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

May 26,2011

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

Dear Ms. Hedman:

Re: Request for Redesignation Petition and Maintenance Plan for the Indiana Portion (Lake and Porter Counties) of the ChicagoGary-Lake IL-IN Nonattainment Area for Fine Particles

The Indiana Department of Environmental Management (IDEM) submits a Redesignation Petition and Maintenance Plan for the Indiana Portion (Lake and Porter counties) of the Chicago-Lake IL-IN Nonattainment Area, which was designated as nonattainment of the annual standard for fine particles on April 5, 2005. IDEM conducted

a public hearing concerning the Redesignation Petition and Maintenance Plan on May 18, 2011, and the public comment period concluded on May 20, 2011.

This submittal documents the public review process, including a detailed summary of and response to substantive comments.

The attached document consists of the following:

Redesignation Petition and Maintenance Plan • A formal request that the Indiana Portion (Lake and Porter counties) of the Chicago-Lake IL-IN Nonatlainment Area be redesignated to attainment and reclassified as maintenance. It contains and meets the requirements set forth in Section 107 of the Clean Air Act and in United States Environmental Protection Agency (U.S. EPA) Redesignation Guidance.

• A maintenance year of 2025 is established and 2015 and 2020 are analyzed as interim years.

• The appendices of the document contain historical air quality trend data, projected emission inventory data, and thorough documentation of the mobile emissions analysis.

Recycled Paper (i) An Equal Opportunity Employer Please Recycle 

### VMs. Hedman Page 2

Motor Vehicle Emissions Budgets

• Contained in the Redesignation Petition is a new Motor Vehicle Emissions Budget for 2016 and 2025. The Northwestern Indiana Regional Planning Commission's (NIRPC's) travel demand forecasting model and U.S. EPA's software program referred to as MOBILE6.2 were used to determine emissions for the annual fine particle nonattainment area.

• A conservative margin of safety was applied to the 2016 and 2025 projected emissions.

• The travel demand model was updated with the best available assumptions.

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

IDEM requests that U.S. EPA proceed with review and approval of this submittal. If you have any questions or need additional information, please contact Scott Deloney, Chief, Air Programs Branch, at (317) 233-5694.

Sincerely,

Keith Baugues Assistant Commissioner Office of Air Quality

KBlsadlghf Enclosure: Request for Redesignation Petition and Maintenance Plan Under the Annual National Ambient Air Quality Standard for Fine Particles for the Indiana Portion of the Chicago-Gary-Lake County, IL-IN Nonattainment Area

Cc: John Summerhays, U.S. EPA Region 5 (wi enclosures) Matt Rau, U.S. EPA Region 5 (wi enclosures) John Mooney, U.S. EPA Region 5 (no enclosures) Cheryl Newton, U.S. EPA Region 5 (no enclosures) Pat Morris, U.S. EPA Region 5 (no enclosures) Bill Brown, NIRPC (wi enclosures) Rob Kaleel, Illinois EPA (wi enclosures) Scott Deloney, IDEM (no enclosures) Christine Pedersen, IDEM (no enclosures) Gale Ferris, IDEM (wi enclosures)i 

# REQUEST FOR REDESIGNATION AND MAINTENANCE PLAN UNDER THE ANNUAL NATIONAL AMBIENT AIR QUALITY STANDARD FOR FINE PARTICLES

For the Indiana Portion of the

Chicago-Gary-Lake County, IL-IN Nonattainment Area for Fine Particles

Lake and Porter Counties, Indiana

Prepared By: The Indiana Department of Environmental Management

May 2011ii 

### This page intentionally left blankiii TABLE OF CONTENTS

1.0 INTRODUCTION

.................................................................................................................... 1

1.1 Background ................................................................................................................ ................1 1.2 Geographical Description .................................................................................................. ........3 1.3 Status of Air Quality ..................................................................................................... .............3

2.0 REQUIREMENTS FOR REDESIGNATION

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

2.1 General ................................................................................................................... ....................3 2.2 Fine Particles Monitoring ................................................................................................. .........3 2.3 Emission Inventory ........................................................................................................ ............4 2.4 Modeling Demonstration .................................................................................................... .......4 2.5 Controls and Regulations .................................................................................................. .........4 2.6 Corrective Actions for Potential Future Viol ations of the Fine Particle Standard ....................5

3.0 FINE PARTICLES MONITORING

..................................................................................... 5

3.1 Fine Particle Monitoring Network .......................................................................................... ...5 3.2 Ambient Fine Particles Monitoring Data ...................................................................................6 3.3 Quality Assurance ......................................................................................................... ...........14 3.4 Continued Monitoring ...................................................................................................... ........14

4.0 EMISSION INVENTORY

.................................................................................................... 14

4.1 Emission Trends ........................................................................................................... ............14 4.2 Base Year Inventory ....................................................................................................... .........25 4.3 Emission Projections ...................................................................................................... ..........26 4.4 Demonstration of Maintenance .............................................................................................. ..32 4.5 Permanent and Enforceable Emission Reductions ..................................................................33 4.6 Provisions for Future Updates ............................................................................................. ....33

5.0 TRANSPORTATION CONFORMITY BUDGETS

.......................................................... 33

5.1 On-Road Emission Estimates ................................................................................................ ..33 5.2 Overview .................................................................................................................. ................33 5.3 Analysis Years ............................................................................................................ .............34 5.4 Emission Estimates ........................................................................................................ ..........34 5.5 Motor Vehicle Emission Budget ............................................................................................. .35 5.6 Commitment to Amend Motor Vehicle Emi ssion Budgets Using Motor Vehicle Emission Simulator (MOVES) ............................................................................................................ ....35iv 6.0 CONTROL MEASURES AND REGULATIONS

............................................................ 36

6.1 Reasonably Available C ontrol Technology (RACT) .............................................................36 6.2 Implementation of Past State Im plementation Plan (SIP) Revisions .....................................36 6.3 Nitrogen Oxides (NO x ) Rule ..................................................................................................36 6.4 Measures Beyond Clean Air Act SIP Requirements ..............................................................37 6.5 Controls to Remain in Effect ............................................................................................. .....41 6.6 New Source Review Provisions ............................................................................................. 41

7.0 MODELING AND METEOROLOGY

.............................................................................. 42

7.1 Summary of Modeling Results to Support Rulemakings .......................................................42 7.2 Lake Michigan Air Directors Cons ortium (LADCO) Round 5 Speciated Modeled Attainment Test Results ..................................................................................................... ....46 7.3 LADCO Round 5 Particle S ource Apportionment Results ....................................................47 7.4 Summary of Existing Modeling Results ................................................................................56 7.5 Meteorological Analysis for Lake and Porter Counties, Indiana ...........................................56 7.6 Surface Air Conditions Present During Hi gh Fine Particle Concentration Days ...................56 7.7 Upper Air Conditions Present During High Fine Particle Concentration Days .....................56 7.8 Analyses of Atmospheric Conditions Duri ng High Fine Particle Concentration Days .........57 7.9 Summary of Air Quality Index Days in Lake and Po rter Counties, Indiana ..........................57 7.10 Summary of Meteorological Analysis fo r Lake and Porter Counties, Indiana ......................59

8.0 CORRECTIVE ACTIONS

.................................................................................................. 59

8.1 Commitment to Revise Plan ................................................................................................ ...59 8.2 Commitment for Contingency Measures ...............................................................................60 8.3 Contingency Measures ..................................................................................................... ......60

9.0 PUBLIC PARTICIPATION

.............................................................................................. 61

10.0 CONCLUSIONS

.................................................................................................................. 62

FIGURES

Figure 3.1 Chicago Nonattainment Area ......................................................................................... 6

TABLES

Table 1.1 National Ambient Air Quality Standards for Fine Particles (PM 2.5 ) ...............................2 Table 3.1 Monitoring Data for Indian a’s Portion of the Chicago Area ...........................................7 Table 3.2 Monitoring Data for Illinois’ Portion of the Chicago Area .............................................8 Table 4.1 Comparison of 2008 Estimated and 2025 Projected Emission Estimates, Lake and Porter Counties, Indiana ................................................................................................32 Table 4.2 Comparison of 2008 Estimated and 2025 Projected Emission Estimates, Entire Chicago Area ................................................................................................................. 32v Table 5.1 Emission Estimates fo r On-Road Mobile Sources .....................................................34 Table 5.2 Motor Vehicle Emission Budgets for Lake and Porter Counties ...............................35 Table 6.1 Trends in Electri c Generating Unit (EGU) NO x Emissions Statewide in Indiana .....37 Table 7.1 Clean Air Transport Rule M odeling Results from U.S. EPA - 2010 .........................43 Table 7.2 LADCO Round 6 M odeling Results for Annual PM 2.5 – Without the Clean Air Interstate Rule Emission Reductions ..........................................................................45 Table 7.3 LADCO Round 5 Speciated Modeled Attainment Test Modeling Results for Lake and Porter Counties, Indiana .............................................................................47 Table 7.4 Ranking and Percentage of Highest Number of Days at Air Quality Index Levels of Health Concern ...........................................................................................59

GRAPHS

Graph 3.1 Fine Particle Design Values fo r Indiana’s Portion of the Chicago Area, 2006 through 2010 ......................................................................................................10 Graph 3.2 Fine Particle Design Values fo r Illinois’ Portion of the Chicago Area, 2006 through 2010 ......................................................................................................11 Graph 3.3 Annual Fine Particle Trends fo r Indiana’s Portion of the Chicago Area, 2006 through 2010 ......................................................................................................12 Graph 3.4 Annual Fine Particle Trends fo r Illinois’ Portion of the Chicago Area, 2006 through 2010 ......................................................................................................13 Graph 4.1 NO x Point Source Emission Trends, Lake and Porter Counties, Indiana, 2002, 2005, and 2008 .................................................................................................15 Graph 4.2 Sulfur Dioxide (SO 2 ) Point Source Emission Trends, Lake and Porter Counties, Indiana, 2002, 2005, and 2008 ...................................................................................16 Graph 4.3 Direct PM 2.5 Point Source Emission Trends, Lake and Porter Counties, Indiana, 2002, 2005, and 2008 .................................................................................................16 Graph 4.4 NO x Point Source Emission Trends, Entire Chicago Area, 2002, 2005, and 2008 ....17 Graph 4.5 SO 2 Point Source Emission Trends, Entire Chicago Area, 2002, 2005, and 2008 ....17 Graph 4.6 Direct PM 2.5 Point Source Emission Trends, Entire Chicago Area, 2002, 2005, and 2008 .................................................................................................18 Graph 4.7 NO x Emission Trends, Lake and Porter Counties, Indiana, 2002, 2005, and 2008 ...19 Graph 4.8 SO 2 Emission Trends, Lake and Porter Counties, Indiana, 2002, 2005, and 2008 ....20 Graph 4.9 Direct PM 2.5 Emission Trends, Lake and Po rter Counties, Indiana, 2002, 2005, and 2008 .................................................................................................20 Graph 4.10 NO x Emission Trends, Entire Chicago Area, 2002, 2005, and 2008 .........................21 Graph 4.11 SO 2 Emission Trends, Entire Chicago Area, 2002, 2005, and 2008 ..........................21 Graph 4.12 Direct PM 2.5 Emission Trends, Entire Chicago Area, 2002, 2005, and 2008 .............22 Graph 4.13 NO x Emissions from EGUs, Lake and Po rter Counties, Indiana, 1999 to 2009 ........23 Graph 4.14 Indiana Statewide NO x Emissions from EGUs, 1999 to 2009 ...................................24 Graph 4.15 SO 2 Emissions from EGUs, Lake and Port er Counties, Indiana, 1999 to 2009 .........24 Graph 4.16 Indiana Statewide SO 2 Emissions from EGUs, 1999 to 2009 ....................................25 Graph 4.17 Comparison of 2005 and 2008 Es timated and 2015, 2020, and 2025 Projected NO x Emissions, Lake and Porter Counties, Indiana ...................................................27 Graph 4.18 Comparison of 2005 and 2008 Estim ated and 2015, 2020, and 2025 Projected SO 2 Emissions, Lake and Port er Counties, Indiana ...................................................28vi Graph 4.19 Comparison of 2005 and 2008 Es timated and 2015, 2020, and 2025 Projected Direct PM 2.5 Emissions, Lake and Porter Counties, Indiana ......................................28 Graph 4.20 Comparison of 2005 and 2008 Es timated and 2020, 2015, and 2025 Projected NO x , SO 2 , and Direct PM 2.5 Emissions, Lake and Port er Counties, Indiana ..............29 Graph 4.21 Comparison of 2005 and 2008 Es timated and 2015, 2020, and 2025 Projected NO x Emissions, Entire Chicago Area .........................................................................29 Graph 4.22 Comparison of 2005 and 2008 Estim ated and 2015, 2020, and 2025 Projected` SO 2 Emissions, Entire Chicago Area ..........................................................................30 Graph 4.23 Comparison of 2005 and 2008 Es timated and 2015, 2020, and 2025 Projected Direct PM 2.5 Emissions, Entire Chicago Area ............................................................30 Graph 4.24 Comparison of 2005 and 2008 Es timated and 2015 and 2025 Projected NO x , SO 2 , and Direct PM 2.5 Emissions, Entire Chicago Area ............................................31 Graph 7.1 PM 2.5 Design Value Trends for Lake and Porter Counties, Indiana, 2000 to 2010 ...44 Graph 7.2 LADCO Round 6 Modeling Results for Lake and Porter C ounties, Indiana for 2012 and 2018 ............................................................................................................46

CHARTS

Chart 7.1 Regional/Emission Sector Part iculate Source Apportionment Technology (PSAT) Results ...........................................................................................................48 Chart 7.2 Modeled Contributions by Specie at the East Chicago – Franklin School PM 2.5 Monitor ....................................................................................................................... 52 Chart 7.3 Modeled Contributions by Specie at the Griffith PM 2.5 Monitor ...............................52 Chart 7.4 Modeled Contributions by Sp ecie at the Gary – Madison Street PM 2.5 Monitor .......53 Chart 7.5 Modeled Contributions by Sp ecie at the Gary – Ivanhoe School PM 2.5 Monitor ......53 Chart 7.6 Modeled Contributions by Specie at the Hammond – Purdue PM 2.5 Monitor ...........54 Chart 7.7 Modeled Contributions by Sp ecie at the Hammond – Clark High School PM 2.5 Monitor .............................................................................................................54 Chart 7.8 Modeled Contributions by Sp ecie at the Dunes National Lakeshore PM 2.5 Monitor 55 Chart 7.9 Modeled Contributions by Specie at the Ogden Dunes PM 2.5 Monitor .....................55 Chart 7.10 Distribution of PM 2.5 Concentration Days on the AQI Levels of Health Concern, Lake and Porter Counties, Indiana .............................................................................58vii APPENDICES

A Air Quality System (AQS) and Indiana De partment of Environmental Management (IDEM) Fine Particle Monitor Data Values for the Chicago Area (2000 –2010) B NO x , SO 2 , and Direct PM 2.5 Point Source Emissions ( 2002, 2005, and 2008), Chicago Area C NO x , SO 2 , and Direct PM 2.5 Emission Trends, All Sources (2002, 2005, and 2008), Chicago Area D NO x and SO 2 Emission Trends from EGUs, Lake a nd Porter Counties, Indiana (1999 to 2009) E 2005 and 2008 Base Year Emission Inve ntories and 2015, 2020, and 2025 Projected Emission Inventories for NO x , SO 2 , and Direct PM 2.5 , Chicago Area F Example Mobile Source Input and Output Calc ulation Files for Lake and Porter Counties, Indiana G IDEM - Area Source Inventory Standard Operating Procedure H LADCO Emission Estimates Technical Support Document I LADCO Round 5 Modeling Technical S upport Document (Round 5 Photochemical Modeling Based on “Base M” Emission Inve ntory, revised version of “Base K”) J Modeling Summary K Public Participation Process Documentsviii 

### This page intentionally left blank1 REQUEST FOR REDESIGNATION AND MAINTENANCE PLAN UNDER THE ANNUAL NATI ONAL AMBIENT AIR QUALITY STANDARD FOR FINE PARTICLES

CHICAGO-GARY-LAKE CO UNTY IL-IN AREA

1.0 INTRODUCTION

This document supports Indiana’s request that Lake and Porter counties, Indiana, which are part of the Chicago-Gary-Lake County IL-IN nonattainmen t area for fine particles (herein referred to as the “Chicago Area”), be redesignated from no nattainment to attainment of the 1997 annual standard for fine particles. All monitors for fi ne particles in the Chicago Area have recorded three years of quality assured ambient air qua lity monitoring data for the years 2008 through 2010, demonstrating attainment with the annual standa rd for fine particles, therefore; Indiana’s portion of the Chicago Area is eligible for redesignation.

