INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT We ProtectHoosiers andOurEnvironment.

Michael R. Pence Govemor

SusanHedman Regional Administrator U.S. EPA, Region 5 77 West Jackson Boulevard Chicago, Illinois 60604

DearMs. Hedman: 100 N. Senate Avenue • Indianapolis, IN 46204 (800) 451-6027 • (317) 232-8603 • www.idem.IN.gov

January 13, 2015 Thomas W. Easterly Commissioner

Re: State Implementation Plan Submittal for · IndianaRegarding 326 lAC 5-1-8, AEP Rockport (LSA#12-392)

Pursuantto Section 110 ofthe CleanAirAct and Title 13 ofthe IndianaCode, the IndianaDepartmentofEnvironmental Management (IDEM) submits an amendmentto the Indiana state implementationplan (SIP). This amendment consists ofthe addition of326 lAC 5- 1-8 accomplishedthrough one rulemaking. IDEMrequests thattheUnited States Environmental ProtectionAgency (U.S. EPA) approve 326 lAC 5-1-8. This SIP revision adds TemporaryAlternative Opacity Limits (TAOL) for two units at American Electric Power (AEP) Rockportlocatedin Spencer County. Both oftheunits have continuous opacitymonitoring systems (COMS). IDEMhas providedthree parts to the Technical SupportDocumentationinAttachment 1: (1) May 19,2004Technical Support Documentfrom AmericanElectric Power (AEP) withinformation onpollutioncontrolpractices and operation and maintenanceprocedures; (2) a spreadsheetlistingthe duration (hours) of startup and shutdown opacity exceedances usedto develop the TemporaryAlternative Opacity Limit (TAOL); and (3) modeling. Thesetwo units are also subjectto the Mercury and Air Toxics (MATS) rule. OnNovember 19, 2014, U.S. EPApublishedrevisions to the MATS rule addressing startup and shutdownprovisions. The MATS rulerequires specifiedworkpractice standards during startup and shutdown. During startup, facilities are eitherrequiredto engage all controls once coal is fired anduse cleanfuels during startup, oruse clean fuels during startup to the maximum extentpossible and engagethe particulate matter control device within one hour of adding coal. The latter option applies whenfacilities are limiting startup to four hours after a unitbegins generating electricity instead ofstartup ending when any electricity is generated. Eitherwayfacilities subjectto MATS are strivingto engage their controls as soon as itis safe. This submittal consists ofone 

### (1) hard copy ofthe required documentation. An electronic version ofthe submittal inPDF format that is identicalto the hard copyhas been sent to Chris Panos at the U.S. EPARegion 5 office. In orderto assist withyour review ofthis state implementationplan submission, a list ofsuppmting documents is attached.

AnEqual Opportunity Employer 

# 0 @ RecycledPaper AStatethatWorks 

# -Throughoutthe development ofthis**rule~** staffofthe Office ofLegal Counsel worked closely withyour staffto ensure that any potentialproblemsthatmight exist withthis requested state implementationplanrevision wouldberesolved. I requestthatU.S. EPA approve this modification ofIndiana's state implementationplan. Ifyouhave any questions regarding this submittal, please contact Christine Pedersen, Rule Development Section Chief, Office ofLegal Counsel at (317) 233-5684.

NK/sb Attachments:

.Supporting Documents

cc: JohnMooney, U.S. EPARegionV (no enclosures) PamelaBlakley, U.S. EPARegionV (no enclosures) DougAburano, U.S. EPARegionV (no enclosures) Steve Rosenthal, U.S. EPA Region V (no enclosures) Christine Pedersen, IDEM (no enclosures) SIP fileSupporting Documents

Attachment A: Administrative Checklist (40 CPR 51, Appendix V) Attachment B: Final Rule. LSA Document #12-392(F) as posted in the Indiana Register on December 3, 2014 (DIN: 20141203-IR-326120392FRA) Attachment C: Signature Page Attachment D: SecondNotice ofPublic Comment Period, including the Notice ofPublic Hearing, as published in the Indiana Register on February 12, 2014 (DIN: 20120711-IR-326120392FNA) Attachment E: Certificates ofWeb Publication Attachment F: Transcript ofFirst Public Hearing held on June 11, 2014 Attachment G: Proposed Rule, including the Notice ofPublic Hearing, as published in the Indiana Register on July 30, 2014 (DIN: 20140730-IR-326120392PRA) Attachment H: Transcript ofSecond Public Hearing, including Response to Comments from Third CommentPeriod, held on September 10, 2014 Attachment I: Technical SupportADMINISTRATIVE CHECKLIST (40 CFR51, Appendix V) 1. The submittal is accompaniedby a formal letter ofsubmittal Enclosed from the governor or his designee. 2. Evidence that the State has adopted the plan in the State code Attachment C or body ofregulations; or issued the permit, order, consent agreement ("document"); in final fmm.

a. Date ofadoption or final issuance: November 6, 2014 b. The effective date ofthe plan, ifdifferent December 6, 2014 from the adoption/issuance date. 3. Evidence that the State has the necessary legal authority IC 13-14-8 under state lawto adopt and implementthe plan. 4. A copy ofthe actual regulation or document submitted for Attachment B approval and incorporation by reference into the plan, includingthe following:

a. Indication ofthe changes made to the existing approved plan, where applicable. b. The submittal shall be a copy ofthe official State regulation or document signed, stamped, dated by the appropriate state official indicatingthat it is fully enforceable bythe State. Effective date shall be stated in the document itself. 5. Evidence thatthe State followed all ofthe procedural requirements ofthe State's laws and constitution in conducting and completingthe adoption/issuance ofthe plan. Attachment C

6. Evidence that public notice was given, including date of Attachments D, E, and G proofofpublication. _x_Notice ofFirst Public Hearing and Certificates ofWeb Publication _x_Notice ofSecond Public Hearing and Certificates ofWeb Publication 7. Ce1iification that public hearings were held in accordance with informationprovided in public hearing notice. _x_Transcript from First Public Hearing _x_Transcript from Second Public Hearing 8. Compilation ofpublic comments and State'sresponse. x Second Notice _x_Proposed Rule x Third Comment Period 9. Technical Suppmi Document (ifsource specific change). Attachments F and H

Attachments D, F, G and H

Attachment IIndiana Register TITLE 326 AIR POLLUTION CONTROL DIVISION Final Rule LSA Document #12-392(F) DIGEST Adds 326 lAC 5-1-8 concerning temporary alternative opacity limitations (TAOL) for the AEP Rockport Generating Station. Effective 30 days after filing with the Publisher. HISTORY First Notice of Comment Period: July 11, 2012, Indiana Register (DIN: 20120711-IR-326120392FNA). Second Notice of Comment Period: February 12, 2014, Indiana Register (DIN: 20140212-IR-326120392SNA). Notice of First Hearing: February 12, 2014, Indiana Register (DIN: 20140212-IR-326120392PHA). Change in Notice of Public Hearing: May 7, 2014, Indiana Register (DIN: 20140507-IR-326120392CHA). Date of First Hearing: June 11, 2014. Proposed Rule: July 30, 2014, Indiana Register (DIN: 20140730-IR-326120392PRA). Notice of Second Hearing: July 30, 2014, Indiana Register (DIN: 20140730-IR-326120392PHA). Date of Second Hearing: September 10, 2014. 326 lAC 5-1-8 SECTION 1. 3261AC 5-1-81S ADDED TO READ AS FOLLOWS: 326 lAC 5-1-8 Site-specific temporary alternative opacity limitations Authority: IC 13-14-8; IC 13-17 Affected: IC 13-11 Sec. 8. In accordance with section 3(d) ofthis rule, Indiana Michigan Power Company (dba American Electric Power) Rockport Units #1 and #2, located in Spencer County, when burning fuels identified in section 3(d)(1) ofthis rule shall comply with the following temporary alternative opacity limitations: (1) When building a new fire in a boiler, opacity may exceed the applicable limitation established in section 2 ofthis rule for a period not to exceed a total oftwo (2) hours (twenty (20) six (6) minute averaging periods) during the startup period, or until the flue gas temperature reaches two hundred fifty (250) degrees Fahrenheit at the inlet ofthe electrostatic precipitators, whichever occurs first. (2) When shutting down a boiler, opacity may exceed the applicable limitation established in section 2 ofthis rule once the flue gas temperature has dropped below two hundred fifty (250) degrees Fahrenheit at the inlet ofthe electrostatic precipitators for a period not to exceed a total of one and one-half (1.5) hours (fifteen (15) six (6) minute averaging periods) during the shutdown period. (Air Pollution Control Division; 3261AC 5-1-B; filed Nov 6, 2014, 10:00 a.m.: 20141203-IR-326120392FRA)

LSA Document #12-392(F) Proposed Rule: 20140730-IR-326120392PRA Hearing Held: September 10, 2014 ApprovedbyAttorney General: October24, 2014 Approvedby Governor: November5, 2014 Filed with Publisher: November6, 2014, 10:00 a.m. Documents IncorporatedbyReference: None Received byPublisher Small Business Regulatory Coordinator: Jessica Faust-Hamblin, IDEM Small Business Regulator Coordinator, MC 60-041GCS W041, 402 West Washington Street, Indianapolis, IN 46204-2251, (317) 232-B172 or(BOO) 9BB-7901, ctap@idem.in.gov · Small Business Assistance Program Ombudsman: Steven N. Howell, IDEM Small Business Assistance Program Ombudsman, MC 50-011GCN 1301, 100 North Senate Avenue, Indianapolis, IN 46204-2251, (317) 232-B5B7 or (BOO) 451-6027, snhowell@idem.in.gov Posted: 12103/2014 byLegislative Services Agency An html version ofthis document.

Date: Dec 08,2014 10:58:27AM EST DIN: 20141203-IR-326120392FRA Page 1

# Rule SignaturePage

Rule#: Agency: Subject: ADOPTED: LSA Document#12-392(F) EnvironmentalRules Board Rockport TAOL

# By:d~-~ BeverlyJ. Gard Chairperson, EnvironmentalRules Board

APPROVED:

Governor, State ofIndiana

ACCEPTED FORFILING: By: TITLE 326 AIRPOllUTION CON1ROL DIVISION LSADocument#12-392(FR) Filed withPublisher: November 6, 2014, 10:00 a.m. By: Rlw

# Datc:~'l

ate:Indiana Register TITLE 326 AIR POLLUTION CONTROL DIVISION SECOND NOTICE OF COMMENT PERIOD LSA Document #12-392 TEMPORARY ALTERNATIVE OPACITY LIMITATIONS AT AEP ROCKPORT GENERATING STATION PURPOSE OF NOTICE The Indiana Department of Environmental Management (IDEM) has developed draft rule language for a new rule at 326 lAC 5-1-8 concerning temporary alternative opacity limitations (TAOL) for the AEP Rockport Generating Station. By this notice, IDEM is soliciting public comment on the draft rule language. IDEM seeks comment on the affected citations listed and any other provisions ofTitle 326 that may be affected by this rulemaking. HISTORY First Notice of Comment Period: July 11, 2012, Indiana Register (DIN: 20120711-IR-326120392FNA). CITATIONS AFFECTED: 326 lAC 5-1-8. AUTHORITY: IC 13-14-8; IC 13-17-3-4; IC 13-17-3-11. SUBJECT MATTER AND BASIC PURPOSE OF RULEMAKING Basic Purpose and Background Indiana Michigan Power Company (dba American Electric Power (AEP)) operates a coal-fired electric generating station in Rockport (Spencer County), Indiana, consisting oftwo units, boiler Units #1 and #2. Both of these units are subject to the New Source Performance Standard (NSPS) for Fossil-Fuel-Fired Steam Generators. Since the NSPS does not apply emission limits during startup and shutdown, the opacity limit at 326 lAC 5-1-2 applies to these units during startup and shutdown. State rules at 326 lAC 5-1-2 require a 40% opacity limit for any six minute averaging period. When building a new fire in a boiler, or shutting down a boiler, opacity is limited to 60% for any six minute averaging period for not more than two six minute averaging periods in 24 hours (326 lAC 5-1-3(a)). Historically, boilers that use fuel oil as a startup fuel and have an electrostatic precipitator (ESP) as a control device have trouble meeting an opacity limit until the exhaust gases have reached a certain temperature. The ESP cannot be safely engaged until the control device has reached an appropriate temperature. To address this issue, IDEM amended 326 lAC 5-1-3 in 1998 by adding a new subsection (e) to allow sources that had existing startup and shutdown conditions in their construction or operating permits to be exempt from the opacity limit until the exhaust gases achieved a temperature of250 degrees Fahrenheit at the inlet ofthe baghouses or ESP. The United States Environmental Protection Agency (U.S. EPA) approved this new exemption provision, along with a process for other sources to obtain temporary alternative opacity limitations, into Indiana's State Implementation Plan (SIP) on July 16, 2002. U.S. EPA approved the limited exemption from opacity limits in 326 lAC 5-1-3(e) based on a modeling analysis assessing the worst-case impact showing that the exemption would notjeopardize continued attainment ofthe particulate matter air quality standard (PM 10). AEP Rockport's units did not have preexisting opacity exemptions in their permits at that time, and therefore, are not part ofthe limited exemption in 326 lAC 3-5-1(e). Indiana's opacity rules at 326 lAC 5-1-3(d) allow a source to request a TAOL for periods of startup or shutdown of a boiler. AEP has requested a TAOL for both boilers (Units #1 and #2) at its Rockport Generating Station. IDEM is proposing a TAOL that limits the exemption during startup to 2 hours (1.5 hours for shutdown) or until the flue gas temperature reaches 250 degrees Fahrenheit, whichever occurs first. The proposed TAOL is similar to what the source has proposed in an appeal ofthe Title V permit. IDEM has conducted modeling that indicates the TAOL would not impact maintenance of air quality standards. Spencer County was recently**de~i~nated** as attainment for fine particulate matter (PM2.5). The TAOL will be submitted to U.S. EPA as a SIP reVISIOn. IC 13-14-9-41dentification of Restrictions and Requirements Not Imposed under Federal Law No element ofthe draft rule imposes either a restriction or a requirement on persons to whom the draft rule applies that is not imposed under federal law. The opacity limits in the federal NSPS do not apply during startup and shutdown, and instead the opacity limits at 326 lAC 5-1-2(1) and 326 lAC 5-1-3(a) and 326 lAC 5-1-3(b) apply during startup and shutdown. The proposed TAOL will provide an alternative compliance option to those limits currently imposed under state law for the AEP Rockport Generating Station. The new TAOL will be imposed under federal law once it is approved by U.S. EPA into the Indiana SIP. Potential Fiscal Impact There is no cost associated with this rulemaking. The alternative opacity limits will allow the two units at AEP Rockport Generating Station to comply with opacity limits similar to units at other power plants that are already

Date: Dec 30,2014 9:16:14AM EST DIN: 20140212-IR-326120392SNA Page 1Indiana Register allowed to use similar limits under current state law. Public Participation and Work Group Information At this time, no work group is planned for the rulemaking. Ifyou feel that a work group or other informal discussion on the rule is appropriate, please contact Susan Bern, Rules Development Branch, Office of Legal Counsel at (317) 233-5697 or (800) 451-6021 (in Indiana). SUMMARY/RESPONSE TO COMMENTS FROM THE FIRST COMMENT PERIOD IDEM requested public comment from July 11, 2012, through August 10, 2012, on alternative ways to achieve the purpose ofthe rule and suggestions for the development of draft rule language. IDEM received comments from the following parties by the comment period deadline: Indiana Michigan Power Company/American Electric Power (AEP) Following is a summary ofthe comments received and IDEM's responses thereto: Comment: The commenter appreciates the opportunity to comment on the potential development of specific rule language for the Rockport Plant TAOL that has been requested as part ofthe initial Title V permit issued to the source. Since that time the Title V permit opacity provision containing the TAOL has been under appeal and Indiana Michigan Power has been working with IDEM to develop permit language acceptable to both parties as part ofthe settlement ofthe larger permit appeal. IDEM has not previously incorporated any TAOLs for startup and shutdown, as is contemplated by the TAOL being developed for Rockport. The TAOL language in 326 lAC 5- 1-3(e) does not appear to require incorporation into 326 lAC 5, just U.S. EPA approval as a SIP revision. In working with the Office ofAir Quality (OAQ) Permits Branch to resolve the overall Title V appeal, it has been the commenter's understanding that the TAOL would be submitted to U.S. EPA without any rulemaking being necessary. (AEP) Response: In order for U.S. EPA to approve the TAOL into the SIP it needs to be permanent and enforceable. Adding the TAOL to 326 lAC 5-1 will provide a mechanism for IDEM to submit the TAOL to U.S. EPA for SIP approval. Comment: If IDEM incorporates the TAOL into rule language, IDEM should use the current version ofthe TAOL language from settlement negotiations. The rule should not be finalized until such time as the permit appeal is settled. (AEP) Response: IDEM agrees and has used the draft settlement language supplied by the commenter in the draft rule. The shutdown language specifies that the shutdown period begins when the flue gas temperature has dropped below 250 degrees Fahrenheit. U.S. EPA does not consider it appropriate to allow the shutdown TAOL if the exhaust temperature exceeds 250 degrees Fahrenheit. IDEM will hold off on finalizing the rule until the appeal is final. IDEM is also working with U.S. EPA to ensure that the TAOL will be approved into the SIP. One ofthe requirements of 326 lAC 5-1-3(d) is that the source demonstrates that during periods of startup and shutdown the TAOL will not impact the maintenance ofthe National Ambient Air Quality Standards (NAAQS). Modeling conducted by IOEM indicates that the proposed TAOL will not impact the maintenance ofthe NAAQS. REQUEST FOR PUBLIC COMMENTS This notice requests the submission of comments on the draft rule language, including suggestions for specific revisions to language to be contained in the draft rule. Comments may be submitted in one ofthe following ways: (1) By mail or common carrier to the following address:

LSA Document #12-392 Opacity TAOL Susan Bern Rules Development Branch Office of Legal Counsel Indiana Department of Environmental Management Indiana Government Center North 100 North Senate Avenue Mail Code 61-49 Indianapolis, IN 46204-2251 (2) By facsimile to (317) 233-5970. Please confirm the timely receipt offaxed comments by calling the Rules Development Branch at (317) 233-8903. (3) By electronic mail to sbem@idem.in.gov. To confirm timely delivery ofsubmitted comments, please request a document receipt when sending the electronic mail. PLEASE NOTE: Electronic mail comments will NOT be considered part ofthe official written comment period unless they are sent to the email address indicated in this notice. (4) Hand delivered to the receptionist on duty at the thirteenth floor reception desk, Office of Legal Counsel, Indiana Government Center North, 100 North Senate Avenue, Indianapolis, Indiana. Regardless ofthe delivery method used, in order to properly identify each comment with the rulemaking action it is intended to address, each comment document must clearly specify the LSA document number ofthe

Date: Dec 30,2014 9:16:14AM EST DIN: 20140212-IR-326120392SNA Page 2Indiana Register rulemaking. COMMENT PERIOD DEADLINE All comments must be postmarked, faxed, or time stamped not later than March 14, 2014. Hand-delivered comments must be delivered to the appropriate office by 4:45 p.m. on the above-listed deadline date. Additional information regarding this action may be obtained from Susan Bem, Rules Development Branch, Office of Legal Counsel, (317) 233-5697 or (800) 451-6027 (in Indiana). DRAFT RULE SECTION 1. 326 lAC 5-1-8 IS ADDED TO READ AS FOLLOWS: 326 lAC 5-1-8 Site-specific temporary alternative opacity limitations Authority: IC 13-14-8; IC 13-17 Affected: IC 13-11 Sec. 8. In accordance with section 3(d) ofthis rule, Indiana Michigan Power Company (dba American Electric Power) Rockport Units #1 and #2, located in Spencer County, when burning fuels identified in section 3(d)(1) ofthis rule, shall comply with the following temporary alternative opacity limitations: (1) When building a new fire in a boiler, opacity may exceed the applicable limitation established in section 2 ofthis rule for a period not to exceed a total oftwo (2) hours (twenty (20) six (6) minute averaging periods) during the startup period, or until the flue gas temperature reaches two hundred fifty (250) degrees Fahrenheit atthe inlet ofthe electrostatic precipitators, whichever occurs first. (2) When shutting down a boiler, opacity may exceed the applicable limitation established in section 2 ofthis rule once the flue gas temperature has dropped belowtwo hundred fifty (250) degrees Fahrenheit at the inlet ofthe electrostatic precipitators for a period not to exceed a total ofone and one-half (1.5) hours (fifteen (15) six (6) minute averaging periods) during the shutdown period. (Air Pollution Control Division; 3261AC 5-1-8)

Notice of Public Hearing

Posted: 02/12/2014 byLegislative Services Agency An html version ofthis document.

Date: Dec 30,2014 9:16:14AM EST DIN: 20140212-IR-326120392SNA Page 3Indiana Register TITLE 326 AIR POLLUTION CONTROL DIVISION Change in Notice of Public Hearing LSA Document #12-392 The Air Pollution Control Division gives notice that the date ofthe public hearing for LSA Document #12-392, posted at 20140212-IR-326120392SNA, has been changed. The changed Notice of Public Hearing appears below: Notice ofPublic Hearing UnderIC 4-22-2-24. IC 13-14-8-6, and IC 13-14-9, notice is herebygiven that on June 11, 2014, at 1:30 p.m., at the Indiana Government CenterSouth, 302 West Washington Street, Conference CenterRoom A, Indianapolis, Indiana, the Environmental Rules Board will holda public hearing on amendments to 326 lAC 5-1 concerning temporary alternative opacitylimitations (TAOL) for the AEP Rockport Generating Station. The purpose ofthis hearing is to receive comments from the publicpriorto preliminaryadoption ofthese rules by the board. All interestedpersons are invited and will be given reasonable opportunity to express their views concerning the proposedamendments. Oralstatements will be heard, but, for the accuracy ofthe record, all comments should be submitted in writing. Additional information regarding this action maybe obtained from Susan Bem, Rules Development Branch, Office ofLegal Counsel, (317) 233-5697 or (800) 451-6027 (in Indiana). Individuals requiring reasonable accommodations forparticipation in this event should contact the Indiana Department ofEnvironmental Management, Americans with Disabilities Actcoordinatorat: Attn: ADA Coordinator Indiana Department ofEnvironmental Management Indiana Government CenterNorth 100 North Senate Avenue Indianapolis, IN 46204-2251 orcall (317) 233-1785 (V). Speech and hearing impaired callers may contact IDEM via the Indiana Relay Service (711) or(BOO) 743-3333. Please provide a minimum of72 hours notification. Copies ofthese rules are now on file at the Rules Development Branch, Office ofLegal Counsel, Indiana Department ofEnvironmental Management, Indiana Government CenterNorth, 100 North Senate Avenue, Thirteenth Floorand Legislative Services Agency, Indiana Government CenterNorth, 100 North Senate Avenue, Room N201, Indianapolis, Indiana andare open forpublic inspection. Nancy King, Chief Rules Development Branch Office of Legal Counsel

Posted: 05/0712014 by Legislative Services Agency An html version ofthis document.

Date: Dec 30,2014 9:22:51AM EST DIN: 20140507-IR-326120392CHA Page 1INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT We ProtectHoosiers and OurEnvironment. 100 N. Senate Avenue • Indianapolis, IN 46204 (800) 451-6027 • (317) 232-8603 • www.idem.IN.gov Michael R. Pence Governor Thomas W. Easterly Commissioner May2, 2014



### CERTIFICATE OFPUBLICATION This is to certifythatthe IndianaDepartment ofEnvironmental Management (IDEM) Notice of Public Hearings for the Environmental Rules BoardMeeting, 06/11/2014, regardingthe following rulemaking actions:

• Global WarmingPotentials Table Update, LSA#14-56 • Rockport Temporary Alternative Opacity Limit, LSA#12-392

was published onIDEM's web site onorbefore May 5, 2014. Itwill remainposted onthe site until at least June 11, 2014. The notice infull maybe found atthe following web address, underthe "Statewide" category. http://www.in.gov/idem/6777.htm Web publication ofthe notice was atthe request ofChristine Pedersen, Section Chief, Rule Development Section, Office ofLegal Counsel, IDEM.

Attachments: Copy ofweb page as published.

AnEqual Opportunity Employer By:

Mike Finkelstein IDEMWebmaster 

# 0

AStatethatWorks 

# - @ RecycledPaperTextFir.:!aPeroonAccountCenterOnlineSerd::ecFMcHelp.'.-6A+GOVERNORrv1IKEPENCEIN.govAbomlncltana1ftIDEMHomeAboute-ServicesFeaturedToj)icsNewsandEventsPublicNoticesFac:tSheets-----------------------Formsl·AapsRulesContacrInformationAboutYDurEnviiDmnentAirQuaiii}rAirTDxicsPmgramBlue-GreenAl•gaeCleanWa<erlnIndianaCommuni.tyEl'lvimnmentalHealth·---CTAP:ComplianceandTechnicalAssistanceProgram.IDHilSearch----------------------------PUBUCNOTOOCES:STATEWIDETl1isistileIDEMPublict-IGti·DeSiteiornoticesco.veringtheentireStateofIndiana.Tl1ispag;epuhlicnoticesasrequir•erlbystaruteorruleincludling::permitting,rulmtaiking.meeting:amiinformationrelatedtothenmice.Forpuhlitnotrequiring!.I1Dtices,pleasecll!?C!::th!?Sub-Scriptions:Wanttolcrlowabo•ut.asaslhey'-rej:losteci?Yollcanno-wregioo,youwillbesentane-mailortexrrmessa:g;gto.yo•urphoneeJterytimelnEMadds.allaminevermissanewposting.Tosubscribe,clicl:ontil!!subscriptionlinkintheStatewideTfpeofHoticetEl'entfiROFlIROFl,-Date----I12014fl3145 6 7 8 9101u12 131415 16 1718 19202122 232425 2627 28 293031Currenttimezone:EasternDaylightTime)•I111:32:37Arv1lt;JAppl\·'. LegalNotice ofPublic Hearing Under40 CFR51.102, notice is hereby given thattheEnvironmentalRules Board (board) will hold a public hearing at itsregularly scheduledmeeting onWednesday, June 11, 2014, for each ofthe airprogramrules listed inthis notice. Themeeting willconvene at 1:30p.m. atthe Indiana Government Center-South, Conference RoomA, 302 WestWashington Street, Indianapolis, Indiana. Thepurpose ofthe hearing is to receivepublic commentspriorto board action. All interestedpersons are invited and willbe given a reasonable opportunityto express theirviews concerningtheproposed action. Board documents maybe viewed and downloaded from the IndianaDepartment of EnvironmentalManagement's Web site as early as one weekpriorto the meeting·at http://www.in.gov/idem/4696.htm. Copies oftheproposed airprogramrules are also availableto any personupon

### r~quest, maybe viewed online viathe Internetfrom local libraries, and are available forpublic inspection at the following locations: IndianaDepartment ofEnvironmentalManagement, Office ofLegal Counsel, Indiana Government Center-North, 100 Nmih Senate Avenue, 13thFloor, Indianapolis,Indiana 46204. IndianaDepartment ofEnvironmentalManagement, Northwest Office, 330 WestUS Highway 30, Suites E andF,Valparaiso, IN46385. IndianaDepartment ofEnvironmentalManagement, Nmihern Office, Suite 450, 300N. Michigan Street, SouthBend, Indiana46601. IndianaDepartment ofEnvironmentalManagement, SouthwestOffice, 1120 North Vincennes Avenue, P.O. Box 128, Petersburg, Indiana47567-0128. IndianaDepartmentofEnvironmentalManagement, Southeast Office, 820 West Sweet Street, Brownstown, Indiana47220-9557. Legislative Services Agency, Indiana Government Center-North, 100North Senate Avenue, RoomN201, Indianapolis, Indiana46204. The following airprogramrules are noticedfor hearing and action: Global Warming Potentials TableUpdate (LSA# 14-56). Thepurpose ofthis hearing is to. receivepublic commentpriorto adoption ofamendments to 326 lAC 2-2-1 and 326 IAC 2-7-1 concerningrevisions to the global warmingpotentialstable for consistencywithfederal requirements andto streamlinethe development ofPrevention ofSignificantDeterioration (PSD) andTitleV airpermits. Thisrule will be submittedto the United States Environmental ProtectionAgency as a revisionto the State ImplementationPlanrequiredbythe Clean Air Act. A copy ofthe mostrecentlypublishedversion ofthisrule is available at: http://Www.in.gov/idem/5679.htm. Foradditional mformation concerningthis rule contact SusanBern atthe Indiana Depa1iment ofEnvironmentalManagement, Office ofLegal Counsel, Indiana Government CenterNorth, 100NorthSenateAvenue, Indianapolis at (317) 233-5697 or (800) 451-6027 (ext. 3-5697)(inIndiana), or sbem@idem.in.gov.Rockport Temporary Alternative Opacity Limit (LSA# 12-392). The purpose ofthis hearingis to receivepublic commentpriorto adoption ofa newrule at 326 lAC 5-1-8 concerningtemporary alternative opacity limitations (TAOL) for theAEP Rockport Generating Station. This rule will be submittedto the United States Environmental ProtectionAgency as a revisionto the State ImplementationPlanrequired bythe CleanAirAct. A copy ofthe most recentlypublished version ofthisrule is available at: http://www.in.gov/idem/5679.htm. Foradditional information concemingthis rule contact SusanBern attheIndiana Department ofEnvironnientalManagement, Office ofLegalCounsel, Indiana Government CenterNorth, 100Nmih Senate Avenue, Indianapolis at (317) 233-5697 or (800) 451-6027 (ext. 3-5697)(inIndiana), or sbem@idem.in.gov.

. Forthese hearings, oral statements will beheard, butfor the accuracy ofthe record, please submit statements inwritingto the attendant designatedto receive written comments at the publichearings. A transcript ofthe hearings and allwritten submissions to the board atthepublicheadngs shall be opento public inspection atthe IndianaDepatimentofEnvironmentalManagement; copies maybemade available to anypersonuponpayment ofreproduction costs. Any person heard orrepresented atthehearings orrequestingnotice shall be givenwrittennotice ofthe actions ofthe board. · ChristinePedersen, Chief Rules Development Section Office ofLegal Counsel********************************************************************~************* Individualsrequiring reasonable accommodations for participation inthis event should contact theIndianaDepartment ofEnvironmental Management, Americans withDisabilitiesAct· coordinator at: Attn: ADA Coordinator IndianaDepatimentofEnvironmentalManagement 100N. SenateAvenue· Indianapolis, IN46204.

or call (317) 233-1785. Speech andhearing impaired callers may contactthe agency viathe IndianaRelay Service at 1-800-743-3333. Pleaseprovide aminimum of72hours' notification.INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT We ProtectHoosiers andOurEnvironment. 100 N. Senate Avenue • Indianapolis, IN 46204 (800) 451-6027 • (317) 232-8603 • www.idem.IN.gov Michael R. Pence Governor Thomas W. Easterly Commissioner July 31,2014



### CERTIFICATE OFPUBLICATION This is to certify thatthe IndianaDepartment ofEnvironmental Management (IDEM) Notice of Public Hearings for the Environmental Rules BoardMeeting, 09/10/2014, regarding the following rulemaking actions:

• Rockport Temporary Alternative Opacity Limit, LSA#12-392 • Stage II VaporRecovery Systems, LSA#12-636

was published onIDEM's web site on orbefore August 1, 2014. Itwill remainposted on the site until at least September 10,2014. Thenotice infull maybe found atthe following web address, underthe "Statewide" category. http:/ /www.in.gov /idem/6777.htm Web publication ofthe notice was at the request ofChristine Pedersen, Section Chief, Rule Development Section, Office ofLegal Counsel, IDEM.

Attachments: Copy ofweb page as published.

AnEqual Opporhmity Employer By:

Mike Finkelstein IDEMWebmaster

AState**that~** @ RecycledPaperFindant-.g:n·:;yFln:laPer::onAo::ourttO:-nte:lOnli():;'ier\•l:e:::FAO::A·6A+GOVERNORMIKEPENCEINgovAboutIndianaAgrtculture&EnvironmentHomeA!Joute-ser1icesFea!UredTopicsNewsandEventsPublicNoticesFactSheetsFDrmsMapsRulesContactInformationAboutYourEnvironmentAirQualityAlrToxicsProgramBlue-GreenAlgaeCommunityEnvJronmemalHealthCTAP:complianceandTechnicalAssistanceProgramEnvironmentalCleanupEnvironmentalEducationEnvironmentalJusticeHoosierRfverNatchforPollutionPreventionn...u.........n...-....-...;.....Business&EmploymentEducation&TrainingFamily&HealthPublicNotices:StatewideLaw&JusticeSearellPublicSafetyTaxes&FinanceThisistheIDEMPublicNoticeSitefornoticescoveringtheentireStateofIndiana.Thispage··publicaccesstoallagencystate-widepublicnoticesasrequiredbystatuteorruleincluding:rulemaking,meetingandhearingnotices.ClickhighlightedlinkstoviewadditionalForpublicmeetingsnotrequiringnotices,pleasechecktheIDEMCalendar.Subscriptions:Wanttoknownewnoticesassoonasthey'reposted?Youcannowsubpublicnoticepage.Bysubscribingtoaregion,youwillbesentane-mailortextmessageioIDEMaddsinfo.rmationtothisregionalpage.Thisallowsyouto.staycurrentonallpostingposting.Tosubscribe,clickonthesubscriptionlinkinthelefthandcolumn.Tourism&Transp011ation,.-Date..-Time----)(to:34:30AMItoK!ApplyLegalNotice ofPublic Hearing Under 40 CFR 51.102, notice is hereby giventhatthe Environmental Rules Board (board) will hold a public hearing at its regularly scheduledmeeting on Wednesday, September 10, 2014, for each ofthe air programrules listed inthis notice. The meeting will convene at 1:30 p.m. atthe Indiana Government Center-South, Conference RoomA, 302 West Washington Street, Indianapolis, Indiana. The purpose ofthe hearing is to receivepublic comments priorto board action. All interestedpersons are invited and will be given a reasonable opportunityto express their views concerningthe proposed action. Board documents maybe viewed and downloaded from the IndianaDepartment of Environmental Management's Web site as early as one weekpriorto themeeting at http:/ /www.in.gov/idem/4696.htm. · Copies oftheproposed air programrules are also available to any personuponrequest, maybe viewed online viathe Internetfrom local libraries, and are available for public inspection at the following locations: IndianaDepartment ofEnvironmental Management, Office ofLegal Counsel, Indiana GovernmentCenter-North, 100North SenateAvenue, 13thFloor, Indianapolis, Indiana46204. IndianaDepartmentofEnvironmental Management, Northwest Office, 330 WestUS Highway 30, Suites E andF, Valparaiso, IN46385. IndianaDepartment ofEnvironmental Management, Northern Office, Suite 450, 300N. Michigan Street, SouthBend, Indiana46601. IndianaDepartmentofEnvironmental**M~nagement,** Southwest Office, 1120North Vincennes Avenue, P.O. Box 128, Petersburg, Indiana 47567-0128. IndianaDepartment ofEnvironmental Management, Southeast Office, 820 West Sweet Street, Brownstown, indiana 47220-9557. Legislative Services Agency, IndianaGovernment Center-North, 100North Senate Avenue, RoomN201, Indianapolis, Indiana46204. The following air programrules are noticed for hearing and action: RockportTemporary Alternative OpacityLimit (LSA# 12-392). The purpose ofthis hearing is to receive public commentpriorto final adoption ofa newrule at 326 lAC 5-1-8 concerning temporary alternative opacity limitations (TAOL) for the AEP Rockport Generating Station. This rulewill be submittedto the United States Environmental ProtectionAgency as a revision to the State ImplementationPlanrequired bythe CleanAirAct. A copy ofthemostrecently published version ofthis rule is available at: http://www.in.gov/idem/5679.htm. For additional information concerningthis rule contact SusanBern atthe Indiana Department ofEnvironmental Management, Office ofLegal Counsel, Indiana Government Center Nmih, 100Nmih Senate Avenue, Indianapolis at (317) 233-5697 or (800) 451-6027 (ext. 3-5697)(inIndiana), or sbem@idem.in.gov. StageIIVaporRecovery Systems. (LSA # 12-636). The purpose ofthis hearing is to receive public commentpriorto preliminary adoption ofamendments to 326 lAC 2-11-2, 326 lAC 8-4-1, and 326 lAC 8-4-6 concerning revisions to stage II vaporrecovery systemrequirements for consistency withU.S. EPA's determination that on board refueling vapor recovery technology is inwidespread use andthat stage II vaporrecovery systems are no longerrequired in certain ozone nonattainment areas as long as the National AmbientAir Quality Standards for ozone are met. This rule will be submittedto the United States Environmental ProtectionAgency as a i'evision to the State ImplementationPlanrequired bythe Clean Air Act. A copy ofthe most recently publishedversion ofthisrule is available at: http://www.in.gov/idern/5679.htm. For additional infmmation concerning this rule contact Christine Pedersen at the Indiana Department ofEnvironmental Management, Office ofLegal Counsel, Indiana Government CenterNorth, 100 Nmih Senate Avenue, Indianapolis at (317) 233-5684 or (800) 451-6027 (ext. 3-5684)(inIndiana), or cpederse@idem.in.gov. Forthese hearings, oral statements will be heard, but for the accuracy ofthe record,

. please submit statements inwritingto the attendant designated to receive written comments at the public hearings.

. A transcript ofthe hearings and all written submissions to the board atthe public hearings shall be opento public inspection atthe IndianaDepmiment ofEnvironmental Management; copies maybe made available to any personuponpayment ofreproduction costs. Anyperson heard orrepresented atthe hearings orrequesting notice shall be given written notice ofthe actions oftheboard. Christine Pedersen, Chief Rules Development Section Office ofLegal Counsel 

### ****************************************************************************** Individuals requiringreasonable accommodations for pmiicipationinthis event should contact the IndianaDepmiment ofEnvironmental Management, Americans withDisabilities Act coordinator at: Attn: ADACoordinator IndianaDepatiment ofEnvironmental Management 100 N. SenateAvenue Indianapolis, IN 46204

or call (317) 233-1785. Speech andhearing impaired callers maycontactthe agency viathe IndianaRelay Service at 1-800-743-3333. Pleaseprovide a minimum of72 hours' notification.. 

### ) 1 2 3 4 5 6 ·7

8 9 

### 10 11 

### 12 13 14 

### 15 INDIANA ENVIRONMENTAL RULES BOARD INDIANA GOVERNMENT CENTER SOUTH 302 WEST WASHINGTON STREET INDIANAPOLIS, INDIANA JUNE 11, 2014

- 1:30 P.M.

MEMBERS PRESENT:

Chair William Etzler-Small Business Ken Rulon-Agriculture Gail Boydston-Manufacturing Tom R. Anderson-Environmental Interests Chris Horn-Labor Gary Powdrill-General Public Ted Niemiec-MBdical Kelly Carmichael-Public Utility Joanne Alexandrovich-Local Government Cal Davidson-Solid Waste Management David Bausman, Lt. Governor Proxy for ISDA Mike Mettler-ISDH Proxy. Cameron Clark-Director of IDNR Kent Abernathy-,for IDEM Commissioner

The meeting was held on the 11th day of JUNE, 16 2014, at 1:30 p.m. at the Indiana Government Center 17 South, Conference Room A,**.~ndianapolis,** 

### Indiana, and 18 reported by me, Marjorie A. Addington, Notary Public 19 in and for the County of Hamilton, State of Indiana; 20 CM, CSR: KS. 21 22 

### 23 24 25 ACCURATE REPORTING OF INDIANA William F. Daniels Prop. RPR/CP CM 12922 Brighton Avenue Carmel, Indiana '46032 (317) 848-0088 

### 1

### 1 2 3 4 5 

### 6 7 8 9 10 11 12 ) 

### 13 14 15 16 17 18 19 20 21 22 23 24 

### 25 CHAIRMAN ETZLER: Good afternoon, it's 1:30 and we'll call the June meeting of the Environmental Rules Board to order. We have a quorum present. Are there any additions or changes to the agenda? (No response.) CHAIRMAN ETZLER: Okay. L'd ask each of the board members to introdtice yourselves and what segment you represent,**please~** 

### KENT ABERNATHY: I'm Kent Abernathy, I'm here for Commissioner Tom Easterly. Staff of IDEM. I'm the Chief of

DAVID BAUSMAN: .David Bausman, Director of Policy and Regulatory Affairs, the Indiana State Department of Agriculture, serve as Lt. Governor's proxy. MIKE METTLER: I'm Mike Mettler, I'm proxy £or the State Health Commissioner, Dr. VanNess. CHRIS HORN: My name's Chris Horn and I represent labor. GAIL BOYDSTON: Gail Boydston representing manufacturing. KEN RULON: Ken Rulon representing agriculture. CHAIRMAN ETZLER: Bill Etzler, small business. 2

### 1 2 3 4 5 6 7 8 9 

### 10 11 12 13 14 15 16 17 18 19 20 21 22 .23 

## ) 24 25 TOM ANDERSON: Tom Anderson, environment. GARY POWDRILL: Gary Powdrill, the community at large. TED NIEMIEC: Ted Niemiec representing health

care. JOANNE ALEXANDROVICH: Joanne Alexandrovich, local government. KELLY CARMICHAEL: representing utilities. I'm Kelly Carmichael

CHAIRMAN ETZLER: Thank you. Our first order of business is the approval of the April 9th, 2014 Board Meeting Summary. Are there**~ny** 

### additions or corrections? (No response.) TOM ANDERSON: Move for approval. GARY POWDRILL: Second. CHAIRMAN ETZLER: We have a motion on the second? Those in favor say "aye." (All respond "aye.") CHAIRMAN ETZLER: Those opp<;:>sed say "aye." (No response.) CHAIRMAN .ETZLER: Motion is carried. reports. Mr. Abernathy. IDEM

KENT ABERNATHY: Thank you, Mr. Chairman. Again, I'm Ken Abernathy, Chief of Staff of IDEM and 3

# )

) 1 2 3 

### 4 5 

### 6 

### 7 8 9 

### CHAIRMAN ETZLER: Dr. Alexandrovich. JOANNE ALEXANDROVICH: Yes. CHAIRMAN ETZLER: Dr. Niemiec. TED NIEMIEC: Yes. CHAIRMAN ETZLER: Mr. Powdrill. GARY POWDRILL: Yes. CHAIRMAN ETZLER: Mr. Anderson. TOM ANDERSON: Yes. CHAIRMAN ETZLER: Mr. Etzler votes yes. Ms. 10 Boydston? 11 GAIL BOYDSTON: Yes. 12 CHAIRMAN ETZLER: Mr. Horn. 13 

## 14 15 16 

### 17 18 

### 19 20 

### CHRIS HORN: Yes. CHAIRMAN ETZLER: Mr. Mettler. MIKE METTLER: Yes. CHAIRMAN ETZLER: Mr. Bausman. DAVID BAUSMAN: Yes. CHAIRMAN ETZLER: Mr. Davidson. CALVIN DAVIDSON: Yes. CHAIRMAN ETZLER: Mr. Clark. 21 CAMERON CLARK: Aye. 22 CHAIRMAN ETZLER: The motion is approved 13 24

23 to zero to finally adopt the amendments to the Global 24 25 

### Warming Potentials Table. Next on the agenda is a public hearing

# )



# ) 1 2 3 

### 4 5 

### before the Environmental Rules Board of the State of Indiana concerning preliminary adoption of new rules at 326 IAC 5, the Rockport Generating Station Temporary Alternative Opacity Limit. I will now 25



### introduce Exhibit D, the draft rules, into the record 6 of the hearing. Is there someone from the Board to 7 present the rule? Ms. Pedersen has extraordinary 8 duties today

.

.g 

### CHRIS PEDERSEN: Yeah. Again, my name· is 10 

### Chris Pedersen of the Rules Development Branch. This 11 rulemaking is for Rockport Power Plant, a coal-fired 12. 13 

### 14 15 16 

### 17 18 19 20 

### 21 22 

### 23 24 25 

### electric generating station in Spencer County that is operated by Indiana Michigan Power, a branch of American Electric Power. The company has requested a temporary alternative opacity limit during periods of startup and shutdown for its boilers. Opacity is used as· a

measure of particulate matter emissions and Spencer County is designated as attainment for fine particulate matter PM2.5. Boiler units 1 and 2 at Rockport are subject to the New Source Performance Standard for fossil fuel fired**stea~** 

### generators. The New Source Performance·Standard does not apply during startup and shutdown. However, the opacity limits in the

### 26

1 state +ule at 326 IAC 5-1-2 apply at all times, so 2 the more stringent New Source Performance Standards 3 would apply during their routine operations and then 4 the state opacity rules would apply during startup 5 and shutdown. 6 The opacity rules at 326 IAC.5-1-2 include a 7 40 percent opacity limit for any six-minute averaging 8 

### period. Historically, boilers that use fuel oil as a 9 startup**fu~l** 

### and have an electrostatic precipitator 10 as a control device have trouble meeting an opacity 11 limit until the exhaust gases have reached a certain 12 temperature. An electrostatic precipitator cannot be 

## ) 13 safely engaged until the control device has reached 14 the appropriate temperature. 15 To address this· issue, 326 IAC 5-1-3 was 16 amended in 1998 by adding a new Subsection (e)· to 17 allow sources that had existing startup and shutdown 18 conditions in their construction or operating permits 19 to be exempt from the opacity limit until the exhaust 20 gases achieve a temperature of 250 degrees Fahrenheit 21 at the inlet of the baghouses or the electrostatic 22 precipitator. 23 US EPA approved this exemption provision 

# ) 24 along with a process for other sources to obtain 25 temporary alternative opacity**l~mits** 

### into Indiana's

## )



# )

) 27

1 

### State Implementation Plan in 2002. Rockport's units 2 did not have pre-existing opacity exemptions in their 3 permits at that time and, therefore, they are not 4 part of the limited exemption in 326 IAC 5-1-3(e). 5 In accordance with Indiana's opacity rules 6 at 326 IAC 5-1-3(d), and this is the part of the 7 rules that allow for the other process to have others 8 

### get the temporary alternative opacity limit, in 9 

### accordance with that, Indiana Michigan Power Company 10 has requested a temporary alternative opacity limit 11 for Units 1 and 2 at Rockport Power Plant during 12 startup and shutdown. 13 For boilers startup IDEM is proposing the 14 boilers be exempt from the opacity limit for up to 15 two hours or until the flue gas**te~perature** 

### reaches 16 250 degrees**Fahrenheit~** 

### whichever occurs first. 

### 17 ·During shutdown IDEM proposes the boilers be exempt .18 for up to one and a half pours**aft~r** 

### the flue gas

19**tempe~ature** 

### goes below 250 degrees Fahrenheit. This 20 will make startup and shutdown requirements at 21 Rockport consistent with those at other power plants 22 in Indiana. 23 IDEM has conducted modeling that indicates 24 25 the proposed temporary alternative opacity limit will not impact maintenance of air quality standards.

### j 28

1 

### IDEM will continue to work with US EPA on the 2 modeling protocol for Rockport Power Plant a$ needed. 3 This plan will be submitted t6 US EPA as a revision 4 to the State Implementation Plan. The Department 5 requests that the Board preliminarily-adopt-the rule 6 as presented. We do have technical staff here to 7 answer any questions. 8 CHAIRMAN ETZLER: Are there any questions 9 from the Board at this time? 10

. GARY POWDRILL: I notice in your Tentative 11 Environmental Rulemaking Schedule there are similar 12 rulemakings for Alcoa and Walsh and Kelly. Are they 13 14 15 the basic same issue as opacity at startup or are they something different? CHRIS PEDERSEN: They're different. I 

### 16 believe those are mostly S02-related rulemakings, 17 yeah, so they would be different. 18 

### JOANNE ALEXANDROVICH: Why did it take so 19 long, 2002 to 2014, and what has been going on with 20 the opacity in that time period? 21 ·cHRIS PEDERSEN: I would not be able to 22 · answer that. That would be something that would have 23 to probably be addressed to**~ockport;** 

### I don't know 24 whether any of our staff here would have that 25 information about why they waited this long.

## )

) ,• 

### 1 JOANNE ALEXANDROVICH: Well, I'm just 2 wondering, I mean I would think**t~at** 

### your staff has 3 reviewed their opacity measurements and seen that 4 there were issues, I expect? 5 

### CHRIS PEDERSEN: I can't say if there were 6 issues or not, I don't know. 7 

### CHAIRMAN ETZLER: Thank you. We have two 8 speakers, Mr. Long from Indiana Michigan Power. 9 10 

### 11 12 13 

### DAVID LONG: Good afternoon. My name is David Long. I'm actually employed by the American Electric Power Service Corporation, which is the technical services organization that supports the companies of the American Electric Power System. 14 Today I'm here to speak on behalf of AEP Indiana 15 Michigan Power in**suppo~t** 

### of the Rockport Plant 16 temporary alternative opacity limit being considered 17 by the Board for adoption. 18 Over the past years we've been working with 19 IDEM to identify the appropriate values for the 29



### 20 temporary alternative opacity limitation covering the 21 startup and shutdown of the generating units at 22 Rockport Plant that can be complied with on a 23 continuous basis as part of the Title V process, as 24 25 

### well as working with IDEM to develop the necessary rule language which is now before you for preliminary30 

### 1 adoption. This**t~mporary** 

### alternative opacity limit 2 is donsistent with the applicable federal**standard~,** 

### 3 grants relief from the opacity standards of the 

### 4 Indiana SIP and assures that the generating units at 5 Rockport continue to use good air pollution control 6 practices during startup and shutdown. 7 We wish to thank IDEM's Office of Air 8 Quality for working with us to develop the rulemaking 9 package before you today and encourage you to vote in 10 favor of preliminarily adopting the rule at this 11 time. Thank you for your time. 12 CHAIRMAN ETZLER: Do the Board members have 13 any questions? Thank you. 14 GARY POWDRILL: Mr. Chairman. ·15 CHAIRMAN ETZLER: Oh, I'm sorry. 16 GARY POWDRlLL: Do you potentially have the 17 answer to Dr. Alexandrovich's question? 18 DAVID LONG: Well, yes and no. You know, 19 part of why we're here today goes way back in history 20 to when Rockport was originally permitted in the 21 1970s and the predecessor agency to IDEM and US EPA 22 both took the view that at that time that Subpart (d) 23 did not offer opacity exemptions. Well, as people

\ 

### 24 have come to understand Subpart (d) since that time, 1 } 

### 25 it's sort of "Yeah, you really are entitled to them31

1 I 

### during startup and shutdown because Subpart (d) I 2 

### doesn't apply," so at the point IDEM and us were 3 

### talking about the exceedances that occurred primarily 4 

### during startup but periodically during shutdown 5 

### conditions it was agreed that, yes, it was 6 appropriate for us to begin .working our way through 7 

### this process; 

# s And there have been a couple of different 9 

### versions of the TAOL, one thqt was in the original 10 

### Title V permit and -then the version that's before you 11 

### today, and the**e~olution** 

### of.the language that's 12 

### occurred has been due primarily to changes in how the 13 

### units have performed over time based on fuel supplies 14 

### and the**l~ke.** 15 

### So, yes, IDEM does look at our reports and 16 

### if there's a question they've talked t6 us, and Dan 17 

### Hancock, who has retired from IDEM, was the gentleman 18 

### who actually·developed the numbers that are in the 19. 

### rule as it appears.today. 20 

### JOANNE ALEXANDROVICH: So excursions from the 21 

### opacity were considered exceedances and really 22 

### nothing else was done about them? 23 

### DAVID LONG: Yeah. 24 

### JOANNE ALEXANDROVICH: And it's only the 25 

### precipitator that needs to be up to 250 

### degrees, is

### )

)

