## INDIANA DEPARTMENT OF 

## ENVIRONMENTAL MANAGEMENT We Protect Hoosiers and Our Environment. Mitchell E. Daniels Jr. 100 North Senate Avenue Governor Indianapolis, Indiana 46204 (31 7) 232-8603 Thomas K Easterly Toll Free (800) 451-6027 Commissioner www.idem.lN.gov

E



### Mr. Bharat Mathur January 21, 2010 

### Acting Regional Administrator U.S. Environmental Protection Agency Region 5 

### 77 West Jackson Boulevard Chicago, IL 60604-3950

Re: Request for Redesignation Petition and Maintenance Plan for Ozone Attainment for the Indiana Portion of the Cincinnati-Hamilton, OH-KY-IN 8-Hour Ozone Nonattainment Area

Dear Mr. Mathur:

With this letter the Indiana Department of Environmental Management (IDEM) submits the final Redesignation Petition and Maintenance Plan for the Indiana portion of the CincinnatiHamilton, OH-KY-IN, 8-hour ozone nonattainment area (Lawrenceburg Township in Dearborn County). IDEM conducted a public hearing concerning the Redesignation Petition and Maintenance Plan on January 7,201 0. The public comment period concluded on January 13, 201 0 and no comments were received.



### i The attached document consists of the following:

f 

### Redesignation Petition and Maintenance Plan A formal request that the Indiana portion of the Cincinnati-Hamilton, OH-KY-IN nonattainment area (Lawrenceburg Township in Dearborn County) be redesignated to attainment and reclassified as "maintenance". It contains and meets the requirements
set forth in Section 107 of the Clean Air Act and in U.S. EPA Redesignation Guidance. 

# I A maintenance year of 2020 is established and 201 5 

### is analyzed as an interim year.
The appendices of the document contain historic air quality trend data, projected emission inventory data and thorough documentation of the mobile emissions analysis.

Recycled Paper @ An Equal Opportunity Employer Please Recycle 

### 0

### B. Mathur, Page 2

Motor Vehicle Emission Budgets Contained in the Redesignation Petition is a new Motor Vehicle Emissions Budget for 2015 and 2020. The Ohio Kentucky Indiana (OKI) Regional Council of Governments' travel demand model and MOBILE6.2 were used to determine emissions for the area. A conservative margin of safety was applied to the 2015 and 2020 projected emissions.
The travel demand model was updated with the best available assumptions.

Vehicle registration data gathered from the Indiana Bureau of Motor Vehicles were used to replace the MOBILE6.2 default vehicle age distribution.

IDEM requests that the U.S. EPA proceed with review and approval of this submittal. If you have any questions or need additional information, please contact Scott Deloney, Chief, Air Programs Branch, at (3 17) 233-5694.

Commissioner

TWEIsadlskr Attachments: Request for Redesignation and Maintenance Plan and Appendices

Cc: John Surnrnerhays, U.S. EPA Region 5 (wl enclosures) Ed Doty, U.S. EPA Region 5 (wl enclosures) Cheryl 

### L. Newton, U.S. EPA Region 5 (no enclosures) Pat Morris, U.S. EPA Region 5 (no enclosures) John Mooney, U.S. EPA Region 5 (no enclosures) Scott Deloney, IDEM-OAQ (no enclosures) Christine Pedersen, IDEM-OAQ (no enclosures) Sarah Raymond, IDEM-OAQ (wl enclosures)

# REQUEST FOR REDESIGNATION AND MAINTENANCE PLAN FOR OZONE ATTAINMENT IN THE INDIANAPORTION OF THE CINCINNATIHAMILTON, OH-KY-IN 8-HOUR OZONE NONATTAINMENT AREA

Dearborn County, Indiana (Lawrenceburg Township)

Developed By: The Indiana Department of Environmental Management

January 2010

### This page intentionally left blankTABLE OF CONTENTS
1.0 INTRODUCTION ...................................................................................................... 1

1.1 Back ground

................................................................................................................. ..............................2 1.2 Geographical Description of Indiana' s Portion of the Nonattainment Area ............................................. 2

1.3 Status of Air Qu ality

...................................................................................................... ............................3

2.0 REQUIREMENTS FOR REDESIGNATION ......................................................... 3

2.1 General .................................................................................................................... ..................................3 2.2 Ozone Monitoring............. ...................................................................................................... ..............3 2.3 Emission Inventory....................................................................................................................................4 2.4 Modeling De monstration..................................................................................................... ......................4 2.5 Controls and Regulations ................................................................................................... .......................4

2.6 Corrective Actions for Potential Fu ture Violations of the Standard......................................................... .5

3.0 OZONE MONITORING ........................................................................................... 5
3.1 Ozone Monitoring Network ................................................................................................... ...................5 3.2 Ambient Ozone Monitoring Data.............................................................................................. ................7 3.3 Quality Assurance .......................................................................................................... ...........................9

3.4 Continued Monito ring ....................................................................................................... ......................10

4.0 EMISSION INVENTORY....................................................................................... 10

4.1 Emission Trends............................................................................................................ ..........................10 4.2 Base Year Inventory........................................................................................................ ........................17

4.3 Emission Projections ....................................................................................................... ........................18

4.4 Demonstration of Maintenance ............................................................................................... ................23

4.5 Permanent and Enforceable Emissions Reductions............................................................................. ....23

4.6 Provisions for Future Updates .............................................................................................. ...................24

5.0 TRANSPORTATION CONFORMITY BUDGETS ............................................. 24

5.1 On-Road Emi ssion Estimates ................................................................................................. .................24

5.2 Overview ................................................................................................................... ..............................24

5.3 Emission Estimates......................................................................................................... .........................25

i6.0 CONTROL MEASURES AND REGULATIONS................................................. 27
6.1 Reasonably Available Co ntrol Technolo gy (RACT)............................................................................. ..27 6.2 Implementation of Past SIP Re visions ....................................................................................... .............27 6.3 Nitrogen Oxides (NO x ) Rule ...................................................................................................................27 6.4 Measures B eyond Clean Air Act Requirements................................................................................ .....28

6.5 Controls to Remain in Effect............................................................................................... ....................29

6.6 New Source Review Provisions ............................................................................................... ...............30

7.0 MODELING and METEOROLOGY..................................................................... 30
7.1 Summary of Modeling Results................................................................................................ ................30 7.2 U.S. EPA Modeling Analysis for HDE Final Rulemaking......................................................................30 7.3 U.S. EPA Modeling for Clean Air Interstate Rule (CAIR), 2005 ...........................................................31 7.4 LADCO's Round 5 and Round 6 Modeling for 8-Hour Ozone Standard ................................................32 7.5 Summary of Exis ting Modeli ng Results....................................................................................... ...........33 7.6 Temperature Analysis for the Cincinnati, Ohio Area......................................................................... .....34 7.7 Summary of Mete orological Conditions ....................................................................................... ..........37

8.0 CORRECTIVE ACTIONS ...................................................................................... 38

8.1 Commitment to Revise Plan.................................................................................................. ..................38

8.2 Commitment for Co ntingency Measures........................................................................................ .........38 8.3 Contingency Measures ....................................................................................................... .....................39

9.0 PUBLIC PARTICIPATION.................................................................................... 40

10.0 CONCLUSIONS ..................................................................................................... 40

iiFIGURES
3.1 Cincinnati-Hamilton, OH- KY-IN Nonattainment Area .......................................................................... .6

TABLES
3.1 Monitoring Data for Kentucky’s Portion of the Nonattainment Area (Annual 4 th High and Design Values in ppm) ................................................................................................................. .............................. 7 3.2 Monitoring Data for Ohio’s Portion of the Nonattainment Area (Annual 4 th High and Design Values in ppm) ............................................................................................................................................................... 8 4.1 Comparison of 2008 Emissions and 2020 Projected NO x and VOC Emission Estimates, All Anthropogenic Sources in Lawren ceburg Township, Dearborn County (Tons Per Summer Day) .............. 22 4.2 Comparison of 2008 Emissions and 2020 Projected NO x and VOC Emissions Estimates, All Anthropogenic Sources in the Entire Nona ttainment Area (Tons Per Summer Day)................................... 22
5.1 Emission Estimates for On-Road Mobile Sources for the Cincinnati-Hamilton, OH-KY-IN Ozone Nonattainme nt Area............................................................................................................. ......................... 255.3 Motor Vehicle Emission Budgets (MVEB) for the Ohio and Indiana Portions of the CincinnatiHamilton, OH-KY-IN Ozone Nonattainment Area.................................................................................... .. 25

6.1 Trends in EGU Ozone Season NO x Emissions Statewid e in Indiana .....................................................28 7.1 Modeling Results: U.S. EPA HDE Rulemaking for the Cincinnati-Hamilton, OH-KY-IN Nonattainme nt Area............................................................................................................. ......................... 31 7.2 Modeling Results From U.S. EPA for the Clean Air In terstate Rule .....................................................32 7.3 Application of Round 5 RRFs (with CAIR) to Most Current Base-Year Design Values...................... 33 7.4 Application of Round 6 RRFs (without CAIR) to Most Current Base-Year Design Values................. 33 7.5 Analysis of Maximum Temperatur es for the Cincinna ti, Ohio Area..................................................... 35 7.6 Comparison of Days with 90° F and 8- hour Ozone Exceedance Days 1998-2008 ............................... 36

iiiGRAPHS

3.1 2007-2009 Design Values for the Cincinna ti-Hamilton, OH-KY-IN Nonattainment Area..................... 8 3.2 Design Value Trends in the Cincinnati-Hami ton, OH-KY-IN Nonattainment Area, 2004-2009............ 9

4.1 NO x Point Source Emissions, Lawrenceburg Township, Dearborn County, Indiana, 2005 and 2008 ... 11 4.2 VOC Point Source Emissions, Lawrenceburg Township, Dearborn County, Indiana, 2005 and 2008. 11

4.3 NO x Point Source Emissions, Entire Nonattainment Area, 2005 and 2008............................................12
4.4 VOC Point Source Emissions, Entir e Nonattainment Area, 2005 and 2008 ..........................................12

4.5 NO x Emissions from Lawrenceburg Township, Dear born County, Indiana Electric Generating Unit American Electric Power-Tanners Cree k Generating Stati on, 1999-2008 ................................................... 14

4.6 NO x Emissions from Entire Nonattainment Area Electric Generating Units, 1999-2008 ..................... 14

4.7 NO x Emissions Trends, 2005 and 2008, All Anthropogenic Sources in Lawrenceburg Township, Dearborn County ................................................................................................................ .......................... 15 4.8 VOC Emissions Trends, 2005 and 2008, All Anthropogenic Sources in Lawrenceburg Township, Dearborn County ................................................................................................................ .......................... 16

4.9 NO x Emissions Trends, 2005 and 2008, All Anthr opogenic Sources-Entire Nonattainment Area ....... 16
4.10 VOC Emissions Trends, 2005 and 2008, All Anthropogenic Sources-Entire Nonattainment Area.... 17 4.11 Comparison of 2008 Emissions and 2015 and 2020 Projected NO x Emissions for Lawrenceburg Township, Dearborn County ...................................................................................................... .................. 19 4.12 Comparison of 2008 Emissions and 2015 and 2020 Projected VOC Emissions for Lawrenceburg Township, Dearborn County ...................................................................................................... .................. 20 4.13 Comparison of 2008 Emissions and 2015 and 2020 Projected NO x Emissions for Entire Nonattainme nt Area............................................................................................................. ......................... 20 4.14 Comparison of 2008 Emissions and 2015 and 2020 Projected VOC Emissions for Entire Nonattainme nt Area............................................................................................................. ......................... 21 4.15 Comparison of 2008 Emissions and 2015 and 2020 Projected NO x Emissions for Lawrenceburg Township, Dearborn County Indian a and, Kentucky and Ohio.................................................................... 21 4.16 Comparison of 2008 Emissions and 2015 and 2020 Projected NO x Emissions for Lawrenceburg Township, Dearborn County Indian a and, Kentucky and Ohio.................................................................... 22 7.1 Actual Design Values for Cincinnati From 1996 Through 2008............................................................33 7.2 Comparison of Days with 90° F and 8-hour Ozone Exceedance Days ..................................................37

ivAPPENDICES

A Air Quality System (AQS) Monitor Da ta Values for Cincinnati-Hamilton OHKY-IN Nonattainment Area (2004-2009)

