State of Wisconsin 1 DEPARTMENT OF NATURAL RESOURCES

September 11, 2009

Jim Doyle, Governor

Matthew J. Frank, Secretary

Mr. Bharat Mathur, Acting Region V Administrator

USEPA-Region V (R-19J)

77 West Jackson Boulevard

Chicago, IL 60604

101 S. Webster St.

Box 7921

Madison , Wisconsin 53707-7921

Telephone 608-266-2621

FAX 608-267-3579

TTY Access via relay - 711

Subject: Request to redesignate to attainment for the 1997 8-hour ozone standard the Counties of Door,

Kenosha, Kewaunee, Manitowoc, Milwaukee, Ozaukee, Racine, Sheboygan, Washington and Waukesha

Dear Mr. Mathur:

Under the federal Clean Air Act, USEPA is required to identify those areas of the nation that do not meet the

NAAQS for ozone. On April 30, 2004, U.S. EPA published a final rule in the Federal Register setting forth

designations and classifications for the 1997 8-hour ozone standard. Effective on June 15, 2004, USEPA

designated ten Wisconsin counties as nonattainment areas for the 1997 8-hour ozone standards. Those counties

are Door, Kenosha, Kewaunee, Manitowoc, Milwaukee, Ozaukee, Racine, Sheboygan, Washington, and

Waukesha.

WDNR proposed to designate these same ten counties as nonattainment for 8-hour ozone for state air quality

planning purposes under s. 285.11(5), Stats., and ch. NR 401, Wis. Adm. Code. WDNR held a public hearing on

November 9, 2004 in Milwaukee regarding the proposed redesignation. After review and addressing the

comments from the hearing and the associated public comment period, WDNR designated all ten counties as

nonattainment of the 8-hour ozone NAAQS in March 2005.

Based on 2004 through 2006 ozone monitoring data, WDNR submitted a redesignation request to USEPA for the

Milwaukee-Racine 6-County Area (Kenosha, Milwaukee, Ozaukee, Racine, Washington, and Waukesha) and the

counties of Manitowoc and Kewaunee for the 1997 8-hour ozone standard on June 14, 2007. USEPA published a

final rule in the Federal Register on May 21, 2008, redesignating Kewaunee County as attainment for the 1997 8-

hour ozone standard (73 FR 29346). The other seven counties remained as nonattainment because based on 2005

through 2007 ozone monitoring data, subsequent exceedances of the 1997 8-hour ozone NAAQS were monitored.

This letter's redesignation request supersedes the previous June 14, 2007 redesignation request to USEPA for the

Milwaukee-Racine 6-County Area and Manitowoc County.

1997 8-Hour Ozone Standard - Redesignation Proposal

One of the requirements for redesignating an area from nonattainment to attainment of the 1997 8-hour ozone

NAAQS is showing that attainment has been achieved based on the most recent three years of monitoring data.

The average of the fourth highest peak daily 8-hour concentrations for the three most recent monitoring years

must be below the NAAQS. WDNR's ozone monitors located in the specified counties did not record a violation

of the 8-hour ozone NAAQS concentration during the 2006, 2007 and 2008 ozone seasons. Based on this

dnr.wi.gov

wisconsin.gov Printed on

Recycled

Paper
monitoring data, WDNR requests EPA redesignate the counties of Door, Kenosha, Kewaunee, Manitowoc,

Milwaukee, Ozaukee, Racine, Sheboygan, Washington, and Waukesha to attainment of the 1997 8-hour ozone air

quality standard.

Wisconsin State Implementation Plan - Ozone Attainment Demonstration

Under Section 110 and Part D of the Clean Air Act, WDNR must submit an attainment demonstration for the

1997 8-hour ozone NAAQS as part of the redesignation request. WDNR includes an attainment demonstration

document with this redesignation request which provides an overview of measured and modeled air quality data

demonstrating how full implementation of Wisconsin's ozone air quality SIP and other factors contribute to

attainment of the 19978-hour ozone NAAQS throughout the current nine nonattainment counties in Wisconsin.

