### IDEM INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
We Protect Hoosiers and Our Environment.
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.lN.gov
April 8, 2011

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

Dear Ms. Hedman: 

### R5CEIVED 

## APR 11 

## 2011

u. .). _.' J OFFiCE OF**RE'3~0f1;\L ,~GM!!;IST?ATO'l.** 

Re: Request for Redesignation Petition and Maintenance Plan Under the Annual National Ambient Air Quality Standard for Fine Particles for the Southwestern Indiana Nonattainment Area

The Indiana Department of Environmental Management (IDEM) submits a draft Redesignation Petition and Maintenance Plan for the Southwestern Indiana 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 March 15, 2011, and the public comment period concluded on March 18, 2011.

The attached document consists of the following:

Redesignation Petition and Maintenance Plan • A formal request that the Southwestern Indiana Nonattainment 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 2022 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.

Motor Vehicle Emissions Budgets

• Contained in the Redesignation Petition is a new Motor Vehicle Emissions Budget for 2015 and 2022. The Evansville Metropolitan Planning Organization'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.

Recycled Paper 

# e An Equal Opportunity Employer Please Recycle 

### 0Ms. Hedman Page 2

• A conservative margin of safety was applied to the 2015 and 2022 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 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

KB:sms Enclosure: Request for Redesignation Petition and Maintenance Plan Under the Annual National Ambient Air Quality Standard for Fine Particles for the SQuthwestern ( Indiana Nonattainment Area Cc: John Mooney, U.S. EPA Region 5 (no enclosures) Matt Rau, U.S. EPA Region 5 (wI enclosures) John Summerhays, U.S. EPA Region 5 (wI enclosures) Cheryl Newton, U.S. EPA Region 5 (no enclosures) Pat Morris, U.S. EPA Region 5 (no enclosures) Scott Deloney, IDEM (no enclosures) Christine Pedersen, IDEM (no enclosures) Shawn Seals, IDEM (wI enclosures)



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

Southwestern Indiana Area

Prepared By: The Indiana Department of Environmental Management

April 2011This page intentionally left blank

ii 

### (TABLE OF CONTENTS

1.0 

### INTRODUCTION 1

1.1 Background 1 1.2 Geographical Description 2 1.3 Status of Air Quality : 3

2.0 REQUIREMENTS FOR REDESIGNATION .3

2.1 General 3 2.2 Fine Particle 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 Violations of the Fine Particle Standard 5

3.0 FINE PARTICLES 

### MONITORING 5

3.1 Fine Particle Monitoring Network 5 3.2 Ambient Fine Particle Monitoring Data 6 3.3 Quality Assurance 11 (; 3.4 Continued Monitoring 11

4.0 EMISSION INVENTORY 11

4.1 Emission Trends 11 4.2 Base Year Inventory 20 4.3 Emission Projections 21 4.4 Demonstration of Maintenance 25 4.5 Permanent and Enforceable Emission Reductions 26 4.6 Provisions for Future Updates 26

5.0 TRANSPORTATION CONFORMITY BUDGETS 26

5.1 Onroad Emission Estimates 26 5.2 Overview 27 5.3 Analysis Years 27 5.4 Emission Estimations 27 5.5 Motor Vehicle Emission Budgets 28 5.6 Commitment to Amend Motor Vehicle Emission Budgets Using Motor Vehicle Emission Simulator (MOVES) 29


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1116.0 CONTROL MEASURES AND REGULATIONS 29

6.1 Reasonably Available Control Technology (RACT) 29 6.2 Implementation of Past State Implementation Plan (SIP) Revisions .30 6.3 Nitrogen Oxides (NOx) Rule 30 6.4 Measures Beyond Clean Air Act SIP Requirements .31 6.5 Controls to Remain in Effect 35 6.6 New Source Review Provisions 35

7.0 MODELING AND METEOROLOGy 35

7.1 Summary of Modeling Results to Support Rulemakings .36 7.2 Lake Michigan Air Directors Consortium's (LADCO) Round 5 Speciated Modeled Attainment Test Results 39 7.3 LADCO Round 5 Particulate Source Apportionment Results .40 7.4 Summary of Existing Modeling Results .43 7.5 Meteorological Analysis for Southwestern Indiana .43 7.6 Surface Air Conditions Present during High Fine Particle Concentration Days .43 7.7 Upper Air Conditions Present during High Fine Particle Concentration Days .43 7.8 Analysis of Atmospheric Conditions during High Fine Particle Concentration Days .44 7.9 Summary of Air Quality Index Days in Southwestern Indiana .44 7.10 Summary of Meteorological Analysis for Southwestern Indiana .45

8.0 CORRECTIVE ACTIONS 45

8.1 Commitment to Revise Plan 45 8.2 Commitment for Contingency Measures .46 8.3 Contingency Measures 46

9.0 PUBLIC PARTICIPATION 47

10.0 CONCLUSIONS 48

FIGURES

Figure 3.1 Southwestern Indiana Area 6 Figure 4.1 Regional NO x Electric Generating Unit (EGU) Reductions Between 2002 and 2009 18 Figure 4.2 Regional Sulfur Dioxide (S02) EGU Reductions Between 2002 and 2009 20

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# G TABLES

Table 1.1 National Ambient Air Quality Standards for Fine Particles 2 Table 3.1 Monitoring Data for the Southwestern Indiana Area 8 Table 4.1 Comparison of 2005 Estimated and 2022 Projected Emission Estimates, Southwestern Indiana Area 25 Table 4.2 Comparison of 2008 Estimated and 2022 Projected Emission Estimates, Southwestern Indiana Area 25 Table 5.1 Emission Estimations for Onroad Mobile Sources for the Southwestern Indiana Area 28 Table 5.2 Mobile Source Emission Budgets for the Southwestern Indiana Area 28 Table 6.1 Trends in EGU NO x Emissions Statewide in Indiana .31 Table 7.1 Transport Rule Modeling Results from U.S. EPA

- 2010 36 Table 7.2 LADCO Round 6 Modeling Results 38 Table 7.3 LADCO Round 5 Speciated Modeled Attainment Test (SMAT) Modeling Results for Southwestern Indiana 40 Table 7.4 Ranking of Highest Number of Days at Air Quality Index (AQI) Levels of Health Concern 45

GRAPHS

Graph 3.1 Design Values for the Southwestern Indiana Area for Fine Particles

- 2000 through 2009 9 Graph 3.2 Southwestern Indiana Annual Fine Particle Trends

- 2000 through 2009 10 Graph 4.1 Southwestern Indiana Area NO x Point Source Emissions Trend

- 2002, 2005 and 2008 12 Graph 4.2 Southwestern Indiana Area S02 Point Source Emissions Trend

- 2002, 2005 and 2008 13 Graph 4.3 Southwestern Indiana Area Direct Fine Particle (PM2.s) Point Source Emissions Trend

- 2002, 2005 and 2008 13 Graph 4.4 NO x Emissions Trend, All Sources in the Southwestern Indiana Area

- 2002, 2005 and 2008 15 Graph 4.5 S02 Emissions Trend, All Sources in the Southwestern Indiana Area

- 2002, 2005 and 2008 15 Graph 4.6 Direct PM2.5 Emissions Trend, All Sources in the Southwestern Indiana Area

- 2002", 2005 and 2008 16 Graph 4.7 Regional NO x Emissions from EGUs

- 1999 to 2009 17 Graph 4.8 Regional S02 Emissions from EGUs

- 1999 to 2009 19 Graph 4.9 Comparison of2005, 2008, 2015, 2020 and 2022 Projected NO x Emissions for the Southwestern Indiana Area ; 22 Graph 4.10 Comparison of 2005, 2008, 2015, 2020 and 2022 Projected S02 Emissions for the Southwestern Indiana Area 23 Graph 4.11 Comparison of2005, 2008, 2015, 2020 and 2022 Projected Direct PM2.s Emissions for the Southwestern Indiana Area 23



### vGraph 4.12 Comparison of2005, 2008, 2015, 2020 and 2022 Projected NO x , S02 and Direct PM2.5 Emissions for the Southwestern Indiana Area 24 Graph 7.1 PM2.5 Design Value Trends for the Southwestern Indiana Area

- 2000 through 2009 37 Graph 7.2 LADCO Modeling Results for Southwestern Indiana PM2.5 Monitors

- 2005,2009,2012 and 2018 39

CHARTS

Chart 7.1 Regional/Emission Sector Particulate Source Apportionment (PSAT) Results .41 Chart 7.2 Modeled Contribution by Species to the Jasper, Dubois County PM 2

. 5 Monitor .42 Chart 7.3 Modeled Contribution by Species to the University of Evansville PM 2

. 5 Monitor .42 Chart 7.4 Distribution ofPM2.5 Concentration Days on the AQI Levels of Health Concern .44

