# APPENDIXG Public Participation DocumentationOral statements will be heard, but for the accuracy ofthe record, statements to written comments atthe public hearing. IDEM will also accept written comments through March 11,2008. Mailed comments shouldbe addressed to: 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 Indiana Department ofEnvironmental Management Indianapolis, IN 46206-2251 A transcript ofthe hearing and all written submissions provided at the public hearing shall be opento public inspection at IDEM and copies maybe made available to anypersonupon payment ofreproduction costs. Anypersonheard orrepresented at the hearing orrequesting notice shallbe given written notice ofactions resulting from the hearing. For additional information contactMs. Pat Daniel, at the IndianaDepartment of Environmental Management, AirPrograms Branch, Office ofAir Quality, Room 1001, Indiana Government CenterNorth, 100 North Senate Avenue, Indianapolis or call (317) 233-0429 or (800) 451-6027 ext. 3-0429 (in Indiana).



### ************************************************************************ Individuals requiring reasonable accommodationsforparticipation in this hearing shouldcontactthe IDEMAmericans with DisabilitiesAct(ADA) coordinatorat: Attn: ADA Coordinator Indiana Department ofEnvironmental Management

- Mail Code 50-10 100 North SenateAvenue Indianapolis, IN 46204-2251 Orcall (317) 233-1785 (voice) or (317) 232-6565 (TDD). Pleaseprovide a minimum of 72 hours notification.



### G-3COMPUTATION 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** 

### ..

2008 May II, SS State of Indiana Lake County

My commission expires aforesaid, and thatthe printed matter attached hereto is atrue copy, which was duly publishe in said paperfor :L time , the dates of publication being as**follow~** REDESIGNATION PETITION

......................................................0·····················································

. 

### 1!.??······

..

# ·I7?~··.LQu~7 

# · 

# Subwibedaod ,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~ance** Plan

.. 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 Busj**ness~** 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 AirQuaiity 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 ofwhich

shall total more than four solid lines ofthe type in which the body ofthe advertisement is set). Number ofequivalent lines Head

- Number oflines Body

- Number oflines Tail

- Number oflines

Total number oflines 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 ofpublication ($1.00 for each proofin excess oftwo) T@TAL AMOUNT OF CLAIM DATA FOR COMPUTING COST 

### RECEIVED -STATEGFlfij]jji\-Nif-

.. JAN 3 I 2008
DEPARTMENTOFEllVIRONMENTAlMANAGEMEUT '-- OF

__ FIC;.;.E..:.;OFAIRQUALITY**$---~ $---~** 

$----'-- $ -".0"'0'-**$._--~** $----'--**$---~ $--~-** **$---~**

$

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

$ -".0""0'-

Width ofsingle column 7.83 ems Number ofinsertions --LQ Size oftype 5.7 point $----'--**$--~-** $

__**~5,",3c.>.0",-6** Pursuant to theprovisions andpenalties of Chapter 155, Acts of1953, I hereby certify that the foregoing account isjust and correct, that the amount claimed is legally due, after allowing alljust credits, and that no part ofthe same has been paid.

DATE: 01128/2008

81956-51l13't4 PUBLISHER'S AFFIDAVIT State ofIndiana 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 ofgeneral circulation printed and published in the English language in the city ofINDIANAPOLIS 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: o I128/2008 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= .84881956-5111344 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:lJ1Jy** SW_Qrn, says thatSHE-is clerk

. ofthe INDIANAPOLIS NEWSPAPERS a DAILY STAR newspaper ofgeneral 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 equafs

### I

## Ll0 equivalent lines at 

## d1&ents

### p~rline AdclitiQIl.al charge fornbtices containing rule or tabular work

, (50 percent ofabOveamount), ", ,',

Charge for extra proofs ofp\.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, '".:

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I. h,ereby cer:tify that the foregoing account is jtlst and correct, that the amount claimedis legally due, i;!.,fteralloWing alljust 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)

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### . /
, LegalClerk oftl).eTIMES newspaper of general Circulation printEtd,ahd published in the Ehglish language in the (city) (tiYwn) 

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_______**~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

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## C! 7ell/ JAN 0 1 2008 

### InEPARTMEllTOFElWlRONMEtlTAlMAtlAGEMEtlT ! OFFICEOFAIRQUAUlY , PUBLISHER'S CLAIM

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### -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~~g** **p~;**

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

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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~_of**the

__-'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 for

### 1 time

__ , the dates of publication being:, follows: /) 

## \ Ia-;d j' 6

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. 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.erStreel, 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}F v '
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## 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**-_..:.......----_._~**..-.._.__._._---_._
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### 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,**'~"1~:j;:J;:IQ,ba:cJ~;.s]j~ff;:'i7;I"l;Q;;'0'(3$'I::l;r~r;"C'CC','C,C;** 

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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



### an

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, , , 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"

;".1 

### 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

ease an

i.**. ~**

, - ; : ! : 

## to;

:::.:1...- ._ 

### 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 speakingPAGE 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

, __"

_f

. i 

### 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

i

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## , .. , 

## r i i

....... 

### 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 originallyC', i 

### ,. t.



### r'! 

## i 1**~.** j 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

r: f 

### 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

r" ; 1 ' j"

r' 

### i I' \. 

### 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;.

. ; 

### 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... ..'



# r-: ! I L J 

### 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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} :. t. '

# rf ' 

### 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'tPAGE 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

i ' i



## -, 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( .•.

i i 

### 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 l ( i" ( 

# t." 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 leasti ; i 

### .j**~.** J r"l 

### I !

, I Lj 

### 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 movePAGE 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**!-,,~;,;;,c;,~'·;·;,;;c;;;.;·,·.;;,c;;;;;,,;;';c;;;;c;ccl** ..... ...**~.,~j;;s.;.;;,,.c;,.;;;;;:;j;J:~;;-"!J:ta,t;c.:J:.l;y"** ..**;8:p;pJ2;;0;'J;;;i;;n;:@;;cc;a;,;;;;m::a;;ic"n4~;~·n;;a;;f;'I;'@;ec.cc;;;;pc,l;;;(j!lcl'l;;i;c;;;;;·;tcR;,;e;;,;;{I;v:g;:;;;;;;;;;;,;;,ccc;** 

### 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

. Hearing Location: 

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# 4- No Do you wish to present oral testimony? Has written testimony been submitted? Will written testimony be submitted? Do you wish to be informed of future

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or final**act~ons** in this matter?**~ame:** iearing

## Locat~on: Date: 

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## INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
PUBLIC HEARING COMMENT FORM Page


# Ilc267/atf Title ofPublic Hearing: 

## hde. 5t

## 7't/ rh i?1 

## !le-6i:zm 

## eX**~I /~~;:**  Location:

### &'~y-T{/ 

## y 7ec4 Date:

i Name: 

### K412t1U /(;'(0

## c~ Organization/Company: 

## ------------,----------...rr------ Address: 

## R::U,A**Ji(cuI/~/l** 

# mE- ;if**U-P1~72:?'<:** 

### -7;t/ 

### :3 7-) Phone Number: 

## 2/9 £3& /?.s:/

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### If

you wouldlike to submitcomments, please do so on thisform, oryou may attach them to this document.

Revised 5/16/97 levGentlemen,
deserves however I've been busy with personal matters. I appreciate yourwillingness to hold apublic hearing to hearouropinions 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 askhowpermitting the emission oflargerquantities oftoxic soot would accomplishthis mission. IfEPA grants yourrequest, is this notjust whatwill happen? In searching for information on soot, I found arecentarticle from Argonne National Laboratory APS research group that describes a newtechnology that allows examination ofthis material while itis in a nano state (way too small to see). This DOE facility warns ofthe health, environmental and aesthetics risks ofsoot. Sootparticles are created when hydrocarbons are not completely burned. (incomplete combustion) Otherwise known incommercial applications as carbonblack, sootcreates healthproblems and may contribute to thousands ofpremature deaths each year according to the US Environmental ProtectionAgency (yourboss????) Sootbegins withthe chemical growth oflarge benzene-basedhydrocarbons which aggregate andmerge from .5 nanometers to 20 to 50 nanometeers in diameterwhichthen coagulate to form larger sootparticles. At ANY size, sootis problematic though itposes the greatesthealthrisks in therange of 2.5 micrometers to 10micrometers. Health effects noted by Argonne from soot (particularly fine particles which canget deep into the lungs and cause serious healthproblems) include: Increased respiratory symptoms such as irritation ofthe airways, coughing or difficulty breathing Decreased lung function Aggravated asthma Development ofchronic bronchitis Irregularheartbeat Nonfatal heart attacks and Premature death inpeople with heart oflung disease People withheart orlung diseases, children and olderadults are most likely to be affected byparticlepollution exposure. However, even ifyou are healthy, you may experience temporary symptoms from exposure to elevated levels ofparticlepollution.