The attainment demonstration also documents how permanent and enforceable control measures of ozone

precursors in Wisconsin's ozone nonattainment counties have resulted in substantial emission reductions for these

counties to date. Furthermore, these control measures are projected to yield emission reductions that meet

reasonable further progress (RFP) requirements. The subsequent ozone modeling of future year scenarios that

include these projected emissions scenarios resulted in predicted ozone concentrations that show attainment and

maintenance of the 19978-hour ozone NAAQS in Wisconsin.

The information necessary to support this submittal is extensive. Rather than supplying hundreds of pages of

attachments to this letter, we have included a CD containing all electronic documents as referenced in this letter's

attachment page. If you have any questions regarding this SIP revision submittal, please feel free to call either

Larry Bruss at 608-267-7543 or Ralph Patterson at 608-267-7546.

Sincerely,

Ralph Patterson -AM/7

Tom Steidl -LS/8

Larry Bruss-AM/7

Mr. John gion V (A-18J), 77 West Jackson Boulevard, Chicago, IL 60604
Attachments on CD

• SIP Checklist

• Public hearing notice

• Class 1 hearing notice tear sheet

• SIP Certification

• Redesignation Request Documents

o Redesignation Request Technical Support Document - 51 pages

o Appendix 1 - Redesignation Guidance from U.S. EPA - 72 pages

o Appendix 2 - Ozone Data Summaries for 2006 to 2008 -88 pages

o Appendix 3 - Components of Wisconsin Ozone SIP - 5 pages

o Appendix 4 - 2002 and 2005/2007 Wisconsin Redesignation Emission Inventories

Documentation - 30 pages

o Appendix 5 - EGU Inventory Methodology and Emissions for 2002, 2007, 2012 and

2020 - 6 pages

o Appendix 6 - Point non-EGU Emissions for 2002, 2007, 2012 and 2020 - 228 pages

o Appendix 7 - Area Emissions for 2002, 2007, 2012, and 2020 - 42 pages

o Appendix 8 - Nonroad emissions for 2002, 2007, 2012, and 2020 - 12 pages

o Appendix 9 - Onroad Emissions for 2002, 2007, 2012, and 2020 - 3 pages

o Appendix 10 - Wisconsin MACT Standards - 3 pages

o Appendix 11 - State 1- Hour Ozone Redesignation Documents for the MilwaukeeRacine 6 - County Area - 11 pages

o Appendix 12 - WDNR's response to Public Comments - 4 pages

• Attainment Demonstration Documents

o Attainment Demonstration Technical Support Document - 66 pages

o Appendix A - Regional Air Quality Analyses for Ozone, PM2.5, and Regional Haze,

Final Technical Support Document, LADCO - 169 pages

o Appendix B - Base K/Round 4 Strategy Modeling: Emissions, LADCO - 16 pages

o Appendix C - Base M Strategy Modeling Emissions (Revised), LADCO - 24 pages

o Appendix D - Regional Air Quality Analyses for Ozone, PM2.5, and Regional Haze:

Final Technical Support Document (Supplement), September 12, 2008, LADCO - 56

pages

o Appendix E - Overview: VOC/NOx Ratios and Ozone Production - 3 pages

o Appendix F - Ozone Control Rules - 4 pages

o Appendix G - Classification and Regression Tree (CART) - 1 page
EPA Region V 

Wisconsin SIP Submittal 

Completeness Review

Submittal Letter 

1. Signed by Governor’s Designee (John Melby, Jr.)? Yes _x__ No ___ 

2. Date of Submittal _____September 11, 2009_________________________________ 

3. WDNR Person in charge of SIP submittal. 

Name _Ralph Patterson_______________ Telephone _608-267-7546___________ 

 FAX Number ___608-267-0560____________ 

E-MAIL Address__Ralph.Patterson@wisconsin.gov____________________________ 

4. WDNR Technical Person in charge of answering questions on SIP Submittal 

Name _Joseph Hoch_______________ Telephone ____608-264-8861________ 

 FAX Number ____608-267-0560___________ 

E-MAIL Address___Joseph.Hoch@wisonsin.gov___________________________ 

Incorporation Into Wisconsin Administrative Code

5. Is evidence that the State incorporated the revision into the Wisconsin Administrative Code 

supplied in this SIP package? 

 Yes __ 

 No_x_ if No explain. 

