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/m 3 annual and 35 ug/m 3 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.



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Director 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 St ate Implementation Plan for Achieving the Particulate Matter le ss 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 PM 2.5 

## 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 DivisionTable of Contents

1. Intr oducti on........................................................................................................... 1 2. Redesignation Pa ckage Components .................................................................. 3 3. Demonstration of Atta inment of the St andard....................................................... 4 4. State Implementation Plan Approval and Compliance with Clean Air Act and Part D Requi rements .......................................................................................... 10 5. Demonstration of Impr ovement in Ai r Quality ..................................................... 11 6. Weight of Evidence fo r Fine Particul ate Matter................................................... 17 6.1. PM 2.5 Compos ition.............................................................................................. 18 6.2. PM 2.5 Sour ces..................................................................................................... 20 6.3. Requirements for Permanen t, Quantifiable Reductions...................................... 21 6.4. Stationary Source Facility Details....................................................................... 22 6.5. Other Sour ce Cat egories.................................................................................... 24 6.6. Trends Analysis.................................................................................................. 24 7. Maintenan ce Plan............................................................................................... 36 8. Transportation C onformity Budgets.................................................................... 40 9. Public Partici pation and Comments.................................................................... 43

List of Tables

Table 1. National Ambient Air Qua lity Standards for Fine Part icles. ............................... 1 Table 2. Southeast Michigan 2007-2010 M onitor Data Design Value for Annual PM 2.5 NAAQS.

. ............................................................................................................... 5 Table 3. Southeast Michigan 2007-2010 M onitor Data Design Value for Daily PM 2.5 NAAQS.

. ............................................................................................................... 6 Table 4. Percent Data Comple teness per Quarte r for 20 07-2010.

.................................. 9 Table 5. Southeast Michigan Emission Reduct ion Demonstration Inventories for 2005 and 2008 for Annual PM 2.5

. . ................................................................................ 11 Table 6. Southeast Michigan Emission Reduct ion Demonstration Inventories for 2005 and 2008 for Daily PM 2.5

. . ................................................................................... 12 Table 7. List of Sources that have Gone Out of Business in Wayne County, Michigan between 2005 and 2008 and Their Emi ssions.................................................... 13 Table 8. Period Averag e Contribution to PM 2.5 for the Southwest Sector at Dearborn.. 30 Table 9. Individual-Site (I) and Multi-Site (M) PMF-Resolved Factors for Allen Park and Dearbor n.. .......................................................................................................... 31 Table 10. Maintenance Plan Em ission Inventories for annual PM 2.5 , 2008-2022.

. ....... 37 Table 11. Maintenance Plan Em ission Inventories for Daily PM 2.5 , 2008-2022............ 37 Table 12. Motor Vehicle Emissions Budget Ca lculation for Livingston, Macomb, Monroe, Oakland, St. Clair, Washt enaw, and Wayne Countie s........................................ 41 Table 13. Final Motor Vehicle Emissions Budgets for Annual PM 2.5

............................. 42 Table 14. Final Motor Vehicle Emissions Budgets for Daily PM 2.5

. . ............................... 42List of Figures

Figure 1. Southeast Michigan Counties for PM 2.5 Attainment Redesignation.................. 2 Figure 2. Locations of PM 2.5 Monitors. ............................................................................ 4 Figure 3. Historic Annual PM 2.5 Design Va lues. .............................................................. 7 Figure 4. Historic Daily PM 2.5 Design Va lues. ................................................................. 8 Figure 5. CART Index of PM 2.5 Conduciveness in Detroit. ............................................ 15 Figure 6. Tendency to Generate Elevated PM 2.5. Number of Elevated Days/Number of Conducive Days,. ............................................................................................... 16 Figure 7. Average PM 2.5 Composition for Dear born and Alle n Park.............................. 18 Figure 8. Average PM 2.5 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 Source s Near the Dear born Monitor. ................................ 23 Figure 11. Annual Average of Annual PM 2.5

.................................................................. 25 Figure 12. 98 th Percentile Concentration of Daily PM 2.5

. ............................................... 26 Figure 13. The Average PM 2.5 Species Composition per Site by Year.......................... 27 Figure 14. The Iron Component of Soil (or Crustal) PM 2.5

............................................ 28 Figure 15. Local PM Excess at the Dearbor n Monitor................................................... 29 Figure 16. Wind Roses of Highest Factor Cont ribution Days Resolved by PMF at Allen Park and Dearborn for Industria l Zinc and Steel (Manganese)........................... 30 Figure 17. Non-Parametric Wind Regr ession (NWR) on the Excess Species Concentrations at Dearborn Compared with A llen Park. .................................... 32 Figure 18. Average Concentration of Organic Matte r by PMF Factor by Site for All Data.

