1 Draft Technical Support Document

Indiana

Area Designations For the

2010 SO 2 Primary National Ambient Air Quality Standard

Summary

Pursuant to section 1 07(d) of the Clean Air Act , EPA must initially designate areas as either “unclassifiable”, “attainment”, or “nonattainment” for the 2010 one

- hour sulfur dioxide (SO 2 ) primary national ambient air quality standard (NAAQS)

. The Clean Air Act defines a nonattainment area as

one that does not meet the NAAQS or that contributes to a violation in a nearby area.

Indiana submitted recommendations on May 11, 2011 with supplemental recommendations on January 6, 2012 and April 26, 2012

. Table 1 below lists Indiana’s recommendations and identifies the counties or portions of counties in Indiana that EPA intends to designate “nonattainment” based on monitored

violations

.

Table 1

. Nonattainment Designation for Indiana

Area Indiana ’s Recommended Designation of Areas/Counties EPA’s Intended Designated

Nonattainment Areas/Counties Indianapolis , IN Marion County (part ial )

- Wayne , Center and Perry Township s Nonattainment Nonattainment

Morgan County , IN Morgan Co unty (partial)

- Clay and Washington Townships Nonattainment Nonattainment

Richmond , IN Wayne Co unty (partial)

- Wayne Township Nonattainment Nonattainment

Southwest Indiana , IN

Daviess Co unty (partial)

- Veale Township

Pike Co unty (partial)

- Washington Township Nonattainment

Nonattainment Nonattainment

Nonattainment

Terre Haute , IN Vigo Co unty (partial)

- Fayette Township

- Harrison Township

- Otter Creek Township Unclassifiable

Nonattainment

Unclassifiable Nonattainment

Nonattainment

Nonattainment2 Background

On June 3, 2010, EPA revised the primary SO 2 NAAQS (75 FR 35520, published on June 22, 2010). EPA revised the primary SO 2 standard by establishing a new one

- hour standard at a level of 75 parts per billion (ppb) w hich is attained when the three

- year average of the 99 th percentile of one

- hour daily maximum concentrations does not exceed 75 ppb. EPA has determined that this is the level necessary to provide protection of public h ealth with an adequate margin of safety, especially for children, the elderly and those with asthma. These groups are particularly susceptible to the health effects associated with breathing SO 2

. EPA is revoking the two prior primary standards of 140 ppb evaluated

over 24 hours, and 30 ppb evaluated over an entire year because they will not add additional public health protection given a one

- hour standard at 75 ppb. Accordingly, EPA is not designating areas in this process on the basis of either of these two primary standards. Similarly, the secondary standard

for SO 2 has not been revised, so EPA is not designating areas in this process on the basis of the secondary standard.

EPA’s SO 2 Designation Approach

Section 107(d) of the Clean Air Act requires that not later than one year after promulgation of a new or revised NAAQS, state Governors must submit their recommendations for designations and boundaries to EPA by June 2011. Section 107(d) also requires EPA to provide notification to states no less t han

120

- days prior to promulgating an initial area designation that is a modification of a state’s

recommendation

. EPA was to promulgate initial area designations within two years of promulgation of the revised primary standard, although EPA has extended this deadline for one additional year due to having insufficient information to promulgate the designations. If a state did not submit designation recommendations, EPA will promulgate the designations that it deems appropriate

. If a state or tribe disagr ees with EPA’s intended designations, they have an opportunity to demonstrate why any proposed modification is inappropriate.

Designations guidance was issued by EPA through a March 24, 2011, memorandum from Stephen D. Page, Director, U.S. EPA, Office of Air Quality Planning and Standards, to Air Division Directors, U.S. EPA Regions I

- X. This memorandum identifies factors EPA intends to evaluate in determining boundaries for areas designated nonattainment. These five factors include: 1) a ir quality data ; 2)

e missions and emissions

- related data (location of sources and potential contribution to ambient SO 2 concentrations) ; 3) m eteorology (w eather/transport patterns); 4) g eography/topography (mountain ranges

or other air basin boundaries); and 5) j urisdictional boundaries (e.g., counties, air districts, pre

- existing nonattainment areas, reservations, metropolitan planning organization) , among any other criteria deemed to

be relevant to establishing appropriate area designations and boundaries for th e one

- hour SO2 NAAQS.

