# 8-HOUR OZONE REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE
MILWAUKEE-RACINE 6-COUNTY SUBPART-2 MODERATE NONATTAINMENT AREA
SHEBOYGAN COUNTY SUBPART-2 MODERATE NONATTAINMENT AREA
DOOR COUNTY SUBPART-1 BASIC NONATTAINMENT AREA
MANITOWOC COUNTY SUBPART-1 BASIC NONATTAINMENT AREA
WISCONSIN

Developed By: The Wisconsin Department of Natural Resources September 200913 

### V. IMPROVEMENT IN AIR QUALITY IS DUE TO PERMANENT AND ENFORCEABLE MEASURES Wisconsin must be able to reasonably attribute the improvement in air quality to emission reductions that are permanent and enforceable. To satisfy this requirement, Wisconsin submits the following data indicating a decrease in emissions between 2002, when the Milwaukee-Racine 6-County Area and the c ounties of Door, Manitowoc, and Sheboygan were monitored as nonattainment for the 8-hour ozone NAAQS, and 2007, when these nine counties were monitored as being in attainment based on ozone design values determined from 2006 through 2008 data. In addition, Wisconsin has documented specific permanent and enforceable programs responsible for emission reductions over this time period. A. Nonattainment Y ear (2002) Inventory As part of a larger inventory development project, the WDNR prepared a comprehensive inventory for the State of Wisconsin. This inventory included point, mobile, and area sources for precursors of ozone (VOC and NOx) for the nonattainment year 2002. Biogenic emission estimates were not include d. A basic descripti on of the utilized methodologies follows.

• Point Source Inventory - The methodology used to develop the comprehensive 2002 non-Electric Generating Unit (non-EGU) poi nt source inventory is contained in Appendix 4. Contained in Appendix 5 is the EGU emission estimation methodology created by a WDNR Air Management engi neer and EGU specialist. The EGU emissions inventory incorporates U.S. EPA’s Clean Air Markets Division data.

• Area Source Inventory – The 2002 area source emissi ons inventory was derived by backcasting the Wisconsin 2005 Base Year emissions inventory submittal to U.S. EPA in June of 2007. This was done sin ce different methodologies were used to develop the original Wisconsin 2002 Base Y ear emissions inventory compared to the 2005 inventory. WDNR received verbal conf irmation from U.S. EPA Region 5 staff that this is an acceptable approach during a phone call on May 18 th 

### , 2009. These emission estimates were made based on va rious activity data compiled by, but not limited to, the U.S. Census Bureau, the U. S. Energy Information Administration, U.S. Bureau of Economic Analysis, the Lake Michigan Air Director’s Consortium (LADCO), as well as several Wisconsin St ate agencies. A description of the methodologies followed to develop the or iginal and backcasted 2002 inventory is included in Appendix 4. Appendix 7 contai ns area source emissions by county and SCC, including the backcasted growth factors.

• Nonroad Inventory – The nonroad emission estimates were prepared by using the U.S. EPA National Mobile Inventory (NMI M) model. Pechan, an independent contractor, provided marine and rail emissi on estimates via LADCO for Wisconsin in 2002. Aircraft emissions were calc ulated using the Federal Aviation Administration’s Emissions and Di spersion Modeling System (EDMS).14 

### • Onroad Inventory - 2002 mobile source emissi ons were calculated using MOBILE6.2. All emission estimates were ma de in accordance with the Users Guide to MOBILE 6.1 and MOBILE 6.2 , U.S. EPA, Office of Transportation and Air Quality, Assessment and Standards Division, August 2003, EPA 420-R-03-010 and The Technical Guidance on the Use of MOBILE6 for Emission Inventory Preparation , U.S. EPA, Office of Air and Radiat ion, Office of Transportation and Air Quality, January 2002. Point, area, nonroad, and onroad emissions data are in Appendices 5 through 9. Tables 5 and 6 below summarize total emissions in 2002, reported as tons per summer day (tpsd). As the tables indicate, major sources categ ories of NOx in 2002 are point and onroad. Milwaukee County has the greatest level of NOx emissions. Area and nonroad sources account for the greatest VOC emissions. Em issions of VOC are hi ghest in Milwaukee County followed by Waukesha County.
Table 5: Total NOx Emissions for Nonattainment Year 2002 (Tons per Summer Day) 

### County Point Area Onroad Nonroad Total Kenosha 67.64 0.80 8.08 4.42 80.94 Milwaukee 37.80 6.10 44.44 18.50 106.84 Ozaukee 6.49 0.60 6.66 5.83 19.58 Racine 1.55 1.08 8.71 5.94 17.28 Washington 0.36 0.86 9.71 4.31 15.24 Waukesha 0.89 3.43 25.58 12.94 42.84MilwaukeeRacine 6-Co. Area 114.73 12.87 103.18 51.94 282.72
Door 0.01 0.19 2.68 6.74 9.62 Manitowoc 2.83 0.42 7.41 4.21 14.87 Sheboygan 26.07 1.00 8.25 4.47 39.79 * Point includes combined non-EGU and EGU emissions 

### Table 6: Total VOC Emissions for Nonattainment Year 2002 (Tons per Summer Day) 

### County Point Area Onroad Nonroad Total Kenosha 0.63 6.22 3.61 4.99 15.45 Milwaukee 7.54 45.90 20.92 18.38 92.74 Ozaukee 0.51 6.77 2.54 3.07 12.89 Racine 1.61 18.19 4.06 6.78 30.64 Washington 0.62 11.41 3.61 6.34 21.98 Waukesha 3.81 18.12 10.62 21.63 54.18MilwaukeeRacine 6-Co. Area 14.72 106.61 45.36 61.19 227.88
Door 0.23 1.57 1.39 9.63 12.82 Manitowoc 1.58 4.63 3.26 3.59 13.06 Sheboygan 2.50 7.59 3.76 5.62 19.47 * Point includes combined non-EGU and EGU emissions15 