) 

### 1 2 

### .that right? DAVID LONG: Well, the precipitator's at the 3 tail end of the unit, so -- JOANNE ALEXANDROVICH: So it wasn't an issue before the ESP was installed or was that there originally? DAVID. LONG: The precipitato:t;'s that are on 32

4 5 6 7 8 9 

### 10 11 12 13 

### 14 Rockport Plant were installed with the construction of the units, they had to be in order for us to comply with the NSPS and the· state particulate rules. JOANNE ALEXANDROVICH: Thank you. CHAIRMAN ETZLER: Thank you, sir. Ms. Perras. JODI ·PERRAS: Good afternoon. My name is 15. Jodi Perras and I'm representing the Sierra Club's 16 Hoosier Chapter today-and our 7,500 members in 17 Indiana, and we're a nonprofit environmental 18 organization, the nationis oldest and largest 19 environmental advocacy group. 20 I rise to ask you to postpone acting on the 21 rule today because there are some serious problems 22 with how it was developed, and on behalf of the 23 Sierra Club and Earthjustice, which helped us look at 

### 24 this .rule, we oppose the proposed rule because firstl 25 a little bit about the issue of particulate matter33



### 1 and these temporary alternative opacity limits. 2 Opacity is the primary method.of measuring 3 

### 4 5 

### 6 

### 7 8 

### 9 10 11 12 13 14 15 16 

### 17 18 19 

### particulate .matter at Rockport. Both short-term and long-term exposure to particulate matter causes serious health effects, especially PM2.5, smaller PM particles. PM2:5. There's no safe threshold for exposure to

The proposed rule has not been demonstrated

as needed or justifiable as Indiana's Clean Air Act State Implementation requires. The proposed rule does not meet EPA's criteria for approval as a State Implementation Plan revision. What we are submitting today into the record is documentation from IDEM's files of repeated excess opacity violations at the Rockport Plant. Under the law, I&M must demonstrate that Rockport cannot meet the opacity limits during startup and shutdown, and it has not provided this demonstration. For example, they do not explain why 20 I&M cannot take other steps to control opacity and 21 PM, for example improving maintenance, upgrading the 22 electrostatic precipitators, installing additional 23. control equipmerit. I&M must demonstrate that the 24 temporary alternative opacity limits will not 25 interfere with the maintenance of the National

# ) 34

1 2 

### Ambient Air Quality Standards, and they have not done(

so. For example, we have just found out in the last 3 few days that IDEM's modeling that was referred to 4 earlier to evaluate the impact of this rule on the 

## ·s 24-hour PM2.5 National Ambient Air Quality Standards

6 assumes there is no, zero, PM2.5 in the air other 7 

### than the PM2.5 from Rockport and we know there are 8 9 

### 10 11 

### 12 13 14 15 16 17 18 

### other plants downwind that are contributing, so if your modeling already assumes zero, sure_, but that's

an assumption that shouldn't be allowed by this board, and we would ask you to table this ·rule and take a closer look at that issue. The temporary alternative opacity limit is too broad to be justifiable, even if r&M had made the required**demonstrations~** 

### For example, I&M does not · explain why· a flat-out exemption is needed and justifiable as required during the specified time period as opposed to a higher opacity limit, for 19 example. Why should they be allowed a two-hour 20 exemption, a complete two-hour exemption from the 21 rule? Who can hold their breath for two hours down 22 in Rockport? 23 The documents I&M**submitt~d** 

### in support of 24 its request for this limit are from 2001 and 2004. 

## t5 They should not be relied upon to demonstrate the·

### 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 

## ) 24· 25 need for a temporary alternative opacity limit at Rockport 10 years later. So in conclusion, we would submit to you that the requirements for a temporary alternative opacity limit protect the public from

. breathing dangerous, unnecessary particle pollution. They are required by the Clean Air Act that the company needs to go through these steps. They are 35.

not optional requirements, these must be met, and I&M has not met these requirements. Thank you. And I'll submit these into the record. I'm sorry I didn't I just came in from out of town and I wasn't able to**m~ke** 

### copies for all of you. CHAIRMAN ETZLER: Does the Board have any questions? JOANNE ALEXANDROVICH: Yeah, I do. The requirements that you say, is that under 326 lAC 5-1-3(d) (2), are those the ones you're referring to? JODI PERRAS: I**believ~** 

### so. I had some attorneys who prepared this for me, so I believe those are the requirements that we're referring to. KELLY CARMICHAEL: Has IDEM had approvability discussions with EPA? CHRIS PEDERSEN: Has IDEM had approvability discussions with EPA? BETSY ZLATOS: I'm Betsy Zlatos, Office of

# )

)

) 1 

### 2 Legal Counsel with Office of Air Quality. CHAIRMAN ETZLER: Would you come forward, 3 please? 

### 4 BETSY ZLATOS: I guess I'm subbing· in for 

### 36

5 Susan Bern, who's actually been the one working on the 6 SIP approval, and Susan has had numerous discussions 7 with contacts at EPA about the approvability of this 8 · particular provision. 9 KELLY CARMICHAEL: And is it EPA's view that 10 it is approvable? 11 BETSY ZLATOS: That is the impression we get, 12 yes. And as a matter of fact, EPA had required that 13 14 15 16 17 18 19 20 21 

### 22 23 24 we put a time limit on the shutdown provision, so it had been it was either that or the temperature it had been one or the other, the 250 degrees, below 

### 250 degrees, and I believe an·hour and a half for shutdown, so they put the two together. (

KELLY CARMICHAEL: So it's EPA's view as far

as IDEM knows in IDEM's view that it's approvable and protected? BETSY ZLATOS: Yes

.. KELLY CARMICHAEL: Thank you. BETSY ZLATOS: Any other questions? JOANNE ALEXANDROVICH: I have a question fori 25 you, yes. When did Rockport make the request for the

### 1 rulemaking? BETSY ZLATOS: That has had a long history and I'm not exactly sure. It was a number of years ago that they put in their request for the temporary alternative opacity limitation, and it's actually been ratcheted down from the original request. I think there's been improvements. 

### 37

2 3 

### 4 5 6 7 8 

### The old inspector for the plant had gone, or 9 the retired inspector, had gone out .and I believe 10· looked over data that showed that, you know, that it 11 was the smallest window for startup and shutdown in 12 terms of the alternate limitation. 13 But**th~** 

### thing was it had gone back and 14 forth, I think it got stuck.at IDEM for a while, it 15 got stuck with Mr. Long, perhaps, for a while, and 16 then there was kind of a reconvening and everybody 17 said "Okay, we need to look at this again" and that's 18 when I think the time was ratcheted down to even a 19 shorter startup and shutdown time, so it has extended 20 a number of years. TED NIEMIEC: I have a question. Would 21 22 someone from IDEM please give IDEM's**re~ponse** 

### to thB 23 statements t·hat were made as part of the request to 24 ·postpone this today? 25 

### BETSY ZLATOS:. Well, I mean, I think that38

1 it's IDEM's position that AEP or I&M Rockport has 2 made the required demonstration for the limitation 3 and basically it's kind of tantamount to requiring 4 them to continue to violate if they do temporarily go 5 over the limitation,·and I would remind the Board 6 that the current federal rule does allow for a total 7 exemption during startup, shutdown and malfunction, 8 which the state rule does**not~** 9 TOM ANDERSON: Have they been cited for 10 violations? 11 BETSY ZLATOS: I cannot answer that, I don't 12 know. 

# ) 13 PHIL PERRY: Phil Perry with the Compliance 14 and Enforcement Branch. 

### 15 CHAIRMAN ETZLER: Please come forward. 16 PHIL PERRY: Yes, I don't believe that they 

### 17 have been cited for any excess emissions. While they 18 may have had them, the Agency evaluates those in the 19 scheme of the**~est** of the violations and the fact 20 that they monitor continuously to look at that and we 21 have not pursued any actions against them. 22 CHAIRMAN ETZLER: And just for the record 23 would you state your name and your 

# ) 24 PHIL PERRY: Yes, Phil Perry, I'm the Branch 25 Chief for the Compliance and Enforcement Branch.

### )



# ) 1 

### 2 CHAIRMAN ETZLER: Thank you, sir. TOM ANDERSON: I've got a question that if .39

3 you're aware of.any of the violations or official 4 5 

### violations? JODI PERRAS: Exhibit A·that we're submitting 6 today has letters from October .30th, 2009, July 30th, 7 2010, October 6th,_2011, September 6th, 2012, and 8 

### November 19th, 2013, all from IDEM's Air Compliance 9 and**Enfor~ement** 

### Section, indicating violations or 10 deviations of permit requirements and conditions 11 related to opacitj limitations. 12 Phil is correct that Office of Air Quality 13 14 15 

### 16 17 18 

### 19 20 21 22 23 

### 24 25 

### has taken no action, but every year they have been sent this letter saying that documenting these deviations and saying that "OAQ is not·pursuing legal action at this time, however future deviations could result in referral for**enforc~ment,"** 

### so we have five years of these repeated letters to I&M, to your question. TOM ANDERSON: So in other words, I guess there have been exceedances but no violations have been issued? JODI PERRAS: No enforcement actions have been taken. KELLY CARMICHAEL: And, in fact, why this

## )



## )



# ) 40

1 .TAOL is needed, right? The temporary alternative 2 opacity limit is directly related to establish 3 requirements by which Rockport has to comply with in order to not deviate? 

### 4 5 PHIL PERRY: That is correct, yeah. Rockport 6 is required on a quarterly basis to report all 7 deviations as well as certify annually, of which they 8 do, and that's what those letters -were addressing 9 were the reporting of those deviations. 10 KEN RULON: I just wondered if you had made 11 your concerns -- I mean from my perspective, IDEM, 12 you made a lot of very technical challenges and you 13 made a lot of accusorial kind of reviews of IDEM's 14 not doing certain things they weie supposed to do. 15 The second notice went out like three months ago. 16 Did you make IDEM aware of your concerns in that 17 area, because they're a lot more able to answer those 18. questions scientifically than, frankly, we are. 19 JODI PERRAS: Yeahr and to that question I 20 would say that when we saw this coming up on the 21 agenda was when we started looking at the plant's 22 history, so there are a lot of sources in the state 23 and we don't have the resources to look at every 24 25 single power plant, every single industry in the state, and when this rule comes before the Board, we41

1 

### ·took a look at the plant's history and that's the 2 

### documentation that we're presenting today. We did 3 

### I believe our attorney did discuss with IDEM some of 4 

### this information just in the last few days as she was 5 

### preparing these comments for the Board, so we have 6 

### discussed this with IDEM, we've made a call to EPA 7 

### about it, but this is something that we just, you 8 

### know, just started working on because it appeared on 9 

### the Board agenda a month or so ago. 10 

### And, again, to my point that the modeling is 11 

### flawed that went into this where they did not address 12 

### other sources of PM, IDEM's modeling did not address 13 

### ·other sources of PM in deciding that this**rul~** 

### met 14 

### the national standards and that alone in and of 15 

### itself I would suggest the Board should direct IDEM 16 

### to redo its modeling to be more compliant with what 17" 

### their State Implementation Plan**r~quires.** 18 

### CHAIRMAN ETZLER: Ms. Pedersen? 19 

### CHRIS PEDERSEN: One comment I would make is 20 

### just remember this is preliminary adoption, so we 21 

### have the time to work things out, but also the 22 

### modeler that worked on this is here and would like to 23 

### address the Board. 

### ) 24 

### MIKE MOSIER: Hello, I'm Mike Mosier, I work

J 25 

### in the Air Programs Branch and I'm an air quality

### 42

1 

## ) monitor for this project. What we did is we worked 2 

### with EPA very closely and worked with their technical 3 

### staff and when we came up with the proposal what we 4 

### did with this, we submitted it to them and asked them 5 

### for any comments. 6 

### We took a very conservative approach, we 7 

### made a very constraining scenario for I&M when we 8 

### submitted the analysis and when we submitted it to 9 

### EPA with no background, because our approach was so 10 

### conservative, they did not have any adverse comment 11 

### when**~e** 

### submitted this analysis to them, so my 12 

### interpretation from that was it was okay. 13 

### CHAIRMAN ETZLER: Thank you, sir. 14 

### MIKE MOSIER: You're welcome. 15 

### TOM ANDERSON: A quick question. On the 16 

### issue of modeling, had you assumed a zero PM2.5 in '17 

### the area with the addition at the source?

18 

### MIKE MOSIER: We just assumed Rockport's 19 

### emissions, what we did is we assumed all PM10 was 20 

### actually PM2.5, which was very conservative, and then 21 

### we took the worst-case hour and looked at that and 22 

### said it's going to be operating on a 24-hour basis, 23 88,760 

### hours a year for five years, and then we put 24 

### 'that into the model and we modeled it and it was 

# . 25 

### below the National Ambient Air Quality Standards.1 2 3 4 5 6 7 8 9**~0** 11 12 13 14 15 16 17 18 19 20 21 22 23 

### ) 24 25 43 

### TOM ANDERSON: I understand that, but I think the allegation was that you had assumed a zero background. MIKE MOSIER: That is cdrrect, and we submitted it that way to EPA and, again, EPA, their technical staff, did not have any adverse comments when we submitted it that way. TOM ANDERSON:. Thank you. MIKE MOSIER: You're welcome. CHAIRMAN ETZLER: Are there any other questions from the Board? KELLY CARMICHAEL: I do have one comment, Mr. Chairmani and that is I think, at least from my perspective, I do homework in advance of these meetings and there is a public comment period, so I would. encourage folks to be engaged in the publi9 comment period, get information in the record so that

we as a board can review that information prior to public hearings. CHAIRMAN ETZLER: Thank you. JOANNE ALEXANDROVICH: I guess I'll just make two last comments. There is a typo on the rule information sheet, you have the wrong rule written down at the last of the first paragraph, you have "3-5-1" 

### instead of 11 5-1-3."

## )



## ) 44

1 CHRIS PEDERSEN: Thank you. 2 JOANNE ALEXANDROVlCH: And my other just kind 3 of comment is that since from what I understand this 4 process bf**~aking** 

### temporary opacity limit has been 5 ongoing for so long and it wasn't all on Rockport's 6 side, I'm a little disappointed that my first 7 .question could be answered of why it took·so long. 8 9 

### CHAIRMAN ETZLER: Thank you. Hearing no further comment, this hearing is concluded. Is there 10 any further Board discussion? 11 12 

### 13 TOM ANDERSON: I guess I just have a question. The information that has been 'submitted that we haven't seen, since this is just preliminary 14 adoption, will the Agency look at that and consider 15 that information before final adoption action would 16. be taken? CHRIS PEDERSEN: Yes. 17 18 

### TOM ANDERSON: All right, thank you. 19 KEN RULON: Just another kind of prelim 20 how the process works kind of a question. I'd like 21 to review the data as well and so if we go ahead and 22 approve it at this time we still then can move to 23 change it at final adoption, is that correct? 24 25 

### CHAIRMAN ETZLER: That's correct. KEN RULON: Okay, so thank you. I would move

### 1 2 3 4 5 6 7 8 '9 10 11 12 

## l 13 14 15 16 17 18 19 20 21 22 23 24 25 

### to adopt. CHAIRMAN ETZLER: We have a motion to · preliminary adopt. KELLY CARMICHAEL: Second. CHAIRMAN ETZLER: And we have a**second~** 

### All in favor signify by saying "aye." (All respond "aye.") Those opposed same sign. 45



### CHAIRMAN ETZLER: (No response.) CHAIRMAN ETZLER: The Board has preliminarily adopted the new rule for the Rockport Generating Station Temporary Alternative Opacity Limit. Next we have a public hearing before the ·Environmental Rules Board of the State of indiana concerning preliminary adoption of amendments to rules at 329 

### IAC 9, 

### the Underground Storage Tank Delivery Prohibition Rules. I will now introduce Exhibit E, the draft rules, into the record of the hearing. Is there someone from the Department? ·LAUREN AGUILAR: Sorry to disappoint be6ause it's not Chris again, but good afternoon members of the Board, my .name is Lauren Aguilar and on behalf of IDEM the**Indi~na** 

### Underground Storage Tank or UST rules found at 329 

### IAC 9 

### require owners and operators to install and maintain equipment to prevent

# ) 99



### 1**GAR~** 

### POWDRILL: So moved. 2 TOM ANDERSON: Second. 3 CHAIRMAN ETZLER: The meeting's adjourned. 4 (WHEREUPON, at 3:50p.m., June 11, 2014, this 5 hearing concluded for the day.) 6 

### 7 8 9 

### 10 11 12 13 14 15 16 

### .17

18 

### 19 20 21 22 23 24 251 

### CERTIFICATE 2 

### STATE OF INDIANA ss: 3 

### COUNTY OF HAMILTON 4 

### 5 I, Marjorie A. Addington, the undersigned Court Reporter and Notary Public residing a-nd 6 maintaining offices in the City of Carmel, Hamilton County, Indiana, do hereby certify: 7 8 

### 100

9 

### That I reported to the best of my ability in machine shorthand all of the words spoken by all 10 parties in attendance during the course of the hearing; 11 

### 12 13 That I later reduced my shorthand notes into the foregoing typewritten transcript form, which 14 typewritten transcript {s 