Section 107 of the Clean Air Act (CAA) establishe s specific requirements to be met in order for an area to be considered fo r redesignation, including:

(a) A determination that the area has attained the annual standard for fine particles. (b) A State Implementation Plan (SIP) for the area under Section 110(k) is fully approved. (c) A determination that the improvement in air quality is due to permanent and enforceable reductions in emissions resul ting from implementation of the SIP and other federal requirements. (d) A maintenance plan under Sect ion 175A is fully approved. (e) A determination that all Section 110 and Part D requirements have been met.

A maintenance plan provides for the continued atta inment of the air quality standard by an area for a period of ten years after the United Stat es Environmental Protection Agency (U.S. EPA) has formally redesignated the area to attainment. The plan also pr ovides assurances that even if there is a subsequent exceedance of the air quality standard, then measures in the maintenance plan will prevent any future occurrences through contingency measures that would be triggered.

This document addresses each of these requireme nts, and provides additional information to support continued compliance with the a nnual standard for fine particles.

1.1 Background

The CAA requires states with areas designate d nonattainment of th e applicable National Ambient Air Quality Standard (NAAQS) for fine particles to develop SI Ps to expeditiously attain and maintain the standar d. In 1997, U.S. EPA set daily and annual air quality standards for fine particles (PM 2.5 ), as shown in Table 1.1. The terms “fine particles” and “PM 2.5 ” are used synonymously throughout this document. The PM 2.5 standards were legally challenged and upheld by the U.S. Supreme Court in February of 2001. In 1999, the Indiana Department of2 Environmental Management (IDEM) began monitori ng for fine particle concentrations. U.S. EPA designated areas in Indiana under the a nnual fine particles st andard on December 17, 2004, as attainment, nonattainment or unclassifiable , with an effective date of April 5, 2005.

Table 1.1 National Ambient Air Quality Standards for Fine Particles

Annual 24-Hour

1997 PM 2.5 Standards 15 μg/m 3 Annual arithmetic mean, averaged over three years 65 μg/m 3 24-hour average, 98 th percentile, averaged over three years

2006 PM 2.5 Standards 15 μg/m 3 Annual arithmetic mean, averaged over three years 35 μg/m 3 24-hour average, 98 th percentile, averaged over three years
Note: The Chicago Area meets the 1997 and 2006 24-hou r NAAQS for fine particles. Since this area is solely designated nonattainment under the 1997 annual standard for fine particles, this document only addresses the annual standard.

On December 17, 2004, based on 2001 through 2003 monitoring data, U.S. EPA designated the Chicago Area as nonattainment of the annual stan dard for fine particles (40 CFR 81.315). The Chicago Area was subject to Section 172 of the CAA, including the development of a plan to reduce nitrogen oxides (NO x ), sulfur dioxide (SO 2 ), and direct fine particle (PM 2.5 ) emissions and a demonstration that the area will meet the annual standard for fine particles by April 5, 2010. In order to satisfy these requirements, Indiana submitted a redesignation petition and maintenance plan to U.S. EPA on April 3, 2008, de monstrating that Lake and Porter counties, Indiana met the NAAQS for fine particles by Apr il 5, 2010, with an ample margin of safety. The Chicago Area monitors have continued to m eet the annual NAAQS for fine particles since the end of 2007.

There were no fine particle monitors in the Ch icago Area that violated the 1997 24-hour standard for fine particles and none that cu rrently violate the 2006 24- hour standard for fine particles. As a result, the Chicago Area was designated nonatta inment for fine particles solely under the 1997 annual standard. Therefore, this document pert ains only to the 1997 annual standard for fine particles.

The Chicago nonattainment area for fine particles, as defined in Section 1.2, has not previously been subject to nonattainment area rulemakings fo r fine particles. However, the Chicago Area had been subject to nonattain ment area rulemakings under the 1-hour ozone standard. The 1- hour ozone standard was revoked on June 15, 2005. Lake and Porter counties had also been subject to nonattainment rulemakings under the 8- hour ozone standard and were redesignated to attainment and classified as maintenance under the 8-hour ozone standard on May 11, 2010. The Illinois portion of the Chicago Area 8-hour ozone nonattainment area remains designated as “nonattainment” under the 8-hour ozone standard.3 1.2 Geographical Description

The Chicago nonattainment area for fi ne particles consists of Lake and Porter counties, Indiana and Cook, DuPage, Kane, Lake, McHenry, and Will counties, and portions of Grundy (Aux Sable and Goose Lake Townships) and Kendall (Oswego Township) counties, Illinois. The Chicago Area contains such citi es as Gary, Hammond, East Chica go, Portage, and Valparaiso in Indiana and Chicago, Elgin, Aurora, a nd Joliet in Illinois. This ar ea is depicted in Figure 3.1.

IDEM and Illinois Environmental Protection Agency (IEPA) are responsible for assuring the nonattainment area for fine particles complies with the CAA requirements. IDEM is responsible for Lake and Porter counties, Indiana, while IE PA is responsible for Cook, DuPage, Kane, Lake, McHenry, and Will Counties, and portions of Grundy (Aux Sable and Goose Lake Townships) and Kendall (Oswego Township) counties, Illinois. IDEM and IEPA have worked cooperatively with U.S. EPA Region V to addr ess attainment planning issues.

Although the agencies have worked toge ther on a comprehensive plan for the multi-state nonattainment areas, the State of Illinois is required to make a separate submittal for its portion of the planning components to U.S. EPA. As su ch, this submittal only covers Lake and Porter counties, Indiana.

1.3 Status of Air Quality

Monitoring data for fine particles for the th ree years, 2008 through 2010, demonstrates that air quality has met the annual NAAQS for fine part icles in the Chicago Area. This fact, accompanied by the permanent and enforceable reductions in emission levels discussed in Section 4.0, justifies a redesignati on to attainment for the area based on Section 107(d)(3)(E) of the CAA.

2.0 REQUIREMENTS FOR REDESIGNATION

2.1 General

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

2.2 Fine Particles Monitoring

1) A demonstration that the annual standard for fine particles, as published in 40 Code of Federal Regulations (CFR) 50.13, has been attained. Fine particle4 monitoring data must show that violati ons of the annual ambient standard are no longer occurring.

2) Ambient monitoring data quality assu red in accordance with 40 CFR 58.15, recorded in the U.S. EPA Air Quality Sy stem (AQS) database, and available for public view.

3) A showing that the three-year average of annual values, based on data from all monitoring sites in the area or its aff ected downwind environs, do not exceed 15.0 micrograms per cubic meter (μg/m 3 ). This showing must rely on three complete, consecutive calendar years of quality assured data.

4) A commitment that, once redesignated, the state will continue to operate an appropriate monitoring network to verify the area is in compliance (maintenance) with the standard.

2.3 Emission Inventory

1) A comprehensive emission inventory of the precursors of fine particles (direct PM 2.5 , NO x , and SO 2 completed for the base ye ar (2008 in this case).

2) A projection of the emission inventory to a year at least ten years following redesignation.

3) A demonstration that the pr ojected level of emissions is sufficient to maintain the annual standard for fine particles.

4) A demonstration that improvement in air quality between th e year violations occurred and the year attainment wa s achieved is based on permanent and enforceable emission reductions a nd not on temporary adverse economic conditions or unusually favorable meteorology.

5) Provisions for future updates of the i nventory to enable tr acking of the emission levels, including emission inventory statements from emission sources.

2.4 Modeling Demonstration

While no modeling is required for redesignating nonattainment areas, IDEM has evaluated the results of federal control-case modeling to demons trate that compliance with the standard will be maintained.

2.5 Controls and Regulations

1) A U.S. EPA approved SIP control stra tegy that includes R easonably Available Control Technology (RACT) requirements fo r existing stationary sources covered5 by Control Technology Guidelines (CTG ) and non-CTG RACT for all major

sources.

2) Evidence that control measures required in past SIP revisi ons have been fully implemented.

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

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

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

2.6 Corrective Actions for Potential Future Vi olations of the Fine Particle Standard

1) A commitment to submit a revised plan eight years af ter redesignation.

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

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

4) A list of NO x , SO 2 , and direct PM 2.5 sources potentially subject to future controls.

3.0 FINE PARTICLES MONITORING

3.1 Fine Particle Monitoring Network

There are currently twen ty-three Federal Reference Method m onitors measuring fine particle concentrations in this nonattainment area. Six monitors are located in Indiana’s portion of the nonattainment area and are operated by IDEM’s Office of Air Qualit y (OAQ). Seventeen monitors are located in Illinois’s portion of the nonattainment and are operated by IEPA’s Bureau of Air; Air Monitoring Section (AMS). A listing of the monitor readings from 2008 through 2010 are shown in Tables 3.1, 3.2, and A ppendix A and was retrieved from U.S. EPA’s AQS database. The locations of the monitoring sites for this nonattainme nt area are shown in Figure 3.1.

There are also four source orient ed monitors located in the nonattainment area that collect background fine particle concentr ations. Two monitors are located in Lake County, Indiana and are operated by IDEM’s OAQ (Gary – IITRI ( 18-089-0022) and Gary – Burr Street (18-089- 0026)). Two monitors are located in Cook Count y, Illinois and are operated by IEPA’s Bureau6 of Air AMS (McCook (17-031-1016) and Schiller Park (17-031-3103)). While the source oriented monitors are not used to determine attainment with the annual standard for fine particles, the monitoring lo cations and data are included as supporting material.

Three monitors in Indiana’s portion of the nonattain ment area have been discontinued. The Gary - Federal Building monitor (18-089-1016) in Lake, County, Indiana was discontinued in September 2002. The Dunes National Lakeshore monitor (18-127-0020) in Porter County, Indiana, and the Gary - Ivanhoe School monito r (18-089-1003) in Lake County, Indiana were discontinued on December 31, 2007.

Figure 3.1 Chicago Nonattainment Area

3.2 Ambient Fine Particles Monitoring Data

The following information summarizes U.S. EPA's "Guideline on Data Handling Conventions for the PM NAAQS," U.S. EPA-454/R-99-008, Ap ril 1999. Three complete years of fine particle monitoring data are required to demonstr ate attainment at a monitoring site. The annual ambient air quality standard for fine particles is met at an ambient air quality monitoring site7 when the three-year average of the annual average of fine particle concentr ations is less than or equal to 15.0 μg/m 3 . When this occurs, the site is said to be in attainment. While calculating design values, three significant di gits must be carried in the co mputations, with final values rounded to the nearest 0.1 μg/m 3 . Decimals 0.05 or greater are rounded up, and those less than 0.05 are rounded down, so that 15.049 μg/m 3 is the largest concentration that is less than or equal to 15.0 μg/m 3 . Values at or below 15.0 μg/m 3 meet the standard. Values equal to or greater than 15.1 μg/m 3 exceed the standard.

Data handling procedures are applied on an indi vidual basis at each monitor in the area. An individual site’s three-year av erage of the annual average fine particles concentr ation is also called the site’s design value . An area is in compliance w ith the annual NAAQS for fine particles only if all monitoring sites meet the NAAQS. The air quality design value for the area is the highest design value among all sites in the area. Table 3.1 outlines the annual fine particle values by site and the 2008 through 2010 design valu es for the six active fi ne particle monitoring sites in Indiana’s portion of the Chicago Area. Ta ble 3.2 outlines the annual fine particle values by site and the 2008 through 2010 design values for th e seventeen fine particle monitoring sites in Illinois’ portion of the Chicago Area. A ppendix A contains the complete monitoring data monitoring summary from 2000 to 2010 for all of the Chicago Area monitors which includes the twenty-three active, the four source oriented, a nd the three discontinued fi ne particles monitoring sites.

Table 3.1 Monitoring Data for Indiana’s Portion of the Chicago Area ( Annual Average and 2008 - 2010 Design Values)

SITE ID COUNTY SITE NAME YEAR Annual Average (μg/m 3 ) 2008-2010 Design Value (μg/m 3 )

18-089-0006 Lake East Chicago – Franklin School 2008 11.95 11.9 2009 11.34 2010 12.48

18-089-0027 Lake Griffith 2008 11.69 11.7 2009 11.00 2010 12.39

18-089-2004 Lake Hammond – Purdue 2008 11.66 N/A* 2009 N/A* 2010 12.30

18-089-2010 Lake Hammond – Clark High School 2008 12.42 11.7 2009 10.80 2010 11.90

18-089-0031 Lake Gary – Madison Street 2008 12.27 12.4 2009 12.12 2010 12.908 18-127-0024 Porter Ogden Dunes 2008 10.89 11.2 2009 11.29 2008 11.56

*The Hammond – Purdue monitoring site was physically removed to accommodate heating and cooling building repairs on the roof which were conducted from February 12, 2009 through November 18, 2009. As a result, the 2009 monitoring data and 2008 through 2010 three year design value are considered incomplete.

