was

2005

. Annual emissions for other years were used when appropriate. Significant d ifferences between the two years were identified, investigated , and documented

. Reviewing past and

present submissions , p rocess additions and deletions were compared, identified and highlighted for further investigation. If sufficient information was not p rovided in the cover letter, the facility was contacted to explain the differences.

Accidental releases

- Facilities were asked to identify accidental releases either through the assignment of a separate accidental release process or an explanation in the ir cover letter as to the

account ing of the release(s) in their inventory

. Throughout 200 8

, DAQ staff compiled e

- mails of

accidental releases sent through DNREC ’s Environmental Release Notification System list

server. This information was checked against accidental releases identified in the emission inventory reports. The Delaware City Refinery (Premcor) had the greatest number of reported

accidental releases. DAQ requested and received a spreadsheet of detailed accidental release

information from the ref inery

. DAQ compared this information to the release notification

information and to emissions reported as accidental releases by the refinery

.

Comments Spreadsheet

– D AQ developed a M icrosoft ® Word document to list any data from

individual facilities that had significant changes, such as significant decreases or increases in

emissions

, the reason for the changes in emissions

, and a list of issues that needed to be addressed before the QA/QC process could be completed. This information was also listed on th e facility’s ACD sheet.

Other ACD checks

– DAQ staff v erified that the emission certification report (facility summary) was signed by the Responsible Official . Any request for con fidential business information was forwarded to the DAQ paralegal staff for review. The tracking spreadsheet was updated to include any communications with the facilities and to document when the ACD was completed2

- 9 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

for each facility and when all issues, if any, were resolved. The completed ACD, cover letter

, signed emissions summar y page, submitted supporting calculation sheets , notes and other correspondence (i.e., e

- mails) were placed in the facility file.

2.7.2 Administrative Review of Activity Data Report Forms

Activity data report form information was used to update facility gener al information and calculate emissions. Information from the activity reports were entered into the Terminal Server

Satellite i

- STEPS  database by DAQ staff. The database maintain ed an audit trail (user ID and date stamp) of data added to the system.

A ct ivity data were used by the database to calculate emissions based on emission factors

contained in the database. Fuel combustion throughputs for small boilers and generators were used in this way. Once emissions were estimated for a facility that report ed activity data, the

200 8 emissions could be compared to data from previous years

.

A ll Title V permitted facilities are required to submit a signed emissions certification report as part of their permit requirements

. F or those Title V facilities that report ed activity data, the DAQ point source inventory staff generated the emissions summary pag e based on emissions

calculated within i

- STEPS  and mailed it to the facility for signature by the Responsible Official. The ACD was not complete until the signed emi ssions summary page was returned to DAQ and

the signature verified. The date the emissions summary page was mailed to a facility was documented within the tracking spreadsheet, as well as the due date for receiving the signed document. Finally, the actual date it was received was recorded.

The tracking spreadsheet was updated to include a record of communications with the facilities and to document when the ACD was completed for each facility and when all issues, if any, were resolved. The completed ACD, s igned emissions summary page, notes and other correspondence (i.e., e

- mails) were placed in the facility file.



### 2.8 Re port ed Data and Estimating Emissions

The 200 8 stationary point source inventory included all criteria pollutants and their precursors ( PM 10 - P RI, PM 2.5 - PRI, SO 2 , NO

x , NH 3 , VOC , and CO )

, all hazardous air pollutants (HAPs) , and the six greenhouse gases as defined by the Kyoto Protocol (UN, 1998)

. For the 2008 PM 2.5 Attainment Year SIP inventory

, only emissions of PM 2.5 , SO 2 , and NO

x from New Cast le County

facilities are included in this report.

If PM 2.5 emissions were missing, DAQ augmented PM 2.5 emissions within the point source inventory either by using standard emission factors based on throughput information provided by the facility

, or as d escribed in S ection 2. 11

.

Emissions of sulfur dioxide were calculated using FIRE emission factors, except for large units

that use CEMs to monitor SO 2

. Percent s ulfur in the fuel is critical in calculating accurate SO 2 emissions for combustion processes u sing emission factors. DAQ reviewed and worked with the facilities to resolve any issues associated with the reported percent s ulfur.2

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X

DAQ require d facilities to report data to the process level, identified by an eight

- digit Standard Classification Code (S CC). Key data reported include d SCC identification, product or fuel throughput, operating schedule, control equipment information (type, capture efficiency and control efficiency), stack parameters (height , diameter, flow rate, velocity and temperature), a nd
emission factors, if FIRE factors were not used

. Data collected w ere consistent with EPA’s

Procedures Volume I (EPA, 1991 b )

, the Air Emission Reporting Requirements (AERR)

– Final

Rule ( EPA, 2008 )

, Emissions Inventory Guidance for Implementation of Ozon e and Particulate Matter National Air Quality Standards (NAAQS) and Regional Haze Regulations (EPA, 2005 b ) (hereafter referred to as Emissions Inventory Guidance )

, and EIIP documents

.

2.8.1 Emission Estimation Methods

A nnual emission s could either be calculate d within i

- STEPS  using uncontrolled emission factors, throughput data , and control data

, or outside the system using mass balance, stack tests,

or other means. Terminal Serve r Satellite i

- STEPS  allowed for the use of nine emission

estimation methods , wh ich are presented in Table 2

- 2.

Table 2

- 2

. **i**

- STEPS  Emission Estimation Methods

**i**

- STEPS 

Method Code Basis for Emissions Estimate

1 S tack test data a

2 Material balance

3 Use of emission factor outside of **i**

- STEPS  or use of
EPA TANKS software

4 Best engineering judgment

5 State or local agency emission factor

6 New construction /not yet operational (zero emissions)

7 Source closed/operation ceased (zero emissions)

8 **i**

- STEPS  default emission factor

9 Facility

- supplied emission factor

a includes Continuous and Predictive Emission Monitoring

A nnual emissions are calculated by the database when Method Code (MC) 8 or 9 is designated.

The m onthly fuel or process throughput rates obtained from the facility are summed to an annual rate and then applie d to the relevant emission factor

, ei ther the system default (MC8) or one supplied by the facility (MC9). This calculation produces an annual emissions estimate in tons

per year. A nnual emissions may be calculate d outside of i

- STEPS  with only the annual

e missions entered in i

- STEPS  . Annual emissions calculated outside of i

- STEPS  are identified

in the database by MC 1 through MC 4. Facilities were asked when deriv ing annual emissions

from stack tests to take into consideration operating conditions during t he stack tests, such as load and control efficiency

, and be aware when stack test conditions were not representative of operating conditions in 200 8

.

For MC8 or MC 9, e missions are calculated by the database through the use of a default or facility

- supplie d emission factor using the following equation for pollutant x :2

- 11 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

E

a = [ (Q

a ) * (EF

x ) * ( FP ) / 2000 ] * (1

- CE

x )

where:

E
a = Annual emissions, tons per year Q

a = Annual process throughput

EF

x = Emission f actor for pollutant x

FP = F uel parameter , such as percent sulfur or ash content

CE

x = Overall capture and control efficiency

When a facility chooses MC 8 for a process, i

- STEPS  automatically selects the emission factor associated with the process SCC and calculate s the emissions. For MC9 , facilities were required to document facility

- supplied emission factors. The emission factor must be documented by the facility or otherwise verified by DAQ

. If not, DAQ replaced it with the current i

- STEPS  SCC

emission factor. Facilities may choose to calculate emissions outside of i

- STEPS  and enter the emissions using MC3. If an emission factor is used by the facility to calculate the emissions, the

factor must be documented by the facility or otherwise verified by DAQ . If not, DAQ changed

the record to an MC8.



### 2.9 Technical Review of Submitted Data and Information

Once issues from the completeness determination were resolved, the technical review would begin. The technical review was conducted through a series of database queries. The query

results wer e exported to a spreadsheet for ease of review and to compare to previous years’ data.

The s preadsheet s allow ed DAQ inventory staff to identify missing, suspicious or conflicting data

. Any critical issues were identified and corrected in the database

. Que stionable data, missing information, and the correction of errors were handled in several ways. When a problem was identified, such as missing data, a typographic error, or other simple errors in the data, a phone

call or e

- mail to the facility was usuall y sufficient to resolve and document the issue. Usually no other correspondence was needed.

The following information was included in the technical review :

• General facility information ;

• Narrative descriptions of the following: group/point, process, SC C, SCC units, and pollutant;

• Design capacity and standard design capacity units ;

• Operating schedule, percent quarterly throughputs, and fuel sulfur and ash content;

• Monthly and annual throughputs provide d in the SCC units described;

• Process

- level annual em issions for all pollutants for each process;

• Stack ID and parameters;

• Emission calculation method;

• Abatement equipment information, including capture and control efficiencies for each pollutant;

• Calculations and documentation entered by the facility into a Notes field; and

• A summary page of facility

- wide annual emissions for each pollutant.2

- 12 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

The re were six general areas of data and information in the technical review, including f acility

g eneral, g roup/ p oint (emissions unit)

, p rocess u nit

, stack information

, p rocess u nit c ontrols and

p rocess u nit e missions . The review of each section is described in detail below.

2

. 9 .1 Facility General

The following facility general information was reviewed : facility name, facility site identification number, mailing addres s, year of inventory, North American Industry Classification System (NAICS) code , contact person

, and phone number. Any missing or questionable information,

such as NAICS code or an incorrect inventory year, was noted and resolved. As an example

, the

NAICS code was compared to a brief description of the facility’s business activity supplied by the facility. DAQ had previously determined facility coordinates and thus this information only needed to be updated for newly inventoried facilities.

2. 9 .2 Group/P oint (Emissions Unit)

Group information defines a piece of equipment, a group of related processes, or a particular activity at a facility. D esign capacity, and annual and seasonal operating information were reviewed individually and in context with other information in the Emissions Unit spreadsheet.

A description of the equipment or activity is provided along with the design capacity and design capacity units. If the design capacity is missing for combustion equipment, an attempt wa s made

to determine t he design capacity of the equipment by reviewing permits or contacting the facility

.

The operating schedule was reviewed for missing or inconsistent data. Hours per day and normal daily start and end times were also provided

. The annual hours operated is calculated by i

STEPS  from the hours per day, days per week and weeks per year the facility enters into the

system

. A facility could override this calculated value by entering the actual number of hours operated for the year, if the facility had accurate records

.

The percent quarterly throughput was corroborated with operating information. i

- STEPS 

enforce d a range of between 95 and 101 percent for the sum of the four quarterly throughputs. A review of the database indicated that all sums of the quarter ly throughputs were within the range

of 98 to 101 percent

. When necessary

, i n order to be consistent with the EIS requirements (EPA,

20 09 )

, the second quarter (March, April and May) and /or the fourth quarter (September, October and November) percent throug hputs were adjusted so the sum of all four quarters would equal 100 percent. The third quarter (summer season) was not adjusted, since it was assumed the facility would have provided an accurate summer season value.

2. 9

. 3 Process Unit

Numerous database queries and spreadsheets were developed to review the process unit level data reported by facilities. Th e information was re viewed individually and in context with other

information in this section and related sections such as the g roup/ emissions unit and stack

information. P rocess u nit information includes the process description, stack identifier, Source Classification Code (SCC ) and description, percent sulfur and ash (for combustion units), and2

- 13 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

monthly throughput for most processes. In a limited number of instances only annual throughput was provided.

The process description field is a text field that is used to describe a process in more detail than is defined by the SCC description

. A determination was made whether the process description provide d by the facility was consistent with the SCC description. As an example, the process description may mention No.6 oil for a piece of combustion equipment; and therefore the SCC description must be for combustion equipment burning No.6 oil.

In most cases mon thly throughputs were provided by facilities

. i

- STEPS  sum s the monthly throughputs and store s the value in the annual throughput field. In cases where there were significant changes in the group

- level emissions as compared to a previous year, the annual

t hroughputs were compared to previous data. If the comparison of throughput explains the
difference in emissions, such as fuel switching, or an increase or decrease in fuel usage, this was noted on the Administrative Completeness Determination page and adde d to the tracking spreadsheet.

Each SCC has associated standard units as defined by EPA in its master list of SCCs and are

contained within i

- STEPS  . Facilities are given the option within i

- STEPS  to change the units to make them appropriate to the data they are reporting. DAQ staff compared the SCC units as reported by the facility to the standard units. If the two values d id not match

, DAQ staff

determine d if the revised units were properly applied in the emission calculations

.

2.9.4 Stack Parameters

S tack parameters and associated group and process unit information were reviewed

. Each stack has an identification number and description assigned. The stack parameters include height above ground, diameter, exit gas temperature , velocity, and flow rate. If emissions were considered fugitive, then i

- STEPS  requires only a stack identification number , a release point type (fugitive) and a height value. A default of ten feet was used for stack height when no fugitive height was provided.

If no stack inform ation was provided for a process unit

, DAQ would use information provided for the process in previous years and make the appropriate link within i

- STEPS  between the

stack and process unit record s . If no previous year stack data exist ed in the database , a stack

record was created and linked to the process based on permit file information or subsequent discussions with the facility. During data entry of the process unit record by facilities, Terminal

Server Satellite i

- STEPS  flash e s a warning message, if a stack is not identified for the process.

2. 9

. 5 Process Unit Control Equipment

C ontrol information for controlled processes was reviewed . A control device identification
number, i

- STEPS  control device code, pollutant

- specific capture and control efficien cies, and a description of the abatement equipment were reviewed

. Control issues were flagged and

resolved

, if possible. Particulate, SO 2 , and NO

x control devices were evaluated to determine if

the control efficiency fell within a range expected for the id entified control device.2

- 14 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

2. 9

. 6 Process Unit Emissions

Process unit emissions and associated information by pollutant were reviewe d. The EIS pollutant code, pollutant name, the emission estimation method code, emission factor, the overall capture

and cont rol efficiencies, and annual emissions in tons per year were compiled in spreadsheets

. The capture and control efficiencies were compared to the process unit control section. Issues associated with pollutant code or capture and control efficiencies were fl agged, investigated, and

resolved.

