### Indiana Department of Environmental Management

Michael R. Pence Govenwr



### Mr. Robert Kaplan Acting Regional Administrator We Protect Hoosiers and Our Environment. 100 N. Senate Avenue • Indianapolis, IN 46204 (800) 451-6027 • (317) 232-8603 • www.idem.IN.gov



### March 31,2016 Carol S. Comer Commis simwr



### U.S. Environmental Protection Agency Region 5 77 West Jackson Boulevard Chicago, IL 60604-3950

Dear Mr. Kaplan: Re: State Implementation Plan Submittal for Indiana Regarding 1-Hour S0 2 

### Attainment A.B. Brown Generating Station in Posey County, Indiana (Commissioner's Order #2016-01) Addendum Documentation of the Public Participation Process

Pursuant to Section 110 of the Clean Air Act (CAA) and Title 13 of the Indiana Code (IC), the Indiana Department of Environmental Management (IDEM) submits an amendment to the Indiana state implementation plan (SIP) for the A.B

. Brown Generating Station accomplished by Commissioner's Order #2016-01. IDEM submitted a request for parallel processing of the amendment to Indiana's SIP on January 27, 2016. The public comment period commenced on January 13, 2016 and concluded on February 16, 2016

. IDEM conducted a public hearing concerning the proposed SIP revision on March 23, 2016. The attached enclosure consists of the following:

• Commissioner's Order #2016-01 issued on January 11, 2016, that establishes permanent and e nforceable sulfur dioxide (S0 2) 

### emission limits for A.B. Brown, located in Posey County, Indiana, in order to ensure continued attainment of the 2010 primary 1-hour S02 

### standard in the area surrounding the facility. The Commissioner's Order contains emission limitations for Units 1 & 

### 2, as well as reporting and record keeping requirements and method for compliance. The effective date for the emission limitations in the Commission e r's Order is April 19 , 2016. It contains and meets the requirements set forth in 42 U.S .C

. 

### § 7407(d)(3)(E)(iii) and the conditions will become applicable requirements as defined in 326 Indiana Administrative Code (lAC) 2-7-1.

• Administrative checklist and modeling summary.

An Eq ua l Opportunity E mploye r 

# 0 Please Redu ce , Re use , Recycle A State**th at~** 

### Mr. Robert Kaplan Page 2 of 2

• Documentation of the public participation process including: (1) A transcript of the public hearing and record of all comments

. (2) A summary of and response to substantive comments. This submittal consists of one (1) hard copy of the required documentation. An electronic version of the submittal in PDF format that is identical to the hard copy has been sent to Doug Aburano, Chief of U

.S. EPA Region 5's Attainment Planning and Maintenance Section and Chris Panos of U.S. EPA Region 5. IDEM requests that U.S. EPA proceed with review and approval of this amendment to Indiana's SIP. If you have any questions or need additional information, please contact Brian Callahan, Chief, Air Quality Standards and Implementation Section, Office of Air Quality at (317) 232-8244 or bcallaha@ idem .I N

.gov.

KB/sd/mad/bec/gf Attachments: Supporting Documents Sincerely, 

# f?-xrD-r Keith Baugues Assistant Commissioner Office of Air Quality

· cc : Doug Aburano, U.S. EPA Region 5 (no enclosures) John Mooney, U.S. EPA Region 5 (no enclosures) Steve Rosenthal, U.S. EPA Region 5 (no enclosures) Pamela Blakley, U.S. EPA Region 5 (no enclosures) John Summerhays, U.S. EPA Region 5 (no enclosures) Chris Panos, U.S. EPA Region 5 (no enclosures) Jennifer Liljegren, U.S. EPA Region 5 (no enclosures) Keith Baugues, IDEM-OAQ (no enclosures) Scott Deloney, IDEM-OAQ (no enclosures) Mark Derf, IDEM
-OAQ (no enclosures) Brian Callahan, IDEM
-OAQ (no enclosures) Mike Mosier, IDEM-OAQ (no enclosure) Christine Pedersen, IDEM-OAQ (no enclosures) Jessica Reiss, IDEM-OAQ (no enclosures) File Copy

### Supporting Documents

Attachment 

### A: Administrative Checklist (40 CFR 51, Appendix V) Attachment B: Commissioner's Order #2016-01 Attachment C: Public Participation Documentation Attachment D: Modeling Summary Data, calculations and methodology for determining 24-hour rolling average S0 2 

### emission limits based on A.B. Brown's continuous emission monitoring data (available upon request).

# Attachment A Administrative Checklist

### ADMINISTRATIVE CHECKLIST (40 CFR 51, Appendix V) 

### 1. The submittal is accompanied by a f01malletter of submittal from the governor or his designee. 2. Evidence that the State has adopted the plan in the State code or body ofregulations; oi· issued the pe1mit, order, consent agreement ("document"); in final form.

a. Date of adoption or final issuance: b. The effective date ofthe plan, ifdifferent from the adoption/issuance date. 3. Evidence that the State has the necessary legal authority under state law to adopt and implement the plan. 4. A copy ofthe actual regulation or document submitted for approval and incorporation by reference into the plan, including the following:

a. Indication ofthe changes made to the existing approved plan, where applicable. b. The submittal shall be a copy ofthe official State regulation or document signed, stamped, dated by the appropriate state official indicating that it is fully enforceable by the State. Effective date shall be stated in the document itself. 5. Evidence that the State followed all ofthe procedural requirements ofthe State's laws and constitution in conducting and completing the adoption/issuance ofthe plan. 6. Evidence that public notice was given, including date of proof ofpublication. 7. Certification that public hearings were held in accordance with information provided in public hearing notice. 8. Compilation ofpublic comments and State's response. 9. Technical Support Document (if source specific change). Enclosed

Attaclunent B

f 

### January 11,2016 April 19, 2016

IC 13-14-1-9 IC 13-14-2-1 Attaclunent B

Attaclunent B

Attaclunent C

Attaclunent C

Attachment C Attachment D

# Attachment B Commissioner's Order for A.B. Brown Generating Station addressing the 1-hour S02 

# NAAQS Posey CountyIDEM INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT We Protect Hoosiers and Our Environment.

Michael R. Pence**Go~·cJ110r** 100 N

. Senate Avenue • Ind ia n apolis , IN 46204 (800) 451-6027 • (317) 232-8603 • \WJW.idem.IN.gov carols. comer Cummlsslu11er STATE OF INDIANA COUNTY OF MARION

. ) ) SS: ) BEFORE THE INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
IN THE MATTER OF : ) ORDER OF THE COMMISSIONER ) PURSUANT TO IC 13-14-2-1 ) FOR A.B. BROWN GENERATING STATION ) OF INDIANA ) )

NOTICE AND ORDER OF THE COMMISSIONER OF THE DEPARTMENT OF ENVffiONMENTAL MANAGEMENT This Notice and Order of the Commissioner of the Department of Environmental Management ("Order") is issued pursuant to Indiana Code ("IC") 13-14-1-9, IC 13-14-2-1, and IC 13-14-2-7. During the Commissioner's review, it was determined that the Petition should be granted according to the terms specified below: PETITION Petitioner is Southern Indiana Gas and Electric Company (SIGECO) A.B. Brown Generating Station ("Petitioner"), a sta tionary electric power plant with Source J.D. Number 129-00010, located at 8511 Welborn Road in Mount Vernon, Posey County, Indiana, and permitted under the Palt 70 air operating permit program. On March 2, 2015, the U.S. District Court for the Northern District ofCalifornia accepted a Consent Decree between the U.S. Environmental Protection Agency ("U.S. EPA"), the Sierra Club, and the Natural Resources Defense Council

. to resolve litigation concerning deadlines for completing 1

-hour sulfur dioxide ("S02") National Ambient Air Quality Standard ("NAAQS") designations. Under the Consent Decree, U.S. EPA must designate certain areas as nonattainment, attaimnent, or unclassifiable in tlu·ee phases. The first Consent Decree phase requires U.S. EPA to designate areas that contain stationary sources that had not been atmounced for retirement as o(March 2, 2015 and either emitted more than 16,000 tons ofS02 in 2012 or emitted more than 2,600 tons ofS02 and had an ammal average emission rate of more than 0.45 pounds of S02 per one million British thermal units ("lb/MMBtu") in 2012, according to U.S. EPA's Air Quality Markets Database. On March 20, 2015, U.S. EPA identified five (5) sources in Indiana that met the criteria for the first phase of Consent Decree designations. U.S. EPA's list included the Petitioner, A.B. Brown Generating Station.

An cqun l Opportuni ty employer 

# 0

AState**th ~**  

### (i} R ec

ycl e d PaperCommissioner's Order No 2016-01 Page 2 of 5

On September 16, 2015, the Indiana Department of Envirorunental Management ("IDEM") recommended designation of the area sul1'ounding A.B. Brown Generating Station as attainment. The recommendation was based on modeling that included a permanent and enforceable S02 emission limitations and emission rates at A.B. Brown Generating Station. On December 21, 2015, the Petitioner submitted a request to the Commissioner to impose permanent and enforceable S02 emission limitations and emission rates on the Petitioner in order to ensure continued attainment of the S02 NAAQS in the area surrounding A.B. Brown Generating Station. · The Petitioner proposed S02 emission limitations, expressed in S02 lb/MMBtu, and emission rates, expressed in S02 pounds per hour ("lb/hr"), applicable to both Unit No. 1 and Unit No. 2, as follows:

a. 0. 363 lb/MMBtu, twenty-four (24) hour rolling average; b. 1831.6 lb/hr, twenty-four (24) hour rolling average; and

c. 2152.2lb/hr, one (I) hour average. 

### FINDINGS Pursuant to IC 13-14-2-1(b) and lC 13-14-2-7(1), the Commissioner may issue Orders to secure compliance with Indiana's environmental statutes and rules, including the ambient air quality standard for 802 at 326lndiana Administrative Code ("lAC") 1-3-4(b)(1)(A). Based on the foregoing information, IDEM finds the following: 1. Petmanent and enforceable S02 emission limitations and emission rates for A.B. Brown Generating Station are required in order to model continued attainment of the !-hour S02 NAAQS in the area surrounding the Petitioner. 2. Adding S02 emission limitations and emission rates to the Petitioner's Part 70 Operating Permit is not adequately permanent to assure continued attainment ofthe S02 NAAQS. Instead, a Commissioner's Order is required to**~nsure** S02 emission limitations and emission rates remain permanent and enforceable, as required by 42 U.S.C. 

### § 7407(d)(3)(E)(iii). 3. Approval by U.S. EPA of the Commissioner's Order into the Indiana State Implementation Plan ("SIP") is required to make Order requirements federally enforceable. Upon approval into the Indiana SIP, the Order requirements become applicable requirements as defined in 326 lAC 2-7-1(6). 4. Based on modeling conducted by IDEM, the S02 emission limitations and emission rates proposed by the Petitioner must be clarified and adjusted in order to assure continued attainment ofthe S02 NAAQS.Commissioner's Order No 2016-01 Page 3 of5



### ORDER 1. This Order approves the Petition submitted by the Petitioner according to the tenus specified below. This Order imposes on the Petitioner the 

### S02 emission limitations and emission rates described below. 2. When Unit No. 1 is operating alone, the unit shall not exceed 

### S02 emission limitations and emission rates as follows:

a. 2152.2 lh/hr, one (1) hour average or emission rate of 0.855 lh/MMBtu, one (1) hour average; and b. 1831.6 lh/hr, twenty-four (24) hour rolling average or emission rate of 0.727 lh/MMBtu, twenty-four (24) hour rolling average. 3. When both Unit No. I and Unit No. 2* are in operation, both units shall not exceed combined 

### S02 emission limitations and emission rates as follows:

a. 2152.2 lb/hr, one (I) hour average or emission mte of 0.426 lb/MMBtu, one (1) hour average; and b. 1831.6 lb/ln·, twenty-four (24) hour rolling average or emission rate of 0.363 lh/MMBtu, twenty-fom (24) hour rolling average. 4. When Unit No.2* is operating alone, the unit shall not exceed 

### S02 emission limitations and emission rates as follows:

a. 1745.7 lb/hr, one (1) hour average or emission rate of 0.690 lb/MMBtu, one (1) hour average; and h. 1485.59 lb/lu·, twenty-four (24) hour rolling average or emission rate of 0.588 lb/MMBtu, twenty-four (24) hour rolling average. *Pursuant to PSD (65) 1355 issued on February 22, 1979, Unit No.2 shall not exceed an 

### S02 emission limitation of 0.69 lb/MMBtu, thirty (30) day rolling average. The 

### S02 emission limitation applies to Unit No. 2 whenever Unit No. 2 is operating; this includes when Unit No. 2 is operating alone and when both Unit No. 1 and Unit No. 2 are in operation. 5. The Petitioner shall comply with the 

### S02 emission limitations and emission rates beginning April 19, 2016. 6. As required by 326 lAC 2-7-2(d)(l) and 326 lAC 2-7-5, the Petitioner shall apply to incorporate Order requirements, including reporting and recordkeeping requirements and methods to determine compliance, into its Part 70 Operating Permit within ninety (90) days of U.S. EPA approval ofthe Commissioner's Order into the Indiana SIP.Commissioner's Order No 2016-0l Page 4 of5



### 7. From April 19, 2016 until IDEM issues a Permit incorporating Order requirements, the Petitioner shall comply with the reporting and recordkeeping requirements and methods to determine compliance specified in this paragraph.

a. Reporting: The Petitioner shall submit to IDEM, on a qumterly basis, a report of the daily maximum twenty-four (24) hour S02 rolling average for Unit No. I, for Unit No. 2, and for Unit No. I and Unit No. 2 combined. b. Recordkeeping: The Petitioner shall maintain records adequate to document compliance with the S02emission limitations and emission rates.

c. Method to determine compliance: Compliance shall be determined by a continuous emission monitoring system in accordance with 326 lAC 3-5. 8. This Order shall apply to and be binding upon the Petitioner, its successors and assigns. No change in ownership, corporate, or partnership status ofthe Petitioner shall in any way alter its status or responsibilities under this Order. 9. The requirements of this Order supersede any less stringent requirements applicable to the Petitioner. 

