Mary Gade Regional Administrator 

U.S. EPA, Region 5 

77 West Jackson Boulevard 

Chicago, Illinois 60604 

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Re: Indiana Infrastructure (Section 110(a)(l) and (2)) 

State Implementation Plan Submittal 

Dear Ms. Gade: 

I am writing to confirm that the State of Indiana continues to retain the resources 

necessary to evaluate ambient air quality, develop plans to attain new and existing ambient air 

quality standards, run a complete new source review program, and effectively enforce all 

applicable requirements. Specifically, the Indiana Department of Environmental Management (IDEM) can implement and satisfactorily complete the Section 110 requirements listed below. 

We satisfy these requirements for the current and any prospective future air quality standards, 

including any current and future air quality standards for ozone and for various sizes of 

particulate matter. 

The SIP elements listed below are required under section 110(a)(l) and (2). Section 

1 10(a)(l) provides the procedural and timing requirements for SIPs. Section 1 10(a)(2) lists the 

basic or "infrastructure" elements that all SIPs must contain. Following each element is IDEM'S 

discussion as to the department's ability to fulfill the requirement. 

Section 1 10 (a)(2) elements 

Emission limits and other control measures: Section 110(a)(2)(A) requires SIPs to include 

enforceable emission limits and other control measures, means or techniques, schedules for 

compliance and other related matters. EPA notes that the specific nonattainment area plan 

requirements of section 1 1 O(a)(2)(1) are subject to the timing requirement of section 172, not the timing requirement of section 110(a)(l), and also that SIPs to meet this section are not covered 

by the Consent Decree. 

IDEM continues to update and implement needed revisions to Indiana's SIP as 

necessary to meet ambient air quality standards. Authority to adopt emissions 

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are used to determine compliance with the U.S EPA's NAAQS. Indiana's 2008 

Ambient Air Monitoring Annual Network Plan documents the framework for 

establishment and maintenance of Indiana's air quality surveillance system and lists 

any changes that are proposed to take place to the current network during the 2008 

season. 

Program for enforcement of control measures: Section 110(a)(2)(C) requires States to 

include a program providing for enforcement of all SIP measures and the regulation of 

construction of new and modified stationary sources to meet prevention of significant 

deterioration (PSD) and nonattainment NSR requirements. 

IDEM maintains an enforcement program to ensure compliance with SIP 

requirements. Indiana Code 13-14-1-12 provides the commissioner with the 

authority to enforce rules 'cconsistent with the purposes of the air pollution control 

laws" The commissioner also has the authority, under IC 13-14-2-7 and IC 13-17-3- 

3, to assess civil penalties and obtain compliance with any applicable rule a board has adopted in order to enforce air pollution control laws. Additionally, IC 13-14- 

10-2 allows for an emergency restraining order that will prevent "any person 

causing or contributing to the alleged pollution to stop the ... introduction of 

contaminants causing or contributing to the pollution." 

Interstate transport: Section 1 10(a)(2)(D) requires SIPs to include provisions prohibiting any 

source or other type of emissions activity in one State from contributing significantly to 

nonattainment, or interfering with maintenance, or the NAAQS in another State, or fiom 

interfering with measures required to prevent significant deterioration of air quality or to protect 

visibility in another State. EPA has already issued CAIR to assist States in developing SIPs to meet this requirement for purposes of the 8-hour Ozone and PM2.5 NAAQS, and has issued 

separate guidance to all States on how to comply with each prong of this statutory provision. 

IDEM has adopted and implemented the various major programs related to the 

interstate transport of pollution. Indiana Administrative Code (IAC) 326 IAC 1-7 

(Stack Height Provisions), 326 IAC 21-1 (Acid Deposition Control), 326 IAC 10-4 (Nitrogen Oxides Budget Trading Program), 326 IAC 24-1,326 IAC 24-2,326 IAC 

24-3 (Clean Air Interstate Rule), and 326 IAC 24-4 (Clean Air Mercury Rule, final 

adopted on October 3,2007, expected to be effective by the end of January 2008) all 

address Congressional and U.S. EPA concerns over the transport of emissions of 

regulated pollutants beyond our state borders. 
system to monitor emissions from stationary sources and to submit periodic emissions reports. 

Indiana's rules for monitoring requirements contained in 326 IAC 3 include rules that specify the continuous monitoring of emissions, minimum performance and 

operating specifications, quality assurance requirements, record keeping 

requirements, source sampling procedure, and fuel sampling and analysis 

'procedures. Additional emission reporting requirements are found in 326 IAC 2-6. 