........................................................................................................................... 33 Figure 19. CMB Source Apportionm ent of Carbon Ma ss for Detroit.............................. 33 Figure 20. Changes in Southeast Mich igan Employment and Travel, 2002-2009......... 34

Appendices

Appendix A – Annual and Daily PM 2.5 Monitoring Data Appendix B -- Emission Inventory Methodology Appendix C – PM 2.5 Redesignation Inventory On-road Mobile Emissions Appendix D – Stat ionary Source Facility Details Appendix E -- Impact of Sout heast Michigan’s New Economic Reality on Regional Pollutant Emissions Appendix F – Public Part icipation DocumentationMichigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 1 1. Introduction

The State of Michigan, through the Michi gan Department of Environmental Quality (MDEQ), requests the U.S. Environment al Protection Agency (EPA) make a determination that Southeast Michigan is in at tainment with the Particulate Matter less than 2.5 microns in diameter (PM 2.5 ) National Ambient Air Q uality 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 Mi chigan State Implementation Plan (SIP). The seven counties in the Southeast Michigan PM 2.5 nonattainment area are Livingston, Macomb, Monroe, Oakland, St. Clair , Washtenaw, and Wayne, shown in Figure 1.

The EPA established the NAAQS for fine par ticulate matter, the annual and daily PM 2.5 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 qua lity monitoring data for the years 2001- 2003. Annual averages over 15 mi crograms per cubic meter (μg/m 3 ) and daily standards over 65 μg/m 3 were considered to be violatin g the standard, too high to be protective of health. The EPA designated sev en counties in Michigan as nonattainment for the annual standard.

The EPA revised the NAAQS for PM 2.5 , for the daily standard, in 2006. While the annual standard was maintained at 15 μg/m 3 , the daily standard was reduced to 35 μg/m 3 . (See Table 1)

The EPA designated areas in Michigan as atta inment or nonattainment of the 2006 PM 2.5 standards in November 2009. The desi gnations were based on design values derived from air quality monitoring data for the years 2006-2008. Daily values over 35 μg/m 3 were considered to be violating the st andard, 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 Qua lity Standards for Fine Particles.

Annual 24-Hour

1997 Fine Particles Standards (PM 2.5 ) 15 μg/m 3 Annual arithmetic mean, averaged over three
years 65 μg/m 3 24-hour average, 98 th percentile, averaged over three years

2006 Fine Particles

Standards (PM 2.5 ) 15 μg/m 3 Annual arithmetic mean, averaged over three
years 35 μg/m 3 24-hour average, 98 th percentile, averaged over three yearsMichigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 2 Air quality monitoring data collected in t he 2007-2010 period showed all seven counties in Southeast Michigan in attainment for the PM 2.5 annual and daily NAAQS.

Figure 1. Southeast Michigan Counties for PM 2.5 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 (C AA) establishes requirements to be met in order for an area to be qualified for r edesignation 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 result ing from implementat ion 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 PM 2.5 air quality monitors throughout Michigan with the primary objective being to determine compliance with the PM 2.5 NAAQS. The MDEQ submits network revi ews to the EPA Region 5 annually to ensure that air monitoring operations comply wit h all applicable feder al requirements. Figure 2 shows the locations of PM 2.5 monitors in Southeast Michigan.

Figure 2. Locations of PM 2.5 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 indicate s whether or not vi olations of the PM 2.5 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/m 3 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/m 3 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 M onitor Data Design Value for Annual PM 2.5 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 10.2Michigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 6 Table 3. Southeast Michigan 2007-2010 M onitor Data Design Value for Daily PM 2.5 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 Va lues. shows historic annual 3-year average design values at each site in the area to be redesignated. The data shows a strong andMichigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 7 steady decline in annual PM 2.5 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 lo cal level. Appendix A contains a table of the historical annual PM 2.5 values by quarter and year.

Figure 3. Historic Annual PM 2.5 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 08-10Concentration (ug/m3)