# I

L;;;c;;;;;; 

# I I 

# I I

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# I

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### I I 

### I 

## I 

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## I I 

# I 

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# I Intenus ofenvironmental damage, Argonne notes the haze causedby soot whichnot affects

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### ~~~~ ..

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## ....; ..**~~~;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. Italso 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 ofparticle size however. The real questionto be addressed is why we would violate the spirit ofthe Clean AirAct and allow any increase inthe airpollution for this regioninthe name ofeconomic improvement. Successful businesses (especially inthe face ofpenalties for squandering the public resources ofwater, earth and air) push hard to manage waste both forthe sake oftheir bottom line and for the preservation ofthat which makes commerce possible. To increase the level ofpollution ofsootallowed is to promote inefficiency inthe face of existing technologies that allow complete combustion andpostpone the day ofreckoning for legacy waste cleanup. Haven't we learned anything fromthe cost ofcleaning up the US Steel channel mess? Pay me now orpayme (lots more) later. Meanwhile your children andmine will be breathing airpurposefully dirty and ourpublic health costs will nse. Please gentlemen, listento yourpublic. Do the rightthing. Establish and enforce laws andregulations thatpromote parsimony, good stewardship, health, wealth and competitiveness. Indiana canbe green both inherenvironment andher economy. 

### -1<';4£6

### IlJ 

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## shcCj!uba(, J1 QT 

### 2LQ.**S'J&-IR'~J** 

### (1-1) 0iJS-- cfP-PJ (c: e 

### II \ 211, 6/ .JFrontiers Archives 

### I Contact the Editor 

### I [\rgonne National Laboratory

Visualizing first images ofsoot 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 ofthe 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. Overthe years, researchers have used a variety oftechniques 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 ofa human haiL) Yet this size range covers mostofthe 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 2/21/2008Tiny 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. Overthe years, researchers have used a variety oftechniques to study soot particles. But until now, it has been difficult or impossible to study the structure of particles in the 1 nanometerto 100 nanometersize range as they are formed. (A nanometer is about 1/50,000 the diameter of a human hair.) Yet this size range covers most ofthe 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 ofAPS 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 smallerthan 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 diameterposethe greatest problems, because they can get deep into your lungs, and some may even get into yourbloodstream. 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 largerthan 2.5 micrometers and smallerthan 10 micrometersin 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 EPAto 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 ofchronic bronchitis;
• irregular heartbeat;
• nonfatal heart attacks; and
• premature death in people with heart or lung disease. People with heart orlung diseases, children and older adults are the 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. 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 ofourtreasured national parks and wilderness areas. For more information about visibility, visit ww\vepa.gov!visibilitv. Environmentaldamage Particles can be carried over long distances by wind and then settle on ground orwater. The effects ofthis settling include: making lakes and streams acidic; changing the nutrient balance in coastal waters and large riverbasins; depleting the nutrients in soil; damaging sensitive forests and farm crops; and affecting the diversity ofecosystems. 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 aboutthe effects of paliicle pollution and acid rain.You will need Adobe Acrobat Readerto 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 ofpariicle exposure, and simple measures you can take to reduce your risk. 

### (PDf, 2 pp, 320 KBPage 

## INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT PUBLIC HEARING COMMENT FORM

Title ofPublic Hearing: 

## B:w:tICU

## ICt

# itt 

# oS)

# b 

# 1 teJ"-ll

# qIi

# Jr,rD 

## '1 Location: 

# NY -teQJ Date:

# f2.-1/0

# i
Name: 

# }M,D;tJrt-·

# C6l-e-~**Organization/Com~any:** UUM.tJ N 

# f!;eJA/&;5

. Address: 

# 4. LDG

# 012 PLVvlf:-.

Revised 5/16/97 lev Phone Number: 

# ;UCJ

-5/lJ I--

## 70q~ .•

,

### ..

<'**~.**

## INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT Page

__
PUBLIC HEARING COMMENT FORM

Title ofPublic Hearing: Location: Date: -+:-

_ Name: Organization/Company:

### -----------~r---------_rr_------ Address: Phone Number: 

## ------------r-------

,;. 

### If

you wouldlike to submitcomments, please do so on thisform, oryou may attach them to this document.!



# -iJere:fU

# t-ke4iiiF /2g[Jut) 

# ---)0

# a&:Y\8~iAe4~0!3l4LhO' IS 

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### !

Revised 5/16/97 levDaniel. 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 OFFICEOFAIRQIIALITY 

## Programs Branch Office ofAir Quality MC 61-50 100 North Senate Avenue IndianaDepartment ofEnvironmental Management Indianapolis, IN 

## 46206-2251 DearMr. Deloney, The Dunelands Group ofthe Hoosier ChapterofSierra Club would like to go onrecord 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 concernedwith the impact ofmore use of woodbuming stoves ofany 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

## ScottDeloney, Chief Programs Branch Office ofAir Quality MC 61-50 100 N. Senate Ave. Indiana Dept. ofEnvironmental Management Indianapolis, IN 46206-2251 DearMr. Deloney: I am writing to voice my opposition to the granting ofthe PM 2.5 attainment in Lake and Porter counties. There are justtoo many unresolved questions regarding increased air emissions at BP, as well as in otherindustries in northwest Indiana, in the nearfuture. 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 of35 micrograms. Thank you for the opportunity to comment, but I hope that you study this further and do not grant attainment ofPM 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

1Daniel, 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 ScottDeloney Office ofAir 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 ofLake and Portercounties 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 resultofexposure to fme particulate matterincluding premature death, hospital admissions, doctor's visits, lost time at work, etc. This is offthe website ofthe Union ofConcerned Scientists. "PM 2.5 has aprofound effect onpublic health. It can easilybecome trapped inthe human body and canhave negative consequences for aperson's health. Over 2,000 peer-reviewed studies published since the currentPM 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 ofHealth concludedthat even an exposure level of 13.4 micrograms ofPM 2.5 would put 11.5 million elderly Americans at increasedrisk ofcardiovascular 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 ofourelderly citizens." There is no goodjustification 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 theirrecommendations. Fromthe UCS, "When considering safe levels ofpollution in the air that we breathe, the EPA is only allowedto considerhealth effects. Nothing else can be considered, including economic, oreven 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 ofan organized effort ofthe USEPA andthe IDEM to promote increased industrial production in northwest Indiana. Itis unethical and it may be illegal. (The timing is

3/13/2008interesting too considering the pending permits for the BP refinery in Whiting and US Steel in Gary.) It is my position that "attainment ofPM 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

3/13/2008Daniel, 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 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 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

3/13/2008alSv 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 ofLake Michigan. These are precious resources and the only tourist draw for this area (aside from the Casino boats) are the dunes and LakeMichigan. Don't spoil apotential 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, werequest that the 2007 data be added to this application priorto submission to EPA. This is especiallyimportant because one ofthe critical monitors listed, located at the WaterPlant on Madison Street in Gary,justbegan operating in July 2005. Anotherreason 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 havejustrecently 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.

