RICK SNYDER

GOVERNOR

STATE OF MICHIGAN

DEPARTMENT OF ENVIRONMENTAL QUALITY

LANSING

July 5,2011

DE...'1

DAN WYANT

DIRECTOR

Ms. Susan Hedman, Regional Administrator

U.S. Environmental Protection Agency

Region 5

77 West Jackson Boulevard (R-19J)

Chicago, Illinois 60604-3507

Dear Ms. Hedman:

The Michigan Department of Environmental Quality (MDEQ) submits this request in support of a

redesignation to attainment of the 15 ug/m3 annual and 35 ug/m3 daily fine particulate matter

National Ambient Air Quality Standards for seven southeast Michigan counties (Livingston,

Macomb, Monroe, Oakland, SI. Clair, Washtenaw and Wayne), and a proposed revision to the

Michigan State Implementation Plan.

The MDEQ requests that the U.S. Environmental Protection Agency (U.S. EPA) proceed with

final review and approval of this attainment redesignation. If you have any questions or need

additional information, please contact Mr. G. Vinson Hellwig, Chief, Air Quality Division, at

517-373-7069, hellwigv@michigan.gov; or you may contact me.

0,"

Director

Wyao'turd

517-373-7917

Enclosure

cc: Governor Rick Snyder

Ms. Cheryl Newton, U.S. EPA, Region 5

Mr. John Summerhays, U.S. EPA, Region 5

Mr. Andrew Chang, U.S. EPA, Region 5

Mr. Chuck Hersey, SEMCOG

Mr. Jim Sygo, Deputy Director, MDEQ

Mr. G. Vinson Hellwig, MDEQ

Mr. Robert Irvine, MDEQ

Ms. Cindy Hodges, MDEQ

CONSTITUTION HALL· 525 WEST ALLEGAN STREET· P.O. BOX 30473 • LANSING, MICHIGAN 48909-7973

WNW,mlchlgan.gov/deq • (800) 662-9278
Proposed Revision to Michigan’s State Implementation Plan for 

Achieving the Particulate Matter less than 2.5 microns in diameter 

National Ambient Air Quality Standard (NAAQS) 

Request to Redesignate to Attainment Status 

For Both the Annual and 24-Hour PM2.5 NAAQS

Southeast Michigan Counties of 

Livingston, Macomb, Monroe, Oakland, 

St. Clair, Washtenaw, and Wayne 

and 

Proposed Maintenance Plan for Southeast Michigan 

July 5, 2011 

Michigan Department of Environmental Quality 

Air Quality Division 
Table of Contents 

1. Introduction........................................................................................................... 1 

2. Redesignation Package Components .................................................................. 3 

3. Demonstration of Attainment of the Standard....................................................... 4 

4. State Implementation Plan Approval and Compliance with Clean Air Act and 

Part D Requirements .......................................................................................... 10 

5. Demonstration of Improvement in Air Quality ..................................................... 11 

6. Weight of Evidence for Fine Particulate Matter................................................... 17 

6.1. PM2.5 Composition.............................................................................................. 18 

6.2. PM2.5 Sources..................................................................................................... 20 

6.3. Requirements for Permanent, Quantifiable Reductions...................................... 21 

6.4. Stationary Source Facility Details....................................................................... 22 

6.5. Other Source Categories.................................................................................... 24 

6.6. Trends Analysis.................................................................................................. 24 

7. Maintenance Plan............................................................................................... 36 

8. Transportation Conformity Budgets.................................................................... 40 

9. Public Participation and Comments.................................................................... 43 

List of Tables 

Table 1. National Ambient Air Quality Standards for Fine Particles. ............................... 1 

Table 2. Southeast Michigan 2007-2010 Monitor Data Design Value for Annual PM2.5

NAAQS................................................................................................................. 5 

Table 3. Southeast Michigan 2007-2010 Monitor Data Design Value for Daily PM2.5

NAAQS................................................................................................................. 6 

Table 4. Percent Data Completeness per Quarter for 2007-2010. .................................. 9 

Table 5. Southeast Michigan Emission Reduction Demonstration Inventories for 2005 

and 2008 for Annual PM2.5.................................................................................. 11 

Table 6. Southeast Michigan Emission Reduction Demonstration Inventories for 2005 

and 2008 for Daily PM2.5..................................................................................... 12 

Table 7. List of Sources that have Gone Out of Business in Wayne County, Michigan 

between 2005 and 2008 and Their Emissions.................................................... 13 

Table 8. Period Average Contribution to PM2.5 for the Southwest Sector at Dearborn.. 30 

Table 9. Individual-Site (I) and Multi-Site (M) PMF-Resolved Factors for Allen Park and 

Dearborn.. .......................................................................................................... 31 

Table 10. Maintenance Plan Emission Inventories for annual PM2.5, 2008-2022.. ....... 37 

Table 11. Maintenance Plan Emission Inventories for Daily PM2.5, 2008-2022............ 37 

Table 12. Motor Vehicle Emissions Budget Calculation for Livingston, Macomb, Monroe, 

Oakland, St. Clair, Washtenaw, and Wayne Counties........................................ 41 

Table 13. Final Motor Vehicle Emissions Budgets for Annual PM2.5 ............................. 42 

Table 14. Final Motor Vehicle Emissions Budgets for Daily PM2.5................................. 42 
List of Figures 

Figure 1. Southeast Michigan Counties for PM2.5 Attainment Redesignation.................. 2 

Figure 2. Locations of PM2.5 Monitors. ............................................................................ 4 

Figure 3. Historic Annual PM2.5 Design Values. .............................................................. 7 

Figure 4. Historic Daily PM2.5 Design Values. ................................................................. 8 

Figure 5. CART Index of PM2.5 Conduciveness in Detroit. ............................................ 15 

Figure 6. Tendency to Generate Elevated PM2.5. Number of Elevated Days/Number of 

Conducive Days,. ............................................................................................... 16 

Figure 7. Average PM2.5 Composition for Dearborn and Allen Park.............................. 18 

Figure 8. Average PM2.5 Species Composition by Site for Three Multi-Year Periods.... 19 

Figure 9. The Urban Excess by Species in Detroit for Three Multi-Year Periods. ......... 21 

Figure 10. Map of Emission Sources Near the Dearborn Monitor. ................................ 23 

Figure 11. Annual Average of Annual PM2.5.................................................................. 25 

Figure 12. 98th Percentile Concentration of Daily PM2.5. ............................................... 26 

Figure 13. The Average PM2.5 Species Composition per Site by Year.......................... 27 

Figure 14. The Iron Component of Soil (or Crustal) PM2.5............................................ 28 

Figure 15. Local PM Excess at the Dearborn Monitor................................................... 29 

Figure 16. Wind Roses of Highest Factor Contribution Days Resolved by PMF at Allen 

Park and Dearborn for Industrial Zinc and Steel (Manganese)........................... 30 

Figure 17. Non-Parametric Wind Regression (NWR) on the Excess Species 

Concentrations at Dearborn Compared with Allen Park. .................................... 32 

Figure 18. Average Concentration of Organic Matter by PMF Factor by Site for All Data.

........................................................................................................................... 33 

Figure 19. CMB Source Apportionment of Carbon Mass for Detroit.............................. 33 

Figure 20. Changes in Southeast Michigan Employment and Travel, 2002-2009......... 34 

 

Appendices

 Appendix A – Annual and Daily PM2.5 Monitoring Data 

 Appendix B -- Emission Inventory Methodology 

Appendix C – PM2.5 Redesignation Inventory On-road Mobile Emissions 

Appendix D – Stationary Source Facility Details 

 Appendix E -- Impact of Southeast Michigan’s New Economic Reality 

on Regional Pollutant Emissions 

Appendix F – Public Participation Documentation 
Michigan Department of Environmental Quality 

Proposed Request to Redesignate Southeast Michigan Counties 

July 2011 

Page 1

1. Introduction 

The State of Michigan, through the Michigan Department of Environmental Quality 

(MDEQ), requests the U.S. Environmental Protection Agency (EPA) make a 

determination that Southeast Michigan is in attainment with the Particulate Matter less 

than 2.5 microns in diameter (PM2.5) National Ambient Air Quality Standards (NAAQS), 

to change the legal status of the area from nonattainment to attainment, and to approve 

the maintenance plan as a revision to the Michigan State Implementation Plan (SIP). 

The seven counties in the Southeast Michigan PM2.5 nonattainment area are Livingston, 

Macomb, Monroe, Oakland, St. Clair, Washtenaw, and Wayne, shown in Figure 1. 

 

The EPA established the NAAQS for fine particulate matter, the annual and daily PM2.5

standard, in 1997 (See Table 1). The EPA designated areas in Michigan as attainment 

or nonattainment of the annual standard in January 2005. The designations were 

based on design values derived from air quality monitoring data for the years 2001-

2003. Annual averages over 15 micrograms per cubic meter (μg/m3) and daily 

standards over 65 μg/m3 were considered to be violating the standard, too high to be 

protective of health. The EPA designated seven counties in Michigan as nonattainment 

for the annual standard. 