The March 24, 2011, memo recommended that area boundaries default to the county boundary unless

information provided by the state or tribe justifies a larger or smaller boundary than that of the county. EPA believes it is appropriat e to evaluate each potential area on a case

- by

- case basis, and to recognize that

area

- specific analyses conducted by states, tribes and/or EPA may support a differing boundary than a county boundary.

In this technical support document, EPA discusses its r eview and technical analysis of the recommendations regarding areas with monitored violations submitted by Indiana for designations for the

one

- hour SO 2 standard and any modifications from these recommendations.3

Definition of important terms used in this document:

1) Designated nonattainment area

– an area which EPA has determined, based on a s tate
recommendation and/ or on the technical analysis included in this document, has violat ed the 2010 SO 2 NAAQS

, based on the most recent three years of air quality monitoring data , or contributes to a violation in a nearby area.

2 ) Recommended nonattainment area

– an area a s tate or t ribe has recommended that EPA designate

as nonattainment.

3 ) Violating monitor

– an ambient air monitor meeting all methods, quality assurance and siting criteria and requirements whose valid design value exceed s 75 ppb, as described in Appendix T of 40 CFR part 50.

4 ) 20 10 SO 2 NAAQS

– The NAAQS for SO 2 promulgated in 20 10

. This NAAQS is 75 ppb, b ased on

the three year average of the 99th percentile of the annual distribution of daily maximum one

- hour average concentrations. See 40 CFR Part 50.17.

5) Design Value

- a statistic computed according to the data handling procedures of the NAAQS (in 40

CFR 50 Appendix T) that , by comparison to the level of the NAAQS , indicates whether the area is violating the NAAQS

.

Technical analysis for the Indianapolis , IN Area

Introduction

This technical analysis for the Indianapolis , IN Area identifies Marion County with a monitor that

violate s the 2010 SO 2 NAAQS

, and evaluates nearby counties for contributions to SO 2 concentrations

in the area. EPA has evaluated this county and nearby counties based on a review of the evidence for

the factors recommended in t he March 24, 2011 EPA guidance

.

Figure 1 is a map of the area showing the locations and design values of air quality monitors in the area, and the counties surrounding any violating air quality monitors.4

Figure 1. Map of Indianapolis , IN area sources and monitors

For the Indianapolis , IN area, Indiana recommended that a portion of Marion County consisting of Center, Perry, and Wayne Townships be designated nonattainment.

Based on EPA's technical analysis described below, EPA agrees with the State’s recommendation.
Thus, EPA is intending to designate the three recommended townships in Marion C ount y in Indiana as nonattainment for the 2 010 SO 2 NAAQS to define the Indianapolis nonattainment area.

Detailed Assessment

Air Qual ity Data

This factor considers the SO 2 air quality monitoring data, including the design values (in ppb )

calculated for all air quality monitors in Marion C ount y in the Indianapolis area and the surrounding

area based on data for the 2009 to 2011 period

.

The 2010 SO 2 NAAQS design value for Marion County, Indiana in the Indianapolis , IN area is shown

in Table 2

.

Table 2 . Air Quality Data for Nonattainment Designations in Indianapolis
County State Recommended

Nonattainment? Monitor Air Quality System ID Monitor Location SO 2 Design Value,

2009

- 2011 ( ppb )

Marion Yes 18

- 097

- 0057 39.749,

- 86.1836 8 0

Marion No 18

- 097

- 0073 39.7895,

- 86.0608 56

Marion No 18

- 097

- 0078 39.8111,

- 86.1145 40

Monitor in Bold has the highest 200 9

- 2011 design value in the respective county.5

Marion County show s a monitored violation of the 2010 SO 2 NAAQS. Therefore

, some area in th is

count y and possibly additional areas in surrounding counties must be designated nonattainment

. The

absence of a violati ng monitor alone is not a sufficient reason to eliminate nearby counties as

candidates for nonattainment status. Each area has been evaluated based on the evidence for the five

factors and other relevant information.