### B. Attainment Year (2007) Inventory WDNR developed a 2007 attainment year in ventory by growing the statewide 2005 base year emissions inventory of VOC and NOx emissions for the current nine nonattainment counties in Wisconsin. Point sector emi ssions estimates, both EGU and non-EGU, are actual 2007 reported emissions. Biogenic emi ssion estimates were not included. WDNR received written confirmation from U.S. EPA Region V staff that this is an acceptable approach. The 2007 inventory emissions were determined using the following approaches.

• Point Source Inventory Projections - Actual 2007 reported em issions, both EGU and non-EGU, are presented in Appendices 4 and 5.

• Area Source Inventory Projections - Projections were perf ormed by applying growth factors and applicable emission controls to the 2005 base year inventory. These growth factors were carefully selected ba sed on a prioritization schema. Foremost priority was given to county-specific empl oyment based growth factors. Next, if available, a state-specific employment based growth factor was used. These employment based growth factors were dete rmined from U.S. Census Bureau County Business Patterns data 1 

### . Next county-specific growth factors developed by Pechan 2 

### contained in the document entitled Development of Updated Growth and Control Factors for the Lake Michigan Air Directors Consortium (LADCO)- Draft Report (December 29, 2005) were used. Next, if a county-specific growth factor was unavailable, a Wisconsin state-specific growth factor developed by Pechan was applied. Finally, an EGAS 6.0-generated growth factor was employed if no other growth factors were available. Appendix 7 contains area source growth factors, emission controls, and grown emissions by county and SCC.

• Nonroad Inventory Projections - 2007 nonroad mobile em ission estimates were prepared by using the U.S. EPA National M obile Inventory (NMIM) model. Marine and rail emissions were grown from 2005 Pech an state-wide growth factors. EGAS 6.0-generated growth factors were used to grow the aircraft inventory.

• Onroad Inventory Projections - Emission projections were created using the U.S. EPA MOBILE 6.2 model. All projections were made in accordance with the Users Guide to MOBILE 6.1 and MOBILE 6.2 , U.S. EPA, Office of Transportation and Air Quality, Assessment and Standards Division, August 2003, EPA 420-R-03-010 and The Technical Guidance on the Use of MOBILE6.2 for Emission Inventory Preparation , U.S. EPA, Office of Air and Radiat ion, Office of Transportation and Air Quality, August 2004, EPA 420-R-04-013.

1 http://www.census.gov/econ/cbp/download/index.htm 2 Pechan is an independent contractor, which, through contracts with LADCO, has developed state specific emission inventory data, including growth factors, for the entire LADCO region.16 

### Point, area, nonroad, and onroad emissions data are in Appendices 5, through 9. Tables 7 and 8 below summarize the total emissions. Ta ble 9 compares the total emissions for the nonattainment and the attainment inventorie s for the Milwaukee-Racine 6-County Area and the counties of Door, Manitowoc, and Sheboygan.
Table 7: Total NOx Emissions for Attainment Year 2007 (Tons per Summer Day) 

### County Point Area Onroad Nonroad Total Kenosha 10.62 0.83 6.05 3.95 21.45 Milwaukee 26.88 6.29 29.81 16.83 79.81 Ozaukee 1.11 0.62 4.70 4.84 11.27 Racine 0.93 1.12 6.21 5.17 13.43 Washington 0.74 0.90 7.20 3.61 12.45 Waukesha 1.41 3.54 19.24 11.26 35.45MilwaukeeRacine 6-Co. Area 41.69 13.30 73.21 45.66 173.86
Door 0.002 0.20 1.97 5.28 7.452 Manitowoc 3.13 0.43 5.38 3.61 12.55 Sheboygan 12.99 1.04 5.81 3.73 23.57 * Point includes combined non-EGU and EGU emissions



### Table 8: Total VOC Emissions for Attainment Year 2007 (Tons per Summer Day) 

### County Point Area Onroad Nonroad Total Kenosha 1.61 5.72 2.63 4.13 14.09 Milwaukee 5.16 41.40 13.75 14.46 74.77 Ozaukee 0.46 6.41 1.75 2.23 10.85 Racine 1.25 17.17 2.82 5.59 26.83 Washington 0.59 11.03 2.63 5.07 19.32 Waukesha 3.13 16.82 7.81 16.97 44.73MilwaukeeRacine 6-Co. Area 12.20 98.55 31.39 48.45 190.59
Door 0.30 1.51 0.93 8.85 11.59 Manitowoc 1.43 4.39 2.24 3.15 11.21 Sheboygan 2.26 7.08 2.50 5.02 16.86 * Point includes combined non-EGU and EGU emissions17 

### Table 9: Comparison of 9-County A rea Total NOx and VOC emissions for 2002 and 2007 (Tons per summer day) Milwaukee-Racine 6-County Area

