Vf.f~;n·,:_~ 

"""". '~ ·-."'.' , ~'· 

. 

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 (PM2.5) 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 PM2.5 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 

Director 

ste .. ,E.~ 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 (PM2.5) 

Michigan Department of Environmental Quality 

Air Quality Division 

P.O. Box 30260 

Lansing, Michigan 48909 

http://www.michigan.gov/deqair 

May 15, 2008 
Table of Contents 

1. Executive Summary...................................................................................... 1 

2. Background and Overview of the PM2.5 Rule.............................................. 13 

2.1 General Background/History of the PM2.5 Rule ................................ 13 

 2.2 Michigan Nonattainment Areas........................................................ 13 

3. General Planning Provisions ...................................................................... 17 

4. State Implementation Plan Approval and Compliance with CAA 

 Section 110 and Part D Requirements. ...................................................... 18 

5. Local Planning............................................................................................ 19 

6. Monitoring................................................................................................... 20 

7. Emissions Inventory ................................................................................... 21 

8. Transportation Conformity Budget.............................................................. 24 

9. Weight of Evidence (WOE)......................................................................... 25 

 9.1 Fine Particulate Matter..................................................................... 26 

 9.2 Emissions ........................................................................................ 27 

9.3 Monitoring........................................................................................ 29 

 9.4 Organic Carbon: More Study Needed.............................................. 32 

 9.5 Modeling .......................................................................................... 33 

 9.5.1 Photochemical Modeling .................................................... 33 

 9.5.2 Local Scale Dispersion Modeling ....................................... 35 

9.5.3 Combined Modeling Results............................................... 42 

10. Attainment Strategy .................................................................................... 44 

 10.1 Implementation of National Controls................................................ 44 

 10.2 Implementation of Local Controls .................................................... 45 

 10.3 Voluntary Measures......................................................................... 48 

 10.4 Tracking Progress and Continuing Evaluation................................. 49 

11. RACT and RACM ....................................................................................... 50 

 11.1 RACT-RACM Modeling.................................................................... 50 

 11.2 NOx RACT-RACM Analysis............................................................. 53 

 11.3 SO2 RACT-RACM Analysis ............................................................. 58 

 11.4 PM2.5 RACT-RACM Analysis ........................................................... 60 

12. Reasonable Further Progress (RFP) Requirements................................... 64 

13. Contingency Measures............................................................................... 65 

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

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

References............................................................................................................ 70 

Page ii
Figures

Figure 1.a Southeast Michigan PM2.5 Nonattainment Area................................. 1 

Figure 1.b 3-year Average PM2.5 Levels: Toledo and Luna Pier ......................... 2 

Figure 1.c 3-Year Average PM2.5 Concentrations 2001-2003............................. 2 

Figure 1.d Organic Mass Comparison Dearborn vs. Allen Park.......................... 4 

Figure 1.e Industrial Sources Within 3 Miles of Dearborn Monitor ...................... 4 

Figure 1.f Influence of Iron on Crustal PM2.5 ...................................................... 5 

Figure 1.g Location of Severstal in Relation to Dearborn Monitor....................... 5 

Figure 1.h Pollution Rose for Iron at Dearborn 2003-2004 ................................. 5 

Figure 1.i Average PM2.5 Concentration at Each Site When Winds are from the 

Northeast ........................................................................................... 6 

Figure 1.j Average PM2.5 Concentration at Each Site When Winds are from the 

Northwest........................................................................................... 6 

Figure 1.k Average PM2.5 Concentrations by Wind Direction 2003-2004............ 7 

Figure 1.l 3-Year Average PM2.5 Concentrations Southeast Michigan............. 10 

Figure 1.m Average Annual Statewide PM2.5 Concentrations-Midwest States... 10 

Figure 2.2.a PM2.5 Nonattainment Area Showing Location of PM2.5 Monitors...... 14 

Figure 2.2.b Former PM10 Nonattainment Area ................................................... 15 

Figure 2.2.c Three-year average PM2.5 Levels Toledo and Luna Pier ................. 16 

Figure 6.a Michigan’s 2007 PM2.5 Monitoring Network ..................................... 20 

Tables

Table 1.a Forecasted Change in PM2.5 Concentration between 2005 and 

 2009....................................................................................................9 

Table 7.a Summary of Michigan's nonattainment 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 contribution to the Dearborn monitor.....................41 

Table 11.1.a Statewide RACT-RACM run results .................................................52 

Table 11.1.b 7-county nonattainment area RACT-RACM run results....................53 

Table 11.2.a NOx Tons and Percentages by Emission Source.............................56 

Table 11.2.b Percent Reduction and Dollar per Ton of NOX Reductions..............56 

Table 11.2.c NOx Emission Sources in Southeast Michigan.................................57 

Table 11.3.a SO2 Tons and Percentages by Emission Source .............................60 

Table 11.3.b Potential SO2 Tons Removed...........................................................60 

Table 11.3.c SO2 Emission Sources in Southeast Michigan .................................60 

Table 11.4.a PM2.5 Tons and Percentages by Emission Source ...........................62 

Table 11.4.b Potential PM2.5 Controls and Reductions Achieved..........................63 

Table 13.a Contingency measures.....................................................................68 

Page iii
Appendices

Appendix A: Weight of Evidence Tables and Figures 

Appendix B: Response to Public Comments 

Appendix C: Emissions Inventory Methodology

Appendix D: Mobile Emissions used for the Conformity Budget 

Appendix E: Southeastern Michigan PM2.5 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 Model for Ambient Fine Particulate Matter Over Southeast 

Michigan: High Concentration Days

Appendix J: Severstal Permit 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 iv
HPMS 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 Emissions Reporting System 

MDA Michigan Department 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 Industrial Classification 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 

PM10 Course Particulate Matter, <10 um in diameter 

PM2.5 Fine Particulate Matter, <2.5 um in diameter 

PTI Permit to Install 

PMF Positive Matrix Factorization 

RACM Reasonably Available Control Measures 

RACT Reasonably Available 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 Industrial Classification 

SIP State Implementation Plan 

Page v
SNCR Selective Non-catalytic Reduction 

SO2 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 Environmental Protection Agency 

VMT Vehicle Miles Traveled 

VOC Volatile Organic Carbon 

WOE Weight of Evidence 

Page vi
1. Executive Summary 

The purpose of this summary is to synthesize three years of planning and analysis of 

fine particulate (PM2.5) pollution in Southeast Michigan, and to demonstrate the 

connections between this analysis and the strategy for attaining the National 

Ambient Air Quality Standards (NAAQS) for PM2.5. 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 government 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 strategy. However, the vast majority of the 

technical information is contained in other sections of this State Implementation Plan 

(SIP). 

A new standard and an initial assessment 

Over the last 30 years, the United States Environmental Protection Agency (EPA) 

adopted several air quality standards to protect 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 achieved compliance with each through 

regulatory programs to reduce emissions. The most recent NAAQS for fine 

particulate matter less than 2.5 microns or PM2.5) 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 the monitors were measuring 

attainment and half were recording violations of the annual standard (see Figure 

1.a). 

Figure 1.a 

In examining the data between 2001 and 2003 we learned the following about 

locations measuring violations: 

1 
• Several monitors were closer to attaining the PM2.5 NAAQS as compared to 

other monitors in the region. 

• Higher levels of PM 2.5 were mostly 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 tracked with higher levels in the Toledo 

area (see Figure 1.b). 

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

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

Figure 1.b 

Figure 1.c

Source: MDEQ monitoring

2 
A closer examination of monitoring data 

After this initial screening and evaluation of monitoring data, we began a deeper 

probing of the data, seeking answers to key questions including: 

• What are the similarities and differences between levels at violating monitors, 

particularly between Dearborn and the other sites? 

• What is the composition of PM2.5 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 cases, different studies produced conflicting results. 

Nonetheless, we were able to converge on several more detailed findings supported 

by weighing the results of the different studies. (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 Dearborn 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 differences in PM characteristics between 

Dearborn and other monitoring sites, particularly Allen Park, which is only six miles 

from Dearborn but is located in a less industrialized area. These identified 

differences provided invaluable information for isolating the causes of nonattainment 

as well as possible solutions. 

In particular, it was clear that the Dearborn monitoring site was much more heavily 

influenced by industrial sources (see Figure 1.d), and levels of PM2.5 had significantly 

higher amounts of soil and organic carbon (OC). Furthermore, the vast majority of 

the “soil” component at Dearborn was iron. Perhaps most significantly, reducing the 

levels of soil and organics at Dearborn to levels characteristic of sites measuring 

compliance would likely bring Dearborn into attainment. 

3 
 Figure 1.d 

Investigation of emission sources confirmed there was a complex array of sources 

within 3 miles of the Dearborn site (see Figure 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 the soil component at Dearborn, as well as 

pollution roses for this iron component, pointing directly to the southwest, clearly 

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

Figure 1.f 

Figure 1.g Figure 1.h 

N

 

5 
Finally, several evaluations were conducted assessing the degree to which sources 

in other parts of the region impacted particulate 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 sources as well as motor vehicles and fuels. 

Figure 1.i 

Average PM2.5 Concentration at Each Site When 

Winds Are From the Northeast

Figure 1.j 

Average PM2.5 Concentration at Each Site When 

Winds Are Form the Northwest 

6 
1.k 

7 
Additional monitoring data is available for analysis 

With the passage of time, as the initial analyses 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 site at Luna Pier was measuring attainment 

and EPA revised 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 multistate 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 findings that local controls would have to be 

implemented to complement the benefits of “on the 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. This included investigations of monitoring, 

modeling, and emissions inventory data. The multiple perspective analysis was 

designed to help sort out similarities and differences 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 PM2.5 they 

contribute? 

We learned it was reasonable to expect significant reductions in emissions and that 

regional reductions would contribute to reducing particulate levels from 1.5 and 1.9 

μg/m3 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, there would be some incremental benefit from 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 

8 
regional 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 PM2.5 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 

Design 

Value1

2009 

Design 

Value2

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: 

• PM2.5 levels continued to improve at all sites with the largest improvements at 

the sites of greatest concern (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 emission levels), see Figure 1.m. 

• Despite the 2005 levels, the trend remained downward and all but two sites 

were measuring attainment. 