3/13/2008Daniel, 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

1Daniel, 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

1Page 1 of1
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 ofall, while IDEM is allowed to use data from 2004, 2005 and 2006 as the design values for the application, we requestthat the 2007 databe added to this application priorto submission to EPA. This is especially important because one ofthe critical monitors listed, located at the WaterPlant onMadison Streetin Gary,justbegan operating inJuly 2005. Anotherreason this application is too premature is because while manyregulations exist, such as the Clean Air Interstate Rules (CAIR), that will help reduce PM 2.5, some ofthese regulations havejustrecently gone into effect or will not take effect for several years. As aresult, we believe it is too early to fully assess the impacts ofthese regulations.
Thank you verymuch for attending to this urgentmatter. There is already way too manypollutants in North West Indiana's air. Every child and adult has to be poisoned on a dailybasis. IDEM never seems to look atthe cumulative effect ofthe particulates from all the industry. We have some ofthe highest cancerrates in the world righthere as well as serious asthmaproblems. Quit acting like it's ok for the people you are supposed to beprotecting to getplenty more pollution. Stop this insanity. Now.
Thanks. Randi Light 37 Shore Drive Portage, IN46368

3/12/2008March 11, 2008 Scott Deloney, Chief Programs Branch OtIlcc ofAir 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. DearMr. 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
OEPARThlEHTOfmVIROIlMEHTAlMANAGEMENT OffICEOf!\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 ofSave The Dunes Organization. Sincerely,

Bessie Dent Progr:llil CoordinatorMarch 11, 2008 Scott Deloney, Chief Program Branch Office ofAir Quality MC 61-50 100 North Senate Avenue IndianaDept. ofEnvironmental Management Indianapolis, IN 46206-2251 DearMr. Deloney: Thank you for the opportunity to commentupon the Indiana Dept. ofEnvironmental Management's (IDEM) request to EPAto approve the Re-designation andMaintenance Plan for Lake andPorter Counties for Particulate Matter (PM) 2.5. Since I am a member ofSave the Dunes this application is ofgreat concern to me. Accordingto the EPA severe health effects are associated with exposure to excess levels ofairborne fine particulate matter (PM2.5). I am convinced thatthis application is too premature to be adequately studied. It also appears to be too vague and potentially subjective. Save the Dunes takes the positionthat attainment ofPM 2.5 in Lake and Porter Counties should notbe granted at this time. Thank you for allowing me to comment. I appreciate you consideration

.



# .cerel\;h IL

eHardy 

# "1
ownPoint, IN ember Save the Dunes

### Indiana Steel 

## Environmental Group

March 11, 2008 Lake andPorterCounties FineParticulateMatter(pM2.5) RedesignationPetition andMaintenancePlan ScottDeloney, Chief Programs Branch OfficeofAirQuality MC 61-50 100 North SenateAvenue Indianapolis Indiana46204 STATE OF**i:V-;JIf!.N!~** 

### MAR 1. 

### 3 2008
DEP.4RTMENTOFENVIROIIMEnmMANAGEMEIlT OffICEOFAIRQUALITY
Munster, Indiana 46321 Tel: 219-836-1000 Fax: 219-836-4100

Subject: Comments In SupportofRedesignation ofLake andPorter Counties as Attainmentfor PMz.5 DearMr. Deloney: The Indiana SteelEnvironmental Group is acoalitionofIndiana steel companies established to focus onenvironmental matters ofconcernto its members. The Indiana SteelEnvironmentalGroup (ISEG) consists ofmembershipfromArcelorMittal Indiana Harbor, LLC, United States Steel Gary Works, United States SteelMidwestPlant, ArcelorMittal Burns HarborLLC, andNucor Steel Crawfordsville. The Indiana SteelEnvironmental Group strongly supports the IndianaDepartmentofEnvironmental Management's (IDEM's) draftpetitionforthe redesignationofLake andPorterCounties as attainmentforfme articulatematter(PM25) andprovides the following comments. I Thethree-yeardesignvalues for all monitors usedto determine attainmentinLakeandPorterCountieshave unifonnly met U.S. EPA's annual PM2.5 standardforthe 2002-2004,2003-2005 and2004-2006periods. The only remaining question is whetherLake andPorterCounties still somehow "contributeto" nonattainmentin CookCounty

- the only county thatis stillin actual, directnonattainmentin theentiremetropolitan statistical area. Due to theirphysical location, Lake andPorterCounties canonly theoretically "contribute" to violations attheCookCounty monitors atCicero andWilsonAvenue whenthe windisblowingonefinite direction

- from the southeast. EPA's ownwind rose analysis innorthwest Indianaindicates thatprevailingwinds blow away from theviolatingmonitors morethan90% ofthe time. See SupplementalRiskAssessmentofPotential AirEmissions at5-7 (Dec. 2006) CEPAWindRose Analysis") available athttp://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 StateoflndianaandArcelorMittal Burns Harborhave both appealedU.S. EPA's original designation ofPorterCounty as nonattainmentforPM2.S to the D.C. CircuitCourtofAppeals. That proceeding is currently in the briefing stage and will likely be argued during late summer or early fall of 2008. Submission ofthe proposedredesignationrequestfor Lake andPorterCounties is fully consistentwiththatappeal and will only furtherassist inliftingtheregillatoJYburdens associated withEPA's initial nonattainmentdesignation.



## ArcelorMlttal NUCCIR SHEET NILL·CRAWFDRDSVtLLE2 Ifthere is any "contribution" to area airquality problems in theregion. itflows theotherdirection. AmbientPM2.51evels steadily decline whenmoving south and eastfrom central Cook County toLake County andconsistently furtherdecline through PorterCounty. This illustrates thatthe winds cause Cook County's dominantemissions to travel south andeast
We suggestthatIDEM incorporatethispointmoreprominently in Section 3.3 oftheRedesignationPetition. That section containspowerful evidence thatthe vastmajority ofemissions atthe two nonattainingmonitors inCook Coimty stemfrom local (and notregional) emissions. Itmakes this point inthe contextofadetailed discussion ofthreeparticular"highmonitorvalue" days (pp. 23-29). One ofthose threedays, however, happenedto occurduring therare instancewhen winds were blowingfrom the southeast. While IDEM'sbacktrajectory analysis from thatparticularday forecloses afmding ofcontributionfrom Lake or Portercounties despitethosewinds, itwouldbe useful to note thatthis winddirectionmakesthepotentialfor contribution exceptionally rare. IDEM shouldfurther supportandclarify its contribution analysis by providingthe statutory underpinningsthatrequireEPA to apply asignificancethreshold. Congress selectedthe term "contributes" to defmethe conceptofindirectnonattainment status in CAA §107(d)(1)(A)(i). Contributeis commonly defmed as playing "asignificantpartinbringing about an end orresult" WEBSTER'S NINTIINEWCOLLIGATEDICTIONARY at285. Aminimalorimmaterial addition ofPM2.5 orprecursorsfrom Lake orPorterCounty doesnot, "playasignificantpartinbringing about" nonattainmentattheCookCounty monitors. That conclusionis furtherreinforcedby theCleanAirAct's structure. Nonattainmentdesignations are usedto drive State ImplementationPlan ("SIP") amendments necessary to secure attainmentstatus. Requiring such SIP amendments inthe absence ofademonstratedcausal relationship (e.g.• in areas thatdo notplay "a significantpart" innonattainment status) would impose anunnecessmyburdenonregulatedentities. Finally, we concurwithIDEM's conclusionthat "SinceLake and Portercounties attainedthe annual standardforfmeparticles priorto anAttainmentorRACT SIPbeingdue, and sincethe implementationruleforfme particles stipulatesthatstates are only requiredto draft andimplementRACT rules fortheprecursoremissions reductions necessary to attain the standard, no furtherRACT rules arerequiredforthis area." Thispositionreflects EPA's standing"CleanDataPolicy" andwill avoidthe impositionofadditionalregulations that arenotneededto satisfy thePM2.5NAAQS. We greatly appreciate IDEM's effortsto secureredesignationofLake andPortercounties. Shouldyouhave any questions regarding these comments,please feel free to contactme at (219) 836-1000. Sincerely,



# Y:b/l<r--

PatrickM. Gorman. P.E. Facilitator, Indiana SteelEnvironmental Group

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


## ArcelorMiffo( NUCCIR SHEErUILL·CRAWFORDSVILLEMarch II, 2008

LakeandPorterCounties FineParticulateMatter(PM2.s) RedesignationPetitionandMaintenancePlan ScottDeloney, Chief Programs Branch Officeof AirQualityMC 61-50 100North Senate A venue Re: Comments ofNWIFOFumlnSup.portofRedesignationofLake.3ndPorter Counties as Attainmentfor**PM~.5** DearMr. Deloney: These comments are submittedbytheNWI Forum in strong supportofthe IndianaDepartmentof Environmental Management's 

### (IDEM's) draftpetition for the redesignatioIlofLake and Porter Counties as attainment for fine partlculatematter (PM2.5). I The NorthwestIndiana Fotftuu is amembership base<}, not for profit regional economic development organization. Our mettibetshipof 123 and growing representsindustrial and commercialbusinesses, .financial entities; universitiesandllllinIcipalities 

