# Fine Particle Attainment Demonstration and Technical Support Document



# For the Indiana Portion of the

Cincinnati – Hamilton, OH-KY-IN

Fine Particle Nonattainment Area Lawrenceburg Township, Dearborn County Indiana

Prepared By: Indiana Department of Environmental Management Office of Air Quality

June 2008This page intentionally left blanki 

### TABLE OF CONTENTS

1.0 OVERVIEW.................................................................................................................. ........1

1.1 INTRODUCTION .............................................................................................................. ....1 1.2 NATIONAL AMBINET AIR QUALITY STANDARDS .....................................................1 1.3 GEOGRAPHICAL DESCRIPTION.......................................................................................4 1.4 CONTROL STRATEGY........................................................................................................6 1.5 ATTAINMENT TEST........................................................................................................... .6

2.0 CLEAN AIR ACT REQUIREMENTS...............................................................................8

2.1 GENERAL REQUIREMENTS ..............................................................................................8 2.1.1 Reasonably Available Control Measures (RACM) .......................................................8 2.1.2 Reasonably Available Control Technology (RACT).....................................................9 2.2 REASONABLE FURT HER PROGRESS..............................................................................9 2.3 EMISSIONS INVENTORIES................................................................................................9 2.4 IDENTIFICATION AND QUANTIF ICATION OF EMISSIONS......................................10 2.5 PERMIT PROGRAM FOR NEW AND MODIFIED MAJOR SOURCES.........................10 2.6 OTHER CONTROL MEASUR ES, MEANS OR TECHNIQUES ......................................10 2.7 COMPLIANCE WITH SECTION 110(A)(2) ......................................................................11 2.8 EQUIVALENT TECHNIQUES...........................................................................................11 2.9 CONTINGENCY MEASURES ...........................................................................................11 2.10 ATTAINMENT DEMONSTRATION.................................................................................11 2.10.1 Photochemical Grid Modeling Analysis...................................................................12 2.10.2 Air Quality Trends Analysis .....................................................................................12 2.10.3 Emissions Trends Analysis.......................................................................................14 2.11 CONTROL STRATEGY......................................................................................................14 2.12 MOBILE SOURCE EMISSIONS BUDGET .......................................................................14

3.0 TECHNICAL ELEMENTS OF DEMONSTRATION ...................................................15

3.1 PHOTOCHEMICAL MODELING ANALYSIS .................................................................15 3.1.1 Modeling Methodology ...............................................................................................16 3.1.2 Modeling Preparation and Objectives..........................................................................16 3.1.3 Meteorology Selection.................................................................................................1 7 3.1.4 Modeling Domain ........................................................................................................ 17 3.1.5 Selection of Base Year................................................................................................. 19 3.1.6 Selection of Future Years ............................................................................................19 3.1.7 Emissions Inputs ....................................................................................................... ...19 3.1.8 Model Performance...................................................................................................... 20 3.2 MODELED ATTAINMENT TEST .....................................................................................21 3.3 ATTAINMENT TEST RESULTS .......................................................................................23 3.4 UNMONITORED AREA ANALYSIS ................................................................................26ii 4.0 AIR QUAL ITY TR ENDS ..................................................................................................30

5.0 EMISSIONS TRENDS ANALYSIS..................................................................................34

6.0 CONTROL STRATEGY ...................................................................................................43

6.1 MODELED CONT ROL MEASURES.................................................................................43 6.1.1 Heavy-Duty Gasoline and Diesel Highway Vehicle Standards...................................43 6.1.2 Large Non-Road Diesel Engine Standards ..................................................................44 6.1.3 Non-Road Spark-Ignition Engines and Recreational Engine Standards .....................44 6.1.4 NO x SIP Call................................................................................................................44 6.1.5 Clean Air Interstate Rule (CAIR) ................................................................................45 6.2 ADDITIONAL CONT ROL MEASURES............................................................................45 6.2.1 Federal Controls....................................................................................................... ....45 6.2.2 Indiana Statewide Controls..........................................................................................46 6.2.3 Kentucky Statewide Controls ......................................................................................47 6.2.4 Ohio Statewide Controls..............................................................................................48

7.0 WEIGHT OF EVIDENCE ANALYSIS............................................................................50

7.1 LADCO’S R OUND 5 MODELING.....................................................................................50 7.2 LADCO’S ROUND 5 SPECIATED MODELED ATTAINMENT TEST RESULTS........52 7.3 LADCO’S ROUND 5 PARTICULATE SOURCE APPORTIONMENT RESULTS.........53 7.4 DAILY MONITORED DATA COMPARISON FOR CINCINNATI PM 2.5 MONITORING SITES....................................................................................................................................55 7.5 SUMMARY OF ASSOCIATION FOR SOUTHEASTERN INTEGRATED PLANNING (ASIP) MODELING FOR KENTUCKY .............................................................................56 7.6 SUMMARY OF ATTAINMENT TEST MODELING RESULTS .....................................58

8.0 MOBILE SOURCE EMISSIONS BUDGET ...................................................................59

8.1 ON-ROAD EMISSIONS ESTIMATIONS ..........................................................................59 8.2 OVERVIEW .................................................................................................................. .......59 8.3 EMISSIONS ESTIMATIONS..............................................................................................59

9.0 CONTINGENCY MEASURES.........................................................................................61

10.0 PUBLIC PARTICIPATION ..............................................................................................62

11.0 CONCLUSION ............................................................................................................... ....62iii FIGURES

Figure 1.1 U.S. EPA Fine Particle Nonattainment Area Designations............................................5 Figure 3.1 LADCO Meteorological a nd Emissions Modeling Domain ........................................18 Figure 3.2 Model Performance Metrics for Annual PM 2.5 Modeling............................................21 Figure 3.3 Spatial Representation for the Cincinnati Area PM 2.5 Monitoring Sites......................27 Figure 4.1 Controlling Monitor Design Values.............................................................................31 Figure 4.2 Three-Year Fine Particle Design Values......................................................................32 Figure 4.3 Annual PM 2.5 Vales for the Cincinnati Area................................................................33 Figure 5.1 Regional NO x Reductions 2005 - 2010 ........................................................................41 Figure 5.2 Regional SO 2 Reductions 2005 - 2010.........................................................................42 Figure 7.1 Graph of Modeling Results for the Cincinnati Area PM 2.5 Monitors for 2009, 2012 and 2018.........................................................................................................................................52 Figure 7.2 Daily Monitoring Data Comparison for the Cincinnati Area PM 2.5 Monitors.............56

TABLES

Table 1.1 National Ambient Air Quality Standards for Fine Particles............................................1 Table 1.2 Cincinnati Area 2001-2003 Air Quality Monitoring Data used for Designation ............3 Table 1.3 Attainment Test Results.............................................................................................. .....7 Table 3.1 Observed Quarterly Mean PM 2.5 /Quarterly Mean Composition, Murray Rd., Hamilton County, Monitor.............................................................................................................................23 Table 3.2 Quarterly Mean Composition for each Component of PM 2.5 , Murray Rd., Hamilton County, Monitor.............................................................................................................................24 Table 3.3 Relative Response Factors (RRFs) for each Component, Murray Rd., Hamilton County, Ohio, Monitor...................................................................................................................24 Table 3.4 Projected Quarterly Species Estimates, Murray Rd., Hamilton County, Monitor. .......25 Table 3.5 Attainment Test Results for the Cincinnati Area...........................................................25 Table 3.6 Annual Design Values for Cincinnati Nonattainment Area from 2000 - 2006 .............28 Table 3.7 Modeling Results for PM 2.5 Monitors located in or near the Cincinnati Fine Particle Nonattainment Area for 2009, 2012 and 2018...............................................................................30 Table 4.1 Cincinnati Nonattainment Area’s Annual Fine Particle Design Values........................30 Table 5.1 NO x Emissions Inventories (tons per year) Entire Nonattainment Area .......................36 Table 5.2 SO 2 Emissions Inventories (tons per year) Entire Nonattainment Area ........................37 Table 5.3 PM 2.5 Emissions Inventories (tons per year) Entire Nonattainment Area .....................37 Table 5.4 Statewide Annual NO x and SO 2 EGU Budgets .............................................................40 Table 7.1 LADCO’s Round 5 Modeling Results for the Clean Air Interstate Rule (CAIR).........51 Table 7.2 LADCO’s Round 5 SMAT Modeling Results for the Cincinnati Area (Percent change from 2005 observed to 2009 modeled concentration) ...................................................................53 Table 7.3 ASIP’s Base G4 Annual PM 2.5 Modeling Results .........................................................57 Table 8.1 Emissions Estimations for On-Road Mobile Sources ...................................................60 Table 8.2 Mobile Vehicle Emissions Budget ................................................................................60iv CHARTS Chart 2.1 Fine Particle Design Value Trends ................................................................................13 Chart 2.2 Fine Particle Design Values for the Cincinnati Nonattainment Area............................13 Chart 3.1 Annual PM 2.5 Values for the Cincinnati Nonattainment Area .......................................29 Chart 4.1 Historical Design Values for the Cincinnati Nonattainment Area from 2001 - 2006 ...31 Chart 5.1 Emissions Trends – All Anthropogenic Sources, 2005 and 2009 .................................34 Chart 5.2 NO x Emissions Trends – All Anthropogenic Sources, 2005 and 2009 .........................35 Chart 5.3 SO 2 Emissions Trends – All Anthropogenic Sources, 2005 and 2009 ..........................35 Chart 5.4 PM 2.5 Emissions Trends – All Anthropogenic Sources, 2005 and 2009 .......................36 Chart 5.5 NO x Emissions Trends – Dearborn County, 2005 and 2009 .........................................38 Chart 5.6 SO 2 Emissions Trends – Dearborn County, 2005 and 2009..........................................38 Chart 5.7 PM 2.5 Emissions Trends – Dearborn County, 2005 and 2009........................................39 Chart 5.8 Statewide NO x Emissions Trends from EGUs...............................................................39 Chart 7.1 Regional/Emission Sector PSAT Results, Murray Rd., Hamilton County, PM 2.5 Monitor ......................................................................................................54 Chart 7.2 Pie Charts of the Modeled Species Contributions to the Murray Rd. – St. Bernard, OH PM 2.5 Monitor..................................................................................................55 Chart 7.3 Pie Charts of the Modeled Species Contributions to the Univ. College - Covington, KY PM 2.5 Monitor ...................................................................................................................... .........55

APPENDICES

Appendix A .....................Aerometric Information Re trieval System (AIRS) Monitoring Data

Appendix A-1..........................................Technical Supplement: 2007 Monitoring Data

Appendix B..........................................................................Emissions Inventories

Appendix C..............................................Section 110(a)(1) and (2) SIP Submittal Letter

Appendix D.........................U.S. EPA Guidance on the Use of Models and Other Analyses

Appendix E...............................LADCO’s Round 5 Modeling Technical Support Document

Appendix F...........................LADCO’s Modeling Protoc ol Addendum: Technical Details

Appendix G...............................Attainment Test Results for all Cincinnati Area Monitors

Appendix H..........................................................Example MOBILE Input/Output Files

Appendix I..................................................................Public Participation Documents

Appendix J.......ASIP Base G4 Annual PM 2.5 Modeling Results for all Cincinnati Area Monitors

Appendix K.................Modeled Species Contributions at Northern Kentucky PM 2.5 Monitor1 1.0 OVERVIEW

1.1 INTRODUCTION

Particulate matter is one of six criteria air pollutants that scientists have identified as being particularly harmful to humans and the environment. National Ambient Air Quality Standards (NAAQS) have been developed for these six pollutants and are used as measurements of air quality. Fine particles and precursor pollutants are emitted by a wide range of sources, including power plants, cars, trucks, industrial sources and other burning or combustion-related activities.

1.2 NATIONAL AMBIENT AIR QUALITY STANDARDS

The Clean Air Act as amended in 1990 (CAAA) requires areas designated as nonattainment of the applicable NAAQS to develop State Implementation Plans (SIPs) to expeditiously attain and maintain the standard. In 1997, U.S. EPA set daily and annual air quality standards for fine particles (fine particulate matter), as shown in Table 1.1 below. The standards were legally challenged and upheld by the U.S. Supreme Court in February of 2001. In 1999, Indiana began monitoring for fine particle concentrations. The United States Environmental Protection Agency (U.S. EPA) designated areas in Indiana under the standards for fine particles on December 17, 2004 as attainment, nonattainment or unclassifiable, with an effective date of April 5, 2005.

Table 1.1 National Ambient Air Quality Standards for Fine Particles

Annual 24-Hour

1997 Fine Particles Standards (PM 2.5 ) 15.0 μg/m 3 Annual arithmetic mean, averaged over 3 years 65.0 μg/m 3 24-hour average, 98 th percentile, averaged over 3 years

2006 Fine Particles Standards (PM 2.5 ) 15.0 μg/m 3 Annual arithmetic mean, averaged over 3 years 35.0 μg/m 3 24-hour average, 98 th percentile, averaged over 3 years
Note: The Cincinnati area meets the 1997 24-hour NAAQS’ for fine particles. Since this area is solely designated nonattainment under the 1997 annual standard for fine particles, this document only addresses the annual standard. Designations hav e not been made for the 2006 revised daily standard at this time.

On December 17, 2004, based on 2001-2003 monitoring data, U.S. EPA designated the Cincinnati-Hamilton OH-KY-IN area as nonattainment of the annual standard for fine particles, and subject to CAA Part D Title 1, Section 172 of Subpart 1 requirements, including the development of a plan to reduce oxides of nitrogen (NO x ), sulfur dioxide (SO 2 ) and direct PM 2.5 emissions and a demonstration that the area will meet the annual standard for fine particles by April 5, 2010.

These designations became effective on April 5, 2005. Also, on April 5, 2005, U.S. EPA issued a supplemental notice changing the designation status of several areas based on updated quality2 assured monitoring data from 2002-2004. This action did not affect the Cincinnati area. Monitors for fine particle levels for the Cincinnati area are located in Campbell and Kenton counties in Kentucky and Butler, Clermont, and Hamilton counties in Ohio (see Figure 1.1). Based on the most recent three years of monitoring data, 2004-2006, the Cincinnati fine particle nonattainment area has not measured air quality that meets the standard. A comprehensive detail of the monitoring data is included in Appendix A.

The Cincinnati-Hamilton OH-KY-IN area as defined in Section 1.3, has not previously been subject to nonattainment area rulemakings for fine particles. However, the area had been subject to nonattainment area rulemakings under the 1-hour and the 8-hour ozone standards. The 1-hour ozone standard was revoked on June 15, 2005, but the Cincinnati area remained designated as nonattainment under the 8-hour ozone standard.