Dearborn SW HS Wyandotte Allen Park Linwood

Luna Pier E 7 Mile Oak Park Ypsilanti Livonia

Port Huron New Haven Newberry FIA A nnual 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 PM 2.5 NAAQS. Appendix A also contains a table of the historical daily PM 2.5 values.Michigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 8 Figure 4. Historic Daily PM 2.5 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 08-10Concentration (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 subm itted to EPA’s monitoring data repository called the Air Quality System (AQS). All data in t he 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 am bient monitoring data are specified in 40 CFR, Part 50, National Primary and Se condary 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 Michi gan meet the completeness criteria.Michigan Department ofEnvironmental QualityProposed Request to Redesignate Southeast Michigan CountiesJuly 2011Page 9Table 4. Percent Data Completeness per Quarter for 2007-2010.Monitor2007Q12007Q22007Q32007Q42008Q12008Q22008Q32008Q42009Q12009Q22009Q32009Q42010Q12010Q22010Q32010Q4NewHaven26099000997 97 87 97 97 90 97 100 93 97 100 87 100 100 100 100Luna Pier26115000597 87 94 100 100 100 94 90 97 97 97 87 100 97 100 94Oak Park261250001100 93 97 100 97 93 97 100 100 97 90 100 97 100 97 94Port Huron26147000597 93 97 97 97 97 97 97 90 100 97 97 93 100 97 100Ypsilanti26161000890 90 97 100 90 100 100 97 97 97 100 100 97 93 100 97Allen Park26163000196 97 93 100 97 99 93 95 93 98 92 93 89 96 91 90SW HS26163001593 100 87 97 100 100 100 97 100 90 100 94 100 100 97 97Linwood261630016 87 87 97 97 94 100 94 100 90 87 87 100 87 93 100 97E 7 Mile261630019100 93 100 90 97 100 81 100 100 100 97 90 100 77 84 94Livonia26163002587 100 100 90 87 97 100 97 97 100 93 90 93 97 87 97Dearborn261630033 97 97 94 90 100 93 97 100 90 100 93 100 90 100 97 100Wyandotte261630036 97 93 97 97 100 97 97 100 93 97 93 77 77 97 94 100Newberry26163003887 90 87 100 94 97 87 93 83 94 90 94 90 100 100 97FIA261630039 97 100 97 93 97 93 94 97 97 100 100 91 92 98 83 91Page 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 PM 2.5 nonattainment area under Part D, Subpart 1 of the CAA. Sect ion 110 of the CAA delineates general SIP requirements and Part D contains requireme nts specific to nonattainment areas. Southeast Michigan meets all app licable requirements for PM 2.5 redesignation under these provisions.

Southeast Michigan was originally classi fied as a nonattainment area under the 1997 annual PM 2.5 NAAQS. The EPA strengthened the daily standard in 2006 and Southeast Michigan was then classified as nonattainment for the daily PM 2.5 NAAQS as well.

Michigan’s SIP was submitted to EPA in Ma y 2008 and contains all required emission control programs related to PM 2.5 under Section 110 of the CAA. Programs for emissions limitations, permitti ng, 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 reasonab ly attributed to emissions reductions of primary PM 2.5 and the PM 2.5 precursor pollutants nitrogen oxides (NO X ) and sulfur dioxide (SO 2 ) that are permanent and enforceable. An examinati on of primary PM 2.5 , NO X and SO 2 emissions from a period of nonattain ment (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 Directo rs Consortium (LADCO) to yield annual and winter day nonattainment area (NAA) to tals. 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 includ ed in Appendices A and B.

Table 5 and Table 6 identify emission reductions by source category for the Southeast Michigan NAA. While SO 2 emissions increased slightly over this 3-year period, both NO X , and PM 2.5 emissions decreased by more than 10 percent. All pollutant emissions decreased for the mari ne, airports and ra ilroad category (MAR) and on-road mobile sources. All pollutant emissions increased for the electric generating unit (EGU) sources.

Table 5. Southeast Michigan Emission Reduct ion Demonstration Inventories for 2005 and 2008 for Annual PM 2.5

. All units are in tons per year.

NOx SO 2 PM 2.5 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 14,686.02Michigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 12 Table 6. Southeast Michigan Emission Reduct ion Demonstration Inventories for 2005 and 2008 for Daily PM 2.5

. All units are in tons per winter day.

NOx SO 2 PM 2.5 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 c ontrol programs contained in the PM 2.5 SIP for Southeast Michigan. This SIP, submitt ed 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 hav e brought all monitors in Southeast Michigan into compliance with both the annual and 24-hour PM 2.5 NAAQS.

Point Sources Companies in the nonattainm ent area have made signific ant emissions reductions that are permanent and enforceable. Additi onal detail on all of these companies can be found in Appendix D.

One source that has made si gnificant 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. Severs tal’s Blast Furnace B is currently shutdown, but will have a baghouse installed w hen it restarts. In addition, torch cutting is no longer permitted on site, sca rfing operations reduced their opacity and torpedo cars were required to reduce smoking. This source was also subject to Maximum Achievable Control Technolog y (MACT) Subpart FFFFF for integrated iron and steel mills. Total emissions reductions were 147 tons of PM 2.5

.
Another large source in the area is US Steel. US Steel upgraded a baghouse on their Blast Furnace B in September 2005, wh ich reduced particulate emissions by 76 tons per year (Consent Order 1-2005). In addition this faci lity is subject to MACT Subpart FFFFF for integrated iron and steel m ills 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, loca ted in the area, is a major volatile organic compound (VOC) source, but has some NO X 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 detail ed 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 NO X SIP Call.

