INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

We Protect Hoosiers and Our Environment. 

Michael R. Pence 

Govemor 

Susan Hedman 

Regional Administrator 

U.S. EPA, Region 5 

77 West Jackson Boulevard 

Chicago, Illinois 60604 

Dear Ms. 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 · 

Indiana Regarding 326 lAC 5-1-8, AEP Rockport 

(LSA #12-392) 

Pursuant to Section 110 of the Clean Air Act and Title 13 of the Indiana Code, the 

Indiana Department of Environmental Management (IDEM) submits an amendment to the 

Indiana state implementation plan (SIP). This amendment consists of the addition of326 lAC 5-

1-8 accomplished through one rulemaking. IDEM requests that the United States Environmental 

Protection Agency (U.S. EPA) approve 326 lAC 5-1-8. 

This SIP revision adds Temporary Alternative Opacity Limits (TAOL) for two units at 

American Electric Power (AEP) Rockport located in Spencer County. Both ofthe units have 

continuous opacity monitoring systems (COMS). IDEM has provided three parts to the 

Technical Support Documentation in Attachment 1: (1) May 19,2004 Technical Support 

Document from American Electric Power (AEP) with information on pollution control practices 

and operation and maintenance procedures; (2) a spreadsheet listing the duration (hours) of 

startup and shutdown opacity exceedances used to develop the Temporary Alternative Opacity 

Limit (TAOL); and (3) modeling. These two units are also subject to the Mercury and Air Toxics 

(MATS) rule. On November 19, 2014, U.S. EPA published revisions to the MATS rule 

addressing startup and shutdown provisions. The MATS rule requires specified work practice 

standards during startup and shutdown. During startup, facilities are either required to engage all 

controls once coal is fired and use clean fuels during startup, or use clean fuels during startup to 

the maximum extent possible and engage the particulate matter control device within one hour of 

adding coal. The latter option applies when facilities are limiting startup to four hours after a 

unit begins generating electricity instead of startup ending when any electricity is generated. 

Either way facilities subject to MATS are striving to engage their controls as soon as it is safe. 

This submittal consists of one (1) hard copy of the required documentation. An 

electronic version of the submittal in PDF format that is identical to the hard copy has been sent 

to Chris Panos at the U.S. EPA Region 5 office. In order to assist with your review of this state 

implementation plan submission, a list of suppmting documents is attached. 

An Equal Opportunity Employer 0 @ Recycled Paper A State that Works 

-
Throughout the development of this rule~ staff of the Office of Legal Counsel worked 

closely with your staff to ensure that any potential problems that might exist with this requested 

state implementation plan revision would be resolved. I request that U.S. EPA approve this 

modification of Indiana's state implementation plan. If you have any questions regarding this 

submittal, please contact Christine Pedersen, Rule Development Section Chief, Office of Legal 

Counsel at (317) 233-5684. 

NK/sb 

Attachments: . Supporting Documents 

cc: John Mooney, U.S. EPA Region V (no enclosures) 

Pamela Blakley, U.S. EPA Region V (no enclosures) 

Doug Aburano, U.S. EPA Region V (no enclosures) 

Steve Rosenthal, U.S. EPA Region V (no enclosures) 

Christine Pedersen, IDEM (no enclosures) 

SIP file 
Supporting 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: Second Notice of Public Comment Period, including the Notice of Public Hearing, as 

published in the Indiana Register on February 12, 2014 (DIN: 20120711-IR-326120392FNA) 

Attachment E: Certificates of Web Publication 

Attachment F: Transcript of First Public Hearing held on June 11, 2014 

Attachment G: Proposed Rule, including the Notice of Public Hearing, as published in the Indiana 

Register on July 30, 2014 (DIN: 20140730-IR-326120392PRA) 

Attachment H: Transcript of Second Public Hearing, including Response to Comments from Third 

Comment Period, held on September 10, 2014 

Attachment I: Technical Support 
ADMINISTRATIVE CHECKLIST (40 CFR 51, Appendix V) 

1. The submittal is accompanied by a formal letter of submittal Enclosed 

from the governor or his designee. 

2. Evidence that the State has adopted the plan in the State code Attachment C 

or body of regulations; or issued the permit, order, consent 

agreement ("document"); in final fmm. 

a. Date of adoption or final issuance: November 6, 2014 

b. The effective date of the plan, if different December 6, 2014 

from the adoption/issuance date. 

3. Evidence that the State has the necessary legal authority IC 13-14-8 

under state law to adopt and implement the plan. 

4. A copy of the actual regulation or document submitted for Attachment B 

approval and incorporation by reference into the plan, 

including the following: 

a. Indication of the changes made to the existing 

approved plan, where applicable. 

b. The submittal shall be a copy of the official State 

regulation or document signed, stamped, dated by 

the appropriate state official indicating that it is fully 

enforceable by the State. Effective date shall be stated 

in the document itself. 

5. Evidence that the State followed all of the procedural 

requirements of the State's laws and constitution in 

conducting and completing the adoption/issuance of the plan. 

Attachment C 

6. Evidence that public notice was given, including date of Attachments D, E, and G 

proof of publication. 

_x_Notice of First Public Hearing and Certificates of Web Publication 

_x_ Notice of Second Public Hearing and Certificates of Web Publication 

7. Ce1iification that public hearings were held in accordance 

with information provided in public hearing notice. 

_x_ Transcript from First Public Hearing 

_x_ Transcript from Second Public Hearing 

8. Compilation of public comments and State's response. 

x Second Notice 

_x_ Proposed Rule 

x Third Comment Period 

9. Technical Suppmi Document (if source specific change). 

Attachments F and H 

Attachments D, F, G and H 

Attachment I 
Indiana 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) of this 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) of this 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 of this rule for a period not to exceed a total of two (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 of the electrostatic precipitators, whichever occurs first. 

(2) When shutting down a boiler, opacity may exceed the applicable limitation established in section 2 

of this rule once the flue gas temperature has dropped below two hundred fifty (250) degrees 

Fahrenheit at the inlet of the 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 

Approved by Attorney General: October 24, 2014 

Approved by Governor: November 5, 2014 

Filed with Publisher: November 6, 2014, 10:00 a.m. 

Documents Incorporated by Reference: None Received by Publisher 

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 by Legislative Services Agency 

An html version of this document. 

