APPENDIXG

Public Participation Documentation
Oral statements will be heard, but for the accuracy ofthe record, statements

to written comments at the public hearing.

IDEM will also accept written comments through March 11,2008. Mailed

comments should be addressed to:

Lake and Porter Counties Fine Particulate Matter (PM2.s)

Redesignation Petition and Maintenance Plan

Scott Deloney, Chief

Programs Branch

Office ofAir Quality MC 61-50

100 North Senate Avenue

Indiana Department ofEnvironmental Management

Indianapolis, IN 46206-2251

A transcript ofthe hearing and all written submissions provided at the public

hearing shall be open to public inspection at IDEM and copies may be made available to

any person upon payment ofreproduction costs. Any person heard or represented at the

hearing or requesting notice shall be given written notice of actions resulting from the

hearing.

For additional information contact Ms. Pat Daniel, at the Indiana Department of

Environmental Management, Air Programs Branch, Office ofAir Quality, Room 1001,

Indiana Government Center North, 100 North Senate Avenue, Indianapolis or call (317)

233-0429 or (800) 451-6027 ext. 3-0429 (in Indiana).

************************************************************************

Individuals requiring reasonable accommodationsfor participation in this hearing

should contact the IDEMAmericans with Disabilities Act (ADA) coordinator at:

Attn: ADA Coordinator

Indiana Department ofEnvironmental Management - Mail Code 50-10

100 North Senate Avenue

Indianapolis, IN 46204-2251

Or call (317) 233-1785 (voice) or (317) 232-6565 (TDD). Please provide a minimum of

72 hours notification.

G-3
COMPUTATION OF CHARGES

73.00

lines,

2 146.00

columns wide equals equivalent

lines at :.~.~.~.Q cents per line $ ~.?:.g} .

containing rule or tabular work

Charge for extra proofs of publication ($1.00 for each proof in excess of two)

TOTAL AMOUNT OF CLAIM

48.03

$ ,

DATA FOR COMPUTING COST

Width of single column 6.8 ems

Size of type 5.5 point

Number of insertions 1

Pursuant to the provisions and penalties of Ch. 155, Acts 1953,

I hereby certify that the foregoing account is just and correct, that the amount claimed is legally due, after allowing all just credits, and th,

PUBLISHER'S AFFIDAVIT

newspaper of general circulation printed and published in the English language in the city (

. JY!~~.~~~~y.~~~~ in state and coun1

Personally appeared before me a notary public in and for said county and state, th

MARIBEL DELBREY

undersigned wh(

being duly sworn, says that he/she is J:l.~~~.~ GJ-!~R:r;: ..

of the P.9~!~!~.1.~!-:'.~!; a ~~.I.~X ..

May II, 2008

SS State of Indiana

Lake County

My commission expires

aforesaid, and that the printed matter attached hereto is a true copy, which was duly publishe

in said paper for :L time , the dates of publication being as follow~

REDESIGNATION PETITION ......................................................0····················································· .

1!.??······..·I7?~··.LQu~7 · Subwibed aod ,wom to befo'".~~t~i':(J~L~~

Notary Public

Or- 20 .

Individuals requiring reasonable accomlY,lodations for participa~

tion in this hearing should contact the IDEM Americans with Disa~

bjlities Act (ADA) coordinator at:

Attn: ADA Coordina~or

Indiana Department of Environmental MaQagement

Mail Code 50~ 10

100 North Senate-Avenue

I Indianapolis. IN 46204-2251

,Or ca,1I (317) 233-1785 (voice) or (317) 232"6565 (TOD)-. Please Iprovide a minimum of 72 hours notificatio!1. .

no part of the same has been paid

/"?- ;3;- ~~~~ ~~~J2~,:::::::::~~"""'";;2'8"

, Redesignation Petition and Mainte~ancePlan

.. tn association with the Annual Standard for Fine Particulate Matter

(PM2:Sl

lake and Porter Cou'nties. Indiana

Notice is herE;by given under 40 CFR 51.102 that the Indiana De-

,partment of Environmental Management (IDEM) MIl hold· a public

;hearing on February 27, 2008. The purpose of this hearing is to

receive public comment on the Draft Redesignation' Petition and

Maintenance Plan in Association with the Annual Standard for

F.ine Particulate Matter (PM2.S), for Lake and Porter CountIes, In- diana.:ni"e meeting'will convene at 6:00 p.m. (loq31 time) in the

Multi-Purpose Room #C125, at Ivy Tech Community College -

Gary Campus, located at 1440 East 35th AvenUE;!, Gary, Indiana.

The· Multi-Purpose Room is located il") the ·Iower level of the Busjness~ Science and Administration.building. All· interested persor.s. are invited 'and will be given opportunity to eXpress their views' ..

· concerning th"e·draftdolZuments.

This Redesignation Petition an~ Maintenance Plan is being drafted

and submittea ,consistent with United States Environmental Pro":

tection Agency·(U.S. EPA) gUidance.

Copies of the draft documents will be 'availab~e on or before Janu,-

: ary 28;,2008 to any person upon reQuest and at the following

locqtions: ..

• Indiana Department of Environmental Management, Office of Air Quality, Indiana Government Center North, '100 North S,enate,

·RooiTI..f~1l003, .Indlanapolis, Indiana.

• India.na Department of Environmental Management, Northwest

Regional,9ffice, 8315 Virginia Stre~t, Suite 1, Merrillville, Indiana.

·.Crolf(n P.Qlnt CommunitY J..ibrary, 214' South Court Street, Crown Point, Indiana.

• Valparaiso· Public Ubrary,. 103 Jefferson Street, Valparaiso,

Indiana.

: • Gary Public Library, 220 West 5th Avenue, Gary, IndiaAa.

• Hammond Public Ubrary, 564 State Street, Hammond, Indiana.

• Whiting PUblic Library, 1735 Oliver street, Whiting, Indiana.

Oral statements will be heard, but for the accuracy of the record,

statements should be submitted i'n writing. Written statements

may be, subl!lltted to the attendant designated to'receive writ;ten

comments at the public hearing.

· IDEM will also accept written comments through March 11, 2008.

· Mailed comments should be addressed to:

·' . Lake a::d:~~~~~:~r:~~~ti~::~;~~~:~:a~::~~J~~2.5) Scott Delohey, Chief

Programs Branch

Offic;e.of Air Quaiity MC 61-50

. 100 North Semite Avenue

Indiana Department of Environmental Management

fndianapolis, IN 46206-2251

A transcript of the hearing and all written submission.s provided at the public hearing shall be open to public inspection at IDEM

a!1d copies may be mad~' available to ~ny person upon payment

of reproduction costs. Any person heard or represented at the

hearing or requesting notice shall be given written notice of ac- tions, resulting fro'm the hearing.

, For. additional information contact Ms. Pat Daniel, at the Indiana

Departmen,t of EnVironmental Management, Air Programs

Branch, Office of Air Quality, Room 1001, .Indiana Government

: Center North, 100 North Senate Avenue, Indianapolis or call (317)

, 233-0429 or (~OO) 451~6027 ext. 3-0429 (in IndianaJ. .

*******************.**....*******...*****************>l<*
I·Orrll neSCnne{1 l)Y :':llatc ljoara tl! Accounts

IND DEPT OF ENVIRONMENTAL MGMT

MARlON COUNTY, INDIANA

81956-5111344 (Jeneral Form No. 99 P (Re\' 1(87)

To: INDIANAPOLIS NEWSPAPERS

307 N PENNSYLVANIA ST - PO BOX 145

INDIANAPOLIS, IN 46206-0145

PUBLISHER'S CLAIM

LINE COUNT

Display Matter - (Must not exceed two actual lines, neither of which

shall total more than four solid lines ofthe type in which the body

of the advertisement is set). Number of equivalent lines

Head - Number of lines

Body - Number of lines

Tail - Number of lines

Total number of lines in notice

COMPUTATION OF CHARGES

135.0 lines -.-L.Q columns wide equals 135.0 equivalent

lines at .393 cents per line

Additional charge for notices containing rule and figure work (50 per cent of

above amount)

Charges for extra proofs of publication ($1.00 for each proof in excess of two)

T@TAL AMOUNT OF CLAIM

DATA FOR COMPUTING COST

RECEIVED -STATEGFlfij]jji\-Nif- ..

JAN 3 I 2008

DEPARTMENTOF EllVIRONMENTAl MANAGEMEUT '-- OF__FIC;.;.E..:.;OF AIR QUALITY

$---~

$---~

$----'--

$ -".0"'0'-

$._--~

$----'--

$---~

$--~-

$---~

$__~5,-,,3~.0=6

$ -".0""0'-

Width ofsingle column 7.83 ems

Number of insertions --LQ

Size of type 5.7 point $----'-- $--~-

$__~5,",3c.>.0",-6

Pursuant to the provisions and penalties ofChapter 155, Acts of1953,

I hereby certify that the foregoing account is just and correct, that the amount claimed is legally due, after

allowing all just credits, and that no part ofthe same has been paid.

DATE: 01128/2008

81956-51l13't4 PUBLISHER'S AFFIDAVIT

State of Indiana SS:

MARION County

Personally appeared before me, a notary public in and for said county and state,

the undersigned Karen Mullins who, being duly sworn, says that SHE is clerk

ofthe INDIANAPOLIS NEWSPAPERS a DAILY STAR newspaper of general circulation

printed and published in the English language in the city of INDIANAPOLIS in state

and county aforesaid, and that the printed matter attached hereto is a true copy,

which was duly published in said paper for "1 time(s), between the dates of:

oI128/2008 and 0I/28/2008

Subscribed and sworn to before me on OIl28/2008

S=~h!-~ Notary Public

STATE PRESCRIBED FORMULA

FOIlTI 65-REV 1-88 My commissiop·expires·· ~t_..:·"UJn··=:!H.=·l.I'·~..J.i·~,lU~iliPitll!>'..L': Ifl~_S

Susan Ketchem N9!a~.lj{~tilt~,.qWndiana

Mi'E!Mu'iiiASI6Ji<.E!lC/f.'05i06/2011

7.83 PICA COLUMN - 94 POINT

94 POINTS / 5.7 PT. TYPE - 16.49

16.49 EMS / 250 - .06596 SQUARES

.06596 SQUARES x $5.14 - .339 CENTS PER LINE

PUBLISHED 1 TIME = .339

PUBLISHED 2 TIMES= .509

PUBLISHED 3 TIMES= .679

PUBLISHED 4 TIMES= .848
81956-5111344 PUBLISHER'S AFFIDAVIT

Subscribed and sworn to before me on 01/28/2008

PUBLISHED 1 TIME = .33>

PUBLISHED 2 TIMES= .50

PUBLISHED 3 TIMES= .67'

PUBLISHED 4 TIMES= .84

1 time(s), between the dates of:

SS:

which was duly published in said paper for

Personally appeared before me, a notary public in and for said county and state,

printed and published in the English language in the city oflNDIANAPOLlS in stat!.

State ofIndiana

MARION County

and county aforesaid, and that the printed matter attached hereto is a true copy,

thellnclersi~neDJ(llre_nMl!.IJlll~\YQQ,Qt;:lngJ:lJ1JySW_Qrn, says thatSHE-is clerk .

ofthe INDIANAPOLIS NEWSPAPERS a DAILY STAR newspaper of general circl

01128/2008 and 01128/2008

My commission expires: -f__"........u...:.L.:.JI........u:u.......:l......=.I.o-"__
Form Presqlibed by State Board of Accounts ',\

,/r)i~ /L-1

(Governmental Unit)

___ -,L",a""k",,e,,--_~ County, Indiana

General Form No. 99P (Revised 1995)

To: Northwest Indiana Newspapers

60l-45th Avenue, Munster, IN 46321

PUBLISHER'S CLAIM

LINE

Display Matter (Must not exceed two actual lines, neither of which shall total more

, that four solid lines of type in which the body of the advertisement is set) -- number

of equivalent lines '

Head -- number of lines

BOdy'-- number of lines

Tp;il-- nUmber oflines

Total humber of lines in notice

COMPUTATION OF CHARGES

/LICYrn~s columns Wide equafsI Ll0 equivalent lines at d1&ents p~rline

AdclitiQIl.al charge fornbtices containing rule or tabular work

, (50 percent of abOve amount), ", ,',

Charge for extra proofs of p\.l.blica,tion ($1.00 for each proof in excess of two)

TOTAL'AMOUNT OF CLAIM'

,DATA FOR COMPUTING COST

WIdth of single column 604 ems'

Number ofinsertio,tis -;..;.. ,

SizeOftype 5.5poiht '

/'/ '>' ,/"

P1'.1rsuaht to ,the, provisiQnSand'penalties'of' Oha;-piE)rJi5,5. 'Acts 1953, '".: - .. , - .'--. -~.. // (;.';"

$ ,2./;', 72

«J-.1.dtLVc.f

/I).()()

, $5/"7)

,-;1. . jei) C/ 7d/'J

I. h,ereby cer:tify that the foregoing account is jtlst and correct, that the amount claimed is legally due,

i;!.,fteralloWing all just credits, and that rio part of the sam~Lhas be~n,-paid.

" " ',' j ,,-' '~~-~:~~~~._,

Pate: 'c~tj;'r7 91(, 2dC22:" Title: / Legp;lClerk

PUBLISHER'S AFFIDAVIT

State of Indiana )

) ss:

Lake, "County)

rk~sJ~:ll~l:h!:aL1d;~~\r~::z~~~li:e::ga::l;o:;::,ci:::~t::~s::t:,~ , " " . /

, LegalClerk of tl).eTIMES newspaper of general Circulation

printEtd,ahd published in the Ehglish language in the (city) (tiYwn) of MllIl.ster ' ~""" ":,'" __.::..1,.',' _:' <.:<", __ ,_ ,,:', _ ,',' .,' ,', - . ,', " :' . _:':. "; ,i.:........ '-:_ ,"

:::1n, th~.~tate£l,ndcounty aforesaid, and that the printed matter attached hereto is

, ~r\1i;~€)~y;WhiChwaSdUIY: publiShed in said paper for2..tiirie---£,·th~"dates

'O(PW~~:~:~~::~::?~e t~~it;;rt·;~6~ "',", -~
/l)[~1 (Governmental Unit)

_______~L""a""k"'e"'___ County, Indiana

To: _·-"N~0~r!::t!o!h~wt!!..s:e2st~I±!n",d~ia~n~a~N~ew~s~p~a",p<.>e",r-"s _

601-45th Avenue, Munster, IN 46321

$ Lj/. 7 ')

@...pd~.;L(

/O·()()

~/. 7)

-/(X) C! 7ell/

JAN 0 1 2008

InEPARTMEllT OF ElWlRONMEtlTAl MAtlAGEMEtlT ! OFFICE OF AIR QUAUlY ,

PUBLISHER'S CLAIM

L .. ;)9 f

wide equals I -10 eqUivalent lines at . £.bents per line

lS in notice

es

es

Imn 6.4 ems

1S -Int

NG COST

r OF CLAIM

Indiana Departrrentol

Environmental Management.

Northwest Regional Office,

8315VirginiaSlreet, Suite, 1.

Merrillville,lndiana,

Crown Point community

Library.

214 South Court Street.

Crown Poinl. Indiana.

Notice is hereby given under

40 CFR 51.102 lhat the Indiana Departmenl of Environmental Management (IDEM)

H ~~~r~~~ ~7,Pu;~~B.hef~~gp~; pose of lhis hearing IS 10 receive pUblic comment on the

Draft Redesignation Petition

and Maintenance Plan in Association with the Annual Standard-lor Fine Particulate Matler

(PM2.5l, lor Lake and Porter

CounHes. Indiana. The meeting

will convene at 6:00 p.m. (Ioc,!!

lime) in !he Mulli-Purpos~

Room #CT25. at Ivy Tecb.

Community 1",;(.11''''\:1'' • Gary

Campus, located al 144q East ... _~_RGES

~~;~~\~iJ:;10:,I~Z~ istralion buildil,g. All Inl~~r~sted

persons are invil€d and Will be

r~~~~ ~i~~~osrtun~~ncl~ni:;pr~~~ 1DS

drattdocumenls. .. '\

,"~~,~~:::.::a;\~~ ;:.~~:~~ r notices containing rule or tabular work drafted and submilted C(1~SISt-

~n~n":~tr U~i:~~~:~~es E;;:~~; amount) (U.S. EPA) guidance.

w;~O£:'~~~;::~,~'~~ d~~U~~~;: )ofs of publication ($1. 00 for each proof in excess of two) January 28. 2008 10 any per·

son upon request and at the

lo\lowinglocations'

Indiana Department of

Environmenlal Managemenl.

Ol1ke 01 Air Qoality. Indiana

Government Center North, 100

NOM Senate, Room N1003.

Indianapolis, Indiana.

LIJI

Title: L=e='go<.:a=l'-C;::.;l:.:e=rk::.:- _

PUBLISHER'S AFFIDAVIT

ss:

ry . /;::> lJotar~ Publlc

My commission expires: ---'l>..U-7Z\-d~-nu....JL1_.L/_..:'<O:::.....LI -"C).d..JO~/...:o.,><J-,l..-_

::P<".~ Subscribed and sworn to before me thi~;' (}--td-/l , 20 <2...J?./

,20Ug

Personally appeare a llOtary public in and for said county an~tate,

the undersigned 2..--Ud:=:..!<:W-L!=r;.~!:..IU,,:=::,,~~:::::xwhO,bemg duly sworn, says that_he IS

__-=L,""e",g",a:=.l-"C~l",er",k~_ofthe__-'T""I..."M""E"'S"'- newspaper of general circulation

State of Indiana)

)

_--"L"'a""k""e'---_County)

printed and pUblished in the English language in the (city) (town) of Munster

in the st,ate and county aforesaid, and that the printed·matter attached hereto is

a true copy, which was duly published in said paper for1 time__ , the dates

of publication being:,follows: /)

\ Ia-;d j' 6 a~ ;Jt: d:{'"£/

i .

rVisions and penalties of Chapter 155, Acts 1953,

It the foregoing account is just and correct, that the amount claimed is legally due,

, credits, and that no part of the same has been paid.

d~

Valparaiso Public library.

103 Jefferson Street,

Valparaiso. Indiana.

Gary Public Library,

220 Wesl51h Avenue,

Gary. Indiana.

Hammond Public Library,

564 Slate Street,

Hammond, Indiana.

Whiting Public library.

1735 Oliv.er Streel,

Whiling, Indiana. ) (J...-

Oral statements will be heard, C> but tor the accuracy of the rec- ---

ord, statements should be submined in writing. Wrillen slatements may be submilled (0 the

allendanl designated to receive wriUen comments al the .

public hearing.

