Appendix AAnnual and Daily PM2.5Monitoring Data2Data Completeness and Quarterly Averages of Fine Particulate Material in MichiganGuideline on Data Handling Conventions for the PM NAAQS, p 4 "If you're doing an intermediate calculation, such as quarterlyaverage PM10 value from the 24-hour values, keep all digits on your calculator."updated 3/4/11shaded cell indicates sampling frequency changed to 1:6 red'n in samplling frequency from 1:6 to 1:12shaded cell indicates sampling frequency changed to 1:3 from 1:1 sampling frequeny increased to daily - +/- 5% NAAQS orsFirst Quarter Second Quarter Third Quarter Fourth Quarter3-YrAIRSID Site POCSch # Obs. # % Quart.Sch #Obs. # % Quart. Sch # Obs. # % Quart. Sch # Obs. # % Quart.AnnualAnnual260990009New Haven1 199930 24 80 11.66 30 227313.55 31 31 100 13.95 5 27 540 11.45 12.66260990009New Haven1 200031 29 9416.2630 29 97 12.76 31 30 97 12.43 30 25 83 12.22 13.42260990009New Haven1 200130 28 93 14.75 31 28 90 14.68 30 29 97 13.18 31 30 97 11.78 13.60 13.2260990009New Haven1 200230 28 93 11.86 30 28 93 13.37 31 30 9715.1931 31 100 12.98 13.35 13.5260990009New Haven1 200330 29 97 14.47 30 26 87 12.92 31 31 100 13.08 30 28 93 10.92 12.85 13.3260990009New Haven1 200431 31 100 11.82 30 30 100 11.49 31 30 97 14.23 30 30 100 10.29 11.96 12.7260990009New Haven1 200530 30 10015.2131 31 100 14.21 30 29 9716.1431 30 97 11.94 14.38 13.1260990009New Haven1 200630 30 100 13.68 15 15 100 9.65 15 12 80 9.50 16 15 94 12.27 11.28 12.5260990009New Haven1 200730 29 97 12.37 30 29 97 9.58 31 27 87 13.33 30 29 97 12.46 11.94 12.5260990009New Haven1 200831 30 97 13.24 30 27 90 9.10 31 30 97 10.91 30 30 100 9.38 10.66 11.3260990009New Haven1 200930 28 93 13.71 31 31 100 6.30 30 30 100 8.09 31 27 87 9.85 9.49 10.7260990009New Haven1 201030 30 100 9.35 30 30 100 7.27 31 31 100 10.28 31 31 100 8.79 8.92 9.7261150005Luna Pier1 1999--- --- --- --- --- --- --- --- --- --- --- --- 5 5 100 12.56 12.56261150005Luna Pier1 200031 30 9716.9230 29 97 14.54 31 29 94 14.33 30 29 97 14.9615.19261150005Luna Pier1 200130 27 9016.2431 25 8116.5830 29 9715.6831 30 97 12.6915.3014.3261150005Luna Pier1 200230 30 100 14.99 30 27 9017.7731 28 9015.9631 25 8116.30 16.26 15.6261150005Luna Pier1 200330 28 9315.9330 27 90 12.84 31 31 100 14.36 30 30 100 12.01 13.7915.1261150005Luna Pier1 200431 26 84 13.02 30 30 100 12.61 31 31 100 14.83 30 29 90 11.47 12.98 14.3261150005Luna Pier1 200530 28 9316.5031 27 87 13.40 30 27 9019.7831 30 97 13.1015.7014.2261150005Luna Pier1 200630 27 90 14.55 30 29 97 10.91 31 30 97 12.98 31 30 97 12.45 12.72 13.8261150005Luna Pier1 200730 29 97 12.26 30 26 87 11.41 31 29 94 14.87 30 30 100 13.78 13.08 13.8261150005Luna Pier1 200831 31 100 13.25 30 30 100 9.76 31 29 94 12.28 30 27 90 10.16 11.36 12.4261150005Luna Pier1 200930 30 100 13.84 31 30 97 8.19 30 28 93 9.75 31 27 87 9.54 10.33 11.6261150005Luna Pier1 201030 30 100 10.07 30 29 97 7.76 31 31 100 10.73 31 29 94 8.87 9.36 10.43First Quarter Second Quarter Third Quarter Fourth Quarter3-YrAIRSID Site POCSch # Obs. # % Quart.Sch #Obs. # % Quart. Sch # Obs. # % Quart. Sch # Obs. # % Quart.AnnualAnnual261250001Oak Park1 199930 25 83 13.83 30 186014.84 31 25 81 14.64 30 26 87 13.32 14.16261250001Oak Park1 200031 24 7718.5730 28 93 14.79 31 185811.88 30 206716.31 15.39261250001Oak Park1 200130 28 9315.5831 26 8417.3030 26 87 14.81 31 165212.23 14.98 14.8261250001Oak Park1 200230 155012.73 30 217017.2931 27 8716.0731 27 87 13.9015.0015.1261250001Oak Park1 200330 28 9318.3930 27 90 13.79 31 30 97 13.66 30 30 100 12.48 14.58 14.9261250001Oak Park1 200431 30 97 13.73 30 30 100 11.26 31 30 97 14.78 30 27 90 11.26 12.76 14.1261250001Oak Park1 200530 27 9017.4931 31 100 13.77 30 30 10017.6131 30 97 12.9915.4714.3261250001Oak Park1 200630 27 90 13.51 15 15 100 10.40 15 14 93 10.76 16 16 100 13.78 12.11 13.4261250001Oak Park1 200730 30 100 12.48 30 28 93 12.27 31 30 97 14.68 30 30 100 13.89 13.33 13.6261250001Oak Park1 200831 30 97 13.59 30 28 93 8.75 31 30 97 11.31 30 30 100 9.79 10.86 12.1261250001Oak Park1 200930 30 100 14.24 31 30 97 7.26 30 27 90 9.14 31 31 100 9.47 10.03 11.4261250001Oak Park1 201030 29 97 9.91 30 30 100 7.36 31 30 97 10.74 31 29 94 8.46 9.12 10.0261470005Port Huron1 199916 23 144 12.13 30 25 83 13.46 31 28 9015.1230 27 90 11.94 13.16261470005Port Huron1 200031 216817.0430 26 87 14.65 31 29 94 12.83 30 26 87 12.87 14.35261470005Port Huron1 200130 28 93 13.65 31 30 9716.2630 27 90 14.12 31 27 87 11.81 13.96 13.8261470005Port Huron1 200230 29 97 12.13 30 26 87 14.03 31 29 9416.2831 29 94 12.91 13.84 14.0261470005Port Huron1 200330 24 8018.7330 30 100 13.11 31 29 94 13.05 30 27 90 12.11 14.25 14.0261470005Port Huron1 200431 28 90 11.44 30 28 93 12.81 31 27 87 13.18 30 29 97 10.99 12.11 13.4261470005Port Huron1 200530 30 10016.7631 28 90 14.73 30 24 8016.4731 29 94 12.4115.0913.8261470005Port Huron1 200630 30 10015.5215 15 100 10.71 15 15 100 9.09 16 16 100 12.86 12.04 13.1261470005Port Huron1 200730 29 97 12.64 30 28 93 9.97 31 30 97 14.49 30 29 97 12.64 12.44 13.2261470005Port Huron1 200831 30 97 13.66 30 29 97 9.78 31 30 97 11.56 30 29 97 9.31 11.08 11.9261470005Port Huron1 200930 27 90 13.99 31 31 100 6.92 30 29 97 8.86 31 30 97 9.19 9.74 11.1261470005Port Huron1 201030 28 93 8.53 30 30 100 8.06 31 30 97 10.32 31 31 100 8.86 8.94 9.9261610008Ypsilanti1 1999--- --- --- --- --- --- --- --- 20 18 90 14.72 30 28 93 13.66 14.19261610008Ypsilanti1 200031 134216.8230 28 93 12.85 31 31 100 13.21 30 30 100 14.16 14.26261610008Ypsilanti1 200130 28 9315.9231 30 9715.4630 29 97 14.15 31 30 97 12.44 14.49 14.3261610008Ypsilanti1 200230 29 97 14.71 30 30 100 14.57 31 26 8416.4331 29 94 13.72 14.86 14.5261610008Ypsilanti1 200330 25 8316.7030 28 9315.0531 30 97 14.39 30 29 97 12.78 14.73 14.7261610008Ypsilanti1 200431 30 97 13.74 30 28 93 11.76 31 31 100 14.17 30 29 97 11.79 12.87 14.2261610008Ypsilanti1 200530 29 9717.4931 27 87 14.27 30 29 9717.6931 29 94 13.0015.6114.4261610008Ypsilanti1 200630 24 80 14.80 30 29 97 10.67 31 29 94 13.12 31 237411.61 12.55 13.7261610008Ypsilanti1 200730 27 90 12.95 30 27 90 11.68 31 30 97 13.78 30 30 100 13.51 12.98 13.7261610008Ypsilanti1 200831 28 90 13.23 30 30 100 9.07 31 31 100 11.21 30 29 97 10.13 10.91 12.1261610008Ypsilanti1 200930 29 97 13.50 31 30 97 7.76 30 28 93 9.27 31 31 100 9.21 9.94 11.3261610008Ypsilanti1 201030 29 97 9.97 30 28 93 7.32 31 31 100 10.29 31 30 97 9.36 9.24 10.04First Quarter Second Quarter Third Quarter Fourth Quarter3-YrAIRSID Site POCSch # Obs. # % Quart.Sch #Obs. # % Quart. Sch # Obs. # % Quart. Sch # Obs. # % Quart.AnnualAnnual261610008Ypsilanti2 200115 14 9316.1916 16 100 13.99 15 12 80 12.18 15 14 93 12.86 13.81261610008Ypsilanti2 200215 13 87 12.35 15 117313.34 15 117313.17 15 14 93 13.14 13.00261610008Ypsilanti2 200315 14 9316.8015 149313.59 16 16 10017.4115 14 93 12.6915.1214.0261610008Ypsilanti2 200415 14 93 10.29 15 14 93 9.83 16 16 100 13.21 15 15 100 11.01 11.09 13.1261610008Ypsilanti2 200515 15 10018.7915 15 10015.0115 13 8721.3516 16 100 11.6516.7014.3261610008Ypsilanti2 200615 12 8017.9316 13 81 10.52 16 14 8811.6416 16 100 14.01 13.53 13.8261610008Ypsilanti2 20077 6 8617.678 6 75 9.47 7 7 100 14.90 8 6 7515.1714.30 14.8261610008Ypsilanti2 20088 13 16315.177 7 100 9.70 8 7 8818.167 7 100 8.91 12.99 13.6261610008Ypsilanti2 200915 14 93 12.97 16 16 100 9.04 15 14 93 8.02 15 14 93 9.17 9.80 12.4261610008Ypsilanti2 201015 13 87 8.32 15 15 100 8.11 16 16 100 10.25 15 15 100 10.93 9.40 10.7261630001Allen Park1 1999--- --- --- --- 17 48 28218.9992 78 8516.6392 83 90 14.3716.66261630001Allen Park1 200091 81 8916.9991 86 95 13.69 92 87 95 14.46 92 85 9217.08 15.56261630001Allen Park1 200190 76 8420.0591 80 8816.6892 86 9317.4692 556014.7917.25 16.5261630001Allen Park1 200290 78 8715.3291 72 7916.1592 667217.3392 87 9515.02 15.96 16.3261630001Allen Park1 200390 79 8817.3791 86 9515.2592 808715.1190 80 89 13.1715.23 16.1261630001Allen Park1 200491 74 8115.4191 85 93 12.22 92 89 9716.1892 83 90 13.14 14.2415.1261630001Allen Park1 200590 88 9818.4591 86 95 13.77 92 89 9717.1592 86 93 14.3815.94 15.1261630001Allen Park1 200690 81 90 13.70 91 83 91 11.59 92 87 95 13.76 92 90 98 13.65 13.18 14.5261630001Allen Park1 200790 86 96 12.92 91 88 97 10.28 92 86 93 13.74 92 92 100 14.08 12.76 14.0261630001Allen Park1 200891 88 97 13.86 91 90 99 10.18 92 86 93 12.98 92 87 95 10.30 11.83 12.6261630001Allen Park1 200990 84 93 13.87 91 89 98 8.94 92 79 86 11.32 92 86 93 10.11 11.06 11.9261630001Allen Park1 201090 80 89 11.19 91 87 96 8.83 92 84 91 11.83 92 83 90 9.05 10.23 11.0261630001Allen Park2 1999--- --- --- --- 9 66726.0815 13 8718.2215 12 80 14.5419.62261630001Allen Park2 200016 13 8116.8215 12 80 13.32 15 14 9315.2915 15 10018.57 16.00261630001Allen Park2 200115 14 9318.6216 15 9415.8215 15 10016.2215 13 87 14.2216.22 17.3261630001Allen Park2 200215 64013.10 15 96011.80 15 74716.1915 15 100 14.63 13.9315.4261630001Allen Park2 200315 10 6721.2115 15 10016.6316 15 9418.7715 15 100 13.4517.52 15.9261630001Allen Park2 200415 15 100 12.03 15 14 93 10.63 16 15 94 13.68 15 14 93 12.96 12.3314.6261630001Allen Park2 200515 14 9319.6115 15 10016.2215 15 10022.4716 15 94 12.3517.66 15.8261630001Allen Park2 200615 13 8717.3215 13 87 11.35 15 13 87 12.00 16 15 94 14.77 13.86 14.6261630001Allen Park2 20077 57118.048 6 75 8.62 7 6 8617.478 6 7518.47 15.65 15.7261630001Allen Park2 20088 8 100 14.28 7 7 100 11.31 8 56321.027 7 100 9.06 13.92 14.5261630001Allen Park2 200915 15 100 14.55 16 15 94 10.11 15 15 100 9.43 15 117311.20 11.32 13.6261630001Allen Park2 2010monitor moved to Dearborn5First Quarter Second Quarter Third Quarter Fourth Quarter3-YrAIRSID Site POCSch # Obs. # % Quart.Sch #Obs. # % Quart. Sch # Obs. # % Quart. Sch # Obs. # % Quart.AnnualAnnual261630015SW HS1 199912 86718.6930 27 9016.5431 25 8118.5430 25 8316.53 17.57261630015SW HS1 200031 30 9720.3430 28 9317.0431 31 10016.2930 30 10018.71 18.10261630015SW HS1 200130 29 9719.3331 28 9020.0530 30 10017.6731 27 8716.07 18.28 18.0261630015SW HS1 200230 27 9016.8030 27 9017.4231 25 8118.2731 29 9417.20 17.42 17.9261630015SW HS1 200330 26 8717.4130 27 9015.3931 30 9716.6830 27 9017.26 16.69 17.5261630015SW HS1 200431 31 100 14.95 30 27 9015.0131 29 9417.6930 28 93 13.9015.39 16.5261630015SW HS1 200530 27 9020.2031 27 87 14.73 30 30 10018.7331 30 9715.18 17.21 16.4261630015SW HS1 200630 29 9716.9830 26 87 12.26 31 28 90 14.93 31 31 100 14.56 14.6815.8261630015SW HS1 200730 28 9315.1530 30 100 13.06 31 27 87 15.12 30 29 97 14.82 14.5415.5261630015SW HS1 200831 31 10016.0730 30 100 11.00 31 32 103 12.03 30 29 97 12.29 12.85 14.0261630015SW HS1 200930 30 10015.4031 28 90 8.18 30 29 97 10.35 31 29 94 10.53 11.12 12.8261630015SW HS1 201030 30 100 11.35 30 30 100 8.98 31 30 97 11.85 31 30 97 10.51 10.67 11.5261630016Linw ood1 1999--- --- --- --- 17 28 16519.3092 79 8615.7692 82 8916.17 17.08261630016Linw ood1 200091 83 9117.6791 74 81 13.82 92 78 85 13.52 92 90 9816.94 15.49261630016Linw ood1 200190 81 9017.1991 84 9215.6692 83 9016.5792 79 86 13.4715.72 16.1261630016Linw ood1 200290 73 8115.0491 82 9015.6192 75 8216.7892 88 96 14.9515.60 15.6261630016Linw ood1 200390 84 9318.3691 85 9315.3392 86 93 14.94 92 71 77 14.7815.85 15.7261630016Linw ood1 200491 76 84 14.87 91 80 88 12.10 92 82 89 14.78 92 86 93 13.00 13.6915.0261630016Linw ood1 200590 87 9718.9291 79 87 14.78 92 84 9116.6292 88 96 13.7016.01 15.2261630016Linw ood1 200690 79 88 13.04 15 14 93 11.58 15 13 87 12.58 16 17 106 14.97 13.04 14.2261630016Linw ood1 200730 26 87 13.98 30 26 87 12.12 31 30 97 14.74 30 29 97 14.61 13.86 14.3261630016Linw ood1 200831 29 94 14.59 30 30 100 9.58 31 29 94 12.61 30 30 100 10.96 11.94 12.9261630016Linw ood1 200930 27 90 14.27 31 27 87 8.22 30 26 87 9.23 31 31 100 9.70 10.36 12.1261630016Linw ood1 201030 26 87 10.42 30 28 93 8.55 31 31 100 11.34 31 30 97 9.10 9.85 10.7261630019E 7 Mile1 2000--- --- --- --- 21 17 81 13.93 31 24 77 13.74 30 29 9715.8714.51261630019E 7 Mile1 200130 26 87 14.58 31 29 94 14.88 30 30 100 14.76 31 30 97 13.79 14.50261630019E 7 Mile1 200230 26 87 14.39 30 28 9315.8331 28 9017.8631 30 97 14.4815.6414.9261630019E 7 Mile1 200330 26 8717.0530 30 100 14.80 31 30 97 13.98 30 29 97 13.01 14.7115.0261630019E 7 Mile1 200431 31 100 13.23 30 29 97 12.47 31 30 9715.4430 29 97 11.76 13.23 14.5261630019E 7 Mile1 200530 28 9319.8231 31 100 14.48 30 29 9717.4331 29 94 14.2016.4814.8261630019E 7 Mile1 200630 30 10015.2015 15 100 10.39 15 14 93 11.78 16 16 100 13.46 12.71 14.1261630019E 7 Mile1 200730 30 100 13.20 30 28 93 11.16 31 31 100 14.36 30 27 90 13.31 13.01 14.1261630019E 7 Mile1 200831 30 97 13.60 30 30 100 9.51 31 26 84 11.42 30 30 100 10.79 11.33 12.3261630019E 7 Mile1 200930 30 100 14.73 31 31 100 7.61 30 26 87 9.88 31 28 90 9.95 10.54 11.6261630019E 7 Mile1 201030 30 100 10.27 30 23 77 8.68 31 26 84 11.18 31 29 94 9.44 9.89 10.66First Quarter Second Quarter Third Quarter Fourth Quarter3-YrAIRSID Site POCSch # Obs. # % Quart.Sch #Obs. # % Quart. Sch # Obs. # % Quart. Sch # Obs. # % Quart.AnnualAnnual261630025Livonia1 1999--- --- --- --- --- --- --- --- 15 15 10015.2130 196310.93 13.07261630025Livonia1 200031 30 9716.5330 28 93 14.08 31 30 97 13.28 30 25 83 14.46 14.59261630025Livonia1 200130 27 9015.3931 30 9715.6730 29 9715.1431 29 94 12.18 14.60 14.1261630025Livonia1 200230 186013.33 30 28 93 14.26 31 29 9416.4731 28 90 13.43 14.37 14.5261630025Livonia1 200330 26 8715.9630 28 10015.3631 31 100 13.89 30 27 90 11.59 14.20 14.4261630025Livonia1 200431 29 94 12.72 30 25 83 11.98 31 28 90 14.13 30 30 100 11.45 12.57 13.7261630025Livonia1 200530 26 8717.8631 28 90 11.74 30 30 10017.4531 30 97 12.68 14.93 13.9261630025Livonia1 200630 27 90 13.49 15 14 93 11.23 15 15 100 10.01 16 17 106 12.70 11.86 13.1261630025Livonia1 200730 26 87 12.23 30 30 100 10.59 31 31 100 13.76 30 27 90 14.42 12.75 13.2261630025Livonia1 200831 27 87 13.56 30 29 97 9.50 31 31 100 11.21 30 30 100 9.77 11.01 11.9261630025Livonia1 200930 29 97 13.93 31 31 100 7.40 30 28 93 9.19 31 28 90 9.01 9.88 11.2261630025Livonia1 201030 28 93 9.37 30 29 97 6.65 31 27 87 10.98 31 30 97 9.40 9.10 10.0261630033Dearborn1 199919 84213.98 30 26 8716.7531 28 9018.3130 29 9718.24 16.82261630033Dearborn1 200031 29 9422.7630 23 7720.1331 27 8717.5630 29 9720.06 20.13261630033Dearborn1 200130 29 9720.9531 29 9418.5830 28 9318.2731 29 9420.63 19.61 18.9261630033Dearborn1 200230 29 9720.9930 28 9318.1531 29 9420.2231 30 9720.00 19.84 19.9261630033Dearborn1 200330 28 9322.5930 27 9019.0331 27 8717.8330 28 9317.34 19.20 19.5261630033Dearborn1 200431 29 9417.7130 25 8316.1031 25 8117.4630 28 9316.06 16.83 18.6261630033Dearborn1 200530 28 9321.5031 31 10016.5730 28 9318.2231 28 9017.90 18.55 18.2261630033Dearborn1 200630 28 9318.7930 29 97 12.85 31 27 8715.5631 31 10017.30 16.13 17.2261630033Dearborn1 200730 29 9718.8430 29 9715.2031 29 9416.0230 27 9017.49 16.89 17.2261630033Dearborn1 200831 31 10016.5930 28 93 11.18 31 30 97 13.51 30 30 100 12.06 13.3415.4261630033Dearborn1 200930 29 9717.2931 31 100 8.42 30 27 90 10.42 31 31 100 12.13 12.07 14.1261630033Dearborn1 201030 27 90 11.70 30 30 100 9.39 31 30 97 12.32 31 31 100 11.90 11.33 12.2261630033Dearborn2 201015 14 93 13.18 15 15 100 10.05 16 15 94 12.30 15 15 100 13.70 12.31261630036Wyandotte1 199914 75017.0630 175714.55 31 26 8418.8530 217014.6716.28261630036Wyandotte1 200031 165219.3030 28 9316.5231 29 9415.6430 30 10019.07 17.63261630036Wyandotte1 200130 30 10021.4931 30 9717.5330 29 9718.5331 24 7715.26 18.20 17.4261630036Wyandotte1 200230 24 8015.4030 28 9315.9831 28 9016.5131 25 8117.24 16.28 17.4261630036Wyandotte1 200330 24 8015.0730 24 8020.3731 28 9016.3730 29 97 13.4516.32 16.9261630036Wyandotte1 200431 27 87 14.48 30 29 97 12.74 31 29 9415.9130 28 93 11.52 13.6615.4261630036Wyandotte1 200530 29 9716.9631 28 90 14.93 30 29 9718.5831 27 8715.19 16.42 15.5261630036Wyandotte1 200630 29 9715.1030 26 87 10.95 31 29 94 13.69 31 29 94 11.94 12.92 14.3261630036Wyandotte1 200730 29 97 13.75 30 28 93 11.96 31 30 97 14.60 30 29 97 13.47 13.45 14.3261630036Wyandotte1 200831 31 100 12.55 30 29 97 9.47 31 30 97 11.95 30 30 100 9.78 10.94 12.4261630036Wyandotte1 200930 28 93 14.21 31 30 97 7.86 30 28 93 9.89 31 25 81 9.47 10.36 11.6261630036Wyandotte1 201030 23 77 9.44 30 29 97 7.84 31 29 94 11.30 31 31 100 8.84 9.36 10.27First Quarter Second Quarter Third Quarter Fourth Quarter3-YrAIRSID Site POCSch # Obs. # % Quart.Sch #Obs. # % Quart. Sch # Obs. # % Quart. Sch # Obs. # % Quart.AnnualAnnual261630038New berry1 2004--- --- --- --- --- --- --- --- --- --- --- --- 2 2 10029.70261630038New berry1 200530 28 9316.9831 25 81 14.60 30 227317.66 16.41261630038New berry1 200630 29 97 11.09 31 27 87 14.34 31 28 90 11.98 12.47261630038New berry1 200730 27 90 13.63 30 27 90 12.85 31 28 9015.3530 30 100 14.23 14.02 14.3261630038New berry1 200831 29 94 13.95 30 30 100 10.15 31 28 90 12.16 30 28 93 10.99 11.81 12.8261630038New berry1 200930 25 83 13.24 31 29 94 7.89 30 27 90 9.43 31 29 94 10.12 10.17 12.0261630038New berry1 201030 27 90 9.39 30 30 100 8.73 31 31 100 11.92 31 30 97 10.12 10.04 10.7261630039FIA\Lafayette St1 2005--- 7 ---18.2031 28 90 14.25261630039FIA\Lafayette St1 200630 29 97 14.78 30 30 100 11.71 31 31 100 14.20 31 30 97 11.84 13.13261630039 FIA\Lafayette St 1 2007 30 29 97 13.83 30 30 100 12.98 31 30 97 14.65 30 28 93 13.86 13.83 13.5261630039 FIA\Lafayette St 1200831 30 97 14.26 30 28 93 10.70 31 29 94 12.80 30 29 97 11.14 12.23 13.1261630039 FIA\Lafayette St1 200930 29 97 14.67 31 31 100 7.89 30 30 100 9.44 92 84 91 10.78 10.70 12.3261630039 FIA\Lafayette St1 201090 83 92 10.69 91 89 98 8.65 92 76 83 11.22 92 84 91 9.62 10.05 11.0A 3-year annual average of 15.1 ug/m3 would violate the NAAQS according to the data handling conventions in 40 CFR part 50vandalismvandalism8CurrentSampling1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 99-01 00-02 01-03 02-04 03-05 04-06 05-07 06-08 07-09 08-10 09-11AIRS ID SitePOC Freq98th% ile98th% ile98th% ile98th% ile98th% ile98th% ile98th% ile98th% ile98th% ile98th% ile98th% ile98th% ileAvg Avg Avg Avg Avg Avg Avg Avg Avg Avg Avg260990009 New Haven 1 1 in 3 31.9 33.242.0 35.631.8 31.941.534.4 29.0 28.9 26.2 25.536 37 363335 3635 31 28 27 26261150005 Luna Pier 1 1 in 3 18.137.2 39.2 42.734.7 35.049.332.6 32.2 28.6 23.6 26.3 3240 39 37 40 39 3831 28 26 25261250001 Oak Park 1 1 in 342.8 40.7 39.4 38.4 36.632.552.233.035.330.4 30.1 27.141 40 38 36 40 39 4033 32 29 29261470005 Port Huron 1 1 in 344.533.140.5 35.3 37.232.247.6 37.9 36.331.0 29.9 25.839 36 383539 39 413532 29 28261470005 Port Huron 2 --- --- ---35.9 37.7 38.0--- --- --- ---36 37 37--- --- --- --- --- --- --- ---261610008 Ypsilanti 1 1 in 340.630.339.730.938.831.552.131.3 34.5 28.2 28.2 23.33734363441 38 3931 30 27 26261610008 Ypsilanti 2 1 in 6 --- ---39.032.6 32.5 31.254.633.0 30.6 31.3 29.4 22.439 3635 3239 40 3932 30 28 26261630001 Allen Park 1 1 in 143.7 38.6 44.2 39.6 40.5 36.9 43.032.8 31.0 30.3 29.2 27.842 41 41 39 40 38 3631 30 29 29261630001 Allen Park 2 1 in 644.134.640.130.939.233.858.034.236.232.3 32.4 ---4035373544 42 4334 34 --- ---261630015 SW High Sch. 1 1 in 350.2 44.5 42.9 38.233.636.0 49.7 36.234.0 34.3 30.9 26.646 42 38 36 40 41 403533 31 29261630016 Linw ood 1 1 in 644.5 40.3 40.9 42.7 46.2 38.3 51.8 36.934.3 30.0 31.0 27.942 41 43 42 45 42 4134 32 30 29261630019 E 7 Mile 1 1 in 6 ---42.0 42.034.437.135.052.3 36.231.9 31.9 29.2 28.642 39 38 36 41 41 4033 31 30 29261630025 Livonia 1 1 in 638.4 35.9 44.732.738.132.240.230.4 32.8 28.3 29.3 25.340 38 393437 3434 31 30 28 27261630033 Dearborn 1 1 in 345.1 45.1 43.2 45.7 42.8 39.4 50.2 43.1 36.631.735.728.644 45 44 43 44 44 43 373532 32261630033 Dearborn 2 1 in 6 --- --- --- --- --- --- 31.5 --- --- --- --- --- ---261630036 Wyandotte 1 1 in 345.0 42.7 46.634.1 34.8 32.346.733.2 28.6 26.3 26.9 24.445 41 393438 37 3629 27 26 26261630038 New berry 1 1 in 3 --- --- --- --- ---36.8 57.528.6 33.4 31.5 25.9 30.4 --- --- --- --- ---41 4031 30 29 28261630039 FIA/Lafayette 1 1 in 3--- --- --- --- --- ---43.932.4 34.8 31.7 31.7 27.7 ------ --- --- ---38 3733 33 30 30A 3-year 24-hour average of 36 ug/m3 would violate the NAAQS according to the data handling conventions in 40 CFR part 5098thPercentile PM2.5Values Averaged over 3 Yearsupdated 3/1/11