Currently, the rules at 326 IAC 3 are being updated by the state rulewriters and 

once the rulemaking process is complete, the revised rules will be submitted to the 

U.S. EPA for SIP approval. 

Emergency power: Section 11 O(a)(Z)(G) requires States to provide for authority to address 

activities causing imminent and substantial endangerment to public health, including 

contingency plans to implement the emergency episode provisions in their SIPs. 

326 IAC 1-5, (Episode Alert Levels) establishes air pollution episode levels based on 

concentrations, of criteria pollutants. The rule requires that emergency reduction 

plans (ERP) be submitted to the commissioner by applicable major air pollution 

sources. The ERP's shall state those actions that will be taken when each episode levels is declared, to reduce or eliminate emissions of the appropriate air pollutants. 

Indiana wil1,revise the particulate matter SIP when the U.S. EPA promulgates 

revisions to 40 CFR Part 51, Subpart H-Prevention of Air Pollution Emergency 

Episodes which address priority classifications and significant harm level for 

Future SIP revisions: Section 110(a)(2)(H) requires States to have the authority to revise their 

SIPs in response to changes in the NAAQS, availability of improved methods for attaining the 

NAAQS, or in response to an EPA finding that the SIP is substantially inadequate. 

IDEM continues to update and implement needed revisions to Indiana's SIP as 

necessary to meet ambient air quality standards. Authority to adopt emissions 

standards and compliance schedules is found at Indiana Code (IC) 13-14-8, IC 13- 

17-3-4, IC 13-17-3-1 1, IC 13-17-3-14. 

Consultation with government officials: Section 1 lO(a)(2)(J) requires States to provide a 

process for consultation with local governments and Federal Land Managers carrying out 

NAAQS implementation requirements pursuant to section 12 1 relating to consultation. 
IDEM monitors air quality daily and when necessary reports the daily air quality 

index to the interested public and media. IDEM participates and submits 

information to U.S. EPA's AIRNOW program. Additionally, IDEM maintains 

SmogWatch which is an informational tool created by IDEM to share air quality 

forecasts for each day. SmogWatch provides daily information about ground-level ozone, particulate matter concentration levels, health information, and monitoring data for seven regions in Indiana. 

PSD and visibility protection: Section 1 10(a)(2)(J) also requires States to meet applicable 

requirements of Part C related to prevention of significant deterioration and visibility protection. 

Indiana's SIP approved prevention of significant deterioration (PSD) rules are 

found in 326 IAC 2-2. Early next year, 2008, IDEM will be submitting the regional 

haze/ BART SIP to the U.S. EPA which addresses Indiana's contribution to 

visibility issues in Class 1 areas. 

Air quality modeling data: Section 1 1 O(a)(2)(K) requires that SIPs provide for performing air 

quality modeling for predicting effects on air quality of emissions from any NAAQS pollutant 

and submission of such data to EPA upon request. 

IDEM reviews the potential impact of major and some minor new sources. 

Indiana's rules regarding air quality modeling are contained in 326 IAC 2-2-4,326 

IAC 2-2-5,326 IAC 2-2-6, and 326 IAC 2-2-7. Modeling data are available upon 

request by the U.S. EPA or other interested parties. 

Permitting fees: Section 1 10(a)(2)(L) requires SIPs to require each major stationary source to 

pay permitting fees to cover the cost of reviewing, approving, implementing, and enforcing a 

permit. 

IDEM continues to implement the approved Title V program, including requiring 

major sources to pay permit fees. The authority to establish Title V permit fees are 

found at Indiana Code (IC) 13-17-8. The fees for Title V are found at 326 IAC 2-7- 

19. Additional fees that may apply to Title V sources are found at 326 IAC 2-1.1-7. 

Fees for FESOPs are found at 326 IAC 2-8-16 and 326 IAC 2-8-18. IDEM is 

currently reorganizing their rule structure so these citations are expected to change 

once the work is completed. 
I believe that the IDEM meets or exceeds all of the necessary infrastructure needs, 

enabling us to continue to satisfy these requirements of the Clean Air Act. If you have any 

questions, please feel free to contact Mr. Scott Deloney, Chief, Air Programs Branch at (3 17) 

233-5684. 

Assistant 

Office of Air Qu 

cc: Scott Deloney 

John Mooney 

Steve Rosenthal 

Rules SIP file 

Commissioner SIP file