### within Lake, Porter and LaPorte counties - a diverse group. In total, our membership reflects $40 Billion in commerceannuallyon**beh~fofthe.** StateofIndiana. Redesignation ofboth counties is criticallyimpo,ttantto removingtheadditional regulatoryhurdle Qfl10nattainInentstatus anditsifupediments to attractinginvestment, bUSln'eSs andjobs to Lakeand 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 offurther state-level requireIllents,Sirtrilar1y; the nonattainment 

### designations discourage investments for the development ofnew facilities., Thel?fomptremoval ofthat additionaJ regulatory burden 

### will help the comp1lilies who have already heavily invested in Lake and PorterCounties to**maketlttt(,)hli~Ilges** necessaryto cPmpe.teintheglobaleconomy. 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 MZ004,**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 inthe 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** ofPorterCounty<ls nonattainment for PMZ • 5to**·tlI~·.** D;C.CircuitGQi(lrtofAPPeaIs

.. Thatproceeding is cpxrentlr in the briefing stage and.win,liKelybe.argued

. duringlate sl@rtierorelJrlyfa.JI 0'20.08..SuJ:l1uissiollOftheproposed**rede~i~atign** requestfor Lake andI'OI;tepCounties is fuUyconsistent'Wi.tn thatappealandWijlQ,uyf¢'tlierassistin liftingthe**t~guI!-tt<>iy;,bUtdeIl$** asSociateq;**witblW1\~s.ivitlal** nonattainmentdesignatiofhPM2.5Redesignation PetitionComments 2008

Due to their physical location) Lake and Porter Counties can only theoretically "contribute" to violationsattheCookCountymonitors atCicero and WilsonAvenuewhenthewindis blowingonefinite direction

- from the southeast. EPA's own wind rOse analysis in northwest Indiana indicates that prevailingwinds blow away from the violating monitors motethan 90% ofthe time. See Supplemental RiskAssessmentofPotentialAirEmissions at 5-7 (Dec. 2006) ("EPAWindRose Analysis") available at**11tm:Ii~'Ww&Y!la.gov/tegion5t$ites/indiauahatbor!.** If there is any "contribution" to area air quality problems inthe.region, it flows the otherdirection. Ambient PM.t-s levels steadilydecline when moving sQuih and eastfrom central Cook Countyto Lake County 

### and cQnsiStently further decline tbrough. Porter 

### County. This illustratesthatthe prevailingwinds causeCookCQunty's dominantemissionsto travel south and east
- natLakeandPorter's Counties; cleanerairio "swimupstrearn}>4 We suggest that 

### IDEM incorporate this point more prominelltly in Section**~.3** of the RedesignationPetition. Thatsection contllinspowerful evidencethatt11evastmajorityofemissions atthe two nonattaining monitors in Cook County stem 

### from local (andnQtregioMI) emissions. It makes this pointin the context Q.fa·(ietaHed discussion ofthree particular "high mo1'1itbf**value~'** days (pp.**23~29).** One ofthose threeQI,lYli" however, hllP;pened

### to Q<Wtlr duringtherare instance 'W'hell winds were blowing rrQmthe southeast. While 

### IDEM's backtrajectory analysis from thmpart1cularday f0recloses 

### afinding ofcontribulionfromLakeorPortercounties despitethosewinds, itwouldbeusefulto notethatthis wind directionmakes'thepOtentialfor contributionexceptionaJlyrare. 

### IDEM should also consider clarifying the various stattnnentsin the Redesignation Petition that attemptto conveythe statutory threshold for "contribution." Several.Partsorthe petition state (or infer) thatredesignation is appropriate ifEPA cQnclOdesthatLake alta Porter Cottnties were not "significantly contributing" tothe.CookCOunty violations. See, e.!}'" p. 

### 17C"Ifenlissions 

### tram Lake andP0Itercounties were significantly contributing

...."), p. 22 {"it is evident**thatthen~is'** I10significant impact from Northwest Indiana.")p.$9 ("significantly contributingto thevioli:ttingmonitQrscinIllinois"). Otherparts oftheRedesignation Pet,ition potentially indicate;'alowerreJe:vance"threshold<for 'Icontribution" analysiS. 

### See, e.g., p. 

### 22**('~whfleemiSsions** from aUsurroun.diJ:lg a.reaS mayhave sl11attimpacts"), p. 29 ("In<iianais confidentthatitscontributionto thislocalized

### effectisn: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~**  conceptofindirectnonattain.rnelltstatus in CAA§I07(d}(1)(1\.)(1). Con(rifJl#c 

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

### lNlNrtI NEW COLU<1ATB DICTIONARYat 285.A'@:t,riw3,l or**imm~terial** a4PitionofPM2 .$ orprccursors tromLake orPorterCQootydoesnot "playasigntflcantparlin**bringingab.o~t';nonattainmellt** atthe Co,ok <;:ounty monitors, Tbat"cpnclusion is ful1herreinfotced by.theSle

# an 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

..,inareas 

### thatdo'no:tplay "asignificantpart" innonattaitlll: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 RedesignationPetition COrrtrt1ents March 11, 2008

While the**R.edesi~ation** Petition

. provides.amplejustification to**redesi~ateboth** Lake andPorter Counties, itis worthnQiingihatthe

### linkbetween. PorterCountyemissions 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 ofLake County to "contribute" to nonattaimuent. IfemlssionsinPorterCountywereacttlally contributingto nonattainmentto thewest, that impact wO'-lld be mQstnotablein irrtrnediately adjacent Lake County. The contrary steady decrease of ambient PM2. Slevelsf'tom west to eastdemonsttates the absence ofsuch an impactandprovidesfurther proofl'l1at Porter CQtITlty 

### is trot "contribmmg." Thus, ifU$. EPA (improperly)**r~ses** to redesignate bo1'b. cOllnties, IDItM should consider requesting separate treatment for 

### porterCounty due to this even moretenuol.lcs causal 

### linktotheviolatingmonitors. 

### 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 implementationrUleforfinepattieIes stipulates tbatstates 

### areonlyrequiredto&I;lItaP.dimplementRACT 

### rules f"Qr the precursore111issionsreduetions 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 impftsitionofbQrdeti;$Q1.neadditiQrtal.l'egulationsthatarenotneededtQ satisfy

### the

### NMz;5 NMQS. We greatly apprec.ia.telDeM'sef'forts toseclWe.redesignationofLakeantjl'Qnetcounties. Should you haveanyquestions**regardingth~$eeo1ll.1tl'ent$,** pleaseJe.el

### free tocontact**me:at(:21~) 763~6303.**  Sincerely,

# ~~·fU,lft~ James W.Fltntnery .•:•..•.....

# a Chaitlfian.·Bo&rdof Directors. NQrthwestJndianaForum, Inc.

# Improving Environment

March 11, 2008 Dan Murray, Assistant Commissioner Office ofAir Quality Mail Code 61-50 IndianaDepartment ofEnvironmental 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 DearMr. Murray: On behalfofImproving Kids' Environment, Inc., I am writing to express IKE's opposition to the IndianaDepartment ofEnvironmental Management's intent to seekredesignation ofLake and Porter Counties, Indiana, to the status ofmaintenance counties for the fine particle health standard. Redesignation ofthe 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 CommissionerEasterly. IKE shares IDEM's interest in lessening the economic development impacts ofa nonattainment designation. However, it is premature for Indiana to seekto 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 particularrequest 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 ofthe 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 ofa nonattainment area before the entire area is in attainment. Based on a recent conversation with staffat the USEPA Region V office, the agency has never approved such a request. Second, Lake and PorterCounties are part ofamulti-state nonattainment area, designated as such in accordance with USEPA guidance. Like ozone in some respects, PM2.5 is aregional pollutant. The main sources ofemissions in the S02 and NOx inventories are point sources in Lake and PorterCounties, and nearly halfofthose emissions come from electric generating units, whoseemissions can travel regionally. See Appendices BandD. Because ofthe concentration oflarge and numerous point sources as well as significant emissions from motor vehicles, USEPA guidance treats large metropolitan areas (even ifthey are multi-state) as a single nonattainment area.
in Lake County do not meet the recently revised PM2.5 daily standard of35 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 Indianato collaborate with Illinois on an attainment plan for the region than to seek redesignation at this time. Thank you for your consideration ofthese comments. Please do not hesitate to contact me ifyou have questions. Very truly yours,**-::r~G.n~(** 

## ... \.",.

... Janet G. McCabe Executive Director Cc: IKE Board IKE Advisory Board ScottDeloney, OAQ Branch ChiefILLINOIS 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 IndianaDepartmentofEnvironmental Management Indianapolis, Indiana46206-2251 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
DEPARTMENTOfENVIRONMENTALMA/IAGEMEIIT OffiCEOfAIRQUAlllY