IDEM wilj also accept written

~~~8~e~~le~hr~~~~e~l~rcS~O~~ 1----------------------------------------------- be addressed to:

Lake and Porter Counties Fine

ParticulaleMaller (PM2.5)

Redesignalion Petilion and

MainlenancePlan

Scoll Deloney, ~hiel

Programs Branch

OttiC"o of Air Qualify MC 61-50

1o(fNrOl.I, Senate Avenue

1~~i.-!.'rr:!'::Dor ~rtmenl of

En~i'i','l1m-Ontd Management

Indi~jJ,apolls,l!N 46206-2251

Atranscripl of the hearjng and

all written submissions pro·

. vided al the public hearing

shall be open 10 public inspection at IDEM and copies may

be made available 10 any person upon payment of reproduction costs. Any person

heard or represented at the

hearing or requesting notice

shall be given written notice of

aclions resulting from Ihe hearing.

For additional informalion conlact Ms. Pat Daniel, at lhe Indiana Department 01 Environmental Managemenl. Air Programs Branch, Office of Air

Qualily, Room 1001. Indiana

Government Center North, 100

North Senate Avenue, Indianapolis or cafl' (317) 233-0429

or (BOO) 451·6027 ext. 3..()429

(in Indiana).

Incflviduals requ'lring reasonable accommodations for partieipalion in this hearing should

coniaci Ihe IDEM Americans

with Disabilities Act {ADA} co·

ordinalora!:

Alln: ADA Coordinator

Indiana Deparlmenl of

Environmenlal Management -

Mail Code 50-10

100 North Senate Avenue

Incfla(l,apoliS, IN 46204-2251

Or call (317} 233·17B5 (voice)

or (317) 232-6565 (TOO).

Please provide a minimum 01

72 hours notilicalion.

--_1/28 ·20047219 .._..._..
;¥/fi}Fv ' .. )

(C. '7)'/),()02

:JI DI

A~"

INDIANA DEPARTMENT ·OF ENVIRONMENTAL MANAGEMENT

PUBLIC HEARING ATTENDANCE RECORD

Page l

Title of ~ublic Hearing: F',(\) C PA liZ, T \L l... ( S i=t C I) s:: S (0, I'JATJi.)NLocation: 1UY TS' c.. t-I - (;;, A R- YDate: z../2 "f /00

LA 1(_ c; + t)C> 12... TG CO (J/\} TfE S

Pleasep~~nt all the information:

NAME ORGANIZATION! PHONE ADDRESS

COMPANY NUMBER

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/!Aj(0

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\)'1 Y-Ve~vt [~/X-rL Cvttr trf ~~1 ACi Qk 23cx:) 0 R:3'-:'i.~DC{..I) l:0[CLt f7J 20b (';'~l.f Lt(;46:2 q

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th"\;' ').{r.-C;.5 S"-{Ylfl XJ/1 j1! 1/100 ~/ C~~ q-t;JCf-05 ..- /Cafi/7/ /4&~~'/

1~;4/if/l/ I /\~2 CrL 2,t! /l1"1d/~O'1 14 Itt S?a' 2'/l/ (j~3 "2/ /(

--.¥............,-,..-. , ;lj'/ Y'3t~ /YS'/ fJ;)/" /}fle

Revised 5/16/97 iV

"
INDIANA DfPARfMENT OF ENVIRONMENTAL MANAGEMENT

Under 40CFR 51.102

A PUBLIC HEARING O~ THE MATTER OF

REDESIGNATION PETITION and MAINTENANCE PLAN

IN ASSOCIATION WITH THE ANNUAL STANDARD FOR FINE

PARTICULATE MATTER (PM2.5)

PAGE

,

" .

: -i

. ::

REPORT OF PUBLIC HEARING had in the

above-entitled matter, taken at Ivy Tech Community

Coll.ege, Gary Campus, 1440 East 35th Avenue, Gary,

Indiana, on February 27, 2008, commencing at 6:00

o'clock in the evening.

SEIDEL & SASSE

COURT REPORTERS, INC.

150 W. lincolnway, Suite 1005

Valparaiso, IN 46383

219.462.3436

-_..:.......----_._~..-.._.__._._---_._.._.-.. ---~_ _--_ _-.".__ ._.-- .•.... _.._-_._----..,...-----_....,.._-~.-_ .._.".- _ .
. I

. .J

fl

\. j

PAGE

go ahead and get started.

This is a public hearing to solely accept

comments concerning the draft redesignation petition and

maintenance plan in association with the annual fine

particulate matter standard for Lake and Porter

Counties. This hearing is being held to conform to the

provisions in 4D CFR Part 51 regarding public hearings

for state implementation plan submittals.

My name is Pat Daniel. I'm a senior

environmental manager in the planning section of the

Indiana Department of Environmental Management, Office

of Air Quality. I have been appointed to act as hearing

officer for this public hearing .. Also, here with me

from the Office of Air Quality is Scott Deloney. He is

the chief of the programs branch, also in the Office of

Air Quality.

Notice of the time and place of the hearing

was given, as provided by law, by publication in the

following newspapers: The Indianapolis Star,

Indianapolis, Indiana; The Times, Munster, Indiana; the

Post-Tribune, Merrillville, Indiana.

The purpose of this hearing'is to provide

interested persons a~ opportunity to offer comments to

the state regarding the draft redesignation petition and
PAGE

\ .

. !

(

.,

\

i

Appearance blanks have been distributed in the hearing

room for all those desiring to be shown appearing on

record in this cause. If you have not already filled

out the form, please do so and indicate if you are

appearing for yourself or on behalf of a group or

organization, and identify such group or organization.

Also, note the capacity in which you appear'; such as

attorney, officer or authorized spokesperson. Any

person who is heard or represented at this hearing or

who requests notice may be given written notice of the

final action taken on this state implementation plan

submittal. Please indicate on the appearance card if

you wish to receive this notification. When appearance

cards have been completed, they should be handed to me,

and I will include them in the official record of this

proceeding. Oral statements will be heard, but written

statements may be handed to me or mailed to the Office

of Air Quality on or before close of business on March

11th, 2008.

A written transcript of this hearing is being

made. The transcript will be open for public

inspection, and a copy of the transcript will be made

available to any person upon payment of the copying

cost. After the conclusion of this public hearing, I

.':-:-.."""====-== ==== == _=_.=..-== -=--_._.---~~_.. _-_._ -_ ~_.~--
PAGE

e comments

received at this hearing and recommending changes which

may need to be made to the document.

I would like to introduce the following

documents into the record: the notice of the public

hearing, a draft copy of the request for redesignation

petition and maintenance plan for ozone attainment - not

ozone, I'm sorry - for fine particle attainment in the

fine particle nonattainment area, Lake and Porter

Counties, supplement to Appendix A, 2007 monitoring data

technical support documentation.

Finally, I would like to briefly go over the

contents of the draft document. The most recent design

value for the area, based on 2005 through 2007 data, is

14.5 micrograms per cubic meter. This design value

represents fine particle concentrations that are below

the national ambient air quality standard, thus the area

is eligible to be redesignated to attainment under the

annual fine particle standard and classified as

maintenance.

A maintenance classification requires that

the state ensure that air quality is maintained. This

means that total emissions contributing to fine particle

concentrations cannot increase over time and that the

state maintain a permitting program that helps ensure

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PAGE,

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Environmental Management has prepared the draft

redesignation and maintenance plan for Lake and Porter

Counties consistent with U.S. EPA guidance. The draft

petition outlines a demonstration that the area has

attained the standard based on monitored concentrations

and that the reductions in monitored concentrations are

attributable to permanent and enforceable reductions in

precursor emissions, specifically reductions of oxides

of nitrogen.

Furthermore, the draft maintenance plan

outlines the following: Lake and Porter Counties do not

significantly contribute to violations outside its

portion of the nonattainment area; redesignating the

area to attainment will not adversely affect any

downwind area's ability to attain the standard; regional

precursor emissions of, oxides of nitrogen and sulfur

dioxide will continue to decline in the future; due to

existing and future emission controls, the area's air

quality is not projected to worsen, and should improve

further over time; a commitment for all existing

emission control programs to remain in place; a

commitment to revise the plan within eight years of

implementation of redesignation; a commitment to adopt

and expeditiously implement necessary corrective actions
PAGE I

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action level response is triggered by a violation of the

standard 3-year average of 15.1 micrograms per cubic

meter occurs; a mobile source budget for transportation

conformity budget.

And if I could back up just for a few

minutes, in 1997, the U.S. EPA, United States

Environmental Protection Agency, set daily and annual

standards, ambient air quality standards for fine

particles at 15 micrograms per cubic meter on an annual

basis, and at 65 micrograms per cubic meter on a 24-hour

or daily basis. Legal challenges to the new standards

for fine particles resulted in delayed implementation of

the standard until February 2001 when the Supreme Court

upheld the standards and ruled that the U.S. EPA could

proceed with implementation of the new standards.

Indiana began monitoring for fine particles in 1999.

The U.S. EPA originally designated Lake and Porter

Counties under the fine particle standards"based on 2001

through 2003 monitoring data in December 2004. The U.S.

EPA -- U.S. EPA designated areas throughout the country

as attainment, nonattainment or unclassifiable. Lake

and Porter Counties were designated nonattainment as

part of the Chicago nonattainment area. However, the

U.S. EPA withdrew a number of counties identified as
PAGE

for 2002

through 2004 prior to the effective date of

designations, which was April 5th, 2005, based on the

fact that those counties had met the standard at the

close of 2004.

Although the 2001 through 2003 design value

for the East Chicago monitoring site in Lake County

resulted in a nonattainment designation for Lake and

Porter Counties, the 2002 through 2004 monitored design

values for all monitoring sites in both Lake and Porter

Counties demonstrated attainment at the close of 2004,

and the State of Indiana requested that the counties be

classifie~ in accordance with measured air quality. The

U.S. EPA proceeded with a nonattainment designation for

Lake and Porter Counties. Since being designated

nonattainment, Lake and Porter County -- Counties have

continued to record three years of quality assured

ambient air quality monitoring data for the years 2003

through 2005, and 2004 through 2006 and now, 2005

through 2007, which demonstrates a continued compliance

with the annual fine particle standard.

This concludes my comments regarding the

draft redesignation petition and maintenance plan for

Lak~ and Porter Counties.

Before opening this hearing for public
PAGE I

c~ ...... ..ts, may I 0 ce aga n remind you that this hearing

pertains solely to the draft redesignation petition and

maintenance plan in association with the annual fine

particle standard for Lake and Porter Counties, and only

comments germane to this matter will be considered as

part of the public record. Scott and I will be

available following this hearing to address any

questions you may have that do not pertain to this

specific matter.

This hearing is now open for public -- for

public comment.

SCOTT DELONEY: I do have four cards from

individuals that indicate that they would like to speak

tonight. If during this portion of the hearing, now

th~t it is open for public comment, someone else decides

that they wish to speak, you're welcome to fill out a

card and deliver it at any time before the hearing is

closed, and Pat will make it very clear before the

hearing is, in fact, closed. Due to time constraints,

the first individual that I'm going to call is Karen ~-

is it Kroczek?

KAREN KROCZEK:· Correct. Thank you.

SCOTT DELONEY: Great. If you wouldn't mind

coming forward just a littl~ bit to make sure that the

recorder properly records your comments i.nto the public
"

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PAGE

KAREN KROCZEK: Scott, Pat, ladies and

gentlemen, I come to you this evening without the depth

of research on this topic of redesignation that I would

like to be able to bring with me, but I have had a

personal matter, a close relative who is terminal, and

so I've been dealing with thi~gs.

I really appreciate your willingness to cOme

here and listen to the public comments on this matter.

I think it's an extremely important concern to many of

us. The mission of IDEM is to encourage and aid

businesses and citizens in" protecting and improving

Indiana's environment. I would, therefore, ask how

permitting the emission of larger quantities of toxic

soot could accomplish this mission. If EPA grants your

request to increase the amount of emissions, is this

likely to support an improvement in protecting and

improving Indiana environment?

In searching for information regarding

regarding soot, I found an article from Argonne National

Laboratory, until recently, my employer, where an APS

research group describes a new technology, new in 2003,

that allows examination of the nano particles that make

up soot while it's still in ananostate, which is, of

course, way too small for U.S. Steel to see it 0 L4

-"-----"---"--"----'======~--------
PAGE 11

rgonne, warns 0

environmental and aesthetic risks of soot. Soot

particles are created when hydrocarbons are not

completely burned. That is, there's incomplete

combustion of hydrocarbons. In commercial applications,

this is often referred to as carbon black. Soot creates

health problems and may contribute to thousands of

premature deaths each year, according to the United

States Environmental Protection Agency.

Soot begins with the chemical growth of large

benzene-based hydrocarbons, and anybody who deals with

chemicals knows benzene is not something you want to

play with. It's a complex particle. Anyway, it

aggregates and merges from .5 nanometers up to 20 to 50

nanometers in diameter, at which time it coagulates and

starts causing real problems. The smaller the particle

size, the more dangerous it is, because it actually gets

into our lungs and into our bloodstream.

Health effects that are noted by Argonne from

soot, particularly fine particles, include increased

respiratory symptoms, such as irritation of the airways,

coughing or difficulties with breathing, decreased lung

function, aggravated asthma, development of chronic

bronchitis, irregular heartbeat, nonfatal heart attacks

and premature death in people who have heart who have
PAGE 1

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children and older adults are most likely to be affected

by particle pollution exposure. However, even if you're

healthy, you may experience temporary symptoms from

exposure to elevated levels of fine particle pollution.

I brought the Argonne report with me, and I will submit

that as part of written comment.

In terms of environmental damage, Argonne

notes that the haze that is caused by soot overlays many

of our cities and affects even our pristine national

parks. Additionally, it contributes to acidity in lakes

and streams, negative nutrient balance in coastal waters

and large river basins. It depletes soil nutrients,

damages sensitive forests and farm crops and affects the

diversity of ecosystems. It also eats up our monuments

and statues because of the acidity. Does this sound

. like something we would -~ that we would encourage in

order to assist the citizens and the businesses of

Northwest Indiana and improving our Indiana environment?

The issue, however, before us is not particle

size, and I realize that IDEM is very good at measuring

particle size and reporting out, and I'm not really

being critical of IDEM inhere. I think the real

question to be addressed here is why would we violate

the spirit of the Clean Water Act? We're not supposed
; we re suppos

PAGE 1;

etter at th s on a

___._._. ~. ..._.L--_

continuing basis. And in my relationship with IDEM

workers in the past, I have found them very supportive

of the idea that we should get cleaner; we should

provide a better environment for our children and for

ourselves.

Successful businesses, in my experience,

especially when they are in an environment where

penalties are levied and exercised for squandering the

public resources of water, air and soil, successful

businesses push hard to manage waste, both for the sakes

of their bottom line; wasting is -- is not making good

use of your resources, and also, that for the

preservation of that which makes commerce possible.

Squandering your resources, whether they're people or

your environment, and you are going to screw up your

business in the long term. To increase the level of

pollution of soot -- of soot is to permit -- to promote

inefficiency in the face of existing technologies that

allows complete combustion, and it's also postponing the

day of reckoning for legacy waste cleanup. Have we not

learned anything from the clean -- cleanup of U.S.

Steel 's ch~nnel? Pay me now or pay m~ later, but if you

pay me later, you're going to have to pay more, and it's

our grandchildren that we will be paying this bill. And
, your c dren and mine, and my

PAGE 1

{. "

grandchildren will be breathing air that is purposefully

dirtier than it needs to be.

Please, listen to your public. Do the right

thing. Establish and enforce laws and regulations that

promote parsimony, good stewardship, health, wealth and

competitiveness. Indiana is part of the rust belt. I'm

very concerned about jobs. But if I were a green

employer, I would not want to come near a place that is

belching soot, and polluting the water, and leading to a

general degradation of our environment. Indiana can be

green, and both her environment and her economy can

thrive.

Thank you very much.

SCOTT DELONEY: Thank you. If I understood,

Ms. Kroczek, you did have written comments that you

wanted to be part of the record, too; is that correct?

KAREN KROCZEK: I do.

SCOTT DELONEY: All right. Next person, Mark

Coleman.

MARK COLEMAN: I'll just go ahead and stand

up and talk so everybody can hear.

My name's Mark Coleman. I live in Ogden

Dunes, Porter County, Indiana. I've been a resident for

ten years in Nofthwest Indiana, and I am speaking
PAGE 1·

against the designation or redesignating Lake and Porter

County to attainment status. It is unreasonable and

illogical to designate Lake and Porter Counties in

attainment. Just a few short months ago, our area was

designated as the worst and most unhealthy place to live

by at least two national -- nationally distributed

magazines. This is the world's perception of our area.

The methods the state uses to determine

attainment are flawed. The Congress of the United

States has already spoken out unanimously against

Indiana's flawed environmental policies. They voted 387

to 26 for a resolution to stop a permit issued by the

state to BP for which would -- a permit which would

allow more pollution into Lake Michigan. Studies show

that states with stronger environmental policies

consistently outperform the weaker environmental states

on all economic measures, This is th~ conclusion of

Professor Steven Meyer of MIT. Another study was done

by the Southern Studies in North Carolina, and they

determined that states with the best environmental

records also offer the best job opportunities in climate

for long-term economic development.

It it appears the reason that you want to

redesignate Lake and Porter Counties to attainment

status is to. according to the newspapers, make it okay
PAGE 1

sses an add more

pollution to our -- our already polluted air. And

this -- this is a flawed logic. If the only reason to

change the designation is to open the door for more

pollution, it makes more sense just to keep the

nonattainment status intact and then make sure that no

more pollution comes in. I mean what we need to do is

attract clean industry.

There's -- I went to the auto show, and I

talked to one of the representatives -- representatives

there, and he said that the only reason that fuel sales

technology hasn't been widely distributed is because the

oil lobbyists are preventing the technology from being

widely distributed, and the biggest expansion that we're

talking about in Northwest Indiana is going to be the --

the BP expansion. They want to increase their

pollution, as far as we know, 40 percent more, you know,

even before they begin operations, so they're telling us

they want to put 40 percent more pollution into our

already brown skies. There's other industries we can

develop here that will provide just as good of jobs for

a far longer period of time. We need sustainable -- a

need a sustainable economy; we need a sustai~able

environment. They have to work holistically together,

and the only way we're going to get there is ·if we start
y now.

PAGE 11

years own the

road. We have to start now. In 50 years, we'll be

doing great if we start now, so that's what we have to

do.

And that's all I have to say. Thanks.

SCOTT DELONEY: Thank you, Mr. Coleman.

The next individual I have is Ms. Lisa

George?

LISA GEORGE: Hi. I'm representing all the

people that breathe in Lake and Porter County. Just a

few things. I don't understand why, and the

hopefully, somebody from IDEM can answer the question:

Why do we need to redesignate to pollute more? Why

couldn't we just shift the amount of pollution? If you

want new companies to come in and to be able to pollute,

why can't you take some of the allocation that you have

from U.S. Steel and other polluters, or even smaller

companies, reduce the amount that they can pollute so

that the new businesses can pollute? That's my

question.

SCOTT DELONEY: I'd be more than happy to

answer that. What I would like to do is defer back to

the opening remarks that Pat had made with regard to

what does it mean to be classified as maintenance.

Basically, the state implementation plan that we have on
PAGE 1"

we are soliciting comments

for is a document of two main components. The first

component is a demonstration showing that since 2003,

measured air quality, based on the Federal Health Based

Standard for fine particles has been complied by all

monitors measuring fine particle concentrations within

both Lake and Porter Counties. And that's based on that

fact that the area's eligible for its air quality status

to be recognized for measuring air quality that meets

that standard. In other words, consistent with all

other counties in the country that measure air quality

that meets the standard, we would like for Lake and

Porter Counties to be recognized the same way.

The second component is what's referred to as

a maintenance plan, okay? So we refer to being

redesignated from non~ttainment to attainment and

classified to maintenance. What being classified as

maintenance means is that the state actually has an

obligation, under the Clean Air Act, to ensure that air

quality is maintained. The state, by federal approval

of its plan, is obligated by law to ensure that we do

not re-violate the air quality standard. We have to

ensure that there's no backsliding with regard to

measured air quality, and the precursor emissions that

contribute to fine particle concentrations cannot

_0, __" _
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PAGE 1:

increase over time. So in all of the actions that the

department does within the Office of Air Quality by

approving a maintenance plan, we are locking ourselves

into a contract with the federal government that

prohibits us from allowing emissions to grow over time,

next year, the year, after all the way out to the year

2020.

Eight years from now, we are required by law

to update that plan and to extend that horizon for ten

more years. Eight years from now, we will be in -- we

would be in Lake County again, basically committing to

take the same action all the way out to the year 2030.

So actually, being redesignated to attainment and

classified as maintenance really does provide the same

limitations with regard to growth in emissions or

worsening in air quality that being designated

nonattainment does. One of the key differences that I'd

like to point out is, is that being designated

nonattainment right now, if we measure air quality that

doesn't meet the standard today, we aren't committed to

taking any sort of action. As a maintenance area, if

we're redesignated and classified as maintenance, if we

violate the standard this year, we are committed

under by federal law, by approving that maintenance

plan, to take swift action in order to reverse that
PAGE l'

and address it with whatever action is necessary

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at the state level to ensure that air quality is

reattained as expeditiously as practicable. That means

that we can't drag our feet.

So in reality, a maintenance classification

provides much greater obligation to the State of Indiana

to ensure that air quality is not just protected, but

that all action is taken to ensure that it's maintained

over time. In this instance, the plan that we have

presented is to ensure that it's maintained all the way

to the year 2020. Within this plan, we also commit

eight years from now to extend that horizon to ensure

that it's protected all the way to the year 2030.

Does that help at all?

LISA GEORGE: So what you're saying is the

level of pollution 'will not get any worse than it is

right today, is what you're saying?

SCOTT DELONEY: That is what we are

committing to as part of our plan; that is correct. And

I don't want to get overly technical, so if anybody

wants a more detailed explanation, we're here as long as

you would like for us to stay here this evening, but one

of the things that we're required to do as part of this

plan is establish a base here. We established the year

2005, because at the time that this was originally
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PAGE 21

drafted, 2006 was the most recent complete monitoring

year complete. That meant that the three-year average

at the close of 2006 was 2004 through 2006. The year

straddled in the middle is 2005. So if we're going to

compare what air quality was like to the time period in

which we measured air quality, we chose 2005 as being

the representative year, because it was in the center of

the period in which -- most recent period in which we

measured air quality that met the standard. So we

compare 2005 with previous years to determine this

improvement in air quality; is it due to decreased

emissions. We made that determination. Then when we're

looking at are we going to be able to continue

maintenance, we compare 2005 with 2010, and we compare

it with 2020 to take a look at a snapshot in time are we

going to be on this same path as we proceed down the

road. And we did, in fact, make that determination. We

also demonstrated that that would, in fact, occur based

on chemical modeling that's done in conjunction with our

neighboring states with the Lake Michigan Air Directors

Consortium.

Now, every year we develop an emissions

inventory and we collect emissions from all permitted

sources within the state. That is our way of tracking

are we maintaining this course. Then once every three
PAGE 2

emissions inventory

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based on data associated with our permitted entities as

well as for mobile sources, automobiles, trucks;

off-road sources like agrjcultural equipment; railroads;

biogenic emissions that are emitted naturally from

trees, and plants and other vegetation. That

comprehensive inventory, we're obligated to develop and

commit to the U.S. EPA for review and approval once

every three years. Once that's complete, we're

comparing it to the previous three years to determine

have we seen any sort of increase that would trigger our

maintenance plan to take any sort of action to make sure

that what we're committing to is maintained.

So yes, in short, the answer to your question

is, yes, we -- we are obligated to ensure that increased

pollution associated with fine particles does not occur.

LISA GEORGE: So it wouldn't get any worse.

SCOTT DELONEY: Correct.

LISA GEORGE: Okay.

SCOTT DELONEY: And the demonstration that we

have made is that it will be even b~tter, because the

improvements that we have seen today are based on

control measures that have been implemented today. Some

of the biggest control measures to ever be implemented

to address soot, fine particles, particulate matter
PAGE 2~

n beginning next year. That's the Clean

,

Air Interstate Rule that affects all midwest states and

a number of states to the east and northeast. That is

going to substantially decrease emissions from coke and

major coal combustion sources that contribute to fine

particle concentrations. So one of the largest

improvements in fine particles across the midwest that

we're going to be seeing are going to come from this

Clean Air Interstate Rule, which th~ effective date of

that is January of 2009. So not only are we already

measuring air quality that meets the standard; some of

the bi ggest control measures to be i mpl emente-d-~t.y.o----

further address fine particles kick in in the near

future, so we are going to see even further improvements

over time. That's reflected in modeling that the U.S.

EPA did, association associated with their rules, and

it is also reflected in the modeling that we hav~

conducted in conjunction with our neighboring states.

LISA GEORGE: And if you do not if it is

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not redesignated as attainment status, the pollution

won't get -- I mean there won't be less pollution?

Why -- why the change? I mean if it's been getting,

better, why do you .have to change the designation?

SCOTT DELONEY: The reason that the

designation 'is -- is it an absolute necessity to
;.

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PAGE 2:

e area? No. But the state has to submit

a state implementation plan to the U.S. EPA in

conjunction with its designation as a nonattainment

area. We have two choices. We either submit a

demonstration as to how the area is going to attain the

standard by its deadline, or we submit a SIP

demonstrating that it's already complied with the

standard based on measured air quality. Well, it

doesn't make a lot of sense for us to submit a state

implementation plan to EPA to comply with the Clean Air

Act mandate that is theoretical in nature that says,

well, this is how we're going to meet the standard when

we already have measured air quality that demonstrates

we've met the standard. So we have to decide which path

are we going to take in order to submit a SIP within

three years of the designation that demonstrates that

the area will comply with the standard that it's been in

compliance with since 2ob3. So this is the form of the

state implementation plan that we decided to submit.

LISA GEORGE: Thank you.

SCOTT DELONEY:· You're welcome.

LISA GEORGE: Who does the testing?

SCOTT DELONEY: The Depart~ent of

Enviro~mental Management conducts the air quality

monitoring for the area; however, that is overseen by
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PAGE 2·

the United States Environmental Protection Agency.

Ma'am, did you have something that was

pressing?

KARIN KIRULAS: I just have a question on

that, though. Let's say that you find that the

particles are more than they should be. What

specifically do you do? Do you tell U.S. Steel to, you

know, shut down for a coupl~ weeks, or I mean --

SCOTT DELONEY: Okay. I can -- I can answer

that question. Is it -- is it okay if I go ahead and

answer that question?

LISA GEORGE: Yes. Yeah, yeah.

SCOTT DELONEY: Okay. Part of the

maintenance plan, if EPA approves the maintenance plan

for this area and federal action would then be taken,

EPA would propose to improve the plan; they would

solicit public comment. Based on that comment, they

would decide whether to approve it. If they approve the

plan, it becomes effective. Now, that's like a contract

with the state in terms of what it is that we're

required to do associated with that maintenance

classification.

The maintenance plan contains two triggers

which Pat had referred to. One of those triggers is

what's teferred to as -- as a warning -- or action level
PAGE 2

erefore, if we were to measure air quality

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that no longer meets the standard, we ar€ required to

first conduct a detailed study to determine was this, in

fact, a violation of the standard, why did the violation

occur, what contributed to this violation occurring, and

we have to take swift regulatory action to ensure that

the area complies with the standard within a time frame

that the U.S. EPA determines to be based on as

expeditious as practicable. That doesn't mean we have

three years. It doesn't mean that we have five years

from the date of a redes -- of a designation like we

have with the original designation, nonattainment

designation. That means that we have to demonstrate

that we are taking swift action to ensure that the

control measures necessary to reattain the standard are

implemented as quickly as possible. So ~hat is what we

have to do.

Now, in making.that determination, when I

mentioned that we conduct a study to determine how it is

that we re-violated, why we re-violated, part of that is

. to determine what is it -- what regulatory effort is

necessary on our part in ord~r to reattain compliance

with the standard. What that regulatory effort will

consist of is impossible to identify at this point in

time. The reason is, is that number one, we don't
PAGE 2

anticipate re-violating the standard. Number two, if it

wer~ unexpectedly to occur in the future, it could occur

17 years from now. Well, 17 years from now, we don't

know what type of control mechanism would be most cost

effective in order to address the standard. Automobiles

continue to improve, controls for industries, fuels --

fuel oils, coal, everything is getting -- the technology

in operation efficiencies and improvements are in

