### IDEM INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT We Protect Hoosiers and Our Environment.

Mitchell E. Daniels Jr. 100 North Senate Avenue Governor Indianapolis, Indiana 46204 (317) 232-8603 Thomas W. Easterly Toll Free (800) 451-6027 Commissioner www.idem.lN.gov

June 16, 2011 Ms. Susan Hedman Regional Administrator U.S. Environmental Protection Agency Region 5 77 West Jackson Boulevard Chicago, IL 60604-3950

Re: Request for Redesignation Petition and Maintenance Plan for the Indiana Portion (Madison Township, Jefferson County and Clark and Floyd counties) of the Louisville KY-IN Nonattainment Area for Fine Particles Dear Ms. Hedman:

The Indiana Department of Environmental Management (IDEM) submits a Redesignation Petition and Maintenance Plan for the Indiana Portion (Madison Township, Jefferson County and Clark and Floyd counties) of the Louisville KY-IN Nonattainment Area, which was designated as nonattainment of the annual standard for fine particles on April 5, 2005. IDEM conducted a public hearing concerning the Redesignation Petition and Maintenance Plan on May 26, 2011, and the public comment period concluded on May 29,2011.

During the public comment period, the Louisville Metro Air Pollution Control District and Kentucky Department of Environmental Management provided an updated emission inventory for Kentucky's portion of the nonattainment area (Bullitt and Jefferson counties). The new emission inventory numbers have been incorporated into the final Redesignation Petition and Maintenance Plan and Appendices S, C, and E.

The attached document consists of the following:

Redesignation Petition and Maintenance Plan • A formal request that the Indiana Portion (Madison Township, Jefferson County and Clark and Floyd counties) of the Louisville KY-IN Nonattainment Area for Fine Particles be redesignated to attainment and reclassified as maintenance. It contains and meets the requirements set forth in Section 107 of the Clean Air Act and in United States Environmental Protection Agency (U.S. EPA) Redesignation Guidance.

• The appendices of the document contain historical air quality trend data, projected emission inventory data, and thorough documentation of the mobile emissions analysis. •

Recycled Paper (i) An Equal O!>!>orlunity Employer Please Recycle 0Ms. Hedman Page 2 • A maintenance year of 2025 is established and 2015 and 2020 are analyzed as interim years.

• A summary of, and response to, all comments.

Motor Vehicle Emissions Budgets

• Contained in the Redesignation Petition is a new Motor Vehicle Emissions Budget for 2015 and 2025. The Kentuckiana Regional Planning and Development Agency's (KIPDA's) travel demand forecasting model and U.S. EPA's software program referred to as Motor Vehicle Emission Simulator (MOVES) were used to determine emissions for the annual fine particle nonattainment area.

• A conservative margin of safety was applied to the 2015 and 2025 projected emissions.

• The travel demand model was updated with the best available assumptions.

• Vehicle registration data gathered from the Indiana Bureau of Motor Vehicles were used to replace the MOVES default vehicle age distribution.

IDEM requests that U.S. EPA proceed with review and approval of this submittal. If you have any questions or need additional information, please contact Scott Deloney, Chief, Air Programs Branch, at (317) 233-5694.

Sincerely,

# /~ 

# 8 '--'-8"

p oj Keith Baugues Assistant Commissioner Office of Air Quality KB/sad/ghf Enclosure: Request for Redesignation Petition and Maintenance Plan Under the Annual National Ambient Air Quality Standard for Fine Particles for the Indiana Portion of the Louisville KY-IN Nonattainment Area

Cc: John Summerhays, U.S. EPA Region 5 (wI enclosures) Matt Rau, U.S. EPA Region 5 (wI enclosures) John Mooney, U.S. EPA Region 5 (no enclosures)

. Cheryl Newton, U.S. EPA Region 5 (no enclosures)

. Pat Morris, U.S. EPA Region 5 (no enclosures)

Cynthia Lee, LMAPCD (wI enclosures) John Gowins, KDEP (wI enclosures) Randy Simon, KIPDA (no enclosures) Larry D. Chaney, KIPDA (wI enclosure) Jesse Mayes, KYTC (no enclosures) Scott Deloney, IDEM (no enclosures) Christine Pedersen, IDEM (no enclosures) Gale Ferris, IDEM (wI enclosures)

# REQUEST FOR REDESIGNATION AND MAINTENANCE PLAN UNDER THE ANNUAL NATIONAL AMBIENT AIR QUALITY. STANDARD FOR FINE PARTICLES

For the Indiana Portion of the

Louisville KY-IN Nonattainment Area for Fine Particles



# Jefferson County (Madison Township), Clark and Floyd Counties, Indiana

Prepared By: The Indiana Department of Environmental Management

June 2011

### This page intentionally left blank

11iii TABLE OF CONTENTS

1.0 INTRODUCTION

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

1.1 Background ................................................................................................................ ................1 1.2 Geographical Description .................................................................................................. ........3 1.3 Status of Air Quality ..................................................................................................... .............3

2.0 REQUIREMENTS FOR REDESIGNATION

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

2.1 General ................................................................................................................... ....................3 2.2 Fine Particle Monitoring .................................................................................................. ..........4 2.3 Emission Inventory ........................................................................................................ ............4 2.4 Modeling Demonstration .................................................................................................... .......5 2.5 Controls and Regulations .................................................................................................. .........5 2.6 Corrective Actions for Potential Future Viol ations of the Fine Particle Standard ....................5

3.0 FINE PARTICLE MONITORING

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

3.1 Fine Particle Monitoring Network .......................................................................................... ...5 3.2 Ambient Fine Particle Monitoring Data ....................................................................................6 3.3 Quality Assurance ......................................................................................................... ...........11 3.4 Continued Monitoring ...................................................................................................... ........11

4.0 EMISSION INVENTORY

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

4.1 Emission Trends ........................................................................................................... ............12 4.2 Base Year Inventory ....................................................................................................... .........22 4.3 Emission Projections ...................................................................................................... ..........23 4.4 Demonstration of Maintenance .............................................................................................. ..29 4.5 Permanent and Enforceable Emission Reductions ..................................................................30 4.6 Provisions for Future Updates ............................................................................................. ....30

5.0 TRANSPORTATION CONFORMITY BUDGETS

.......................................................... 30

5.1 Onroad Emission Estimates ................................................................................................. ....30 5.2 Overview .................................................................................................................. ................31 5.3 Emission Es timations ...................................................................................................... .........31

6.0 CONTROL MEASURES AND REGULATIONS ..............................................................33

6.1 Reasonably Available Control Technology (RACT) ...............................................................33 6.2 Implementation of Past State Implementation Plan (SIP) Revisions.......................................34 6.3 Nitrogen Oxides (NO x ) Rule ....................................................................................................34iv 6.4 Measures Beyond Clean Ai r Act SIP Requirements ...............................................................35 6.5 Controls to Remain in Effect .............................................................................................. .....39 6.6 New Source Review Provisions .............................................................................................. .39

7.0 MODELING AND METEOROLOGY ................................................................................39

7.1 Summary of Modeling Results to Support Rulemakings ........................................................40 7.2 Lake Michigan Air Directors C onsortium’s (LADCO) Round 5 Speciated Modeled Attainment Test Results ............................................................................................43 7.3 LADCO Round 5 Particulate So urce Apportionment Results .................................................44 7.4 Summary of Existing Modeling Results ..................................................................................50 7.5 Meteorological Analysis for the Louisville Area .....................................................................50 7.6 Surface Air Conditions Present during High Fine Particle Concentration Days .....................50 7.7 Upper Air Conditions Present during High Fine Particle Concentration Days .......................50 7.8 Analyses of Atmospheric Conditions during High Fine Particle Concentration Days ............51 7.9 Summary of Air Quality Index (AQ I) Days in the Louisville Area ........................................51 7.10 Summary of Meteorological Anal ysis for the Louisville Area ..............................................52

8.0 CORRECTIVE ACTIONS ...................................................................................................53

8.1 Commitment to Revise Plan ................................................................................................. ...53 8.2 Commitment for Con tingency Measures .................................................................................53 8.3 Contingency Measures ...................................................................................................... .......53

9.0 PUBLIC PARTICIPATION ................................................................................................54

10.0 CONCLUSIONS ..................................................................................................................55

FIGURES

Figure 3.1 Louisville Basic Nonattainment Area ............................................................................6

TABLES

Table 1.1 National Ambient Air Quality Standards for Fine Particles (PM 2.5 ) ..............................2 Table 3.1 Monitoring Data for Indiana’ s Portion of the Louisville Area ........................................7 Table 3.2 Monitoring Data for Kentucky’ s Portion of the Louisville Area .....................................8 Table 4.1 Comparison of 2008 Estimated and 2025 Projected Emission Estimates, Clark, Floyd, and Jefferson Counties, Indiana ..............................................................29 Table 4.2 Comparison of 2008 Estimated and 2025 Projected Emission Estimates, Louisville Area .............................................................................................................. 29 Table 5.1 Emission Estimations for Onroad Mobile Sources ........................................................32 Table 5.2 Motor Vehicle Emission B udgets for the Louisville Area ............................................32 Table 6.1 Trends in Electric Generating Unit (EGU) NO x Emissions Statewide in Indiana .........35v Table 7.1 Clean Air Transport Rule Mode ling Results from U.S. EPA (Using 2003- 2007 Design Values) ...........................................................................................................40 Table 7.2 Clean Air Transport Rule Mode ling Results from U.S. EPA (Using 2006 – 2010 Design Values) ...........................................................................................................41 Table 7.3 LADCO Round 6 Mode ling Results for Annual PM 2.5 – Without Clean Air Interstate Rule Emission Reductions (Using 2003 – 2007 Design Values) ...............42 Table 7.4 LADCO Round 6 M odeling Results for Annual PM 2.5 – Without Clean Air ............43 Interstate Rule Emission Reductions (Using 2006 – 2010 Design Values) Table 7.5 LADCO Round 5 Speciated Modele d Attainment Test Modeling Results for Southern Indiana .........................................................................................................44 Table 7.6 Ranking and Percen tage of Highest Number of Days at AQI Levels of Health Concern ......................................................................................................52

GRAPHS

Graph 3.1 Fine Particle Design Values for Indiana’s Portion of the Louisville Area ...................9 Graph 3.2 Fine Particle Design Values for Ke ntucky’s Portion of the Louisville Area ...............9 Graph 3.3 Annual Fine Particle Trends for Indiana’s Portion of the Louisville Area ................10 Graph 3.4 Annual Fine Particle Trends for Ke ntucky’s Portion of the Louisville Area .............10 Graph 4.1 NO x Point Source Emissions Trend, Cl ark, Floyd, and Jefferson Counties, Indiana ..................................................................................................................... ...12 Graph 4.2 Sulfur Dioxide (SO 2 ) Point Source Emissions Trend, Clark, Floyd, and Jefferson Counties, Indiana ........................................................................................13 Graph 4.3 Direct PM 2.5 Point Source Emissions Trend, Clark, Floyd, and Jefferson Counties, Indiana ........................................................................................................13 Graph 4.4 NO x Point Source Emissions Trend, Louisville Area ................................................14 Graph 4.5 SO 2 Point Source Emissions Trend, Louisville Area .................................................14 Graph 4.6 Direct PM 2.5 Point Source Emissions Trend, Louisville Area ...................................15 Graph 4.7 NO x Emissions Trend, All Sources, Clark, Floyd, and Jefferson Counties, Indiana

............................................................................................................................ ........16 Graph 4.8 SO 2 Emissions Trend, All Sources, Clark, Floyd, and Jefferson Counties, Indiana

............................................................................................................................ ........17 Graph 4.9 Direct PM 2.5 Emissions Trend, All Sources, Clark, Floyd, and Jefferson Counties, Indiana ..................................................................................................................... ...17 Graph 4.10 NO x Emissions Trend, All S ources, Louisville Area ..................................................18 Graph 4.11 SO 2 Emissions Trend, All Sources, Louisville Area ..................................................18 Graph 4.12 Direct PM 2.5 Emissions Trend, All Sources, Louisville Area .....................................19 Graph 4.13 NO x Emissions from EGUs, Floyd, a nd Jefferson Counties, Indiana ........................20 Graph 4.14 SO 2 Emissions from EGUs, Floyd, and Jefferson Counties, Indiana .........................21 Graph 4.15 NO x Emissions from EGUs, Louisville Area .............................................................21 Graph 4.16 SO 2 Emissions from EGUs, Louisville Area ..............................................................22 Graph 4.17 Comparison of 2005, 2008, 2015, and 2025 Projected NO x Emissions, Clark, Floyd, and Jefferson Co unties, Indiana ......................................................................25 Graph 4.18 Comparison of 2005, 2008, 2015, and 2025 Projected SO 2 Emissions, Clark, Floyd, and Jefferson Co unties, Indiana ......................................................................25vi Graph 4.19 Comparison of 2005, 2008, 2015, and 2025 Projected Direct PM 2.5 Emissions, Clark, Floyd, and Jefferson Counties, Indiana ...........................................................26 Graph 4.20 Comparison of 2005, 2008, 2015, and 2025 Projected NO x , SO 2 , and Direct PM 2.5 Emissions, Clark, Floyd, and Je fferson Counties, Indiana ...............................26 Graph 4.21 Comparison of 2005, 2008, 2015, and 2025 Projected NO x Emissions, Louisville Area ...........................................................................................................27 Graph 4.22 Comparison of 2005, 2008, 2015, and 2025 Projected SO 2 Emissions, Louisville Area ...........................................................................................................27 Graph 4.23 Comparison of 2005, 2008, 2015, and 2025 Projected Direct PM 2.5 Emissions, Louisville Area ...........................................................................................................28 Graph 4.24 Comparison of 2005, 2008, 2015, and 2025 Projected NO x , SO 2 , and Direct PM 2.5 Emissions, Louisville Area ..............................................................................28 Graph 7.1 PM 2.5 Design Value Trends for the Louisville Area ..................................................41