Table 3.2 Monitoring Data for Illinois’ Portion of the Chicago Area (Annual Average and 2008 through 2010 Design Values)

SITE ID COUNTY SITE NAME YEAR Annual Average (μg/m 3 ) 2008-2010 Design Value (μg/m 3 )

17-031-0022 Cook Chicago – Washington High School 2008 12.54 12.7 2009 11.62 2010 14.04

17-031-0050 Cook Chicago – Southeast Police Station 2008 11.80 11.8 2009 10.99 2010 12.47

17-031-0052 Cook Chicago – Mayfair Pump Station 2008 12.18 12.5 2009 12.69 2010 12.57

17-031-0057 Cook Chicago – Springfield Pump Station 2008 12.03 11.8 2009 11.33 2010 12.03*

17-031-0076 Cook Chicago – Com Ed Maintenance Building 2008 11.89 11.8 2009 11.12 2010 12.25

17-031-2001 Cook Blue Island 2008 12.50 11.9 2009 11.68 2010 11.59

17-031-3301 Cook Summit 2008 12.03 12.0 2009 11.62 2010 12.23

17-031-4007 Cook Des Plaines 2008 11.35 11.0 2009 11.02 2010 10.60

17-031-4201 Cook Northbrook 2008 10.09 9.6 2009 9.33 2010 9.34

17-031-6005 Cook Cicero 2008 13.25* 12.4 2009 11.98* 2010 11.909 17-043-4002 DuPage Naperville 2008 11.28 10.9 2009 9.83 2010 11.67

17-089-0003 Kane Elgin 2008 10.79 10.6 2009 9.61 2010 11.29

17-089-0007 Kane Aurora 2008 10.34 10.6 2009 10.01 2010 11.44

17-097-1007 Lake Zion 2008 9.34 9.3 2009 8.83 2010 9.66

17-111-0001 McHenry Cary 2008 10.10 10.0 2009 9.65 2010 10.24

17-197-1002 Will Joliet 2008 11.66 11.3 2009 10.52 2010 11.83

17-197-1011 Will Braidwood 2008 10.31 9.7 2009 8.73 2010 10.02

*Indicates the mean does no t satisfy summary criteria.

Red Text Indicates Incomplete Data

Graph 3.1 visually demonstrates the 2006 through 2010 design values for Indiana’s portion of the Chicago Area.10 Graph 3.1 Fine Particle Design Values for Indiana’s Portion of the Chicago Area, 2006 through 2010

Red line represents the annual standard for fine particles of 15 μg/m 3

The Hammond - Purdue monitoring site was physically removed to accommodate heating and cooling building repairs on the roof which were conducted from February 12, 2009 through November 18, 2009. As a result, the 2007 through 2009 and 2008 through 2010 three year design values are considered incomplete and are not included in Graph 3.1.
Graph 3.2 visually demonstrates the 2006 through 2010 design values for Illinois’ portion of the Chicago Area. 8.0 9.0 10.0 11.0 12.0 13.0 14.0 15.0 16.0

06

‐ 08 07

‐ 09 08

‐ 10

East Chicago ‐ Franklin School Griffith Hammond ‐ Purdue Hammond ‐ Clark High School Gary ‐ Madison Street Ogden Dunesug/m311 Graph 3.2 Fine Particle Design Values for Il linois’ Portion of the Chicago Area, 2006 through 2010

Red line represents the annual standard for fine particles of 15 μg/m 3

. 8.0 9.0 10.0 11.0 12.0 13.0 14.0 15.0 16.0

06

‐ 08 07

‐ 09 08

‐ 10

Chicago ‐ Washington High Schoo l Chicago ‐ Southeast Police Station Chicago ‐ Mayfair Pump Station Chicago ‐ Springfield Pump Station Chicago ‐ Com Ed Maintenance Building Blue Island
Summi t Des Plaines Northbroo k
Cicero Naperville Elgin
Aurora Zion Cary
Jolie t Braidwoodug/m312 Graph 3.3 Annual Fine Particle Trends for In diana’s Portion of the Chicago Area, 2006 through 2010

Red line represents the annual standard for fine particles of 15 μg/m 3

The Hammond - Purdue monitoring site was physically removed to accommodate heating and cooling building repairs on the roof which were conducted from February 12, 2009 through November 18, 2009. As a result, the 2009 monitoring data is considered incomplete and has not been included in Graph 3.3. 8.0 9.0 10.0 11.0 12.0 13.0 14.0 15.0 16.0

2006 2007 2008 2009 2010

East Chicago ‐ Franklin School Griffith Gary ‐ Ivanhoe School Hammond ‐ Purdue Hammond ‐ Clark High School Gary ‐ Madison Street Dunes National Lakeshore Ogden Dunesug/m3

Year13 Graph 3.4 Annual Fine Particle Trends for Illinois’ Portion of the Chicago Area, 2006 through 2010

Red line represents the annual standard for fine particles of 15 μg/m 3

The design values for Lake and Porter counties, I ndiana, along with the nonattainment area in its entirety, demonstrate th at the annual NAAQS for fine partic les has been attained. Appendix A contains the complete fine particles monito ring data summary for the years 2000 through 2010.

Graphs 3.1 and 3.2 show the trends in design valu es, while Graphs 3.3 and 3.4 show the trend for annual fine particles. A comprehensive list of the design values for the Chicago Area fine particles monitoring sites over the 2000 through 2010 monitoring period is outlined in Appendix A. The area's design values have recently tre nded downward, as emissions have declined due to programs such as the Acid Rain program and cl eaner automobiles and fuels both regionally and locally. U.S. EPA’s rule to c ontrol nitrogen oxides from spec ific source categories (40 CFR Parts 51, 72, 75, and 96, published on October 17, 1998 and referred to as the “NO x SIP Call”) has significantly reduced emissions from larg e electric generating units (EGUs), industrial boilers, and cement kilns. Indiana's NO x SIP Call Rule was adopted into the Indiana Administrative Code (IAC) on June 6, 2001 at 326 IAC 10-3 and 326 ICA 10-4. The elevated 8.0 9.0 10.0 11.0 12.0 13.0 14.0 15.0 16.0 17.0 18.0

2006 2007 2008 2009 2010

Chicago ‐ Washington High School Chicago ‐ Southeast Police Station Chicago ‐ Mayfair Pump Station Chicago ‐ Springfield Pump Station Chicago ‐ Com Ed Maintenance Building Blue Island Summit Des Plaines Northbrook Cicero Naperville Elgin Aurora Zion Cary Joliet Braidwoodug/m3

Year14 fine particle values for 2005 are considered an abnormal occurrence. An analysis of meteorological conditions and monitoring values is included in Section 7.0 and supports the conclusion that attainment of the standard as of 2010 is not the result of unusually favorable meteorological conditions. It is expected that this downward trend will persist as the above programs continue and U.S. EPA’s proposed Clean Air Transport Rule is implemented.

3.3 Quality Assurance

Indiana and Illinois have quality assured all data shown in A ppendix A in accordance with 40 CFR 58.10 and recorded the data in the AQS databa se and, thus, the data is available to the public.

3.4 Continued Monitoring

Indiana and Illinois commit to con tinue monitoring fine particle c oncentrations at the active sites indicated in Tables 3.1, 3.2, and A ppendix A. IDEM will consult with U.S. EPA Region V staff prior to making changes to the existing Indian a monitoring network th rough the annual network review should changes become necessary in the fu ture. IDEM will continue to quality assure the Indiana monitoring data to meet the requirement s of 40 CFR 58. IDEM will enter all data into AQS on a timely basis in accordance with federal guidelines.

4.0 EMISSION INVENTORY

U.S. EPA’s Redesignation Guidance and Impl ementation Rules require the submittal of a comprehensive inventory of precursor emissions for fine particles (NO x , SO 2 , and direct PM 2.5 ) representative of the year wh en the area achieves attainment of the annual NAAQS for fine particles (base year). IDEM is using 2008 as the base year. IDEM must also demonstrate that the improvement in air quality between the year that violations occurred and the year that attainment was achieved is based on permanen t and enforceable emission reductions. Other requirements related to the emission inventory in clude: a projection of th e emission inventory to a year at least ten years following redesignation; a demonstration that the projected level of emissions is sufficient to maintain the annual stan dard for fine particles; and, a commitment to provide future updates of the inventory to enable tracking of emission leve ls during the ten year maintenance period. Consistent with the federal implementation rule for fine particles, IDEM and U.S. EPA do not consider volatile or ganic compounds (VOCs) or ammonia (NH 3 ) to be significant contributors to fine particles. The following subs ections address each of these requirements.

4.1 Emission Trends

Point Sources

The point source data are obtained from Indian a's emissions reporting program and are based on county point source totals. Lake and Porter counties, Indiana, had a 34.31% reduction in NO x point source emissions, a 7.34% reduction in SO 2 point source emissions, and a 8.71% reduction15 in direct PM 2.5 point source emissions from 2002 to 2008. Lake and Porter counties, Indiana, had a 4.77% reduction in NO x point source emissions, a slight increase (14.08%) in SO 2 point source emissions, and a slight increase (3.49%) in direct PM 2.5 point source emissions from 2005 to 2008. A moderate increase in Lake and Porter counties, Indiana, in direct PM 2.5 point source emissions from 2005 to 2008 is noted, how ever, this increase in direct PM 2.5 emissions is due to the fact that most companies did not submit their direct PM 2.5 emissions data in 2005 but did submit direct PM 2.5 data in the 2009 emission inventory, from which the 2008 inventory is extrapolated. Graphs 4.1, 4.2, and 4.3 demonstrat e the trend in point source emissions of NO x , SO 2 , and direct PM 2.5 for the Lake and Porter counties, I ndiana that generally correspond to the years of monitored values used in this redesi gnation petition.

Point source data for Illinois’ portion of the Chi cago Area is based on count y point source. Point source data for the years 2002 and 2008 were ta ken directly from Illinois EPA’s document entitled Maintenance Plan for the Chicago Nonattainment for the 1997 PM 2.5 National Ambient Air Quality Standard, prepared September 7, 2010. This docum ent is hereafter referred to as the “Chicago Maintenance Plan”. The 2005 point so urce data for Illinois’ portion of the Chicago nonattainment area were interpolated from th e 2002 and 2008 emissions data. The Chicago Area had a 33.93% reduction in NO x point source emissions, a 19.48% reduction in SO 2 point source emissions, and a slight increase (4.61%) in direct PM 2.5 point source emissions from 2002 to 2008. The Chicago Area had a 12.72% reduction in NO x point source emissions, a 5.62% reduction in SO 2 point source emissions, and a sli ght increase (7.95%) in direct PM 2.5 point source emissions from 2005 to 2008. Th e moderate increase in direct PM 2.5 emissions is far outweighed by the signif icant reductions in NO x and SO 2 that have occurred and will continue to occur in the future. Graphs 4.4, 4.5, and 4.6 demons trate the trend in poin t source emissions of NO x , SO 2 , and direct PM 2.5 emissions for the entire Chicago Area. Graphs and data tables of emissions for the point source catego ry can be found in Appendix B.

Graph 4.1 NO x Point Source Emission Trends, Lake and Porter Counties, Indiana, 2002, 2005, and 2008

0 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000

2002 2005 2008TonsperYear

Nitrogen Oxides Year16 Graph 4.2 SO 2 Point Source Emission Trends, Lake and Porter Counties, Indiana, 2002, 2005, and 2008

Graph 4.3 Direct PM 2.5 Point Source Emission Trends, Lake and Porter Counties, Indiana, 2002, 2005, and 2008 0 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000

2002 2005 2008TonsperYear

Sulfur Dioxide Year

0 1,000 2,000 3,000 4,000 5,000 6,000 7,000 8,000

2002 2005 2008TonsperYear

Direct Fine Particles Year17 Graph 4.4 NO x Point Source Emission Trends, Entire Chicago Area, 2002, 2005, and 2008

Graph 4.5 SO 2 Point Source Emission Trends Entire Chicago Area, 2002, 2005, and 2008 0 20,000 40,000 60,000 80,000 100,000 120,000 140,000

2002 2005 2008TonsperYear

Nitrogen Oxides Year

0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000 180,000 200,000

2002 2005 2008TonsperYear

Sulfur Dioxide Year18 Graph 4.6 Direct PM 2.5 Point Source Emission Trends, Entire Chicago Area, 2002, 2005, and 2008

All Anthropogenic Sources

Periodic inventories, which include emissions fr om all sectors (mobile, area, nonroad, and point source), were prepared for 2002, 2005, and 2008. Th e 2008 data for Lake and Porter counties, Indiana were extrapolated from the 2005 em ission inventory. The 2002 and 2008 data for Illinois’ portion of the Chicago Area were taken directly from the Chicago Maintenance Plan. The 2005 data were interpolated from th e 2002 and 2008 emissions data. Regional NO x emission reductions affect fine particle levels in the Chicago Area far more so than NO x emission reductions within the nonattainment area itself. These emission trends roughly follow the years of monitored trends discussed in Section 3.0. There is a downward trend in NO x emissions from 2002 to 2005 and a further d ecrease through 2008. The decrease in NO x can be largely attributed to the impact of the NO x SIP Call. There is a general downward trend in direct PM 2.5 and SO 2 emissions from 2002 to 2008, as well. As noted previously, th ere is an overall increase in direct PM 2.5 anthropogenic emissions in Lake and Porter counties, Indiana, but an overall decrease in the entire nonattainment area. Gr aphs and data tables of emissions from each source category are available in Appendix C.

Mobile emission inventories and pr ojections for Lake and Porter c ounties, Indiana were prepared by the Northwestern Indiana Regional Planning Commission (NIRPC), the Indiana Department of Transportation, and IDEM and are explained in further detail in Section 5.0. All 2005 data for Lake and Porter counties, Indian a are from the 2005 periodic invent ory which has been identified as one of the preferred databases for SIP devel opment. All 2008 emissions were extrapolated 0 3,000 6,000 9,000 12,000 15,000

2002 2005 2008TonsperYear

Direct Fine Particles Year19 from the 2005 Lake Michigan Air Directors Consortium’s (LADCO’s) modeling inventory, using LADCO’s growth factors, for all sectors except point sources (electrical generating units and non-electrical generating units). Point source emissions for 2008 were compiled from Indiana’s annual emission s inventory database.

Graphs 4.7, 4.8, and 4.9 show the trend in anthropoge nic emissions for Lake and Porter counties, Indiana. Graphs 4.10, 4.11, and 4.12 show the trend in anthropogenic emissions for the entire Chicago Area. The emission inventory developm ent and emissions projection discussion below, with the exception of the mobile emission invent ory and projections, identify procedures used by IDEM and LADCO regarding emi ssions for the Chicago Area.

