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.IN.gov

Date: March 10, 2011 ,

Ms. Susan Hedman

Regional Administrator

U.S. Environmental Protection Agency

Region 5

77 West Jackson Boulevard

Chicago, IL 60604-3950

Re: Supplement to the Indiana Regional Haze

State Implementation Plan (SIP) submittal

Dear Ms. Hedman:

Enclosed is a supplement to Indiana's Regional Haze SIP submittal, dated

January 14, 2011. These materials include documentation of the public involvement

process. There were no public comments received by IDEM, however comments from

the National Park Service and United States Forest Service are included.

IDEM has worked closely with the Lake Michigan Air Directors Consortium

(LADCO), other regional planning organizations, Federal Land Managers (FLMs), the

United States Environmental Protection Agency (U.S. EPA), and other states to address

the requirements of the Regional Haze rule.

IDEM requests that the U.S. EPA proceed with review and approval of this

submittal. The complete Regional Haze SIP document has been provided for your

convenience. If you have any questions or need additional information, please contact

Scott Deloney, Chief, Air Programs Branch, at (317).233-5694.

Sincerely,

tJLB~r Keith Baugues

Assistant Commissioner

Office of Air Quality

KB/jb

Attachments

Cc: John Summerhays, U.S. EPA Region 5 (wI enclosures)

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

Scott Deloney, IDEM (no enclosures)

Christine Pedersen, IDEM (no enclosures)

Recycled Paper (i) An Equal Opportunity Employer Please Recycle U
Indiana Regional Haze State Implementation 

Plan 

Developed By: 

The Indiana Department of Environmental Management 

November 2010
i 

Table of Contents

1.0 Introduction and Background ......................................................................................... 1

2.0 Regional Planning ............................................................................................................. 3

3.0 Indiana and Federal Land Manager Coordination ....................................................... 7

4.0 Development of Reasonable Progress Goals ................................................................... 8

4.1 Assessment of Baseline (or Current) Conditions and Estimate of Natural Conditions 

(in Class 1 Areas) ........................................................................................................... 10

4.2 Glidepaths to Natural Conditions in 2064 .................................................................... 11

4.3 Letters Requesting Participation in Consultation Process from States with Class 1 

Areas................................................................................................................................. 12

5.0 Emissions Inventory ....................................................................................................... 12

5.1 Base Year Emissions ....................................................................................................... 12

5.2 On-road Mobile ............................................................................................................... 13

5.3 Nonroad Mobile .............................................................................................................. 14

5.4 Area Sources .................................................................................................................... 14

5.5 Point Sources – Electric Generating Units (EGUs) ..................................................... 15

5.6 Point Sources – Non-EGU .............................................................................................. 15

5.7 Other Improvements ...................................................................................................... 15

5.8 Future Year Emissions ................................................................................................... 18

6.0 Modeling Assessment ...................................................................................................... 23

6.1 Regional Haze/Visibility ................................................................................................. 24

6.2 Regional Haze Modeling Results ................................................................................... 26

7.0 Reasonable Progress Goals ............................................................................................ 30

7.1 Background ..................................................................................................................... 30

7.2 Voyageurs National Park and Boundary Waters Canoe Area Wilderness Area ..... 30

7.3 Mammoth Cave National Park ...................................................................................... 31

7.4 Great Smoky Mountains National Park ....................................................................... 32

7.5 Sipsey Wilderness Area .................................................................................................. 33

7.6 James River Face Wilderness Area, Shenandoah National Park, Dolly Sods/Otter 

Creek Wilderness Areas ................................................................................................. 34

7.7 Caney Creek and Upper Buffalo Wilderness Areas, AR, and Hercules-Glades and 

Mingo Wilderness Areas, MO ....................................................................................... 36

7.8 Isle Royale National Park and Seney National Wildlife Refuge, MI ......................... 38

7.9 Acadia National Park, ME, Moosehorn Wilderness Area, ME, Great Gulf 

Wilderness Area, NH, Brigantine Wilderness Area, NJ, and Lye Brook Wilderness 

Area, VT (MANE-VU) ................................................................................................... 40

8.0 Best Available Retrofit Technology ............................................................................... 42

8.1 BART - Eligible Sources in Indiana .............................................................................. 43

8.2 Sources Subject to BART ............................................................................................... 44

8.3 BART Analysis ................................................................................................................ 52

8.4 BART Determination and Modeling for Burns Harbor ............................................. 52

8.4.1 IDEM’s BART Determination Process ......................................................................... 53

8.4.2 IDEM’s BART Modeling Process.................................................................................. 54

8.4.3 Modeling Domain and Meteorology .............................................................................. 54

8.4.4 Class 1 Areas ................................................................................................................... 55
ii 

8.4.5 Visibility Impairment Pollutants Analyzed .................................................................. 55

8.4.6 IDEM’s Subject to BART Determination Modeling Results ..................................... 56

8.4.7 IDEM’s Culpability Modeling Results for Burns Harbor ......................................... 57

8.4.8 Burns Harbor’s BART Determination Modeling ........................................................ 57

8.4.9 Comparison of Burns Harbor and IDEM BART Determination Modeling ............. 59

8.4.10 Summary of Burns Harbor BART Determination Analysis ....................................... 60

8.5 BART Determination and Modeling for ESSROC Cement Corporation - Speed.... 61

8.5.1 IDEM’s BART Determination Process ........................................................................ 62

8.5.2 ESSROC’s BART Determination Modeling Results ................................................... 64

8.5.3 IDEM’s BART Determination Modeling Results ....................................................... 64

8.5.4 Summary of ESSROC BART Determination Analysis ............................................... 65

8.6 BART Determination and Modeling for SABIC Innovative Plastics – Mount 

Vernon Modeling Project Overview .............................................................................. 65

8.6.1 IDEM’s BART Determination Process ......................................................................... 66

8.6.2 Visibility Impairment Pollutants Analyzed .................................................................. 67

8.6.3 SABIC’s BART Determination Modeling Results ....................................................... 68

8.6.4 IDEM’s BART Determination Modeling Results ........................................................ 69

8.6.5 Summary of SABIC BART Determination Analysis ................................................... 70

8.7 BART Determination and Modeling for Alcoa ............................................................ 70

8.7.1 Summary of Alcoa BART Analysis ............................................................................... 71

8.7.2 BART-eligible units at Alcoa ......................................................................................... 71

8.7.3 BART Analysis ................................................................................................................ 72

8.7.4 Control Strategy .............................................................................................................. 72

8.7.5 Discussion......................................................................................................................... 74

8.8 Indiana BART Rule ........................................................................................................ 80

9.0 Long Term Strategy ........................................................................................................ 80

9.1 Strategy requirements .................................................................................................... 80

9.2 Strategy ............................................................................................................................ 80

9.3 Future Activities ............................................................................................................. 83

10.0 State Implementation Plan Revisions and Adequacy of the Existing Plan................ 83

10.1 State Implementation Plan Revisions............................................................................ 83

10.2 Determination of the Adequacy of the Existing Plan .................................................. 83

11.0 Public Participation ........................................................................................................ 84

List of Tables 

Table 1 Impacts of LADCO States upon Class I Area ................................................................ 5 

Table 2 Calls and Meetings Regarding Class 1 Areas ................................................................. 7

Table 3 Summary of On-road Emissions (Tons Per Day – July 15, 2005) ............................... 20

Table 4 EGU Emissions for Base (5a), Will Do (5b), and May Do (5c) Scenarios .................. 21

Table 5 Emissions Summaries ................................................................................................... 22

Table 6 Class 1 Areas Modeled by the MRPO .......................................................................... 23

Table 7 Visibility Modeling Results (Deciviews) for Class 1 Areas in Eastern U.S. (Worst 

20%) ............................................................................................................................. 29

Table 8 Visibility Modeling Results (Deciviews) for Class 1 Areas in Eastern U.S. (Best 20%)

 ...................................................................................................................................... 29
iii 

Table 9 MRPO Round 5 Modeling Results (dv) ....................................................................... 42

Table 10 Indiana Sources with BART-Eligible Units ................................................................. 43

Table 11 Indiana BART-eligible Electric Generating Units covered by CAIR .......................... 45

Table 12 IDEM’s Revised CALPUFF Modeling Results for Burns Harbor ............................... 56

Table 13 Number of Modeled Days over 0.5 dvs for Class 1 Areas ........................................... 56

Table 14 IDEM’s Culpability Modeling Results for Burns Harbor ............................................ 57

Table 15 Comparison of Ammonia Concentrations (ppb) for CALPUFF modeling for 

ArcelorMittal................................................................................................................. 58 

Table 16 Burns Harbor’s CALPUFF Modeling Results over 0.5 Dv .......................................... 59

Table 17 Number of Modeled Days over 0.5 dv for Class 1 Areas ............................................. 59

Table 18 IDEM’s Revised CALPUFF Modeling Results at Seney ............................................. 60

Table 19 BART-eligible Stack Parameters for Burns Harbor ..................................................... 61

Table 20 BART Emission Rates for ESSROC - Speed ............................................................... 63

Table 21 BART-eligible Stack Parameters for ESSROC - Speed ............................................... 64

Table 22 ESSROC – Speed’s CALPUFF Modeling Results ....................................................... 64

Table 23 IDEM’s Revised CALPUFF Modeling Results for ESSROC - Speed ......................... 65

Table 24 BART Emission Rates for SABIC................................................................................ 67

Table 25 BART-Eligible Stack Parameters for SABIC ............................................................... 68

Table 26 SABIC’s CALPUFF Modeling Results over 0.5 dv ..................................................... 69

Table 27 IDEM’s Revised CALPUFF Modeling Results for SABIC ......................................... 70

Table 28 Summary of Visibility Modeling Analysis ................................................................... 73

Table 29 Summary of emissions impact of various control scenarios ......................................... 73

Table 30 Alcoa Proposed BART Control Strategy ...................................................................... 76

Table 31 Alcoa Proposed BART Emission Limits ...................................................................... 77

Table 32 Highest Contribution from BART-eligible Units in any Modeling Scenario ............... 78

Table 33 Source Culpability for the Highest Baseline Impact .................................................... 79

Table 34 Indiana EGUs Megawatts with SO2 Controls, Comparison of Actual or Projected 

Controls to Projections Made in EPA IPM Runs and Scenarios Modeled by 

LADCO..........................................................................................................................81 

Table 35 Indiana EGUs Megawatts with NOx Controls, Comparison of Actual or Projected 

Controls to Projections Made in EPA IPM Runs and Scenarios Modeled by 

LADCO..........................................................................................................................82 

List of Figures 

Figure 1 Regional Planning Organizations ................................................................................... 4

Figure 2 Map Showing Locations of South Central and Southeastern Class 1 Areas .................. 9 

Figure 3 Map Showing Locations of Class 1 Areas in Northeastern U.S. .................................... 9

Figure 4 Map Showing Locations of Class 1 Areas in Northern U.S. ........................................ 10

Figure 5 July 15, 2005 Motor Vehicle Emissions for VOC and NOx (Tons Per Day) ............... 13

Figure 6 Base Year Emission Plots for Canada (SO2 Sources) .................................................. 16

Figure 7 Base Year Emission Plots for Canada (NOx Sources) .................................................. 17

Figure 8 Isoprene Emissions for Current Inventory (left) v. Previous Inventory (right) ............ 18

Figure 9 Average Daily Tonnage of Ammonia Emissions for Midwest States by Month (2005)

....................................................................................................................................................... 18

Figure 10 Visibility Modeling Results for Class 1 Areas in Eastern U.S. .................................... 28
iv 

Figure 11 Mammoth Cave Uniform Rate of Progress Glidepath ................................................. 32

Figure 12 Great Smoky Mountains Uniform Rate of Progress Glidepath .................................... 33

Figure 13 Sipsey Uniform Rate of Progress Glidepath ................................................................ 34

Figure 14 James River Face Uniform Rate of Progress Glidepath ............................................... 35

Figure 15 Shenandoah Uniform Rate of Progress Glidepath ........................................................ 35

Figure 16 Dolly Sods Uniform Rate of Progress Glidepath ......................................................... 36

Figure 17 Caney Uniform Rate of Progress Glidepath ................................................................. 37

Figure 18 Upper Buffalo Uniform Rate of Progress Glidepath .................................................... 37

Figure 19 Hercules-Glades Uniform Rate of Progress Glidepath ................................................ 38

Figure 20 Mingo Uniform Rate of Progress Glidepath ................................................................ 38

Figure 21 Acadia Visibility Impact Modeling .............................................................................. 41

Figure 22 Lye Brook Visibility Impact Modeling ........................................................................ 41

Appendices 

Appendix 1 - Class I Areas Located Within (or Impacted by) Midwest RPO States 

Appendix 2 - Letters Requesting Participation by States with Class I Areas 

Appendix 3 - Assessment of Class I Areas Impacted by Indiana Sources 

Appendix 4 - SIP Checklist 

Appendix 5 - BART Eligible Units

 Appendix 5a - Additional BART information for Burns Harbor 

Appendix 5b - Additional BART information for ESSROC-Speed 

Appendix 5c - Additional BART information for SABIC 

 Appendix 5d - BART determination Report for Alcoa, Inc. - Warrick Operations 

Appendix 6 - Smoke Management

Appendix 7 - Indiana BART Rule 

Appendix 8 - Public Hearing Process 

 Appendix 8a - Legal Notice of Public Hearing 

 Appendix 8b - Certification of Publication 

 Appendix 8c - Public Hearing Transcript 

Appendix 9 - IDEM Responses to National Park Service Comments 

Appendix 9a - Baseline Visibility Conditions, Pollutant Contributions, Needed Visibility 

Improvement and Glide Paths for the Uniform Rate of Progress 

Appendix 9b - LADCO Technical Support Document "Regional Air Quality Analyses for 

Ozone, PM2.5, and Regional Haze: Final Technical Support Document" 

Appendix 9c - LADCO's "Reasonable Progress for Class 1 Areas in the Northern 

Midwest – Factor Analysis” Document (July 18, 2007) 

Appendix 9d - Discussions and Data for ArcelorMittal Burns Harbor, ESSROC - Speed 

and SABIC CALPUFF Results using Bondville Ammonia Monitoring 

Results 2003-2005 

Appendix 9e - Alcoa Responses to National Park Service Comments

Appendix 10 - IDEM Response to United States Forest Service Comments 

Appendix 10a - SO2 and NOx Credits for Projected Best Available Retrofit Technology 

Appendix 10b - BART Analyses Cumulative Haze Impacts E-mails 
1 

1.0 Introduction and Background 

This document constitutes the Indiana Department of Environmental Management (IDEM) Regional 

Haze State Implementation Plan (SIP). The federal Regional Haze Rule requires Indiana to submit a 

SIP to the United States Environmental Protection Agency (U.S. EPA). Indiana does not have any Class 

1 areas; however, Indiana sources have been determined to impact visibility in Class 1 areas in other 

states. The Clean Air Act requires Indiana to develop a strategy to mitigate visibility impairment in 

those areas. The strategy has been developed in consultation with the Midwest Regional Planning 

Organization (MRPO) and affected states using data and tools, including emissions inventories and 

modeling analyses taking into consideration factors such as existing pollution control programs, 

emissions reduction needs, compliance schedules, and smoke management techniques. This document 

describes Indiana’s consultation process, technical analyses, and actions to be pursued to reduce 

visibility impairment in other Class 1 areas. 

In amendments to the Clean Air Act in 1977, Congress added Section 169 (42 U.S.C. 7491) setting forth 

the following national visibility goal: 

Congress hereby declares as a national goal the prevention of any future, and the remedying of 

any existing, impairment of visibility in mandatory Class 1 Federal areas which impairment 

results from manmade air pollution. 

When the Clean Air Act was amended in 1990, Congress added Section 169B (42 U.S.C. 7492), 

authorizing further research and regular assessments of the progress made so far. In 1993, the National 

Academy of Sciences concluded that “current scientific knowledge is adequate and control technologies 

are available for taking regulatory action to improve and protect visibility.”1

 

In addition to authorizing creation of visibility transport commissions and setting forth their duties, 

Section 169B(f) of the Clean Air Act mandated creation of the Grand Canyon Visibility Transport 

Commission (Commission) to make recommendations to U.S. EPA for the region affecting the visibility 

of Grand Canyon National Park. The Commission submitted its report to U.S. EPA in June 1996, 

following four years of research and policy development. That report, as well as the many research 

reports prepared by the Commission, contributed invaluable information to U.S. EPA in its development 

of the federal Regional Haze Rule. 

U.S. EPA’s Regional Haze Rule (RH Rule) was adopted July 1, 1999, and went into effect on August 

30, 1999 (64 FR 35714). The RH Rule is aimed at achieving national visibility goals by 2064. This 

rulemaking addressed the combined visibility effects of various pollution sources over a wide 

geographic region. This wide reaching pollution net means that many states, even those without Class 1 

areas, are required to participate in haze reduction efforts. U.S. EPA designated five Regional Planning 

Organizations (RPO) to assist with the coordination and cooperation needed to address the haze issue. 

U.S. EPA’s Regional Haze rulemaking process was controversial. On May 24, 2002, the U.S. Court of 

Appeals, DC District Court, ruled on the challenge brought by the American Corn Growers Association 

against the RH Rule. The Court remanded to U.S. EPA the Best Available Retrofit Technology (BART) 

provisions of the rule, and denied industry’s challenge to the haze rule goals of natural visibility and no 

degradation requirements. U.S. EPA issued revisions to the RH Rule pursuant to the remand. 

 

1 Protecting Visibility in National Parks and Wilderness Areas, National Research Council. Washington, DC: 1993. 
2 

Regional haze is caused by tiny particles that absorb and scatter sunlight, creating white and brown haze. 

The RH Rule requires States to submit SIPs to address regional haze visibility impairment in 156 

federally protected parks and wilderness areas. These 156 scenic areas are called “mandatory Class 1 

Federal areas” in the Clean Air Act but are generally referred to as “Class 1 areas.” As required by the 

Clean Air Act, U.S. EPA included in the final RH Rule a requirement for BART for certain large 

stationary sources. The RH Rule uses the term “BART-eligible source” to describe these sources. Under 

the Clean Air Act, BART is required for any BART-eligible source that a state determines “emits any air 

pollutant which may reasonably be anticipated to cause or contribute to any impairment of visibility in 

any such area.” Accordingly, for stationary sources meeting these criteria, states must address the 

BART requirement when they develop their Regional Haze SIPs. 

On July 6, 2005, U.S. EPA published the Best Available Retrofit Technology Guidelines (BART 

Guidelines) in the Federal Register (70 FR 39104). These guidelines are a component of the July 1, 1999 

Regional Haze regulations. 

Though States have some discretion on the use of the BART Guidelines for most sources, Section 

169A(b) of the Clean Air Act and 40 CFR 51.308(e)(1)(ii)(B) require that states follow the BART 

Guidelines for fossil-fuel fired generating power plants having a capacity in excess of 750 megawatts. 

All Regional Haze SIPs are due three years after U.S. EPA designated PM2.5 attainment and 

nonattainment areas. The FY 2004 Omnibus Appropriations Bill effectively addressed 40 CFR 

51.308(b) and (c). The Appropriations Bill said that all Regional Haze SIPs would be due three years 

after the PM2.5 designation dates regardless of attainment status. The U.S. EPA approved PM2.5

designations for all areas of each state on December 17, 2004. All Regional Haze SIPs were therefore 

due December 17, 2007. 

The RH Rule requires states to set reasonable progress goals toward meeting a national goal of natural 

visibility conditions in Class 1 areas by the year 2064. The first reasonable progress goals will be 

established for the planning period 2008 to 2018. 

Even though Indiana has no Class 1 areas, U.S. EPA's Regional Haze Rule requires a state to address 

regional haze in each Class 1 area outside the state which may be affected by emissions from within the 

state. Indiana has participated in extensive technical analyses conducted by the MRPO to determine if 

any Class 1 areas have visibility impairment that may be caused by sources within the state. 

This Regional Haze SIP will address the initial 10-year implementation period (i.e., reasonable progress 

by the year 2018). SIP requirements (pursuant to 40 CFR 51.308(d)) include establishing reasonable 

progress goals, determining baseline conditions, determining natural conditions, providing a long-term 

control strategy, providing a monitoring strategy (air quality and emissions), and establishing BART 

emissions limitations and an associated compliance schedule. 

Pursuant to the requirements of 40 CFR 51.308(a) and (b), Indiana submits this SIP to meet the 

requirements of the RH Rule that was adopted to comply with requirements set forth in the Clean Air 

Act. Elements of this SIP address the core requirements pursuant to 40 CFR 51.308(d) and the BART 

components of 40 CFR 50.308(e). In addition, this SIP describes Indiana’s consultation process, 

technical analyses, and actions to be pursued to reduce visibility impairment in Class 1 areas. 
3 

Indiana has developed this SIP in accordance with Indiana laws and rules and has the authority to 

implement the SIP in accordance with those laws and rules. 

Indiana will provide public notice of the opportunity to comment on the SIP and of the public hearing 

that will be held regarding the SIP. Public comments will be addressed and summarized in the final 

version of the SIP. 

2.0 Regional Planning 

The MRPO was formed to facilitate regional planning to address the regional haze regulations adopted 

by U.S. EPA in 1999. The primary objective of the MRPO is to assess both visibility impairment due to 

regional haze in the mandatory Federal Class 1 areas located inside the borders of the five States of 

Illinois, Indiana, Michigan, Ohio, and Wisconsin, and to assess the impact of emissions from the five 

states on visibility impairment due to regional haze in the mandatory Federal Class 1 areas located 

outside the borders of the five States. Members of the MRPO include the five states, tribes located 

within the five states, Federal Land Managers (U.S. National Park Service, U.S. Fish & Wildlife 

Service, and U.S. Forest Service), and U.S. EPA. The Lake Michigan Air Directors Consortium 

(LADCO) has been designated as the agency to receive federal grant funds on behalf of the MRPO. 

This SIP uses data analyses, modeling results and other technical support documents prepared for 

MRPO members. By coordinating with the MRPO and other Regional Planning Organizations (RPOs), 

Indiana has worked to ensure that its long term strategy provides sufficient reductions to mitigate 

impacts of sources from Indiana on affected Class 1 areas. 

The other RPOs are Mid-Atlantic / Northeast Visibility Union (MANE-VU), Central Regional Air 

Planning Association (CENRAP), Visibility Improvement State and Tribal Association of the Southeast 

(VISTAS), and Western Regional Air Partnership (WRAP). Figure 1 shows a map of the regional 

planning organization boundaries. 
4 

Figure 1 Regional Planning Organizations 

Indiana does not have any Class 1 areas. However, emissions from Indiana sources have been 

determined to impact Class 1 areas in other states. Table 1, taken from Appendix 1 contains a list of 

these Class 1 areas for all the LADCO states, and the analyses performed to assess the impact from 

Indiana that were compiled by the MRPO. 
5 

Table 1 (This is Table 1 from Appendix 1 Showing Impacts of LADCO States upon Class I Areas) 

AREA NAME IL IN MI OH WI 

81.401 Alabama. 

Sipsey Wilderness Area (1) (1) 

 

81.404 Arkansas. 

Caney Creek National Wilderness 

Area (2), (4) (2), (4) (2), (4) 

Upper Buffalo National Wilderness 

Area (1),(2),(4),(5) (2), (4) (2), (4) (2) 

 

81.408 Georgia. 

Cohotta Wilderness Area 

Okefenokee Wilderness Area 

Wolf Island Wilderness Area 

 

81.411 Kentucky. 

Mammoth Cave National Park (1), (2), (5) (1), (2), (5) (1), (2) (1), (2), (5) 

 

81.412 Louisiana. 

Breton Wilderness Area 

 

81.413 Maine. 

Acadia National Park (3) (3) (3) (3) 

Moosehorn Wilderness Area (3) (3) (3) (3) 

 

81.414 Michigan. 

Isle Royale National Park (1), (2) (1), (2) (1), (2) (1), (2) 

Seney National Wilderness Area (1), (2) (1), (2) (1), (2) (1), (2) (1), (2) 

 

81.415 Minnesota. 

Boundary Waters Canoe Area 

National Wilderness Area (2) (2) (2) (1), (2) 

Voyageurs National Park (2) (2) (1), (2) 

 

81.416 Missouri. 

Hercules-Glades National Wilderness 

Area (2), (4), (5) (2), (4), (5) (2), (4) (2) 

Mingo National Wilderness Area (2), (4), (5) (2), (4), (5) (2) (2), (4) (2) 

 

81.419 New Hampshire. 

Great Gulf National Wilderness Area (3) (3) (3) (1), (3) 

Pres. Range-Dry River National 

Wilderness Area 

 
6 

Key 

(1) MRPO Back Trajectory Analyses 

 (2) MRPO PSAT Modeling 

 (3) MANE-VU Contribution Assessment 

 (4) Missouri-Arkansas Contribution 

 (5) VISTAS Areas of Influence 

The following areas are listed as possibly being impacted by Indiana sources: 

Southeastern U.S. (VISTAS) - Sipsey Wilderness Area, AL; Mammoth Cave National Park, KY; Great 

Smoky Mountains National Park, NC and TN; James River Face Wilderness Area, VA; Shenandoah 

National Park, VA; and Dolly Sods / Otter Creek Wilderness Areas, WV 

Eastern U.S. (MANE-VU) - Acadia National Park, ME; Moosehorn Wilderness Area, ME; Great Gulf 

Wilderness Area, NH; Brigantine Wilderness Area, NJ; and Lye Brook Wilderness Area, VT 

AREA NAME IL IN MI OH WI 

81.42 New Jersey. 

Brigantine National Wilderness Area (3) (3) (1), (3) (1), (3) 

 

81.422 North Carolina. 

Great Smoky Mountains NP{1} (1) (1) (1) 

Joyce Kilmer-Slickrock Wilderness 

Area {2} 

Linville Gorge Wilderness Area 

Shining Rock Wilderness Area 

Swanquarter Wilderness Area 

 

81.426 South Carolina. 

Cape Romain Wilderness 

 

81.428 Tennessee. 

Great Smoky Mountains NP{1} (1) (1) (1) 

Joyce Kilmer-Slickrock Wilderness 

Area {2} 

 

81.431 Vermont. 

Lye Brook National Wilderness Area (2), (3) (2), (3) (2), (3) (1), (2), (3) 

 

81.433 Virginia. 

James River Face National Wilderness 

Area (2) (2) (2) (2), (5) 

Shanandoah National Park (2), (3) (1), (2), (3) (2), (3) (1),(2),(3),(5) 

 

81.435 West Virginia. 

Dolly Sods/Other Creek National 

Wilderness Area (2), (3) (1), (2), (3) (1), (2), (3) (1),(2),(3),(5) 
7 

Northern U.S. (MRPO and CENRAP) - Isle Royale National Park, MI; Seney National Wildlife 

Refuge, MI; Boundary Waters Canoe Area Wilderness Area, MN; and Voyageurs National Park, MN 

South Central U.S. (CENRAP) - Hercules-Glades Wilderness Area, MO; Mingo Wilderness Area, MO; 

Caney Creek Wilderness Area, AR; and Upper Buffalo Wilderness Area, AR 

Class I areas outside the areas listed above were not analyzed further, as there was no impact from 

Indiana sources shown. Further, no impacts from Indiana were noted in the WRAP states and no 

requests for controls were initiated by those states. 