APPENDICES

A-I Air Quality System (AQS) and Indiana Department of Environmental Management (IDEM) Monitor Data Values for the Southwestern Indiana Area (2000-2009) A-2 AQS and IDEM Monitor Data Values for the Southwestern Indiana Area (2000-2010) B NO x , S02 and Direct PM2.5 Point Source Emissions (2002, 2005 and 2008) for the Southwestern Indiana Area C NO x , S02 and Direct PM 2

. 5 (2002, 2005 and 2008) Emission Trends, All Sources, Southwestern Indiana Area D NO x and S02 Emissions from Electric Generating Units, Southwestern Indiana Area E 2005 Base Year Emission Inventory, 2008 Secondary Validation Year Emission Inventory and 2015, 2020 and 2022 Projected Emission Inventory for NO x , S02 and Direct PM2.5 in Southwestern Indiana Area F Example Mobile Source 2002, 2010, 2015 and 2025 MOBILE6.2 Input and Output Calculation Files G Jasper Post Office Incomplete PM2.5 Monitoring Data Analysis H Area Source Standard Operating Procedure (SOP) 1-1 LADCO Modeling Protocol 1-2 LADCO Regional Air Quality Analyses for Ozone, PM2.5 and Regional Haze: Technical Support Document 1-3 LADCO Ozone and PM 2 .5 Modeling Results J NO x and S02 Emissions from Electric Generating Units, Six State Region K Modeling and Meteorology Summary L Public Participation Process Documents

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# (1 REQUEST FOR REDESIGNATION AND MAINTENANCE PLAN UNDER THE ANNUAL NATI ONAL AMBIENT AIR QUALITY STANDARD FOR FINE PARTICLES

SOUTHWESTERN INDIANA AREA

1.0 INTRODUCTION

This document supports Indiana’s request that Dubois, Vanderburgh and Warrick counties, Montgomery Township in Gibson County, Ohio Township in Spencer County, and Washington Township in Pike County (herein referred to as the “Southwestern Indiana Area”), be redesignated from nonattainment to attainment of the 1997 annual standard for fine particles. All monitors for fine particles in the Southwestern Indiana Area have recorded three years of quality assured ambient air quality monitoring data for the years 2007 through 2009, demonstrating attainment with the annual standard for fine particles, and the Southwestern Indiana Area is thereby 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) An approved State Implementation Plan (S IP) for the area under Section 110(k). (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 fully approved maintenance plan under Section 175A. (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, measures in the maintenance plan will prevent any future occurrences through con tingency 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 particul ate matter 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, Indiana began monitoring for2 fine particle concentrations. The U.S. EPA desi gnated areas in Indiana un der the fine particle standards on December 17, 2004, as attainment, nonattainment or unclass ifiable, with an effective date of April 5, 2005.

Table 1.1 National Ambient Air Quality Standards for Fine Particles

Annual 24-Hour

1997 Fine Particles

Standard (PM 2.5 ) 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 Fine Particles

Standard (PM 2.5 ) 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 Southwestern Indiana Area meets the 1997 and 2006 24-hour NAAQS for fine particles. Since this area is solely designated nonattainment under th e 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 Southwestern Indiana Area as nonattainment of the annual standard for fine particles, and subject to Section 172 of the CAA, including the develo pment of a plan to re duce nitrogen oxides (NO x ), sulfur dioxide (SO 2 ) and direct PM 2.5 emissions and a demonstrati on that the area will meet the annual standard for fine particles by April 5, 201 0. In order to satisfy these requirements, Indiana submitted a redesignation petition and ma intenance plan to U.S. EPA on April 3, 2008, demonstrating that the Southw estern Indiana Area had met the NAAQS for fine particles by April 5, 2010, with an ample margin of safety. The Southwestern Indiana Area monitors have continued to meet the annual NAAQS for fine particles since the end of 2009.

There were no fine particle monitors in the S outhwestern Indiana Area that violated the 1997 24- hour standard for fine particles th at currently violate the 2006 24-hour standard for fine particles. As a result, the Southwestern Indiana Area was de signated nonattainment for fine particles solely under the 1997 annual standard. Therefore, this document pertains only to the 1997 annual standard for fine particles.

The Southwestern Indiana Area non attainment area for fine partic les, as defined in Section 1.2, has not previously been subject to nonattainment area rulemakings for fine particles. However, the area had been subject to nonattainment ar ea rulemakings under the 1-hour and the 8-hour ozone standards. The 1-hour ozone st andard was revoked on June 15, 2005 and both Vanderburgh and Warrick counties were redesignated to attain ment of the 1997 8-hour ozone standard on January 30, 2006.

1.2 Geographical Description

The Southwestern Indiana nonattainment area for fine particles consists of Dubois, Vanderburgh and Warrick counties, Montgomery Township in Gibson County, Ohio Township in Spencer County and Washington Township in Pike Count y. The Southwestern Indiana Area includes cities such as Evansville, Jasper, Boonvill e, Huntingburg, Petersburg and Rockport and such3 towns as Yankeetown, Inglefield, Owensville, Ferdinand, Chandler, Newburgh and Kasson. This area is depicted in Figure 3.1.

The agency responsible for assuring the nonattai nment area for fine particles complies with the CAA requirements is the Indiana Department of Environmental Management (IDEM), which is responsible for the entire Southwestern Indiana Ar ea. IDEM has worked c ooperatively with U.S. EPA Region V to address at tainment planning issues.

1.3 Status of Air Quality

Monitoring data for fine particles for the th ree years, 2007 through 2009, demonstrates that air quality has met the annual NAAQS for fine partic les in the Southweste rn Indiana Area. For reference purposes, 2010 monitoring data will be included in Appendix A-2 once quality assured. This fact, accompanied by the permanen t and enforceable reductions in emission levels discussed in Section 4.0, justifie s a redesignation to attainment for the subject 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 entitled Procedures for Processing Requests to Redesignate Areas to Attainment , issued September 4, 1992, to Re gional 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 Particle Monitoring

1) A demonstration that the annual standard for fine particles, as published in 40 CFR 50.13, has been attained. Fine partic le monitoring data must show that violations of the annual ambient standard are no longer occurring.

2) Ambient monitoring data quality a ssured 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 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 emissi on inventory of direct PM 2.5 and the precursors of fine particles completed for the base year (2005 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 annual updates of the inventory to enable tracking of the emission levels, including an annual em ission statement from major 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 demonstrate 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 Reasonably Available Control Technology (RACT) requirements fo r existing stationary sources covered 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 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 Particles 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 four Federal Reference Method monitors measuring fine particle concentrations in this nonattainment area. Thes e monitors are located as follows: Dubois County (Jasper, Indiana) and Vanderburgh County (Mill Road/Buena Vista, Civi c Center/Post Office and University of Evansville, Evansville, Indian a). The four monitors are operated by IDEM’s Office of Air Quality (OAQ). A listing of th e monitor readings fr om 2007 through 2009, is shown in Table 3.1 and Appendix A and were retrie ved from the U.S. EPA’s Air Quality System (AQS). The locations of the monitoring sites for this nonattainment ar ea are shown in Figure 3.1.

Included as supporting material ar e two fine particle monitors that operated in Dubois County (Jasper, Indiana) from 2006 to 2008. IDEM also operates two fine particle monitors in nearby Spencer County (Dale, Indiana) a nd Gibson County (Oakland City, I ndiana) that are not part of the Southwestern Indiana nonattainment area.6 Figure 3.1 Southwestern Indiana Nonattainment Area

3.2 Ambient Fine Particle Monitoring Data

The following information summarizes U.S. EP A'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 am bient air quality monitoring site 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.7 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 particle 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 2007 through 2009 design valu es for the 6 active fine particle monitoring sites in the Southwestern Indi ana Area. In addition, 2 discontinued fine particles monitoring sites (Jasper Sport and Jasper Golf) ar e outlined for histor ical reference.8 Table 3.1 Monitoring Data for the Southwestern Indiana Area (Annual Average and 2007-2009 Design Values)

SITE ID COUNTY SITE NAME YEAR Annual Average μg/m3 2007-2009 Average

μg/m3

18-037-0004 Dubois JasperSport 1 2007 14.61 13.4 5 2008 12.10 2009

18-037-0005 Dubois JasperGolf 1 2007 14.92 13.7 5 2008 12.53 2009

18-037-2001 Dubois Jasper-Post Office 2007 14.26 2
13.2 3 2008 12.93 2009 12.49

18-051-0012 Gibson Oakland City 4 2007 11.2 5 2008 11.33 2009 11.00

18-147-0009 Spencer Dale 2007 14.13 12.6 2008 12.03 2009 11.77

18-163-0006/20 Vanderburgh EvansvilleCivic Center/Post Office 6 2007 13.91

12.9 2008 12.58

2009 12.32

18-163-0012/21 Vanderburgh EvansvilleMill Road/Buena Vista 7 2007 14.23

13.1 2008 12.70

2009 12.28

18-163-0016 Vanderburgh EvansvilleUniversity of Evansville 2007 14.21

13.1 2008 12.53

2009 12.49

1 The Jasper Sport and Jasper Golf monitors began operation February 1, 2006 and were discontinued on December 31, 2008. 2 Exceptional event data removed from calculations. 3 Incomplete data see Appendix G. 4 The Oakland City monitor began operation on January 18, 2008. 5 Indicates design value is based on two years of data. 6 The Evansville Civic Center monitor wa s replaced by the Evansville Post Offi ce monitor and data for 2009 as well as the 2007-2009 design value have been combined. 7 The Evansville Mill Road monitor was replaced by the Evansville Buena Vist a monitor and data for 2009 as well as the 2007-2009 design value have been combined.9 Graph 3.1 visually demonstrates the 2000 throug h 2009 design values for the Southwestern Indiana nonattainment area.