In the review a process was flagged i f there was throughput or operating information that indicated a process was operating, but no emissions were provided. If emissions were expected, but not provided, the process unit emissions from the most recent year were checked. Usually, in cases such as this, the facility provided an explanation in the process unit or process emissions Notes field. An example of this would be when CEM s are used for NO

x or SO 2 emissions from

combus tion source s that utilize more than one type of fuel. A ll NO

x or SO 2 emissions would be reported under the major fuel burned. The secondary fuel would have a throughput, but no process unit emissions.

2.9.7 A Multi

- y ear Comparison of Facility Level Emissi ons

A spreadsheet of criteria pollutant f acility

- wide emissions in tons per year was created for the years 2002 through 2008

. Any significant differences in the 2008 emissions compared to the previous years ’ data were flagged. F uel switching, production c hanges

, or the addition of

controls , were the most common reasons for the observed differences.



### 2. 10 Technical Review Using Database Queries, Reports and Spreadsheets

N umerous database queries , reports and spreadsheets were created to identify informati on that appeared to be missing, in error or inconsistent with other related information. This included analysis of related operating schedule information.

If an issue initially identified by DAQ or the facility, and subsequently corrected in the i

- STEPS 

database by DAQ, had a significant impact on the facility’s reported total emissions

, DAQ

request ed documentatio n from the facility acknowledg ing the change in emissions. The documentation may be in the form of a letter, e

- mail, or facsimile from the faci lity. Title V

facilit ies were required to re submit a new emissions summary report signed by the Responsible

Official.

If issues were unable to be resolved with the facility, DAQ staff update d or modifie d the information submitted by the facility to the ex tent needed to develop emission estimates . This usually was acknowledged in correspondence with the facility.



### 2. 11 PM 2.5 

### Augmentation of Facility Reported Emissions

To insure PM 2.5 - PRI, PM 2.5 - FIL, and PM

- CON were calculated properly for all combustion and

non

- combustion sources, n umerous database queries and s preadsheets were developed to identify2

- 15 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

missing emissions or inconsistencies between the PM emission estimate s for a given process. Missing emissions were determined as follows :

• With the exception of gas e ous fuel fired external combustion processes, AP

- 42 PM 2.5 - FIL

and PM

- CON emission factors were available for nearly all external combustion

process es . If filterable or condensable emissions were not reported by the facility

, DAQ

staff calculated the se emissions using the AP

- 42 factors.

• F or e xternal combustion processes burning gaseous fuels

, PM 2.5 - PRI w as estimated using factors published in “ R evision of the PM Emissions From Natural Gas Combustion in the Final Version of the 2002 NEI ” ( EPA

, 2005 c ) and an EPA Excel file en titled “ Ratios to Adjust PM ” containing SCCs and PM 2.5 - PRI emission factors (EPA, 2005 d )

. If PM 2.5 - PRI

w as not reported, DAQ staff estimated these emissions using these factors. Specific

filterable and condensable factors are curren tly not available for gaseous fuels

.

• If PM 2.5 - PRI was missing, D AQ equated it to the sum of PM 2.5 - FIL and PM

- CON;

• In instances where a facility reported only PM 10 (PRI and/or FIL) D AQ assumed that

PM 2.5 conservatively equaled PM 10

.

Since primary emission s are the sum of the filterable and condensable component s
, queries and a spreadsheet were developed to insure that PM 2.5 - PRI matched the sum of its component s

.



### 2. 12 Review of NO

x 

### and SO 2 

### Emissions from EGUs and Other Large Sources

In 2002 there were 21 electric generation units ( EGUs ) in New Castle County

. The Madison

Street combustion turbine closed in 2004. D AQ staff conducted a review of NO

x and SO 2 emissions for the 20 remaining EGUs in New Castle County

. Most of t hese units report
emissions based o n continuous emissions monitoring ( CEM ) data to EPA through their Air Markets Program Data (AMP D ) website (EPA, 20 10 )

. The web site contains emissions data reported to EPA’s Acid Rain and NOx Budget Program s

. D AQ staff compared AMP D 2008

emissions to emiss ions reported to D AQ.

There were 18 New Castle County EGUs listed in AMPD t hat had annual 2008 NO

x and SO 2

e missions that could be compared to annual emissions reported to D AQ. An additional two units reported 2008 emissions for six months (April

– Septe mber)

. For those units that only reported

six

- month emissions, an annual estimate was needed to directly compare to the facility reported

value. A NO

x emission factor was calculated in pounds of NO

x emissions per MM Btu using the

six

- month emission amount d ivided by the heat content of the fuel listed in AMP D for the six months. Annual emissions were then calculated by applying this factor to the annual fuel heat content reported in i

- STEPS 

.

There were five additional units ( non

- EGU ) report ing annual emiss ions under the NO

x Budget Program. These units were located at the Delaware City Refinery (Premcor) and were evaluated using the same methodology as above.

Differences in NO

x emissions reported to DAQ compared to EPA’s AMPD data were expected

for some unit s since the Acid Rain Program requires the use of the unit’s maximum load value as a default at times when the CEM is not functioning properly. DAQ staff worked with these

facilities to determine the best estimate of actual NO

x emissions for the inventory.2

- 16 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X



### 2.1 3 Methods for Correcting Erroneous Data

Questionable data, missing information, and the correction of errors were addressed in several ways. In all cases D AQ maintain ed a paper or electronic trail of changes made by staff or the facility. When a prob lem was identified, such as missing data, typographic error, or other simple errors in the data, a phone call or e

- mail usually was sufficient to resolve and document the issue. Usually no other correspondence was needed.

If an issue had a significant imp act on the facility’s initially reported total emissions

, D AQ

request ed documentatio n from the facility acknowledg ing the change in the emissions. The documentation may be in the form of a letter, e

- mail, or fa csimile from the facility. T V facilit ies

were required to re submit a new emissions summary report signed by the Responsible Official.

For submissions where there were extensive problems

, a facility may have been asked to meet

with D AQ staff to outline the issues and to develop ways to address the pro blems. Once issues

ha d been discussed and resolved, the facility may have be en asked to resubmit information through the on

- line reporting system. D AQ staff w ou l d reopen the facility ’s record within the

Terminal Server Satellite i

- STEPS  on

- line system to allow access for corrections and updates.

If issues were unable to be resolved with the facility, D AQ staff update d or modifie d the information submitted by the facility to the extent needed to develop emission estimates . This usually was acknowledged in correspondence with the facility.



### 2.1 4 Facility Site and Stack Coordinates

Facility and stack coordinates were verified during previous PEI inventories. C oordinates were verified through the use of high

- resolution aerial photography that DNREC had prev iously placed in GIS. Existing site coordinates contained in i

- STEPS  were plotted and superimposed on the aerial photography. Staff from the Engineering and Compliance (E&C) Branch met with inventory staff and reviewed the resulting facility locations on the aerial photographs. E&C staff were knowledgeable enough with the layout of the facilities they permit to identify them on the photographs. Based on the permitting engineer’s advice, the facility point was moved, if necessary, to place it over the geogr aphic center of emissions activity at the facility. For several facilities, ground reconnaissance was performed to verify a facility’s location.

Two New Castle County facilities , Corrado Construction and Micropore, were new to emissions reporting for 2008 and their coordinates were determined using Google Earth.



### 2.1 5 Database Management

The 200 8 point source inventory database was managed using i

- STEPS  for Microsoft  SQL Server 5.0 data management system, associated utilities and applications including the Terminal

Server Satellite i

- STEPS  on

- line system and Microsoft  Access

. Microsoft  Access was used to create queries and reports from the SQL tables

. After the administrative review and a check of

reasonableness o f the facil ity

- wide emissions w ere com plete d for most facilities

, a cop y of the2

- 17 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

Terminal Server database w as produced as an archive of data reported by the facilities. A second

database was created as the 200 8 production database for purposes of developing the several

inventor ies required for 2008 . This database was managed using the Agency i

- STEPS 

.

DNREC ’s Office of Information Technology (OIT) provides computer network support and routine database management functions. Joseph Handley, Application Support Project Leader , of

the OIT office se rved as liaison between D AQ inventory staff and OIT

. Mr. Handley also helped with user network, Internet connectivity

, and firewall issues.

i

- STEPS  utilizes relational database s and contain s functions and utilities to maintain database integrity. There a re field

- sensitive look up tables, and data element and record validation routines that ensure valid data and enforce database integrity. The system has a record level audit trail

that document s changes made to the records, identifies the user and the dat e the change was

made. In addition

, there are comment/note windows for each record where text can be added by

the user and D AQ staff to clarify information provided or supply additional documentation.



### 2.16 Data Submission to EPA’s E mission s I nventory S ystem

E missions Inventory System (EIS) staging tables (EPA, 2009) in Microsoft  Access format were generated from the i

- STEPS  database. EIS is the EPA’s air emissions inventory data management system. An application developed in conjunction with the Department’s Information Technology staff was used to map information in the i

- STEPS  database to the EIS staging tables. EPA’s EIS Bridge T ool was then used to prepare emissions inventory data in the staging tables for submission to EIS. The EIS Bridge Tool transform s emissions inventory data

into CERS XML files.

The XML file s w ere submitted to the EIS QA environment to obtain several feedback reports that would identify errors and issues associated with the submitted files. All significant issues

associated with man datory and necessary fields were reviewed and resolved prior to submission

of the XML files to the EIS Production environment

. Emissions data submitted to the EIS

Production environment are used by EPA to populate the National Emissions Inventory.

Producti on submissions of the 2008 emissions data and facility information were initially made during May 2010 to meet the June 1, 2011 EPA reporting requirement, while final corrections

and additions were sent to EIS between December 2010 and January 2011.



### 2.17 Sourc e Sector Discussions

All New C astle County facilities associated with hot

- mix asphalt production and electric generation are included in the 200 8 PM 2.5 Attainment Year SIP point source inventory. Details of these industry sectors are presented below.

2.1 7 .1 Hot

- m ix Asphalt Plants

H ot

- mix asphalt (also known as asphaltic concrete or blacktop) production facilities have been historically tracked and permitted by the Department as point sources

. There were five facilities2

- 18 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

in New Castle County for 200 8 and these are all included in the point source inventory . Delaware

facilities employ both drum mixer and rotary dryer process es in the production of hot

- mix asphalt . The appropriate SCCs were used to identify these processes. In 200 8

, all New Castle County fac ilities collectively emitted 12 tons PM 2.5 - PRI, two tons of SO 2

, and 13 tons of NO

x .

The activity data forms were used to obtain throughput data from hot

- mix asphalt plants. Data from the completed forms were entered into i

- STEPS  and EPA standard emissio n factors were

used to calculated emissions within i

- STEPS  based on the SCC provided by the facility. In a

few instance emissions were based on stack tests.

Many asphalt plants employ crushing operations powered by diesel engines. The emissions f rom thes e diesel engines were estimated based on reported fuel usage and FIRE 6.24 emission factors.

2. 1 7

. 2 Electric Generating Units (EGUs)

New Castle County EGU s are represented by two large generating stations ( Calpine Edge Moor and Calpine Hay Road ), three Calpine peaking unit stations

, and generators at the Delaware City Refinery (Premcor)

. In total, there are 20 EGUs located at six facilities in New Castle County included in the point source inventory . EGUs in Delaware include external combustion boilers and

combustion turbines

. Small diesel generators used by businesses and institutions for emergency backup power and load management are not included in this discussion, and are generally not reported to the point source inventory. 200 8 PM 2.5 , SO 2 , and NO

x e missions from New Castle County EGUs are presented in Table 2

- 3

. Note that PM 2.5 emissions given in the following tables represent primary emissions (i.e. , filterable plus condensable).

Table 2

- 3

. 200 8 PM 2.5 and Precursor Emissions for New Castle County EGUs

Annual Emissions, TPY Facility Name Unit Description PM 2.5 SO 2 NO
x Calpine Christian a Turbine #11 < 1 < 1 1
Turbine #14 < 1 < 1 1 Calpine Delaware City Turbine #10 < 1 < 1 1

Calpine Edge Moor Boiler #3 107 2,011 525

Boiler #4 242 4,923 1, 292
Boiler #5 11 176 163

Turbine < 1 < 1 < 1

Calpine Hay Road Turbine #1 7 2 65

Turbine #2 7 2 70
Turbine #3 7 1 47
Turbine #5 5 2 7
Turbine #6 5 2 7
Turbine #7 5 1 6 Calpine West Substation Turbine 1 1 1

Delaware City Refinery Boiler #1 1 4 9 200

Boiler #2 11 15 41
Boiler #3 15 54 254

Boiler #4 3 11 184

Turbine #1 28 202 83

Turbine #2 13 49 47

Total 479 7

, 463 2

, 9942

- 19 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

E missions from New Castle County EGUs represent 71% and 54 % of the county

- wide point source

emissions of SO 2 and N O

x , respectively. Most p eaking units operate exclusively during the summer to meet periods of high demand. Their operation may coincide with days when air quality is most likely to experience an exceedance of the daily fine particulate standard.

2.1 7

. 3 Em issions by Source Sector

Table 2

- 4 provides New Castle County total PM 2.5 - PRI, SO 2 , and N O

x
, emissions grouped by source sector as defined by the first three digits of the SCC codes assigned to each process.

The source sectors include various combustion and manufacturing processing, material storage and transfer operations, and solid waste disposal. Combustion processes account for the majority of the particulate, SO 2 , and NO

x emissions in New Castle County from the point source sector.