Indiana has participated in meetings and conference calls with states within the MRPO and the RPOs 

outside the Midwest to discuss their assessments of visibility conditions, analyses of culpability, and 

possible measures that could be taken to meet visibility goals for 2018. The sections later in this 

document provide that information on a state-by-state basis. Table 2 shows the calls and meetings held 

with states and RPOs with Class 1 areas in which Indiana participated. 

Table 2 Calls and Meetings Regarding Class 1 Areas 

Date Group 

March 12, 2007 Northern States (Michigan and Minnesota) call 

April 3, 2007 CENRAP call 

April 17, 2007 Northern States meeting 

April 25 - 26, 2007 Denver RPO - Federal Land Manager meeting 

May 11, 2007 CENRAP call 

May 17, 2007 Northern States call 

June 7, 2007 CENRAP call 

June 18, 2007 Northern States call 

July 10 - 11, 2007 MANE-VU Science meeting (covered by MRPO) 

July 19, 2007 MANE-VU call 

July 30, 2007 Northern States call 

August 6, 2007 MANE-VU meeting 

August 23, 2007 Northern States call 

February 7, 2008 Northern States call 

June 25, 2008 Northern States call 

3.0 Indiana and Federal Land Manager Coordination 

The provision at 40 CFR 51.308(i) requires coordination between Indiana and the Federal Land 

Managers (FLMs). Opportunities have been provided by the MRPO for FLMs to review and comment 

on each of the technical documents developed by the MRPO and included in this SIP. Indiana has 

provided agency contacts to the FLMs as required. In development of this plan, the FLMs were 

consulted in accordance with the provisions of 40 CFR 51.308(i)(2). 
8 

During the consultation process, the FLMs were given the opportunity to address the following: 

· Assessment of the impairment of visibility in any Class 1 areas 

· Recommendations on the development of reasonable progress goals 

· Recommendations on the development and implementation of strategies to address visibility 

impairment. 

Indiana has consulted directly with the FLMs by email and phone, during periodic MRPO calls and 

meetings, at the FLM-RPO meeting in Denver on April 25 and 26, 2007, and during discussions with 

other states and RPOs with Class 1 areas (for example, the MANE-VU meeting August 6, 2007 in 

Chicago). Indiana will provide the FLMs an opportunity for review of the SIP, at least 60 days prior to 

holding the public hearing for the SIP. Comments received from the FLMs on this plan will be 

summarized and responses will be included in the final version. 

Indiana will continue to coordinate and consult with the FLMs during the development of future 

progress reports and plan revisions, as well as during the implementation of programs having the 

potential to contribute to visibility impairment in the Class 1 areas. The FLMs will be consulted during 

the development and review of implementation plan revisions and during the review of 5-year progress 

reports 

4.0 Development of Reasonable Progress Goals 

The following maps show the locations of Class 1 areas in the central, eastern, and northeastern portions 

of the U.S. Modeling indicated that Indiana sources had no measurable impact on Class I areas in the 

Western Regional Air Partnership (WRAP). Therefore, Class I areas in that region are not addressed in 

this SIP. 
9 

Figure 2 Map Showing Locations of South Central and Southeastern Class 1 Areas 

Figure 3 Map Showing Locations of Class 1 Areas in Northeastern U.S. 
10 

Figure 4 Map Showing Locations of Class 1 Areas in Northern U.S. 

Seney

Boundary Waters

Canoe Area

Isle Royale

Voyageurs

4.1 Assessment of Baseline (or Current) Conditions and Estimate of Natural Conditions (in 

Class 1 Areas) 

The RH Rule requires states with Class 1 areas to establish reasonable progress goals, expressed in 

deciviews (dv), for visibility improvement at each affected Class 1 area. The goals must provide for 

reasonable progress toward achieving natural visibility conditions, provide for improvement in visibility 

for the most impaired days over the period of the implementation plan, and ensure no degradation in 

visibility for the least impaired days over the same period, (40 CFR 51.308(d)(1)). 

An evaluation of the chemical composition of the light extinction for 20 % best visibility days and 20% 

worst visibility days was performed for the northern Class 1 areas. The results are shown in Appendix 

9a, Figure 1 of the National Park Service response to comments document attached. For the 20% worst 

visibility days, the pollutants that contribute to visibility impairment are sulfates, which represent 35-

55% impairment, nitrates are 25-30% of the pollutant contribution, and organic carbon contributes 12-

22% to visibility impairment. 

In addition, sulfates represent the highest contributing pollutant to light extinction with nitrates and 

organic carbon providing seasonal contributions. Nitrates have higher contributions during the late fall, 

winter and early spring while organic carbon has higher contributions to light extinction during the 

summer. Elemental carbon and coarse mass are fairly consistent throughout the year at all northern 

Class 1 areas. Monthly average light extinction values for the northern Class 1 areas are shown in 

Appendix 9a, Figure 2 of the National Park Service response to comments document attached. 
11 

LADCO conducted photochemical modeling for baseline and future year light extinction. This source 

apportionment modeling analyzed regional, source, and pollutant impacts on visibility at northern, south 

central, southeastern, and northeastern Class 1 Areas as shown in Appendix 1, Figure 3 through Figure 

8. Indiana’s contributions to visibility impairment at each of these Class 1 areas comprises mainly of 

sulfates from EGU emissions. Indiana contributions to visibility impairment at all the Class 1 areas 

analyzed were less than 5 Mm-1 with the exception of Indiana’s contribution to visibility at Mammoth 

Cave National Park in Kentucky. The future year modeling shows that Indiana is projected to have 

reduced its contribution on Mammoth Caves’ visibility impairment by approximately 50% by 2018. 

Back trajectory analyses to determine which states were culpable during bad visibility days at each of 

the northern Class 1 areas analyzed were also conducted by LADCO. Table 1 in Appendix 1, shows the 

percentage of light extinction culpability from states in the eastern United States at the northern Class 1 

areas. Indiana is shown to contribute less than 3 % light extinction at Boundary Waters Canoe Area, 

MN and Seney Wilderness, MI and no appreciable contribution to light extinction at Voyageurs 

National Park, MN. LADCO summarized its back trajectory, Round 4 and Round 5 PSAT analyses 

along with the CENRAP and MPCA PSAT modeling results to show the state culpabilities on the 

northern Class 1 areas. As can be seen in Appendix 1, Table 2, Indiana’s impacts on the Boundary 

Waters, Voyageurs, and Isle Royale Class 1 areas are less than 6% of the total visibility impairment. 

Indiana is modeled to have a slightly higher impact at Seney, with modeled results less than 12% of total 

visibility impairment. Emission reductions that are projected through future year 2018 PSAT modeling 

show Indiana’s impact will be reduced approximately 20% or more, decreasing Indiana’s impact on 

future year visibility at Seney. 

Baseline visibility conditions for the northern Class 1 areas, taken from 2000 through 2004, established 

the baseline values at the northern Class 1 areas between 18.5 and 23.5 deciviews for the 20% worst 

days using the old IMPROVE equation and baseline values at the northern Class 1 areas between 19.5 

and 24.5 deciviews using the new IMPROVE equation. This information is used to establish the 

uniform rate of improvement (URI) for 2018. Appendix 9a, Table 3 shows the visibility values for the 

northern Class 1 area using the old and new IMPROVE equations. 

4.2 Glidepaths to Natural Conditions in 2064 

The states and RPOs with Class 1 areas performed their analyses to determine baseline conditions and 

natural conditions for 2064. The Regional Haze Rule directs states to graphically show what would be a 

"uniform rate of progress" toward natural conditions for each Class 1 area within their state, as well as 

Class 1 areas outside the state which may be affected by emissions from sources within the state. The 

uniform rate of progress is also known as the "glidepath." The glidepath is a straight line drawn from 

the baseline level of visibility impairment for 2000 - 2004 to the level representing no manmade 

impairment in 2064. 

Glidepaths were developed by the states and RPOs for their own Class 1 areas using their available 

information. The MRPO also developed glidepaths for the Class 1 areas impacted by states within the 

RPO. The glidepath is one of the indicators used in setting reasonable progress goals. 
12 

The glide paths, as determined by LADCO’s Base M modeling, show the different emission scenarios 

meeting the glide paths for most Class 1 areas by 2018. The different emission scenarios include: 

- R5S1a scenario - EGU emissions as assumed by the EPA’s IPM3.0 model 

- R5S1b scenario – EPA’s IPM3.0 model emissions for EGUs along with several “will do” 

adjustments identified by states (legally binding agreements such as consent degrees, operating 

permits, signed contracts, etc). 

Modeling results show the deciview values resulting from the different emission rates fall in line with 

the glide path for each Class 1 area for the 20% worst days. Further explanation of the glide path results 

can be found in the “Regional Air Quality Analyses for Ozone, PM2.5 and Regional Haze: Final 

Technical Support Document, April 25, 2008” page 96-100. The glide paths for several Class 1 areas 

are found in Figure 10 on page 27. 

4.3 Letters Requesting Participation in Consultation Process from States with Class 1 Areas 

As a result of the various analyses performed by the MRPO and other RPOs, Indiana was invited to 

participate in a number of consultations regarding contributions to Class 1 areas. These include 

Arkansas, Missouri, Minnesota, and Michigan. Also included were New Jersey, New Hampshire, and 

Vermont - each individually and together as part of the MANE-VU letter. Copies of these letters are 

found in Appendix 2. 

5.0 Emissions Inventory 

A great deal of technical information must be assembled to determine the causes of impaired visibility in 

the Class 1 areas. Required in 40 CFR 51.308(d)(4)(v) is a statewide emissions inventory of pollutants 

that are reasonably anticipated to cause or contribute to visibility impairment in any mandatory Class 1 

area. The pollutants inventoried by Indiana for this purpose include volatile organic compounds 

(VOCs), nitrogen oxides (NOx), fine particulate (PM2.5), coarse particulate (PM10), and sulfur dioxide 

(SO2). An inventory was developed for the baseline year 2005. In addition, projections of future 

emissions have been made for 2009 and 2018. Indiana will update this inventory on a periodic basis, 

every three years. A summary of the inventory results follows; the complete emission inventory is 

available at: http://www.ladco.org/tech/emis/current/. The following information is taken from Section 

3.6 of the MRPO document, “Regional Air Quality Analyses for Ozone, PM2.5, and Regional Haze: 

Final Technical Support Document, April 25, 2008, States of Illinois, Indiana, Michigan, Ohio, and 

Wisconsin.” This document is available at the MRPO website: 

http://www.ladco.org/reports/technical_support_document/tsd/tsd_version_iv_april_25_2008_final.pdf

5.1 Base Year Emissions 

Through coordination with the MRPO and other states, a base year inventory was prepared for regional 

modeling analysis. The states reviewed methodologies and assisted in the preparation of key segments 

of the emissions inventory that was eventually submitted to the MRPO. 
13 

For on-road, nonroad, ammonia, and biogenic sources, the 2005 emissions were estimated by models. 

For the other sectors, point sources, area sources, and MAR (commercial marine, aircraft, and railroads), 

the 2005 emissions were prepared using data supplied by the MRPO States and, for non-MRPO states, 

data developed by other RPOs. In particular, for the non-MRPO states, a contractor (Alpine, with 

assistance from MACTEC) obtained the latest base (2002) and future year emission files (2009 and 

2018) from the other RPOs. Specifically, the following versions of these emissions files were used here: 

o MANE-VU: Version 3.1 

o WRAP: Pre2002d 

o CENRAP: Base F 

o VISTAS: Base F 

Emissions for 2005 were then estimated by linearly interpolating between the 2002 and 2009 emissions.2

Further discussion of the development of the 2005 base year emissions is provided below. 

5.2 On-road Mobile 

The CONsolidated Community Emissions Processing Tool (CONCEPT)3 was run by a contractor 

(Environ) using transportation data (e.g., VMT and vehicle speeds) supplied by the state and local 

planning agencies in the MRPO States and Minnesota for 24 networks. These data were first processed 

with T3 (Travel Demand Modeling [TDM] Transformation Tool) to provide input files for CONCEPT 

to calculate link specific, hourly emission estimates. CONCEPT was run with meteorological data for a 

July and January weekday, Saturday, and Sunday (July 15 – 17 and January 16 – 18). Spatial plots of 

emissions for July 15 are provided in the following figure. 

Figure 5 July 15, 2005 Motor Vehicle Emissions for VOC and NOx (Tons Per Day) 

 

2 Emissions Inventory Assistance: 2005 Base Year Biogenic and Other (non-MRPO) State Emissions”, March 12, 2007 3

 CONCEPT was developed as joint project between Alpine Geophysics, LLC and ENVIRON Corporation, with Midwest 

RPO and joint RPO funding, the CONCEPT model combines the best attributes of current emissions modeling systems into 

an open source model. 
14 

For the non-MRPO states, CONCEPT was run by Environ using RPO-based HPMS county-level data 

(2002 and 2009) and MOBILE6 inputs (2002) compiled by another contractor for VISTAS. HPMS 

VMT for 2005 was generated by linearly interpolating between the 2002 and 2009 data. The 2002 

MOBILE6 inputs were used for the 2005 modeling, with a few adjustments (e.g., fuel sulfur content was 

set to 30 ppm, as required by the Tier 2/low sulfur regulations). 

5.3 Nonroad Mobile 

NMIM20054

 was run by Grant Hetherington (Wisconsin Department of Natural Resources). The 

following are the NMIM2005 model runs prepared for the emissions inventory. 

o Phase 1: Run NMIM2005 for the MRPO states plus Minnesota plus Iowa and Missouri 

agriculture with Pechan’s modifications only5

. The Pechan modifications that were not 

incorporated in the default NMIM2005 inputs and need to be incorporated are BSFC emission 

factor data, Michigan population data, Missouri seasonality data and revised countynrfile, 

countyyear, countyyearmonth, datasource and gasoline NCD tables that assimilate fuel changes 

and file references. 

o Phase 2: Run NMIM2005 for the MRPO states plus Minnesota plus Iowa and Missouri 

agriculture with Pechan’s modifications, revised 2005 MRPO gasoline parameters and a 

modified SCC table containing PM2.5 corrections for diesel equipment. 

o Phase 3: Run NMIM2005 for the MRPO states plus Minnesota plus Iowa and Missouri 

agriculture with Pechan’s modifications, revised 2005 MRPO gasoline parameters, a modified 

SCC table containing PM2.5 corrections for diesel equipment and AIR's NONROAD.EXE. (Note: 

it is not clear if Phase 3 was used.) 

Not all sectors of the nonroad inventory are calculated by NMIM2005 (i.e., commercial marine, aircraft, 

and railroads) and those were handled separately. Aircraft emissions were supplied by the states. 

Updated information for railroads and commercial marine was prepared by a contractor (Environ).6

 For 

the non-MRPO states, Alpine developed appropriate emissions files based on data from the other RPOs, 

as noted above. 

5.4 Area Sources 

EMS (Emissions Modeling System) was run by the MRPO using 2005 data supplied by the MRPO 

states and, for the non-MRPO states, using emission files supplied by Alpine based on data from the 

other RPOs to produce weekday, Saturday, and Sunday emissions for each month. Upon reviewing the 

 

4

 The National Mobile Inventory Model (NMIM) is a free, desktop computer application developed by EPA to help develop 

estimates of current and future emission inventories for on-road motor vehicles and nonroad equipment. NMIM uses current 

versions of MOBILE6 and NONROAD to calculate emission inventories, based on multiple input scenarios entered into the 

system. NMIM is used to calculate national, state or county inventories. 

5

 “LADCO Nonroad Emissions Inventory Project – Development of Local Data for Construction and Agricultural 

Equipment”, Final Report, September 10, 2004 

6

 “LADCO 2005 Locomotive Emissions”, Environ, February 2007, and “LADCO 2005 Commercial Marine Emissions”, 

Environ, March 2, 2007 
15 

data, further attention was given to two source categories, industrial adhesives and sealants and outdoor 

wood boilers, in order to provide updated emissions estimates. These activities are described below. 

Industrial Adhesives and Sealants: The National Emissions Inventory shows this to be a large VOC 

emissions category in the MRPO States (i.e.., 50,000 TPY). U.S. EPA subsequently determined that 

“(f)or the Region V states, we no longer believe that there are any activities in the Industrial Adhesives 

and Sealants category (SCC 2440020000) that have not been inventoried either in the point source 

Industrial Adhesives and Sealants category or under the Consumer and Commercial Adhesives and 

Sealants nonpoint category (SCC 2460600000 - all adhesives and sealants).” Consequently, this 

category was omitted from the 2005 regional emissions inventory. 

Outdoor Wood Boilers: Over the past several years, the installation and operation of outdoor wood 

boilers for residential use has increased dramatically in many northern states. Relying on an emission 

estimation methodology prepared by Bart Sponseller (Wisconsin Department of Natural Resources), 

emissions were calculated by the other states for this category. 

For the non-MRPO states, a contractor (Alpine, with assistance from MACTEC) estimated 2005 

emissions by linearly interpolating between the 2002 and 2009 emissions developed by the other RPOs. 

5.5 Point Sources – Electric Generating Units (EGUs) 

EMS was run by the MRPO using 2005 data supplied by the MRPO states and, for the non-MRPO 

states, using emission files supplied by Alpine based on data from the other RPOs to produce weekday, 

Saturday, and Sunday emissions for each month. 

The annual and summer season EGU emissions were temporalized for modeling purposes using profiles 

prepared by Scott Edick (Michigan Department of Environmental Quality) based on CEM data for the 

period 2002 – 2005. Since the CEM data was the source of the emissions data, EGUs were removed 

from the general point source files provided by the states. 

5.6 Point Sources – Non-EGU 

EMS was run by the MRPO using 2005 data supplied by the MRPO states and, for the non-MRPO 

states, using emission files supplied by Alpine based on data from the other RPOs, to produce weekday, 

Saturday, and Sunday emissions for each month. 

5.7 Other Improvements 

Canadian Emissions: Previous modeling inventories for Canadian sources were flawed due to problems 

with emissions (e.g., MRPO inventories omitted ammonia emissions) or stack parameters (e.g., VISTAS 

inventories failed to include proper stack parameters, resulting in emissions getting dumped in the 

surface layer of the model). Scott Edick of the Michigan DEQ processed the 2005 Canadian National 

Pollutant Release Inventory (NPRI). Specifically, a subset of the NPRI data which is relevant to the air 

quality modeling was reformatted. Circle plots of point source emissions are presented in the following 

figures. 
16 

Figure 6 Base Year Emission Plots for Canada 

 
17 

Figure 7 Base Year Emission Plots for Canada 

Biogenic Emissions: A contractor (Alpine) provided an updated version of the CONCEPT/MEGAN7

(Model of Emissions of Gases and Aerosols from Nature) biogenics 

model, which was used to produce base year biogenic emission estimates. Model improvements 

included: (a) reduced model run times, (b) improved ability to run successive days, and (c) enhanced 

meteorological input processing8

. 

As a result of the model improvements and more recent data sets, there is more regional isoprene using 

MEGAN compared to the BIOME estimates used for Base K (see Figure 8). Also, with the secondary 

organic aerosol updates to the CAMx air quality model, Base M includes emissions for monoterpenes 

and sesquiterpenes, which are precursors of secondary PM2.5 organic carbon mass. 

 

7

 See http://bai.acd.ucar.edu/Megan/ 

8

 Subsequent to delivery of the updated CONCEPT/MEGAN model, it was found that more recent data sets and model 

formulations were available. Consequently, additional model improvements were undertaken. Compared to the initial 

updated model, the revised model reflects lower emissions for several organic aerosol species and NOx. 
18 

Figure 8 Isoprene Emissions for Current Inventory (left) v. Previous Inventory (right) 

Ammonia Emissions: The CMU-based 2002 ammonia emissions were projected to 2005 using growth 

factors from the Round 4 emissions modeling. These emissions were then adjusted by applying 

temporal factors by month based on the process-based ammonia emissions model. A plot of the average 

daily emissions by state and month is provided in Figure 9. 

Figure 9 Average Daily Tonnage of Ammonia Emissions for Midwest States by Month (2005) 

5.8 Future Year Emissions 

Emission inventories were developed for two future years: 2009 and 2018. For on-road, nonroad, and 

EGU sources, the future year emissions were estimated by models (i.e., CONCEPT, NMIM2005, and 

IPM, respectively) and then processed by the MRPO with EMS. 

For other sectors (area, commercial marine, aircraft, and railroads, and non-EGU point sources) the 

future year emissions for the MRPO States were derived by applying growth and control factors to the 

base year inventory. These factors were developed by a contractor (E.H. Pechan).9

 For the non-MRPO 

states, future year emission files were supplied by Alpine based on data from the other RPOs. 

Growth factors were based initially on EGAS (version 5.0), and were subsequently modified (for select, 

priority categories) by examining emissions activity data. 

 

9

 “Development of 2005 Base Year Growth and Control Factors for Lake Michigan Air Directors Consortium”, Final Report, 

September 2007 
19 

Control factors were prepared for the following area, commercial marine, aircraft, railroad, and nonEGU point source existing (“on the books”) controls: 

On-Highway Mobile Sources 

o Tier II/low sulfur fuel 

o Inspection/maintenance programs (nonattainment areas) 

o Reformulated gasoline (nonattainment areas) 

Off-Highway Mobile Sources 

o Federal control programs incorporated into NONROAD model (e.g., nonroad diesel rule), 

plus the evaporative Large Spark Ignition and Recreational Vehicle standards 

o Heavy-duty diesel (2007) engine standard/low sulfur fuel 

o Federal railroad/locomotive standards 

o Federal commercial marine vessel engine standards 

Area Sources 

o Consumer solvents 

o AIM coatings 

o Aerosol coatings 

o Portable fuel containers 

o Woodstoves 

o Stage II Vapor Recovery 

Point Sources - EGUs 

o Title IV (Phases I and II) 

o NOx SIP Call 

o Clean Air Interstate Rule (CAIR) 

o Clean Air Mercury Rule 

Other Point Sources 

o VOC 2-, 4-, 7-, and 10-year MACT standards 

o Combustion turbine MACT 

o Industrial boiler/process heater/RICE MACT 

o Consent decrees (refineries, ethanol plants, and ALCOA)10

o Other (Illinois and Ohio NOx RACT11, and BART in IN and WI) 

o MACT12

Further discussion of the development of the future year emissions is provided below: 

On-road: Similar to the base year modeling, CONCEPT was run using transportation data (e.g., VMT 

and vehicle speeds) supplied by the state and local planning agencies for 2009 and 2018. CONCEPT 

was only run with meteorological data for the July weekday. The emissions for Saturday and Sunday 

 

10 E.H. Pechan’s original control file included control factors for three sources in Wayne County, MI. These control factors 

were not applied in the regional-scale modeling to avoid double-counting with the state’s local-scale analysis for PM2.5 11 WI believes that NOx RACT for their sources is already included in the 2005 basecase and EGU “will do” scenario, and IN 

provided NOx RACT information for inclusion as a non-EGU “may do” scenario. 12 E.H. Pechan’s original control file included EPA-default control factor information. Alternative control factors were 

developed by Wisconsin for a few MACT categories, and were also applied to the other four MRPO States. 
20 

were derived by using scaling factors based on the 2005 emissions. The state-level emissions for the 

five MRPO States plus Minnesota are summarized in the following table13. 