Graph 3.1 Design Values for the Southwestern Indiana Area for Fine Particles - 2000 through 2009

Red line represents annual PM 2.5 standard of 15 μg/m 310 Graph 3.2 Southwestern Indiana Annual Fine Particle Trends - 2000 through 2009

Red line represents annual PM 2.5 standard of 15 μg/m 3

The design values for the Southwestern Indiana nonattainment area demonstrate that the annual NAAQS for fine particles has been attained. Refe r to Appendix A for the complete fine particle monitoring data summary for the years 2000 to 2009.

Graph 3.1 shows the trend in design values for the region, while Graph 3.2 shows the trend for annual fine particles. A compre hensive list of the fine particle monitoring sites design values over this period is outlined in Appendix A. The area's design values have recently trended downward, as emissions have declined due to programs such as the Acid Rain program and cleaner automobiles and fuels both regionally and lo cally. U.S. EPA’s rule to control nitrogen oxides from specific 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 large electric generating units (EGUs), industria l boilers and cement kilns. Indiana's NO x SIP Call Rule was adopted into the Indiana Administ rative Code on June 6, 2001 at 326 IAC 10-3 and 326 ICA 10-4. The elevated fine particle values for 2005 are considered an abnormal occurrence. An analysis of meteorological conditions and mon itoring values is included in Section 7.0 and supports the conc lusion that attainment of the standard as of 2009 is not the result of unusually favorable meteorological conditi ons. It is expected that this downward trend will continue as the above programs continue an d the U.S. EPA’s proposed Clean Air Transport Rule (Transport Rule) is implemented.11 3.3 Quality Assurance

IDEM has quality assured all data shown in Appendix A in accordance with 40 CFR 58.10 and recorded the data in the AQS database and, thus, the data is available to the public.

3.4 Continued Monitoring

Indiana commits to continue monitoring fine partic le concentrations at the active sites indicated in Table 3.1 and Appendix A. IDEM will consult with U.S. EPA Region V staff prior to making changes to the existing Indiana monitoring ne twork through the annual network review should changes become necessary in the future. IDEM will continue to qual ity assure the Indiana monitoring data to meet the requirements 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 achieved attainment of the annual NAAQS for fine particles (base year). Indiana is using 2005 as the base year. ID EM 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 emissi ons inventory include: a projecti on of the 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 implemen tation rule for fine particles, IDEM and U.S. EPA do not consider volatile organi c compounds (VOCs) or ammonia (NH 3 ) to be significant contributors to fine particles. The following subsections addre ss each of these requirements.

4.1 Emission Trends

Point Sources

Graphs 4.1, 4.2 and 4.3 show that the tr end in point source emissions of NO x , SO 2 and direct PM 2.5 for the Southwestern Indiana Area generally correspond to th e years of monitored values used in this redesignat ion petition. A secondary validation year of 2008 is used in this document for informational purposes only. The point so urce data are taken from Indiana's emissions reporting program and are based on county point source totals, as opposed to township level emissions. The Southwestern Indi ana Area had a 33% reduction in NO x point source emissions and a slight increase (4%) in SO 2 point source emissions from 2002 to 2005. A moderate increase in direct PM 2.5 point source emissions from 2002 to 2005 is noted, this increase in direct PM 2.5 emissions is due to the f act that most companies di d not submit their direct PM 2.5 emissions data in 2002 but did submit direct PM 2.5 data in the 2005 emi ssions inventory. The Southwestern Indiana Area had a 29% reduction in NO x point source emissions, and a 36%12 reduction in SO 2 point source emissions from 2005 to 2008. As Graph 4.7 illustrates, Southwestern Indiana NO x emissions from electric generating units have decreased substantially during this time period as well. Graphs and da ta tables of emissions for the point source category can be found in Appendix B.
Graph 4.1 Southwestern Indiana Area NO x Point Source Emission Trends - 2002, 2005 and 2008

‐ 20,000 40,000 60,000 80,000 100,000 120,000 140,000

2002 2005 2008TonsperYear

Year Nitrogen Oxides13 Graph 4.2 Southwestern Indiana Area SO 2 Point Source Emission Trends - 2002, 2005 and 2008

Graph 4.3 Southwestern Indiana Area Direct PM 2.5 Point Source Emission Trends - 2002, 2005 and 2008 ‐ 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000

2002 2005 2008TonsperYear

Year Sulfur Dioxide

‐ 2,000 4,000 6,000 8,000 10,000 12,000 14,000

2002 2005 2008TonsperYear

Year Direct Fine Particulate Matter14 All Anthropogenic Sources

Periodic inventories, which include emissions fr om all sectors (mobile, area, nonroad and point sources), were prepared for 2002, 2005 and 2008. The 2008 data were extrapolated from the 2005 emission inventory. Graphs 4.4, 4.5 and 4.6 show the trend in anthropogenic source emissions for the Southwestern Indiana Area. Regional NO x emission reducti ons affect fine particle levels in the Southwestern Indiana Area far more so than NO x emission reductions within the nonattainment area itself. These emission tre nds roughly follow the years of monitored trends discussed in Sectio n 3. There is a downward trend in NO x emissions from 2002 to 2005 and a further decrease 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 SO 2 emissions from 2002 to 2008 as well. While an increase in direct PM 2.5 anthropogenic source emissions from 2002 to 2005 for the Southwestern Indiana Area is noted, this increase in direct PM 2.5 emissions from 2002 to 2005 is due to previously unreported emissions from companies that did not submit their direct PM 2.5 emissions data in 2002 but did submit direct PM 2.5 data in the 2005 emissions inventory, from which the 2008, 2015, 2020 and 2022 data is extrapolated. Graphs and data tables of emissions from each source category are available in Appendix C.

Mobile emissions inventories a nd projections for all counties we re prepared by the Evansville Metropolitan Planning Organizatio n (EMPO) and the Indiana Department of Transportation and are explained in further detail in Section 5.0. All 2005 data for the Southwestern Indiana Area are from the 2005 periodic inventory which has been identified as one of the preferred databases for SIP development. For the 2008 attainment y ear, emissions were extrapolated from the 2005 Lake Michigan Air Directors Consortium’s (LADCO) modeling inventory, using LADCO’s growth factors, for all sectors except point sources (e lectrical generating un its and non-electrical generating units). Point source emissions fo r 2008 were compiled from Indiana’s annual emissions inventory database.

The emissions inventory development and emissi ons projection discussion below, with the exception of the mobile emissions inventory and projections, identify procedures used by IDEM and LADCO regarding emissions for the Southwestern Indiana Area.15 Graph 4.4 NO x Emission Trends, All Sources in th e Southwestern Indiana Area - 2002, 2005 and 2008 (With CAIR)

Graph 4.5 SO 2 Emission Trends, All Sources in the Southwestern Indiana Area - 2002, 2005 and 2008 (With CAIR) ‐ 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000

2002 2005 2008TonsperYear

Year Nitrogen Oxides

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

2002 2005 2008TonsperYear

Year Sulfur Dioxide16 Graph 4.6 Direct PM 2.5 Emission Trends, All Sources in th e Southwestern Indiana Area – 2002, 2005 and 2008 (With CAIR)

EGU Sources

Graphs 4.7 and 4.8 show both NO x and SO 2 emissions are decreasing s ubstantially in response to national programs affecting all EGUs such as the Acid Rain program and the NO x SIP Call. Other sectors of the inventory also impact the fo rmation of fine particles, but large regional sources such as EGUs have a substantial impact on the form ation of fine particles.

The data were taken from U.S. EPA's Clean Air Markets database located at http://www.epa.gov/airmarkets

. Data are available sooner for these units than other point sources in the inventory because of the NO x SIP Call budget and trading requirements. Information from 2003 is significant because some EGUs started operation of their NO x SIP Call controls in order to generate Early Re duction Credits for their future year NO x budgets. The first season of the NO x SIP Call budget period began May 31, 2004.