Table 2

- 4 . 200 8 PM 2.5 and Precursor Emissions b y Industry Sector

SCC SCC Description Annual Emissions, TPY

PM 2.5 SO 2 NO
x 101 External Comb. Boilers

- Utilities 402 7

, 199 2

, 659

102 External Comb. Boilers

- Industrial 269 1

, 120 2

, 061

103 External Comb. Boilers

– Co mmercial 1 28 51

105 Ex. Comb. Boilers

- Space Heaters < 1 < 1 16

201 Internal Comb. Engines

- Utilities 37 12 208

202 Internal Comb. Engines

- Industrial 41 252 145

203 Internal Comb. Engines

- Commercial < 1 < 1 4

270 Internal Comb. Engines

– Off

- ro ad 1 12

301 Chemical Manufacturing 55 78 42

303 Primary Metal Production 56 42 190

304 Secondary Metal Production < 1

305 Mineral Products 16 2 13

306 Petroleum Industry 199 1782 164

307 Pulp, Paper and Wood Products < 1

308 Rubber and Misc. Pl astics Products < 1 < 1 1

309 Fabricated Metal Products 1

385 Cooling Tower 1 5

399 Misc. Manufacturing < 1

402 Surface Coating Operations 7 < 1 5

406 Transport/Marketing of Petrol. Prod. < 1 < 1 1

501 Solid Waste Disposal

- Government 1 7 2

5 02 Solid Waste Disposal

– Comm./Inst. 8 24 11

503 Solid Waste Disposal

- Industrial 2 28 4

6 82 Miscellaneous Processes < 1

Statewide Total 1

, 1 09 10

, 576 5

, 589



### 2.18 Emissions by Facility

Facility

- level annual e missions for the 58 facilities included in th e 200 8 PM 2.5 Attainment Year

SIP inventory are provided in Tables 2

- 5 . For recent facility name changes, the former name is included in parentheses.2

- 20 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

Table 2

- 5

. 200 8 PM 2.5 and Precursor Emissions for New Castle County Facilities

Annual Emissions, TPY

Fac ility Name PM 2

. 5 SO 2 NO
x A.I. DuPont Hospital 1 25 13 Amtrak Maintenance Facility < 1 < 1 4

Ashland Research Center ( Hercules ) 1 9 6

Astrazeneca Pharmaceuticals < 1 < 1 7 BASF ( Ciba Specialty Chemicals ) 2 < 1 10 Calpine

– Christiana ( Conectiv ) < 1 < 1 2 Calpine

- Delaware City ( Conectiv ) < 1 < 1 1 Calpine

- Edge Moor ( Conectiv ) 360 7,110 1,980 Calpine

- Hay Road ( Conectiv ) 36 10 2 02 Calpine

- West Substation ( Conectiv ) 1 1 Christiana Hospital < 1 4 16

Christiana Materials 3 1 3 Chrysler ( Daiml erChrysler ) 3 24 34

Clean Earth of New Castle 8 24 11

Contractors Materials 2 < 1 2

Corrado Construction < 1 < 1 1 Croda (Uniqema) 1 7 49

Dassault Falcon Jet < 1 < 1 1 Delaware City Refinery (Premcor) 446 2,548 2,525 Delaware City Terminal (Premcor ) < 1 < 1 < 1

Del

. Correctional Center

- Smyrna < 1 < 1 6 Delaware Recyclable Products 1 28 3

Diamond Materials 5 1 9 DSWA Cherry Island Landfill 1 7 1

DuPont

- Chestnut Run 8 140 45

DuPont

- Edge Moor 17 17 32

DuPont

- Red Lion < 1 47 13

DuPont B uilding

- Wilmington 3 57 19 DuPont Experimental Station 27 438 156

DuPont Stine

- Haskell Lab 1 8 16

E

- A

- R Specialty Composites < 1 < 1 1

Eastern Shore Natural Gas

– Del City < 1 < 1 4 Edgemoor Materials 2 < 1 3 Evraz Claymont Steel 64 42 190

FMC 17 < 1 30

Formosa Plastics 26 < 1 25

FP International < 1 < 1 1

General Motors 7 < 1 25 Honeywell International < 1 < 1 Johnson Controls Battery < 1 < 1 3

Kuehne Chemical < 1 < 1 1

MacDermid < 1 < 1 3 Magellan Terminals < 1 5 3 Medal Air Liquide < 1 < 1 4 Motech Americas ( GE Energy ) < 1 < 1 < 1

continued next page2

- 21 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

Table 2

- 5 . continued

Facility Name Annual Emissions, TPY

PM 2

. 5 SO 2 NO
x Noramco < 1 < 1 1

NVF

– Yorklyn < 1 < 1 < 1

Occidental Chemical < 1 < 1 < 1 Prince Minerals (Americ an Minerals) < 1 < 1 < 1 Printpack < 1 < 1 2

Pure Green Industries < 1 < 1 1

Rohm & Haas Electronic Materials < 1 < 1 4 St. Francis Hospital < 1 < 1 4

Sunoco 66 17 83 University of Delaware

- Newark < 1 3 22 Veterans Administration Hospital < 1 < 1 4 Wilmington Hospital < 1 < 1 7 Wilmington WWTP < 1 1 2
New Castle County Total 1,109 10,576 5, 589

2.18.1 Sources of PM 2.5 Emissions

The Delaware City Refinery is the largest source of PM 2.5 - PRI, emitting 446 tons in 2008. 56% of these emissions (263 tons) are associated with the catalytic cracker and coker CO boilers. The Calpine Edge Moor/Hay Road complex is the second largest PM 2.5 - PRI source in Delaware. The

coal

- fired units at th is facility ha ve particulate controls , which have the ability to capture

f ilterable particulates only

. Calpine EM/HR emitted 396 tons of PM 2.5 - PRI of which 3 08 tons

were condensables

. All other facilities in New Castle County emitted less than 100 TPY of NO

x in 2008.

The top ten PM 2.5 sources, representing 9 7 % of county

- wide an nual PM 2.5 emissions for 200 8 from point sources in New Castle County , are presented in Table 2

- 6 and in Figure 2

- 1.

Table 2

- 6

. 200 8 New Castle County Facility Ranking of PM 2 .5 Annual Emissions

Facility Name Major Activity TPY Delaware City Refinery / Terminal Petroleum Refinery 446

C alpine

– Edge Moor/Hay Road Electricity Generation 396

Sunoco Petroleum Refinery 66

Evraz Claymont Steel Steel Manufacturing 64 DuPont Experimental Station R&D / Hazardous Waste Incinerator 27

Formosa Plastics PVC Ma nufacturing 26 DuPont Edge Moor Chemical Manufacturing 17

FMC Chemical Manufacturing 17

DuPont Chestnut Run Research & Development 8

Clean Earth of New Castle Contaminated Soil Remediation 8

All Other Facilities 34 County Total 1

, 1 092

- 22 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

Figure 2

- 1

. 200 8 PM 2.5 Annual Emissions by Facility

2.1 8 .2 Sources of SO 2 Emissions

The top three facilities account for 96% of the county

- wide annual SO 2 emissions from point

sources in New Castle County

. The top facility, Calpine Edge Moor/Hay Road power plants

, burn ing coal in 2008 to generate electricity, accounted for 67% of county SO 2 emissions

. The Delaware City Refinery accounted for another 25% of the county total SO 2 emissions. The third largest source of SO 2 emissions is the DuPont Experimental Station

, which utilizes residual oil in

its several boilers

. The top ten SO 2 sources in New Castle County are presented in Table 2

- 7 and in Figure 2

- 2.

Table 2

- 7

. 200 8 New Castle County Facility Ranking of SO 2 Annual Emissions

Facility Name Major Activity TPY

C alpine Edge Moor/Hay Road Electricity Generation 7

, 120 Delaware City Refinery Petroleum Refinery 2

, 548 DuPont Experimental Station R&D / Hazardous Waste Incinerator 438

DuPont Chestnut Run Research & Development 140 DuPont Building Wilmington Commerc ial Building 57

DuPont Red Lion Chemical Manufacturing 47 Evraz Claymont Steel Steel Manufacturing 42 Delaware Recyclable Products Construction Debris Landfill 28 A.I. DuPont Hospital Health Services 25

Clean Earth of New Castle Contaminated Soil Reme diation 24

All Other Facilities 107 County Total 10

, 5762

- 23 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

Figure 2

- 2

. 200 8 SO 2 Annual Emissions by Facility

2.1 8 .3 Sources of NO

x Emissions

The largest source of NO

x emissions in New Castle County for 2008 is the Delaware City

R efinery. A large majority of emissions (7 1 %) from the refinery come from just a few processes, including the catalytic cracking unit, the fluidized coking unit, and four boilers used for electricity generation. The second largest source of NO

x emissions is the Calpine Edg e Moor/Hay

Road electric generation complex. The refinery and Calpine EM/HR combined account for 84%

of NO

x emissions from point sources in New Castle County.

The top ten NO

x sources, representing 9 5 % of county

- wide NO

x emissions for 200 8 from New

Castle County point sources

, are presented in Table 2

- 8 and in Figure 2

- 3

.



### 2.19 Closed Facilities

Several facilities included in the 2008 PM 2.5 Attainment Year SIP inventory have since permanently closed. Table 2

- 9 presents a list of closed facilities and the month and year operations ceased. For historical context, all New Castle County facilities that reported for 2002 and 2005 that

have since closed are also included in Table 2

- 9.2

- 24 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

Table 2

- 8

. 200 8 New Castle County Facility Ranking of NO x Annual Emissi ons

Facility Name Major Activity TPY Delaware City Refinery Petroleum Refinery 2

, 525 Calpine Edge Moor/Hay Road Electricity Generation 2

, 182

Evraz Claymont Steel Steel Manufacturing 190 DuPont Experimental Station R&D / Hazardous Waste Incinerator 15 6

Sunoco Petroleum Refinery 83

Croda Chemical Manufacturing 49

DuPont Chestnut Run Research & Development 45 Chrysler Automobile Assembly 34 DuPont Edge Moor Chemical Manufacturing 32

General Motors Automobile Assembly 25

All Other Facilities 268 County Total 5

, 589

Figure 2

- 3

. 200 8 NO x Annual Emissions by Facility2

- 25 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

Table 2

- 9

. Reporting Facilities That Have Ceased Operations

Facility Name Date Closed

Metachem Products May 2002 Lafarge November 2002

Westvaco May 2003

Kaneka July 2003

VPI Film (VPI Mirrex) July 2003 Wilmington Piece Dye September 2003

General Chemical June 2004

Laidlaw Sep tember 20 04

Conectiv

- Madison Street December 2004 Industraplate Mar ch 20 05

Ametek October 2005 Hardcore Composites January 2006 Spatz Fiberglass December 2007

PTFE July 2008
CPI (Unisource) October 2008

Occidental Chemical October 2008 Pepsi Cola Bottling November 2008 NVF Yorklyn March 2009 Chrysler (DaimlerChrysler) December 2009

Tilcon

– Terminal Avenue June 2011



### 2. 2 0 Refere nces

DNREC, 200 6

. Regulations Governing the Control of Air Pollution, Regulation No. 1144

– Control of Stationary Generator Emissions

, Delaware Department of Natural Resources and Environmental Control, Division of Air Quality, Updated to November 2006

.

EPA, 1991 a

. Emission Inventory Requirements for Ozone State Implementation Plans , EPA

450/4

- 91

- 010, USEPA, Office of Air Quality Planning and Standards, Research Triangle
Park, N.C., March 1991.

EPA, 1991 b

. Procedures for the Preparation of Emission Inv entories for Carbon Monoxide and Precursors of Ozone , Volume I: General Guidance for Stationary Sources, EPA

- 450/4

- 91

- 016, USEPA, Office of Air Quality Planning and Standards, Research Triangle Park, N.C., May 1991.

EPA, 1997

. Emissions Inventory Improv ement Plan (EIIP), Volume II: Point Sources Preferred

and Alternative Methods , Chapter 1, EPA

- 454/R

- 97

- 004b, USEPA, Office of Air Quality Planning and Standards, Research Triangle Park, N.C., July 1997.

EPA, 2005 a. TANKS Version 4.09D, Windows

- based comp uter software program for estimating VOC emissions from storage tanks, 2005.2

- 26 2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

EPA, 2005 b

. Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations

, EPA

- 454 /R

- 05

- 001, USEPA, Emissions Inventory Group Emissions, Monitoring and Analysis Division, Office of Air Quality Planning and Standards, Research Triangle Park,
NC, November 2005.

EPA, 2005 c

. Revision of the PM Emissions From Natural Gas Combustion in the Final Version of the 2002 NEI , USEPA, Emissions Inventory Group, Office of Air Quality Planning and Standards, Research Triangle Park, NC, August 2005. ftp://ftp.epa.gov/EmisInventory/ 2002finalnei/documentation/point/pm_adjustment_2002_nei.pdf

EPA, 2005 d

. 2002 Final NEI Documentation Containing Ratios to Adjust PM Values for

Natural Gas Combustion , Excel file, Roy Huntley, August 2005., USEPA, E missions Inventory Group, Office of Air Quality Planning and Standards, Research Triangle Park, NC, August 2005. ftp://ftp.epa.gov/EmisInventory/2002finalnei/documentation/point/aug mentation_point/ratios_to_adjust_pmvalues_in_nei_for_naturalgas_combustion082005.xls

EPA, 2008

. Air Emission Reporting Requirements (AERR)

– Final Rule , U.S . Environmental Protection Agency, 40 CFR Part 51, Vol. 73, No 2143, December 17, 2008.

EPA, 2009: 2008 National Emissions Inventory, Emissions Inventory System Implementation Plan, Section 7 Reporting Instruction for Point Emissions

, Revised, August 3, 2009

. http://www.epa.gov/ttn/chief/net/neip/index.html

.

EPA, 2010. CEM Data for the Acid Rain and NOx Budget Programs, Clean Air Markets
Division, http://ampd.epa.gov/ampd/QueryToolie.html , Office of Air and Radiation,
USEPA, accessed 2010.

UN, 1998. Kyoto Protocol to the United Nations Framework Convention on Climate Change

, Annex A, United Nations, 1998.2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTOR Y FOR PM 2.5 , SO 2 , & NO
X

3

- 1 

### S ECTION 

### 3

S TATIONARY 

### N ON



### - P OINT 

### S OURCES

Stationary non

- point source s represent a large and diverse set of individual emission source categories. A non

- point source category is either represented by small facilities too numerous to individually inventory, such as commercial cooking at restaurants and fuel combustion at a variety

of small businesses , or is a common activity, such as residential open burning

. Emissions from the

non

- point source categories were estimated at the county level.



### 3.1 Sour ce Categories

There are a number of non

- point source categories which contribute emissions of PM 2.5 , SO 2 , and

NO

x . These categories can be grouped into several category types. These include:

• Fuel Combustion

– The combustion of fuels in industrial, commer cial, institutional, and residential furnaces, engines, boilers, wood stoves, and fireplaces create emissions

of PM 2.5 , SO 2 , and NO

x .