WDNR is requesting EPA redesignate the counties of Door, Kenosha, Kewaunee, Manitowoc, 

Milwaukee, Ozaukee, Racine, Sheboygan, Washington, and Waukesha to attainment of the 1997 8-hour 

ozone air quality standard. 

6. The effective date of the regulation is or was ___________N/A_________ 

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

state Attorney General 

 Yes_______ 

 No_______ 

 Not applicable _x______ 

 For No and Not applicable explain answer. This is a redesignation request. 

8. Has WDNR provided evidence that it has necessary legal authority under State law to adopt and 

implement the revision? 

 Yes _______ 

 No ___x____ 

 Additional Explanation (if necessary). This is a redesignation request. 

9. Did the State include a copy of the actual regulation or document for USEPA review? 

 Yes ____ 
2

 No__x___ 

 Additional Explanation (if necessary). 

10. Did the State provide evidence that it followed all of the requirements of its Administrative 

Procedures Act (ch. 227, Wis. Stats., Administrative Procedure and Review) in conducting and 

completing adoption/issuance of the revision? 

 Yes____

 No_x_____ 

 Additional Explanation (if necessary) 

11. Did the State include evidence that Public Notice was given of the revision, including date of 

publication? 

 Yes__x__ 

 No ____ 

 Additional Explanation (if necessary) 

12. Did the State provide a copy of the certification that public hearings were held in accordance with 

the information provided in the public notice (copy of notarized Class I paper proof). 

 Yes_x__ 

 No___ 

 Additional Explanation (if necessary). 

13. Does the submittal contain a compilation of public comments and the State’s response? 

 Yes__x__ 

 No____ 

 Additional Explanation (if necessary). 

Technical Issues 

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

15. Does the submittal identify the designation, status of the attainment plan and attainment date for 

the area(s) 

 Yes_x___ 

 No_____ 

 Additional Explanation (if necessary) 

16. Does the submittal identify the location and types of affected sources? 

 Yes__x___ 

 No_____ 

 Additional Explanation (if necessary) 
3

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

changes in actual emissions from affected sources? 

 Yes___ 

 No_x___ 

 Additional explanation (if necessary) This submittal is a redesignation request and includes 

emissions data to support the redesignation request. 

18. Has the State demonstrated that the NAAQS/PSD Increment/RFP demonstration/visibility will be 

protected if the revision is approved and implemented? 

 Yes__x__ 

 No____ 

 Additional explanation (if necessary). WDNR is requesting EPA redesignate the counties of 

Door, Kenosha, Kewaunee, Manitowoc, Milwaukee, Ozaukee, Racine, Sheboygan, Washington, and 

Waukesha to attainment of the 1997 8-hour ozone air quality standard. The submittal demonstrates the 8-

hour ozone standard is attained in these counties. 

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

 Yes_x__ 

 No____ 

 Unnecessary____ 

20. Has the State provided evidence that emission limitations are based on continuous emission 

reduction technology? 

 Yes____ 

 No_x___ 

 Additional explanation (if necessary). Not applicable 

21. Has the State provided evidence that the revision contains emission limitations, work practice 

standards and record keeping/reporting requirements where necessary, to ensure emission levels? 

 Yes___ 

 No__x__ 

 Additional explanation (if necessary). Not applicable 

22. Does the submittal contain enforcement/compliance strategies including how compliance will be 

determined in practice, and at what frequency? 

 Yes___ 

 No__x_ 

 Additional explanation (if necessary). Not applicable 
4

STATE APPROVABILITY CHECKLISTENFORCEABILITY 

USEPA USE ONLY 

SIP Package Number ___________ 

Date Received by USEPA ________________ 

Date Due_____________________________ 

State: WISCONSIN 
5

WDNR Information 

Subject Matter: Redesignatiion of the counties of Door, Kenosha, Kewaunee, Manitowoc, 

Milwaukee, Ozaukee, Racine, Sheboygan, Washington, and Waukesha to attainment of the 1997 8-hour 

ozone air quality standard.

Applicability 

USEPA Question USEPA Requirement State Response 

What sources are being regulated? Clear discussion WDNR is requesting 

redesignation based on 

monitoring and emissions 

data. The redesignation doe

directly address the 

regulation of any source. 

