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 

Commissimwr 

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 S02 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 enforceable sulfur dioxide (S02) 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 Commissioner'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 Equal Opportunity Employer 0 Please Reduce, Reuse, Recycle A State that~ 
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.IN.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 S02 

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 of regulations; oi· issued the pe1mit, order, consent 

agreement ("document"); in final form. 

a. Date of adoption or final issuance: 

b. The effective date ofthe plan, if different 

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 of the actual regulation or document submitted for 

approval and incorporation by reference into the plan, 

including the following: 

a. Indication of the changes made to the existing 

approved plan, where applicable. 

b. The submittal shall be a copy of the 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 of the procedural 

requirements of the State's laws and constitution in 

conducting and completing the adoption/issuance of the plan. 

6. Evidence that public notice was given, including date of 

proof of publication. 

7. Certification that public hearings were held in accordance 

with information provided in public hearing notice. 

8. Compilation of public 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 County 
IDEM INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

We Protect Hoosiers and Our Environment. 

Michael R. Pence 

Go~·cJ110r 

100 N. Senate Avenue • Indianapolis, 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 stationary 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 of California 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 cqunl Opportunity employer 0 

A State th ~ (i} Recycled Paper 
Commissioner'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 of the 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 

of the 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 of the 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 S02 emission 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 of the 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 of Federal 

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 (181

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 of the Indiana SIP. 

Persons seeking judicial review of this 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 of Environmental Adjudication at (317) 232-8591. If you have questions 

regarding this Order, please contact Mark Dert; Office of Air Quality, by telephone at (317) 233-

5682 or email at MDERF@idem.IN.gov. 

Dated at Indianapolis, Indiana this __ill~:_ day of January, 2016. 

taro! S. Comer 

Commissioner 

Indiana Department of Environmental Management 
Attachment C 

Public Participation Documentation 
~th 

bh, EM Indiana Department of Environmental Management 

Df;,RSARY 

Michael R. Pence 

Govenwr 

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 

Commissi011er 

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 A venue, Mount Vernon, 

Indiana 47620, the Indiana Department of Environmental 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 of Air Quality, (317) 233-5682. 

Individuals requiring reasonable accommodations for participation in this event should contact 

the Indiana Department of Environmental Management, Americans with Disabilities Act 

coordinator at: 

Attn: ADA Coordinator 

Indiana Department of Environmental Management 

Indiana Government Center North 

100 North Senate A venue 

Indianapolis, IN 46204-2251 

or call (317) 233-1785 (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 of the Commissioner's Order is available to any person upon request and is available for 

public inspection at the following locations: 

An Equal Opportunity Employer 0 Please Reduce, Reuse, Recycle A Stale hat~ 
Indiana Department of Environmental Management 

Office of Air Quality 

Indiana Government Center-North 

100 North Senate A venue 

I Oth Floor 

Indianapolis, Indiana 46204. 

and 

Indiana Department of Environmental Management 

Southwest Regional Office 

I J 20 Notth Vincennes A venue 

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 Derf at the contact information provided below. 

Mark Derf 

Indiana Department of Environmental Management 

Office of Air Quality 

100 North Senate A venue 

Mail Code 61-50 IGCN 1003 

Indianapolis, 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 • Indianapolis, IN 46204 

(800) 451 -6027 • (317) 232-8603 • www.idem.IN.gov 

Michael R. Pence 

Gm•ernor 

Carol S. Comer 

Commissioner 

January 13,2016 

CERTIFICATE OF PUBLICATION 

This is to certify that the Indiana Department of Environmental 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 of Indiana 

was published on IDEM's web site on January 13, 2016. It is expected that it will remain posted 

on the site until at least February 16,2016. 

The notice in full was also made available the same day online at the following web address, 

under "Commissioner's Orders". 

http://www.in.gov/idem/4686.htm 

Web publication of the notice was at the request of Scott Deloney, Branch Chief, Programs 

Branch, Office of Air Quality, IDEM. 

Attachments: 

Copy of web page as published. 

An Equal Opportunity Employer 

By: 

Mike Finklestein 

IDEM Webmaster 

0 

A State that~ (i) Recycled Paper 
~ IDEM Extr•net I> Sugg=e<! S"!t"' - ID Co~WMAddress to Lat Lo... ~ Free Hotm•il [) GIS Mop Review- All Doc-. [J http-www.ep•.gov-lln-o-. ~ Indian• Gener•l Aownbly_ rJ Login - !Itt-net Yohoo! :[) Ricoh Printer, RNP002673_. ~ Web Sloce G:llery -

Indiana Beach Program I [J 

land Quality 

Partners for Pollution Prevention 

Pollution Prevention 

Recycle Indiana 

Storm Water Permitting 

Waste Tire Program 

Water Quality 

Watersheds and Nonpoint Source 

Water Pollution 

Wellands, Lakes and Streams 

Regulation 

Resources 

Compliance 

Funding 

Monitoring 

Permitting 

Environmental Consultants List 

Environmental Guidance 

Environmental Publications 

Nonrule Policies 

f You iD 

• Article 1 G State Environmental Policy !PDB [J 

Article 17 Public Records (Reoealedl IPDFJ [J 

Article 17.1 Public Records; Confidenti~llnformation: ConfidentialitY Agreements 

lElill [J 

Article 18 Asbestos Management !POFJ [J 

Article 19 Mobile Sourct' Ryles !POFJ [J 

Article 20 Hazardous Air PolfU1ants !POFJ [J 

- Article 21 Acid Deoosirion Control !POA [J 

• Article 22 Srratosohenc Ozone Protection IPDFJ [J 

• Article 23 lead-based Paint Prooram !PDFI [tJ 

• Article 24 Trading Programs· Nitrogen Oxides (NOxl and Sulfur Dioxide (S02l 

J.EQEl [J 

• Article 25 Voluntarv Performance Based leadership Programs !PDFl [tJ 

• Article 26 Reoional Haze !POFJ [J 

The Indiana Administrative Code Title 316 Air Pollution Control Division website provides 

the most up-to-date listing of these files. 

Commi:sioner's Orders 

A Commissioner's Order is a permanent enforceable order specifically authorized by an air 

rule as an alternative to a rule requirement Once issued, a Commissioner's Order becomes 

a condition in an air permit In most cases. a Commissioner's Order will be submitted to 

U.S. EPA for approval as an amendment to Indiana's state implementation plan for the 

Clean Air Act. 

Commissioner's Order 12.016-01 for A_B_ Brown Generating Station of Indiana: 

• Notice and Order of the Commissioner of the Department of Environmental 

Management IPDFl [l 

, Legal Notice of Public Hearing I PDF] [l 

Commissioner's Order #2015-01 for Abengoa Bioenergy of lrnfrana: 

o Notice and Order of the Commissioner of the Department of Environmental 

Management IPDFl [l 

• l egal Notice of Public Hearing I PDF] [l 

Commissioner's Order 12.014-01 for Jeffboat LLC: 

o Notice and Order of the Commissioner of the Department of Environmental 

Management IPDFl [J 

• Legal Notice of Public Hearing I PDF] [l 

Commissioner's Order 12009-0AQ-01: 

• Notice of Commissioner's Order I PDF! [J 

Commissioner's Order 12008-02 and Variance. lndianapofiS Power & Light -

Harding Street Generating Station: 

Notice Order and Variance of the Commissioner of the oeoartment of 

Environmental Management IPOFl [l 

• IPL Legal Notice of Comment Period and Opoortunity to Recuts! a Public 

Hearing IOOCI f3 

o No lice of Variance Decision IPOFI (9 

Commissioner's Order 12.008-01 and Variance, ALCOA Power Generating, Inc. -

ALCOA Warrick Power Plant 

. - Dote anc:! lime 

Dote: 

Wednosdoy, J•nu•ry 13, 2016 

Time: 

2:26:36 PM 

1">1 Change dote •nd tim._. 

Trme~ne --------------------------------------

(\JTC.OS:OO) Eanorn Time (US&. C•nod•) 

Change: time zone... 

Doytight Saving Time bog in> on Sunday, March 13, 2016 at 2.~ AM. The 

_clock is set to go forward 1 hour otthottime. 

G!!t mer@ bmt · ont 1nf erm§pon on lint!: 

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II COncel I I >.oply 

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• • • · -- lflll:'lll6 
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T.me 

~ 2:24:11 PM . I l.•,j han e date and time. .. I 

nm~zcne 

(UTC..OS:OO) Eastern Time (US e.t Canodo) 

I Change time :one... I 

D.,j1ignt Soving Time b<gin• on Sundoy, March 13,2016 at 2:00AM. The 

clock ~ ~et tc go forward 1 hcur at that time. 

0 Notify me when the dock changes 

1 al~Ct tiEI!C ~~!J!: iDf!:!tmAiiS::O QQitMt 

H£'"' Sh~ l '""'t lh$; s;l2s;r ~r:~ Iim!: i2nc? 

I OK II cane.! l l ;.IY.)ly 

No c:urm:t publiC noti::ts. 

No current pubr~e nou:es. 

Perry 

Tell City !!oat Works, Int. 12/31/2015- Yes 

Enfofj:0 £Dl• SI~Jo Qo:ratjog Permn (fESQPl 01/30f2Dl 6 

lE!lE! 