# Appendix B

EMISSIONS INVENTORY

METHODOLOGY

SUPPORT DOCUMENTATION

FOR THE

PM 2.5 

# REQUEST TO REDESIGNATE TO

ATTAINMENT

− SOUTHEAST MICHIGAN

March 2011

## Table of Contents

Page No.

1. Introduc tion .......................................................................................................1

2. EGU Point Sources...........................................................................................1

3. Non-EGU Poin t Sources ...................................................................................3

4. Stationary Area (N on-point) S ources ................................................................7

5. Non-road Mob ile Sour ces ................................................................................47

6. On-road Mobile Sources..................................................................................49Page 1 

## 1. Introduction

2005 and 2008 Emissions Inventory

Emissions inventory documentation support for the PM 2.5 

### Request to Redesignate to Attainment is provided in this appendix. An inventory was prepared for the following Michigan counties: Livingston, Macomb, Mo nroe, Oakland, St. Clair, Washtenaw, and Wayne. Mobile estimates for the nona ttainment counties were prepared by the Southeast Michigan Council of Governm ents (SEMCOG). The remaining emission source categories were developed by t he Michigan Department of Environmental Quality (MDEQ) and the Lake Michigan Air Dir ector’s Consortium (LADCO). LADCO is the Midwest Regional Planning Organization (MRPO) which MDEQ and other Midwest

states access for a multitude of technical air quality planning activities. The focus of the inventory effort was to produce emission inv entories for the nonattainment year (2005) and the attainment base year (2 008). The future year proj ections (2018 and 2022) take into account existing control measures and measures that are promulgated and known to be on the way. Many of t he future year emission estimate s for this inventory product

were taken from the LADCO Base B Inventor y. Where data was not available in the Base B inventory, data from the previous inventory cycle - Base M run was utilized, if appropriate. Procedures used to prepare the Base M inventor y product can be found in

the Regional Air Quality Analyses for Ozone, PM 2.5 

### , and Regional Haze: Technical Support Document , prepared by LADCO. LADCO has produced numerous summary reports with state and county tota l emissions, and posted them on their Internet site at:

http://www.ladco.org/tech/emis/

In a related effort, the 2005 and 2008 Michigan statewide inv entories were submitted to the U.S. Environmental Protection Agency (EPA) by the MDEQ pursuant to 40 CFR Part 51, Subpart A – Emissions Inventory R eporting Requirements. Many of the more significant methodologies are described in this appendix.

2018 and 2022 Growth and Control Factors

To assess progress for attaining air quality g oals, LADCO uses emission activity growth

and control data to forecast emissions from a 2005 nonattain ment year and 2008 attainment year inventories to two future y ears of interest. Thes e future years include 2018 and 2022 (e.g., 2018 is the first milest one for regional haze reasonable progress demonstrations). As a contractor to LADC O, Pechan prepared emission control factors to support forecasting for 2018 and 2022. Bec ause the incremental level of effort required to develop emission activity growth factors for each year over the 2003-2018 period was nominal, Pechan prepared non-electric generat ing unit (non-EGU) point, area and non-road source growth factors for each year over this entire period.

For the non-EGU point source, stationary area source and Marine, Air and Railroad (MAR) source sectors, the fu ture year emissions for the LADCO states were derived by applying growth and control factors to the base year inventory. Growth factors were based initially on Economical Growth Analysis System (E GAS version 5.0), and werePage 2 

### subsequently modified (for select priority ca tegories) by examini ng emissions activity

data.

The report, Development of 2005 Base Year Grow th and Control Factors for Lake Michigan Air Directors Consortium (LADCO), describes Pechan’s efforts to develop emission growth and control data to support fu ture year air quality modeling by LADCO. The report is organized into a background chapter and:

Chapter II, which describes the development of the emission activity growth data; Chapter III, which discusses how the emission control data were compiled; Chapter IV, which describes the preparation of the growth and cont rol factor files; Chapter V, which identifie s projection issues for future consideration; and Chapter VI, which presents the referenc es consulted in preparing this report.

The Pechan Growth and Control Factor report is too lengthy to be included in this document, but it can be prov ided upon request or downloaded at:

http://www.ladco.org/reports/technical_s upport_document/references/ladco_2005_base _yr_growth_and_control s_report_final.pdf

Additional information on the procedures used to project emissions can be found in the Regional Air Quality Analyses for Ozone, PM 2.5 

### , and Regional Haze: Technical Support

Document , prepared by LADCO.



## 2. EGU Point Sources

2005 EGU Point Source Methodology

The 2005 electrical generation unit (EGU) po int source data originated with annual emissions data provided to MD EQ via the Michigan Air Em issions Reporting System (MAERS). Temporal allocation was perform ed by emission unit, month, day of week, and hour using the procedures described in Temporally Allocating Emissions with CEM Data for Chemical Transport and SIP Modeling , available at:

http://www.epa.gov/ttn/chief/conference/ei15/session4/edick.pdf

In addition to the heat input-based temporal profiles described in the paper, separate temporal profiles were developed based on Continuous Emissions Monitoring (CEM) reported emissions of nitrogen oxi des (NOx) and sulfur dioxide (SO 2 

### ) and these profiles were used instead of heat input to tempor alize annual emissions of the respective pollutants into winter weekday. The CEM data used as the basis of the profiles was for 2004 through 2006, obtained from t he EPA Clean Air Markets Division (CAMD) website:

http://cfpub.epa.gov/gdm/index.cfm ?fuseaction=iss.progressresults

2008 EGU Point Source MethodologyPage 3 

### Year 2008 EGU annual emissions were obtained from MAERS, and temporally adjusted to represent winter weekday as determi ned from LADCO base B inventory data.

2018 Future Year EGU Point Source Methodology

In developing emission projections for y ear 2018, consideration was given to both British Thermal Units (BTU) heat input of EG Us within the 7-county area, as well as scheduled facility improvements such as sele ctive catalytic reduction (SCR) of NOx and flue gas desulfurization (FGD) for reduction of SO 2 

### . Because of several utility and industrial EGUs that experi ence load-shifting among various units, peaker plant use, and occasional shutdowns, total combined BT U heat input data was obtained for the 7- county region for each year of years 2002 – 2008. Correlation and bivariate regression analysis of each year’s BTU heat input wa s then performed to forecast the 7-county future year boiler BTU heat input requirements. The results of this analysis were then used to predict year 2018 BTU heat i nput and for comparison with other known Integrated Planning Model (IPM) studies by the EPA in their development of the air transport rule. The EPA relied on the IPM m odel when developing their base case v.4.10 emission projections for years 2012- 2050. The EPA’s base case v.4.10 IPM

model results consider the national Title IV SO 2 

### cap-and-trade progra m, NOx SIP Call regional ozone season cap-and-trade program, and all current settlements and state rules. The EPA base case simulation repr esents conditions without the proposed transport rule and without the rule it replaces, the Clean Air In terstate Rule (CAIR). The predicted BTU heat input obtaine d from regression forecasts was then compared to the heat input results obtained by the EPA’s bas e case v.4.10 IPM model results and also with LADCO/Visibility Improvem ent State and Tribal Association of the Southeast (VISTAS) BTU heat input to determine t he reasonableness of the prediction. Deductions were made for selective catalytic reduction and flue gas desulfurization at

the Detroit Edison Monroe Power Plant that occurred after y ear 2008. These additional control measures would explain the further reduction in emissions in the future year

2018 emission forecast.

2022 Future Year EGU Point Source Methodology

Bivariate regression analysis was used to fo recast future year 2022 energy demand as BTU heat input of EGUs for t he 7-county planning area, as was done in the earlier 2018

forecast. Because emission reductions occurred in earlier years between 2008 and 2018, the later 2022 forecast is reflective of expected energy demand growth after control measures were implemented at t he Detroit Edison Monroe Power Plant.Page 4 

## 3. Non-EGU Point Sources

2005 Non-EGU Point Source Methodologies

The original source of the 2005 point sour ce data is the 2005 Michigan point source emission inventory. This section of t he document describes the compilation and processing of point source emission data s ubmitted to comply wit h the Consolidated Emission Reporting Rule (CER R) for the EPA National Emi ssions Inventory (NEI) 2005 inventory.

The data originates with the ent ry of data by the reporting fa cilities into MAERS. The electronic data received from the reporting fa cilities is reviewed and compiled by the MDEQ and exported to the fixed-width text version of the National Inventory Format (NIF). After the exported data is loaded in to a PostgreSQL database patterned after the Microsoft (MS) Access version of the NIF, the following processing steps and checks are performed.

Both emissions estimated by default calcul ations in MAERS and any emissions reported by facility operators are maintained in MAERS. For evaluation and quality assurance purposes, both types of record s are included in the exports . To avoid double-counting, where a specific process/pollutant has emi ssion records both reported directly by the facility operator and estimated via MAERS calculations, the latter are excluded.

Portable facilities such as asphalt plants r eport total throughput and emissions, plus operating percentages for each county in which the portable facility was located during the year. From this information, record s are generated for each county of operation, and throughput and emissions are apportioned based on the operating percentages reported by county and process. As geographic coordinates for all operating sites are not reported, coordinates corre sponding to the centers of the counties of operation are assigned.

As attention has shifted from total particulate to PM 10 

### and PM 2.5 

### , total particulate records

are excluded from the reporting requirements.

Over 99.8% of total criteria pollutant emissions are acc ounted for by emissions reported by the operator. Therefore, exported criteria emissi ons estimated via MAERS

calculations are excluded.

In the site table, where strF acilityCategory is not set in the export, it is set to “01.”

Mandatory geo-coordinate fields were added to the NIF specifications released in December 2003, well after it would have been possible to collect this information from the reporting facilities for 2002 operations. T he following values were deemed most often representative and the exported dat a are updated accordingly for 2002 data:

“strHorizontalCollectionMe thodCode” is set to '027' “strHorizontalAccuracyMeas ure” is set to '2000'Page 5 

### “strHorizontalReferenceDatumCode” is set to '001'

“strReferencePointCode” is set to '106'

For 2005, these geographic data elements were r equested of the facilities. The defaults above were applied only where data was not provided by the facility.

MAERS tracks emissions of some pollutants t hat are of interest to the Great Lakes Commission (GLC), but which do not have corresponding pollutant codes in the most recent NIF pollutant code tabl e. Emission records for the following pollutant codes are

excluded:

7440508; 8052413; DICDD,TOT; DICDF,TOT; HYDFLUORO; PERFLUORO; TRICDD,TO; TRICDF,TO; CH4 ; CO2; N20; 117840; 7783064.

Emission records for ammonia are exported wit h the Chemical Abstract Service number 7664417, rather than the pollutant code NH3 . These pollutant codes are updated to NH3. Likewise, records exported with pol lutant codes PAH and POM are updated to pollutant codes 234 and 246, respectively.

All criteria and Hazardous Air Pollutant (H AP) emissions are repor ted at the process level, and the export routines reflect that in the strEmissionDataLevel field of the

emission table. This field is set to null for criteria pollutant emission records per EPA guidance.

All emissions are exported as pounds of annual emissions. The EPA guidance suggests that criteria pollutant emi ssion be reported in tons. The field strEmissionUnitNumerator is changed to TO N and the filed dblEmissionNumericValue is divided by 2000 for criteria pollutant emission records.

Null values in the quarterly throughput fiel ds of process record s are set to zero.

Where quarterly throughput fields of pr ocess records sum to zero, throughput percentages are set to 25% for each quarter.

MAERS recognizes a control device code of '909' for a “Roll Media Fiberglass Tack Filter (Tacky 1 side),” which is not recognized in the NIF code tables. Where this control device code is exported, the “strPrimaryDev iceTypeCode” field of the control equipment table is updated to a value of 058.

Because of the exclusion of emission records as described above, referential integrity of the exported data can be compromi sed. At this point, it is re-established by deleting records stepwise, in the following order.

CE records without corresponding EM records PE records without corresponding EM records EP records without corresponding EM records ER records without corresponding EP records EU records without corresponding EP recordsPage 6 

### SI records without corresponding EU records

The data are then checked again for referentia l integrity and mandatory fields and then

loaded into the MS Access shell version of the NIF via append queries that connect to the PostgreSQL data tables via ODBC. T he Basic Content and Format Checker is run and its output is reviewed. Where correct ions are needed, to assure consistency among data sources, the correct ions are made in the MAERS and a full iteration of the export and post-processing steps are performed.

The 2005 point source inventory was incorp orated into the LADCO Base M inventory

and serve as the basis for Mi chigan’s 2005 CERR submittal.

2008 Stationary Non-EGU Point Source Methodologies

The 2008 point source data have as their or iginal sources the 2008 Michigan point source emission inventory. This section of the document describes the compilation and processing of point source emission data submitted to comply with CERR for the EPA NEI 2005 inventory.

The data originates with the ent ry of data by the reporting fa cilities into the MAERS.

The electronic data received fr om the reporting facilities is reviewed and compiled by the MDEQ, and exported to the Consolidat ed Emissions Reporting Schema (CERS) extendible markup language (XML) text versi on of the EPA Emissions Inventory System (EIS). After the exported data is loaded into a PostgreSQL database patterned after the MS Access version of the CERS Staging Ta bles, the following processing steps and checks are performed.

Both emissions estimated by default calculat ions in MAERS and any emissions reported by facility operators are maintained in MAER S. For evaluation and quality assurance purposes, both types of record s are included in the exports . To avoid double-counting, where a specific process/pollutant has emi ssion records both reported directly by the facility operator and estimated via MAERS calculations, the latter are excluded.

Portable facilities such as asphalt plants r eport total throughput and emissions, plus operating percentages for each county in which the portable facility was located during the year. From this information, record s are generated for each county of operation, and throughput and emissions are apportioned based on the operating percentages reported by county and process. As geographic coordinates for all operating sites are not reported, coordinates corre sponding to the centers of the counties of operation are assigned.

As attention has shifted from total particulate to PM 10 

### and PM 2.5 

### , total particulate records

are excluded from the reporting requirements.

Over 99.8% of total criteria emissions are accounted for by emissions reported by the operator, therefore exported cr iteria emissions estimated via MAERS calculations are

excluded.Page 7 

### All criteria and HAP emissions are reported at the process level.

All emissions are exported as pounds of annual emissions. The EPA guidance suggests that criteria pollut ant emissions be reported in tons. The CERS emissions

field is converted to TONs and the em issions unit field is changed to TON.

Null values in the quarterly throughput fiel ds of process record s are set to zero.

Where quarterly throughput fields of pr ocess records sum to zero, throughput percentages are set to 25% for each quarter.

The 2008 point source inventory was incorp orated into the LADCO Base B inventory

and serve as the basis for Mi chigan’s 2008 CERR submittal.

2018 and 2022 Future Year Stationary Non-EGU Point Source Methodologies

A Correlation/Regression analysis of energy demand as expressed as BTU heat input for actual year fuel consumption of year s 2002-2008 obtained from MAERS was used to derive future year growth factors. The resu lts of this analysis did not indicate any trend with time within the 7-county planning r egion. Future year 2018 and 2022 emission projections take into consideration a 7-y ear average of the BTU heat input from nonEGU sources. Additional analysis was perfo rmed at the statewide level using Energy

Information Administration fuel BTU heat input data for years 2002-2008. Unlike the Southeast Michigan 7-county area, which didn’ t show any trend with time, the statewide correlation/regression analysis showed a declin ing trend with time in BTU heat input. It was found that the 7-year average BTU heat i nput resulted in growth factors for the 7- county area that were greater than those obtai ned from the statewide correlation/regression analysis.



## 4. Stationary Area (Non-point) Sources

2005 and 2008 Stationary Area Source Emission Inventory

The following is a description of the vari ous area source categories that were inventoried as part of the years 2005 and 2008 emissions inventories as required by the EPA under CERR. It also provides document ation as part of the development of a broader emissions inventory (which encompa sses point, area, non-road mobile, on-road mobile, and biogenic sources) that is bei ng developed to support State Implementation Plan (SIP) requirements for at tainment demonstrations.Page 8Summary of Area Sources and Respective AirPollutants Inventoried for 2005 InventorySeq # Area Source Description SCCs SIC CO NH3 NOxPM10-PRIPM25-PRI SOX VOC1 Residential coal 2104001000 8811√√√√√√√2 Residential distillate oil 2104004000 8811√√√√√√√3 Residential kerosene 2104011000 8811√√√√√√√4 Residential natural gas 2104006000 8811√√√√√√√5 Residential propane 2199007000 8811√√√√√√6 Commercial coal 2103002000 9999√√√√√√√7 Commercial distillate oil 2103004000 9999√√√√√√√8 Commercial kerosene 2103011005 9999√√√√√√√9 Commercial natural gas 2103006000 9999√√√√√√√10 Commercial residual oil 2103005000 9999√√√√√√√11 Industrial coal 2102002000 3999√√√√√√√12 Industrial distillate oil 2102004000 3999√√√√√√√13 Industrial kerosene 2102011000 3999√√√√√√√14 Industrial natural gas 2102006000 3999√√√√√√√15 Industrial residual oil 2102005000 3999√√√√√√√16 Remedial action 2660000000 9511√√√√√17 Municipal landfills 2620030000 4953√√√√√Page 9 

### Stationary Source Fossil Fuel Combustion

The combustion of natural gas, propane-liquefied petroleum gas (LPG), distillate fuel oil, kerosene, and residual fuel oil in small boile rs, furnaces, heaters, and stoves are also a source of VOC, NO x, particulates, SO 2 

### , and ammonia emissions. Because these sources are so numerous to be identified in poi nt source inventories, this area source category attempts to provide a collective estimate of emissions from these smaller energy consumption sources by subtracting all f uel used by point sources from total fuel consumption. Procedures for the estimation of these smalle r sources are presented in

the EPA’s documents entitled:

1. Volume II, Chapter 2 of the Emission Inventory Im provement Program January

2001 Preferred and Alternate Methods for Es timating Air Emissions from Boilers.

2. Emission Inventory Improvement Program –April 6, 1999, Area Source Category

Abstract- Fuel Oil and Kerosene Combustion.

3. Emission Inventory Improvement Program –April 6, 1999, Area Source Category

Abstract-Natural Gas and LPG Combustion.

4. Emission Inventory Improvement Program –April 6, 1999, Area Source Category

Abstract-Coal Combustion.

5. Documentation for the Dr aft 1999 National Emissions Inv entory (Version 3.0) for

Criteria Air Poll utants and Ammonia.

6. Hanke, B.H, manuscript prepared fo r U.S Environmental Protection Agency

entitled: A National Methodology and Emission Inventory for Residential Fuel

Combustion.

This documentation involves determination of total fuel consumpti on over an area with subsequent fuel deductions made for point sour ce fuel consumption, and then applying

emissions factors to estimate fuel emissions.