Graph 4.7 NO x Emission Trends, Lake and Porter Counties, Indiana, 2002, 2005, and 2008

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

2002 2005 2008TonsperYear

Nitrogen Oxides Year20 Graph 4.8 SO 2 Emission Trends, Lake and Porter Counties, Indiana, 2002, 2005, and 2008

Graph 4.9 Direct PM 2.5 Emission Trends, Lake and Porter Counties, Indiana, 2002, 2005, and 2008 0 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000

2002 2005 2008TonsperYear

Sulfur Dioxide Year

0 3,000 6,000 9,000 12,000 15,000

2002 2005 2008TonsperYear

Direct Fine Particles Year21 Graph 4.10 NO x Emission Trends, Entire Chicago Area, 2002, 2005, and 2008

Graph 4.11 SO 2 Emission Trends, Entire Chicago Area, 2002, 2005, and 2008 0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000 450,000 500,000

2002 2005 2008TonsperYear

Nitrogen Oxides Year

0 50,000 100,000 150,000 200,000 250,000

2002 2005 2008TonsperYear

Sulfur Dioxide Year22 Graph 4.12 Direct PM 2.5 Emission Trends, Entire Chicago Area, 2002, 2005, and 2008

EGU Sources

Both NO x and SO 2 emissions are decreasing substantially in Lake and Porter counties, Indiana, as well as statewide in response to national programs affecting all EGUs, such as the Acid Rain program and the NO x SIP Call. Other sectors of the invent ory also impact the formation of fine particles, but large regional sour ces, such as EGUs, have a subs tantial impact on the formation of fine particles. The data was taken fro m U.S. EPA's Clean Air Markets database. 1

As part of the NO x SIP Call, the states were required to adopt into their rules a budget for all large EGUs. Indiana’s budget is referenced in 326 IAC 10-4. The budget represents a statewide cap on NO x emissions. Although each unit is allocated emissions based upon hi storic heat input, utilities can meet this budget by over-controlling certain units or purchasing credits from the market to account for overages at other units. To summarize, NO x emissions have dramatically decreased over the years represented on these graphs.

These emissions, capped by the state rule, are exp ected to remain near these levels throughout the maintenance period covered by this request. The state cap for the NOx SIP Call remained in place through 2008, at which time the Clean Air Inte rstate Rule (CAIR) program superseded it. CAIR, issued in March 2005, adopted by the Indi ana Air Pollution Control Board on November 1, 2006, and implemented beginning in 2010, will continue to reduce regional EGU NO x

1 http://www.epa.gov/airmarkets 0 5,000 10,000 15,000 20,000 25,000 30,000 35,000 40,000

2002 2005 2008TonsperYear

Direct Fine Particles Year23 emissions statewide by approximately another 17% by 2015 and 57% for EGU SO 2 emissions by 2015. The D.C. Circuit court’s vacatur of CAIR in July of 2008 and subsequent remand without vacatur of CAIR in December of 2008 directs U.S. EPA to revise the CAIR rule in the future. The proposed Clean Air Transport Rule (CAIR’s replacement rule) will result in similar or greater emission reductions than assumed within the current emission inventories once it is implemented.

There are three EGUs located in Indiana’s por tion of the nonattainment area: The Northern Indiana Public Service Company (NIPSCO) – Bailly Generating Stati on, Dominion Resources – State Line Generating Plant, and British Pe troleum – Whiting Clean Energy Power Plant. Graphs 4.13 and 4.15 depict the trends in NO x and SO 2 emissions from EGUs in Lake and Porter counties, Indiana for the years 1999 through 2009. As the result of a recent settlement with U.S. EPA to resolve violations of the CAA’s new sour ce review requirements, NIPSCO has agreed to upgrade existing pollution control equipment, as well as install additional pollution control equipment at three of its four coal-fired power plants located in Northwest Indiana (i.e. Bailly, Michigan City, and R.H. Schafer Generati ng Stations) to comply with stringent NO x and SO 2 emission rates and annual tonnage limitations. The settlement also requires NIPSCO to optimize existing PM pollution control equipment to meet unit-specific emissions and permanently retire its fourth facility, the Dean H. Mitchell Gene rating Station. The Dean H. Mitchell Generating Station has been out of operation since 2002 and its permanent retirement will ensure that the facility does not restart without proper perm itting under the CAA. Graphs 4.13 and 4.15 depict the trends in NO x and SO 2 EGU emissions in Lake and Porter counties, Indiana for the years 1999 through 2009. Graphs 4.14 and 4.16 depi ct the trends in statewide NO x and SO 2 EGU emissions for the years 1999 through 2009. Graphs and data tables of emissions from the EGU source category can be found in Appendix D.

Graph 4.13 NO x Emissions from EGUs, Lake and Porter Counties, Indiana, 1999 to 2009

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

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

Nitrogen Oxides Year24 Graph 4.14 Indiana Statewide NO x Emissions from EGUs, 1999 to 2009

Graph 4.15 SO 2 Emissions from EGUs, Lake and Porter Counties, Indiana, 1999 to 2009 0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000

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

Nitrogen Oxides Year

0 3,000 6,000 9,000 12,000 15,000 18,000 21,000 24,000 27,000 30,000

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

Sulfur Dioxide Year25 Graph 4.16 Indiana Statewide SO 2 Emissions from EGUs, 1999 to 2009

4.2 Base Year Inventory

IDEM prepared a comprehensive inventory fo r the Chicago Area, including area, mobile, nonroad, and point sources for direct PM 2.5 , NO x , and SO 2 for 2005 and 2008 (the years with the most complete emissions inventory availabl e at this time). The 2008 emission inventory represents a base year for maintenance purpos es. The 2007 implementation rule for the annual standard for fine part icles states that NO x , SO 2 , and direct PM 2.5 are the regulated precursors of fine particles. Ammonia and VOC s are not required to be addre ssed unless the state or U.S. EPA make a technical demonstration that emissions of these pollutants from sources in the state significantly contribute to PM 2.5 concentrations in a given nonattainment area. U.S. EPA and IDEM have not determined ammonia or VOCs ar e significant contributor s to fine particles formation in Indiana. IDEM’s 2008 base ye ar inventory was deve loped as follows:

 Area sources were extrapolated from the Indiana 2005 periodic inventory submitted to U.S. EPA.

 Mobile source emissions were calculated from MOBILE6.2 model-produced emission factors and data extrac ted from the region’s travel-dema nd model. These emissions were then interpolated as needed to determine 2008 base year values.

 Point source information was compiled from IDEM’s emissions inventory database and U.S. EPA's Clean Air Mark ets acid rain database.

 Biogenic emissions are not specifically incl uded in these summaries, but are included in the photochemical modeling result s presented in Section 7.0. 0 100,000 200,000 300,000 400,000 500,000 600,000 700,000 800,000 900,000 1,000,000

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

Sulfur Dioxide Year26  Nonroad emissions were extrapolated fr om the 2005 National Emissions Inventory (NEI). To address concerns about the accuracy of some of the categories in U.S. EPA’s nonroad emissions model, Lake Michig an Air Directors Consortium (LADCO) contracted with two companies to review th e base data and make recommendations. One of the contractors also estimated emissions for two nonroad categories not included in U.S. EPA's nonroad model. Emissions were estimated for commercial marine vessels and railroads. The recreational motorboa t population and spatial surrogates (used to assign emissions to each) were also signi ficantly updated. The populations for the construction equipment category were also reviewed and updated based upon surveys completed in the Midwest and the temporal al location for agricultur al sources was also updated. A new nonroad estimation model was provided by U.S. EPA for the 2005 analysis.

● Area, nonroad, mobile, and point source emission s data referenced for Illinois’ portion of the Chicago Area were taken directly from the Chicago Maintenance Plan. This inventory was prepared using similar met hodologies. Emissions for the year 2005 were interpolated from the 2002 and 2008 emissions data.

Appendix C contains data tables and graphs of these emissions.

4.3 Emission Projections

In consultation with U.S. EPA and other stakeholders, IDEM se lected the year 2025 as the maintenance year for this redesignation request . This document contai ns projected emission inventories for 2015, 2020, and 2025. These emission projections we re prepared by IDEM, with assistance from LADCO, Illinois EPA, and the Northwest Indiana Regional Planning Commission.

The detailed 2015, 2020, and 2025 emission inventor y for the Chicago Area can be found in Appendix E. Emission trends are an important gauge for continued comp liance with the annual standard for fine particles. Therefore, IDEM performed an initial comparison of the inventories for the base year of 2008, interim years of 2015 and 2020, and maintenance year of 2025 for Lake and Porter counties, Indiana, as well as the entire Chicago Area.

The 2005 LADCO modeling inventory was used as the basis for estimated emissions for Lake and Porter counties, Indiana for the y ears 2008, 2015, 2020, and 2025, using LADCO’s growth factors, for all sectors except point sources (electric generati ng units and non-electric generating units). Point source emissions for 2005 and 2008 were compiled from Indiana’s annual emission inventory database. The 2015 interim year emi ssions were interpolat ed based on the 2009 and 2018 LADCO modeling inventory, us ing LADCO’s growth factors, for all sectors. The 2020 interim year emissions and the 2025 maintenance year emissions were extrapolated from the 2009 and 2018 LADCO modeling inventory.

The projected emission inventories for 2015, 2020, and 2025 for Illinois’ portion of the Chicago Area were taken directly from the Chicago Maintenance Plan.27 Graphs 4.17, 4.18, 4.19, and 4.20 visually compare 2005 and 2008 (base year) NO x , SO 2 , and direct PM 2.5 county total estimated emissions with the 2015, 2020, and 2025 projected emissions for Lake and Porter counties, Indiana. Graphs 4.21, 4.22, 4.23, and 4.24 visually compare the 2005 and 2008 (base year) NO x , SO 2 , and direct PM 2.5 county total estimated emissions with the 2015, 2020, and 2025 projected emissions for the enti re Chicago Area. Mobile source emission inventories are further described in Section 5.0. In addition to LADCO’s estimates, point source emissions were projected based upon the statewide EGU NO x budgets from Indiana’s NO x rule.

EGU emission estimates for 2015, 2020, and 2025 were projected using the budgets from the proposed Transport Rule and Options 1 and 2 from the recent Notice of Data Availability. Since it is likely that the finalized rule will include a budget approximating one of these, IDEM used the option with the highest allotment each for the NIPSCO – Bailly Generating Station, Dominion Resources – State Line Generating Pl ant, and British Petroleum – Whiting Clean Energy Power Plant to develop conservative proj ections. These allowances cover 2014 forward, so the same projections were used for all thr ee years. Further, th e consent decree provides overall caps for all NIPSCO facilities in Northwest Indiana. The emissions allowed under these caps are similar to those in the Transport Rule. Therefore, IDEM is confident that emissions in these three years will be close to or below the pr ojections. Graphs and data tables of emissions from the EGU source category can be found in Appendix D.

Graph 4.17 Comparison of 2005 and 2008 Estimated and 2015, 2020, and 2025 Projected NO x Emissions, Lake and Po rter Counties, Indiana

0 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000

2005 2008 2015 2020 2025TonsperYear

Nitrogen Oxides Year28 Graph 4.18 Comparison of 2005 and 2008 Estimated and 2015, 2020, and 2025 Projected SO 2 Emissions, Lake and Po rter Counties, Indiana

Graph 4.19 Comparison of 2005 and 2008 Estimated and 2015, 2020, and 2025 Projected Direct PM 2.5 Emissions, Lake and Po rter Counties, Indiana 0 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000

2005 2008 2015 2020 2025TonsperYear

Sulfur Dioxide Year

0 1,000 2,000 3,000 4,000 5,000 6,000 7,000 8,000 9,000 10,000

2005 2008 2015 2020 2025TonsperYear

Direct Fine Particles Year29 Graph 4.20 Comparison of 2005 and 2008 Estimated and 2015, 2020, and 2025 Projected NO x , SO 2 , and Direct PM 2.5 Emissions, Lake and Porter Counties, Indiana

Graph 4.21 Comparison of 2005 and 2008 Estimated and 2015, 2020, and 2025 Projected NO x Emissions, Entire Chicago Area 0 10,000 20,000 30,000 40,000 50,000 60,000 70,000

2005 2008 2015 2020 2025TonsperYear

Nitrogen Oxides Sulfur Dioxide Direct Fine Particles

0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000

2005 2008 2015 2020 2025TonsperYear

Nitrogen Oxides Year30 Graph 4.22 Comparison of 2005 and 2008 Estimated and 2015, 2020, and 2025 Projected SO 2 Emissions, Entire Chicago Area

Graph 4.23 Comparison of 2005 and 2008 Estimated and 2015, 2020, and 2025 Projected Direct PM 2.5 Emissions, Entire Chicago Area 0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000 180,000 200,000

2005 2008 2015 2020 2025TonsperYear

Sulfur Dioxide Year

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

2005 2008 2015 2020 2025TonsperYear

Direct Fine Particles Year31 Graph 4.24 Comparison of 2005 and 2008 Estimated and 2015, 2020, and 2025 Projected NO x , SO 2 , and Direct PM 2.5 Emissions, Entire Chicago Area

NO x emissions within Lake and Porter counties, Indiana are projecte d to decline by 41.23% between 2008 and 2025. NO x emissions within the Chicago Area are projected to decline by 46.46% between 2008 and 2025. Emission reduction bene fits from U.S. EPA rules covering the NO x SIP Call, Tier 2 Motor Vehicle Emissi on Standards and Gasoline Sulfur Control Requirements, Heavy-Duty Highway Engine Rule, and the Nonroad Diesel Engine Rule are factored into the changes. Additi onally, due to implementation of the NO x SIP Call across the eastern United States, NO x and fine particle levels enteri ng the Chicago Area will also be decreased. SO 2 emissions within Lake and Porter countie s, Indiana are projected to decrease by 35.54% between 2008 and 2025. SO 2 emissions within the Chi cago Area are projected to decline by 34.73% between 2008 and 2025. Direct PM 2.5 emissions within Lake and Porter counties, Indiana are project ed to decrease by 6.74% between 2008 and 2025. Direct PM 2.5 emissions within the Chicago Area are projec ted to decline by 2.69% between 2008 and 2025. 0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000

2005 2008 2015 2020 2025TonsperYear

Nitrogen Oxides Sulfur Dioxide Direct Fine Particles Year32 Table 4.1 Comparison of 2008 Estimated and 2025 Projected Emission Estimates, Lake and Porter Counties, Indiana (Tons per Year)

2008 2025 Change % Change

NO x 59,581.74 35,013.79 -24,567.95 41.23% decrease

SO 2 56,198.68 36,787.24 -19,411.44 35.54% decrease
Direct PM 2.5 7,250.93 6,762.10 -488.83 6.74% decrease

Table 4.2 Comparison of 2008 Estimated and 2025 Projected Emission Estimates, Entire Chicago Area (Tons per Year)

2008 2025 Change % Change

NO x 278,649.74 149,198.79 -129,450.95 46.46% decrease

SO 2 152,367.68 99,453.24 -52,914.44 34.73% decrease
Direct PM 2.5 25,767.93 25,074.10 -693.83 2.69% decrease

4.4 Demonstration of Maintenance

Quality assured ambient air quality data from all the monitoring sites indicat e that air quality in Indiana’s portion of the nonattainment area met the annual standard for fine particles for the three-year period ending in 2010. U.S. EPA’ s Redesignation Guidance states, “A state may generally demonstrate maintenance of the NAAQS by either showing that future emissions of a pollutant or its precursors will not exceed the level of the atta inment inventory, or by modeling to show that the future mix of sources and em ission rates will not cause a violation of the NAAQS.” Section 3.0 of this document shows that the Chicago Area has in fact measured attainment for fine particles for the thr ee consecutive periods ending in 2008, 2009, and 2010. Additionally, emission projections outlined in Secti on 4.0 of this document clearly illustrate that regional NO x , SO 2 , and direct PM 2.5 emissions in the area will cont inue to decline leading to local reductions between 2008 (base year) and 2025 (maintenance plan horizon). Section 7.0 further discusses the implications of these emi ssion trends and provides an analysis to support these conclusions.

