### State of Wisconsin

DEPARTMENT OF NATURAL RESOURCES

101 S. Webster Street

Box 7921

Madison WI 53707-7921



### May 30,2013

Ms. Susan Hedman Regional Administrator

U

. S. Environmental Protection Agency (EPA)

77 West Jackson Boulevard, R-19J Chicago IL 60604-3507 Scott Walker, Governor Cathy Stepp, Secretary

Telephone 608-266-2621

Toll Free 1-888-936-7463

TTY Access via relay

- 711



### Subject: Milwaukee-Racine Redesignation Request- Supplemental Information

Dear Ms. Hedman:

The Wisconsin Department of Natural Resources (WDNR) hereby submits draft supplemental State Implementation

Plan (SIP) information for Wisconsin's outstanding fine particulate matter (PM 25 ) 

### Milwaukee-Racine Nonattainment

Area redesignation request. The WDNR originally submitted a redesignation request for this nonattainment area to
the U.S. EPA on June 5, 2012 for the 2006 24-hour PM 2

. 5 

### National Ambient Air Quality Standard (NAAQS). All of

the PM 2

. 5 

### monitors in this area have been measuring attainment of the 2006 24-hour PM 25 

### NAAQS since 2010.

The WDNR requests that the U.S. EPA begin parallel processing the regulatory review of this supplemental SIP

information while the state completes the required public input and legislative review process. The WDNR will

submit the fmal information to the U.S. EPA once the following regulatory steps are completed:

• Conclusion of Wisconsin Legislative Review: July 1

, 2013

• Public Hearing: July 8

, 2013, 11 :OOam

, at WDNR Southeast Region Headquarters

• Conclusion of Public Comment Period: July 10

, 2013

The WDNR has the legal authority under Wisconsin law to adopt a nd implement these requested SIP revisions.

Section 285.11 (6)

, Wis. Stats

., authorizes th e WDNR to dev e lop and revise th e SIP for prevention, abatement, and

control of air pollution . A copy of the public h eari n g notice is includ ed as an attachment. In accordance with th e April 6, 2011 McCabe Memo, one paper copy of th e SIP revision documents is enclosed

. In addition, an e lectroni c

copy of these documents is provided as well on an enclosed CD. If you have any questions regarding this submittal

, please feel free to call Joseph Hoch at (608) 267-7543 or Ralph Patterson at (608) 267-7546.

cc: WDNR: Patrick Stevens (AD/8), Joseph Hoch (AM/7)

, Ralph Patterson (AM/7)

U.S

. E PA Re g ion V (77 West Jackson Boul ev ard

, C hic ag o
, IL 60604) :
G e or g e Czerniak (A-18J), John Moon ey (A- 18J)

, Dou g l as Abur a no (AR-18J)

, Jacqu e line Nwia (AT

- 18J)

