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### ·-."'.'

## ~'·**'~** ,

.

JENNIFER M. GRANHOLM

GOVERNOR STATE OF M.!CHJGAN

DEPARTMENT OF ENVIRONMENTAL QUALITY

LANSING

June 13, 2008

Mr. Bharat Mathur, Acting Regional Administrator

U.S. Environmental Protection Agency, Region 5

77 West Jackson Boulevard (R19J) Chicago, Illinois 60604-3507

Dear Mr. Mathur:

# DE~

STEVEN E. CHESTER

DIRECTOR

The Michigan Department of Environmental Quality (MDEQ) submits the enclosed State Implementation Plan (SIP) revision for fine particulate matter (PM 2

. 5 ) for Southeast Michigan as required by the Clean Air Act.

This SIP submittal demonstrates through a weight-of-evidence approach that Michigan's

seven counties, designated as nonattainment of the 1997 PM 2

. 5 National Ambient Air Quality Standards, will be in attainment by 2010. The controls necessary to achieve

attainment are a combination of federal controls and state permits and orders that are referenced in this SIP.

If you have any questions, please contact Mr. G. Vinson Hellwig, Chief, Air Quality
Division, at 517-373-7069.

Enclosure

cc: Ms. Cheryl Newton, EPA

Mr. Chuck Hersey, SEMCOG

Mr. Mike Koerber, LADCO 

# s;"A

ste

..

# ,E.~ Director

517-373-7917

Mr. Jim Sygo, Deputy Director, MDEQ

Mr. G. Vinson Hellwig, MDEQ

Mr. Robert Irvine, MDEQ

CONSTITUTION HALL • 525 WEST ALLEGAN STREET • P.O. BOX 30473 • LANSING, MICHIGAN 48909-7973
www.michigan.gov • (BOO) 662-9278

## Michigan Department of Environmental Quality Air Quality Division



# STATE IMPLEMENTATION PLAN
SUBMITTAL

FOR

FINE PARTICULATE MATTER (PM 2.5 

# )

Michigan Department of Environmental Quality Air Quality Division

P.O. Box 30260 Lansing, Michigan 48909 http://www.michigan.gov/deqair

May 15, 2008Table of Contents

1. Executiv e Summa ry ...................................................................................... 1
2. Background and Overview of the PM 2.5 Rule.............................................. 13

2.1 General Background/ History of the PM 2.5 Rule ................................ 13
2.2 Michigan Nonatta inment Ar eas ........................................................ 13
3. General Planning Provisi ons ...................................................................... 17
4. State Implementation Plan Ap proval and Compliance with CAA

Section 110 and Pa rt D Requirements

. ...................................................... 18

5. Local Pl anning ............................................................................................ 19

6. Monito ring ................................................................................................... 20

7. Emissions In ventory ................................................................................... 21
8. Transportation Conf or mity B udget.............................................................. 24
9. Weight of Ev idence (WOE ) ......................................................................... 25

9.1 Fine Particul ate Matte r ..................................................................... 26

9.2 Emi ssions

........................................................................................ 27

9.3 Monito ring ........................................................................................ 29
9.4 Organic Carbon: Mo re Study Ne eded .............................................. 32

9.5 Mode ling .......................................................................................... 33

9.5.1 Photochemic al Modelin g .................................................... 33

9.5.2 Local Scale Dis persion Mode ling ....................................... 35

9.5.3 Combined Mode ling Result s............................................... 42

10. Attainment Strategy

.................................................................................... 44
10.1 Implementation of National Cont rols ................................................ 44
10.2 Implementation of Local Cont rols .................................................... 45
10.3 Voluntary Measures

......................................................................... 48
10.4 Tracking Progress and C ontinuing Eval uation ................................. 49

11. RACT an d RACM

....................................................................................... 50

11.1 RACT-R ACM Modelin g .................................................................... 50

11.2 NOx RACT -RACM Anal ysis ............................................................. 53

11.3 SO 2 RACT-RACM A nalysis ............................................................. 58

11.4 PM 2.5 RACT-RACM A nalysis ........................................................... 60
12. Reasonable Further Progre ss (R FP) Require ments................................... 64
13. Contingency Measures

............................................................................... 65

13.1 Tier I ................................................................................................... 65

13.1 Tier II .................................................................................................. 65

Referenc es ............................................................................................................ 70

Page iiFigures

Figure 1.a Southeast Michigan PM 2.5 Nonattainm ent Area................................. 1 Figure 1.b 3-year Average PM 2.5 Levels: Toledo and Luna Pier ......................... 2 Figure 1.c 3-Year Average PM 2.5 Concentrations 2001-2 003............................. 2 Figure 1.d Organic Mass Comparis on Dear born vs. Allen Pa rk.......................... 4 Figure 1.e Industrial Sources Within 3 Miles of Dearbo rn Monitor ...................... 4 Figure 1.f Influence of Iron on Crustal PM 2.5 ...................................................... 5 Figure 1.g Location of Severstal in Relation to Dear born Monitor....................... 5 Figure 1.h Pollution Rose fo r Iron at Dear born 2003-20 04 ................................. 5 Figure 1.i Average PM 2.5 Concentration at Each Site When Winds are from the

Northeas t ........................................................................................... 6 Figure 1.j Average PM 2.5 Concentration at Each Si te When Winds are from the

Northwes t........................................................................................... 6 Figure 1.k Average PM 2.5 Concentrations by Wi nd Direction 200 3-2004............ 7 Figure 1.l 3-Year Average PM 2.5 Concentrations Southe ast Michigan............. 10 Figure 1.m Average A nnual Statewide PM 2.5 Concentrations-Midwest States... 10 Figure 2.2.a PM 2.5 Nonattainment Area Showing Location of PM 2.5 Monitors...... 14
Figure 2.2.b Former PM 10 Nonattainment Area ................................................... 15
Figure 2.2.c Three-year average PM 2.5 Levels Toledo an d Luna Pi er ................. 16
Figure 6.a Michigan’s 2007 PM 2.5 Monitoring Ne twork ..................................... 20

Tables

Table 1.a Forecasted Change in PM 2.5 Concentration between 2005 and

200 9....................................................................................................9 Table 7.a Summary of Michi gan's nonattainm ent areas

................................... 22
Table 8.a Transportation Conformity Budget

.................................................... 24
Table 9.5.a Comparison of Clarkson and STI source apportionment results .......38

Table 9.5.b Severstal’s 2009 contribut ion to the Dearbo rn monitor .....................41
Table 11.1.a Statewide RACT-RACM run results .................................................52 Table 11.1.b 7-county nonattainment area RACT-RACM r un res ults....................53
Table 11.2.a NOx Tons and Pe rcentages by Emi ssion Sour ce .............................56
Table 11.2.b Percent Reduction and Do llar per Ton of NOX Reduct ions ..............56
Table 11.2.c NOx Emission So urces in Southeas t Michi gan .................................57
Table 11.3.a SO 2 Tons and Percentages by Emission Source .............................60
Table 11.3.b Potential SO 2 Tons Remo ved...........................................................60
Table 11.3.c SO 2 Emission Sources in Southeast Mi chigan .................................60
Table 11.4.a PM 2.5 Tons and Percentages by Emission Source ...........................62

Table 11.4.b Potential PM 2.5 Controls and Reduc tions Achi eved..........................63 Table 13.a Contingency m easures

..................................................................... 68

Page iiiAppendices

Appendix A: Weight of Ev idenc e Tables and Figures
Appendix B: Response to Public Comments
Appendix C: Emissions Inventory Methodology
Appendix D: Mobile Em issions used for the Conformity B udget Appendix E: Southeastern Michigan PM 2.5 Control Plan: Monitoring Strategy
Appendix F: Calculation of Severstal Emissions Appendix G: Overview of Recent Detroit PM Source Apportionment Studies Appendix H: Modeling Inputs Appendix I: A Conceptual M odel for Ambient Fine Partic ulat e Matter Over Southeast Michigan: High Concentration Days Appendix J: Severstal Permi t to Install (PTI) #182-05B

List of Acronyms

AEO Annual Emissions Output
AMS Area Mobile Source AQD Air Quality Division BOF Basic Oxygen Furnace
CAA Clean Air Act
CAIR Clean Air Interstate Rule
CAMD Clean Air Markets Division CAMR Clean Air Mercury Rule CEM Continuous Emissions Monitoring CERR Consolidated Emissions Reporting Rule
CIBO Council of Industrial Boiler Owners CMAQ Congestion Mitigation Air Quality
CMB Chemical Mass Balance
D.C. Circuit U.S. Court of Appeals for the District of Columbia Circuit DEQ Department of Environmental Quality DLEG Department of Labor and Economic Growth DOJ Department of Justice

E 7 Mi East 7 Mile
EC Elemental Carbon EGU Electric Generating Unit EIA Energy Information Agency EIIP Emissions Inventory Improvement Program EPA United States Environmental Protection Agency ESP Electrostatic Precipitator FCCU Fluid Catalytic Cracking Unit FHWA Federal Highway Administration
FRM Federal Reference Method

Page ivHPMS Highway Performance Monitoring System ICI Institutional, Commercial and Industrial IPM Integrated Planning Model LADCO Lake Michigan Area Director Consortium
LNB Low NOx Burner LMOP Landfill Methane Outreach Program LTO Landing-Take Off MAERS Michigan Air Emissi ons Reporting System MDA Michigan Departm ent of Agriculture MDOT Michigan Department of Transportation MDEQ Michigan Department of Environmental Quality NACAA National Association of Clean Air Agencies
NAAQS National Ambient Air Quality Standard
NAICS North American Industr ial Class ification System
NESHAP National Emissions Standards for Hazardous Air Pollutants NEI National Emissions Inventory

NH3 Ammonia NIF National Inventory Format NMIM National Mobile Inventory Model
NO Nitrous oxide NOx Oxides of Nitrogen
NSR New Source Review
NWS National Weather Service OC Organic Carbon OM Organic Mass

PM Particulate Matter

PM 10 Course Particulate Ma tter, <10 um in diameter

PM 2.5 Fine Particulate Matter, <2.5 um in diameter

PTI Permit to Install

PMF Positive Matrix Factorization RACM Reasonably Availa ble Control Measures RACT Reasonably Ava ilable Control Technology RFP Reasonable Further Progress RIC Reciprocating Internal Combustion [engine] ROP Renewable Operating Permit
RPS Renewable Portfolio Standards

RRF Relative Reduction Factor RTI Research Triangle Institute RVP Reid Vapor Pressure
SCC Source Classification Code SCR Selective Catalytic Reduction SEMCOG Southeast Michigan Council of Governments SEMOS Southeast Michigan Ozone Study SEP Supplemental Environmental Program
SIC Standard Industria l Classification SIP State Implementation Plan

Page vSNCR Selective Non-catalytic Reduction
SO 2 Sulfur Dioxide
SOx Oxides of Sulfur STI Sonoma Technology, Inc. STN Speciation Trends Network SWHS Southwestern High School (monitoring site) tpy Tons per Year TSD Technical Support Document
U.S. EPA United States Envi ronmental Protection Agency

VMT Vehicle Miles Traveled VOC Volatile Organic Carbon WOE Weight of Evidence

Page vi1. Executive Summary

The purpose of this summary is to synthes ize three years of planning and analysis of fine particulate (PM 2.5 ) pollution in Southeast Michi gan, and to demonstrate the connections between this analysis and the strategy for attaining the National Ambient Air Quality St andards (NAAQS) for PM 2.5 . While not technically required, this summary was prepared in the spirit of the Clean Air Act (CAA) and is intended for policymakers at all levels of governm ent as well as the general public. Some

technical information is included in this summary as necessary to communicate the policy that is the basis of the attainment st rategy. However, the vast majority of the
technical information is contained in other se ctions of this State Implementation Plan (SIP).

A new standard and an initial assessment

Over the last 30 years, t he United States Environment al Protection Agency (EPA) adopted several air quality standards to protec t the public from the health effects of particulate matter in our air. Each of these standards has been more stringent than its predecessor and the region has ac hieved compliance with each through regulatory programs to reduce emissions . The most recent NAAQS for fine particulate matter less than 2.5 microns or PM 2.5 ) was unique inasmuch as the region was in compliance with the daily standard, but some monitors measured
violations of the annual standard. In short, half of t he monitors were measuring attainment and half were recording viol ations of the annual standard (see Figure 1.a).

Figure 1.a

In examining the data between 2001 and 2003 we l ear ned the following about locations measuring violations:

1• Several monitors were closer to attaining the PM 2.5 NAAQS as compared to
other monitors in the region.

• Higher levels of PM 2.5 were most ly confined to a fairly well-defined subsection of Wayne County.

• The exception was a site in southern Monroe County (Luna Pier).

• Higher levels at the Luna Pier site tr acked with higher levels in the Toledo area (see Figure 1.b).

• Levels at the Dearborn monitor were clear ly higher than the rest of the region

and sites in other urban areas in the Midwest (see Figure 1.c).

Figure 1.b

Fi g ure 1.c

Source: MDEQ monitoring

2A closer examination of monitoring data

After this initial screening and evaluati on of monitoring data, we began a deeper probing of the data, seeking ans we rs to key questions including:

• What are the similarities and differences between levels at violating monitors,
particularly between Dearbor n and the other sites?

• What is the composition of PM 2.5 at the different sites (fine particulate is made up of a wide variety of constituents)?

• What sources are impacting the different sites?

Numerous studies and analyses were conducted in pursuing answers to these questions. In some case s, different studies produced co nflicting results. Nonetheless, we were able to converge on several more detailed findings supported by weighing the results of the different studi es. (A detailed description is provided in the “Weight of Evidence” section.)

Additional monitoring data were available and provided further confirmation that

monitors in southwest Detroit and east Dearbor n were very distinct from the rest of the region. In addition, the data showed that levels at all sites measuring violations were improving.

Moreover, we were able to note significant dif ferences in PM characteristics between Dearborn and other monitoring sites, particu larly Allen Park, which is only six miles
from Dearborn but is located in a less industrialized area. These identified differences provided invaluable information fo r isolating the causes of nonattainment as well as possible solutions.

In particular, it was clear that the Dearborn monitoring si te was much more h eavily influenced by industrial sources (see Figure 1.d), and levels of PM 2.5 had significantly higher amounts of soil and organi c carbon (OC). Furthermore , the vast majority of the “soil” component at Dearbor n was iron. Perhaps most significantly, reducing the levels of soil and organics at Dearborn to le vels characteristic of sites measuring compliance would likely bri ng Dearborn into attainment.

3Figure 1.d

Investigation of emission sources confirm ed there was a complex array of sources
within 3 miles of the D earborn site (see Fi gure 1.e). These sources vary in their levels of emissions as well as the way in which those emissions are discharged to

the air.

Figure 1.e

The significantly high proportion of iron in t he soil component at Dearborn, as well as pollution roses for this iron component, point ing directly to the southwest, clearly

4showed that this excess was a result of near by steel-making facility (see Figures 1.f1.h). 

### Figure 1.f

Figure 1.g Figure 1.h

N

5Finally, several evaluations were conducted assessing the degree to which sources in other parts of the region impacted particu late levels at the highest sites (Dearborn and SWHS). After looking at this issue from several perspectives, it was clear that
these sources had little to no influence on excess levels at these problem sites (see Figures 1.i-1.k). And, to whatever extent they did contribute particulate to these problem sites that contribution was going to be reduced as a result of the numerous multistate emission reduction programs already being phased in. These controls
come from a combination of industrial sour ces as well as motor vehicles and fuels.

Figure 1.i Average PM 2.5 Concentration at Each Site When

Winds Ar e F r o m t he Nor t he as t

Figure 1.j Average PM 2.5 Concentration at Each Site When

Winds Are Form the Northwest

6

### 1.k

7Additional monitoring data is available for analysis

With the passage of time, as the initia l analy ses described above were conducted, additional monitoring data were collected and analyzed. This allowed us to see if the new data supported or invalidated our initial findings.

The results were encouraging on a number of fronts. Improvements were being measured at all monitors. In fact, the si te at Luna Pier was measuring attainment

and EPA re vised its initial proposal for Toledo, designating it an attainment area. This confirmed our initial finding that while located in the Southeast Michigan region, Luna Pier’s particulate levels tracked more closely with those of Toledo.

Also, values at sites marginally out of compliance (Linwood, Allen Park and Wyandotte) were being reduced. These reductions were expected, and can be attributed to the ubiquitous nature of many of the mult i state pollution reduction programs being phased in. It was becoming clearer that these marginal sites would soon be in compliance with the standard.

Levels at Dearborn and SWHS monitors also improved but remained higher than all the other areas of the region. Initial fi ndings that local controls would have to be implemented to complement t he benefits of “on t he books” multistate controls were
reaffirmed.

Honing in on solving the problem required more extensive analysis

This reaffirmation resulted in a commitment to do more refined analysis to provide
information from multiple perspectives. Th is included investigat ions of monitoring, modeling, and emissions inv entory data. The multiple perspective analysis was designed to help sort out similarities and di fferences in study results in order to answer several policy questions:

• How much will regional reductions in emissions help? When?

• How much will local controls help?

• How well can we further pinpoint local sources and the species of PM 2.5 they

contribute?

