SupportDocumentforSulfurDioxideDesignationRecommendationsforthe2010S02NAAQSs•.;•.MichiganDepartmentofEnvironmentalQualityAirQualityDivisionP.O.Box30260Lansing,Michigan48909-7760September18,2015TABLE OF CONTENTS
Page No. Executive Summary .........

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1 Michigan Impacts .... ..................

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# a Recommended Nonattainment Area .....

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1 FIGURES Figure
1 Figure 2 Figure 3 Figure 4 Figure 5 Figure 6 Figure 7 Appendix 

### A: Appendix

B : Appendix
C : Source Modeling lmpacts .... .. ..... .........................................................................

4 Isopleth and Max

. Impact for the Dan E . Karn Generating Complex ....................

5 Isopleth and Max. Impact for the Eckert Power Station

/ Er ickso n Power Plant ............................

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. .. ...... 5 Isopleth and Max. Impact for the J.H

. Campbell Generating Complex ............. .... 6 Isopleth and Max

. Impact for the We Energies Presque Isle Power Plant ...... ..... 6 Isopleth and Max

. Impact for the Monroe Power Plant .....

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. . .... 7 Isopleth and Max

. Impact for the Belle River/St. Clair Power Plants ............

.. . ..... 7 Proposed S0 2 1-hour Nonattainment Area .........

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. ......... ......... 10 2012-2014 Michigan/Wisconsin 1-hour S0 2 Monitor Design Values IDEM Modeling for Michigan City Generating Modeling Protocols/Reports



### iiEXECUTIVESUMMARYTheMichiganDepartmentofEnvironmentalQuality(MDEQ)issubmittingitsrecommendeddesignationsforthe1-hoursulfurdioxide(S02)NationalAmbientAirQualityStandard(NAAQS).TheserecommendationsarebasedonthedispersionmodelingoftheeightlargeS02sourcesidentifiedbytheUnitedStatesEnvironmentalProtectionAgency(USEPA)inaletterdatedMarch20,2015,fromActingAssistantAdministratorJanetMcCabe.Specifically,theMDEQisrecommendingasub-countyboundaryinSt.ClairCounty,Michiganbedesignatedasnonattainment,andthatthecountiesofBay,Eaton,Ingham,Marquette,Monroe,andOttawabedesignatedasattainment.TherecommendedgeographicalboundaryoftheSt.ClairCountynonattainmentareawasdeterminedusingdispersionmodeling,emissions-relateddata,meteorology,geography/topographyandjurisdictionalboundariesasoutlinedintheUSEPA'sguidancememorandumdatedMarch20,2015.Ourrecommendationsforthecountylevelattainmentareasfollowthecorrespondingmethodologyinthissameguidance.AdescriptionoftheMDEQ'sanalysisforboththenonattainmentareaandtheattainmentareasisprovidedinthisdocument.iiiIntroduction The United States Environmental Protection Agency (USEPA) revised the primary Nat

i onal Ambient Air Quality Standard (NAAQS) for sulfur dioxide (S0 2 ) on June 2 , 2010

. The newshortterm standard
is based on the 3-year average of the ggt h percentile of the yearly distribution of 1-hour daily maximum concentrations

. This level was set at 75 parts per billion (ppb)

. In July 2013

, the USEPA identified areas in 16 states as nonattainment and expressed their intent to address designations for the remainder of the country in future actions. On March 2, 2015, a consent decree was reached between the USEPA

, the Sierra Club and the Natural Resources Defense Council to resolve litigation concerning the deadline for completing these other 1-hour S02 designations

. In the consent decree, the USEPA agreed to complete the designations

in three rounds

, with the first round to be completed by July 2 , 2016

. On March 20
, 2015

, the USEPA updated guidance to the states on designating areas. Areas will be designated as either attainment

