### IDEM INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

We Proleel Hoosiers and Our Environmenl.
Mitchell E. Daniels Jr. 100 North Senate Avenue Governor Indianapolis, Indiana 46204 (317) 232-8603 Thomas W. Easterly Toll Free (800) 451-6027 Commissioner www.idem.IN.gov

January 14, 2011

Ms. Susan Hedman Regional Administrator U.S. Environmental Protection Agency Region 5 77 West Jackson Boulevard Chicago, IL 60604-3950

Dear Ms. Hedman:

Re: Submittal of Indiana Regional Haze State Implementation Plan

The Indiana Department of Environmental Management (IDEM) submits the Indiana Regional Haze State Implementation Plan (SIP). IDEM conducted a public hearing concerning the SIP on January 11, 2011 and the public comment period concluded on January 13, 2011.

IDEM has worked closely with the Lake Michigan Air Directors Consortium (LADCO), other regional planning organizations, Federal Land Managers (FLMs), the United States Environmental Protection Agency (U.S. EPA), and other states to address the requirements of the Regional Haze rule.

IDEM has completed the following tasks related to the Regional Haze SIP: Demonstrated that the implementation plan includes all measures necessary to obtain our fair share of emission reductions needed to meet Reasonable Progress Goals at all Class I areas where visibility is impacted by emissions from Indiana (40 CFR 51.308(d)(3)(ii)). Identification of BART-eligible units Modeling to determine sources subject to BART Review of analyses submitted by sources subject to BART Determined that one source is subject to BART Development of the BART rule, 326 lAC 216-2, final adopted by the Air Pollution Control Board on November 3,2010 to incorporate emission limits for sources subject to BART

In addition, IDEM is committed to continue working with other regions and states

on improving visibility in Class I areas, including the following:

Recycled Paper (i) An Equal Opportunity Employer Please Recycle 

### UMs. Hedman, Page 2

Address comments from the FLMs and public concerning Indiana's draft Regional Haze SIP. These will be submitted in a later addendum. Submit a SIP report in 2013 to update and review the status of impacts to visibility in Class I areas Submit a Regional Haze SIP revision by July 31,2018

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 (317) 233-5694.

Sincerely,

# E)~6 Keith Baugues Assistant Commissioner Office of Air Quality

KB/knr Attachments

Cc: John Summerhays, U.S. EPA Region 5 (wi enclosures) Cheryl Newton, U.S. EPA Region 5 (no enclosures) Scott Deloney, IDEM (no enclosures) Christine Pedersen, IDEM (no enclosures)

# Draft
Indiana Regional Haze State Implementation Plan

Developed By: The Indiana Department of Environmental Management

November 2010i Table of Contents

1.0 Introduction and Background ......................................................................................... 1 2.0 Regional Planning ............................................................................................................. 3 3.0 Indiana and Federal Land Manager Coordination ....................................................... 5 4.0 Development of Reasonable Progress Goals ................................................................... 6 4.1 Assessment of Baseline (or Current) Condition s and Estimate of Natural Conditions (in Class 1 Areas)

.............................................................................................................................. .. 7 4.2 Glidepaths to Natural Conditions in 2064 ............................................................................ 8 4.3 Letters Requesting Participation in Consul tation Process from States with Class 1 Areas 8 5.0 Emissions Inventory ......................................................................................................... 8 5.1 Base Year Emissions ......................................................................................................... 9 5.2 On-road Mobile ................................................................................................................. 9 5.3 Nonroad Mobile .............................................................................................................. 10 5.4 Area Sources .................................................................................................................... 11 5.5 Point Sources – Electric Generating Units (EGUs) ........................................................... 11 5.6 Point Sources – Non-EGU .................................................................................................... 12 5.7 Other Improvements ............................................................................................................ 12 5.8 Future Year Emissions ......................................................................................................... 14 6.0 Modeling Assessment ...................................................................................................... 19 6.1 Regional Haze/Visibility .................................................................................................. ..... 20 6.2 Attainment Tests for Re gional Haze/Visibility................................................................... 20 6.3 Regional Haze Modeling Results ......................................................................................... 22 7.0 Reasonable Progress Goals ............................................................................................ 25 7.1 Background ........................................................................................................................... 25 7.2 Voyageurs National Park and Boundary Waters Canoe Area Wilderness Area ........... 25 7.3 Mammoth Cave National Park ............................................................................................ 26 7.4 Great Smoky Mountains National Park ............................................................................. 27 7.5 Sipsey Wilderness Area ........................................................................................................ 27 7.6 James River Face Wilderness Area, Shenandoah National Park, Dolly Sods/Otter Creek Wilderness Areas ........................................................................................................................ 28 7.7 Caney Creek and Upper Buffalo Wilder ness Areas, AR, and Hercules-Glades and Mingo Wilderness Areas, MO ................................................................................................... 30 7.8 Isle Royale National Park and Se ney National Wildlife Refuge, MI ............................... 32 7.9 Acadia National Park, ME, Moosehorn Wi lderness Area, ME, Gr eat Gulf Wilderness Area, NH, Brigantine Wilderness Area, NJ, and Lye Brook Wilderness Area, VT (MANEVU) 33 8.0 Best Available Retrofit Technology ............................................................................... 35 8.1 BART - Eligible Sources in Indiana .................................................................................... 36 8.2 Sources Subject to BART ..................................................................................................... 37 8.3 BART Analysis ...................................................................................................................... 42 8.4 BART Determination and Modeling for Burns Harbor ................................................... 43 8.4.1 IDEM’s BART Determination Process ......................................................................... 43 8.4.2 IDEM’s BART Modeling Process .................................................................................. 44 8.4.3 Modeling Domain and Meteorology .............................................................................. 45ii 8.4.4 Class 1 Areas ................................................................................................................... 45 8.4.5 Visibility Impairment Pollutants Analyzed .................................................................. 46 8.4.6 IDEM’s Subject to BART Determination Modeling Results ..................................... 46 8.4.7 IDEM’s Culpability Modelin g Results for Burns Harbor ......................................... 47 8.4.8 Burns Harbor’s BART Determination Modeling ........................................................ 48 8.4.9 Comparison of Burns Harbor and IDEM BART Determination Modeling ............. 49 8.4.10 Summary of Burns Harbor BART Determination Analysis ....................................... 50 8.5 BART Determination and Modeling fo r ESSROC Cement Corporation - Speed .......... 51 8.5.1 IDEM’s BART Determination Process ........................................................................ 52 8.5.2 ESSROC’s BART Determin ation Modeling Results ................................................... 54 8.5.3 IDEM’s BART Determination Modeling Results ....................................................... 54 8.5.4 Summary of ESSROC BART Determination Analysis ............................................... 55 8.6 BART Determination and Modeling for SA BIC Innovative Plastics – Mount Vernon . 55 8.6.1 IDEM’s BART Determination Process ......................................................................... 56 8.6.2 Visibility Impairment Pollutants Analyzed .................................................................. 57 8.6.3 SABIC’s BART Determination Modeling Results ....................................................... 58 8.6.4 IDEM’s BART Determination Modeling Results ........................................................ 59 8.6.5 Summary of SABIC BART Determination Analysis ................................................... 60 8.7 BART Determination and Modeling for Alcoa .................................................................. 60 8.7.1 Summary of Alcoa BART Analysis ............................................................................... 60 8.7.2 BART-eligible units at Alcoa ......................................................................................... 61 8.7.3 BART Analysis ................................................................................................................ 61 8.7.4 Control Strategy .............................................................................................................. 62 8.7.5 Discussion ......................................................................................................................... 63 8.8 Indiana BART Rule .............................................................................................................. 69 9.0 Long Term Strategy ........................................................................................................ 69 9.1 Strategy requirements .......................................................................................................... 69 9.2 Discussion

............................................................................................................................... 69 9.3 Strategy

.............................................................................................................................. .... 70 10.0 State Implementation Plan Revisions a nd Adequacy of the Existing Plan................ 70 10.1 State Implementation Plan Revisions ................................................................................ 70 10.2 Determination of the Adequacy of the Existing Plan ...................................................... 70

List of Tables

Table 1 Calls and Meetings Regarding Class 1 Areas .................................................................... 5 Table 2 Summary of On-road Emissions (Tons Per Day – July 15, 2005) .................................. 16 Table 3 EGU Emissions for Base (5a), Will Do (5b), and May Do (5c) Scenarios ..................... 17 Table 4 Emissions Summaries ................................................................................................... ... 18 Table 5 Class 1 Areas Modeled by the MRPO ............................................................................. 19 Table 6 Visibility Modeling Results (Deciviews) for Class 1 Areas in Eastern U.S. (Worst 20%)

............................................................................................................................... ........................ 24 Table 7 Visibility Modeling Results (Deciviews) for Class 1 Areas in Eastern U.S. (Best 20%) 24 Table 8 MRPO Round 5 Modeling Results (dv) .......................................................................... 35 Table 9 Indiana Sources with BART-Eligible Units .................................................................... 36iii Table 10 Indiana BART-eligible Electric Generating Units covered by CAIR .......................... 38 Table 11 IDEM’s Revised CALPUFF M odeling Results for Burns Harbor ............................... 47 Table 12 Number of Modeled Days over 0.5 dvs for Class 1 Areas ........................................... 47 Table 13 IDEM’s Culpability Modeling Results for Burns Harbor ............................................ 48 Table 14 Burns Harbor’s CALPUF F Modeling Results over 0.5 Dv .......................................... 49 Table 15 Number of Modeled Days over 0.5 dv for Class 1 Areas ............................................. 49 Table 16 IDEM’s Revised CALPUF F Modeling Results at Seney ............................................. 50 Table 17 BART-eligible Stack Parameters for Burns Harbor ..................................................... 51 Table 18 BART Emission Rates for ESSROC - Speed ............................................................... 53 Table 19 BART-eligible Stack Parameters for ESSROC - Speed ............................................... 54 Table 20 ESSROC – Speed’s CALPUFF Modeling Results ....................................................... 54 Table 21 IDEM’s Revised CALPUFF Mode ling Results for ESSROC - Speed ......................... 55 Table 22 BART Emission Rates for SABIC................................................................................ 57 Table 23 BART-Eligible Stack Parameters for SABIC ............................................................... 58 Table 24 SABIC’s CALPUFF Mo deling Results over 0.5 dv ..................................................... 59 Table 25 IDEM’s Revised CALPUF F Modeling Results for SABIC ......................................... 59 Table 26 Summary of Visibi lity Modeling Analysis ................................................................... 62 Table 27 Summary of emissions impact of various control scenarios ......................................... 63 Table 28 Alcoa Proposed BART Control Strategy ...................................................................... 65 Table 29 Alcoa Proposed BART Emission Limits ...................................................................... 66 Table 30 Highest Contribution from BART-elig ible Units in any Modeling Scenario ............... 67 Table 31 Source Culpability for the Highest Baseline Impact .................................................... 68

List of Figures

Figure 1 Regional Planning Organizations ..................................................................................... 4 Figure 3 Map Showing Locations of Cla ss 1 Areas in Northeastern U.S. ...................................... 7 Figure 4 Map Showing Locations of Class 1 Areas in Northern U.S. ............................................ 7 Figure 5 July 15, 2005 Motor Vehicle Emissions for VOC and NO x (Tons Per Day) ................. 10 Figure 6 Base Year Emission Plots for Canada ............................................................................ 12 Figure 7 Base Year Emission Plots for Canada ............................................................................ 13 Figure 8 Isoprene Emissions for Current Invent ory (left) v. Previous Inventory (right) .............. 14 Figure 9 Average Daily Tonnage of Ammonia Em issions for Midwest States by Month (2005) 14 Figure 10 Visibility Modeling Results fo r Class 1 Areas in Eastern U.S. .................................... 23 Figure 11 Mammoth Cave Uniform Ra te of Progress Glidepath ................................................. 26 Figure 12 Great Smoky Mountains Unifor m Rate of Progress Glidepath .................................... 27 Figure 13 Sipsey Uniform Rate of Progress Glidepath ................................................................ 28 Figure 14 James River Face Uniform Rate of Progress Glidepath ............................................... 29 Figure 15 Shenandoah Uniform Rate of Progress Glidepath ........................................................ 29 Figure 16 Dolly Sods Uniform Ra te of Progress Glidepath ......................................................... 30 Figure 17 Caney Uniform Rate of Progress Glidepath ................................................................. 31 Figure 18 Upper Buffalo Uniform Rate of Progress Glidepath .................................................... 31 Figure 19 Hercules-Glades Uniform Rate of Progress Glidepath ................................................ 32 Figure 20 Mingo Uniform Rate of Progress Glidepath ................................................................ 32 Figure 21 Acadia Visibility Impact Modeling .............................................................................. 34 Figure 22 Lye Brook Visibility Impact Modeling ........................................................................ 34iv Appendices

Appendix 1 - Class I Areas Located Within (or Impacted by) Midwest RPO States Appendix 2 - Letters Reques ting Participation by Stat es with Class I Areas Appendix 3 - Assessment of Class I Areas Impacted by Indiana Sources Appendix 4 - SIP Checklist Appendix 5 - BART Eligibility and Modeling Results Appendix 5a - Additional BART information for Burns Harbor Appendix 5b - Additional BART information for ESSROC-Speed Appendix 5c - Additional BART information for SABIC Appendix 5d - BART determination Report for Alcoa, Inc. - Warrick Operations Appendix 6 - Smoke Management Appendix 7 - Indiana BART Rule1 1.0 Introduction and Background

This document constitutes the Indiana Department of Environmental Management (IDEM) Regional Haze State Implementation Plan (SIP). The federal Regional Haze Rule requires Indiana to submit a SIP to the United States Environmental Protection Agency (U.S. EPA). Indiana does not have any Class 1 areas; however , Indiana sources have been determined to impact visibility in Class 1 areas in other states . The Clean Air Act requi res Indiana to develop a strategy to mitigate visibility impairment in thos e areas. The strategy has been developed in consultation with the Midwest Regional Planni ng Organization (MRPO) and affected states using data and tools, including emissions i nventories and modeling analyses taking into consideration factors such as existing pollution control programs, emissions reduction needs, compliance schedules, and smoke management tec hniques. This document describes Indiana’s consultation process, technical analyses, and actions to be pursued to reduce visibility impairment in other Class 1 areas.

In amendments to the Clean Air Act in 1977, Congress added Section 169 (42 U.S.C. 7491) setting forth the following national visibility goal: Congress hereby declares as a national goal the prevention of any future, and the remedying of any existing, impairment of vi sibility in mandatory Class 1 Federal areas which impairment results fr om manmade air pollution.

When the Clean Air Act was amended in 1990, C ongress added Section 169B (42 U.S.C. 7492), authorizing further research and regular assessmen ts of the progress made so far. In 1993, the National Academy of Sciences concluded that “c urrent scientific knowledge is adequate and control technologies are availabl e for taking regulatory action to improve and protect visibility.” 1

In addition to authorizing creati on of visibility transport commi ssions and setting forth their duties, Section 169B(f) of the Clean Air Act mandated creation of the Grand Canyon Visibility Transport Commission (Commission) to make recommendations to U.S. EPA for the region affecting the visibility of Grand Canyon Nationa l Park. The Commission submitted its report to U.S. EPA in June 1996, following four years of re search and policy development. That report, as well as the many research reports prepar ed by the Commission, contributed invaluable information to U.S. EPA in its developmen t of the federal Regional Haze Rule.

U.S. EPA’s Regional Haze Rule (RH Rule) was adopted July 1, 1999, and went into effect on August 30, 1999 (64 FR 35714). The RH Rule is ai med at achieving national visibility goals by 2064. This rulemaking addressed the combined visi bility effects of va rious pollution sources over a wide geographic region. This wide reach ing pollution net means that many states, even those without Class 1 areas, are required to par ticipate in haze reduction efforts. U.S. EPA designated five Regional Planni ng Organizations (RPO) to assi st with the coordination and cooperation needed to addr ess the haze issue.

U.S. EPA’s Regional Haze rulemaking process wa s controversial. On May 24, 2002, the U.S. Court of Appeals, DC District Court, rule d on the challenge brought by the American Corn Growers Association against the RH Rule. The Court remanded to U.S. EPA the Best Available

1 Protecting Visibility in National Parks and Wilderness Areas , National Research Council. Washington, DC: 1993.2 Retrofit Technology (BART) provisions of the rule , and denied industry’s challenge to the haze rule goals of natural visibility and no degradation requirements. U.S. EPA issued revisions to the RH Rule pursuant to the remand.

Regional haze is caused by tiny particles that ab sorb and scatter sunli ght, creating white and brown haze. The RH Rule requires States to submit SIPs to address regional haze visibility impairment in 156 federally protected parks a nd wilderness areas. Thes e 156 scenic areas are called “mandatory Class 1 Federal areas” in the Cl ean Air Act but are generally referred to as “Class 1 areas.” As required by the Clean Air Ac t, U.S. EPA included in the final RH Rule a requirement for BART for certain large stationa ry sources. The RH Rule uses the term “BARTeligible source” to describe these sources. Under the Clean Air Act, BART is required for any BART-eligible source that a state determines “emits any air pollutant which may reasonably be anticipated to cause or c ontribute to any impairment of visibility in any such area.” Accordingly, for stationary sources meeting these criteria, st ates must address the BART requirement when they develop their Regional Haze SIPs.

On July 6, 2005, U.S. EPA published the Best Available Retrofit Technology Guidelines (BART Guidelines) in the Federal Regist er (70 FR 39104). These guidelines are a component of the July 1, 1999 Regional Haze regulations.

Though States have some discretion on the use of the BART Guidelines for most sources, Section 169A(b) of the Clean Air Act and 40 CF R 51.308(e)(1)(ii)(B) require that states follow the BART Guidelines for fossil-fuel fired genera ting power plants having a capacity in excess of 750 megawatts.

All Regional Haze SIPs ar e due three years after U.S. EPA designated PM 2.5 attainment and nonattainment areas. The FY 2004 Omnibus Appr opriations Bill effectively addressed 40 CFR 51.308(b) and (c). The Appropriations Bill said th at all Regional Haze SIPs would be due three years after the PM 2.5 designation dates regardless of attainment status. The U.S. EPA approved PM 2.5 designations for all areas of each stat e on December 17, 2004. All Regional Haze SIPs were therefore due December 17, 2007.

The RH Rule requires states to set reasonable progress goals to ward meeting a national goal of natural visibility conditions in Class 1 areas by the year 2064. The first reasonable progress goals will be established for the planning period 2008 to 2018.

Even though Indiana has no Class 1 areas, U.S. EPA's Regional Haze Rule requires a state to address regional haze in each Class 1 area outside the state which may be affected by emissions from within the state. Indian a has participated in extensive technical analyses conducted by the MRPO to determine if any Class 1 areas have visibility impairment that may be caused by sources within the state.

This Regional Haze SIP will address the initial 10-year implementation period (i.e., reasonable progress by the year 2018). SIP requirem ents (pursuant to 40 CFR 51.308(d)) include establishing reasonable progress goals, determin ing baseline conditions, determining natural conditions, providing a long-term control strateg y, providing a monitoring strategy (air quality3 and emissions), and establishing BART emissi ons limitations and an associated compliance schedule.

Pursuant to the requirements of 40 CFR 51.308(a) a nd (b), Indiana submits this SIP to meet the requirements of the RH Rule that was adopted to comply with requirements set forth in the Clean Air Act. Elements of this SIP addre ss the core requirements pursuant to 40 CFR 51.308(d) and the BART components of 40 CFR 50.308(e). In addition, this SIP describes Indiana’s consultation process, technical analyses, and actions to be pursued to reduce visibility impairment in Class 1 areas.

Indiana has developed this SIP in accordance with Indiana laws and rules and has the authority to implement the SIP in accordance with those laws and rules.

Indiana will provide public notice of the opportuni ty to comment on the SIP and of the public hearing that will be held regarding the SIP. Public comments will be addressed and summarized in the final version of the SIP.

2.0 Regional Planning

The MRPO was formed to facil itate regional planning to address the regional haze regulations adopted by U.S. EPA in 1999. The primary objective of the MRPO is to a ssess both visibility impairment due to regional haze in the mandato ry Federal Class 1 areas located inside the borders of the five States of Illinois, Indiana, Michigan, Ohio, and Wisconsin, and to assess the impact of emissions from the five states on visi bility impairment due to regional haze in the mandatory Federal Class 1 areas located outside th e borders of the five States. Members of the MRPO include the five states, tribes located with in the five states, Federal Land Managers (U.S. National Park Service, U.S. Fish & Wildlife Serv ice, and U.S. Forest Service), and U.S. EPA. The Lake Michigan Air Directors Consortium (LADC O) has been designated as the agency to receive federal grant fund s on behalf of the MRPO.

This SIP uses data analyses, modeling results a nd other technical support documents prepared for MRPO members. By coordina ting with the MRPO and other Regional Planning Organizations (RPOs), Indiana has worked to ensure that its lo ng term strategy provides sufficient reductions to mitigate impacts of sources from Indiana on affected Class 1 areas.