CHARTS

Chart 7.1 Regional/Emission Sector Part iculate Source Apportionment Technology Results, Jeffersonville, Indiana – Walnut Street PM 2.5 Monitor ................................45 Chart 7.2 Modeled Contribution by Speci es at the Jeffersonville, Indiana Walnut Street PM 2.5 Monitor ......................................................................................46 Chart 7.3 Modeled Contribution by Sp ecies at the New Albany, Indiana PM 2.5 Monitor .........46 Chart 7.4 Modeled Contribution by Species at the Carpenter Street – Shepherdsville, Kentucky PM 2.5 Monitor .............................................................................................47 Chart 7.5 Modeled Contribution by Sp ecies at the Elizabethtown, Kentucky PM 2.5 Monitor .............................................................................................................47 Chart 7.6 Modeled Contribution by Species at the Southern Avenue – Louisville, Kentucky PM 2.5 Monitor ............................................................................................48 Chart 7.7 Modeled Contribution by Species at the Wyandotte Park – Louisville, Kentucky PM 2.5 Monitor .............................................................................................................48 Chart 7.8 Modeled Contribution by Species at the Barret Avenue – Louisville, Kentucky PM 2.5 Monitor .............................................................................................................49 Chart 7.9 Modeled Contribution by Species at the Watson Elementary – Louisville, Kentucky PM 2.5 Monitor .............................................................................................49 Chart 7.10 Distribution of PM 2.5 Concentration Days on the AQI Levels of Health Concern for the Louisville Area ...............................................................................................51vii APPENDICES

A Air Quality System (AQS) and Indi ana Department of Environmental Management (IDEM) Fine Particle Mon itor Data Values for the Louisville Area (2000 – 2010) B NO x , SO 2 , and Direct PM 2.5 Point Source Emissions (2005 and 2008), Louisville Area C NO x , SO 2 , and Direct PM 2.5 Emissions, All Sources (2005 and 2008), Louisville Area D NO x and SO 2 Emission Trends from EGUs, Louisville Area (1999 to 2009) E 2005 and 2008 Base Year Emission Inventor ies and 2015 and 2025 Projected Emission Inventories for NO x , SO 2 , and Direct PM 2.5 , Louisville Area F Example Mobile Source Input and Output Calculation Files for the Louisville Area G IDEM - Area Source Inventory Standard Operating Procedure H LADCO Emission Estimates Technical Support Document I LADCO Round 5 Modeling Technical S upport Document (Round 5 Photochemical Modeling Based on “Base M” Emission Inve ntory, revised version of “Base K”) J Modeling Summary K Public Participation Process Documentsviii 

### This page intentionally left blank1 REQUEST FOR REDESIGNATION AND MAINTENANCE PLAN UNDER THE ANNUAL NATI ONAL AMBIENT AIR QUALITY STANDARD FOR FINE PARTICLES

LOUISVILLE KY-IN AREA

1.0 INTRODUCTION

This document supports Indiana’s request that Jefferson County (Madison Township) and Clark and Floyd counties, Indiana, which are part of the Louisville KY-IN nona ttainment area for fine particles (herein referred to as the “Louisville Area”), be redesignated from nonattainment to attainment of the 1997 annual standard for fine part icles. All monitors fo r fine particles in the Louisville Area have recorded three years of qua lity assured ambient air quality monitoring data for the years 2008 through 2010, demonstrating atta inment with the annual standard for fine particles; therefore, Indiana’ s portion of the Louisville Area is eligible for redesignation.

Section 107 of the Clean Air Act (CAA) establishe s specific requirements to be met in order for an area to be considered fo r redesignation, including:

(a) A determination that the area has attained the annual standard for fine particles. (b) A State Implementation Plan (SIP) for the area under Section 110(k) that is fully approved. (c) A determination that the improvement in air quality is due to permanent and enforceable reductions in emissions resul ting from implementation of the SIP and other federal requirements. (d) A maintenance plan under Secti on 175A that is fully approved. (e) A determination that all Section 110 and Part D requirements have been met.

A maintenance plan provides for the continued atta inment of the air quality standard by an area for a period of ten years after the United Stat es Environmental Protection Agency (U.S. EPA) has formally redesignated the area to attainment. The plan also pr ovides assurances that even if there is a subsequent exceedance of the air quality standard, then measures in the maintenance plan will prevent any future occurrences through contingency measures that would be triggered.

This document addresses each of these requireme nts, and provides additional information to support continued compliance with the a nnual standard for fine particles.

1.1 Background

The CAA requires states with areas designate d nonattainment of th e applicable National Ambient Air Quality Standard (NAAQS) for fine particles to develop SI Ps to expeditiously attain and maintain the standar d. In 1997, U.S. EPA set daily and annual air quality standards for fine particles (PM 2.5 ), as shown in Table 1.1. The terms “fine particles” and “PM 2.5 ” are used synonymously throughout this document. The PM 2.5 standards were legally challenged and upheld by the U.S. Supreme Court in February of 2001. In 1999, the Indiana Department of2 Environmental Management (IDEM) began monitori ng for fine particle concentrations. U.S. EPA designated areas in Indiana under the annual standard for fine particles on December 17, 2004, as attainment, nonattainment or unclassifiabl e, with an effective date of April 5, 2005.

Table 1.1 National Ambient Air Quality Standards for Fine Particles

Annual 24-Hour

1997 PM 2.5 Standards 15 μg/m 3 * Annual arithmetic mean, averaged over three years 65 μg/m 3 24-hour average, 98 th percentile, averaged over three years

2006 PM 2.5 Standards 15 μg/m 3 Annual arithmetic mean, averaged over three years 35 μg/m 3 24-hour average, 98 th percentile, averaged over three years * micrograms per cubic meter (μg/m 3 )

Note: The Louisville Area meets the 1997 and 2006 24-hour NAAQS for fine particles. Since this area is solely designated nonattainment under the 1997 annual standard for fine particles, this document only addresses the annual standard.

On December 17, 2004, based on 2001 through 2003 monitoring data, U.S. EPA designated the Louisville Area as nonattainment of the annual st andard for fine particles (40 CFR 81.315). The Louisville Area is subject to Section 172 of th e CAA, including the development of a plan to reduce nitrogen oxides (NO x ), sulfur dioxide (SO 2 ), and direct PM 2.5 emissions and a demonstration that the area will meet the annual standard for fi ne particles by April 5, 2010. In order to satisfy these requirements, Indiana subm itted an attainment demo nstration to U.S. EPA on April 3, 2008, demonstrating th at with the combination of clean air measures and the implementation of local and federally required c ontrol measures, air quality in the nonattainment area would meet the annual NAAQS for fine partic les by April 5, 2010, with an ample margin of safety. The Louisville Area monitors have continued to meet the annual NAAQS for fine particles since the end of 2008.

There were no fine particle monitors in th e Louisville Area that violated the 1997 24-hour standard for fine particles and none that curr ently violate the 2006 24-hour standard for fine particles. As a result, the Louisville Area was designated nonattainment for fine particles solely under the 1997 annual standard. Therefore, this document pertains only to the 1997 annual standard for fine particles.

The Louisville nonattainment area fo r fine particles, as defined in Section 1.2, has not previously been subject to nonattainment area rulemakings fo r fine particles. However, Clark and Floyd counties, Indiana and Bullitt, Oldham, and Jeffers on counties, Kentucky, ha ve been subject to nonattainment area rulemakings under the 1-hour ozone standard. The 1-hour ozone standard was revoked on June 15, 2005. These counties ha ve also been subject to nonattainment rulemakings under the 8-hour ozone standard. Cl ark and Floyd counties were redesignated to attainment and classified as maintenance under the 8-hour ozone st andard on July 19, 2007. Bullitt, Oldham, and Jefferson counties were rede signated to attainment and classified as maintenance on August 6, 2007.3 1.2 Geographical Description

The Louisville nonattainment area for fine pa rticles consists of Jefferson County (Madison Township) and Clark and Floyd counties, Indiana, and Bullitt and Jeffe rson counties, Kentucky. The Louisville Area contains such cities as Clarksville, New Albany, and Madison in Indiana and Louisville in Kentucky. This area is depicted in Figure 3.1.

The agencies responsible for assuring the nonattain ment area for fine particles complies with the CAA requirements are:



### • IDEM, which is responsible for Jefferson County (Madison Township) and Clark and Floyd counties, Indiana.



### • The Louisville Metro Air Pollution Control District (LMAPCD), which is responsible for Jefferson County, Kentucky.



### • The Kentucky Department for Environmental Protection (KDEP), which is responsible for Bullitt County, Kentucky. The KDEP is requesting redesignation of Kentucky’s portion of the nonattainment area.

These three agencies have worked cooperatively with U.S. EPA Regions IV and V to address attainment planning issues.

Although the agencies have worked toge ther on a comprehensive plan for the multi-state nonattainment area, the State of Kentucky is requir ed to make a separate submittal for its portion of the planning components to U.S. EPA. This submittal only covers Jefferson County (Madison Township) and Clark and Floyd counties, Indiana.

1.3 Status of Air Quality

Monitoring data for fine particles for the th ree years, 2008 through 2010, demonstrates that air quality has met the annual NAAQS for fine partic les in the Louisville Area. This fact, accompanied by the permanent and enforceable reductions in emission levels discussed in Section 4.0, justifies a redesignati on to attainment for the area based on Section 107(d)(3)(E) of the CAA.

2.0 REQUIREMENTS FOR REDESIGNATION

2.1 General

Section 110 and Part D of the CAA list a num ber of requirements that must be met by nonattainment areas prior to consideration for rede signation to attainment. In addition, U.S. EPA has published detailed guidance in a document en titled “Procedures for Processing Requests to Redesignate Areas to Attainment”, issued Sept ember 4, 1992, to Regional Air Directors. This document is hereafter referred to as “Redesigna tion Guidance”. This Request for Redesignation and Maintenance Plan is based on the Redesi gnation Guidance, supplemented with additional4 guidance received from staff of the Attainment Planning and Maintenanc e Section of U.S. EPA Region V. The specific requirements for redesignation are listed below.

2.2 Fine Particle Monitoring

1) A demonstration that the annual standard for fine particles, as published in 40 Code of Federal Regulations (CFR) 50.13, has been attained. Fine particle monitoring data must show that violati ons of the annual ambient standard are no longer occurring.

2) Ambient monitoring data quality-assured in accordance with 40 CFR 58.15, recorded in the U.S. EPA Air Quality Sy stem (AQS) database, and available for public view.

3) A showing that the three-year average of annual values, based on data from all monitoring sites in the area or its aff ected downwind environs, do not exceed 15.0 μg/m 3 . This showing must rely on three complete, consecutive calendar years of quality assured data.

4) A commitment that, once redesignated, the state will continue to operate an appropriate monitoring network to verify the area is in compliance (maintenance) with the standard.

2.3 Emission Inventory

1) A comprehensive emission inventory of the precursors of fine particles (direct PM 2.5 , NO x , and SO 2 ) completed for the base ye ar (2008, in this case).

2) A projection of the emission inventory to a year at least ten years following redesignation.

3) A demonstration that the pr ojected level of emissions is sufficient to maintain the annual standard for fine particles.

4) A demonstration that improvement in air quality between th e year violations occurred and the year attainment wa s achieved is based on permanent and enforceable emission reductions a nd not on temporary adverse economic conditions or unusually favorable meteorology.

5) Provisions for future updates of the i nventory to enable tr acking of the emission levels, including emission inventory statements from emission sources.5 2.4 Modeling Demonstration

While no modeling is required for redesignating nonattainment areas, IDEM has evaluated the results of federal control-case modeling to demons trate that compliance with the standard will be maintained.

2.5 Controls and Regulations

1) A U.S. EPA-approved SIP control stra tegy that includes Reasonably Available Control Technology (RACT) requirements fo r existing stationary sources covered by Control Technology Guidelines (CTG ) and non-CTG RACT for all major

sources.

2) Evidence that control measures required in past SIP revisi ons have been fully implemented.

3) Acceptable provisions to pr ovide for new source review.

4) Assurances that existing controls will remain in effect after redesignation, unless the state demonstrates through photochemical modeling that the standard can be maintained without one or more controls.

5) If appropriate, a commitment to adopt a requirement that all transportation plans conform with, and are cons istent with, the SIP.

2.6 Corrective Actions for Potential Future Vi olations of the Fine Particle Standard

1) A commitment to submit a revised plan eight years af ter redesignation.

2) A commitment to expeditiously enact and implement additional contingency control measures in response to excee ding specified predetermined levels (triggers) or in the event that future vi olations of the ambient standard occur.

3) A list of potential contingency measures that would be implemented in such an
event.

4) A list of NO x , SO 2 , and direct PM 2.5 sources potentially subject to future controls.

3.0 FINE PARTICLE MONITORING

3.1 Fine Particle Monitoring Network

There are currently eight Federal Reference Method monitors measuring fine particle concentrations in this nonattainme nt area. Three monitors are locat ed in Indiana’s portion of the nonattainment area and are opera ted by IDEM’s Office of Air Qu ality (OAQ). Five monitors6 located in Kentucky’s portion of the nonattain ment area are operated by the LMAPCD. The monitor readings from 2008 through 2010 are show n in Tables 3.1, 3.2, and Appendix A and were retrieved from U.S. EPA’s AQS database. The locations of the monitoring sites for this nonattainment area are shown in Figure 3.1. The Barret Avenue monitor (21-111-0048) located in Jefferson County, Kentucky was discontinued on December 31, 2008.

Figure 3.1 Louisville Basic Nonattainment Area

3.2 Ambient Fine Particle Monitoring Data

The following information summarizes U.S. EPA's "Guideline on Data Handling Conventions for the PM NAAQS," U.S. EPA-454/R-99-008, Ap ril 1999. Three complete years of fine particle monitoring data are required to demonstr ate attainment at a monitoring site. The annual ambient air quality standard for fine particles is met at an ambient air quality monitoring site7 when the three-year average of the annual average of fine particle concentr ations is less than or equal to 15.0 μg/m 3 . When this occurs, the site is said to be in attainment. While calculating design values, three significant di gits must be carried in the co mputations, with final values rounded to the nearest 0.1 μg/m 3 . Decimals of 0.05 or greate r are rounded up, and those less than 0.05 are rounded down, so that 15.049 μg/m 3 is the largest concentration that is less than or equal to 15.0 μg/m 3 . Values at or below 15.0 μg/m 3 meet the standard. Values equal to or greater than 15.1 μg/m 3 exceed the standard.

Data handling procedures are applied on an indi vidual basis at each monitor in the area. An individual site’s three-year av erage of the annual average fine particle concentr ation is also called the site’s design value . An area is in compliance w ith the annual NAAQS for fine particles only if all monitoring sites meet the NAAQS. The air quality design value for the area is the highest design value among all sites in the area. Table 3.1 outlines the annual fine particle values by site and the 2008 through 2010 design va lues for the three ac tive fine particle monitoring sites in Indiana’s por tion of the Louisville Area. Ta ble 3.2 outlines the annual fine particle values by site and the 2008 through 2010 design values for the six fine particle monitoring sites (five active and one recently discontinued) in Kentucky’s portion of the Louisville Area. Appendix A contains the co mplete monitoring data summary from 2000 to 2010 for all of the Louisville Area monitors.