, nonattainment

, or unclassifiable. The first round of designations are for two groups of areas

: 1) areas that have newly monitored violations of the 2010 S0 2 standard

; and 2) areas that contain any stationary source that emitted more than 16

, 000 tons of S02 in 2012 or emitted more than 2 , 600 tons of S0 2 , had a 2012 emission rate of at least 0.45 pounds (lbs) S0 2 per million BTU (mmbtu)

, and that has not been announced (as of March 2, 2015) for retirement. State designat

i on recommendations

to the USEPA for these areas must be submitted by September 18 , 2015. Michigan Impacts For the first round of designations as described
in the consent decree

, there are no additional areas in Michigan with newly monitored violations of the 2010 S0 2 standard. The USEPA has identified the following facilities as falling within the emission levels referenced above

: • Dan E. Karn/J

. C . Weadock Generating Complex
in Bay County (Consumers Energy) • Erickson Power Plant in Eaton County (Lansing Board of Water and Light) • Eckert Power Station in Ingham County (Lansing Board of Water and Light) • Presque Isle Power Plant in Marquette County (We Energies) • Monroe Power Plant in Monroe County (DTE) • J.H. Campbell Generating Complex
in Ottawa County (Consumers Energy) • Belle River Power Plant in St. Clair County (DTE) • St. Clair Power Plant in St. Clair County (DTE) The USEPA also identified the Michigan City Generating Station in Laporte County, Indiana as potentially impacting areas in Michigan

. The facility is located approximately
10 kilometers (km) from the nearest Michigan border. The Indiana Department of Environmental Management (IDEM) was contacted to investigate potential impacts from this source within Michigan and determine

if any resulting attainment issues could exist. IDEM responded that their review of the facility

, using continuous emiss

i on monitoring (CEMS) data and seasonal background concentrations

, yielded no violations of the S0 2 NAAQS threshold

. As such

, no attainment issues are expected
in the southwest corner of Michigan as a result of this facility

. The Michigan Department of Environmental Quality (MDEQ) is responsible for developing S0 2 designation recommendations
for the areas surrounding these facil

i ties

. The companies that

## own the eight affected facilities agreed to perform the necessary dispersion modeling to determine their S0 2 impacts and to determine

if the 1-hour NMOS was being violated. Based on this analysis

, the MDEO is providing recommendations

to the USEPA on appropriate S0 2 attainment and nonattainment areas

. Summary of Modeling The analysis began with the MDEO requesting each facility to provide
a modeling protocol that included the facility description

, model selection, emissions characterization

, source description

, background concentration

, meteorology

, modeling domain and off-site emissions inventory. The draft modeling protocols were reviewed by the MDEQ and the USEPA. The facilities then finalized the protocols by incorporating the revisions suggested by the MDEQ and the USEPA. These protocols and modeling results can be found in Appendix C. The MDEO followed US EPA guidance throughout the modeling and designation process

. The USEPA updated designation guidance with a March 20 , 2015

, document. The USEPA also provided
a Draft S0 2 NMOS Designations Modeling Technical Assistance Document (TAD), dated December 2013, to provide guidance on the use of modeling data when determining

i f an area is meeting or not meeting the 2010 S0 2 standard

. Modeling of the facilities was carried out on an individual basis

, except for the Eckert Power Station in Ingham County and the Erickson Power Station in Eaton County

, which are less than 10 km apart, and the Belle River Power Plant and the St. Clair Power P
l ant
, both in St. Clair County

, which are just over 2 km apart

. Because of their close proximity to one another

, the two sets of facilities were modeled together

. Table
1 summarizes the results from the modeling runs and the background S0 2 concentration for each area. The final column represents the expected highest impacts by adding the modeled high value and background value for each modeled source or group of sources

. A narrative describing the individual facility modeling follows. • Dan E. 