What are criteria for exemption? Clear discussion Not applicable 

Is calculation procedure for 

exemption clearly specified? 

Supply example calculation or clear explanation 

of how to determine exemption (line by line, 

etc.) 

Not applicable 

Is emission inventory listed in the 

background document of the 

attainment demonstration? 

Inventory including allowable and actual 

emissions in source category should be 

included, for enforcement purposes and 

independent of any Clean Air Act requirements, 

in the attainment demonstration if such data is 

necessary for determining baselines in 

regulations. 

Emission inventories are 

included with the submittal.

Please refer to Appendices 5

6, 7, 8, and 9. 

Is the averaging time(s) used in 

the rule different from that of the 

ambient standard? 

The averaging time in the rule must be 

consistent with protecting the ambient standard 

in question. Normally, it should be equal to or 

shorter than the time associated with the 

standard. Longer term averaging is available 

only in limited instances provided that the 

ambient standard is not compromised. 

Not applicable 

What are the units of compliance 

(lbs VOC per gallon of solids 

applied less water, grains per 

standard cubic foot?) 

Clearly stated in the rule. Not applicable 

Is bubbling or averaging of any 

type allowed? If yes, state 

criteria. Could a USEPA 

inspector independently determine 

if the criteria were met?? Does 

USEPA have to approve each 

case? 

Explicit description of how averaging, bubbling, 

or equivalency is to be determined. VOC 

equivalency must be on a “solids applied” basis. 

Any method must be independently 

reproducible. Provision must be explicit as to 

whether USEPA case-by-case approval is 

required. If provision intended to be “generic” 

then USEPA bubble policy must be met. 

Not applicable 
6

If there is a redesignation, will 

this change the emission 

limitations? If yes, which ones 

and how? 

Regulation may not automatically allow for self 

nullification upon redesignation of area to 

attainment. New maintenance demonstration 

required to order to drop regulation. 

WDNR does not anticipate 

that the redesignation will 

change any emission 

limitation. 

Compliance Dates 

USEPA Question USEPA Requirement State Response 

What is the compliance date? The compliance date must not be later 

than the approved or about to be 

approved date of attainment unless 

emission reductions are not necessary 

for attainment. In some cases, it will 

be necessary for the regulation to 

specify dates in compliance schedules 

that are required to be submitted by 

source to state. 

Not applicable.

What is the attainment date? Clearly defined. Not applicable 

Specificity of conduct 

USEPA Question USEPA Requirement State Response 

What test method is required? Test method must be explicitly stated. Not applicable. 

What is the averaging time in the 

compliance test method? 

Averaging time and application of 

limit must be explicit. 

Not applicable. 

Is a compliance calculation or 

evaluation required? (i.e., daily 

weighted average for VOC). 

Clearly defined. Not applicable. 

If a compliance calculation is 

necessary, list the formula, period of 

compliance, and/or evaluation 

method. 

Formula must be explicit. Not applicable. 

Incorporation by reference

USEPA Question USEPA Requirement State Response 

What is the state authority for 

rulemaking. 

Clearly stated. Not applicable. 

Are methods/rules incorporated by 

reference in the right manner? 

Clearly stated. Not applicable. 

Record keeping

USEPA Question USEPA Requirement State Response 

What records are required to 

determine compliance? 

Clearly stated. Not applicable. 
7

In what form or units (lbs/gal, gr/dscf, 

etc.) must the records be kept? On 

what time basis (instantaneously, 

hourly daily)? 

Records to be kept must be consistent 

with units of compliance in the 

performance requirements, including 

the applicable time period . 

Not applicable. 

Does the rule affirmatively require 

the records be kept? 

There must be clearly defined and 

distinguishable from what constitutes 

a violation. 

Not applicable. 

Exemptions

USEPA Question USEPA Requirement State Response 

List any exemptions allowed. Must be clearly defined and 

distinguishable from what constitutes 

a violation. 

Not applicable. 

Is the criteria for application clear? Clearly stated. Not applicable. 

Malfunction Provisions

USEPA Question USEPA Requirement State Response 

Are there any malfunction provisions 

in the rule? 