Total fuel consumption information was bas ed on data supplied from U.S. Department of Energy, Energy Information Administration (EIA) document s. The unaccounted fuel consumption was then apportioned to individ ual counties using U.S. Census Bureau

information for the individual end use sect or fuel types bas ed on LADCO states methodology. Area source fuel emissions were reported for the following residential, commercial/institutional, and industrial end use sectors. Since utility boilers are accounted as point sources, area source emissions are not reported for this end use

sector.

Residential Boilers & FurnacesPage 10 

### County emission estimates for the resident ial end use sector were based on the consumption of natural gas, propane-LPG, distillate fuel oil, kerosene, and coal. This energy consumption informati on was obtained from U.S. Department of Energy, EIA data. Since the EIA merely provides stat ewide fuel consumption totals, county fuel consumption estimates were obtained by app ortioning the fuel consumption based on the number of year 2000 occupied household census counts using the given fuel.

Emission estimates were calculated usi ng the following mathematical equation:

Cf = Ch/Sh x Sf

Where:

Cf = Estimated county residential sector consum ption of a given fuel type for year 2005

Ch = Number of year 2000 census occupied households in a given county that utilize a given fuel type

Sh = Total number of year 2000 census o ccupied households statewide that utilize a given fuel type

Sf = Total statewide resi dential sector consumpti on of a given fuel type

Michigan Residential Fuel Cons umption Information Sources

Residential Fuel Type U.S. Dept of Energy, EIA Data Sources

Natural gas Natural Gas Annual 2005, Michigan Table 48 Propane LPG Petroleum Marketing Annual, 2005, Table 49: Prime Supplier Sales Volumes of Aviation Fuels, Propane and Residual Fuel Oil by PAD District and State

Distillate fuel oil Fuel Oil and Ke rosene Sales 2005 Report, Table 19: Adjusted Sales for Residential Use: Distillate Fuel Oil and Kerosene, 2005

Kerosene Fuel Oil and Kerosene Sales 2005 Report, Table 18: Adjusted Sales of Kerosene by Energy Use Coal EIA Annual Coal Report 2005, Table 26 U.S. Coal Consumption by End Use Sect or, by Census Division and State 2005, 2004 (Thousand Short Tons)

Upon obtaining county residential fuel consumption estimates for the various fuel types in all Michigan counties Cf, emission estima tes were obtained by applying an emission factor that is specific to that fuel type. These emi ssion factors were obtained from various EPA publications.Page 11 

### Michigan Residential Fuel Emission Factors

Residential Fuel Type Units CO NH 3 NOx PM 10 - PRI PM 25 - PRI SO 2 VOC

Natural gas Lbs/million

cubic feet 40 0.49 94 7.6 7.6 0.6 5.5

Propane

LPG Lbs/1,000 gal 3.2 13 0.68 0.68 0.1 0.5

Distillate

fuel oil Lbs/1,000 gal 5.0 0.8 18 2.38 2.13 42.60 0.7

Kerosene Lbs/1,000 gal 4.8 0.8 17.4 2.38 2.13 41.1 0.7

Coal Lbs/ton 275 0.000565 3.0 18.63 4.86 37.83 10



### Sources of Emission Factors:

1. U.S. Environmental Protection Agency Documentation for the Draft 1999 National Emissions Inventory (Version 3. 0) for Criteria Ai r Pollutants and

Ammonia.

2. Hanke, B.H, manuscript prepared fo r U.S Environmental Protection Agency

entitled: A National Methodology and Emission Inventory for Residential Fuel

Combustion.

3. U.S. Environmental Protec tion Agency. Final Report on Development and

Selection of Ammonia Emission Factors.

The resulting emission estimates were r eported by individual fuel type using the following SCC codes:

Michigan Residential Com bustion Emission SCC Codes

Residential Fuel Type SCC

Natural gas 2104006000 Propane LPG 2199007000

Distillate fuel oil 2104004000

Kerosene 2104011000

Coal 2104001000Page 12 

### Commercial/Institutional Boilers and Furnaces

Estimation of fuel combustion by the comme rcial/institutional sector was performed using an adaptation of a methodology present ed in the following EPA publications:

1. Emission Inventory Improvement Progr am –April 6, 1999, Area Source Category

Abstract- Fuel Oil and Kerosene Combustion

2. Emission Inventory Improvement Program –April 6, 1999, Area Source Category

Abstract-Natural Gas and LPG Combustion

3. Emission Inventory Improvement Program –April 6, 1999, Area Source Category

Abstract-Coal Combustion

County emission estimates for the commercial/ institutional end use sector were based on the consumption of natural gas, residual fuel oil, distillate fuel oil, kerosene, and coal. This energy consumption information was ob tained from U.S. Department of Energy,

EIA data. Fuels were subtra cted for point sources, and t he net area fuel contribution was apportioned or allocated using procedures instructed by LADCO. This procedure

involved statewide commercial/ institutional fuel apportionment to a county level using the commercial/institutional employment data as obtained from U.S. Department of Commerce, Bureau of Census publication entitled County Business Patterns, Michigan:

2003 (CBP/03-24 issued September, 2005). County fuel estimate s of individual fuel types were estimated usi ng the following equation:

Cf = Ce/Se x Sf

Cf = Estimated county commercial/instituti onal sector consumption of a given fuel type Ce = Total county employment in t he commercial/institutional sector Se = Statewide employment in commercial/institutional sector

Sf = Statewide commercial/institutional se ctor consumption of a given fuel type

Because the Energy Information data includes di esel fuel totals within the distillate fuel oil total, these motor vehicle fuels were dedu cted to provide only an estimate of #1, #2,

and #4 fuel oils.Page 13 

### Michigan Commercial/Institutional Fue l Consumption Information Sources

Fuel Type U.S. Dept of Energy, EIA Data Sources Natural gas Natural Gas Annual 2005, Michigan Table 48

Residual fuel oil Fuel Oil and Ke rosene Sales 2005 Report, Table 17: Adjusted Sales of Residual Oil by Energy Use, 2004 and

2005

Distillate fuel oil Fuel Oil and Kero sene Sales 2005 Report, Table 20: Adjusted Sales for Commercial Use: Distillate Fuel Oil,

Residual Fuel Oil and Kerosene 2005

Kerosene Fuel Oil and Kerosene Sales 2005 Report, Table 18: Adjusted Sales of Kerosene by Energy Use Coal EIA Annual Coal Report 2005, Table 26 U.S. Coal Consumption by End Use Sect or, by Census Division and State 2005, 2004 (Thousand Short Tons)

Upon obtaining county commercia l/institutional fuel consumption estimates for the various fuel types in all Michigan counties Cf, emission estimates were obtained by applying an emission factor that is specific to that fuel type. These emission factors were obtained from various EPA publications.

Michigan Commercial/Institutional Fuel Emission Factors

Commercial/Institutional Fuel Type Units CO NH 3 

### Nox PM 10 

### - PRI PM 25 

### - PRI SO 2 

### VOC

Natural gas Lbs/million

cubic feet 84 0.49 100 7.6 7.6 0.6 5.5

Residual fuel oil Lbs/1,000 gal 5 0.80 55 9.07 3.37 194.05 1.13

Distillate fuel oil Lbs/1,000 gal 5 0.80 20 2.38 2.13 53.96 0.34

Kerosene Lbs/1,000 gal 5 0.80 18 2.38 2.13 41.1 0.713

Coal Lbs/ton 6 0.000565 7. 5 6.0 2.2 36.86 0.05

Sources of Emission Factors:

1. LADCO state uniform adopted emission fa ctors for commercial/institutional natural gas combustion.Page 14 

### 2. U.S. Environmental Protecti on Agency. FIRES database.

3. U.S. Environmental Protection Agency. Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Po int and Area Sources, 5th Edition and Supplements (AP-42).

4. U.S. Environmental Protecti on Agency. Final Report on Development and

Selection of Ammonia Emission Factors.

The resulting emission estimates were r eported by individual fuel type using the following SCC codes:

Michigan Commercial/Institutiona l Combustion Emission SCC Codes

Fuel Type SCC Natural gas 2103006000

Residual fuel oil 2103005000

Distillate fuel oil 2103004000

Kerosene 2103011005

Coal 2103002000

Industrial Boilers and Furnaces

Estimation of fuel combustion emissions of industrial boilers and furnaces was performed in similar manner as the commercial/in stitutional sector. Statewide industrial fuel consumption information was obtained fr om the U.S. Departm ent of Energy, EIA publications. Point source deductions were made for each fuel type to obtain the area contribution that was then apportioned to t he county level using LADCO prescribed procedures.

County fuel consumption estimates of natural gas, residual fuel oil, distillate fuel oil, kerosene, and coal were based upon the following mathematical equation:

Cf = Ce/Se x Sf

Cf = Estimated county industrial sect or consumption of a given fuel type Ce = Total county employment in the industrial sector Se = Statewide employment in industrial sector

Sf = Statewide industrial sector c onsumption of a given fuel typePage 15 

### Michigan Industrial Fuel C onsumption Information Sources

Industrial Fuel Type U.S. Dept of Energy, EIA Data Sources

Natural gas Natural Gas Annual 2005, Michigan Table 48

Residual fuel oil Fuel Oil and Ke rosene Sales 2005 Report, Table 17: Adjusted Sales of Residual Oil by Energy Use, 2004 and

2005

Distillate fuel oil Fuel Oil and Ke rosene Sales 2005 Report, Table 21: Adjusted Sales for Industrial Use: Distillate Fuel Oil, Residual Fuel Oil, and Keros ene (#1, #2, and #4 fuel oils – excludes diesel oil)

Kerosene Fuel Oil and Kerosene Sales 2005 Report, Table 18: Adjusted Sales of Kerosene by Energy Use Coal EIA Annual Coal Report 2005, Table 26: U.S. Coal Consumption by End Use Sector, by Census Division and State 2005, 2004 (Thousand Short Tons)

County employment data was obtained from the U.S. Departm ent of Commerce, Bureau of Census publication entitled County Business Patterns, Michigan: 2003 (CBP/03-24 issued September, 2005) . Upon obtaining county industrial fuel consumption estimates for the various fuel types in all Michigan counties Cf, emission estimates were obtained by applying an emission fact or that is specific to that fuel type. These emission factors were generally based on the LADCO adopted emissions

factors.

Michigan Industrial Fuel Emission Factors

Industrial Fuel Type Units CO NH 3 

### NOx PM 10 

### - PRI PM 25 

### - PRI SO 2 

### VOC

Natural

gas Lbs/million

cubic feet 84 3.2 100 7.6 7.6 0.6 5.5

Residual

fuel oil Lbs/1,000 gal 5.0 0.8 55 7.17 4.67 157 0.28

Distillate

fuel oil Lbs/1,000 gal 5.0 0.8 20 2.3 1.55 53.96 0.2

Kerosene Lbs/1,000 gal 5.0 0.8 18 2.38 2.13 41.1 0.713

Coal Lbs/ton 6 0.00057 7.5 6.0 2.2 38 0.05Page 16 

### Sources of Emission Factors:

1. LADCO state uniform adopted emission factors for industrial natural gas, residual fuel oil, distillate fuel oil, and coal combustion.

2. U.S. Environmental Protec tion Agency. FIRES database.

3. U.S. Environmental Protection Agency. Compilation of Air Pollutant Emission Factors, Volume 1: Stat ionary Point and Area Sources, 5th Edition and Supplements (AP-42).

4. U.S. Environmental Prot ection Agency. Final Report on Development and

Selection of Ammonia Emission Factors.

Emission estimates were reported using the following SCC codes:

Michigan Industrial Combustion Emission SCC Codes

Industrial Fuel Type SCC

Natural gas 2102006000

Residual fuel oil 2102005000

Distillate fuel oil 2102004000

Kerosene 2102011000

Coal 2102002000

Remedial Action, Site Clean Up & Leaking Storage Tanks

Evaporative VOC emissions occur during remediation and cleanup at sites of

environmental contamination. Such remediat ion activities may include air stripping or sparging of a VOC from contam inated groundwater or incinera tion of a spoil material

removed from a contaminated site. In some instances carbon adsorption may be required to reduce VOC emitted during air stripping or spraying operations.

Estimation of VOC loss from remedial acti on activities was determined by summing the allowable emissions from permi ts to those parties that we re engaged in such activities as provided by the MDEQ, Air Quality Divis ion (AQD), Permit Section. Although site remediation activities are subject to NESH APs, these requirements did not apply at the time of the year 2005 emissions inventory. Emissions were reported using an SCC of

2660000000.

Municipal Waste Landfills

A municipal solid waste landfill is defined as any facility that is regulated under

Subtitle D of the Resource Conservation and Recovery Act (RCRA) that receives primarily household and/or commercial wastes.Page 17 

### VOCs are produced from municipal solid wast e by: the volatiliz ation of the waste material itself, the microbiological (anaerobi c) putrefaction of organic waste materials that result in the formation of organic acid s and alcohols that are vaporized, and the

chemical reaction of one or more wast e materials or chemical decomposition

intermediate. The rate at which VOCs ar e emitted from a landfill is dependent upon the structural design of cells, the waste com position (physical/chem ical properties), the

moisture content of the wast e, the amount of waste dispos ed, temperature, age of the landfill, the chemical reactivity of the waste, the microbiologic al toxicity of the waste, and the effectiveness of landfill gas collection syst ems. Where landfill gas is collected for use in boilers, internal com bustion engines (reciprocating and turbines) or flared at the landfill site, there are additional air po llutants such as NOx, particulates (PM 2.5 

### and

PM 10 

### ), and carbon monoxide pr oduced from incomplete combustion.

Estimation of VOC emissions from munici pal landfills were based on the revised technical procedures presented in the EPA publication entitled: Volume III, Chapter 15 of the Emission Inventory Improvement Pr ogram January 2001 Revised Final Guidance

for Landfills . In this publication, the preferred method for the estimation of area source

emissions is to use the LandGem model or the equations from the Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources, 5th Edition and Supplements (AP-42) section on landfills. LandGem is a computer-based model that uses the same equations as that of AP-42. The emissions calculation for the estimation of landfill gas requires site specific information including: landfill design capacity, accumulated waste totals from oper ation of the landfill, and existing control requirements from landfill gas collection system s. Landfills may be subject to either new source performance standards ( 40 Code of Federal Regulations Part 60 Subpart

WWW ) or emission guidelines ( 40 Code of Federal Regulations, Part 60, Subpart Cc ). Landfills are now also subject to NESHAPs that became effective on January 16, 2003. For those landfills that were not being repor ted in the point sour ce inventory, area emission estimates were reported on the basis on LandGem model simulations using the SCC of 2620030000. These simulations reflected total waste receipts under the prior year 1999 inventory with addition made for waste receipts for years 2000-2005 as obtained from annual reports by the MDEQ, Waste and Hazardous Division Report of Solid Waste Landfilled in Michigan . For those landfills that operated landfill gas collection/combustion systems, emission estima tes considered Tables 2.4-3 and 2.4-5 of AP-42 with adjustments considered for a l andfill gas methane collection efficiency of 75% of LandGem model predicted methane generation at a given landfill site.

Non-Methane Organic Compound Control Efficiencies for Landfill Gas

Combustion from AP-42

Combustion Control

Device Typical Control Efficiency (%)

Boilers 98

Flares 99.2

Gas Turbines 94.4 IC Engine 97.2Page 18 

### Emission Rates for Secondary Compoun ds from Landfill Gas Combustion (Based upon lbs/ Million Cubic F eet of Landfill Gas Combusted)

Combustion Control

Device NOx PM 2.5 

### - PRI PM 10 

### - PRI CO

Flare 40 17 17 750 IC Engine 250 48 48 470

Boiler 33 8.2 8.2 5.7

Gas Turbines 87 22 22 230

Open Burning: Municipal Solid Waste

For the category of open burning of municipa l solid waste (MSW), EPA’s methodology from Appendix A of Documentation for the Final 2002 N onpoint Sector (Feb 06 Version) National Emission Inventory for Crit eria and Hazardous Air Pollutants was followed. The ratio of urban to rural population was obt ained from 2000 U.S. C ensus data, per the EPA’s method, then multiplied by a 2005 U.S. Census Bureau estimate of the county population in Michigan to obtain an estimate of rural population in 2005. Per capita emission factors were used, after first excluding those counties where the population was greater than 80% urban unde r EPA’s presumption that open burning of MSW would

not occur there.

Outdoor Wood Boilers

The Wisconsin methodology distributed by Ba rt Sponseller was followed. Per that methodology, the MARAMA emission factor of 13.82 g/kg wood burned was used.

An estimate of 11.68 cords/yr/unit in Mich igan was obtained from Br ian Brady, AQD. Brian serves as the AQD’s outdoor wood boiler expert.

Michigan estimated an average weighted densit y of 1.65 tons/cord of wood, based on

information contained within Table 8 of the USDA survey report Residential Fuelwood Consumption and Producti on in Michigan, 1992

.

Per the Wisconsin methodology, it was assum ed that 90% of outdoor wood boilers are

used in rural areas and 10% are used in urban areas. To determine which counties were urban and which were rural, staff review ed the list of counties, which are part of Michigan’s Consolidated Statistical Areas (metropolitan areas) and determined that the

22 affected counties should be considered as urban. Ten percent of the 29,568 Michigan outdoor wood boilers were apportioned to the urban counties by population. The remaining 90% of the outdoor wood boi lers were apportioned to the 61 rural counties by population.

2005 Residential Wood BurningPage 19 

### Michigan utilized the EIIP methodology’s alte rnative method for estimating emissions from residential wood burning, by apportioning data from the U.S. Census Bureau and

the EIA.

Two options were available to estimate wood burning households per county.

• Housing Units with Wood Heat by C ounty was determined by using 1990 U.S. Census Data, Database C90STF3C1, Summa ry Level State, for House Heating Fuel for Occupied Housing Units ( http://venus.census.gov/cdrom/lookup ). Although this data is for the 1990 year, it did provide a value for each county.

• Housing Units with Wood Heat by C ounty was determined by using the U.S. Census Bureau’s DP-4, Profile of Select ed Housing Characteristics: 2000, Data Set: Census 2000 Summary File 3 (SF 3) for Michigan. This file provided a total value of households using wood heating. However, no breakdown was given by county.

The AQD staff used the 2000 nu mber of total wood burni ng households in Michigan, and used the 1990 county proportions of the 1990 total to apportion the 2000 value to the county level.

Then based on county value for number of w ood burning households, the value for state wood use in cords was apportioned to each county. The 2003 state wood use in cords

data came from the US MAP States Page, Table 8, Residential Energy Consumption Estimates, Selected Years 1960-2003, Michigan , from the U.S. Department of Energy,

EIA:

http://www.eia.doe.go v/emeu/states/sep

_ use/res/use_res_mi.html

Data for 2005 was not available at t he time the 2005 inventory was developed.

Once county wood use in cords was produced , the next step was to determine the wood weight in tons for each count y. Wood weight was determi ned by estimating a weighted average wood weight of 1.65 tons per cord , from species and c onsumption data from Table 8 of the USDA report, “Residentia l Fuelwood Consumpti on and Production in Michigan, 1992.”

Michigan did not have data available on t he number of catalytic and non-catalytic woodstoves in Michigan, but did utilize 1993 survey data which showed the proportions of fireplaces to woodstoves by county in Michigan. This was used to apportion wood weight per county between wo od stoves and fireplaces. SCCs and emission factors were selected for fireplaces – cordwood (2104008001), and woodstoves – general (2104008010).

No ozone season activity was estimated, as staf f felt it was unlikely that residents would utilize their fireplaces or wood stoves between June 1 and August 31 of each year.Page 20 

### FIRE 6.23 and Source Summary Database (SSD) list the fo llowing Area Mobile Source Codes (AMS):

A2104008000: Total wood stoves and fireplaces A2104008001: (lb/ton dry wood burned): Fireplaces - general A2104008010: (mg/Mg dry wood burned): Wood stoves - general A2104008030: (lb/ton dr y wood burned): Catalytic wood stoves - general A2104008050: (lb/ton dry wood burned): Non-catalytic wood stoves - general A2104008051: (lb/ton dr y wood burned): Non-catalytic wood stoves -

conventional A2104008052: (lb/ton dry w ood burned): Non-catalytic wood stoves - low emitting A2104008053: (lb/ton dry w ood burned): Non-catalytic wood stoves - pellet fired

Michigan selected AMS codes A2104008001 and A2104008010. These were the most appropriate codes, as data exis ts for the proportion of woodstoves to fireplaces per county in Michigan, but data was not availa ble on numbers of catalytic or non-catalytic

wood stoves. Emission factors for A2104008010 were converted from mg/Mg to lb/ton by multiplying by the conver sion factor of 2.00E-06.

References:

1. EPA, Factor Information Retrieval System Version 6.23 , U.S. Environmental Protection Agency, 2000.

2. EPA, STAPPA, ALAPCO, Emission Inventory Improvement Program (EIIP) , Volume III, July 1997, Chapter 2.

2008 Residential Wood Combustion

Michigan utilized the EPA’s Residential Wood Combustion tool (RWC_2008_Toolv4.1)

to estimate emissions from Residential Wood Combustion for the 2008 emissions inventory. The residentia l wood combustion tool was modified to address a few deficiencies with Michigan Counties. D ouble-counting of emissions for SCCs 2104008400, 21048510, and 210400861 0 was resolved, and the allocation of appliances for SCC 2104008610 Hydr onic heater: outdoor was revised using an inverse population density methodology.

Structure Fires

The EIIP guidance from EIIP Volume III, Chapter 18: Structure Fires , was followed. The preferred method for estimating emissions wa s used, due to the availability of county

level structure fire data for 2002. More recent data was not available; the fire statistics data, which was originally kept by the Mich igan State Police Fire Marshall Division, is now kept by the Michigan Department of Labor and Economic Growth. DLEG staff were unable to locate more recent county le vel data on structure fires. The 2002 dataPage 21 

### was re-used from the 2002 area source submittal. However, it did not provide any detail

on the extent of each structur e fire, or indicate if the structure was residential or

commercial.

The default fuel loading factor provided in the EIIP guidance (1. 15 tons of fuel per structure fire) was used. Emission factor s for VOC, CO, and NOx were obtained from

Table 18.4-1.

Year 2018 and 2022 Stationary Area S ource Emission Inventory Projections :

Area sources represent those emission sources that do not report to MAERS. Future year projections take into considerat ion the corresponding BT U heat input from residential, commercial/instit utional, and unaccounted industr ial sources. Residential projections considered SEMCOG forecast of expected number of households within the 7-county area. Similarly, regional economic employm ent forecast from SEMCOG projections was used to derive the non-manufac turing sector employment growth for the 7-county area. For unaccounted industrial sources, growth rates were assumed to be similar as Non-EGU source projections.Page 22 

## 5. Non-Road Mobile Sources

Non-Road Emissions Estimation Exclusi ve of Locomotive, Shipping, and Aircraft

Emissions

Non-road equipment populati on and emission estimates for 2005, 2008, 2018, and 2022

were obtained from the EPA NONROAD2008a model to simulate winter weekday and annual PM2.5, SO2, and NOx emissions. The updated model and technical support

documentation can be obtained from: http://www.epa.gov/otaq/nonrdmdl.htm . Fuel property information utilized in LADCO regional emission simulations we re from Grant Hetherington of the State of Wisconsin

and from EPA NONROAD2008 model documentation.

