Appendix A: Tables 

Figures

MDEQ PM2.5 SIP
3-Year Average PM2.5 Concen

Year Average PM2.5 Conce

Southeast Michigan Southeast Michigan

Figure 1

Source: SEMCOG

Open symbols indicate monitors that currently violate the annual standard.

9

12151821

2000-2002 2001-2003 2002-2004 2003-2005 2004-2006 

Concentration (ug/m3)
Expected Change in On-Road Mo

Emissions due to National Co

tons/year

0

50,000

100,000150,000

2002 2005 2009 

45%

50%

47%

27%

25%

26%

Figure 2

Percentages indicate reduction from 

Source: SEMCOG On-Road Mobile Source Emissions Inventory for Southeast Michigan PM2.5 
Table 1

Note: Modeling includes regional and national controls, not local controls

Monitor County Site 03-'05 04-'06 05-'07

Bas

DeVa

260990009 Macomb New Haven 13 12.5 12.5 261150005 Monroe Luna Pier 14.1 13.8 13.8 261250001 Oakland Oak Park 14.3 13.4 13.6 261470005 St. Clair Port Huron 13.8 13.1 13.2 261610008 Washtenaw Ypsilanti 14.3 13.6 13.7 261630001 Wayne Allen Park 15.1 14.5 14 261630015 Wayne Southwest HS 16.4 15.8 15.5 261630016 Wayne Linwood 15.2 14.2 14.3 261630019 Wayne E. 7 Mile 14.8 14.1 14.1 261630025 Wayne Livonia 13.9 13.1 13.2 261630033 Wayne Dearborn 18.2 17.2 17.2 

261630036 Wayne Wyandotte 15.4 14.3 14.3 

* A

peri

Forecasted Change in PM2.5 Concentrations Betwe

due to Regional and National On-the-Book

Source: LADCO Round 5 Modeling
Industrial Sources Within 3 Miles of Dea

Figure 3
Figure 3: 2002 Annual NOx, PM10, SO2 and VOC, Dearborn Monitor, Way
W

Location of Severstal 

in Relation to Dearborn Monitor

1,000 Yards

Severstal steel facility

Po

for Ir

Figure 4 

Dearborn Monitor

Average is n

are from the 
Figure 6

Source: LADCO

Analysis of Crustal Concentrations in Southe

Iron vs. Non-Iron
•Emissions for PM2.5 calculated 

using RTI’s (2006) PM2.5-fil ratio: PM.•Highlighted numbers indicate past actual emissions that used RTI (2006) emission factors instead of those reported by Severstal North America (from PTI #182-05B). •For additional details see Appendix GSource: MDEQ

Source Nam e 2002 p a st a ctu a l B B F S toves (B F G ) 19.42 

C B F S toves (B F G ) 34.80 B B F S toves (NG ) 1.74 C B F S toves (NG ) 1.65 B B F Cas thous e (Roof M onitor) 15.53 C B F Cas thous e (Roof M onitor) 27.11 B B F B leeders 0.12 

C B F B leeders 0.20 B B F Taphole B urning 0.14 C B F Taphole B urning 0.10 

BF B Casthouse Baghouse Stack 0.00 BF C Casthouse Baghouse Stack 0.00 

Lim e Unloading - B O F Rec eiving 2.63 

Reladling S outh - S TA CK 3.12 

Reladling S outh - F UG ITIV E S 1.08 

Torch Cutting 1.99 

B OF Natural Gas 1.98 

BOF ESP Stack 147.72 

B OF S econdary E m iss. B aghouse 0.00 

B O F Tapping (Roof M onitor) 125.27 

B O F S lag Tap (Roof M onitor) 8.57 B O F Charging (Roof M onitor) 40.79 Des ulfuriz ation - S TA CK 3.84 

Des ulfuriz ation - F UG ITIV E S 2.96 #1 LRF Stack 29.68 

#2 LRF Stack 16.96 

DD B aghous e - Cok e Trans fer 3.75 E E B aghouse - Coke Unloading 4.69 

E E B aghouse - Natural Gas 0.02 

Raw M aterial Handling 4.38 A nnealing Furnaces 4.42 Reheat Furnace #1 11.84 

Reheat Furnace #2 11.84 

Reheat Furnace #3 11.84 

Hand S c arfing 13.14 B BF Slag Pit 0.01 C BF Slag Pit 0.02 Des ulfuriz ation S lag P it 0.07 P arts Cleaning 0.00 

M aintenance Paint Booth 0.00 J-9 Dip Tank 0.00 Fine Coal Silo Baghouse 0.00 F ilter #4 (P ulveriz er B aghous e) 0.00 Rail Unloading Baghouse 0.00 

Raw Coal Silo Baghouse 0.00 

Rail Car B uilding Heater 0.00 

P ulveriz er Hot G as G enerator 0.00 

P roc es s F ugitives 0.00 S e ve rsta l Em issio n s T o ta ls 553.43 

Table 2:

Severstal Emissions for 

PM2.5 in tons per year (2002 

Base year versus 2009 

Potential)

9
Table 3: Emissions reductions near Dearborn and SWHS monitors Source: MDEQ

Company Equipement Change Date Nox (tpy) SO2 (tpy)

Filterable PM (tpy) 

CO Boiler1 Nov-03 -184.4 -10.1

FCCU Controls1 Dec-04 -242 -389 -84.0

BT Inter Heater1 Nov-05 -14

BT Charge Heater1 Nov-05 -9Crude/Vac Heater1 Nov-05 -145Street sweeping2 

Retired offsets2 

Total -410 -573.4 -94

US Steel Corp Blast furnace B bag house3 Sep-05 

Blast furnace C4,8 Oct-07 -81.5 702.9 -50

Blast furnace B4,8 Jul-08 -31.0 256.6 -34

BOF4,9 Oct-07 67.9 0.1 -496

Torch cutting4 2007 -2

Reladling4 2007 -12

annealing and reheat furnaces4 2007 60.6 0.3 5

Coal pulverization4 2007 21.5 0.1 16

other4 2007 0.1 15

Total 37.6 960.0 -558

--

28 Switch yard locomotives anti-idling controls5 2007-2008 96 

--

4 Swith yard locomotivesengine rebuild6 2007-2008 66 

--

School bus (diesel oxidation catalyst and crankcase filter)7

1 NSR Settlement Agreement w ith Marathon Petroleum Company (reported in MDEQ PTI #388-07)2 MDEQ Permit to Install (PTI) application Heavy Oil Upgrade Project #388-07 for Marathon Petroleum Company3 MDEQ Consent Order 1-2005 and ROP 199600123a for United States Steel4 MDEQ Permit to Install #182-05B for Severstal North America, Inc.5 Supplemental Environmental Project (SEP) for Chrysler 6 Funding from the Federal Congestion Mitigation Air Quality (CMAQ) Program7 Funded by Severstal SEP, Clean School Bus federal grants, and possible additional buses from Marathon P8 Used 0.15 emissions factors (Severstal uses 0.09) for blast furnace cast house roof monitors prior to cont9 Used 0.23 emissions factor (Severstal uses 0.046) for BOF tapping and 0.15 emissions factor (Severstal u

Marathon Petroleum CoSeverstal North America
Table 1

Recent Plant Closings

Dearborn & SWHS Monitoring areas

NOx SO2 PM25 PM10 VOC NOx SO2 PM25 PM10 

Carmeuse/ Detroit Lime 2002 555.98 29.14 5.87 0.00 

Daimler Chrystler McGraw Glass 2003 8.25 0.05 5.32 

Frito Lay 2003 4.54 0.02 2.13 1.15 

IPMC Acquisition 2003 128.08 0.40 3.71 Gutter Supliers, Inc 2004 0.73 0.00 1.56 Darling International* 2005 19.48 5.25 16.94 12.48 5.54 0.91 0.23 0.51 Honeywell 2005 39.21 37.60 82.15 

Total 

*Partial plant closing

Facility Last Year Reported 2002 (tons/year) Current (tons/year)

Source: MDEQ

Table 4
10

121416182022

2000 2001 2002 2003 2004 

Dearborn Wyandotte SWHS Allen Park Linw ood Ypsilanti Linear (Allen Park) Linear (Wyandotte) Linear (Oak ParkLinear (Ypsilanti) Linear (SWHS) Linear (Dearborn

Source: LADCO

Figure 7

Trends in Southeast Michigan PM2.5 Mon

Industrial vs. Non-Industrial Site

Monitors in industrial areas Monitors in 
AERMOD Hot Spot Modeling Results - 2008

Source: SEMCOG & MDEQ

Table 5

Estimate of Potential Emission Reductio

Diesel Switch Engine Retrofits in Dearbo

Switch Engine Locomotives Being Retrofitted Retrofit of all 

Switch Locomotive

Number of 

Engines Type of Retrofit Funding Source

PM2.5 

emission 

reduction per 

locomotive

Average PM 

Reduction 

(tons/day)2

PM 

Reduc

(lb/d

CSX 4

Retrofit of 

conventional 

diesel locomotive 

with Generator 

Set (GENSET) 

engine 

technology

80% Federal 

Congestion 

Mitigation Air 

Quality (CMAQ) 

Program, 20% 

CSX

0.46 tons/year1 0.0055 10.9

Norfolk 

Southern 12 Teleflex Ecotrans APU technology Chrysler SEP .07 tons/year2 0.0025 5.0

U.S. Steel 

(River Rouge 

and Ecorse)

16

Kim HotStart

APU's along with 

the ZTR 

SmartStart

systems

Chrysler SEP .07 tons/year2 0.0033 6.6

Total 32 0.0113 22.61CSX CMAQ funding application. Submitted to SEMCOG on September 7, 2007.2EPA, Case Study: Chicago Locomotive Idle Reduction Project, March, 2004. 335 average switch engine service days/yea

PM per retrofitted engine per year.

Railyard
1 

2

Ambassad

3

4

= Wyand

= Linw

Key

+ PM2.5

Norfolk Southern

CSX

7

6

5

7

6

5 -F

US Steel

Rail yard

Location of Rail Yards and PM2.5 M

in Dearborn Area 

Figure 8
Source: SEMCOG

9
Table 6

SO2 and NOx RACT model run 

Michigan’s seven county non-attainm

Source: MDEQ

Monitored

2005 Base RRF 2005 RACM Ne

ug/m3 ug/m3 

Dearborn 18.55 0.945 17.54 West Fort 17.21 0.945 16.27 

Wyandotte 16.41 0.945 15.51 

Linwood 16.01 0.945 15.14 

Port Huron 15.09 0.942 14.22 

Allen Park 15.94 0.945 15.07 

New Haven 14.37 0.942 13.54 

Ypsilanti 15.61 0.950 14.82 

Livonia 14.94 0.950 14.19 

Ann Arbor 13.20 0.950 12.54 

East 7 Mile 16.48 0.960 15.82 

Luna Pier 15.70 0.958 15.05 Oak Park 15.46 0.960 14.84 

Lansing 13.54 0.959 12.98 

Flint 12.89 0.973 12.54 

Bay City 12.44 0.972 12.09 

Kalamazoo 13.83 0.976 13.50 Saginaw 11.72 0.972 11.39 

Jenison 13.99 0.978 13.68 

Grand Rapids 13.72 0.978 13.42 

Holland 12.39 0.979 12.13 

Coloma 13.05 0.982 12.81 

Muskegon 13.07 0.982 12.84 Sault Ste Marie 8.16 0.982 8.01 

STATEWIDE AVERAGE 

MICHIGAN RACT-RACM ANALYSIS

(ASSUMES 100% NOx/SO2 CUTS IN 7-COUNTY SE MICHIGAN - ALL SO
Table 7

Change in Southeast Michigan PM2.5 Conc

3 Yr. Average

2001-2003 2005-2007

Dearborn 19.5 17.2 2.

SW HS 17.5 15.5 2.

Wyandotte 16.9 14.3 2.Allen Park 16.1 14.0 2.Linwood 15.7 14.3 1Luna Pier 15.1 13.8 1Oak Park 14.8 13.6 1Ypsilanti 14.7 13.7 1.Livonia 14.4 13.2 1.E 7 Mile 15.0 14.1 0Port Huron 14.0 13.2 0.New Haven 13.3 12.5 0.Regional Average 15.6 14.1 1.Monitoring Site Cha

Source: Compiled by SEMCOG using MDEQ monitoring data 
Table 8 

PM2.5 Monitoring Data Summary: Annual PM2.5 

Source: MDEQ

Time Period

Year

Dearborn

SW HS

Wyandotte

Allen Park

Linwood 

Luna Pier

Oak Park

Ypsilanti

Livonia

E 7 Mile

2000 22.76 20.34 19.30 16.99 17.67 16.92 18.57 16.82 16.53 

2001 20.95 19.33 21.49 20.05 17.19 16.24 15.58 15.92 15.39 142002 20.99 16.80 15.40 15.32 15.04 14.99 12.73 14.71 13.33 14

2003 22.59 17.41 15.07 17.37 18.36 15.93 18.39 16.70 15.96 17

2004 17.71 14.95 14.48 15.41 14.87 13.02 13.73 13.74 12.72 132005 21.50 20.20 16.96 18.45 18.92 16.50 17.49 17.49 17.86 192006 18.79 16.98 15.10 13.70 13.04 14.55 13.51 14.80 13.34 15

2007 18.84 15.15 13.75 12.92 13.98 12.26 12.48 12.95 12.23 13

2008* 16.59 16.07 12.55 13.86 14.59 13.25 13.59 13.23 13.56 13

2000 20.13 17.04 16.52 13.69 13.82 14.54 14.79 12.85 14.08 132001 18.58 20.05 17.53 16.68 15.66 16.58 17.30 15.46 15.67 142002 18.15 17.42 15.98 16.15 15.61 17.77 17.29 14.57 14.26 152003 19.03 15.39 20.37 15.25 15.33 12.84 13.79 15.05 15.36 142004 16.10 15.01 12.74 12.22 12.10 12.61 11.26 11.76 11.98 12

2005 16.57 14.73 14.93 13.77 14.78 13.40 13.77 14.27 11.74 14

2006 12.85 12.26 10.95 11.59 11.58 10.91 10.40 10.67 11.23 102007 15.20 13.05 12.41 10.28 12.12 11.41 12.27 11.68 10.59 11

20082000 17.56 16.29 15.64 14.46 13.52 14.33 11.88 13.21 13.28 132001 18.27 17.67 18.53 17.46 16.57 15.68 14.81 14.15 15.14 142002 20.22 18.27 16.51 17.33 16.78 15.96 16.07 16.43 16.47 172003 17.83 16.68 16.37 15.11 14.94 14.36 13.66 14.39 13.89 13

2004 17.46 17.69 15.91 16.18 14.78 14.83 14.78 14.17 14.13 15

2005 18.22 18.73 18.58 17.15 16.62 19.78 17.61 17.69 17.45 172006 15.56 14.93 13.69 13.76 12.58 12.98 10.76 13.12 10.01 11

2007 16.02 15.12 14.60 13.76 14.74 14.87 14.68 13.78 13.76 14

2008

1st Quarter 

Average

2nd Quarter 

Average 3rd Quarter Average

*Note: The first quarter of 2008 for Dearborn, normally the highest quarter of the year, is 

quarter data. All the other monitors except Dearborn and Wyandotte increased from 200
Table 8: ContinuedSource: MDEQ

Time Period

Year

Dearborn

SW HS

Wyandotte

Allen Park

Linwood 

Luna Pier

Oak Park

Ypsilanti

Livonia

E 7 Mile

2000 20.06 18.71 19.07 17.08 16.94 14.96 16.31 14.16 14.46 

2001 20.63 16.07 15.26 14.79 13.47 12.69 12.23 12.44 12.18 13.72002 20.00 17.20 17.24 15.02 14.95 16.30 13.90 13.72 13.43 14.4

2003 17.34 17.26 13.45 13.17 14.78 12.01 12.48 12.78 11.59 13.0

2004 16.06 13.90 11.52 13.14 13.00 11.47 11.26 11.79 11.45 11.7

2005 17.90 15.18 15.19 14.38 13.70 13.10 12.99 13.00 12.68 14.2

2006 17.30 14.56 11.94 13.70 14.97 12.45 13.78 11.61 12.46 13.4

2007 17.49 14.82 13.47 14.08 14.61 13.78 13.89 13.51 14.42 13.3

20081999 16.82 17.57 16.28 16.66 17.08 14.16 14.19 13.07 

2000 20.13 18.10 17.63 15.56 15.49 15.19 15.39 14.26 14.59 14.

2001 19.61 18.28 18.20 17.25 15.72 15.30 14.70 14.49 14.60 14.2002 19.84 17.42 16.28 15.96 15.60 16.26 15.00 14.86 14.37 15.

2003 19.20 16.69 16.32 15.23 15.85 13.79 14.58 14.73 14.20 14.2004 16.83 15.39 13.66 14.24 13.69 12.98 12.76 12.87 12.57 13.

2005 18.55 17.21 16.42 15.94 16.01 15.70 15.47 15.61 14.93 16.

2006 16.13 14.68 12.92 13.19 13.04 12.72 12.11 12.55 11.80 12.

2007 16.89 14.54 13.59 12.76 13.86 13.08 13.33 12.98 12.75 13.

2008

99-01 18.9 18.0 17.4 16.5 16.1 15.2 14.7 14.3 14.1 

00-02 19.9 17.9 17.4 16.3 15.6 15.8 15.0 14.5 14.5 14

01-03 19.5 17.5 16.9 16.1 15.7 15.1 14.8 14.7 14.4 15

02-04 18.6 16.5 15.4 15.1 15.0 14.3 14.1 14.2 13.7 14

03-05 18.2 16.4 15.5 15.1 15.2 14.2 14.3 14.4 13.9 14

04-06 17.2 15.8 14.3 14.5 14.2 13.8 13.4 13.7 13.1 1405-07 17.2 15.5 14.3 14.0 14.3 13.8 13.6 13.7 13.2 14

Annual Average 3-Year Average 4th Quarter Average
PM2.5 Speciation Trends 

ug/m3/year

Species

Allen Park

Jan ’01-

Dec ‘06

Dearborn

May ‘02 –

Dec ‘06

Luna Pier

May ‘02 - Dec 

‘06

Nitrate -0.16 -0.11 -0.19

-0.22

0.007

-0.22

Soil -0.019 -0.08 0.008 

-0.32

Sulfate -0.17 -0.19 

EC 0.01 -0.04 

OC -0.17 -0.54 

FRM PM2.5 (1999-2005)

-0.32 -0.56 

Significant trends in bold.

Table 9

Source: LADCO 
Figure 10

Source: LADCO
Figure 11

Source: LADCO
Figure 12

Source: SEMOS

9.2 8.7 10.3 11.3 11.9 

02468

101214

Port Huron New Haven E. Seven

Mile

Linwood SW High

School

Monitoring Site

PM2.5 Conc. (ug/m3)

When Winds Are From Northeast (0-6

2001 - 2006

Average PM2.5 Concentrations
Figure 13

Source: SEMOS

When Winds Are From Northwest (300

2001 - 2006

Average PM2.5 Concentrations

5.7

7.0 7.2 7.8

9.9 

02468

1012

Saginaw Flint Oak Park Linwood SW High

School

Monitoring Site

PM2.5 Conc. (ug/m3)
Figure 14

Source: LADCO
Figure 15

Source: LADCO
Pollution Roses

2003-2004

Organic Ca

Iron – Allen Park

AverageMedian

W 

N

N

S

W

S

1

Figure 16

Source: MDEQ

E

Iron – Dearborn

Organic Car

E

W W
Source: LADCO 

Figure 17
Average Difference in Concent

Between Dearborn and Selected “Backg

Figure 18

0123456789

Oak Park Linwood E7 Mile SWHS Wyandotte Allen P

N NE ESES 

Difference (ug/m3)

Background Monitor

Wind Direction

Source: MDEQ 
Proximity of Severstal to Air Mo

Severstal

Dearborn 

Monitor

Allen Park

Monitor

Figure 19
Table 10

Organic Carbon Analysis by Wind Dir

Dearborn vs. Allen Park

2003-2006

Source: SEMOS

Northeast Winds East Winds 

Dearborn Allen Park Difference Dearborn Allen Park Difference 

2003 Average 3.91 3.47 0.44 4.88 5.00 -0.12 2004 Average 2.96 2.75 0.21 4.05 3.10 0.96 2005 Average 3.14 2.69 0.45 4.60 3.96 0.64 2006 Average 3.70 3.67 0.03 3.33 2.66 0.67 4-yr Average 3.42 3.12 0.30 4.45 3.95 0.50 Median 3.39 2.86 4.38 3.56 

Std. Deviation 0.87 1.04 0.59 1.78 1.80 1.54 

Northwest Winds West Winds 

Dearborn Allen Park Difference Dearborn Allen Park Difference 

2003 Average 5.55 4.57 0.98 6.47 3.58 2.89 2004 Average 4.10 3.34 0.76 5.21 3.29 1.92 2005 Average 2.45 2.41 0.04 4.89 3.46 1.43 2006 Average 3.27 2.90 0.36 4.49 3.56 0.92 4-Yr Average 3.62 3.15 0.47 5.18 3.47 1.71 Median 3.65 3.03 4.82 3.21 

Std. Deviation 1.30 1.14 0.79 1.42 1.35 1.43 

MeasurementMeasurement
Figure 20

Source: LADCO 
Detroit PMF Results: 

Organic Mass (OM)

Bu

C

Allen PaDearbor

• Mobile/urban factor is ~ 50% of 

OM at both sites

• Diesel at Allen Park is a large 

amount of OM

• OM associated with sulfate and 

nitrate is 13%-20%

• Industrial profiles account for 8%-

15% of OM, higher at Dearborn

Met

B

Dies

19%

Secondary 

9%

Figure 21

SOURCE: Sonoma Technologies Inc., 2006
0 2 4 6 8 

Source contribution, ug/m3

Mobile

Gasoline Veh.

Diesel Veh.

Sec. Sulfate/Coal

Sec. Nitrate

Iron/Steel Mfg.

Refinery/Oil

Municipal Incin.

Sludge Incin.

Mixed Industrial

Industrial/Zinc

Sea Salt/Road Salt

Crustal

Biomass Burning

BBBBGGHHMWW

Summary of Source Apportionment Results a

Figure 22

Source: LADCO
Dearborn CMB

w/ point source profile

Jan 2004

Feb 2004

Mar 2004

Apr 2004

May 2004

Jun 2004

Jul 2004

Aug 2004

Sep 2004

Oct 2004

Nov 2004

Dec 2004

Jan 2005

Feb 2005

Mar 2005

1/28/2004

9/24/2004

11/5/2004

Source contribution 

μg m-3

02468

101214

Figure 23

Dearborn CMB Analysis

Source Profile Comparison – Average vs. 

Source: LADCO

Monthly Averages

Days

High 
Figure 24

Source: “Preliminary Results from the Deployment of an Advanced Mobile LaboraJeff Brook, Environment Canada, May 7, 2007.Continuous Monitoring of CRUISER is 
Route of CRUISER in Detro

Figure 25

Dearborn

Sausage 

Factory

Train

Dix 

Road Allen 

Park

Source: 
Observed Increase in Pollutant Concen

Between Locations Immediately Upwind & 

of Zug Island

Fall 2006

Source: “Preliminary Results from the Deployment of an Advanced Mobile Laboratory in Detroit”, Jeff Brook, Environment Canada, May 7, 2007.

Table 11
Figure 26: Black carbon (aethalometer) data for FIA (LF) and combined monitors of Dearborn (D), Newberry (NB), FIA and Allen Park (not shown) (red indicates higher concentrations and green indicates lower concentrations).

Joint surface from aethalometer data at all 4 sites – area of greatest COMBINED influence on all sites. Highly industrialized area

FIA aethalometer dAmbassador Bridge 

Zug Island
Newberry aethalometer data – points very specifically to intermodal freight terminal (1 hr data, 2006)

Figure 27: Black carbon (aethalometer) and OC data for Newberry monitor (red indicates higher concentrations and green indicates lower concentrations).

Newberry continufreight terminal as 
Figure 28

Dearborn Monitor Relative to Severstal Op

Source: MDEQ
Figure 29

Detroit Metro Airport 2002 Windro

Source: MDEQ
Dearborn Monitor

Allen Park Monitor

SEVERSTAL

MARATHON

FORD MOTORS

ROUGE COMPLEX

Figure 30

Monitors of Concern Relative to Primary F

Source: MDEQ
Figure 31

Source: “Data Analysis to Support Local Area Modeling” (Kenski, 2007) 
Dearborn Allen 

Monitored Values (ug/m3) (ug/

2000-2004 Weighted Total Average 1 19.3 17Monitored Local Primary Values 2Clarkson Report 4.55 2.

Sonoma Report 4.36 1.

LADCO Analysis 4 3.25 0.

AERMOD Modeled Value (Dearborn only) 2 4.661 Total PM-2.52 Local Industrial Primary PM-2.5 only3 Assumed to be the neighbor scale contribution to Dearborn

4 LADCO report assumes Soil-Fe contribution only

MONITORED VERSUS MODELED LOCAL 

TABLE 312

Source: MDEQ
Table 13

Estimated Contribution to PM2.5 Concen

from Local Sources 

Hotspot Modeling Results

MAERS

EMISSIONS 4.66 μg/m3 2.3

(tpy)

A8640 479.3 PM-2.5 SEVERSTAL NORTH AMERICA, INC. 3.44 μg/m3 0.4

A7809 666.3 PM-10 U S STEEL GREAT LAKES WORKS 0.15 μg/m3 0.9A8648 17.0 PM-10 FORD MOTOR CO ROUGE COMPLEX 0.39 μg/m3 0.0A9831 198.3 PM-10 MARATHON ASHLAND PETROLEUM 0.11 μg/m3 0.0B2132 12.6 PM-10 WYANDOTTE DEPT MUNI POWER 0.00 μg/m3 0.0B2169 71.2 PM-10 CARMEUSE LIME/ RIVER ROUGE 0.28 μg/m3 0.6B2810 42.6 PM-10 DETROIT EDISON RIVER ROUGE 0.00 μg/m3 0.0B2811 186.8 PM-10 DETROIT EDISON TRENTON CHANNEL 0.00 μg/m3 0.0B3518 5.5 PM-10 UNITED STATES GYPSUM CO 0.01 μg/m3 0.0B3533 15.0 PM-10 EDW C LEVY CO PLANT 1 0.15 μg/m3 0.0B3567 7.3 PM-10 ST MARY'S CEMENT 0.06 μg/m3 0.0N6631 84.4 PM-10 DEARBORN INDUSTRIAL GENERATION 0.05 μg/m3 0.0

DEARBORN TOTAL SW

Source: MDEQ
Public Comment Period Record 

STATE OF MICHIGAN 

DEPARTMENT OF ENVIRONMENTAL QUALITY 

AIR QUALITY DIVISION 

PROPOSED PM2.5

STATE IMPLEMENTATION PLAN 

February 4 to March 5, 2008

 
PM 2.5 PUBLIC COMMENT PERIOD RECORD 

TABLE OF CONTENTS 

Notice published on the DEQ Internet........................................................................1 

Notice of Public Comment Period published in the DEQ Calendar on February 4, 

February 18, and March 3, 2008 .....................................................................2 

Written Comments Submitted by: 

Michael Johnston, Michigan Manufacturers Association .................................5 

Kurt A. Kissling, Pepper Hamilton LLP ............................................................7 

Michael Lebeis, DTE Energy ...........................................................................9 

Louis P. Pocalujka, Consumers Energy ........................................................11 

Paul Tait, Southeast Michigan Council of Governments................................13 

Steve Rosenthal, U.S. Environmental Protection Agency .............................14 

APPENDIX A: Proposed PM 2.5 State Implementation Plan, February 4, 2008 

 
MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY 

MICHIGAN’S FINE PARTICULATE MATTER (PM 2.5) STATE IMPLEMENTATION 

PLAN (SIP): The Air Quality Division is holding a public comment period through 

March 5, 2008, on a proposed SIP for Southeast Michigan’s PM 2.5 nonattainment 

area, including Livingston, Macomb, Monroe, Oakland, St. Clair, Washtenaw, and 

Wayne counties. The public comment period meets the public participation requirements 

for a SIP submittal. 

Written comments should be sent to: 

Attention: Mary Ann Halbeisen 

Michigan Department of Environmental Quality 

Air Quality Division 

P.O. Box 30260 

Lansing, Michigan 48909 

TENTATIVE PUBLIC HEARING SCHEDULED: 

If requested by March 5, 2008, a public hearing will be held on March 11, 2008, at 1:30 

p.m., in the Constitution Hall, Lillian Hatcher Conference Room, 3rd Floor North, 525 

West Allegan Street, Lansing, Michigan. Those interested may contact the Air Quality 

Division at 517-335-1059 after March 5, 2008, to determine if a hearing was requested 

and will be held. 

The PM 2.5 SIP can be viewed by clicking on the following links: 

• Michigan State Implementation Plan for PM 2.5

• Appendix A

• Appendix C

• Appendix D

• Appendix E

• Appendix F

For further information, contact Cynthia Hodges at 517-335-1059 or Email at 

hodgesc@michigan.gov. 

Decision-maker: DEQ Director.

PM 2.5 PUBLIC COMMENT PERIOD RECORD

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MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY 

PO BOX 30473 

LANSING MI 48909-7973

CALENDAR February 4, 2008

♦ ENVIRONMENTAL 

 ASSISTANCE CENTER 

 800-662-9278 

 E-mail: deq-ead-env-

 assist@michigan.gov

The DEQ Environmental Assistance Center (EAC) is available to provide direct 

access to DEQ environmental programs, answers to environmental questions, 

referrals to DEQ technical staff, and quick response. Questions on any items 

listed in the DEQ Calendar can be referred to the EAC. 

♦ PUBLICATION 

SCHEDULE 

The DEQ Calendar is published every two weeks, on alternate Mondays, by the 

Michigan Department of Environmental Quality. We welcome your comments. 

♦ CALENDAR LISTSERV You may subscribe to receive the DEQ Calendar electronically by sending an 

Email to the listserv at LISTSERV@LISTSERV.MICHIGAN.GOV and in the 

body of the message type Subscribe, DEQ-CALENDAR, and your name. 

♦ INTERNET ACCESS 

 www.michigan.gov/ 

 deqcalendar 

The DEQ Calendar is available on the DEQ World Wide Web site in pdf and 

html format. Access the calendar at www.michigan.gov/deqcalendar. 

♦ TIMETABLE FOR 

DECISIONS 

No decision listed in the DEQ Calendar will be made prior to seven days after 

the initial Calendar publication date. 

♦ TIPS FOR CITIZEN INPUT Refer to the “Public Involvement Handbook, A Citizens Guide” to increase the 

effectiveness of your input into DEQ programs. Access the handbook at 

www.michigan.gov/deq and click on "Get Involved, Programs for Citizens." 

♦ CONTENTS PART I: ENVIRONMENTAL ISSUES, PERMITTING, AND RELATED

 REGULATIONS 

*Permit Decisions Before the Office of the Director 3 

*Other Decisions Before the Office of the Director 3 

*Proposed Settlements of Contested Cases 5 

*Administrative Rules Promulgation 5 

*Announcements 5 

*Public Hearings and Meetings 6 

*Division Permit Contacts 9 

PART II: ENVIRONMENTAL CONFERENCES, WORKSHOPS, AND 

TRAINING PROGRAMS 10 

Recycled 

Paper

Governor Jennifer M. Granholm  Director Steven E. Chester

PM 2.5 PUBLIC COMMENT PERIOD RECORD

2
CALENDAR February 4, 2008

PART I: 

ENVIRONMENTAL ISSUES, PERMITTING AND RELATED REGULATIONS

Permit Decisions Before the Office of the Director 

AIR QUALITY 

DIVISION 

See Map - n

DOW CHEMICAL COMPANY – 32 INCINERATOR, MIDLAND, MIDLAND COUNTY, proposed 

Permit to Install application for changes to permit conditions for the existing hazardous waste 

incinerator and operation of 32-Incinerator. The facility is located at Midland Operations, Main Street, 

Midland. Additionally, the new 32-Incinerator will require revisions to Renewable Operating Permit 

(ROP) No. MI-ROP-A4033-2004a. This public comment period meets the public participation 

requirements for a future administrative amendment to the ROP. The responsible official for the source 

is Brad Fedorchak, Michigan Operations, 1261 Building, D-Street, Midland, Michigan. New Source 

Review and ROP public notice documents can be viewed on the Internet at 

www.michigan.gov/deqair. Public comment will be taken through February 19, 2008. If a public 

hearing is requested in writing by February 19, 2008, an informational session and public hearing 

will be held February 21, 2008, (see February 21 listing in this calendar). Written comments should 

be sent to the Michigan Department of Environmental Quality, Air Quality Division, P.O. Box 30260, 

Lansing, Michigan 48909, to the attention of William A. Presson, Acting Permit Section Supervisor. 

Information Contact: Paul Schleusener, Air Quality Division, 517-335-6828. Decision-maker: 

G. Vinson Hellwig, Air Quality Division Chief. 

WASTE AND 

HAZARDOUS 

MATERIALS 

DIVISION 

See Map - o

SAUK TRAIL DEVELOPMENT, INC., WAYNE COUNTY. Consideration of a Part 115 Solid Waste 

Management construction permit application for a type II solid waste landfill modification of an 

existing permit. A decision is expected by May 8, 2008. Information Contact: Larry AuBuchon at 

586-753-3840 or, Email at aubuchol@michigan.gov Decision-maker: DEQ Director.

Other Decisions Before the Office of the Director 

ENVIRONMENTAL 

SCIENCE AND 

SERVICES DIVISION 

See Map - p

CLEAN CORPORATE CITIZEN DESIGNATION, PILGRIM MANOR RETIREMENT COMMUNITY, 

2025 LEONARD STREET NE, GRAND RAPIDS, MICHIGAN, KENT COUNTY. The Michigan 

Department of Environmental Quality has received an application for Clean Corporate Citizen (C3) 

designation from Pilgrim Manor Retirement Community as provided for under Administrative Rules 

R324.1508: Clean Corporate Citizen Program. A decision on the C3 designation approval or 

disapproval will be made on or before March 18, 2008. The C3 program provides incentives for 

improved environmental protection. Regulated establishments that have demonstrated 

environmental stewardship can receive C3 designation and public recognition for their efforts and 

are entitled to certain regulatory benefits. Information Contact: Kelie Bond, Environmental Science 

and Services Division, 517-241-7969. Decision-maker: DEQ Director. 

AIR QUALITY 

DIVISION 

See Map - q

H INDUSTRIES, DETROIT, WAYNE COUNTY. Written comments are being accepted on a 

proposed Consent Order to administratively resolve alleged air pollution violations. You may obtain 

copies of the proposed Consent Order and Staff Activity Report on the Web at 

www.michigan.gov/deqair. Submit written comments to Ronald Pollom, Michigan Department of 

Environmental Quality, Air Quality Division, P.O. Box 30260, Lansing, Michigan 48909. Written 

comments must be received by February 20, 2008. If a request is received in writing by February 20, 

2008, a public hearing will be scheduled. Information Contact: Ronald Pollom, Air Quality Division, 

517-335-4624. Decision-maker: G. Vinson Hellwig, Air Quality Division Chief. 

AIR QUALITY 

DIVISION 

See Map - r 

MICHIGAN’S FINE PARTICULATE MATTER (PM 2.5) STATE IMPLEMENTATION PLAN (SIP) 

proposed for Southeast Michigan’s PM 2.5 nonattainment area, including Livingston, Macomb, 

Monroe, Oakland, St. Clair, Washtenaw, and Wayne counties. The Air Quality Division will hold a 

public comment period through March 5, 2008, that meets the public participation requirements for a 

SIP submittal. The PM 2.5 SIP can be viewed on the Web at www.michigan.gov/deqair. If requested 

by March 5, 2008, a hearing will be held March 11, 2008 (see March 11 listing in this calendar). 

Written comments should be sent to the Michigan Department of Environmental Quality, Air Quality 

Division, P.O. Box 30260, Lansing, Michigan 48909, to the attention of Mary Ann Halbeisen. 

Information Contact: Cynthia Hodges, Air Quality Division, 517-335-1059. Decision-maker: DEQ 

Director.

3 

PM 2.5 PUBLIC COMMENT PERIOD RECORD

3
CALENDAR February 4, 2008

any air emission changes at the stationary source. The ROP public notice documents can be viewed 

on the Web at www.michigan.gov/deqair. The responsible official of the stationary source is Tim 

Schimke, 1525 Miltner Street, Cadillac, Michigan 49601. Comments on the draft permit are to be 

submitted to Kurt Childs, Michigan Department of Environmental Quality, Air Quality Division, 

Cadillac District Office, 120 West Chapin Street, Cadillac, Michigan 49601. The decision-maker for 

the permit is Janis Denman, District Supervisor. If requested in writing by March 5, 2008, a public 

hearing may be scheduled. Information Contact: Kurt Childs, Air Quality Division, 231-775-3960, 

extension 6253. 

MARCH 5, 2008 DEADLINE FOR PUBLIC COMMENT REGARDING MICHIGAN’S FINE PARTICULATE MATTER 

(PM 2.5) STATE IMPLEMENTATION PLAN (SIP) proposed for Southeast Michigan’s PM 2.5 

nonattainment area, including Livingston, Macomb, Monroe, Oakland, St. Clair, Washtenaw, and 

Wayne counties. This public comment period meets the public participation requirements for a SIP 

submittal. The PM 2.5 SIP can be viewed on the Web at www.michigan.gov/deqair. If requested by 

March 5, 2008, a hearing will be held March 11, 2008 (see March 11 listing in this calendar). Written 

comments should be sent to the Michigan Department of Environmental Quality, Air Quality Division, 

P.O. Box 30260, Lansing, Michigan 48909, to the attention of Mary Ann Halbeisen. Information 

Contact: Cynthia Hodges, Air Quality Division, 517-335-1059. 

MARCH 11, 2008 TENTATIVELY SCHEDULED PUBLIC HEARING REGARDING MICHIGAN’S FINE 

PARTICULATE MATTER (PM 2.5) STATE IMPLEMENTATION PLAN (SIP) proposed for 

Southeast Michigan’s PM 2.5 nonattainment area, including Livingston, Macomb, Monroe, Oakland, 

St. Clair, Washtenaw, and Wayne counties. This public comment period meets the public participation 

requirements for a SIP submittal. The PM 2.5 SIP can be viewed on the Web at 

1:30 p.m. 

www.michigan.gov/deqair. If requested by March 5, 2008, a public hearing will be held in the 

Constitution Hall, Lillian Hatcher Conference Room, 3rd Floor North, 525 West Allegan Street, 

Lansing, Michigan. Those interested may contact the Air Quality Division at 517-335-1059 after March 

5, 2008, to determine if a hearing was requested and will be held. Information Contact: Cynthia 

Hodges, Air Quality Division, 517-335-1059. 

Division Permit Contacts 

For additional information on permits, contact: 

Air Quality Division 517-373-7074 Pam Blue 

517-335-4607 Cari DeBruler 

Land and Water Management Division 517-373-8798 Wendy Fitzner

(land/water interface permits) 

Office of Geological Survey 517-241-1545 Thomas Godbold 

(oil, gas, mineral well, and sand dune mining permits) 

Waste & Hazardous Materials Division 517-335-4034 Wanda Williams 

Water Bureau 517-241-1346 Susan Ashcraft 

• Groundwater Permits on Public Notice

• NPDES Permits on Public Notice

• Certificates of Coverage on Public Notice

9 

PM 2.5 PUBLIC COMMENT PERIOD RECORD

4
 

620 S. Capitol Avenue • Lansing, MI 48933-4247 • Phone: 517-372-5900 • Fax: 517-372-3322 • http://www.mma-net.org 

“Manufacturing Makes Michigan Work” 

Attention: Mary Ann Halbeisen 

Michigan Department of Environmental Quality 

Air Quality Division 

P.O. Box 30260 

Lansing, Michigan 48909 

 

Sent via Email: halbeism@Michigan.gov

March 5, 2008 

 

 Michigan’s Fine Particulate Matter (Pm 2.5) State Implementation Plan 

The Michigan Manufactures Association appreciates the opportunity to submit comments on the 

notice for the proposed State Implementation Plan for Fine Particulate Matter (PM 2.5), which 

requires response by March 5, 2008. 

The history on setting the federal standard dates back to 1997, when the EPA issued its PM 2.5 

standard. MMA has been concerned about the economic impact of additional federal regulation 

on Michigan. MMA filed comments with the EPA outlining our concerns as recently as January 

30, 2006. The history on setting the federal standard dates back to 1997, when the EPA issued 

its PM 2.5 standard. The federal courts have deliberated on these issues for years until the DC 

Circuit Court in 2002, rejected the claim that the agency acted in an arbitrary and capricious 

manner in setting the standard. Despite our objections, and those of many business 

organizations across the country, including the National Association of Manufacturers, the EPA 

has moved forward with changes in the standard, which result in seven counties in southeast 

Michigan being designated as not meeting the National Ambient Air Quality Standards for 

Particulate Matter (PM 2.5), including Wayne, Oakland, Macomb, Washtenaw, St. Clair, 

Monroe, and Livingston. 

Given the constraints of the federal regulatory mandate, the state is forced to respond with a state 

implementation plan or face federal sanctions that include withholding federal transportation 

dollars. 

The proposed SIP forwarded by the DEQ is the product of years of close consultation with 

Southeast Michigan Council of Governments (SEMCOG), which is the Metropolitan Planning 

Organization for Southeast Michigan. SEMCOG’s Air Quality Task Force has held several 

meetings over the past several years that have included opportunities for public involvement and 

comment from interested stakeholders. 

With our state economy having a manufacturing concentration seven times greater than the 

national average, any increase in regulation in Michigan tends to have more impact here than in 

other states. We believe the SIP addresses the requirements scientifically, and to the extent 

possible, recognizes the cost implications for Michigan. 

We appreciate the work of both the DEQ and SEMCOG in developing this science based 

approach. Many stakeholders have taken advantage of the opportunities provided in the process 

PM 2.5 PUBLIC COMMENT PERIOD RECORD

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620 S. Capitol Avenue • Lansing, MI 48933-4247 • Phone: 517-372-5900 • Fax: 517-372-3322 • http://www.mma-net.org 

“Manufacturing Makes Michigan Work” 

to make contributions to the understanding of PM 2.5. We believe that with the increased 

monitoring we have learned a great deal about the speciation of the components of PM 2.5. As 

we learn more, we begin to understand how much more there is to learn in the future. We hope 

that increased knowledge will help us refine our regulatory approaches to ensure regulatory 

resources are targeted where they have the most benefit, while not spending economic resources 

where they do not generate environmental benefit. We are confident we will continue to make 

significant scientific progress for the benefit Michigan’s air quality and our economy. 

We believe that Michigan is very close to meeting attainment under the new federal standards, 

and we look forward to achieving the goal of meeting attainment again. Michigan manufacturers 

are already spending billions of dollars implementing multiple control strategies that will 

continue to yield significant co-benefits for air quality in Michigan. 

The process used to develop the DEQ’s proposed SIP for PM 2.5 has been open and deliberative. 

Michigan is poised to continue to make significant progress in air quality improvement. MMA 

supports the proposed SIP for PM 2.5. 

Thank you for the opportunity to participate in your processes and comment on the proposed SIP 

for PM 2.5. 

Sincerely, 

Michael Johnston 

Director of Regulatory Affairs

PM 2.5 PUBLIC COMMENT PERIOD RECORD

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COMMENTS OF CONSUMERS ENERGY 

March 5, 2008 

Submitted via e-mail to: halbeism@michigan.gov 

SUBJECT: Comments of Consumers Energy on Michigan Department of Environmental 

Quality’s Proposed State Implementation Plan Submittal for Fine Particulate Matter (PM 2.5) 

Ms Halbeisen: 

Consumers Energy appreciates this opportunity to comment on the DEQ’s Proposed State 

Implementation Plan Submittal for Regional Haze. Consumers Energy is one of the nation’s 

largest combined gas and electric utilities, ranking fifth among the gas utilities and thirteenth 

among electric utilities. We serve approximately 6.5 million of Michigan’s 9.9 million residents 

with electricity, or gas, or both. We serve more than 8,600 industrial electric customers. 

Consumers Energy is proud of its achievements in meeting or exceeding previous Federal and 

State air regulatory initiatives. These include, but are not limited to Michigan’s 1980 sulfur in 

fuel limitation rule, the Acid Rain provisions of the 1990 Clean Air Act Amendments, and the 

NOx SIP Call. We are currently carrying out our plans for the implementation of the first phase 

of the Clean Air Interstate Rule (CAIR). We have historically been active participants in State 

Implementation Plan (SIP) development for criteria pollutants in Michigan, particularly when 

our sources are factors in designing an attainment strategy. Accordingly, we have been active 

participants in the preparation of this proposed SIP. 

GENERAL STATEMENT REGARDING AIR EMISSIONS AND AMBIENT AIR 

QUALITY 

Nationwide, emitting sources, including electric power plants, have been making dramatic 

reductions in emissions for decades while supplying the nation’s ever-increasing demand for 

energy and consumer products. Since 1970, total emissions of the six criteria air pollutants 

dropped by 54 percent. Air quality will continue to dramatically improve due to huge emission 

cuts already in the pipeline, some ordered just within this past year. 

Many of the control programs that are producing these successes are still being implemented. 

For the electric utility industry, this includes CAIR, which will result in significant reductions in 

PM 2.5 and its precursors, over the course of its implementation. 

PM 2.5 PUBLIC COMMENT PERIOD RECORD

11
COMMENTS PERTAINING TO THE PROPOSED STATE IMPLEMENTATION PLAN 

SUBMITTAL FOR PM 2.5 

Consumers Energy supports the DEQ’s proposed submittal and plan of action. In particular, we 

commend the Department and the Southeast Michigan Council of Governments (SEMCOG) for 

convening a stakeholder group that was well versed in issues related to particulate matter and 

nonattainment in Southeast Michigan. We believe that the end result is a deliberate, practical, 

area-specific approach to defining and resolving the issue of nonattainment of the PM 2.5 

NAAQS in Southeast Michigan. 

We believe that it is important to acknowledge and commend the efforts of the DEQ’s Air 

Quality Division and SEMCOG, with assistance from the Lake Michigan Air Directors 

Consortium (LADCO), in working to understand the nature of PM 2.5 nonattainment in 

Southeast Michigan. This included the use of advanced monitoring techniques to detect and 

quantify the various components of PM 2.5, as well as the efforts put forth to compile a 

comprehensive emissions inventory. It made use of reasoned application of air quality computer 

models for PM 2.5. We also acknowledge the strong, open, professional, working interaction 

with the stakeholder group. The information obtained and ideas exchanged, combined with State 

and Federal rules that are on the books, the application of local control measures, and the trend 

analyses for PM 2.5 data, provide the basis for the weight of evidence argument for attaining the 

standard. The problem was clearly analyzed, debated and defined. The solution presented in this 

proposed submittal is geared towards resolving the problem at hand. 

During this process, the state of the understanding of PM 2.5 was advanced. It also brought the 

recognition that there is much more that is to be learned, particularly as we head towards 

addressing nonattainment issues with regard to the next PM 2.5 NAAQS. 

Consumers Energy appreciates this opportunity to discuss our views on the DEQ’s Proposed 

State Implementation Plan Submittal for PM 2.5. If you have any questions, please contact 

Louis Pocalujka at 517-788-2160. 

Sincerely, 

Louis Pocalujka, Senior Environmental Planner 

Environmental & Laboratory Services 

Consumers Energy 

1945 W. Parnall Road 

Jackson, MI 49201

2

PM 2.5 PUBLIC COMMENT PERIOD RECORD

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PM 2.5 PUBLIC COMMENT PERIOD RECORD

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4++t~ S~.4y UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 48 on$ REGION 5 ~WJ AIR AND RADIA1-ION DIVISION 

** \O 77 WEST JACKSON BOULEVARD 

'%L PRO+"" CHICAGO, IL 60604-3590 

MAR 1 7 2008 REPLY TO THE ATTENTION OF: 

(AR-18J) 

Robert Irvine 

Division of Air Quality 

Department of Environmental Quality 

525 West Allegan Street 

P.O. Box 30473 

Lansing, MI 48909-7973 

Dear Mr. Irvine: 

We appreciate the work that the Michigan Department of 

Environmental Quality has done to address the particulate matter 

problem in Southeast Michigan. We are pleased to review the 

draft plan that you have made available for public comment. 

The enclosure provides comments on your draft plan. We are 

particularly concerned that Michigan appears to need to request 

an extension to the attainment deadline for Southeast Michigan, 

and in that context that Michigan appears not to have evaluated 

candidate control measures adequately or implemented a full set 

of reasonably available control measures. 

We look forward to working with you to address these concerns. 

Please contact John Summerhays at (312) 886-6067 if you have any 

questions about these comments. 

Sincerely yours, 

sieve Rosenthal, ~cting Chief 

Criteria Pollutants Section 

cc: Mary Ann Halbeisen, MDEQ 

Enclosure 

PM 2.5 PUBLIC COMMENT PERIOD RECORD

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1

Comments on Draft Michigan SIP 

for PM2.5 in Southeast Michigan 

Modeling Analyses

Michigan’s attainment demonstration for PM2.5 in Southeast Michigan reflects a 

combination of regional and local modeling. Michigan’s draft SIP mostly addresses the 

local area analysis, and so our comments predominantly apply to this analysis. 

A key component of the local area analysis is the concentration, identified through air 

quality data analyses, that is attributed to local sources. Our guidance for local area 

analyses recommends using a concentration derived in this manner in conjunction with 

local area modeling that assess prospective reductions in these local area concentrations. 

We applaud Michigan for following this general approach. However, we have concerns 

about several elements of Michigan’s draft analysis. We have organized our modeling 

comments into comments on 1) the magnitude of the estimated impact of local sources, 

2) the relationship between the estimated impact of local sources (derived from 

monitoring data) and the emissions of the sources included in the local source modeling 

analysis, 3) separating the concentration addressed by regional modeling from the 

concentration addressed by local source modeling, 4) more specific comments on 

modeling methods used in the local source modeling, 5) clarifications we would request, 

and 6) evidence to be considered in the weight of evidence assessment. 

1. The most challenging element of a local area analysis is assessing the concentrations 

attributable to local sources and assuring reasonable correspondence between this impact 

estimate and the source emissions to which those impacts are being attributed. Source 

apportionment analyses are often the best means of assessing this impact, and we are 

pleased that several studies of this type have been conducted. This first comment 

addresses the overall magnitude of the local source impacts. 

a. The local area analysis must address the same time frame as the regional analysis. If 

Michigan uses regional modeling for years centering on 2005, then Michigan must assure 

that its local area analysis also represents conditions in the years centered on 2005. 