Waupaca Four.dry.lnc. Plom 5 PTe\'tntion of Signifiant O~tsrioration 

(PSOliSigrnficant Sot~ ce b!odjficgtion to a 

Pm 70 Oomtmg Pmnit (359701 IPOFI 

Sianffig nt PPm\rt ~.iodrlionon toe P"n 70 

Or;<!!?ting p....,;, P5981) JPQF] 

1!121/2015-

01120/2016 

Yes 

Warrick Processin<J Facilny Norice for Pvblit; lnform>t;on t.t .. t;ng IOOCI 12/02/2015- Yes 

Wa-Jpaca Founclly, ~- R\'IS II Solid WasJ• Pmn Public Notic• f?DFI 

Ol/01/2016. 

1112312015- No 

12/16/2015 

Pilei! 

Petersburg [cil)') W'llTP 01113/2016- Yes 

02/15/2016 

-- - Commissioner's Order ~2016~ l eyal NQticr ard Oppommirv for Pubf:c 01117/2016- Yes 

01 for A. B. Brown Ge~raling H"'rino IPpfl 02116/2016 

Station 

-- -~--

consolidated Grain ana Barge Significant Scurc! f!~if!S;.ntion to a Pan 70 12/301201 s- Ye: 

co. o~~ ariog Pmnit (~§~7l [PDF[ 01/29/2016 

ig!:lffi~m emnil t.~~ fi, iiiism 12!! P~a 72 

oa...,.ring P"'"'ir 136'621 [PQE] 

PoseyvUie (tOYm) VNITP NPQ ~ Qrofl ~S?!!ll et!F[ 12/2312015 - Yes 

01/25/2016 

Valero er.ewabl~ Fu~ls Si!I!!ifiem ~o~tr~f MQ!!ifi~i!Jton ro a P~n 7Q 12/09/201 s- Yes 

Company, u.c (dba Valero ~raring rmnn ~~~l.!lQJ PQfl 01/08/2016 

Mount Vernon Plant) Si!!.!lifi!;l!nt Pffi1Ji1 M!!!!ifi'-l!ion to a Pa!J70 

Qllerating Permit 1~6'1 ~l [POE] 

West Frnn~ in Coal Transftr ~PQ!;~I!"'flf!..;..;;, l[!!llfl 12102/2015 - Yes 

raolity 01/04/2016 

?ermit !>.'um~er.123· 6479·00026 

· ?ermit Number: 123-35970·00019 an~ 

123·35981-00019 

Applicant Company: Renewable 

Resowces LLC 

?errnitliUm!>er. FP 87-13 

Project 1.\anog;;r: Jo.~n Hale 

?rojec:t Manager. Jay Hanko 

Permit Numl:fr.IN002.4325 

Projett Monaer. r,lark Derl 

Addi1icnol Anainrnent Designation 

documents are a·;aiJable on the ~ 

OiQxi{r (S02l ~Jonau" rm!!!t 

~page 

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Permit !lumber: 129-36267-001)35 and 

129-36269·00035 

Project Manager. J ason House 

P01mi: 1lumber.IN004051i 

Permit Number. 129-36200·00051 a no 

129-36213-00051 

Project Manager.. Jennifer Carlino 

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Hearing Location: M-1 . Ve.rAo.--. FO ' I 

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Name: We.ILJ.'-1- e.c, J h_,.,(.j 

Organization I Cbmpany: S( <<r-tJ<. .. Ovh 

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Address: "b"J>D'( £- /i~ 4f,t_,r -11--. 

City: ty Vi. N'Vt( (.a- State: 111-J Zip: '--1771'--f 

I 

Representing what interest? 

C--ktt--f\.. ;_·,('. ... 

Do you wish to present an ora! testimony? / 

Yes l.r,...... No .. Has a written testimony been submitted? Yes No v/ 

Will a written testimony be submitted? Yes,_____.- No 

Do you wish to be informed of future or 

final actions in this matter? Yes v-~o 

-· I PLEASE PR!NT 

Hearing Location: M--hVerMA Ffl 

Date: 112du _\ 

Name: tJ i'ks f,::'-,t;~, V\4 IA'i?\ , 

Organization I Company:·/) ' ~~ 

E-Mail Address: Ill 'I lo~.~"'c."' "o. u~ 11(r '""t1J) I ~ C-o\1\.----- I 

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D. ./ -

Do you wish tl'present an oral te~timony? Yes-::z!_ No 

Has a written testimony been submitted? Yes~ No2{_ 

Will a written testimony be submitted? Ye'si.. No 

Do you wish to be informed of future or 

final actions In this matter? Yes'-::t:__. No 

·----·- . ----------------~--------- ----------·-

PLEASE PR!NT 

Hearing Location: />$/, 1/e_{'Vlu ~ f'·f:> 

Date: NHCYI 2Z f<Oit. 

Name: /viA?!! &WilT" 

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Do you wish to present an oral testimony? Yes_LNo 

Has a written testimony been submitted? Yes Not/-

Will a written testimony be submitted? Yes;/ No 

Do you wish to be informed of future or ... ---- final actions in this matter? Yes t-'/ No 
-

PLEJ;\SE PRINT 

Hearing Location: U\t~ \J '<./\1\CJ\/) 

Date: 'f,-1 .... ~ -- _t l9. ' 

Name: ~{.C1U\ 'YJ~o 

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Representing ~ i,nteresl? {\'\ 

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Has a· written testimony been submitted? · Yes_ No ,.,..,~ ........ 

. Will a written testimony be submitted? Yes_ No 1,..,. ... 

Do you wish to b~ informed of future or ' ,/ 

. final actions in this matter? Yes No~ 

·-

PLEASE PR,NT 

Hearing Location: 

Date: '{;;. \' ·'t s. ff/11 t c laud_ 

Name: -:s./ ·"L·s/ z.o 1 b 

Org·anization I Company: 

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Address: ~b '\J \t>\ ;>r ~ 

City: ~vlfvt<; v iJ /e- State: TN Zip: lf/7)7 

Representing what interest? 

~ 

Do you wish to present an oral testimony? Yes /_.No 

Has a written testimony been submitted? Yes~~ 

Will a written testimony be submitted? Yes~ No 

Do you wish to be informed of future or 

final actions in this matter? Yes·~o 

-

PLEASE PRJNT 

Hearing Location: VY\+ lleJvn on 

Date: 2-3 mAA;64~__. 2-0 10 

Name: (\f\.cu----vc:t n n. (A) orf-3· ofl 

Organization I Company: --···- E-Mail Address: ,Oct ka. vJ CJc{?, ~ ?(D [ t C() VVl 

Address: q "L.D VCcvyt(J_. Sl---:--

City: VVI+-. VQ..tr1on State: .-::QU . Zip:lf't&2o 

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rt\ 1 0 uJ V\ 1 P'e t so{\ &.. i"rtbv-Jtr 

Do you wish to pres~nt an o·ral testimony? Yes t/.....-No 

Has a written testimony been submitted? Yes No :£... 

Will a written testimony be submitted? Yes No .2_ 

Do you wish to be informed of future or 

final actions in this matter? Yes (./'"No 
PLEASE PRJNT 

Hearing Location: Mti 

Organi:z:ation/ Company:()..1J I<~ t,q:fc h 

Address: f?Oc) A-!~ ,':f&Jr. -; " , City: ff\rU ·' State;:ti) Zip:l.f77/;; 

Representing whaf Jnt~~est? 

PvitJe 1/e&lf;v 

Do you wish to present an oral testimony? 

Has a written testimony been submitted? 

Will a written testimony be submitted? 

Do you wish to be informed of future or 

final actions in this matter? 

PLEASE PRJNT . 

Date: 3- z :> -/G 

Name: .S/-,.tfb l+cc/c. 

Address: I C>SlO IV 

Yes__. NoV 

Ye'ii.Z No 

Yesl/ No:...==---' 

City: Jt.efo State: ItV Zip: 

Representing what interest? 

(ASI .Siw.l<Ak . 

Do you wish to present an oral testimony? 

Has a written testimony been submitted? 

Will a written testimony be submitted? 

YesL No 

Yes No~ 

Yes~ No 

,_D_o_y_o_u_w_is_h_t_o_b_e_i_n_fo..;.r_m_e:-d-o_f_fu~t-u-re_o~r---.:.--==-.;..;...-=;;;;:..--' _final actions .. II in this matter? Yes No L 

·---···-----· 

I:" I PKINI 

Hearing Location: f+l-·· v~'"'" ., F(r.._, S.\,lh '"' 

Date: >h>/t G 

Name: '[)q,.,-+«\ ( ~uc._ 

Organi:z:ation I Company: C:--1 ( 7--"-V\. I lA <:-::r· 

E-Mail Address: j;."" bQV' q Q "'-5 i. eo! 0\ 

Address: (D '1..{ '-1 O'v.rp" ~'> f..cl. 

City: ~~- Vu n~"' State: ::nlv Zip: '-Ff-C.;uJ 

Represetng what interest? · c· ,. , \zen~·. 