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

Rule#: 

Agency: 

Subject: 

ADOPTED: 

LSA Document#12-392(F) 

Environmental Rules Board 

Rockport TAOL 

By:d~-~ Beverly J. Gard 

Chairperson, Environmental Rules Board 

APPROVED: 

Governor, State of Indiana 

ACCEPTED FOR FILING: 

By: TITLE 326 AIR POllUTION CON1ROL DIVISION 

LSA Document #12-392(FR) 

Filed with Publisher: 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 of Title 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 of two 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 of 250 degrees Fahrenheit at the inlet of the 

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 not jeopardize continued attainment of the particulate matter air quality standard (PM10). AEP 

Rockport's units did not have preexisting opacity exemptions in their permits at that time, and therefore, are not 

part of the 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 of the Title V permit. IDEM has conducted modeling that 

indicates the T AOL 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 of the 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 1 
Indiana 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. If you 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 of the 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 of the 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 T AOL that has been requested as part of the initial Title V permit issued to 

the source. Since that time the Title V permit opacity provision containing the T AOL has been under appeal and 

Indiana Michigan Power has been working with IDEM to develop permit language acceptable to both parties as 

part of the settlement of the larger permit appeal. IDEM has not previously incorporated any TAOLs for startup 

and shutdown, as is contemplated by the T AOL being developed for Rockport. The T AOL 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 of Air 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 of the 

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 of the 

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 of the National Ambient Air Quality Standards (NAAQS). Modeling 

conducted by I OEM indicates that the proposed T AOL will not impact the maintenance of the 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 of the 

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 of faxed comments by calling the Rules 

Development Branch at (317) 233-8903. 

(3) By electronic mail to sbem@idem.in.gov. To confirm timely delivery of submitted comments, please 

request a document receipt when sending the electronic mail. PLEASE NOTE: Electronic mail comments 

will NOT be considered part of the 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 of the 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 of the 

Date: Dec 30,2014 9:16:14AM EST DIN: 20140212-IR-326120392SNA Page 2 
Indiana 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) of this 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) of this 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 of this rule for a period not to exceed a total of two (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 of the electrostatic precipitators, whichever occurs first. 

(2) When shutting down a boiler, opacity may exceed the applicable limitation established in section 2 

of this rule once the flue gas temperature has dropped below two hundred fifty (250) degrees 

Fahrenheit at the inlet of the 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 5-1-8) 

Notice of Public Hearing 

Posted: 02/12/2014 by Legislative Services Agency 

An html version of this document. 

Date: Dec 30,2014 9:16:14AM EST DIN: 20140212-IR-326120392SNA Page 3 
Indiana 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 of the public hearing for LSA Document #12-392, 

posted at 20140212-IR-326120392SNA, has been changed. The changed Notice of Public Hearing appears 

below: 

Notice of Public Hearing 

Under IC 4-22-2-24. IC 13-14-8-6, and IC 13-14-9, notice is hereby given that on June 11, 2014, at 1:30 

p.m., at the Indiana Government Center South, 302 West Washington Street, Conference Center Room A, 

Indianapolis, Indiana, the Environmental Rules Board will hold a public hearing on amendments to 326 lAC 5-1 

concerning temporary alternative opacity limitations (TAOL) for the AEP Rockport Generating Station. 

The purpose of this hearing is to receive comments from the public prior to preliminary adoption of these 

rules by the board. All interested persons are invited and will be given reasonable opportunity to express their 

views concerning the proposed amendments. Oral statements will be heard, but, for the accuracy of the record, 

all comments should be submitted in writing. 

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). 

Individuals requiring reasonable accommodations for participation in this event should contact the Indiana 

Department of Environmental Management, Americans with Disabilities Act coordinator at: 

Attn: ADA Coordinator 

Indiana Department of Environmental Management 

Indiana Government Center North 

100 North Senate A venue 

Indianapolis, IN 46204-2251 

or call (317) 233-1785 (V). Speech and hearing impaired callers may contact IDEM via the Indiana Relay Service 

(711) or (BOO) 7 43-3333. Please provide a minimum of 72 hours notification. 

Copies of these rules are now on file at the Rules Development Branch, Office of Legal Counsel, Indiana 

Department of Environmental Management, Indiana Government Center North, 100 North Senate Avenue, 

Thirteenth Floor and Legislative Services Agency, Indiana Government Center North, 100 North Senate Avenue, 

Room N201, Indianapolis, Indiana and are open for public inspection. 

Nancy King, Chief 

Rules Development Branch 

Office of Legal Counsel 

Posted: 05/0712014 by Legislative Services Agency 

An html version of this document. 

Date: Dec 30,2014 9:22:51AM EST DIN: 20140507-IR-326120392CHA Page 1 
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

We Protect Hoosiers and Our Environment. 

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 

May 2, 2014 

CERTIFICATE OF PUBLICATION 

This is to certify that the Indiana Department of Environmental Management (IDEM) Notice of 

Public Hearings for the Environmental Rules Board Meeting, 06/11/2014, regarding the 

following rulemaking actions: 

• Global Warming Potentials Table Update, LSA #14-56 

• Rockport Temporary Alternative Opacity Limit, LSA #12-392 

was published on IDEM's web site on or before May 5, 2014. It will remain posted on the site 

until at least June 11, 2014. 

The notice in full may be found at the following web address, under the "Statewide" category. 

http://www.in.gov/idem/6777.htm 

Web publication of the notice was at the request of Christine Pedersen, Section Chief, Rule 

Development Section, Office of Legal Counsel, IDEM. 

Attachments: 

Copy of web page as published. 

An Equal Opportunity Employer 

By: 

Mike Finkelstein 

IDEM Webmaster 

0 

A State that Works 

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PUBUC NOTOOCES: STATEWIDE 

Tl1is is tile IDEM Public t-IGti·De Site ior notices co.vering the entire State of Indiana. Tl1is pa g;e 

puhlic notices as requir•erl by starute or rule includling:: permitting, rulmtaiking. meeting: ami 

information related to the nmice. For puhlit not requiring!.I1Dtices, please cll!?C!:: th!? 