NOx VOC Sector 2002 2007 Net Change (2007 – 2002) 2002 2007 Net Change (2007 – 2002) Point 114.73 41.69 -73.04 14.72 12.20 -2.52 Area 12.87 13.30 0.43 106.61 98.55 -8.06 Onroad 103.18 73.21 -29.97 45.36 31.39 -13.97 Nonroad 51.94 45.66 -6.28 61.19 48.45 -12.74 Total 282.72 173.86 -108.86 227.88 190.59 -37.29 Door County NOx VOC Sector 2002 2007 Net Change (2007 – 2002) 2002 2007 Net Change (2007 – 2002) Point 0.01 0.002 -0.01 0.23 0.30 0.07 Area 0.19 0.20 0.01 1.57 1.51 -0.06 Onroad 2.68 1.97 -0.71 1.39 0.93 -0.46 Nonroad 6.74 5.28 -1.46 9.63 8.85 -0.78 Total 9.62 7.452 -2.17 12.82 11.59 -1.23 Manitowoc County NOx VOC Sector 2002 2007 Net Change (2007 – 2002) 2002 2007 Net Change (2007 – 2002) Point 2.83 3.13 0.30 1.58 1.43 -0.15 Area 0.42 0.43 0.01 4.63 4.39 -0.24 Onroad 7.41 5.38 -2.03 3.26 2.24 -1.02 Nonroad 4.21 3.61 -0.60 3.59 3.15 -0.44 Total 14.87 12.55 -2.32 13.06 11.21 -1.85 Sheboygan County NOx VOC Sector 2002 2007 Net Change (2007 – 2002) 2002 2007 Net Change (2007 – 2002) Point 26.07 12.99 -13.08 2.50 2.26 -0.24 Area 1.00 1.04 0.04 7.59 7.08 -0.51 Onroad 8.25 5.81 -2.44 3.76 2.50 -1.26 Nonroad 4.47 3.73 -0.74 5.62 5.02 -0.60 Total 39.79 23.57 -16.22 19.47 16.86 -2.6118 

### Table 9 shows a substantial decrease in NOx (37 %) and moderate decrease in VOC (16 %) between 2002 and 2007 throughout the ni ne nonattainment counties. Large NOx reductions in the point categor y are due to controls on elect ric generating units in the area. Vehicle fleet turnover also contri buted to NOx and VOC reductions for both the onroad and nonroad emission sectors. Emissi ons have also decreased for the nonroad sector due to various control programs, su ch as the clean air nonroad diesel rule. C. Permanent and Enforceable Control Measures The improvement in air quality can be attr ibutable to a number of regulatory control measures that Wisconsin has implemented in recent years. Air quality in the MilwaukeeRacine 6-County Area and the counties of Door, Manitowoc, and Sheboygan is significantly affected by the transport of oz one from upwind counties. Therefore, in addition to controls implemented in the ar ea, region-wide controls implemented in upwind counties are also relevant to the impr ovement in the air quality in these nine counties. 1. Rate of Progress Plan Areas designated as nonattainment for the 1- hour ozone standard ar e required to reduce VOC emissions 3% per year from “adjusted” 199 0 levels until the areas attain the ozone standard and get reclassified. For severe ozone areas, Rate of Progress (ROP) plans are required to meet milestone years in 1996 (15%), 1999 (24%), 2002 (33%), 2005 (42%) and 2007 (48%). For each milestone plan, an additional 3% reduction must be identified as a contingency measure. A contingency measure is a control option that could be instituted in addition to existi ng air quality control measures. Wisconsin inventoried actual emissions of VO Cs from all stationary, mobile, and area sources and first submitted it as part of its 1992 SIP requirements. In late 1993, Wisconsin submitted a 1996 ROP SIP revision to the U.S. EPA describing actions the state planned to implement to achieve th e 3% annual VOC reductions beginning in 1996, known as the “15% VOC reduction plan.” On March 22, 1996, Wisconsin became the first state to receive U.S. EPA approval of its 15% VOC reduction plan (61 FR 11735). The 1990 level of emissions in the state was 341 tons per day, so the state was required to reduce VOC emissions by 51.2 tons per day, be ginning in 1996. The 1996 plan allocated the reduction as follows: a) 51% (26.3 tons per day) from mobile sources; b) 36% (18.4 tons per day) from area sources; and c) 13% (6.5 tons per day) from industrial sources. Federal programs to reduce VOC emissions in cluded reformulated gasoline, clean fuel fleets, and revised motor vehicle emission standards. Wisconsin program elements included rules defining VOC Reasonably Av ailable Control Technology (RACT) for major sources, enhancement to the vehicle inspection and maintenance (I/M) programs, stage 2 gasoline fuel vapor recovery, solvent limits for various coatin gs applications, and some voluntary industrial solven t regulation enhancements.19 