Do you wish to present an oral testimony? YesK No 

Has a written testimony been submitted? Yes NoY 

Will a written testimony be submitted? Yes"- No 

Do you wish to be informed of future or 

final actions in this matter? Yesl_ No 
-

PLEASE PRINT 

Hearing Location: (V'\"'"C, v '(, .(' 1"\Q '1"1 

Date: 3/~J/iG 

Name: l~~v''"' -n,~ ~""'~ P~v··1 Organization I Company: ·~~ Cl 1-1 -c... ;;:_......, 

E-Mail Address: 

Address: ~0:;.,. We..s \-. r ... i· \\.\" <s\f 

City: yy\\, L} {..... (" '" 0 f\ State: :1: ;\J · Zip: 4/G ~-o 

Representing wh~~erest? 

(._ 0 /}'\ 1'1'\ '-.>-. 0- t . 

' Do you wish to present an oral testimony? Yes ~ 

No t/ 

Has a written testimony been submitted? Yes No v 

.... 

Will a written testimony be submitted? Yes No 

Do you wish to be informed of future or "' final actions in this matter? Yes ·t/ No 
In the Matter Of 

A.B. Brown Generating Station of Indiana 

PUBLIC HEARING 

March 23, 2016 

CONNOR REPORTING 

111 Monument Circle, Suite 4350 

Indianapolis, IN 46204 

Phone: 317-236-6022 

Fax: 317-236-6015 

Toll 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 

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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 

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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. 

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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 

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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 

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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 

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V:, r~EPOR'riNG Connor Reporting 

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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 

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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 August 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 were 

violating that standard. The US EPA designated four 

areas in Indiana as nonattainment of the 2010 primary 

one -hour S02 National Ambient Air Quality Standard. 

IDEM addressed those four areas through revision of 

S02 emission limitations in the Indiana Rules at 326 

Indiana Administrative Code Article 7. IDEM has 

reques ted the US EPA approve these rule revisions into 

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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 

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JACONNOR. 

~ ltEPOR'lrMNG 

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March 23, 2016 

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 submit 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 Technica l Ass 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 

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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 monitor 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 

rates 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 Indiana State 

Implementation Plan. 

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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 

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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 

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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 

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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 

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Public Hearing 

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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 

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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 received comments and a list of folks who would like 

13 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 ma ke sure that the official record for this hearing 

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 st ateme 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. 

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Public Hearing 

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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 

13 page . Too many childre n and adults in our r egion 

14 strugg l e with asthma and other respiratory and 

15 cardi ovascular diseases exacerbated by pollution; and 

16 sulfur dioxide needs to be adequately addressed to 

17 protect public health. 

18 Sierra Cl ub ' s a na lysis 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 awed mode ling 

22 that will not ensure that the concentration of air 

23 pollution s tays bel ow the health standard. It is 

2 4 assumed that t he plant will never exceed t he emissions 

25 limi t -- an unrealistic assumption given that A.B. 

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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 

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Public Hearing 

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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 

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Public Hearing 

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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 

13 prove us wrong and redo the modeling and show us it 

14 didn•t make any difference or, alternatively, 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 used when you start cal culating the new 

18 emission limits for the Vec tren plant. 

19 The other big point that Sierra Club made was 

20 that the assumption seems to be that the Vectren plant 

21 always runs under st abl e operating conditions. Of 

22 course, tha t•s not true for any industrial plant. You 

23 have maintenance issues, you have equipment fai lure, 

24 you have start-up and shut-down conditions. These 

25 need t o be taken into consideration. 

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Public Hearing 

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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 estimate of the variability 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 ations a nd vari ability in the 802 

20 emissions 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. He llo everyone. My 

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Public Hearing 

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1 name is Mark, Bryant and I am making these comments 

2 representing two groups. First of all and foremost , 

3 I 'm a resident of Posey County. Also, I am a member 

4 of Val l eyWatch based in Evansville, Indiana, whose 

5 mission is to protec t the health and e nvironment of 

6 those who live in t he 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 Management is failing to live up to its miss ion to 

16 implement federal and state regulations to protect 

17 human health by allowing a c l early weaker 

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 issued 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 fail s to protect human health due to 

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Public Hearing 

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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 emissions threshold rather than the 

14 modeling method it chose . At the very l east , IDEM 

15 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 harder. 

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 required to act in the 

25 public interest is responsible for ongoing tragedies 

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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 plant 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 sulf ur dioxide discharge thr eshold they could 

13 easily meet, without regard for the health of those 

14 that live in the surrounding community. 

15 Since Vectren has repeatedly failed to . provide a 

16 reasonable sul fur dioxide emissions solution on its 

17 own, it is IDEM's duty and responsibility to work with 

18 Vectren and other organizations to develop and 

19 initiate a plan to protect the public health. 

20 Thank you for l e tting me submit these comments. 

21 HEARING OFFICER DERF: Thank you . 

22 MR. DELONEY: Thank you very much. 

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 notification if the re is 

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Public Hearing 

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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 

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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 

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Public Hearing 

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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 soybean 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 had changed some 

8 figures in the Source Code . Well, I 'm not a modeling 

9 expert, so I 'm not capable of going into that , but I'm 

10 cert a inly going to notify the EPA t o look into the 

11 Source Code of t he modeling Mr. Derf has done, because 

12 our experience in southwestern Indiana - - and 

13 particularly in that particular area -- shows that he 

14 was willing 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 should b e attainment under the sulf ur 

20 dioxide standards . And t here ' s not much other 

21 evidence besides his modeling that would indicate 

22 that. 

23 So that ' s part of t he comments which we just 

24 fil ed, i s a -- particularly a letter which was 

25 addressed to Janet McCabe, who is now the Assistant 

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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 

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Public Hearing 

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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 

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1 student here. 

Public Hearing 

March 23, 2016 

2 Bu t as I got a litt le older, I started taking 

3 more c l asses in ethics and partici 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 poll 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 tiful and wonderful, 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 met EPA standards? I was just floored. 

16 The danger was invisible to me and invisible to 

17 everyone e lse . 

18 As a student leader on campu s, I felt for t he 

19 students that are coming after me . 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 level s that were so high, 

25 these pol lution levels that were so high. I feel for 

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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 

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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 chil dren play 

10 outside? Are we putting their health at risk? And 

11 what about the health of our ne 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 their profits 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 Indiana and, indeed, from my 

29 

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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 more filters 

8 and scrubbers, they will merely pass on the cost to 

9 the consumer, as they have done in the past. Moving 

10 away from highly polluting, coal-burning energy 

11 towards nearly any a lternative would be a step toward 

12 the b e tter future for the tri-state , for our children 

13 and for our families . 

14 Should we believe Vectren and IDEM that their new 

15 proposal wi ll keep emissions below t hreshold levels? 

16 Their proposal a llows Vectren to submit sulfur dioxide 

17 right up t o the limit . Can we beli eve that Vectren as 

18 a corporation will not exceed these limits, when 

19 they've done so in the past in blatant disregard for 

20 the heal th of their neighbors. And who pays the cost? 

21 Vectren doesn 't. Those of us in the Marrs community, 

22 and my home is right in it . And those of us at USI 

23 are t he ones who are paying the hospital bills. We 

24 are the ones paying.the high electric rates that 

25 s ubs i dize the dirty energy production . And I ask 

30 

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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 resident of Evansville, 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 Evansville is 

11 rated the most miserable place t o l ive, or close, one 

12 of the reasons is because of t he poor health of 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 ects people with hea 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 fighting cancer; you ' ve got that constant onslaught of 

24 inflammation. It keeps our entire area unhealthy, and 

25 if we ' re going t o have a productive community, we need 

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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 Next we have 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 Vectr en regarding the new sulfur 

14 dioxide standards are overly optimistic. As a person 

15 likely to be affected, I would hope 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 causing direct and indirect human health 

23 e ffec ts . While Vectren claims to scrub emissions from 

24 the A.B. Brown plant, continuing problems with air 

25 qua lity in our area suggest that the me asures that are 

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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 Tha 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 just made about just being satisfied with attainment. 

20 I don't understand 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 ha n t hat. 

25 And I don't understand that mentality at all. Why 

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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. Watson . 

14 No other comment 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 (Pause) 

20 MR . DELONEY : If not , those t hat have already 

21 spoken that may wish to have additional time, you have 

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 Posey 

34 

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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 

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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 share 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. 