9 
9

12

15

18

21

2000-2002 2001-2003 2002-2004 2003-2005 2004-2006 2005-2007

Concentration (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 PM2.5 Concentrations – Midwest States 

0

3

6

9

12

15

18

Illinois

Indiana

Iowa

Kansas

Michigan

Minnesota

Missouri

Nebraska

Ohio

Wisconsin

Concentration (ug/m3)

2004 2005 2006

10 
In 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 the modification of several continuously 

operated switch engine locomotives in the 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/m3) 

and will most likely measure attainment at the end of 2008. There are three key 

reasons supporting this expectation that the 3-year average will decline by another 

0.5 μg/m3 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/m3

). 

Actions moving forward 

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

benefits of the local emission reductions described above. As best as possible, the 

impacts of meteorology (positive or negative) will be taken into account. 

Also, as part of its partnership with MDEQ, the Southeast Michigan Council of 

Governments (SEMCOG) purchased a continuous 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 partnering 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 particulate. While the strategy for complying 

with the annual average will contribute 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 PM2.5

concentrations has already been completed 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 PM2.5 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 

PM2.5 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 the region’s urban industrial core. This confirms that 

emission reductions to bring the Dearborn monitor into compliance must come from 

this urban core. 

11 
The results of the conceptual model have also led us to pursue additional analyses 

over the coming months. These analyses will provide a clearer explanation of the 

source contribution of specific PM2.5 components, particularly OC, nitrate, and zinc. 

This continuing work will further expand Southeast Michigan’s wealth of information 

and knowledge regarding fine particulate concentrations in the area. 

12 
2. Background and Overview of the PM2.5 Rule 

2.1 General Background/History of the PM2.5 Rule 

The EPA promulgated the NAAQS for PM2.5 in July 1997. Since the EPA lacked 

sufficient air quality data to make designations for the newly promulgated standards, 

Congress passed legislation that delayed designations until three years of air quality 

data were collected by EPA-approved air quality monitors. The first monitors were 

put in place in 1998; however, a number of additional monitors did not come online 

until 1999, and therefore three complete years of data could not be collected until 

the 2000-2002 time period. 

After the EPA promulgated the PM2.5 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 May 14, 1999, the D.C. Circuit 

held that the CAA, as applied by the EPA in setting the 1997 standards for 

particulate matter (PM) and ozone, was unconstitutional as an improper delegation 

of legislative authority to the EPA. The ruling did not question the science or 

decision-making process used to establish the standards. The court remanded the 

PM2.5 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 rehearing and the D.C. 

Court denied the petition. 

The DOJ and the EPA then filed a petition with 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 approach to setting the NAAQS was in accordance with the CAA and 

did not constitute an unconstitutional delegation of authority. The Supreme Court 

also affirmed that the CAA requires the EPA to set standards at levels necessary to 

protect the public health and welfare, without considering the economic costs of 

implementing the standards. The Supreme Court remanded several other issues 

back to the D.C. Circuit, including the issue of whether the EPA acted arbitrarily and 

capriciously in establishing the specific levels of the standards. 

The D.C. Circuit heard arguments in this remanded case 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 PM2.5 standards. 

2.2 Michigan Nonattainment Areas 

With the court’s support and sufficient data, the EPA could now move forward with 

nonattainment designations. States were directed to submit their recommendations 

for designations of attainment and nonattainment. The MDEQ recommended that 

only Wayne and Monroe Counties be designated as nonattainment for PM2.5 and 

that each county be designated as a separate nonattainment area. 

13 
In June 2004, the EPA proposed a seven-county PM2.5 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 nonattainment 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

Southwestern High 15.5 μg/m3

School (SWHS)

Dearborn 17.2 μg/m3

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 current and historical monitoring data for 

particulate matter. The monitors showing violation of the standard in Wayne County 

are located in an area with a history of particulate matter problems, associated with 

local industrial sources. Figure 2.2.b shows the location of these monitors relative to 

the former PM10 nonattainment area. As the map illustrates, the areas are nearly 

identical. The primary source of the former PM10 problem was determined to be a 

few local industrial sources. Emissions from these sources were reduced and the 

region came into compliance in 19961

. 

 

1

 These emission reductions probably also helped lower PM2.5 concentrations in the area. However, 

no long-term PM2.5 monitoring data exist to determine the degree of improvement. 

14 
Linwood 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 the monitors in the seven-county area were 

measuring attainment, making a widespread nonattainment designation 

inappropriate from a regulatory perspective and misleading from a public health 

perspective. Several monitors measuring attainment in the seven-county area are 

downwind of the monitors showing violations of the standard (i.e., all counties north 

of Wayne and Monroe Counties). Adding controls in these downwind counties 

would not address the nonattainment in Wayne and Monroe Counties. In addition, 

transport of PM2.5 precursors from these counties would be addressed through the 

EPA’s Clean Air Interstate Rule (CAIR) and nitrogen oxides (NOx) SIP call. 

The Luna Pier monitor, located in the southeastern corner of Monroe County, is one 

mile north of the Ohio border. In the February 2004, PM2.5 nonattainment 

designation recommendation to the EPA, the MDEQ asserted strongly that Monroe 

County should be designated as a separate nonattainment area from Wayne County 

because PM2.5 levels at the Luna Pier monitor tracked more closely with those in 

Toledo, Ohio (Figure 2.2.c). 

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

12

15

18

1999-2001 2000-2002 2001-2003 2002-2004 2003-2005

C 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 Pier site had been decreasing in recent 

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 designated a seven-county area in Southeast 

Michigan as not attaining the PM2.5 standard. As of 2006, the only monitors that 

currently record PM2.5 concentrations above the standard are in the industrialized 

section of Detroit in Wayne County. 

16 
3. General Planning Provisions 

Pursuant to the requirements of 40 CFR 51, Appendix W, the MDEQ submits this 

SIP to meet the requirements of the EPA’s Fine Particulate rules, which were 

adopted to comply with CAA requirements. 

The MDEQ has authority to submit this SIP under Part 55, Air Pollution Control, of 

the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended 

(Act 451). 

The MDEQ provided public notice of the opportunity to comment on the SIP on 

February 4, 2008. On February 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. 

17 
4. State Implementation Plan Approval and Compliance with CAA Section 

110 and Part D Requirements. 

Section 110 of the CAA delineates general SIP requirements and Part D contains 

requirements applicable to Subpart 1 nonattainment areas. The language in 

MDEQ’s current rules refers to “particulate matter,” which would apply to any size 

fraction of particulate matter (e.g., PM10 or PM2.5). This provision in Michigan’s 

current law is adequate for the current SIP submittal and any future changes to the 

particulate matter standards. The MDEQ meets all the requirements of 

Section 110(a) SIP elements. 

Programs for emissions limitations, permitting, emissions inventories and 

statements, ambient monitoring, Reasonably Available Control Technology (RACT), 

Reasonably Available Control Measures (RACM) and contingency measures are 

included in the MDEQ SIP. 

Subpart 110(a)(2)(D) requires that SIPS contain certain measures to prevent 

sources in a state from significantly contributing to air quality problems in another 

state. The MDEQ has met the requirements of the federal CAIR to reduce NOx and 

sulfur dioxide (SO2) emissions contributing to downwind 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 Review (NSR) permitting program for major 

and modified sources of PM in nonattainment areas under the MDEQ’s permit 

program. Permits to install cannot be issued unless the applicant can demonstrate 

that increased emissions from the new or modified source will not result in a violation 

of the NAAQS.

18 
5. Local Planning 

The SIP was developed in close consultation with SEMCOG and its air quality task 

force and technical advisory group. SEMCOG is the metropolitan planning 

organization for Southeast Michigan and the lead local air quality planning agency 

under the CAA. 

In the early 1990s, SEMCOG formed the Southeast Michigan Ozone Study 

(SEMOS), an air quality technical advisory group to help understand the cause of air 

quality problems in the region and the sources that contribute to them. While the 

group’s name implies that its focus is ozone, 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 PM2.5 SIP development. SEMOS members are a 

diverse group of analysts, modelers, and scientists from both industry and 

government. While it includes many local stakeholders, representatives 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, technical 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 evaluate strategies for bringing Southeast 

Michigan into attainment of the new 8-hour ozone standard and continues its activity 

in addressing PM2.5. The Task Force is comprised of state and local policymakers, 

industry representatives, and other community stakeholders. 

This SIP utilizes data that was gathered and analyzed by SEMOS and evaluated by 

the Air Quality Task Force. By coordinating with local, state and regional members, 

MDEQ has worked to ensure that its strategy provides reasonable reductions to 

mitigate impacts of sources on affected PM2.5 nonattainment areas. 

19 
6. Monitoring 

Section 110(a)(2)(B) of the federal CAA requires a monitoring strategy for 

measuring, characterizing, and reporting PM2.5. The MDEQ maintains a 

comprehensive network of PM2.5 air quality monitors throughout Michigan with the 

primary objective being to determine compliance with the PM2.5 NAAQS. The MDEQ 

submits network reviews2

 to the EPA Region 5 annually to ensure that its air 

monitoring operations comply with all applicable federal requirements. 

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

since the PM2.5 designations were made. However, no reductions in the PM2.5

Federal Reference Method (FRM) network in the designated nonattainment area 

were made. The PM2.5 monitoring network is shown in Figure 6.a. 

Figure 6.1: Michigan’s 2007 PM2.5 FRM Monitoring Network

Source: MDEQ

Figure 6.a: Michigan’s 2007 PM2.5 FRM monitoring network. 

 

2

 See http://www.deq.state.mi.us/documents/deq-aqd-air-aqe-Monitoring-Network-Review-final-9-6-

07.pdf for MDEQ’s 2006 network review.

20 
7. Emissions Inventory 

Rule 40 CFR 51.1002 (c) requires pollutants contributing to fine particles to be part 

of a state’s SIP. The MDEQ believes that primary particles (EC/OC and crustal 

material), SO2, and NOx are the main components of PM2.5, and they are included in 

our analyses. Volatile organic compounds (VOCs) and ammonia (NH3) are included 

in the emissions inventory (and modeling inventories); however, they are not a part 

of the MDEQ’s current attainment strategy for PM2.5. VOCs’ contributions to PM2.5 

are still being investigated, and therefore control measures for these compounds will 

not be included in this SIP (although controls 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 PM2.5 emissions and emissions of PM2.5 precursors. 

