EPA-4 50/3-75-040
MARCH 1975
IMPLEMENTATION PLAN REVIEW
FOR
DELAWARE
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
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EPA-450/3-75-040
IMPLEMENTATION PLAN REVIEW
FOR
DELAWARE
AS REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
Prepared by the Following Task Force:
U. S. Environmental Protection Agency, Region III
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Environmental Services of TRW, Inc.
800 Foil in Lane, SE, Vienna, Virginia 22180
(Contract 68-02-1385)
U. S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
Property Of
March 1975 EPA U'rrr
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DELAWARE
ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
(SECTION IV - STATE IMPLEMENTATION PLAN REVIEW)
Table of Contents Page
1.0 EXECUTIVE SUMMARY 1
2.0 STATE IMPLEMENTATION PLAN REVIEW 5
2. I Summary . . , 5
2.2 Air Quality Setting For The State Of Delaware 10
2.3 Background on the Development of Delaware's
Current State Implementation Plan 11
3.0 CURRENT ASSESSMENTS BASED ON STATE IMPLEMENTATION
PLAN REVIEW 13
3.1 Metropolitan Philadelphia Air Quality Control
Region 14
3.2 Southern Delaware Air Quality Control Region. ..... 15
APPENDIX A - STATE IMPLEMENTATION PLAN BACKGROUND
APPENDIX B - REGIONAL SUMMARY
APPENDIX C - POWER PLANT SUMMARY
APPENDIX D - INDUSTRIAL, COMMERCIAL, INSTITUTIONAL SOURCE SUMMARY
APPENDIX E - AQCR FUEL USE SUMMARY
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1.0 EXECUTIVE SUMMARY
The enclosed report is the U.S. Environmental Protection Agency's
(EPA) response to Section IV of the Energy Supply and Environmental
Coordination Act of 1974 (ESECA). Section IV required EPA to review
each State Implementation Plan (SIP) to determine if revisions can be
made to control regulations for stationary fuel combustion sources
without interfering with the attainment and maintenance of the National
Ambient Air Quality Standards (NAAQS). In addition to requiring th,at
EPA report to the State on whether control regulations might be revised,
ESECA provides that EPA must approve or disapprove any revised regulations
relating to fuel burning stationary sources within three months after
they are submitted to EPA by the States. The States may, as in the
Clean Air Act of 1970, initiate State Implementation Plan revisions;
ESECA does not, however require States to change any existing plan.
Congress has intended that this report provide the State with infor-
mation on excessively restrictive control regulations. The intent of
ESECA is that SIP's, wherever possible, be revised in,the interest of
conserving Tow sulfur fuels or converting sources which burn oil or
natural gas to coal. EPA's objective in carrying out the SIP reviews,
therefore, has been to try to establish if emissions from combustion
sources may be increased. Where an indication can be found that
emissions from certain fuel burning sources can be increased and still
attain and maintain NAAQS, it may be plausible that fuel resource
allocations can be altered for "clean fuel savings" in a manner con-
sistent with both environmental and national energy needs.
In many respects, the ESECA SIP reviews parallel EPA's policy on
clean fuels. The Clean Fuels Policy has consisted of reviewing imple-
mentation plans with regards to saving low sulfur fuels and, where the
primary sulfur dioxide air quality standards were not exceeded, to
encourage States to either defer compliance regulations or to revise
the S02 emission regulations. The States have also been asked to
discourage large scale shifts from coal to oil where this could be done
without jeopardizing the attainment and maintenance of the NAAQS.
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To date, EPA's fuels policy has addressed only those States with
the largest clean fuels saving potential. Several of these States have
or are currently in the process of revising SOy regulations. These States
are generally in the Eastern half of the United States. ESECA, however,
extends the analysis of potentially over-restrictive regulations to all 55
States and territories. In addition, the current reviews address the attain-
ment and maintenance of all the National Ambient Air Quality Standards.
There are, in general, four predominant reasons for the existence
of overly restrictive emission limitations within the State Implementation
Plans. These are (1) the state's prerogative to surpass NAAQS; (2) the
use of the example region approach in developing State-wide air quality con-
trol strategies; (3) the existence of state air quality standards which are
more stringent than NAAQS; and (4) the "hot spots" in only part of an Air
Quality Control Region (AQCR) which have been used as the basis for control-
ling the entire region. Since each of these situations effect many State
plans and in some instances conflict with current national energy concerns,
a review of the State Implementation Plans is a logical follow-up to EPA's
initial appraisal of the SIP's conducted in 1972. At that time SIP's were
approved by EPA if they demonstrated the-attainment of NAAQS p_r more stringent
state air quality standards. Also, at that time an acceptable method for
formulating control strategies was the use of an example region for demon-
strating the attainment of the standards.
The example region concept permitted a State to identify the most
polluted Air Quality Control Region (AQCR) and adopt control regulations which
would be adequate to attain the NAAQS in that region. In using an example
region, it was assumed that NAAQS would be attained in the other AQCRs of
the State if the control regulations were applied to similar sources. The
problem with the use of an example region is that it can result in controls
which are more stringent than needed to attain NAAQS, especially in the util-
ization of clean fuels, for areas of the State where sources would not other-
wise contribute to NAAQS violations. For instance, a control strategy based
on a particulaV region or source can result in a regulation requiring 1 per-
cent sulfur oil to be burned state-wide where the use of 3 percent sulfur
coal would be adequate to attain NAAQS in some locations.
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EPA anticipates that a number of States will use the review find-
ings to assist them in making the decision whether or not to revise
portions of their State Implementation Plans. However, it is most
important for those States which desire to submit a revised plan to
recognize the review's limitations. The findings of this report are
by no means conclusive and are neither intended nor adequate to be the
sole basis for SIP revisions; they do, however, represent EPA's best
judgment and effort in complying with the ESECA requirements. The
time and resources which EPA has had to prepare the reports has not
permitted the consideration of growth, economics, and control strategy
tradeoffs. Also, there has been only limited dispersion modeling data
available by which to address individual point source emissions. Where
the modeling data for specific sources were found, however, they were
used in the analysis.