attachments: (1) EPA Region V SIP Submittal Checklist

, (2) Public Hearing Notice

, (3) Supplemental SIP Information

dnr.wi.gov wisconsin

. gov 

## Naturally 

# WISCONSIN PRINT ED ON RECYCLED PAP

ER

## SUPPLEMENTAL INFORMATION FO R A JUNE 2012 REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE 24-HOUR FINE

PARTICULATE MATTER NATION AL AMBIENT AIR QUALITY

STANDARD

FOR THE

MILWAUKEE-RACINE 3-COUNTY

NONATTAINMENT AREA

WISCONSIN

Developed By: The Wisconsin Department of Natural Resources

May 2013

## Table of Contents

Supplemental Emissions Inventory Information for Ammonia (NH 3 

### ) 1

Supplemental Design Value Modeling 312007 Ammonia (NH3) Emissions in Milwaukee, Racine, and Waukesha CountiesSectorNH3Emissions(tons)Percentof TotalSectorNH3Emissions(tons)Percentof TotalSectorNH3Emissions(tons)Percentof TotalEGU Point 1.82 0.07%Point 32.33 1.23%Stationary 1,960.58 74.22%Non-EGU Point 30.51 1.15%Area 613.34 23.22%Area 1,928.25 72.99%Agricultural NH31,314.91 49.78%Onroad 673.17 25.48% Onroad 673.17 25.48%Mobile 681.09 25.78%Nonroad 7.08 0.27%Nonroad 7.92 0.30%MAR 0.84 0.03%CountyNH3Emissions(tons)Percentof TotalMilwaukee 979.51 37.08%Racine 832.54 31.52%Waukesha 829.62 31.41%NotesThese NH3emissions were developed by the Lake Michigan Air DirectorsConsortium (LADCO). Documentation regarding how these emissionswere calculated can be found at:http://www.ladco.org/tech/emis/basecv8/Base_C_Emissions_Documentation_Sept_12.pdf.EGU = Electric Generating UnitMAR = Marine, Aircraft, and Rail2Total Statewide Wisconsin Ammonia (NH3) Emissions – 2005, 2007, & 2018NotesLADCO only provided onroad estimates (i.e., “MOVES”) for 2007 emissions. These emissions were assumed to be the same for 2005and 2018.These onroad emissions are less than 3% of the total estimated NH3emissions for each of the three years shown.Agricultural NH3emissions account for 95%, 94%, and 94% of total statewide NH3emissions in 2005, 2007, and 2018, respectively.In 2007, the NH3emissions in the Milwaukee-Racine Nonattainment Area were estimated to be 2,641.66 tons. This is only 2.2% of the statewidetotal NH3emissions (120,941 tons) in 2007.

### 3 

## DAILY FINE PARTICULATE MATTER (PM 2.5 

## ) DESIGN VALUE MODELING

The Wisconsin Department of Natural Resources (WDNR) reviewed the latest future year design value modeling developed by the Lake Michigan Air Directors Consortium (LADCO) for PM 2.5 in the Milwaukee-Racine Nonattainment Area. This information is summarized on Page 11 of “ Appendix B – Regional Air Quality Analyses for Ozone, PM 2.5 , and Regional Haze ” of a Final Technical Support Document dated September 25, 2008. LADCO provided design values for 2009, 2012, and 2018. The WDNR specifically considered the design values from the

“with CAIR” scenarios for the discu ssion contained in this paper.

2009 - 2012

A comparison of modeled PM 2.5 design values and air monitoring conducted by the WDNR for 2008 – 2012 is shown on the following page. The primary takeaways are as follows:

 Design values calculated from WDNR air monitoring data are below LADCO modeled design values.

 Downward trends from 2008 through 2012 for air mon itoring sites where data is available from WDNR air monitoring are steeper than was anticipated by the 2008 LADCO modeling.

2018

LADCO also developed 2016 – 2018 PM 2.5 design values as part of their 2008 PM 2.5 modeling. The design values

are as follows:

Site Name Site Id 2016 – 2018 Design Value MILWAUKEE SIXTEENTH ST. HEALTH CENTER 550790010 33 μg/m 3
MILWAUKEE SER DNR HDQRS 550790026 33 μg/m 3

MILWAUKEE VIRGINIA STREET FI RE STATION 5 50790043 36 μg/m 3
MILWAUKEE FIRE DEPT HDQRS 550790099 32 μg/m 3
WAUKESHA CLEVELAND AVE 551330027 29 μg/m 3

All of the 2016 – 2018 Milwaukee-Racine Nonattainment Area design values are below the 2006 24-Hour PM 2.5 National Ambient Air Quality Standard (NAAQS) of 35 μg/m 3 , except for the projected design value at the WDNR’s Milwaukee Virginia Street Fi re Station air monitoring location.

The U.S. Environmental Prot ection Agency (EPA) recently updated its Mo deled Attainment Test Software (MATS) from Version 2.3.1 to 2.5.1. The 2008 LADCO modeling relied on the older MATS version to develop the 2016 –

2018 PM 2.5 design values. In consultation with the U.S. EPA and LADCO, the WDNR reproduced the 2008 LADCO future year modeling using both MATS versions and found that the projected 2016 – 2018 design value dropped from 35.8 μg/m 3 to 33.0 μg/m 3 at the WDNR’s Virginia Street Fire Station air monitoring location when using the latest software. The WDNR confirmed this result (i.e., lower design value) with the U.S. EPA.4Milwaukee Virginia Street Fire Station (Site Id: 550790043)2007 – 2009 (LADCO 2008 Modeling): 38 μg/m32008 – 2010 (LADCO 2008 Modeling): 37.33 μg/m32009 – 2011 (LADCO 2008 Modeling): 36.67 μg/m32010 – 2012 (LADCO 2008 Modeling): 36 μg/m32007 – 2009 (WDNR – Air Monitoring): 36 μg/m3This site was discontinued on 12/31/2009.Milwaukee Fire Department Headquarters (Site Id: 550790099)2007 – 2009 (LADCO 2008 Modeling): 33 μg/m32008 – 2010 (LADCO 2008 Modeling): 32.67 μg/m32009 – 2011 (LADCO 2008 Modeling): 32.33 μg/m32010 – 2012 (LADCO 2008 Modeling): 32 μg/m32007 – 2009 (WDNR – Air Monitoring): 36 μg/m3This site was discontinued on 12/31/2009. It was restarted in 2012.Note: 2008 – 2010 & 2009 – 2011 design values for the LADCO 2008 modeling are interpolated since only 2007 – 2009 & 2010 – 2012 were developed.