### In 1997, after an analysis of VOC emissions in the nine county nonattainment area (Door, Kenosha, Manitowoc, Milwaukee, Ozaukee, Racine, Sheboygan, Washington, and Waukesha), Wisconsin sent a letter to U.S. EPA indicating that the state had achieved the required milestone of reducing VOCs by 15% fr om the 1990 base level of emissions. In 1997, Wisconsin submitted a 1999 ROP SIP revision to U.S. EPA describing actions the state planned to begin implementing in 1999 to achieve the required additional 3% annual reduction in VOCs in the state’s six severe nonattainment counties. In the 1999 plan, Wisconsin projected that VOC emission control measures in the 1996 plan, along with additional emission reductions from a dopted federal programs, would be sufficient to reach the 1999 rate-of-progress. In 2000, Wisconsin completed an analysis of emissions that demonstrated that the st ate met the emissions milestone for 1999 of reducing VOC emissions by 9% from 1996 to 1999. In late 2000, Wisconsin included the 2002, 2005 and 2007 ROP SIP revisions with the 1- hour attainment demonstration plan. On October 10, 2001, the U.S. EPA approved the ROP SIP revisions (66 FR 51572). 2. VOC Reasonably Availabl e Control Technology Section 182(b)(2) of the 1990 CAA requires states with moderate nonattainment areas to implement RACT under section 172(c)(1) w ith respect to each of the following: a) each category of VOC sources in the ar ea covered by a CTG document issued by the Administrator between the date of the enactment of the 1990 CAA and the date of attainment b) all VOC sources in the area covered by any CTG issued before the enactment date of the 1990 CAA c) all other major stationary sources of VOCs that are located in the area Wisconsin has adopted and implemented, as a pa rt of its SIP, rule s requiring all existing major stationary sources of VOCs at the 25 ton level in the Milwa ukee-Racine 6-County Area and Sheboygan County to meet RACT. These RACT requirements are contained within chs. NR 419 to 424, Wis. Adm. Code, and apply to sources in categories covered by all applicable CTG and other non-CTG source categories of VOCs. Even though Manitowoc and Door Counties were not design ated as moderate nonattainment areas and are not subject to these requirements, the ch anges are significant because of the large contribution of VOCs from the Milwa ukee-Racine 6-County Area and Sheboygan County. There are certain source categories for which CTG documents exist but for which Wisconsin has no stationary sources. For such categories, Wisconsin submitted negative declarations to U.S. EPA certifying that sources do not exist in Wisconsin for such categories and therefore rules need no t be adopted for those categories.20 

### As noted in subsection 4 below (and Appe ndix 10), Wisconsin has adopted Maximum Achievable Control Technology (MACT) ru les further controlling VOC emissions throughout the state. The Occupational Sa fety and Health Administration (OSHA) enacted rules have also limited VOC emissions in Wisconsin. The cumulative effect of these rules is very effective emissions control of all high-emitting stationary sources of VOC in the area. Thus, Wisconsin has re-examined its VOC RACT rules and determined that it meets the Subpart 2 VOC RACT requirement. VOC RACT rules have been ve ry successful in reducing em issions over the past decades as indicated in Table 10. Note that VOCs and reactive organic gases (ROGs) are nearly identical in definition and phot ochemical function. ROG excludes CFCs and HCFCs.
Table 10: Emissions of Reactive Organic Gases in 9-County Area 1985 & 2005 County 1985 ROG (tons) 2005 ROG (tons) Percent Decrease (%) Door 214.23 105.65 50.7 Kenosha 840.19 534.97 36.3 Manitowoc 470.24 559.20 -18.9 Milwaukee 10,728.51 2,143.25 80.0 Ozaukee 283.69 156.24 44.9 Racine 1,235.84 448.89 63.7 Sheboygan 1,244.94 908.28 27.0 Washington 619.00 222.00 64.1 Waukesha 1,647.31 1,147.63 30.3 Totals 17,283.95 6,226.11 64.0 Source: http://dnr.wi.gov/air/emission/historical_emissions/historical_emissions_rog.htm 

### ROG emissions in the Milwaukee-Racine 6-County Area and th e counties of Door, Manitowoc, and Sheboygan have declin ed by 64% in total between 1985 and 2007. 3. NOx Reasonably Available Control Technology Wisconsin established specific NOx controls as part of the necessary progress plans setting formal maximum NOx budgets within Wisconsin's SIP. These specific controls were implemented in November 2001 in Wis. Admin. Code NR 428. In 2006, Wisconsin started rule making proceedings to implement NOx RACT requirements on major sources in the Milwa ukee-Racine 6-County Area. The emission requirements apply to individua l stationary combustion units at major sources with a compliance date of May 1, 2009. The proposed RACT rule is estimated to achieve reductions of over 29,000 tons per year of NOx emissions from 2002 emission levels. WDNR has updated NR 428 to comply with NOx RACT requirements. WDNR plans to submit this rule prior to, or concurrently with, submittal of this redesignation request.21 

### 4. Measures in addition to Clean Air Act Requirements In anticipation of the need for additi onal reductions beyond CAA requirements, Wisconsin worked with the community to identify and implement additional control measures. Thus, in addition to emission reduc tions that will occur as a result of various federal measures, further reductions in ozone precursor emissions have occurred, or are anticipated to occur, as a result of local and federal control programs. These additional non-voluntary control measures include:

• NOx SIP Call : To address the ozone transport problem, U.S. EPA finalized rulemaking in September 1998 requiring 22 states to reduce NOx emissions within each state to a le vel consistent with a NOx emissions budget identified in the final rule (63 FR 57356). The 22 states were required to submit a revision to their SIP addre ssing the regional transport of ozone, consisting of rules to reduce NOx emissions from electr ic utility boilers, cement kilns, large industrial boilers, and stati onary internal combustion engines. Implementation of the NOx SIP call in states upwi nd from Wisconsin began in May 2004. This rule results in a significant reducti on of NOx emissions th at contribute to ozone concentrations in the Milw aukee-Racine 6-County Area and the counties of Door, Manitowoc, and Sheboygan. Note: Wisconsin was removed from the requirement to implement the NOx SIP as a result of the litigation after the NOx SIP call was finalized.

• Best Available Retrofit Technology (BART) : s. NR 433 affects certain large sources of NOx, SO2, or direct pa rticle pollution th at began operation between 1962 and 1977. The main sources subject to emission reductions are boilers at electric generating power pl ants and pulp and paper facilities.

• Mercury Multipollutant Reduction Alternative : s. NR 446 allows large or small coal-fired electrical generating units the option to reduce NOx, SO2, and mercury by 2015 to the emission limitations listed in s. NR 446.14 instead of the mercury only limitations listed in s. NR 446.12 and 446.13.