B Nitrogen Oxides (NO x ) and Volatile Organic Compounds (VOC), Point Source Emissions, 2005 and 2008, for Lawrenceburg Township, Dearborn County Indiana and Entire Cincinnati-Ham ilton OH-KY-IN Nonattainment Area

C Nitrogen Oxides (NO x ) and Volatile Organic Compounds (VOC), All Emission Sources, 2005 and 2008, for Lawrenceburg Township, Dearborn County, Indiana and Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area

D Nitrogen Oxides (NO x ) Emissions from Electric Generating Units, Lawrenceburg Township, Dearborn County, Indiana and Entire Cincinnati-Hamilton OH-KY-IN Nonattainment Area

E 2008 Base Year Emissions Inventory and 2015 and 2020 Projected Emissions Inventory for Nitrogen Oxides (NO x ) and Volatile Organic Compounds (VOC), All Emission Sources for Lawrencebur g Township, Dearborn County, Indiana and Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area

F Mobile Source Input/Output Calculation Files

G Indiana Department of Environmen tal Management (IDEM)-Area Source Inventory Standard Operating Procedure

H Lake Michigan Air Directors Cons ortium (LADCO) Emission Estimates Technical Support Document

I Lake Michigan Air Directors Consor tium (LADCO) Round 5 Modeling Technical Support Document (Round 5 Photochemical Modeling Based on “Base M” Emissions Inventory, Revised Version of “Base K”)

v

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viREQUEST FOR REDESIGNATION AND MAINTENANCE PLAN FOR OZONE ATTAINMENT IN THE INDIANA PORTION OF THE CINCINNATI-HAMILTON OH-KY-IN 8-HOUR OZONE NONATTAINMENT AREA

DEARBORN COUNTY, INDIANA (LAWRENCEBURG TOWNSHIP)

1.0 INTRODUCTION

This document supports Indiana’s request that the Indi ana portion (Lawren ceburg Township in Dearborn County, Indiana) of the Cincinnati-H amilton OH-KY-IN area be redesignated from nonattainment to attainment for the 1997 8-hour ozone standard. In addition, the States of Kentucky and Ohio also intend to submit requests for their porti ons of the Cincinnati-Hamilton OH-KY-IN basic ozone nonattainment area to be redesignated from nonattainment to attainment for the 8-hour ozone national ambient air qual ity standard (NAAQS). The Cincinnati-Hamilton OH-KY-IN area has recorded three (3) years of complete, qualit y-assured ambient air quality monitoring data for the years 2007 through 2009, dem onstrating attainment of the 8-hour ozone standard.

Indiana’s request is based on Section 107(d)(3)( D) of the Clean Air Act (CAA), which states:

The Governor of any State may, on the Governor’s own motion, submit to the Administrator a revised designation of any area or portion th ereof within the State. Within 18 months of receipt of a complete State redesignation submittal, the Administrator shall approve or deny such redesignation. The submission of a redesignation by a Governor shall not affect the effectiveness or enforceability of the applicable implementation plan for the State.

Section 107(d)(3)(E) of the CAA establishes specif ic requirements to be met in order for an area (or portion of an area) to be consid ered for redesignation as follows:

The Administrator may not promulgate a re designation of a nonattainment area (or portion thereof) to attainment unless--

(i) the Administrator determines that the area has attained the national ambient air quality standard; (ii) the Administrator has fully approved the applicable implementation plan for the area under section 110(k); (iii) the Administrator determines that the improvement in air quality is due to permanent and enforceable reductio ns in emissions resulting from implementation of the applicable implementation plan and applicable Federal air pollutant control regu lations and other permanent and enforceable reductions;

1(iv) the Administrator has fully approved a maintenance plan for the area as meeting the requirements of section 175A; and (v) the state containing such area has met all requirements applicable to the area under section 110 and part D.

This document addresses each of these requireme nts, and provides additional information to support continued compliance with the 1997 8-hour ozone standard.

1.1 Background

The Clean Air Act (CAA) requires areas designat ed nonattainment for the NAAQS for ozone to develop State Implementation Plans (SIPs) to expedi tiously attain and maintain the standard. In 1997, the United States Environmen tal Protection Agency (U.S. EP A) revised the air quality standards for ozone, replacing the 1979 1-hour standard with an 8-hour ozone standard set at 0.08 parts per million (ppm). The standard was challenged legally and upheld by the U.S. Supreme Court in February of 2001. The U.S. EPA designated areas under the 8-hour ozone standard on April 15, 2004 as attainme nt, nonattainment or unclassifiable.

The U.S. EPA designated Lawrenceburg Township in Dearborn County, Indiana as a portion of the Cincinnati-Hamilton OH-KY-IN nonattainment area (40 CFR 81.315) and classified the area “basic” under Subpart 1 of Part D of the CAA. The specific counties an d partial counties that comprise the nonattainment area, as de fined in 40 CFR 81.315, 40 CFR 81.318 and 40 CFR 81.336, include Lawrenceburg Township in Dear born County, Indiana; Boone, Campbell and Kenton counties, Kentucky; and Butler, Clermont , Clinton, Hamilton and Warren counties, Ohio. This designation subjected th e area to the new 8-hour oz one requirements, including development of a plan to reduce emissions of volatile organic compounds (VOCs) and nitrogen oxides (NO x ) and a demonstration that the area will meet the federal 8-hour air quality standard for ozone by June 15, 2010.

1.2 Geographical Description of Indiana’s Po rtion of the Entire Nonattainment Area

Following is a brief description of the Cincinnati basic nonattainment area.

Lawrenceburg Township, located in Dearborn C ounty in southeast Indiana, Boone, Campbell and Kenton counties located in north central Ke ntucky and Butler, Clermont, Clinton, Hamilton and Warren counties located in southwestern Ohio are part of the Cincinnati metropolitan statistical area. This area is surrounded by the Indiana counties of Franklin, Ohio, Ripley, Switzerland and Union, the Kentucky counties of Bracken, Gallatin, Gran t and Pendleton and the Ohio counties of Brown, Fayette, Greene, Highland, Montgomery and Preble. The Ohio River flows along the borders of Indian a, Kentucky and Ohio and the ar ea lies within the Ohio River Valley. The Cincinnati-Hamilton OH-KY-IN Basic Nonattainment Area is depicted in Figure 3.1.

The Indiana Department of Environmental Mana gement (IDEM), on behalf of the State of Indiana, is requesting redesignation of Lawrenceburg Township, Dearborn County, Indiana. The Kentucky Department for Environmental Protecti on (KDEP) is responsible for Boone, Campbell

2and Kenton counties in Kentucky. The Ohio Envi ronmental Protection Agency (Ohio EPA) is responsible for Butler, Clermont, Clinton, Ham ilton and Warren counties in Ohio. KDEP and Ohio EPA are requesting redesignation of thei r portions of the nonattainment area from U.S. EPA Regions IV and V, concurrently.

1.3 Status of Air Quality

Ozone monitoring data for the most recent three (3) years, 2007 through 2009, demonstrates that air quality has met the NAAQS for ozone thr oughout the nonattainme nt area, including Lawrenceburg Township in Dearborn County. This fact, accompanied by the permanent and enforceable decreases in emission levels discu ssed in Section 4.0, justifies a redesignation to attainment for Indiana’s portion of the nonattainment area based on Section 107(d)(3)(E) of the CAA.

2.0 REQUIREMENTS FOR REDESIGNATION

2.1 General

Section 110 and Part D of the CAA list a num ber of requirements that must be met by nonattainment areas prior to consideration for rede signation to attainment. In addition, U.S. EPA has published detailed guidance in a document entitled Procedures for Processing Requests to Redesignate Areas to Attainment , issued September 4, 1992, to Re gional Air Directors. This document is hereafter referred to as “Redesigna tion Guidance”. This Request for Redesignation and Maintenance Plan is based on the Redesi gnation Guidance, supplemented with additional guidance received from staff of the Criteria Pollutant Section of U.S. EPA Region V. The specific requirements for redesignation are listed below.

2.2 Ozone Monitoring CAA Section 107(d)(3)(E)(i)

1) A demonstration that the NAAQS for ozone, as published in 40 CFR 50.4, has been attained. Ozone monitoring data must show that violations of the ambient standard are no longer occurring.

2) Ambient monitoring data quality assure d in accordance with 40 CFR 58.10, have been recorded in the U.S. EPA Air Quality System (AQS) database, and made available for public view.

3) A showing that the three-year average of the fourth highest values, based on data from all monitoring sites in the area or its affected downwind environs, are below 85 parts per billion (ppb). This show ing must rely on three (3) complete, consecutive calendar years of quality assured data.

4) A commitment that, once redesignated, the state will continue to operate an appropriate monitoring network to verify the maintenance of the attainment
status.

32.3 Emission Inventory CAA Section 107(d)(3)(E)(iii)

1) A comprehensive emissions inventory of the precursors of ozone completed for the base year.

2) A projection of the emissions inventor y to a year at le ast 10 years following redesignation.

3) A demonstration that the pr ojected level of emissions is sufficient to maintain the ozone standard.

4) A demonstration that improvement in air quality between th e year violations occurred and attainment was achieved is based on permanent and enforceable emission reductions and not on tempor ary adverse economic conditions or unusually favorable meteorology.

5) Provisions for future annual updates of the inventory to enable tracking of the emission levels including an annual em ission statement from major sources.

2.4 Modeling Demonstration

While no modeling is required for redesigna ting ozone nonattainment areas, IDEM has incorporated photochemical modeling informati on as part of this document to further support its request for Lawrenceburg Townsh ip in Dearborn County, Indiana, to be redesignated to attainment.

2.5 Controls and Regulations CAA Section 107(d)(3)(E)(i i) & CAA Secti on 107(d)(3)(E)(v)

1) A U.S. EPA approved SIP control stra tegy that includes Reasonably Available Control Technology (RACT) requirements fo r existing stationary sources covered by Control Technology Guidelines (CTG ) and non-CTG RACT for all major

sources.
2) Evidence that control measures required in past ozone SIP revisions have been fully implemented.

3) Acceptable provisions to pr ovide for new source review.

4) Assurances that existing controls will remain in effect after redesignation, unless the state demonstrates through photochemical modeling that the standard can be maintained without one or more controls.

5) If appropriate, a commitment to adopt a requirement that all transportation plans conform with and are consistent with the SIP.

42.6 Corrective Actions for Potential Future Violations of the Standard

1) A commitment to submit a revised pl an eight (8) years after redesignation.

2) A commitment to expeditiously enact and implement additional contingency control measures in response to excee ding specified predetermined levels (triggers) or in the event that future vi olations of the ambient standards occur.

3) A list of potential contingency measures that would be implemented in such an
event.

4) A list of VOC and NO x sources potentially subjec t to future controls.