### EFFECTIVE DATE OF ORDER Pursuant to IC 13-14-2-l(d), IC 4-21.5-3-1, IC 4-21.5-3-5(a)(6), and 40 Code ofFederal Regulations ("CFR") 51.102, IDEM will give notice of this Order to each entity to whom the Order is directed and affected neighbors by mailing and to the general public by web publication. Pursuant to IC 4-21.5-3-7(a)(3), IC 4-21.5-3-2(e), and IC 4-21.5-3-5, this Order may be appealed by filing a Petition for review within eighteen (18) days after the date affected persons were given notice of the Order by U.S. mail. Information on petitions for review of this Order can be foundatlC 4-21.5-3-7. Pursuant to IC 4-21.5-3-5(£) and IC 4-21.5-3-2(e), the Order is effective eighteen (18) days from mailing of notice unless a Petition for review has been filed before or on the eighteenth (18 1 h) 

### day. However, the compliance date for the emission limitations in this Order is Aprill9, 2016. Pursuant to 40 CFR 51.103, IDEM will submit this Order to U.S. EPA as a revision to the Indiana SIP. Upon approval by the U.S. EPA, this Order will be pat1 ofthe Indiana SIP. Persons seekingjudicial review ofthis Order may do so in accordance with IC 4-21.5-5.Commissioner's Order No 2016-01 Page 5 of5

If you have procedural or scheduling questions regarding your request for review, you may contact the Office ofEnvironmental Adjudication at (317) 232-8591. If you have questions regarding this Order, please contact Mark Dert; Office ofAir Quality, by telephone at (317) 233- 5682 or email at MDERF@idem.IN.gov. Dated at Indianapolis, Indiana this

### __ill~:_ day ofJanuary, 2016.

taro! S. Comer Commissioner Indiana Department ofEnvironmental Management

# Attachment C Public Participation Documentation

### ~th

# bh,**EM** Indiana Department of Environmental Management

Df;,RSARY
Michael R. Pence Govenw r We Protect Hoosiers and Our Environment. 100 N. Senate Avenue • Indianapolis , IN 46204 (800) 451-6027 • (317) 232-8603 • www.idem

. IN

.gov



### Legal Notice for Public Hearing State Implementation Plan (SIP) Submittal A.B. Brown Generating Station in Posey County Commissioner's Ordet· No 2016-01 Carol S

. Comer C

ommi ssi011er

Notice is hereby given under 40 CFR 51.102 that on March 23, 2016, at 6:00PM CDT, at the Mount Vernon Fire Station Training Room, located at 311 College Avenue, Mount Vernon, Indiana 47620, the Indiana Department ofEnvironmental Management (" IDEM") will hold a public hearing regarding a revision to the Indiana state implementation plan (SIP) for Southern Indiana Gas and Electric Company, A.B. Brown Generating Station, Source l.D. Number 129- 00010, located at 8511 W**~!born** Road, Mount Vernon, Posey County, Indiana. The purpose of this hearing is to receive public comment on a proposed revision to the SIP that is accomplished by Commissioner's Order No. 2016-01 for A.B

. Brown Generating Station. The Commissioner's Order imposes sulfur dioxide emissions limits and emissions rates upon A.B. Brown Generating Station. This Commissioner' s Order will be submitted to the United States Environmental Protection Agency (" U.S. EPA") for approval as a revision to the Indiana SIP. All interested persons are invited and will be given reasonable opportunity to express their views concerning the proposed revision to the SIP to incorporate sulfur dioxide emission limits and emission rates concerning A

.B. Brown Generating Station. Oral statements will be heard and transcribed, but, for the accuracy of the record, all comments should be submitted in writing. Additional information regarding this action may be obtained from Mark Derf, Air Programs Branch, Office ofAir Quality, (317) 233

-5682. Individual s requiring reas onable accommodations for participation in this event should contact the Indiana Department ofEnvironmental Management, Americans with Disabi lities Act coordinator at: Attn: ADA Coordinator Indiana Department ofEnvironmental Management Indiana Government Center North 100 North Senate Avenue Indianapolis, IN 46204-2251

or call (317) 233- 17 85 (V). Speech and hearing impaired callers may contact IDEM via the Indiana Relay Service (711) or (800) 743

-3333. Please provide a minimum of72 hours notification. A copy ofthe Commissioner's Order is available to any person upon reque st and is available for public inspection at the following location s :

A n Equal Opportun ity Employ e r 

# 0 Please Red uce , Reu se , Recyc le A Sta le**hat~**Indiana Department of Environmental Management Office of Air Quality Indiana Government Center-North 100 North Senate Avenue IOth Floor Indianapolis, Indiana 46204. and Indiana Department of Environmental Management Southwest Regional Office I 

### J20 Notth Vincennes Avenue Petersburg, Indiana 47567. and Alexandrian Public Library 115 West Fifth Street Mount Vernon, Indiana 47620. The Commissioner's Order is also available on the IDEM website at: http://www.in.gov/idem/4686.htm. For additional information, please contact Mark Derfat the contact inf ormation provided below. Mark Derf Indiana Department ofEnvironmental Management Office ofAir Quality 100 North Senate Avenue Mail Code 61-50 IGCN 1003 Indianapoli s, Indiana 46204 Phone: (317) 233-5682 Fax: (317) 233-2342 E-mail: MDERF@idem.IN.gov.INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT We Protect Hoosiers and Our Environment. 100 N

. Senate Avenue • Ind ianapo lis, IN 46204 (800) 451 -6027 • (317) 232-8603 • www.idem

. IN

.gov Michael R. Pence Gm•ernor Ca rol S. Come r Commissioner

January 1 3,2016



### CERTIFICATE OF PUBLICATION This is to certify that the Indiana Department ofEnvironmental Management (IDEM) notice of public comment period and opportunity for a Public Hearing regarding the following:



### • Commissioner's Order #2016-01 foa· A.B. B.-own Generating Station ofIndiana

was published on IDEM 's web s ite on January 13, 2016. It is expected that it will remain posted on the s ite until at least February 1 6,2016. The notice in full was also made available the same day online at the following web address, under "Commi ssioner's Orders". http: //www.in

.gov/idem/4686.htm Web publication of the notice was at the request ofScott Deloney, Branch Chief , Programs Branch, Office ofAir Quality, IDEM.

Attachments: Copy ofweb page as published

.

An E q ual Oppor tunity Employer By :

Mike Finklestein IDEM Webmaster 

# 0

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o Notice and O rder of the Commissioner of t he Department of Environmental Management IPDFl [l • l egal Notice of Publ ic Hearing IPDF] [l Commissioner's Order 12.014-01 for Jeffboat LLC:

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- Harding Street Generating Station: Notice O rder and Variance of the Commissioner of the oeo artm e nt o f Environmental Management IPOFl [l • IPL Legal Notice o f Comment P eriod and Opoortunity to Recuts! a Publ ic Hearing IOOCI f3

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## In the Matter Of 

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.B

. Brown Generating Station ofIndiana



# PUBLIC HEARING March 23, 2016

CONNOR REPORTING 111 Monument Ci rcle , Suite 4350 Indianapolis, IN 46204 Phone: 317-2 36 -6022 Fax: 31 7- 236- 601 5 To ll Free: 800-554-3376

### 1 STATE OF INDIANA Public Hearing March 23, 2016

2 

### COUNTY OF MARION SS BEFORE THE INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 3 4 

### IN THE MATTER OF: 5 ORDER OF THE COMMISSIONER PURSUANT TO 13-14-2-1 6 FOR A.B. BROWN GENERATING STATION OF INDIANA 7 8 9 

### 10 PUBLIC HEARING 11 Report of proceedings of the public hearing with 12 regard to the A.B. Brown Generating Station in Posey 13 County, Commissioner's Order No. 2016-01, held March 23, 14 2016 at the Mount Vernon Fire Station Training Room, 311 15 College Avenue, Mount Vernon, Indiana. 16 17 18 19 

### 20 21 22 23 24 25
Connor Reporting www.connorreporting.com 317.236.6022

### 2 

### 1 2 3 4 5 6 7 

### 8 9 10 11 

### 12 13 

### 14 15 16 17 18 19 20 21 22 23 24 25 Public Hearing March 23, 2016 

### START TIME: 6:00 P.M.

HEARING OFFICER DERF: We have 6 o'clock. If I could have everybody's attention, we'll go ahead and get started. This is a public hearing to provide interested persons an opportunity to provide comments to the State regarding the proposed revision to the Indiana State Implementation Plan for Vectren's A.B. Brown Generating Station, Source ID Number 129-00010. It's located at 8511 Welborn Road, Mount Vernon, Posey County, Indiana. This hearing is being held to conform to the provisions of 40 Code of Federal Regulations Part 51.102 regarding public hearings for 2



### State Implementation Plan submittals. This hearing is not an opportunity to revise previously-adopted rules. My name is Mark Derf. I'm a Section Chief in the Technical Support and Modeling Section of the Indiana Department of Environmental Management, Office of Air Quality. I've been appointed to act as Hearing Officer for this public hearing. I would like to introduce Scott Deloney of IDEM's Office of Air Quality; Jessica Reiss of the Office of Legal Counsel; and Courtney Arango, our Communication Director of the Office of Program Support. They are Connor Reporting www.connorreporting.com 317.236.6022

### 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Public Hearing March 23, 2016 here to help with these proceedings. As you came in, a sign-in sheet was located in the back of the room for interested parties to be recognized for participating in the hearing. For those interested in providing comments today, please fill out the appearance cards that have been distributed in the room. If you have not already filled out a card, please do so, as Scott is showing, and indicate if you're appearing for yourself or on behalf of a group or organization and identify such group or organization; also note the capacity in which you appear, whether you're appearing as an attorney,

an officer, or an authorized spokesperson. Any person who is heard or represented at this hearing or who requests notice may be given written notice of the final action taken on this State Implementation Plan revision. Please indicate on the appearance card if you wish to receive this notification. When appearance cards have been completed, they should be handed to me or Scott, and I will include them with the official record for this proceeding. Oral statements will be heard. Written statements may be handed to us. Due to the potential high volume of commenters, a time limit on oral 3**4~CONNOR.** 

### V:,**r~EPOR'riNG** Connor Reporting www.connorreporting.com 317.236.60224 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Public Hearing March 23, 2016
comments of five minutes will be applied, in order to

ensure that all commenters are afforded an opportunity to be heard. I request that each commenter be mindful and respectful of this time limit. Scott will provide notification to each commenter when one minute of the allotted time remains, as well as when the allotted time has elapsed. If time allows at the end of the hearing, commenters who submitted appearance cards and wish to add to their previous oral statements may be able to submit additional comments. A written transcript of this hearing is being made. The transcript will be open for public inspection, and a copy of the transcript will be made available to any person upon payment of the copying cost. At this time, I would like to introduce the following documents into the record: First, we have the Notice of Public Hearing. Second, we have the Commissioner's Order. It's No. 2016-01 for A.B. Brown Generating Station, imposing sulfur dioxide emission limits and emission rates, addressing area designations under the 2010 one-hour sulfur dioxide standard. And finally, I would like to briefly go over IDEM's proposed revision to the State Implementation 4

Connor Reporting www.connorreporting.com 317.236.6022

### 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Public Hearing March 23, 2016 Plan. On June 2nd, 2010, the United States Environmental Protection Agency, the US EPA, revised the primary National Ambient Air Quality Standard for sulfur dioxide, better known as S02. The US EPA revoked both the previous 24-hour and annual primary S02 standards and established a new one-hour S02 standard at a level of 75 parts per billion, based on the three-year average of the annual 99th percentile of the one-hour daily maximum concentration. The US EPA studies have linked shorter-term exposure to S02 to respiratory impacts in humans. On Augus t 5th, 2013, the US EPA published a notice, announcing designations of 29 areas in 16 states as not attaining

-- we'll refer to those as nonattainment)

-- the 2010 primary one -hour S02 National Ambient Air Quality Standard , based on ambient a ir qua lity monitoring data for the years 2009 through 2011 that showed that these areas w ere violating that standard. The US EPA designated four

areas in Indiana as nonat tainment of the 2010 primary

one -hour S02 National Ambient Air Quality Standard. IDEM addressed those four areas through revision of S02 emission limi tations in the Indiana Rules at 326 Indiana Administrative Code Article 7. IDEM has reque s ted the US EPA approve these rule revisions into 5



## £CONNOR**REPORTING** Con nor Reporting www .connorreportin g .com 317.236.60226 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Public Hearing March 23, 2016 the Indiana State Implementation Plan and provided an attainment demonstration, showing that after the effective date of the Indiana Rules, the areas will meet the 2010 one-hour S02 standard. The US EPA is currently reviewing the State Implementation Plan revision and attainment demonstration. On March 2nd, 2015, the US District Court of the Northern District of California accepted, as an enforceable order, an agreement between the US EPA Sierra Club and the Natural Resources Defense Council to resolve litigation concerning the deadline for completing air quality designations for the remainder of the country. The court's order directed the US EPA to complete remaining designations in three additional rounds: Round 2 by August 2nd, 2016; Round 3 by December 31st, 2017; and Round 4 by December 31st, 2020. The US EPA will complete these designations by designating areas as either nonattainment, attainment,

or unclassifiable. The court order directed the US EPA to designate two groups of areas under Round 2 of the air quality designations: First, areas that have newly-monitored violations of the 2010 primary S02 National Ambient Air Quality Standard during the years 2012 through 2014; and second, areas that contain any stationary 6