Table 1.2 Cincinnati Area 2001-2003 Air Quality Monitoring Data used for Designation3 SITE ID COUNTY SITE NAME YEAR Annual Average μg/m 3 2001-2003 Average μg/m 3

21-037-0003 Campbell Alexandria Pk. 2001 13.44
21-037-0003 Campbell Alexandria Pk. 2002 14.81
21-037-0003 Campbell Alexandria Pk. 2003 13.42 13.89

21-117-0007 Kenton Univ. College 2001 15.25
21-117-0007 Kenton Univ. College 2002 15.06
21-117-0007 Kenton Univ. College 2003 14.30 14.87

39-017-0003 Butler Bonita & St. John 2001 16.51
39-017-0003 Butler Bonita & St. John 2002 16.66
39-017-0003 Butler Bonita & St. John 2003 14.81 15.99

39-017-0016 Butler Nilles Rd. 2001 15.81
39-017-0016 Butler Nilles Rd. 2002 15.29
39-017-0016 Butler Nilles Rd. 2003 15.77 15.62

39-017-0017 Butler Wilwood 2001 15.72
39-017-0017 Butler Wilwood 2002 15.53
39-017-0017 Butler Wilwood 2003 14.44 15.23

39-017-1004 Butler Hook Field Airport 2001 No data for 2001
39-017-1004 Butler Hook Field Airport 2002 13.69
39-017-1004 Butler Hook Field Airport 2003 14.91 14.30

39-061-0014 Hamilton Seymour & Vine St. 2001 18.38
39-061-0014 Hamilton Seymour & Vine St. 2002 17.91 39-061-0014 Hamilton Seymour & Vine St. 2003 17.19 17.82

39-061-0040 Hamilton Howard Taft 2001 15.76
39-061-0040 Hamilton Howard Taft 2002 15.16
39-061-0040 Hamilton Howard Taft 2003 15.42 15.44

39-061-0041 Hamilton Winneste Ave. 2001 16.01
39-061-0041 Hamilton Winneste Ave. 2002 15.06
39-061-0041 Hamilton Winneste Ave. 2003 15.21 15.42

39-061-0042 Hamilton W. 8th St. 2001 17.66
39-061-0042 Hamilton W. 8th St. 2002 16.74
39-061-0042 Hamilton W. 8th St. 2003 16.63 17.01

39-061-0043 Hamilton E. Kemper Rd. 2001 15.91
39-061-0043 Hamilton E. Kemper Rd. 2002 15.41
39-061-0043 Hamilton E. Kemper Rd. 2003 15.60 15.64

39-061-7001 Hamilton Sherman Ave. 2001 16.75
39-061-7001 Hamilton Sherman Ave. 2002 16.03
39-061-7001 Hamilton Sherman Ave. 2003 16.01 16.26

39-0061-8001 Hamilton Murray Rd. 2001 16.86
39-0061-8001 Hamilton Murray Rd. 2002 16.92
39-0061-8001 Hamilton Murray Rd. 2003 17.26 17.01

Value above the standard Less than three years of data

Section 172 of the CAA stipulates the requirements that nonattainment areas must meet, including the development of a plan to reduce direct and precursor emissions of the applicable4 NAAQS. The plan must include a demonstration that the area will meet the ambient air quality standard within five (5) years of designation, or April 5, 2010.

In accordance with U.S. EPA’s Clean Air Fine Particle Implementation Rule 1

, this document demonstrates that, with the combination of current clean air measures and the implementation of local and federally-required control measures, air quality in the Cincinnati nonattainment area will meet the annual fine particle standard by the attainment date. This document contains the annual fine particle standard attainment de monstration for the Cincinnati-Hamilton OH-KY-IN fine particle nonattainment area.

1.3 GEOGRAPHICAL DESCRIPTION

The entire Cincinnati-Hamilton OH-KY-IN fine particle nonattainment area consists of Lawrenceburg Township in Dearborn County, Indi ana; Butler, Clermont, Hamilton, and Warren counties, Ohio; and Boone, Campbell and Kenton counties, Kentucky and contains such cities as Cincinnati, Hamilton, and Middletown, all in Ohio. This area is depicted in Figure 1.1.

Fine particle monitors are located in Campbell and Kenton counties in Kentucky and Butler, Clermont, and Hamilton counties in Ohio. There are no monitors for fine particles in the Indiana portion of the Cincinnati nonattainment area. The hi ghest levels of fine particle concentrations have been typically monitored at the Murray Rd. monitor (39-0061-8001) in Hamilton County, Ohio. Refer to Figure 1.1 for the location of the monitors in the nonattainment area. Designations were made based upon monitored air quality data measured during 2001, 2002 and 2003. Table 1.2 shows the monitored design values for 2001-2003. Two monitors, 400 Clermont Dr. in Clermont County, Ohio and Grooms Rd. in Hamilton County, Ohio, did not have sufficient monitoring data to calculate design values for the 2001-2003 period, and therefore, are not included in Table 1.2.

U.S. EPA designated areas under the fine particle standards as attainment, nonattainment or unclassifiable, on December 17, 2004, with an effective date of April 5, 2005. The Cincinnati fine particle nonattainment area was designated nonattainment of the annual fine particle standard pursuant to the CAA. As a result, Section 172(c) of the CAA set forth requirements for Indiana’s State Implementation Plan (SIP) submittal.

Figure 1.1 Cincinnati Fine Particle Area Designations and Monitor Locations

1 http://www.epa.gov/fedrgstr/EPA-AIR/2007/April/Day-25/a6347.htmThe agencies responsible for assuring the fine particle nonattainment area complies with the CAA requirements are:

< The Ohio Environmental Protection Agency (Ohio EPA), which is responsible for Butler, Clermont, Clinton, Hamilton and Warren counties, Ohio;

< The Kentucky Department for Environm ental Protection, (KDEP) which is responsible for Boone, Campbell and Kenton counties, Kentucky; and,

< The Indiana Department of Environmental Management (IDEM), which is responsible for Lawrenceburg Township, Dearborn County, Indiana.

These three (3) state agencies have worked cooperatively with U.S. EPA Regions IV and V to address attainment planning issues.

Although the three (3) agencies, in the three (3) states, have worked together on a comprehensive plan for the multi-state nonattainment areas, each state is required to make a separate submittal for its portion of the planning components to U.S. EPA. Attainment demonstrations are SIP submittals and U.S. EPA action on them is taken separately. As such, this submittal covers Lawrenceburg Township in Dearborn County, Indiana.

56 1.4 CONTROL STRATEGY

Several control measures already in place or being implemented over the next few years will reduce stationary point, on-road mobile, and non-road mobile source emissions. The expected federal and state control measures were modeled for the attainment year of 2009.

The federal control measures that were modeled included the Tier 2 vehicle standards, the heavy-duty gasoline and diesel highway vehicle sta ndards, low sulfur gasoline and diesel fuels, large non-road diesel engines standard and the non-road spark-ignition engines and recreational engines standard.

The state control measures that were modeled include the NO x SIP Call and the Clean Air Interstate Rule (CAIR). The control measures included in the modeling are described in greater detail in Section 6.0.

1.5 ATTAINMENT TEST

U.S. EPA guidance requires that attainment demonstrations for fine particles be supported by photochemical grid modeling. A computer model is used to predict maximum fine particle concentrations in every grid cell (or point of analysis) within the nonattainment area.

The attainment test is not based on absolute modeling results, but rather Relative Responses achieved by comparing the modeled base year to the modeled control strategy, at specific monitoring sites. The benchmark for attainment is that the results of applying the relative response factors to the current monitored design values are below the annual fine particle standard. The latest regional modeling conducted by the Lake Michigan Air Director’s Consortium (LADCO) shows all future year concentrations below the annual fine particle NAAQS of 15.0 μg/m 3

. The results of the various steps used to calculate the predicted future year concentrations for each monitor located in the Cincinnati fine particle nonattainment area are shown in Table 1.3. The first three columns are the monitor identification number, monitor name and county in which the monitor is located. The next two columns are the modeling base year design value and the future year design value. As shown in Table 1.3, all of the monitors in the area are expected to be below the standard. According to U.S. EPA guidance, areas with future year design values between 14.5 μg/m 3 and 15.5 μg/m 3 need to provide a more comprehensive weight of evidence analyses to demonstrate that the area will attain the fine particle NAAQS. Areas with future year design values lower than 14.5 μg/m 3 at each monitor site only need to provide a basic supplemental analysis that the area will attain the annual fine particle standard.7 Table 1.3 Attainment Test Results for Cincinnati-Hamilton OH-KY-IN

Monitor ID Monitor Name County Design Value 2003-2006

(μg/m 3 ) Design Value 2003-2007

(μg/m 3 ) Future Year 2009 (μg/m 3 )
390170003 Bonita & St John Butler 16.1 15.80 13.3 390170016 Nilles Rd. Butler 15.8 15.66 13.0 390170017 Wilwood Butler 16.1 15.53 a 13.6 390171004 Hook Field Airport Butler 14.9 14.86 12.4 390250022 400 Clermont Dr. Clermont 14.7 14.62 11.8 390610006 Grooms Rd. Hamilton 15.5 15.43 12.7 390610014 Seymour & Vine St. Hamilton 17.4 17.27 14.4 390610040 Howard Taft Hamilton 15.5 15.41 12.7 390610041 Winneste Ave. Hamilton 15.4 14.57 b 13.0 390610042 101 W. 8th St. Hamilton 17.0 16.83 13.9 390610043 254 Kemper Rd. Hamilton 15.6 15.40 12.9 390617001 Sherman Ave. Hamilton 16.3 16.11 13.3 390618001 Murray Rd. Hamilton 17.7 17.44 14.6 210370003 Alexandria Pk. Campbell 13.3 13.75 a 11.6 211170007 Univ. College Kenton 14.4 14.29 11.8

a Monitors were not operational after 2005.
b Monitors were not operational after 2004.

Since the area’s future year design value is predicted to be below the fine particle standard, at 14.6 μg/m 3 at the Murray Rd. fine particle monitor, a weight of evidence analysis is necessary for Lawrenceburg Township. The analysis further demonstrates that the nonattainment area will comply with the annual fine particle standard by the prescribed attainment date of April 5, 2010. This demonstration includes an analysis of air quality trends, emissions trends, and a current air quality data summary of emissions reductions still to occur in 2008 and 2009, along with additional measures that were not included in the air quality modeling. IDEM believes that the modeled attainment demonstration in conjunction with the weight of evidence analysis and an identified set of control measures provides the necessary evidence that the Cincinnati-Hamilton OH-KY-IN nonattainment area will attain the fine particle standard by April 5, 2010.

The structure and content of this document addresses each of the elements required by the CAA and U.S. EPA guidance. Compliance with these elements provides the technical analysis necessary to support a demonstration of the following:

 the Cincinnati area will attain the annual fine particle standard by the attainment date;

 air quality in the area is improving;

 emissions reductions from national and regional control measures included in the attainment plan will bring the area into attainment as expeditiously as possible;

 regional modeling performed by LADCO demonstrates that with regional NO x and8 SO 2 reductions, the area will be able to comply with the annual fine particle standard without additional control measures; and,

 the additional implementation of control measures not included in the modeling analysis will provide further assurance that the standard is attained and maintained.

2.0 CLEAN AIR ACT REQUIREMENTS

Section 172(c) of the CAA specifies the various planning requirements that apply to fine particulate matter nonattainment areas. Also, because the fine particle nonattainment area includes counties within the State of Kentucky, Section 182(j) of the CAA adds additional plan provisions. The CAA specifies the following requirements:

1. General requirements for Reasonably Available Control Measures (RACM)/Reasonably Available Control Technology (RACT), 2. Reasonable Further Progress (RFP), 3. Emissions inventories, 4. Identification and quantification of emissions, 5. Permit program for new and modified sources, 6. Other control measures, means or techniques 7. Compliance with Section 110(a)(2), 8. Equivalent techniques, 9. Contingency measures, 10. Demonstration of attainment based upon photochemical grid modeling or equivalent analytical method, and 11. Mobile source emissions budget.

These components were due by April 5, 2008. The following section provides an overview of Indiana’s progress in meeting the CAA requirements mentioned above.

2.1 GENERAL REQUIREMENTS (SECTION 172(C)(1))

2.1.1 Reasonably Available Control Measures (RACM)

The CAA requires a demonstration that the State has adopted all reasonable and available control measures to demonstrate attainment as expeditiously as practicable and that no additional measures that are reasonably available will advance the attainment date. Although regional photochemical modeling indicates that no additional control measures are necessary to achieve the annual fine particle standard by the attainment date, IDEM participates in the regional planning effort through LADCO to evaluate potential control measures to attain the 8-hour ozone and fine particle standards and achieve regional haze goals.

Candidate control measures were evaluated primarily for feasibility, cost effectiveness, and the ability to implement them in a relatively short time frame (i.e., January 1, 2009, for the 2009 monitoring year). Due mainly to the lengthy rulemaking process in Indiana, many of the control strategies evaluated could not be implemented by the 2009 monitoring year and were not9 pursued since they were not needed to demonstrate attainment in an expeditious fashion.

2.1.2 Reasonably Available Control Technology (RACT)

U.S. EPA’s Clean Air Fine Particle Implementation Rule makes a determination that areas classified under Subpart 1 will meet the CAA’s RACT requirement by submitting a demonstration that shows attainment as expeditiously as practicable, but no later than 5 years after designation. This document will show th at this requirement will be met with the implementation of mandatory federal control measures and regional measures implemented in Ohio, Kentucky and Indiana. This document also shows that the projected annual fine particle design value will provide an ample margin of safety, well below U.S. EPA’s defined threshold for a detailed RACT analysis to be completed in conjunction with this submittal.

2.2 REASONABLE FURTHER PROGRESS (SECTION 172 (C)(2))

Based on U.S. EPA’s Fine Particle Implementation rule, Reasonable Further Progress (RFP) is met by ensuring emissions reductions needed for attainment are implemented by the beginning of the monitoring season preceding the attainment date (i.e., by January 1, 2009). As confirmed by regional photochemical modeling, no additional local controls are necessary to attain the air quality standard by the attainment date.

2.3 EMISSIONS INVENTORIES (SECTION 172 (C)(3))

U.S. EPA guidance requires the submittal of a comprehensive emissions inventory of direct fine particle and fine particle precursor emissions [oxides of nitrogen (NO x ) and sulfur dioxide (SO 2 )] representative of the base year (2005). IDEM has also prepared comprehensive emissions inventory projections for the attainment year (2009). Consistent with the federal implementation rule for fine particles, Indiana does not consider volatile organic compounds or ammonia to be significant contributors to fine particles. IDEM meets this requirement through the submittal of the statewide emissions inventory under the Cons olidated Emission Reporting Rule (CERR) for the State of Indiana.

IDEM submitted a statewide 2005 emissions inventory for stationary and area sources to U.S. EPA in June 2007. The 2005 emissions inventory, fo r Dearborn County in Indiana is included as Appendix B. The emissions inventory used in this attainment demonstration is also subject to public comment along with the full attainment demonstration.