The other RPOs are Mid-Atlantic / Northeast Visibility Union (MANE-VU), Central Regional Air Planning Association (CENRAP), Visibility Improvement State and Tribal Association of the Southeast (VISTAS), and Western Regional Ai r Partnership (WRAP). Figure 1 shows a map of the regional planni ng organization boundaries.4 Figure 1 Regional Planning Organizations

Indiana does not have any Class 1 areas. Howeve r, emissions from Indiana sources have been determined to impact Class 1 areas in other stat es. Appendix 1 contains a list of these Class 1 areas, and the analyses performed to assess the impact from Indiana that were compiled by the MRPO. The following areas are listed as po ssibly being impacted by Indiana sources:

Southeastern U.S. (VISTAS) - Sipsey Wilderness Ar ea, AL; Mammoth Cave National Park, KY; Great Smoky Mountains National Park, NC and TN; James River Face Wilderness Area, VA; Shenandoah National Park, VA; and Dolly S ods / Otter Creek Wild erness Areas, WV

Eastern U.S. (MANE-VU) - Acadia National Park, ME; Moosehorn Wilderness Area, ME; Great Gulf Wilderness Area, NH; Brigantine W ilderness Area, NJ; and Lye Brook Wilderness Area, VT

Northern U.S. (MRPO and CENRAP) - Isle Royale National Park, MI; Seney National Wildlife Refuge, MI; Boundary Waters Canoe Area Wilder ness Area, MN; and Voyageurs National Park, MN

South Central U.S. (CENRAP) - Hercules-Glades Wilderness Area, MO; Mingo Wilderness Area, MO; Caney Creek Wilderness Area, AR ; and Upper Buffalo Wilderness Area, AR5 Class I areas outside the areas lis ted above were not analyzed fu rther, as there was no impact from Indiana sources shown. Further, no impacts from Indiana were noted in the WRAP states and no requests for controls were initiated by those states.

Indiana has participated in meetings and confer ence calls with states within the MRPO and the RPOs outside the Midwest to discuss their assessm ents of visibility c onditions, analyses of culpability, and possible measures that could be taken to meet visibility goals for 2018. The sections later in this document provide that information on a stat e-by-state basis. Table 1 shows the calls and meetings held with states a nd RPOs with Class 1 areas in which Indiana participated.

Table 1 Calls and Meetings Regarding Class 1 Areas Date Group March 12, 2007 Northern States (Michigan and Mi nnesota) call April 3, 2007 CENRAP call April 17, 2007 Northern States meeting April 25 - 26, 2007 Denver RPO - Federal Land Manager meeting May 11, 2007 CENRAP call May 17, 2007 Northern States call June 7, 2007 CENRAP call June 18, 2007 Northern States call July 10 - 11, 2007 MANE-VU Science meeting (covered by MRPO) July 19, 2007 MANE-VU call July 30, 2007 Northern States call August 6, 2007 MANE-VU meeting August 23, 2007 Northern States call February 7, 2008 Northern States call June 25, 2008 Northern States call

3.0 Indiana and Federal Land Manager Coordination

The provision at 40 CFR 51.308(i) requires coordination between Indiana and the Federal Land Managers (FLMs). Opportunities have been pr ovided by the MRPO for FLMs to review and comment on each of the technical documents devel oped by the MRPO and included in this SIP. Indiana has provided agency contacts to the FLMs as required. In developm ent of this plan, the FLMs were consulted in accordance with the provisions of 40 CFR 51.308(i)(2).

During the consultation process, the FLMs were gi ven the opportunity to address the following: · Assessment of the impairment of visibility in any Class 1 areas · Recommendations on the developm ent of reasonable progress goals · Recommendations on the development and implemen tation of strategies to address visibility impairment.

Indiana has consulted directly with the FLMs by email and phone, during periodic MRPO calls and meetings, at the FLM-RPO meeting in Denver on April 25 and 26, 2007, and during discussions with other states and RPOs with Cl ass 1 areas (for example, the MANE-VU meeting6 August 6, 2007 in Chicago). Indiana will provide the FLMs an opportunity for review of the SIP, at least 60 days prior to holding the public heari ng for the SIP. Comments received from the FLMs on this plan will be summarized and responses will be included in the final version.

Indiana will continue to coordina te and consult with the FLMs dur ing the development of future progress reports and plan revisi ons, as well as during the implem entation of programs having the potential to contribute to visibility impairment in the Class 1 areas. The FLMs will be consulted during the development and review of implementa tion plan revisions and during the review of 5- year progress reports

4.0 Development of Reasonable Progress Goals

The following maps show the locations of Class 1 areas in the central, eastern, and northeastern portions of the U.S. Modeling indicated that In diana sources had no measurable impact on Class I areas in the Western Regional Ai r Partnership (WRAP). Therefore, Class I areas in that region are not addressed in this SIP.

Figure 2 Map Showing Locations of South Central and Southeastern Class 1 Areas7 Figure 3 Map Showing Locations of Cl ass 1 Areas in Northeastern U.S.

Figure 4 Map Showing Locations of Class 1 Areas in Northern U.S.

Seney Boundary Waters

Canoe Area Isle Royale Voyageurs

4.1 Assessment of Baseline (or Current) Conditions and Estimate of Natural Conditions (in Class 1 Areas)

The RH Rule requires states with Class 1 areas to establish reasonable progress goals, expressed in deciviews (dv), for visibility improvement at each affected Class 1 area. The goals must provide for reasonable progress toward achievi ng natural visibility conditions, provide for8 improvement in visibility for the most impaired days over the period of the implementation plan, and ensure no degradation in visibility for the least impaired days over the same period, (40 CFR 51.308(d)(1)).

4.2 Glidepaths to Natural Conditions in 2064

The states and RPOs with Class 1 areas perf ormed their analyses to determine baseline conditions and natural conditions for 2064. The Regi onal Haze Rule directs states to graphically show what would be a "uniform rate of progress" toward natural conditions for each Class 1 area within their state, as well as Class 1 areas ou tside the state which may be affected by emissions from sources within the state. The uniform rate of progress is also known as the "glidepath." The glidepath is a straight line drawn from the baseline level of visibility impairment for 2000 - 2004 to the level representing no manmade impairment in 2064.

Glidepaths were developed by the states and RPOs for their own Class 1 areas using their available information. The MRPO also develope d glidepaths for the Class 1 areas impacted by states within the RPO. The glid epath is one of the indicators us ed in setting reasonable progress goals.

4.3 Letters Requesting Participation in Consul tation Process from States with Class 1 Areas

As a result of the various analyses performed by the MRPO and other RPOs, Indiana was invited to participate in a number of c onsultations regarding contributi ons to Class 1 areas. These include Arkansas, Missouri, Minnesota, and Mi chigan. Also included were New Jersey, New Hampshire, and Vermont - each individually and together as part of the MANE-VU letter. Copies of these letters are found in Appendix 2.

5.0 Emissions Inventory

A great deal of technical information must be assembled to determine the causes of impaired visibility in the Class 1 areas. Required in 40 CFR 51.308(d)(4)(v) is a statewide emissions inventory of pollutants that are reasonably anti cipated to cause or contribute to visibility impairment in any mandatory Class 1 area. Th e pollutants inventoried by Indiana for this purpose include volatile organic com pounds (VOCs), nitrogen oxides (NO x ), fine particulate (PM 2.5 ), coarse particulate (PM 10 ), and sulfur dioxide (SO 2 ). An inventory was developed for the baseline year 2005. In addition, projections of future emissions have been made for 2009 and 2018. Indiana will update this inventory on a periodi c basis, every three years. A summary of the inventory results follows; the comple te emission inventory is available at: http://www.ladco.org/tech/emis/current/. The foll owing information is taken from Section 3.6 of the MRPO document, “Regional Air Quality An alyses for Ozone, PM2.5, and Regional Haze: Final Technical Support Document, April 25, 2008, St ates of Illinois, Indi ana, Michigan, Ohio, and Wisconsin.” This document is available at the MRPO website: http://www.ladco.org/reports/technical_suppor t_document/tsd/tsd_version_iv_april_25_2008_fin al.pdf9 5.1 Base Year Emissions

Through coordination with the MRPO and other stat es, a base year inventory was prepared for regional modeling analysis. The states reviewed methodologies a nd assisted in the preparation of key segments of the emissions inventory that was eventually submitted to the MRPO. For on-road, nonroad, ammonia, and biogenic s ources, the 2005 emissions were estimated by models. For the other sector s, point sources, area sources , and MAR (commercial marine, aircraft, and railroads), the 2005 emissions were prepared using data supplied by the MRPO States and, for non-MRPO states , data developed by other RPOs . In particular, for the nonMRPO states, a contractor (Alp ine, with assistance from MACT EC) obtained the latest base (2002) and future year emission files (2009 and 2018) from the other RPOs. Specifically, the following versions of these emissions files were used here:

o MANE-VU: Version 3.1

o WRAP: Pre2002d

o CENRAP: Base F

o VISTAS: Base F

Emissions for 2005 were then estimated by li nearly interpolating between the 2002 and 2009 emissions. 2

Further discussion of the development of the 2005 base year emissions is provided below.

5.2 On-road Mobile

The CONsolidated Community Emissions Processing Tool (CONCEPT) 3 was run by a contractor (Environ) using tran sportation data (e.g., VMT and ve hicle speeds) supplied by the state and local planning agencies in the MRPO St ates and Minnesota for 24 networks. These data were first processed with T3 (Travel Demand Modeling [TDM] Transformation Tool) to provide input files for CONCEPT to cal culate link specific, hourly em ission estimates. CONCEPT was run with meteorological data for a July and January weekday, Saturday, and Sunday (July 15 – 17 and January 16 – 18). Spatial plots of emissi ons for July 15 are provided in the following figure.

2 Emissions Inventory Assistance: 2005 Base Year Biogen ic and Other (non-MRPO) State Emissions”, March 12, 2007

3 CONCEPT was developed as joint project between Alpine Geophysics, LLC and ENVIRON Corporation, with Midwest RPO and joint RPO funding, the CONCEPT model combines the best attributes of current emissions modeling systems into an open source model.10 Figure 5 July 15, 2005 Motor Vehicle Emissions for VOC and NO x (Tons Per Day)

For the non-MRPO states, CONCEPT was run by Environ using RPO-based HPMS county-level data (2002 and 2009) and MOBILE6 inputs (2002) compiled by anot her contractor for VISTAS. HPMS VMT for 2005 was generated by linearly interpolating between the 2002 and 2009 data. The 2002 MOBILE6 inputs were used for the 2005 m odeling, with a few adjustments (e.g., fuel sulfur content was set to 30 ppm, as requi red by the Tier 2/low sulfur regulations).

5.3 Nonroad Mobile

NMIM2005 4 was run by Grant Hetherington (Wisconsin Department of Natural Resources). The following are the NMIM2005 model runs prep ared for the emissions inventory.

o Phase 1: Run NMIM2005 for the MRPO states plus Minnesota plus Iowa and Missouri agriculture with Pechan ’s modifications only 5 . The Pechan modifications that were not incorporated in the default NMIM2005 inputs and need to be incorporated are BSFC emission factor data, Michigan population da ta, Missouri seasonality data and revised countynrfile, countyyear, count yyearmonth, datasource and gasoline NCD tables that assimilate fuel changes and file references.

o Phase 2: Run NMIM2005 for the MRPO states plus Minnesota plus Iowa and Missouri agriculture with Pech an’s modifications, revised 2005 MR PO gasoline parameters and a modified SCC table containing PM 2.5 corrections for diesel equipment.

o Phase 3: Run NMIM2005 for the MRPO states plus Minnesota plus Iowa and Missouri agriculture with P echan’s modifications, revised 2005 MRPO gasoline parameters, a

4 The National Mobile Inventory Model (NMIM) is a free, desktop computer application developed by EPA to help develop estimates of current and future emission inventories for on-road motor vehicles and nonroad equipment. NMIM uses current versions of MO BILE6 and NONROAD to calculate emi ssion inventories, based on multiple input scenarios entered into the system. NMIM is used to calculate national, state or county inventories.

5 “LADCO Nonroad Emissions Inventory Project – Development of Local Data for Construction and Agricultural Equipment”, Final Report, September 10, 200411 modified SCC table containing PM 2.5 corrections for diesel equipment and AIR's NONROAD.EXE. (Note: it is not cl ear if Phase 3 was used.)

Not all sectors of the nonroad inventory are calculated by NMIM2005 (i.e., commercial marine, aircraft, and railroads) and thos e were handled separately. Airc raft emissions were supplied by the states. Updated information for railroad s and commercial marine was prepared by a contractor (Environ). 6 For the non-MRPO states, Alpine de veloped appropriate emissions files based on data from the other RPOs, as noted above.

5.4 Area Sources

EMS (Emissions Modeling System) was run by the MRPO using 2005 data supplied by the MRPO states and, for the non-MRPO states, us ing emission files supplied by Alpine based on data from the other RPOs to produce weekday, Sa turday, and Sunday emissions for each month. Upon reviewing the data, further attention wa s given to two source categories, industrial adhesives and sealants and outdoor wood boilers, in order to provide updated emissions estimates. These activities are described below.

Industrial Adhesives and Sealants : The National Emissions Inventor y shows this to be a large VOC emissions category in the MRPO States (i.e.., 50,000 TPY). U.S. EPA subsequently determined that “(f)or the Region V states, we no longer believe that ther e are any activities in the Industrial Adhesives a nd Sealants category (SCC 2440020000) that have not been inventoried either in the point source Industrial Adhe sives and Sealants category or under the Consumer and Commercial Adhesives and Sealants nonpoint category (SCC 2460600000 - all adhesives and sealants).” Consequently, this category was omitted from the 2005 regional emissions inventory.

Outdoor Wood Boilers: Over the past several y ears, the installation and operation of outdoor wood boilers for residential use has increased dramatically in many northern states. Relying on an emission estimation methodology prepared by Bart Sponseller (Wisconsin Department of Natural Resources), emissions were calculate d by the other states for this category.

For the non-MRPO states, a contractor (Alpine, with assistance from MACTEC) estimated 2005 emissions by linearly interpolating between the 2002 and 2009 emissions developed by the other RPOs.

5.5 Point Sources – Electric Generating Units (EGUs)

EMS was run by the MRPO using 2005 data s upplied by the MRPO st ates and, for the nonMRPO states, using emission file s supplied by Alpine based on da ta from the other RPOs to produce weekday, Saturday, and Sunday emissions for each month.

The annual and summer season EGU emissions were temporalized for modeling purposes using profiles prepared by Scott Edick (Michigan Department of Environmental Quality) based on

6 “LADCO 2005 Locomotive Emissions”, Environ, February 2007, and “LADCO 2005 Commercial Marine Emissions”, Environ, March 2, 200712 CEM data for the period 2002 – 2005. Since the CE M data was the source of the emissions data, EGUs were removed from the general poi nt source files provided by the states.

5.6 Point Sources – Non-EGU

EMS was run by the MRPO using 2005 data s upplied by the MRPO st ates and, for the nonMRPO states, using emission file s supplied by Alpine based on da ta from the other RPOs, to produce weekday, Saturday, and Sunday emissions for each month.

5.7 Other Improvements

Canadian Emissions: Previous modeling inventorie s for Canadian sources were flawed due to problems with emissions (e.g., MRPO invent ories omitted ammonia emissions) or stack parameters (e.g., VISTAS inventories failed to in clude proper stack para meters, resulting in emissions getting dumped in the surface layer of the model). Scott Edick of the Michigan DEQ processed the 2005 Canadian National Pollutant Release Inventory (NPRI). Specifically, a subset of the NPRI data which is relevant to the air quality modeling was reformatted. Circle plots of point source emissions are presented in the following figures.

Figure 6 Base Year Emission Plots for Canada13 Figure 7 Base Year Emission Plots for Canada

Biogenic Emissions: A contractor (Alpine) provided an updated version of the CONCEPT/MEGAN 7 (Model of Emissions of Gases and Aerosols from Nature) biogenics model, which was used to produce base year biogenic emission estimates. Model improvements included: (a) reduced model run times, (b) impr oved ability to run successive days, and (c) enhanced meteorologi cal input processing 8

.
As a result of the model improvements and more recent data sets, there is more regional isoprene using MEGAN compared to the BIOME estimates us ed for Base K (see Figure 8). Also, with the secondary organic aerosol updates to the CAMx air quality model, Base M includes emissions for monoterpenes and sesquiterpen es, which are precursors of secondary PM 2.5 organic carbon mass.

7 See http://bai.acd.ucar.edu/Megan/

8 Subsequent to delivery of the updated CONCEPT/MEGAN model, it was found that more recent data sets and model formulations were available. Consequently, additional model improvements were undertaken. Compared to the initial updated model, the revised model reflects lower emissions for several organic aerosol species and NOx.14 Figure 8 Isoprene Emissions for Current Invent ory (left) v. Previous Inventory (right)

Ammonia Emissions: The CMU-based 2002 ammonia emissions were projected to 2005 using growth factors from the Round 4 emissions mode ling. These emissions were then adjusted by applying temporal factors by m onth based on the process-based ammonia emissions model. A plot of the average daily emissions by stat e and month is provided in Figure 9.

Figure 9 Average Daily Tonnage of Ammonia Emissions for Midwest States by Month (2005)

5.8 Future Year Emissions

Emission inventories were de veloped for two future years: 2009 and 2018. For on-road, nonroad, and EGU sources, the future year em issions were estimated by models (i.e., CONCEPT, NMIM2005, and IPM, respectively) a nd then processed by the MRPO with EMS.

For other sectors (area, commercial marine, aircra ft, and railroads, and non-EGU point sources) the future year emissions for the MRPO States were derived by applyi ng growth and control factors to the base year inventory. These fact ors were developed by a co ntractor (E.H. Pechan). 9 For the non-MRPO states, future year emission file s were supplied by Alpine based on data from the other RPOs.

9 “Development of 2005 Base Year Growth and Control Factors for Lake Michigan Air Directors Consortium”, Final Report, September 200715 Growth factors were based initially on EGAS (v ersion 5.0), and were subsequently modified (for select, priority categories) by examining emissions activity data. Control factors were prepared for the following ar ea, commercial marine, aircraft, railroad, and non-EGU point source existing (“on the books”) controls:

On-Highway Mobile Sources

o Tier II/low sulfur fuel

o Inspection/maintenance programs (nonattainment areas)

o Reformulated gasoline (nonattainment areas) Off-Highway Mobile Sources

o Federal control programs incorporated into NONROAD model (e.g., nonroad diesel rule), plus the evaporative Large Spark Ignition and Recreational Vehicle standards

o Heavy-duty diesel (2007) engine standard/low sulfur fuel

o Federal railroad/locomotive standards

o Federal commercial marine vessel engine standards Area Sources

o Consumer solvents

o AIM coatings

o Aerosol coatings

o Portable fuel containers

o Woodstoves

o Stage II Vapor Recovery Point Sources - EGUs

o Title IV (Phases I and II)

o NO x SIP Call

o Clean Air Interstate Rule (CAIR)

o Clean Air Mercury Rule Other Point Sources

o VOC 2-, 4-, 7-, and 10-year MACT standards

o Combustion turbine MACT

o Industrial boile r/process heater/RICE MACT

o Consent decrees (refineries, ethanol plants, and ALCOA) 10

o Other (Illinois and Ohio NO x RACT 11 , and BART in IN and WI)

o MACT 12

Further discussion of the development of the future year emissions is provided below:

On-road: Similar to the base year modeling, C ONCEPT was run using transportation data (e.g., VMT and vehicle speeds) supplied by the stat e and local planning agencies for 2009 and 2018. CONCEPT was only run with mete orological data for the July weekday. The emissions for

10 E.H. Pechan’s original control file included control fact ors for three sources in Wayne County, MI. These control factors were not applied in the regional-scale modeling to avoid double-counting with th e state’s local-scale analysis for PM 2.5 11 WI believes that NOx RACT for their sources is al ready included in the 2005 basecase and EGU “will do” scenario, and IN provided NOx RACT information for inclusion as a non-EGU “may do” scenario.

12 E.H. Pechan’s original control file included EPA-defau lt control factor information. Alternative control factors were developed by Wisconsin for a few MACT categories, and were also applied to the other four MRPO States.16 Saturday and Sunday were derived by using sc aling factors based on the 2005 emissions. The state-level emissions for the five MRPO States plus Minnesota are summarized in the following table 13

. Table 2 Summary of On-road Emissions (Tons Per Day – July 15, 2005)

Year State CO VOC NO x PM 2.5 SO 2 NH3 Sum of VMT
2005 IL 3,684 342 748 13 10 36 344,087,820
IN 3,385 282 541 9 11 26 245,537,232
MI 4,210 352 722 12 14 35 340,834,026
MN 2,569 219 381 6 8 18 170,024,600 OH 6,113 680 934 16 19 37 360,521,069
WI 2,206 175 458 8 9 20 189,123,964
Total 22,168 2,049 3,783 65 70 171 1,650,128,710
2009 IL 2,824 268 528 10 4 39 372,132,591
IN 2,840 235 402 7 3 26 249,817,026
MI 3,172 269 501 9 4 37 356,347,011
MN 2,257 206 308 5 2 22 204,443,018 OH 4,619 424 694 12 5 40 387,428,127
WI 1,673 119 322 6 2 21 197,729,965
Total 17,385 1,522 2,754 49 20 184 1,767,897,738
2018 IL 2,085 152 201 6 4 43 413,887,887
IN 2,217 138 173 4 3 30 288,042,232
MI 2,434 164 204 6 4 41 388,128,432
MN 1,800 123 137 4 2 25 237,022,214 OH 3,362 243 274 7 4 43 421,694,093
WI 1,256 68 139 4 2 22 218,277,168
Total 13,153 888 1,128 31 18 204 1,967,052,026

For the non-MRPO states, CONCEPT was run by Environ using HPMS county-level data and MOBILE6 inputs compiled by another contractor for VISTAS. The emissions modeling for Iowa, Missouri, and Oklahoma was redone for 2009 to reflect the state- developed registration distribution data. (The initial modeling for 2009 used national default values for registration distribution assumed by VISTAS’ contractor. CENRAP’s contractor developed emissions inventories for 2002 and 2018 using the state de veloped data. For c onsistency, Environ’s remodeling for these three states for 2009 also used the state-developed data.) Off-road: Similar to the base year inve ntory, NMIM2005 was run by Grant Hetherington (Wisconsin Department of Natural Resources ) to produce the future year inventories, with updated growth factors by E.H. Pechan.