We learned it was reasonable to expect sign ificant reductions in emissions and that regional reductions would cont ribute to reducing partic ulate levels from 1.5 and 1.9 μg/m 3 between 2005 and 2009 (see Table 1.a). The most helpful regional reductions would come from sources typically upwind of the Dearborn and SWHS monitors.

However, to the minor extent that other, typically downwind, sources in the region contribute to the problem, t here would be some incremental benefit fro m the major emission reductions occurring from regional controls. More importantly, if the impact of these downwind sources on excess levels was being underestimated, their beneficial impact on attainment (due to reductions from

8regional controls) was also being underestimated. Thus, we reaffirmed that local reductions were needed to reduce the excess particulate at this site.

Table 1.a Forecasted Change in PM 2.5 Concentrations between 2005 and 2009 Due to Regional and National On-the-Books Controls

Average Concentration

County Monitor '03-'05 '04-'06 '05-'07 2005

Base Year

Desig n Value 1 2009 Design

Value 2 Forecasted

Decrease

Wayne Dearborn 18.2 17.2 17.2 17.5 15.8 -1.7

Wayne Southwest

HS 16.4 15.8 15.5 15.9 14.2 -1.7
Wayne Wyandotte 15.4 14.3 14.3 14.7 13.1 -1.6
Wayne Linwood 15.2 14.2 14.3 14.6 13.1 -1.5
Wayne Allen Park 15.1 14.5 14.0 14.5 13.0 -1.5
Wayne E. 7 Mile 14.8 14.1 14.1 14.3 12.9 -1.4

Monroe Luna Pier 14.1 13.8 13.8 13.9 12.2 -1.7

Washtenaw Ypsilanti 14.3 13.6 13.7 13.9 12.2 -1.7

Oakland Oak Park 14.3 13.4 13.6 13.8 12.4 -1.4

St. Clair Port Huron 13.8 13 .1 13.2 13.4 11.8 -1.6
Wayne Livonia 13.9 13.1 13.2 13.4 11.8 -1.6

Macomb New Haven 13.0 12.5 12.5 12.7 11.4 -1.3

Source: LADCO Round 5 Modeling

1 Average of three 3-year periods, centered on 2005

2 Does not include impact of local controls at Marathon, U.S. Steel and Severstal.

Improvements in air quality continue , implementation of local reductions begins

Monitoring data through 2007 were now available. Analysis of these data led to the following findings:

• PM 2.5 levels continued to improve at all sites with the larges t improvements at the sites of greatest co ncern (see Figure 1.l).

• The organic excess at Dearborn declined for reasons we are not yet able to
explain.

• Unusually high levels were measured in 2005 in a multistate domain, (i.e.,
were unrelated to local changes in em ission levels), see Figure 1.m.

• Despite the 2005 levels, the trend remained downward and all but two sites were measuring attainment.

99 12 15 18 21

2000-2002 2001-2003 2002-2004 2003-2005 2004-2006 2005-2007Concentration (ug/m3) Dearborn

SW HS

Wyandotte

Allen Park

Linwood

Luna Pier

Oak Park

Ypsilanti

Livonia

E 7 Mile

Port Huron

New Haven Figure 1.l 3-Year Average PM2.5 Concentrations Southeast Michigan

Figure 1.m Average Annual Statewide PM 2.5 Concentrations – Midwest States

0 3 6 9 12 15 18

I llin o is

I ndiana

I owa Kan s as Michigan

M

innes o ta Misso u

r i Nebraska O hio Wis c ons i nConcentration (ug/m3)

2004 2005 2006

10In that same timeframe, implementation of local controls began. These included the installation of controls at Severstal Steel, reduced emissions at the Marathon Oil refinery, reductions at U.S. Steel, and t he modification of several continuously operated switch engine locomotives in t he rail yard adjacent to the Dearborn

monitor. These local controls were designed to supplement the benefits from regional reductions and to provide the additional increment needed to bring the

Dearborn monitor into attainment.

Furthermore, as of 2007 the SWHS site is marginally over the standard (15.5 μg/m 3 ) and will most likely measure attainment at the end of 2008. T here are three key reasons supporting this expectation that t he 3-year average will decline by another 0.5 μg/m 3 at the end of 2008. First, significant multistate emission reductions will continue reducing the regional contribution. Second, some of the benefits of local controls will begin accruing. And third, the unusually high values from the episode of 2005 will not be in the 3-year average (the average for the last 2 years is 14.6 μg/m 3 ).

Actions moving forward

The Michigan Department of Environmental Quality (MDEQ) will be tracking the

benefits of the local emission reductions des cribed above. As best as possible, the impacts of meteorology (positive or negative) will be taken into account.

Also, as part of its partnership with MD EQ, the Southeast Michigan Council of Governments (SEMCOG) purchased a conti nuous elemental carbon/organic carbon (EC/OC) monitor to gain a deeper understanding of OC levels in the Dearborn area. Data from this monitor, which began operating in June 2007, will allow creation of a multiyear database to track trends.

Finally, SEMCOG and MDEQ continue partner ing to improve the region’s air quality and have already initiated several steps in developing a plan for the newly promulgated 24-hour standard for fine particula te. While the strategy for complying with the annual average will cont ribute to attaining the new daily standard, we expect more action will be necessary.

A consulting contract to develop a conceptual model for days with high PM 2.5 concentrations has already been comple ted and will be used to craft another attainment strategy to address the unique aspects of the 24-hour standard (see Appendix I). While focused on explaining high daily PM 2.5 concentrations, data from this conceptual model also reinforces the strategy of targeted local reductions to attain the annual standard. Figure 5.5 in Appendix I shows the amount of local

PM 2.5 excess, by wind direction, at six of the monitors in Southeast Michigan on days with high fine particulate concentrations. In all cases the local excess is highest when winds are coming from t he region’s urban industrial core. This confirms that emission reductions to bring the Dearborn monitor into compliance must come from

this urban core.

11The results of the conceptual model have also led us to pursue additional analyses over the coming months. These analyses w ill provide a clearer explanation of the source contribution of specific PM 2.5 components, particularly OC, nitrate, and zinc. This continuing work will fu rther expand Southeast Michigan ’s wealth of information and knowledge regarding fine particulate concentrations in the area.

122. Background and Overview of the PM 2.5 Rule

2.1 General Background/History of the PM 2.5 Rule

The EPA promulgated the NAAQS for PM 2.5 in July 1997. Since the EPA lacked sufficient air quality data to make designa tions for the newly promulgated standards, Congress passed legislation that delayed designations until three years of air quality data were collected by EPA-approved air qualit y monitors. The fi rst monitors were put in place in 1998; however, a number of additional monitors did not come online until 1999, and therefore three complete year s of data could not be collected until the 2000-2002 time period.

After the EPA promulgated the PM 2.5 standard, several industry organizations and state governments challenged the EPA's action in the U.S. Court of Appeals for the
District of Columbia Circuit (the D.C. Circuit). On Ma y 14, 1999, the D.C. Circuit held that the CAA, as applied by t he EPA in setting the 1997 standards for particulate matter (PM) and ozone, was unc onstitutional as an improper delegation of legislative authority to the EPA. The ruling did not question the science or decision-making process used to establis h the standards. The court remanded the

PM 2.5 standards to the EPA but did not vacate them. In June 1999, the Department of Justice (DOJ) and the EPA petitioned the D. C. Court for a rehear ing and the D.C. Court denied the petition.

The DOJ and the EPA then filed a petition wi th the United States Supreme Court in December 1999 to appeal the decision of the D.C. Circuit. The Supreme Court held that the EPA's approa ch to setting the NAAQS was in accordance with the CAA and

did not constitute an unconstitutional del egation of authority. The Supreme Court
also affirmed that the CAA r equires the EPA to set standards at levels necessary to protect the public health and welfare, without considerin g the economic costs of implementing the standards. The Suprem e Court remanded several other issues back to the D.C. Circuit, including the iss ue of whether the EPA acted arbitrarily and capriciously in establishing the specific levels of the standards.

The D.C. Circuit heard argum ents in this remanded cas e in December 2001 and issued its decision on March 26, 2002. The D. C. Circuit rejected the claim that the EPA had acted arbitrarily and capriciously in setting the levels of the standards. This last decision by the D.C. Circuit gave the EPA a clear path to move forward with implementation of the PM 2.5 standards.

2.2 Michigan Nonattainment Areas

With the court’s support and sufficient dat a, the EPA co uld now move forward with nonattainment designations. States were directed to submit their recommendations for designations of attainment and nonatta inment. The MDEQ recommended that only Wayne and Monroe Counties be des ignated as nonattainment for PM 2.5 and that each county be designated as a separate nonattainment area.

13In June 2004, the EPA proposed a seven-county PM 2.5 nonattainment area for Southeast Michigan including Livingston, Macomb, Monroe, Oakland, St. Clair, Washtenaw, and Wayne Counties (Figure 2.2. a). The MDEQ submitted a letter in September 2004, again requesting two nonatta inment areas of only Wayne and
Monroe Counties instead of seven counties.

Wayne

Monroe Washtenaw Oakland

Livingston Macomb St. Clair

Monitor < standard

Monitor > standard Figure 2.2.a: PM2.5 Nonattainment Area showing the location of PM2.5

monitors

3

- Year Annual Average Year Annual Average

2005

- 2007 SWHS Dearborn

Source: SEMCOG 15.5 μg/m 3 Southwestern High School (SWHS) 17.2 μg/m 3 Dearborn PM2.5
Concentration Violating Monitor

Monitor originally >

standard Luna Pier Wyandotte Allen Park Linwood East 7 Mile Oak Park Port Huron

New Haven

Livonia

Ypsilanti

In that letter, the MDEQ stated that the seven-county nonattainment area in Southeast Michigan was arbitrary based on cu rrent and historical monitoring data for particulate matter. The monitors showi ng violation of the standard in Wayne County are located in an area with a history of par ticulate matter problem s, associated with local industrial sources. Figure 2.2.b shows the location of these monitors relative to
the former PM 10 nonattainment area. As the map illustrates, the areas are nearly identical. The primary source of the former PM 10 problem was determined to be a
few local industrial sources. Emissions from these sources were reduced and the region came into compliance in 1996 1

.

1 These emission reductions probably also helped lower PM 2.5 concentrations in the area. However, no long-term PM 2.5 monitoring data exist to determine the degree of improvement.

14Linwood Linwood E. 7 Mile Oak Park Figure 2.2.b: Former PM10 Nonattainment Area with Overlay of PM2.5 Monitors Wayne County

NORTHVILLE

NORTHVILLE

NOVI

PLYMOUTH PLYMOUTH

CANTON

VAN BUREN

SUMPTER BELLEVILLE Livonia

Dearborn SW High SW High

School

Wyandotte Allen Park FARMINGTON

LIVONIA

GARDEN CITY WESTLAND

INKSTER

ROMULUS WAYNE

HURON REDFORD SOUTHFIELD

DEARBORN HTS.

DEARBORN

FLATROCK TAYLOR

WOODHAVEN HIGHLAND PARK OAK

PARK

HAMTRAMCK

DETROIT

ALLEN

PARK MELVINDALE

SOUTHGATE

RIVERVIEW CENTERLINE

EASTPOINTE

TRENTON Former PM10 Nonattainment Boundary

Nonattaining PM2.5

Monitors (2004-2006)

Attaining PM2.5

Monitors (2004-2006) Source: SEMCOG

The MDEQ also asserted that most of t he monitors in the seven-county area were measuring attainment, making a wi des pread nonattainment designation inappropriate from a regulat ory perspective and misleadi ng from a public health perspective. Several monitors measuring attainment in the seven-county area are
downwind of the monitors sho wing violations of the standar d (i.e., all counties north of Wayne and Monroe Counties). Adding controls in these downwind counties

would not address the nonattainment in Wa yne and Monroe Counties. In addition, transport of PM 2.5 precursors from these counties would be addressed through the EPA’s Clean Air Interstate Rule (CAI R) and nitrogen oxides (NOx) SIP call.

The Luna Pier monitor, located in the sout heastern corner of Monroe County, is one
mile north of the Ohio bor der. In the February 2004, PM 2.5 nonattainment designation recommendation to the EPA, t he MDEQ asserted strongly that Monroe County should be designated as a separate nonattainment area from Wayne County

because PM 2.5 levels at the Luna Pier monitor tr acked more closely with those in Toledo, Ohio (Figure 2.2.c).

15Figure 2.2.c: 3-Year Average PM2.5 Levels Toledo and Luna Pier

12 15 18

1999-2001 2000-2002 2001-2003 2002-2004 2003-2005C o n cen tratio n(ug/m3)

Luna Pier

Toledo - Erie

Toledo - Collins

Toledo - Airport

Source: SEMCOG

Trend data showed that levels at the Luna Pi er site had been decreasing in rec ent years and would likely measure attainment by 2004. Levels at the site have continued to track those in Toledo, and monitors in both areas have measured
attainment of the standard since 2004. In 2005, EPA redesignated the Toledo area as attainment, but Luna Pier is still considered nonattainment because it was grouped with the Detroit nonattainment area.

The EPA made final nonattainment designations in April 2005. Disregarding the MDEQ’s recommendations, the EPA desig nat ed a seven-county area in Southeast Michigan as not attaining the PM 2.5 standard. As of 2006, the only monitors that currently record PM 2.5 concentrations above the standar d are in the industrialized section of Detroit in Wayne County.

163. General Planning Provisions

Pursuant to the requirements of 40 CFR 51, Appendix W, the MD EQ submits this SIP to meet the requirement s of the EPA’s Fine Partic ulate rules, which were adopted to comply with CAA requirements.

The MDEQ has authority to submit this SIP under Part 55, Air Pollut ion Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act 451).

The MDEQ provided public notice of t he opportunity to comment on the SIP on February 4, 2008. On F ebruary 4, 2008, MDEQ also provided notice of the opportunity for a public hearing if requested on March 11, 2008. Public comments were addressed and are summarized in Appendix B.

174. State Implementation Plan Appro val and Compliance with CAA Section 110 and Part D Requirements.

Section 110 of the CAA de lineates general SIP requirem ents and Part D contains requirements applicable to Subpart 1 nona ttainment areas. The language in MDEQ’s current rules refers to “particula te matter,” which would apply to any size fraction of particulate matter (e.g., PM 10 or PM 2.5 ). This provision in Michigan’s current law is adequate for the current SIP submittal and any future changes to the particulate matter standards. The MD EQ meets all the requirements of Section 110(a) SIP elements.

Programs for emissions limitations, pe rmitting, emissions inventories and statements, ambient monito ring, Reasonably Availab le Control Technology (RACT), Reasonably Available Cont rol Measures (RACM) and c ontingency measures are

included in t he MDEQ SIP.

Subpart 110(a)(2)(D) requires that SIPS c ontain certain measures to prevent sources in a state from signi ficantly contributing to ai r quality problem s in another
state. The MDEQ has met the requirements of the feder al CAIR to reduce NOx and sulfur dioxide (SO 2 ) emissions contributing to downw ind states. The MDEQ’s rules to implement the CAIR have been conditionally approved in a rule (Volume 42, Number 244, December 20, 2007).

The MDEQ administers a New Source Re view (NSR) permitting program for major
and modified sources of PM in nonattain ment areas under the MD EQ’s permit program. Permits to insta ll cannot be issued unless t he applicant can demonstrate
that increased emissions from the new or modified source will not result in a violation
of the NAAQS.

185. Local Planning

The SIP was developed in close consulta tion with SEMCOG and its air quality task force and technical advisory group. SEMCOG is the metropolitan planning organization for Southeast Michigan and t he lead local air quality planning agency
under the CAA.

In the early 1990s, SEMCOG formed t he Southeast Michigan Ozone Study (SEMOS), an air quality technical advisor y group to help understand the cause of air quality problems in the region and the sources that contri bute to them. While the group’s name implies that its focus is oz one, its mission is much broader. The group has been instrumental in the procurement and analysis of air quality data used in ozone, carbon monoxide, and PM 2.5 SIP development. SEMOS members are a diverse group of analysts, modelers, and scientists from both industry and government. While it includes many loca l stakeholders, repres entatives from the MDEQ, the EPA, Lake Michigan Air Directors Consortium (LADCO), and Canadian national and provincial environmental agencies also participate.

While SEMOS deals with the complex, tec hnical aspects of air quality, SEMCOG’s Air Quality Task Force addresses the local policy-related issues. The Task Force, which was originally formed in the 1990s to address the ozone and carbon monoxide NAAQS, was reconvened in 2003 to help eval uate strategies for bringing Southeast Michigan into attainment of the new 8-hour ozone standard and continues its activity in addressing PM 2.5 . The Task Force is comprised of state and local policymakers, industry representatives, and ot her community stakeholders.

This SIP utilizes data that was gather ed and analyzed by SEMOS and evaluated by the Air Quality Task Force. By coordinati ng with local, state a nd regional members,
MDEQ has worked to ensure that its strat egy provides reasonable reductions to mitigate impacts of sources on affected PM 2.5 nonattainment areas.

196. Monitoring

Section 110(a)(2)(B) of t he federal CAA requires a monitoring strategy for measuring, characterizing, and reporting PM 2.5 . The MDEQ maintains a comprehensive network of PM 2.5 air quality monitors throughout Michigan with the primary objective being to determine compliance with the PM 2.5 NAAQS. The MDEQ

submits network reviews 2 to the EPA Region 5 annually to ensure that its air monitoring operations comply with a ll applicable federal requirements.