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 ‐ 2,000 4,000 6,000 8,000 10,000 12,000 14,000

2002 2005 2008TonsperYear

Year Direct Fine Particulate Matter17 the maintenance period covered by this request. The state cap for the NO x SIP Call remained in place through 2008, at which time the CAIR program superseded it. CAIR, issued in March 2005, adopted by the Indiana Air Pollution Control Board on November 1, 2006, and implemented beginning in 2010, will c ontinue to reduce regional EGU NO x 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 2008, directs U.S. EPA to revise the CAIR rule in the future. The proposed 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.

As demonstrated by Figure 4.1 and Gr aph 4.7, significant reductions of NO x associated with the NO x SIP Call and preparation for CAIR have been achieved statewide as well as regionally. For the six state region (Arkansas, Indiana, Illi nois, Kentucky, Missouri and Tennessee) shown in Figure 4.1, within the area south of latitude 38 and west of longit ude -87 (the southwest quadrant denoted by brown lines), there has been a redu ction in upwind EGU emissions of more than 197,000 tons of NO x from 2002 to 2009. These six states ar e important because they represent the predominant upwind states most likely to affect the Southwestern Indiana Area. The specific EGU emissions for NO x and SO 2 from the southwest quadrant, as well as the change in emissions from 1999 to 2009 are listed in Appendix D.

Graph 4.7 Regional NO x Emissions from Electric Ge nerating Units - 1999 to 2009

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

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Total Nitrogen Oxide Emissions (Tons/Year)TonsperYear18 Figure 4.1 Regional NO x EGU Reductions Between 2002 and 2009

As demonstrated by Figure 4. 2, reductions of regional SO 2 from upwind EGUs have also been achieved. For the six state region (Arkansas, Indiana, Illinois, Kentucky, Missouri and Tennessee) shown in Figure 4.2, in the area south of latitude 38 and west of longitude -87 (the southwest quadrant denoted by the brown lines), there has been a reduction of upwind EGU emissions of over 24,000 tons of SO 2 from 2002 to 2009. The specific EGU emissions for NO x and SO 2 from the southwest quadrant, as well as the change from 1999 to 2009 are listed in Appendix D.

Although there are minor fluctuations in the SO 2 emissions over time, as shown in Graph 4.8, well over 50% reductions have b een realized to date. As noted by Graph 4.10 significant reductions are expected in SO 2 emissions from the CAIR program and BART (Best Available Retrofit Technology), once implemented. As a result of the CAIR program, five EGU’s will achieve significant reductions in SO 2 . It is expected that this downward trend will continue as19 the above programs continue and the U.S. EPA’ s proposed Transport Rule is implemented. Alcoa and Cayuga both installed scrubbers in 2008 that will result in a 90% reduction in SO 2 emissions, to meet CAIR rules. Gibson instal led Flue Gas Desulfurization (FGD) systems on Units 1, 2 and 3 between 2006 and 2008. Clifty Cr eek is in the process of installing FGD systems which will also result in 90% reductions in SO 2 at those facilities, despite some technology related problems. Wabash Valley wa s ordered to shut down Units 2, 3 and 5 and complied by September 30, 2009. As a result of Wabash Valley’s successful legal appeal, they may restart these units in the future. At this ti me, there is no clear indi cation that Wabash Valley will restart units 2, 3 and 5. Edwardsport is repl acing all of the coal fired boilers with an Integrated Gasification Combined Cycle (IGCC) system which will result in a slight increase in NO x of 32.49 tons per year and a substantial reduction in SO 2 of 9,834 tons per year. Also, as a result of a recent settlement agreement, American Electric Po wer (AEP) Rockport will install scrubbers to achieve a 90% reduction in SO 2. Appendix B shows detailed emissions for the point source emissions, and Appendix D shows detailed em issions for the Electric Generating Units.

Graph 4.8 Regional SO 2 Emissions from Electric Ge nerating Units - 1999 to 2009

0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000 450,000 500,000

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Total Sulfur Dioxide Emissions (Tons/Year)TonsperYear20 Figure 4.2 Regional SO 2 EGU Reductions Between 2002 and 2009

4.2 Base Year Inventory

IDEM prepared a comprehensive inventory for th e Southwestern Indiana Area, including area, mobile, nonroad and point sources for direct PM 2.5 and precursors of fine particles (NO x and SO 2 ) for 2005 and 2008 (the years with the most comple te emissions inventories available at this time). The 2005 emission inventory represents a base year for maintenance purposes. The 2007 implementation rule for the annual fine particle standard states that NO x , SO 2 and direct PM 2.5 are the regulated precurs ors of fine particles. Ammonia and VOCs are not required to be addressed unless the state or U.S. EPA makes a t echnical demonstration th at emissions of these pollutants from sources in the stat e significantly contribute to PM 2.5 concentrations in a given nonattainment area. U.S. EPA and IDEM have not determined ammonia or VOCs to be significant contributors to fine pa rticles formation in the State of Indiana. Indiana’s 2005 base year inventory was determined by the following:21  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 2005 base year values.

 Point source information was compiled from IDEM’s emissions statement 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 represented in Section 7.

 Nonroad emissions were extrapolated fr om the 2002 National Emissions Inventory (NEI). To address concerns about the accuracy of some of the categories in U.S. EPA’s nonroad emissions model, LADCO contracted with two companies to review the base data and make recommendations. One of th e contractors also estimated emissions for two nonroad categories not included in U.S. EPA's nonroad model. Emissions were estimated for commercial marine vessels a nd railroads. The recreational motorboat population and spatial surrogates (used to as sign emissions to each) were significantly updated. The populations for the constructi on equipment category were reviewed and updated based upon surveys completed in the Midwest and the temporal allocation for agricultural sources was also updated. A new nonroad es timation model was provided by U.S. EPA for the 2002 analysis.

Appendix C contains data tables a nd graphs of all these emissions.

4.3 Emission Projections

In consultation with U.S. EPA and other stakeholders, IDEM se lected the year 2022 as the maintenance year for this redesignation request . This document contai ns projected emission inventories for 2015, 2020 and 2022 for the Southwestern Indiana Area. These emission projections were prepared by IDEM, with assistance from LADCO and the Evansville Metropolitan Planning Organiza tion. The projected emission inventories for 2020 and 2022 were extrapolated from 2018 estimates developed by LADCO.

The detailed 2015, 2020 and 2022 emissions inventory for the Southwestern Indiana Area can be found in Appendix E. Emission trends are an im portant gauge for continued compliance with the annual standard for fine particles. Therefore, IDEM performed an in itial comparison of the inventories for the base year of 2005, secondary validation year of 2008, interim years of 2015 and 2020 and maintenance year of 2022 fo r the Southwestern Indiana Area.

The 2005 LADCO modeling inventory was used as the basis for estimated emissions for the years 2008, 2015, 2020 and 2022, using LADCO’s growth factors, for all s ectors except point sources (electrical generating units and non-electrical generating un its). Point source emissions for 2005 and 2008 were compiled from Indiana’s a nnual emissions inventory databases. The 2008 secondary validation emissions for other s ectors were extrapolated from 2005 values. The 2015 interim year emissions were interpol ated based on the 2009 and 2018 LADCO modeling inventory, using LADCO’s growth factors, for all sectors. The 2020 interim year emissions and the 2022 maintenance year emissions were extrapolated from the 2018 LADCO modeling22 inventory.

Graphs 4.9, 4.10, and 4.11 visually compare 2005 (base year) and 2008 (secondary validation year) NO x , SO 2 and direct PM 2.5 county total estimated emissions with the 2015, 2020 and 2022 projected emissions for the Southwestern Indian a 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 the Indiana NO x rule. It should be noted that EGU emission estimates for 2015, 2020, and 2022 were projected using the Department of Energy Information’s Annual En ergy Outlook Supplemental tables for the year 2018. These tables were generated for the reference case of the Annual Energy Outlook 2007 (AEO 2007) using the National Energy Modeling Syst em. Graphs and data tables of emissions from the EGU source category can be found in Appendix D.