### a true record to the best of my ability of the hearing; 15 16 

### 17 That I am not a relative or employee or attorney or counsel of any of the parties, nor am I a 18 relative or an employee of such attorney or counsel, and that I am not financially interested in this 19 

### action. 20 21 22 

### 23 IN WITNESS HERETO, I have affixed Notarial Seal and subscribed my signature below this 18th day of JUNE, 2013.

24 Notary Public County of**Resi~ence:** 

### 25 My Commission Expires on:Indiana Register TITLE 326 AIR POLLUTION CONTROL DIVISION Proposed Rule LSA Document #12-392 DIGEST Adds 326 lAC 5-1-8 concerning temporary alternative opacity limitations (TAOL) for the AEP Rockport Generating Station. Effective 30 days afterfiling with the Publisher. HISTORY First Notice of Comment Period: July 11, 2012, Indiana Register (DIN: 20120711-IR-326120392FNA). Second Notice of Comment Period: February 12, 2014, Indiana Register (DIN: 20140212-IR-326120392SNA). Notice of First Hearing: February 12, 2014, Indiana Register (DIN: 20140212-IR-326120392PHA). Change in Notice of Public Hearing: May 7, 2014, Indiana Register (DIN: 20140507-IR-326120392CHA). Date of First Hearing: June 11, 2014. PUBLIC COMMENTS UNDER IC 13-14-9-4.5 IC 13-14-9-4.5 states that a board may not adopt a rule under IC 13-14-9 that is substantively different from the draft rule published under IC 13-14-9-4, until the board has conducted a third comment period that is at least 21 days long. Because this proposed rule is not substantively different from the draft rule published on February 12, 2014 at DIN: 20140212-IR-326120392SNA, the Indiana Department of Environmental Management (IDEM) is not requesting additional comment on this proposed rule. SUMMARY/RESPONSE TO COMMENTS FROM THE SECOND COMMENT PERIOD The Indiana Department of Environmental Management (IDEM) requested public comment from February 12, 2014, through March 14, 2014, on IDEM's draft rule language. IDEM received comments from the following parties: Indiana Michigan Power Company, dba American Electric Power (AEP) Following is a summary ofthe comments received and IDEM's responses thereto: Comment: Since the time ofthe issuance ofthe initial Title V permit, the opacity provision containing the temporary opacity limit (TAOL) has been under appeal and IMPA has been working with IDEM to develop permit language acceptable to both parties as part ofthe settlement ofthe larger permit appeal. AEP requests that IDEM update the proposed rule language as follows: "(1) When building a new fire in a boiler, opacity may exceed the applicable limitation established in 326 lAC 5-1-2 for a period not to exceed a total oftwo (2) four (4) hours (twenty (20) forty (40) six (6)-minute averaging periods) during the start-up period, or until the flue gas temperature reaches two hundred fifty (250) degrees Fahrenheit at the inlet ofthe electrostatic precipitator, whichever occurs first. (2) When shutting down a boiler, opacity may exceed the applicable limitation established in 326 lAC 5-1-2 for a period not to exceed a total of one and half (1.5) hour (fifteen (15) ten (10) six (6)-minute averaging periods) during the shutdown period. (3) Operation ofthe electrostatic precipitator is not required during these times." (AEP) Response: The proposed time frames requested are the same as the draft rule language and therefore have not been amended for preliminary adoption. IDEM does not agree that item (3) should be included and has not made the change as requested. It is not necessary since the rule does not require operation ofthe ESP, therefore the exemption is not needed. The ESP language is included in the Title V operating permit. IDEM is also proposing to the retain the following language as proposed in the draft rule as it is necessary for state implementation plan (SIP) approval by the United States Environmental Protection Agency: (2) When shutting down a boiler, opacity may exceed the applicable limitation established in section 2 ofthis rule once the flue gas temperature has dropped below two hundred fifty (250) degrees Fahrenheit at the inlet ofthe electrostatic precipitators for a period not to exceed a total of one and one half (1.5) hours (fifteen (15) six (6)-minute averaging periods) during the shutdown period. SUMMARY/RESPONSE TO COMMENTS RECEIVED AT THE FIRST PUBLIC HEARING On June 11, 2014, the Environmental Rt,Jies Board (board) conducted the first public hearing/board meeting concerning the development of new rule language at 326 lAC 5-1-8. Comments were made by the following parties: Jodi Perras, on behalf ofthe Sierra Club Hoosier Chapter (SC) Following is a summary ofthe comments received and IDEM's responses thereto: Comment: Indiana Michigan Power- Rockport Plant, d/b/a American Electric Power (AEP) must Date: Dec 30,2014 9:15:42AM EST DIN: 20140730-IR-326120392PRA Page 1Indiana Register demonstrate that Rockport cannot meet the opacity limits during startup and shutdown, and it has not provided this demonstration. AEP does not explain why they cannot take other steps to control opacity and particulate matter, for example, improving maintenance, upgrading the electrostatic precipitators (ESP), or installing additional control equipment. (SC) Response: Boilers that use fuel oil as a startup fuel and have an ESP as a control device have trouble meeting an opacity limit until the exhaust gases have reached a certain temperature. The ESP cannot be safely engaged until the control device has reached an appropriate temperature. AEP has indicated that they operate the ESP as much as they can to limit the occurrence of exceedances ofthe opacity limit. Installing additional controls is a major investment and is not warranted in this situation. Adding a baghouse to replace the ESP is the type of project that is required in federal consent decrees or federal rulemaking that affects all power plants. The recent Mercury and Air Taxies Standards (referred to as MATS or Utility NESHAP) will require additional controls and additional particulate matter monitoring for many power plants. Upgrading the ESP does not address the safety issue concerns. Over the last five years (2009- 2013), AEP Rockport has a compliance rate of 99.81% based on the Continuous Opacity Monitoring System (COMS) data. This is above the average compliance rate for other sources measuring opacity using a COMS. All opacity exceedances including those attributable to startup and shutdown occurrences are reported to the department as required by AEP Rockport's Title V permit. Only about one third ofthe reported exceedances were due to startup/shutdown events. IDEM evaluates each reported exceedance and takes the appropriate enforcement action as necessary. The department has determined that none ofthe opacity exceedances were significant enough to warrant formal enforcement action, but has issued violation letters to address the deviations. For comparable sources, IDEM has already addressed this issue; 326 lAC 5-1-3 was amended in 1998 by adding a new subsection (e) to allow sources that had existing startup and shutdown conditions in their construction or operating permits to be exempt from the opacity limit until the exhaust gases achieved a temperature of250 degrees Fahrenheit at the inlet ofthe baghouses or ESP. U.S. EPA approved this exemption provision, along with a process for other sources to obtain TAOLs, into Indiana's state implementation plan (SIP) on July 16, 2002. U.S. EPA approved the limited exemption from opacity limits based on a modeling analysis assessing the worst-case impact showing that the exemption would notjeopardize continued attainment ofthe particulate matter air quality standard (PM 10). IDEM did not model all power plants, but used an example power plant to reflect the worst case dispersion scenario (short stacks). AEP Rockport's units did not have preexisting opacity exemptions in their permits at that time and are not part ofthe limited exemption in 326 lAC 5-1-3(e). Therefore, AEP Rockport has requested a TAOL for their facility. Comment: AEP must demonstrate that the temporary alternative opacity limits will not interfere with the maintenance ofthe National Ambient Air Quality Standards (NAAQS). IDEM's modeling to evaluate impact ofthis rule on the 24-hour PM 5 NAAQS assumes there is no PM2 5 in the air from other sources. (SC) Response: IDEM Joes not agree that background concentrations need to be considered because ofthe nature ofthe scenario modeled. While the TAOL is limited to just startup and shutdown the modeling is conservative because emissions were assumed to occur continuously. AEP's modeling analysis estimated PM 10 emission rates to examine the various operating conditions the unit undergoes during startup. In the early stages the burners are firing oil with the amount of coal being burned steadily increasing. The highest emissions are estimated to occur when the unit has transitioned from oil to coal and under partial load. At this time the ESP is partially energized and AEP assumes an approximate efficiency of 60%. A previous inspector indicated that the ESP is operated at 75% of capability prior to any fire. IDEM's conservative PM 2 5 modeling analysis assumed all PM 10 emis.sions are PM2.5 and modeled the highest emission estimate for the startup cycle, assuming it would occur continuously. U.S. EPA has previously reviewed the modeling and has indicated that the modeling was acceptable. Spencer County is classified as attainment ofthe particulate matter NAAQS. IDEM is considering running another modeling scenario that takes into account the intermittent nature ofthese emissions that would include the background concentration. U.S. EPAwill be consulted before IDEM runs additional modeling scenarios. Comment: The temporary alternative opacity limit is too broad to be justifiable. Why is a flat-out exemption needed and justifiable as opposed to a higher opacity limit? Why is it a two-hour exemption? (SC) Response: There is no opacity limit as part ofthe TAOL because the structure ofthe TAOL is time and temperature based. The opacity reading varies during startup and shutdown and the exemption is only applicable during a narrow operating scenario. If an opacity limit was selected that could account for all opacity readings that could happen during this operating scenario, then it would serve little purpose because it would have to be a very high opacity limit. IDEM identified 2 hours as a limit for the exemption based on past COMS data. In the initial Title V permit, IDEM had used four hours for start-up and has further ratcheted this number down as additional COMS data and duration of exceedances during startup was evaluated over the years. In 326 lAC 5-3- 1(e)(2)(A)(i), the TAOL for equipment with baghouses or ESPs applies until the exhaust gas has achieved a temperature of250 degrees Fahrenheit with no time limit. The proposed TAOL for AEP Rockport provides additional restrictions on time. The proposed TAOL is equivalent (or more stringent) than the TAOLs for other

Date: Dec 30,2014 9:15:42AM EST DIN: 20140730-IR-326120392PRA Page 2Indiana Register Indiana power plants. Comment: The documents AEP submitted in support of its request are from 2001 and 2004. They should not be relied upon to demonstrate a need for a temporary alternative opacity limit at Rockport ten years later. (SC) Response: While the source requested a TAOL in 2001 and 2004 more recent data was evaluated for the rulemaking. IDEM has evaluated COMS data from 2007 to 2013 to confirm that the proposed TAOL in the rulemaking is currently appropriate. IDEM has also conducted additional modeling using updated modeling software. 326 lAC 5-1-8 SECTION 1. 326 lAC 5-1-8 IS ADDED TO READ AS FOLLOWS: 326 lAC 5-1-8 Site-specific temporary alternative opacity limitations Authority: IC 13-14-8; IC 13-17 Affected: IC 13-11 Sec. 8. In accordance with section 3(d) ofthis rule, Indiana Michigan Power Company (dba American Electric Power) Rockport Units #1 and #2, located in Spencer County, when burning fuels identified in section 3(d)(1) ofthis rule, shall comply with the following temporary alternative opacity limitations: (1) When building a new fire in a boiler, opacity may exceed the applicable limitation established in section 2 ofthis rule for a period not to exceed a total oftwo (2) hours (twenty (20) six (6) minute averaging periods) during the startup period, or until the flue gas temperature reaches two hundred fifty (250) degrees Fahrenheit atthe inlet ofthe electrostatic precipitators, whichever occurs first. (2) When shutting down a boiler, opacity may exceed the applicable limitation established in section 2 ofthis rule once the flue gas temperature has dropped below two hundred fifty (250) degrees Fahrenheit at the inlet ofthe electrostatic precipitators for a period notto exceed a total of one and one-half (1.5) hours (fifteen (15) six (6) minute averaging periods) during the shutdown period. (Air Pollution Control Division; 326 JAG 5-1-8)

Notice of Public Hearing

Posted: 07/30/2014 byLegislative Services Agency An html version ofthis document.

Date: Dec 30,2014 9:15:42AM EST DIN: 20140730-IR-326120392PRA Page 3Indiana Register TITLE 326 AIR POLLUTION CONTROL DIVISION

Notice ofPublic Hearing Notice of Public Hearing LSA Document #12-392

Under IC 4-22-2-24. IC 13-14-B-6. and IC 13-14-9, notice is herebygiven that on September 10, 2014, at 1:30p.m., at the Indiana Government Center South, 302 West Washington Street, Conference CenterRoom A, Indianapolis, Indiana, the Environmental Rules Board will holda public hearing on amendments to 3261AC 5-1 (adds 326 lAC 5-1-B) concerning temporaryalternative opacitylimitations (TAOL) for the AEP Rockport Generating Station. The purpose ofthis hearing is to receive comments from the publicpriorto final adoption ofthese rules by the board. All interestedpersons are invited and will be given reasonable opportunity to express their views concerning the proposedamendments. Oral statements will be heard, but, for the accuracy ofthe record, all comments should be submitted in writing. Additional information regarding this action maybe obtained from Susan Bern, Rules Development Branch, Office ofLegal Counsel, (317) 233-5697 or(BOO) 451-6027 (in Indiana). Individuals requiring reasonable accommodations forparticipation in this event should contact the Indiana Department ofEnvironmental Management, Americans with Disabilities Actcoordinatorat: Attn: ADA Coordinator Indiana Department ofEnvironmental Management Indiana Government CenterNorth 100 North Senate Avenue Indianapolis, IN 46204-2251 orcall (317) 233-17B5 (V). Speech and hearing impaired callers maycontact IDEM via the Indiana Relay Service (711) or(BOO) 743-3333. Please provide a minimum of72 hours notification. Copies ofthese rules are nowon file at the Rules Development Branch, Office ofLegal Counsel, Indiana Department ofEnvironmental Management, Indiana Government CenterNorth, 100 North Senate Avenue, Thirteenth Floorand Legislative ServicesAgency, Indiana Government CenterNorth, 100 North Senate Avenue, Room N201, Indianapolis, Indiana and are open forpublic inspection. Nancy King, Chief Rules Development Branch Office of Legal Counsel

Posted: 07/30/2014 byLegislative Services Agency An html version ofthis document.

Date: Dec 30,2014 9:22:30AM EST DIN: 20140730-IR-326120392PHA Page 11 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 ' ) 22 23 

### BEFORE THE STATE OF INDIANA ENVIRONMENTAL RULES BOARD

PUBLIC MEETING OF SEPTEMBER 10, 2014 

# ORIGINAL

PROCEEDINGS before the Indiana Environmental Rules Board, Beverly Gard, Chairman, taken before me, Lindy L. Meyer, Jr., a Notary Public in and for the State of Indiana, County of Shelby, at the Indiana Government Center South 1 

### Conference Center, Room A 1 402 

### West Washington Street 1 

### Indianapolis, Indiana, ·on Wednesday, September 10, 2014 

### at 1:29 

### o'clock p.m.

William F. Daniels, RPR/CP- CM d/b/a ACCURATE REPORTING OF INDIANA 12922 

### Brighton Avenue Carmel, Indiana 46032 (317) 848-0088 1

### 1 APPEARANCES: 2 BOARD MEMBERS: Beverly Gard, Chairman 3 Thomas R. Anderson Gary Powdrill· 4 Dr. Ted Niemiec Joanne Alexandrovich 5 Kelly Carmichael Ken Rulon 6 William Etzler Chris·Horn 7 Gail Boydston Mike Mettler, Proxy, Department of 8 Health Cameron F. Clark, Director, Department of 9 Natural Resources Pamela Fisher, Proxy, Indiana Economic 10 Development Corporation David Bausman, Proxy, Lieutenant 11 Governor Thomas W. Easterly (nonvoting) 12 13 IDEM STAFF MEMBERS: Christine Pedersen 14 Susan Bern Lauren Aguilar 15 MaryAnn Stevens Dan Watts 16 Bruce Palin Nancy King 17 Janet Pittman 18 

### PUBLIC SPEAKERS: 19 Jodi Perras Bowden Quinn 20 Steven Peckinpaugh Dave Menzer 21 Josh Trenary Kim Ferraro 22 Charles Mitch 23 

### 21 

### 2 1:29 o'clock p.m. September 10, 20143



### 3 CHAIRMAN GARD: The Chair is going to 4 call this meeting to order. We have a very big 5 agenda, and so we ought to get moving as quickly 6 

### as possible. The Chair sees a quorum. We have 7 

### eight voting members present. Let me ask you 8 all, as we do every meeting, to go around and 9 introduce yourselves and tell what constituency 10 you represent. 11 

### COMM. EASTERLY: I'm Tom Easterly, 12 the Commissioner of IDEM. 13 

### MR. RULON: Ken Rulon, representing 14 agriculture. 15 

### MR. BAUSMAN: David Bausman, Director 16 of Policy and Regulatory Affairs at ISDA, serv'ing 17 as the Lieutenant Governor's proxy. 18 

### MR. CLARK: Cameron Clark, the 19 Director oj 

### the Indiana Department of Natural 20 Resources. 21 MR. METTLER: Mike Mettler;. proxy for 22 the State**H~alth** 

### Commissioner, Dr.· VanNess. 23 

### MS. FISHER: Pam Fisher, proxy for

### 1 Secretary of Commerce Victor Smith. 2 

### MS. BOYDSTON: Gail Boydston, 3 representing manufacturing. 4 

### 5 public. 6 

### 7 business. 8 

### CHAIRMAN GARD: Beverly Gard, general

MR. ETZLER: Bill Etzler 1**~mall**



### MR. ANDERSON: Tom Anderson 1 9 

### environmental. 10 11 at large. 12 13 care. 14 MR. POWDRILL: Gary Powdrill 1 

### public

DR. NIEMIEC: Ted Niemiec 1 

### health

MS. ALEXANDROVICH: Joanne 15 Alexandrovich 1 

### county government 1 

### local 16 government. 17 

### 18 utilities. 19 

### 20 MR. CARMICHAEL: Kelly Carmichael,

MR. HORN: Chris Horn, labor. CHAIRMAN GARD: Thank you all. 21 The first order of business today is 22 approval of the summary of the June 11th, 2014 23 Board meeting. Are there additions or 41 

### 2 3 aye. 4 5 6 7 8 9 10 11 

### 12 13 14 15 16 17 18 19 20 

### 21 passed. MR. RULON: Second. CHAIRMAN GARD: All in fayor, say

MR. HORN: Aye. MS. ALEXANDROVICH: Aye. MR. CARMICHAEL: Aye. MR. ETZLER: Aye. MR. ANDERSON: Aye. MR. BAUSMAN: Aye. MR. POWDRILL: Aye. MR. CLARK: Aye. MR. METTLER: Aye. DR. NIEMIEC: Aye. MS. FISHER: Aye. MS. BOYDSTON: Aye. MR. RULON: Aye. CHAIRMAN GARD: Aye. Those opposed, say nay. (No response.) CHAIRMAN.GARD: The motion has

22 This is a public hearing before the 16



### 23 Environmental Rules Board of the State of Indiana

# ) 1 2 3 4 5 6 7 8 9 10 11 

## ) 12 13 14 15 16 17 18 19 20 21 22 23 

# ) concerning final adoption of amendments to the rules at 326 IAC 5, Rockport Temporary Alternative Opacity Limit. I will now introduce Exhibit D, the preliminarily adopted rules, into the record of the hearing. Is there someone from the Department to present the rules? Susan Bern? 17

MS. BEM: My name is Susan Bern, and I work in the Rule**Develop~ent·Branch.** 

### This rulemaking is for Indiana Michigan Power coal-fired electric generating station in Rockport, Indiana, also located in Spencer County. Its parent company is American Electric Power, or AEP. AEP has requested a temporary**alternati~e** 

### opacity limit, or TAOL, for Units 1 and 2 at its Rockport Generating Station. IDEM is proposing a TAOL that limits the exemption**d~ring** 

### start-up to two hours or until the flue gas temperature reaches 250 degrees Fahrenheit, whichever occurs first. There is also a similar TAOL for shutdown, but it's limited to 1.5 hours.

