Page 1 

Enclosure 1

Indiana Sulfur Dioxide (SO2) 2008 through 2010 Monitoring Data Summary 

Compared to the 1-Hour Standard 

County Monitor 

Site ID 2008 2009 2010 

2008-2010 

Design Value 

Daviess 18-027-0002 122 138 115 125 

Floyd 18-043-0004 117 87 72 92 

Floyd 18-043-0007 ^ 192 68 75 112 

Floyd 18-043-1004 138 125 123 129 

Fountain 18-045-0001 236 38 26 100 

Gibson 18-051-0001 ^ 56 44 45 48 

Gibson 18-051-0002 90 65 74 76 

Wabash, IL 17-185-0001 90 69 66 75 

Hendricks 18-063-0002 32 34* 33* 

Jasper 18-073-0002 61 88 39 63 

Lake 18-089-0022 67 59 57 61 

Lake 18-089-2008 37 37 34 36 

LaPorte 18-091-0005 29 23 30 27 

Marion 18-097-0057 79 75 103 86 

Marion 18-097-0073 29 61 48 46 

Morgan 18-109-1001 91 98 105 98 

Pike 18-125-0005 205 194 211 203 

Porter 18-127-0011 82 51 62 65 

Vanderburgh 18-163-0012/21 41 17 19 26 

Vanderburgh 18-163-1002 43 14 18 25 

Vigo 18-167-0018 120 115 61 99 

Vigo 18-167-1014 137 142 169 149 

Warrick 18-173-0002^ 111 38 18 56 

Wayne 18-177-0006 109 70 109 96 

* Not a complete year of data 

^ Monitor was discontinued at the end of 2010 

Design Value greater than or equal to 76 ppb 

Illinois Monitor 
Page 2 

Indiana SO2 2000 through 2010 Monitoring Data Summary Compared to the 1-Hou

Note: U.S. EPA established a new 1-hour primary SO2 standard on June 2, 2010. The new 1-hour standard is met when the 3-year average of the 99th percentile (4th high) of the dai

within an area does not exceed 75 parts per billion (ppb). Only the 2008 through 2010 design values over the new 1-hour standard are highlighted below. Data prior to this was com

standards. The 2000 through 2007 data compared to the new 1-hour standard is included for reference purposes only. 

County Site ID 

99th Percentile Values (4th High)(ppb) 3-year Design Val

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 00-02 01-03 02-04 03-05 04-06 

Daviess 18-027-0002 120 119 119 107 131 91 135 112 122 138 115 119 115 119 110 119 Floyd 18-043-0004 130 98 115 151 152 159 123 139 117 87 72 114 121 139 154 145 Floyd 18-043-0007 170 120 68 67 74 157 158 164 192 68 75 119 85 70 99 130 Floyd 18-043-1004 163 151 119 173 174 158 177 194 138 125 123 144 148 155 168 170 Fountain 18-045-0001 104 118 114 127 125 180 169 200 236 38 26 112 120 122 144 158 Gibson 18-051-0001 103 106 86 82 135 122 101 103 56 44 45 98 91 101 113 119 Gibson 18-051-0002 279 203 194 266 226 154 265 136 90 65 74 225 221 229 215 215 Wabash, IL 17-085-0001 179 138 131 125 172 187 161 109 90 69 66 149 131 142 161 173 Hendricks 18-063-0002 

Monitor began operation in 2004 49 40 37 46 32 34 

Monitor began operation in 2004 49 45 42 

Jasper 18-073-0002 74 60 44 66 44 58 64 49 61 88 39 59 57 51 56 55 Lake 18-089-0022 79 87 80 75 111 115 78 66 67 59 57 82 81 89 100 101 Lake 18-089-2008 105 115 53 72 39 42 36 50 37 37 34 91 80 55 51 39 LaPorte 18-091-0005 32 37 33 31 31 29 27 26 29 23 30 34 34 32 30 29 Marion 18-097-0057 89 98 111 122 116 103 127 122 79 75 103 99 110 116 114 115 Marion 18-097-0073 66 73 82 78 92 79 69 51 29 61 48 74 78 84 83 80 Morgan 18-109-1001 