Point Source - EGU: Future year emissions were based on U.S. EPA’s IPM3.0 modeling. Three CAIR scenarios were addressed:

13 For northeastern IL (CATS region), 2009 and 2018 emissions were increased by 9% and 8%, respectively, to reflect newer transportation modeling by CATS.17  5a: U.S. EPA’s IPM3.0 was assumed as the future year base for EGUs.

 5b: U.S. EPA’s IPM3.0, with several “will do” adjustments identified by the States. These adjustments should reflect a legally binding commitment (e.g., signed contract, consent decree, or operating permit).

 5c: U.S. EPA’s IPM3.0, with several “may do” adjustments identified by the States. These adjustments reflect less rigorous criter ia, but should still be some type of public reality (e.g., BART determinati on or press announcement).

The following table summarizes the SO 2 and NO x emissions for the three scenarios. The net effect is a small change (increase) in regional SO 2 and NO x emissions.

Table 3 EGU Emissions for Base (5a), Will Do (5b), and May Do (5c) Scenarios 2010 (Tons per Day) 2018 (Tons per Day) SO 2 5a 5b 5c 5a 5b 5c IL 958 881 881 869 433 433 IN 1033 1318 1318 1036 1194 1194 MI 667 667 667 725 725 725 OH 1326 1410 1410 983 1127 1127 WI 460 460 421 435 499 235 Total 4444 4736 4697 4048 3978 3714 MN 162 148 148 187 167 157

NO x 5a 5b 5c 5a 5b 5c IL 275 247 247 224 195 195 IN 370 372 372 255 266 266 MI 242 242 242 243 243 243 OH 281 305 305 285 310 310 WI 165 164 155 176 172 145 Total 1333 1330 1321 1183 1186 1159 MN 116 142 142 132 157 12518 Table 4 Emissions Summaries

VOC NO x SO 2 PM 2.5 July 2005 2009 2018 2005 2009 2018 2005 2009 2018 2005 2009 2018

Nonroad

IL 321 257 213 333 275 155 33 5 0 30 24 14

IN 195 160 128 191 158 89 19 3 0 17 13 7

MI 414 350 271 239 197 112 22 3 0 22 18 11

OH 356 294 238 304 246 135 29 5 0 27 22 13

WI 238 203 157 157 129 77 15 2 0 14 12 7 5-StateTotal 1,524 1,264 1,007 1,224 1,005 568 118 18 2 110 89 52 Commercial marine, aircraft, and railroad

IL 11 10 6 246 228 165 22 19 17 7 6 4

IN 5 5 3 93 87 65 8 7 6 2 2 2

MI 7 7 7 87 82 65 21 14 8 3 3 2

OH 7 7 5 134 126 94 14 12 10 4 4 2

WI 4 4 3 58 54 41 8 6 5 2 2 1

5-StateTotal 34 33 24 618 577 430 73 58 46 18 17 11

Other Area

IL 675 594 582 48 48 49 11 16 16 40 64 69

IN 391 358 384 56 58 59 32 32 32 2 2 2

MI 652 562 549 49 50 51 29 29 28 111 114 120

OH 604 506 487 93 108 108 6 15 14 19 35 34

WI 315 290 293 37 37 37 17 13 13 11 12 12 5-StateTotal 2,637 2,310 2,295 283 301 304 95 105 103 183 227 237

On-Road

IL 341 268 151 748 528 201 9 4 3 13 10 6

IN 282 235 138 541 402 173 11 3 2 9 7 2

MI 351 269 163 722 501 204 14 4 3 12 9 3

OH 680 424 242 934 693 274 18 4 4 16 12 4

WI 175 119 68 457 322 138 9 2 2 8 6 2 5-StateTotal 1,829 1,315 762 3,402 2,446 990 61 17 14 58 44 17

EGU
IL 7 6 7 305 275 224 1,158 958 869 13 34 77
IN 6 6 6 393 370 255 2,614 1,033 1,036 16 73 74
MI 6 4 4 393 242 243 1,251 667 725 15 25 29 OH 4 5 6 408 280 285 3,405 1,326 983 28 94 80

WI 5 2 3 213 165 177 545 460 435 - 22 25 5-StateTotal 28 23 26 1,712 1,332 1,184 8,973 4,444 4,048 72 248 285

Non-EGU

IL 221 218 258 330 218 235 423 335 346 16 17 19

IN 130 137 167 179 175 178 218 216 180 35 36 44

MI 116 119 140 240 242 271 158 148 163 20 21 25

OH 84 87 104 175 166 178 289 288 293 27 28 33

WI 84 87 106 97 93 81 156 152 85 - 0 0 5-StateTotal 635 648 775 1,021 894 943 1,244 1,139 1,067 98 102 121

Total
IL 1,576 1,353 1,217 2,010 1,572 1,029 1,656 1,337 1,251 119 155 189
IN 1,009 901 826 1,453 1,250 819 2,902 1,294 1,256 81 133 131
MI 1,546 1,311 1,134 1,730 1,314 946 1,495 865 927 183 190 190 OH 1,735 1,323 1,082 2,048 1,619 1,074 3,761 1,650 1,304 121 195 16619 VOC NO x SO 2 PM 2.5 July 2005 2009 2018 2005 2009 2018 2005 2009 2018 2005 2009 2018
WI 821 705 630 1,019 800 551 750 563 540 35 54 47 5-StateTotal 6,687 5,593 4,889 8,260 6,555 4,419 10,564 5,781 5,280 539 727 723

6.0 Modeling Assessment

Provided in 40 CFR Part 51, Appendix W are guide lines for conducting regional-scale modeling to simulate pollutants impairing visibility. The U.S. EP A recommends the use of one of three models and the MRPO chose the Comprehensive Air Qu ality Model with extensions (CAMx).

The air quality analysis conducted by the MRPO includes weight of evidence approaches which rely on extensive data analysis and modeling. Given uncerta inties in emissions inve ntories and modeling, these data analyses are a necessary part of the overall technical support.

Modeling includes base year analys es for 2005 to evaluate model performance and strategy analyses to assess candidate control strategies. The analyses were conducted in accordance with the U.S. EPA’s “Guidance on the Use of Models and Other Analys es for Demonstrating Atta inment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze”, EPA-454/B-07-002, April 2007 (Modeling Guidance). The regional haze modeling covers the full calendar year of 2005 for the eastern U.S. and uses 36 kilometer meteorology and modeling domains using CAMx.

The Clean Air Act sets as a national goal, “the prevention of any future, and the remedying of any existing, impairment of visibility in Class 1 ar eas which impairment results from manmade air pollution” 14 for regional haze. In the 5-state MRPO re gion, there are two Class 1 areas: Isle Royale National Park, MI and Seney National Wildlife Refuge , MI. The U.S. EPA visibility rules (64 FR 35714, July 1, 1999) require reasonable progress towa rd achieving “natural conditions” by the year 2064. Table 5 lists the areas that were modeled.

Table 5 Class 1 Areas Modeled by the MRPO Class 1 Area Identifier State Acadia National Park ACAD1 Maine Boundary Waters Canoe Area Wilderness Area BOWA1 Minnesota Brigantine Wilderness Area BRIG1 New Jersey Caney Creek Wilderness Area CACR1 Arkansas Dolly Sods Wilderness Area DOSO1 West Virginia Hercules-Glades Wilderness Area HEGL1 Missouri Isle Royale National Park ISLE1 Michigan James River Face Wilderness Area JARI1 Virginia Lye Brook Wilderness Area LYBR1 Vermont Mammoth Cave National Park MACA1 Kentucky Mingo Wilderness Area MING1 Missouri Seney National Wildlife Refuge SENE1 Michigan Shenandoah National Park SHEN1 Virginia

14 Section 169A of the Clean Air Act20 Class 1 Area Identifier State Upper Buffalo Wilderness Area UPBU1 Arkansas Voyageurs National Pa rk VOYA2 Minnesota

The primary source of modeling used in this document is from "R egional Air Quality Analyses for Ozone, PM 2.5 and Regional Haze: Technical Support Document", April 25, 2008, States of Illinois, Indiana, Michigan, Ohio, and Wisconsin.

6.1 Regional Haze/Visibility

The components of the visibility equation match up very closely to the prominent chemical forms of PM 2.5 : nitrate ion, sulfate ion, ammonium ion, orga nic carbon, elemental carbon, and soil (U.S. EPA, 2007). Since these modeling applications will support PM 2.5 and Regional Haze rules, model performance will be most rigorous for each of these PM 2.5 species and coarse mass.

One of the problems related to PM model perfor mance evaluation involves matching inconsistent monitor methodologies and model specie definition. Additionally, speciated measurements rarely add up to measurements of total fine mass. This unexplaine d fraction is usually attri buted to the retention of water on the weighed samples (Timin, 2002). Other problems with comparing speciation samples and Federal Reference Method (FRM) measurements in clude volatilization of nitrate and positive and negative organic carbon ar tifacts (Timin, 2002).

Organic material is typically estim ated from organic carbon using a factor of 1.4, which is based on the assumption that carbon accounts for 70% of the organi c mass. Recent literature recommends a factor of 1.6 ± 0.2 for urban aerosol and 2.1 ± 0.2 for non-urban ar eas that see more aged aerosols (Turpin and Lim, 2001; “Interagency Monitori ng of Protected Visual Envir onments (IMPROVE)”, 2006). These factors are applied to ob servation data based on land use type be fore being compared to model output. These factors may also be used to reduce modeled estimates of organic material to organic carbon.

Performance metrics used to de scribe model performance for PM 2.5 species include mean bias, gross error, fractional bias, and fractional error (U.S. EP A, 2007). The bias and error metrics are used to describe performance in terms of the measured concentration units ( μ g/m3). Even though the distribution of PM 2.5 is log-normal, the data is not transformed for this anal ysis. The mode l attainment tests outlined by U.S. EPA for the PM 2.5 National Ambient Air Qualit y Standards (NAAQS) and RH Rule require relative res ponse factors to be applied to actual concentrations and not transformed concentrations. No minimum value is used to elim inate data points for the purposes of this analysis.

6.2 Attainment Tests for Regional Haze/Visibility

Visibility may be estimated by two similar meth ods that relate light extinction to ambient PM 2.5 concentrations (FLAG, 2000; U.S. EPA, 2007). Vi sibility will be estimated using the new equation recommended by the IMPROVE steering committee (IMPROVE, 2006). The new and old equations produce very similar estimates of light extinction in the upper Midwest. The new equation will be emphasized for the SIP modeling demonstrati on due to its more up-to-date science.21 The equation shown below relates PM 2.5 specie concentrations to light extinction. Additional factors of relative humidity adjustment factor (fRH) are included that change the light sc attering of sulfate and nitrate based on climatologically averaged relative humidity.

β ext = 2.2*fSRH*[small sulfate] + 2.4*fS(R H)*[small nitrate] + 4.8*fLRH*[large su lfate] + 5.1*fL(RH)*[large nitrate]+ 2.8*[small OCM] + 6.1*[large OCM] + 10*E C + 1*SOIL + 0.6*CM + 1.7*fSS(RH)*SS + β rayleigh

β ext - Estimated extinction coefficient (Mm-1) Sulfate - Sulfate associated with ammonium (SO4*1.375) Nitrate - Nitrate associated with ammonium (NO3*1.29) OCM - Organic carbon Mass EC - Elemental carbon SOIL - Inorganic primary PM 2.5 (soil, crustal, other) CM - Coarse fraction particulate matter SS - Sea salt β rayleigh Light scattering due to Rayleigh scattering (site specific) fRH - Relative humidity adjustment factor

The apportionment of sulfate, nitrate, and organic carbon mass into small and large size fractions is shown below using ‘X’ as a pl aceholder for these species.

Large X = ([Total X] / [20 μg/m3]) * [Total X], where [Total X] < 20 μg/m3 Large X = [Total X], where [Total X] ≥ 20 μg/m3 Small X = [Total X] – [Large X]

The fRH values are long-term averag es that are site and month spec ific (U.S. EPA, 2003a; U.S. EPA 2003b; FLAG, 2000). The light scat tering due to Rayleigh is site specific (IMPROVE, 2006). The NO 2 component to the light extinction equation is not include d since it is not measured at Class 1 areas in the upper Midwest. The visibility equation is expressed as an extinction coefficient ( β ext) and is converted to deciviews using the equation below.

Deciview = 10ln( β ext/ β rayleigh)

The reasonable progress test to dete rmine the relationship between current and future year visibility is expressed in deciview units. The ch anges in deciviews between the curre nt and future year strategy is the reasonable progress test and is shown below.

Change in Deciview = 10ln[( β ext)future / ( β ext)base]

- or - Change in Deciview = Deciviewbase – Deciviewfuture

Visibility will be estimated for key Class 1 areas in the Midwest for the base year and various future year scenarios. The changes in vi sibility between the baseline and fu ture year will be assessed using procedures in U.S. EPA’s modeling guidance document (U.S. EPA, 2007).

1. The visibility in deciviews (dv) will be ranke d from high to low at each Class 1 area for the calendar years 2000-2004 using the monthly and s ite specific fRH values and the more recent IMPROVE light extinction equation. 2. The mean dv for the 20% days with the best an d the 20% days with the worst visibility are estimated for each Class 1 area for each year of the 2000-2004 baseline period.22 3. The mean observed extinction coefficient for th e days during the modeling period (2005) with the 20% best and 20% worst visibility will be calculated. 4. The mean predicted extinction coefficient for th e corresponding 20% best and 20% worst days of the modeling period of the base case and future year strategy will be calculated using monthly site specific fRH values. 5. The relative response factor for the 20% best an d 20% worst group of days for each site for each of the particulate matter species in the light extinction equation is estimated. 6. The relative response factors are multiplied by daily measured PM data during the 2000-2004 baseline to estimate future daily values of these species. 7. These future daily PM estimates are used to estim ate light extinction for each of the previously identified 20% best and 20% worst days of mon itored data. Light extinction is converted to dv and the mean value for the best and worst days fo r each year of the baseline period is estimated. 8. The 5 mean dv values for the wors t and best days (one from each of the 5 years) are averaged together for a mean value for the best and worst days. 9. The future year mean dv values in step 8 are compared to the observed values from step 2. The differences are compared to established goals fo r reasonable progress to determine if reasonable progress is demonstrated.

6.3 Regional Haze Modeling Results

For regional haze, the calculation of future year conditions assumed: (a) baseline concentrations based on 2000-2004 IMPROVE data, with updated (substituted) data for Mingo, Boundary Waters, Voyageurs, Isle Royale, and Sene y (see “Impact of Missing Data on Worst Days at Midwest Northern Class 1 Areas”, March 12, 2007 (revised 6/19/07)), (b) use of the new IMPROVE light extinction equation, and (c) use of U.S. EPA default values for natural conditions, based on the new IMPROVE light extinction equation.

Pursuant to the RH Rule, states mu st consider several factors in es tablishing reasonable progress goals for their Class 1 areas, including the uniform rate of visibility improvement. The uniform rate of visibility improvement values for the 2018 planning y ear were derived (for the 20% worst visibility days) based on a straight line betw een the baseline concentration va lue (plotted in the year 2004, end year of the 5-year baseline period) and the natural condition value (plotted in the year 2064, the date for achieving natural conditions). Plots of these “glidepaths” for Class 1 areas in the eastern U.S. showing the worst 20% days and best 20% days are presente d in Figure 10. A tabular summary of measured baseline and modeled future year dv values for these Class 1 areas are provided in Tables 6 and 7. This information was taken from the MRPO Technical Support Document (TSD). Data for Smoky Mountains and Sipsey were not included in that report. Caney Cr eek was not plotted in the MRPO TSD. These are addressed individually in later portions of this section.

The haze results show that several Class 1 areas in th e eastern U.S. are expected to be greater than the uniform rate of visibility improvement values (in 2018), including those in northern Michigan and several in the northeastern U.S. Many other Class 1 area s in the eastern U.S. are expected to be less than the uniform rate of visibility improvement values (in 2018).23 Figure 10 Visibility Modeling Results for Class 1 Areas in Eastern U.S. Voyageurs Boundary Waters Isle Royale

Seney Mammoth Cave Upper Buffalo

Mingo Shenandoah Dolly Sods

Brigantine Lye Brook Acadia24 Table 6 Visibility Modeling Result s (Deciviews) for Class 1 Areas in Eastern U.S. (Worst 20%)

Site 2000-2004 Baseline 2018 URP 2009 OTB 2009 OTB+Will Do 2012 OTB 2018 OTB 2018 OTB+Will Do Boundary Waters 19.86 17.94 18.45 18.51 18.33 17.94 17.92 Voyageurs 19.48 17.75 18.2 18.28 18.07 17.63 17.66 Seney 24.38 21.64 23.1 23.1 23.04 22.59 22.42 Isle Royale 1 21.59 19.43 20.52 20.58 20.43 20.09 20.13 Isle Royale 9 21.59 19.43 20.33 20.37 20.22 19.84 19.82
Hercules-Glades 26.75 23.13 24.72 24.82 24.69 24.22 24.17 Mingo 28.15 24.27 25.88 26.13 25.68 24.74 24.83 Caney Creek 26.36 22.91 23.39 23.55 23.29 22.44 22.4 Upper Buffalo 26.27 22.82 23.34 23.47 23.27 22.59 22.55
Mammoth Cave 31.37 26.64 27.11 27.41 27.01 26.1 26.15 Dolly Sods 29.05 24.69 24 24.06 23.9 23 23.04
Shenandoah 29.31 25.12 24.99 25.04 24.87 23.92 23.95
James River Face 29.12 24.91 25.17 25.25 25.01 24.06 24.12 Brigantine 29.01 25.05 25.79 25.83 25.72 25.21 25.22 Lye Brook 24.45 21.48 22.04 22.08 21.86 21.14 21.14
Acadia 22.89 20.45 21.72 21.75 21.72 21.49 21.49

Table 7 Visibility Modeling Results (Deciviews) for Class 1 Areas in Eastern U.S. (Best 20%)

Site 2000-2004 Baseline 2018 URP 2009 OTB 2009 OTB+Will Do 2012 OTB 2018 OTB 2018 OTB+Will Do Boundary Waters 6.42 6.42 6.21 6.2 6.19 6.14 6.12 Voyageurs 7.09 7.09 6.86 6.89 6.83 6.75 6.76 Seney 7.14 7.14 7.57 7.59 7.58 7.71 7.78 Isle Royale 1 6.75 6.75 6.62 6.64 6.59 6.6 6.62 Isle Royale 9 6.75 6.75 6.56 6.57 6.55 6.52 6.5
Hercules-Glades 12.84 12.84 12.51 12.56 12.32 11.66 11.64 Mingo 14.46 14.46 14.07 14.13 13.89 13.28 13.29 Caney Creek 11.24 11.24 10.88 10.95 10.85 10.52 10.52 Upper Buffalo 11.71 11.71 11.13 11.19 11.08 10.73 10.74
Mammoth Cave 16.51 16.51 15.76 15.88 15.69 15.25 15.25 Dolly Sods 12.28 12.28 11. 25 11.29 11.23 11 11.01
Shenandoah 10.93 10.93 10.13 10.16 10.11 9.91 9.91
James River Face 14.21 14.21 13.38 13.43 13.38 13.14 13.14 Brigantine 14.33 14.33 14.15 14.16 14.08 13.92 13.92 Lye Brook 6.37 6.37 6.25 6.28 6.23 6.14 6.15
Acadia 8.78 8.78 8.86 8.88 8.86 8.82 8.82

URP - uniform rate of progress OTB - on-the-books controls OTB+Will Do - on-the-books controls plus adjust ments for controls from states commitments25 7.0 Reasonable Progress Goals

7.1 Background

IDEM assessed each of the Class 1 areas identified in the MRPO report as being impacted by Indiana sources. Information provided by the MRPO, techni cal documents from the other RPOs, and letters received from other states indicat ing their decisions regarding reas onable further progress goals were used to make these assessments.

In determining reasonable progress for regional haze, Section 169 of the Clean Air Act and U.S. EPA’s visibility rule requires states to consider five factors:

 Costs of compliance

 Time necessary for compliance

 Energy and non-air quality environm ental impacts of compliance

 Remaining useful life of any existing source subject to such requirements

 Uniform rate of visibility improvement (needed to attain natural visibility conditions by 2064)

Since Indiana has no Class 1 areas, th e states with Class 1 areas took th e lead in establishing reasonable progress goals. Indiana participated in the discussions and provided info rmation to assist in setting the goals. The states developing the plans addressed th e four factors and developed the uniform rate of progress glidepaths.

In the following sections, these analyses are summarize d. A detailed analysis of each area is included in the appendices. In the previous section, MRPO modeling was used to identify areas possibly impacted by Indiana sources. In Sections 7.3 through 7.7, VI STAS modeling results are used to provide additional evidence regarding progress in achieving visibility improvements.

7.2 Voyageurs National Park and Boundary Waters Canoe Area Wilderness Area

Indiana sources have shown an impact on these Cl ass 1 areas through modeling studies. Minnesota has determined that several other states are significant c ontributors to visibility impa irment in these areas at this time and is working with them as th ey develop their reasona ble progress goals.

The cover letter from the Minnesota Pollution Cont rol Agency contains their reasonable progress analysis and can be found in Appendix 3. Indiana ha s participated in the consultation calls and the MRPO modeling process used by Minnesota to reach their conclusions.

As can be seen in the map in the Minnesota letter in Appendix 3, page 3-7, Indian a is barely in the Areas of Influence that impact their Class 1 areas. Minn esota has developed a long term strategy sufficient to meet their 2018 reasonable progress goals, and has not requested additional assistance from Indiana. Further, reductions for Indiana BART sources (a nd other states) resulting from new settlements, committed controls, current controls, and the propos ed Transport Rule will be greater than those anticipated during the earlier mode ling studies. Table 10 contains a table showing these projections. While specific modeling results will not be available for some time, it follows that Indiana’s influence will be further reduced.26 Indiana concurs that this is the best approach fo r addressing visibility impa irment at Voyageurs and Boundary Waters Class 1 areas at this time. Theref ore, no further analysis for this SIP is necessary.