The data upon which the reports' findings are based are the most
currently available to the Federal Government. However, EPA believes
that the States possess the best information for developing revised
plans. The States have the most up-to-date air quality and emissions
data, a better feel for growth, and the fullest understanding for the
complex problems facing them in the attainment and maintenance of
air quality. Therefore, those States desiring to revise a plan are
encouraged to verify and, in many instances, expand the modeling and
monitoring data supporting EPA's findings. In developing a suitable
plan, it is suggested that States select control strategies which
place emissions for fuel combustion sources into perspective with
all sources of emissions such as smelters or other industrial pro-
cesses. States are encouraged to consider the overall impact which
the potential relaxation of overly restrictive emissions regulations
for combustion sources might have on their future control programs.
This may include air quality maintenance, prevention of significant
deterioration, increased TSP, NO , and HC emissions which occur in
/\
fuel switching, and other potential air pollution situations such as
sul fates.
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Part of each State's review was organized to provide an analysis of
the S(L and TSP emission tolerances within each of the various AQCRs.
The regional emission tolerance estimate is, in many cases, EPA's only
measure of the "over-cleaning" accomplished by a SIP. The tolerance
assessments have been combined in Appendix B with other regional air
quality "indicators" in an attempt to provide an evaluation of a region's
candidacy for changing emission limitation regulations. In conjunction
with the regional analysis, a summary of the State's fuel combustion
sources (power plants, industrial sources and area sources) has been
carried out in Appendices C, D and E.
The State Implementation Plan for Delaware has been reviewed
for the most prevalent causes of over-restrictive fuel combustion emission
limiting regulations. The major findings of the review are:
FOR BOTH TOTAL SUSPENDED PARTICULATES AND SULFUR DIOXIDE.
THERE IS LITTLE TO NO INDICATION.THAT CURRENT EMISSION
REGULATIONS ARE OVER-RESTRICTIVE.
The supportive findings of the SIP review are:
National Ambient Air Quality standards for suspended parti-
culates and sulfur dioxide were exceeded in the Metropolitan
Philadelphia Air Quality Control Region during 1973, and is
a poor candidate for revising emission regulations.
In the Southern Delaware Air Quality Control Region, there
were no violations of National 'Ambient Air Quality Standards
for either suspended particulates or sulfur dioxide during
1973. However there are no modeling data available to determine
if an increase in emissions could be tolerated without exceeding
standards. There are no regulatory limits on the fuel sulfur
content in this region.
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2.0 STATE IMPLEMENTATION PLAN REVIEW
2.1 SUMMARY
A revision of fuel combustion source emissions.regulations will.de-
pend on many factors.
Does the State have air quality standards which are more
stringent than NAAQS?
Does the State have emission limitation regulations for control
of (I) power plants, (2) industrial sources, (3) area sources?
Did the State use an example region approach for demonstrating
the attainment of NAAQS or more stringent State standards?
Has the State not initiated action to modify combustion source
emission regulations for fuel savings; i.e., under the Clean
Fuels Policy?
Are there no proposed Air Quality Maintenance Areas?
Are there indications of a sufficient number of monitoring sites
within a region?
Is there an expected 1975 attainment date for NAAQS in the State
Implementation Plan?
Based on (1973) air quality data, are there no reported violations
of NAAQS?
Based on (1973) air quality data, are there indications of a
tolerance for increasing emissions?
Are the total emissions from stationary fuel combustion sources
proportionally lower than those of other sources?
Do modeling results for specific fuel combustion sources show a
potential for a regulation revision?
The following portion of this report is directed at answering these
questions. An AQCR's potential for revising regulations increases when
there are affirmative responses to the above. . .
The initial part of the SIP review report, Section 2 and Appendix A,
was organized to provide the background and current situation information
for the State Implementation Plan. Section 3 and the remaining Appendices
provide an AQCR analysis which helps establish the overall potential for
revising regulations.
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Based on an overall evaluation of EPA's current information, AOCR's
have been rated as either a good, poor or marginal candidate for revising
emission limiting regulations, These ratings which are shown in Table 2-1
were determined by assessing the following criteria:
Good
1) Adequate number
of air monitoring
s i tes
2) No NAAQS violations
3) Attainment date of
1975 for NAAQS in
the SIP
4) No proposed AQMAs
5) Modeling results
show a potential
for regulation
revision
Poor
1) Violation of NAAQS
2) Attainment date for
NAAQS later than
1975
3) Proposed AQMA
4) Modeling results
show no potential
for regulation
revision
Marginal
1) No air quality data
or insufficient number
of monitoring sites
2) Inconsistent
"indicators"
For an AQCR to be rated as a good candidate, all of the criteria
listed under "Good" would have to be satisfied. The overriding factor in
rating an AQCR as a poor candidate is a violation of either the primary
or secondary National Ambient Air Quality Standards during 1973. However,
if any of the other conditions listed under "Poor" exists, the AQCR would
still receive that rating. The predominant reason for a marginal rating
is a lack of sufficient air quality data. In Priority III regions, air
monitoring was not required during 1973, therefore, there may be no data
with which to determine the current air quality status. Marginal ratings
are also given when there are varying or inconsistent "indicators".
After a candidacy has been given to a region, a follow-up analysis
should be conducted depending on the rating. A region that has been indi-
cated to be a good candidate for regulation revision should be examined
in more detail by the state and the Regional office of the EPA, including
an examination of current air quality, emissions, and fuel use data, with
which the state has more familiarity. If the state feels that clean fuels
could be saved in a region rated marginal then an analysis of air quality
data that may have become available since this report should be examined.
If current data do not indicate a potential for regulation revision then
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2.0 STATE IMPLEMENTATION PLAN REVIEW
2.1 SUMMARY'
A revision of fuel combustion source emissions regulations will de-
pend on many factors.
Does the State have air quality standards which are more
stringent than NAAQS?
Does the State have emission limitation regulations for control
of (I) power plants, (2) industrial sources, (3) area sources?
Did the State use an example region approach for demonstrating
the attainment of NAAQS or more stringent State standards?
Has the State not initiated action to modify combustion source
emission regulations for fuel savinqs; i.e., under the Clean
Fuels Policy? ' ' . " .
Are there no proposed Air Quality Maintenance Areas?
Are there indications of a sufficient number of monitoring sites
within a region?
t Is there an expected 1975 attainment date for NAAQS in the State
Implementation Plan?
Based on (1973) air quality data, are there,.no reported violations
of NAAQS?
Based on (197,3) air quality data, are there indications of a:
tolerance for increasing emissions?
t Are the total emissions from stationary fuel combustion sources
proportionally lower than those of other sources?