Due to state and federal budget cuts, the MDEQ has reduced its monitoring net work

since the PM 2.5 designations were made. However, no reductions in the PM 2.5 Federal Reference Method (FRM) network in the designated nonattainment area

were made. The PM 2.5 monitoring network is shown in Figure 6.a.



### F igure 6.1: Michigan’s 2007 PM2.5 FRM Monitoring Network

Source: MDEQ Figure 6.a: Michigan’s 2007 PM 2.5 FRM monitoring network.

2 See http://www.deq.state.mi.us/documents/deq-aqd-ai r -aqe-Monitoring-Network-Review-final-9-6- 07.pdf for MDEQ’s 2006 network review.

207. Emissions Inventory

Rule 40 CFR 51.1002 (c) requires pollutants c ontributing to fine particles to be part
of a state’s SIP. The MDEQ believes t hat primary parti cles (EC/OC and crustal material), SO 2, and NOx are the main components of PM 2.5 , and they are included in our analyses. Volatile organic compounds (VOCs) and ammonia (NH3) are included in the emissions inventory (and modeling inventories); ho wever, they are not a part
of the MDEQ’s current a ttainment strategy for PM 2.5 . VOCs’ contributions to PM 2.5 are still being investigated, and therefore control measures for these compounds will not be included in this SIP (although cont rols for VOCs have been implemented for ozone nonattainment). NH3 emission estimates and atmospheric chemistry are very uncertain; therefore, the MDEQ is not including NH3 controls in this SIP revision.

Rule 40 CFR, Part 51.1008(a) requires the MDEQ to submit to the EPA statewide

emission inventories for direct P M 2.5 emissions and emissions of PM 2.5 precursors. The MDEQ must also submit any additio nal emission inventory information needed to support an attainment demonstration and Reasonable Further Progress (RFP) plan necessary to ensure expeditious atta inment of the standar d. The 2005 base year inventory for Michigan has been subm itted to the EPA pursuant to 40 CFR, Part 51, Subpart A – Emission Inventory Reporting Requirements.

As specified in the applicable EPA guidance, the emissions inventory for Michigan includes primary PM 2.5 , SO 2 , NOx, VOCs, and NH3.

A description of the methodology used to prepare the inventory appears in Appendix C. Mobile estimates for the nonattainment counties wer e prepared by SEMCOG and appear in Appendix D. Mobile emissions for other counties were prepared by the Midwest Regional Planni ng Organization’s (MRPO) contractor using traffic and vehicle information provi ded by the Michigan Department of Transportation (MDOT). The Lake Michigan Air Directors Consortium (LADCO) is the MRPO. A summary of the emissions in ventory is shown in Table 7.a. The MDEQ will update this inventory on a perio dic basis every three years.

In addition, emissions were project ed to 2009 to support the attainment demonstration. The base year and 2009 m odeling inventories were prepared by LADCO. The future year projections take into account existing control measures

and measures that are known to be on the way (e.g., CAIR measures). This inventory is referred to as the LADCO Base-M inventory. Procedures used to prepare these inventory produc ts can be found in the “Regional Air Quality Analyses for Ozone, PM 2.5 , and Regional Haze: Technical Support Document,” prepared by LADCO. LADCO has produced numerous su mmary reports with state and county total emissions and has posted them on their Internet site at:

http://www.ladco.org/tech/emis/basem/baseM_reports.htm

21Table 7.a. Summary of Michigan's nonattainment area 2005 base year annual emissions per county per pollutant in tonsper year (tpy) for area sources (area), nonelectric generating unit point sources(nonegu_pt), on-road mobile (on-road),off-road mobile (nonroad), electricgenerating unit point sources (egu_point),marine, air and rail (mar air rail), andammonia sources (modeled nh3).County name LivingstonMacomb Monroe Oakland St_Clair Washtenaw WayneTotalCounty ID93 99 115 125 147 161 163area3.32 13.42 2.88 24.91 3.29 6.71 32.01 86.54nonegu_pt0.15 16.24 79.41 19.73 10.33 4.48 132.61 262.95on-road200.7 645.87 205.5 1319.26 171.71 388.25 1859.1 4790.39nonroad1.3 4.42 1.44 7.24 1.71 2.66 8.48 27.25egu_point2.5911.781.8 16.17mar air rail0.05 0.27 0.57 0.44 0.34 0.12 1.46 3.25modeled nh3* 280.31 224.2 638.69 84.74 273.56 738.07 113.69 2353.26area647.95 2498.84 606.83 4535.97 563.69 1056.74 6039.67 15949.69nonegu_pt 654.19 720.91 3774.97 1096.91 1978.16 1050.26 9408.81 18684.21on-road 5417.9 14121.2 5454.4 31088 3812.6 9962.2 43981.4 113837.7nonroad 1288.1 5054 1404.71 7153.48 1519.17 2999.65 9410.39 28829.5egu_point5.91 134.42 38483.26 71.97 19690.31 1.45 11369.4 69756.72mar air rail 83.97 589.24 958.21 822.22 557.31 203.64 4166.3 7380.89modeled nh3*0area 1424.61 468.79 1176.54 761.34 341.99 245.58 920.34 5339.19nonegu_pt7.35 113.13 668.31 124.44 112.5 86.86 1342.36 2454.95on-road89.47 265.44 91 559.86 71.06 170.02 792.05 2038.9nonroad 120.62 339.65 121.96 614.54 108.58 2632.17 644 4581.52egu_point0.1 12.83 597.66 8.86 142.13 0.02 352.76 1114.36mar air rail2.55 13.91 29.11 23.91 18.3 6.02 99.3 193.1modeled nh3*0area 4338.29 11807.62 3663.62 17387.4 2671.18 5406.23 24887.81 70162.15nonegu_pt 176.95 2271.05 3555.73 2487.15 1379 388.83 6319.64 16578.35on-road 1696.9 5784.7 1742.6 11918 1550.9 3349.7 16931.1 42973.9nonroad 1927.32 4910.6 1893.76 9862.11 2166.18 2632.17 8396.96 31789.1egu_point0.19 39.67 300.92 8.54 285.490 175.34 810.15mar air rail 23.38 114.92 61.48 93.3 43.26 19.96 460.03 816.33modeled nh3*0VOCpollutantNH3NOxPM25-PRIM22County name Livingston Macomb Monroe Oakland St_Clair Washtenaw WayneTotalCounty ID93 99 115 125 147 161 163area226.78 930.59 181.05 1187.41 238.8 325 1540.36 4629.99nonegu_pt13.7 48.26 7733.15 274.99 1752.75 20.75 6396.53 16240.13on-road71.32 221.44 72.83 458.48 59.06 136.9 647.06 1667.09nonroad 139.72 426.07 139.75 683.2 125.05 342.2 883.35 2739.34egu_point0.07 4.32 120386.7 3.43 66576.72 0.28 40780.46 227751.98mar air rail7.53 38.28 82.64 64.67 72.99 16.93 398.38 681.42modeled nh3*0SO2pollutant* Emission from the NH3 Model for source categories not included in point, area or mobile categories (e.g. agriculture, etc.).238. Transportation Conformity Budget

Transportation conformity is required by Section 176(c) of t he CAA. The EPA’s conformity rule requires t hat transportation plans, program s, and projects conform to SIPs and establishes the criteria and proced ures for determining whether or not they do. Conformity to a SIP means that trans portation activities will not produce new air quality violations, worsen existing violatio ns , or delay timely attainment of the
NAAQS.

Estimates of on-road motor v ehicle emissions are project ed for the attainment year to assess emission trends and to ensure continued compliance wit h the PM 2.5 NAAQS. On-road emissions include thos e from cars, buses and trucks driven on public roadways. These estimates are considered a ceiling or “budget” for

emissions and are used to determine whet her transportation plans and projects
conform to the SIP. Estimated on -road mobile emissions of primary PM 2.5 and NOx must not exceed the emission budget contained in the attainment plan. The
emissions estimates for this sector reflect appropriate and up-to-date assumptions about vehicles miles traveled, socioeconomic variables, fuels used, weather inputs, and other planning assumptions. The me thodology used to estimate mobile emissions in the nonattainment counties ap pear in Appendix D. The transportation emission budget for conformity is provided in Table 8.a.

Table 8.a: Transportation Conformity Budget for Southeast Michigan (in tons per year)

Emissions

Scenario

Primary PM 2.5 

### NOx

2009 1,470 75,500

Source: SEMCOG, South east Michigan On-Road Mobile Source Emissions Inventory for the PM 2.5 State Implementation Plan, January 2008.

249. Weight of Evidence (WOE)

Rule 40 CFR Part 51.1007(a) requires the MDEQ to submit an attainment

demonstration showin g that the area will attain the annual and 24-hour standards as expeditiously as practicable. The demonstration must include: 1) inventory data (see also section 7), 2) emission reducti on analyses, and 3) modeling results on
which the MDEQ bases its attainment date.

The WOE approach used in this SIP includes a variety of data sources to make the demonstration that the Southeast Michigan PM 2.5 nonattainment area will attain the standard by 2010. The MDEQ believes this approach is the most scientifically defensible approach because it relies on not one method, such as modeling, but multiple sources of information. Th is approach provides a more robust demonstration in light of the many uncertain ties that remain regarding the relatively

new PM 2.5 annual standard.

The data sources used in this demonstration include monitoring data, emissions inventory data, photochemical and dispersion modeling, and trend analys is. Taken together, this information provides adequate proof that the areas with the highest
levels of PM 2.5 in the state, namely the Dear born/SWHS monitoring areas, have been seeing substantial reductions in PM 2.5 levels over the last several years. It shows that regional controls of NOx and SO 2 are reducing PM 2.5 in these areas and throughout the state, and will continue to do so for the next several years. The information further shows that significant amounts of PM 2.5 come predominantly from local upwind industrial source s, and that control of thes e sources, primarily the nearby steel mill, will br ing the area into attainment of the annual PM 2.5 standard by

2010.

The Detroit area has been recognized as havi ng a rich source of air quality data and has been the site of many studies by t he EPA (DEARS, multipollutant SIP study), the MDEQ (Detroit Area Toxics Initiative or DATI), University of Michigan, SEMCOG,
LADCO and other contractors. Part of the reason for th e rich data base is the high density of air quality monitors. These num erous monitors have allowed MDEQ to isolate, wit hin a few miles, the areas of highest air pollution, and thus the areas of greatest concern.

The MDEQ’s analysis and attainment strate gy focused on the monitors in Wayne County that are not or were not showing attainment of the standard. While local strategies were not the only ones investigat ed, they proved to be the most effective for attaining the standard. As only two of the 13 monitors in the seven-county area are not in compliance with the standard, and these two violating monitors are within three miles of each other, area-wide contro ls were determined to be impractical and ineffective, particularly since federal r equirements (CAIR, NOx SIP Call, mobile source controls, etc.) will already be controlling the majo r sources outside of Wayne County. Since monitoring trends and model ing data showed that regional on-thebooks controls would result in attainment of the standard at a ll but the Dearborn

25monitor by 2009, our efforts primarily fo cused on identifying and reducing the local

excess at Dearborn.

9.1 Fine Particulate Matter

In 1997, the EPA developed new NAAQS fo r fine particulate matter. The EPA designated the Southeast Michigan area (seven counties ) as nonattainment. The three-year average conc entrations for 2001-2003 showed six monitors were measuring violations of the annual PM 2.5 standard. Five of these monitors were in eastern Wayne County and the sixth was t he Luna Pier monitor in southern Monroe County (see Figure 2.2.a).

As Figure1 in Appendix A s hows, air quality in Southeas t Michigan has steadily improved over the last eight years. Currently only two monitors are showing
violations of the NAAQS standard: Dearborn and SWHS. These two are located in an area with a history of parti culate matter problems asso ciated with local industrial sources. Since the area successfully attained the PM 10 standard after the application of local controls, the MDEQ believes that the most effective attainment strategy for PM 2.5 is to also focus on local emission reductions from sources in this area while national programs will control secondary regional pollutants in the entire nonattainment area and beyond. This strat egy is supported by numerous studies showing a local excess at these two sites, particularly Dearborn that is not measured at other monitors as close as three miles away.

Fine particulate matter is a complicated mi xt ure of ammonium sulfate, ammonium nitrate, OC, EC, soil (or crustal mate rial) and other particles. Some PM 2.5 , particularly in urban areas, is anthropogenic (man-made) in origin and some is biogenic (plant-made) in origin. PM 2.5 is composed of primary (directly emitted) and secondary (formed in the atmosphere) par ticles. Our understanding of how much

PM 2.5 is primary versus secondary, and how fa st secondary formation takes place, is limited. Current speciation analyses of ambient monitoring dat a indicate that PM 2.5 concentrations result from both primary em issions (e.g., crustal matter, EC, and much of OC), and secondary formation (e.g., ammonium sulfate, ammonium nitrate, and some OC).

As discussed above, PM 2.5 is composed of many di fferent components that can come from a wide variety of sources. Few monitoring sites in Southeast Michigan have speciation monitors. Lack of speciated PM 2.5 data at most locations, especially some of those monitors that were orig inally showing violat ions of the standard (Linwood, SWHS, and Wyandotte), has made i dentification of spec ific local source contributors in these areas very difficul t. One must make assumptions based on source proximity to neighboring monitors that do have detailed data available. However, as will be discussed throughout th is WOE, data from the Allen Park and Dearborn monitors, only six miles apart, show significantly different species composition and source apportion ments, particularly with regard to OC and crustal

26material. This implies that very localized emissions are impacting the monitors, particularly at Dearborn.

In addition to the complexity of the PM 2.5 mixture, quantification of PM 2.5 emissions is still evolving. Techniques for measuring these emissions are still being evaluated and debated by the EPA as well as others. Much of the current inventory cannot be measured directly. Instead estimates ar e made through other methods such as factoring total PM emissions (which includes total suspended solids and PM 10 ), or use of activity levels and emission fact ors. This adds to the complexity of determining local source contributions.

9.2 Emissions

Significant emission reductions in the Midwest are expect ed from national controls, including CAIR and additional motor vehicle reductions (Tier 2, the Diesel Rule and low-sulfur fuel require ment s). The EPA’s Mobile6 model predicts that VOC, NOx,

and PM 2.5 emissions from on-road mobile sources alone will be reduced by approximately 50 percent between 2002 and 2009 in Southeast Michigan (see Figure 2 in Appendix A). In addition, national stationary source controls, including CAIR and the NOx SIP call, are expected to reduce point source NOx emissions by 40 percent and SO 2 emissions by 15 percent during this same time period. LADCO modeling of these control measures pr edicts they will result in a 1.3 – 1.7 μ g/m 3

reduction in PM 2.5 mass concentrations at every m onitor in the nonattainment area by 2009 (see Table 1 in Appendix A). Thes e reductions already take into account expected economic growth and increases in tr avel. This is compelling evidence that areas in Southeast Michigan that are current ly attaining the standard will remain in compliance.

While these reductions are already having a significant, positive impact in Southeast Michigan a nd both monitoring and modeling dat a indicated that they will bring SWHS into attainment by 2009, the same could not be said for Dearborn. Additional reductions in the vicinity of this site were clearly needed to ensure its compliance by

the 2010 deadline.

The Dearborn monitor is located in the indus trialized cor e of Detroit, which contains a complex array of emission sources (see Fi gure 3 in Appendix A). This monitor is within 1,000 yards of a steel mill (see Figure 4 in Appendix A). Analysis of speciated monitoring data, particularly the iron compon ent, as well as local hotspot modeling, indicate that emission reductions resulting fr om planned controls at this steel mill will be very effective in bringing Dearborn in to attainment (see Figures 5 and 6, Appendix A). Additional controls at the U.S. Steel facility and Marathon Oil refinery will provide even more emission reductions within a three-mile radius of this monitor. Based on a recent study contracted through EPA (RTI 2006) as well as permit application data, the MDEQ estimates t hese controls will provide a combined primary PM emission reduction of 317 tons/y ear (147 tons/year from controls at

27Severstal derived from MDEQ PTI #182-05B -- see Table 2 in Appendix A and Appendix F for details; 76 tons/year from U.S. Steel baghouse replacement MDEQ Consent Order (CO) #1-2005 and Renewab le Operating Permit (ROP) 199600123a; and 94 tons/year from Marathon through NS R settlement from PTI #388-07 -- see Table 3 in Appendix A).

A number of other industrial facilities in the area surrounding the Dearborn, SWHS, and Wyandotte monitors have either clos ed or scaled back their operations since 2002 (see Table 4 in Appendix A). These changes may be contributing to the more rapid decrease in PM 2.5 levels observed at industrial monitoring sites (see Figure 7 in Appendix A). While some of these changes are permanent (e.g., Honeywell), others may only reflect reduced operations due to Southeast Michigan’s sagging economy. Monitoring analysis will continue to s ee if these trends change in future.

In addition to the on-road mobile emissi on reductions previous ly mentioned, significant reductions are expected from off-road mobile sources. The exact
contribution of mobile sources at Dearborn is not yet known. However, the site is in close proximity to several rail yards, one of which is immedi ately upwind of the monitor. There are as many as 40 s witch yard locomotives operating within 2.5 miles of the site and most operate 24 hours per day, seven days per week. Some of these rail operations are also in t he vicinity of the SWHS monitor.

