AMENDMENTS TO DELAWARE PHASE II ATTAINMENT DEMONSTRATION FOR THE PHILADELPHIA-WILMINGTON-TRENTON OZONE NON-ATTAINMENT AREA

Transcription

1 Doc. No /xx/xx/xx (PROPOSAL) AMENDMENTS TO DELAWARE PHASE II ATTAINMENT DEMONSTRATION FOR THE PHILADELPHIA-WILMINGTON-TRENTON OZONE NON-ATTAINMENT AREA Submitted To U.S. Environmental Protection Agency By Delaware Department of Natural Resources and Environmental Control Dover, Delaware April 2003

2 Table of Contents Page 1. Introduction 1 2. Requirements from EPA on Use of MOBILE6 Model 2 3. MOBILE6 Estimates of On-Road Mobile Source Emissions 2 4. Comparison of MOBILE6-Based Estimates and MOBILE5-Based Estimates 3 5. New MOBILE6-Based Motor Vehicle Emission Budgets 5 Appendix A. MOBILE6 Data Files and Emission Calculations 6 List of Tables Page Table 1. MOBILE6 Estimates of On-Road Motor Vehicle Emissions in Table 2. MOBILE5b Estimates of On-Road Motor Vehicle Emissions in Table 2a. Comparison of Percentage Changes in On-Road Mobile Emissions 4 Table 3. New MOBILE6-Based Motor Vehicle Emission Budgets for ii

3 List of References 1. Federal Clean Air Act, 42 U.S.C.A. '7401 et seq., as amended by the Clean Air Act Amendments of 1990, P.L , November 15, Delaware Phase II Attainment Demonstration for Philadelphia-Wilmington-Trenton Ozone Nonattainment Area, Delaware Department of Natural Resources and Environmental Control, Dover, Delaware, May 1998, as amended in January 2000, and in December, Memorandum: Policy Guidance on the Use of MOBILE6 for SIP Development and Transportation Conformity, from John S. Seitz, Director of Office of Air Quality Planning and Standards, and Margo T. Oge, Director of Office of Transportation and Air Quality, US EPA, Washington D.C., January 18, Delaware 1996 Milestone Demonstration for Kent and New Castle Counties: Demonstrating Adequate Progress toward Attainment of the 1-Hour National Ambient Air Quality Standard for Ground-Level Ozone, Delaware Department of Natural Resources and Environmental Control, Dover, Delaware, January The Delaware 2005 Rate-of-Progress Plan for Kent and New Castle Counties, Delaware Department of Natural Resources and Environmental Control, Dover, Delaware, December Amendments to Delaware 2005 Rate-of-Progress Plan for Kent and New Castle Counties, Delaware Department of Natural Resources and Environmental Control, Dover, Delaware, as proposed in April FR 70444, December 16, 1999; Approval and Promulgation of Air Quality Implementation Plans; Delaware; One-hour Ozone Attainment Demonstration for the Philadelphia-Wilmington-Trenton Ozone Nonattainment Area; proposed rule FR 54598, October 29, 2001; Approval and Promulgation of Air Quality Implementation Plans; Delaware; Post-1996 Rate-of-Progress Plans and One-hour Ozone Attainment Demonstration for the Philadelphia-Wilmington-Trenton Ozone Nonattainment Area; final rule. 9. Memorandum: Clarification of Policy Guidance for MOBILE6 SIPs in Mid-Course Review Areas, from T. Helms and L. Cook, Office of Air Quality Planning and Standards, US EPA, Research Triangle Park, North Carolina, February, iii