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 Underthe Annual National Ambient Air Quality Standard for Fine Particles

- Lake and PorterCounties" (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 ofourjointefforts,. violations ofthe annual PM2.5 NAAQS are still occurring in ourregion. We believe thatemissions from Lake and Portercounties contribute significantly to ongoing violations ofthe annual PM2.5 standard. The Illinois EPA, therefore, strongly opposes Indiana's redesignationpetition and will recommend to the United States Environmental ProtectionAgency (U.S. EPA) that this petition be denied, and that Lake and Portercounties 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 withthe 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 MichiganAir 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 PAPERcoordinate technical and policy developments neededto meetthis 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, mostrecently in 2004, when a new MOA was signed by the four states to include the State ofOhio 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-hourozone andPM2.5 and achieve the reasonable progress goals for regional haze throughout the five state regions." We urge Indianato 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-yearperiod, 2004-2006, used in your analysis. Significantly, based on the most recent 3-yearperiod, 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 closestIllinois monitor to Lake County, Indiana. It is noteworthy that monitors located further north and west ofIndianaare recording lowerPM2.5 concentrations, which suggests that local sources in Lake County are contributing to the annual PM2.5 violation atWashington High School. This new monitoring datacompletely contradicts the rationale provided onpage 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 "pollutionrose" for this site, to illustrate the average PM2.5 concentrations at this location based onthe wind direction occurring during times ofelevated 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 easterlythrough southsoutheasterly wind directions (i.e., from Indiana). Itis also noted that southerly through westerly wind directions also contribute to elevated PM2.5 levels, butthese directions are consistentwith the climatological frequency ofwinds throughoutthe year as shown in the wind rose in Figure 3. Comparing the two figures (Figures 2 and 3), itis obvious that elevated PM2.5 from the easterly wind directions are over-representedrelative 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. Forits Clean Air Interstate rulemaking, U.S. EPA considered a 0.2 

### ug!m3 contribution from anentire 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 atmonitors in Cook County that are exceeding the annual PM2.5 standard. There is'no technical basis for Indianato conclude that sources located in Lake and Porter Counties do not significantly contribute to nonattainment in adjacent states.

2Lake and Portercounties are tied to the Illinois nonattainment counties clearly states that these factors must be considered when the states recommend the boundaries ofa 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 Portercounties 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 inthat it allows Indianato 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 ofair quality. We believe Indiana mustprovide emissions reductions beyond those currently contained in Indiana's State Implementation Plan (SIP). The Illinois EPA, therefore, strongly opposes Indiana's redesignationpetition and will recommend to the U.S. EPA thatthis petition be denied. Indiana should withdraw its draftredesignation 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



### 3Cicero Monitoring Site

Summit Monitoring Site



### Illinois FIGURE 1 

### Cook County Annual PM2.5 Design Values 2005-2007

Washington High School Monitoring SiteFIGURE 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 ScottDeloney, Chief Programs Branch Office ofAir Quality MC 61-50 100 North Senate Avenue Indiana Department ofEnvironmental Management Indianapolis, IN 46206-2251 DearMr. Deloney: Thankyou for the opportunity to commentupon the IndianaDepartment ofEnvironmental Management's (IDEM) requestto EPA to approve the Re-designation and Maintenance Plan for Lake andPorterCounties 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 ofairborne 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 thatreduces 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, 

# ParticlePollution Report, 2003, p. 3.) For example, inthe article 

# Seepage Measurementsfrom LongJ



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# ! Lake, Indiana DunesNationalLakeshore, the authors i"ndieatethattne"flldhtllaf)urres'Natrol1a:l'cakesITcrrerrasthe' "highest nitrate and sulfate levels in precipitation ofany monitored park inthe country." 

## (Seepage Measurements from LongLake, Indiana DunesNationalLakeshore,

Environmental Geology, September 1996, p. 99.) A careful review ofthe dataprovided by IDEM as well as EPA indicates thatthis importantpollutant 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 thatthe average annual standard currently promulgatedby EPA at 15 micrograms still is not low enough to protecthuman 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 ourbeliefthat, while this application is very thorough, it is simply too premature and violates the spirit ofthe cake Michigan AirDirectors Consortium (LADCO). Furthermore, there appears to be conflicting data, there are many questions that need to be answered, some ofthe documentation orwording is unclear, and more work needs to be done onthe Maintenance Plan. This application is too premature for several reasons. First ofall, while IDEM is allowed to use data from 2004, 2005 and 2006 as the design values for the application, we requestthatthe 2007 data be added to this applicationprior to submission to EPA. This is especially importantbecause

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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. Anotherreason 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 havejustrecently gone into effect orwill not take effect for several years. As aresult, we believe it is too early to fully assess the impacts ofthese regulations. Determining the chemical make-up ofa particle

- known as "speciation"

- is an importantpart ofthe effortto reduce PM 2.5 levels, and is accomplishedlargely through data generated by EPA's ambient air speciation monitoring program. We are also very concernedthat 2007 results from area speciationmonitors are notreflected inthis application. While these results may not need to be considered in this application, it must be noted thatthat a number ofthe readings were above the daily standard of35 micrograms atthe Gary Iitri SpeciationMonitor location.**(http://www.in.gov/idem/air/amb/ambi~nt/summary/aqsum** 

## mary.html) This kind ofdata is vital to ensuring that pollution controls are implemented atthe right sources and should not be ignored. Furthermore, we are not clearthatthe emissions inventory and estimates include importantpotential future emissions from the following sources: 

# oIncreased air emissions expected from the expansion of the BP Whiting Refinery as well as the BP AsphaltPlant.

# oIncreased 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 majorpurposes 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 supportthe development ofeffective control plans to address regional pollution problems such as ozone, fine particles, regional haze and airtoxics." IDEM's determination that "emissions from Lake and Porter Counties do not affectthe downwind area's ability to attain the fine particles standard" violates the spirit ofthat Memo ofAgreement. In yourpublic response to these comments, we requestthat Illinois EPA's reaction to this redesignation application be included. While trying to demonstrate Indiana's lack ofculpability in impacting the Chicago nonattainment areayou used February 3, 2005 as an example ofa monitored day higher than the daily standard ofmore than 35 micrograms. It is interesting to note thatthe Ogden Dunes monitorwas 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? Underthe 3.5 ContinuedMonitoring Section, you indicate

## that the existing monitoring network couldpotentially 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 weatherpatterns can contribute to yearly differences in PM 2.5 concentrations from areato area. Onpage 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. Consideringthatthe economy inthis 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 longerto 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** 

## ofcontrol measures that will no longerbe required or utilized ifthis attainment status is granted. In the Corrective Actions section ofthe application, you indicate that "ifa new measure or control is already promulgated and scheduledto be implemented atthe federal or state level, and that measure or control is determined to be sufficientto address the upward trend in air quality, additional local measures will be unnecessary." Can you please provide clarification on what criteriawill be utilized to determine ifa measure or control is sufficient? In addition, your contingency measures section is too vague and should be made clearer. For example, instead ofproviding examples ofcontingency measures that "may" be considered, you should instead provide a more comprehensive list ofcontingency measures that could be implemented. Furthermore, it is ourbeliefthat yourlist offactors that will be considered for the selection ofcontingency measures is too vague and potentially subjective, especially where you
v 

## say "Seconomic and social considerations and other factors IDEM deems appropriate." Inthe list ofpotential contingency measures, you may want to considerhaving idle restrictions placed ontrucks as well as diesel trains; and, instead ofwood stove change-outs, you may wantto implementresidential 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, ifand when Lake and Porter Counties are placed into attainment, Save the Dunes requests thatyou create a StakeholderAdvisory Committee that will help monitorthe maintenance plan. Again, thankyou for the opportunity to comment on this application. It is ourposition that attainment ofPM 2.5 in Lake and Porter Counties should not be granted atthis time. Sincerely, Debbie Chubb President

cc: Environmental Protection Agency444 Barker Road, Michigan City, IN 46360 • 219-879-3937 • www.savedunes.org 

## RECEIVED

STATEOFINDIANA 

### MAR I 4 2008
DEPARTMENTOFEWlIRDNMENTALMANAGEMENT OFFICEOf AIR QUALITY, March 11, 2008 ScottDeloney, Chief Programs Branch Office ofAir Quality MC6I-SO l()ONorthSenateAvenue IndianaDepartment ofEnvlr()ntnental Management Indianapolis,IN46296::22Sl.