increasing over time.· So it's -- I can't say what

action we would take, although our plan lies lays out

a series of exampled control mechanisms that we would

consider at that point in time if unexpectedly, we were

required to look at it.

However, we make it very clear we would work

with the community, meaning all of those that are

interested in participating in this meeting tonight help

us to determine what would be most effective, what would

be most timely, most cost effective and most desirable

on behalf of the community for us to proceed with in

order to reverse that trend.

I'm sorry, Ms. George. Did you have further

comments or questions?

LISA GEORGE: Just another comment is that I

don't -- I don't trust the numbers that you guys have.

r live here, I breathe the air, I smell it. I don't
PAGE 2

y, no matter what your numbers say, no

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matter what EPA says. There are too many people I know

dying of cancer that it's just not -- I mean it's a hot

spot for cancer here, and there's a reason why.

SCOTT DELONEY: Thank you. And that does --

that wraps up your comments?

LISA GEORGE: Uh-huh.

SCOTT DELONEY: Okay. Thank you. The

next -- and, ma'am, did you have any other comments?

I'm sorry. We do need your name to make sure that --

KAREN KIRULAS: Karen, K-a-r-i-n

K-i-r-u-l-a-s.

SCOTT DELONEY: Thank you. And then the last

comment card I have this evening is Mr. Mark Strimbu?

MARK STRIMBU: I just have a couple of

general comments related to the documents that you have

and -- or matters of maybe seeking some clarification in

your --

SCOTT DELONEY: If you wouldn't mind maybe

just sitting at the front table for a moment; that way

she'll be able to make sure that your comments are

entered properly.

MARK STRIMBU: As I"stated, these are

basically td assist IDEM with maybe making some

clarifications in their documents as they move forward
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PAGE 2~

in their edits and revisions to it. The first comment I

have is on Page 7, where it refers to the design value.

It's at the top of the page. It refers to the air

quality and design value for the area is the highest,

the design value among all sites in the area. I think

that might stand some clarifications to it if you're

talking about if that is Lake and Porter County only

since we're addressing specifically Lake and Porter

County as opposed to the entire area that's shown in

Figure 3.1?

SCOTT DELONEY: That is correct. It is

solely representative of Lake and Porter Counties.

MARK STRIMBU: Okay. And on page -- on

Page 23, Section 3.4 where it talks about quality

assurance, it says IDEM's quality assured all data shown

in the tables above. One of the tables above shows

information from out-or-state monitors. I was just

wondering if that statement is correct that you have

gone through and quality assured the other states' data,

or whether it's more like I would suspect, that you're

responsible for your own data in the State of Indiana,

so a clarification.·

SCOTT DELONEY: We can provide that

clarification, and of course, then U.S. EPA, it says

then quality assuring that for us as well as what's
PAGE 2

er states, but, yes, thank you; we'll

provide that clarification.

MARK STRIMBU: And that's the extent of my

comments.

SCOTT DELONEY: Okay. Thank you. Anybody

else wish to speak? Sir?

JIM ALEXANDER: I didn't fill out a card.

SCOTT DELONEY: That's okay. If you can just

make sure that the recorder gets your name.

JIM ALEXANDER: Yeah, My name is Jim

Alexander, and I'm the air compliance manager, U.S.

Steel, Gary Works, and I just want to make a couple

comments, maybe -- maybe to you since you mentioned our

company.

Maybe a good corollary might be the course

particulate matter regulations, PM10. You know, the

courser particles have been regulated for a while,

which we are in attainment of. There's maintenance

plans in place that if our company is found culpable in

. exceed~nce of that i we have to submit a 25 percent

source wide reduction of our particulate matter within

180 days. So kind of in answer to your question, the

answer to your question is -- is yes.

KARIN KIRULAS: But 180 days to be over

polluting is --
i

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PAGE 31

JIM ALEXANDER: No. We're talking about a

violation of the standard.

KARIN KIRULAS: But I mean -- but even still,

what you're telling us is that -- is that, you know,

we'll have a commission, and we'll look at it and, you

know, within three years, we'll almost -- we'll have an

answer. Well, this is --

JIM ALEXANDER: We're not talking three

years; we're talking 180 days.

KARIN KIRULAS: It's still a long time.

JIM ALEXANDER: And the rule states that

those will be written into our permit, so those are

permanent reductions. Now, what you're talking about is

overpolluting and causing an episode in this area.

There's other rules that cover that

SCOTT DELONEY: Correct.

JIM ALEXANDER: -- okay, that calls for more

immediate action. But if we're talking about the

standard for -- for PM10 is 150. If we cause an

exceedence of that, okay, 151 and we're culpable,

there's a rule that strikes directly at -- at that

source, forces those reductions. So the position of

U.S. Steel on this is that there's regulations in place

that allow IDEM to seek attainment for counties that are

in attainment of the Clean Air Act and of the standards.
PAGE 3

review. And I

s had went through a lot of scientific

I sympathize with -- with the people

; :

i :

; i

that breathe it; it's me and my family, also, and I know

the dam~ge that it causes. But these standards were set

by scientists to designate healthy air. And then it's

IDEM's job to regulate industry and point sources, and

area sources and mobile sources to get us into

attainment. Now, we believe that 35, or in this case,

the standard 15 on an annual basis, it is too high, and

what we need to do is to get that standard lower from 15

lower. Not to attack, I believe, redesignation of the

area.

One other point I want to ~ake is that if we

do redesignate, not one limit at Gary Works is relaxed.

It doesn't allow us to pollute more. It does change, in

some cases, new 'source review for new and modified

sources, but in some cases, like Scott pointed out, it

makes it more -- more difficult for us to modify or add,

because you have to stay in attainment of the standards.

You have to do modeling. And in cases where your

modification to your source would model in exceedence,

you just can't do it. If you're nonattainment, there

..

are ways around that, because you already have dirty

air. You do have to get offsets, but sometimes offsets

are bought and not really real reductions or at least
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PAGE 3

not perceived as real. So I guess that's my comments.

I'm not really here to answer questions, but I will.

SCOTT DELONEY: Mr. Coleman?

MARK COLEMAN: I was just going to say it

won't all~w you to raise pollution with your existing

facility, but if you expand, you will be able to

expand --

JIM ALEXANDER: It may -- not the changes.

Not the changes when you redesignate. It does change

new source review, you know, new permitting, okay? But

in some cases, and that would be a new or modified

source out at Gary Works

MARK COLEMAN: It would allow you to

expand --

JIM ALEXANDER: No. No, it doesn't allow us

to get out of new source review. In fact, in some

cases, it makes it more stringent, because we cannot

undertake a project that would endanger attainment,

okay? If - - if 'we are in nonattainment, all we have to

do is sign offsets for those, because we already have

dirty air. So it doesn't change any limits, and it

and it doesn't get us out of new source review. It

doesn't mean we can all of a sudden start building and

polluting more. It means really just the opposite,

because if we endanger that, our project can't move
PAGE 3

ected.

1.

Okay? I'm not really the expert on it, so, you know,

I'm going to kind of stop there.

SCOTT DELONEY: I did want to' - - I di d want

to make one clarification, too, that is worthwhile.

Fine particles are -- are scientifically rather complex.

In fact, some of the top scientists across the count.ry

have been trying to get their arms around one of the

elements that Ms. Kroczek touched on, which is organic

carbon. There may -- fine particles are made up of

solids as well as liquids. There are many contributing

pollutants that -- that result in the formation, and one

of the things that's most important to understand about

fine particles as it relates to some of the concerns

we've heard tonight are that it is a regional pollutant

very similar in nature to ozone, although fine particles

are a -- based on the size of the particulate matter,

they're not at all like course particles. Course

particles do not travel far. Concentrations are usually

higher closer to where they are emitted.

Fine particles, we.monitor a network that's

located throughout the state; we have a number of what

are referred to as background monitors. So in other

words, they identify what the background concentrations

coming into counties like Lake are, representative of
PAGE 3L

be measured in Jasper or Newton Counties. On

an average, comparing our background monitors to what

we're measuring in urban areas, 97 percent of the fine

particle mass is attributed to background levels, not

based on what's being contributed by sources within the

area. What that level is referred to is urban excess,

meaning within this urban area that-we measure air

quality for, less than three percent of the total

measured fine particles are actually attributable to

emission sources within the area. That's all emission

sources: diesel engines, coal combustion,automobiles.

So with that --

MARK COLEMAN: Are these fine particles, or

what are these (indicating)?

SCOTT DELO~EY: What you're looking at there

are not necessarily fine particles.

MARK COLEMAN: Well, they go miles and miles

all the way from the southern tip of Lake Michigan; you

can see it when you're in Chicago in a high-rise; you

can see it going all the way as far as the eye can see.

So if they're not fine particles ["

I"I .

, SCOTT DELO~EY: Well, they're they're --

1-

!

what fine particles represent is microns of 2.5 in size

or less --

MARK COLEMAN: That means nothing to me.
PAGE 3

But what I did

'-".i

i

j

want to try to get at is, is that for particulate

matter, you have total suspended particulates, you have

course particulates, which are ten microns in size, and

then you have these fine particles. The fine particles

standard is just one of several criteria pollutants

defined and controlled by the Clean Air Act, okay? So

we have different standards that have to be met for

particulate matter. We have standards that have to be

met for ozone, lead, carbon monoxide, and other

pollutants. We also have air toxins and -- and

pollutants like mercury that are regulated through other

means and mechanisms as well. So when you look at what

comes out of a stack at a given industrial source,

you're looking at a complex mixture of a variety of

regulated pollutants. It's not just fine particles.

MARK COLEMAN: You mentioned the Clean Air

Act a few times, and I know the Clean Water Act had a

stipulation for eliminating all pollution going into the

water at some certain point, and I was wo~dering, is

there anything in the Clean Air Act to eliminate all

emissions to your knowledge?

SCOTT DELONEY: No. That -- that is not at

all a component of the Clean Air Act. I think that as

environmental regulators, we'd all like to strive for a
PAGE 3-

were zero, you know, emission levels are, you

know, to be achieved, but, you know, I think at the time

that the Clean Air Act was last amended by Congress in

1990, it was recognized that that's not an achievable

goal just based on the energy needs of this country

alone.

MARK COLEMAN: But it's-- it is possible.

SCOTT DELONEY: That is something that

would -- I think would be more appropriate for the U.S.

Environmental Protection Agency to respond to, because

obviously, a national control program tied to an

international control program would be necessary

especially based on, you know, the impact of transport.

With that, I did want to make sure everybody

knows Pat and I are going to remain here as long as

you'd like us to be to answer any additional questions

you have. Are there any additional questions

specifically relevant to the redesignation request and

maintenance plan? If not, I was going to turn it over

to Pat so she could close this, and we could let the

recorder head her way for the evening for other plans.

Ms. George?

LISA GEORGE: Just for the record, I want to

ma~e sure that I'm understanding this clearly and that I

have your word that the total overall emissions allowed
PAGE 3

an they

are today.

SCOTT DELONEY: Correct.

LISA GEORGE: That's correct.

SCOTT DELONEY: That is the commitment that's

made ~s part of the submittal .

MARK COLEMAN: So you're saying BP's

expansion will not increase any air pollution in Lake

and Porter County.

SCOTT DELONEY: That's not what we're saying.

What we're saying is that total emissions contributing

to fine particle concentrations will not increase. What

that means is, is that if we allow --

LISA GEORGE: Well, I don't know what fine

particles

SCOTT DELONEY: -- if we allow increases for

fine particle emission~ to occur here, we are required

to find decreases that would offset those.

KARIN KIRULAS: Decreases where?

SCOTT DELONEY: Decreases either at that

source, next to that source --

KARIN KIRULAS: But here in Lake County

still.

SCOTT DELONEY: Correct. Within the

boundaries of the defined area, which is within Lake and
PAGE 38

Porter Counties. Correct. So that the overall net

n -" T

i

.

sure it's clear we're only talking in reference to fine

particle precursors, and that is specifically oxides of

nitrogen, sulfur dioxide and direct fine particle

emissions.

KARIN KIRULAS: Well, how about the larger

particles; can they increase?

SCOTT DELONEY: Those are governed under

another plan that was approved when the area met that

standard, so there already is a maintenance plan in

place that would prohibit any growth in the course

particles for this area. We went through that process

back in the early nineties when the area was formally

redesignated under that standard after measuring air

quality that met the standard. So we've been operating

under a maintenance plan that includes that commitment

for quite some time.

PAT DANIEL: Are there any additional public

comments for the record?

KARIN KIRULAS: I just have another question.

I mean you're saying that that everything is

nothing's going to change, but then you want to increase

it as -- as a regular standard. I

SCOTT DELONEY: No. We can't -- we can't
PAGE 39

increase the standard. The federal government --

KARIN KIRUL.AS· Not thA ~t~n{i-.:""~ h"+ J ••

want to -- you want to -- wait a minute.

SCOTT DELONEY: The federal government

establishes the standard that it deems to be protective

of public health. That's 15.1. We are required to

comply with that standard. We've cbmplied with that

standard since 2003. What we're requesting is, is that

we be recognized for complying with that standard. In

approving our request, we're committing to ensure that

that standard is not exceeded again in the future, and

that emissions that would contribute to concentrations

tied to that standard do not increase over time either.

KARIN KIRULAS: Okay. Then -- then it

says -- it says here in the Post-Tribune: If EPA

accepts Indiana's petition, that could loosen emissions

restrictions on businesses that want to open or expand

in the area. Is that right; it loosens the

restrictions?

SCOTT DELONEY: No. The same restrictions

apply for a maintenance area when it comes to the state

haVing to comply with th~ air quality standards itself.

KARIN KIRULAS: So the Post Tribune got it

all wrong?

SCOTT DELONEY: I'm not sayi ng that. I'm not
PAGE 40

responsible for what you're reading. What I'm saying

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EPA is -- is setting a -- a rule that the state has to

comply to. What that rule includes is, is that, one, we

have to ensure that air quality is maintained; two, that

emissions do not increase over time, and three, if

there's an unexpected backsliding with regard to air

quality in the area, we are required to take swift

regulatory action. Now, that does not mean that the

agency cannot continue to issue permitting actions to

sources within this county. It's just that the agency

also must ensure that none of those actions result in

any net increase in emissions or would adversely affect

air quality to where we would backslide in any shape or

form.

And we -- if there are other topics that you

wish to discuss or you want clarification on, like I

said, we will remain here, but if it's okay with you, we

were planning to close the hearing, and if there's

anything else that you would like to discuss, we'll be

here as long as you would like for us to be.

PAT DANIEL: In the absence of any further

comments, these proce~dings are hereby concluded. This

hearing is adjourned.

* * * * *
PLEASE PRINT

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INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

PUBLIC HEARING COMMENT FORM

Page

Title of Public Hearing: hde.5t7't/rhi?1 !le-6i:zm eX ~I /~~;: Location: &'~y-T{/ y 7ec4 Date: Ilc267/atf i

Name: K412t1U /(;'(0 c~ Organization/Company:------------,----------...rr------

Address: R::U,A Ji(cuI/~/l mE-

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Phone Number: 2/9 £3& /?.s:/

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Ifyou would like to submit comments, please do so on thisform, or you may attach them to this document.

Revised 5/16/97 lev
Gentlemen,

deserves however I've been busy with personal matters. I appreciate your willingness to

hold a public hearing to hear our opinions regarding the air we breathe.

The mission ofIDEM is to encourage and aid businesses and citizens in protecting and

improving Indiana's environment (cite public announcement ofthis meeting).

I would therefore ask how permitting the emission oflarger quantities oftoxic soot would

accomplish this mission. IfEPA grants your request, is this not just what will happen?

In searching for information on soot, I found a recent article from Argonne National

Laboratory APS research group that describes a new technology that allows examination

ofthis material while it is in a nano state (way too small to see). This DOE facility warns

ofthe health, environmental and aesthetics risks ofsoot.

Soot particles are created when hydrocarbons are not completely burned. (incomplete

combustion) Otherwise known in commercial applications as carbon black, soot creates

health problems and may contribute to thousands ofpremature deaths each year

according to the US Environmental Protection Agency (your boss????)

Soot begins with the chemical growth oflarge benzene-based hydrocarbons which

aggregate and merge from .5 nanometers to 20 to 50 nanometeers in diameter which then

coagulate to form larger soot particles.

At ANY size, soot is problematic though it poses the greatest health risks in the range of

2.5 micrometers to 10 micrometers.

Health effects noted by Argonne from soot (particularly fine particles which can get deep

into the lungs and cause serious health problems) include:

Increased respiratory symptoms such as irritation ofthe airways, coughing or difficulty

breathing

Decreased lung function

Aggravated asthma

Development of chronic bronchitis

Irregular heartbeat

Nonfatal heart attacks and

Premature death in people with heart oflung disease

People with heart or lung diseases, children and older adults are most likely to be affected

by particle pollution exposure. However, even ifyou are healthy, you may experience

temporary symptoms from exposure to elevated levels ofparticle pollution.
I

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In tenus of environmental damage, Argonne notes the haze caused by soot which not

affects..~~~~..?tll".•.~ri~ti~~~atio~ClI JJ~~~ ....;.. ~~~;iti~~~II~~ .i!S~~tt;i~~t~§te't(;i~i~~ ..;iI1I~~s -_ ";ccand'streams;·negative""nutriellt"fra:l'ance"mcoasOOWatefsancr·1arge"nver··baslns,""oepfetes·

soil nutrients, damages sensitive forests and fann cops and affects the diversity of

ecosystems. It also eats up statutes and monuments with acidity.

Does this sound like something that would encourage and aid businesses and citizens in

protecting and improving Indiana's environment???

The issue before us is not the measurement of particle size however. The real question to

be addressed is why we would violate the spirit ofthe Clean Air Act and allow any

increase in the air pollution for this region in the name ofeconomic improvement.

Successful businesses (especially in the face ofpenalties for squandering the public

resources ofwater, earth and air) push hard to manage waste both for the sake oftheir

bottom line and for the preservation ofthat which makes commerce possible. To

increase the level ofpollution ofsoot allowed is to promote inefficiency in the face of

existing technologies that allow complete combustion and postpone the day ofreckoning

for legacy waste clean up. Haven't we learned anything from the cost of cleaning up the

US Steel channel mess? Pay me now or pay me (lots more) later. Meanwhile your

children and mine will be breathing air purposefully dirty and our public health costs will

nse.

Please gentlemen, listen to your public. Do the right thing. Establish and enforce laws

and regulations that promote parsimony, good stewardship, health, wealth and

competitiveness. Indiana can be green both in her environment and her economy.

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Frontiers Archives I Contact the Editor I[\rgonne National Laboratory

Visualizing first images of soot forming in

a flame may lead to advances in health

and in industry.

Studying soot may minimize health

hazards

Tiny soot particles, created when materials burn, create health

problems and may contribute to thousands of premature deaths each

year, according to the U.S. Environmental Protection Agen<;;y.

Researchers from Argonne and Brigham Young Univer~ have used

the Advanced Photon Source (APS) to see for the first time the birth

and growth of the tiniest soot particles in a living flame.

This work promises to contribute to a comprehensive model of how

soot forms and grows. Such a model may help to reduce the health

hazards associated with soot production, to improve the efficiency

and performance of industrial devices that rely on burning

hydrocarbons and to devise efficient production processes that use

soot, such as the industrial manufacture of carbon black.

Over the years, researchers have used a variety of techniques to

study soot particles. But until now, it has been difficult or impossible

to study the structure of particles in the 1 nanometer to 100

nanometer size range as they are formed. (A nanometeris about

1/50,000 the diameter of a human haiL) Yet this size range covers

mostof the initial formation and growth of soot particles.

Soot originates in the incomplete combustion of hydrocarbons.

Studies at other laboratories suggest that soot begins with the

chemical growth of large aromatic (benzene-based) hydrocarbons to

about 0.5 to 2 nanometers in diameter. This substrate or nucleus

grows into an elementary soot particle about 4 nanometers in

diameter and then clusters into small chains. The chains merge to

produce primary particles, 20 to 50 nanometers in diameter, that

coagUlate to form larger soot aggregates.

This formation and growth occurs as a series of chemical and

physical interactions within a flame. Thanks to the high intensity of

APS X-rays, scientists have been able to study for the first time the

initial distribution of soot particles as they form within the flames of

such fuels as toluene and hexane.

"We've been able to observe particles between 0.8 and 15

nanometers in diameter," said Argonne chemist Randall Winans.

"Thanks to the APS, we're able to observe pre-soot particles 10 times

smaller than anything previously observed with a synchrotron X-ray

source."

This research was funded by the U.S. Department of Energy's Office

of Basic Energy Sciences and was carried out at the Basic Energy

Sciences Synchrotron Radiation Center beamUne at the APS.

http://www.anl.gov/Media Center/Frontiers/2003/c4facil.html 2/21/2008
Tiny soot particles, created when materials bum, create health problems and may contribute to

thousands of premature deaths each year, according to the U.S. Environmental Protection

Agency.

Researchers from Argonne and Briqham Young University have used the Advanced Photon

Source (APS) to see for the first time the birth and growth of the tiniest soot particles in a living

flame.

This work promises to contribute to a comprehensive model of how soot forms and grows. Such a

model may help to reduce the health hazards associated with soot production, to improve the

efficiency and performance of industrial devices that rely on burning hydrocarbons and to devise

efficient production processes that use soot, such as the industrial manufacture of carbon black.

Over the years, researchers have used a variety of techniques to study soot particles. But until

now, it has been difficult or impossible to study the structure of particles in the 1 nanometer to

100 nanometer size range as they are formed. (A nanometer is about 1/50,000 the diameter of a

human hair.) Yet this size range covers most of the initial formation and growth of soot particles.

Soot originates in the incomplete combustion of hydrocarbons. Studies at other laboratories

suggest that soot begins with the chemical growth of large aromatic (benzene-based)

hydrocarbons to about 0.5 to 2 nanometers in diameter. This substrate or nucleus grows into an

elementary soot particle about 4 nanometers in diameter and then clusters into small chains. The

chains merge to produce primary particles, 20 to 50 nanometers in diameter, that coagulate to

form larger soot aggregates.

This formation and growth occurs as a series of chemical and physical interactions within a flame.

Thanks to the high intensity of APS X-rays, scientists have been able to study for the first time the

initial distribution of soot particles as they form within the flames of such fuels as toluene and

hexane.

"We've been able to observe particles between 0.8 and 15 nanometers in diameter," said

Argonne chemist Randall Winans. ~Thanks to the APS, we're able to observe pre-soot particles

10 times smaller than anything previously observed with a synchrotron X-ray source."

This research was funded by the U.S. Department of Energy's Office of Basic Energy Sciences

and was carried out at the Basic Energy Sciences SYnchrotron Radiation Center beamline at the

APS

The size ofparticles is directly linked to their potential for causing health problems.

Small particles less thanlO micrometers in diameter pose the greatest problems, because

they can get deep into your lungs, and some may even get into your bloodstream.

Exposure to such particles can affect both your lungs and your heart. Small particles of

concern include "inhalable coarse particles" (such as those found near roadways and

dusty industries), which are larger than 2.5 micrometers and smaller than 10 micrometers
in diameter; and "fine particles" (such as those found in smoke and haze), which are 2.5

micrometers in diameter and smaller.

The Clean Air Act requires EPA to set air quality standards to protect both public health

and the public welfare (e.g. crops and vegetation). Particle pollution affects both.

Health Effects

Particle pollution - especially fine particles - contains microscopic solids or liquid

droplets that are so small that they can get deep into the lungs and cause serious health

problems. Numerous scientific studies have linked particle pollution exposure to a variety

ofproblems, including:

• increased respiratory symptoms, such as irritation ofthe airways, coughing, or

difficulty breathing, for example;

• decreased lung function;

• aggravated asthma;

• development of chronic bronchitis;

• irregular heartbeat;

• nonfatal heart attacks; and

• premature death in people with heart or lung disease.

People with heart or lung diseases, children and older adults are the most likely to be'

affected by particle pollution exposure. However, even if you are healthy, you may

experience temporary symptoms from exposure to elevated levels ofparticle pollution.

For more information about asthma, visit w\vwepagov/asthma.

Environmental Effects

Visibility reduction

Fine particles (PM2.5) are the major cause ofreduced 'visibilitv (haze) in parts ofthe

United States, including many of our treasured national parks and wilderness areas. For

more information about visibility, visit ww\vepa.gov!visibilitv.

Environmental damage

Particles can be carried over long distances by wind and then settle on ground or water.

The effects ofthis settling include: making lakes and streams acidic; changing the

nutrient balance in coastal waters and large river basins; depleting the nutrients in soil;

damaging sensitive forests and farm crops; and affecting the diversity of ecosystems.

More information about the effects ofpaliicle poHution and acid rain.

Aesthetic dll11Ulge

Particle pollution can stain and damage stone and other materials, including culturally

important objects such as statues and monuments. More information about the effects of

paliicle pollution and acid rain.
You will need Adobe Acrobat Reader to view the Adobe PDF files on this page. See

tJ:'.2c_iEDF P,H!~ for more information about getting and using the free Acrobat Reader.

For more information on particle pollution, health and the environment, visit:

Pm"tide Pollution and YouLHea!th: Learn who is at risk from exposure to patiicle

pollution, what health etlects you may experience as a result of pariicle exposure, and

simple measures you can take to reduce your risk. (PDf, 2 pp, 320 KB
Page

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

PUBLIC HEARING COMMENT FORM

Title ofPublic Hearing: B:w:tICUICtitt oS)b1 teJ"-llqIi Jr,rD'1 Location: NY -teQJ Date: f 2.-1/0 i

Name: }M,D;tJrt-· C6l-e-~ Organization/Com~any: UUM.tJ N f!;eJA/&;5 .

Address: 4. LDG012 PLVvlf:-.

Revised 5/16/97 lev

Phone Number: ;UCJ -5/lJ I--70q~

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~.
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

Page __

PUBLIC HEARING COMMENT FORM

Title of Public Hearing: Location: Date: -+:- _

Name: Organization/Company: -----------~r---------_rr_------

Address: Phone Number:------------r-------

,;.

Ifyou would like to submit comments, please do so on thisform, or you may attach them to this document.!

-iJere:fU t-ke4iiiF /2g[Jut) ---)0 a&:Y\8~iAe4~0!3l4LhO' IS P¢h -t-ft:~J2.- k yJ1Ok.e plLmoq -k Cl:2OlC. 11

!

Revised 5/16/97 lev
Daniel. Pat

From:

Sent:

To:

Follow Up Flag:

Flag Status:

odnewsletter@comcast.net

March 11, 2008 2:26 PM

Follow up

Completed

Dear Pat,

Please don't allow more soot. Hold off on designating NWI in attainment.

This attainment application is too premature for several reasons. First of all, while

IDEM is allowed to use data from 2004, 2005 and 2006 as the design values for the

application, we request that the 2007 data be added to this application prior to

submission to EPA. This is especially important because one of the critical monitors

listed, located at the Water Plant on Madison Street in Gary, just began operating in July

2005.

Another reason this application is too premature is because while many regulations exist,

such as the Clean Air Interstate Rules (CAIR), that will help reduce PM 2.5, some of these

regulations have just recently gone into effect or will not take effect for several years.

As a result, we believe it is too early.to fully assess the impacts of these regulations.

Mark Coleman

9 Locust place

Ogden Dunes, IN 46368

Thanks.

1
March 11, 2008

. RECEIVED

STATE OF INDIANA

MAR 1 7 Z008

·L.," ",ec",cc,;;.; ••;;:,';.;.;;;;:;;::;;.;;;; .....;;;;.;;;;.. ;;;;;.;;';'.;.;:.;';;:;:;:;;;;;;;.;;; ;;: ,;;:;;';;;.';';';: .;;;.;;;.;.;;:;;;;:;;;;:;;.;:;.;';; ;cc;;;·.;;;';;.;;.;;:;..;. ;;;:;;I;OEPl\lf1"MEN1'OfIiiVfR(fNMENfAI'MANAGEMErlr" Chief OFFICE OFAIR QIIALITY

Programs Branch

Office ofAir Quality MC 61-50

100 North Senate Avenue

Indiana Department ofEnvironmental Management

Indianapolis, IN 46206-2251

Dear Mr. Deloney,

The Dunelands Group ofthe Hoosier Chapter of Sierra

Club would like to go on record in support ofthe following

Save the Dunes Council comment on the PM 2.5 redesignation and maintenance plan for Lake and Porter

Counties.

We are also concerned with the impact ofmore use of

woodbuming stoves of any type for home heating as

natural gas and electricity prices continue to rise. We

would hope these would be required to use the latest

technology to be as low in pollution as possible.

Sincerely,

~()i~

Sandy O'Brien, group chair

Dunelands Sierra Club .

5500 S. Liverpool Rd.

Hobart, IN 46342
Scott Deloney, Chief

Programs Branch

Office of Air Quality MC 61-50

100 N. Senate Ave.

Indiana Dept. of Environmental Management

Indianapolis, IN 46206-2251

Dear Mr. Deloney:

I am writing to voice my opposition to the granting of the

PM 2.5 attainment in Lake and Porter counties. There are

just too many unresolved questions regarding increased air

emissions at BP, as well as in other industries in northwest

Indiana, in the near future. I am also very concerned that

2007 results from area speculation monitors are not

examined in the application, especially since the one

closest to where I live (Gary) showed a daily level above

the standard of 35 micrograms.

Thank you for the opportunity to comment, but I hope that

you study this further and do not grant attainment of PM

2.5 at this time.

Sincerely,