 

The EPA revised the NAAQS for PM2.5, for the daily standard, in 2006. While the 

annual standard was maintained at 15 μg/m3, the daily standard was reduced to 35 

μg/m3

. (See Table 1) 

The EPA designated areas in Michigan as attainment or nonattainment of the 2006 

PM2.5 standards in November 2009. The designations were based on design values 

derived from air quality monitoring data for the years 2006-2008. Daily values over 

35 μg/m3 were considered to be violating the standard, too high to be protective of 

health. The EPA designated seven counties in Michigan as nonattainment for the 

annual and daily standards.

Table 1. National Ambient Air Quality Standards for Fine Particles. 

Annual 24-Hour 

1997 Fine Particles 

Standards (PM2.5) 

15 μg/m3

Annual arithmetic mean, 

averaged over three 

years 

65 μg/m3

24-hour average, 98th

percentile, averaged over 

three years 

2006 Fine Particles 

Standards (PM2.5) 

15 μg/m3

Annual arithmetic mean, 

averaged over three 

years 

35 μg/m3

24-hour average, 98th

percentile, averaged over 

three years 
Michigan Department of Environmental Quality 

Proposed Request to Redesignate Southeast Michigan Counties 

July 2011 

Page 2

Air quality monitoring data collected in the 2007-2010 period showed all seven counties 

in Southeast Michigan in attainment for the PM2.5 annual and daily NAAQS. 

Figure 1. Southeast Michigan Counties for PM2.5 Attainment Redesignation 

Livingston, Macomb, Monroe, Oakland, St. Clair, Washtenaw, and Wayne. 
Michigan Department of Environmental Quality 

Proposed Request to Redesignate Southeast Michigan Counties 

July 2011 

Page 3

2. Redesignation Package Components 

Section 107 of the federal Clean Air Act (CAA) establishes requirements to be met in 

order for an area to be qualified for redesignation to attainment, including: 

• A determination that the area has attained the NAAQS; 

• An approved SIP for the area under Section 110 (k) of the CAA; 

• A determination that the improvement in air quality is due to permanent and 

enforceable reductions in emissions resulting from implementation of the SIP and 

applicable federal requirements; 

• A fully approved maintenance plan under Section 175A of the CAA; and 

• A determination that all Section 110 and Part D requirements under the CAA 

have been met. 

This document summarizes compliance with each required component of an attainment 

redesignation. 
Michigan Department of Environmental Quality 

Proposed Request to Redesignate Southeast Michigan Counties 

July 2011 

Page 4

3. Demonstration of Attainment of the Standard 

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 reviews to the EPA Region 5 annually to ensure 

that air monitoring operations comply with all applicable federal requirements. Figure 2 

shows the locations of PM2.5 monitors in Southeast Michigan. 

 

Figure 2. Locations of PM2.5 Monitors. 

Oak Park

Ypsilanti

Luna Pier

New Haven

Port Huron

Livonia

Newberry

E. Seven Mile

W. Lafayette

Linwood

Dearborn

Allen Park

SWHS

Wyandotte

Data from air quality monitors indicates whether or not violations of the PM2.5 NAAQS 

are occurring. The monitoring site design value (DV) for the annual average is the 

three-year average of the annual averages, based on data from each of the monitoring 

sites. For the period 2008-2010, the design value is less than 15 μg/m3 for the 

Southeast Michigan area. The DV for the daily standard at each site is the three-year 

average of the 98 percentile concentration of the 24-hour average values, based on 

data from each of the monitoring sites. For the period 2008-2010, the design value is 

less than 35 μg/m3

 for the Southeast Michigan area. Table 2 shows the design values, 
Michigan Department of Environmental Quality 

Proposed Request to Redesignate Southeast Michigan Counties 

July 2011 

Page 5

confirming attainment of the annual NAAQS. Table 3 shows the design values, 

confirming attainment of the daily NAAQS. 

Table 2. Southeast Michigan 2007-2010 Monitor Data Design Value for Annual PM2.5

NAAQS. In Microgram Per Cubic Meter. 

 Annual Average 3-year Average 

County Monitor 2007 2008 2009 2010 2007-2009 2008-2010 

Macomb 

New Haven 

260990009 

11.94 10.66 9.49 8.92 10.7 9.7 

Monroe 

Luna Pier 

261150005 

13.08 11.36 10.33 9.36 11.6 10.4 

Oakland 

Oak Park 

261250001 

13.33 10.86 10.03 9.12 11.4 10.0 

St. Clair 

Port Huron 

261470005 

12.44 11.08 9.74 8.94 11.1 9.9 

Washtenaw 

Ypsilanti 

261610008 

12.98 10.91 9.94 9.24 11.3 10.0 

Allen Park 

261630001 

12.76 11.83 11.06 10.23 11.9 11.0 

Dearborn 

261630033 

16.89 13.34 12.07 11.33 14.1 12.2 

E 7 Mile 

261630019 

13.01 11.33 10.54 9.89 11.6 10.6 

FIA 

261630039 

13.83 12.23 10.70 10.05 12.3 11.0 

Linwood 

261630016 

13.86 11.94 10.36 9.85 12.1 10.7 

Livonia 

261630025 

12.75 11.01 9.88 9.10 11.2 10.0 

Newberry 

261630038 

14.02 11.81 10.17 10.04 12.0 10.7 

SW HS 

261630015 

14.54 12.85 11.12 10.67 12.8 11.5 

Wayne 

Wyandotte 

261630036 

13.45 10.94 10.36 9.36 11.6 10.2 
Michigan Department of Environmental Quality 

Proposed Request to Redesignate Southeast Michigan Counties 

July 2011 

Page 6

Table 3. Southeast Michigan 2007-2010 Monitor Data Design Value for Daily PM2.5

NAAQS. In Microgram Per Cubic Meter.

 Daily 98th Percentile 3-year Average 

County Monitor 2007 2008 2009 2010 2007-2009 2008-2010 

Macomb 

New 

Haven 

260990009 

29.0 28.9 26.2 25.5 28 27 

Monroe 

Luna Pier 

261150005 

32.2 28.6 23.6 26.3 28 26 

Oakland 

Oak Park 

261250001 

35.3 30.4 30.1 27.1 32 29 

St. Clair 

Port Huron 

261470005 

36.3 31.0 29.9 25.8 32 29 

Washtenaw 

Ypsilanti 

261610008 

34.5 28.2 28.2 23.3 30 27 

Allen Park 

261630001 

31.0 30.3 29.2 27.8 30 29 

Dearborn 

261630033 

36.6 31.7 35.7 28.6 35 32 

E 7 Mile 

261630019 

31.9 31.9 29.2 28.6 31 30 

FIA 

261630039 

34.8 31.7 31.7 27.7 33 30 

Linwood 

261630016 

34.3 30.0 31.0 27.9 32 30 

Livonia 

261630025 

32.8 28.3 29.3 25.3 30 28 

Newberry 

261630038 

33.4 31.5 25.9 30.4 30 29 

SW HS 

261630015 

34.0 34.3 30.9 26.6 33 31 

Wayne 

Wyandotte 

261630036 

28.6 26.3 26.9 24.4 27 26 

Figure 3. Historic Annual PM2.5 Design Values. shows historic annual 3-year average 

design values at each site in the area to be redesignated. The data shows a strong and 
Michigan Department of Environmental Quality 

Proposed Request to Redesignate Southeast Michigan Counties 

July 2011 

Page 7

steady decline in annual PM2.5 concentrations in the region. This decline is consistent 

with the decline in emissions experienced over this time period due to control measures 

enacted at both the national and local level. Appendix A contains a table of the historical 

annual PM2.5 values by quarter and year. 

Figure 3. Historic Annual PM2.5 Design Values. 

3-Year Annual Average PM2.5 in Southeast Michigan

8

10

12

14

16

18

20

22

99-01 00-02 01-03 02-04 03-05 04-06 05-07 06-08 07-09 08-10

Concentration (ug/m3)

Dearborn SW HS Wyandotte Allen Park Linwood 

Luna Pier E 7 Mile Oak Park Ypsilanti Livonia

Port Huron New Haven Newberry FIA

Annual Standard 

15 ug/m3

Figure 4 shows historic daily 3-year average design values for the 98% concentrations 

at each site in the area to be redesignated. The data show a significant drop in 

emissions since 2005 with the end result being all monitors in compliance with the 24-

hour PM2.5 NAAQS. Appendix A also contains a table of the historical daily PM2.5

values. 
Michigan Department of Environmental Quality 

Proposed Request to Redesignate Southeast Michigan Counties 

July 2011 

Page 8

 

Figure 4. Historic Daily PM2.5 Design Values. 