Tables 7 and 9 show a downward trend measured PM2.5 at all monitors. They also show 

that the difference between Allen Park and Dearborn has gotten smaller over time. This 

means that presumably, the local contribution to PM2.5 at Dearborn is smaller now than 

it was 3-5 years ago. Thus, if Michigan’s principal analysis of attainment uses data 

centered on 2005, then a lower local source impact would be warranted. 

b. The Sonoma report identifies a “Steel Industry” impact at the Dearborn monitor of 

0.81 ug/m3. The failure to note this result is a serious omission from the draft SIP that 

reduces its credibility. The Sonoma report identifies several other industrial source types 

with similar or greater impacts. The steel mill impact, which reflects the impact of 

Severstal and other sources with similar types of emissions, is a better starting point for 

assessing the impact of local source controls, particularly the controls at Severstal. 

PM 2.5 PUBLIC COMMENT PERIOD RECORD

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2

EPA has also conducted analyses of the impact of steel mills in this area. EPA estimated 

that these sources cumulatively contribute 0.48 ug/m3 to this monitor. Further details of 

EPA’s analysis are provided in “Regulatory Impact Analysis (RIA) for the Proposed 

National Ambient Air Quality Standards for Particulate Matter,” dated October 6, 2006, 

in particular in Appendix B, “Local-Scale Assessment of Primary PM2.5 for Five Urban 

Areas,” at page B-29, Table 17. 

We are continuing to examine the various studies that evaluate the impact of various local 

sources. Nevertheless, it appears that Michigan has substantially overstated the impact of 

local sources included in its analysis, such that the benefit of the noted local controls is 

likely to be substantially less than the draft SIP estimates. 

2. The validity of the local area analysis depends on assuring that the local source impact 

determined by monitoring data analysis reflects the impact of a set of sources that 

reasonably corresponds to the set of sources included in the local area modeling, as well 

as assuring that the composition (mix of PM2.5 components) included in the estimated 

local impact reasonably corresponds to the composition of the modeled emissions. We 

have several comments regarding how well the impact estimate corresponds to the 

emissions being analyzed. 

a. The draft SIP’s estimates of local source impacts reflect the results of source 

apportionment analyses. By their nature, such analyses involve substantial quantities of 

information regarding the composition of each of the source combinations identified as 

contributing to the observed concentrations. This information should be presented, along 

with more information about the studies generally. 

This information should indicate the relative proportions of the various PM2.5 

components that are included. The draft SIP focuses on the combination of “mixed 

industrial” and “soil.” As noted above, information on the contribution of steel industry 

sources is more germane to Michigan’s local area analysis and would provide a better 

means of assessing the impact of emission reductions at Severstal. 

b. The identified sources for the AERMOD modeling only included point sources. 

Michigan must either include other relevant sources or use an estimated impact of local 

sources that excludes the impact of other sources. Other local sources that may be 

affecting the monitors include locomotives and other non-road vehicles, on-road vehicles, 

road dust, and other area sources. Since Michigan in particular has not included “soil”-

related emissions in its modeling analysis, it is inappropriate to include “soil” in its 

monitoring-based estimate of local source impacts. If the impact of local rail operations 

are included in the monitored impact value, it would clearly be important to include those 

sources in the modeling analysis as well. Excluding important local sources of primary 

PM from the modeling but including the impact of those emissions in the monitoringbased impact estimate will cause an overstating of the importance of the modeled 

sources. 

PM 2.5 PUBLIC COMMENT PERIOD RECORD

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c. The AERMOD modeling and post-processing used only total PM2.5 data. Speciation 

of the PM2.5 data into components (organic particles, elemental carbon, sulfate, nitrate, 

and other) should be applied to help determine how much of the emissions and emissions 

reductions (especially from Severstal) may actually be organic particles or elemental 

carbon. It may not be reasonable to assume that all of the PM2.5 emissions are 

crustal/metals without documentation of assumed speciation profiles from these facilities. 

The CAMx modeling speciation profiles are one source of data. 

d. Similarly, Michigan should characterize the composition of the estimated impact of 

local sources to the extent practicable. At least some of this information is available from 

the source apportionment analyses Michigan is using. This type of information is 

essential to assess whether the impact estimate appropriately matches the emissions 

included in the local area modeling. 

The evidence available suggests that the ambient impact used in Michigan’s analysis 

includes a significant fraction of organic particles, especially insofar as this impact 

estimate reflected conditions around 2002. In contrast, the local area modeling appears to 

include very little organic particle emissions. The result appears to be the application of a 

reduction percentage derived from principally inorganic particle emissions data to an 

impact estimate that includes particulate matter (especially organic particulate matter) 

that is not reduced by that percentage. Thus, more generally, despite the challenges of 

addressing speciated information, this type of information is necessary to assure that the 

estimated local impact properly matches the emissions used in the modeling analysis. 

3. Conceptually, Michigan is considering some portion of the monitored concentration to 

be attributable to regional sources and some portion of the monitored concentration to be 

attributable to local sources. It follows that the regional model would only address 

prospective changes in the impacts of regional sources, just as the local area analysis only 

speaks to the impact of local sources. That is, if the 2005-centered total design value at 

the Dearborn monitor is 17.6 ug/m3, and if the impact of the addressed emissions of local 

sources is 2.3 ug/m3, then the regional modeling would only address the difference of 

15.3 ug/m3. 

Since the multiplication by relative response factors is done on a PM2.5 component-byPM2.5 component basis, we recommend that Michigan estimate the local source impact 

on a component-by-component basis, subtract these values from the total estimated 

component concentrations, and thereby obtain an estimate of the portion of the observed 

concentration for each component that is attributable to regional sources (i.e., sources and 

emissions not included in the local area analysis). These regional values should then be 

multiplied times the appropriate relative response factor to estimate the future year 

concentrations attributable to regional sources. 

4. We have several more specific comments on procedures for the local modeling 

analysis. 

PM 2.5 PUBLIC COMMENT PERIOD RECORD

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4

a. The greatest impact of PM2.5 from Severstal on Dearborn seems to be due to 

emissions from roof monitors. The parameters used when modeling these emissions as 

volume sources in AERMOD suggest that the emissions from the roof monitors have no 

buoyancy (i.e. are emitted at ambient temperature). In fact these emissions would be 

quite hot. Consideration of the buoyancy of these emissions in the modeling run could 

have a large impact on the results. 

b. For the AERMOD run which analyzed the impact of Severstal at the Dearborn 

monitor, the rural setting was used though the sources are clearly in an urban area and 

would most likely experience the effects of the urban heat island effect at night. Using 

the urban setting for this analysis would be more appropriate. Given that this rural run 

does not include the increased turbulence at nighttime due to the simulation of the urban 

heat island effect that would be included in the urban run, the contribution of the roof 

monitor emissions from Severstal could be overestimated due to an increased number of 

simulated stable conditions. 

c. On Page 20-21, the last several paragraphs of Section 9.6.2 discuss the guidance for 

demonstrating attainment for Ozone, PM2.5, and Regional Haze. The text further 

discusses how several aspects of the guidance were not followed; e.g., quarterly analysis 

and speciated primary PM2.5. As a general rule, the guidance should be followed. If 

situations arise where the guidance isn't followed, justification and documentation should 

be provided to allow the reviewers to assess the validity of the alternative method. It's 

not clear whether or not quarterly RRF's would result in a significantly different result 

than use of the annual values. Quarterly RRF's should be developed from the modeling 

and applied to the local source contribution to the primary quarterly PM2.5 value. 

d. No information is presented to discuss how the meteorological data has been 

processed, for example what surface and upper air stations were used and how the surface 

characteristics were generated. The meteorological preprocessor for AERMOD, called 

AERMET, incorporates surface characteristics (i.e., surface roughness, Bowen ratio, 

albedo). The selection of surface characteristic values can have a significant impact on 

predicted concentrations. Documentation on these aspects should be included to allow a 

more comprehensive review. 

e. The documentation indicates 1 year of meteorological data was used. The guidance 

recommends more data be used if available. Five years of met data (e.g., 2002-2006) 

should be modeled to determine if there is variation in the local sources impact 

contribution from year to year. This could be particularly important in determining the 

relative response factor and in Step 2 on page 21 where the percent of the local primary 

PM2.5 determined to come from Severstal is based on AERMOD results. 

f. EPA’s guidance recommends using a receptor grid sufficient to represent local scale 

impacts at and near the monitor. We recommend applying a 100 meter receptor grid, 

extending out a distance that would preclude receptors being located on modeled source 

private property (e.g., 300-400 meters). The receptors should be averaged to obtain a 

representative value. 

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5. We would request several types of information that would clarify the nature of the 

State’s analyses. 

a. Throughout the main document there are references to modeling and inventories for 

2002, 2005, and 2009. The CAMx modeling used 2005 and 2009, and the AERMOD 

modeling used 2002 and 2009. However, it is difficult to understand what emissions 

levels were used in various parts of the modeling analyses. Many of the tables in 

Appendix A have inconsistent inventory numbers and it is not always clear what year the 

emissions represent. Also, there is limited documentation available for the CAMx 

modeling inventories. We request the following inventory summary information: 

1) Statewide emissions totals (NOx, VOC, SO2, PM2.5, etc.) used for the 2002, 

2005, and 2009 CAMx modeling for EGU, non-EGU point, area, on-road mobile, 

and non-road mobile. 

2) The same information for the Detroit nonattainment area. 

3) Detailed emissions summaries for 2005 and 2009 for the Detroit area EGUs (by 

unit). 

4) PM2.5 emissions summaries for 2002/2005 and 2009 for all sources modeled with 

AERMOD. 

5) CAMx emissions summaries for 2005 and 2009 for the AERMOD sources. 

6) Detailed emissions (by process and/or stack) for the AERMOD sources. (See 

comment 5.c below) 

b. Page 52 of the TSD shows emissions totals by State and by sector. The emissions 

projections for Michigan for EGU SOX emissions in 2009 projected from 2005 are 667 

TPD. The Michigan EGU SOX emissions in 2009 projected from 2002 are 1,022 TPD. 

The Michigan EGU SOX emissions in 2002 are 1,103 TPD and 1,251 TPD in 2005. 

There is clearly some change in methodology or some reason that needs to be explained 

about why Michigan SOX emissions are higher in 2005 than 2002 and so much lower in 

2009 when projected from 2005 compared to 2009 projected from 2002. 

c. The SIP should also better clarify the inventory of sources used in the local modeling 

analysis. Further documentation of the inventory should especially be provided for 

Severstal, including full documentation of the estimates of emissions before and after 

compliance with the requirements that Michigan has adopted for this company. Given 

the potential for deterioration of control equipment, this documentation should identify 

the limits being imposed, so as to reflect the degree of control equipment deterioration 

which could occur without violating the adopted requirements. The draft SIP should 

include the complete AERMOD input files for both the base case and the future case 

runs. 

Based on information provided informally to EPA, it appears that Michigan has assumed 

a reduction of emissions at Severstal that likely represents an overly optimistic capture 

and control efficiency mandated by the applicable limit. It is also not clear whether the 

emission estimates for the future case and the current case are based on the same 

underlying emission factor. 

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d. The regional modeling indicates PM2.5 reductions of 1.5-1.9 ug/m3 at the Detroit area 

monitors between 2005 and 2009 (Table 1). Application of the speciated model 

attainment test involves calculating changes in concentration for each PM species. 

Therefore, the 1.5-1.9 ug/m3 reduction can be broken down into each of the component 

species. Please supply a table which shows the changes in PM species to allow a better 

understanding of where the PM reductions are coming from. 

e. There is a discussion of the emissions from switching locomotives, noting that 28 of 

them will be retrofitted with anti-idling equipment. It is noted that the emissions from 

these sources are relatively small, but may be important due to their proximity to 

monitors and the fact that they operate 24 hours per day. From the documentation it is 

not clear: 

1) Where all of these rail yards and locomotives are located. 

2) Which ones will be retrofitted or replaced. 

3) How these locomotives and other rail yard sources were modeled in the regional 

modeling and local scale modeling. 

f. To help support the modeled conclusions, it would be helpful to include a discussion on 

the meteorological data used in the AERMOD modeling, including some information that 

support the fact that the number of calms in the 2002 meteorological data was not 

unreasonably large. This seems particularly important in this modeling exercise where 

the greatest impacts are coming from roof monitor emissions close to the receptor that are 

modeled as non-buoyant. 

g. NOx and SO2 RACT modeling is mentioned on page 17 of this section. It is unclear 

how the impact of the 50% reduction in all NOX emissions across the entire State was 

evaluated. The term “relative reduction factor” is mentioned but the estimation 

methodology is not described in any detail. 

h. According to the discussion on page 21, the 2009 project design value for Dearborn 

(15.7) and SWHS (14.2) are based on “on the books” controls after a review of the TSD. 

The TSD has results for each monitor in 2009 based on “on the books plus will do” 

controls and has slightly higher 2009 projected design values for Dearborn (15.8) and 

SWHS. Michigan should clarify whether the “will do” scenario includes the changes in 

emissions from the 3 local sources in Wayne County that are mentioned in the local scale 

dispersion modeling. Michigan should also further explain the differences in controls in 

Southeast Michigan between the “on the books” scenario and the “on the books plus will 

do” scenario. It is difficult to understand why controls beyond those that are on the 

books will lead to an increase in the projected design value. 

h. It is unclear from the write-up how the primary PM2.5 emissions from Severstal were 

modeled in CAMx. Michigan should explain whether the full emissions were modeled 

for both the base and future year CAMx runs, whether the PM2.5 emissions were 

excluded entirely, or whether the 2009 CAMx run reflects emission controls at this 

facility. If Michigan has concluded that it has avoided double-counting the effects of 

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Severstal and its emission changes, Michigan should explain its rationale for this 

conclusion. 

6. We have comments on the supplementary evidence as to whether Southeast Michigan 

will attain the standard by 2009. 

a. Some important evidence, contributing to the weight of evidence, suggests that 

Southeast Michigan will not attain the standard as early as 2009. First, modeling 

conducted by LADCO based on 2000 to 2004 data suggests that the area will be at 17.7 

ug/m3 (minus any reductions from local source emission controls) in 2009. Second, the 

modeling described by Michigan assumes full control of the Monroe power plant, 

whereas the installation of controls at this plant are not expected to occur until mid- to 

late 2009, so that the significant benefits of this control will mostly not occur in 2009. 

For these reasons, and given our concerns about the magnitude of air quality 

improvement that can be expected from the local source controls, we are concerned about 

the prospects that Southeast Michigan will not in fact attain the standard in 2009. 

b. The draft SIP cites a number of emission reductions, implying that these improve the 

prospects beyond what would be inferred from the modeling results. However, most of 

these reductions occurred before 2005, so that these reductions would already be 

reflected in 2005 air quality and thus would already be reflected in Michigan’s modeling 

analysis. 

Most of the plants on the list in Table 4 were closed by 2005. The largest change in 

emissions from plant closings is with NOx, and we agree with the implication that NOx 

emission reductions can have significant benefits for PM2.5 air quality. However, use of 

air quality data centered on 2005 in the modeling analysis inherently already takes credit 

for these air quality benefits. 

Similarly, many of the reductions at Marathon occurred either before or during 2005, and 

the controls at US Steel were implemented in mid-2005. Thus, these reductions are also 

inherently already largely reflected in the modeling analysis. 

Conversely, some emission increases are expected at relevant local sources. For 

example, Severstal is expected to increase its NOx emissions by 37.6 tons per year. If 

the rail yard reductions in NOx (67 and 66 tpy) are significant given their proximity to 

the monitor of interest, then the increase in Severstal’s emissions would also be 

significant. Severstal is also expected to increase its SO2 emissions. Emission increases 

between 2005 and 2009 are also expected at Marathon. 

Reasonably Available Control Technology (RACT)/Reasonably Available Control 

Measures (RACM)

1. The comments above suggest significant prospects that Michigan will not attain the 

PM2.5 standard in 2009. In this context, it appears that Michigan has not provided the 

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review and implementation of RACT measures that the PM Implementation Rule 

requires. 

Michigan seems to have conducted very little review of candidate control measures. 

Michigan must address RACT for the range of significant PM2.5 components or their 

precursors, as applicable for sources throughout the designated nonattainment area. This 

review must address directly emitted organic and inorganic particles as well as SO2 and 

NOx. 

2. Michigan conducted sensitivity modeling assessing the impact of an arbitrary 

percentage reduction of NOx and SO2 emissions, including one run assessing the impact 

of statewide reductions and another run assessing the impact of reductions within the 7-

county nonattainment area. While we are not fully clear on the details of Michigan's 

analysis, Michigan's results suggest to us that reduction of NOx and SO2 emissions in 

Michigan have the potential to provide significant benefit for air quality in the Detroit 

area. We do not think the analysis approach in Appendix F can adequately address the 

RACT/RACM requirement. 

Control measures outside the nonattainment area in some cases have less air quality 

benefit in the nonattainment area and may be less reasonable than control measures 

within the nonattainment area. Nevertheless, Michigan must evaluate the candidate 

measures and assess whether any of these measures can reasonably be implemented 

outside the nonattainment area. 

Within the nonattainment area, given the significant air quality problems that exist and 

appear likely to remain, we believe that Michigan upon further review will identify 

several measures that will be found to constitute RACT. Two measures in particular that 

we would highlight are the set of measures known as "NOx RACT" and coke oven gas 

desulfurization. 

Many states in the Midwest and elsewhere that, like Detroit, are violating both the ozone 

and the PM2.5 standard are adopting rules requiring RACT for NOx. We believe that the 

benefits of reducing industrial point source NOx are commensurate with the portion of 

the inventory that these sources emit. The particulate matter problem by nature involves 

a combination of numerous components, and so the solution to the problem necessarily 

involves numerous measures, no one of which by itself would solve the problem. 

(Indeed, particulate matter appears to have even more contributors than ozone, and an 

even greater variety of control measures may be needed.) It appears that "NOx RACT" 

would have a significant benefit in the Detroit area at reasonable cost. We would be 

happy to share information on the limits that other states have adopted or proposed, to 

provide more information on the limits that they have found to constitute RACT. 

Coke oven gas desulfurization is done at most U.S. coke plants. We believe this measure 

can be expected to provide worthwhile air quality benefits in the Detroit area at 

reasonable cost. Further discussion of this and other iron and steel plant measures is 

provided in a report by RTI International, available at 

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http://www.epa.gov/pm/measures/detroit_steel_recommendations20060207.pdf. This 

report recommends testing of condensible emissions at the EES coke plant to assess the 

quantity of these emissions. These emissions presumably are predominantly sulfate 

emissions, which would be substantially reduced with desulfurization of the coke oven 

gas. That is, desulfurization of the coke oven gas would make moot what quantity of 

condensible particulate matter is currently emitted. 

3. The draft SIP comments on the length of Michigan’s rulemaking process and the 

difficulty of implementing controls before 2010. Since the SIP submittal schedule has 

provided the state 3 years after the April 2005 effective date of the PM2.5 designations to 

complete any necessary rulemaking, the length of the state’s rulemaking process does not 

constitute an acceptable rationale for failing to adopt measures that would facilitate 

attainment. In addition, Michigan has provided very little information on the timetable 

for implementing individual measures. A more detailed review must be conducted to 

identify candidate measures and to evaluate whether each candidate measure is 

reasonable. Given the prospects for continued nonattainment in Southeast Michigan 

beyond 2009, we believe that the SIP submittal schedule is providing Michigan ample 

opportunity to implement additional measures that will assist and expedite attainment. 

4. Regarding organic particle impacts, Michigan’s draft SIP notes the uncertainties 

regarding the composition of this impact. We would comment that 0.8 ug/m3 impact 

attributed to a steel mill, if it all approximates an annual average impact, is a highly 

significant impact. We also note the work underway under LADCO contract to extend 

and enhance previous work on organic particle origins in the Detroit area and elsewhere. 

 

Organic particles are a substantial fraction of the PM2.5 concentrations in Southeast 

Michigan. LADCO has done substantial work to assess contributions to organic particle 

concentrations in Southeast Michigan and elsewhere. This is important information to 

provide in the SIP, in part because it has significant relevance to this plan for providing 

for attainment of the PM2.5 standards. 

The draft SIP comments that the Dearborn monitor records an especially high quantity of 

organic particles, and implicitly suggests that the industrial area has greater than average 

emissions of these particles. For this reason, it is especially important that Michigan 

supplement the air quality analyses with work to investigate these emissions, including 

investigating the industrial sources that would be suspected of emitting this type of 

particulate matter. Since the area has a number of candidate sources of organic 

particulate matter, and since these types of sources appear to have a significant effect on 

air quality, a more thorough investigation of these sources must be conducted. Michigan 

should request stack tests in cases where potentially significant emissions cannot readily 

be estimated accurately through available emission factors. We understand that the 

investigation of candidate measures may need to begin as an investigation of the 

emissions of candidate sources, but for purposes of this SIP the investigation must then 

include an investigation of candidate control measures, with implementation of those 

measures that are reasonable. 

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5. At various places in the SIP, Michigan identifies source types that appear to be 

significant. For example, on page 20, the draft SIP notes that fugitive dust from storage 

piles, unpaved lots, and barren land areas collectively is cause for concern. Michigan 

needs to identify candidate measures and evaluate whether the measures addressing the 

source types that have been identified as contributing to the problem constitute 

RACT/RACM. 

6. Some interesting analysis done by LADCO using nonparametric regression shows 

local area hotspots in Zug Island and at the Ambassador Bridge. The SIP should describe 

what types of controls are being implemented for these 2 hotspot areas that are clearly 

impacting local PM2.5. 

7. Some parts of the discussion of local controls need clarification. On page 32, 

Michigan should provide estimates of PM2.5 emission reductions for U.S. Steel, to 

provide more directly relevant information concerning potential PM2.5 air quality 

impacts. On pages 32-33, for Marathon, it is not clear how the installation of a new 

coking unit to process heavy crude oil will affect PM and PM precursor emissions. 

Enforceability of Control Measures

1. Michigan’s draft SIP does not include copies of any rules, permits, consent decrees or 

other enforceable documents. Therefore, the draft SIP provides no basis for finding the 

control measures described in the SIP to be enforceable or creditable. To make these 

control measures enforceable and creditable, the final SIP must include documents that 

mandate these control measures, and the limits must be provided in a manner that, upon 

EPA approval, could be enforced by EPA. We would also encourage Michigan to send 

us these documents informally for our early review. We intend to examine the limits in 

these documents, to assess the both the enforceability of the requirements and the 

quantitative reduction required, including assessing the degree to which equipment for 

emissions capture and equipment for emissions control might be allowed to deteriorate. 

2. Michigan’s draft SIP notes emission reductions attributable to several source 

shutdowns. For these reductions to be creditable, Michigan must assure that the 

shutdowns are permanent and enforceable, such that the shutdowns will not create offsets 

that would allow a new source or a major modification to use the emission reductions 

negate the air quality benefits of the shutdown. 

Contingency Measures

Under Clean Air Act and the Implementation Rule, contingency measures must be able to 

“take effect without significant further action by the State or EPA.” Merely having a list 

of potential measures that would be candidates for future evaluation, adoption and 

implementation falls well short of this test. Especially given the prospects that Michigan 

will need to implement its contingency measures relatively soon, Michigan needs to 

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complete the evaluation work in advance of submitting its contingency measures, so that 

the submitted contingency measures will be fully defined measures that can be 

implemented promptly. 

Given our concerns about implementation of RACT/RACM in Southeast Michigan, we 

anticipate that the listed contingency measures will also be evaluated as candidate 

RACT/RACM measures. We expect that Michigan’s work on RACT/RACM measures 

will also lead to identification of other possible contingency measures, just as we expect 

that some of the measures on Michigan’s contingency measure list will prove to be 

RACT/RACM. Once Michigan completes the necessary evaluation of candidate 

RACT/RACM measures, Michigan should from that process obtain sufficient 

information also to provide better defined contingency measures. For each measure, we 

then expect the SIP to document exactly how the measure would be implemented and 

under what schedule and under what circumstances the measure would take effect. 

Reasonable Further Progress

If, as appears to be the case, the Detroit area needs an extension of the attainment 

deadline, then Michigan would need to provide a submittal addressing the requirement 

for reasonable further progress. 

Emissions Inventory

We understand that the final SIP will include more thorough documentation of the 

emissions inventory, including documentation being prepared by LADCO. We will 

provide more thorough comments once that documentation becomes available. 

Nevertheless, we recommend one clarification to the summary information provided 

here. The table has a category of emissions identified as “nh3.” We request further 

explanation of this category. We then recommend use of a more descriptive label for this 

category of sources. 

Monitoring Analyses

1. The draft SIP, at page 18, states that “counties to the north of Wayne County do not 

contribute to PM2.5 nonattainment at the monitors showing violation of the standard.” 

The draft SIP then concedes that an increase in concentrations at the violating monitors 

(characterized as a little increase) “is attributable to Oakland and Macomb Counties.” 

Additional comments on EPA’s designation for Southeast Michigan appear at various 

points throughout the draft SIP. As another example, on pages 4 to 5, the State reiterates 

arguments that only Wayne County should be designated nonattainment and asserts that 

EPA’s inclusion of other counties in the designated nonattainment area was “arbitrary.” 

As you know, EPA promulgated designations effective April 5, 2005. That rulemaking 

included EPA's evaluation of what areas violate the standards, and what areas 

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“contribute” to violations of the standard in accordance with section 107 of the Clean Air 

Act. That rulemaking took into consideration the views of the State. Thus, EPA has 

already addressed the appropriate geographic scope of the area that contributes to 

violations of the standards in Wayne County. As a result of that designation, the SIP 

developed for the Southeast Michigan area must meet the statutory and regulatory 

requirements for nonattainment area plans, most notably the requirement for Michigan to 

submit a SIP providing for timely attainment and adequate analysis and implementation 

of RACT and RACM throughout the nonattainment area. While Michigan has latitude to 

provide for attainment using any of various combinations of measures providing for 

timely attainment, the nonattainment area, by defining the contributing area, represents 

the geographic area for which control measures are most likely to be beneficial and 

necessary. 

EPA has previously explained in detail the reasons for the geographic scope of the 

designated nonattainment area. These reasons were articulated both to the State and to 

Oakland County in the following documents: (i) a letter from EPA to Governor Jennifer 

M. Granholm, dated June 29, 2004; (ii) a letter from EPA to Steven E. Chester, Director 

of MDEQ, dated January 20, 2006; (iii) a letter from EPA to Marc D. Machlin, Esq., also 

dated January 20, 2006, concerning a petition for reconsideration filed on behalf of 

Oakland County, Michigan; and (iv) a letter from EPA to Marc D. Machlin, Esq., dated 

September 25, 2007, concerning a second petition for reconsideration filed on behalf of 

Oakland County, Michigan. These documents and other information relevant to the 

designation may be found at: http://www.epa.gov/pmdesignations/. 

The inclusion of this commentary in the draft SIP suggests that Michigan has failed to 

address the requirement for the SIP to examine candidate control measures throughout 

the designated nonattainment area. Furthermore, of course, we disagree with these 

statements, having thoroughly examined the pertinent issues in our prior rulemaking. 

The area violates the annual standard, which reflects a combination of contributions from 

all wind directions. We have already determined that sources beyond the 3 mile radius 

referenced in the draft SIP and indeed sources outside of Wayne County contribute to 

violations of the standards in the area. Accordingly, the area to be addressed by this SIP 

has already been defined, and the SIP is an inappropriate place to dispute the designation 

or to suggest that the State prefers to fall short of its SIP obligation. 

2. Figure 6 does not suggest that OC is decreasing faster at one location or that it is 

substantively decreasing at all. 

3. Figures 8 and 9 contradict each other. The Detroit urban excess in Figure 8 appears to 

be around 1 to 1.5 ug/m3. The Detroit urban excess in Figure 9 appears to be around 5 to 

7 ug/m3. 

4. Section 9.4 and Figure 18 are very confusing. It is very difficult to discern the mobile 

contribution to OC from Figure 18 because it looks like it contains pie charts of 

contributions to PM2.5 mass and not OC. 

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5. A mobile laboratory study is referenced in this section, but the measurement locations 

relative to Dearborn are not stated and the results are for a single day, so it is difficult to 

discern information relevant to Dearborn. 

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General Summary of Comments and MDEQ Responses for the PM2.5 SIP

Comment: Comments were received from several groups that appreciated the 

opportunity to participate with the SEMOS group in developing this SIP and 

WOE. Several comments supported the WOE approach that clearly analyzed 

emissions inventory, monitoring and modeling to develop the attainment strategy. 

Several comments supported using a focused and cost effective strategy in the 

attainment demonstration by targeting sources local to the monitors showing 

non-attainment instead of applying controls to the whole 7-county nonattainment area. 

Comment: DTE Energy did not agree with including additional sulfur dioxide 

controls on the Edison Energy Service’s coke battery as a contingency measure 

since the coke battery is upwind of the Dearborn monitor. 

Response: MDEQ disagrees and believes that sulfur controls on the coke 

battery are a valid contingency measure and likely have some impact on the high 

monitors. 

Comment: DTE Energy indicated several areas that needed clarification: 

1. The table identified as the “Model Based Projections of Future Year Air 

Quality” has a misleading title and should reflect the true nature of this 

modeling projection. 

2. The SIP needs to address other nearby sites that slightly exceed the 

annual NAAQS, like SWHS and should document why this site is of less 

concern than Dearborn (i.e., regional modeling shows attainment). 

3. Indicated that wind directions need to be addressed consistently in the 

document. Sometimes wind directions are separated into 60-degree 

sectors, and other analyses use 10-degree wind sector data. 

4. The current list of contingency measure sources is too broad and 

ambiguous. 

5. The contingency plan would benefit from more details regarding how 

ongoing special monitoring studies at the Dearborn site will be used to 

identify the source(s) responsible for the organic carbon (OC), and 

possibly the sulfate excess, when compared against Allen Park data. 

 

Response: MDEQ has made these corrections/clarifications. 

Comment: SEMCOG suggested that additional information that has become 

available should be incorporated into the SIP before submitting to EPA. 

Response: MDEQ agrees and has made appropriate updates. 
EPA comments

Region V EPA provided extensive comments on Michigan’s draft PM2.5 SIP, 

particularly focusing on the local scale modeling and including several areas 

where information was lacking or needed updating. MDEQ notes that generally 

accepted procedures for doing the local scale modeling, as has been discussed 

for months by state modelers throughout the region as well as EPA modelers, 

was used in this SIP. The approach taken is conservative in the assumptions and 

has been thoroughly described in the SIP document. Comments and responses 

are as follows: 

Comment: Local area modeling needed to address the same time frame as the 

regional modeling. 

Response: The local scale modeling was re-run using ’05 met data. There was 

very little change in the final values as a result of this action. 

Comment: Results from source apportionment analyses should be noted. 

Response: A review of several source apportionment studies was included in 

Appendix G. 

Comment: Modeling could be run using the urban setting. 

Response: The local scale modeling was re-run using urban meteorological 

data.

Comment: Additional information on the MET data used in modeling is needed. 

Response: Surface characteristic values have been documented. The guidance 

(referenced below) specifies "For both base and future year use the same 1 year 

of met data – the same year as used for the photochemical modeling". The 

guidance DOES say "if available, use more than 1 year of met data" but gives no 

additional information. As 2005 was a worse case year (as opposed to 2004 and 

2006), using the single year of 2005 met is defensible, and it remains consistent 

with the photochemical modeling run. 

Reference: "Guidance on the Use of Models and Other Analyses for 

Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5, and Regional 

Haze"; Section 5.3.2 

Comment: Additional details and permit limits for Severstal’s emissions is 

needed. 

Response: Documentation has been added more completely describing the 

permitted emission limits at Severstal and the emission values modeled. 
Comment: Information on modeling locomotives is needed. 

Response: The table describing how locomotives were modeled in the regional 

and local scale modeling has been updated. 

Comment: Additional information on RACT modeling and RACT analysis is 

needed. 

Response: Additional documentation was provided regarding the 50% cut 

analysis for RACT, including the relative reduction factors, etc. Much more detail 

has been provided on the likely affected sources and affected emissions under 

RACT programs. 

Comment: Additional information on contingency measures is needed. 

Response: MDEQ has added more information on the individual potential 

measures and has ranked the measures on the ease of implementation. 

Comment: Clarification needed on the ‘nh3’ category for the emissions table. 

Response: A footnote was added to the table to clarify that the nh3 emission 

values only apply to the NH3 source category in the table. 

Comment: Clarification needed for several figures in the WOE. 

Response: MDEQ has clarified the figures, adding and revising headings and 

making other revisions. 
Appendix C 

EMISSIONS INVENTORY METHODOLOGY 

SUPPORT DOCUMENTATION 

FOR THE 

FINE PARTICULATE SIP 

January 2008 
Table of Contents 

 Page

1. Introduction ............................................................................................................ 2 

2. EGU Point Sources ............................................................................................... 2 

3. Non-EGU Point Sources ........................................................................................ 6 

4. Stationary Non-Point Sources............................................................................... 10 

5. Non-road Mobile Sources ..................................................................................... 49 

6. On-road Mobile Sources ....................................................................................... 52 

7. Area Source Ammonia and Biogenic Emissions................................................... 53 

 1
1. Introduction 

Emissions inventory documentation support for the PM2.5 Fine Particulate SIP is 

provided in this appendix. An inventory was prepared for all counties in Michigan. 

Mobile estimates for the nonattainment counties were prepared by the Southeast 

Michigan Council of Governments (SEMCOG) and appear in a separate appendix. 

Mobile emissions for other counties were prepared by the Midwest Regional Planning 

Organization’s (MRPO) contractor using traffic and vehicle information provided by the 

Michigan Department of Transportation. The Lake Michigan Air Director’s Consortium 

(LADCO) is the MRPO. The focus of the inventory effort was to produce modeling 

inventories for the base year (2005) and the attainment year (2009). The future year 

projections take into account existing control measures and measures that are known to 

be on the way (e.g., CAIR measures). This inventory is referred to as the LADCO 

Base-M inventory. Procedures used to prepare these inventory products can be found 

in the “Regional Air Quality Analyses for Ozone, PM2.5, and Regional Haze: Technical 

Support Document,” prepared by LADCO. LADCO has produced numerous summary 

reports with State and county total emissions and has posted them on their Internet site 

at: 

http://www.ladco.org/tech/emis/basem/baseM_reports.htm

In a related effort, the 2005 Michigan statewide inventory was submitted to the EPA by 

the Michigan Department of Environmental Quality (MDEQ) pursuant to 40 CFR 

Part 51, Subpart A – Emissions Inventory Reporting Requirements. 

2. EGU Point Sources 

2005 EGU Point Source Methodology 

The 2005 EGU point source data originated with annual emissions data provided to 

Michigan DEQ via the Michigan Air Emissions Reporting System (MAERS). Temporal 

allocation was performed by emission unit, month, day of week and hour using the 

procedures described in “Temporally Allocating Emissions with CEM Data for Chemical 

Transport and SIP Modeling,” available at: 

http://www.epa.gov/ttn/chief/conference/ei15/session4/edick.pdf

In addition to the heat input-based temporal profiles described in the paper, separate 

temporal profiles were developed based on Continuous Emissions Monitoring (CEM) 

reported emissions of NOX and SO2 and these profiles were used instead of heat input 

to temporalize annual emissions of the respective pollutants. The CEM data used as 

the basis of the profiles was that for 2004 through 2006 obtained from the EPA Clean 

Air Markets Division (CAMD) website: 

http://cfpub.epa.gov/gdm/index.cfm?fuseaction=iss.progressresults

 2
Growing EGU Point Source to 2009 

The 2009 data is obtained from Integrated Planning Model (IPM) results obtained by the 

EPA and converted to a modeling inventory by LADCO. The following is a LADCO 

Integrated Planning Model discussion, which details the methodologies used to project 

the EGU emissions to 2009 using results from the IPM model: 

Specifically, future year emissions are based on EPA’s IPM3.0 modeling. Three 

CAIR scenarios were addressed: 

• Round 5a: EPA’s IPM3.0 was assumed as the future year base for EGUs. 

• Round 5b: EPA’s IPM3.0, with several “will do” adjustments identified by the 

States. These adjustments should reflect a legally binding commitment (e.g., 

signed contract, consent decree, or operating permit). 

• Round 5c: EPA’s IPM3.0, with several “may do” adjustments identified by the 

States. These adjustments reflect less rigorous criteria, but should still be some 

type of public reality (e.g., BART determination or press announcement). 

Inter-RPO IPM Global Parameter Decisions (May 11, 2005): 

The following summarizes the decisions made by VISTAS, MRPO, CENRAP, 

and MANE-VU for global assumptions to be used in EGU forecasting with IPM. 

These decisions and changes are made to IPM version 2.1.9 assumptions, which 

can be referenced via EPA’s IPM website at: 

 

 http://www.epa.gov/airmarkets/epa-ipm/ 

 A. Market Assumptions 

 1. National Electricity and Peak Demand 

Decision: Use unadjusted Energy Information Agency (EIA) Annual 

Energy Output (AEO) 2005 national electricity and peak demand 

values. 

 2. Regional Electricity and Demand Breakout 

Decision: Use the existing IPM region breakdown as conducted in 

earlier modeling. 

 3. Natural Gas Supply Curve and Price Forecast 

Decision: Take existing supply curves and scale application to EIA 

AEO 2005 price point. In this approach, the EPA 2.1.9 gas supply 

curves will be scaled in such a manner that IPM will solve for AEO 

2005 gas prices when the power sector gas demand in IPM is 

consistent with AEO 2005 power sector gas demand projections. 

In instances where the power sector gas demand in IPM is lower 

than that of AEO 2005 projections, IPM will project gas prices that 

are lower than that in AEO 2005 and vice versa. 

 4. Oil Price Forecast 

 Decision: Use EIA AEO 2005 values. 

 3
 5. Coal Supply and Price Forecast 

Decision: Take existing supply curves and scale application to EIA 

AEO 2005 price points, coal supply regions, and coal grades. In 

this approach, the coal supply curves used in EPA 2.1.9 are scaled 

in such a manner that the average mine mouth coal prices that the 

IPM is solving in aggregated coal supply regions are comparable to 

AEO 2005. Due to the fact that the coal grades and supply regions 

between AEO 2005 and the EPA 2.1.9 are not directly comparable, 

this is an approximate approach and has to be performed in an 

iterative fashion. This approach does not involve updating the coal 

transportation matrix with EIA assumptions due to significant 

differences between the EPA 2.1.9 and EIA AEO 2005 coal supply 

and coal demand regions. 

 B. Technical Assumptions 

 1. Firmly Planned Capacity Assumptions 

Decision: Use revisions and new data as provided by RPOs and 

stakeholders. 

Decision: Allow North Carolina Clean Smokestacks 2009 data as 

provided to define “must run” units. 

2. Pollution Control Retrofit Cost and Performance [SO2, NOx, and 

Hg] Decision: Retain pollution control retrofit cost and performance 

values. 

 3. New Conventional Capacity cost and performance assumptions 

Decision: Use EIA AEO 2005 cost and performance assumptions 

for new conventional capacity. 

Decision: Retain existing 2.1.9 framework cost and performance for 

new renewable capacity. 

Decision: Exclude constraint on new capacity type builds (i.e., no 

new coal). 

 4. SO2 Title IV Allowance Bank 

Decision: Use existing SO2 allowance bank value (4.99 million tons) 

for 2007. 

 5. Nuclear Re-licensing and Uprate 

Decision: Use existing IPM configuration with updated EIA AEO 

2005 (~$27/kW) incurrence cost for continued operation. 

 

 C. Strategy Assumptions 

 1. Clear Air Mercury Rule (CAMR) 

 Decision: Include CAMR in future rounds of IPM modeling. 

 2. Renewable Portfolio Standards 

Decision: Model Renewable Portfolio Standards (RPS) based on 

the most recent Regional Greenhouse Gas Initiative documentation 

using a single RPS region for MA, RI, NY, NJ, MD and CT. The 

RPS requirements within these states can be met by renewable 

generation from New England, New York and PJM. EPA 2.1.9 

 4
methodology and hardwired EIA AEO 2004 projected renewable 

builds for the remainder of the country. 

 D. Other Assumptions 

 1. Run Years 

Decision: Revise runs years to 2008 [2007-08], 2009 [2009], 2012 

[2010-13], 2015 [2014-17], 2018 [2018], 2020 [2019-22], and 2026 

[2023-2030]. 

 2. Canadian Sources 

Decision: Utilize existing v.2.1.9 configuration (no Canadian site 

specific sources). 

3. Non-EGU Point Sources 

2005 Non-EGU Point Source Methodologies 

The 2005 point source data have as their original sources the 2005 Michigan point 

source emission inventory. This section of the document describes the compilation and 

processing of point source emission data submitted to comply with the Consolidated 

Emission Reporting Rule (CERR) for the EPA NEI 2005 inventory. 

The data originates with the entry of data by the reporting facilities into the MAERS. 

The electronic data received from the reporting facilities is reviewed and compiled by 

the MDEQ, and exported to the fixed-width text version of the National Inventory Format 

(NIF). After the exported data is loaded into a PostgreSQL database patterned after the 

MS Access version of the NIF, the following processing steps and checks are 

performed. 

Both emissions estimated by default calculations in MAERS and any emissions reported 

by facility operators are maintained in MAERS. For evaluation and quality assurance 

purposes, both types of records are included in the exports. To avoid double-counting, 

where a specific process/pollutant has emission records both reported directly by the 

facility operator, and estimated via MAERS calculations, the latter are excluded. 

Portable facilities, such as asphalt plants, report total throughput and emissions, plus 

operating percentages for each county in which the portable facility was located during 

the year. From this information, records are generated for each county of operation, 

and throughput and emissions are apportioned based on the operating percentages 

reported by county and process. As geographic coordinates for all operating sites are 

not reported, coordinates corresponding to the centers of the counties of operation are 

assigned. 

As attention has shifted from total particulate to PM10 and PM2.5, total particulate records 

are excluded from the reporting requirements. 

 5
Over 99.8 percent of total criteria emissions are accounted for by emissions reported by 

operator; therefore, exported criteria emissions estimated via MAERS calculations are 

excluded. 

In the site table, where strFacilityCategory is not set in the export, it is set to “01.” 

Mandatory geo-coordinate fields were added to the NIF specifications released in 

December 2003, well after it would have been possible to collect this information from 

the reporting facilities for 2002 operations. The following values were deemed most 

often representative and the exported data are updated accordingly for 2002 data: 

“strHorizontalCollectionMethodCode” is set to '027' 

“strHorizontalAccuracyMeasure” is set to '2000' 

“strHorizontalReferenceDatumCode” is set to '001' 

“strReferencePointCode” is set to '106' 

For 2005, these geographic data elements were requested of the facilities. The defaults 

above were applied only where data was not provided by the facility. 

 

MAERS tracks emissions of some pollutants that are of interest to the Great Lakes 

Commission, but which do not have corresponding pollutant codes in the most recent 

NIF pollutant code table. Emission records for the following pollutant codes are 

excluded: 

7440508; 8052413; DICDD,TOT; DICDF,TOT; HYDFLUORO; PERFLUORO; 

TRICDD,TO; TRICDF,TO; CH4; CO2; N20; 117840; 7783064. 

Emission records for ammonia are exported with the Chemical Abstract Service (CAS) 

number 7664417, rather than the pollutant code NH3. These pollutant codes are 

updated to NH3. Likewise, records exported with pollutant codes PAH and POM are 

updated to pollutant codes 234 and 246, respectively. 

 

All criteria and HAP emissions are reported at the process level, and the export routines 

reflect that in the strEmissionDataLevel field of the emission table. This field is set to 

null for criteria pollutant emission records per EPA guidance. 

All emissions are exported as pounds of annual emissions. The EPA guidance 

suggests that criteria pollutant emission be reported in tons. The field 

strEmissionUnitNumerator is changed to TON and the filed dblEmissionNumericValue is 

divided by two000 for criteria pollutant emission records. 

Null values in the quarterly throughput fields of process records are set to zero. 

Where quarterly throughput fields of process records sum to zero, throughput 

percentages are set to 25% for each quarter. 

 6
MAERS recognizes a control device code of '909' for a “Roll Media Fiberglass Tack 

Filter (Tacky 1 side),” which is not recognized in the NIF code tables. Where this control 

device code is exported, the “strPrimaryDeviceTypeCode” field of the control equipment 

table is updated to a value of 058. 

Because of the exclusion of emission records as described above, referential integrity of 

the exported data can be compromised. At this point, it is re-established by deleting 

records stepwise, in the following order. 

CE records without corresponding EM records 

PE records without corresponding EM records 

EP records without corresponding EM records 

ER records without corresponding EP records 

EU records without corresponding EP records 

SI records without corresponding EU records 

The data are then checked again for referential integrity and mandatory fields and then 

loaded into the MS Access shell version of the NIF via append queries that connect to 

the PostgreSQL data tables via ODBC. The Basic Content and Format Checker is run 

and its output is reviewed. Where corrections are needed, to assure consistency 

among data sources, the corrections are made in the MAERS and a full iteration of the 

export and post-processing steps are performed. 

The 2005 point source inventory was incorporated into the LADCO Base M inventory 

and serve as the basis for Michigan’s 2005 CERR submittal. 

Growing Stationary Non-EGU Point, Stationary Area, Locomotive, Shipping, and 

Aircraft Categories to 2009 

The 2009 emissions are based on work and a follow-up report (E.H. Pechan & 

Associates, Inc., Development of Growth and Control Factors for Lake Michigan Air 

Directors Consortium, Final Report, December 14, 2004) done by E.H. Pechan & 

Associates, Inc. (Pechan). This work supports LADCO’s efforts to forecast 

anthropogenic emissions for the purpose of assessing progress for air quality goals, 

including goals related to regional haze and attainment of the ozone NAAQS. The 

Pechan growth factors were used to estimate the LADCO base M future year emissions 

posted by LADCO in 2007. The future year emissions represent both emission controls 

that already exist and those that are known to be on the way (e.g., CAIR control 

measures). 

To assess progress for attaining air quality goals, LADCO requires emission activity 

growth and control data to forecast emissions from a 2005 base-year inventory to 

several future years of interest. These future years include 2009, 2012, and 2018 (e.g., 

2018 is the first milestone for regional haze reasonable progress demonstrations). 

Pechan prepared emission control factors to support forecasting for each of these 

years. Because the incremental level of effort required to develop emission activity 

 7
growth factors for each year over the 2003-2018 period was nominal, Pechan prepared 

non-EGU point and area and non-road source growth factors for each year over this 

entire period. 

The report describes Pechan efforts to develop emission growth and control data to 

support future year air quality modeling by LADCO. The report is organized into a 

background chapter and: 

Chapter II, which describes the development of the emission activity growth data; 

Chapter III, which discusses how the emission control data were compiled; 

Chapter IV, which describes the preparation of the growth and control factor files; 

Chapter V, which identifies projection issues for future consideration; and 

Chapter VI, which presents the references consulted in preparing this report. 

The Pechan Growth and Control Factor report is too lengthy to be included in this 

document, but it can be provided upon request or downloaded at: 

http://www.ladco.org/reports/rpo/MWRPOprojects/Strategies/Growth&ControlDraftRepor

tOct26-04.pdf

For sectors non-EGU point source, stationary area source and MAR source sectors, the 

future year emissions for the LADCO States were derived by applying growth and 

control factors to the base year inventory. As stated above, these factors were 

developed by a contractor (E.H. Pechan). Growth factors were based initially on EGAS 

(version 5.0), and were subsequently modified (for select, priority categories) by 

examining emissions activity data. 

Additional information on the procedures used to project emissions can be found in the 

“Regional Air Quality Analyses for Ozone, PM2.5, and Regional Haze: Technical Support 

Document” prepared by LADCO. 

4. Stationary Area Sources 

2005 Stationary Area Source Emission Inventory 

The following is a description of the various area source categories that were 

inventoried as part of the year 2005 emissions inventory as required by the EPA under 

the CERR. It also provides documentation as part of the development of a broader 

emissions inventory (which encompasses point, area, non-road mobile, on-road mobile, 

and biogenic sources) that is being developed for (SIP requirements for attainment with 

the 8-hour ozone and PM2.5 NAAQS and the regional haze regulations. For the purpose 

of developing state SIPs to demonstrate compliance with the ozone NAAQS, PM2.5

NAAQS and regional haze rule, states are currently required to submit base-year 

inventories, 3-year cycle update inventories, rate of progress inventories, and modeling 

inventories. In a November 18, 2002 memorandum – 2002 Base-year Emission 

 8
Inventory for SIP Planning Process, EPA identified year 2002 as the base-year for the 

SIP planning process. Within 3 years after designations are determined, states will 

need to submit SIP attainment demonstrations for the 8-hour ozone and PM2.5 NAAQS. 

The 2002 base-year inventory serves several purposes in supporting air quality 

modeling and control measure selection to determine the types and amount of emission 

reductions needed to meet reasonable further progress (RFP) and rate of progress 

(ROP) emission reduction targets and demonstrate attainment. Many of the emission 

inventory planning requirements can be found in the EPA document entitled: Emissions 

Inventory Guidance for Implementation of Ozone and Particulate Matter National 

Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations. Subsequent 

to the submission of the 2002 inventory, there was considerable discussion by LADCO 

staff with states and the EPA as to the appropriateness of 2002 base-year inventory 

with respect to using a 2005 base-year inventory. At the time of the preparation of the 

year 2005 emissions inventory, these discussions were still ongoing between LADCO 

and EPA. EPA designated nonattainment areas for the 8-hour ozone NAAQS with an 

effective date of June 15, 2004, while nonattainment designations for the PM2.5 NAAQS 

were published in the Federal Register later on January 5, 2005, with an effective date 

of April 5, 2005. For those states participating in regional planning organizations, there 

are additional SIP inventory requirements for regional haze. The cascading effect of 

subsequent nonattainment designations as well as subsequent attainment 

demonstrations, existing emission reductions from NOx SIP calls, and the 

appropriateness of the base-years 2002 and 2005 were discussed by LADCO, EPA, 

and the states. The 2005 inventory was developed to fulfill both a base-year inventory 

and three-year cycle update inventories that are required by the existing CERR. 

The following chart shows the specific air pollutants that must be provided by the CERR 

and base-year inventories for the 8-hour ozone and PM2.5 NAAQS and regional haze 

regulations. 

 9
Required Air Pollutants Emissions 

CO NH3 NOX Pb

PM10-

PRI 

PM25-

PRI SOX VOC 

Consolidated 

Emissions 

Reporting Rule 

(CERR) 

√ √ √ √ √ √ √ √

Ozone NAAQS √ √ √

PM2.5 NAAQS √ √ √ √ √ √

Regional haze √ √ √ √ √

In producing the 2005 emission inventory, multiple emission estimates must be provided 

to reflect temporal resolution that is required by the CERR and base-year inventories for 

the ozone and PM2.5 NAAQS. These requirements are summarized as follows: 

Temporal Resolution Requirements for Inventories 

Statewide 

Inventory 

Summer 

Weekday 

Consolidated Emissions 

Reporting Rule (CERR) 

Required 

Ozone NAAQS Required Required 

PM2.5 NAAQS Required Optional 

Regional haze Required Optional 

Consequently, the statewide year 2005 emission estimates that are being provided 

reflect the annual and summer weekday for the referenced air pollutants. A list of the 

30 area source categories appears on the following page. EPA requires specific data 

elements to be provided via electronic data transfer using the National Emission 

Inventory NEI-NIFV3.0 format. A description of data structures can be found in the EPA 

publication NEI Input Format (NIF) Version 3.0 User’s Guide Instructions and 

Conventions of Use, April 2003. 