Over the next two years, 28 of the switch engines in this area will be retrofitted with anti-idling e quipment. These retrofits are being funded through a $1.5 million federal Supplemental Environmental Project. Ba sed on data from a similar project in Chicago (EPA 2004), this initiative is expected to reduce NOx emissions by 67 tons/year and PM by 2 tons /year. In addition, four s witch engine locomotives at the CSX rail yard immediately adjacent to the Dearborn monitoring site will be rebuilt with smaller engines over the next two year s, resulting in an annual emissions
reduction of 66 tons of NOx and 1.8 tons of di esel PM. This project is being funding through the federal Congestion Mitigati on Air Quality (CMAQ) program.

While the emissions reduction expected fr om retrofitting diesel switc h engine locomotives is relatively small compared to those at the large stationary sources, they are expected to have some impact bec ause of their low level of discharge and close proximity to the Dearborn monitor. In fact , modeling predicts the benefit of this control measure will have a much greater impact at Dearborn than at SWHS or Wyandotte (see Table 5 in Appendix A). Al so see Figure 8 in Appendix A for the location of the rail yards listed in Table 5.

In the course of the MDEQ’s technical an aly sis, a large number of storage piles, unpaved lots, and plots of barren land were obs erved within a three-mile radius of both the Dearborn and SWHS monitors (see Figure 9 in Appendix A). The vast majority of emissions from these “fugiti ve” sources are thought to be larger than

PM 2.5 . Nonetheless, the sheer number of them, and their possible aggregate impact, deserves attention. While many of these sources are already the subject of

28a regulatory program as the re sult of a previous SIP, more information is needed to determine the contribution of fugitive dust to PM 2.5 concentrations in the area and the specific sources of these emissions.

Other possible sources of local emissions are small point sources in the area that are exempt from the MDEQ ’s emissions inventory reporting because of lower emissions. Identification and study of thes e sources may occur in the future if funding becomes available.

The MDEQ also analyzed the im pacts of additional NOx and SO 2 emission reductions throughout the nonattainment area to evaluate the need for broad-based controls such as RACT. The MDEQ performed a special photochemical model run of the seven-county nonattainment area with a 100 percent reduction in NOx and
SO 2 for all source types. This provided a screening analysis of the impacts of a beyond-RACT control scenario. It was thought that if the run showed significant improvements in PM 2.5 annual levels, then more source-selective runs would be done. However, the modeli ng resulted in about 1 ug/m 3 reduction at the Dearborn monitor, and other monitors had less in t he area (see Table 6 in Appendix A). This
further reinforced the need for a localized emission reduction strategy in order to reach attainment. The application of RA CT-type control measures throughout the seven-county nonattainment, beyond those already being implemented through the NOx SIP call and CAIR, would do little, if anything, to address the PM 2.5 excess at
Dearborn and therefore would not address th e true source of the fine particulate problem in this area.

9.3 Monitoring

For the purpose of weight of evidence, m onitoring data clearly supports the MDEQ

assessment that attain ment of the annual PM 2.5 standard will be achieved by 2010.
Levels of PM 2.5 in the nonattainment area hav e been on a downward path for a number of years, and this tr end is expected to continue.

The latest three-year average concentrati on (2005-2007) shows that only two of the original six monitors are still exceeding the standard: Dearbor n and SWHS. Since 2000, PM 2.5 concentrations at all sites in the r egion have steadily declined. Overall, the three-year average concentration dropped 1.5 μ g/m 3 between the 2001-2003 and 2005-2007 time periods. The largest and fastest decreases have occurred at the sites with the highest concentrations in the industrial core: Dearborn (2.3 μ g/m 3 ), SWHS (2.0 μ g/m 3 ), Allen Park (2.1 μ g/m 3 ) and Wyandotte (2.6 μ g/m 3 ) (see Table 7 in Appendix A).

Despite a rise in 2005 PM 2.5 concentrations in Southeast Michigan and indeed the
entire Midwestern United States as a whole, there has been a strong downward trend in Southeast Michigan’s PM 2.5 concentrations over the last six years (see Figure 1 in Appendix A). In fact, every monitor in Southeast Michigan recorded its

29lowest annual average PM 2.5 concentration in 2006 or 2007 (see Table 8 in Appendix A). As a result, the last two three-year annual averages (2004-2006 and 2005-2007) show three additional monitors - Allen Park, Linwood and Wyandotte - are now measuring PM 2.5 levels that meet the standar d. In addition, the annual average at SWHS has been below the standard in both 2006 (14.68 μ g/m 3 ) and 2007 (14.54 μ g/m 3 ), and we expect the three-year average for this monitor to demonstrate attainment by the end of 2008.

Examination of trends in PM 2.5 chemical species between 2002 and 2006 shows downward trends for sulfates, nitrates, and OC at Dearborn, Allen Park, and Luna
Pier. The downward trend in OC is statistica lly significant at all three sites, with the greatest decrease occurring at Dearborn (-0.54 ug/m 3 /year, see Table 9 in Appendix A).

PM 2.5 in Southeast Michigan is comprised largely of sulfates, nitrates, and OC with small contributions from EC and crustal material (or soil, see Figure 10 in Appendix A). Various analyses of both local and regional monitoring data all indicate that Southeast Michigan’s nonattainment problem is caused by a combination of regional transport and local emi ssions from sources in the vicinity of the monitors showing violations of t he standard. A LADCO analysis of rural background concentrations versus urban exce ss in the Midwest showed the majority
of PM 2.5 measured in our region is coming from outside Southeast Michigan (see Figure 11 in Appendix A).

Monitoring data indicates that emissions from counties to the north of Wayne County

do not contribute to PM 2.5 nonattainment at the monitors showing violation of the standard. Analysis of this data shows that the vast majo rity of the urban excess at these monitors on days when winds are from the northeast, north or northwest comes from within Wayne County. Little increase is attributable to Oakland and Macomb Counties. And in all cases, average concentrations at the nonattainment monitors are well below the 15ug/m 3 annual standard when winds are from these directions (see Figures 12 and 13 in Appendix A). Furthermore, a recently developed conceptual model fo r days with high PM2.5 conc entrations shows that local fine particulate excess at various monito rs in the region is consistently highest when winds are coming from Wayne County’ s urban industrial core. Thus, rather than emissions from outlying counties contri buting to the local excess at Dearborn, it is the emissions generated in the highly in dustrialized portion of Wayne County that are impacting the outlying counties (s ee Figure 5.5, page 43 in Appendix I).

The regional background alone is not high enough to cause a violation of the standard, since all PM 2.5 monitors in the Southeast Michigan nonattainment area that are less impacted by local source s are meeting the st andard (see Figure 1 and Table 8 in Appendix A). Howeve r, two of the components of PM 2.5 , OC, and soil, have a higher (though declining) local cont ribution (see Figure 14 in Appendix A).

30Within Southeast Michigan, crustal matter is significantly higher at the Dearborn monitor, even though this monitor is less than three miles from several others (see Figure 15 in Appendix A). As mentioned ear lier, the crustal component is largely composed of iron (see Figure 6 in Appendix A). A wind rose for the iron component
of PM 2.5 at Dearborn points directly to the s outhwest. Conversely, the iron wind rose for Allen Park, while measuring much lo wer levels, points to the northeast (see Figure 16 in Appendix A). The Allen Park monitor is approximately five miles
southwest of Dearborn. Additional wind direction analysis shows that, when winds are from the southwest (the predominant wind direction), average crustal concentrations at Dearborn are over 2.5 μg/m 3 higher than those at Allen Park and are sometimes as much as 6 μg/m 3 higher (see Figure 17 in Appendix A). This clearly indicates a significant local iron source directly between these two sites and

closer to the Dearborn monitor.

Additional evidence of a local emissions source is seen in total PM 2.5 as well. The
incremental difference in PM 2.5 concentrations at Dearborn is greatest when compared to monitors to the southwest and west of this site (see Figure 18 in Appendix A). This indicates that there is a large loca l source between Dearborn and the “background” monitors (Allen Park, Luna Pier and Ypsilanti). The Severstal steel facility lies in exactly this position (see Figure 19 in Appendix A). As part of a consent order and permit with the MDEQ, this facility is in the process of installing new baghouses on its blast furnaces and basic oxygen furnace, as well as other control equipment. These changes are expected to reduce primary PM 2.5 emissions at this facility by 147 tons/year (see Table 2 in Appendix A and Appendix F for additional details).

In addition to crustal materi al, OC is signific antly hi gher at the Dearborn monitor (1.5 - 2.0 μg/m 3 higher), even though this monito r is less than three miles from several others (see Figure 15 in Appendix A). The Dearborn wind rose for OC indicates a more even distribution than iron, but still shows noticeably higher
concentrations when the wind is from the we st, southwest or south (see Figure 16 in Appendix A).

A separate analysis of OC levels by wind dir ection indicates that the decrease at Dearborn is occurring at a faster rate than at Allen Park (see Table 10 in Appendix A). This provides corroborat ing evidence that local sources are significantly impacting OC at Dearborn. A faster decrease of OC at Dearborn compared to Allen Park is also shown in Figure 20 in Appendix A. It indicates that OC concentrations are becoming more similar to Allen Park and the difference between the sites has decreased by about 1 ug/m 3 in the past 5 years. However, the specific sources(s) of this excess OC have yet to be identified.

Currently, we are unable to explain the observed decrease in excess OC unique to Dearborn. If this reduction is permanent, fu ture analysis focused on explaining this

urban exc ess will be difficult.

319.4 Organic Carbon: More Study Needed

Determining the source of local OC emi ssions is difficult. Results o f source apportionment studies conducted to date are not definitive due to data limitations. However, the data indicates a significant local industrial component at Dearborn that

exceeds that seen at Allen Park and other sites in Southeast Michigan. Mobile sources also appear to significantly cont ribute to the OC mass (see Figure 21 in Appendix A). Further analysis is needed to identify the s ource(s) of OC excess at

Dearborn and determine how it can be contro lled. To this end, the MDEQ, with support from SEMCOG, has initiated conti nuous monitoring for OC at Dearborn. LADCO is sponsoring additional measurem ent-based source app ortionment studies

as well.

To help understand the OC fraction, six re cent source apportionment studies (based on the positive matrix factorization [PMF] statistical analysis method) were examined (Kenski 2007, see Figure 22 in Appendix A and Appendix G). Several common findings are:

• At Dearborn, the source apportionment studies indicate that local industrial sources, including steel manufacturing but also other metal industries, likely contribute 2.5-3.5 ug/m 3 to annual average PM 2.5

.

• Dearborn also experiences higher mob ile source impacts than Allen Park (1.3 to 1.7 ug/m 3 greater), and much of the increase is from diesel sources.

• Secondary sulfate and nitrate levels do not differ much between Allen Park and Dearborn, evidence that these leve ls are not being influenced by local sources. However, some of the indus trial source fingerprints did include sulfate mass, which indicates that lo cal sources of sulfate are present and
need further evaluation.

Chemical mass balance (CMB) analyses on high PM 2.5 days at Dearborn show varied patterns, suggesting that varying mixtur es of sources are impacting this site on any given day. Plumes from industria l sources as well as emissions from smoking vehicles appear evident in thes e episodes (see Figure 23 in Appendix A). However, the observed contribution from smoking vehicles is not unique to Dearborn. The same patterns are evident at Allen Park and other sites in Southeast Michigan, as well as sites in other parts of the Midwest where this analysis has been done. Thus, smoking vehicles do not appear to explain the PM 2.5 excess being measured at Dearborn (STI 2006).

Additional studies that hav e been conducted in Detroit to help assess the sources of

PM 2.5 , particularly for OC, are still being analyz ed. However, preliminary results of one study done by an advanced mobile labo ratory from Canada (CRUISER) showed some peaks in OC from high vehicle traffic areas, trains, and a sausage smoking factory (see Figure 24 for t he monitor data and Figure 25 for the map locations in Appendix A). In addition, upwind/downwind anal ysis of one of the Detroit steel mills showed a large difference in PM 2.5 , particulate sulfate, black carbon, and several

32precursors, as well as a small (0.8 ug/m 3 ) increase in OC (see Table 11 in Appendix A). Although this was only one sampling event taken in a short time period, it does indicate that this steel mill may have a si gnificant amount of particulate emissions, but may only be a moderate source of particulate OC.

Another preliminary analysi s by LADCO us ed nonparametri c regression and kernel density estimates to regress continuous monitor concentrations to wind speed and wind direction data to map locations of rela tively high OC and black carbon sources. This study was done at Dearborn and Allen Park as well as the Newberry and FIA (or Lafayette Street) sites, two of MDEQ’s new monitori ng sites, because they have the necessary black carbon continuous mo nitors. Newberry also has an OC

continuous monitor.

A highly industrialized area near Zug Island was indicated for high black carbon emissions in a combined analys is of all f our sites (see Figure 26 in Appendix A). The FIA site showed high black carbon em issions from the Ambassador Bridge (Figure 26 in Appendix A). The analysis at Newberry indicates that an intermodal freight terminal in the area emits higher c oncentrations of both OC and black carbon (similar to EC but uses a different anal ytical method to determine concentration) than the surrounding areas (see Figure 27 in Appendix A). Thus trains, trucks and cars may be an important source of these pollutants. However, these increases are relative to the surrounding areas and may only be a few tenths of a microgram increase. It is important to note that annual average co ncentrations at these two sites are currently below the st andard (see Table 8 in Appendix A). Also, EC tends to be a very small fraction of the total PM 2.5 mass. Overall, there are still many unanswered questions with OC and more needs to be done to identify the source(s) of OC excess at Dearborn, how they hav e changed over time, and if necessary, how they can be controlled in the future.

9.5 Modeling

For the purpose of weight of evidenc e, photochemical and disper sion modeling support the MDEQ assessment that attainment of the annual PM 2.5 standard will be achieved by 2010 at the monitors curr ently exceeding the standard, and that monitors that are meeting the standard wil l remain in attainment of the annual

standard. The most recent combination of photochemical and local scale modeling
shows attainment of the st andard at the highest monitor (Dearborn) by 2009. Details of these analyses follow.

9.5.1 Photochemical Modeling

Extensive photochemical modeling (CAM x) has been conducted by LADCO to

address PM 2.5 , as well as ozone and haze in Michigan. A comprehensive Technical Support Document (TSD) describes the mo deling parameters, th e testing of the model itself, and the predicted reductions in these pollutants in future years. An

33electronic version of the document is available at http://ladco.org/Technical_Support_Document.html . Section 3 of the TSD describes the model and inputs, and Section 4 provides the modeled future year PM 2.5 levels
for the state.

Table 10 (see also Table 1 in Appendix A) in the TSD shows the modeled PM 2.5 levels at several monitors in Wayne Count y, Michigan (not including the impact of local controls). The two highest monitors, Dearborn (261630033) and SWHS (261630015), have 2009 values of 15.8 ug/m 3 and 14.2 ug/m 3 , respectively, in the Round 5 modeling.

Of the two modeling scenarios, Round 5 is a more recent version than Round 4, with

Round 5 us ing a base year of 2005 and Ro und 4 using a 2002 base year. Other upgrades to the model and inventory were also made in the Round 5 modeling (see below for a summary and section 3.3 of the TSD for more details).

Base M/Round 5 (2005) Base K/Round 4 (2002)

• CAMx v4.50 * CAMx 4.30 • CB05 gas phase chemistry * CB-IV with update d gas-phase chemistry • SOA chemistry updates * No SOA chemistry updates • AERMOD dry deposition scheme * Wesley-based dry deposition • ISORROPIA inorganic chemistry • ISORROPIA inorganic chemistry • SOAP organic chemistry • SOAP organic chemistry • RADM aqueous phase chemistry • RADM aqueous phase chemistry • PPM horizontal transport • PPM horizontal transport

In addition, the models used different sets of meteorological (MET) data for the two modeling scenarios. Both 2002 and 2005 had above-average ozone-conducive days, but 2002 was more severe than 2005. The relationship between meteorology

and PM 2.5 is not well understood, but it likely influences PM 2.5 . Overall the models show good agreement in magnitude of PM 2.5 mass, but some species are

overestimated and others are underestima ted. In 2002, sulfates had good agreement, but nitrates were overestimat ed in winter. In 2005, sulfates are underestimated but nitrates had good agreement. In both years, OC is still largely

underestimated.

While both 2005 and 2002 are considered “SIP quality,” which bas e year used is a policy decision. The MDEQ has chos en to use the Round 5, 2005 emissions inventory since it is more recent and more accurately reflects actual conditions and emissions changes. Also the 2005 modelin g base year more closely predicts the actual annual averages from the air quality monitors.

The Round 5 modeling demonstrated that a ll monitors with the exception of the Dearborn monitor show attainment by t he 2010 attainment date. The Dearborn monitor is further evaluated using local scale modeling described below, which

shows that the local scale emission reduc tions at Severstal wil l bring the Dearborn monitor value to15.1 ug/m 3 by the 2010 attainment date.