Sub-Scriptions: Want to lcrlow abo•ut .as as lhey'-re j:losteci? Yoll can no-w 

regioo, you will be sent an e-mail ortexrr messa:g;g to.yo•ur phone eJtery time lnEM adds 

.all ami never miss a new posting. To subscribe, clicl:on til!! subscription link in the 

Statewide 

Tfpe of HoticetEl'ent 

fiROFl 

IROFl 

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u 12 13 14 15 16 17 

18 19 20 21 22 23 24 

25 26 27 28 29 30 31 

Current time zone: Eastern Daylight Time 

) 

111
. Legal Notice of Public Hearing 

Under 40 CFR 51.102, notice is hereby given that the Environmental Rules Board (board) will 

hold a public hearing at its regularly scheduled meeting on Wednesday, June 11, 2014, for each 

of the air program rules listed in this notice. The meeting will convene at 1:30 p.m. at the Indiana 

Government Center-South, Conference Room A, 302 West Washington Street, Indianapolis, 

Indiana. The purpose of the hearing is to receive public comments prior to board action. All 

interested persons are invited and will be given a reasonable opportunity to express their views 

concerning the proposed action. 

Board documents may be viewed and downloaded from the Indiana Department of 

Environmental Management's Web site as early as one week prior to the meeting·at 

http://www.in.gov/idem/4696.htm. 

Copies of the proposed air program rules are also available to any person upon r~quest, may be 

viewed online via the Internet from local libraries, and are available for public inspection at the 

following locations: 

Indiana Department of Environmental Management, Office of Legal Counsel, Indiana 

Government Center-North, 100 Nmih Senate Avenue, 13th Floor, Indianapolis, Indiana 46204. 

Indiana Department of Environmental Management, Northwest Office, 330 West US 

Highway 30, Suites E and F, Valparaiso, IN 46385. 

Indiana Department of Environmental Management, Nmihern Office, Suite 450, 300 N. 

Michigan Street, South Bend, Indiana 46601. 

Indiana Department of Environmental Management, Southwest Office, 1120 North 

Vincennes Avenue, P.O. Box 128, Petersburg, Indiana 47567-0128. 

Indiana Department of Environmental Management, Southeast Office, 820 West Sweet 

Street, Brownstown, Indiana47220-9557. 

Legislative Services Agency, Indiana Government Center-North, 100 North Senate 

Avenue, Room N201, Indianapolis, Indiana 46204. 

The following air program rules are noticed for hearing and action: 

Global Warming Potentials Table Update (LSA # 14-56). The purpose of this hearing is to. 

receive public comment prior to adoption of amendments to 326 lAC 2-2-1 and 326 IAC 2-7-1 

concerning revisions to the global warming potentials table for consistency with federal 

requirements and to streamline the development of Prevention of Significant Deterioration (PSD) 

and Title V air permits. This rule will be submitted to the United States Environmental 

Protection Agency as a revision to the State Implementation Plan required by the Clean Air Act. 

A copy of the most recently published version of this rule is available at: 

http://Www.in.gov/idem/5679 .htm. 

For additional mformation concerning this rule contact Susan Bern at the Indiana 

Depa1iment of Environmental Management, Office of Legal Counsel, Indiana Government 

Center North, 100 North Senate Avenue, Indianapolis at (317) 233-5697 or (800) 451-6027 (ext. 

3-5697)(in Indiana), or sbem@idem.in.gov. 
Rockport Temporary Alternative Opacity Limit (LSA # 12-392). The purpose of this 

hearing is to receive public comment prior to adoption of a new rule at 326 lAC 5-1-8 

concerning temporary alternative opacity limitations (TAOL) for the AEP Rockport Generating 

Station. This rule will be submitted to the United States Environmental Protection Agency as a 

revision to the State Implementation Plan required by the Clean Air Act. A copy of the most 

recently published version ofthis rule is available at: http://www.in.gov/idem/5679.htm. 

For additional information conceming this rule contact Susan Bern at the Indiana 

Department ofEnvironniental Management, Office ofLegal Counsel, Indiana Government 

Center North, 100 Nmih Senate Avenue, Indianapolis at (317) 233-5697 or (800) 451-6027 (ext. 

3-5697)(in Indiana), or sbem@idem.in.gov. 

. For these hearings, oral statements will be heard, but for the accuracy of the record, 

please submit statements in writing to the attendant designated to receive written comments at 

the public hearings. 

A transcript of the hearings and all written submissions to the board at the public headngs 

shall be open to public inspection at the Indiana Depatiment of Environmental Management; 

copies may be made available to any person upon payment of reproduction costs. Any person 

heard or represented at the hearings or requesting notice shall be given written notice of the 

actions of the board. · 

Christine Pedersen, Chief 

Rules Development Section 

Office ofLegal Counsel 

******************************************************************~*********** 

Individuals requiring reasonable accommodations for participation in this event should contact 

the Indiana Department of Environmental Management, Americans with Disabilities Act· 

coordinator at: 

Attn: ADA Coordinator 

Indiana Depatiment of Environmental Management 

100 N. Senate Avenue· 

Indianapolis, IN 46204. 

or call (317) 233-1785. Speech and hearing impaired callers may contactthe agency via the 

Indiana Relay Service at 1-800-743-3333. Please provide a minimum of72 hours' notification. 
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

We Protect Hoosiers and Our Environment. 

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 OF PUBLICATION 

This is to certify that the Indiana Department of Environmental Management (IDEM) Notice of 

Public Hearings for the Environmental Rules Board Meeting, 09/10/2014, regarding the 

following rulemaking actions: 

• Rockport Temporary Alternative Opacity Limit, LSA #12-392 

• Stage II Vapor Recovery Systems, LSA #12-636 

was published on IDEM's web site on or before August 1, 2014. It will remain posted on the site 

until at least September 10,2014. 

The notice in full may be found at the following web address, under the "Statewide" category. 

http:/ /www.in. gov /idem/ 6777 .htm 

Web publication of the notice was at the request of Christine Pedersen, Section Chief, Rule 

Development Section, Office of Legal Counsel, IDEM. 

Attachments: 

Copy of web page as published. 

An Equal Opporhmity Employer 

By: 

Mike Finkelstein 

IDEM Webmaster 

A State that~ @ Recycled Paper 
Findant-.g:n·:;y Fln:la Per::on Ao::ourttO:-nte:l Onli():;'ier\•l:e::: FAO:: A·6A+ GOVERNOR 

MIKE PENCE INgov 

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,.-Date ..-Time----

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(to:34:30AM 

It oK ! 
Legal Notice of Public Hearing 

Under 40 CFR 51.102, notice is hereby given that the Environmental Rules Board (board) will 

hold a public hearing at its regularly scheduled meeting on Wednesday, September 10, 2014, for 

each of the air program rules listed in this notice. The meeting will convene at 1:30 p.m. at the 

Indiana Government Center-South, Conference Room A, 302 West Washington Street, 

Indianapolis, Indiana. The purpose of the hearing is to receive public comments prior to board 

action. All interested persons are invited and will be given a reasonable opportunity to express 

their views concerning the proposed action. 