## JACONNOR.**~** 

### ltEPOR'lrMNG Connor Reporting www.connorreporting.com 317.236.60227 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Public Hearin g March 23 , 20 16

sources that, according to the US EPA Air Quality Markets Database, either emitted more than 16,000 tons of S02 in 2012 or emitted more than 2,600 tons of S02 and had an annual average emission rate of at least 0.45 pounds of S02 per million British Thermal Units in 2012 and that had not been announced as of March 2nd, 2015 for retirement. In response to the court's order , the US EPA identified f i ve coal-fired, electric generating power plants in Indiana on March 20th of 2015 as meeting Round 2 criteria established in the court's order

. One of the electric power plants ident i fied was A.B

. Brown Generating Station of Posey County. As a result of the court order, states we r e given until September 18th, 2015 to submi t updated

r ecommendations and supporting information for area designations to the US EPA. IDEM conducted air dispersion mode ling to e valuate A

. B

. Brown ' s 2 012 through 2014 actual emissions, in order to characterize the a ir quality s urrounding the source . Initial modeling was conducted based on US EPA ' s S02 National Ambient Air Quality Standard Designations Mode ling Technic a l As s i s tance Document and other US EPA modeling guidance , a nd took into account A

. B. Brown's S02 continuous emission monitoring data from 7



## £CONNOR**REPORTING** Connor Reporting www.connorreporting .com 317.236.60228 1 2 3 4 5 6 7 8 9 10 11 1 2 13 14 15 16 17 18 19 20 21 22 23 24 25 Public Hearing March 23, 2016 Units 1 and 2, as well as emissions from nearby S02

sources. Temporally-varying seasonal S02 background concentrations taken from a nearby S02 m onitor were included in the model runs to accurately characterize air quality in the area. The US EPA guidance recommends that sources not causing significant concentration gradients in a vicinity of the source of interest would be included in the model via monitored background concentrations

. On September 16, 2015, IDEM supplemented to the US EPA designation recommendations for all five years mentioned in the court order, meeting the court-orde red deadline

. IDEM • s recommendation was to designate the area surrounding A.B. Brown Generating Station as attainment. The recommendation was based

on the air dispers ion modeling that included proposed enforceable S02 emission limitations a nd emission rate s on Units 1 and 2 at A.B. Brown Generating Station. The US EPA reviewed Indiana •s designation recommendations and commented that the one -hour S02 emission limits did indeed s how attainment; however, the emission limits were not considered permanent and federally enforceable at that point in time and must first be incorporated into the Indi ana State Implementation Plan. 8



## £CONNOR**REPORTING** Connor Re porting www.connorreporting.com 317.236

.6022

### 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Public Hearing March 23, 2016 On December 21st, 2015, A.B. Brown voluntarily submitted a request to the Commissioner of IDEM to impose S02 emission limitations and emission rates through a Commissioner's Order that would be permanent and federally enforceable once the limits were incorporated into the Indiana State Implementation Plan. This action would ensure continued attainment of the one-hour S02 National Ambient Air Quality Standard in the area surrounding A.B. Brown Generating Station. IDEM reviewed this request and issued a Commissioner's Order on January 11, 2016 to establish permanent and enforceable S02 emission limits for A.B. Brown. The Commissioner's Order contains the following emission limitations in pounds of S02 per million British Thermal Units and emission rates in pounds of S02 per hour for A.B. Brown's Units 1 and 2, which are reduced slightly from the limits requested. First, when Unit 1 is operating alone, the unit shall not exceed S02 emission limitations and emission rates as follows: "A" is 2, 152.2 pounds per hour, based on a one-hour averaging period, or emission rate of 0.855 pounds per million British Thermal Units based on a one-hour averaging time; and "B", 1,831.6 pounds per hour based on a 24-hour rolling average 9



## AA CONNOR. lllLREPORTftN(; Connor Reporting www.connorreporting.com 317.236.602210 Public Hearing March 23, 2016 

### 1 period, or emission rate of 0.727 pounds per million 2 British Thermal Units based on a 24-hour rolling 3 average. 4 When both Units 1 and 2 are in operation, both 5 units shall not exceed combined 802 emission 6 

### limitations and emission rates as follows: "A", 

### 7 2,152.2 pounds per hour, based on a one-hour average 8 period, or emission rate of 0.426 pounds per million 9 British Thermal Units based on a one-hour averaging 10 period. And "B", 1,831.6 pounds per hour based on a 11 24-hour rolling average period, or emission rate of 12 0.363 pounds per million British Thermal Units based 13 on a 24-hour rolling average. 14 3: When Unit No. 2 is operating alone, the unit 15 shall not exceed 802 emission limits and emission 16 rates as follows: "A", 1, 745.7 pounds per hour on a 17 one-hour averaging period, or emission rate of 0.69 18 pounds per million British Thermal Units based on a 19 one-hour average. And "B", we have 1,485.59 pounds 20 per hour based on a 24-hour rolling average period, or 21 emission rate of 0.588 pounds per million British 22 Thermal Units based on a 24-hour rolling average. 23 In addition, the order incorporates reporting and 24 recordkeeping requirements and methods of compliance 25 for the 802 emission limitations. The effective date 10



## £CONNOR 

## U.- REPORTING Connor Reporting www.connorreporting.com 317.236.602211 Public Hearing March 23, 2016 

### 1 for the emission limitations in the Commissioner's 2 Order is April 19th, 2016. In order to make the 3 emission limitations and emission rates federally 4 enforceable, they must be incorporated into the 5 Indiana State Implementation Plan, which is what IDEM 6 has proposed to do. 7 On February 16th, 2016, in accordance with the 8 Round 2 consent decree timeline, the US EPA submitted 9 letters and technical support documents to the states, 10 detailing its intentions on designating areas under 11 the one-hour S02 standard based on the states' 12 recommendations. The US EPA valued IDEM's modeling 13 approach, found it to be acceptable to establish 14 emission limitations that would provide for 15 attainment. While the US EPA has preliminarily 16 recommended the area surrounding A.B. Brown as 17 nonattainment, the US EPA does acknowledge the efforts 18 made by IDEM and A.B. Brown to establish permanent and 19 federally-enforceable S02 limits that will reduce the 20 amount of S02 emissions emitted from A.B. Brown and 21 characterize air quality in the surrounding area as 22 continuing to attain the one-hour S02 National Ambient 23 Air Quality Standard. Incorporation of the emission 24 limitations established in the Commissioner's Order 25 into the Indiana State Implementation Plan will make 11

Connor Reporting www.connorreporting.com 317.236.602212 Public Hearing March 23, 2016 

### 1 the S02 limits federally-enforceable and permanent. 2 This will ensure S02 emissions from A.B. Brown will be 3 lower and provide assurance that air quality 4 surrounding A.B. Brown Generating Station will 5 continue to attain the one-hour S02 standard. The US 6 EPA will promulgate its final S02 area designation and 7 designate the area surrounding A.B. Brown as 8 attainment no later than July 2nd, 2016. 9 The sole purpose of this public hearing is to 10 collect public comment on the incorporation of the 11 emission limits contained in the Commissioner's Order 12 No. 2016-01 into Indiana's State Implementation Plan 13 in order for those limits to become permanent and 14 enforceable. It is worth noting that the 15 Commissioner's Order itself is a final agency action. 16 IDEM is not accepting comment on that action or the 17 limits contained therein; rather, the incorporation of 18 those limits in the Indiana State Implementation Plan. 19 This concludes my comments regarding the proposed 20 revision to the Indiana State Implementation Plan for 21 A.B. Brown Generating Station, located in Mount 22 Vernon, Posey County, Indiana. 23 Before opening this hearing for public comment, 24 may I once again remind you that this hearing pertains 25 to this proposed revision to the Indiana State 12

Connor Reporting www.connorreporting.com 317.236.602213 Public Hearing March 23, 2016 

### 1 Implementation Plan and only comments germane to this 2 matter will be considered as part of the public record 3 and addressed within the agency's final action. 4 Upon submission, the US EPA will be responsible 5 for reviewing Indiana's request for a State 6 Implementation Plan revision. The Clean Air Act 7 provides the standard for approval of State 8 

### Implementation Plan revisions in Section llO(L) A 

### 9 revision to the State Implementation Plan is 10 approvable unless it will interfere with attainment of 11 any National Ambient Air Quality Standard or any other 12 requirement of the Clean Air Act. Comments concerning 13 whether the imposition of new, additional sulfur 14 dioxide emission limits and the emission rates upon 15 A.B. Brown Generating Station does or does not 16 interfere with any National Ambient Air Quality 17 Standard or any other requirement of the Clean Air Act 18 would be germane to the US EPA's designation process 19 and consideration of Indiana's State Implementation 20 Plan revision. 21 Those interested in commenting on whether these 22 limits are adequate to demonstrate attainment of the 23 one-hour S02 standard are advised to comment on the US 24 EPA's Responses to Designation Recommendations 25 published in the Federal Register at 81 Federal 13



## £CONNOR 

## '4l!L REPORTit,S(;lJ Connor Reporting www.connorreporting.com 317.236.6022

### 14 Public Hearing March 23, 2016 

### 1 Register page 10563 on March 1st, 2016. Comments are 2 due on that action by March 31st, 2016. The US EPA 3 also will publish a separate Federal Register notice, 4 soliciting comment on Indiana ' s request to revise the 5 State Implementation Plan to incorporate the emission 6 limits within Commissioner ' s Order No. 2016-01 upon 7 Indiana ' s final submission. 8 

### Okay. We will be available following this 9 hearing to address any questions you may have that do 10 not pertain this specific matter. I would say this 11 hearing is now open for public comment. We ' ve 12 rec eived comments and a list of folks who would like 1 3 to provide oral statements. 14 MR

. DELONEY: Again, my name is Scott Deloney, 15 and I'll be calling on individuals that have submitted 16 a card to speak. One thing I do ask is, we want to 1 7 m ake sure that the official record for this h earing 18 properly reflects your name as well as the comments 19 that you share this evening. So I would request, if 20 you wouldn ' t mind coming to this corner of the room so 21 our court reporter is able to properly reflect your 22 s t atem e n t for this evening. 23 The first comment card that I have is for miss 24 Wendy Bredhold

. 25 MS. BREDHOLD: Thank you for being here today. 14



## £ CONNOR**REPORTING** Connor Re porting www .connorreporting

.co m 317.236

.6022

### 15 Public Hearing March 23, 2016 

### 1 My name is Wendy Bredhold. I'm an Evansville 2 resident, and though I am now employed by the Sierra 3 Club, which called for this hearing, I came to this 4 issue 10 years ago when I learned that I live in a 5 heavily-polluted region of the country; and now as a 6 mother whose daughter attends daycare near Vectren's 7 A.B

. Brown plant, I am particularly concerned about 8 its dangerous levels of sulfur dioxide pollution. 9 Sulfur dioxide can trigger an asthma attack in as 10 little as five minutes

. And if you picked up an 11 Evansville Courier 

### & Press today, you saw that the 12 annual Not

- A

- Gonna

- Whee z e asthma camp was on the front 1 3 page . Too m a ny c hildre n a nd adults in our r egion 14 strugg l e with as thma and other respiratory and 1 5 cardi ovascular disease s exacerbated by pollution; and 16 sulfur dioxide n eeds to be adequately addressed to 17 protect public health. 18 Sierra Cl ub ' s a n a lysi s s hows that the plan that 19 IDEM and Vectren have come up with to control for 20 sulfur dioxide for A.B

. Brown does not go far enough. 21 The sulfur dioxide limits a r e based on fl a wed m od e ling 22 that wil l not ensure that the concentration of air 23 pollution s tays be l ow the health standard. It is 2 4 assumed that t h e plant will n ever exceed t h e e mi ss ion s 2 5 limi t

-- an unrealistic assumption given that A.B. 15



## £CONNOR**REPORTING** Connor Re porting www.connorreporting.com 3 1 7.236.602216 Public Hearing March 23, 2016 

### 1 Brown has violated its current sulfur dioxide limit in 2 recent years. 3 The plan does not take into account other major 4 producers of sulfur dioxide in the area, such as 5 Alcoa's Warrick and Vectren's E.B. Culley plants in 6 Warrick County, Duke Energy's plant in Gibson County, 7 and Big Rivers' Robert D. Green plant in Webster 8 County, Kentucky. And the proposed limits allow A.B. 9 Brown to emit sulfur dioxide pollution right up to the 10 standard; so any errors in their analysis could tip 11 the area into unhealthy air. The plan should have a 12 reasonable margin of error, given that public health 13 is at stake. 14 And as a Vectren rate payer, I don't understand 15 why I'm paying the highest electric rates in the 16 state, a premium rate, for a product that threatens my 17 family's health. And the costs of these plants will 18 continue to increase if Vectren must comply with 19 additional safeguards intended to protect our health 20 and environment. Vectren makes it very clear, when 21 addressing its shareholders, that it will seek to pass 22 all of those costs

-- potentially hundreds of 23 millions

-- on to us the, rate payers. 24 And this isn't reflected in my written testimony, 25 but I also question