2005 and 2008 Aircraft Emissions Estimation

To estimate aircraft emissions, aircraft ac tivity was obtained for Michigan airports. Historically this information was obtained from MDOT. However, MDOT was unable to provide updated information for year 2005. In the absence of updated MDOT 2005 aircraft activity data, commercial aircra ft and commercial air freight departure information by aircraft model type was obtai ned from Federal Aviation Administration (FAA) airport records. For determining airport LTO cycles, the Air Traffic Activity Data System (ATADS) air traffic count database of larger towered airports, Terminal Area Forecast (TAF) air traffic operations databas e of towered and non-towered airports, and G.C.R. & Associates airport activity data we re used. Since ATADS provides aircraft operations for a limited number of the states’ airports, TAF aircraft operations estimates

were considered where ATADS information was unavailable. G.C.R. & Associates, Inc.

consultant data was used for the smaller ai rports of which FAA aircraft operations information was unavailable. The following in formation from the res pective sources was considered in the development of emission estimates:

1. Commercial scheduled and non-scheduled ai rcraft air carrier activity and commercial air freight activity by aircraft model types;

2. General aviation and air taxi annual local and itinerant operations for year 2005;

3. Military annual local and itinerant operations for year 2005. Due to need to have aircraft operations informa tion expressed as LTO cycles, the following assumptions were made:

a. For commercial aircraft and commer cial air freight activity, the number of annual aircraft annual LTO cycles was assumed to be equal to the number of departures. The daily LTO cycle frequency was then obtained by dividing the yearly LTO cycles by 365.Page 23 

### b. For general aircraft annual local and itinerant airport operations, each respective operations total wa s divided by two to obtain the corresponding year local and itinerant LTO cycles. The expected daily local and itinerant LTO cycles then were obtained by dividing these annual totals by 365.

c. For military annual local and itin erant operations, each respective operations total was divided by two to obtain the corresponding year local and itinerant LTO cycl es. The expected military daily local and itinerant LTO cycles then were obtained by dividing these annual totals by 365.

Airport LTO cycles were further categoriz ed into commercial aircraft by plane and engine type, general aviation itinerant aircraft of unknown aircraft type, general aviation local aircraft of unknown aircraft type, and milita ry aircraft. This was necessary to utilize the U.S. Department of Transportation, FAA Emissions and Dispersion Modeling System 4.5 (EDMS). A descr iption of this model can be found in the FAA publication entitled, Emissions and Dispersion Modelin g System (EDMS) User Manual (September 2004). Commercial and air freight aircraft emission factors per LTO cycle were determined using EDMS 4.5 for each comme rcial aircraft type models where possible were used at each towered airport. Def ault commercial aircraft engine type, and EPA default time in mode values for takeoff, appr oach, and landing roll times were used in

the EDMS 4.5 model simulations.

For those aircraft types that could not be determined using the EDMS 4.5 emissions model, aircraft emission factors based on EPA alternative fleet average procedures

were then used to estimate their emissi ons. These included general aviation and air

taxi itinerant aircraft of unk nown aircraft type, general avia tion local aircraft of unknown aircraft type, and military aircraft. Conver sion from total hydrocarbons to VOC was performed and based on the EPA guidance.

Aircraft emissions were then obtained by adding emissions contributions from commercial, itinerant general, and local gene ral aircraft, and were reported using the following SCC codes:

Michigan Aircraft Emission SCC Codes

Aircraft Type SCC Military 2275001000

Commercial 2275020000

General Aviation 2275050000Page 24 

### 2005 Locomotive and Shippi ng Emissions Estimation

The 2005 non-road shipping and locomotive em issions were prepared using the same techniques used for the 2002 emissions. These estimates are based on work and a follow-up report (Environ Report for LADCO, 2002 Shipping Emissions Sources, April 2004) completed by Environ to support LADCO’s efforts to prepare a 2002 Air Emissions Inventory. The report describes Environ effo rts to develop a shipping 2002 air emissions estimates to support air quality modeling. The Enviro n report is too long to be included in this document, but it can be provided upon request or downloaded at:

http://ladco.org/reports/rpo/MWRPOprojects/Emissions/Environ_Final_Report_nonroad.pdf

The estimate of 2005 locomotive and shippi ng emissions was made by LADCO in the same manner as the 2002 inventory descri bed above. The 2005 estimates are part of LADCO’s Base M inventory.

2008 Locomotive, Shipping, and Ai rcraft Emissions Estimation

The 2008 emissions are based on work and a follow-up report (E.H. Pechan & Associates, Inc., Development of Growth and Control Factors for Lake Michigan Air

Directors Consortium , Final Report, December 14, 2004) done by E.H. Pechan & Associates, Inc. (Pechan). This work suppo rts LADCO’s efforts to forecast anthropogenic emissions for the purpose of assessing progress for air quality goals, including goals related to regional haze and attain ment of the ozone NA AQS. The Pechan growth factors were used to estimate the LA DCO Base M future year emissions posted by LADCO in 2007. The future year emissi ons represent both emission controls that already exist and those that are known to be on the way.

Non-road Mobile Source Emission Inven tory Projections to 2018 and 2022

The non-road source categories exclusive of locomotive, shipping, and aircraft were grown in the EPA Mobile source model NMIM. The locomotive, shipping, and aircraft non-NMIM source categories we re grown using growth factors provided in the report, Development of Growth and Control Fa ctors for Lake Michigan Air Directors Consortium, Final Report, December 14, 2004

, prepared by Pechan for LADCO and available upon request.

See Growing Stationary Non-EG U Point, Stationary Area, Locomotive, Shipping, and Aircraft Categories for the Years 2018 and 2022 in the Non-EGU Point Sources

section for references and methodology for proj ecting the Locomotive, Shipping and Aircraft emissions inventory.Page 25 

## 6. On-road Mobile Sources

Please refer to the On-road Mobile Sour ce Emissions Inventory for Southeast Michigan – PM 2.5 

### Redesignation Request, January 27, 2011, prepared by SEMCOG, and contained in Appendix C.

# Appendix C

On-Road Mobile Source Emissions Inventory for Southeast Michigan

PM 2.5 

# Redesignation Request

# On

‐ Road Mobile Source Emissions Inventory for

Southeast Michigan

PM2.5 Redesignation Request

January 27, 2011

Prepared by the

Southeast Michigan Council of Governments (SEMCOG)

535 Griswold, Suite 300 Detroit, MI 48226

(313) 961

‐ 4266ii 

# Table of Contents

I. Emissions Inventory Summary ............................................................................1

II. On-Road Mobile Emissi ons Inventory Development .........................................1

A. Local Travel Data Inputs ............................................................................2

1. Demograp hic Data ....................................................................................

2. SEMCOG’s Travel Demand Forecasting M odel (TDFM) .......................... 3. Mapping of TDFM Functi onal Classes and Area Ty pes............................ To MOVES R oad Types ...........................................................................

4. Vehicle Miles of Travel (VMT)................................................................... 5. Hourly VM T Fracti ons ............................................................................... 6. Road Type Distribut ion ............................................................................. 7. Average Speed Distribut ions..................................................................... 8. Ramp Fractions.........................................................................................

9. Vehicle Population .................................................................................... 10. Vehicle Age Distribut ion............................................................................

B. Other Local Data Inputs

...............................................................................

List of Tables

Table 1 Annual and 24-Hour PM2. 5 On-Road Emissions Inventory

for Southeast Michi gan ................................................................................1 Table 2 Mapping of TDFM Functional Class and Area Type to

MOVES Road Type......................................................................................4

Table 3 VMT Distribution Factor s by HPMS V ehicle Ty pes ......................................5 Table 4 Road Type Distri bution Used in MOVES......................................................6

Table 5 Urban and Rural Ramp Frac tions.................................................................7 Table 6 Mapping between MOVES Vehicle Types and Michigan DOS Body Style ...........................................................................................8 Table 7 Mapping between HPMS Vehicle Types and Michigan DOS Body Style ...........................................................................................9 Table 8 Monthly Average Min/Max Temperatures for PM2. 5..................................10

Table 9 Barometric Pressu re Data used in MO VES................................................10

Table 10 Revised RVP and Ethanol Market Shares Used in MOVES.......................111 

## On-Road Mobile Source Emissions Inventory for Southeast Michigan PM2.5 Redesignation Request

I. Emissions Inventory Summary

Below are the annual and daily on-road mobile so urce emission inventorie s for fine particulate
(PM2.5), nitrogen oxide (NOx) and sulfur dioxide (SO2). The da ily inventory reflects average
winter weekday conditions because the highest PM2.5 concentrations generally occur during the

winter season.

Table 1: Annual and 24-Hour PM2.5 On-Road Emi ssions Inventories for Southeast Michigan

Annual Inventory Average Winter Weekday Inventory

Year Vehicle Population Vehicle

Miles of

Travel (millions) PM2.5 (tons) NOx (tons) SO2 (tons) Vehicle

Miles of

Travel (millions) PM2.5 (tons) NOx (tons) SO2 (tons)

2005 3,660,074 44,187 5,323 154,294 3,809 126.1 19.2 460.8 8.6

2008 3,647,666 44,156 4,360 119,194 1,066 125.6 15.7 365.3 3.1

2018 3,667,667 44,279 1,633 37,847 310 126.3 6.6 117.8 0.9

2022 3,687,940 44,523 1,311 28,044 294 127.0 5.6 88.1 0.8

2035 3,795,289 45,819 1,123 21,791 283 130.7 4.9 69.2 0.8



### II. On-Road Mobile Emissi ons Inventory Development

The PM2.5 on-road emissions inventories were developed using the U.S. EPA’s new Motor

Vehicle Emission Simulator (MOVES) model. Th e analysis used version MOVES2010a, which
was released in August 2010. MOVES is EPA’s su ccessor to the Mobile6 model. However, in
addition to generating mobile emission rates, M OVES also has the capability to calculate onroad mobile emissions inventories, thus eliminat ing the need for most of the post-processing that
was necessary with Mobile6.

To prepare a regional emissions inventory, the userhas the choice of modeling each county
separately or combining counties to form a cu stom domain. SEMCOG has chosen the latter
option for two reasons. First and foremost, staff believe that traffic c ount and vehicle population
data used in the emissions modeling process ar e more robust at the regional level and more
accurately reflect the travel patterns in the region, which are not confined within county
boundaries. For example, the age distribution of ve hicles registered with in a specific county may
not reflect the age distribution of vehicles traveling on that co unty’s roads because of the high
amount of inter-county travel in the region. The second reason fo r choosing the custom domain
option is that it saves a significant amount of time. A single MOVES run, whether by county or
custom domain, takes approxima tely one hour. Thus, a typical conformity analysis which2 

### requires two separate runs for each of four require d analysis years, would take 56 hours if run at
the county level but only 8 hour s using the custom domain.

MOVES includes default data for many of its nece ssary data inputs. However, wherever possible
SEMCOG has incorporated local data in order to develop the most accurate emissions inventory
for Southeast Michigan. These lo cal data inputs are described be low. To ease the transition from
Mobile6 to MOVES, EPA has provided a number of “conversion tools” that allow users to
convert local data inputs used in Mobile6 to the MOVES input format. SEMCOG has taken
advantage of several of these tools. Their use is noted under the appropriate sections below.

A. Local Travel Data Inputs

1. Demographic Data

Travel forecasts used to develop the on-ro ad mobile source emissions inventory were
based on demographic data from SEMC OG’s 2035 Regional Development Forecast
(RDF), which was adopted in early 2008. A thre e-step process was used to develop this

forecast.

1) Regional forecast totals of population, house holds and jobs were generated from
the REMI (Regional Economic Models, Inc.) model which forecasts Southeast
Michigan’s ability to attract and retain population and j obs relative to all other
parts of the United States. Regional totals are developed in five-year intervals
from the 2005 base year to 2035;

2) The regional totals were then used to develop a small-area forecast that
disaggregates regional populat ion, households and jobs in to five-acre grid cells
using the UrbanSim model. UrbanSim is a computer simulation model for
planning and analysis of urban developm ent. It incorporates the interaction
between land use, transportation, and public policy. In doing so, it puts future
population and jobs into the most desirabl e grid cells and models residential and
nonresidential developments as demand arises.

3) Grid cells from the small-area forecast were aggregated to traffic analysis zones
(TAZs) for use in SEMCOG’s travel forecasting model.

As noted above, SEMCOG’s RDF provides forecas ts in five-year increments from 2005
to 2035. The 2008, 2018 and 2022 demographic forecasts used to develop the PM2.5
emissions inventories were interpolated using the two closest five-year forecasts for each
of these years (i.e. 2008 was interpolated using the 2005 and 2010 RDF forecasts).3 

### It should also be noted that the 2035 RDF was developed prior to the severe economic

downturn in late 2008. The 2040 RDF, which is currently under development and will be
completed in March 2012, will likely forecast significantly lower population and
employment for the region.

2. SEMCOG’s Travel Demand Forecasting Model (TDFM)

Vehicle miles of travel (VMT) forecasts for the on-road emissions inventory were
developed using version E5 of SEMCOG’s Travel Demand Forecasting Model (TDFM),
which was implemented in 2009. The TDFM r uns on the TransCAD software platform
and utilizes the standard four-step travel modeling process: trip generation, trip

distribution, mode choice, a nd traffic assignment. Detailed documentation on the model
is contained in a separate SEMCOG doc ument that is available upon request.

3. Mapping of Travel Demand Model (TDFM) F unctional Classes and Area Types to
MOVES Road Types

In order to use TDFM travel data in MOVE S, the road types used in SEMCOG’s model

must be reconciled with those used in MOVE S. The MOVES model uses four basic road
types for on-road activities: Urban Restricte d, Urban Unrestricted, Rural Restricted and

Rural Unrestricted. The term restricted refers to restricted or limited access roadways. In
the SEMCOG region, this includes all freeway facilities. All othe r roadways in the
SEMCOG region are considered unrestricted f acilities. The TDFM also includes several
special functional classes thatare not part of the regular roadway network (e.g. walk
only, external zone connectors, transit-only links). These ar e not included in SEMCOG’s
emissions modeling.

As TDFM functional classes do not distingu ish between urban and rural facilities,
another TDFM variable, Area Type, was used as a surrogate. The TDFM defines four
area types (urban business, urban, suburban a nd rural) and assigns one to each roadway
link based on the density of households, population and employment in the traffic
analysis zone in which the link resides.

Table 2 shows how each area type and functi onal class in SEMCOG’s TDFM is mapped
to the four road types used in MOVES.4 

### Table 2: Mapping of TDFM Functional Cla ss and Area Type to MOVES Road Type

SEMCOG TDFM Area Type SEMCOG TDFM

Functional Class Urban

Business Urban Suburban Rural

1 - Interstate Freeway

2 - Other Freeway

8 - Ramp

11 - Freeway Connector 4 – MOVES Urban Restricted Road Type 2 – MOVES Rural Restricted Road Type

4 - Principal Arterial

5 - Minor Arterial

6 - Collector

7 - Local

12 - Gravel Road

99 - Centroid connector (local road surrogate) 5 – MOVES Urban Unrestricted Road Type 3 – MOVES Rural Unrestricted Road Type

81-94 Transit Use Only

90 - External

96 - Walk Only Non-road or outside region. Not used in MOVES



### 4. Vehicle Miles of Travel (VMT)

MOVES requires the user to input annual VMT by the six FHWA Highway Performance
Monitoring System (HPMS) vehicle types:

1) Motorcycle

2) Passenger car

3) Other 4-tire, 2-axle vehicles

4) Bus

5) Single unit truck

6) Combination truck

However, local VMT data used in the MOVE S model is derived from SEMCOG’s Travel
Demand Forecast Model, which generates av erage weekday VMT forecasts and does not
currently have the capability to allocate this VMT to different vehicle types. Thus, some
adjustments were required to convert the TDFM data into the format required for
MOVES. These adjustments are described below.5 

### a. HPMS Normalization
In accordance with EPA and FHWA guidance, SEMCOG TDFM VMT was
normalized to HPMS VMT by county and ro ad type. Normalization factors were
developed by dividing 2009 HPMS VMT by 2009 TDFM VMT. The resulting factors
were then applied to TDFM VMT in all analysis years.

b. Distribution of VMT Amon g HPMS Vehicle Types
A two-step process was used to devel op this distribution. First, SEMCOG’s 2006

screen line traffic count da tabase was used to devel op VMT distribution factors
among the six HPMS vehicle classes. This database includes 779 tr affic classification
counts collected throughout the seven-county SEMCOG region. When collected, the
counts were classified by FH WA’s standard 13 traffic bins. These bins were then
aggregated to the six HPMS classifications.

The second step in the process involved adjus ting for a recognized bias in the traffic

count data toward undercounti ng the proportion of light truc ks, SUVs, and vans. This
bias was first recognized in 2004 when loca l count data was compared to both vehicle
registration records and Mobile6 national defa ult data. The bias is likely due to the
inability of traffic counting equipment to co rrectly distinguishing these vehicles from
cars, causing them to be classified under the HPMS system as “passenger cars” rather

than “other 4-tire, 2-axle vehicles”. To corre ct for this bias, the count data from these

two classifications were combined and then redistributed based on the MOVES
default distribution. Both the original a nd adjusted factors are shown in Table 3.

Table 3: VMT Distribution Fa ctors by HPMS Vehicle Types

HPMS Vehicle Type Before Step 2 Adjustment After Step 2 Adjustment*

1 Motorcycle 0.011567 0.011567

2 Passenger Car 0.713678 0.534530

3 Other 4-tire, 2-axle vehicles 0.186204 0.365352

4 Bus 0.008705 0.008705

5 Single-Unit Truck 0.039116 0.039116

6 Combination Truck 0.040730 0.040730

* MOVES default split between vehicle types 2 & 3: 59.4% vs. 40.6%



### c. Conversion of Average Weekday VMT to Annual VMT
Monthly and weekend day adjustment fact ors were developed using 2004-2006 data
from the 150+ permanent traffic recording (PTR) stations in Southeast Michigan.
These adjustment factors, along with the HPMS-normalized weekday VMT by
vehicle type were then entered into EPA’s aadvmtcalculator_hpms.xls converter tool
to compute the annual VMT and monthly and daily VMT fractions needed for

MOVES.6 

### 5. Hourly VMT Fractions

Two different data sources were used to develop hourly VMT fractions for MOVES:

1) 2006 screen line traffic counts collecte d by SEMCOG - All screen line counts

include classification data but we re only collected on weekdays.

2) 2005 PTR counts for locations within th e SEMCOG region - This data includes
both weekdays and weekends but all of the count stations are on freeways and
only a limited number of these stat ions collect classification data.

Using this data, SEMCOG was able to deve lop weekday hourly VMT fractions for each
of the four MOVES road types and six HPMS vehicle types. However, for weekends, the
count data was not robust enough to develop separate factors by road type or vehicle type
so only a single set of hourly VMT factors was developed for all the road types and
vehicle types.

6. Road Type Distribution

SEMCOG 2006 screen line counts were used to develop the Road Type Distribution for
each HPMS vehicle type. Because these counts were not evenly distributed among the
four MOVES road types, the count data wa s first expanded to reflect the system-wide
VMT distribution by road type from the TD FM. Table 4 shows the final distribution

factors used in MOVES runs for PM2.5 re-d esignation request. The same distributions
were used for all analysis years.

Table 4: Road Type Distribution Used in MOVES

MOVES Road Type

HPMS Vehicle Type Rural

Restricted Rural

Unrestricted Urban

Restricted Urban

Unrestricted



### Motorcycle 0.082102 0.080699 0.348661 0.488538



### Passenger Car 0.051566 0.092906 0.290307 0.565221



### Other 4-tire, 2-axle vehicles 0.054670 0.154881 0.258523 0.531927

Bus 0.115776 0.082206 0.365080 0.436938

Single-Unit Truck 0.080163 0.127845 0.355673 0.436318

Combination Truck 0.171595 0.066330 0.447998 0.314077



### 7. Average Speed Distributions

MOVES uses the distribution of vehicle hours traveled (VHT) by average speed to
determine an appropriate operating mode dist ribution. To develop the local average speed

distribution for Southeast Michigan, SEMCOG used congested speed and VHT output7 

### from the TDFM to compute the VHT fr action in each MOVES speed bin. MOVES
requires the user to input hourly speed distributions by road type and vehicle class. While
SEMCOG’s travel model does not provide hourly speed data, it does calculate speeds by
four different time periods:

1) AM peak, simulating the hours of 7:00 - 9:00 a.m.;

2) PM peak, simulating the hours of 3:00 - 6:00 p.m.;

3) Mid-day, simulating the hours of 9:00 a.m. - 3:00 p.m.;

4) Off-peak, simulating the hours of 6:00 p.m. - 7:00 a.m.

For MOVES, a separate speed distributions wa s developed for each of these time periods
and applied to all hours within that period. This was done as follows:

• For each time period, the directional c ongested speed of each roadway link was
assigned to one of MOVES 13 speed bins;

• The associated directional VHT on the links was then aggregated by speed bin
and MOVES road type;

• Then, for each road type, the VHT fraction in each speed bin was computed.

As no local data is currently available on sp eed differentiation betw een vehicle classes,
the same distributions were ap plied to all vehicle types.

Note: Ramp data was not included in the deve lopment of the above speed distributions as

it was assumed that MOVES makes an intern al adjustment for ramps using the usersupplied ramp fractions.

8. Ramp Fractions

Ramp fractions used in MOVES were deri ved from SEMCOG’s Trav el Demand Forecast
Model. Table 4 shows the TDFM ramp fractions for each of the years modeled in
SEMCOG’s long-range transportation plan. Whil e the fractions show little variation over
time, there is a significant difference betw een urban and rural areas. Thus, SEMCOG
decided to use separate ramp fractions for ur ban and rural areas in MOVES. Rather than
select the fraction associated with any one TDFM forecast year, the average of all six
years was chosen. The specific fractions used in MOVES are shown in the far right

column of Table 5.

Table 5: Urban and Rural Ramp Fractions

TDFM Forecast Year Area Type 2005 2010 2015 2020 2025 2030 2035 MOVES 2-Rural Ramp 0.0412 0.0408 0.0397 0.0398 0.0398 0.0395 0.0393 0.04 4-Urban Ramp 0.0795 0.0807 0.0814 0.0812 0.0809 0.0837 0.0843 0.088 

### 9. Vehicle Population

Year 2010 vehicle registration data from the Michigan Department of State (DOS) was
used to develop the base year vehicle population inputs for MOVES. This data was
supplemented with vehicle title data to capture information on public sector fleet vehicles
(e.g. those owned and operated by cities, counties, universities, etc.) that do not appear in
the registration database. The body style and plat e type fields in th e DOS database were
used to determine the MOVES source type of each vehicle. Table 6 shows how each
DOS body style and plate type was mapped to the MOVES source types. Where DOS
data did not provide sufficien t detail, the data was supplemented with information from
other sources including local transit agen cies, the National Transit Database, and
MOVES default distributions for Southeast Michigan counties.

Table 6. Mapping between MOVES Vehicle Types and Michigan DOS Body Style

MOVES Vehicle Type Michigan DOS Body Style 11 – Motorcycle Motorcycle 21 – Passenger Car 2-door; 4-door; Convertible 31 – Passenger Truck Station Wa gon; Non-Commercial Pick-up/Van 32 – Light Commercial Truc k Ambulance; Hearse; Panel; Commercial Pick-up/Van
41 – Intercity Bus

42 – Transit Bus

43 – School Bus Bus
(Apportioned this data between MOVES M41 and M43 vehicle types using split factors from MOVES 2010 default run; data for M42- transit buses was added using local fleet data from local transit providers)



### 51 – Refuse Truck 52 – Single-unit Short-haul

Truck 53 – Single–unit Long-haul

Truck Dump Truck; Mixer; utility; Wrecker; Stake; Tank
(Apportioned this data MOVES M51, M52 and M53 vehicle types using split factors from MOVES 2010 default run.)



### 54 – Motor Home Motor Home

61 – Combination Short-haul

Truck 62 – Combination Long-haul

Truck Tractor
(Apportioned this data between MOVES M61 and M62 vehicle types using split factors from MOVES 2010 default run)



### To generate future year vehicle population data, it was assumed that this population
would grow at the same rate as forecasted vehicle miles of travel from the TDFM. The
rate of growth between 2010 and each future an alysis year was calculated. This rate was
then uniformly applied to all 2010 vehicle popul ation source types to generate the future
year population.

Detailed documentation on th e development of SEMCOG’s vehicle population data is
contained in a separate SEMCOG mobile emissions model development memo.9 

### 10. Vehicle Age Distribution

Year 2010 DOS vehicle registration and title data were also used to develop the
vehicle/source type age distri bution used in MOVES. The DOS body style field was used
to assign each vehicle to one of six HPMS vehicle types (see Table 7 below). Once
HPMS vehicle types had been assigned, th e data was aggregated by model year and
assigned to the appropriate age categor y. Model years 2010 and 2011 were considered
age 0, 2009 was considered age 1 and so on. Model years 1980 and older were grouped
into the age 30+ category. The age distribut ion for each HPMS vehicle type was then
computed. The same distributions ar e used for all analysis years.