 10
Summary of Area Sources and Respective Air Pollutants Inventoried for 2005 Inve

Seq # 

Area Source 

Description SCCs SIC CO NH3 NOX

1 

Crude oil production 2310010000 1311 

2 

Natural gas production 2310020000 1311 

3 Breweries 2302070001 2082 4 Cutback asphalts 2461021000 2951 5 Distilleries 2302070010 2085 6 

Emulsified asphalts 2461022000 2951 

7 Aircraft refueling 2275900000 4581 8 Commercial coal 2103002000 9999 √ √ √ 9 

Commercial distillate oil 2103004000 9999 √ √ √ 

10 

Commercial kerosene 2103011005 9999 √ √ √ 

11 

Commercial natural gas 2103006000 9999 √ √ √ 

12 

Commercial residual oil 2103005000 9999 √ √ √ 

13 

Gasoline marketing 

2505030120, 2501060100, 2501060051, 2501060052, 2501060053, 2501060200 5541 

14 Industrial coal 2102002000 3999 √ √ √ 15 

Industrial distillate oil 2102004000 3999 √ √ √ 

16 

Industrial kerosene 2102011000 3999 √ √ √ 

11
17 

Industrial natural gas 2102006000 3999 √ √ √ 

18 

Industrial residual oil 2102005000 3999 √ √ √ 

19 Residential coal 2104001000 8811 √ √ √ 20 

Residential distillate oil 2104004000 8811 √ √ √ 

21 

Residential kerosene 2104011000 8811 √ √ √ 

22 

Residential natural gas 2104006000 8811 √ √ √ 

23 

Residential propane 2199007000 8811 √ √ 

24 Municipal landfills 2620030000 4953 √ √ 25 Vessel ballasting 2505020900 4432 26 Vessel loading 

2505020120, 2505020030,2505020150, 2505020180, 

2505020090, 2505020060 4432 

27 Remedial action 2660000000 9511 √ √ 28 

Traffic marking paints 2401008000 1611 

29 Wineries 2302070005 2084 30 Aviation stage I 2501080050 5541 

12
Oil and Natural Gas Production 

The oil and gas production area source category represents those VOC emissions that 

result from the exploration, drilling, and the field processing of crude oil and natural gas. 

Fugitive VOC emissions occur from control valves, relief valves, spills, pipe fittings, 

pump seals and compressor seals in the production and field processing of crude oil 

and natural gas. Individual county crude oil and natural gas production data was 

obtained from the MDEQ, Geological and Land Management Division. VOC emission 

factors were derived from the EPA publication entitled: Revision of Evaporative 

Hydrocarbon Emission Factors (EPA – 450/3-76-039). The emission factors are 107 

pounds of emitted VOC per thousand barrels of produced crude oil and 175 pounds of 

emitted VOC per million cubic feet of produced natural gas. For crude oil production, 

emission controls reflecting NESHAP application of a 45% reduction in VOC were 

considered. This control level was based on EPA determination of an overall 45% 

reduction in VOC from oil and natural gas production facilities. This control reduction 

was obtained from a 5/14/99 EPA fact sheet that was published with the Final Air Toxics 

Rules for Oil and Natural Gas Production Facilities and Natural Gas Transmission and 

Storage Facilities. Rule effectiveness of 80% was then applied, and point source 

deductions were performed to estimate the area source contribution. For natural gas, 

emission controls from Michigan air pollution control rule R336.1629 of 72% and the 

federal emission control reduction in VOC of 19% associated with NESHAP application 

to natural gas transmission and storage were applied. The 19% emission reduction was 

obtained from the 5/14/99 EPA fact sheet that was published with the Final Air Toxics 

Rules for Oil and Natural Gas Production Facilities and Natural Gas Transmission and 

Storage Facilities. The federal NESHAP rule became effective June 17, 1999. Area 

source emissions were then reported using Source Classification Codes (SCC) of 

2310010000 for crude petroleum oil production and 2310020000 for natural gas 

production. 

Vessel Loading/Ballasting 

Evaporative VOC occur from Great Lakes ships when being loaded with gasoline and 

petrochemicals. Vapors are also displaced when cargo tanks are loaded with water for 

ballasting. In order to estimate VOC from vessel loading/ballasting activities, a list of 

marine terminals at Michigan based ports handling petroleum products was obtained 

from the MDOT. Because of the need to acquire information on gasoline and 

petrochemical handling at each Michigan port and the time frames during vessel 

loading/ballasting occurred, a survey form was again sent to the marine terminals that 

were previously surveyed in the 2002 inventory. This State survey approach went 

beyond the EPA’s prescribed inventory procedures in Volume III, Chapter 12 of the 

Emission Inventory Improvement Program January 2001 guidance for Marine Vessel 

Loading, Ballasting and Transit. The survey form requested information on days of 

operation, seasonal fuel transfer information on gasoline, distillate fuel oil, jet naphtha, 

jet kerosene, kerosene, residual fuel oil, and crude petroleum loading into ship and 

barge cargo tanks as well as ballast operations. The survey data was then summed to 

derive individual county totals. The results of this survey revealed that there were only 

 13
two fuel types (contaminated gasoline, and residual fuel oil) where loading had 

occurred. VOC emission factors (0.00009 lbs/1000 gallons of residual fuel oil and 3.4 

lbs/1000 gallons of gasoline) were then applied to their respective fuel volumes to 

obtain the estimated emission losses. Although the EPA, on September 19, 1995, 

issued Federal Standards for Marine Tank Vessel Loading Operations and National 

Emission Standards for Hazardous Air Pollutants for Marine Vessel Loading Operations, 

the respective facilities transferring fuel were exempt from control requirements. 

Consequently, emissions estimates were based on the respective emission factors 

without the application of control measures. Individual county VOC emission estimates 

from loading and ballasting operations were reported using the following SCC codes: 

Vessel Loading/Ballasting 

Operations 

Reported 

SCC Code 

Vessel loading, distillate fuel 

oil 

2505020090 

Vessel loading, gasoline 2505020120 

Vessel loading, residual fuel 

oil 

2505020060 

Vessel loading, crude oil 2505020030 

Vessel loading, naphtha 2505020150 

Vessel loading, jet kerosene 2505020180 

Vessel loading, kerosene 2505020180 

Vessel ballasting, gasoline 2505020900 

Vessel ballasting, crude oil 2505020900 

Service Station Loading (Stage I) 

Gasoline vapor loss occurs at service stations when gasoline is unloaded from delivery 

tank trucks into underground storage tanks. The extent of vapor loss is dependent upon 

the method of filling (splash, submerge, or vapor balanced). In computing VOC 

emissions from service station loading, year 2005 gasoline throughput estimates were 

obtained from Energy Information Administration's Petroleum Marketing Monthly data. 

The monthly data was then summed to derive an estimated statewide gasoline total. 

County gasoline total estimates were then determined by apportioning the statewide 

gasoline by the percent of state gasoline sales occurring within each county. County 

gasoline sales data was obtained from the U.S. Department of Commerce, Bureau of 

Census, Michigan 1997 Economic Census, Retail Trade, Geographic Area Series. State 

gasoline throughput consumption was apportioned on a county basis using the following 

mathematical equation: 

Ct = St x Cs/Ss 

 14
Where: 

Ct = Estimated county gasoline consumption for year 2005 

St = Statewide gasoline consumption for year 2005 

Cs = County gasoline service station retail sales data 

Ss = State gasoline service station retail sales data 

VOC emission estimates were developed based upon the guidance provided in the EPA 

prescribed inventory procedures in Volume III, Chapter 11 of the Emission Inventory 

Improvement Program January 2001 guidance for Gasoline Marketing (Stage I and

Stage II) and subsequent September 2002 Draft Summary of the Analysis of the 

Emissions Reported in the 1999 NEI for Stage I and Stage II Operations at Gasoline 

Service Stations. Year 2005 and summer weekday emission factors were developed 

based upon actual temperature, and RVP fuel volatility information for various regions of 

the State to reflect the applicable RVP control measures. Monthly temperature data 

was obtained for the year 2005 from the NOAA, National Climatic Center Local 

Climatological Data that was utilized in determining year and summer day temperatures 

for the Michigan Upper Peninsula and Michigan Lower Peninsula regions. Reid Vaporr 

Pressure (RVP) data for marketed gasoline during year 2005 was obtained from the 

Michigan Department of Agriculture, Motor Fuels Quality, Laboratory Division. VOC 

mission factors were then developed for splash fill, submerge fill, and vapor balanced 

gasoline dispensing facilities on a county basis which reflected the actual temperature 

and RVP of marketed gasoline products. 

Year 2005 Temperature Summary

Lower Upper

Peninsula Peninsula

Month Month

Avg of Day Avg of Day

Month Maximum Maximum

December 33.5 24.8

January 28.0 18.9

February 33.8 29.5

March 38.2 33.2

April 59.7 53.8

May 64.8 59.3

June 82.4 77.1

July 83.5 79.4

August 81.8 77.1

September 77.3 72.5

October 62.1 55.7

November 49.4 37.1

Year Avg 57.9 51.5

Ozone Season Avg 74.9 69.9

Summer Weekday Avg 82.6 77.9

Stage I loading emission factors were 

determined using the methodology specified in 

September 2002 Draft Summary of the 

Analysis of the Emissions Reported in the 1999 

NEI for Stage I and Stage II Operations at 

Gasoline Service Stations. The following 

equation is presented: 

L = 12.46xSPM/T 

Where: 

L = Loading loss (uncontrolled), pounds per 

1000 gal of liquid 

 loaded 

S= A saturation factor where S= 0.6 for 

submerged loading 

 with no vapor balance, S = 1.00 for 

submerge loading 

 with vapor balance, and S = 1.45 = splash 

 15
loading no 

 vapor balance 

P = True vapor pressure of liquid loaded, pounds per square 

 inch absolute (psia) 

M = Molecular weight of vapors, pounds per pound-mole 

T = Temperature of bulk liquid in degrees F + 460 

The quantity of county gasoline throughput that is splash filled, submerge filled, and 

vapor balanced was estimated on basis of past gasoline surveys, and the applicability of 

state regulations which require the installation of submerge fill or vapor balanced 

systems. These percentages were obtained from the year 1999 emissions inventory. 

The same county fractional percentages of splash filled, submerge filled, and vapor 

balanced were used in the year 2005 inventory for consistency with respect to prior 

emission inventory. 

The respective emission estimates were reported using the following SCC codes: 

Michigan Gasoline Marketing Stage I Emission SCC Codes 

Stage I Type SCC 

Submerge filled 

loading 

2501060051 

Splash filled 

loading 

2501060052 

Vapor balanced 

loading 

2501060053 

The EPA on December 19, 2003 issued final rule requirements for Stage I gasoline 

distribution in Standards of Performance for Bulk Gasoline Terminals and National 

Emission Standards for Gasoline Distribution Facilities (Bulk Gasoline Terminals and 

Pipeline Breakout Stations. These NESHAP requirements will be applied in point 

source inventories for bulk terminals. 

 16
17

Calculation of Stage I Emission Factors for Year 2005

Notes: Gasoline stage I temperatures based on available data as of 5/18/06. Reid vapor pressures were derived from Michigan Dept. of Agriculture analytical data which showed 

higher than expected averages due to the suspension of RVP restrictions during Hurricane Katrina. 

Ozone Summer Year 2005 Year 2005 Year 2005 Year 2005 

Year 

2005 Season Weekday Ozone Summer Ozone Summer 

Annual 

4/1/05-

9/30/05 

6/1/05-

8/31/05 Year 2005 Season Weekday Year Ozone Summer 

Year 

2005 Season Weekday 

Emission Emission Emission Annual 

4/1/05-

9/30/05 

6/1/05-

8/31/05 2005 Season Weekday Annual 

4/1/05-

9/30/05 

6/1/05-

8/31/05 S

Factor Factor Factor Temperature Temperature Temperature Annual RVP RVP 

True 

Vapor True Vapor True Vapor 

Region 

lbs/1000 

gal 

lbs/1000 

gal 

lbs/1000 

gal F F F RVP 

4/1/05-

9/30/05 

6/1/05-

8/31/05 

Pressure 

P Pressure P Pressure P 

Vapor Balance Gasoline 

Upper Peninsula 0.76 0.91 0.99 51.1 69.9 77.9 11.2 9.6 9.0 4.82 5.82 6.4 

Lower Peninsula 0.86 1.00 1.07 57.9 74.9 82.6 11.2 9.6 9.0 5.58 6.5 7 

SE Michigan 0.86 0.96 0.99 57.9 74.9 82.6 11.2 9.3 8.4 5.58 6.23 6.4 

Submerge Fill GasolineUpper Peninsula 4.54 5.44 5.93 51.1 69.9 77.9 11.2 9.6 9.0 4.82 5.82 6.4 

Lower Peninsula 5.19 6.01 6.43 57.9 74.9 82.6 11.2 9.6 9.0 5.58 6.5 7 SE Michigan 5.19 5.79 5.91 57.9 74.9 82.6 11.2 9.3 8.4 5.58 6.23 6.4 Splash Fill Gasoline 

Upper Peninsula 10.97 13.14 14.33 51.1 69.9 77.9 11.2 9.6 9.0 4.82 5.82 6.4 

Lower Peninsula 12.54 14.53 15.54 57.9 74.9 82.6 11.2 9.6 9.0 5.58 6.5 7 SE Michigan 12.54 13.99 14.29 57.9 74.9 82.6 11.2 9.3 8.4 5.58 6.23 6.4 
18

Service Station Unloading/Vehicle Fueling (Stage II) 

Motor vehicle fueling at service stations results in evaporative loss of gasoline. VOC 

emissions are produced during displacement of vaporized hydrocarbons and spillage of 

gasoline during refueling. EPA guidance in Volume III, Chapter 11 of the Emission 

Inventory Improvement Program January 2001 guidance for Gasoline Marketing (Stage 

I and Stage II) recommends the MOBILE model be used to generate refueling (Stage II) 

emission factors for highway emission inventories. Additional procedures were 

presented in September 2002 Draft Summary of the Analysis of the Emissions Reported 

in the 1999 NEI for Stage I and Stage II Operations at Gasoline Service Stations. The 

MOBILE6 model was used to derive the Stage II emission factor by obtaining monthly 

emission factors in grams/VOC mile as well as fuel economy as miles per gallon and 

vehicle miles traveled mix for the different gasoline vehicle types (e.g., LDTV, LDGT, 

and HDGV). For each vehicle type, the monthly emission factor was multiplied by the 

fuel economy to obtain an emission factor in unit grams of VOC/gallon. 

 grams VOC/gallon = Grams/mile x miles/gallon 

Stage II grams/gallon refueling emission factor rates were initially prepared by 

SEMCOG using MOBILE6.2 and then later adjusted for year 2005 state specific RVP 

and temperature data. The vehicle miles traveled (VMT) mix for each vehicle types was 

used to calculate a single weighted monthly emission factor. Summer and average 

annual emission factors were then developed for Southeast Michigan, the rest of the 

Lower Peninsula, and the Upper Peninsula. SEMCOG’s Stage II grams/gallon adjusted 

emission factors are presented below. It is noted that the Stage II emission rates for 

year 2005 were greater than year 2002 rates due to the marketing of RVP exempt fuels 

created by Hurricane Katrina disruption of refinery operations. 

Year 2005 Refueling Emission Rates for State of Michigan 

Average Type and Geographical Area Grams/Gal

lon 

Summer (Average of monthly refueling emission rates for June, July & 

August, 2005) 

 Southeast Michigan (Livingston, Macomb, Monroe, Oakland, St. Clair, 

Washtenaw and Wayne counties) 

2.71 

 Rest of Lower Peninsula (All counties in Lower Peninsula except the 

7 Southeast Michigan counties) 

3.04 

 Upper Peninsula (All counties in the Upper Peninsula) 2.85 

Average Annual (Average of monthly refueling emission rates) 

 Southeast Michigan (Livingston, Macomb, Monroe, Oakland, St. Clair, 

Washtenaw and Wayne counties) 

2.94 

 Rest of Lower Peninsula (All counties in Lower Peninsula except the 

7 Southeast Michigan counties) 

3.05 

 Upper Peninsula (All counties in the Upper Peninsula) 2.94 
19

All rates were initially calculated using MOBILE6.2 model, and then later adjusted for 

year 2005 RVP and temperature conditions. 

The respective SEMCOG grams VOC/gallon were then converted to lbs/1000 gallons. 

 Lbs VOC/1000 gallons = Grams VOC/gallon x 1 lb/453 grams x 1000 gallons 

Year 2005 gasoline throughput estimates were obtained from Energy Information 

Administration's Petroleum Marketing Monthly data. The monthly data was then 

summed to derive an estimated statewide gasoline total. County gasoline total 

estimates were then determined by apportioning the statewide gasoline by the percent 

of state gasoline sales occurring within each county. County gasoline sales data was 

obtained from the U.S. Department of Commerce, Bureau of Census, Michigan 1997 

Economic Census, Retail Trade, Geographic Area Series. Total county emissions 

estimates were based on the county gasoline volume by the corresponding refueling 

emission factor. Emission rates were reported using the SCC code 2501060100. 

Service Station Tank Breathing 

Pressure changes occur within underground storage tanks as a result of temperature 

differences that exist between gasoline vapor and the liquid phases. The exchange of 

vapor within the storage tank to the atmosphere is commonly described as tank 

breathing. 

Underground gasoline storage tank breathing losses were estimated by applying a 1.0 

pound per thousand gallon throughput emission factor using procedures presented in 

EPA’s Volume III, Chapter 11 of the Emission Inventory Improvement Program January 

2001 guidance for Gasoline Marketing (Stage I and Stage II) and September 2002 Draft 

Summary of the Analysis of the Emissions Reported in the 1999 NEI for Stage I and 

Stage II Operations at Gasoline Service Stations. Year 2005 county gasoline 

consumption estimates were obtained by apportionment of the statewide gasoline 

consumption based on the county percentage of state gasoline retail sales. Statewide 

gasoline consumption data was obtained from Energy Information Administration's 

Petroleum Marketing Monthly and county retail gasoline sales information was identified 

in the U.S. Department of Commerce, Bureau of Census, Michigan 1997 Economic 

Census, Retail Trade, Geographic Area Series. Emission estimates were reported 

using the SCC of 2501060200.

Gasoline Tank Truck Transit 

Breathing losses from gasoline tank trucks occurs as a result of pressure changes 

within the containment vessel. The pressure change in the containment vessel is 

caused by temperature differences between the vapor and liquid phases as well as 
20

agitation during transport. Gasoline tank trucks leak VOC vapors and liquids from 

gaskets, seals, and seams during transport. 

Because some gasoline is delivered to bulk plants rather than delivered directly to 

service stations from terminals, the amount of gasoline transferred in any area may 

exceed the total gasoline consumption, due to additional trips involved. Therefore, 

gasoline tank truck transit evaporation emissions were based on the total volume of 

gasoline transferred rather than county consumption level. 

The total gasoline transferred in a given county was obtained by taking the sum of both 

the service station volume delivery and the bulk plant gasoline transfer. The bulk plant 

gasoline transfer volume in a county was obtained from point source data. VOC 

emissions estimates were developed using the gasoline tank truck transit emission 

factors identified by EPA procedures presented in Volume III, Chapter 11 of the 

Emission Inventory Improvement Program January 2001 guidance for Gasoline 

Marketing (Stage I and Stage II) . In this document, VOC loss from gas filled tank truck 

emission factor was 0.005 lbs/1000 gallons while empty vapor-filled tank trucks were 

0.055 lbs/1000 gallons. A single emission factor of 0.06 lbs/1000 gallons was derived 

by taking the sum of the two respective factors, and then applying this emission factor to 

the total transported gasoline volume. Further emission adjustments were then made to 

the respective emission totals to reflect those delivery vessels in those counties that are 

subject to Michigan Air Pollution Control Rule R 336.1627. A control efficiency of 76% 

was considered before subsequent application of an 80% rule effectiveness and 100% 

rule penetration factors for delivery vessels in those counties subject to R336.1627. 

Emission estimates were reported using the SCC of 2505030120. 

Aviation Fuel Stage I Loading 

Gasoline vapor loss occurs at airports when gasoline is unloaded from delivery tank 

trucks into underground storage tanks. Because of the need to temporally adjust aircraft 

refueling emissions for all respective fuel types within all Michigan counties, it was 

determined that local aviation fuel sales information could only be acquired by 

contacting each fuel distributor serving each airport. Because the fleet of the aircraft 

varies at each airport, the amount of fuel type consumed will likewise be dependent on 

the types of aircraft being serviced and not just based upon Landing-Take Offs (LTOs) 

alone. 

A list of those Michigan commercial and private airports where fuels are dispensed was 

obtained from the MDOT publication 2003 Michigan Airport Directory. A survey form 

was then mail to each airport operations manager. Total fuels sales information by fuel 

type(s) and season were obtained from either airport staff or assigned fixed base 

operators. This information was then summed for each Michigan county to provide an 

estimate of the total volumes of jet kerosene, jet naphtha, and aviation gasoline handled 

at each airport facility. Stage I loading VOC emission factors for jet kerosene and jet 

naphtha were determined using the following equation: 
21

L = 12.46xSPM/T 

Where: 

L = Loading loss (uncontrolled), pounds per 1000 gal of liquid 

 loaded 

S= A saturation factor where 1.45 = splash loading 

P = True vapor pressure of liquid loaded, pounds per square 

 inch absolute (psia) 

M = Molecular weight of vapors, pounds per pound-mole 

T = Temperature of bulk liquid in degrees F + 460 

For Stage I aviation gasoline VOC emissions, an emission factor was obtained the EPA 

publication entitled: Documentation for the 2002 Nonpoint Source National Emission 

Inventory for Criteria and Hazardous Air Pollutants (January 2004 Version). The 

resultant emission factors were then applied to the total county fuel throughput after 

considering point source fuel throughput deductions. Because EPA does not have 

itemized SCC codes by fuel type, VOC emissions were added together and reported 

using a SCC of 2501080050. 

Aircraft Refueling (Stage II) 

Aircraft refueling at airports results in the evaporative loss of aviation gasoline, jet 

kerosene, and jet naphtha. VOC emissions occur when vapor laden air in a partially 

empty fuel tank is displaced to the atmosphere during refueling. The quantity of the 

vapor being displaced is dependent upon the fuel temperature, fuel vapor pressure, 

aircraft fuel tank temperature, and the fuel dispensing rate. 

Because of the need to temporally adjust aircraft refueling emissions for each 

respective fuel type within each Michigan county, it was determined that local aviation 

fuel sales information could only be acquired by contacting each fuel distributor serving 

each airport. Because the fleet of the aircraft varies at each airport, the amount of fuel 

type consumed will likewise be dependent on the types of aircraft being serviced and 

not just based upon LTOs alone. 

A list of those Michigan commercial and private airports where fuels are dispensed was 

obtained from the MDOT publication 2003 Michigan Airport Directory. A survey form 

was then mailed to each airport operations manager. Total fuels sales information by 

fuel type(s) and season were obtained from either airport staff or assigned fixed base 

operators. This information was then summed for each Michigan county to provide the 
22

total dispensed volumes of jet kerosene, jet naphtha, and aviation gasoline. VOC 

aviation refueling loss emission factors were obtained from the EPA publication 

Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area 

Sources, 5th Edition and Supplements (AP-42) were then applied to the respective 

county total fuel volumes. 

Aviation Fuel 

Type 

Emission Factor as lbs of 

VOC/1000 gallons fuel 

Jet kerosene 0.08 

Jet naphtha 5.58 

Aviation 

gasoline 

12.20 

Because there is no provision currently to allow for the reporting of emissions by 

individual fuel type, emissions were then summed for all fuel types and reported using 

the SCC code 2275900000. 

Traffic Marking Coatings 

Traffic marking coatings are paints that are used to mark pavement, including dividing 

lines for traffic lanes, parking space markings, crosswalks, and arrows to direct traffic 

flow. VOC emissions result from the evaporation of organic solvents during the 

application and curing of the marking paint. 

VOC emissions were estimated for each county using the methodology identified in the 

EPA’s Volume III, Chapter 14 of the Emission Inventory Improvement Program May 

1997 Final Guidance for Traffic Markings. The preferred method was to conduct 

surveys to determine the volume of water and solvent based coating consumption, 

coating formulation (in terms of pounds of VOC content per applied gallon), and months 

of year 2005 when the coatings were applied. Survey forms were mailed to all Michigan 

county road commissions, major municipality road maintenance departments, and to 

MDOT. In those situations where a county road commission failed to submit such 

information, emission estimates were based upon results of those counties that had 

responded to the survey. An average coating application rate (total gallons of coating 

applied per road miles in county) was first determined from survey respondents. Road 

length miles were obtained for the counties that failed to respond to the survey. Total 

coating gallon consumption estimates were estimated for counties that failed to respond 

by applying the road length miles to the average coating application rate. Similarly, an 

average VOC content (as lbs/gallon) was obtained by dividing the total mass of VOC 

emissions by the total coating volume of survey respondents. The result thereof was 

then applied to the estimated coating volumes for those counties that did not respond to 

the survey. This average density was reflective of the proportions of solvent and water 

based coatings by survey respondents. Seasonal coating application was also based 
23

upon county survey results of the months during which the coatings were applied. It 

should be recognized that year 2002 was a recession year in which Michigan county 

and local governments had limited budgets. Consequently, it is likely that projected 

emissions would be greater during better economic times. Traffic marking paint 

emissions were reported using a SCC of 2401008000 

Cutback Asphalts 

Cutback asphalt is a bituminous road coating material that is prepared by blending an 

asphalt cement tar with a petroleum distillate (such as naphtha, kerosene, or other fuel 

oils). Cutback asphalt is used as a pavement sealant, tack coat, pothole filler, and a 

bonding agent between layers of paving material. Evaporative loss of the solvent from 

bitumen cement occurs as the cutback asphalt cures on the road surface. The rate at 

which VOC emissions occur is dependent both upon the temperature of the applied 

road surface, and the type of solvent used in the formulation of the cutback asphalt 

material. Gasoline or naphtha is used as a diluent in the production of “rapid cure” 

cutback asphalts. Kerosene and other low volatility fuel oils are also used as diluents in 

the production of “medium cure” and “slow cure” cutback asphalts. 

VOC emissions were estimated for each county using the methodology identified in the 

EPA’s Volume III, Chapter 17 of the Emission Inventory Improvement Program January 

2001 Final Guidance for Asphalt Paving. In this document, the preferred method was to 

conduct surveys to determine locally-specific information on cutback asphalt use on 

Michigan roads. 

In order to estimate VOC emissions from the application of cutback asphalt materials 

(rapid cure, medium cure, and slow cure), a survey was mailed to all Michigan county 

road commissions, major municipality road maintenance departments, and to MDOT. 

The survey requested information on: 

1. The quantities of rapid cure, medium cure, and slow cure cutback asphalt 

materials that were applied during year 2005; 

2. The type of petroleum distillate and volume that was used as a diluent in the 

formulation of each cutback paving material; and 

3. The months during which cutback asphalt materials were applied. 

The EPA has determined that evaporation occurs on about four months with 75 percent 

by weight of diluent evaporates in the first day for rapid cure materials while it takes 

about one week for 50 percent by weight of diluent to evaporate from medium cure 

cutback asphalt materials. Conservative estimates were made by assuming that all the 

diluent evaporates within the season during which it is applied. 
24

VOC emission estimates were based on the amount of the petroleum based diluent that 

comprises the cutback asphalt material and then applying their respective solvent 

density. Emission estimates were reported using a SCC of 2461021000. 

Emulsified Asphalts 

Emulsified asphalts are a type of liquefied road surfacing material that is used in the 

same application as cutback asphalts. Instead of blending the asphalt material with a 

petroleum distillate like their cutback asphalt counterparts, emulsified asphalts use a 

blend of water with an emulsifier (soap). Emulsified asphalts either rely on water 

evaporation to cure (anionic-high float emulsions) or ionic bonding of the emulsion and 

the aggregate surface (cationic emulsions). 

In the EPA’s Volume III, Chapter 17 of the Emission Inventory Improvement Program 

January 2001 Final Guidance for Asphalt Paving., the preferred method is conduct a 

survey of emulsified asphalt application on Michigan roads. Survey forms were mailed 

to all Michigan county road commissions, major municipality road maintenance 

departments, and to MDOT. This form requested information on the quantities of 

asphalt materials (in pounds and barrels) applied to Michigan roadways and the months 

during which they were applied. Road length miles were also obtained for all Michigan 

counties. In those situations where a county road commission failed to submit such 

information, emission estimates were based upon results of those counties that had 

responded to the survey. An average application rate (total barrels of emulsified 

asphalts applied per road miles in county) was first determined from survey 

respondents. Total barrel consumption estimates were estimated for counties that 

failed to respond by applying the road length miles to the average emulsified asphalt 

application rate. VOC emissions were obtained by applying an EPA factor of 9.2 lbs 

VOC/barrel of applied asphalt. It was further assumed that all emissions occur during 

the season that the asphalt materials were applied and reported using a SCC of 

2461022000. 

Breweries 

Breweries, microbreweries, brewpubs, and contract brewers emit VOC including 

ethanol, ethyl acetate, myrcene and other higher alcohols from various brewing 

processes. For the smaller brewers, VOC are lost by the fermentation, in brew kettles, 

hot wort, mash and lauter tuns, and through spent grain. Microbreweries and brewpubs 

typically produce beer for patron on-site consumption, although some may have limited 

keg distribution. These smaller microbreweries and brewpubs typically combine some 

processes, and canning/bottling operations typically do not exist since the beer is 

consumed on-site or stored in kegs. 

Various trade organization lists were obtained to identify brewers in the State of 

Michigan along with their beer production. Although there are some regional breweries, 

the vast majority are brewpubs and microbreweries. These facilities have very small to 
25

insignificant volatile organic compound emissions. Emission estimates were based on a 

combined emission factor rate obtained from Compilation of Air Pollutant Emission 

Factors, Volume 1: Stationary Point and Area Sources, 5th Edition and Supplements 

(AP-42) of 3.0465 lbs VOC per 1000 barrels. Consequently, this small emission factor 

and Michigan beer production rates didn’t justify the need for a survey of such 

establishments. Emissions were estimated by establishment on the basis of trade 

reported production and applying the respective emission factor. A SCC of 2302070001 

was used in reporting brewery emissions. 

Distilleries 

Distilleries include ethanol production facilities that are used in the production of 

gasohol motor fuels, grain alcohol for industrial purposes, and distilled spirits for 

personal consumption. These products are produced from the fermentation of aged 

mashed grains with distillation for the capture of desired alcohol based products. The 

fermentation products use yeast to convert grain sugars into ethanol, ethyl acetate, 

isomyl alcohol, isobutyl alcohol and carbon dioxide. Grains used in the process may 

include corn, rye, barley, and wheat. A more detailed description of distilleries and their 

emissions can be found in the EPA publication entitled: Compilation of Air Pollutant 

Emission Factors, Volume 1: Stationary Point and Area Sources, 5th Edition and 

Supplements (AP-42).

During year 2005, there was only one ethanol production facility in operation. The 

Michigan Ethanol LLC - Caro, Michigan facility was already being reported as a point 

source. Consequently, the area source contribution from distilleries using SCC 

2302070010 had zero emissions for all Michigan counties. A number of new ethanol 

plants were under construction, but did not operate in the 2005 inventory year. 

Wineries 

Wineries produce alcohol beverages from the fermentation of fruit juices. The major 

processes in vinification include fruit harvesting, crushing, pressing, fermentation, 

clarification, aging, finishing, and bottling. During this fermentation process of both red 

and white wines, primarily ethanol and smaller quantities of methyl alcohol, n-propyl 

alcohol, butyl alcohol, isoamyl alcohol, and acetaldehydes are produced along with 

carbon dioxide. This process involves the reaction of a yeast with glucose and fructose 

sugars to produce ethanol and carbon dioxide. The EPA emission factors are reflective 

of VOC evolved during fermentation in vinification. 

County estimates of wine production were based upon wine volume information of 

Michigan Department of Treasury tax receipt information supplied to the Michigan 

Grape and Wine Industry Council. A VOC emission factor was obtained from 

Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area 

Sources, 5th Edition and Supplements (AP-42).of 4.6263 lbs VOC/ 1000 gallons This 

emission factor is a sum of ethyl alcohol, methyl alcohol, n-propyl alcohol, n-butyl 
26

alcohol, sec-butyl alcohol, isobutyl alcohol, isoamyl alcohol and acetaldehyde for red 

wine from AP-42. Emission estimates were reported using a SCC of 230207005 

Stationary Source Fossil Fuel Combustion 

The combustion of natural gas, propane-LPG, distillate fuel oil, kerosene, and residual 

fuel oil in small boilers, furnaces, heaters, and stoves are also a source of VOC, NOx, 

particulates, sulfur dioxide, and ammonia emissions. Because these sources are so 

numerous to be identified in point source inventories, this area source category 

attempts to provide a collective estimate of emissions from these smaller energy 

consumption sources by subtracting all fuel used by point sources from total fuel 

consumption. Procedures for the estimation of these smaller sources are presented in 

the EPA’s documents entitled: 

1. Volume II, Chapter 2 of the Emission Inventory Improvement Program January 

2001 Preferred and Alternate Methods for Estimating Air Emissions from Boilers. 

2. Emission Inventory Improvement Program –April 6, 1999, Area Source Category 

Abstract- Fuel Oil and Kerosene Combustion 

3. Emission Inventory Improvement Program –April 6, 1999, Area Source Category 

Abstract-Natural Gas and LPG Combustion

4. Emission Inventory Improvement Program –April 6, 1999, Area Source Category 

Abstract-Coal Combustion

5. Documentation for the Draft 1999 National Emissions Inventory (Version 3.0) for 

Criteria Air Pollutants and Ammonia

6. Hanke, B.H, manuscript prepared for U.S Environmental Protection Agency 

entitled: A National Methodology and Emission Inventory for Residential Fuel 

Combustion

This documentation involves determination of total fuel consumption over an area with 

subsequent fuel deductions made for point source fuel consumption, and then applying 

emissions factors to estimate fuel emissions. 

Total fuel consumption information was based on data supplied from U.S. Department 

of Energy, EIA documents. This unaccounted fuel consumption was then apportioned to 

individual counties using U.S. Census Bureau information for the individual end use 

sector fuel types based upon LADCO states methodology. Area source fuel emissions 

were reported for the following residential, commercial/institutional, and industrial end 

use sectors. Since utility boilers are accounted as point sources, area source emissions 

are not reported for this end use sector. 
27

Residential Boilers & Furnaces 

County emission estimates for the residential end use sector was based upon the 

consumption of natural gas, propane-LPG, distillate fuel oil, kerosene, and coal. This 

energy consumption information was obtained from U.S. Department of Energy, EIA 

data. Since the EIA merely provides statewide fuel consumption totals, county fuel 

consumption estimates were obtained by apportioning the fuel consumption based upon 

the number of year 2000 occupied household census counts using the given fuel. 

Emission estimates were calculated using the following mathematical equation: 

 Cf = Ch/Sh x Sf 

Where 

Cf = Estimated county residential sector consumption of a given fuel type for year 2005 

Ch = Number of year 2000 census occupied households in a given county that utilize a 

given fuel type 

Sh = Total number of year 2000 census occupied households statewide that utilize a 

given fuel type 

Sf = Total statewide residential sector consumption of a given fuel type 

Michigan Residential Fuel Consumption Information Sources 

Residential Fuel 

Type 

U.S. Dept of Energy, EIA Data Sources 

Natural gas Natural Gas Annual 2005, Michigan Table 48 

Propane LPG Petroleum Marketing Annual, 2005, Table 49: Prime 

Supplier Sales Volumes of Aviation Fuels, Propane and 

Residual Fuel Oil by PAD District and State 

Distillate fuel oil Fuel Oil and Kerosene Sales 2005 Report, Table 19: 

Adjusted Sales for Residential Use: Distillate Fuel Oil and 

Kerosene, 2005 

Kerosene Fuel Oil and Kerosene Sales 2005 Report, Table 18: 

Adjusted Sales of Kerosene by Energy Use 

Coal EIA Annual Coal Report 2005, Table 26 U.S. Coal 

Consumption by End Use Sector, by Census Division and 

State 2005, 2004 (Thousand Short Tons) 
28

Upon obtaining county residential fuel consumption estimates for the various fuel types 

in all Michigan counties Cf, emission estimates were obtained by applying an emission 

factor that is specific to that fuel type. These emission factors were obtained from 

various EPA publications. 

Michigan Residential Fuel Emission Factors 

Residential 

Fuel Type 

Units CO NH3 NOx PM10-

PRI 

PM25-

PRI 

SO2 VOC

Natural gas Lbs/million 

cubic feet 

40 0.49 94 7.6 7.6 0.6 5.5 

Propane 

LPG 

Lbs/1000 

gal 

3.2 13 0.68 0.68 0.1 0.5 

Distillate 

fuel oil 

Lbs/1000 

gal 

5.0 0.8 18 2.38 2.13 42.60 0.7 

Kerosene Lbs/1000 

gal 

4.8 0.8 17.4 2.38 2.13 41.1 0.7 

Coal Lbs/ton 275 0.000565 3.0 18.63 4.86 37.83 10 

Sources of Emission Factors: 

1. U.S. Environmental Protection Agency Documentation for the Draft 1999 

National Emissions Inventory (Version 3.0) for Criteria Air Pollutants and 

Ammonia

2. Hanke, B.H, manuscript prepared for U.S Environmental Protection Agency 

entitled: A National Methodology and Emission Inventory for Residential Fuel 

Combustion

3. U.S. Environmental Protection Agency. Final Report on Development and 

Selection of Ammonia Emission Factors

The resulting emission estimates were reported by individual fuel type using the 

following SCC codes. 
29

Michigan Residential Combustion Emission SCC Codes 

Residential Fuel 

Type 

SCC 

Natural gas 2104006000 

Propane LPG 2199007000 

Distillate fuel oil 2104004000 

Kerosene 2104011000 

Coal 2104001000 

Commercial/Institutional Boilers and Furnaces 

Estimation of fuel combustion by the commercial/institutional sector was performed 

using an adaptation of a methodology presented in the U.S. Environmental Protection 

Agency publications: 

1. Emission Inventory Improvement Program –April 6, 1999, Area Source Category 

Abstract- Fuel Oil and Kerosene Combustion 

2. Emission Inventory Improvement Program –April 6, 1999, Area Source Category 

Abstract-Natural Gas and LPG Combustion

3. Emission Inventory Improvement Program –April 6, 1999, Area Source Category 

Abstract-Coal Combustion

County emission estimates for the commercial/institutional end use sector were based 

upon the consumption of natural gas, residual fuel oil, distillate fuel oil, kerosene, and 

coal. This energy consumption information was obtained from U.S. Department of 

Energy, EIA data. Fuels were subtracted for point sources, and the net area fuel 

contribution was apportioned or allocated using procedures instructed by LADCO. This 

procedure involved statewide commercial/ institutional fuel apportionment to a county 

level using the commercial/institutional employment data as obtained from U.S. 

Department of Commerce, Bureau of Census publication entitled: County Business 

Patterns, Michigan: 2003 (CBP/03-24 issued September, 2005). County fuel estimates 

of individual fuel types were estimated using the following equation: 

 Cf = Ce/Se x Sf 

Cf = Estimated county commercial/institutional sector consumption of a given fuel type 

Ce= Total county employment in the commercial/institutional sector 

Se= Statewide employment in commercial/institutional sector 

Sf= Statewide commercial/institutional sector consumption of a given fuel type 
30

Because the Energy Information data includes diesel fuel totals within the distillate fuel 

oil total, these motor vehicle fuels were deducted to provide only an estimate of #1, #2, 

and #4 fuel oils. 

Michigan Commercial/Institutional Fuel Consumption Information Sources 

Fuel Type U.S. Dept of Energy, EIA Data Sources 

Natural gas Natural Gas Annual 2005, Michigan Table 48 

Residual fuel oil Fuel Oil and Kerosene Sales 2005 Report, Table 17: 

Adjusted Sales of Residual Oil by Energy Use, 2004 and 

2005 

Distillate fuel oil Fuel Oil and Kerosene Sales 2005 Report, Table 20: 

Adjusted Sales for Commercial Use: Distillate Fuel Oil, 

Residual Fuel Oil and Kerosene 2005 

Kerosene Fuel Oil and Kerosene Sales 2005 Report, Table 18: 

Adjusted Sales of Kerosene by Energy Use 

Coal EIA Annual Coal Report 2005, Table 26 U.S. Coal 

Consumption by End Use Sector, by Census Division and 

State 2005, 2004 (Thousand Short Tons) 

Upon obtaining county commercial/institutional fuel consumption estimates for the 

various fuel types in all Michigan counties Cf, emission estimates were obtained by 

applying an emission factor that is specific to that fuel type. These emission factors 

were obtained from various EPA publications. 

Michigan Commercial/Institutional Fuel Emission Factors 

Commercial/Institutional 

Fuel Type 

Units CO NH3 NOx PM10-

PRI 

PM25-

PRI 

SO2 VOC 

Natural gas Lbs/million 

cubic feet 

84 0.49 100 7.6 7.6 0.6 5.5 

Residual fuel oil Lbs/1000 

gal 

5 0.80 55 9.07 3.37 194.05 1.13 

Distillate fuel oil Lbs/1000 

gal 

5 0.80 20 2.38 2.13 53.96 0.34 

Kerosene Lbs/1000 

gal 

5 0.80 18 2.38 2.13 41.1 0.713

Coal Lbs/ton 6 0.000565 7.5 6.0 2.2 36.86 0.05 
31

Sources of Emission Factors: 

1. LADCO state uniform adopted emission factors for commercial/institutional 

natural gas combustion 

2. U.S. Environmental Protection Agency. FIRES database 

3. U.S. Environmental Protection Agency. Compilation of Air Pollutant Emission 

Factors, Volume 1: Stationary Point and Area Sources, 5th Edition and 

Supplements (AP-42)

4. U.S. Environmental Protection Agency. Final Report on Development and 

Selection of Ammonia Emission Factors

The resulting emission estimates were reported by individual fuel type using the 

following SCC codes. 

Michigan Commercial/Institutional Combustion Emission SCC Codes 

 Fuel Type SCC 

Natural gas 2103006000 

Residual fuel oil 2103005000 

Distillate fuel oil 2103004000 

Kerosene 2103011005 

Coal 2103002000 

Industrial Boilers and Furnaces 

Estimation of fuel combustion emissions of industrial boilers and furnaces was 

performed in similar manner as the commercial/institutional sector. Statewide industrial 

fuel consumption information was obtained from the U.S. Department of Energy, EIA 

publications. Point source deductions were made for each fuel type to obtain the area 

contribution which was then apportioned to the county level using LADCO prescribed 

procedures. 

 

County fuel consumption estimates of natural gas, residual fuel oil, distillate fuel oil, 

kerosene, and coal were based upon the following mathematical equation: 

 Cf = Ce/Se x Sf 
32

Cf = Estimated county industrial sector consumption of a given fuel type 

Ce= Total county employment in the industrial sector 

Se= Statewide employment in industrial sector 

Sf= Statewide industrial sector consumption of a given fuel type 

Michigan Industrial Fuel Consumption Information Sources 

Industrial Fuel 

Type 

U.S. Dept of Energy, EIA Data Sources 

Natural gas Natural Gas Annual 2005, Michigan Table 48 

Residual fuel oil Fuel Oil and Kerosene Sales 2005 Report, Table 17: 

Adjusted Sales of Residual Oil by Energy Use, 2004 and 

2005 

Distillate fuel oil Fuel Oil and Kerosene Sales 2005 Report, Table 21 

Adjusted Sales for Industrial Use: Distillate Fuel Oil, 

Residual Fuel Oil, and Kerosene (#1, #2, and #4 fuel 

oils– excludes diesel oil) 

Kerosene Fuel Oil and Kerosene Sales 2005 Report, , Table 18: 

Adjusted Sales of Kerosene by Energy Use 

Coal EIA Annual Coal Report 2005, Table 26 U.S. Coal 

Consumption by End Use Sector, by Census Division and 

State 2005, 2004 (Thousand Short Tons) 

County employment data was obtained from the U.S. Department of Commerce, 

Bureau of Census publication entitled: County Business Patterns, Michigan: 2003 

(CBP/03-24 issued September, 2005). Upon obtaining county industrial fuel 

consumption estimates for the various fuel types in all Michigan counties Cf, emission 

estimates were obtained by applying an emission factor that is specific to that fuel type. 

These emission factors were generally based on the LADCO adopted emissions 

factors. 
33

Michigan Industrial Fuel Emission Factors 

Industrial 

Fuel Type 

Units CO NH3 NOx PM10-

PRI 

PM25-

PRI 

SO2 VOC 

Natural 

gas 

Lbs/million 

cubic feet 

84 3.2 100 7.6 7.6 0.6 5.5 

Residual 

fuel oil 

Lbs/1000 

gal 

5.0 0.8 55 7.17 4.67 157 0.28 

Distillate 

fuel oil 

Lbs/1000 

gal 

5.0 0.8 20 2.3 1.55 53.96 0.2 

Kerosene Lbs/1000 

gal 

5.0 0.8 18 2.38 2.13 41.1 0.713

Coal Lbs/ton 6 0.00057 7.5 6.0 2.2 38 0.05 

Sources of Emission Factors: 

1. LADCO state uniform adopted emission factors for industrial natural gas, residual 

fuel oil, distillate fuel oil, and coal combustion 

2. U.S. Environmental Protection Agency. FIRES database 

3. U.S. Environmental Protection Agency. Compilation of Air Pollutant Emission 

Factors, Volume 1: Stationary Point and Area Sources, 5th Edition and 

Supplements (AP-42)

4. U.S. Environmental Protection Agency. Final Report on Development and 

Selection of Ammonia Emission Factors

Emission estimates were reported using the following SCC codes: 

Michigan Industrial Combustion Emission SCC Codes 

Industrial Fuel 

Type 

SCC 

Natural gas 2102006000 

Residual fuel oil 2102005000 

Distillate fuel oil 2102004000 

Kerosene 2102011000 

Coal 2102002000 
34

Remedial Action, Site Clean Up & Leaking Storage Tanks 

Evaporative VOC emissions occur during remediation and clean up at those sites of 

environmental contamination. Such remediation activities may include air stripping or 

sparging of a VOC from contaminated groundwater or incineration of a spoil material 

removed from a contaminated site. In some instances carbon adsorption may be 

required to reduce VOC emitted during air stripping or spraying operations. 

Estimation of VOC loss from remedial action activities was determined by summing the 

allowable emissions from permits to those parties that were engaged in such activities 

as provided by the MDEQ, Air Quality Division, Permit Section. Although site 

remediation activities are subject to NESHAPs, these requirements did not apply at the 

time of the year 2005 emissions inventory. Emissions were reported using a SCC of 

2660000000. 

Municipal Waste Landfills 

A municipal solid waste landfill is defined as any facility that is regulated under Subtitle 

D of the Resource Conservation and Recovery Act (RCRA) which receives primarily 

household and/or commercial wastes. 

VOC are produced from municipal solid waste by: the volatilization of the waste 

material itself, the microbiological (anaerobic) putrefaction of organic waste materials 

that result in the formation of organic acids and alcohols that are vaporized, and the 

chemical reaction of one or more waste materials or chemical decomposition 

intermediate. The rate at which VOCs are emitted from a landfill is dependent upon the 

structural design of cells, the waste composition (physical/chemical properties), the 

moisture content of the waste, the amount of waste disposed, temperature, age of the 

landfill, the chemical reactivity of the waste, the microbiological toxicity of the waste, and 

the effectiveness of landfill gas collection systems. Where landfill gas is collected for 

use in boilers, internal combustion engines (reciprocating and turbines) or flared at the 

landfill site, there are additional air pollutants such as NOx, particulates (PM2.5 and 

PM10), and carbon monoxide produced from incomplete combustion. 

Estimation of VOC emissions from municipal landfills were based on the revised 

technical procedures presented in the EPA publication entitled: Volume III, Chapter 15 

of the Emission Inventory Improvement Program January 2001 Revised Final Guidance 

for Landfills. In this publication, the preferred method for the estimation of area source 

emissions is to use the LandGem model or the equations from the Compilation of Air 

Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources, 5th Edition 

and Supplements (AP-42) section on landfills. LandGem is a computer based model 

that uses the same equations as that of AP-42. The emissions calculation for the 

estimation of landfill gas requires site specific information including: landfill design 

capacity, accumulated waste totals from operation of the landfill, and existing control 

requirements from landfill gas collection systems. Landfills may be subject to either 
35

new source performance standards (40 Code of Federal Regulations part 60 Subpart 

WWW) or emission guidelines (40 Code of Federal Regulations, part 60, Subpart Cc). 

Landfills are now also subject to NESHAPs which became effective on January 16, 

2003. For those landfills that were not being reported in the point source inventory, 

area emission estimates were reported on the basis on LandGem model simulations 

using the SCC of 2620030000. These simulations reflected total waste receipts under 

the prior year 1999 inventory with addition made for waste receipts for years 2000-2005 

as obtained from annual reports by the MDEQ, Waste and Hazardous Division Report 

of Solid Waste Landfilled in Michigan. For those landfills that operated landfill gas 

collection/combustion systems, emission estimates considered tables 2.4-3 and 2.4-5 

of AP-42 with adjustments considered for a landfill gas methane collection efficiency of 

75% of LandGem model predicted methane generation at a given landfill site. 

Non-Methane Organic Compound Control Efficiencies for Landfill Gas 

Combustion from AP-42 

Combustion Control 

Device 

Typical Control Efficiency (%) 

Boilers 98 

Flares 99.2 

Gas Turbines 94.4 

IC Engine 97.2 

Emission Rates for Secondary Compounds from Landfill Gas Combustion 

(Based upon lbs/ Million Cubic Feet of Landfill Gas Combusted) 

Combustion Control 

Device 

NOX PM2.5-

PRI 

PM10-

PRI 

CO 

Flare 40 17 17 750 

IC Engine 250 48 48 470 

Boiler 33 8.2 8.2 5.7 

Gas Turbines 87 22 22 230 

Architectural Surface Coating, 2005 

Alternative method one was chosen from the guidance document Emission Inventory 

Improvement Program (EIIP), Volume III, Area Sources Preferred and Alternative 

Methods, Chapter 3: Architectural Surface Coating. Data was readily available for the 

use of per capita emission factors. 