Emissions and Emissions

- Related Data

Evidence of SO 2 emissions sources in the vicinity of a violating monitor is an important factor for determining whether a nearby area is contributing to a monitored violation. For this factor, EPA evaluated county level emission data for SO 2 and any growth in SO 2 emitting activities since the date represented by those emissions data

.

Emissions

EPA recognize s that there might be no new information on any changes in emissions that may have

occurred after 2008, but would consider more recent years if available

. Indiana did not provide updated emissions information, therefore EPA relied on the 2008 N ational E missions I nventory (NEI)

emissions data (NEI08V 2 ).

Table 3 shows total emissions of SO 2 (given in tons per year) for violating and potentially contributing

counties in and around the Indianapolis area and sources emitting (or anticipated to contribute) greater
than 100 ton s per year of SO 2 according to the 2008 NEI.

Table 3 . SO2 Emission s (NEI08V 2 )
County Facility Located in

State

Recommended

Nonattainment Area ? Facility

– Total SO 2 Air

Emissions NEI08V 2 (tons per year) Facility Location Total County

SO 2 Emissions (tons per year)

Marion, IN Yes IPL Harding Street Station

19,578 39.7119,

- 86.1975 26,576

Yes C C Perry K Steam Plant

4,493 39.7622,

- 86.1667

Yes Rolls

- Royce Corporation

Plant 5 & 8

- 142 39.7245,

- 86.2696

Yes Covanta Indianapolis Inc

110 39.7337,

- 86.1888

Partial Indianapolis Intl

- 102 39.7066,

- 86.321

The four sources that are fully in the nonattainment area recommended by the State are relatively near

the violating monitor. The Indianapolis International Airport has relatively low emissions and is located approximately 13 kilometers from the violating monitor . Thus

, while Ind iana recommended boundaries for administrative convenience that include some but not all of this airport, the exclusion of a portion of the airport from the nonattainment does not represent the exclusion of any significant

contribution to the monitored vio lation.6

Emissions Controls

The emissions data used by EPA in this technical analysis and provided in Table 3 represent emissions levels taking into account any control strategies implemented on stationary sources in the Indianapolis area up to and including 2008. EPA has not received any additional information on emissions reductions resulting from controls put into place after 2008.

Meteorology (weather/transport patterns)

Indiana provided information indicating that winds on day s with high concentrations of SO 2 are most likely to come from the southwest but occasionally come from the northeast and other directions.

Geography/topography (mountain ranges or other air basin boundaries)

The Indianapolis area does not have any geog raphical or topographical barriers significantly limiting

air

- pol lution transport within its air shed. Therefore, this factor did not play a significant role in determining the nonattainment boundary.

Jurisdictional boundaries

Indiana did not have any nonattainment areas under the prior SO 2 NAAQS . EPA finds that county or township boundaries in Indiana provide a suitable administrative basis for formulating nonattainment

area boundaries.

Other Relevant Information

EPA did not receive additional information relevant to establishing a nonattainment area boundary for

this area.

Conclusion

After considering the factors described above, EPA intends to designate , based on monitored violations, Wayne, Center and Perry Townships in Marion County as the Indianapolis , IN

nonattainment area for the 2010 SO 2 NAAQS

. An air quality monitor in Marion County shows a

violation of the 20 10 SO 2 NAAQS, based on 2009 to 2011 air quality data

. EPA finds these three townships include the sourc es that contribute to this monitored violation

. Based on the consideration of all the relevant and available information, as described above, EPA believes that the boundaries described herein encompass the appropriate nonattainment area.7 Technical analysis for Morgan County , IN

Introduction

This technical analysis for Morgan County , IN identifies Morgan C ount y with a monitor that violate s the 2010 SO 2 NAAQS

, and evaluates nearby counties for contributions to SO 2 concentrations in the

a rea. EPA has evaluated this county and nearby counties based on the evidence for the factors

recommended in the March 24, 2011 EPA guidance

.

Figure 3 is a map of the area showing the locations and design values of air quality monitors in the area, and the counties surrounding any violating air quality monitors.

Figure 3. Map of Morgan County , IN area sources and monitors

For the Morgan County , IN area, Indiana recommended that a portion of Morgan County consisting of Clay and Washington Townships be designated nonattainment.