HEARING 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 

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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 

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317.236.6022 
1 

---------

0 

0.363 10:12 

0.426 10:8 

0.45 7:5 

0.588 10:21 

0.69 10:17 

0.727 10:1 

0.855 9:23 

1 -------

1 8:1,189:17,1910:4 

1,485.59 10:19 

1,745.7 10:16 

1,831.6 9:2410:10 

10 15:4 

10563 14:1 

11 9:12 

110(L) 13:8 

129-00010 2:10 

16 5:13 8:10 

16,000 7:2 

16th 11:7 23:24 

18th 7:15 

1979 25:8 

1980 25:10 

1999 23:24 24:1 

19th 11:2 

1st 14:1 

2 

2 6:15,217:108:1,189:17 

10:4,1411:8 

2,152.2 9:2110:7 

2,600 7:3 

2008 23:17 

2009 5:17 

2010 4:22 5:1,15,20 6:4, 

23 23:18 

Public Hearing 

March 23, 2016 Index: 0 363 .. appeanng 

2011 5:18 

2012 6:24 7:3,6,18 

2013 5:12 

2014 6:25 7:19 

2015 6:7 7:7,10,15 8:10 

9:1 

2016 6:15 9:1211:2,7 

12:814:1,2 

2016-01 4:1912:1214:6 

2017 6:16 

2020 6:17 

20th 7:9 

21st 9:1 

24-hour 5:5 9:25 10:2,11, 

13,20,22 19:5 35:4,5 

25 23:16 

29 5:13 

2nd 5:1 6:7,15 7:712:8 

--------

3 ---------

3 6:1510:14 

31st 6:16 14:2 

326 5:23 

35 25:10 

--------

4 ----------

4 6:16 

40 2:13 

5 

50 25:16 

51.102 2:14 

5th 5:12 

6 

6 2:3 

----------

7 5:24 

75 5:7 

7 

--------

8 -----------

81 13:25 

8511 2:11 

99th 5:8 

9 

--··-------

A ----------

A.B. 2:9 4:19 7:12,18,24 

8:14,18 9:1 ,9, 13,17 

11:16,18,2012:2,4,7,21 

13:15 15:7,20,2516:8 

17:2 20:20 21:2,5,16 22:4 

24:5 29:5,8 32:9,24 

acceptable 11:13 

accepted 6:8 

accepting 12:16 33:23 

accomplish 24:16 

accordance 11:7 

account 7:24 16:3 

accurate 21:9 

accurately 8:4 

acidic 32:21 

acknowledge 11:17 

act 2:2013:6,12,17 21:24 

action 3:169:712:15,16 

13:3 14:2 22:9 

actions 28:11 

actual 7:19 

add 4:9 30:7 

added 28:14 

addition 10:23 

additional 4:10 6:14 

13:1316:19 26:9 34:21 

address 14:9 35:22 

addressed 5:22 13:3 

15:16 24:25 

addressing 4:2116:21 

adequate 13:22 34:3 

adequately 15:16 20:18 

adjourned 36:11 

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Administrative 5:24 

admit 22:2 

adults 15:13 

advantage 34:23 

advised 13:23 

Advisory 23:24 

affect 31:15 

affected 32:15 

affects 18:16 31:17,19 

afforded 4:2 

agency 5:2 12:15 

agency's 13:3 

agreement 6:9 

ahead 2:4 

air 2:19,235:3,16,17,21 

6:12,21,24 7:1,17,20,22 

8:5,16 9:811:21,2312:3 

13:6,11,12,16,1715:22 

16:1118:6,1619:20 25:1 

26:3 27:14,24 28:5 32:24 

Alcoa's 16:5 

allergy 33:16 

allotted 4:6 

allowed 30:7 

allowing 20:17 

alternative 30:11 

alternatively 18:14 

ambient 5:3,16,17,21 

6:23 7:22 9:8 11:22 

13:11,16 

amount 11:2020:9,10 

29:24 

analysis 15:18 16:10 

angry 28:7 

animal 33:11 

announced 7:6 

announcing 5:13 

annual 5:5,8 7:415:12 

anymore 25:1 o 

appearance 3:6,18,20 

4:8 

appearing 3:9,12 

317.236.6022 
2 

applied 4:1 

appointed 2:20 

approach 11 :13 

approvable 13:10 

approval 13:7 

approve 5:25 

April 11 :2 23:24 

Arango 2:24 

area 4:21 7:16 8:5,14 9:9 

11:16,2112:6,71 6:4,11 

20:19,23 21:4 24:13,19 

29:4 30:2 31:24 32:25 

areas 5: 13,18,20,22 6:3, 

18,21,22,25 11:1017:22 

argument 18:4 

Article 5:24 

Assistance 7:23 

Assistant 24:25 

Associate 32:7 

assume 21:9 

assumed 15:24 

assumption 15:25 18:20 

assurance 12:3 

asthma 15:9,12,14 27:20 

29:18 31:16 35:15 

attack 15:9 

attain 11:22 12:5 

attaining 5:14 

attainment 6:2,6,18 

8:15,21 9:711:1512:8 

13:10,22 20:22 21 :5 

24:19 32:16 33:19 

attends 15:6 

attention 2:4 

attorney 3:12 

audit 21:15 

August 5:12 6:15 

authorized 3:13 

autoimmune 31 :20,22 

average 5:8 7:4 9:25 

10:3,7,11 '13, 19,20,22 

19:5 34:2 35:4,5 

averages 34:4 

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Public Hearing 

March 23, 2016 Index: a lied .. comment 

averaging· 9:22,24 10:9, British 7:5 9:16,2310:2, 

17 9,12, 18,21 

aware 23:1 Brown 2:9 4:19 7:12 

8:14,18 9:1,9,1411 :16, 

B 18,20 12:2,4,7,2113:15 

15:7,20 16:1,917:2 20:20 

21:2,5,16 22:5 24:5 29:6, 

B-mlnus 34:10 8 32:9,24 

back 3:328:331:13 Brown's 7:18,25 9:17 

background 8:2,9 Bryant 19:24,25 20:1 

Bar 26:22 BTU 19:4 

barely 32:18 budget 29:24 

Bartell 28:18,21 build 24:4 

based 5:7,16 7:21 8:15 built 25:7 

9:22,24,2510:2,7,9,10, 

12,18,20,2211:11 15:21 bulbs 30:3 

20:4 23:20 35:4 burger 26:22 

baseline 18:16 burning 32:2 

basis 19:5 21:1 26:22 

bears 20:12 c 

beautiful 26:17 27:11 

28:22 

calculated 34:4 

beauty 26:16 calculating 18:17 

behalf 3:10 California 6:8 23:20 

Berg 28:18,19,21 35:13 

call 24:14 

berm-style 30:5 

called 15:3 

big 16:7 17:25 18:19 calling 14:15 

31:18 camp 15:12 

billion 5:7 campus 26:14,20 27:18, 

bills 29:23 30:6,23 22 

Biological 23:19 cancer 31:23 

Biology 32:7 capability 19:15 

Blair 23:2,3 25:18,20 capable 24:9 33:24 

blatant 30:19 capacity 3:11 

blood 31 :18 captured 21:20 

card 3:8,18 14:16,23 body 31 :21 28:17 31:5 

Bowl 27:4 cardiovascular 15:15 

brag 26:1 20:11 

breathing 27:8,14,23 cards 3:6,20 4:8 34:14 

28:5 care 29:15 

breathing-related 

27:20 case 24:17 

Bredhold 14:24,25 15:1 category 31 :19 

briefly 4:24 caught 24:1 

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causing 8:6 32:22 

Center 23:18 29:15 35:19 

changed 24:7 

characterize 7:20 8:4 

11:21 

charge 22:7 

charges 20:7 

checked 29:3 

checking 29:5 

Chief 2:17 

child 29:15,17,18 

children 15:13 29:5,9,11, 

21 30:12 35:18 

Children's 29:15 35:18 

chose 21:14 22:8,10 

citizen 32:19 

claim 32:17 

claims 32:23 

classes 27:3 

Clean 13:6,12,17 

clear 16:20 

close 29:3 31:11 36:7 

closed 34:22 35:8,23 

Club 6:10 15:3 17:21 

18:19 23:5 27:5 28:19 

32:12 

Club's 15:18 17:19 23:21 

25:17 

coal 32:2 

coal-burning 30:10 

coal-fired 7:8 33:6 

Code 2:13 5:24 24:6,8,1 1 

colder 30:4 

colds 35:16 

colleague 35:14 

collect 12:10 

college 27:13 

combined 10:5 

comment 12:10,16,23 

13:23 14:4,11 ,23 28:17 

31 :5 34:14 

317.236.6022 
3 

commentary 33:16 

commented 8:20 

commenter 4:3,517:15 

cornmenters 3:25 4:2,8 

commenting 13:21 

comments 2:7 3:5 4:1, 

1012:1913:1,1214:1,12, 

1817:17,19,22 20:1 

22:20 23:22 24:23 33:18 

35:11,24 

Commissioner 9:2 

Commissioner's 4:19 

9:4,12,1411:1,2412:11, 

15 14:6 

common 18:4 

Communication 2:24 

communities 21:22 

community 20:10 22:14 

26:21 30:21 31:13,25 

32:1 

complaint 17:22 

complete 6:14,17 

completed 3:20 

completing 6:12 

compliance 10:24 35:20 

comply 16:18 

Conagra 24:4,17 

concentration 5:9 8:7 

15:22 

concentrations 8:3,9 

concern 32:10 

concerned 15:7 23:25 

31:8 

concerns 29:20 

concludes 12:19 

conclusion 17:7 

condemn 21:6 

conditions 18:21,24 

33:16 

conducted 7:17,21 

conform 2:13 

consent 11:8 

consideration 13:19 

18:25 

Public Hearing 

March 23, 2016 Index: commentarv .. dollar 

considered 8:22 13:2 

34:1 

constant 31 :23 

consume 29:23 

consumer 30:9 

contained 12:11,17 

contends 32:12 

continue 12:516:18 20:8 

26:1 

continued 9:7 

continuing 11 :22 32:24 

continuous 7:25 

contracts 31:17 

contribute 32:21 33:10 

contributors 18:6 

control 15:19 

conversations 25:23 

copy 4:13 25:3 

copying 4:14 

corner 14:20 

corporate 32:19 

corporation 30:18 

cost 4:15 30:8,20 

costs 16:17,22 

cough 33:15 

Council 6:10 

Counsel 2:24 

counties 17:25 

country 6:1315:5 22:8 

26:4 

county 2:12 7:13 12:22 

16:6,8 18:1,12 20:3,11' 