349.5.2 Local Scale Dispersion Modeling

As a complement to LADCO’s CAMx, the MDEQ conducted local scale dispersion modeling to determine the impacts of lo calized emission reductions at large
industrial fa cilities in the vicinity of t he air monitors showing violations of the standard. This modeling s howed approximately 0.73 ug/m 3 annual reduction in

PM 2.5 at the Dearborn monitor as a result of the controls required at Severstal.

Additional reductions are attr ibuted primarily to the locomotive controls and controls
installed at Marathon and U.S. Steel.

The local scale modeling is a key to determining impacts of local controls on the nearby monitors that i s not accounted fo r in the CAMx. Predicted impacts from regional grid models such as CAMx cannot account for reductions in close proximity to the monitors because they typically use 36km or 12km grid resolution for SIP

attainment demonstrations. Emission reduc tions from a local area/point source within each grid are “spread out ” over the entire grid. Thus, grid models provide useful information concerning regional c ontributions but fail to adequately address neighborhood scale interactions.

For areas like the Dearborn monitor location, where local source primary emissions may contri bute a sizable portion of the total PM 2.5 (i.e., 10 to 30 percent of the total annual average), use of a Gau ssian dispersion model may wo rk well for determining local primary impacts within a small area. Such model ing techniques have become known as local scale, or “hotspot” modeling. Similar to regional scale photochemical grid modeling analyses, the EPA recommends that hotspot dispersion modeling

results be used in a relative manner rat her than the absolute manner employed in new source review (NSR) permitting anal yses. Therefore, that is the approach followed by the MDEQ in this WOE demonstration.

The process to determine neighborhood scale impacts fo llows the principles suggested in Section 5.3.2 of the EPA’s Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze dated April 2007. Similar gui dance has been discussed in various regional workshops sponsored by LADCO.

As indicated by Section 5. 3.2, there is no single, si mple method for quantifying the local contribution to a specific loc ation. In fact, the local component will likely include
contributions from more than one source. When applying the model to changes in primary PM 2.5 , the recommended approach is to ident ify the individual components
of PM 2.5 . This approach is necessary so that the non-primary components of PM 2.5 (i.e., nitrates, sulfates, etc.) can be re moved and only the primary portions can be considered. For purposes of this analysis, only the speciated primary components
identified as “soil” and “mixed industrial s” were considered. These components should contain most of the metals expect ed from the steel industry plus fugitive

emissions associated with large industrial areas.

35Local MET data was used to represent t he dispersive nature of the Southeast Michigan wind patterns. Meteorology dat a, collected from the National Weather Service (NWS) at the Detroit Metro Airport, was used for the local scale analysis. To be consistent with the regional scale model ing, 2005 meteorology was utilized. To
determine surface characteristics around the Detroit Metro NWS data collection site, the recently released EPA pre-processor ( AERSURFACE) was utilized. The results from the AERSURFACE program , which were separated by month over 12 sectors, was supplied to the EPA meteorological pre-processor, AERMET, to create the hourly meteorology data required by AERMOD.

The guidance further recommends that the analysis be done on a quarterly basis. This evaluation deviates from that appr oach because most of the referenced material was provided on an annual basis. For regional modeling, one reason for performing analyses on a quarterly basis is to account for secondary chemistry variances by season. Since the local sca le analysis deals expl icitly with primary emissions, seasonal chemistry variances do not apply. Therefor e, this deviation from the guidance is not expected to significant ly alter the results of this analysis.

The guidance recommends using a relati ve approach to determine the reductions from planned control strategies rather than absolute model resu lts. This is different from the usual application of results from Gaussian models for regulatory permitting. This is, however, consistent with regional modeling of PM 2.5 , thus is more appropriate for this purpose. The relati ve reduction factor derived from the 2005 base modeling and the antic ipated 2009 emissions was applied to the specified primary component of PM 2.5 for anticipated reductions.

a. Process for determining impacts of localized emissions reductions.

The methodology used to predict the impacts of required local SIP controls on future

PM 2.5 levels is summarized as follows:

1) Estimate the amount of observed (monitored) PM 2.5 at the Dearborn monitor that is local in origin. 2) Model base year PM 2.5 emissions (PM 10 if PM 2.5 emissions data is unavailable) from local point sour ces to determine the impact on the

Dearborn monitor. 3) Calculate the amount of observed PM 2.5 at the Dearborn monitor that comes
from Severstal. 4) Model future year (2009) PM 2.5 emissions from Severstal to determine impact on the Dearborn monitor. 5) Calculate the relative reduction factor for 2009 emission reductions at
Severstal. 6) Calculate the predicted PM 2.5 reduction at the Dearborn monitor in 2009 as
a result of SIP controls at Severstal.

361) Local impacts.

To confidently apply a dispersion model in an attainment test , it is first important to determine the local component of the monitored primary PM 2.5 . For this analysis, it is important to identify the local contributions from as small an area as possible to
ease identification of the lik ely contributing sources.

For purposes of this WOE demonstration, three monitoring sites in the area of Southeast Michigan with the highest PM 2.5 levels were reviewed: Dearborn, SWHS,

and Allen Park.

Dearborn monitor The Dearborn monitor consistently records the highest values of PM 2.5 in Southeast Michigan, making it the primary monito r of concern. The 2000-2004 weighted average (i.e., the average of the three 3- year averages from those years) is 19.3 ug/m 3 . As seen in Figure 28 in Appendix A, the monitor resides approximately 1,000 yards northeast of the Severs tal steel mill. This is t he direction of the climatic prevailing wind direction (Figure 29 in A ppendix A). Between the steel mill and the monitor lies a major rail switching yard that has approximately 19 to 30 trains per day being operated within the yard. Appr oximately 16 engines will be idling in the rail yard at any given time. The Ford Mo tor Company Rouge Complex is located just north of the Severstal facility. Another st eel company, U.S. Stee l, is located on Zug Island, approximately three miles southeast of the monitor. Additionally, a major gasoline refinery, Marathon, is located approx imately two miles sout h of the monitor. Figure 30 in Appendix A shows the relationsh ip of the monitor to these influencing
facilities. PM 2.5 filters collected at the Dearborn monitor are analyzed for particle speciation. This monitor has the highest PM 2.5 levels in the nonattainment area and is key to demonstrating attainment. It will become the primary point of reference in
this WOE demonstration.

SWHS monitor
The SWHS monitor is 2.2 miles east of the Dearborn monito r and approximately one
mile north of the U.S. Steel facility on Zug Island (Figure 30 in Appendix A). With the predominant southwest winds (Figure 29 in Appendix A), this location is also
vulnerable to emissions from U.S. Steel , Severstal, and Marathon. The 2000-2004 weighted average is 17.3 ug/m 3 . Speciated PM 2.5 data is not available from the
SWHS site.

Allen Park monitor The Allen Park Monitor is located approxim ately six miles southw est of the Dearborn monitor (Figure 30 in Appendix A). Due to the prevailing winds (Figure 29 in Appen dix A), the Allen Park monitor is locat ed upwind of the majority of facilities that likely impact the Dearborn and SWHS moni tors during southwest winds episodes. The 2000-2004 weighted av erage is 15.8 ug/m 3 . Due to the upwind nature of the Allen Park monitor location, this monitor c an provide more of a regional aspect of Southeast Michigan as compared to t he Dearborn and SWHS monitors, which

37receive a large local component of primary PM 2.5 . Filters collected at the Allen Park monitor are analyzed for particle speciation.

Dearborn vs. Allen Park monitor analysis Comparison of the particle speciation at Allen Park and Dearborn monitors provides helpful information on the local sources im pacting the Dearborn monitor. Several reports analyzing the Dearborn and Allen Park filters have been funded through LADCO. Data from the reports w ere heavily relied upon for this portion of the WOE
demonstration. This section of the WO E relied primarily on source apportionment analysis of the two monitors by STI (2006) and Clarkson University. These reports, in their entirety, are ava ilable at the LADCO web site --see references for the web

address. It should be noted that additional reports are also available from LADCO. Some of these reports contain additional analysis through 2006.

Based on the differences between the 2000-2004 weighted average contribution at Dearborn (19.3 ug/m 3 ) and Allen Park (15.8 ug/m 3 ), first conclusions suggest a maximum of 3.5 ug/m 3 of PM 2.5 impacting Dearborn are from local sources. This conclusion is supported by the STI (2006) report “Data Analysis and Source Apportionment of PM 2.5 in Selected Midwestern Cities,” November 2007, which states that, “...the Allen Park site does not seem to be influenced by sources in the Dearborn area...” (page 3-10).

It is possible that the 3.5 ug/m 3 value is an overestimation of local impacts because there are likely sources that impact both monitors. A comparison of the results from the following reports provides a more realis tic estimate of local contribution to the Dearborn site. The difference between the combined soil and mixed industry at Allen Park (2.23 ug/m 3 ) and Dearborn (4.55 ug/m 3 ) is 2.32 ug/m 3 in the Clarkson report (see Table 9.5.a). The differenc e between the combined soil and mixed industry at Allen Park (1.98 ug/m 3 ) and Dearborn (4.36 ug/m 3 ) is 2.38 ug/m 3 in the STI (2006) report (see Table 9.5.a).

38Table 9.5.a: Comparison of Clarks on and STI source apportionment results (in ug/m 3 ).

Clarkson Report STI Report

Allen

Park Dearborn Allen Park Dearborn (2001-

2003 ) (2002-2003) (2002-2004) (2002-2005)

Sulfate 5.10 8.00 4.51 4.49

Nitrate 3.40 3.98 4.16 4.26

Soil 0.98 2.23 0.63 0.88 Aged Sea and Road Salt 0.46 0.46 Spark-ignition Vehicl es 3.70 4.07 3.53 3.96

Diesel Vehicles 0.84 1.13 2.37 1.06 Biomass Burning 0.37 0.31

Mixed Industrial 1.25 2.32 1.35 3.48

Local Primary
Particulate

Soil + Industrial 2.23 4.55 1.98 4.36

Dearborn - Allen Park 2.32 2.38

The local contribut ion of primary PM 2.5 in the range of 2.30 ug/m 3 to the Dearborn monitor is further supported by additional analysis by LADCO, documented in a presentation titled, “Data A nalysis to Support Local Area M odeling,” (Kenski, 2007). In Figure 31 in Appendix A from the Kenski repor t, approximately 3.25 ug/m 3 is

associated with the Dearborn monito r while approximately 0.95 ug/m 3 is associated with Allen Park monitor. Subtracting the Allen Park concentration as area background would leave at t he Dearborn monitor 2.30 ug/m 3 as local contribution,
which is similar to the Clarkson and STI re sults. It is likely that this is an
underestimation since some of the sources contributing to Dearborn also contribute to a small degree to Allen Park.

For purposes of this WOE demonstrat ion, a concentration of 2.30 ug/m 3 of primary fine particulate will be considered as nearby local contribution to the Dearborn site (Table 12 in Appendix A).

2) Model base year local source emissions.

The EPA AERMOD Gaussian Dispersion model was used to predict impacts at the monitors of concern. Table 13 in Appendix A provides the signific ant sources used in the AERMOD model to predict impacts from neighborhood scale emissions (see Figure 3 in Appendix A). Mo st of the sources were tr eated as a single individual point source using a weighted, representative stack. D ue to the proximity of the Severstal facility, detailed refined modeli ng used all individual point and volume sources as defined during previous NSR permitting. Actual PM 2.5 2002 emissions from Severstal (totaling 553.4 tons/year) were identified by the MDEQ at each

39detailed emission point. Emissions used from the other sources were PM 10 emissions as provided by the facility 2002 Michigan Air Emissions Reporting System (MAERS). The total modeled impact at the Dearborn monitor is 4.61 ug/m 3

, with 2.96 ug/m 3 coming from Severstal. Emissions from these sources have not changed significantly in the last several years and are considered representative for 2005

3) Calculation of the amount of Severstal PM 2.5 impacting the Dearborn monitor.

To determine the Severstal impact on the Dearborn monitor, a Relative Reduction

Factor was derived based on the modeled v a lues from the loca l sources. The Severstal predicted impact (2.96 ug/m 3 ) was divided by the overall predicted impact from all local sources (4.61 ug/m 3 ) for a Relative Reduction Factor of 0.642. Applying this factor to the prev iously determined local primary PM 2.5 contribution to the Dearborn monitor of 2.30 ug/m 3 yields an annual average of 1.48 ug/m 3 contributed by Severstal to the Dearborn monitor.

4) Modeled impact of 2009 Severstal emissions on the Dearborn monitor.

The AERMOD model was run using the 2009 Severstal projected emissions. The emission total is reduced by 148 tons of PM 2.5 from the 2002 level because of the various controls that the company is insta lling. The inventory list is summarized in Table 2 of the Appendix A. The 2009 Se verstal impact was predicted by AERMOD to be 1.47 ug/m 3

.

5) Calculation of the Relative Reduction Factor.

The 2009 impact was predicted to be 1.47 ug/m 3 as compared to the 2002 base case impact of 2.96 ug/m 3 . This provides a Relative Reduction Factor of 0.497 (i.e., 1.47 / 2.96 = 0.497).

6) Calculation of the reduction in ug/m 3 at Dearborn in 2009 because of Severstal

controls.

The reduction in observed values at the Dearborn monitor in 2009 resulting from reductions at Severstal is calculated by mult iplying the relative reduction factor of 0.497 by the predicted Severs tal contribution of 1.48 ug/m 3 in 2002. Therefore the expected reduction by 2009 will be 0.73 ug/m 3 based only on Severstal reductions. Table 9.5.b summarizes these figures. It s hould be noted that this is a conservative prediction because other emissi on reductions in the area from U.S. Steel, Marathon, locomotive retrofits, and other sour ces have not been accounted for in this
calculation and will further contribute to reductions at the Dearborn monitor.

b. Modeled local control strategies.

The LADCO analysis (Figure 13 in Append ix A) provided evidence that iron accounts for approxim ately 1.4 ug/m 3 of primary particulate to the Dearborn monitor.

40Iron is associated primarily with steel pr oduction, and most can be attributed to Severstal. Table 13 in Append ix A indicates that U.S. Steel contributes only slightly to Dearborn compared to Severstal. As such, based on the annual emissions, prevailing winds, and close proximity, it can be reasonably assumed that Severstal contributes the majority of excess PM 2.5 which is not seen at other area monitors. As provided in the previous section, the assumption that Severstal contributes 1.48 ug/m 3 to the Dearborn monitor is likely an underestimation, as conservative assumptions are applied at each step of this analysis.

Table 2 in Appendix A lists 2002 emissions from the permit application inventory and 2009 projected emissions. It is believ ed that the 2002 emissions closely resembles 2005 emissions. As shown by the total emissions reductions, Severstal will reduce emissions by installing new particulate controls on two blast furnaces, the basic oxygen furnace and several other smaller operat ions in the facility. The sum of the reductions will be 148 tons per year. These reductions were not taken into account during the regional modeli ng performed with CAMx. Thus, double-counting should

not be an issue.

The AERMOD model was run using the 2009 Severstal projected emissions. The

new 2009 Impact was predicted to be 1.47 ug/m 3 as compared to the 2005 Base
Case impact of 2.96 ug/m 3 . This provides a Relative Reduction Factor ( RRF ) of 0.497 (i.e., 1.47 / 2.96 = 0.497). Applied to the monitored 2002 Contribution by Severstal (1.48 ug/m 3 ), the expected Severstal reduction by 2009 will be 0.73 ug/m 3

. Table 9.5.b summarizes these figures. This reduction in primar y particulate from Severstal, in conjunction with the regional 2009 predict ion of total PM 2.5 particulate (15.8 ug/m 3 ), indicates that Dearborn will be nearly in attainment by 2009 even before considering other reducti ons of neighborhood scale emissions.

Table 9.5.b: Severstal’s 2009 contri bution to the Dearborn monitor

2005 Base Case: Predicted AERMOD Severstal Contribution to Dearborn 2.96 ug/m3

AERMOD Total: AERMOD Neighborhood Scale Contribution to Dearborn 4.61 ug/m3

Relative Factor: Severstal Relative Factor (2005 Base Case / AERMOD Total) 0.642

Total: MONITORED Neighborhood Scale Contributi on to Dearborn Monitor 2.30 ug/m3

2002 Contribution: Severstal’s 2002 Contribution to the Dearborn Monitor (Total x Relative Factor) 1.48 ug/m3

2009 Impact: Predicted AERMOD Severstal Contribution to Dearborn 1.47 ug/m3

RRF : Relative Reduction Factor (2009 Impact / 2002 Base Case) 0.497

2009 Severstal Reduction to Dearborn Impact (RRF x 2002 Contribution) 0.73 ug/m3

41c. AERMOD dispersion model validation.

The hotspot dispersion modeling resu lts can be evaluat ed to address model performance. Similar to grid modeling, the dispersion model results should be compared to ambient data to ensur e the model is working well.

As discussed in the previous section, combined soil (including metals) and mixed industrial impacts at the Dearbor n m onitor were concluded to be 4.55 ug/m 3 per the Clarkson report and 4.36 ug/m 3 per the STI report. Table 13 in Appendix A provides overall combined impacts and individual contribution for each source near the
Dearborn monitor based on the AERMOD mode ling. The combined near source industrial emissions were predicted to yield an impact of 4.61 ug/m 3 at the Dearborn monitor. This close comparison to the Clarkson and STI values suggests that the emissions estimates and dispersion model are doing a reasonable job addressing the local component of primary PM 2.5 from nearby industrial sources.