Table 3 Summary of On-road Emissions (Tons Per Day – July 15, 2005)

Year State CO VOC NOx PM2.5 SO2 NH3 Sum of VMT 

2005 IL 3,684 342 748 13 10 36 344,087,820 

 IN 3,385 282 541 9 11 26 245,537,232 

 MI 4,210 352 722 12 14 35 340,834,026 

 MN 2,569 219 381 6 8 18 170,024,600 

 OH 6,113 680 934 16 19 37 360,521,069 

 WI 2,206 175 458 8 9 20 189,123,964 

 Total 22,168 2,049 3,783 65 70 171 1,650,128,710 

2009 IL 2,824 268 528 10 4 39 372,132,591 

 IN 2,840 235 402 7 3 26 249,817,026 

 MI 3,172 269 501 9 4 37 356,347,011 

 MN 2,257 206 308 5 2 22 204,443,018 

 OH 4,619 424 694 12 5 40 387,428,127 

 WI 1,673 119 322 6 2 21 197,729,965 

 Total 17,385 1,522 2,754 49 20 184 1,767,897,738 

2018 IL 2,085 152 201 6 4 43 413,887,887 

 IN 2,217 138 173 4 3 30 288,042,232 

 MI 2,434 164 204 6 4 41 388,128,432 

 MN 1,800 123 137 4 2 25 237,022,214 

 OH 3,362 243 274 7 4 43 421,694,093 

 WI 1,256 68 139 4 2 22 218,277,168 

 Total 13,153 888 1,128 31 18 204 1,967,052,026 

For the non-MRPO states, CONCEPT was run by Environ using HPMS county-level data and 

MOBILE6 inputs compiled by another contractor for VISTAS. The emissions modeling for Iowa, 

Missouri, and Oklahoma was redone for 2009 to reflect the state-developed registration distribution 

data. (The initial modeling for 2009 used national default values for registration distribution assumed by 

VISTAS’ contractor. CENRAP’s contractor developed emissions inventories for 2002 and 2018 using 

the state developed data. For consistency, Environ’s remodeling for these three states for 2009 also used 

the state-developed data.) 

Off-road: Similar to the base year inventory, NMIM2005 was run by Grant Hetherington (Wisconsin 

Department of Natural Resources) to produce the future year inventories, with updated 

growth factors by E.H. Pechan. 

Point Source - EGU: Future year emissions were based on U.S. EPA’s IPM3.0 modeling. Two 

additional scenarios were addressed to analyze actual implementation of controls in each 

state to meet CAIR requirements: 

 5a: U.S. EPA’s IPM3.0 was assumed as the CAIR future year base for EGUs. 

 

13 For northeastern IL (CATS region), 2009 and 2018 emissions were increased by 9% and 8%, respectively, to reflect newer 

transportation modeling by CATS. 
21 

 5b: U.S. EPA’s IPM3.0 CAIR run, with several “will do” adjustments identified by the States. 

These adjustments should reflect a legally binding commitment (e.g., signed contract, consent 

decree, or operating permit). 

 5c: U.S. EPA’s IPM3.0 CAIR run, with several “may do” adjustments identified by the States. 

These adjustments reflect less rigorous criteria, but should still be some type of public reality 

(e.g., BART determination or press announcement). 

Table 4 summarizes the SO2 and NOx emissions for the three scenarios. The EGU emissions were the 

only changes in scenarios 5b and 5c. The net effect is a small change (increase) in regional SO2 and 

NOx emissions. SO2 emissions increase from scenario 5a to scenarios 5b and 5c by 28% while NOx

emissions increase only 1% for Indiana in 2009. These increases are 15% for SO2 in 2018 and 4% for 

NOx in 2018. Emissions differed from the IPM predicted runs because the CAIR rule included a widespread trading program and use of banked allowances. Therefore, some companies could attain their 

CAIR budget through means other than installation of advanced control devices. Also, there were 

several facilities identified in the LADCO states that would likely not complete scrubber projects as 

originally predicted by the IPM 3.0 runs. Emissions for 2005 were then substituted for 2009 LADCO 

runs. For Indiana, 2005 “unscrubbed” data was substituted for all the Clifty Creek units. This 

information is found at the LADCO website; ladco.org/tech/Emis/round5/index.php, “Current Inventory 

– LADCO’s Round 5, 2009/2018 Inventory (August 2007)”, under “State Total Reports”. Emission 

projections from 2009 to 2018 show significant decreases in NOx emissions for scenario 5a of 31% and 

NOx emissions decreases for scenarios 5b and 5c of 29%, each. Emission projections from 2009 to 2018 

show decreases in SO2 emissions for scenarios 5b and 5c of 9% each. 

Table 4 EGU Emissions for Base (5a), Will Do (5b), and May Do (5c) Scenarios 

 2009 

(Tons per Day) 

2018 

(Tons per Day) 

SO2 5a 5b 5c 5a 5b 5c 

IL 958 881 881 869 433 433

IN 1033 1318 1318 1036 1194 1194

MI 667 667 667 725 725 725

OH 1326 1410 1410 983 1127 1127

WI 460 460 421 435 499 235

Total 4444 4736 4697 4048 3978 3714

MN 162 148 148 187 167 157

 

NOx 5a 5b 5c 5a 5b 5c 

IL 275 247 247 224 195 195

IN 370 372 372 255 266 266

MI 242 242 242 243 243 243

OH 281 305 305 285 310 310

WI 165 164 155 176 172 145

Total 1333 1330 1321 1183 1186 1159

MN 116 142 142 132 157 125

Table 5 shows the emissions for various pollutants from emission sectors used in the Round 5 runs. 

This table illustrates the amount of reductions in each sector from controls in place and projected over 

the years, including those listed on page 15. Overall, emissions from Indiana and the Midwest, as a 
22 

whole, are reduced significantly over this time, illustrating that Indiana is making reasonable progress 

toward reducing emissions. 

Table 5 Emissions Summaries 

VOC NOx SO2 PM2.5

July 2005 2009 2018 2005 2009 2018 2005 2009 2018 2005 2009 2018 

Nonroad 

IL 321 257 213 333 275 155 33 5 0 30 24 14 

IN 195 160 128 191 158 89 19 3 0 17 13 7 

MI 414 350 271 239 197 112 22 3 0 22 18 11 

OH 356 294 238 304 246 135 29 5 0 27 22 13 

WI 238 203 157 157 129 77 15 2 0 14 12 7 

5-StateTotal 1,524 1,264 1,007 1,224 1,005 568 118 18 2 110 89 52 

Commercial marine, aircraft, and railroad 

IL 11 10 6 246 228 165 22 19 17 7 6 4 

IN 5 5 3 93 87 65 8 7 6 2 2 2 

MI 7 7 7 87 82 65 21 14 8 3 3 2 

OH 7 7 5 134 126 94 14 12 10 4 4 2 

WI 4 4 3 58 54 41 8 6 5 2 2 1 

5-StateTotal 34 33 24 618 577 430 73 58 46 18 17 11 

Other Area 

IL 675 594 582 48 48 49 11 16 16 40 64 69 

IN 391 358 384 56 58 59 32 32 32 2 2 2 

MI 652 562 549 49 50 51 29 29 28 111 114 120 

OH 604 506 487 93 108 108 6 15 14 19 35 34 

WI 315 290 293 37 37 37 17 13 13 11 12 12 

5-StateTotal 2,637 2,310 2,295 283 301 304 95 105 103 183 227 237 

On-Road 

IL 341 268 151 748 528 201 9 4 3 13 10 6 

IN 282 235 138 541 402 173 11 3 2 9 7 2 

MI 351 269 163 722 501 204 14 4 3 12 9 3 

OH 680 424 242 934 693 274 18 4 4 16 12 4 

WI 175 119 68 457 322 138 9 2 2 8 6 2 

5-StateTotal 1,829 1,315 762 3,402 2,446 990 61 17 14 58 44 17 

EGU 

IL 7 6 7 305 275 224 1,158 958 869 13 34 77 

IN 6 6 6 393 370 255 2,614 1,033 1,036 16 73 74 

MI 6 4 4 393 242 243 1,251 667 725 15 25 29 

OH 4 5 6 408 280 285 3,405 1,326 983 28 94 80 

WI 5 2 3 213 165 177 545 460 435 - 22 25 

5-StateTotal 28 23 26 1,712 1,332 1,184 8,973 4,444 4,048 72 248 285 

Non-EGU 

IL 221 218 258 330 218 235 423 335 346 16 17 19 

IN 130 137 167 179 175 178 218 216 180 35 36 44 

MI 116 119 140 240 242 271 158 148 163 20 21 25 

OH 84 87 104 175 166 178 289 288 293 27 28 33 

WI 84 87 106 97 93 81 156 152 85 - 0 0 

5-StateTotal 635 648 775 1,021 894 943 1,244 1,139 1,067 98 102 121 

 
23 

VOC NOx SO2 PM2.5

July 2005 2009 2018 2005 2009 2018 2005 2009 2018 2005 2009 2018 

Total 

IL 1,576 1,353 1,217 2,010 1,572 1,029 1,656 1,337 1,251 119 155 189 

IN 1,009 901 826 1,453 1,250 819 2,902 1,294 1,256 81 133 131 

MI 1,546 1,311 1,134 1,730 1,314 946 1,495 865 927 183 190 190 

OH 1,735 1,323 1,082 2,048 1,619 1,074 3,761 1,650 1,304 121 195 166 

WI 821 705 630 1,019 800 551 750 563 540 35 54 47 

5-StateTotal 6,687 5,593 4,889 8,260 6,555 4,419 10,564 5,781 5,280 539 727 723 

6.0 Modeling Assessment 

Provided in 40 CFR Part 51, Appendix W are guidelines for conducting regional-scale modeling to 

simulate pollutants impairing visibility. The U.S. EPA recommends the use of one of three models and 

the MRPO chose the Comprehensive Air Quality Model with extensions (CAMx). 

The air quality analysis conducted by the MRPO includes weight of evidence approaches which rely on 

extensive data analysis and modeling. Given uncertainties in emissions inventories and modeling, these 

data analyses are a necessary part of the overall technical support. 

Modeling includes base year analyses for 2005 to evaluate model performance and strategy analyses to 

assess candidate control strategies. The analyses were conducted in accordance with the U.S. EPA’s 

“Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality 

Goals for Ozone, PM2.5, and Regional Haze”, EPA-454/B-07-002, April 2007 (Modeling Guidance). 

The regional haze modeling covers the full calendar year of 2005 for the eastern U.S. and uses 36 

kilometer meteorology and modeling domains using CAMx. 

The Clean Air Act sets as a national goal, “the prevention of any future, and the remedying of any 

existing, impairment of visibility in Class 1 areas which impairment results from manmade air 

pollution”14 for regional haze. In the 5-state MRPO region, there are two Class 1 areas: Isle Royale 

National Park, MI and Seney National Wildlife Refuge, MI. The U.S. EPA visibility rules (64 FR 

35714, July 1, 1999) require reasonable progress toward achieving “natural conditions” by the year 

2064. Table 6 lists the areas that were modeled. 

Table 6 Class 1 Areas Modeled by the MRPO 

Class 1 Area Identifier State 

Acadia National Park ACAD1 Maine 

Boundary Waters Canoe Area Wilderness Area BOWA1 Minnesota 

Brigantine Wilderness Area BRIG1 New Jersey 

Caney Creek Wilderness Area CACR1 Arkansas 

Dolly Sods Wilderness Area DOSO1 West Virginia 

Hercules-Glades Wilderness Area HEGL1 Missouri 

Isle Royale National Park ISLE1 Michigan 

James River Face Wilderness Area JARI1 Virginia 

Lye Brook Wilderness Area LYBR1 Vermont 

 

14 Section 169A of the Clean Air Act 
24 

Class 1 Area Identifier State 

Mammoth Cave National Park MACA1 Kentucky 

Mingo Wilderness Area MING1 Missouri 

Seney National Wildlife Refuge SENE1 Michigan 

Shenandoah National Park SHEN1 Virginia 

Upper Buffalo Wilderness Area UPBU1 Arkansas 

Voyageurs National Park VOYA2 Minnesota 

The primary source of modeling used in this document is from "Regional Air Quality Analyses for 

Ozone, PM2.5 and Regional Haze: Technical Support Document", April 25, 2008, States of Illinois, 

Indiana, Michigan, Ohio, and Wisconsin. 

6.1 Regional Haze/Visibility 

The components of the visibility equation match up very closely to the prominent chemical forms of 

PM2.5: nitrate ion, sulfate ion, ammonium ion, organic carbon, elemental carbon, and soil (U.S. EPA, 

2007). Since these modeling applications will support PM2.5 and Regional Haze rules, model 

performance will be most rigorous for each of these PM2.5 species and coarse mass. 

One of the problems related to PM model performance evaluation involves matching inconsistent 

monitor methodologies and model specie definition. Additionally, speciated measurements rarely add 

up to measurements of total fine mass. This unexplained fraction is usually attributed to the retention of 

water on the weighed samples (Timin, 2002). Other problems with comparing speciation samples and 

Federal Reference Method (FRM) measurements include volatilization of nitrate and positive and 

negative organic carbon artifacts (Timin, 2002). 

Organic material is typically estimated from organic carbon using a factor of 1.4, which is based on the 

assumption that carbon accounts for 70% of the organic mass. Recent literature recommends a factor of 

1.6 ± 0.2 for urban aerosol and 2.1 ± 0.2 for non-urban areas that see more aged aerosols (Turpin and 

Lim, 2001; “Interagency Monitoring of Protected Visual Environments (IMPROVE)”, 2006). These 

factors are applied to observation data based on land use type before being compared to model output. 

These factors may also be used to reduce modeled estimates of organic material to organic carbon. 

Performance metrics used to describe model performance for PM2.5 species include mean bias, gross 

error, fractional bias, and fractional error (U.S. EPA, 2007). The bias and error metrics are used to 

describe performance in terms of the measured concentration units (μg/m3). Even though the 

distribution of PM2.5 is log-normal, the data is not transformed for this analysis. The model attainment 

tests outlined by U.S. EPA for the PM2.5 National Ambient Air Quality Standards (NAAQS) and RH 

Rule require relative response factors to be applied to actual concentrations and not transformed 

concentrations. No minimum value is used to eliminate data points for the purposes of this analysis.

Visibility may be estimated by two similar methods that relate light extinction to ambient PM2.5

concentrations (FLAG, 2000; U.S. EPA, 2007). Visibility will be estimated using the new equation 

recommended by the IMPROVE steering committee (IMPROVE, 2006). The new and old equations 

produce very similar estimates of light extinction in the upper Midwest. The new equation will be 

emphasized for the SIP modeling demonstration due to its more up-to-date science. 
25 

The equation shown below relates PM2.5 specie concentrations to light extinction. Additional factors of 

relative humidity adjustment factor (fRH) are included that change the light scattering of sulfate and 

nitrate based on climatologically averaged relative humidity. 

βext = 2.2*fSRH*[small sulfate] + 2.4*fS(RH)*[small nitrate] + 4.8*fLRH*[large sulfate] + 5.1*fL(RH)*[large nitrate]+ 

2.8*[small OCM] + 6.1*[large OCM] + 10*EC + 1*SOIL + 0.6*CM + 1.7*fSS(RH)*SS + βrayleigh 

βext - Estimated extinction coefficient (Mm-1) 

Sulfate - Sulfate associated with ammonium (SO4*1.375) 

Nitrate - Nitrate associated with ammonium (NO3*1.29) 

OCM - Organic carbon Mass 

EC - Elemental carbon 

SOIL - Inorganic primary PM2.5 (soil, crustal, other) 

CM - Coarse fraction particulate matter 

SS - Sea salt 

βrayleigh Light scattering due to Rayleigh scattering (site specific) 

fRH - Relative humidity adjustment factor

The apportionment of sulfate, nitrate, and organic carbon mass into small and large size fractions is 

shown below using ‘X’ as a placeholder for these species. 

Large X = ([Total X] / [20 μg/m3]) * [Total X], where [Total X] < 20 μg/m3 

Large X = [Total X], where [Total X] ≥ 20 μg/m3 

Small X = [Total X] – [Large X]

The fRH values are long-term averages that are site and month specific (U.S. EPA, 2003a; U.S. EPA 

2003b; FLAG, 2000). The light scattering due to Rayleigh is site specific (IMPROVE, 2006). The NO2

component to the light extinction equation is not included since it is not measured at Class 1 areas in the 

upper Midwest. The visibility equation is expressed as an extinction coefficient (βext) and is converted 

to deciviews using the equation below. 

Deciview = 10ln(βext/ βrayleigh)

The reasonable progress test to determine the relationship between current and future year visibility is 

expressed in deciview units. The changes in deciviews between the current and future year strategy is 

the reasonable progress test and is shown below. 

Change in Deciview = 10ln[(βext)future / (βext)base] 

- or - 

Change in Deciview = Deciviewbase – Deciviewfuture 

Visibility will be estimated for key Class 1 areas in the Midwest for the base year and various future 

year scenarios. The changes in visibility between the baseline and future year will be assessed using 

procedures in U.S. EPA’s modeling guidance document (U.S. EPA, 2007). 

1. The visibility in deciviews (dv) will be ranked from high to low at each Class 1 area for the 

calendar years 2000-2004 using the monthly and site specific fRH values and the more recent 

IMPROVE light extinction equation. 

2. The mean dv for the 20% days with the best and the 20% days with the worst visibility are 

estimated for each Class 1 area for each year of the 2000-2004 baseline period. 
26 

3. The mean observed extinction coefficient for the days during the modeling period (2005) with 

the 20% best and 20% worst visibility will be calculated. 

4. The mean predicted extinction coefficient for the corresponding 20% best and 20% worst days of 

the modeling period of the base case and future year strategy will be calculated using monthly 

site specific fRH values. 

5. The relative response factor for the 20% best and 20% worst group of days for each site for each 

of the particulate matter species in the light extinction equation is estimated. 

6. The relative response factors are multiplied by daily measured PM data during the 2000-2004 

baseline to estimate future daily values of these species. 

7. These future daily PM estimates are used to estimate light extinction for each of the previously 

identified 20% best and 20% worst days of monitored data. Light extinction is converted to dv 

and the mean value for the best and worst days for each year of the baseline period is estimated. 

8. The 5 mean dv values for the worst and best days (one from each of the 5 years) are averaged 

together for a mean value for the best and worst days. 

9. The future year mean dv values in step 8 are compared to the observed values from step 2. The 

differences are compared to established goals for reasonable progress to determine if reasonable 

progress is demonstrated. 

6.2 Regional Haze Modeling Results 

For regional haze, the calculation of future year conditions assumed: (a) baseline concentrations based 

on 2000-2004 IMPROVE data, with updated (substituted) data for Mingo, Boundary Waters, 

Voyageurs, Isle Royale, and Seney (see “Impact of Missing Data on Worst Days at Midwest Northern 

Class 1 Areas”, March 12, 2007 (revised 6/19/07)), (b) use of the new IMPROVE light extinction 

equation, and (c) use of U.S. EPA default values for natural conditions, based on the new IMPROVE 

light extinction equation. 

Pursuant to the RH Rule, states must consider several factors in establishing reasonable progress goals 

for their Class 1 areas, including the uniform rate of visibility improvement. The uniform rate of 

visibility improvement values for the 2018 planning year were derived (for the 20% worst visibility 

days) based on a straight line between the baseline concentration value (plotted in the year 2004, end 

year of the 5-year baseline period) and the natural condition value (plotted in the year 2064, the date for 

achieving natural conditions). Plots of these “glidepaths” for Class 1 areas in the eastern U.S. showing 

the worst 20% days and best 20% days are presented in Figure . A tabular summary of measured 

baseline and modeled future year dv values for these Class 1 areas are provided in Tables 7 and 8. 

These values are based upon the emissions shown in Section 5, Tables 4 and 5. Note that column 

headings, on-the-books controls, "OTB," is equal to scenario 5a and on-the-books controls plus 

adjustments for controls from states commitments, "OTB+Will Do," is equivalent to scenario 5b. Only 

emissions from EGUs are changed when moving from 5a to 5b. This information was taken from the 

MRPO Technical Support Document (TSD). Data for Smoky Mountains and Sipsey were not included 

in that report. Caney Creek was not plotted in the MRPO TSD. These are addressed individually in 

later portions of this section. 

The visibility modeling results show that the rates of visibility improvement in several Class 1 areas in 

the eastern U.S. are expected to be greater than the glidepath (i.e. further improvement needed), in 2018, 

including those in northern Michigan and several in the northeastern U.S. The rates of visibility 
27 

improvement in many other Class 1 areas in the eastern U.S. are expected to be better than the glidepath, 

e.g. Mammoth Cave and Dolly Sods, in 2018. 
28 

Figure 10 Visibility Modeling Results for Class 1 Areas in Eastern U.S. 

 Voyageurs Boundary Waters Isle Royale 

 Seney Mammoth Cave Upper Buffalo 

 Mingo Shenandoah Dolly Sods 

 Brigantine Lye Brook Acadia 
29 

Table 7 Visibility Modeling Results (Deciviews) for Class 1 Areas in Eastern U.S. (Worst 20%) 

Site 2000-2004 

Baseline 

2018 

URP 

2009 

OTB 

2009 

OTB+Will Do 

2012 

OTB 

2018 

OTB 

2018 

OTB+Will Do 

Boundary Waters 19.86 17.94 18.45 18.51 18.33 17.94 17.92 

Voyageurs 19.48 17.75 18.2 18.28 18.07 17.63 17.66 

Seney 24.38 21.64 23.1 23.1 23.04 22.59 22.42 

Isle Royale 1 21.59 19.43 20.52 20.58 20.43 20.09 20.13 

Isle Royale 9 21.59 19.43 20.33 20.37 20.22 19.84 19.82 

Hercules-Glades 26.75 23.13 24.72 24.82 24.69 24.22 24.17 

Mingo 28.15 24.27 25.88 26.13 25.68 24.74 24.83 

Caney Creek 26.36 22.91 23.39 23.55 23.29 22.44 22.4 

Upper Buffalo 26.27 22.82 23.34 23.47 23.27 22.59 22.55 

Mammoth Cave 31.37 26.64 27.11 27.41 27.01 26.1 26.15 

Dolly Sods 29.05 24.69 24 24.06 23.9 23 23.04 

Shenandoah 29.31 25.12 24.99 25.04 24.87 23.92 23.95 

James River Face 29.12 24.91 25.17 25.25 25.01 24.06 24.12 

Brigantine 29.01 25.05 25.79 25.83 25.72 25.21 25.22 

Lye Brook 24.45 21.48 22.04 22.08 21.86 21.14 21.14 

Acadia 22.89 20.45 21.72 21.75 21.72 21.49 21.49 

Table 8 Visibility Modeling Results (Deciviews) for Class 1 Areas in Eastern U.S. (Best 20%) 

Site 2000-2004 

Baseline 

2018 

URP 

2009 

OTB 

2009 

OTB+Will Do 

2012 

OTB 

2018 

OTB 

2018 

OTB+Will Do 

Boundary Waters 6.42 6.42 6.21 6.2 6.19 6.14 6.12 

Voyageurs 7.09 7.09 6.86 6.89 6.83 6.75 6.76 

Seney 7.14 7.14 7.57 7.59 7.58 7.71 7.78 

Isle Royale 1 6.75 6.75 6.62 6.64 6.59 6.6 6.62 

Isle Royale 9 6.75 6.75 6.56 6.57 6.55 6.52 6.5 

Hercules-Glades 12.84 12.84 12.51 12.56 12.32 11.66 11.64 

Mingo 14.46 14.46 14.07 14.13 13.89 13.28 13.29 

Caney Creek 11.24 11.24 10.88 10.95 10.85 10.52 10.52 

Upper Buffalo 11.71 11.71 11.13 11.19 11.08 10.73 10.74 

Mammoth Cave 16.51 16.51 15.76 15.88 15.69 15.25 15.25 

Dolly Sods 12.28 12.28 11.25 11.29 11.23 11 11.01 

Shenandoah 10.93 10.93 10.13 10.16 10.11 9.91 9.91 

James River Face 14.21 14.21 13.38 13.43 13.38 13.14 13.14 

Brigantine 14.33 14.33 14.15 14.16 14.08 13.92 13.92 

Lye Brook 6.37 6.37 6.25 6.28 6.23 6.14 6.15 

Acadia 8.78 8.78 8.86 8.88 8.86 8.82 8.82 

 URP - uniform rate of progress OTB - on-the-books controls 

 OTB+Will Do - on-the-books controls plus adjustments for controls from states commitments 
30 

7.0 Reasonable Progress Goals 

7.1 Background 

IDEM assessed each of the Class 1 areas identified in the MRPO report as being impacted by Indiana 

sources. Information provided by the MRPO and technical documents from the other RPOs are found in 

Appendix 1 and letters received from other states indicating their decisions regarding reasonable further 

progress goals, Appendix 2, were used to make these assessments. 

In determining reasonable progress for regional haze, Section 169 of the Clean Air Act and U.S. EPA’s 

visibility rule requires states to consider five factors: 

 Costs of compliance 

 Time necessary for compliance 

 Energy and non-air quality environmental impacts of compliance 

 Remaining useful life of any existing source subject to such requirements 

 Uniform rate of visibility improvement (needed to attain natural visibility conditions by 2064) 

LADCO’s “Reasonable Progress for Class 1 Areas in the Northern Midwest – Factor Analysis” (July 18, 

2007) addresses factor analysis to establish a reasonable progress goal toward achieving natural 

visibility conditions in mandatory Class 1 areas, see Appendix 9c. In addition, Appendix 9b provides 

additional information related to Indiana's emissions and visibility contributions and a detailed 

discussion of the measures needed to achieve Indiana's share of reductions. 

Since Indiana has no Class 1 areas, the states with Class 1 areas took the lead in establishing reasonable 

progress goals. Indiana participated in the discussions and provided information to assist in setting the 

goals. The states developing the plans addressed the four factors and developed the uniform rate of 

progress glidepaths. 

In the following sections, these analyses are summarized. A detailed analysis of each area is included in 

the appendices. In the previous section, MRPO modeling was used to identify areas possibly impacted 

by Indiana sources. In Sections 7.3 through 7.7, VISTAS modeling results are used to provide 

additional evidence regarding progress in achieving visibility improvements. 

7.2 Voyageurs National Park and Boundary Waters Canoe Area Wilderness Area 

Indiana sources have shown an impact on these Class 1 areas through modeling studies. Minnesota has 

determined that several other states are significant contributors to visibility impairment in these areas at 

this time and is working with them as they develop their reasonable progress goals. 

The cover letter from the Minnesota Pollution Control Agency contains their reasonable progress 

analysis and can be found in Appendix 3. Indiana has participated in the consultation calls and the 

MRPO modeling process used by Minnesota to reach their conclusions. 