Monitor began operation in 2004 130 141 108 140 91 98 105 

Monitor began operation in 2004 130 136 126 

Pike 18-125-0005 107 155 130 183 151 119 161 172 205 194 211 131 156 155 151 144 Porter 18-127-0011 62 53 57 53 59 74 55 62 82 51 62 57 54 56 62 63 Vanderburgh 18-163-0012/21 97 82 64 85 72 66 67 69 41 17 1 19 81 77 74 74 68 Vanderburgh 18-163-1002 33 33 33 45 79 60 21 27 43 14 18 33 37 52 61 53 Vigo 18-167-0018 99 104 69 83 130 100 99 90 120 115 61 91 85 94 104 110 Vigo 18-167-1014 143 204 129 143 134 138 104 133 137 142 169 159 159 135 138 125 Warrick 18-173-0002 253 233 202 217 238 143 199 103 111 38 18 229 217 219 199 193 Wayne 18-177-0006 101 107 109 96 101 126 95 100 109 70 109 106 104 102 108 107 

One Year of Data Two Years of Data Incomplete Data Illinois Monitor Design Value grea
Page 3 

Indiana SO2 Monitor Locations

The monitor in Hendricks County is not included on this map since the 2008-2010 data is incomplete. 
1

Enclosure 2

Indiana’s Assessment of the Sulfur Dioxide (SO2) Standard for Nonattainment 

Designation 

Background

On June 2, 2010, the United States Environmental Protection Agency (U.S. EPA) revised the 

primary National Ambient Air Quality Standard (NAAQS) for sulfur dioxide (SO2) [75 FR 

35520]. U.S. EPA revoked both the previous 24-hour and annual primary SO2 standards and 

established a new 1-hour SO2 standard at a level of 75 parts per billion (ppb), based on the threeyear average of the annual 99th percentile of the 1-hour daily maximum concentrations. 

In accordance with Clean Air Act (CAA) Section 107(d), U.S. EPA must designate areas as 

attainment, nonattainment, or unclassifiable for the new 1-hour SO2 standard within two years 

following promulgation of the new standard, or June 2, 2012. States are expected to submit 

initial areas designation recommendations by June 2, 2011. 

U.S. EPA’s final area designations are expected to be based principally on 2008 through 2010 air 

quality data reported from SO2 monitors currently in place, and any refined modeling states 

choose to conduct specifically for area designations. U.S. EPA expects to designate areas in the 

following manner: 

 Nonattainment if either monitoring data or appropriate refined modeling results show a 

violation. 

 Attainment if monitoring and appropriate modeling data show no violations. For an area 

to be designated as attainment, appropriate dispersion modeling regarding such sources 

needs to show the absence of violations even if monitoring does not show a violation. 

 Unclassifiable for all other areas lacking monitoring data and air quality modeling results 

showing no violations. 

Indiana’s Assessment

Consistent with the U.S. EPA’s March 24, 2011 guidance memorandum titled “Area 

Designations for the 2010 Revised Primary Sulfur Dioxide National Ambient Air Quality 

Standards”, the Indiana Department of Environmental Management (IDEM) has conducted a 

thorough review of the affected areas in Indiana. IDEM’s review focused on the following 

analysis criteria outlined in the guidance: 
2

 Air quality monitoring data: Indiana’s core evaluation is based on 2008 through 2010 

monitoring data and is presented in the tables below. The air quality analysis looks at the 

three-year average of the 99th percentile of the yearly distribution of 1-hour daily 

maximum SO2 concentrations for each county. A three-year design value over the new 

SO2 standard is highlighted in yellow. Data was retrieved from the U.S. EPA’s Air 

Quality System (AQS). IDEM is also requesting that U.S. EPA use 2009 through 2011 

monitoring data when making final designations. 

 Emissions-related data: Indiana received detailed emissions information from each 

source emitting over 10 tons of SO2 per year. This data is detailed below for each county 

recommended as nonattainment. Tables identified in this analysis show all stationary 

sources with reported SO2 emissions in tons per year at the facility level within each 

county. U.S. EPA’s Designation Guidance identifies that significant emission levels in 

nearby areas may indicate the potential for the area to contribute to a violation of the SO2

standard. U.S. EPA also suggests states consider sources within 50 kilometers (km) of a 

violating monitor to support nonattainment recommendations. Therefore, for counties 

with violating monitors, Indiana sources within 50 km of the monitor are included in the 

analysis. 

 Geography/topography: The geography and topography analysis looked at physical 

features and land use that might have an effect on the air shed and, therefore, the 

distribution of pollutants over an area. Indiana does not have any significant topographic 

features that significantly influence the distribution of SO2 concentrations within the 

state. 

 Jurisdictional boundaries: The analysis of jurisdictional boundaries looks at the 

planning structure of an area to determine if the implementation of controls in a potential 

nonattainment area can be carried out in a cohesive manner. Indiana is recommending 

the entire county as the nonattainment area boundary which encompasses any Core Based 

Statistical Area (CBSA), Metropolitan Statistical Area (MSA), and/or any Combined 

Statistical Area (CSA) boundaries. 