3.0 OZONE MONITORING

3.1 Ozone Monitoring Network

There are currently eleven (11) monitors measuring ozone concentratio ns in the CincinnatiHamilton OH-KY-IN nonattainment area. Three monitors are located in Kentucky and eight monitors are located in Ohio. Indiana doe s not have any ozone monitors located in Lawrenceburg Township in Dearborn County. A listing of the sites al ong with their annual fourth highest readings from 2007 through 2009 ar e shown in Table 3.1 and Table 3.2 and were retrieved from U.S. EPA’s Air Quality System (A QS) database. The locations of the monitoring sites for this nonattainment area are shown on Figure 3.1.

5Figure 3.1 Map of the Cincinnati-Hamilton OH-KY-IN Nonattainment Area

39-017-1004

39-061-0006

39-061-0010

21-117-0007 21-037-3002 39-017-0004 39-165-0007

39-025-0022
39-061-0040 39-027-1002

21-015-0003 BOONE

GRANT MASON PENDLETON

OWEN BRACKEN KENTON

LEWIS CAMPBELL

GALLATIN

CARROLL

ROBERTSON HARRISON HENRY FLEMING Butler

Brown Clinton

Highland Warren Greene

Clermont

Adams Preble

Hamilton Fayette Montgomery Madison Clark

Dearborn Franklin Union

Ohio Wayne

Switzerland Fayette

Ripley



## Legend

Ozone Monitor Interstate Higways US Highways

Indiana Counties in Attainment

Ohio Counties in Attainment Kentucky Counties in Attainment

Cincinnati-Hamilton OH-KY-IN Nonattainment Area 0 2 0 4 0 10 Miles

0 2 5 5 0 12.5 Kilometers

10/28/09

63.2 Ambient Ozone Monitoring Data

The following information is taken from U.S. EPA's "Guideline on Data Handling Conventions for the 8-Hour Ozone National Ambient Air Quality Standard ( NAAQS)," EPA-454/R-98-017, December 1998.

U.S. EPA requires three (3) comple te years of ozone monitoring da ta to demonstrate attainment at a monitoring site. The 8-hour primary and secondary ozone ambient ai r quality standards are met at an ambient air quality monitoring site wh en the three-year average of the annual fourthhighest daily maximum 8-hour average ozone concentration is le ss than or equal to 0.08 parts per million (ppm). When this occurs, the site is deemed to be in attainment. Three (3) significant digits must be carried out in the computations. Because the third decimal digit, in ppm, is rounded, 0.084 ppm is the largest con centration that is less than or equal to 0.08 ppm. Therefore, for the purposes of this request, the 8-hour standa rd is considered to be 0.085 ppm. Values below 0.085 ppm meet the standard, values equa l to or greater than 0.085 ppm exceed the standard. These data handling procedures are ap plied on an individual basi s at each monitor in the area. An area complies with the 8-hour oz one NAAQS only if every monitoring site in the area meets the NAAQS. An individual site's th ree-year average of th e annual fourth highest daily maximum 8-hour average ozone concentration is also called the site's design value. The air quality design value for the area is the highest design va lue among all sites in the area. Table 3.1 outlines the annual fourth high values and thre e-year design values for 2004 through 2009 for the three active monitoring sites in Kentucky’s portion of the nonattainment area. Table 3.2 outlines the annual fourth high values and three-year design values for 2004 through 2009 for the eight active monitoring sites within Oh io’s portion of the nonattainment area. None of the eleven monitors within the Cincinnati-Hamilton OH-KY-IN nonattainment area has a 2007 through 2009 design value greater than 0.082 ppm.

Table 3.1 Monitoring Data for Kentucky’s Portion of the Nonattainment Area (Annual 4 th High and Design Values in ppm)

County Site ID 2004 2005 2006 2007 2008 2009 2004- 2006 2005- 2007 2006- 2008 2007- 2009 Boone 21-015-0003 0.070 0.082 0.071 0.078 0.064 0.064 0.074 0.077 0.071 0.069 Campbell 21-037-3002 0.086 0.075 0.068 0.076

Kenton 21-117-0007 0.073 0.084 0.075 0.085 0.073 0.074 0.077 0.081 0.078 0.077 Red text indicates values are ≥ 0.085 ppm

7Table 3.2 Monitoring Data for Ohio’s Portion of Nonattainment Area (Annual 4 th High and Design Values in ppm)

County Site ID 2004 2005 2006 2007 2008 2009 2004- 2006 2005- 2007 2006- 2008 2007- 2009 Butler 39-017-0004 0.075 0.086 0.079 0.091 0.071 0.073 0.080 0.085 0.080 0.078 Butler 39-017-1004 0.076 0.088 0.076 0.091 0.079 0.076 0.080 0.085 0.082 0.082 Clermont 39-025-0022 0.076 0.083 0.077 0.086 0.071 0.069 0.079 0.082 0.078 0.075 Clinton 39-027-1002 0.078 0.083 0.081 0.082 0.076 0.070 0.081 0.082 0.080 0.076 Hamilton 39-061-0006 0.076 0.089 0.081 0.089 0.086 0.072 0.082 0.086 0.085 0.082 Hamilton 39-061-0010 0.075 0.085 0.081 0.086 0.077 0.065 0.080 0.084 0.081 0.076 Hamilton 39-061-0040 0.076 0.087 0.078 0.086 0.080 0.074 0.080 0.084 0.081 0.080 Warren 39-165-0007 0.081 0.092 0.086 0.088 0.082 0.077 0.086 0.089 0.085 0.082 Red text indicates values are ≥ 0.085 ppm
Graph 3.1 below visually demonstrates the desi gn values for this nonattainment area. The highest design value within the nonattainment ar ea is 0.082 ppm. The design values calculated for the Cincinnati-Hamilton OH-KY-IN nonattain ment area demonstrate that the NAAQS for ozone has been attained.

Graph 3.1 2007-2009 Design Values for th e Cincinnati-Hamilton OH-KY-IN Nonattainment Area

0.000 0.010 0.020 0.030 0.040 0.050 0.060 0.070 0.080 0.090

KY 338, KY Highland Heights, KY Covington, KY Hamilton, OH Middletow n, OH Batavia, OH Wilmington, OH Cincinnati, OH-Grooms Rd. Cleves, OH Cincinnati, OH-WM. How ard Taft Rd. Lebanon, OH

21-015-0003 21-037-3002 21-117-0007 39-017-0004 39-017-1004 39-025-0022 39-027-1002 39-061-0006 39-061-0010 39-061-0040 39-165-0007Parts per Million

2007-2009 8-Hour Ozone Standard

8Graph 3.2 illustrates the design value tre nds for the Cincinnati-Hamilton OH-KY-IN nonattainment area.

Graph 3.2 Design Value Trends in the Cincinnati-Hamilton OH-KY-IN Nonattainment Area, 2004-2009

0.060 0.065 0.070 0.075 0.080 0.085 0.090 0.095

04-06 05-07 06-08 07-09Parts per Million 21-015-0003 KY 338, KY

21-037-3002 Highland Heights, KY 21-117-0007 Covington, KY

39-017-0004 Hamilton, OH

39-017-1004 Middletow n, OH

39-025-0022 Batavia, OH

39-027-1002 Wilmington, OH

39-061-0006 Cincinnati, OHGrooms Rd. 39-061-0010 Cleves, OH

39-061-0040 Cincinnati, OHWM. How ard Taft Rd. 39-165-0007 Lebanon, OH

8-Hour Ozone Standard

The above graph shows the trend in design values for the region over the pa st several years. A comprehensive list of the individual sites' design values over this period is in Appendix A. The area's design values have recently trended dow nward as emissions have declined due to programs such as the Acid Rain program and cl eaner automobiles and fuels both regionally and locally. U.S. EPA’s rule to c ontrol nitrogen oxides from spec ific source categories (40 CFR Parts 51, 72, 75 and 96, published on October 17, 1998 and referred to as the “NO x SIP Call”) has significantly reduced emissions from larg e electric generating units (EGUs), industrial boilers and cement kilns. Indiana's NO x Rule was approved on June 6, 2001 (326 IAC 10-3 and 10-4). The SIP submittals of other Midwest states were approved in this timeframe as well. An analysis of meteorological conditions and monitoring values is in Section 7.0 and supports the conclusion that attainment of the standard as of 2009 is not the result of unusually favorable meteorological conditions. It is expected that this downward trend will continue as the above programs continue.

3.3 Quality Assurance

Ohio and Kentucky have quality assured all da ta shown in Appendix A in accordance with 40 CFR 58.10 and the Quality Assurance Manual. Ohio and Kentucky have recorded the data in the AQS database and, thus, the data are available to the public.

93.4 Continued Monitoring

Ohio and Kentucky have committed to continue mon itoring ozone levels at the sites indicated in Table 3.1 and Appendix A. IDEM will consult with Ohio, Kentucky and the U.S. EPA Region IV and V staff prior to making changes to the existing monitoring network, should changes become necessary in the future. Ohio and Kentucky will continue to quality assure the monitoring data to meet the requirements of 40 CFR 58. Updates to the IDEM website 1 will provide real time availability of the data and knowledge of any exceedances at these monitors. Ohio and Kentucky will enter a ll data into AQS in a timely manner in accordance with federal guidelines.

4.0 EMISSION INVENTORY

U.S. EPA’s Redesignation Guidance requires the submittal of a comprehensive inventory of ozone precursor emissions (VOC and NO x ) representative of the year when the area achieves attainment of the ozone air qua lity standard. Indiana must also demonstrate that the improvement in air quality between the year that violations occurred and the year that attainment was achieved is based on permanent and enforcea ble emission reductions. Other requirements related to the emissions inventory include a projection of the emissi on inventory to a year at least ten (10) years following redesignation, a demonstra tion that the projected level of emissions is sufficient to maintain the ozone standard and a commitment to provide future updates of the inventory to enable tracking of emission levels during the ten (10) year maintenance period. The following subsections address each of these requirements.

4.1 Emission Trends

Point Sources Graphs 4.1 and 4.2 show the trend within Indi ana’s portion of the Cincinnati-Hamilton OH-KYIN nonattainment area, in poi nt source emissions of NO x and VOC, respectively, that generally correspond to the years of monitored values refere nced in this plan. The point source data is taken from Indiana's annual emissions reporting program. Graphs and data tables of emissions from each point source in Lawrenceburg Townsh ip, Dearborn County, Indiana are available in Appendix B. Although the Indiana data shows a sli ght increase in the poi nt source emissions for NO x and VOC, the emissions within Indiana’ s portion of the Cinci nnati-Hamilton OH-KY-IN nonattainment area are insignificant compared to the point source emission s within the entire nonattainment area, as can be seen in Graphs 4.15 and 4.16. Graphs 4.3 and 4.4 show the trend of point source emissions within the entire Cincinnati-Hamilton OH-KY-IN nonattainment area. Although the emissions trend within the enti re Cincinnati-Hamilton OH-KY-IN nonattainment area for VOC shows very little change in point source emissions, overall anthropogenic emissions for NO x and VOC are trending downward, as can be seen in Graphs 4.9 and 4.10.