Based on EPA's technical analysis described below, EPA agrees with the State’s recommendation for

the Morgan County nonattainment area, based upon currently available information. These townships

are listed above in Table 1

.

Detailed Assessment

Air Quality Data8

This factor considers the SO 2 air quality monitoring data, including the design values (in ppb )

calculated for all air quality monitors in Morgan C ount y in the Morgan County area and the surrounding area based on data for the 200 9 to 20 1 1 period

.

The 2010 SO 2 NAAQS design values for Morgan County, Indiana in the Morgan County area are shown in Table 6

.

Table 6 . Air Quality Data for Nonattainment Designations in Morgan County

Cou nty State Recommended

Nonattainment? Monitor Air Quality System ID Monitor Location SO 2 Design Value,

200 9

- 20 1 1 ( ppb ) Morgan Yes 18

- 109

- 1001 39.515,

- 86.3917 100
Monitors in Bold have the highest 2009 to 2011 design value in the respective county.

Morgan County shows a violation of the 2010 SO 2 NAAQS. Therefore

, some area in this county and possibly additional areas in surrounding counties must be designated nonattainment

. The absence of a violating monitor alone is not a sufficient reason to elim inate nearby counties as candidates for

nonattainment status.

Emissions and Emissions

- Related Data

Evidence of SO 2 emissions sources in the vicinity of a violating monitor is an important factor for determining whether a nearby area is contributing to a monitored violation. For this factor, EPA evaluated county level emission data for SO 2 and any growth in SO 2 emitting activities since the date represented by those emissions data

.

Emissions

EPA recognize s that there might be no new information on any changes in emissions that may have

occurred after 2008, but would consider more recent years if available

. Indiana did not provide updated emissions information, therefore EPA relied on the 2008 N ational E missions I nventory (NEI)

emissions data ( NEI08 V2 ).

Table 7 shows total emissions of SO 2 (given in tons per year) for violating and potentially contributing

counties in and around the Morgan County area and sources emitting (or anticipated to contribute) greater than 100 ton s per year of SO 2 accordi ng to the 2008 NEI.

Table 7 . SO2 Emission s ( NEI08V2 )
County Facility Located in

State

Recommended

Nonattainment Area ? Facility

– Total SO 2 Air

Emissions NEI08V2 (tons per year) Facility Location Total County

SO 2 Emissions (tons per year)

Morgan, IN Yes IPALCO

- Pritchard Station

13,102 39.4867,

- 86.4165 13,821

Yes Hydraulic Press Brick Co.

- 515 39.538744,

- 86.3706489

Emissions Controls

The emissions data used by EPA in this technical analysis and provided in Table 7 represent emissions levels taking into account any control strategies implemented on stationary sources in the Morgan County area up to and including 2008. EPA has not received any additional information on emissions reductions resulting from controls pu t into place after 2008.

Meteorology (weather/transport patterns)

Indiana’s submittal provides pollution rose information that indicates that violations occur most often with southwesterly winds, but also indicates that violations can occur with other wind directions as

well.

Geography/topography (mountain ranges or o ther air basin boundaries)

The Morgan County area does not have any geographical or topographical barriers significantly limiting air

- pol lution transport within its air shed. Therefore, this factor did not play a significant role

in determining the nonatt ainment boundary.

Jurisdictional boundaries

Indiana did not have any nonattainment areas under the prior SO 2 NAAQS standard. EPA finds that

county and township boundaries are a suitable administrative basis for defining a nonattainment area.

Other Relevant Information

EPA did not receive additional information relevant to establishing a nonattainment area boundary for

this area.

Conclusion

After considering the factors described above, EPA intends to designate Clay and Washington Townships within Morgan County (as listed in Table 1) to comprise the Morgan County , IN

nonattainment area for the 2010 SO 2 NAAQS , based on a monitored violation in the county.

The air quality monitor in Morgan County shows a violation of the 20 10 SO 2 NAAQS, based on 200 9

to 2011 air quality data

. There are no other nearby areas that EPA finds to contribute to the SO 2 concentrations in Morgan County

. Based on the consideration of all the relevant and available information, as described above, EPA believes that the bound aries described herein encompass the an appropriate nonattainment area for the 20 10 SO 2 NAAQS.