Indiana is recommending counties with a 2008 through 2010 design value above the new 1-hour 

SO2 standard as nonattainment. In accordance with U.S. EPA’s final rule, the expected 

presumptive boundary for any area designated nonattainment is the county boundary associated 

with the violation unless additional information is provided to U.S. EPA demonstrating a 

different boundary is appropriate. Indiana is recommending the county boundary as the 

nonattainment area. In addition, Indiana is recommending all other counties where monitoring is 

lacking and modeling is not available as unclassifiable. 
3

As a result of thorough analysis, IDEM has developed the following evaluation of nonattainment 

area boundaries for designating areas under the revised 1-hour NAAQS for SO2. 

Indiana’s Recommendations

East Central Indiana: Wayne County 

Within East Central Indiana there is only one SO2 monitor located at 1321 South 9th Street in 

Richmond in Wayne County, Indiana. Monitoring data for the Richmond monitor is listed 

below. The 2008 through 2010 design value for the Richmond monitor is above the new 1-hour 

standard. 

East Central Indiana Monitoring Data 

County Site ID 2008 2009 2010 

2008-2010 

Design Value 

Wayne 18-177-0006 109 70 109 96 

Design Value greater than or equal to 76 ppb 

Indiana evaluated sources that had over 10 tons of SO2 per year within 50 km of a violating 

monitor. The Richmond Power and Light facility in Richmond, Indiana is the only SO2 source 

within Wayne County contributing to the monitor violation in Richmond. 

Indiana is recommending Wayne County as nonattainment based upon the monitor violation. 

The county boundary encompasses the only source contributing to the monitor violation. 

East Central Indiana Emissions 

County Facility Address City 

2008 Actual SO2 Emissions 

(Tons Per Year) 

Wayne Richmond Power and 

Light 

2000 U.S. 27 South Richmond 8,681 

Central Indiana: Marion and Morgan Counties 

Within Central Indiana there are two SO2 monitors located in Marion County and one SO2

monitor located in Morgan County. The monitors in Marion County are located at 1321 South 

Harding Street and 6125 East 16th Street, both in Indianapolis, Indiana. The monitor in Morgan 

County is located at 6075 High Street in Martinsville, Indiana. Monitoring data for the three 

Central Indiana monitors are listed below. The 2008 through 2010 design values for two of the 

three monitors in Central Indiana are above the new 1-hour standard. 
4

Central Indiana Monitoring Data 

County Site ID 2008 2009 2010 

2008-2010 

Design Value 

Marion 18-097-0057 79 75 103 86 

Marion 18-097-0073 29 61 48 46 

Morgan 18-109-1001 91 98 105 98 

Design Value greater than or equal to 76 ppb 

Indiana evaluated sources that had over 10 tons of SO2 per year within 50 km of a violating 

monitor. Within Marion and Morgan counties there are ten sources contributing SO2 emissions 

above 10 tons per year; these are listed in the table below. In nearby Hendricks County there is 

one source, Steel Dynamics, emitting over 10 tons of SO2 per year. However, Indiana does not 

believe that Steel Dynamics contributes to the monitor violations in Marion or Morgan counties. 

The limited monitoring data in Hendricks County also shows values below the new 1-hour SO2

standard. 

Therefore, Indiana is only recommending Marion and Morgan counties as nonattainment based 

upon the monitor violations. The county boundaries encompass the ten sources contributing to 

the monitor violations. 

Central Indiana Emissions 

County Facility Address City 

2008 Actual SO2 Emissions 

(Tons Per Year) 

Marion Indianapolis Power 

and Light-Harding 

Street Station 

3700 South Harding 

Street 

Indianapolis 19,578 

Morgan Indianapolis Power 

and Light-Eagle 

Valley Station 

4040 Blue Bluff Road Martinsville 13,102 

Marion C.C. Perry K Steam 

Plant 

366 Kentucky Avenue Indianapolis 4,493 

Morgan Hydraulic Press 

Brick Company 

6618 North Tidewater Mooresville 515 

Marion Rolls-Royce 

Corporation, Plant 5 

& 8 

2355 & 2001 S. Tibbs 

Avenue 

Indianapolis 142 

Marion Covanta 

Indianapolis, Inc. 