• Open Burning

– Open burning create s emissions of PM 2.5 , SO 2 , and NO

x . Open burning categories include trash burning, pre scribed burning, burning of land clearing

debris , wildfires, and house and vehicle fires.

• Fugitive Dust

– Primary crustal particulate is created from construction activities, agricultural production, and as a result of vehicle traffic. Fugitive dust is la rgely coarse material, with only a small percentage being fine particulate.

Individual facilities are typically grouped with other like sources into a source categor y

. S ource categories are grouped in such a way that emissions are estimated collectively u sing one methodology. For the 200 8 inventory , the distinction between point and non

- point was defined by a n annual emission threshold based on recent point source data (see Section 2 for point source criteria)

. Table 3

- 1 lists the source categorie s for whi ch PM 2.5 , SO 2 , and NO

x for New Castle County were estimated.

Table 3

- 1. Non

- point Source Categories Inventoried

Agricultural Burning Residential Construction

Agricultural Production Residential Fuel Combustion

Commercial Construction Residential Op en Burning
Commercial Cooking Residential Wood Combustion

Commercial Fuel Combustion Road Construction

Industrial Fuel Combustion Structure Fires
Land Clearing Debris Burning Vehicle Fires

Paved & Unpaved Road Dust Wildfires

Prescribed Burning2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTOR Y FOR PM 2.5 , SO 2 , & NO
X

3

- 2 Ther e were several source categories evaluated, but not included, in the non

- point source inventory.

These include :

• Crematories

– While there are at least a dozen human/pet crematories and several laboratory animal incinerators in Delaware, DNREC was unable t o locate emission factors for ozone precursors. Emissions from fuels used at these facilities are included in the commercial fuel combustion category.

• Feed Mills and Concrete Plants

- These industry sectors were considered a source of particulate matter, both from material handling processes and fugitive dust (i.e., storage piles). Several large feed mills in Delaware already met the criteria for reporting as a Title V facility due to combustion emissions from process boilers and grain dryers. The lack of quality emissions data (i.e., emission factors) for feed mills persuaded DAQ from inventorying smaller feed mills. Lack of data was also the reason for not further considering concrete plants.

• Slash Burning

- No activity for the burning of slash from logg ing for future silvicultural operations was identified. This was confirmed by the Delaware Division of Forestry. However, recently logged lands are occasionally converted to agriculture. This activity, previously reported as slash burning, is now reported under the land clearing debris burning category.



### 3.2 Emission Estimation Methodologies and Activity Data

The 2005 Delaware Periodic Emission Inventory served as the starting point for non

- point source category selection and methodology development. One new category, a gricultural b urning, was

added to the non

- point sector. In 2007 a gricultural b urning was specifically delineated on the prescribed burning approval application form. This allowed DAQ to track the burning of woody debris specific to agricultural activities separate from other prescribed burning activities and other land clearing debris burning, (the latter is not permitted under Delaware Air Regulation 1113. )

New methods were applied to some existing source categories, and emission factors were updated

where available. N ew methods and emission factors came primarily from current Emission Inventory Improvement Program, Volume III document s and documented projects performed by

the California Air Resource Board (CARB)

. Other sources of information included the Compilation of Air Pollutant Emission Factors, Volume I ( AP

- 42 ), the Factor Information Retrieval System (FIRE), and several projects performed by the Mid

- Atlantic Regional Air Manage ment Association (MARAMA) and EPA.

Emissions from m ost n on

- point source categories were estimated by multiplying an indicator of collective activity by a corresponding emission factor . An indicator is any parameter associated with the activity level of a source, such as production, employment, fuel usage

, or po pula tion that can be

correlated with the emission s from that source. The corresponding emission factors are per unit of production, per employee, per unit of commodity consumed, or per capita, respectively. T he basic equation that was applied to emission development for most non

- point source categories is as

follows:2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTOR Y FOR PM 2.5 , SO 2 , & NO
X

3

- 3 Emissions (E) = Activity Data (Q) x Emission Factor (EF)

If a source category had a regulatory control placed on it at the Federal or State level, the equation expands to the followi ng:

E = Q x EF x [1

- (CE)(RE)(RP)]

where: CE = control efficiency

RE = rule effectiveness RP = rule penetration

The control efficiency (CE) represents the typical emissions reduction achieved as compared to the

other wise uncontrolled emissions. A control may be a piece of equipment, such as a cyclone used to capture particulates , or it may be an operational control, such as low sulfur fuel

.

Rule effectiveness (RE) reflects the ability of the regulatory program to ach ieve all emissions reductions that could have been achieved by full compliance with the applicable regulations at all

sources at all times. If a rule is not being followed by all of the regulated community, then emissions will be higher than would otherwi se be if there was 100% compliance. As an example,

while the burning of trash is illegal under any circumstances in Delaware, the practice of burning household trash in backyard burn barrels still takes place in many rural areas of the State.

Rule penetra tion (RP) represents the percent of sources within a source category that are subject to the rule that requires control. As an example, while businesses and developers are prohibited from burning woody debris, Delaware residents may burn small piles of bra nches and limbs d uring certain times of the year

. Therefore, RP is less than 100%. In the case of the burning of trash or leaves, no person or business is exempt, and thus RP is 100%.

A major portion of the work involved in creating the 200 8 non

- point sou rce inventory was in collecting activity data for each source category. The a ctivity data gathered was related to the type

of emission factors available and

, in many cases, obtained from local sources. Surveys, letters, e

mails , and phone calls to individu al businesses to obtain representative data for a source category was a technique used for several source categories. The type of activity data and the data source for each category is provided in Table 3

- 2.

Point source backout was performed for the indu strial and commercial fuel combustion categories to avoid double counting of emissions between point and non

- point sources

. Point source fuel

usage w as backed out f rom fuel consumption data obtained from the U.S. Department of Energy’s (DOE) E nergy I nforma tion A dministration (EIA).



### 3.3 2008 Emissions Summary

Table 3

- 3 provides a summar y of the 200 8 annual (tons per year, TPY) emissions for each non

point source category for New Castle County. The totals may not match the sum of the

individual values due t o independent rounding.2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTOR Y FOR PM 2.5 , SO 2 , & NO
X

3

- 4 Table 3

- 2. Summary of 2008 Non

- point Source Activity Data

Source Category Activity Data Source of Activity Data

Agricultural Burning Acreage and vegetation type DAQ Area Source Compliance Program
Agricultural Production Planted and harvested crop acreage Delaware Department of Agriculture

Commercial Construction Value of construction put in place; construction employment;

construction businesses US Census Bureau County Business Patterns; Delaware Department of

Labor

Commercial Cooking Population Delaware Population Consortium

Commercial Fuel Combustion Fuel consumption DOE Energy Information Admin.

Industrial Fuel Combustion Fuel consumption DOE Energy Information Admin.

Land Clearing Debris Burning Acreage disturbed during road, commercial, and residential

construction DAQ data calculated for the construction dust categories
Paved & Unpaved Road Dust Vehicle miles traveled Delaware Department of Transportation
Prescribed Burning Acreage and vegetation type DAQ Area Source Compliance Program

Residential Construction Residential building permits US Census Bureau

Residential Fuel Combustion Fuel consumption DOE Energy Information Admin.
Residential Open Burning Rural households US Census Bureau

Residential Wood Combustion Occupied households Delaware Population Consortium

Road Construction Highway capital outlays Federal Highway Administration

Structure Fires Number of structures fires Delaware Fire Marshal and DAQ Area Source Compliance Program

Vehicle Fires Number of vehicle fires Delaware Fire Marshal

Wildfires Acreage and vegetation type Delaware Division of Forestry

Combustion processes and fugitive dust account for 84% of the direct particulate emissions in New Castle County from the non

- point sector. Road dust and r esidential wood combustion are the two largest non

- point source category of direct PM 2.5 . Figure 3

- 1 presents the top eight PM 2.5 non

- point

sources in New Castle County for 200 8

.

Figure 3

- 1. 200 8 New Castle County PM 2.5 Emissions by

Non

- point Source Category2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTOR Y FOR PM 2.5 , SO 2 , & NO
X

3

- 5 The important precursor pollutants to the formation of secondary fine particulate emissions are SO 2 and NO

x . The non

- point sector is a small contributor of these pollutants to the overall county totals. Nearly all of the SO 2 and NO

x emissions result from the combustion of fossil fuels.

Table 3

- 3 . Summary of 200 8 New Castle County Emissions
from Non

- point Sources

Source Categories PM 2.5 SO 2 NO X TPY TPY TPY

FUEL COMBUSTION

Commercial/Institutional 3 16 246

Industrial 3 34 445

Residentia l Fossil Fuel 20 339 535

Residential Wood 404 8 47

Fuel Combustion Total 4 29 399 1

, 273

OPEN BURNING

Agricultural Burning 4

--- 1
Land Clearing Debris Burning 0

--- 0
Prescribed Burning 43 3 11
Residential Open Burning 2 < 1 < 1

Structure Fires 3

--- < 1

Vehicle Fires 4

--- < 1

Wildfires 1 < 1 < 1

Open Burning Total 5 6 3 1 3

FUGITIVE DUST

Agricultural Production 48

--- --- Commercial Construction 63

--- --- Paved and Unpaved Road Dust 413

--- --- Residential Construction 2

--- --- Road C onstruction 51

--- --- Fugitive Dust Total 576

--- ---
OTHER SOURCES
Commercial Cooking 131

--- ---
Other Sources Total 131

--- ---

NON

- POINT SECTOR TOTAL 1,191 402 1

, 2872008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

4

- 1 

### S ECTION 

### 4

N ON



### - R OAD 

### M OBILE 

### S OURCE S

Non

- road mobile sources represent a large and diverse set of off

- road vehicles and non

- stationary equipment. Emission estimates of PM 2.5 , SO 2 , and NO

x for this source sector account for exhaust

emissions from engine fuel combustion

.



### 4.1 Source Categories

Non

- road vehicles and equipment are grouped into four source category types for the purpose of developing emission estimates. These include:

• Aircraft

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

category.

• Locomotives

– Commercial line haul and yard locomotives are considered under this

source category.

• Commercial Marine Vessels (CMVs)

– Various types of vessels that navigate the Delaware Bay and River and the Chesapeake and Delaware Canal are included under this source category. Recreational boats are included in the next category.

• Other Off

- road Vehicles and Equipment

– All other off

- road emission sources are accounted for through the use of EPA’s NONROAD model. The NONROAD model compiles off

- road equipment pertinent to Delaware into the following subcategories:

• Recreational (land

- based) ;

• Construction;

• Industrial;

• Lawn and Garden;

• Agricult ural;

• Commercial;

• Logging;

• Airport Ground Support;

• Recreational Marine; and

• Railway Maintenance.

Individual equipment SCCs covered in the NONROAD model are further broken down by the fuel type, including 2

- stroke gasoline, 4

- stroke gasoline, d ie sel, lique fied petroleum gas (LPG), and compressed natural gas (CNG).



### 4.2 Emission Estimation Methodologies

The 200 5 Delaware Periodic Emission Inventory served as the starting point for non

- road source category selection and methodology development. No new sources were added to Delaware’s off

-2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

4

- 2 road mobile source inventory. However, n ew versions of EPA’s NONROAD model and the Federal Aviation Administration’s (FAA) Emissions and Dispersion Modeling System (EDMS) were used

for 2008

.

Similar to the estimatio n of stationary non

- point emissions, off

- road equipment emissions were estimated by multiplying an indicator of collective activity within the inventory area for a source category by a corresponding emission factor

. The indicator s of activity for off

- road sources include landing and take

- offs (LTOs), vessel port

- of

- calls, time

- in

- mode (TIMs, which are pertinent to aircraft and CMVs), gross ton miles (locomotives), equipment populations and economic activity (both pertinent to NONROAD equipment) that can be correlated with the emission s from that

source. The corresponding emission factors are amount of pollutant (either grams or pounds) per unit of fuel used (locomotives and military/commercial aircraft) , per LTO (air taxi and general aviation) or per unit of power output in brake horsepower or kilowatt

- hours (NONROAD equipment and CMVs , respectively ).

A major portion of the work involved in creating the 200 8 non

- road source inventory was in collecting activity data for each source category. The activity data gathered was related to the type of emission factors available and, in many cases, obtained from local sources. More information

about gathering activity data for each source category is presented below

.

There are no point source data t hat must be backed out of the non

- road mobile source sector. Even though larger airports may report as a point source, their reported point source emissions do not include ground support equipment or aircraft engine emissions. Also, aircraft emissions are estimated only for LTOs that take place at a Delaware airport. Emissions from aircraft that transit Delaware airspace are not included in Delaware’s inventory.

4. 2.1 NONROAD Model Equipment

DAQ used NONROAD200 8 a to develop 200 8 annual emission estimates for New Castle County

. Most equipment covered by the NONROAD model is powered by diesel

- fueled compression

- ignition engines or gasoline

- fueled spark

- ignition engines. Engines fueled by compressed natural gas (CNG) and liquefied petroleum gas (LPG) engines are also included in

the NONROAD model. Table 4

- 1 lists general SCCs addressed by the NONROAD model. Equipment categories are defined at the 7

- digit SCC level (with recreational marine and railway maintenance being exceptions) and specific equipment are d efined at the 10

- digit SCC level.

To estimate pollutant emissions, the NONROAD model multiplies equipment populations and their associated activity by the appropriate emission factors. Geographic allocation factors (GAFs) are used to distribute national equipment populations to states/ coun ties. These factors are based on surrogate indicators of equipment populations. For example, harvested cropland is the surrogate indicator used in allocating agricultural equipment. A national average engine activity (i.e., load factor times annual hour s of use) is used in NONROAD.