### BEFORE THE

DEPARTMENT OF NATURAL RESOURCES

Notice of Public Hearing

Supplemental Information for Wisconsin’s Fine Particulate Matter (PM 2.5 

### ) Redesignation Request

for the Milwaukee-Racine Nonattainment Area

NOTICE IS HEREBY GIVEN that pursuant to ss. 285.11(5) and (6) and 285.23(2) and (4), Wis.

Stats. , and ch. NR 401, Wis. Adm. Code , the Wisconsin Department of Natural Resources will hold a public hearing on supplemental information it plans to submit to the U.S. Environmental Protection Agency (EPA) in support of a redesignation request that was submitted on June 5, 2012.

Background

The Department submitted a redesignation request for the Milwaukee-Racine Nonattainment Area to the U.S. EPA on June 5, 2012 for the 2006 24-hour PM 2.5 

### National Ambient Air Quality Standard (NAAQS).

The Milwaukee-Racine Nonattainment Area includes th e counties of Milwaukee, Racine, and Waukesha. In light of two recent decisions from the United States Court of Appeals for the District of Columbia ( EME Homer City Generation, L.P. v. EPA issued on August 21, 2012 and Natural Resources Defense

Council v. EPA issued on January 4, 2013), the U.S. EPA requested additional information before it could make a regulatory decision on the Department’s outst anding redesignation request. The Department is taking comment on an ammonia (NH 3 

### ) emissions inventory and PM 2.5 

### design value modeling for the

Milwaukee-Racine Nonattainment Area.

NOTICE IS HEREBY FURTHER GIVEN that th e public hearing will be held on:

Monday, July 8, 2013 at 11:00 a.m. WI DNR Southeast Region Headquarters, Room 140 - 141 2300 N. Dr. Martin Luther King Jr. Drive Milwaukee, WI

NOTICE IS HEREBY FURTHER GIVEN that pursu ant to the Americans with Disabilities Act, reasonable accommodations, including the provision of informational material in an alternative format, will be provided for qualified individuals with disabilities upon request. Please call Mr. Joseph Hoch at (608) 267-7543 with specific information on your request at least 10 days before the scheduled hearing.

Written Comments and Copies of Documents

Written comments on the PM 2.5 

### redesignation request supplemental information may be submitted to Mr. Joseph Hoch, Bureau of Air Management AM/7, P.O. Box 7921, Madison, WI 53707 no later than July 10, 2013 . Comments may also be submitted electroni cally to joseph.hoch@wisconsin.gov. Written comments will have the same weight and effect as or al statements presented at the hearing. The PM 2.5 

### redesignation request supplemental information may be obtained by contacting Mr. Joseph Hoch at (608) 267-7543 or downloaded from http://dnr.w i.gov/topic/AirQuality/Particles.html.

Dated at Madison, Wisconsin May 22, 2013

STATE OF WISCONSIN

DEPARTMENT OF NATURAL RESOURCES

By /s/ Matt Moroney for Cathy Stepp, Secretary

# EPA Region V


# Wisconsin SIP Submittal Completeness Review

Submittal Letter

1. Signed by Governor’s Designee (Bart Sponseller)? Yes X No

2. Date of Submittal: May 30, 2013

3. WDNR Person in charge of SIP submittal. Name: Ralph Patterson Telephone Number: (608) 267-7546 Fax Number: (608) 267-0560

E-mail Address: Ralph.Patterson@wisconsin.gov

4. WDNR Technical Person in charge of answering questions on SIP Submittal Name: Joseph Hoch Telephone: (608) 267-7543 Fax Number: (608) 267-0560

E-mail Address: Joseph.Hoch@wisconsin.gov


# Incorporation Into Wisconsin Administrative Code

5. Is evidence that the State incorporated the revision into the Wisconsin Administrative Code supplied in this SIP package?