1 http://www.in.gov/idem/4670.htm

10Graph 4.1 NO x Point Source Emissions, Lawren ceburg Township, Dearborn County, Indiana, 2005 and 2008

- 5.00 10.00 15.00 20.00 25.00 30.00 35.00

2005 2008
YearTons Per Summer Day

NOx

Graph 4.2 VOC Point Source Emissions, La wrenceburg Township, Dearborn County, Indiana, 2005 and 2008

- 0.50 1.00 1.50 2.00 2.50 3.00 3.50 4.00

2005 2008 YearTons Per Summer Day

VOC

11Graph 4.3 NO x Point Source Emissions, Entire Nonattainment Area, 2005 and 2008

- 25.00 50.00 75.00 100.00 125.00 150.00 175.00 200.00

2005 2008 YearTons Per Summer Day

NOx

Graph 4.4 VOC Point Source Emissions, Entire Nonattainment Area, 2005 and 2008

- 2.00 4.00 6.00 8.00 10.00 12.00 14.00 16.00

2005 2008 YearTons Per Summer Day

VOC

12EGU Sources Graph 4.5 shows the trend in NO x emissions from the American Electric Power (AEP)-Tanners Creek Generating Station in Lawrenceburg Town ship, Dearborn County, Indiana. Graph 4.6 depicts the trends in NO x emissions from EGUs for the entire nonattainment area. While ozone and its precursors are also transported into this region from outside areas, this information does provide some indication of the impact that the EGUs located in the nonattainment area may have on the entire nonattainment area. The emissions are decreasing substantially in response to national programs affecting all EGUs, such as the Acid Rain program and the NO x SIP Call. Other sectors of the inventory also impact ozone formation, but large regional sources such as EGUs have a substantial impact on the formation of ozone. Graphs and data tables of emissions from each EGU source are available in Appendix D.

These data were taken from U.S. EPA's Clean Air Markets database 2

. Data are available sooner for these units than other point sources in the inventory because of the NO x SIP Call budget and trading requirements. Information from 2003 is significant because some EGUs started operation of their NO x SIP Call controls in order to gene rate Early Reduction Credits for their future year NO x budgets. The first season of the NO x SIP Call budget period began May 31, 2004.

As part of the NO x SIP Call, the states were required to adopt into their rules a budget for all large EGUs. Indiana’s budget is found in Indiana’s rules at 326 IAC 10-4. The budget represents a statewide cap on NO x emissions. Although each unit is allocated emissions based upon historic heat input, utilities can meet this budget by over-controlling certain units or purchasing credits from the market to account fo r overages at other units . To summarize, NO x emissions have dramatically decreased over the years as represented on these graphs. These emissions, capped by the state rule, should remain at least this low through the maintenance period covered by this request.

2 http://www.epa.gov/airmarkets/

13Graph 4.5 NO x Emissions from Lawrenceburg Township, Dearborn County, Indiana Electric Generating Unit American Electric Power-Tanners Creek Generating Station, 1999-2008

0 5,000 10,000 15,000 20,000 25,000 30,000 35,000 40,0001999200020012002200320042005200620072008

YearTons per Year

NOx

Graph 4.6 NO x Emissions from Entire Nonattainment Area Electric Generating Units, 1999-2008

0 20,000 40,000 60,000 80,000 100,000 120,000 140,0001999200020012002200320042005200620072008

YearTons per Year

NOx

14All Anthropogenic Sources Periodic inventories, which include emissions fr om all sectors (mobile, area, nonroad and point sources) were prepared for 2005 and will be prep ared soon for 2008. The 2008 point source data for Lawrenceburg Township, Dearborn County, Indiana is taken from Indiana’s annual emissions reporting program. All other emission sources were extrapolated from Indiana’s 2005 periodic inventory submitted to U.S. EPA. Graphs 4.7 and 4.8 show the trends for the total emissions for NO x and VOC for all anthropogenic sour ce categories within Dearborn County, and Graphs 4.9 and 4.10 show the trends for the entire nonattainment area, which also roughly follow the years of monitored air quality trends discussed in Section 3.0. Although Indiana’s portion of the nonattainment area shows an increa se in VOC, overall anthropogenic emissions in the entire nonattainment area have decreased as can be seen in Graph 4.10. Graphs and data tables of emissions from each source category are available in Appendix C. IDEM received emissions information for the Ohio and Kentucky portions of the nonattainment area for the years 2005, 2008, 2015 and 2020 from the Ohio EPA and Kentucky Division for Air Quality.

Graph 4.7 NO x Emissions Trends, 2005 and 2008, All Anthropogenic Sources in Lawrenceburg Township, Dearborn County

- 5.00 10.00 15.00 20.00 25.00 30.00 35.00

2005 2008 YearTons Per Summer Day

NOx

15Graph 4.8 VOC Emissions Trends, 2005 and 2008, All Anthropogenic Sources in Lawrenceburg Township, Dearborn County

- 1.00 2.00 3.00 4.00 5.00 6.00 7.00 8.00

2005 2008 YearTons Per Summer Day

VOC

Graph 4.9 NO x Emissions Trends, 2005 and 2008, All Anthropogenic Sources-Entire Nonattainment Area

- 50.00 100.00 150.00 200.00 250.00 300.00 350.00 400.00

2005 2008 YearTons Per Summer Day

NOx

16Graph 4.10 VOC Emissions Trends, 2005 and 2008, All Anthropogenic Sources-Entire Nonattainment Area

- 25.00 50.00 75.00 100.00 125.00 150.00 175.00 200.00 225.00

2005 2008 YearTons Per Summer Day

VOC

4.2 Base Year Inventory

IDEM prepared a comprehensive inventory for Lawrenceburg Township, Dearborn County, including area, mobile, nonroad and point s ources for precursors of ozone (VOC and NO x ) for the base year 2008.

• Area sources were extrapolated from the Indi ana 2005 periodic inventory submitted to U.S. EPA.

• Mobile source emissions were calculated fr om MOBILE6.2 produced emission factors and data extracted from the region’s travel-demand model. Several adjustments were made to the travel demand model and calculation methodol ogy since 1996. As a result, since the 1996, 1999 and 2002 emission inventories were prepared with slightly different methodology, they do not provide a true comparison with the 2004 through 2020 estimates. The fluctuations referenced in the data, pa rticularly 1996 through 2002 NO x emissions, are due to changes in the calculation methodology, not necessarily actual mobile source emissions.

• Point source information was compiled from IDEM’s 2008 annual emissions statement database and the 2008 U.S. EPA Ai r Markets acid rain database 3

.
• Biogenic emissions are not included in these summaries.

• Nonroad emissions for 2008 were extrapolat ed from the 2005 National Emissions Inventory (NEI). To address concerns about the accuracy of some of the categories in U.S. EPA’s nonroad emissions model, the Lake Mich igan Air Directors Consortium (LADCO),

3 http://camddataandmaps.epa.gov/gdm/

17contracted with two (2) companies to review the base data and make recommendations. One of the contractors also estimated emissions for two (2) categories not included in U.S. EPA’s nonroad model and reviewed model inputs for another. Emissions were estimated for commercial marine vessels and railroads. Recreational motorboat population and spatial surrogates (used to assign emissions to each county) were significantly updated. The populations for the construction equipment cat egory were reviewed and updated based upon surveys completed in the Midwest and the tem poral allocation for agricultural sources was also updated by the other contra ctor. A new nonroad estimati on model was provided by U.S. EPA for the 2002 analysis. The 1996 and 1999 nonroad emission estimates were generated by a previous U.S. EPA model, and thus, cannot provide a true comparison. The fluctuations referenced in the data could be due to changes in the model and methodology and do not necessarily reflect changes in emissions.

IDEM received emissions information for the Ohio and Kentucky portions of the nonattainment area for the years 2005, 2008, 2015 and 2020 from the Ohio EPA and Kentucky Division for Air Quality. This inventory was prepar ed using similar methodologies.

Appendices B, C and E contain data tables and graphs of all these emissions.

4.3 Emission Projections

In consultation with the U.S. EPA and other stak eholders, IDEM selected the year 2020 as the maintenance year for this redesignation re quest. This document contains projected NO x and VOC emissions inventories for 2015 4 and 2020 5

.
IDEM, with assistance from LADCO, prepared NO x and VOC emission projections for 2015 and 2020 for Indiana’s portion of the nonattainment ar ea. IDEM received emissions information for Ohio and Kentucky portions of the nonattainment area for the years 2005, 2008, 2015 and 2020 from the Ohio EPA and Kentucky Division for Air Quality.

The detailed NO x and VOC inventory information for the entire nonattainment area for 2015 and 2020 is in Appendix E. NO x and VOC emission trends are an important gauge for continued compliance with the ozone standard. Therefore, IDEM performed an initial comparison of the NO x and VOC inventories for the base year (2008), interim year (2015) and maintenance year (2020) for Lawrenceburg Township, Dearborn C ounty. Graphs 4.11 and 4.12 visually compare the 2008 (base year) estimated NO x and VOC emissions with the 2015 and 2020 projected emissions for Lawrenceburg Township, Dear born County, and Graphs 4.13 and 4.14 visually compare the 2008 (base year) estimated NO x and VOC emissions with the 2015 and 2020 projected emissions for the entire nonattainme nt area. Graphs 4.15 and 4.16 visually compare the 2008 (base year) estimated NO x and VOC emissions with the 2015 and 2020 projected emissions for Lawrenceburg Township to the Ke ntucky and Ohio portions of the nonattainment area. Mobile source emission inventories are de scribed in Section 5.0. In addition to LADCO’s

4 In Section 4.3 all emissions projections for area, non-road, and point/EGU emission projections for the year 2015 are based on 2009 emission estimates.
5 In Section 4.3 all emission projections for area, non-road, and point/EGU emission projections for the year 2020 are based on 2018 emission estimates.

18estimates, NO x emissions were projected based on the statewide EGU NO x budgets from the Indiana NO x rule. Although Indiana’s portion of the nonattainment area shows a slight increase in emissions from 2015 to 2020 for both NO x and VOC, overall anthropogenic emissions in the entire nonattainment area have decreased as can be seen in Graph 4.13 and Graph 4.14

Graph 4.11 Comparison of 2008 Emis sions and 2015 and 2020 Projected NO x Emissions for Lawrenceburg Township, Dearborn County

- 5.00 10.00 15.00 20.00 25.00 30.00 35.00

2008 2015 2020 YearTons Per Summer Day

NOX

19Graph 4.12 Comparison of 2008 Emissions and 2015 and 2020 Projected VOC Emissions for Lawrenceburg Township, Dearborn County

- 1.00 2.00 3.00 4.00 5.00 6.00 7.00 8.00

2008 2015 2020 YearTons Per Summer Day

VOC

Graph 4.13 Comparison of 2008 Emis sions and 2015 and 2020 Projected NO x Emissions for the Entire Nonattainment Area

- 50.00 100.00 150.00 200.00 250.00 300.00 350.00

2008 2015 2020 YearTons Per Summer Day

NOX

20Graph 4.14 Comparison of 2008 Emissions and 2015 and 2020 Projected VOC Emissions for the Entire Nonattainment Area

- 25.00 50.00 75.00 100.00 125.00 150.00 175.00 200.00

2008 2015 2020 YearTons Per Summer Day

VOC

Graph 4.15 Comparison of 2008 Emis sions and 2015 and 2020 Projected NO x Emissions for Lawrenceburg Township, Dearborn Count y Indiana and Kentucky and Ohio

- 50.00 100.00 150.00 200.00 250.00

2008 2015 2020 YearTons Per Summer Day

Lawrenceburg Township, IN Kentucky Ohio

21Graph 4.16 Comparison of 2008 Emissions and 2015 and 2020 Projected VOC Emissions for Lawrenceburg Township, Dearborn County Indiana and Kentucky and Ohio

- 20.00 40.00 60.00 80.00 100.00 120.00 140.00 160.00

2008 2015 2020 YearTons Per Summer Day

Lawrenceburg Township, IN Kentucky Ohio

Table 4.1 Comparison of 2008 Emissions and 2020 Projected NO x and VOC Emission Estimates, All Anthropogenic Sources in Lawrenceburg Township, Dearborn County, Indiana (Tons per Summer Day)

2008 2020 Change % Decrease NO X 33.09 32.56 -0.53 1.60% VOC 7.49 6.96 -0.53 7.07%

Table 4.2 Comparison of 2008 Emissions and 2020 Projected NO x and VOC Emission

Estimates, All Anthropogenic Sources in the Entire Nonattainment Area (Tons Per Summer Day)

2008 2020 Change % Decrease NO X 309.47 262.47 47.00 15.18% VOC 187.78 157.37 30.41 16.19%

VOC emissions within Lawrenceburg Township, Dearborn County are projected to decline by 7.07% between 2008 and 2020 and by 16.19% in the entire nonattainment area. NO x emissions within Lawrenceburg Township, Dearborn County are projected to decline by 1.60% between 2008 and 2020 and by 15.18% in the entire nonattai nment area. Emission reduction benefits

22from U.S. EPA rules covering the NO x SIP Call, Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements 6 , Heavy-Duty Highway Engine Rule 7 and Nonroad Diesel Engine Rule 8 are factored into the changes. Fu rther, due to implementation of the NO x SIP Call across the eastern United States, NO x and ozone levels entering th is area will decrease.