~~~/~

Karin Kirulis

;/C( - Cf3 g:-{} 711 (
Daniel, Pat

From:

Sent:

To:

Follow Up Flag:

Flag Status:

Michele Bonneau [mbonneau7@yahoo.com]

IUI~)UdY, February 28,20083:09 PM

Follow up

Green

Is there no one that will stand up for our future air quality? Not even those we elected

to do this job for us? Who will your children blame?

Never miss a thing. Make Yahoo your home page.

http://www.yahoo.com/r/hs

1
Daniel, Pat

From: DELONEY, SCOTT

To: Daniel, Pat

Subject: FW: Lake and Porter

Follow Up Flag: Follow up

Flag Status: Green

From: jpbiod@comcast.net [mailto:jpbiod@comcast.net]

sent: Tuesday, March 11,20083:20 PM

To: DELONEY, SCOTT

Subject: Lake and Porter

Scott Deloney

Office of Air Quality

100 North Senate Avenue

Indiana Department ofEnvironmental Management

Indianapolis, IN 4 6206-2 251

March 11, 2008

Re: Re-designating Lake and Porter Counties for Particulate Matter (PM) 2.5.

I strongly oppose the designation of Lake and Porter counties as "in attainment" ofthe PM2.5 standard. It is a

move based on economic concerns, not public health.

There are many known health effects that are the result of exposure to fme particulate matter including premature

death, hospital admissions, doctor's visits, lost time at work, etc.

This is offthe website ofthe Union ofConcerned Scientists. "PM 2.5 has a profound effect on public health. It

can easily become trapped in the human body and can have negative consequences for a person's health. Over

2,000 peer-reviewed studies published since the current PM 2.5 standards went into effect in 1997 link fme

particle pollution to strokes, heart disease, respiratory ailments, and premature death."

It continues, "A study funded by the EPA and the National Institutes of Health concluded that even an exposure

level of 13.4 micrograms ofPM 2.5 would put 11.5 million elderly Americans at increased risk of cardiovascular

and respiratory disease. These fmdings provide compelling evidence that fme particle concentrations well belQw

the national standard are harmful to the cardiovascular and respiratory health ofour elderly citizens."

There is no good justification for changing the designation for Lake and Porter Counties. In fact, it is the direct

result ofpolitical interference. The original decision ofthe EPA ignored the recommendations ofits own staff

scientists and skewed their recommendations.

From the UCS, "When considering safe levels of pollution in the air that we breathe, the EPA is only allowed to

consider health effects. Nothing else can be considered, including economic, or even environmental, effects.

According to its own scientific advisors, the EPA did not use the best available public health science in issuing

the new standards."

I am convinced that this redesignation is the result of an organized effort ofthe USEPA and the IDEM to promote

increased industrial production in northwest Indiana. It is unethical and it may be illegal. (The timing is

3/13/2008
interesting too considering the pending permits for the BP refinery in Whiting and US Steel in Gary.)

It is my position that "attainment of PM 2.5" in Lake and Porter Counties is a sham should be rejected.

1773 Selo Dr

Schererville, IN 46375

219-322-7239

By fax and e-mail

3/13/2008
Daniel, Pat

From:

Sent:

To:

Follow Up Flag:

Flag Status:

Mr. Daniels,

Lou Gagliardi [Igagliardi@worldwidewirelessinc.com]

Wednesday, March 12,200812:11 PM

Follow up

Green

This attainment application is too premature for several reasons.

First of

all, while IDEM is allowed to use data from 2004, 2005 and 2006 as the design values for

the application, we request that the 2007 data be added to this application prior to

submission to EPA. This is especially important because one of the critical monitors

listed, located at the Water Plant on Madison Street in Gary, just began operating in July

2005.

Another reason this application is too premature is because while many regulations exist,

such as the Clean Air Interstate Rules (CAIR), that will help reduce PM 2.5, some of these

regulations have just recently gone into effect or will not take effect for several years.

As a result, we believe it is too 'early to fully assess the impacts of these regulations.

Lou Gagliardi

2 Shore Drive

Portage, IN 46368

Thanks.

1
Daniel. Pat

From: Buckpr@aol.com

To: Daniel, Pat

Subject: attainment application

Follow Up Flag: Follow up

Flag Status: Green

It is our understanding that IDEM wants to designate NWI in "attainment" for soot, potentially allowing

more soot to be pumped into our air. Although we did not write the following we agree whole heartedly that we

want less soot in the air we breathe rather than more!

This attainment application is too premature for several reasons. First of all, while IDEM is allowed to use

data from 2004, 2005 and 2006 as the design values for the application, we request that the 2007 data be

added to this application prior to submission to EPA. This is especially important because one of the critical

monitors listed, located at the Water Plant on Madison Street in Gary, just began operating in July 2005.

Another reason this application is too premature is because while many regulations exist, such as the Clean

Air Interstate Rules (CAIR), that will help reduce PM 2.5, some of these regulations have just recently gone

into effect or will not take effect for several years. As a result, we believe it is too early to fully assess the

impacts of these regulations.

Please inform us of your action on this issue.

Thank you.

Sincerely,

Patricia and Richard Gonzales

Gary, IN

buckpr@aol.com

219/939.9946

3/13/2008
alSv 1 VI 1

Daniel, Pat

From:

To: Daniel, Pat

Subject: RE: BP

Follow Up Flag: Follow up

Flag Status: Green

As a resident ofNW IN (Ogden Dunes), I am concerned both about the air quality and the water

quality--particularly that ofLake Michigan and its tributaries. Please do not allow US Steel and BP

Amoco to spew pollution into our already contaminated air and destroy the water quality of Lake

Michigan. These are precious resources and the only tourist draw for this area (aside from the Casino

boats) are the dunes and Lake Michigan. Don't spoil a potential source ofrevenue by rushing to grant

variances to these industrial giants.

Thanks, Susan Squire, 17 Bittersweet, Portage, IN 46368

This attainment application is too premature for several reasons. First of

all, while IDEM is allowed to use data from 2004, 2005 and 2006 as the design

values for the application, we request that the 2007 data be added to this

application prior to submission to EPA. This is especially important because

one ofthe critical monitors listed, located at the Water Plant on Madison

Street in Gary, just began operating in July 2005.

Another reason this application is too premature is because while many

regulations exist, such as the Clean Air Interstate Rules (CAIR), that will help

reduce PM 2.5, some ofthese regulations have just recently gone into effect or

will not take effect for several years. As a result, we believe it is too early

to fully assess the impacts ofthese regulations.

3/13/2008
Daniel, Pat

From:

Sent:

Follow Up Flag:

Flag Status:

Dear Mr. Deloney,

jean smith Uagsmith@earthlink.net]

Wednesday, March 12, 2008 1:29 AM

Follow up

Green

This attainment application is too premature for several reasons.

First of

all, while IDEM is allowed to use data from 2004, 2005 and 2006 as the design values for

the application, we request that the 2007 data be added to this application prior to

submission to EPA. This is especially important because one of the critical monitors

listed, located at the Water Plant on Madison Street in Gary, just began operating in July 2005. .

Another reason this application is too premature is beca~se while many regulations exist,

such as the Clean Air Interstate Rules (CAIR), that will help reduce PM 2.5, some of these

regulations have just recently gone into effect or will not take effect for several years.

As a result, we believe it is too early to fully assess the impacts of these regulations.

Sincerely,

Jean Smith

18 Cedar Court

Ogden Dunes, IN 46368

1
Daniel, Pat

Subject: No More Soot PLEASE!!! think of our children!!!

To whom it may concern:

This attainment application is too premature for several reasons.

First of all, while IDEM is allowed to use data from 2004, 2005 and

2006 as the design values for the application, we request that the

2007 data be added to this application prior to submission to EPA.

This is especially important because one of the critical monitors listed, located at the

Water Plant on Madison Street in Gary, just began operating in July 2005.

Another reason this application is too premature is because while many regulations exist,

such as the Clean Air Interstate Rules (CAIR), that will help reduce PM 2.5, some of these

regulations have just recently gone into effect or will not take effect for several years.

As a result, we believe it is too early to fully assess the impacts of these regulations.

Best,

Lynda Jorgensen

4 The Thumb

Portage, IN 46368

1
Daniel, Pat

From:

Subject: Attainment Application

2.in.usJ

I am against the attainment application as I believe it is too early to accurately assess

the impacts of the Clean Air Interstate Rules.

I thank you for allowing me to voice my opinion.

Regards,

J.C. Lehmann

110 Hillcrest

Portage, IN

1
Daniel. Pat

From:

Sent:

valronstudios@comcast.net

This attainment application is too premature for several reasons. First of all, while

IDEM is allowed to use data from 2004, 2005 and 2006 as the design values for the

application, we request that the 2007 data be added to this application prior to

submission to EPA. This is especially important because one of the critical monitors

listed, located at the Water Plant on Madison Street in Gary, just began operating in July

2005.

Another reason this application is too premature is because while many regulations exist,

such as the Clean Air Interstate Rules (CAIR), that will help reduce PM 2.5, some of these

regulations have just recently gone into effect or will not take effect for several years.

As a result, we believe it is too early to fully assess the impacts of these regulations.

Ron Wennekes

215 Davis Dr.

Beverly Shores IN 46301

1
Page 1 of 1

Daniel, Pat

Sent: Tuesday, March 11, 2008 7:59 PM

To: Daniel, Pat

Subject: attainment

This attainment application is too premature for several reasons. First of all, while IDEM is allowed to use data from

2004, 2005 and 2006 as the design values for the application, we request that the 2007 data be added to this application

prior to submission to EPA. This is especially important because one ofthe critical monitors listed, located at the

Water Plant on Madison Street in Gary,just began operating in July 2005.

Another reason this application is too premature is because while many regulations exist, such as the Clean Air

Interstate Rules (CAIR), that will help reduce PM 2.5, some ofthese regulations have just recently gone into effect or

will not take effect for several years. As a result, we believe it is too early to fully assess the impacts ofthese

regulations.

Thank you very much for attending to this urgent matter. There is already way too many pollutants in North West

Indiana's air. Every child and adult has to be poisoned on a daily basis. IDEM never seems to look at the cumulative

effect ofthe particulates from all the industry. We have some ofthe highest cancer rates in the world right here as well

as serious asthma problems. Quit acting like it's ok for the people you are supposed to be protecting to get plenty more

pollution. Stop this insanity. Now.

Thanks.

Randi Light

37 Shore Drive

Portage, IN 46368

3/12/2008
March 11, 2008

Scott Deloney, Chief

Programs Branch

OtIlcc of Air Quality Me 61-50

100 North Senate Avenue

Indiana Department ofEnvironmental Management

Indianapolis, IN 46206-2251

Re-Designation and Maintenance Plan for Lake and

Porter Counties for Particulate Matter (PM) 2.5.