-- our rate payer money was 16**~.CONNOR.** 

### 1111.![. 

### R.EPOR1'1NG Connor Reporting www.connorreporting.com 317.236.602217 Public Hearing March 23, 2016 

### 1 invested in scrubbers that have been installed on 2 those units at A.B. Brown. Why are they not 3 protecting us from this pollution? Why aren't those 4 scrubbers that have been installed reducing the 5 pollution and keeping it at a place that's not too 6 harmful to our house? 7 In conclusion, for years Vectren rate payers have 8 been told that the reason that we pay the highest 9 rates in Indiana is that Vectren has invested our 10 money in processes that reduce pollution. But as this 11 hearing clearly demonstrates, we can't put enough of 12 our money into these plants to prevent them from 13 harming our health in one way or another. 14 

### HEARING OFFICER DERF: Thank you. 15 

### MR. DELONEY: The next commenter I have is Niles 16 Rosenquist. 17 

### MR. ROSENQUIST: I have written comments. Some 18 of what I have to say is going to be redundant. I'm 19 here mostly to support the Sierra Club's comments that 20 Wendy has referred to already. 21 Sierra Club had two

-- from reading their 22 comments, they had two primary areas of complaint 23 against this plant. One was the modeling; and, as 24 

### Wendy mentioned, the fact that major sources of 802 

### 25 pollution from nearby counties, the big power plants 17

Connor Reporting www.connorreporting.com 317.236.602218 Public Hearing March 23, 2016 

### 1 up in Gibson County and in Warrick County, were not 2 included in the modeling. There•s no particular 3 reason I can see why they weren•t included. Maybe, 4 you know

-- common sense argument here is that, you 5 know, you may be thinking they•re just negligible 6 contributors to Posey County•s air quality. A l ot of 7 people find

-- they•re very skeptical of that, and I 8 would just cut to the quick and say I think the IDEM 9 should redo their modeling study and include those 10 sources, just to prove one way or another. You can 11 prove it•s wrong. we•re skeptical that that sulfur 12 dioxide isn•t crossing the county line

. You could 1 3 prove us wrong and redo the m odel ing a n d show us it 14 didn•t make any differe nce or , alternative ly, if in 1 5 fact that sulfur dioxide is impacting Posey County•s 16 air , of course that aff ects substantially the baseline 17 that•s u sed whe n you start cal culating the new 18 emission limit s for the Vec tren pl a nt. 19 The other big point that Sierra C lub m ade was 20 that the assumption seems to be that the Vectren plant 2 1 always runs under s t abl e operating conditions. Of 22 course, tha t•s no t true for any industrial plant. You 23 have maintenance issues, you h ave e quipment fai lure, 24 you have start -up and shut-down conditions. These 25 need t o be taken into considerat ion. 18



## £CONNOR**REPORTING** Connor Reporting www.con norreporting. co m 31 7 .236 .602219 Public Hearing March 23, 2016 

### 1 My simple-minded suggestion here is that Vectren 2 should supply historical data, maybe two or three 3 

### years worth, of their emissions data just a 4 thought

-- pounds of sulfur dioxide per million BTU on 5 a 24-hour basis; and just an average person could look 6 at those numbers and see how Vectren has been doing 7 both in terms of variability due to all of these 8 operation variables and, of course, they could also 9 always pick out the specific numbers where Vectren has 10 exceeded its current requirements

. 11 And going forward

-- I think maybe this is too 12 simple, but you could just do statistics on that day, 13 a standard deviation and mean, and get a pretty good 14 est imate of the variabi lity going forwar d and 15 Vectren's capability, and that estimate could be 16 figured into a new requirement to be protective not 17 only during stable operations but would be protective 18 enough so that even when these inevitable incidents of 19 unstabl e oper at ions a nd vari abi lity in the 802 20 e missions come into play, the air quality would still 21 be protected. 22 I guess that ' s what I have to say . 23 HEARING OFFICER DERF: Thank you. 24 MR. DELONEY: Next up we have Mr. Mark Bryant. 25 MR. BRYANT: Good evening. H e llo everyone. My 1 9



## £CONNOR**REPORTING** Connor Reporting www .co nnorreporting.com 3 17 .236

.602220 Public Hearing March 23, 2016 

### 1 name is Mark, Bryant and I am making these comments 2 representi ng two groups. First of all and foremost , 3 I 'm a resident of Posey County. A ls o, I a m a m ember 4 of Val l eyWatch based in Evansvi lle, Indiana, whose 5 mission is to protec t the health and e nvi ronment of 6 those who live in t h e lower Ohio Val ley. 7 Vectren charges its rate payers the highest rates 8 anywhere in the state, while they cont inue to dump an 9 excessive amount of toxic and unhealthy pollutants 10 into the surrounding community. The amount of 11 respiratory and cardiovascular disease in Posey County 12 bears testament to the increased level of pollution 13 residents s u ffer. 14 The Indiana Department of Environmental 15 Man agement is fa iling to live up to its mis s ion to 16 implement federal and state regulations to protect 17 human h ealth by allowing a c l early weake r 18 environmental standard than one required to adequately 19 protect human health in the area a r ound the Posey 20 County A.B

. Brown Power Generating Station. IDEM 21 recently is sued an order, designating Posey County as 22 in attai nment for sulfur d i oxide emi ssions, even 23 though this area has historical ly exceeded EPA s ulfur 24 dioxide emission standards. 25 IDEM'S order fai l s to protect human h ealth due to 20



## £CONNOR V.. REPORTING Connor Reportin g www. co nnorreportin g.com 3 17 .236.602221 Public Hearing March 23, 2016 

### 1 the basis that the order uses to set sulfur dioxide 2 emission limits from the A.B

. Brown Power Generating 3 Station

. As a resident of Posey County, I must remind 4 this panel that designating the geographic area around 5 the A

. B

. Brown Posey County facility as in attainment 6 will condemn members of my family to a greater and 7 needless health risk than what a stricter sulfur 8 dioxide emissions limit would allow. 9 One cannot assume IDEM 1 

### s modeling is accurate, 10 since IDEM failed to disclose any information in the 11 final order about their modeling effort

. There are 12 many methods IDEM could have used to set a realistic 13 sulfur dioxide emi ssions threshold rather than the 14 m ode ling method it c h ose . At the very l east , IDEM 1 5 could have ordered an audit of the procedures and 16 equipment at the A.B. Brown faci lity to independently 17 verify if the installed scrubber technology could meet 18 a stricter sulfur dioxide standard by scrubbing the 19 emitted efflue nt h arder. 20 This is the same captured r e gulation story that 21 causes so much devastation in the health of our 22 communities and to our most vulnerable populations. 23 The cozy relationship that has developed between 24 utilities and those that are requi red to act in the 25 public interest is responsible for ongoing tragedies 21



## £ CONNOR**REPORTING** Connor Reporting www .connorreporting.com 317.236.602222 Pub li c Hearing March 23, 2016 

### 1 such as the poisoning of water supplied in Flint, 2 Michigan. Vectren officials even admit that Indiana 3 has a very favorable regulatory environment. 4 Vectren has known for many years that its A.B. 5 Brown power p lant would exceed the newer EPA sulfur 6 dioxide emissions threshold, and even though they 7 charge some of the highest residential electric rates 8 in the country, they chose to offer only one solution 9 for their sulfur dioxide emission discharge action. 10 Vectren chose to solve their sulfur dioxide discharge 11 problem by petitioning a user-friendly IDEM to simply 12 i ssue a s ul f ur dioxide discharge thr eshold they could 13 eas ily meet, without regard for the h ealth of those 14 that li ve in the surrounding community. 15 Since Vectren ha s repeatedly failed to
. provide a 16 reasonabl e sul fur dioxide e missions solution on its 1 7 own, 

### it is IDEM's duty and responsibility to work with 18 Vectren and other organizations to develop and 19 initi ate a plan to protect the public health. 20 Thank you fo r l e tting m e submit these comments. 21 HEARING OFFICER DERF: Thank you . 22 MR. DELONEY: Thank you very muc h. 23 We ' ve been very fortunate that, this evening so 24 far, we ' ve all been able to stick within our time 25 limit. I will give you a n ot ification if the re is 22



## £CONNOR 

## U.. REPORTING Connor Reporting www .connorreporti ng .com 317.236.602223 Public Hearing March 23, 2016 

### 1 only one minute remaining, just so you are aware. 2 Next up we have Mr. John Blair. 3 

### MR. BLAIR: Again, thank you for having this 4 hearing. I think that you know it would probably have 5 gone under the radar had Sierra Club not requested a 6 hearing. 7 ValleyWatch

-- I'm here representing ValleyWatch. 8 ValleyWatch's purpose is to protect the public health 9 and environment of the lower Ohio river valley, and 23



### 10 sometimes we win, sometimes we lose. This isn't a 11 healthy place to live, and I think people understand 12 that. 13 The S02 standard that we're dealing with here

-- 14 I'm proud to say ValleyWatch was a part of suing the 15 EPA to get them to do the standard again, because they 16 hadn't done it for 25 years when we sued them in

-- 17 actually, it was about 2008, I think we sued them, and 18 it was finalized around 2010. We were with the Center 19 for Biological Diversity, which is an excellent group 20 based in California, too. 21 I am submitting the Earth Justice Sierra Club's 22 comments as ValleyWatches comments here too. I want 23 to make sure that that's done, as well as a Media 24 Advisory from April 16th, 1999, because frankly, I'm 25 really concerned with IDEM's credibility on this
Connor Reporting www.connorreporting.com 317.236.6022

### 24 Public Hearing March 23, 2016 

### 1 modeling. In 1999, Mr. Derf was caught with his pants 2 down, literally

-- wel l, not lite rally

-- by 3 manipulating data in order to grant a permit for 4 ConAgra to build a large soybe an processing facility 5 just west of the A.B. Brown plant ; and when that data 6 was looked at into the point of the Source Code and 7 everything, it was found that they h ad chan ged som e 8 figures in the Source Code

. Well, I 'm not a modeling 9 expert, so I 'm not capable of go ing into that , but I'm 10 cert a inly going to notify the EPA t o look into the 11 Source Code of t h e modeling Mr. Derf has done, because 12 our experience in southwestern Indiana

- - and 13 particularly in that particular area -- shows that he 14 was wi lling to

-- I woul d call it fraud 15 fraudulently manipulate t he data in order to 16 accomplish his goal, whi c h at that time was issuing a 17 permit t o ConAgra. In this case , I think it ' s he's 1 8 willing to manipulate t he data in order to show that 19 that area shoul d b e attainm ent under the s ul f u r 20 dioxide standards

. And t h ere ' s not m uch other 21 evidence beside s his modeling that would indicate 22 that. 23 So that ' s part of t he com ments which w e just 24 fi l ed , i s a -- particularly a letter which was 25 addressed to Janet M cCabe, who is n ow the Assistant 24



## £ CONNOR**REPORTING** Connor Re portin g www.connorreporting.com 3 17 .236 .6022

### 25 Public Hearing March 23, 2016 

### 1 EPA person for Air, and it talks all about it, and I 2 think that it's pretty self-explanatory. I have one 3 more copy of it, if somebody would like to see that 4 letter. 5 We feel that

-- we're happy that there's lower 6 802 emission limits put on this facility. It's about 7 time. That plant was built

-- the first one carne on 8 

### line, I believe, in 1979; 

### the second one maybe a 9 couple years later, and at the time, it was 10 

### state-of-the-art. But it's not 1980 

### anymore. It's 35 11 

### years later and not much has been done to improve the 12 scrubber technology there. So, we're in a situation 13 where most new facilities or newer facilities are 14 being required to meet a much lower limitation than 15 these emission rates allow. Even at the best, it's 16 these are 50 

### percent higher than the ones that Sierra 17 

### Club's modeling finds should be. 18 

### MR. DELONEY: One minute, Mr. Blair, just to give 19 

### you a heads up. 20 

### MR. BLAIR: Okay. If I quit being interrupted, 21 I'll be able to do that. 22 So, these emission rates are too high, and 23 through conversations I've had with a variety of 24 people, I also found that all this has been pretty 25 much initiated by IDEM, and I suspect the reason for 25

Connor Reporting www.connorreporting.com 317.236.602226 Public Hearing March 23, 2016 

### 1 that is because they want to continue to brag 2 worldwide that they meet all the emissions limits, all 3 the National Air Quality Standards all over the 4 country, they meet them in Indiana, every one of them. 5 And it just isn't so. 6 Was that within the time limit, Mr. Deloney? 7 

### MR. DELONEY: You had eight seconds left. 8 We do have two more speakers, and it looks like 9 we may end up having additional time if anyone wishes 10 more time for the floor. 11 Shelby Heck. 12 MS. HECK: My name is Shelby Heck. I've been a 13 student at USI for the past three years. I've been 14 living on campus every year. 15 

### Growing up, I was always taught to respect nature 16 and love its beauty that it has; and coming to USI and 17 coming to Evansville, I really found it a beautiful 18 place, like seeing the dogwoods in the spring and the 19 tulips also. I mean, I just really fell in love with 20 the campus and also the people of the Evansville 21 community. I found myself going to Tin Man Trivia and 22 Bar Louie dollar burger nights on a regular basis with 23 all of my friends, and I always talked to the people 24 still in high school I knew and I told them how much I 25 loved USI and loved Evansville and loved being a 26

Connor Reporting www.connorreporting.com 317.236.602227 

### 1 student here. Publi c Hea ri ng March 23 , 2 016



### 2 Bu t as I got a lit t le older , I started taking 3 more c l asses in ethics and partic i pating in Ethics 4 Bowl ev ery year and a l so getting involved with the 5 Sierra Club and environmental movements, and I learned 6 that Evansville is not as rosy as it looks. It's 7 actual ly very polluted, and the pol l utants that we ' re 8 breathing are actually very dangerous to us . 9 I didn ' t realize this when I first started going 10 to USI. I didn't know