20,21 21:3,5 35:1 

County's 18:6,15 

couple 25:9 

Courier 15:11 

court 6:7,20 7:14 8:12 

14:21 

court's 6:13 7:7,11 

court-ordered 8:13 

Courtney 2:24 

cozy 21:23 

created 28:14 

credibility 23:25 

criteria 7:10 

crossing 18:12 

Culley 16:5 

curious 34:5 

current 16:119:10 

cut 18:8 

D 

daily 5:9 

damage 33:11 

danger 27:16 

dangerous 15:8 27:8 

29:7 

data 5:17 7:2519:2,3 

24:3,5, 15,18 31:14 

Database 7:2 

date 6:3 10:25 

daughter 15:6 

daughters 28:22,24 

day 19:12 

daycare 15:6 

deadline 6:118:13 

dealing 23:13 

December 6:16 9:1 

decree 11:8 

Defense 6:10 

degrade 33:10 

Deloney 2:22 14:14 

17:1519:24 22:22 25:18 

26:6,7 28:17 31:4 32:4 

33:14 34:13,16,20 35:2,6, 

21 36:7 

demonstrate 13:22 

demonstrates 17:11 

demonstratiOn 6:2,6 

Department 2:19 20:14 

deposition 32:21 

Derf 2:3,1717:1419:23 

22:2124:1,1128:16 

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33:13 36:10 

designate 6:20 8:14 12:7 

designated 5:19 

designating 6:1811:10 

20:21 21:4 

designation 8:11,19 

12:613:18,24 

designations 4:22 5:13 

6:12,14,17,22 7:17,22 

detailing 11:10 

devastation 21:21 

develop 22:18 

developed 21 :23 

deviation 19:13 

difference 18:14 

difficult 31:22 

dioxide 4:20,22 5:4 

13:1415:8,9,16,20,21 

16:1,4,918:12,1519:4 

20:22,24 21:1,8, 13,18 

22:6,9, 10, 12,16 24:20 

30:16 31:9,15 32:10,14, 

20 33:2 

direct 32:22 

directed 6:13,20 

Director 2:25 

dirty 30:25 33:9 

discharge 22:9,10,12 

disclose 21:10 

discussion 35:25 

disease 20:11 31:17,20, 

22 

diseases 15:15 

dispersion 7:18 8:16 

disregard 30:19 

distributed 3:7 

District 6:7,8 

dithers 33:8 

Diversity 23:19 

Document 7:23 

documents 4:1711:9 

dogwoods 26:18 

dollar 26:22 

317.236.6022 
4 

doubt 34:7 

downwind 32:9 

due 3:2414:2 19:7 20:25 

Duke 16:6 

dump 20:8 

duty 22:17 

E 

E.B. 16:5 

Earth 23:21 

easily 22:13 

easy 27:23 

echo 33:18 

ecosystem 33:10 

effective 6:3 10:25 33:1 

effects 31:8 32:23 

effluent 21:19 

effort 21:11 

efforts 11:17 33:2 35:17 

elapsed 4:7 

electric 7:8,1116:15 

22:7 30:24 

electrical 33:4 

electricity 33:7 

Elementary 29:13 35:18 

emission 4:20,21 5:23 

7:4,25 8:17,21,22 9:3,13, 

15.16,20.22 10:1.5.6.8. 

11.15, 17,21,25 11:1,3, 14, 

2312:1113:1414:5 

18:18 20:24 21:2 22:9 

25:6.15.22 27:24 29:7 

emissions 7:19 8:1 

11:20 12:2 15:24 19:3,20 

20:22 21:8.13 22:6.16 

26:2 29:5.18 30:15 32:23 

33:3,9 35:19 

emit 16:9 

emitted 7:2.3 11:20 

21:19 

employed 15:2 33:1 

employees 34:6 

end 4:7 26:9 

Public Hearing 

March 23, 2016 

energy 29:23,25 30:10, 

25 33:9 

Energy's 16:6 

energy~efficient 30:5 

enforceable 6:9 8:17,23 

9:5.1311:412:14 

ensure 4:2 9:7 12:2 

15:22 

entire 31:24 

environment 16:20 20:5 

22:3 23:9 29:1 

environmental 2:19 5:2 

20:14,18 27:5 

EPA 5:2,4,10,12.19,25 

6:4.9.13.17.20 7:1.8.17. 

24 8:5.11 '19 11 :8, 12, 15, 

1712:613:414:2 20:23 

22:5 23:15 24:10 25:1 

27:15 31:1 

EPA'S 7:2113:18.24 

equipment 18:23 21:16 

Eric 32:5.6 

error 16:12 

errors 16:10 

establish 9:1211:13.18 

established 5:6 7:10 

11:24 

estimate 19:14,15 

ethics 27:3 

evaluate 7:18 

Evansville 15:1.1120:4 

26:17,20,25 27:6 31:7,10 

33:4 

evening 14:19,2219:25 

22:23 36:5 

everybody's 2:4 

evidence 24:21 

exacerbated 15:15 

exceed 9:20 10:5,15 

15:24 22:5 30:18 

exceeded 19:10 20:23 

exceeding 33:21 

excellent 23:19 

excessive 20:9 

excuses 33:8 

executives 34:6 

experience 24:12 30:1 

experiences 27:21 

expert 24:9 

explore 28:25 

exposure 5:10 

extra 31:20 

extreme 29:18 35:15 

F 

facilities 25:13 

facility 21 :5,16 24:4 25:6 

29:16 32:9 

fact 17:2418:15 34:8 

failed 21:10 22:15 

failing 20:15 

fails 20:25 

failure 18:23 

families 30:13 

family 21:6 

family's 16:17 

favorable 22:3 

February 11:7 

federal 2:1313:2514:3 

20:16 

federally 8:23 9:5 11:3 

federally-enforceable 

11:1912:1 

feel 25:5 27:25 

fell 26:19 

felt 27:18,19 

fighting 31 :23 

figured 19:16 

figures 24:8 

filed 24:24 

fill 3:6 

filled 3:8 

filters 30:7 

final 3:1612:6,1513:3 

14:7 21:11 

Connor Reporting 

www.connorreporting.com 

Index: doubt..greater 

finalized 23:18 

finally 4:24 

financial 29:23 

find 18:7 31:1 34:5 

finds 25:17 

flawed 15:21 

Flint 22:1 

floor 26:10 34:22 

floored 27:15 

folks 14:12 

foremost 20:2 

forest 28:25 

fortunate 22:23 

forward 19:11,1434:17 

found 11:13 24:7 25:24 

26:17.21 29:1 

frankly 23:24 

fraud 24:14 

fraudulently 24:15 

friends 26:23 

front 15:12 

future 30:12 

G 

gasses 32:20 

generating 2:10 4:20 

7:9.12 8:14.18 9:912:4. 