.

..DearMr. Deloney:

### ~Thankyou fortheopportunity to commentupon theIndiana DepartmentofEllvironmental·

.Management's (IDEM)request to EPA to approve the Re-designation andMaintenance Planfor

take and PorterCountiesJorParticulateMatter(PM) 2.5.

... SavetheDunes Counciltakesthisapplicatioll very seriously. According to the Enviionmental Protection Agency(EPA), severe health effects are associated with exposureto excess**lev~ls** of· airbomefine particulate matter(PM2.5), induding tens ofthousandsbfprematuredeaths and

. hospital admissions, and hundredsofthousands ofdoctor visits, workand school absences and

respiratory illnessesyearly

. .. . .

..Dedicateclto P:'eservation andProtection oftheIndiana tJunes$iiice 1952

... • .@100%post-eonsumer;,,;YCledpaper, processedch'orine

### ir~e'Savethe Dunes Comments on PM 2.5, p. 2
A cl'!-reful review ofthe data provided byIDEM as well as EPA: indicates that this important' pollutant is on a downward trend

.. Neverthelyss, it mustbe stated that Save'theDunes' 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

### 15micrograms 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 beliefthat, while this application is very thorough, itis simply too,premature and violates the spirit ofthe Lake Michigan AirDirectors 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 morework needs to be done on the Maintenance Plan. This application is too premature for several

### reaso~s., First ofall, while IDEM is allowed to use '
"data from 2004, 2005 and 2006as the design 'values for ,the application, we request thatthe 2007

databe added,tothis application priorto submission to EPA. This is especially important ' ' because one of the critical monitors listed,located.atthe Water Plant on Madison Streetin 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 ofthese regulations havejustrecently gone into effect or wilrnot takeeffectfor several years. 

## As a result, we believe itis too early to fUlly ass'ess the impacts ofthese regulations. ' , Determining the chemical make'-up.

### ofa particie

- known'as "speciation" is animportantpan: ofthe effort to reduce

### PM 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 .notreflectedinthis application. 'While $ese'results may not need to be considered 

### Inthis application, it must.be ndfed thatthat a number ofthe readings were ' above the,daily standard of35 rillcrograms at the GaryJitri Speciation MonitorlOcation.**~(http://www.in.gov/idernlair/amb/~lI:i1bient/summary/aqsummary.html)** This IGn4 ofdata is vital to ensuring that pollution controls, are implemented at therightsourcesand should not be '
"ignored.

Furthermore, we are not 

### clearthat the emissions inventory and estimates'inClude important potential future emissions from thefollowing sources: '
• Increased air emissions expected from the expansion ofthe BPWhiting Refinery as well as the BPAsphalt Plant. '" '

., Increased emissionsthat couldresultfrol1)theexpansionofthe Gary-Chicago International Airport..., ' ,'., , ' .' '
•**In~reased** emissions resultingfrom an iIicrease in the use ofresidential**woo~coinbustion** , deviees-such as hydronic heaters,also known as Outdoor'Wood Furnace**Boilets~** One ofthe major purposes ofLADCO, as stated in'a Memo ofAgreementfor Interstate Air Pollution Study and Control**sigll{~d** in 2004 byformer IDEM Commissioner Laurie I(aplali, is thedevelopmentoftmilti-state,multi-poUutantplanning "to supportthe development ofeffective cdntroI plans to address regionalpoUution problems stich 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 thefine particles standard" violates the spirit ofthat

. Mem€lof:AgfeeH1CUf:',InY0urpublic"response'totlresc"c**omments~we'rl~llt:festtli:atrlllfrbisEf>lt·s'"'** reaction to this fe-designationapplication be included. While trying to demonstrate Indiana's lack ofculpability in impacting the Chicago nonattainment area you used February 3, 2005 as an example ofa monitored day higher than the daily.standard ofmore than 35 micrograms. It is interesting to note that the OgdenDunes

-monitor was not operational thatday, as indicatedon Table 3.5 ofthe application. This begsthe' following question: How often do any ofthe 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 objectto any changes that might be made in thenetwork since monitor changes could potentiallybe implementedto make the outcomes look more favorable.

- Your application-must be prese"nted ina manner that demonstrates that attainment was achieved basedon permanent and enforceable emission reductions. This application needs to demonstrate more clearly thatJavorable weather conditions dming the design value years did notheavily influence emissions reduCtions: This is because weather pattemscan contribute to yearly differences inPM 2.5 concentrations from area to area. On page 25 ofthe application,

### y~ujndicate thatutilities cannieettheir budget for nitrous oxide (NOx) emissions by purchasing eniissions credits.

-How many credits were actuallypurchased and howinuch impact do thesecredit purchases actuallyhaveonthe reduction ofregional No'x emissi:oIis7

. - .

- - Vehicle

### ~ge distribution is animportant consideration whtm projecting transportation conformity budgets and travel**d~mand** forecasts. Considering that theeconomyin this areais mostlikely in recession, people and companies will most likely holdonto their cars arid fleetvehides much longer;: which means that it will take longer to phase in newer models thatwill 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

# ofcontrol measures thafwill no longer be required or utilized ifthis.attainment status is granted

.. In the Conective Actions section ofthe application, you indicatethat "ifa riew measure or- control isalre;ldy promulgated' and Scheduled to beimplemented atthe federal or statelev'el, and thatmeasureor control is determined to be sufficient to address the upwardtrend in airquaiity, additional local measures will be'unnecessary." Can you please provide clarification on what criteria will be utilized to determine ifa measure or controlis**suffici~nt?** In add}tion, your contingency measures sedionisloo vague and should be'made clearer. For example, instead of providing examples ofcontingencymeasures that "may" be**considered~** you should insteaci" provide a more comprehensivelist ofcontlngeIicy !Ueasures that couldbeimplemented.

.Save**th~** Dunes Comments on PM 2.5, p. 4

Furti:Iermore, itis·oUrbeliefthat yourlist offactors that will be considered for the selection of

"

...economic and social considerations and.otherfactors IDEM deems appropriate." In the li'stofpotential contingency measures, you may want to consider having idle restrictions placed on trucks as well asdiesel trains; and,**in~tead** ofwood 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 toevaluate their average truck-waitingtimes and implement more efficientgate· operations. Finally, ifand when Lake and Porter Counties are placed into attainment, Save theDunes requests that you createa StakeholderAdvisory Committee that will help monitorthe maintenance plan. ' Again, thankyou' fotthe opportunity to comment6n this application.' It is our position that attaimrient.ofPM 25 in Lake and PorterCounties**sho~ld** nofbe granted'atthis time. Sincerely,

DebbkChubb

,**Presid~nt**

cc: Environmental Protection AgencyPage 1 of1
Daniel, Pat

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# ----
..".-
" . 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.

1Daniel, 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

1rage 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 otherparticulates into the air and lungs ofthe people ofNorthwest Indiana. Do not support this tragedy. (The Rev) Charles H. Hensel 8414 Oak Ave Gary, IN 46403

3/13/2008rage 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 notbe granted, You and Iboth 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 lasthalf century. In addition, you and Iboth know that the release oflead into the already toxic air ofnorthern 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 sooneror later all the industry in this part and otherparts of the state will eventually either clean up theirpollution or die from it. It really isjust a matter ofwhen. Is 100 years enough to getthe pollution under control? 200 years perhaps, or 500 more than that? Ifwe 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 ofburhome environment. They will not shutthe plant. They will comply ifand when we get smart about the damage being caused and find the political will to do theright thing and stop poisoning ournests. Thank you, Kurt Oldenbrook
Be abetter friend, newshound, and know-it-all with Yahoo! Mobile. IryjtJ1QW.