• Tier 2 Emission Standards for Vehicles and Gasoline Sulfur Standards : On February 10, 2000, U.S. EPA finalized a federal rule to significantly reduce emissions from cars and light tr ucks, including sport utility vehicles (SUVs). Under this rule, automakers are required to sell lower-emitting cars, and refineries are required to make clean er, lower sulfur gasoline. This rule applies nationwide. The federal rules are being phased in between 2004 and 2009. U.S. EPA has estimated that NOx emission reductions will be approximately 77% for passenger cars, 86% for smaller SUVs, light trucks, and minivans, and 65-95% reductions fo r larger SUVs, vans, and heavier trucks. VOC emission reductions will be approximately 12% for passenger cars, 18% for smaller SUVs, light trucks, and minivans, and 15% for larger SUVs, vans, and heavier trucks.22 

### • Ultra-low Sulfur Diesel Requi rements for Highway Vehicles : Beginning June 1, 2006, refiners started producing dies el fuel for use in highway vehicles with a sulfur content of no more than 15 ppm. At the terminal level, highway diesel fuel sold as low sulfur fuel was required to meet the 15 ppm sulfur standard as of July 15, 2006. For retail st ations and fleets, highway diesel fuel sold as low sulfur fuel met the 15 pp m sulfur standard by October 15, 2006.

• Clean Air Nonroad Diesel Rule : In June 2004, U.S. EPA finalized the Clean Air Nonroad Diesel Rule which requires stringent pollution controls on diesel engines used in industries such as c onstruction, agriculture , and mining that will result in a reduction in NOx emissions. In addition, beginning in 2007, sulfur levels in nonroad diesel fuels were reduced by 99 percent from current levels (from approximately 3,000 ppm now to 15 ppm in 2010). In the case of locomotive and marine diesel fuel, the second step will occur in 2012. The rule also requires engine manufacturers to use advanced clean technologies, similar to catalytic technologies used in passenger cars. New engine standards took effect, based on engine horsepowe r, in 2008. This rule applies nationwide.

• Mobile Sources Air Toxics Rule : In February 2007, U.S. EPA issued a final rule to reduce hazardous air pollutants from mobile sources. Among these requirements in the rule are new standards to reduce non-methane hydrocarbon exhaust emissions from new gasoline-fueled passenger vehicles, more stringent evaporative emissions standards for new passenger vehicles and establishing standards that wi ll limit hydrocarbon emissions that evaporate from and permeate through porta ble fuel containers such as gas cans. These standards have a co -benefit of reduci ng VOC emissions.

• Maximum Achievable Control Technology Standards : Using a technology based approach, the U.S. EPA develops standards for controlling emissions of air toxics from each major type of f acility within an industry group. These standards are based on emission levels that are already being achieved by lower emitting sources in an industr y. For a list of MACT standards implemented in the Milwaukee-Racine 6-County Area and the counties of Door, Manitowoc, and Sheboygan see Appendix 10.

• Stationary Source NOx Control Program (Wis. Adm. Code NR 428) : NR 428 addresses stationary source NOx emissions and is structured to meet ROP emission reduction requirements th rough 2007, the 1-hour ozone standard attainment deadline for the Lake Michig an region. The program encompasses the seven southeast counties of Kenos ha, Milwaukee, Ozaukee, Racine, Sheboygan, Washington, and Waukesha, which are upwind of Manitowoc and Door. It controls NOx for larger ex isting sources and establishes emissions standards for new sources. The existing source control program reduces emissions at electric ut ility facilities and on la rger industrial combustion sources from projected ba seline levels in 2002. The performance standards23 

### for new sources address emission rates from new uncontrolled facilities in the seven counties and for those undergoing major modification. The existing source performance standards aff ect 48 individual units at 21 facilities. This program was targeted to achieve reductions of 30 tons of NOx per day at an average cost of appr oximately $1,000 per ton by the 2003 ozone season. The program was expected to achieve a 55 ton per day reduction by 2007 at an average cost of approximately $1,600 per ton. The program consists of two basic elem ents: 1) ozone season emission limits for electric utility systems comprised of boilers equal to or greater than 500 mmbtu/hr; and 2) Unit-specific requirement s of either emission rate limits or combustion optimization for other large emission sources. WDNR has updated NR 428 to comply with NOx RACT requirements. WDNR plans to submit the rule prior to, or concurrently with, submittal of this redesignation request.

• Clean Air Interstate Rule ( CAIR) (Wis. Adm. Code NR 432) : NR 432 applies to all major electric generati ng units in Wisconsin and in upwind states. Nationwide, CAIR results in a reduction of NOx emissions by 53% by 2009 and 63% by 2015. Sulfur dioxide emissions will be reduced by 45% by 2010 and by 57% by 2015. A rule implementing CAIR in Wisconsin was adopted by the Natural Resources Board. On December 23, 2008, the D.C. Circuit Court decided to remand, rather than vacate, the CAIR rule, thus leaving CAIR in place while U.S. EPA revises the rule. Due to the ongoing litigation involving CAIR, all potential emission re ductions resulting from CAIR have been left out of the em ission projections in Section VI.

• Side Benefits of Control of Hazard ous Pollutants (Wis. Adm. Code NR 445) : NR 445 applies to all stationary air contaminant sources, which may emit hazardous contaminants. Some sources may be exempt from these requirements based on a risk-based thres hold. These controls are expected to result in the reduction of NOx emi ssions from the nonroad stationary reciprocating diesel engines. The re duction is the result of NR 445 requiring affected engines to fire low sulfur on-road fuel beginning in July 2006. NR 445 also includes an incentive to replace old engines with engines that meet Tier 2 or later nonroad standards. This will result in reductio ns of NOx in the Milwaukee-Racine 6-County Area as well as in the counties of Door, Manitowoc, and Sheboygan.