2113:15 20:20 21:2 

geographic 21:4 

germane 13:1.1835:11 

Gibson 16:618:1 

give 22:25 25:18 

goal 24:16 

good 19:13.25 32:19 

grade 34:9 

grades 33:23 

gradients 8:7 

grant 24:3 

Gray 34:25 35:3 

greater 21:6 

317.236.6022 
5 

Green 16:7 

group 3:10,11 23:19 

groups 6:21 20:2 

Growing 26:15 

guess 19:22 

guidance 7:24 8:5 

H 

handed 3:21,24 

happy 25:5 35:6,21 36:1 

hard 28:23 

harder 21:19 

harmful 17:6 

harming 17:13 

heads 25:19 

health 15:17,23 16:12,17, 

19 17:13 20:5,17,19,25 

21:7,21 22:13,19 23:8 

29:10,11,19 30:20 31:8, 

12,14 32:22 33:11 

healthy 23:11 32:1 

heard 3:14,23 4:3 

hearing 2:3,6,12,15,20, 

21 3:4,1 5 4:8,11 ,18 12:9, 

23,24 14:9,11 '17 15:3 

17:11,1419:23 22:21 

23:4,6 28:16,20 33:13 

34:22 35:7,22,23 36:7,10 

hearings 2:14 

heart 31 :17 

heavily-polluted 15:5 

Heck 26:11 ,12 

held 2:12 

high 3:25 25:22 26:24 

27:24,25 28:13 30:6,24 

33:9 

higher 25:16 

highest 16:15 17:8 20:7 

22:7 29:24 30:2 33:5 

highly 30:10 

historical 19:2 

historically 20:23 

hold 33:7 

£ 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 9:17,21,2510:7,10, 

16,20 

house 17:6 

human 20:17,19,25 

32:22 33:11 

humans 5:11 

hundreds 16:22 

ID 2:10 

IDEM 5:22,24 7:17 8:1 0 

9:2,1111:5,1812:16 

15:1918:8 20:20 21 :10, 

12,14 22:11 25:25 30:14 

31:1 32:13 

IDEM'S 2:22 4:25 8:13 

11:12 20:25 21:9 22:17 

23:25 

identified 7:8,12 

identify 3:10 

illnesses 27:20 

impacting 18:15 

impacts 5: 11 

implement 20:16 

Implementation 2:9,15 

3:17 4:25 6:1,5 8:25 9:6 

11 :5,2512:12,18,20 13:1, 

6,8,9, 19 14:5 

impose 9:3 

imposing 4:20 

imposition 13:1 3 

improve 25:11 

incidents 19:18 

include 3:21 18:9 

included 8:4,8,16 18:2,3 

including 29:5 

incorporate 14:5 

incorporated 8:24 9:6 

11:4 

incorporates 10:23 

incorporation 11 :23 

12:10,17 

increase 16:18 

increased 20:12 

independently 21:16 

Indiana 2:8,12,18 5:20, 

23,24 6:1 ,3 7:9 8:24 9:6 

11:5,25 12:18,20,22,25 

17:9 20:4,14 22:2 24:12 

26:4 29:25 32:8 

Indiana's 8:1912:12 

13:5,1914:4,7 

indirect 32:22 

individuals 14:15 

industrial 18:22 

inevitable 19:18 

inflammation 31:21,24 

inform 35:17 

information 7: 16 21:10 

27:13 35:1 36:2 

Initial 7:21 

initiate 22: 19 

initiated 25:25 

inordinate 29:24 

inspection 4:13 

installed 17:1,4 21:17 

intended 16:19 

intentions 11:10 

interest 8:8 21 :25 

interested 2:6 3:3,5 

13:21 

interfere 13:10,16 

interrupted 25:20 

introduce 2:22 4:16 

invested 17:1,9 

invisible 27:16 

involved 27:4 

issue 15:4 22:12 

issued 9:11 20:21 

issues 18:23 

issuing 24:16 

Connor Reporting 

www.connorreporting.com 

Index: Green .. limitations 

J 

Janet 24:25 

January 9:12 

Jean 31:5,6 

Jessica 2:23 

John 23:2 

July 12:8 

June 5:1 

Justice 23:21 

K 

keeping 17:5 

Kentucky 16:8 

kind 34:5 

knew 26:24 33:23 

L 

lake 29:2 

large 24:4 

leader 27:18 

learn 28:25 

learned 15:4 27:5 

Learning 29:7,15 35:19 

LED 30:3 

left 26:7 

Legal 2:24 

letter 24:24 25:4 

letters 11 :9 

letting 22:20 

level 5:7 20:1 2 

levels 15:8 27:24,25 

28:13 29:8 30:4,15 31:9 

35:19 

light 30:3 

limit 3:25 4:4 15:25 16:1 

21 :8 22:25 26:6 30:17 

limitation 25:14 

limitations 5:23 8:17 

9:3,15,20 10:6,25 11:1 ,3, 

14,24 

317.236.6022 
6 

limits 4:21 8:21,22 9:5, 

13,1810:1511:1912:1, 

11,13,17,1813:14,22 

14:6 15:2116:818:18 

21:2 25:6 26:2 30:18 

linked 5:10 

list 14:12 

literally 24:2 

litigation 6:11 

live 15:4 20:6,15 22:14 

23:1131:11 32:8 34:7 

lived 30:1 

living 26:14 27:22 

local 32:15 

located 2:11 3:212:21 

Lois 34:25 

long 28:23 35:9 

looked 24:6 

lose 23:10 

lot 18:6 

Louie 26:22 

love 26:16,19 

loved 26:25 

lower 12:3 20:6 23:9 

25:5,14 

M 

mad 28:7 

made 4:12,1311:18 

18:19 33:19 

maintenance 18:23 

major 16:317:24 

make 11:2,25 14:17 

18:14 23:23 29:4 36:2,8 

makes 16:20 28:7 31:21 

33:8 

making 20:1 

Man 26:21 

Management 2:19 20:15 

manipulate 24:15,18 

manipulating 24:3 

March 6:7 7:6,9 14:1,2 

Public Hearing 

March 23, 2016 

margin 16:12 

Mark 2:1719:24 20:1 

35:8 

Markets 7:2 

Marrs 29:12 30:21 35:17 

Maryann 33:14 

matter 13:214:10 

maximum 5:9 

Mccabe 24:25 

Mccloud 32:5,6,7 

measures 32:25 

Media 23:23 

meet 6:4 21:17 22:13 

25:14 26:4 

meet all 26:2 

meeting 7:10 8:12 32:18 

35:8 

member 20:3 

members 21 :6 

mentality 33:25 

mentioned 8:12 17:24 

mere 32:16 

met 27:15 

method 21:14 

methods 10:24 21:12 

Michigan 22:2 

Midwest 30:2 

miles 29:3 32:8 

million 7:59:16,2310:1, 

8,12,18,2119:4 

millions 16:23 

mind 14:20 35:14 

mindful 4:3 

minimize 33:2 

minute 4:5 23:1 25:18 

minutes 4:1 15:10 

miserable 31:11 

miserly 30:4 

mission 20:5,15 

mitigate 28:13 

model 8:4,8 

modeling 2:18 7:18,21, 

23,248:1611:1215:21 

17:23 18:2,9,13 21:9,11, 

1424:1,8,11,2125:17 

models 32:12,17 

money 16:2517:10,12 

monitor 8:3 

monitored 8:8 

monitoring 5:17 7:25 

mother 15:6 

Mount 2:1112:21 

movements 27:5 

Moving 30:9 

N 

nation 33:5 

National 5:3,16,21 6:23 

7:22 9:811:22 13:11,16 

26:3 

natural 6:10 29:1 

nature 26:15 

nearby 8:1,317:25 

needless 21:7 

negligible 18:5 

neighbor 32:19 

neighbor's 29:11 

neighbors 29:20 30:20 

newer 22:525:13 

newly-monitored 6:22 

News 35:1 

nights 26:22 

Niles 17:15 

nonattainment 5:15,20 

6:1811:17 

Northern 6:8 

nose 33:15 

Not-a-gonna-wheeze 

15:12 

note 3:1129:14 

notice 3:15,164:18 5:13 

14:3 

Connor Report;ng 

www.connorreporting.com 

Index: limits .. overl~ 

notification 3:19 4:5 

22:25 

notify 24:10 

noting 12:14 

Number 2:10 

numbers 19:6,9 35:3 

0 ---------

offer 22:8 

offered 32:13 35:24 

Office 2:19,23,25 

officer 2:3,21 3:13 17:14 

19:23 22:2128:16 33:13 

36:10 

official 3:2214:17 35:25 

36:1 ,4 

officials 22:2 

Ohio 20:6 23:9 

older 27:2 

one-hour 4:22 5:6,9,15, 

21 6:4 8:20 9:8,22,24 

10:7,9,17,1911:11,22 

12:513:23 

ongoing 21:25 

onslaught 31:23 

open 4:12 14:11 

opening 12:23 

operating 9:1910:14 

18:21 

operation 10:4 19:6 

operations 19:17,19 

opportunity 2:7,16 4:2 

34:23 

optimistic 32:14 

oral 3:23,25 4:914:13 

order 4:1,19 6:9,13,20 

7:8,11,14,19 8:12 9:4,12, 

1410:2311:2,2412:11, 

13,15 14:6 20:21 ,25 21:1' 