4.4 Demonstration of Maintenance

Ambient air quality data from all monitoring si tes indicate that air quality in the entire Cincinnati-Hamilton OH-KY-IN nonattainment ar ea met the NAAQS for ozone in 2009. U.S. EPA’s Redesignation Guidance (pg. 9) states, “A state may generally demonstrate maintenance of the NAAQS by either showing that future emi ssions of a pollutant or its precursors will not exceed the level of the attainment inventory, or by modeling to show that the future mix of sources and emissions rates will not cause a violation of the NAAQS.” Emissions projections outlined in Section 4.0 of this documen t clearly illustrate that VOC and NO x emissions in Lawrenceburg Township, Dearborn County and the entire nonattainment area will continue to decline between 2008 (base year) and 2020. Section 7.0 further disc usses the implications of these emissions trends and provi des an analysis to support thes e conclusions. Therefore, air quality should meet the ozone NAAQS through the projected years of 2015 and 2020.

In Indiana, major point sources in all counties are required to submit air emissions information once every three (3) years or annually if the VOC potential to emit is greater than 250 tons per year or the NO x potential to emit is greater than 2,500 tons per year, in accordance with Indiana’s Emission Statement Rule at 326 IAC 2-6. IDEM pr epares a new periodic inventory for all ozone precursor emission sectors every three (3) years. These ozone precursor inventories will be prepared for 2011, 2014 and 2017, as necessary, to comply with the inventory reporting requirements established in the CAA. Emissions information will be compared to the 2008 base year and the 2020 projected maintenance year inventories to assess emission trends, as necessary, to assure continued co mpliance with the ozone standard.

4.5 Permanent and Enforceable Emissions Reductions

Permanent and enforceable reductions of VOCs and NO x have resulted in attainment of the 8- hour ozone standard. Some of these reductions were due to the application of Reasonably Available Control Technology (RACT) rules and some were due to the application of tighter federal standards on new vehicles. In additi on, Title IV of the Clean Air Act and the NO x SIP Call required the reduction of NO x from utility sources. Section 6.0 identifies the emission control measures specific to Lawrenceburg Township, Dearborn County, as well as the implementation status of each measure.

6 http://www.epa.gov/fedrgstr/EPA-AIR/2000/February/Day-10/a19a.htm 7 http://www.epa.gov/fedrgstr/EPA-AIR /1997/October/Day-21/a27494.htm 8 http://www.epa.gov/fedrgstr/EPA-AIR/1998/October/Day-23/a24836.htm

234.6 Provisions for Future Updates

As required by Section 175A(b) of the CAA, Indi ana commits to submit to the Administrator, eight (8) years after redesignation, an additional revision of this SIP. The revision will contain Indiana's plan for maintaining the national primar y ozone air quality standa rd for ten (10) years beyond the first ten (10) year period after redesignation.

5.0 MOBILE SOURCE EMISSION BUDGETS

U.S. EPA requirements outlined in 40 CFR 93.118(e) (4) stipulate that mobile source emissions budgets for VOC and NO x be established as part of a Stat e Implementation Plan (SIP). The mobile source emissions budgets are necessary to demonstrate conformance of transportation plans and improvement programs with the SIP. The following is a summary of the detailed mobile input and output calculati on files located in Appendix F.

5.1 On-Road Emission Estimates

The Ohio-Kentucky-Indiana Regional Council of Governments (OKI) is the Metropolitan Planning Organization (MPO) for the Cinci nnati-Hamilton OH-KY-IN area which includes Dearborn County in Indiana; Butler, Clermont, Clinton, Hamilton, and Warren Counties in Ohio; as well as, Boone, Campbell and Kenton Counties in Kentucky. This organization maintains a travel demand forecasting model that is used to simulate the traffic in the area and to predict what traffic would be in future years given growth expectations. The model is used mostly to identify where travel capacity will be needed a nd to determine the infrastructure requirements necessary to meet that need. It is also used to su pport the calculation of mobile source emissions. The travel demand forecasting model is used to predict the total daily vehicle miles traveled (VMT) and the U.S. EPA software program referred to as MOBILE6.2 is used to produce emission factors to calculate the emission s per mile. The product of these two outputs, once combined, is the total amount of pollution emitted by on-road vehicles for the particular analyzed area.

5.2 Overview

Broadly described, MOBILE6.2 is used to genera te “emission factors”, which are the average emissions per mile (grams/mile) for ozone precursors: NO x and VOC. There are numerous variables that can affect the emission factors. The vehicle-fleet (vehicles on the road) age and the vehicle types have a major a ffect on the emission factors. The facility-type the vehicles are traveling on (MOBILE6.2 facility-t ypes are Freeway, Arterial, Lo cal and Ramp) and the vehicle speeds also affect the emission factor values. Me teorological factors such as air temperature and humidity affect the emission factors, as does fuel type, such as low RVP gasoline. These data are estimated using the best available data to generate emission factor s for the appropriate ozone precursors, NO x and VOC. After emission factors are ge nerated, the emission factor(s) must be multiplied by the VMT to determine the quantity of vehicle-related emissions. This information derives from the travel demand model (TDM).

24It should be noted that each year analyzed w ill have different emission factors, volumes, speeds and likely some additional links. MOBILE6.2 i nput and output files can all be found in Appendix F.

5.3 Emission Estimations

Table 5.1 outlines the on-road emission estimates for the entire nonattainment area for the years 2005, 2008 (Attainment Year), 2015 (Interim Year) and 2020 (Horizon Year). The following emission estimates are based on the actual TDM network runs for the years 2005, 2008, 2015 and 2020. Table 5.1 Emission Estimations for On-Road Mobile Sources for the Cincinnati-Hamilton OH-KY-IN Ozone Nonattainment Area

Cincinnati-Hamilton OHKY-IN NA Area 2005 2008 2015 2020 VOC (tons/day) 69.43 55.47 35.35 32.14

NO x (tons/day) 136.73 113.45 51.04 38.17 Lawrenceburg Township (Dearborn County Indiana) subtotal VOC (tons/day) 1.00 0.75 0.50 0.42

NO x (tons/day) 1.44 1.14 0.60 0.42

Lawrenceburg Township subtotal % VOC (tons/day) 1.44 1.35 1.41 1.31

NO x (tons/day) 1.05 1.00 1.18 1.10

Table 5.2 contains the 2015 and 2020 regional moto r vehicle emissions budgets for the Ohio and Indiana portions of the nonattainment area.

Table 5.2 Motor Vehicle Emission Budgets (MVEB) for the Ohio and Indiana Portions of the Cincinna ti-Hamilton OH-Ky-IN Ozone Nonattainment Area

2015 2020 VOC (tons/day) 31.73 28.82 NO x (tons/day) 49.00 34.39

This document creates an Interim Year Moto r Vehicle Emission Budgets (MVEB) for 2015 and a Horizon Year MVEB for 2020 for the Ohio and Indiana portions of th e nonattainment area.

25These budgets are based on the 2008 on-road emi ssion inventory used to support photochemical modeling for the same year, and has incorporated a fifteen (15) percent safety margin as described below.

Initial Base M (2005) CAMx mode ling results indicated a worst ca se future design value in the Cincinnati-Hamilton OH-KY-IN nonattainment area of 83 ppb. In an effort to accommodate future variations in TDMs and vehicle miles travel ed forecast when no change to the network is planned, Indiana consulted with the interage ncy consultation group, including U.S. EPA – Region 5, to determine a reasonable approach to address this vari ation. Based on this discussion, a fifteen (15) percent safety margin was approve d and has been added to the MVEB for the Ohio and Indiana portions of this nonattainment area.

A fifteen (15) percent safety margin is appropriate because; 1) ther e is an acknowledged potential variation in VMT forecast and potentia l estimated mobile source emissions due to expected modifications to TDM and mobile emi ssions models; and 2) the total decrease in emissions from all sources is sufficient to acco mmodate this fifteen (15) percent allocation of safety margin to mobile sources while still continuing to maintain total emissions in the Cincinnati-Hamilton OH-KY-IN area well below the 2008 attainment level of emissions. This fifteen (15) percent safety margin was calculated by adding a straight-line fi fteen (15) percent to the mobile source emission estimates for the years 2015 and 2020. Safety margin, as defined by the conformity rule, looks at the total emissions from all sources in the nonattainment area. The actual allocation is less than fi fteen (15) percent of the total emission reduction from all sources as can be seen from Tables 4.1 and 4.2.

In summary, for all three states combined, the mobile budget safety margin allocation translates into:

• An allocation of 6.14 tons/day for VOC and 9.39 tons/day for NO x for 2015; and

• An allocation of 6.76 tons/day for VOC and 9.49 tons/day for NO x for 2020.

40 CFR 93.101 defines safety margin as the amount by which the total projected emissions from all sources of a given pollutant area less than the total emissions that would satisfy the applicable requirement for reasonable further progress, attain ment, or maintenance. When compared to the overall safety margin as defined by 40 CFR 93.101, it is evident this alloca tion to mobile sourcesis significantly below the total safety margin for all sources in the Cincinnati-Hamilton OH-KYIN area as detailed in Tables 4.1 and 4.2.

While Indiana believes that this is sufficient to support the requested in crease, Indiana and its partners will be conducting additional air quality modeling which will include the adjusted onroad mobile emissions as well as any additiona l corrections and modifications that may be necessary due to the constant review and evaluation of the model inputs.

Appendix F of this document provides a detailed description of how the above budgets were established and also documents the consultation and coordina tion process among the effected environmental and transportation planning agencies in establishing the budgets.

266.0 CONTROL MEASURES AND REGULATIONS

This section provides specif ic information on the control measures implemented in Lawrenceburg Township, Dearborn County, includi ng CAA requirements and additional state or local measures implemented beyond CAA requirements.

6.1 Reasonably Available Control Technology (RACT)

As required by Section 172 of the CAA, in th e mid-1990s, Indiana promulgated rules requiring RACT for emissions of VOCs. There were no sp ecific rules required by the CAA such as RACT for existing sources beyond statew ide rules. Statewide RACT ru les have applied to all new sources locating in Indiana since that time. The Indiana rules are found in 326 IAC 8. The following is a listing of applicable rules:

326 IAC 8-1 Best Available C ontrol Technology-New Facilities 326 IAC 8-2 Surface Coating Emission Limitations 326 IAC 8-3 Solvent Degreasing Operations 326 IAC 8-4 Petroleum Sources 326 IAC 8-5 Miscellaneous Operations 326 IAC 8-6 Organic Solvent Emission Limitations

Additional rules specifically applicable to Lawrenceburg Township, Dearborn County are summarized in Section 6.4.