• Local Controls of Traffic Congestion : The Milwaukee-Racine 6-County Area has implemented local controls to decrease the traffic congestion in the city. These voluntary local controls w ill reduce idling times of motor vehicles and thus reduce NOx emissions. The state does not commit to continuing these voluntary programs. Implemented measures include:24 

### • Commuter Value Pass (CVP) & UPASS programs : The CVP transit agency program offers discounted tr ansit passes through large employers, providing a shared cost program betw een employer and employee. The UPASS program involves giving students /staff at area universities 'free' transit passes paid th rough student fees.

• Rideshare : A Wisconsin Department of Transportation interactive webbased ride matching service.

• Advanced Traveler Information Systems : Real-time data from traffic condition cameras is used to provide tr aveler information to the media and motorists. In addition, the live upd ates are communicated to motorists using electronic messaging signs.

• Education/Marketing Promotion : Wisconsin Partners for Clean Air voluntary coalition promoting emi ssion reductions along with an Air Quality Watch & Advisory Program alerting the public to air quality conditions and promoting transportation alternatives.

• Traffic Incident Management : A freeway operational detection and control system with limited use of service patrol vehicles to assist road clearance and motorists. (limited to Kenosha and Racine counties)

• Ramp Metering and High-Occupancy Vehicle Priority : Located on freeway entrance ramps to control the rate of entry and encourage ridesharing and transit use.

• Guaranteed Ride Home (State a nd Milwaukee County Transit System (MCTS)) : Provides transit and vanpool partic ipants a taxi ride in the case of an employee or family member's illness or medical emergency. WisDot also offers reimbursement to employers who offer a guaranteed ride when an unforeseen event occurs.

• Van Pool (State and MCTS) : The State Vanpool provides alternative transportation for commuting to Ma dison from the Milwaukee area.

• Park & Rides : A system of park and ride facilities throughout the area designed for meeting transit and carpools.
5. Controls to Remain in Effect Wisconsin intends to maintain the non-volunt ary control measures listed above after redesignation. Wisconsin hereby commits that any changes to its rules or emission limits applicable to VOC and/or NOx sources, as required for maintenance of the ozone standard in the Milwaukee-Racine 6-County Ar ea or the counties of Door, Manitowoc, or25 

### Sheboygan, will be submitted to U.S. EPA for approval as a SIP revision. Wisconsin, through its Bureau of Air Management, has th e necessary resources to actively enforce any violations of its rules or permit provision s. After redesignation, it intends to continue enforcing all rules that relate to the emissi on of ozone precursors in these nine counties

. 6. New Source Review Provisions Wisconsin has a fully approved New Source Revi ew (NSR) procedure. This is addressed in Wis. Adm. Code NR 405. The rule includes provisions for the Prevention of Significant Deterioration (PSD) in Wis. Ad m. Code NR 405.01. U.S. EPA has approved this program as a part of Wisconsin’s SIP a nd it is applicable to attainment areas in Wisconsin. The review process will be identical to that used for new sources. Any new source or major modification causing significant emissions under Wis. Adm. Code NR 405 will be required to receive an air polluti on control permit and apply Best Available Control Technology (BACT). Significant, as defined in Table A of the chapter, is defined as a net emissions increase or potenti al to emit of any air contaminant above the applicable threshold, including 40 tons/year NOx and 40 tons/year VOC. Any major source that is not listed in the 2005 emi ssion inventory or for which attainment demonstration credit was taken upon closure of the facility will not be allowed to construct, reopen, modify, or reconstruct wi thout meeting any applicable permit rule requirement.UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

QUICKLOOK CRITERIA PARAMETERS
Jan. 7, 2015 Report Request ID: 1283755 Report Code: AMP450

Selection Criteria Page 1 User ID: GHG

State County City Site Parameter POC AQCR UAR CBSA CSA EPA Region 55 117 0006 GEOGRAPHIC SELECTIONS

PROTOCOL SELECTIONS Parameter Classification Parameter Method Duration QUICK LOOK
SELECTED OPTIONS

WORKFILE DELIMITER MERGE PDF FILES EVENTS PROCESSING AGENCY ROLE Option Type Option Value

, YES EXCLUDE REGIONALLY CONCURRED EVENTS

PQAO SORT ORDER

1 2 3 4 5 6 7 Order Column

PARAMETER_CODE STATE_CODE COUNTY_CODE SITE_ID POC DATES EDT_ID
DATE CRITERIA

2014 Start Date End Date 2014 Tribal Code

APPLICABLE STANDARDS Standard Description CO 1-hour 1971 CO 8-hour 1971 Lead 3-Month 2009 Lead 3-Month PM10 Surrogate 2009

NO2 1-hour NO2 Annual 1971 Ozone 1-hour Daily 2005 Ozone 8-Hour 2008 PM10 24-hour 2006 PM25 24-hour 2013 PM25 Annual 2013 SO2 1-hour 2010 SO2 24-hour 1971 SO2 3-hour 1971 SO2 Annual 1971Jan. 7, 2015

Note: The * indicates that the mean does not satisfy summary criteria. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY AIR QUALITY SYSTEM QUICK LOOK REPORT (AMP450)

Page 1 of 3 EXCEPTIONAL DATA TYPES
EDT DESCRIPTION
0 1 2 5 NO EVENTS
EVENTS EXCLUDED
EVENTS INCLUDED
EVENTS WITH CONCURRENCE EXCLUDEDJan. 7, 2015