The MDEQ must also submit any additional emission inventory information needed 

to support an attainment demonstration and Reasonable Further Progress (RFP) 

plan necessary to ensure expeditious attainment of the standard. The 2005 base 

year inventory for Michigan has been submitted 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 PM2.5, SO2, NOx, VOCs, and NH3. 

A description of the methodology used to prepare the inventory appears in 

Appendix C. Mobile estimates for the nonattainment counties were prepared by 

SEMCOG and appear in Appendix D. Mobile emissions for other counties were 

prepared by the Midwest Regional Planning Organization’s (MRPO) contractor using 

traffic and vehicle information provided by the Michigan Department of 

Transportation (MDOT). The Lake Michigan Air Directors Consortium (LADCO) is 

the MRPO. A summary of the emissions inventory is shown in Table 7.a. The 

MDEQ will update this inventory on a periodic basis every three years. 

In addition, emissions were projected to 2009 to support the attainment 

demonstration. The base year and 2009 modeling 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 products can be found in the “Regional Air Quality Analyses 

for Ozone, PM2.5, and Regional Haze: Technical Support Document,” prepared by 

LADCO. LADCO has produced numerous summary 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

21 
Table 7.a. Summary of Michigan's nonattainment area 2005 base year annual emissions per county p

per year (tpy) for area sources (area), nonelectric generating unit point sources (nonegu_pt), on-road m

off-road mobile (nonroad), electric generating unit point sources (egu_point), marine, air and rail (mar aammonia sources (modeled nh3). 

County name Livingston Macomb Monroe Oakland St_Clair Washtenaw Wayne To

County ID 93 99 115 125 147 161 163

area 3.32 13.42 2.88 24.91 3.29 6.71 32.01 

nonegu_pt 0.15 16.24 79.41 19.73 10.33 4.48 132.61 

on-road 200.7 645.87 205.5 1319.26 171.71 388.25 1859.1 4

nonroad 1.3 4.42 1.44 7.24 1.71 2.66 8.48 

egu_point 2.59 11.78 1.8 

mar air rail 0.05 0.27 0.57 0.44 0.34 0.12 1.46 

modeled nh3* 280.31 224.2 638.69 84.74 273.56 738.07 113.69 2

area 647.95 2498.84 606.83 4535.97 563.69 1056.74 6039.67 15

nonegu_pt 654.19 720.91 3774.97 1096.91 1978.16 1050.26 9408.81 18

on-road 5417.9 14121.2 5454.4 31088 3812.6 9962.2 43981.4 11

nonroad 1288.1 5054 1404.71 7153.48 1519.17 2999.65 9410.39 2

egu_point 5.91 134.42 38483.26 71.97 19690.31 1.45 11369.4 69

mar air rail 83.97 589.24 958.21 822.22 557.31 203.64 4166.3 7

modeled nh3*

area 1424.61 468.79 1176.54 761.34 341.99 245.58 920.34 5

nonegu_pt 7.35 113.13 668.31 124.44 112.5 86.86 1342.36 2

on-road 89.47 265.44 91 559.86 71.06 170.02 792.05 

nonroad 120.62 339.65 121.96 614.54 108.58 2632.17 644 4

egu_point 0.1 12.83 597.66 8.86 142.13 0.02 352.76 1

mar air rail 2.55 13.91 29.11 23.91 18.3 6.02 99.3 

modeled nh3*

area 4338.29 11807.62 3663.62 17387.4 2671.18 5406.23 24887.81 70

nonegu_pt 176.95 2271.05 3555.73 2487.15 1379 388.83 6319.64 16

on-road 1696.9 5784.7 1742.6 11918 1550.9 3349.7 16931.1 4

nonroad 1927.32 4910.6 1893.76 9862.11 2166.18 2632.17 8396.96 3

egu_point 0.19 39.67 300.92 8.54 285.49 0 175.34 

mar air rail 23.38 114.92 61.48 93.3 43.26 19.96 460.03 

VOC modeled nh3*

pollutant

NH3NOx

PM25-

PRIM

22 
County name Livingston Macomb Monroe Oakland St_Clair Washtenaw Wayne To

County ID 93 99 115 125 147 161 163

area 226.78 930.59 181.05 1187.41 238.8 325 1540.36 4

nonegu_pt 13.7 48.26 7733.15 274.99 1752.75 20.75 6396.53 16

on-road 71.32 221.44 72.83 458.48 59.06 136.9 647.06 1

nonroad 139.72 426.07 139.75 683.2 125.05 342.2 883.35 2

egu_point 0.07 4.32 120386.7 3.43 66576.72 0.28 40780.46 227

mar air rail 7.53 38.28 82.64 64.67 72.99 16.93 398.38 

SO2 modeled nh3*

pollutant

* Emission from the NH3 Model for source categories not included in point, area or mobile categories (e.g. agriculture, etc.)

23 
8. Transportation Conformity Budget 

Transportation conformity is required by Section 176(c) of the CAA. The EPA’s 

conformity rule requires that transportation plans, programs, and projects conform to 

SIPs and establishes the criteria and procedures for determining whether or not they 

do. Conformity to a SIP means that transportation activities will not produce new air 

quality violations, worsen existing violations, or delay timely attainment of the 

NAAQS. 

Estimates of on-road motor vehicle emissions are projected for the attainment year 

to assess emission trends and to ensure continued compliance with the PM2.5

NAAQS. On-road emissions include those from cars, buses and trucks driven on 

public roadways. These estimates are considered a ceiling or “budget” for 

emissions and are used to determine whether transportation plans and projects 

conform to the SIP. Estimated on-road mobile emissions of primary PM2.5 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 methodology used to estimate mobile 

emissions in the nonattainment counties appear 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 PM2.5 NOx 

2009 1,470 75,500 

Source: SEMCOG, Southeast Michigan On-Road Mobile Source Emissions Inventory for the PM2.5

State Implementation Plan, January 2008.

24 
9. Weight of Evidence (WOE) 

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

demonstration showing 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 reduction 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 PM2.5 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. This approach provides a more robust 

demonstration in light of the many uncertainties that remain regarding the relatively 

new PM2.5 annual standard. 

The data sources used in this demonstration include monitoring data, emissions 

inventory data, photochemical and dispersion modeling, and trend analysis. Taken 

together, this information provides adequate proof that the areas with the highest 

levels of PM2.5 in the state, namely the Dearborn/SWHS monitoring areas, have 

been seeing substantial reductions in PM2.5 levels over the last several years. It 

shows that regional controls of NOx and SO2 are reducing PM2.5 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 PM2.5 come predominantly from 

local upwind industrial sources, and that control of these sources, primarily the 

nearby steel mill, will bring the area into attainment of the annual PM2.5 standard by 

2010. 

The Detroit area has been recognized as having a rich source of air quality data and 

has been the site of many studies by the 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 the rich data base is the high 

density of air quality monitors. These numerous monitors have allowed MDEQ to 

isolate, within a few miles, the areas of highest air pollution, and thus the areas of 

greatest concern. 

The MDEQ’s analysis and attainment strategy 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 investigated, 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 controls were determined to be impractical and 

ineffective, particularly since federal requirements (CAIR, NOx SIP Call, mobile 

source controls, etc.) will already be controlling the major sources outside of Wayne 

County. Since monitoring trends and modeling data showed that regional on-thebooks controls would result in attainment of the standard at all but the Dearborn 

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

excess at Dearborn. 

9.1 Fine Particulate Matter 

In 1997, the EPA developed new NAAQS for fine particulate matter. The EPA 

designated the Southeast Michigan area (seven counties) as nonattainment. The 

three-year average concentrations for 2001-2003 showed six monitors were 

measuring violations of the annual PM2.5 standard. Five of these monitors were in 

eastern Wayne County and the sixth was the Luna Pier monitor in southern Monroe 

County (see Figure 2.2.a). 

As Figure1 in Appendix A shows, air quality in Southeast 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 particulate matter problems associated with local industrial 

sources. Since the area successfully attained the PM10 standard after the 

application of local controls, the MDEQ believes that the most effective attainment 

strategy for PM2.5 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 strategy 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 mixture of ammonium sulfate, ammonium 

nitrate, OC, EC, soil (or crustal material) and other particles. Some PM2.5, 

particularly in urban areas, is anthropogenic (man-made) in origin and some is 

biogenic (plant-made) in origin. PM2.5 is composed of primary (directly emitted) and 

secondary (formed in the atmosphere) particles. Our understanding of how much 

PM2.5 is primary versus secondary, and how fast secondary formation takes place, is 

limited. Current speciation analyses of ambient monitoring data indicate that PM2.5

concentrations result from both primary emissions (e.g., crustal matter, EC, and 

much of OC), and secondary formation (e.g., ammonium sulfate, ammonium nitrate, 

and some OC). 

As discussed above, PM2.5 is composed of many different components that can 

come from a wide variety of sources. Few monitoring sites in Southeast Michigan 

have speciation monitors. Lack of speciated PM2.5 data at most locations, especially 

some of those monitors that were originally showing violations of the standard 

(Linwood, SWHS, and Wyandotte), has made identification of specific local source 

contributors in these areas very difficult. One must make assumptions based on 

source proximity to neighboring monitors that do have detailed data available. 

However, as will be discussed throughout this WOE, data from the Allen Park and 

Dearborn monitors, only six miles apart, show significantly different species 

composition and source apportionments, particularly with regard to OC and crustal 

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

particularly at Dearborn. 

In addition to the complexity of the PM2.5 mixture, quantification of PM2.5 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 are made through other methods such as 

factoring total PM emissions (which includes total suspended solids and PM10), or 

use of activity levels and emission factors. This adds to the complexity of 

determining local source contributions. 

9.2 Emissions 

Significant emission reductions in the Midwest are expected from national controls, 

including CAIR and additional motor vehicle reductions (Tier 2, the Diesel Rule and 

low-sulfur fuel requirements). The EPA’s Mobile6 model predicts that VOC, NOx, 

and PM2.5 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 SO2 emissions by 15 percent during this same time period. LADCO 

modeling of these control measures predicts they will result in a 1.3 – 1.7 μg/m3

reduction in PM2.5 mass concentrations at every monitor in the nonattainment area 

by 2009 (see Table 1 in Appendix A). These reductions already take into account 

expected economic growth and increases in travel. This is compelling evidence that 

areas in Southeast Michigan that are currently attaining the standard will remain in 

compliance. 