6.2 Implementation of Past SIP Revisions

Lawrenceburg Township, Dearborn County was not required to develop an Attainment Demonstration SIP for the 1-hour NAAQS. Th e area was designated nonattainment for 8-hour ozone NAAQS in April 2004. Indiana previously submitted an Attainment Demonstration for Lawrenceburg Township, Dearborn County on June 13, 2007, but the area has now attained the standard. Emissions of VOCs are regulated by a pplicable statewide provisions of 326 IAC 8.

6.3 Nitrogen Oxides (NO x ) Rule

The U.S. EPA NO x SIP Call required twenty-two states to adopt rules that would result in significant emission reductions from large EGUs, industrial boilers and cement kilns in the eastern United States. Indiana adopted this rule in 2001. Beginning in 2004, this rule accounts for a reduction of approximately thirty-one percent (31%) of all NO x emissions statewide compared to the previous uncontrolled years.

Twenty-one other states have also adopted these rules. The resu lt is that significant reductions have occurred regionally and upwind within the nonattainment area because of the number of affected units within the region. Graphs 4.5 and 4.6 show that emissions covered by this program have been trending downward since 1999. Table 6.1, compiled from data taken from the U.S. EPA Clean Air Markets website, quantifies the gradual NO x reductions that have occurred in Indiana as a result of Titl e IV (Acid Rain) of the CAA and the NO x SIP Call Rule.

27Further, U.S. EPA more recently published Phase II of the NO x SIP Call that established a budget for large (greater than 1 ton per day emissi ons) stationary internal combustion engines. This rule decreases emissions statewide from natural gas compressor stations by 4,263 tons during the ozone season. The Indiana Phase II NO x SIP Call rule became effective February 26, 2006 and implementation began in 2007.

TABLE 6.1 Trends in EGU Ozone Season NO x Emissions Statewide in Indiana

Statewide Indiana NO x Emissions from EGUs Year NOx Emissions (Tons per Year) 1999 347,216.5 2000 334,522.1 2001 315,419.7 2002 281,146.1 2003 260,980.0 2004 224,311.3 2005 207,981.6 2006 202,728.0 2007 196,553.1 2008 196,134.5 Budget 2009-2014 108,935.0

6.4 Measures Beyond Clean Air Act Requirements

Reductions in ozone precursor emissi ons have occurred, or are anticipa ted to occur, as a result of local and federal control programs. Th ese additional control measures include:

Tier 2 Emission Standards for Vehicl es and Gasoline Sulfur Standards 9 In February 2000, U.S. EPA finalized a federa l rule to significan tly reduce emissions from light-duty trucks, including SUVs to m eet an average standard of 0.07 grams of NO x per mile. Implementation began in 2004 and was completed in 2007. The Tier 2 standards also cover passenger vehicles over 8,500 pounds gross ve hicle weight rating (large pickup trucks and SUVs), which are no t covered by the current Tier 1 standards. For these vehicles, the standards were pha sed in beginning in 2008, with full compliance in 2009. The new standards require vehicles to be 77% to 95% clea ner than those on the road prior to the new standards. The standard s also reduced the sulf ur content of gasoline to 30 ppm beginning in January 2006.

Heavy-Duty Diesel Engines 10 In July 2000, U.S. EPA issued a final rule for Heavy Duty Highway Engines, a program that includes low-sulfur diesel fuel standards that took eff ect in 2004. A second phase of standards and testing procedur es took effect in 2007 that reduced highway diesel fuel

9 http://www.epa.gov/fedrgstr/EPA-AIR /2000/February/Day-10/a19a.htm 10 http://www.epa.gov/fedrgstr/EPA-AIR /1997/October/Day-21/a27494.htm

28sulfur content to 15 ppm. The total program is expected to achieve a 95% reduction in NO x from diesel trucks and buses, a la rge sector of the mobile sources NO x inventory.

Clean Air Nonroad Diesel Rule 11 In May 2004, U.S. EPA issued the Clean Air N onroad Diesel Rule. This rule applies to diesel engines used in industries such as construction, agriculture and mining. It also contains a cleaner fuel standard similar to the highway diesel program. The new standards will cut emissions from nonroad dies el engines by over ninety percent (90%). Nonroad diesel equipment, as described in this rule, currently accounts for forty-seven percent (47%) of diesel pa rticulate matter (PM) and tw enty-five percent (25%) of nitrogen oxides (NO x ) from mobile sources nationwide. Sulfur levels will be reduced in nonroad diesel fuel by ninety-nine percent (99% ) from current levels, from approximately three thousand (3,000) parts per million (ppm ) now to (fifteen) 15 ppm in 2015. New engine standards take effect, based on engine horsepower, starting in 2008.

Together, these rules will substantially reduce lo cal and regional sources of ozone precursors. The modeling analyses discussed in Section 7.0 include these rules and show the ozone concentrations expected to re sult from their implementation.

Local Reductions Several permanent and enforceable reductions in emissions from local point sources have occurred beyond Clean Air Act Requirements.

The American Electric Power (AEP) -Tanner’s Creek Generating Station power plant, located in Lawrenceburg Township in Dearborn County, is covered by a consent decree and several, but not all, electric generating units will have to apply controls. Currently, the power plant is controlled by low NO x burner technology (dry bottom only) and overfire air. AEP-Tanner’s Creek Generating Station will be installing selective non-catalytic reduction systems on three of its four electric generating units, with operation to begin in early 2010. This will achieve an additional 30% reduction in NO x. The reductions from facili ties like the AEP-Tanners Creek power plant will help improve air quality in the Cincinnati-Hamilton OH-KY-IN nonattainment

area.

6.5 Controls to Remain in Effect

Indiana commits to maintaining the aforemen tioned control measures after redesignation. Indiana commits that any changes to its rules or emission limits applicable to VOC and/or NO x sources, as required for maintenance of the ozone standard in Lawrenceburg Township, Dearborn County, will be submitted to U.S. EPA for approval as a SIP revision.

Indiana, through IDEM’s Office of Air Quality (OAQ) and the Office of Legal Counsel has the legal authority and necessary resources to activel y enforce any violations of its rules or permit provisions. After redesignation, it intends to continue enforcing all rules that relate to the emission of ozone precursors in Lawren ceburg Township, Dearborn County.

11 http://www.epa.gov/fedrgstr/EPA-AIR /1998/October/Day-23/a24836.htm

296.6 New Source Review Provisions

Indiana has a long standing and fully implemente d New Source Review (NSR) program that is outlined in 326 IAC 2. The rule includes the Prevention of Significant Deterioration (PSD) permitting program in 326 IAC 2-2. Indiana's PSD program was conditionally approved on March 3, 2003 (68 FR 9892) and received final approval on May 20, 2004 (69 FR 29071) by U.S. EPA as part of the SIP.

Any facility that is not listed in the 2005 emission inventory, or for the closing of which credit was taken in demonstrating attainment, will not be allowed to construct, reopen, modify, or reconstruct without meeting all ap plicable permit rule requirements. The review process will be identical to that used for new sources. Once the area is redesignated, Indiana will implement NSR for major sources through the PSD program, wh ich requires an air quality analysis to evaluate whether the new sour ce will threaten the NAAQS.

7.0 MODELING AND METEOROLOGY

7.1 Summary of Modeling Results for National Emissi on Control Strategies in Final Rulemakings

Although U.S. EPA’s Redesignation Guidance does not require modeling for ozone nonattainment areas seeking redesignation, extens ive modeling has been performed covering the Cincinnati, Ohio region to determine the effect of national emission cont rol strategies on ozone levels. These modeling analyses determined that the Cincinnati-Hamilton OH-KY-IN 8-hour ozone nonattainment area is significantly impact ed by ozone and ozone precursor transport and regional NO x reductions have helped the area attain the 8-hour standar d. These results show that even in the absence of the Clean Air Interstate Rule (CAIR), the area will continue to attain the standard. Modeling results w ith or without CAIR do not di ffer significantly because the summertime CAIR program is essentially the same as the NO x SIP Call, which was already included in the modeling analysis.

7.2 U.S. EPA Modeling Analysis for HDE Final Rulemaking

U.S. EPA conducted modeling for Tier II vehicles and low-sulfur fuels. This analysis was performed in 2000 to support final rulemaking fo r the Heavy Duty Engine (HDE) and Vehicle Standards and Highway Diesel Fu el and its expected impact on ozone levels. “Technical Support Document for the Heavy Duty Engine an d Vehicle Standards and Highway Diesel Fuel Sulfur Control Requirements: Air Qual ity Modeling Analyses ” (EPA420-R-00-028) was referenced for support of this ozone redesignatio n for the Cincinnati nonattainment area. Base year emissions from 1996 were modeled for th ree ozone episodes: June 12-24, 1995; July 5-15, 1995; and August 7-21, 1995. Results of this modeli ng show that ozone impacts from these fuel emission control measures, as well as the NO x SIP Call, would be substa ntial in the CincinnatiHamilton OH-KY-IN nonattainment area. Relative Response Factors (RRF) were calculated for each monitor in the Cincinnati-Hamilton OH-KY -IN nonattainment area for future years 2007 and 2020. IDEM has applied these RRFs to th e most recent three-year (2007-2009) design values. The resulting future year design va lues for 2007 and 2020 were calculated and are

30shown below in Table 7.1. The 2007 modeled future year design values for all monitors in the Cincinnati-Hamilton OH-KY-IN nona ttainment area are in atta inment of the 8-hour ozone NAAQS of 0.08 ppm.

Table 7.1 Modeling Results: U.S. EPA HDE Rulemaking for the Cincinnati-Hamilton OH-KY-IN Nonattainment Area

Monitor ID Monitor Name County Design Value 2006- 2008 Modeled Relative Response Factor (RRFs) Future Design Value Modeled Relative Response Factor (RRFs) Future Design Value

2007 Base 2007 2020 Base 2020
390170004 Cincinnati CMSA Butle r 0.080 0.8957 0.072 0.8710 0.074 390171004 Cincinnati CMSA Butle r 0.082 0.8816 0.072 0.8507 0.069 390250020 Cincinnati CMSA Clerm ont 0.078 0.8834 0.069 0.8600 0.068 390271002 Cincinnati CMSA Clin ton 0.080 0.8560 0.068 0.8191 0.067 390610006 Cincinnati CMSA Ham ilton 0.085 0.8949 0.076 0.8771 0.074 390610010 Cincinnati CMSA Ham ilton 0.081 0.8826 0.071 0.8749 0.071 390610037 Cincinnati CMSA Ham ilton 0.081 0.9095 0.074 0.8969 0.073 391650006 Cincinnati CMSA Warre n 0.085 0.8851 0.075 0.8576 0.063 210150003 Cincinnati CMSA- KY B oone 0.071 0.8478 0.060 0.8205 0.071 210371001 Cincinnati CMSA- KY Cam pbell 0.081 0.8804 0.073 0.8804 0.067 211170007 Cincinnati CMSA- KY Ke nton 0.078 0.8940 0.069 0.8787 0.074

7.3 U.S. EPA Modeling for Clean Ai r Interstate Rule (CAIR), 2005

On March 10, 2005, the U.S. EPA finalized CAIR. NO x emissions from power plants will be cut by 1.7 million tons by 2009 and emissions will be reduced by 1.3 million tons in 2015 in 28 eastern states and the District of Columbia. Compared to a 2003 baseline, Indiana will reduce NO x emissions by 113,000 tons by 2009 and 149,000 tons by 2015. To support this rulemaking, U.S. EPA first conducted a base case future year modeling run to show future year concentrations resulting from existing emissions controls and then conducted future year modeling with emission reductions a ttributed to CAIR. Results in Table 7.2 show what the base case modeled results without CAIR (base) and with CAIR’s emission reductions included. The modeling was based on 1999 – 2003 (1999-2001, 2000-2002 and 2001-2003) design values. Future year modeling was conducted, incl uding the Cincinnati-Hamilton OH-KY-IN nonattainment area, and the future year desi gn values for 2010 and 2015 were evaluated for attainment of the 8-hour ozone NAAQS. Results of the base case future year modeling and future year modeling with CAIR show that th e area will attain the 8-hour ozone NAAQS in 2010 under both scenarios with modele d concentrations below 0.085 ppm and modeled concentrations decreasing further by 2015. On December 23, 2008, CAIR was remanded without vacatur by the D.C. Circuit Court.