MDEQ, Air Quality Division staff determined per capita usage factors by dividing the 

2004 national total architectural surface quantities for solvent and water based coatings

(U.S. Census Bureau MA325F, Paint and Allied Products) by the U.S. population for 

2004 (U.S. Census Bureau, http://www.census.gov). 
36

http://www.census.gov/industry/1/ma325f04.pdf

http://www.census.gov/popest/national/files/NST_EST2005_ALLDATA.csv

Solvent-Based Paint 

Solvent-based paints produced and shipped in the U.S. in 2004, the most recent 

available year, were totaled (includes architectural lacquers and architectural coatings, 

n.s.k.). The resulting number was divided by the 2005 U.S. population to produce a per 

capita solvent-based paint usage factor of 0.5265 gallons per person. 

The resulting solvent paint use, in gallons per county, was multiplied by a VOC emission 

factor of 3.87 lb/gal, from Table 5-2 of the EIIP guidance, Volume III, Area Sources 

Preferred and Alternative Methods, Chapter 3: Architectural Surface Coating. This 

produced total VOC emissions from solvent-based paint. The VOC was then speciated 

for toxics, utilizing speciation factors from Table 5-4 from the EIIP guidance. Acetone, 

listed in the methodology prepared by the Great Lakes states, was removed because it 

is not a toxic. 

Water-Based Paint 

Water-based paints produced and shipped in the U.S. in 2004 were totaled. The 

resulting number was divided by the 2005 U.S. population to produce a per capita 

water-based paint usage factor of 2.2473 gallons per person. 

The resulting water-based paint use in gallons per county was multiplied by a VOC 

emission factor of 0.74 lb/gal, from Table 5-2 from the EIIP guidance, Volume III, Area 

Sources Preferred and Alternative Methods, Chapter 3: Architectural Surface Coating. 

This produced total VOC emissions from water-based paint. The VOC was speciated 

for toxics, utilizing speciation factors from Table 5-3 from the EIIP guidance.

No point source deductions were performed, as none were needed for this category. 

Autobody Refinishing in Michigan, 2005 

Alternate method 3 of the EIIP document, Volume III, Area Sources Preferred and 

Alternative Methods, Chapter 13: Auto Body Refinishing was followed by Michigan. 

National emissions for the category were allocated to the county level based on census 

data. 

79,429.59 tons of VOC were estimated nationally for this category based on 1997, 1998 

and 1999 data, as indicated within the GLC methodology. The estimate of national 

VOC emissions from autobody refinishing was divided by a 2005 national population 

estimate of 296,410,404 to produce a VOC emission factor of 0.54 lbs/person. 
37

Area source estimations were adjusted by deducting point source VOC emissions. 

A seasonal adjustment factor of 1.0 was made for this category for the ozone season. 

The category of auto refinishing was considered to be uniform throughout the year, per 

Table 5.8.1 of the EPA document Procedures for the Preparation of Emission 

Inventories for Carbon Monoxide and Precursors of Ozone, Volume I: General 

Guidance for Stationary Sources. Ozone season daily emissions were calculated per 

the example on page 5-23 of this document. Ozone season throughput was also 

calculated. 5 activity days per week were selected, per Table 5.8.1. Annually, 260 days 

of operation were assumed. NOx and CO emissions were not calculated, as this 

category is not considered a source of NOx or CO. 

References 

1. Emission Inventory Improvement Program, Volume 3, Chapter 13, Auto Body 

Refinishing, January 2000. 

2. Fire 6.23 database 

3. U.S. Census Bureau, Population Division. 2006. Population Estimates Program. 

Washington, DC 20233. 

4. Annual County Business Patterns data are available through U.S. census at 

http://www.census.gov/epcd/cbp/view/cbpview.html 

5. Section 3.8 of Procedures for the Preparation of Emission Inventories for Carbon 

Monoxide and Precursors of Ozone, Volume I (1991)

Estimating Emissions from Consumer and Commercial Solvent Use

The GLC methodology, a portion of which is included below, was based on the EIIP 

guidance document, Volume III, Area Sources Preferred and Alternative Methods, 

Chapter 5: Consumer and Commercial Solvent Use. Michigan used the EIIP and GLC 

guidance for the estimation of criteria and toxic pollutants for this category for 2005. 

Michigan chose to use the preferred method with per capita emission factors, adjusted 

for the federal VOC reduction rule as provided in Table 2 of the EIIP guidance. 
38

SCCs

The following SCCs were utilized by Michigan, per LADCO’s recommendations: 

2460100000 personal care 

products 

2460200000 household 

Products 

2460400000 automotive 

aftermarket 

2460600000 adhesives and 

sealants 

2460800000 FIFRA-regulated 

products 

2460500000 coatings and 

related products 

2460900000 miscellaneous 

products 

From GLC methodology: 

Overview

All quotes and information contained within are from the source, Emission Inventory 

Improvement Program, Volume 3, Chapter 5, Consumer and Commercial Solvent Use, 

August 1996. The consumer and commercial solvent source category includes a wide 

array of products including personal care products, household cleaning products and 

household pesticides. However, all VOC emitting products used by businesses, 

institutions and numerous industrial manufacturing operations are also included. A 

detailed list of products included in this category can be found on page 5.2-3 of the 

1996 EIIP document. The majority of VOCs introduced into the atmosphere from this 

category is a result of evaporation of the solvent contained in the product or from the 

propellant released during product use. 

Dry cleaning Area Source Emissions for Michigan, 2005 

Standard Industrial Classification (SIC) 7215 (coin-operated dry cleaning 

establishments) was not considered for this inventory. The AQD’s dry cleaning staff in 

the Technical Programs Unit indicated that virtually all coin-operated dry cleaning 

machines in Michigan have been discontinued due to the large cost of keeping them 

supplied with perchloroethylene (per Elden Dickinson, AQD). SIC 7216 (dry cleaning 

establishments, excluding coin-operated facilities) was considered instead. Under the 

North American Industrial Classification System (NAICS), SIC 7216 is known as NAICS 

812320. 
39

To calculate 2002 VOC emissions, Michigan utilized alternative method two, per 

employee emission factor. 2003 county employment data was obtained from the U.S. 

Census Bureau’s document, 2003 Michigan County Business Patterns. 2005 data was 

not available, and was not expected for some time. 

Dry cleaning has a uniform seasonal adjustment factor (1.0), remaining constant during 

the ozone season, per EPA’s Procedures for the Preparation of Emission Inventories for 

Carbon Monoxide and Precursors of Ozone, Volume I: General Guidance for Stationary 

Sources. 

2003 employment data, the latest from the U.S. Census Bureau’s County Business 

Patterns, was obtained for NAICS 812320, for each county where it was available. 

Where available, employment data for the broader category of NAICS 812 was also 

obtained. 

The next step was to determine a ratio between the number of employees under NAICS 

812320, and the number of employees under NAICS 812. For counties that had 

employment numbers for NAICS 812, this ratio was used to estimate how many of the 

employees would fall under the code 812320. 

The next task was to develop an employment number for those counties where 

drycleaner employment numbers were not available from the County Business Patterns. 

Using population numbers for those counties where employment data was available, a 

per capita number of dry cleaning employees was calculated. As certain counties have 

no perchloroethylene drycleaners (per lists of perc dry cleaners from Randy Johnson, 

AQD), values of zero were entered for those counties. 

Reports from Michigan’s 2005 point source emission inventory (the latest complete 

inventory) were reviewed to determine if any counties had point source employment for 

SIC 7216 (NAICS 812320). Berrien, Ingham and Jackson (NAICS 8123) counties did 

have point sources under SIC 7216, and the number of employees at each source was 

obtained from the emission inventory. Each source’s employment number was 

subtracted from the appropriate county’s employment number. 

Once estimates of employment for SIC 7216 were available for each county, an 

emission factor for VOC of 1,800 lb/yr/employee was obtained from Table 4.5-1 of EIIP 

Vol. III, Chapter 4. 
40

From EIIP 

Subcategory Reactive VOC 

(lb/year/employee

) 

Total Organics 

(lb/year/employee

) 

All solvents (total) 1,800 2,300 

Halogenated Solvents 

 PERC, TCA and CFC 

113 

 Coin Operated 

 Commercial/Industrial 

980 

52 

1,200 

Mineral Spirits and Other 

Unspecified Solvents 

1,800 1,800 

On a per-unit basis: 0.8 tons/facility-year (assumes that average coin-op facility has two 

dry cleaning units and each emits 0.4 tons of PERC per year). 

From AP-42 

 Commercial: 1.3 lb/year/person (all nonmethane VOC) 

 Coin Operated: 0.4 lb/year/person (all nonmethane VOC) 

A rule for perchloroethylene dry cleaning air emissions became effective late 1996 

(58FR49354. National Emission Standards for Hazardous Air Pollutants for Source 

Categories: Perchloro-ethylene Dry Cleaning Facilities. Final Rule. September 22, 

1993.). EPA estimates the rule reduces perchloroethylene emissions from dry cleaning 

operations by 44%. Depending on the methodology used to estimate air emissions 

from perchloroethylene dry cleaning operations the effectiveness of this rule may need 

to be factored into the calculation. 

References: 

U.S. Census Bureau, 2003 Michigan County Business Patterns 

Emission Inventory Improvement Program Vol. III, Area Sources: Preferred and 

Alternative Methods, Chapter 4, Dry cleaning. May 1996. 

Elden Dickinson, Dry Cleaning Unit, Drinking Water and Radiological Protection 

Division, Michigan DEQ. Personal communication, 5/07/01. 

US EPA. Procedures for the Preparation of Emission Inventories for Carbon Monoxide 

and Precursors of Ozone, Volume I: General Guidance for Stationary Sources. May 

1991. EPA –450/4-91-016. 
41

Graphic Arts Criteria and Toxics, 2005 

The EIIP area source guidance document, dated November 18, 1996, was followed. 

The EIIP preferred method was not utilized, as it required a survey of facilities. 

Alternative Method 1, ink sales emission factor method, was found to be not feasible for 

Michigan, as (during calculation of the 1999 inventory) point sources used more ink than 

the state proportion of national ink production was calculated to be. 

Per Alternative Method 2, the population of the inventory region was obtained from state 

data for 2005, and multiplied by the per capita emission factor provided in the EIIP 

guidance. This produced total uncontrolled emissions from all graphic arts facilities with 

less than 100 tons per year of VOC emissions, for the entire state. This method used a 

1991 EPA emission factor of 0.00065 tons VOC per capita. 

Total uncontrolled VOC emissions from area source graphic arts facilities (those with 

less than 100 tons per year of VOC emissions) was then estimated for each county. 

This was done by obtaining uncontrolled VOC emissions from point sources with less 

than 100 tons per year of VOC, from the 2005 EI. SICs 2711, 2721, 2752 and 2754 

(NAICS 51111, 511112, 323114, and 323111) were the SIC codes queried. This 

number was then subtracted from total uncontrolled emissions from graphic arts 

facilities, on a county by county basis. The remaining number is the area source VOC 

emissions per year. 

Solvent Cleaning 2005 (criteria) 

In this category, the use of solvents is broken into two broad classifications. The 

classifications are solvent cleaning (which is composed of cold cleaning and vapor/inline cleaning), and solvent cleanup (predominantly wipe cleaning of external surfaces). 

EIIP Alternative Method 

Solvent Cleaning Equipment (both Cold Cleaners and Vapor/In-line Cleaners):

Emission factors: 

EIIP Table 6.5-2 provides per capita and per employee emission factors, as reproduced 

below. 

Recommended Method for Solvent Cleaning Equipment

Michigan chose to use the per employment factors available in Table 6.5-2 from 

Procedures for the Preparation of Emission Inventories for Carbon Monoxide and 

Precursors of Ozone: Volume I: General Guidance for Stationary Sources (EPA, 1991), 

for the 2005 emissions inventory. Employee data was obtained from the U.S. Bureau 
42

of the Census document, County Business Patterns, Michigan: 2003, which was the 

most recent version at the time the category was estimated. Area source emissions 

were then determined by subtracting point source emissions from total emissions. 

When the result was a negative number, area source emissions were set to zero. 

The following SCCs, per email from Grant Hetherington, WI DNR on 9/19/05, were 

utilized for reporting the emissions to be consistent with the other LADCO states: 

2415360000 - Auto Repair Services (SIC 75): Cold Cleaning 

2415345000 - Miscellaneous Manufacturing (SIC 39): Cold Cleaning 

2415245000 - Miscellaneous Manufacturing (SIC 39): Conveyerized Degreasing 

241523000 - Electronic and Other Elec. (SIC 36): Conveyerized Degreasing 
43

Table 6.5-2: Per Capita and Per Employee Solvent Cleaning Emission Factors 

(EPA, 1991) 

Per Capita 

Factor 

Per Employee 

Factor 

(lb/yr/person) (lb/yr/person) 

Subcategory SIC Codes VOCs Organic

s 

VOCs Organic

s 

Solvent 

cleaning 

25, 33-39, 

417 

4.3 7.2 87 144 

(total) 423, 551, 

552, 

554-556, 

753 

Cold Cleaning 

Automobile 

Repair 

417, 423, 

551, 

2.5 2.5 270 270 

552, 554-

556, 

753 

Manufacturing 25, 33-39 1.1 1.1 24 24 

Vapor and In-Line Cleaning

Electronics and 36 0.21 1.1 29 150 

Electrical 

Other 25, 33-39, 

417, 

0.49 25 9.8 49 

423, 551, 

552, 

554-556, 

753 

2005 point source employment data was obtained from MAERS. These values were 

then deducted from the total emissions estimated by using the per capita emission 

factor and 2005 Michigan county population data. 

References 

EPA. Procedures for the Preparation of Emission Inventories for Carbon Monoxide and 

Precursors of Ozone: Volume I: General Guidance for Stationary Sources (May 1991). 

EPA. STAPPA-ALAPCO-EPA Emission Inventory Improvement Program (EIIP). 

Volume III - Area Sources Preferred and Alternative Methods. Chapter 6, Solvent 

Cleaning. September 1997. 
44

US Department of Commerce, Bureau of the Census. County Business Patterns, 

Michigan: 2003. September 2005. 

Industrial Surface Coatings, Toxics, 2005 

The GLC methodology was followed by Michigan for estimating toxics for 2005. The 

GLC methodology is based on EIIP, Volume III, Area Sources Preferred and Alternative 

Methods, Chapter 8: Industrial Surface Coating. In most cases alternative method one, 

default per employee factors, were used, except for SCCs where the per employeebased emission factors yielded unrealistically high values of pollutants. The MDEQ, Air 

Quality Division staff believe that the point source employee deductions performed for 

each affected SCC (based on NAICS information from U.S. Census Bureau’s County 

Business Patterns, and the Air Quality Division’s point source inventory) do not account 

for all of the point source employees, resulting in the high values. 

For the SCCs 2401050000 (miscellaneous finished metal) and 2401070000 (motor 

vehicles), it was decided that per capita based emission estimates would be utilized 

instead of the per employment based methods which yielded large values of 486 million 

lbs VOC (935 tons per summer weekday) and 57 million lbs VOC, respectively. The per 

capita methods yielded more realistic numbers of 4.6 million and 10.9 million lbs VOC. 

For the SCC 2401020000 (furniture and fixtures), the employment based method 

resulted in an estimate of 31 million lbs (60 tons per summer weekday). The per capita 

method resulted in an estimate of 20 million lbs. As the estimates for 2401020000 

appeared unrealistically large with either method, this category was omitted from the 

inventory. 

Total area source VOC emissions for industrial surface coating for 2005 were 

approximately 50 million lbs. 

From the GLC methodology: 

Source Identification

Searching through the Standard Industrial Classification Code List (SIC), the 

North American Industry Classification System (NAICS), through the Factor 

Information Retrieval System (FIRE 6.23) and table 8.5-1 of the Volume III 

Chapter 8 Industrial Surface Coating September 1997 publication of EPA, the 

following codes were identified for each of the fifteen industrial surface coating 

category. 

Factory Finished Wood - A2401015000

SIC 2426-2429, 243-245, 2492, 2499 

NAICS 321113, 321912, 32192, 321911, 321918, 33711, 321212, 321214, 

321213, 321991, 321992, 33999, 333414, 321999, 321211 
45

Wood Furniture - A2401020000

SIC 25 

NAICS 337122, 337121, 337124, 337214, 33791, 337129, 337125, 337211, 

33636, 339942, 

337127, 337212, 337215, 33792, 

Metal Cans - A2401040000

SIC 3411 

NAICS 332431 

Misc Finished Metals - 240105000

SIC 34xx(exclude 341 and 3498) 

NAICS 332211, 332212, 332213, 332999, 332722, 332117, 332912, 332611, 

332998, 332913, 332439, 33251, 332919, 332312, 322225, 332618, 332321, 

332313, 33242, 332612, 332322, 332311, 339911, 333924, 332114, 332721, 

332994, 334518, 332111, 332112, 33637, 332115, 332116, 332214, 332813, 

339914, 339912, 332812, 332992, 332993, 332995, 332911 

Machinery and Equipment - A2401055000

SIC 35 

NAICS 333611, 333618, 333111, 332323, 333312, 333112, 33312, 333131, 

336311, 333995 

333132, 333921, 333922, 333923, 333924, 333513, 332997, 333514, 333511, 

333515, 333516, 333992, 333518, 333292, 33321, 333291, 333293, 333294, 

33322, 33241, 333295, 333911, 332991, 333912, 333411, 333993, 333612, 

333994, 333613, 314999, 334418, 333996, 333997, 33271, 333999, 334119, 

334518, 333512, 333991, 333412, 336391, 333415, 333913, 

Large Appliances - A240106000

SIC 363 

NAICS 335221, 335222, 335224, 335211, 339999, 333414, 335212, 333298, 

335228, 

Electronic and Other Electrical - 2401065000

SIC 36,123,357 

NAICS 334111, 334112, 334113, 33422, 334418, 334613, 333992, 335129, 

333311, 333313, 339942, 51222, 335311, 335313, 335312, 335991, 335314, 

335999, 33511, 335931, 335932, 335121, 335122, 334613, 336321, 335129, 

33431, 334612, 334419, 335911, 335912, 333319, 

334411, 334412, 334414, 336322, 334415, 334416, 334417, 333618, 33429, 

33421, 

Motor Vehicles - 240107000

SIC 3711 
46

NAICS 33611, 336112, 33612, 336211 

Other Transportation Coatings - 2401075000

SIC 37(not 3711,373) 

NAICS 336213, 336312, 336322, 33633, 33634, 33635, 336399, 336212, 

336415, 336411, 336412, 54171, 332912, 336999, 336413, 333911, 333924, 

33651, 336991, 336414, 336419, 336214, 336992 

Marine Coatings - 240108000

SIC 373 

NAICS 48839, 336611, 336612, 81149 

Misc. Product Coatings Manufacturing - 240109000

SIC

NAICS 339 

Industrial High Performance Maintenance Coatings- 2401100000

SIC

NAICS 811 

Other Special Purpose Coatings - 2401200000 

SIC 

NAICS

VOC factors from Table 8.5-1 of the EIIP guidance were applied to employment 

estimates based on the U.S. Bureau of the Census document, County Business 

Patterns: Michigan, 2003, which was the most recent data available at the time 

the estimates were created. 

References

EPA. STAPPA-ALAPCO-EPA Emission Inventory Improvement Program (EIIP). 

Volume III: Chapter 8 Industrial Surface Coating September 1997. 

U. S. Census web site http://www.census.gov/ 
47

Open Burning: Municipal Solid Waste, 2005 Criteria Pollutants 

For the category of open burning of municipal solid waste (MSW), EPA’s methodology 

from Appendix A of Documentation for the Final 2002 Nonpoint Sector (Feb 06 Version) 

National Emission Inventory for Criteria and Hazardous Air Pollutants was followed. 

The ratio of urban to rural population was obtained from 2000 U.S. Census data, per the 

EPA’s method, then multiplied by a 2005 U.S. Census Bureau estimate of the county 

population in Michigan to obtain an estimate of rural population in 2005. Per capita 

emission factors were used, after first excluding those counties where the population 

was greater than 80% urban under EPA’s presumption that open burning of MSW would 

not occur there. 

Outdoor Wood Boilers, 2005 criteria pollutant estimates 

The Wisconsin methodology distributed by Bart Sponseller was followed. Per that 

methodology, the MARAMA emission factor of 13.82 g/kg wood burned was used. 

An estimate of 11.68 cords/yr/unit in Michigan was obtained from Brian Brady, MDEQ 

Air Quality Division. Brian serves as the MDEQ, Air Quality Division’s outdoor wood 

boiler expert. 

Michigan estimated an average weighted density of 1.65 tons/cord of wood, based on 

information contained within Table 8 of the USDA survey report “Residential Fuelwood 

Consumption and Production in Michigan, 1992.” 

Per the Wisconsin methodology, it was assumed that 90% of outdoor wood boilers are 

used in rural areas and 10% are used in urban areas. To determine which counties 

were urban and which were rural, staff reviewed the list of counties, which are part of 

Michigan’s Consolidated Statistical Areas (metropolitan areas) and determined that the 

22 affected counties should be considered as urban. Ten percent of the 29,568 

Michigan outdoor wood boilers were apportioned to the urban counties by population. 

The remaining 90% of the outdoor wood boilers were apportioned to the 61 rural 

counties by population. 

Residential Wood Burning, 2005

Michigan utilized the EIIP methodology’s alternative method for estimating emissions 

from residential woodburning, by apportioning data from the U.S. Census Bureau and 

the EIA. 

Two options were available to estimate woodburning households per county. 
48

• Housing Units with Wood Heat by County was determined by using 1990 U.S. 

Census Data, Database C90STF3C1, Summary Level State, for House Heating 

Fuel for Occupied Housing Units (http://venus.census.gov/cdrom/lookup). 

Although this data is for the 1990 year, it did provide a value for each county. 

• Housing Units with Wood Heat by County was determined by using the U.S. 

Census Bureau’s DP-4, Profile of Selected Housing Characteristics: 2000, Data 

Set: Census 2000 Summary File 3 (SF 3) for Michigan. This file provided a total

value of households using wood heating. However, no breakdown was given by 

county. 

The MDEQ, Air Quality Division staff used the 2000 number of total wood burning 

households in Michigan, and used the 1990 county proportions of the 1990 total to 

apportion the 2000 value to the county level. 

Then, based on county value for number of wood burning households, the value for 

state wood use in cords was apportioned to each county. The 2003 state wood use in 

cords data came from the US 
49

MAP States Page, Table 8, Residential Energy Consumption Estimates, Selected Years 

1960-2003, Michigan, from the U.S. Department of Energy, EIA: 

http://www.eia.doe.gov/emeu/states/sep_use/res/use_res_mi.html

Data for 2005 was not yet available. 

Once county wood use in cords was produced, the next step was to determine the wood 

weight in tons for each county. Wood weight was determined by estimating a weighted 

average wood weight of 1.65 tons per cord, from species and consumption data from 

Table 8 of the USDA report, “Residential Fuelwood Consumption and Production in 

Michigan, 1992.” 

Michigan did not have data available on the number of catalytic and non-catalytic 

woodstoves in Michigan, but did utilize 1993 survey data which showed the proportions 

of fireplaces to woodstoves by county in Michigan. This was used to apportion wood 

weight per county between wood stoves and fireplaces. SCCs and emission factors 

were selected for fireplaces – cordwood (2104008001), and woodstoves – general 

(2104008010). 

No ozone season activity was estimated, as staff felt it was unlikely that residents would 

utilize their fireplaces or wood stoves between June 1 and August 31 of each year. 

FIRE 6.23 (Factor Information Retrieval System Version 6.23) and Source Summary 

Database (SSD) list the following Area Mobile Source Codes (AMS): 

 A2104008000: Total wood stoves and fireplaces 

 A2104008001: (lb/ton dry wood burned): Fireplaces - general 

 A2104008010: (mg/Mg dry wood burned): Wood stoves - general 

 A2104008030: (lb/ton dry wood burned): Catalytic wood stoves - general 

 A2104008050: (lb/ton dry wood burned): Non-catalytic wood stoves - general 

 A2104008051: (lb/ton dry wood burned): Non-catalytic wood stoves - 

conventional 

 A2104008052: (lb/ton dry wood burned): Non-catalytic wood stoves - low emitting 

 A2104008053: (lb/ton dry wood burned): Non-catalytic wood stoves - pellet fired 

Michigan selected AMS codes A2104008001 and A2104008010. These were the most 

appropriate codes, as data exists for the proportion of woodstoves to fireplaces per 

county in Michigan, but data was not available on numbers of catalytic or non-catalytic 

wood stoves. Emission factors for A2104008010 were converted from mg/Mg to lb/ton 

by multiplying by the conversion factor of 2.00E-06. 
50

References 

1. USEPA, “Factor Information Retrieval System Version 6.23”, U.S. Environmental 

Protection Agency, 2000. 

2. EPA, STAPPA, ALAPCO, Emission Inventory Improvement Program (EIIP), Volume 

III, July 1997, Chapter 2. 

Structure Fires, 2005 Criteria Emissions 

The EIIP guidance from EIIP Volume III, Chapter 18: Structure Fires, was followed. The 

preferred method for estimating emissions was used, due to the availability of county 

level structure fire data for 2002. More recent data was not available; the fire statistics 

data, which was originally kept by the Michigan State Police Fire Marshall Division, is 

now kept by the Michigan Department of Labor and Economic Growth. DLEG staff 

were unable to locate more recent county level data on structure fires. The 2002 data 

was re-used from the 2002 area source submittal. However, it did not provide any detail 

on the extent of each structure fire, or indicate if the structure was residential or 

commercial. 

The default fuel loading factor provided in the EIIP guidance (1.15 tons of fuel per 

structure fire) was used. Emission factors for VOC, CO, and NOx were obtained from 

Table 18.4-1. 

Year 2009 Stationary Area Source Emission Inventory Projections: 

See Growing Stationary Non-EGU Point, Stationary Area, Locomotive, Shipping, 

and Aircraft Categories for the Years 2009 in the Non-EGU Point Sources section

for reference and methodology for projecting the Stationary Area Source inventory. 

5. Non-Road Mobile 

Non-Road Emissions Estimation exclusive of Locomotive, Shipping, and Aircraft 

Emissions 

Non-road emission estimates for 2005 and 2009 were obtained from the EPA’s National 

Mobile Inventory Model (NMIM). The model uses a database to store the information 

about individual counties, referred to as the NMIM County Database (NCD); the current 

version is NCD20051207. 
51

Recent updates to the model were made by the EPA and can be found at: 

www.epa.gov/omswww/models/nonrdmdl/nonrdmdl2005/readme.htm, (NONROAD2005 Update Chronology). 

One of the updates included in this modeling was a correction in the NON-ROAD.EXE 

file that includes modifications for permeation. Changes were also made in the external 

files (15 files) to incorporate recommendations of SEMCOG and LADCO consultants 

regarding fuel data. Program files for emissions and population data were modified. 

These changes were made to improve the accuracy of the model estimates and to 

produce emission values that will be consistent with those that will be used for future 

ozone and fine particulate SIP demonstrations. 

The Non-road emissions estimates were prepared by Wisconsin for all LADCO States, 

including Michigan. Additional details on the procedures used to prepare these 

inventory products can be found in the “Regional Air Quality Analyses for Ozone, PM2.5, 

and Regional Haze: Technical Support Document” prepared by LADCO. 

2005 Aircraft Emissions Estimation 

In order to estimate aircraft emissions, aircraft activity was obtained for Michigan 

airports. Historically this information was obtained from MDOT. However MDOT was 

unable to provide updated information for year 2005. In the absence of updated MDOT 

2005 aircraft activity data, commercial aircraft and commercial air freight departure 

information by aircraft model type was obtained from FAA airport records. For 

determining airport LTO cycles, the Air Traffic Activity Data System (ATADS) air traffic 

count database of larger towered airports, Terminal Area Forecast (TAF) air traffic 

operations database of towered and non-towered airports, and G.C.R. & Associates 

airport activity data were used. Since ATADS provides aircraft operations for a limited 

number of the States’ airports, TAF aircraft operations estimates were considered 

where ATADS information was unavailable. G.C.R. & Associates, Inc. consultant data 

was used for the smaller airports of which FAA aircraft operations information was 

unavailable. The following information from the respective sources was considered in 

the development of emission estimates: 

 1. Commercial scheduled and non-scheduled aircraft air carrier activity and 

commercial air freight activity by aircraft model types, 

 2. General aviation and air taxi annual local and itinerant operations for year 

2005, 

 3. Military annual local and itinerant operations for year 2005. Due to need 

to have aircraft operations information expressed as LTO cycles, the 

following assumptions were made: 
52

a. For commercial aircraft and commercial air freight activity, the number of 

annual aircraft annual LTO cycles was assumed to be equal to the number 

of departures. The daily LTO cycle frequency was then obtained by 

dividing the yearly LTO cycles by 365. 

b. For general aircraft annual local and itinerant airport operations, each 

respective operations total was divided by two to obtain the corresponding 

year local and itinerant LTO cycles. The expected daily local and itinerant 

LTO cycles then were obtained by dividing these annual totals by 365. 

c. For military annual local and itinerant operations, each respective 

operations total was divided by two to obtain the corresponding year local 

and itinerant LTO cycles. The expected military daily local and itinerant 

LTO cycles then were obtained by dividing these annual totals by 365. 

Airport LTO cycles were further categorized into commercial aircraft by plane and 

engine type, general aviation itinerant aircraft of unknown aircraft type, general aviation 

local aircraft of unknown aircraft type, and military aircraft. This was necessary in order 

to utilize the U.S. Department of Transportation, FAA EDMS 4.5 Emissions and 

Dispersion Modeling System. A description of this model can be found in the FAA 

publication entitled: Emissions and Dispersion Modeling System (EDMS) User Manual 

(September 2004). Commercial and air freight aircraft emission factors per LTO cycle 

were determined using EDMS 4.5 for each commercial aircraft type models where 

possible were used at each towered airport. Default commercial aircraft engine type, 

and EPA default time in mode values for takeoff, approach, and landing roll times were 

used in the EDMS 4.5 model simulations. 

For those aircraft types that could not be determined using the EDMS 4.5 emissions 

model, aircraft emission factors based upon EPA alternative fleet average procedures 

were then used to estimate their emissions. These included general aviation and air 

taxi itinerant aircraft of unknown aircraft type, general aviation local aircraft of unknown 

aircraft type, and military aircraft. Conversion from total hydrocarbons to VOC was 

performed and based upon the EPA guidance. 

Aircraft emissions were then obtained by adding emissions contributions from 

commercial, itinerant general, and local general aircraft, and were reported using the 

following SCC codes. 
53

Michigan Aircraft Emission SCC Codes 

Aircraft Type SCC 

Military 2275001000 

Commercial 2275020000 

General Aviation 2275050000 

2005 Locomotive and Shipping Emissions Estimation 

The 2005 non-road shipping and Locomotive emissions were prepared using the same 

techniques used for the 2002 emissions. These estimates are based on work and a 

follow-up report (Environ Report for LADCO, April 2004, 2002 Shipping Emissions 

Sources) completed by Environ to support LADCO’s efforts to prepare a 2002 Air 

Emissions Inventory. The report describes Environ efforts to develop a shipping 2002 

air emissions estimates to support air quality modeling. The Environ report is too long to 

be included in this document, but it can be provided upon request or downloaded at: 

http://ladco.org/reports/rpo/MWRPOprojects/Emissions/Environ_Final_Report_nonroad.pdf 

The estimate of 2005 locomotive and shipping emissions was made by LADCO in the 

same manner as the 2002 inventory described above. The 2005 estimates are part of 

LADCO’s base M inventory. 

Non-Road Mobile Source Emission Inventory Projections to 2009

The non-road source categories exclusive of locomotive, shipping, and aircraft were 

grown in the EPA Mobile source model NMIM. The locomotive, shipping, and aircraft 

non-NMIM source categories were grown using growth factors provided in the report 

(E.H. Pechan & Associates, Inc., Development of Growth and Control Factors for Lake 

Michigan Air Directors Consortium, Final Report, December 14, 2004) done by E.H. 

Pechan & Associates, Inc. for LADCO and available upon request. 

See Growing Stationary Non-EGU Point, Stationary Area, Locomotive, Shipping, 

and Aircraft Categories for the Years 2009 in the Non-EGU Point Sources section

for references and methodology for projecting the Locomotive, Shipping and Aircraft 

emissions inventory. 
54

6. On-Road Mobile

For the 2005 base year, the emissions model CONCEPT was run by a LADCO 

contractor (Environ) using transportation data (e.g., VMT and vehicle speeds) supplied 

by the state (MDOT) and local planning agencies (SEMCOG) in the LADCO States and 

Minnesota for 24 networks. These data were first processed with T3 (Travel Demand 

Modeling [TDM] Transformation Tool) to provide input files for CONCEPT to calculate 

link specific, hourly emission estimates. CONCEPT was run with meteorological data for 

a July and January weekday, Saturday, and Sunday (July 15 – 17 and January 16 – 

18). The mobile emissions derived from the SEMCOG network, which include all the 

Michigan nonattainment counties, are detailed in Appendix D. 

Similar to the base year modeling, CONCEPT was run using transportation data (e.g., 

VMT and vehicle speeds) supplied by the state and local planning agencies for 2009 

and 2018. CONCEPT was only run with meteorological data for a weekday. The 

emissions for Saturday and Sunday were derived by using scaling factors based on the 

2005 emissions. 

Additional details on the procedures used to prepare these inventory products can be 

found in the “Regional Air Quality Analyses for Ozone, PM2.5, and Regional Haze: 

Technical Support Document” prepared by LADCO. 

7. Area Source Ammonia and Biogenic Emissions

Ammonia Emissions 

LADCO estimated area source ammonia emissions for all member states, including 

Michigan. The CMU-based 2002 (Base K) ammonia emissions were projected to 2005 

using growth factors from the Round 4 emissions modeling. These emissions were then 

adjusted by applying temporal factors by month based on the process-based ammonia 

emissions model. 

Biogenic Emissions 

A LADCO contractor (Alpine) provided an updated version of the CONCEPT/MEGAN4 

(Model of Emissions of Gases and Aerosols from Nature) biogenics model, which was 

used to produce 2005 base year biogenic emission estimates. Model improvements 

included: (a) reduced model run times, (b) improved ability to run successive days, and 

(c) enhanced meteorological input processing5. 

Compared to the previous (EMS/BIOME) emissions, there is more regional isoprene 

using MEGAN compared to the BIOME estimates used for Base K. Also, with the 
55

secondary organic aerosol updates to the CAMx air quality model, Base M includes 

emissions for monoterpenes and sesquiterpenes, which are pre-cursors of secondary 

PM2.5 organic carbon mass. 

Additional details on the procedures used to prepare these inventory products can be 

found in the “Regional Air Quality Analyses for Ozone, PM2.5, and Regional Haze: 

Technical Support Document” prepared by LADCO. 
Appendix D 

MOBILE EMISSIONS 

USED FOR THE CONFORMITY BUDGET 

SUPPORT DOCUMENTATION 

FOR THE 

FINE PARTICULATE SIP 

January 2008 

 1 
Southeast Michigan On-Road Mobile Source 

Emissions Inventory 

Developed for the 2008 PM2.5 State Implementation Plan Submittal 

January 28, 2008 

Prepared by the 

Southeast Michigan Council of Governments (SEMCOG) 

535 Griswold, Suite 300 

Detroit, MI 48226 

(313) 961-4266 

 2 
Table of Contents

I. Overview of On-Road Mobile Modeling Process..................................................... 3 

II. Modeling Inputs and Assumptions .......................................................................... 3 

A. Mobile6 Input Parameters.................................................................................. 3 

B. Vehicle Miles of Travel (VMT) Estimation & Emissions Calculation................... 6 

III. Resulting On-Road Mobile Source Emissions Inventory ....................................... 14 

List of Tables 

Table 1: Minimum and Maximum Daily Temperatures Used in Mobile6......................... 4 

Table 2: Oxygenated Fuel Inputs Used in Mobile6......................................................... 5 

Table 3: Age Distribution of Southeast Michigan Fleet................................................... 6 

Table 4: Average Annual Daily Travel Adjustment Factors ............................................ 7 

Table 5: HPMS Normalization Factors ........................................................................... 7 

Table 6: VMT Seasonal Adjustment Factors .................................................................. 8 

Table 7: Southeast Michigan VMT Vehicle Mix Factors for Typical Weekday................ 9 

Table 8: Vehicle Class Conversion Process: FHWA to Mobile6................................... 11 

Table 9: Time of Day & Directional Split Factors for Typical Weekday......................... 12 

Table 10: 2002 On-Road Mobile Source Emissions..................................................... 14 

Table 11: 2005 On-Road Mobile Source Emissions..................................................... 15 

Table 12: 2009 On-Road Mobile Source Emissions..................................................... 15 

Table 13: 2018 On-Road Mobile Source Emissions..................................................... 15 

 3 
Southeast Michigan 

PM2.5 On-Road Mobile Source Emissions Inventory 

Developed for the 2008 PM2.5 State Implementation Plan

The Southeast Michigan Council of Governments (SEMCOG) is the Metropolitan 

Planning Organization (MPO) and lead local air quality planning agency for a sevencounty region that comprises Southeast Michigan’s PM2.5 nonattainment area 

(Livingston, Macomb, Monroe, Oakland, Washtenaw, and Wayne counties). Under an 

agreement with the State of Michigan, SEMCOG is responsible for developing the onroad mobile source emissions inventories for this region. 

This document provides detailed information on the air quality emissions modeling 

process used by SEMCOG to develop the on-road mobile source emissions inventory 

for the Southeast Michigan PM2.5 State Implementation Plan (SIP). 

I. Overview of On-Road Mobile Modeling Process 

The general process for developing on-road mobile source emissions inventories 

involves applying emission factors to estimates of vehicle miles of travel (VMT) within 

the Southeast Michigan nonattainment area. The emission factors are generated by the 

U.S. Environmental Protection Agency’s (EPA) Mobile6 model. The VMT is estimated 

using SEMCOG’s Travel Demand Forecast Model. Actual emissions calculation is done 

using a post-processing model, developed by SEMCOG. The post-processor multiplies 

the travel model VMT by the appropriate Mobile6 emission to calculate link-level 

emissions of volatile organic compounds (VOC), carbon monoxide (CO), nitrogen 

oxides (NOx), fine particulate (PM2.5), sulfur dioxide (SO2), and ammonia (NH3). 

Emission inventories were developed for four different analysis years: 2002, 2005, 2009 

and 2018. In keeping with EPA guidance on the preparation of annual inventories, the 

analysis involved the development of seasonal inventories that were then summed to 

create an annual inventory for each analysis year. 

II. Modeling Inputs and Assumptions 

The following paragraphs explain the various model inputs and assumptions used to 

create the emissions inventories. 

A. Mobile6.2 Input Parameters 

As required by the U.S. Environmental Protection Agency (EPA), the inventory was 

developed using emission rates generated by EPA’s Mobile6.2 emission factor 

model. It also used the updated PM rate table for heavy-duty vehicles, which EPA 

released on March 17, 2006. This rate table corrects an over estimation of PM10 and 

PM2.5 heavy-duty vehicle emissions by the previous version of the model for years 

2007 and beyond. 

The Mobile6.2 model allows for input of certain localized data in order to provide 

better emissions estimates for a given region. Six localized data inputs were used in 

SEMCOG’s analysis: 

 4 
• Minimum & Maximum Daily Temperatures: Table 1 shows the temperatures 

used to simulate an average day in each of the four seasons. The values were 

derived from National Weather Service local climatological data reports, provided 

by the Michigan Department of Environmental Quality (MDEQ). 2002 values 

were calculated by averaging the monthly minimum and maximum temperatures 

between 2001 and 2003. Values for years 2005 through 2018, used the average 

monthly minimum and maximum temperatures observed between 2004 and 

2006. 

Table 1 

Minimum and Maximum Daily Temperatures 

Used in Mobile6 

Season 

Winter Spring Summer Fall Analysis 

Year 

Min Max Min Max Min Max Min Max 

2002 22.8 35.6 38.1 56.8 62.5 81.9 44.6 61.8 

2005-2018 22.3 35.2 39.8 58.7 62.8 81.7 45.1 62.6 

• Reid Vapor Pressure (RVP): Mobile6 summer runs for years 2002 and 2005 

used an RVP of 7.8 pounds per square inch (psi), which was the maximum level 

allowed by law in Southeast Michigan during the summer months until 2007. In 

2007, a new law went into affect, requiring 7.0 psi vapor pressure gasoline 

between June 1st and September 15th of each year. Thus, an RVP of 7.0 was 

used for summer runs in years 2009 and 2018. 

For the other three seasons, 2002 fuel sample data, obtained from the Michigan 

Department of Agriculture, were used to compute the average RVP for each 

season in each year. The averages were 12.3 psi for winter, 11.1 psi for spring, 

and 10.7 psi for fall. These values were used for all analysis years. 

• Gasoline Sulfur Values: The 2002 values were derived from Alliance of 

Automobile Manufacturers North American Fuel Survey data for Wayne County, 

Michigan. The summer value was 439 ppm. The value for the other three 

seasons was 424 ppm. As new gasoline sulfur standards should be phased-in 

by 2009 in Midwest states, the Mobile6 default value of 30 ppm was used for all 

seasons in years 2009 and 2018. 

• Diesel Sulfur Values: As with gasoline, the 2002 diesel sulfur level was derived 

from the 2002 Alliance of Automobile Manufacturers fuel survey. This value was 

380 ppm. As data on seasonal variation was not available, the same value was 

used for all 2002 runs. For future years, the new diesel sulfur standard of 15 

ppm, which begins phasing in during 2006, was used. A value of 106.3 was used 

for 2005, which was derived through linear interpolation of the 2002 and 2006 

values. 

 5 
• Oxygenated Fuels Inputs: In addition to providing the local gasoline sulfur 

values, the 2002 North American Fuel Survey data showed that approximately 

25% of the fuel sold in Southeast Michigan contained an oxygenate. The vast 

majority of this oxygenate was ethanol. A small fraction was MTBE. The 

observed values from the fuel survey were used in SEMCOG’s 2002 base year 

modeling. For 2005 and all future years, SEMCOG assumed that oxygenate 

would continue to be present in 25% of the region’s gasoline. However, as use 

of MTBE was banned in Michigan in 2003, it was assumed that all of the 

oxygenate in these years would be ethanol. Table 6 shows the specific 

oxygenate inputs used in Mobile6. 

Table 2 

Oxygenated Fuel Inputs Used in Mobile6 

Year Oxygenate % Market Share % Weight 

Ethanol 20.7 3.2 2002 MTBE 3.5 1.9 

2005 - Ethanol 25.0 3.2 

2018 MTBE 0.0 0.0 

• Age Distribution of Vehicle Fleet: Table 3 shows the vehicle fleet age 

distribution data used in Mobile6. The light-duty distribution was developed by 

the Lake Michigan Air Directors Consortium (LADCO), using 2004 vehicle 

registration data for Southeast Michigan. The heavy-duty distribution was 

developed from national data, using EPA guidance. 

 6 
Table 3 

Age Distribution of Southeast Michigan Fleet 

Vehicle Class Vehicle 

Age 

(Years) Light Duty 

Vehicle 

Light Duty 

Truck 1 

Light Duty 

Truck 2 

Light Duty 

Truck 3 

Light Duty 

Truck 4 

Heavy Duty 

Truck 

Heavy 

Duty Bus Motorcycle

1 0.0919 0.1267 0.1563 0.1325 0.1375 0.031 0.029 0.017 

2 0.1225 0.1689 0.2084 0.1767 0.1833 0.082 0.078 0.098 

3 0.1262 0.1740 0.2147 0.1820 0.1888 0.068 0.065 0.088 

4 0.0866 0.0421 0.1114 0.0940 0.1255 0.077 0.074 0.071 

5 0.0438 0.0207 0.0500 0.0383 0.0567 0.065 0.062 0.072 

6 0.0452 0.0155 0.0455 0.0500 0.0757 0.082 0.097 0.063 

7 0.0359 0.0166 0.0370 0.0256 0.0429 0.062 0.069 0.052 

8 0.0345 0.0123 0.0278 0.0233 0.0351 0.047 0.059 0.040 

9 0.0337 0.0210 0.0225 0.0228 0.0256 0.037 0.044 0.027 

10 0.0419 0.0260 0.0217 0.0300 0.0252 0.036 0.046 0.020 

11 0.0401 0.0391 0.0213 0.0296 0.0289 0.042 0.051 0.020 

12 0.0409 0.0357 0.0204 0.0248 0.0087 0.048 0.053 0.432 

13 0.0390 0.0290 0.0160 0.0227 0.0115 0.045 0.048 0.000 

14 0.0374 0.0435 0.0112 0.0175 0.0041 0.041 0.046 0.000 

15 0.0351 0.0390 0.0080 0.0208 0.0069 0.038 0.042 0.000 

16 0.0338 0.0426 0.0075 0.0228 0.0045 0.031 0.034 0.000 

17 0.0270 0.0322 0.0084 0.0179 0.0050 0.026 0.028 0.000 

18 0.0194 0.0354 0.0022 0.0140 0.0037 0.014 0.013 0.000 

19 0.0174 0.0279 0.0026 0.0132 0.0071 0.010 0.011 0.000 

20 0.0133 0.0201 0.0019 0.0101 0.0056 0.010 0.010 0.000 

21 0.0094 0.0115 0.0018 0.0075 0.0028 0.010 0.007 0.000 

22 0.0049 0.0054 0.0011 0.0040 0.0016 0.018 0.008 0.000 

23 0.0027 0.0041 0.0005 0.0021 0.0007 0.017 0.007 0.000 

24 0.0026 0.0030 0.0004 0.0012 0.0002 0.014 0.005 0.000 

25+ 0.0148 0.0078 0.0016 0.0168 0.0125 0.049 0.015 0.000 

B. Vehicle Miles of Travel (VMT) Estimation & Emissions Calculation 

• Demographic Data: Travel forecasts used in the conformity analysis are based 

on demographic data from SEMCOG’s 2030 Regional Development Forecast 

(RDF), which was published in 2001. 

• Description of SEMCOG’s travel forecasting model: VMT forecasts for the 

conformity analysis were developed using SEMCOG’s TransCAD travel 

forecasting model (version E4-enhanced). A more detailed description of the 

model is available from SEMCOG upon request. 

 7 
• HPMS Normalization Factors: EPA and FHWA guidance stipulates that VMT 

used to construct mobile source emissions inventories be consistent with that 

reported through the Highway Performance Monitoring System (HPMS), In 

accordance with this guidance, SEMCOG developed factors to normalize the 

TransCAD travel model VMT to the Michigan Department of Transportation 

(MDOT) HPMS VMT. The factors were developed in a four-step process: 

1. 2002 HPMS universe data, aggregated by county and functional class, were 

obtained from MDOT. 

2. 2002 average weekday TransCAD model VMT were also aggregated by 

county and functional class. 

3. TransCAD VMT was converted to average annual daily VMT (AADVMT) 

using day-of-week adjustment factors from MDOT’s publication Seasonal 

Analysis of Michigan’s Permanent Traffic Recorder (PTR) Data For 2001, 

2002, 2003.

4. Normalization factors for each county and functional class were computed by 

dividing the HPMS VMT by the corresponding TransCAD AADVMT. 

The daily adjustment factors used in step 3, along with the resulting 

normalization factors, are provided in tables 4 and 5. These factors were applied 

to all travel model VMT, in both current and future years, prior to calculating 

vehicle emissions. 

Table 4 

Average Annual Daily Travel Adjustment Factors 

Area Type1 Urban Urban 

Area Limit Rural 

AADT Adj. 

Factor 0.8597 0.9214 1.0209 

1 Urban includes the city of Detroit; Urban Area Limit includes Macomb, Oakland and Wayne 

counties (excluding Detroit); Rural includes Livingston, Monroe, St. Clair and Washtenaw 

counties. 

Table 5 

HPMS Normalization Factors 

County Freeway Principal 

 Arterial 

Minor 

Arterial Collector 

Livingston 0.688099 1.585526 1.015991 0.535365 

Macomb 1.040133 1.204916 1.136826 0.855788 

Monroe 0.855686 1.007290 1.093279 0.689459 

Oakland 1.074974 1.043694 1.009170 0.697480 

St. Clair 0.867815 1.066117 1.363675 1.033534 

Washtenaw 0.829980 0.930350 0.900897 0.793497 

Wayne 

Detroit 1.137798 1.184245 1.372235 1.784939 

Outer-Wayne 1.061630 1.344744 1.280373 1.665449 

 8 
• VMT Seasonal Adjustment: Once the travel model VMT had been normalized 

to HPMS data, seasonal adjustment factors were applied to generate average 

daily VMT for each of the four seasons. The factors are shown in Table 6 below. 

They were developed using data from the MDOT report Seasonal Analysis of 

Michigan’s Permanent Traffic Recorder (PTR) Data for 2001, 2002, 2003. 

Table 6 

VMT Seasonal Adjustment Factors 

Season Area Type1

Winter Summer Spring Fall 

Urban 0.9417 1.0384 1.0080 1.0172 

Urban Area Limit 0.9491 1.0095 1.0528 0.9940 

Rural 0.8685 1.1682 0.9737 1.0357 

1 Urban include the city of Detroit; Urban Area Limit includes Macomb. Oakland and Wayne 

counties (excluding Detroit); Rural includes Livingston, Monroe, St. Clair and Washtenaw 

counties. 

• VMT Distribution by Vehicle Class: SEMCOG’s emissions post-processor 

apportions each roadway link’s hourly VMT among the eight different vehicle 

classes contained in the Mobile6 default “descriptive” emissions rate tables. This 

is done by multiplying the hourly VMT by the appropriate vehicle mix factors, 

listed in Table 7. 

The factors were developed using vehicle classification count data for Southeast 

Michigan. Freeway factors were computed from year 2000 MDOT PTR data. 

Arterial factors were developed from 1999 and 2000 screen line traffic counts 

taken by SEMCOG. The conversion of traffic count data from the standard 13 

FHWA bins to the eight vehicle classes in Mobile6 was done using vehicle sales 

and mileage accumulation data from EPA’s technical memorandum: Fleet 

Characterization Data for Mobile61

. Table 8 shows this apportionment. 