11 24:3,15,18 

ordered 21:15 

organization 3:10,11 

organizations 22:18 

overly 32:14 

317.236.6022 
7 

panel 21:4 

pants 24:1 

p 

parent 28:21 29:16 

parents 33:22 35:17,18 

part 2:141 3:2 23:14 

24:23 35:25 

participating 3:4 27:3 

particulate 31:16 

parties 3:3 

parts 5:7 

pass 16:21 30:8 

passes 31:18 

past 26:13 27:14 30:9,19 

Pause 34: 15,19,24 36:6 

pay 17:8 29:24 30:2 33:9 

payer 16:14,25 

payers 16:23 17:7 20:7 

paying 16:15 30:23,24 

payment 4:14 

pays 30:20 

people 18:7 23: 11 25:24 

26:20,23 31:17,19 

people's 31:16 

percent 25: 16 

percentile 5:8 

period 9:22 10:1,8,1 0,11, 

17,20 

permanent 8:22 9:4,1 3 

11 :18 12:1,13 

permit 24:3,17 

person 3:14 4:14 19:5 

25:1 32: 14 

persons 2:7 

pertain 14: 10 

pertains 12:24 

petitioning 22: 11 

pick 19:9 

picked 15:10 

place 17:5 23:1126:18 

£CONNOR REPORTING 

Public Hearing 

March 23, 2016 Index: panel .. recommendation 

31 :11 

plan 2:9,15 3: 17 5:1 6:1,5 

8:25 9:7 11:5,25 12:12, 

18,20 13: 1,6,8,9,20 14:5 

15:1816:3, 11 22:19 

plant 15:7,2416:6,7 

17:23 18:18,20,22 22:5 

24:5 25:7 32:11,24 33:1 0 

plants 7:9,111 6:5,17 

17:12,25 

play 19:20 28:24 29:9 

played 28:12 

point 8:23 18:19 24:6 

poisoning 22:1 

polls 31:10 

pollutants 20:9 27:7 

32:21 

polluted 27:7 28:7 

polluting 30:10 

pollution 15:8,15,23 

16:9 17:3,5,10,25 20:12 

27:25 31:16 33:7 

poor 31:12,14 

populations 21:22 

Posey 2:11 7:1212:22 

18:6,15 20:3,1 1 ' 19,21 

21:3,5 34:25 

potential 3:24 

potentially 16:22 

potentially-flawed 

32:17 

pounds 7:5 9:15, 17,21 , 

23,25 10:1,7,8,10,12,16, 

18,19,21 19:4 

power 7:9,1117:25 20:20 

21:2 22:5 32:16 

preliminarily 11:15 

premium 16: 16 

Press 15:11 

pretty 19:13 25:2,24 

prevent 17:12 

previous 4:9 5:5 

previously-adopted 

2:16 

primary 5:3,5,15,20 6:23 

17:22 

prioritizing 29:19 

problem 22:11 28:14 

problems 29:18 32:24 

35: 15 

procedures 21:15 

proceeding 3:22 

proceedings 3:1 

process 13:18 

processes 17:10 

processing 24:4 

produce 33:6 

producers 16:4 

product 16:16 

production 30:25 

productive 31 :25 

Professor 32:7 

profits 29:19 

Program 2:25 

promulgate 12:6 

properly 14:18,21 

property 28:23 29:2 

proposal 30: 15, 16 

proposed 2:8 4:25 8:16 

11:612:19,2516:8 

protect 15:17 16:19 20:5, 

16,19,25 22:19 23:8 

protected 19:21 

protecting 17:3 

Protection 5:2 

protective 19:16,17 

proud 23:14 

prove 18:10,11,13 

provide 2:6,7 4:4 11 :14 

12:3 14:13 22:15 34:17 

provided 6:1 

providing 3:5 

provisions 2:13 

public 2:6,14,21 4:12,18 

12:9,10,23 13:2 14:11 

15:17 16: 12 21:25 22:19 

23:8 35:22,24 

Connor Reporting 

www.connorreporting.com 

publish 14:3 

published 5:12 13:25 

purpose 12:9 23:8 

put 17:11 25:6 33:20 

putting 29:10 

Q 

quality 2:20,23 5:3,16, 

17,21 6:12,21 ,24 7:1,20, 

22 8:5 9:8 11 :21,23 12:3 

13: 11,16 18:619:20 26:3 

32:25 

question 16:25 35:1,13 

questions 14:9 34:3 

35:7,9,22 36:9 

quick 18:8 

quit 25:20 

R 

radar 23:5 

raised 34:4 

rate 7:4 9:22 10:1 ,8, 11, 

17,2116:14,16,23,25 

17:7 20:7 

rated 31:11 

rates 4:21 8:18 9:3,16,21 

10:6,16 11:313:1416:15 

17:9 20:7 22:7 25:15,22 

29:25 30:24 33:4,7,9 

reading 17:21 

realistic 21:12 

realize 27:9 

reason 17:8 18:3 25:25 

reasonable 16: 12 22:16 

reasons 31:12 

receive 3:18 

received 14:12 

recent 16:2 

recently 20:21 

recess 29:12 

recognized 3:4 

recommendation 8:13, 

15 

317.236.6022 
8 

recommendations 7:16 

8:11,2011:1213:24 

recommended 11:16 

recommends 8:6 

record 3:22 4:17 13:2 

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 

23:5 

requesting 28:20 

requests 3:15 

required 20:18 21:24 

25:14 

requirement 13:12,17 

19:16 

requirements 10:24 

19:10 

reservations 28:3 

resident 15:2 20:3 21:3 

31:7 

residential 22:7 

residents 20:13 

resolve 6:11 

Resources 6:10 

respect 26:15 

respectful 4:4 

respiratory 5:11 15:14 

20:11 

response 7:7 

Responses 13:24 

responsibility 22:17 

28:11,12 

responsible 13:4 21:25 

result 7:14 33:8 

retirement 7:7 

reviewed 8:19 9:11 

reviewing 6:513:5 

revise 2:1614:4 

revised 5:2 

revision 2:8 3:17 4:25 

5:22 6:612:20,25 13:6,9, 

20 

revisions 5:2513:8 

revoked 5:5 

risk 21:7 29:10 

river 23:9 

Rivers' 16:7 

Road 2:11 

Robert 16:7 

role 28:12 

rolling 9:2510:2,11,13, 

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 

11:8 

rounds 6:15 

rule 5:25 

rules 2:16 5:23 6:3 

runny 33:15 

runs 8:418:21 

s 

safe 29:4,9,12 

safeguards 16:19 

safely 28:24 

satisfied 33:19 34:9 

school 26:24 33:21 

Scott 2:22 3:8,21 4:4 

14:14 

scrub 32:23 

scrubber 21:17 25:12 

scrubbers 17:1,4 30:8 

scrubbing 21:18 

searched 28:22 

seasonal 8:2 

seconds 26:7 

Section 2:17,18 13:8 

secure 29:22 

seek 16:21 

self-explanatory 25:2 

sends 29:16 

senior 27:12 28:5 

sense 18:4 

separate 14:3 

September 7:15 8:10 

Connor Reporting 

www.connorreporting.com 

service 33:4 

services 33:10 

set 21:1,12 30:4 

share 14:19 36:2 

shareholders 16:21 

sheet 3:2 

Shelby 26:11,12 29:14 

shocked 27:11,13 

shorter-term 5:10 

show 8:2118:13 24:18 

showed 5:18 

showing 3:8 6:2 

shows 15:18 24:13 

shut-down 18:24 

Sierra 6:1015:2,18 

17:19,2118:19 23:5,21 

25:16 27:5 28:19 32:12 

sign-in 3:2 

significant 8:6 

simple 19:12 

simple-minded 19:1 

simply 22:11 35:23 

situation 25:12 29:23 

skeptical 18:7,11 

slightly 9:18 

small 29:2 

S02 5:4,6,10,15,21,23 

6:4,23 7:3,5,21,25 8:1,2, 

3,17,20 9:3,8,13,15,17,20 

10:5,15,2511:11,19,20, 

2212:1,2,5,613:2317:24 

19:19 23:13 25:6 28:13 

29:8,17 32:1 35:19 

sole 12:9 

soliciting 14:4 

solution 22:8,16 31:2 

solve 22:10 

son 35:15 

source 2:10 7:20 8:7 

24:6,8,11 

sources 7:1 8:2,6 17:24 

18:10 

Southern 32:8 

317.236.6022 
9 

southwestern 24:12 

sox 32:20 

soybean 24:4 

speak 14:16 

speakers 26:8 

speaking 35:14 

specific 14:10 19:9 

spoke 29:16 

spoken 34:21 

spokesperson 3:13 

spring 26:18 

stable 18:2119:17 

stake 16:13 

standard 4:23 5:3,7,16, 

19,21 6:4,24 7:22 9:9 

11:11,2312:513:7,11,17, 

2315:2316:1019:13 

20:18 21:18 23:13,15 

32:18 

standards 5:6 20:24 

24:20 26:3 27:15 32:14 

start 18:17 

start-up 18:24 

started 2:5 27:2,9 

state 2:8,9,15 3:16 4:25 

6:1,5 8:24 9:6 11 :5,25 

12:12,18,20,2513:5,7,9, 

1914:516:16 20:8,16 

33:5 

state-of-the-art 25:10 

statement 14:22 

statements 3:23,24 4:9 

14:13 

states 5:1,14 7:1411:9 

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 

30:16 

submittals 2:15 

submitted 4:8 9:2 11 :8 

14:15 

submitting 23:21 

subsidize 30:25 

substantially 18:16 

sued 23:16,17 

suffer 20:13 

suggest 32:25 

suggestion 19:1 

suing 23:14 

sulfur 4:20,22 5:413:13 

15:8,9,16,20,2116:1,4,9 

18:11,1519:4 20:22,23 

21:1,7, 13,18 22:5,9, 10, 

12,16 24:19 30:16 31:8, 

15 32:10,13,20 33:2 

summer 29:1 

supplemented 8:10 

supplied 22:1 

supply 19:2 

support 2:18,2511:9 

17:19 33:2 

supporting 7:16 

surrounding 7:20 8:14 

9:911:16,2112:4,7 20:10 

22:14 

suspect 25:25 

T 

taking 27:2,23 

talked 26:23 

talks 25:1 

taught 26:15 

teacher 33:22 

technical 2:18 7:23 11:9 

technically 27:12 

technology 21:1725:12 

Temporally-varying 

8:2 

terms 19:7 

testament 20:12 

testimony 16:24 34:17 

Thermal 7:5 9:16,23 

10:2,9, 12,18,22 

thermostat 30:3 

thing 14:16 

thinking 18:5 

thought 19:4 

threatens 16:16 

three-year 5:8 

threshold 21:13 22:6,12 

30:15 

time 3:25 4:4,6,7,16 8:23 

9:24 22:24 24:16 25:7,9 

26:6,9,10 28:2,10 34:21 

timeline 11:8 

Tin 26:21 

tip 16:10 

today 3:514:2515:11 

32:10 35:14 

told 17:8 26:24 

tons 7:2,3 

toxic 20:9 

tragedies 21:25 

transcript 4:11,12,13 

tri-state 30:12 

trigger 15:9 

triggers 31:21 

Connor Reporting 

www.connorreporting.com 

Trivia 26:21 

true 18:22 

tulips 26:19 

types 36:8 

u ----------- -----

unclassifiable 6:19 

understand 16:14 23:11 

33:20,25 

unhealthy 16:1120:9 

31:24 

unit 9:1910:14 

United 5:1 

units 7:5 8:1,18 9:16,17, 

2310:2,4,5,9,12,18,22 

17:2 

University 32:8 

unrealistic 15:25 

unstable 19:19 

updated 7:15 

upsetting 29:8 

user-friendly 22:11 

USI 26:13,16,25 27:10 

28:3,9 29:3,14 30:22 

USI'S 35:18 

utilities 21 :24 33:6 

utility 32:16,18 33:8 

v -------

valley 20:6 23:9 

Valleywatch 20:4 23:7, 

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 

317.236.6022 
10 

Vectren's 2:9 15:6 16:5 

19:15 

verify 21:17 

Vernon 2:1112:22 

vicinity 8:7 

violated 16:1 

violating 5:19 

violations 6:23 

voice 32:10 

volume 3:25 

voluntarily 9:1 

vulnerable 21:22 29:20 

w 

Warrick 16:5,6 18:1 

water 22:1 

Watson 33:14,15 34:13 

weaker 20:17 

Webb 31:5,6 

Webster 16:7 

Welborn 2:11 

Wendy 14:2415:117:20, 

24 

west 24:5 

wife 28:22 29:22 30:3 

win 23:10 

winter 30:4 

wishes 26:9 34:17 

wondered 27:21 

wonderful 27:11 

wooded 29:2 

work 22:1729:331:1 

34:6 

worldwide 26:2 

worth 12:14 19:3 

written 3:15,234:11 

16:24 17:17 

wrong 18:11,13 29:21 

y 

year 26:14 27:4,12 28:5 

29:7 

Public Hearing 

March 23, 2016 

years 5:17 6:24 8:1115:4 

16:217:7 19:3 22:4 23:16 

25:9,11 26:13 27:14,23 

28:6 

Connor Reporting 

www.connorreporting.com 

Index: Vectren's .. years 

317.236.6022 
~~i¥M ?:::::===1 n=d=i=a=n=a=D=e=p=a=r=t=m=e=n=t=o=f=E=n=v=ir=o=n=m=e=n=t=~=:==-=~=a=n=a=g=e=m=e=nt===~ ~ 0 0- Protecting Hoosiers and Our Environment Since 1986 AStatethat~ 

COMMENT SHEET 

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 of my close 

friends have noticed and many have told me to consider giving up my job just to live somewhere 

that might be healthier, I cannot help but to think that the excessive and harmful levels of sulfur 

dioxide in the air where I work and near where I live are a key part of the 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 of Hoosiers 

may literally be on the line. 

I know that the EPA says that local air quality fails to meet and attain safe levels of sulfur 

dioxide. Protection from air pollution is a legal right to which every American citizen is 

entitled. The citizens of this 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 of the citizemy 

here. Knowing that part of why 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 of why I can't breath, that I am also paying some of the 