Table 3.1 Monitoring Data for Indiana’s Portion of the Louisville Area (Annual Average and 2008 through 2010 Design Values)

SITE ID COUNTY SITE NAME YEAR Annual Average (μg/m 3 ) 2008-2010 Design Value (μg/m 3 )

18-019-0006 Clark Jeffersonville – Walnut Street 2008 14.48 14.1 2009 13.01 2010 14.67

18-019-0008 Clark Charlestown State Park 2008 13.44 12.2 2009 10.84 2010 12.45

18-089-2004 Floyd New Albany 2008 12.70 12.8 2009 11.91 2010 13.80

Red Text Indicates Incomplete Data

The Charlestown State Park monitor began operation on July 2, 2008.8 Table 3.2 Monitoring Data for Kentucky’s Portion of the Louisville Area (Annual Average and 2008 through 2010 Design Values)

SITE ID COUNTY SITE NAME YEAR Annual Average (μg/m 3 ) 2008-2010 Design Value (μg/m 3 )

21-029-0006 Bullitt Shepherdsville 2008 12.84 12.70 2009 11.81 2010 13.45

21-111-0043 Jefferson Southern Avenue 2008 13.17 12.95 2009 12.21 2010 13.47

21-111-0044 Jefferson Wyandotte Park 2008 13.41 13.20 2009 12.45 2010 13.74

21-111-0048 Jefferson Barret Avenue 2008 13.44 13.44 2009 N/A 2010 N/A

21-111-0051 Jefferson Watson Elementary 2008 12.78 13.07 2009 11.59 2010 14.83

21-111-0067 Jefferson Cannons Lane 2008 N/A 12.47 2009 11.67 2010 13.27

Blue Text Indicates Design Value Based on One Year of Data

Green Text Indicates Design Value Based on Two Years of Data

The Barrett Avenue monitor discontinued operation on December 31, 2008.

The Cannons Lane monitor began operation on January 1, 2009.

Graph 3.1 visually demonstrates the 2006 through 2010 design values for Indiana’s portion of the Louisville Area. Graph 3.2 visually demons trates the 2006 through 2010 design values for Kentucky’s portion of the Louisville Area.9 Graph 3.1 Fine Particle Design Values for Indiana’s Portion of the Louisville Area, 2006 through 2010

Red line represents the annual standard for fine particles of 15 μg/m 3

. The Charlestown State Park monitor began operation on July 2, 2008.

Graph 3.2 Fine Particle Design Values for Kent ucky’s Portion of the Louisville Area, 2006 through 2010

Red line represents the annual standard for fine particles of 15 μg/m 3

. The Barrett Avenue monitor discontinued operation on December 31, 2008.

The Cannons Lane monitor began operation on January 1, 2009. 6.0 8.0 10.0 12.0 14.0 16.0

2006

‐ 2008 2007

‐ 2009 2008

‐ 2010ug/m3

Jeffersonville ‐ Walnut Street Charlestown State Park New Albany

6.0 8.0 10.0 12.0 14.0 16.0 18.0

Shepherdsville Southern
Avenue Wyandotte Park Barret Avenue Watson Elementary Cannons Lane

21

‐ 029

‐ 0006 21

‐ 111

‐ 0043 21

‐ 111

‐ 0044 21

‐ 111

‐ 0048 21

‐ 111

‐ 0051 21

‐ 111

‐ 0067ug/m3

2006

‐ 2008 2007

‐ 2009 2008

‐ 201010 The design values for Clark and Floyd counties, I ndiana, along with the nonattainment area in its entirety, demonstrate that the annual NAAQS for fine particles has been attained.

Graph 3.3 Annual Fine Particle Trends for Indi ana’s Portion of the Louisville Area, 2006 through 2010

Red line represents the annual standard for fine particles of 15 μg/m 3

. The Charlestown State Park monitor began operation on July 2, 2008.

Graph 3.4 Annual Fine Particle Trends for Kentuc ky’s Portion of the Louisville Area, 2006 through 2010

Red line represents the annual standard for fine particles of 15 μg/m 3

. The Barrett Avenue monitor discontinued operation on December 31, 2008.

The Cannons Lane monitor began operation on January 1, 2009. 8.0 10.0 12.0 14.0 16.0 18.0

2006 2007 2008 2009 2010ug/m3

Jeffersonville ‐ Walnut Street Charlestown State Park New Albany Year

8.0 10.0 12.0 14.0 16.0 18.0

2006 2007 2008 2009 2010ug/m3

Shepherdsville Southern Avenue Wyandotte Park
Barret Avenue Watson Elementary Cannons Lane Year11 Graphs 3.1 and 3.2 show the trends in design va lues, while Graphs 3.3 and 3.4 show the trends for annual fine particles. The area's design values have recently trended downward, as emissions have declined both regionally and locally due to programs such as the Acid Rain program and cleaner automobiles and fuels. U.S. EPA’s rule to control nitrogen oxides from specific source categories (40 CFR Parts 51, 72, 75, and 96, publishe d on October 17, 1998, and referred to as the “NO x SIP Call”) has signifi cantly reduced emissions from la rge electric generating units (EGUs), industrial boilers, and cement kilns. Indiana's NO x SIP Call Rule was adopted into the Indiana Administrative Code (IAC) on June 6, 2001 at 326 IAC 10-3 and 326 ICA 10-4. The elevated fine particle values for 2005 are consid ered an abnormal occurrence. An analysis of meteorological conditions and monitoring values is included in Section 7.0 and supports the conclusion that attainment of the standard as of 2010 is not the result of unusually favorable meteorological conditions. It is expected that this downward trend will persist as the above programs continue and U.S. EPA’s proposed Cl ean Air Transport Rule (Transport Rule) is implemented.

3.3 Quality Assurance

Indiana and Kentucky have quality assured all data shown in Appendix A in accordance with 40 CFR 58.10 and recorded the data in the AQS database and, thus, the data is available to the public.

3.4 Continued Monitoring

Indiana and Kentucky commit to c ontinue monitoring fine particle concentrations at the active sites indicated in Tables 3.1 and 3.2, and Appe ndix A. IDEM will consult with U.S. EPA Region V staff prior to making changes to the existing Indiana monitoring network through the annual network review should changes become nece ssary in the future. IDEM will continue to quality assure the Indiana monitoring data to meet the requirements of 40 CFR 58. IDEM will enter all data into AQS on a timely basi s in accordance with federal guidelines.

4.0 EMISSION INVENTORY

U.S. EPA’s Redesignation Guidance and Impl ementation Rule requires the submittal of a comprehensive inventory of precursor emissions for fine particles (NO x , SO 2 , and direct PM 2.5 ) representative of the year wh en the area achieved attainment of the annual NAAQS for fine particles (base year). IDEM is using 2008 as the base year. Consis tent with the federal implementation rule for fine particles, IDEM and U.S. EPA do not consider volatile organic compounds (VOCs) or ammonia (NH 3 ) to be significant contributor s to fine particles. IDEM must also demonstrate that the improvement in air quality between the year that violations occurred and the year that attainment was achieved is based on permanent and enforceable emission reductions. Other requirements relate d to the emission inventory include: a projection of the emission inventory to a ye ar at least ten years following redesignation; a demonstration that the projected level of emi ssions is sufficient to maintain the annual standard for fine12 particles; and a commitment to provide future updates of the inventory to enable tracking of emission levels during the ten year maintenance period. The following subsections address each of these requirements.

4.1 Emission Trends

Point Sources

The point source data are obtained from Indian a's emissions reporting program and are based on county point source totals. Clark, Floyd, and Je fferson counties, Indiana, had a 7.43% reduction in NO x point source emissions, a 19.07% reduction in SO 2 point source emissions, and a 11.09% reduction in direct PM 2.5 point source emissions from 2005 to 2008. Graphs 4.1, 4.2, and 4.3 demonstrate the trends in point source emissions of NO x , SO 2 , and direct PM 2.5 for these counties.

The Louisville Area had a slight increase of 1.62% NO x point source emissions, a 16.50% reduction in SO 2 point source emissions, and a 9.07% reduction in direct PM 2.5 point source emissions from 2005 to 2008. Point source data for the Louisville Area is a combination of data from Indiana’s and Kentucky’s emissions repor ting programs. Graphs 4.4, 4.5, and 4.6 show the trends in point source emissions of total NO x , SO 2 , and direct PM 2.5 emissions for the Louisville Area. Graphs and data tables of emissions for the point source category can be found in Appendix B.

Graph 4.1 NO x Point Source Emissions Trend, Clark, Floyd, and Jefferson Counties, Indiana, 2005 and 2008

0 5,000 10,000 15,000 20,000 25,000 30,000 35,000 40,000

2005 2008TonsperYear

Nitrogen Oxides Year13 Graph 4.2 SO 2 Point Source Emissions Trend, Clark, Floyd, and Jefferson Counties, Indiana, 2005 and 2008

Graph 4.3 Direct PM 2.5 Point Source Emissions Trend, Clark, Floyd, and Jefferson Counties, Indiana, 2005 and 2008

0 200 400 600 800 1,000 1,200 1,400

2005 2008TonsperYear

Fine Particles Year 0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000

2005 2008TonsperYear

Sulfur Dioxide Year14 Graph 4.4 NO x Point Source Emissions Tren d, Louisville Area, 2005 and 2008

Graph 4.5 SO 2 Point Source Emissions Tre nd, Louisville Area, 2005 and 2008 0 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000

2005 2008TonsperYear

Nitrogen Oxides Year

0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000 180,000 200,000

2005 2008TonsperYear

Sulfur Dioxide Year15 Graph 4.6 Direct PM 2.5 Point Source Emissions Trend, Louisville Area, 2005 and 2008

All Anthropogenic Sources

Periodic inventories, which include emissions fr om all sectors (mobile, area, nonroad, and point source), were prepared for 2005 and 2008. The 2008 data were extrapolated from the 2005 emission inventory. Regional NO x emission reductions affect fi ne particle levels in the Louisville Area far more so than NO x emission reductions within th e nonattainment area itself. These emission trends roughly follow the years of monitored trends discussed in Section 3.0. There is a downward trend in NO x and SO 2 emissions from 2005 to 2008 in Clark, Floyd and Jefferson counties, Indiana, as well as th e Louisville Area. The decrease in NO x can be largely attributed to the impact of the NO x SIP Call. Graphs and data tables of emissions from each source category are available in Appendix C.

Mobile emission inventories and pr ojections for all counties in the Louisville Area were prepared by the Kentuckiana Regional Planning and Devel opment Agency (KIPDA), Indiana Department of Transportation (INDOT), and ID EM and are explained in furthe r detail in Sect ion 5.0. All 2005 data for Clark, Floyd, and Jefferson counties, Indiana are from the 2005 periodic inventory which has been identified as one of the preferred databases for SIP development. All 2008 emissions were extrapolated from the 2005 Lake Michigan Air Di rectors Consortium’s (LADCO’s) modeling inventory, using LADCO’s gr owth factors, for al l sectors except point sources (electrical generating units and non-electrical generating un its). Point source emissions for 2008 were compiled from Indiana’s annual emission inventory database. 0 1,000 2,000 3,000 4,000 5,000 6,000

2005 2008TonsperYear

Fine Particles Year16 Graphs 4.7, 4.8, and 4.9 show the trends in an thropogenic emissions for Clark, Floyd, and Jefferson counties, Indiana. Graphs 4.10, 4.11, and 4.12 show th e trends in anthropogenic emissions for the Louisville Area. The em ission inventory development and emissions projection discussion below, with the excep tion of the mobile emission inventory and projections, identify procedures used by ID EM and LADCO regarding emissions for the Louisville Area.

Graph 4.7 NO x Emissions Trend, All Sources, Clark, Floyd, and Jefferson Counties, Indiana, 2005 and 2008

0 5,000 10,000 15,000 20,000 25,000 30,000 35,000 40,000 45,000 50,000

2005 2008TonsperYear

Nitrogen Oxides Year17 Graph 4.8 SO 2 Emissions Trend, All Sources, Clark, Floyd, and Jefferson Counties, Indiana, 2005 and 2008

Graph 4.9 Direct PM 2.5 Emissions Trend, All Sources, Clark, Floyd, and Jefferson Counties, Indiana, 2005 and 2008 0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000

2005 2008TonsperYear

Sulfur Dioxide Year

0 500 1,000 1,500 2,000

2005 2008TonsperYear

Fine Particles Year18 Graph 4.10 NO x Emissions Trend, All Sources, Louisville Area, 2005 and 2008

Graph 4.11 SO 2 Emissions Trend, All Sources , Louisville Area, 2005 and 2008 0 20,000 40,000 60,000 80,000 100,000 120,000

2005 2008TonsperYear

Nitrogen Oxides Year

0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000 180,000 200,000

2005 2008TonsperYear

Sulfur Dioxide Year19 Graph 4.12 Direct PM 2.5 Emissions Trend, All Sources, Louisville Area, 2005 and 2008

EGU Sources

Both NO x and SO 2 emissions have decreased substantiall y in the Louisville Area in response to national programs affecting all EGUs, such as the Acid Rain program and the NO x SIP Call. Other sectors of the inventory also impact the fo rmation of fine particles, but large regional sources, such as EGUs, have a substantial impact on the formation of fine particles. The data was taken from U.S. EPA's Cl ean Air Markets database. 1

As part of the NO x SIP Call, the states were required to adopt into their rules a budget for all large EGUs. Indiana’s budget is referenced in 326 IAC 10-4. The budget represents a statewide cap on NO x emissions. Although each unit is allocated emissions based upon hi storic heat input, utilities can meet this budget by over-controlling certain units or purchasing credits from the market to account for overages at other units. To summarize, NO x emissions have dramatically decreased over the years represented on these graphs.

These emissions, capped by the state rule, are exp ected to remain near these levels throughout the maintenance period covered by this request. The state cap for the NOx SIP Call remained in place through 2008, at which time the Clean Air Inte rstate Rule (CAIR) program superseded it. CAIR, issued in March 2005, adopted by the Indi ana Air Pollution Control Board on November 1, 2006, and implemented beginning in 2010, will continue to reduce regional EGU NO x emissions statewide by approximately another 17% by 2015 and 57% for EGU SO 2 emissions by

1 http://www.epa.gov/airmarkets 0 1,000 2,000 3,000 4,000 5,000 6,000 7,000 8,000 9,000 10,000

2005 2008TonsperYear

Fine Particles Year20 2015. The D.C. Circuit court’s vacatur of CAIR in July of 2008 and subsequent remand without vacatur of CAIR in December 2008, directs U.S. EPA to revise the CAIR rule in the future. The proposed Clean Air Transport Rule (CAIR’s replacem ent rule) will result in similar or greater emission reductions than assumed within the current emission i nventories once it is implemented.