3/27/2008Daniel, 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 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 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 ofthe comments received and IDEM's responses thereto: Summary/Response to Comments Received at Public Hearing

Comment: Commenter asked how permitting the emission oflargerquantities of toxic soot could help IDEM to meettheir mission to encourage and aid businesses and citizens in protecting and improving Indiana's environment. (Kroczek) On February 27,2008, the IndianaDepartment ofEnvironmental Management (IDEM) conducted apublic hearing concerning the draftredesignation request ofthe annual fine particulate matter (PM2.s) standard for Lake and Portercounties, Indiana. Comments were made bythe 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 

### NorthwestIndiana Redesignation Request and Maintenance Plan in**A.§§.g,£,ill,timl;,~ltllith.~.,,A:llIlJlaLS,taJtd.a£d,{for,,,Eine,;",Rar,ticulacftLMattel:"",."".";,.,** 

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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 thattheir emissions would not cause or contribute to a re-violation ofthe standard. Comment: Commenterreferenced an article from Argonne National Laboratorythat warned ofhealth, environmental and aesthetic risks ofsoot. The commenter summarized how sootparticles are formed, the health effects and the environmental damage ofsoot, particularlyfine particles. (Kroczek) 

### IDEM agrees with the commenter on the potential health and environmental effects ofexposure to elevated levels ofrme 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 thatpromote goodstewardship, health, wealth andcompetitiveness. (Kroczek) 

### IDEM acknowledges comments provided.

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# I I I Comment: The commenteropposed designating orredesignating 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 liveby at leasttwo nationally distributed magazines. (Coleman) 

### Lake and Porter counties have measured air quality that meets the annual rme particle standard since 2003 and many ofthe 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 bythe 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 permitissued 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 andPortercounties to attainment status is, according to the newspapers, to make it okay for expandingbusinesses and new businesses to add more pollution into the already polluted air. (Coleman) Comment: The commenter asked "Whydo we need to redesignate to pollute more? Why couldn't wejust shiftthe amount ofpollution? Ifyou 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 otherpolluters

...reduce the amountthat they canpollute so that new businesses canpollute?" (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 ofSignificantDeterioration (PSD). New major sources or major modifications ofexisting sources mustinstall best available control technology and demonstrate that the resulting emissions would not cause or contribute to a violatipn ofany 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 itis 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 cannotincrease 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 nextten years and continue to attain the current annual rme particle standard. Future year modeling takes into accountprojected emissions increases from industry and population growth, as well as emissions controlstrategies. 

### Comment: Commenter asked "Ifairquality is gettingbetter, why do youhave 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 consistentwith other counties in the nation that measure air quality that meets the standard. 

### Comment: Commenter stated that she doesn't trustthe numbers that IDEM has. She lives in the area, breathes the air and smells it. She doesn'tthink it's healthy no matter what the numbers say and no matterwhat EPA says. (George) Methodology used in the documentto demonstrate attainment ofthe standard, as well as certified quality assured monitoring data is readily available and verifiable in U.S. EPA guidance documents.

. 

### Comment: Commenter asked "ifyou find thatthe 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) Ifemissions startincreasing afterthe area is redesignated, or monitored exceedances occur, as part ofthe 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 commenterprovided suggestions to help IDEM clarify statements made in the document. The first comment was on page 7, where itreferences the design value. It 

### refers to the airquality and design value for the area as the highest design value among all sites in the area. Ifthe statementreferences Lake and Porter counties only, it shouldberevised to make that clear. Onpage 23, Section 3.4, it states that IDEM has

3quality 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 ofIndiana data only. (NiSource) IDEM appreciates the suggestions and will revise the document accordingly. Comment: Maybe a good corollary mightbethe courseparticulatematterregulations, PMI0. Coarseparticles have beenregulated for a while, for which we are in attainment. There's a maintenance plan inplace that ifourcompany is found culpable in exceedance ofthat, we have to submit a 25 percent source widereduction ofourparticulate 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 ofscientificreview. And I sympathize with the people that breathe it, it's me and my family also, and Iknow the damage that it causes. But these standards were setby scientists to designate healthy air. It's IDEM's job to regulate industry and point sources, and area sources andmobile sources to getus into attainment. Now, ifwe believe that 35, or in this case, the standard of15 on an annual basis, is too high and what we need to do is to getthat standard lowered from 15, not to attack the redesignation. (U.S. Steel) Comment: Ifwe do redesignate, not one limit at GaryWorks is relaxed. It does not allow us to pollute more. It does change, in some cases, new source review fornew and modified sources, butitmakes itmore difficult for us to modify or add, because you have to stayin attainment ofthe standards. (U.S. Steel) IDEM appreciates the preceding comments and the supportto redesignate the area to attainment. Summary/Response to Comments Received During Comment Period IDEM requested public commenton the draftredesignation 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 LyndaJorgensen Dunelands Kirulis Bonneau Sweeney Gagliardi Gonzales Squire Smith Jorgensen



### 4Joanne Lehmann Ron Wennekes Bessie Dent, The Calumet Project June Hardy PatrickM. 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 LauraDemchuck 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 ofcomments received and IDEM's responses thereto: Comment: The commenter expressed concern with the impact ofmore use ofwood burning stoves ofany type for home heating a,s natural gas and electricityprices continue to rise. Users shouldbe required to use the latest technology to be as low in pollution as possible. (Dunelands) 

### This is an issue ofnational 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: Commenterexpressed 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 otherindustries in northwest Indiana, in the near future. (Kirulis) 

### Potential developments, that we're aware of, were considered as part ofthe maintenance plan when we estimated economic growth and the corresponding increase in emissions. Emissions are expected to be lowerin ten years than they are now. There are additional emissions controls "on the books" thathave not been fully implementedyet, and these willhelp offset area growth. In addition, major new sources will be subjectto new source review permitting under the Prevention of SignificantDeterioration rule requiring best available controltechnology and a

5demonstration that the emissions will not cause or contribute to a violation ofany
Comment: Commenterexpressed 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 ofthe 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 ofthe 2007 monitoring data. It shows that all ofIndiana'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 ourfuture air quality? Not even those we elected to do thisjob for us? Who will your childrenblame?" (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 ofprojected future emissions, including proposed controls on large utilities, on and offroad vehicles, and fuels, and has determined that the standard will be metby an increasing margin ofsafety in the coming years. Comment: Commenter strongly opposes the designation ofLake and Porter counties as "in attainment" ofthe PM2.5 standard. Commenterbelieves the move is based on economic concerns, not public health, and that the redesignation is the result ofan 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 ofpublic health and the environment. It was determined that the current standards are protective ofpublic health. Ambient annualrme particle levels measured in Lake and Porter Counties meet these standards. Comment: The commentermentions 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 ofelderly citizens. (Sweeney) IDEM agrees that there are known health effects associated with exposure to elevated levels offine particles. However, the federal ambient air quality standards are set atlevels that are determined to be protective ofhuman health. The standards are reviewed every five years to determine whether the standards are sufficientto protect public health. In 2006, the U.S. EPA determined that the current annual standard for rme particles is sufficientto protectpublic health. As studies continue

6into the future, thatinformation will be used to determine ifthe air quality standards remain the same or need to be Comment: Several commenterprovided comments that the attainment application is premature. The commenternoted that IDEM used data from 2004, 2005 and 2006 as the design values in the application; the commenters requested that the 2007 databe added to the application priorto submittal to U.S. EPA. (Gagliardi) (Gonzales) (Squire) (Smith) (Jorgensen) (Wennekes) (Light) (Hardy) (SAVE) (Defauw) As stated in introduction section ofthe 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 ofthe 2007 monitoring data. It shows that all ofIndiana's population-exposure monitoring sites continue to demonstrate attainment from 2005

- 2007. Comment: Several commenters also noted that although manyregulations exist, such as the Clean AirInterstate Rule (CAIR), which will help reduce PM2.5, some ofthese regulations havejustrecently 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 offederal and state rules which are currently in effect. Modeling shows thatfuture reductions resulting from the new rules will continue to further reduce PM2.5 levels. Comment: Several commenters support the comments submittedby Save the Dunes Organization. (Dunelands) (Calumet) (Hardy) IDEM acknowledges receipt ofthe comment Comment: Commenters strongly support IDEM's draftpetition for redesignation of Lake and Porter counties as attainment for fine particulate matter. (ISEG) (NWI Forum) Thankyou for your support. Comment: Commenters point out that Lake and Porter counties can onlytheoretically "contribute" to violations at the Cook countymonitors at Cicero and Wilson Avenue when the wind is blowing one finite direction

- from the southeast. EPA's own wind rose analysis indicates thatprevailing 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)

7IDEM 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 standardpriorto an Attainment orRACT SIP being due, and since the implementationrule for fine particles stipulates that states are only required to draft and implementRACT rules for the precursor emissions reductionsnecessary to attain the standard, no further RACT rules are required for this area. (ISEG) (NWI Forum) IDEM appreciates the support. It should be noted that the majority ofmajor sources for NOxwithin Lake and Porter counties are subjectto the NOxSIP Call, thereby meeting RAeT requirements for NOx' Therefore, any reductions to be gained through the applicability ofNOxRACT for Lake and Porter counties would be negligible. Comment: The commenteropposes IDEM's intent to seek redesignation ofLake and Portercounties 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 collectivelyto solve regional air quality challenges. (IKE) IDEM contends that the area and the associated petition meets the requirements for redesignation contained in the Clean AirAct, and therefore, it should be redesignated to attainment. IDEM intends to continue working cooperatively with LADCO and the otherLADCO states to address regional air quality issues, and that cooperation is not dependent on the designation status ofLake and Porter counties. Comment: The commenter states that it is premature for Indianato 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 notprovide for attainment ofthe standard in the Chicago area. Comment: The commenter states that air quality data do not supportthis 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.