 9 
Table 7 

Southeast Michigan VMT Vehicle Mix Factors for Typical Weekday - Freeways 

 Vehicle Type 

Hour LDGV LDDV LDGT LDGT LDDT HDGV HDDV MC Total Road 

Type 1&2 3&4 

1 46.05 0.34 26.37 9.36 0.25 5.38 12.25 0.00 100.00

2 43.18 0.32 24.47 8.68 0.23 7.05 16.07 0.00 100.00

3 39.97 0.30 24.63 8.74 0.23 7.66 17.46 0.00 98.99

4 37.94 0.28 24.76 8.79 0.23 8.54 19.46 0.00 100.00

5 40.14 0.30 26.98 9.58 0.26 7.17 16.33 0.00 100.76

6 44.87 0.33 30.45 10.82 0.29 4.04 9.21 0.00 100.00

7 45.71 0.34 30.83 10.95 0.29 3.36 7.65 0.87 100.00

8 49.01 0.36 28.31 10.05 0.26 3.39 7.73 0.87 99.99

9 46.39 0.34 26.67 9.47 0.25 4.88 11.12 0.87 100.00

10 41.91 0.31 26.50 9.40 0.25 6.37 14.51 0.87 100.13

11 40.56 0.30 25.94 9.21 0.24 6.98 15.90 0.87 100.00

12 40.56 0.30 25.94 9.21 0.24 7.02 15.99 0.87 100.13

13 41.15 0.30 26.06 9.25 0.24 6.75 15.38 0.87 100.00

14 41.83 0.31 26.93 9.56 0.25 6.44 14.68 0.87 100.87

15 42.50 0.31 27.89 9.91 0.27 5.57 12.68 0.87 100.01

16 43.85 0.32 29.18 10.37 0.27 4.65 10.60 0.87 100.13

17 46.39 0.34 28.69 10.18 0.27 3.74 8.51 0.87 99.00

18 48.42 0.36 28.11 9.98 0.26 3.39 7.73 0.87 99.12

19 48.42 0.36 28.11 9.98 0.26 3.39 7.73 0.87 99.12

20 47.74 0.35 27.87 9.89 0.26 3.97 9.04 0.87 99.99

21 48.33 0.36 28.08 9.97 0.26 3.70 8.43 0.87 99.99

22 48.33 0.36 27.99 9.93 0.26 3.70 8.43 0.00 98.99

23 48.25 0.36 27.87 9.89 0.26 4.08 9.30 0.00 99.99

Freeway 

24 47.40 0.35 27.39 9.72 0.25 4.77 10.86 0.00 100.74

 10 
Table 7 continued 

Southeast Michigan VMT Vehicle Mix Factors for Typical Weekday - Arterials

Vehicle Type 

LDGV LDDV LDGT LDGT LDDT HDGV HDDV MC Total Road 

Type 

 

Hour 

 1&2 3&4 

1 53.71 0.40 29.24 10.38 0.27 1.53 3.48 1.00 100.00

2 53.04 0.39 29.51 10.47 0.28 1.57 3.58 1.15 100.00

3 51.58 0.38 29.97 10.64 0.27 1.88 4.28 1.15 100.15

4 50.23 0.37 30.97 10.99 0.29 1.88 4.28 1.00 100.00

5 49.08 0.36 31.08 11.04 0.29 2.18 4.97 1.00 100.01

6 47.42 0.35 31.45 11.17 0.29 2.53 5.77 1.00 100.00

7 47.63 0.35 30.57 10.86 0.29 3.05 6.95 1.00 100.70

8 47.94 0.35 28.59 10.15 0.26 3.61 8.23 1.00 100.15

9 46.59 0.34 28.12 9.98 0.26 3.97 9.04 1.00 99.30

10 45.70 0.34 29.29 10.39 0.28 4.01 9.14 1.00 100.16

11 45.70 0.34 29.79 10.58 0.28 3.75 8.55 1.00 100.01

12 46.28 0.34 29.49 10.46 0.28 3.71 8.45 1.00 100.00

13 46.95 0.35 28.99 10.29 0.27 3.71 8.45 1.00 100.00

14 46.95 0.35 28.99 10.29 0.27 3.66 8.34 1.00 99.85

15 47.16 0.35 28.95 10.27 0.27 3.61 8.23 1.00 99.85

16 47.16 0.35 29.06 10.31 0.27 3.87 8.82 1.00 100.85

17 47.84 0.35 28.67 10.18 0.26 3.82 8.71 1.00 100.84

18 48.72 0.36 28.13 9.98 0.26 3.52 8.02 1.00 100.00

19 49.87 0.37 28.64 10.17 0.27 2.91 6.63 1.00 99.85

20 51.11 0.38 29.07 10.32 0.27 2.39 5.45 1.15 100.15

21 52.26 0.39 29.47 10.46 0.28 2.09 4.76 1.00 100.69

22 53.14 0.39 28.93 10.27 0.27 1.83 4.17 1.00 100.00

23 53.82 0.40 29.17 10.35 0.27 1.53 3.48 1.00 100.00

Arterial 

24 54.60 0.40 29.44 10.45 0.27 1.22 2.78 0.85 100.00

 11 
Table 8 

Vehicle Class Conversion Process: FHWA to Mobile6

FHWA 

Class 

(Count Bin) 

General 

Vehicle Class 

 

Mobile6 

Vehicle Class 

 

Proportion

Assigned 

to M6 Class

Bin 1 Motorcycle Motorcycle 100.0

Light Duty Gas Vehicle 67.6

Light Duty Diesel Vehicle 0.5

Light Duty Gas Truck 1&2 23.4

Light Duty Gas Truck 3&4 8.3

Bin 2 Light Duty Vehicle 

Light Duty Diesel Truck 0.2

Light Duty Gas Truck 1&2 73.2

Light Duty Gas Truck 3&4 26.0

Bin 3 Light Duty Truck 

Light Duty Diesel Truck 0.8

Bins 4-13 Heavy Duty Heavy Duty Gas Truck 30.5

Heavy Duty Diesel Truck 69.5

• Time of Day and Directional Split Apportioning: SEMCOG’s emission 

estimation process is designed to capture the temporal variation in emissions. 

This is accomplished through the application of hour-of-day (K) and directional 

split (D) factors, developed from 1985 traffic survey data2. Table 9 provides both 

the hourly distribution and directional split factors, by functional class.. The 

factors are applied at the link level. Thus, the daily VMT for each two-way link is 

divided into 48 separate values (24 hours x 2 directions for each hour). In the 

case of one-way links/streets, only the hourly factors are applied, creating 24 

hourly VMT values per link. 

 12 
Table 9 

Time of Day & Directional Split Factors for Typical Weekday 

Time of Day 

Volume Factors 

Directional Split 

Hour Ending Factors 

Freeways Arterials Freeways Arterials 

 1:00 a.m. 0.015 0.014 0.59 0.60 

 2:00 0.009 0.007 0.58 0.59 

 3:00 0.007 0.005 0.58 0.60 

 4:00 0.006 0.003 0.56 0.58 

 5:00 0.009 0.004 0.59 0.61 

 6:00 0.022 0.012 0.62 0.67 

 7:00 0.051 0.031 0.64 0.67 

 8:00 0.075 0.056 0.61 0.65 

 9:00 0.064 0.058 0.58 0.60 

 10:00 0.052 0.048 0.56 0.57 

 11:00 0.049 0.050 0.54 0.55 

 12:00 0.051 0.057 0.53 0.54 

 1:00 p.m. 0.051 0.062 0.53 0.54 

 2:00 0.052 0.060 0.53 0.54 

 3:00 0.060 0.065 0.53 0.54 

 4:00 0.073 0.076 0.55 0.56 

 5:00 0.079 0.081 0.58 0.58 

 6:00 0.077 0.079 0.57 0.58 

 7:00 0.054 0.061 0.56 0.56 

 8:00 0.038 0.048 0.54 0.55 

 9:00 0.031 0.040 0.55 0.56 

 10:00 0.030 0.035 0.55 0.57 

 11:00 0.026 0.026 0.55 0.61 

 12:00 0.021 0.021 0.55 0.57 

Source: Survey of Regional Traffic Volume Patterns in Southeast Michigan, 

SEMCOG, September 1985. 

 13 
• Travel Speed Estimation: Because of recognized limitations with speeds 

generated from most travel demand models, SEMCOG’s emissions estimation 

process does not use link speeds from TransCAD. Instead a post-processing 

equation is used, based on research conducted by Richard Dowling and 

Alexander Skabardonis in the early 1990’s3

. Their findings, along with speed 

data collected by SEMCOG in 19924

, were used to develop the following speed 

equation5

: 

Avg. Link Speed = Avg. Queue Speed * (Avg. Queue Length/Length) + 

Uncongested Speed * (1 – (Avg. Queue Length/Length)) 

where: Uncongested Speed = 1.24 * Survey Speed(fc,h)/(1 + (V/Ci)

11) 

 fc = functional class 

 h = hour of day 

 Avg. Queue Speed = capacity/lane * 25 ft./vehicle 

 Avg. Queue Length = average Queue * 25 ft./vehicle 

 Avg. Queue = (Q1 + Q2)/2 

 Q1 = queue at start of time slice 

 Q2 = queue at end of time slice 

 = Q1 + (1-hour traffic/lane – 1-hour 

capacity/lane) 

Separate link speeds are calculated for each hour of the day and direction of 

travel (48 speeds for each two-way link, 24 speeds for each one-way link). 

• Local VMT Estimation and Emissions Calculation: Because SEMCOG’s 

travel model does not include local (residential) streets, the emissions postprocessor uses gross level local road VMT data from MDOT’s HPMS to calculate 

base-year local road emissions. This VMT is allocated among the different 

vehicle classes using the vehicle mix distribution for arterials during the noon 

hour (see Table 4 of Appendix G). A single set of local road emission factors, 

based on the Mobile6.2 default speed of 12.9 mph, is applied to the local VMT 

(for each vehicle class) to calculate emissions. This process can be expressed 

as follows: 

LRE = ∑cv Local VMTc * %VMTv * EFv

where: LRE = local road emissions 

 %VMT = % VMT occurring on an urban arterial at noon hour 

 c = county 

 v = vehicle class 

 EF = emission factor for local road at 12.9 mph 

• Emissions from Freeway and Arterial Travel: As noted above, SEMCOG’s 

post-processing model (EMIS_FC_M6PM) follows EPA’s Quality Review 

Guidelines for 1990 Base Year Inventories. However, the program does not use 

the approach of assigning one emission factor for each vehicle type and road 

type, at a single speed. Instead emissions are calculated at the link level, based 

on the directional speed and VMT for each hour, on each link. The process can 

 14 
be expressed by the following equation: 

Ea-b = ∑k,d,v VMTa-b (in hour k, direction d) * EFfc,s,v * %VMTfc,v 

where: Ea-b = emissions for link a-b 

k = hour of day 

d = direction of travel 

v = vehicle class 

EF = emissions factor 

fc = functional class/facility type 

s = average link speed in hour k, direction d 

• Daily Emissions Summation for Each Season: Once link-level emissions 

have been calculated, they are aggregated by pollutant, vehicle class, functional 

class and county. Summary reports are then generated showing total daily 

emissions of each pollutant by county, road type and vehicle type. Information on 

VMT and average speed is also provided. A separate post-processing run is 

performed for each season of each analysis year. 

• Annual Emissions Calculation: Once average daily emissions have been 

calculated for each season in a given analysis year. These emissions are 

multiplied by the number of days in that season, then summed to obtain the 

annual inventory. Emissions are reported in tons per year. 

II. Resulting On-Road Mobile Source Emissions Inventory 

Tables 10-13 contain the on-road mobile source emissions inventories resulting from the 

modeling process described above. Each table lists the annual emissions of six different 

pollutants, by county, for a given analysis year (2002, 2005, 2009 or 2018). The six 

pollutants are those specified in the EPA’s 2007 Clean Air Fine Particle Implementation 

Rule. They include volatile organic compounds (VOC), carbon monoxide (CO), nitrogen 

oxide (NOx), directly emitted PM2.5, sulfur dioxide (SO2), and ammonia (NH3). 

Table 10 

2002 On-Road Mobile Source Emissions 

Tons/Year 

County VOC CO NOx Primary

PM2.5* SO2 NH3 

 Livingston 2,273 41,619 7,032 118 295 189

 Macomb 7,893 131,842 18,736 359 945 624

 Monroe 2,372 42,803 7,124 121 305 195

 Oakland 16,351 275,611 41,379 760 1,960 1,279

 St. Clair 2,091 34,038 4,997 95 250 165

Washtenaw 4,536 80,205 13,071 226 575 370

 Wayne 23,457 391,446 59,052 1,087 2,793 1,821

 Reg. Total 58,972 997,564 151,390 2,767 7,122 4,642

* Primary PM2.5, which includes all exhaust emissions as well as those from brake and tire wear. 

Table 11 

2005 On-Road Mobile Source Emissions 

 15 
Tons/Year 

County VOC CO NOx Primary

PM2.5* SO2 NH3 

 Livingston 1,697 31,039 5,418 89 71 201

 Macomb 5,785 97,334 14,121 265 221 646

 Monroe 1,743 31,635 5,454 91 73 206

 Oakland 11,918 202,301 31,088 560 458 1,319

 St. Clair 1,551 25,240 3,813 71 59 172

Washtenaw 3,350 59,242 9,962 170 137 388

 Wayne 16,931 284,801 43,981 792 647 1,859

 Reg. Total 42,974 731,593 113,838 2,039 1,667 4,790

* Primary PM2.5, which includes all exhaust emissions as well as those from brake and tire wear. 

Table 12 

2009 On-Road Mobile Source Emissions 

 Tons/Year 

County VOC CO NOx 

Primary 

PM2.5* SO2 NH3 

 Livingston 1,303 23,364 3,650 65 20 209

 Macomb 4,364 72,675 9,434 193 63 666

 Monroe 1,339 23,958 3,703 67 21 215

 Oakland 8,965 150,463 20,682 404 130 1,355

 St. Clair 1,177 18,988 2,559 52 17 178

Washtenaw 2,580 45,167 6,801 125 40 410

 Wayne 12,449 207,581 28,657 559 179 1,870

 Reg. Total 32,177 542,196 75,486 1,465 469 4,903

* Primary PM2.5, which includes all exhaust emissions as well as those from brake and tire wear. 

Table 13 

2018 On-Road Mobile Source Emissions 

 County Tons/Year 

VOC CO NOx Primary 

PM2.5* SO2 NH3 

 Livingston 802 20,339 1,375 39 23 237 

 Macomb 2,521 59,542 3,502 113 67 705 

 Monroe 802 20,286 1,357 39 23 236 

 Oakland 5,107 120,939 7,386 228 134 1,409 

 St. Clair 702 16,100 980 31 19 195 

Washtenaw 1,548 38,146 2,501 74 43 449 

 Wayne 7,030 166,315 10,270 314 185 1,932 

 Reg. Total 18,511 441,665 27,372 837 493 5,164 

*Primary PM2.5, which includes all exhaust emissions as well as those from brake and tire wear. 

 

1 U.S. Environmental Protection Agency, Fleet Characterization Data for Mobile6: Development and Use of Age 

Distributions, Average Annual Mileage Accumulation Rates, and Projected Vehicle Counts for Use in MOBILE6, 

September 2001. 2 SEMCOG, Survey of Regional Traffic Volume Patterns in Southeast Michigan, tables 3–7, 1985. 

 16 
 

3

 Dowling, Richard and Alexander Skabardonis, Improving the Average Travel Speeds Estimated by Planning 

Models, Transportation Research Board, January 1992. 4

 SEMCOG, Survey of Roadway Speeds in Southeast Michigan, January 1993. 5

 More complete documentation of the use of SEMCOG speed survey data in the development of this equation can 

be found in the document Redesignation of Southeast Michigan to Attainment for Ozone: Technical Support 

Document, jointly published by MDNR, MDOT and SEMCOG in November 1993. 

 17 
Appendix E 

SOUTHEASTERN MICHIGAN PM2.5 CONTROL PLAN: 

MONITORING STRATEGY 

SUPPORT DOCUMENTATION 

FOR THE 

FINE PARTICULATE SIP 

May 2008 
Southeastern Michigan PM2.5 Control Plan: Monitoring Strategy 

The purpose of this document is to propose a monitoring strategy as part of the southeastern 

Michigan PM2.5 control plan. The strategy consists of ambient measurements both from the 

existing monitoring network (with a few changes) and new special purpose monitoring, and 

associated data analyses. The ability to implement this strategy, especially changing the 

existing network and conducting new monitoring, is dependent on the availability of additional 

funding. (Note, the strategy will need to be reviewed and, as necessary, revised based on the 

final set of emission reduction programs selected for the PM2.5 control plan.) 

Monitoring Objectives 

The objectives of the monitoring strategy include: 

• assess attainment of National Ambient Air Quality Standard, 

• provide real-time measurements (to support public outreach), 

• improve understanding of the PM2.5 nonattainment problem (including to help 

identify the contribution of source types and source regions to PM2.5 levels), 

• track progress towards attainment (and assess effectiveness of emission 

reduction programs). 

Measurements 

A summary of existing and suggested additional measurements is provided in Table 1. A map 

of the existing monitoring sites is shown in Figure 1. 

Figure 1. PM2.5 Monitoring Sites in Southeastern Michigan (Note: although not shown, there are 

two other sites – Newberry and FIA – located near Dearborn and Fort Street (SWHS)) 
Two changes to the existing monitoring network (pending the availability of funding) are 

recommended: 

• Establish a TEOM monitor at SWHS1

. 

• Establish an STN monitor at SWHS – either by moving the Luna Pier STN 

monitor or siting an available STN monitor (which would require additional 

resources for lab support). 

It should also be noted that in light of pending budget cuts by USEPA, the State may need to 

reduce the number of FRM (and, perhaps, STN) sites in the network. Further discussion is 

needed on any specific proposed reductions. 

New special purpose monitoring (pending the availability of funding) is desirable to improve 

understanding of the PM2.5 nonattainment problem, especially for organic carbon. General 

suggestions for organic carbon-related monitoring and data analyses are discussed in the 

Appendix. Of these suggestions, serious consideration should be given to the following 

activities in southeastern Michigan: 

• Collect continuous OC/EC data at Dearborn and, if possible, Allen Park. (Note, 

these data should be reviewed regularly to assess the adequacy of the existing 

1-in-6-day STN sampling schedule at Dearborn.) 

• Collect speciated OC data at Dearborn. High time resolution data are important. 

One approach is to analyze existing or new filters for many high OC 

concentration days, similar to what University of Wisconsin did earlier this year. 

• Following analysis of the continuous measurements (see below) and the 

subsequent identification of important local sources, source sampling should be 

conducted for the important sources in the vicinity of the Dearborn monitor to 

develop improved source profiles for source apportionment analyses. 

Although lesser priority, additional lab analyses of existing filters would also be desirable to 

support source apportionment analyses and improve understanding of PM2.5 sources: 

• ICP/MS to determine metals concentrations - ICP/MS yields lower minimum 

detection limits (MDLs) than the standard XRF protocol, but also has 

disadvantages, including poorer resolution for some species and it is a 

destructive method. While ICP/MS is technically feasible and yields good quality 

data, it is more expensive than XRF (i.e., about $28K for 40 elements on 100 

FRM Teflon samples, or about $19K for 20 elements on 100 FRM Teflon 

samples). 

• Scanning electron microscopy to assess sources of certain elements (note: this 

type of analysis was recently done using filters collected in the vicinity of Granite 

City Steel near St. Louis) 

 

1

 As noted in Table 1, Dr. Jerry Keeler has operated a TEOM at SW High School, but these data are not 

currently available. 
Data Analysis 

Near-term activities include additional analysis of existing measurements, including a review of 

continuous measurements to assess plume hits, and an examination of burning sources, as 

discussed in the Appendix. On-going activities include quarterly review of FRM and STN data, 

and periodic source apportionment studies using the latest measurement (e.g., assess trends in 

source contributions). These activities can be conducted by in-house personnel (e.g., MDEQ 

and LADCO). 
Table 1. PM2.5-Related Air Quality Measurements in Southeastern Michigan 

Monitoring Type FRM TEOM Aethalometer STN Pollutant/Species PM2.5 mass PM2.5 mass Black (elemental) 

carbon 

Sulfates, nitrates, organic carbon, 

elemental carbon, soil 

Sampling Frequency 1-in-3 day, 1-in-6 

day 

continuous continuous 1-in-3 day, 1-in-6 

day 

Purpose Assess attainment 

of NAAQS 

Provide real-time measurements 

Provide data for SIP development 

Provide data for Sdevelopment 

(improve understanding of PM2.5) 

Allen Park 261630001 x x x x SW High School 261630015 x x (Keeler short-term 

study) 

Linwood 261630016 x E. 7 Mile 261630019 x Livonia 261630025 x Dearborn 261630033 x x x x Wyandotte 261630036 x Newberry 261630038 x x x x (Schauer shor

term study) 

FIA 261630039 x x New Haven 260990009 x Luna Pier 261150005 x x (move to SWHSOak Park 261250001 x Port Huron 261470005 x x Ann Arbor 261610005 x Ypsilanti 261610008 x x x 
APPENDIX 

Organic Carbon Monitoring and Data Analysis Activities 

Overview: The purpose of this paper is to suggest ambient measurements and data analyses for 

organic carbon (OC) to address the following objectives: 

 Near-Term (by early 2007): (1) better define burning source(s) 

 (2) better identify local OC sources 

 (3) justify emissions inventory adjustment factors 

 Longer-Term (2008 and beyond): (1) improve understanding of mobile sources 

 (2) improve understanding of OC sources 

 (3) assess effectiveness of control programs in 

 reducing OC concentrations 

These monitoring and data analysis activities are intended to provide a better understanding of 

organic carbon and support possible regulatory efforts for PM2.5 in the Upper Midwest. 

Background: In 2004 – 2005, LADCO supported the Urban Organics Study, with contractor 

assistance study by the University of Wisconsin and Sonoma Technology, Inc. (STI). The purpose 

of this study was to provide ambient measurement-based information on sources of PM2.5 organic 

carbon concentrations (e.g., anthropogenic v. biogenic, urban v. rural, and primary v. secondary). 

It was hoped that this information would be sufficient to identify organic carbon sources and to 

determine possible control programs. 

Special OC measurements were made at five urban sites (Chicago, St. Louis, Detroit, Cincinnati, 

and Indianapolis) and one rural site (Bondville, IL)2

. Source apportionment analyses were then 

conducted using these measurements. The study results indicated four major OC source types 

(mobile, burning, industrial, and secondary), but were unable to provide any further definition. 

Consequently, the resulting control strategy implications were rather general, and numerous 

suggestions were made for further work. 

Monitoring and Data Analysis Activities: To meet the near-term and longer-term objectives, the 

following activities should be considered: 

(1) Maintain STN Network: Speciated PM2.5 measurements need to be continued at a 

core set of existing sites. (Due to funding cuts and periodic network reviews, it may 

not be possible or necessary to maintain all original STN sites.) On-going 

measurements are needed to define trends in PM2.5 species and improve 

understanding of organic carbon sources. 

(2) Continuous Data Collection: Continuous EC/OC (Sunset method) and BC 

(aethelometer) measurements at multiple locations are needed to further explore 

plumes and diurnal behavior. Such data are desirable in one or more of the 

expected PM2.5 residual nonattainment areas: Detroit, Chicago, Cleveland, Granite 

City (St. Louis), and Steubenville. 

 

2

 In the case of Detroit, STI focused on measurements collected at Allen Park, while UW analyzed 

measurements from both Allen Park and Dearborn. 
While we are awaiting these data, follow-up analyses to the Urban Organics Study 

should be conducted. For example, available continuous air quality and 

meteorological measurements should be reviewed to look for plume “hits”. This 

analysis may help identify nearby sources. 

(3) Speciated OC Data Collection: Special measurements, such as hi-vol sampling with 

analysis of individual organic species to identify specific chemical markers to 

support source apportionment studies. Such measurements were collected in the 

Urban Organics Study, and a special study in the Seney National Wildlife Refuge 

(see “Source Apportionment of Atmospheric Fine Particulate Matter Collected at the 

Seney National Wildlife Refuge”, May 2004). In the Seney study, chemical markers 

associated with biogenic emissions were identified. 

(4) Analysis of Burning Source: Levoglucosan analysis is needed to determine biomass 

burning (independent of OC analysis). The Jeff Collett method (anion-exchange 

chromatography with pulsed amperometric detection) is very specific for 

levoglucosan and can be done more cheaply. This is typically done on high-vol 

filters and has not been attempted on archived STN or FRM filters, but Jeff thinks it 

is possible and is interested in such a project. (Neil Frank is also interested in a 

multi-regional program to look at ways to estimate biomass using levoglucosan and, 

perhaps, potassium and may have money that could be leveraged.) 

While we are awaiting these data, follow-up analyses to the Urban Organics Study 

should be conducted. For example, back trajectories should be prepared for all 

days identified as having a high burning source impact in the initial source 

apportionment analyses. This information may help determine source regions and 

burning activities. 

(5) Examination of Old and New Carbon: C14 analysis could be conducted to determine 

fossil/modern carbon split. New carbon is mostly associated with biogenic 

Secondary Organic Aerosol (SOA) and biomass burning, while old carbon is 

associated with mobile source, stationary fossil fuel combustion, and fossil fuel 

source SOA. Together with the levoglucosan data above, this would allow us to 

develop a more certain bound on anthropogenic and biogenic contributions (i.e., 

biomass burning is a fraction of modern carbon -- whatever is left of modern carbon 

after biomass burning is subtracted is the biogenic contribution). This is an 

expensive analysis -- ~$500/sample. 

(6) Characterize Intra-City Spatial Variability (Jamie Schauer methodology): Routine 

sampling along a transect in the prevailing wind direction with at least three sites to 

quantify upwind, center city or industry, and downwind. Detroit would be an ideal 

location; for example, select Allen Park, Dearborn, and Linwood. Combining this 

with continuous data (EC/OC) would help discern some source patterns (mobile, 

industrial plumes) in the much higher resolution data. 

(7) Development of Source Profiles: Source sampling is critical in light of the significant 

uncertainties we have discovered in numerous source apportionment studies. Most 

important are steel mills, especially the different processes within the mills, 

locomotives, and other off-road mobile sources. Data on on-road mobile sources 

would be helpful as well. (Note, these data may be EPA’s Kansas City study.) 
Would also be useful to have resuspended dust (road dust and soil) for various 

cities -- this would help interpret some profiles that can confuse common crustal 

signatures with those of industrial processes and develop some knowledge of 

geological variability in the Midwest. Need to find Gary Casuccio's report on 

CCSEM at a Pennsylvania steel mill -- supposedly this characterizes various 

processes. 

(8) Additional Data Analyses (using existing data): Besides the two follow-up data 

analysis activities noted above (i.e., analysis of available continuous data and 

trajectory analyses of burning source), additional recommended analyses include: 

(a) evaluate the emissions inventory in the context of the source apportionment 

results (note, this analysis is likely to lead to an adjustment factor for primary 

organic carbon emissions from on-road mobile sources), and (b) assess trends in 

source contributions (note, this analysis may help determine the effectiveness of 

certain control programs). 

The table below identifies the relevant objectives for these activities: 

Next Steps: This paper will be shared with federal, state, academic, and stakeholder 

representatives to ensure that the recommended activities are relevant and appropriate. In 

addition, available funding options need to be explored (e.g., private foundations, special federal 

appropriation, and stakeholder contributions). Once we have a good idea of how much new 

money will be available, then the activities will be prioritized and LADCO will proceed with a 

competitive contract process.
Appendix F 

CALCULATION OF SEVERSTAL EMISSIONS 

SUPPORT DOCUMENTATION 

FOR THE 

FINE PARTICULATE SIP 

May 2008 
Determining the emissions from Severstal North America steel mill for Michigan’s 

AERMOD modeling evaluation was complicated process that involved using: 

1)PM emissions reported from MDEQ permit #182-05B (Severstal permit) and 

2)emissions and calculation from the steel mill study done by RTI (2006) to 

determine PM2.5. This appendix gives the details in how the emissions estimates 

for modeling were developed. 

Table 1 shows how PM was calculated for the Severstal permit showing the 

throughput and emissions factors used by Severstal in their permit. The 2009 

future potential limits for PM are the maximum emission limits allowed in the 

Severstal permit once controls are installed (fall 2007 for most emission 

sources). 

Table 2 compares the 2002 PM emissions and emissions factors used in the 

Severstal permit, the RTI report, and MDEQ that were used to develop the 

AERMOD modeling emissions. MDEQ used a hybrid between the Severstal 

permit emissions and the RTI report, based on recommendations of MDEQ 

permit engineers. The RTI report indicated that Severstal has a local hood to 

capture charging and tapping emissions from the BOF and send the emissions to 

the ESP for control. Severstal uses an estimated capture efficiency of 95 percent 

for charging and tapping emissions (emission factors of 0.03 and 0.046 lb/ton, 

respectively). RTI research indicated that 95 percent capture is more appropriate 

for hoods designed and dedicated to capture fugitive emissions, not for a local 

hood like Severstal had. Furthermore, Severstal had several exceedances of the 

20 percent opacity limit for the BOF shop, which supported a lower capture 

efficiency as in the RTI report.

There is no emission factor for the type of blast furnace casthouse roof monitor 

as used at Severstal. Severstal uses 85 percent capture efficiency, however, 

one study, as indicated in the RTI report, found a 74 percent reduction using a 

similar system. RTI used a75 percent reduction which would also be supported 

by the opacity exceedences reported for the casthouses as well. 

Since the Severstal permit does not contain PM2.5 emissions numbers, they had 

to be calculated using the PM2.5-FIL:PM-FIL ratio provided in the RTI report. 

Table 3 shows the generic source types and ratios used to calculate PM2.5 from 

PM (this table is Table 5-2 in the RTI report). Table 4 show the ratio used for 

each Severstal specific emission sources to calculate the 2002 actual PM2.5

emissions and the 2009 PM2.5 future potential emissions used for MDEQs 

AERMOD modeling. 
Table 1. PM calculations from Severstal permit. 

Source

Throughput Value Throughput Value

2009 

Emission 

Factor 

Value

Units

2009 

Potential 

Emissions 

(tpy)

2002 

Emission 

Factor

Units

2002 

Emissions 

(tpy)

B BF Stoves (BFG) 13,392.0 MMSCF 15,136.6 MMSCF 2.9 lb/MMSCF 21.95 2.9 lb/MMSCF 19.42 

C BF Stoves (BFG) 24,003.0 MMSCF 37,841.1 MMSCF 2 lb/MMSCF 37.84 2.9 lb/MMSCF 34.80 

B BF Stoves (NG) 459.0 MMSCF 483.7 MMSCF 7.6 lb/MMSCF 1.84 7.6 lb/MMSCF 1.74 C BF Stoves (NG) 434.0 MMSCF 655.3 MMSCF 7.6 lb/MMSCF 2.49 7.6 lb/MMSCF 1.65 B BF Casthouse (Roof Monitor) 900,533.0 TPY 949,000.0 TPY 0.012 lb/ton 5.69 0.09 lb/ton 40.52 

C BF Casthouse (Roof Monitor) 1,571,337.0 TPY 2,372,500.0 TPY 0.012 lb/ton 14.24 0.09 lb/ton 70.71 

B BF Bleeders 80.5 MMSCF 84.9 MMSCF 2.9 lb/MMSCF 0.12 2.9 lb/MMSCF 0.12 C BF Bleeders 140.5 MMSCF 212.2 MMSCF 2.9 lb/MMSCF 0.31 2.9 lb/MMSCF 0.20 B BF Taphole Burning 1,440.0 ft. of pipe 1,517.5 ft. of pipe 0.5 lb Fe/lb fume 0.15 0.5 lb Fe/lb fume 0.14 C BF Taphole Burning 1,020.0 ft. of pipe 1,540.1 ft. of pipe 0.5 lb Fe/lb fume 0.15 0.5 lb Fe/lb fume 0.10 BF B Casthouse Baghouse Stack 250,000 ACFM 0.003 gr/dscf 24.46 

BF C Casthouse Baghouse Stack 500,000 ACFM 0.003 gr/dscf 48.93 

Lime Unloading - BOF Receiving 14,000 ACFM 14,000 ACFM 0.005 gr/dscf 2.63 0.600 lb/hr 2.63 Reladling South - STACK 130,000 ACFM 0.010 gr/dscf 13.58 

Reladling South - FUGITIVES 2,471,870.0 TPY 3,321,500.0 TPY 0.0038 lb/ton 6.31 0.0038 lb/ton 4.697 

Torch Cutting 39,745.2 TPY 0.1 lb/ton 0.00 0.1 lb/ton 1.987 

BOF Natural Gas 520.0 MMSCF 698.7 MMSCF 7.6 lb/MMSCF 2.66 7.6 lb/MMSCF 1.98 

BOF ESP Stack 841,000 ACFM 841,000 ACFM 0.0152 gr/dscf 223.12 0.0152 gr/dscf 202.35 

BOF Secondary Emiss. Baghouse 1,000,000 ACFM 0.003 gr/dscf 32.62 

BOF Tapping (Roof Monitor) 2,944,089.0 TPY 4,052,230.0 TPY 0.0026 lb/ton 5.27 0.046 lb/ton 67.71 

BOF Slag Tap (Roof Monitor) 372,502.0 TPY 500,538.2 TPY 0.0026 lb/ton 0.65 0.046 lb/ton 8.57 

BOF Charging (Roof Monitor) 2,471,870 TPY 3,321,500.0 TPY 0.0060 lb/ton 9.96 0.030 lb/ton 37.08 

Desulfurization - STACK 94,500 ACFM 94,500 ACFM 0.010 gr/dscf 9.15 0.010 gr/dscf 9.15 Desulfurization - FUGITIVES 2,471,870.0 TPY 3,321,500.0 TPY 0.0218 lb/ton 36.20 0.0218 lb/ton 26.94 

#1 LRF Stack 175,000 ACFM 175,000 ACFM 0.0052 gr/dscf 29.68 0.0052 gr/dscf 29.68 

#2 LRF Stack 100,000 ACFM 100,000 ACFM 0.0052 gr/dscf 16.96 0.0052 gr/dscf 16.96 

Vacuum DegasserDD Baghouse - Coke Transfer 20,000.0 ACFM 20,000.0 ACFM 0.005 gr/dscf 3.75 0.005 gr/dscf 3.75 EE Baghouse - Coke Unloading 25,000.0 ACFM 25,000.0 ACFM 0.005 gr/dscf 4.69 0.005 gr/dscf 4.69 EE Baghouse - Natural Gas 5.0 MMSCF 6.7 MMSCF 7.6 lb/MMSCF 0.03 7.6 lb/MMSCF 0.02 Raw Material Handling 1.00 PPH 4.38 1.00 PPH 4.38 Annealing Furnaces 883.2 MMSCF 1,215.7 MMSCF 10 lb/MMSCF 6.08 10 lb/MMSCF 4.42 Reheat Furnace #1 2,367.0 MMSCF 2,593.4 MMSCF 10 lb/MMSCF 12.97 10 lb/MMSCF 11.84 

Reheat Furnace #2 2,367.0 MMSCF 2,593.4 MMSCF 10 lb/MMSCF 12.97 10 lb/MMSCF 11.84 

Reheat Furnace #3 2,367.0 MMSCF 2,593.4 MMSCF 10 lb/MMSCF 12.97 10 lb/MMSCF 11.84 

Hand Scarfing 262,805.0 TPY 353,136.0 TPY 0.1 lb/ton 17.66 0.1 lb/ton 13.14 

B BF Slag Pit 156,692.7 TPY 165,126.0 TPY 0.0088 lb/ton 0.73 0.0088 lb/ton 0.69 

C BF Slag Pit 273,412.6 TPY 412,815.0 TPY 0.0088 lb/ton 1.82 0.0088 lb/ton 1.20 

Desulfurization Slag Pit 81,571.7 TPY 109,609.5 TPY 0.09 lb/ton 4.93 0.09 lb/ton 3.67 

Parts Cleaning 2,131.0 Gallons 2,131.0 GallonsMaintenance Paint Booth 70.0 Gallons 70.0 GallonsJ-9 Dip Tank 1,210.0 Gallons 1,210.0 Gallons 0.1 lb/1000lb 0.00 

Equipment and Emissions from On-Site Coal PulverizationFine Coal Silo Baghouse 6,200.0 ACFM 0.005 gr/dscf 1.16 

Filter #4 (Pulverizer Baghouse) 16,000.0 ACFM 0.005 gr/dscf 3.00 

Rail Unloading Baghouse 30,000.0 ACFM 0.005 gr/dscf 1.88 

Raw Coal Silo Baghouse 1,800.0 ACFM 0.005 gr/dscf 0.34 

Rail Car Building Heater 214.7 MMSCF 7.6 lb/MMSCF 0.82 

Pulverizer Hot Gas Generator 214.7 MMSCF 7.6 lb/MMSCF 0.82 

Process Fugitives 8.56 

Totals 573.14 664.20 

PM

EMISSIONS RESTRICTED BY LIMITS IN EXISTING PERMIT

RULE 290 EXEMPT EMISSION UNIT

2002 ACTUAL 2009 PROJECTED
Table 2. 2002 PM emissions and emissions factors comparisons used in the 

Severstal permit, RTI report and MDEQ AERMOD modeling. Numbers in red 

used RTI values instead of Severstal permit numbers. 

Source

Severstal 

2002 

Emission 

Factor

Severstal 

2002 

Emissions 

(tpy)

RTI 2002 

Emission 

Factor

RTI 2002 

Emissions 

(tpy)

MDEQ 2002 

Emission 

Factor

MDEQ 

2002 

Emissions 

(tpy)

Units for 

emissions 

factors

B BF Stoves (BFG) 2.9 19.42 2.9 19.42 2.9 19.42 lb/MMSCF

C BF Stoves (BFG) 2.9 34.80 2.9 34.80 2.9 34.80 lb/MMSCF

B BF Stoves (NG) 7.6 1.74 1.9 0.44 7.6 1.74 lb/MMSCF

C BF Stoves (NG) 7.6 1.65 1.9 0.41 7.6 1.65 lb/MMSCF

B BF Casthouse (Roof Monitor) 0.09 40.52 0.15 67.54 0.15 67.54

0.15 117.85

0.230 338.57

0.230 42.84

0.150 185.39

lb/ton

C BF Casthouse (Roof Monitor) 0.09 70.71 0.15 117.85 lb/ton

B BF Bleeders 2.9 0.12 2.9 0.12 2.9 0.12 lb/MMSCF

C BF Bleeders 2.9 0.20 2.9 0.20 2.9 0.20 lb/MMSCF

B BF Taphole Burning 0.5 0.14 inventory 0.14 0.5 0.14 lb Fe/lb fume

C BF Taphole Burning 0.500 0.10 inventory 0.10 0.5 0.10 lb Fe/lb fume

BF B Casthouse Baghouse Stack

BF C Casthouse Baghouse Stack

Lime Unloading - BOF Receiving 0.600 2.63 0.005 2.63 0.600 2.63 lb/hr

Reladling South - STACK 0.01 13.58 0.010 13.58 0.010 13.58 gr/dscf

Reladling South - FUGITIVES 0.0038 4.697 0.0095 11.74 0.0038 4.697 lb/ton

Torch Cutting 0.1 1.987 0.1 1.99 0.1 1.987 lb/ton

BOF Natural Gas 7.6000 1.98 1.9 0.49 7.6 1.98 lb/MMSCF

BOF ESP Stack 0.0152 202.35 39.9 lb/hr 174.80 0.0152 202.35 gr/dscf

BOF Secondary Emiss. Baghouse

BOF Tapping (Roof Monitor) 0.046 67.71 0.230 338.57 lb/ton

BOF Slag Tap (Roof Monitor) 0.046 8.57 lb/ton

BOF Charging (Roof Monitor) 0.030 37.08 0.150 185.39 lb/ton

Desulfurization - STACK 0.01 9.15 0.010 9.15 0.010 9.15 gr/dscf

Desulfurization - FUGITIVES 0.0218 26.94 0.055 67.98 0.0218 26.94 lb/ton

#1 LRF Stack 0.0052 29.68 0.0052 29.68 0.0052 29.68 gr/dscf

#2 LRF Stack 0.0052 16.96 0.0052 16.96 0.0052 16.96 gr/dscf

Vacuum Degasser

DD Baghouse - Coke Transfer 0.005 3.75 inventory 3.75 0.005 3.75 gr/dscf

EE Baghouse - Coke Unloading 0.005 4.69 0.005 4.69 gr/dscf

EE Baghouse - Natural Gas 7.60 0.02 7.6 0.02 lb/MMSCF

Raw Material Handling 1 4.38 inventory 4.38 1.00 4.38 PPH

Annealing Furnaces 10 4.42 1.9 0.84 10 4.42 lb/MMSCF

Reheat Furnace #1 10 11.84 1.9 2.25 10 11.84 lb/MMSCF

Reheat Furnace #2 10 11.84 1.9 2.25 10 11.84 lb/MMSCF

Reheat Furnace #3 10 11.84 1.9 2.25 10 11.84 lb/MMSCF

Hand Scarfing 0.1 13.14 0.1 13.14 0.1 13.14 lb/ton

B BF Slag Pit 0.0088 0.69 0.0088 0.69 0.0088 0.69 lb/ton

C BF Slag Pit 0.0088 1.20 0.0088 1.20 0.0088 1.20 lb/ton

Desulfurization Slag Pit 0.09 3.67 0.09 3.67 0.09 3.67 lb/ton

Parts Cleaning

Maintenance Paint Booth

J-9 Dip Tank

Fine Coal Silo Baghouse

Filter #4 (Pulverizer Baghouse)

Rail Unloading Baghouse

Raw Coal Silo Baghouse

Rail Car Building Heater

Pulverizer Hot Gas Generator

Process Fugitives

Storage piles tpy PM10 3.10

Unpaved roads inventory 75.00

Paved roads tpy PM10 34.00

Parking lots, open areas inventory 22.00

CC baghouse coke transfer inventory 4.70

Totals 664.20 1267.21 1191.80

Emissions reported in RTI report only

Equipment and Emissions from On-Site Coal Pulverization
Table 3. Ratios to calculate PM2.5-Fil from the RTI report (Table 5.2 in RTI report) 
Table 4. Ratio used from the RTI report to determine PM2.5 fraction of PM 

reported in Severstal permit. Numbers in red were not in Appendix B-2 in the RTI 

report. 

Source Name (from Severstal 

permit)

Sources in RTI Report in Appendix 

B-2 (unless otherwise noted)

PM2.5 fil 

ratio: PM

MDEQ 2002 

PM2.5 

Emissions

MDEQ 

2009 

Potential 

PM2.5 

Emissions

Net 

Change 

(tpy)

B BF Stoves (BFG) B BF Stoves (BFG) 1.00 19.42 21.95 2.53

C BF Stoves (BFG) C BF Stoves (BFG) 1.00 34.80 37.84 3.04

B BF Stoves (NG) B BF Stoves (NG) 1.00 1.74 1.84 0.09

C BF Stoves (NG) C BF Stoves (NG) 1.00 1.65 2.49 0.84

B BF Casthouse (Roof Monitor) B BF Casthouse (Roof Monitor) 0.23 15.53 1.31 -14.22

C BF Casthouse (Roof Monitor) C BF Casthouse (Roof Monitor) 0.23 27.11 3.27 -23.83

B BF Bleeders BF bleeder stacks 1.00 0.12 0.12 0.01

C BF Bleeders BF bleeder stacks 1.00 0.20 0.31 0.10

B BF Taphole Burning Tapehole burning 1.00 0.14 0.15 0.01

C BF Taphole Burning Tapehole burning 1.00 0.10 0.15 0.05

BF B Casthouse Baghouse Stack Blast furnace casthouse* 0.23

0.23

0.19

0.20

1.00

1.00

1

1

1

1

1

1

0.15

* from Table 5-2 in RTI report (see Table 3 above)

0.00 5.63 5.63

BF C Casthouse Baghouse Stack Blast furnace casthouse* 0.00 11.25 11.25

Lime Unloading - BOF Receiving Lime unloading 1.00 2.63 2.63 0.00

Reladling South - STACK Reladling South - Stack 0.23 3.12 0.00 -3.12

Reladling South - FUGITIVES Reladling South - Fugatives 0.23 1.08 1.45 0.37

Torch Cutting Torch Cutting 1.00 1.99 0.00 -1.99

BOF Natural Gas BOF (NG) 1.00 1.98 2.66 0.68

BOF ESP Stack BOF ESP Stack 0.73 147.72 162.88 15.16

BOF Secondary Emiss. Baghouse avg of BOF charge/tap baghouse* 0.00 6.20 6.20

BOF Tapping (Roof Monitor) BOF Tapping (Roof Monitor) 0.37 125.27 1.95 -123.32

BOF Slag Tap (Roof Monitor) Slag* 8.57 0.13 -8.44

BOF Charging (Roof Monitor) BOF Charging (Roof Monitor) 0.22 40.79 2.19 -38.59

Desulfurization - STACK Desulfurization - STACK 0.42 3.84 3.84 0.00

Desulfurization - FUGITIVES Desulfurization - FUGITIVES 0.11 2.96 3.98 1.02

#1 LRF Stack #1 LRF Stack 1.00 29.68 29.68 0.00

#2 LRF Stack #2 LRF Stack 1.00 16.96 16.96 0.00

Vacuum Degasser

DD Baghouse - Coke Transfer DD Baghouse - Coke Transfer 1.00 3.75 3.75 0.00

EE Baghouse - Coke Unloading assumed same as DD Baghouse 4.69 4.69 0.00

EE Baghouse - Natural Gas assumed same as DD Baghouse 0.02 0.03 0.01

Raw Material Handling Raw Material Handling 1.00 4.38 4.38 0.00

Annealing Furnaces Annealing Furnaces (NG) 1.00 4.42 6.08 1.66

Reheat Furnace #1 Reheat Furnace #1 (NG) 1.00 11.84 12.97 1.13

Reheat Furnace #2 Reheat Furnace #2 (NG) 1.00 11.84 12.97 1.13

Reheat Furnace #3 Reheat Furnace #3 (NG) 1.00 11.84 12.97 1.13

Hand Scarfing Hand Scarfing 1.00 13.14 17.66 4.52

B BF Slag Pit B BF Slag Pit 0.02 0.01 0.01 0.00

C BF Slag Pit C BF Slag Pit 0.02 0.02 0.04 0.01

Desulfurization Slag Pit Desulfurization Slag Pit 0.02 0.07 0.10 0.03

Parts Cleaning 0.00 0.00 0.00

Maintenance Paint Booth 0.00 0.00 0.00

J-9 Dip Tank 0.00 0.00 0.00

Fine Coal Silo Baghouse assumed same as DD Baghouse 0.00 1.16 1.16

Filter #4 (Pulverizer Baghouse) assumed same as DD Baghouse 0.00 3.00 3.00

Rail Unloading Baghouse assumed same as DD Baghouse 0.00 1.88 1.88

Raw Coal Silo Baghouse assumed same as DD Baghouse 0.00 0.34 0.34

Rail Car Building Heater assumed same as DD Baghouse 0.00 0.82 0.82

Pulverizer Hot Gas Generator assumed same as DD Baghouse 0.00 0.82 0.82

Process Fugitives AP-42, aggregate handling (2006)** 0.00 1.28 1.28

Totals 553.43 405.81 -147.62

Equipment and Emissions from On-Site Coal Pulverization

EMISSIONS RESTRICTED BY LIMITS IN EXISTING PERMIT

**from revisions to AP-42, 5th edition 
Appendix G 

OVERVIEW OF RECENT DETROIT PM SOURCE 

APPORTIONMENT STUDIES 

SUPPORT DOCUMENTATION 

FOR THE 

FINE PARTICULATE SIP 

May 2008 
Overview of Recent Detroit PM Source Apportionment Studies 

Donna Kenski 

Lake Michigan Air Directors Consortium 

November 26, 2007 

 Concentrations of PM2.5 in the Detroit metropolitan area currently exceed 

the National Ambient Air Quality Standard (NAAQS) at 2 of 11 monitoring sites 

and are within 1 ug of the NAAQS at 4 others (Fig. 1). Modeling studies show 

that federal controls are expected to bring all but the Dearborn monitor into 

attainment by 2012(?). Additional local control measures will be needed to 

achieve the NAAQS at Dearborn. To ensure effective controls, it is imperative 

that the state and local air programs understand the current composition of PM2.5

at each site and also the sources that contribute significant mass to them. 

For general background, Fig. 2 shows the chemical components averaged 

over several years at the speciation trends network (STN) sites in Detroit and 

upwind. Organic carbon is the largest component of PM2.5 on an annual average 

basis, followed by ammonium sulfate and ammonium nitrate. Concentrations of 

ammonium sulfate are similar among sites, indicating its regional origin. Organic 

carbon (OC) and ammonium nitrate, in contrast, have significant site-to-site 

variability. It is these site differences in concentration, as well as temporal 

differences, that the source apportionment models use to extract information on 

the sources that contribute to PM2.5 mass. 

 Six recently published source apportionment studies have examined data 

from Detroit monitors. These studies are summarized here and a few key 

findings are drawn from the group as a whole. The studies varied in the number 

of samples analyzed, the locations of sample collection, the species chosen for 

study, the source apportionment models applied, and the time periods of sample 

collection, so conclusions here are necessarily qualitative and somewhat 

general. Nevertheless, similarities can be drawn despite the variety of 

approaches and data used. The two most robust studies, Wade et al. (2007) and 

Gildemeister et al. (2007), both used STN data from the Allen Park and Dearborn 

sites. The remaining four studies reviewed here collected data independent of 

the STN network, although one (Brown et al., 2006) used the Allen Park site to 

collect samples. Figure 3 shows the monitoring sites where data were collected 

for the studies presented here and Fig. 4 shows the sampling dates for the 

studies. 

Study Summaries 

Wade et al. (2007): In the most comprehensive and most recent source 

apportionment analysis to date, Sonoma Technology examined STN data from 
Allen Park (12/2000-12/2006, 662 samples) and Dearborn (5/2002-12/2006, 253 

samples). Similar sources were identified at both sites, and contributions were 

similar for the major sources: secondary sulfate, secondary nitrate, and organic 

mass. The organic mass factor is described as distinct from elemental carbon 

(diesel) but is not necessarily only gasoline vehicles. Instead it probably includes 

some mass from other non-vehicle combustion sources, and is influenced by 

photochemistry and transport. The two sites are distinguished by the mass 

allocated to a steel source (1.27 ug at Dearborn vs. 0.05 ug at Allen Park), diesel 

vehicles (2.84 ug at Dearborn vs. 0.88 ug at Allen Park), and crustal species 

(1.36 ug at Dearborn vs. 0.62 at Allen Park). Additional mixed industrial factors 

were identified at each site as well, accounting for about 2 ug. The mixed 

industrial factors include some sulfate, indicating that local sulfate controls may 

be effective. Table 1 gives the source allocations for this study and the others, 

and Figure 5 shows the contributions by source, site, and study authors. 

Gildemeister et al. (2007): In a study very similar to Wade et al., Gildemeister 

et al. examined STN data from Allen Park (12/2000-4/2005) and Dearborn 

(5/2002-4/2005). PMF was used to distinguish seven sources common to both 

sites: Secondary sulfate, secondary nitrate, gasoline, diesel, mixed sea/road 

salt, iron/steel, and soil. A mixed industrial factor was also identified at Dearborn 

and a biomass burning factor was identified at Allen Park. Contributions to total 

PM2.5 mass are given in Table 1 and Fig. 5. Mass contributions from the 

secondary sulfate, secondary nitrate, and sea salt were similar at both sites, and 

also similar to those derived by Wade et al. The influence of local iron and steel 

industrial sources, mobile sources (gasoline and diesel), and soil was higher at 

Dearborn than Allen Park. Interestingly, gasoline sources were well correlated 

but diesel sources were not. The authors suggest that the diesel factor is a 

combination of sources with both area and point source characteristics. The 

wind analysis for diesel showed distinct directionality toward the port of Detroit 

and Ambassador Bridge. 