. What I saw was, you know, 11 beau ti ful and wonderfu l, and then I just get shocked 12 in my thi rd year -- technically my senior y ear of 13 college. I get shocked with this information that the 14 air I have been breathing for the past three years 15 hasn 't even m et EPA standards? I was just floored. 16 The danger was invisible to me and invisible to 17 everyone e ls e . 18 As a student leader on campu s, I felt for t he 19 students that are coming after m e . I felt for those 20 who have asthma and breathing-related illnesses

. I 21 wondered , like, what the i r experi ences would be like 22 living on campus for four, five maybe even six 23 

### years 

### -- if they ' re taking it easy 

## -- and breathing 24 

### this air with these emission leve l s that were so high, 25 these pol lution levels that were so high. I feel for 27



## £CONNOR Q:. 

## REPORTING Co nn or Reportin g www.connorreporti ng .com 3 1 7.236.6022

### 28 Pub lic Hearing March 23, 2016 

### 1 those students coming after me. 2 While at one time I could say I had no 3 reservations about coming to USI, I now look back and 4 I wish I would have known. I wish I would have known 5 senior year that the air that I would be breathing for 6 the next three to four to five years was this 7 polluted. And it makes me mad. It makes me angry 8 that I did not know that and that all of the students 9 at USI do not know that. 10 

### So, I think it's time for Vectren to take some 11 

### responsibility for their actions and some 12 responsibility for the role that they have played in 13 these S02 levels being so high and to mitigate this 14 problem they have created and added to. 15 Thank you. 16 

### HEARING OFFICER DERF: Thank you. 17 

### MR. DELONEY: The next comment card I have is for 18 Bartell Berg. 19 

### MR. BERG: Thank you to Sierra Club for 20 

### requesting this hearing

. 21 So, my name is Dr

. Bartell Berg. I am a parent 22 of two beautiful daughters, and my wife and I searched 23 long and hard for a new home with some property so 24 that our daughters could play outside safely, so they 25 could explore the forest, so they could learn from 28



## £ CONNOR V,. REPORl'ING Connor Reporting www.connorreporting.com 317.236.6022

### 29 Public Hearing March 23, 2016 

### 1 their natural environment. Last summer we found a 2 home on a small lake with some wooded property, and it 3 was close to USI where I work, four miles. I checked 4 on line to make sure that the area was safe for my 5 children, including checking the emissions from A.B. 6 Brown. 7 Learning this year of the dangerous emission 8 levels of 802 from A.B

. Brown was so upsetting. Is it 9 safe to let me -- for me to let my chi l dren play 10 

### outside? Are we putting their heal th at risk? And 11 what about the health of our n e ighbor's children? Is 12 it safe for them to even have recess at Marrs 13 Elementary? 14 I note that what Shelby said about USI

-- they 15 have a Children's Learning Center , a child care 16 facility there, and I spoke with a parent who sends 17 her child there who didn ' t even know of the 802 18 emissions, and her child has extreme asthma problems. 19 Vectren is prioritizing thei r profi ts over the health 20 

### concerns of the most vulnerable of their neighbors, 21 especially children. And that is wrong. 22 While my wife and I have a relatively secure 23 financial situation, our energy bills consume an 24 inordinate amount of our budget. We pay the highest 25 energy rates in Indi ana and , indeed, from my 29



## £ CONNOR**REPORTING** Connor Reporting www.connorreporting.com 317.236.602230 Public Hearing March 23, 2016 

### 1 experience of having lived in two other states in this 2 area, we pay some of the highest in the Midwest. My 3 wife and I use LED light bulbs, we keep the thermostat 4 set to miserly levels, colder than this in the winter . 5 We have an energy-effic ient , berm

- style home; and our 6 bills are still quite high

. 7 If Vectren is allowed to merely add m ore filters 8 a nd scrubbers, they will merely pass on the cost to 9 the consumer, as they h ave done in the past. Moving 10 away from highly polluting, coal-burning energy 11 towards n early any a lte rnative would be a step toward 12 the b e tt er future for the tri- state , for our children 13 and for our families

. 1 4 Should w e believe Vectren and IDEM that their new 15 proposal wi ll keep e mi ssions below t h reshold levels? 16 Their proposal a ll ows Vectren to submit sulfur dioxide 17 right up t o the limi t
. Can we bel i eve that Vectren as 18 a corporation will not exceed these limi ts , when 19 the y've done so in the past in blatant disregard for 20 the h eal th of their neighbors. And who pays the cost? 21 Vectren doesn 't

. Those of us in the Marrs community, 22 and m y home is right in it

. And those of us at USI 23 are t h e ones who are paying the hospital bills

. We 2 4 are the ones paying.the high electric rates that 25 s ub s i dize the dirty energy production

. And I ask 30



## £ CONNOR**REPORTDNG** Connor Reporti ng www. co nno rrepo rtin g.com 3 17. 236

.602231 Public Hearing March 23, 2016 

### 1 IDEM, Vectren and the EPA to work with u s to find a 2 better solution

. 3 Thank you . 4 

### MR. DELONEY: Thank you. 5 

### The next comment card i s from Jean Webb. 6 

### MS. WEBB : My name i s Jean Webb, and I'm a 7 res ident of Evansvi lle, and I'm here because I am 8 concerned about the health effects of the sulfur 9 d i oxide levels. 31



### 10 Any of the polls you see where Evansvil le is 11 rated the most miserable place t o l ive, or close, o n e 12 of the reasons is because of t h e poor health o f our 13 community, and I'm sure the hospitals can back this up 14 with data. We have poor health here. 15 And that sulfur dioxide, it ' s going to affect 16 people ' s asthma, and the particulate pollution it 17 contracts to also aff ec ts people with he a rt disease, 18 because it passes into the blood. But the other b ig 19 category of people that it affects is anyone with 20 autoimmune disease, such as myself. That extra 21 inflammation in the body triggers and makes any 22 autoimmune disease more difficult. Also anyone 23 fighti ng cancer; you ' ve got that constant onslaught o f 24 inflam mation. It keeps our ent ire area unhealthy, and 25 if we ' re going t o have a productive community, we need 

## £. CONNOR V,. REPORTING Connor Reporting www.connorreporting.com 3 17. 236.602232 Public Hearing March 23, 2016 

### 1 a healthy community, and we need to replace that S02 2 and that coal burning with more renewables. 3 Thank you. 4 

### MR. DELONEY: Thank you. 5 

### N e xt we h a v e Eric McCloud. 6 

### MR. McCLOUD: Okay. Well, hi. My name is Eric 7 McCloud. I'm an Associate Professor of Biology at the 8 University of Southern Indiana, and I live a few miles 9 downwind of the A.B. Brown facility. So I'm here 32



### 10 today to voice my concern about sulfur dioxide release 11 at the plant. 12 The Sierra Club contends that the models t hat are 13 offered by IDEM and V ectr en regarding the new sulfur 14 dioxide standards are overly optimistic. As a person 15 likely to be affected, I w ou ld hop e t hat my local 16 power utility would go beyond mere attainment rather 17 than use potentially-flawed mode ls t o c l aim just 18 barely meeting the standard. I want my utility to b e 19 a good neighbor and a good corporate citizen

. 20 As we know, sulfur dioxide and related SOX gasses 21 are pollutants that contribute to acidic deposition as 22 well as caus ing direct and indirect huma n h ealth 23 e ffec ts
. While Vectren claims to scrub emissions from 24 the A.B. Brown plant, continuing problems with air 25 qua li ty in our area suggest that the me asures that are**CONNOR REPORTDNG**  Con nor Reporting www.connorreporting.com 3 17.236.602233 Public Hearing March 23, 2016 33 

### 1 employed so far have not been effective. Accordingly, 2 I support efforts to minimize sulfur dioxide 3 emissions. 4 Here in Evansville our electrical service rates 5 are among the highest in the state and the nation

. 6 While other utilities that produce coal-fired 7 electricity can hol d down both pollution and rates, my 8 utility dithers and makes excuses. As a result, we 9 pay high rates for dirty energy whose emissions 10 degrade ecosystem services and contribute to plant, 11 animal, and human health damage. 12 Th a nks. 1 3 

### HEARING OFFICER DERF: Thank you. 14 

### MR. DELONEY: Next we have Maryann Watson. 15 

### MS. WATSON: My runny nose and cough i s not a 16 commentary on the conditions. It ' s more of an allergy 17 right now, I think

. 18 I just want to echo one of the comments t hat was 19 jus t made about just being satisfied with attainment. 20 I don't unde rstand why there's not more stress put on 2 1 exceeding or going beyond. I am a former school 22 t eacher, and I know parents that would not have been 23 accepting of C grades when they knew that their 24 students were capable of doing much better t h a n t h at. 25 And I don't understand that mentality at all. Why 

## #.CONNOR**REPORTING** Connor Repo rting www .connorreporting.com 317.236.6022

### 34 Public Hearing March 23, 2016
1 

### should we not strive to go beyond what is considered 2 perhaps average? 3 And then there were some adequate questions I 4 think raised about how those averages are calculated 5 anyway, and I ' d be kind of curious to find out where 6 various Vectren executives and employees work. I 7 doubt that many of them live out near, but I don't 

### 8 know. I don 't know that as a fact. 9 But anyway, why are we satisfied with a C grade, 10 perhaps, when even a B or B-minus would be, perhaps, 11 

### better? 12 Thank you. 13 

### MR. DELONEY: Thank you, Ms. Wat son . 14 

### No other comm ent cards? 15 

### (Pause) 16 

### MR

. DELONEY: With that , is there anybody else 1 7 that wishes t o come forward to provide testimony for 18 the record? 1 9 (Pa use) 20 

### MR

. DELONEY : If not , those t hat have already 21 spoken that may wish to have additional time, you h ave 22 the floor now before the hearing is closed, i f you 23 wish to take advantage of that opportunity

. 24 (Pause) 25 

### MS. GRAY: Hi. I'm Lois Gray with the Pos ey 34



## #.CONNOR**REPORTING** Con nor Reportin g www.connorreporting .com 317.236.6022

### 35 Public Hearing March 23, 2016 

### 1 County News. Can I just ask an information question? 2 

### MR. DELONEY: Sure. 3 

### MS. GRAY: All of the numbers have next to them 4 "based on a 24-hour rolling average". What is a 5 "24-hour rolling average"? 6 

### MR. DELONEY: We'd be more than happy to answer 7 questions like that once the hearing itself has been 8 closed. Mark and I will remain after the meeting 9 however long it will take to answer any questions that 10 you might have. 11 Are there any other comments germane to the 12 record? 13 

### MR. BERG: I actually have a question, because it 14 came to mind today after speaking to my colleague with 15 a son who has extreme asthma problems. He doesn't get 16 colds; he has to go to the hospital. Has

-- have 17 there been efforts to inform parents at Marrs 18 Elementary and parents of children at USI's Children's 19 Learning Center of the S02 emissions levels that are 20 currently not in compliance? 21 MR. DELONEY: Okay. Again, we'd be happy to 22 address any questions after the public hearing itself 23 has been closed, but the hearing itself is simply to 24 reflect public comments that are offered for the 25 official record. That discussion wouldn't be part of 35



## £CONNOR**~** 

## REPORTINC28 Connor Reporting www.connorreporting.com 317.236.602236
1 2 3 4 5 6 7 8 9 10 11 12 Public Hearing March 23, 2016 36 

### that official record

. But we ' d be more than happy to make ourselves available to s hare what information we
can . Is there anything else for the official record for this evening? {Pause) MR. DELONEY: If not, we can close the hearing and make ourselves available for any types of questions that you might have. H

EARING OFFICER DERF: All right

. This hearing is adjourned. Thank you very much.

13 END TIME: 6: 54 P

. M. 14 1 5 16 1 7 18 19 20 21 22 23 2 4 25 

## £CONNOR**REPORTING** Connor Re portin g www.connorreporting .com 317

.236

.602237
1 2 3 4 5 6 7 8 9 10 11 Public Hearing March 23, 2016 

### CERTIFICATE OF REPORTER.

I, KAREN K

. KEIM, CRR, RPR, a Certified Court Reporter in the States of Illinois and Missouri, do hereby certify that the proceedings in the above-entitled cause were taken by me to the best of my ability and thereafter reduced to writing; that I

am neither counsel for, related to, nor employed by any of the parties to the action, and further that I

am not a relative or employee of any attorney or counsel employed by the parties thereto, nor 37



### 12 financially or othe rwise interested in the outcome of 13 

### the action. 14 15 16 

### 17 18 19 Karen K. Keirn Certified Realtime Reporter 20 Illinois CSR No. 84 -1577 Missouri CCR No. 1328 21 22 

### 23 24 25 

### KAREN K

. KEIM



## £CONNOR v_ REPORTDNG Connor Reporting www.connorreporting.com 3 17. 236

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## £CONNOR V.. REPORTING Public Hearing March 23, 2016 Index: a lied

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18:25 Public Hearing March 23, 2016 Index: commentarv

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## £ CONNOR**IREPORTDNG** Public Hearing March 23, 2016 home 28:23 29:2 30:5,22 hope 32:15 hospital 30:23 35:16 hospitals 31:13 hour 9:17,2 1,2510:7, 10,

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## £CONNOR**REPORTING** Public Hearing March 23, 2016 Index: panel

. .recommendation
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14:17 34:18 35:12,25 36:1,4 recordkeeping 10:24 redo 18:9,13 reduce 11:1917:10 reduced 9:18 reducing 17:4 redundant 17:18 refer 5:14 referred 17:20 reflect 14:21 35:24 reflected 16:24 reflects 14:18 regard 22:13 region 15:5,13 Register 13:25 14:1,3 regular 26:22 regulation 21:20 regulations 2:14 20:16 regulatory 22:3 Reiss 2:23 related 32:20 relationship 21 :23 release 32:10 remain 35:8 remainder 6:12 remaining 6:14 23:1 remains 4:6 remind 12:24 21:3 renewables 32:2 repeatedly 22:15 replace 32:1 reporter 14:21 reporting 10:23 represented 3:14 Public Hearing March 23, 2016 Index· recommendations