3-Year Average of 98th Percentile Daily Concentration

25

30

35

40

45

50

99-01 00-02 01-03 02-04 03-05 04-06 05-07 06-08 07-09 08-10

Concentration (ug/m3)

New Haven Luna Pier Oak Park Port Huron Ypsilanti

Allen Park SW High Sch. Linwood E 7 Mile Livonia

Dearborn Wyandotte Newberry FIA/Lafayette

Daily Standard 

35 ug/m3

State and local air monitoring data is submitted to EPA’s monitoring data repository 

called the Air Quality System (AQS). All data in the AQS has been quality assured, 

meeting the requirements specified in Title 40 of the Code of Federal Regulations Part 

58 Appendix A. The completeness criteria for ambient monitoring data are specified in

40 CFR, Part 50, National Primary and Secondary Ambient Air Quality Standards, 

Appendix N. A minimum completeness of 75 percent per quarter for each year period is 

required at each monitoring site. Data completeness information is presented in Table

4. All monitors in Southeast Michigan meet the completeness criteria. 
Michigan Department of Environmental Quality 

Proposed Request to Redesignate Southeast Michigan Counties July 2011 

Page 9

Table 4. Percent Data Completeness per Quarter for 2007-2010. 

Monitor 

2007 

Q1

2007 

Q2

2007 

Q3

2007 

Q4

2008 

Q1

2008 

Q2

2008 

Q3

2008 

Q4

2009 

Q1

2009 

Q2

2009 

Q3

2009 

Q4

2010 

Q1

2010 

Q2

2010 

Q3

2010 

Q4

New 

Haven 

260990009 97 97 87 97 97 90 97 100 93 97 100 87 100 100 100 100 

Luna Pier 

261150005 97 87 94 100 100 100 94 90 97 97 97 87 100 97 100 94 

Oak Park 

261250001 100 93 97 100 97 93 97 100 100 97 90 100 97 100 97 94 

Port Huron 

261470005 97 93 97 97 97 97 97 97 90 100 97 97 93 100 97 100 

Ypsilanti 

261610008 90 90 97 100 90 100 100 97 97 97 100 100 97 93 100 97 

Allen Park 

261630001 96 97 93 100 97 99 93 95 93 98 92 93 89 96 91 90 

SW HS 

261630015 93 100 87 97 100 100 100 97 100 90 100 94 100 100 97 97 

Linwood 

261630016 87 87 97 97 94 100 94 100 90 87 87 100 87 93 100 97 

E 7 Mile 

261630019 100 93 100 90 97 100 81 100 100 100 97 90 100 77 84 94 

Livonia 

261630025 87 100 100 90 87 97 100 97 97 100 93 90 93 97 87 97 

Dearborn 

261630033 97 97 94 90 100 93 97 100 90 100 93 100 90 100 97 100 

Wyandotte 

261630036 97 93 97 97 100 97 97 100 93 97 93 77 77 97 94 100 

Newberry 

261630038 87 90 87 100 94 97 87 93 83 94 90 94 90 100 100 97 

FIA 

261630039 97 100 97 93 97 93 94 97 97 100 100 91 92 98 83 91 
Page 10

4. State Implementation Plan Approval and Compliance with Clean Air Act 

(CAA) Section 110 and Part D Requirements 

The Southeast Michigan area is classified as a PM2.5 nonattainment area under 

Part D, Subpart 1 of the CAA. Section 110 of the CAA delineates general SIP 

requirements and Part D contains requirements specific to nonattainment areas. 

Southeast Michigan meets all applicable requirements for PM2.5 redesignation under 

these provisions. 

Southeast Michigan was originally classified as a nonattainment area under the 1997 

annual PM2.5 NAAQS. The EPA strengthened the daily standard in 2006 and 

Southeast Michigan was then classified as nonattainment for the daily PM2.5 NAAQS 

as well. 

Michigan’s SIP was submitted to EPA in May 2008 and contains all required emission 

control programs related to PM2.5 under Section 110 of the CAA. Programs for 

emissions limitations, permitting, emission inventories and statements, emission fees, 

enforcement authorities, and ambient monitoring have been implemented in Michigan 

and are included in the SIP. 
Michigan Department of Environmental Quality 

Proposed Request to Redesignate Southeast Michigan Counties 

July 2011 

Page 11

5. Demonstration of Improvement in Air Quality 

Improvement in air quality must be reasonably attributed to emissions reductions of 

primary PM2.5 and the PM2.5 precursor pollutants nitrogen oxides (NOX) and sulfur 

dioxide (SO2) that are permanent and enforceable. An examination of primary PM2.5, 

NOX and SO2 emissions from a period of nonattainment (2005) to attainment (2008) 

shows a decline in overall emissions during this time period. The source of the 

emissions data is the MDEQ 2005 (base M) and 2008 (base B) emissions inventory 

processed by the Lake Michigan Air Directors Consortium (LADCO) to yield annual 

and winter day nonattainment area (NAA) totals. The on-road emissions were 

calculated by the Southeast Michigan Council of Governments (SEMCOG) using the 

2010a version of the Motor Vehicle Emission Simulator model. Non-road emissions 

estimates were obtained using EPA’s National Mobile Inventory Model. Details 

regarding this data are included in Appendices A and B. 

Table 5 and Table 6 identify emission reductions by source category for the 

Southeast Michigan NAA. While SO2 emissions increased slightly over this 3-year 

period, both NOX, and PM2.5 emissions decreased by more than 10 percent. All 

pollutant emissions decreased for the marine, airports and railroad category (MAR) 

and on-road mobile sources. All pollutant emissions increased for the electric 

generating unit (EGU) sources. 

 

Table 5. Southeast Michigan Emission Reduction Demonstration Inventories for 2005 

and 2008 for Annual PM2.5. All units are in tons per year. 

 NOx SO2 PM2.5

 2005 2008 2005 2008 2005 2008 

EGU 69,756.71 70,008.00 227,751.98 233,870.64 1,105.51 1,375.31

NON-EGU 18,684.20 18,817.18 16,240.13 19,793.49 2,454.95 1,605.72

Area 15,949.68 17,157.57 4,629.99 5,702.94 5,456.25 5,406.06

Non-road 28,829.50 24,065.61 2,739.34 426.61 2,203.67 1,773.31

MAR 7,380.89 6,380.17 681.42 588.82 193.09 165.62

On-road 154,294.00 119,194.00 3,809.00 1,066.00 5,323.00 4,360.00

Total 294,894.98 255,622.53 253,108.86 261,447.50 16,736.47 14,686.02
Michigan Department of Environmental Quality 

Proposed Request to Redesignate Southeast Michigan Counties 

July 2011 

Page 12

Table 6. Southeast Michigan Emission Reduction Demonstration Inventories for 2005 

and 2008 for Daily PM2.5. All units are in tons per winter day. 

 NOx SO2 PM2.5

 2005 2008 2005 2008 2005 2008 

EGU 217.63 220.95 636.63 682.05 2.90 2.91 

NON-EGU 51.51 49.76 44.06 51.33 6.61 3.98 

Area 81.73 80.58 16.08 16.46 25.21 15.46 

Non-road 54.99 47.82 4.61 0.81 4.16 3.70 

MAR 20.97 19.80 2.85 1.75 0.52 0.50 

On-road 461.20 366.20 8.60 3.10 19.20 15.70 

Total 887.63 785.11 712.83 755.50 58.60 42.25 

Reductions in emissions between 2005 and 2008 can be attributed to the 

combination of local and national control programs contained in the PM2.5 SIP for 

Southeast Michigan. This SIP, submitted in May 2008 included targeted reductions 

in the industrialized area of Detroit as well as federal emissions controls that were 

being phased in for both stationary and mobile sources. The significant emission 

reductions these measures produced have brought all monitors in Southeast 

Michigan into compliance with both the annual and 24-hour PM2.5 NAAQS. 

Point Sources

Companies in the nonattainment area have made significant emissions reductions 

that are permanent and enforceable. Additional detail on all of these companies can 

be found in Appendix D. 

One source that has made significant reductions is the Severstal steel mill located 

less than one mile southwest of the Dearborn monitor. Appendix D gives detailed 

information about this point source. Based on the MDEQ’s permit #182-05B for 

Severstal, baghouses were installed for their Basic Oxygen Furnace and Blast 

Furnace C and began operation in 2007. Severstal’s Blast Furnace B is currently 

shutdown, but will have a baghouse installed when it restarts. In addition, torch 

cutting is no longer permitted on site, scarfing operations reduced their opacity and 

torpedo cars were required to reduce smoking. This source was also subject to 

Maximum Achievable Control Technology (MACT) Subpart FFFFF for integrated iron 

and steel mills. Total emissions reductions were 147 tons of PM2.5. 