It should be noted that Lawrenceburg Township is a small portion of Dearborn County, Indiana and only accounts for a portion of the county’s stationary and area source categories in the emissions inventory. However, the largest st ationary point source within Dearborn County, Indiana, an electric generating facility, is located in Lawrenceburg Township. To be conservative in demonstrating attainment, the emissions inventory included in this document and Appendix B consists of the entire county.

2.4 IDENTIFICATION AND QUANTIFICATION OF EMISSIONS (SECTION 172 (C)(4))10 Section 172(c)(4) requires the SIP to identify and quantify the emissions of pollutants (in this case, particulate matter, NO x and SO 2 ) that sources will be allowed from the construction and operation of major new and modified sources in accordance with Section 173(a)(1)(B), and will not interfere with attainment of the annual fine particle standard by the attainment date. Indiana’s permitting rules which meet this requirement are outlined in rule 326 IAC 2-3.

2.5 PERMIT PROGRAM FOR NEW AND MODIFIED MAJOR SOURCES (SECTION 172 (C)(5))

Section 172 (c)(5) requires the State to implement a permit program consistent with the requirements of Section 173. Indiana has a l ong standing and fully-implemented New Source Review (NSR) permitting program that is outlined in rule 326 IAC 2-3. Indiana’s NSR program was approved by U.S. EPA on Oct. 7, 1994 (94 FR 24838), as part of the SIP.

Any facility that is not listed in the 2005 emissions inventory, or for the closing of which credit was taken in demonstrating attainment, will not be allowed to construct, reopen, modify, or reconstruct without meeting all applicable permit rule requirements, including an air quality analysis to evaluate whether the new source will threaten the NAAQS.

2.6 OTHER CONTROL MEASURES, MEANS OR TECHNIQUES (SECTION 172 (C)(6))

Modeling conducted by LADCO to predict future y ear fine particle design values show that existing emission control measures will bring the Cincinnati area into attainment of the annual fine particle NAAQS and provide for an ample ma rgin of safety. Federal and local control measures to be phased-in or implemented in the next several years will provide even greater assurance that air quality will continue to meet the standard into the future. In addition, LADCO modeling conducted to determine the impact of the Clean Air Interstate Rule in the region, shows that future year design values for the Cincinnati-Hamilton OH-KY-IN fine particle nonattainment area will attain the annual fine particle standard with values below 15.0 μg/m 3

. Existing and future national and regional control measures will ensure that attainment in each county will be maintained with an increasing margin of safety over time. These measures are discussed in greater detail in the Control Strategy Section (Section 6.0). Therefore, no additional control measures are being implemented and modeled to demonstrate attainment. However, additional control measures are being implemented to provide assurance of the area maintaining air quality below the standard.

2.7 COMPLIANCE WITH SECTION 110(A)(2) (SECTION 172 (C)(7))11 Section 172(c)(7) requires nonattainment SIPs to meet the applicable provisions of Section 110(a)(2). IDEM has reviewed the requirements of Section 110(a)(2) and has concluded that prior rule submittals, along with this attainment demonstration, address the relevant requirements associated with rule development, state implementation plan submissions, and implementation and enforcement of required control measures. Within a letter to U.S. EPA dated December 7, 2007, Indiana reaffirmed that it maintains the necessary infrastructure and resources to comply with Sections 110(a)(1) and (2) for all criteria pollutants (Appendix C).

2.8 EQUIVALENT TECHNIQUES (SECTION 172(C)(8))

IDEM has followed U.S. EPA guidance on pro cedures for modeling, preparing emissions inventories and plan submittals. Therefore, IDEM is not requesting approval for equivalent techniques, as allowed under Section 172(c)(8).

2.9 CONTINGENCY MEASURES (SECTION 172 (C)(9))

Section 172 (c)(9) of the CAA requires states with nonattainment areas to include contingency measures as part of attainment demonstrations. Contingency measures are specific measures to be undertaken in the event that the area fails to attain the standard by the applicable attainment date. The selected contingency measures are discussed in greater detail in Section 9.0 of this document.

2.10 ATTAINMENT DEMONSTRATION

U.S. EPA’s Fine Particle Implementation Rule requires the submittal of an attainment demonstration SIP that includes local, regional a nd/or national modeling analyses that meet the attainment modeling criteria set forth in U.S. EPA’s modeling guidance. Through LADCO, photochemical modeling was conducted using the Comprehensive Air Quality Model with Extensions (CAMx) for this modeled attainment demonstration. This modeling is being supplemented with regional modeling performed by LADCO in developing the Clean Air Interstate Rule (CAIR) and rulemaking to support national control measures.

U.S. EPA modeling guidance for the annual fine pa rticle standard stipulates that the following elements be included in an approvable attainment demonstration submittal:

3⁄4 photochemical grid modeling analysis; 3⁄4 air quality trends analysis; 3⁄4 emissions trends analysis; 3⁄4 identification of control measures factored into the modeling analysis as well as those not factored into the modeling analysis; and, 3⁄4 identification of mobile source emissions budgets (SO 2 , NO x and direct PM 2.5 ) for transportation conformity purposes.

Each element of this attainment demonstration is described briefly below and in more detail in12 the Technical Elements of Demonstration (Sections 3.0 – 7.0) and Mobile Source Emissions Budgets (Section 8.0).

2.10.1 Photochemical Grid Modeling Analysis

A more detailed discussion of the photochemical grid modeling, model selection, methodologies, attainment test, model inputs, modeling protocol and analysis method is included in the Photochemical Modeling Analysis Section of the Technical Elements of Demonstration (Section 3.1).

2.10.2 Air Quality Trends Analysis

Implementation of national control strategies has resulted in improvement in air quality within the Cincinnati annual fine particle nonattainment area. Data show emissions are decreasing, air quality peak values are on the decline, and the number of exceedances are also decreasing.

The technical data (Sections 3.0-7.0) show a continual decline in the fine particle concentration levels since 2001.

Chart 2.1 shows the decline in the controlling fine particle design value 2 for the Cincinnati fine particle nonattainment area. During the 2001-2003 time period, the Seymour & Vine Street ambient monitor represented the area ’ s controlling annual fine particle design value. As shown in this table, the area’s design value has decreased from 17.82 μg/m 3 to 17.33 μg/m 3 , a decline of 0.49 μg/m 3 since being designated as nonattainment. The current design value for 2004-2006 is shown in Chart 2.2. Modeling predicts that this value will decline by an additional 2.73 μg/m 3 by 2009. The controlling annual fine particle monitor for the latest 3-year design value (2004- 2006) is the Murray Road ambient monitor with a design value of 17.3 μg/m 3 . Modeling predicts that this value will decline by an additional 3.1 μg/m 3 by 2009, demonstrating attainment of the standard prior to the April 5, 2010 attainment date.

Chart 2.1 Fine Particle Design Value Trends

2 The design value for a nonattainment area, which characterizes the severity of the area’s air quality problem, is represented b y the highest design value at any individual fine particle monitoring site. The design value of a monitoring site is the average of the fine particle value over a three-year period. If a monitor is less than or equal to 15.0 μg/m 3 it is considered attainment. A monitor that measures 15.05 μg/m 3 or higher is considered nonattainment. (Decimals 0.049 or lower are rounded down, decimals 0.050 are rounded up). Three year design values are reporte d with only 1 decimal point. Values close to 15.0 may be shown with two decimal points for clarification.12.00 13.00 14.00 15.00 16.00 17.00 18.00

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Chart 2.2 Fine Particle Design Values for the Cincinnati Nonattainment Area

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A more complete picture of the air quality improvement in the Cincinnati fine particle nonattainment area is shown in Chart 4.1 and Figure 4.3, included in Section 4.0 of this

1314 document.

2.10.3 Emissions Trends Analysis

Control measures have been implemented requiring substantial emissions reductions from mobile, industrial, and area sources. A detailed discussion of emissions trends is included in the Emissions Trends Analysis section of this document (Section 5.0).

2.11 CONTROL STRATEGY

Several control measures already in place or being implemented over the next few years will reduce point, on-road mobile and non-road mobile source emissions. The Federal and State control measures which were included in the photochemical modeling for the future year design value and additional control measures due to be implemented, but not included in the modeling, are discussed in greater detail in the Control Strategy section of this document (Section 6.0).

2.12 MOBILE SOURCE EMISSIONS BUDGET

U.S. EPA requirements outlined in 40 CFR 93.118(e)(4) stipulate that a mobile source emissions budget be established as part of the attainment demonstration. The mobile source emissions budget is necessary to demonstrate conformity of transportation plans with the state implementation plan.

The purpose of transportation conformity is to ensure that Federal transportation actions occurring in the nonattainment area do not hinder the area from attaining and maintaining the annual fine particle standard. This means that the level of emissions estimated by the metropolitan planning organization for the Transportation Implementation Plan and the Long Range Transportation Plan must not exceed the motor vehicle emissions budget as defined in this attainment demonstration.

In general, while the total vehicle miles traveled (VMT) has increased throughout the region, mobile source emissions levels have decreased significantly since 1999. This decline in emissions is a result of federal motor vehicle control requirements and cleaner motor fuels.

The mobile source emissions budget is included in Section 8.0 of this document.15 

### 3.0 TECHNICAL ELEMENTS OF DEMONSTRATION

This section presents details of the technical work done to analyze air quality data to demonstrate attainment of the annual fine particle standard. The results of the computer modeling and an analysis of air quality and emissions inventory trends presents strong evidence that pending control measures will improve air quality, thereby assuring air quality levels below the annual fine particle NAAQS by April 5, 2010.

3.1 PHOTOCHEMICAL MODELING ANALYSIS

Indiana is required to submit modeling as part of its attainment demonstration. U.S. EPA’s implementation guidance allows states to submit regional or national modeling as the sole (primary) modeling analysis. This modeling demonstration relies upon regional modeling as the primary modeling analysis and Indiana will include national modeling, conducted by U.S. EPA as a weight of evidence analysis.

The primary attainment modeling analysis for the Cincinnati nonattainment area was performed in conjunction with the fine particle and regional haze modeling conducted by LADCO. LADCO is comprised of five Midwest states: Illinois, Indiana, Michigan, Ohio and Wisconsin. LADCO provides expertise in review of monitoring data, development of emissions inventories and meteorological files and application of photochemical modeling and evaluation of model performance and modeled results. LADCO prepared the “Regional Air Quality Analyses for Ozone, PM 2.5, and Regional Haze: Technical Support Document” (LADCO, 2008), a detailed technical support document describing the methodology for the fine particle attainment demonstration modeling analysis for all the states supported by LADCO. This document can be found in Appendix E.

Extensive regional modeling has been performed covering the Cincinnati fine particle nonattainment area to determine the effect of national, regional and local emission control strategies on fine particle levels. These modeling analyses determined that the Cincinnati area is impacted by regional transport of fine particles and its precursors; SO 2 , NO x , organic carbon (OC) and ammonium (NH 4 ) associated with sulfates and nitrates. National emissions reductions, including those associated with CAIR are an effective way to demonstrate attainment of the annual fine particle standard in this area. Future year modeled annual fine particle concentrations in the Cincinnati area are expected to be reduced from baseline design values by 13% to 20% in 2009 and reduced by 17% to 24% by 2018 leading to the attainment of the annual fine particle NAAQS of 15 μg/m 3

. The following paragraphs briefly describe the methods, inputs used and major components of this analysis. The attainment demonstration and modeling procedures followed were recommended by U.S. EPA’s “Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 and Regional Haze” (EPA454/B-07-002, April 2007), Appendix D.16 3.1.1 Modeling Methodology

The modeling analysis is a complex technical evaluation that begins with selection of the modeling system. LADCO used the following modeling system:

• Air Quality Model: Comprehensive Air Quality Model with Extensions (CAMx version 4.50).

• Meteorological Model: Mesoscale Model (MM5) version 3.7.

• Emissions Models: Emissions Modeling System (EMS-2003) and, Consolidated Community Emissions Processing Tool (CONCEPT).

Model Selection Title 40, Code of Federal Regulations, Part 51, Appendix W, does not offer specific recommendations for photochemical models to be used for attainment demonstrations. However, the models selected must be scientifically appropriate for the intended application and be freely available for review and available to stakeholders and their consultants for execution and verification at low or no cost. All of the models selected for use in this analysis meet these criteria and have been peer reviewed. Past performance has shown that the models are not biased toward under or overestimates.

The air quality model selected for this technical analysis was CAMx (version 4.50), an Eulerian photochemical grid model developed by ENVIR ON and approved by U.S. EPA for this use. CAMx allows for integrated “one-atmosphere” assessment of ozone and PM 2.5 . Notable features of CAMx include flexi-nesting, which allows fo r reconfiguration of nested grids within the model, multiple gas phase chemistry mechanism options and Particulate Source Apportionment Technology. CAMx modeling is performed on a Linux computing platform with a Portland Group (PGI) Fortran compiler to create executable files.

3.1.2 Modeling Preparation and Objectives

The modeling analysis included (1) preparation of a protocol, (2) preparation of emissions inventories, (3) preparation of meteorological i nputs, (4) application of the model and diagnostic analysis of inputs, (5) evaluation of performan ce, (6) evaluation of reduction scenarios, and, (7) analysis of modeling results. The specific objectives of the analysis were to:

* apply the model to 2005 meteorological and emissions data and evaluate CAMx model performance, * prepare future-year (2009) emissions inventory to evaluate future federal, regional and local emissions control strategies for the attainment of the annual fine particle standard, and, * run the model for the future year to evaluate the combined effects of growth and emissions reductions resulting from national, regional and local measures.17 3.1.3 Meteorology Selection

Domain and grid resolution for the modeling analyses included a national Regional Planning Organization grid at 36 kilometers for both the meteorological and emissions modeling. Landuse files were based on the Biogenic Emi ssions Landuse Database, version 3 (BELD3) 1 kilometer data and photolysis rates were calculated with the Tropospheric Ultraviolet-Visible (TUV) radiation model.

3.1.4 Modeling Domain

The domain for this modeling analysis was approximately centered on the Midwest portion of the country, including the Cincinnati fine par ticle nonattainment area. The meteorological modeling domain consists of a grid of 36 kilometer cells that extends over the entire continental United States. The photochemical modeling grid consists of a grid of 36 kilometer cells that extends over the LADCO five-state region and adjacent states. Selection of the domain was based upon distribution of emissions sources, locations of meteorological and air quality monitoring sites, and typical meteorological conditions in the area. Figure 3.1 shows the meteorological and emissions modeling domain.Figure 3.1 LADCO Modeling Domain

Meteorological inputs were processed using th e National Center for Atmospheric Research (NCAR) 5 th generation Mesoscale Model (MM5) version 3.7. A more detailed explanation of the inputs for the MM5 model are listed on page 48 of the “Regional Air Quality Analyses for Ozone, PM 2.5 , and Regional Haze Technical Support Document”, included in Appendix E.