## Karn/J.C. Weadock Generating Complex: The modeling for this facility was carried out by Horizon Environmental on behalf of Consumers Energy using the AERMOD model with 2012-2014 hourly meteorological data from the Nat

i onal Weather Service station at the MBS International Airport in Freeland

, Michigan

. The facility was modeled by itself because no other S02 sources were found in the immediate area. The maximum 3-year average of the 99

1 h 

## percentile of the maximum daily 1-hour concentrations for the off-site receptors was found to be 28

. 9 ppb

. Adding an ambient background concentration
of 17

. 9 ppb derived from the MDEO's Lansing monitoring station gives a total predicted impact of 46

. 8 ppb, which is well below the NMOS of 75 ppb. • Erickson/Eckert Power Stations: The MDEQ carries out S0 2 monitoring
in Lansing

. The 2012-2014 design value at this station is 17

. 9 ppb

, ind

i cating that the area is meeting the 1-hour S0 2 NAAQS. Still

, modeling was conducted for the Erickson/Eckert power plants by 

# NTH Consultants for the Lansing Board of Water and Light. This modeling was carried out using AERMOD coupled with 2012-2014 meteorological data from Lansing Capital Region International Airport

. Off-site sources included
in the modeling were Michigan State University, Thompsen-McCully Asphalt and Superior Asphalt. Using the Lansing S0 2 design value of 17

. 9 ppb as the background to be added to the predicted 

# 2facility impact of 35.4 ppb, the resulting total impact is 53.3 ppb

. This is much less than the NAAQS of 75 ppb

. • J . H . Campbell Generating Complex: Horizon Environmental carried out modeling of the J . H . Campbell Generating Complex for Consumers Energy with AERMOD using 2012-2014 meteorological data from Muskegon County A ir port located in Norton Shores

, Michigan

. No other sources of S0 2 were found to exist near the J . H. Campbell plant. While MDEQ operates an S0 2 monitoring station in West Ol

i ve where the J . H . Campbell plant is located, that station began operating
in January 2015, so data from that station is not yet available to compute an ambient background. As such, the 10.3 ppb des

i gn value recorded at the MDEQ

' s Grand Rapids air monitoring station was considered as the ambient background

. Adding the 10.3 ppb to the predicted facility

i mpact of 42.8 ppb yields a total impact of 53

. 1 ppb

. This level of impact is well below the NAAQS of 75 ppb. • Presque Isle Power Plant: AERMOD modeling for the Presque Isle Power Plant was conducted for We Energies by Trinity Consultants. Meteorological data from Munising, Michigan for the years 2012-2014 was used

. Marquette Board of Light 

### & Power and Northern Michigan University were both identified as S0 2 sources to be included in the modeling analysis. The predicted impact from the Presque Isle Power Plant and the other sources was found to be 33.1 ppb

. Adding th

i s impact to the 6 . 8 ppb amb

i ent background derived from the Forest County

, Wisconsin mon

i toring station yields a total impact of 39

. 9 ppb. The 39

. 9 impact meets the 1-hour S0 2 NAAQS

. • Monroe Power Plant: DTE conducted modeling using AERMOD for the Monroe Power Plant. Meteorological data for the years 2012-2014 from Monroe Custer Airport was used by DTE in this modeling

. The MDEQ operates an S0 2 air monitoring station at Sterling State Park in Monroe, which is located just to the north of the Monroe Power Plant. While only two years of S0 2 data exist for this site

, a bac k ground of 18

. 2 ppb was derived from this data as a conservative estimate. Sources in addition to the Monroe Power Plant used in the analysis include IKO Monroe

, Guardian Industries and Gerdau MacSteei-Monroe. Monroe Power Plant emission rates for the modeling were the allowable rates in the current air permit

, reflecting the operation of wet flue gas desulfurization systems on all four units

. DTE

' s modeling predicted

a maximum facility and other source impact of 42

. 8 ppb. Adding the 18

. 2 ppb background estimate to this impact gives a total impact of 61 ppb. This is below the 75 ppb NAAQS

. • Belle River/St. Clair Power Plants: Because of their close pro xi mity, DTE modeled the Belle River and St. Clair Power Plants in the same AERMOD ana

l ysis. Two sets of meteorological data from 2012-2014 were used in these runs: Pontiac and Port Huron. While both data sets were collected by the National Weather Service at airports, the Pontiac data was based on 1-minute averaging times. The Port Huron data was based on 1-hour averaging times