4 1. Introduction Under the Clean Air Act Amendments of 1990 (CAAA, Reference 1), Kent and New Castle Counties in Delaware are classified as severe nonattainment areas with respect to the 1-hour National Ambient Air Quality Standard (NAAQS) for ground-level ozone. The CAAA requires Delaware to submit to the US Environmental Protection Agency (EPA) a State Implementation Plan (SIP) revision to demonstrate that the 1-hour ozone standard can be attained in 2005 in these two counties with necessary and adequate control measures from VOC and NOx emission sources. That SIP revision, entitled Delaware Phase II Attainment Demonstration for Philadelphia-Wilmington-Trenton Ozone Nonattainment Area, was originally submitted to EPA in May 1998, and amended two times thereafter (Reference 2). One requirement of EPA for a state s attainment demonstration SIP revision is to set up on-road motor vehicle VOC and NOx emission budgets for use in transportation conformity analysis in that state. In its amendments to the Phase II Attainment Demonstration SIP in January 2000, Delaware set up these two budgets for 2005 using EPA s MOBILE5b model and including MOBILE5-based Tier 2 benefits. In its amendments to the Phase II Attainment Demonstration SIP in December 2000, Delaware committed that it would revise the budgets within one year after the release of the thenanticipated MOBILE6 model. In January 2002, EPA officially released the MOBILE6 model. The document proposed herein is to use MOBILE6 model to revise the on-road motor vehicle VOC and NOx emission budgets in the Delaware Phase II Attainment Demonstration SIP, as amended in January 2000 (Reference 2). The agency with direct responsibility for preparing and submitting this document is the Delaware Department of Natural Resources and Environmental Control (DNREC), Division of Air and Waste Management, Air Quality Management Section (AQM), under the direction of Ali Mirzakhalili, Program Administrator. The working responsibility for this document falls within the Planning and Community Protection (PCP) Branch of AQM, under the management of Raymond H. Malenfant, Program Manager II, and Ron Amirikian, Program Manager I. The following staff members of PCP are responsible for the preparation of this document: Frank Gao, Ph.D., P.E., Environmental Engineer Principal Author and Project Leader Phil Wheeler, MRP, Environmental Planner Lead person for MOBILE6 modeling Comments and/or questions regarding this document should be addressed to F. Gao at (302) , Frank.Gao@state.de.us, or Phil Wheeler at (302) , Philip.Wheeler@state.de.us, Air Quality Management Section, DAWM-DNREC, 156 South State Street, Dover, DE

5 2. Requirements from EPA on Use of MOBILE6 Model In January 2002, EPA officially released the MOBILE6 model for states to use in their ozone SIP revisions and transportation conformity analysis. In a policy guidance regarding the use of MOBILE6 model (Reference 3), EPA requires that, if a state used MOBILE5-based Tier 2 benefits when it determined its previous on-road motor vehicle emission budgets, the state must revise those budgets within one year after MOBILE6 is released, and submit the revised budgets to EPA as a SIP revision. Since Delaware used the MOBILE5-based Tier 2 benefits in its last mobile budget SIP submittal, Delaware needs to meet this requirement upon the MOBILE6 release (See also References 7 and 8). According to the same guidance, Delaware can revise its motor vehicle emission budgets using MOBILE6 without revising the entire Phase II Attainment Demonstration SIP or completing additional modeling, if Delaware can satisfy the following two criteria: (1) the SIP continues to demonstrate attainment when the MOBILE6 is used to estimate motor vehicle emissions and to set up new emission budgets, and (2) the growth and control strategy assumptions for stationary sources and non-road mobile sources continue to be valid to maintain the overall conclusions of the SIP. Delaware has decided not to revise the entire Phase II Attainment Demonstration SIP and not to conduct additional modeling. The second criterion above can be satisfied by the following two documents: (1) Delaware 1996 Milestone Demonstration for Kent and New Castle Counties (Reference 4), and (2) Delaware 1999 Milestone Compliance Demonstration for Kent and New Castle Counties. In these two documents, Delaware has successfully demonstrated that the overall emissions of VOC and/or NOx in the 1996 and 1999 Periodical Emission Inventories are below the emission targets in these two milestone years, which indicates continuous adequate progress toward the attainment of the 1-hour ozone standard in In addition, Delaware is currently amending its 2005 Rate-of-Progress Plan by incorporating the MOBILE6-based mobile source emission estimates. In this current SIP amendments document, Delaware has demonstrated that, with adequate additional controls over non-mobile sources, the 2005 rate-of-progress emission targets for both VOC and NOx will be successfully met (Reference 6). In the following sections of this document, Delaware will show that EPA s first criterion will be satisfied by demonstrating that the MOBILE6 estimates of motor vehicle emissions are equal to or lower than the previous MOBILE5 estimates for the attainment year of 2005, and that the percentage change in on-road motor vehicle emissions using MOBILE6 is the same or higher than the percentage change calculated using MOBILE5. 3. MOBILE6 Estimates of On-Road Mobile Source Emissions The MOBILE6 modeling has been conducted in-house cooperatively by staff members of DelDOT and DNREC Air Quality Management Section. The modeling includes all control measures specified in Delaware s 2005 Rate-of-Progress Plan (Reference 5). The model input files, output files, and summary of emission factors generated by MOBILE6 are provided in Appendix A of this document. Using the - 2 -