Board documents may be viewed and downloaded from the Indiana Department of 

Environmental Management's Web site as early as one week prior to the meeting at 

http:/ /www.in.gov/idem/4696.htm. · 

Copies of the proposed air program rules are also available to any person upon request, may be 

viewed online via the Internet from local libraries, and are available for public inspection at the 

following locations: 

Indiana Department of Environmental Management, Office of Legal Counsel, Indiana 

Government Center-North, 100 North Senate Avenue, 13th Floor, Indianapolis, Indiana 46204. 

Indiana Department of Environmental Management, Northwest Office, 330 West US 

Highway 30, Suites E and F, Valparaiso, IN 46385. 

Indiana Department of Environmental Management, Northern Office, Suite 450, 300 N. 

Michigan Street, South Bend, Indiana 46601. 

Indiana Department ofEnvironmental M~nagement, Southwest Office, 1120 North 

Vincennes Avenue, P.O. Box 128, Petersburg, Indiana 47567-0128. 

Indiana Department of Environmental Management, Southeast Office, 820 West Sweet 

Street, Brownstown, indiana 47220-9557. 

Legislative Services Agency, Indiana Government Center-North, 100 North Senate 

Avenue, Room N201, Indianapolis, Indiana 46204. 

The following air program rules are noticed for hearing and action: 

Rockport Temporary Alternative Opacity Limit (LSA # 12-392). The purpose of this hearing 

is to receive public comment prior to final adoption of a new rule at 326 lAC 5-1-8 concerning 

temporary alternative opacity limitations (TAOL) for the AEP Rockport Generating Station. 

This rule will be submitted to the United States Environmental Protection Agency as a revision 

to the State Implementation Plan required by the Clean Air Act. A copy of the most recently 

published version of this rule is available at: http://www.in.gov/idem/5679.htm. 

For additional information concerning this rule contact Susan Bern at the Indiana 

Department of Environmental Management, Office of Legal Counsel, Indiana Government 

Center Nmih, 100 Nmih Senate Avenue, Indianapolis at (317) 233-5697 or (800) 451-6027 (ext. 

3-5697)(in Indiana), or sbem@idem.in.gov. 

Stage II Vapor Recovery Systems. (LSA # 12-636). The purpose of this hearing is to receive 

public comment prior to preliminary adoption of amendments to 326 lAC 2-11-2, 326 lAC 8-4-
1, and 326 lAC 8-4-6 concerning revisions to stage II vapor recovery system requirements for 

consistency with U.S. EPA's determination that on board refueling vapor recovery technology is 

in widespread use and that stage II vapor recovery systems are no longer required in certain 

ozone nonattainment areas as long as the National Ambient Air Quality Standards for ozone are 

met. This rule will be submitted to the United States Environmental Protection Agency as a 

i'evision to the State Implementation Plan required by the Clean Air Act. A copy of the most 

recently published version ofthis rule is available at: http://www.in.gov/idern/5679.htm. 

For additional infmmation concerning this rule contact Christine Pedersen at the Indiana 

Department of Environmental Management, Office of Legal Counsel, Indiana Government 

Center North, 100 Nmih Senate Avenue, Indianapolis at (317) 233-5684 or (800) 451-6027 (ext. 

3-5684)(in Indiana), or cpederse@idem.in.gov. 

For these hearings, oral statements will be heard, but for the accuracy of the record, . 

please submit statements in writing to the attendant designated to receive written comments at 

the public hearings. . 

A transcript of the hearings and all written submissions to the board at the public hearings 

shall be open to public inspection at the Indiana Depmiment of Environmental Management; 

copies may be made available to any person upon payment of reproduction costs. Any person 

heard or represented at the hearings or requesting notice shall be given written notice of the 

actions of the board. 

Christine Pedersen, Chief 

Rules Development Section 

Office of Legal Counsel 

****************************************************************************** 

Individuals requiring reasonable accommodations for pmiicipation in this event should contact 

the Indiana Depmiment of Environmental Management, Americans with Disabilities Act 

coordinator at: 

Attn: ADA Coordinator 

Indiana Depatiment of Environmental Management 

100 N. Senate A venue 

Indianapolis, IN 46204 

or call (317) 233-1785. Speech and hearing impaired callers may contact the agency via the 

Indiana Relay Service at 1-800-743-3333. Please provide a minimum of 72 hours' notification. 
. ) 

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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. 

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ACCURATE REPORTING OF INDIANA 

William F. Daniels Prop. RPR/CP CM 

12922 Brighton Avenue 

Carmel, Indiana '46032 

(317) 848-0088 

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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. 

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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 

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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. 

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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 

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23 to zero to finally adopt the amendments to the Global 

24 

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Warming Potentials Table. 

Next on the agenda is a public hearing 
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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 

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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 

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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 
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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 

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the proposed temporary alternative opacity limit will 

not impact maintenance of air quality standards. 
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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 

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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. 
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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. 

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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 

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well as working with IDEM to develop the necessary 

rule language which is now before you for preliminary 
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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 

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25 it's sort of "Yeah, you really are entitled to them 
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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 
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.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? 

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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 matter 
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1 and these temporary alternative opacity limits. 

2 Opacity is the primary method.of measuring 

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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 
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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 

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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· 
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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 
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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 

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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. 

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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. 

21 TED NIEMIEC: I have a question. Would 

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 that 
38 

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 

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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 

4 order to not deviate? 

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, we 
41 

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. 
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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? 

17 CHRIS PEDERSEN: Yes. 

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 

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CHAIRMAN ETZLER: That's correct. 

KEN RULON: Okay, so thank you. I would move 
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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.) 

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1 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 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. 

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 of the comments received and IDEM's responses thereto: 

Comment: Since the time of the issuance of the 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 of the settlement of the 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 of two (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 of the 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 of the 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 of the 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 of this 

rule once the flue gas temperature has dropped below two hundred fifty (250) degrees Fahrenheit at the inlet 

of the 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 of the Sierra Club Hoosier Chapter (SC) 

Following is a summary of the 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 1 
Indiana 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 of the opacity limit. Installing additional 

controls is a major investment and is not warranted in this situation. Adding a bag house 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 of the 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 of the 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 of 250 degrees Fahrenheit at the inlet of the bag houses 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 not jeopardize continued attainment of the 

particulate matter air quality standard (PM10). 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 of the limited exemption in 326 lAC 5-1-3(e). 