Note: The * indicates that the mean does not satisfy summary criteria. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY AIR QUALITY SYSTEM QUICK LOOK REPORT (AMP450)

Page 2 of 3 Ozone (44201) Wisconsin Parts per million (007)

SITE ID P

O C PQAO CITY COUNTY ADDRESS YEAR METH VALID DAYS MEAS 1ST

MAX 1-HR CERT and EVAL EDT 55-117-0006 1 1175 Not in a city Sheboygan KOHLER ANDRE PARK, 1520 Beach Park Rd. 2014 087 182 .089 .084 0 2ND MAX 1-HR 1-HOUR NUM DAYS REQ 184 .082 3RD MAX 1-HR .081

4TH MAX 1-HR DAY MAX> STD 0 EST DAYS> STD 0.0 MISS DAYS< STD
2Jan. 7, 2015

Note: The * indicates that the mean does not satisfy summary criteria. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY AIR QUALITY SYSTEM QUICK LOOK REPORT (AMP450)

Page 3 of 3 Ozone (44201) Wisconsin Parts per million (007)

SITE ID P

O C PQAO CITY COUNTY ADDRESS YEAR METH VALID DAYS MEAS 4TH MAX 8-HR CERT

and EVAL EDT 55-117-0006 1 1175 Not in a city Sheboygan KOHLER ANDRE PARK, 1520 Beach Park Rd. 2014 087 .079 .076 0 8-HOUR NUM DAYS REQ 184 .073 .072 DAY MAX> STD 2 180 %OBS 98 1ST MAX 8-HR 2ND

MAX 8-HR 3RD

MAX 8-HRJan. 7, 2015

Note: These reported values do not reflect the combination of 14129 and 85129 and validation substitution tests utilized for Design Value Calculations UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM QUICK LOOK REPORT (AMP450) Lead (TSP) LCJan. 7, 2015

Note: The * indicates that the mean does not satisfy summary criteria. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY AIR QUALITY SYSTEM QUICK LOOK REPORT (AMP450 END)

44201 087 INSTRUMENTAL ULTRA VIOLET ABSORPTION PARAMETER METHOD

CODE COLLECTION METHOD ANALYSIS METHOD METHODS USED IN THIS REPORTJan. 7, 2015

Note: The * indicates that the mean does not satisfy summary criteria. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY AIR QUALITY SYSTEM QUICK LOOK REPORT (AMP450 END)

PQAOS USED IN THIS REPORT

PQAO AGENCY DESCRIPTION 1175 Wisconsin Dept Of Natural Resources, Air Monitoring SectionJan. 7, 2015

Note: The * indicates that the mean does not satisfy summary criteria. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY AIR QUALITY SYSTEM QUICK LOOK REPORT (AMP450 END)

M

N

S

U

X

Y The monitoring organization has revised data from this monitor since the

most recent certification letter received from the state. The certifying agency has submitted the certification letter and required summary reports, but the certifying agency and/or EPA has determined that issues regarding the quality of the ambient concentration data cannot be resolved due to data completeness, the lack of performed quality assurance checks or the results of uncertainty statistics shown in the AMP255 report or the certification and quality assurance report. The certifying agency has submitted the certification letter and required summary reports. A value of "S" conveys no Regional assessment regarding data quality per se. This flag will remain until the Region provides an "N" or "Y" concurrence flag. Uncertified. The certifying agency did not submit a required certification letter and summary reports for this monitor even though the due date has passed, or the state's certification letter specifically did not apply the certification to this monitor. Certification is not required by 40 CFR 58.15 and no conditions apply to be the basis for assigning another flag value The certifying agency has submitted a certification letter, and EPA has no unresolved reservations about data quality (after reviewing the letter, the attached summary reports, the amount of quality assurance data submitted to AQS, the quality statistics, and the highest reported concentrations). MEANING CERTIFICATION EVALUATION AND CONCURRENCE FLAG MEANINGS

FLAGUNITED STATES ENVIRONMENTAL PROTECTION AGENCY

DATA COMPLETENESS REPORT
Jan. 7, 2015 Report Request ID: 1283758 Report Code: AMP430

Selection Criteria Page 1 User ID: GHG

State County City Site Parameter POC AQCR UAR CBSA CSA EPA Region 55 117 0006 GEOGRAPHIC SELECTIONS

PROTOCOL SELECTIONS Parameter Classification Parameter Method Duration
ALL
SELECTED OPTIONS

OZONE EVALUATION MERGE PDF FILES AGENCY ROLE Option Type Option Value SEASONAL-HOURLY YES REPORTING SORT ORDER

1 2 3 4 5 6 7 Order Column

EPA_REGION STATE_CODE MONITOR_TYPE COUNTY_CODE SITE_ID PARAMETER_CODE POC
DATE CRITERIA

2014 Start Date End Date 2014 01 12

Tribal Code

APPLICABLE STANDARDS Standard Description CO 1-hour 1971 Lead 3-Month 2009 Lead 3-Month PM10 Surrogate 2009 Lead Quarterly 1978 NO2 Annual 1971 Ozone 1-hour Daily 2005 PM10 24-hour 2006 PM25 Annual 2013 SO2 1-hour 2010Jan. 7, 2015 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM DATA COMPLETENESS REPORT

Page 1 of 3 MONITORS NOT REPORTINGJan. 7, 2015 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM DATA COMPLETENESS REPORT