Do modeling results for specific fuel combustion sources show a
potential for a regulation revision?
\
The following portion of this report is directed at answering these
questions. An AQCR's potential for revising regulations increases when
there are affirmative responses to the above.
The initial part of the SIP review report, Section 2 and Appendjx A,
was organized to provide the background and current situation information
for the State Implementation Plan. Section 3 and the remaining Appendices
provide an AQCR analysis which helps establish the overall potential for
revising regulations.
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Based on an overall evaluation of EPA's current information, AQCR's
have been rated as either a good, poor or marginal candidate for revising
emission limiting regulations. These ratings which are shown in Table 2-1
were determined by assessing the following criteria:
Good
1) Adequate number
of air monitoring
sites
2) No NAAQS violations
3) Attainment date of
1975 for NAAQS in
the SIP
4) No proposed AQMAs
5) Modeling results
show a potential
for regulation
revision
Poor
1) Violation of NAAQS
2) Attainment date for
NAAQS later than
1975
3) Proposed AQMA
4) Modeling results
show no potential
for regulation
revision
Marginal
1) No air quality data
or insufficient number
of monitoring sites
2) Inconsistent
"indicators"
For an AQCR to be rated as a good candidate, all of the criteria
listed under "Good" would have to be satisfied. The overriding factor in
rating an AQCR as a poor candidate is a violation of either the primary
or secondary National Ambient Air Quality Standards during 1973. However,
if any of the other conditions listed under "Poor" exists, the AQCR would
still receive that rating. The predominant reason for a marginal rating
is a lack of sufficient air quality data. In Priority III regions, air
monitoring was not required during 1973, therefore, there may be no data
with which to determine the current air quality status. Marginal ratings
are also given when there are varying or inconsistent "indicators".
After a candidacy has been given to a region, a follow-up analysis
should be conducted depending on the rating. A region that has been indi-
cated to be a good candidate for regulation revision should be examined
in more detail by the state and the Regional office of the EPA, including
an examination of current air quality, emissions, and fuel use data, with
which the state has more familiarity. If the state feels that clean fuels
could be saved in,a region rated marginal then an analysis of air quality
data that may have become available since this report should be examined.
If current data do not indicate a potential for regulation revision then
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2.0 STATE IMPLEMENTATION PLAN,REVIEW
2.1 SUMMARY
A revision of fuel combustion source emissions regulations will de-
pend on many factors.
Does the State have air quality standards which are more
stringent than NAAQS?
Does the State have emission limitation regulations for control
of (I) power plants, (2) industrial sources, (3) area sources?
Did the State use an example region approach for demonstrating
the attainment of NAAQS o_r more stringent State standards?
Has the State not initiated action to modify combustion source .
emission regulations for fuel savings; i.e., under the Clean
Fuels Policy?
Are there no proposed Air Quality Maintenance Areas?
*
Are there indications of a sufficient number of monitoring sites
within a region?
Is there an expected 1975 attainment date for NAAQS in the State
Implementation Plan?
Based on (1973) air quality data, are there no reported violations
of NAAQS?
a Based on (1973) air quality data, are there indications of a
tolerance for increasing emissions?
Are the total emissions from stationary fuel combustion sources
proportionally lower than those of other sources?
Do modeling results for specific fuel combustion sources show a
potential for a regulation revision?
The following portion of this report is directed at answering these
questions. An AQCR's potential for revising regulations increases when
there are affirmative responses to the above.
The initial part of the SIP review report, Section 2 and Appendix A,
was organized to provide the background and current situation information
for the State Implementation Plan. Section 3 and the remaining Appendices
provide an AQCR analysis which helps establish the overall potential for
revising regulations.
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Based on an overall evaluation of EPA's current information, AOCR's
have been rated as either a good, poor or marginal candidate for revising
emission limiting regulations. These ratings which are shown in Table 2-1
were determined by assessing the following criteria:
Good
1) Adequate number
of ai r moni toring
sites
2) No NAAQS violations
3) Attainment date of
1975 for NAAQS in
the SIP
4) No proposed AQMAs
5) Modeling results
show a potential
for regulation
revision
Pp_or_
1) Violation of NAAQS
2) Attainment date for
NAAQS later than
1975
3) Proposed AQMA
4) Modeling results
show no potential
for regulation
revision
Marginal
1 ) No air quality data
or insufficient number
of monitoring sites
2) Inconsistent
"indicators"
For an AQCR to be rated as a good candidate, all of the criteria
listed under "Good" would have to be satisfied. The overriding factor in
rating an AQCR as a poor candidate is a violation of either the primary
or secondary National Ambient Air Quality Standards during 1973. However,
if any of the other conditions listed under "Poor" exists, the AQCR would
still receive that rating. The predominant reason for a marginal rating
is a lack of sufficient air quality data. In Priority III regions, air
monitorirrg was not required during 1973, therefore, there may be no data
with which to determine the current air quality status. Marginal ratings
are also given when there are varying or inconsistent "indicators".
After a candidacy has been given to a region, a follow-up analysis
should be conducted depending on the rating. A region that has been indi-
cated to be a good candidate for regulation revision should be examined
in more detail by the state and the Regional office of the EPA, including
an examination of current air quality, emissions, and fuel use data, with
which the state has more familiarity. If the state feels that clean fuels
could be saved in a region rated marginal then an analysis of air quality
data that may have become available since this report should be examined.
If current data do not indicate a potential for regulation revision then
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further study would not be warranted. An AQCR that has been indicated to
be a poor candidate would not warrant further study unless the state feels
that new information has become available indicating that the poor rating
is no longer valid.
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TABLE 2-1
DELAHARE STATE IMPLEMENTATION PLAN REVIEW
(SUMMARY)
"Indicators"
* Does the State have air quality standards which
are more stringent than NAAQS?
i Does the State have emission limiting regulations
for control of:
I. Power plants
2. Industrial sources
3. Area sources
Did the State use an example region approach for
demonstrating the attainment of NAAQS or more strin-
gent State standards?
Has the State not initiated action to modify
combustion source, emission regulations for fuel
savings; i.e., under the Clean Fuels Policy?
Are there no proposed Air Quality Maintenance
Areas?
Are there indications of a sufficient number of
monitoring sites within a region?
t Is there an expected 1975 attainment date for
NAAQS in the State Implementation Plan?
Based on (1973) Air Quality Data, are there no
reported violations af NAAQS?