Technical analysis for Richmond , IN

Introduction

This technical analysis for Richmond , IN identifies Wayne C ount y with monitor s that violate the 2010

SO 2 NAAQS

, and evaluates nearby counties for contributions to SO 2 concentrations in the area. EPA10

has evaluated this county and nearby counties based on the evidence for the factors recommended in the March 24, 2011 EPA guidance

.

Figure 4 is a map of the area showing the locations and design values of air quality monitors in the area, and the counties surrounding any violating air quality monitors.

Figure 4. Map of Richmond , IN area sources and monitors

For the Richmond , IN area, Indiana recommended that a portion of Wayne County consisting of Wayne Township be designated nonattainment.

Based on EPA's technical analysis described below, EPA agrees with the State’s recommendation for

the 2 010 SO 2 NAAQS to comprise the Morgan County nonattainment area, based upon a monitored violation of the NAAQS. Th is nonattainment area is listed above in Table 1

.

Detailed Assessment

Air Quality Data

This factor considers the SO 2 air quality monitoring data, including the design values (in ppb )

calculated for all air quality monitors in Wayne C ount y in the Richmond , IN area and the surrounding

area based on data for the 2009 to 2011 period

.

The 2010 SO 2 NAAQS design value for county in the Richmond and surrounding area are shown in

Table 8

.11

Table 8 . Air Quality Data for Nonattainment Designations in Richmond
County State Recommended

Nonattainment? Monitor Air Quality System ID Monitor Location SO 2 Design Value,

2009

- 2011 ( ppb )

Wayne Yes 181770006 39.8122,

- 84.89 87
Monitors in Bold have the highest 2009 to 2011 design value in the respective county.

Wayne County show s a monitored violation of the 2010 SO 2 NAAQS. Therefore

, some area in this

county and possibly additional areas in surrounding counties must be designated nonattainment

. The absence of a violating monitor alone is not a sufficient reason to eliminate nearby counties as

candidates for nonattainment status.

Emissions and Emissions

- Related Data

Evidence of SO 2 emissions sources in the vicinity of a violating monitor is an important factor for determining whether a nearby area is contributing to a monitored violation. For this factor, EPA evaluated county level emissio n data for SO 2 and any growth in SO 2 emitting activities since the date represented by those emissions data

.

Emissions

EPA recognize s that there might be no new information on any changes in emissions that may have

occurred after 2008, but would conside r more recent years if available

. Indiana did not provide updated emissions information, therefore EPA relied on the 2008 N ational E missions I nventory (NEI)

emissions data ( NEI08V2 ).

Table 9 shows total emissions of SO 2 (given in tons per year) for violating and potentially contributing

counties in and around the Richmond area and sources emitting (or anticipated to contribute) greater
than 100 ton s per year of SO 2 according to the 2008 NEI. Only Wayne County, shown in bold, contains sources sufficiently nearby to consider for including in the Richmond nonattainment area.

Table 9 . SO2 Emissions ( NEI08V2 )

County Facility Located in State

Recommended

Nonattainment Area ? Facility

– Total SO 2 Air

Emissions NEI08V2 (tons per year) Facility Location Total County SO 2 Emissions (tons per year) Wayne, IN Yes Richmond Power & Light

- 8,681 39.8028,

- 84.8953 9,012

Emissions Controls

The emissions data used by EPA in this technical analysis and provided in Table 9 represent emissions levels taking into account any control strategies implemented on stationary sources in the Richmond area up to and including 2008. EPA has not received any additional information on emissions reductions resulting from controls put int o place after 2008.

Meteorology (weather/transport patterns)

Pollution rose information provided by Indiana indicates that violations appear to occur exclusively when winds are blowing from the southwest, in which case s the Richmond Power & Light facilit y is upwind of the violating monitor.12

Geography/topography (mountain ranges or other air basin boundaries)

The Richmond area does not have any geographical or topographical barriers significantly limiting air

pol lution transport within its air shed. Ther efore, this factor did not play a significant role in determining the nonattainment boundary.