To improve the accuracy of the model runs, default inputs were replaced in the NONROAD model option files for select parameters. In the options packet, inputs that can be replaced include: Reid vapor pressure (RVP), temperature, oxygenated fuel weight percent, and fuel sulfur levels. Local activity data inputs, such as equipment populations or activity (e.g., hours of use or load factors), can also replace default values in the model.2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

4

- 3 Table 4

- 1. SCCs Addressed by th e NONROAD Model

Nonroad
SCCs SCC Descriptions Nonroad
SCCs SCC Descriptions

2260xxxxxx

2260001xxx

2260002xxx

2260003xxx

2260004xxx

2260005xxx

2260006xxx

2260007xxx

2265xxxxxx

2265001xxx

2265002xxx

2265003xxx

2265004xxx

2265005xxx

2265006xxx

2265007xxx

2265008xxx

226501xxxx

2267xxxxxx

2267001xxx

2267002xxx

2267003xxx

2267004xxx

2267005xxx

2267006xxx

2267008xxx 2

- stroke gasoline engines

- recreational vehicles

- construction equipment

- industrial equipment

- lawn & garden equipment

- agricultural equipment

- light commercial equipment

- logging equipment

4

- stroke gasoline engines

- recreational vehicles

- construction equipment

- industrial equipment

- la wn & garden equipment

- agricultural equipment

- light commercial equipment

- logging equipment

- airport service equipment

- oil field equipment LPG engines

- recreational vehicles

- construction equipment

- industrial equipment

- lawn & garden equipment

- agricultural equipment

- light commercial equipment

- airport service equipment 2268xxxxxx

2268002xxx

2268003xxx

2268005xxx

2268006 xxx 226801xxxx

2270xxxxxx

2270001xxx

2270002xxx

2270003xxx

2270004xxx

2270005xxx

2270006xxx

2270007xxx

2270008xxx

2270009xxx

227001xxxx

2282xxxxxx

2285xxx015 CNG engines

- construction equipment

- industrial equipment

- agricultural equipment

- light commercial equipment

- oil field equipment Diesel engines

- recreational vehicles

- construction equipment

- industrial equipment

- lawn & garden equipment

- f arm equipment

- light commercial equipment

- logging equipment

- airport service equipment

- underground mining equipment

- oil field equipment Recreational marine equipment

Rail way maintenance equipment

NONROAD model option files were prepared to account for temperatures and fuel characteristics representative of each county for each of the four seasons (winter, spring, summer, and fall). Temperature and fuel input values for each three

- month period (Dece mber

February, March

- May, June

- August, and September

- November) were averaged to estimate seasonal values. Minimum, maximum, and average temperatures per month were obtained from

the National Weather Service for the New Castle County Airport. Table 4

- 2 pre sents a summary
of New Castle County temperature and gasoline fuel characteristics data used for each season. A sulfur content of 351 ppm for off

- road diesel fuel was used for 2008 based on an EPA recommendation report (EPA, 2009 a ).

Table 4

- 2. NONROAD Model Temperature and Fuel Characteristic Input Values by Season for 2008

County Season Oxygen Weight % RVP psi Gasoline
Sulfur

ppm Temperature, o F

Minimum Maximum Average

New Castle Summer 3.55 6.82 39 66 86 76
New Castle Autumn 3.2 8.06 40.67 48 66 57
New Castle Winter 3.29 10.54 44 30 46 37
New Castle Spring 3.2 8.06 40.67 44 64 53

DAQ researched the availability of state and county

- specific data to improve upon the default equipment populations and G AFs incorporated in the model. DAQ replaced the default equipment population of recreational marine equipment with Delaware

- specific data. DAQ used2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

4

- 4 recreational boat registration data provided by the Delaware Division of Fish and Wildlife (DNREC, 2009) to estimate the total recre ational marine equipment population in use within

Delaware waters. DAQ determined this to be a preferable approach to the NONROAD default approach of a top

- down allocation of the national equipment population. However, registration

data were not used to a llocate recreational marine activity to the county level because residents may register their boats in one county, but use their boats in other parts of the State or neighboring counties.

DAQ updated GAFs for numerous equipment categories. Table 4

- 3 pro vides a list of GAFs and the associated equipment populations that use the GAFs that were updated with 2008 Delaware

specific data. For golf carts

, DAQ replaced the GAFs based on the number of golf courses in each county with the county total square kilome ters of golf courses in each county. DAQ believes that golf cart usage is more directly related to the size of each golf course than to the number of courses that exist in each county. If an equipment population is not identified in Table

4

- 3, then the mod el default GAFs were used in the 2008 runs.

Table 4

- 3. 2008 Delaware

- specific Geographic Allocation Factors

Geographic

Allocation Factor Data Source Equipment Population
Population DE Population Consortium

Aircraft NOx emissions D elaware 2008 inventory Airport g round support equipment

Dollar value of construction US Census Bureau and DE DOL Construction equipment

Harvested acres DE Department of Agriculture Agricultural equipment Area of golf courses Delaware State Golf Association Golf carts

Wholesale businesses BOC County Business Patterns Commercial equipment Single and duplex housing BOC Fact F inder website Residential lawn & garden equipment Landscaping businesses BOC County Business Patterns Comm ercial lawn & garden equipment Manufacturing employees BOC County Business Patterns Industrial equipment

Snowfall Weather W arehouse website Snow blowers and snowmobiles

4.2.2 Aircraft

The aircraft source category includes emissions from commercial, air taxi, general aviation, and military aircraft. These sub

- categories are described as follows:

• Commercial aircraft are used for scheduled service transporting passengers, freight, or both;

• Air taxis are used for scheduled service carrying passengers and/or freight, but are

smaller aircraft that operate on a more limited basis than the commercial carriers;

• General aviation includes other non

- military aircraft used for recreational flying, business, personal transportation, and various other activities; and

• Military aircraft are used by the U.S. military in a wide range of missions.

Airport

- specific emissions for all aircraft sub

- categories were allocated to the county in which each airport is located. Where there are multiple airports in a given county, th e emissions were summed to provide a county

- level emissions estimate. Aircraft emissions are reported under the following SCCs:2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

4

- 5 Table 4

- 4

. SCCs for Aircraft

SCC Descriptor 1 Descriptor 3 Descriptor 6 Descriptor 8

2275001000 Mobile Sources Aircraft Military Aircraft Total

2275020000 Mobile Sources Aircraft Commercial Aircraft Total: All Types

2275050000 Mobile Sources Aircraft General Aviation Total

2275060000 Mobile Sources Aircraft Air Taxi Total

DAQ estimated annual aircraft emissions using a combination of airport

- specific activity data and Federal Aviation Administration (FAA)/EPA emission factors. Estimating aircraft emissions focuses on the “mixing zone,” which has a height (mixing height) equal to the thickness of the inversion layer. A ir emissions within this zone are trapped by the inversion layer and ultimately affect ground

- level pollutant concentrations. When aircraft are above the mixing zone, emissions tend to disperse and have no ground

- level effects. The aircraft operations wi thin the mixing zone are defined by the landing and take

- off (LTO) cycle. Each LTO cycle consists of five specific operating modes:

• Approach

– aircraft operates in this mode when it approaches the airport on

its descent from the mixing height to when it lands on the runway.

• Taxi/idle

- in

– aircraft operates in this mode when it taxis from the runway to the gate and turns its engines off.

• Taxi/idle

- out

– this period occurs from engine start

- up to take

- off as the aircraft taxis

from the gate back out to the runway.

• Take

- off

– this mode is characterized primarily by full

- throttle operation that typically lasts until the aircraft reaches between 500 and 1000 feet above ground, which is when engine power is reduced.

• Climb

- out

– this mod e begins right after the take

- off mode and lasts until the aircraft passes out of the mixing height.

The operation time in each of these modes is dependent on the aircraft category, local meteorological conditions, and operational considerations at a give n airport. The time

- in

- mode (TIM) for the take

- off operating mode is the least variable.

The following are the general steps to be used to estimate aircraft emissions:

• Determine the mixing height to be used to define the LTO cycle;

• Define the fleet make

- up for each airport;

• Determine airport activity in terms of the number of LTOs by aircraft/engine type;

• Select emission factors for each engine model associated with the aircraft fleet;

• Estimate the TIM for the aircraft fleet at each airport;

• Calculate em issions based on aircraft LTOs, emission factors for each aircraft engine model, and estimated aircraft TIM; and

• Aggregate the emissions across aircraft

.

DAQ conta cted the New Castle County and Summit airports to request the number of aircraft

LTOs for calendar year 200 8 for each of the four aircraft types

. Additionally, each airport was2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

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- 6 requested to provide LTOs by aircraft make and engine type ; however this level of detail was not provided by the airports for 2008. D AQ assumed 200 8 aircraft were of the same mix of aircraft/engine types as reported for 2002. Table 4

- 5 provides the LTO data by the four aircraft types for the two airports in New Castle County.

Table 4

- 5. 2008 LTO Data for New Castle County

Airport County Category LTOs
New Castle County New Castle Military 4

, 61 8 New Castle County New Castle Commercial 488 New Castle County New Castle Air Taxi 5 ,2 44 New Castle County New Castle General Aviation 40,342

Summit New Castle General Aviation 34

, 700

DNREC used these airport

- specific LTO data to estimate commercial and military aircraft emissions using FAA’s Emissions and Dispersion Modeling System (EDMS), Version 5. 1 (FAA, 200 8 ) . The model requires detailed inputs on aircraft operation by aircraft an d engine type. DNREC matched the aircraft LTO data to the existing aircraft/engine types in EDMS, and used the default EDMS TIM data. A mixing height of 2,300 feet was used for both airports in New Castle County based on an isopleth chart of annual avera ge morning mixing heights for the continental U.S. as provided in EPA’s Procedures Manual (EPA, 1992). The Delaware Army National Guard (DE ARNG) and the Delaware Air National Guard (DE ANG) operate units at the New Castle County Airport and contribute to the military LTOs at that airport.

EDMS generates emissions for SO 2 and NO

x in tons per year. EDMS d oes not estimate particulate emissions by aircraft/engine type. As such, DAQ used fleet average PM 2.5 emission rates applied to total LTOs outside EDMS. The model also generates emissions for ground support equipment (GSE). However, DAQ used the GSE est imates generated from the NONROAD model, so these were subtracted from the EDMS results. EPA fleet average emission factors were applied to the LTO data to estimate annual general aviation and air taxi

emissions.

4.2.3 Locomotives

Railroad locomotives ar e a combustion source of emissions with most significant emissions occurring where there is a concentration of railroad activity (such as a large switch yard). The primary fuel consumed by railroad locomotives is distillate oil (diesel fuel). Locomotives can perform two different types of operations: line haul and yard (or switch). Line haul locomotives generally travel between distant locations, such as from one city to another. Yard locomotives are primarily responsible for moving railcars within a pa rticular railway yard. Locomotive

emissions are reported under the SCCs provided in Table 4

- 6.

For line haul locomotives, DAQ calculated Class I operation emissions separately from Class II/III operations. Line haul locomotive emissions for passenger tr ains and commuter lines were estimated to be zero since rail service in Delaware (Amtrak and SEPTA) is electric powered. Fuel consumption was used to estimate locomotive engine emissions. Fuel consumption rates are usually known only for the entire inters tate operating region, therefore, it is necessary to allocate the total amount of fuel consumed "system

- wide" to Delaware and its counties.2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

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- 7 Table 4

- 6. SCC s for Locomotives

SCC Descriptor 1 Descriptor 3 Descriptor 6 Descriptor 8

2285002006 Mobile Sources Railroad Equipment Diesel Line Haul Locomotives: Class I Operations

2285002007 Mobile Sources Railroad Equipment Diesel Line Haul Locomotives: Class II/Class III Operations

2285002010 Mobile Sources Railroad Equipment Diesel Yard Locomotives

Line Haul Locomotives

– Class I Operations

Norfolk Southern and CSX Transportation operate Class I locomotives within New Castle County. DAQ contacted these companies to obtain estimates of fuel consumption or data to calculate fuel consumption (e.g., gr oss ton

- miles (GTM) and gallons of fuel consumed per GTM).

Norfolk Southern provided GTM data at the county level for each county in Delaware in which they operated. Norfolk Southern provided a fuel consumption index (GTM/fuel consumed) for the

system that includes operations in Delaware. CSX provided GTM and fuel consumption data for New Castle County

, the only county in which CSX operates in Delaware. The system

- wide fuel consumption indices, county

- specific GTM, and calculated county

- level f uel consum ption are provided in Table 4

- 7

.

Table 4

- 7. 2008 New Castle County Locomotive Fuel Consumption Data for Class I Line Haul Operations

Class I Railroad Gross Ton Miles (GMT) System

- wide
GMT/Gallon

Diesel Fuel Consumed, gallons/year

Norfolk Southern 307,435,000 811.27 377,748 CSX Transportation 683,000,000 886.83 770,161

Line Haul Locomotives

– Class II/III Operations

The Maryland & Delaware Railroad is the only Class II/III railroad that operates in New Castle County. The compan y provided 200 8 statewide fuel consumption data. The Maryland & Delaware Railroad operates in New Castle and Sussex Counties. Track miles within each county were used to allocate statewide fuel consumption to each county. The Maryland & Delaware Railroad estimated 3,013 gallons of diesel fuel was used in New Castle County for 2008

.

Yard Locomotives

Norfolk Southern, CSX Transportation, and Maryland & Delaware have yard operations within New Castle County . These companies provided the number of locomotives by switchyard

location. Table 4

- 8 provides a summary of switchyard operations and fuel consumption. CSX and Maryland & Delaware provided Delaware

- specific fuel consumption for 2008. An average switchyard engine fuel consumption estimate of 32 ,4 47 gallons per year was ap plied based on a recent regional study coordinated through the Eastern Regional Technical Advisory Committee (ERTAC, 2010)

.2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
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- 8 Table 4

- 8

. 200 8 Switchyard Activity and Estimated Fuel Consumption

Class I Switchyard No. of Yard

Locomotives Fuel Consumed, gallons/year

Norfolk Southern 9 292,024
Maryland & Delaware 1 9,640 CSX Transportation 2 120,000

4.2.4 Commercial Marine Vessels

The CMV sector includes many types of vessels, such as large deep

- draft vessels, barge towboats, harbor tugs, dredging vessels, ferries, excursion vessels, and commercial fishing vessels. In addition to the numerous vessel types, each vessel type engages in different activities

such as hoteling, maneuvering within the port, and cruising.