The modeling analysis involves several steps. Be low is a brief overview of the steps involved. A more detailed explanation of the modeling analysis and methodology can be found in Appendix F of this document.

Modeled Attainment Demonstration for Annual PM 2.5 1) Calculating site-specific baseline concentrations. Annual arithmetic mean is calculated by averaging the four quarterly arithmetic mean concentrations observed during a calendar year. 2) Identifying grid cells near monitoring site. U.S. EPA recommends using the single modeled value in or near the grid cell which contains the monitor. 3) Choosing model predictions to calculate a relative response factor (RRF) near a monitor.

a. For an annual PM 2.5 prediction, U.S. EPA recommends taking the spatially

1819 averaged values of the nearby predictions (mean value of the grid cell array). b. The component-specific RRFs are computed by taking the ratio of the mean of the spatially averaged daily predictions. 4) Estimating design values at unmonitored locations.

a. Interpolate ambient data by creating a set of quarterly average spatial fields. b. The four (4) quarters can then be averaged to get an annual average set of fields. 5) Choosing a base year emissions inventory to be projected for calculating RRFs. U.S. EPA recommends using emissions which correspond to the monitored period reflected by chosen baseline design value period. 6) Choosing year to project future emissions. Emissions should be projected to the attainment year, based on an area’s air quality classification.

3.1.5 Selection of Base Year

There were two (2) base years selected in the LADCO modeling analyses: 2002 3 and 2005. 2002 was run initially and as more recent emissions and meteorological data became available prior to the submittal of the attainment demonstration, 2005 was evaluated. The emissions for 2005 take into account national emissions control strategies as opposed to 2002 which did not include national emissions control strategies such as the NO x SIP Call. 2005 had meteorological conditions considered to be conducive for fine pa rticle development. LADCO performed several analyses on the meteorological data and trend analyses on fine particles and its pre-cursors. Results showed comparable meteorology for 2002 and 2005 and Theil trend analysis showed consistent improvement of fine particle concentrations throughout the Midwest since 1999 with annual decreases from 0.2 μg/m 3 to 0.5 μg/m 3 in the Cincinnati fine particle nonattainment area.

3.1.6 Selection of Future Years

The future year of interest for the Cincinnati area, due to its annual PM 2.5 nonattainment status, was 2010 (five (5) years from the effective date of designation under the annual standard). This year represents the attainment date. Therefore, 2009 is the future year of interest in order to show emissions reductions preceding the attainment year to demonstrate attainment in the area. 2012 and 2018 future years were also modeled in order to demonstrate continued attainment of the fine particle NAAQS.

3.1.7 Emissions Inputs

EMS and CONCEPT are two of the key emissions modeling tools used to determine emissions estimates for LADCO’s Round 5 photochemical modeling.

- On-road source emissions were developed fr om CONCEPT using vehicle miles traveled

3 US EPA guidance recommended using 2002 as the baseyear fo r modeling analyses, but allows states to use 2005. LADCO began the modeling exercise using 2002 as the base year, but as more recent emissions and meteorological data became available prior to the modeling being complete d, a decision was made to switch to 2005 as the baseyear. This decision was discussed with U.S. EPA staff.20 (VMT) and vehicle speeds supplied by state and local planning agencies for 24 networks. The CONCEPT model was run for winter (January 15-17) and summer (July 16-18) emissions profile days representing a weekday, Saturday and Sunday. - Non-road sources were developed from the National Mobile Inventory Model (NMIM2005). Marine, aircraft and railroad emissions were prepared by ENVIRON and handled separately from non-road sources. - Area source emissions were developed with EMS for weekday, Saturday and Sunday emissions for each month of the modeled period. - Point source emissions were developed from state inventories and continuous emissions monitoring (CEM) data from electrical generating units. EMS calculated the point source emissions for weekday, Saturday and Sunday emissions for each month of the modeled period. - Biogenic emissions were supplied by Alpi ne using an updated CONCEPT/Model of Emissions of Gases and Aerosols from Na ture (MEGAN) biogenic emissions model. - Ammonium emissions were developed from a Carnegie Mellon University-based 2002 ammonia emissions model which were grown out to 2005 and adjusted by temporal monthly factors. - Canadian emissions were taken from the 2005 Canadian National Pollutant Release Inventory, Version 1.0 (NPRI).

Future year emissions were grown from the basecase 2005 emissions and estimates were developed from the emissions models; EMS/CONCEPT and NMIM for on-road and non-road emissions sources. Future year emissions for EGUs were developed from Integrated Planning Model version 3.0 (IPM3.0) with several CAIR emissions control scenarios factored in. Growth and control factors were applied to area, marine/aircraft/ railroad and non-EGU point source emissions as well as emission changes due to applied local consent decrees, RACT and Best Achievable Retrofit Technology (BART).

3.1.8 Model Performance

Model performance was evaluated according to U.S. EPA statistical guideline recommendations, in order for the modeled concentrations to replicate observed concentrations. PM 2.5 model performance was evaluated by LADCO through a va riety of methods. Time series plots of monthly average mean bias and annual fractional bias were used and are shown in Figure 3.2.

Figure 3.2Model Performance Metrics for Annual PM 2.5 Modeling

Model performance was relatively good for nitrates, elemental carbon, ammonium and soil with under prediction of organic carbon and over prediction of sulfates, although the sulfateperformance would be considered acceptable with bias values within 35 percent. The day-today, as well as, the hour-to-hour variations from observed data and modeled data are consistent. There is acceptable modeled performance in the overall fine particle mass concentrations with some variability in the modeled performance of several of the species compositions of the fine particles.

3.2 MODELED ATTAINMENT TEST

The modeled attainment demonstration consists of analyses that estimate whether existing and future emissions reductions along with appropriate growth factors for future emissions will result in future ambient concentrations that will meet the NAAQS. The attainment demonstration also identifies a set of emissions control measures that will ensure that an area will continue to attain the NAAQS into the future. In order to make this determination, a modeled attainment test is required.

2122 The annual PM 2.5 attainment test, as described in U.S. EPA guidance, recommends a modeled attainment test in which the results are used in a “relative” rather than “absolute” sense. This approach takes the ratio of the photochemical modeling results and future to baseline predictions at specific monitoring sites. This ratio is known as a relative response factor (RRF). Once a RRF has been determined, the RRF is applied to the current design value of a pollutant or in the case of PM 2.5 , the different components which make up fine particles. The major components that make up fine particles are as follows:

- mass associated with sulfates (SO 4 ); - mass associated with nitrates (NO 3 ); - mass associated with ammonium (NH 4 ); - mass associated with organic carbon (OC); - mass associated with elemental carbon (EC); - mass associated with particle bound water (pbw); - mass associated with “other” primary inorganic particulate matter (soil); and, - passively collected mass.

The steps involved in the annual PM 2.5 modeled attainment test, otherwise known as the Speciated Modeled Attainment Test (SMAT) are listed below. The specific inputs and results of the SMAT for the Cincinnati area are listed in Section 3.3 of this document.

Step 1: Compute the observed quarterly mean PM 2.5 and quarterly mean composition of each monitor.

- This is accomplished by multiplying the monitored quarterly mean concentration of Federal Reference Method (FRM) derived PM 2.5 by the monitored fractional composition of PM 2.5 species for each quarter.

- In the event that monitored speciated data is not available, LADCO used chemically speciated IMPROVE and STN PM 2.5 data to develop seasonal spatial fields for each PM 2.5 species. SAS software package PROC KRIG function (EPA, 2004b) was used to develop these spatial fields.

Step 2: Using model results, derive component-specific RRFs at each monitor for each quarter for each of the components for PM 2.5
.

- Air quality modeling is applied to estimate current and future year concentrations for each component of PM 2.5.

- Relative response factors are derived by taking the ratio of future year concentrations over the baseline modeled concentrations at the monitoring site.

Step 3: Apply the component-specific relative response factors to the observed air quality to obtain quarterly species estimates.

- The current quarterly mean component concentration from Step 1 is multiplied by the component-specific RRF derived in Step 2, which gives an estimated future quarterly mean concentration for each component.23 Step 4: Calculate a future year annual average PM 2.5 estimate.

- The quarterly mean components (estimated in Step 3) are summed together for a quarterly mean PM 2.5 value. - The four quarterly mean PM 2.5 values are determined and the average of these four quarterly mean PM 2.5 values will give a future year annual average PM 2.5 value for each monitor analyzed.

3.3 ATTAINMENT TEST RESULTS

LADCO performed the attainment tests for all upper Midwest state monitoring sites, including those located in the Cincinnati area. LADCO followed U.S. EPA guidance concerning the modeled attainment test for the Cincinnati area. LADCO’s latest modeling (Round 5) showed all future year concentrations were below the annual fine particle NAAQS of 15.0 micrograms per cubic meter.

Results of Step 1 of the attainment test for the annual fine particle NAAQS are shown in following two tables. Table 3.1 shows the percentage of the quarterly mean for each individual pollutant of the observed quarterly mean. Table 3.2 shows the mass of each individual component of the quarterly mean of the fine particle samples. This is the observed quarterly mean and composition of the controlling monitor for the Cincinnati area, which is the Murray Road monitor, St. Bernard, Ohio.

Table 3.1 Percent of Quarterly Mean Composition Murray Rd., Hamilton Co. Monitor

Pollutant (percent of total mass) Quarter 1 Quarter 2 Quarter 3 Quarter 4

SO 4 26.85 35.75 37.22 26.5 NO 3 23.78 0.25 0 12.03 OC 19.0 19.82 12.1 21.64 EC 3.5 4.65 3.09 5.2 Soil 2.29 2.88 1.99 3.33 NH 4 15.83 12.12 11.78 12.74 Pbw 8.74 12.78 12.61 8.4124 Table 3.2 Observed Quarterly Mean/Quarterly Mean Composition for each Component of PM 2.5 Murray Rd., Hamilton Co. Monitor

Pollutant (μg/m 3 ) Quarter 1 Quarter 2 Quarter 3 Quarter 4 Average

SO 4 4.4571 5.8523 8.2256 3.9830 5.6 NO 3 3.9475 0.0409 0.0000 1.8081 1.4 OC 3.1540 3.2445 2.6741 3.2525 3.1 EC 0.5810 0.7612 0.6829 0.7816 0.7 Soil 0.3801 0.4715 0.4398 0.5005 0.4 NH 4 2.6278 1.9840 2.6034 1.9148 2.3 Pbw 1.4508 2.0921 2.7868 1.2640 1.9 Quarterly FRM Mean (total mass) 16.6 16.37 22.1 15.03

Passively collected mass is not used in the modeling and calculation of the RRFs. Passive mass appears to result from contamination of the filters from handling and contact with the FRM cassette. It is not included in Tables 3.1 and 3.2 above. For this reason, the percentages in Table 3.1 may not total 100% and the mass of the individual pollutant components may not equal the total mass of the Quarterly FRM Mean.

Once the observed quarterly mean and composition of the fine particle concentrations are determined, Step 2 of the attainment test requires that the component-specific relative response factors be derived for each quarter from the bas ecase and future year modeled concentrations at each monitor. The results of this step are shown in Table 3.3.

Table 3.3 Relative Response Factors (RRFs) for each Component Murray Rd., Hamilton Co. Monitor

Pollutant Quarter 1 Quarter 2 Quarter 3 Quarter 4 SO 4 0.8104 0.6331 0.577 0.7754 NO 3 1.0886 1.0155 1.0923 0.9857 OC 0.961 1.0798 1.082 1.0235 EC 0.8969 0.9228 0.9099 0.8876 Soil 1.4146 1.3785 1.537 1.4007 NH 4 0.9077 0.6968 0.6441 0.846 Pbw 0.8687 0.6307 0.5734 0.8172

The derived relative response factors for each quarter are then applied to the observed quarterly compositions of the fine particle concentrations to calculate the projected quarterly species estimates for each monitor, as per Step 3 of the attainment test guidance. Results are shown in25 Table 3.4. Table 3.4 Projected Quarterly Species Estimates Murray Rd., Hamilton Co. Monitor

Pollutant (μg/m 3 ) Quarter 1 Quarter 2 Quarter 3 Quarter 4 TOTAL SO 4 3.6120 3.7051 4.7462 3.0884 3.8 NO 3 4.2972 0.0416 0.0000 1.7823 1.5 OC 3.0310 3.5034 2.8934 3.3289 3.2 EC 0.5211 0.7024 0.6214 0.6937 0.6 Soil 0.5377 0.6499 0.6760 0.7010 0.6 NH 4 2.3852 1.3825 1.6768 1.6199 1.8 Pbw 1.2603 1.3195 1.5980 1.0330 1.3 TOTAL 15.64 11.30 12.21 12.25

Finally, Step 4 of the attainment test calculates the future year annual average fine particle concentrations, which are compared to the annual fine particle NAAQS of 15.0 micrograms per cubic meter. Table 3.5 shows a summary of the future year, 2009, modeled concentrations that show all fine particle monitors in the Cincinnati area will attain the annual fine particle standard.

Table 3.5 Attainment Test Results for Cincinnati-Hamilton OH-KY-IN Nonattainment Area

Monitor ID Monitor Name County Modeled Design Value

2003-2006

(μg/m 3 ) Futurecase 2009 (μg/m 3 ) 390170003 Bonita & St John Butler 16.1 13.3 390170016 Nilles Rd. Butler 15.8 13.0 390170017 Wilwood Butler 16.1 13.6 390171004 Hook Field Airport Butler 14.9 12.4 390250022 Clermont Dr. Clermont 14.7 11.8 390610006 Grooms Rd. Hamilton 15.5 12.7 390610014 Seymour & Vine St. Hamilton 17.4 14.4 390610040 Howard Taft Hamilton 15.5 12.7 390610041 Winneste Ave. Hamilton 15.4 13.0 390610042 W. 8th St. Hamilton 17.0 13.9 390610043 E. Kemper Rd. Hamilton 15.6 12.9 390617001 Sherman Ave. Hamilton 16.3 13.3 390618001 Murray Rd. Hamilton 17.7 14.6 210373002 Alexandria Pk. Campbell 13.3 11.6 211170007 Univ. College Kenton 14.4 11.8 An additional adjustment is made to values in Table 3.4 to arrive at results in Table 3.5. The reason is, again, passively collected mass. In the attainment test calculations, the passive mass is26 assumed to remain constant over time, e.g. the RRF equals 1.0. Therefore, the portion of the observed basecase sample attributed to passive mass is added back into the projected 2009 mass, to provide the averages in Table 3.5.

Modeled results show similar mean species compositions and relative response factors at all the fine particle monitoring sites and all monitors show compliance with the annual fine particle NAAQS.