Rule must specify what exceedances 

may be excused, how the standard is 

to be applied, and who makes the 

determination. 

Not applicable. 
WISCONSIN DEPARTMENT OF NATURAL RESOURCES

BUREAU OF AIR MANAGEMENT

STATE IMPLEMENTATION PLAN REVISION

CERTIFICATION

Pursuant to the requirements of 40 CFR s. 51.1 02{f), I hereby certify that the Wisconsin

Department of Natural Resources held the hearing described below; that the hearing was

held in accordance with the public notice (copy attached), as required by 40 CFR s.

51.102{d); and that I was the presiding officer at the hearing.

Subject:

Proposed Redesignation to Attainment for the 1997 8-Hour Ozone Standard of the

Counties of Door, Kenosha, Kewaunee, Manitowoc, Milwaukee, Ozaukee, Racine,

Sheboygan, Washington and Waukesha and Ozone Attainment Demonstration.

Hearing held:

Tuesday, August 18, 2009 in Milwaukee, Wisconsin.

Written comments were received until August 28, 2009.

Thomas

~~~! F. Steidl .. .

BUREAU OF LEGAL SERVICES

Subscribe:q and sworn to before me

this jlz;tl/ day of 5:~JJtlJ6q-2009.

Notary Public, State of s nsin

My commission is permanent.
BEFORE THE

DEPARTMENT OF NATURAL RESOURCES

Notice of Public Hearing

Proposed Redesignation to Attainment for the 1997 8 -Hour Ozone Standard

of the Counties of Door, Kenosha, Kewaunee, Manitowoc, Milwaukee, Ozaukee, Racine,

Sheboygan, Washington, and Waukesha and Ozone Attainment Demonstration

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

Stats., and ch. NR 401, Wis. Adm. Code, the Department of Natural Resources will hold a public hearing

on its proposal to redesignate the Counties of Door, Kenosha, Kewaunee, Manitowoc, Milwaukee,

Ozaukee, Racine, Sheboygan, Washington, and Waukesha from nonattainment to attainment of the 1997

8-hour National Ambient Air Quality Standard (NAAQS) for ozone. The Department is also seeking

public comment on its ozone attainment demonstration which is part of the state implementation plan

(SIP) for ozone control which Wisconsin must submit to the U.S. Environmental Protection Agency

(USEPA) under the federal Clean Air Act.

Background

Under the federal Clean Air Act, USEPA is required to identify those areas of the nation that do not

meet the NAAQS for ozone. On April 30, 2004, U.S. EPA published a final rule in the Federal Register

setting forth designations and classifications for the 1997 8-hour ozone standard. Effective on June 15,

2004, USEPA designated ten Wisconsin counties as nonattainment areas for the 1997 8-hour ozone

standards. Those counties are Door, Kenosha, Kewaunee, Manitowoc, Milwaukee, Ozaukee, Racine,

Sheboygan, Washington, and Waukesha.

The Department proposed to designate these same 10 counties as nonattainment for 8-hour ozone for

state air quality planning purposes under s. 285.11(5), Stats., and ch. NR 401, Wis. Adm. Code. The

Department held a public hearing on November 9, 2004 in Milwaukee. After review and addressing the

comments from the hearing and the associated public comment period, the Department designated all 10

counties as nonattainment of the 8-hour ozone NAAQS in March 2005.

Based on 2004 through 2006 ozone monitoring data, the Department submitted a

redesignation request to USEPA for the Milwaukee-Racine 6-County Area (Kenosha, Milwaukee,

Ozaukee, Racine, Washington, and Waukesha) and the counties of Manitowoc and Kewaunee for

the 1997 8-hour ozone standard on June 14, 2007. USEPA published a final rule in the Federal

Register on May 21, 2008, redesignating Kewaunee County as attainment for the 1997 8-hour

ozone standard (73 FR 29346). The other seven counties remained as nonattainment because

based on 2005 through 2007 ozone monitoring data, subsequent exceedances of the 1997 8-hour

ozone NAAQS were monitored. This current redesignation proposal supersedes the previous

redesignation request to USEPA for the Milwaukee-Racine 6-County Area and Manitowoc

County.

1997 8-Hour Ozone Standard - Redesignation Proposal

One of the requirements for redesignating an area from nonattainment to attainment of the 1997 8-

hour ozone NAAQS is showing that attainment has been achieved based on the most recent three years of

monitoring data. The average of the fourth highest peak daily 8-hour concentrations for the three most