In Indiana, major point sources in all counties are required to submit air emissions information once every three years, or annually, if the NO x or SO 2 potential to emit is greater than 2,500 tons per year in accordance with the Emission Reporting Rule, 326 IAC 2-6. IDEM prepares a new periodic inventory for all precurs or emission sectors every three y ears. These precursor emission inventories will be prepared for 2011, 2014, a nd 2017, as necessary, to comply with the inventory reporting requirements established in the CAA. Emissions information will be compared to the 2008 base year and the 2025 proj ected maintenance year inventories to assess emission trends, as necessary, to assure continue d compliance with the a nnual standard for fine particles.33 4.5 Permanent and Enforceable Emission Reductions

Permanent and enforceable reductions of NO x and SO 2 have contributed to th e attainment of the annual standard for fine particles. Some of th ese reductions were due to the implementation of the NO x SIP Call rule and some were due to the application of tight er federal standards on motor vehicles and fuels.

Section 6.0 identifies the emission control measur es specific to Lake and Porter counties, Indiana, as well as the implement ation status of each measure.

4.6 Provisions for Future Updates

As required by Section 175A(b) of the CAA, Indi ana commits to submit to the Administrator, eight years after redesignation, an additional revi sion of this SIP. Th e revision will contain Indiana's plan for maintaining the national primary fine particles air quality standard for ten years beyond the first ten-year pe riod after re designation.

5.0 TRANSPORTATION CONFORMITY BUDGETS

U.S. EPA requirements outlined in 40 CFR 93.118( e)(4) stipulate that motor vehicle emission budgets (MVEBs) for direct PM 2.5 and NO x be established as part of a SIP. The MVEBs are necessary to demonstrate conformance of tran sportation plans and impr ovement programs with the SIP.

5.1 On-Road Emission Estimates

The Northwest Indiana Regional Planning Comm ission (NIRPC) is the Metropolitan Planning Organization (MPO) for the area that includes Lake, Porter, and LaPorte counties. This organization maintains a travel demand forecast model that is used to simulate the traffic in the area and are used to predict what the traffic would be like in future years given growth expectations. They are also used mostly to iden tify where travel capacity will be needed and to determine the infrastructure requirements necessary to meet that need. It is also used to support the calculation of mobile source emissions. The tr avel demand forecast model is used to predict the total daily vehicle miles traveled (VMT) and the U.S. EPA software program, MOBILE6.2, is used to calculate per mile emissions. The pr oduct of these two outputs, once combined, is the estimated total amount of pollution emitted by the on-road vehicles for the area analyzed.

5.2 Overview

Broadly described, MOBILE6.2 is used to determ ine “emission factors”, which are the average emissions per mile (grams/mile) for fine pa rticles and fine particle precursors (NO x , SO 2 , and direct PM 2.5 ). There are numerous variables that can affect the emission factors. The vehiclefleet (vehicles on the road) age and the vehicle type s have a major effect on the emission factors. The facility-type on which vehicles are trav eling (MOBILE6.2 facili ty types are Freeway, Arterial, Local, and Ramp) and th e vehicle speeds also affect the emission factor values.34 Meteorological factors such as ai r temperature and humidity affect emission factors, as does fuel type, such as low Reid Vapor Pressure gaso line. These data are estimated using the best available data to create emission factors for PM 2.5 precursors (NO x , SO 2 , and direct PM 2.5 ). After emission factors are determined, they must be multiplied by the VMT to determine the quantity of vehicle-related emissions. This in formation is derived from the travel demand model.

It should be noted that each year analyzed will have different emission factors, volumes, speeds, and likely results in additional modeling. MO BILE6.2 input and output files are found in Appendix F.

5.3 Analysis Years

The travel demand model contains road networ ks that are time specific. The NIRPC has modeled the years 2005, 2010, 2020, and 2030. Informa tion, including emissions, has also been interpolated from 2005 and 2010 for the year 2008, from 2010 and 2020 for the years 2015 and 2016, and from 2020 and 2030 for the year 2025. This Redesignation Petition provides emission inventory estimates for 2002, 2005, 2008, 2015, 2020, and 2025 to meet the requirements specified by the CAA and U.S. EPA. The emi ssion estimates outlined in Section 4.0 of this document reference the mobile source em issions data contained in Table 5.1.

5.4 Emission Estimates

Table 5.1 outlines on-road emission estimates for the entire nonattainment area for the years 2005, 2008 (base/attainment year), 2015, 2016, 2020 (int erim years), and 2025 (horizon year).

Table 5.1 Emission Estimates for On-Road Mobile Sources

Chicago Area 2005 2008 2015 2016 2020 2025 Direct PM 2.5 (tons/year) 2,443.50 1,816.00 1,231.00 1,137.00 1,043.00 1,064.00
NO x (tons/year) 133,623.50 99,627.00 49,746.00 39,424.00 29,102.00 23,687.00
Lake and Porter Counties, IN subtotal

Direct PM 2.5 (tons/year) 229.39 187.09 136.61 132.15 114.32 115.39
NO x (tons/year) 14,095.55 10,703.81 5,723.67 5,179.87 3,004.68 2,534.95

Lake and Porter Counties, IN subtotal%

Direct PM 2.5 (tons/year) 9.39% 10.30% 11.10% 11.62% 10.96% 10.84% NO x (tons/year) 10.55% 10.74% 11.51% 13.14% 10.32% 10.70%35 5.5 Motor Vehicle Emission Budget

Table 5.2 contains the motor vehicle emi ssion budget for the Indiana portion of the nonattainment area for the years 2016 and 2025. These MVEBs are intended to be direct replacements of those provided in Indiana’s previous submittal.

Table 5.2 Motor Vehicle Emission Budgets for Lake and Porter Counties

2016 2025 PM 2.5 (tons/year) 145.37 132.70 NO x (tons/year) 5,697.86 2,915.19

Consistent with the federal implementation rule for fine particles, Indiana does not consider mobile source SO 2 to be a significant contributor to fine particles for this nonattainment area, as mobile source SO 2 constitutes less than one percent (<1% ) of the area’s total anthropogenic emissions.

These budgets include emission estimates calculated for 2016 and 2025. The emission estimates are derived from the MPO’s travel demand models and MOBILE6.2, as described above. Through the interagency consultatio n process, it was determined th at an interim budget year of 2016, in addition to the horizon year budget of 2025, would be appropriate. The interagency consultation group approved a ten pe rcent (10%) safety margin for PM 2.5 and NO x mobile source emissions estimates for the year 2016 and a fifteen percent (15%) safety margin for PM 2.5 and NO x mobile source emissions estimates for the y ear 2025. Margins of safety are used to accommodate the wide array of assumptions that ar e factored into the calculation process. Since assumptions change over time, it is necessary to have a margin of safety that will accommodate the impact of refined assumptions in the process.

The rule at 40 CFR 93.101 defines safety marg in as the amount by which the total projected emissions from all sources of a given pollutant ar e less than the total emissions that would satisfy the applicable requirement for reasonable furthe r progress, attainment, or maintenance. When compared to the overall safety margin as de fined by 40 CFR 93.101, it is ev ident this allocation to mobile sources is significantly below the total safety margin for all sources in Lake and Porter counties, Indiana as detailed in Table 4.1.

5.6 Commitment to Amend Motor Vehicle Emi ssion Budgets Using Motor Vehicle Emission Simulator (MOVES)

On March 2, 2010, U.S. EPA published a Notice of Availability for the MOVES model. IDEM is committed to submitting a revision to the MOBILE6.2 developed MVEBs using the MOVES model as soon as possible and well in adva nce of the March 2, 2012, expiration of the transportation conformity “grace period.” ID EM recognizes that U.S. EPA will allow the MOBILE6.2 budgets to be replaced through an ade quacy notice in place of a full publication to the Federal Register.36 All methodologies, latest planning assumpti ons, margins of safety, and MOVES model commitments were determined appropriate through the intera gency consultation
process.

6.0 CONTROL MEASURES AND REGULATIONS

This section provides specific information on the control measures that have been or will be implemented in Lake and Porter counties, Indi ana, including CAA requirements and additional state or local measures imple mented beyond CAA requirements.

6.1 Reasonably Available Control Technology (RACT)

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

326 IAC 8-1-6 BACT fo r Non-Specific Sources 326 IAC 8-2 Surface Coating Emission Limitations 326 IAC 8-3 Solvent Degreasing Operations 326 IAC 8-4 Petroleum Sources 326 IAC 8-5 Miscellaneous Operation 326 IAC 8-6 Organic Solvent Emission Limitations

Since Lake and Porter counties, I ndiana attained the annual standard for fine particles prior to an Attainment SIP or RACT SIP being due, and sinc e the Implementation Rule for fine particles stipulates that states are only required to draft and implemen t RACT rules for the precursor emission reductions necessary to attain the sta ndard, no further RACT rules are required for this area. These Indiana rules are CAA requirement s already in the SIP and provide secondary benefits for PM 2.5
. 6.2 Implementation of Past SIP Revisions

The Chicago Area was designated nonattainment for the annual standard for fine particles in 2003 and the area has now attained the standard well in advance of its attainment deadline of 2010. As a result, Indiana is no longer required to develop and submit an Attainment SIP or RACT SIP for this area under the an nual NAAQS for fine particles.

6.3 Nitrogen Oxides Rule

The U.S. EPA NO x SIP Call required twenty-two states to adopt rules that would result in significant emission reductions from large EGUs, industrial boilers, and cement kilns in the eastern United States. The Indiana rule was adopted in 2001. Beginning in 2004, this rule37 accounts for a reduction of a pproximately 31% of all NO x emissions statewide compared to previous uncont rolled years.

Twenty-one other states have also adopted these rules. The result is that significant reductions have occurred regionally and within the nonattai nment area because of th e number of affected units within the region. From Graphs 4.13 and 4.14, it can be seen that emissions covered by this program have been trending downward since 1999. Table 6.1, compiled from data taken from the U.S. EPA Clean Air Markets web site, quantifies the gradual NO x reductions that have occurred in Indiana as a result of Titl e IV (Acid Rain) of the CAA and the NO x SIP Call Rule. The NOx SIP Call cap stayed in place through 2008, at which time the caps in the CAIR program superseded it. Since CAIR is a regiona l cap and trade program, it cannot be predicted at this time what affect this will have on EGUs located in the nonattainment area or other upwind counties.

Further, U.S. EPA published Phase II of the NO x SIP Call that established a budget for large (emissions of greater than 1 ton pe r day) stationary internal combus tion engines. In Indiana, the rule decreases emissions statewide from natural gas compressor stations by 4,263 tons during the ozone season (April through Septem ber). The Indiana Phase II NO x SIP Call Rule became effective February 26, 2006 and im plementation began in 2007.

Table 6.1 Trends in EGU NO x Emissions Statewide in Indiana

Year NO x Emissions (tons/year) 1999 347,216.5 2000 334,522.1 2001 315,419.7 2002 281,146.1 2003 260,980.0 2004 224,311.3 2005 207,981.6 2006 202,728.0 2007 196,553.1 2008 196,134.5 2009 110,968.9 Budget 2009-2014 108,935 Budget 2015 and later 90,779

6.4 Measures Beyond Clean Air Act SIP Requirements

Reductions in fine particle precur sor emissions have occurred, or are anticipated to occur, as a result of local and federal programs. These additional control measures include those listed in this section.38 Tier 2 Vehicle Standards 2

Federal Tier 2 motor vehicle sta ndards require all passe nger vehicles in a manufacturer’s fleet, including light-duty trucks and s port utility vehicles (SUVs), to meet an average standard of 0.07 grams of NO x per mile. Implementation began in 2004 and was completed in 2007. The Tier 2 standards also cover passenger vehicles over 8,500 pounds gross vehicle weight rating (larger pickup trucks and SUVs), which are not covered by the current Tier 1 standards. For these vehicles, the standards were phased in begi nning in 2008, with full compliance in 2009. The new standards require vehicles to be 77% to 95 % cleaner than those on the road prior to the program. The Tier 2 standards also reduced the sulfur content of gasoline to 30 parts per million (ppm) beginning in January 2006. Most gasoline sold in Indiana prior to January 2006 had a sulfur content of about 500 ppm. Sulfur occurs naturally in gasoline, but interferes with the operation of catalytic converters on vehicles resulting in higher NO x emissions. Lower sulfur gasoline is necessary to achieve the Tier 2 vehicle emission standards.

Heavy-Duty Gasoline and Dies el Highway Vehicle Standards 3

New U.S. EPA standards designed to reduce NO x and VOC emissions from heavy-duty gasoline and diesel highway vehicles took effect in 2004. A second pha se of standards and testing procedures that began in 2007, reduced fine par ticles from heavy-duty highway engines and also reduced highway diesel fuel su lfur content to 15 ppm since th e sulfur can damage emission control devices. The total program is expect ed to achieve a 90% reduction in direct PM 2.5 emissions and a 95% reduction in NO x emissions for these new engi nes using low sulfur diesel, compared to existing engines using higher sulf ur content diesel. There will also be SO 2 reductions from these rules. U.S. EPA ha s not quantified the expected reductions.

