pp

Sulfur Dioxide Designation Recommendations 

for the 2010 S02 NAAQS 

s•.;•. 

Michigan Department of Environmental Quality 

Air Quality Division 

P.O. Box 30260 

Lansing, Michigan 48909-7760 

September 18, 2015 
Michigan Impacts ......................... ........................................................................................... 1 

Summary of Modeling ......................... ... ............................. ... ............................................... .. 2 

Recommended Attainment Areas ........... .... ............................ ....... .......................................... a 

Recommended Nonattainment Area ....................................................................................... 8 

TABLES 

Table 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/Erickson 

Power Plant ......................................... .................................. ............................. 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 ........................................ 7 

Isopleth and Max. Impact for the Belle River/St. Clair Power Plants .................... 7 

Proposed S02 1-hour Nonattainment Area ......................................................... 10 

2012-2014 Michigan/Wisconsin 1-hour S02 Monitor Design Values 

IDEM Modeling for Michigan City Generating 

Modeling Protocols/Reports 

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Eaton, Ingham, Marquette, Monroe, and Ottawa be designated as attainment. 

The recommended geographical boundary of the St. Clair County nonattainment area was determined 

using dispersion modeling, emissions-related data, meteorology, geography/topography and 

jurisdictional boundaries as outlined in the USEPA's guidance memorandum dated March 20, 2015. 

Our recommendations for the county level attainment areas follow the corresponding methodology in 

this same guidance. A description of the MDEQ's analysis for both the nonattainment area and the 

attainment areas is provided in this document. 

iii 
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 S02 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 S02, had a 

2012 emission rate of at least 0.45 pounds (lbs) S02 per million BTU (mmbtu), and that has not 

been announced (as of March 2, 2015) for retirement. State designation 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 S02 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 emission monitoring (CEMS) data and seasonal background 

concentrations, yielded no violations of the S02 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 S02 

designation recommendations for the areas surrounding these facil ities. The companies that 
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 S02 NMOS Designations Modeling Technical Assistance Document (TAD), 

dated December 2013, to provide guidance on the use of modeling data when determining if an 

area is meeting or not meeting the 2010 S02 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 

Plant, 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 S02 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 National 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 991h 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 S02 monitoring in Lansing. The 

2012-2014 design value at this station is 17.9 ppb, indicating that the area is meeting the 

1-hour S02 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 S02 design value of 17.9 ppb as the background to be added to the predicted 

2 
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 design 

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 impact 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 S02 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 this impact to the 6.8 ppb ambient 

background derived from the Forest County, Wisconsin monitoring station yields a total 

impact of 39.9 ppb. The 39.9 impact meets the 1-hour S02 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 S02 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 S02 data exist for this site, a background 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 proximity, DTE modeled the 

Belle River and St. Clair Power Plants in the same AERMOD analysis. 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 S02 

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 S02 emissions in St. Clair County. Using ambient air monitoring 

data from the Port Huron monitor, the MDEQ determined an ambient background of 

15 ppb S02 was appropriate for St. Clair County. This background was derived 

3 
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 Background 

County Facility Name the 99% daily Concentration 1 Combined S02 max. 1-hour Impact (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 Erickson Power 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 15.0 131.7 Clair Power Plant 

1 One-hour S02 backgrounds for the Dan E. Karn/J.C. Weadock Complex and Eckert/Erickson Power Plants are from 

the Lansing monitor; background for the J.H. Campbell Plant is from the Grand Rapids monitor; background for the 

Presque Isle Plant is from Forest County, WI; background for the Monroe Power Plant is from 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 results displayed in Table 1, five of the six facilities/groups have 

combined impacts (facility, 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 S02 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 Figure 6 illustrates 

predicted areas of nonattainment. Note: The isopleths do not include background 

concentrations of S02. 

4 
Figure 2. Isopleth and Max. Impact (ppb) for the Eckert Power Station/Erickson Power 

Plant 

UTM East (m) 

5 
Figure 4. Isopleth and Max. Impact (ppb) for the We Energies Presque Isle Power Plant 

6 
Figure 6. Isopleth and Max. Impact (ppb) for the Belle River/St. Clair Power Plants 

7 
March 20, 2015, USEPA guidance. Therefore, the MDEQ recommends an attainmen,t 

designation for the 1-hour S02 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 S02 NAAQS. As such, the USEPA's guidance requires the MDEQ to 

consider air quality data, emissions-related data, meteorology, geography/topography and 

jurisdictional boundaries in determining the nonattainment area boundaries. 

Air Quality Data: The MDEQ collects S02 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 modeling 

predicts that the area should remain in attainment, the MDEQ recommends the City of Port 

Huron not be in the nonattainment area. 

Emission-Related Information: As described in the previous section, the only significant sources 

of S02 in St. Clair County are the Belle River and St. Clair Power 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 facilities, the 

data does have a high percentage of calms. Using Pontiac meteorological 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 proximity 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 international 

boundary with Canada. As such, it forms a natural boundary for the recommended 

nonattainment area to the east. 

Jurisdictional Boundaries: As described above, those areas with modeled concentrations 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 modeling 

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 approximately four 

miles to the north of Smiths Creek Road. 

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State Highway M-29 to Church Road to Arnold Road to County Line Road on the south; County 

Line Road and the Macomb County/St. Clair County boundary to Stoddard Road to Wales 

Ridge Road on the west; and Alpine Road to Fitz Road to Smiths Creek Road to Range Road to 

Huron Avenue to the St. Clair River on the north. 

9 
10 

• Top Contributing S02 Sources C S02 Nonattalnment Area 

/'../ 75 ppb S02 (source plus background) 

p

Forest County, WI 6.8 

Lansing 17.9 

Port Huron 69.4 

Sterling State Park, Monroe* 18.2 

* Two 

years of data only. 

NIPSCO Michigan City 2012-2014 CEMS Hourly Emissions Data Boiler 12 

1-HOUR 502 MODEUNG CONSENT DECREE LAPORTE COUNTY NIPSCO BOILER 12 

- 45.0 

-60.0 

- 75.00001 

- 90.00001 

- 105.0 

- 120.0 

- 135.0 

- 1500 

- 1650 

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121. 

126. 

130. 1 

129. 1 

141. 

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138. 

142. 

141. 

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. 144. 141. 

76 96.07 98.46 96.63 10 . . . . . 

100. 102. 10 

106. 105. 10 

102. 1~0 

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94.3394.5497.4796.43 103. hog_ 1o~106. 98. 

. . . ,;, "'~ "' ~ 

104. 103. 01 ~8. 110. 10 

101. 103. 105. 105. 103. 1b5. 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= 165.061 (506800, 4618200) 

AERMOD 15181 2012-2014 Gary IITRI Meteorology Hourly Seasonal Background Concentrations