. The Pontiac data was preferred by the USEPA because

, even though Pontiac was farther away

, it had a lower incidence of calms

. A review of 2013 emission inventory information identified

E
. B Eddy and Cargill Salt as having S0 2 emissions that could potentially impact the modeling of the Belle River
/ St. Clair Power Plants

. However

, the 2013 inventory data did not account for the fact both of these sources have shut down their coal-fired boilers

. Therefore

, there were no other significant sources of S0 2 emissions
in St. Clair County. Using ambient air monitoring data from the Port Huron monitor

, the MDEQ determined an amb

i ent background of 15 ppb S0 2 was appropriate for St. Clair County

. This background was derived 

### 3considering only monitor concentrations when the wind was blowing from direct io ns other than from the Belle River/St. Clair facilities or from sources located in Sarnia

, Ontario

. Avoiding these sectors was crucial so the final predicted impact would not " double count" facility impacts

. A background of 15 ppb is also consistent with the Allen Park-derived background that was used in the Wayne County S0 2 State Implementation P
l an (SIP) analysis

. The MDEQ found using the Pontiac meteorological data resulted in a hotspot impact that was appro x imately 12 ppb higher than the Port Huron data. This impact of 116.7 ppb

, when added to the 15 ppb ambient bac k ground produced

a total impact of 131.7 ppb. This value exceeds the NAAQS for the 3-year average of the ggth percentile of daily maximum concentrations

. Table 1. Source Modeling Impacts 3-year average of Bac kgrou nd County Faci

l ity Name

the 99% daily Concentration

1 Combined S0 2 max

. 1-hour

I mpact

( ppb) (ppb)

(ppb) Bay

Dan E. Karn /J.C. Weadock

28

. 9
17

. 9 46.8 GeneratinQ Complex Ingham

/ Eckert Power Station/ 35.4 17.9 53.3 Eaton
Eri ckso n Po we r Plant Ottawa

J . H . Campbell Generating

42 .8 10.3 53.1 Complex Marquette

We Energies Presque Isle 33.1
6.8 39.9 Power Plant Monroe Monroe Power Plant 42.8 18.2 61.0 St. Clair

Belle River Power PlanUSt. 116.7

15 .0

1 3 1 . 7 Clair Po wer Plant 1 One-hour S0 2 backgrounds for the Dan E . Karn/J.C

. Weadock Complex and Ec kert/ Eric kson Power P
l ants are from the Lansing monitor

; background for the J.H

. Campbell Plant

i s from the Grand Rapids monitor; ba ckg ro u nd fo r the Presque Isle Plant is from Forest County, WI
; background for the Monroe Power P lant is f r o m the Sterling State Park monitor in Monroe; and the background for Belle River/St. Clair Plants is from the Port Huron monitor. The design values for these monitoring stations are included
in Appendix A. Based on the modeling resu

l ts displayed
in Table 1, five of the six facilities/groups have comb

i ned impacts (faci

l ity , additional sources
if applicable, and background

) that meet the 1-hour S02 standard

. The combined modeling analysis for the Belle River Power Plant and the St. Clair Power Plant resulted in impacts above the 1-hour S0 2 standard. Figures

1 through
6 show concentration isopleth plots and the maximum impact area for each of the six modeling demonstrations

. Figures

1 through
5 demonstrate areas in attainment and F
i gure 6 illust

r ates predicted areas of nonattainment. Note: The isopleths do not include background concentrations
of S0 2.