As can be seen in the map in the Minnesota letter in Appendix 3, page 3-7, Indiana is barely in the Areas 

of Influence that impact their Class 1 areas. Minnesota has developed a long term strategy sufficient to 
31 

meet their 2018 reasonable progress goals, and has not requested additional assistance from Indiana. 

Further, reductions for Indiana BART sources (and other states) resulting from new settlements, 

committed controls, current controls, and the proposed Transport Rule will be greater than those 

anticipated during the earlier modeling studies. Table 11 contains a table showing these projections. 

While specific modeling results will not be available for some time, it follows that Indiana’s influence 

will be further reduced. 

Indiana concurs that this is the best approach for addressing visibility impairment at Voyageurs and 

Boundary Waters Class 1 areas at this time. Therefore, no further analysis for this SIP is necessary. 

7.3 Mammoth Cave National Park 

Indiana sources have shown an impact on this Class 1 area through modeling studies. However, since 

sources in Kentucky and Indiana must comply with Clean Air Interstate Rule (CAIR) requirements, the 

Kentucky analysis has determined that these controls are sufficient to address visibility in this area. 

Further, VISTAS modeling has shown that Mammoth Cave is more than meeting its uniform rate of 

progress (glidepath) and has determined that no additional reductions are needed from Indiana at this 

time. 

The cover letter from the Kentucky Department for Environmental Protection contains this information, 

Appendix 3, page 3-25. The results of the long term strategy developed by Kentucky and VISTAS 

provide anticipated visibility improvements below the glidepath, as can be seen in following figure. 
32 

Figure 11 Mammoth Cave Uniform Rate of Progress Glidepath 

Analyses performed by the MRPO show similar results. Indiana concurs that this approach is an 

effective means of addressing visibility impairment at Mammoth. In addition, an Indiana source, Alcoa, 

was determined to significantly impact this area and is the subject of the Indiana BART rule. This is 

covered in Section 8. 

7.4 Great Smoky Mountains National Park 

In the MRPO summary of Class 1 areas impacted by sources from within the MRPO (Appendix 1), 

Indiana was determined to contribute to visibility impairment in this Class 1 area. Since that time, 

VISTAS has conducted several analyses to assist in developing reasonable progress goals. 

The following figure shows that the long term strategy developed for this Class 1 area easily meets the 

glidepath through 2018. 
33 

Figure 12 Great Smoky Mountains Uniform Rate of Progress Glidepath 

In the "Technical Analyses Supporting Regional Haze State Implementation Plan," June 8, 2007, North 

Carolina Department of Environment and Natural Resources stated that contributions from other RPOs 

are comparatively small and the greatest benefits would likely be from further EGU reductions within 

the VISTAS states. Indiana was not contacted by Tennessee or North Carolina regarding consultations 

for this area and believes that no further analysis for a long term control strategy is necessary at this 

time. 

7.5 Sipsey Wilderness Area 

In the MRPO summary of Class 1 areas impacted by sources from within the MRPO (Appendix 1), 

Indiana was determined to contribute to visibility impairment in this Class 1 area. Since that time, 

VISTAS conducted several analyses to assist in developing reasonable progress goals. The following 

figure shows that the long term strategy for this Class 1 area meets the glidepath through 2018. 
34 

Figure 13 Sipsey Uniform Rate of Progress Glidepath 

Indiana has not been contacted by Alabama regarding consultations for this area and believes that no 

further analysis for a long term control strategy is necessary at this time. 

7.6 James River Face Wilderness Area, Shenandoah National Park, Dolly Sods/Otter Creek 

Wilderness Areas 

In the MRPO summary of Class 1 areas impacted by sources from within the MRPO (Appendix 1), 

Indiana was determined to contribute to visibility impairment in these more distant Class 1 areas. Since 

that time, VISTAS has conducted several analyses to assist in developing reasonable progress goals. 

The results of the long term strategy developed by the states and VISTAS provide anticipated visibility 

improvements below the glidepath. Figures 14, 15, and 16 show the glidepaths for each of these areas. 
35 

Figure 14 James River Face Uniform Rate of Progress Glidepath 

Figure 15 Shenandoah Uniform Rate of Progress Glidepath 
36 

Figure 16 Dolly Sods Uniform Rate of Progress Glidepath 

Neither Virginia nor West Virginia contacted IDEM to participate in consultations for these areas. The 

four factor analyses performed by the VISTAS states and resulting long term strategies indicate that 

controls closer to the Class 1 areas provide the most effective reductions at this time. Additionally, the 

long term strategies provide anticipated visibility improvements below the glidepaths. Indiana concurs 

with these conclusions. 

7.7 Caney Creek and Upper Buffalo Wilderness Areas, AR, and Hercules-Glades and Mingo 

Wilderness Areas, MO 

These areas were identified in early MRPO modeling and other analyses as being impacted by Indiana 

sources. Indiana was invited to participate in the consultation process for these areas, and attended the 

conference phone calls. Arkansas and Missouri notified IDEM that they consider the consultation 

process finished. They have developed long term strategies that meet Rate of Progress Goals by 2018. 

Further, Southwestern Indiana was included in the area of influence which impacts these areas 

(Appendix 3, page 52). The controls in existence in the 2002 inventory, those installed after 2002, and 

controls planned out to 2018, were analyzed. A large majority of these sources will be controlled by 

2018, which will further aid in the progress toward their reasonable progress goals. 

 

Figures 17 - 20 show glidepaths resulting from the long term strategies developed by the states. All the 

Class 1 areas are projected to meet their reasonable progress goals in 2018. 

At this time, they have concluded that no reductions are necessary from Indiana. The letter providing 

this information is in Appendix 3, page 45. 
37 

Figure 17 Caney Uniform Rate of Progress Glidepath 

Uniform Rate of Reasonable Progress Glide Path

Caney Creek Wilderness - 20% Data Days

26.36

25.38

22.91

20.45

17.99

15.52

13.06

11.58

21.48

0

5

10

15

20

25

30

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

Year

Haz ni ess Index (Dec vi ei ws)

Glide Path Natural Condition (Worst Days) Observation Method 1 Prediction

Figure 18 Upper Buffalo Uniform Rate of Progress Glidepath 

Uniform Rate of Reasonable Progress Glide Path

Upper Buffalo Wilderness - 20% Data Days

26.27

25.29

22.84

20.39

17.94

15.49

13.04

11.57

21.61

0

5

10

15

20

25

30

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

Year

Haz ni ess Index (Dec vi ei ws)

Glide Path Natural Condition (Worst Days) Observation Method 1 Prediction
38 

Figure 19 Hercules-Glades Uniform Rate of Progress Glidepath 

Uniform Rate of Reasonable Progress Glide Path

Hercules-Glades Wilderness - 20% Data Days

26.75

25.72

23.14

20.57

17.99

15.42

12.84

11.30

22.19

0

5

10

15

20

25

30

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

Year

Haz ni ess Index (Dec vi ei ws)

Glide Path Natural Condition (Worst Days) Observation Method 1 Prediction

Figure 20 Mingo Uniform Rate of Progress Glidepath 

Uniform Rate of Reasonable Progress Glide Path

Mingo - 20% Data Days

28.02

26.98

24.37

21.77

19.17

16.56

13.96

12.40

23.21

0

5

10

15

20

25

30

35

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

Year

Haz ni ess Index (Dec vi ei ws)

Glide Path Natural Condition (Worst Days) Observation Method 1 Prediction

7.8 Isle Royale National Park and Seney National Wildlife Refuge, MI 

Indiana sources have shown an impact on these Class 1 areas through modeling studies. Indiana and 

the other Midwestern states participated extensively in the MRPO modeling and data analysis efforts for 

fine particulates, ozone, and haze in these areas. Michigan determined that existing and on-the-books 

controls (those controls scheduled in response to regulatory actions within this time period), combined 
39 

with reductions necessary to meet the new 24-hour fine particulates standard and possibly the new ozone 

standard will be sufficient to meet their reasonable progress goals. 

The letter from the Michigan Department of Air Quality, Appendix 3, page 3-56, contains their 

conclusions. Indiana concurs that this is the best approach for addressing visibility impairment at Isle 

Royale National Park and Seney National Wildlife Refuge Class 1 areas at this time. Therefore, no 

further analysis for this SIP is necessary. 

In the Michigan SIP Submittal for Regional Haze, October 2010, Tables 10.3.2.c and 10.3.2.d showed 

the top 30 facilities impacting visibility at Isle Royale and Seney, inside and outside the state of 

Michigan. Included on this list were three Indiana facilities, Rockport in Spencer County, Gallagher in 

Floyd County, and Clifty Creek in Jefferson County. 

There are controls planned for all three of these facilities. Rockport, which has 2 units, signed a consent 

decree in October 2007 in which they agreed to install SCR and FGD on Unit 1 by December 31, 2017 

and SCR and FGD on Unit 2 by December 31, 2019. Gallagher, which has four units, signed a consent 

decree in December 2009, which according to U.S. EPA, by January 1, 2013, will reduce SO2 emissions 

by 35,000 tons per year compared to 2008 and NOx by 2100 tons per year. Clifty began construction of 

FGDs for all five units, but postponed completion when CAIR was vacated, citing economic concerns. 

It is anticipated these will be completed after 2014 as the Transport Rule becomes effective. 

Finally, in January 2011, NIPSCO signed a consent decree. NIPSCO operates four large EGUs in 

northern Indiana. While these facilities were not listed as among the largest sources impacting Seney 

and Isle Royale, because of their size and proximity these controls will result in less visibility 

impairment. Specifically, Mitchell will be permanently shut down, two new FGDs at Schahfer and one 

at Michigan City will be added, and upgrades made to two FGDs at Schahfer and two upgrades to FGDs 

at Bailly. Also, some NOx controls will be added and upgraded, along with a system wide cap on 

overall emissions. According to U.S. EPA, these upgrades and additions will result in SO2 reductions of 

about 46,000 tons per year and NOx reductions of 18,000 tons per year compared to 2008. These 

controls will be phased in through the end of 2015. 

Comparing these control requirements to LADCO modeling, Clifty Creek was not included in any year, 

Gallagher was not included in any year, and Rockport was included starting in 2012. For the NIPSCO 

sources, Bailly was included as existing controls, Michigan City was not included in any year, Mitchell 

was not included in any year, and for Schahfer, two units were included as existing controls and two 

were not included in any year. Overall, reductions from these settlements are much greater than 

anticipated by the modeling and will provide greater visibility benefits. 

This summarizes reasonable progress for Indiana EGUs that likely have the greatest impacts upon 

Michigan’s Class I areas. Indiana will continue to work with Michigan through the MRPO to evaluate 

the progress in the Class 1 areas. 

More specific information regarding these controls is in Table 11. The U.S. EPA Compliance and 

Enforcement website, http://cfpub.epa.gov/compliance/cases/, has the consent decrees and supporting 

information. 
40 

7.9 Acadia National Park, ME, Moosehorn Wilderness Area, ME, Great Gulf Wilderness 

Area, NH, Brigantine Wilderness Area, NJ, and Lye Brook Wilderness Area, VT (MANE-VU) 

Indiana sources have shown an impact on these Class 1 areas through the MRPO and MANE-VU 

modeling projects. Indiana, along with the other MRPO states, has participated in consultations with 

MANE-VU. 

MANE-VU released “Assessment of Reasonable Progress for Regional Haze in MANE-VU Class 1 

Areas - Methodology for Source Selection, Evaluation of Control Options, and Four Factor Analysis, 

July 2007” which supported requests of states outside that area to examine controls for specific types of 

sources. This assessment is a large document and is not included in this submittal. It is available online 

at the MANE-VU website, http://www.manevu.org, under “Consultations - Projects and Work 

Products.” The resulting request is referred to as the “MANE-VU Ask”. 

MANE-VU Ask: In its “Statement of the Mid-Atlantic/Northeast Visibility Union (MANE-VU) 

Concerning a Request for a Course of Action by States Outside of MANE-VU Toward Assuring 

Reasonable Progress” (June 20, 2007), Appendix 3, pages 64 - 65, MANE-VU suggested that several 

control strategies should be pursued for adoption and implementation15, including: 

 Application of Best Available Retrofit Technology 

 90% (or greater) reduction in SO2 emissions from each of the EGU stacks on MANE-VU’s list 

of 167 stacks (located in 19 states), which reflect those stacks determined to be reasonably 

anticipated to cause or contribute to visibility impairment in the MANE-VU Class 1 areas 

 28% reduction in non-EGU (point, area, on-road, and off-road) SO2 emissions relative to on-thebooks and on-the-way 2018 projections 

 Continued evaluation of other measures, including measures to reduce SO2 and NOx emissions 

from coal-burning facilities and promulgation of new source performance standards for wood 

combustion 

 Further reduction in power plant SO2 (and NOx) emissions beyond the current Clean Air 

Interstate Rule program 

Of the 167 stacks, 15 are from 9 sources in Indiana (Appendix 3, page 63). Most of these stacks have or 

will have post-combustion emission controls (i.e., scrubbers). A list of these sources, along with the 

control information is in Table 11. 

The two sets of charts from MRPO "Round 5" modeling show the culpability of geographic areas to 

visibility conditions in two Class 1 areas in the northeast. The left charts are the best days, the right 

charts are the worst days. 

 

15 The June 20 statement was transmitted to the MRPO States in letters dated July 30 from Anna Garcia, acting Executive 

Director, MANE-VU. 
41 

Figure 21 Acadia Visibility Impact Modeling 

The figure on the left is modeled from the best 20% visibility days and the figure on the right is 

modeled from the worst 20% visibility days. 

Figure 22 Lye Brook Visibility Impact Modeling 

The figure on the left is modeled from the best 20% visibility days and the figure on the right is 

modeled from the worst 20% visibility days. 

These charts demonstrate that Indiana sources have insignificant impacts on these areas. 

The MRPO conducted modeling to evaluate the various levels of controls in place or planned between 

2008 and 2018. From this "Round 5" modeling, Table 9 was produced for MANE-VU Class 1 areas. 
42 

Table 9 MRPO Round 5 Modeling Results (dv) 

Best 20% Baseline 2018 2009 2009 2012 2018 2018 

Site 2000-2004 URP Value Base Will Do Base Base Will Do 

Brigantine 14.33 14.33 14.15 14.16 14.08 13.92 13.92 

Lye Brook 6.37 6.37 6.25 6.28 6.23 6.14 6.15 

Acadia 8.78 8.78 8.86 8.88 8.86 8.82 8.82 

 

Worst 20% Baseline 2018 2009 2009 2012 2018 2018 

Site 2000-2004 URP Value Base Will Do Base Base Will Do 

Brigantine 29.01 25.05 25.79 25.83 25.72 25.21 25.22

Lye Brook 24.45 21.48 22.04 22.08 21.86 21.14 21.14 

Acadia 22.89 20.45 21.72 21.75 21.72 21.49 21.49

However, in "Recent MANE-VU Projections of Visibility for 2018", MANE-VU Stakeholder Briefing, 

April 4, 2008, it is stated, "The Uniform Rate is achieved and exceeded at all MANE-VU Class I sites." 

This presentation is available on the MANE-VU website, www.nescaum.org/topics/regionalhaze/regional-haze-documents. 

These results show that for the northeastern Class 1 areas, controls already implemented and on-thebooks may or may not result in achievement of reasonable progress goals. However, Indiana, along 

with the other MRPO states, has continued to work with MANE-VU states. Results of this work have 

assisted U.S. EPA in developing the recently proposed Air Transport Rule, which is discussed in the 

next section. One of the intentions of this proposed rule is to provide for reductions of regional 

pollutants to the level that upwind states are not contributing to nonattainment or interference with 

maintenance of the 1997 ozone and annual PM2.5 and 2006 24-hour PM2.5 standards. These reductions 

also will eliminate much of the regional contributions to regional haze. U.S. EPA has also committed to 

timely development of a second Transport Rule that will address contributions from non-EGU sectors. 

These sources were also of concern to MANE-VU and MRPO workgroups. 

At this time, Indiana believes that these actions adequately address visibility concerns and are 

appropriate to meet reasonable progress goals given Indiana’s marginal impact on those areas. 

8.0 Best Available Retrofit Technology 

BART Guidelines are a component of the July 1, 1999 Regional Haze regulations, that are intended to 

protect and improve visibility in national parks and wilderness areas. 

The process of establishing BART emission limitations includes identification of those sources that meet 

the definition of “BART-eligible source”, a determination of whether these sources are emitting any air 

pollutant that may be contributing to any impairment of visibility in a Class 1 area, and identification of 

the appropriate type and the level of control for reducing emissions. 
43 

8.1 BART - Eligible Sources in Indiana 

The BART-eligible sources in Indiana are shown in the following table. The BART-eligible sources 

were identified using the methodology in the “Regional Haze Regulations and Guidelines for Best 

Available Retrofit Technology (BART) Determinations; Final Rule" (40 CFR Part 51). 

Table 10 Indiana Sources with BART-Eligible Units 

County County ID Plant ID Name

Cass 017 00006 Logansport Municipal Light & Power 

Cass 017 00005 ESSROC Materials, Inc. 

Clark 019 00008 ESSROC Cement Corporation 

Dearborn 029 00002 American Electric Power-Tanners Creek 

Gibson 051 00013 Duke Energy – Gibson 

Jasper 073 00008 NIPSCO - R. M. Schahfer 

Lake 089 00318 Mittal Steel USA Inc.- Indiana Harbor West 

Lake 089 00003 BP Products North America, Inc. - Whiting Refinery 

Lake 089 00112 Carmeuse Lime, Inc. 

Lake 089 00210 State Line Energy, L.L.C. 

Lake 089 00121 U.S. Steel - Gary Works 

Lake 089 00316 Mittal Steel USA Inc.- Indiana Harbor East 

Lake 089 00117 NIPSCO - D. H. Mitchell Station 

Laporte 091 00021 NIPSCO - Michigan City 

Lawrence 093 00002 Lehigh Cement Company 

Marion 097 00033 IPL Harding Street Station 

Marion 097 00034 Citizens Thermal Energy 

Pike 125 00002 Indianapolis Power & Light/AES Petersburg 

Pike 125 00001 Hoosier Energy - Ratts Station 

Porter 127 00002 NIPSCO - Bailly Station 

Porter 127 00001 Mittal Steel USA Inc.- Burns Harbor 

Posey 129 00002 SABIC Innovative Plastics (formerly GE Plastics) 

Posey 129 00010 SIGECO - A. B. Brown 

Putnam 133 00002 Buzzi Unicem USA 

Sullivan 153 00005 Hoosier Energy - Merom Station 

Tippecanoe 157 00012 Purdue University 

Vermillion 165 00001 Duke Energy – Cayuga 

Vermillion 165 00009 Eli Lilly and Company-Clinton Labs 

Vigo 167 00021 Duke Energy – Wabash River 

Warrick 173 00002 & 00007 ALCOA Inc. 

Warrick 173 00001 SIGECO - F. B. Culley Generating Station 

Wayne 177 00009 Richmond Power & Light 

IDEM identified sources within the BART source categories and sent a survey to obtain additional 

information to develop a list of BART-eligible sources. Based on the surveys and subsequent 

discussions and comments, IDEM determined that sources in Table 10 have at least one BART-eligible 

unit. Supporting documentation is in Appendix 5 - BART Eligible Units. 
44 

8.2 Sources Subject to BART 

IDEM conducted further modeling in coordination with the MRPO to determine which BART-eligible 

sources are subject to BART. Using dispersion modeling (Option 1 in the BART Guidelines), IDEM 

determined that the following non-EGUs were subject to BART: Alcoa Inc., ESSROC Cement 

Corporation, SABIC Innovative Plastics (formerly GE Plastics), and Mittal Steel USA Inc.-Burns 

Harbor. Modeling indicated that the following EGUs were subject to BART: ALCOA Inc., Hoosier 

Energy - Ratts Station, Richmond Power & Light, State Line Energy, NIPSCO - D. H. Mitchell Station, 

NIPSCO - Michigan City, NIPSCO - Bailly Station, SIGECO - A. B. Brown, and SIGECO - F. B. 

Culley Generating Station. 

In addition, IDEM identified the following fossil-fuel fired generating power plants as having a capacity 

in excess of 750 megawatts: Duke Energy - Gibson, Duke Energy - Cayuga, Indianapolis Power & 

Light/AES Petersburg, IPL - Harding Street Station, NIPSCO - R. M. Schahfer, American Electric 

Power-Tanners Creek, Duke Energy - Wabash River, and Hoosier Energy - Merom Station. 

Indiana accepted the U.S. EPA analysis that CAIR achieves greater progress than BART and may be 

used by States as a BART substitute (70 FR 39137). The Indiana Air Pollution Control Board, on 

November 1, 2006, adopted CAIR for the Indiana EGUs to participate in the cap and trade program. 

CAIR, therefore, satisfies the BART NOx and SO2 requirements for these sources. The PM impact on 

visibility on Class 1 areas was addressed for these sources. One EGU, ALCOA-Warrick Power Plant 

Boiler # 4, was determined to be subject to BART. 

In December 2008, the DC Circuit Court remanded CAIR to U.S. EPA without vacatur because it found 

that "allowing CAIR to remain in effect until it is replaced by a rule consistent with our opinion would at 

least temporarily preserve the environmental values covered by CAIR." The CAIR requirements are 

currently in place and CAIR's regional control programs are operating while U.S. EPA develops 

replacement rules in response to the remand. 

On July 6, 2010, U.S. EPA proposed a CAIR replacement, the Clean Air Transport Rule (TR), which as 

proposed, will achieve emission reductions of NOx and SO2 beyond those originally required by CAIR 

through additional air pollution reductions from power plants beginning in 2012. Therefore, Indiana 

believes that the Transport Rule will also achieve greater progress than BART. The TR is proposed to 

be initially in the form of a Federal Implementation Plan, which would not require action by Indiana to 

be put into place. 

Table 11 contains a listing of all Indiana EGUs and the Megawatt capacities of each unit. It highlights 

the units which are BART-eligible and notes which units were included in the MANEVU “ask” list, 

which was described in Section 7.9. 
45 

Table 11 Indiana BART-eligible Electric Generating Units covered by CAIR 

INDIANA COAL-FIRED UNITS EPA IPM 3.0 2006 runs 

LADCO Round 5 

Runs 

BART-eligible Units

SO2 NOx 

 

*MANEVU Ask

 

FACILITY_

NAME 

UNIT

ID 

Capacity 

MWatts 

2009 + Projected 

SO2_CONTROL 

2009 + Projected 

NOx_CONTROL 

IPM 

Existing 

IPM 

2010 

Retrofit 

IPM 

2015 

Retrofit 

IPM 

2020 

Retrofit 

LADCO 

2012 

Retrofit 

LADCO 

2018 

Retrofit 

A B Brown 

Generating 

Station 1 250 Dual Alkali FGD 

Selective Catalytic 

Reduction SCR+FGD 

A B Brown 

Generating 

Station 2 250 Dual Alkali FGD 

Selective Catalytic 

Reduction SCR+FGD 

Alcoa 

Allowance 

Management 

Inc 1 144 

Wet Limestone 

FGD (2008) 

Low NOx Burner

Technology w/ 

Overfire Air 

LNB 

w/SOFA 

Alcoa 

Allowance 

Management 

Inc 2 144 

Wet Limestone 

FGD (2008) 

Low NOx Burner

Technology w/ 

Overfire Air 

LNB 

w/SOFA 

Alcoa 

Allowance 

Management 

Inc 3 144 

Wet Limestone 

FGD (2008) 

Low NOx Burner

Technology w/ 

Overfire Air 

LNB 

w/SOFA 

Alcoa 

Allowance 

Management 

Inc 4 300 

Wet Limestone 

FGD (2008) 

Low NOx Burner

Selective Catalytic 

Reduction SCR FGD FGD FGD FGD 

Bailly 

Generating 

Station 7 160 Wet Limestone 

Overfire Air / 

Selective Catalytic 

Reduction (2008) SCR+FGD 

Bailly 

Generating 

Station 8 320 Wet Limestone 

Overfire Air / 

Selective Catalytic 

Reduction SCR+FGD 

Cayuga* 1 500 

Wet Limestone 

(2008 - 95%) 

Low NOx Burner

Technology w/ 

Separated OFA 

FGD+LNB 

w/SOFA SCR SCR SCR SCR 

Cayuga* 2 495 

Wet Limestone 

(2008 - 95%) 

Low NOx Burner

Technology w/ 

Separated OFA 

FGD+LNB 

w/SOFA SCR SCR SCR SCR 

Clifty Creek* 1 217 

(FGD Scheduled 

possibly 2013) 

Overfire Air 

Selective Catalytic 

Reduction FGD+SCR 

Clifty Creek* 2 217 

(FGD Scheduled 

possibly 2013) 

Overfire Air 

Selective Catalytic 

Reduction FGD+SCR 

Clifty Creek* 3 217 

(FGD Scheduled 

possibly 2013) 

Overfire Air 

Selective Catalytic 

Reduction FGD+SCR 

Clifty Creek* 4 217 

(FGD Scheduled 

possibly 2013) 

Overfire Air 

Selective Catalytic 

Reduction FGD+SCR 
46 

INDIANA COAL-FIRED UNITS EPA IPM 3.0 2006 runs 

LADCO Round 5 

Runs 

BART-eligible Units

SO2 NOx 

 

*MANEVU Ask

 

FACILITY_

NAME 

UNIT

ID 

Capacity 

MWatts 

2009 + Projected 

SO2_CONTROL 

2009 + Projected 

NOx_CONTROL 

IPM 

Existing 

IPM 

2010 

Retrofit 

IPM 

2015 

Retrofit 

IPM 

2020 

Retrofit 

LADCO 

2012 

Retrofit 

LADCO 

2018 

Retrofit 

Clifty Creek* 5 217 

(FGD Scheduled 

possibly 2013) 

Overfire Air 

Selective Catalytic 

Reduction FGD+SCR 

Clifty Creek* 6 217 

(FGD Scheduled 

possibly 2013) Overfire Air FGD SCR SCR SCR SCR SCR 

Dean H 

Mitchell 

Generating 

Station 11 125 Shut Down Shut Down LNB 

Dean H 

Mitchell 

Generating 

Station 4 125 Shut Down Shut Down 

Comb. 