While these reductions are already having a significant, positive impact in Southeast 

Michigan and both monitoring and modeling data 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 industrialized core of Detroit, which contains 

a complex array of emission sources (see Figure 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 component, as well as local hotspot modeling, 

indicate that emission reductions resulting from planned controls at this steel mill will 

be very effective in bringing Dearborn into 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 these controls will provide a combined 

primary PM emission reduction of 317 tons/year (147 tons/year from controls at 

27 
Severstal 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 Renewable Operating Permit (ROP) 199600123a; 

and 94 tons/year from Marathon through NSR 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 closed or scaled back their operations since 

2002 (see Table 4 in Appendix A). These changes may be contributing to the more 

rapid decrease in PM2.5 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 see if these trends change in future.

In addition to the on-road mobile emission reductions previously 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 immediately upwind of the 

monitor. There are as many as 40 switch 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 the vicinity of the SWHS monitor. 

Over the next two years, 28 of the switch engines in this area will be retrofitted with 

anti-idling equipment. These retrofits are being funded through a $1.5 million federal 

Supplemental Environmental Project. Based 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 switch engine locomotives at 

the CSX 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 66 tons of NOx and 1.8 tons of diesel PM. This project is being funding 

through the federal Congestion Mitigation Air Quality (CMAQ) program. 

While the emissions reduction expected from retrofitting diesel switch engine 

locomotives is relatively small compared to those at the large stationary sources, 

they are expected to have some impact because 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). Also 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 analysis, a large number of storage piles, 

unpaved lots, and plots of barren land were observed 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 “fugitive” sources are thought to be larger than 

PM2.5. Nonetheless, the sheer number of them, and their possible aggregate 

impact, deserves attention. While many of these sources are already the subject of 

28 
a regulatory program as the result of a previous SIP, more information is needed to 

determine the contribution of fugitive dust to PM2.5 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 these sources may occur in the future if 

funding becomes available. 

The MDEQ also analyzed the impacts of additional NOx and SO2 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 

SO2 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 PM2.5 annual levels, then more source-selective runs would be 

done. However, the modeling resulted in about 1 ug/m3 reduction at the Dearborn 

monitor, and other monitors had less in the 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 RACT-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 PM2.5 excess at 

Dearborn and therefore would not address the true source of the fine particulate 

problem in this area. 

9.3 Monitoring 

For the purpose of weight of evidence, monitoring data clearly supports the MDEQ 

assessment that attainment of the annual PM2.5 standard will be achieved by 2010. 

Levels of PM2.5 in the nonattainment area have been on a downward path for a 

number of years, and this trend is expected to continue. 

The latest three-year average concentration (2005-2007) shows that only two of the 

original six monitors are still exceeding the standard: Dearborn and SWHS. Since 

2000, PM2.5 concentrations at all sites in the region have steadily declined. Overall, 

the three-year average concentration dropped 1.5 μg/m3

 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 μg/m3), 

SWHS (2.0 μg/m3

), Allen Park (2.1 μg/m3) and Wyandotte (2.6 μg/m3) (see Table 7 

in Appendix A). 

Despite a rise in 2005 PM2.5 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 PM2.5 concentrations over the last six years (see 

Figure 1 in Appendix A). In fact, every monitor in Southeast Michigan recorded its 

29 
lowest annual average PM2.5 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 PM2.5 levels that meet the standard. In addition, the annual 

average at SWHS has been below the standard in both 2006 (14.68 μg/m3

) and 

2007 (14.54 μg/m3

), and we expect the three-year average for this monitor to 

demonstrate attainment by the end of 2008. 

Examination of trends in PM2.5 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 statistically significant at all three sites, with the 

greatest decrease occurring at Dearborn (-0.54 ug/m3/year, see Table 9 in 

Appendix A). 

PM2.5 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 emissions from sources in the vicinity of 

the monitors showing violations of the standard. A LADCO analysis of rural 

background concentrations versus urban excess in the Midwest showed the majority 

of PM2.5 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 PM2.5 nonattainment at the monitors showing violation of the 

standard. Analysis of this data shows that the vast majority 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/m3

 annual standard when winds are from these 

directions (see Figures 12 and 13 in Appendix A). Furthermore, a recently 

developed conceptual model for days with high PM2.5 concentrations shows that 

local fine particulate excess at various monitors in the region is consistently highest 

when winds are coming from Wayne County’s urban industrial core. Thus, rather 

than emissions from outlying counties contributing to the local excess at Dearborn, it 

is the emissions generated in the highly industrialized portion of Wayne County that 

are impacting the outlying counties (see 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 PM2.5 monitors in the Southeast Michigan nonattainment area 

that are less impacted by local sources are meeting the standard (see Figure 1 and 

Table 8 in Appendix A). However, two of the components of PM2.5, OC, and soil,

have a higher (though declining) local contribution (see Figure 14 in Appendix A). 

30 
Within 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 earlier, the crustal component is largely 

composed of iron (see Figure 6 in Appendix A). A wind rose for the iron component 

of PM2.5 at Dearborn points directly to the southwest. Conversely, the iron wind rose 

for Allen Park, while measuring much lower 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/m3 higher than those at Allen Park and 

are sometimes as much as 6 μg/m3 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 PM2.5 as well. The 

incremental difference in PM2.5 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 local 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 PM2.5 emissions 

at this facility by 147 tons/year (see Table 2 in Appendix A and Appendix F for 

additional details). 

In addition to crustal material, OC is significantly higher at the Dearborn monitor 

(1.5 - 2.0 μg/m3 higher), even though this monitor 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 west, southwest or south (see Figure 16 in 

Appendix A). 

A separate analysis of OC levels by wind direction indicates that the decrease at 

Dearborn is occurring at a faster rate than at Allen Park (see Table 10 in 

Appendix A). This provides corroborating 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/m3

 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, future analysis focused on explaining this 

urban excess will be difficult. 

31 
9.4 Organic Carbon: More Study Needed 

Determining the source of local OC emissions is difficult. Results of 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 contribute to the OC mass (see Figure 21 in 

Appendix A). Further analysis is needed to identify the source(s) of OC excess at 

Dearborn and determine how it can be controlled. To this end, the MDEQ, with 

support from SEMCOG, has initiated continuous monitoring for OC at Dearborn. 

LADCO is sponsoring additional measurement-based source apportionment studies 

as well. 

To help understand the OC fraction, six recent 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/m3 to annual average PM2.5. 

• Dearborn also experiences higher mobile source impacts than Allen Park 

(1.3 to 1.7 ug/m3 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 levels are not being influenced by local 

sources. However, some of the industrial source fingerprints did include 

sulfate mass, which indicates that local sources of sulfate are present and 

need further evaluation. 

 

Chemical mass balance (CMB) analyses on high PM2.5 days at Dearborn show 

varied patterns, suggesting that varying mixtures of sources are impacting this site 

on any given day. Plumes from industrial sources as well as emissions from 

smoking vehicles appear evident in these 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 PM2.5 excess being 

measured at Dearborn (STI 2006). 

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

PM2.5, particularly for OC, are still being analyzed. However, preliminary results of 

one study done by an advanced mobile laboratory from Canada (CRUISER) showed 

some peaks in OC from high vehicle traffic areas, trains, and a sausage smoking 

factory (see Figure 24 for the monitor data and Figure 25 for the map locations in 

Appendix A). In addition, upwind/downwind analysis of one of the Detroit steel mills 

showed a large difference in PM2.5, particulate sulfate, black carbon, and several 

32 
precursors, as well as a small (0.8 ug/m3

) 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 significant amount of particulate emissions, 

but may only be a moderate source of particulate OC. 

Another preliminary analysis by LADCO used nonparametric regression and kernel 

density estimates to regress continuous monitor concentrations to wind speed and 

wind direction data to map locations of relatively 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 monitoring sites, because they have 

the necessary black carbon continuous monitors. Newberry also has an OC 

continuous monitor. 

A highly industrialized area near Zug Island was indicated for high black carbon 

emissions in a combined analysis of all four sites (see Figure 26 in Appendix A). 

The FIA site showed high black carbon emissions from the Ambassador Bridge 

(Figure 26 in Appendix A). The analysis at Newberry indicates that an intermodal 

freight terminal in the area emits higher concentrations of both OC and black carbon 

(similar to EC but uses a different analytical 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 concentrations at these two 

sites are currently below the standard (see Table 8 in Appendix A). Also, EC tends to 

be a very small fraction of the total PM2.5 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 have changed over time, and if necessary, how 

they can be controlled in the future. 

9.5 Modeling 

For the purpose of weight of evidence, photochemical and dispersion modeling 

support the MDEQ assessment that attainment of the annual PM2.5 standard will be 

achieved by 2010 at the monitors currently exceeding the standard, and that 

monitors that are meeting the standard will remain in attainment of the annual 

standard. The most recent combination of photochemical and local scale modeling 

shows attainment of the standard at the highest monitor (Dearborn) by 2009. Details 

of these analyses follow. 

9.5.1 Photochemical Modeling 

Extensive photochemical modeling (CAMx) has been conducted by LADCO to 

address PM2.5, as well as ozone and haze in Michigan. A comprehensive Technical 

Support Document (TSD) describes the modeling parameters, the testing of the 

model itself, and the predicted reductions in these pollutants in future years. An 

33 
electronic 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 PM2.5 levels 

for the state. 

Table 10 (see also Table 1 in Appendix A) in the TSD shows the modeled PM2.5 

levels at several monitors in Wayne County, Michigan (not including the impact of 

local controls). The two highest monitors, Dearborn (261630033) and SWHS 

(261630015), have 2009 values of 15.8 ug/m3 and 14.2 ug/m3, respectively, in the 

Round 5 modeling. 

 

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

Round 5 using a base year of 2005 and Round 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 updated 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 PM2.5 is not well understood, but it likely influences PM2.5. Overall the models 

show good agreement in magnitude of PM2.5 mass, but some species are 

overestimated and others are underestimated. In 2002, sulfates had good 

agreement, but nitrates were overestimated 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 base year used is a 

policy decision. The MDEQ has chosen 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 modeling base year more closely predicts the 

actual annual averages from the air quality monitors. 