Another large source in the area is US Steel. US Steel upgraded a baghouse on 

their Blast Furnace B in September 2005, which reduced particulate emissions by 76 

tons per year (Consent Order 1-2005). In addition this facility is subject to MACT 

Subpart FFFFF for integrated iron and steel mills and Subpart CCCCC for coke oven: 

pushing, quenching and battery stacks. 
Michigan Department of Environmental Quality 

Proposed Request to Redesignate Southeast Michigan Counties 

July 2011 

Page 13

The Ford Motor Company-Rouge Complex, located in the area, is a major volatile 

organic compound (VOC) source, but has some NOX emissions as well. This source 

is subject to two MACTs: Subpart IIII for surface coatings of automobiles and light 

duty trucks as well as Subpart MMMM for surface coating of miscellaneous metal 

parts and products. 

The Marathon-Ashland Petroleum Refinery is subject to several MACT and New 

Source Performance Standards as detailed in their Renewable Operating Permit 

#199700013. 

Dearborn Industrial Generation is a large source that burns blast furnace gas from 

Severstal to supply energy to Severstal. This source is subject to the Acid Rain 

Program and the NOX SIP Call. 

In addition to these permanent and enforceable emission reductions from the large 

companies around the Dearborn monitor, permanent and enforceable reductions 

have occurred from several facilities in Wayne County that have shut down. Table 7 

shows the companies as well as the emissions changes from 2005 to 2008. 

Table 7. List of Sources that have Gone Out of Business in Wayne County, Michigan 

between 2005 and 2008 and Their Emissions. 

2005 2008 

Facility Name SRN 

Last Year 

Reported

Permit 

voided? NOx PM10 PM2.5SO2 VOC NOx PM10 PM2.5SO2 VOC

Ajax Materials 

Corporation M4601 2007 yes 8.4 3.1 - 4.4 4.3 -- -- -- -- -- 

Edison Energy 

Services M4848 2007 yes -- 0.0 -- -- -- -- -- -- -- -- 

Ferrous 

Environmental M4798 2007 -- 5.5 -- -- -- -- -- -- -- -- 

Spartan Industrial M3066 2007 -- -- -- -- 8.9 -- -- -- -- -- 

Great Lakes 

Petroleum 

Terminal, LLC 

B4752 2007 yes 

14.3 0.5 0.5 31.1 34.1 -- -- -- -- -- 

Arkema, Inc* B2173 2009 yes 89.0 3.8 3.8 0.3 13.3 35.8 1.5 1.5 0.1 7.9

M-Lok, Inc** A8196 2008 Yes -- -- -- -- 26.8 -- -- -- -- 16.0 

*Arkema, Inc completely closed in 2009. 

** M-Lok, Inc. closed in the summer of 2008. 

Mobile Sources

In addition to these local stationary source controls, the Federal Motor Vehicle 

Control Program has produced significant emission reductions from on-road and nonroad motor vehicles throughout the country. Phase-in of federal “Tier 2” emissions 
Michigan Department of Environmental Quality 

Proposed Request to Redesignate Southeast Michigan Counties 

July 2011 

Page 14

standards began in 2004, affecting light-duty passenger vehicles, including sport 

utility vehicles, minivans, and pickup trucks. In 2004, a requirement for lower sulfur 

gasoline began phasing in, and in 2006, a similar requirement for ultra low sulfur 

diesel fuel took effect. All of these controls contributed to a significant reduction in 

mobile source emissions of PM2.5, NOX and SO2. These reductions are permanent 

and enforceable and have contributed to the overall improvement in PM2.5 levels in 

Southeast Michigan. 

In addition to federal mobile controls, several voluntary mobile control measures have 

occurred in the Detroit area. The Diesel Emissions Reduction Act (DERA) Grant 

projects have provided partial funding to retrofit 39 school buses with Diesel 

Oxidation Catalysts in 2005. An additional 160 Detroit Public School buses have or 

will be retrofitted in 2010 and 2011. DERA Grants have also provided for several 

other diesel emission reductions on marine and off-road equipment and heavy duty 

diesel trucks in 2008 and 2009. 

Four switch yard trains at the CSX rail yard by Severstal Steel were rebuilt using 

money mainly from the Federal Congestion Mitigation and Air Quality Improvement 

Funding. These rebuilds were expected to reduce emissions of NOX by 66 ton per 

year and particulate matter (PM) by 1.8 tons per year. Financed by Chrysler’s 

Supplemental Environmental Project, 28 trains were retrofitted with anti-idling 

technology in the US Steel Delray Connecting Railroad Company and Norfolk 

Southern Railroad/Consolidated Rail. This anti-idling technology was calculated to 

reduce NOX emissions by 29 tons per year, and PM emissions by 1.3 tons per year. 

Meteorological Conduciveness

Actual PM2.5 levels adjusted for meteorological conduciveness are another indicator 

of overall improvement in air quality. PM2.5 trend analysis is complicated by the 

dependence of PM2.5 formation on meteorology, including wind direction, wind speed, 

pressure, and temperature changes. To more accurately discern trends in PM2.5

concentrations, the data can be adjusted to remove the impact from meteorological 

confounders. LADCO used a statistical technique, called Classification and 

Regression Tree (CART) analysis, to partition PM2.5 values into various categories of 

PM2.5 conducive meteorology. This determined the PM2.5-forming potential of each 

year’s meteorology.1 Metrological and monitoring data from five monitors in Detroit 

and Down River areas of Wayne County. Figure 5 shows that the years 2001, 2002, 

2003, 2005, 2007, and 2008 were more conducive for PM2.5 formation than the 

average. 

 

1

 Kenski, Donna, Air Quality Overview, Lake Michigan Air Directors Consortium, Project Team 

Meeting, September 22-23, 2010 
Michigan Department of Environmental Quality 

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July 2011 

Page 15

Figure 5. CART Index of PM2.5 Conduciveness in Detroit. 

-0.8

-0.6

-0.4

-0.2

0

0.2

0.4

0.6

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Condusivenss Index

Index represents fraction of PM2.5 conducive days in each year, above or below the 1999-2009 average. 

1=twice as many days as average, -1=half as many days as average year. 

The MDEQ divided the number of days in which daily PM2.5 values were elevated 

(above 25 μg/m3

) at ambient air quality monitors by the number of days with 

conducive meteorology. The ratios were converted to percentages to increase 

clarity. Because there is year-to-year fluctuation, an average of the percent of high 

PM2.5 days over three years was calculated. This removed some of the uncertainty 

inherent in the yearly results. Figure 6 shows that during the period 1999 to 2004, 

over 60 percent of PM2.5 conducive days experienced elevated PM2.5 levels, but 

during the period 2008-2009, the percentage drops to 31. 
Michigan Department of Environmental Quality 

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Figure 6. Tendency to Generate Elevated PM2.5. Number of Elevated Days/Number 

of Conducive Days, Converted to Percent. 

Tendency to Generate Elevated PM2.5 (>25 ug/m3)

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

PM2.5 concentrations in 2007-08 were moderate despite better than average PM2.5-

conducive meteorology. The CART analysis and the number of high PM2.5

concentrations on meteorologically conducive days reinforces the demonstration that 

reductions in primary PM2.5 and PM2.5 precursor emissions have led to the actual 

improvements in air quality, rather than less conducive meteorology. 
Michigan Department of Environmental Quality 

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July 2011 

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6. Weight of Evidence for Fine Particulate Matter 

This section is called Weight of Evidence (WOE) because it is intended to provide 

additional supporting information, or “evidence,” that emissions have been and are 

being reduced in the highest PM2.5 area, in the vicinity of the Dearborn air monitor. 

This information should be seen as a supplement to the emission inventories that are 

contained in Section 5 of this document and which serve as the primary evidence that 

emission reductions have brought about the change in attainment status from 

nonattainment to attainment at the design value monitor in Dearborn between the 

years 2005 and 2008. 

Using a WOE is consistent with Michigan’s PM2.5 implementation plan for the annual 

standard which was completed in 2008. A WOE approach was used because it is 

the most scientifically defensible; it relies on not one method, such as modeling, but 

multiple sources of information, providing a more robust SIP demonstration. The 

WOE included monitoring data, emissions inventory data, photochemical and 

dispersion modeling, and trend analysis. The implementation plan focused on the 

monitors in Wayne County that were not showing attainment of the standard in the 

years prior to 2008. 

In the implementation plan, local strategies were shown through modeling to be 

effective for attaining the standard. As only two of the 13 monitors in the sevencounty area were not in compliance with the standard in 2007 (SWHS showed 

attainment in 2008), and these two violating monitors were within three miles of each 

other, stationary source nonattainment area-wide controls were determined to be 

impractical. The plan noted that federal requirements (Acid Rain, NOX SIP Call, 

mobile source controls, etc.) would already be controlling major sources in the region, 

although, monitoring trends and modeling data showed that these regional on-thebooks federally mandated controls still may not quite provide for attainment at the 

Dearborn monitor by 2009. Thus efforts in the 2008 SIP primarily focused on 

identifying and reducing the local excess PM2.5 in the Dearborn area. 