7.3 Mammoth Cave National Park

Indiana sources have shown an impact on this Cl ass 1 area through modeling st udies. However, since sources in Kentucky and Indiana must comply with Cl ean Air Interstate Rule (CAIR) requirements, the Kentucky analysis has determined that these controls are sufficient to address visibility in this area. Further, VISTAS modeling has shown that Mammoth Ca ve is more than meeting its uniform rate of progress (glidepath) and has determined that no addi tional reductions are needed from Indiana at this time.

The cover letter from the Kentucky Department for E nvironmental Protection contains this information, Appendix 3, page 3-25. The result s of the long term strategy de veloped by Kentucky and VISTAS provide anticipated visibility improvements below th e glidepath, as can be seen in following figure.

Figure 11 Mammoth Cave Uniform Rate of Progress Glidepath

Analyses performed by the MRPO show similar result s. Indiana concurs that this approach is an effective means of addressing visibility impairment at Mammoth. In addition, an Indiana source, Alcoa, was determined to significantly impact this area and is the subject of the Indiana BART rule. This is covered in Section 8.27 7.4 Great Smoky Mountains National Park

In the MRPO summary of Class 1 areas impacted by sources from within the MRPO (Appendix 1), Indiana was determined to contribut e to visibility impairment in this Class 1 area. Since that time, VISTAS has conducted several analyses to assist in developing reasona ble progress goals. The following figure shows that the l ong term strategy developed for this Class 1 area easily meets the glidepath through 2018.

Figure 12 Great Smoky Mountains Unif orm Rate of Progress Glidepath

In the "Technical Analyses Supporting Regional H aze State Implementation Plan," June 8, 2007, North Carolina Department of Environment and Natural Res ources stated that contri butions from other RPOs are comparatively small and the greatest benefits would likely be from further EGU reductions within the VISTAS states. Indiana was not contacted by Tennessee or Nort h Carolina regarding consultations for this area and believes that no fu rther analysis for a long term cont rol strategy is necessary at this time.

7.5 Sipsey Wilderness Area

In the MRPO summary of Class 1 areas impacted by sources from within the MRPO (Appendix 1), Indiana was determined to contribut e to visibility impairment in this Class 1 area. Since that time, VISTAS conducted several analyses to assist in developing reasona ble progress goals. The following figure shows that the long term strategy for this Class 1 area meets the glidepath through 2018.28 Figure 13 Sipsey Uniform Ra te of Progress Glidepath

Indiana has not been contacted by Alabama regardi ng consultations for this area and believes that no further analysis for a long term contro l strategy is necessary at this time.

7.6 James River Face Wilderness Area, Shenandoah National Park, Dolly Sods/Otter Creek Wilderness Areas

In the MRPO summary of Class 1 areas impacted by sources from within the MRPO (Appendix 1), Indiana was determined to contribute to visibility impairment in these more distant Class 1 areas. Since that time, VISTAS has conducted seve ral analyses to assist in devel oping reasonable progress goals. The results of the long term strategy developed by th e states and VISTAS provide anticipated visibility improvements below the glidepath. Figures 14, 15, a nd 16 show the glidepaths for each of these areas.29 Figure 14 James River Face Uniform Rate of Progress Glidepath

Figure 15 Shenandoah Uniform Rate of Progress Glidepath30 Figure 16 Dolly Sods Uniform Rate of Progress Glidepath

Neither Virginia nor West Virginia contacted IDEM to participate in consultations for these areas. The four factor analyses performed by the VISTAS states and resulting long term st rategies indicate that controls closer to the Class 1 area s provide the most effective reductions at this time. Additionally, the long term strategies provide antici pated visibility improvements below the glidepaths. Indiana concurs with these conclusions.

7.7 Caney Creek and Upper Buffalo Wilderness Areas, AR, and Hercules-Glades and Mingo Wilderness Areas, MO

These areas were identified in ea rly MRPO modeling and other analys es as being impacted by Indiana sources. Indiana was invited to participate in the consultation process for th ese areas, and attended the conference phone calls. Arkansas and Missouri notified IDEM that they consider the consultation process finished. They have developed long term st rategies that meet Rate of Progress Goals by 2018. Further, Southwestern Indiana was included in the area of influence which impacts these areas (Appendix 3, page 52). The contro ls in existence in the 2002 invent ory, those installed after 2002, and controls planned out to 2018, were analyzed. A larg e majority of these sour ces will be controlled by 2018, which will further aid in the progress toward their reasonable progress goals.

Figures 17 - 20 show glidepaths resulting from the long term strategies develope d by the states. All the Class 1 areas are projected to meet th eir reasonable progre ss goals in 2018.

At this time, they have concluded that no reductions are necessary from Indiana. The letter providing this information is in Appendix 3, page 45.31 Figure 17 Caney Uniform Rate of Progress Glidepath

Uniform Rate of Reasonable Progress Glide Path Caney Creek Wilderness - 20% Data Days

26.36 25.38

22.91

20.45

17.99

15.52

13.06

11.58 21.48

0 5 10 15 20 25 30

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

Year H a z i n e s s I n d e x ( D e c i v i e w s )

Glide Path Natural Condition (Worst Days) Observation Method 1 Prediction

Figure 18 Upper Buffalo Uniform Rate of Progress Glidepath

Uniform Rate of Reasonable Progress Glide Path Upper Buffalo Wilderness - 20% Data Days

26.27 25.29

22.84

20.39

17.94

15.49

13.04

11.57 21.61

0 5 10 15 20 25 30

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

Year H a z i n e s s I n d e x ( D e c i v i e w s )

Glide Path Natural Condition (Worst Days) Observation Method 1 Prediction32 Figure 19 Hercules-Glades Uniform Rate of Progress Glidepath

Uniform Rate of Reasonable Progress Glide Path

Hercules-Glades Wilderness - 20% Data Days

26.75 25.72

23.14

20.57

17.99

15.42

12.84

11.30 22.19

0 5 10 15 20 25 30

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

Year H a z i n e s s I n d e x ( D e c i v i e w s )

Glide Path Natural Condition (Worst Days) Observation Method 1 Prediction

Figure 20 Mingo Uniform Rate of Progress Glidepath

Uniform Rate of Reasonable Progress Glide Path Mingo - 20% Data Days

28.02 26.98

24.37

21.77

19.17

16.56

13.96
12.40 23.21

0 5 10 15 20 25 30 35

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

Year H a z i n e s s I n d e x ( D e c i v i e w s )

Glide Path Natural Condition (Worst Days) Observation Method 1 Prediction

7.8 Isle Royale National Park and Sene y National Wildlife Refuge, MI

Indiana sources have shown an impact on these Cl ass 1 areas through modeling studies. Indiana and the other Midwestern states participated extensively in the MRPO modeling and da ta analysis efforts for fine particulates, ozone, and haze in these areas. Michigan determined that existing and on-the-books33 controls (those controls scheduled in response to regulatory actions w ithin this time period), combined with reductions necessary to meet the new 24-hour fine particulates standard and possibly the new ozone standard will be sufficient to m eet their reasonable progress goals. The letter from the Michigan Department of Ai r Quality, Appendix 3, page 3-56, contains their conclusions. Indiana concurs that th is is the best approach for addres sing visibility impairment at Isle Royale National Park and Seney National Wildlife Ref uge Class 1 areas at this time. Therefore, no further analysis for this SIP is necessary. Indian a will continue to work with Michigan through the MRPO to evaluate the progress in the Class 1 areas.

7.9 Acadia National Park, ME, Moosehorn W ilderness Area, ME, G reat Gulf Wilderness Area, NH, Brigantine Wilderness Area, NJ, a nd Lye Brook Wilderness Area, VT (MANE-VU)

Indiana sources have shown an impact on thes e Class 1 areas through the MRPO and MANE-VU modeling projects. Indiana, along w ith the other MRPO states, has par ticipated in consultations with MANE-VU.

MANE-VU released “Assessment of Reasonable Progress for Regional Haze in MANE-VU Class 1 Areas - Methodology for Source Selection, Evaluation of Control Options, and Four Factor Analysis, July 2007” which supported requests of st ates outside that area to examin e controls for specific types of sources. This assessment is a large document and is not included in this submittal. It is available online at the MANE-VU website, http://www.manevu.or g, under “Consultations - Projects and Work Products.” The resulting request is referred to as the “MANE-VU Ask”.

MANE-VU Ask: In its “Statement of the Mid-At lantic/Northeast Visibi lity Union (MANE-VU) Concerning a Request for a Course of Action by States Outside of MANE-VU Toward Assuring Reasonable Progress” (June 20, 2007) , Appendix 3, pages 64 - 65, MANE-VU suggested that several control strategies should be pursu ed for adoption and implementation 15 , including:

 Application of Best Ava ilable Retrofit Technology

 90% (or greater) reduction in SO 2 emissions from each of the EGU stacks on MANE-VU’s list of 167 stacks (located in 19 stat es), which reflect those stacks determined to be reasonably anticipated to cause or contri bute to visibility impairment in the MANE-VU Class 1 areas

 28% reduction in non-EGU (point, area, on-road, and off-road) SO 2 emissions relative to on-thebooks and on-the-way 2018 projections

 Continued evaluation of other measur es, including measures to reduce SO 2 and NO x emissions from coal-burning facilities a nd promulgation of new source performance standards for wood combustion

 Further reduction in power plant SO 2 (and NO x ) emissions beyond the current Clean Air Interstate Rule program

Of the 167 stacks, 15 are from 9 sources in Indiana (A ppendix 3, page 63). Most of these stacks have or will have post-combustion emission controls (i.e., sc rubbers). A list of these sources, along with the control information is in Table 10.

15 The June 20 statement was transmitted to the MRPO States in letters dated July 30 from Anna Garcia, acting Executive Director, MANE-VU.34 The two sets of charts from MRPO "Round 5" modeling show the culp ability of geogr aphic areas to visibility conditions in two Class 1 areas in the northeast. The left charts are the best days, the right charts are the worst days.

Figure 21 Acadia Visibility Impact Modeling

Figure 22 Lye Brook Visibility Impact Modeling

These charts demonstrate that Indiana sources have insignificant impacts on these areas.

The MRPO conducted modeling to evalua te the various levels of contro ls in place or planned between 2008 and 2018. From this "Round 5" modeling, Table 8 was produced for MANE-VU Class 1 areas.35 Table 8 MRPO Round 5 Modeling Results (dv)

Best 20% Baseline 2018 2009 2009 2012 2018 2018
Site 2000-2004 URP Value Base Will Do Base Base Will Do Brigantine 14.33 14.33 14. 15 14.16 14.08 13.92 13.92 Lye Brook 6.37 6.37 6.25 6.28 6.23 6.14 6.15
Acadia 8.78 8.78 8.86 8.88 8.86 8.82 8.82

Worst 20% Baseline 2018 2009 2009 2012 2018 2018
Site 2000-2004 URP Value Base Will Do Base Base Will Do Brigantine 29.01 25.05 25.79 25.83 25.72 25.21 25.22 Lye Brook 24.45 21.48 22. 04 22.08 21.86 21.14 21.14 Acadia 22.89 20.45 21.72 21.75 21.72 21.49 21.49

However, in "Recent MANE-VU Projections of Visi bility for 2018", MANE-VU Stakeholder Briefing, April 4, 2008, it is stated, "The Uniform Rate is achi eved and exceeded at all MANE-VU Class I sites." This presentation is available on the MANE -VU website, www.nescaum. org/topics/regionalhaze/regional-haze-documents.

These results show that for the northeastern Cla ss 1 areas, controls already implemented and on-thebooks may or may not result in achievement of reas onable progress goals. However, Indiana, along with the other MRPO states, has co ntinued to work with MANE-VU stat es. Results of this work have assisted U.S. EPA in developing the recently propos ed Air Transport Rule, which is discussed in the next section. One of the intentions of this pr oposed rule is to provide for reductions of regional pollutants to the level that upwi nd states are not contributing to nonattainment or interference with maintenance of the 1997 ozone and annual PM 2.5 and 2006 24-hour PM 2.5 standards. These reductions also will eliminate much of the regional contributions to regional haze. U.S. EPA has also committed to timely development of a second Transport Rule that wi ll address contributions from non-EGU sectors. These sources were also of concern to MANE-VU and MRPO workgroups.

At this time, Indiana believes that these actions adequately address visi bility concerns and are appropriate to meet reasonable progress goals given Indiana’s ma rginal impact on those areas.

8.0 Best Available Retrofit Technology

BART Guidelines are a component of the July 1, 1999 Regional Haze regulations, that are intended to protect and improve visibility in national parks and wilderness areas.

The process of establishing BART emission limitations includes identification of those sources that meet the definition of “BART-eligible source”, a determin ation of whether these sources are emitting any air pollutant that may be contributing to any impairment of visibility in a Class 1 area, and identification of the appropriate type and the level of control for reducing emissions.36 8.1 BART - Eligible Sources in Indiana

The BART-eligible sources in Indiana are shown in the following table. The BART-eligible sources were identified using the methodology in the “ Regional Haze Regulations and Guidelines for Best Available Retrofit Technology (BART) Determinations; Final Rule" ( 40 CFR Part 51).

Table 9 Indiana Sources wi th BART-Eligible Units County County ID Plant ID Name Cass 017 00006 Logansport Municipal Light & Power Cass 017 00005 ESSROC Materials, Inc. Clark 019 00008 ESSROC Cement Corporation Dearborn 029 00002 American Electric Power-Tanners Creek Gibson 051 00013 Duke Energy – Gibson Jasper 073 00008 N IPSCO - R. M. Schahfer Lake 089 00318 Mittal Steel USA Inc.- Indiana Harbor West Lake 089 00003 BP Products North America, Inc. - Whiting Refinery Lake 089 00112 Carmeuse Lime, Inc. Lake 089 00210 State Line Energy, L.L.C. Lake 089 00121 U.S. Steel - Gary Works Lake 089 00316 Mittal Steel USA Inc.- Indiana Harbor East Lake 089 00117 N IPSCO - D. H. Mitchell Station Laporte 091 00021 N IPSCO - Michigan City Lawrence 093 00002 Lehigh Cement Company Marion 097 00033 IPL Harding Street Station Marion 097 00034 Citizens Thermal Energy Pike 125 00002 Indianapolis Power & Light/AES Petersburg Pike 125 00001 Hoosier Energy - Ratts Station Porter 127 00002 N IPSCO - Bailly Station Porter 127 00001 Mittal Steel USA Inc.- Burns Harbor Posey 129 00002 SABIC Innovative Plastics (formerly GE Plastics) Posey 129 00010 SIGECO - A. B. Brown Putnam 133 00002 Buzzi Unicem USA Sullivan 153 00005 Hoosier Energy - Merom Station Tippecanoe 157 00012 Purdue University Vermillion 165 00001 Duke Energy – Cayuga Vermillion 165 00009 Eli Lilly and Company-Clinton Labs Vigo 167 00021 Duke Energy – Wabash River Warrick 173 00002 & 00007 ALCOA Inc. Warrick 173 00001 SIGECO - F. B. Culley Generating Station Wayne 177 00009 Richmond Power & Light

IDEM identified sources within the BART source cat egories and sent a survey to obtain additional information to develop a list of BART-eligible sources. Based on the surveys and subsequent discussions and comments, IDEM determined that s ources in Table 9 have at least one BART-eligible unit. Supporting documentation is in Appendix 5 - BART Eligible Units.37 8.2 Sources Subject to BART

IDEM conducted further modeling in coordination w ith the MRPO to determine which BART-eligible sources are subject to BART. Us ing dispersion modeling (Option 1 in the BART Guidelines), IDEM determined that the following non-EGUs were subject to BART: Alcoa Inc., ESSROC Cement Corporation, SABIC Innovative Pl astics (formerly GE Plastics), a nd Mittal Steel USA Inc.-Burns Harbor. Modeling indicated that the following EGUs were subject to BART: ALCOA Inc., Hoosier Energy - Ratts Station, Richmond Power & Light, Stat e Line Energy, NIPSCO - D. H. Mitchell Station, NIPSCO - Michigan City, NIPSCO - Bailly Station, SIGECO - A. B. Brown, and SIGECO - F. B. Culley Generating Station.

In addition, IDEM identified the following fossil-fuel fired generating power plan ts as having a capacity in excess of 750 megawatts: Duke Energy - Gibso n, Duke Energy - Cayuga, Indianapolis Power & Light/AES Petersburg, IPL - Harding Street Stat ion, NIPSCO - R. M. Schahfer, American Electric Power-Tanners Creek, Duke Energy - Wabash Rive r, and Hoosier Energy - Merom Station.

Indiana accepted the U.S. EPA analysis that CAIR achieves greater progress than BART and may be used by States as a BART substitute (70 FR 39137). The Indiana Air Pollution Control Board, on November 1, 2006, adopted CAIR for the Indiana EGUs to participate in the cap and trade program. CAIR, therefore, satisfies the BART NO x and SO 2 requirements for these sources. The PM impact on visibility on Class 1 areas was addressed for thes e sources. One EGU, ALCOA-Warrick Power Plant Boiler # 4, was determined to be subject to BART.

In December 2008, the DC Circuit C ourt remanded CAIR to U.S. EPA without vacatur because it found that "allowing CAIR to remain in effect until it is re placed by a rule consistent with our opinion would at least temporarily preserve the environmental valu es covered by CAIR." The CAIR requirements are currently in place and CAIR's regional control programs are operating while U.S. EPA develops replacement rules in re sponse to the remand.

On July 6, 2010, U.S. EPA proposed a CAIR replacement, the Clean Air Transport Rule (TR), which as proposed, will achieve emission reductions of NO x and SO 2 beyond those original ly required by CAIR through additional air pollution reduc tions from power plants beginni ng in 2012. Therefore, Indiana believes that the Transport Rule wi ll also achieve greater progress than BART. The TR is proposed to be initially in the form of a Federal Implementati on Plan, which would not require action by Indiana to be put into place.

Table 10 shows Indiana BART-eligible EGU units cove red by CAIR, controls assumed to be in place by the EPA 2006 IPM 3.0 runs that supp orted the CAIR rule, and cont rols assumed by the LADCO Round 5 runs used by IDEM to evaluate regional haze scenarios. It contai ns updated information regarding current controls, committed controls, and results from le gal settlements. The table shows that controls in place or committed, as a whole, exceed requirements fo r CAIR. Further, proposed allocations in the TR for some major units without announ ced plans for controls are much less than allowances provided in CAIR.