The model further gives a combined im pact from these s ources of 0.65 ug/m 3 at the predominantly upwind Allen Park monitor. This minimal impact is expected because
of the location of the monitor in relation to the sources. This also follows the STI assumption that, “...the Allen Park site does not seem to be influenced by sources in the Dearborn area...” (page 3-10).

The AERMOD modeled impact at the SWHS monitor (2.59 ug/m 3 ) from the same

sources is less than the modeled impact at Dearborn (4.61 ug/m 3 ) for the same emission sources. This is expected because of the larger distance between the
sources and SWHS. The Dearborn minus SWHS modeled difference, 2.02 ug/m 3 (4.61 ug/m 3 - 2.59 ug/m 3 ) is similar to the monito red 2000-2004 weighted average difference of 2.0 ug/m 3 (19.3 ug/m 3 - 17.3 ug/m 3 ).

In all cases, some AERMOD overpredict ion is expected because all source emissions, except Severstal, assumed PM 10 emissions will be higher than PM 2.5 emissions. Table 12 in Appendix A provides a summa ry of the Dearborn minus the Allen Park industrial part iculate differences.

AERMOD modeling summary files for t he 2005 and 2009 analyses are attached as Appendix H.

9.5.3 Combined Modeling Results

The impacts of future year emission reduc tions, taking into account future year growth as well, is demonstrated by co mbining the regional scale photochem ical modeling with the local scale modeling. To avoid double counting of emission reductions, the modeled local source emi ssion reductions are not accounted for in the regional modeling in ventory. The futu re year predicted PM 2.5 levels as determined by the regional modeling is in cluded in Table 10 in Section 4 of the LADCO TSD (see also Table 1 in Appendix A). The values for the two monitors that

42are showing violations of the standard in Michigan, in micrograms per cubic meter,
are as follows:

Monitor 2009 (regional) 2009 (local) 2009 predicted

level

Dearborn 15.8 0.73 reduction from
Severstal 15.07

SWHS 14.2 Not calculated Less than 14.2 expected

The predicted PM 2.5 impact at the Dearborn monitor in 2009 resulting from primary

PM 2.5 emission reductions at Severstal is a reduction of 0.73 ug/m 3 . When this reduction is subtracted from 15.8 ug/m 3 as projected from t he regional modeling, the resulting calculated PM 2.5 level at the Dearborn monitor in 2009 is predicted to be 15.07 ug/m 3 . With the PM 2.5 standard at 15 ug/m 3 , this modeling demonstration provides additional support for attainm ent by 2010. While the modeled value is slightly over the standard, the AQD belie ves that the additional reductions from
locomotive retrofits and other local sources described in section 10 of this document

will ensure that the Dearbor n monitor and the entire nona ttainment area will come into attainment by 2010.

4310. Attainment Strategy

The attainment strategy approach for fine par ticulate should be m ultifaceted. There are four components to the a ttainment strategy for PM 2.5 :

1. Implementation of national controls; 2. Implementation of local controls; 3. Voluntary measures, and; 4. Areas of continued study.

This multifaceted strategy is based on lessons learned from our technical analyses
as reflected in the WOE demonstration. N o single program can be relied upon for

attainment and our limitations in predicting the future thr ough the use of air pollution models, travel models, and economic models, are recognized in this multifaceted attainment strategy.

Acknowledging that some activities that will contribute to air quality improvement and attainment do not necessarily lend themselv es to regulatory action and that controls in certain parts of the nonattainment area wil l contribute very little toward attainment, the strategy targets local controls in a portion of eastern Wayne County. This is

consistent with the location of violat ing monitors and with earlier successful strategies in attaining previ ous particulate matter standards.

10.1 Implementation of National Controls

a) Mobile Sources

Mobile sources are recognized as a significant contributor to PM 2.5 levels in both

attainment and nonattainment areas. T he focus on reducing emissions costeffectively in the eastern portion of Way ne County is somewhat incompatible with specialized vehicular emission reducti on programs. More importantly, the
contribution of mobile sources to PM 2.5 levels will be reduced throughout the region
and nation as a result of several new f ederal requirements. These requirements affect both vehicle design as well as fuel specifications. We estimate the following programs will reduce PM 2.5 mobile source emissions by over 51 percent between 2002 and the attainment year, 2010.

Tier 2 emission standards : We expect significant reductions in mobile source emissions from implementation of the Tier 2 progr am. The Tier 2 program requires manufacturers to produc e vehicles that emit much lower levels of pollution than earlier generat ions. Because this is a national program, these reductions from “on-board” controls will be occurring in Southeast Michigan as well as in upwind areas. Consequently, transport into the region will be reduced.

44Diesel Rule: Similarly, the EPA estimates its new Diesel Rule will result in a 97 percent reduction in emissions from heavy-duty diesel trucks. As with gasoline vehicles, these reductions will occur throughout the entire country.

Low sulfur gasoline and diesel fuel: Beginning in 2004, refineries began phasing in a new sulfur levels for gasol ine du e to new federal standards for fuel. This standard requires the average sulfur level to be no greater than 30 parts per million (ppm). This repr esents a 14-fold reduction in Southeast Michigan where average levels in 2002 were 430 ppm. Also beginning in 2006, a new requirement for ultra low sulfur diesel fuel (15 ppm) will begin phasing in. As with gasoline, this r epresents an enormous decrease from the 380 ppm average measured in 2002. 3 These sulfur reductions are a key contributor to the large-sca le vehicular emission reductions shown in Figure 2 of Appendix A.

Although these low sulfur fuel programs are f ederal requ irements, the Michigan Department of Ag riculture (MDA) is committed to testing for compliance with these standards. The MDA will update its ex isting programs and regulations to include a provision fo r the enforcement of these standards.

Implementation of this progr am and enforcement of th is program i s primarily the responsibility of the EPA. Usi ng a combination of its enforcement authority under the Clean Air Act and its program for certifying manufacturer compliance with vehicle emissions st andards, the EPA is a key partner in implementing this facet of the control strategy.

b) Stationary Sources

Clean Air Interstate Rule : In 2005, the EPA finalize d a rule to address longrange transport of PM 2.5 , commonly referred to as t he CAIR rule. This rule will result in major reductions of su lfates and nitrates, two of the most significant contributors to PM 2.5 at monitors showing violations of the standards and throughout the nonattainment area. The MDEQ has primary responsibility for ensuring that required emission reductions are implemented. The MDEQ is committed to ensuring t hese reductions occur as scheduled in

the national rule.

10.2 Implementation of Local Controls

a) Severstal steel production facility

Two enforceable programs have already been put in place to secure emission

reductions that are a key component of the PM 2.5 attainment strategy. One is a recently approved consent order between Se verstal and the MDEQ. The other is a

3 Alliance of Automobile Manufacturers. 2002 Nort h American summer and winter fuel surveys.

45recently approved permit that is subject to the consent order. These programs require emission reductions fr om the following sources:

• Basic Oxygen Furnace (BOF): Install baghouse.

• Blast furnace C: Install baghouse.

• Blast furnace B: Install baghouse or shutdown by June 2008.

• Torch cutting: No longer permitted on site.

• Scarfing operations: Reduce opacity.

• Torpedo cars: Reduce smoking.

The combined impact of these controls is expected to reduce annual primary PM 2.5 emissions by 147 tons/year, and will be especial ly critical in reducing the excess iron identified in our technical analysis (MDEQ PTI #182-05B--see Tables 2 and 3 in Appendix A and Appendix F, and Appendix J).

Furthermore, a Supplemental Environmental Pr oject requires Severstal to take the following additional ac tions:

• School bus retrofits: The Comp any will spend $100,000 to retrofit approximately 100 school buses in the local area with diesel oxidation catalysts and/or engine crankcase filter s. These devices will reduce the exposure of children to diesel part iculate emissions as well as reduce

overall PM 2.5 emissions in the area.

• Company-owned diesel equipment re trofits: The Company will spend $100,000 to retrofit some of it s own on-site diesel equipment.

• Planting of trees in the area: The Company will spend $200,000 on tree planting in the area, providing bot h air quality and aesthetic benefits.

b) U.S. Steel

An enforceable consent order and permi t between the company and the MDEQ

resulted in reductions at the B blast fu rnace. The existin g baghouse was replaced resulting in an annual primar y PM emissions reduction of 76 tons (Consent Order #1-2005, ROP #199600123a--see T able 3 in Appendix A).

c) Marathon

An enforceable consent order and permi t at Marathon also resulted in PM 2.5 emission reductions. These reductions resu lted from the following specific actions that are currently being implemented:

• Fluid Catalytic Cracking Unit (FCCU): Company is adding an electrostatic precipitator (ESP) and catalyst additives.

• CO Boiler: Has been shut down.

• Crude/Vac Heater: NOx Controls.

• BT Inter Heater and BT Charge Heater: NOx reductions.

46The combined impact of these controls reduced annual primary PM emissions by 94 tons/year.

Marathon has also applied for a permit to install a coking unit to process heav y crude oil. The proposed permit is current ly in the public comment phase of the permitting process; however, if the permit is successfully completed, the company will marginally reduce PM and its precursors. In addi tion, pending permit approval, Marathon is planning several other air quality actions (MDEQ PTI #388-07--see Table 3 in Appendix A).

• Voluntary retrofit of school bus es in the City of Detroit fleet.

• Voluntary enhanced street sweeping on public roads in the vicinity of the plant.

• Voluntary installation of air monito ring stations in and around the facility.

• Voluntary installation of particulate controls on the tr uck fleet that will transport petroleum coke.

• Voluntary purchase of PM 10 offsets from closed plants to retire.

d) Reductions from plant clos ures and changes in operations

As discussed in the WOE, PM 2.5 levels are improving. T he rate of improvement is greater at the industrial monitoring sites (Dearborn, SWHS, and Wyandotte). While local regulatory measures were not respons ible for this improvement, many of these reductions are permanent and the impac t on attainment and maintenance is significant.

e) Diesel Switch Engine Locomotive Retrofits

In the course of identifying possible s ources for emission reductions, we also considered factors beyond the quantity of emissions. Thes e include the nature of the emissions and proximity to the Dear born and SWHS monitors and surrounding communities. Approximately 40 switch engi nes operate in these areas on a fairly

continuous basis with little or no emission control. Over t he next two years, 28 of the switch engines in this area will be retrof itted with anti-idling equipment. Based on data from a similar project in Chicago (USEP A 2004), this initiative is expected to reduce NOx emissions by 67 tons/year and PM by 2 tons per year. In addition, four to six switch engine locomotives at the C SX rail yard immediately adjacent to the Dearborn monitoring site will be rebuilt with smaller engines over the next two years, resulting in an annual emissions reduction of at least 66 tons of NOx and 1.8 tons of diesel PM. This brings the total annual r eduction from these retrofits to 132 tons of
NOx and 3.8 tons of diesel PM.

4710.3 Voluntary measures

a) High emitting vehicle detection

Despite the massive reducti ons in vehicular emissions as a result of on-board controls and cleaner fuels, a small portion of the vehicle population contributes disproportionately to the total amount of th ese emissions. Because of the cost, effectiveness, and time to implement a mandatory vehicle-test ing program, this measure is not being pursued. Furthermore, a large number of vehicles that operate in the region are not registered in the area and are merel y passing through. Thus, they would not be subject to the test.

Nonetheless, advances in technology make it feasible to sample vehicle emissions in-situ using a remote sensing device. SEMCOG recently completed a project to identify the number and characteristics of hi gh emitters i n the region. The project showed that Southeast Michigan has fewer high emitters than ot her parts of the country due to its newer fleet. However, t he study also showed that 10 percent of the fleet contributes 70 percent of the emissions. Thus, reducing the number of high emitters has significant emission reduction potential. The project included contacting owners of high emitting vehi cles and encouraging them to voluntarily seek repairs. Roughly 40 percent of those contacted did seek repairs, which shows great promise for a broader vo luntary program. The vast majority of those who did not seek repairs said they could not a fford them. SEMCOG is pursuing follow-up activities to make the public aware of t he high emitter issue with a goal of reducing the number of high-polluting vehicles on the road.

b) Fugitive Dust Reduction

In the course of MDEQ’s technical analysis, a large number of storage piles, unpaved lots, and plots of barren land were obs erved within a three-mile radius of both the Dearborn and SWHS monitors (see Figure 9 in Appendix A). The vast majority of emissions from these “fugiti ve” sources are thought to be larger than

PM 2.5 . Nonetheless, the sheer number of them, and their possible aggregate impact, deserves attention. While many of these sources are already the subject of a regulatory program as the re sult of a previous SIP, voluntary programs, targeted at smaller establishments in the area, ma y produce additional benefits and should be explored.

To that end, SEMCOG has teamed with S outhwest Detroit Environmental Vision and a graduate class at the University of Michi gan (U of M) to dev elop a blueprint for greening pr operties in this area. Duri ng the 2007-2008 academic year, the U of M students will be researching different plant species that could have the greatest potential for reducing dust in the area, t he locations where planting could be most advantageous, and ways that such landscaping could be marketed to businesses in the community as well as other potential funding organizations.

48While the precise impact of this initiative on fine particulate concentrations in the area is unknown, implementation of such a greening program will certainly improve the overall environment for the people who live and work in the area.

10.4 Tracking Progress and Continuing Evaluation

Another part of the mult ifaceted approach to the PM 2.5 strategy involves tracking progress toward attainment and continued evaluation of other possible contributors that should be the subject of control. Th is differs from the traditional approach to SIP development but is consistent with the weight of evidence on which this strategy is based. Specifically, instead of presuming that attainment will occur exactly as planned, this section includes a course of action, tracking progress, and identifying

other contributors that should be subject to control. Each of these elements is

discussed below.

a. PM 2.5 Monitoring Network Enhancement – In order to improve our understanding of the PM 2.5 nonattainment problem in Southeast Michigan, particularly with regard to individual species, enhancements to the current monitoring network are needed. Appendix E is a draft strategy for improving the monitoring network in this regi on, provided the MDEQ can obtain additional funding. These enhancements will not only improve our understanding of current PM 2.5 concentrations, they will also allow us to better track progress towards attainment.

b. Organic Carbon Anal ysis – While the controls listed in sections 10.1 to 10.3 above will have a sign ificant impact on PM 2.5 in Southeast Michigan, more needs to be done to understand and address the excess OC component. Much time and effort has been spent anal yzing available OC data. However, the lack of speciated data at many monitoring locations and the relatively short history of monitoring data make it difficult to identify the source(s) of

these emissions. Additional studi es will be pursued to increase our understanding of this component and its c ontribution to Southeast Michigan’s fine particulate problem.

4911. RACT and RACM

Rule 40 CFR Part 51.1010 requires the MD EQ to submit with the attainment
demonstration a SIP revision demonstrati ng that it has adopted all RACM (including RACT for stationary sources) necessary to demonstrate attainment as expeditious ly as practicable. RACM is the applicati on of reasonable controls on sources in a nonattainment area to expedite the attainment of the area. RACT is a subset of RACM; the application of such controls spec ifically on stationary sources. For areas that are projected to attain by 2010, RACT and RACM are not needed because they will not result in more expeditious attainment.

The MDEQ’s PM 2.5 SIP has been developed to dem onstrate through a weight of evidence approach that the nonattainment area will attain the standard by 2010 through a combination of multistate regi onal controls and reductions at several sources in close proximity to the areas with the highest PM 2.5 annual levels.
Additional area-wide controls more reflecti ve of RACT and RACM are not believed to be appropriate for addressing the PM 2.5 problems at the viol ating monitors in Southeast Michigan.

However, before making the decision not to pursue RACT controls, the MDEQ did perform a modeling screening ev aluation of the impacts that large emission reductions would have on the violating monito rs, as described in Section 11.1 below.

The results of the m odeling, of 0.49 ug/m 3 for statewide reductions and 1.01 ug/m 3
for 7 county reductions at t he Dearborn monitor are not in significant. However, a very large emission reduction in the multicounty area and statewide, clearly a draconian control program, w ould be required to achieve such reductions. Thus, a RACT and RACM program, being “reasonably available” by def inition, would be expected to provide much smaller emission reductions and therefore much smaller improvements in PM 2.5 levels at the violating monitors.

The MDEQ took one further step in evaluati ng RACT by evaluating the sources likely impacted by such a program. Parts 11.2 through 11.4 below contain details on the point sources of SO 2 , NOx, and primary PM 2.5 in the 7-county area along with information necessary in the event that RACT control programs for these sources were instituted in the area. This analysi s further demonstrates that a RACT program addressing stationary sources would result in much smaller emissions reductions

than were modeled in the screeni ng modeling. The conclusion from this is that such control programs would have little impact on reducing PM 2.5 levels at the violating

monitors.

11.1 RACT-RACM modeling

To determine the impacts of additional NOx and SO 2 reductions on PM 2.5 monitors, two sensitivity tests were performed with the CAMx model.