Large Nonroad Diesel Engine Standards 4

In May 2004, U.S. EPA promulgated new rules for large nonroad diesel engines, such as those used in construction, agricultur al, and industrial equipment, to be phased in between 2008 and 2014. The nonroad diesel rules also reduce the al lowable sulfur in nonroad diesel fuel by over 99%. Prior to 2006, nonroad diesel fuel averaged approximately 3,400 ppm sulfur. This rule limited nonroad diesel sulfur content to 500 ppm by 2006 with a further reduction to 15 ppm by 2010. The combined engine and fuel rules will reduce NO x and PM emissions from large nonroad diesel engines by over 90%, compared to current nonroad engines using higher sulfur content diesel.

Nonroad Spark-Ignition Engines and Recreational Engine Standards

This new standard, effectiv e in July 2003, regulates NO x , VOCs, and carbon monoxide (CO) for groups of previously unregulated nonroad engines. The new standard applies to all new engines sold in the United States and imported after the st andards went into effect . The standard applies to large spark-ignition engines (forklifts and airport ground se rvice equipment), recreational

2 http://www.epa.gov/fedrgstr/EPA-AIR /2000/February/Day-10/a19a.htm
3 http://www.epa.gov/fedrgstr/EPA-AIR /1997/October/Day-21/a27494.htm
4 http://www.epa.gov/fedrgstr/EPA-AIR /1998/October/Day-23/a24836.htm39 vehicles (off-highway motorcycle s and all-terrain vehicles), a nd recreational marine diesel engines. The regulation varies based upon the type of engine and vehicle.

The emissions from large spark-ignition engines contribute to ozone form ation and ambient CO and PM 2.5 levels in urban areas. Tier 1 of this standard was implemented in 2004 and Tier 2 started in 2007. Like the large spark-ignition engines, emissions from recreational vehicles contribute to ozone and fine partic les formation and ambient CO and PM 2.5 levels. For Model Year 2006 off-highway motorcycles and all-terrain vehicles, at least 50% of a manufacture’s fleet was required to meet the new exhaust emissions standard and 100% of the fleet was required to meet the standards in 2007. Recreati onal marine diesel engines over 37 kilowatts are used in yachts, cruisers, and ot her types of pleasure cr aft. Emissions from recreational marine engines contribute to ozone formation and PM levels, especially surrounding marinas.

When all of the nonroad spark- ignition engines and recreationa l engine standards are fully implemented, an overall 72% reduc tion in VOC, 80% reduction in NO x , and 56% reduction in CO emissions are expected by 2020.

Reciprocating Internal Co mbustion Engine Standards 5

This new standard, effective in May 2010, regulates emissions of air toxics from existing diesel powered stationary reciprocating internal combustion engines that meet specific s ite rating, age, and size criteria. These engines are typically used at industrial facilities (e.g. power, chemical, and manufacturing plants) to ge nerate electricity for compre ssors and pumps and to produce electricity to pump water for flood a nd fire control during emergencies.

The standard applies to stationary diesel engine s: (1) used at area sources of air toxics and constructed or reconstructed befo re June 12, 2006; (2) used at majo r sources of air toxics, having a site rating of less than or e qual to 500 horsepower, and constr ucted or reconstructed before June 12, 2006; and, (3) used at major sources of air toxics for non-emergency purposes, having a site rating of greater than 500 horsepower, and constructed or reconstructed before December 19, 2002.

Operators of existing engines will be required to: (1) install em issions control equipment that would limit air toxics up to 70% for stationary non-emergency engi nes with a site rating greater than 300 horsepower; (2) perform emission test s to demonstrate engine performance and compliance with rule requirements; and, (3) bur n ultra-low sulfur fuel in stationary nonemergency engines with a site rati ng greater than 300 horsepower.

When all of the reciprocating internal combustion engine standards are fully implemented in 2013, U.S. EPA estimates that emissions from these engines will reduce air toxics by approximately 1,000 tons per year (tpy), PM 2.5 by 2,800 tpy, CO by 14,000 tpy, and VOC by 27,000 tpy.

5 http://www.epa.gov/ttn/atw/rice/fr03mr10.pdf40 Category 3 Marine Diesel Engine Standards 6

This new standard, effective in June 2010, pr omulgates more stringent exhaust emission standards for new large marine diesel engines with per-cylinder displacement at or above 30 liters (commonly referred to as Category 3 compre ssion-ignition marine engines) as part of a coordinated strategy to address em issions from all ships that affect U.S. air quality. These emission standards are equivalent to those adop ted in the amendments to Annex VI to the International Convention for the Prevention of Pollution from Ships (MARPOL Annex VI). The emission standards apply in two stages—near-term standards for newly built engines will apply beginning in 2011; long-term standard s requiring an 80% reduction in NO x emissions will begin in 2016.

U.S. EPA is adopting changes to the diesel fuel program to allow for the production and sale of diesel fuel with up to 1,000 ppm sulfur for use in Category 3 marine vessels. The regulations generally forbid production and sale of fuels with more than 1 ,000 ppm sulfur for use in most U.S. waters, unless operators achieve equiva lent emission reducti ons in other ways.

U.S. EPA is also adopting provisions to apply some emission and fuel standards to foreignflagged and in-use vessels that are covered by MARPOL Annex VI.

When this strategy is fully implemen ted in 2030, U.S. EPA estimates that NO x and PM 2.5 emissions in the U.S. will be reduced by approximately 1.2 million tpy and 143,000 tpy, respectively.

Clean Air Interstate Rule (CAIR)

On May 12, 2005, U.S. EPA promulgated the “Rule to Reduce Interstate Transport of Fine Particulate Matter and Ozone (C lean Air Interstate Rule); Revisions to Acid Rain Program; Revisions to the NO x SIP Call”; Final Rule (70 FR 25162). Th is rule established the requirement for states to adopt rules limiting the emissions of NO x and SO 2 and provided a model rule for the states to use in developing thei r rules to meet federal requirements. The purpose of CAIR was to reduce interstate transport of precu rsors to fine particles and ozone.

CAIR applied to: (1) any stationary, fossil-fuel -fired boiler or stati onary, fossil-fuel-fired combustion turbine, a generator w ith a nameplate capacity of more than 25 megawatt electrical (MWe) producing electricity for sale; and (2) a unit that qualifies as a cogeneration unit during the 12-month period starting on the da te that the unit first produces electricity and continues to qualify as a cogeneration unit, a cogeneration unit serving at any time a generator with a nameplate capacity of more than 25 MWe and s upplying in any calendar year more than onethird of the unit’s potentia l electric output capacity or 219,000 megawatt hours (MWh), whichever is greater, to any utility power distri bution system for sale.

6 http://www.regulations.gov/s earch/Regs/home.html#documen tDetail?R=0900006480ae43a641 This rule provides annual state caps for NO x and SO 2 in two phases, with the Phase I caps for NO x and SO 2 starting in 2009 and 2010, respectively. Ph ase II caps become effective in 2015. U.S. EPA is allowing the caps to be met through a cap and trade program if a state chooses to participate in the program.

In response to U.S. EPA’s rulemaking, IDEM a dopted a state rule in 2006 based on the model federal rule. IDEM’s rule includes annual and seasonal NO x trading programs, and an annual SO 2 trading program. This rule requir es compliance effective January 1, 2009.

SO 2 emissions from power plants in the 28 eastern states and the District of Columbia covered by CAIR will be cut by 4.3 million tons by 2009 and reduced by an additional 5.4 million tons in 2015. NO x emissions will be cut by 1.7 million tons by 2009 and reduced by an additional 1.3 million tons in 2015. The D.C. Circuit court’s va catur of CAIR in July of 2008 and subsequent remand without vacatur of CAIR in December of 2008 directs U.S. EPA to revise or replace CAIR in order to properly address the deficiencies outlined by the court.

Since the court’s opinion made it clear that CAIR is deficient and must be revised or replaced, the program cannot be defined as permanent a nd enforceable for SIP purposes. On July 6, 2010, U.S. EPA proposed the Clean Air Transport Rule to replace CAIR. The Clean Air Transport

Rule will result in even further benefits above and beyond CAIR than what is assumed within the emission inventories and modeling.

Together, these rules will substantially reduce local and regional sour ces of fine particle precursors. The modeling analyses discussed in Section 7.0 include thes e rules and show the reductions in annual fine particle concentrations expected to result from the implementation of these rules.

6.5 Controls to Remain in Effect

IDEM commits to maintain the control measures listed above after redesignation, or submit to U.S. EPA, as a SIP revision, any changes to its rules or emission limits applicable to NO x , SO 2 , or direct PM 2.5 sources as required for maintenance of th e annual standard for fine particles in Lake and Porter counties, Indiana.

Indiana, through IDEM’s Office of Air Quality and its Compliance and Enforcement Branch, has the legal authority and necessary resources to act ively enforce any violations of its rules or permit provisions. After redesignati on, it intends to continue enforci ng all rules that relate to the emission of fine particles and fi ne particle precursors in Lake and Porter counties, Indiana.

6.6 New Source Review Provisions

Indiana has a long standing and fully implemente d New Source Review (NSR) program that is outlined in rule 326 IAC 2. The rule includes pr ovisions for the Prevention of Significant Deterioration (PSD) permitting program in 326 IAC 2-2 and the emissions offset rule in 326 IAC42 2-3. Indiana's PSD program was conditionally approved on March 3, 2003 (68 FR 9892) and received final approval on May 20, 2004 (69 FR 29071) by U.S. EPA as part of the SIP.

Any emission unit that is not lis ted in the 2005 emission inventor y, or for which credit through the shutdown or curtailment of operations was taken in demonstrating attainment, will not be allowed to construct, reopen, modify, or recons truct without meeting all applicable permit rule requirements. The review process will be identical to that used for new sources. Once the area is redesignated, OAQ will implement NSR through the PSD program, which requires an air quality analysis to evaluate whethe r the new source will threaten the NAAQS.

7.0 MODELING AND METEOROLOGY

Although U.S. EPA’s Redesignation Guidance does not require modeling for fine particle nonattainment areas seeking rede signation, extensive modeling has been performed for the Chicago Area to determine the effect of nationa l emission control strategies on fine particle levels. These modeling analyses determined that the Chicago Area, including Lake and Porter counties in Northwest Indiana, ar e significantly impacted by regiona l transport of fine particles and its precursors, and that regional SO 2 and NO x reductions are an effective way to attain the annual standard for fine particles in this area . Future year modeled annual fine particle concentrations are expected to be reduced by 2% to 9% from baseline design values. Examples of these modeling analyses are described in this section and can also be found in Appendix H.

7.1 Summary of Modeling Results to Support Rulemakings

U.S. EPA Modeling for Clean Air Transport Rule 2010 7

U.S. EPA performed modeling to support the emission reductions associated with the proposed Clean Air Transport Rule. U.S. EPA used the Comprehensive Air Qualit y Model with Extension (CAMx version 5), applied to the 2005 mete orology, as processed by the Mesoscale Model (MM5), version 3.7.4. Emissions input into CAMx included SO 2 , NO x , VOCs, NH 3 , and direct PM 2.5 for 2005. The modeling was based on the annua l fine particle design values calculated from 2003 through 2005, 2004 through 2006, and 2005 through 2007. Future year modeling was conducted, which included the Chicago Area, and the future year design values for 2012 and 2014 were evaluated for attainment of the annual NAAQS for fine particles of 15 μg/m 3 , as shown in Table 7.1. Fine particle concentratio ns are accounted for by modeling both the base future year emissions and then the emission reductions associated with the Clean Air Transport Rule. U.S. EPA found model performance met s uggested benchmark performance goals within or close to the ranges found in othe r comparable modeling applications.

7 http://www.epa.gov/airquality/transp ort/pdfs/TR_AQModeling_TSD.pdf43 Table 7.1 Clean Air Transport Rule Modeli ng Results from U.S. EPA – 2010

SITE ID SITE NAME COUNTY Design Value 2003 – 2007

(μg/m 3 ) Future Design Value 2012 Base

(μg/m 3 ) Future Design Value 2014 Base

(μg/m 3 ) 18-089-0006 East Chicago - Franklin School Lake 14.27 13.83 13.35 18-089-0027 Griffith Lake 13.83 13.44 12.97 18-089-1003 Gary – Ivanhoe School Lake 14.02 13.61 13.15 18-089-2004 Hammond - Purdue Lake 14.05 13.66 13.19 18-089-2010 Hammond – Clark High School Lake 13.89 13.47 12.99 18-127-0020 Ogden Dunes Porter 12.66 12.18 11.73 18-127-0024 Dunes National Lakeshor e Porter 13.21 12.73 12.26 17-031-0022 Chicago – Washington High Sc hool Cook - IL 15.21 14.70 14.22 17-031-0050 Chicago – Southeast Police Station Cook - IL 14.81 14.32 13.82 17-031-0052 Chicago – Mayfair Pump Station Cook - IL 15.75 15.16 14.64 17-031-0057 Chicago – Springfield Pump St ation Cook - IL 15.03 14.50 13.98 17-031-0076 Chicago – Com Ed Maintenance Building Cook - IL 14.89 14.41 13.87 17-031-2001 Blue Island Cook - IL 14.77 14.28 13.8 17-031-3301 Summit Cook - IL 15.24 14.73 14.2 17-031-4007 Des Plaines Cook - IL 12.78 12.45 11.92 17-031-4201 Northbrook Cook - IL 12.76 12.44 11.91 17-031-6005 Cicero Cook - IL 15.48 14.92 14.40 17-043-4002 Naperville Du Page - IL 13.82 13.51 12.95 17-089-0003 Elgin Kane - IL 13.32 12.94 12.36 17-089-0007 Aurora Kane - IL 14.34 13.95 13.39 17-097-1007 Zion Lake - IL 11.81 11.57 11.06 17-111-0001 Cary McHenry - IL 12.40 12.08 11.53 17-197-1002 Joliet Will - IL 13.63 13.33 12.79 17-197-1011 Braidwood Will - IL 11.52 11.26 10.77

Modeling results show that the base future year modeling with emi ssion reductions from the Clean Air Transport Rule will account for a 0.4 to 0.5 μg/m 3 decrease in concentrations for 2012, as well as a 0.9 to 1.0 μg/m 3 decrease in concentrations fo r 2014 in the Chicago Area.