The Round 5 modeling demonstrated that all monitors with the exception of the 

Dearborn monitor show attainment by the 2010 attainment date. The Dearborn 

monitor is further evaluated using local scale modeling described below, which 

shows that the local scale emission reductions at Severstal will bring the Dearborn 

monitor value to15.1 ug/m3

 by the 2010 attainment date. 

34 
9.5.2 Local Scale Dispersion Modeling 

As a complement to LADCO’s CAMx, the MDEQ conducted local scale dispersion 

modeling to determine the impacts of localized emission reductions at large 

industrial facilities in the vicinity of the air monitors showing violations of the 

standard. This modeling showed approximately 0.73 ug/m3

 annual reduction in 

PM2.5 at the Dearborn monitor as a result of the controls required at Severstal. 

Additional reductions are attributed 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 is not accounted for 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 reductions from a local area/point source 

within each grid are “spread out” over the entire grid. Thus, grid models provide 

useful information concerning regional contributions but fail to adequately address 

neighborhood scale interactions. 

For areas like the Dearborn monitor location, where local source primary emissions 

may contribute a sizable portion of the total PM2.5 (i.e., 10 to 30 percent of the total 

annual average), use of a Gaussian dispersion model may work well for determining 

local primary impacts within a small area. Such modeling 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 rather than the absolute manner employed in 

new source review (NSR) permitting analyses. Therefore, that is the approach 

followed by the MDEQ in this WOE demonstration. 

The process to determine neighborhood scale impacts follows 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, PM2.5, and 

Regional Haze dated April 2007. Similar guidance has been discussed in various 

regional workshops sponsored by LADCO. 

As indicated by Section 5.3.2, there is no single, simple method for quantifying the 

local contribution to a specific location. In fact, the local component will likely include 

contributions from more than one source. When applying the model to changes in 

primary PM2.5, the recommended approach is to identify the individual components 

of PM2.5. This approach is necessary so that the non-primary components of PM2.5 

(i.e., nitrates, sulfates, etc.) can be removed and only the primary portions can be 

considered. For purposes of this analysis, only the speciated primary components 

identified as “soil” and “mixed industrials” were considered. These components 

should contain most of the metals expected from the steel industry plus fugitive 

emissions associated with large industrial areas. 

35 
Local MET data was used to represent the dispersive nature of the Southeast 

Michigan wind patterns. Meteorology data, 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 modeling, 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 approach 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 scale analysis deals explicitly with primary 

emissions, seasonal chemistry variances do not apply. Therefore, this deviation 

from the guidance is not expected to significantly alter the results of this analysis. 

The guidance recommends using a relative approach to determine the reductions 

from planned control strategies rather than absolute model results. This is different 

from the usual application of results from Gaussian models for regulatory permitting. 

This is, however, consistent with regional modeling of PM2.5, thus is more 

appropriate for this purpose. The relative reduction factor derived from the 2005 

base modeling and the anticipated 2009 emissions was applied to the specified 

primary component of PM2.5 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 

PM2.5 levels is summarized as follows: 

1) Estimate the amount of observed (monitored) PM2.5 at the Dearborn monitor 

that is local in origin. 

2) Model base year PM2.5 emissions (PM10 if PM2.5 emissions data is 

unavailable) from local point sources to determine the impact on the 

Dearborn monitor. 

3) Calculate the amount of observed PM2.5 at the Dearborn monitor that comes 

from Severstal. 

4) Model future year (2009) PM2.5 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 PM2.5 reduction at the Dearborn monitor in 2009 as 

a result of SIP controls at Severstal. 

36 
1) 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 PM2.5. For this analysis, it 

is important to identify the local contributions from as small an area as possible to 

ease identification of the likely contributing sources. 

For purposes of this WOE demonstration, three monitoring sites in the area of 

Southeast Michigan with the highest PM2.5 levels were reviewed: Dearborn, SWHS, 

and Allen Park. 

Dearborn monitor

The Dearborn monitor consistently records the highest values of PM2.5 in Southeast 

Michigan, making it the primary monitor of concern. The 2000-2004 weighted 

average (i.e., the average of the three 3-year averages from those years) is 

19.3 ug/m3. As seen in Figure 28 in Appendix A, the monitor resides approximately 

1,000 yards northeast of the Severstal steel mill. This is the direction of the climatic 

prevailing wind direction (Figure 29 in Appendix 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. Approximately 16 engines will be idling in the 

rail yard at any given time. The Ford Motor Company Rouge Complex is located just 

north of the Severstal facility. Another steel company, U.S. Steel, is located on Zug 

Island, approximately three miles southeast of the monitor. Additionally, a major 

gasoline refinery, Marathon, is located approximately two miles south of the monitor. 

Figure 30 in Appendix A shows the relationship of the monitor to these influencing 

facilities. PM2.5 filters collected at the Dearborn monitor are analyzed for particle 

speciation. This monitor has the highest PM2.5 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 monitor 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/m3. Speciated PM2.5 data is not available from the 

SWHS site. 

Allen Park monitor

The Allen Park Monitor is located approximately six miles southwest of the Dearborn 

monitor (Figure 30 in Appendix A). Due to the prevailing winds (Figure 29 in 

Appendix A), the Allen Park monitor is located upwind of the majority of facilities that 

likely impact the Dearborn and SWHS monitors during southwest winds episodes. 

The 2000-2004 weighted average is 15.8 ug/m3

. Due to the upwind nature of the 

Allen Park monitor location, this monitor can provide more of a regional aspect of 

Southeast Michigan as compared to the Dearborn and SWHS monitors, which 

37 
receive a large local component of primary PM2.5. 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 impacting the Dearborn monitor. Several 

reports analyzing the Dearborn and Allen Park filters have been funded through 

LADCO. Data from the reports were heavily relied upon for this portion of the WOE 

demonstration. This section of the WOE relied primarily on source apportionment 

analysis of the two monitors by STI (2006) and Clarkson University. These reports, 

in their entirety, are available 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/m3

) and Allen Park (15.8 ug/m3), first conclusions suggest a 

maximum of 3.5 ug/m3 of PM2.5 impacting Dearborn are from local sources. This 

conclusion is supported by the STI (2006) report “Data Analysis and Source 

Apportionment of PM2.5 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/m3 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 realistic estimate of local contribution to the 

Dearborn site. The difference between the combined soil and mixed industry at 

Allen Park (2.23 ug/m3

) and Dearborn (4.55 ug/m3) is 2.32 ug/m3 in the Clarkson 

report (see Table 9.5.a). The difference between the combined soil and mixed 

industry at Allen Park (1.98 ug/m3) and Dearborn (4.36 ug/m3) is 2.38 ug/m3 in the 

STI (2006) report (see Table 9.5.a). 

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

 (in ug/m3

). 

 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 Vehicles 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 contribution of primary PM2.5 in the range of 2.30 ug/m3

 to the Dearborn 

monitor is further supported by additional analysis by LADCO, documented in a 

presentation titled, “Data Analysis to Support Local Area Modeling,” (Kenski, 2007). 

In Figure 31 in Appendix A from the Kenski report, approximately 3.25 ug/m3 is 

associated with the Dearborn monitor while approximately 0.95 ug/m3 is associated 

with Allen Park monitor. Subtracting the Allen Park concentration as area 

background would leave at the Dearborn monitor 2.30 ug/m3 as local contribution, 

which is similar to the Clarkson and STI results. 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 demonstration, a concentration of 2.30 ug/m3 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 significant sources used 

in the AERMOD model to predict impacts from neighborhood scale emissions (see 

Figure 3 in Appendix A). Most of the sources were treated as a single individual 

point source using a weighted, representative stack. Due to the proximity of the 

Severstal facility, detailed refined modeling used all individual point and volume 

sources as defined during previous NSR permitting. Actual PM2.5 2002 emissions 

from Severstal (totaling 553.4 tons/year) were identified by the MDEQ at each 

39 
detailed emission point. Emissions used from the other sources were PM10

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/m3

, with 

2.96 ug/m3 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 PM2.5 impacting the Dearborn monitor. 

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

Factor was derived based on the modeled values from the local sources. The 

Severstal predicted impact (2.96 ug/m3) was divided by the overall predicted impact 

from all local sources (4.61 ug/m3

) for a Relative Reduction Factor of 0.642. 

Applying this factor to the previously determined local primary PM2.5 contribution to 

the Dearborn monitor of 2.30 ug/m3 yields an annual average of 1.48 ug/m3

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 PM2.5 from the 2002 level because of the 

various controls that the company is installing. The inventory list is summarized in 

Table 2 of the Appendix A. The 2009 Severstal impact was predicted by AERMOD 

to be 1.47 ug/m3

. 

5) Calculation of the Relative Reduction Factor. 

The 2009 impact was predicted to be 1.47 ug/m3

 as compared to the 2002 base 

case impact of 2.96 ug/m3

. This provides a Relative Reduction Factor of 0.497 

(i.e., 1.47 / 2.96 = 0.497). 

6) Calculation of the reduction in ug/m3

 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 multiplying the relative reduction factor of 

0.497 by the predicted Severstal contribution of 1.48 ug/m3

 in 2002. Therefore the 

expected reduction by 2009 will be 0.73 ug/m3

 based only on Severstal reductions. 

Table 9.5.b summarizes these figures. It should be noted that this is a conservative 

prediction because other emission reductions in the area from U.S. Steel, Marathon, 

locomotive retrofits, and other sources 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 Appendix A) provided evidence that iron 

accounts for approximately 1.4 ug/m3

 of primary particulate to the Dearborn monitor. 

40 
Iron is associated primarily with steel production, and most can be attributed to 

Severstal. Table 13 in Appendix 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 PM2.5 which is not seen at other area monitors. 

As provided in the previous section, the assumption that Severstal contributes 

1.48 ug/m3

 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 believed 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 operations in the facility. The sum of the 

reductions will be 148 tons per year. These reductions were not taken into account 

during the regional modeling 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/m3 as compared to the 2005 Base 

Case impact of 2.96 ug/m3

. 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/m3), the expected Severstal reduction by 2009 will be 0.73 ug/m3. 