Yes No X (if No, explain)

Not applicable. This is not a rule submittal and therefore requires no incorporation into the Wisconsin

Administrative Code.

6. The effective date of the regulation is or was: Not applicable

7. Are test methods/rules incorporated by reference correctly? (Has approval been obtained from the state Attorney General

Yes No (if No, explain answer) Not applicable X (if No t applicable, explain answer)

This is not a rule submittal and therefore the Attorney General need not approve this submittal.

8. Has WDNR provided evidence that it has necessary legal authority under State law to adopt and implement the revision? Provide additional explanation (if necessary).

Yes X

No2

9. Did the State include a copy of the actual regula tion or document for USEPA review? Provide additional explanation (if necessary).

Yes X

No

10. Did the State provide evidence that it followed all of the requirements of its Administrative Procedures Act (ch. 227, Wis. Stats., Administrative Procedure and Review) in conducting and completing adoption/issuance of the revision? Provide additional explanation (if necessary).

Yes

No X

Not applicable.

11. Did the State include evidence that Public Notice was given of the revision, including date of publication? Provide additional explanation (if necessary).

Yes X

No

The state provided a copy of the public hearing noti ce and newspaper publication of the upcoming (July 8, 2013) public hearing.

12. Did the State provide a copy of the certification that public hearings were held in accordance with the information provided in the public notice (copy of not arized Class I paper proof). Provide additional explanation (if necessary).

Yes

No X

This was not submitted yet because the state is as king the U.S. EPA for parallel processing of the supplemental SIP information and the public hearing has not yet occurred. This can be provided after the conclusion of the public hearing and comment period.

13. Does the submittal contain a compilation of public co mments and the State’s res ponse? Provide additional explanation (if necessary).

Yes

No X

This was not submitted yet because the state is as king the U.S. EPA for parallel processing of the supplemental SIP information and the public hearing has not yet occurred. This can be provided after the conclusion of the public hearing and comment period.



# Technical Issues

14. Name all the regulated pollutants affected by the revision.

Ammonia (NH 3 )3

15. Does the submittal identify the designation, status of the attainment plan and attainment date for the area(s)? Provide additional explanation (if necessary).

Yes X

No

16. Does the submittal identify the location and types of affected sources? Provide additional explanation (if necessary).

Yes

No X

Not applicable since this SIP submittal is not a rule.

17. Does the submittal quantify the changes in SIP-allowable emissions and estimate or quantify the changes in

actual emissions from affected sources? Provi de additional explanation (if necessary).

Yes X

No

NH 3 emission inventories are presented for 2005, 2007, and 2018.

18. Has the State demonstrated that the NAAQS/PSD In crement/RFP demonstration/vi sibility will be protected if the revision is approved and implemented? Provide additional explanation (if necessary).

Yes X

No

19. Has the State provided modeling information to support the revision.

Yes

No Unnecessary X

20. Has the State provided evidence that emission limitations are based on continuous emission reduction technology? Provide additional explanation (if necessary).

Yes

No X

Not applicable.

21. Has the State provided evidence that the revision contains emission limitations, work practice standards and record keeping/reporting requirements where necessa ry, to ensure emission levels? Provide additional explanation (if necessary).

Yes

No X

Not applicable.4

22. Does the submittal contain enforcement/compliance strategies including how compliance will be determined in practice, and at what frequency? Provide additional explanation (if necessary).

Yes

No X

Not applicable.5



# STATE APPROVABILITY CHECKLISTENFORCEABILITY

USEPA USE ONLY

SIP Package Number ___________ Date Received by USEPA ________________
Date Due_____________________________

State: WISCONSIN6



# WDNR Information

Subject Matter: Ozone Redesignation Request and Maintenance Plan for the MilwaukeeRacine Nonattainment Area and the Sheboygan County Nonattainment Area



## Applicability

USEPA Question USEPA Requirement State Response

What sources are being regulated? Clear discussion No sources are being regulated under the SIP submittal. This is not a rulemaking.

What are criteria for exemption? Clear discussion This is not applicable to this SIP submittal.