Only one PM 2.5 monitor in the Chicago Area had a modeled design value above the annual standard for fine particles for 2012. The Chi cago - Mayfair Pump St ation monitor (ID 17-031- 0052) had a 2003 through 2007 design value of 15.75 μg/m 3 . Review of this monitor’s most current 2006 through 2010 design va lue shows that the design value has decreased by 2.42 μg/m 3 to 13.33 μg/m 3 . Therefore, modeling results should fa ll by a similar value and be well below the annual standard for fine particles. De sign values from 2003 through 2007 to 2006 through 2010 have fallen by an average of 2.1 μg/m 3 throughout the Chicago Area. Graph 7.1 shows the downward trend of the design valu es from 2000 through 2010 from the PM 2.5 monitors located in Lake and Porter counties, Indi ana. In fact, all design valu es are below the annual NAAQS for fine particles.44 Graph 7.1 PM 2.5 Design Value Trends for Lake and Porter Counties, Indiana, 2000 to 2010

Results of the U.S. EPA’s Clean Air Transport Rule modeling show that the Chicago Area will attain the annual fine particle NAAQS in 2012 with modeled impacts reduced by 3% to 4%, and will remain below 15 μg/m 3 . With further reductions projecte d in the Clean Air Transport Rule for 2014, all design values decrease by 6% to 7% a nd the area will continue to attain the annual NAAQS for fine particles.

LADCO Modeling for Clean Ai r Interstate Rule (CAIR)

LADCO conducted modeling to determine the imp act of CAIR in the Midwest. LADCO’s modeling used the CAMx model applied to the year 2005 meteorology, as processed by the MM5. Emissions input into CAMx included SO 2 , NO x , VOCs, NH 3 , and direct PM 2.5 for 2005. The modeling was based on 2003 through 2007 design values. Future year modeling for 2012 and 2018 was conducted and the future year design values were determined without the emission reductions associated with CAIR (Round 6), as shown in Table 7.2. The Clean Air Transport Rule is expected to provide reductions above and beyond CAIR. 11.0 12.0 13.0 14.0 15.0 16.0 17.0 18.0

00

‐ 04 01

‐ 05 02

‐ 06 03

‐ 07 04

‐ 08 05

‐ 09 06

‐ 10Concentrations(ug/m3)

Design Value Years

East Chicago Gary ‐ IITRI Gary ‐ Burr St. Griffith Gary ‐ Madison Street Gary ‐ Ivanhoe Hammond ‐ Clark HS Dunes Natl. Lakeshore Ogden Dunes Annual Standard45 Table 7.2 LADCO Round 6 Modeling Results for Annual PM 2.5 – Without CAIR Emission Reductions (Using 2003 – 2007 Design Values)

SITE ID SITE NAME COUNTY Design Value 2003-2007

(μg/m 3 ) Base-case 2012 (μg/m 3 ) Base-case 2018 (μg/m 3 ) 18-089-0006 East Chicago – Franklin School Lake 14.3 13.7 13.6 18-089-0027 Griffith Lake 13.8 13.0 12.8 18-089-1003 Gary – Ivanhoe Sc hool Lake 14.0 13.1 12.9 18-089-2004 Hammond – Purdue Lake 14.1 13.4 13.3 18-089-2010 Hammond – Clark High School Lake 13.9 13.3 13.2 18-127-0020 Ogden Dunes Porter 12.7 11.9 11.7 18-127-0024 Dunes National Lakes hore Porter 13.2 12.4 12.1 17-031-0022 Chicago – Washington High School Cook - IL 15.2 14.6 14.6 17-031-0050 Chicago – Southeast Police Station Cook - IL 14.8 14.2 14.1 17-031-0052 Chicago – Mayfair Pump Station Cook - IL 15.8 14.9 14.7 17-031-0057 Chicago – Springfield Pump Station Cook - IL 15.0 14.4 14.3 17-031-0076 Chicago – Com Ed Maintenance Building Cook - IL 14.9 14.3 14.2 17-031-2001 Blue Island Cook - IL 14.8 14.2 14.1 17-031-3301 Summit Cook - IL 15.3 14.7 14.6 17-031-4007 Des Plaines Cook - IL 12.8 12.1 11.8 17-031-4201 Northbrook Cook - IL 12.8 12.1 11.8 17-031-6005 Cicero Cook - IL 15.5 14.9 14.8 17-043-4002 Naperville Du Page - IL 13.8 13.0 12.7 17-089-0003 Elgin Kane - IL 13.3 12.5 12.1 17-089-0007 Aurora Kane - IL 14.8 13.9 13.5 17-097-1007 Zion Lake - IL 11.8 11.2 10.9 17-111-0001 Cary McHenry - IL 12.4 11.5 11.2 17-197-1002 Joliet Will - IL 13.7 12.9 12.5 17-197-1011 Braidwood Will - IL 11.5 10.7 10.5

Results of the LADCO Round 6 modeling show th at the Chicago Area would attain the annual NAAQS for fine particles by 2012. As shown in Table 7.2, future year modeled annual fine particle concentrations for 2012 will be 4% to 6% lower than baseli ne annual fine particle design values and 5% to 8% lower in 2018 and will co ntinue to decrease thereafter. A graphical representation of the results for the fine particle monitors located in La ke and Porter counties, Indiana is shown in Graph 7.2.46 Graph 7.2 LADCO Round 6 Modeling Results for Lake and Porter Counties, Indiana for 2012 and 2018

It should be noted that PM 2.5 monitors exist at Gary – IITRI and Gary – Burr Street, however these are source oriented monitors used to compar e to the daily standard only and are not used to determine annual fine part icle attainment status.

7.2 LADCO Round 5 Speciated Mode led Attainment Test Results

The Speciated Modeled Attainment Test (SMAT) is the attainment test for annual fine particles. To determine the future year annual fine particle concentrations, speciated data is calculated. The different species that were modeled and are a ssociated with fine particles include sulfates, nitrates, organic carbon, elemental carbon, a mmonium, particle bound water, “other” primary inorganic fine particles, and pa ssively collected mass. The SM AT results from LADCO’s Round 5 modeling are listed below. Round 5 modeled the emission reducti ons associated with CAIR so the results reflect the impacts from CAIR. Per cent ranges of the model results from the seven active fine particle monitors in Lake and Port er counties, Indiana were broken down into the speciated constituents of fine particle emissions. The percent change from the observed speciated data in 2005 to the futu re year modeled results for 2009 are listed in Table 7.3. While these modeling results are outdated, this weight of evidence demonstration shows the reduction potential from national emission control measures for the PM 2.5 species in Northwest Indiana. An updated analysis will be conducted at a la ter time, using more current emissions and meteorological data and for a rele vant future year projection. 10.0 11.0 12.0 13.0 14.0 15.0 16.0

2003

‐ 2007 2012 2018Concentrations(ug/m3)

Design Value Years

East Chicago Griffith Gary ‐ Madison St. Gary ‐ Ivanhoe Hammond ‐ Purdue Hammond ‐ Clark HS

Dunes Natl. Lakeshore Ogden Dunes Annual Standard47 Table 7.3 LADCO Round 5 SMAT Modeling Results for Lake and Porter Counties, Indiana (Percent decrease from observed to modeled concentrations)

Species of PM 2.5 2009 Sulfates 9% - 10% Nitrates 5% - 6% Organic Carbon 1% - 2% Elemental Carbon 10% - 20% Ammonium 6% - 7% Particle Bound Water 9%

The results demonstrate that elemental carbon, sulfate, particle bound water, ammonium, and nitrates concentration de creases are projected to be at least 6% in the future year 2009. Lesser organic carbon reductions are projected to occur, up to 2%. LADCO modeling shows good performance for sulfates and elemental carbon predicted baseline concen trations, slight overprediction for nitrate concentra tions, and under-predictions of or ganic carbon concentrations. Overall, model performance is adequate for SIP planning and gives a good idea of the effects of emission reductions from national emission cont rol measures on Lake and Porter counties, Indiana.

7.3 LADCO Round 5 Particulate So urce Apportionment Results

Particulate Source Apportionment (PSAT) modeli ng was conducted by LADCO. The results of the PSAT Round 5 modeling show the regional contributions by emission sectors on each monitor that was modeled. Chart 7.1 displays the PSAT modeling results for the East Chicago – Franklin School, Griffith, Gary – Ivanhoe School, Gary – Clark High School, and Hammond – Purdue fine particle monitors in Lake Count y, Indiana and the Dunes National Lakeshore and Ogden Dunes fine particle monitors in Porter County, Indiana. Emi ssion contributions from Illinois’ portion of the nonattainment area was the biggest regional contributor to the East Chicago – Franklin School, Gr iffith, Gary – Clark High School , and Hammond – Purdue fine particle monitors. Emission contributions from both the Indiana and Illinois portions of the nonattainment area were the bigge st regional contributors to the Dunes National Lakeshore, Ogden Dunes, and Gary – Ivanhoe High School fine particle monitors. I ndiana and Illinois were the biggest state contributo rs to all of the monitors depicted in Chart 7.1.

The PSAT Round 5 modeling results indicate the majority of Indiana’s emission sector contributions to fine particle concentrations come from E GUs, ammonium emission sources, mobile, and off-road (including marine, aircra ft, and railroad), and non-EGU sources. These results are considered to be representative of Lake and Porter counties, Indiana as EGU, ammonium, and non-EGU emissions impact the entire area.48 Chart 7.1 Regional/Emission Sector Particulate Sou rce Apportionment Technology (PSAT) Results

East Chicago – Franklin School PM 2.5 Monitor, Lake County, Indiana

Griffith PM 2.5 Monitor, Lake County, Indiana49 Gary – Ivanhoe School PM 2.5 Monitor, Lake County, Indiana

Hammond – Purdue PM 2.5 Monitor, Lake County, Indiana50 Gary – Clark High School PM 2.5 Monitor, Lake County, Indiana

Dunes National Lakeshore PM 2.5 Monitor, Porter County, Indiana51 Ogden Dunes PM 2.5 Monitor, Porter County, Indiana

The following pie charts depict the specie contribu tions to fine particle concentrations at the Lake and Porter counties, Indiana monitors. The pie charts incl ude both the observed 2005 contributions and 2009 modeled contributions for each monitor. Since the monitors are in close proximity to each other, results are fairly simila r in the distribution of specie concentrations among the monitors. Charts 7.2 through 7.7 cover th e fine particle monitors in Lake County while Charts 7.8 and 7.9 cover the monitors in Porter County with the highest monitored concentrations that are used to determine comp liance with the annual NAAQS for fine particles.

The speciation listed in the pie charts include SO 4 – sulfate mass, NO 3 – nitrate mass, OC – organic carbon mass, EC – elemental carbon mass, Soil – crustal material mass, NH 4 – ammonium mass, PBW – partic les bound water mass, and BLAN – passively collected mass.52 Chart 7.2 Modeled Contributions by Sp ecie at the East Chicago – Franklin School PM 2.5 Monitor (Observed Concentrations = 13.8 μg/m 3 ) (Modeled Concentrations =13.2 μg/m 3 )

Chart 7.3 Modeled Contributions by Specie at the Griffith PM 2.5 Monitor (Observed Concentrations = 13.3 μg/m 3 ) (Modeled Concentrations =12.4 μg/m 3 ) so4 26%

no3 14%

oc 25% ec 5% soil 4% nh4 13% pbw 10% blan 4% Observed 2005 Contributions at the East Chicago - Franklin School PM 2.5 Monitor

so4

no3

oc

ec
soil

nh4 pbw
blan so4 23%

no3 14%

oc 28% ec 5% soil 6%

nh4 12% pbw 8%

blan 4% 2009 Modeled Contributions at the East Chicago - Franklin School PM 2.5 Monitor

so4

no3

oc

ec
soil

nh4 pbw

blan

so4 27%

no3 14%

oc 24% ec 4% soil 4% nh4 13% pbw 10% blan 4% Observed 2005 Contributions at the Griffith PM 2.5 Monitor

so4

no3

oc

ec
soil

nh4 pbw

blan so4 24%

no3 15%

oc 27% ec 4% soil 5% nh4 12% pbw 9% blan 4% 2009 Modeled Contributions at the Griffith PM 2.5 Monitor

so4

no3

oc

ec
soil

nh4 pbw

blan53 Chart 7.4 Modeled Contributions by Specie at the Gary - Madison Street PM 2.5 Monitor (Observed Concentrations = 13.5 μg/m 3 ) (Modeled Concentrations =12.3 μg/m 3 )

Chart 7.5 Modeled Contributions by Specie at the Gary - Ivanhoe School PM 2.5 Monitor (Observed Concentrations = 15.2 μg/m 3 ) (Modeled Concentrations =12.9 μg/m 3 ) so4 27%

no3 12%

oc 24% ec 7% soil 4% nh4 12% pbw 10% blan 4% Observed 2005 Contributions at the Gary - Madison Street PM 2.5 Monitor

so4

no3

oc

ec

soil

nh4
pbw

blan so4 23%

no3 13%

oc 27% ec 7% soil 5% nh4 12% pbw 9% blan 4% 2009 Modeled Contributions at the Gary - Madison Street PM 2.5 Monitor

so4

no3

oc

ec
soil

nh4
pbw

blan

so4 24%

no3 13%

oc 27% ec 7% soil 6%

nh4 11% pbw 8%

blan 4% 2009 Modeled Contributions at the Gary - Ivanhoe School PM 2.5 Monitor

so4

no3

oc

ec
soil

nh4
pbw

blan so4 27%

no3 12%

oc 24% ec 7% soil 4% nh4 13% pbw 9% blan 4% Observed 2005 Contributions at the Gary - Ivanhoe School PM 2.5 Monitor

so4

no3

oc

ec

soil

nh4
pbw

blan54 Chart 7.6 Modeled Contributions by Speci e at the Hammond - Purdue PM 2.5 Monitor (Observed Concentrations = 13.6 μg/m 3 ) (Modeled Concentrations =12.7 μg/m 3 )

Chart 7.7 Modeled Contributions by Specie at the Hammond – Clark High School PM 2.5 Monitor (Observed Concentrations = 13.4 μg/m 3 ) (Modeled Concentrations =12.5 μg/m 3 ) so4 23%

no3 15%

oc 27% ec 5% soil 6%

nh4 12% pbw 8% blan 4% 2009 Modeled Contributions at the Hammond - Purdue PM 2.5 Monitor

so4

no3

oc

ec

soil

nh4
pbw

blan so4 26%

no3 14%

oc 24% ec 5% soil 4% nh4 13% pbw 10% blan 4% Observed 2005 Contributions at the

Hammond - Purdue PM 2.5 Monitor

so4

no3

oc

ec

soil

nh4
pbw

blan

so4 26%

no3 14%

oc 23% ec 5% soil 5% nh4 13% pbw 10%

blan 4% Observed 2005 Contributions at the Hammond - Clark High School PM 2.5 Monitor

so4

no3

oc

ec

soil

nh4
pbw

blan so4 23%

no3 14%

oc 26% ec 5%

soil 7%

nh4 12% pbw 9% blan 4% 2009 Modeled Contributions at the Hammond - Clark High School PM 2.5 Monitor

so4

no3

oc

ec

soil

nh4
pbw

blan55 Chart 7.8 Modeled Contributions by Speci e at the Dunes National Lakeshore PM 2.5 Monitor (Observed Concentrations = 12.1 μg/m 3 ) (Modeled Concentrations =11.2 μg/m 3 )