There are two EGUs located in Indiana’s porti on of the nonattainment area: The Duke Energy Indiana – Gallagher Generating Station in Fl oyd County, Indiana and the Indiana Kentucky Electric Corporation (IKEC) – Clifty Creek Power Plant in Jefferson County, Indiana. As the result of a recent settlement with U.S. EPA to resolve violations of the CAA’s new source review requirements, the Duke Energy Indiana – Galla gher Generating Station will be shutting down two of its four coal-fired E GUs (Units 1 and 3) by no later than February 1, 2012. The settlement also establishes overall NO x and SO 2 caps. The remaining units (Units 2 and 4) have recently installed dry sorbent control technology to reduce SO 2 . Graphs 4.13 and 4.14 depict the trends in NO x and SO 2 EGU emissions in Floyd and Jefferson counties, Indiana for the years 1999 through 2009. Graphs 4.15 and 4.16 depict the trends in NO x and SO 2 emissions from EGUs in the Louisville Area for the years 1999 through 2009. Graphs and data tables of emissions from the EGU source ca tegory can be found in Appendix D.

Graph 4.13 NO x Emissions from EGUs, Floyd and Jefferson Counties, Indiana, 1999 to 2009

0 5,000 10,000 15,000 20,000 25,000 30,000 35,000 40,000 45,000

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009TonsperYear

Nitrogen Oxides Year21 Graph 4.14 SO 2 Emissions from EGUs, Floyd, and Jefferson Counties, Indiana, 1999 to 2009

Graph 4.15 NO x Emissions from EGUs, Louisville Area, 1999 to 2009

0 20,000 40,000 60,000 80,000 100,000 120,000 140,000

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009TonsperYear

Sulfur Dioxide Year

0 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009TonsperYear

Nitrogen Oxides Year22 Graph 4.16 SO 2 Emissions from EGUs, Louisville Area, 1999 to 2009

4.2 Base Year Inventory

IDEM prepared a comprehensive inventory for the Louisville Area, including area, mobile, nonroad, and point sources for direct PM 2.5 , NO x , and SO 2 for 2005 and 2008 (the years with the most complete emission inventory availabl e at this time). The 2008 emission inventory represents a base year for maintenance purpos es. The 2007 implementation rule for the annual standard for fine part icles states that NO x , SO 2 , and direct PM 2.5 are the regulated precursors for fine particles. Ammonia and VOC s are not required to be addre ssed unless the state or U.S. EPA make a technical demonstration that emissions of these pollutants from sources in the state significantly contribute to PM 2.5 concentrations in a given nonattainment area. U.S. EPA and IDEM have not determined that ammonia or VOCs are significant contributors to fine particles formation in Indiana. IDEM’s 2008 base ye ar inventory was deve loped as follows:

 Area sources were extrapolated from the Indiana 2005 periodic inventory submitted to U.S. EPA.

 Mobile source emissions were calculated from U.S. EPA’s Motor Vehicle Emission Simulator (MOVES) model-produced emission factors and data ex tracted from the region’s travel-demand model. These emissions were then interpolated as needed to determine 2008 base year values.

 Point source information was compiled from IDEM’s emission inventory database and U.S. EPA's Clean Air Mark ets acid rain database.

 Biogenic emissions are not specifically incl uded in these summaries, but are included in the photochemical modeling result s presented in Section 7.0. 0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000 180,000 200,000

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009TonsperYear

Sulfur Dioxide Year23  Nonroad emissions were extrapolated fr om the 2005 National Emissions Inventory (NEI). To address concerns about the accuracy of some of the categories in U.S. EPA’s nonroad emissions model, LADCO contracted with two companies to review the base data and make recommendations. One of th e contractors also estimated emissions for two nonroad categories not included in U.S. EPA's nonroad model. Emissions were estimated for commercial marine vessels a nd railroads. The recreational motorboat population and spatial surrogates (used to assign emissions to each) were also significantly updated. The populations for the construction equipment category were also reviewed and updated based upon surveys comp leted in the Midwest. The temporal allocation for agricultural sources was al so updated. A new nonroad estimation model was provided by U.S. EPA for the 2005 analysis.

● Area, nonroad, mobile, and point source em issions data referenced for Kentucky’s portion of the Louisville Area were provi ded by LAMPCD, KDEP, and KIPDA. This inventory was prepared us ing similar methodologies.

Appendix C contains data tables and graphs of these emissions.

4.3 Emission Projections

In consultation with U.S. EPA and other stakeholders, IDEM se lected the year 2025 as the maintenance year for this redesignation request . This document contai ns projected emission inventories for 2015 and 2025. These emission projections we re prepared by IDEM, with assistance from LADCO, LA MPCD, KDEP, and KIPDA.

The detailed 2015 and 2025 emission inventory for the Louisville Area can be found in Appendix E. Emission trends are an important gauge for continued comp liance with the annual standard for fine particles. Therefore, IDEM performed an initial comparison of the inventories for the base year of 2008, interim year of 2015, and maintenance year of 2025 for Clark, Floyd, and Jefferson counties, Indiana, as we ll as the entire Louisville Area.

The 2005 LADCO modeling inventory was used as the basis for estimated emissions for the years 2008, 2015, and 2025, using LADCO’s growth factor s, for all sectors except point sources (electric generating units and non- electric generating units). Point source emissions for 2005 and 2008 were compiled from Indiana’s annual emissi on inventory database. The 2015 interim year emissions were interpolated based on th e 2009 and 2018 LADCO modeling inventory, using LADCO’s growth factors, for all sectors. The 2025 maintenance year emissions were extrapolated from the 2018 LADCO modeling inventory.

The projected emission inventories for 2015 and 2025 for Kentucky’s portion of the Louisville Area were provided by LAMP CD, KDEP, and KIPDA.

Graphs 4.17, 4.18, 4.19, and 4.20 visually compare 2005 and 2008 (base year) NO x , SO 2 , and direct PM 2.5 total estimated emissions with the 2015 a nd 2025 projected emissions for Clark, Floyd, and Jefferson counties, Indiana. Gra phs 4.21, 4.22, 4.23, and 4.24 visually compare the 2005 and 2008 (base year) NO x , SO 2 , and direct PM 2.5 total estimated emi ssions with the 2015 and 2025 projected emissions for the Louisville Ar ea. Mobile source emission inventories are24 further described in Section 5.0. In addition to LADCO’s estimates, point source emissions were projected based upon the statewide EGU NO x budgets from Indiana’s NO x rule. NO x and SO 2 EGU emission estimates for 2015 and 2025 for the IKEC – Clifty Creek Power Plant were projected using the budgets from the proposed Cl ean Air Transport Rule and Options 1 and 2 from the recent Notice of Data Availability. Since it is likely that the finalized rule will include a budget approximating one of these, IDEM used the option with the highest allotment to develop conservative projections. Furthe r, the Duke Energy Indiana/U.S. EPA consent decree provides overall NO x and SO 2 caps for the Duke Energy – Gallagher Generating Station in Floyd County, Indiana. The emissions allowed under these caps are similar to those in the Transport Rule. Therefore, IDEM is confident that NO x and SO 2 emissions in 2015 and 2025 will be close to or below the projections. Additionally, the SO 2 and NO x allocations for the Duke Energy Indiana – Gallagher Generating Station and IKEC – Clifty Creek Power Plant for 2014 and beyond within the proposed Clean Air Transport Rule are le ss than 2009 actual emissions. Direct PM 2.5 emission estimates for 2015 and 2025 for the IKEC – Clifty Creek Power Plant were projected using the limits from the new proposed Na tional Emission Standards for Hazardous Air Pollutants for coal and oil-fired EGUs. Th e Duke Energy – Gallagher Generating Station replaced the electrostatic precip itators with baghouses on all four of their EGU units in late 2007 and early 2008. This reduced direct PM 2.5 emissions below base year levels. Duke Energy Indiana will also be shutting down two of its four coal-fired EGUs (Units 1 and 3) by no later than February 1, 2012. The remaining units (Units 2 and 4) have recently installed dry sorbent control technology to reduce SO 2 . This will further reduce direct PM 2.5 emissions below base year levels.

The Tennessee Valley Authority has also recently entered into a consent decree with U.S. EPA that establishes system-wide annual tonnage limits for NO x and SO 2 for its eleven coal-fired power plants located in Alabam a, Kentucky, and Tennessee. NO x will be limited to 100,600 tons per year beginning in 2011 and capped at 52,000 tons per year in 2018 and each year thereafter. SO 2 will be limited to 285,000 tons per year beginning in 2011 and capped at 110,000 tons per year in 2019 and each year thereafter. Th is will result in sign ificant regional NO x and SO 2 reductions, further ensuring that th e area will continue to maintain compliance with the standard with an increasing margin of safety. Graphs a nd data tables of emissi ons from the EGU source category can be found in Appendix D.25 Graph 4.17 Comparison of 2005, 2008, 2015, and 2025 Projected NO x Emissions, Clark, Floyd, and Jefferson Counties, Indiana

Graph 4.18 Comparison of 2005, 2008, 2015, and 2025 Projected SO 2 Emissions, Clark, Floyd, and Jefferson Counties, Indiana 0 10,000 20,000 30,000 40,000 50,000 60,000

2005 2008 2015 2025TonsperYear

Nitrogen Oxides Year

0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000

2005 2008 2015 2025TonsperYear

Sulfur Dioxide Year26 Graph 4.19 Comparison of 2005, 2008, 2015, and 2025 Projected Direct PM 2.5 Emissions, Clark, Floyd, and Jefferson Counties, Indiana

Graph 4.20 Comparison of 2005, 2008, 2015, and 2025 Projected NO x , SO 2 , and Direct PM 2.5 Emissions, Clark, Floyd, and Jefferson Counties, Indiana 0 500 1,000 1,500 2,000

2005 2008 2015 2025TonsperYear

Fine Particles Year

0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000

2005 2008 2015 2025TonsperYear

Nitrogen Oxides Sulfur Dioxide Fine Particles Year27 Graph 4.21 Comparison of 2005, 2008, 2015, and 2025 Projected NO x Emissions, Louisville Area

Graph 4.22 Comparison of 2005, 2008, 2015, and 2025 Projected SO 2 Emissions, Louisville Area 0 20,000 40,000 60,000 80,000 100,000 120,000

2005 2008 2015 2025TonsperYear

Nitrogen Oxides Year

0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000 180,000 200,000

2005 2008 2015 2025TonsperYear

Sulfur Dioxide Year28 Graph 4.23 Comparison of 2005, 2008, 2015, and 2025 Projected Direct PM 2.5 Emissions, Louisville Area

Graph 4.24 Comparison of 2005, 2008, 2015 and 2025 Projected NO x , SO 2 , and Direct PM 2.5 Emissions, Louisville Area 0 1,000 2,000 3,000 4,000 5,000 6,000 7,000 8,000 9,000 10,000

2005 2008 2015 2025TonsperYear

Fine Particles Year

0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000 180,000 200,000

2005 2008 2015 2025TonsperYear

Nitrogen Oxides Sulfur Dioxide Fine Particles Year29 NO x emissions within Clark, Floyd, and Jefferson c ounties, Indiana are pr ojected to decline by 47.70% between 2008 and 2025. NO x emissions within the Louisville Area are projected to decline by 39.04% between 2008 and 2025. Emission reduction benefits from U.S. EPA rules covering the NO x SIP Call, Tier 2 Motor Vehicle Em ission Standards and Gasoline Sulfur Control Requirements, Heavy-Duty Highway Engine Rule, and the Nonroad Diesel Engine Rule are factored into the changes. Addi tionally, due to implementation of the NO x SIP Call across the eastern United States, NO x and fine particle levels entering the Louisville Area will also be decreased. SO 2 emissions within Clark, Floyd, and Jeffers on counties, Indiana are projected to decrease by 69.52% between 2008 and 2025. SO 2 emissions within the Louisville Area are projected to decline by 49.78% between 2008 and 2025. Direct PM 2.5 emissions within Clark, Floyd, and Jefferson counties, I ndiana are projected to decr ease by 12.35% between 2008 and 2025. Direct PM 2.5 emissions within the Louisville Area are projec ted to decline by 24.81% between 2008 and 2025.

Table 4.1 Comparison of 2008 Estimated and 2025 Projected Emission Estimates, Clark, Floyd, and Jefferson Counties, Indiana (Tons per Year)

2008 2025 Change % Change

NO x 37,526.06 19,627.44 -17,898.62 47.70% decrease

SO 2 109,372.52 33,340.99 - 76,031.53 69.52% decrease

Direct PM 2.5 1,202.47 1,054.00 -148.47 12.35% decrease

Table 4.2 Comparison of 2008 Estimated and 2025 Projected Emission Estimates, Louisville Area (Tons per Year)

2008 2025 Change % Change

NO x 97,533.93 59,455.17 -38,078.76 39.04% decrease

SO 2 151,503.01 76,082.07 -75,42 0.94 49.78% decrease

Direct PM 2.5 6,724.02 5,055.61 -1,668.41 24.81% decrease

4.4 Demonstration of Maintenance

Quality-assured ambient air quality data from all the monitoring sites indicat e that air quality in Indiana’s portion of the nonattainment area met the annual standard for fine particles for the three-year period ending in 2010. U.S. EPA’ s Redesignation Guidance states, “A state may generally demonstrate maintenance of the NAAQS by either showing that future emissions of a pollutant or its precursors will not exceed the level of the atta inment inventory, or by modeling to show that the future mix of sources and em ission rates will not cause a violation of the NAAQS”. Section 3.0 of this document shows that the Louisville Area has, in fact, measured attainment for fine particles for the thr ee consecutive periods ending in 2008, 2009, and 2010. Additionally, emission projections outlined in Secti on 4.0 of this document clearly illustrate that regional NO x , SO 2 , and direct PM 2.5 emissions in the area will c ontinue to decline leading to30 local reductions between 2008 (base year) and 2025 (maintenance plan horizon). Section 7.0 further discusses the implications of these emi ssion trends and provides an analysis to support these conclusions.