8Commentermentions that Lake and Porter counties arepart ofamultiComment: state a a areabefore the entire areahas attained. Based on conversation with U.S. EPA Region V staff, the agency has never approved such a request. (IKE) 

### IDEM is aware ofthe 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 thatis in compliance with the annual fme particle standard, and thereby eligible for redesignation, based on Section 107(d) ofthe Clean AirAct. Comment: Like ozone in some respects, PM2.5 is aregional pollutant. The main sources ofemissions 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 motorvehicles, 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 ofa few monitoring sites in Cook County, Illinois. IDEM has determined thatLake and Porter counties are notprimary contributors to measured levels at those sites. A number ofmonitoring sites located between and/or around the site locations with values above the standard measure air quality below the standard. If

### Lake and Porter counties were primary contributors to monitored violations in NorthwestIllinois, these sites would maintain values above the standard as well. IDEM believes thatthe 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 atlevels less than 0.1 ug/m3. Comment: The commenternoted that several monitors in Lake County do notmeet therecentlyrevised PM2.5 daily standard of35 micrograms per cubic meter, based on 2005-2007 data. These counties are very likelyto be designated as nonattainmentunder 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 ordoes not meet health standards and whatpermittingrules 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 

### NorthwestIndiana that currently do not meetthe revised daily PM 2.5 daily standard of35 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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### ..r,elati;¥:eJ¥:;s:lllalLg,eogltap,hic"av.ca.,db:e.ctly,.influenced",by,a"spemfi.c"",b,,,:",,bn,,",.,,••,," ""'n,"""'"'''''''''''' source or sources ofair 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 airquality has greatly improved as aresult ofourjoint efforts, violations ofthe annual PM2 . 5NAAQS are still occurringin ourregion. We believethat emissions from Lake and Porter counties contribute significantlyto 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 ofthe nonattainment area does not primarily contribute to monitored violations ofthe standard within the Illinois portion ofthe nonattainment area. Lake and Porter counties are subjectto the most stringent group ofemission controls within the state ofIndiana. This collection ofpermanent 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 ofLake and Porter counties. Comment: As Indiana's petition notes, 

### PM 1.5 concentrations exceeding the level of the annual NAAQS were measured in northeastern Illinois during the 3-yearperiod, 2004-2006, used in your analysis. Based on the most recent 3-yearperiod, 2005-2007, a violation ofthe annual 

### PM1.5 NAAQS has beenmeasured at the Illinois monitoring station at the Washington High School. This monitoring station is the closest Illinois monitorto Lake County, Indiana. (IL EPA) Analyses performed by IDEM show that background concentrations and local sources have much greaterimpact on the Cook County, IL monitors than sources in NWIndiana.

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### There are two additional monitoring sites in close proximity to 170310022, one at 103rd and Luella Streets in Chicago (170310050) and one atRobertsdale in Hammond (180892010). Site 170310050 has a 2005-2007 design value of 14.7 uglm 3
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### Site 180892010 has a design value for the same time period of 14.0 uglm 3• 

### 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 similarregional 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 "pollutionrose" for this site, to illustrate the average PM2 .5 concentrations at this location based on the wind direction occurring during times ofelevated PM2.5 levels. Please note the high average contributions occurring at Washington High School when winds are from easterly through south-southeasterly wind directions. Itis 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. Itis 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
. 5violations at Washington High School. (IL EPA) 

### A summary ofthe 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 backtrajectories show that a majority ofthe previous day's air came from the south, west and southwestwith more stagnant conditions when the air was recirculated over the area. This information suggests thatthe 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 thatimpact a PM2.S monitoring site. The PSAT results show thatthe Illinois monitors are overwhelmingly impacted from the Chicago, Illinois portion ofthe 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.

11Chart 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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............,..,-,J 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 performedby LADCO demonstrates that Lake and Portercounties by themselves contribute amounts that are far greaterthan 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 nonattainmentin adjacent states. (IL EPA) Indiana has adopted the Clean Air Interstate Rule, which is intended to address power plantcontributions 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 orderfor 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.

12!



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### 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** 

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## ·ano-cWUsou·Ave:;'···T"..•".··· and in Lake and Porter counties. The location ofthe two violating monitors in Northeast Illinois results in 

### elevated concentrations representative oflocalized "urban excess", primarily attributable to localized mobile and fugitive source emissions. Indiana is confidentthat its contribution to this localized effectis negligible. Comment: Lake and Portercounties 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 ofa nonattainment area. (IL EPA) 

### Indiana's petition is to redesignate a portion ofthe interstate nonattainment area, not to revise the statistical boundaries, as allowed in Section 107.(d)(3) ofthe Clean AirAct. 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 ofair quality. (IL EPA) 

### IDEM has demonstrated in its petition thatitmeets the requirements for redesignation contained in the Clean AirAct, 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 ofa particle

- known as speciation

- is an importantpart ofthe effort to reduce PM2.5 levels and is accomplishedlargely through data generated byEPA's ambient air speciationmonitoring program. The commenteris concerned that 

### 2007 results from area speciation monitors are notreflected in the application. While these results may notbe need to be considered in this application, it mustbe noted that a number ofthe readings were above the daily standard of35 micrograms at the Gary IITRI monitoring location. (SAVE) 

### Speciation data has notbeen reviewed for the Gary IITRI monitor. While some values may currently be above the revised daily PM standard of35 micrograms per cubicmeter, 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 thatif the designations are made in 2009, the area will have realized air quality benefits from recently implementedmeasures and may not be violating the daily standard when designations occur. .

13The Environmental Protection Agency has launched a voluntary partnership programto 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 majorpurposes ofLADCO, as stated in aMemo ofAgreement for Interstate Air Pollution Study and Control, signed in 2004 by former IDEM Commissioner Lori Kaplan, is the development ofmulti-state, multi-pollutantplanning to support the development ofeffective 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 ofthe 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 ofthe standard would occur. I Comment: Commenternoted that it was not clearthat 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) I 

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IDEM has demonstrated in its petition that itmeets 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 otherLADCO states to address regional air quality issues within the region. Comment: While trying to demonstrate Indiana's lack ofculpability in impacting the Chicago nonattainment area you used February 3,2005 as an example ofa monitored day higher than the daily standard ofmore than 35 micrograms. Itis 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

14;; "1I

I i ·f 1 I I '1 I ·1 minimum of75% ofthe data per quarter must be available in order to determine if 

# I the design value represents attainment. Ifless than 75% ofthe 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£** 

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# 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. I 

### Comment: Underthe 3.5 Continued Monitoring Section, you indicate thatthe existing monitoring network could potentiallybe changed with EPA approval. We would strongly object to any changes that mightbe made in the network since monitorchanges could potentiallybe 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 ofan 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 draftplan 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 amannerthat demonstrates that attainment was achieved based on pennanent and enforceable emission reductions. This application needs to demonstratemore clearlythat favorable weather conditions during the design value years did notheavily influence emissionreductions. (SAVE) Permanent and enforceable reductions ofsulfur dioxides, direct PM2.s, and oxides of nitrogen have contributed to the attainment ofthe annual standard for fine particles. Some ofthese reductions were due to the implementation ofthe NOx SIP Call, and some were due to the application oftighter 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 ofpermanent and enforceable emissions reductions implemented in the region. 

### Comment: Onpage 25 ofthe application, you indicate that utilities can meet their budget for nitrous oxide (NOx) emissions bypurchasing emission credits. How many credits were actuallypurchased and how much impact do these creditpurchases actually have on the reduction ofregional NOx emissions? (SAVE)


### 15