Is calculation procedure for exemption clearly specified? Supply example calculation or clear explanation of how to determine exemption (line by line, etc.) This is not applicable to this SIP submittal.

Is emission inventory listed in the background

document of the

attainment demonstration? Inventory including allowable

and actual emissions in source category should be included, for enforcement purposes and independent of any Clean Air Act requirements, in the

attainment demonstration if such data is necessary for determining baselines in regulations. Yes. Wisconsin is submitting 2005, 2007, and 2018 NH3 emission inventories as part of this

SIP submittal.

Is the averaging time(s)

used in the rule different

from that of the ambient

standard? The averaging time in the rule

must be consistent with protecting the ambient standard in question. Normally, it should be equal to or shorter than the

time associated with the standard. Longer term averaging is available only in limited instances provided that

the ambient standard is not compromised. This is not applicable to this SIP submittal.

What are the units of compliance (lbs VOC per gallon of solids applied less water, grains per standard cubic foot?) Clearly stated in the rule. This is not applicable to this SIP submittal.7



### USEPA Question USEPA Requirement State Response

Is bubbling or averaging of any type allowed? If yes, state criteria. Could a USEPA inspector independently determine

if the criteria were met??

Does USEPA have to approve each case? Explicit description of how averaging, bubbling, or equivalency is to be determined. VOC equivalency must be on a “solids applied” basis. Any method must be independently reproducible. Provision must be explicit as to whether USEPA case-by-case approval is required. If provision intended to be “generic” then USEPA bubble policy must be

met. This is not applicable to this SIP submittal.

If there is a redesignation, will this change the

emission limitations? If yes, which ones and how? Regulation may not automatically allow for self nullification upon redesignation

of area to attainment. New

maintenance demonstration required to order to drop regulation. This is not applicable to this SIP submittal. This is not a rulemaking.



## Compliance Dates

USEPA Question USEPA Requirement State Response

What is the compliance

date? The compliance date must not be later than the approved or about to be approved date of

attainment unless emission reductions are not necessary for attainment. In some cases, it will be necessary for the regulation to specify dates in compliance schedules that are required to be submitted by

source to state. This is not applicable to this SIP submittal. This is not a rulemaking.

What is the attainment

date? Clearly defined. This is not applicable to this SIP submittal. This is not a rulemaking.



## Specificity of Conduct

USEPA Question USEPA Requirement State Response

What test method is required? Test method must be explicitly

stated. This is not applicable to this SIP submittal.

What is the averaging time in the compliance test

method? Averaging time and application of limit must be explicit. This is not applicable to this SIP submittal.

Is a compliance

calculation or evaluation required? (i.e., daily weighted average for Clearly defined. This is not applicable to this SIP submittal.8



### USEPA Question USEPA Requirement State Response

VOC). If a compliance calculation is necessary, list the formula, period of compliance, and/or

evaluation method. Formula must be explicit. This is not applicable to this SIP submittal.



## Incorporation by Reference

USEPA Question USEPA Requirement State Response

What is the state authority for rulemaking. Clearly stated. This is not applicable to this SIP submittal. This is not a rulemaking.

Are methods/rules incorporated by reference in the right manner? Clearly stated. This is not applicable to this SIP submittal. This is not a rulemaking.



## Recordkeeping

USEPA Question USEPA Requirement State Response
What records are required to determine compliance? Clearly stated. This is not applicable to this SIP submittal. This is not a rulemaking.

In what form or units (lbs/gal, gr/dscf, etc.) must the records be kept? On

what time basis (instantaneously, hourly daily)? Records to be kept must be

consistent with units of compliance in the performance requirements, including the applicable time period . This is not applicable to this SIP submittal.

Does the rule affirmatively require the records be kept? There must be clearly defined and distinguishable from what

constitutes a violation. This is not applicable to this SIP submittal.



## Exemptions

USEPA Question USEPA Requirement State Response

List any exemptions

allowed. Must be clearly defined and distinguishable from what

constitutes a violation. This is not applicable to this SIP submittal.

Is the criteria for application clear? Clearly stated. This is not applicable to this SIP submittal.



## Malfunction Provisions

USEPA Question USEPA Requirement State Response

Are there any malfunction provisions in the rule? Rule must specify what exceedances may be excused,

how the standard is to be applied, and who makes the

determination. This is not applicable to this SIP submittal.9