Table 10 also provides information regarding controls for units incl uded in the "MANE-VU ask".38 Table 10 Indiana BART-eligible Electri c Generating Units covered by CAIR

INDIANA COAL-FIRED UNITS EPA IPM 3.0 2006 runs LADCO Round 5 Runs

BART-eligible Units

*MANEVU Ask SO 2 NO x

FACILITY_NAME UNITID 2009 + Projected SO 2 _CONTROL 2009 + Projected NO x _CONTROL IPM Existing IPM 2010 Retrofit IPM 2015 Retrofit IPM 2020 Retrofit LADCO 2012 Retrofit LADCO 2018 Retrofit A B Brown Generating Station 1 Dual Alkali FGD Selective Catalytic Reduction SCR+FGD

Alcoa Allowance Management Inc 2 Wet Limestone FGD (2008) Low NO
x Burner Technology w/ Overfire Air LNB w/SOFA

Alcoa Allowance Management Inc 3 Wet Limestone FGD (2008) Low NO
x Burner Technology w/ Overfire Air LNB w/SOFA

Alcoa Allowance Management Inc 4 Wet Limestone FGD (2008) Low NO
x Burner Selective Catalytic Reduction SCR FGD FGD FGD FGD

Bailly Generating Station 7 Wet Limestone Overfire Air / Selective Catalytic Reduction (2008) SCR+FGD

Bailly Generating Station 8 Wet Limestone Overfire Air / Selective Catalytic Reduction SCR+FGD

Cayuga * 1 Wet Limestone (2008 - 95%) Low NO
x Burner Technology w/ Separated OFA FGD+LNB w/SOFA SCR SCR SCR SCR

Cayuga * 2 Wet Limestone (2008 - 95%) Low NO
x Burner Technology w/ Separated OFA FGD+LNB w/SOFA SCR SCR SCR SCR

Clifty Creek * 1 (FGD Scheduled possibly 2013) Overfire Air Selective Catalytic Reduction FGD+SCR

Clifty Creek * 2 (FGD Scheduled possibly 2013) Overfire Air Selective Catalytic Reduction FGD+SCR

Clifty Creek * 3 (FGD Scheduled possibly 2013) Overfire Air Selective Catalytic Reduction FGD+SCR

Clifty Creek * 4 (FGD Scheduled possibly 2013) Overfire Air Selective Catalytic Reduction FGD+SCR

Clifty Creek * 5 (FGD Scheduled possibly 2013) Overfire Air Selective Catalytic Reduction FGD+SCR

Clifty Creek * 6 (FGD Scheduled possibly 2013) Overfire Air FGD SCR SCR SCR SCR SCR

Dean H Mitchell Generating Station 11 Shut Down Shut Down LNB Dean H Mitchell Generating Station 4 Shut Down Shut Down Comb. Optimization SCR SCR Dean H Mitchell Generating Station 5 Shut Down Shut Down Comb. Optimization SCR SCR Dean H Mitchell Generating Station 6 Shut Down Shut Down LNB SCR SCR39 INDIANA COAL-FIRED UNITS EPA IPM 3.0 2006 runs LADCO Round 5

BART-eligible Units

*MANEVU Ask SO 2 NO x

FACILITY_NAME UNITID 2009 + Projected SO 2 _CONTROL 2009 + Projected NO x _CONTROL IPM Existing IPM 2010 Retrofit IPM 2015 Retrofit IPM 2020 Retrofit LADCO 2012 Retrofit LADCO 2018 Retrofit

Edwardsport 7-1 Unit will retire in 2012, IGCC will replace all the units in 2012 Unit will retire in 2012, IGCC will replace all the units in 2012 Retire Retire Retire Retire Retire

Edwardsport 7-2 Unit will retire in 2012, IGCC will replace all the units in 2012 Unit will retire in 2012, IGCC will replace all the units in 2012 Retire Retire Retire Retire Retire

Edwardsport 8-1 Unit will retire in 2012, IGCC will replace all the units in 2012 Unit will retire in 2012, IGCC will replace all the units in 2012 Retire Retire Retire Retire Retire

F B Culley Generating Station 2 Wet Limestone Low NO
x Burner Technology (Dry Bottom only) FGD+LNB SNCR SNCR

F B Culley Generating Station 3 Wet Limestone Low NO
x Burner Technology (Dry Bottom only) Selective Catalytic Reduction FGD+SCR

Frank E Ratts 1SG1 U.S. EPAsettlement , plantwide from 2009 levels 42% reduction - 2012, 58% - 2014 Low NO
x Burner Technology (DryBottom only) OFA2008 LNB SCR SCR

Frank E Ratts 2SG1 U.S. EPAsettlement , plantwide from 2009 levels 42% reduction - 2012, 58% - 2014 Low NO
x Burner Technology (DryBottom only) OFA2008 LNB SCR SCR

Gibson * 1 Wet Limestone LNB w/ Overfire Air Selective Catalytic Reduction SCR+FGD

Gibson * 2 Wet Limestone Low NO
x Burner Technology w/ Overfire Air Selective Catalytic Reduction SCR+FGD

Gibson * 3 Wet Limestone Low NO
x Burner Technology w/ Overfire Air Selective Catalytic Reduction SCR+FGD

Gibson * 4 Wet Limestone Low NO
x Burner Technology w/ Overfire Air Selective Catalytic Reduction SCR+FGD

Gibson 5 Wet Limestone Low NO
x Burner Technology w/ Overfire Air Selective Catalytic Reduction SCR+FGD40 INDIANA COAL-FIRED UNITS EPA IPM 3.0 2006 runs LADCO Round 5

BART-eligible Units *MANEVU Ask SO 2 NO x

FACILITY_NAME UNITID 2009 + Projected SO 2 _CONTROL 2009 + Projected NO x _CONTROL IPM Existing IPM 2010 Retrofit IPM 2015 Retrofit IPM 2020 Retrofit LADCO 2012 Retrofit LADCO 2018 Retrofit

Harding Street Station (EW Stout) 50 LNB w/ SeparatedOFA Selective Noncatalytic Reduction SNCR

Harding Street Station (EW Stout) 60 LNB w/ SeparatedOFA Selective Noncatalytic Reduction SNCR

Harding Street Station (EW Stout) * 70 Wet Limestone LNB w/ Closedcoupled/Separated OFA Selective Catalytic Reduction SCR FGD FGD FGD FGD FGD

IPL Eagle Valley Generating Station 3

IPL Eagle Valley Generating Station 4 Low NOx Burner Technology w/ Separated OFA LNB w/SOFA

IPL Eagle Valley Generating Station 5 Low NOx Burner Technology w/ Separated OFA LNB w/SOFA

IPL Eagle Valley Generating Station 6 Low NOx Burner Technology w/ Separated OFA LNB w/SOFA

Merom 1SG1 upgrade FGD - 90% 2012, upgrade to 95% 2014 Selective Catalytic Reduction Low NO
x Burner Technology w/ Overfire Air SCR+FGD

Merom 2SG1 upgrade FGD - 90% 2012, upgrade to 95% 2014 Selective Catalytic Reduction Low NO
x Burner Technology w/ Overfire Air

Michigan City Generating Station 12 Overfire Air - Selective Catalytic Reduction SCR Hg Control Hg Control

Petersburg 1 Wet Limestone Low NO
x Burner Technology w/ Closed-coupled/Sep. OFA FGD+LNB SCR SCR

Petersburg 2 Wet Limestone LNB w/ Closedcoupled/Separated OFA Selective Catalytic Reduction FGD+SCR

Petersburg 3 Wet Limestone LNB w/ Closedcoupled/Separated OFA Selective Catalytic Reduction FGD+SCR

Petersburg 4 Wet Limestone Low NO
x Burner Technology w/ Closed-coupled/Sep. OFA FGD+LNB SCR SCR SCR41 INDIANA COAL-FIRED UNITS EPA IPM 3.0 2006 runs LADCO Round 5

BART-eligible Units

*MANEVU Ask SO 2 NO x

FACILITY_NAME UNITID 2009 + Projected SO 2 _CONTROL 2009 + Projected NO x _CONTROL IPM Existing IPM 2010 Retrofit IPM 2015 Retrofit IPM 2020 Retrofit LADCO 2012 Retrofit LADCO 2018 Retrofit

R Gallagher * 1 Shut down by 2/1/12 or Convert to NG 1/1/13 Shut down by 2/1/12 or Convert to NG 1/1/13 LNB

R Gallagher * 2 Dry Sorbent Technology 1/1/11 Low NO
x Burner Technology w/ Overfire Air LNB

R Gallagher * 3 Shut down by 2/1/12 or Convert to NG 1/1/13 Shut down by 2/1/12 or Convert to NG 1/1/13 LNB

R Gallagher * 4 Dry Sorbent Technology 1/1/11 Low NO
x Burner Technology w/ Overfire Air LNB

R M Schahfer Generating Station 14 Overfire Air Selective Catalytic Reduction SCR Hg Control Hg Control

R M Schahfer Generating Station 15 LNB (Dry Bottom only) A 35% efficient stratified overfire air system was added in 2008 LNB Hg Control Hg Control

R M Schahfer Generating Station 17 Wet Limestone LNB w/ Closedcoupled/Separated OFA SCR FGD+LNB

R M Schahfer Generating Station 18 Wet Limestone LNB w/ Closedcoupled/Separated OFA LNB FGD+LNB

Rockport * MB1 FGD 12/31/17 TR allowances < CAIR 2012 and 2014 LNB (Dry Bottom only) (SCR 12/31/17) LNB w/OFA FGD FGD FGD+SCR FGD FGD+SCR

Rockport * MB2 FGD 12/31/19 TR allowances < CAIR 2012 and 2014 Low NO
x Burner Technology (Dry Bottom only) (SCR 12/31/19) LNB w/OFA FGD FGD FGD+SCR FGD FGD+SCR

State Line Generating Station (IN) 3 State Line Generating Station (IN) 4 Overfire Air SCR SCR SCR+Hg Control SCR SCR (-Hg Control)

Tanners Creek * U1 Burn only coal with

no more than 1.2 lb/MMBtu annual
average Low NO
x Burner Technology (Dry Bottom only) A 30% efficient SNCR will be in place in 2010. SNCR will operate year round OFA

Tanners Creek * U2 Burn only coal with

no more than 1.2 lb/MMBtu annual
average Low NO
x Burner Technology (Dry Bottom only) A 30% efficient SNCR will be in place in 2010. SNCR will operate year round OFA42 INDIANA COAL-FIRED UNITS EPA IPM 3.0 2006 runs LADCO Round 5

BART-eligible Units

*MANEVU Ask SO 2 NO x

FACILITY_NAME UNITID 2009 + Projected SO 2 _CONTROL 2009 + Projected NO x _CONTROL IPM Existing IPM 2010 Retrofit IPM 2015 Retrofit IPM 2020 Retrofit LADCO 2012 Retrofit LADCO 2018 Retrofit

Tanners Creek * U3 Burn only coal with

no more than 1.2 lb/MMBtu annual
average Low NO
x Burner Technology (Dry Bottom only) A 30% efficient SNCR will be in place in 2010. SNCR will operate year round OFA FGD+SCR FGD+SCR

Tanners Creek * U4 Burn only coal with

no more than 1.2% sulfur
content annual average Overfire Air OFA

Wabash River Gen Station * 1 IGCC IGCC Wabash River Gen Station * 2 Shut Down 9-30-09 Shut Down 9-30-09 LNB Wabash River Gen Station * 3 Shut Down 9-30-09 Shut Down 9-30-09 LNB SNCR SNCR

Wabash River Gen Station * 4 Low NO
x Burner Technology w/ Overfire Air LNB Wabash River Gen Station * 5 Shut Down 9-30-09 Shut Down 9-30-09 LNB SNCR SNCR

Wabash River Gen Station * 6 TR allocation in 2014 < CAIR Low NO
x Burner Technology w/ Separated OFA LNB FGD+SCR FGD+SCR

Whitewater Valley 1 Low NO
x Burner Technology w/ Separated OFA Ammonia Injection Overfire Air LNB

Whitewater Valley 2 Other Low NO
x Burner Technology w/ Separated OFA Ammonia Injection Overfire Air LNB

8.3 BART Analysis

IDEM began the BART rulemaking process in A ugust 2006. Following the due process of rulemaking which included the notices of hearings and commen ts, the Indiana Administrative Code at 326 IAC 26- 1, Best Available Retrofit Technology, was final adopted on October 3, 2007 and became effective February 22, 2008. A copy of th is rule is in Appendix 7.

The rule requires that sources subject to BART, upon notification from the department, submit to the department a BART analysis. The rule incorporat es by reference the BART Guidelines codified as Appendix Y at 40 CFR 51. The analysis should be pe rformed following those guidelines. The analysis must address at a minimum SO 2 , NO x , and particulate matter (PM) and consider the following factors: (1) the cost of compliance, (2) th e energy and non-air quality environm ental impacts of compliance, (3) any existing pollution control technology in use at the source, (4) th e remaining useful life of the source, and (5) the degree of visibility improvement that ma y reasonably be anticipated from the use of BART.43 The BART Guidelines require that the States consid er, at a minimum, certain control alternatives in determining BART controls. These alternatives include: BA CT, LAER, NSPS, and MACT, as applicable, pollution prevention, use of retrofit controls and, if avai lable, improvement of existing controls. In addition, the rule a llows sources to propose alternatives to source-specific BART, provided the alternative achieves greater reasonable progress to wards improving visibility. The alternative could include emissions controls at different locations of the same source, diffe rent sources, or at a source not subject to BART. The requirements for sources that choose an alternative to source-specific BART, in detail, are included in 32 6 IAC 26-1 and 40 CFR 51.308(e).

The department was required to review the analys es for completeness and approvability in accordance with 326 IAC 26-1, the BART Guidelines, and 40 CFR 51.308(e). The emission limits representing BART or an alternative to BART are to be includ ed in the sources’ Part 70 permits and submitted to U.S. EPA for approval into the SIP. The sources shall be required to comply with these requirements within five years of the effective da te of the state ru le, i.e., in 2013.

Of the sources identified as BART-eligible, modeli ng indicated that one non- EGU source, Alcoa, was subject to BART. IDEM identified several EGUs subject to BART. However, as provided by the federal rule, IDEM assumed NO x and SO 2 BART requirements are met by the participation of these sources in the CAIR NO x and SO 2 trading program. Other non-EGU s ources were also identified as being BART-eligible. These sources, SABIC I nnovative Plastics-Mt. Vernon, ArcelorMittal-Burns Harbor LLC, and ESSROC Ce ment Corp.-Speed submitted modeling an alyses showing that they did not contribute significantly to visibility impairment at any Class 1 areas. IDEM found that these analyses met all applicable criteria and have accepte d the findings. An analysis for each follows.

8.4 BART Determination and Mo deling for Burns Harbor

ArcelorMittal, LLC (Burns Harbor), formerly know n as ISG Burns Harbor, operates a steelmaking facility located in Burns Harbor, Porter County, Indi ana. In accordance with the BART Guidelines, Burns Harbor was identified as a BART-eligible source.

IDEM initially conducted long range transport modeling of the poten tial emissions from the BARTeligible emission units from Burns Harbor using th e CALPUFF model. IDEM determined Burns Harbor to be subject to BART for havi ng visibility impacts on nearby Cla ss I areas. Subsequently, Burns Harbor submitted its own BART exemption modeling analysis. This analysis used the maximum 24- hour average actual emission rates of sulfur dioxide and nitrogen oxides and compared modeled results with the annual average natural background light coe fficient, according to the BART guidance. Burns Harbor conducted CALPUFF modeling at the four near est Class I areas in which Burns Harbor had the greatest visibility impact, which were Mammot h Cave, Seney National Wildlife Refuge, Mingo Wilderness, and Isle Royale National Park. The CA LPUFF results showed Burns Harbor would not be subject to BART. The following de scribes IDEM’s revised BART mo deling and Burns Harbor’s BART exemption modeling analysis and results.

8.4.1 IDEM’s BART Determination Process

IDEM sent BART surveys in the fall of 2005 to sour ces that were identified as having possible BARTeligible emission units. Potential BART-eligible sour ces at Burns Harbor’s were identified as the Power Station including Boilers #7-#12, #1 and #2 Coke Battery pushing and underfire, Blast Furnaces C & D,44 Sinter Windbox, Steelmaking Stations #1 - #3, Steelma king Vessels #1 and #2, Hot Strip Furnaces #1 - #3, 160” Plate Mill Furnaces #1 - #2 and #5 - #8, 110” Pl ate Mill Furnaces #1 - #3, and Blast Furnaces C & D and steelmaking fugitives. These Burns Harbor emission units, described at the end of this section, met all three of the BART-eligible criteria for SO 2 , NO x , and PM, as listed below:

1.) Identify whether emission units ar e in one of the 26 source categories - Burns Harbor operates a steelmaking facility, identified as one of the 26 listed categories. 2.) Identify whether emission units were in existence on August 7, 1977 and began operation after August 2, 1962 - The construction dates for the BART-elig ible emission units at Burns Harbor were estimated within the BA RT eligibility timeframe. 3.) Compare potential emi ssions from emission units to 250 tons/y r or more threshold of a visibility impairing pollutant (NO x , SO 2 and PM) - Potential NO x and SO 2 emissions from all BART-eligible emission units exceed 250 tons/year of any single visibility impairing pollutant with potential NO x emissions of 7743.0 tons/yr and potential SO 2 emissions of 18769.0 tons/yr. Potential PM 10 emissions from all BART-eligible units at Burns Harbor totaled 1168.9 tons/yr.

Source specific stack and detailed emissions informa tion were requested to be used in IDEM’s BART determination modeling analyses. A Burns Harbor submitted the survey results to IDEM on March 2, 2006. IDEM conducted preliminary CALP UFF modeling, in which potential NO x , SO 2 , and PM 10 emissions from Burns Harbor’s BART-eligible emissi on units were modeled to determine the visibility impacts. Results showed the visibility impacts fr om Burns Harbor exceeded th e BART threshold of the 98 th percentile of 0.5 dv with a tota l of thirty days over 0.5 dv for 2002, thirty-nine days over 0.5 dv for 2003, and forty-four days over 0.5 dv for 2004 at the si xteen Class 1 areas mode led. Burns Harbor had the most visibility impact days at Seney National W ildlife Refuge with ten days in 2002, seventeen days in 2003 and nineteen days in 2004. Based on the info rmation provided, Burns Harbor was determined to be subject to BART.

OCS Environmental, Inc. and ENSR Corporation prepared the Burns Harbor BART modeling analysis, conducted CALPUFF modeling, and submitted the results to IDEM on May 13, 2008. Additional information was submitted by Burns Harbor and its consultants and the information gathered from these submittals aided IDEM’s review of Burns Harbor’s subject to BART de termination. This material is contained in Appendix 5a.

8.4.2 IDEM’s BART Modeling Process

IDEM conducted long range transport modeling in c oordination with the MRPO to determine which BART-eligible sources have visibilit y impacts that exceed BART modeli ng thresholds and are subject to BART. LADCO created a “Single Source Mode ling to Support Regional Haze BART Modeling Protocol” for the states of Indiana, Illinois, Mi chigan, Wisconsin, and Ohio. This document can be found in Appendix 5a. IDEM used th is protocol in order to remain consistent with the other MRPO states in conducting its subject to BART determinations.

CALPUFF was identified by U.S. EPA as the best regulatory modeli ng application available for long range transport of primary pollutants and the only EP A-approved model for predicting a single source’s contribution to visibility impact s. CALPUFF inputs include seve ral modules within CALPUFF to determine transport (CALPUFF), meteorology (CALM ET), inorganic chemistr y effects (POSTUTIL),45 and post-processing of the results (CALPOST). Th e versions used in the IDEM’s CALPUFF modeling are as follows:

CALPUFF version 5.711a, Level 040716 CALMET version 5.53a, Level 040716 CALPOST version 5.51, Level 030709 CALMM5 version 2.0, Level 021111 POSTUTIL version 1.4, Level 040818

Modeling options used in CALPUF F are consistent with guidance found in the Interagency Workgroup on Air Quality Modeling (IWAQM), “Phase 2 Su mmary Report and Recommendations for Modeling Long Range Transport Impacts” (EPA-454/R-98-019). Any modifications in the CALPUFF modeling approach from the IWAQM documents are discu ssed in detail in the MRPO CALPUFF modeling protocol. LADCO created a vers ion of CALPUFF that could be executed on a Linux Red Hat operating system and created input files in or der to conduct the CALPUFF modeling. As a result of MRPO discussions with U.S. EPA, th e change in dv is compared with natural visibility conditions on the 20% best days and not the averag e visibility conditions. The natural visibility conditions are defined as the 20% best days, as listed in the U. S. EPA’s “Guidance for Estimating Natural Visibility Conditions under the Regi onal Haze Rule” (EPA, 2003). IDEM has accepted previous BART determination analyses using the average annual natural background conditions if the subject to BART source conducted more refined CALPUFF modeling in accordance with state or federally approved protocols.

8.4.3 Modeling Domain and Meteorology

The modeling domain used for the MRPO CALPUFF modeling analysis was a Lambert conformal grid projection centered at 97 West, 40 North with true latitudes at 33 No rth and 45 North and origin at (-900 km, -1620 km). The horizontal domain consisted of 97 36-kilometer cells in the east-west direction and 90 36-kilometer cells in the north-south direction. Approximately 15 kilome ters in the vertical atmosphere were resolved with 16 vertical layers. Landuse and terrai n data were extracted from global datasets, taken from United States Geological Survey (USGS) Composite Theme Grid landuse and USGS Digital Elevation Model terrain height.

IDEM modeling covered three years of meteorological data (2002-2004) with the meteorological inputs taken from the prognostic meteorological model us ing four-dimensional data-assimilation (FDDA). Meteorological Model 5 (MM5 versi on 3.6) output was used to supply hourly meteorological data for CALMET input. Observation data was included in the ETA analysis fields to initialize MM5.

8.4.4 Class 1 Areas

There were sixteen Class I areas an alyzed in the MRPO area with disc rete receptors covering the nearby Class I areas. The Class I areas were taken from th e National Parks Service Class I area receptor index. Receptor grids with a resolution of 1-kilometer we re placed at each Class I area with a total of 4,434 receptors analyzed. The sixteen Class I areas and the states where the Class I ar eas are located are listed below:

Boundary Waters Canoe Area – MN Brigantine Wilderness Area – NJ Dolly Sods/Otter Creek Wilderness – WV Great Gulf Wilderness – NH46 Great Smoky Mountains National Park – TN Hercules-Glades Wilderness– MO Isle Royale National Park – MI James River Face Wilderness – VA Linville Gorge Wilderness– NC Lye Brook Wilderness – VT Mammoth Cave National Park – KY Mingo Wilderness Area – MO Seney National Wildlife Refuge – MI Shenandoah National Park – VA Sipsey Wilderness – AL Voyageurs National Park – MN

8.4.5 Visibility Impairment Pollutants Analyzed

Pursuant to the U.S. EPA and MRPO guidance, SO 2 , NO x , and PM are considered the primary visibility impairing pollutants. U.S. EPA recommends states use their judgment in dete rmining whether volatile organic compounds (VOCs) and ammonia cont ribute to visibility impairment. SO 2 , NO x , and PM 10 were modeled using the CALPUFF model for the Burns Harbor analysis. Visibility impairing pollutants such as VOCs and ammonia were not modeled but may be evaluated at a later date. The Burns Harbor submittal contained information which included th e methodologies for estimating daily emission rates from all the BART-eligible units at Burns Har bor, as found in Appendix 5a. The 24-hour average emission rates from the highest emitting day are pref erred in the CALPUFF modeling analysis to be consistent with the Modeling Guid ance determining visibility impair ment for BART determinations. Burns Harbor calculated its emissions from its com bustion units and process units using several methods to determine the maximum 24-hour emissions. Combus tion unit emissions were calculated using actual daily fuel use records and emission factors based on fuel sampling, stack testing, or U.S. EPA’s AP-42. Process unit emissions were calculated using th e maximum 24-hour production rates and emission factors derived from stack tests a nd U.S. EPA’s AP-42. For the sma ller process units that only had monthly production data, the average daily production rates were calcul ated and used to determine the 24-hour average emission rates from the highest emitting day.

The stack parameters of all the BART-eligible so urces at Burns Harbor, as well as the area source parameters that define the slag pits and steelmaking fugitive area dimensions are summarized in Table 17 at the end of this section. Th e coordinates of the Burns Harbor BART-eligible emission units are based on Lambert Conformal Conic (LCC) in orde r to project on the CALPUFF modeling domain.