Graph 4.9 Comparison of 2005, 2008, 2015, 2020 and 2022 Projected NO x Emissions for the Southwestern Indiana Area (With CAIR)

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

2005 2008 2015 2020 2022TonsperYear

Year Nitrogen Oxides23 Graph 4.10 Comparison of 2005, 2008, 2015, 2020 and 2022 Projected SO 2 Emissions for the Southwestern Indiana Area (With CAIR)

Graph 4.11 Comparison of 2005, 2008, 2015, 2020 and 2022 Projected Direct PM 2.5 Emissions for the Southwestern Indiana Area (With CAIR) ‐ 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000

2005 2008 2015 2020 2022TonsperYear

Year Sulfur Dioxide

‐ 2,000 4,000 6,000 8,000 10,000 12,000 14,000 16,000

2005 2008 2015 2020 2022TonsperYear

Year Direct Fine Particulate Matter24 Graph 4.12 Comparison of 2005, 2008, 2015, 2020 and 2022 Projected SO 2 , NO x and Direct PM 2.5 Emission Trends for the Southwestern Indiana Area (With CAIR)

NO x emissions within the Southwestern Indiana Area are projected to decline by 48% between 2005 and 2022. Emission reduction benefits from U.S. EPA rules covering the NO x SIP Call, Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements, HeavyDuty Highway Engine Rule and the Nonroad Diesel Engine Rule are factored into the changes. Additionally, due to implementation of the NO x SIP Call across the eastern United States, NO x and fine particle levels entering the Southwestern Indiana Area will also be decreased. SO 2 emissions within the Southwestern Indiana Ar ea are projected to decline by 74% between 2005 and 2022. While an increase in direct PM 2.5 emissions in the Southwestern Indiana Area is noted, this increase in emissions from 2002 to 2005 is due to previously unreported emissions from companies that did not submit their direct PM 2.5 emissions data in 2002 but did submit direct PM 2.5 data in the 2005 emissions invent ory, from which the 2008, 2015, 2020 and 2022 data is extrapolated. The 2015, 2020 and 2022 emission projections assume no additional controls will be installed. This approach over-predicts future year emissions as it is reasonable to assume a significant number of facilities will need to install additional co ntrols to comply with CAIR and/or the proposed Transport Rule. The increase in direct PM 2.5 emissions in the Southwestern Indiana Area is outweighed by the significant regional reductions in NO x and SO 2 that have occurred and will continue to occur in the future. ‐ 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000

2005 2008 2015 2020 2022TonsperYear

Nitrogen Oxides Sulfur Dioxide Direct Fine Particulate Matter25 Table 4.1 Comparison of 2005 Estimated and 2022 Project ed Emission Estimates, Southwestern Indiana Area (Annual-Tons)

2005 2022 Change % Change
NO x 99,921.66 51,884.76 -48,036.90 48.07% decrease
SO 2 365,954.11 94,626.89 -271,327.22 74.14% decrease
Direct PM 2.5 10,159.65 12,604.06 2,444.41 24.06% increase

Table 4.2 Comparison of 2008 Estimated and 2022 Project ed Emission Estimates, Southwestern Indiana Area (Annual-Tons)

2008 2022 Change % Change
NO x 74,286.88 51,884.76 -22,402.12 30.16% decrease
SO 2 234,126.80 94,626.89 -139,499.91 59.58% decrease
Direct PM 2.5 13,045.38 12,604.06 -441.32 3.38% decrease

4.4 Demonstration of Maintenance

Quality-assured ambient air quality data from all the monitoring sites indicat e that air quality in the Southwestern Indiana Area met the annual N AAQS for fine particles for the three-year period ending in 2009. U.S. EPA’s Redesignati on Guidance (Page 9) 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 issions rates will not cau se a violation of the NAAQS.” Section 3.0 of this document shows that the Southwestern Indiana Area has in fact measured attainment for fine particles for the four consecutive pe riods ending in 2006, 2007, 2008 and 2009. Additionally, emissions projections outlined in Section 4.0 of this document clearly illustrate that regional NO x and SO 2 emissions in the area will continue to decline leading to local reductions betw een 2005 (base year) and 2022 (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 and 2017, as necessary, to comply with the inventory reporting requirements established in the CAA. Emissions information will be compared to the 2005 base year and the 2022 projected maintenance y ear inventories to asse ss emission trends, as necessary, to assure continued compliance w ith the annual standard for fine particles.26 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 and some were due to the applica tion of tighter federal standards on motor vehicles and fuels.

Section 6.0 identifies the emission control measures specific to the Southwestern Indiana Area, as well as the implementation 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. The 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 MOBILE SOURCE EMISSION BUDGETS

U.S. EPA requirements outlined in 40 CFR 93.118( e)(4) stipulate that mobile source emission budgets for direct PM 2.5 and NO x be established as part of a SIP. The mobile source emission budgets (MVEBs) are necessary to demonstrat e conformance of transportation plans and improvement programs with the SIP.

5.1 Onroad Emission Estimates

The Evansville Metropolitan Planning Organi zation (EMPO) is the Metropolitan Planning Organization (MPO) for the Evansville area. The EMPO study area contains approximately 650 square miles in Indiana, including the City of Evansville, Vanderburgh County, Warrick County and a very small area of eastern Posey C ounty. In Kentucky, the study area encompasses approximately 440 square miles which include s the City of Henders on and Henderson County. Additionally, the Indiana Department of Trans portation (INDOT) and the EMPO have executed an agreement for the EMPO to provide pl anning assistance in rural Gibson County.

The EMPO maintains a travel demand forecas ting model that was updated and improved in 2006. The model incorporates the road network of a five county area, which includes the Indiana counties of Vanderburgh, Warrick, Gibson a nd Posey, and Henderson County in Kentucky. Incorporated into the travel de mand model is a post-processor th at uses the U.S. EPA-required emissions estimation model MOBILE6.2 to calculate total emissions.

The EMPO travel demand model is used to simula te the traffic in the area and to predict what traffic would be in future years given growth exp ectations. The model is used mostly to identify where travel capacity will be needed and to de termine the infrastructure requirements necessary to meet that need. It is also used to support the calculation of mobile source emissions. The travel demand forecasting model is used to predic t the total daily vehicle miles traveled (VMT) and MOBILE6.2 is used to produce emission factor s to calculate the emissions per mile. The27 product of these two outputs, once combined, is the total amount of pollution emitted by onroad vehicles for the particular analyzed area. D ubois County, Ohio Township in Spencer County and Washington Township in Pike County are Indian a areas included in U.S. EPA’s nonattainment designations for fine particles th at do not fall under the jurisdiction of EMPO. In cases such as this, INDOT uses Highway Performance Monitori ng System (HMPS) baseline data to estimate and project mobile source emissions. This is a national program that requires state Departments of Transportation to collect traffic counts thr oughout the state on a regul ar basis under a certain regulated method. This HPMS data was colle cted and provided by INDOT and was used for these three areas beyond Evansv ille MPO’s jurisdiction.

5.2 Overview

Broadly described, MOBILE6.2 is used to genera te “emission factors,” which are the average emissions per mile (grams/mile) for direct PM 2.5 and PM 2.5 precursors, including NO x and SO 2
. There are numerous variables that can affect the emission factors. The ve hicle-fleet (vehicles on the road) age and the vehicle types have a major a ffect on the emission factors. The facility-type the vehicles are traveling on (M OBILE6.2 facility types are Freew ay, Arterial, Local and Ramp) and the vehicle speeds also affect the emission f actor values. Meteorological factors such as air temperature and humidity affect the emission factors, as does fuel type, such as low Reid Vapor Pressure gasoline. These data are estimated using the best available data to generate emission factors for direct PM 2.5 and PM 2.5 precursors, including NO x and SO 2 . After emission factors are generated, the emission factor(s) must be multiplied by the VMT to determine the quantity of vehicle-related emissions. This information de rives from the travel demand model (TDM).

It should be noted that each year analyzed will have different emission factors, volumes, speeds and likely some additional links such as roads. MOBILE6.2 input and ou tput files can all be found in Appendix F.

5.3 Analysis Years

The travel demand model contains road networks that are time specific. The EMPO has modeled the years 2002, 2010, 2015, 2025 and 2035. Informati on, including emissions, has also been interpolated from 2002 and 2010 for the year s 2005 and 2008 and from 2015 and 2025 for the years 2020 and 2022. This Redesignation Petition provides emissions inventory estimates for 2002, 2005, 2010, 2020 and 2022 to meet the requiremen ts specified by the CAA and the U.S. EPA. The emissions estimates outlined in S ection 4.0 of this document include the 2005, 2010, 2020 and 2022 mobile source emissions data referenced in Table 5.1.

5.4 Emission Estimations

Table 5.1 outlines predicted onroad emissions estima tes for the entire nonattainment area for the years 2005 (base year), 2008 (attainment yea r), 2015 (interim year), 2020 and 2022 (Horizon Year). The following emission estimates are based on the TDM network runs for the years 2005, 2008, 2015, 2020 and 2022.28 Table 5.1 Emission Estimations for Onroad Mobile Sources for the Southwestern Indiana PM 2.5 Nonattainment Area

2005 2008 2015 2020 2022
Direct PM 2.5 (tons/year) 117.67 91.59 54.33 50.48 48.93
NO x (tons/year) 6,528.04 5,018.06 2,503.19 1,929.38 1,699.86

5.5 Mobile Source Emission Budgets

Table 5.2 contains the MVEBs for the entire nonattainment area fo r the years 2015 and 2022.

Table 5.2 Mobile Source Emission Budgets for the Southwestern Indiana PM 2.5 Nonattainment Area

2015 2022 PM 2.5 (tons/year) 57.05 53.83 NO x (tons/year) 2,628.35 1,869.84

Consistent with the federal im plementation rule for fine part icles, IDEM does not consider mobile source SO 2 emissions to be a significant contri butor to fine particles for this nonattainment area, as SO 2 constitutes less than one percent (<1%) of the area’s total anthropogenic emissions for the years 2005, 2008, 2015, 2020 or 2022.