2320 South Harding 

Street 

Indianapolis 110 

Marion Quemetco, Inc. 7870 W. Morris Street Indianapolis 74 

Marion Vertellus Agriculture 

& Nutrition 

Specialities, LLC 

1500 South Tibbs 

Avenue 

Indianapolis 30 

Marion Indianapolis Belmont 

Waste Water 

Treatment Plant 

2700 South Belmont 

Avenue 

Indianapolis 16 

Marion National Starch, LLC 1515 S. Drover Street Indianapolis 12 

Hendricks* Steel Dynamics, Inc. 8000 N. County Road 

225 E. 

Pittsboro 272 

*Other source within 50 km of violating monitors, but excluded from recommended nonattainment area. 
5

West Central Indiana: Fountain, Vermillion and Vigo Counties 

Within West Central Indiana there are two SO2 monitors located in Vigo County and one SO2

monitor located in Fountain County. The monitors in Vigo County are located at 961 North 

Lafayette Avenue and Ft. Harrison Road, both in Terre Haute, Indiana. The monitor in Fountain 

County is located North of State Route 234 and East of the Wabash River. Monitoring data for 

the three West Central Indiana monitors are listed below. The 2008 through 2010 design values 

for all three monitors in West Central Indiana are above the new 1-hour standard. 

The monitor in Fountain County located near the Duke Energy-Cayuga Generating Station was 

discontinued for a short period of time at the end of 2010. The temporary shutdown of the 

monitor was based on a decrease in SO2 emissions due to the installation of a flue-gas 

desulfurization (FGD) scrubber in 2008. This control mechanism drastically reduced the SO2

emissions from the Duke Energy-Cayuga Generating Station to approximately 2,500 tons per 

year, meaning the facility was no longer subject to monitoring requirements under 326 IAC 7-3-

2. The source has agreed to continue monitoring. 

West Central Indiana Monitoring Data 

County Site ID 2008 2009 2010 

2008-2010 

Design Value 

Fountain 18-045-0001 236 38 26 100 

Vigo 18-167-0018 120 115 61 99 

Vigo 18-167-1014 137 142 169 149 

Design Value greater than or equal to 76 ppb 

Indiana evaluated sources that had over 10 tons of SO2 per year within 50 km of a violating 

monitor. Within Vigo County there are five sources contributing SO2 emissions emitting above 

10 tons per year; these are listed in the table below. There are no SO2 sources in Fountain 

County. Indiana evaluated three sources over 10 tons of SO2 per year in nearby Vermillion 

County. The three sources in Vermillion County have the potential to contribute to the monitor 

violation in Fountain. 

Indiana is recommending Fountain and Vigo counties as nonattainment based upon the monitor 

violation. Indiana is also recommending Vermillion County as nonattainment based upon the 

source contribution to the monitor in Fountain County. The county boundaries encompass the 

sources contributing to the monitor violations in Fountain, Vermillion and Vigo counties. 

West Central Indiana Emissions 

County Facility Address City 

2008 Actual SO2 Emissions 

(Tons Per Year) 

Vigo Duke Energy 

Indiana-Wabash 

River 

450 Bolton Road West Terre 

Haute 

75,822 

Vermillion Duke Energy 

Indiana-Cayuga 

State Road 63 Cayuga 50,118 
6

Vermillion Eli Lilly & 

Company-Clinton 

Labs 

10500 South State Road 

63 

Clinton 1,779 

Vigo Duke Energy Wabash 

River Combined 

Cycle Plant 

445 Bolton Road Terre Haute 414 

Vigo Danisco Sweeteners 160 West Dallas Drive Terre Haute 370 

Vermillion Colonial Brick 

Corporation 

817 West Park Cayuga 140 

Vigo Boral Brick 

Manufacturing 

Facility 

5601 East Price Drive Terre Haute 82 

Vigo SG Solutions LLC 444 West Sandford 

Avenue 

West Terre 

Haute 

41 

Southeast Indiana: Floyd County 

Within Southeast Indiana there are three SO2 monitors located in Floyd County. The monitors in 

Floyd County are located at Wiley Tower on Bald Knob Road, Falling Run, and 2230 Green 

Valley Road all in New Albany, Indiana. Monitoring data for the three Southeast Indiana 

monitors are listed below. The 2008 through 2010 design values for all three monitors in 

Southeast Indiana are above the new 1-hour standard. 

IDEM operates a SO2 monitoring site at the Green Valley Elementary School (site ID 18-043-

1004) downwind of the Duke Energy Indiana-Gallagher Generating Station in Floyd County. 

This monitor records approximately the same ambient levels of SO2 as the Falling Run monitor 

(site ID 18-043-0007), also located at the generating station. The Falling Run site does not 

support meteorological monitoring and was discontinued at the end of 2010 since it would not be 

suitable in terms of cost effectiveness to meet the requirements of the new 1-hour SO2 standard 

monitoring requirements. With the continuation of monitoring at the Green Valley Elementary 

School monitor and the Bald Knob monitor (site ID 18-043-0004) located at the Gallagher 

Generating Station, all monitoring requirements in Southeast Indiana will be met for the 1-hour 

SO2 standard. 