This section includes background information on the nature of the PM2.5 in the 

Dearborn area. The components of PM2.5 are similar in many locations but 

component percentages can vary between locations. Understanding this mix can 

help determine sources in the area that can be considered as contributors to the 

overall PM2.5 problem. 

The section also provides information on typical sources of the three constituents of 

PM2.5 that are accounted for in the inventory in Section 5. The three are primary 

PM2.5, sulfates, and nitrates, the latter two of which are represented in the inventory 

by SO2 and NOX. 
Michigan Department of Environmental Quality 

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This SIP redesignation demonstration addresses both the annual and daily PM2.5

standards. While high daily values are often driven by winter time inversions, unlike 

the high annual standard causes, the same controls that lead to annual reductions 

should have positive impacts on the daily standard. This WOE, therefore, is intended 

to apply to the daily standard as well as the annual. 

6.1. PM2.5 Composition 

Fine particulate matter is a complex mixture of ammonium sulfate, ammonium nitrate, 

organic carbon, elemental carbon, soil (or crustal material) and other particles. Some 

PM2.5, particularly in urban areas, is anthropogenic (man-made) in origin and some is 

biogenic (natural) in origin. PM2.5 is composed of primary (directly emitted) and 

secondary (formed in the atmosphere) particles. Current speciation analyses of 

ambient monitoring data indicate that PM2.5 concentrations result from both primary 

emissions (e.g., crustal matter, elemental carbon, and much of the organic carbon), 

and secondary formation (e.g., ammonium sulfate, ammonium nitrate, and some 

organic carbon). Figure 7 shows the composition of PM2.5 at two monitors in the 

Detroit area. 

Figure 7. Average PM2.5 Composition for Dearborn and 

Allen Park. 

Source: Brown, et. al., 2006. 

The largest components of PM2.5 at the monitors showing nonattainment are 

ammonium sulfate, ammonium nitrate and organic carbon. Soil also is significant at 

the Dearborn monitor. The Dearborn and Allen Park monitors are only a few miles 

apart, but show differences in composition and average concentration, indicating that 

local sources have a large impact on the Dearborn monitor. Based on EPA’s 

implementation guidance, primary PM2.5 and SO2 must be regulated. NOX must be 
Michigan Department of Environmental Quality 

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July 2011 

Page 19

regulated unless the state or EPA can demonstrate that NOx is not a significant 

contributor to PM2.5. Since ammonium nitrate contributes 20-30% of PM2.5 mass, 

Michigan determined NOX is a significant contributor to PM2.5. 

The ambient levels of PM2.5 have been decreasing in recent years as can be seen in 

Figure 8. In recent years, all sites with speciated data have had reductions in 

sulfates and organic carbon. The soil component at Dearborn, which is largely 

composed of iron, has also decreased, which is attributed to additional controls 

installed at the Severstal steel mill. Regional controls of NOX and SO2 reduced PM2.5

in this area and throughout the state, and will continue to do so for the next several 

years. Significant amounts of PM2.5 came predominantly from local upwind industrial 

sources (iron and some organic carbon), and control of these sources significantly 

reduced the local excess at this site and brought it into attainment of both the annual 

and daily PM2.5 standards in 2009 and has continued to keep it well within these 

standards in 2010. 

Figure 8. Average PM2.5 Species Composition by Site for Three Multi-Year 

Periods. 

Source: LADCO, November 2010 
Michigan Department of Environmental Quality 

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6.2. PM2.5 Sources 

PM2.5 comes from a variety of local and regional sources. Primary PM2.5 is directly 

emitted as a particle and is usually deposited on a monitor from nearby sources. 

However, on occasion, primary PM2.5 is carried for many miles from forest fires or 

dust storms before it is deposited. NOX is emitted as a gas, but can convert quickly 

to a particulate form of ammonium nitrate. Thus NOX sources can be local sources 

within a few miles of a monitor, at a greater distance away from the monitor but within 

the Southeast Michigan region, or from a multi-state region. SO2 requires time to 

form ammonium sulfate and will mostly come from a greater distance away from the 

monitor but within the Southeast Michigan region and from a multi-state region, 

similar to ammonium nitrate. 

The Dearborn monitor is located in the industrialized core of Detroit, which contains a 

complex array of emission sources. In the area of the Dearborn monitor, there are a 

variety of sources of primary PM2.5, including steel mills, an auto manufacturer, a 

refinery, and a variety of smaller stationary sources. Sources of NOX include various 

sizes of industrial combustion operations and electric generating facilities. SO2

sources are some of the same combustion operations, particularly large boilers and 

electric generating facilities burning coal or oil. 

Figure 9 provides information on PM2.5 coming in to Detroit, called background, and 

PM2.5 locally generated, called urban excess. The federal regional controls address 

much of the background while controls of local facilities (as well as federal rules for 

mobile sources) address the urban excess. Ammonium sulfate, mostly from regional 

sources, has similar concentrations as the regional background, which has been 

reduced in recent years (2008-2009). Ammonium nitrate comes from local and 

regional sources and both the local and regional contribution has decreased in recent 

years. Soil is part of the primary PM2.5 component and has also been decreasing in 

recent years, especially the local excess. Organic carbon is part of both the primary 

and secondary PM2.5. The local portion is most likely primary PM2.5 and has been 

decreasing over recent years. The background organic carbon is likely a mix of 

primary and secondary PM2.5 and has remained relatively constant in recent years 

(see Figure 9). This figure shows that local concentrations of PM2.5 have been 

significantly reduced, helping Southeast Michigan reach attainment. 
Michigan Department of Environmental Quality 

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Figure 9. The Urban Excess by Species in Detroit for Three Multi-Year Periods. 

Source: LADCO, November 2010 

6.3. Requirements for Permanent, Quantifiable Reductions 

The CAA states that a redesignation request must demonstrate that the nonattainment area has experienced emission reductions that led to the improvement in its 

ambient air. Secondly, it is required that the emission reductions are shown to be 

permanent and quantifiable. As stated in Section 5, the emission reductions 

responsible for the continued decline in PM2.5 levels in the nonattainment area, and 

particularly in the Dearborn area, come from a variety of sources. 

The largest emission reductions between 2005 and 2008 are from the on-road mobile 

sector. These reductions are primarily due to federal control programs that are 

permanent and enforceable and therefore meet the intent of the CAA. Other 

emission reductions that are positively impacting the nonattainment area are the 

federal and state acid rain program and NOX SIP call affecting EGUs. While the 

EGUs in the nonattainment inventory do not show emission reductions from 2005-

2008, these programs on a regional basis are reducing PM2.5 levels in the air 

reaching the nonattainment area and contributing to attainment. These control 

programs are permanent and enforceable and meet the CAA requirement. 
Michigan Department of Environmental Quality 

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July 2011 

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Stationary source controls that were included in Southeast Michigan’s PM2.5 SIP and 

permanent closure of facilities in the vicinity of the Dearborn monitor also result in 

permanent and enforceable emission reductions that directly impact the monitors in 

that area. Appendix D in this document contains information regarding a number of 

these sources. 

6.4. Stationary Source Facility Details 

To further evaluate local stationary emission sources, sources were analyzed for 

emissions, throughput (as a stable surrogate for emissions), emission controls and 

other pertinent information and compared to the ambient PM2.5. Figure 10 shows the 

location of emissions sources around the Dearborn monitor. Changes at many of 

these sources are analyzed in Appendix D. 
Michigan Department of Environmental Quality 

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Figure 10. Map of Emission Sources Near the Dearborn Monitor. 

List of Sources 

SRN Source SRN Source 

A6902 Darling International Inc B3533 Edw C Levy Co Plant 1 

A7809 US Steel Great Lakes Works B3567 St Mary's Cement 

A8196 M-Lok Riley Plating – OOB* B4752 Great Lakes Petroleum Terminal – OOB* 

A8640 SeverStal North America B5162 Xcel Steel Pickling (formerly Castle Steel) 

A8648 Ford Motor Co. - Rouge Complex B5558 Honeywell – OOB* 

A9196 Fabricon Products Inc B7071 Automotive Components Holding 

A9831 Marathon-Ashland Oil Refinery B9080 Envirosolids, LLC 

B2103 Detroit Water and Sewerage Department K1636 City of Dearborn 

B2169 Carmeuse Lime, Inc. (River Rouge Facility) M3066 Spartan Industrial – OOB* 

B2247 Buckeye Terminals LLC (Detroit Terminal) M4685 Detroit Salt 

B2798 Detroit Edison Co. - Delray M4798 Ferrous Environmental – OOB* 

B2810 Detroit Edison Co. - River Rouge M4848 Ford Motor Allen Park Clay Mine – OOB* 

B2926 Sunoco Partners M & T, L.P. (River Rouge 

Terminal) 

N0226 Hinkle MFG LLC 

B2956 Ford Motor New Model Program N1014 Magni Industries Inc 

B3195 Cadillac Asphalt Products N6631 Dearborn Industrial Generation 

B3518 United States Gypsum Company N7723 DTE Energy / Ford World Headquarters 

* OOB means out of business 

Dearborn Monitor 
Michigan Department of Environmental Quality 

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July 2011 

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6.5. Other Source Categories 

Point source emissions were discussed in Section 6.4 and in detail in Appendix D. 