3.4 UNMONITORED AREA ANALYSIS

U.S. EPA has recommended in its “Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 and Regional Haze” (EPA454/B-07-002, April 2007) an “unmonitored area analysis” for areas without monitors that could potentially exceed the NAAQS if monitors existed in those areas. The “unmonitored area analysis” uses a combination of ambient data to provide spatial fields for monitored and unmonitored areas and model outputs for predicted concentrations throughout a region. Lawrenceburg Township in Dearborn County, Indi ana was designated as nonattainment for the annual fine particle standard despite the fact that there is no fine particle monitor in the county. This county is adjacent to Hamilton County in Ohio, which has monitors in the southern, central, and northeastern portions of the county.

Ambient fine particle monitors in the Cincinnati area provide adequate coverage, as per 40 CFR, Part 58, Appendix D, 4.7. Indiana has placed fine particle monitors throughout the state as per this guidance that based the number of monitors on the population of the metropolitan statistical area (MSA) and the design values for monitored areas. The monitors are therefore concentrated in the more urban areas where higher pollutant concentrations are expected. Due to the rural nature of Dearborn County and its location upwind of the Cincinnati area, there are no fine particle monitors located in Dearborn County. There are fine particle monitors located in nearby Butler and Clermont counties in Ohio and Campbell and Kenton counties in Kentucky. While these Campbell and Kenton county monitors were sited upwind of the urban center of the Cincinnati OH MSA, the resulting design values between these monitors are comparable with the latest 3-year design values (2004-2006) and range between 13.8 and 14.1 μg/m3.

Figure 3.3 shows the Cincinnati area PM 2.5 monitoring network. Circles surrounding the monitors indicate the spatial scale of coverage for each of the monitors. The spatial scale of representation describes the physical dimensions of the air parcel measured at and near the monitor. In the rural areas, the air quality in the spatial coverages of the regional and urban monitor is considered to have similar concentrations. The monitors shown in Figure 3.3 are those closest to the unmonitored nonattainment areas.

An urban monitor has a spatial scale of representation which extends from 4 to 50 kilometers from the monitoring site. Nilles Rd. and Hook Field Airport fine particle monitors are urban monitors and their spatial scale of representation extends into Dearborn County and Hamilton and Clermont counties in Ohio. Nilles Rd. ambient monitor represents a downwind urban scale monitor, whose air quality monitoring extends out 50 kilometers. The Nilles Rd. fine particlemonitor’s current annual PM 2.5 3-year design value (2004-2006) is 15.5 μg/m 3 . Hook Field Airport ambient monitor represents a downwind urban scale monitor, whose air quality monitoring extends out 50 kilometers. The Hook Field Airport fine particle monitor’s current annual PM 2.5 3-year design value (2004-2006) is 14.6 μg/m 3 . All other monitors in the Cincinnati area are neighborhood monitors that have spatial scales of representation which extend from 0.5 to 4 kilometers.

Figure 3.3 Spatial Representation for the Cincinnati Area PM 2.5 Monitoring Sites

Lawrence Township Rush

Ripley H enry

Wayne

Franklin

Decatur Randolph

Jefferson Fayette

Switzerland Ohio Dearborn Union Darke

Brown Clark Miami

Clinton Greene Champaign

Clermont Butler Preble

Warren

Hamilton Montgomery

Grant Pendleton Bracken Gallatin Boone

Kenton Campbell PM2.5 Monitor ohiostatebndy polygon

PM2.5 Attainment Area

PM2.5 Nonattainment Area

50km

50km

Table 3.6 shows the fine particle monitors located outside the urban center of Cincinnati; the monitors in Butler and Clermont counties in Ohio and the Campbell and Kenton county monitors
2728 in Kentucky have displayed typically lower annual design values than the monitors impacted by the Cincinnati urban core emissions. Average differences in concentrations between the rural monitors and urban monitors range from 3.0 μg/m 3 to 5.5 μg/m 3 . In addition, the Butler County monitor in Ohio and Kenton and Campbell county monitors in Kentucky, show lower design values that would be more representative of air quality in Dearborn County. It is apparent that the higher annual fine particle concentrations are found in or near the urban center of Cincinnati. This fact is shown in the annual design values for each of the Cincinnati area fine particle monitors over the past seven (7) years (2000-2006). Chart 3.1 shows the general downward trend in fine particle concentrations in the Cincinnati area, with the exception of 2005.

Table 3.6 Annual Design Values for the Cincinnati Nonattainment Area from 2000 – 2006

County Site 2000 2001 2002 2003 2004 2005 2006 Butler Bonita & St John 17.0 16.5 16.7 14.8 14.1 18.6 14.1 Butler Nilles Rd. 18.9 15.8 15.3 15.8 14.7 17.9 13.9 Butler Wilwood 17.9 15.7 15.5 14.4 14.3 17.2 N/D Butler Hook Field Airport N/D N/D 13.7 14.9 13.6 16.9 13.4 Clermont Clermont Dr. N/D N/D N/D N/D N/D 15.6 12.7 Hamilton Grooms Rd. N/D N/D N/D N/D N/D 16.6 13.3 Hamilton Seymour & Vine St. 19.3 18.4 17.9 17.2 16.0 19.7 15.4 Hamilton Howard Taft 16.7 15.8 15.2 15.4 14.7 17.4 13.5 Hamilton Winneste Ave. 19.8 16.0 15.1 15.2 14.4 N/D N/D Hamilton W. 8th St. 20.6 17.7 16.7 16.6 16.1 19.1 14.9 Hamilton E. Kemper Rd. 19.1 15.9 15.4 15.6 15.0 16.6 14.4 Hamilton Sherman Ave. 17.2 16.8 16.0 16.0 15.4 18.3 14.3 Hamilton Murray Rd. 19.3 16.9 16.9 17.3 16.1 20.0 16.0 Campbell Alexandria Pk. 15.1 13.4 14.8 13.4 12.8 14.8 11.5

Kenton Univ. College 16.3 15.3 15.1 14.3 13.4 15.9 13.3
N/D No data

Chart 3.1Annual PM 2.5 Values for Cincinnati Nonattainment Area

10.0 12.0 14.0 16.0 18.0 20.0 22.0

2001 2002 2003 2004 2005 2006

Standard Alexandria Pk. Univ. College Bonita & St. John
Nilles Rd. Wilwood Hook Field Airport Clermont Dr.
Grooms Rd. Seymour & Vine St. Howard Taft Winneste Ave.
W. 8th St. E. Kemper Rd. Sherman Ave. Murray Rd.

29 U.S. EPA has developed the “Modeled Attainment Test Software” (MATS) to spatially interpret data, adjust spatial fields with modeled output gradients and multiply the fields by modeled RRFs. However, the PM 2.5 portion of MATS is not available at this time. U.S. EPA guidance recommends using nearby ambient data as well as modeled output to determine the concentrations in unmonitored areas. In the case of the unmonitored areas of Dearborn County, ambient monitored data in Hamilton, Clermont and Butler counties in Ohio and Campbell and Kenton counties in Kentucky show decreasing annual design values and future year modeled results in the Cincinnati area fine particle monitors fall below the annual fine particle standard.

A review of the LADCO Round 5 modeling results for the Cincinnati area PM 2.5 monitoring sites is shown in Table 3.7. The 2009 modeled results show that the highest modeled concentrations will be 14.6 μg/m 3 , 0.4 μg/m 3 below the annual fine particle NAAQS of 15.0 μg/m 3 with other modeled results in the Cincinnati area and other nearby areas much lower. Modeling results for2012 and 2018 indicate future year design values will continue to decrease in all CincinnatiHamilton OH-KY-IN area monitors. These results confirm that the adjacent U.S. EPA designated nonattainment Indiana county of Dearborn will be in attainment of the annual fine particle standard by 2009 and continue through 2018 as modeled fine particle concentrations are less than 14.0 μg/m 3 and continue to decrease in the future.30 Table 3.7 Modeling Results for PM 2.5 Monitors located in or near the Cincinnati Fine Particle Nonattainment Area for 2009, 2012 and 2018

2005 2009 2012 2018 Monitor Site County Base Year Future Year Future Year Future Year
390170003 Bonita & St John Butler 16.1 13.3 13.2 12.6
390170016 Nilles Rd. Butler 15.8 13.0 13.0 12.4
390170017 Wilwood Butler 16.1 13.6 13.5 12.9
390171004 Hook Field Airport Butler 14.9 12.4 12.3 11.8
390250022 Clermont Dr. Clermont 14.7 11.8 11.7 11.2
390610006 Grooms Rd. Hamilton 15.5 12.7 12.6 12.1
390610014 Seymour & Vine St. Hamilton 17.4 14.4 14.3 13.7
390610040 Howard Taft Hamilton 15.5 12.7 12.6 12.1
390610041 Winneste Ave. Hamilton 15.4 13.0 12.9 12.3
390610042 W. 8th St. Hamilton 17.0 13.9 13.8 13.2
390610043 E. Kemper Rd. Hamilton 15.6 12.9 12.8 12.3
390617001 Sherman Ave. Hamilton 16.3 13.3 13.2 12.7
390618001 Murray Rd. Hamilton 17.7 14.6 14.5 13.9
210370003 Alexandria Pk. Campbell 13.3 11.6 11.5 11.0
211170007 Univ. College Kenton 14.4 11.8 11.7 11.2

4.0 AIR QUALITY TRENDS

One benchmark for attainment with the annual fine particle standard is the area’s design value. Table 4.1 shows the yearly trend in the design value for the area since 2003. This value is determined by the average of each monitor’s PM 2.5 values over a three-year period.

Table 4.1 Cincinnati Nonattainment Area’s Annual Fine Particle Design Values

Year Design Value [ μ g/m 3 ] (Monitor Location) 3-Year Period

2006 17.33 (Murray Rd.) 2004-2006

2005 17.76 (Murray Rd.) 2003-2005

2004 17.02 (Seymour & Vine St.) 2002-2004

2003 17.82 (Seymour & Vine St.) 2001-2003

Figure 4.1 Controlling Monitor Design ValuesDirect PM 2.5 Trends (Controlling Monitor Values)

12.00 13.00 14.00 15.00 16.00 17.00 18.00 19.00 20.00

2001-2003 2002-2004 2003-2005 2004-2006ug/m3

Controlling Monitor Standard

As shown in Figure 4.1, the data shows a relatively continual decline since the implementation of federal control programs such as NO x SIP Call and the new engine and fuel standards. To give a more complete picture of the air quality improvement in the nonattainment area, Chart 4.1 lists the design values for each of the ambient fine particle monitors in the nonattainment area.

Chart 4.1 Historical Design Values for Cincinnati Nonattainment Area from 2001-2006

Three-Year Design Values 2001-2006

10.00 11.00 12.00 13.00 14.00 15.00 16.00 17.00 18.00 19.00 20.00

Alexandria Pk.
Uni

v . College

B

o n ita

&

St.

Jo

h

n Nilles Rd. Wilwo o d

H

oo

k Field Ai

rport Clermont Dr.

Gr

o oms

R

d. Seymour & Vine St. How a r d

T

a ft Winneste Ave. W. 8th S t .

E.

Kem per Rd.

S her

m

a n Ave .

M

u r r ay

Rd.ug/m3

2001-2003 2002-2004 2003-2005 2004-2006 Standard

31Figure 4.2 shows the design values for the Cincinnati fine particle nonattainment area from 2001 through 2006. Figure 4.2 Three-Year Fine Particle Design Values

12.0 13.0 14.0 15.0 16.0 17.0 18.0 19.0 20.0

2001-2003 2002-2004 2003-2005 2004-2006ug/m3

Standard Alexandria Pk. Univ. College Bonita & St. John
Nilles Rd. Wilwood Hook Field Airport Seymour & Vine St.
Howard Taft Winneste Ave. W. 8th St. E. Kemper Rd.
Sherman Ave. Murray Rd. Clermont Dr. Grooms Rd.

32 Looking at the design value for each year between 2001 and 2006, as shown in Chart 4.1 and Figure 4.2, the annual design values for the Cincinnati fine particle nonattainment area monitors generally show a downward trend. In the figure, the NAAQS value for annual PM 2.5 of 15.0 μg/m 3 is identified by the red line. A general downward trend can be noticed with the exception of 2005. 2005 had extended meteorological events that led to several PM 2.5 episodes in which daily PM 2.5 concentrations in the Cincinnati area were extremely high. This in turn, weighed the annual PM 2.5 concentrations and the latest 3-year design value for the area.

Figure 4.3 shows the monitored values from 2001-2006 for each of the monitors in the Cincinnati fine particle nonattainment area.Figure 4.3 Annual PM 2.5 Values for the Cincinnati Area

10.0 12.0 14.0 16.0 18.0 20.0 22.0

2001 2002 2003 2004 2005 2006

Standard Alexandria Pk. Univ. College Bonita & St. John
Nilles Rd. Wilwood Hook Field Airport Clermont Dr.
Grooms Rd. Seymour & Vine St. Howard Taft Winneste Ave.
W. 8th St. E. Kemper Rd. Sherman Ave. Murray Rd.

335.0 EMISSIONS TRENDS ANALYSIS

Charts 5.1, 5.2, 5.3, and 5.4 compare 2005 actual SO 2 , NO x and direct PM 2.5 emissions, which were used in the modeling demonstration, to the projected 2009 emissions.

Chart 5.1 Emissions Trends – All Anthropogenic Sources

Trends- All Anthropogenic Sources Cincinnati Nonattainment Area

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

2005 2009Annual Tons

NOx Direct PM2.5 SO2

34Chart 5.2 NO x Emissions Trends

NO x Trends - All Anthropogenic Sources Entire Nonattainment Area

- 20,000.00 40,000.00 60,000.00 80,000.00 100,000.00 120,000.00 140,000.00 160,000.00

NOX NOX

2005 2009Annual Tons

Ohio Total Kentucky Total
Indiana Total

Chart 5.3 SO 2 Emissions Trends

SO 2 Trends - All Anthropogenic Sources Entire Nonattainment Area

- 50,000.00 100,000.00 150,000.00 200,000.00 250,000.00 300,000.00

SO2 SO2

2005 2009Annual Tons

Ohio Total Kentucky Total
Indiana Total

35Chart 5.4 Direct PM 2.5 Emissions Trends

Direct PM 2.5 Trends - All Anthropogenic Sources Entire Nonattainment Area

- 2,000.00 4,000.00 6,000.00 8,000.00 10,000.00 12,000.00

Direct PM 2.5 Direct PM 2.5

2005 2009Annual Tons

Ohio Total Kentucky Total
Indiana Total

Table 5.1 shows the NO x emissions that were modeled for the nonattainment area, broken down by state and by emissions source sectors (point, area, mobile, and non-road). The 2005 estimated emissions were pulled from the LADCO emissions inventory files used to support modeling (Appendix B).