In its 1999 final rule for commercial marine diesel engines, EPA defined three categories of marine diesel engines based on engine displacement, power and revolutions per minute (rpm) (EPA, 1999a). Table 4

- 9 presents the definitions for each category.

Table 4

- 9. U.S. EPA Marine Engine Category Definitions

Category Displacement per cylinder Power range (kW) RPM range

1 disp. < 5 liters and power > 37 kW 37

- 2,300 1,800

- 3,000

2 5 < disp lacement < 30 liters 1,500

- 8,000 750

- 1,500

3 d isp lacement > 30 liters 2,500

- 80,000 60

- 900

The EPA classifies CMV emissions by fuel type (residual and diesel) and by mode of operation (port and underway). CMVs often burn multiple types of fuel and may burn different fuels for different operating modes or locations (i.e., near ports). DAQ used t he port and underway SCCs

to characterize the CMV emissions as listed in Table 4

- 10. The SCC classification is based on the most common type of fuel utilized by the vessel category. Ocean

- going vessels (OGV) predominately burn intermediate fuel oil (IFO). DAQ placed emissions from OGVs burning IFO in the residual fuel SCC. This is consistent with how petroleum product sales data are reported by the Energy Information Administration and EPA’s classification of fuels ( EPA 1999b)

.

Table 4

- 10

. SCC s for C ommercial Marine Vessels

SCC Descriptor 1 Descriptor 3 Descriptor 6 Descriptor 8

2280002100 Mobile Sources Marine Vessels, Commercial Diesel Port emissions

2280002200 Mobile Sources Marine Vessels, Commercial Diesel Underway emissions

2280003100 Mobile Sources Marine Vessels, Commercial Residual Port emissions

2280003200 Mobile Sources Marine Vessels, Commercial Residual Underway emissions

There are four activity modes for CMV; cruise, reduced speed zone (RSZ), maneuver, and hotel. Underway emissions are estimated as the combined activity of cruise and RSZ modes. Port2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

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- 9 emissions are estimated as the combined activity of maneuvering and hote ling modes. Emissions from ferries and dredging are considered port emissions since these vessels operate primarily within the port area.

DAQ calculated emissions for ocean

- going vessels, towboats, tug

- assist vessels, ferries and

vessels associated with dredging operations. CMV engine emissions are assumed to be a function of the following:

• Mode of operation,

• Vessel type (bulk carrier, tanker, towboat, etc.);

• Vessel dead weight tonnage (DWT);

• Type of engine (2

- stroke, 4

- stroke, or steam); and

• Length of w aterway segment.

Therefore, DAQ accounted for these variations when estimating CMV activity. The four modes of operation that are performed by vessels are defined below:

Cruise

- This mode is assumed to begin 25 miles out from the port breakwater unt il the vessel reaches the breakwater (EPA, 1999c). The breakwater is located at the mouth of the Delaware Bay. Cruise mode is not applicable to New Castle County.

Reduced Speed Zone (RSZ)

- This mode begins at the breakwater and continues until the

vesse l is one to two nautical miles from the berth or anchorage. The vessel is assumed to have a speed of twelve knots during this mode (EPA, 2009 c ). This mode is also referred to as transit, and escort for towboats and tug

- assist vessels.

Maneuvering

- This mode is defined as the time the vessel slows to below four knots until the dock lines are secure. This mode is also referred to as assist mode for tug

- assist vessels.

Hoteling

- This mode is defined as the time the vessel is at dock. During this mode, the vessel operates auxiliary engines for electrical power.

The waterway segment distances used to estimate activity and to allocate the activity to New Castle County were estimated from the Google Earth website in 2008 by tracing the shipping

channel. Se gment distances are shown in Table 4

- 11. The distance South is given to the breakwater at the mouth of the Delaware Bay. The distance north is given to the Delaware

Pennsylvania border. The distance for the C&D Canal East is given from the Delaware

Mary land border to the entrance of the Delaware River (Reedy Point).

The engine activity for each mode is calculated using the following equation:

Calls Time LoadFactor Power Activity mode mode × × × =
where:

Activity mode = activity by mode (kilowatt

- hours)

Power = rated engine power by vessel and engine type (kilowatts)

Load Factor = load factor of the engine by vessel type and mode

Time = time in mode per call by vessel type (hours)2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
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- 10 Calls = number of calls by vessel and engine type

Table 4

- 11. Waterway Segment Distances for the Delaware River Area

Waterway Segment Distance (mi.)

Point South

DE/PA Border 83. 8 Oceanport 83.3 Port of Wilmington 76. 1 Magellan Terminal 75. 6 Delaware City Refinery 6 6

. 0

C&D Canal 62. 6

Lat itude 39 o 30' 57. 7

New Castle Co/Kent Co 48. 5

Kent Co/Sussex Co 15. 9

Point North Port of Wilmington 7.7

C&D Canal 21.2

Point East

C&D Canal 13.0

This calculation must be performed for both propulsion and auxiliary engines and for each mode. Both propulsion engines and auxiliary engines are operating during cruise, RSZ and maneuvering modes. Only auxiliary engines operate during hoteling. Once the activity is calculated, it is allocated to the county level using county allocation factors.

This approach to calculating activity of CMVs was used for all vessel types except vessels involved in dredging activity. For dredging, the activity data used for emissions calculations was the volume of material dredged. Details on the sources and development of activity data are provided in the following subsections.

Ocean

- G oing Vessels

DAQ obtained vessel call data for ocean

- going vessels (OGVs) during calendar year 2008 from the Marine Exchange for the Delaware River and Bay (ME, 2010). Data were obtained for vessels that called on ports in Delaware, New Jersey and Pennsylvania. The d ata for the entire port area is required since the majority of vessels pass through Delaware waters en route to other ports. The vessel call data included the vessel name, ship type, DWT, pier, and the date of the call. The ship types calling on the Delaw are River Area ports in 2008 are shown in Table 4

- 12.

Vessels may shift between piers during the same call on the Delaware River a rea. DAQ adjusted the vessel call data to remove shifts between piers, where possible, to avoid double counting using a meth odology recommended by the staff of the Marine Exchange. Data on the engine power and engine type (2

- stroke, 4

- stroke, and steam) used on OGVs were not available through the Marine Exchange. Therefore, DAQ assigned engine power and engine type based on av erage engine data obtained from other sources.

For propulsion engines, the average engine power and the engine type were obtained from the EPA report Commercial Marine Activity for Deep Sea Ports in the United States ( Deep Sea

Ports ) (EPA, 1999c). This r eport presents data for vessels that called on the Delaware River a rea2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

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- 11 ports during calendar year 1996. Note that the Delaware River a rea includes ports in Delaware, New Jersey and Pennsylvania, which are located on the Delaware River. The number of call s by vessel and engine type is presented for specific DWT ranges. The average engine power is also given.

Table 4

- 12. Vessel Types Calling on Delaware River Area Ports in 2008

Codes Main Vessel Type Additional Vessel Types Included w/ Main Type

BU Bulk Chemical (CH), Ore (OR)

CC Container Container/Bulk (CB), Part Container (PC)

GC General Cargo

MS Miscellaneous Cable Ship (CL), Heavy Lift (HL), Livestock (LV), Tall Ship (TS)

P R Passenger

RF Refrigerated Cargo (Reefer) Container Reefer (CR)

RR Roll on

- Roll off (RORO) RORO Container (RC)

TA Tanker Bulk Oil (BO), Gas Carrier (PG)

VE Vehicle Carrier

In order to calculate underway emissions, the number of calls (by vessel type and DWT range) had to be allocated to each port. The ports in Delaware include the Port of Wilmington, Magellan Terminal, Delaware City Refinery , and Oceanport. One port in New Jersey, Bermuda International on Salem Creek, is located adjacent to Delaware. All other ports in New Jersey and all ports in Pennsylvania are located north of the Delaware/Pennsylvania state line. Vessels calling on New Jersey and Pennsylvania ports must be inc luded in underway emission calculations for Delaware since the vessels travel through the Delaware portion of the bay and

river.

Table 4

- 13 presents the assigned propulsion engine power and the number of calls by vessel type, DWT range and engine type fo r calls on the Delaware River a rea in 200 8 . In addition to vessels traveling in the Delaware River Bay and River, 424 OGVs traversed the C&D Canal to or from the Chesapeake Bay.

Towboats and Tug Assists

Towboats are used to transport non

- self

- propelled vessels, either dry cargo or tanker barges, throughout the Delaware River area, including the C&D Canal. DAQ obtained data on the number of towboat trips during calendar year 2008 from Waterborne Commerce of the United

States (USACE, 2010 a ). DAQ subtracte d the number of towboat trips for the Port of Wilmington (POW) and the C&D Canal from the number of trips on the Delaware River (PA to the Sea). For towboats traveling to and from the POW and traveling through the C&D Canal, DAQ assumed

that half the vesse ls travel north and the other half travel south to/from the POW and the canal.

In 2008, 13,203 towboat trips transited Delaware waters on the Delaware River, with a trip

defined as a one

- way passage. 1,184 towboat trips entered or exited the Port of Wilmi ngton, and 3,597 towboat trips transited the C&D Canal.2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

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- 12 Table 4

- 13. Average Propulsion Engine Power and the 2008 Number of Calls for OGVs Calling on the Delaware River Area (DE, NJ and PA)

Code DWT Range Engine Type Power (hp) Calls Code DWT Range Engine Type Power (hp) Calls

BU < 25,000 2

- stroke 9,665 41 RF 15,000

- 25,000 2

- stroke 18,467 72

BU < 25,000 4

- stroke 7,504 6 RR <15,000 2

- stroke 8,280 13

BU 25,000

- 35,000 2

- stroke 9,696 85 RR <15,000 4

- stroke 8,553 13

BU 35,000

- 45,000 2

- stroke 10,320 56 RR 15,000

- 30,000 2

- stroke 12,852 16

BU > 45,000 2

- stroke 16,328 90 RR >30,000 2

- stroke 2 6, 562 0

CC < 25,000 2

- stroke 17,757 126 TA <30,000 2

- stroke 10,008 75

CC < 25,000 4

- stroke 10,898 67 TA <30,000 4

- stroke 7,077 18

CC 25,000

- 35,000 2

- stroke 16,327 145 TA <30,000 Steam 14,646 8

CC 35,000

- 45,000 2

- stroke 34,467 117 TA 30,000

- 60,000 2

- stroke 12,616 195

CC > 45,000 2

- stroke 30,856 54 TA 30,000

- 60,000 4

- stroke 15,360 13

GC < 15,000 2

- stroke 5,784 45 TA 30,000

- 60,000 Steam 15,498 135

GC < 15,000 4

- stroke 3,944 57 TA 60,000

- 90,000 2

- stroke 16,026 69

GC 15,000

- 30,000 2

- stroke 10,456 30 TA 60,000

- 90,000 4

- stroke 14,305 10

GC 15,000

- 30,000 4

- stroke 7,536 5 TA 90,000

- 120,000 2

- stroke 15,451 302

GC 30,000

- 45,000 2

- stroke 12,876 33 TA 90,000

- 120,000 Steam 23,923 7

GC > 45,000 2

- stroke 12,170 2 TA 120,000

- 150,000 2

- stroke 23,046 56

MS < 1 0 ,000 2

- stroke 3,500 6 TA > 150,000 2

- stroke 25,559 113

MS < 1 0 ,000 4

- stroke 11,671 3 TA > 150,000 Steam 36,324 35

P R < 5,000 4

- stroke 16,108 12 VE <12,500 2

- stroke 11,877 13

P R 5,000

- 10,000 4

- stroke 20,776 0 VE <12,500 4

- stroke 13,150 3

P R 5,000

- 10,000 steam 40,649 1 VE 12,500

- 15,000 2

- stroke 12,859 30

RF 5,000

- 10,000 2

- stroke 9,706 115 VE 12,500

- 15,000 4

- stroke 14,770 6

RF 5,000

- 10,000 4

- stroke 6,837 20 VE 15,000

- 17,500 2

- stroke 13,911 30

RF 10,000

- 15,000 2

- stroke 12,500 173 VE > 17,500 2

- stroke 15,224 51

RF 10,000

- 15,000 4

- stroke 15,672 3

Tugs assist OGVs from the shipping channel to its intended berth and then back to the channel when the vessel leaves port. This activity is considered the maneuvering mode for OGVs. Two tugs are typically required to assist an OGV with a DWT greater than 20,000 tons; for smaller OGVs, one tug suffices (EPA, 2009 b ). The num ber of tug assists (3,428 in 2008) is directly related to the number of OGVs calling to a Delaware port. Note that a tug assisting a vessel to Bermuda International in New Jersey and the piers at the oil refineries in Marcus Hook, PA will require a tug to pick up the OGV in Delaware waters, thus tug assists are included for these docks. The tug meeting time to the docking time is usually within one hour (Anderson, 2010).

In addition to assisting OGVs to maneuver into port, tugboats escort gas carriers through the Delaware Bay and River (Andersen, 2010). Other vessels typically do not utilize an escort. Tug escort trips are included in the number of towboat trips transiting Delaware waters presented

above. DNREC did not estimate emissions from hoteling o f towboats and tugs due to lack of activity data.

Vessel speeds, average maneuvering and hoteling time, propulsion and auxiliary engine horsepower ratings, and engine load factors for OGVs, towboats, and tugs were obtained from

EPA’s Deep Sea Ports (EPA, 1999c) and Preparing Port Emission Inventories (EPA, 2009 b )

.2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

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- 13 For RSZ mode, time

- in

- mode for each vessel was calculated based on vessel speeds and waterway segment distances provided in Table 4

- 11.

Dredging

Maintenance dredging is performed routinely on the Delaware River to keep the channels to their required depths. Dredging involves multiple vessels, including dredges, assist tugs, and generator barges that provide additional power. Estimating emissions f rom dredging vessel engine activity

is time

- consuming. Therefore, DAQ developed emissions based on the volume of material dredged during calendar year 2008 rather than engine activity in kilowatt

- hours.