In Indiana, major point sources in all counties are required to submit emissions information once every three years, or annually, if the NO x or SO 2 potential to emit is greater than 2,500 tons per year, in accordance with the Emission Reporti ng Rule, 326 IAC 2-6. IDEM prepares a new periodic inventory for all precurs or emission sectors every three y ears. These precursor emission inventories will be prepared for 2011, 2014, a nd 2017, as necessary, to comply with the inventory reporting requirements established in the CAA. Emissions information will be compared to the 2008 base year and the 2025 proj ected maintenance year inventories to assess emission trends, as necessary, to assure continue d compliance with the a nnual standard for fine particles.

4.5 Permanent and Enforceable Emission Reductions

Permanent and enforceable reductions of NO x and SO 2 have contributed to th e attainment of the annual standard for fine particles. Some of th ese reductions were due to the implementation of the NO x SIP Call rule and some were due to the application of tight er federal standards on motor vehicles and fuels.

Section 6.0 identifies the emission control meas ures specific to Clark, Floyd, and Jefferson counties, Indiana, as well as the impl ementation status of each measure.

4.6 Provisions for Future Updates

As required by Section 175A(b) of the CAA, Indi ana commits to submit to the Administrator, eight years after redesignation, an additional revi sion of this SIP. Th e revision will contain Indiana's plan for maintaining the national primary fine particles air quality standard for ten years beyond the first ten-year pe riod after re designation.

5.0 TRANSPORTATION CONFORMITY BUDGETS

U.S. EPA requirements outlined in 40 CFR 93.118( e)(4) stipulate that motor vehicle emission budgets (MVEBs) for direct PM 2.5 and NO x be established as part of a SIP. The MVEBs are necessary to demonstrate conformance of tran sportation plans and impr ovement programs with the SIP.

The following is a summary of the detailed mobile input and output calcul ation files located in Appendix F.

5.1 Onroad Emission Estimates

KIPDA is the Metropolitan Pl anning Organization (MPO) for Clark and Floyd Counties in Indiana, as well as Bullitt, Jefferson, and Oldham Counties in Kentucky. All of the MPO31 counties except for Oldham County are in the nona ttainment area for fine particles. Madison Township in Jefferson County, Indiana is also in the nonattainment area. KIPDA maintains a travel demand forecast model that is used to simu late the traffic in the area and to predict what traffic would be in future years given growth exp ectations. The model is used mostly to identify where travel capacity will be needed and to de termine the infrastructure requirements necessary to meet that need. It is also used to support the calculation of mobile source emissions. The travel demand forecast model is used to predict the total daily vehicle miles traveled (VMT) and the U.S. EPA software program referred to as MOVES is used to produce emission factors to calculate the emissions per mile. The product of these two outputs, once combined, is the estimated total amount of pollution emitted by the onroad vehicles for the area analyzed. Madison Township in Jefferson County, Indiana doe s not fall under the jurisdiction of KIPDA. In cases such as this, INDOT’s Highway Perfor mance Monitoring System (HPMS) baseline data is used to estimate and project mobile source emi ssions. This is a national program that requires state Departments of Transporta tion to collect traffic counts throughout the state on a regular basis under a certain regulated method. This HP MS data is collected and provided by INDOT and was used for these areas beyond KIPDA’s jurisdiction.

5.2 Overview

Broadly described, MOVES is used to genera te “emission factors”, which are the average emissions per mile (grams/mile) for fi ne particle precursors, including NO x , SO 2 , and direct PM 2.5 . There are numerous variables that can aff ect the emission factors. The vehicle fleet (vehicles on the road), age, and the vehicle types have a major e ffect on the emission factors. The facility-type on which vehicles are travelin g (MOVES facility types are Freeway, Arterial, Local, and Ramp) and the vehicle sp eeds also affect the emission f actor values. Meteorological factors such as air temperature a nd humidity affect emission factors, as does fuel type, such as low Reid Vapor Pressure gasoline. These data are estimated using the best available data to create emission factors for NO x , SO 2 , and direct PM 2.5 . After emission factors are generated, they must be multiplied by the VMT to determine the quantity of vehicle-related emissions. This information is derived from th e travel demand model (TDM).

It should be noted that each year analyzed will have different emission factors, volumes, speeds, and likely results in additional modeling. MOVE S input summary and RunSpec parameters can be found in Appendix F. The full MOVES m odeling package, including input and output documentation, is provided elec tronically in Appendix F.

5.3 Emission Estimations

Table 5.1 outlines the onroad emission estimates for the entire nonattainment area for the years 2005, 2008 (base/attainment year), 20 15 (interim year), and 2025 (horizon year). The following emission estimates are based on the actual TDM network runs for the years 2005, 2008, 2015, and 2025.32 Table 5.1 Emission Estimations for Onroad Mob ile Sources for the Louisville Area

Kentucky Emissions (Bullitt and Jefferson County) 2005 2008 2015 2025

Direct PM 2.5 (tons/year) 805.38 712.46 395.37 217.84 NO x (tons/year) 25,193.80 21,914.85 12,042.31 6,285.38 Indiana Emissions (Madison Township in Jefferson County, Clark and Floyd Counties) Direct PM 2.5 (tons/year) 250.23 210.91 109.58 63.93 NO x (tons/year) 7,550.76 6,245.60 3,349.82 1,811.80 Louisville Area Emission Totals Direct PM 2.5 (tons/year) 1,055.61 923.37 504.95 281.77 NO x (tons/year) 32,744.56 28,160.45 15,392.13 8,097.18

Table 5.2 contains the MVEBs for the entire nonattainment area fo r the years 2015 and 2025.

Table 5.2 Motor Vehicle Emission Budgets for the Louisville Area

2015 2025 Direct PM 2.5 (tons/year) 580.69 324.04

NO x (tons/year) 17,700.95 9,311.76

Consistent with the federal im plementation rule for fine part icles, IDEM does not consider mobile source SO 2 emissions to be a significant contri butor to fine particles for this nonattainment area, as SO 2 from mobile sources constitutes less than 0.2% of the area’s total anthropogenic SO 2 emissions for the years 2005, 2008, 2015, and 2025.

This document creates an interim year budge t for 2015 and a horizon year budget for 2025 for the entire nonattainment area. These budge ts are based on the 2008 onroad source emission inventory used to support photochemical modeling for the same year, and has incorporated an appropriate safety margin as described below.

In an effort to accommodate future variations in TDMs and the VMT forecast when no change to the network is planned, IDEM consulted with th e interagency consultatio n group, including U.S. EPA Region V, to determine a reasonable approach to address this variation. The interagency consultation group approved a 15% safety margin for direct PM 2.5 mobile source emission estimates for the years 2015 and 2025, and a 15% safety margin for NO x mobile source emission estimates for the years 2015 and 2025.33 The safety margins are appropriate because: 1) there is an acknowledged potential variation in the VMT forecast and potential estimated mobile source emissions due to expected modifications to TDM and mobile emissions models; and, 2) the to tal decrease in emissions from all sources is sufficient to accommodate the safety margin alloca tions detailed above to mobile sources while still continuing to maintain tota l emissions in the Louisville Ar ea well below the 2008 attainment level of emissions. These safety margins were ca lculated by adding a strai ght-line percentage to the mobile source emission estimates for the years 2015 and 2025. Safety margin, as defined by the conformity rule, looks at the total emissions from all sources in the nonattainment area. The resulting 2015 and 2025 MVEBs for direct PM 2.5 and NO x emissions remain well below the 2008 base year emissions refe renced in Table 5.1.

In summary, for Indiana and Kentucky combin ed, the mobile budget safety margin allocation translates into:

 An allocation of 75.74 tons/year for PM 2.5 and 2,308.82 tons/year for NO x for 2015.

 An allocation of 42.27 tons/year for PM 2.5 and 1,214.58 tons/year for NO x for 2025.

The federal rule at 40 CFR 93.101 defines safety margin as the amount by which the total projected emissions from all sources of a given pollutant are less than the total emissions that would satisfy the applicable requirement for reasonable further progress, attainment, or maintenance. When compared to the overall safety margin as defined by 40 CFR 93.101, it is evident that this allocation to mobile sources is significantly below the total safety margin for all sources in the Louisville Area as detailed in Table 4.2.

While IDEM believes that this is sufficient to support the requested increase, IDEM and its partners will be conducting additional air quality modeling which will include the adjusted mobile source emissions, as well as any additiona l corrections and modifications that may be necessary due to the constant review and evaluation of the model inputs.

All methodologies, latest planning assumptions, and margins of safety were determined to be appropriate through the intera gency consultation process.

6.0 CONTROL MEASURES AND REGULATIONS

This section provides specific information on the control measures that have been or will be implemented in Jefferson County (Madison Township) and Clark and Floyd counties, Indiana, including CAA requirements and additional stat e or local measures implemented beyond CAA requirements.

6.1 Reasonably Available Control Technology (RACT)

As required by Section 172 of the CAA, in the mid-1990s, Indiana promulgated rules requiring RACT for emissions of VOCs. There were no specific rules required by the CAA, such as RACT for existing sources, beyond st atewide rules. Statewide RACT rules have applied to all34 new sources locating in Indiana since that time. The Indiana rules are found in 326 IAC 8. The following is a listing of applicable rules:

326 IAC 8-1-6 Best Available Contro l Technology for Non-Specific Sources 326 IAC 8-2 Surface Coating Emission Limitations 326 IAC 8-3 Solvent Degreasing Operations 326 IAC 8-4 Petroleum Sources 326 IAC 8-5 Miscellaneous Operation 326 IAC 8-6 Organic Solvent Emission Limitations

Since Jefferson County (Madison Township) and Cl ark and Floyd counties, Indiana attained the annual standard for fine particles prior to an Attainment SIP or RACT SIP being due, and since the Implementation Rule for fine particles stipulat es that states are only required to draft and implement RACT rules for the precursor emission reductions necessary to attain the standard, no further RACT rules are required for this area. These Indiana rules are CAA requirements already in the SIP and provide secondary benefits for PM 2.5
. 6.2 Implementation of Past SIP Revisions

The Louisville Area was designated nonattainment for the annual standard for fine particles in 2003 and the area attained the standard well in a dvance of its attainment deadline of 2010. As a result, Indiana is no longer required to devel op and submit an Attainment SIP or RACT SIP for this area under the annual NAAQ S for fine particles.

6.3 Nitrogen Oxides Rule

The U.S. EPA NO x SIP Call required twenty-two states to adopt rules that would result in significant emission reductions from large EGUs, industrial boilers, and cement kilns in the eastern United States. The Indiana rule was adopted in 2001. Beginning in 2004, this rule accounts for a reduction of a pproximately 31% of all NO x emissions statewide compared to previous uncont rolled years.

Twenty-one other states have also adopted these rules. The result is that significant reductions have occurred regionally and within the nonattai nment area because of th e number of affected units within the region. From Graphs 4.13 and 4.15, it can be seen that emissions covered by this program have been trending downward since 1999. Table 6.1, compiled from data taken from the U.S. EPA Clean Air Markets web site, quantifies the gradual NO x reductions that have occurred in Indiana as a result of Titl e IV (Acid Rain) of the CAA and the NO x SIP Call Rule. The NOx SIP Call cap stayed in place through 2008, at which time the caps in the CAIR program superseded it. Since CAIR is a regiona l cap and trade program, it cannot be predicted at this time what affect this will have on EGU units located in the nonattainment area or other upwind counties.

Further, U.S. EPA published Phase II of the NO x SIP Call that established a budget for large (emissions of greater than 1 ton pe r day) stationary internal combus tion engines. In Indiana, the rule decreases emissions statewide from natural gas compressor stations by 4,263 tons during the35 ozone season (April through September). Th e Indiana Phase II NOx SIP Call Rule became effective February 26, 2006 and implementation began in 2007.

Table 6.1 Trends in EGU NO x Emissions Statewide in Indiana

Year NO x Emissions (tons/year) 1999 347,216.5 2000 334,522.1 2001 315,419.7 2002 281,146.1 2003 260,980.0 2004 224,311.3 2005 207,981.6 2006 202,728.0 2007 196,553.1 2008 196,134.5 2009 110,968.9 Budget 2009-2014 108,935 Budget 2015 and later 90,779

6.4 Measures Beyond Clean Air Act SIP Requirements

Reductions in fine particle precur sor emissions have occurred, or are anticipated to occur, as a result of local and federal programs. These additional control measures include those listed in this section.

Tier 2 Vehicle Standards 2

Federal Tier 2 motor vehicle sta ndards require all passe nger vehicles in a manufacturer’s fleet, including light-duty trucks and s port utility vehicles (SUVs), to meet an average standard of 0.07 grams of NO x per mile. Implementation began in 2004 and was completed in 2007. The Tier 2 standards also cover passenger vehicles over 8,500 pounds gross vehicle weight rating (larger pickup trucks and SUVs), which are not covered by the current Tier 1 standards. For these vehicles, the standards were phased in begi nning in 2008, with full compliance in 2009. The new standards require vehicles to be 77% to 95 % cleaner than those on the road prior to the program. The Tier 2 standards also reduced the su lfur content of gasoline to 30 parts per million (ppm) beginning in January 2006. Most gasoline sold in Indiana prior to January 2006 had a sulfur content of about 500 ppm. Sulfur occurs naturally in gasoline, but interferes with the operation of catalytic converters on vehicles resulting in higher NO x emissions. Lower sulfur gasoline is necessary to achieve the Tier 2 vehicle emission standards.

2 http://www.epa.gov/fedrgstr/EPA-AIR /2000/February/Day-10/a19a.htm36 Heavy-Duty Gasoline and Dies el Highway Vehicle Standards 3

New U.S. EPA standards designed to reduce NO x and VOC emissions from heavy-duty gasoline and diesel highway vehicles took effect in 2004. A second pha se of standards and testing procedures that began in 2007, reduced PM 2.5 emissions from heavy- duty highway engines and also reduced highway diesel fuel sulfur content to 15 ppm since the sulfur can damage emission control devices. The total program is expect ed to achieve a 90% reduction in direct PM 2.5 emissions and a 95% reduction in NO x emissions for these new engi nes using low sulfur diesel, compared to existing engines using higher sulf ur content diesel. There will also be SO 2 reductions from these rules although U.S. EPA has not quantified the expected reductions.

Large Nonroad Diesel Engine Standards 4

In May 2004, U.S. EPA promulgated new rules for large nonroad diesel engines, such as those used in construction, agricultur al, and industrial equipment, to be phased in between 2008 and 2014. The nonroad diesel rules also reduce the al lowable sulfur in nonroad diesel fuel by over 99%. Prior to 2006, nonroad diesel fuel averaged approximately 3,400 ppm sulfur. This rule limited nonroad diesel sulfur content to 500 ppm by 2006 with a further reduction to 15 ppm by 2010. The combined engine and fuel rules will reduce NO x and PM emissions from large nonroad diesel engines by over 90%, compared to current nonroad engines using higher sulfur content diesel.