8.4.6 IDEM’s Subject to BART Determination Modeling Results

IDEM based its initial CALPUFF modeling on potentia l emissions from Burns Harbor’s BART-eligible emission units. The differences between IDEM’s in itial BART determination modeling and the revised modeling conducted from Burns Harbor’s BART exemption modeling submittals were the 24-hour average emission rate estimates from the hi ghest emitting day supplied by Burns Harbor. Methodologies explaining Burns Harbo r’s emission calculations are found in Appendix 5a. The emission estimates meet the BART guidance for us ing the 24-hour average emission rates from the highest emitting day in th e CALPUFF modeling.

The criteria used to determine if a source is “contributing” to visibility impairment is the 98 th percentile that is equal to 0.5 dv for MRPO States using a ma ximum 24-hour emission rate and the peak value that is equal to 0.5 dv for MRPO States usi ng an actual 24-hour emission rate. The 98 th percentile is interpreted as any source with more than 21 days of visibility impairment over the 3 year modeling47 period or 7 days of visibility impair ment in any one of the 3 years mode led is “contributing” to visibility impairment.

Results of IDEM’s revised BART dete rmination modeling showed that the 98 th percentile dv impact from Burns Harbor was above 0.5 dv; with a total of ten days over 0.5 dv for 2002, seventeen days over 0.5 dv in 2003 and nineteen days over 0.5 dv in 2004. Table 11 shows IDEM’s revised CALPUFF modeling results with the top eigh t rankings of the highest dv impacts from Burns Harbor for 2002 through 2004. The total number of days which m odeled above 0.5 dv for all three modeled years is forty-six, above the twenty -two day threshold for 98 th percentile of the cumulative three-year modeled period, as shown below in Table 12. Therefore, based on IDEM’s CALPUFF analysis, Burns Harbor’s BART-eligible emission units are subject to BART.

Table 11 IDEM’s Revised CALPUFF Mo deling Results for Burns Harbor
Impact

Rank 2002 - Seney dv/Day 2003 - Seney dv/Day 2004 - Seney dv/Day

1st 1.397 (274) 1.886 (321) 2.415 (364)
2nd 1.104 (263) 1.471 (281) 1.745 (250)
3rd 1.102 (315) 1.413 (350) 1.335 (321)
4th 1.071 (273) 1.285 (294) 1.328 (247)
5th 0.964 (245) 1.247 (32) 1.267 (60)
6th 0.875 (55) 1.238 (232) 1.170 (231)
7th 0.592 (159) 0.998 (315) 0.882 (3)
8th 0.561 (102) 0.993 (233) 0.766 (85)

Table 12 Number of Modeled Days over 0.5 dvs for Class 1 Areas Year 2002 2003 2004 Total Seney 10 17 19 46 Mammoth Cave 7 1 4 12 Mingo 5 3 3 11 Isle Royale 1 4 4 9

8.4.7 IDEM’s Culpability Modeling Results for Burns Harbor

IDEM conducted additional CALPUFF modeling for Bu rns Harbor to determine if certain BARTeligible emissions points within Burns Harbor were contributing more to the visibility impacts on surrounding Class 1 areas then othe r emission points. To conduct the culpability analysis, BARTeligible emission points were grouped according to emissions. Five separate CALPUFF runs were conducted based on the following:

Group 1 – Power Station Boilers #7 - #12: SO 2 emissions = 218.31 grams/sec; NO x = 29.60 grams/sec Group 2 - #1, #2 Coke Battery Underfire: SO 2 emissions = 133.42 grams/sec; NO x = 99.98 grams/sec Group 3 – Windbox/C&D Blast Furnaces: SO 2 emissions = 109.11 grams/sec; NO x = 50.19 grams/sec Group 4 - #1, #2, #3 Hot Strip Furnace/#1, #2 160” Plate Mill Furnace: SO 2 emissions = 67.07 grams/sec; NO x = 31.17 grams/sec48 Group 5 - #1,#2 Coke Battery Pushing/Blast Furna ce C&D Casthouse/ #1, #2 Steelmaking HMD Stations/Steel Making Vessel #3/Steelmaking FM Boiler/#5-#8 160” Plant Mill Furnace/#1,#2 110” Plate Mill Furnace/Steelmaki ng HMC Station #3/110” Plate Mill Normalizing Furnace: SO 2 emissions = 3.82 grams/sec; NO x = 8.64 grams/sec

Results of IDEM’s culpability modeling are show n below in Table 13. Separately, each source group showed impacts below the 98 th percentile of the 0.5 dv visibility th reshold. The source group with the maximum impact was the Group 1 Power Station Boilers #7-#12.

Table 13 IDEM’s Culpability Mode ling Results for Burns Harbor
Impact

Rank 2002 – Seney Max. dv/# of Days 2003 – Power Station Max. dv/# of Days 2004 – Power Station Max. dv/# of Days

Power Station 0.557 1 0.629 3 0.785 3

Underfire 0.479 0 0.674 1 0.865 2

Windbox 0.331 0 0.469 0 0.589 1

Furnaces 0.229 0 0.318 0 0.382 0

Other 0.152 0 0.29 0 0.212 0

While this analysis does not c onstitute a subject to BART determination, it shows which sources contribute more to higher visibility impact days. The power station boilers, c oke battery underfire, and windbox/blast furnace groups have the highest amount of impacts days over 0.5 dv.

8.4.8 Burns Harbor’s BART Determination Modeling

Burns Harbor submitted modeling for its BART determ ination, using information and inputs taken from the VISTAS BART Modeling Protocol, the MRPO BART Modeling Protocol, and IDEM’s initial CALPUFF input files. Burns Har bor used the latest EPA-approve d version of CALMET (version 5.8) to create a more refined 6-kilometer CALMET data set from 2002 through 2004. Burns Harbor’s approach to processing the CALMET data is referenced in Section 3.0 “Meteorological Data” in their Source Specific BART Modeling Repor t: ArcelorMittal Burns Harbor LL C, found in Appendix 5a. This approach was accepted by IDEM after consultation with U.S. EPA, Region 5.

Burns Harbor used the latest EPA-approved versi on of CALPUFF (version 5.8) along with selected MRPO options listed in the MRPO “Single S ource Modeling to Suppor t Regional Haze BART Modeling Protocol”. IDEM’s preliminary CALPU FF modeling used a more conservative extinction coefficient (20% best day natural background), du e to the 36-kilometer modeling grid used by the MRPO, rather than an annual average natural backgr ound coefficient. Burns Harbor’s use of a more refined 6-kilometer grid warranted the use of the average annual na tural background concentrations for Class I areas in the eastern United States, pursuan t to U.S. EPA’s “Guidance for Estimating Natural Visibility Conditions Under the Regi onal Haze Program” (EPA-454/B-03-005).

The new IMPROVE equation is used to estimate light extinction, and was used to determine the visibility impacts from Burns Harbor. The ne w IMPROVE equation approach was accepted by U.S.49 EPA and the Federal Land Managers for previous BART modeling analyses and is referenced in Section 4.0 “CALPUFF Modeling” in the Source Specific BART Modeling Report: ArcelorMittal Burns Harbor LLC. This is found in Appendix 5a.

Table 14 below shows the results of Burns Harbor’s modeling, submitted on September 4, 2008. The CALPUFF results show visibi lity impacts below the 98 th percentile of the 0.5 dv threshold at the four nearest Class 1 areas: Mammoth Cave in Kentucky, Seney National Wildlife Refuge and Isle Royale National Park in Michigan, and Mi ngo Wilderness Area in Missouri. Results are summarized in Table 15. Visibility impacts for an individual year or the 3-year cumulative total do not exceed the 98 th percentile of the 0.5 dv threshold at any Class 1 areas.

Table 14 Burns Harbor’s CALPUFF Modeling Results over 0.5 Dv
Impact

Rank 2002 dv/Location/(day) 2003 dv/Location/(day) 2004 dv/Location/(day)

1st 0.751 at Seney (314) 1.165 at Seney (320) 1.030 at Seney (344)
2nd 0.750 at Seney (269) 0.695 at Seney (31) 0.891 at Seney (363)
3rd 0.568 at Seney (261) 0.54 at Seney (350) 0.865 at Seney (320)
4th 0.501 at Seney (50) 0.508 at Seney (280) 0.845 at Seney (79) 5th 0.45 at Seney (222) 0.487 at Seney (231) 0.794 at Seney (249) 6th 0.369 at Seney (273) 0.471 at Seney (66) 0.673 at Seney (78) 7th 0.359 at Seney (161) 0.398 at Seney (293) 0.547 at Seney (2) 8th 0.346 at Seney (272) 0.375 at Se ney (342) 0.464 at Seney (230)

Table 15 Number of Modeled Days over 0.5 dv for Class 1 Areas Year Seney Mammoth Cave Mingo Isle Royale

2002 4 2 3 0 2003 4 3 1 2 2004 7 1 0 2 TOTAL 15 6 4 4

8.4.9 Comparison of Burns Harbor and IDEM BART Determination Modeling

Due to Burns Harbor’s use of more refined CALPU FF and CALMET 6-kilometer grid files, differences in the results occurred compared to IDEM’s review. Based on the changes from the MRPO 36- kilometer grid and use of the best 20% natural ba ckground values to the 6-kilometer grid and annual average natural background values used by Burns Ha rbor, the number of days over the 0.5 dv threshold were lowered by 5 to 7 days.

In addition, Burns Harbor’s use of the new IMPROVE equation resulted in lower visibility impacts. Burns Harbor conducted a comparison of the old and new IMPROVE equations on their results and showed that for Seney, the new IMPROVE equation lowe red the number of days with visibility impacts over the 0.5 dv threshold by 3 to 4 days. Table 16 shows a comparison of IDEM’s 36 kilometer results with the previous IMPROVE equation and the new IMPROVE equation.50 Table 16 IDEM’s Revised CALPU FF Modeling Results at Seney Comparing old and new IMPROVE equations

Seney 2002 IMPROVE 2003 IMPROVE 2004 IMPROVE

Impact Rank Old New Old New Old New

1st 1.40 0.76 1.89 1.05 2.42 1.35

2nd 1.10 0.61 1.47 0.77 1.75 0.95

3rd 1.10 0.60 1.41 0.76 1.33 0.74

4th 1.07 0.57 1.28 0.68 1.33 0.72

5th 0.96 0.51 1.25 0.66 1.27 0.66

6th 0.87 0.45 1.24 0.67 1.17 0.64

7th 0.59 0.29 1.00 0.55 0.88 0.46

8th 0.56 0.29 0.98 0.53 0.77 0.41 Total Days over 0.5 DV 10 5 17 8 19 6

As illustrated, the new IMPROVE equation lowered the nu mber of visibility impact days above 0.5 dv at Seney National Wildlife Refuge by 5 to 13 days. Re sulting dv values were reduced by approximately 50%. Results for Mammoth Cave, Mingo Wilderness Ar ea and Isle Royale Na tional Park can be found in Appendix 5a.

Burns Harbor used default H 2 O 2 background concentrations of 1.0 co mpared to the MRPO’s seasonal H 2 O 2 background concentrations, which varied from 0.5 to 3.5. This difference was not significant as these variables are only used when the option for aqueous phase reactions are taken into account. Another change was the total natu ral background extinction coefficien ts used by Burns Harbor were allocated to soils instead of di stributed among sulfates, nitrates, organic and elemental carbon, coarse mass and soil. This change did not significantly aff ect visibility results as explained in Section 4.0 “CALPUFF Modeling” in their Source Specific BART Modeling Report: ArcelorMittal Burns Harbor LLC.

IDEM’s review of the Burns Har bor modeling has shown that the re fined modeling and use of the new IMPROVE equation and the annual aver age natural background concentrat ions have resulted in lower visibility impacts. Based on the more refined grid approach, Burns Harbor has demonstrated that the number of days with visibility impacts from the source fall below th e visibility threshold of 22 days above 0.5 dv and the source will not be subject to BART.

8.4.10 Summary of Burns Harbor BART Determination Analysis

In accordance with 70 FR 39104 and the criteria set forth by U.S. EPA for sources which might be BART-eligible, Burns Harbor was identified as a BART-eligible source. IDEM conducted dispersion/long range transport modeling of the BART -eligible emissions units from Burns Harbor and determined Burns Harbor to be subject to BART. Subsequently, Burns Harbor submitted a BART51 modeling analysis and through updated emission estim ates, revised stack parameters, refined grid modeling, use of annual average natu ral background concentrations, a nd determination of visibility impacts using the new IMPROVE equation, indicated Burns Harbor’s BART-eligible emissions units would not be subject to BART. ID EM’s review of Burns Harbor’s modeling analysis and the revised emission rates show that Burns Harbor w ill not be subject to BART, with the 98 th percentile dv value below the 0.5 dv threshold at surroun ding Class I areas. Therefore, the BART-eligible units from Burns Harbor are not subject to BART a nd no further analysis is required.

Table 17 BART-eligible Stack Parameters for Burns Harbor

Emission Unit Base Elevation LLC East LLC North Stack Height Stack Diameter Exhaust Velocity Exhaust Temperature POINT Source (m) (km) (km) (m) (m) (m/sec) ( o K) Power Stations (Boilers #7 - #12) 187.14 816.32 225.26 67.06 3.43 13.34 505.00
#1 Coke Battery Pushing 187.54 816.09 224.28 20.12 0.76 9.44 323.00 #1 Coke Battery Underfire 187.15 816.02 224.26 76.81 3.78 7.15 547.00 #2 Coke Battery Pushing 187.15 816.13 224.04 26.82 2.44 20.20 335.00 #2 Coke Battery Underfire 187.14 816.02 224.10 75.90 4.18 4.48 505.00 Sinter Windbox Stack 187.15 815.98 225.24 24.08 2.39 55.12 319.00 Blast Furnace D Casthouse 187.14 816.14 225.30 18.90 1.56 24.70 533.00 Blast Furnace C Stoves 187.15 816.18 225.27 61.26 3.48 15.89 519.00 Blast Furnace D Stoves 187.14 816.15 225.42 61.26 3.59 14.93 519.00 Blast Furnace C Casthouse 187.14 816.14 225.30 18.90 1.56 24.70 533.00 Steelmaking HMD Station #1 187.14 816.38 225.89 25.91 2.05 12.95 305.00
Steelmaking HMD Station #2 187.14 816.41 225.89 25.91 3.04 5.89 305.00
Steelmaking Vessels #1 and #2 187.15 816.41 225.91 24.99 6.02 5.65 325.00
Steelmaking Vessels #3 187.15 816.41 225.99 11.58 3.71 2.64 332.00 Steelmaking FM Boiler 187.15 816.56 225.89 67.66 1.99 1.79 478.00 Hot Strip Furnace #1 187.14 816.97 225.23 41.45 4.30 7.06 811.00 Hot Strip Furnace #3 187.14 817.01 225.23 41.45 3.97 8.81 811.00 Hot Strip Furnace #2 187.14 817.00 225.23 41.45 4.30 7.02 811.00 160 “ Plate Mill Furnace #1 187.14 816.98 225.06 54.25 3.10 4.37 673.00 160 “ Plate Mill Furnace #2 187.14 817.0 225.06 54.25 3.10 4.09 693.00

160 “ Plate Mill Furnace #5 187.14 817.02 225.06 39.92 1.95 12.48 783.00

160 “ Plate Mill Furnace #6 and #7 187.14 817.02 224.94 32.92 2.24 9.99 783.00

160 “ Plate Mill Furnace #8 187.14 817.02 224.92 50.90 1.74 2.99 673.00 110 “ Plate Mill Furnace #1 and #2 187.14 817.02 224.83 54.56 4.44 2.13 838.00
Steelmaking HMD Station #3 187.14 816.47 225.92 25.91 2.05 12.95 305.00
110 “ Plate Mill Normalizing Furnace 187.14 816.82 224.54 45.72 1.92 4.27 305.00

Base Elevation LLC East LLC North Release Height Area Side Length Initial Vertical
AREA Source (m) (km) (km) (m) (m) (m)
Blast Furnace C Slag Pit 187.14 816.15 225.38 50.00 30.00 30.00
Blast Furnace D Slag Pit 187.14 816.13 225.52 50.00 40.00 30.00
Steelmaking Fugitives 187.14 816.44 225.86 50.00 150.00 150.0

8.5 BART Determination and Modeling fo r ESSROC Cement Corporation - Speed

ESSROC Cement Corporation (ESSROC) operates a Po rtland cement manufacturi ng facility located in Speed, Clark County, Indiana. In accordance with th e BART Guidelines and criteria for BART-eligible sources, ESSROC was identified as a BART-eligible source.52 IDEM initially conducted long-rang e transport modeling of the poten tial emissions from the BARTeligible emission units from ESSROC using the CA LPUFF model. IDEM determined ESSROC to be subject to BART for having visibility impacts on nearby Class I areas. Subsequently, ESSROC submitted their own BART exemption modeling analys is using the 24-hour average actual emission rates from the highest emitting day, according to the BART Guidance. Based on IDEM’s comments, ESSROC submitted additional information concerning the SO 2 and NO x emissions used in the CALPUFF modeling. ESSROC’s CALP UFF results showed ESSROC woul d not be subject to BART. This information is all contained in Appendix 5b. This document cont ains IDEM review of ESSROC’s BART modeling analysis and the re sults of IDEM’s revised BART mo deling. IDEM’s results showed that the visibility impairment fr om the ESSROC’s sulfur dioxide and nitrogen oxide emissions would not exceed thresholds established in the BART Guidel ines and, therefore, will not be subject to BART.

8.5.1 IDEM’s BART Determination Process

IDEM sent out BART surveys in the fall of 2005 to sources that we re identified as having possible BART-eligible emission units. ESSROC’s Kilns #1 and #2 were identified as potential BART-eligible sources as these two ESSROC emission units met all three of the BART-eligible criteria, as listed below:

1.) Identify whether emission units ar e in one of the 26 source categories - ESSROC operates a Portland cement plant, identified as one of the 26 listed categories. 2.) Identify whether emission units were in existence on August 7, 1977 and began operation after August 2, 1962 - The construction date of Kiln #1 was 1971 and Kiln #2 was in existence before August 7, 1977 and operating after August 1962. 3.) Compare potential emi ssions from emission units to 250 tons/y r or more threshold of a visibility impairing pollutant (i.e. sulfur dioxide (SO 2 ), nitrogen oxide (NO x ) and particulate matter (PM)) - Potential NO x and SO 2 emissions from both kilns exceed 250 tons/year of any single visibility impairing pollutant with potential NO x emissions of 3,600.4 tons/yr and potential SO 2 emissions of 12,772.1 tons/yr. Potential PM10 emissions from a ll BART-eligible units at ESSROC totaled 895.1 tons/yr.

Source specific stack and detailed emissions inform ation was requested to be used in IDEM’s BART determination modeling analyses. A BART survey wa s sent to ESSROC, but no response was received from the company; therefore, ESSROC was determ ined to be subject to BART. IDEM conducted preliminary CALPUFF mode ling, in which potential NO x and SO 2 emissions from ESSROC’s Kiln #1 and Kiln #2 were modeled to determ ine the visibility impacts. Resu lts showed the visibility impacts from ESSROC exceeded the BART threshold of 98 th percentile of 0.5 dv with a total of ten days over 0.5 dv for 2002, eight days over 0.5 dv for 2003, and seven days over 0.5 dv for 2004. The cumulative number of days over 0.5 dv for the three year mo deled period was twenty-five days, over the 98 th percentile of the three-year modeled period threshold of twenty-two days.

Trinity Consultants prepared and submitted to IDEM a BART modeling protocol for ESSROC on January 18, 2007. Based on IDEM’s comments and res ponses to comments concerning the protocol, an IDEM-approved protocol was sent to ESSROC on February 15, 2007. The re sponse and additional continuous emissions monitoring (CEM) data for th e revised emission rates that were submitted by53 ESSROC can be found in Appendix 5b. Information gathered from these submittals aided IDEM in conducting a revised CALPUFF modeli ng analysis for ESSROC’s subject to BART determination.

IDEM’s BART modeling process, the modeling domain and meteorology, and the Class 1 areas analyzed are the same as in Section 8.4.

SO 2 , NO x , and PM were modeled using the CALPUFF m odel for the SABIC analysis. Visibility impairing pollutants such as VOCs and ammonia were not modeled, but may be evaluated at a later date. IDEM received the BART exemption submittal from ESSROC on July 20, 2007. The emissions listed in ESSROC’s initial submittal included a proposed plantwide applicability limitation (PAL) for NO x and CEM data from the two kilns. Average 24-hour ma ximum emission rates are preferred for use in the CALPUFF model, consistent with th e Modeling guidance to determine a s ource’s visibility impairment. The emission rates can be found in Table 18.

It should be noted that ESSROC’s initial s ubmittal contained general information on the SO 2 CEM data for Kilns #1 and #2. The submittal showed that from January 1, 2006 through June 28, 2007, the maximum daily average hourly emission rates fo r Kiln #1 was 92.4 lb/hr and for Kiln #2 was 334.2 lb/hr. At IDEM’s request for further informati on, ESSROC’s latest submittal from May 7, 2008 further detailed the CEM data for SO 2 and NO x from Kilns #1 and #2. The highest emitting day from the period reviewed by ESSROC (April 26, 20 06 through March 1, 2008) showed NO x emissions from December 4, 2006 were measured at 17,928 lb/day. The highest emitting day for SO 2 was May 20, 2006 with SO 2 emissions measured at 10,706 lb/day.