### 4

# Figure 1. Isopleth and Max

. Impact (ppb) for the Dan E. Karn Generating Complex Figure
2 . Isopleth and Max. Impact (ppb) for the Eckert Powe

r Station/Erickson Power Plant

UTM East (m ) 

# 5

### Figure 3. Isopleth and Max. Impact (ppb) for the J.H. Campbell Generating Complex U T M East (m] 

### Figure 4. Isopleth and Max. Impact (ppb) for the We Energies Presque Isle Power Plant 6

### Figure 5. Isopleth and Max. Impact (ppb) for the Monroe Power Plant Figure 6. Isopleth and Max

. Impact (ppb) for the Belle River/St. Clair Power Plants 

### 7

## Recommended Attainment Areas Based on the source modeling described above

, the areas surrounding the following facilities are found in attainment of the 2010 S0 2 1-hour NAAQS: Dan E. Karn
/ J.C

. Weadock Generating Complex

, Erickson Power Plant and Eckert Power Station, We Energies Presque Is

l e Power Plant

, Monroe Power Plant, and J . H. Campbell Generating Comple x. For each

, the MDEQ recommends attainment boundaries to include the entire county in which the facility resides

. This follows the recommended approach for facilities modeling atta

i nment as described
in the March 20, 2015

, USEPA guidance

. Therefore, the MDEQ recommends an attainmen,t designation for the 1-hour S0 2 NAAQS for Bay County

, Eaton County, Ingham County

, Marquette County

, Monroe County and Ottawa County

. Recommended Nonattainment Area As shown in Table

1 , modeling of the Belle River/St. Clair Power Plants revealed impacts exceeding the 1-hour S0 2 NAAQS

. As such

, the USEPA

' s guidance requires the MDEQ to consider air qual

i ty data

, emissions-related data

, meteorology

, geography/topography and jurisdictional boundaries

in determining the nonattainment area boundaries

. Air Quality Data

: The MDEQ collects S0 2 data at its Port Huron air quality monitoring station located on Dove Road. The design value for this station is 69 ppb which meets the NAAQS

. Given the monitoring data meets the NAAQS and the Belle River
/ St. Clair Power Plant model

i ng predicts that the area should remain in attainment, the MDEQ recommends the C

i ty of Port Huron not be in the nonattainment area. Emission-Related Information

: As described
in the previous section

, the only signif

i cant so u rces of S0 2 in St. Clair County are the Belle River and St. Clair Powe

r Plants

. As such, the _ nonattainment area will be Belle River/St. Clair-centric

, as there are no additional sources contributing
to the nonattainment area. Meteorology

: The Belle River and St. Clair Power Plants were modeled with AERMOD using both Port Huron and Pontiac meteorological data. While Port Huron is closer to the facili ti es , the data does have a high percentage of calms. Using Pontiac me t eorological data does produce
a maximum impact that is 12 ppb higher than predicted using Port Huron data, but both data sets predict areas of nonattainment. And

, in both cases

, the area of nonattainment

is confined to St. Clair County

. Geography/Topography: There is no elevated terrain in close pro x imity to the Belle River/ St. Clair Power Plants. However

, the plants are located on the St. Clair River

, which may cause some channelization
of the winds, suggesting that perhaps Port Huron meteorological data should be used in future modeling analyses

. The St. Clair River also forms the

i nternat

i onal boundary with Canada. As such

, it forms a natural boundary for t he recommended nonattainment area to the east. Jurisdictional Boundaries

: As described above

, those areas with modeled concen tr at

i ons above the 1-hour NAAQS and on American soil are all confined to St. Clair County. However

, Figure 6 shows that not all of St. Clair County is predicted to be in nonattainment. The 75 ppb model

i ng isopleth extends only as far north as Smiths Creek Road

. Using Smiths Creek Road as the northern boundary of the nonattainment area is substantiated by the 69 ppb design value measured at the MDEQ

' s Port Huron monitoring station

, which is located appro x imately four miles to the north of Smiths Creek Road.