50The first test reduced ALL state wide anthropogenic sources of NO, NO 2 , and SO 2 emissions by 50 percent. Utility software provided by LADCO allowed the combined emission inventory (all point sources pl us all area sources) to be reduced by 50 percent across the entire st ate of Michigan. The CAMx model was run using the modified emissions files containing the statewide reduced em issions and compared results to the unaltered 2005 base case (Base M emissions inventory). The relative
results were used to determine what effect such a draconian cut in emissions would make to sensitive monitors through the State of Michigan. In this test, the Relative Reduction Factor (RRF) was 0.973 at the Dearborn monitor, which yielded an approximate annual reduction of 0.49 ug/m 3 using 2005 monitored values (Table 11.1.a).

The second test involved eliminating A LL (i.e., 100 %) of the anthropogenic NO,
NO 2 , and SO 2 emissions in the 7-county nonattain ment area of Southeast Michigan. The CAMx model was again run using the al tered emissions files containing the modified 7-county emissions and compared results to the unaltered 2005 base case (Base M emissions inventory). The relati ve results were used to determine what
effect such additional draconian cuts in em issions would make to sensitive monitors through the State of Michigan. In this test, the RRF was 0.945 at the Dearborn monitor which yielded an approximate annual reduction of 1.01 ug/m 3 using 2005 monitored values (Table 11.1.b).

While the Dearborn monitor reductions of 0.49 ug/m 3 (e.g., 50 percent statewide cuts) and 1.01 ug/m 3 (100 percent 7-county cuts) are signi ficant, it is clear that this level of reduction compared to the massi ve emissions cuts assumed in these analyses could not be justified and are not lik ely attainable. Such a costly control program would be very difficult to implement in an area like Detroit that has been in an economic recession for years.

51Table 11.1.a: Statewide RACT-RACM run results. 

## MICHIGAN RACT-RACM ANALYSIS
(ASSUMES 50% NOx/SO 2 CUTS STATEWIDE - ALL SOURCES)

2005 2005

Monitored RRF w/MI
RACM Net
Reduction
MICHIGAN

MONITOR S ug/m3 ug/m3 ug/m3 Lansing 13.54 0.944 12.78 0.76
Jenison 13.99 0.950 13.29 0.70 Grand Rapids 13.72 0.950 13.03 0.69
Holland 12.39 0.945 11.71 0.68
Port Huron 15.09 0.964 14.55 0.54 Bay City 12.44 0.957 11.91 0.53

New Haven 14.37 0.964 13.86 0.51 Saginaw 11.72 0.957 11.22 0.50 Muskegon 13.07 0.962 12.57 0.50

Dearborn 18.55 0.973 18.06 0.49
Kalamazoo 13.83 0.965 13.34 0.49

Flint 12.89 0.963 12.41 0.48
West Fort 17.21 0.973 16.75 0.46 Ypsilanti 15.61 0.971 15.16 0.45

Luna Pier 15.70 0.972 15.26 0.44 Wyandotte 16.41 0.973 15.97 0.44
Livonia 14.94 0.971 14.51 0.43
Linwood 16.01 0.973 15.58 0.43
Coloma 13.05 0.967 12.63 0.42
East 7 Mile 16.48 0.974 16.06 0.42
Allen Park 15.94 0.973 15.52 0.42
Oak Park 15.46 0.974 15.06 0.40
Ann Arbor 13.20 0.971 12.82 0.38
Sault Ste Marie 8.16 0.971 7.92 0.24

STATEWIDE AVERAGE 0.49

52Table 11.1.b: 7-county nonattainment area RACT-RACM run results


## MICHIGAN RACT-RACM ANALYSIS
(ASSUMES 100% NOx/SO 2 CUTS IN 7-COUNTY SE MICHIGAN - ALL SOURCES)

Monitored

2005 Base RRF 2005 RACM Net Reduction ug/m3 ug/m3 ug/m3

Dearborn 18.55 0.945 17.54 1.01
West Fort 17.21 0.945 16.27 0.94 Wyandotte 16.41 0.945 15.51 0.90
Linwood 16.01 0.945 15.14 0.87
Port Huron 15.09 0.942 14.22 0.87
Allen Park 15.94 0.945 15.07 0.87
New Haven 14.37 0.942 13.54 0.83 Ypsilanti 15.61 0.950 14.82 0.79
Livonia 14.94 0.950 14.19 0.75
Ann Arbor 13.20 0.950 12.54 0.66
East 7 Mile 16.48 0.960 15.82 0.66
Luna Pier 15.70 0.958 15.05 0.65
Oak Park 15.46 0.960 14.84 0.62 Lansing 13.54 0.959 12.98 0.56

Flint 12.89 0.973 12.54 0.35 Bay City 12.44 0.972 12.09 0.35
Kalamazoo 13.83 0.976 13.50 0.33 Saginaw 11.72 0.972 11.39 0.33
Jenison 13.99 0.978 13.68 0.31 Grand Rapids 13.72 0.978 13.42 0.30
Holland 12.39 0.979 12.13 0.26
Coloma 13.05 0.982 12.81 0.24 Muskegon 13.07 0.982 12.84 0.23
Sault Ste Marie 8.16 0.982 8.01 0.15

STATEWIDE AVERAGE 0.58

11.2 NOx RACT-RACM Analysis

The MDEQ’s NOx RACT analysis began by looking at the 2005 MAERS inventory for all reporting NOx stationar y sources in the 7-county PM 2.5 nonattainment area.
The total NOx emissions for these sources are greater than 81,000 tons/year. A cutoff of 50 uncontrolled tons of NOx per year per source was used to isolate those sources that are most likely to be lar ge enough to be impacted by a RACT control program. This grouping of lar ger sources represents the va st majority of stationary source NOx emissions, at approximately 79,000 tons/year.

53This grouping of larger sources was then broken down by major source type, based on operations at each of t he stationary sources. A breakdown of the source categories by size is as follows. As expected, the highest emitters are EGUs. The next highest sources group are industrial/ comme rcial/ institutional (ICI) boilers. The third highest grouping is k ilns operated in the area at two sources. The fourth highest is reciprocating internal co mbustion (RIC) engines, compressors and turbines used in the natural gas industry. Next are the blast furnace emissions at the steel-manufacturing operations in the area. Coming in next is the glassmanufacturing operations. Flares at local landfills and fuel test cells used by the major automotive manufacturers had minima l impacts as well as any remaining

miscellaneous sources without any stationary source-specific coherency to be used
for RACT controls. See Table 11.2.a.

It should be noted that source reporting to Michigan’s emission inventory contained several groupings of units reported as “one” unit; therefore it is hard to determine the exact number of units at each stationary s ource. For example, a stationary source listed under ICI may have 6 boilers with aggr egated emissions greater than 50 tons.
NOx controls are on individual units and may not garner the predicted emission

reductions as listed in Table 11.2.b.

EGUs The EGUs are currently regulated under the CAIR and reductions will occur in conjunction with a regional trading program.

ICI Boilers
A review of Council of Industrial Boiler Owner s (CIBO) comments and presentations during Ohio’s NOx RACT Rule’s public comment period, LADCO’s ICI Boiler workgroup presentations and a review of information submitted by the Energy and Environmental Analysis, In c. to the Oak Ridge National Laboratory in May 2005, represented the most common ideas for RACT controls that would typically be used
for ICI boilers. The most common for ICI boilers would be low NOx burner combustion controls (LNB) and selective ca talytic reduction (SCR) or selective noncatalytic reduction (SNCR) post combustion controls.

Out of 30 potential ICI stationary sources within Southeast Mich igan that could have NOx controls installed, le ss than 4 percent are currently controlled for NOx. The anticipated level of emission reduc tion Mich igan could achieve in the nonattainment
area from affected sources is outlined in Ta ble 11.2.b. Table 11.2.c. provides an
assessment of NOx emissions sources t hat emit more than 50 tons per year.

Regarding the ICI boilers, a workgroup cons isting of the states in LADCO and the Ozone Transport Commission and their respective regions is composing a request asking the EPA to create a national rule to reduce emis sions from boilers greater
than 50 mmBtu/hour heat input rates. If a national rule is implemented it would create consistency among the states as op posed to a patchwork of statewide or nonattainment area-specific control programs.

54Kilns There are two stationary s ources with large kilns operati ng in the area. There is some potential for post-combusti on controls on these units as shown in

Table 11.2.b.

RIC Engines Large RIC engines are subject to a Michigan rule (Rule 818) that addresses NOx reduction requirement s for these units. There are potential additional reductions available in this category by lowering the th reshold level for affected facilities within

our rules. This could result in additiona l NOx reductions as listed in Table 11.2.b.

Furnaces at Steel Mills Blast and arc furnaces in operation at t he steel mills in the area could provide
additional controls. Some controls ar e currently being planned for two of the stationary sources in the area. Additional post-combustion controls would be hard to configure but not impossible. The cost per ton could be hi gher than what is

indicated in Table 11.2.b.

Glass Mfg. There is one stationary source in the area that manufactures flat gl ass. This process

is combustion and heat intensive. Additi onal post-combustion controls would be hard to configure but not impossible. The cost per ton could be higher than what is

indicated in Table 11.2.b.

Flares at Landfills Flares at landfills are potential sources of emi ssion reductions. They are used to vent the build-up of methane gases within the landfill. It could be dangerous, due to explosion hazards, to add on post-com bustion controls. The EPA created the Landfill Methane Outreach Progr am (LMOP) in 1994 to reduce methane emissions from landfills. Twenty-seven landfills in Michigan currently utilize the methane gas generated to produce electricity. The EPA has a landfill gas energy cost model that
can be used to evaluate the economic feasib ility of a landfill gas energy project. However, specific reductions are not well known or published at this time.

Fuel Test Cells Fuel test cells are used by auto manufactu rers to test the aut omotive engines using gasoline and diesel fuel, as appropriate. The largest emitting sources in this area
control their VOC emissions with thermal oxidizers that are creating high NOx emissions. Controlling the VOC control equipment could be the only option for NOx control. This would entail adding post-combustion controls to a thermal oxidizer and may not be technically feasible. Due to the high temperatures of the exhaust gases from the oxidizer, sources would need to “c ool-down” the gas stream prior to entry into post combustion controls such as S CR or SNCR. If the temperature of the exhaust gas entering the post-combustion cont rols is too high, it could result in corrosion of the equipment or f ouling of the catalyst. Th e additional cost for piping and other equipment to cool the exhaust gas stream is undetermined at this time,

55but warrants future review as more data bec omes available. Additionally, not all the fuel test cells currently have VOC contro ls and requiring additio nal NOx control may result in less VOC controls being used.

Table 11.2.a. NOx Tons and Percentages by Emission Source

Sources NOx Emissions in Tons* Percentage of Total

Tons
EGUs 61,811 78
ICI Boilers 7,942 10

Kilns 3,028 4 RIC Engines 2,429 3
Furnaces at Steel Mills 1,970 2.4 Glass Mfg. 1,515 1.9

Flares at Landfills 500 0.6
Fuel Test Cells 117 0.1

Totals 79,312 100%

* Values have been rounded.

Table 11.2.b. Percent Reduction and Dollar per Ton of NOX Reductions

Tons of NOx Reduced Cost Per

Ton* Percent

Remo ved Control Type Landfill

Flares Fuel Test
Cells ICI Kilns RIC Furnaces Glass Mfg. $700.00 40% LNB NA NA 3,177 NA NA NA NA $1,200.00 80% SCR NA NA 6,354 2,422 1,943 1,576 1,212 $1,500.00 50% SNCR NA NA 3,971 1,514 1,214 985 757

* Cost per ton values were based on EPA estimates as presented by Black & Veatch on

December 2 005

Note: The ICI boilers were the only units considered for combustion controls. ICI, RIC, kilns, furn aces at steel mills and glass manufacturing operations were considered for post-combustion controls. The remaining sources are not easily controlled.

56Table 11.2.c. NOx Emission Sources in Southeast Michigan* County SRN Name Tons Engine Testing

WAYNE N6327 FEDERAL- MOGUL POWERTRAIN, INC. 63.78

WAYNE B6230 FORD MOTOR CO RESEARCH &DEV CTR 53.92 Glass Mfg.

MONROE B1877 GUARDIAN INDUSTRIES 1,515.67 Recip Internal Combustion

LIVINGSTON N5572 HOWELL COMPRESSOR STATION 716.98

SAINT CLAIR B6478 BELLE RIVER COMPRESSOR STATION 567.82

SAINT CLAIR B6481 MID MICHIGAN GAS STORAGE CO - CAPAC 320.98

SAINT CLAIR B6637 ST. CLAIR COMPRESSOR STATION 189.95

WASHTENAW N3920 FREEDOM COMPRESSOR STATION 189.10

LIVINGSTON N5590 HARTLAND PRODUCTION FACILITY 155.61

MACOMB B6636 RAY COMPRESSOR STATION 75.04

MACOMB N3391 ROMEO GAS PROCESSING PL ANT 58.54

SAINT CLAIR B6480 COLUMBUS COMPRESSOR STATION 52.75

WAYNE B2158 BUCKEYE TERMINALS, LLC - WOODHAVEN 52.50

MACOMB B8337 MUTTONVILLE COMPRESSOR STATION 50.59

Industrial/Commercial/Institutional Boilers

WAYNE A7809 U S STEEL GREAT LAKES WORKS 3,041.27

WAYNE M4148 GREATER DETROI T RESOURCE RECOVERY 786.74

WAYNE A9831 MARATHON PETROLEUM COMPANY LLC 463.13

WAYNE N6631 DEARBORN INDUSTRIAL GENERATION 379.89

WAYNE M4199 GENERAL MOTORS HAMTRAMCK 367.16

SAINT CLAIR B6420 E.B. EDDY PAPER INC. 364.45

WASHTENAW M0675 UNIVERSITY OF MICHIGAN 284.96

SAINT CLAIR A6240 CARGILL SALT INC. 232.17

OAKLAND N1436 CHRYSLER TE CHNOL OGY CENTER 206.21

OAKLAND B7227 GENERAL MOTORS - ORION ASSEMBLY 168.77

WAYNE B2814 DETROIT THERMAL BEACON HEATING PL ANT 164.39

LIVINGSTON N5590 HARTLAND PRODUCTION FACILITY 155.61

MACOMB B4049 GM TECHNICAL CENTER 149.62

WAYNE M4734 FORD MOTOR CO AUTOTRANS NEW PROD 139.26

WAYNE B2185 DETROIT PUBLIC LIGHTING DEPARTMENT 119.97

WAYNE A8650 FORD MOTOR CO/ WAYNE COMPLEX 107.19

OAKLAND B2329 PARKEDALE PHARMACEUTICALS, INC. 97.53

WAYNE M4764 FORD MOTOR CO ELM STREET BOILERHOUSE 84.39

OAKLAND B4031 GENERAL MOTORS - PONTIAC ASSY CENT ER 80.85

WAYNE M4782 EQ-BELLEVILLE 77.51

WAYNE B2173 TAMINCO HIGHER AMINES, INC. 71.71

MACOMB A3567 FORD MOTOR COMPANY - STERLING PLANT 71.15

WASHTENAW B2052 GM POWERTRAIN GROUP WILLOW RUN PLANT 63.28

WAYNE A8638 DETROIT DIESEL CORPORATION 55.51

WAYNE B6230 FORD MOTOR CO RESEARCH &DEV CTR 54.13

WAYNE B2158 BUCKEYE TERMINALS, LLC - WOODHAVEN 52.50

OAKLAND G5067 WILLIAM BEAUMONT HOSPITAL 52.47

MACOMB B2767 DAIMLERCHRYSLER AG, WARREN TRUCK 50.71

57Blast and Other Furnace Operations at Steel

Mills

WAYNE A7809 U S STEEL GREAT LAKES WORKS 1,603.10

WAYNE A8640 SEVERSTAL NORTH AMERICA, INC. 248.63

MONROE B7061 MACSTEEL MONROE INC 118.52

Kilns

MONROE B1743 HOLCIM (US) INC. 2,582.05

WAYNE B2169 CARMEUSE LIME/ RIVER ROUGE 446.535

Flares at Landfills

WAYNE N5986 CARLETON FARMS LANDFILL 170.10

MACOMB N5984 PINE TREE ACRES, INC. 139.89

WASHTENAW N2688 VEOLIA ARBOR HILLS LANDFILL 112.65

WAYNE M4469 RIVERVIEW LAND PERSERVE 77.69

* Combined emissions from stationary sources greater than 50 tons per year.

11.3 SO 2 RACT-RACM Analysis

The MDEQ’s SO 2 RACT analysis began by looki ng at the 2005 MAERS inventory for all reporting SO 2 stationary sources in the 7-county PM 2.5 nonattainment area.
The total SO 2 emissions for these sources are greater than 245,000 tons/year. A cut-off of greater than 50 tons of SO 2 per year per source was used to isolate those sources that are most likely to be large enough to be impacted by a RACT control program. This groupi ng of larger sources repres ents the vast majority of stationary source SO 2 emissions, at approximately 244,000 tons/year.

This grouping of larger sources was t hen broken down by major source type, based on operations at each of the stationary sources. A breakdown of the source categories by size is as follows . The highest emitters are EGUs, with the next highes t sources group being ICI boilers . The third highest source group was flares used to burn off gases at steel mill operations. The fourth highest was glass manufacturing operat ions. Building heater s were next, with casting operations at steel mills following closely. The remaining were miscellaneous
sources. See Table 11.3.a.