Dear Mr. Deloney:

CALUMET PROJECT

6819 Indianapolis Blvd.

Hammond, IN 46324

(219) 845-5008

Fax (219)845-5032

~417

RECEIVED

STATE OF INDiANA

MAR 1 4 2008

OEPARThlEHT Of mVIROIlMEHTAl MANAGEMENT

OffICE Of !\IR o.UAl~ITI:.......-_-, >-----_.""'"""'......~-

The Calumet Project support the comments submitted on the Designation and Maintenance Plan

for Lake and Porter Counties for Particulate Matter (PM) 2.5 to your office from Debbie Chubb,

President of Save The Dunes Organization.

Sincerely,

Bessie Dent

Progr:llil Coordinator
March 11, 2008

Scott Deloney, Chief

Program Branch

Office ofAir Quality MC 61-50

100 North Senate Avenue

Indiana Dept. ofEnvironmental Management

Indianapolis, IN 46206-2251

Dear Mr. Deloney:

Thank you for the opportunity to comment upon the Indiana Dept. ofEnvironmental

Management's (IDEM) request to EPA to approve the Re-designation and Maintenance

Plan for Lake and Porter Counties for Particulate Matter (PM) 2.5.

Since I am a member of Save the Dunes this application is of great concern to me.

According to the EPA severe health effects are associated with exposure to excess levels

of airborne fine particulate matter (PM2.5).

I am convinced that this application is too premature to be adequately studied. It also

appears to be too vague and potentially subjective. Save the Dunes takes the position that

attainment ofPM 2.5 in Lake and Porter Counties should not be granted at this time.

Thank you for allowing me to comment. I appreciate you consideration.

.cerel\;h IL

eHardy "1

own Point, IN

ember Save the Dunes
Indiana Steel

Environmental

Group

March 11, 2008

Lake and Porter Counties Fine Particulate Matter (pM2.5)

Redesignation Petition and Maintenance Plan

Scott Deloney, Chief

Programs Branch

Office ofAir Quality MC 61-50

100 North Senate Avenue

Indianapolis Indiana 46204

STATE OF i:V-;JIf!.N!~

MAR 1. 3 2008

DEP.4RTMENT OF ENVIROIIMEnm MANAGEMEIlT

OffICE OF AIR QUALITY

Munster, Indiana 46321

Tel: 219-836-1000

Fax: 219-836-4100

Subject: Comments In Support of Redesignation ofLake and Porter Counties as Attainment for PMz.5

Dear Mr. Deloney:

The Indiana Steel Environmental Group is a coalition ofIndiana steel companies established to focus on environmental matters

of concern to its members. The Indiana Steel Environmental Group (ISEG) consists ofmembership from ArcelorMittal Indiana

Harbor, LLC, United States Steel Gary Works, United States Steel Midwest Plant, ArcelorMittal Burns Harbor LLC, and Nucor

Steel Crawfordsville.

The Indiana Steel Environmental Group strongly supports the Indiana Department ofEnvironmental Management's (IDEM's)

draft petition for the redesignation ofLake and Porter Counties as attainment for fme articulate matter (PM25) and provides the

following comments. I

The three-year design values for all monitors used to determine attainment in Lake and Porter Counties have unifonnly met

U.S. EPA's annual PM2.5 standard for the 2002-2004,2003-2005 and 2004-2006 periods. The only remaining question is

whether Lake and Porter Counties still somehow "contribute to" nonattainment in Cook County - the only county that is still in

actual, direct nonattainment in the entire metropolitan statistical area.

Due to their physical location, Lake and Porter Counties can only theoretically "contribute" to violations at the Cook County

monitors at Cicero and Wilson Avenue when the wind is blowing one finite direction - from the southeast. EPA's own wind

rose analysis in northwest Indiana indicates that prevailing winds blow away from the violating monitors more than 90% ofthe

time. See Supplemental Risk Assessment ofPotential Air Emissions at 5-7 (Dec. 2006) CEPA Wind Rose Analysis") available

at http://www.epa.gov/region5/sites/indianaharborl.

I While there is serious question regarding whether U.S. EPA properly classified Porter County as a nonattainment area in the first instance~ the

monitoring data and detailed analysis in IDEM's draft Redesignation Petition helps rectify that initial classification error. As you may know, the

State oflndiana and ArcelorMittal Burns Harbor have both appealed U.S. EPA's original designation ofPorterCounty as nonattainmentfor PM2.S to

the D.C. Circuit Court of Appeals. That proceeding is currently in the briefing stage and will likely be argued during late summer or early fall of

2008. Submission ofthe proposed redesignation request for Lake and PorterCounties is fully consistent with that appeal and will only further assist

in lifting the regillatoJY burdens associated with EPA's initial nonattainment designation.

ArcelorMlttal NUCCIR

SHEET NILL·CRAWFDRDSVtLLE
2

Ifthere is any "contribution" to area air quality problems in the region. it flows the other direction. Ambient PM2.51evels

steadily decline when moving south and east from central Cook County to Lake County and consistently further decline through

Porter County. This illustrates that the winds cause Cook County's dominant emissions to travel south and east

We suggest that IDEM incorporate this point more prominently in Section 3.3 ofthe Redesignation Petition. That section

contains powerful evidence that the vast majority of emissions at the two nonattaining monitors in Cook Coimty stem from local

(and not regional) emissions. It makes this point in the context of a detailed discussion ofthree particular "high monitor value"

days (pp. 23-29). One ofthose three days, however, happened to occur during the rare instance when winds were blowing from

the southeast. While IDEM's back trajectory analysis from that particular day forecloses a fmding of contribution from Lake or

Porter counties despite those winds, it would be useful to note that this wind direction makes the potential for contribution

exceptionally rare.

IDEM should further support and clarify its contribution analysis by providing the statutory underpinnings that require EPA to

apply a significance threshold. Congress selected the term "contributes" to defme the concept ofindirect nonattainment status

in CAA §107(d)(1)(A)(i). Contribute is commonly defmed as playing "a significant part in bringing about an end orresult"

WEBSTER'S NINTII NEW COLLIGATE DICTIONARY at 285. A minimal or immaterial addition ofPM2.5 or precursors from Lake

or Porter County does not, "playa significantpart in bringing about" nonattainment at the Cook County monitors. That

conclusion is further reinforced by the Clean Air Act's structure. Nonattainment designations are used to drive State

Implementation Plan ("SIP") amendments necessary to secure attainment status. Requiring such SIP amendments in the

absence of a demonstrated causal relationship (e.g.• in areas that do not play "a significant part" in nonattainment status) would

impose an unnecessmy burden on regulated entities.

Finally, we concur with IDEM's conclusion that "Since Lake and Porter counties attained the annual standard for fme particles

priorto an Attainment orRACT SIP being due, and since the implementation rule forfme particles stipulates that states are

only required to draft and implement RACT rules for the precursor emissions reductions necessary to attain the standard, no

further RACT rules are required for this area." This position reflects EPA's standing "Clean Data Policy" and will avoid the

imposition of additional regulations that are not needed to satisfy the PM2.5 NAAQS.

We greatly appreciate IDEM's effortsto secure redesignation ofLake and Porter counties. Should you have any questions

regarding these comments, please feel free to contact me at (219) 836-1000.

Sincerely,

Y:b/l<r--

Patrick M. Gorman. P.E.

Facilitator, Indiana Steel Environmental Group

2 LaPorte County's monitored compliance with the PM2.5 standards (and its designation as an attainment area) further supports this view.

ArcelorMiffo( NUCCIR

SHEErUILL·CRAWFORDSVILLE
March II, 2008

Lake and Porter Counties Fine Particulate Matter (PM2.

s)

Redesignation Petition and Maintenance Plan

Scott Deloney, Chief

Programs Branch

Office ofAir QualityMC 61-50

100 North Senate Avenue

Re: Comments ofNWI FOFumlnSup.port ofRedesignation ofLake.3nd Porter Counties as

Attainmentfor PM~.5

Dear Mr. Deloney:

These comments are submitted by the NWI Forum in strong support ofthe Indiana Department of

Environmental Management's (IDEM's) draft petition for the redesignatioIl of Lake and Porter Counties

as attainment for fine partlculatematter (PM2.5). I The Northwest Indiana Fotftuu is a membership base<},

not for profit regional economic development organization. Our mettibetshipof 123 and growing

representsindustrial and commercial businesses, .financial entities; universitiesandllllinIcipalities within

Lake, Porter and LaPorte counties - a diverse group. In total, our membership reflects $40 Billion in

commerce annually on beh~fofthe. State ofIndiana.

Redesignation ofboth counties is critically impo,ttantto removing the additional regulatory hurdle

Qfl10nattainInentstatus anditsifupediments to attracting investment, bUSln'eSs and jobs to Lake and Porter

Counties. For example, theinonattaimnent designation discourages companies from making significant

capital inv~st1tlents to upclateor eXPand facilities in Lake or Porter Counties. TItat de~ITent effect is

primarily due to theadditio:n~burdensposed by New Source Reviewperrnitting, the requirement to

obtain ~U1issions offsets and the threat of further state-level requireIllents,Sirtrilar1y; the nonattainment

designations discourage investments for the development of new facilities., Thel?fompt removal of that

additionaJ regulatory burden will help the comp1lilies who have already heavily invested in Lake and

PorterCounties to maketlttt(,)hli~Ilges necessary to cPmpe.tein the globaleconomy.

The three-year dtWigtl v~lues for all monitors.in Lake and Porter Counties have unifonnly met

tJ.S.EP:A's annual PM~.5 standard for the 20Q2 M Z004, 2QQ3~2005 and 2004':ZQ06penods. The only

remWwng question isW1').efl1et L~l'eal1d·. Porter Counties sHU somehow '~c(1).tt'ibl1t¢: to" nonattainmentin

(;0<:)15: Co!Wty - the only c.Ol.1fity'tbat isstiU in actual" dircect nonatt~nm~t.inthetmtire metropolitan

statistical·area.

I Wb;iI~ there is.serious question reIi8rd~g,wbether u.s. EPA pI"(jpedYcI~Sl!ifi.ed Port~rC<iuntyas ..~. n:onattainment area in the

first in:~tance, the monitoring data and d~tailed analysis in lDE~:~4t!lfiRedf\siguatioll P¢fitIQi) bell'S rectify. that initial

clas$ifi:Qationerror. As you may know,the State ofIndiana and Atg¢lorMitt!i1 B1Itf.ls fIa~&QflJaveb\}th,appealed U.s. EPA's

o.Iigin.ald~ignation of Porter County<ls nonattainment for PMZ•5 to ·tlI~·. D;C.Circuit GQi(lrt ofAPPeaIs.. That proceeding is

cpxrentlr in the briefing stage and.win, liKely be. argued.during late sl@rtieror elJrly fa.JI 0'20.08..SuJ:l1uissiollOfthe proposed

rede~i~atign request for Lake and I'OI;tepCounties is fuUyconsistent'Wi.tn thatappeal and WijlQ,uyf¢'tlierassistin lifting the

t~guI!-tt<>iy;,bUtdeIl$ asSociateq; witblW1\~s.ivitlal nonattainmentdesignatiofh
PM2.5 Redesignation Petition Comments

2008

Due to their physical location) Lake and Porter Counties can only theoretically "contribute" to

violations atthe Cook County monitors at Cicero and Wilson Avenue when the windis blowing one finite

direction - from the southeast. EPA's own wind rOse analysis in northwest Indiana indicates that

prevailing winds blow away from the violating monitors mote than 90% ofthe time. See Supplemental

Risk Assessment ofPotential Air Emissions at 5-7 (Dec. 2006) ("EPA Wind Rose Analysis") available at

11tm:Ii~'Ww&Y!la.gov/tegion5t$ites/indiauahatbor!. If there is any "contribution" to area air quality

problems in the.region, it flows the other direction. Ambient PM.t-s levels steadily decline when moving

sQuih and east from central Cook County to Lake County and cQnsiStently further decline tbrough. Porter

County. This illustratesthat the prevailing winds cause Cook CQunty's dominant emissions to travel south

and east - nat Lake and Porter's Counties; cleaner airio "swim upstrearn}>4

We suggest that IDEM incorporate this point more prominelltly in Section ~.3 of the

Redesignation Petition. That section contllinspowerful evidence thatt11evastmajority ofemissions atthe

two nonattaining monitors in Cook County stem from local (andnQt regioMI) emissions. It makes this

point in the context Q.fa·(ietaHed discussion of three particular "high mo1'1itbf value~' days (pp. 23~29).

One ofthose threeQI,lYli" however, hllP;pened to Q<Wtlr during the rare instance 'W'hell winds were blowing

rrQmthe southeast. While IDEM's back trajectory analysis from thmpart1cular day f0recloses a finding

ofcontribulion from Lake orPorter counties despite those winds, itwould be usefulto note that this wind

direction makes'the pOtential for contribution exceptionaJly rare.

IDEM should also consider clarifying the various stattnnentsin the Redesignation Petition that

attempt to convey the statutory threshold for "contribution." Several.Parts orthe petition state (or infer)

thatredesignation is appropriate ifEPA cQnclOdes that Lake alta Porter Cottnties were not "significantly

contributing" to the.CookCOunty violations. See, e.!}'" p. 17 C"Ifenlissions tram Lake andP0Iter counties

were significantly contributing...."), p. 22 {"it is evident thatthen~is' I10significant impact from

Northwest Indiana.")p.$9 ("significantly contributing to the violi:ttingmonitQrsc in Illinois"). Otherparts

ofthe Redesignation Pet,ition potentially indicate;'a lowerreJe:vance"threshold<for 'Icontribution" analysiS.

See, e.g., p. 22 ('~whfleemiSsions from aUsurroun.diJ:lg a.reaS may have sl11attimpacts"), p. 29 ("In<iianais

confident thatits contribution to thislocalized effect is n:egli:gillltt").

IDEM should further support and clarify its contrili>ution analysi'sby providing the statutory

underpinnings thatl'~qu.ite EPA to apply a significance tbreshold, OQngr:¢$$ selected the tettrt

i'contributes" to defiJ:l~ th~ concept ofindirect nonattain.rnelltstatus in CAA§I07(d}(1)(1\.)(1). Con(rifJl#c

is common:ly defined as playingI<a signifl¢antw~in briJ:l~ihg abpntanetrd orresult." WEl3STER;'S

lNlNrtI NEW COLU<1ATB DICTIONARY at 285.A'@:t,riw3,l or imm~terial a4PitionofPM2.$ orprccursors

tromLake or PorterCQooty does not "playa signtflcantparl in bringingab.o~t';nonattainmellt at the Co,ok

<;:ounty monitors, Tbat"cpnclusion is ful1herreinfotced by. theSlean Air Act;~ structure. NOllattainnrel1t

.4esignations are used. to:. drive State Imple111~n,tation ...Plan ("SIP") aowndments necessary. to SeCllre

~®itm1ent status. ReqOiri~gsuch SIP arnenclmentsin tbeabsenc~Qfa'(l¢monstrated causal relationshjp

(e.g.., in areas thatdo' no:tplay "a significant part" in nonattaitlll:1ent stat!1$} 'WQuld Impose an unnecessary

burdenon regulated'ehti:tt~s. . .

~4t~orte County'sttlOIlifored compllance with thePM25st~nd~ds(and itsd:esrgnation as an attaiWlt¢n}

a.rea) fUrther.sll~por.ts·this; vIew. . . .
PM2.5 Redesignation Petition COrrtrt1ents

March 11, 2008

While the R.edesi~ation Petition.provides.amplejustification to redesi~ateboth Lake and Porter

Counties, it is worth nQiingihat the link between. Porter County emissions an.d l'l1e, violating Cook County

monitors is even moretel1UOus. Emissions from Porter County would have torravel over not just

numerous attaining Cook county momtors.hut 1'J.lso over all of Lake County to "contribute" to

nonattaimuent. Ifemlssionsin PorterCountywereacttlally contributing to nonattainment to the west, that

impact wO'-lld be mQstnotablein irrtrnediately adjacent Lake County. The contrary steady decrease of

ambient PM2.S levelsf'tom west to eastdemonsttates the absence ofsuch an impactandprovidesfurther

proof l'l1at Porter CQtITlty is trot "contribmmg." Thus, if U$. EPA (improperly) r~ses to redesignate

bo1'b. cOllnties, IDItM should consider requesting separate treatment for porter County due to this even

more tenuol.lcs causal link to the violating monitors.

Finally, weconcut with IOEM's conclusion tlmt "Since Lake an.d Ponelfcotinties attained the

annual. s~dard for une pllttieles prior. to an, Attainment or RACY Sl}>bcw,g.due, and since. the

implementation rUleforfinepattieIes stipulates tbatstates are onlyrequired to &I;lItaP.dimplement RACT

rules f"Qr the precursor e111issionsreduetions nec.esslilty to attain the standard, no.1iUrfher RACT rules are

reqllired for this area." rws ppsition reflects EPA?s standing "Clean Data. P(;)liey"and will avoid the

impftsition ofbQrdeti;$Q1.ne additiQrtal.l'egulations that arenot needed tQ satisfy the NMz;5 NMQS.

We greatly apprec.ia.telDeM'sef'forts toseclWe.redesignation ofLake antjl'Qnet counties. Should

you have any questions regardingth~$eeo1ll.1tl'ent$, pleaseJe.el free to contact me:at(:21~) 763~6303.

Sincerely,

~~·fU,lft~ James W.Fltntnery .• :•..•.....a

Chaitlfian. ·Bo&rd ofDirectors.

NQrthwestJndiana Forum, Inc.
Improving

Environment

March 11, 2008

Dan Murray, Assistant Commissioner

Office of Air Quality

Mail Code 61-50

Indiana Department of Environmental Management

100 N. Senate Ave.

Indianapolis, IN 46206-2251

3951 Meridian St, Ste 160

Indianapolis, IN 46208-4062

www.ikecoalition.org

317-902-3610

mccabe@ikecoalition.org

Re: Redesignation Petition and Maintenance Plan for Lake and Porter Counties Indiana

Dear Mr. Murray:

On behalf of Improving Kids' Environment, Inc., I am writing to express IKE's opposition to

the Indiana Department of Environmental Management's intent to seek redesignation of Lake and

Porter Counties, Indiana, to the status of maintenance counties for the fine particle health standard.

Redesignation of the Indiana counties is not the best way to achieve public health and economic

goals for the region, and will undermine the 15 year commitment among the Lake Michigan states to

work collectively to solve regional air quality challenges. Improving Kids' Environment, Inc. is a

not-for-profit organization that works to reduce environmental threats to children's health in Indiana.

IKE appreciates the opportunity to provide these comments to you and Commissioner Easterly.

IKE shares IDEM's interest in lessening the economic development impacts of a

nonattainment designation. However, it is premature for Indiana to seek to redesignate its counties

in this multi-state, regional nonattainment area while monitors elsewhere in the region still violate

the standard. Although I fully appreciate the state's desire to return counties to attainment status, I

cannot support this particular request for two reasons.

First, the air quality data do not support this designation. Based on 2004-2006 data, two

monitors in the nonattainment area continue to monitor violations of the annual health standard for

PM2.5 and I understand that the 2005-2007 monitoring data show five monitors in violation.

Granting Indiana's request would require USEPA to redesignate a portion of a nonattainment area

before the entire area is in attainment. Based on a recent conversation with staff at the USEPA

Region V office, the agency has never approved such a request.

Second, Lake and Porter Counties are part of a multi-state nonattainment area, designated as

such in accordance with USEPA guidance. Like ozone in some respects, PM2.5 is a regional

pollutant. The main sources of emissions in the S02 and NOx inventories are point sources in Lake

and Porter Counties, and nearly half of those emissions come from electric generating units, whose
emissions can travel regionally. See Appendices Band D. Because of the concentration of large

and numerous point sources as well as significant emissions from motor vehicles, USEPA guidance

treats large metropolitan areas (even if they are multi-state) as a single nonattainment area.

in Lake County do not meet the recently revised PM2.5 daily standard of 35 f.Lg/m3 based on 2005-7

data. These counties are very likely to be designated as nonattainment under the revised standard. It

therefore will serve little purpose to resdesignate them now to attainment for the annual standard and

will likely confuse regulated industry and the public about whether air quality does or does not meet

health standards and what permitting and other regulatory requirements apply.

It is more appropriate for Indiana to collaborate with Illinois on an attainment plan for the

region than to seek redesignation at this time. Thank you for your consideration of these comments.

Please do not hesitate to contact me if you have questions.

Very truly yours,

-::r~G.n~(...\.",....

Janet G. McCabe

Executive Director

Cc: IKE Board

IKE Advisory Board

Scott Deloney, OAQ Branch Chief
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 NORTH GRAND AVENUE EAST, P.O. Box 19276, SPRINGFIELD, ILLINOIS 62794-9276 - ( 217) 782-3397

JAMES R. THOMPSON CENTER, 100 WEST RANDOLPH, SUITE 11-300, CHICAGO, IL 60601 - (31 2) 814-6026

(217) 785-4140

March 10,2008

Mr. Scott Deloney, Chief

Air Programs Branch

Office ofAir Quality - Mail Code 61-50

100 North Senate Avenue

Indiana Department ofEnvironmental Management

Indianapolis, Indiana 46206-2251

Re: Lake and Porter Counties Fine Particulate Matter (PM2.5)

Redesignation Petition and Maintenance Plan

Dear Mr. Deloney:

,RECEIVED I ,STATE OF INDIANA

MAR 1 2 2008

DEPARTMENT Of ENVIRONMENTAL MA/IAGEMEIIT

OffiCE Of AIR QUAlllY

The Illinois Environmental Protection Agency (Illinois EPA) appreciates the opportunity

to provide comments on the State ofIndiana's draft document: "Request for

Redesignation and Maintenance Plan Under the Annual National Ambient Air Quality

Standard for Fine Particles - Lake and Porter Counties" (January 2008). The request

seeks to redesignate two Indiana counties, Lake and Porter, as attainment for the annual

PM2.5 National Ambient Air Quality Standard (NAAQS). As you know, the states of

Indiana, Illinois, Wisconsin, Michigan, and Ohio have worked cooperatively for many

years to improve air quality throughout the Lake Michigan region. Although air quality

has greatly improved as a result of ourjoint efforts,. violations ofthe annual PM2.5

NAAQS are still occurring in our region. We believe that emissions from Lake and

Porter counties contribute significantly to ongoing violations ofthe annual PM2.5

standard. The Illinois EPA, therefore, strongly opposes Indiana's redesignation petition

and will recommend to the United States Environmental Protection Agency (U.S. EPA)

that this petition be denied, and that Lake and Porter counties remain designated as .

nonattainment until the annual PM2.5 NAAQS is achieved in the entire Lake Michigan

regIOn.