### 1 2 3 4 5 

### 6 7 8 9 10 11 12 } 

### 13 14 l5 

### 16 17 18 19 20 21 22 23 

### 18

At preliminary adoption, a few issues were addressed. One was.the length of time between the request in 2002 and now. There was a long delay, as it was not until their Title V permit

came up for renewal was there a push to get the TAOL SIP approved. Initially, the request was under subsection (e) in Article 5 for power plants that already have a**TAOL~** 

### and the request was revised to fall under subsection (d), where a SIP revision is required. As the Title V permit worked its way through the appeal process, the TAOL language evolved to further limit the time frame the TAOL

. could be used for, as the opacity issues improved

over the years. Another issue at preliminary adoption was opacity violations at the source. Since preliminary adoption, IDEM did take another look at the COMS, or continuous opacity monitoring system, data at AEP Rockport, and the compliance rate for the 2009-through-2013 time frame is 99.81 percent. About one-third of the

# ) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 19

reported exceedences were due to the**start~up/shutdown** 

### eventsr and IDEM had determined that the opacity exceedences were not significant enough to warrant formal enforcement action. And I could

-- one of the other issues was the information used to develop the TAOL. Initially 1 

### AEP had put

-- in their 2002 request had looked at their COMS data at that time to develop the TAOL 1 

### but that was not the information used to develop the most recent TAOL that's in this proposed rule. We used more recent information from 2007 through 2013. Rockport is looking at other steps to control emissions. They are currently installing dry sorbent injection to control sulfur**dioxid~** 

### and mercury. Activated carbon injection has been in use to control mercury for upcoming standards. Both of these controls could reduce opacity. In**th~** 

### modeling for preliminary adoptionr IDEM did not address other sources of PM. EPA had given us indication that the changes would be SIP approvable 1 

### because they had already approved this type of TAOL for the other power plants in

### 20

1 Indiana, .and AEP Rockport would have comparable 2 or bette·r dispersion than the other power plants 3 

### with a taller stack. Since the TAOL is for such 4 a narrow conservatively defined scenario, EPA did 5 not raise any flags in regards to not including 6 the other sources of PM. 7 In more recent discussions with EPA, they 8 did mention that if we wanted to characterize the 9 emissions differently, we could remodel, and we 10 have conducted modeling averaging all of the 11 different emission rates over the 24-hour 12 start-up period versus the maximum emissions as 13 if they were emitting 24/7.

. . 

### 14 For the 24-hour PM2 • 5 

### standard over a 15**five~year.** 

### meteorological data time period, the 16 value is .92 micrograms per meter cubed. If you 17 add in a background of 24, the total is 24.92 18 micrograms per meter cubed. The PM 2 • 5

### 24**~hour** 

### 19 standard is 35 micrograms per meter cubed. This 20 is below the standard when modeling the 21 worst-case**e~ission** 

### rate over the whole day, and 22 Spencer County is designated as attainment for 23 )1 2 3 4 5 6 7 8 9 10 11 

### ) 12 13 14 15 16 17 18 19 20 21 22 23 

### While the source may need to use the TAOL in less instances as time goes on, the TAOL is still needed as the ESP cannot be fully engaged until the control device has reached an appropriate temperature. This type of TAOL 21



### already exists for**simil~r** 

### power plants, and the TAOL for AEP Rockport is more stringent than what**e~ists** 

### for the other power plants. The Department requests that the Board final adopt the rule as presented. Thank you. CHAIRMAN GARD: Any questions from the Board for Susan? Yes. MR. POWDRILL: How is this rule impacted by something I read last week that I can't quote, that said EPA was becoming more stringent on start-up/shutdown and maintenance exceedences?MS. BEM: In

-- over time, EPA has been revising

-- you know, there's lots of different categories for their rules: New source performance standards, maximum achievable control1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 ) 22



### technology standards. And over timer they've been having to go back and revise those standards and make sure it's specifically stated in the**rul~s** 

### that they apply during**sta~t-up** 

### and shutdown. And then 1 

### you**know~** 

### as you have all of these standards apply during start-up and shutdown and not just during normal operating times 1 

### you know 1 

### that's when you start having trouble complying with the standard, and that's a little bit different than the SIP limits or in

our state opacity rules where they already applied in start-up/shutdown. You know 1 

### we have them applicable-during all time frames 1 

### and then this is an exemption for this narrow situation. COMM. EASTERLY: But we might have to

come back at some time in the future and give you another rule that meets EPA's new requirements/ which aren't fully defined yet. MR

.. POWDRILL: Okay. · So 1 

### this rule may be

-- may be changed later on 1 

### may have to be changed? COMM. EASTERLY: A number of rules

### 1 2 3 4 5 

### 6 7 

### 8 9 10 11 12 13 14 15 

### 16 17 

### 18 19 20 21 22 23 

## ) may have to, but we'll get there when we get there. MR. POWDRILL: Okay. 23

MS. BEM: Yes, we do have malfunction rules, and sometimes we have exactly what's defined as a malfunction. EPA has some proposed regulations out there to address that also that

are somewhat related. MR. POWDRILL: Thank you. CHAIRMAN GARD: Any other questions for Susan? (No response.) CHAIRMAN GARD: Thank you, Susan. MS. BEM: Thank you. CHAIRMAN'GARD: We have we have

one appearance card, Jodi Perras, Sierra Club. MS. PERRAS: Good afternoon, Madam Chair, members of the Board. I am Jodi Perras, Senior Campaign Representative for the Sierra Club's Beyond Coal Campaign here in Indiana. I'm also representing the Sierra Club's Hoosier Chapter. We're a nonprofit environmental organization with 7500 members in Indiana, and a1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 

## ) copy of my talking points are being distributed to you all. 24



### We remain opposed to the proposed exemption from the opacity standards because opacity is the primary method to measure particulate matter emissions at Rockport. Both short-term and long-term exposure to PM is

-- can

cause serious health effects 1 

### and there are no safe limits. From talking to people at these plants 1 

### we know start-up and shutdown times are particularly a problem for people living around them. The proposed exemption has not been shown to be needed or justified 1 

### ·as the Indiana's Clean Air Act SIP requires 1 

### and the rule doesn't meet EPA's criteria 1 

### in our opinion 1 

### and we stand by

our comments. There are several reasons for that 1 

### the big one being that there has been no demonstration that Rockport cannot meet some kind of opacity limits during start-up and shutdown. Both their decade-old application and IDEM's response to our comments are silent on the question of IDEM needs to require Rockport to try**-~** 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 25



### to comply with the existing limits or to**sho~** 

### why other steps, such a better maintenance of ESP's, switching to cleaner start-up fuel, et cetera, cannot be taken to achieve**compl~ance.** 

### Instead, they simply reiterate that the Rockport plant has exceeded.the opacity limits and, therefore, needs

an exemption. But the fact they've exceeded the limits doesn't demonstrate that the plant is unable to meet them or to meet some kind of limit. In Pennsylvania and Wisconsin, power plants are required, to conduct some kind of performance test to show what they can meet, and then the rules

are designed to achieve that. We don't have that here in Indiana. They just get a blanket exemption for a period of time. Exemptions should not be used to create the illusion of compliance. Rather than working to ensure that Rockport complies with these limits, IDEM's proposal is to simply exempt the plant from the limits during start-up and shutdown. But simply exempting them from pollution limits does nothing to ensure that the.

### 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 ) 

### public health benefits of those limits are being achieved or that pollution is being reduced to the extent practicable. IDEM's statements about the ESP'S not being available during start-up and shutdown are

erroneous. IDEM claims that they cannot be 26

safely engaged until flue-gas temperature reaches 250 degrees, but IDEM's own application, as we read it, makes clear that an ESP can achieve at least 60 to 75 percent opacity removal, even before. it is engaged; in other words, before the first ESP field is energized. The simple reality is that I&M can control its opacity emissions even during start-up and shutdown, but they will only do so if IDEM and you, the Board, require ,them to do so. IDEM continues to rely on stale information. Their**applicat~on** 

### documents from I&M are more than a decade old, and IDEM has failed for require them to update that application or a technical support document from the.company. While they state that they have looked at

more recent data in COMS, that data simply shows

### --l 1 2 3 4 5 6 7 8 9 10 11 

### ) 12 13 14 15 16 17 ·1s 19 20 21 22 23 

### that Rockport continues to exceed opacity standards. There's no evidence that IDEM has evaluated current information regarding why such exceedences occur or why I&M could or could not take steps at Rockport to consistently achieve**comp~iance** 

### with opacity limits. 27



### So, therefore.' the requirements for a TAOL to protect the public from breathing dangerous, unnecessary particle pollution are required by the Clean Air Act and are not optional. I&M has not met these requirements, and we would ask the Board to send this back to the agency and**requir~** 

### I&M to make that demonstration and not to be exempt completely during that start-up and shutdown time, but to have to meet some kind of opacity limit that is practicable. I'd be happy to take any questions. CHAIRMAN GARD: Are there any questions for Ms. Perras? MR. ANDERSON: Yes. One of the questions I would have is that haven't you looked at what one proposed alternative would be of cleaner start-up fuel?

## -· I

) 28

1 MS. PERRAS: That could be

-- that 2 could be one thing that could be considered 1 

### and 3 we would like to see a demonstration of that 4 option being considered. 5 

### CHAIRMAN GARD: Other questions for 6 Ms. Perras? 7 (No response.) 8 9 10 

### CHAIRMAN GARD: Thank you. MS. PERRAS: Thank you. CHAIRMAN GARD: Is there anyone else 11 from the audience that wishes to make a 12 statement? 13 (No**respons~.)** 14 

### CHAIRMAN GARD: This hearing is 15 concluded. 16 The Board will now consider final adoption 17 of Rockp?rt Temporary Alternative Opacity Limit. 18 Is there any further Board discussion? 19 (No response.) 20 

### CHAIRMAN GARD: If not 1 

### do I hear a 21 motion to finally

-- for final adoption of the 22 rule as presented? 23 

### MR. CARMICHAEL: So moved.1 2 3 

### 4 Mr. Rulon? 5 6 7 8 9 10 11 

### 12 13 14 15 16 17 18 19 20 

### 21 absent. CHAIRMAN GARD: Is there a second? MR. HORN: I second the motion. CHAIRMAN GARD: I 1 

### ll call the roll.

MR. RULON: Aye. CHAIRMAN GARD: Mr. Carmichael? MR. CARMICHAEL: Aye. CHAIRMAN GARD: Dr. Alexandrovich? MS. ALEXANDROVICH: Aye. CHAIRMAN GARD: Dr.**N~emiec?** 

### DR. NIEMIEC: Aye. CHAIRMAN GARD: Mr. Powdrill? MR. POWDRILL: Aye. CHAIRMAN GARD: Mr. Anderson? MR. ANDERSON: No. CHAIRMAN GARD: Mr. Etzler? MR. ETZLER: Yes. CHAIRMAN GARD: Ms. Boydston? MS. BOYDSTON: Yes. CHAIRMAN GARD: Mr. Davidson is

22 Mr. Horn? 23 

### MR. HORN: Yes. 29

### 1 2 3 4 5 6 

### 7 

### CHAIRMAN GARD: Ms. Fisher? MS. FISHER: Yes. CHAIRMAN GARD: Mr. Mettler? MR. METTLER: Yes. CHAIRMAN GARD: Mr. Bausman? MR. BAUSMAN: Yes. CHAIRMAN GARD: .Mr. Clark? 8 MR. CLARK: No. 9 CHAIRMAN GARD: The· Chair votes aye. 10 Did I

-- is there anybody that I missed? 11 (No response.) 12 CHAIRMAN GARD: Okay. One, two, 13 about, four, five, six, seven -- the rule is 14 

### adopted twelve to two. Thank you. 15 This is a public hearing**~efore** 

### the 16 Environmental Rules Board for the State of 17 Indiana concerning final adoption of amendments 18 to Rules 329 IAC 9-1 and 329 IAC 9-4.5, 19 Underground Storage Tank Delivery Prohibition. 20 I will introduce Exhibit E, the 21 preliminary adopted

-- preliminarily adopted 22 rules with IDEM 1 

### s suggested changes, into the 23 record of the hearing. 30144

1 

### CERTIFICATE 2 

### I 1 

### Lindy L. Meyer, Jr. 1 

### the undersigned 3 

### Court Reporter and Notary Public residing in the 4 

### City of Shelbyville 1 

### Ehelby County 1 

### Indiana 1 

### do 5 

### hereby certify that the foregoing is a true and 6 

### correct transcript of the proceedings taken by me 7 

### on Wednesday 1 

### September 10 1 

### 2014 in this matter 8 

### and transcribed by me.

10 11 

### 12 Notary Public in and 13 

### .for the State of Indiana. 14 

### 15 My Commission expires October 27 1 

### 2016. 16 17 18 19 

### 20 21 22 231.'"

.



### May 19,2004 Mr. DanHancock IndianaDepartment ofEnvironmental Management Office ofAir

### Quality 100North SenateAvenue P. 0,Box 6015 Indianapolis, IN 46206-6015

DearMr. Hancock: )

.

# ~**~·-'·'~1 ~-** **~** 

## - A/L':/·r' ') 1 

### /QQ4. 

# d-**~~** ;I l l.J J. ·-**~** atate: :;f Indiana

,**n:••}J-..~·.l''** ,. . • Lep<,•·--'·'J"t ;): frr,,rr:-n:nental M Office-; nj' f'Jr (Juality anagement;

.**-~~;r.:,.~~..._,.,,..,.,~,.,....** .. ,**""!''""""~-~** . American Electric Power 1Riverside Plaza Columbus, OH 43215-2373 www.aep.com



### Enclosedplease find acopy ofthe SupplementalTechnical SupportDocumentfor theTemp-orary Alternative Opacity limit Request for AEP's Rockport Plant. This supplements the formal request for a Temporary Alternative Opacitylimitfor Rockport filed in aletter dated August 16, 2001. I want to thank you for your**~uidance**

### in whatneededto beincludedin this docuinent. If

### you have any questions regarding the informationin the document orto set up a meeting to discuss this matter, ifyou feel one wouldbeuseful, please contactme at 614-716-1245 atyourconvenience. Sincerely,

# OAj~ DavidJ. 

### Long, PE Engineer Air

### Quality Services Section

enclosure

cc: P. A. DalPorto- w/attachment J. J. 

### Henry- w/attachment P. C. Hale- Rockport Plant- w/attachment

### SUPPLEMENTAL TECHNICAL SUPPORTDOCUMENT AMERICANELECTRIC POWER ROCKPORT PLANT TEMPORARYALTERNATIVE OPACITYLIMITREQUEST

Preparedfor AmericanElectric Power RockportPlant

Preparedby

D. 