Nonroad Spark-Ignition Engines and Recreational Engine Standards

This standard, effective in July 2003, regulates NO x , VOCs, and carbon monoxide (CO) for groups of previously unregulated nonroad engines. The standard applies to all new engines sold in the United States and imported after the standa rds went into effect. The standard applies to large spark-ignition engines (f orklifts and airport ground service equipment), recreational vehicles (off-highway motorcycle s and all-terrain vehicles), a nd recreational marine diesel engines. The regulation varies based upon the type of engine and vehicle.

The emissions from large spark-ignition engines contribute to ozone form ation and ambient CO and PM 2.5 levels in urban areas. Tier 1 of this standard was implemented in 2004 and Tier 2 started in 2007. Like the large spark-ignition engines, emissions from recreational vehicles contribute to ozone and fine partic le formation and ambient CO and PM 2.5 levels. For Model Year 2006 off-highway motorcycles and all-terrain vehicles, at least 50% of a manufacture’s fleet was required to meet the new exhaust emissions standard and 100% of the fleet was required to meet the standards in 2007. Recreati onal marine diesel engines over 37 kilowatts are used in yachts, cruisers, and ot her types of pleasure cr aft. Emissions from recreational marine engines contribute to ozone formation and PM levels, especially surrounding marinas.

When all of the nonroad spark- ignition engines and recreationa l engine standards are fully implemented, an overall 72% reduc tion in VOC, 80% reduction in NO x , and 56% reduction in CO emissions is expected by 2020.

3 http://www.epa.gov/fedrgstr/EPA-AIR /1997/October/Day-21/a27494.htm

4 http://www.epa.gov/fedrgstr/EPA-AIR /1998/October/Day-23/a24836.htm37 Reciprocating Internal Co mbustion Engine Standards 5

This new standard, effective in May 2010, regulates emissions of air toxics from existing diesel powered stationary reciprocating internal combustion engines that meet specific s ite rating, age, and size criteria. These engines are typically used at industrial facilities (e.g. power, chemical, and manufacturing plants) to ge nerate electricity for compre ssors and pumps and to produce electricity to pump water for flood a nd fire control during emergencies.

The standard applies to stationary diesel engine s: (1) used at area sources of air toxics and constructed or reconstructed befo re June 12, 2006; (2) used at majo r sources of air toxics, having a site rating of less than or e qual to 500 horsepower, and constr ucted or reconstructed before June 12, 2006; and, (3) used at major sources of air toxics for non-emergency purposes, having a site rating of greater than 500 horsepower, and constructed or reconstructed before December 19, 2002.

Operators of existing engines will be required to: (1) install em issions control equipment that would limit air toxics up to 70% for stationary non-emergency engi nes with a site rating greater than 300 horsepower; (2) perform emission test s to demonstrate engine performance and compliance with rule requirements; and, (3) bur n ultra-low sulfur fuel in stationary nonemergency engines with a site rati ng greater than 300 horsepower.

When all of the reciprocating internal combustion engine standards are fully implemented in 2013, U.S. EPA estimates that emissions from these engines will reduce air toxics by approximately 1,000 tons per year (tpy), PM 2.5 by 2,800 tpy, CO by 14,000 tpy, and VOC by 27,000 tpy.

Category 3 Marine Diesel Engine Standards 6

This new standard, effective in June 2010, pr omulgates more stringent exhaust emission standards for new large marine diesel engines with per-cylinder displacement at or above 30 liters (commonly referred to as Category 3 compre ssion-ignition marine engines) as part of a coordinated strategy to address em issions from all ships that affect U.S. air quality. These emission standards are equivalent to those adop ted in the amendments to Annex VI to the International Convention for the Prevention of Pollution from Ships (MARPOL Annex VI). The emission standards apply in two stages—near-term standards for newly built engines will apply beginning in 2011; long-term standard s requiring an 80% reduction in NO x emissions will begin in 2016.

U.S. EPA is adopting changes to the diesel fuel program to allow for the production and sale of diesel fuel with up to 1,000 ppm sulfur for use in Category 3 marine vessels. The regulations generally forbid production and sale of fuels with more than 1 ,000 ppm sulfur for use in most U.S. waters, unless operators achieve equiva lent emission reducti ons in other ways.

5 http://www.epa.gov/ttn/atw/rice/fr03mr10.pdf

6 http://www.regulations.gov/s earch/Regs/home.html#documen tDetail?R=0900006480ae43a638 U.S. EPA is also adopting provisions to apply some emission and fuel standards to foreignflagged and in-use vessels that are covered by MARPOL Annex VI.

When this strategy is fully implemen ted in 2030, U.S. EPA estimates that NO x and PM 2.5 emissions in the U.S. will be reduced by approximately 1.2 million tpy and 143,000 tpy, respectively.

Clean Air Interstate Rule (CAIR)

On May 12, 2005, U.S. EPA promulgated the “Rule to Reduce Interstate Transport of Fine Particulate Matter and Ozone (C lean Air Interstate Rule); Revisions to Acid Rain Program; Revisions to the NO x SIP Call”; Final Rule (70 FR 25162). Th is rule established the requirement for states to adopt rules limiting the emissions of NO x and SO 2 and provided a model rule for the states to use in developing thei r rules to meet federal requirements. The purpose of CAIR was to reduce interstate transport of precu rsors to fine particles and ozone.

CAIR applies to: (1) any stati onary, fossil-fuel-fired boiler or stationary, fossil-fuel-fired combustion turbine, a generator w ith a nameplate capacity of more than 25 megawatt electrical (MWe) producing electricity for sale; and (2) a unit that qualifies as a cogeneration unit during the 12-month period starting on the da te that the unit first produces electricity and continues to qualify as a cogeneration unit, a cogeneration unit serving at any time a generator with a nameplate capacity of more than 25 MWe and s upplying in any calendar year more than onethird of the unit’s potentia l electric output capacity or 219,000 megawatt hours (MWh), whichever is greater, to any utility power distri bution system for sale.

This rule provides annual state caps for NO x and SO 2 in two phases, with the Phase I caps for NO x and SO 2 starting in 2009 and 2010, respectively. Ph ase II caps become effective in 2015. U.S. EPA is allowing the caps to be met through a cap and trade program if a state chooses to participate in the program.

In response to U.S. EPA’s rulemaking, IDEM a dopted a state rule in 2006 based on the model federal rule. IDEM’s rule includes annual and seasonal NO x trading programs, and an annual SO 2 trading program. This rule requir es compliance effective January 1, 2009.

SO 2 emissions from power plants in the 28 eastern states and the District of Columbia covered by CAIR will be cut by 4.3 million tons by 2009 and reduced by an additional 5.4 million tons in 2015. NO x emissions will be cut by 1.7 million tons by 2009 and reduced by an additional 1.3 million tons in 2015. The D.C. Circuit court’s va catur of CAIR in July of 2008 and subsequent remand without vacatur of CAIR in December of 2008 directs U.S. EPA to revise or replace CAIR in order to properly address the deficiencies outlined by the court.

Since the court’s opinion made it clear that CAIR is deficient and must be revised or replaced, the program cannot be defined as permanent a nd enforceable for SIP purposes. On July 6, 2010, U.S. EPA proposed the Clean Air Transport Rule to replace CAIR. The Clean Air Transport Rule will result in even greater benefits than CA IR and than what is assumed within the emission inventories and modeling.39 Together, these rules will substantially reduce local and regional sour ces of fine particle precursors. The modeling analyses discussed in Section 7.0 include thes e rules and show the reductions in annual fine particle concentrations expected to result from the implementation of these rules.

6.5 Controls to Remain in Effect

IDEM commits to maintain the control measures listed above after redesignation, or submit to U.S. EPA, as a SIP revision, any changes to its rules or emission limits applicable to NO x , SO 2 , or direct PM 2.5 sources as required for maintenance of th e annual standard for fine particles in Jefferson County (Madison Township) and Clark and Floyd counties, Indiana.

Indiana, through IDEM’s Office of Air Quality and its Compliance and Enforcement Branch, has the legal authority and necessary resources to act ively enforce any violations of its rules or permit provisions. After redesignati on, it intends to continue enforci ng all rules that relate to the emission of fine particles and fine particle precursors in Jefferson County (Madison Township) and Clark and Floyd counties.

6.6 New Source Review Provisions

Indiana has a long standing and fully implemente d New Source Review (NSR) program that is outlined in rule 326 IAC 2. The rule includes provisions for the Prevention of Significant Deterioration (PSD) permitting program in 326 IAC 2-2 and the emissions offset rule in 326 IAC 2-3. Indiana's PSD program was conditionally approved on March 3, 2003 (68 FR 9892) and received final approval on May 20, 2004 (69 FR 29071) by U.S. EPA as part of the SIP.

Any emission unit that is not lis ted in the 2005 emission inventor y, or for which credit through the shutdown or curtailment of operations was taken in demonstrating attainment, will not be allowed to construct, reopen, modify, or recons truct without meeting all applicable permit rule requirements. The review process will be identical to that used for new sources. Once the area is redesignated, OAQ will implement NSR through the PSD program, which requires an air quality analysis to evaluate whethe r the new source will threaten the NAAQS.

7.0 MODELING AND METEOROLOGY

Although U.S. EPA Redesignation Guidance does not require modeling for fine particle nonattainment areas seeking rede signation, extensive modeling has been performed for the Louisville Area to determine the effect of natio nal emission control strate gies on fine particle levels. These modeling analyses determined th at the Louisville Area, including Clark and Floyd counties, Indiana, are significantly impacted by regional transport of fi ne particles and its precursors, and that regional NO x and SO 2 reductions are an effectiv e way to attain the annual standard for fine particles in th is area. Future year modeled a nnual fine particle concentrations are expected to be reduced by 0.3 to 0.9 μg/m 3 from baseline design values. Examples of these modeling analyses are describe d in this section and can al so be found in Appendix J.40 7.1 Summary of Modeling Results to Support Rulemakings

U.S. EPA Modeling for Clean Air Transport Rule 2010 7

U.S. EPA performed modeling to support the emission reductions associated with the proposed Clean Air Transport Rule. U.S. EPA used the Comprehensive Air Quality Model with Extensions (CAMx, version 5), applied to the 2005 meteorology, as processed by the Mesoscale Model (MM5), version 3.7.4. Emissi ons input into CAMx included SO 2 , NO x , VOCs, NH 3 , and direct PM 2.5 for 2005. The modeling was based on th e annual fine particle design values calculated from 2003 through 2005, 2004 through 2006, and 2005 through 2007. Future year modeling was conducted, which included the Louisvil le Area, and the future year design values for 2012 and 2014 were evaluated for attainment of the annual NAAQS for fine particles of 15 μg/m 3 , as shown in Table 7.1. Fine particle con centrations are accounted for by modeling both the base future year emissions and then the em ission reductions associated with the Clean Air Transport Rule. U.S. EPA found that the model performance met the suggested benchmark performance goals within or close to the ranges found in other comparable modeling applications.

Table 7.1 Clean Air Transport Rule Modeling Results from U.S. EPA (Using 2003 through 2007 Design Values)

SITE ID SITE NAME COUNTY Design Value 2003 – 2007

(μg/m 3 ) Future Design Value 2012 Base

(μg/m 3 ) Future Design Value 2014 Base

(μg/m 3 ) 18-019-0006 Jeffersonville – Walnut St. Clark. 16.40 15.96 15.46 18-043-1004 New Albany Floyd 14.80 14.50 14.04 21-029-0006 Carpenter Street Bullitt – KY 14.90 14.58 14.07 21-093-0006 Elizabethtown Hardin – KY 13.58 13.34 12.82 21-111-0043 Southern Avenue Jefferson – KY 15.53 15.19 14.71 21-111-0044 Wyandotte Park Jefferson – KY 15.31 14.93 14.45 21-111-0048 Barret Avenue Jefferson – KY 15.25 14.87 14.38 21-111-0051 Watson Elementary Jefferson – KY 14.70 14.43 13.95

Modeling results show that the base future year modeling with emi ssion reductions from the Clean Air Transport Rule will account for a 0.3 to 0.4 μg/m 3 decrease in concentrations for 2012, as well as a 0.8 to 0.9 μg/m 3 decrease in concentrations fo r 2014 in the Louisville Area.

While results of U.S. EPA’s Clean Air Transport Rule modeling show modeled PM 2.5 concentrations above the standard with base ca se emissions at the Jeffersonville, Indiana – Walnut Street PM 2.5 monitor (Clark County), it should be not ed that the base year design value used by U.S. EPA was taken from 2003 thr ough 2007 and is higher than current 2006 through 2010 design values in the Louisville Area. Gr aph 7.1 shows the downward trend of the design values from 1999 through 2010 from the PM 2.5 monitors in the Louisvi lle Area. In fact, all design values are below the annual standard for fine particles.

7 http://www.epa.gov/airquality/transp ort/pdfs/TR_AQModeling_TSD.pdf41 Graph 7.1 PM 2.5 Design Value Trends for the Louisville Area, 1999 to 2010

The resulting decrease of the design value at the Jeffersonville, Indiana – Walnut Street PM 2.5 monitor is 1.74 μg/m 3 and 1.92 μg/m 3 at the New Albany, Indiana PM 2.5 monitor (Floyd County). The annual PM 2.5 design values for the Louisville Ar ea monitors have dropped with the 2006 through 2010 design values ranging from 1.29 μg/m 3 to 1.93 μg/m 3 less than the 2003 through 2007 design values modeled by U.S. EPA. Therefore, U.S. EPA’s Clean Air Transport Rule modeling, using the current 2006 through 2010 design values, showed lower modeled concentrations approaching the annua l NAAQS for fine particles (15.0 μg/m 3 ). Results of this modeling are shown below in Table 7.2 and are based on the relative re sponse factors (RRFs) calculated from the annual PM 2.5 future year base case resu lts divided by the 2003 through 2007 PM 2.5 base case design values. This is a simplistic version of PM 2.5 RRF calculations and is used only as a weight of evidence demonstrat ion of future year modeled results.