Chart 7.9 Modeled Contributions by Specie at the Ogden Dunes PM 2.5 Monitor (Observed Concentrations = 12.6 μg/m 3 ) (Modeled Concentrations =11.5 μg/m 3 )

Results of the Round 5 PSAT modeling for the Lake and Porter counties, I ndiana fine particle monitors show the highes t pollutant contributors to base-cas e and future year fine particle concentrations are sulfate, orga nic carbon, ammonium, and nitrate. Future year modeling shows decreases in sulfates, nitrates , and ammonium. The future year modeling did show slight increases in organic carbon and soils from the base-case modeled concentrations. so4 26%

no3 14%

oc 23% ec 5% soil 5% nh4 13% pbw 10% blan 4% Observed 2005 Contributions at the Dunes National Lakeshore PM 2.5 Monitor

so4

no3

oc

ec

soil

nh4
pbw

blan so4 23%

no3 14%

oc 26% ec 5%

soil 7%

nh4 12% pbw 9% blan 4% 2009 Modeled Contributions at the Dunes National Lakeshore PM 2.5 Monitor

so4

no3

oc

ec

soil

nh4
pbw

blan

so4 26%

no3 14%

oc 23% ec 5% soil 5% nh4 13% pbw 10% blan 4% Observed 2005 Contributions at the Ogden Dunes PM 2.5 Monitor

so4

no3

oc

ec

soil

nh4
pbw

blan so4 23%

no3 14%

oc 26% ec 5%

soil 7%

nh4 12% pbw 9% blan 4% 2009 Modeled Contributions at the Ogden Dunes PM 2.5 Monitor

so4

no3

oc

ec

soil

nh4
pbw

blan56 7.4 Summary of Existing Modeling Results

U.S. EPA and LADCO modeling for future year design values ha ve consistently shown that existing national emission control measures will bring Lake and Porter counties, Indiana into attainment of the annual NAAQS for fine part icles. Emission control measures to be implemented in the next several years will provide even greater assurance that air quality will continue to meet the standard into the future. Modeling support for CAIR has shown that future year design values for Lake and Porter countie s, Indiana will continue to attain the annual standard for fine particles with modeled future year design values below 15 μg/m 3 . U.S. EPA future year modeling of national emission control strategies will ensure that Lake and Porter counties, Indiana will maintain lower fine partic le concentrations with an increasing margin of safety.

7.5 Meteorological Analysis for Lake and Porter Counties, Indiana

Meteorological conditions are one of the most important factors that influence development and transport of fine particles. Stagnant surface conditions during any time of the year and upper air ridging provides conducive conditions for develo pment and transport of fine particles. Ultimately, passage of surface cold fronts with a clean air mass ch ange will lower fine particle readings in Lake and Po rter counties, Indiana.

7.6 Surface Air Conditions Present During Hi gh Fine Particle Concentration Days

Higher annual concentrations of fine particles tend to correlat e with warmer temperatures and lighter wind speeds, although high fine particle ep isodes can occur in the summer or winter. It should be noted that higher annual fine particle co ncentrations are driven by individual days with higher fine particle concentrations throughout the monitored y ear. Therefore, it is difficult to attribute higher fine particle concentrations to annualized mete orological rankings. Review of several of the higher fine partic le concentration episodes over th e past few years reveal that conditions were hot in the summer with temperatures in the middle 80 o s Fahrenheit or higher and average wind speeds were fairly light. Fall and winter days with higher fine particle concentrations had near normal temperatures bu t wind speeds were very light, and humidity was higher.

7.7 Upper Air Conditions Present During Hi gh Fine Particle Concentration Days

Upper air ridges and more stagnant surface wind conditions predominately affect development and build up of fine particles. Slow movi ng upper air ridges can effectively suppress mixing within the many levels of the atmosphere and caus e pollutants to build up over time. Inversions or increases in temperature with a rise in al titude will prevent mixing with air from the upper atmosphere. These conditions can occur at any time of the year a nd are evident in elevated fine particle episodes in spring, summer, fall, and wi nter months. Review of surface and upper air features of higher fine particle concentration days showed sta gnant surface conditions and upper air ridges existed on those days and helped in the buildup of fine particle concentrations.57 7.8 Analyses of Atmospheric Conditions Duri ng High Fine Particle Concentration Days

Analyses have been conducted to determine the atmospheric conditions that are most prevalent during higher fine particle con centration days in Indiana. L ADCO applied a Classification and Regression Tree (CART) analysis to data from Indiana that correla ted different le vels of fine particle concentrations to meteorological conditi ons from 1999 to 2004 (Donna Kenski, 2005). This type of analysis evaluates meteorological conditions, such as temperature, pressure, wind speed, wind direction, relative humidity, and dew poi nt temperatures at the surface, as well as morning and evening mixing heights in the upper atmosphere which were present when higher concentrations of fine particles were monitored. Results of this CART analysis indicated factors that played a larger role in higher fine partic le concentrations in Indiana were warm-weather conditions with high dew points, southwest winds, and high eveni ng mixing heights. Previous day’s concentrations of fine particles play a key role in higher impacts as well.

Fine particles are made up of severa l constituents, including direct PM 2.5 , sulfates, nitrates, ammonium, organic carbon, and elemental car bon. Depending on the time of the year, concentrations of fine particle constituents vary, with nitrates being more prevalent in the winter and sulfates more prevalent in the summer. Su lfate and nitrates emission reductions have the biggest impact on lower future year fine particle concentrations.

7.9 Summary of Air Quality Index Days in Lake and Porter Counties, Indiana

An analysis was conducted to review the daily fine particle concentrations over a year to determine the Air Quality Index (AQI) trends . Chart 7.10 shows by year (2000 through 2010), the percentage of days during the calendar year which fine particle conc entrations reached the AQI ranges for “Good” (0 to 15.3 μg/m 3 ), “Moderate” (15.4 μg/m 3 to 40.4 μg/m 3 ), and “Unhealthy for Sensitive Groups (USG)” (40.5 μg/m 3 to 65.4 μg/m 3 ). There were no days that fine particle levels reached the “Unhealthy” level of 65.5 μg/m 3 to 150.4 μg/m 3

.58 Chart 7.10 Distribution of PM 2.5 Concentration Days on the AQ I Levels of Health Concern, Lake and Porter Counties, Indiana

Table 7.4 shows how the years ranked for the th ree AQI ranges. The year 2009 had the most “Good” concentration days during the 11-year period analyzed (2000 through 2010). The year 2000 had the most “Moderate” concentration days and the years 2001, 2003, and 2005 had the most “USG” concentration days with no days recorded in 2006, 2008, and 2009. As can be seen, weather plays a large role in fine particle concentration de velopment and transport as 2001, 2002, 2005, 2007, and 2010 were warmer than normal summers which translated to moderate and unhealthy for sensitive gr oup levels of air quality. 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010PercentageofYear

Year

Good Moderate USG59 Table 7.4 Ranking and Percentage of Highest Number of Days at AQI Levels of Health Concern

Ranking Good Moderate Unhealthy for Sensitive Group 1 st 2009 – 78% 2000 – 46% 2001 – 3% 2 nd 2008 – 72% 2001 – 42% 2005 – 3% 3 rd 2004 – 69% 2005 – 40% 2003 – 3% 4 th 2007 – 69% 2002 – 39% 2000 – 2% 5 th 2006 – 66% 2003 – 36% 2010 – 2% 6 th 2010 – 64% 2006 – 34% 2002 – 2% 7 th 2003 – 63% 2010 – 34% 2007 – 2% 8 th 2002 – 60% 2007 – 30% 2004 – 1% 9 th 2005 – 59% 2004 – 30% 10 th 2001 – 56% 2008 – 28% 11 th 2000 – 52% 2009 – 22%

7.10 Summary of Meteorological Analysis fo r Lake and Porter Counties, Indiana

Annual fine particle concentrations in Lake and Porter counties, In diana are driven by higher fine particle concentration days that can occur during any time of the year. Conditions that are most prevalent during higher fine pa rticle concentration days are lighter winds, higher relative humidity, and above average temperatures in th e summer, and near normal temperatures in the fall, winter, or spring. Approxima tely 70% of the days when PM 2.5 concentrations were in the USG range occurred in the summer months with maximum high temperatures of 80oF or above. Weather plays a large role in fine particle concentration de velopment and transport as 2001, 2002, 2005, and 2006 were warmer than normal summer s which translated to more days of moderate and unhealthy for sensitive group levels of air quality. Uppe r air weather patterns generally include ridging over the area with stag nant conditions at the surface caused by lower mixing heights and stable conditi ons for summer episodes and ridgi ng or troughs over the area in the fall, winter, or spring episodes. Surface wind s from any direction can transport pollutants from surrounding areas into Lake and Porter countie s, Indiana. Nitrates are bigger contributors to fine particle concentrations in the winter and sulfates are bi gger contributors to fine particle concentrations in the summer.

8.0 CORRECTIVE ACTIONS

8.1 Commitment to Revise Plan

As noted in Section 4.6, IDEM commits to review and revise, as appropriate, its Maintenance Plan eight years after re designation, as required by S ection 175A of the CAA

.60 8.2 Commitment for Contingency Measures

IDEM will monitor fine particle concentrations to determine whether trends indicate higher values or whether emissions appear to be increasing. If it is determ ined that fine particle levels and emissions are increasing and action is necessary to reverse that trend, IDEM will take action to reverse the noted trend, prior to a violation of th e standard occurring.

IDEM commits to adopt and expeditiously impl ement necessary corrective action in accordance with an Action Level Response described below.

Action Level Response

An Action Level Response shall be prompted when ever a violation of the standard (three year average annual arithmetic mean value of 15.1 μg/m 3 or greater) occurs. In the event that the Action Level is triggered and is not found to be due to an atypical unfavorable meteorological condition, exceptional event, malfunction, or noncompliance with a permit condition or rule requirement, IDEM will determine additional co ntrol measures needed to assure future attainment of the annual NAAQS for fine partic les. In this case, measures that can be implemented in a short time will be selected in order to be in place within eighteen months from the end of the year that prom pted the Action Level Response.

Control Measure Select ion and Implementation

Adoption of any additional control measures is subject to the necessary administrative and legal processes. This process will include publication of notices, an opportunity for public hearing, and other measures required by Indiana law fo r rulemaking by state environmental boards.

If a new measure or control is already promulgated and schedul ed to be implemented at the federal or state level, and that measure or contro l is determined to be sufficient to address the upward trend in air quality, additi onal local measures may be unn ecessary. Furthermore, IDEM will submit to U.S. EPA an analysis to demonstrate the proposed measures are adequate to return the area to attainment.

8.3 Contingency Measures

Contingency measures to be considered will be se lected from a comprehensive list of measures deemed appropriate and effective at the time the selection is made. Listed below are example measures that may be considered. The se lection of measures will be based upon costeffectiveness, emission reduction po tential, economic and social c onsiderations, or other factors that IDEM deems appropriate. ID EM will solicit input from intere sted and affected persons in the maintenance area prior to selecting appropria te contingency measures. All of the listed contingency measures are potentially effectiv e or proven methods of obtaining significant reductions of fine particle precursor emissions. Because it is not possible at this time to determine what control measure will be appropriate at an unspecified time in the future, the list of contingency measures outlined below is not comprehensive. IDEM anticipates that if61 contingency measures should ever be necessary, it is unlikely th at a significant number (i.e., all those listed below) will be required.

1) Vehicle inspection and main tenance program enhancements (increase weight limit, addition of diesel vehicles, etc.). 2) Alternative fuel and diesel retrofit programs for fleet vehicle operations. 3) Require NO x or SO 2 emission offsets for new and modified major sources. 4) Require NO x or SO 2 emission offsets for new and modified minor sources. 5) Increase the ratio of emission of fsets required for new sources. 6) Require NO x or SO 2 controls on new minor sour ces (less than 100 tons). 7) Wood stove change out program. 8) Require increased recovery effici ency at sulfur recovery plants. 9) Various emission reduction measures or dust suppressant for unpaved roads and/or parking lots. 10) Idling Restrictions. 11) Broader geographic applicab ility of existing measures. 12) One or more transportation control meas ures sufficient to achieve at least a 0.5% reduction in actual area-wide precursor emi ssions. Transportation measures will be selected from the following, based upon the f actors listed above, af ter consultation with affected local governments: a) Trip reduction programs, includi ng, but not limited to, employer-based transportation management plans, area wide rideshare programs, work schedule changes, and telecommuting. b) Transit improvements. c) Traffic flow improvements. d) Other new or innovative transportation m easures not yet in widespread use that affected state and local gove rnments deem appropriate.

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

9.0 PUBLIC PARTICIPATION

Indiana published notification for a public hearing and soli citation for public comment concerning the draft Redesignation Petition and Maintenance Plan on the IDEM Web site on April 14, 2011, with publicati on in the following newspape rs on the following dates:

1) The Indianapolis Star, Indi anapolis, Indiana (April 15, 2011). 2) The Times, Munster, Indiana (April 14, 2011). 3) The Post Tribune, Merrillv ille, Indiana (April 14, 2011).62 A public hearing to receive comments concerning the redesignation reque st was conducted on May 18, 2011, at the Lake County Public Library- Highland Branch in Highland, Indiana. The public comment period closed on May 20, 2011. On e comment letter was received during the public comment period. Appendix K includes a copy of the public notice, public hearing script, certifications of newspaper publication of the public notice, the official tran script from the public hearing, and a detailed summary of a nd response to substantive comments.

10.0 CONCLUSIONS

Lake and Porter counties, Indian a, have attained the annual NAAQ S for fine particles. This petition demonstrates that Lake and Porter counties, Indiana, ha ve complied with the applicable provisions of the CAA regarding redesignation of nonattainment areas for fine particles. IDEM has prepared a State Implementation and Maintenan ce Plan that meets the requirement of Section 110(a)(1) of the CAA.

Indiana has performed an analysis that shows the air quality imp rovements are due to permanent and enforceable measures and that additional significant regional NO x and SO 2 reductions following implementation of the Phase II NO x SIP Call rule, and CAIR or its replacement rule will ensure continued compliance (maintenance) with the standard. Furthermore, emission projections indicate that NO x and SO 2 emissions will continue to decline, ensuring that the area continues to maintain compliance with the sta ndard and provide for an increased margin of safety. Based on this presentation, Lake and Port er counties, Indiana, meet the requirements for redesignation under the CAA (Section 107(d)(3)) and U.S. EP A guidance for fine particles.

Consistent with the authority granted to U.S. EP A, the State of Indiana requests that Lake and Porter counties, Indiana, be re designated to attainment for the annual fine particles standard simultaneously with U.S. EPA approval of this Indiana State Implementation and Maintenance Plan.