Table 5.1 NO x Emissions Inventories (tons per year) Entire Nonattainment Area

Sector NOx 2005 NOx 2009 %Reduction 2005-2009

Area 7,820.06 5,305.69 32.15 Non-road 21,627.45 15,954.40 26.23 On-road 43,955.54 33,851.76 53.94

Point 66,820.05 40,628.18 39.20 Total 140,223.10 95,740.03 43.60

Table 5.2 shows the SO 2 emissions for the attainment area by emission source sectors (point, area, mobile, and non-road). The projected 2009 emissions were pulled from the LADCO emissions inventory files to support the modeling (Appendix B).

3637 Table 5.2 SO 2 Emissions Inventories (tons per year) Entire Nonattainment Area

Sector SO 2 2005 SO 2 2009 %Reduction 2005-2009

Area 3,499.85 1,680.40 51.99 Non-road 2,322.65 846.29 63.56 On-road 884.77 221.01 75.02

Point 235,432.16 137,302.85 41.68 Total 242,139.43 140,050.55 42.16

Table 5.3 shows the PM 2.5 emissions for the nonattainment area by emission source sectors (point, area, mobile, and non-road). The 2005 estimated emissions were pulled from the LADCO emissions inventory files used to support the modeling (Appendix B).

Table 5.3 PM 2.5 Emissions Inventories (tons per year) Entire Nonattainment Area

Sector Direct PM 2.5 2005 Direct PM 2.5 2009 %Reduction 2005-2009

Area 2,080.89 1,623.83 21.96 Non-road 1,397.24 1,089.48 22.03 On-road 758.54 551.82 27.25

Point 2,816.58 6,998.93 -148.49 Total 7,053.25 10,264.06 -45.52

The CAIR rule provides annual state caps for NO x and SO 2 in two phases, with the Phase I caps for NO x and SO 2 starting in 2009 and 2010, respectively. In response to U.S. EPA’s rulemaking, IDEM adopted its state rule in 2006 based on the federal rule. IDEM’s rule includes an annual and seasonal NO x trading program, and an annual SO 2 trading program. Indiana’s NO x and SO 2 EGU budgets are shown in Table 5.4. EGU reductions occurring outside of the Cincinnati fine particle nonattainment area will have a positive affect on the area.

Charts 5.5, 5.6, and 5.7 compare 2005 actual SO 2 , NO x and direct PM 2.5 emissions, which were used in the modeling demonstration, to the projected 2009 emissions for Dearborn County in Indiana. While projected emissions for Dearborn County in 2009 do not decrease, the cap and trade programs, as illustrated in Charts 5.2 and 5.3, result in significant decreases in SO 2 and NO x across the nonattainment area.Chart 5.5 Direct NO x Emissions Trends

NOx Point Source Emission Trends Dearborn County

0 2,000 4,000 6,000 8,000 10,000 12,000

2005 2009Annual Tons

NOx

Chart 5.6 Direct SO 2 Emissions Trends

SO2 Point Source Emissions Trends Dearborn County

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

2005 2009Annual Tons

SO2

38Chart 5.7 Direct PM 2.5 Emissions Trends



### Direct PM 2.5 

### Point Source Emission Trends Dearborn County

0 20 40 60 80 100 120 140 160

2005 2009Annual Tons

Direct PM2.5

Chart 5.8 Statewide NO x Emissions Trends



### Statewide NOx Emissions from EGUs

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

1999 2000 2001 2002 2003 2004 2005 2006Annual Tons

NOx

3940 Table 5.4 Statewide Annual SO 2 and NO x EGU Budgets

STATEWIDE EGU SO 2 TRENDS STATEWIDE EGU NOx TRENDS

Year SO 2 Emissions, tons / annual Year NOx Emissions, tons / annual 1999 941,852.4 1999 347,217 2000 874,617.2 2000 334,522 2001 795,505.6 2001 315,420 2002 778,868.0 2002 281,146 2003 804,828.6 2003 260,980 2004 862,876.4 2004 224,311 2005 870,811.8 2005 207,982 2006 820,993.4 2006 202,728 Budget 2010-2014 254,599 Budget 2009-2014 108,935 Budget 2015 and later 178,219 Budget 2015 and later 90,779

As demonstrated by Figure 5.1, significant reductions of NO x associated with the NO x SIP Call and CAIR have been achieved statewide as well as regionally. For the six (6) state (Arkansas, Indiana, Illinois, Kentucky, Missouri and Tennessee) region shown in Figure 5.1 (the area south of latitude 39.3052 and west of longitude -84.8194 (the southwest quadrant denoted by crosshairs)) there is an estimated reduction in upwind EGU emissions of more than 203,000 tons of NO x from 2005 to 2010.Figure 5.1 Regional NO x Reductions 2005 through 2010

Difference in Tons Per Year

> -30000

-30000 - -20000

-20000 - -10000

-10000 - -1

-1 - 1

1 - 4000 

### NOx Difference 2005 - 2010

41Figure 5.2 Regional SO 2 Reductions 2005 through 2010

Difference in Tons Per Year

> -75000

-75000 - -50000

-50000 - -25000

-25000 - -1

-1 - 1

1 - 25000 

## SO2 Difference 2005 - 2010

4243 As demonstrated by Figure 5.2, reductions of regional SO 2 from upwind EGUs have also been achieved. For the six (6) state (Arkansas, Indiana, Illinois, Kentucky, Missouri and Tennessee) region shown in Figure 5.1 (the area south of latitude 39.3052 and west of longitude -84.8194 (the southwest quadrant denoted by crosshairs)) there is an estimated reduction in upwind EGU emissions of more than 570,000 tons of SO 2 from 2005 to 2010.

6.0 CONTROL STRATEGY

Several control measures already in place or being implemented over the next few years will reduce point, on-road mobile and non-road source emissions. The federal and state control measures included in the photochemical modeling for the future year design value and those additional control measures due to be implemented, but not included in the modeling, are less certain, discussed in sections 6.1 and 6.2. While the impacts of VOC reductions are minimal, they are nevertheless beneficial for controlling fine particle levels. Therefore, control measures that reduce VOC emissions are included in the following sections.

6.1 MODELED CONTROL MEASURES

Federal Tier 2 motor vehicle standards require all passenger vehicles in a manufacturer’s fleet, including light-duty trucks and sport 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 regulations. For these vehicles, the standards will be phased in beginning in 2008, with full compliance in 2009. The new standards require vehicles to be 77% to 95% cleaner than those on the road today. The Tier 2 standards also reduced the sulfur content of gasoline to 30 ppm beginning in January 2006. Most gasoline sold in Indiana prior to January 2006 had a sulfur content of about 500 ppm. Sulfur occurs naturally in gasoline, but interferes with the operation of catalytic converters on vehicles resulting in higher NO x emissions. Lower sulfur gasoline is necessary to achieve the Tier 2 vehicle emission standards.

6.1.1 Heavy-Duty Gasoline and Diesel Highway Vehicles Standards

New U.S. EPA standards designed to reduce NO x and VOC emissions from heavy-duty gasoline and diesel highway vehicles began to take e ffect in 2004. A second phase of standards and testing procedures, which began in 2007, reduced particulate matter 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 expected to achieve a 90% reduction in direct particulate matter (PM) emissions and a 95% reduction in NO x emissions for these new engines using low sulfur diesel, compared to ex isting engines using higher-content diesel. There will also be SO 2 reductions from these rules. The U.S. EPA has not quantified the expected reductions.44 6.1.2 Large Non-Road Diesel Engines Standards

In May 2004, U.S. EPA promulgated new rules for large non-road diesel engines, such as those used in construction, agricultural and industrial equipment, to be phased in between 2008 and 2014. The non-road diesel rules also reduce the allowable sulfur in non-road diesel fuel by over 99%. Non-road diesel fuel currently averages approximately 3,400 ppm sulfur. This rule limited non-road diesel sulfur content to 500 ppm in 2006 and 15 ppm in 2010. The combined engine and fuel rules will reduce NO x and PM emissions from large non-road diesel engines by over 90%, compared to current non-road engines using higher-content diesel.

6.1.3 Non-Road Spark-Ignition Engines And Recreational Engines Standards

The new standard, effective in July 2003, regulates NO x , VOCs and carbon monoxide (CO), for groups of previously unregulated non-road engines. The new standard applies to all new engines sold in the United States and imported after the standards went into effect. The standard applies to large spark-ignition engines (forklifts a nd airport ground service equipment), recreational vehicles (off-highway motorcycles and all-terrain vehicles), and recreational marine diesel engines. The regulation varies based upon the type of engine and vehicle.

The large spark-ignition engines contribute to ozone formation and ambient CO and PM levels in urban areas. Tier 1 of this standard was implemented in 2004 and Tier 2 started in 2007. Like the large spark-ignition, recreational vehicles c ontribute to ozone formation and ambient CO and PM levels. For the off-highway motorcycles and all-terrain vehicles, model year 2006, at least 50% of a manufacture’s fleet was required to meet the new exhaust emissions standard and 100% of the fleet was required to meet the standards in 2007. 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 non-road spark-ignition engines and recreational engine standards are fully implemented, an overall 72% reduction in VOCs, 80% reduction in NO x and 56% reduction in CO emissions are expected by 2020. These controls will help reduce ambient concentrations of ozone, CO and fine PM.

6.1.4 NO x SIP Call

The U.S. EPA NO x SIP Call required twenty-two (22) states to adopt rules that would result in significant emissions reductions from large electric generating units (EGUs), industrial boilers, and cement kilns in the eastern United States. Indiana adopted this rule in 2001. Beginning in 2004, this rule accounts for a reduction of approximately 31% of total NO x emissions statewide compared to previous uncontrolled years.

Twenty-one (21) other states have also adopted these rules, including states surrounding Indiana. The result is that significant reductions have occurred upwind and within Cincinnati fine particle nonattainment area because of the number of affected sources within the region.4546 6.1.5 Clean Air Interstate Rule (CAIR)

On May 12, 2005, the U.S. EPA promulgated the “Rule to Reduce Interstate Transport of Fine Particulate Matter and Ozone (Clean 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 sulfur dioxide (SO 2 ) and provided a model rule for the states to use in developing their rules to meet Federal requirements. The purpose of CAIR is to reduce interstate transport of precursors to fine particles and ozone.

CAIR applies to: (1) any stationary, fossil-fuel -fired boiler or stationary, fossil-fuel-fired combustion turbine, a generator with nameplate capacity of more than 25 MWe producing electricity for sale, or (2) 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 cogeneration unit, a cogeneration unit serving at any time a generator with a nameplate capacity of more than 25 MWe and supplying in any calendar year more than one-third of the unit’s potential electric output capacity or 219,000 MWh, whichever is greater to any utility power distribution system for sale.

This rule provides annual state caps for NO x and SO 2 in two phases, with the Phase I caps for NO x and SO 2 starting in 2009 and 2010, respectively. Phase II caps become effective in 2015. The U.S. EPA is allowing the caps to be met through a cap and trade program if a state chooses to participate in the program.

In response to U.S. EPA’s rulemaking, IDEM adopted its 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 requires compliance effective January 1, 2009.

6.2 ADDITIONAL CONTROL MEASURES

This section provides a summary of the additional control measures that have been or will be implemented in the nonattainment area and were not included in the modeling demonstration.

6.2.1 Federal Controls

* Portable Fuel Container (Gas Can) Controls

U.S. EPA issued a final rule on February 26, 2007 (71 FR 15830) to regulate VOC emissions from portable gasoline containers, or gas cans. Portable fuel containers are consumer products used to refuel a wide variety of gasoline-powered equipment, including lawn and garden equipment, recreational equipment, and passenger vehicles that have run out of gas. The proposed standards will reduce hydrocarbon emissions from evaporation, permeation, and spillage. These standards would significantly reduce benzene and other toxics, as well as VOC more generally.47 The rule proposed a performance-based standard of 0.3 grams per gallon per day of hydrocarbons, based on the emissions from the can over a diurnal test cycle. The standard will apply to gas cans manufactured on or after January 1, 2009. The U.S. EPA also proposed test procedures and a certification and compliance program, in order to ensure that gas cans meet the emissions standard over a range of in-use conditions. The proposed standards will result in the use of best available control technologies, such as durable permeation barriers, automatically closing spouts, and cans that are well-sealed.

Emissions reductions expected to be 18% by 2009, 54% reduction at full implementation in 2015.

* Small Non-Road Engine Rule

On April 17, 2007, U.S. EPA proposed a rule to control emissions from new gasolinepowered small non-road engines, including lawn and garden equipment (<25 hp) and recreational watercraft. Under the proposed rule, the exhaust emissions standards for Class I non-road engines will take effect in 2012 and for Class II engines in 2011. The watercraft standards will take effect in 2009. U.S. EPA anticipates that when fully implemented, the proposed standards will result in a 70% reduction in hydrocarbon and NO x emissions and a 20% reduction in CO from new engines’ exhaust, as well as a 70% reduction in evaporative emissions.

6.2.2 Indiana Statewide Controls

IDEM is proposing to implement several statewide VOC control rules. Through MRPO consultation, the other MRPO states (Illinois, Indiana, Michigan, Ohio, and Wisconsin) have also agreed to implement a series of similar controls to address regional ozone and particulate matter nonattainment areas in the upper Midwest. The rules will apply region-wide to consumer and commercial products, architectural and industrial maintenance (AIM), automobile refinishing operations, cold cleaning degreasing and Stage I vapor recovery.

* Consumer and Commercial Products (326 IAC 8)

This is a proposed new rule to adopt OTC model rule with additional product coverage and more stringent VOC limits (14.2 % reduction beyond Federal Part 59 rule, for a total reduction of 21% from uncontrolled emissions).

• Architectural and Industrial Maintenance (AIM) Coatings (326 IAC 8-14)

This rule will adopt more stringent VOC limits for AIM coatings based on Ozone Transport Commission model rule, 21% reduction beyond Federal Part 59 limits.48 * Automobile Refinishing Operations (326 IAC 8-10)

This rule will extend existing regulations statewide. A 55% reduction is expected from uncontrolled emissions, 24% reduction beyond Federal Part 59 limits.

* Stage I Vapor Recovery (326 IAC 8-4)

The existing regulation requires gasoline dispensing facilities with a monthly gasoline throughput of 10,000 gallons per month or greater to maintain vapor balance systems to collect gasoline vapors displaced during the transfer of gasoline between storage tanks and delivery trucks. The proposed rulemaking will amend 326 IAC 4-1 to apply to all gasoline dispensing facilities regardless of when the storage tank was installed. IDEM estimates that the rules requiring submerged loading and vapor balancing will achieve a 90% reduction in VOC emissions versus uncontrolled underground storage tank loading.

6.2.3 Kentucky Statewide Controls

Kentucky has adopted a number of regulations and legislation to address pollution issues across the state. These include the NO x SIP Call Rule, Open Burning Ban and Clean Air Interstate Rule. All of these regulations were modeled in the attainment demonstration. These regulations are summarized below.