This section addresses the remaining area and mobile sources addressed in the 

emissions inventory in Section 5. 

Based on the emissions inventory all area and mobile sources have lower emissions 

in 2008 compared to 2005 for primary PM2.5. Mobile sources (including non-road, 

MAR, and on-road) have also reduced emissions for NOX and SO2. Phase in of the 

Tier 2 mobile vehicle controls, low sulfur gasoline requirements and corresponding 

diesel rules that puts similar controls on diesel fuel and heavy-duty vehicles are 

producing significant reduction in mobile emissions. In addition regional summertime 

gasoline rules that reduce the Reid vapor pressure (RVP) in fuel from 7.8 to 7.0 

began in 2007. 

Also federal rules for aircraft, recreational vehicles, diesel marine engines and large 

industrial spark-ignition engines went into effect between 2005 and 2008 which 

produced emission reductions in the MAR and non-road mobile emissions 

categories. 

6.6. Trends Analysis 

The 3-year PM2.5 annual average (Figure 11) and 3-year 98th percentile (Figure 12) 

for daily PM2.5 have decreased over the last 10 years. The only monitor in Southeast 

Michigan that was above the standard in the 2006-2008 3-year average was the 

Dearborn monitor. Since 2007-2009, this monitor has been in compliance with both 

the annual and daily PM2.5 standard. 
Michigan Department of Environmental Quality 

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July 2011 

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Figure 11. Annual Average of Annual PM2.5. 

Annual Average PM2.5

7

9

11

13

15

17

19

21

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Concentration (ug/m3)

Dearborn SW HS Wyandotte Allen Park Linwood 

Luna Pier E 7 Mile Oak Park Ypsilanti Livonia

Port Huron New Haven Newberry FIA

Annual Standard 

15 ug/m3

Source: MDEQ monitor data 
Michigan Department of Environmental Quality 

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July 2011 

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Figure 12. 98th Percentile Concentration of Daily PM2.5. 

98th Percentile Daily PM2.5 per Year

20

25

30

35

40

45

50

55

60

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Concentration (ug/m3)

New Haven Luna Pier Oak Park Port Huron Ypsilanti

Allen Park SW High Sch. Linwood E 7 Mile Livonia

Dearborn Wyandotte Newberry FIA/Lafayette

Daily Standard 

35 ug/m3

Source: MDEQ monitor data 

The PM2.5 speciation data in Figure 13 shows a decrease in concentrations each 

year at the speciated sites in Southeast Michigan. While all sites show a decrease 

mostly due to sulfate reductions, Dearborn shows reductions in carbon and soil 

concentrations as well. 
Michigan Department of Environmental Quality 

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July 2011 

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Figure 13. The Average PM2.5 Species Composition per Site by Year. 

Source: LADCO, November 2010 

 

A trend that is statistically significant gives greater credibility to trend analysis data 

than merely observing a downward trend. Two statistical tests, least squares fit and 

Theil fit regression were preformed by LADCO (September 2010) on the speciated 

components of PM2.5 to determine if the downward trends observed in Detroit are 

statistically significant. Both tests showed a statistical decrease in organic carbon, 

ammonium sulfate, ammonium nitrate, and soil at the Detroit sites. 

These tests indicate that the downward trends in Detroit are more than a random 

coincidence. Based on these analyses, which were used to calculate a yearly 

concentration change, there has been an average annual reduction in PM2.5 of 0.4 to 

0.6 μg/m3

 per year. The NOX SIP call, the Acid Rain Program, and the sulfur 

reductions in fuels have all contributed to the decrease in ammonium sulfate and 

ammonium nitrate. The decrease in organic carbon has been significant, but the 

sources of organic carbon are still uncertain, as will be discussed further below. 

Reductions in soil, particularly at the Dearborn monitor, are due to decreases in iron. 

While iron is a component of soil, it also has an additional source at the Dearborn 

monitor, a steel mill. As seen in Figure 14, much of the soil (or crustal) is composed 

of iron at the Dearborn monitor, and it has been decreasing in recent years. 
Michigan Department of Environmental Quality 

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July 2011 

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Figure 14. The Iron Component of Soil (or Crustal) PM2.5. 

Source: LADCO, November 2010 

The Dearborn monitor is in a very industrialized area, directly downwind of a steel 

mill, and a few miles from a car manufacturing plant, oil refinery, waste incinerator, a 

second steel mill, a rail yard and electric generating units. Figure 15 shows the local 

excess of PM at Dearborn for the daily PM2.5 standard. The map in Figure 15 shows 

the population density, indicating high population around the Dearborn monitor 

(marked by the green dot). The red dots on the map mark the location of other 

monitors in the area. 

The bar graph in the upper right hand corner of Figure 15 indicates the “excess” 

PM2.5 concentrations (finer local scale source contributions) above the “network-wide” 

base concentration (regional background source contributions). The excess local 

and regional network-wide base concentrations at Dearborn have decreased over the 

years. In 2008 and 2009, the mean local excess (red line in the yellow bar) has also 

decreased and is near the regional network-wide base concentration (black line in 

the yellow bar). 

A 1-dimensional nonparametric wind regression (1-D NWR) indicates the average 

concentration when winds come from a specific wind direction and is particularly 

useful for identifying sources and their emissions strengths. The figure in the lower 

left corner of Figure 15 indicates the sources to the southwest of the Dearborn 

monitor (center of circles) have the greatest contributions to the Dearborn monitor. 

This is the direction of the nearby steel mill. The graph in the lower right corner of 
Michigan Department of Environmental Quality 

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Figure 15 transforms the 1-D NWR plot into a linear scale. It also separates out the 

years into three (3) three-year periods. It shows that concentrations, particularly from 

the southwest, have decreased by nearly 5 μg/m3

 over the nine-year period. 

Figure 15. Local PM Excess at the Dearborn Monitor. 

Source: Turner, 2010 

Table 8 further indicates that the southwest sector has a much greater contribution to 

local PM2.5 excess mass than other sectors, but it is also decreasing in recent years. 

In 2007, the steel mill southwest of the Dearborn monitor, Severstal, installed 

baghouses on their Blast Furnace and Basic Oxygen Furnace. Thus the reduction in 

PM2.5 contribution in the southwest sector may be explained by the Severstal 

controls. 
Michigan Department of Environmental Quality 

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July 2011 

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Table 8. Period Average Contribution to PM2.5 (μg/M3

) for the Southwest 

(SW, 165-290 On) Sector at Dearborn. 

Source: Turner, 2010 

Positive Matrix Factorization (PMF) indicates a strong southwesterly influence from a 

steel (manganese) and zinc factor at the Dearborn monitor (see Figure 16). 

Figure 16. Wind Roses of Highest Factor Contribution Days Resolved by PMF at Allen 

Park and Dearborn for Industrial Zinc and Steel (Manganese). 

Source: Wade, et. al, 2008 

Doing PMF modeling using both an individual site and multiple site methodology, 

Wade, et. al. (2008) found over 2 μg/m3 of PM2.5 mass are contributed from the steel 

and zinc factors (the steel and zinc factors total contribute 2.4 μg/m3

 for the individual 

Dearborn site, or 2.85 for the Dearborn multi-site). All of these studies indicate that 

controls on the steel mill can and have greatly reduced PM2.5 contributions from that 

source. 

Dearborn 

Allen Park 
Michigan Department of Environmental Quality 

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July 2011 

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Table 9. Individual-Site (I) and Multi-Site (M) PMF-Resolved Factors for Allen Park 

and Dearborn. All concentration units are μg/m3

. 

Factor Allen Park-I Allen Park-M Dearborn-I Dearborn-M 

Sulfate 5.18 5.34 5.50 5.52 

Nitrate 3.35 3.11 3.29 3.00 

Organic matter 2.60 4.10 4.10 4.40 

EC 2.48 2.28 2.49 2.39 

Soil 0.97 0.34 1.12 0.97 

Copper (Cu/Ni) NR NR NR NR 

Zinc 0.37 0.19 1.10 1.55 

Steel (Fe/Mn) 0.57 0.13 1.30 1.30 

Modeled Mass 15.50 15.44 18.91 19.04 

Measured 

Mass 

15.65 15.65 19.06 19.06 

NR=not resolved 

Multi-site modeling included only those days with valid data for both sites. PMFmodeled daily contributions from the individual-site modeling of Section 3 were 

censored to include only those days used for the multi-site modeling. Thus, the 

reported individual-site average contributions are modestly different from the results 

presented in Section 3 (Wade, et. al. 2008) 

The other component that has been reduced at the Dearborn monitor is organic 

carbon (OC). As stated above, the sources of OC are still not well understood. 