Table 18 BART Emission Rates for ESSROC - Speed

Emission Unit Potential NO x Emissions Potential SO 2 Emissions Highest NO x Emission

Rate 1 Highest SO 2 Emission

Rate 1 Highest NO x Emission Rate Highest SO 2 Emission Rate

(lb/hr) (lb/hr) (lb/day) (lb/day) (lb/hr) (lb/hr)

Kiln #1 360.0 1104.0 302.6 37.8

Kiln #2 462.0 1812.0 444.4 408.3

TOTAL 822.0 2916.0 17928.0 10706.0 747.0 446.1

1 Highest emission rates determined from CEM data taken from April 26, 2006 to March 1, 2008

In order to be consistent with previous BART analyses, the ESSROC analysis was run with both stack parameters averaged to give one representative point and also run with each individual stack in one run. Both scenarios were run to determine the overall visi bility impact from ESSROC. The coordinates of the kilns are based on LCC in order to project on the CALPUFF modeling domain. Table 19 shows the stack parameters of Kilns #1 and #2 that were m odeled in CALPUFF. The average of the stack parameters were calculated, in order to replicate the initial BART modeling conducted by IDEM. IDEM’s BART analysis modeled both the indi vidual and averaged stack parameters.54 Table 19 BART-eligible Stack Parameters for ESSROC - Speed Emission Base LLC LLC Stack Stack Exhaust Exhaust
Unit Elevation East North Height Diameter Velocity Temperature (m) (km) (km) (m) (m) (m/sec) ( o K)

Kiln #1 137.16 972.493 -114.574 36.58 2.44 22.16 513.70

Kiln #2 138.07 972.738 -114.621 64.92 2.97 16.31 422.00

AVERAGE 137.62 972.61 -114.60 50.76 2.71 19.24 467.88

8.5.2 ESSROC’s BART Determin ation Modeling Results

ESSROC submitted modeling for its BART determina tion, using information and inputs taken from VISTAS BART Modeling Protocol, MRPO BART Modeling Protocol and IDEM’s CALPUFF input files. ESSROC used a more refined 4-kilomete r CALMET data set taken from 2001 through 2003 as well as a 4-kilometer CALPUFF grid, as supplied by VISTAS. ESSROC’s initial modeling showed visibility impacts lower than the 98 th percentile (8 th highest day of the year) of the 0.5 dv threshold. ESSROC’s revised modeling, submitted on May 7, 2008, took into account the CEM data for Kilns #1 and #2 and showed visibility impacts below the 98 th percentile of the 0.5 dv threshold, as shown in Table 20.

Table 20 ESSROC – Speed’s CALPUFF Modeling Results Impact

Rank 2002 dv (day) 2003 dv (day) 2004 dv (day)

1st 0.698 (81) 0.977 (342) 1.038 (244)

2nd 0.591 (303) 0.697 (60) 1.014 (296)

3rd 0.552 (291) 0.687 (23) 0.614 (274)

4th 0.505 (140) 0.636 (312) 0.552 (56) 5th 0.495 (330) 0.490 (220) 0.529 (179) 6th 0.480 (46) 0.486 (30) 0.426 (270) 7th 0.442(317) 0.485 (311) 0.386 (21) 8th 0.440 (55) 0.428 (99) 0.372 (228)

8.5.3 IDEM’s BART Determination Modeling Results

IDEM based its initial CALPUFF modeling on potent ial emissions from ESSROC’s BART eligible emission units. ESSROC’s initial BA RT exemption submittal indicated SO 2 and NO x emissions were much less than the potential emission calculations. IDEM requested further CEM data from ESSROC. This information was submitted on May 7, 2008. Mode led differences between IDEM’s initial BART determination modeling and ESSROC’s revi sed modeling were a result of lower NO x and SO 2 emission rates for ESSROC’s Kilns #1 and #2, as taken from the CEM data. ESSROC calculated its emissions from available CEM data from the kilns, taken from March 26, 2006 to April 1, 2008. This55 determination met the subject to BART modeling requirements for using the 24-hour average actual emission rate from the highest emitting day.

Table 21 IDEM’s Revised CALPUFF Modeling Results for ESSROC - Speed
Impact

Rank 2002 dv (day) 2003 dv (day) 2004 dv (day)

1st 0.747 (81) 1.033 (342) 1.088 (244)

2nd 0.637 (291) 0.744 (23) 1.083 (296)

3rd 0.581 (303) 0.712 (60) 0.660 (56)

4th 0.573 (317) 0.689 (312) 0.609 (179)

5th 0.537 (140) 0.556 (220) 0.574 (274)

6th 0.517 (46) 0.553 (311) 0.465 (21) 7th 0.463 (330) 0.504 (30) 0.415 (270) 8th 0.456 (55) 0.461 (99) 0.408 (247)

Table 21 above shows IDEM’s revised CALPUFF mode ling results, using the CEM data for Kilns #1 and #2 with the top eight rankings of the highe st dv impacts from ESSROC for 2002 through 2004. There were six days above 0.5 dv in 2002, seven days above 0.5 dv in 2003 and five days above 0.5 dv in 2004. The 98 th percentile for all three modeled years is eighteen days above 0.5 dv, below the twenty-two day threshold for 98 th percentile of the three-year modeled period. While CALPUFF modeled impacts exceeding 0.5 dv, all at Mammoth Cave, the 98 th percentile of modeled impacts were below 0.5 dv and did not exceed the subject to BART threshold.

8.5.4 Summary of ESSROC BART Determination Analysis

ESSROC operates a Portland cement manufacturing facility in Speed, Clark County, Indiana. In accordance with BART Guidelines a nd the criteria for sources which might be BART-eligible, ESSROC was identified as a BART-eligible source. IDEM conducted dispersi on/long range transport modeling of the BART-eligible emissions units from ESSROC a nd determined ESSROC to be subject to BART. Subsequently, ESSROC submitted a BART modeling analysis and thr ough revised emissions and stack parameters, indicated that their CALPUFF modeling showed ESSROC w ould not be subject to BART. IDEM’s review of ESSROC’s modeling analysis and the revised emission rates have shown that ESSROC would not be subject to BART, with the 98 th percentile dv value below the 0.5 dv threshold. Therefore, the BART-eligible units from ESSROC ar e not subject to BART a nd no further analysis is required.

8.6 BART Determination and Modeling for SA BIC Innovative Plastics – Mount Vernon Modeling Project Overview

SABIC Innovative Plastics Mt. Vernon, LLC (SABIC), formerly known as G.E. Plastics, operates a chemical manufacturing facility located in Mount Vernon, Posey County, Indiana. In accordance with56 the BART Guidelines and criteria set forth for BART-eligible sources, SABIC was identified as a BART-eligible source.

IDEM initially conducted long range transport modeling of the poten tial emissions from the BARTeligible emission units from SABIC using the CA LPUFF model. IDEM determined SABIC to be subject to BART for having visibility impacts on n earby Class I areas. Subsequently, SABIC submitted their own BART exemption modeling analysis usi ng the maximum 24-hour av erage actual emission rates and comparing modeled results with the an nual average natural background light coefficient, according to the Modeling Guidance. SABIC con ducted CALPUFF modeling at the nearest Class I areas in which SABIC had the greatest visibi lity impact, which were Mammoth Cave and Mingo Wilderness. These CALPUFF results showed SA BIC was not subject to BART. This document contains IDEM’s review of SABIC’s BART exemp tion modeling analysis and the results of IDEM’s revised BART modeling. IDEM’s CA LPUFF modeling results show that the visibility impairment from the appropriate maximum 24-hour average emission rates of sulfur dioxide, nitrogen oxides, and particulate matter from SABIC’s Mount Vernon facili ty will not exceed thres holds established in the BART Guidelines, and therefore, will not be subject to BART.

8.6.1 IDEM’s BART Determination Process

IDEM sent out BART surveys in the fall of 2005 to sources that we re identified as having possible BART-eligible emission units. SABIC’s B&W, Erie and Lasker boilers, nine of the sixteen carbon monoxide generators, Heater H109, and portions of the transfer and finishing un its were identified as potential BART-eligible sources as these SABIC em ission units met all three of the BART-eligible criteria for SO 2 , NO x , and PM, as listed below:

1.) Identify whether emission units ar e in one of the 26 source categories - SABIC operates a chemical manufacturing plant, identified as one of the 26 listed categories. 2.) Identify whether emission units were in existence on August 7, 1977 and began operation after August 2, 1962 - The construction dates for the BART elig ible emission units at SABIC are as follows: B&W Boiler- 1975, Erie Boiler- 1975, Lasker Boiler- 1962, Riley Boiler- 1962, Heater H109- 1974 and nine of the sixteen existing carbon monoxide generators were estimated in the BART eligibility timeframe. 3.) Compare potential emi ssions from emission units to 250 tons/y r or more threshold of a visibility impairing pollutant (NO x , SO 2 and PM) - Potential NO x and SO 2 emissions from all BART eligible emission units exceed 250 tons/yr of any single visibility impairing po llutant with potential NO x emissions of 2431.7 tons/yr and potential SO 2 emissions of 5644.2 tons/yr. Potential PM 10 emissions from all BART-eligible units at SABIC total 1391.4 tons/yr.

Source specific stack and detailed emissions informa tion were requested to be used in IDEM’s BART determination modeling analyses. A BART survey was sent to SABIC and SABIC submitted the survey results to IDEM on December 6, 2005. IDEM conduc ted preliminary CALPUFF modeling, in which potential NO x and SO 2 emissions from SABIC’s BART eligib le emission units were modeled to determine the visibility impacts. Results showed the visibility impacts from SABIC exceeded the BART threshold of the 98 th percentile of 0.5 dv with a total of nine days over 0.5 dv for 2002, twelve days over 0.5 dv for 2003, and seven days over 0.5 dv for 2004. Based on the information provided, SABIC was determined to be subject to BART.57 SABIC and GZA GeoEnvironmental, Inc. (GZA) met with IDEM staff on February 25, 2008 to discuss the BART modeling results and submitted a BART exemption modeling protocol to IDEM. IDEM reviewed and approved the protocol on February 28, 2007. This protocol can be found in Appendix 5c. GZA prepared the SABIC BART modeling anal ysis, conducted CALPUFF modeling and submitted revised emissions, stack information and the resu lts to IDEM on May 7, 2008. Additional information submitted by SABIC and GZA, also found in Appendix 5c , aided IDEM’s review of SABIC’s subject to BART determination.

IDEM’s BART Modeling Process, the Modeling Do main and Meteorology, and the Class 1 arrears analyzed are the same as in Section 8.4.

8.6.2 Visibility Impairment Pollutants Analyzed

SO 2 , NO x , and PM were modeled using the CALPUFF m odel for the SABIC analysis. Visibility impairing pollutants such as VOCs and ammonia were not modeled but may be evaluated at a later date. SABIC’s submittal included the methodologies for es timating daily emission rates from the boilers and carbon monoxide generators and the emissions for all BART-eligible units at SABIC, as found below in Table 22. Average 24-hour maximum emission rates are preferred in the CA LPUFF modeling analysis to be consistent with the Modeling Guidance determining visibility impairment for BART determinations.

Table 22 BART Emission Rates for SABIC

Emission Unit Maximum Actual Emissions (pounds/hour)

NO x SO 2 PM 10 PM 2.5
B&W (09-001) 1 54.21 117.64 10.81 7.64
Erie Boiler (09-002) 1 81.20 702.82 17.75 15.88
Lasker Boiler (09-002) 1 41.97 363.27 8.24 7.5
Carbon Monoxide Generators COS (08-706) 2 0.62 152.80 0.03 0.007
Riley Boiler (09-106) 17.85 0.11 1.34 1.34
Heater (H109) 1.88 0.011 0.14 0.14
Transfer/Finishing Units 3 0.0 0.0 3.42 0.86

TOTAL 197.7 1336.6 41.7 33.4

1 Maximum actual 24-hour average emission rates estimated from SO 2 emission profile analysis.
2 Nine of the sixteen carbon monoxide generators were cons tructed prior to August 7, 1977.
3 Conservative estimates of fugitive emissions from transfer/finishing units of 15 tons/yr.

SABIC calculated its emissions fr om the Erie, Lasker boilers, a nd the carbon monoxide generators, taking into account the enforceable sulfur input limit, as listed in its Part 70 Operating Permit (T129- 6794-00002). Data was based on the coal bunkered for th e boilers, daily coal sampling, amount of coke58 purchased for feed to COS, and sulfur content of the purchased coke. Nine of the sixteen carbon monoxide generators were built duri ng the BART eligible constructi on period so the emissions from those emission units were ratioed to account for onl y the BART eligible units. The other seven COS units were built after August 7, 1977 and therefore, are not BART eligible.

Table 23 shows the stack parameters of all the BART -eligible sources at SABIC, as well as the area source parameters that define the transfer and finishing area dimensi ons. The coordinates of the SABIC BART eligible emission units are based on LCC in order to project on the CALPUFF modeling domain.

Table 23 BART-Eligible Stack Parameters for SABIC Emission Unit Base Elevation LLC East LLC North Stack Height Stack Diameter Exhaust Velocity Exhaust Temperature POINT Source (m) (km) (km) (m) (m) (m/sec) ( o K)

B&W 122.0 793.329 -195.36 30.48 1.68 48.68 450

Erie & Lasker 122.0 793.29 -195.33 76.2 2.29 21.02 431
Riley 122.0 793.276 -195.36 16.76 1.73 24.75 471

COS 122.0 793.392 -195.30 48.77 1.57 4.37 889

Heater 122.0 793.437 -195.58 22.98 0.99 5.21 644

Base Elevation LLC East LLC North Release Height Area Side Length Initial Vertical
AREA Source (m) (km) (km) (m) (m) (m)

Transfer/Finish 122.0 790.34 -192.17 22.9 201 10.6

8.6.3 SABIC’s BART Determin ation Modeling Results

SABIC submitted modeling for its BART determinati on, using information and inputs taken from the VISTAS BART Modeling Protocol, the MRPO BA RT Modeling Protocol, and IDEM’s initial CALPUFF input files. SABIC used a more refi ned 4-kilometer CALMET data set from 2001 through 2003 as well as a 4-kilometer CALPUFF grid, as s upplied by VISTAS. IDEM’s preliminary CALPUFF modeling used a more conservative extinction coefficient (20% best day natural background), due to the 36-kilometer modeling used by MRPO, rather than an annual average natural background coefficient. SABIC’s use of a more refined 4- kilometer grid warranted the use of average annual natural background concentrations for Class I areas in the eastern Un ited States, pursuant to U.S. EPA’s “Guidance for Estimating Natural Visibility Conditions Unde r the Regional Haze Program” (EPA-454/B-03-005). This approach was accepted by IDEM.

SABIC submitted a permit modification application to IDEM on May 29, 2008, which requested IDEM to remove the provision to burn oil in the B&W Boile r from SABIC's Part 70 Operating Permit. While the B&W boiler is not capable of bur ning residual oil since the oil stor age tank and oil supply system are no longer operable, the oil burning pr ovision still exists in the Part 70 Operating Permit and, therefore, was analyzed for visibility impacts for the BART determination.59 Table 24 below, shows the results of SABIC’ s modeling, submitted on May 7, 2008, July 10, 2008 and August 8, 2008. The CALPUFF results show visibility impacts below the 98 th percentile of the 0.5 dv threshold at the two nearest Class 1 areas, Mammoth Cave in Kentucky and Mi ngo Wilderness Area in Missouri. SABIC modeled above the 0.5 dv threshold on one day in 2001, two days above the threshold at Mammoth Cave and one day at Mingo in 2002, a nd two days above the threshold at Mingo and one day at Mammoth in 2003. The visibility impacts for an individual year or the 3-year cumulative total do not exceed the 98 th percentile of the 0.5 dv thres hold level at any Class 1 areas.

Table 24 SABIC’s CALPUFF Modeling Results over 0.5 dv
Impact

Rank 2001 dv/Location/(day) 2002 dv/Location/(day) 2003 dv/Location/(day)

1st 0.506 at Mammoth (55) 0.657 at Mammoth (347) 0.703 at Mammoth (349)
2nd 0.562 at Mingo (345) 0.575 at Mingo (253)
3rd 0.550 at Mammoth (213) 0.558 at Mingo (53)

8.6.4 IDEM’s BART Determination Modeling Results

IDEM based its initial CALPUFF modeling on pote ntial emissions from SABIC’s BART eligible emission units. The differences between IDEM’s in itial BART determination modeling and the revised modeling conducted from SABIC’s BART exempti on modeling submittals were the maximum 24-hour average emission rate estimates supplied by SABI C. Methodologies expl aining SABIC’s emission calculations are found in Appendix 5c. The emission estimates follow the Modeling Guidance for using the maximum 24-hour average emission rates in the CALPUFF modeling.

Results of IDEM’s revised BART dete rmination modeling show that the 98 th percentile dv impact from SABIC is below 0.5 dv. Table 25 shows IDEM’s revi sed CALPUFF modeling resu lts with the top eight rankings of the highest dv impacts from SABIC for 2002 through 2004. The total number of days which modeled above 0.5 dv for all three m odeled years is seventeen, below the twenty-two day threshold for 98 th percentile of the cumulative three-year modeled period. Ther efore, SABIC’s BART-eligible emission units are exempt from BART.

Table 25 IDEM’s Revised CALPUFF Modeling Results for SABIC
Impact

Rank 2002 dv/Location/(day) 2003 dv/Location/(day) 2004 dv/Location/(day)

1st 1.050 at Mingo (345) 1.004 at Mingo (253) 0.705 at Mammoth (38)
2nd 0.632 at Mammoth (347) 0.827 at Mammoth (349) 0.601 at Mingo (328)
3rd 0.625 at Mammoth (361) 0.707 at Mammoth (263) 0.570 at Linville (15)
4th 0.563 at Mammoth (16) 0.678 at Mammoth (346) 0.569 at Mammoth (14)
5th 0.501 at Mammoth (360) 0.669 at Mammoth (6) 0.522 at Mammoth (30) 6th 0.327 at Mammoth (12) 0.600 at Mingo (252) 0.506 at Hercules (363) 7th 0.311 at Mammoth (213) 0.476 at Mammoth (360) 0.413 at Mammoth (346) 8th 0.311 at Mammoth (351) 0.471at Mammoth (361) 0.394 at Mammoth (289)60 8.6.5 Summary of SABIC BART Determination Analysis

SABIC operates a chemical manufacturing facility in Mount Vernon, Posey County, Indiana. The BART Guidelines in the Federal Register (70 FR 39104) are a component of the Regional Haze regulations, published on July 1, 1999, and are intende d to protect and improve visibility in national parks and wilderness areas. In accordance with 70 FR 39104 and the criteria set forth by U.S. EPA for sources which might be BART-eligible, SABIC was identified as a BART-eligible source. IDEM conducted dispersion/long range transport modeling of the BART-eligible emissions units from SABIC and determined SABIC to be subject to BART. Subsequently, SABIC s ubmitted a BART modeling analysis and through revised emissions, stack para meters, and use of annual average natural background concentrations, indicated that their CALPUFF m odeling showed SABIC’s BART-eligible emissions units would not be subject to BART. IDEM’s revi ew of SABIC’s modeling analysis and the revised emission rates show that SABIC will not be subject to BART, with the 98 th percentile dv value below the 0.5 dv threshold at surrounding Cla ss I areas. Therefore, the BART -eligible units from SABIC are not subject to BART and no further analysis is required.

8.7 BART Determination and Modeling for Alcoa

Of the sources identified as BART-eligible, modeli ng indicated that one n on-EGU source, Alcoa - Alcoa Warrick Operations and Alcoa Power Gene ration (APGI) - are subject to BART. Alcoa submitted a BART analysis in which it developed BART and alternative BART control strategies. Due to technical or economic concerns relating to BART units, the alte rnative requires less emissions reductions from several subject-to-BART units. Howe ver, it proposes to control emissions from Boiler 1 that is not a BART-eligible unit, resulting in greater overall emission reductions. The modeling analysis shows that the alternative also achieve s greater visibility impr ovement than BART. IDEM has reviewed the analyses for completeness and approvability in acco rdance with 326 IAC 26-1, the BART Guidelines, and 40 CFR 51.308(e). The emissi on limits representing BA RT or the alternative to BART will be included in this rulemaking and the Part 70 permit for each unit subject to BART. The completed BART rulemaking will be submitted to U. S. EPA for approval into the SIP. The Alcoa BART analysis is in Appendix 5d. Note that there is an addendum to Appendix 5d that contains updated information provided by Alcoa. The tables in this document use the updated information.

8.7.1 Summary of Alcoa BART Analysis

Alcoa, located in Newburgh, Warrick County, Indiana, is subject to BART. The source submitted a BART analysis in December 2008, in which it developed BART and alternative BART control strategies. Since then, IDEM and the source worked together to address several issues related to the analysis. The alternative achieves a visibility improvement equal to 0.46 dv and an overall improvement in visibility equal to 75% over the baseline. It will be seen in the discussion to follow that sulfates are the major contributor to vi sibility impairment. The alternative, though it achieves gr eater reductions in all pollutants (PM, SO 2 , and NO x ), achieves significantly higher reductions in SO 2 , equal to approximately 21,600 tons. This section briefly describes the Alcoa BART proposal including the BART-eligible units, analysis, and control strategy. This also incl udes four tables: Table 28 shows proposed BART controls, Table 29 shows proposed emission limitations, while Tables 30 and 31 show source culpability toward the highe st estimated visibility impact.61 8.7.2 BART-eligible units at Alcoa

Alcoa identified 18 ingot furnaces, three boilers (B oilers 2, 3, and 4), and five aluminum refining furnaces (Potlines 2-6) as meeting the BART-eligibil ity criteria. Boilers 2 and 3 are classified as industrial boilers. Boiler 4 is classified as an EGU

. Alcoa, in its December analysis addressed PM, SO 2 , and NO x for all its BART-eligible units including Boiler 4. According to the Indiana BART rule, 326 IAC 26-1-5, participation of this boiler in CAIR satisfies the SO 2 and NO x requirements. The BART analysis will therefore address PM only for this boiler.