In addition to these permanent and enforceabl e 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 PM 10 PM 2.5 SO 2 VOC NOx PM 10 PM 2.5 SO 2 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 sour ce controls, the Federal Motor Vehicle Control Program has produced significant em ission reductions from on-road and nonroad motor vehicles throughout the country. Phase-in of federal “Tier 2” emissionsMichigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 14 standards began in 2004, affecting light-dut y 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 sim ilar requirement for ultra low sulfur diesel fuel took effect. All of these cont rols contributed to a significant reduction in mobile source emissions of PM 2.5 , NO X and SO 2 . These reductions are permanent and enforceable and have contributed to the overall improvement in PM 2.5 levels in Southeast Michigan.

In addition to federal mobile controls, seve ral voluntary mobile control measures have occurred in the Detroit area. The Diese l 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 ma rine and off-road equipment and heavy duty diesel trucks in 2008 and 2009.

Four switch yard trains at the CSX rail ya rd 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 NO X 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 an ti-idling technology was calculated to reduce NO X emissions by 29 tons per year, and PM emissions by 1.3 tons per year.

Meteorological Conduciveness

Actual PM 2.5 levels adjusted for meteorologica l conduciveness are another indicator of overall improvement in air quality. PM 2.5 trend analysis is complicated by the dependence of PM 2.5 formation on meteorology, includ ing wind direction, wind speed, pressure, and temperature changes. To mo re accurately discern trends in PM 2.5 concentrations, the data can be adjusted to remove the impact from meteorological confounders. LADCO used a statistical technique, called Classification and Regression Tree (CART) anal ysis, to partition PM 2.5 values into various categories of PM 2.5 conducive meteorology. This determined the PM 2.5 -forming potential of each year’s meteorology. 1 Metrological and monitoring data fr om 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 PM 2.5 formation than the
average.

1 Kenski, Donna, Air Quality Overview, Lake Michigan Air Directors Consortium, Project Team Meeting, September 22-23, 2010Michigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 15 Figure 5. CART Index of PM 2.5 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 2009Condusivenss Index

Index represents fraction of PM 2.5 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 PM 2.5 values were elevated (above 25 μg/m 3 ) at ambient air quality monito rs by the number of days with conducive meteorology. The ratios were converted to percentages to increase clarity. Because there is year-to-year fl uctuation, an average of the percent of high PM 2.5 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 PM 2.5 conducive days experienced elevated PM 2.5 levels, but during the period 2008-2009, t he percentage drops to 31.Michigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 16 Figure 6. Tendency to Generate Elevated PM 2.5. 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

PM 2.5 concentrations in 2007-08 were m oderate despite better than average PM 2.5 - conducive meteorology. The CART analysis and the number of high PM 2.5 concentrations on meteorologically conduciv e days reinforces the demonstration that reductions in primary PM 2.5 and PM 2.5 precursor emissions have led to the actual improvements in air quality, rather than less conducive meteorology.Michigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 17 6. Weight of Evidence fo r Fine Particulate Matter

This section is called Weight of Evidenc e (WOE) because it is intended to provide additional supporting information, or “evi dence,” that emissions have been and are being reduced in the highest PM 2.5 area, in the vicinity of the Dearborn air monitor. This information should be seen as a supplement to the emission in ventories that are contained in Section 5 of this document and which serve as the primary evidence that emission reductions have brought about t he change in attainment status from nonattainment to attainment at the desi gn value monitor in Dearborn between the years 2005 and 2008.

Using a WOE is consist ent with Michigan’s PM 2.5 implementation plan for the annual standard which was completed in 2008. A WOE approach was used because it is the most scientifica lly defensible; it relies on not one method, such as modeling, but multiple sources of information, providi ng a more robust SIP demonstration. The WOE included monitoring data, emissi ons 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 strat egies 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 ar ea-wide controls were determined to be impractical. The plan noted that federal requirements (Acid Rain, NO X SIP Call, mobile source controls, etc.) would already be controlling major sources in the region, although, monitoring trends and modeling data showed that thes e regional on-thebooks federally mandated controls still may not quite provide for attainment at the Dearborn monitor by 2009. Thus effort s in the 2008 SIP pr imarily focused on identifying and reducing the local excess PM 2.5 in the Dearborn area.

This section includes background information on the nature of the PM 2.5 in the Dearborn area. The components of PM 2.5 are similar in many locations but component percentages can vary between loca tions. Understanding this mix can help determine sources in the area that c an be considered as contributors to the overall PM 2.5 problem.