Optimization SCR SCR

Dean H 

Mitchell 

Generating 

Station 5 125 Shut Down Shut Down 

Comb. 

Optimization SCR SCR 

Dean H 

Mitchell 

Generating 

Station 6 110 Shut Down Shut Down LNB SCR SCR

Edwardsport 7-1 40 

Unit will retire in 

2012, IGCC will 

replace all the units 

in 2012 

Unit will retire in 

2012, IGCC will 

replace all the units 

in 2012    Retire Retire Retire Retire Retire 

Edwardsport 7-2 40 

Unit will retire in 

2012, IGCC will 

replace all the units 

in 2012 

Unit will retire in 

2012, IGCC will 

replace all the units 

in 2012    Retire Retire Retire Retire Retire 

Edwardsport 8-1 40 

Unit will retire in 

2012, IGCC will 

replace all the units 

in 2012 

Unit will retire in 

2012, IGCC will 

replace all the units 

in 2012    Retire Retire Retire Retire Retire 

F B Culley 

Generating 

Station 2 90 Wet Limestone 

Low NOx Burner

Technology (Dry 

Bottom only) FGD+LNB SNCR SNCR 

F B Culley 

Generating 

Station 3 270 Wet Limestone 

Low NOx Burner

Technology (Dry 

Bottom only) 

Selective Catalytic 

Reduction FGD+SCR 

Frank E 

Ratts 1SG1 122 

U.S. EPA 

settlement, plantwide from 2009 

levels 42% 

reduction - 2012, 

58% - 2014 

Low NOx Burner

Technology (Dry 

Bottom only) OFA2008 LNB SCR SCR 
47 

INDIANA COAL-FIRED UNITS EPA IPM 3.0 2006 runs 

LADCO Round 5 

Runs 

BART-eligible Units

SO2 NOx 

 

*MANEVU Ask

 

FACILITY_

NAME 

UNIT

ID 

Capacity 

MWatts 

2009 + Projected 

SO2_CONTROL 

2009 + Projected 

NOx_CONTROL 

IPM 

Existing 

IPM 

2010 

Retrofit 

IPM 

2015 

Retrofit 

IPM 

2020 

Retrofit 

LADCO 

2012 

Retrofit 

LADCO 

2018 

Retrofit 

Frank E 

Ratts 2SG1 121 

U.S. EPA 

settlement, plantwide from 2009 

levels 42% 

reduction - 2012, 

58% - 2014 

Low NOx Burner

Technology (Dry 

Bottom only) OFA2008 LNB SCR SCR 

Gibson* 1 630 Wet Limestone 

LNB w/ Overfire 

Air Selective 

Catalytic Reduction SCR+FGD 

Gibson* 2 630 Wet Limestone 

Low NOx Burner

Technology w/ 

Overfire Air 

Selective Catalytic 

Reduction SCR+FGD 

Gibson* 3 630 Wet Limestone 

Low NOx Burner 

Technology w/ 

Overfire Air 

Selective Catalytic 

Reduction SCR+FGD 

Gibson* 4 622 Wet Limestone 

Low NOx Burner 

Technology w/ 

Overfire Air 

Selective Catalytic 

Reduction SCR+FGD 

Gibson 5 620 Wet Limestone 

Low NOx Burner 

Technology w/ 

Overfire Air 

Selective Catalytic 

Reduction SCR+FGD 

Harding 

Street Station 

(EW Stout) 50 109 

LNB w/ Separated 

OFA Selective 

Non-catalytic 

Reduction SNCR 

Harding 

Street Station 

(EW Stout) 60 109 

LNB w/ Separated 

OFA Selective 

Non-catalytic 

Reduction SNCR 

Harding 

Street Station 

(EW Stout)* 70 435 Wet Limestone 

LNB w/ Closedcoupled/Separated 

OFA Selective 

Catalytic Reduction SCR FGD FGD FGD FGD FGD 

IPL Eagle 

Valley 

Generating 

Station 3 43 
48 

INDIANA COAL-FIRED UNITS EPA IPM 3.0 2006 runs 

LADCO Round 5 

Runs 

BART-eligible Units

SO2 NOx 

 

*MANEVU Ask

 

FACILITY_

NAME 

UNIT

ID 

Capacity 

MWatts 

2009 + Projected 

SO2_CONTROL 

2009 + Projected 

NOx_CONTROL 

IPM 

Existing 

IPM 

2010 

Retrofit 

IPM 

2015 

Retrofit 

IPM 

2020 

Retrofit 

LADCO 

2012 

Retrofit 

LADCO 

2018 

Retrofit 

IPL Eagle 

Valley 

Generating 

Station 4 56 

Low NOx Burner 

Technology w/ 

Separated OFA 

LNB 

w/SOFA 

IPL Eagle 

Valley 

Generating 

Station 5 62 

Low NOx Burner 

Technology w/ 

Separated OFA 

LNB 

w/SOFA 

IPL Eagle 

Valley 

Generating 

Station 6 99 

Low NOx Burner 

Technology w/ 

Separated OFA 

LNB 

w/SOFA 

Merom 1SG1 507 

upgrade FGD-90% 

2012, upgrade to 

95% 2014 

Selective Catalytic 

Reduction Low Nox 

Burner Technology 

w/ Overfire Air SCR+FGD 

Merom 2SG1 493 

upgrade FGD-90% 

2012, upgrade to 

95% 2014 

Selective Catalytic 

Reduction Low NOx

Burner Technology 

w/ Overfire Air SCR+FGD 

Michigan 

City 

Generating 

Station 12 469 

Overfire Air - 

Selective Catalytic 

Reduction SCR 

Hg 

Control 

Hg 

Control 

Petersburg 1 232 Wet Limestone 

Low NOx Burner

Technology w/ 

Closedcoupled/Sep. OFA FGD+LNB SCR SCR 

Petersburg 2 407 Wet Limestone 

LNB w/ Closedcoupled/Separated 

OFA Selective 

Catalytic Reduction FGD+SCR 

Petersburg 3 510 Wet Limestone 

LNB w/ Closedcoupled/Separated 

OFA Selective 

Catalytic Reduction FGD+SCR 

Petersburg 4 545 Wet Limestone 

Low NOx Burner 

Technology w/ 

Closedcoupled/Sep. OFA FGD+LNB SCR SCR SCR 

R Gallagher* 1 140 

Shut down by 

2/1/12 or Convert to 

NG 1/1/13 

Shut down by 

2/1/12 or Convert to 

NG 1/1/13 LNB 
49 

INDIANA COAL-FIRED UNITS EPA IPM 3.0 2006 runs 

LADCO Round 5 

Runs 

BART-eligible Units

SO2 NOx 

 

*MANEVU Ask

 

FACILITY_

NAME 

UNIT

ID 

Capacity 

MWatts 

2009 + Projected 

SO2_CONTROL 

2009 + Projected 

NOx_CONTROL 

IPM 

Existing 

IPM 

2010 

Retrofit 

IPM 

2015 

Retrofit 

IPM 

2020 

Retrofit 

LADCO 

2012 

Retrofit 

LADCO 

2018 

Retrofit 

R Gallagher* 2 140 

Dry Sorbent 

Technology 1/1/11 

Low NOx Burner 

Technology w/ 

Overfire Air LNB 

R Gallagher* 3 140 

Shut down by 

2/1/12 or Convert to 

NG 1/1/13 

Shut down by 

2/1/12 or Convert to 

NG 1/1/13 LNB 

R Gallagher* 4 140 

Dry Sorbent 

Technology 1/1/11 

Low NOx Burner 

Technology w/ 

Overfire Air LNB 

R M 

Schahfer 

Generating 

Station 14 431 

Overfire Air 

Selective Catalytic 

Reduction SCR 

Hg 

Control 

Hg 

Control 

R M 

Schahfer 

Generating 

Station 15 472 

LNB (Dry Bottom 

only) A 35% 

efficient stratified 

overfire air system 

was added in 2008 LNB 

Hg 

Control 

Hg 

Control 

R M 

Schahfer 

Generating 

Station 17 361 

Wet Limestone LNB w/ Closedcoupled/Separated 

OFA 

SCR 

FGD+ 

LNB 

FGD+ 

LNB 

FGD+ 

LNB 

R M 

Schahfer 

Generating 

Station 18 361 

Wet Limestone LNB w/ Closedcoupled/Separated 

OFA 

LNB 

 FGD+ 

LNB 

 FGD+ 

LNB 

 FGD+ 

LNB 

Rockport* MB1 1300 

FGD 12/31/17 TR 

allowances < CAIR 

2012 and 2014 

LNB (Dry Bottom 

only) (SCR 

12/31/17) LNB w/OFA FGD FGD 

FGD+ 

SCR FGD 

FGD+ 

SCR 

Rockport* MB2 1300 

FGD 12/31/17 TR 

allowances < CAIR 

2012 and 2014 

Low NOx Burner 

Technology (Dry 

Bottom only) (SCR 

12/31/19) LNB w/OFA FGD FGD 

FGD+ 

SCR FGD 

FGD+ 

SCR 

State Line 

Generating 

Station (IN) 3 187 

State Line 

Generating 

Station (IN) 4 303 Overfire Air SCR SCR 

SCR+Hg 

Control SCR 

SCR 

(-Hg 

Control) 

Tanners 

Creek* U1 140 

Burn only coal with 

no more than 1.2 

lb/MMBtu annual 

average 

Low NOx Burner 

Technology (Dry 

Bottom only) A 

30% efficient 

SNCR will be in 

place in 2010. 

SNCR will operate 

year round OFA 
50 

INDIANA COAL-FIRED UNITS EPA IPM 3.0 2006 runs 

LADCO Round 5 

Runs 

BART-eligible Units

SO2 NOx 

 

*MANEVU Ask

 

FACILITY_

NAME 

UNIT

ID 

Capacity 

MWatts 

2009 + Projected 

SO2_CONTROL 

2009 + Projected 

NOx_CONTROL 

IPM 

Existing 

IPM 

2010 

Retrofit 

IPM 

2015 

Retrofit 

IPM 

2020 

Retrofit 

LADCO 

2012 

Retrofit 

LADCO 

2018 

Retrofit 

Tanners 

Creek* U2 140 

Burn only coal with 

no more than 1.2 

lb/MMBtu annual 

average 

Low NOx Burner 

Technology (Dry 

Bottom only) A 

30% efficient 

SNCR will be in 

place in 2010. 

SNCR will operate 

year round OFA 

Tanners 

Creek* U3 200 

Burn only coal with 

no more than 1.2 

lb/MMBtu annual 

average 

Low NOx Burner 

Technology (Dry 

Bottom only) A 

30% efficient 

SNCR will be in 

place in 2010. 

SNCR will operate 

year round OFA 

FGD+ 

SCR 

FGD+ 

SCR 

Tanners 

Creek* U4 500 

Burn only coal with 

no more than 1.2% 

sulfur content 

annual average Overfire Air OFA 

Wabash 

River Gen 

Station* 1 85 IGCC IGCC 

Wabash 

River Gen 

Station* 2 85 Shut Down 9-30-09 Shut Down 9-30-09 LNB 

Wabash 

River Gen 

Station* 3 85 Shut Down 9-30-09 Shut Down 9-30-09 LNB SNCR SNCR 

Wabash 

River Gen 

Station* 4 85 

Low NOx Burner 

Technology w/ 

Overfire Air LNB 

Wabash 

River Gen 

Station* 5 95 Shut Down 9-30-09 Shut Down 9-30-09 LNB SNCR SNCR 

Wabash 

River Gen 

Station* 6 318 

TR allocation in 

2014 < CAIR 

Low NOx Burner

Technology w/ 

Separated OFA LNB 

FGD+ 

SCR 

FGD+ 

SCR 

Whitewater 

Valley 1 34.77 

Low NOx Burner 

Technology w/ 

Separated OFA 

Ammonia Injection 

Overfire Air LNB 

Whitewater 

Valley 2 62.8 Other 

Low NOx Burner

Technology w/ 

Separated OFA 

Ammonia Injection 

Overfire Air LNB 
51 

Table 11 also shows several control scenarios: 

“2009+Projected SO2 Controls”: These are SO2 controls currently in place, under construction, or 

required by legal action in the foreseeable future. 

“2009+Projected NOx Controls”: These are NOx controls currently in place, under construction, or 

required by legal action in the foreseeable future. 

EPA IPM 3.0 2006 runs - There were several scenarios modeled by U.S.EPA to support the CAIR rule. 

The information in the table is taken directly from their parsed files: 

“IPM existing”: These are the combinations of NOx and SO2 controls that were in existence, 

according to their records at the time. 

“IPM 2010 Retrofit”: This column summarizes any controls added after “IPM existing”. 

“IPM 2015 Retrofit”: This column summarizes any controls added after 2010. The information 

contained is cumulative to 2015 – it includes all retrofits to 2015. 

“IPM 2020 Retrofit”: This column summarizes any controls added after 2015. The information 

contained is cumulative to 2020 – it includes all retrofits to 2020. 

For LADCO Round 5 Modeling Runs, the IPM 3.0 files were used with some adjustments based upon 

information from the states. Different years were modeled because of key regulatory program dates. 

The information in these columns is cumulative, as in the EPA scenarios: 

“LADCO 2012 Retrofit”: Very similar to EPA’s IPM 2015 Retrofit. 

“LADCO 2018 Retrofit”: Very similar to EPA’s IPM 2020 Retrofit. 

The purpose of this table is to show the assumptions made in the various modeling scenarios upon which 

this Regional Haze SIP is based, compared to the best current information available regarding Indiana 

EGU controls. Several of the utilities completed NOx and SO2 control projects around 2008 to meet 

CAIR requirements. These varied from the IPM assumptions in some cases. Further, several consent 

decrees have been completed to the present time, These decrees include: American Electric Power, 

October 9, 2007, which affects Rockport and Tanners Creek; Duke R Gallagher, December 22, 2009; 

Hoosier Energy REC, July 23, 2010, which affects Merom and Frank E Ratts; and Northern Indiana 

Public Service, January 13, 2011, which affects Bailly Generating Station, Dean H Mitchell Generating 

Station, Michigan City Generating Station, and R M Schahfer Generating Station. This information was 

not available in 2006 when the IPM projections were made, and in some cases, add significant controls 

not assumed in the modeling for a particular year. 
52 

8.3 BART Analysis 

IDEM began the BART rulemaking process in August 2006. Following the due process of rulemaking 

which included the notices of hearings and comments, the Indiana Administrative Code at 326 IAC 26-

1, Best Available Retrofit Technology, was final adopted on October 3, 2007 and became effective 

February 22, 2008. A copy of this rule is in Appendix 7. 

The rule requires that sources subject to BART, upon notification from the department, submit to the 

department a BART analysis. The rule incorporates by reference the BART Guidelines codified as 

Appendix Y at 40 CFR 51. The analysis should be performed following those guidelines. The analysis 

must address at a minimum SO2, NOx, and particulate matter (PM) and consider the following factors: 

(1) the cost of compliance, (2) the energy and non-air quality environmental impacts of compliance, (3) 

any existing pollution control technology in use at the source, (4) the remaining useful life of the source, 

and (5) the degree of visibility improvement that may reasonably be anticipated from the use of BART. 

The BART Guidelines require that the States consider, at a minimum, certain control alternatives in 

determining BART controls. These alternatives include: BACT, LAER, NSPS, and MACT, as 

applicable, pollution prevention, use of retrofit controls and, if available, improvement of existing 

controls. In addition, the rule allows sources to propose alternatives to source-specific BART, provided 

the alternative achieves greater reasonable progress towards improving visibility. The alternative could 

include emissions controls at different locations of the same source, different sources, or at a source not 

subject to BART. The requirements for sources that choose an alternative to source-specific BART, in 

detail, are included in 326 IAC 26-1 and 40 CFR 51.308(e). 

The department was required to review the analyses for completeness and approvability in accordance 

with 326 IAC 26-1, the BART Guidelines, and 40 CFR 51.308(e). The emission limits representing 

BART or an alternative to BART are to be included in the sources’ Part 70 permits and submitted to 

U.S. EPA for approval into the SIP. The sources shall be required to comply with these requirements 

within five years of the effective date of the state rule, i.e., in 2013. 

Of the sources identified as BART-eligible, modeling indicated that one non-EGU source, Alcoa, was 

subject to BART. IDEM identified several EGUs subject to BART. However, as provided by the 

federal rule, IDEM assumed NOx and SO2 BART requirements are met by the participation of these 

sources in the CAIR NOx and SO2 trading program. Other non-EGU sources were also identified as 

being BART-eligible. These sources, SABIC Innovative Plastics-Mt. Vernon, ArcelorMittal-Burns 

Harbor LLC, and ESSROC Cement Corp.-Speed submitted modeling analyses showing that they did not 

contribute significantly to visibility impairment at any Class 1 areas. IDEM found that these analyses 

met all applicable criteria and have accepted the findings. An analysis for each follows. 

8.4 BART Determination and Modeling for Burns Harbor 

ArcelorMittal, LLC (Burns Harbor), formerly known as ISG Burns Harbor, operates a steelmaking 

facility located in Burns Harbor, Porter County, Indiana. In accordance with the BART Guidelines, 

Burns Harbor was identified as a BART-eligible source. 

IDEM initially conducted long range transport modeling of the potential emissions from the BARTeligible emission units from Burns Harbor using the CALPUFF model. IDEM determined Burns Harbor 

to be subject to BART for having visibility impacts on nearby Class I areas. Subsequently, Burns 
53 

Harbor submitted its own BART exemption modeling analysis. This analysis used the maximum 24-

hour average actual emission rates of sulfur dioxide and nitrogen oxides and compared modeled results 

with the annual average natural background light coefficient, according to the BART guidance. Burns 

Harbor conducted CALPUFF modeling at the four nearest Class I areas in which Burns Harbor had the 

greatest visibility impact, which were Mammoth Cave, Seney National Wildlife Refuge, Mingo 

Wilderness, and Isle Royale National Park. The CALPUFF results showed Burns Harbor would not be 

subject to BART. The following describes IDEM’s revised BART modeling and Burns Harbor’s BART 

exemption modeling analysis and results. 

8.4.1 IDEM’s BART Determination Process 

IDEM sent BART surveys in the fall of 2005 to sources that were identified as having possible BARTeligible emission units. Potential BART-eligible sources at Burns Harbor’s were identified as the Power 

Station including Boilers #7-#12, #1 and #2 Coke Battery pushing and underfire, Blast Furnaces C & D, 

Sinter Windbox, Steelmaking Stations #1 - #3, Steelmaking Vessels #1 and #2, Hot Strip Furnaces #1 - 

#3, 160” Plate Mill Furnaces #1 - #2 and #5 - #8, 110” Plate Mill Furnaces #1 - #3, and Blast Furnaces 

C & D and steelmaking fugitives. These Burns Harbor emission units, described at the end of this 

section, met all three of the BART-eligible criteria for SO2, NOx, and PM, as listed below: 

1.) Identify whether emission units are in one of the 26 source categories - Burns Harbor operates a 

steelmaking facility, identified as one of the 26 listed categories. 

2.) Identify whether emission units were in existence on August 7, 1977 and began operation after 

August 2, 1962 - The construction dates for the BART-eligible emission units at Burns Harbor 

were estimated within the BART eligibility timeframe.

3.) Compare potential emissions from emission units to 250 tons/yr or more threshold of a visibility 

impairing pollutant (NOx, SO2 and PM) - Potential NOx and SO2 emissions from all BART-eligible 

emission units exceed 250 tons/year of any single visibility impairing pollutant with potential NOx

emissions of 7743.0 tons/yr and potential SO2 emissions of 18769.0 tons/yr. Potential PM10

emissions from all BART-eligible units at Burns Harbor totaled 1168.9 tons/yr.

Source specific stack and detailed emissions information were requested to be used in IDEM’s BART 

determination modeling analyses. Burns Harbor submitted the survey results to IDEM on March 2, 

2006. IDEM conducted preliminary CALPUFF modeling, in which potential NOx, SO2, and PM10

emissions from Burns Harbor’s BART-eligible emission units were modeled to determine the visibility 

impacts. Results showed the visibility impacts from Burns Harbor exceeded the BART threshold of the 

98th percentile of 0.5 dv with a total of thirty days over 0.5 dv for 2002, thirty-nine days over 0.5 dv for 

2003, and forty-four days over 0.5 dv for 2004 at the sixteen Class 1 areas modeled. Burns Harbor had 

the most visibility impact days at Seney National Wildlife Refuge with ten days in 2002, seventeen days 

in 2003 and nineteen days in 2004. Based on the information provided, Burns Harbor was determined to 

be subject to BART. 

OCS Environmental, Inc. and ENSR Corporation prepared the Burns Harbor BART modeling analysis, 

conducted CALPUFF modeling, and submitted the results to IDEM on May 13, 2008. Additional 

information was submitted by Burns Harbor and its consultants and the information gathered from these 

submittals aided IDEM’s review of Burns Harbor’s subject to BART determination. This material is 

contained in Appendix 5a. 
54 

8.4.2 IDEM’s BART Modeling Process 

IDEM conducted long range transport modeling in coordination with the MRPO to determine which 

BART-eligible sources have visibility impacts that exceed BART modeling thresholds and are subject to 

BART. LADCO created a “Single Source Modeling to Support Regional Haze BART Modeling 

Protocol” for the states of Indiana, Illinois, Michigan, Wisconsin, and Ohio. This document can be 

found in Appendix 5a. IDEM used this protocol in order to remain consistent with the other MRPO 

states in conducting its subject to BART determinations. 

CALPUFF was identified by U.S. EPA as the best regulatory modeling application available for long 

range transport of primary pollutants and the only EPA-approved model for predicting a single source’s 

contribution to visibility impacts. CALPUFF inputs include several modules within CALPUFF to 

determine transport (CALPUFF), meteorology (CALMET), inorganic chemistry effects (POSTUTIL), 

and post-processing of the results (CALPOST). The versions used in the IDEM’s CALPUFF modeling 

are as follows: 

CALPUFF version 5.711a, Level 040716 CALMET version 5.53a, Level 040716 

CALPOST version 5.51, Level 030709 CALMM5 version 2.0, Level 021111 

POSTUTIL version 1.4, Level 040818 

Modeling options used in CALPUFF are consistent with guidance found in the Interagency Workgroup 

on Air Quality Modeling (IWAQM), “Phase 2 Summary Report and Recommendations for Modeling 

Long Range Transport Impacts” (EPA-454/R-98-019). Any modifications in the CALPUFF modeling 

approach from the IWAQM documents are discussed in detail in the MRPO CALPUFF modeling 

protocol. LADCO created a version of CALPUFF that could be executed on a Linux Red Hat operating 

system and created input files in order to conduct the CALPUFF modeling. 

As a result of MRPO discussions with U.S. EPA, the change in dv is compared with natural visibility 

conditions on the 20% best days and not the average visibility conditions. The natural visibility 

conditions are defined as the 20% best days, as listed in the U.S. EPA’s “Guidance for Estimating 

Natural Visibility Conditions under the Regional Haze Rule” (EPA, 2003). IDEM has accepted 

previous BART determination analyses using the average annual natural background conditions if the 

subject to BART source conducted more refined CALPUFF modeling in accordance with state or 

federally approved protocols. 

8.4.3 Modeling Domain and Meteorology 

The modeling domain used for the MRPO CALPUFF modeling analysis was a Lambert conformal grid 

projection centered at 97 West, 40 North with true latitudes at 33 North and 45 North and origin at (-900 

km, -1620 km). The horizontal domain consisted of 97 36-kilometer cells in the east-west direction and 

90 36-kilometer cells in the north-south direction. Approximately 15 kilometers in the vertical 

atmosphere were resolved with 16 vertical layers. Landuse and terrain data were extracted from global 

datasets, taken from United States Geological Survey (USGS) Composite Theme Grid landuse and 

USGS Digital Elevation Model terrain height. 
55 

IDEM modeling covered three years of meteorological data (2002-2004) with the meteorological inputs 

taken from the prognostic meteorological model using four-dimensional data-assimilation (FDDA). 

Meteorological Model 5 (MM5 version 3.6) output was used to supply hourly meteorological data for 

CALMET input. Observation data was included in the ETA analysis fields to initialize MM5. 

8.4.4 Class 1 Areas 

There were sixteen Class I areas analyzed in the MRPO area with discrete receptors covering the nearby 

Class I areas. The Class I areas were taken from the National Park Service Class I area receptor index. 