Based on (1973) Air Quality Data, are there
indications of a tolerance for increasing emissions?
Are the total emissions from stationary fuel
.combustion sources proportionally lower than those of
other sources?
Do modeling results for specific fuel combustion
sources show a potential for a regulation revision?3
Based on the above indicators, what is the poten-
tial for revising fuel combustion source emission
limiting regulations?
State of
DeI aware
TSP
Yes
Yes
Yes
Yes
No
SO,
Yes
Yes
Yes
Yes
No
Yes Yes
Metropolitan
Phi ladelphia
AQCR 45
TSP SO,
Yes Yes
No No
Poor Poor
Southern
Delaware
AQCR 46
TSP
Yes
Yes
Yes
No
No
Yes
Yes
Yes
Ho
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No No
N.A. N.A.
Marg. Marg.
Modeling data available for one power plant only
There are no regulatory limits on the fuel sulfur content.
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METROPOLITAN
PHILADELPHIA
INTERSTATE
(DELAWARE-
NEW JERSEY-
PENNSYLVANIA)
SOUTHERN
.DELAWARE
INTRASTATE
Figure 2-1 Delaware Air Quality Control Regions
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2.2 AIR QUALITY SETTING FOR THE STATE OF DELAWARE
2.2.1 Delaware Air Quality Control Regions
The State of Delaware has been divided into two Air Quality Control
Regions. The Federal designations of these regions and the other states
that comprise the interstate region are as follows:
Metropolitan Philadelphia Interstate (Pennsylvania, New Jersey)
Southern Delaware Intrastate
The Metropolitan Philadelphia AQCR is classified Priority I for both sus-
pended particulates and sulfur dioxide, while the Southern Delaware AQCR
is classified Priority III for these pollutants. There are no proposed
Delaware Air Quality Maintenance Areas in these regions.
2.2.2 Ambient Air Quality Standards
Delaware has adopted air quality standards for both suspended par-
ticulates and sulfur dioxide which are shown on Table A-2. The State stand-
ards for both pollutants are more stringent than the Federal standards, and
the State has also adopted a one-hour primary standard for particulates and
annual and 24-hour secondary standards for sulfur dioxide.
2.2.3 Air Quality Status
Air monitoring data for 1973 for total suspended particulates and
sulfur dioxide are summarized in Tables A-4 and A-5 respectively. These
data are from the SAROAD data bank as of July 1974, and the "Monthly Air
Quality Data Summary," State of Delaware Department of Natural Resources
and Environmental Control.
National Ambient Air Quality Standards for total suspended particu-
lates were exceeded during 1973 in each'of the three States comprising the
Metropolitan Philadelphia Air Quality Control Region. Sulfur dioxide stand-
ards were also exceeded in the region.
There were no air quality violations during 1973 in the Southern
Delaware AQCR, although there were not a substantial amount of data with
which to determine the air quality status. As previously mentioned, this
is a Priority III region for both suspended participates and sulfur dioxide,
therefore air monitors were not officially required during 1973.
10
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2.2.4 Emissions Summary
A summary of participate and sulfur dioxide emissions by region is
presented in Tables A-6 and A-7 respectively. These data are from the
"1972 National Emissions Report" June, 1974 which utilizes information in
the National Emissions Data System (NEDS).
In the Delaware portion of the Metropolitan Philadelphia AQCR, fuel
combustion sources account for approximately one-third of the particulate
and sulfur dioxide emissions, while compared to the total AQCR emissions,
Delaware fuel combustion sources contribute approximately one percent of
the emissions. However in the Southern Delaware AQCR, fuel combustion
sources contribute almost all of the particulate and sulfur dioxide emis-
sions (Table A-8).
2.3 BACKGROUND ON THE DEVELOPMENT OF DELAWARE'S CURRENT STATE IMPLEMENTA-
TION PLAN
2.3.1 Control Strategy for Particulate Matter and Sulfur Dioxide
The basis for recommending approval of the particulate matter and
sulfur oxides control strategies for the Delaware portion (New Castle County)
of the Metropolitan Philadelphia Interstate Air Quality Control Region was a
modeling analysis prepared by EPA using the Implementation Planning Program
(IPP). The analysis included: (1) an extensive update of the emission
inventories in the "Existing" Sulfur Oxides and Particulate Matter Plans
submitted by Delaware, Pennsylvania and New Jersey under the 1967 Clean
Air Act, and evaluated under the provisions of Section 16 (Savings Provi-
sion) of the Clean Air Act, as amended in 1970; (2) a careful calibration
of measured air quality data and predicted pollutant concentrations; and
(3) the application of the emission limitations which were to be submitted
with the final plans. The emission limitations applied to the sources lo-
cated in the Delaware portion of the Region follow:
A. Sulfur dioxide
1. Fuel combustion. The maximum sulfur content by weight for all fuels
is 1.0%. The regulation submitted in the plan also limited distil-
late oil to 0.3% by weight.
II
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B. Particulate Matter
I. Fuel combustion. For equipment with a heat input equal to or
greater than 500,000 BID per hour particulate emissions shall
not exceed 0.3 pounds per million BTU heat input.
The results of the analysis showed that the expected concentrations would
be below the national standards for sulfur oxides and particulate matter.
Furthermore, the modeling showed that additional control of Delaware sources
would have little impact upon the areas with the highest concentrations in
the Region (Philadelphia-Camden area), primarily due to the distances from
the sources in Delaware to these areas. While the predicted concentrations
did not include growth, it was estimated that a 22 percent growth in sulfur
oxides emissions and a 13 percent growth in particulate matter emissions
could be tolerated by 1975 before the secondary standards would be exceeded
in Delaware. In addition, the Delaware regulations provided for additional
point source control of particulate matter and a further reduction of the
fuel sulfur content if, between July 1, 1973, and October 1, 1974, the
secondary standards were exceeded in New Castle County. These measures,
the requirement that all new sources comply with the Federal Standards of
Performance for New Sources, and Delaware's control of construction and
modification of sources could be used to prevent pollutant concentrations
from exceeding th.e secondary standards. It was recommended that the State
of Delaware undertake a comprehensive study of growth patterns and trends
for each pollutant category to help assess future control needs.
The Southern Delaware Intrastate Air Quality Control Region is Pri-
ority III for particulate matter and sulfur oxides. Therefore, the plan
needed only to provide a strategy for insuring that the secondary standards
would be maintained. The plan stated that Delaware intended to maintain
the standards through strict control of new sources. The State also has
emission-limiting regulations which apply to this Region.