Table 7: Mapping between HPMS Vehicle Types and Michigan DOS Body Styles

HPMS Vehicle Type Michigan DOS Body Style

Motorcycle Motorcycle

Passenger Car 2-door; 4-door; Convertible

Other 4-tire, 2-axle vehicles Station Wagon; Non-Commercial Pick-up/Van;
Ambulance; Hearse; Panel;

Bus Bus

Single-unit Short Truck Dump Truck; Mixer; Utility; Wrecker; Stake; Tank ,

Motor Home

Combination Truck Tractor

B. Other Local Data Inputs

1. Temperature and Humidity Data

Temperature and humidity data are require d inputs for MOVES. For the PM2.5 on-road
mobile emissions inventories, local temper ature profiles were developed for each month
of the year. To generate these profil es, the average minimum and maximum daily
temperatures for each month in Southeast Michigan were computed using 2007-2009

National Weather Service (NWS) local clim atological data reports. This data was
provided by the Michigan Department of Environmental Quality (MDEQ). EPA’s
MeteorologicalDataConverter_Mobile6.xls tool was then used to convert the average
minimum and maximum temperatures to th e required hourly temperature inputs for
MOVES. Table 8 shows the average min/max te mperatures that were used to develop
each month’s hourly profile.10 

### Table 8: Monthly Average Mi n/Max Temperatures for PM2.5

Month Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Min 18.4 17.2 28.6 39.5 48.7 60.0 61.4 62.9 56.6 44.1 34.3 22.7

Max 32.2 31.5 46.2 60.0 70.2 79.8 81.2 81.8 76.1 62.4 48.6 34.8



### SEMCOG’s emissions analysis used MOVE S default humidity data for Southeast
Michigan as no other local data was available.

2. Barometric Pressure

The barometric pressure used for Southeas t Michigan was the average of the MOVES
default values for SEMCOG’s seven counties. Table 9 below shows each county’s
default value and the resulting average used for the emissions inventory.

Table 9: Barometric Pressure Data used in MOVES

SEMCOG County MOVES Default

Barometric Pressure (inches of Mercury, inHg) 26093 - Livingston 29.113

26099 - Macomb 29.144

26115 - Monroe 29.173

26125 - Oakland 29.146

26147 - St. Clair 29.172

26161 - Washtenaw 29.095 26163 - Wayne 29.069 Average 29.130



### 3. Fuel Supply/Fuel Formulation

In transitioning its mobile emissions m odeling from Mobile6 to MOVES, SEMCOG
reviewed both the Fuel Supply and Fuel Form ulation default values contained in MOVES
for counties in Southeast Michigan (Len awee, Livingston, Macomb, Monroe, Oakland,
St. Clair, Washtenaw and Wayne counties). Only 2005 and later years were reviewed.
Earlier years will be reviewed in future if there is a need to model them.

Several adjustments were made to accurately reflect observed ethanol market share data
from the Michigan Department of Agricultu re as well as State regulation on permitted
oxygenates and maximum allowable summer time Reid vapor pressure (RVP) in
Southeast Michigan. These adjustments are documented below.

• Corrected the 2012 summertime gasolin e RVP for all SEMCOG Counties to
reflect the State’s legal limit fo r Southeast Michigan (7.0 psi).11 

### • Zeroed out any market share for gasoline with MTBE or TAME since neither has
been used in Michigan since 2003.

• Adjusted the ethanol market share fo r all SEMCOG counties to match observed
data from the Michigan De partment of Agriculture’s Consumer Protection
Section Annual Reports for years 2005-2009.

• Set the ethanol market share for all SE MCOG counties to 100% in years 2010 and

later. This was the observed share in 2009 a nd is expected to continue in future
due to federal requirements for increased use of biofuels.

The resulting RVP and ethanol market shar e values used in MOVES after the above

corrections are shown in Table 10 below.

Table 10: Revised RVP and Ethanol Market Shares used in MOVES

Year Summer RVP

(months 5-9) Ethanol

Market Share

(all months)

2005 7.8 psi 39.5% 2006 7.8 psi 58.4% 2007 7.0 psi 80.3% 2008 7.0 psi 98.9% 2009 7.0 psi 100.0% 2010 and later 7.0 psi 100.0%

.

# Appendix D

Stationary Source Facility Detail

### 2 Purpose of this Appendix The information in this appendix was collected for the purpose of supplementing inventory data found in Section 5 of the main document. The data in this appendix was collected from company permits, Air Quality Division (AQD) field reports, special studies, and discussions with companies that are in the general vicinity of the Dearborn air monitor, which has the highest PM 2.5 values in Southeast Michigan. Figure 1 shows the

location of emission sources around the Dearborn monitor. These sources will be discussed below. These sources include both large and smaller facilities. Most are still operating but some are closed.

Figure 1. Map of Emission Sour ces Near the Dearborn Monitor

Dearborn Monitor

### 3 List of Sources

SRN Source SRN Source

A6902 Darling International Inc B3533 Edw C Levy Co Plant 1

A7809 US Steel Great Lakes Works B3567 St Mary's Cement

A8196 M-Lok Riley Plating – OOB* B4752 Great Lakes Petroleum Terminal – OOB*

A8640 Severstal North America B5162 Xcel Steel Pickling (formerly Castle Steel)

A8648 Ford Motor Co. - Rouge Complex B5558 Honeywell – OOB*

A9196 Fabricon Products Inc B7071 Automotive Components Holding

A9831 Marathon-Ashland Oil Refinery B9080 Envirosolids, LLC

B2103 Detroit Water and Sewerage Department K1636 City of Dearborn

B2169 Carmeuse Lime, Inc. (River Rouge Facility) M3066 Spartan Industrial – OOB*

B2247 Buckeye Terminals LLC (Detroit Terminal) M4685 Detroit Salt

B2798 Detroit Edison Co. - Delray M4798 Ferrous Environmental – OOB*

B2810 Detroit Edison Co. - River Rouge M4848 Ford Motor Allen Park Clay Mine – OOB*

B2926 Sunoco Partners M & T, L.P. (River Rouge Terminal) N0226 Hinkle MFG LLC

B2956 Ford Motor New Model Program N1014 Magni Industries Inc

B3195 Cadillac Asphalt Products N6 631 Dearborn Industrial Generation

B3518 United States Gypsum Company N77 23 DTE Energy / Ford World Headquarters

* OOB means “Out of Business.”

The purpose of this source-by-source review is to better understand the types of facilities that may be impacting the PM 2.5 levels in the vicinity of the Dearborn monitor and activities at the facilities that may have contributed to emission changes over a period of years. Various parameters were acquired, including emissions information, operating schedules, distance and direction from the Dearborn monitor, stack heights, and product throughput.

An example of additional information that can be helpful in understanding emissions impacting the Dearborn area can be seen by co mparing emissions inventories for 2005 to 2008 (see Tables 5 and 6 in the main document), NO X and SO 2 emissions from electric generating unit (EGU) and non-EGU point sources in the 7-county nonattainment area increase between 2005 and 2008 for the annual inventory. However, this may not reflect the changes that are occurring at sources that are in the more immediate vicinity of the Dearborn monitor. Some of these facilities may have reduced their emissions which may have a positive impact on PM 2.5 levels in the area, which is not obvious by the 7-county emissions data. In general, since local sources have a bigger impact on the nearby Dearborn monitor than more distant sources, they deserve to be analyzed in greater detail.

It should be noted that attempts were made to obtain detailed information for other sources as well. Sources throughout the 7-county nonattainment area were screened to determine permanent and enforceable reductions made between 2005 and 2008. However, emissions inventories and permits to install (PTI) do not give clear indications of what controls are installed or when controls are installed. Therefore, it made the most sense to focus limited resources on analyzing sources near the Dearborn monitor.

### 4 Other Consideration - Emission Inventory Challenges of PM2.5

Using emission inventories for PM 2.5 and precursors is the primary metric required to demonstrate the reason for an area moving from nonattainment to attainment. This is detailed in Section 5 of the main document. The use of inventories brings some inherent issues described here and is the reason for considering other metrics of information in making a robust demonstration, as has been done in Section 6 of the main document and in this appendix. The Michigan Air Emissions Reporting System (MAERS) emissions inventory from 1998-2008 was eval uated. Emissions inventory trends are very difficult to interpret since the data is always changing. Companies may report emission units (reporting group or individual uni ts), source classification codes (SCCs), etc. differently from year to year. In additi on, emission factors that are used to calculate the emissions are frequently changed by the Environmental Protection Agency (EPA) as

better data becomes available. If no emission factor is available, the company does not have to report emissions for that pollut ant. The company may also use different methods for calculating emissions from year to year, including federal emission factory stack testing and continuous emission monitoring (CEM).

In the case of particulate matter (PM), major changes have occurred over the last ten years. In 1998, only PM-primary and PM 10 -primary were reported. In 1999, a few companies voluntarily started reporting PM 2.5 -primary. In 2002 PM-primary was no longer reported, only PM 10 -primary and PM 2.5 -primary. In 2004, PM 10 -filterable and

PM 2.5 -filterable started to be reported, thus, PM 10 -primary, PM 10 -filterable, PM 2.5 -primary

and PM 2.5 -filterable are reported for each SCC. Each emissions unit may have more than one SCC and may report emissions for PM 10 and/or PM 2.5 that are either filterable or primary.

Other Metrics Used

Emissions of primary PM 2.5 are obviously important when assessing a nearby facility’s potential impacts on the monitor. Emissions of PM 2.5 precursors, SO 2 and NO X , are also important to understand. Depending on the facility distance to the monitor, these precursors may have time to react to form PM 2.5 in the form of sulfates and nitrates. Stack heights are important because they affect dispersion of the pollutants. Tall stacks produce pollutant plumes that may not impact a nearby ground level monitor, but can influence a monitor at some distance away. Short stacks tend to have the opposite effect, impacting nearby sources.

Process throughput (or production) usually is a more consistent measure of what is happening at an industrial process than reported emissions when looking at trends. The emissions are often calculated based on throughput, but emission factors may change over time as described previously. However, throughput will not indicate decreases in emissions if control equipment is added.

The location of a facility relative to the Dearborn monitor is important. Wind, in the area are predominantly from the south and southwest, so sources located in this upwind direction from the monitor will have a much larger impact than sources in other directions. The proximity of a source to the monitor also can determine the level of impact the source may have. A facility’s operating schedule can be informative, particularly if the facility has seasonal changes. For the daily PM 2.5 standard, high PM 2.5 levels occur more often in winter months, so a company’s operating schedule could

### 5 suggest higher or lower impacts to the Dearborn monitor during the more critical winter

months.

Determining emission trends from a nearby facili ty is important in judging how the facility may have impacted PM 2.5 levels in the area over the 2005 – 2008 time period, which represents the change from not meeting the PM 2.5 standard to meeting the standard at the Dearborn monitor. However, throughput may provide an even clearer picture of a facility’s impact in cases where emission data may be less reliable as described in the previous paragraphs. Reporting of throughput by a facility is usually a much more stable metric than emissions, and companies generally keep good records of throughput. Throughput trends therefore are also used to help understand changes in potential emission impacts from facilities near the Dearborn monitor. It should be noted that throughput does not account for controls that may be added to a process at a facility, resulting in lower emissions from the year the controls were added into the future. Aside from this, increases and decreases in throughput can be expected to result in increases

and decreases in emissions.

In the following facility studies, emission trends are compared to throughput trends to help show reliability of emissions informati on. Also, years when the two metrics diverge can show that additional controls may have been added.

Ultimately, these evaluations of facilities may provide insight into whether emissions reductions can be expected to be permanent or are fluctuations in throughput. One requirement of the redesignation state implementation plan (SIP) is to show that emission reductions that led to the area meeting the standard are permanent and enforceable, as described in Section 5 of the main document. These facility studies may provide some clues as to the source of reductions when this information is not readily available and whether reductions are per manent. The trends themselves also can provide insight on expectations for future emissions and impacts on the ambient air in the vicinity of the Dearborn monitor.

FACILITY DETAILS

Severstal Severstal North America, Inc. operates an integrated steel mill at the Rouge Industrial Complex in Dearborn, Michigan. The Rouge Industrial Complex is located at 3001 Miller Road in Dearborn, Michigan (Wayne County). The complex is bounded by Rotunda Drive on the north, Miller Road on the east, Dix Avenue and Rouge River on the south, and Schaefer Road on the west. The area is mainly industrial, and the nearest residence is approximately 1500 ft east of Mille r Road. This mill is less than one mile southeast of the Dearborn air monitoring station (Dearborn monitor).

Severstal operations cover approximately 500 acres, occupying the southern half of the Rouge complex. Operations include three blast furnaces (BFA, BFB, BFC) with only BFB currently operational, a waste oxides reclamation facility, a basic oxygen furnace (BOF) shop, two continuous casters, a hot strip mill, and cold mill operations. The plant produces sheet steel that is used in a variety of manufacturing applications. Ford Motor Company operates the remainder of the complex. Severstal North America, Inc. is independent of the Ford Motor Company and is an autonomous producer of steel.

### 6 The steel mill runs year around, 24 hours per day, seven days per week. The stack emission heights are generally over 150 ft for the major emissions units. The annealing furnaces have shorter stacks at 64 feet. A few minor emission sources have baghouse stacks ranging from 27 to 51 feet. Severstal may also have some areas of fugitive

emissions that are not as well documented.

A review of the company’s emission inventory data from 1998 through 2008 indicates that the facility’s operations have decr eased since approximately 2005. The BOF and the blast furnaces with their stoves are the major sources of emissions and throughput at

Severstal.

Comparing emissions trends to throughput trends indicates that they generally match, but there is an occasional year that diverges (see Figure 2 through 4). Emission factors used to calculate emissions for a process can be determined by the company, and they are occasionally revised. For example, Severstal used AP-42 factors for their blast furnace cast house operations in 1998, but in 1999-2007, they used stack test data from another steel mill. In 2008, they ran their own stack tests and are now using those values. Severstal has done additional on-site stack tests and will be using those results for future emissions reports. Thus throughput may more accurately represent emissions to ambient air over several year s, unless controls are added.

Figure 2. BOF Emissions to Throughput Comparison at Severstal

BOF-NOx

0 50 100 150 200 250

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008emissions (tons)

0 500,000 1,000,000 1,500,000 2,000,000 2,500,000 3,000,000 3,500,000Thruput (tons)

Nox Thruput (tons) BOF- SO2

- 0.05 0.10 0.15 0.20 0.25

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008emissions (tons)

0 500,000 1,000,000 1,500,000 2,000,000 2,500,000 3,000,000 3,500,000thruput (tons)

SO2 Thruput (tons)

BOF-PM

0 50 100 150 200 250

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008emissions (tons)

0 500,000 1,000,000 1,500,000 2,000,000 2,500,000 3,000,000 3,500,000thruput (tons)

PM2.5 (tons) PM10 (tons) Thruput (tons)

### 7 Figure 3. Blast Furnace Emissions to Throughput Comparisons at Severstal

Blast Furnaces - NOx

- 5.00 10.00 15.00 20.00 25.00 30.00

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007* 2008*emissions (tons)

0 200000 400000 600000 800000 1000000 1200000 1400000 1600000 1800000thruput (tons)

NOX-BFC NOX-BFB Thruput-BFB Thruput-BFC Blast Furnaces - SO2

0 5 10 15 20 25 30 35 40 45 50

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007* 2008*emissions (tons)

0 200,000 400,000 600,000 800,000 1,000,000 1,200,000 1,400,000 1,600,000 1,800,000thruput (tons)

SO2-BFB SO2-BFC Thruput-BFB Thruput-BFC 438 2,409

1,344

Blast Furnace B - PM

0 5 10 15 20 25

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008emissions (tons)

0 200,000 400,000 600,000 800,000 1,000,000 1,200,000thruput (tons)

pm10 PM2.5 Thruput-BFB Blast Furnace C - PM

0 5 10 15 20 25 30 35 40

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007* 2008*emissions (tons)

0 200,000 400,000 600,000 800,000 1,000,000 1,200,000 1,400,000 1,600,000 1,800,000thruput (tons)

PM2.5 PM10 Thruput-BFC

Figure 4. Blast Furnace Stove Emissions to Throughput Comparisons at Severstal

BF Stoves - NOx

0 50 100 150 200 250 300 350

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008emissions (tons)

0 5000 10000 15000 20000 25000 30000thruput (e6ft3)

Nox-BFB NOX-BFC BFB Stove Gas BFC Stove Gas BF Stoves - SO2

- 20.00 40.00 60.00 80.00 100.00 120.00

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008emissions (tons)

0 5000 10000 15000 20000 25000 30000thruput (E6ft3)

SO2-BFB SO2-BFC BFB Stove Gas BFC Stove Gas

Stove BFB - PM

0 10 20 30 40 50 60 70

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008emissions (tons)

0 2000 4000 6000 8000 10000 12000 14000 16000 18000thruput (E6ft3)

PM10-pri (tons) PM2.5 pri (tons) BFB Stove Gas Stove BFC - PM

0 20 40 60 80 100 120

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008emissions (tons)

0 5000 10000 15000 20000 25000 30000thruput (E6ft3)

PM2.5-pri PM10-pri BFC Stove Gas

### 8 A different comparison can be made with throughput compared to ambient PM 2.5 . For Severstal, this comparison does show some correlation. In 2007, baghouse controls for the BOF and blast furnace C were added. In January 2008, blast furnace B was severely damaged; requiring shut down and has not been repaired. The company indicated that when the blast furnace B does start up again, it will be controlled by a baghouse. In 2008 throughput began to increase for the BOF and Blast Furnace C, but

ambient PM 2.5 decreased. This decrease in ambient PM 2.5 may be due to the blast furnace B shut down, as well as the impact of the new controls (see Figure 57).

Figure 5. BOF Throughput to Ambient PM 2.5 Concentrations at the

Dearborn Monitor

BOF

0 500,000 1,000,000 1,500,000 2,000,000 2,500,000 3,000,000 3,500,000

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008Thruput (tons)

0 5 10 15 20 25concentration (ug/m3)

BOF material thruput (tons) PM2.5 (ug/m3)

### 9 Figure 6. Blast Furnace Throughput to Ambient PM 2.5 Concentrations at

the Dearborn Monitor

Blast Furnace Thruput

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

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008thruput (tons)

0 5 10 15 20 25concentration (ug/m3)

B Blast Furnace Cast House (tons) C Blast Furnace Cast House (tons) PM2.5 (ug/m3)

Figure 7. Blast Furnace Stoves Throughput to Ambient PM 2.5 Concentrations at the Dearborn Monitor

BF Stoves Gas Thruput

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

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008Thruput (E6ft3)

0 5 10 15 20 25Concentration (ug/m3)

Stoves BFB Gas (E6ft3) Stoves BFC Gas (E6ft3) PM2.5 (ug/m3)

Severstal, being a major emissions source located very near and directly upwind of the Dearborn monitor, is considered to directly impact PM 2.5 levels at the monitor. With the recent (2007) installation of additional PM controls to the steel mill, ambient PM 2.5 showed attainment for PM 2.5 NAAQS for the first time at the Dearborn monitor. A major reason can be explained by additional Severstal controls, and this source is a likely candidate for contingency measures if additional controls are needed in the Dearborn

area.

### 10 US Steel United States Steel, Great Lakes Works operates an integrated steel mill that has been in operation since August 1930. It is located just south of the city of Detroit. The site consists of approximately 1100 acres that span along the Detroit River through the cities of Ecorse and River Rouge. The facility includes the Main Plant Area, the 80-inch Hot Strip Mill, and the iron making and coke-making operations on Zug Island. The plant produces flat-rolled steel products for the automotive, appliance, container, service center, and piping and tubing industries. It should be noted that the coke-making operations have been sold to another company.

The primary iron producing facility is located on Zug Island, in the city of River Rouge. Zug Island is bordered by the Rouge River on the north, south, and west sides and the Detroit River on the east side. The Zug Island facility includes three operating blast furnaces, one coke oven, coke by-product recovery plant, and three boiler houses. The facility site is zoned heavy industrial. The nearest residential area is approximately 0.6 miles from the facility. This portion of the facility is located 2.5 miles southeast of the

Dearborn monitor.

The 80-inch Hot Strip Mill facility is located in the city of River Rouge between the Zug Island and Main Plant facility location. The 80-inch Hot Strip Mill facility includes the hot strip finishing and shipping building, scale pit, coil storage and shipping building, slab yard, and 80-inch hot strip mill. The facility site is zoned heavy industrial. The nearest residential area is approximately 1.5 miles from the facility.

The Main Plant Area is located on a 682-acre site located in the city of Ecorse. It is bordered by the Detroit River on the east, by the 80-inch Hot Mill Strip facility on the north, by the E.W. Levy Plant No. 5 on the south and Jefferson Avenue to the west. The following steel-making operations are located at the Main Plant: No. 2 Basic Oxygen Process (#2 BOP), Vacuum Degasser, Ladle Metallurgical Facility (LMF), Pickle Line, Electrogalvanizing Line, No. 4 tandem cold mill, Annealing Furnace, and Boiler House. The plant site is zoned heavy industrial. The nearest residential area is approximately 0.5 mile from the facility.

US Steel has several large emitting sources, and in some cases, the emissions do not follow throughput (see Figures 8 through 14). In particular, some units’ emissions in 2004 and 2005 do not follow throughput (see Figure 8 through 12). Information is not available to explain these changes. Also, emission factors used are not reported for several years in the AQD MAERS program, so the reason for changes are difficult to

track.

### 11 Figure 8. 80” Strip mill emissions to throughput comparison at US Steel.

80" Mill - Nox & SO2

0 500 1000 1500 2000 2500

19

98 1999 20 00

20

0 1 2

0 02 20 0 3

2004 20 05

20

0 6
2

0 07 20 0 8Emissions (tons)

0 1000 2000 3000 4000 5000 6000 7000 8000 9000 10000Thruput (Million FT3)

Nox SO2 Thruput 80" Mill - PM

0 5 10 15 20 25 30

1998 1999 2000 20 01 200 2 2003 2004
2 005 2006 2007 2008Emissions (tons)

0 2000 4000 6000 8000 10000Thruput (Million FT3)

PM10 Thruput

Figure 9. Blast furnaces B and D emissions to throughput comparison at US Steel.

Blast Furance B

0 50 100 150 200 250 300 350

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 0 5000 10000 15000 20000 25000 30000

Nox SO2 PM10 Thruput Blast Furnace D

0 50 100 150 200 250 300 350 400

19

98

1999 2000 2001 2002 2003 2004
2 005

2006 2007 2008Emissions (tons)

0 5000 10000 15000 20000 25000 30000 35000 40000Thruput (E6FT3)

Nox SO2 PM10 Thruput

Figure 10. Coke oven emissions to throughput comparison at US Steel.

Coke Oven - SO2 & NOx

0 500 1000 1500 2000 2500

1998 1999 2000 20012002 20032004 20052006 20072008 1050000 1100000 1150000 1200000 1250000 1300000 1350000 1400000Thruput (tons)

Nox SO2 Thruput Coke Oven - PM

0 50 100 150 200 250 300 350 400 450 500

1998 1999 2000 20012002 2003 2004 20052006 20072008 1050000 1100000 1150000 1200000 1250000 1300000 1350000 1400000

PM 10 PM 25 Thruput

### 12 Figure 11. Coke oven gas flare emissions to throughput comparison at US Steel.

Coke Oven Gas Flares - SO2

0.00 200.00 400.00 600.00 800.00 1,000.00 1,200.00 1,400.00 1,600.00

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 0 500 1000 1500 2000 2500 3000 3500 4000 4500

SO2 Thruput Coke Oven Gas Flares - Nox & PM

0 20 40 60 80 100 120 140 160 180

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 0 500 1000 1500 2000 2500 3000 3500 4000 4500

Nox PM10 Thruput

Figure 12. BOF emissions to throughput comparison at US Steel.

BOF - Nox, PM, &SO2

0 100 200 300 400 500 600 700 800 900

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 0 500000 1000000 1500000 2000000 2500000 3000000 3500000 4000000

Nox SO2 PM10 PM2.5 Thruput

Figure 13. Zug Island boiler house #1 emissions to throughput comparison at US Steel.