Receptor grids with a resolution of 1-kilometer were placed at each Class I area with a total of 4,434 

receptors analyzed. The sixteen Class I areas and the states where the Class I areas are located are listed 

below: 

Boundary Waters Canoe Area – MN Brigantine Wilderness Area – NJ 

Dolly Sods/Otter Creek Wilderness – WV Great Gulf Wilderness – NH 

Great Smoky Mountains National Park – TN Hercules-Glades Wilderness– MO 

Isle Royale National Park – MI James River Face Wilderness – VA 

Linville Gorge Wilderness– NC Lye Brook Wilderness – VT 

Mammoth Cave National Park – KY Mingo Wilderness Area – MO 

Seney National Wildlife Refuge – MI Shenandoah National Park – VA 

Sipsey Wilderness – AL Voyageurs National Park – MN 

8.4.5 Visibility Impairment Pollutants Analyzed 

Pursuant to the U.S. EPA and MRPO guidance, SO2, NOx, and PM are considered the primary visibility 

impairing pollutants. U.S. EPA recommends states use their judgment in determining whether volatile 

organic compounds (VOCs) and ammonia contribute to visibility impairment. SO2, NOx, and PM10

were modeled using the CALPUFF model for the Burns Harbor analysis. Visibility impairing pollutants 

such as VOCs and ammonia were not modeled but may be evaluated at a later date. The Burns Harbor 

submittal contained information which included the methodologies for estimating daily emission rates 

from all the BART-eligible units at Burns Harbor, as found in Appendix 5a. The 24-hour average 

emission rates from the highest emitting day are preferred in the CALPUFF modeling analysis to be 

consistent with the Modeling Guidance determining visibility impairment for BART determinations. 

Burns Harbor calculated its emissions from its combustion units and process units using several methods 

to determine the maximum 24-hour emissions. Combustion unit emissions were calculated using actual 

daily fuel use records and emission factors based on fuel sampling, stack testing, or U.S. EPA’s AP-42. 

Process unit emissions were calculated using the maximum 24-hour production rates and emission 

factors derived from stack tests and U.S. EPA’s AP-42. For the smaller process units that only had 

monthly production data, the average daily production rates were calculated and used to determine the 

24-hour average emission rates from the highest emitting day. 

The stack parameters of all the BART-eligible sources at Burns Harbor, as well as the area source 

parameters that define the slag pits and steelmaking fugitive area dimensions are summarized in Table 

18 at the end of this section. The coordinates of the Burns Harbor BART-eligible emission units are 

based on Lambert Conformal Conic (LCC) in order to project on the CALPUFF modeling domain. 
56 

8.4.6 IDEM’s Subject to BART Determination Modeling Results 

IDEM based its initial CALPUFF modeling on potential emissions from Burns Harbor’s BART-eligible 

emission units. The differences between IDEM’s initial BART determination modeling and the revised 

modeling conducted from Burns Harbor’s BART exemption modeling submittals were the 24-hour 

average emission rate estimates from the highest emitting day supplied by Burns Harbor. 

Methodologies explaining Burns Harbor’s emission calculations are found in Appendix 5a. The 

emission estimates meet the BART guidance for using the 24-hour average emission rates from the 

highest emitting day in the CALPUFF modeling. 

The criteria used to determine if a source is “contributing” to visibility impairment is the 98th percentile 

that is equal to 0.5 dv for MRPO States using a maximum 24-hour emission rate and the peak value that 

is equal to 0.5 dv for MRPO States using an actual 24-hour emission rate. The 98th percentile is 

interpreted as any source with more than 21 days of visibility impairment over the 3 year modeling 

period or 7 days of visibility impairment in any one of the 3 years modeled is “contributing” to visibility 

impairment. 

Results of IDEM’s revised BART determination modeling showed that the 98th percentile dv impact 

from Burns Harbor was above 0.5 dv; with a total of ten days over 0.5 dv for 2002, seventeen days over 

0.5 dv in 2003 and nineteen days over 0.5 dv in 2004. Table 12 shows IDEM’s revised CALPUFF 

modeling results with the top eight rankings of the highest dv impacts from Burns Harbor for 2002 

through 2004. The total number of days which modeled above 0.5 dv for all three modeled years is 

forty-six, above the twenty-two day threshold for 98th percentile of the cumulative three-year modeled 

period, as shown below in Table 13. Therefore, based on IDEM’s CALPUFF analysis, Burns Harbor’s 

BART-eligible emission units are subject to BART. 

Table 12 IDEM’s Revised CALPUFF Modeling Results for Burns Harbor 

Impact 

Rank 

2002 - Seney 

dv/Day 

2003 - Seney

dv/Day 

2004 - Seney 

dv/Day 

1st 1.397 (274) 1.886 (321) 2.415 (364) 

2nd 1.104 (263) 1.471 (281) 1.745 (250) 

3rd 1.102 (315) 1.413 (350) 1.335 (321) 

4th 1.071 (273) 1.285 (294) 1.328 (247) 

5th 0.964 (245) 1.247 (32) 1.267 (60) 

6th 0.875 (55) 1.238 (232) 1.170 (231) 

7th 0.592 (159) 0.998 (315) 0.882 (3) 

8th 0.561 (102) 0.993 (233) 0.766 (85) 

Table 13 Number of Modeled Days over 0.5 dvs for Class 1 Areas 

Year 2002 2003 2004 Total

Seney 10 17 19 46 

Mammoth Cave 7 1 4 12 

Mingo 5 3 3 11 

Isle Royale 1 4 4 9 
57 

8.4.7 IDEM’s Culpability Modeling Results for Burns Harbor 

IDEM conducted additional CALPUFF modeling for Burns Harbor to determine if certain BARTeligible emissions points within Burns Harbor were contributing more to the visibility impacts on 

surrounding Class 1 areas then other emission points. To conduct the culpability analysis, BARTeligible emission points were grouped according to emissions. Five separate CALPUFF runs were 

conducted based on the following: 

Group 1 – Power Station Boilers #7 - #12: SO2 emissions = 218.31 grams/sec; NOx = 29.60 grams/sec 

Group 2 - #1, #2 Coke Battery Underfire: SO2 emissions = 133.42 grams/sec; NOx = 99.98 grams/sec 

Group 3 – Windbox/C&D Blast Furnaces: SO2 emissions = 109.11 grams/sec; NOx = 50.19 grams/sec 

Group 4 - #1, #2, #3 Hot Strip Furnace/#1, #2 160” Plate Mill Furnace: 

 SO2 emissions = 67.07 grams/sec; NOx = 31.17 grams/sec 

Group 5 - #1,#2 Coke Battery Pushing/Blast Furnace C&D Casthouse/ #1, #2 Steelmaking HMD 

Stations/Steel Making Vessel #3/Steelmaking FM Boiler/#5-#8 160” Plant Mill Furnace/#1,#2 110” 

Plate Mill Furnace/Steelmaking HMC Station #3/110” Plate Mill Normalizing Furnace: 

 SO2 emissions = 3.82 grams/sec; NOx = 8.64 grams/sec 

Results of IDEM’s culpability modeling are shown below in Table 14. Separately, each source group 

showed impacts below the 98thpercentile of the 0.5 dv visibility threshold. The source group with the 

maximum impact was the Group 1 Power Station Boilers #7-#12. 

Table 14 IDEM’s Culpability Modeling Results for Burns Harbor 

Impact 

Rank 

2002 – Seney 

Max. dv/# of Days 

2003 – Power Station 

Max. dv/# of Days 

2004 – Power Station 

Max. dv/# of Days 

Power 

Station 0.557 1 0.629 3 0.785 3 

Underfire 0.479 0 0.674 1 0.865 2 

Windbox 0.331 0 0.469 0 0.589 1 

Furnaces 0.229 0 0.318 0 0.382 0 

Other 0.152 0 0.29 0 0.212 0 

While this analysis does not constitute a subject to BART determination, it shows which sources 

contribute more to higher visibility impact days. The power station boilers, coke battery underfire, and 

windbox/blast furnace groups have the highest amount of impacts days over 0.5 dv. 

8.4.8 Burns Harbor’s BART Determination Modeling 

Burns Harbor submitted modeling for its BART determination, using information and inputs taken from 

the VISTAS BART Modeling Protocol, the MRPO BART Modeling Protocol, and IDEM’s initial 

CALPUFF input files. Burns Harbor used the latest EPA-approved version of CALMET (version 5.8) 

to create a more refined 6-kilometer CALMET data set from 2002 through 2004. Burns Harbor’s 

approach to processing the CALMET data is referenced in Section 3.0 “Meteorological Data” in their 
58 

Source Specific BART Modeling Report: ArcelorMittal Burns Harbor LLC, found in Appendix 5a. This 

approach was accepted by IDEM after consultation with U.S. EPA, Region 5. 

Burns Harbor used the latest EPA-approved version of CALPUFF (version 5.8) along with selected 

MRPO options listed in the MRPO “Single Source Modeling to Support Regional Haze BART 

Modeling Protocol”. IDEM’s preliminary CALPUFF modeling used a more conservative extinction 

coefficient (20% best day natural background), due to the 36-kilometer modeling grid used by the 

MRPO, rather than an annual average natural background coefficient. Burns Harbor’s use of a more 

refined 6-kilometer grid warranted the use of the average annual natural background concentrations for 

Class I areas in the eastern United States, pursuant to U.S. EPA’s “Guidance for Estimating Natural 

Visibility Conditions Under the Regional Haze Program” (EPA-454/B-03-005). 

Information from the LADCO MRPO protocol was used in the modeling and the protocol approved by 

U.S. EPA included the domain seasonal ammonia values, taken from annual 2002 CAMx simulations, 

which represented the best available information to conduct CALPUFF modeling for the MRPO states. 

Burns Harbor used background ammonia values of 0.3 ppb in January through March with 0.5 ppb the 

rest of the year, which follows MRPO protocol for BART modeling. For the purposes of BART 

analyses, the U.S. EPA has determined that it did not intend to limit States to the use of the 20% best 

visibility days. States may use 20% best visibility days or annual average natural background values. 

IDEM conducted additional CALPUFF runs, using Bondville ammonia data collected from November 

2003 through October 2005. This data was not available at the time the LADCO MRPO BART 

modeling protocol was created and distributed to the LADCO states in early 2006. Below in Table 15 is 

the comparison of the 2002 seasonal averages with the 2003 to 2005 Bondville average monitored 

monthly ammonia data. 

Table 15 Comparison of Ammonia Concentrations (ppb) for CALPUFF modeling for 

ArcelorMittal 

Data Source Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 

CAMx 2002 0.3 0.3 0.3 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5

Bondville 03-05 0.43 0.57 2.16 2.31 1.69 1.45 1.5 1.7 1.58 1.81 2.17 0.57 

The new IMPROVE equation is used to estimate light extinction, and was used to determine the 

visibility impacts from Burns Harbor. The new IMPROVE equation approach was accepted by U.S. 

EPA and the Federal Land Managers for previous BART modeling analyses and is referenced in Section 

4.0 “CALPUFF Modeling” in the Source Specific BART Modeling Report: ArcelorMittal Burns Harbor 

LLC. This is found in Appendix 5a. 

Table 16 below shows the results of Burns Harbor’s modeling, submitted on September 4, 2008. The 

CALPUFF results show visibility impacts below the 98th percentile of the 0.5 dv threshold at the four 

nearest Class 1 areas: Mammoth Cave in Kentucky, Seney National Wildlife Refuge and Isle Royale 

National Park in Michigan, and Mingo Wilderness Area in Missouri. Results are summarized in Table 

17. Visibility impacts for an individual year or the 3-year cumulative total do not exceed the 98th

percentile of the 0.5 dv threshold at any Class 1 areas. 
59 

Table 16 Burns Harbor’s CALPUFF Modeling Results over 0.5 Dv 

Impact 

Rank 

2002 

dv/Location/(day) 

2003 

dv/Location/(day) 

2004 

dv/Location/(day) 

1st 0.751 at Seney (314) 1.165 at Seney (320) 1.030 at Seney (344) 

2nd 0.750 at Seney (269) 0.695 at Seney (31) 0.891 at Seney (363) 

3rd 0.568 at Seney (261) 0.54 at Seney (350) 0.865 at Seney (320) 

4th 0.501 at Seney (50) 0.508 at Seney (280) 0.845 at Seney (79) 

5th 0.45 at Seney (222) 0.487 at Seney (231) 0.794 at Seney (249) 

6th 0.369 at Seney (273) 0.471 at Seney (66) 0.673 at Seney (78) 

7th 0.359 at Seney (161) 0.398 at Seney (293) 0.547 at Seney (2) 

8th 0.346 at Seney (272) 0.375 at Seney (342) 0.464 at Seney (230) 

Table 17 Number of Modeled Days over 0.5 dv for Class 1 Areas 

Year Seney Mammoth 

Cave 

Mingo Isle Royale 

2002 4 2 3 0 

2003 4 3 1 2 

2004 7 1 0 2 

TOTAL 15 6 4 4 

8.4.9 Comparison of Burns Harbor and IDEM BART Determination Modeling 

Due to Burns Harbor’s use of more refined CALPUFF and CALMET 6-kilometer grid files, differences 

in the results occurred compared to IDEM’s review. Based on the changes from the MRPO 36-

kilometer grid and use of the 20% best visibility days to the 6-kilometer grid and annual average natural 

background values used by Burns Harbor, the number of days over the 0.5 dv threshold were lowered by 

5 to 7 days. 

Comparison of the Burns Harbor CALPUFF modeling results using the MRPO background ammonia 

concentrations and the 2003 – 2005 Bondville data showed only slight increases in overall light 

extinction and the delta deciview changes. The largest light extinction change was 1.06% and the delta 

deciviews change was 0.084 dv at Seney. There was an increase in the number of days compared to the 

BART threshold using the revised ammonia background at Mingo and Seney National Wildlife Refuges, 

however the results when calculated using the new IMPROVE model did not change. A summary of 

results for Burns Harbor, ESSROC Cement Corporation - Speed and SABIC can be found in Appendix 

9e. The new IMPROVE equation spreadsheet results for Burns Harbor are included. 

In addition, Burns Harbor’s use of the new IMPROVE equation resulted in lower visibility impacts. 

Burns Harbor conducted a comparison of the old and new IMPROVE equations on their results and 

showed that for Seney, the new IMPROVE equation lowered the number of days with visibility impacts 

over the 0.5 dv threshold by 3 to 4 days. Table 18 shows a comparison of IDEM’s 36 kilometer results 

with the previous IMPROVE equation and the new IMPROVE equation. 
60 

Table 18 IDEM’s Revised CALPUFF Modeling Results at Seney 

Comparing old and new IMPROVE equations

Seney 

2002 

IMPROVE 

2003 

IMPROVE

2004 

IMPROVE 

Impact Rank Old New Old New Old New 

1st 1.40 0.76 1.89 1.05 2.42 1.35 

2nd 1.10 0.61 1.47 0.77 1.75 0.95 

3rd 1.10 0.60 1.41 0.76 1.33 0.74 

4th 1.07 0.57 1.28 0.68 1.33 0.72 

5th 0.96 0.51 1.25 0.66 1.27 0.66 

6th 0.87 0.45 1.24 0.67 1.17 0.64 

7th 0.59 0.29 1.00 0.55 0.88 0.46 

8th 0.56 0.29 0.98 0.53 0.77 0.41 

Total Days over 0.5 

DV 10 5 17 8 19 6 

As illustrated, the new IMPROVE equation lowered the number of visibility impact days above 0.5 dv at 

Seney National Wildlife Refuge by 5 to 13 days. Resulting dv values were reduced by approximately 

50%. Results for Mammoth Cave, Mingo Wilderness Area and Isle Royale National Park can be found 

in Appendix 5a. 

Burns Harbor used default H2O2 background concentrations of 1.0 compared to the MRPO’s seasonal 

H2O2 background concentrations, which varied from 0.5 to 3.5. This difference was not significant as 

these variables are only used when the option for aqueous phase reactions are taken into account. 

Another change was the total natural background extinction coefficients used by Burns Harbor were 

allocated to soils instead of distributed among sulfates, nitrates, organic and elemental carbon, coarse 

mass and soil. This change did not significantly affect visibility results as explained in Section 4.0 

“CALPUFF Modeling” in their Source Specific BART Modeling Report: ArcelorMittal Burns Harbor 

LLC. 

IDEM’s review of the Burns Harbor modeling has shown that the refined modeling and use of the new 

IMPROVE equation and the annual average natural background concentrations have resulted in lower 

visibility impacts. Based on the more refined grid approach, Burns Harbor has demonstrated that the 

number of days with visibility impacts from the source fall below the visibility threshold of 22 days 

above 0.5 dv and the source will not be subject to BART. 

 

8.4.10 Summary of Burns Harbor BART Determination Analysis 

In accordance with 70 FR 39104 and the criteria set forth by U.S. EPA for sources which might be 

BART-eligible, Burns Harbor was identified as a BART-eligible source. IDEM conducted 

dispersion/long range transport modeling of the BART-eligible emissions units from Burns Harbor and 

determined Burns Harbor to be subject to BART. Subsequently, Burns Harbor submitted a BART 
61 

modeling analysis and through updated emission estimates, revised stack parameters, refined grid 

modeling, use of annual average natural background concentrations, and determination of visibility 

impacts using the new IMPROVE equation, indicated Burns Harbor’s BART-eligible emissions units 

would not be subject to BART. IDEM’s review of Burns Harbor’s modeling analysis and the revised 

emission rates show that Burns Harbor will not be subject to BART, with the 98th percentile dv value 

below the 0.5 dv threshold at surrounding Class I areas. Therefore, the BART-eligible units from Burns 

Harbor are not subject to BART and no further analysis is required. 

Table 19 BART-eligible Stack Parameters for Burns Harbor 

Emission Unit Base 

Elevation 

LLC 

East 

LLC 

North 

Stack 

Height 

Stack 

Diameter 

Exhaust 

Velocity 

Exhaust 

Temperature 

POINT Source (m) (km) (km) (m) (m) (m/sec) (

o

K)

Power Stations (Boilers #7 - 

#12) 187.14 816.32 225.26 67.06 3.43 13.34 505.00

#1 Coke Battery Pushing 187.54 816.09 224.28 20.12 0.76 9.44 323.00

#1 Coke Battery Underfire 187.15 816.02 224.26 76.81 3.78 7.15 547.00

#2 Coke Battery Pushing 187.15 816.13 224.04 26.82 2.44 20.20 335.00

#2 Coke Battery Underfire 187.14 816.02 224.10 75.90 4.18 4.48 505.00

Sinter Windbox Stack 187.15 815.98 225.24 24.08 2.39 55.12 319.00

Blast Furnace D Casthouse 187.14 816.14 225.30 18.90 1.56 24.70 533.00

Blast Furnace C Stoves 187.15 816.18 225.27 61.26 3.48 15.89 519.00

Blast Furnace D Stoves 187.14 816.15 225.42 61.26 3.59 14.93 519.00

Blast Furnace C Casthouse 187.14 816.14 225.30 18.90 1.56 24.70 533.00

Steelmaking HMD Station 

#1

187.14 816.38 225.89 25.91 2.05 12.95 305.00

Steelmaking HMD Station 

#2

187.14 816.41 225.89 25.91 3.04 5.89 305.00

Steelmaking Vessels #1 

and #2

187.15 816.41 225.91 24.99 6.02 5.65 325.00

Steelmaking Vessels #3 187.15 816.41 225.99 11.58 3.71 2.64 332.00

Steelmaking FM Boiler 187.15 816.56 225.89 67.66 1.99 1.79 478.00

Hot Strip Furnace #1 187.14 816.97 225.23 41.45 4.30 7.06 811.00

Hot Strip Furnace #3 187.14 817.01 225.23 41.45 3.97 8.81 811.00

Hot Strip Furnace #2 187.14 817.00 225.23 41.45 4.30 7.02 811.00

160 “ Plate Mill Furnace #1 187.14 816.98 225.06 54.25 3.10 4.37 673.00

160 “ Plate Mill Furnace #2 187.14 817.0 225.06 54.25 3.10 4.09 693.00

160 “ Plate Mill Furnace #5

187.14 817.02 225.06 39.92 1.95 12.48 783.00

160 “ Plate Mill Furnace #6 

and #7

187.14 817.02 224.94 32.92 2.24 9.99 783.00

160 “ Plate Mill Furnace #8 187.14 817.02 224.92 50.90 1.74 2.99 673.00

110 “ Plate Mill Furnace #1 

and #2

187.14 817.02 224.83 54.56 4.44 2.13 838.00

Steelmaking HMD Station 

#3

187.14 816.47 225.92 25.91 2.05 12.95 305.00

110 “ Plate Mill Normalizing 

Furnace

187.14 816.82 224.54 45.72 1.92 4.27 305.00

Base 

Elevation

LLC 

East

LLC 

North

Release 

Height

Area Side 

Length Initial Vertical

AREA Source (m) (km) (km) (m) (m) (m)

Blast Furnace C Slag Pit 187.14 816.15 225.38 50.00 30.00 30.00

Blast Furnace D Slag Pit 187.14 816.13 225.52 50.00 40.00 30.00

Steelmaking Fugitives 187.14 816.44 225.86 50.00 150.00 150.0

8.5 BART Determination and Modeling for ESSROC Cement Corporation - Speed 

ESSROC Cement Corporation (ESSROC) operates a Portland cement manufacturing facility located in 

Speed, Clark County, Indiana. In accordance with the BART Guidelines and criteria for BART-eligible 

sources, ESSROC was identified as a BART-eligible source. 
62 

IDEM initially conducted long-range transport modeling of the potential emissions from the BARTeligible emission units from ESSROC using the CALPUFF model. IDEM determined ESSROC to be 

subject to BART for having visibility impacts on nearby Class I areas. Subsequently, ESSROC 

submitted their own BART exemption modeling analysis using the 24-hour average actual emission 

rates from the highest emitting day, according to the BART Guidance. Based on IDEM’s comments, 

ESSROC submitted additional information concerning the SO2 and NOx emissions used in the 

CALPUFF modeling. ESSROC’s CALPUFF results showed ESSROC would not be subject to BART. 

This information is all contained in Appendix 5b. This document contains IDEM review of ESSROC’s 

BART modeling analysis and the results of IDEM’s revised BART modeling. IDEM’s results showed 

that the visibility impairment from the ESSROC’s sulfur dioxide and nitrogen oxide emissions would 

not exceed thresholds established in the BART Guidelines and, therefore, will not be subject to BART. 

8.5.1 IDEM’s BART Determination Process 

IDEM sent out BART surveys in the fall of 2005 to sources that were identified as having possible 

BART-eligible emission units. ESSROC’s Kilns #1 and #2 were identified as potential BART-eligible 

sources as these two ESSROC emission units met all three of the BART-eligible criteria, as listed 

below: 

1.) Identify whether emission units are in one of the 26 source categories - ESSROC operates a 

Portland cement plant, identified as one of the 26 listed categories. 

2.) Identify whether emission units were in existence on August 7, 1977 and began operation after 

August 2, 1962 - The construction date of Kiln #1 was 1971 and Kiln #2 was in existence before 

August 7, 1977 and operating after August 1962.

3.) Compare potential emissions from emission units to 250 tons/yr or more threshold of a visibility 

impairing pollutant (i.e. sulfur dioxide (SO2), nitrogen oxide (NOx) and particulate matter (PM)) - 

Potential NOx and SO2 emissions from both kilns exceed 250 tons/year of any single visibility 

impairing pollutant with potential NOx emissions of 3,600.4 tons/yr and potential SO2 emissions of 

12,772.1 tons/yr. Potential PM10 emissions from all BART-eligible units at ESSROC totaled 895.1 

tons/yr.

Source specific stack and detailed emissions information was requested to be used in IDEM’s BART 

determination modeling analyses. A BART survey was sent to ESSROC, but no response was received 

from the company; therefore, ESSROC was determined to be subject to BART. IDEM conducted 

preliminary CALPUFF modeling, in which potential NOx and SO2 emissions from ESSROC’s Kiln #1 

and Kiln #2 were modeled to determine the visibility impacts. Results showed the visibility impacts 

from ESSROC exceeded the BART threshold of 98th percentile of 0.5 dv with a total of ten days over 

0.5 dv for 2002, eight days over 0.5 dv for 2003, and seven days over 0.5 dv for 2004. The cumulative 

number of days over 0.5 dv for the three year modeled period was twenty-five days, over the 98th

percentile of the three-year modeled period threshold of twenty-two days. 

Trinity Consultants prepared and submitted to IDEM a BART modeling protocol for ESSROC on 

January 18, 2007. Based on IDEM’s comments and responses to comments concerning the protocol, an 

IDEM-approved protocol was sent to ESSROC on February 15, 2007. The response and additional 

continuous emissions monitoring (CEM) data for the revised emission rates that were submitted by 
63 

ESSROC can be found in Appendix 5b. Information gathered from these submittals aided IDEM in 

conducting a revised CALPUFF modeling analysis for ESSROC’s subject to BART determination. 

IDEM’s BART modeling process, the modeling domain and meteorology, and the Class 1 areas 

analyzed are the same as in Section 8.4. 

SO2, NOx, and PM were modeled using the CALPUFF model for the SABIC analysis. Visibility 

impairing pollutants such as VOCs and ammonia were not modeled, but may be evaluated at a later date. 

IDEM received the BART exemption submittal from ESSROC on July 20, 2007. The emissions listed 

in ESSROC’s initial submittal included a proposed plantwide applicability limitation (PAL) for NOx and 

CEM data from the two kilns. Average 24-hour maximum emission rates are preferred for use in the 

CALPUFF model, consistent with the Modeling guidance to determine a source’s visibility impairment. 

The emission rates can be found in Table 20. 

It should be noted that ESSROC’s initial submittal contained general information on the SO2 CEM data 

for Kilns #1 and #2. The submittal showed that from January 1, 2006 through June 28, 2007, the 

maximum daily average hourly emission rates for Kiln #1 was 92.4 lb/hr and for Kiln #2 was 334.2 

lb/hr. At IDEM’s request for further information, ESSROC’s latest submittal from May 7, 2008 further 

detailed the CEM data for SO2 and NOx from Kilns #1 and #2. The highest emitting day from the period 

reviewed by ESSROC (April 26, 2006 through March 1, 2008) showed NOx emissions from December 

4, 2006 were measured at 17,928 lb/day. The highest emitting day for SO2 was May 20, 2006 with SO2

emissions measured at 10,706 lb/day. 