### J. Long Air Quality Services Section AmericanElectric Power Service Corporation

May 19,2004

## Table ofContents Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 PrecipitatorMaintenance and Operation

................................................... 1 Air Quality Analysis

........................................................................... 6 Conclusion

...............................: . ..................................................... 10 Appendix A- SCREEN3 Simulations Usedin the Air QualityAnalysis

.............. 12 Appendix B -AirQualityDataUsedin the Air QualityAnalysis

..................... 43



### List ofTables Table 1. Unit 1 startups and shutdowns for the period 2001 through the first quarter of2004

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

### Table 2. Unit 2 startups and shutdowns for the period 2001 through the first quarter of2004

.................................................................· .............:·:................5 

### Table 3. SCREEN3 Input data

................................................................... 8 

### Table 4. Modelingresults from startup case examined

.......................................10



### i

### INTRODUCTION On August 16,2001,AmericanElectric Power filed a request for a Temporary Alternative OpacityLimitation (TAOL) coveringthe startup and shutdown ofthe main boilers at the Rockport Plant. TherequestedTAOLwould allow an exemption from the 20% opacity limit during startup until such time as the flue gas entering the electrostatic precipitatorreaches a temperature of250F and subsequently during shutdowns, the TAOLwould allow up to 10 six-minute average periods to exceed 20%. During IDEM'sreview ofthatrequest, itwas determined that since Rockport did not have an existing TAOL, the filing neededto be made under the provision of326lAC 3- 5-1(d) which requires the submittal ofadditional supporting opacity information and an analysis demonstrating that there would be no adverse ambient air quality impacts from the granting ofthe TAOL. The purpose ofthis report is to supply the additional data and analysis that supports the approval ofthe requestedTAOLfor the Rockport Plant. 

### PRECIPITATOROPERATIONAND MAINTENANCE The electrostatic precipitators (ESP) on each ofthe units at Rockport Plantconsistoffour individual boxes containing 32 electrical bus sections each, f<;>r a total of 128 electrical bus sections perunit. All ofthe electrical btis sections are controlledusing an electronic control systemthatutilizes an opacityfeed backsignal based on the stackopacity monitorreadingwhen operated in full automatic mode. Full automatic operation allows the optimization ofinputpowerto the precipitators while maintaining opacity and precipitatorperformance over a wjde range ofoperating conditions. Theprecipitatorcontrol buildings are checked on a dailybasis by the operations department at theplant for any abnormalconditions both with the Transformer-Rectifier sets and rapping devices. When an abnormal condition is noted, ajob orderis originated and sent to the appropriate maintenance group for action. Repairs that can be made with

.the unitin service are scheduled to·be undertaken as quickly as possible, whilerepairs

that will require a unit outage to address are placed on the outagejoborderlist. In general, every four toeight weeks, engineering personnel perform

# adetailed evaluation ofthe condition ofthe electrostatic precipitatorboxes andrappers on each unit. This evaluation is then documented and circulated to management forreview and planningpurposes. Duringnormal unit operating conditions and while the fans are operated during a unit shutdown, all ofthe operablebus sections in the ESP are normally energized. During unit startup, ourroutine procedurerequires that all operable bus sections except the first operable bus section in each gas pathbeenergizedpriorto fan start. Thepurpose for this sequence ofoperation (i.e. the first operable bus section in each gas path) is to reduce the risk ofan explosion insidethe ESP shouldunstable oil firing occur. We would deviate from our normal practice in the event thatthe firing ofthe unit becomes extremely unstable while firing mainly oil during a startup. In this unusual event, itmay become



### 1

### necessary to deenergize the entire ESP until the gas temperature in the precipitator reaches 200F to volatilize offany oil residue that may have collectedin the ESP. This is an abnormal condition that is rarely invokedto protectthe safety or ourpersonnel and equipment. When such an event occurs, the proper notifications are made to the Indiana Department ofEnvironmental Management (IDEM) within four business hours ofthe event. Based on guidance from IDEM staff, we have tabulated the startups and shutdowns for

.the period 2001 through the first quarter of2004 for each unit atRockport Plant and have

noted the operating status ofthe otherunit. This was necessary since opacity compliance at the RockportPlant is monitored on the common stack. Table 1contains the data relating to the Unit 1 startups and shutdowns and Table 

## 2contains the comparable data for Unit 2. Unit 1underwent 18 startups and 18 shutdowns during the period examined. One ofthe shutdowns occurred as aresult ofthe loss ofallelectrical transmission circuits leaving the site. Theresulting shutdown withoutpower caused the loss ofall.CEMS and COMS data for this shutdown. Therefore, the calculated statistics for shutdowns will be based on theremaining 17 shutdowns for which datais available. These 17 shutdowns experienced opacity exceedances averaging 0.3 hours per shutdown with aminimum period ofexceedance ofzero (0) hours to amaximum of2.5 hours. The maximum sixminute opacity measured during any oftheses shutdowns was 60%. During the 18 startups, opacity exceedances averaged 1.9 hours with aminimum ofzero (0) hours to a ,maximum of 10.2 hours. The maximum six-minute opacity measured during any ofthese startups was 76%. Unit 2underwent 15 startups and 16 shutdowns during the period examined. The 16 shutdowns averaged 0.2 hours ofopacity exceedances per shutdown with aminimum period ofzero (0) hours to amaximum of0.8 hours ofexceedance. The maximum sixminute opacity measured during any ciftheses shutdowns was 67%. Duringthe 15 startups, opacity exceedances averaged 0.8 hours with aminimum ofzero (0) hours to a maximum of3.6 hours. The maximum six-minute opacity measured during any ofthese startups Was 60%. When the two units are combined, there were 33 startups and 34 shutdowns, 33 ofthe shutdowns having valid opacity data. The average startup has 1.4 hours ofopacity valm)s exceeding the 20% opacity limit and the typical shutdown has an average of0.3 hours of opacity values exceeding the 20% opacity limit. There is no typical startup or shutdown event from an exceedance perspective. In any given event, the exceedances can be concentrated in one single continuous event or they may be spread over anumber of hours.

2

### Table 1. Unit 1 startups and shutdowns for the period 2001 through the first quarter of 2004. Startup/Shutdown Number ofSix PeakStack Remarks Date Minute Opacity Exceedances Reading March 30,2004- 2.7 hours 56% Hot restart following Startup shutdown due to loss ofall transmission circuits. Unit 2 out ofse!Vice. Malfunction notificationmadeto IDEM. March 29, 2004

- Unknown Unknown Black shutdown due to loss of shutdown all transmission circuits. No data available due to loss of

.. 

### power to plant. Unit 2 outof service. December7, 2003

- 0.0 hours NA Unit 2 operating. startup Hotrestart. December7, 2003

- 0.0 hours NA Unit 2 operating. shutdown December7, 2003

- 0.0 hours NA Unit 2 operating. startup Hotrestart. December7, 2003

- 0.1 hours 38% Unit 2 operating. shutdown November 17-18, 3.2hours 64% Unit 2 operating. 2003

- startup September 20, 2003 0.4 hours 35% Unit 2 operating. -shutdown June 1-2, 2003- 1.8 hours 42% Unit 2 operating. startup May 30, 2003

- 0.0 hours NA Unit 2 operating. shutdown April 20, 2003

- 0.0 hours NA Unit 2 operating. startup April18, 2003- 0.1 hours 21% Unit 2 operating. shutdown March 20, 2003

- 3.7 hours 42% Unit 2 operating. startup March 19, 2003

- 0.1 hours 40% Unit 2 operating. shutdown March 10,2003- 2.1 hours 32% Unit 2 operating. startup March 5, 2003

- 0.1 hours 21% Unit 2 operating. shutdown December21, 2002 3.4hours 70% Unit 2 operating. -startup



### 3November 30, 2002 0.1 hours 35% Unit 2 operating. -shutdown October 13-14, 1.8 hours 42% Unit 2 operating. 2002

- startup October 10, 2002

- 0.1 hours 42% Unit 2 operating. shutdown August 10, 2002

- 1.0 hours 42% Unit 2 operating. startup August4, 2002

- 0.4 hours 36% Unit 2 operating. shutdown April3-4, 2002- 1.6 hours 50% Unit 2 operating. startup March 23,2002- 0.0 hours NA Unit 2 operating. shutdown December 31, 2001 0.6 hours 37% Unit 2 operating. -startup December28, 2001 1:3 hours 55% Unit 2 operating. -shutdown September 3, 2001 0.5 hours 31% Unit 2 operating. -·startup September 1, 2001 0.0 hours NA Unit 2 operating.

· -shutdown

May 11-12, 2001- 10.2hours 70% Unit 2 out ofservice. startup HotRestart May 11;2001- 0.2hours 36% Unit 2 out ofservice. shutdown April27-29, 2001- 0.6 hours 76% Unit 2 operating. startup March 31 to April 2.5 hours 60% Unit 2 operating. 1, 2001- shutdown February 14, 2001- 0.5 hours 33% Unit 2 operating. startup HotRestart February 14,2001- 0.0 hours NA

.Unit 2 operating. shutdown February 10-11, 0.8 hours 33% Unit 2 operating. 2001 -startup February 5-6,2001 0.3 hours 53% Unit 2 operating. -shutdown

4

### Table 2. Unit 2 startups and shutdowns for the period 2001 through the first quarter of 2004.**Startup/Shutdo~** 

### NumberofSix PeakStack Remarks Date Minute Opacity Exceedances Reading February7, 2004

- 0.8 hours 36% Unit 1 operating normally. Shutdown January 5-6, 2004- 0.9 hours 32% Unit 1operating normally. startup December 30,2003 0.0 hours NA Unit 1 operating normally. -shutdown October 26, 2003

- 1.0 hours 50% Unit 1 out ofservice startup October 24, 2003

- 0.5 hours 67% Unit 1out ofservice shutdown August 10, 2003- 0.0 hours NA Unit 1 operating normally. startup Hotrestart. August 10, 2003- 0.1 hours 40% Unit 1 operatingnormally. shutdown July 27, 2003- 0.0 hours NA Unit 1 operating normally. startup Hotrestart. July 26, 2003

- 0.1 hours 67% Unit 1operatingnormally. shutdown April 5-6, 2003

- 1.5 hours 44% Unit !.operatingnormally. startup March 28,2003- 0.0 hours NA Unit 1 operatingnormally. shutdown October 23, 2002- 0.6 hours 35% Unit 1 operating. startup October 18, 2002- 0.1 hours 37% Unit 1 operating. shutdown April 24, 2002

- 3.6 hours 60% Unit 1 operating. startup HotRestart April23, 2002- 0.0 hours NA Unit 1 operating. shutdown March 13-15, 2002 1.6 hours 39% Unit 1 operating. -startup January 26, 2002- 0.3 hours 29% Unit 1 operating. shutdown November 18, 2001 0.9 hours 35% Unit 1 operating. -startup November 17,2001 0.1 hours 49% Unit 1 operating. -shutdown November4-5, 0.0 hours NA Unit 1operating. 2001

- startup



### 5 .,November 3, 2001 0.0 hours NA Unit 1 operating. -shutdown November 2, 2001 0.2 hours 25% Unit 1 operating. -startup October 30, 2001- 0.1 hours 21% Unit 1 operating. shutdown October26, 2001_- 0.0 hours NA Unit 1 operating. startup October24-25, 0.8 hours 35% Unit 1 operating. 2001

- shutdown September 17, 2001 0.3 hours 42% Unit 1 operating.

- startur>_ September 10, 2001 0.0 hours NA Unit 1 operating. -shutdown May 13,2001- 0.1 hours 37% Unit 1 operating. startup May 5, 2001- 0.0 hours NA Unit 1 operating. shutdown January8, 2001- 0.8 hours 30% Unit 1 operating. startup January 5, 2001

- 0.2hours 21% Unit 1 operating. shutdown 

### Air Quality Analysis

. In accordance with therequirements of326 lAC 3-5-1(d), an analysis ofthe air quality

impacts ofthe TAOLbeingrequestedis requiredin addition to the demonstration ofthe needfor an alternative opacitylimitationbased onactual operating opacity. The analysis being suppliedunderthis requirement is basedon.a coldunit startup condition that would take approximately 17.hours from initiation to finally reaching stable full load. Itis assumedthat the first field ofthe electrostatic precipitatoris not energized, for the reasons previously discussed, until the generatingunit surpasses 450 MW ofnet electrical load, which would approximateESP temperatures inthe 200 to 250F degree range.. We have assumed that the ESPefficiency degrades under these conditions from the approximately 99.9% design efficiencyto approximately 60% efficiency until such time as the first field is energized. This assumed degradation is generallyfar greaterthan that experienced, but due to the nearly continuous changes intemperature conditions during a cold startup, these assumptions represent a very conservative estimate ofthe·actualESP efficiencyover the periodofreducedESP operation during the coldstartup. Dueto the transient nature ofstartup conditions, an emission test to determine the actual ESP efficiencyis neither reasonable norpractical. We are not analyzing a shutdown for the following reasons. First, once firing ofthe steamgenerator ceases, the only ash going to theESP is that which is being swept out of the unit under the force ofthe airflow. No additional ash loading is being added sinceno fuel is being combusted. Also, the entireESP is leftin service until the fans are shut



### 6down, which wouldincrease the overall ESPefficiency to above the level assumed for the startup case describedpreviously. Finally, even when the steam generatoris fanned for the purpose ofcoolinguntil reaches near ambienttemperatures, the elapsedtime is far less than thatrequired.for a cold startup, making the previously described startup case a morelimiting casefor conducting the air quality analysis. In developing this analysis, we attempt to examine the various operatingconditions the unit undergoes during a startup. The early stages ofthe startup utilize multiple sets ofoil lighters for a number ofhours with no more than limited coal combustion. Finally, after the unit is placedunderload, the amount ofcoal being burnedis steadilyincreased and the amount ofoil is decreaseduntil only coal is being fired exceptfor shortperiods of time when pulverizers arebroughtinto service. Forthose cases studied where oil is the onlyfuel being combusted;no control from the electrostatic precipitatoris assumed and all ofthe ash is assumed to be PM10. Once coal is being fired, theparticulate emission rateis assumed to be40% ofthe AP-42 uncontrolled emissionrate until the unithas exceeded450MW, when we assume that the emission rate then changes to the NSPS emissionlimit of0.1lb!MMBtu times the estimatedheat inputbasedon an estimated ' . maximumfull loadheatinput of 13,2321\1Jv1Btu perhour. The AP-42 uncontrolled emissionratefor total particulate is_ 

### 10 times the percent ash in the coal, which for the period 2001 to 2003 averaged 5.3%. This equates to an uncontrolled emission factor of 53 lb/ton oftotal particulate. PMto is estimatedbymultiplying the total particulaterate by0.23, which is the scaling factor ofthe AP-42 emission factors for TSP to PM10. fu order to estimate the ambient impacts, the SCREEN3 model was selectedfor this application. SCREEN3 was selected, as itis a very conservative model interms ofthe air qualityimpacts generated andis capable ofdirectly generating 1-hour ambient concentrations under a worst-case meteorologicregime.· Use ofa morerefined model like Industrial Source Complex (ISC) orAERMQD was rejected due to the inabilityof themodels to handle transient conditions, such as a startup, in a reasonable fashion. In addition, the results from the use ofa morerefinedmodel wouldbe very dependent on themeteorology selectedfor the simulation, while the use ofthe SCREEN3 model eliminates this potential bias by allowing the model to find the worst-case meteorologic conditions for a given hour as itis run. In orderto develop the mostlimitingpossible case, we have assumed that the only unitin operation was the unitbeing started up. Table 3 identifies the userinput values used in the modeling simulations. Each ofthese cases was then run_through SCREEN3 with peakterrain values for the distances 0 to 2000 meters, 2000 to 3000 meters, 3000 to 5000 meters, 5000 to 7500 meters and 7500 to 50000meters of5 meters, 16 meters, 19 meters, 31 meters, and 74 meters above stackbase respectively. Theresults ofthese individual simulations were then inputinto a spreadsheet where a 24-hourTSP andPM10 ambient concentrations due solelyto the operation ofthe RockportPlant were determined.



### 7

### a e . tput ata. 

### T bl 3 SCREEN3 In d 

### Case Heat TSP Stack Stack Stack Exit Gas AmbientAir Input Emission Height Inside Flow Temperaure Temperature MMBtu/ Rate (m) Diameter Rate (K) 

### Hr (g[sec) (m) (acfm) 28 Burners on 392 0.73 272.5 12.95 132,661 310.9 

### Oil 42

### Burners on 588 1.09 272.5 12.95 291,070 310.9 

### Oil 70 Burners on 980 1.82 272.5 12.95 331,654 310.9 

### Oil 70 Burners on 1,540 144.3 272.5 12.95 521,169 310.9 

### Oil+7 on Coal w/60% ESPEff. 70 Burners on 2,660 255.15 272.5 12.95 900,203 345.0 

### 0il+7on Coal w/60% ESPEff. 450MWw/ 4,284 646.0 272.5 12.95 1,451,000 394.26 

### 60% ESP Efficiency

SOMW 5,598 70.54. 272.5 12.95 1,894,194 4oo:o 

### 700MW 6,664 83.96 272.5 12.95 2,255,000 408.15 

### lOOOMW 9,520 120.0 272.5 12.95. 3,222,000 422.04 

### FullLoad 13,232 168.0 272.5 12.95 4,478,000 434.26 !Assumes no control effect from ESPdue to ftne particle s1ze (all PM10) and nature of fuel oil ash; A background ambient concentration, based on the lowestfifth high PM10 monitored value in Vanderhurgh and Spencer Counties inIndiana, andDaviess County, Kentucky, during the year 2001 was selected to representbackground since no other sources were consideredin the actual air quality modeling analysis. Thevalue generatedbythis methodwas 24 ug/m3 from the Spencer County, Indianamonitor, AIRS number 1814700088. The selected value in this case shouldnot overlypenalize the sourcebeing studiedby double counting the contribution ofthat source, butmustbe sufficiently conservative to coverthe impacts on a typical day from other sources having a significant impact on the area around the source being studied since they are notbeing explicitly modeled as part ofthis study. Using the fifth high valuefor background overstates the actual background value that wouldbe determined for Prevention ofSignificantDeviation (PSD) purposes. Typically the PSD and National Ambient Air Quality Standards background value wouldbebased on a minimum value since it would onlybe considering the.contribution ofdistant sources to the local ambient concentration. All ofthe sources having a significantlocal impact would be explicitly consideredin the modeling demonstrationinthese cases.