highest utility rates in the nation-all because of the supposedly high environmental standards 

that Vectren ostensibly meets-is a kick in the teeth. Vectren insists that rates are high because 

of the cost of cleaning 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 of the students at USI, and the small vulnerable bodies of the 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 of a project. Building in wiggle room for mistakes, 

oversights, or unforeseen challenges is simply wise planning. If IDEM & 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 of the health oflocal population as citizens of this 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 to justify 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 of plants like ConAgra. In this instance, IDEM 

seriously failed in their analysis of the 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 of protest 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 of Environmental Management 

Office of Air 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 behalf of Siena 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 of Environmental 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 S02 NAAQS. 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 of the 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 of the 1-hour S02NAAQS, 

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 of actual emissions over 2012-

2014 indicates that Brown's actual S02 emissions have been causing violations of the 2010 

standard. Enclosure 3 at 22. These violations tln·eaten public health in south em Indiana. 

As IDEM is aware, exposure to S02 causes serious health problems and thus preventing 

any violation of the S02 NAAQS anywhere in Indiana is of utmost 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 of the S02 NAAQS." 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 of that 

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 of the !-

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 of the most impmiant inputs to the model is the background concentration of 802• 

IDEM modeled only two major sources ofS02 as part of the 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 of Brown, id., but in another place says it focused only on background 

sources within 10 Ian. I d. at 7 ("Indiana focused on areas within 10 km for each of the 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 of Brown. IDEM also excluded the Culley power plant, a 

two-unit, coal-fired power plant. Culley is approximately 35 km east of Brown. Finally, IDEM 

excluded the large Gibson power plant, which is approximately 50 km north of Brown. 

2 
IDEM 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 of emissions. 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 of very 

prescriptive procedures for identifying which background sources should be included in the 

modeled emission inventory for NAAQS compliance demonstrations." EPA, Additional 

Clarification Regarding Application of Appendix 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 of which 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 of modeled 

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 of the 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. If IDEM 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 of which 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 !-hour N02 standard than for the annual standard." !d. at 16. Here, the 

Order establishes one set of limits 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 of the 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. 

If IDEM had inclnded Wanick, Culley, or Gibson, or any combination of those 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 of 7 5 ppb. 

Given that the decision regarding which major sources to include in the background is 

dispositive, IDEM's exclusion of emissions 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. 

3 
B. IDEM's Reliance on Projected Emissions Under the New Permit Limits Does Not 

Acconntfor Exceedances of Permit 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 of every 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 of coal-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 of sulfur 

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 of the emission limits. 

As a result of this 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 of the percentage of operating 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 of what method 

1 EPA recently concluded that this provision of the 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 of the Indiana SIP has not yet 

been revised and instead remains in force. 

4 
it uses, IDEM's modeling assumption that the Brown units will comply 100% of the 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 of the new S02 limits for the Brown plant resulted in a !-

hour S02 concentration of 196.08 f1g/m3

, just barely below the 1-hom S02 NAAQS 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 of a microgram per meter cubed. The margin by 

which IDEM claims that Posey County is in attainment may fall well within the margin of error 

of the model. 

Second, IDEM's calculations are inconsistent with EPA regulations on how to calculate 

1-hr S02 concentrations for purposes of compliance with the 2010 1-hr S02 NAAQS. 

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 S02 concentration (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 S02 NAAQS," 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 of these comments. Please do not hesitate to contact us 

if you have any questions. 

5 
Sincerely, 

Matthew Gerhart 

Earthjustice 

633 17111 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 of Environmental Management 

Telephone: (317) 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 of Sierra 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 County . 

Pursuant to 40 C.F .R. § 51.102, 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 of the date, place, and time of the 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 Valley 
Sierra Club Beyond Coal Campaign 

Telephone: (812) 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 of the 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 of 75 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 of the 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 of the 802 NAAQS" 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 of IDEM'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 of the 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 S02 modeling 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 "S02 NAAQS 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 S02 emission 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 of the source of interest 

should be modeled and that number of sources is expected to be small. Sources located 

fmiher from the source of interest will be captured in the background concentrations that 

are measured at nearby monitoring sites. 

In the case of A.B. Brown, the Buena Vista S02 monitoring site in Evansville was 

deemed representative, if not conservative, for 1-hour 802 background 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 of thumb" 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 I 0 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 of interest 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 of the 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 of the limits. IDEM's 

modeling assumes A.B. Brown operates under stable conditions and ignores the realworld operations of coal-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 of cunent requirements. A statistical 

analysis (including standard deviations and mean) for estimate of variability 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 of emission 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 of Units 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 of the 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 of comment 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 of the American Meteorological 

Society/Environmental Protection Agency Regulatory Model (AERMOD) software. The 

commenters question the inconsistency ofiDEM's calculations of the !-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 of regulatory applications in all types of tenain. 

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 of U.S. EPA's 

Suppmi Center for Regulatory Atmospheric Modeling (SCRAM) contains additional 

infmmation concerning the accuracy of AERMOD and the issue of rounding 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 Ill 0 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 S02 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 of A.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 of the Clean Air Act. The mandate requires each 

NAAQS be periodically reviewed to determine if the 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 of people, typically children 

and the elderly, therefore, the standards are considered conservative in nature. In the case 

of the 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 of this standard is protective of public health and welfare, with an adequate 

margin of safety of all groups of people, 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 of the ·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 of the 2010 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 S02 averaging time. Both units can never exceed 

2,152.2lbs S02/hr. (0.426 lbs S02/MMBtu) when operating together. Therefore, Indiana 

modeled the S02 proposed emission limitations recommended by A.B. Brown. Five scenarios 

were modeled. Modeled concentrations for all five of A.B. Brown's operating scenarios were 

added to the temporally ·varying 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 scenario 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 1076.445 645.66 406.5 ---.. ··· --~ 

.... &., __ ._.,.._,.. __ . ~-~ . ---.----·-· - -·- --·-- Boiler2 Modeled lb/hr 641.4 1081.575 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 of Enclosure 3 oflndiana's Preliminary Recommendations 

Concerning Round 2 Air Quality Designations for the 2010 Primary 1-hour S02 Standard.