6 emission factors generated by MOBILE6 and the latest planning assumption (i.e., the 2002 vehicle registration data, VMT/speed data) currently available to the responsible agencies (DNREC and DelDOT), the MOBILE6-based motor vehicle emissions can be calculated. The calculations and results are also presented in Appendix A. The MOBILE6 estimates of on-road motor vehicle emissions in the attainment year 2005 are summarized in Table 1. Table 1. MOBILE6 Estimates of On-Road Motor Vehicle Emissions in Attainment Year Kent County New Castle County Total NAA* 2005 VOC NOx VOC NOx VOC NOx Emissions (TPD) *NAA: Non-Attainment Area. 4. Comparison of MOBILE6-Based Estimates and MOBILE5b-Based Estimates The MOBILE5-based estimates of on-road motor vehicle emissions in 2005 are presented in Table 2. These estimates are also the on-road motor vehicle emission budgets as specified in Delaware s Phase II Attainment Demonstration SIP, as amended in January 2000 (Reference 2). Details of how Delaware conducted MOBILE5b modeling work and obtained these estimates are provided in Delaware s 2005 Rate-of- Progress Plan (Reference 5). Table 2. MOBILE5 Estimates of On-Road Motor Vehicle Emissions in Attainment Year Kent County New Castle County Total NAA* 2005 VOC NOx VOC NOx VOC NOx Emission (TPD) *NAA: Non-Attainment Area. Comparison of MOBILE6-based estimates and MOBILE5-based estimates can be made through the following steps. (1) For the total non-attainment area (NAA), the MOBILE6-based VOC emission is 0.62 TPD higher than the MOBILE5-based VOC emission ( = TPD), while the MOBILE6-based NOx emission is 1.11 TPD lower than the MOBILE5-based NOx emission ( = TPD). (2) Delaware s 1990 baseline VOC and NOx emissions, as adjusted to the attainment year of 2005 using MOBILE6 model, are TPD and TPD, respectively (Table 3, Reference 6). The ratio of VOC to NOx baseline emissions is - 3 -

7 VOC : NOx = : = 1 : 1.19 (3) Using the above VOC-to-NOx emission ratio, the 0.62 TPD VOC emission increase due to using MOBILE6 is equivalent to a 0.74 TPD NOx emission increase (0.62 x 1.19 = 0.74 TPD). This equivalent NOx emission increase is smaller than the 1.13 TPD NOx emission decrease as indicated in (1) above. The above comparison indicates that in the attainment year of 2005, the new MOBILE6 estimates are lower than the MOBILE5 estimates previously presented in Delaware s Phase II Attainment Demonstration SIP, as amended in January 2000 (Reference 2), and in Delaware s 2005 Rate-of-Progress Plan (Reference 5). In February 2003, EPA issued a memorandum that provides clarifying guidance on how to demonstrate attainment when using MOBILE6-based estimates to replace MOBILE5-based estimates (Reference 9). According to this latest clarifying guidance, Delaware should compare the percentage change in the on-road mobile source emissions between the 1990 base year and the attainment year of If the percentage change in the on-road emissions using MOBILE6 is the same or higher than the percentage change based on MOBILE5, a shortfall is not indicated and Delaware s attainment demonstration SIP continues to demonstrate attainment. The above-mentioned comparison is accomplished and summarized in Table 2a. As indicated in Table 2a, the percentage changes in the on-road mobile emissions using MOBILE6 are 62.6% and 26.2% for VOC and NOx, respectively. The percentage changes using MOBILE5 are 58.3% and 18.1% for VOC and NOx, respectively. It is clear that percentage changes in both VOC and NOx emissions in the mobile sector are higher when using MOBILE6 than using MOBILE5, which indicates that Delaware continues to demonstrate attainment. Therefore, the first criterion specified in EPA s MOBILE6 guidance document (Reference 3) is satisfied. As mentioned in Section 2 of this document, the second criterion has been satisfied as well. Table 2a. Comparison of Percentage Changes in On-Road Mobile Emissions. Kent County New Castle County Total NAA VOC NOx VOC NOx VOC NOx MOBILE6 Estimates 1990 Base Year Attainment Year % reduction 56.6% 8.9% 64.2% 31.4% 62.6% 26.2% MOBILE5b Estimates 1990 Base Year Attainment Year % reduction 62.5% 25.6% 56.7% 15.2% 58.3% 18.1% - 4 -

8 5. New MOBILE6-Based Motor Vehicle Emission Budgets Since the two criteria specified in EPA s MOBILE6 guidance document (Reference 3) are satisfied, Delaware has decided to set the new MOBILE6-based estimates to be the new on-road motor vehicle emission budgets for Kent and New Castle Counties in the attainment year of 2005, as presented in Table 3. After EPA determines that mobile budgets established by this SIP revision are adequate, these budgets shall be used to determine the conformity of transportation plans and programs to the SIP (References 3, 7 and 8). Table 3. New MOBILE6-Based Motor Vehicle Emission Budgets for Attainment Year Kent County New Castle County Total NAA* 2005 VOC NOx VOC NOx VOC NOx Budgets (TPD) * Non-attainment area

9 Appendix A. MOBILE6 Data Files and Emissions Calculations. Due to the large number of the data files, hard and/or electronic copies will be available only upon request. Written request should be addressed to Phil Wheeler at or AQM-DNREC, 156 S. State Street, Dover, DE