Zug Island Boiler House #1 -Nox & SO2

0 200 400 600 800 1000 1200 1400

1998 1999 2000 2001 2002 2003 2004 20052006 20072008 0 5000 10000 15000 20000 25000 30000 35000

Nox SO2 Thruput Zug Island Boiler House #1 - PM

0 5 10 15 20 25 30 35 40

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 0 5000 10000 15000 20000 25000 30000 35000

PM10 PM2.5 Thruput

### 13 Figure 14. Zug Island boiler house #2 emissions to throughput comparison at US Steel.

Zug Island Boiler House #2 - SO2 & NOx

0 200 400 600 800 1000 1200 1400 1600

1998 1999 2000 2001 2002 2003 2004 20052006 20072008 0 5000 10000 15000 20000 25000 30000 35000 40000 45000

Nox SO2 Thruput Zug Island Boiler House #2 - PM

0 10 20 30 40 50 60

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 0 5000 10000 15000 20000 25000 30000 35000 40000 45000

PM 10 PM 2.5 Thruput

Since throughput does not follow emissions very well, another comparison was made. Throughput was compared to ambient PM 2.5 at the Dearborn monitor and at the Southwest High School (SWHS) monitor, since US Steel is much closer and upwind of the SWHS monitor. This comparison shows some correlation for some emission units, but not for others (see Figure 15).

It should be noted that while US Steel is a large emissions source, it may have less impact on the Dearborn monitor than other large sources in the area, since it is

downwind of the monitor.

Figure 15. Throughput to Ambient PM 2.5 Concentrations at the Dearborn and SWHS

Monitors.

Thruput to Ambient PM2.5

0 5000 10000 15000 20000 25000 30000 35000 40000 45000

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008Thruput (million Ft3)

0 5 10 15 20 25Ambient PM2.5 (ug/m3)

BFB BFD Zug Boiler #1

Zug Boiler #2 Dearborn PM2.5 SWHS PM2.5 Thruput to Ambient PM2.5

0 1000 2000 3000 4000 5000 6000 7000 8000 9000 10000

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008Thruput (Milion FT3)

0 5 10 15 20 25Ambient PM2.5 (ug/m3)

80"Mill Coke Oven Flares Dearborn PM2.5 SWHS PM2.5

Thruput to Ambient PM2.5

0 500000 1000000 1500000 2000000 2500000 3000000 3500000 4000000

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008Thruput (tons)

0 5 10 15 20 25Ambient PM2.5 (ug/m3)

Coke oven BOF Dearborn PM2.5 SWHS PM2.5

### 14 Marathon-Ashland Petroleum LLC Marathon Ashland Petroleum LLC. – Detroit Refinery and Detroit Light Products Terminal are located at 1300 Fort Street and 12700 Toronto Street in the southwest part of the city of Detroit. The facilities are sited between Interstate Highway I-75, Fort Street, Oakwood Avenue and Dix Avenue and the Rouge River. The nearest residential area is approximately 100 feet west of Stocker Avenue near the Rouge River Terminal. Marathon is located two miles south of the Dearborn monitor. The refinery operates 24 hours per day, seven days per week and 52 weeks per year.

Marathon Ashland Petroleum LLC refinery processes approximately 72,000 barrels per day of crude oil, which is refined into a product mix of liquefied petroleum gases, gasoline, fuel oil, asphalt, and other products. The makeup of this production will vary depending on the type of crude used as charge stocks. The finished products leave the facility via truck, lake tanker, railroad car, or pipeline.

The refinery is organized into five complexes for operations and maintenance purposes. Complex I has the Crude and Vacuum Units. Complex II consists of the Unifiner, Alkylation, and Sulfur Recovery units. Complex III includes the Fluid Catalytic Cracking Unit (FCCU) and other Light Ends Units. Complex IV includes the Catalytic Reformers, Hydrotreaters, and Boilers; and Complex V contains the Storage and Blending Facilities, as well as the Marine Loading Facilities. The refinery operations are controlled by a Distributed Control Computer System.

Crude oil is the raw material the refinery utilizes to create finished products such as fuels and asphalt. The refinery is staged such that processing alters the physical and chemical state of the crude oil, which in turn, produces marketable products. Both sweet and sour crude oils are processed at the Detroit refinery. Sour crude contains a higher content of sulfur components than sweet crude. All crude oil is pipelined into the refinery. Other raw material may be brought into the refinery by pipeline or is transported in trucks including iso-butane, n-butane, toluene, xylene, ethanol, gas oil and catalysts.

Reviewing the company’s emission inventory and throughput data from 1998 through 2008 indicated that the facility’s operations had actually increased for the years 2006 through 2008; i.e., the same time period as the decreased emissions shown on the Dearborn monitor. Marathon reported source emissions using the emissions factors within MAERs. The material and fossil fuel throughput amounts for the largest units at this location, the FCCU, Zurn Boiler and B&W Boiler were used to determine whether significant changes in operations had occurred. See Figure 16 through Figure 19. The graphs begin in the year 2003 and go through 2008. Prior to 2003 the operations at the facility were intermittent. Emissions for PM 2.5 were not reported, and back calculations of the emissions using the most current emission factor did not show anything significant.

The Detroit Heavy Oil Upgrade project (DHO UP) air permit (most recent permitting activity) has specific emi ssion limits for the FCCU, Zurn Boiler and B&W Boiler, which are federally enforceable. In addition, the refinery purchased 80 tons of PM 10 emission credits for offsetting purposes during the permitting for the DHOUP project. Per the facility and district staff contact, the credits were never used and were retired from use.

### 15 The offsets were purchased from Central Wayne Recovery and Carmeuse Lime. Central Wayne Recovery was located in Inkster MI, near Dearborn. The facility ceased all operations in the fall of 2003. Therefore the reductions are permanent.

Carmeuse Lime (formerly known as Detroit Lime) was located on Dix Road in Detroit near Dearborn. The facility ceased all operations in Fall 2002. Therefore the reductions
are permanent.

Zurn Boiler The Zurn Boiler’s normal operations are year-round 24 hours a day. The exhaust stack for this unit is 150 feet high with an inside diameter of 72 inches. This unit is centrally located within the facility boundaries. The facility originally proposed removal of the Zurn boiler (at 210 mmbtu/hr) and replacing it with a new boiler (rated at 300 mmbtu/hr). However, the facility determined that the extra steam generating capacity was not necessary and kept the Zurn boiler in operation. The Zurn boiler has the capacity to burn refinery fuel gas, but only uses natural gas at this time. The Zurn boiler has federally enforceable permitted emission limits for NOx, CO, VOC, PM and PM 10 . The Zurn boiler also has a material throughput limit of 210,000 cubic feet per hour of fuel burned. The Zurn Boiler has a federally enforceable permit limit requiring installation and maintenance of multi-staged low-NOx burners. Figure 16 shows a comparison of

emissions to ambient PM 2.5 at the Dearborn monitor.

Figure 16. Zurn Boiler Emissions to Ambient PM 2.5 at Dearborn Monitor



### Emissions to ambient PM2.5 for Zurn Boiler

0.0 1,000.0 2,000.0 3,000.0 4,000.0 5,000.0 6,000.0

199 8 199 9 2000 2001 2002 200 3 2004 2005 2006 200 7 200 8Emissions (lbs)

0 5 10 15 20 25PM2.5 (ug/m3)

so2 pm2.5 * ambient PM2.5

*PM 2.5 emissions calculated based on throughput.

FCCU The FCCU’s normal operations are year-round, 24 hours a day. The exhaust stack for this unit is 195 feet high with an inside diameter of 72 inches. This unit is centrally located within the facility boundaries. Per the company contact, the FCCU has had major control projects installed to help reduce PM from the unit. In December 2004, the refinery installed Electrostatic Precipitators on the exhaust portion of this stream to reduce PM below the federal limits. After they began using higher sulfur crude (tar sands?) they experienced an increase of PM rates in 2008. In late 2008, the facility

### 16 installed an ammonia injection system to condition the gas plume on the unit to keep PM at conservative levels below the company’s allowable limits. Overall the facility estimates that the ammonia injection system installation reduced NOx emission by 20 percent. Per the facility, they have reduced criteria pollutant emissions by 75 percent through the installation of state of the art technologies (see Figure 17 and Figure 18).

Figure 17. Emissions to Throughput Comparison for the FCCU at Marathon

FCCU

0.0 100,000.0 200,000.0 300,000.0 400,000.0 500,000.0 600,000.0 700,000.0 800,000.0 900,000.0 1,000,000.0

19981999200020012002200320042005200620072008LBS

0.0 2,000.0 4,000.0 6,000.0 8,000.0 10,000.0 12,000.0bbls nox

thruput FCCU

0.0 200,000.0 400,000.0 600,000.0 800,000.0 1,000,000.0 1,200,000.0 1,400,000.0

19981999200020012002200320042005200620072008LBS

0.0 2,000.0 4,000.0 6,000.0 8,000.0 10,000.0 12,000.0bbls so2

thruput

Figure 18. FCC Emissions to Ambient PM 2.5 at Dearborn Monitor



### Emissions to ambient PM2.5 for FCCU

0.0 200,000.0 400,000.0 600,000.0 800,000.0 1,000,000.0 1,200,000.0 1,400,000.0

199 8

199 9

2000 200 1

200 2

2003 200 4

2005 2006 200 7

2008Emissions (lbs)

0 5 10 15 20 25PM2.5 (ug/m3)

nox so2 ambient PM2.5

B&W Boiler The B&W Boiler’s normal operations are yea r-round, 24 hours a day. The exhaust stack for this unit is 150 feet high with an inside diameter of 80 inches. However, this unit is centrally located within the facility boundaries. The B&W boiler has federally enforceable permitted emission limits for NOx, CO, VOC, PM and PM 10 . In addition, the

unit has a SO 2 federally enforceable permit limit. The B&W boiler also has a federally enforceable material throughput limit of 300,000 cubic feet per hour of fuel burned. The boiler has a low NOx burner and flue gas reci rculation control system. The B&W boiler burns natural and process gases (see Figure 19).

### 17 Figure 19. B&W Boiler Emissions for Marathon to Ambient PM 2.5 at Dearborn Monitor



### Emissions to Ambient PM2.5 for B&W Boiler

0 1,000 2,000 3,000 4,000 5,000 6,000 7,000 8,000 9,000

2003 2004 2005 2006 2007 2008Emissions (lbs)

0.00 5.00 10.00 15.00 20.00 25.00PM2.5 (ug/m3)

so2 pm2.5 * ambient PM2.5

*PM 2.5 emissions calculated based on throughput.

Ford Motor Company - Rouge Complex The Ford Motor Company Dearborn Assembly Plant is located on Miller Road in the city of Dearborn, part of the Rouge Industrial Complex. The facility is bounded by Rotunda Drive to the north, by Interstate 94 on the northwest, Schaefer Avenue to the west, the Rouge River to the south and Miller Road to the east. It is located less than one mile

west of the Dearborn monitor.

The Ford Dearborn Rouge Complex consists of four individual manufacturing plants that produce automobile and automobile components, as follows: an assembly plant that produces and paints vehicles, an engine and fuel tank manufacturing plant that produces automobile engines and metal fuel tanks, a stamping plant that stamps vehicle body panels and similar body parts for other vehicles, and a diversified manufacturing plant

that electrocoats and manufactures vehicle frames.

Ford operations at the Rouge complex have not experienced the economic downslide as have other Ford facilities. Series F-150 trucks are built in the complex and production levels have been relatively stable. See Figure 20 for production information for the four plants. Ford ceased foundry operations around 1981 in the closing of the Specialty Foundry. The steel-making operations located in the complex are currently owned by

Severstal.

### 18 Figure 20: Productions for the Ford Rouge Complex.

### 19 Several emissions were combined under the RG-Paint reporting group, which has natural gas usage reported. RG-Paint reports the total natural gas combustion for the Dearborn Truck Plant paint shop building. The natural gas usage includes the paint shop space heating, booth air supply houses, hot water boilers, coating curing ovens and air emission abatement equipment (thermal oxidizers and carbon adsorption systems). In addition, the EU-NATGASSPACE emission unit includes all the natural gas used for space heating at the Dearborn Truck Plant outside of the paint shop (i.e., bodyand final assembly buildings). Several other EUs report natural gas usage as well. EUHEATERSFRAME includes the natural gas used for space heating the Dearborn Diversified Manufacturing Plant (DDMP, form ally known as the Dearborn Frame Plant).EU-ECOATFRAME includes the natural gas used in the DDMP Ecoat curing oven. EUHEATERSENGINE includes the natural gas used for space heating the Dearborn Engine and Fuel Tank Plant.

The old Dearborn Assembly Plant ceased operations in May 2004. A portion of the building was demolished in 2004/2005. The remaining building was decommissioned and put into a cold idle status (natural gas line was blanked) after the heating season in 2005. Although there may have been other efficiency improvements, it appears the shutdown of the old Dearborn Assembly Plant was a significant portion of the decrease in natural gas usage (see Figure 21).

### 20 Figure 21: Ford Rouge Complex natural gas usage.

NOx emissions are generated from the combustion of natural gas (space heaters, air houses, ovens, thermal oxidizers) located at the Dearborn Truck Plant (paint and assembly), from natural gas combusti on (space heaters and ovens) at the other manufacturing facilities and also from the gasoline combustion associated with engine dynamometer testing (EU-DYNOTEST) located at the Engine Plant. Generally any SO X and PM 2.5 emissions result from natural gas combustion and the gasoline combustion in the engine dynameters. In addition, there are PM 2.5 emissions generated from the painting, body scuffing and machining operations located at Ford manufacturing facilities at the Rouge Complex. In addition to the natural gas, diesel fuel is used for emergency generators and fire pumps, gasoline is us ed in the engine testing dynamometers and propane is used for the mobile hi-los.

There are three natural gas billing meters to account for all of the natural gas used by Severstal and Ford in the Rouge Complex. The facility indicates that the total natural gas usage allocated to the Ford facilities is a reasonable value. Building-specific usage rates are considered less reliable and provided to the company by Severstal for budgetary purposes. Similarly, the PM 2.5 due to natural gas combustion will be less reliable on a building by building basis.

Dearborn Industrial Generation (DIG) began providing steam to the facilities at the complex around August 2001. At that time, the temporary 250-MMBTU boilers, in use since the summer of 1999 as interim replacement for the Rouge Powerhouse, were idled in advance of being shutdown and removed.

The facility fugitive dust plan indicates several areas are swept, flushed or treated to keep dust to a minimum. There are two road vacuum/sweepers. These two road sweepers are cleaned daily and sent to the mechanic shop for routine maintenance (grease, inspection, etc.) on a weekly basis. A consent order mentions bulk materials to address road salt stored in a dome and used to melt snow during the winter season and to address the occasional construction-related debris when temporarily stored on site while awaiting proper waste characterization just prior to being hauled offsite. At this time, the road salt is stored in a dome. There is no need for other enclosures as there are no other permanent material stockpiles. The newest Ford facilities in the Rouge Complex are those buildings associated with the Dearborn Truck Plant. The Paint shop

### 21 became operational in late 2001. Operations in the new final assembly and body shop buildings began during 2004, replacing the fo rmer Dearborn Assembly Plant operations.

Ford’s Installation of the green roof on the Dearborn Truck Plant Final Assembly building was completed in June 2003. There are no reports estimating any air emission reductions associated with the green roof. There have been some storm water benefits from the green roof. The MDEQ believes that the installation of a green roof (while not documented) impacts the reduction of NOx and possibly PM 2.5 within the immediate

area.

Ford is upwind of the Dearborn monitor; however, its throughput does not correspond

well with the ambient PM 2.5 trends. The major emissions from Ford are VOCs (430 tons per year), which the MDEQ is not analyzing for controls in this SIP. Other pollutants such as NOx (>50 tons per year) and PM (>10 tons per year) are not as large as other facilities in the area, and therefore may have less affect on ambient PM 2.5 in the

Dearborn area.

Dearborn Industrial Generation Dearborn Industrial Generation (DIG) is located directly east of Severstal Steel, less than one-quarter mile from the Dearborn monitor. DIG is a cogeneration unit that uses blast furnace gas from Severstal to produce electricity and also provides steam back to Severstal for their processes. The facility consists of three natural gas fired combustion turbines (one installed 1999, other two in 2001), three natural gas (NG) and blast furnace gas (BFG) fired boilers (all installed 2001), and two diesel fuel oil fired emergency generators (installed 2003). Two existing flares (previously owned and operated by Rouge/Severstal Steel Company and now owned by DIG, one installed 1936 other in 1999) burn blast furnace gas if it cannot be utilized in the boilers. All three of the boilers are designed to fire a mixture of up to 95 percent BFG and five percent NG (by heat input) or 100 percent NG. The BFG is received from Severstal Steel as a byproduct of their iron and steel-making operations.

The plant runs year around and use for each unit varies by quarter and year. There is no regular pattern of usage. The flares, boilers and all but one combustion turbine have stacks over 150 feet high. The one combustion turbine has a shorter stack at 60 feet.

Emissions appear to mirror throughput in most cases (see

### 22 Figure 22 through Figure 24 ) . Emissions are determined by parametric emission monitors (PEMs), CEMs, stack tests or ot her. MAERS factors are rarely used to

determine emissions. Boiler #2 for PM 10 has lower emissions compared to throughput than the other boilers (see

### 23 Figure 22). These numbers are based on stack test emissions. The NOx emissions for the boilers do not follow the throughput. These emissions are combined for natural gas and process gas usage. NOx emissions appear to decrease as process gas throughput increases. Therefore emissions to throughput will not correlate as well as other pollutants. These NOx emissions are based on CEMs or PEMs.

Turbine #3 has lower emissions for PM10 compared to throughput than the other turbines (see Figure 23). All three turbines are equipped with low NOx burners. The

emissions are based on stack test emissions.

### 24 Figure 22. SO 2 , PM 10 and NOx for Boilers at DIG

SO2 Thruput to Emissions

0.00 20.00 40.00 60.00 80.00 100.00 120.00 140.00 160.00 180.00 200.00

2000 2001 2002 2003 2004 2005 2006 2007 2008E m ission (tons)

0 10000 20000 30000 40000 50000 60000Thruput(Million Ft3) PM10 Thruput to Emissions

0.00 5.00 10.00 15.00 20.00 25.00 30.00 35.00 40.00 45.00

20002001 20022003 20042005200620072008Emissions (tons)

0 10000 20000 30000 40000 50000 60000Thruput (Million Ft3) NOx Thruput to Emissions

0.00 5.00 10.00 15.00 20.00 25.00 30.00 35.00 40.00 45.00

2000 2001 2002 2003 2004 2005 2006 2007 2008Em ission (tons)

0 10000 20000 30000 40000 50000 60000Thruput (Million Ft3)

Boiler #1 Boiler #2 Boiler #3 Boiler #1 thruput Boiler #2 thruput Boiler #3 thruput

Figure 23. PM 10 and NOx for Turbines at DIG

PM10 Thruput to Emissions

0.00 5.00 10.00 15.00 20.00 25.00

2000 20012002 20032004200520062007 2008Emission (tons)

0 1000 2000 3000 4000 5000 6000 7000 8000Thruput (Million Ft3) Turbine #1

Turbine #2

Turbine #3

Turbine #1 thruput

Turbine #2 thruput

Turbine #3 thruput NOx Thruput to Emissions

0.00 20.00 40.00 60.00 80.00 100.00 120.00 140.00

200020012002200320042005200620072008Emission (tons)

0 1000 2000 3000 4000 5000 6000 7000 8000Thruput (Million Ft3)

### 25 Figure 24. SO 2 and NO X for Flares at DIG

SO2 Thruput to Emissions

0.00 50.00 100.00 150.00 200.00 250.00 300.00 350.00 400.00 450.00

2000 2001 2002 2003 2004 2005 2006 2007 2008Emissions (tons)

0 10000 20000 30000 40000 50000 60000 70000 80000Thruput (Million Ft3) Flare #1

Flare #2

Flare #1 thruput

Flare #2 thruput NOx Thruput to Emissions

0.00 50.00 100.00 150.00 200.00 250.00

2000 2001 2002 2003 2004 2005 2006 2007 2008Emissions (tons)

0 10000 20000 30000 40000 50000 60000 70000 80000Thruput (M illion Ft3)

Throughput for the boilers and flares at DIG was compared to throughput at the blast furnaces at Severstal (see Figure 25). For the initial year (2001-2004) the throughput does not align; however, for 2005-2008, throughput correlates for DIG and Severstal. The boilers and one flare were built in 2001. Since they were just starting up, they likely were not in full use until around 2005 where they start to correlate with Severstal’s

emissions.

Figure 25. Throughput Comparing DIG to Severstal

Thruput for DIG and Severstal

0 10000 20000 30000 40000 50000 60000 70000 80000

1 998

1 9

9 9

2000
2 0

0

1

200 2

2003
2 0

0 4

200 5

2006
2 0

0 7

200 8thruput (million ft3)

0 500000 1000000 1500000 2000000 2500000 3000000thruput (tons) Boiler #1 process gas (E6FT3)

Boiler #2 process gas (E6FT3)

Boiler #3 process gas (E6FT3)

Flare #1 (E6FT3)

Flare #2 (E6FT3)

B and C Blast

Furnace Cast House (tons)

### 26 Ambient PM 2.5 at Dearborn is decreasing similar to emissions at DIG after 2005, but earlier years do not correspond to PM 2.5 ambient concentrations (see Figure 26).

Figure 26. Throughput to ambient PM 2.5 for DIG



### Thruput to Ambient PM2.5 at Dearborn

0 10000 20000 30000 40000 50000 60000 70000 80000

2000 2001 2002 2003 2004 2005 2006 2007 2008Thruput (Millions Ft3)

0.00 5.00 10.00 15.00 20.00 25.00Concentration (ug/m3) Boiler #1 process gas (E6FT3)

Boiler #2 process gas (E6FT3)

Boiler #3 process gas (E6FT3)

Flare #1 (E6FT3)

Flare #2 (E6FT3)

PM2.5 (ug/m3)

Cadillac Asphalt Products Corporation The Cadillac Asphalt Products Corporation Plant 5A hot mix asphalt facility is located at 670 S. Dix Avenue, Detroit, Michigan. The location is about one half mile south of the Ford Rouge Complex and 1.5 miles south-southwest of the Dearborn monitor.

The facility operates a 525 tons-per-hour parallel flow hot mix asphalt (HMA) process. During a permit modification in 1999, the plant was limited to the use of natural gas and No. 2 fuel oil (where previously it had been a llowed to use recycled oils). The maximum allowed production at the facility, based on a 12-month rolling period, is 940,000 tons per year, with a maximum hourly capacity of 525 tons per hour of HMA. The HMA production season in Michigan usually occurs early April through November, depending

on weather conditions.

Figure 27 and 28 indicate an increase in the natural gas throughput for 2003 and a significant decrease for asphalt throughputs for 2006 (which can be attributed to the beginning of the economic decline in Michigan). Other than 2006, the asphalt operations were fairly steady. This could imply that emissions from the facility are not reflected in the decreasing PM 2.5 levels at the Dearborn monitor.

### 27 Figure 27. Throughput of Natural Gas in Asphalt Heater



### Asphalt Heater Natural Gas Thruput

0.00 20.00 40.00 60.00 80.00 100.00 120.00

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Calendar YearEFT3

Figure 28. Throughput of Hot Mix Asphalt Through Rotary Drum



### Hot Mix Asphalt through Rotary Drum

0 100,000 200,000 300,000 400,000 500,000

2 00

0 2001 2 00

2
2 00

3 2004
2 00

6
2 00

7 2008

Calendar Year Tons

US Gypsum The US Gypsum plant is located 2.5 miles southeast of the Dearborn monitor in River Rouge. This plant emits 50 tons or less of NO X and 100 tons or less of PM.

Ninety percent of the plant’s production is gypsum wallboard. US Gypsum Company's exclusive registered trade name for its gypsum wallboard is Sheetrock. The plant also manufactures cement board, which is used as backing for tiled walls, such as

bathrooms.

The primary raw material used is gypsum, or calcium sulfate, which forms airborne particulate air pollution during the manufacturing process. The plant has a large number of baghouse type dust collectors to control these emissions.