12
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3.0 CURRENT ASSESSMENTS BASED ON STATE IMPLEMENTATION PLAN REVIEW
The purpose of this section is to evaluate the available information
for the State of Delaware and determine the feasibility of revisions to
the SIP which would result in clean fuel conservation. The assessments
will be made by AQCR addressing each type of fuel combustion source: power
plants, large industrial and commercial/institutional sources, and area
sources. The assessments must be made for each pollutant separately and
are made on the basis of seven criteria: (1) 1973 air quality violations;
(2) expected NAAQS attainment dates; (3) proposed Air Quality Maintenance
Area (AQMA) designations; (4) total emissions; (5) portion of emissions
from Delaware fuel combustion sources; (6) regional tolerance for emissions
increase; and (7) pollutant priority classifications. Tables B-l and B-2
tabulate these criteria for TSP and S02, respectively.
As mentioned previously, regional air quality data for 1973 are pre-
sented in Tables A-4 and A-5 for total suspended particulates and sulfur
dioxide respectively. Table C-l shows the 1973 fuel use and fuel sulfur
content for the Delaware power plants. Table C-2 is a summary of modeling
results for one of the power plants.1 Although it is realized that there
are some limitations to results obtained by modeling, it is presented in
this report as another indicator in assessing the candidacy of a region to
revise emission regulations.
Appendix D shows the fuel use and emissions data for the major fuel
combustion sources that were listed in the NEDS emission inventory. Only
those sources emitting 100 tons per year or more of either particulates or
sulfur dioxide are listed. Appendix E shows the total fuel use for the two
Delaware Air Quality Control Regions.
The modeling analysis of the power plants was performed by the Wai den
Research Division of Abcor Inc. The model used was a Gaussian plume
model developed by the Meteorology Laboratory, EPA, and was based on
1972 plant operations. Detailed information can be found in; Modeling
Analysis of Power Plants for Fuel Conversion, (Group II) September 4, 1974.
13
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3.1 METROPOLITAN PHILADELPHIA INTERSTATE AIR QUALITY CONTROL REGION
3.1.1 Regional Assessment
This region has been rated a poor candidate for revision of either
participate or sulfur dioxide emission limits. During 1973, ambient levels
of total suspended particulates exceeded Federal standards in each of the
three States in this region. The highest annual average was recorded in
the Pennsylvania portion of the region, while the highest 24-hour value
was recorded in Delaware (Table A-4). Violations of the 24-hour standard
also occurred in New Jersey. There is virtually no potential for an in-
crease in particulate emissions in this region without further jeopardizing
air quality standards.
The Federal annual standard for sulfur dioxide was not exceeded in
the region during 1973, although it was equalled in the New Jersey portion
of the AQCR. A violation of the 24-hour standard was recorded in Delaware
and Pennsylvania. As with particulates, there is no tolerance for an in-
crease in sulfur dioxide emissions in the region.
3.1.2 Power Plant Assessment
There are two Delaware power plants in this region, having a combined
generating capacity of over 900 MW. Both of these plants were multi-fuel
fired during 1973. The smaller of the two plants, Delaware City, has been
firing high sulfur fuels, with the fluid coke containing an average sulfur
content of 6.7%, and .the fuel oil containing over 2% sulfur. The plant also
used a large amount of refinery gas. Even if there was a possibility of
revising emission limits in this region, a clean fuel savings could not be
achieved at this plant.
The Edge Moor plant in Wilmington is primarily oil fired, but also
used a small amount of natural gas during 1973. This plant consists of five
boilers, four of which are convertible to coal. Particulate control equip-
ment has tested efficiencies (1971) of 66%, 63%, 57%, and 95% respectively,
on units 1-4. Table C-2 summarizes the results of modeling analysis for
the plant showing the maximum contribution to ambient particulate and sul-
fur dioxide levels that would occur as a result of a switch to 2.5% sulfur
coal. The data indicate that under certain conditions, the emissions from
14
-------
this plant alone could cause violations of the primary 24-hour standard for
S02» and severely impact particulate levels. The meteorological conditions
which are associated with the highest ground-level contributions by this
plant are estimated to occur about twenty-five percent of the time.
3.1.3 Industrial, Commercial, Institutional Source Assessment
There are several major fuel combustion sources in the Delaware por-
tion of this region, which are listed in Table D-l. All of these sources
are firing oil representing a clean fuel savings potential, however because
of the air quality status there is no potential for a switch to coal or a
higher sulfur content fuel oil. Delaware point source fuel combustion ac-
counts for approximately five percent of the particulate and sulfur dioxide
emissions in the region.
3.1.4 Area Source Assessment
Area source fuel use is shown in Table E-'l. Based on the total amount
of fuel used, there is not a significant clean fuel savings afforded by these
sources. Area source fuel combustion accounts for approximately three per-
cent of the particulate emissions and thirty percent of the sulfur dioxide
emissions.
3.1.5 Fuel Use Assessment
Appendix E shows the fuel use for the region which accounts for the
majority of the oil and natural gas used in the State. Coal use is not sub-
stantial in the region.
3.2 SOUTHERN DELAWARE AIR QUALITY CONTROL REGION
3.2.1 Regional Assessment
This region has been rated marginal for revision of either particu-
late or sulfur dioxide emission limits. This rating was given since there
were no modeling data for any fuel combustion sources in the region to deter-
mine if there is a tolerance for an increase in emissions without violating
National Ambient Air Quality Standards. Also, there is no regulatory limit
on the sulfur content of fuel in this region.
15
-------
There were no violations of the Federal standards for either sus-
pended participates or sulfur dioxide during 1973 in this region (Tables
A-4, A-5). Suspended particulate data for 1974 also indicate that there
were no violations.
3.2.2 Power Plant Assessment
There are two power plants in this region, the Indian River plant
in Sussex County, and McKee Run in Kent County. These plants which have
a combined generating capacity of 373 MW contribute approximately eleven
percent of the particulate and seventy percent of the sulfur dioxide emis-
sions in the region.
The Indian River plant is coal fired, therefore it does not have a
fuel switch case. The McKee Run plant is dual fired (oil and gas), however
the plant is small with a correspondingly low amount of fuel use (Table C-l).
There is not a significant clean fuel savings potential afforded by these
plants.