recent monitoring years must be below the NAAQS. The Department's ozone monitors located in the

specified counties did not record a violation of the 8 -hour ozone NAAQS concentration during the 2006,
2007 and 2008 ozone seasons. Based on the monitoring data, the Department is proposing to redesignate

the counties of Door, Kenosha, Kewaunee, Manitowoc, Milwaukee, Ozaukee, Racine, Sheboygan,

Washington, and Waukesha to attainment of the 1997 8-hour ozone air quality standard. The Department

will request that USEPA redesignate these counties to attainment through a federal action. The

Department will also complete the state redesignation work so that these counties will be designated as

attainment areas for the 1997 8-hour ozone standard under both state and federal law.

The redesignation of these counties to attainment may alter the permitting requirements for new

sources of volatile organic compounds (VOC) and nitrogen oxides (NOx) emissions. Redesignation may

raise the major source threshold, change the required emission control technology for major sources, and

eliminate the need for acquiring VOC and NOx offsets prior to construction of major sources. All other

aspects of the Wisconsin's Ozone Control Program and the related air quality management program

commitments will remain as currently adopted and approved by the USEPA. This includes the VOC and

NOx emission control programs embodied in the SIP for Ozone Control, and a continued commitment to

air quality monitoring, periodic inventory reports, operation and new construction permits, and other

related air quality management efforts.

Wisconsin State Implementation Plan - Ozone Attainment Demonstration

Under Section 110 and Part D of the Clean Air Act prior to submittal of a complete

redesignation request, Wisconsin must submit an attainment demonstration for the 1997 8-hour

ozone NAAQS. The Department has prepared a proposed attainment demonstration document

which provides an overview of measured and modeled air quality data that demonstrates how full

implementation of Wisconsin's ozone air quality SIP and other factors have contributed to

attainment of the 1997 8-hour ozone NAAQS throughout the current nine nonattainment counties

in Wisconsin.

The attainment demonstration also documents how permanent and enforceable control

measures of ozone precursors in Wisconsin 's ozone nonattainment counties have resulted in

substantial emission reductions for these counties to date. Furthermore , these control measures

are projected to yield emission reductions that meet reasonable further progress (RFP)

requirements. The subsequent ozone modeling of future year scenarios that include these

projected emissions scenarios resulted in predicted ozone concentrations that show attainment

and maintenance of the 1997 8-hour ozone NAAQS in Wisconsin through at least 2018.

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

Tuesday, August 18, 2009 at 1:00 p.m.

WI DNR Southeast Region Headquarters, Room 140-141

2300 N. Dr. Martin Luther King Jr. Drive

Milwaukee, WI

NOTICE IS HEREBY FURTHER GIVEN that pursuant to the Americans with Disabilities Act,

reasonable accommodations, including the provision of informational material in an alternative format,

will be provided for qualified individuals with disabilities upon request . Please call Joseph Hoch at (608)

264-8861 with specific information on your request at least 10 days before the date of the scheduled

hearing.

Written Comments and Copies of Documents
Written comments on the proposed redesignation may be submitted to Mr. Joseph Hoch, Bureau of

Air Management AMJ7, P.O. Box 7921, Madison, WI 53707 no later than August 28, 2009 . Comments

may be submitted electronically to joseph.hoch@wisconsin.gov. Written comments will have the same

weight and effect as oral statements presented at the hearing.

A copy of the documents supporting the redesignation request and the attainment

demonstration may be downloaded from http://dnr.wi.gov/air/aq/ozone/ozresources.htm or a hard

copy may be obtained from:

Joseph Hoch AM/7

Bureau of Air Management

P.O. Box 7921

Madison, WI 53707

Joseph. Hoch ,wisconsin.gov

Phone : (608) 264-8861

FAX: (608) 267-0560

Dated at Madison, Wisconsin

STATE OF WISCONSIN

DEPARTMENT OF NATURAL RESOURCES
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