Brown et al. (2006): Like Wade et al. and Gildemeister et al., Brown et al. 

applied PMF to STN data from Allen Park and Dearborn. Seven sources were 

detected at Allen Park and nine at Dearborn. The allocations to secondary 

sulfate and nitrate were similar at both sites and also similar to those in Wade 

and Gildemeister. Mobile sources were about twice as high at Allen Park, but 

similar at Dearborn. Industrial sources accounted for about 1.3 ug/m3 at Allen 

Park and 3.5 ug/m3 at Dearborn. A biomass burning source accounted for 0.3 

ug/m3 at both sites. 

In addition, this study collected samples at Allen Park from Feb. 2004-Feb. 

2005 on a 1-in-6-day schedule. These samples were analyzed for speciated 

organic carbon and elemental carbon in monthly composites and the resulting 

dataset was analyzed using the chemical mass balance (CMB) method of source 

apportionment. Eight sources were modeled. The mass apportioned was total 

organic carbon, rather than PM2.5 as in the studies above. Using the organic 

species allows more precise identification of source contributions from carbon 
sources such as motor vehicles. In this study, mobile sources were apportioned 

to gasoline, diesel, and smoking vehicles. In Detroit, more than half of the OC 

allocated to mobile sources was attributed to smoking vehicles. Other sources 

included biomass burning, vegetative detritus, and dirt. Natural gas combustion 

was included in the model but its contribution was negligible. A significant 

portion of OC mass during the summer months was not allocated to any source 

and was presumed to be of secondary biogenic origin. This study is included in 

Table 1 and Fig. 5 despite the difference in the basis for allocating mass (OC vs 

PM2.5), because the sources it modeled are dominated by OC. 

Morishita et al (2006): This study made speciated PM2.5 measurements 

during 4 summers (2000-2003) at the Maybury school near the Ambassador 

Bridge (see Fig. 3). Maybury school is not a Michigan DEQ site but is close to 

the West Fort St. site. PMF was applied to 96 samples, using 15 species: S, Se, 

Mn, Fe, Ni, Zn, Rb, Mo, Cd., Ba, La, Sm, Pb, EC, and OC. Notably, nitrate was 

excluded from the analysis, although since these were summer samples the 

nitrate fraction would likely be small. The important crustal species Ca and Si 

were also excluded, which may have hindered the model’s ability to detect a soil 

or road dust source. Six sources were identified and quantified, as given in 

Table 1 below: Secondary sulfate/coal combustion, motor vehicles, municipal 

waste incineration, oil refining/combustion, sewage sludge incineration, and 

iron/steel manufacturing. This study also evaluated two distinct periods during 

2000 more intensively and found that elevated local source emissions, including 

incinerator and refinery emissions, were associated with adverse health effects 

during accompanying toxicological studies. 

Hammond et al. (2007): Another special measurement study, in which 

researchers collected speciated PM2.5 samples for 11 2-week periods between 

October 1999 and May 2002. Samples were collected at Maybury School (as in 

Morishita, above), and also at Keith School in east Detroit. A total of 154 

samples from the two sites were used in a PMF analysis. Species included 

were: PM25 mass, OC, EC, La, Sm, Ce, Pb, Al, P, S, V, Cr, Mn, Fe, Ni, Cu, Zn, 

K, and Se. As in the previous study, nitrate, Ca, and Si were not included. In 

East Detroit (Keith School) 5 sources were identified: Secondary sulfate/coal 

combustion, motor vehicles, refinery/oil combustion, automotive electroplating, 

and a mixed industrial factor including iron/steel manufacturing and waste 

incineration. At Maybury School, 7 sources were identified. These included the 

same factors found at Keith School, except the motor vehicles were split into two 

separate factors distinguished by gasoline combustion and diesel combustion, 

and an additional sewage sludge incineration source was identified. 

Pere-Trepat et al. (2007): This analysis applied PMF to DRUM samples 

collected over a 6 week period at the Allen Park site between February and April 

2002. The DRUM sampler collects particles in 3 different size modes 

(2.5>Dp>1.15, 1.15>Dp>0.34, and 0.34>Dp>0.1um) and in 3 hour time 

increments. Each size mode was analyzed for metals, PM mass, and optical 
absorption. Carbon and nitrate cannot be quantified from this type of sampler, so 

a large fraction of PM2.5 mass was not represented in the species modeled. 

Misaligned time stamps plagued the analysis, but once discovered were able to 

be corrected. Nine factors were resolved with PMF: road salt, a mixed industrial 

factor with iron and zinc, 2 metal works factors (one with iron in all sizes and Zn, 

Ti, Cu, and Mn, and the other with intermediate size Fe, small size sulfur, and Zn, 

Al, Si, and Ca), road dust, and 4 sulfur-dominated sources. The authors suggest 

that some of the metal-dominated profiles may represent different processes or 

batch operations at the same facilities, because the wind direction analysis 

indicated similar origins for each. The sulfur profiles were distinguished by size 

fraction and temporal behavior and the authors concluded that one was of local 

origin because of its irregular peaks at random time intervals and one was 

transported from distant sources long range because of its slowly evolving 

temporal pattern. Of the other 2 sulfur factors, one may represent dry or wet 

deposition of sulfate on local soils which are subsequently resuspended, and the 

other may be associated with industrial activity in the Rouge complex, because it 

had peaks in the southerly direction. The study did not include quantitative 

estimates of PM2.5 mass associated with each source factor, so it is not included 

in Table 1 or Fig. 4. 

Key Findings and Synthesis: 

• The Wade et al., Gildemeister, and Brown studies made very similar 

allocations to major sources at Allen Park and Dearborn. The data and 

modeling approach in these 2 studies were almost identical, which no 

doubt was an important factor in their similar findings. 

• The Morishita and Hammond studies differed from Wade, Gildemeister, 

and Brown in that data were collected at different locations and the 

species included in the models were somewhat different. Important 

crustal components Ca and Si were not included as fitting species. 

Compared to the Wade, Gildemeister, and Brown studies, contributions 

from vehicles were about the same, secondary sulfate was about twice as 

high, and industrial contributions were highly variable, ranging from 

inconsequential at Keith School to a total of 7 ug at Maybury School. The 

very high allocation to secondary sulfate and low allocation to industry in 

Hammond et al. may indicate that mass from industrial sources is being 

assigned incorrectly to secondary sulfate. 

• At Dearborn, the source apportionment results indicate that local 

industrial sources, including steel manufacturing but also other metal 

industries, likely contribute 2.5-3.5 ug/m3 to annual average PM2.5. 

• Dearborn also experiences higher vehicle impacts than Allen Park (1.3 to 

1.7 ug greater), and much of the increase is from diesel sources. 

• Contributions from secondary sulfate and nitrate do not differ much 

between Allen Park and Dearborn, evidence that these categories are not 

being influenced by local sources. Some of the industrial source 
fingerprints did include sulfate mass, however, which indicates that local 

sources of sulfate are present and may be suitable targets for control. 

References 

1. Brown, S.G., H.R. Hafner, P.T. Roberts, J.J. Schauer, and R.J. Sheesley, 

Integration of Results for the Upper Midwest Urban Organics Study, Sonoma 

Technology Report STI-903520-2942-FR (March 2006).

2. Gildemeister, A.E., P.K. Hopke, E. Kim, Sources of fine urban particulate 

matter in Detroit, MI, Chemosphere 69(2007):1064-1074. 

3. Hammond, D.M., J.T. Dvonch, G.J. Keeler, E.A. Parker, A.S. Kamal, J.A. 

Barres, F.Y. Yip, W. Brakefield-Caldwell, Atmos. Env. (2007), doi:10.1016 

(accepted manuscript). 

4. Morishita, M., G.J. Keeler, J.G. Wagner, and J.R. Harkema, Source 

Identification of ambient PM2.5 during summer inhalation exposure studies in 

Detroit, MI, Atmos. Env. 40(2006): 3823-3834. 

5. Pere-Trepat, E., E. Kim, P. Paatero, P.K. Hopke, Source apportionment of 

time and size-resolved ambient particulate matter measured with a rotating 

DRUM impactor, Atmos. Env. 41(2007):5921-5933. 

6. Wade, K.S., J.R. Turner, S.B. Brown, J. Garlock, and H.R. Hafner, Data 

Analysis and Source Apportionment of PM2.5 in Selected Midwestern Cities, 

Sonoma Technology Draft Final Report STI-907018.03-3264-DFR (Nov. 

2007). 
Fig. 1. Current Design Values for Detroit-Area PM2.5 FRM Monitors 

Fig. 2 Chemical Composition of PM2.5 at Speciation Trends Network Sites 
Fig. 3 Monitoring Sites in Detroit Where Source Apportionment Studies Have Been 

Performed 

Fig. 4 Dates of Source Apportionment Studies
0 2 4 6 8 10 

Source contribution, ug/m3

Mobile

Gasoline Veh.

Diesel Veh.

Sec. Sulfate/Coal

Sec. Nitrate

Iron/Steel Mfg.

Refinery/Oil

Municipal Incin.

Sludge Incin.

Mixed Industrial

Industrial/Zinc

Sea Salt/Road Salt

Crustal

Biomass Burning BrownOC-Allen Park

BrownPM-Allen ParkBrownPM-DearbornGildemeister-Allen PGildemeister-DearboHammond-KeithHammond-MayburyMorishita-MayburyWade-Allen ParkWade-DearbornBrownOC-Allen ParkWade-Dearborn

Summar

y of Source Apportionment Results at Detroit Site

Fig. 5 Summary of Source Contributions from Various Studies and Sites (contributions less than 0.05 ug/m3 are 

symbols are used for each study and site; colors indicate sites—i.e., red=Allen Park, blue=Dearborn, orange=Kei

een=Maybury School. 
Table 1 Summary of Source Contributions to PM2.5 by Study and Site 

Wade et al. Gildemeister et al. Brown et al.a

Morishita 

et al.b 

Source Category 

Allen 

Park Dearborn 

Allen 

Park Dearborn 

Allen 

Park(OC) 

Allen 

Park(PM) 

Dearborn 

(PM) Maybury School 

Vehicles 2.04 2.31  Gasoline 2.77 2.08 2.53 3.75 3.53 3.96  Diesel 0.88 2.84 0.67 1.17 2.37 1.06 Secondary sulfate/coal 4.99 5.24 4.99 4.84 4.51 4.49 7.28 Secondary nitrate 2.91 3.36 4.49 3.89 4.16 4.26 Industrial 1.35 2.35  Iron/steel mfg. 0.05 1.27 0.51 1.24 0.81 3.47  Mixed industry/zinc 0.85 1.51 1.30 0.32  Mixed industry/lead 1.39 0.55  Municipal incinerator 1.56  Sludge incinerator 1.76  Refinery/oil combustion 0.23  Electroplating Sea/road salt 0.57 0.72 Crustal/soil 0.62 1.36 1.29 2.14 0.11 0.63 0.88 Biomass burning 0.51 1.20 0.30 0.31 aBrown et al. apportioned PM2.5 using STN data and organic carbon mass using speciated organic data. bMorishita data are averaged over 5 different sampling periods and weighted by number of samples. 
Table 1 (Alternate version) Summary of Source Contributions to PM2.5 by Study and Site 

Allen Park Dearborn Maybur

Wade Gildemeister Brown(PM)a Brown(OC) Wade Gildemeister Brown(PM) Morishitab 

Vehicles 2.04 2.31  Gasoline 2.77 2.53 3.53 2.08 3.75 3.96  Diesel 0.88 0.67 2.37 2.84 1.17 1.06 Secondary sulfate/coal 4.99 4.99 4.51 5.24 4.84 4.49 7.28 Secondary nitrate 2.91 4.49 4.16 3.36 3.89 4.26 Industrial 1.35 2.35  Iron/steel mfg. 0.05 0.51 1.27 1.24 0.81 3.47  Mixed industry/zinc 0.85 1.51 1.30 0.32  Mixed industry/lead 1.39 0.55  Municipal incinerator 1.56  Sludge incinerator 1.76  Refinery/oil combustion 0.23  Electroplating Sea/road salt 0.57 0.72 Crustal/soil 0.62 1.29 0.63 0.11 1.36 2.14 0.88 Biomass burning 0.51 0.30 1.20 0.31 aBrown et al. apportioned PM2.5 using STN data and organic carbon mass using speciated organic data. bMorishita data are averaged over 5 different sampling periods and weighted by number of samples. 
Appendix H 

MODELING INPUT FILES

SUPPORT DOCUMENTATION 

FOR THE 

FINE PARTICULATE SIP 

April 2008 
2005 AERMOD SUMMARY – DEARBORN MONITOR LOCATION 

 *** AERMOD - VERSION 07026 *** *** 2005 MONITOR IMPACTS *** 

04/28/08 

 *** POINT SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ 

EMIS RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR 

SCALAR 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) 

VARY BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- - - - - 

 

 BF_B_SS 0 0.60870E+00 322263.4 4685504.0 192.0 57.91 672.04 9.60 2.52 YES YES NO 

 BF_C_SS 0 0.10486E+01 322221.8 4685586.5 192.0 64.01 672.04 13.70 2.74 YES YES NO 

 BFCCH_BS 0 0.00000E+00 322262.1 4685580.0 192.0 60.96 338.71 19.96 2.74 YES YES NO 

 LM_UL_BH 0 0.75700E-01 322184.0 4684950.0 192.0 10.97 294.26 22.64 0.61 YES YES NO 

 HMTRN_BH 0 0.89800E-01 322024.8 4685203.0 192.0 8.23 352.60 0.05 1.75 YES YES NO 

 BOF_ESP 0 0.42495E+01 321932.5 4685047.5 192.0 64.92 422.04 18.84 5.18 YES YES NO 

 BOF_BH 0 0.00000E+00 322004.8 4685285.0 192.0 60.96 338.71 18.95 4.88 YES YES NO 

 DESLF_BH 0 0.11050E+00 321971.5 4685217.5 192.0 11.28 380.37 0.05 1.68 YES YES NO 

 LRF#1_S 0 0.85380E+00 321983.0 4684947.0 192.0 45.11 297.04 13.97 2.74 YES YES NO 

 LRF2_FLX 0 0.48790E+00 322097.1 4684808.5 192.0 45.72 433.15 17.97 1.83 YES YES NO 

 COKE_REC 0 0.24280E+00 322127.2 4684707.5 192.0 5.49 294.26 21.38 0.71 YES YES NO 

 ANEAL_1S 0 0.11600E-01 321846.1 4685170.0 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_2S 0 0.11600E-01 321826.2 4685209.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_3S 0 0.11600E-01 321806.3 4685249.0 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_4S 0 0.11600E-01 321786.4 4685288.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_5S 0 0.11600E-01 321766.5 4685328.0 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_6S 0 0.11600E-01 321746.6 4685367.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_1N 0 0.11600E-01 321726.0 4685387.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_2N 0 0.11600E-01 321713.8 4685412.0 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_3N 0 0.11600E-01 321701.4 4685436.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_4N 0 0.11600E-01 321689.1 4685461.0 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_5N 0 0.11600E-01 321676.7 4685485.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 RFURN1_1 0 0.17030E+00 320999.0 4685172.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 RFURN1_2 0 0.17030E+00 321004.0 4685162.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 RFURN2_1 0 0.17030E+00 321009.0 4685152.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 RFURN2_2 0 0.17030E+00 321014.0 4685141.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 RFURN3_1 0 0.17030E+00 321020.0 4685131.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 RFURN3_2 0 0.17030E+00 321025.0 4685120.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 EU0099 0 0.59750E+01 326027.0 4682852.0 192.0 96.01 477.60 4.28 5.03 NO YES NO 

 EU0096 0 0.26820E+01 326192.0 4683221.0 192.0 20.73 294.30 15.16 3.30 NO YES NO 

 EU0095 0 0.26310E+01 326475.0 4683520.0 192.0 19.81 294.30 10.35 3.05 NO YES NO 

 RG0130 0 0.23970E+01 326323.0 4683637.0 192.0 60.96 416.50 15.63 5.33 NO YES NO 

 EU0096A 0 0.12010E+01 326192.0 4683221.0 192.0 70.10 560.90 13.53 2.82 NO YES NO 

 RG0133 0 0.98900E+00 326299.0 4683107.0 192.0 26.82 560.90 7.48 2.97 NO YES NO 

 RG0132 0 0.87100E+00 326305.0 4683579.0 192.0 20.73 560.90 17.11 1.68 NO YES NO 

 EU0095A 0 0.84500E+00 326475.0 4683520.0 192.0 60.96 383.20 13.37 2.84 NO YES NO 

 EU0120 0 0.34600E+00 326309.0 4683644.0 192.0 33.22 544.30 21.15 1.40 NO YES NO 

 RG0133A 0 0.29900E+00 326299.0 4683107.0 192.0 26.82 560.90 7.48 2.97 NO YES NO 

 EU0118 0 0.24100E+00 326059.0 4683063.0 192.0 37.49 422.00 9.27 0.91 NO YES NO 

 EU0076 0 0.21800E+00 325960.0 4683058.0 192.0 31.09 477.60 1.62 4.27 NO YES NO 

 *** POINT SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ 

EMIS RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR 

SCALAR 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) 

VARY BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- - - - - 

 

 EU0076A 0 0.16500E+00 326087.0 4683007.0 192.0 31.09 477.60 1.62 4.27 NO YES NO 

 RG0130A 0 0.15900E+00 326323.0 4683637.0 192.0 60.96 416.50 15.63 5.33 NO YES NO 

 RG0132A 0 0.14700E+00 326305.0 4683579.0 192.0 20.73 560.90 17.11 1.68 NO YES NO 

 A8648 0 0.49000E+00 321801.0 4686168.0 192.0 12.31 295.70 10.14 0.31 NO YES NO 

 A9831 0 0.57000E+01 322000.0 4683150.0 192.0 49.43 455.50 10.24 1.91 NO YES NO 

 B2132 0 0.36000E+00 322800.0 4675000.0 192.0 46.94 415.70 8.71 2.44 NO YES NO 

 B2169 0 0.20500E+01 324525.0 4682560.0 192.0 12.19 294.30 10.00 0.30 NO YES NO 

 B2810 0 0.12300E+01 325800.0 4682000.0 192.0 123.80 427.30 47.00 3.82 NO YES NO 

 B2811 0 0.53700E+01 319700.0 4665600.0 192.0 162.69 419.70 41.04 4.34 NO YES NO 

 B3518 0 0.16000E+00 324200.0 4682800.0 192.0 29.01 344.70 17.80 0.71 NO YES NO 

 B3533 0 0.43000E+00 323800.0 4686900.0 192.0 12.19 294.30 10.00 0.30 NO YES NO 

 B3567 0 0.21000E+00 323850.0 4683450.0 192.0 12.19 294.30 10.00 0.30 NO YES NO 

 N6631 0 0.24300E+01 322513.0 4685652.0 192.0 55.27 416.40 17.46 3.37 NO YES NO 

 *** VOLUME SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY 
 ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- 

 

 B_CH_RM1 0 0.89400E-01 322245.7 4685529.0 192.0 23.17 6.55 10.77 YES 

 B_CH_RM2 0 0.89400E-01 322239.4 4685541.5 192.0 23.17 6.55 10.77 YES 

 B_CH_RM3 0 0.89400E-01 322233.0 4685554.0 192.0 23.17 6.55 10.77 YES 

 B_CH_RM4 0 0.89400E-01 322226.5 4685567.0 192.0 23.17 6.55 10.77 YES 

 B_CH_RM5 0 0.89400E-01 322220.4 4685579.5 192.0 23.17 6.55 10.77 YES 

 C_CH_RM1 0 0.19500E+00 322190.4 4685634.5 192.0 29.26 6.59 13.61 YES 

 C_CH_RM2 0 0.19500E+00 322184.1 4685647.0 192.0 29.26 6.59 13.61 YES 

 C_CH_RM3 0 0.19500E+00 322177.7 4685659.5 192.0 29.26 6.59 13.61 YES 

 C_CH_RM4 0 0.19500E+00 322171.4 4685672.5 192.0 29.26 6.59 13.61 YES 

 BOF_RMW1 0 0.31400E+00 322007.2 4685043.5 192.0 65.53 8.62 30.20 YES 

 BOF_RMW2 0 0.31400E+00 321998.8 4685060.0 192.0 65.53 8.62 30.20 YES 

 BOF_RMW3 0 0.31400E+00 321990.5 4685076.5 192.0 65.53 8.62 30.20 YES 

 BOF_RMW4 0 0.31400E+00 321982.3 4685093.0 192.0 65.53 8.62 30.20 YES 

 BOF_RMW5 0 0.31400E+00 321973.8 4685109.5 192.0 65.53 8.62 30.20 YES 

 BOF_RMW6 0 0.31400E+00 321965.7 4685126.0 192.0 65.53 8.62 30.20 YES 

 BOF_RME1 0 0.31400E+00 322043.5 4685061.0 192.0 65.53 7.66 30.20 YES 

 BOF_RME2 0 0.31400E+00 322036.2 4685075.5 192.0 65.53 7.66 30.20 YES 

 BOF_RME3 0 0.31400E+00 322028.7 4685090.0 192.0 65.53 7.66 30.20 YES 

 BOF_RME4 0 0.31400E+00 322021.3 4685105.0 192.0 65.53 7.66 30.20 YES 

 BOF_RME5 0 0.31400E+00 322013.9 4685119.5 192.0 65.53 7.66 30.20 YES 

 BOF_RMN1 0 0.31400E+00 321991.2 4685164.5 192.0 57.61 4.47 26.51 YES 

 BOF_RMN2 0 0.31400E+00 321986.9 4685173.0 192.0 57.61 4.47 26.51 YES 

 BOF_RMN3 0 0.31400E+00 321982.7 4685181.5 192.0 57.61 4.47 26.51 YES 

 BOF_RMN4 0 0.31400E+00 321978.3 4685190.0 192.0 57.61 4.47 26.51 YES 

 BOF_RMN5 0 0.31400E+00 321973.8 4685199.0 192.0 57.61 4.47 26.51 YES 

 HND_SCF1 0 0.75600E-01 321254.4 4684513.0 192.0 31.39 7.10 14.60 YES 

 HND_SCF2 0 0.75600E-01 321247.6 4684527.0 192.0 31.39 7.10 14.60 YES 

 HND_SCF3 0 0.75600E-01 321240.7 4684540.5 192.0 31.39 7.10 14.60 YES 

 HND_SCF4 0 0.75600E-01 321233.8 4684554.0 192.0 31.39 7.10 14.60 YES 

 HND_SCF5 0 0.75600E-01 321227.0 4684568.0 192.0 31.39 7.10 14.60 YES 

GROUP ID SOURCE IDs 

 

 ALL BF_B_SS , BF_C_SS , B_CH_RM1, B_CH_RM2, B_CH_RM3, B_CH_RM4, B_CH_RM5, C_CH_RM1, C_CH_RM2, C_CH_RM3, 

C_CH_RM4, BFCCH_BS, 

 LM_UL_BH, HMTRN_BH, BOF_ESP , BOF_BH , BOF_RMW1, BOF_RMW2, BOF_RMW3, BOF_RMW4, BOF_RMW5, BOF_RMW6, 

BOF_RME1, BOF_RME2, 

 BOF_RME3, BOF_RME4, BOF_RME5, BOF_RMN1, BOF_RMN2, BOF_RMN3, BOF_RMN4, BOF_RMN5, DESLF_BH, LRF#1_S , 

LRF2_FLX, COKE_REC, 

 ANEAL_1S, ANEAL_2S, ANEAL_3S, ANEAL_4S, ANEAL_5S, ANEAL_6S, ANEAL_1N, ANEAL_2N, ANEAL_3N, ANEAL_4N, 

ANEAL_5N, RFURN1_1, 

 RFURN1_2, RFURN2_1, RFURN2_2, RFURN3_1, RFURN3_2, HND_SCF1, HND_SCF2, HND_SCF3, HND_SCF4, HND_SCF5, EU0099 

, EU0096 , 

 EU0095 , RG0130 , EU0096A , RG0133 , RG0132 , EU0095A , EU0120 , RG0133A , EU0118 , EU0076 , EU0076A 

, RG0130A , 

 RG0132A , A8648 , A9831 , B2132 , B2169 , B2810 , B2811 , B3518 , B3533 , B3567 , N6631 

, 

 A8640 BF_B_SS , BF_C_SS , B_CH_RM1, B_CH_RM2, B_CH_RM3, B_CH_RM4, B_CH_RM5, C_CH_RM1, C_CH_RM2, C_CH_RM3, 

C_CH_RM4, BFCCH_BS, 

 LM_UL_BH, HMTRN_BH, BOF_ESP , BOF_BH , BOF_RMW1, BOF_RMW2, BOF_RMW3, BOF_RMW4, BOF_RMW5, BOF_RMW6, 

BOF_RME1, BOF_RME2, 

 BOF_RME3, BOF_RME4, BOF_RME5, BOF_RMN1, BOF_RMN2, BOF_RMN3, BOF_RMN4, BOF_RMN5, DESLF_BH, LRF#1_S , 

LRF2_FLX, COKE_REC, 

 ANEAL_1S, ANEAL_2S, ANEAL_3S, ANEAL_4S, ANEAL_5S, ANEAL_6S, ANEAL_1N, ANEAL_2N, ANEAL_3N, ANEAL_4N, 

RFURN1_1, RFURN1_2, 

 RFURN2_1, RFURN2_2, RFURN3_1, RFURN3_2, HND_SCF1, HND_SCF2, HND_SCF3, HND_SCF4, HND_SCF5, 

 A7809 EU0099 , EU0096 , EU0095 , RG0130 , EU0096A , RG0133 , RG0132 , EU0095A , EU0120 , RG0133A , EU0118 

, EU0076 , 

 EU0076A , RG0130A , RG0132A , 

 A8648 A8648 , 

 A9831 A9831 , 

 B2132 B2132 , 

 B2169 B2169 , 
 

 B2810 B2810 , 

 B2811 B2811 , 

 

 

SUMMARY OF MAXIMUM ANNUAL ( 1 YRS) RESULTS *** 

 ALL 1ST HIGHEST VALUE IS 4.60659 AT ( 322805.00, 4685985.00 

 A8640 1ST HIGHEST VALUE IS 2.95616 AT ( 322805.00, 4685985.00 

 A7809 1ST HIGHEST VALUE IS 0.26618 AT ( 322805.00, 4685985.00 

 A8648 1ST HIGHEST VALUE IS 0.56898 AT ( 322805.00, 4685985.00 

 A9831 1ST HIGHEST VALUE IS 0.19489 AT ( 322805.00, 4685985.00 

 B2132 1ST HIGHEST VALUE IS 0.00403 AT ( 322805.00, 4685985.00 

 B2169 1ST HIGHEST VALUE IS 0.25617 AT ( 322805.00, 4685985.00 

 B2810 1ST HIGHEST VALUE IS 0.00447 AT ( 322805.00, 4685985.00 

 B2811 1ST HIGHEST VALUE IS 0.01419 AT ( 322805.00, 4685985.00 

 B3518 1ST HIGHEST VALUE IS 0.01233 AT ( 322805.00, 4685985.00 

 B3533 1ST HIGHEST VALUE IS 0.22609 AT ( 322805.00, 4685985.00 

 B3567 1ST HIGHEST VALUE IS 0.04949 AT ( 322805.00, 4685985.00 

 N6631 1ST HIGHEST VALUE IS 0.04971 AT ( 322805.00, 4685985.00 
2005 AERMOD SUMMARY – SWHS MONITOR LOCATION 

*** AERMOD - VERSION 07026 *** *** 2005 MONITOR IMPACTS *** 

04/28/08 

 *** POINT SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ 

EMIS RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR 

SCALAR 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) 

VARY BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- - - - - 

 

 BF_B_SS 0 0.60870E+00 322263.4 4685504.0 192.0 57.91 672.04 9.60 2.52 YES YES NO 

 BF_C_SS 0 0.10486E+01 322221.8 4685586.5 192.0 64.01 672.04 13.70 2.74 YES YES NO 

 BFCCH_BS 0 0.00000E+00 322262.1 4685580.0 192.0 60.96 338.71 19.96 2.74 YES YES NO 

 LM_UL_BH 0 0.75700E-01 322184.0 4684950.0 192.0 10.97 294.26 22.64 0.61 YES YES NO 

 HMTRN_BH 0 0.89800E-01 322024.8 4685203.0 192.0 8.23 352.60 0.05 1.75 YES YES NO 

 BOF_ESP 0 0.42495E+01 321932.5 4685047.5 192.0 64.92 422.04 18.84 5.18 YES YES NO 

 BOF_BH 0 0.00000E+00 322004.8 4685285.0 192.0 60.96 338.71 18.95 4.88 YES YES NO 

 DESLF_BH 0 0.11050E+00 321971.5 4685217.5 192.0 11.28 380.37 0.05 1.68 YES YES NO 

 LRF#1_S 0 0.85380E+00 321983.0 4684947.0 192.0 45.11 297.04 13.97 2.74 YES YES NO 

 LRF2_FLX 0 0.48790E+00 322097.1 4684808.5 192.0 45.72 433.15 17.97 1.83 YES YES NO 

 COKE_REC 0 0.24280E+00 322127.2 4684707.5 192.0 5.49 294.26 21.38 0.71 YES YES NO 

 ANEAL_1S 0 0.11600E-01 321846.1 4685170.0 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_2S 0 0.11600E-01 321826.2 4685209.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_3S 0 0.11600E-01 321806.3 4685249.0 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_4S 0 0.11600E-01 321786.4 4685288.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_5S 0 0.11600E-01 321766.5 4685328.0 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_6S 0 0.11600E-01 321746.6 4685367.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_1N 0 0.11600E-01 321726.0 4685387.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_2N 0 0.11600E-01 321713.8 4685412.0 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_3N 0 0.11600E-01 321701.4 4685436.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_4N 0 0.11600E-01 321689.1 4685461.0 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_5N 0 0.11600E-01 321676.7 4685485.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 RFURN1_1 0 0.17030E+00 320999.0 4685172.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 RFURN1_2 0 0.17030E+00 321004.0 4685162.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 RFURN2_1 0 0.17030E+00 321009.0 4685152.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 RFURN2_2 0 0.17030E+00 321014.0 4685141.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 RFURN3_1 0 0.17030E+00 321020.0 4685131.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 RFURN3_2 0 0.17030E+00 321025.0 4685120.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 EU0099 0 0.59750E+01 326027.0 4682852.0 192.0 96.01 477.60 4.28 5.03 NO YES NO 

 EU0096 0 0.26820E+01 326192.0 4683221.0 192.0 20.73 294.30 15.16 3.30 NO YES NO 

 EU0095 0 0.26310E+01 326475.0 4683520.0 192.0 19.81 294.30 10.35 3.05 NO YES NO 

 RG0130 0 0.23970E+01 326323.0 4683637.0 192.0 60.96 416.50 15.63 5.33 NO YES NO 

 EU0096A 0 0.12010E+01 326192.0 4683221.0 192.0 70.10 560.90 13.53 2.82 NO YES NO 

 RG0133 0 0.98900E+00 326299.0 4683107.0 192.0 26.82 560.90 7.48 2.97 NO YES NO 

 RG0132 0 0.87100E+00 326305.0 4683579.0 192.0 20.73 560.90 17.11 1.68 NO YES NO 

 EU0095A 0 0.84500E+00 326475.0 4683520.0 192.0 60.96 383.20 13.37 2.84 NO YES NO 

 EU0120 0 0.34600E+00 326309.0 4683644.0 192.0 33.22 544.30 21.15 1.40 NO YES NO 

 RG0133A 0 0.29900E+00 326299.0 4683107.0 192.0 26.82 560.90 7.48 2.97 NO YES NO 

 EU0118 0 0.24100E+00 326059.0 4683063.0 192.0 37.49 422.00 9.27 0.91 NO YES NO 

 EU0076 0 0.21800E+00 325960.0 4683058.0 192.0 31.09 477.60 1.62 4.27 NO YES NO 

 *** POINT SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ 

EMIS RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR 

SCALAR 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) 

VARY BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- - - - - 

 

 EU0076A 0 0.16500E+00 326087.0 4683007.0 192.0 31.09 477.60 1.62 4.27 NO YES NO 

 RG0130A 0 0.15900E+00 326323.0 4683637.0 192.0 60.96 416.50 15.63 5.33 NO YES NO 

 RG0132A 0 0.14700E+00 326305.0 4683579.0 192.0 20.73 560.90 17.11 1.68 NO YES NO 

 A8648 0 0.49000E+00 321801.0 4686168.0 192.0 12.31 295.70 10.14 0.31 NO YES NO 

 A9831 0 0.57000E+01 322000.0 4683150.0 192.0 49.43 455.50 10.24 1.91 NO YES NO 

 B2132 0 0.36000E+00 322800.0 4675000.0 192.0 46.94 415.70 8.71 2.44 NO YES NO 

 B2169 0 0.20500E+01 324525.0 4682560.0 192.0 12.19 294.30 10.00 0.30 NO YES NO 

 B2810 0 0.12300E+01 325800.0 4682000.0 192.0 123.80 427.30 47.00 3.82 NO YES NO 

 B2811 0 0.53700E+01 319700.0 4665600.0 192.0 162.69 419.70 41.04 4.34 NO YES NO 

 B3518 0 0.16000E+00 324200.0 4682800.0 192.0 29.01 344.70 17.80 0.71 NO YES NO 

 B3533 0 0.43000E+00 323800.0 4686900.0 192.0 12.19 294.30 10.00 0.30 NO YES NO 

 B3567 0 0.21000E+00 323850.0 4683450.0 192.0 12.19 294.30 10.00 0.30 NO YES NO 

 N6631 0 0.24300E+01 322513.0 4685652.0 192.0 55.27 416.40 17.46 3.37 NO YES NO 

 *** VOLUME SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY 
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- 

 

 B_CH_RM1 0 0.89400E-01 322245.7 4685529.0 192.0 23.17 6.55 10.77 YES 

 B_CH_RM2 0 0.89400E-01 322239.4 4685541.5 192.0 23.17 6.55 10.77 YES 

 B_CH_RM3 0 0.89400E-01 322233.0 4685554.0 192.0 23.17 6.55 10.77 YES 

 B_CH_RM4 0 0.89400E-01 322226.5 4685567.0 192.0 23.17 6.55 10.77 YES 

 B_CH_RM5 0 0.89400E-01 322220.4 4685579.5 192.0 23.17 6.55 10.77 YES 

 C_CH_RM1 0 0.19500E+00 322190.4 4685634.5 192.0 29.26 6.59 13.61 YES 

 C_CH_RM2 0 0.19500E+00 322184.1 4685647.0 192.0 29.26 6.59 13.61 YES 

 C_CH_RM3 0 0.19500E+00 322177.7 4685659.5 192.0 29.26 6.59 13.61 YES 

 C_CH_RM4 0 0.19500E+00 322171.4 4685672.5 192.0 29.26 6.59 13.61 YES 

 BOF_RMW1 0 0.31400E+00 322007.2 4685043.5 192.0 65.53 8.62 30.20 YES 

 BOF_RMW2 0 0.31400E+00 321998.8 4685060.0 192.0 65.53 8.62 30.20 YES 

 BOF_RMW3 0 0.31400E+00 321990.5 4685076.5 192.0 65.53 8.62 30.20 YES 

 BOF_RMW4 0 0.31400E+00 321982.3 4685093.0 192.0 65.53 8.62 30.20 YES 

 BOF_RMW5 0 0.31400E+00 321973.8 4685109.5 192.0 65.53 8.62 30.20 YES 

 BOF_RMW6 0 0.31400E+00 321965.7 4685126.0 192.0 65.53 8.62 30.20 YES 

 BOF_RME1 0 0.31400E+00 322043.5 4685061.0 192.0 65.53 7.66 30.20 YES 

 BOF_RME2 0 0.31400E+00 322036.2 4685075.5 192.0 65.53 7.66 30.20 YES 

 BOF_RME3 0 0.31400E+00 322028.7 4685090.0 192.0 65.53 7.66 30.20 YES 

 BOF_RME4 0 0.31400E+00 322021.3 4685105.0 192.0 65.53 7.66 30.20 YES 

 BOF_RME5 0 0.31400E+00 322013.9 4685119.5 192.0 65.53 7.66 30.20 YES 

 BOF_RMN1 0 0.31400E+00 321991.2 4685164.5 192.0 57.61 4.47 26.51 YES 

 BOF_RMN2 0 0.31400E+00 321986.9 4685173.0 192.0 57.61 4.47 26.51 YES 

 BOF_RMN3 0 0.31400E+00 321982.7 4685181.5 192.0 57.61 4.47 26.51 YES 

 BOF_RMN4 0 0.31400E+00 321978.3 4685190.0 192.0 57.61 4.47 26.51 YES 

 BOF_RMN5 0 0.31400E+00 321973.8 4685199.0 192.0 57.61 4.47 26.51 YES 

 HND_SCF1 0 0.75600E-01 321254.4 4684513.0 192.0 31.39 7.10 14.60 YES 

 HND_SCF2 0 0.75600E-01 321247.6 4684527.0 192.0 31.39 7.10 14.60 YES 

 HND_SCF3 0 0.75600E-01 321240.7 4684540.5 192.0 31.39 7.10 14.60 YES 

 HND_SCF4 0 0.75600E-01 321233.8 4684554.0 192.0 31.39 7.10 14.60 YES 

 HND_SCF5 0 0.75600E-01 321227.0 4684568.0 192.0 31.39 7.10 14.60 YES 

GROUP ID SOURCE IDs 

 

 ALL BF_B_SS , BF_C_SS , B_CH_RM1, B_CH_RM2, B_CH_RM3, B_CH_RM4, B_CH_RM5, C_CH_RM1, C_CH_RM2, C_CH_RM3, 

C_CH_RM4, BFCCH_BS, 

 LM_UL_BH, HMTRN_BH, BOF_ESP , BOF_BH , BOF_RMW1, BOF_RMW2, BOF_RMW3, BOF_RMW4, BOF_RMW5, BOF_RMW6, 

BOF_RME1, BOF_RME2, 

 BOF_RME3, BOF_RME4, BOF_RME5, BOF_RMN1, BOF_RMN2, BOF_RMN3, BOF_RMN4, BOF_RMN5, DESLF_BH, LRF#1_S , 

LRF2_FLX, COKE_REC, 

 ANEAL_1S, ANEAL_2S, ANEAL_3S, ANEAL_4S, ANEAL_5S, ANEAL_6S, ANEAL_1N, ANEAL_2N, ANEAL_3N, ANEAL_4N, 

ANEAL_5N, RFURN1_1, 

 RFURN1_2, RFURN2_1, RFURN2_2, RFURN3_1, RFURN3_2, HND_SCF1, HND_SCF2, HND_SCF3, HND_SCF4, HND_SCF5, EU0099 

, EU0096 , 

 EU0095 , RG0130 , EU0096A , RG0133 , RG0132 , EU0095A , EU0120 , RG0133A , EU0118 , EU0076 , EU0076A 

, RG0130A , 

 RG0132A , A8648 , A9831 , B2132 , B2169 , B2810 , B2811 , B3518 , B3533 , B3567 , N6631 

, 

 A8640 BF_B_SS , BF_C_SS , B_CH_RM1, B_CH_RM2, B_CH_RM3, B_CH_RM4, B_CH_RM5, C_CH_RM1, C_CH_RM2, C_CH_RM3, 

C_CH_RM4, BFCCH_BS, 

 LM_UL_BH, HMTRN_BH, BOF_ESP , BOF_BH , BOF_RMW1, BOF_RMW2, BOF_RMW3, BOF_RMW4, BOF_RMW5, BOF_RMW6, 

BOF_RME1, BOF_RME2, 

 BOF_RME3, BOF_RME4, BOF_RME5, BOF_RMN1, BOF_RMN2, BOF_RMN3, BOF_RMN4, BOF_RMN5, DESLF_BH, LRF#1_S , 

LRF2_FLX, COKE_REC, 

 ANEAL_1S, ANEAL_2S, ANEAL_3S, ANEAL_4S, ANEAL_5S, ANEAL_6S, ANEAL_1N, ANEAL_2N, ANEAL_3N, ANEAL_4N, 

RFURN1_1, RFURN1_2, 

 RFURN2_1, RFURN2_2, RFURN3_1, RFURN3_2, HND_SCF1, HND_SCF2, HND_SCF3, HND_SCF4, HND_SCF5, 

 A7809 EU0099 , EU0096 , EU0095 , RG0130 , EU0096A , RG0133 , RG0132 , EU0095A , EU0120 , RG0133A , EU0118 

, EU0076 , 

 EU0076A , RG0130A , RG0132A , 

 A8648 A8648 , 

 A9831 A9831 , 

 B2132 B2132 , 

 B2169 B2169 , 
 B2810 B2810 , 

 

 B2811 B2811 , 

 

 

SUMMARY OF MAXIMUM ANNUAL ( 1 YRS) RESULTS *** 

 ALL 1ST HIGHEST VALUE IS 2.59188 AT ( 326344.00, 4685318.00 

 A8640 1ST HIGHEST VALUE IS 0.50181 AT ( 326344.00, 4685318.00 

 A7809 1ST HIGHEST VALUE IS 1.32983 AT ( 326344.00, 4685318.00 

 A8648 1ST HIGHEST VALUE IS 0.05653 AT ( 326344.00, 4685318.00 

 A9831 1ST HIGHEST VALUE IS 0.12335 AT ( 326344.00, 4685318.00 

 B2132 1ST HIGHEST VALUE IS 0.00528 AT ( 326344.00, 4685318.00 

 B2169 1ST HIGHEST VALUE IS 0.37947 AT ( 326344.00, 4685318.00 

 B2810 1ST HIGHEST VALUE IS 0.00836 AT ( 326344.00, 4685318.00 

 B2811 1ST HIGHEST VALUE IS 0.01458 AT ( 326344.00, 4685318.00 

 B3518 1ST HIGHEST VALUE IS 0.01348 AT ( 326344.00, 4685318.00 

 B3533 1ST HIGHEST VALUE IS 0.09325 AT ( 326344.00, 4685318.00 

 B3567 1ST HIGHEST VALUE IS 0.04027 AT ( 326344.00, 4685318.00 

 N6631 1ST HIGHEST VALUE IS 0.02793 AT ( 326344.00, 4685318.00 
2005 AERMOD SUMMARY – ALLEN PARK MONITOR 

LOCATION 

*** AERMOD - VERSION 07026 *** *** 2005 MONITOR IMPACTS *** 

04/28/08 

 *** POINT SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ 

EMIS RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR 

SCALAR 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) 

VARY BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- - - - - 

 

 BF_B_SS 0 0.60870E+00 322263.4 4685504.0 192.0 57.91 672.04 9.60 2.52 YES YES NO 

 BF_C_SS 0 0.10486E+01 322221.8 4685586.5 192.0 64.01 672.04 13.70 2.74 YES YES NO 

 BFCCH_BS 0 0.00000E+00 322262.1 4685580.0 192.0 60.96 338.71 19.96 2.74 YES YES NO 

 LM_UL_BH 0 0.75700E-01 322184.0 4684950.0 192.0 10.97 294.26 22.64 0.61 YES YES NO 

 HMTRN_BH 0 0.89800E-01 322024.8 4685203.0 192.0 8.23 352.60 0.05 1.75 YES YES NO 

 BOF_ESP 0 0.42495E+01 321932.5 4685047.5 192.0 64.92 422.04 18.84 5.18 YES YES NO 

 BOF_BH 0 0.00000E+00 322004.8 4685285.0 192.0 60.96 338.71 18.95 4.88 YES YES NO 

 DESLF_BH 0 0.11050E+00 321971.5 4685217.5 192.0 11.28 380.37 0.05 1.68 YES YES NO 

 LRF#1_S 0 0.85380E+00 321983.0 4684947.0 192.0 45.11 297.04 13.97 2.74 YES YES NO 

 LRF2_FLX 0 0.48790E+00 322097.1 4684808.5 192.0 45.72 433.15 17.97 1.83 YES YES NO 

 COKE_REC 0 0.24280E+00 322127.2 4684707.5 192.0 5.49 294.26 21.38 0.71 YES YES NO 

 ANEAL_1S 0 0.11600E-01 321846.1 4685170.0 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_2S 0 0.11600E-01 321826.2 4685209.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_3S 0 0.11600E-01 321806.3 4685249.0 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_4S 0 0.11600E-01 321786.4 4685288.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_5S 0 0.11600E-01 321766.5 4685328.0 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_6S 0 0.11600E-01 321746.6 4685367.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_1N 0 0.11600E-01 321726.0 4685387.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_2N 0 0.11600E-01 321713.8 4685412.0 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_3N 0 0.11600E-01 321701.4 4685436.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_4N 0 0.11600E-01 321689.1 4685461.0 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_5N 0 0.11600E-01 321676.7 4685485.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 RFURN1_1 0 0.17030E+00 320999.0 4685172.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 RFURN1_2 0 0.17030E+00 321004.0 4685162.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 RFURN2_1 0 0.17030E+00 321009.0 4685152.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 RFURN2_2 0 0.17030E+00 321014.0 4685141.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 RFURN3_1 0 0.17030E+00 321020.0 4685131.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 RFURN3_2 0 0.17030E+00 321025.0 4685120.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 EU0099 0 0.59750E+01 326027.0 4682852.0 192.0 96.01 477.60 4.28 5.03 NO YES NO 

 EU0096 0 0.26820E+01 326192.0 4683221.0 192.0 20.73 294.30 15.16 3.30 NO YES NO 

 EU0095 0 0.26310E+01 326475.0 4683520.0 192.0 19.81 294.30 10.35 3.05 NO YES NO 

 RG0130 0 0.23970E+01 326323.0 4683637.0 192.0 60.96 416.50 15.63 5.33 NO YES NO 

 EU0096A 0 0.12010E+01 326192.0 4683221.0 192.0 70.10 560.90 13.53 2.82 NO YES NO 

 RG0133 0 0.98900E+00 326299.0 4683107.0 192.0 26.82 560.90 7.48 2.97 NO YES NO 

 RG0132 0 0.87100E+00 326305.0 4683579.0 192.0 20.73 560.90 17.11 1.68 NO YES NO 

 EU0095A 0 0.84500E+00 326475.0 4683520.0 192.0 60.96 383.20 13.37 2.84 NO YES NO 

 EU0120 0 0.34600E+00 326309.0 4683644.0 192.0 33.22 544.30 21.15 1.40 NO YES NO 

 RG0133A 0 0.29900E+00 326299.0 4683107.0 192.0 26.82 560.90 7.48 2.97 NO YES NO 

 EU0118 0 0.24100E+00 326059.0 4683063.0 192.0 37.49 422.00 9.27 0.91 NO YES NO 

 EU0076 0 0.21800E+00 325960.0 4683058.0 192.0 31.09 477.60 1.62 4.27 NO YES NO 

 *** POINT SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ 

EMIS RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR 

SCALAR 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) 

VARY BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- - - - - 

 

 EU0076A 0 0.16500E+00 326087.0 4683007.0 192.0 31.09 477.60 1.62 4.27 NO YES NO 

 RG0130A 0 0.15900E+00 326323.0 4683637.0 192.0 60.96 416.50 15.63 5.33 NO YES NO 

 RG0132A 0 0.14700E+00 326305.0 4683579.0 192.0 20.73 560.90 17.11 1.68 NO YES NO 

 A8648 0 0.49000E+00 321801.0 4686168.0 192.0 12.31 295.70 10.14 0.31 NO YES NO 

 A9831 0 0.57000E+01 322000.0 4683150.0 192.0 49.43 455.50 10.24 1.91 NO YES NO 

 B2132 0 0.36000E+00 322800.0 4675000.0 192.0 46.94 415.70 8.71 2.44 NO YES NO 

 B2169 0 0.20500E+01 324525.0 4682560.0 192.0 12.19 294.30 10.00 0.30 NO YES NO 

 B2810 0 0.12300E+01 325800.0 4682000.0 192.0 123.80 427.30 47.00 3.82 NO YES NO 

 B2811 0 0.53700E+01 319700.0 4665600.0 192.0 162.69 419.70 41.04 4.34 NO YES NO 

 B3518 0 0.16000E+00 324200.0 4682800.0 192.0 29.01 344.70 17.80 0.71 NO YES NO 

 B3533 0 0.43000E+00 323800.0 4686900.0 192.0 12.19 294.30 10.00 0.30 NO YES NO 

 B3567 0 0.21000E+00 323850.0 4683450.0 192.0 12.19 294.30 10.00 0.30 NO YES NO 

 N6631 0 0.24300E+01 322513.0 4685652.0 192.0 55.27 416.40 17.46 3.37 NO YES NO 

 *** VOLUME SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE 
 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- 

 

 B_CH_RM1 0 0.89400E-01 322245.7 4685529.0 192.0 23.17 6.55 10.77 YES 

 B_CH_RM2 0 0.89400E-01 322239.4 4685541.5 192.0 23.17 6.55 10.77 YES 

 B_CH_RM3 0 0.89400E-01 322233.0 4685554.0 192.0 23.17 6.55 10.77 YES 

 B_CH_RM4 0 0.89400E-01 322226.5 4685567.0 192.0 23.17 6.55 10.77 YES 

 B_CH_RM5 0 0.89400E-01 322220.4 4685579.5 192.0 23.17 6.55 10.77 YES 

 C_CH_RM1 0 0.19500E+00 322190.4 4685634.5 192.0 29.26 6.59 13.61 YES 

 C_CH_RM2 0 0.19500E+00 322184.1 4685647.0 192.0 29.26 6.59 13.61 YES 

 C_CH_RM3 0 0.19500E+00 322177.7 4685659.5 192.0 29.26 6.59 13.61 YES 

 C_CH_RM4 0 0.19500E+00 322171.4 4685672.5 192.0 29.26 6.59 13.61 YES 

 BOF_RMW1 0 0.31400E+00 322007.2 4685043.5 192.0 65.53 8.62 30.20 YES 

 BOF_RMW2 0 0.31400E+00 321998.8 4685060.0 192.0 65.53 8.62 30.20 YES 

 BOF_RMW3 0 0.31400E+00 321990.5 4685076.5 192.0 65.53 8.62 30.20 YES 

 BOF_RMW4 0 0.31400E+00 321982.3 4685093.0 192.0 65.53 8.62 30.20 YES 

 BOF_RMW5 0 0.31400E+00 321973.8 4685109.5 192.0 65.53 8.62 30.20 YES 

 BOF_RMW6 0 0.31400E+00 321965.7 4685126.0 192.0 65.53 8.62 30.20 YES 

 BOF_RME1 0 0.31400E+00 322043.5 4685061.0 192.0 65.53 7.66 30.20 YES 

 BOF_RME2 0 0.31400E+00 322036.2 4685075.5 192.0 65.53 7.66 30.20 YES 

 BOF_RME3 0 0.31400E+00 322028.7 4685090.0 192.0 65.53 7.66 30.20 YES 

 BOF_RME4 0 0.31400E+00 322021.3 4685105.0 192.0 65.53 7.66 30.20 YES 

 BOF_RME5 0 0.31400E+00 322013.9 4685119.5 192.0 65.53 7.66 30.20 YES 

 BOF_RMN1 0 0.31400E+00 321991.2 4685164.5 192.0 57.61 4.47 26.51 YES 

 BOF_RMN2 0 0.31400E+00 321986.9 4685173.0 192.0 57.61 4.47 26.51 YES 

 BOF_RMN3 0 0.31400E+00 321982.7 4685181.5 192.0 57.61 4.47 26.51 YES 

 BOF_RMN4 0 0.31400E+00 321978.3 4685190.0 192.0 57.61 4.47 26.51 YES 

 BOF_RMN5 0 0.31400E+00 321973.8 4685199.0 192.0 57.61 4.47 26.51 YES 

 HND_SCF1 0 0.75600E-01 321254.4 4684513.0 192.0 31.39 7.10 14.60 YES 

 HND_SCF2 0 0.75600E-01 321247.6 4684527.0 192.0 31.39 7.10 14.60 YES 

 HND_SCF3 0 0.75600E-01 321240.7 4684540.5 192.0 31.39 7.10 14.60 YES 

 HND_SCF4 0 0.75600E-01 321233.8 4684554.0 192.0 31.39 7.10 14.60 YES 

 HND_SCF5 0 0.75600E-01 321227.0 4684568.0 192.0 31.39 7.10 14.60 YES 

GROUP ID SOURCE IDs 

 