Jurisdictional boundaries

Indiana did not have any nonattainment areas under the prior SO 2 NAAQS standard

. EPA finds that township and county boundaries provide a suitable administrative basis for defining a nonattainment

area.

Other Relevant Information

EPA did not receive additional information relevant to establishing a nonattainment area boundary for

this area.

Conclusion

After considering th e factors described above, EPA intends to designate Wayne Township within Wayne County to comprise the Richmond , IN nonattainment area
, based on a monitored violation.

The air quality monitor in Wayne County shows a violation of the 20 10 SO 2 NAAQS, base d on 2009

to 2011 air quality data

. There are no other nearby areas that EPA finds to contribute to the monitored

violation of the SO 2 NAAQS in Wayne County

. Based on the consideration of all the relevant and available information, as described above, EPA believes that the boundaries described herein encompass the appropriate nonattainment area for the 20 10 SO 2 NAAQS.

Technical ana lysis for Southw est Indiana , IN

Introduction

This technical analysis for Southw est Indiana , IN identifies Daviess and Pike C ount ies with monitor s that violate the 2010 SO 2 NAAQS

, and evaluates nearby counties for contributions to SO 2 concentrations in the area. EPA has evaluated this county and nearby counties based on the evidence

for the factors recommended in the March 24, 2011 EPA guidance

.

Figure 5 is a map of the area analyzed showing the locations and design values of air quality monitors in the area, and the counties surrounding any violating air quality monitors.13

Figure 5. M ap of Southwest Indiana area sources and monitors

For the Southwest Indiana , IN area, Indiana recommended that Veale Township within Daviess County and Washington Township within Pike County be designated nonattainment.

Based on EPA's technical analysis described below, EPA agrees with the State’s recommendation for

the boundaries of the Morgan County nonattainment area for the 2 010 SO 2 NAAQS

. The townships to
be included in the nonattainment area are listed above in Table 1.

Detailed Assessment

Air Quality Data

This factor considers the SO 2 air quality monitoring data, including the design values (in ppb )

calculated for all air quality monitors in Daviess and Pike counties in the Southwest Indiana area and

the sur rounding area based on data for the 2009 to 2011 period

.

The 2010 SO 2 NAAQS design values for Daviess and Pike C ount ies , Indiana in the Southw est Indiana

area are shown in Table 10

.

Table 1 0 . Air Quality Data for Nonattainment Designations in Southwest Indiana
County State Recommended

Nonattainment? Monitor Air Quality System ID Monitor Location SO 2 Design Value,

2009

- 2011 (ppb)

Daviess Yes 180270002 38.5728,

- 87.2147 118

Pike Yes 181250005 38.5192,

- 87.2497 175
Monitors in Bold have the highest 2009 to 2011 design value in the respective county.14

Daviess and Pike C ounties show monitored violation s of the 2010 SO 2 NAAQS. Therefore

, some area in these counties and possibly additional areas in surrounding counties must be designated

nonattainment

. The absence of a violating monitor alone is not a sufficient reason to eliminate nearby

counties as candidates for nonattainment status.

Emissions and Emissions

- Related Data

Evidence of SO 2 emissions sources in the vicinity of a violating monitor is a n important factor for determining whether a nearby area is contributing to a monitored violation. For this factor, EPA evaluated county level emission data for SO 2 and any growth in SO 2 emitting activities since the date represented by those emissions da ta

.

Emissions

EPA recognize s that there might be no new information on any changes in emissions that may have

occurred after 2008, but would consider more recent years if available

. Indiana did not provide updated emissions information, therefore EPA relied on the 2008 N ational E missions I nventory (NEI)

emissions data ( NEI08V2 ).

Table 11 shows total emissions of SO 2 (given in tons per year) for violating and potentially contributing counties in and around the Southw est Indiana area and sources emitting (or anticipated to contribute) greater than 100 ton s per year of SO 2 according to the 2008 NEI. T he counties that contain all or part of the Southwest Indiana nonattainment area for the 2010 SO 2 NAAQS are shown in

bold

.