# 8While75ppbisnotexpectedtooccurinthefarsouthernorwesternportionsofSt.ClairCounty,theMDEQdoesnotwishtocarveoutirregularlyshapedareasofattainmentsurroundedbynonattainmentinthesamegeopoliticalarea.Therefore,theMDEQrecommendsthatthenonattainmentareaextendtotheremainingportionsofsouthernandwesternSt.ClairCounty.Basedupontheseconsiderations,theMDEQisrecommendingtheUSEPAdesignatethesubcountyareaofSt.ClairCountyshowninFigure7asnonattainmentforS02.Specifically,theareawouldincludethatportionofSt.ClairCountydefinedbytheSt.ClairRiverontheeast;StateHighwayM-29toChurchRoadtoArnoldRoadtoCountyLineRoadonthesouth;CountyLineRoadandtheMacombCounty/St.ClairCountyboundarytoStoddardRoadtoWalesRidgeRoadonthewest;andAlpineRoadtoFitzRoadtoSmithsCreekRoadtoRangeRoadtoHuronAvenuetotheSt.ClairRiveronthenorth.9

# Figure 7. Proposed S0 2 1 - hour Nona tt ainment Area Sulfur Dioxide (802) 

# Nonattainment Area 

# 10

• Top Cont

r ibuting S02 Sou
r ces 

# C S02 Nona tt al n ment Area /'../ 75 ppb S02 (source
p lu s b ackg

r ound)APPENDIX

A 2012-2014 Michigan/Wisconsin 1-hour 80 2 Monitor Design Values

### 2012-2014 Michigan/Wisconsin

1 - hour 

### 50 2 

### Monitor Design Values Monitor Location

3-year

1 - hour S0 2 Design Value 

### (ppb) Grand Rapids

10

. 3 Forest County

, WI

6.8 Lansing

17

. 9 Port Huron

69.4 Sterling State Park

, Monroe

*
18.2 * Two y ears of data onl y.APPENDIX

B IDEM Modeling for Michigan City Generating

# NIPSCO Michigan City 2012-2014 CEMS Hourly Emissions Data Bo i ler 12 1-HOUR 502 MODEUNG CONSENT DECREE LAPORTE COUNTY N I PSCO BOILER 12



# - 45 . 0 -60 . 0

- 7 5 . 00001

- 90 . 000 0 1

- 10 5 . 0

- 1 20 . 0

- 135 . 0

- 1 5 00

- 1650


# \ 11 1 .



# 1 1 1 . 

# h. 5 . I 121 . 126 .

130 . 1 129 . 1 

# 141 . 141 . 1 138 . 142.
14 1 . 144 . 144 . 142. 139 . 138 . 144 . 

# i 123 . 126 . 134 . 140 . 140 . 143 .

**1~3**
**. 1~5** 
**. 1~**  **1~**
**. ~0**  **. 1~1** 
**. 1~0** 
**. 1~1** 
**.** 

# 124 . 123 . 127 . 

# .,6. 1 44 . 141 . 76 96 . 07 98 . 46 96 . 63 10


# . . . . . 1 00 . 102 . 10 106 . 105 . 10 102 .


# 1~0

**_1594 61**  **1~3**
**. ~~**  94 . 3394 . 5497.4796 . 43 103 . hog _ 

# 1o~106

**.** 98 .



# . . . 

# ,;,

**"'~** 

# "'

**~** 104 . 103 .

**01 ~8** 

**.** 

# 110 . 10 101 . 103 . 105 . 105 . 103 . 1 b 5 . 109 . 10 100 . 102 .



# 1~4 **~~** 107 . 10 99 : 56

**1~1**
**.** 

# 10

_ 1 .

**1~3**
**. ~**  **1~7**
**. 10~**  

# 99 : 09



# 1~1
**.** 99 . _ 63



# 1~2. **1~3**
**.** v.5 .



# 1~4
**. 1~**  100 . 99 . 37 99 . 69 101 . 104 . 105 . 103 . 10

SCale : 1 " = 309 . 4 Meters GROUP NIPSCOMC- 4TH-HIGHEST MAX DAILY 1 -HR VALUES AVERAGED OVER 3 YEARS Max= 1 65 . 061 

# (506800 , 4618200) 

# AERMOD 15181 2012-2014 

# Gary IITR I Meteorology Hourly Seasonal Background ConcentrationsAPPENDIX
C Modeling Protocols/Reports