3.2.3 .Industrial, Commercial, Institutional Source Assessment
The major fuel combustion sources in this region are listed in Table
D-l. These sources are all firing oil of a moderate sulfur content, thereby
affording little potential clean fuel savings. Point source fuel combustion
in the region contributes approximately thirty-nine percent of the particu-
late emissions and twenty-two percent of the sulfur dioxide emissions.
3.2.4 Area Source Assessment
Area source fuel use in this region is shown in Table E-l, and as in
the Metropolitan Philadelphia AQCR, these sources do not afford a significant
clean fuel savings potential. Area sources contribute approximately thirty-
eight percent of the particulate emissions and seven percent of the sulfur
dioxide emissions in the region.
3.2.5 Fuel Use Assessment
Fuel use. data by the region are presented in Appendix E.
16
-------
APPENDIX A
STATE IMPLEMENTATION PLAN BACKGROUND
-------
TABLE A-1
AIR POLLUTANT PRIORITY CLASSIFICATIONS
Air Quality
Control Region
Metropolitan Philadelphia Interstate
( New Jersey, Penn.)
Southern Delaware Intrastate
Priority Classification'
Part. S0_2
I I
III
III
1975 Population
(Millions)
6.07
0.18
Proposed ,
AQMA Designations
None
None
Criteria based on maximum measured (or estimated) pollution concentration in area:
Priority
Sulfur Dioxide
Annual arithmetic mean
24-hour maximum
Parti cul ate matter:
Annual geometric mean
24-hour maximum
I
Greater than
(yg/m3)
too
455
95
325
II
From - To
(yg/m3)
60 - 100
260 - 455
60 - 95
150 - 325
III
Less than
(yg/m3)
60
260
60
150
Federal Register, August, 1974, SMSA's showing potential for NAAQS violations due to growth.
c Delaware portion only
-------
Federal
State
TABLE A-2
AMBIENT AIR QUALITY STANDARDS
All Concentrations In yg/rrr
Total Suspended Particulates
Sulfur Oxides
Primary
Secondary
Primary
Secondary
Annual
75(G)
60(G)
70(G)
60(G)
24-Hour
260a
150a
200a
150a
1-Hour
500a
Annual
80(A)
--
70(6)
80 (A)
60(A)
24-Hour
365a
--
260b
340a
2603
3-Hour
I300a
I300a
(6) Geometric mean
(A) Arithmetic mean
Not to be exceeded more than once per year
99th percentile value, not to be exceeded
-------
TABLE A-3
AIR QUALITY STANDARDS ATTAINMENT DATES3
Air Quality Participates Sulfur Dioxide
Control Region Primary Secondary Primary Secondary
Metropolitan Phil. 1/72 1/74 1/72 1/74
Southern Delaware b b b b
a From State Implementation Plan
Air quality levels below secondary standards at time of submission of SIP
-------
TABLE A-4
AIR QUALITY STATUS, TSP
TSP Concentration(yg/m3)
2nd
Air Quality Stations Highest Reading HR^
Control Region Reporting - Annual 24-Hr 24-Hr
Metropolitan Phil.3 60d 87e 558 383
1974 Delaware Air
Quality f 13 137 415 337
Southern Delaware 3 -- 207 117
1974 Delaware Air
Qualityf 3 47 158
a 1973 Air Quality Data in National Air Data Bank, July 28, 1974
Violations based on more than one reading in excess of standard
Formula: /£nd Hl-ghest 24 Hr - 24 Hr Secondary Standard^ lnn
V 2nd Highest 24-Hr - Background / '
Background values: 37.5 pg/m3 in Metropolitan Philadelphia
Total number of stations in AQCR
e Reading recorded in Pennsylvania portion of AQCR
Data from State of Delaware Department of Natural Resources and
- # Stations Exceeding National %
Ambient Air Quality
Primary
Annual 24-Hrb Annual
1 3 2
1 1 2
0
00 0
/Annual - Annual Secondary Standar
\ Annual - Background
AQCR, 30 pg/m3 in Southern Delaware
Environmental Control, covering the
9 The particulate problem at two stations where standards are exceeded are due to localized problems.
is indicated.
Reduction not required
Standards
Secondary
% 24-Hrb %
3 13 22
15 2 15
0
0
'd) x 100
AQCR
period from February
Local control action
Reduction Standard
Requi red on Which %
to Meet Reduction
Standards0 Is Based
+67 24-Hour
g
h 24-Hour
h
1, 1974 to January 31, 1975.
rather than regional reduction
-------
TABLE A-5
AIR QUALITY STATUS,
SO? Concentration(pg/m3)
# Stations Exceeding National
Air Quality
Control Region
Metropolitan Phil.
Southern Delaware
Stations
Bubbler
11
1
#
Stations
Reporting
Con tin.
23
0
Highest
Annual
80d
--
Reading
24-Hr
41 6e
86
2nd
Highest
Reading
24-Hr
416f
18
Ambient Air Quality Stds.
Primary
Annual
0
0
24-Hrb
1
0
Secondary
3-Hr
0
0
Reduction
Required
To Meet
Standards0
+ 12
9
Standard
on Which %
Reduction
Is Based
24-Hour
24-Hour
1973 Air Quality Data in National Air Data Bank, July 28, 1974
Violations based on more than one reading in excess of standard
Formula:
(2nd Highest 24 Hr - 24 Hr Secondary Standard) ,nn
\ 2nd Highest 24-Hr . '
Reading recorded in New Jersey Protion of AQCR
e Reading recorded in Pennsylvania Portion of AQCR
Highest reading used since 2nd highest reading not available
Reduction not required
I Annual - Annual Secondary Standard]
\ Annual
x 100
-------
TABLE A-6
DELAWARE PARTICIPATE EMISSIONS SUMMARY3
Control Region
Metropolitan Phil .
Delaware
Other (Penn. , N.J. )
Total
Southern Delaware
Total
(103 tons/yr) %
31.8
1018.1
1049.9
8.8
1058.7
3
96
99.
1
100
(103 tons/yr) %
0.3
12.8
13.1
1.0
14.1
1
1
1
11
1
(103 tons/yr) %
1.6
118.8
120.4
3.4
123.8
5
12
11
39
12
Area Source Fuel Combustion
(103 tons/yr) %
9.4
186.9
196.3
3.3
199.6
30
18
19
38
19
Source: 1972 National Emissions Report, EPA, June 1974
Excludes emissions from electricity generation
-------
TABLE A-7
DELAWARE SULFUR DIOXIDE EMISSIONS SUMMARY5
Air Quality
Control Region
Metropolitan Phil
Delaware
Other (Penn., N.J.'