Table 7.2 Clean Air Transport Rule Modeling Results from U.S. EPA (Using 2006 through 2010 Design Values)

SITE ID SITE NAME COUNTY Design Value 2006-2010

(μg/m 3 ) 2012 RRF Future Design Value 2012 Base

(μg/m 3 ) 2014 RRF Future Design Value 2014 Base

(μg/m 3 ) 18-019-0006 Jeffersonville – Walnut Street Clark 14.71 0.973 14.31 0.943 13.49 18-043-1004 New Albany Floyd 12.93 0.980 12.67 0.949 12.02 21-029-0006 Carpenter Street Bullitt – KY 13.32 0.979 13.03 0.944 12.31 21-111-0043 Elizabethtown Jefferson – KY 13.62 0.978 13.37 0.947 12.63 21-111-0044 Southern Avenue Jefferson – KY 13.75 0.975 13.45 0.944 12.74 21-111-0048 Wyandotte Park Jefferson – KY 13.41 0.975 13.08 0.943 12.35 21-111-0051 Barret Avenue Jefferson – K Y 13.42 0.982 13.08 0.949 12.34 12.00 14.00 16.00 18.00

1999

‐ 2003 2000

‐ 2004 2001

‐ 2005 2002

‐ 2006 2003

‐ 2007 2004

‐ 2008 2005

‐ 2009 2006

‐ 2010Concentrations(ug/m3)

Design Value Years Jeffersonville ‐ Walnut St. Charlestown State Park New Albany Shepherdsville Southern Avenue Wyandotte Park

Barret Avenue/Cannon Lane Watson Elementary Annual NAAQS42 As can be seen, modeled results are lower when current annual fine particle design values are used to determine future year modeling. Using the 2006 through 2010 design values, all Louisville Area PM 2.5 monitoring sites would not exceed th e annual NAAQS for fine particles in 2012 and remain below the annual PM 2.5 NAAQS in 2014.

LADCO Modeling for the Clean Air Interstate Rule (CAIR)

LADCO conducted modeling to determine the imp act of CAIR in the Midwest. LADCO’s modeling used the CAMx model applied to the year 2005 meteorology, as processed by the MM5. Emissions input into CAMx included SO 2 , NO x , VOCs, NH 3 , and direct PM 2.5 for 2005. The modeling was based on 2003 through 2007 design values. Future year modeling for 2012 and 2018 was conducted and the future year design values were determined without the emission reductions associated with CAIR (Round 6), as shown in Table 7.3. The U.S. Clean Air Transport Rule is expected to pr ovide reductions above and beyond CAIR.

Table 7.3 LADCO Round 6 Modeling Results for Annual PM 2.5 – Without CAIR Emission Reductions (Using 2003 – 2007 Design Values)

SITE ID SITE NAME COUNTY Design Value 2003-2007

(μg/m 3 ) Base-case 2012 (μg/m 3 ) Base-case 2018 (μg/m 3 ) 18-019-0006 Jeffersonville – Walnut St. Clark 16.5 15.6 15.5 18-043-1004 New Albany Floyd 14.9 14.0 13.8 21-029-0006 Carpenter Street Bullitt – KY 14.9 14.2 14.1 21-093-0006 Elizabethtown Hardin – KY 13.6 12.8 12.7 21-111-0043 Southern Avenue Jefferson – KY 15.6 14.6 14.4 21-111-0044 Wyandotte Park Jefferson – KY 15.3 14.5 14.4 21-111-0048 Barret Avenue Jefferson – KY 15.1 14.3 14.2 21-111-0051 Watson Elementary Jefferson – KY 14.8 13.9 13.8

LADCO based its Round 6 modeling on annual design values from 2003 through 2007. Current annual fine particle design values have dropped since this design value period, as shown previously in Graph 7.1. A decrease of the design values from 2003 through 2007 to 2006 through 2010 at the Jeffersonvi lle – Walnut Street PM 2.5 monitor of 1.74 μg/m 3 and 1.92 μg/m 3 at the New Albany, Indiana PM 2.5 monitor occurred. The design values for the Louisville Area monitors have dropped with the 2006 through 2010 design va lues ranging from 1.29 μg/m 3 to 1.93 μg/m 3 less than the 2003 through 2007 design values. The 2006 through 2010 design values were multiplied by the RRFs calculations, based on the future year design values divided by the 2003 through 2007 design value. Th ese results are shown in Table 7.4.43 Table 7.4 LADCO Round 6 Modeling Results for Annual PM 2.5 – Without CAIR Emission Reductions (Using 2006 – 2010 Design Values)

SITE ID SITE NAME COUNTY Design Value 2006-2010

(μg/m 3 ) 2012 RRF Base-case 2012 (μg/m 3 ) 2018 RRF Basecase 2018 (μg/m 3 ) 18-019-0006 Jeffersonville – Walnut St. Clark 14.71 0.945 13.9 0.939 13.8 18-043-1004 New Albany Floyd 12. 93 0.940 12.1 0.926 12.0 21-029-0006 Carpenter Street Bullitt – KY 13.32 0.953 12.7 0.946 12.6 21-111-0043 Southern Avenue Jefferson – KY 13.62 0.936 12.7 0.923 12.6 21-111-0044 Wyandotte Park Jefferson – KY 13.75 0.948 13.0 0.941 12.9 21-111-0048 Barret Avenue/Cannon Lane Jefferson – KY 13.41 0.947 12.7 0.940 12.6 21-111-0051 Watson Elementary Jefferson – KY 13.42 0.939 12.6 0.932 12.5

As can be seen, annual PM 2.5 modeled results are lower when current design values are used to determine future year modeling. Using the 2006 through 2010 design values, all Louisville Area monitoring sites will be below the annual NAAQS fo r fine particles by 2012 and will continue to decrease thereafter.

7.2 LADCO Round 5 Speciated Mode led Attainment Test Results

The Speciated Modeled Attainment Test (SMAT) is the attainment test for annual fine particles. To determine the future year annual fine particle concentrations, speciated data is calculated. The different species that were modeled and are a ssociated with fine particles include sulfates, nitrates, organic carbon, elemental carbon, a mmonium, particle bound water, “other” primary inorganic fine particles, and pa ssively collected mass. The SM AT results from LADCO’s Round 5 modeling are listed below. Round 5 modeled the emission reducti ons associated with CAIR so the results reflect the impacts from CAIR. Percent ranges of the model results from the Jeffersonville, Indiana – Wal nut Street and New Albany PM 2.5 monitors in Clark and Floyd counties, Indiana, were broken down into the speciated constituents of fine particle emissions. The percent change from the obser ved speciated data in 2005 to th e future year modeled results for 2009 are listed in Table 7.5. While these m odeling results are outdated, this weight of evidence demonstration shows th e reduction potential from nati onal emission control measures for the PM 2.5 species in southern Indiana. An updated analysis will be conducted at a later time, using more current emissions and meteorological da ta and for a relevant fu ture year projection.44 Table 7.5 LADCO Round 5 SMAT Modeling Results for Southern Indiana (Percent decrease from observed to modeled concentrations)

Species of PM 2.5 2009 Sulfates 30% Nitrates 0% Organic Carbon 0% Elemental Carbon 14% - 16% Ammonium 24% - 26% Particle Bound Water 25% - 29%

The results demonstrate that sulfate, ammonium, elemental carbon, and particle bound water concentration decreases are proj ected to be at least 14% in the future year 2009. LADCO modeling shows good performance for sulfates and elemental carbon predicted baseline concentrations, slight over-predi ction for nitrate con centrations, and under-pre dictions of organic carbon concentrations. Overall, model performa nce is adequate for SIP planning and gives a good idea of the effects of emission reductions from national emission control measures on southern Indiana.

7.3 LADCO Round 5 Particulate So urce Apportionment Results

Particulate Source Apportionment (PSAT) modeli ng was conducted by LADCO. The results of the PSAT modeling show the regional contribu tions by emission sector s on each monitor that was modeled. Chart 7.1 displa ys the PSAT modeling results for the Jeffersonville –Walnut Street fine particle monitor in Clark County, Indiana. Kent ucky was the biggest regional contributor to the monitor with Indiana, Ohio, and the remaining Visibility Improvement State and Tribal Association of the Southeast (V ISTAS) Regional Planning Organization states (Alabama, Florida, Georgia, Kentucky, Mississipp i, North Carolina, South Carolina, Tennessee, Virginia, and West Virginia and the Eastern Band of the Cherokee Indians) also being significant contributors.

The PSAT Round 5 modeling results indicate that the majority of Indiana’s emission sector contributions to fine particle concentrations come from E GUs, ammonium emission sources, mobile, non-EGU sources, off-road (including marine , aircraft, and railroad), and area emission sources. These results are considered to be representative of Clark, Floyd, and Jefferson counties, Indiana as EGU, ammonium, and non-EGU emissions impact the entire area.45 Chart 7.1 Regional/Emission Sector Particulate Sou rce Apportionment Technology (PSAT) Test Results, Jeffersonville, I ndiana – Walnut Street PM 2.5 Monitor

The following pie charts depict th e contribution by species to fine particle concentrations at the Louisville Area monitors. Th e pie charts include both the observed 2005 contributions and 2009 modeled contributions for each monitor. Since the monitors are in close proximity to each other, results are fairly similar in the distribution of sp ecies concentrations among the monitors. Charts 7.2 through 7.9 cover the eight fine particle monito rs in the Louisville Area that are used to determine compliance with the an nual NAAQS for fine particles.

The speciation listed in the pie charts include SO 4 – sulfate mass, NO 3 – nitrate mass, OC – organic carbon mass, EC – elemental carbon mass, Soil – crustal material mass, NH 4 – ammonium mass, PBW – partic le bound water mass, and BLAN – passively collected mass.46 Chart 7.2 Modeled Contributions by Species at the Jeffersonville, Indiana Walnut Street PM 2.5 Monitor (Observed Concentrations = 16.2 μg/m 3 ) (Modeled Concentrations =13.6 μg/m 3 )

Chart 7.3 Modeled Contribution by Species at the New Albany, Indiana PM 2.5 Monitor (Observed Concentrations = 14.5 μg/m 3 ) (Modeled Concentrations =12.1 μg/m 3 )

so4 35%

no3 7% oc 23% ec 4% soil 4% nh4 13% pbw 11%

blan 3% Observed 2005 Contributions at

the New Albany PM 2.5 Monitor

so4

no3

oc

ec soil

nh4 pbw

blan so4 29%

no3 8% oc 28% ec 4% soil 5% nh4 12% pbw 10% blan 4% 2009 Modeled Contributions at the New Albany PM 2.5 Monitor

so4
no3

oc

ec soil
nh4 pbw
blan so4 27%

no3 9% oc 31% ec 4% soil 4% nh4 12% pbw 9% blan 4% 2009 Modeled Contributions at the Jeffersonville PM 2.5 Monitor

so4
no3

oc

ec soil
nh4 pbw
blan so4 33%

no3 7% oc 26% ec 4% soil 3% nh4 13% pbw 11%

blan 3% Observed 2005 Contributions at the Jeffersonville PM 2.5 Monitor

so4
no3

oc

ec soil
nh4 pbw
blan47 Chart 7.4 Modeled Contribution by Species at th e Carpenter Street – Shepherdsville, Kentucky PM 2.5 Monitor (Observed Concentrations = 14.7 μg/m 3 ) (Modeled Concentrations =12.4 μg/m 3 )

Chart 7.5 Modeled Contribution by Species at the Elizabethtown, Kentucky PM 2.5 Monitor (Observed Concentrations = 13.4 μg/m 3 ) (Modeled Concentrations =11.2 μg/m 3 ) so4 35%

no3 7% oc 24% ec 4% soil 3% nh4 13% pbw 11% blan 3% Observed 2005 Contributions at the Shepherdsville PM 2.5 Monitor

so4
no3

oc

ec soil
nh4 pbw
blan so4 28%

no3 8% oc 29% ec 5% soil 6% nh4 11% pbw 9% blan 4% 2009 Modeled Contributions at the Shepherdsville PM 2.5 Monitor

so4
no3

oc

ec soil
nh4 pbw blan

so4 29%

no3 8% oc 29% ec 4% soil 5% nh4 12% pbw 9% blan 4% 2009 Modeled Contributions at the Elizabethtown PM 2.5 Monitor

so4 no3

oc

ec soil
nh4 pbw blan so4 35%

no3 7% oc 24% ec 4% soil 3% nh4 12% pbw 11% blan 4% Observed 2005 Contributions at the Elizabethtown PM 2.5 Monitor

so4 no3

oc

ec soil
nh4 pbw blan48 Chart 7.6 Modeled Contribution by Species at the Southern Avenue – Louisville, Kentucky PM 2.5 Monitor (Observed Concentrations = 15.3 μg/m 3 ) (Modeled Concentrations =12.8 μg/m 3 )

Chart 7.7 Modeled Contribution by Species at the Wyandotte Park – Louisville, Kentucky PM 2.5 Monitor (Observed Concentrations = 15.2 μg/m 3 ) (Modeled Concentrations =12.8 μg/m 3 ) so4 35%

no3 7% oc 24% ec 4% soil 3% nh4 13% pbw 11%

blan 3% Observed 2005 Contributions at the Southern Avenue PM 2.5 Monitor

so4 no3

oc

ec soil
nh4 pbw blan so4 29%

no3 8% oc 28% ec 5% soil 5% nh4 12% pbw 9%

blan 4% 2009 Modeled Contributions at the

Southern Avenue PM 2.5 Monitor

so4 no3

oc

ec soil nh4 pbw blan

so4 34%

no3 7% oc 25% ec 4% soil 3% nh4 13% pbw 11%

blan 3% Observed 2005 Contributions at the Wyandotte Park PM 2.5 Monitor

so4 no3

oc

ec soil nh4 pbw blan so4 28%

no3 8% oc 29% ec 5% soil 5% nh4 12% pbw 9% blan 4% 2009 Modeled Contributions at Wyandotte Park PM 2.5 Monitor

so4 no3

oc

ec soil nh4 pbw blan49 Chart 7.8 Modeled Contribution by Species at the Barret Avenue – Louisville, Kentucky PM 2.5 Monitor (Observed Concentrations = 14.8 μg/m 3 ) (Modeled Concentrations =12.6 μg/m 3 )

Chart 7.9 Modeled Contribution by Species at the Watson Elementary – Louisville, Kentucky PM 2.5 Monitor (Observed Concentrations = 14.6 μg/m 3 ) (Modeled Concentrations =12.0 μg/m 3 )

Results of the Round 5 PSAT modeling for the Louisv ille Area fine particle monitors show the highest pollutant contributors to base-case and future year fine particle concentrations are sulfate, organic carbon, ammonium, and nitrat e. Future year modeling show s decreases in sulfates (due to the emission reductions from CAIR) and amm onium. The future year modeling did show slight increases in nitrates from the base-case modeled concentrations. so4 34%

no3 7% oc 25% ec 4% soil 3% nh4 13% pbw 11% blan 3% Observed 2005 Contributions at the Barret Avenue PM 2.5 Monitor

so4 no3

oc

ec soil nh4 pbw blan so4 28%

no3 8% oc 29% ec 5% soil 5% nh4 12% pbw 9% blan 4% 2009 Modeled Contributions at the Barret Avenue PM 2.5 Monitor

so4 no3

oc

ec soil nh4 pbw blan

so4 35%

no3 7% oc 23% ec 4% soil 4% nh4 13% pbw 11% blan 3% Observed 2005 Contributions at the

Watson Elementary PM 2.5 Monitor

so4 no3

oc

ec soil nh4 pbw blan so4 29%

no3 9% oc 28% ec 4% soil 5% nh4 12% pbw 9% blan 4% 2009 Modeled Concentrations at

the Watson Elementary PM 2.5 Monitor

so4 no3

oc

ec soil nh4 pbw blan50 7.4 Summary of Existing Modeling Results

U.S. EPA and LADCO modeling for future year design values ha ve consistently shown that existing national emission control measures will bri ng the Louisville Area into attainment of the annual NAAQS for fine particles. Emission contro l measures to be implemented in the next several years will help air quality meet the standard in the future. Modeling support for CAIR has shown that future year design values for the Louisville Area will conti nue to attain the annual standard for fine particles with modeled future year design values below 15 μg/m 3 . U.S. EPA future year modeling of national emission cont rol strategies, based on current design values, shows that the Louisville Area will approach the annual NAAQS fo r fine particles. Future national and local emission control strategies will ensure that the Louisville Area will maintain lower fine particle concentrations w ith an increasing margin of safety.