 ALL BF_B_SS , BF_C_SS , B_CH_RM1, B_CH_RM2, B_CH_RM3, B_CH_RM4, B_CH_RM5, C_CH_RM1, C_CH_RM2, C_CH_RM3, 

C_CH_RM4, BFCCH_BS, 

 LM_UL_BH, HMTRN_BH, BOF_ESP , BOF_BH , BOF_RMW1, BOF_RMW2, BOF_RMW3, BOF_RMW4, BOF_RMW5, BOF_RMW6, 

BOF_RME1, BOF_RME2, 

 BOF_RME3, BOF_RME4, BOF_RME5, BOF_RMN1, BOF_RMN2, BOF_RMN3, BOF_RMN4, BOF_RMN5, DESLF_BH, LRF#1_S , 

LRF2_FLX, COKE_REC, 

 ANEAL_1S, ANEAL_2S, ANEAL_3S, ANEAL_4S, ANEAL_5S, ANEAL_6S, ANEAL_1N, ANEAL_2N, ANEAL_3N, ANEAL_4N, 

ANEAL_5N, RFURN1_1, 

 RFURN1_2, RFURN2_1, RFURN2_2, RFURN3_1, RFURN3_2, HND_SCF1, HND_SCF2, HND_SCF3, HND_SCF4, HND_SCF5, EU0099 

, EU0096 , 

 EU0095 , RG0130 , EU0096A , RG0133 , RG0132 , EU0095A , EU0120 , RG0133A , EU0118 , EU0076 , EU0076A 

, RG0130A , 

 RG0132A , A8648 , A9831 , B2132 , B2169 , B2810 , B2811 , B3518 , B3533 , B3567 , N6631 

, 

 A8640 BF_B_SS , BF_C_SS , B_CH_RM1, B_CH_RM2, B_CH_RM3, B_CH_RM4, B_CH_RM5, C_CH_RM1, C_CH_RM2, C_CH_RM3, 

C_CH_RM4, BFCCH_BS, 

 LM_UL_BH, HMTRN_BH, BOF_ESP , BOF_BH , BOF_RMW1, BOF_RMW2, BOF_RMW3, BOF_RMW4, BOF_RMW5, BOF_RMW6, 

BOF_RME1, BOF_RME2, 

 BOF_RME3, BOF_RME4, BOF_RME5, BOF_RMN1, BOF_RMN2, BOF_RMN3, BOF_RMN4, BOF_RMN5, DESLF_BH, LRF#1_S , 

LRF2_FLX, COKE_REC, 

 ANEAL_1S, ANEAL_2S, ANEAL_3S, ANEAL_4S, ANEAL_5S, ANEAL_6S, ANEAL_1N, ANEAL_2N, ANEAL_3N, ANEAL_4N, 

RFURN1_1, RFURN1_2, 

 RFURN2_1, RFURN2_2, RFURN3_1, RFURN3_2, HND_SCF1, HND_SCF2, HND_SCF3, HND_SCF4, HND_SCF5, 

 A7809 EU0099 , EU0096 , EU0095 , RG0130 , EU0096A , RG0133 , RG0132 , EU0095A , EU0120 , RG0133A , EU0118 

, EU0076 , 

 EU0076A , RG0130A , RG0132A , 

 A8648 A8648 , 

 A9831 A9831 , 

 B2132 B2132 , 

 B2169 B2169 , 
 

 B2810 B2810 , 

 B2811 B2811 , 

 

 

SUMMARY OF MAXIMUM ANNUAL ( 1 YRS) RESULTS *** 

 ALL 1ST HIGHEST VALUE IS 0.65418 AT ( 317758.00, 4677306.00 

 A8640 1ST HIGHEST VALUE IS 0.30438 AT ( 317758.00, 4677306.00 

 A7809 1ST HIGHEST VALUE IS 0.12431 AT ( 317758.00, 4677306.00 

 A8648 1ST HIGHEST VALUE IS 0.02034 AT ( 317758.00, 4677306.00 

 A9831 1ST HIGHEST VALUE IS 0.08876 AT ( 317758.00, 4677306.00 

 B2132 1ST HIGHEST VALUE IS 0.00370 AT ( 317758.00, 4677306.00 

 B2169 1ST HIGHEST VALUE IS 0.05075 AT ( 317758.00, 4677306.00 

 B2810 1ST HIGHEST VALUE IS 0.00364 AT ( 317758.00, 4677306.00 

 B2811 1ST HIGHEST VALUE IS 0.01773 AT ( 317758.00, 4677306.00 

 B3518 1ST HIGHEST VALUE IS 0.00303 AT ( 317758.00, 4677306.00 

 B3533 1ST HIGHEST VALUE IS 0.01187 AT ( 317758.00, 4677306.00 

 B3567 1ST HIGHEST VALUE IS 0.00617 AT ( 317758.00, 4677306.00 

 N6631 1ST HIGHEST VALUE IS 0.01956 AT ( 317758.00, 4677306.00 
2005 AERMOD SUMMARY – WYANDOTTE MONITOR 

LOCATION 

*** AERMOD - VERSION 07026 *** *** 2005 MONITOR IMPACTS *** 

04/28/08 

 *** POINT SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ 

EMIS RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR 

SCALAR 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) 

VARY BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- - - - - 

 

 BF_B_SS 0 0.60870E+00 322263.4 4685504.0 192.0 57.91 672.04 9.60 2.52 YES YES NO 

 BF_C_SS 0 0.10486E+01 322221.8 4685586.5 192.0 64.01 672.04 13.70 2.74 YES YES NO 

 BFCCH_BS 0 0.00000E+00 322262.1 4685580.0 192.0 60.96 338.71 19.96 2.74 YES YES NO 

 LM_UL_BH 0 0.75700E-01 322184.0 4684950.0 192.0 10.97 294.26 22.64 0.61 YES YES NO 

 HMTRN_BH 0 0.89800E-01 322024.8 4685203.0 192.0 8.23 352.60 0.05 1.75 YES YES NO 

 BOF_ESP 0 0.42495E+01 321932.5 4685047.5 192.0 64.92 422.04 18.84 5.18 YES YES NO 

 BOF_BH 0 0.00000E+00 322004.8 4685285.0 192.0 60.96 338.71 18.95 4.88 YES YES NO 

 DESLF_BH 0 0.11050E+00 321971.5 4685217.5 192.0 11.28 380.37 0.05 1.68 YES YES NO 

 LRF#1_S 0 0.85380E+00 321983.0 4684947.0 192.0 45.11 297.04 13.97 2.74 YES YES NO 

 LRF2_FLX 0 0.48790E+00 322097.1 4684808.5 192.0 45.72 433.15 17.97 1.83 YES YES NO 

 COKE_REC 0 0.24280E+00 322127.2 4684707.5 192.0 5.49 294.26 21.38 0.71 YES YES NO 

 ANEAL_1S 0 0.11600E-01 321846.1 4685170.0 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_2S 0 0.11600E-01 321826.2 4685209.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_3S 0 0.11600E-01 321806.3 4685249.0 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_4S 0 0.11600E-01 321786.4 4685288.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_5S 0 0.11600E-01 321766.5 4685328.0 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_6S 0 0.11600E-01 321746.6 4685367.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_1N 0 0.11600E-01 321726.0 4685387.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_2N 0 0.11600E-01 321713.8 4685412.0 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_3N 0 0.11600E-01 321701.4 4685436.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_4N 0 0.11600E-01 321689.1 4685461.0 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 ANEAL_5N 0 0.11600E-01 321676.7 4685485.5 192.0 21.34 1060.93 0.05 0.76 YES YES NO 

 RFURN1_1 0 0.17030E+00 320999.0 4685172.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 RFURN1_2 0 0.17030E+00 321004.0 4685162.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 RFURN2_1 0 0.17030E+00 321009.0 4685152.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 RFURN2_2 0 0.17030E+00 321014.0 4685141.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 RFURN3_1 0 0.17030E+00 321020.0 4685131.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 RFURN3_2 0 0.17030E+00 321025.0 4685120.0 192.0 63.40 922.04 4.39 4.27 YES YES NO 

 EU0099 0 0.59750E+01 326027.0 4682852.0 192.0 96.01 477.60 4.28 5.03 NO YES NO 

 EU0096 0 0.26820E+01 326192.0 4683221.0 192.0 20.73 294.30 15.16 3.30 NO YES NO 

 EU0095 0 0.26310E+01 326475.0 4683520.0 192.0 19.81 294.30 10.35 3.05 NO YES NO 

 RG0130 0 0.23970E+01 326323.0 4683637.0 192.0 60.96 416.50 15.63 5.33 NO YES NO 

 EU0096A 0 0.12010E+01 326192.0 4683221.0 192.0 70.10 560.90 13.53 2.82 NO YES NO 

 RG0133 0 0.98900E+00 326299.0 4683107.0 192.0 26.82 560.90 7.48 2.97 NO YES NO 

 RG0132 0 0.87100E+00 326305.0 4683579.0 192.0 20.73 560.90 17.11 1.68 NO YES NO 

 EU0095A 0 0.84500E+00 326475.0 4683520.0 192.0 60.96 383.20 13.37 2.84 NO YES NO 

 EU0120 0 0.34600E+00 326309.0 4683644.0 192.0 33.22 544.30 21.15 1.40 NO YES NO 

 RG0133A 0 0.29900E+00 326299.0 4683107.0 192.0 26.82 560.90 7.48 2.97 NO YES NO 

 EU0118 0 0.24100E+00 326059.0 4683063.0 192.0 37.49 422.00 9.27 0.91 NO YES NO 

 EU0076 0 0.21800E+00 325960.0 4683058.0 192.0 31.09 477.60 1.62 4.27 NO YES NO 

 *** POINT SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ 

EMIS RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR 

SCALAR 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) 

VARY BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- - - - - 

 

 EU0076A 0 0.16500E+00 326087.0 4683007.0 192.0 31.09 477.60 1.62 4.27 NO YES NO 

 RG0130A 0 0.15900E+00 326323.0 4683637.0 192.0 60.96 416.50 15.63 5.33 NO YES NO 

 RG0132A 0 0.14700E+00 326305.0 4683579.0 192.0 20.73 560.90 17.11 1.68 NO YES NO 

 A8648 0 0.49000E+00 321801.0 4686168.0 192.0 12.31 295.70 10.14 0.31 NO YES NO 

 A9831 0 0.57000E+01 322000.0 4683150.0 192.0 49.43 455.50 10.24 1.91 NO YES NO 

 B2132 0 0.36000E+00 322800.0 4675000.0 192.0 46.94 415.70 8.71 2.44 NO YES NO 

 B2169 0 0.20500E+01 324525.0 4682560.0 192.0 12.19 294.30 10.00 0.30 NO YES NO 

 B2810 0 0.12300E+01 325800.0 4682000.0 192.0 123.80 427.30 47.00 3.82 NO YES NO 

 B2811 0 0.53700E+01 319700.0 4665600.0 192.0 162.69 419.70 41.04 4.34 NO YES NO 

 B3518 0 0.16000E+00 324200.0 4682800.0 192.0 29.01 344.70 17.80 0.71 NO YES NO 

 B3533 0 0.43000E+00 323800.0 4686900.0 192.0 12.19 294.30 10.00 0.30 NO YES NO 

 B3567 0 0.21000E+00 323850.0 4683450.0 192.0 12.19 294.30 10.00 0.30 NO YES NO 

 N6631 0 0.24300E+01 322513.0 4685652.0 192.0 55.27 416.40 17.46 3.37 NO YES NO 

 *** VOLUME SOURCE DATA *** 

 
 NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- 

 

 B_CH_RM1 0 0.89400E-01 322245.7 4685529.0 192.0 23.17 6.55 10.77 YES 

 B_CH_RM2 0 0.89400E-01 322239.4 4685541.5 192.0 23.17 6.55 10.77 YES 

 B_CH_RM3 0 0.89400E-01 322233.0 4685554.0 192.0 23.17 6.55 10.77 YES 

 B_CH_RM4 0 0.89400E-01 322226.5 4685567.0 192.0 23.17 6.55 10.77 YES 

 B_CH_RM5 0 0.89400E-01 322220.4 4685579.5 192.0 23.17 6.55 10.77 YES 

 C_CH_RM1 0 0.19500E+00 322190.4 4685634.5 192.0 29.26 6.59 13.61 YES 

 C_CH_RM2 0 0.19500E+00 322184.1 4685647.0 192.0 29.26 6.59 13.61 YES 

 C_CH_RM3 0 0.19500E+00 322177.7 4685659.5 192.0 29.26 6.59 13.61 YES 

 C_CH_RM4 0 0.19500E+00 322171.4 4685672.5 192.0 29.26 6.59 13.61 YES 

 BOF_RMW1 0 0.31400E+00 322007.2 4685043.5 192.0 65.53 8.62 30.20 YES 

 BOF_RMW2 0 0.31400E+00 321998.8 4685060.0 192.0 65.53 8.62 30.20 YES 

 BOF_RMW3 0 0.31400E+00 321990.5 4685076.5 192.0 65.53 8.62 30.20 YES 

 BOF_RMW4 0 0.31400E+00 321982.3 4685093.0 192.0 65.53 8.62 30.20 YES 

 BOF_RMW5 0 0.31400E+00 321973.8 4685109.5 192.0 65.53 8.62 30.20 YES 

 BOF_RMW6 0 0.31400E+00 321965.7 4685126.0 192.0 65.53 8.62 30.20 YES 

 BOF_RME1 0 0.31400E+00 322043.5 4685061.0 192.0 65.53 7.66 30.20 YES 

 BOF_RME2 0 0.31400E+00 322036.2 4685075.5 192.0 65.53 7.66 30.20 YES 

 BOF_RME3 0 0.31400E+00 322028.7 4685090.0 192.0 65.53 7.66 30.20 YES 

 BOF_RME4 0 0.31400E+00 322021.3 4685105.0 192.0 65.53 7.66 30.20 YES 

 BOF_RME5 0 0.31400E+00 322013.9 4685119.5 192.0 65.53 7.66 30.20 YES 

 BOF_RMN1 0 0.31400E+00 321991.2 4685164.5 192.0 57.61 4.47 26.51 YES 

 BOF_RMN2 0 0.31400E+00 321986.9 4685173.0 192.0 57.61 4.47 26.51 YES 

 BOF_RMN3 0 0.31400E+00 321982.7 4685181.5 192.0 57.61 4.47 26.51 YES 

 BOF_RMN4 0 0.31400E+00 321978.3 4685190.0 192.0 57.61 4.47 26.51 YES 

 BOF_RMN5 0 0.31400E+00 321973.8 4685199.0 192.0 57.61 4.47 26.51 YES 

 HND_SCF1 0 0.75600E-01 321254.4 4684513.0 192.0 31.39 7.10 14.60 YES 

 HND_SCF2 0 0.75600E-01 321247.6 4684527.0 192.0 31.39 7.10 14.60 YES 

 HND_SCF3 0 0.75600E-01 321240.7 4684540.5 192.0 31.39 7.10 14.60 YES 

 HND_SCF4 0 0.75600E-01 321233.8 4684554.0 192.0 31.39 7.10 14.60 YES 

 HND_SCF5 0 0.75600E-01 321227.0 4684568.0 192.0 31.39 7.10 14.60 YES 

GROUP ID SOURCE IDs 

 

 ALL BF_B_SS , BF_C_SS , B_CH_RM1, B_CH_RM2, B_CH_RM3, B_CH_RM4, B_CH_RM5, C_CH_RM1, C_CH_RM2, C_CH_RM3, 

C_CH_RM4, BFCCH_BS, 

 LM_UL_BH, HMTRN_BH, BOF_ESP , BOF_BH , BOF_RMW1, BOF_RMW2, BOF_RMW3, BOF_RMW4, BOF_RMW5, BOF_RMW6, 

BOF_RME1, BOF_RME2, 

 BOF_RME3, BOF_RME4, BOF_RME5, BOF_RMN1, BOF_RMN2, BOF_RMN3, BOF_RMN4, BOF_RMN5, DESLF_BH, LRF#1_S , 

LRF2_FLX, COKE_REC, 

 ANEAL_1S, ANEAL_2S, ANEAL_3S, ANEAL_4S, ANEAL_5S, ANEAL_6S, ANEAL_1N, ANEAL_2N, ANEAL_3N, ANEAL_4N, 

ANEAL_5N, RFURN1_1, 

 RFURN1_2, RFURN2_1, RFURN2_2, RFURN3_1, RFURN3_2, HND_SCF1, HND_SCF2, HND_SCF3, HND_SCF4, HND_SCF5, EU0099 

, EU0096 , 

 EU0095 , RG0130 , EU0096A , RG0133 , RG0132 , EU0095A , EU0120 , RG0133A , EU0118 , EU0076 , EU0076A 

, RG0130A , 

 RG0132A , A8648 , A9831 , B2132 , B2169 , B2810 , B2811 , B3518 , B3533 , B3567 , N6631 

, 

 A8640 BF_B_SS , BF_C_SS , B_CH_RM1, B_CH_RM2, B_CH_RM3, B_CH_RM4, B_CH_RM5, C_CH_RM1, C_CH_RM2, C_CH_RM3, 

C_CH_RM4, BFCCH_BS, 

 LM_UL_BH, HMTRN_BH, BOF_ESP , BOF_BH , BOF_RMW1, BOF_RMW2, BOF_RMW3, BOF_RMW4, BOF_RMW5, BOF_RMW6, 

BOF_RME1, BOF_RME2, 

 BOF_RME3, BOF_RME4, BOF_RME5, BOF_RMN1, BOF_RMN2, BOF_RMN3, BOF_RMN4, BOF_RMN5, DESLF_BH, LRF#1_S , 

LRF2_FLX, COKE_REC, 

 ANEAL_1S, ANEAL_2S, ANEAL_3S, ANEAL_4S, ANEAL_5S, ANEAL_6S, ANEAL_1N, ANEAL_2N, ANEAL_3N, ANEAL_4N, 

RFURN1_1, RFURN1_2, 

 RFURN2_1, RFURN2_2, RFURN3_1, RFURN3_2, HND_SCF1, HND_SCF2, HND_SCF3, HND_SCF4, HND_SCF5, 

 A7809 EU0099 , EU0096 , EU0095 , RG0130 , EU0096A , RG0133 , RG0132 , EU0095A , EU0120 , RG0133A , EU0118 

, EU0076 , 

 EU0076A , RG0130A , RG0132A , 

 A8648 A8648 , 

 A9831 A9831 , 

 B2132 B2132 , 
 B2169 B2169 , 

 

 B2810 B2810 , 

 B2811 B2811 , 

 

 

SUMMARY OF MAXIMUM ANNUAL ( 1 YRS) RESULTS *** 

 ALL 1ST HIGHEST VALUE IS 0.59903 AT ( 322122.00, 4672602.00 

 A8640 1ST HIGHEST VALUE IS 0.14990 AT ( 322122.00, 4672602.00 

 A7809 1ST HIGHEST VALUE IS 0.23338 AT ( 322122.00, 4672602.00 

 A8648 1ST HIGHEST VALUE IS 0.00868 AT ( 322122.00, 4672602.00 

 A9831 1ST HIGHEST VALUE IS 0.05830 AT ( 322122.00, 4672602.00 

 B2132 1ST HIGHEST VALUE IS 0.00978 AT ( 322122.00, 4672602.00 

 B2169 1ST HIGHEST VALUE IS 0.07196 AT ( 322122.00, 4672602.00 

 B2810 1ST HIGHEST VALUE IS 0.00581 AT ( 322122.00, 4672602.00 

 B2811 1ST HIGHEST VALUE IS 0.03137 AT ( 322122.00, 4672602.00 

 B3518 1ST HIGHEST VALUE IS 0.00397 AT ( 322122.00, 4672602.00 

 B3533 1ST HIGHEST VALUE IS 0.00798 AT ( 322122.00, 4672602.00 

 B3567 1ST HIGHEST VALUE IS 0.00612 AT ( 322122.00, 4672602.00 

 N6631 1ST HIGHEST VALUE IS 0.01227 AT ( 322122.00, 4672602.00 
2009 AERMOD SUMMARY – DEARBORN MONITOR LOCATION 

*** AERMOD - VERSION 07026 *** *** 2009 MONITOR IMPACTS (from Severstal, Marathon and U.S. reductions o *** 

04/28/08 

 *** POINT SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ 

EMIS RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR 

SCALAR 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) 

VARY BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- - - - - 

 

 BF_B_SS 0 0.68440E+00 322263.4 4685504.0 192.0 57.91 672.04 9.60 2.52 YES NO NO 

 BF_C_SS 0 0.11602E+01 322221.8 4685586.5 192.0 64.01 672.04 13.70 2.74 YES NO NO 

 BFCCH_BS 0 0.48560E+00 322262.1 4685580.0 192.0 60.96 338.71 19.96 2.74 YES NO NO 

 LM_UL_BH 0 0.75700E-01 322184.0 4684950.0 192.0 10.97 294.26 22.64 0.61 YES NO NO 

 HMTRN_BH 0 0.00000E+00 322024.8 4685203.0 192.0 8.23 352.60 0.05 1.75 YES NO NO 

 BOF_ESP 0 0.46856E+01 321932.5 4685047.5 192.0 64.92 422.04 18.84 5.18 YES NO NO 

 BOF_BH 0 0.17840E+00 322004.8 4685285.0 192.0 60.96 338.71 18.95 4.88 YES NO NO 

 DESLF_BH 0 0.11050E+00 321971.5 4685217.5 192.0 11.28 380.37 0.05 1.68 YES NO NO 

 LRF#1_S 0 0.85380E+00 321983.0 4684947.0 192.0 45.11 297.04 13.97 2.74 YES NO NO 

 LRF2_FLX 0 0.48790E+00 322097.1 4684808.5 192.0 45.72 433.15 17.97 1.83 YES NO NO 

 COKE_REC 0 0.24280E+00 322127.2 4684707.5 192.0 5.49 294.26 21.38 0.71 YES NO NO 

 ANEAL_1S 0 0.15900E-01 321846.1 4685170.0 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_2S 0 0.15900E-01 321826.2 4685209.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_3S 0 0.15900E-01 321806.3 4685249.0 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_4S 0 0.15900E-01 321786.4 4685288.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_5S 0 0.15900E-01 321766.5 4685328.0 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_6S 0 0.15900E-01 321746.6 4685367.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_1N 0 0.15900E-01 321726.0 4685387.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_2N 0 0.15900E-01 321713.8 4685412.0 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_3N 0 0.15900E-01 321701.4 4685436.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_4N 0 0.15900E-01 321689.1 4685461.0 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_5N 0 0.15900E-01 321676.7 4685485.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 RFURN1_1 0 0.18660E+00 320999.0 4685172.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 RFURN1_2 0 0.18660E+00 321004.0 4685162.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 RFURN2_1 0 0.18660E+00 321009.0 4685152.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 RFURN2_2 0 0.18660E+00 321014.0 4685141.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 RFURN3_1 0 0.18660E+00 321020.0 4685131.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 RFURN3_2 0 0.18660E+00 321025.0 4685120.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 EU0099 0 0.40750E+01 326027.0 4682852.0 192.0 96.01 477.60 4.28 5.03 NO NO NO 

 EU0096 0 0.26820E+01 326192.0 4683221.0 192.0 20.73 294.30 15.16 3.30 NO NO NO 

 EU0095 0 0.26310E+01 326475.0 4683520.0 192.0 19.81 294.30 10.35 3.05 NO NO NO 

 RG0130 0 0.23970E+01 326323.0 4683637.0 192.0 60.96 416.50 15.63 5.33 NO NO NO 

 EU0096A 0 0.12010E+01 326192.0 4683221.0 192.0 70.10 560.90 13.53 2.82 NO NO NO 

 RG0133 0 0.98900E+00 326299.0 4683107.0 192.0 26.82 560.90 7.48 2.97 NO NO NO 

 RG0132 0 0.87100E+00 326305.0 4683579.0 192.0 20.73 560.90 17.11 1.68 NO NO NO 

 EU0095A 0 0.84500E+00 326475.0 4683520.0 192.0 60.96 383.20 13.37 2.84 NO NO NO 

 EU0120 0 0.34600E+00 326309.0 4683644.0 192.0 33.22 544.30 21.15 1.40 NO NO NO 

 RG0133A 0 0.29900E+00 326299.0 4683107.0 192.0 26.82 560.90 7.48 2.97 NO NO NO 

 EU0118 0 0.24100E+00 326059.0 4683063.0 192.0 37.49 422.00 9.27 0.91 NO NO NO 

 EU0076 0 0.21800E+00 325960.0 4683058.0 192.0 31.09 477.60 1.62 4.27 NO NO NO 

 *** POINT SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ 

EMIS RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR 

SCALAR 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) 

VARY BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- - - - - 

 

 EU0076A 0 0.16500E+00 326087.0 4683007.0 192.0 31.09 477.60 1.62 4.27 NO NO NO 

 RG0130A 0 0.15900E+00 326323.0 4683637.0 192.0 60.96 416.50 15.63 5.33 NO NO NO 

 RG0132A 0 0.14700E+00 326305.0 4683579.0 192.0 20.73 560.90 17.11 1.68 NO NO NO 

 A8648 0 0.49000E+00 321801.0 4686168.0 192.0 12.31 295.70 10.14 0.31 NO NO NO 

 A9831 0 0.28200E+01 322000.0 4683150.0 192.0 49.43 455.50 10.24 1.91 NO NO NO 

 B2132 0 0.36000E+00 322800.0 4675000.0 192.0 46.94 415.70 8.71 2.44 NO NO NO 

 B2169 0 0.20500E+01 324525.0 4682560.0 192.0 12.19 294.30 10.00 0.30 NO NO NO 

 B2810 0 0.12300E+01 325800.0 4682000.0 192.0 123.80 427.30 47.00 3.82 NO NO NO 

 B2811 0 0.53700E+01 319700.0 4665600.0 192.0 162.69 419.70 41.04 4.34 NO NO NO 

 B3518 0 0.16000E+00 324200.0 4682800.0 192.0 29.01 344.70 17.80 0.71 NO NO NO 

 B3533 0 0.43000E+00 323800.0 4686900.0 192.0 12.19 294.30 10.00 0.30 NO NO NO 

 B3567 0 0.21000E+00 323850.0 4683450.0 192.0 12.19 294.30 10.00 0.30 NO NO NO 

 N6631 0 0.24300E+01 322513.0 4685652.0 192.0 55.27 416.40 17.46 3.37 NO NO NO 

 *** VOLUME SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY 
 ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- 

 

 B_CH_RM1 0 0.75000E-02 322245.7 4685529.0 192.0 23.17 6.55 10.77 NO 

 B_CH_RM2 0 0.75000E-02 322239.4 4685541.5 192.0 23.17 6.55 10.77 NO 

 B_CH_RM3 0 0.75000E-02 322233.0 4685554.0 192.0 23.17 6.55 10.77 NO 

 B_CH_RM4 0 0.75000E-02 322226.5 4685567.0 192.0 23.17 6.55 10.77 NO 

 B_CH_RM5 0 0.75000E-02 322220.4 4685579.5 192.0 23.17 6.55 10.77 NO 

 C_CH_RM1 0 0.23500E-01 322190.4 4685634.5 192.0 29.26 6.59 13.61 NO 

 C_CH_RM2 0 0.23500E-01 322184.1 4685647.0 192.0 29.26 6.59 13.61 NO 

 C_CH_RM3 0 0.23500E-01 322177.7 4685659.5 192.0 29.26 6.59 13.61 NO 

 C_CH_RM4 0 0.23500E-01 322171.4 4685672.5 192.0 29.26 6.59 13.61 NO 

 BOF_RMW1 0 0.77000E-02 322007.2 4685043.5 192.0 65.53 8.62 30.20 NO 

 BOF_RMW2 0 0.77000E-02 321998.8 4685060.0 192.0 65.53 8.62 30.20 NO 

 BOF_RMW3 0 0.77000E-02 321990.5 4685076.5 192.0 65.53 8.62 30.20 NO 

 BOF_RMW4 0 0.77000E-02 321982.3 4685093.0 192.0 65.53 8.62 30.20 NO 

 BOF_RMW5 0 0.77000E-02 321973.8 4685109.5 192.0 65.53 8.62 30.20 NO 

 BOF_RMW6 0 0.77000E-02 321965.7 4685126.0 192.0 65.53 8.62 30.20 NO 

 BOF_RME1 0 0.77000E-02 322043.5 4685061.0 192.0 65.53 7.66 30.20 NO 

 BOF_RME2 0 0.77000E-02 322036.2 4685075.5 192.0 65.53 7.66 30.20 NO 

 BOF_RME3 0 0.77000E-02 322028.7 4685090.0 192.0 65.53 7.66 30.20 NO 

 BOF_RME4 0 0.77000E-02 322021.3 4685105.0 192.0 65.53 7.66 30.20 NO 

 BOF_RME5 0 0.77000E-02 322013.9 4685119.5 192.0 65.53 7.66 30.20 NO 

 BOF_RMN1 0 0.77000E-02 321991.2 4685164.5 192.0 57.61 4.47 26.51 NO 

 BOF_RMN2 0 0.77000E-02 321986.9 4685173.0 192.0 57.61 4.47 26.51 NO 

 BOF_RMN3 0 0.77000E-02 321982.7 4685181.5 192.0 57.61 4.47 26.51 NO 

 BOF_RMN4 0 0.77000E-02 321978.3 4685190.0 192.0 57.61 4.47 26.51 NO 

 BOF_RMN5 0 0.77000E-02 321973.8 4685199.0 192.0 57.61 4.47 26.51 NO 

 HND_SCF1 0 0.10160E+00 321254.4 4684513.0 192.0 31.39 7.10 14.60 NO 

 HND_SCF2 0 0.10160E+00 321247.6 4684527.0 192.0 31.39 7.10 14.60 NO 

 HND_SCF3 0 0.10160E+00 321240.7 4684540.5 192.0 31.39 7.10 14.60 NO 

 HND_SCF4 0 0.10160E+00 321233.8 4684554.0 192.0 31.39 7.10 14.60 NO 

 HND_SCF5 0 0.10160E+00 321227.0 4684568.0 192.0 31.39 7.10 14.60 NO 

GROUP ID SOURCE IDs 

 

 ALL BF_B_SS , BF_C_SS , B_CH_RM1, B_CH_RM2, B_CH_RM3, B_CH_RM4, B_CH_RM5, C_CH_RM1, C_CH_RM2, C_CH_RM3, 

C_CH_RM4, BFCCH_BS, 

 LM_UL_BH, HMTRN_BH, BOF_ESP , BOF_BH , BOF_RMW1, BOF_RMW2, BOF_RMW3, BOF_RMW4, BOF_RMW5, BOF_RMW6, 

BOF_RME1, BOF_RME2, 

 BOF_RME3, BOF_RME4, BOF_RME5, BOF_RMN1, BOF_RMN2, BOF_RMN3, BOF_RMN4, BOF_RMN5, DESLF_BH, LRF#1_S , 

LRF2_FLX, COKE_REC, 

 ANEAL_1S, ANEAL_2S, ANEAL_3S, ANEAL_4S, ANEAL_5S, ANEAL_6S, ANEAL_1N, ANEAL_2N, ANEAL_3N, ANEAL_4N, 

ANEAL_5N, RFURN1_1, 

 RFURN1_2, RFURN2_1, RFURN2_2, RFURN3_1, RFURN3_2, HND_SCF1, HND_SCF2, HND_SCF3, HND_SCF4, HND_SCF5, EU0099 

, EU0096 , 

 EU0095 , RG0130 , EU0096A , RG0133 , RG0132 , EU0095A , EU0120 , RG0133A , EU0118 , EU0076 , EU0076A 

, RG0130A , 

 RG0132A , A8648 , A9831 , B2132 , B2169 , B2810 , B2811 , B3518 , B3533 , B3567 , N6631 

, 

 A8640 BF_B_SS , BF_C_SS , B_CH_RM1, B_CH_RM2, B_CH_RM3, B_CH_RM4, B_CH_RM5, C_CH_RM1, C_CH_RM2, C_CH_RM3, 

C_CH_RM4, BFCCH_BS, 

 LM_UL_BH, HMTRN_BH, BOF_ESP , BOF_BH , BOF_RMW1, BOF_RMW2, BOF_RMW3, BOF_RMW4, BOF_RMW5, BOF_RMW6, 

BOF_RME1, BOF_RME2, 

 BOF_RME3, BOF_RME4, BOF_RME5, BOF_RMN1, BOF_RMN2, BOF_RMN3, BOF_RMN4, BOF_RMN5, DESLF_BH, LRF#1_S , 

LRF2_FLX, COKE_REC, 

 ANEAL_1S, ANEAL_2S, ANEAL_3S, ANEAL_4S, ANEAL_5S, ANEAL_6S, ANEAL_1N, ANEAL_2N, ANEAL_3N, ANEAL_4N, 

RFURN1_1, RFURN1_2, 

 RFURN2_1, RFURN2_2, RFURN3_1, RFURN3_2, HND_SCF1, HND_SCF2, HND_SCF3, HND_SCF4, HND_SCF5, 

 A7809 EU0099 , EU0096 , EU0095 , RG0130 , EU0096A , RG0133 , RG0132 , EU0095A , EU0120 , RG0133A , EU0118 

, EU0076 , 

 EU0076A , RG0130A , RG0132A , 

 A8648 A8648 , 

 A9831 A9831 , 

 B2132 B2132 , 

 B2169 B2169 , 
 

 B2810 B2810 , 

 B2811 B2811 , 

 

 

SUMMARY OF MAXIMUM ANNUAL ( 1 YRS) RESULTS *** 

 ALL 1ST HIGHEST VALUE IS 2.90616 AT ( 322805.00, 4685985.00 

 A8640 1ST HIGHEST VALUE IS 1.46937 AT ( 322805.00, 4685985.00 

 A7809 1ST HIGHEST VALUE IS 0.20107 AT ( 322805.00, 4685985.00 

 A8648 1ST HIGHEST VALUE IS 0.40983 AT ( 322805.00, 4685985.00 

 A9831 1ST HIGHEST VALUE IS 0.04845 AT ( 322805.00, 4685985.00 

 B2132 1ST HIGHEST VALUE IS 0.00198 AT ( 322805.00, 4685985.00 

 B2169 1ST HIGHEST VALUE IS 0.44433 AT ( 322805.00, 4685985.00 

 B2810 1ST HIGHEST VALUE IS 0.00163 AT ( 322805.00, 4685985.00 

 B2811 1ST HIGHEST VALUE IS 0.00469 AT ( 322805.00, 4685985.00 

 B3518 1ST HIGHEST VALUE IS 0.00573 AT ( 322805.00, 4685985.00 

 B3533 1ST HIGHEST VALUE IS 0.19010 AT ( 322805.00, 4685985.00 

 B3567 1ST HIGHEST VALUE IS 0.07665 AT ( 322805.00, 4685985.00 

 N6631 1ST HIGHEST VALUE IS 0.04956 AT ( 322805.00, 4685985.00 
2009 AERMOD SUMMARY – SWHS MONITOR LOCATION 

*** AERMOD - VERSION 07026 *** *** 2009 MONITOR IMPACTS (from Severstal, Marathon and U.S. reductions o *** 

04/28/08 

 *** POINT SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ 

EMIS RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR 

SCALAR 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) 

VARY BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- - - - - 

 

 BF_B_SS 0 0.68440E+00 322263.4 4685504.0 192.0 57.91 672.04 9.60 2.52 YES NO NO 

 BF_C_SS 0 0.11602E+01 322221.8 4685586.5 192.0 64.01 672.04 13.70 2.74 YES NO NO 

 BFCCH_BS 0 0.48560E+00 322262.1 4685580.0 192.0 60.96 338.71 19.96 2.74 YES NO NO 

 LM_UL_BH 0 0.75700E-01 322184.0 4684950.0 192.0 10.97 294.26 22.64 0.61 YES NO NO 

 HMTRN_BH 0 0.00000E+00 322024.8 4685203.0 192.0 8.23 352.60 0.05 1.75 YES NO NO 

 BOF_ESP 0 0.46856E+01 321932.5 4685047.5 192.0 64.92 422.04 18.84 5.18 YES NO NO 

 BOF_BH 0 0.17840E+00 322004.8 4685285.0 192.0 60.96 338.71 18.95 4.88 YES NO NO 

 DESLF_BH 0 0.11050E+00 321971.5 4685217.5 192.0 11.28 380.37 0.05 1.68 YES NO NO 

 LRF#1_S 0 0.85380E+00 321983.0 4684947.0 192.0 45.11 297.04 13.97 2.74 YES NO NO 

 LRF2_FLX 0 0.48790E+00 322097.1 4684808.5 192.0 45.72 433.15 17.97 1.83 YES NO NO 

 COKE_REC 0 0.24280E+00 322127.2 4684707.5 192.0 5.49 294.26 21.38 0.71 YES NO NO 

 ANEAL_1S 0 0.15900E-01 321846.1 4685170.0 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_2S 0 0.15900E-01 321826.2 4685209.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_3S 0 0.15900E-01 321806.3 4685249.0 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_4S 0 0.15900E-01 321786.4 4685288.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_5S 0 0.15900E-01 321766.5 4685328.0 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_6S 0 0.15900E-01 321746.6 4685367.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_1N 0 0.15900E-01 321726.0 4685387.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_2N 0 0.15900E-01 321713.8 4685412.0 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_3N 0 0.15900E-01 321701.4 4685436.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_4N 0 0.15900E-01 321689.1 4685461.0 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_5N 0 0.15900E-01 321676.7 4685485.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 RFURN1_1 0 0.18660E+00 320999.0 4685172.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 RFURN1_2 0 0.18660E+00 321004.0 4685162.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 RFURN2_1 0 0.18660E+00 321009.0 4685152.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 RFURN2_2 0 0.18660E+00 321014.0 4685141.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 RFURN3_1 0 0.18660E+00 321020.0 4685131.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 RFURN3_2 0 0.18660E+00 321025.0 4685120.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 EU0099 0 0.40750E+01 326027.0 4682852.0 192.0 96.01 477.60 4.28 5.03 NO NO NO 

 EU0096 0 0.26820E+01 326192.0 4683221.0 192.0 20.73 294.30 15.16 3.30 NO NO NO 

 EU0095 0 0.26310E+01 326475.0 4683520.0 192.0 19.81 294.30 10.35 3.05 NO NO NO 

 RG0130 0 0.23970E+01 326323.0 4683637.0 192.0 60.96 416.50 15.63 5.33 NO NO NO 

 EU0096A 0 0.12010E+01 326192.0 4683221.0 192.0 70.10 560.90 13.53 2.82 NO NO NO 

 RG0133 0 0.98900E+00 326299.0 4683107.0 192.0 26.82 560.90 7.48 2.97 NO NO NO 

 RG0132 0 0.87100E+00 326305.0 4683579.0 192.0 20.73 560.90 17.11 1.68 NO NO NO 

 EU0095A 0 0.84500E+00 326475.0 4683520.0 192.0 60.96 383.20 13.37 2.84 NO NO NO 

 EU0120 0 0.34600E+00 326309.0 4683644.0 192.0 33.22 544.30 21.15 1.40 NO NO NO 

 RG0133A 0 0.29900E+00 326299.0 4683107.0 192.0 26.82 560.90 7.48 2.97 NO NO NO 

 EU0118 0 0.24100E+00 326059.0 4683063.0 192.0 37.49 422.00 9.27 0.91 NO NO NO 

 EU0076 0 0.21800E+00 325960.0 4683058.0 192.0 31.09 477.60 1.62 4.27 NO NO NO 

 *** POINT SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ 

EMIS RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR 

SCALAR 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) 

VARY BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- - - - - 

 

 EU0076A 0 0.16500E+00 326087.0 4683007.0 192.0 31.09 477.60 1.62 4.27 NO NO NO 

 RG0130A 0 0.15900E+00 326323.0 4683637.0 192.0 60.96 416.50 15.63 5.33 NO NO NO 

 RG0132A 0 0.14700E+00 326305.0 4683579.0 192.0 20.73 560.90 17.11 1.68 NO NO NO 

 A8648 0 0.49000E+00 321801.0 4686168.0 192.0 12.31 295.70 10.14 0.31 NO NO NO 

 A9831 0 0.28200E+01 322000.0 4683150.0 192.0 49.43 455.50 10.24 1.91 NO NO NO 

 B2132 0 0.36000E+00 322800.0 4675000.0 192.0 46.94 415.70 8.71 2.44 NO NO NO 

 B2169 0 0.20500E+01 324525.0 4682560.0 192.0 12.19 294.30 10.00 0.30 NO NO NO 

 B2810 0 0.12300E+01 325800.0 4682000.0 192.0 123.80 427.30 47.00 3.82 NO NO NO 

 B2811 0 0.53700E+01 319700.0 4665600.0 192.0 162.69 419.70 41.04 4.34 NO NO NO 

 B3518 0 0.16000E+00 324200.0 4682800.0 192.0 29.01 344.70 17.80 0.71 NO NO NO 

 B3533 0 0.43000E+00 323800.0 4686900.0 192.0 12.19 294.30 10.00 0.30 NO NO NO 

 B3567 0 0.21000E+00 323850.0 4683450.0 192.0 12.19 294.30 10.00 0.30 NO NO NO 

 N6631 0 0.24300E+01 322513.0 4685652.0 192.0 55.27 416.40 17.46 3.37 NO NO NO 

 *** VOLUME SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY 
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- 

 

 B_CH_RM1 0 0.75000E-02 322245.7 4685529.0 192.0 23.17 6.55 10.77 NO 

 B_CH_RM2 0 0.75000E-02 322239.4 4685541.5 192.0 23.17 6.55 10.77 NO 

 B_CH_RM3 0 0.75000E-02 322233.0 4685554.0 192.0 23.17 6.55 10.77 NO 

 B_CH_RM4 0 0.75000E-02 322226.5 4685567.0 192.0 23.17 6.55 10.77 NO 

 B_CH_RM5 0 0.75000E-02 322220.4 4685579.5 192.0 23.17 6.55 10.77 NO 

 C_CH_RM1 0 0.23500E-01 322190.4 4685634.5 192.0 29.26 6.59 13.61 NO 

 C_CH_RM2 0 0.23500E-01 322184.1 4685647.0 192.0 29.26 6.59 13.61 NO 

 C_CH_RM3 0 0.23500E-01 322177.7 4685659.5 192.0 29.26 6.59 13.61 NO 

 C_CH_RM4 0 0.23500E-01 322171.4 4685672.5 192.0 29.26 6.59 13.61 NO 

 BOF_RMW1 0 0.77000E-02 322007.2 4685043.5 192.0 65.53 8.62 30.20 NO 

 BOF_RMW2 0 0.77000E-02 321998.8 4685060.0 192.0 65.53 8.62 30.20 NO 

 BOF_RMW3 0 0.77000E-02 321990.5 4685076.5 192.0 65.53 8.62 30.20 NO 

 BOF_RMW4 0 0.77000E-02 321982.3 4685093.0 192.0 65.53 8.62 30.20 NO 

 BOF_RMW5 0 0.77000E-02 321973.8 4685109.5 192.0 65.53 8.62 30.20 NO 

 BOF_RMW6 0 0.77000E-02 321965.7 4685126.0 192.0 65.53 8.62 30.20 NO 

 BOF_RME1 0 0.77000E-02 322043.5 4685061.0 192.0 65.53 7.66 30.20 NO 

 BOF_RME2 0 0.77000E-02 322036.2 4685075.5 192.0 65.53 7.66 30.20 NO 

 BOF_RME3 0 0.77000E-02 322028.7 4685090.0 192.0 65.53 7.66 30.20 NO 

 BOF_RME4 0 0.77000E-02 322021.3 4685105.0 192.0 65.53 7.66 30.20 NO 

 BOF_RME5 0 0.77000E-02 322013.9 4685119.5 192.0 65.53 7.66 30.20 NO 

 BOF_RMN1 0 0.77000E-02 321991.2 4685164.5 192.0 57.61 4.47 26.51 NO 

 BOF_RMN2 0 0.77000E-02 321986.9 4685173.0 192.0 57.61 4.47 26.51 NO 

 BOF_RMN3 0 0.77000E-02 321982.7 4685181.5 192.0 57.61 4.47 26.51 NO 

 BOF_RMN4 0 0.77000E-02 321978.3 4685190.0 192.0 57.61 4.47 26.51 NO 

 BOF_RMN5 0 0.77000E-02 321973.8 4685199.0 192.0 57.61 4.47 26.51 NO 

 HND_SCF1 0 0.10160E+00 321254.4 4684513.0 192.0 31.39 7.10 14.60 NO 

 HND_SCF2 0 0.10160E+00 321247.6 4684527.0 192.0 31.39 7.10 14.60 NO 

 HND_SCF3 0 0.10160E+00 321240.7 4684540.5 192.0 31.39 7.10 14.60 NO 

 HND_SCF4 0 0.10160E+00 321233.8 4684554.0 192.0 31.39 7.10 14.60 NO 

 HND_SCF5 0 0.10160E+00 321227.0 4684568.0 192.0 31.39 7.10 14.60 NO 

GROUP ID SOURCE IDs 

 

 ALL BF_B_SS , BF_C_SS , B_CH_RM1, B_CH_RM2, B_CH_RM3, B_CH_RM4, B_CH_RM5, C_CH_RM1, C_CH_RM2, C_CH_RM3, 

C_CH_RM4, BFCCH_BS, 

 LM_UL_BH, HMTRN_BH, BOF_ESP , BOF_BH , BOF_RMW1, BOF_RMW2, BOF_RMW3, BOF_RMW4, BOF_RMW5, BOF_RMW6, 

BOF_RME1, BOF_RME2, 

 BOF_RME3, BOF_RME4, BOF_RME5, BOF_RMN1, BOF_RMN2, BOF_RMN3, BOF_RMN4, BOF_RMN5, DESLF_BH, LRF#1_S , 

LRF2_FLX, COKE_REC, 

 ANEAL_1S, ANEAL_2S, ANEAL_3S, ANEAL_4S, ANEAL_5S, ANEAL_6S, ANEAL_1N, ANEAL_2N, ANEAL_3N, ANEAL_4N, 

ANEAL_5N, RFURN1_1, 

 RFURN1_2, RFURN2_1, RFURN2_2, RFURN3_1, RFURN3_2, HND_SCF1, HND_SCF2, HND_SCF3, HND_SCF4, HND_SCF5, EU0099 

, EU0096 , 

 EU0095 , RG0130 , EU0096A , RG0133 , RG0132 , EU0095A , EU0120 , RG0133A , EU0118 , EU0076 , EU0076A 

, RG0130A , 

 RG0132A , A8648 , A9831 , B2132 , B2169 , B2810 , B2811 , B3518 , B3533 , B3567 , N6631 

, 

 A8640 BF_B_SS , BF_C_SS , B_CH_RM1, B_CH_RM2, B_CH_RM3, B_CH_RM4, B_CH_RM5, C_CH_RM1, C_CH_RM2, C_CH_RM3, 

C_CH_RM4, BFCCH_BS, 

 LM_UL_BH, HMTRN_BH, BOF_ESP , BOF_BH , BOF_RMW1, BOF_RMW2, BOF_RMW3, BOF_RMW4, BOF_RMW5, BOF_RMW6, 

BOF_RME1, BOF_RME2, 

 BOF_RME3, BOF_RME4, BOF_RME5, BOF_RMN1, BOF_RMN2, BOF_RMN3, BOF_RMN4, BOF_RMN5, DESLF_BH, LRF#1_S , 

LRF2_FLX, COKE_REC, 

 ANEAL_1S, ANEAL_2S, ANEAL_3S, ANEAL_4S, ANEAL_5S, ANEAL_6S, ANEAL_1N, ANEAL_2N, ANEAL_3N, ANEAL_4N, 

RFURN1_1, RFURN1_2, 

 RFURN2_1, RFURN2_2, RFURN3_1, RFURN3_2, HND_SCF1, HND_SCF2, HND_SCF3, HND_SCF4, HND_SCF5, 

 A7809 EU0099 , EU0096 , EU0095 , RG0130 , EU0096A , RG0133 , RG0132 , EU0095A , EU0120 , RG0133A , EU0118 

, EU0076 , 

 EU0076A , RG0130A , RG0132A , 

 A8648 A8648 , 

 A9831 A9831 , 

 B2132 B2132 , 

 B2169 B2169 , 
 B2810 B2810 , 

 

 B2811 B2811 , 

 

 

SUMMARY OF MAXIMUM ANNUAL ( 1 YRS) RESULTS *** 

 ALL 1ST HIGHEST VALUE IS 1.87622 AT ( 326344.00, 4685318.00 

 A8640 1ST HIGHEST VALUE IS 0.24373 AT ( 326344.00, 4685318.00 

 A7809 1ST HIGHEST VALUE IS 0.87434 AT ( 326344.00, 4685318.00 

 A8648 1ST HIGHEST VALUE IS 0.08392 AT ( 326344.00, 4685318.00 

 A9831 1ST HIGHEST VALUE IS 0.04044 AT ( 326344.00, 4685318.00 

 B2132 1ST HIGHEST VALUE IS 0.00264 AT ( 326344.00, 4685318.00 

 B2169 1ST HIGHEST VALUE IS 0.44840 AT ( 326344.00, 4685318.00 

 B2810 1ST HIGHEST VALUE IS 0.00293 AT ( 326344.00, 4685318.00 

 B2811 1ST HIGHEST VALUE IS 0.00483 AT ( 326344.00, 4685318.00 

 B3518 1ST HIGHEST VALUE IS 0.00962 AT ( 326344.00, 4685318.00 

 B3533 1ST HIGHEST VALUE IS 0.11624 AT ( 326344.00, 4685318.00 

 B3567 1ST HIGHEST VALUE IS 0.03397 AT ( 326344.00, 4685318.00 

 N6631 1ST HIGHEST VALUE IS 0.01533 AT ( 326344.00, 4685318.00 
2009 AERMOD SUMMARY – ALLEN PARK MONITOR 

LOCATION 

*** AERMOD - VERSION 07026 *** *** 2009 MONITOR IMPACTS (from Severstal, Marathon and U.S. reductions o *** 

04/28/08 

 *** POINT SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ 

EMIS RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR 

SCALAR 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) 