Therefore, AEP Rockport has requested a T AOL for their facility. 

Comment: AEP must demonstrate that the temporary alternative opacity limits will not interfere with the 

maintenance of the National Ambient Air Quality Standards (NAAQS). IDEM's modeling to evaluate impact of this 

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 of the 

nature of the 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 PM10 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 

PM10 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 of the particulate matter NAAQS. IDEM is considering running another 

modeling scenario that takes into account the intermittent nature of these emissions that would include the 

background concentration. U.S. EPA will 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 of the TAOL because the structure of the T AOL 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 of 250 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 2 
Indiana 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) of this 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) of this 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 of this rule for a period not to exceed a total of two (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 of the electrostatic precipitators, whichever occurs first. 

(2) When shutting down a boiler, opacity may exceed the applicable limitation established in section 2 

of this rule once the flue gas temperature has dropped below two hundred fifty (250) degrees 

Fahrenheit at the inlet of the 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; 326 JAG 5-1-8) 

Notice of Public Hearing 

Posted: 07/30/2014 by Legislative Services Agency 

An html version of this document. 

Date: Dec 30,2014 9:15:42AM EST DIN: 20140730-IR-326120392PRA Page 3 
Indiana Register 

TITLE 326 AIR POLLUTION CONTROL DIVISION 

Notice of Public 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 hereby given that on September 10, 2014, at 

1:30 p.m., at the Indiana Government Center South, 302 West Washington Street, Conference Center Room A, 

Indianapolis, Indiana, the Environmental Rules Board will hold a public hearing on amendments to 3261AC 5-1 

(adds 326 lAC 5-1-B) concerning temporary alternative opacity limitations (TAOL) for the AEP Rockport 

Generating Station. 

The purpose of this hearing is to receive comments from the public prior to final adoption of these rules by 

the board. All interested persons are invited and will be given reasonable opportunity to express their views 

concerning the proposed amendments. Oral statements will be heard, but, for the accuracy of the record, all 

comments should be submitted in writing. 

Additional information regarding this action may be obtained from Susan Bern, Rules Development Branch, 

Office of Legal Counsel, (317) 233-5697 or (BOO) 451-6027 (in Indiana). 

Individuals requiring reasonable accommodations for participation in this event should contact the Indiana 

Department of Environmental Management, Americans with Disabilities Act coordinator at: 

Attn: ADA Coordinator 

Indiana Department of Environmental Management 

Indiana Government Center North 

100 North Senate A venue 

Indianapolis, IN 46204-2251 

or call (317) 233-17B5 (V). Speech and hearing impaired callers may contact IDEM via the Indiana Relay Service 

(711) or (BOO) 7 43-3333. Please provide a minimum of 72 hours notification. 

Copies of these rules are now on file at the Rules Development Branch, Office of Legal Counsel, Indiana 

Department of Environmental Management, Indiana Government Center North, 100 North Senate Avenue, 

Thirteenth Floor and Legislative Services Agency, Indiana Government Center North, 100 North Senate Avenue, 

Room N201, Indianapolis, Indiana and are open for public inspection. 

Nancy King, Chief 

Rules Development Branch 

Office of Legal Counsel 

Posted: 07/30/2014 by Legislative Services Agency 

An html version of this document. 

Date: Dec 30,2014 9:22:30AM EST DIN: 20140730-IR-326120392PHA Page 1 
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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 A1 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 

2 
1 

2 

1:29 o'clock p.m. 

September 10, 2014 

3 

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. 

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11 at large. 

12 

13 care. 

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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 

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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 
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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. 
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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 
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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. 

Initially1 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 
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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 PM2 • 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 

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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 control 
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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 
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may have to, but we'll get there when we get 

there. 

MR. POWDRILL: Okay. 

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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 a 
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copy of my talking points are being distributed 

to you all. 

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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 justified1 ·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 
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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. 
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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 
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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? 
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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.) 

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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. 
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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. 

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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. 

30 
144 

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 

23 
1.'" . 

May 19,2004 

Mr. Dan Hancock 

Indiana Department of Environmental Management 

Office of Air Quality 

100 North Senate A venue 

P. 0, Box 6015 

Indianapolis, IN 46206-6015 

Dear Mr. Hancock: 

) . 

~ ~·-'·'~1 ~-

~ -

A/L':/·r' ~~ ;I l ') l.J J. 1 /QQ4. ·- d- ~ atate: :;f Indiana , n:••}J-..~·.l'' ,. . • Lep<,•·--'·'J"t ;): frr,,rr:-n:nental M 

Office-; nj' f'Jr (Juality anagement; . -~~;r.:,.~~..._,.,,..,.,~,.,.... .. , 

""!''""""~-~ . 

American Electric Power 

1 Riverside Plaza 

Columbus, OH 43215-2373 

www.aep.com 

Enclosed please find a copy of the Supplemental Technical Support Document for the Temp-orary Alternative 

Opacity limit Request for AEP' s Rockport Plant. This supplements the formal request for a Temporary 

Alternative Opacity limit for Rockport filed in a letter dated August 16, 2001. I want to thank you for your 

~uidance in what needed to be included in this docuinent. 

If you have any questions regarding the information in the document or to set up a meeting to discuss this 

matter, if you feel one would be useful, please contact me at 614-716-1245 at your convenience. 

Sincerely, 

OAj~ David J. 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 SUPPORT DOCUMENT 

AMERICAN ELECTRIC POWER 

ROCKPORT PLANT 

TEMPORARY ALTERNATIVE OPACITY LIMIT REQUEST 

Prepared for 

American Electric Power 

Rockport Plant 

Prepared by 

D. J. Long 

Air Quality Services Section 

American Electric Power Service Corporation 

May 19,2004 
Table of Contents 

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 

Precipitator Maintenance and Operation ................................................... 1 

Air Quality Analysis ........................................................................... 6 

Conclusion ............................... : ...................................................... 10 

Appendix A- SCREEN3 Simulations Used in the Air Quality Analysis .............. 12 

Appendix B -Air Quality Data Used in the Air Quality Analysis ..................... 43 

List of Tables 

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 

of 2004 ................................................................. · ............. :·: ................ 5 

Table 3. SCREEN3 Input data ................................................................... 8 

Table 4. Modeling results from startup case examined ....................................... 10 

i 
INTRODUCTION 

On August 16,2001, American Electric Power filed a request for a Temporary 

Alternative Opacity Limitation (TAOL) covering the startup and shutdown of the main 

boilers at the Rockport Plant. The requested TAOL would allow an exemption from the 

20% opacity limit during startup until such time as the flue gas entering the electrostatic 

precipitator reaches a temperature of 250F and subsequently during shutdowns, the 

TAOL would allow up to 10 six-minute average periods to exceed 20%. 