Table 20 BART Emission Rates for ESSROC - Speed 

Emission 

Unit 

Potential 

NOx 

Emissions 

Potential 

SO2 

Emissions 

Highest 

NOx

Emission 

Rate 1

Highest SO2

Emission 

Rate 1

Highest NOx 

Emission 

Rate 

Highest SO2

Emission 

Rate 

 (lb/hr) (lb/hr) (lb/day) (lb/day) (lb/hr) (lb/hr) 

Kiln #1 360.0 1104.0 302.6 37.8 

Kiln #2 462.0 1812.0 444.4 408.3 

TOTAL 822.0 2916.0 17928.0 10706.0 747.0 446.1 

1

 Highest emission rates determined from CEM data taken from April 26, 2006 to March 1, 2008 

In order to be consistent with previous BART analyses, the ESSROC analysis was run with both stack 

parameters averaged to give one representative point and also run with each individual stack in one run. 

Both scenarios were run to determine the overall visibility impact from ESSROC. The coordinates of 

the kilns are based on LCC in order to project on the CALPUFF modeling domain. Table 21 shows the 

stack parameters of Kilns #1 and #2 that were modeled in CALPUFF. The average of the stack 

parameters were calculated, in order to replicate the initial BART modeling conducted by IDEM. 

IDEM’s BART analysis modeled both the individual and averaged stack parameters. 
64 

Table 21 BART-eligible Stack Parameters for ESSROC - Speed

Emission Base LLC LLC Stack Stack Exhaust Exhaust 

Unit Elevation East North Height Diameter Velocity Temperature

 (m) (km) (km) (m) (m) (m/sec) (o

K) 

Kiln #1 137.16 972.493 -114.574 36.58 2.44 22.16 513.70 

Kiln #2 138.07 972.738 -114.621 64.92 2.97 16.31 422.00 

AVERAGE 137.62 972.61 -114.60 50.76 2.71 19.24 467.88 

8.5.2 ESSROC’s BART Determination Modeling Results 

ESSROC submitted modeling for its BART determination, using information and inputs taken from 

VISTAS BART Modeling Protocol, MRPO BART Modeling Protocol and IDEM’s CALPUFF input 

files. ESSROC used a more refined 4-kilometer CALMET data set taken from 2001 through 2003 as 

well as a 4-kilometer CALPUFF grid, as supplied by VISTAS. ESSROC’s initial modeling showed 

visibility impacts lower than the 98th percentile (8th highest day of the year) of the 0.5 dv threshold. 

ESSROC’s revised modeling, submitted on May 7, 2008, took into account the CEM data for Kilns #1 

and #2 and showed visibility impacts below the 98th percentile of the 0.5 dv threshold, as shown in 

Table 22. 

Table 22 ESSROC – Speed’s CALPUFF Modeling Results 

Impact 

Rank 

2002 

dv (day) 

2003 

dv (day) 

2004 

dv (day) 

1st 0.698 (81) 0.977 (342) 1.038 (244) 

2nd 0.591 (303) 0.697 (60) 1.014 (296) 

3rd 0.552 (291) 0.687 (23) 0.614 (274) 

4th 0.505 (140) 0.636 (312) 0.552 (56) 

5th 0.495 (330) 0.490 (220) 0.529 (179) 

6th 0.480 (46) 0.486 (30) 0.426 (270) 

7th 0.442(317) 0.485 (311) 0.386 (21) 

8th 0.440 (55) 0.428 (99) 0.372 (228) 

8.5.3 IDEM’s BART Determination Modeling Results 

IDEM based its initial CALPUFF modeling on potential emissions from ESSROC’s BART eligible 

emission units. ESSROC’s initial BART exemption submittal indicated SO2 and NOx emissions were 

much less than the potential emission calculations. IDEM requested further CEM data from ESSROC. 

This information was submitted on May 7, 2008. Modeled differences between IDEM’s initial BART 

determination modeling and ESSROC’s revised modeling were a result of lower NOx and SO2 emission 

rates for ESSROC’s Kilns #1 and #2, as taken from the CEM data. ESSROC calculated its emissions 

from available CEM data from the kilns, taken from March 26, 2006 to April 1, 2008. This 
65 

determination met the subject to BART modeling requirements for using the 24-hour average actual 

emission rate from the highest emitting day. 

Table 23 IDEM’s Revised CALPUFF Modeling Results for ESSROC - Speed 

Impact 

Rank 

2002 

dv (day) 

2003 

dv (day) 

2004 

dv (day) 

1st 0.747 (81) 1.033 (342) 1.088 (244) 

2nd 0.637 (291) 0.744 (23) 1.083 (296) 

3rd 0.581 (303) 0.712 (60) 0.660 (56) 

4th 0.573 (317) 0.689 (312) 0.609 (179) 

5th 0.537 (140) 0.556 (220) 0.574 (274) 

6th 0.517 (46) 0.553 (311) 0.465 (21) 

7th 0.463 (330) 0.504 (30) 0.415 (270) 

8th 0.456 (55) 0.461 (99) 0.408 (247) 

Table 23 above shows IDEM’s revised CALPUFF modeling results, using the CEM data for Kilns #1 

and #2 with the top eight rankings of the highest dv impacts from ESSROC for 2002 through 2004. 

There were six days above 0.5 dv in 2002, seven days above 0.5 dv in 2003 and five days above 0.5 dv 

in 2004. The 98th percentile for all three modeled years is eighteen days above 0.5 dv, below the 

twenty-two day threshold for 98th percentile of the three-year modeled period. While CALPUFF 

modeled impacts exceeding 0.5 dv, all at Mammoth Cave, the 98th percentile of modeled impacts were 

below 0.5 dv and did not exceed the subject to BART threshold. 

8.5.4 Summary of ESSROC BART Determination Analysis 

ESSROC operates a Portland cement manufacturing facility in Speed, Clark County, Indiana. In 

accordance with BART Guidelines and the criteria for sources which might be BART-eligible, ESSROC 

was identified as a BART-eligible source. IDEM conducted dispersion/long range transport modeling of 

the BART-eligible emissions units from ESSROC and determined ESSROC to be subject to BART. 

Subsequently, ESSROC submitted a BART modeling analysis and through revised emissions and stack 

parameters, indicated that their CALPUFF modeling showed ESSROC would not be subject to BART. 

IDEM’s review of ESSROC’s modeling analysis and the revised emission rates have shown that 

ESSROC would not be subject to BART, with the 98th percentile dv value below the 0.5 dv threshold. 

Therefore, the BART-eligible units from ESSROC are not subject to BART and no further analysis is 

required. 

8.6 BART Determination and Modeling for SABIC Innovative Plastics – Mount Vernon 

Modeling Project Overview 

SABIC Innovative Plastics Mt. Vernon, LLC (SABIC), formerly known as G.E. Plastics, operates a 

chemical manufacturing facility located in Mount Vernon, Posey County, Indiana. In accordance with 
66 

the BART Guidelines and criteria set forth for BART-eligible sources, SABIC was identified as a 

BART-eligible source. 

IDEM initially conducted long range transport modeling of the potential emissions from the BARTeligible emission units from SABIC using the CALPUFF model. IDEM determined SABIC to be 

subject to BART for having visibility impacts on nearby Class I areas. Subsequently, SABIC submitted 

their own BART exemption modeling analysis using the maximum 24-hour average actual emission 

rates and comparing modeled results with the annual average natural background light coefficient, 

according to the Modeling Guidance. SABIC conducted CALPUFF modeling at the nearest Class I 

areas in which SABIC had the greatest visibility impact, which were Mammoth Cave and Mingo 

Wilderness. These CALPUFF results showed SABIC was not subject to BART. This document 

contains IDEM’s review of SABIC’s BART exemption modeling analysis and the results of IDEM’s 

revised BART modeling. IDEM’s CALPUFF modeling results show that the visibility impairment from 

the appropriate maximum 24-hour average emission rates of sulfur dioxide, nitrogen oxides, and 

particulate matter from SABIC’s Mount Vernon facility will not exceed thresholds established in the 

BART Guidelines, and therefore, will not be subject to BART. 

8.6.1 IDEM’s BART Determination Process 

IDEM sent out BART surveys in the fall of 2005 to sources that were identified as having possible 

BART-eligible emission units. SABIC’s B&W, Erie and Lasker boilers, nine of the sixteen carbon 

monoxide generators, Heater H109, and portions of the transfer and finishing units were identified as 

potential BART-eligible sources as these SABIC emission units met all three of the BART-eligible 

criteria for SO2, NOx, and PM, as listed below: 

1.) Identify whether emission units are in one of the 26 source categories - SABIC operates a chemical 

manufacturing plant, identified as one of the 26 listed categories. 

2.) Identify whether emission units were in existence on August 7, 1977 and began operation after 

August 2, 1962 - The construction dates for the BART eligible emission units at SABIC are as 

follows: B&W Boiler- 1975, Erie Boiler- 1975, Lasker Boiler- 1962, Riley Boiler- 1962, Heater 

H109- 1974 and nine of the sixteen existing carbon monoxide generators were estimated in the 

BART eligibility timeframe.

3.) Compare potential emissions from emission units to 250 tons/yr or more threshold of a visibility 

impairing pollutant (NOx, SO2 and PM) - Potential NOx and SO2 emissions from all BART eligible 

emission units exceed 250 tons/yr of any single visibility impairing pollutant with potential NOx

emissions of 2431.7 tons/yr and potential SO2 emissions of 5644.2 tons/yr. Potential PM10

emissions from all BART-eligible units at SABIC total 1391.4 tons/yr.

Source specific stack and detailed emissions information were requested to be used in IDEM’s BART 

determination modeling analyses. A BART survey was sent to SABIC and SABIC submitted the survey 

results to IDEM on December 6, 2005. IDEM conducted preliminary CALPUFF modeling, in which 

potential NOx and SO2 emissions from SABIC’s BART eligible emission units were modeled to 

determine the visibility impacts. Results showed the visibility impacts from SABIC exceeded the 

BART threshold of the 98th percentile of 0.5 dv with a total of nine days over 0.5 dv for 2002, twelve 

days over 0.5 dv for 2003, and seven days over 0.5 dv for 2004. Based on the information provided, 

SABIC was determined to be subject to BART. 
67 

SABIC and GZA GeoEnvironmental, Inc. (GZA) met with IDEM staff on February 25, 2008 to discuss 

the BART modeling results and submitted a BART exemption modeling protocol to IDEM. IDEM 

reviewed and approved the protocol on February 28, 2007. This protocol can be found in Appendix 5c. 

GZA prepared the SABIC BART modeling analysis, conducted CALPUFF modeling and submitted 

revised emissions, stack information and the results to IDEM on May 7, 2008. Additional information 

submitted by SABIC and GZA, also found in Appendix 5c, aided IDEM’s review of SABIC’s subject to 

BART determination. 

IDEM’s BART Modeling Process, the Modeling Domain and Meteorology, and the Class 1 areas 

analyzed are the same as in Section 8.4. 

8.6.2 Visibility Impairment Pollutants Analyzed 

SO2, NOx, and PM were modeled using the CALPUFF model for the SABIC analysis. Visibility 

impairing pollutants such as VOCs and ammonia were not modeled but may be evaluated at a later date. 

SABIC’s submittal included the methodologies for estimating daily emission rates from the boilers and 

carbon monoxide generators and the emissions for all BART-eligible units at SABIC, as found below in 

Table 24. Average 24-hour maximum emission rates are preferred in the CALPUFF modeling analysis 

to be consistent with the Modeling Guidance determining visibility impairment for BART 

determinations. 

Table 24 BART Emission Rates for SABIC

Emission Unit 

Maximum Actual Emissions 

(pounds/hour)

NOx SO2 PM10 PM2.5

B&W (09-001) 1 54.21 117.64 10.81 7.64 

Erie Boiler (09-002) 1 81.20 702.82 17.75 15.88 

Lasker Boiler (09-002) 1 41.97 363.27 8.24 7.5 

Carbon Monoxide Generators COS (08-706) 2 0.62 152.80 0.03 0.007 

Riley Boiler (09-106) 17.85 0.11 1.34 1.34 

Heater (H109) 1.88 0.011 0.14 0.14 

Transfer/Finishing Units 3 0.0 0.0 3.42 0.86 

TOTAL 197.7 1336.6 41.7 33.4 

1

 Maximum actual 24-hour average emission rates estimated from SO2 emission profile analysis. 

2

 Nine of the sixteen carbon monoxide generators were constructed prior to August 7, 1977. 

3

 Conservative estimates of fugitive emissions from transfer/finishing units of 15 tons/yr. 

SABIC calculated its emissions from the Erie, Lasker boilers, and the carbon monoxide generators, 

taking into account the enforceable sulfur input limit, as listed in its Part 70 Operating Permit (T129-
68 

6794-00002). Data was based on the coal bunkered for the boilers, daily coal sampling, amount of coke 

purchased for feed to COS, and sulfur content of the purchased coke. Nine of the sixteen carbon 

monoxide generators were built during the BART eligible construction period so the emissions from 

those emission units were ratioed to account for only the BART eligible units. The other seven COS 

units were built after August 7, 1977 and therefore, are not BART eligible. 

Table 25 shows the stack parameters of all the BART-eligible sources at SABIC, as well as the area 

source parameters that define the transfer and finishing area dimensions. The coordinates of the SABIC 

BART eligible emission units are based on LCC in order to project on the CALPUFF modeling domain. 

Table 25 BART-Eligible Stack Parameters for SABIC

Emission 

Unit 

Base 

Elevation 

LLC 

East 

LLC 

North 

Stack 

Height 

Stack 

Diameter 

Exhaust 

Velocity 

Exhaust 

Temperature

POINT 

Source (m) (km) (km) (m) (m) (m/sec) (o

K) 

B&W 122.0 793.329 -195.36 30.48 1.68 48.68 450 

Erie & Lasker 122.0 793.29 -195.33 76.2 2.29 21.02 431 

Riley 122.0 793.276 -195.36 16.76 1.73 24.75 471 

COS 122.0 793.392 -195.30 48.77 1.57 4.37 889 

Heater 122.0 793.437 -195.58 22.98 0.99 5.21 644 

Base 

Elevation 

LLC 

East 

LLC 

North 

Release

Height 

Area Side 

Length 

Initial 

Vertical 

AREA Source (m) (km) (km) (m) (m) (m)

Transfer/Finish 122.0 790.34 -192.17 22.9 201 10.6 

8.6.3 SABIC’s BART Determination Modeling Results 

SABIC submitted modeling for its BART determination, using information and inputs taken from the 

VISTAS BART Modeling Protocol, the MRPO BART Modeling Protocol, and IDEM’s initial 

CALPUFF input files. SABIC used a more refined 4-kilometer CALMET data set from 2001 through 

2003 as well as a 4-kilometer CALPUFF grid, as supplied by VISTAS. IDEM’s preliminary CALPUFF 

modeling used a more conservative extinction coefficient (20% best day natural background), due to the 

36-kilometer modeling used by MRPO, rather than an annual average natural background coefficient. 

SABIC’s use of a more refined 4-kilometer grid warranted the use of average annual natural background 

concentrations for Class I areas in the eastern United States, pursuant to U.S. EPA’s “Guidance for 

Estimating Natural Visibility Conditions Under the Regional Haze Program” (EPA-454/B-03-005). 

This approach was accepted by IDEM. 

SABIC submitted a permit modification application to IDEM on May 29, 2008, which requested IDEM 

to remove the provision to burn oil in the B&W Boiler from SABIC's Part 70 Operating Permit. While 

the B&W boiler is not capable of burning residual oil since the oil storage tank and oil supply system are 
69 

no longer operable, the oil burning provision still exists in the Part 70 Operating Permit and, therefore, 

was analyzed for visibility impacts for the BART determination. 

Table 26 below, shows the results of SABIC’s modeling, submitted on May 7, 2008, July 10, 2008 and 

August 8, 2008. The CALPUFF results show visibility impacts below the 98th percentile of the 0.5 dv 

threshold at the two nearest Class 1 areas, Mammoth Cave in Kentucky and Mingo Wilderness Area in 

Missouri. SABIC modeled above the 0.5 dv threshold on one day in 2001, two days above the threshold 

at Mammoth Cave and one day at Mingo in 2002, and two days above the threshold at Mingo and one 

day at Mammoth in 2003. The visibility impacts for an individual year or the 3-year cumulative total do 

not exceed the 98th percentile of the 0.5 dv threshold level at any Class 1 areas. 

Table 26 SABIC’s CALPUFF Modeling Results over 0.5 dv 

Impact 

Rank 

2001 

dv/Location/(day) 

2002 

dv/Location/(day) 

2003 

dv/Location/(day) 

1st 0.506 at Mammoth (55) 0.657 at Mammoth (347) 0.703 at Mammoth (349) 

2nd 0.562 at Mingo (345) 0.575 at Mingo (253) 

3rd 0.550 at Mammoth (213) 0.558 at Mingo (53) 

8.6.4 IDEM’s BART Determination Modeling Results 

IDEM based its initial CALPUFF modeling on potential emissions from SABIC’s BART eligible 

emission units. The differences between IDEM’s initial BART determination modeling and the revised 

modeling conducted from SABIC’s BART exemption modeling submittals were the maximum 24-hour 

average emission rate estimates supplied by SABIC. Methodologies explaining SABIC’s emission 

calculations are found in Appendix 5c. The emission estimates follow the Modeling Guidance for using 

the maximum 24-hour average emission rates in the CALPUFF modeling. 

Results of IDEM’s revised BART determination modeling show that the 98th percentile dv impact from 

SABIC is below 0.5 dv. Table 27 shows IDEM’s revised CALPUFF modeling results with the top eight 

rankings of the highest dv impacts from SABIC for 2002 through 2004. The total number of days which 

modeled above 0.5 dv for all three modeled years is seventeen, below the twenty-two day threshold for 

98th percentile of the cumulative three-year modeled period. Therefore, SABIC’s BART-eligible 

emission units are exempt from BART. 
70 

Table 27 IDEM’s Revised CALPUFF Modeling Results for SABIC 

Impact 

Rank 

2002 

dv/Location/(day) 

2003 

dv/Location/(day) 

2004 

dv/Location/(day) 

1st 1.050 at Mingo (345) 1.004 at Mingo (253) 0.705 at Mammoth (38) 

2nd 0.632 at Mammoth (347) 0.827 at Mammoth (349) 0.601 at Mingo (328) 

3rd 0.625 at Mammoth (361) 0.707 at Mammoth (263) 0.570 at Linville (15) 

4th 0.563 at Mammoth (16) 0.678 at Mammoth (346) 0.569 at Mammoth (14) 

5th 0.501 at Mammoth (360) 0.669 at Mammoth (6) 0.522 at Mammoth (30) 

6th 0.327 at Mammoth (12) 0.600 at Mingo (252) 0.506 at Hercules (363) 

7th 0.311 at Mammoth (213) 0.476 at Mammoth (360) 0.413 at Mammoth (346)

8th 0.311 at Mammoth (351) 0.471at Mammoth (361) 0.394 at Mammoth (289)

8.6.5 Summary of SABIC BART Determination Analysis 

SABIC operates a chemical manufacturing facility in Mount Vernon, Posey County, Indiana. The 

BART Guidelines in the Federal Register (70 FR 39104) are a component of the Regional Haze 

regulations, published on July 1, 1999, and are intended to protect and improve visibility in national 

parks and wilderness areas. In accordance with 70 FR 39104 and the criteria set forth by U.S. EPA for 

sources which might be BART-eligible, SABIC was identified as a BART-eligible source. IDEM 

conducted dispersion/long range transport modeling of the BART-eligible emissions units from SABIC 

and determined SABIC to be subject to BART. Subsequently, SABIC submitted a BART modeling 

analysis and through revised emissions, stack parameters, and use of annual average natural background 

concentrations, indicated that their CALPUFF modeling showed SABIC’s BART-eligible emissions 

units would not be subject to BART. IDEM’s review of SABIC’s modeling analysis and the revised 

emission rates show that SABIC will not be subject to BART, with the 98th percentile dv value below 

the 0.5 dv threshold at surrounding Class I areas. Therefore, the BART-eligible units from SABIC are 

not subject to BART and no further analysis is required. 

8.7 BART Determination and Modeling for Alcoa 

Of the sources identified as BART-eligible, modeling indicated that one non-EGU source, Alcoa - 

Alcoa Warrick Operations and Alcoa Power Generation (APGI) - are subject to BART. Alcoa 

submitted a BART analysis in which it developed BART and alternative BART control strategies. Due 

to technical or economic concerns relating to BART units, the alternative requires less emissions 

reductions from several subject-to-BART units. However, it proposes to control emissions from Boiler 

1 that is not a BART-eligible unit, resulting in greater overall emission reductions. The modeling 

analysis shows that the alternative also achieves greater visibility improvement than BART. 

IDEM has reviewed the analyses for completeness and approvability in accordance with 326 IAC 26-1, 

the BART Guidelines, and 40 CFR 51.308(e). The emission limits representing BART or the alternative 

to BART will be included in this rulemaking and the Part 70 permit for each unit subject to BART. The 

completed BART rulemaking will be submitted to U.S. EPA for approval into the SIP. The Alcoa 

BART analysis is in Appendix 5d. Note that there is an addendum to Appendix 5d that contains updated 

information provided by Alcoa. The tables in this document use the updated information. 
71 

8.7.1 Summary of Alcoa BART Analysis 

Alcoa, located in Newburgh, Warrick County, Indiana, is subject to BART. The source submitted a 

BART analysis in December 2008, in which it developed BART and alternative BART control 

strategies. Since then, IDEM and the source worked together to address several issues related to the 

analysis. The alternative achieves a visibility improvement equal to 0.46 dv and an overall improvement 

in visibility equal to 75% over the baseline. It will be seen in the discussion to follow that sulfates are 

the major contributor to visibility impairment. The alternative, though it achieves greater reductions in 

all pollutants (PM, SO2, and NOx), achieves significantly higher reductions in SO2, equal to 

approximately 21,600 tons. This section briefly describes the Alcoa BART proposal including the 

BART-eligible units, analysis, and control strategy. This also includes four tables: Table 30 shows 

proposed BART controls, Table 31 shows proposed emission limitations, while Tables 32 and 33 show 

source culpability toward the highest estimated visibility impact. 

8.7.2 BART-eligible units at Alcoa 

Alcoa identified 18 ingot furnaces, three boilers (Boilers 2, 3, and 4), and five aluminum refining 

furnaces (Potlines 2-6) as meeting the BART-eligibility criteria. Boilers 2 and 3 are classified as 

industrial boilers. Boiler 4 is classified as an EGU. Alcoa, in its December analysis addressed PM, SO2, 

and NOx for all its BART-eligible units including Boiler 4. According to the Indiana BART rule, 326 

IAC 26-1-5, participation of this boiler in CAIR satisfies the SO2 and NOx requirements. The BART 

analysis will therefore address PM only for this boiler. 

Boilers 2, 3, and 4 are dry bottom, pulverized coal-fired units. Boiler 2 came online in January 1964, 

Boiler 3 came online in October 1965, and the construction of Boiler 4 started on March 16, 1968. 

Boilers 2 and 3 each had a nominal heat input capacity of 1,357 MMBtu/hr prior to a recent upgrade to a 

nominal heat input capacity of 1,589 MMBtu/hr. Boiler 4 has a nominal heat input capacity of 2,958 

MMBtu/hr. Each boiler is equipped with an electrostatic precipitator (ESP) for PM control. Boiler 2 

was equipped with a low NOx burner (LNB) and overfire air (OFA) in 2004, Boiler 3 was equipped with 

LNB and OFA in 2002, and Boiler 4 was equipped with a LNB in 1998 and a selective catalytic 

reduction (SCR) system in 2004. Wet flue gas desulfurization (FGD) scrubbers were installed on all 

boilers in 2008. 

Emissions from potlines are captured and controlled with primary controls. Any uncaptured emissions 

escape through the roof monitors atop the potline buildings. The primary controls consist of a gas 

treatment system followed by a fabric filtration system. The total fluoride and particulate removal 

efficiencies of the control systems are estimated to exceed 99%. 

Ingot furnace emissions are uncontrolled. There are several material handling operations at the facility 

that meet the criteria for beginning operation between 1962 and 1977. However, the BART Guidelines 

require that only those operations at primary aluminum ore reduction plants that meet the NSPS 

applicability criteria for this source category should be considered for BART controls. These operations 

are the potroom groups and anode bake plants. The department also identified three (3) ingot furnaces 

in the Alcoa Title V permit that meet the 1962-1977 timeline criteria but were not included in the 

analysis. According to Alcoa, one of these furnaces has been physically removed and the other two 
72 

furnaces did not operate in the baseline years. As discussed later, based on the impact of the other 18-

furnaces included in the analysis, the impact of these furnaces would be negligible. 

 

8.7.3 BART Analysis 

Before beginning the five step case-by-case BART analysis, Alcoa performed a baseline visibility 

impact analysis following a protocol submitted to IDEM. It determined the visibility impact for each of 

the years 2001-2003 using the CALPUFF model with emission rates based on the 24-hour average 

actual emissions from the highest emitting day. The initial screening model projected the highest 

visibility impact at Mammoth Cave National Park (MCNP). Other Class I areas screened included 

Mingo Wilderness Area, Sipsey Wilderness Area, Great Smokey Mountains National Park, Joyce 

Kilmer – Slick Rock Wilderness Area, Cohutta Wilderness Area, and Shining Rock Wilderness Area. 

The impact at MNCP exceeded 0.5 dv. Since the visibility impact was highest at MCNP, the BART 

analysis was solely based on the impact at MCNP. 

With a few exceptions (as explained below), Alcoa followed the following five-steps in its BART 

analysis, as required by the Indiana BART rule and the BART Guidelines: 

Step 1- Identify all available retrofit control technologies 

Step 2- Eliminate technically infeasible options 

Step 3- Evaluate control effectiveness of remaining control technologies 

Step 4- Evaluate impacts and document the results 

Step 5- Evaluate visibility impacts. 