This document creates an interim year budge t for 2015 and a horizon year budget for 2022 for the Southwestern Indiana Area. These budgets are based on the 2005 onroad emission inventory used to support photochemical modeling for the sa me year, and has incorp orated an appropriate safety margin as described below.

In an effort to accommodate future variations in TDMs and VMT forecast when no change to the network is planned, IDEM consulted with the interagency consultati on group, including U.S. EPA Region V, to determine a reasonable approach to address this variation. The interagency consultation group approved a five (5%) safety margin for PM 2.5 and NO x mobile source emissions estimates for the year 2015 and a ten percent (10%) safety margin for PM 2.5 and NO x mobile source emissions es timates for the year 2022.

The safety margins are appropriate because: 1) there is an acknowledged potential variation in VMT forecast and potential estimated mobile sour ce emissions due to expected modifications to TDM and mobile emissions models; and 2) the total decrease in emissions from all sources is sufficient to accommodate the safety margin alloca tions detailed above to mobile sources while still continuing to maintain total emissions in the Southwestern Indiana nonattainment area well below the 2008 attainment level of emissions. Th ese safety margins were calculated by adding a straight-line percentage to the mobile source emission estimates for the years 2015 and 2022. Safety margin, as defined by the conformity rule, looks at the total emissions from all sources in29 the nonattainment area. The re sulting 2015 and 2022 MVEBs for PM 2.5 and NO x emissions remain well below the 2005 base year emissions referenced in Table 5.1.

In summary, the mobile budget safety margin allocation translates into:

 An allocation of 2.72 tons/year for PM 2.5 and 125.16 tons/year for NO x for 2015.

 An allocation of 4.90 tons/year for PM 2.5 and 169.98 tons/year for NO x for 2022.

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 the Southwestern Indiana Area as detailed in Table 4.1.

While IDEM believes that this is sufficient to support the requested increase, IDEM and its partners will be conducting additional air quality modeling which will include the adjusted mobile emissions, as well as any additional corr ections and modifications that may be necessary due to the constant review and evaluation of the model inputs.

5.6 Commitment to Amend Motor Vehi cle Emission Budgets Using MOVES

On March 2, 2010, U.S. EPA published a Notice of Availability for the Motor Vehicle Emission Simulator (MOVES) model. Indiana is committed to submitting a revision to the MOBILE6.2 developed MVEBs using the MOVES model as s oon as possible and well in advance of the March 2, 2012, expiration of the transportation c onformity “grace period.” IDEM recognizes that U.S. EPA will allow the MOBILE6.2 budgets to be replaced through an adequacy notice in place of a full publication to the Federal Register.

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 the Southwestern Indiana Area, including CAA requirements and additional state or local measures implemented 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 all30 new sources locating in Indiana si nce 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 the Southwestern Indiana Area attained the annual NAAQS for fine particles prior to an Attainment SIP or RACT SIP being due, and sin ce 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 area was designated nonattainment for the annual standard for fine particles in 2003 and the area 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 At tainment SIP or RACT SIP for this area under the annual NAAQS for fine particles.

6.3 Nitrogen Oxides (NO x ) 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. Indiana adopted this rule in 2001. Begi nning in 2004, this rule accounts for a reduction of approximately thirty-one percent (31%) of all NO x emissions statewide compared to previous uncontrolled 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 Graph 4.7 and Fi gures 4.1 and 4.2, it can be seen that emissions covered by this program have been genera lly trending downward si nce 1999. Table 6.1, compiled from data taken from the U.S. EPA Cl ean Air Markets Web site, quantifies the gradual NO x reductions that have occurred in Indiana as a result of Title IV (Acid Rain) of the CAA and the NO x SIP Call Rule. The NO x SIP Call cap stayed in place through 2008, at which time the caps in the CAIR program superseded it. Sin ce CAIR is a regional cap and trade program, it cannot be predicted at this time what effect this will have on EGU units located in the nonattainment area or other upwind counties. Further, U.S. EPA published Phase II of the NO x SIP Call that estab lishes 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 (May through October). The Indiana Phase II NO x SIP Call Rule became effective February 26, 2006 and implementation began in 2007.31 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 particles precurs or emissions have occurred, or are anticipated to occur, as a result of local and federal programs. These additional control measures include:

Tier 2 Vehicles Standards 8

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 beginni ng 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 Ti er 2 vehicle emissions standards.

Heavy-Duty Gasoline and Dies el Highway Vehicle Standards 9

New U.S. EPA standards designed to reduce NO x and VOC emissions from heavy-duty gasoline

8 http://www.epa.gov/fedrgstr/EPA-A IR/2000/February/Day-10/a19a.htm

9 http://www.epa.gov/fedrgstr/EPA-A IR/1997/October/Day-21/a27494.htm32 and diesel highway vehicles took effect in 2004. A second pha se of standards and testing procedures, that began in 2007, reduced PM 2.5 emissions from heavy-duty highway engines and also reduced highway diesel fuel sulfur content to 15 ppm since the sulfur can damage emissions 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. The U.S. EPA has not quantified the expected reductions.

Large Nonroad Diesel Engine Standards 10

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 Engines 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 vehicles (off-highway motorcycles and all-terra in vehicles) and recreational marine diesel engines. The regulation varies based upon the type of engine and vehicle.

The large spark-ignition engines co ntribute to ozone formation and ambient CO and PM levels in urban areas. Tier 1 of this standard was impl emented in 2004 and Tier 2 started in 2007. Like the large spark-ignition engines, recreational vehi cles contribute to ozone and fine particles formation and ambient CO and PM levels. Fo r Model Year 2006 off-highway motorcycles and all-terrain vehicles, at least 50% of a manufacturer’s fleet wa s required to meet the new exhaust emissions standard and 100% of the fleet wa s required to meet th e standards in 2007. Recreational marine diesel engines over 37 kilowatts are used in yachts, cruisers and other types of pleasure craft. 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.

10 http://www.epa.gov/fedrgstr/EPA-A IR/1998/October/Day-23/a24836.htm33 Reciprocating Internal Co mbustion Engine Standards 11

This new standard, effective in May 2010, regulat es air toxics emissions from existing diesel powered stationary reciprocating internal combustion engines that meet specific site 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 engines: (1) used at area sources of air toxics emissions and constructed or reconstructed before June 12, 2006; (2) used at major sources of air toxics emissions, having a site rating of less than or equal to 500 horsepower, and constructed or reconstructed before June 12, 2006; and, (3) used at major sources of air toxics for nonemergency purposes, having a site rating of gr eater 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 emissions test s to demonstrate engine performance and compliance with rule requirements; and, (3) burn u ltra-low sulfur fuel in station non-emergency engines with a site rating gr eater 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 VOCs by 27,000 tpy.

Category 3 Marine Diesel Engine Standards 12

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 reductions in other ways.

U.S. EPA is also adopting provisions to apply some emission and fuel standards to foreign-

11 http://www.epa.gov/ttn/atw/rice/fr03mr10.pdf 12 http://www.regulations.gov/ search/Regs/home.html#documen tDetail?R=0900006480ae43a634 flagged and in-use vessels that ar e covered by MARPOL Annex VI.

When this strategy is fully implemen ted in 2030, U.S. EPA estimates that NO x and PM 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, the U.S. EPA promulgated the “Rul e 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. This 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 their rules to meet federal requi rements. The purpose of CAIR was to reduce interstate transport of precursors of fine particles and ozone.

CAIR applied to: (1) any stationary, fossil fuel -fired boiler or stati onary, fossil fuel-fired combustion turbine, a generator with nameplate capacity of mo re than 25 megawatt electrical (MWe) producing electricity for sale; and (2) fo r a unit that qualifies as a cogeneration unit during the 12-month period starting on the date that the unit first produces electricity and continues to qualify as a cogene ration unit, a cogeneration unit se rving at any time a generator with a nameplate capacit y of more than 25 MWe and supplying in any calendar year more than one-third of the unit’s potent ial electric output capacity or 219,000 MWh (megawatt hours), whichever is greater to any utility power distri bution system for sale.

This rule provided 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. The U.S. EPA allows 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 an annual and seasonal NO x trading program and an annual SO 2 trading program. This rule requir ed 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 2008 and subsequent remand without vacatur of CAIR in December 2008 directs U.S. EP A to revise/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/replaced, the program cannot be defined as permanent and enforceable for SIP purposes. On July 6, 2010, U.S. EPA proposed the Clean Air Transport Rule to replace CAIR. The Transport Rule will result in even further benefits above and beyond CAIR than what is assumed within the emission inventories and modeling.35 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

Indiana commits to maintain the control measur es 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 the annual standard for fine particles in the Southwestern Indiana nonattainment area.

Indiana, through IDEM’s Office of Air Quality (OAQ) and its Compliance and Enforcement Branch, has the legal authority a nd necessary resources to actively enforce any violations of its rules or permit provisions. After redesignation, it intends to continue en forcing all rules that relate to the emission of fine pa rticles and fine particles precurs ors in the Southwestern Indiana Area.