DAQ obtained the dredging activity data from both th e USACE and from within DNREC. The amount of material dredged by USACE contractors was obtained from the USACE report on dredging contracts awarded for the year 2008 (USACE, 2010 b ). DAQ also contacted the

Delaware Division of Soil and Water Conservation to obtain the amount of material dredged by the Division (DSWC, 2010). Table 4

- 14 presents the estimated amount of material dredged and the type of dredge used. DAQ assumed all the dredging activity is maintenance dredging. New cut dredging results in hi gher emissions, therefore this assumption may result in lower emission estimates than are actually occurring in the area.

Table 4

- 14. Material Dredged in the New Castle County P ortion of the Delaware River Area during 2008

Project Location Type of Equip ment Total Material Dredged (cubic yards)

P hiladelphia to the Sea Hydraulic Dredge 732,697
Chesapeake & Delaware Canal Hydraulic Dredge 600,000
Port of Wilmington Hydraulic Dredge 650 ,000

Premcor Berth Maintenance Hydraulic Dredge 230,000

Ferries

The Three Forts Ferry was identified as the only ferry service in New Castle County. This ferry travels from either Delaware City, DE or Fort Mott, NJ to Fort Delaware located on Pea Patch Island in the Delaware River. Monthly trip count data for the ferr y was obtained by contacting the Delaware River & Bay Authority ( DRBA, 2010) . The Three Forts Ferry made 2,280 one

way trips in 2008. The Delaware River and Bay Authority also provided the engine and time

- in

mode data for the Three Forts Ferry.

Spatial Allocation

DAQ developed county allocation factors for CMV activity data based on the location of the activity on the various waterways and length of the waterway segment. In developing county allocation factors, DAQ assumed that from latitude 39 o 30' to 25 miles beyond the mouth of the Delaware Bay, the activity is split evenly between Delaware and New Jersey since the ship channel roughly corresponds to the boundary between the two states. Above latitude 39 o 30', all

emissions are allocated to Delaware s ince the entire breadth of the river is under Delaware’s2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

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- 14 jurisdiction. Allocations were developed for each activity mode, since the activity takes place in different areas depending on the mode.

For OGV maneuvering and hotel i ng modes, the activity is all ocated to the county in which the port is located. All the Delaware ports are located in New Castle County. Therefore, all maneuvering and hoteling activity was allocated to New Castle County.

For the RSZ mode, county allocation factors were developed for the four ports in Delaware (Port of Wilmington, Magellan Terminal, Oceanport, and Delaware City Refinery), Bermuda International in New Jersey, and from the Pennsylvania

- Delaware border to the breakwater (PA/DE to the Sea).

Allocating dredging to each county was based on the river miles in each county, and split between Delaware and New Jersey below latitude 39 o 30'

. While the Three Forts Ferry travels to Fort Mott on the New Jersey side of the Delaware River, at that latitude, Delaware’s jurisdictional waters extend the breadth of the river. Therefore, all activity for the Three Forts Ferry was allocated to New Castle County.



### 4.3 200 8 Emissions Summary

Table 4

- 1 5 provides a summar y of the 200 8 annual (tons per year, TPY) New Castle County

emissions for aircraft, locomotives, commercial marine vessels, and all equipment emissions estimated using EPA’s NONROAD model

. The non

- road sector is a significant contributor to

PM 2.5 emissions and emissions of NO

x and SO 2 as precursors to the secondar y formation of

PM 2.5 in New Castle County

. The totals may not match the sum of the individual values due to independent rounding.

Table 4

- 1 5

. Summary of 200 8 New Castle County Emissions from Non

- road
Sources in tons/year

Source Categories PM 2.5 SO 2 NO X NONROAD Model Equipment 148 28 1,676

Aircraft 8 2 13

Locomotives 9 3 239

Commercial Marine Vessels 146 1,034 2,389

NON

- ROAD SECTOR TOTAL 312 1,067 4,317



### 4.4 References

Anderson, 2010: Scott Anderson, Maritime Exchange for the Delaware River and Bay, Philadelphia PA, e

- mail to David Fees, DNREC, on March 24, 2010.

DNREC, 200 9 : Delaware Department of Natural Resources and Environmental Control, Division of Fish and Wildlife, Delaware Annual Boating Statistics.

DRBA, 2010: Monthly trips data for the Three Forts Ferry , provided by J. Fred Coldren, Delaware River and Bay Authority, via e

- mail to David Fees, DNREC, March 22, 2010.2008 N EW C ASTLE C OUNTY A TTAINMENT Y EAR SIP E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
X

4

- 15 DSWC, 2010: Brian Kelly, Delaware Division of Soil and Water Conservation, e

- mail to David Fees, DNREC, on February 23, 2010.

EPA, 1992: U.S. Environmental Protection Agency, Office of Air and Radiation, Procedures for Emission Inventory Preparation, Volume IV: Mobile Sources , EPA

- 450/4

- 81

- 026d (Revised), 1992.

EPA, 1999a: Final Regulatory Impact Analysis: Control of Emissions from Marine Diesel Engines . U.S. Environmental Protection Agency, Office of Mobile Sources, Engine Programs and Compliance Division, EPA420

- R

- 99

- 026, November 1999.

EPA, 1999b: In

- Use Marine Diesel Fuel, U.S. Environmental Protection Agency, Office of Mobile Sources, Engine Programs and Compliance Division, EPA 420

- R

- 99

- 027, August

1999.

EPA, 1999c: Commercial Marine Activity for Deep Sea Ports in the United States . U.S.

Environmenta l Protection Agency. Prepared by ARCADIS Geraghty & Miller, Inc.

EPA420

- R

- 99

- 020, September 1999.

EPA, 2009a: Suggested Nationwide Average Fuel Properties . Assessment and Standards Division, Office of Transportation and Air Quality, U.S. Environmental Protection Agency. EPA

- 420

- B

- 09

- 018, April 2009.

EPA, 2009b: Current Methodologies in Preparing Mobile Source Port

- Related Emission

Inventories . U.S. Environmental Protection Agency. Prepared by ICF International, 09

- 024, April 2009.

ERTAC, 2010. “ ERT AC Rail Emissions Inventory

– Part 2: Class I Railyard Switcher

Locomotives ”, Eastern Regional Technical Advisory Committee, October 2010.

FAA, 200 8 : Federal Highway Administration, “ Emissions and Dispersion Modeling System (EDMS) User’s Manual ”, Version 5

. 1

, FAA

- AEE

- 07

- 01, Revision 5, September 19, 200 8

.

ME, 20 10 : “Ship Traffic: Delaware River Ports : 200 8 ” [data files], from Scott Anderson, Maritime Exchange for the Delaware River and Bay, Philadelphia PA, via e

- mail to David

Fees

, Division of Air Quality, DNREC, February 2010

.

USACE, 20 10 a : Waterborne Commerce of the United States

– Calendar Year 200 8

– Part 1 Waterways and Harbors Atlantic Coast. Department of the Army Corps of Engineers

, Institute of Water Resources, WR

- WCUS

- 0 8

- 1, March 2010

.

USACE, 20 10 b : “U

. S

. Army Corps o f Engineers Dredging Contracts Awarded; Fiscal Year 200 8 Awards”, U

. S

. Army Corps o f Engineers, information retrieved in 2010 from http://www.iwr.usace.army.mil/ndc/dredge/pdf/awards08.pdf2008 A TTAINMENT Y EAR S TATE I MPLEMENTATION P LAN E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
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- 1 

### S ECTION 

### 5

O N



### - R OAD 

### M OBILE 

### S OURCES

The 200 8 on

- road mobile source inventory is an estimate of vehicle emissions based on actual vehicle miles traveled (VMT) on Delaware roadways in 200 8 using EPA’s Motor Vehicle Emission Simulator (MOVES) model. Vehicles i nclude passenger cars, light

- duty trucks, including sport utility vehicles, heavy

- duty trucks, buses, and motorcycles. Emissions were calculated for vehicles fueled by gasoline or diesel. Controls as of 200 8 were incorporated into

the MOVES model inputs, a nd thus emission s account for controls. Engine exhaust emissions for

PM 2.5 , SO 2 , and NO

x , as well as for other criteria pollutants

, air toxics

, and greenhouse gases

were calculated . In addition, particulate matter brake and tire wear emissions were separat ely

calculated. Monthly e missions were calculated by roadway class , vehicle type, and county.

The applicable Standard Classification Codes (SCCs) comprising vehicle type, roadway class, and emission process (exhaust

, evaporative , brake wear, and tire wea r ) are shown in Table 5

- 1. As an example, the SCC applicable to exhaust emissions from a passenger car fueled by gasoline on an urban interstate would be 220100123X, with the “2201001” indicating that the vehicle is a light

- duty gasoline vehicle, the “23” indicating the activity is occurring on an urban interstate, and the “X” indicating that the emissions are exhaust emissions.

Table 5

- 1

. SCCs Included in On

- road Mobile Inventory

SCC Digits Applicable

Portion of
SCC Code Portion that SCC

Describes Desc ription

1

- 7 2201001 Vehicle type Light

- duty gasoline vehicles (passenger cars)

1

- 7 2201020 Vehicle type Light

- duty gasoline trucks 1 (0

- 6,000 lb gross vehicle weight rating [GVWR])

1

- 7 2201040 Vehicle type Light

- duty gasoline trucks 2 (6,001

- 8,500 lb GVWR)

1

- 7 2201070 Vehicle type Heavy

- duty gasoline vehicles (> 8,500 lb GVWR)

1

- 7 2201080 Vehicle type Motorcycles (gasoline)

1

- 7 2230001 Vehicle type Light

- duty diesel vehicles (passenger cars)

1

- 7 2230060 Vehicle type Light

- duty diesel tr ucks (0

- 8,500 lb GVWR)

1

- 7 2230071 Vehicle type Class 2b heavy

- duty diesel vehicles (8,501

- 10,000 lb GVWR)

1

- 7 2230072 Vehicle type Class 3, 4, and 5 heavy

- duty diesel vehicles (10,001

- 19,500 lb GVWR)

1

- 7 2230073 Vehicle type Class 6 and 7 heavy

- d uty diesel vehicles (19,501

- 33,000 lb GVWR)

1

- 7 2230074 Vehicle type Class 8 heavy

- duty diesel vehicles (> 33,000 lb GVWR)

1

- 7 2230075 Vehicle type Diesel buses

8

- 9 11 Roadway type Rural interstates

8

- 9 13 Roadway type Rural other principal art erials

8

- 9 15 Roadway type Rural minor arterials

8

- 9 17 Roadway type Rural major collectors

8

- 9 19 Roadway type Rural minor collectors

Continued next page2008 A TTAINMENT Y EAR S TATE I MPLEMENTATION P LAN E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
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- 2 Table 5

- 1. continued

SCC Digits Applicable

Portion of
SCC Code Portion that SC C

Describes Description

8

- 9 21 Roadway type Rural locals

8

- 9 23 Roadway type Urban interstates

8

- 9 25 Roadway type Urban other freeways and expressways

8

- 9 27 Roadway type Urban other principal arterials

8

- 9 29 Roadway type Urban minor arter ials

8

- 9 31 Roadway type Urban collectors

8

- 9 33 Roadway type Urban locals

10 X Emission process Exhaust

10 V Emission process Evaporative

10 B Emission process Brake wear

10 T Emission process Tire wear



### 5.1 Input Data Specific to New Castle Count y for 2008

The 2008 inventory was the first year that DAQ used the MOVES model to develop on

- road mobile emissions. The MOBILE6.2 model was used previously. The MOVES model allows for adjustment s to a variety of model inputs, and as such, DAQ, with assist ance from the Delaware Department of Transportation (DelDOT), put forth considerable effort in creating a suite of

county

- specific 2008 input data files. The New Castle C ounty

- specific input data types created for the 2008 inventory include VMT (by vehicle and roadway type), vehicle registration data (vehicle populations and age distributions), meteorological data (temperature and relative humidity), average speeds in the form of speed bin fractions (weekday versus weekend and by roadway type), fuel formula tions and supply, and inspection and maintenance program specifications. Each of these input data sets are discussed separately below.

5.1.1 Vehicle Miles Traveled (VMT) Data

The activity data used for developing the on

- road emission inventory is VMT. DelDOT p rovided

200 8 VMT data by roadway type for New Castle County

. DelDOT is required to submit calendar year VMT data annually to the Federal Highway Administration’s (FHWA) Highway Performance Monitoring System (HPMS) . The VMT is estimated based on data from p ermanent traffic count stations throughout the county

. DelDOT’s traffic count program provide s daily and

seasonal variation data. Additional temporary stations provide shorter

- term counts that are expanded with factors derived from appropriate permanent c ount stations. Counting and expansion activities are consistent with FHWA guidelines. The traffic data submitted to HPMS

are considered the most accurate VMT totals for New Castle C ounty.

Since the VMT provided by DelDOT is supplied by HPMS roadway type, the task of creating VMT by MOVES road type fractions only requires mapping the twelve HPMS road types to the four MOVES road types. The road type allocations for New Castle County for 2008 are provided

in Table 5

- 2.2008 A TTAINMENT Y EAR S TATE I MPLEMENTATION P LAN E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
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- 3 Table 5

- 2

. New Castle County VMT Fr actions by Road Type

MOVES Road Type
Code Road Type Description VMT Fraction by Road Type

2 Rural Restricted Access 0.0000

3 Rural Unrestricted Access 0.1274

4 Urban Restricted Access 0.2813

5 Urban Unrestricted Access 0.5914

Total 1.0000

VMT Fr actions b y Vehicle Type

VMT by vehicle type data are not collected in Delaware, so an alternate procedure was developed using the local registration data in calculating the VMT mixes rather than using the default MOVES VMT distribution by vehicle type. Th is methodology uses national default MOVES mileage accumulation and diesel sales fraction data in combination with the Delaware

county

- specific registration data to develop estimates of VMT by vehicle type. The number of vehicles registered in Delaware by model year, vehicle type, and county was multiplied first by the MOBILE6.2 default gasoline or diesel sales fraction corresponding to that vehicle type and model year, and then by the average number of miles accumulated annually by vehicles of the

same ag e and vehicle type in the MOBILE6.2 default mileage accumulation database. This provided an estimate of VMT by vehicle age and vehicle type. These VMT estimates were then

summed for all years by vehicle type. The total VMT for each vehicle type was divi ded by the total calculated VMT to give VMT fractions by vehicle type. Table 5

- 3 present s the resulting

VMT fractions by vehicle type for New Castle County

.