31Table 7.2 Modeling Results from U.S. EPA fo r the Clean Air Interstate Rule

County MSA/CMSA Design Value (ppm) Future Design Value (ppm) Future Design Value (ppm) 1999-2003 2010 Base 2010 CAIR 2015 Base 2015 CAIR Butler Cincinnati, OH – KY 0.0890 0.0782 0.0780 0.0752 0.0736 Clermont Cincinnati, OH – KY 0.0900 0.0781 0.0780 0.0751 0.0725 Clinton Cincinnati, OH – KY 0.0957 0.0817 0.0814 0.0774 0.0757 Hamilton Cincinnati, OH - KY 0.0893 0.0788 0.0786 0.0758 0.0743 Warren Cincinnati, OH – KY 0.0920 0.0802 0.0800 0.0766 0.0751 Boone Cincinnati, OH – KY 0.0853 0.0731 0.0731 0.0710 0.0680 Campbell Cincinnati, OH – KY 0.0925 0.0816 0.0815 0.0788 0.0768

Kenton Cincinnati, OH – KY 0.0863 0.0757 0.0756 0.0733 0.0713

7.4 LADCO’s Round 5 and Round 6 Modeli ng for 8-Hour Ozone Standard

LADCO recently performed updated Comprehensive Air Quality Model (CAMx) modeling for ozone, referred to as “Round 5 and Round 6”, whic h used the most recent emissions inventories and model updates. This modeling was performe d to support attainment demonstrations for the five-state LADCO region. The photochemical model used by LADCO and Indiana for the 8- hour ozone standard analysis is CAMx, Versi on 4.5, developed by Environ. This model has been accepted by U.S. EPA as an approved air quality model for regulatory analysis and attainment demonstrations. Requirements of 40 CFR 51.112 as well as the “Guidance on the Use of Models and Other Analyses in Attain ment Demonstrations for the 8-Hour Ozone NAAQS” (EPA-454/R-05-002, Oct. 2005) are satisfied with the use of CAMx for attainment demonstrations. Meteorology from 2005, as well as 2005 base year emissions, were used to conduct the modeling. The ozone m odeling metrics for bias, error, fractional bias, and fractional error met U.S. EPA modeling gu idance performance criteria. The base-year design value for attainment purposes was calculated from the periods 2003 - 2005, 2004 - 2006 and 2005 - 2007.

Round 5 modeling included several scenarios fo r attaining the ozone NAAQS. One scenario included the implementation of "on-the-books" contro ls for future years such as U.S. EPA motor vehicle and fuel standards with the inclus ion of CAIR. Round 6 modeling included the implementation of "on-the-books" controls, sim ilar to the Round 5 mode ling except without the inclusion of CAIR. The futu re years modeled were 2009, 2012 and 2018. Modeling results, in Table 7.3 and 7.4 below, show ozone concentr ations in the Cincinnati-Hamilton OH-KY-IN nonattainment area below the 8-hour ozone standard in 2009.

32Table 7.3 Application of Round 5 RRFs (with CAIR) to Most Current Base-Year Design Values
2009 2012 2018

Monitor ID Site 2003-2007 Base DV 2009 RRF Future DV 2012 RRF Future DV 2018 RRF Future DV 390170004 Butler Co. - OH 0.0833 0.947 0.078 0.922 0.076 0.851 0.070 390171004 Butler Co. - OH 0.0823 0.95 0.078 0.925 0.076 0.853 0.070 390250022 Clermont Co. - OH 0.0810 0.962 0.077 0.941 0.076 0.877 0.071 390271002 Clinton Co. - OH 0.0823 0.941 0.077 0.910 0.074 0.830 0.068 390610006 Hamilton Co. - OH 0.0847 0.967 0.081 0.948 0.080 0.881 0.074 390610010 Hamilton Co. - OH 0.0820 0.955 0.078 0.934 0.076 0.878 0.071 390610040 Hamilton Co. - OH 0.0817 0.975 0.079 0.958 0.078 0.900 0.073 391650007 Warren Co. - OH 0.0877 0.947 0.083 0.921 0.080 0.846 0.074 210150003 Boone Co. - KY 0.0753 0.949 0.071 0.919 0.069 0.856 0.064 210370003 Campbell Co. – KY 0.0853 0.978 0.083 0.962 0.082 0.906 0.077 211170007 Kenton Co. - KY 0.0783 0.965 0.075 0.949 0.074 0.898 0.070

Table 7.4 Application of Round 6 RRFs (without CAIR) to Most Current Base-Year Design Values
2009 2012 2018

Monitor ID Site 2003-2007 Base DV 2009 RRF Future DV 2012 RRF Future DV 2018 RRF Future DV 390170004 Butler Co. - OH 0.0833 0.947 0.0789 0.925 0.0771 0.868 0.0723 390171004 Butler Co. - OH 0.0823 0.948 0.0781 0.927 0.0763 0.868 0.0715 390250022 Clermont Co. - OH 0.0810 0.955 0.0774 0.939 0.0761 0.893 0.0723 390271002 Clinton Co. - OH 0.0823 0.94 0.0774 0.913 0.0752 0.849 0.0699 390610006 Hamilton Co. - OH 0.0847 0.962 0.0814 0.947 0.0802 0.898 0.0760 390610010 Hamilton Co. - OH 0.0820 0.953 0.0781 0.935 0.0767 0.892 0.0731 390610040 Hamilton Co. - OH 0.0817 0.964 0.0787 0.952 0.0777 0.912 0.0742 391650007 Warren Co. - OH 0.0877 0.944 0.0828 0.92 0.0807 0.857 0.0751 210150003 Boone Co. - KY 0.0753 0.945 0.0712 0.925 0.0697 0.878 0.0661 210370003 Campbell Co. – KY 0.0853 0.968 0.0829 0.957 0.0817 0.920 0.0785 211170007 Kenton Co. - KY 0.0783 0.961 0.0753 0.948 0.0743 0.912 0.0714

7.5 Summary of Existing Modeling Results

U.S. EPA and LADCO modeling sh ows that existing national emi ssion control measures have brought counties in the Cincinnati-Hamilton OH-KY-IN nonattainment area into attainment of the 8-hour ozone NAAQS. Rulemakings to be implemented in the next several years will provide even greater assurance that air quality will co ntinue to meet the standard into the future. Modeling support for the NO x SIP Call, Heavy Duty Engine and Highway Diesel Fuel, and Tier II/Low Sulfur Fuel and CAIR has shown future y ear design values for counties in the CincinnatiHamilton OH-KY-IN nonattainment area will attain the ozone standard with modeled future year design values below 0.085 ppm. Review of the design values of the ozone monitors in the Cincinnati-Hamilton OH-KY-IN nonattainment area show an overall decline in ozone concentrations, as indicated by the trend lin e for the ozone monitor (390610006) in Hamilton County, Ohio with the highest design value for 2007-2009.

33Graph 7.1 Actual Design Values for Cincinnati Nonattainment Area from 1997 through 2009

0.06 0.065

0.07 0.075

0.08 0.085

0.09 0.095

0.1 0.105

0.11

1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 390170004
390171004
390250020
390250022
390271002
390610006
390610010
390610037
390610040
391650002
391650006
391650007
210150003
210371001
210373002
210370003
211170007 Linear (390610006)

On December 23, 2008, CAIR was remanded wit hout vacatur by the D.C. Circuit Court. U.S. EPA has modeled base case future years with ex isting emission controls only and shown that counties in the Cincinnati-Ham ilton OH-KY-IN nonattainment area will attain the 8-hour ozone NAAQS without proposed additional national emission control strategi es. The application of the most current relative res ponse factors from LADCO’s Round 5 and Round 6 modeling demonstrates that the area will continue to attain the standard into the future with or without implementation of CAIR. Future national and loca l emission control strate gies will ensure that each county’s attainment will be maintained with an increasing margin of safety over time.

7.6 Temperature Analysis for the Cincinnati, Ohio Area

Meteorological conditions are one of the most important factors that influence ozone development and transport. A temperature an alysis was conducted to determine how the temperatures during the ozone c onducive months of April, May, June, July, August, September and October compare to normal temperatures fo r the Cincinnati area for the years 1971 through 2000. Temperature information was taken from the National Weather Service Station at Cincinnati Municipal Airport Lunken Field . Normal maximum temperatures from 1971-2000 for the Cincinnati area are as follows:
May – 74.8 o F June – 82.7 o F July – 86.7 o F August – 85.1 o F September – 78.7 o F May - September – 81.6 o F

34Monthly maximum temperatures for the prev ious 10 years (2000 – 2009) during the summer months are compared to norma l summer month temperatures in Table 7.5. Overall, the temperatures during the 2002, 2003, 2005 and 2007 su mmer months of May, June, July, August and September were 1% to 6% above nor mal while temperatures during the 2000, 2001, 2004, 2006, 2008 and 2009 summer months were at normal to 4% lower than the normal temperatures. Table 7.5 shows the average temperatures in the Cincinnati area for each of the past ten years and the percent difference from normal for each year.

Table 7.5 Analysis of Maximum Temperatures for the Cincinnati, Ohio Area (Percent Change from Maximum Temperature ( o F) Normals (1971 – 2000))

Normal 2000 2001 2002 2003 2004

Max Max % Max % Max % Max % Max % May 74.8 75.6 +1 75.1 0 70.5 -6 70.5 -6 76.5 +2 June 82.7 81.2 -2 80.1 -3 83.1 0 83.1 0 80.4 -3 July 86.7 81.9 -6 83.9 -3 89.0 +3 89.0 +3 82.3 -5 August 85.1 81.4 -4 83.8 -2 88.0 +3 88.0 +3 80.2 -6 September 78.7 74.9 -5 74.5 -5 82.8 +5 82.8 +5 79 0 AVE 81.6 79.0 -3 79.5 -3 82.7 +1 82.7 +1 79.7 -2

Normal 2005 2006 2007 2008 2009

Max Max % Max % Max % Max % Max % May 74.8 71.6 -4 71.9 -4 79.9 +7 71.1 -5 74.2 -1 June 82.7 85.3 +3 80.1 -3 85.6 +4 83.8 +1 82.1 -1 July 86.7 86.5 0 86.7 0 85.8 -1 84.9 -2 78.7 -9 August 85.1 87.5 +3 87 +2 93.6 +10 85.4 0 81.6 -4 September 78.7 81.6 +4 73.1 -7 85.7 +9 82.4 +5 76.6 -3 AVE. 81.6 82.5 +1 79.8 -2 86.1 +6 81.5 0 78.6 -4

The number of days with temperatures of 90 o F and higher were collected from the National Weather Service Station at Cincinnati Municipal Airport Lunken Field and compared to the average number of days from 1999 through 200 9 as well as the number of 8-hour ozone exceedance days. Table 7.6 shows this compar ison of 8-hour ozone exceedance days and number of 90 o F temperature days while Graph 7. 2 shows the correlation graphically.