Total
Southern Delaware
Total
Total Emissions
Electricity Generation
Point Source Fuel Combustion
Area Source Fuel Combustion
(IP3 tons/yr)
194.1
668.8
862.9
36.6
899.5
%
22
74
96
4
100
(1Q3 tons/yr)
49.7
281.0
330.7
25.7
356.4
%
26
42
38
70
40
(1Q3 tons/yr)
9.5
131.6
141.1
8.0
149.1
%
5
' 20
16
22
17
(103 tons/yr) %
5.4
187.7
193.1
2.4
195.5
3
28
22
7
22
Source: 1972 National Emissions Report, EPA, June 1974
Excludes emissions from electricity generation
-------
TABLE A-8
DELAWARE FUEL COMBUSTION SOURCE SUMMARY
Other Fuel Combustion
Point Sources
Total Emissions
1Q3 tons/yr
% Emissions From ,
Delaware Fuel Combustion Sources
n i r I^UCM i uy
Control Region
Metropolitan Phi 1 .
Southern Delaware
Total
ruwer
Plants3
2
2
4
Part.
3
1
' 4
S02
16
6
22
Part.
1049.9
8.8
1058.7
SOp
862.9
36.6
899.5'
Part.
1
88
502
7
99
Delaware power plants only
Delaware sources which contribute 100 tons or more per year of particulate or sulfur dioxide emissions
c AQCR total
Percent of total AQCR emissions
-------
TABLE A-9
SUMMARY OF DELAWARE FUEL COMBUSTION EMISSION REGULATIONS
I. Particulate Matter
Particulate emissions are not to exceed 0.3 pounds per million
BTU h,eat input, maximum 2-hour average, from any fuel burning unit. This
regulation does not apply to units having a heat input of less than one
million BTU's.
II. Sulfur Dioxide
A. Limit on Sulfur Content of Fuel
1. No person shall offer for sale, sell or purchase
any fuel having a sulfur content greater than one
(1.0) percent by weight when such fuel is intended
for use in any fuel burning equipment in New Castle
County. No person shall use any fuel having a sul-
fur content greater than one (1.0) percent by weight
in any fuel burning equipment in New Castle County.
In Kent and Sussex counties, there is no regulatory
limit on the sulfur in fuel.
2. No person shall offer for sale, sell, purchase or
use in any fuel burning equipment, distillate fuel
oil having a sulfur content greater than 0.3 percent
by weight.
B. Emission Control in Lieu of Sulfur Content Limits of
Section A.
The limits on sulfur content established by Sec-
tion A shall not apply to any fuel burning equip-
ment employing emission control which limits sulfur
dioxide emission to that which would result from
burning, without emission control, a fuel permitted
by Section A. In order to employ an emission control
rather than sulfur content limits as a means of com-
plying with this Regulation, an owner or operator of
fuel burning equipment must demonstrate to the Depart-
ment in advance that the equivalent emission will be
achieved.
-------
APPENDIX B
REGIONAL SUMMARY
-------
TABLE B-l
REGIONAL INDICATORS FOR REVISION OF PARTICIPATE EMISSION REGULATIONS
Alr Qua1ity Particulate % Emissions
Air Quality Number of Number of Emissions From Delaware Fuel TSP Attainment AQMAs
Control Region Stations3 Violations" (103 tons/yr) Combustion Priority Datesd Proposed?
Metropolitan Phil. 60 15 31.8 1 I 1/72 Nof
Southern Delaware 3 0 8.8 88 III e No
a Total number of stations in AQCR
Number of violations of secondary standards in AQCR
Delaware emissions from all sources
As submitted in Delaware SIP (Primary Standard)
e Air quality levels below standards at time of SIP submittal
Delaware portion only
-------
TABLE B-2
REGIONAL INDICATORS FOR REVISION OF SULFUR DIOXIDE EMISSION REGULATIONS
A1r Qual1t* S0? % Emissions
Air Quality Number of Number of Emissions , From Delaware Fuel SOj Attainment AQMAs
Control Region Stations5 Violations (1Q3 tons/yr) Combustion Priority Dates0 Proposed?
Metropolitan Phil. 34 1 194.1 7 I 1/72 No6
Southern Delaware 1 '0 36.6 99 III d No
a Total number of 24-hour bubbler and continuous monitoring stations in AQCR
Delaware emissions from all sources
c As submitted in Delaware SIP (Primary Standard)
Air quality levels below standards at time of SIP submittal
e Delaware portion only
-------
APPENDIX C
POWER PLANT SUMMARY
-------
TABLE C-l
POWER PLANT FUEL USE SUMMARY3
MI i yua i i L_y
Control Region
Metropolitan Phil.
Southern Delaware
Plant
Delaware City
Edge Moor
Indian River
McKee Run
i ^ / o v^a p a {. i u_y
(MW)
120.0
789.0
340.0
33.0
Type
Fluid Coke
Oil
Gas
Oil
Gas
Coal
Oil
Gas
% S
6.7
2.29
0.5
1.62
1.05
Quantityb
I69C
1639
4116
4528
631
814
354
181
1 J / + I UC 1
% S
6.65
1.21
0.9
1.65
1.79
lo O
SIP
1.0
1.0
a Source: Air Resources Section, Delaware Department of Natural Resources and Environmental Control
Coal quantity is in 103 tons, oil is in 103 barrels, gas is in I06 cu. ft.
0 Fluid coke figures given in 103 tons
-------
TABLE C-2
SUMMARY OF POWER PLANT MODELING RESULTS3
Maximum 24-Hour Concentration
SO? Particulates Maximum Annual
Air Quality
Control Region
Metropolitan Phil .
Plant
Edge Moor
1972 Operations
Fuel Switch #lb
Fuel Switch #2C
Nominal
Load
89
404
437
Maximum
Load
108
491
491
Nominal
Load
9
193
206
Maximum
Load
9
237
237
Concentration (pg/m-3)
S02 Parti culates
__
Source: Modeling Analysis of Power Plants for Fuel Conversion (Group II) Halden Research, Sept. 4, 1974
Switch oil consumption to 2.5% coal in units 1-4
c Switch oil and natural gas consumption to 2.5% coal in units 1-4
-------
ADDENDUM TO APPENDIX C
USE AND LIMITATIONS OF MODELING ANALYSIS DATA3
1. The data inputs for the modeling have been extracted from the
appropriate FPC Form 67 and the most representative meteorological data
available. However, £o calculate the occurrence of the highest 24-hour
concentration, assumptions as to the daily emission rate are necessary.