8.7.4 Control Strategy 

As stated above, Alcoa proposed an alternative to BART. The alternative requires less emissions 

reductions on some units for technical or economic reasons. However, it proposes to control emissions 

from Boiler 1 which is not a BART-eligible unit. For example, Alcoa determined SO2 BART for 

Boilers 2 and 3 as 92% reduction, but it proposes to control SO2 emissions from these boilers by 90% as 

an alternative. Alcoa currently limits sulfur in the anode grade coke to ≤ 2%. Based on a market study, 

it has determined that the supply of <3% sulfur coke cannot be ascertained beyond 2013. Therefore, it 

proposes BART as ≤ 3% sulfur coke and the alternative as ≤ 3.5% sulfur coke. In the alternative, the 

source proposes to control SO2 emissions from Boiler 1 by 91% and NOx emissions at 0.38 lb/MMBtu. 

The proposed controls and the associated emission limits are shown in Tables 31 and 32, respectively. 

As can be seen in Tables 28 and 29, below, the alternative achieves greater visibility improvement and 

emissions reductions. 
73 

Table 28 Summary of Visibility Modeling Analysis 

 Modeling scenario Visibility impact (dv) Average impact (dv)

 2001 2002 2003 

1. Baseline, BART-eligible units only 1.852 1.906 1.788 1.849 

2. BART, BART-eligible units only 0.444 0.299 0.402 0.382 

Average improvement 1.467

3. Baseline, BART-eligible units and 

 Boiler 1 2.311 2.774 2.549 2.545 

4. Alternative BART 0.686 0.463 0.595 0.581 

Average improvement 1.964

Incremental improvement due to alternative control strategy = 0.497 dv

Table 29 Summary of emissions impact of various control scenarios 

Emissions (tons)

 Baseline Baseline 

 BART-eligible including Alternative 

 units only BART boiler 1 BART

NOx 9,786.35 4,935.68 14,718.72 7,326.55 

SO2 60,268.69 10,062.80 86,171.53 14,373.70 

PM 5,717.84 2,680.84 6,594.14 3,353.56 

Emissions reductions (tons)

 Alternative BART BART Difference

NOx 7,392.17 4,850.67 2,541.50 

SO2 71,797.83 50,205.89 21,591.94

PM 3,240.58 3,037.00 203.58 

A discussion of the proposed control strategy follows. 
74 

8.7.5 Discussion 

The BART Guidance does not specify a visibility threshold, cost effectiveness ($/ton), or cost/benefit 

($/dv improvement) value that a control measure should meet for it to be considered as BART. This 

analysis therefore proceeded to determine a feasible control strategy on a case-by-case basis, taking into 

consideration the visibility impact, applicable control technologies, their cost, and other factors.

1. Highest Contributors to Visibility Impairment 

Table 32 shows species contribution for each BART-eligible unit for its highest contribution in any 

baseline year. Table 33 shows total contribution and % species contribution for each BART-eligible 

unit at the highest modeled baseline contribution. Staff developed these tables from the source 

contribution table provided by Alcoa in its April 2, 2009 communication. It can be seen from these 

tables that Boilers 2 and 3 are the highest contributors to visibility impairment. In the year of maximum 

impact, Boilers 2 and 3 contribute approximately 95%, followed by potlines 3%, followed by Boiler 4 

equal to 2%, and the contribution from ingot furnaces is zero. Sulfates and nitrates from Boilers 2 and 3 

account for 73% and 25% of the impacts, respectively. It will be seen from the discussion to follow that 

the proposed controls significantly reduce visibility impact and that any additional incremental control 

will be achieved at high cost. 

2. Boilers 2 and 3 - SO2

Alcoa determined BART as wet limestone flue gas desulfurization (FGD) for these boilers at control 

efficiency equal to 92% and alternative control as 90% reduction. As an alternative, Alcoa proposes to 

control SO2 from Boiler 1 (which is not a BART-eligible unit) by 91%. 

3. Boilers 2 and 3 - NOx

Alcoa proposes low NOx Burners (LNB) and OFA with an emission limit equal to 0.38 lb/MMBtu as 

BART and as alternative BART for these boilers. U.S.EPA’s presumptive BART limit for these boiler 

types is equal to 0.39 lb/MMBtu. Baseline modeling without these controls shows the highest visibility 

impact due to these boilers equal to 0.458 dv, which is projected to decrease to 0.064 dv with the above 

controls. Alcoa identified Selective Non-catalytic Reduction (SNCRs) and SCRs as feasible 

technologies to control NOx from these boilers; however, it did not perform visibility impact analysis 

with these technologies. The capital and annual costs of SNCR controls on these boilers are estimated at 

$3 million and $2.8 million respectively. The capital and annual costs of SCRs are estimated at $70 

million and $13 million. Additional controls on these boilers are likely to yield visibility improvement 

at a very high cost/benefit ($/dv improvement). 

4. Potlines

The maximum impact from these sources is 0.231 dv. This includes contributions due to vents and 

primary controls. Sulfates are the main contributors, at approximately 0.188 dv. Contributions due to 

other species are less than 0.01 dv. Therefore, any add-on controls for these pollutants will result in 

insignificant improvements in visibility. Due to insignificant impact from vents (0.013 dv), Alcoa did 

not perform the 5-step analysis for these sources. Further, these sources are subject to 40 CFR 63, 

Subpart LL, Maximum Achievable Control Technology (MACT). In order to comply with these 

standards, Alcoa follows work practices which minimize emissions escaping roof vents. 
75 

Sulfur dioxide from potlines can be controlled by lowering sulfur content in the anode grade coke and/or 

by installing wet scrubbers. Alcoa presently limits sulfur at ≤ 2%. From a market study, Alcoa has 

concluded that a supply of coke below 3% sulfur cannot be ensured beyond 2013, the year when the 

BART controls will be needed. Therefore it proposes ≤ 3% sulfur coke as BART and ≤ 3.5% sulfur 

coke as alternative BART. The 3.5% sulfur limit in the coke translates into 2.919% sulfur in the baked 

anode composite, the practice Alcoa follows to measure the sulfur content. 

The installed and annual costs of wet scrubbers on potlines are estimated at $300 million and $55 

million respectively. Modeling shows that SO2 scrubbers on potlines can improve visibility by 0.138 dv. 

This improvement will be achieved at a cost/benefit ratio equal to $398 million/dv. Also, there are 

severe space and access limitations at the facility that would complicate the installation. 

 

5. Boilers 2, 3 and 4 - PM

The maximum baseline impact due to filterable PM emissions from these sources is 0.035 dv. Alcoa 

proposes ESPs with an emission limit equal to 0.03 lb/MMBtu as BART controls for Boilers 2 and 3. 

Alcoa determined BART for Boiler 4 as 0.015 lb/MMBtu, but it proposes alternative BART for this 

boiler as 0.1 lb/MMBtu. This boiler has a LNB and SCR for NOx control. Alcoa has noticed excessive 

conversion of SO2 to SO3 in the SCR due to the addition of an extra catalyst layer. To reduce SO3, 

which has the potential to adversely affect the downstream equipment and in order to comply with the 

sulfuric acid limit in its permit, Alcoa has applied for a permit to install a dry reagent injection system 

between the SCR and ESP. This system will remove SO3 from the gas stream, but it is expected to 

adversely affect the performance of the downstream ESP. The impact of this system on the ESP 

performance is not yet known. To account for this uncertainty, Alcoa proposes 0.1 lb/MMBtu as the 

alternative BART limit. A recent test, after the startup of the SO2 scrubber on this boiler, measured an 

emission rate equal to 0.05 lb/MMBtu which includes PM and sulfuric acid. 

The above limits are projected to lower the contribution from Boilers 2, 3, and 4 to approximately 0.005 

dv. Alcoa identified fabric filters as feasible control technology for these boilers. However, estimating 

that these controls will not significantly improve visibility, it did not perform cost and visibility impact 

analyses with these controls. It roughly estimated the cost of fabric filters on these boilers at $97.18 

million. This estimate is based on the cost of a fabric filter installed on a utility boiler. Alcoa estimates 

that installation of fabric filters on these boilers will improve visibility by 0.024 dv at a cost/benefit ratio 

equal to $445 million/dv. 

6. Ingot furnaces 

The maximum baseline impact from these sources is 0.003 dv. Due to insignificant impact from these 

sources, Alcoa did not perform a 5-step BART analysis for these sources. 
76 

Table 30 Alcoa Proposed BART Control Strategy

Emission unit BART Alternative BART 

Boiler 1 not a BART-eligible unit 

PM ESP 

SO2 

wet FGD with 91% emissions reduction 

efficiency 

NOx LNB with staged OFA 

Boilers 2 and 

3 

PM ESP ESP 

SO2

wet FGD with 92% emissions 

reduction efficiency 

wet FGD with 90% emissions reduction 

efficiency 

NOx LNB with staged OFA LNB with staged OFA 

 

Boiler 4 - PM ESP ESP 

 

Potlines 

- Fugitive 

emissions 

PM no add-on control no add-on control 

SO2 limit anode grade coke to 3% sulfur limit anode grade coke to 3.5% sulfur 

NOx no add-on control no add-on control 

- Primary 

emissions 

PM 

gas treatment system followed by 

fabric filter gas treatment system followed by fabric filter 

SO2 limit anode grade coke to 3% sulfur limit anode grade coke to 3.5% sulfur 

NOx no add-on control no add-on control 

 

Ingot 

Furnaces no add-on control no add-on control 
77 

Table 31 Alcoa Proposed BART Emission Limits 

Emission unit Emission limit Compliance demonstration method 

Boiler # 1 

PM 

(filterable) 

0.03 lb/MMBtu, 24-hour daily 

average 

CEMS at the scrubber outlet according to 

PS-11, 40 CFR Part 60, Appendix B 

SO2

91% reduction, 24-hour daily 

average 

CEMS at the scrubber inlet and outlet, 

according to 40 CFR Part 60, following 

Appendix B, PS-2 

NOx

0.38 lb/MMBtu, 24-hour daily 

average CEMS at the scrubber outlet, following PS-2 

 

Boilers 2 and 

3 

PM 

(filterable) 

0.03 lb/MMBtu, 24-hour daily 

average 

CEMS at the scrubber outlet according to 

PS-11, 40 CFR Part 60, Appendix B 

SO2

90% reduction, 24-hour daily 

average 

CEMS at the scrubber inlet and outlet, 

following PS-2 

NOx

0.38 lb/MMBtu, 24-hour rolling 

average CEMS at the scrubber outlet, following PS-2 

 

Boiler #4 

PM (filterable 

and sulfuric 

acid) 0.1lb/MMBtu 

The compliance method is according to 40 

CFR 60, Appendix A, Method 5 

 

Potlines 2-6 

PM 

(filterable) 0.005 grains/scf 

The compliance method is according to 40 

CFR 60, Appendix A, Method 5 

SO2

The sulfur content in each 

monthly baked anode composite 

shall not exceed 2.919%, 

provided however that hourly 

SO2 emissions from the potlines 

shall not exceed 1,456 lbs/hr. on 

a combined basis, and 

determined on a monthly basis. 

ASTM D3177-02, modified by adding 

saturated bromine water before the pH 

adjustment. Alternatively, determination of 

sulfur content by x-ray fluorescence. 
78 

Table 32 Highest Contribution from BART-eligible Units in any Modeling Scenario 

 Contribution (dv) 

BARTeligible 

unit 

Year of 

maximum 

contribution 

Modeling 

scenario Sulfates Nitrates

Filterable 

PM 2.5 

Filterable 

PM 10 Condensable Total 

Boilers 

2 and 3 2002 

Baseline: 

BARTeligible 

units 

+boiler 1 1.331 0.458 0.014 0.000 0.011 1.814

Boiler 4 2002 

Baseline: 

BARTeligible 

units 

+boiler 1 0.021 0.000 0.010 0.031

Potlines 2003 

Alternative 

BARTBARTeligible 

units 

+boiler 1 

Vents 0.003 0.000 0.004 0.001 0.005 0.013

Primary 

controls 0.185 0.002 0.005 0.000 0.008 0.200

Ingot 

furnaces 2003 

Baseline: 

BARTeligible 

units only 0.000 0.003 0.000 0.000 0.000 0.003
79 

Table 33 Source Culpability for the Highest Baseline Impact 

Year of maximum 

impact 2002 

Modeling scenario: Baseline with BART-eligible units and boiler 1 

BART-eligible unit (s) 

Contribution 

(dv) 

Total 

contribution 

(dv) % contribution % species contribution 

Boilers 2 and 3 1.814 95.17% 

Sulfates 1.331 73.37%

Nitrates 0.458 25.25%

Filterable PM2.5 0.014 0.77%

Filterable PM10 0 0.00%

Condensables 0.011 0.61%

Boiler 4 0.031 1.63% 

Filterable PM2.5 0.021 67.74%

Filterable PM10 0 0.00%

Condensables 0.01 32.26%

Potlines 

Vents 

Sulfates 0.001 0.004 0.21% 25.00%

Nitrates 0 0.00%

Filterable PM2.5 0.001 25.00%

Filterable PM10 0 0.00%

Condensables 0.002 50.00%

Primary controls 0.057 2.99% 

Sulfates 0.05 87.72%

Nitrates 0.001 1.75%

Filterable PM2.5 0.002 3.51%

Filterable PM10 0 0.00%

Condensables 0.004 7.02%

Ingot furnaces 0 0.00% 

Sulfates 0 

Nitrates 0 

Filterable PM2.5 0 

Filterable PM10 0 

Condensables 0 

Total contribution 1.906 100.00% 

 
80 

8.8 Indiana BART Rule 

On November 3, 2010, the Indiana Air Pollution Control Board adopted as final the Indiana BART rule, 

326 IAC 26-2. It includes the limits listed in the section above. It will become effective three to four 

months after this date. The rule is found in Appendix 7. 

9.0 Long Term Strategy 

9.1 Strategy requirements 

Federal provisions at 40 CFR 51.308(d)(3) require Indiana to include in its SIP a long-term strategy that 

addresses regional haze visibility impairment for each mandatory Class 1 Federal area which may be 

affected by emissions from Indiana sources. The long-term strategy must include enforceable emissions 

limitations, compliance schedules and other measures necessary to achieve the reasonable progress goals 

established by the states or tribes where the Class 1 areas are located. The strategy must be based on 

consultation with the states with Class 1 areas impacted by Indiana emissions and must be based on 

factors such as ongoing air pollution programs, smoke management techniques for agricultural and 

forestry management purposes, source retirement and replacement schedules, and emission limitations 

and schedules for compliance to achieve the reasonable progress goals. This section describes how 

Indiana plans to meet its long-term strategy obligations. 

9.2 Strategy 

Indiana does not have any Class 1 areas; however, emissions from Indiana were determined to impact 

Class 1 areas in other states. Indiana consulted with those states to develop reasonable progress goals. 

The consultation with other states and Federal Land Managers is explained in detail in Sections 2 and 3 

respectively. Indiana consulted with other states and tribes by participation in the MRPO Regional 

Haze Workgroup calls and other MRPO discussions to develop technical information necessary for 

development of coordinated strategies. Indiana also coordinated with CENRAP and MANE-VU to 

develop a weight of evidence analysis that was used to develop Indiana’s long-term strategy. Strategy 

development considered the impacts of Indiana’s emissions on Class 1 areas outside of Indiana. The 

emission inventory and modeling used to develop reasonable progress goals are described in detail in 

Sections 4.0, 5.0, and 6.0. The results of Class 1 area analyses are described in detail in Section 7.0. 

Each state must obtain its fair share of reductions necessary to reduce visibility impacts in neighboring 

states with Class 1 areas. Appendix 8c addresses the analyses performed by EC/R for LADCO in the 

document “Reasonable Progress for Class I Areas in the Northern Midwest – Factor Analysis”, July 18, 

2007. As stated in the report: 

“The purpose of this report is to analyze these reasonable progress factors for several 

possible control strategies intended to improve visibility in the northern-Midwest Class I areas: 

• SO2 and NOX emissions from electric generating units (EGUs) 

• SO2 and NOX emissions from Industrial, commercial and institutional (ICI) boilers 

• Ammonia from agricultural operations 

• NOX emissions from onroad and nonroad mobile sources 

• NOX emissions from reciprocating engines and turbines 
81 

In addition, an analysis is provided of existing (“on the books”) control programs: 

• Clean Air Interstate Rule (CAIR) 

• BART for available States (i.e., MI, MN, WI, and ND) 

• Maximum Available Control Technology (MACT) standards for combustion turbines and 

industrial boilers 

• On-road mobile source programs (i.e., 2007 Highway Diesel Rule, Tier II/Low Sulfur 

Gasoline) 

• Non-road mobile source programs (i.e., Non-road Diesel Rule, Control of Emissions from 

Unregulated Non-road Engines, Locomotive/Marine ANPRM)” 

The report concludes that EGU control programs to reduce SO2 and NOx emissions are the most 

effective in reducing visibility impacts. 

Table 11, from Section 8, shows the list of all Indiana EGUs and includes their existing and projected 

controls, as identified by IDEM, compared to the assumptions made in the EPA IPM runs and LADCO 

Round 5 modeling runs. Tables 34 and 35 summarize the megawatts controlled under the various 

scenarios. The generating capacity with IDEM known and projected control devices are compared 

scenario by scenario with EPA and LADCO cases. This table is an approximation because specific 

control efficiencies assumed by IDEM and EPA may vary and the controls specified by the consent 

decrees may have options for timing and ending control equipment. However, this is the best way to 

represent the overall amount of advanced control devices installed and planned to the Indiana electrical 

generating system. 

The table indicates that EGUs installed controls early for the NOX SIP call and later in response to 

CAIR. At the end of the projection periods, essentially the same amount of capacity is controlled for 

both pollutants. The most important of the projections are the comparisons with LADCO controls for 

2012 and 2018, as these are the years relied upon for the haze modeling in this SIP. SO2 controls are 

3.5% less than anticipated in 2012, which would result in slightly less visibility improvement than 

expected, but 32.9% greater in 2018, the end of this 10 year period. This would result in substantially 

greater improvement in visibility than anticipated. For NOx, projected controls are 10.3% greater in 

2012 and 1.6% less in 2018, resulting in slightly less improvement at the end of the period. Overall, 

with SO2 being the most significant pollutant, Indiana’s contributions to visibility impairment would be 

less in 2018 than predicted by the modeling. 

Table 34 Indiana EGUs Megawatts with SO2 Controls, Comparison of Actual or Projected 

Controls to Projections Made in EPA IPM Runs and Scenarios Modeled by LADCO 

IDEM 

Base 

Case 

EPA 

Base 

Case 

IDEM 

2010 

EPA 

2010 

IDEM 

2015 EPA 2015 IDEM 2020 

EPA 

2020 

IDEM 

2012 

LADCO 

2012 

IDEM 

2018 

LADCO 

2018 

10,800 9,463 10,800 13,220 12,810 13,520 15,882 13,978 11,077 11,496 15,882 11,954 
82 

Table 35 Indiana EGUs Megawatts with NOx Controls, Comparison of Actual or Projected 

Controls to Projections Made in EPA IPM Runs and Scenarios Modeled by LADCO 

IDEM 

Base 

Case 

EPA 

Base 

Case 

IDEM 

2010 

EPA 

2010 

IDEM 

2015 EPA 2015 IDEM 2020 

EPA 

2020 

IDEM 

2012 

LADCO 

2012 

IDEM 

2018 

LADCO 

2018 

12,981 11,420 12,981 11,637 13,103 12,425 15,703 15,958 13,103 11,880 15,703 15,958 

Beyond the projections made for the tables above, the CAIR replacement rule will also have an impact 

on Indiana utilities. The largest remaining uncontrolled units have proposed allocations under the TR 

that are substantially below present emissions levels. It is unknown how the utilities will address the 

budgets, but it is likely there will be additional reductions in the 2015 to 2018 timeframe over those 

projected above.. 

In addition to the EGU reductions, Indiana anticipates significant reductions from federal programs, 

such as the 2007 diesel rule, Tier II/Low Sulfur fuels and the non-road mobile source programs. These 

have been factored into future year modeling. 

Other area source, mobile source, and non-EGU point source reduction programs currently in place, “on 

the books” controls, were listed in Section 5.8. Some of the measures include Reasonably Available 

Control Technology (RACT) on particulate and VOC sources, measures in the Rate of Progress Plans 

(RFPs) to meet the 1-hour ozone NAAQS, the NOx SIP Call (Phase 1 for EGUs and Phase 2 for 

stationary internal combustion engines), and CAIR. As described in Section 8, Indiana has a fully 

adopted CAIR rule, which will be replaced by the newly proposed Clean Air Transport Rule, which will 

provide additional reductions. 

Indiana is currently, or will be shortly, working on additional programs to address the revised SO2, 

PM2.5 and 8-hour ozone NAAQS. These programs will further reduce Indiana’s contribution to Class 1 

areas in other States. 

Indiana has in its state rules sections that apply specifically to visibility in Class 1 areas. First, “adverse 

impact on visibility” is defined and then responsibilities of sources impacting federal Class I areas. 

These are contained in Indiana’s Permit Review Rules, 326 IAC 2-2, Prevention of Significant 

Deterioration (PSD) Requirements. 

In Indiana, prescribed burning must be conducted in accordance with state law under Indiana Code (IC) 

13-17-9 and regulations under 326 IAC 4-1. County or local ordinances may also apply in some parts of 

the state. In addition, the Indiana Department of Natural Resources (IDNR) has developed a fact sheet 

on prescribed burning that includes smoke management recommendations (Appendix 6). Prescribed 

burning of state-owned land by IDNR is allowed under 326 IAC 4-1-3(c), but must be extinguished if it 

creates a pollution problem. Prescribed burning also may not be conducted during unfavorable weather 

conditions, including when a pollution alert or ozone action day has been declared. Most burning of 

agricultural land is exempt from regulation. 
83 

9.3 Future Activities 

As explained above, at this time, reductions in Indiana emissions from the BART rule and other 

programs are sufficient to meet the reasonable progress goals in other states. However, to continue to 

assist those states in meeting their reasonable progress goals and to minimize its contribution to those 

states, Indiana commits to the following actions: 

1. Effectively enforce the existing control measures. 

2. Work with U.S. EPA and other states and regional planning organizations to address multipollutant air quality problems in the eastern and northeastern U.S. 

3. Continue consultation with states with Class 1 areas to monitor their progress in meeting 

their reasonable progress goals and develop coordinated strategies, as and when needed, to 

mitigate visibility impacts in those areas. 

10.0 State Implementation Plan Revisions and Adequacy of the Existing Plan 

10.1 State Implementation Plan Revisions 

The federal rule at 40 CFR 51.308(f) requires Indiana to revise its regional haze implementation plan 

and submit a plan revision to U.S. EPA by July 31, 2018, and every ten years thereafter. In accordance 

with the requirements listed in 40 CFR 51.308(f) of the federal rule for regional haze, Indiana commits 

to doing this. 

In addition, 40 CFR 51.308(g) requires periodic reports evaluating progress towards the reasonable 

progress goals established for each mandatory Class 1 area. In accordance with the requirements listed 

in 40 CFR 51.308(g) of the federal rule for regional haze, Indiana commits to submitting a report on 

reasonable progress to U.S. EPA every five years following the initial submittal of the SIP. The report 

will be in the form of a SIP revision. The reasonable progress report will evaluate the progress made 

towards the reasonable progress goal for each mandatory Class 1 area which may be affected by 

emissions from Indiana sources. All requirements listed in 40 CFR 51.308(g) shall be addressed in the 

SIP revision for reasonable progress. 

10.2 Determination of the Adequacy of the Existing Plan 

Depending on the findings of the five-year progress report, Indiana commits to taking one of the actions 

listed in 40 CFR 51.308(h), “Determination of the adequacy of existing implementation plan”. The 

findings of the five-year progress report will determine which action is appropriate and necessary. The 

actions in 40 CFR 51.308(h) include the following: 

(1) If the state determines that the existing implementation plan requires no further substantive 

revision at this time in order to achieve established goals for visibility improvement and 

emissions reductions, the state must provide to the Administrator a negative declaration that 

further revision of the existing implementation plan is not needed at this time. 

(2) If the state determines that the implementation plan is or may be inadequate to ensure reasonable 

progress due to emissions from sources in another state(s) which participated in a regional 

planning process, the state must provide notification to the Administrator and to the other state(s) 
84 

which participated in the regional planning process with the states. The state must also 

collaborate with the other state(s) through the regional planning process for the purpose of 

developing additional strategies to address the plan's deficiencies. 

(3) Where the state determines that the implementation plan is or may be inadequate to ensure 

reasonable progress due to emissions from sources in another country, the state shall provide 

notification, along with available information, to the Administrator. 

(4) Where the state determines that the implementation plan is or may be inadequate to ensure 

reasonable progress due to emissions from sources within the state, the state shall revise its 

implementation plan to address the plan's deficiencies within one year. 

11.0 Public Participation 

Indiana published notification for a public hearing and solicitation for public comment concerning the 

draft Indiana Regional Haze State Implementation Plan in the Indianapolis Star, Indianapolis, Indiana on 

December 10, 2010. 

A public hearing to receive comments concerning the SIP was conducted on January 11, 2011 at the 

Indianapolis-Marion County Public Library-West Indianapolis Branch. The comments from the Federal 

Land Managers were also presented at this hearing. The public comment period closed on January 13, 

2011. Comments were received by the agency concerning this submission. Appendix 8 documents the 

public hearing process and includes a copy of the public notice, certification of publication, and the 

public hearing transcript. There were no public comments received by IDEM, however comments from 

the National Park Service and United States Forest Service are included in Appendices 9 and 10, 

respectively. 
Appendices 
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