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 at 326 IAC 2. The rule include s provisions for the Prevention of Significant Deterioration (PSD) permitting program in 326 IAC 2-2. 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 facility that is not listed in the 2005 emission inventory, or for which credit through the shutdown or curtailment was taken in demonstrating attainment, will not be allowed to construct, reopen, modify, or reconstruct without meeting a ll 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, wh ich requires an air quality analysis to evaluate whether the new sour ce will threaten the NAAQS.

7.0 MODELING AND METEOROLOGY

Although U.S. EPA’s Redesignation Guidance do es not require modeling for nonattainment areas seeking redesignation, exte nsive modeling has been performed covering the Southwestern Indiana region to determine the e ffect of national emission contro l strategies on fine particle levels. These modeling analyses determined that the Southwestern Indiana Area, including Vanderburgh, Warrick, and Dubois counties and Montgomery Township in Gibson County, Ohio Township in Spencer County and Washington To wnship in Pike County, is significantly impacted by regional transport of fine partic les and its precursors, and that regional SO 2 and NO x reductions are an effective way to attain the annual standard for fine particle s 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 m odeling analyses are desc ribed in this section.36 7.1 Summary of Modeling Results to Support Rulemakings

U.S. EPA Modeling for Transport Rule 2010 13

U.S. EPA performed modeling to support the emission reductions associated with the Proposed Transport Rule. U.S. EPA used the Comprehe nsive Air Quality Model with Extension (CAMx Version 5), applied to the 2005 meteorology, as processed by the Mesoscale Model (MM5), Version 3.7.4. Emissions i nput into CAMx included SO 2 , NO x , VOCs, NH 3 and direct PM 2.5 for 2005. The modeling was based on the annual fine particle design values calculated from 2003 through 2005, 2004 through 2006, and 2005 through 2007. Future year modeling was conducted, which included the Southwestern Indiana 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 con centrations are accounted for by modeling both the base future year emissions and then the em ission reductions associat ed with the 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.

Table 7.1 Transport Rule Modeling Re sults from U.S. EPA – 2010

County Monitor ID Design Value 2003-2007

(μg/m 3 ) Future Design Value 2012 Base

(μg/m 3 ) Future Design Value 2014 Base

(μg/m 3 ) Vanderburgh Co. 18-163-0006 14.69 14.55 14.02 Vanderburgh Co. 18-163-0012 14.82 14.64 14.09 Vanderburgh Co. 18-163-0016 14.99 14.84 14.30 Dubois Co. 18-037-2001 15.18 15.07 14.50

Knox Co. 18-083-0004 14.03 13.94 13.33 Spencer Co. 18-147-0009 14.32 14.21 13.65 Daviess Co. – KY 21-059-0005 14.10 14.14 13.59

Modeling results show that the base future year modeling with emi ssion reductions from the Transport Rule accounts for 0.1 to 0.2 μg/m 3 decreases in concentrations for 2012 and 0.5 to 0.7 μg/m 3 decreases in concentrations for 2014 in the Southwestern Indiana Area.

While results of U.S.EPA’s Transport Rule m odeling show modeled con centrations above the standard using base case emissions at the Dubois Co. PM 2.5 monitoring site, it should be noted that the base year design value used by U.S. EPA was taken from 2003 through 2007 and is higher than current 2005 through 200 9 design values in the area. Graph 7.1 shows the downward trend of the design values from 2000 through 2009 for the PM 2.5 monitors in the Southwestern Indiana Area. The resulting decrease of th e 2003 through 2007 design value to the 2005 through 2009 design value at the Dubois Co. PM 2.5 monitor is 1.3 μg/m 3 with all the area’s PM 2.5

13 http://www.epa.gov/airquality/tran sport/pdfs/TR_AQModeling_TSD.pdf37 monitors design values decreasing from 0.9 μg/m 3 to 1.3 μg/m 3 . Therefore, U.S.EPA’s Transport Rule modeling, using current 2005 through 2009 design values , shows all modeled concentrations below the annual fi ne particles standard of 15.0 μg/m 3

. Graph 7.1 PM 2.5 Design Value Trends for the Southwestern Indiana Area - 2000 through 2009

Results of the U.S. Transport Rule modeling sh ow that all Southweste rn Indiana counties will attain the annual fine particle NAAQS in 2012 with modeled impacts reduced by 1% to 2%, and remain below 15 μg/m 3 . With further reductions projecte d in the U.S. Transport Rule for 2014, all design values decrease by 4% to 5% and c ontinue 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 , NOx, 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 s hown in Table 7.2. The U.S. Transport Rule is expected to provide reduc tions above and beyond CAIR. 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

‐ 09Concentrations(ug/m3)

Design Value Year

Civic Center W. Mill Rd. U of Evansville Spencer Co.

Dubois Co. Knox Co. Annual Standard38 Table 7.2 LADCO’s Round 6 Modeling Results (Without the Clean Air Intersta te Rule emission reductions)

Monitor ID Monitor Name County Design Value 2003-2007

(μg/m 3 ) Base-case 2012 (μg/m 3 ) Base-case 2018 (μg/m 3 ) 18-163-0006 Civic Center Vanderburgh 14.7 13.9 13.7 18-163-0012 W. Mill Rd. Vanderburgh 14.8 13.9 13.6 18-163-0016 Univ. of Evansville Vanderburgh 15.0 14.2 14.0 18-147-0009 Dale Spencer 14.3 13.2 13.0 18-037-2001 Jasper Post Office Dubois 15.2 14.0 13.8 18-037-0004 Sports Complex Dubois 13.9 12.8 12.6 18-037-0005 Jasper Golf Course Dubois 14.0 12.9 12.8 18-083-0004 SW Purdue Ag. Knox 14.0 13.1 12.9 21-059-0005 Owensboro Daviess - KY 14.4 13.8 13.6 21-059-0014 Wesleyan College Daviess - KY 13.0 12.6 12.5

Results of the LADCO Round 6 modeling show th at all Southwestern Indiana counties will attain the annual NAAQS for fine particles by 2012. As shown in Table 7.2, future year modeled annual fine particle concentratio ns for 2012 will be 3% to 8% lower than baseline annual fine particle design values and 4% to 9% lower in 2018 and will continue to decrease thereafter.39 Graph 7.2 Modeling Results for Southwestern Indiana PM 2.5 Monitors - 2009, 2012, and 2018

7.2 LADCO’s Round 5 Speciated M odeled 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 passively collected mass. The SMAT results from LADCO’s Round 5 modeling are listed below. Percent ranges of the model results from the six fine particle monitors in Southwestern Indiana were broken do wn into these speciated constituents of fine particles emissions. The percent decrease from th e observed speciated data in 2005 to the future year modeled results for 2009 are listed in Table 7.3.40 Table 7.3 LADCO’s Round 5 SMAT Modeling Results for Southwestern Indiana (Percent decrease from observed to modeled concentrations)

Species of PM 2.5 2009 Sulfates 24% - 29% Nitrates 0% - 8% Organic Carbon 0% - 4% Elemental Carbon 0% - 20% Ammonium 16% - 26% Particle Bound Water 19% - 31%

The results show that sulfate, ammonium, and particle bound water concentration decreases are projected to occur by at least 16% in 2009. Lesser nitrate reductions are projected to occur, up to 8%, with organic carbon reductions occurr ing up to 4%. LADCO modeling shows good performance for sulfates and elemental carbon predicted baseline concen trations, slight overprediction for nitrate concentra tions and under-predictions of organic carbon concentrations. Overall, model performance is adequate for SIP planning and gives a good idea of the effects of emissions reductions from national emission control measures on the Southwes tern Indiana Area.

7.3 LADCO’s Round 5 Particulate Source Apportionment Results

Particulate Source Apportionment (PSAT) modeli ng was conducted by LADCO. The results of the PSAT Round 5 modeling shows the regional contributions by emission sectors on each monitor that was modeled. Chart 7.1 shows th e PSAT modeling results for the Jasper, Dubois County fine particles monitor; Civic Center, West Mill Road and University of Evansville fine particles monitors in Vanderburgh County; Dale, Spencer County fine particles monitor; and the Knox County fine particles monitor. Indiana was the biggest regional cont ributor to the Jasper, West Mill Road and the Dale fine particle monitors. Kentucky was the biggest regional contributor to the Civic Center a nd University of Evansville fine particle monitors. Illinois was the biggest regional contributor to the Knox County fine partic les monitor. The PSAT Round 5 modeling results show the majority of Indiana’s emission sector contributi ons to fine particle concentrations come from EGUs, ammonium emission sources, off-road (including marine, aircraft, and railroad) and non-EGU sources. These results are consid ered to be representative of the entire Southwestern Indiana Area as EGU, ammonium and non-EGU emissions impact the entire area.41 Chart 7.1 Regional/Emission Sector PSAT Results

Jasper, Dubois Co. Civic Center, Evansville

West Mill Road, Evansville University of Evansville

Dale, Spencer Co. Knox Co.42 The following pie charts depict the species contribu tions to fine particle concentrations at the Southwestern Indiana monitors. The pie charts include both the observe d 2005 contributions and 2009 modeled contributions for each monitor. Sin ce the monitors are in close proximity of each other, results are fairly similar in the distribut ion of species concentra tions among the monitors. Charts 7.2 and 7.3 cover the fine particle monito rs in the Southwestern Indiana Area with the highest monitored concentrations that are used to determine compliance with the annual NAAQS for fine particles.