Table 11 . SO2 Emission s ( NEI08V2 )

County Facility Located in State

Recommended

Nonattainment Area ? Facility

– Total SO 2 Air

Emissions NEI08V2 (tons per year) Facility Location Total County

SO 2 Emissions (tons per year)

Pike Yes Hoosier Energy

- Ratts

Station

- 27,334 38.5183,

- 87.2722 49,850

Yes IPL Petersburg Generating

Station

- 22,494 38.5267,

- 87.2525

Daviess None 150

Emissions Controls

The emissions data used by EPA in this technical analysis and provided in Table 11 represent emissions levels taking into account any control strategies implemented on stationary sources in the

Southwest Indiana area up to and including 2008. EP A has not received any additional information on emissions reductions resulting from controls put into place after 2008.

Meteorology (weather/transport patterns)

Pollution rose information provided by Indiana suggests that high concentrations of SO 2 at t he Pike County monitor are most likely to occur with winds ranging from southwesterly to northwesterly. Nevertheless, w hen considering a one hour standard, violations can occur at anytime, even when weather patterns are varied from the normal trends of th e area. For this area, wind patterns can be from any direction. Therefore, for a one hour standard, it is useful to consider all directions to have potential contribution.15

Geography/topography (mountain ranges or other air basin boundaries)

The Southwest Indiana area does not have any geographical or topographical barriers significantly limiting air

- pol lution transport within its air shed. Therefore, this factor did not play a significant role

in determining the nonattainment boundary.

Jurisdict ional boundaries

Indiana did not have any nonattainment areas under the prior SO 2 NAAQS standard. EPA finds that township and county boundaries provide a suitable administrative basis for defining a nonattainment

area.

Other Relevant Information

EPA did not receive additional information relevant to establishing a nonattainment area boundary for

this area.

Conclusion

After considering the factors described above, EPA intends to designate Veale Township with in

Daviess County and Washington Township within Pike C ounty as the Southwest Indiana , IN

nonattainment area for the 2010 SO 2 NAAQS

.

The air quality monitor s in Daviess and Pike C ounties shows violation s of the 20 10 SO 2 NAAQS,

based on 2009 to 2011 air quality data

. There are no nearby areas outside these counties that EPA

finds to contribute to the SO 2 NAAQS violations in Daviess and Pike C ounties

. Based on the consideration of all the relevant and available information, as described above, EPA believes that the

boundaries described herein e ncompass the appropriate nonattainment area for the 20 10 SO 2 NAAQS.

Technical analysis for Terre Haute , IN

Introduction

This technical analysis for Terre Haute , IN identifies Vigo County with monitor s that violate the 2010

SO 2 NAAQS and evaluates nearby counties for contributions to SO 2 concentrations in the area. EPA

has evaluated this county and nearby counties based on the evidence for the factors recommended in the March 24, 2011 EPA guidance

.

Figure 6 is a map of the ar ea showing the locations and design values of air quality monitors in the area, and the counties surrounding any violating air quality monitors.16

Figure 6. Map of Terre Haute , IN area sources and monitors

For the Terre Haute , IN area, Indiana recommen ded that a portion of Vigo County consisting of Harrison Township be designated nonattainment.

However, EPA intends in addition to include Fayette Township and Otter Creek Township in this nonattainment area, to include an important contributing source (PSI Energy’s Wabash River plant, in Fayette Township) and connecting land to provide a continuous nonattainment area (in Otter Creek Township). Based on EPA's technical analysis described below, EPA is intending to designate these townships in Vigo County in Indiana as nonattainment for the 2 010 SO 2 NAAQS as part of the Terre

Haute nonattainment area

, based upon currently available information. These townships are listed

above in Table 1

.

Detailed Assessment

Air Quality Data

This factor considers the SO 2 air quality monitoring data, including the design values (in ppb )

calculated for all air qual ity monitors in Vigo County in the Terre Haute , IN Area and the surround ing

area based on data for the 2009 to 2011 period

.

The 2010 SO 2 NAAQS design values for county in the Terre Haute area is shown in Table 1 2

.17

Table 1 2 . Air Quality Data for Nonattainment Designations in Indiana
County State Recommended

Nonattainment? Monitor Air Quality System ID Monitor Location SO 2 Design Value,

2009

- 2011 ( ppb ) Vigo, IN Yes 181671014 39.5147,

- 87.4078 150

Yes 181670018 39.4861,

- 87.4014 90
Monitors in Bold have the highest 2009

- 2011 design value in the respective county.