.. Southern representing 20:2 23:7 request 4:3 9:2,11 13:5

14:4,19 requested 5:25 9:18

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20,22 35:4,5 room 3:3,7 14:20 Rosenquist 17:16,17 rosy 27:6 Round 6:15,16,21 7:10

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30:1 states' 11:11 Station 2:10 4:20 7:12

8:15,19 9:10 12:4,21 13:15 20:20 21:3 stationary 6:25 statistics 19:12 stays 15:23 step 30:11 stick 22:24 Public Hearing March 23, 2016 Index· southwestern

..Vectren story 21:20 stress 33:20 stricter 21:7,18 strive 34:1 struggle 15:14 student 26:1327:1,18 students 27:19 28:1,8

33:24 studies 5:10 study 18:9 submission 13:4 14:7 submit 4:10 7:15 22:20

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14 Valleywatch's 23:8 Valleywatches 23:22 valued 11:12 variability 19:7,14,19 variables 19:8 variety 25:23 Vectren 15:1916:14,18,

20 17:7,918:18,20 19:1, 6,9 20:7 22:2,4, 10, 15,18 28:10 29:19 30:7,14,16, 17,21 31:1 32:13,23 34:6 317.236.602210 Vectren's 2:9 15:6 16:5

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Connor Reporting www.connorreporting.com Index: Vectren's

..years

317.236.6022

## ~

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# 0 0- Protecting Hoosiers and OurEnvironment Since 1986

## AStatethat~

COMMENTSHEET Title 

### of Public Hearing:

___ __J_;4_,_·-"'-G--"fl""-'--r.::..().:.:ZV::.......LfJ___,C===t>-""'>/12f!''I/J7'-L•

# lli1:?-Z2e::.-a:=:.{Jt-L/2,.,'12cc.Lr_**~::___~=--.:_r** Jer:___

____ Date:

# -?d~**Pubi~Hsrt~~~~n=-----~.~~~~Vw&~~~~~~~~~~6~~~~~~-~---------------~** YOUR NAME ORGANIZATION/COMPANY E-MAIL PHONE NUMBER ADDRESS, CITY, ZIP

Page 

### of

__My name is Dr. Mary Lyn Stoll and I have lived and worked in the area since 2005. I have always struggled with allergies and mild asthma, but I have experienced more fi·equent and severe upper respiratory infections since moving here than ever before. Several ofmy close friends have noticed and many have told me to consider giving up myjobjust to live somewhere that might be healthier, I cannot help but to think that the excessive and harmful levels ofsulfur dioxide in the air where I work and near where I live are a key part ofthe problem. It is well known that that sulfur dioxide causes serious respiratory problems. It is also clear that sulfur dioxide affects cardiovascular health and can make heart disease worse. The lives ofHoosiers may literally be on the line. I know that the EPA says that local air quality fails to meet and attain safe levels ofsulfur dioxide. Protection from air pollution is a legal right to which every American citizen is entitled. The citizens ofthis area have every right to expect--to demand--that the air they breath meets goverrunent standards. The fact that our air quality has not and does not meet the minimum standards put in place by law is unacceptable and unjust. But it is not simply a matter of govermnent failing to protect the basic rights ofthe citizemy here. Knowing that part ofwhy I find it difficult to do something so basic as breathing, because the govermnent is failing to protect my basic rights, is bad enough. But knowing that Vectren's coal :fired power plant emissions are part ofwhy I can't breath, that I am also paying some ofthe highest utility rates in the nation-all because ofthe supposedly high environmental standards that Vectren ostensibly meets-is a kick in the teeth. Vectren insists that rates are high because ofthe cost ofcleaning up their plants, and yet despite paying so much more than my friends a11d family in other states, Vectren's plants are dumping unsafe levels of sulfur dioxide into my lungs, the lungs ofthe students at USI, and the small vulnerable bodies ofthe kids at the Marrs Elementary School so close to A. B. Brown. Why are we paying so much to keep outdated dirty plants open in the first place? As cons11mers, we are being ripped off-paying extra for clean air protection that we simply are not getting. It is also disconcerting to see that Vectren plans to pollute up to the maximum allowable levels. This amounts to planning for failure. No measurement or human endeavor is ever perfect, so it is always wise to build in some wiggle room. When my students beg for excuses because they faced a hurdle before a deadline, I can't help but to fault them for not planning a little room to deal with challenges that arise in the middle ofa project. Building in wiggle room for mistakes, oversights, or unforeseen challenges is simply wise planning. IfIDEM & Vectren really put human health first, they would not be planning to pollute to the maximum allowable amount. As the largest sulfur dioxide emitter in the area, they set the tone for the entire area. Knowing that other companies will also be damaging local air quality with emissions, they should strive to be more responsible corporate citizens rather than trying to get away with dmnping as much toxicity on the local population as is legally permitted.

### In sum, this plan does not adequately protect the people ofthis area. It 

### is unjust and harmful. The moral value ofthe health oflocal population as citizens ofthis nation and as stakeholders impacted by Vectren's business decisions should be given far greater weight.

## MEIHA ADVISORY 

## APRIL 16, 1999 FOR IMMEDIATE RELEASE 

### Below is a copy of a letter sent to Ms. Janet McCabe of IDEM demanding that the permit for the ConAgra facility be rescinded due to incorrect information being used in the Model used tojustify the plant in the first place. Valley Watch concurs with ChemQuery in making this demand. It 

### is imperative that scientific process be used in determining the efficacy ofplants like ConAgra. In this instance, IDEM seriously failed in their analysis ofthe impact ConAgra w.9uld have on downwind environs, resulting in underestimating the impact by ?X. If 

### IDEM refuses to revisit the permit, Valley Watch is prepared to increase the level ofprotest over this failure of our government and direct it toward Govemor Frank O'Bannon who is ultimately responsible for the decisions made by the IDEM. 

### 15 April 1999 Ms. Janet McCabe Assistant Commissioner, Office of Air Management Indiana Dept. of Environmental Management 

### 100 North Senate Ave. PO Box 

### 6015 Indianapolis, IN 

### 46206-6015 Dear Ms. McCabe: ChemQuery would like to thank you for the invitation to meet in your office in Indianapolis on Tuesday, April 13, 1999. This is to confirm and summarize the meeting held with members of your staff to discuss the RPM-IV modeling and air quality issues in southwest Indiana pertaining to the ConAgra permit. In attendance at this meeting were Dr. Joanne Alexandrovich, Vanderburgh County Ozone Officer, and ChemQuery's Dr. Howard Dunn, Dr. Jeff Seyler, and Dr. Tom Pickett. Members of your staff present were Mr. Mark Derf, Mr. Ken Ritter, and Mr. John Welch. Additionally, you and Mr. Tim Method were present intermittently.

### We appreciate the changes that you made at our request in the input parameters for the RPM-IV model program. These included 

# * use of meterologicai conditions for the day in question (July 12, 1995) 

# * use of the actual measured NOX values for Vanderburgh County 

## * use of corrected NO to N02 emission ratio (95:5 rather than 5:95) 

# * use of correct molecular weight input for the PAR parameter (14 g/mole rather than 86.2 g/mole) as per the RPM-IV operator's manual. When Mark Derf entered the corrected parameters on IDEM's computer, the new output predicted an ozone impact of 7 ppb for the proposed ConAgra plant (as opposed to the 1 ppb predicted in earlier runs). In view of this 7-fold increase in ozone impact, we believe that the ConAgra permit should be reexamined and denied. An ozone increase of this magnitude cannot help but cause or contribute to a violation of the ambient air standard. ChemQuery is convinced that southwest Indiana will be in violation of the ozone ambient air standard by the end of this summer. Additional major sources of hydrocarbons will only exacerbate the situation and put undue financial burden on our existing industry. If the ConAgra permit is not reexamined and denied, the inevitable ozone exceedences in southwest Indiana will be a direct result of IDEM's misassessment of ConAgra's impact. Sincerely, Dr. Howard E. Dunn ChemQuery

# ~EARTHJUSTICE**~** 8ec:ac.tm the 

### earfll l7eiM1s 

### a

## &ODd~ February 16, 2016 

### Via e-mail to MDERF@idem.IN.gov MarkDerf Indiana Depattment ofEnvironmental Management Office ofAir Quality 100 North Senate Avenue Mail Code 61-50 IGCN 1003 Indianapolis, Indiana 46204

# ~SIERRA 

# •**~N~Y.~**

Re: Commissioner's Order 2016-01, A.B. Brown Generating Station

Dear Mr. Derf: On behalfofSiena Club and Earthjustice, we submit the following comments on Commissioner's Order 2016-01, which sets S02 emission limitations and emission rates for the A.B. Brown Generating Station (" Brown") owned and operated by Southern Indiana Gas and Electric Company ("SIGECO"). The Order states that SIGECO requested that the new emission limits be incorporated into the Indiana State Implementation Plan ("SIP") after the Indiana Department ofEnvironmental Management ("IDEM") concluded that such limits would result in Posey County being in attainment for the piimary 1-hour S02 National Ambient Air Quality Standards ("NAAQS")

. Order at 2. IDEM had previously found that under Brown's current emission limits, Brown's emissions would cause Posey County to be 

### in nonattainment ofthe 1- hour S02NAAQS. Letter from Carol S. Comer, Commissioner, Indiana Department of Environmental Management to Susan Hedman, Regional Administrator, EPA Region 

### 5 (Sept. 16, 2015), Enclosure 3, at 22 [hereinafter Enclosure 3]. We fully support incorporating lower S02 emissions limits for Brown Units 1 and 2 into the Indiana SIP. However, IDEM has not supported its conclusion that the new limits will result in Posey County being 

### in attainment for the 1-hour S02 NAAQS. IDEM has failed to follow EPA guidance regarding calculation of S02 concentrations and determination ofthe sources to include in the background concentration. IDEM's modeling also used an unrealistic and unreasonable assumption that the Brown units would never exceed their permit limits. In order to determine whether Brown causes or contributes to nonattainment ofthe 1-hour S02 NAAQS, IDEM should update its modeling to address these tlu·ee issues.

### I. LOWER S02 

### LIMITS FOR BROWN ARE URGENTLY NEEDED. As noted above, we fully support promptly incorporating lower S02 emissions limits for Brown Units 1 and 2 into the Indiana SIP. IDEM's modeling ofactual emissions over 2012- 2014 indicates that Brown's actual S02 emissions have been causing violations ofthe 2010 standard. Enclosure 3 at 22. These violations tln·eaten public health in southem Indiana. As IDEM is aware, exposure to S02 causes serious health problems and thus preventing any violation ofthe S02 NAAQS anywhere in Indiana is ofutmost importance for public health. Exposure to high levels of S02 for even very shott time periods-such as five minutes-has significant health impacts, including decreased lung function, aggravation of asthma, and premature death. See Primary National Ambient Air Quality Standard for Sulfur Dioxide Final Rule, 75 Fed. Reg. 35,520, 35,525 (June 22, 2010). In order to protect against these serious hmms, we urge IDEM to promptly approve the new limits for Brown. 

### II. IDEM'S CONCLUSION THAT THE NEW LIMITS WILL RESULT IN ATTAINMENT IS NOT SUPPORTED BY THE RECORD. IDEM finds that the S02 emission limitations and emission rates in the order are necessary "in order to assure continued attainment ofthe S02NAAQS." Order at 2. This finding is not supported by the record. IDEM relied on modeling to conclude that the new limits will result in attainment. IDEM did not provide the actual modeling files to Siena Club until today, so we have not been able to fully evaluate the reasonableness and accuracy ofthat modeling. However, it is clear that IDEM's modeling suffers from at least three flaws that render it unreliable for determining whether Brown causes or contributes to attainment ofthe 

### !- hour S02 NAAQS. As explained below, IDEM should redo the modeling and should make the full modeling report and all modeling files publicly available. A. IDEM Excluded Major Sources of SO, From the Background Concentration of 

### SOa" One ofthe most impmiant inputs to the model is the background concentration of 80 2 • IDEM modeled only two major sources ofS02 as part ofthe background: the SABIC and Countrymark facilities. Enclosure 3 at 21, Table 11. It is unclem· what methodology IDEM used for excluding background sources, because IDEM says in one place that it evaluated background sources within 30 Ian ofBrown, id., but in another place says it focused only on background sources within 10 Ian. 

### Id. at 7 ("Indiana focused on areas within 10 km for each ofthe modeled Consent Decree sources,"). IDEM's modeling excluded several major sources ofS02 emissions close to Brown, most notably the four-unit Wanick power plant and the Alcoa industrial operations at the Warrick site. Wanick is approximately 35 km east ofBrown. IDEM also excluded the Culley power plant, a two-unit, coal-fired power plant. Culley is approximately 35 km east ofBrown. Finally, IDEM excluded the large Gibson power plant, which is approximately 50 km north ofBrown.