Chart 7.2 Pie Charts - Species Modeled Contri butions to Jasper, Dubois Co. PM 2.5 Monitor (Observed Concentrations = 14.8 μg/m 3 ) (Modeled Concentrations =14.0 μg/m 3 )

Chart 7.3 Pie Charts - Species Modeled Contribut ions to University of Evansville PM 2.5 Monitor (Observed Concentrations = 15.4 μg/m 3 ) (Modeled Concentrations =14.1 μg/m 3 )

Results of the Round 5 PSAT modeli ng for Southwestern Indiana fine particle monitors show the highest pollutant contributors to base-case and future year fine particle concentrations are sulfate, organic carbon, ammonium and nitrate. Future y ear modeling shows decreases in sulfates (due to the emission reductions from CAIR) and amm onium. The future year modeling did show slight increases in organic carbon and nitrates from the base-case modeled concentrations. Observed 2005 Contributions at Jasper PM2.5 Monitor

so4 36%

no3 9% oc 21% ec 3% soil 2% nh4 14% pbw 12% blan 3%

so4

no3

oc

ec
soil

nh4 pbw

blan 2009 Modeled Contributions at Jasper PM2.5 Monitor

so4 31%

no3 10%

oc 25% ec 3% soil 3% nh4 14% pbw 10% blan 4%

so4

no3

oc

ec
soil

nh4 pbw
blan

Observed 2005 Contributions at University of Evansville PM2.5 Monitor

so4 32%

no3 11%

oc 23% ec 4% soil 3%

nh4 14% pbw 10% blan 3%

so4

no3

oc

ec
soil

nh4 pbw

blan 2009 Modeled Contributions at University of Evansville PM2.5 Monitor

so4 27%

no3 12%

oc 26% ec 4% soil 4%

nh4 13% pbw 10% blan 4%

so4

no3

oc

ec
soil

nh4 pbw

blan43 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 the Southwestern Indiana counties 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 the Southwestern Indian a counties 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 contro l strategies showed the Southwestern Indiana counties will attain the annual NAAQS for fine particles without addi tional national emission controls. Future national and local emission contro l strategies will ensure that the Southwestern Indiana fine particle nonattainment area will maintain lower fi ne particle concen trations with an increasing margin of safety.

7.5 Meteorological Analysis for Southwestern 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 particles readings in the Southwestern Indiana Area.

7.6 Surface Air Conditions Present during Hi gh Fine Particles Concentrations Days

Higher concentrations of fine particles tend to correlate with warmer te mperatures and lighter wind speeds, although high fine particle episodes can occur in the summer or winter. It should be noted that higher annual fine particle concen trations are driven by in dividual days with higher fine particle concentrations throughout the monitored year. Therefore, it is difficult to attribute higher fine particle concentrati ons to annualized meteorological ra nkings. Review of several of the higher fine particle concentration episodes over the past few years show 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 pa rticles concentrations had near normal temperatures but wind speeds were very light.

7.7 Upper Air Conditions Present during Hi gh Fine Particles Concentrations 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 and are evident in elevated fine particles episodes in spring, summer, fall and wint er 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.44 7.8 Analyses of Atmospheric Conditions dur ing High Fine Particles Concentration Days

Analyses have been conducted to determine the atmospheric conditions that are most prevalent during higher fine particle concentration days in Indiana. LADCO applied a Classification and Regression Tree (CART) analysis to data from Indiana that correla ted different levels of fine particle concentrations to meteorological conditi ons from 1999 through 2004. (Donna Kenski, 2005). This type of analysis looks at the me teorological conditions, such as temperature, pressure, wind speed, wind direction, relative hu midity and dew point 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 particle concentrations in Indiana were warm-weather condit ions with high dew points, southwest winds and high evening 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 particulate constituents vary, w ith nitrates being more prevalent in the winter and sulfates more prevalent in the summer. Sulfate and nitrate emission reductions have the biggest impact on lower future year fine particle concentrations.

An analysis was conducted to review the daily fine particle concentrations over a year to determine the Air Quality Index (AQI) trends . Chart 7.4 below shows by year (2001 through 2009), the percentage number of days during which fine particle concentrations 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 during which fine particle levels reached the “Unhealthy” level of 65.5 μg/m 3 to 150.4 μg/m 3

.

Chart 7.4 Distribution of PM 2.5 Concentration Days on the AQ I Levels of Health Concern45 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 9-year period analyzed (2001 through 2009). The year 2005 had the most “Moderate” concentration days and the years 2002, 2005 and 2006 had the most “Unhealthy for Sensitive Group (USG)” concen tration days with no USG days recorded in 2004, 2007, 2008 and 2009.

Table 7.4 Ranking of Highest Number of Days at AQI Levels of Health Concern

Ranking Good Moderate Unhealthy for Sensitive Group 1 st 2009 – 76% 2005 – 44% 2002 – 2% 2 nd 2008 – 70% 2001 – 43% 2005 – 2% 3 rd 2004 – 67% 2007 – 37% 2006 – 1% 4 th 2006 – 65% 2003 – 36% 2001 – 1% 5 th 2003 – 63% 2002 – 35% 2003 – 1% 6 th 2007 – 63% 2006 – 34% 7 th 2002 – 63% 2004 – 33% 8 th 2001 – 56% 2008 – 30% 9 th 2005 – 54% 2009 – 24%

7.9 Summary of Meteorological Anal ysis for Southwestern Indiana

Annual fine particle concentrations in the Sout hwestern Indiana Area 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 80 o F 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 sensit ive group levels of air quality. Upper air w eather patterns generally include ridging over the area with stag nant conditions at the surface. Surface winds from any direction can transport pollutants from surrounding areas into th e Southwestern Indiana Area. Nitrates are bigger contribut ors to fine particle concentrati ons in the winter and sulfates are bigger 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.46 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 im plement necessary corrective action in the following circumstance:

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 prompted the Action Level.

Control Measure Select ion and Implementation

Adoption of any additional control measures is subject to the necessary administrative and legal processes. This process will in clude publication of notices, an opportunity for public hearing and other measures required by Indiana law for 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 in this section are example measures that may be considered. The selection 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 is not comprehensive. IDEM anticipates that if contingency measures47 should ever be necessary, it is unlikely that a si gnificant number (i.e., all those listed below) will be required.

1) Alternative fuel and diesel retrofit programs for fleet vehicle operations. 2) Require NO x or SO 2 emission offsets for new and modified major sources. 3) Require NO x or SO 2 emission offsets for new a nd modified minor sources. 4) Increase the ratio of emission of fsets required for new sources. 5) Require NO x or SO 2 controls on new minor sour ces (less than 100 tons). 6) Wood stove change-out program. 7) Require increased recovery effici ency at sulfur recovery plants. 8) Various emissions reduction measures or dus t suppressant for unpaved roads and/or parking lots. 9) Idling Restrictions. 10) Broader geographic applicab ility of existing measures. 11) One or more transportation co ntrol measures sufficient to achi eve at least a half a percent (0.5%) reduction in actual area-wide precursor emissions. 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, including, 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 measur es not yet in widespread use that affect state and local governments, as deemed 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

This section will be finalized upon completion of the public heari ng and public comment period.

10.0 CONCLUSIONS

The Southwestern Indiana Area ha s attained the annual NAAQS for fi ne particles. This petition demonstrates that the Southwestern Indiana Area has complied with the a pplicable provisions of the CAA regarding redesignation of nonattainment area s for fine particles. IDEM has prepared a State Implementation and Maintenance 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 reductions48 following implementation of the Phase II NO x SIP Call and CAIR and/or its replacement rule or program will ensure continued compliance (maint enance) with the standard. Furthermore, emission projections indicate that NO x and SO 2 emissions will continue to decline, thus ensuring that the area continues to maintain compliance with the standard and provide for an increasing margin of safety. Based on this presentation, th e Southwestern Indiana nonattainment area for fine particles meets the requirements for rede signation under the CAA (Section 107(d)(3)) and U.S. EPA guidance for fine particles.

Consistent with the authority granted to the U. S. EPA, the State of Indiana requests that the Southwestern Indiana nonattainment area for fine pa rticles be redesignated to attainment for the annual fine particles standard simultaneously with U.S. EPA approval of this Indiana State Implementation and Maintenance Plan and the provisions contained herein.