Table 9.5.b summarizes these figures. This reduction in primary particulate from 

Severstal, in conjunction with the regional 2009 prediction of total PM2.5 particulate 

(15.8 ug/m3

), indicates that Dearborn will be nearly in attainment by 2009 even 

before considering other reductions of neighborhood scale emissions. 

Table 9.5.b: Severstal’s 2009 contribution 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 Contribution 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 

41 
c. AERMOD dispersion model validation. 

The hotspot dispersion modeling results can be evaluated to address model 

performance. Similar to grid modeling, the dispersion model results should be 

compared to ambient data to ensure the model is working well. 

As discussed in the previous section, combined soil (including metals) and mixed 

industrial impacts at the Dearborn monitor were concluded to be 4.55 ug/m3 per the 

Clarkson report and 4.36 ug/m3 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 modeling. The combined near source 

industrial emissions were predicted to yield an impact of 4.61 ug/m3 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 PM2.5 from nearby industrial sources. 

The model further gives a combined impact from these sources of 0.65 ug/m3 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/m3) from the same 

sources is less than the modeled impact at Dearborn (4.61 ug/m3) 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/m3

(4.61 ug/m3 - 2.59 ug/m3) is similar to the monitored 2000-2004 weighted average 

difference of 2.0 ug/m3

 (19.3 ug/m3 - 17.3 ug/m3). 

In all cases, some AERMOD overprediction is expected because all source 

emissions, except Severstal, assumed PM10 emissions will be higher than PM2.5

emissions. Table 12 in Appendix A provides a summary of the Dearborn minus the 

Allen Park industrial particulate differences. 

AERMOD modeling summary files for the 2005 and 2009 analyses are attached as 

Appendix H. 

9.5.3 Combined Modeling Results 

The impacts of future year emission reductions, taking into account future year 

growth as well, is demonstrated by combining the regional scale photochemical 

modeling with the local scale modeling. To avoid double counting of emission 

reductions, the modeled local source emission reductions are not accounted for in 

the regional modeling inventory. The future year predicted PM2.5 levels as 

determined by the regional modeling is included in Table 10 in Section 4 of the 

LADCO TSD (see also Table 1 in Appendix A). The values for the two monitors that 

42 
are 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 PM2.5 impact at the Dearborn monitor in 2009 resulting from primary 

PM2.5 emission reductions at Severstal is a reduction of 0.73 ug/m3. When this 

reduction is subtracted from 15.8 ug/m3

 as projected from the regional modeling, the 

resulting calculated PM2.5 level at the Dearborn monitor in 2009 is predicted to be 

15.07 ug/m3. With the PM2.5 standard at 15 ug/m3, this modeling demonstration 

provides additional support for attainment by 2010. While the modeled value is 

slightly over the standard, the AQD believes that the additional reductions from 

locomotive retrofits and other local sources described in section 10 of this document 

will ensure that the Dearborn monitor and the entire nonattainment area will come 

into attainment by 2010. 

43 
10. Attainment Strategy 

The attainment strategy approach for fine particulate should be multifaceted. There 

are four components to the attainment strategy for PM2.5: 

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. No single program can be relied upon for 

attainment and our limitations in predicting the future through 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 themselves to regulatory action and that controls 

in certain parts of the nonattainment area will contribute very little toward attainment, 

the strategy targets local controls in a portion of eastern Wayne County. This is 

consistent with the location of violating monitors and with earlier successful 

strategies in attaining previous particulate matter standards. 

10.1 Implementation of National Controls 

a) Mobile Sources 

Mobile sources are recognized as a significant contributor to PM2.5 levels in both 

attainment and nonattainment areas. The focus on reducing emissions costeffectively in the eastern portion of Wayne County is somewhat incompatible with 

specialized vehicular emission reduction programs. More importantly, the 

contribution of mobile sources to PM2.5 levels will be reduced throughout the region 

and nation as a result of several new federal requirements. These requirements 

affect both vehicle design as well as fuel specifications. We estimate the following 

programs will reduce PM2.5 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 program. The Tier 2 

program requires manufacturers to produce vehicles that emit much lower 

levels of pollution than earlier generations. 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. 

44 
Diesel 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 gasoline due to new federal standards for 

fuel. This standard requires the average sulfur level to be no greater than 

30 parts per million (ppm). This represents 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 represents an enormous decrease from the 

380 ppm average measured in 2002.3 These sulfur reductions are a key 

contributor to the large-scale vehicular emission reductions shown in Figure 2 

of Appendix A. 

Although these low sulfur fuel programs are federal requirements, the 

Michigan Department of Agriculture (MDA) is committed to testing for 

compliance with these standards. The MDA will update its existing programs 

and regulations to include a provision for the enforcement of these standards. 

Implementation of this program and enforcement of this program is primarily 

the responsibility of the EPA. Using a combination of its enforcement 

authority under the Clean Air Act and its program for certifying manufacturer 

compliance with vehicle emissions standards, 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 finalized a rule to address longrange transport of PM2.5, commonly referred to as the CAIR rule. This rule 

will result in major reductions of sulfates and nitrates, two of the most 

significant contributors to PM2.5 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 these 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 PM2.5 attainment strategy. One is a 

recently approved consent order between Severstal and the MDEQ. The other is a 

 

3

 Alliance of Automobile Manufacturers. 2002 North American summer and winter fuel surveys. 

45 
recently approved permit that is subject to the consent order. These programs 

require emission reductions from 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 PM2.5

emissions by 147 tons/year, and will be especially 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 Project requires Severstal to take the 

following additional actions: 

• School bus retrofits: The Company will spend $100,000 to retrofit 

approximately 100 school buses in the local area with diesel oxidation 

catalysts and/or engine crankcase filters. These devices will reduce the 

exposure of children to diesel particulate emissions as well as reduce 

overall PM2.5 emissions in the area. 

• Company-owned diesel equipment retrofits: The Company will spend 

$100,000 to retrofit some of its own on-site diesel equipment. 

• Planting of trees in the area: The Company will spend $200,000 on tree 

planting in the area, providing both air quality and aesthetic benefits. 

b) U.S. Steel

An enforceable consent order and permit between the company and the MDEQ 

resulted in reductions at the B blast furnace. The existing baghouse was replaced 

resulting in an annual primary PM emissions reduction of 76 tons (Consent Order 

#1-2005, ROP #199600123a--see Table 3 in Appendix A). 

c) Marathon

An enforceable consent order and permit at Marathon also resulted in PM2.5

emission reductions. These reductions resulted 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. 

46 
The 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 heavy 

crude oil. The proposed permit is currently 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 addition, 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 buses in the City of Detroit fleet. 

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

plant. 

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

• Voluntary installation of particulate controls on the truck fleet that will 

transport petroleum coke. 

• Voluntary purchase of PM10 offsets from closed plants to retire. 

d) Reductions from plant closures and changes in operations

As discussed in the WOE, PM2.5 levels are improving. The rate of improvement is 

greater at the industrial monitoring sites (Dearborn, SWHS, and Wyandotte). While 

local regulatory measures were not responsible for this improvement, many of these 

reductions are permanent and the impact on attainment and maintenance is 

significant. 

e) Diesel Switch Engine Locomotive Retrofits

In the course of identifying possible sources for emission reductions, we also 

considered factors beyond the quantity of emissions. These include the nature of 

the emissions and proximity to the Dearborn and SWHS monitors and surrounding 

communities. Approximately 40 switch engines operate in these areas on a fairly 

continuous basis with little or no emission control. Over the next two years, 28 of the 

switch engines in this area will be retrofitted with anti-idling equipment. Based on 

data from a similar project in Chicago (USEPA 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 CSX 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 reduction from these retrofits to 132 tons of 

NOx and 3.8 tons of diesel PM. 

47 
10.3 Voluntary measures

a) High emitting vehicle detection 

Despite the massive reductions 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 these emissions. Because of the cost, 

effectiveness, and time to implement a mandatory vehicle-testing 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 merely 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 high emitters in the region. The project 

showed that Southeast Michigan has fewer high emitters than other parts of the 

country due to its newer fleet. However, the 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 vehicles and encouraging them to voluntarily 

seek repairs. Roughly 40 percent of those contacted did seek repairs, which shows 

great promise for a broader voluntary program. The vast majority of those who did 

not seek repairs said they could not afford them. SEMCOG is pursuing follow-up 

activities to make the public aware of the 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 observed 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 “fugitive” sources are thought to be larger than 

PM2.5. 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 result of a previous SIP, voluntary programs, targeted at 

smaller establishments in the area, may produce additional benefits and should be 

explored. 

To that end, SEMCOG has teamed with Southwest Detroit Environmental Vision and 

a graduate class at the University of Michigan (U of M) to develop a blueprint for 

greening properties in this area. During 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, the 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. 

48 
While 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 multifaceted approach to the PM2.5 strategy involves tracking 

progress toward attainment and continued evaluation of other possible contributors 

that should be the subject of control. This 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. PM2.5 Monitoring Network Enhancement – In order to improve our 

understanding of the PM2.5 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 region, provided the MDEQ can obtain 

additional funding. These enhancements will not only improve our 

understanding of current PM2.5 concentrations, they will also allow us to better 

track progress towards attainment. 

b. Organic Carbon Analysis – While the controls listed in sections 10.1 to 10.3 

above will have a significant impact on PM2.5 in Southeast Michigan, more 

needs to be done to understand and address the excess OC component. 

Much time and effort has been spent analyzing 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 studies will be pursued to increase our 

understanding of this component and its contribution to Southeast Michigan’s 

fine particulate problem. 

49 
11. RACT and RACM 

Rule 40 CFR Part 51.1010 requires the MDEQ to submit with the attainment 

demonstration a SIP revision demonstrating that it has adopted all RACM (including 

RACT for stationary sources) necessary to demonstrate attainment as expeditiously 

as practicable. RACM is the application 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 specifically 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 PM2.5 SIP has been developed to demonstrate through a weight of 

evidence approach that the nonattainment area will attain the standard by 2010 

through a combination of multistate regional controls and reductions at several 

sources in close proximity to the areas with the highest PM2.5 annual levels. 

Additional area-wide controls more reflective of RACT and RACM are not believed to 

be appropriate for addressing the PM2.5 problems at the violating monitors in 

Southeast Michigan. 

However, before making the decision not to pursue RACT controls, the MDEQ did 

perform a modeling screening evaluation of the impacts that large emission 

reductions would have on the violating monitors, as described in Section 11.1 below. 