It should be noted that source reporting to Michigan’s emission inventory

contained s everal groupings of units reported as “one” unit; therefore it is hard to
determine the exact number of units at each stationary source. For example, a stationary source listed under ICI may hav e 6 boilers with aggregated emissions greater than 50 tons. SO 2 controls are on individual units and may not garner the predicted emission reductions as listed in Table 11.3.b.

58EGUs The EGUs are currently regulated under the CAIR and reductions will occur in conjunction with a regional trading program.

ICI Boilers A review of LADCO’s ICI Boiler workgroup presentations and a review of information submitted by the Energy and En v ironmental Analysis, Inc. to the Oak Ridge National Laboratory in May 2005 represented the most common ideas for RACT controls that would typically be us ed for ICI boilers. The most common for ICI boilers would be dry or wet scrubber s with a slight potential for in-duct injection.

Out of potential ICI sources within S outheas t Michigan that could have SO 2 controls installed, none ar e currently controlled for SO 2 . The anticipated level of emission reductions Michigan could obt ain in the nonattainment area from
affected sources are outlined in Table 11.3.b. Table 11.3.c. provides an
assessment of SO 2 emissions sources that emit more than 50 tons per year in the Southeast Michigan’s nonattainment area.

Regarding the ICI boilers, a workgroup c ons isting of the states in LADCO and Ozone Transport Commission and their respective regions are composing a request that the EPA create a national rule to achieve reductions for boilers greater than 50 mmBtu/hour heat input rates.

Kilns There is one large stationary source with large kilns operating in the area. There is little potential for additional pos t-combustion SO 2 controls at this source. The current scrubber in operation at the site has an estimated 30-50 percent efficiency for SO 2 removal. Testing is currently being done at this site to
determine a more accurate estimate. On ce a determination is made, the MDEQ can then determine whether to require SO 2 controls at other smaller kilns in Southeast Michigan.

Glass Mfg. The flat glass manufacturing operations could vent the SO 2 emissions to hoods

and install the controls as listed in Table 11.3.b

Furnaces and Casting at Steel Mills Furnaces and casting operati ons at the local steel mills could vent the SO 2 emissions to hoods and install the cont rols as listed in Table 11.3.b.

59Table 11.3.a. SO 2 Tons and Percentages by Emission Source

Sources SO 2 Emissions in Tons* Percentage of Total

Tons
EGUs 228,747 94

Kilns 7,381 3
ICI Boilers 4,336 1.6 Furnaces & Casting 3,144 1.2 Glass Mfg. 499 0.2

Totals 244,107 100

* Values are rounded

Table 11.3.b. Potential SO 2 Tons Removed
Tons of SO 2 Reduced Cost Per

Ton* Percent

Remo ved Control Type Kilns Glass Mfg. Furnaces & Casting ICI

$965.00 90% Dry
Scrubber NA 449 2,854 3,902

$750.00 95% Wet
Scrubber NA 474 3,013 4,119

* Cost per ton values were based on EPA estimates as presented by

Black & Veatch on December 2005

Table 11.3.c. SO 2 Emission Sources in Southeast Michigan*

County SRN Facility Name SCC SO 2 in

tons Glass Mfg.

MONROE B1877 GUARDIAN INDUSTRIES 30501403 499.38

Kilns
MONROE B1743 HOLCIM (US) INC. 30500706 7,227.00

WAYNE B2169 CARMEUSE LIME/ RIVER ROUGE 30501618 154.92 Furnace & Casting Operations

WAYNE A7809 U S STEEL GREAT LAKES WORKS 30390024 3144.180
ICI Boilers

ST. CLAIR B6420 E.B. EDDY PAPER INC. 10200202 1355.620

WAYNE A7809 U S STEEL GREAT LAKES WORKS 10200707 1094.877

WAYNE A6240 CARGILL SALT INC. 10100204 598.038

WAYNE N6631 DEARBORN INDUSTRIAL GENERATION 10200704 511.23

WAYNE M4199 GENERAL MOTORS HAMTRAMCK 10200204 333.010

WAYNE A8640 SEVERSTAL NORTH AMERICA, INC. 10200704 324.817

WAYNE B7227 GENERAL MOTORS - ORION ASSEMBLY 10200204 118.514 * Combined emissions from stationary sources greater than 50 tons per year.

11.4 PM 2.5 RACT-RACM Analysis

The MDEQ’s primary PM 2.5 RACT analysis began by looking at the 2005 MAERS inventory for all reporting primary PM 2.5 stationary sources in the 7-county PM 2.5

60nonattainment area. The total primary PM 2.5 emissions for these sources are greater than 2,250 tons/year. A cut-off of greater t han 15 tons of primary PM 2.5 per year per source was used to isolate t hose sources that are most likely to be large enough to be impacted by a RACT cont rol program. This grouping of larger sources represents the vast majority of stationary source primary PM 2.5 emissions, at approximately 1,870 tons/year.

This grouping of larger sources was t hen broken down by major source type, based on operations at each of the stationary sources. A breakdown of the source categories by size is as follows . The highest emitters are EGUs with the next highes t group being metal production. The third highest was mineral production, and the fourth highest was ICI boilers (see Table 11.4.a).

Table 11.4.b shows the individual emissi on units greater than 15 tons and their

current controls.

EGUs The EGUs are currently regulated under Michigan’s Rule R.336.1331 (Rule 331) and currently have an ESP or bag house for PM 2.5 control. Also, several EGUs will be replacing ESPs with baghouses to comply with the MDEQ’s proposed mercury rules.

Metal Production All of the larger sources are or will be controlled for PM 2.5 using capture hoods, baghouses and ESPs. The RTI (2006) report indicated several other sources of

PM 2.5 emissions, but most of these are minor sources (less than 15 tons/year emissions). (See Table 11.4.b for the individual emission units and their controls.)

Mineral Production For the mineral production facilities, nearly 20 tons are controlled by a bagho use; however, the remaining 300 tons are uncontro lled. These operations could vent the emissions to hoods and possibly inst all a baghouse or ESP. However, based on information in AirControlNET (ver. 4.1), no PM 2.5 controls are suggested for glass furnaces.

ICI Boilers For the ICI boilers, 55 tons of the 89 tons are controll ed. The emissions unit at U.S. Steel is actually a reporting group of 5 boilers. Each indiv idual boiler emits less than 15 tons; therefore controlling these sources would not create enough
reductions to be beneficial and would cr eate undue costs to the facilities.

Based on the small amount of potent ial reductions from primary PM 2.5 within the nonattainment area due to the large num ber of sources that are already controlled, additional controls are not likely to be considered RACT in the PM 2.5 nonattainment area.

61Table 11.4.a. PM 2.5 Tons and Percentages by Emission Source

Sources PM 2.5 Emissions in

Tons Percentage of

Tons
EGUs 841.66 44.9%

Metal Production 627.79 33.5%

Mineral Production 320.46 17.1%
ICI Boilers 84.17 4.5%

Totals 1874.08 100.0%

62Table 11.4.b. Potential PM2.5Controls and Reductions AchievedSRNSourcesSCCEmission Process DescriptionPM2.5inTonsControlsMineral ProductionB1877GUARDIAN INDUSTRIES30501403FLAT GLASS: RAW MATERIAL FORGLASS MELTING FURNACE161.208B1877GUARDIAN INDUSTRIES30501403FLAT GLASS: RAW MATERIAL FORMELTING FURNACE138.419B1743HOLCIM (US) INC.30500706CEMENT KILNS19.717BaghousePrimary Metal ProductionA7809U S STEEL GREAT LAKES WORKS30300913BOF - VESSELS - OXYGEN BLOWING133.971ESPA8640SEVERSTAL NORTH AMERICA, INC.30300917TAPPING: BOF128.979BaghouseA7809U S STEEL GREAT LAKES WORKS30390024BLAST FURNACE GAS TO FLARES43.401FlaresA8640SEVERSTAL NORTH AMERICA, INC.30300916CHARGING:BOF40.700BaghouseA7809U S STEEL GREAT LAKES WORKS30390004BLAST FURNACE GAS TO BLASTFURNACE D STOVES40.520BaghouseA7809U S STEEL GREAT LAKES WORKS30390004BLAST FURNACE GAS TO BLASTFURNACE B STOVES34.711BaghouseA7809U S STEEL GREAT LAKES WORKS30300304COKE QUENCHING34.364Baghouse andquench towerA7809U S STEEL GREAT LAKES WORKS30300917BOF - VESSELS - TAPPING28.164BaghouseA8640SEVERSTAL NORTH AMERICA, INC.30300825"C" BLAST FURNACECASTHOUSE27.115BaghouseA8640SEVERSTAL NORTH AMERICA, INC.30300825"B"BLAST FURNACE CASTHOUSE16.716Baghouse in2008ICI BoilersA6240CARGILL SALT INC.10100204SPREAD STOKER COAL FIREDBOILER55.470Baghouse andcycloneA7809U S STEEL GREAT LAKES WORKS10200704NO 2 BOILER HOUSE BOILERS (ALL5) BF GAS USE17.630B2032MARYSVILLE NPDC10200602NATURAL GAS OVEN FOR E-COATLINE (EUECOAT)15.9086364 12. Reasonable Further Progress (RFP) Requirements

Rule 40 CFR, Part 51.1009 requires a demons tration of RFP. However, if the

state submits an attainment demonstration showing attainment by 2010, the state is not required to submit a separate RF P plan. Through the weight of evidence demonstration in the SIP, Michigan has demonstrated that a ttainment of the

PM 2.5 annual standard will be achieved by 2010. Therefore a separate RFP plan is not required to be part of this SIP submittal.13. Contingency Measures

Rule 40 CFR, Part 51.1012 requires that the state must submit in each attainment plan spec ific contingency measures to be undertaken if the area fails to make reasonable further progre ss, or fails to attain the PM 2.5 NAAQS by its

attainment date.

Michigan is using a two-tier approach fo r the contingency measures. The first tier contains measures that are very likely to occur. The state is actively pursuing these rules or permits with companies in the nonattainm ent area. The second

tier contains additional meas ures that need further invest igation. The options in the second tier will be a starting point for ev aluations of future controls in the

event attainment does not occur in 2010 as predicted in this SIP. It will also be

considered for controls needed for the new 24 hour PM 2.5 NAAQS. The list of contingency measures is shown in Table 13.a.

13.1 Tier I

1) State Mercury Rules. All EGUs in the state will be required to comply with a 90 percent mercury reduction using activated carbon inje ction, which requir es a baghouse (many EGUs in the state have ESPs and will have to upgrade) or do multipollutant controls of 75 percent mercury reductions, 95 percent NOx reductions and 90 percent SO 2 reductions.

2) ICI boilers. Michigan is working with other LADCO states, as well as the Northeast states, to develop a n ational rule for ICI boilers that they will propose to

the EPA.

3) Clean diesel projects. Michigan is applying for federal grants to retrofit additional school buses and possibly some municipal bus fleets in the Detroit area.

4) Street sweeping. The Marathon Petroleum Company is proposing in a permit to sweep several streets in the vicinity of the Marathon Plant and near the D earborn

monitor.

13.2 Tier II

The primary source of information the MD EQ used in developing the following list of potential contingenc y measures was t he steel mill report developed by RTI (2006). The report provided information on areas for possible additional control at the facilities which directly impact the monitor showing nonattainment of the

PM 2.5 standard. In addition, control options from NACAA, EPA, and various web

65sites were evaluated and included in t he contingency list. Furthermore, the RACT evaluations for NOx, SO 2 , and primary PM 2.5 indicated a few possible
measures for control. The list of c ontingency measures wit h associated data is

shown in Table 13.a.

1) Steel Mill Operations. a) EES Coke battery controls. Require additional SO 2 controls by adding on a desulfurization unit. b) Process heater and boilers. Require additional SOx and NOx contro ls on various operation process

heaters and boilers. c) Casting operations. Require additional NOx controls on t he hot strip mill processing at the steel facilities, such as Low NOx burners and SNCR. Em issions reported for these operations are 500+ tons fr om Severstal and 300+ tons from the
U.S. Steel. d) Torpedo Cars. Require covers or cars to be filled bef ore transporting, to reduce smoking. Continue studying options to reduce emissions from this source. e) Slag Pits. Require additional controls on the sl ag pits at the steel facilities. Suggested controls include water suppression, capture hoods or operations and baghouses. f) Capture hoods. Install or upgrade capture hoods for vari ous processes at the steel mills, such as the kish pile.

2) Reciprocating Internal Combustion (RIC) Engines.
Lower the threshold limit of NOx emissi ons in the current rule for RIC engines requiring c ontrols.

3) Outdoor Wood Burners. Require performance st andards on outdoor wood burner manufacturers. Emissions estimated at 8000 tons/year of fine particulate in Michigan with 90 percent emitted from No vember through March.

4) Flat Glass Melting Furnace. Require NOx, SO 2 and primary PM 2.5 controls. NOx controls such as low NOx burners, SCR, and SNCR can reduc e emission from 40 to 75 percent (AirControlNET, 2005). However, EPA does not have suggested controls for
SO 2 or PM 2.5 for this type of facility.

665) Charbroiling operations at restaurants. a) Require installation of catalytic oxid izer for conveyorized charbroilers at commercial cooking es tablishments, reducing PM 2.5 source emissions by 85 percent. Other eastern states and California already have these requirements. b) Require installation of an ESP (s mog-hog) or scrubber on underfired charboilers at restaurants, reducing PM 2.5 source emissions by 99 percent.

6) Paved roads and unpaved lots.

Fugitive dust from paved roads and unpav ed lots is a potential source of

PM 2.5 . Further evaluation of potential reductions in PM 2.5 from these sources will be pursued. Detailed cost and emissi on reduction information specific to these sources in the high PM 2.5 area in Southeast Michigan is not available

and therefore not lis ted in Table 13.a.

67Source or CategoryControl OptionsExpected EmissionReductionTime needed forlegislation/ ruleTime needed forimplementationCommentsTier I—Controls likely to happenActivated carbon injection(requires a baghouse)90% mercuryreductionMercury Rule forEGUsMultipollutant strategy:75% mercury, 95%NOx and 90% SO2reductionsWorking on rule,may be in placeby end of 2008Beginning January2015Wet or Dry Scrubbers30 to 85% reductionsin SO2Federal ICI boiler ruleSCR, SNCR or low NOxBurners30 to 80% reductionin NOx12-18 months< 6 month afterrules promulgatedMulti-regional workgroupto request EPApromulgate federalregulations.Clean Diesel projectsRetrofit additional schoolbuses and possibly somemunicipal bus fleetsNot Applicable< 6 monthsCurrently applying forfederal grantsStreet sweepingMarathon is proposing tosweepseveral streets in thevicinity of the DearbornmonitorNot Applicable< 6 monthsPart of permit to installapplication #388-07Tier II—Potential Contingency MeasuresSO2controls on EESCoke BatteryInstall a desulfurization uniton the coke battery.90% reduction of SOxemissions112-18 months< 6 months afterrules promulgatedSuggested in RTI (2006)report.NOx controls forprocess furnaces andboilers at Steel millsLow NOx burners, ultra lowNOxburners, SNCR, SCR,flue gas recirculation, or acombination of NOx controls40-97% reduction112-18 months< 6 months afterrules promulgatedSuggested in RTI (2006)report.Slag pits at steel millsIncorporate techniques toreduce emissions, such aswet suppression or anenclosure and baghouse12-18 months< 6 months afterrules promulgatedSuggested by MDEQpermit engineers andinspector.Torpedo cars at steelmillsRequire covers to reducesmokingNot Applicable< 6 monthsBased on MDEQ AQDconsent order #6-200668Upgrade/install hoodsfor processes at steelmillsImprove capture efficiencies(e.g., kish pile at Severstal)12-18 months< 6 months afterrules promulgatedSuggested in RTI (2006)report and by MDEQinspector.SO2controls for boilersand process heaters atsteel millsAdvanced, wet or dry flue gasdesulfurization90-99% SO2removal112-18 months< 6 months afterrules promulgatedSuggested in RTI (2006)report and byRACT/RACM evaluation.Casting operations atsteel millsAdd SO2controls for castingoperations90-95% SO2removal,potentially 1680-1770tons reduced312-18 months< 6 months afterrules promulgatedPossible sources indicatedbyRACT/RACMevaluation.NOx controls on RICenginesLower the threshold limit incurrent State rule50-80% NOx control,1188-1901 tonsreduced312-18 months< 6 months afterrules promulgatedPossible sources indicatedbyRACT/RACMevaluation.Outdoor wood burnersRequired performancestandards: outdoor woodburners for new units12-18 months< 6 months afterrules promulgatedFew sources innonattainment areaFlat glass meltingfurnaceRequire controls for SO2,NOx, and primary PM2.510-85% NOx control,$700-$2320/ton412-18 months< 6 months afterrules promulgatedNo controls are suggestedfor SO2or PM2.5for thissource4Commercial cookingconveyorizedcharbroilerCatalytic oxidizer83% PM2.5control,$3000/ton212-18 months< 6 months afterrules promulgatedCommercial cookinglarge underfired grillingESP (Smog-hog) or scrubber99% PM2.5control,$6000/ton212-18 months< 6 months afterrules promulgated1RTI report (2006)2EPA Lists of Potential Control Measures for PM2.5and Precursors3Based on EPA estimates as presented by Black and Veatch, December 20054AirControlNET, ver 4.1, September 200569REFERENCES

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