7.5 Meteorological Analysis for the Louisville Area

Meteorological conditions are one of the most important factors that influence development and transport of fine particles. Stagnant surface conditions during any time of the year and upper air ridging provides conducive conditions for develo pment and transport of fine particles. Ultimately, passage of surface cold fronts with a clean air mass ch ange will lower fine particle readings in the Louisville Area.

7.6 Surface Air Conditions Present during Hi gh Fine Particle Concentration Days

Higher annual concentrations of fine particles tend to correlat e with warmer temperatures and lighter wind speeds, although high fine particle ep isodes can occur in the summer or winter. It should be noted that higher annual fine particle co ncentrations are driven by individual days with higher fine particle concentrations throughout the monitored y ear. Therefore, it is difficult to attribute higher fine particle concentrations to annualized mete orological rankings. Review of several of the higher fine partic le concentration episodes over th e past few years reveals that conditions were hot in the summer with temperatures in the middle 80os Fahrenheit (oF) or higher and average wind speeds were fair ly light. Fall and winter days with higher fine particle concentrations had near normal temperatures, bu t wind speeds were very light and humidity was higher.

7.7 Upper Air Conditions Present during Hi gh Fine Particle Concentration Days

Upper air ridges and more stagnant surface wind conditions predominately affect development and build up of fine particles. Slow movi ng upper air ridges can effectively suppress mixing within the many levels of the atmosphere and caus e pollutants to build up over time. Inversions or increases in temperature with a rise in al titude will prevent mixing with air from the upper atmosphere. These conditions can occur at any time of the year and are evident in elevated fine particle episodes in spring, summer, fall, and wi nter months. Review of surface and upper air features of higher fine particle concentration days showed sta gnant surface conditions and upper air ridges existed on those days and helped in the buildup of fine particle concentrations.51 7.8 Analyses of Atmospheric Conditions duri ng High Fine Particle Concentration Days

Analyses were conducted to determine the atmos pheric conditions that ar e most prevalent during higher fine particle concentra tion days in Indiana. LADC O applied a Classification and Regression Tree (CART) analysis to data from Indiana that correla ted different le vels of fine particle concentrations to meteorological conditi ons from 1999 to 2004 (Donna Kenski, 2005). This type of analysis evaluates meteorological conditions, such as temperature, pressure, wind speed, wind direction, relative humidity, and dew poi nt temperatures at the surface, as well as morning and evening mixing heights in the upper atmosphere which were present when higher concentrations of fine particles were monitored. Results of this CART analysis indicated factors that played a larger role in higher fine partic le concentrations in Indiana were warm-weather conditions with high dew points, southwest winds, and high eveni ng mixing heights. Previous day’s concentrations of fine particles play a key role in higher impacts as well.

Fine particles are made up of severa l constituents, including direct PM 2.5 , sulfates, nitrates, ammonium, organic carbon, and elemental car bon. Depending on the time of the year, concentrations of fine particle constituents vary, with nitrates being more prevalent in the winter and sulfates more prevalent in the summer. Sulf ates and nitrates emission reductions have the biggest impact on lower future year fine particle concentrations.

7.9 Summary of Air Quality Index Days for the Louisville Area

An analysis was conducted to review the daily fine particle concentrations over a year to determine the Air Quality Index (AQI) trends . Chart 7.10 shows by year (2000 through 2010), the percentage of days during the calendar year on which fine particle concentrations reached the AQI ranges for “Good” (0 to 15.3 μg/m 3 ), “Moderate” (15.4 μg/m 3 to 40.4 μg/m 3 ), and “Unhealthy for Sensitive Groups (USG)” (40.5 μg/m 3 to 65.4 μg/m 3 ). There were no days that fine particle levels reached the “Unhealthy” level of 65.5 μg/m 3 to 150.4 μg/m 3

.

Chart 7.10 Distribution of PM 2.5 Concentration Days on th e Air Quality Index (AQI) Levels of Health Concern for the Louisville Area

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010Percentage of Days

Year

Good Moderate USG52 Table 7.6 shows how the years ranked for the th ree AQI ranges. The year 2009 had the most “Good” concentration days during the 11-year period analyzed (2000 through 2010). The year 2000 had the most “Moderate” concentration da ys and the year 2005 had the most “USG” concentration days with no days recorded in 2006, 2008, and 2009. As can be seen, weather plays a large role in fine particle concen tration development and transport as 2001, 2002, 2005, and 2007 were warmer than normal summers whic h translated to moderate and unhealthy for sensitive group levels of air quality.

Table 7.6 Ranking and Percentage of Highest Number of Days at AQI Levels of Health Concern

Ranking Good Moderate Unhealthy for Sensitive Group 1 st 2009 – 76% 2000 – 52% 2005 – 3% 2 nd 2008 – 65% 2005 – 51% 2002 – 3% 3 rd 2006 – 64% 2001 – 47% 2000 – 2% 4 th 2002 – 63% 2007 – 46% 2001 – 2% 5 th 2010 – 61% 2004 – 41% 2007 – 2% 6 th 2003 – 59% 2003 – 40% 2003 – 1% 7 th 2004 – 58% 2010 – 38% 2010 – 1% 8 th 2007 – 52% 2006 – 36% 2004 – 1% 9 th 2001 – 51% 2008 – 35% 10 th 2005 – 46% 2002 – 34% 11 th 2000 – 46% 2009 – 24%

7.10 Summary of Meteorological Anal ysis for the Louisville Area

Annual fine particle concentrations in the L ouisville Area are driven by higher fine particle concentration days that can occur during any ti me of the year. Conditions that are most prevalent during higher fine pa rticle concentration days are lighter winds, higher relative humidity, and above average temperatures in th e summer, and near normal temperatures in the fall, winter, or spring. Approxima tely 70% of the days when PM 2.5 concentrations were in the USG range occurred in the summer months with maximum high temperatures of 80oF or above. Weather plays a large role in fine particle concentration de velopment and transport as 2001, 2002, 2005, and 2006 were warmer than normal summer s which translated to more days of “moderate and unhealthy for sensitive group” levels of air quality and near normal temperatures in the fall, winter, or spring. Upper air weathe r patterns generally include ridging over the area with stagnant conditions at th e surface caused by lower mixing he ights and stable conditions for summer episodes and ridging or troughs over the ar ea in the fall, winter, or spring episodes. Surface winds from any direction can transpor t pollutants from surrounding areas into the Louisville Area. Nitrates are bigg er contributors to fine particle concentrations in the winter and sulfates are bigger contribut ors to fine particle con centrations in the summer.53 8.0 CORRECTIVE ACTIONS

8.1 Commitment to Revise Plan

As noted in Section 4.6, IDEM commits to review and revise, as appropriate, its Maintenance Plan eight years after re designation, as required by S ection 175A of the CAA

. 8.2 Commitment for Contingency Measures

IDEM will monitor fine particle concentrations to determine whether trends indicate higher values or whether emissions appear to be increasing. If it is determ ined that fine particle levels and emissions are increasing and action is necessary to reverse that trend, IDEM will take action to reverse the noted trend, prior to a violation of th e standard occurring.

IDEM commits to adopt and expeditiously impl ement necessary corrective action in accordance with an Action Level Response described below.

Action Level Response

An Action Level Response shall be prompted when ever a violation of th e standard (three-year average annual arithmetic mean value of 15.1 μg/m 3 or greater) occurs. In the event that the Action Level is triggered and is not found to be due to an atypical unfavorable meteorological condition, exceptional event, malfunction, or noncompliance with a permit condition or rule requirement, IDEM will determine additional co ntrol measures needed to assure future attainment of the annual NAAQS for fine partic les. In this case, measures that can be implemented in a short time will be selected in order to be in place within eighteen months from the end of the year that prom pted the Action Level Response.

Control Measure Select ion and Implementation

Adoption of any additional control measures is subject to the necessary administrative and legal processes. This process will include publication of notices, an opportunity for public hearing, and other measures required by Indiana law fo r rulemaking by state environmental boards.

If a new measure or control is already promulgated and schedul ed to be implemented at the federal or state level, and that measure or contro l is determined to be sufficient to address the upward trend in air quality, additi onal local measures may be unn ecessary. Furthermore, IDEM will submit to U.S. EPA an analysis to demonstrate that the proposed measures are adequate to return the area to attainment.

8.3 Contingency Measures

Contingency measures to be considered will be se lected from a comprehensive list of measures deemed appropriate and effective at the time the selection is made. Listed below are example measures that may be considered. The se lection of measures will be based upon costeffectiveness, emission reduction po tential, economic and social c onsiderations, or other factors54 that IDEM deems appropriate. ID EM will solicit input from intere sted and affected persons in the maintenance area prior to selecting appropria te contingency measures. All of the listed contingency measures are potentially effectiv e or proven methods of obtaining significant reductions of fine particle precursor emissions. Because it is not possible at this time to determine what control measure will be appropriate at an unspecified time in the future, the list of contingency measures outlined below is not comprehensive. IDEM anticipates that if contingency measures should ever be necessary, it is unlikely th at a significant number (i.e., all those listed below) will be required.

1) Vehicle inspection an d maintenance program. 2) Alternative fuel and diesel retrofit programs for fleet vehicle operations. 3) Require NO x or SO 2 emission offsets for new and modified major sources. 4) Require NO x or SO 2 emission offsets for new and modified minor sources. 5) Increase the ratio of emission of fsets required for new sources. 6) Require NO x or SO 2 controls on new minor sour ces (less than 100 tons). 7) Wood stove change out program. 8) Various emission reduction measures or dust suppressant for unpaved roads and/or parking lots. 9) Idling Restrictions. 10) Broader geographic applicab ility of existing measures. 11) One or more transportation control meas ures sufficient to achieve at least a 0.5% reduction in actual area-wide precursor emi ssions. Transportation measures will be selected from the following, based upon the f actors listed above, af ter consultation with affected local governments: a) Trip reduction programs, includi ng, but not limited to, employer-based transportation management plans, area wide rideshare programs, work schedule changes, and telecommuting. b) Transit improvements. c) Traffic flow improvements. d) Other new or innovative transportation m easures not yet in widespread use that affected state and local governments deem appropriate.

No contingency measure shall be implemented w ithout providing the opportunity for full public participation during which the relative costs and be nefits of individual meas ures, at the time they are under consideration, can be fully evaluated.

9.0 PUBLIC PARTICIPATION

Indiana published notification for a public hearing and soli citation for public comment concerning the draft Redesignation Petition and Maintenance Plan on IDEM’s website 8 on April 27, 2011, with publication in the followi ng newspapers on the following dates:

8 http://www.in.gov/idem/4658.htm55 1) The Indianapolis Star, Indi anapolis, Indiana (May 5, 2011). 2) The New Albany Tribune, New Albany, Indiana (April 26, 2011). 3) The Evening News, Jeffersonvi lle, Indiana (April 26, 2011). 4) The Madison Courier, Madi son, Indiana (April 22, 2011).

A public hearing to receive comments concerning the redesignation reque st was conducted on May 26, 2011, at the Jefferson Township Public Li brary, Clarksville Branch in Clarksville, Indiana. No comments were received at the public hearing. The public comment period closed on May 29, 2011. One comment letter was receiv ed during the public comment period. Appendix K includes a copy of the public notice, public hearing script , certifications of newspaper publication of the public notice, the o fficial transcript from the public hearing, and a detailed summary of and response to substantive comments.

10.0 CONCLUSIONS

Jefferson County (Madison Township) and Clark and Floyd counties, Indiana, have attained the annual NAAQS for fine particles. This petiti on demonstrates that Jefferson County (Madison Township) and Clark and Floyd counties, Indiana, have complied with the applicable provisions of the CAA regarding redesigna tion of nonattainment areas for fine particles. IDEM has prepared a State Implementation and Maintenance Plan that meets the requirement of Section 110(a)(1) of the CAA.

Indiana has performed an analysis that shows the air quality imp rovements are due to permanent and enforceable measures and that additional significant regional NO x and SO 2 reductions following implementation of the Phase II NO x SIP Call rule and CAIR or its replacement rule will ensure continued compliance (maintenance) with the standard. Furthermore, emission projections indicate that NO x and SO 2 emissions will continue to decline, ensuring that the area continues to maintain compliance with the sta ndard and provide for an increased margin of safety. Based on this presentation, Jefferson Co unty (Madison Township) and Clark and Floyd counties, Indiana, meet the requirements fo r redesignation under the CAA (Section 107(d)(3)) and U.S. EPA guidance for fine particles.

Consistent with the authority granted to U.S. EPA, the State of Indiana requests that Jefferson County (Madison Township) and Clark and Floy d counties, Indiana, be redesignated to attainment for the annual fine particles standard simultaneously with U.S. EPA approval of this State Implementation and Maintenance Plan.