During IDEM's review of that request, it was determined that since Rockport did not 

have an existing TAOL, the filing needed to be made under the provision of 326 lAC 3-

5-1(d) which requires the submittal of additional supporting opacity information and an 

analysis demonstrating that there would be no adverse ambient air quality impacts from 

the granting of the TAOL. The purpose of this report is to supply the additional data and 

analysis that supports the approval of the requested TAOL for the Rockport Plant. 

PRECIPITATOR OPERATION AND MAINTENANCE 

The electrostatic precipitators (ESP) on each of the units at Rockport Plant consist of four 

individual boxes containing 32 electrical bus sections each, f<;>r a total of 128 electrical 

bus sections per unit. All of the electrical btis sections are controlled using an electronic 

control system that utilizes an opacity feed back signal based on the stack opacity 

monitor reading when operated in full automatic mode. Full automatic operation allows 

the optimization of input power to the precipitators while maintaining opacity and 

precipitator performance over a wjde range of operating conditions. 

The precipitator control buildings are checked on a daily basis by the operations 

department at the plant for any abnormalconditions both with the Transformer-Rectifier 

sets and rapping devices. When an abnormal condition is noted, a job order is originated 

and sent to the appropriate maintenance group for action. Repairs that can be made with 

. the unit in service are scheduled to· be undertaken as quickly as possible, while repairs 

that will require a unit outage to address are placed on the outage job order list. 

In general, every four to eight weeks, engineering personnel perform a detailed 

evaluation of the condition of the electrostatic precipitator boxes and rappers on each 

unit. This evaluation is then documented and circulated to management for review and 

planning purposes. 

During normal unit operating conditions and while the fans are operated during a unit 

shutdown, all of the operable bus sections in the ESP are normally energized. During 

unit startup, our routine procedure requires that all operable bus sections except the first 

operable bus section in each gas path be energized prior to fan start. The purpose for this 

sequence of operation (i.e. the first operable bus section in each gas path) is to reduce the 

risk of an explosion inside the ESP should unstable oil firing occur. We would deviate 

from our normal practice in the event that the firing of the unit becomes extremely 

unstable while firing mainly oil during a startup. In this unusual event, it may become 

1 
necessary to deenergize the entire ESP until the gas temperature in the precipitator 

reaches 200F to volatilize off any oil residue that may have collected in the ESP. This is 

an abnormal condition that is rarely invoked to protect the safety or our personnel and 

equipment. When such an event occurs, the proper notifications are made to the Indiana 

Department of Environmental Management (IDEM) within four business hours of the 

event. 

Based on guidance from IDEM staff, we have tabulated the startups and shutdowns for 

. the period 2001 through the first quarter of 2004 for each unit at Rockport Plant and have 

noted the operating status of the other unit. This was necessary since opacity compliance 

at the Rockport Plant is monitored on the common stack. Table 1 contains the data 

relating to the Unit 1 startups and shutdowns and Table 2 contains the comparable data 

for Unit 2. 

Unit 1 underwent 18 startups and 18 shutdowns during the period examined. One of the 

shutdowns occurred as a result of the loss of all electrical transmission circuits leaving 

the site. The resulting shutdown without power caused the loss of all.CEMS and COMS 

data for this shutdown. Therefore, the calculated statistics for shutdowns will be based 

on the remaining 17 shutdowns for which data is available. These 17 shutdowns 

experienced opacity exceedances averaging 0.3 hours per shutdown with a minimum 

period of exceedance of zero (0) hours to a maximum of 2.5 hours. The maximum sixminute opacity measured during any of theses shutdowns was 60%. During the 18 

startups, opacity exceedances averaged 1.9 hours with a minimum of zero (0) hours to a 

,maximum of 10.2 hours. The maximum six-minute opacity measured during any of these 

startups was 76%. 

Unit 2 underwent 15 startups and 16 shutdowns during the period examined. The 16 

shutdowns averaged 0.2 hours of opacity exceedances per shutdown with a minimum 

period of zero (0) hours to a maximum of 0.8 hours of exceedance. The maximum sixminute opacity measured during any cif theses shutdowns was 67%. During the 15 

startups, opacity exceedances averaged 0.8 hours with a minimum of zero (0) hours to a 

maximum of 3.6 hours. The maximum six-minute opacity measured during any of these 

startups Was 60%. 

When the two units are combined, there were 33 startups and 34 shutdowns, 33 of the 

shutdowns having valid opacity data. The average startup has 1.4 hours of opacity valm)s 

exceeding the 20% opacity limit and the typical shutdown has an average of 0.3 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 a number of 

hours. 

2 
Table 1. Unit 1 startups and shutdowns for the period 2001 through the first quarter of 

2004. 

Startup/Shutdown Number of Six Peak Stack Remarks 

Date Minute Opacity 

Exceedances Reading 

March 30,2004- 2.7 hours 56% Hot restart following 

Startup shutdown due to loss of all 

transmission circuits. Unit 2 

out of se!Vice. Malfunction 

notification made to 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 out of 

service. 

December 7, 2003 - 0.0 hours NA Unit 2 operating. 

startup Hot restart. 

December 7, 2003 - 0.0 hours NA Unit 2 operating. 

shutdown 

December 7, 2003 - 0.0 hours NA Unit 2 operating. 

startup Hot restart. 

December 7, 2003 - 0.1 hours 38% Unit 2 operating. 

shutdown 

November 17-18, 3.2 hours 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 

December 21, 2002 3.4 hours 70% Unit 2 operating. 

-startup 

3 
November 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 

August 4, 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 

December 28, 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- 10.2 hours 70% Unit 2 out of service. 

startup Hot Restart 

May 11;2001- 0.2hours 36% Unit 2 out of service. 

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 Hot Restart 

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~ Number of Six Peak Stack Remarks 

Date Minute Opacity 

Exceedances Reading 

February 7, 2004 - 0.8 hours 36% Unit 1 operating normally. 