The section also provides information on typi cal sources of the three constituents of PM 2.5 that are accounted for in the inventory in Section 5. The three are primary PM 2.5 , sulfates, and nitrates, the latter two of which are represented in the inventory by SO 2 and NO X

.Michigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 18 This SIP redesignation demonstrati on addresses both the annual and daily PM 2.5 standards. While high daily values are oft en 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 standar d. This WOE, t herefore, is intended to apply to the daily standar d as well as the annual.

6.1. PM 2.5 Composition

Fine particulate matter is a complex mixture of ammonium sulfate, ammonium nitrate, organic carbon, elemental carbon, soil (or cr ustal material) and other particles. Some PM 2.5 , particularly in urban areas, is anthropogenic (man-made) in origin and some is biogenic (natural) in origin. PM 2.5 is composed of primary (directly emitted) and secondary (formed in the atmosphere) parti cles. Current speciation analyses of ambient monitoring data indicate that PM 2.5 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, ammoni um nitrate, and some organic carbon). Figure 7 shows the composition of PM 2.5 at two monitors in the Detroit area.

Figure 7. Average PM 2.5 Composition for Dearborn and Allen Park.

Source: Brown, et. al., 2006.

The largest components of PM 2.5 at the monitors showing nonattainment are ammonium sulfate, ammonium nitrate and organic carbon. So il also is significant at the Dearborn monitor. T he Dearborn and Allen Park monitors are only a few miles apart, but show differences in composition a nd average concentration, indicating that local sources have a large impact on t he Dearborn monitor. Based on EPA’s implementation guidance, primary PM 2.5 and SO 2 must be regulated. NO X must beMichigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 19 regulated unless the state or EPA can demonst rate that NOx is not a significant contributor to PM 2.5 . Since ammonium nitrat e contributes 20-30% of PM 2.5 mass, Michigan determined NO X is a significant contributor to PM 2.5

.

The ambient levels of PM 2.5 have been decreasing in recent years as can be seen in Figure 8. In recent years, all site s with speciated data have had reductions in sulfates and organic carbon. The soil co mponent at Dearborn, which is largely composed of iron, has also decreased, whic h is attributed to additional controls installed at the Severstal steel mill. Regional controls of NO X and SO 2 reduced PM 2.5 in this area and throughout the state, and wil l continue to do so for the next several years. Significant amounts of PM 2.5 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 PM 2.5 standards in 2009 and has conti nued to keep it well within these standards in 2010.

Figure 8. Average PM 2.5 Species Composition by Si te for Three Multi-Year Periods.

Source: LADCO, November 2010Michigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 20 6.2. PM 2.5 Sources

PM 2.5 comes from a variety of local and regional sources. Primary PM 2.5 is directly emitted as a particle and is usually deposit ed on a monitor from nearby sources. However, on occasion, primary PM 2.5 is carried for many miles from forest fires or dust storms before it is deposited. NO X is emitted as a gas, but can convert quickly to a particulate form of a mmonium nitrate. Thus NO X sources can be local sources within a few miles of a monito r, at a greater distance away from the monitor but within the Southeast Michigan region, or from a multi-st ate region. SO 2 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 mu lti-state region, similar to ammonium nitrate.

The Dearborn monitor is located in the indus trialized core of Detroit, which contains a complex array of emission sour ces. In the area of the D earborn monitor, there are a variety of sources of primary PM 2.5 , including steel mills, an auto manufacturer, a refinery, and a variety of smaller stationary sources. Sources of NO X include various sizes of industrial combustion operations and electric generating facilities. SO 2 sources are some of the same combustion operations, particularly large boilers and electric generating facilities burning coal or oil.

Figure 9 provides information on PM 2.5 coming in to Detroit, called background, and PM 2.5 locally generated, called urban excess. The federal regiona l controls address much of the background while controls of lo cal facilities (as well as federal rules for mobile sources) address the ur ban excess. Ammonium sulfat e, mostly from regional sources, has similar concentrations as the regional background, which has been reduced in recent years (2008-2009). Amm onium nitrate comes from local and regional sources and both the local and regiona l contribution has decreased in recent years. Soil is part of the primary PM 2.5 component and has also been decreasing in recent years, especially the local excess. Organic carbon is part of both the primary and secondary PM 2.5 . The local portion is most likely primary PM 2.5 and has been decreasing over recent years. The backg round organic carbon is likely a mix of primary and secondary PM 2.5 and has remained relatively constant in recent years (see Figure 9). This figure shows t hat local concentrations of PM 2.5 have been significantly reduced, helping Sout heast Michigan reach attainment.Michigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 21 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 redes ignation request must demonst rate that the nonattainment area has experienced emis sion reductions that led to the improvement in its ambient air. Secondly, it is required that the emissi on reductions are shown to be permanent and quantifiable. As stated in Section 5, the emission reductions responsible for the continued decline in PM 2.5 levels in the nona ttainment area, and particularly in the Dearborn area, co me from a variety of sources.