Vigo County show s monitored violation s of the 2010 SO 2 NAAQS. Therefore

, some area in this county and possibly additional areas in surrounding counties must be designated nonattainment

. The absence of a violating monitor alone is not a sufficient reason to eliminate nearby counties as

candidates for nonattainment status.

Emissions and Emissions

- Related Data

Evidence of SO 2 emissions sources in the vicinity of a violati ng monitor is an important factor for determining whether a nearby area is contributing to a monitored violation. For this factor, EPA evaluated county level emission data for SO 2 and any growth in SO 2 emitting activities since the date represented by tho se emissions data

.

Emissions

EPA recognize s that there might be no new information on any changes in emissions that may have

occurred after 2008, but would consider more recent years if available

. Indiana did not provide updated emissions information, therefore EPA relied on the 2008 N ational E missions I nventory (NEI)

emissions data ( NEI08V2 ).

Table 13 shows total emissions of SO 2 (given in tons per year) for violating and potentially contributing counties in and around the Terre Haute Area and sources emitting or anticipated to

contribute greater than 100 ton s per year of SO 2 according to the 2008 NEI

. The counties that contain

a ll or part of the Terre Haute nonattainment area for the 2010 SO 2 NAAQS are shown in bold

.

Table 1 3 . SO2 Emissions NEI08V2
County Facility Located

in State

Recommended

N A Area ? Facility

– Total SO 2 Air

Emissions NEI08V2 (tons per year) Facility Location Total County

SO 2 Emissions (tons per year)

Vigo, IN No * PSI Energy

- Wabash River

75,823 39.53,

- 87.4247 78,291

Yes International Paper Co

- 1,215 39.4408,

- 87.42295

No * W abash R iver C ombined

C ycle P lant

- 414 39.530785

, - 87.424787

No Danisco Sweeteners

- 370 39.361448

, - 87.413742
*These sources are included in the nonattainment area that EPA intends to promulgate

The most significant source in the area, the PSI Energy

– Wabash River facility, is located in Fayette Township, just northwest of Harrison Township. This facility clearly contributes to the violation in Vigo County and must be included in the nonattainment area.18

Emissions Controls

The emissions data used by EPA in this technical analysis and provided in Table 13 represent emissions levels taking into account any control strategies implemented on stationary sources in the

Terre Haute area up to and including 2008. EPA has not received any additional information on emissions reductions resulting from controls put into place after 2008.

Meteorology (weather/transport patterns)

Pollution rose information provided by Indiana indicates that high concentrations of SO 2 are especially likely to occur with winds from the northwest (when winds are blowing from the PSI Energy

- Wabash River facility toward the violating monitors), but high concentrations can occur with a range of other

wind directions as well.

Geography/topography (mountain ranges or other air basin boundaries)

The Terre Haute Area does not have any geog raphical or topographical barriers significantly limiting

air

- pol lution transport within its air shed. Therefore, this factor did not play a significant role in determining the nonattainment boundary.

Jurisdictional boundaries

Indiana did not have any nonattainment areas under the prior SO 2 NAAQS standard. EPA finds that township and county boundaries provide a suitable administrative basis for defining a nonattainment

area.

Conclusion

Two air quality monitor s in Vigo County show a violation of the 2 0 10 SO 2 NAAQS, based on 2009 to

2011 air quality data. Indiana recommended defining a nonattainment area to include only Harrison Township, which includes the two monitors recording violations of the standard. EPA finds that the

nonattainment area must a lso include PSI Energy’s Wabash River power plant, which EPA finds to be a key contributor to the violations. This plant is located nearby in Fayette Township. EPA also intends to define a single relatively continuous area, which EPA envisions achieving by also including Otter Creek Township as a connecting township. Thus, a fter considering the factors described above, EPA intends to designate the Terre Haute , IN Area as nonattainment for the 2010 SO 2 NAAQS and to define this area to include Harrison, Ot ter Creek, and Fayette Townships in Vigo County.