Shutdown 

January 5-6, 2004- 0.9 hours 32% Unit 1 operating normally. 

startup 

December 30,2003 0.0 hours NA Unit 1 operating normally. 

-shutdown 

October 26, 2003 - 1.0 hours 50% Unit 1 out of service 

startup 

October 24, 2003 - 0.5 hours 67% Unit 1 out of service 

shutdown 

August 10, 2003- 0.0 hours NA Unit 1 operating normally. 

startup Hot restart. 

August 10, 2003- 0.1 hours 40% Unit 1 operating normally. 

shutdown 

July 27, 2003- 0.0 hours NA Unit 1 operating normally. 

startup Hot restart. 

July 26, 2003 - 0.1 hours 67% Unit 1 operating normally. 

shutdown 

April 5-6, 2003 - 1.5 hours 44% Unit !.operating normally. 

startup 

March 28,2003- 0.0 hours NA Unit 1 operating normally. 

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 Hot Restart 

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 

November 4-5, 0.0 hours NA Unit 1 operating. 

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 

October 26, 2001_- 0.0 hours NA Unit 1 operating. 

startup 

October 24-25, 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 the requirements of 326 lAC 3-5-1(d), an analysis of the air quality 

impacts of the TAOL being requested is required in addition to the demonstration of the 

need for an alternative opacity limitation based on actual operating opacity. The analysis 

being supplied under this requirement is based on. a cold unit startup condition that would 

take approximately 17.hours from initiation to finally reaching stable full load. It is 

assumed that the first field of the electrostatic precipitator is not energized, for the 

reasons previously discussed, until the generating unit surpasses 450 MW of net electrical 

load, which would approximate ESP temperatures in the 200 to 250 F degree range .. We 

have assumed that the ESP efficiency degrades under these conditions from the 

approximately 99.9% design efficiency to approximately 60% efficiency until such time 

as the first field is energized. This assumed degradation is generally far greater than that 

experienced, but due to the nearly continuous changes in temperature conditions during a 

cold startup, these assumptions represent a very conservative estimate of the·actual ESP 

efficiency over the period of reduced ESP operation during the cold startup. Due to the 

transient nature of startup conditions, an emission test to determine the actual ESP 

efficiency is neither reasonable nor practical. 

We are not analyzing a shutdown for the following reasons. First, once firing of the 

steam generator ceases, the only ash going to the ESP is that which is being swept out of 

the unit under the force of the airflow. No additional ash loading is being added since no 

fuel is being combusted. Also, the entire ESP is left in service until the fans are shut 

6 
down, which would increase the overall ESP efficiency to above the level assumed for 

the startup case described previously. Finally, even when the steam generator is fanned 

for the purpose of cooling until reaches near ambient temperatures, the elapsed time is far 

less than that required.for a cold startup, making the previously described startup case a 

more limiting case for conducting the air quality analysis. 

In developing this analysis, we attempt to examine the various operating conditions the 

unit undergoes during a startup. The early stages of the startup utilize multiple sets of oil 

lighters for a number of hours with no more than limited coal combustion. Finally, after 

the unit is placed under load, the amount of coal being burned is steadily increased and 

the amount of oil is decreased until only coal is being fired except for short periods of 

time when pulverizers are brought into service. For those cases studied where oil is the 

only fuel being combusted; no control from the electrostatic precipitator is assumed and 

all of the ash is assumed to be PM10. Once coal is being fired, the particulate emission 

rate is assumed to be 40% of the AP-42 uncontrolled emission rate until the unit has 

exceeded 450MW, when we assume that the emission rate then changes to the NSPS 

emission limit of 0.1lb!MMBtu times the estimated heat input based on an estimated ' . 

maximum full load heat input of 13,2321\1Jv1Btu per hour. The AP-42 uncontrolled 

emission rate for 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 of total particulate. PMto is estimated by multiplying the total particulate rate 

by 0.23, which is the scaling factor of the AP-42 emission factors for TSP to PM10. 

fu order to estimate the ambient impacts, the SCREEN3 model was selected for this 

application. SCREEN3 was selected, as it is a very conservative model in terms of the air 

quality impacts generated and is capable of directly generating 1-hour ambient 

concentrations under a worst-case meteorologic regime.· Use of a more refined model 

like Industrial Source Complex (ISC) or AERMQD was rejected due to the inability of 

the models to handle transient conditions, such as a startup, in a reasonable fashion. In 

addition, the results from the use of a more refined model would be very dependent on 

the meteorology selected for the simulation, while the use of the SCREEN3 model 

eliminates this potential bias by allowing the model to find the worst-case meteorologic 

conditions for a given hour as it is run. In order to develop the most limiting possible 

case, we have assumed that the only unit in operation was the unit being started up. 

Table 3 identifies the user input values used in the modeling simulations. 

Each of these cases was then run_through SCREEN3 with peak terrain values for the 

distances 0 to 2000 meters, 2000 to 3000 meters, 3000 to 5000 meters, 5000 to 7500 

meters and 7500 to 50000 meters of 5 meters, 16 meters, 19 meters, 31 meters, and 74 

meters above stack base respectively. The results of these individual simulations were 

then input into a spreadsheet where a 24-hour TSP and PM10 ambient concentrations due 

solely to the operation of the Rockport Plant were determined. 

7 
T a e . bl 3 SCREEN3 In tput d ata. 

Case Heat TSP Stack Stack Stack Exit Gas Ambient Air 

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+7 on 

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 

Full Load 13,232 168.0 272.5 12.95 4,478,000 434.26 

! Assumes no control effect from ESP due to ftne particle s1ze (all PM10) and nature of 

fuel oil ash; 

A background ambient concentration, based on the lowest fifth high PM10 monitored 

value in Vanderhurgh and Spencer Counties in Indiana, and Daviess County, Kentucky, 

during the year 2001 was selected to represent background since no other sources were 

considered in the actual air quality modeling analysis. The value generated by this 

method was 24 ug/m3 from the Spencer County, Indiana monitor, AIRS number 

1814700088. The selected value in this case should not overly penalize the source being 

studied by double counting the contribution of that source, but must be sufficiently 

conservative to cover the impacts on a typical day from other sources having a significant 

impact on the area around the source being studied since they are not being explicitly 

modeled as part of this study. 

Using the fifth high value for background overstates the actual background value that 

would be determined for Prevention of Significant Deviation (PSD) purposes. Typically 

the PSD and National Ambient Air Quality Standards background value would be based 

on a minimum value since it would only be considering the. contribution of distant 

sources to the local ambient concentration. All of the sources having a significant local 

impact would be explicitly considered in the modeling demonstration in these cases. 