The largest emission reductions between 20 05 and 2008 are from the on-road mobile sector. These reductions are primarily due to federal control programs that are permanent and enforceable and t herefore 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 NO X SIP call affecting EGUs. While the EGUs in the nonattainment inventory do not show emission reductions from 2005- 2008, these programs on a regi onal basis are reducing PM 2.5 levels in the air reaching the nonattainment ar ea and contributing to attainment. These control programs are permanent and enforceable and meet the CAA requirement.Michigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 22 Stationary source controls that were included in Southeast Michigan’s PM 2.5 SIP and permanent closure of facilities in the vicini ty of the Dearborn monitor also result in permanent and enforceable emission reductions t hat directly impact the monitors in that area. Appen dix D in this document contains information regarding a number of these sources.

6.4. Stationary Source Facility Details

To further evaluate local st ationary 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 PM 2.5

. Figure 10 shows the location of emissions sources around the D earborn monitor. Changes at many of these sources are analyzed in Appendix D.Michigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 23 Figure 10. Map of Emission Source s 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 N6 631 Dearborn Industrial Generation B3518 United States Gypsum Company N77 23 DTE Energy / Ford World Headquarters
* OOB means out of business Dearborn MonitorMichigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 24 6.5. Other Source Categories

Point source emissions were discussed in Se ction 6.4 and in detail in Appendix D. This section addresses the remaining ar ea 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 PM 2.5 . Mobile sources (including non-road, MAR, and on-road) have also reduced emissions for NO X and SO 2 . Phase in of the Tier 2 mobile vehicle controls, low su lfur gasoline requirements and corresponding diesel rules that puts similar controls on diesel fuel and heavy-duty vehicles are producing significant reduction in mobile em issions. 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 aircra ft, recreational vehicles, di esel marine engines and large industrial spark-ignition engines went into effect between 2005 and 2008 which produced emission reductions in t he MAR and non-road mobile emissions categories.

6.6. Trends Analysis

The 3-year PM 2.5 annual average ( Figure 11) and 3-year 98 th percentile ( Figure 12) for daily PM 2.5 have decreased over the last 10 year s. 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 PM 2.5 standard.Michigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 25 Figure 11. Annual Average of Annual PM 2.5

.

Annual Average PM2.5

7 9 11 13 15 17 19 21

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010Concentration (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 dataMichigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 26 Figure 12. 98 th Percentile Concentration of Daily PM 2.5

.
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 2010Concentration (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 PM 2.5 speciation data in Figure 13 shows a decrease in concentrations each year at the speciated sites in Southeast Mi chigan. While all sites show a decrease mostly due to sulfate reductions, Dear born shows reductions in carbon and soil concentrations as well.Michigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 27 Figure 13. The Average PM 2.5 Species Composition per Site by Year.

Source: LADCO, November 2010

A trend that is statistically significant gi ves greater credibility to trend analysis data than merely observing a downwar d trend. Two statistical te sts, least squares fit and Theil fit regression were preformed by LADCO (September 2010) on the speciated components of PM 2.5 to determine if the downward trends observed in Detroit are statistically significant. Both tests show ed a statistical decrease in organic carbon, ammonium sulfate, ammoni um 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, wh ich were used to calculate a yearly concentration change, there has been an average annual reduction in PM 2.5 of 0.4 to 0.6 μg/m 3 per year. The NO X 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 ar e still uncertain, as will be discussed further below.

Reductions in soil, particularly at the Dearbor n 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 m onitor, and it has been decreasing in recent years.Michigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 28 Figure 14. The Iron Component of Soil (or Crustal) PM 2.5

.

Source: LADCO, November 2010

The Dearborn monitor is in a very industr ialized 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 PM 2.5 standard. The map in Figure 15 shows the population density, indicating high population around t he 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” PM 2.5 concentrations (finer local scale source contributions) above the “network-wide” base concentration (regional background sour ce contributions). The excess local and regional network-wide base concentrations at Dearborn have decreased over the years. In 2008 and 2009, t he 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 nonparametri c wind regression (1-D NW R) indicates the average concentration when winds come from a spec ific wind direction and is particularly useful for identifying sources and their emis sions 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 greates t contributions to the Dearborn monitor. This is the direction of the nearby steel m ill. The graph in the lower right corner ofMichigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 29 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/m 3 over the nine-ye ar 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 PM 2.5 excess mass than other sector s, 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 Ox ygen Furnace. Thus the reduction in PM 2.5 contribution in the southwest sector may be explained by the Severstal controls.Michigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 30 Table 8. Period Averag e Contribution to PM 2.5 (μg/M 3 ) for the Southwest (SW, 165-290 O n) Sector at Dearborn.