Page 2 of 3 DATE RANGE: REGION: (05) CHICAGO

Wisconsin MONITOR TYPE: Wisconsin Dept Of Natural Resources, Air Monitoring Section SLAMS JAN. 01, 2014 DEC. 31, 2014

THRU

SITE ID CITY ADDRESS PARAMETER POC DURATION METHOD ------------------------------- OBSERVATIONS ------------------------------- NUMBER / PERCENT

55-117-0006

55-117-0006

55-117-0006

55-117-0006

55-117-0006

55-117-0006 44201

61101

61102

61103

61104

62101 Ozone

Wind Speed - Scalar

Wind Direction - Scalar

Wind Speed - Resultant

Wind Direction - Resultant

Outdoor Temperature 1

1

1

1

1

1 1

1

1

1

1

1 KOHLER ANDRE PARK, 1520 Beach Park Rd.

KOHLER ANDRE PARK, 1520 Beach Park Rd.

KOHLER ANDRE PARK, 1520 Beach Park Rd.

KOHLER ANDRE PARK, 1520 Beach Park Rd.

KOHLER ANDRE PARK, 1520 Beach Park Rd.

KOHLER ANDRE PARK, 1520 Beach Park Rd. 087

050

050

020

020

040 383

529

529

529 100%

73%

73%

73% 740

742

742

742 99%

100%

100%

100% 718

720

720

720 100%

100%

100%

100% 739

743

743

743 99%

100%

100%

100% 704

711

711

711 95%

96%

96%

96% 712

418

418

275

275

694 99%

92%

92%

95%

95%

96% 358

508

508

508 99%

68%

68%

68% 4354

3863

3863

783

783

4647 99%

61%

61%

31%

31%

53% MONITORS REPORTING

JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC YEAR STATE: REP ORG:Jan. 7, 2015 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM DATA COMPLETENESS REPORT

Page 3 of 3 DATE RANGE: REGION: (05) CHICAGO

Wisconsin

MONITOR TYPE:

Wisconsin Dept Of Natural Resources, Air Monitoring Section SLAMS JAN. 01, 2014 DEC. 31, 2014

THRU

PARAMETER ACTIVE MONITORS # NOT REPORTING # MONITORS > 75% MONITORS AVG COMPLETENESS 44201 61101 61102 61103 61104 62101 Ozone

Wind Speed - Scalar Wind Direction - Scalar Wind Speed - Resultant Wind Direction - Resultant Outdoor Temperature 1 1 1 1 1 1 0 0 0 0 0 0 1 0 0 0 0 0 99.0% 61.0% 61.0% 31.0% 31.0% 53.0% 6 0 1 56.0% 6 0 1 56.0% 6 0 1 56.0% 6 0 1 56.0% 6 0 1 56.0% Wisconsin Dept Of Natural Resources, Air Monit Wisconsin REGION SUMMARY: (05) CHICAGO REPORT SUMMARY: MT SUMMARY: SLAMS REPORT SUMMARY

STATE:

STATE SUMMARY: REP ORG:

RO SUMMARY:UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

CERTIFICATION EVALUATION AND CONCURRENCE
Jan. 7, 2015 Report Request ID: 1283749 Report Code: AMP600

Selection Criteria Page 1 User ID: GHG

State County City Site Parameter POC AQCR UAR CBSA CSA EPA Region 55 117 0006 GEOGRAPHIC SELECTIONS

PROTOCOL SELECTIONS Parameter Classification Parameter Method Duration
CRITERIA
SELECTED OPTIONS

MERGE PDF FILES AGENCY ROLE Option Type Option Value YES CERTIFYING
DATE CRITERIA

2014 Start Date End Date 2014 Tribal CodeJan. 7, 2015 

### Data Evaluation and Concurrence Report Summary

Page 1 of 1 2014 Certification Year: Certifying Agency (CA): Wisconsin Dept Of Natural Resources, Air Monitoring Section (1175) Pollutants in Report:

PQAO Parameter Code Ozone 44201 Parameter Name Code 1

1175 Wisconsin Dept Of Natural Resources, Air Monitoring Section PQAO Code

AQS Site-ID POC AQS

Recommended Flag Cert. Agency

Recommended Flag Reason for AQS Recommendation Signature of Monitoring Organization Representative: ________________________________________________________ PQAO Name Summary of 'N' flags for all pollutants: 1 0 PQAOs in Report:

04/26/12 TSA Date Monitors Evaluated Monitors Recommended for

Concurrence by AQS Monitors NOT Recommended for Concurrence by AQS

## Data Evaluation and Concurrence Report for Gaseous Pollutants 2014 Certifying Year Certifying Agency Code Wisconsin Dept Of Natural Resources, Air Monitoring Section (1175) Ozone (44201) (ppm) Wisconsin Dept Of Natural Resources, Air Monitoring Section (1175) PQAO Name 10/01/2009 QAPP Approval Date

1 55-117-0006 SLAMS 0.049 Mean
0.018

Min
0.089 Max
0 Exceed. Count 0

Outlier Count 99 Perc. Comp. 0.68

Precision
+/-0.53

Bias
100 Complete
100 Complete
- 1.15

Bias
Y PQAO Level Criteria Y Aqs Rec Flag CA Rec

Flag Epa Concur 

### Parameter

8 Y Number of Valid Audits NPAP Bias Criteria Met NPAP Audit Summary: 1.18056

1.84 Routine Data One Point Quality Check Annual PE NPAP Concur. Flag AQS Site ID POC Monitor

Type Bias QAPP Appr. Y

## Data Evaluation and Concurrence Report for Particulate Matter

## Data Concurrence and Evaluation Report for Lead