The results of the modeling, of 0.49 ug/m3 for statewide reductions and 1.01 ug/m3

for 7 county reductions at the Dearborn monitor are not insignificant. However, a 

very large emission reduction in the multicounty area and statewide, clearly a 

draconian control program, would be required to achieve such reductions. Thus, a 

RACT and RACM program, being “reasonably available” by definition, would be 

expected to provide much smaller emission reductions and therefore much smaller 

improvements in PM2.5 levels at the violating monitors. 

The MDEQ took one further step in evaluating 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 SO2, NOx, and primary PM2.5 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 analysis further demonstrates that a RACT program 

addressing stationary sources would result in much smaller emissions reductions 

than were modeled in the screening modeling. The conclusion from this is that such 

control programs would have little impact on reducing PM2.5 levels at the violating 

monitors. 

11.1 RACT-RACM modeling 

To determine the impacts of additional NOx and SO2 reductions on PM2.5 monitors, 

two sensitivity tests were performed with the CAMx model. 

50 
The first test reduced ALL statewide anthropogenic sources of NO, NO2, and SO2

emissions by 50 percent. Utility software provided by LADCO allowed the combined 

emission inventory (all point sources plus all area sources) to be reduced by 

50 percent across the entire state of Michigan. The CAMx model was run using the 

modified emissions files containing the statewide reduced emissions 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/m3 using 2005 monitored values 

(Table 11.1.a). 

The second test involved eliminating ALL (i.e., 100 %) of the anthropogenic NO, 

NO2, and SO2 emissions in the 7-county nonattainment area of Southeast Michigan. 

The CAMx model was again run using the altered emissions files containing the 

modified 7-county emissions and compared results to the unaltered 2005 base case 

(Base M emissions inventory). The relative results were used to determine what 

effect such additional draconian cuts in emissions 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/m3 using 2005 

monitored values (Table 11.1.b). 

While the Dearborn monitor reductions of 0.49 ug/m3

 (e.g., 50 percent statewide 

cuts) and 1.01 ug/m3 (100 percent 7-county cuts) are significant, it is clear that this 

level of reduction compared to the massive emissions cuts assumed in these 

analyses could not be justified and are not likely 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. 

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

MICHIGAN RACT-RACM ANALYSIS 

(ASSUMES 50% NOx/SO2 CUTS STATEWIDE - ALL SOURCES) 

2005 2005 

Monitored RRF 

w/MI 

RACM 

Net 

Reduction 

MICHIGAN 

MONITORS 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 

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

MICHIGAN RACT-RACM ANALYSIS 

(ASSUMES 100% NOx/SO2 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 stationary sources in the 7-county PM2.5 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 large enough to be impacted by a RACT control 

program. This grouping of larger sources represents the vast majority of stationary 

source NOx emissions, at approximately 79,000 tons/year. 

53 
This grouping of larger sources was then 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. As expected, the highest emitters are EGUs. The 

next highest sources group are industrial/ commercial/ institutional (ICI) boilers. The 

third highest grouping is kilns operated in the area at two sources. The fourth 

highest is reciprocating internal combustion (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 minimal 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 source. For example, a stationary source 

listed under ICI may have 6 boilers with aggregated 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 Owners (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, Inc. 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 catalytic reduction (SCR) or selective noncatalytic reduction (SNCR) post combustion controls. 

Out of 30 potential ICI stationary sources within Southeast Michigan that could have 

NOx controls installed, less than 4 percent are currently controlled for NOx. The 

anticipated level of emission reduction Michigan could achieve in the nonattainment 

area from affected sources is outlined in Table 11.2.b. Table 11.2.c. provides an 

assessment of NOx emissions sources that emit more than 50 tons per year. 

Regarding the ICI boilers, a workgroup consisting 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 emissions from boilers greater 

than 50 mmBtu/hour heat input rates. If a national rule is implemented it would 

create consistency among the states as opposed to a patchwork of statewide or 

nonattainment area-specific control programs. 

54 
Kilns

There are two stationary sources with large kilns operating in the area. There is 

some potential for post-combustion 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 requirements for these units. There are potential additional reductions 

available in this category by lowering the threshold level for affected facilities within 

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

Furnaces at Steel Mills

Blast and arc furnaces in operation at the steel mills in the area could provide

additional controls. Some controls are 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 higher than what is 

indicated in Table 11.2.b. 

Glass Mfg.

There is one stationary source in the area that manufactures flat glass. This process 

is combustion and heat intensive. Additional 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 emission 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-combustion controls. The EPA created the 

Landfill Methane Outreach Program (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 feasibility 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 manufacturers to test the automotive 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 “cool-down” the gas stream prior to entry 

into post combustion controls such as SCR or SNCR. If the temperature of the 

exhaust gas entering the post-combustion controls is too high, it could result in 

corrosion of the equipment or fouling of the catalyst. The additional cost for piping 

and other equipment to cool the exhaust gas stream is undetermined at this time, 

55 
but warrants future review as more data becomes available. Additionally, not all the 

fuel test cells currently have VOC controls and requiring additional 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 

Cost Per Tons of NOx Reduced 

Ton* 

Percent 

Removed 

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 2005 

Note: The ICI boilers were the only units considered for combustion controls. ICI, RIC, 

kilns, furnaces at steel mills and glass manufacturing operations were considered for 

post-combustion controls. The remaining sources are not easily controlled. 

56 
Table 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 PLANT 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 DETROIT 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 TECHNOLOGY CENTER 206.21

OAKLAND B7227 GENERAL MOTORS - ORION ASSEMBLY 168.77

WAYNE B2814 DETROIT THERMAL BEACON HEATING PLANT 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 CENTER 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

57 
Blast 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 SO2 RACT-RACM Analysis 

The MDEQ’s SO2 RACT analysis began by looking at the 2005 MAERS inventory 

for all reporting SO2 stationary sources in the 7-county PM2.5 nonattainment area. 

The total SO2 emissions for these sources are greater than 245,000 tons/year. A 

cut-off of greater than 50 tons of SO2 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 grouping of larger sources represents the vast majority of 

stationary source SO2 emissions, at approximately 244,000 tons/year. 

This grouping of larger sources was then 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 highest 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 operations. Building heaters 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 several 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 have 6 boilers with aggregated emissions 

greater than 50 tons. SO2 controls are on individual units and may not garner the 

predicted emission reductions as listed in Table 11.3.b. 

58 
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 LADCO’s ICI Boiler workgroup presentations and a review of 

information submitted by the Energy and Environmental Analysis, Inc. 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 dry or wet scrubbers with a slight potential for in-duct 

injection. 

Out of potential ICI sources within Southeast Michigan that could have SO2

controls installed, none are currently controlled for SO2. The anticipated level of 

emission reductions Michigan could obtain in the nonattainment area from 

affected sources are outlined in Table 11.3.b. Table 11.3.c. provides an 

assessment of SO2 emissions sources that emit more than 50 tons per year in 

the Southeast Michigan’s nonattainment area. 

Regarding the ICI boilers, a workgroup consisting 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 post-combustion SO2 controls at this source. The 

current scrubber in operation at the site has an estimated 30-50 percent 

efficiency for SO2 removal. Testing is currently being done at this site to 

determine a more accurate estimate. Once a determination is made, the MDEQ 

can then determine whether to require SO2 controls at other smaller kilns in 

Southeast Michigan. 

Glass Mfg.

The flat glass manufacturing operations could vent the SO2 emissions to hoods 

and install the controls as listed in Table 11.3.b 

Furnaces and Casting at Steel Mills

Furnaces and casting operations at the local steel mills could vent the SO2

emissions to hoods and install the controls as listed in Table 11.3.b. 

59 
Table 11.3.a. SO2 Tons and Percentages by Emission Source 

Sources SO2 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 SO2 Tons Removed 

Cost Per Tons of SO2 Reduced 

Ton* 

Percent 

Removed 

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. SO2 Emission Sources in Southeast Michigan* 

County SRN Facility Name SCC SO2 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 PM2.5 RACT-RACM Analysis 

The MDEQ’s primary PM2.5 RACT analysis began by looking at the 2005 MAERS 

inventory for all reporting primary PM2.5 stationary sources in the 7-county PM2.5

60 
nonattainment area. The total primary PM2.5 emissions for these sources are 

greater than 2,250 tons/year. A cut-off of greater than 15 tons of primary PM2.5

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 grouping of larger 

sources represents the vast majority of stationary source primary PM2.5

emissions, at approximately 1,870 tons/year. 

This grouping of larger sources was then 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 highest 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 emission 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 baghouse for PM2.5 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 PM2.5 using capture hoods, 

baghouses and ESPs. The RTI (2006) report indicated several other sources of 

PM2.5 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 baghouse; 

however, the remaining 300 tons are uncontrolled. These operations could vent 

the emissions to hoods and possibly install a baghouse or ESP. However, based 

on information in AirControlNET (ver. 4.1), no PM2.5 controls are suggested for 

glass furnaces. 

ICI Boilers

For the ICI boilers, 55 tons of the 89 tons are controlled. The emissions unit at 

U.S. Steel is actually a reporting group of 5 boilers. Each individual boiler emits 

less than 15 tons; therefore controlling these sources would not create enough 

reductions to be beneficial and would create undue costs to the facilities. 

Based on the small amount of potential reductions from primary PM2.5 within the 

nonattainment area due to the large number of sources that are already 

controlled, additional controls are not likely to be considered RACT in the PM2.5 

nonattainment area. 