The results of the modeling exercise provide a range of.the most probable
maximum concentration.
2. It should be recognized that time and data constraints are such
that the model predictions are useful but not omniscient. There are no
data available, in general, to "validate" the model. Therefore, all rele-
vant data, including hard data on actual daily plant operations, shouTci
be obtained, reviewed, and evaluated. In this way, the modeling results
can be used as a logical part of the entire decision-making framework, not
as an arbitrary, dogmatic absolute "answer", divorced from the real situation
involved. In some cases it will be necessary to adjust the model's predic-
tions based upon more complete and detailed information on a particular
plant's operations.
3. Results of these evaluations are not intended to be used in any
legal actions, including both public hearing and court proceedings. The
very nature of atmospheric dispersion modeling is such that results are not
suitable to legally prove (or disprove) a particular modeling result. The
assumptions and judgments necessarily involved in modeling tend to mitigate
against prpof in a legal sense.
4. The best use of the data is in negotiations with states or sources
in trying to establish a rational course of action to be followed with reason-
able assurance that the air quality impact will be as indicated by the model.
Extracted from comments by the Monitoring and Data Analysis Division, OAQPS
-------
APPENDIX D
INDUSTRIAL, COMMERCIAL, INSTITUTIONAL SOURCE SUMMARY
-------
TABLE D-l
INDUSTRIAL, COMMERCIAL, INSTITUTIONAL FUEL COMBUSTION SOURCES'
Air Quality
Control Region
Metropolitan Phil,
Fuel Use
Emissions(Tons/Year)
Source
Sunolin Chemical Co.
E.I. DuPont (Wilmington)
Amo.co Chem.
I C I America
E.I. DuPont (Experimental
Station)
National Vulcan
Phoenix Steel
Chrysler Corp.
Allied Chemical
Container Corp. of America
General Motors
E.I. DuPont (Pigments Plant)
J. Bancroft & Sons
Univ. of Delaware
E.I. DuPont (Chestnut Labs)
Hercules Inc.
Type
Oil
Gas
Oi 1
Oil
Oil
Gas
Oi 1
Oil
Oil
Oil
Oi 1
Oil
Oil
Oil
Oil
Oil
Oil
Oil
% S
1.0
1.0
1.0
.1.0
0.75
1.0
1.4
0.8
1.0
1.0
0.84
1.0
0.8
1.0
0.75
1.0
K
Amount
704.8
3356.0
380.2
315.3
176.2
236.0
180.0
109.5
68.1
119.4
86.9
79.3
92.4
85.4
94.8
59.2
62.2
38.7
Part.
340
154
153
82
87
8
33
57
42
38
44
" 39
46
26
30
17
S0£
2090
1254
1034
543
445
361
341
319
286
261
255
253
250
194
155
128
Southern Delaware
E.I. DuPont
Oil
2.1
898.6
226
6230
-------
TABLE D-l cont.
Air Quality
Control Region
Southern Delaware
(cont.)
Fuel Use
Emissions Tons/Year
Source
General Foods
Draper Canning
Dover AFB
Standard Brands
Townsend's Inc.
Type
Oil
-Oi 1
Oil
Oil
Oil
% S
2.0
2.3
0.71
2.0
1.0
Amount'3
93.1
50.1
81.2
21.2
31.0
Part.
45
24
39
7
15
S02
618
379
190
126
102
Sources which emit 100 tons or more per year of either particulates or sulfur dioxide are
listed in decreasing order of S02 emissions. Data are from National Emissions Data System.
Fuel quantity, oil is in 10^ barrels, gas is in 10^ cu. ft.
-------
APPENDIX E
AQCR FUEL USE SUMMARY
-------
TABLE E-l
FUEL USE SUMMARY5
Air Quality
Control Region
Metropolitan Phil,
Area Sources
Residential
Industrial
Comm/Inst.
Total
Point Sources
E:lec." Gen.
Industrial
Comm/Inst.
Total
GRAND TOTAL
Coal (IP3 tons)
Oil (IP3 Barrels)
Residual
Distillate
Gas (106 cu. ft.)
Natural Process
Coke
(IQ3 tons)
8
3
3
14
0
0
0
0
14
0
119
4
123
0
0
0
0
123
0
0
59
59
5,575
2,649
370
8,594
8,653
1 ,-628
106
453
2,187
28
321
3
352
2,539
9,100
4,300
'3,200
16,600
2,057
5,170
100
7,327
23,927
0
0
0
0
0
2,869
0
2,869
2,869
0
0
0
0
183
0
0
183
183
Southern Delaware
Area Sources
Residential
Industrial
Comm/Inst.
Total
Point Sources
Elec. Gen
Industrial
Comm/Inst.
Total
GRAND TOTAL
0
0
16
16
923
55
129
1,107
1,220
1,470
890
3,580
0
0
0
0
0
0
0
0
0
0
5
833
0
0
833
875
337
1,111
1 1 1
1,559
1,575
7
29
0
36
1,143
277
368
0
645
4,225
0
0
0
0
0
0
0
0
0
0
Source: Stationary Source Fuel Summary Report (NEDS) December, 1974
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-75-040
3. RECIPIENT'S ACCESSIOWNO.
4. TITLE AND SUBTITLE
5. REPORT DATE
IMPLEMENTATION PLAN REVIEW FOR DELAWARE AS
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL
COORDINATION ACT
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Research Triangle
Park, N.C., Regional Office III, Philadelphia,
Pa., and TRW, Inc., Vienna, Virginia
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Section IV of the Energy Supply and Environmental Coordination Act of 1974,
(ESECA) requires EPA to review each State Implementation Plan (SIP) to determine
if revisions can be made to control regulations for stationary fuel combustion
sources without interfering with the attainment and maintenance of the national
ambient air quality standards. This document, which is also required by Section
IV of ESECA, is EPA's report to the State indicating where regulations might be
revised.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Air pollution
State Implementation Plans
8. DISTRIBUTION STATEMENT
Release unlimited
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
40
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
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