### 28 US Gypsum has one stack for its mill rock dryer that is 122 feet tall. A second baghouse stack that is discharged inside a building is only 25 feet tall. US Gypsum operates year around, generally 4 to 6 days per week.

Emissions reported in MAERS are based on M AERS emission factors or other factors. The NOx emissions and some PM emissions appear to closely follow the throughput values (see Figure 29 and Figure 30). The emissions do not correlate well with the

ambient PM 2.5 (see Figure 31). US Gypsum does mostly grinding of materials and does not incinerate, therefore, most of it emissions are likely in the PM 10 fraction rather than

the PM 2.5 fraction.

Figure 29. NO X Emissions to Throughput Comparison for US Gypsum

Emissions to Thruput for NOx

0.00 10.00 20.00 30.00 40.00 50.00 60.00

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008Emissions (tons)

0.00 100.00 200.00 300.00 400.00 500.00 600.00Thruput (million ft3) NOX

Nox Thruput

EU0085

Figure 30. PM 10 Emissions to Throughput Comparison for US Gypsum

Emissions to Thruput for PM10

0.00 20.00 40.00 60.00 80.00 100.00 120.00

19981999200020012002200320042005200620072008Emissions (tons)

0 50,000 100,000 150,000 200,000 250,000 300,000 350,000Thruput (tons) PM10-PRI

PM10-FIL

PM-PRI

PM10 thruput

EU0051

### 29 Figure 31. Emissions to Ambient PM 2.5 Concentrations for US Gypsum

Emissions to Ambient PM2.5

0.00 20.00 40.00 60.00 80.00 100.00 120.00

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008Emissions (tons)

0 5 10 15 20 25PM2.5 (ug/m3) NOX

PM10-FIL

PM10-PRI

PM-PRI

SO2

Ambient

PM2.5

Carmeuse Lime/River Rouge Carmeuse Lime in River Rouge is approximat ely 2.5 miles southeast from the Dearborn monitor. Another lime plant, Carmeuse/Det roit Lime was less than a mile from the Dearborn monitor; however, that plant closed down in 2003.

Carmeuse Lime/River Rouge produces lime by the calcination of limestone. Limestone is calcinated in two horizontal rotary kilns. Limestone from the storage pile is transferred to the kilns through transfer stations and conveyors. The facility has two rotary kilns that may be operated simultaneously. The kilns are fired using pulverized coal and natural gas. The gases from the kilns are exhausted through two baghouses.

Three baghouses collect emissions generated by the handling of lime (loadout and rescreen). Flue dust from the kilns is pneumat ically conveyed to the flue dust tank where it is stored and loaded into trucks. The flue dust tank and loadout spout are controlled by a dust collector.

Carmeuse Lime/River Rouge is a major emitter of NOx, SO 2 and PM. Carmeuse has two baghouse stacks about 70 feet tall. This plant operates year around and uses mostly MAERS emission factors. The emi ssions generally follow the throughput of lime (see Figure 32). The emissions do not correlate well to the ambient data at Dearborn. This may be partially explained by the facility distance and direction from the Dearborn monitor (see Figure 33).

### 30 Figure 32. Emissions to Throughput Comparison for Carmeuse Lime/River Rouge

Thruput to Emissions

0 100 200 300 400 500 600

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008Emissions (tons)

0 100000 200000 300000 400000 500000 600000 700000Thruput (tons) SO2

PM10

Nox

Lime Thruput

Bit Coal Thruput

Limestone Thruput

Figure 33. Emissions to Ambient PM 2.5 Concentrations for Carmeuse Lime/River Rouge

Emissions to Ambient PM2.5

0 100 200 300 400 500 600

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008Emissions (tons)

0 5 10 15 20 25

SO2

PM10

Nox

PM2.5 (ug/m3)

Detroit Wastewater Treatment Plant

The Detroit Wastewater Treatment Plant is located two miles southeast of the Dearborn monitor. The wastewater treatment plant collects and treats domestic and industrial wastewater from the Metro Detroit area. The treatment capacity of the plant is about two billion gallons per day. The treated wastewater is discharged to the Detroit River. The treatment involves removal of large solids using bar racks and grit chambers, primary and secondary biological treatment for the removal of suspended and dissolved solids, clarification, chlorination of water from secondary clarifiers, sludge dewatering, sludge incineration and ash disposal to a sanitary landfill. The treatment processes are significant sources of volatile organic co mpound emissions; however, the incineration of sludge from filtration is the major source of NO X , SO 2 , and PM.

The facility has 14 sludge incinerators cont rolled by venturi and impingement tray scrubbers. The complex I incinerators (incinerators 1 through 6) were constructed in 1940. The Installation permit (No. C-6657) covers Tall Stack #1 (254 ft tall) for Complex I Sewage Sludge Incinerator System serving Incinerators 1 through 6. The Complex II

### 31 incinerators were constructed in 1970 and are covered by installation permits C-6649through C-6656 for incinerators 7 through 14 respectively. Installation permit (No. C6658) covers Tall Stack #II (254 ft tall) for Complex II sewage sludge incinerator system serving incinerators 7 through 10. Installation permit (No. C-6659) covers Tall Stack III (254 ft tall) for Complex II sludge incinerator system serving incinerators 11 through 14. Each incinerator has a flue (stack). These flues are enclosed within three tall stacks. The six flues for the incinerators Number 1-6 are enclosed in Tall Stack #1, flues for

incinerators 7-10 are enclosed in the Tall Stack II and flues for incinerators 11-14 are enclosed in Tall Stack #III. For an observer, only three stacks are visible.

Installation permits (No. C-6628 and C-6629) cover Sludge Mixer #1(East) and Sludge Mixer #1 (West) respectively. The sludge/lime mixing area is also covered by the installation permit (No. C-6629). Because sludge mixers are situated inside the lime pad area, EGLIMEPAD and the sludge mixe rs (EGSLUDGEMIXER1 and EGSLUDGE MIXER2) are combined into one emission unit. Installation permits (No. C-6630 through C-6635) cover Lime Storage Silos 1 through 6, which are controlled by a fabric filter baghouse. The sludge mixing facility is controlled by a fabric filter baghouse. Complex I and Complex II ash handling systems are controlled by fabric filters.

The plant runs year around. Emissions are calculated using MAERS emission factors (see Figure 34) according to the MAERS inventory. While the SO 2 and NOx correlate with the throughput, the PM does not. In 2005, MAERS emissions factors were reported to be used, but control efficiencies were added.

Figure 34. Emissions to Throughput Comparison for DWTP

Emission to Thruput

0 50 100 150 200 250 300 350 400 450 500

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008Emissions (tons)

0 20000 40000 60000 80000 100000 120000 140000 160000 180000 200000Thruput (tons)

NOX thruput (tons) Emission to Thruput

0 20 40 60 80 100 120 140 160 180

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008Emissions (tons)

0 20000 40000 60000 80000 100000 120000 140000 160000 180000 200000Thruput (tons)

PM10-PRI PM10MITOT PM25-PRI PM-PRI SO2 thruput (tons)

Emissions to ambient data do not correlate well except for the later 3 to 4 years (see

### 32 Figure 35). In general, this source’s location and controls may partially explain this. The plant has multiple controls for their incinerators, such as demisters, impingement plate scrubbers and venturi scrubbers that control 90-99 percent of PM emissions.

### 33 Figure 35. Emissions to Ambient PM 2.5 Concentrations for DWTP

Emissions to Ambient PM2.5

0 5 10 15 20 25 30 35 40 45 50

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008Emissions (tons)

0 5 10 15 20 25PM2.5 (ug/m3)

PM10-PRI PM10MITOT PM25-PRI PM2.5 Emissions to Ambient PM2.5

0 50 100 150 200 250 300 350 400 450 500

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008Emissions (tons)

0 5 10 15 20 25PM2.5 (ug/m3)

NOX SO2 PM2.5

St. Mary’s Cement St. Mary’s is a cement processing plant about 1.5 miles southeast of the Dearborn monitor. The plant has less than 10 tons per year emissions of NO X and SO 2 , and

around 25-35 tons of PM 10 per year. PM emissions are ma inly from their grinding mills that have bag house control with 99.9 percent control efficiency of PM 10 . There are no emissions stacks indicated in MAERS and the majority of their activity occurs in the warmer months. The emissions do not match the throughput (see Figure 36) probably because the emission factors for PM have changed. Also, MAERS indicates the method used as “other,” but no other indication of how the emission factor is calculated is shown

in MAERS. The emissions do not match the ambient PM 2.5 (see Figure 37) although there is a slight trend downward for the last four years for both emissions and ambient data. The emissions from this source are not from combustion, but rather grinding, therefore, the size fraction will likely be greater than PM 2.5 , more in the PM 10 size range. This source is not likely to affect the ambient PM 2.5 in the Dearborn area for this reason.

Figure 36. Emissions to Throughput Comparison for St. Mary’s

Emissions to Thruput

0 5 10 15 20 25 30 35

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008Emissions (tons)

0 200,000 400,000 600,000 800,000 1,000,000 1,200,000Thruput (tons) NOX

PM10-FIL

PM10-PRI

PM-PRI

SO2

thruput

### 34 Figure 37. Emissions to Ambient PM 2.5 Concentrations for St. Mary’s

Emissions to Ambient PM2.5

0 5 10 15 20 25 30 35

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008Emissions (tons)

0 5 10 15 20 25PM2.5 (ug/m3) NOX

PM10-FIL

PM10-PRI

PM-PRI

SO2

PM2.5

Edward C. Levy Co Plant 1 This company crushes and screens slag. It is located approximately one mile northeast of the Dearborn monitor. Most of their emissions are from hauling on paved and unpaved roads in the form of PM 10 . Since the operation is crushing, most of the PM is likely in the PM 10 fraction, not PM 2.5 . This source likely has little effect of the ambient

PM 2.5 is the area.

Darling International, Inc. The facility is a rendering operation located at 3350 Greenfield Road, Melvindale, Wayne County, Michigan. It is approximately two m iles southwest of the Dearborn monitor. This facility has two permits, one for the three boilers in operation at the site and the other permit covers processing operations. As of 2004, to address numerous odor complaints, the facility does not “render” animal carcasses at this location. All carcasses are packaged and sent to another location (Coldwater, Michigan) for processing.

Rendering is a process that converts waste animal tissue into stable, value-added materials. Rendering can refer to any processing of animal byproducts into more useful materials, or more narrowly to the rendering of whole animal fatty tissue into purified fats like lard or tallow. The majority of tissue processed comes from slaughterhouses, but also includes restaurant grease and butcher shop trimmings. This material can include the fatty tissue, bones, and offal, as well as entire carcasses of animals condemned at slaughterhouses, and those that have died on farms.

However, the facility continues to process grease and oils taken in from local restaurants. This includes cooking off the water and filtering any solids remaining in the

grease.

Power Plants Detroit Edison has two power plants in the area. One plant has very tall stacks (>350 ft) and likely doesn’t significantly affect the Dearborn monitor. The other plant has natural gas fired combustion turbines that operate only during peak demand. This source has low emissions and may not be impacting the Dearborn monitor significantly.

### 35 Small Sources Several sources have minimal emissions (less than 5 tons) and were not evaluated. These sources include Xcel Steel Pickling, Ford Motor New Model Program, Automotive Components Holding; Envirosolids LLC, City of Dearborn, Detroit Salt, Hinkle MFG LLC, and DTE Energy/Ford World Headquarters.

VOC Sources Several sources emit primarily VOCs, such as Fabricon Products, Inc.; Buckeye Terminals LLC; Sunoco Partners M&T; LP (River Rouge Terminal); and Magni Industries, Inc. Since the EPA and DEQ did not find that VOCs should be evaluated for possible controls, these sources were not further evaluated.

Sources Out of Business Near the Dearborn Monitor Several sources that were located near the Dearborn Monitor have ceased operations. These include, M-Lok (aka Riley Plating), Spartan Industrial, Great Lakes Petroleum Terminal (Owens Corning), Ferrous Environmental, Ford Motor Clay Mine and Honeywell Industries (aka Allied Signal and Detroit Tar). Of the four sources indicated above, only Honeywell had significant particulate (PM 2.5 ), oxides of nitrogen (NO X ) and oxides of sulfur (SO X ) emissions. The Ford Motor Clay Mine had high particulate emissions due to truck traffic. The remaining two sources emitted VOCs through coating operations.

Honeywell Honeywell (SRN B5558) is located 2.5 miles southeast of the Dearborn monitor, just north of Zug Island (US Steel). Honeywell ceased operations in 2005, with some minor emissions for volatile organic compounds as the storage tanks were emptied completely. The source permits were voided in calendar year 2005. The facility had boiler and process heater material throughputs of more than 24,801,449 million gallons in 1998 reducing to approximately 533 thousand gallons in 2004. AQD staff believes the data submitted in 1998 was reported erroneously, (i.e., may have been in gallons only) so data is not included in the review. Therefore the material throughput value for the boiler and process heaters in 1999 were approximately 2,200 million gallons of fuel oil. Please note the facility did have a coal fired boiler; however, this boiler was not in operation during the time frame under discussion.

The NO X emissions decreased from 57 tons per year in 1999 to 1.3 tons in 2004 with zero emissions reported in 2005. The SO X emissions decreased from 105 tons per year in 1999 to 25.2 tons in 2004 and again no emissions reported for 2005. The PM 2.5 emissions were reported from 2003 and 2004 and calculated using an emissions factor based on those year’s submittals of 2.5 pounds PM 2.5 per material throughput. The

PM 2.5 emissions were calculated for 1999 as 2.8 tons and reported at 1.4 tons in 2004 (see Figure 38 and Figure 39).

### 36 Figure 38. Honeywell Emissions



### Honeywell Emissions

0 10 20 30 40 50 60 70 80 90 100

1999 2000 2001 2002 2003 2004 2005

Calendar years Tons

Nox Emissions Sox Emissions PM 2.5 Emissions

Figure 39. Material Throughput for Honeywell

Material Thruput Thousand Gallons

0 500 1,000 1,500 2,000 2,500

1999 2000 2001 2002 2003 2004 2005

Great Lakes Petroleum (Owens Corning) This company was located about 1.5 miles south-southeast of the Dearborn monitor. It produced asphalt, was a small source of NO X (< 30 tons per year), PM (< 20 tons per year) and emitted 30-70 tons of SO 2 (see 

### Figure 40 ). Owens Corning shut down their Detroit Plant on January 1, 2008. The company has had their ROP voided and will have their PTIs voided, as well.

### 37 Figure 40. Emissions from Owens Corning



### Owens Corning Emissions

0 10 20 30 40 50 60 70 80

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007Emissions (tons)

NOX

PM10-PRI

PM25-PRI

SO2

# Appendix E

Impact of Southeast Michigan’s New Economic Reality on Regional Pollutant Emissions

Provided by SEMCOG2 

## The Impact of Southeast Mich igan’s New Economic Reality on Regional Pollutant Emissions

While substantial emission reductions have been achieved through implementation of local and

national controls included in the PM2.5 State Implementation Plan fo r Southeast Michigan, significant additional reductions have occurred as a result of the economic transformation that has taken place in the region.

Since 2000, Southeast Michigan has lost over 116,000 people and 400,000 jobs. The recent loss of jobs is almost entirely due to the permanent downsizing of the American auto industry and the overall decline of the manufacturing sector. Sinc e the early 1900s, manufacturing had been the predominant source of jobs in Mi chigan. However, this has cha nged significantly over the past decade. Between 2002 and 2007, the state lost nearly 404,000 auto-related jobs, while gaining just over 200,000 jobs in non-manufact uring sectors (Figure 1).

Figure 1 Growing and declining indus tries in Michigan, 2002-2007

Source: U.S. Bureau of Labor Statistics, Don Grimes



### There is national recognition that the American auto industry a nd the manufacturing sector as a whole, will never return to its prerecession size and that future jobs in the region will need to come
from other sectors. Indeed, this transition is al ready taking place. By the end of 2007, the number of health care jobs in Southeast Michigan had actually surpassed the number in manufacturing (Figure 2).3 

### Figure 2 Employment is shifting to less polluting sectors
Manufacturing vs. health care jo bs, Southeast Michigan, 2000-2009

Source: SEMCOG analysis of Michig an Labor Market Information data



### The transition away from manufacturing to a more service and retail based economy has resulted in lower utility consumption. Figures 3, 4 and 5 show the decline in natural ga s, electricity and water use over the past decade. Lower utility use means lower pollutant emissions from these sources.

Figure 3 Figure 4 The region is consuming less natural gas The region is also consuming less electricity
Consumers Energy gas deliveries DTE electricity deliveries

Source: Consumers Energy Source: DTE Energy4 

### Figure 5 Water use is also declining
Average daily water use, Detroit Water and Sewerage Department

Source: The Foster Group



### In addition to the reduction in ma nufacturing activity and the resulting decline in stationary source pollution, Southeast Michigan has also experienced a significant decrease in vehicle miles of travel (VMT). Since 2002, VMT has declined 13 percent. As would be expected, this decrease has closely mirrored the decline in regional employment (Figure 6).

Figure 6 As jobs have declined, so has travel
Changes in Southeast Michigan em ployment and travel, 2002-2009

Source: SEMCOG and U.S. Bureau of Economic Analysis5 

### It is important to understand that these economic ch anges are not a temporary artifact of the current nation-wide recession. As noted earlier, the change s in Southeast Michigan began long before 2008. Employment has been dropping since 2000 and populat ion, which had shown little growth over the last 40 years, began to decline in 2006.

Furthermore, the latest demographic forecasts for the region do not predict much change in this trend for the foreseeable future The latest forecast from the Southeast Michigan Council of Governments (SEMCOG) shows that by 2035 the region will still have 196,000 fewer people and 213,000 fewer jobs than it had in 2000 (Figures 7 and 8).

Figure 7 Southeast Michigan will have 196,000 fewer people in 35 years
Actual and projected population, 2001-2035

Source: SEMCOG



### Figure 8 Southeast Michigan will have 213,000 fewer jobs in 35 years
Actual and projected employment, 2000-2035

Source: SEMCOG6 

### As previously shown, the amount of travel in the region is closely ti ed to the amount of employment. Thus, fewer jobs in the future will also mean less vehicle miles of travel. This reduction, on top of the already expected polluta nt decrease from fleet turnover, means on-road mobile source emissions will continue to decline significantly in the future.

The above weight of evidence, coupled with the dramatic decrease in monitored PM2.5 concentrations in the region, clea rly indicates that significant a nd permanent emission reductions have occurred in Southeast Michigan and will remain for the foreseeable future.

# Appendix F

Public Hearing and Comments

### 2 

## Calendar Notice of Public Comment Period and Public Hearing

### 3

### 4

### 5 Response to Comments

Comment : Several commenters stated the local targeted reductions as well as regional and federal programs including sulfur in fuel limits, acid rain provisions, NO X SIP call, Clean Air Interstate Rule and its replacement rule and fleet turnovers, helped reduce PM 2.5 in the

nonattainment area. Response : MDEQ agrees with these comments. Thank you for your support.

Comment : Several commenters recognized the research effort and analysis to develop the state implementation plan (SIP) and correctly identify the sources contributing to the PM 2.5 problem. Response : MDEQ agrees with these comments. Thank you for your support.

Comment : Several commenters encourage the MDEQ to recognize the progress in improving air quality and it should be recognized by an attainment designation. Response : MDEQ agrees with these comments. Thank you for your support.

Comment : Several commenters indicated that EPA is looking to tighten the PM 2.5 standard, thus MDEQ should not attempt to redesignate the area to attainment. Response : Unless EPA revokes the current standards, Michigan still must show that all areas are attaining the current standards, regardless of whether EPA changes the standard in the future. Furthermore, MDEQ was recently told by senior EPA program staff that there is no

current estimate when new PM 2.5 standards will be proposed. This uncertainty is another reason to move forward with redesignation to attainment.

Comment : Several commenters indicated the economic downturn in Michigan as the reason the 7-county area reached attainment. For this reason, the cause of the lower monitored PM 2.5 is not permanent or enforceable. When the economy improves, emissions will increase and the area may fall back into nonattainment. Response : MDEQ acknowledges that there has been an economic downturn, but believes that permanent and enforceable emissions reductions have occurred beyond the downturn to bring the area into attainment. Reductions from federal control programs for the on-road mobile sector, acid rain program, NO X SIP call, local stationary source controls, and permanent closure of facilities (permit withdrawn) are permanent and enforceable. These emission reductions are significant, and the reduction in PM 2.5 levels can reasonably be attributed to these emission

reductions.

Also, the maintenance plan which is part of this redesignation proposal clearly demonstrates that future year emissions will remain below those of the 2008 attainment year. The demonstration uses a variety of estimates to project future emissions based on growth estimates for the various categories of sources that make up the emissions inventory. The maintenance plan also includes a list of continge ncy measures. Contingency measures are a

menu of additional controls from which to choose further emissions reductions in the event an area violates the National Ambient Air Quality Standards (NAAQS).

Furthermore, economic projections from the Southeast Michigan Council of Governments (SEMCOG) (see Appendix E) indicates that many of the manufacturing jobs in southeast Michigan are gone permanently, and MDEQ cannot assume that emission levels will return to pre-recession levels. An excerpt from the SEMCOG projections follows:

### 6 “The recent loss of jobs is almost entirely due to the permanent downsizing of the American auto industry and the overall decline of the manufacturing sector. . . Between 2002 and 2007, the state lost nearly 404,000 auto-related jobs, while gaining just over 200,000 jobs in non-manufacturing sectors. . . There is national recognition that the American auto industry and the manufacturing sector as a whole, will never return to its prerecession size and that future jobs in the region will need to come from other sectors. . . The transition away from manufacturing to a more service and retail based economy has resulted in lower utility consumption . . .[and] decline in stationary source pollution.”

Comment : Consumers Energy and BASF commented that continued success in attaining air quality standards is essential to the health and economic revitalization and competiveness of

our state. Response : MDEQ agrees with these comments and cont inues to implement programs to attain
and maintain the NAAQS.

Comment : Several commenters stated that PM 2.5 has many health effects including cardiovascular disease in post-menopausal women, premature mortality, heart attacks, strokes, cardiovascular hospital admissions, respiratory hospital admissions, asthma emergency room visits, asthma exacerbations and chronic bronchitis. Added to that is a lack of health insurance and medical facilities. These all add to a greater concern of the issue of PM 2.5 emissions and the health implication of redesignating. Such a move will prove to be a detriment to vulnerable

groups. Response : MDEQ acknowledges that serious health issues can be attributed to PM 2.5 at levels above the NAAQS and has made attainment of the NAAQS a priority. In setting the 1997

annual PM 2.5 NAAQS and the 2006 daily NAAQS, EPA believed, based on all available data, that the standards were protective of human health. Now that the air quality in the 7-county area is meeting these levels, the area should be designated attainment as provided for in the Clean Air Act (CAA). Part of the CAA requirements for an area to qualify for redesignation is the development of a maintenance plan that projects that the area will remain in attainment of the standard for at least 10 years. MDEQ makes this demonstration in this redesignation proposal. MDEQ also will continue monitoring PM 2.5 levels in the area and will continue requiring permits for new or modified sources in the area to demonstrate that any emissions of PM 2.5 from these sources are to be within legal levels.

Comment : The Michigan Environmental Council (MEC) commented that their primary concern with the redesignation is that it does not account for the downturn in the economy, and they use electric generation data to make their point. They point out that the MDEQ data shows an increase in electric generation unit (EGU) emissions for the years 2005 to 2008 but that the department uses data from 2007 to 2010 to demonstrate attainment of the standard. MEC also stated that electric energy usage was lower in 2007-2009, but then increased in 2010 by 6.1 percent and is expected to increase by another 2.3 percent in 2011 according to the Public Service Commission. Since MDEQ used 2007-2010 to demonstrate attainment, it did not take

into account the current increases in electrical demand. Response : MDEQ did take into account EGU activi ty and emissions for the years described in the MEC comments through 2010 in developing the redesignation request. The fact that actual emissions from EGUs in southeast Michigan increased during the years leading to attainment of the standard simply shows that other sources are responsible for the drop in emissions in the area of the Dearborn monitor, traditionally the monitor with the highest PM 2.5 levels. If the energy usage increased by 6.1 percent statewide in 2010, it is not reflected in the monitored values for 2010, which were the lowest recorded for all monitors in southeast Michigan.