Southeast Indiana Monitoring Data 

County Site ID 2008 2009 2010 

2008-2010 

Design Value 

Floyd 18-043-0004 117 87 72 92 

Floyd 18-043-0007 192 68 75 112 

Floyd 18-043-1004 138 125 123 129 

Design Value greater than or equal to 76 ppb 
7

Indiana evaluated sources that had over 10 tons of SO2 per year within 50 km of a violating 

monitor. The Duke Energy Indiana-Gallagher Generating Station is the only SO2 source within 

Floyd County contributing to the monitor violation in New Albany. 

Indiana is recommending Floyd County as nonattainment based upon the monitor violation. The 

county boundary encompasses the only source contributing to the monitor violation. 

Southeast Indiana Emissions 

County Facility Address City 

2008 Actual SO2 Emissions 

(Tons Per Year) 

Floyd Duke Energy 

Indiana-Gallagher 

Jackson Street New 

Albany 

40,438 

Southwest Indiana: Daviess, Gibson and Pike Counties 

Within Southwest Indiana there is one SO2 monitor in Daviess County, two monitors in Gibson 

County, and one monitor located in Pike County. The monitor in Daviess County is located on 

State Road 57. The monitors in Gibson County are located at the Gibson Generating Station 

southeast of the plant and on Gibson Coal Road. The monitor in Pike County is located at 1587 

East Arda Lane. Monitoring data for the four Southwest Indiana monitors are listed below. The 

2008 through 2010 design values for three of the four monitors in Southwest Indiana are above 

the new 1-hour standard. 

An additional monitor is located in Mount Carmel, Illinois, near the Gibson Generating Station 

in Gibson County. With the permission of U.S. EPA, the Gibson Tower monitor (site ID number 

18-051-0001) in Gibson County was discontinued at the end of 2010 with the stipulation that a 

meteorological monitoring site in Mount Carmel, IL be established. This will satisfy all 

monitoring requirements in Southwest Indiana. 

With the implementation of new federal measures, such as the Clean Air Transport Rule, Gibson 

County may attain by the end of 2011. 

Southwest Indiana Monitoring Data 

County Site ID 2008 2009 2010 

2008-2010 

Design Value 

Daviess 18-027-0002 122 138 115 125 

Gibson 18-051-0001 56 44 45 48 

Gibson 18-051-0002 90 65 74 76 

Wabash, IL 17-185-0001 90 69 66 75 

Pike 18-125-0005 205 194 211 203 

Design Value greater than or equal to 76 ppb 

Illinois Monitor 
8

Indiana evaluated sources that had over 10 tons of SO2 per year within 50 km of a violating 

monitor. Pike County has two sources and both Gibson and Daviess counties have one source 

contributing SO2 emissions above 10 tons per year; these are listed in the table below. The two 

large sources in Pike County heavily influence the monitor violations in Daviess County, more 

so than the small SO2 source within Daviess County. There are no other sources within 50 km of 

the monitor violations occurring in Gibson, Pike or Daviess counties. 

Therefore, Indiana is recommending Gibson, Pike, and Daviess counties as nonattainment based 

upon the monitor violations. The county boundaries encompass the sources contributing to the 

monitor violations in Gibson, Pike and Daviess counties. 

Southwest Indiana Emissions 

County Facility Address City 

2008 Actual SO2 Emissions 

(Tons Per Year) 

Pike Hoosier EnergyRatts Generating 

Station 

6825 North Blackburn 

Road 

Petersburg 27,335 

Pike Indianapolis Power 

and Light-Petersburg 

Generating Station 

Highway 57 North Petersburg 22,494 

Gibson Duke Energy 

Indiana-Gibson 

State Road 64 Princeton 20,527 

Daviess Grain Processing 

Corporation 

1443 South 300 West Washington 42 

Summary of Recommendations

The nine counties that currently measure ambient concentrations above the new 1-hour 

SO2 standard are Daviess, Floyd, Fountain, Gibson, Marion, Morgan, Pike, Vigo, and Wayne 

counties. Indiana is recommending these nine counties to be classified as nonattainment based 

on the monitored violations. Indiana is also recommending Vermillion County be classified 

nonattainment based on contributions to the monitor in Fountain County. Indiana feels that these 

ten counties incorporate all sources likely contributing to monitored violations of the standard 

within 50 km of a monitoring site. Indiana is requesting that any county not outlined in this 

enclosure be designated as unclassifiable.