8 

(K) 

293 

293 

293 

293 

293 

293 

293 

293 

293 

293 
Since we are only explicitly modeling the impacts of the facility being considered for the 

TAOL, background in this case must also account for the impacts of other area sources as 

well as the regional background from distant sources .. 

In addition to the method selected for determining the background, the use of the annual 

arithmetic average was also considered. For the five specific monitors considered for this 

study, the range of average daily values was from 19 to 27 ug/m3 for 2001. Considering 

that the value generated by the use of the lowest of the fifth high values falls within this 

range, it yields further justification that the use of the lowest fifth high value is a 

reasonable representation of the typical air quality in the area surrounding the Rockport 

Plant. 

When added to the conservative estimate of ambient impacts from a startup of this nature 

based on the SCREEN3 simulations, we produce a highly conservative estimate of the 

ambient conditions when the two values are combined. If these values do not exceed any 

ambient standards, the TAOL being requested should not jeopardize the ambient air 

quality standard if granted. The results of this analysis are shown in Table 4, on the next 

page. 

From these results, we note that all values are well below the 24-hour ambient standards 

for both TSP and PMlO. We used the same background for both TSP and PMlO since 

TSP data is no longer available in the dataset available from the online AIRS Databas~. 

Even with this shortcoming, the TSP value is approximately 80% of the secondary 

standard of 150 ug/m3 identified in 326 lAC 1-3-4, which leaves a significant margin of 

safety to the secondary TSP standard identified in the state regulations should the 

background be higher. The PM10 value determined in this study is approximately33% of 

the PM10 standards found in 326 lAC 1-3-4 and 40 CFR 50.6. When considered in 

conjunction with the conservative nature of the SCREEN3 model, this demonstration is 

be adequate to demonstrate that the ambient air quality standards for both TSP and PM10 

will be protected with the approval of the requested TAOL. 

9 
T bl 4 M d 1' 1 f . d a e . o e mg resu ts rom startl!P case exanune . 

PM Rate PMto Rate PM Cone. PM10 Cone 

Hour Case (g/sec) (g/sec) (ug!m3) (ug!m3) 

1 28 Burners on oil 0.73 0.73 3.6 3.6 

2 42 Burners on oil 1.09 1.09 3.7 3.7 

3 70 Burners on oil 1.82 1.82 5.8 5.8 

70 Burners on oil + 7 

4 burners on coal 86.26 19.84. 202.8 46.6 

70 Burners on oil + 7 

5 burners on coal oil 86.26 19.84 202.8 46.6 

70 Burners on oil + 7 

6 burners on coal oil 86.26 19.84 202.8 46.6 

70 Burners on oil + 7 

7 burners on coal 86.26 19.84 202;8 46.6 

70 Burners on oil + 7 

8 burners on coal 86.26 19.84 202.8 46.6 

70 Burners on oil + 7 

9 burners on coal 86.26 19.84 202.8 46.6 

70 Burners on oil + 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 Full Load 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 Full Load 168 38.64 35.8 8.2 

21 Full Load 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 Full Load 168 38.64 35.8 8.2 

24 Hour Average 94.1 22.1 

Background 24 24 

Peak Predicted Concentration 118.1 46.1 

Conclusions 

The opacity and air quality analysis presented in this document. support the conclusion 

that the Temporary Alternative Opacity Limit (T AOL) for the Rockport Plant is 

10 
technically justified and will not cause a violation of any air quality standards. The air 

quality analysis was performed in a fashion that generated a worst-case scenario under 

the assumption that opacity exceedances would be exempt until such time as the ESP 

temperatures reached 250 F as requested in the August 16, 200lletter submitted to IDEM 

requesting the TAOL. Further, since there is no additional ash loading being placed in 

the boiler during shutdown, the analysis demonstrates that this portion of the TAOL is 

also technically justified that the granting of 10 exceedances of the 20% opacity standard 

during shutdown will not cause a violation of any air quality standard relating to 

particulate matter. 

11 
History of AEP 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 0.3 
3/19/2012 

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 of AEP 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 of two (2) 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 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 of Air Quality (OAQ) performed a PM2.

5 air quality modeling analysis to confirm the 

TAOL will not have an adverse impact on the National Ambient Air Quality Standards (NAAQS). Two 

different modeling scenarios were examined and both showed no adverse impact on air quality in the 

area. 

The purpose of the 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 of actual stack heights with respect to Good Engineering Practice (GEP), 

the meteorolbgical data used, a description of the model used in the analysis, the receptor 

grid utilized for the analyses, and the treatment of terrain. 

C. Demonstrate that the source will not cause or contribute to a violation of the 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 · 

1 
scenario 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. 

If one unit is up and running during a startup or shutdow_n of the 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 PM10 emission rates. It is assumed that PM2.s would be some fraction 

of the PM10 emission rates. Due to the difficulty in calculating PM2.5 emission rates, OAQ assumed .all 

PM10 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 PM10 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 

2 
20 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. If stacks 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 of the stack. The downwind wake is considered to extend 

five times the lesser of the structure's height or width. 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 or width) 

The physical stack heights for AEP are above GEP stack height, so only the GEP height is 

allowed in the modeling. The effect of aerodynamic 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 of 2008 through 2012 surface data from Evansville, 

Indiana and upper air measurements taken at Lincoln, Illinois. The meteorological data was 

preprocessed using the latest versions of AERMINUTE, 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 1 000 meters, 

• 2000 meters spacing out to 10,000 meters, 

• 5000 meters spacing out to 50,000 meters. 

Treatment of Terrain 

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 height just 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 PM10 emission rates are PM2.5. 

Looking at the previous modeling work done for the Indiana PM opacity rule, PM10 was the 

pollutant examined and not PM2.5. The new PM2.

5 standards are more constraining than the PM10 

standards. This adds another level of conservatism. · 

Examining PM2.5 background values also show that they are more constrictive when compared to 

PM10 background. For the years 2011-2013, the PM10 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 PM10 and PM2.5 backgrounds. When adding 

calculated PM2.

5 modeling concentrations to background, PM2.

5 values 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. 

4 
Table 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 another worst 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 of the 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 itself to 

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 3 years 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 of the standard when modeling for 

AEP's proposed TAOL during periods of startup and shutdown. 

5