In 1991, the State ofIndiana, in conjunction with the states ofIllinois, Michigan, and

Wisconsin, signed a Memorandum ofAgreement (MOA) which committed the four

states to work cooperatively to improve ozone air quality in the Lake Michigan region.

The 1991 MOA established the Lake Michigan Air Directors Consortium (LADCO) to

ROCKFORD - 4302 North Main Street, Rockford, IL 61103 - (815) 987-7760 • DES PLAINES - 9511 W. Harrison St., Des Plaines, IL 60016 - (847) 294-4000

ELGIN - 595 South State, Elgin, IL 60123 - (847) 608-3131 • PEORIA - 5415 N. University St., Peoria, IL 61614 - (309) 693-5463

BUREAU OF LAND - PEORIA - 7620 N. University St., Peoria, IL 61614 - (309) 693-5462 • CHAMPAIGN - 2125 South First Street, Champaign, IL 61820 - (217) 278-5800

SPRINGFIELD - 4500 S. Sixth Street Rd., Springfield, IL 62706 - (217) 786-6892 '. COLLINSVILLE - 2009 Mall Street, Collinsville, IL 62234 - (618) 346-5120

MARION - 2309 W. Main St., Suite 116, Marion, IL 62959 - (618) 993-7200

PRINTED ON RECYCLED PAPER
coordinate technical and policy developments needed to meet this challenge. The level of

cooperation between the LADCO states and the success ofthose efforts to improve air

reaffirmed this commitment a number oftimes since 1991, most recently in 2004, when a

new MOA was signed by the four states to include the State of Ohio in the collaborative

planning process. The 2004 MOA "reaffirms the cooperative effort by the states and the

U.S. EPA to ... identify, evaluate, and implement sufficient emission reductions to

provide for attainment ofthe NAAQS for 8-hour ozone and PM2.5 and achieve the

reasonable progress goals for regional haze throughout the five state regions." We urge

Indiana to continue to work cooperatively with the other LADCO states until a control

strategy that solves this problem has been identified and implemented.

This work is not completed. As Indiana's petition notes, PM2.5 concentrations

exceeding the level ofthe annual NAAQS were measured in northeastern Illinois during

the 3-year period, 2004-2006, used in your analysis. Significantly, based on the most

recent 3-year period, 2005-2007, a violation ofthe annual PM2.5 NAAQS has been

measured at the Illinois monitoring station located at the Washiligton High School (see

Figure I). This monitoring station is the closest Illinois monitor to Lake County, Indiana.

It is noteworthy that monitors located further north and west ofIndiana are recording

lower PM2.5 concentrations, which suggests that local sources in Lake County are

contributing to the annual PM2.5 violation at Washington High School. This new

monitoring data completely contradicts the rationale provided on page 10 ofthe

"Request".

To further establish that emissions from Indiana are contributing to elevated PM2.5 levels

at Washington High School, the Illinois EPA developed a "pollution rose" for this site, to

illustrate the average PM2.5 concentrations at this location based on the wind direction

occurring during times of elevated PM2.5 levels (defined as exceeding 25 ug!m\ The

results ofthis analysis are shown in Figure 2. Please note the high average contributions

occurring at Washington High School when winds are from easterly through southsoutheasterly wind directions (i.e., from Indiana). It is also noted that southerly through

westerly wind directions also contribute to elevated PM2.5 levels, but these directions are

consistent with the climatological frequency ofwinds throughout the year as shown in the

wind rose in Figure 3. Comparing the two figures (Figures 2 and 3), it is obvious that

elevated PM2.5 from the easterly wind directions are over-represented relative to the

frequency of winds from those directions. Again, these results are suggestive oflocal

impacts from sources in Lake and Porter counties to the measured PM2.5 violations at

Washington High School.

For its Clean Air Interstate rulemaking, U.S. EPA considered a 0.2 ug!m3 contribution

from an entire state a significant contribution for PM2.5. Recent modeling performed by

LADCO demonstrates that Lake and Porter counties by themselves contribute amounts

that are far greater than U.S. EPA's thresholds at monitors in Cook County that are

exceeding the annual PM2.5 standard. There is'no technical basis for Indiana to conclude

that sources located in Lake and Porter Counties do not significantly contribute to

nonattainment in adjacent states.

2
Lake and Porter counties are tied to the Illinois nonattainment counties

clearly states that these factors must be considered when the states recommend the

boundaries of a nonattainment area (see "Designations for the Fine Particle National

Ambient Air Quality Standards", Aprill, 2003). U.S. EPA properly considered these

factors in determining the reasonableness ofthe nonattainment area boundaries when the·

boundaries were finalized in 2005.

In summary, there is no technical or legal basis for Indiana's contention that emissions

from Lake and Porter counties do not contribute significantly to ongoing violations ofthe

annual PM2.5 standard in the region and that further emission reductions from these

counties is not warranted. Redesignation ofIndiana's Lake and Porter counties to

attainment will exacerbate the problem in that it allows Indiana to avoid taking the

necessary steps to address the regional emission problems and instead would allow the

counties to comply with lesser standards that may lead to a worsening of air quality. We

believe Indiana must provide emissions reductions beyond those currently contained in

Indiana's State Implementation Plan (SIP). The Illinois EPA, therefore, strongly opposes

Indiana's redesignation petition and will recommend to the U.S. EPA that this petition be

denied. Indiana should withdraw its draft redesignation proposal and Lake and Porter

counties should remain nonattainment until the annual PM2.5 air quality standard is

achieved in the entire Lake Michigan region.

Sincerely,

d~~.. -- Laurel L. Kroack, Chief

Bureau ofAir

Enclosures

cc: Cheryl Newton, Acting Director, Air and Radiation Division, U.S. EPA Region 5

Tom W. Easterly, Commissioner, IN-IDEM

Kevin Kessler, Acting Director, Bureau Air Management, WI-DNR

H. Vincent Hellwig, ChiefAir Quality Division, MI-DEQ

Robert Hodanbosi, Chief, Division ofAir Pollution, OH-EPA

3
Cicero Monitoring Site

Summit Monitoring Site

Illinois

FIGURE 1

Cook County

Annual PM2.5 Design Values

2005-2007

Washington High School

Monitoring Site
FIGURE 2 .

Chicago - Washington High School

2005-2007

N

s

FIGURE 3

Wind Rose

Alsip 4500 West 123rd Street

2005-2007

N

s
March 11, 2008

Scott Deloney, Chief

Programs Branch

Office ofAir Quality MC 61-50

100 North Senate Avenue

Indiana Department of Environmental Management

Indianapolis, IN 46206-2251

Dear Mr. Deloney:

Thank you for the opportunity to comment upon the

Indiana Department ofEnvironmental Management's

(IDEM) request to EPA to approve the Re-designation and

Maintenance Plan for Lake and Porter Counties for

Particulate Matter (PM) 2.5.

Save the Dunes Council takes this application very

seriously. According to the Environmental Protection

Agency (EPA), severe health effects are associated with

exposure to excess levels of airborne fine particulate matter

(PM2.5), including tens ofthousands ofpremature deaths

and hospital admissions, and hundreds ofthousands of

doctor visits, work and school absences and respiratory

illnesses yearly.

Fine particles are also a major source ofhaze that reduces

visibility in our landscape, and it "affects vegetation and

ecosystems by settling on soil and water, upsetting delicate

nutrient and chemical balances." (Environmental Protection

Agency, Particle Pollution Report, 2003, p. 3.) For

example, in the article Seepage Measurementsfrom Long
J

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Lake, Indiana Dunes National Lakeshore, the authors

i"ndieatethattne"flldhtllaf)urres'Natrol1a:l'cakesITcrrerrasthe'

"highest nitrate and sulfate levels in precipitation of any

monitored park in the country." (Seepage Measurements

from Long Lake, Indiana Dunes National Lakeshore,

Environmental Geology, September 1996, p. 99.)

A careful review ofthe data provided by IDEM as well as

EPA indicates that this important pollutant is on a

downward trend. Nevertheless, it must be stated that Save

the Dunes' Board ofDirectors supports the 2006 position of

the Union ofConcerned Scientists that the average annual

standard currently promulgated by EPA at 15 micrograms

still is not low enough to protect human health and should

instead be at 13 to 14 micrograms.

(http://www.ucsusa.org/scientific integrity/interference/e121!

':particulate-matter.html)

As a result, it is our beliefthat, while this application is

very thorough, it is simply too premature and violates the

spirit ofthe cake Michigan Air Directors Consortium

(LADCO). Furthermore, there appears to be conflicting

data, there are many questions that need to be answered,

some ofthe documentation or wording is unclear, and more

work needs to be done on the Maintenance Plan.

This application is too premature for several reasons. First

of all, while IDEM is allowed to use data from 2004, 2005

and 2006 as the design values for the application, we

request that the 2007 data be added to this application prior

to submission to EPA. This is especially important because
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one ofthe critical monitors listed, located at the Water

."., " ,,..,.,.v·Plattt·o·n··MaeIisfin··Street'in"oat)';jnst-beganopetatirrg"ln

July 2005.

Another reason this application is too premature is because

while many regulations exist, such as the Clean Air

Interstate Rules (CAIR), that will help reduce PM 2.5,

some ofthese regulations have just recently gone into

effect or will not take effect for several years. As a result,

we believe it is too early to fully assess the impacts ofthese

regulations.

Determining the chemical make-up of a particle - known as

"speciation" - is an important part ofthe effort to reduce

PM 2.5 levels, and is accomplished largely through data

generated by EPA's ambient air speciation monitoring

program. We are also very concerned that 2007 results

from area speciation monitors are not reflected in this

application. While these results may not need to be

considered in this application, it must be noted that that a

number ofthe readings were above the daily standard of 35

micrograms at the Gary Iitri Speciation Monitor location.

(http://www.in.gov/idem/air/amb/ambi~nt/summary/aqsum

mary.html) This kind of data is vital to ensuring that

pollution controls are implemented at the right sources and

should not be ignored.

Furthermore, we are not clear that the emissions inventory

and estimates include important potential future emissions

from the following sources:

o Increased air emissions expected from the expansion of

the BP Whiting Refinery as well as the BP Asphalt Plant.
o Increased emissions that could result from the expansion

,",....",.,......F·····of,tllecGary...ehieagoI·ntemattorral*irpurt

o Increased emissions resulting from an increase in the use

ofresidential wood combustion devices such as hydronic

heaters, also known as Outdoor Wood Furna~e Boilers.

One ofthe major purposes ofLADCO, as stated in a Memo

ofAgreement for Interstate Air Pollution Stl.!dy and Control

signed in 2004 by former IDEM Commissioner Laurie

Kaplan, is the development ofmulti-state, multi-pollutant

planning "to support the development of effective control

plans to address regional pollution problems such as ozone,

fine particles, regional haze and air toxics." IDEM's

determination that "emissions from Lake and Porter

Counties do not affect the downwind area's ability to attain

the fine particles standard" violates the spirit ofthat Memo

ofAgreement. In your public response to these comments,

we request that Illinois EPA's reaction to this redesignation application be included.

While trying to demonstrate Indiana's lack of culpability in

impacting the Chicago nonattainment area you used

February 3, 2005 as an example of a monitored day higher

than the daily standard ofmore than 35 micrograms. It is

interesting to note that the Ogden Dunes monitor was not

operational that qay, as indicated on Table 3.5 ofthe

application. This begs the following question: How often

do any ofthe monitors not report results, and how are those

non-reporting values factored into the annual average?

Under the 3.5 Continued Monitoring Section, you indicate
that the existing monitoring network could potentially be

challg~d"witR,:g:PA!8'H:ppro¥al';',We'wottld,~troftgl",>;0bj'eet"tCl',

any changes that might be made in the network since

monitor changes could potentially be implemented to make

the outcomes look more favorable.

Your application must be presented in a manner that

demonstrates that attainment was achieved based on

permanent and enforceable emission reductions. This

application needs to demonstrate more clearly that

favorable weather conditions during the design value years

did not heavily influence emissions reductions. This is

because weather patterns can contribute to yearly

differences in PM 2.5 concentrations from area to area.

On page 25 ofthe application, you indicate that utilities can

meet their budget for nitrous oxide (NOx) emissions by

purchasing emissions credits. How many credits were

actually purchased and how much impact do these credit

purchases actually have on the reduction ofregional NOx

emissions?

Vehicle age distribution is an important consideration when

projecting transportation conformity budgets and travel

demand forecasts. Considering that the economy in this

area is most likely in recession, people and companies will

most likely hold onto their cars and fleet vehicles much

longer, which means that it will take longer to phase in

newer models that will have reduced emissions.

In the application, IDEM has committed to maintaining
certain control measures after re-designation, and those

""eo"ntl~t}l"rrleaSttresare""'Hsted:"fB.EM'sfrottl'd"atsoprrrvrde'a'ttst

of control measures that will no longer be required or

utilized ifthis attainment status is granted.

In the Corrective Actions section ofthe application, you

indicate that "if a new measure or control is already

promulgated and scheduled to be implemented at the

federal or state level, and that measure or control is

determined to be sufficient to address the upward trend in

air quality, additional local measures will be unnecessary."

Can you please provide clarification on what criteria will

be utilized to determine if a measure or control is

sufficient? In addition, your contingency measures section

is too vague and should be made clearer. For example,

instead of providing examples of contingency measures

that "may" be considered, you should instead provide a

more comprehensive list of contingency measures that

could be implemented.

Furthermore, it is our beliefthat your list offactors that will

be considered for the selection of contingency measures is

too vague and potentially subjective, especially where you v

say "Seconomic and social considerations and other factors

IDEM deems appropriate."

In the list of potential contingency measures, you may want

to consider having idle restrictions placed on trucks as well

as diesel trains; and, instead ofwood stove change-outs,

you may want to implement residential wood combustion

emissions reduction strategies. Residential and industrial
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, wet-vacuum street sweeping would help also. Another idea

",mci~ht',be·to"Wf)fle·"~l+th·'area"irrdttstrieS"·tcrt~\fttftrate"tlretr

average truck-waiting times and implement more efficient

gate operations.

Finally, if and when Lake and Porter Counties are placed

into attainment, Save the Dunes requests that you create a

Stakeholder Advisory Committee that will help monitor the

maintenance plan.

Again, thank you for the opportunity to comment on this

application. It is our position that attainment ofPM 2.5 in

Lake and Porter Counties should not be granted at this

time.

Sincerely,

Debbie Chubb

President

cc: Environmental Protection Agency
444 Barker Road, Michigan City, IN 46360 • 219-879-3937 • www.savedunes.org

RECEIVED

STATE OF INDIANA

MAR I 4 2008

DEPARTMENTOF EWlIRDNMENTAL MANAGEMENT

OFFICE OfAIRQUALITY,

March 11, 2008

Scott Deloney, Chief

Programs Branch

Office ofAir Quality MC6I-SO

l()ONorthSenate Avenue

Indiana Department ofEnvlr()ntnental Management

Indianapolis,IN46296::22Sl. .

.. Dear Mr. Deloney:

~Thankyou forthe opportunity to comment upon the Indiana Department ofEllvironmental·

. Management's (IDEM) request to EPA to approve the Re-designation and Maintenance Plan for

take and Porter CountiesJorParticulateMatter (PM) 2.5. ...

Save the Dunes Counciltakesthisapplicatioll very seriously. According to the Enviionmental

Protection Agency (EPA), severe health effects are associated with exposure to excess lev~ls of·

airbomefine particulate matter (PM2

.

5

), induding tens ofthousandsbfprematuredeaths and

. hospital admissions, and hundreds of thousands of doctor visits, workand school absences and

respiratory illnesses yearly. .. . .

.. Dedicateclto P:'eservation and Protection of the Indiana tJunes$iiice 1952

... • .@100%post-eonsumer;,,;YCledpaper, processed ch'orine ir~e'
Save the Dunes Comments on PM 2.5, p. 2

A cl'!-reful review of the data provided byIDEM as well as EPA: indicates that this important'

pollutant is on a downward trend.. Neverthelyss, it must be stated that Save'the Dunes' Board of

ccccDicr~@t€lrscsuppoFts0Hlec"2006cpositi'On·oft1Ye·l:fltiott·df··et)rrcemed·Sch~fitfsts·th.artl1e·,·a:vera:g"e···

annual standard currently promulgated byEPA,at 15 micrograms still is not low enough to

protec~ human health and should instead be, at 13 to 14 micrograms.

(http://www.ucsusa.org/scientificintegrity/interference/epa-particulate-matter.htm!)

As a result, it is our belief that, while this application is very thorough, it is simply too, premature

and violates the spirit of the Lake Michigan Air Directors Consortium (LADCO). Furthermore,

there appears to be conflicting data,there are many questions that need to be answered, some of

the ~ocumentati0n or wording is unclear, and more work needs to be done on the Maintenance

Plan.

This application is too premature for several reaso~s., First of all, while IDEM is allowed to use '

"data from 2004, 2005 and 2006 as the design 'values for ,the application, we request that the 2007

data be added,tothis application prior to submission to EPA. This is especially important ' '

because one ofthe critical monitors listed,located.atthe Water Plant on Madison Street in Gary" '

just began operating in July 2005. ' '

. An'other reason this application is too premature is because while many regulations'exist,such as

the Clean Air Interstate Rules (cA.IR), thatwill help r.educe PM 2.5, some of these regulations

have just recently gone into effect or wilrnot takeeffectfor several years. As a result, we

believe itis too early to fUlly ass'ess the impacts of these regulations. ' ,

Determining the chemical make'-up.of a particie - known 'as "speciation" is an important pan:

ofthe effort to reducePM 2.5levels, and is accomplished largely through data generated by

EPA's ambient-air speciation monitoring program. ,We are also very concerned that 2007 results

from area speciation monitors are .notreflected in this application. 'While $ese' results may not

need to be considered Inthis application, it must .be ndfed that that a number of the readings were '

above the, daily standard of 35 rillcrograms at the Gary Jitri Speciation Monitor lOcation.

~(http://www.in.gov/idernlair/amb/~lI:i1bient/summary/aqsummary.html) This IGn4 of data is vital

to ensuring that pollution controls, are implemented at therightsourcesand should not be '

" ignored.

Furthermore, we are not clear that the emissions inventory and estimates'inClude important

potential future emissions from thefollowing sources: '

• Increased air emissions expected from the expansion of the BP Whiting Refinery as well as

the BP Asphalt Plant. '" '

., Increased emissionsthat could result frol1)theexpansionof the Gary-Chicago International

Airport..., ' ,'., , ' .' '

• In~reased emissions resultingfrom an iIicrease in the use of residential woo~coinbustion ,

deviees-such as hydronic heaters,also known as Outdoor'Wood Furnace Boilets~

One of the major purposes of LADCO, asstated in' a Memo of Agreement for Interstate Air

Pollution Study and Control sigll{~d in 2004 by former IDEM Commissioner Laurie I(aplali, is

thedevelopmentoftmilti-state,multi-poUutant planning "to support the development ofeffective

cdntroI plans to address regionalpoUution problemsstich as ozone, fineparticle~, regional haze

, .
Save ~he Dunes Comments on PM 2.5, p. 3

and air toxics." IDEM's determination that "emissions from Lake and Porter Counties do not

affect the downwind area's ability to attain the fine particles standard" violates the spirit of that .

Mem€lof:AgfeeH1CUf:',In Y0ur public"response'totlresc"comments~we'rl~llt:festtli:atrlllfrbisEf>lt·s'"'

reaction to this fe-designation application be included.

While trying to demonstrate Indiana's lack of culpability in impacting the Chicago

nonattainment area you used February 3, 2005 as an example of a monitored day higher than the

daily.standard of more than 35 micrograms. It is interesting to note that the Ogden Dunes

-monitor was not operational that day, as indicated on Table 3.5 of the application. This begs the'

following question: How often do any of the monitors notreport results, and how ate those nonreporting values factored into the annual average?

Under the 3.5Continued Monitoring Section, you indicate that the existing moriitoring network

could potentially be changed with EPA's approval. We would strongly object to any changes

that might be made in thenetwork since monitor changes could potentially be implemented to

make the outcomes look more favorable. -

Your application-must be prese"nted in a manner that demonstrates that attainment was achieved

based on permanent and enforceable emission reductions. This application needs to demonstrate

more clearly thatJavorable weather conditions dming the design value years did not heavily

influence emissions reduCtions: This is because weather pattemscan contribute to yearly

differences in PM 2.5 concentrations from area to area.

On page 25 of the application, y~ujndicate that utilities cannieettheir budget for nitrous oxide

(NOx) emissions by purchasing eniissions credits. -How many credits were actually purchased

and howinuch impact do these credit purchases actuallyhave on the reduction ofregional No'x

emissi:oIis7 . - .

- -

Vehicle ~ge distribution is an important consideration whtm projecting transportation conformity

budgets and travel d~mand forecasts. Considering that the economy in this areais most likely in

recession, people and companies will most likely hold onto their cars arid fleetvehides much

longer;: which means that it will take longer to phase in newer models that will have reduced

emissions.

In. the application, IDEMhasconinlitted to maintaining certairi con.trol measures atter r~­

designation, and those control measures are listed. IDEM should also provideaJist of control

measures thafwill no longer be required or utilized if this. attainment status is granted..