35Table 7.6 Comparison of Days with 90 o F and 8-Hour Ozone Exceedance Days 1998- 2009 Number of Days with Temperatures of 90 o F and higher

Site County Ave. 90 o F Days 1998 1999 2000 2001 2002 2003
Cincinnati, OH Hamilton Co. 21.2 15 33 4 9 37 5

Number of 8-Hour Exceedance Days at Cinc innati Nonattainment area ozone monitors

Monitor County 1998 1999 2000 2001 2002 2003

390170004 Butler Co 18 28 9 17 29 17 390171004 Butler Co 33 37 10 16 33 17 390250020 Clermont Co 30 42 15 N/O N/O N/O 390250022 Clermont Co N/O N/O N/O 14 28 8 390271002 Clinton Co 35 45 17 24 35 16 390610006 Hamilton Co 21 22 6 13 33 18 390610010 Hamilton Co 22 15 6 8 24 12 390610040 Hamilton Co N/O 24 10 13 29 10 391650006 Warren Co 18 34 11 14 33 2 391650007 Warren Co N/O N/O N/O N/O N/O 18 210150003 Boone Co 18 22 6 9 21 5 210371001 Campbell Co 22 21 N/O N/O N/O N/O 210373002 Campbell Co N/ O N/O N/O N/O N/O N/O 210370003 Campbell Co N/O N/O 12 19 38 8 211170007 Kenton Co 22 28 9 12 32 8

Number of Days with Temperatures of 90 o F and higher

Site County Ave. 90 o F Days 2004 2005 2006 2007 2008 2009
Cincinnati, OH Hamilton Co. 21.2 4 30 25 52 25 4

Number of 8-Hour Exceedance Days at Cinc innati Nonattainment area ozone monitors

Monitor County 2004 2005 2006 2007 2008 2009

390170004 Butler Co 3 22 11 20 1 0 390171004 Butler Co 5 24 4 27 7 0 390250020 Clermont Co N/O N/O N/O N/O N/O N/O 390250022 Clermont Co 4 16 7 17 0 0 390271002 Clinton Co 6 23 10 21 4 0 390610006 Hamilton Co 4 22 9 33 12 0 390610010 Hamilton Co 3 19 10 23 7 0 390610040 Hamilton Co 4 20 8 15 7 0 391650006 Warren Co N/ O N/O N/O N/O N/O N/O 391650007 Warren Co 10 24 12 32 11 0 210150003 Boone Co 1 8 0 6 0 0 210371001 Campbell Co N/ O N/O N/O N/O N/O N/O 210373002 Campbell Co N/O N/O N/O 19 2 0 210370003 Campbell Co 5 23 N/O N/O N/O N/O 211170007 Kenton Co 2 12 3 12 2 0 N/O – Not Operational

36Graph 7.2 Comparison of Days with 90 o F and 8-Hour Ozone Exceedance Days

0 10 20 30 40 50 60

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

YearNumber of Days 90o F Days

390170004

390171004
390250020
390250022

390271002
390610006
390610010

390610037
390610040
391650006

391650007
210150003
210371001

210373002
210370003
211170007

As can be seen, a greater number of ozone excee dance days per year correlate with a greater number of 90 o F days per year. The effects of nationa l control measures appear to have an impact on the number of ozone exceedance days pe r year. This is evident in that 2005 had a greater number of days with temperatures of 90 o F or more but the number of 8-hour exceedance days was lower. While other me teorological factors may have infl uenced this result to some degree, it appears that the lower emissions helped to k eep the number of 8-hour ozone exceedance days lower during the ozone-conduciv e conditions of 2005. In 2007, there were 52 days of 90 o F or more and three monitors with the number of 8-hour ozone exceedance days over 25. In 2002 there were 37 days of 90 o F or more and nine monitors with the number of 8-hour ozone exceedance days over 25. There were si milar meteorological conditions in 2002 and 2007 and less monitors had days over the 8-hour oz one standard in 2007, indicating that emission reductions are decreasing ozone concentrations in the area.

7.7 Summary of Meteorological Conditions

The analysis of the departure from normal of the maximum temperatur es during the summer months shows variation as illustrated in Table 7.6 and Graph 7.2. The analysis shows that 15 or more days with temperatures of 90 o F and higher occurred in 1998, 1999, 2002, 2005, 2006, 2007 and 2008. The number of 8-hour ozone exceedance days for those years shows a greater correlation to the number of higher temperature da ys. However, the years with a lesser number of 90 o F days still yielded 8-hour ozone exceedance days. For example, 2000 and 2001 had fewer than the normal amount of 90 o F days; however, there were st ill a significant number of 8- hour ozone exceedances for those years. In co mparison, 2004 was a cooler year, but due to

37national emission reduction measures in effect , there were fewer ozone exceedances. Lower ozone values correspond to lowered local and re gional ozone precursor em issions despite ozone conducive conditions. The 8-hour ozone standard, e xpressed as a 4th high ozone value averaged over 3 years, accounts for variations in temperature. Despite such variations, ozone values in the Cincinnati nonattainment area ha ve steadily decreased since 1998.

8.0 CORRECTIVE ACTIONS

8.1 Commitment to Revise Plan

As noted in Section 4.6 above, Indiana commits to review its Maintenanc e Plan eight (8) years after redesignation, as require d by Section 175A of the CAA.

8.2 Commitment for Contingency Measures

Indiana hereby commits to adopt and expeditiously implement necessary corrective actions in the following circumstances:

Warning Level Response: A Warning Level Response shall be prompted whenever an annual (1-year) fourth high monitored value of 0.089 ppm occurs in a sing le ozone season, or a two (2)-year average fourth high monitored value of 0.085 ppm or great er occurs within the maintenance area. A Warning Level Response will consist of a study to determine whether the ozone value indicates a trend toward hi gher ozone values or whether emissions appear to be increasing. The study will evaluate whether the trend, if any, is likely to continue and, if so, the control measures necessary to revers e the trend taking into consideration ease and timing for implementation, as well as economic and social considerations. Implementation of necessary controls in re sponse to a Warning Level Response trigger will take place as expeditiously as possible, bu t in no event later than twelve (12) months from the conclusion of the most recent ozone season (September 30). Should it be determined through the Warning Level study that action is necessary to reverse the noted trend, the procedures for control selecti on and implementation outlined under “Action Level Response” shall be followed.
Action Level Response An Action Level Response shall be prompted wh enever a violation of the standard (three (3)-year average fourth high monitored value of 0.085 ppm or greater) occurs within the maintenance area. In the event that the Acti on Level is triggered and is not found to be due to an exceptional event, malfunction, or noncompliance with a permit condition or rule requirement, IDEM will determine additional control measures needed to assure future attainment of the NAAQS for ozone. In this case, measures that can be implemented in a short time will be selected and be in place within eighteen (18) months from the close of the ozone season that prompted the Action Level.

38Control Measure Selection and Implementation Adoption of any additional control measures is subject to the necessary administrative and legal process. This process will include publication of notices, an opportunity for public hearing and other measures require d by Indiana law for rulemaking by state environmental boards.

If a new measure/control is al ready promulgated and scheduled to be implemented at the federal or state level, and that measure/contro l is determined to be sufficient to address the upward trend in air quality, additional local measures may be unnecessary. Furthermore, Indiana will submit to U.S. EP A an analysis to demonstrate the proposed measures are adequate to re turn the area to attainment.

8.3 Contingency Measures

Contingency measures to be considered will be selected from a comprehensive list of measures deemed appropriate and effective at the time the selection is made. Listed below are example

measures that may be considered. The selec tion of measures w ill be based upon costeffectiveness, emission reduction po tential, economic and social c onsiderations, or other factors that IDEM and U.S. EPA deem a ppropriate. IDEM will solicit input from interested and affected persons in the maintenance area prior to selecting appropriate c ontingency measures. All of the listed contingency measures are potentially effect ive or proven methods of obtaining significant reductions of ozone precursor emissions. Because it is not possible at this time to determine what control measure will be a ppropriate at an unspecified ti me in the future, the list of contingency measures outlined below is not comprehensive. Indiana anticipates that if contingency measures should ever be necessary, it is unlikely th at a significant number (i.e., all those listed below) will be required.

1. Installation of a vehicle emissions testing program 2. Asphalt paving (lower VOC formulation) 3. Diesel exhaust retrofits 4. Traffic flow improvements 5. Idle reduction programs 6. Portable fuel containe r regulation (statewide) 7. Park and ride facilities 8. Rideshare/carpool program 9. VOC cap/trade program for ma jor stationary sources 10. Commercial/consumer solvents (statewide) 11. NO x Reasonably Availabl e Control Technology

No contingency measure shall be implemented w ithout providing the opportunity for full public participation during which the relative costs and be nefits of individual meas ures, at the time they are under consideration, can be fully evaluated.

399.0 PUBLIC PARTICIPATION

Indiana published notification for a public hearing and soli citation for public comment concerning the draft Redesignation Petition and Maintenance Plan in the Journal Press, Lawrenceburg, Indiana on December 7, 2009 and the Indianapolis Star, Indianapolis, Indiana on December 8, 2009.

A public hearing to receive comments concerni ng the redesignation re quest was conducted on January 7, 2010 at the Lawrenceburg Public Li brary in Lawrenceburg, Indiana. The public comment period closed on January 13, 2009, no comments were received by the agency concerning this submission. Appendix J documents the public hearing process and includes a copy of the public notice, certificat ions of publication, and the transc ript from the public hearing.

10.0 CONCLUSIONS

Lawrenceburg Township in Dearborn County, Indian a, along with the rema ining portion of the Cincinnati-Hamilton OH-KY-IN nonattainment ar ea, has attained the NAAQS standard for ozone. This petition demonstrates that Lawrenceburg Township in Dearborn County has complied with the applicable provisions of the CAA regarding redesignation of ozone nonattainment areas. IDEM has prepared a Re designation Request and Maintenance Plan that meets the requirement of Section 11 0(a)(1) of the Clean Air Act.

Indiana has performed an analysis that shows the air quality imp rovements are due to permanent and enforceable measures and that significant regional NO x reductions will ensure continued compliance (maintenance) with the standard. Additionally, Indiana has ensured that all CAA requirements necessary to support redesignation have been met.

In addition to the corrective actions (should they be necessary) outlined in this submittal, Indiana continues to participate in the regional air quality planning e fforts sponsored by LADCO. The current goal of the planning process is to establis h a regional control strategy that provides for attainment of the ozone and fine particle sta ndards throughout the states of Illinois, Indiana, Michigan, Ohio and Wisconsin. Along with th e other LADCO states, Indiana is developing local and statewide emission control measures , where photochemical modeling and culpability analyses demonstrate a clear need and cost effectiveness analyses justify the implementation of such measures. These actions will provide fo r an even greater margin of safety for the Cincinnati, Ohio area and ensure conti nued maintenance well into the future.

Based on this presentation, Indi ana’s portion of the nonattainmen t area (Lawrenceburg Township in Dearborn County) meets the requirements for redesignatio n under Section 107(d)(3) of the CAA and U.S. EPA guidance. Furthermore, because this area is subject to transport, additional regional NO x and VOC reductions will ensure conti nued compliance (maintenance) with the standards and provide an in creased margin of safety.

40Consistent with the authority granted to the U.S. EPA under Section 107(d)(3) of the CAA, Indiana requests that Lawrence burg Township in Dearborn County be redesignated to attainment simultaneously with U.S. EPA approval of th e Redesignation Request and Maintenance Plan provisions contained herein.

41