### 8 (K) 293 293 293 293

293

293

293 293 293 293Since we are only explicitlymodeling the impacts ofthe facility being consideredfor the TAOL, backgroundin this case must also account for the impacts ofother area sources as well as the regional background from distant sources.. In addition to the method selected for determining the background, the use ofthe annual arithmetic average was also considered. Forthe five specific monitors consideredfor this study, the range ofaverage daily values was from 19 to 27 ug/m3 for 2001. Considering that the value generatedbythe use ofthe lowest ofthe fifth high values falls within this range, ityields furtherjustification that the use ofthe lowest fifth high value is a reasonablerepresentation ofthe typical air quality in the area surrounding the Rockport Plant. When added to theconservative estimate ofambient impacts from a startup ofthis nature based on the SCREEN3 simulations, weproduce a highly conservative estimate ofthe ambientconditions when the two values are combined. Ifthese values do not exceed any ambient standards, the TAOLbeing requested shouldnotjeopardizethe ambient air quality standardifgranted. Theresults ofthis analysis are shown in Table 4, on the next page. Fromtheseresults, we note that all values are well below the 24-hour ambient standards for bothTSP andPMlO. Weusedthe same background for bothTSP andPMlO since TSP datais no longer available inthe dataset available from the online AIRS**Databas~.** Even with this shortcoming, the TSPvalueis approximately 80% ofthe secondary standard of 150 ug/m3 identified in 326 lAC 1-3-4, which leaves a significant margin of safetyto the secondaryTSP standardidentifiedinthe state regulations shouldthe backgroundbe higher. ThePM10 value determined in this study is approximately33% of thePM10 standards found in 326 lAC 1-3-4 and 40 CFR 50.6. When consideredin conjunction with the conservativenature ofthe SCREEN3 model, this demonstrationis be adequate to demonstrate that the ambient airquality standards for bothTSP and PM10 will beprotected with the approval ofthe requestedTAOL.



### 9

### T bl 4 M d 1' 

### 1 f 

### . d 

### a e . o e mg

### resu ts rom startl!P case exanune . PMRate

### PMto Rate PMCone. PM10 Cone Hour Case (g/sec) (g/sec) (ug!m3) (ug!m3) 1 28 Burnersonoil 0.73 0.73 3.6 3.6 2 42 Burners onoil 1.09 1.09 3.7 3.7 3 70 Burnersonoil 1.82 1.82 5.8 5.8 70 Burners onoil 

### +7 4 burners on coal 86.26 19.84. 202.8 46.6 70 Burnersonoil 

### +7 

### 5 burners on coal oil 86.26 19.84 202.8 46.6 70 Burners onoil 

### +7 6 burners on coal oil 86.26 19.84 202.8 46.6 70 Burners onoil 

### +7 7 burners on coal 86.26 19.84 202;8 46.6 70 Burners onoil 

### +7 

### 8 burners oncoal 86.26 19.84 202.8 46.6 70 Burnersonoil 

### +7 9 burners on coal 86.26 19.84 202.8 46.6 70 Burnersonoil 

### + 14 10 burners on coal 255.15 58.68 241.4 55.5 11 450 MW

- 60% ESP Eff.



### . 646 148.58 339.9 78.2 12 550MW 144.3 33.189 340.4 78.3 13 700MW 83.96 19.3108 30.9 7.1 14 700MW 83.96 19.3108 30.9 7.1 15 1000MW 120 27.6 34.1 7.9 16 1000MW 120 27.6 34.1 7.9 17 FullLoad 168 38.64 35.8 8.2 18 Full Load 168 38.64 35.8 8.2 19 Full Load 168 38.64 35.8 8.2 20 FullLoad 168 38.64 35.8 8.2 21 FullLoad 168 38.64 35.8 8.2 22 Full Load 168 38-.64 35.8 8.2 23 Full Load 168 38.64 35.8 8.2 24 FullLoad 168 38.64 35.8 8.2 24 HourAverage 94.1 22.1 Background 24 24 PeakPredicted Concentration 118.1 46.1



### Conclusions The opacity and air quality analysis presentedin this document.support the conclusion that the Temporary Alternative OpacityLimit (T 

### AOL) for the RockportPlantis

10technicallyjustified and will not cause a violation ofany air quality standards. The air quality analysis was performedin a fashion that generated a worst-case scenario under the assumption that opacity exceedances would be exemptuntil such time as theESP temperatures reached 250 F as requestedinthe August 16, 200llettersubmitted to IDEM requesting the TAOL. Further, since there is no additional ash loadingbeing placedin the boiler during shutdown, the analysis demonstrates thatthis portion ofthe TAOLis also technicallyjustifiedthat the granting of 10 exceedances ofthe 20% opacity standard during shutdown will not cause a violation ofany air quality standard relating to particulate matter.



### 11History ofAEP Rockport Startup/Shutdown Compiled 10-23-13 Opacity Exceedances from Quarterly Reports

Date Unit Start duration hrs Shut duration hrs 12/2/2007 1 0.2 12/5/2007 1 1.6 5/9/2008 1 0.4 4/6/2009 1 0.8 4/2/2009 1 1.8 7/18/2009 1 0.9 7/26/2009 1 2.1 2/20/2010 1 1.2 3/26/2010 1 0.8 11/19/2011 1 0.1

2/5/2011 1 0.2 6/4/2011 1 0.1 9/24/2011 1 1.7 3/2/2012 1 1.1 3/3/2012 1 0.1 11/10/2012 1 0.2 6/6/13 1 0.9 6/18/13 1 0.1

10/10/2007 2 1.3 11/21/2007 2 0.5 11/25/2007 2 0.7 12/3/2007 2 0.5 3/1/2008 2 0.6 3/16/2008 2 1.2 4/1/2008 2 1.1 5/29/2008 2 0.3 5/29/2008 2 0.8 6/15/2008 2 0.4 6/20/2008 2 0.1 5/18/2009 2 0.1 9/26/2009 2 0.8 11/29/2009 2 0.4 3/23/2010 2 0.5 7/26/2010 2 0.2 9/4/2010 2 0.4 11/20/2010 2 0.5

1/5/2011 2 2 4/12/2011 2 1.3 7/25/2011 2 0.6 11/1/2011 2 0.33/19/2012 5/5/2012 10/4/2012 10/11/2012

2/2/2013 5/10/2013

6/8/13 2 2 2 2 2 2 2 History ofAEP Rockport Startup/Shutdown Opacity Exceedances from Quarterly Reports

0.1 0.6 0.2 0.5 0.4 0.4 0.2 Compiled 10-23-13

## Air Quality Analysis Indiana Michigan Power Company dba American Electric Power, (AEP) Rockport, Indiana (Spencer County) Plant 10: 147-00020

Indiana Michigan Power Company dba American Electric Power (AEP) at Rockport operates a coal-fired electric generating station in Rockport (Spencer County), Indiana, consisting oftwo (2) units, boiler Units 1 and 2. Both ofthese units are subject to the New Source Performance Standard (NSPS) for fossil fuel fired steam generators. Since the NSPS does not apply emission limits during startup and shutdown, the opacity limit in 3261AC 5-1-2 applies to these units during those operations. Indiana's opacity rules in 3261AC 5-1-3(d) allow a source to request a temporary alternative opacity limit {T AOL) for periods of startup and shutdown of a boiler. AEP has requested a TAOL for both boilers (Units 1 and 2) at its Rockport Generating Station. Section 326 lAC 5-1-8 was added to provide AEP a site specific TAOL.

The Office ofAir Quality (OAQ) performed a PM2.5 air quality modeling analysis to confirm the TAOL will not have an adverse impact on the National AmbientAir Quality Standards (NAAQS). Two different modeling scenarios were examined and both showed no adverse impact on air quality in the area.

The purpose ofthe air quality impact analysis in the permit application is to accomplish the following objectives. Each objective is individually addressed in this document in each section outlined below. A. Emissions analyzed for the air quality impact. B. Provide analyses ofactual stack heights with respect to Good Engineering Practice (GEP), the meteorolbgical data used, a description ofthe model used in the analysis, the receptor grid utilized for the analyses, and the treatment ofterrain. C. Demonstrate that the source will not cause or contribute to a violation ofthe NAAQS. D. Summarize the Air Quality Analysis.

Proposed Startup and Shutdown Emissions The emissions data was provided by AEP from their May 2004, supplemental technical support document. The emission rates shown in Table 1 below were based on a cold unit startup scenario that would take approximately 17 hours to reach full load. The cold unit startup was a more constricting ·

1scenario when evaluated with shutdown conditions. During shutdown, the electrostatic precipitator (ESP) is left in operation until the fans are shut off. This would increase the overall ESP control efficiency above the level assumed for the startup case. Plus, fuel is not being combusted during a shutdown operation and no additional ash loading is being added. Ifone unit is up and running during a startup or shutdow_n ofthe other unit, the temperature and flow rates would be higher and this would not be the most constraining scenario since the two units share a common stack. Both boiler units have the same maximum capacity. AEP provided o·nly PM and PM 10 emission rates. It is assumed that PM2.s would be some fraction ofthe PM 10 emission rates. Due to the difficulty in calculating PM2.5 emission rates, OAQ assumed .all PM 10 emissions are PM2.5 for both worst case modeling scenarios. This assumption makes the analysis more conservative in nature since PM2.5 emissions are probably less than PM 10 emissions during startup and shutdown.

Hour

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 TABLE 1 Startup Emission Rates

Startup Event PM1o Source Emission Rates (grams per second) 28 Burners on oil 0.73 42 Burners on oil 1.09 70-Burners on oil plus 7 burners on coal 1.82 70 Burners on oil plus 7**burne~s** on coal 19.84 70 Bufners on oil plus 7 burners on coal 19.84 70 Burners on oil plus 7 burners on coal 19.84 70 Burners on oil plus 7 burners on coal 19.84 70 Burners on oil plus 7 burners on coal 19.84 70 Burners on oil plus 7 burners on coal 19.84 70 Burners on oil plus 14 burners on cqal 58.68 450 MW- 60% ESP Eff. 148.58 550MW 33.189 700MW 19.3108 700MW 19.3108 1000MW 27.6 1000MW 27.6 Full Load 38.64 Full Load 38.64 Full Load 38.64

220 Full Load 38.64 21 Full Load 38.64 22 Full Load 38.64 23 Full Load 38.64 24 Full Load 38.64

Stack Height Compliance with Good Engineering Practice (GEP) Applicability Stacks should comply with GEP requirements established in 326 lAC 1-7-4. Ifstacks are lower than GEP, excessive ambient concentrations due to aerodynamic downwash may occur. Dispersion modeling credit for stacks taller than 65 meters (213 feet) is limited to GEP for the purpose of establishing emission limitations. The GEP stack height takes into account the distance and dimensions of nearby structures, which affects the downwind wake ofthe stack. The downwind wake is considered to extend five times the lesser ofthe structure's height orwidth. A GEP stack height is determined for each nearby structure by the following formula: · ·

Where:

Stacks Hg = H + 1.5L Hg is the GEP stack height H is the structure height Lis the structure's lesser dimension (height orwidth)

The physical stack heights for AEP are above GEP stack height, so only the GEP height is allowed in the modeling. The effect ofaerodynamic downwash is accounted for in the air quality analysis for the project. Meteorological Data The National Weather Service (NWS) 1-minute Automated Surface Observation Station (ASOS) meteorological data used in AERMOD consisted of2008 through 2012 surface data from Evansville, Indiana and upper air measurements taken at Lincoln, Illinois. The meteorological data was preprocessed using the latest versions ofAERMINUTE, AERSURFACE, and AERMET at the time the air quality analysis was conducted for the TAOL. Model Description OAQ used AERMOD Version 12345. All regulatory default options were utilized in ttle U.S. EPA approved model, as listed in the 40 Code of Federal Register Part 51, Appendix W "Guideline on Air Quality Models". · Receptor Grid The receptor grid is outlined below:

• 100 meter spacing along the facility's property boundary,

3• 250 meter spacing out to 250 meters, • 500 meter spacing out to 500 meters, • 1000 meters spacing out to 1000 meters, • 2000 meters spacing out to 10,000 meters, • 5000 meters spacing out to 50,000 meters. Treatment ofTerrain Receptor terrain elevation inputs were interpolated from NED (National Elevation Dataset) data obtained from the USGS. NED terrain data was preprocessed using AERMAP.

OAQ performed two modeling scenarios to address the TAOL. Only the 24-hour averaging time was examined since startup and shutdown emission rates are short term in nature. Scenario 1 - Modeling Assumptions OAQ assumed the worst case emission rate would occur for the entire 24-hour period continuously. This would be Hour 11 which has the emission rate of 148.58 g/s. The se<;:ond highest emission rate is 58.68 g/s which is well below the emission rate in Hour 11. Also, the physical stack height was 272.5 meters. Using the GEP stack height formula, GEP stack height is 220.7 meters. OAQ set the stack heightjust below GEP at 219.5 meters. The stack flow rate was set at the lowest rate of 132,661 actual cubic feet per minute (acfm) which was for Hour 1 and not for Hour 11. The flow rate for Hour 11 was 1,451,000 acfm which is almost 11 times greater than Hour 1. The temperatu're was set for 310.9 degrees Kelvin. Again, this was the lowest temperature for the 24-hour startup period. As discussed earlier, OAQ assumed all PM 10 emission rates are PM2.5. Looking at the previous modeling work done for the Indiana PM opacity rule, PM 10 was the pollutant examined and not PM2.5. The new PM2.5standards are more constraining than the PM 10 standards. This adds another level of conservatism. · Examining PM2.5 background values also show that they are more constrictive when compared to PM 10 background. For the years 2011-2013, the PM 10 monitored design values range approximate!¥ 31 ug/m3 to 119 ug/m3 below the standard whereas the PM2.5 monitored design values are only 7 ug/m to 14 ug/m3 below the standard. There is a huge disparity between PM 10 and PM2.5 backgrounds. When adding calculated PM2.5 modeling concentrations to background, PM2.5values would have to be·a lot lower in magnitude to be below the NAAQS. Since conservative assumptions were made in Scenario 1, background was not added to the modeled concentration to avoid "double counting". This was to avoid adding AEP's conservative modeled impact to monitoring that records their PM2.5 contribution already. · U.S. EPA has also given a positive indication that this scenario would be approvable the way it is currently presented. Results for the Scenario 1 analysis are provided in Table 2.

4Table 2 Scenario 1 NAAQS Results Polluta.nt Year Time-Averaging Maximum Total NAAQS Limit NAAQS Period Concentration ug/m3 ug/m3 Violation ug/m3 PM2.s 2008- 24-hour 22.2 22.2 35 No 2012 Scenario 2 - Modeling Assumptions OAQ assumed anotherworst case scenario by averaging "all" the different emissions over the 24- hour period. This worst case scenario takes into account the total emissions for the 24-hour period. This approach assumes all the same stack parameters are the same as Scenario 1 except using an emission rate which is averaged. The average emission rate for Scenario 2 is 31.9 g/s. Intermittent emissions can be defined as emergency generators, startup and shutdown operations, or from any intermittent emission scenarios which are random in nature and not scheduled. OAQ believes AEP meets this definition for intermittent emissions for their startup and show down operations and this scenario provides a better characterization ofthe emissions. By defining the operation as intermittent, the emissions can be average over time. This scenario provides a more realistic approach but with conservatism still built into the analysis with the use of all the stack parameter assumptions from Scenario 1. This methodology for intermittent emissions follows OAQ's Prevention of Significant Deterioration (PSD) source review procedures. Since this analysis uses emission averaging, it also lends itselfto adding background to the modeled concentration. Results for the Scenario 2 analysis are provided in Table 3. Table 3 Scenario 2 NAAQS Results Pollutant Year Time-Averaging Maximum Background Total NAAQS Limit NAAQS Period Concentration Concentration ug/m3 ug/m3 ug/m3 Violation ug/m3 PM2.s 2008- 24-hour 4.76 241 28.76 35 No 2012 The latest 3years 2011-2013 were used. Background data was taken from a representative monitoring station. The Dale monitor is in the same county as AEP and is approximately 20 miles due north from the facility. The monitor under certain meteorological conditions probably records AEP's presence in the area: AEP's physical stack height is · 272.5 meters (894 feet) which allows emissions to be carried greater distances.

OAQ modeled two worst case operating scenarios to demonstrate the new 24-hour PM2.5 NAAQS would be protected. Each scenario showed no violations ofthe standard when modeling for AEP's proposed TAOL during periods ofstartup and shutdown.

5