In the Conective Actions section ofthe application, you indicate that "if a riew measure or -

control isalre;ldy promulgated' and Scheduled to be implemented at the federal or statelev'el, and

thatmeasure or control is determined to be sufficient to address the upwardtrend in air quaiity,

additional local measures will be' unnecessary." Can you please provide clarification on what

criteria will be utilized to determine if a measure or control is suffici~nt? In add}tion, your

contingency measures sedionisloo vague and should be'made clearer. For example, instead of

providing examples of contingency measures that "may" be considered~ you should insteaci"

provide a more comprehensive list of contlngeIicy !Ueasures that could be implemented. .
Save th~ Dunes Comments on PM 2.5, p. 4

Furti:Iermore, it is· oUr belief that your list of factors that will be considered for the selection of

" ... economic and social considerations and.other factors IDEM deems appropriate."

In the li'stof potential contingency measures, you may want to consider having idle restrictions

placed on trucks as well as diesel trains; and, in~tead of wood stove change-outs, you may want

to implement residential wood combustion emissions.reduction strategies.. Residential and

industrial wet,~vacuum street sweeping would help also. Another idea might be to work with area

industries to evaluate their average truck-waiting times and implement more efficient gate·

operations.

Finally, if and when Lake and Porter Counties are placed into attainment, Save the Dunes

requests that you createa Stakeholder Advisory Committee that will help monitor the

maintenance plan. '

Again, thank you' fot the opportunity to comment6n this application.' It is our position that

attaimrient.ofPM 25 in Lake and Porter Counties sho~ld nofbe granted'atthis time.

Sincerely,

DebbkChubb

, Presid~nt

cc: Environmental Protection Agency
Page 1 of 1

Daniel, Pat ..-,~-" "--,-,-,,..-.- - ..---,,-,.- -.-.., -............•.........•._"".•..•._ ,,--_ _ ,..'.--~~,-_.'._-~-'~-_., , ' ".'''''..". ----..".- " .

Sent: Wednesday, February 27,20089:26 AM

To: Daniel, Pat

Subject: pending BP permit

Follow Up Flag: Follow up

Flag Status: Green

Dear Pat,

NO MORE pollution of any kind from SP. First they tried the water, now they want to spew'more pollutants into

the air. I am unwilling to sacrifice my health for them .. or the jobs I'm sure they will claim will be lost if not

allowed to proceed. Please say NO

to their permit request.

Sincerely,

Laura Demchuck

7007 Forest Ave.

Gary, IN 46403

Climb to the top of the charts! Play the word scramble challenge with star power. PlgYDQW!

3/13/2008
Daniel, Pat

From:

Sent:

Follow Up Flag:

Flag Status:

Donna Norkus [dnorkus@ureach.com]

Tuesday, February 26, 2008 8:56 PM

BP Emissions

Follow up

Green

The Clean Air Act and/or Clean Water Act should not be usurped in favor of a nongovernmental entity's desire to expand at low cost. It is possible to achieve expansion

while honoring regulations currently in effect nationally. The only real barrier to doing

so is the desire for even greater profits. Do not give in to this corporate greed.

Protect the citizens of northwest Indiana, as well as the environment, to the best of your

ability by telling BP no.

There is no reason to trade breathable air for jobs. BP can achieve its expansion while

complying with existing regulations.

I believe your job is to protect the citizens and the environment of Indiana by ensuring

compliance with existing law.

Please continue to do so.

Donna Norkus

Beverly Shores

1
Daniel. Pat

From:

Sent:

Follow Up Flag:

Flag Status:

leslie@leslienuss.com

Ut:~'UdIY, February 26,200810:01 PM

Follow up

Green

Hi, I am somewhat new to NWI and at first I thought Irrdiana was a great clean state and

lately I am learning more and more about how lax the environmental regulations are and how

polluted this state is and our water, air, etc.

Please don't cave in to corporate pressure. BP can afford to be environmentally

responsible. Please do not let them spew their pollution into our air. We will all bear

the costs if you give BP corporate welfare by letting them off the hook instead of

treating their pollution responsibly.

In the late 80's I started the recycling programs for the University of Illinois at

Urbana-Champaign. I know from my involvement there that we need good people with integrity

to be leaders in calling for corporations to respect the health of the people who live

where they have businesses.

If you work for IDEM, you must know about the dire state of planet earth.

We need people who will fight for what is right and not cower under the dangling dollars

and intimidation of corporations.

Please be that person.

thank you,

Leslie Nuss

1
Daniel. Pat

From:

Sent:

Subject:

Follow Up Flag:

Flag Status:

jim!george fig.ace@earthlink.net]

March 11, 2008 2:41 PM

Fw: correct email to IDEM

Follow up

Completed

Mr. Daniel, I totally agree with the message below. NO MORE POLLUTION, PLEASE! Regards,

Jim George, Ogden Dunes, In.

-----Forwarded Message-----

>From: odnewsletter@comcast.net

>Sent: Mar 11, 2008 1:34 PM

>To: odnewsletter@comcast.net

>Subject: correct email to IDEM

>

> Sorry here's correct email:

>

>pdaniel@idem.in.gov

>

>This attainment application is too premature for several reasons.

>First of all, while IDEM is allowed to use data from 2004, 2005 and

>2006 as the design values for the application, we request that the 2007

>data be added to this application prior to submission to EPA. This is

>especially important because one of the critical monitors listed,

>located at the Water Plant on Madison Street in Gary, just began operating in July 2005.

>

>Another reason this application is too premature is because while many

>regulations exist, such as the Clean Air Interstate Rules (CAIR), that

>will help reduce PM 2.5, some of these regulations have just recently

>gone into effect or will not take effect for several years. As a

>result, we believe it is too early to fully assess the impacts of these regulations.

>

>

>Include your name & address.

>

>

>Thanks.

1
Daniel, Pat

From:

Sent:

Follow Up Flag:

Flag Status:

Jlm!george Ug.ace@earthlink.net]

February 26, 2008 3:32 PM

BP

Follow up

Green

Dear Pat Daniel, Please do not allow SP to increase soot emmisions. Our air is dirty

enough. We do not need more particulates of anything in our air. We should be

decreasing, not increasing anything. e'mon, do the right thing for our sake. Thank you.

Jim George

1
rage 1 Ul 1

Daniel, Pat

From:

Sent: Wednesday, February 27,20089:39 AM

To: Daniel, Pat

Subject: NO

Follow Up Flag: Follow up

Flag Status: Green

It is unconscionable to pennit even more soot and other particulates into the air and lungs ofthe people

of Northwest Indiana. Do not support this tragedy.

(The Rev) Charles H. Hensel

8414 Oak Ave

Gary, IN 46403

3/13/2008
rage 1 or 1

Daniel, Pat

From: Kurt nlrll",nl-,rrot-,!£

Wednesday, March 19,20085:09 PM

To: Daniel, Pat

Subject: BP Permit

Follow Up Flag: Follow up

Flag Status: Green

Dear Sir,

The permit for BP to continue polluting Northwest Indiana should not be granted,

You and I both know that the public meeting was stacked with BP employees and their families. Most

were probably paid to be there. This is and has been a common occurrence in Indiana for the last half

century. In addition, you and I both know that the release oflead into the already toxic air of northern

Indiana will cause more problems for the children ofour area. Now you may not care, but we who live

here do. You may not know, but I do, that sooner or later all the industry in this part and other parts of

the state will eventually either clean up their pollution or die from it. It really is just a matter ofwhen. Is

100 years enough to get the pollution under control? 200 years perhaps, or 500 more than that? If we

begin now the clean-up will be easier and fewer people will die from cancer.

BP will not go out ofbusiness ifforced to stop all pollution in the air, soil, and water of bur home

environment. They will not shut the plant. They will comply if and when we get smart about the damage

being caused and find the political will to do the right thing and stop poisoning our nests.

Thank you,

Kurt Oldenbrook

Be a better friend, newshound, and know-it-all with Yahoo! Mobile. IryjtJ1QW.

3/27/2008
Daniel, Pat

rctgc 1 Vl 1

From:

Wednesday, March 19, 2008 3:45 PM

To: Daniel, Pat

Subject: IDEM wants to designate NWI in "attainment" for soot potentially allowing more

Follow Up Flag: Follow up

Flag Status: Completed

This attainment application is'too premature for several reasons. First of

all, while IDEM is allowed to use data from 2004, 2005 and 2006 as the design

values for the application, we request that the 2007 data be added to this

application prior to submission to EPA. This is especially important because

one of the critical monitors listed, located at the Water Plant on Madison

Street in Gary, just began operating in July 2005.

Another reason this application is too premature is because while many

regulations exist, such as the Clean Air Interstate Rules (CAIR), that will help

reduce PM 2.5, some of these regulations have just recently gone into effect or

will not take effect for several years. As a result, we believe it is too early

to fully assess the impacts of these regulations.

John Defauw

5865 Dunes Highway

Ogden Dunes,ln 46368

Create a Home Theater Like the Pros. Wi'ltGb tbE:lyi<:fE:lQQnAQlHoIl1El.

3/27/2008
Daniel, Pat

From:

Sent:

Follow Up Flag:

Flag Status:

Nina Klooster [ninaklooster@mac.com]

Wednesday, February 27,20089:53 AM

Polution in NWlndiana

Follow up

Completed

I am seriously concerned about the incident of diseases like cancer and neurological

problems in areas like Hobart and Gary. IDEM please wake up and get the facts about

childhood cancer. Please stop pretending to be interested in the environment and protect

the citizens from these health hazards. Nina Klooster 1438 W 700 N Lake Village, IN 46349

1
Following is a summary of the comments received and IDEM's responses thereto:

Summary/Response to Comments Received at Public Hearing

Comment: Commenter asked how permitting the emission oflarger quantities of

toxic soot could help IDEM to meet their mission to encourage and aid businesses and

citizens in protecting and improving Indiana's environment. (Kroczek)

On February 27,2008, the Indiana Department of Environmental Management (IDEM)

conducted a public hearing concerning the draft redesignation request ofthe annual fine

particulate matter (PM2.s) standard for Lake and Porter counties, Indiana. Comments

were made by the foHowing parties:

Kroczek

Coleman

George

Kirulis

NiSource

U.S. Steel

Karen Kroczek, Concerned Citizen

Mark Coleman, Concerned Citizen

Lisa George, Resident

Karin Kirulis, Resident

Mark Strimbu, NiSource

Jim Alexander, U.S. Steel

Northwest Indiana Redesignation Request and Maintenance Plan in

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Petitioning U.S. EPA to redesignate the area to attainment and reclassifying the

area to maintenance means that IDEM is committed to ensuring that air quality

that meets the annual fme particle standard is maintained. As such, new and

expanding businesses would be required to demonstrate that their emissions would

not cause or contribute to a re-violation of the standard.

Comment: Commenter referenced an article from Argonne National Laboratory that

warned ofhealth, environmental and aesthetic risks ofsoot. The commenter summarized

how soot particles are formed, the health effects and the environmental damage ofsoot,

particularly fine particles. (Kroczek)

IDEM agrees with the commenter on the potential health and environmental effects

of exposure to elevated levels of rme particles and strives to assure that communities

in Indiana comply with the health based standards as expeditiously as possible.

Comment: Commenter encouraged IDEM to establish and enforce laws and

regulations that promote good stewardship, health, wealth and competitiveness.

(Kroczek)

IDEM acknowledges comments provided.

1
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Comment: The commenter opposed designating or redesignating Lake and Porter

"""'2""""~""",,:£g,J:W..tj,~§,,tQ,,~ttill,,~J1t~tJltlJSc;B"CQmm,e.11t~I",£tatetLihat,itjs;;;llll:l.7easonable,andMlo.gical,tQ""""""ee"""""""""""",,

designate the area to attainment since the area was designated as the worse and most

unhealthy place to live by at least two nationally distributed magazines. (Coleman)

Lake and Porter counties have measured air quality that meets the annual rme

particle standard since 2003 and many of the other health based air quality

standards, as well. Air quality in the region has improved significantly over the past

ten years. The criteria used for the assessment referred to are based on factors that

are not comparable to air quality standards. IDEM's assessment is based on

evaluation methods set by the U.S. EPA to measure compliance with the standards

and air quality in the area is in compliance.

Comment: Commenter stated that the methods the state uses to determine attainment

are flawed. Congress has voted on a resolution to stop a permit issued by the state to BP

(Amoco) which would allow more pollution into Lake Michigan. (Coleman)

The state uses the evaluation methods established by U.S. EPA to measure

compliance. The resolution passed by Congress was in conjunction with a water

permit, not air quality attainment status.

Comment: Commenter stated that it appears that the reason IDEM wants to

redesignate Lake and Porter counties to attainment status is, according to the newspapers,

to make it okay for expanding businesses and new businesses to add more pollution into

the already polluted air. (Coleman)

Comment: The commenter asked "Why do we need to redesignate to pollute more?

Why couldn't we just shift the amount ofpollution? If you want new companies to come

in and to be able to pollute why can't you take some ofthe allocation that you have from

U.S. Steeland other polluters...reduce the amount that they can pollute so that new

businesses can pollute?" (George)

In response to the two comments abov,e, IDEM is petitioning U.S. EPA to

redesignate the areas to attainment because air quality in Lake and Porter counties

is in compliance with the annual fine particle standard and should be redesignated

back to attainment.

Large projects that may represent emissions. increases beyond normal expected

growth would be subject to the new source review permitting program for

attainment areas known as Prevention of Significant Deterioration (PSD). New

major sources or major modifications of existing sources must install best available

control technology and demonstrate that the resulting emissions would not cause or

contribute to a violatipn of any national ambient air quality standard. These permits

are subject to public review, comment and the opportunity for a public hearing to

help ensure that these requirements are satisfied.

2
Comment:

(George)

Commenter asked ifthe level ofpollution would get worse than it is today.

Ifthe area is redesignated to attainment and classified to maintenance for the

annual rme particle standard, IDEM has committed to assuring that air quality is

maintained. The Clean Air Act requires that areas with maintenance plans ensure

that there's no backsliding with regard to measured air quality. Precursor

emissions that contribute to rme particle concentrations cannot increase over time.

The document addresses future year modeling with national, regional and local

emission control strategies already in place and strategies to be implemented in the

next few years. Air quality is projected to improve over the next ten years and

continue to attain the current annual rme particle standard. Future year modeling

takes into account projected emissions increases from industry and population

growth, as well as emissions controlstrategies.

Comment: Commenter asked "Ifair quality is getting better, why do you have to

change the designation?" (George)

Lake and Porter counties have measured air quality that complies with the annual

rme particle health based standards since 2003. Therefore the area is eligible for its

air quality status to be classified consistent with other counties in the nation that

measure air quality that meets the standard.

Comment: Commenter stated that she doesn't trust the numbers that IDEM has. She

lives in the area, breathes the air and smells it. She doesn't think it's healthy no matter

what the numbers say and no matter what EPA says. (George)

Methodology used in the document to demonstrate attainment of the standard, as

well as certified quality assured monitoring data is readily available and verifiable

in U.S. EPA guidance documents. .

Comment: Commenter asked "if you find that the particles are more than they should

be, what specifically do you do? Do you tell U.S. Steel to shut down for a couple of

weeks?" (Kirulis)

If emissions start increasing after the area is redesignated, or monitored

exceedances occur, as part of the maintenance plan, IDEM commits to taking swift

action in order to reverse the trend and take whatever action is necessary to ensure

that air quality is re-attained as expeditiously as possible.

Comment: The commenter provided suggestions to help IDEM clarify statements

made in the document. The first comment was on page 7, where it references the design

value. It refers to the air quality and design value for the area as the highest design value

among all sites in the area. Ifthe statement references Lake and Porter counties only, it

should be revised to make that clear. On page 23, Section 3.4, it states that IDEM has

3
quality assured all data shown in the tables. One ofthe tables show information from out-

.' ;.;.. .2,fg;§l~l~.mQ.t!j.t~n:§;;~m,~;Lilsk~lij:[tl1atsJ,atenl~nLis.Jf.ul}L,c.Qn:e£.toIjfJDEMjs;rflspj)nsiblfl.;foI:c;;;.;.;;;;;;.;;.,;.;.;.~.; ;;;;;.;;

State of Indiana data only. (NiSource)

IDEM appreciates the suggestions and will revise the document accordingly.

Comment: Maybe a good corollary might be the course particulate matter regulations,

PMI0. Coarse particles have been regulated for a while, for which we are in attainment.

There's a maintenance plan in place that ifour company is found culpable in exceedance

ofthat, we have to submit a 25 percent source wide reduction ofour particulate matter

within 180 days. So the position ofU.S. Steel on this is that there are regulations in place

that allow IDEM to seek attainment for counties that are in attainment ofthe Clean Air

Act and ofthe standards. (U.S. Steel)

Comment: These standards went through a lot ofscientific review. And I sympathize

with the people that breathe it, it's me and my family also, and I know the damage that it

causes. But these standards were set by scientists to designate healthy air. It's IDEM's

job to regulate industry and point sources, and area sources and mobile sources to get us

into attainment. Now, ifwe believe that 35, or in this case, the standard of 15 on an

annual basis, is too high and what we need to do is to get that standard lowered from 15,

not to attack the redesignation. (U.S. Steel)

Comment: If we do redesignate, not one limit at Gary Works is relaxed. It does not

allow us to pollute more. It does change, in some cases, new source review for new and

modified sources, but it makes it more difficult for us to modify or add, because you have

to stay in attainment ofthe standards. (U.S. Steel)

IDEM appreciates the preceding comments and the support to redesignate the area

to attainment.

Summary/Response to Comments Received During Comment Period

IDEM requested public comment on the draft redesignation request for Lake and Porter

counties from January 28,2008 through March 11,2008. IDEM received comments from

the following parties:

Sandy O'Brien, Dunelands Sierra Club

Karin Kirulis,

Michele Bonneau

Jim Sweeney

Lou Gagliardi

Patricia and Richard Gonzales

Dean Squire

Jean Smith

Lynda Jorgensen

Dunelands

Kirulis

Bonneau

Sweeney

Gagliardi

Gonzales

Squire

Smith

Jorgensen

4
Joanne Lehmann

Ron Wennekes

Bessie Dent, The Calumet Project

June Hardy

Patrick M. Gordon, Indiana Steel Environmental Group

James W. Flannery, The Northwest Indiana Forum

Janet G. McCabe, Improving Kids Environment

Laurel L. Kroack, IL Environmental Protection Agency

Debbie Chubb, Save the Dunes Council

Laura Demchuck

Donna Norkus

Leslie Nuss

Jim George

Charles Hensel

Kurt Oldenbrook

John Defauw

Nina Klooster

Lehmann

Calumet

Hardy

ISEG

NWIForum

IKE

ILEPA

SAVE

Demchuck

Norkus

Nuss

JGeorge

Hensel

Oldenbrook

Defauw

Klooster

Following is a summary of comments received and IDEM's responses thereto:

Comment: The commenter expressed concern with the impact ofmore use ofwood

burning stoves of any type for home heating a,s natural gas and electricity prices continue

to rise. Users should be required to use the latest technology to be as low in pollution as

possible. (Dunelands)

This is an issue of national concern. The Environmental Protection Agency has

launched a voluntary partnership program to reduce air pollution from outdoor

wood-fired boilers and has implemented a program to certify new wood stoves and

fireplaces as energy efficient. Emissions from wood combustion sources were

included in the base-year inventory and expected growth is reflected in the future

year inventories.

Comment: Commenter expressed opposition to the granting ofPM2.5 attainment to

Lake and Porter counties. There are too many unresolved questions regarding increased

air emissions at BP, as well as other industries in northwest Indiana, in the near future.

(Kirulis)

Potential developments, that we're aware of, were considered as part of the

maintenance plan when we estimated economic growth and the corresponding

increase in emissions. Emissions are expected to be lower in ten years than they are

now. There are additional emissions controls "on the books" that have not been

fully implemented yet, and these will help offset area growth. In addition, major

new sources will be subject to new source review permitting under the Prevention of

Significant Deterioration rule requiring best available control technology and a

5
demonstration that the emissions will not cause or contribute to a violation of any

Comment: Commenter expressed concern that the 2007 results from monitors are not

examined in the application, especially the Gary monitor with a level above the standard

of35 micrograms. (Kirulis)

As stated in the introduction section of the document and in the public notice for

this hearing, an addendum was added to the document and placed on the website

prior to the public hearing containing an analysis of the 2007 monitoring data. It

shows that all of Indiana's annual population-exposure monitoring sites continue to

demonstrate attainment from 2005 - 2007.

Comment: Commenter asked "Is there no one that will stand up for our future air

quality? Not even those we elected to do this job for us? Who will your children blame?"

(Bonneau)

IDEM intends to continue cooperating and working with other states through the

Lake Michigan Air Directors Consortium on regional planning initiatives. IDEM

has participated in regional planning and modeling of projected future emissions,

including proposed controls on large utilities, on and off road vehicles, and fuels,

and has determined that the standard will be met by an increasing margin of safety

in the coming years.

Comment: Commenter strongly opposes the designation ofLake and Porter counties

as "in attainment" ofthe PM2.5 standard. Commenter believes the move is based on

economic concerns, not public health, and that the redesignation is the result of an

organized effort ofthe U.S. EPA and IDEM to promote increased industrial production in

northwest Indiana. (Sweeney)

The NAAQS are based upon multiple studies developed by independent scientists to

be protective of public health and the environment. It was determined that the

current standards are protective of public health. Ambient annualrme particle

levels measured in Lake and Porter Counties meet these standards.

Comment: The commenter mentions the known health effects that are the result of

exposure to tine particulate matter and cited several studies with findings that provide

evidence that fine particle concentrations below the national standard are harmful to the

cardiovascular and respiratory health of elderly citizens. (Sweeney)

IDEM agrees that there are known health effects associated with exposure to

elevated levels of fine particles. However, the federal ambient air quality standards

are set at levels that are determined to be protective of human health. The standards

are reviewed every five years to determine whether the standards are sufficient to

protect public health. In 2006, the U.S. EPA determined that the current annual

standard for rme particles is sufficient to protect public health. As studies continue

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into the future, that information will be used to determine ifthe air quality

standards remain the same or need to be

Comment: Several commenter provided comments that the attainment application is

premature. The commenter noted that IDEM used data from 2004, 2005 and 2006 as the

design values in the application; the commenters requested that the 2007 data be added to

the application prior to submittal to U.S. EPA. (Gagliardi) (Gonzales) (Squire) (Smith)

(Jorgensen) (Wennekes) (Light) (Hardy) (SAVE) (Defauw)

As stated in introduction section of the document and the public notice for this

hearing, an addendum was added to the document and placed on the website prior

to the public hearing containing an analysis of the 2007 monitoring data. It shows

that all of Indiana's population-exposure monitoring sites continue to demonstrate

attainment from 2005 - 2007.