### 2IDEM has not adequately supported its decision to exclude emissions from Warrick, Culley, and Gibson from the background concentration used in the modeling. In particular, IDEM has not followed EPA guidance on identifying nearby sources to include in the modeled inventmy ofemissions. EPA has emphasized that "the factors that need to be considered are very case-specific in nature" and "cautioned against the literal and uncritical application ofvery prescriptive procedures for identifying which background sources should be included in the modeled emission inventory for NAAQS compliance demonstrations." EPA, Additional Clarification Regarding Application ofAppendix W Modeling Guidance for the lchour N02 National Ambient Air Quality Standard (Mar. 1, 2011) at 12-13. In other words, EPA guidance recommends that states make source-specific dete1minations ofwhich background sources to model, rather than rely on across-the-board thresholds. By automatically excluding any background source more than 30 km away from Brown, IDEM appears to have done exactly what the guidance cautions against doing. EPA suggests that three initial steps be taken in order to characterize the factors to be considered in deciding which background sources to model: (1) contour plots ofmodeled concentrations should be prepared and overlaid on a map showing features likely to affect dispersion patterns; (2) the controlling meteorological conditions should be identified; and (3) the location ofthe monitoring station used in the modeling should be included on the plot of source impacts, as well as a wind**ros~** depicting general flowpatterns. 

### !d. at 13. We have not seen any indication that IDEM followed these three steps. IfIDEM followed these tluee steps, IDEM should make the documentation publicly available. EPA not only recommends that states make source-specific determinations, but EPA notes that the determination ofwhich background sources to include becomes more complex as the averaging time decreases. "[T]he factors affecting which sources should be included in the modeled inventory and the method for combining modeled with monitored concentrations are more complex for the !-hourN02 standard than for the annual standard." 

### !d. at 16. Here, the Order establishes one set oflimits based on a one-hour averaging time. Given EPA's guidance stating that background detem1inations are more complex with shorter averaging times, IDEM should have taken a close look at whether, under the pmticular circumstances ofthe Brown plant, sources such as Wanick, Culley, and Gibson should be included in the background concentration of S02 • Instead, IDEM appears to have ignored this guidance and used a simplistic rule of thumb to exclude all background sources more than 30 lan (or 10 lan) from Brown. IfIDEM had inclnded Wanick, Culley, or Gibson, or any combination ofthose plants, the modeling results would almost certainly show that Posey County is in nonattainment, because without these sources, the modeling results are equal to the NAAQS limit of7 5 ppb. Given that the decision regarding which major sources to include in the background is dispositive, IDEM's exclusion ofemissions from Warrick, Culley, and Gibson is unsupported by the record and unexplained. IDEM should redo the modeling so as to include at least the emissions from the Warrick power plant and Alcoa operations as well as the Culley power plant in the background concentration of

# so2.

3B. IDEM's Reliance on Projected Emissions Under the New Permit Limits Does Not Acconntfor Exceedances ofPermit Limits It is our understanding that IDEM modeled five scenarios, all based on projected emissions under the new, proposed emission limits for Brown 1 and 2. See Enclosure 3 at 22. In doing so, IDEM seems to have assumed that both Brown units will comply with the new emission limits in every hour ofevery day. In other words, IDEM assumes that in 8,760 hours of the year, neither Brown 1 nor Brown 2 will exceed the !-hour average S02 limits for even an hour. This assumption is unrealistic, for two reasons.· First, IDEM's modeling assumption ignores the real-world operations ofcoal-fired units, which occasionally and often regularly, exceed their permit limits during normal operations and during stmtup, shutdown, and malfunction ("SSM") events. IDEM is well-aware that the Brown plant has in fact violated its S02 permit limits in recent years because IDEM has sent several letters to SIGECO infonning the company that Brown has violated its S02 permit limits. See, e.g, Letter from Lynne l Sullivan, IDEM to Allen Rose, Vectren Corporation (May 27, 2015) (finding violations ofsulfur dioxide permit requirements at Brown); Letter from Lynne J. Sullivan, IDEM to Allen Rose, Vectren Corporation (Apr. 8, 2014) (same); Letter from Lynne l Sullivan, IDEM to Allen Rose, Vectren Corporation (Nov. 19, 2013) (same); Letter from Ly1me J, Sullivan, IDEM to Allen Rose, Vectren Corporation (Feb. 24, 2012) (same); see also Letter from Lynne J, Sullivan, IDEM to Allen Rose, Vectren Corporation (Mar. 26, 2015) (finding that the Brown plant had failed to operate its scrubber in accordance with permit requirements, and providing notice that the violations will be processed as an enforcement case). Second, Indiana law expressly authorizes power plants to exceed their emission limits during malfunction events, 326 Ind. Admin. Code 1-6-4( a). 1 While this provision is contrary to Indiana law and must be rescinded, it has not been to date. At least until that provision is rescinded, it is unrealistic and unreasonable for IDEM to assume 100% compliance with the new pe1mit limits when the Indiana SIP expressly provides that facilities such as Brown can exceed their emission limits under certain circumstances and not be in violation ofthe emission limits. As a result ofthis discrepancy between IDEM's modeling assumption of 100% compliance and actual operation ofthe units, IDEM's modeling overstates the emission reductions that will occur from the new permit limits. IDEM should redo the modeling to account for both Brown units exceeding their permit limits, particularly during SSM events. IDEM could do this by examining historical exceedance reports from Brown and calculating the 3-year average ofthe percentage ofoperating hours during which Brown exceeded its permit limits and the percentage by which emissions exceeded the relevant limits. IDEM could then apply that exceedance rate to the new permit limits in its modeling. Regardless ofwhat method

1EPA recently concluded that this provision ofthe Indiana SIP violates the Clean Air Act, and issued a SIP call requiring Indiana to revise this provision. 80 Fed. Reg. 33,840, 33,846, 33,966 (June 12, 2015). However, our understanding is that this provision ofthe Indiana SIP has not yet been revised and instead remains in force. 

### 4it uses, IDEM's modeling assumption that the Brown units will comply 100% ofthe time with new permit limits is neither realistic nor reasonable. C. IDEM Failed to Follow EPA Regulations Goveming the Calculation of S02 Concentrations, and, As a Result, IDEM Misrepresents Its Modeling Results. IDEM reports that its modeling ofthe new S02 limits for the Brown plant resulted in a !- hour S02 concentration of 196.08 f1g/m3

, just barely below the 1-hom S02NAAQS limit of 196.2 f1g/m3• Enclosure 3 at 23, Table 12. IDEM thus projects that Posey County will be 0.12 3 flg/m below nonattainment. 

### !d. IDEM has not addressed several issues arising from the modeled S02 concentration being so close to the NAAQS limit. First, it is unclear whether the AERMOD software that IDEM used generates results accurate to the tenth ofa microgram per meter cubed. The margin by which IDEM claims that Posey County is in attainment may fall well within the margin oferror ofthe model. Second, IDEM's calculations are inconsistent with EPA regulations on how to calculate 1-hr S02 concentrations for purposes ofcompliance with the 2010 1-hr S02NAAQS. IDEM has converted a NAAQS expressed to two significant figures, 75 pmts per billion, into a number with four significant figmes, 196.2 f1g/m3

. IDEM then reports its modeling results to five significant figures, 196.08 flg/m3

, and claims that this value is "below the !-hour so2 NAAQS." Enclosure 3 at 22. The S02concentration (which EPA calls the "!-hour primary standard design value") "is calculated pursuant to section 5 and then ronnded to the nearest whole number or 1 ppb (decimals 0.5 and greater are rounded up to the nearest whole nnmber, and any decimal lower than 0.5 is ronnded down to the nearest whole number)." 75 Fed. Reg. 35,596 (June 22, 201 0), codified at 40 C.P.R. pt 50, App. T, § 4. Put simply, EPA requires that the S02 concentration be expressed in parts per billion and rounded to the nearest whole nnmber. I

### d. Accordingly, IDEM should have presented its modeling results as 75 ppb, which is equal to the NAAQS limit of75 ppb. IDEM's claim that its modeled concentrations "are below the!- hour S02NAAQS," Enclosure 3 at 22, misrepresents IDEM's results and is based on calculations that do not comply with EPA's regulations. 

## * * *

Thank you for your consideration ofthese comments. Please do not hesitate to contact us ifyou have any questions.



### 5Sincerely, Matthew Gerhart Earthjustice 633 17 111 St., Suite 1600 Denver, CO 80202 (303) 996-9612 mgerhatt@earthjustice

.org Tony Mendoza Sierra Club 85 Second Street, Second Floor San Francisco, CA 94105 (415) 977-5589 tony.mendoza@sienaclub

.org

6

### Via electronic mail and facsimile

# ~ SIERRA

CLUB
FOUNDED 189l

. Mark Derf Section Chief, Technical Support and Modeling Indiana Department ofEnvironmental Management Telephone: (3 17) 233-5682 Facsimile: (3 17) 233-2342 mderf@idem.IN.gov February 16,20 16



### Re: Sierra Club's Request for Public Hearing for Commissioner's Order No. 2016-01, A.B. Brown Genet·ating Station Dear Mr. Derf: On behalf ofSierra Club, I hereby request a public hearing for Commissioner's Order No. 2016-01, A.B. Brown Generating Station. Through Order No. 2016-01, the Department seeks to revise the sulfur dioxide air emission limits and rates in the Indiana State Implementation Plan that apply to the A.B. Brown Generation Station, located in Posey Count y . Pursuant to 40 C.F.R. 

### § 5 1.102, the Department is required to hold the requested public hearing after providing " reasonable notice" which must include, at a minimum, at least 30 days' advance notice ofthe date, place, and time ofthe public hearing . In addition, in order to maximize the opportunity for public participation, Sierra Club respectfully requests that this public hearing be held on a weekday in the evening in Mount Vernon, Indiana, which is near the A.B Brown Generation Station. Thank you for your attention to this matter. Sincerely,

Wendy Bredhold Campaign Representative, Ohio River ValleySierra Club Beyond Coal Campaign Telephone: (8 12) 604-1723 wendy.bredhold@sierraclub.org Cc: Scott Deloney, sdeloney@idem.in.gov (Via electronic mail)

2

### A.B. Brown Public Participation for Revision to Indiana State Implementation Plan for 1-hour Sulfur Dioxide National Ambient Air Quality Standard Summary aud Response to Written Comments and Comments Received at Public Hearing 

### IDEM requested public comment on the revision to the Indiana State Implementation plan (SIP) for Vectren (fmmerly Southern Indiana Gas and Electric Company) A.B. Brown Generating Station from January 13,2008 tln·ough February 16,2016. A public hearing was also held on March 23,2016. IDEM received comments fi·om the following parties: Tony Mendoza, Sierra Club (written comments) Matthew Gerhmi, Emihjustice (written comments) Wendy Bredhold, Sierra Club Niles Rosenquist, Concerned Citizen/Sierra Club Mark Bryant, Concerned Citizen/Valley Watch, Inc. John Blair, Valley Watch, Inc. Shelby Heck, University of Southern Indiana student Bmiell Berg, University of Southem Indiana professor Jean Webb, Concemed Citizen Eric McCloud, University of Southern Indiana professor Mary Ann Watson, Concerned Citizen Lois Gray, Posey County News Gary Creasey, Concerned Citizen (written comments) Dr. MaryLyn Stoll, Concerned Citizen (written comments) Mendoza Gerhmi Bredhold Rosenquist Bryant Blair Heck Berg Webb McCloud Watson Gray Creasey Stoll

The following is a summary ofthe comments received and IDEM's responses thereto: 

### Comment: Lower sulfur dioxide (S02) 

### limits for A.B. Brown Generating Station are urgently needed. The connnenters fully support promptly incmporating lower S02 

### emission limits for A.B. Brown Units 1 and 2 into the Indiana SIP. The commenters state that in order to protect against health impacts from exposure to S02 

### above the Primary National Ambient Air Quality Standard (NAAQS) for S02 

### final rule, 75 FR 35520, 35525 (June 22, 2010), the commenters urge IDEM to promptly approve the new limits. (Mendoza) (Gerhmi) (Bredhold) (Rosenquist) (Blair) Response: IDEM appreciates the support and has already approved the new limits tln·ough the applicable Commissioner's Order. IDEM worked with A.B. Brown Generating Station to establish limits for Units 1 and 2 within the applicable Commissioner's Order that are acceptable to the U.S. EPA to demonstrate attailnnent of the Primary !-hour S02 

### NAAQS of75 parts per billion (ppb). IDEM will be requesting these limits to become federally enforceable within Indiana's SIP. The limitations will be
1

### effective on April19, 2016, and are expected to be federally enforceable before Round 2 designations are effective. 

### Comment: IDEM's conclusion that the new limits will result in attainment is not suppmied by the record. Siena Club states at least three flaws that render's IDEM's modeling umeliable for determining whether A.B. Brown causes or contributes to attainment ofthe 1-hour S02 NAAQS. The commenters feel that the S02 emission limitations and emission rates in the order which are necessary "in order to assure continued attainment ofthe 802NAAQS" are not supported by the record. IDEM did not provide actual modeling files to Siena Club until February 16; therefore Sierra Club was not able to fully evaluate the reasonableness and accuracy ofIDEM's modeling. (Mendoza) (Gerhart) (Bredhold) (Rosenquist) (Blair) (Bryant) 

### Response: IDEM provided contact infmmation in the public comment and public hearing notices for interested parties to request additional information or technical details associated with the modeling conducted for the A.B. Brown Commissioner's Order and proposed SIP revision. IDEM was responsive to Siena Club's Public Records request; the request was made Wednesday, February 10, 2016, within the final days ofthe public comment period, ending Tuesday, February 16,2016. There are specific public record procedures that must be followed to provide additional information upon request. The A.B. Brown S02modeling files were made available to Siena Club once the request was received and processed. IDEM followed applicable U.S. EPA guidance and modeling procedures, and continually consulted with U.S. EPA to ensure the proposed limits can secure federal approval. 