Table 5

- 3

. New Castle County VMT Fractions by Vehicle Type

MOVES

Vehicle Type Code Vehicle Desc ription VMT Fraction by Vehicle Type

11 Motorcycle 0.0072

21 Passenger Car 0.4469

31 Passenger Truck 0.3738

32 Light Commercial Truck 0.1325

41 Intercity Bus 0.0031

42 Transit Bus 0.0011

43 School Bus 0.0018

51 Refuse Truck 0.0003

52 Single Unit Short

- haul Truck 0.0078

53 Single Unit Long

- haul Truck 0.0007

54 Motor Home 0.0003

61 Combination Short

- haul Truck 0.0122

62 Combination Long

- haul Truck 0.0123

Total 1.00002008 A TTAINMENT Y EAR S TATE I MPLEMENTATION P LAN E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
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- 4 VMT Temporal Allocation s

The MOVES model input files include allocations of VMT by month. Monthly allocation of VMT is accomplished through the use of permanent count station data provided by DelDOT. For 2008, DelDOT provided monthly VMT data from 27 permanent count stations throughout

Ne w Castle County. Each month’s data for all 27 count station were summed and divided by the sum of the annual VMT recorded by the 27 stations. The monthly VMT fractions created in this

way are provided in Table 5

- 4.

Table 5

- 4

. Monthly VMT Allocation Fract ions

Month VMT

Fraction Month VMT

Fraction
January 0.0795 July 0.0877
February 0.0735 August 0.0905

March 0.0834 September 0.0819
April 0.0859 October 0.0795
May 0.0901 November 0.0784

June 0.0860 December 0.0836

5.1.2 Meteorological Data

Temperature and relative humidity are the meteorological data required for MOVES runs. Hourly data were obtained from the National Climatic Data Center (NCDC, 20 10 ) from data collected at the New Castle County airport

. These data were compiled as monthly averages of

e ach hour of the day for input into the MOVES runs.

5.1.3 Fuel Data

The entire State receives Federal reformulated gasoline. However, the fuel parameters vary seasonally as well as by county, based on information from EPA’s Reformulated Gasoline Fuel Survey . Th is survey reports in

- use gasoline parameters during winter and summer. New Castle County is well

- represented in this survey, as the Philadelphia, PA

- Wilmington, DE

- Trenton, NJ

ar ea is one of the surveyed areas . Thus, it was felt that the parameters obtain ed from this study could be directly applied for use in the Delaware inventory . F uel parameters were obtained from the survey for calendar year 200 8 and obtained directly from EPA (EPA, 20 09 ) since the Office of Transportation and Air Quality ceased postin g such data on their RFG fuel survey data web page after 2006

.

The MOVES model has nearly 9,000 choices in its library of fuel formulations. Summertime fuel survey data for 2008 from 21 gasoline stations located in New Castle County were averaged for

Rei d Vapor Pressure (RVP) to determine the fuel formulation that best matched in

- use fuel characteristics in New Castle County. Th e summer fuel data were applied to the ozone season months of May through September. The summer fuel data were also applied to Oc tober as data

indicated that fuel formulations are slow to switch to wintertime fuel. The winter fuel data were applied to January, February, and December , based on survey data

. Fuel RVP for the remaining

months (March, April, and November) were calculated using a straight line interpolation method2008 A TTAINMENT Y EAR S TATE I MPLEMENTATION P LAN E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
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- 5 between summer and winter fuel data

. The resulting RVP and sulfur content for New Castle County by month are provided in Table 5

- 5

.

Table 5

- 5

. 200 8 Gasoline Fuel Parameters for New Castle County

Month s Reid V apor Pressure (psi) Sulfur Content (ppm)

Jan

, Feb and Dec 13.4 51.8 Mar, Apr and Nov 10.6 52.4 May

- Oct 6.8 6 53.1

Source: EPA Reformulated Gasoline Survey, 200 9

.

5.1.4 Vehicle Populations and Age Distributions

Vehicle registration data were obtaine d from the Delaware Division of Motor Vehicles (DMV)

. The data are a snapshot of DMV’s registration database as of July 1, 200 8 . The data show the number of vehicles registered by model year for each of the 16 MOBILE6 .2 vehicle classes . The

16 vehicle clas ses were converted to the 13 MOVES vehicle types using a converter provided by EPA. New Castle vehicle populations by MOVES vehicle type are provided in Tabl e 5. 6

. Vehicle age distribution fractions were developed for each of the 13 vehicle types based on model year. Vehicle 30 years and older were lumped into one fraction.

Table 5

- 6

. 2008 Vehicle Populations for New Castle County

Vehicle

Code Vehicle Type Number of

Vehicles

11 Motorcycle 12

, 505

21 Passenger Vehicle 244

, 034

31 Passenger Truck 149

, 74 2

32 Light Comm ercial Truck 49

, 542

41 Intercity Bus 398

42 Transit Bus 244

43 School Bus 997

51 Refuse Truck 77

52 Single Unit Short

- Haul Truck 3

, 103

53 Single Unit Long

- Haul Truck 216

54 Motor Home 390

61 Combination Short

- Haul Truck 1

, 211

62 C ombination Long

- Haul Truck 917

5.1.5 Vehicle Speeds

The MOVES model represents average vehicle speeds by roadway type through the use of speed bin fractions. There are 16 speed bin s with the first representing speeds less than 2.5 miles per hour (mph), with e ach subsequent bin having a range of 5 mph (i.e., 42.5 mph

– 47.5 mph). The final bin represents speeds equal to or greater than 72.5 mph. For 2008, DelDOT provided seasonal speed bin fractions for each of the four MOVES roadway types, for each hour of the day, and for weekday and weekend driving patterns. DelDOT estimated speeds using the

Peninsula travel demand model. The model accounts for traffic volumes and variations in travel2008 A TTAINMENT Y EAR S TATE I MPLEMENTATION P LAN E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
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- 6 according to purpose, which impact average speeds. Table 5

- 7 summarizes the matrix of parameters that results in 12,288 records for speeds in New Castle County

.

Table 5

- 7

. 200 8 Average Speed Matrix

Parameter Number of

Variables

Season 4

Hour 24
Roadway Type 4 Weekday/Weekend 2 Speed Bins 16

5.1.6 Northeast Ozone Trans port Region Low Emission Vehicle Program

Delaware belongs to the Northeast Ozone Transport Region (OTR). The States in this region have adopted a low

- emission vehicle program that began with the 1999 model year. The National LEV program (NLEV), which be gan with the 2001 model year, is the default modeled in MOVES. Therefore, to correctly model the Northeast Ozone Transport Region LEV program in place in Delaware, the early NLEV database was used in the MOVES run specification. The phase

- in schedule of t he Northeast Ozone Transport Region LEV program is shown in Table 5

- 8. This phase

- in schedule was applied to gasoline

- powered passenger cars, passenger trucks, and light commercial trucks under 8,501 GVWR

.

Table 5

- 8. LEV Implementation Schedule in the Northeast OTR

Model Year Federal Tier I
Standards Transitional LEV
Standards LEV
Standards Tier 2
Standards

1999 30% 40% 30%

2000 40% 60%

2001

- 2003 100%

2004 and later 100%

5.1.7 Inspection and Maintenance (I/M)

The I/M programs for New Castle Count y include a biennial onboard diagnostic testing program (OBD II) since 2002 for 1996 and later model year vehicles. Vehicle emission computer systems are checked for any diagnostic trouble codes present, a symptom of excess em issions which is a failing result for the vehicle. Older vehicles, starting with model year (MY) 1968

, are given a curb idle test (MY 1968

- 1980) or a two

- speed idle test (MY 1981

- 1995). A tailpipe probe is

inserted for 60 seconds to determine exhaust con centrations of hydrocarbon s and carbon monoxide. Depending on the model year, vehicles with an excess emission concentration of either pollutant will fail the test. Older vehicles (MY 1975

- 1995) are also given a fuel system

pressure test (FP) and a gas cap (GC) test. Air pressure is applied to the fuel system from the

fuel inlet to the canister. After air pressure has been applied, pressure degradation is monitored.2008 A TTAINMENT Y EAR S TATE I MPLEMENTATION P LAN E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
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- 7 Vehicles fail the fuel system pressure test if it cannot maintain the equivalent pressure of eight inches of water for up to two minutes after being pressurized to 14.0 ± 0.5 inches of water. A similar pressure test is applied to the vehicle’s gas cap.

Table 5

- 9

. New Castle County I/M Program Parameters

Test Type IDLE 2500/IDLE FP & GC OBD I/M

Test Frequency Biennial Biennial Biennial Biennial

Program Type Test Only Test Only Test Only Test Only

Model Years 1968

- 1980 1981

- 1995 1975

- 1995 1996

- 2 003

Compliance Factor s

Passenger Vehicle 88.57 94.82 96.00 95.23

Passenger Truck 84.60 89.17 9 0.24 89.53

Light Comm. Truck 79.20 83.48 84.48 83.82

Vehicles Tested (gasoline only)

Passenger Vehicle Yes Yes Yes Yes

Passenger Truck Yes Yes Yes Yes Light Comm. Truck (up to 8,500 GVWR) Yes Yes Yes Yes

School Bus No No No No Single Unit
Short

- Ha ul Truck No No No No Single Unit Long

- Haul Truck No No No No

Refuse Truck No No No No

Combination
Short

- Haul Truck No No No No

Combination Long

- Haul Truck No No No No

Motor Home No No No No

Intercity Bus No No No No

Transit Bus No No No No

Motorcyc le No No No No



### 5.2 Running the MOVES Model

Running the MOVES model is accomplished through the development of (1) a run specification unique to a particular scenario of interest (2) the County Data Manager (CDM) that contains the various model inputs a s described in Section 5.1 of this report, and (3) the form of the desired data output files. Unlike the MOBILE6 model that generated only emission factors that then were matched with the corresponding activity data, such as VMT, to develop emission estima tes,

t he MOVES model, when executed in the Inventory Mode, provides final emissions.2008 A TTAINMENT Y EAR S TATE I MPLEMENTATION P LAN E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
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- 8 The run specification, or “runspec”, is where a user identifies the modeling scale (national, county, or project

- level domain ), and scenario parameters such as whether to run MOVES in inventory or lookup table mode, geographic boundaries ( a county or multiple counties) , time spans (year, month(s), hour(s) of the day, weekdays and weekends) , fuel types, vehicle types, road types, and pollutants. The runspec is also where in put data sets (other than the C DM ) are identified. Two input data sets were prepared for 2008 MOVES runs, including the early NLEV program (see Section 5.1.6) and Stage 2 vapor recovery controls. All other inputs are provided in

the CDM.

The CDM for New C astle for 2008 included county

- specific data for all of the parameters provided in Section 5.1 of this report. Conversely , model default data were used for the following parameters: VMT daily and hourly fractions, ramp fractions, and diesel sales fractions by vehicle type. In addition, speed bin profiles and road type VMT fractions were not vehicle type specific.

The MOVES emissions outputs were specified by county and month at the SCC level (see Table

5

- 1).



### 5.3 Controls

All MOVES

- recognized on

- road co ntrol measures known to be in place in Delaware in 2008

were included in the MOVES emission inventory mode modeling. Local control programs include Delaware’s I/M program, the Federal reformulated gasoline program, and the Northeast Ozone Transport Region LEV program. The MOVES model internally includes all national control programs, such as the Tier 1 and Tier 2 gasoline fuel and light duty engine emission

standards as well as the ultra

- low sulfur diesel fuel and heavy duty engine standards.

Two Delawar e control programs, the anti

- tampering procedures (ATP) performed at the inspections lanes and the anti

- idling regulation (DNREC, 2005) were not accounted for in the MOVES runs since the model does not provide for inputting these programs

. For the ATP

con trol program , v ehicles that are tested are also check ed to see if the catalytic converter, gas cap and fuel inlet restrictor are present. Vehicles will fail inspection if an y of these devices are missing.

Regulation 1145, Excessive Idling of Heavy Duty V ehicles, is designed to eliminate emissions caused by extending idling. While MOVES delineates emissions processes for extended idling,

current ly the available control programs within MOVES do not account for anti

- idling measures. Delaware currently has no off

- model method to determine emission benefits from either ATP or Reg. 1145.



### 5.4 Results

The PM 2.5 exhaust emissions are comprised of elemental carbon, organic carbon, and sulfates,

while total PM 2.5 shown in Table 5

- 10 includes exhaust, brake wear, a nd tire wear emissions.

PM 2.5 exhaust emissions account for 91.4% of total PM 2.5 emissions.2008 A TTAINMENT Y EAR S TATE I MPLEMENTATION P LAN E MISSIONS I NVENTORY FOR PM 2.5 , SO 2 , & NO
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- 9 Table 5

- 1 0

. 200 8 Annual On

- road Mobile Emissions by Vehicle Type for New Castle County

Vehicle Type Annual Emissions, TPY

PM 2.5 SO 2 NO
x Light

- duty Gasoline Ve hicles 49 31 2,188

Light

- duty Gasoline Trucks 55 44 3,310

Heavy

- duty Gasoline Vehicles 5 4 324

Motorcycles 2 1 40

Light

- duty Diesel Vehicles 1 0 11

Light

- duty Diesel Trucks 8 1 130

Heavy

- duty Diesel Vehicles 142 12 2,879

Total 282 94 9,311

5.5 Refere nces

DNREC , 200 5 : Regulations Governing the Control of Air Pollution

, Regulation 1145, Delaware Department of Natural Resources and Environmental Control, Division of Air Quality, April 11, 2005

.

EPA, 200 9 : U.S. Environmental Protection Agency, “Reform ulated Gasoline Parameters for 2008” spreadsheet containing fuel survey data send via e

- mail by Jamiee Dong, Office of Transportation and Air Quality, to Steven Potter, Bureau of Air Management, CT DEM, March 4, 2009

.

NCDC, 200 9 : Annual Climatological Su mmary, National Climatic Data Center , Asheville, NC,

website accessed December 200 9

.