Comment: Several commenters also noted that although many regulations exist, such

as the Clean Air Interstate Rule (CAIR), which will help reduce PM2.5, some ofthese

regulations have just recently gone into effect or will not take effect for several years. As

a result, they believe it is too early to fully assess the impacts ofthese regulations.

(Gagliardi) (Gonzales) (Squire) (Smith) (Jorgensen) (Lehmann) (Wennekes) (Light)

(SAVE) (Defauw)

Lake and Porter County monitors have shown attainment for several years, since

2003, which reflects the impact of federal and state rules which are currently in

effect. Modeling shows that future reductions resulting from the new rules will

continue to further reduce PM2.5 levels.

Comment: Several commenters support the comments submitted by Save the Dunes

Organization. (Dunelands) (Calumet) (Hardy)

IDEM acknowledges receipt of the comment

Comment: Commenters strongly support IDEM's draft petition for redesignation of

Lake and Porter counties as attainment for fine particulate matter. (ISEG) (NWI Forum)

Thank you for your support.

Comment: Commenters point out that Lake and Porter counties can only theoretically

"contribute" to violations at the Cook county monitors at Cicero and Wilson Avenue

when the wind is blowing one finite direction - from the southeast. EPA's own wind

rose analysis indicates that prevailing winds blow away from the violating monitors more

than 90% ofthe time, http://www.epa.gov/region5/sites/indianaharbor/. The commenters

suggest that IDEM incorporate this point more prominently in Section 3.3 ofthe

redesignation petition. (ISEG) (NWI Forum)

7
IDEM appreciates the comments and will review the document to determine ifthe

Comment: The commenters concur with IDEM's conclusion that since the area

attained the standard prior to an Attainment or RACT SIP being due, and since the

implementation rule for fine particles stipulates that states are only required to draft and

implement RACT rules for the precursor emissions reductions necessary to attain the

standard, no further RACT rules are required for this area. (ISEG) (NWI Forum)

IDEM appreciates the support. Itshould be noted that the majority of major

sources for NOx within Lake and Porter counties are subject to the NOx SIP Call,

thereby meeting RAeT requirements for NOx' Therefore, any reductions to be

gained through the applicability of NOx RACT for Lake and Porter counties would

be negligible.

Comment: The commenter opposes IDEM's intent to seek redesignation of Lake and

Porter counties for the fine particle health standard. The commenter states that

redesignation ofthese counties is not the best way to achieve public health and economic

goals ofthe region, and will undermine the 15 year commitment among the Lake

Michigan states to work collectively to solve regional air quality challenges. (IKE)

IDEM contends that the area and the associated petition meets the requirements for

redesignation contained in the Clean Air Act, and therefore, it should be

redesignated to attainment. IDEM intends to continue working cooperatively with

LADCO and the other LADCO states to address regional air quality issues, and that

cooperation is not dependent on the designation status of Lake and Porter counties.

Comment: The commenter states that it is premature for Indiana to seek to

redesignate its counties in this multi-state, regional nonattainment area while monitors

elsewhere in the region still violate the standard. (IKE)

Ambient air quality in Lake and Porter counties has measured annual fine particle

levels in compliance with the standard since 2003. Furthermore, IDEM has

conducted an analysis to determine Indiana's culpability on downwind monitors

~nd has determined that Lake and Porter counties do not primarily impact

monitored violations in the Chicago area and additional controls in Lake and Porter

counties will not provide for attainment of the standard in the Chicago area.

Comment: The commenter states that air quality data do not support this designation.

Based on 2004-2006 data, two monitors in the nonattainment area continue to monitor

violations ofthe standard and that 2005-2007 monitoring data show five monitors in

violation. (IKE)

Please see response above.

8
Comment: Commenter mentions that Lake and Porter counties are part of a multistate

a a area before the entire area has attained. Based on

conversation with U.S. EPA Region V staff, the agency has never approved such a

request. (IKE)

IDEM is aware of the fact that by approving this redesignation petition, U.S. EPA

will be setting precedent. Nevertheless, Lake and Porter counties have attained and

maintained air quality that is in compliance with the annual fme particle standard,

and thereby eligible for redesignation, based on Section 107(d) of the Clean Air Act.

Comment: Like ozone in some respects, PM2.5 is a regional pollutant. The main

sources of emissions in the S02 and NOx inventories are point sources in Lake and

Porter counties and nearly halfofthose emissions come from electric generating units,

whose emissions can travel regionally. Because ofthe concentration oflarge and

numerous point sources as well as significant emissions from motor vehicles, U.S. EPA

guidance treats large metropolitan areas (even ifthey are multi-state) as a single

nonattainment area. (IKE)

IDEM has evaluated monitoring data on a case-by-case basis and determined that

monitored concentrations throughout the region are closely representative of

background levels, with the exception of a few monitoring sites in Cook County,

Illinois. IDEM has determined that Lake and Porter counties are not primary

contributors to measured levels at those sites. A number of monitoring sites located

between and/or around the site locations with values above the standard measure

air quality below the standard. IfLake and Porter counties were primary

contributors to monitored violations in Northwest Illinois, these sites would

maintain values above the standard as well. IDEM believes that the sites that

measure air quality above the standard are affected by localized urban excess that is

not attributable to Lake and Porter counties. LADCO modeling shows that EGU

and mobile source emissions from Lake and Porter counties impact Cook county

monitors at levels less than 0.1 ug/m3.

Comment: The commenter noted that several monitors in Lake County do not meet

the recently revised PM2.5 daily standard of35 micrograms per cubic meter, based on

2005-2007 data. These counties are very likely to be designated as nonattainment under

the revised standard and it will serve little purpose to redesignate them now to attainment

for the annual.standard. The commenter contends that doing so would likely confuse the

regulated industry and the public about whether air quality does or does not meet health

standards and what permitting rules apply. (IKE)

This document only addresses the annual fme particle standard. Designations have

not been made for the revised 24 hour (daily standard) for fine particles. There are

only two monitors in Northwest Indiana that currently do not meet the revised daily

PM 2.5 daily standard of 35 micrograms per cubic meter, based on 2005-2007 data.

Those two monitors are the East Chicago (35.5 ug/m3) and Gary Burr Street (36.9).

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The Gary Burr Street monitor is a source oriented monitor and is intended to reflect

.·:.::":,.:.,.,~,ir"QJ,udl~,,ill.a..r,elati;¥:eJ¥:;s:lllalLg,eogltap,hic"av.ca.,db:e.ctly,.influenced",by,a"spemfi.c"",b,,,:",,bn,,",.,,••,," ""'n,"""'"''''''''''''

source or sources of air pollution. This monitor is not used to determine attainment

with the annual fine particle standard, but U.S. EPA determined it could be

compared to the daily standard. IDEM considers these to be hot spots and not

reflective ofthe overall air quality in the area.

The East Chicago monitor in Lake County is slightly above the 24-hr PM standard,

however, photochemical modeling results show that by 2009 the monitor will be in

attainment.

Comment: The states ofIllinois, Indiana, Wisconsin, Michigan and Ohio have

worked cooperatively for many years to improve air quality throughout the region.

Although air quality has greatly improved as a result ofour joint efforts, violations ofthe

annual PM2.5NAAQS are still occurringin our region. We believe that emissions from

Lake and Porter counties contribute significantly to ongoing violations ofthe annual

PM2.5 standard. Therefore, IL EPA strongly opposes Indiana's redesignation petition. (IL

EPA)

IDEM has conducted an analysis to determine Indiana's culpability on downwind

monitors and has determined, as summarized in this document, that Indiana's

portion of the nonattainment area does not primarily contribute to monitored

violations of the standard within the Illinois portion of the nonattainment area.

Lake and Porter counties are subject to the most stringent group of emission

controls within the state of Indiana. This collection of permanent and enforceable

controls is as equally stringent as those that apply elsewhere within the

nonattainment area, and in some cases, more stringent. Indiana believes that the

monitoring sites in Cook County, Illinois that currently measure rme particle

concentrations above the standard are affected by localized "urban excess", mostly

attributable to localized mobile and fugitive sources.

IDEM intends to continue working cooperatively with LADCO and the other

LADCO states to address regional air quality issues, and that cooperation is not

dependent on the specific designation of Lake and Porter counties.

Comment: As Indiana's petition notes, PM1.5 concentrations exceeding the level of

the annual NAAQS were measured in northeastern Illinois during the 3-year period,

2004-2006, used in your analysis. Based on the most recent 3-year period, 2005-2007, a

violation ofthe annual PM1.5 NAAQS has been measured at the Illinois monitoring

station at the Washington High School. This monitoring station is the closest Illinois

monitor to Lake County, Indiana. (IL EPA)

Analyses performed by IDEM show that background concentrations and local

sources have much greater impact on the Cook County, IL monitors than sources in

NWIndiana.

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Data for 2005-2007 indicates that a total of five sites in Cook County have exceeded

the annual NAAQS. This includes the .site...~l~..s.~s.tt~~Il~i~Il~;~?g~~o~~~'I~~~?'§·i '.11.11

IljJ:4th;Strecet,··elricag·o:··rt...Kts"sit~·i§~lts·slfie(rasapopiiliifion';exposure'sIfe:IUs1lii-"ee" .

year design value is 15.3 uglm3

•

There are two additional monitoring sites in close proximity to 170310022, one at

103rd and Luella Streets in Chicago (170310050) and one at Robertsdale in

Hammond (180892010). Site 170310050 has a 2005-2007 design value of 14.7 uglm3

•

Site 180892010 has a design value for the same time period of 14.0 uglm3

• Indiana

believes local impacts, primarily from fugitive sources are the reason the

Washington High School monitor is exceeding the standard, since there isn't a

similar regional pattern among the monitors in close proximity.

Comment: To further establish that emissions from Indiana are contributing to

elevated PM2.5levels at Washington High School, the Illinois EPA developed a

"pollution rose" for this site, to illustrate the average PM2.5 concentrations at this location

based on the wind direction occurring during times of elevated PM2.5 levels. Please note

the high average contributions occurring at Washington High School when winds are

from easterly through south-southeasterly wind directions. It is also noted that southerly

through westerly wind directions also contribute to elevated PM2.5 levels, but these

directions are consistent with the climatological frequency ofwinds throughout the year.

It is obvious that elevated PM2.5 from the easterly wind directions are over-represented

relative to the frequency ofwinds from those directions. Again, these results are

suggestive oflocal impacts from sources in Lake and Porter counties to the measured

PM2.5 violations at Washington High School. (IL EPA)

A summary of the data from 2005 through 2007 indicates that on the higher PM2.S

days, surface and upper air winds came from every direction. The majority ofthe

winds on the higher PM2.5 days came from the south, west and east directions. The

back trajectories show that a majority of the previous day's air came from the

south, west and southwest with more stagnant conditions when the air was recirculated over the area. This information suggests that the Illinois monitors are

impacted from all surrounding areas and local emissions appear to be the difference

between sites attaining or not attaining the NAAQS.

To further demonstrate this point, LADCO conducted annual PM2.5 particulate

source apportionment (PSAT) modeling for the Illinois monitoring sites. This

modeling shows the regional and emission sources that impact a PM2.S monitoring

site. The PSAT results show that the Illinois monitors are overwhelmingly impacted

from the Chicago, Illinois portion of the Illinois PM2.5 nonattainment area, with a

large portion ofthe impact from area, marine/airplane/rail, mobile and non-EGU

emission sources. Lake and PorterCounty emissions have lesser impacts than

Wisconsin, Illinois and boundary condi(ions.

11
Chart 1 below shows the PSAT results for the Washington High School PM2.5

;"mU,Uit<lJZmg;;~iteb,l£hile"LAkeLr;j)x,teJ",,~ounties,;ha;Mee,$ome"impaet,c"thc";,mouitoJZ,,is,e-,,,,',,,,,,,,,,c;;c,,,,,,,,,,,, i""c,,;

impacted by all surrounding areas.

Chart 1

II. - Cook: (17031)022) baseM3

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sector EGU _ nonEGU

onroad area

nh3

BC

Avg Cone = 15.3 ug/m3

Region 1iOiiiiiii....----------------------------,

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Indiana Illinois 11==,"=_:- II ,,",'

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o 1 2 3 4 5 6 7

Concentration (ulifm3)

Comment: For its Clean Air Interstate rulemaking, U.S. EPA considered a 0.2 uglm3

contribution from an entire state a significant contribution for PM2.5. Recent modeling

performed by LADCO demonstrates that Lake and Porter counties by themselves

contribute amounts that are far greater than U.S. EPA's thresholds at monitors in Cook

Countythat are exceeding the annual PM2.5 standard. There is no technical basis for

Indiana to conclude that sources located in Lake and Porter Counties do not significantly

contribute to nonattainment in adjacent states. (IL EPA)

Indiana has adopted the Clean Air Interstate Rule, which is intended to address

power plant contributions to downwind nonattainment areas. Indiana is also

analyzing other stationary source control measures that could address additional

downwind contributions. Such measures are not limited to Lake and Porter

sources, and do not require a nonattainment designation in Lake and Porter

counties in order for the state to adopt them. Indiana commits to maintain all

emission control measures that have been implemented in Lake and Porter counties,

including the vehi~le inspection and maintenance program.

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If emissions deriving from Lake and Porter counties were significantly contributing

to the violating monit?rs inIllin.0is, ",e."'?lll<l.~~p~~tt?se.e.si~~~.. ~l~~ated~alu~s~t. ., ....•....•J"" +;T:lfe''Sites"ttrc'ateid·1jelW~·en"'Efi1t~i1tn8.··Po·rter··c(riiiilies a"'fi<l"lllc''Cfcero ·ano-cWUsou·Ave:;'···T"..•".···

and in Lake and Porter counties.

The location of the two violating monitors in Northeast Illinois results in elevated

concentrations representative of localized "urban excess", primarily attributable to

localized mobile and fugitive source emissions. Indiana is confident that its

contribution to this localized effect is negligible.

Comment: Lake and Porter counties are tied to the Illinois nonattainment counties

geographically and economically and reside in the same lakeshore environment. U.S.

EPA guidance clearly states that these factors must be considered when the states

recommend the boundaries of a nonattainment area. (IL EPA)

Indiana's petition is to redesignate a portion of the interstate nonattainment area,

not to revise the statistical boundaries, as allowed in Section 107.(d)(3) of the Clean

Air Act.

Comment: Redesignation ofIndiana's Lake and Porter counties to attainment will

exacerbate the problem in that it allows Indiana to avoid taking the necessary steps to

address the regional emission problems and instead would allow the counties to comply

with lesser standards that may lead to a worsening of air quality. (IL EPA)

IDEM has demonstrated in its petition that it meets the requirements for

redesignation contained in the Clean Air Act, and therefore, should be redesignated.

However, redesignation does not bar IDEM from continued interstate efforts to

improve air quality. IDEM intends to continue working cooperatively with the other

LADCO states to address regional air quality issues.

Comment: Determining the chemical make-up of a particle - known as speciation - is

an important part ofthe effort to reduce PM2.

5 levels and is accomplished largely through

data generated by EPA's ambient air speciation monitoring program. The commenter is

concerned that 2007 results from area speciation monitors are not reflected in the

application. While these results may not be need to be considered in this application, it

must be noted that a number ofthe readings were above the daily standard of35

micrograms at the Gary IITRI monitoring location. (SAVE)

Speciation data has not been reviewed for the Gary IITRI monitor. While some

values may currently be above the revised daily PM standard of 35 micrograms per

cubic meter, the 3-year design value is 34.7 and below the standard. Designations for

the new daily rIDe particle standard have not been made. IDEM anticipates that if

the designations are made in 2009, the area will have realized air quality benefits

from recently implemented measures and may not be violating the daily standard

when designations occur. .

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The Environmental Protection Agency has launched a voluntary partnership

program to reduce air pollution from outdoor wood-fired boilers and has

implemented a program to certify new wood stoves and fireplaces as energy

efficient.

Comment: One ofthe major purposes of LADCO, as stated in a Memo ofAgreement

for Interstate Air Pollution Study and Control, signed in 2004 by former IDEM

Commissioner Lori Kaplan, is the development ofmulti-state, multi-pollutant planning to

support the development of effective control plans to address regional pollution problems

such as ozone, fine'particles, regional haze and air toxics. IDEM's determination that

"emissions from Lake and Porter counties do not affect the downwind area's ability to

attain the fine particles standard violates the spirit ofthat Memo ofAgreement. (SAVE)

The purpose ofthe Redesignation Petition and Maintenance Plan is to demonstrate

and ensure that compliance of the air quality standard will be maintained in the

future. In making this demonstration, we have estimated emissions 10 years into the

future and taken into account expected economic growth. Our estimates show that

even with growth, declining emissions due to the Clean Air Interstate Rule, new

engine and fuel standards and other measures will ensure that the annual fine

particle standard will be maintained. We will continue to monitor emissions and ,me

particle values.;closely, and the maintenance plan has triggers that require IDEM to

take action even before an actual violation of the standard would occur.

I Comment: Commenter noted that it was not clear that the emissions inventory and

~"'~=c,~c"",c",",,,,, ,;iii",,';;;';';';; i,0i;;~sJimale£j,nc1llde",ill1po;ri.anLpatential:;fut'ur~emi~8i@n8,;tr@n1:~seveFal;;cSOljll1G€S~;"i1iJ.~I:u<1l:ill@;tlle"~"s;;""",,,,, .

I expansion ofthe BP Whiting Refinery, the BP asphalt Plant, the expansion ofthe GaryI Chicago International Airport and the increase in the use ofresidential wood combustion

I devices, such as outdoor wood furnace boilers. (SAVE)

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IDEM has demonstrated in its petition that it meets the requirements for

redesignation contained in the Clean Air Act, and therefore, should be redesignated.

However, redesignation does not bar IDEM from continued interstate efforts to

improve air quality. IDEM intends to continue working cooperatively with LADCO

and the other LADCO states to address regional air quality issues within the region.

Comment: While trying to demonstrate Indiana's lack of culpability in impacting the

Chicago nonattainment area you used February 3,2005 as an example of a monitored day

higher than the daily standard ofmore than 35 micrograms. It is interesting to note that

the Ogden Dunes monitor was not operational that day, as indicated on Table 3.5 ofthe

application. This begs the following question: How often do any ofthe monitors not

report results, and how are those non-reporting values factored into the annual average?

(SAVE)

U.S. EPA issued the "Guideline on Data Handling Conventions for the PM

NAAQS" in April 1999. These guidelines outline what states are required to do

when there is missing data. U.S. EPA's monitoring guidance stipulates that a

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·1 minimum of 75% ofthe data per quarter must be available in order to determine if

I the design value represents attainment. If less than 75% of the data is valid, then . .. ·1···· i!.;r;i!i!i!0i£C;;:iii£.iii!"i!0;;;'"';ti1e"maXiilium"quarte}:lyiivaIue'f~';fu':tgr~';;;"q;;~~~"~c;;;;'th;'th;;~:yec;'~"p;;rO~ri;·C""=CCCT£ •..;.q;"~i!'?'''''' ••'''i!;

I substituted for all missing samples for that quarter. U.S. EPA also encourages

! states to explore alternative methods for evaluating the data, which Indiana has .,

1 done for any monitorthat has missing data.

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Comment: Under the 3.5 Continued Monitoring Section, you indicate that the existing

monitoring network could potentially be changed with EPA approval. We would strongly

object to any changes that might be made in the network since monitor changes could

potentially be implemented to make the outcomes look more favorable. (SAVE)

In October 2006, U.S. EPA issued f"mal regulations concerning state and local

agency ambient air monitoring networks. These regulations require states to submit.

an annual monitoring network review to U.S. EPA. Each year, IDEM will provide

to U.S. EPA the framework for establishment and maintenance of an air quality

surveillance system and will list any changes that are proposed to take place during

the network season. IDEM discusses changes to monitoring networks with affected

communities and the draft plan is placed on public notice prior to submittal to U.S.

EPA.

In Indiana's 2008 Final Network Monitoring Plan there were several changes to the

PM 2.5 monitoring network, including relocating 2 sites, discontinuing 7 sites and

adding 3 sites. Indiana's 2008 Final Network Monitoring Plan can be viewed at

http://www.in.gov/idem/programs/air/amb/docs/2008 monitoring plan.pdf

Comment: You application must be presented in a manner that demonstrates that

attainment was achieved based on pennanent and enforceable emission reductions. This

application needs to demonstrate more clearly that favorable weather conditions during

the design value years did not heavily influence emission reductions. (SAVE)

Permanent and enforceable reductions ofsulfur dioxides, direct PM2.s, and oxides of

nitrogen have contributed to the attainment of the annual standard for fine

particles. Some of these reductions were due to the implementation of the NOx SIP

Call, and some were due to the application of tighter federal standards on new

vehicles and fuels.

NOx emissions within the Northwest Indiana area are projected to decline by almost

42% between 2005 and 2020. Photochemical modeling supports the continued

decrease in f"me particle concentrations in Lake and Porter counties in the future.

Please refer to Section 6.2 ofthe document for a summary of permanent and

enforceable emissions reductions implemented in the region.

Comment: On page 25 ofthe application, you indicate that utilities can meet their

budget for nitrous oxide (NOx) emissions by purchasing emission credits. How many

credits were actually purchased and how much impact do these credit purchases actually

have on the reduction ofregional NOx emissions? (SAVE)

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