### Comment: IDEM excluded major sources of S02 from the background concentration of S02. IDEM did not clearly identifY its methodology for excluding sources. Commenters request the air dispersion modeling be remodeled to account for these sources. (Mendoza) (Gerhart) (Bredhold) (Rosenquist) 

### Response: IDEM relied on guidance found in the "S02NAAQS Designations Modeling Technical Assistance Document" which provides specific assistance to state air agencies in the characterization of ambient air quality in areas proximate to or impacted by significant S02emission sources. The technical assistance document (TAD) provides guidance on how to model large S02 sources and assess compliance with the 1-hour S02 NAAQS. 40 CFR Part 51, Appendix W, Section 8.2.3.b states sources that are expected to cause a significant concentration gradient in the vicinity ofthe source ofinterest should be modeled and that number of sources is expected to be small. Sources located fmiher from the source ofinterest will be captured in the background concentrations that are measured at nearby monitoring sites. In the case ofA.B. Brown, the Buena Vista S02monitoring site in Evansville was deemed representative, ifnot conservative, for 1-hour 802background concentrations. In addition to modeling large 802 sources within 30 kilometers (SABIC Innovative Plastics and Countrymark Refining and Logistics), S02 impacts from somces in Waniclc and Gibson Counties as well as sources in Kentucky would be measured at the Evansville S02 monitor and therefore would be accounted for and included in the seasonal hourly

2

### background concentrations. These seasonal hourly background values are added directly into the modeling and are instrumental in characterizing the air quality in the area. IDEM feels the 30 kilometer distance used for evaluating whether sources should be included in the area designation modeling, where actual emissions are modeled using actual stack heights, as per U.S. EPA guidance, is more than adequate. It 

### should be noted that the U.S. EPA references a general "rule ofthumb" for estimating the distance to maximum 1-hour impact and the region of significant concentration gradients that may apply in relatively flat terrain is approximately I0 times the source release height. Therefore, maximum impacts from large S02 

### sources would not be expected to occur more than a few kilometers from its location. Therefore, for designation modeling, IDEM used a 10 kilometer modeling receptor grid surrounding A.B. Brown and looked within a 30 kilometer radius to dete1mine if S02 

### sources should be included in the modeling analysis or would be captured by a nearby S02 

### monitoring site. Sources located more than 30 kilometers would not have large modeled impacts in the vicinity of the source ofinterest and would be best characterized by S02 

### monitoring data. This analysis was made with air dispersion modeling ofthe proposed A.B. Brown's S02 

### emission limits, in accordance with U.S. EPA modeling guidance specific to !-hour S02 

### designations, and suppmis designation ofthe area surrounding A.B. Brown Generating Station in Posey County as attainment. IDEM will not conduct additional modeling for the A.B. Brown SIP revision. It 

### should be noted the U.S. EPA provided a review ofindiana's recommendations concerning the Round 2 Consent Decree modeling on February 16,2016. The U.S. EPA agreed with IDEM's assessment for A.B. Brown and the determination that sources beyond 30 kilometers will not cause a significant concentration gradient within the 10 kilometer modeling receptor grid for A.B. Brown. 

### Comment: IDEM's reliance on the projected emissions under the new permit limits (Commissioner's Order) does not account for exceedances ofthe limits. IDEM's modeling assumes A.B. Brown operates under stable conditions and ignores the realworld operations ofcoal-fired units. Indiana law expressly authorizes power plants to exceed their emission limits during malfunction events (326 lAC 1-6-4(a)). (Mendoza) (Gerhart) (Bredhold) (Rosenquist) (Blair) 

### Comment: The cmmnenter suggested looking at the historical emissions data to show variability of operations to show exceedance ofcunent requirements. A statistical analysis (including standard deviations and mean) for estimate ofvariability for new S02 

### limits could be conducted. (Rosenquist) 

### Response to both comments above: Each source in Indiana must demonstrate compliance with its Title V operating permit by collecting emissions information consistent with its repmting and recordkeeping conditions specified in the pe1mit or conduct periodic stack testing to confirm control efficiencies ofemission control equipment. Among the collected emissions data is the hourly 

## so2 emissions from both Units 1 and 2 at A.B. Brown. Variability in emission data is recorded and inspected by IDEM and the U.S. EPA and data values that exceed specific permit conditions are addressed through IDEM's Compliance and Enforcement sections.



### 3

### Initial air dispersion modeling accounted for the actual continuous emissions monitoring data from Units 1 and 2. Lower emission limitations were established based on maximum capacities ofUnits 1 and 2 and those limitations modeled attainment ofthe !-hour SOz standard. This is considered a conservative approach to determining emission limitations that are protective ofthe NAAQS with an ample margin of safety. The A.B. Brown facility will be responsible for demonstrating compliance with the applicable SOzlimits on an ongoing basis. Work practices and other compliance measures are in place to ensure against repeated exceedances of any emission limits as well. IDEM has completed a first notice ofcomment period (LSA Document #15-326) pe1iaining to 326 lAC 1-6. The U.S. EPA published findings in the Federal Register (FR) on June 12,2015 (80 FR 33839) concerning inadequacies to startup, shutdown, and malfunction provisions in state rules. However, 326 lAC 1-6 does not apply to A.B. Brown. The conditions listed in 326 lAC 1-6-1 only apply to the owner or operator of any facility required to obtain a permit under 326 lAC 2-5.1 (exemptions) or 326 lAC 2- 6.1 (minor source). A.B. Brown is a Title V source and is governed by Part 70**pe~mitting** 

### requirements. 

### Comment: IDEM failed to follow EPA regulations goveming the calculation of SOz concentrations and as a result, IDEM misrepresents its modeling results. The commenters question the accuracy ofthe American Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD) software. The commenters question the inconsistency ofiDEM's calculations ofthe !-hour S02 

### concentrations with EPA regulations for pmposes of compliance with the 2010 1-hour S02 

### NAAQS. (Mendoza) (Gerhart) (Bredhold) (Rosenquist) (Blair) 

### Response: The AERMOD is the prefe1Ted model by the U.S. EPA for near-field dispersion modeling for a wide range ofregulatory applications in all types oftenain. The air dispersion modeling used for establishing S02 

### emission limits for A.B. Brown follows U.S. EPA guidance for the 1-hour S02 

### designations and has been accepted by the U.S. EPA. Appendix W to 40 CFR Part 51, Section 9.0 addresses the accuracy and uncertainty of air dispersion models. The Model Clearinghouse, as part ofU.S. EPA's Suppmi Center for Regulatory Atmospheric Modeling (SCRAM) contains additional infmmation concerning the accuracy ofAERMOD and the issue ofrounding modeled results. The Model Clearinghouse response (#01-III-02) recommends to not round modeled results to compare to significant increment levels and NAAQS. 40 CFR 50.4 has specified rounding for the monitoring of several pollutants, including SOz, but rounding has not been applied to modeled results since modeling guidance has consistently recommended to not round. In addition, IDEM has relied on the Federal Register notice (76 FR 69058, November 7, 2011) in which a footnote con·elates the 

### !- hour SOz NAAQS of75 ppb to 196.2 micrograms per cubic meter (flg/m3) 

### for air dispersion modeling pmposes. The modeling results from AERMOD are expressed in micrograms per cubic meter; therefore, IDEM uses the 1-hour S02 

### standard expressed in micrograms per cubic meter. 

### Comment: Commenters claim the area has historically exceeded EPA SOz emission standards. (Bryant) (Heck) (Berg) (McCloud) (Stoll)


### 4

### Response: Overall air quality in the Evansville/Southwest Indiana area has attained the !-hour SOz NAAQS of75 ppb since the standard was finalized in 2010 and was below the standard for the past ten years. The Evansville S02 

### monitoring site, located at Ill0 West Buena Vista Road has recorded !-hour S02 

### monitored values well below the 75 ppb tln·eshold with the three-year !-hour S02 

### design values ranging from 18 to 26 ppb over the past six years. Further benefits from the Data Requirements Rule and other national rulemakings will result in even lower regional and national S02 

### emissions which will help to further reduce monitored S0 2 

### concentrations throughout the region. Futthermore, the historical monitoring data measured at the Evansville

- Buena Vista and Roth Road S02 

### monitors attained the NAAQS applicable at that time, with monitored values well below the 24-hour and annual S02 

### NAAQS of 140 ppb and 30 ppb respectively, before those standards were revoked and replaced by the more stringent !- hour SOz standard in 2010. The Roth Road S02 

### monitor was a source-oriented monitor located approximately 4 kilometers east ofA.B. Brown. It 

### recorded consistently lower hourly SOz values than the Evansville- Buena Vista monitor and was eventually discontinued in 2013. 

### Comment: Commenters question why the emission limitations established by A.B. Brown run right up to the standard and do not exceed or go beyond attainment? (Berg) (Watson) (Stoll) 

### Response: The U.S. EPA establishes the NAAQS based on health studies, as mandated by Sections 108 and 109 ofthe Clean Air Act. The mandate requires each NAAQS be periodically reviewed to determine ifthe existing standard is adequate to protect human health and welfm·e. The Clean Air Scientific Advisory Committee (CASAC) peer reviews all health studies/repmts to determine if a standard needs to be revised. Rulemaking for new NAAQS for all criteria pollutants are developed with opportunity for public pmticipation before the rule is finalized. The final NAAQS are developed based on impacts for the most sensitive groups ofpeople, typically children and the elderly, therefore, the standards are considered conservative in nature. In the case ofthe 2010 !-hour S02 

### NAAQS, this standard represents a much stricter tln·eshold at a lower time-averaging period to account for shmter-term health impacts. Therefore, attainment ofthis standard is protective ofpublic health and welfare, with an adequate margin ofsafety ofall groups ofpeople, especially sensitive groups.

5

# Attachment D A.B. Brown Generating Station: Modeling Summary Posey County

# A.B. Brown Generating Station Modeling Summary for Commissioner's Order #2016-01 Bacl{ground Initial modeling, using hourly continuous emissions monitoring (CEM) data from 2012-2014, showed higher modeled 1-hour sulfur dioxide (S02 ) concentrations

. Modeling for A

.B. Brown, using Mercury and Air Toxics Standard (MATS) S02 compliance emission rates, was then provided in Indiana's Preliminary Recommendations Concerning Round 2 Air Quality Designations for the 2010 Primary 1

-hour S02 Standard submitted to United States Environmental Protection Agency for review/consideration on September 16, 2015. 1 

### Since A.B. Brown decided to use the hydrochloric acid (HCl) emission limit to comply with the MATS instead ofthe

# · so2 emission limits, those rates could not be used and would not satisfy the Consent Decree. As requested by A.B. Brown, IDEM issued a Commissioner's Order on January 11, 2016, to establish permanent and enforceable sulfur dioxide (S02) emission limits for A.B. Brown in order to ensure continued attainment ofthe 20 10 primary 1-hour S02 standard in the area sunounding the facility. The Commissioner's Order contains emission limitations and emission rates for Units 1 & 

### 2, as well as reporting and recordkeeping requirements and method for compliance. · 

### Modeled Limits The Commissioner's Order limits A.B. Brown's S02 emissions to 0.855 lbs S02/MMBtu (pounds per one million British thermal units) for Unit 1 and 0.69 lbs S02 /MMBtu limit for Unit 2 when operating alone based on a 1-hour S02averaging time. Both units can never exceed 2,152.2lbs S02/hr. (0.426 lbs S02 /MMBtu) when operating together. Therefore, Indiana modeled the S02proposed emission limitations recommended by A.B. Brown. Five scenarios were modeled. Modeled concentrations for all five ofA.B. Brown's operating scenarios were added to the temporally ·va rying seasonal S02 background concentrations, as well as the emission limitations and emission rates for all five scenarios as outlined in Table 1. The worst case operating scena rio was Scenario 5: Unit 2 operating at 0.69 lbs S02 /MMBtu and Unit 1 operating at 0.161lbs S02 /MMBtu

. Again, both units, when operating, cannot exceed 2, 152.2 lbs S02 

### /lu·

. Since that is the case, Unit 1 cannot operate at full capacity when Unit 2 is running at 0.69 lbs S02/MMBtu. Also, when Unit 1 is operating at 0

.855 lbs S02/MMBtu, Unit 2 cannot be operating. 

### Table 1 Scenaro 1 Scenario 2 Scenario 3 Scenario 4 Scenario 5

"'OO•o000oo0•0-•0MOOO-OOOOM- • '**~** ·- .....**---·** . ····--· . -·· .... .. ······- -·· ······-·--·-- --· .

### --------·- ·... ·---···· -··-··- - - ·-·-·... ·--·---**------~** .. ---· GroupiD Emission Rate 81 86AII 81 60AII 43 All 82 60AII 82 69AII 8oilerl

__ _ ___lb/MMBtu ·---·--· 0.854725973 0.6 0.4275 0.256417792 0.161437649

.... ·-·- --·· - ····- ·- -· ·--- 

### -·-- -- ·· ·-·--·-·· 

## -- -------- 8oiler2 lb/MMBtu 

### - 0.253517787 0.4275 0.595470356 0.69 8oilerl Modeleq**b/h ---**  2152.2 1510.8 10 76.445 645.66 406.5



# --- ..···**--~** .... &.,

__ ._.,.._,..

# __ .**~-~** . 

## ---.----·-· - 

### -·- --·-- Boiler2 Modeled lb/hr 641.4 108 1 .575 1506.54 1745.7 Total lb/hr 2152.2 2152.2 2152.2 2152.2 2152.2 Concentration ug/m3 188.64213 190.57711 193.45872 194.71424 195.51998

1 http://www.in

.gov/idem/airquality/2432.htm

### All other modeling parameters for A.B. Brown were maintained from the Consent Decree modeling included on Pages 19-23 ofEnclosure 3 oflndiana's Preliminary Recommendations Concerning Round 2 Air Quality Designations for the 2010 Primary 1-hour S02 Standard.