* NO x SIP Call Rule

In response to the U.S. EPA’s NO x SIP call, Kentucky adopted rules to control the emissions of NO x from EGUs and large stationary combustion sources. These rules cover (1) fossil fuel-fired stationary boilers, combustion turbines, and combined cycle systems serving a generator with a nameplate capacity greater than 25 megawatts and selling any amount of electricity, (2) fossil fuel-fired stationary boilers, combustion turbines, and combined cycle systems having a maximum design heat input greater than 250 million British thermal units per hour, and (3) reciprocating stationary internal combustion engines rated at equal or greater than 2400 brake horsepower (3000 brake horsepower for diesel engines and 4400 brake hor sepower for dual fuel engines). As part of the NO x SIP call, the U.S. EPA rules established a NO x budget for sources in Kentucky and other states. Kentucky’s NO x SIP Call rule was predicted to reduce summertime NO x emissions from power plants and other industries by 66% by 2006. In August 2001, the Kentucky Natural Resources and Environmental Protection Cabinet adopted rules requiring the reductions.49 * Open Burning Bans

Kentucky revised the open burning regulation to prohibit most types of open burning inmoderate ozone nonattainment areas within Kentucky during the period of MaySeptember. This requirement continues in the Northern Kentucky area.

* Clean Air Interstate Rule

In response to the U.S. EPA’s CAIR, the KYDAQ developed rules to implement CAIR. Under the rule, Kentucky has caps as follows:

• Annual NO x : 83,205 tons for 2009-2014 and 69,337 tons for 2015 and each year thereafter.

• Ozone season NO x : 36,109 tons for 2009-2014 and 30,651 tons for 2015 and each year thereafter.

• Annual SO 2 : 188,773 tons for 2010-2014 and 132,141 tons for 2015 and each year thereafter.

The state’s NO x allocations have been distributed based on allocation methodologies in 401 KAR 52:210 and 220. The U.S. EPA will determine the SO 2 allocations, which are based on the acid rain program. For the most part the rules follow the U.S. EPA’s model rule. This rule does not preclude the DAQ from adopting additional emissions reduction requirements for covered sources if necessary to attain or maintain an ambient air quality standard.

The KYDAQ CAIR regulations became effective February 2, 2007.

6.2.4 Ohio Statewide Controls

Ohio has adopted a number of regulations and legislation to address pollution issues across the state. These include the 7.8 RVP Gasoline Rule, the High Volume, Low Pressure Autobody Repair Facilities Rule, and the Portable Fuel Containers Rule. All of these regulations were modeled in the attainment demonstration. These regulations are summarized below.

* 7.8 RVP Gasoline

This state rule is fully state-adopted and is effective one year following approval of a waiver by U.S. EPA under CAA Section 211 (c)(4)(C). Given the May 25, 2007 final approval (72 FR 29269) by U.S. EPA, the 7.8 RVP gasoline will be in place for the 2008

ozone season.

* High Volume, Low Pressure Autobody Repair Facilities:

This state rule has been effective since the 2006 ozone season. U.S. EPA approved this revision into the SIP on March 30, 2007.50 * Cold Cleaner Degreaser Operations

This state rule has been effective since the 2006 ozone season. U.S. EPA approved this revision into the SIP on March 30, 2007.

* Portable Fuel Containers

This rule is an effective state rule which has a compliance date of July 1, 2007. U.S. EPA approved this revision into the SIP on March 30, 2007.

* Tier II Emissions Standards for Vehicles and Gasoline Sulfur Standards

In February 2000, U.S. EPA finalized a federal rule to significantly reduce emissions from cars and light trucks, including sport utility vehicles (SUVs). Under this proposal, automakers will be required to sell cleaner cars, and refineries will be required to make cleaner, lower sulfur gasoline. This rule will apply nationwide. The federal rules will phase in between 2004 and 2009. U.S. EPA has estimated that NO x emissions reductions will be approximately 77% for passenger cars, 86% for smaller SUVs, light trucks, and minivans, and 65% to 95% reductions for larger SUVs, vans, and heavier trucks.

* Heavy-Duty Diesel Engines

In July 2000, U.S. EPA issued a final rule for Highway Heavy Duty Engines, a program which includes ultra low sulfur diesel fuel standards. This rule applies to heavy-duty gasoline and diesel trucks and buses. It is anticipated that this rule will result in significant reductions in NO x from diesel trucks and buses, a large sector of the mobile sources NO x inventory.

* Clean Air Non-road Diesel Rule

In May 2004, U.S. EPA issued the Clean Air Non-road Diesel Rule. This rule applies to diesel engines used in industries such as construction, agriculture, and mining. It also contains a cleaner fuel standard similar to the highway diesel program. The new standards will cut emissions from non-road diesel engines by more than 90%. Non-road diesel equipment, as described in this rule, currently accounts for 47% of diesel particulate matter (PM) and 25% of NO x from mobile sources nationwide. Sulfur levels will be reduced in non-road diesel fuel by 99% from current levels, from approximately 3,000 parts per million (ppm) now to 15 ppm in 2010. New engine standards take effect, based on engine horsepower, starting in 2008. Together, these rules will substantially reduce local and regional sources of ozone precursors.

* Architectural and Industrial Maintenance (AIM) Coatings

This rule has been adopted by the State of Ohio.51 * Consumer and Commercial Products (CP)

This rule has been adopted by the State of Ohio and has compliance dates of March 15, 2008 and Jan. 1, 2009.

7.0 WEIGHT OF EVIDENCE ANALYSIS

U.S. EPA’s fine particle modeling guidance requires states to submit a weight of evidence analysis demonstration if future year modeled design values are “close” to the standard (between 14.5 and 15.5 μg/m 3 ), see “Guideline on the Use of Models and Other Analysis in Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 and Regional Haze (April 2007).

Because the 2009 future year design value for the Cincinnati nonattainment area is below the annual fine particle standard but within the 14.5 to 15.5 μg/m 3 (14.6 μg/m 3 at the Murray Rd. ambient fine particle monitor), Indiana is including a weight of evidence analysis to demonstrate that the area will attain the standard by the required date.

The weight of evidence analysis relies on existing modeling conducted by LADCO and U.S. EPA for CAIR and reductions from additional control measures to be implemented that were not included in the modeling analyses. The weight of evidence analysis further supports the fact that the design value will continue downward and leads to the conclusion that the nonattainment area will comply with the fine particle standard by the attainment date.

7.1. LADCO’S ROUND 5 MODELING

LADCO conducted modeling to determine the impact of CAIR in the Midwest. LADCO’s modeling used the CAMx applied to the year 2005 meteorology, as processed by MM5. Emissions input into CAMx included sulfur dioxide, nitrogen oxides, volatile organic compounds, ammonia and direct PM 2.5 for 2005. The modeling was based on 2003 through 2006 design values. Future year modeling for 2009, 2012, and 2018 was conducted and the future year design values were determined, as shown below in Table 7.1.52 Table 7.1 LADCO’s Round 5 Modeling Results for the Clean Air Interstate Rule

Monitor ID Monitor Name County Design Value 2003-2006 Futurecase with CAIR 2009 Futurecase with CAIR 2012 Futurecase with CAIR 2018 (μg/m 3 ) (μg/m 3 ) (μg/m 3 ) (μg/m 3 ) 390170003 Bonita & St John Butler 16.1 13.3 13.2 12.6 390170016 Nilles Rd. Butler 15.8 13.0 13.0 12.4 390170017 Wilwood Butler 16.1 13.6 13.5 12.9 390171004 Hook Field Airport Butler 14.9 12.4 12.3 11.8 390250022 Clermont Dr. Clermont 14.7 11.8 11.7 11.2 390610006 Grooms Rd. Hamilton 15.5 12.7 12.6 12.1 390610014 Seymour & Vine St. Hamilton 17.4 14.4 14.3 13.7 390610040 Howard Taft Hamilton 15.5 12.7 12.6 12.1 390610041 Winneste Ave. Hamilton 15.4 13.0 12.9 12.3 390610042 W. 8th St. Hamilton 17.0 13.9 13.8 13.2 390610043 E. Kemper Rd. Hamilton 15.6 12.9 12.8 12.3 390617001 Sherman Ave. Hamilton 16.3 13.3 13.2 12.7 390618001 Murray Rd. Hamilton 17.7 14.6 14.5 13.9 210373002 Alexandria Pk. Campbell 13.3 11.6 11.5 11.0 211170007 Univ. College Kenton 14.4 11.8 11.7 11.2

Results of the LADCO CAIR modeling show that all counties within the Cincinnati fine particle nonattainment area will attain the annual NAAQS for fine particles of 15 μg/m 3 by 2009. As shown in Figure 7.1, future year modeled annual fine particle concentrations for 2009 will be 13% to 20% lower than baseline annual fine particle design values, 14% to 20% lower in 2012 and 17% to 24% lower in 2018 and will continue to decrease, thereafter.Figure 7.1 Graph of Modeling Results for Cincinnati Area PM 2.5 Monitors for 2009, 2012 and 2018

10 11 12 13 14 15 16 17 18

2005 2009 2012 2018Concentrations (ug/m3)

Standard Bonita & St John Nilles Rd. Wilw ood Hook Field Airport Clermont Dr. Grooms Rd Seymour & Vine St.

How ard Taft Winneste Ave. W. 8th St. E. Kemper Rd.
Sherman Ave. Murray Rd. Fort Thomas Covington

7.2 LADCO’S ROUND 5 SPECIATED MODELED 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, ammonium, particle bound water, “other” primary inorganic fine particles and passively collect ed mass. The SMAT results from LADCO’s Round 5 modeling are listed below. Percent ranges of the modeled results from the fine particle monitors in the Cincinnati area were broken down into these speciated constituents of fine particle emissions. The percent change from the observed and spatial fields speciated data in 2005 to the future year modeled results for 2009 are listed below in Table 7.2.

5354 Table 7.2 LADCO’s Round 5 SMAT Modeling Results for the Cincinnati Area (Percent reduction observed from 2005 to 2009 modeled concentrations)

Species of PM2.5 2009 Sulfates 29% - 36% Nitrates -9% - 0% Organic Carbon -6% - (-2%) Elemental Carbon 0% - 17% Ammonium 19% - 26% Particle Bound Water 24% - 38%

The results show that sulfate, ammonium and particle bound water concentration decreases are projected to occur by at least 19% in the future year 2009. Lesser elemental carbon reductions are projected to occur, up to 17%, with nitrate and organic carbon increases occurring up to 9%. LADCO modeling shows good performance for sulfates and elemental carbon predicted baseline concentrations, slight over-prediction for nitrate concentrations 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 for the Cincinnati area.

7.3 LADCO’S ROUND 5 PARTICULATE SOURCE APPORTIONMENT RESULTS

Particulate Source Apportionment (PSAT) modele d was also conducted by LADCO. The results of the PSAT Round 5 modeling show the contribu tions from regional and emissions sectors on each monitor that was modeled. Chart 7.1 below shows the regional and emissions sector contributions for the Murray Rd. fine particle monitor, with Ohio being the biggest regional contributor. The PSAT Round 5 modeling results show the majority of Indiana’s emissions sector contributions to fine particle concentrations at the Murray Rd. ambient monitor come from electric generating units (EGUs), ammonium, onroad emissions sources, off-road (including marine, aircraft and railroad), non-EGU and area sources. These results are considered to be representative of the entire Cincinnati area as EGU, mobile and ammonium emissions impact on the entire area.Chart 7.1 Regional/Emissions Sector PSAT Results Murray Road, Hamilton Co., PM 2.5 Monitor

The following pie charts depict the species contributions to fine particle concentrations at the Cincinnati area fine particle monitors. The pie charts include both the observed 2005 contributions and future year 2009 modeled contributions for each monitor. Since the monitors are in close proximity of each other, results are fairly similar in the distribution of species concentrations among the monitors. Charts 7.2 and 7.3 cover the fine particle monitors in the Cincinnati area that are used to determine compliance with the annual NAAQS.

55CHART 7.2 Modeled Species Contributions to St. Bernard, OH - Murray Rd. PM 2.5 Monitor

Observed 2005 Contributions at St. Bernard - Murray Rd PM2.5 Monitor

so4 35%

no3 8%

oc 23% ec 4% soil 3% nh4 13% pbw 11% blan 3%

so4

no3

oc

ec
soil

nh4 pbw

blan 2009 Modeled Contributions at St. Bernard - Murray Rd PM2.5 Monitor

so4 27%

no3

10%

oc 27% ec 5% soil 5%

nh4 13% pbw 9% blan 4%

so4

no3

oc

ec
soil

nh4 pbw

blan

CHART 7.3 Modeled Species Contributions to Covington, KY - University College PM 2.5 Monitor

Observed 2005 Contributions at Covington - University College PM2.5 Monitor

so4 35%

no3 8%

oc 23% ec 4% soil 3% nh4 13% pbw 11% blan 3%

so4

no3

oc

ec
soil

nh4 pbw

blan 2009 Modeled Contributions at Covington - University College PM2.5 Monitor

so4 27%

no3

10%

oc 27% ec 5% soil 5%

nh4 13% pbw 9% blan 4%

so4

no3

oc

ec
soil

nh4 pbw

blan

Results of the Round 5 PSAT modeling for all the Cincinnati area fine particle monitors (see Appendix E) show the highest pollutant contributor s to basecase and future year fine particle concentrations are sulfate, organic carbon, ammoni um and nitrate. Future year modeling show decreases in sulfates (due to the emissions reductions from CAIR) and ammonium. The future year modeling did show slight increases in organic carbon and nitrates from the basecase modeled concentrations. However, these increases are offset by the larger decreases in sulfates.

7.4 DAILY MONITORED DATA COMPARISON FOR CINCINNATI PM 2.5 MONITORING SITES

The consistent PSAT results are evident in the monitoring data through the Cincinnati fine particle nonattainment area, as the trends for each of the Cincinnati area monitors follow each other on a daily and annual basis. The daily monitored data was compared for each year between 2003 through 2006. Analyzed for all monitored fine particle days, the Cincinnati area fine particle monitors had average daily impacts which varied from 6 to 10 μg/m 3 ; some days had impacts greater between the urban and rural sites. Average annual impacts between 5.2 and

567.6 μg/m 3 of each fine particle monitor in the Cincinnati area, indicating a more urban influence
to the fine particle concentrations in the area. As can be seen in Figure 7.2, all of the Cincinnati area fine particle monitors track fairly close together each year with higher fine particle episodes evident in 2005.