61 
Table 11.4.a. PM2.5 Tons and Percentages by Emission Source 

Sources 

PM2.5 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% 

62 
Table 11.4.b. Potential PM2.5 Controls and Reductions Achieved 

SRN Sources SCC Emission Process Description PM2.5 in 

Tons 

Mineral Production 

B1877 GUARDIAN INDUSTRIES 30501403 FLAT GLASS: RAW MATERIAL FOR 

GLASS MELTING FURNACE 

161.208 

B1877 GUARDIAN INDUSTRIES 30501403 FLAT GLASS: RAW MATERIAL FOR 

MELTING FURNACE 

138.419 

B1743 HOLCIM (US) INC. 30500706 CEMENT KILNS 19.717 

Primary Metal Production 

A7809 U S STEEL GREAT LAKES WORKS 30300913 BOF - VESSELS - OXYGEN BLOWING 133.971 A8640 SEVERSTAL NORTH AMERICA, INC. 30300917 TAPPING: BOF 128.979 A7809 U S STEEL GREAT LAKES WORKS 30390024 BLAST FURNACE GAS TO FLARES 43.401 A8640 SEVERSTAL NORTH AMERICA, INC. 30300916 CHARGING: BOF 40.700 A7809 U S STEEL GREAT LAKES WORKS 30390004 BLAST FURNACE GAS TO BLAST 

FURNACE D STOVES 

40.520 

A7809 U S STEEL GREAT LAKES WORKS 30390004 BLAST FURNACE GAS TO BLAST 

FURNACE B STOVES 

34.711 

A7809 U S STEEL GREAT LAKES WORKS 30300304 COKE QUENCHING 34.364 A7809 U S STEEL GREAT LAKES WORKS 30300917 BOF - VESSELS - TAPPING 28.164 A8640 SEVERSTAL NORTH AMERICA, INC. 30300825 "C" BLAST FURNACE CASTHOUSE 27.115 A8640 SEVERSTAL NORTH AMERICA, INC. 30300825 "B" BLAST FURNACE CASTHOUSE 16.716 

ICI Boilers 

A6240 CARGILL SALT INC. 10100204 SPREAD STOKER COAL FIRED 

BOILER 

55.470 

A7809 U S STEEL GREAT LAKES WORKS 10200704 NO 2 BOILER HOUSE BOILERS (ALL 

5) BF GAS USE 

17.630 

B2032 MARYSVILLE NPDC 10200602 NATURAL GAS OVEN FOR E-COAT 

LINE (EUECOAT) 

15.908 

63 
64 

12. Reasonable Further Progress (RFP) Requirements 

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

state submits an attainment demonstration showing attainment by 2010, the state 

is not required to submit a separate RFP plan. Through the weight of evidence 

demonstration in the SIP, Michigan has demonstrated that attainment of the 

PM2.5 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 specific contingency measures to be undertaken if the area fails 

to make reasonable further progress, or fails to attain the PM2.5 NAAQS by its 

attainment date. 

Michigan is using a two-tier approach for 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 nonattainment area. The second 

tier contains additional measures that need further investigation. The options in 

the second tier will be a starting point for evaluations 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 PM2.5 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 injection, which requires 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 SO2 reductions. 

2) ICI boilers. 

Michigan is working with other LADCO states, as well as the Northeast 

states, to develop a national 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 Dearborn 

monitor. 

13.2 Tier II 

The primary source of information the MDEQ used in developing the following list 

of potential contingency measures was the 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 

PM2.5 standard. In addition, control options from NACAA, EPA, and various web 

65 
sites were evaluated and included in the contingency list. Furthermore, the 

RACT evaluations for NOx, SO2, and primary PM2.5 indicated a few possible 

measures for control. The list of contingency measures with associated data is 

shown in Table 13.a. 

1) Steel Mill Operations. 

a) EES Coke battery controls. 

Require additional SO2 controls by adding on a desulfurization unit. 

b) Process heater and boilers. 

Require additional SOx and NOx controls on various operation process 

heaters and boilers. 

c) Casting operations. 

Require additional NOx controls on the hot strip mill processing at the 

steel facilities, such as Low NOx burners and SNCR. Emissions reported 

for these operations are 500+ tons from Severstal and 300+ tons from the 

U.S. Steel. 

d) Torpedo Cars. 

Require covers or cars to be filled before transporting, to reduce smoking. 

Continue studying options to reduce emissions from this source. 

e) Slag Pits. 

Require additional controls on the slag 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 various processes at the steel mills, 

such as the kish pile. 

2) Reciprocating Internal Combustion (RIC) Engines. 

Lower the threshold limit of NOx emissions in the current rule for RIC engines 

requiring controls. 

3) Outdoor Wood Burners. 

Require performance standards on outdoor wood burner manufacturers. 

Emissions estimated at 8000 tons/year of fine particulate in Michigan with 90 

percent emitted from November through March. 

4) Flat Glass Melting Furnace. 

Require NOx, SO2 and primary PM2.5 controls. NOx controls such as low 

NOx burners, SCR, and SNCR can reduce emission from 40 to 75 percent 

(AirControlNET, 2005). However, EPA does not have suggested controls for 

SO2 or PM2.5 for this type of facility. 

66 
5) Charbroiling operations at restaurants. 

a) Require installation of catalytic oxidizer for conveyorized charbroilers at 

commercial cooking establishments, reducing PM2.5 source emissions by 

85 percent. Other eastern states and California already have these 

requirements. 

b) Require installation of an ESP (smog-hog) or scrubber on underfired charboilers at restaurants, reducing PM2.5 source emissions by 99 percent. 

6) Paved roads and unpaved lots. 

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

PM2.5. Further evaluation of potential reductions in PM2.5 from these sources 

will be pursued. Detailed cost and emission reduction information specific to 

these sources in the high PM2.5 area in Southeast Michigan is not available 

and therefore not listed in Table 13.a.

67 
Source or Category Control Options Expected Emission 

Reduction 

Time needed for legislation/ rule 

Time needed for implementation 

Tier I—Controls likely to happen 

Activated carbon injection (requires a baghouse) 

90% mercury reduction 

Mercury Rule for EGUs 

Multipollutant strategy: 75% mercury, 95% 

NOx and 90% SO2

reductions 

Working on rule, may be in place 

by end of 2008 

Beginning January 2015 

Wet or Dry Scrubbers 30 to 85% reductions 

in SO2

Federal ICI boiler rule 

SCR, SNCR or low NOx Burners

30 to 80% reduction in NOx 

12-18 months < 6 month after 

rules promulgated 

Clean Diesel projects Retrofit additional school 

buses and possibly some 

municipal bus fleets 

Not Applicable < 6 months 

Street sweeping Marathon is proposing to 

sweep several streets in the 

vicinity of the Dearborn monitor 

Not Applicable < 6 months 

Tier II—Potential Contingency Measures SO2 controls on EES 

Coke Battery 

Install a desulfurization unit on the coke battery. 

90% reduction of SOx emissions1

12-18 months < 6 months after 

rules promulgated 

NOx controls for process furnaces and boilers at Steel mills 

Low NOx burners, ultra low NOx burners, SNCR, SCR, 

flue gas recirculation, or a combination of NOx controls 

40-97% reduction1 12-18 months < 6 months after 

rules promulgated 

Slag pits at steel mills Incorporate techniques to 

reduce emissions, such as 

wet suppression or an enclosure and baghouse 

12-18 months < 6 months after 

rules promulgated 

Torpedo cars at steel mills 

Require covers to reduce smoking 

Not Applicable < 6 months 

68 
Upgrade/install hoods 

for processes at steel mills 

Improve capture efficiencies (e.g., kish pile at Severstal) 

12-18 months < 6 months after 

rules promulgated 

SO2 controls for boilers 

and process heaters at steel mills 

Advanced, wet or dry flue gas desulfurization 

90-99% SO2 removal1 12-18 months < 6 months after 

rules promulgated 

Casting operations at steel mills 

Add SO2 controls for casting 

operations 

90-95% SO2 removal, 

potentially 1680-1770 tons reduced3

12-18 months < 6 months after 

rules promulgated 

NOx controls on RIC engines 

Lower the threshold limit in current State rule 

50-80% NOx control, 1188-1901 tons 

reduced3

12-18 months < 6 months after 

rules promulgated 

Outdoor wood burners Required performance 

standards: outdoor wood 

burners for new units 

12-18 months < 6 months after 

rules promulgated 

Flat glass melting furnace 

Require controls for SO2, 

NOx, and primary PM2.5

10-85% NOx control, $700-$2320/ton4

12-18 months < 6 months after 

rules promulgated 

Commercial cookingconveyorized charbroiler 

Catalytic oxidizer 83% PM2.5 control, 

$3000/ton 2

12-18 months < 6 months after 

rules promulgated 

Commercial cookinglarge underfired grilling ESP (Smog-hog) or scrubber 99% PM2.5 control, $6000/ton 2 12-18 months < 6 months after rules promulgated 1 RTI report (2006) 2 EPA Lists of Potential Control Measures for PM2.5 and Precursors 3 Based on EPA estimates as presented by Black and Veatch, December 2005 4 AirControlNET, ver 4.1, September 2005 

69 
REFERENCES 

AirControlNET, version 4.1. USEPA, September 2005. 

AP 42, Fifth Edition, Volume I, Chapter 13: Miscellaneous, Background 

Document for Revisions to Fine Fraction Ratios Used for AP-42 Fugitive Dust 

Emission Factors, Nov 2006, 

http://www.epa.gov/ttn/chief/ap42/ch13/bgdocs/b13s02.pdf

Clarkson University, “Final Report of the Project Analyses of Midwest PMRelated Measurements.” 

http://www.ladco.org/reports/rpo/MWRPOprojects/DataAnalysis/FinalClarksonFin

al.pdf

Kenski, 2007a, “Data analysis to support local area modeling,” Lake Michigan Air 

Director Consortium. October 17, 2007. 

Kenski, 2007, “Overview of Recent Detroit PM Source Apportionment Studies,” 

Lake Michigan Air Directors Consortium, November 26, 2007. 

LADCO, 2008, “Regional Air Quality Analyses for Ozone, PM2.5, and Regional 

Haze: Technical Support Document” LADCO, April 25, 2008. 

http://ladco.org/Technical_Support_Document.html 

STI, 2006, “Integration of Results for the Upper Midwest Urban Organics Study,” 

Sonoma Technology, Inc., prepared for Lake Michigan Air Directors Consortium, 

March 31, 2006. 

http://www.ladco.org/reports/rpo/MWRPOprojects/Monitoring/Integration_FinalReport.pdf

RTI, 2006, “Evaluation of PM2.5 Emissions and Controls at Two Michigan Steel 

Mills and a Coke Oven Battery,” Prepared by RTI, International for the U.S. 

Environmental Protection Agency, February 7, 2006. 

http://www.epa.gov/pm/measures/detroit_steel_report_final_20060207.pdf 

USEPA, 2004, “Case Study: Chicago Locomotive Idle Reduction Project,” March 

2004. 

70