Boilers 2, 3, and 4 are dry bottom, pulverized coal -fired units. Boiler 2 came online in January 1964, Boiler 3 came online in October 1965, and the cons truction of Boiler 4 st arted on March 16, 1968. Boilers 2 and 3 each had a nominal heat input capac ity of 1,357 MMBtu/hr prior to a recent upgrade to a nominal heat input capacity of 1,589 MMBtu/hr. Bo iler 4 has a nominal heat input capacity of 2,958 MMBtu/hr. Each boiler is equipped with an electrostatic precipitator (ESP) for PM control. Boiler 2 was equipped with a low NO x burner (LNB) and overfire air (OFA ) in 2004, Boiler 3 was equipped with LNB and OFA in 2002, and Boiler 4 was equipped with a LNB in 1998 and a selective catalytic reduction (SCR) system in 2004. Wet flue gas desulf urization (FGD) scrubbers were installed on all boilers in 2008.

Emissions from potlines are captured and controlled with primary controls. Any uncaptured emissions escape through the roof monitors atop the potline bu ildings. The primary cont rols consist of a gas treatment system followed by a fabric filtration system. The total fluoride and particulate removal efficiencies of the control systems are estimated to exceed 99%.

Ingot furnace emissions are uncontro lled. There are several material ha ndling operations at the facility that meet the criteria for beginning operation be tween 1962 and 1977. However, the BART Guidelines require that only those operations at primary aluminum ore reducti on plants that meet the NSPS applicability criteria for this source category should be considered for BART controls. These operations are the potroom groups and anode bake plants. The de partment also identified three (3) ingot furnaces in the Alcoa Title V permit that meet the 1962-1977 timeline criteria but were not included in the analysis. According to Alcoa, one of these furn aces has been physically removed and the other two furnaces did not operate in the baseline years. As di scussed later, based on the impact of the other 18- furnaces included in the analysis, the impact of these furnaces would be negligible.

8.7.3 BART Analysis

Before beginning the five step case-by-case BART analysis, Alcoa performed a baseline visibility impact analysis following a protocol submitted to IDEM. It determined the visibi lity impact for each of the years 2001-2003 using the CALP UFF model with emission rates based on the 24-hour average actual emissions from the highest emitting day. The initial screen ing model projected the highest visibility impact at Mammoth Cave National Park (MCNP). Other Class I areas screened included Mingo Wilderness Area, Sipsey Wilderness Area, Great Smokey Mountains National Park, Joyce Kilmer – Slick Rock Wilderness Area, Cohutta Wild erness Area, and Shining Rock Wilderness Area. The impact at MNCP exceeded 0.5 dv. Since the vi sibility impact was highest at MCNP, the BART analysis was solely based on the impact at MCNP.62 With a few exceptions (as explaine d below), Alcoa followed the following five-steps in its BART analysis, as required by the Indiana BA RT rule and the BART Guidelines:

Step 1- Identify all available retrofit control technologies Step 2- Eliminate technically infeasible options Step 3- Evaluate control effectivenes s of remaining control technologies Step 4- Evaluate impacts and document the results Step 5- Evaluate visibility impacts.

8.7.4 Control Strategy

As stated above, Alcoa proposed an alternative to BART. The alternativ e requires less emissions reductions on some units for technical or economic reasons. However, it propos es to control emissions from Boiler 1 which is not a BART-eligible unit. For example, Alcoa determined SO 2 BART for Boilers 2 and 3 as 92% reducti on, but it proposes to control SO 2 emissions from these boilers by 90% as an alternative. Alcoa currently limits sulfur in the anode grade coke to ≤ 2%. Based on a market study, it has determined that the supply of <3% sulfur c oke cannot be ascertained beyond 2013. Therefore, it proposes BART as ≤ 3% sulfur coke and the alternative as ≤ 3.5% sulfur coke. In the alternative, the source proposes to control SO 2 emissions from Boiler 1 by 91% and NO x emissions at 0.38 lb/MMBtu. The proposed controls and the associated emission lim its are shown in Tables 28 and 29, respectively. As can be seen in Tables 26 and 27, below, the alte rnative achieves greater visibility improvement and emissions reductions.

Table 26 Summary of Visi bility Modeling Analysis Modeling scenario Visibility impact (dv) Average impact (dv) 2001 2002 2003

1. Baseline, BART-eligible units only 1.852 1.906 1.788 1.849

2. BART, BART-eligible units only 0.444 0.299 0.402 0.382

Average improvement 1.467

3. Baseline, BART-eligible units and Boiler 1 2.311 2.774 2.549 2.545

4. Alternative BART 0.686 0.463 0.595 0.581

Average improvement 1.964

Incremental improvement due to alternative control strategy = 0.497 dv63 Table 27 Summary of emissions impa ct of various control scenarios Emissions (tons) Baseline Baseline BART-eligible including Alternative units only BART boiler 1 BART NO x 9,786.35 4,935.68 14,718.72 7,326.55 SO 2 60,268.69 10,062.80 86,171.53 14,373.70 PM 5,717.84 2,680.84 6,594.14 3,353.56

Emissions reductions (tons)

Alternative BART BART Difference NO x 7,392.17 4,850.67 2,541.50 SO 2 71,797.83 50,205.89 21,591.94 PM 3,240.58 3,037.00 203.58

A discussion of the proposed control strategy follows.

8.7.5 Discussion

The BART Guidance does not specify a visibility threshold, cost eff ectiveness ($/ton), or cost/benefit ($/dv improvement) value that a control measure shoul d meet for it to be considered as BART. This analysis therefore proceeded to determine a feasible control strategy on a case-by-case basis, taking into consideration the visibility impact, applicable co ntrol technologies, their cost, and other factors.

1. Highest Contributors to Visibility Impairment Table 30 shows species contribution for each BART-e ligible unit for its highest contribution in any baseline year. Table 31 shows to tal contribution and % species cont ribution for each BART-eligible unit at the highest modeled baseli ne contribution. Staff develope d these tables from the source contribution table provided by Alcoa in its April 2, 2009 communication. It can be seen from these tables that Boilers 2 and 3 are the highest contributors to visibility impairment. In the year of maximum impact, Boilers 2 and 3 contribute approximately 95%, followed by potlines 3%, followed by Boiler 4 equal to 2%, and the contribution from ingot furnaces is zero. Sulfates and nitrates from Boilers 2 and 3 account for 73% and 25% of the impact s, respectively. It will be seen from the discussion to follow that the proposed controls significantly reduce visibility impact and that any addi tional incremental control will be achieved at high cost.

2. Boilers 2 and 3 - SO 2 Alcoa determined BART as wet limestone flue gas desulfurization (FGD) for these boilers at control efficiency equal to 92% and altern ative control as 90% reduction. As an alternative, Alcoa proposes to control SO 2 from Boiler 1 (which is not a BART-eligible unit) by 91%.

3. Boilers 2 and 3 - NO x Alcoa proposes low NO x Burners (LNB) and OFA with an emi ssion limit equal to 0.38 lb/MMBtu as BART and as alternative BART for these boilers. U.S.EPA’s presumptive BART limit for these boiler types is equal to 0.39 lb/MMBtu. Baseline modeling w ithout these controls show s the highest visibility64 impact due to these boilers equal to 0.458 dv, which is projected to decrease to 0.064 dv with the above controls. Alcoa identified Sel ective Non-catalytic Reduction (S NCRs) and SCRs as feasible technologies to control NO x from these boilers; however, it did not perform visibility impact analysis with these technologies. The capital and annual costs of SNCR controls on these boilers are estimated at $3 million and $2.8 million respectively. The capital and annual costs of SCRs are estimated at $70 million and $13 million. Additional controls on these boi lers are likely to yield visibility improvement at a very high cost/ben efit ($/dv improvement).

4. Potlines The maximum impact from these sources is 0.231 dv. This includes contributions due to vents and primary controls. Sulfates are th e main contributors, at approximately 0.188 dv. Contributions due to other species are less than 0.01 dv. Therefore, any a dd-on controls for these pollutants will result in insignificant improvements in visibility. Due to in significant impact from ve nts (0.013 dv), Alcoa did not perform the 5-step analysis fo r these sources. Further, thes e sources are subject to 40 CFR 63, Subpart LL, Maximum Achievable Control Technol ogy (MACT). In order to comply with these standards, Alcoa follows work practices wh ich minimize emissions escaping roof vents.

Sulfur dioxide from potlines can be controlled by lowering sulfur content in the anode grade coke and/or by installing wet scrubbers. Al coa presently limits sulfur at ≤ 2%. From a market study, Alcoa has concluded that a supply of coke below 3% sulfur cannot be ensured beyond 2013, the year when the BART controls will be needed. Therefore it proposes ≤ 3% sulfur coke as BART and ≤ 3.5% sulfur coke as alternative BART. The 3.5% sulfur limit in the coke translates into 2.919% sulfur in the baked anode composite, the practice Alcoa follows to measure the sulfur content.

The installed and annual costs of wet scrubbers on potlines are estimated at $300 million and $55 million respectively. Modeling shows that SO 2 scrubbers on potlines can improve visibility by 0.138 dv. This improvement will be achieved at a cost/ben efit ratio equal to $398 million/dv. Also, there are severe space and access limitations at the faci lity that would complicate the installation.

5. Boilers 2, 3 and 4 - PM The maximum baseline impact due to filterable PM emissions from these sources is 0.035 dv. Alcoa proposes ESPs with an emission limit equal to 0.03 lb/MMBtu as BART contro ls for Boilers 2 and 3. Alcoa determined BART for Boiler 4 as 0.015 lb/MMB tu, but it proposes altern ative BART for this boiler as 0.1 lb/MMBtu. This boiler has a LNB and SCR for NO x control. Alcoa has noticed excessive conversion of SO 2 to SO 3 in the SCR due to the addition of an extra catalyst layer. To reduce SO 3 , which has the potential to adversel y affect the downstream equipment and in order to comply with the sulfuric acid limit in its permit, Alcoa has applied fo r a permit to install a dry reagent injection system between the SCR and ESP. This system will remove SO 3 from the gas stream, but it is expected to adversely affect the performance of the downstream ESP. The impact of this system on the ESP performance is not yet known. To account for this uncertainty, Alco a proposes 0.1 lb/MMBtu as the alternative BART limit. A recent test, after the startup of the SO 2 scrubber on this bo iler, measured an emission rate equal to 0.05 lb/MMBtu which includes PM and sulfuric acid.

The above limits are projected to lower the contri bution from Boilers 2, 3, and 4 to approximately 0.005 dv. Alcoa identified fabric filters as feasible cont rol technology for these boilers. However, estimating that these controls will not significan tly improve visibility, it did not perform cost and visibility impact65 analyses with these controls. It roughly estimated the cost of fabric filters on these boilers at $97.18 million. This estimate is based on the cost of a fabric filter installed on a utility boiler. Alcoa estimates that installation of fabric filters on these boilers will improve visi bility by 0.024 dv at a cost/benefit ratio equal to $445 million/dv.

6. Ingot furnaces The maximum baseline impact from these sources is 0.003 dv . Due to insignificant impact from these sources, Alcoa did not perform a 5-step BART analysis for these sources.

Table 28 Alcoa Proposed BART Control Strategy

Emission unit BART Alternative BART Boiler 1 not a BART-eligible unit PM ESP

SO 2 wet FGD with 91% emissions reduction efficiency NO x LNB with staged OFA Boilers 2 and 3 PM ESP ESP

SO 2 wet FGD with 92% emissions reduction efficiency wet FGD with 90% emissions reduction efficiency NO x LNB with staged OFA LNB with staged OFA

Boiler 4 - PM ESP ESP

Potlines - Fugitive emissions PM no add-on control no add-on control SO 2 limit anode grade coke to 3% sulfur limit anode grade coke to 3.5% sulfur NO x no add-on control no add-on control - Primary emissions

PM gas treatment system followed by fabric filter gas treatment system followed by fabric filter SO 2 limit anode grade coke to 3% sulfur limit anode grade coke to 3.5% sulfur NO x no add-on control no add-on control

Ingot Furnaces no add-on control no add-on control66 Table 29 Alcoa Proposed BART Emission Limits

Emission unit Emission limit Compliance demonstration method Boiler # 1 PM (filterable) 0.03 lb/MMBtu, 24-hour daily
average CEMS at the scrubber outlet according to PS-11, 40 CFR Part 60, Appendix B

SO 2 91% reduction, 24-hour daily
average CEMS at the scrubber inlet and outlet, according to 40 CFR Part 60, following Appendix B, PS-2

NO x 0.38 lb/MMBtu, 24-hour daily average CEMS at the scrubber outlet, following PS-2

Boilers 2 and 3 PM (filterable) 0.03 lb/MMBtu, 24-hour daily
average CEMS at the scrubber outlet according to PS-11, 40 CFR Part 60, Appendix B

SO 2 90% reduction, 24-hour daily
average CEMS at the scrubber inlet and outlet, following PS-2

NO x 0.38 lb/MMBtu, 24-hour rolling average CEMS at the scrubber outlet, following PS-2

Boiler #4 PM (filterable and sulfuric acid) 0.1lb/MMBtu The compliance method is according to 40 CFR 60, Appendix A, Method 5

Potlines 2-6 PM (filterable) 0.005 grains/scf The compliance method is according to 40 CFR 60, Appendix A, Method 5

SO 2 The sulfur content in each monthly baked anode composite shall not exceed 2.919%, provided however that hourly SO 2 emissions from the potlines shall not exceed 1,456 lbs/hr. on a combined basis, and determined on a monthly basis. ASTM D3177-02, modified by adding saturated bromine water before the pH adjustment. Alternatively, determination of sulfur content by x-ray fluorescence.67 Table 30 Highest Contribution from BART-e ligible Units in any Modeling Scenario

Contribution (dv)BARTeligible unit Year of maximum contribution Modeling scenario Sulfates Nitrates Filterable PM 2.5 Filterable PM 10 Condensable Total

Boilers 2 and 3 2002 Baseline:BARTeligible units +boiler 1 1.331 0.458 0.014 0.000 0.011 1.814

Boiler 4 2002 Baseline:BARTeligible units +boiler 1 0.021 0.000 0.010 0.031

Potlines 2003 AlternativeBARTBARTeligible units +boiler 1 Vents 0.003 0.000 0.004 0.001 0.005 0.013 Primary controls 0.185 0.002 0.005 0.000 0.008 0.200

Ingot furnaces 2003 Baseline:BARTeligible units only 0.000 0.003 0.000 0.000 0.000 0.00368 Table 31 Source Culpability for the Highest Baseline Impact

Year of maximum impact 2002

Modeling scenario: Baseline with BART-eligible units and boiler 1

BART-eligible unit (s) Contribution (dv) Total contribution (dv) % contribution % species contribution Boilers 2 and 3 1.814 95.17% Sulfates 1.331 73.37% Nitrates 0.458 25.25% Filterable PM2.5 0.014 0.77% Filterable PM10 0 0.00% Condensables 0.011 0.61% Boiler 4 0.031 1.63% Filterable PM2.5 0.021 67.74% Filterable PM10 0 0.00% Condensables 0.01 32.26% Potlines Vents Sulfates 0.001 0.004 0.21% 25.00% Nitrates 0 0.00% Filterable PM2.5 0.001 25.00% Filterable PM10 0 0.00% Condensables 0.002 50.00% Primary controls 0.057 2.99% Sulfates 0.05 87.72% Nitrates 0.001 1.75% Filterable PM2.5 0.002 3.51% Filterable PM10 0 0.00% Condensables 0.004 7.02% Ingot furnaces 0 0.00% Sulfates 0 Nitrates 0 Filterable PM2.5 0 Filterable PM10 0 Condensables 0 Total contribution 1.906 100.00%69 8.8 Indiana BART Rule

On November 3, 2010, the Indiana Air Pollution Contro l Board adopted as final the Indiana BART rule, 326 IAC 26-2. It includes the limits li sted in the section above. It will become effective three to four months after this date. Th e rule is found in Appendix 7.

9.0 Long Term Strategy

9.1 Strategy requirements

Federal provisions at 40 CFR 51.308(d)(3 ) require Indiana to include in its SIP a long-term strategy that addresses regional haze visi bility impairment for each mandatory Class 1 Federal area which may be affected by emissions from Indiana sources. The long- term strategy must include enforceable emissions limitations, compliance schedules and other measures ne cessary to achieve the reasonable progress goals established by the states or tribes where the Class 1 areas are located. The strategy must be based on consultation with the states with Class 1 areas impacted by Indiana emissions and must be based on factors such as ongoing air polluti on programs, smoke management techniques for agricultural and forestry management purposes, source retirement and replacement schedules, and emission limitations and schedules for compliance to achieve the reasona ble progress goals. This section describes how Indiana plans to meet its l ong-term strategy obligations.

9.2 Discussion

Indiana does not have any Class 1 areas; however, emissions from Indiana were determined to impact Class 1 areas in other states. Indi ana consulted with those states to develop reasonable progress goals. The consultation with other states and Federal Land Ma nagers is explained in de tail in Sections 2 and 3 respectively. Indiana consulted wi th other states and tribes by pa rticipation in the MRPO Regional Haze Workgroup calls and other MRPO discussions to develop technical info rmation necessary for development of coordinated strategies. Indiana also coordinated with CENRAP and MANE-VU to develop a weight of evidence analysis that was used to develop Indiana’s long-term strategy. Strategy development considered the impacts of Indiana’s em issions on Class 1 areas out side of Indiana. The emission inventory and modeling used to develop reasonable progress go als are described in detail in Sections 4.0, 5.0, and 6.0. The results of Class 1 area analyses are desc ribed in detail in Section 7.0. The analyses show no reductions from Indiana sour ces, beyond the BART rule, are necessary to meet the reasonable progress goals of the areas analyzed at this time.

Indiana has in place a number of programs to contro l pollution from stationary and mobile sources. Some of the measures include Reasonably Availa ble Control Technology (R ACT) on particulate and VOC sources, measures in the Rate of Progress Plans (RFPs) to meet the 1-hour ozone NAAQS, NO x SIP Call, and CAIR. As described in Section 8, I ndiana has a fully adopted CAIR rule, which will be replaced by the newly proposed Clea n Air Transport Rule, which will provide additional reductions. Indiana is currently work ing on additional programs such as the revised PM 2.5 and 8-hour ozone NAAQS. These programs will further reduce Indiana’s contribu tion to Class 1 areas in othe r States.

In Indiana, prescribed burning must be conducted in accordance with state law under Indiana Code (IC) 13-17-9 and regulations under 326 IAC 4- 1. County or local ordinances ma y also apply in some parts of70 the state. In addition, the Indian a Department of Natural Resources (IDNR) has developed a fact sheet on prescribed burning that includes smoke manage ment recommendations (Appendix 6). Prescribed burning of state-owned land by IDNR is allowed under 326 IAC 4-1-3(c), but must be extinguished if it creates a pollution problem. Prescribed burning al so may not be conducted during unfavorable weather conditions, including when a pollution alert or ozone action day has b een declared. Most burning of agricultural land is exem pt from regulation.

9.3 Strategy

As explained above, at this time, reductions in Indiana emissions from the BART rule and other programs are sufficient to meet the reasonable progress goals in other states. However, to continue to assist those states in meeting th eir reasonable progress goals and to minimize its contribution to those states, Indiana commits to the following actions:

1. Effectively enforce the existing control measures. 2. Work with U.S. EPA and other states and re gional planning organizations to address multipollutant air quality problems in the eastern and northeastern U.S. 3. Continue consultation with states with Class 1 areas to monitor their progress in meeting their reasonable progress goals and develop co ordinated strategies, as and when needed, to mitigate visibility impacts in those areas.

10.0 State Implementation Plan Revisions and Adequacy of the Existing Plan

10.1 State Implementation Plan Revisions

The federal rule at 40 CFR 51.308(f) requires Indiana to revise its regional haze implementation plan and submit a plan revision to U.S. EPA by July 31, 2018, and every ten years thereafter. In accordance with the requirements listed in 40 CFR 51.308(f) of th e federal rule for regional haze, Indiana commits to doing this.

In addition, 40 CFR 51.308(g) requir es periodic reports evaluating progress towards the reasonable progress goals established for each mandatory Class 1 area. In accordance with the requirements listed in 40 CFR 51.308(g) of the federal rule for region al haze, Indiana commits to submitting a report on reasonable progress to U.S. EPA every five years following the initial submittal of the SIP. The report will be in the form of a SIP revision. The reason able progress report will evaluate the progress made towards the reasonable progress goal for each ma ndatory Class 1 area which may be affected by emissions from Indiana sources. All requirements lis ted in 40 CFR 51.308(g) sh all be addressed in the SIP revision for reasonable progress.

10.2 Determination of the Adequacy of the Existing Plan

Depending on the findings of the five-year progress repo rt, Indiana commits to taking one of the actions listed in 40 CFR 51.308(h), “Determination of the ad equacy of existing implementation plan”. The findings of the five-year progress re port will determine which action is appropriate and necessary. The actions in 40 CFR 51.308(h) include the following:71 (1) If the state determines that the existing implementation plan requires no further substantive revision at this time in order to achieve esta blished goals for visibility improvement and emissions reductions, the state mu st provide to the Ad ministrator a negativ e declaration that further revision of the existing implementa tion plan is not needed at this time. (2) If the state determines that the implementation plan is or may be inadequate to ensure reasonable progress due to emissions from sources in anothe r state(s) which participated in a regional planning process, the state must pr ovide notification to the Administ rator and to the other state(s) which participated in the regional planning pr ocess with the states. The state must also collaborate with the other stat e(s) through the regional planni ng process for the purpose of developing additional strategies to address the plan's deficiencies. (3) Where the state determines that the implementati on plan is or may be inadequate to ensure reasonable progress due to emissions from sources in another country, th e state shall provide notification, along with available in formation, to the Administrator. (4) Where the state determines that the implementati on plan is or may be inadequate to ensure reasonable progress due to emissions from sources within the state, the state shall revise its implementation plan to address the pl an's deficiencies within one year.

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