Figure 7.2 Daily Monitoring Data Comparison for Cincinnati PM 2.5 Monitors

2003 2004

Cincinnati OH-KY-IN Nonattainment Area 2003 PM2.5 Monitor Data

0 10 20 30 40 50 601-Jan1-Feb1-Mar1-Apr1-May1-Jun1-Jul1-Aug1-Sep1-Oct1-Nov1-Dec1-Jan

Calendar Year 2005Micrograms/Cubic Meter Ft Thomas Covington
Bonita
Nilles
Wildwood
Hook Seymour/Vine
Taft
Winneste
W. 8th St. Kemper Rd.
Sherman Rd. Murray Cincinnati OH-KY-IN Nonattainment Area 2004 PM2.5 Monitor Data

0 10 20 30 40 50 601-Jan1-Feb1-Mar1-Apr1-May1-Jun1-Jul1-Aug1-Sep1-Oct1-Nov1-Dec1-Jan

Calendar Year 2005Micrograms/Cubic Meter Ft. Thomas Covington
Bonita
Nilles
Wildwood
Hook Seymour/Vine
Taft
Winneste
W. 8th St. Kemper Rd.
Sherman Murray

2004 chart

2005 2006

Cincinnati OH-KY-IN Nonattainment Area 2005 PM2.5 Monitor Data

0 10 20 30 40 50 601-Jan1-Feb1-Mar1-Apr1-May1-Jun1-Jul1-Aug1-Sep1-Oct1-Nov1-Dec1-Jan

Calendar Year 2005Micrograms/Cubic Meter Ft. Thomas Covington
Bonita
Nilles
Wildwood
Hook Clermont Grooms Seymour/Vine Taft
Winneste W. 8th St. Kemper Rd Sherman Murray Southwest Indiana 2006 PM2.5 Monitor Data

0 10 20 30 40 50 601-Jan1-Feb1-Mar1-Apr1-May1-Jun1-Jul1-Aug1-Sep1-Oct1-Nov1-Dec1-Jan

Calendar Year 2006Micrograms/Cubic Meter Ft. Thomas Covington
Bonita
Nilles Wildwood Clermont Grooms Seymour/Vine
Taft W. 8th St. Kemper Rd. Sherman Murray

7.5 SUMMARY OF ASSOCIATION FOR SOUTHEASTERN INTEGRATED PLANNING (ASIP) MODELING FOR KENTUCKY

Kentucky is located in a different U.S. EPA re gion than Indiana. Region 4 has a separate technical support group that conducts emissions, monitoring and photochemical modeling for all

5758 the Region 4 states, including Kentucky. This group is known as the Association for Southeastern Integrated Planning (ASIP). ASIP has conducted photochemical modeling for annual fine particles, using the Community Multiscale Air Quality (CMAQ) model with their BaseG4 emissions and meteorology taken from 2002.

Modeling results for the Cincinnati-Hamilton OH-KY-IN fine particle nonattainment area show the highest modeled annual fine particle concentrations for Hamilton County, Ohio will exceed the annual fine particle NAAQS of 15.0 μg/m 3 . ASIP modeled at a 12 kilometer grid resolution and the 12 km results showed modeled values to be less than 15.0 μg/m 3 in all but one urban fine particle monitor in Hamilton County in Ohio.

Table 7.3 ASIP’s BaseG4 Annual PM 2.5 Modeling Results

Monitor ID Monitor Name County Design Value 2000-2004 Basecase 2009 12 km (μg/m3) (μg/m3) 39-017-0003 Bonita & St John Butler 16.05 14.06 39-017-0016 Nilles Rd. Butler 15.68 13.40 39-017-0017 Wilwood Butler 15.38 13.38 39-017-1004 Hook Field Airport Butler a a 39-025-0022 Clermont Dr. Clermont a a 39-061-0006 Grooms Rd. Hamilton a a 39-061-0014 Seymour & Vine St. Hamilton 17.67 15.44 39-061-0040 Howard Taft Hamilton 15.56 13.33 39-061-0041 Winneste Ave. Hamilton 15.40 13.16 39-061-0042 W. 8th St. Hamilton 17.10 14.87 39-061-0043 E. Kemper Rd. Hamilton 15.76 13.47 39-061-7001 Sherman Ave. Hamilton 16.26 14.01 39-061-8001 Murray Rd. Hamilton 17.24 15.03 21-037-0003 Fort Thomas Campbell 14.00 11.98 21-117-0007 Univ. College Kenton 14.88 12.68

a No Speciated Modeled Attainment Test data available

Further results can be found in Appendix J, which shows charts of all Ohio and Kentucky fine particle sites and the results of the BaseG4 modeling. All sites fall below the annual fine particle NAAQS with the exception of the Seymour & Vine St. fine particle monitor, which had a modeled fine particle concentration of 15.44 μg/m 3 . Decreases in concentrations from the base year design values, based on 2000-2004, to the modeled future year of 2009 were approximately 2.0 μg/m 3 . Therefore, reductions in current monitored design values would further reflect the decreasing concentrations in the future. The monitored design value ASIP used for the Seymour and Vine St. fine particle monitor, taken from 2000-2004, was 17.67 μg/m 3 , where as the current design value from 2003-2007 is 17.27 μg/m 3 . This decrease of 0.4 μg/m 3 , reflective of more59 current emissions, would provide a modeled future year design value below the annual fine particle NAAQS.

Results from the LADCO and ASIP modeling are different for a number of reasons. LADCO used the Comprehensive Air Quality Model with extension (CAMx) while ASIP used the Community Multiscale Air Quality model (CMAQ). Both models are photochemical models but have different computing algorithms. Another difference is the baseyear emissions and meteorological data modeled; LADCO mode led 2005 emissions and 2005 meteorology while ASIP modeled 2002 emissions and 2005 meteorology. Fine particle conducive conditions were evident for both years with higher fine particle readings evident in Southern Indiana in 2005.

7.6 SUMMARY OF ATTAINMENT TEST MODELING RESULTS

Indiana, in conjunction with LADCO, has performed technical analyses on the air quality in the Midwest in order to develop SIPs for areas that do not presently attain current NAAQS, including the Cincinnati area. LADCO provided th e technical support in order to conduct the air quality analyses necessary to demonstrate future-year compliance with the current annual fine particle NAAQS. Results of the attainment test for annual fine particles for the Cincinnati area show that the area will attain the current annual fine particles NAAQS by 2009, one year before the attainment date deadline of 2010. Additional analyses, using particulate sour ce apportionment (PSAT) and outputs from the Speciated Modeled Attainment Test (SMAT), show that regional, emissions sector and species contributions to fine particle concentrations overall in the Cincinnati area will be reduced in the future. Species contributions are fairly consistent between all the Cincinnati area monitors and emissions reductions will result in similar decreases in fine particle concentrations as well as species contributions to fine particle composition throughout the Cincinnati area. Sulfates are the highest contributing species of fine particles composition in the Cincinnati area and will be reduced as a result of the Clean Air Interstate Rule as well as other emissions control regulations. LADCO modeling for future year design values have shown that existing national emissions control measures will reduce fine particle concentrations in the Cincinnati area and bring the nonattainment counties into attainment of the annual NAAQS for fine particles. Emissions control measures to be implemented in the next several years, including the Clean Air Interstate Rule will help the area attain the annual standard for fine particles with modeled future year design values below 15 μg/m 3 . Future national and local emissions control strategies will ensure that each Cincinnati area county will continue to maintain the annual fine particle standard of 15.0 μg/m 3 with an increasing margin of safety over time.60 8.0 MOBILE SOURCE EMISSIONS BUDGET

The following is a summary of the detailed mobile input and output calculation files located in Appendix H.

8.1 ON-ROAD EMISSIONS ESTIMATIONS

The Ohio-Kentucky-Indiana Regional Council of Governments (OKI) is the Metropolitan Planning Organization (MPO) for the Greater Cincinnati/Northern Kentucky area which includes Dearborn County in Indiana; Butler, Clermont, Clinton, Hamilton, and Warren counties in Ohio; as well as, Boone, Campbell and Kenton counties in Kentucky. This organization maintains a travel demand forecasting model that is used to simulate the traffic in the area and to predict what traffic would be in future years given growth expectations. The model is used mostly to identify where travel capacity will be needed and to determine the infrastructure requirements necessary to meet that need. It is also used to support the calculation of mobile source emissions. The travel demand forecasting model is used to predict the total daily vehicle miles traveled (VMT) and the U.S. EPA software program referred to as MOBILE6 is used to produce emission factors to calculate the emissions per mile. The product of these two outputs, once combined, is the total amount of pollution emitted by on-road vehicles for the particular analyzed area.

8.2 OVERVIEW

Broadly described, MOBILE6 is used to determine “emissions 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 vehicle fleet (vehicles on the road) age and the vehicle-types have a major effect on the emission factors. The facility type the vehicles are traveling on (MOBILE6 facility types are Freeway, Arterial, Local and Ramp) and the vehicle speeds also affect the emission fact or values. Meteorological factors, such as air temperature and humidity, affect the emission f actors and any Vehicle Inspection/Maintenance program in the area will also affect emissions. These data are estimated using the best available data to create emission factors for direct PM 2.5 and PM 2.5 precursors including NO x and SO 2
. After emission factors are determined, the emission factor(s) must be multiplied by the VMT to determine the quantity of vehicle-related emissions. This information derives from the travel demand model.

It should be noted that each year analyzed will have different emission factors, volumes, speeds, and likely some additional links. MOBILE6 inputand output files can be found in Appendix H.

8.3 EMISSIONS ESTIMATIONS

Table 8.1 outlines the on-road emissions estimates for the entire nonattainment area, with subtotals for the Indiana and Ohio portions of the nonattainment area, for the years 2005 and 2009. The 2005 and 2009 emissions estimates are based on the actual travel demand model network for the years 2005 and 2009.61 Table 8.1 Emissions Estimations for On-Road Mobile Sources

Cincinnati NA Area Total 2005 2009 PM2.5 (tons/year) 758.54 551.82

NO x (tons/year) 43,955.54 33,851.76

Indiana and Ohio Emissions Subtotal PM2.5 (tons/year) 608.94 439.96

NO x (tons/year) 35,203.94 27,007.22

Lawrenceburg Township/IN (Emissions Subtotal) PM2.5 (tons/year) 8.84 6.12

NOx (tons/year) 497.76 359.72

Lawrenceburg Township/IN (Percent of NA Area Subtotal) PM2.5 (tons/year) 1.17% 1.11%

NO x (tons/year) 1.13% 1.06%

Table 8.2 contains the motor vehicle emissions budget (Budget) for 2009.

Table 8.2 Mobile Vehicle Emissions Budget

2009 PM 2.5 (tons/year) 461.96

NOx (tons/year) 28,357.58

Consistent with the federal implementation rule for fine particles, Indiana does not consider SO 2 from on-road mobile sources to be a significant contributor to fine particles for this nonattainment area, as they constitute below 3.5% of the area’s projected total SO 2 emissions.

This document creates a motor vehicle emission’s budget (Budget) for 2009 for the Indiana and Ohio portions of the nonattainment area that describes the maximum on-road emissions that cannot be exceeded from the year 2009 and beyond. The emission estimates are derived from62 the MPO’s travel demand model and Mobile6 as described above. A reasonable cushion has been applied to the Budget for the year 2009. Cushions are used to accommodate the impact of refined assumptions in the modeling process. With the cushion applied to the 2009 projected emissions, the 2009 Budget total PM 2.5 and NO x emissions remain well below the base year emissions for the Indiana and Ohio portions of the nonattainment area referenced in Table 8.1.

All methodologies, latest planning assumptions and the cushions were determined through the interagency consultation process.

9.0 CONTINGENCY MEASURES

Contingency measures to be considered will be selected from a comprehensive list of measures deemed appropriate and effective at the time the selection is made. Listed below are examplemeasures that may be considered. The selection of measures will be based upon costeffectiveness, emissions reduction potential, economic and social considerations or other factors that IDEM deems appropriate. IDEM will solicit input from interested and affected persons in the nonattainment area prior to selecting appropriate contingency measures. All of the listed contingency measures are potentially effectiv e or proven methods of obtaining significant reductions of fine particle precursor emissions. Because it is not possible at this time to determine what control measure will be appropriate at an unspecified time in the future, the list of contingency measures outlined below is not comprehensive. Indiana anticipates that if contingency measures should ever be necessary, it is unlikely that a significant 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 emissions offsets for new and modified major sources. 3) Require NO x 4) Increase the ratio of emissions offsets required for new sources. or SO 2 emissions offsets for new and modified minor sources.

5) Require NO x or SO 2 controls on new minor sources (less than 100 tons). 6 Wood stove change-out program. 7) Require increased recovery efficiency at sulfur recovery plants. 8) Various emissions reduction measures or dust suppressant for unpaved roads and/or parking lots. 9) Idling Restrictions. 10) Broader geographic applicability of existing measures. 11) One or more transportation control measures sufficient to achieve 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 factors listed above, after 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.63 d) Other new or innovative transportation measur es not yet in widespread use that affects state and local governments deemed appropriate.

No contingency measure shall be implemented without providing the opportunity for full public participation during which the relative costs and benefits of individual measures, at the time they are under consideration, can be fully evaluated.

10.0 PUBLIC PARTICIPATION

Indiana published notification for a public hearing and solicitation for public comment concerning the draft Attainment Demonstration Plan in the Indianapolis Star, Indianapolis, Indiana; Dearborn County Register, Lawrencebur g, Indiana; the Rising Sun Recorder, Rising Sun, Indiana; the Ohio County News, Risi ng Sun, Indiana; and, the Versailles Republican, Versailles, Indiana on or before April 4, 2008.

A public hearing to receive comments on the attainment demonstration plan was held on May 8, 2008, at the Lawrenceburg Public Library, Depot Meeting Room, 150 Mary Street, Lawrenceburg, Indiana and no comments were received. The public comment period closed on May 9, 2008. One comment letter was received during the public comment period. Appendix I includes a copy of the public notice, certifications of publication, the transcript from the public hearing, public hearing attendance record, copies of all written comments received and a summary of comments received that includes IDEM’s responses, as applicable.

11.0 CONCLUSION

Monitored air quality in the Cincinnati fine particle nonattainment area has shown steady decreases in fine particle levels as a result of national and local control strategies implemented since designation. In fact, the current design value for the nonattainment area is within 1 microgram per cubic meter of the standard. The design value in the area has dropped since 2001 and is predicted to continue to decline and achieve compliance with the standard in an expedient fashion.

This demonstration shows that NO x and SO 2 emissions reductions since designation have had a positive effect on regional fine particle levels. This attainment demonstration shows that once the photochemical modeling results are considered along with additional national, regional, and local control measures to be phased-in or implemented in 2008 and 2009, air quality in the area will achieve attainment of the fine particles standard by April 5, 2010, and provide for an ample margin of safety.

Indiana has submitted an analysis that shows the air quality improvements are due to permanent and enforceable measures and that additional significant regional NO x and SO 2 reductions following implementation of Phase II NO x SIP Call and CAIR will ensure continued compliance (maintenance) with the standard.64 This plan satisfies Indiana’s obligation under S ection 172(c) of the CAA to demonstrate how the area will attain the air quality annual standard for fine particles by the attainment date, and, as a result, realize cleaner air. The development of this plan will bring this region into compliance with state and federal fine particle air quality standards, and provide real progress in the state’s journey toward cleaner air.