Figure 17 below indicates a westerly excess of OC at the Dearborn monitor of 

0.17 μg/m3

. However, this excess is small compared to the nearly 3 μg/m3 reduction 

in OC that has been seen between 2002 and 2009. 
Michigan Department of Environmental Quality 

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July 2011 

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Figure 17. Non-Parametric Wind Regression (NWR) on the Excess Species 

Concentrations at Dearborn Compared with Allen Park. (Red Lines Denote an 

Excess at Dearborn while Blue Lines Denote an Excess at Allen Park.) 

Source: Wade, et. al. 2008 

Several source apportionment studies using both PMF and Chemical Mass Balance 

(CMB) have been done in the Detroit area. In some of these studies OC was 

apportioned to various factors. In all the OC source apportionment studies for PMF, 

mobile sources were major contributors to organic mass (see Figure 18). Coal 

combustion and industrial sources also contributed over 1⁄2 μg/m3

 to organic mass. 
Michigan Department of Environmental Quality 

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July 2011 

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Figure 18. Average Concentration of Organic Matter by PMF Factor by Site for 

All Data. 

Source: Brown, et. al. 2006 

In CMB studies, carbon mass was apportioned largely to mobile sources, (especially 

lube oil impacted or smoking vehicles) and biomass burning (see Figure 19 and 

Sheesley et. al, February 2010). 

Figure 19. CMB Source Apportionment of Carbon Mass for Detroit. 

Source: Brown, et. al. 2006 
Michigan Department of Environmental Quality 

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July 2011 

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Over the past decade the Detroit area has seen a major reduction in employment, 

particularly in the manufacturing sector (see Appendix E for more information). As 

employment has declined, population as well as vehicle miles traveled (VMT) has 

declined (see Figure 20). However, it is difficult to directly tie a drop in VMT to the 

large amount of organic carbon reduction at the Dearborn monitor, since the drop in 

OC levels resulting from a drop in VMT would be expected to be relatively consistent 

across the southeast Michigan monitors, which is not the case. 

Figure 20. Changes in Southeast Michigan Employment and Travel, 2002-2009. 

Source: SEMCOG, 2010 
Michigan Department of Environmental Quality 

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July 2011 

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6. References 

Brown, S.G, Hafner, H.R, Roberts, P. T., Sheesley, R. J., and Shauer, J. J. (2006). 

“Integration of Results for the Upper Midwest Urban Organics Study,” prepared by 

Sonoma Technology, Inc. (Petaluma, CA), and University of Wisconsin (Madison, 

WI), submitted to LADCO. 

LADCO, 2010. “PM2.5 Speciations Trends,” for SEMOS meeting, November 17, 2010. 

LADCO, 2010. “Air Quality Overview,” for Project Team Meeting, September 22-23, 

2010. 

SEMCOG, 2010. The Impact of Southeast Michigan’s New Economic Reality on 

Regional Pollutant Emissions. 

Sheesley, R. J., Shauer, J. J., and Orf, M. L. (2010). “Assessing the Impact of 

Industrial Source Emissions on Atmospheric Carbonaceous Aerosol Concentrations 

Using Routine Monitoring Networks,” J. Air & Waste Management. Assoc. 60:149–

155. 

Turner, J. 2010. “Southeast Michigan PM2.5 Conceptual Model September Update,” 

for SEMOS meeting, Sept. 30, 2010. 

Wade, K.S.; Turner, J.R.; Brown, S.G; Garlock, J.L., Hafner, H.R. (2008). “Data 

analysis and source apportionment of PM2.5 in selected Midwestern cities,” Report # 

STI-907018.03-3264-FR (February 2008), prepared by Sonoma Technology, Inc. 

(Petaluma, CA), submitted to LADCO.
Michigan Department of Environmental Quality 

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July 2011 

Page 36

7. Maintenance Plan 

A maintenance plan must demonstrate continued attainment for at least 10 years 

after approval of a redesignation. Section 175A of the CAA sets forth the elements of 

a maintenance plan for areas seeking redesignation from nonattainment to attainment. Eight years after the redesignation, a revised maintenance plan for the next 

ten years must be submitted to the EPA. To address the possibility of future NAAQS 

violations, the maintenance plan must contain contingency measures. 

 

Continued future attainment is demonstrated through emission inventory projections. 

This demonstration includes an attainment year inventory for 2008, an interim year of 

2018, and a projected maintenance inventory for 2022. The future year inventories 

of primary PM2.5, NOX, and SO2 emissions are shown to remain below attainment 

year 2008 emissions levels, insuring that the area remains in attainment. 

Reductions in PM2.5 emissions will be realized from a variety of sources, including 

federal MACT standards for hazardous air pollutants, federal diesel emissions 

programs, and federal mobile source control programs for both on-road and non-road 

sources. The future year emissions inventories do not include any EGU controls for 

the EPA’s proposed Transport Rule or Michigan’s mercury rule but reductions from 

these sources are expected. The EPA has also developed new NAAQS for NOX and 

SO2 which may further reduce primary PM2.5, SO2 and NOX in Southeast Michigan. 

Voluntary diesel strategies such as clean school bus programs will result in additional 

PM2.5 reductions. The maintenance plan inventory emissions totals for primary 

PM2.5, NOX, and SO2 are provided in Table 10 for annual PM2.5 and Table 11 for daily 

PM2.5. The methodologies used for growing emissions to 2018 and 2022 as well as 

the controls that will impact emissions in those years are described in Appendix B 

and Appendix C. 
Michigan Department of Environmental Quality 

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July 2011 

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Table 10. Maintenance Plan Emission Inventories for annual PM2.5, 2008-2022. 

All units are in tons per year. 

 NOx SO2 PM2.5

 2008 2018 2022 2008 2018 2022 2008 2018 2022 

EGU 70,008.00 57,627.53 60,748.05 233,870.64 205,085.72 216,191.10 1,375.31 1,443.34 1,521.50

NON-EGU 18,817.18 18,590.74 18,590.74 19,793.49 19,555.30 19,555.30 1,605.72 1,586.40 1,586.40

Area 17,157.57 17,563.12 17,805.41 5,702.94 5,837.74 5,918.27 5,406.06 5,533.84 5,610.18

Non-road 24,065.61 10,666.13 8,899.43 426.61 29.38 30.80 1,773.31 1,093.56 910.17

MAR 6,380.17 3,723.14 2,591.48 588.82 399.87 312.15 165.62 73.77 37.06

On-road 119,194.00 37,847.00 28,044.00 1,065.00 310.00 294.00 4,360.00 1,633.00 1,311.00

Total 255,622.53 146,017.66 136,679.11 261,447.50 231,218.01 242,301.62 14,686.02 11,363.91 10,976.30

Table 11. Maintenance Plan Emission Inventories for Daily PM2.5, 2008-2022. 

All units are in tons per winter day. 

 NOx SO2 PM2.5

 2008 2018 2022 2008 2018 2022 2008 2018 2022 

EGU 220.95 186.31 196.40 682.05 595.46 627.70 2.91 3.07 3.24

NON-EGU 49.76 53.49 53.49 51.33 55.17 55.17 3.98 4.28 4.28

Area 80.58 82.72 83.88 16.46 16.90 17.13 15.46 15.87 16.09

Non-road 47.82 23.47 19.44 0.81 0.06 0.07 3.70 2.39 1.98

MAR 19.80 15.90 14.34 1.75 0.00 0.00 0.50 0.00 0.00

On-road 366.20 117.80 88.10 3.10 0.90 0.80 15.70 6.60 5.60

Total 785.11 479.69 455.50 755.50 668.49 700.87 42.25 32.21 31.19

The focus of the PM2.5 inventory effort was to produce emission inventories for the 

nonattainment year (2005) and the attainment year (2008). The future year 

projections (2018 and 2022) take into account existing control measures and 

measures that are promulgated and known to be on the way. Many of the future year 

emission estimates for this inventory product were grown from the LADCO Base B 

(2007, 2008) Inventory. Where data was not available in the Base B inventory, data 

from the previous inventory cycle - Base M (2005) run was utilized, if appropriate. 

 

The inventory was further processed by LADCO to produce annual and winter day 

totals. Full documentation of methodologies and models used to derive emission 

inventories is contained in Appendices B and C. A 2018 and 2022 maintenance 

inventory was prepared by LADCO and SEMCOG. Future year EGU emissions do 

not assume reductions from the federal proposed Transport Rule. 
Michigan Department of Environmental Quality 

Proposed Request to Redesignate Southeast Michigan Counties 

July 2011 

Page 38

Maintenance Commitments

Michigan will develop and submit to the EPA, no later than eight years after approval 

of this redesignation request, a new maintenance plan covering the next ten-year 

period. 