### 7 Further, the maintenance plan in this redesignation plan accounts for all emissions in the area and demonstrates that total emissions will continue to decrease into the future years, through 2022. The maintenance plan emission projections ar e based on the best estimates available of growth in the area. It also should be noted that DTE Energy stated they began reducing emissions at the Monroe power plant, the largest EGU source in the state, starting in 2010 (see statement from Michael Lebeis below). Other EGUs will likely install additional controls to address EPA’s proposed Transport Rule in the next several years. These additional EGU

controls were not taken into account in the 2008 and future emissions inventories of this designation request.

Comment : Several groups requested an extension of the comment period. Response : The notice of the public comment period along with an opportunity to request a public hearing were posted in the MDEQ calendar on April 25, 2011 for a 30-day comment period, which ended on May 25, 2011. A public hearing was requested on May 20 and was held on May 26, 2011. MDEQ believes that there was adequate time during the 30-day comment period for interested parties to provide comments and does not believe that an extension of the comment period is warranted.

Comment : Clean Water Action commented that it is likely when there is an upswing in the economy; monitors such as Allen Park that is currently at 14.6 micrograms per cubic meter (ug/m 3 ) could be expected to exceed the current standard again and therefore should not be designated as in attainment. Response : The current monitored design value for Allen Park for 2008-2010 is 11.0 ug/m 3 , well

below the standard. This monitor has been show ing attainment since 2006. MDEQ believes that the maintenance plan in this redesignation plan does adequately address any upswing in the economy through 2022 and predicts that the entire redesignation area will remain in

attainment.

Comment : Clean Water Action commented that in Dearborn, which is nearest to nonattainment, it looks like daily values are below the NAAQS, only in the most recent previous three years, which shifted in one year. This is evidence that the changes in air quality are not
permanent. Response : MDEQ believes these changes are due to permanent and enforceable permitted controls that were installed near the Dearborn monitor. Controls were installed and began operation in the late summer of 2007 at the steel mill near that monitor. The annual average at the Dearborn monitor dropped from 16.89 in 2007 to 13.34 ug/m 3 in 2008. The monitored

values at Dearborn have continued to be as low or lower for 2009 and 2010 since the controls were added at the steel mill. Further, as stated in previous responses, the maintenance plan demonstrates continued emission reductions through 2022.

Comment : Clean Water Action commented that the state has not yet performed a diesel hotspot analysis, and they are not entirely conf ident that these monitors have been correctly located to best represent the potential danger zones from fine particulate emissions. Response : MDEQ is uncertain what a diesel hotspot analysis is. However, two of the monitors in Wayne County, Newberry and FIA-Lafayette Street were installed using a community air toxics grant from EPA to specifically address diesel issues. Newberry was installed to monitor near the proposed Detroit Intermodal Freight Terminal and FIA-Lafayette was installed to monitor the Ambassador Bridge Traffic. Both Newberry and FIA-Lafayette Street monitors are below the annual standard at 10.7 and 11.0 ug/m 3 , respectively and below the daily standard at 29 and 30 ug/m 3 , respectively.

### 8 Comment : Clean Water Action commented that no safe threshold for PM 2.5 exposure has been determined. So since PM from diesel emissions is particularly deadly and spikes in exposure are not represented by the averaging of monitoring data, this needs to be considered as the state seeks redesignation status. Response : The current NAAQS standards for PM 2.5 are intended to be protective of public health. When air monitors show that a nonattainment area is meeting these standards, the CAA provides for the mechanism of redesignation to reflect that the air meets the standards. MDEQ is following this path and believes it is the appropriate action. MDEQ agrees that diesel emissions are a source of concern and encourages further study of emissions and impacts on public health.

Comment : Clean Water Action commented that EPA is expected to soon tighten the standards

for PM 2.5 . The PM 2.5 standards are expected to be 13 ug/m 3 averaged over three years or lower. If the monitoring data reflected in the 2008-2010 average remains the same, then the Allen Park and Dearborn monitors show levels that would be back in nonattainment. However, there is the possible standard of 12 and that would put Ypsilanti, Allen Park, SWHS, Dearborn, and FIA-Lafayette Street out of compliance. Response : Based on the 2008-2010 3-year averages, the highest monitor, Dearborn, is showing 12.2 ug/m 3 . The remaining monitors are showing 11.5 ug/m 3 or less. Furthermore, unless EPA revokes the current standard, Michigan still must show that they are attaining the current standards, regardless of whether EPA changes the standard in the future. Recent information presented by EPA officials suggests that new PM 2.5 standards will not be proposed

in the near future.

Comment : Two commenters from the Sierra Club commented that “diesel emissions may be a significant risk driver in the context of the total cancer risks estimated in this [DATI] report for the other Detroit area air toxics.” (MDEQ DATI Report, 2010). They go on to say that it raises a

number of concerns about whether these leve ls would actually be adequate to protect public health. It is important that the MDEQ consider the existing international trucking traffic in this area and the projected truck traffic from the proposed bridge, which was not considered here. Diesel pollution should be considered because of traffic going to and from the Ambassador Bridge, and any new bridge to come. Response : MDEQ has accounted for truck traffic in the area. Emissions from Ambassador Bridge traffic, both now and in the future, ar e included in the on-road emissions inventory SEMCOG prepared for the PM 2.5 redesignation request. Current and expected future travel across the bridge is included in SEMCOG’s travel demand model, which produces the vehicle miles of travel that are input to the MOVES emissions model to calculate on-road emissions. Regarding levels of PM 2.5 , as pointed out in a previous response in this document, the monitor near the Ambassador Bridge, FIA-Lafayette Street, is showing attainment for the annual PM 2.5 standard at 11.0 ug/m 3 for 2008-2010, well below the NAAQS.

Comment : DTE Energy commented that the 2005, 2008 and future year inventories used in this redesignation request does not accurately portray emissions at the Monroe Power Plant. The selective catalytic reduction (SCR) controls were not used year-round until 2009. In 2010,

SO 2 emissions dropped by over 50,000 tons due to operation of flue gas desulfurization (FGDs) controls, and the projected inventory between 2008 and 2018 only predicted a total drop of 28,000 tons. In addition, DTE intends to add FGDs on the remaining two units and an SCR on the remaining unit by 2014. Since DTE went through the process of permitting, these reductions are enforceable and permanent. Response : These additional reductions, beyond what is calculated in the emissions inventory, will help to ensure that the area remains in attainment of the standard.

### 9 Public Hearing Record

A public hearing was held on May 26, 2011 as requested. Attending the meeting were G. Vinson Hellwig, representing MDEQ Director Dan Wyant, who is the decision-maker; Craig Fitzner, the hearing officer; and Teresa Cooper, Robert Irvine, Cindy Hodges, Mary Maupin, Amy Robinson and Robert Rusch from the MDEQ. Public statements were made by James Clift from the Michigan Environmental Council, Susan Harley from Clean Water Action, Anne Woiwode representing Sierra Club, and Michael Lebeis from DTE Energy. Also attending were Scott Sinkwitts and Kate Ross from CMS Energy, Kurt Kissling from Pepper-Hamilton Law Firm, and Kristin Jabin from the Michigan Clean Cities. The following are statements from the public hearing.

Hearing Officer’s Statement

Department of Environmental Quality Opening Statement By: Craig Fitzner, Hearings Officer

May 26, 2011

Introduction Good afternoon. My name is Craig Fitzner, and I am the supervisor of air monitoring unit in the Air Quality Division of the Michigan Department of Environmental Quality. I will be serving as the Hearing Officer for this public hearing on the request for redesignation of southeast Michigan, to attainment status for both the annual and 24-hour PM 2.5 NAAQS.

With me today are other MDEQ staff who will be assisting with this hearing. Seated with me are Cindy Hodges of the Strategy Development Unit, and Vince Hellwig, Chief of the Air Quality Division, who is the decision-maker for this redesignation request.

Hearing Agenda To describe how this is going to work today, I will begin with some background information as to why we are here today. I will then describe the purpose of this formal hearing and how your comments will be used. Following that, I will outline the procedures under which we will take your comments and then describe what will happen after today’s hearing. It will then be your time to provide comments, and we will spend the majority of time today listening to those comments. At the end of the hearing, I will provide a short summary and closing.

Background Information By way of background information, the Air Quality Division is responsible for protecting Michigan’s air resources. The law governing those responsibilities is Part 5502 of the 1994 Natural Resources and Environmental Protection Act, Public Act 451, as amended. We are here today for a public hearing on the MDEQ’s request to EPA to redesignate seven counties in southeast Michigan to attainment status for the annual and 24-hour fine particulate matter

standards.

I will now ask Cindy Hodges to summarize the redesignation request.

### 10 Purpose of Public Hearing To fulfill EPA requirements in the redesignation process, the MDEQ must provide a 30-day comment period and the opportunity to request a public hearing in accordance with Section 110 (a) (2) of the Clean Air Act.

The purpose of today’s hearing is to give anyone interested in the redesignation request an opportunity to provide input. The MDEQ will cons ider any comments received in completing the redesignation request.

Procedures Notice of this hearing was published in the MDEQ calendar and on other MDEQ web pages.

As you came in this afternoon, you were given an opportunity to fill out a public comment card. We request that everybody fill out a card and indicate if you wish to make comments. We will use these cards to maintain a record of people interested in the redesignation request and to call upon those who want to make a statement today. To ensure that the hearing is conducted in a fair manner, we will follow these steps: 1. I will call on those who have indicated on the cards that they would like to speak in the general order in which the cards were turned in. When all the cards have been completed, I will ask if anyone else would like to make a statement. 2. When your name is called, please come to the front of the room, face me, and make your statement. If you have written comments or ma terials you would like to present, please hand them to me as you come to the microphone. As you begin your comments, please state your name and any group or association you may represent.

How the Information Will be Used This hearing is being recorded and your comments will be a part of the information the MDEQ will considered in making its decision on this redesignation request. The public comment period for the redesignation request ended May 25, 2011, but comments from this hearing will be accepted as well. Additional information can be submitted until then and will also be considered when the MDEQ completes the redesignation request.

Following the public hearing, the MDEQ staff will review all comments and include them in the redesignation request document including the response to those comments. A copy of the redesignation request including comments will be available on the MDEQ website. These comments will be sent to EPA as part of our redesignation request. Once EPA has determined that the redesignation request is complete, EPA has up to 18 months to propose approval or disapproval of the redesignation request. EPA’s proposal and final determination will be published in the federal register.

Thank you for your attention. I will now begin calling the names of those who have indicated they would like to make a statement.

Closing Statement Thank you for your comments and cooperation today . We appreciate your interest in the redesignation request and that you took the time to be here today.

The hearing is now closed. Thank you again.

Closing time – 4 pm

### 11 Staff Background Information Statement

Michigan Department of Environmental Quality Air Quality Division

Request to Redesignate to Attainment Status

For Both the Annual and 24-Hour PM 2.5 NAAQS May 26, 2011 By Cindy Hodges

The State of Michigan, through the Michigan Department of Environmental Quality, is asking the U.S. Environmental Protection Agency to make a determination that southeast Michigan is in attainment with the annual and daily Fine Particulate Matter (PM 2.5 ) National Ambient Air Quality Standards (NAAQS) and to approve the maintenance plan as a revision to the Michigan State Implementation Plan. The seven counties in the southeast Michigan PM 2.5 nonattainment area are Livingston, Macomb, Monroe, Oakland, St. Clair, Washtenaw, and Wayne.

The EPA established the annual and daily NAAQS for fine particulate matter in 1997 and revised them in 2006. EPA determined that the seven counties should be designated as nonattainment for the annual standard in 2005 and for the daily standard in 2009. The designations were based on design values derived from air quality monitoring data. Annual averages over 15 micrograms per cubic meter (μg/m 3 ) and daily averages over 35 μg/m 3 were considered to be violating the standard. The EPA designated seven counties in Michigan as nonattainment for the annual standard, because m onitored design values exceeded these limits.

The MDEQ submitted a State Implementation Plan to EPA in June 2008 demonstrating that both local and regional control programs would bring about reductions in PM 2.5 levels in the 7- county nonattainment area such that the area would be expected to attain the NAAQS by 2010.

Air quality monitoring data collected in the 2007-2010 period has confirmed that the 7-county southeast Michigan area is attaining the PM 2.5 annual and daily standards. The most recent 3- year average of the ambient annual concentration is 12.2 ug/m 3 , which is below the annual standard of 15.0 ug/m 3 . The most recent 3-year average of the daily ambient concentration is 32 ug/m 3 , which is below the daily standard of 35 ug/m 3

.

The components of the redesignation package include:

• A determination that the area has attained the standard; based on monitoring data, emissions inventory reductions and additional supporting evidence;

• An approved State Implementation Plan for the area;

• A determination that the improvement in air quality is due to permanent and enforceable reductions in emissions;

• A fully approved maintenance plan that includes contingency measures; and

• A determination that all Section 110 and Part D requirements, including monitoring, reporting, and permitting under the Clean Air Act have been met.

The redesignation document summarizes compliance with each required component of the attainment redesignation providing a demonstr ation to EPA that the 7-county area should be redesignated to attainment of the annual and daily PM 2.5 NAAQS.

### 12 Transcription of Citizens’ Statements

TRANSCRIPT OF COMMENTS FROM ATTENDEES
AT A PUBLIC HEARING ON MDEQ’s

PM 2.5 REDESIGNATION REQUEST TO EPA

AIR QUALITY DIVISION, MDEQ MAY 26, 2011

James Clift, Michigan Environmental Council

My name is James Clift, I’m the policy director for the Michigan Environmental Council, we are an umbrella group of environmental, public health, conservation groups located across the

state.

We think the redesignation of the seven countie s in the southeast Michigan area is premature and not in the best interest of the residents of Michigan. The main reason we think so is that we think that the data we’re seeing today is not permanent and enforceable, we think it is a reflection of the economic downturn that Michigan has experienced, and we are concerned that when our economy recovers, the data will not keep us below the current standards.

We noted that in the data that the decision is based on, we did have an increase from our electric generating units in the period of 2005 to 2008, but we show the data, when you’re looking at the data from the 2007 to 2010 framework, shows a significant decrease in the utilization of these facilities by our utilities; DTE the largest utility in southeast Michigan, dropping down to basically 1998 levels of electricity demand. Since that time, we’ve got our public service commission talking about a 2.3% increase in demand in 2011, which followed a 6.1% increase in use in 2010. We also have presented documentation from CMS Energy that talks about a 6% decline in the period of 2007 to 2009, but that they expect a 4% increase in the 2010 to 2011 period.

We couple that with the fact that we think there are significant health impacts that we are experiencing under our current particulate matte r pollution standards. Those involve premature immortality, cardiovascular hospital admissions, respiratory hospital admissions, and asthma emergency visits. We think that Michigan has av oidable health impacts in this area of over one billion dollars per year if we continue to focus on this area of particulate matter pollution and try

to reduce it.

Therefore we think that it’s in the best interest of Michigan actually to keep vigilant in reducing this particulate matter pollution in Michigan, reduce those health care costs, and we don’t see the redesignation as being helpful in continuing that focus. I appreciate this opportunity to comment. Thank you.

(Mr. Clift’s letter was submitted in support of his comment).

### 13

### 14

### 15

### 16

### 17 Susan Harley, Clean Water Action

Thank you so much for holding this hearing and allowing us the opportunity to comment on the MDEQ’s request for redesignation by the EPA of our current 7-county nonattainment status for fine particulates. My name is Susan Harley, I’m the Michigan Policy Director for Clean Water Action. We have over 250,000 members in the state.

First off, I’d like to say that because of the extremely short timeline given regarding the announcement of this public hearing, we would request an extension of the public comment period so that a more thorough analysis can be done of the data presented by the State.

Clean Water Action coordinates the Michigan Diesel Cleanup Campaign and also participates in the Clean Energy Now Coalition that is working to reduce coal plant pollution in the state and transition Michigan to a clean energy economy.

Fine particulate pose a grave danger to human health, including causing premature death, heart attacks and strokes, as well as exasperating existing cardiovascular and respiratory issues such as asthma. I would like to submit to you this study outlining the particular danger from PM 2.5 that is due to diesel emissions. Whereas it does appear that air monitors are at the moment in compliance with current annual and 24-hour standards for PM 2.5 , we do not believe that the state has proven under the weigh of evidence that these changes are permanent and due to sustainable reductions in air pollutants.

It is likely when there is an upswing in the econo my; monitors such as Allen Park that is currently at 14.6 micrograms per cubic meter could be expected to exceed the current standard again and therefore should not be designated as in attainment. Also in Dearborn, which is nearest to nonattainment, it looks like daily values are below the NAAQS, only in the most recent previous three years, which shifted in one year. This is evidence that the changes in air quality are not permanent. Moreover, since the state has not yet done a diesel hotspot analysis, we are not entirely confident that these monitors have been correctly located to best represent the potential danger zones from fine particulate emissions. In addition, no safe threshold for

PM 2.5 exposure has been determined. So since PM from diesel emissions is particularly deadly and spikes in exposure are not represented by t he averaging of monitoring data, this needs to be considered as the state seeks redesignation status.

Lastly, the EPA is expected to soon tighten - again - the standards for PM 2.5 . The PM standards coming down the pike are expected to be 13 micrograms per cubic meter averaged over three years. Or lower, if the monitoring data reflected in the 2008-2010 average remains the same, then the following monitors show levels that would be back in nonattainment. If the standard coming from the EPA is 13, Allen Park and Dearborn would be out of attainment status. However, there is the possible standard of 12 and that would put Ypsilanti, Allen Park, SWHS, Dearborn, and FIA-Lafayette Street out of compliance.

For these and for other reasons, we believe it is not in the best interest of the state’s residents to move forward at this time with a request for redesignation. Thank you.

(Ms. Harley’s comments were submitted in support of her comments as well as the document Clean Air Task Force, 2004, Diesel Emissions: Particulate Matter-Related Health Damages, prepared by Abt Associates, Inc. Due to the length, this document was not included in this redesignation request but is available upon request).

### 18

### 19

### 20 Ann Woiwode

Thank you for holding the hearing and I want to reiterate the comments from Susan Harley regarding the notice of the hearing itself, the comment period was noticed in two calendars but

the actual confirmation that there would be a hearing was only made two days ago and there are a number of people who we are aware of who were unable to come to the hearing, make arrangements to get here with just a two-day notice that the hearing would be held. It would be helpful in future calendars if it’s clear that if someone requests a hearing, it will automatically be held, I believe that wasn’t clear people were awaiting confirmation that a hearing would be held and when they didn’t hear anything until two days before, we literally had people scrambling who were unable to make the hearing.

I am speaking on behalf of the Sierra Club and I want to offer a few comments on the proposed new set of redesignations. As has been said by some others, the monitoring data alone is not sufficient because of these changes in the levels of emissions are not permanent and are not enforceable and that raises a lot of concerns. We want the economy to recover. We want to simultaneously assure that we are protecting the health of people when that happens, and that simply is setting ourselves up for additional health and environmental issues as a result of a recovery that we hope is underway.

There are a couple of other specific observations. From the Detroit Air Toxics Report issued by the MDEQ in Dec. 2010, page ES-3, I want to note that it says that:

“Elevated cancer risk from diesel particulate matter was found in both the DATI-1 and DATI-2 studies. However, these risks were not included in the above estimates and comparisons due to the greater uncertainty associated with determining diesel particulate matter, ambient concentrations, estimating risks and the limited number of sites with surrogate monitoring data. Although these estimated values are relatively uncertain, they serve to provide a general sense of the contribution DPM may add to the cancer risk for air toxics in the Detroit area. The DATI-2 concentration range resulted in an estimated increased cancer risk of approximately 200 x 10 -6 associated with the estimated level at Allen Park, the only site with available surrogate data for comparison. In contrast, the DATI-1 risk estimate was over 300 x 10 -6 . These estimated ranges of cancer risk are considered to have significant uncertainty. However, they suggest that diesel emissions may be a significant risk driver in the context of the total cancer risks estimated in this report for the other Detroit area air toxics.”

That raises a number of concern for us about whether these levels would actually be adequate to protect public health. It is important that the MDEQ consider the existing international trucking traffic in this area and the projected truck traffic from the proposed bridge, which was

not considered here.

The last observation is that given the proposed PM 2.5 rules being developed by the EPA, it is premature to submit a redesignation based on the 2006 standard 15 when EPA is considering lowering those standards to 11 to 13 for a 24-hour standard. Many of the area sites monitored would not meet the new standards in this process should consider those proposed standards.

The hearing notice also said that it would be between 1 and 4 PM and I just want to make sure since the late notice that there will be someone to take comments up until 4 PM so there is no one who is left out if they couldn’t get here at 1 PM. Thank you.

### 21 Mike Lebeis

Yesterday I actually submitted hard copy comment s that already went into the record; I just have a few other things to add to that. This is kind of at the request of Joan Weidner. It actually deals with the enforceability of emission reducti ons that are being implemented in southeast Michigan. The primary location I am commenting on is the Monroe power plant. It turns out that the past actual data were really from 2005 and 2008. The important part about that is that those are years before the flue gas desulfurization was installed on units 3 and 4 and also that was at the time that selective catalytic reduction was installed on units 1, 3 and 4 and was only operated in 2008 during the ozone season because the annual NOx cap did not kick in until 2009 so beginning in 2009, we actually started to winterize our SCR devices so they could operate in a non-ozone season as well as the ozone season. So actually beginning in 2009 and going into the future, those emission reductions that have been acquired by basically putting in the control devices are actually operational now and we have a year or two under our belts to find out what the emissions actually are after putting the devices in.

One thing I want to point out is that 2008 data showed about on the order for units 3 and 4 showed about 58,000 tons of SO 2 and actually 2010 was the first year that the FGDs were running the full year. Actually during that year they dropped to on the order of about just slightly over 1,000 tons. So there is over a 50,000 ton drop in SO 2 emissions, you know, from before the FGDs were installed versus after. The numbers that are projected to go into the future, it shows like between 2008 and 2018 I believe, about a 28,000 ton drop but what we’re saying is that actually from the two units that the FGDs are already installed on, we’ve had almost double that number from just two of the units. And actu ally we’re in the process of installing FGDs on units 1 and 2 and also adding an SCR to unit 2 that is the only unit at the plant that doesn’t have one at this time. And those are projected to be installed by on the order of 2014.

The other thing that comes into play is that these emission reductions are going to be enforceable because we actually went through the process of actually getting the permit for them and we went through a back review for both SO 2 and for NOx to actually solidify the numbers to make sure they’re enforceable so we think that those are permanent reductions that are going to be taking place in the air shed in southeast Michigan. So we just wanted to get that on record that we believe they are permanent and there’s a legitimate reason to use even lower numbers than have been projected at the current estimates at this time. So those are the main things that I wanted to say. Thank you.

### 22 Written Comments

### 23

### 24 Ms. Lorraine Hickman Michigan Department of Environmental Quality, Air Quality Division

P.O. Box 30260 Lansing, MI 48909

Regarding the State of Michigan's move to re designate seven counties in Southeast MI as attainment. In matters of 2.5 particulate ma tter and the impact on Environmental Justice

communities in Southwest Detro it and in particular in the zip code of 48217, I believe it will cause greater harm to the health and quality of life of the residents in these communities and other communities throughout MI . According to a article in the New England Journal of Medicine, particular matter 2.5 has a direct connection to cardiovascular disease in post-menopausal women. Add to that lack of health insurance, and medical facilities most likely there be will be greater concerns of these issues. The health implication of such a move will prove to be a detriment to vulnerable groups

Heavy truck traffic in SW Detroit is a nother concern. Diesel pollution should be considered because of traffic going to and from the Ambassador Bridge, and any new bridge to come. Thanking you for your consideration.

Peace

Rhonda Anderson Field Organizer

National Environmental Justice & Community Partnership Program

Sierra Club/Detroit

2727 Second Ave. suite 320
Detroit, Mi 48201

313 965 0052 office

### 25

### 26

### 27

### 28

### 29