Source: Turner, 2010

Positive Matrix Factorization (PMF) indica tes a strong southweste rly influence from a steel (manganese) and zinc factor at the Dearborn monitor (see Figure 16).

Figure 16. Wind Roses of Highest Factor C ontribution Days Resolved by PMF at Allen Park and Dearborn for Industria l Zinc and Steel (Manganese).

Source: Wade, et. al, 2008

Doing PMF modeling using bot h an individual site and multiple site methodology, Wade, et. al. (2008) found over 2 μg/m 3 of PM 2.5 mass are contributed from the steel and zinc factors (the steel and zinc factors total contribute 2.4 μg/m 3 for the individual Dearborn site, or 2.85 for the De arborn multi-site). All of these studies indicate that controls on the steel mill c an and have greatly reduced PM 2.5 contributions from that

source. Dearborn

Allen ParkMichigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 31 Table 9

. Individual-Site (I) and Multi-Site (M) PMF-Resolved Factors for Allen Park and Dearborn. All concentration units are μg/m 3

.

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 da ys with valid data for both sites. PMFmodeled daily contributions from the indi vidual-site modeling of Section 3 were censored to include only those days used fo r 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 m onitor is organic carbon (OC). As stated above, the source s of OC are still not well understood. Figure 17 below indicates a westerly exce ss of OC at the De arborn monitor of 0.17 μg/m 3 . However, this excess is sm all compared to the nearly 3 μg/m 3 reduction in OC that has been seen between 2002 and 2009.Michigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 32 Figure 17. Non-Parametric Wind Regr ession (NWR) on the Excess Species Concentrations at Dearborn Compared wit h 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 us ing 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 source s also contributed over 1⁄2 μg/m 3 to organic mass.Michigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 33 Figure 18. Average Concentration of Organi c Matter by PMF Fact or by Site for All Data.

Source: Brown, et. al. 2006

In CMB studies, carbon mass was apportioned la rgely 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 Apportionm ent of Carbon Mass for Detroit.

Source: Brown, et. al. 2006Michigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 34 Over the past decade the Detroit area has seen a major reduction in employment, particularly in the manufacturing sector (s ee Appendix E for more information). As employment has declined, popul ation 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 car bon reduction at the Dearborn m onitor, since the drop in OC levels resulting from a drop in VMT w ould be expected to be relatively consistent across the southeast Michigan moni tors, which is not the case.

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

Source: SEMCOG, 2010Michigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 35 6. References

Brown, S.G, Hafner, H.R, Roberts, P. T., S heesley, R. J., and Shauer, J. J. (2006). “Integration of Results for the Upper Mi dwest Urban Organics Stud y,” prepared by Sonoma Technology, Inc. (Petaluma, CA), and University of Wisconsin (Madison, WI), submitted to LADCO.

LADCO, 2010. “PM 2.5 Speciations Trends,” for SEMOS meeting, November 17, 2010.

LADCO, 2010. “Air Quality Overview,” for Project Team Meeti ng, 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). “Asse ssing 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 PM 2.5 Conceptual Model September Update,” for SEMOS meeting, Sept. 30, 2010.

Wade, K.S.; Turner, J.R.; Br own, S.G; Garlock, J.L., Ha fner, H.R. (2008). “Data analysis and source apportionment of PM 2.5 in selected Midwestern cities,” Report # STI-907018.03-3264-FR (February 2008), prepar ed by Sonoma Technology, Inc. (Petaluma, CA), submitted to LADCO.Michigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 36 7. Maintenance Plan

A maintenance plan must demonstrate cont inued attainment for at least 10 years after approval of a redesignation. Section 17 5A of the CAA sets forth the elements of a maintenance plan for areas seeking redes ignation from nonattainment to attainment. Eight years after t he redesignation, a revised maintenance plan for the next ten years must be submitted to the EPA. To address the po ssibility of future NAAQS violations, the maintenance plan mu st contain contingency measures.

Continued future attainment is demonstrat ed 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 PM 2.5 , NO X , and SO 2 emissions are shown to remain below attainment year 2008 emissions levels, insuring that the area remains in attainment.

Reductions in PM 2.5 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 program s 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 Michi gan’s mercury rule but reductions from these sources are expected. The EPA has also developed new NAAQS for NO X and SO 2 which may further reduce primary PM 2.5 , SO 2 and NO X in Southeast Michigan. Voluntary diesel strategies such as clean school bus programs will result in additional PM 2.5 reductions. The maintenance plan inv entory emissions totals for primary PM 2.5 , NO X , and SO 2 are provided in Table 10 for annual PM 2.5 and Table 11 for daily PM 2.5 . 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 Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 37 Table 10. Maintenance Plan Em ission Inventories for annual PM 2.5 , 2008-2022. All units are in tons per year.