The MDEQ will continue to track PM2.5 levels through the operation of an EPAapproved monitoring network as necessary to demonstrate ongoing compliance with 

the NAAQS. Data will be entered into the Air Quality System on a timely basis in 

accordance with federal regulations. The MDEQ will continue to produce periodic 

emission inventories as required by the federal Consolidated Emissions Reporting 

Rule (40 CFR, Part 51) to track future levels of emissions. The control measures for 

PM2.5, SO2 and NOX emissions that were contained in the SIP before redesignation 

of these areas to attainment will be retained, as required by Section 175A of the 

CAA. 

Michigan will expeditiously enact legal authorities needed for additional contingency 

control measures and/or studies of conditions resulting in unexpected PM2.5

increases in response to identified triggering events. 

Action Level Response

An Action Level Response will be prompted when a two-year annual average of 

15 μg/m3 or a two-year 98th percentile average monitored value of 35 μg/m3 or higher 

occurs within the maintenance area. A review of circumstances leading to the high 

monitored values will be conducted if this response is triggered. The MDEQ will 

explore whether a special event, malfunction, or noncompliance with permit 

conditions resulted in high PM2.5 levels in order to immediately address corrective 

measures. The MDEQ will also review meteorological conditions during high PM2.5

episodes. This review will be conducted within six months following the close of the 

PM2.5 year. If the MDEQ determines that contingency measure implementation is 

necessary to prevent a future violation, the MDEQ will select and implement a 

measure that can be implemented promptly. 

Contingency Measure Response

If a violation of the PM2.5 NAAQS occurs, Michigan will select one or more control 

measures from the following list of potential contingency measure for implementation. 

The timing for implementation of a contingency measure is dependent on the process 

needed for legal adoption and source compliance, which varies for each measure. 

Some potential measures/controls have already been promulgated and are 

scheduled to be implemented at the federal or state levels. Other measures will need 

state administrative rulemaking or legislative approval. The MDEQ will seek to 

expedite the process of securing enabling authority and implementing the selected 

measures as needed to reduce PM2.5 levels, with a goal of having measures in place 

as expeditiously as practicable, and within 18 months after state certification of the 

violation. Opportunity for public participation in the contingency measure response 
Michigan Department of Environmental Quality 

Proposed Request to Redesignate Southeast Michigan Counties 

July 2011 

Page 39

will be provided. The MDEQ will submit the identified enforceable contingency 

measures to the EPA as revisions to the SIP as needed. 

List of Potential Contingency Measures

1. Wood stove change-out program. 

2. Steel mill controls. 

3. Coke battery controls. 

4. Diesel retrofit program. 

5. Reduced idling program. 

6. ICI Boiler controls. 

7. Food preparation flame broiler control. 

8. EGU controls. 
Michigan Department of Environmental Quality 

Proposed Request to Redesignate Southeast Michigan Counties 

July 2011 

Page 40

8. Transportation Conformity Budgets 

Transportation conformity is required by Section 176(c) of the CAA. Transportation 

plans, programs, and projects must conform to the applicable SIP. The federal 

transportation conformity rule established the criteria and procedures for determining 

whether conformity is met. 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 from cars, buses, and trucks driven on 

public roadways are projected for the maintenance period to assess emission trends 

and to ensure continued compliance with the PM2.5 NAAQS. 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 PM2.5 and NOX must not exceed the emission budgets contained in the 

maintenance plan. The emissions estimates for this sector reflect appropriate and 

up-to-date assumptions about vehicle miles traveled, socioeconomic variables, fuels 

used, weather inputs, and other planning assumptions. On-road emissions have 

been projected to 2022 in the maintenance inventory. 

 

Typically, the formula for calculating maintenance conformity budgets is: 

On-road emissions inventory for maintenance year + safety margin 

Where: 

safety margin = 90% of emissions reduction from all sources between the 

attainment year and the maintenance year. 

However, recent EPA guidance states that the final budget is equal to either the 

calculated budget or the attainment year emissions, whichever is lower. Table 12 

shows the conformity budgets resulting from the conformity budget formula. In all 

cases, the calculated budgets are higher than the attainment year emissions 

inventory. Therefore, the final budgets will be set equal to the 2008 on-road 

emissions inventory. These values are shown in Table 13 and Table 14. 
Michigan Department of Environmental Quality 

Proposed Request to Redesignate Southeast Michigan Counties 

July 2011 

Page 41

Table 12. Motor Vehicle Emissions Budget Calculation for Livingston, Macomb, 

Monroe, Oakland, St. Clair, Washtenaw, and Wayne Counties. 

Annual PM2.5, Ton per year 

PM2.5

PointEGU 

PointNonEGU

Area 

Total MAR Onroad Nonroad Total

2008 1,375.3 1,605.7 5,406.0 165.6 4,360.0 1,773.3 14,685.9

2022 1,521.0 1,586.0 5,610.0 37.1 1,311.0 910.2 10,975.3

Emissions 

Reduction 145.7 ‐19.7 204.0 ‐128.6 ‐3,049.0 ‐863.1 ‐3,710.6

Safety Margin 3,340

Conformity Budget 4,651

NOx 

PointEGU 

PointNonEGU

Area 

Total MAR Onroad Nonroad Total

2008 70,008.0 18,817.2 17,157.6 6,380.2 119,194.0 24,065.6 255,622.6

2022 60,748.0 18,591.0 17,805.0 2,591.5 28,044.0 8,899.4 136,678.9

Emissions 

Reduction ‐9,260.0 ‐226.2 647.4 ‐3,788.7 ‐91,150.0 ‐15,166.2 ‐118,943.7

Safety Margin 107,050

Conformity Budget 126,759

Daily PM2.5, Tons per day.

PM2.5

PointEGU 

PointNonEGU

Area 

Total MAR Onroad Nonroad Total

2008 2.9 4.0 15.5 0.5 15.7 4.2 42.8

2022 3.2 4.3 16.1 0.0 5.6 1.5 30.7

Emissions 

Reduction 0.3 0.3 0.6 -0.5 -10.1 -2.8 -12.1

Safety Margin 10.9

Conformity Budget 16.5

NOx 

PointEGU 

PointNonEGU

Area 

Total MAR Onroad Nonroad Total

2008 221.0 49.8 80.6 19.8 365.3 58.4 794.9

2022 196.4 53.5 83.9 14.3 88.1 9.0 445.2

Emission Reduction -24.6 3.7 3.3 -5.5 -277.2 -49.4 -349.7

Safety Margin 315.0

Conformity Budget 380.6
Michigan Department of Environmental Quality 

Proposed Request to Redesignate Southeast Michigan Counties 

July 2011 

Page 42

Table 13. Final Motor Vehicle Transportation Conformity Budget Calculation for 

Annual PM2.5. In tons per year. 

Tons/Year 

 PM2.5 NOx 

Total Emission Reduction 2008 - 2022 3,711 118,944 

Safety Margin (90% of total reduction) 3,340 107,050 

2022 On-Road Mobile Emissions 1,311 28,044

Calculated Budget = 

2022 On-Road Emissions + Safety Margin 4,651 135,094 

Attainment Year Emissions (2008) 4,360 119,194 

 

Final Budget* 4,360 119,194 

*Per EPA guidance, the final budget is equal to either the calculated 

budget or the attainment year emissions, which ever is lower. 

Table 14. Final Motor Vehicle Transportation Conformity Budget 

Calculation for Daily PM2.5. In tons per day.

Tons/Winter Weekday 

 PM2.5 NOx 

Total Emission Reduction 2008 - 2022 12 350 

Safety Margin (90% of total reduction) 11 315 

2022 On-Road Mobile Emissions 6 88

Calculated Budget = 

2022 On-Road Emissions + Safety Margin 17 403 

Attainment Year Emissions (2008) 16 365 

Final Budget* 16 365 

*Per EPA guidance, the final budget is equal to either the calculated 

budget or the attainment year emissions, whichever is lower. 
Michigan Department of Environmental Quality 

Proposed Request to Redesignate Southeast Michigan Counties 

July 2011 

Page 43

9. Public Participation and Comments 

In accordance with Section 110 (a) (2) of the CAA, public participation in the SIP 

process was provided for as follows: 

 

Notice of availability of the PM2.5 redesignation documents and notice of the public 

comment period and opportunity to request a public hearing was posted on the 

MDEQ web pages at http://www.Michigan.gov/deqair and 

http://www.michigan.gov/deqcalendar. 

 

A public hearing for this redesignation request, including the baseline emissions 

inventory for PM2.5, SO2 and NOX and the maintenance plan SIP revision was held on 

May 26, 2011, at Constitution Hall in Lansing, Michigan. 

 

A summary of comments received and the MDEQ responses are included in 

Appendix F.