NOx SO 2 PM 2.5
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 18,59 0.74 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 Em ission Inventories for Daily PM 2.5 , 2008-2022. All units are in tons per winter day.

NOx SO 2 PM 2.5 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 PM 2.5 inventory effort was to produce emission inventories for the nonattainment year (2005) and the attainm ent year (2008). The future year projections (2018 and 2022) take into a ccount 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 pr oduct were grown from the LADCO Base B (2007, 2008) Inventory. Wher e 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 SEMC OG. 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 mainte nance plan covering the next ten-year period.

The MDEQ will continue to track PM 2.5 levels through the operation of an EPAapproved monitoring network as necessary to demonstrate ongoing compliance with the NAAQS. Data will be entered into the Ai r Quality System on a timely basis in accordance with federal regulations. T he MDEQ will continue to produce periodic emission inventories as required by the federal Consolidated Emissions Reporting Rule (40 CFR, Part 51) to track future leve ls of emissions. The control measures for PM 2.5 , SO 2 and NO X emissions that were contained in the SIP before redesignation of these areas to attainment will be retai ned, 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 PM 2.5 increases in response to identified triggering events.

Action Level Response An Action Level Response will be prom pted when a two-year annual average of 15 μg/m 3 or a two-year 98 th percentile average monitored value of 35 μg/m 3 or higher occurs within the maintenance area. A review of circumstances leading to the high monitored values will be conduc ted if this response is triggered. The MDEQ will explore whether a special event, malf unction, or noncompliance with permit conditions resulted in high PM 2.5 levels in order to im mediately address corrective measures. The MDEQ will also review meteorological conditions during high PM 2.5 episodes. This review will be conducted withi n six months following the close of the PM 2.5 year. If the MDEQ determines that contingency measure implementation is necessary to prevent a future violati on, the MDEQ will sele ct and implement a measure that can be im plemented promptly.

Contingency Measure Response If a violation of the PM 2.5 NAAQS occurs, Michigan will select one or more control measures from the following list of potential contingency m easure for implementation. The timing for implementation of a conti ngency 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. Ot her measures will need state administrative rulemaking or legi slative approval. The MDEQ will seek to expedite the process of securing enabling authority and implementing the selected measures as needed to reduce PM 2.5 levels, with a goal of having measures in place as expeditiously as practicabl e, and within 18 months afte r state certification of the violation. Opportunity for public partici pation in the conti ngency measure responseMichigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 39 will be provided. The MDEQ will submit the identifi ed enforceable contingency measures to the EPA as revi sions 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 Se ction 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 t hat transportation activities will not produce new air quality violations, wo rsen existing violations, or delay timely attainment of the NAAQS.

Estimates of on-road motor vehicle emissi ons from cars, buses, and trucks driven on public roadways are projected for the ma intenance period to assess emission trends and to ensure continued compliance with the PM 2.5 NAAQS. These estimates are considered a ceiling or “budget” for emi ssions and are used to determine whether transportation plans and projects conform to the SIP. Estimated on-road mobile emissions of PM 2.5 and NO X must not exceed the emissi on budgets contained in the maintenance plan. The emissions estimate s for this sector re flect appropriate and up-to-date assumptions about vehicle miles traveled, socioeconomic variables, fuels used, weather inputs, and ot her planning assumptions. On-road emissions have been projected to 2022 in t he maintenance inventory.

Typically, the formula for calculati ng maintenance conformity budgets is:

On-road emissions inventory for main tenance year + safety margin

Where: safety margin = 90% of emissions reduction from all sources between the attainment year and t he 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 budget s are higher than the attainment year emissions inventory. Therefore, the final budgets will be se t equal to the 2008 on-road emissions inventory. T hese 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, Wa shtenaw, and Wayne Counties.

Annual PM 2.5 , Ton per year

PM 2.5 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 PM 2.5 , Tons per day.

PM 2.5 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 380.6Michigan Department of Environmental Quality Proposed Request to Redesignate Southeast Michigan Counties July 2011

Page 42 Table 13. Final Motor Vehicle Transportati on Conformity Budget Calculation for Annual PM 2.5

. In tons per year.

Tons/Year

PM 2.5 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 Tr ansportation Conformity Budget Calculation for Daily PM 2.5

. In tons per day.

Tons/Winter Weekday

PM 2.5 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 PM 2.5 redesignation documents and notice of the public comment period and opportunity to r equest 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 r equest, including the baseline emissions inventory for PM 2.5 , SO 2 and NO X and the maintenance plan SIP revision was held on May 26, 2011, at Constitution Hall in Lansing, Michigan.

A summary of comments received and t he MDEQ responses are included in Appendix F.