VARY BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- - - - - 

 

 BF_B_SS 0 0.68440E+00 322263.4 4685504.0 192.0 57.91 672.04 9.60 2.52 YES NO NO 

 BF_C_SS 0 0.11602E+01 322221.8 4685586.5 192.0 64.01 672.04 13.70 2.74 YES NO NO 

 BFCCH_BS 0 0.48560E+00 322262.1 4685580.0 192.0 60.96 338.71 19.96 2.74 YES NO NO 

 LM_UL_BH 0 0.75700E-01 322184.0 4684950.0 192.0 10.97 294.26 22.64 0.61 YES NO NO 

 HMTRN_BH 0 0.00000E+00 322024.8 4685203.0 192.0 8.23 352.60 0.05 1.75 YES NO NO 

 BOF_ESP 0 0.46856E+01 321932.5 4685047.5 192.0 64.92 422.04 18.84 5.18 YES NO NO 

 BOF_BH 0 0.17840E+00 322004.8 4685285.0 192.0 60.96 338.71 18.95 4.88 YES NO NO 

 DESLF_BH 0 0.11050E+00 321971.5 4685217.5 192.0 11.28 380.37 0.05 1.68 YES NO NO 

 LRF#1_S 0 0.85380E+00 321983.0 4684947.0 192.0 45.11 297.04 13.97 2.74 YES NO NO 

 LRF2_FLX 0 0.48790E+00 322097.1 4684808.5 192.0 45.72 433.15 17.97 1.83 YES NO NO 

 COKE_REC 0 0.24280E+00 322127.2 4684707.5 192.0 5.49 294.26 21.38 0.71 YES NO NO 

 ANEAL_1S 0 0.15900E-01 321846.1 4685170.0 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_2S 0 0.15900E-01 321826.2 4685209.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_3S 0 0.15900E-01 321806.3 4685249.0 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_4S 0 0.15900E-01 321786.4 4685288.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_5S 0 0.15900E-01 321766.5 4685328.0 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_6S 0 0.15900E-01 321746.6 4685367.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_1N 0 0.15900E-01 321726.0 4685387.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_2N 0 0.15900E-01 321713.8 4685412.0 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_3N 0 0.15900E-01 321701.4 4685436.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_4N 0 0.15900E-01 321689.1 4685461.0 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_5N 0 0.15900E-01 321676.7 4685485.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 RFURN1_1 0 0.18660E+00 320999.0 4685172.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 RFURN1_2 0 0.18660E+00 321004.0 4685162.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 RFURN2_1 0 0.18660E+00 321009.0 4685152.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 RFURN2_2 0 0.18660E+00 321014.0 4685141.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 RFURN3_1 0 0.18660E+00 321020.0 4685131.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 RFURN3_2 0 0.18660E+00 321025.0 4685120.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 EU0099 0 0.40750E+01 326027.0 4682852.0 192.0 96.01 477.60 4.28 5.03 NO NO NO 

 EU0096 0 0.26820E+01 326192.0 4683221.0 192.0 20.73 294.30 15.16 3.30 NO NO NO 

 EU0095 0 0.26310E+01 326475.0 4683520.0 192.0 19.81 294.30 10.35 3.05 NO NO NO 

 RG0130 0 0.23970E+01 326323.0 4683637.0 192.0 60.96 416.50 15.63 5.33 NO NO NO 

 EU0096A 0 0.12010E+01 326192.0 4683221.0 192.0 70.10 560.90 13.53 2.82 NO NO NO 

 RG0133 0 0.98900E+00 326299.0 4683107.0 192.0 26.82 560.90 7.48 2.97 NO NO NO 

 RG0132 0 0.87100E+00 326305.0 4683579.0 192.0 20.73 560.90 17.11 1.68 NO NO NO 

 EU0095A 0 0.84500E+00 326475.0 4683520.0 192.0 60.96 383.20 13.37 2.84 NO NO NO 

 EU0120 0 0.34600E+00 326309.0 4683644.0 192.0 33.22 544.30 21.15 1.40 NO NO NO 

 RG0133A 0 0.29900E+00 326299.0 4683107.0 192.0 26.82 560.90 7.48 2.97 NO NO NO 

 EU0118 0 0.24100E+00 326059.0 4683063.0 192.0 37.49 422.00 9.27 0.91 NO NO NO 

 EU0076 0 0.21800E+00 325960.0 4683058.0 192.0 31.09 477.60 1.62 4.27 NO NO NO 

 *** POINT SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ 

EMIS RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR 

SCALAR 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) 

VARY BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- - - - - 

 

 EU0076A 0 0.16500E+00 326087.0 4683007.0 192.0 31.09 477.60 1.62 4.27 NO NO NO 

 RG0130A 0 0.15900E+00 326323.0 4683637.0 192.0 60.96 416.50 15.63 5.33 NO NO NO 

 RG0132A 0 0.14700E+00 326305.0 4683579.0 192.0 20.73 560.90 17.11 1.68 NO NO NO 

 A8648 0 0.49000E+00 321801.0 4686168.0 192.0 12.31 295.70 10.14 0.31 NO NO NO 

 A9831 0 0.28200E+01 322000.0 4683150.0 192.0 49.43 455.50 10.24 1.91 NO NO NO 

 B2132 0 0.36000E+00 322800.0 4675000.0 192.0 46.94 415.70 8.71 2.44 NO NO NO 

 B2169 0 0.20500E+01 324525.0 4682560.0 192.0 12.19 294.30 10.00 0.30 NO NO NO 

 B2810 0 0.12300E+01 325800.0 4682000.0 192.0 123.80 427.30 47.00 3.82 NO NO NO 

 B2811 0 0.53700E+01 319700.0 4665600.0 192.0 162.69 419.70 41.04 4.34 NO NO NO 

 B3518 0 0.16000E+00 324200.0 4682800.0 192.0 29.01 344.70 17.80 0.71 NO NO NO 

 B3533 0 0.43000E+00 323800.0 4686900.0 192.0 12.19 294.30 10.00 0.30 NO NO NO 

 B3567 0 0.21000E+00 323850.0 4683450.0 192.0 12.19 294.30 10.00 0.30 NO NO NO 

 N6631 0 0.24300E+01 322513.0 4685652.0 192.0 55.27 416.40 17.46 3.37 NO NO NO 

 *** VOLUME SOURCE DATA *** 

 
 NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- 

 

 B_CH_RM1 0 0.75000E-02 322245.7 4685529.0 192.0 23.17 6.55 10.77 NO 

 B_CH_RM2 0 0.75000E-02 322239.4 4685541.5 192.0 23.17 6.55 10.77 NO 

 B_CH_RM3 0 0.75000E-02 322233.0 4685554.0 192.0 23.17 6.55 10.77 NO 

 B_CH_RM4 0 0.75000E-02 322226.5 4685567.0 192.0 23.17 6.55 10.77 NO 

 B_CH_RM5 0 0.75000E-02 322220.4 4685579.5 192.0 23.17 6.55 10.77 NO 

 C_CH_RM1 0 0.23500E-01 322190.4 4685634.5 192.0 29.26 6.59 13.61 NO 

 C_CH_RM2 0 0.23500E-01 322184.1 4685647.0 192.0 29.26 6.59 13.61 NO 

 C_CH_RM3 0 0.23500E-01 322177.7 4685659.5 192.0 29.26 6.59 13.61 NO 

 C_CH_RM4 0 0.23500E-01 322171.4 4685672.5 192.0 29.26 6.59 13.61 NO 

 BOF_RMW1 0 0.77000E-02 322007.2 4685043.5 192.0 65.53 8.62 30.20 NO 

 BOF_RMW2 0 0.77000E-02 321998.8 4685060.0 192.0 65.53 8.62 30.20 NO 

 BOF_RMW3 0 0.77000E-02 321990.5 4685076.5 192.0 65.53 8.62 30.20 NO 

 BOF_RMW4 0 0.77000E-02 321982.3 4685093.0 192.0 65.53 8.62 30.20 NO 

 BOF_RMW5 0 0.77000E-02 321973.8 4685109.5 192.0 65.53 8.62 30.20 NO 

 BOF_RMW6 0 0.77000E-02 321965.7 4685126.0 192.0 65.53 8.62 30.20 NO 

 BOF_RME1 0 0.77000E-02 322043.5 4685061.0 192.0 65.53 7.66 30.20 NO 

 BOF_RME2 0 0.77000E-02 322036.2 4685075.5 192.0 65.53 7.66 30.20 NO 

 BOF_RME3 0 0.77000E-02 322028.7 4685090.0 192.0 65.53 7.66 30.20 NO 

 BOF_RME4 0 0.77000E-02 322021.3 4685105.0 192.0 65.53 7.66 30.20 NO 

 BOF_RME5 0 0.77000E-02 322013.9 4685119.5 192.0 65.53 7.66 30.20 NO 

 BOF_RMN1 0 0.77000E-02 321991.2 4685164.5 192.0 57.61 4.47 26.51 NO 

 BOF_RMN2 0 0.77000E-02 321986.9 4685173.0 192.0 57.61 4.47 26.51 NO 

 BOF_RMN3 0 0.77000E-02 321982.7 4685181.5 192.0 57.61 4.47 26.51 NO 

 BOF_RMN4 0 0.77000E-02 321978.3 4685190.0 192.0 57.61 4.47 26.51 NO 

 BOF_RMN5 0 0.77000E-02 321973.8 4685199.0 192.0 57.61 4.47 26.51 NO 

 HND_SCF1 0 0.10160E+00 321254.4 4684513.0 192.0 31.39 7.10 14.60 NO 

 HND_SCF2 0 0.10160E+00 321247.6 4684527.0 192.0 31.39 7.10 14.60 NO 

 HND_SCF3 0 0.10160E+00 321240.7 4684540.5 192.0 31.39 7.10 14.60 NO 

 HND_SCF4 0 0.10160E+00 321233.8 4684554.0 192.0 31.39 7.10 14.60 NO 

 HND_SCF5 0 0.10160E+00 321227.0 4684568.0 192.0 31.39 7.10 14.60 NO 

GROUP ID SOURCE IDs 

 

 ALL BF_B_SS , BF_C_SS , B_CH_RM1, B_CH_RM2, B_CH_RM3, B_CH_RM4, B_CH_RM5, C_CH_RM1, C_CH_RM2, C_CH_RM3, 

C_CH_RM4, BFCCH_BS, 

 LM_UL_BH, HMTRN_BH, BOF_ESP , BOF_BH , BOF_RMW1, BOF_RMW2, BOF_RMW3, BOF_RMW4, BOF_RMW5, BOF_RMW6, 

BOF_RME1, BOF_RME2, 

 BOF_RME3, BOF_RME4, BOF_RME5, BOF_RMN1, BOF_RMN2, BOF_RMN3, BOF_RMN4, BOF_RMN5, DESLF_BH, LRF#1_S , 

LRF2_FLX, COKE_REC, 

 ANEAL_1S, ANEAL_2S, ANEAL_3S, ANEAL_4S, ANEAL_5S, ANEAL_6S, ANEAL_1N, ANEAL_2N, ANEAL_3N, ANEAL_4N, 

ANEAL_5N, RFURN1_1, 

 RFURN1_2, RFURN2_1, RFURN2_2, RFURN3_1, RFURN3_2, HND_SCF1, HND_SCF2, HND_SCF3, HND_SCF4, HND_SCF5, EU0099 

, EU0096 , 

 EU0095 , RG0130 , EU0096A , RG0133 , RG0132 , EU0095A , EU0120 , RG0133A , EU0118 , EU0076 , EU0076A 

, RG0130A , 

 RG0132A , A8648 , A9831 , B2132 , B2169 , B2810 , B2811 , B3518 , B3533 , B3567 , N6631 

, 

 A8640 BF_B_SS , BF_C_SS , B_CH_RM1, B_CH_RM2, B_CH_RM3, B_CH_RM4, B_CH_RM5, C_CH_RM1, C_CH_RM2, C_CH_RM3, 

C_CH_RM4, BFCCH_BS, 

 LM_UL_BH, HMTRN_BH, BOF_ESP , BOF_BH , BOF_RMW1, BOF_RMW2, BOF_RMW3, BOF_RMW4, BOF_RMW5, BOF_RMW6, 

BOF_RME1, BOF_RME2, 

 BOF_RME3, BOF_RME4, BOF_RME5, BOF_RMN1, BOF_RMN2, BOF_RMN3, BOF_RMN4, BOF_RMN5, DESLF_BH, LRF#1_S , 

LRF2_FLX, COKE_REC, 

 ANEAL_1S, ANEAL_2S, ANEAL_3S, ANEAL_4S, ANEAL_5S, ANEAL_6S, ANEAL_1N, ANEAL_2N, ANEAL_3N, ANEAL_4N, 

RFURN1_1, RFURN1_2, 

 RFURN2_1, RFURN2_2, RFURN3_1, RFURN3_2, HND_SCF1, HND_SCF2, HND_SCF3, HND_SCF4, HND_SCF5, 

 A7809 EU0099 , EU0096 , EU0095 , RG0130 , EU0096A , RG0133 , RG0132 , EU0095A , EU0120 , RG0133A , EU0118 

, EU0076 , 

 EU0076A , RG0130A , RG0132A , 

 A8648 A8648 , 

 A9831 A9831 , 

 B2132 B2132 , 
 B2169 B2169 , 

 

 B2810 B2810 , 

 B2811 B2811 , 

 

 

SUMMARY OF MAXIMUM ANNUAL ( 1 YRS) RESULTS *** 

 ALL 1ST HIGHEST VALUE IS 0.42555 AT ( 317758.00, 4677306.00 

 A8640 1ST HIGHEST VALUE IS 0.14868 AT ( 317758.00, 4677306.00 

 A7809 1ST HIGHEST VALUE IS 0.08436 AT ( 317758.00, 4677306.00 

 A8648 1ST HIGHEST VALUE IS 0.03304 AT ( 317758.00, 4677306.00 

 A9831 1ST HIGHEST VALUE IS 0.02178 AT ( 317758.00, 4677306.00 

 B2132 1ST HIGHEST VALUE IS 0.00156 AT ( 317758.00, 4677306.00 

 B2169 1ST HIGHEST VALUE IS 0.08669 AT ( 317758.00, 4677306.00 

 B2810 1ST HIGHEST VALUE IS 0.00159 AT ( 317758.00, 4677306.00 

 B2811 1ST HIGHEST VALUE IS 0.00585 AT ( 317758.00, 4677306.00 

 B3518 1ST HIGHEST VALUE IS 0.00177 AT ( 317758.00, 4677306.00 

 B3533 1ST HIGHEST VALUE IS 0.01993 AT ( 317758.00, 4677306.00 

 B3567 1ST HIGHEST VALUE IS 0.01052 AT ( 317758.00, 4677306.00 

 N6631 1ST HIGHEST VALUE IS 0.00899 AT ( 317758.00, 4677306.00 
2009 AERMOD SUMMARY – WYANDOTTE MONITOR 

LOCATION 

*** AERMOD - VERSION 07026 *** *** 2009 MONITOR IMPACTS (from Severstal, Marathon and U.S. reductions o *** 

04/28/08 

 *** POINT SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ 

EMIS RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR 

SCALAR 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) 

VARY BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- - - - - 

 

 BF_B_SS 0 0.68440E+00 322263.4 4685504.0 192.0 57.91 672.04 9.60 2.52 YES NO NO 

 BF_C_SS 0 0.11602E+01 322221.8 4685586.5 192.0 64.01 672.04 13.70 2.74 YES NO NO 

 BFCCH_BS 0 0.48560E+00 322262.1 4685580.0 192.0 60.96 338.71 19.96 2.74 YES NO NO 

 LM_UL_BH 0 0.75700E-01 322184.0 4684950.0 192.0 10.97 294.26 22.64 0.61 YES NO NO 

 HMTRN_BH 0 0.00000E+00 322024.8 4685203.0 192.0 8.23 352.60 0.05 1.75 YES NO NO 

 BOF_ESP 0 0.46856E+01 321932.5 4685047.5 192.0 64.92 422.04 18.84 5.18 YES NO NO 

 BOF_BH 0 0.17840E+00 322004.8 4685285.0 192.0 60.96 338.71 18.95 4.88 YES NO NO 

 DESLF_BH 0 0.11050E+00 321971.5 4685217.5 192.0 11.28 380.37 0.05 1.68 YES NO NO 

 LRF#1_S 0 0.85380E+00 321983.0 4684947.0 192.0 45.11 297.04 13.97 2.74 YES NO NO 

 LRF2_FLX 0 0.48790E+00 322097.1 4684808.5 192.0 45.72 433.15 17.97 1.83 YES NO NO 

 COKE_REC 0 0.24280E+00 322127.2 4684707.5 192.0 5.49 294.26 21.38 0.71 YES NO NO 

 ANEAL_1S 0 0.15900E-01 321846.1 4685170.0 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_2S 0 0.15900E-01 321826.2 4685209.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_3S 0 0.15900E-01 321806.3 4685249.0 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_4S 0 0.15900E-01 321786.4 4685288.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_5S 0 0.15900E-01 321766.5 4685328.0 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_6S 0 0.15900E-01 321746.6 4685367.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_1N 0 0.15900E-01 321726.0 4685387.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_2N 0 0.15900E-01 321713.8 4685412.0 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_3N 0 0.15900E-01 321701.4 4685436.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_4N 0 0.15900E-01 321689.1 4685461.0 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 ANEAL_5N 0 0.15900E-01 321676.7 4685485.5 192.0 21.34 1060.93 0.05 0.76 YES NO NO 

 RFURN1_1 0 0.18660E+00 320999.0 4685172.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 RFURN1_2 0 0.18660E+00 321004.0 4685162.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 RFURN2_1 0 0.18660E+00 321009.0 4685152.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 RFURN2_2 0 0.18660E+00 321014.0 4685141.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 RFURN3_1 0 0.18660E+00 321020.0 4685131.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 RFURN3_2 0 0.18660E+00 321025.0 4685120.0 192.0 63.40 922.04 4.39 4.27 YES NO NO 

 EU0099 0 0.40750E+01 326027.0 4682852.0 192.0 96.01 477.60 4.28 5.03 NO NO NO 

 EU0096 0 0.26820E+01 326192.0 4683221.0 192.0 20.73 294.30 15.16 3.30 NO NO NO 

 EU0095 0 0.26310E+01 326475.0 4683520.0 192.0 19.81 294.30 10.35 3.05 NO NO NO 

 RG0130 0 0.23970E+01 326323.0 4683637.0 192.0 60.96 416.50 15.63 5.33 NO NO NO 

 EU0096A 0 0.12010E+01 326192.0 4683221.0 192.0 70.10 560.90 13.53 2.82 NO NO NO 

 RG0133 0 0.98900E+00 326299.0 4683107.0 192.0 26.82 560.90 7.48 2.97 NO NO NO 

 RG0132 0 0.87100E+00 326305.0 4683579.0 192.0 20.73 560.90 17.11 1.68 NO NO NO 

 EU0095A 0 0.84500E+00 326475.0 4683520.0 192.0 60.96 383.20 13.37 2.84 NO NO NO 

 EU0120 0 0.34600E+00 326309.0 4683644.0 192.0 33.22 544.30 21.15 1.40 NO NO NO 

 RG0133A 0 0.29900E+00 326299.0 4683107.0 192.0 26.82 560.90 7.48 2.97 NO NO NO 

 EU0118 0 0.24100E+00 326059.0 4683063.0 192.0 37.49 422.00 9.27 0.91 NO NO NO 

 EU0076 0 0.21800E+00 325960.0 4683058.0 192.0 31.09 477.60 1.62 4.27 NO NO NO 

 *** POINT SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ 

EMIS RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR 

SCALAR 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) 

VARY BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- - - - - 

 

 EU0076A 0 0.16500E+00 326087.0 4683007.0 192.0 31.09 477.60 1.62 4.27 NO NO NO 

 RG0130A 0 0.15900E+00 326323.0 4683637.0 192.0 60.96 416.50 15.63 5.33 NO NO NO 

 RG0132A 0 0.14700E+00 326305.0 4683579.0 192.0 20.73 560.90 17.11 1.68 NO NO NO 

 A8648 0 0.49000E+00 321801.0 4686168.0 192.0 12.31 295.70 10.14 0.31 NO NO NO 

 A9831 0 0.28200E+01 322000.0 4683150.0 192.0 49.43 455.50 10.24 1.91 NO NO NO 

 B2132 0 0.36000E+00 322800.0 4675000.0 192.0 46.94 415.70 8.71 2.44 NO NO NO 

 B2169 0 0.20500E+01 324525.0 4682560.0 192.0 12.19 294.30 10.00 0.30 NO NO NO 

 B2810 0 0.12300E+01 325800.0 4682000.0 192.0 123.80 427.30 47.00 3.82 NO NO NO 

 B2811 0 0.53700E+01 319700.0 4665600.0 192.0 162.69 419.70 41.04 4.34 NO NO NO 

 B3518 0 0.16000E+00 324200.0 4682800.0 192.0 29.01 344.70 17.80 0.71 NO NO NO 

 B3533 0 0.43000E+00 323800.0 4686900.0 192.0 12.19 294.30 10.00 0.30 NO NO NO 

 B3567 0 0.21000E+00 323850.0 4683450.0 192.0 12.19 294.30 10.00 0.30 NO NO NO 

 N6631 0 0.24300E+01 322513.0 4685652.0 192.0 55.27 416.40 17.46 3.37 NO NO NO 

 *** VOLUME SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE 
 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- 

 

 B_CH_RM1 0 0.75000E-02 322245.7 4685529.0 192.0 23.17 6.55 10.77 NO 

 B_CH_RM2 0 0.75000E-02 322239.4 4685541.5 192.0 23.17 6.55 10.77 NO 

 B_CH_RM3 0 0.75000E-02 322233.0 4685554.0 192.0 23.17 6.55 10.77 NO 

 B_CH_RM4 0 0.75000E-02 322226.5 4685567.0 192.0 23.17 6.55 10.77 NO 

 B_CH_RM5 0 0.75000E-02 322220.4 4685579.5 192.0 23.17 6.55 10.77 NO 

 C_CH_RM1 0 0.23500E-01 322190.4 4685634.5 192.0 29.26 6.59 13.61 NO 

 C_CH_RM2 0 0.23500E-01 322184.1 4685647.0 192.0 29.26 6.59 13.61 NO 

 C_CH_RM3 0 0.23500E-01 322177.7 4685659.5 192.0 29.26 6.59 13.61 NO 

 C_CH_RM4 0 0.23500E-01 322171.4 4685672.5 192.0 29.26 6.59 13.61 NO 

 BOF_RMW1 0 0.77000E-02 322007.2 4685043.5 192.0 65.53 8.62 30.20 NO 

 BOF_RMW2 0 0.77000E-02 321998.8 4685060.0 192.0 65.53 8.62 30.20 NO 

 BOF_RMW3 0 0.77000E-02 321990.5 4685076.5 192.0 65.53 8.62 30.20 NO 

 BOF_RMW4 0 0.77000E-02 321982.3 4685093.0 192.0 65.53 8.62 30.20 NO 

 BOF_RMW5 0 0.77000E-02 321973.8 4685109.5 192.0 65.53 8.62 30.20 NO 

 BOF_RMW6 0 0.77000E-02 321965.7 4685126.0 192.0 65.53 8.62 30.20 NO 

 BOF_RME1 0 0.77000E-02 322043.5 4685061.0 192.0 65.53 7.66 30.20 NO 

 BOF_RME2 0 0.77000E-02 322036.2 4685075.5 192.0 65.53 7.66 30.20 NO 

 BOF_RME3 0 0.77000E-02 322028.7 4685090.0 192.0 65.53 7.66 30.20 NO 

 BOF_RME4 0 0.77000E-02 322021.3 4685105.0 192.0 65.53 7.66 30.20 NO 

 BOF_RME5 0 0.77000E-02 322013.9 4685119.5 192.0 65.53 7.66 30.20 NO 

 BOF_RMN1 0 0.77000E-02 321991.2 4685164.5 192.0 57.61 4.47 26.51 NO 

 BOF_RMN2 0 0.77000E-02 321986.9 4685173.0 192.0 57.61 4.47 26.51 NO 

 BOF_RMN3 0 0.77000E-02 321982.7 4685181.5 192.0 57.61 4.47 26.51 NO 

 BOF_RMN4 0 0.77000E-02 321978.3 4685190.0 192.0 57.61 4.47 26.51 NO 

 BOF_RMN5 0 0.77000E-02 321973.8 4685199.0 192.0 57.61 4.47 26.51 NO 

 HND_SCF1 0 0.10160E+00 321254.4 4684513.0 192.0 31.39 7.10 14.60 NO 

 HND_SCF2 0 0.10160E+00 321247.6 4684527.0 192.0 31.39 7.10 14.60 NO 

 HND_SCF3 0 0.10160E+00 321240.7 4684540.5 192.0 31.39 7.10 14.60 NO 

 HND_SCF4 0 0.10160E+00 321233.8 4684554.0 192.0 31.39 7.10 14.60 NO 

 HND_SCF5 0 0.10160E+00 321227.0 4684568.0 192.0 31.39 7.10 14.60 NO 

GROUP ID SOURCE IDs 

 

 ALL BF_B_SS , BF_C_SS , B_CH_RM1, B_CH_RM2, B_CH_RM3, B_CH_RM4, B_CH_RM5, C_CH_RM1, C_CH_RM2, C_CH_RM3, 

C_CH_RM4, BFCCH_BS, 

 LM_UL_BH, HMTRN_BH, BOF_ESP , BOF_BH , BOF_RMW1, BOF_RMW2, BOF_RMW3, BOF_RMW4, BOF_RMW5, BOF_RMW6, 

BOF_RME1, BOF_RME2, 

 BOF_RME3, BOF_RME4, BOF_RME5, BOF_RMN1, BOF_RMN2, BOF_RMN3, BOF_RMN4, BOF_RMN5, DESLF_BH, LRF#1_S , 

LRF2_FLX, COKE_REC, 

 ANEAL_1S, ANEAL_2S, ANEAL_3S, ANEAL_4S, ANEAL_5S, ANEAL_6S, ANEAL_1N, ANEAL_2N, ANEAL_3N, ANEAL_4N, 

ANEAL_5N, RFURN1_1, 

 RFURN1_2, RFURN2_1, RFURN2_2, RFURN3_1, RFURN3_2, HND_SCF1, HND_SCF2, HND_SCF3, HND_SCF4, HND_SCF5, EU0099 

, EU0096 , 

 EU0095 , RG0130 , EU0096A , RG0133 , RG0132 , EU0095A , EU0120 , RG0133A , EU0118 , EU0076 , EU0076A 

, RG0130A , 

 RG0132A , A8648 , A9831 , B2132 , B2169 , B2810 , B2811 , B3518 , B3533 , B3567 , N6631 

, 

 A8640 BF_B_SS , BF_C_SS , B_CH_RM1, B_CH_RM2, B_CH_RM3, B_CH_RM4, B_CH_RM5, C_CH_RM1, C_CH_RM2, C_CH_RM3, 

C_CH_RM4, BFCCH_BS, 

 LM_UL_BH, HMTRN_BH, BOF_ESP , BOF_BH , BOF_RMW1, BOF_RMW2, BOF_RMW3, BOF_RMW4, BOF_RMW5, BOF_RMW6, 

BOF_RME1, BOF_RME2, 

 BOF_RME3, BOF_RME4, BOF_RME5, BOF_RMN1, BOF_RMN2, BOF_RMN3, BOF_RMN4, BOF_RMN5, DESLF_BH, LRF#1_S , 

LRF2_FLX, COKE_REC, 

 ANEAL_1S, ANEAL_2S, ANEAL_3S, ANEAL_4S, ANEAL_5S, ANEAL_6S, ANEAL_1N, ANEAL_2N, ANEAL_3N, ANEAL_4N, 

RFURN1_1, RFURN1_2, 

 RFURN2_1, RFURN2_2, RFURN3_1, RFURN3_2, HND_SCF1, HND_SCF2, HND_SCF3, HND_SCF4, HND_SCF5, 

 A7809 EU0099 , EU0096 , EU0095 , RG0130 , EU0096A , RG0133 , RG0132 , EU0095A , EU0120 , RG0133A , EU0118 

, EU0076 , 

 EU0076A , RG0130A , RG0132A , 

 A8648 A8648 , 

 A9831 A9831 , 

 B2132 B2132 , 

 B2169 B2169 , 
 

 B2810 B2810 , 

 B2811 B2811 , 

 

 

SUMMARY OF MAXIMUM ANNUAL ( 1 YRS) RESULTS *** 

 ALL 1ST HIGHEST VALUE IS 0.44447 AT ( 322122.00, 4672602.00 

 A8640 1ST HIGHEST VALUE IS 0.06301 AT ( 322122.00, 4672602.00 

 A7809 1ST HIGHEST VALUE IS 0.17178 AT ( 322122.00, 4672602.00 

 A8648 1ST HIGHEST VALUE IS 0.01306 AT ( 322122.00, 4672602.00 

 A9831 1ST HIGHEST VALUE IS 0.01817 AT ( 322122.00, 4672602.00 

 B2132 1ST HIGHEST VALUE IS 0.00662 AT ( 322122.00, 4672602.00 

 B2169 1ST HIGHEST VALUE IS 0.12625 AT ( 322122.00, 4672602.00 

 B2810 1ST HIGHEST VALUE IS 0.00191 AT ( 322122.00, 4672602.00 

 B2811 1ST HIGHEST VALUE IS 0.00793 AT ( 322122.00, 4672602.00 

 B3518 1ST HIGHEST VALUE IS 0.00275 AT ( 322122.00, 4672602.00 

 B3533 1ST HIGHEST VALUE IS 0.01534 AT ( 322122.00, 4672602.00 

 B3567 1ST HIGHEST VALUE IS 0.01134 AT ( 322122.00, 4672602.00 

 N6631 1ST HIGHEST VALUE IS 0.00632 AT ( 322122.00, 4672602.00 
2005 AERMOD SUMMARY – DEARBORN MONITOR LOCATION 

RAILYARD REDUCTIONS 

 *** AERMOD - VERSION 07026 *** *** DEARBORN MONITOR IMPACTS *** 

04/29/08 

 *** VOLUME SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- 

 

 CSX_01 0 0.36060E-02 322524.0 4686057.0 192.0 4.25 23.26 3.95 NO 

 CSX_02 0 0.36060E-02 322545.0 4686012.0 192.0 4.25 23.26 3.95 NO 

 CSX_03 0 0.36060E-02 322566.0 4685966.0 192.0 4.25 23.26 3.95 NO 

 CSX_04 0 0.36060E-02 322587.0 4685921.0 192.0 4.25 23.26 3.95 NO 

 CSX_05 0 0.36060E-02 322607.9 4685876.0 192.0 4.25 23.26 3.95 NO 

 CSX_06 0 0.36060E-02 322628.9 4685830.0 192.0 4.25 23.26 3.95 NO 

 CSX_07 0 0.36060E-02 322649.9 4685785.0 192.0 4.25 23.26 3.95 NO 

 CSX_08 0 0.36060E-02 322670.9 4685740.0 192.0 4.25 23.26 3.95 NO 

 CSX_09 0 0.36060E-02 322691.9 4685694.0 192.0 4.25 23.26 3.95 NO 

 CSX_10 0 0.36060E-02 322712.9 4685649.0 192.0 4.25 23.26 3.95 NO 

 CSX_11 0 0.36060E-02 322733.9 4685603.0 192.0 4.25 23.26 3.95 NO 

 CSX_12 0 0.36060E-02 322754.8 4685558.0 192.0 4.25 23.26 3.95 NO 

 CSX_13 0 0.36060E-02 322775.8 4685513.0 192.0 4.25 23.26 3.95 NO 

 CSX_14 0 0.36060E-02 322796.8 4685467.0 192.0 4.25 23.26 3.95 NO 

 CSX_15 0 0.36060E-02 322817.8 4685422.0 192.0 4.25 23.26 3.95 NO 

 CSX_16 0 0.36060E-02 322838.8 4685377.0 192.0 4.25 23.26 3.95 NO 

 SEVER_01 0 0.29250E-03 321271.3 4686627.0 192.0 4.25 23.26 3.95 NO 

 SEVER_02 0 0.29250E-03 321240.7 4686588.0 192.0 4.25 23.26 3.95 NO 

 SEVER_03 0 0.29250E-03 321210.1 4686548.0 192.0 4.25 23.26 3.95 NO 

 SEVER_04 0 0.29250E-03 321179.5 4686509.0 192.0 4.25 23.26 3.95 NO 

 SEVER_05 0 0.29250E-03 321148.9 4686469.0 192.0 4.25 23.26 3.95 NO 

 SEVER_06 0 0.29250E-03 321118.3 4686430.0 192.0 4.25 23.26 3.95 NO 

 SEVER_07 0 0.29250E-03 321087.7 4686390.0 192.0 4.25 23.26 3.95 NO 

 SEVER_08 0 0.29250E-03 321057.1 4686350.0 192.0 4.25 23.26 3.95 NO 

 SEVER_09 0 0.29250E-03 321026.5 4686311.0 192.0 4.25 23.26 3.95 NO 

 SEVER_10 0 0.29250E-03 320995.8 4686271.0 192.0 4.25 23.26 3.95 NO 

 SEVER_11 0 0.29250E-03 320965.3 4686232.0 192.0 4.25 23.26 3.95 NO 

 SEVER_12 0 0.29250E-03 320934.7 4686192.0 192.0 4.25 23.26 3.95 NO 

 SEVER_13 0 0.29250E-03 320904.0 4686153.0 192.0 4.25 23.26 3.95 NO 

 SEVER_14 0 0.29250E-03 320873.4 4686113.0 192.0 4.25 23.26 3.95 NO 

 SEVER_15 0 0.29250E-03 320842.8 4686074.0 192.0 4.25 23.26 3.95 NO 

 CONLV_01 0 0.73150E-03 324682.3 4687492.0 192.0 4.25 23.26 3.95 NO 

 CONLV_02 0 0.73150E-03 324731.7 4687500.0 192.0 4.25 23.26 3.95 NO 

 CONLV_03 0 0.73150E-03 324781.0 4687508.0 192.0 4.25 23.26 3.95 NO 

 CONLV_04 0 0.73150E-03 324830.4 4687516.0 192.0 4.25 23.26 3.95 NO 

 CONLV_05 0 0.73150E-03 324879.8 4687524.0 192.0 4.25 23.26 3.95 NO 

 CONLV_06 0 0.73150E-03 324929.1 4687532.0 192.0 4.25 23.26 3.95 NO 

 CONLV_07 0 0.73150E-03 324978.4 4687540.0 192.0 4.25 23.26 3.95 NO 

 CONLV_08 0 0.73150E-03 325027.8 4687548.0 192.0 4.25 23.26 3.95 NO 

 CONLV_09 0 0.73150E-03 325077.2 4687556.0 192.0 4.25 23.26 3.95 NO 

 *** VOLUME SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- 

 

 CONLV_10 0 0.73150E-03 325126.5 4687564.0 192.0 4.25 23.26 3.95 NO 

 CONLV_11 0 0.73150E-03 325175.9 4687572.0 192.0 4.25 23.26 3.95 NO 

 CONLV_12 0 0.73150E-03 325225.2 4687580.0 192.0 4.25 23.26 3.95 NO 

 CONLV_13 0 0.73150E-03 325274.6 4687588.0 192.0 4.25 23.26 3.95 NO 

 CONLV_14 0 0.73150E-03 325323.9 4687596.0 192.0 4.25 23.26 3.95 NO 

 CONLV_15 0 0.73150E-03 325373.3 4687604.0 192.0 4.25 23.26 3.95 NO 

 CONLV_16 0 0.73150E-03 325422.7 4687612.0 192.0 4.25 23.26 3.95 NO 

 CONLV_17 0 0.73150E-03 325472.0 4687620.0 192.0 4.25 23.26 3.95 NO 

 CONLV_18 0 0.73150E-03 325521.4 4687628.0 192.0 4.25 23.26 3.95 NO 

 NORFK_01 0 0.59770E-03 319338.3 4682375.0 192.0 4.25 23.26 3.95 NO 

 NORFK_02 0 0.59770E-03 319386.9 4682387.0 192.0 4.25 23.26 3.95 NO 

 NORFK_03 0 0.59770E-03 319435.4 4682399.0 192.0 4.25 23.26 3.95 NO 

 NORFK_04 0 0.59770E-03 319484.0 4682411.0 192.0 4.25 23.26 3.95 NO 

 NORFK_05 0 0.59770E-03 319532.5 4682423.0 192.0 4.25 23.26 3.95 NO 

 NORFK_06 0 0.59770E-03 319581.1 4682435.0 192.0 4.25 23.26 3.95 NO 

 NORFK_07 0 0.59770E-03 319629.6 4682447.0 192.0 4.25 23.26 3.95 NO 

 NORFK_08 0 0.59770E-03 319678.2 4682459.0 192.0 4.25 23.26 3.95 NO 

 NORFK_09 0 0.59770E-03 319726.8 4682471.0 192.0 4.25 23.26 3.95 NO 

 NORFK_10 0 0.59770E-03 319775.3 4682483.0 192.0 4.25 23.26 3.95 NO 

 NORFK_11 0 0.59770E-03 319823.8 4682495.0 192.0 4.25 23.26 3.95 NO 

 NORFK_12 0 0.59770E-03 319872.4 4682507.0 192.0 4.25 23.26 3.95 NO 

 NORFK_13 0 0.59770E-03 319921.0 4682518.0 192.0 4.25 23.26 3.95 NO 

 NORFK_14 0 0.59770E-03 319969.5 4682530.0 192.0 4.25 23.26 3.95 NO 

 NORFK_15 0 0.59770E-03 320018.1 4682542.0 192.0 4.25 23.26 3.95 NO 

 NORFK_16 0 0.59770E-03 320066.6 4682554.0 192.0 4.25 23.26 3.95 NO 
 NORFK_17 0 0.59770E-03 320115.2 4682566.0 192.0 4.25 23.26 3.95 NO 

 NORFK_18 0 0.59770E-03 320163.8 4682578.0 192.0 4.25 23.26 3.95 NO 

 NORFK_19 0 0.59770E-03 320212.3 4682590.0 192.0 4.25 23.26 3.95 NO 

 NORFK_20 0 0.59770E-03 320260.8 4682602.0 192.0 4.25 23.26 3.95 NO 

 NORFK_21 0 0.59770E-03 320309.4 4682614.0 192.0 4.25 23.26 3.95 NO 

 NORFK_22 0 0.59770E-03 320358.0 4682626.0 192.0 4.25 23.26 3.95 NO 

 NORFK_23 0 0.59770E-03 320406.5 4682638.0 192.0 4.25 23.26 3.95 NO 

 NORFK_24 0 0.59770E-03 320455.1 4682650.0 192.0 4.25 23.26 3.95 NO 

 NORFK_25 0 0.59770E-03 320503.6 4682662.0 192.0 4.25 23.26 3.95 NO 

 NORFK_26 0 0.59770E-03 320552.2 4682674.0 192.0 4.25 23.26 3.95 NO 

 NORFK_27 0 0.59770E-03 320600.7 4682686.0 192.0 4.25 23.26 3.95 NO 

 NORFK_28 0 0.59770E-03 320649.3 4682698.0 192.0 4.25 23.26 3.95 NO 

 NORFK_29 0 0.59770E-03 320697.8 4682709.0 192.0 4.25 23.26 3.95 NO 

 NORFK_30 0 0.59770E-03 320746.4 4682721.0 192.0 4.25 23.26 3.95 NO 

 NORFK_31 0 0.59770E-03 320794.9 4682733.0 192.0 4.25 23.26 3.95 NO 

 *** VOLUME SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- 

 

 NORFK_32 0 0.59770E-03 320843.5 4682745.0 192.0 4.25 23.26 3.95 NO 

 NORFK_33 0 0.59770E-03 320892.1 4682757.0 192.0 4.25 23.26 3.95 NO 

 NORFK_34 0 0.59770E-03 320940.6 4682769.0 192.0 4.25 23.26 3.95 NO 

 NORFK_35 0 0.59770E-03 320989.2 4682781.0 192.0 4.25 23.26 3.95 NO 

 NORFK_36 0 0.59770E-03 321037.7 4682793.0 192.0 4.25 23.26 3.95 NO 

 NORFK_37 0 0.59770E-03 321086.3 4682805.0 192.0 4.25 23.26 3.95 NO 

 NORFK_38 0 0.59770E-03 321134.8 4682817.0 192.0 4.25 23.26 3.95 NO 

 NORFK_39 0 0.59770E-03 321183.4 4682829.0 192.0 4.25 23.26 3.95 NO 

 NORFK_40 0 0.59770E-03 321231.9 4682841.0 192.0 4.25 23.26 3.95 NO 

 NORFK_41 0 0.59770E-03 321280.5 4682853.0 192.0 4.25 23.26 3.95 NO 

 NORFK_42 0 0.59770E-03 321329.1 4682865.0 192.0 4.25 23.26 3.95 NO 

 NORFK_43 0 0.59770E-03 321377.6 4682877.0 192.0 4.25 23.26 3.95 NO 

 NORFK_44 0 0.59770E-03 321426.2 4682888.0 192.0 4.25 23.26 3.95 NO 

 CONRV_01 0 0.33760E-03 323622.3 4682108.0 192.0 4.25 23.26 3.95 NO 

 CONRV_02 0 0.33760E-03 323608.6 4682060.0 192.0 4.25 23.26 3.95 NO 

 CONRV_03 0 0.33760E-03 323594.9 4682012.0 192.0 4.25 23.26 3.95 NO 

 CONRV_04 0 0.33760E-03 323581.2 4681964.0 192.0 4.25 23.26 3.95 NO 

 CONRV_05 0 0.33760E-03 323567.5 4681916.0 192.0 4.25 23.26 3.95 NO 

 CONRV_06 0 0.33760E-03 323553.8 4681868.0 192.0 4.25 23.26 3.95 NO 

 CONRV_07 0 0.33760E-03 323540.1 4681820.0 192.0 4.25 23.26 3.95 NO 

 CONRV_08 0 0.33760E-03 323526.4 4681772.0 192.0 4.25 23.26 3.95 NO 

 CONRV_09 0 0.33760E-03 323512.7 4681724.0 192.0 4.25 23.26 3.95 NO 

 CONRV_10 0 0.33760E-03 323498.9 4681675.0 192.0 4.25 23.26 3.95 NO 

 CONRV_11 0 0.33760E-03 323485.3 4681627.0 192.0 4.25 23.26 3.95 NO 

 CONRV_12 0 0.33760E-03 323471.5 4681579.0 192.0 4.25 23.26 3.95 NO 

 CONRV_13 0 0.33760E-03 323457.8 4681531.0 192.0 4.25 23.26 3.95 NO 

 CONRV_14 0 0.33760E-03 323444.1 4681483.0 192.0 4.25 23.26 3.95 NO 

 CONRV_15 0 0.33760E-03 323430.4 4681435.0 192.0 4.25 23.26 3.95 NO 

 CONRV_16 0 0.33760E-03 323416.7 4681387.0 192.0 4.25 23.26 3.95 NO 

 CONRV_17 0 0.33760E-03 323403.0 4681339.0 192.0 4.25 23.26 3.95 NO 

 CONRV_18 0 0.33760E-03 323389.3 4681291.0 192.0 4.25 23.26 3.95 NO 

 CONRV_19 0 0.33760E-03 323375.6 4681243.0 192.0 4.25 23.26 3.95 NO 

 CONRV_20 0 0.33760E-03 323361.9 4681195.0 192.0 4.25 23.26 3.95 NO 

 CONRV_21 0 0.33760E-03 323348.2 4681147.0 192.0 4.25 23.26 3.95 NO 

 CONRV_22 0 0.33760E-03 323334.5 4681098.0 192.0 4.25 23.26 3.95 NO 

 CONRV_23 0 0.33760E-03 323320.8 4681050.0 192.0 4.25 23.26 3.95 NO 

 CONRV_24 0 0.33760E-03 323307.0 4681002.0 192.0 4.25 23.26 3.95 NO 

 CONRV_25 0 0.33760E-03 323293.3 4680954.0 192.0 4.25 23.26 3.95 NO 

 CONRV_26 0 0.33760E-03 323279.6 4680906.0 192.0 4.25 23.26 3.95 NO 

 DELRAY_1 0 0.62690E-03 325953.7 4683583.0 192.0 4.25 23.26 3.95 NO 

 *** VOLUME SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- 

 

 DELRAY_2 0 0.62690E-03 325931.9 4683538.0 192.0 4.25 23.26 3.95 NO 

 DELRAY_3 0 0.62690E-03 325910.2 4683493.0 192.0 4.25 23.26 3.95 NO 

 DELRAY_4 0 0.62690E-03 325888.4 4683448.0 192.0 4.25 23.26 3.95 NO 

 DELRAY_5 0 0.62690E-03 325866.6 4683403.0 192.0 4.25 23.26 3.95 NO 

 DELRAY_6 0 0.62690E-03 325844.8 4683358.0 192.0 4.25 23.26 3.95 NO 

 DELRAY_7 0 0.62690E-03 325823.1 4683313.0 192.0 4.25 23.26 3.95 NO 

 USSTL_01 0 0.23420E-02 323661.1 4679390.0 192.0 4.25 23.26 3.95 NO 

 USSTL_02 0 0.23420E-02 323690.8 4679430.0 192.0 4.25 23.26 3.95 NO 

 USSTL_03 0 0.23420E-02 323720.5 4679471.0 192.0 4.25 23.26 3.95 NO 

 USSTL_04 0 0.23420E-02 323750.3 4679511.0 192.0 4.25 23.26 3.95 NO 

 USSTL_05 0 0.23420E-02 323780.0 4679551.0 192.0 4.25 23.26 3.95 NO 

 USSTL_06 0 0.23420E-02 323809.7 4679591.0 192.0 4.25 23.26 3.95 NO 

 USSTL_07 0 0.23420E-02 323839.4 4679631.0 192.0 4.25 23.26 3.95 NO 

 USSTL_08 0 0.23420E-02 323869.2 4679672.0 192.0 4.25 23.26 3.95 NO 

 USSTL_09 0 0.23420E-02 325180.8 4681844.0 192.0 4.25 23.26 3.95 NO 

 USSTL_10 0 0.23420E-02 325230.7 4681841.0 192.0 4.25 23.26 3.95 NO 

 USSTL_11 0 0.23420E-02 325280.7 4681838.0 192.0 4.25 23.26 3.95 NO 

 USSTL_12 0 0.23420E-02 325330.6 4681836.0 192.0 4.25 23.26 3.95 NO 

 USSTL_13 0 0.23420E-02 325380.5 4681833.0 192.0 4.25 23.26 3.95 NO 

 USSTL_14 0 0.23420E-02 325430.4 4681830.0 192.0 4.25 23.26 3.95 NO 
 USSTL_15 0 0.23420E-02 325480.3 4681827.0 192.0 4.25 23.26 3.95 NO 

GROUP ID SOURCE IDs 

 

 ALL CSX_01 , CSX_02 , CSX_03 , CSX_04 , CSX_05 , CSX_06 , CSX_07 , CSX_08 , CSX_09 , CSX_10 , CSX_11 

, CSX_12 , 

 CSX_13 , CSX_14 , CSX_15 , CSX_16 , SEVER_01, SEVER_02, SEVER_03, SEVER_04, SEVER_05, SEVER_06, 

SEVER_07, SEVER_08, 

 SEVER_09, SEVER_10, SEVER_11, SEVER_12, SEVER_13, SEVER_14, SEVER_15, CONLV_01, CONLV_02, CONLV_03, 

CONLV_04, CONLV_05, 

 CONLV_06, CONLV_07, CONLV_08, CONLV_09, CONLV_10, CONLV_11, CONLV_12, CONLV_13, CONLV_14, CONLV_15, 

CONLV_16, CONLV_17, 

 CONLV_18, NORFK_01, NORFK_02, NORFK_03, NORFK_04, NORFK_05, NORFK_06, NORFK_07, NORFK_08, NORFK_09, 

NORFK_10, NORFK_11, 

 NORFK_12, NORFK_13, NORFK_14, NORFK_15, NORFK_16, NORFK_17, NORFK_18, NORFK_19, NORFK_20, NORFK_21, 

NORFK_22, NORFK_23, 

 NORFK_24, NORFK_25, NORFK_26, NORFK_27, NORFK_28, NORFK_29, NORFK_30, NORFK_31, NORFK_32, NORFK_33, 

NORFK_34, NORFK_35, 

 NORFK_36, NORFK_37, NORFK_38, NORFK_39, NORFK_40, NORFK_41, NORFK_42, NORFK_43, NORFK_44, CONRV_01, 

CONRV_02, CONRV_03, 

 CONRV_04, CONRV_05, CONRV_06, CONRV_07, CONRV_08, CONRV_09, CONRV_10, CONRV_11, CONRV_12, CONRV_13, 

CONRV_14, CONRV_15, 

 CONRV_16, CONRV_17, CONRV_18, CONRV_19, CONRV_20, CONRV_21, CONRV_22, CONRV_23, CONRV_24, CONRV_25, 

CONRV_26, DELRAY_1, 

 DELRAY_2, DELRAY_3, DELRAY_4, DELRAY_5, DELRAY_6, DELRAY_7, USSTL_01, USSTL_02, USSTL_03, USSTL_04, 

USSTL_05, USSTL_06, 

 USSTL_07, USSTL_08, USSTL_09, USSTL_10, USSTL_11, USSTL_12, USSTL_13, USSTL_14, USSTL_15, 

 CSX CSX_01 , CSX_02 , CSX_03 , CSX_04 , CSX_05 , CSX_06 , CSX_07 , CSX_08 , CSX_09 , CSX_10 , CSX_11 

, CSX_12 , 

 CSX_13 , CSX_14 , CSX_15 , CSX_16 , 

 SEVERSTA SEVER_01, SEVER_02, SEVER_03, SEVER_04, SEVER_05, SEVER_06, SEVER_07, SEVER_08, SEVER_09, SEVER_10, 

SEVER_11, SEVER_12, 

 SEVER_13, SEVER_14, SEVER_15, 

 CONLIVER CONLV_01, CONLV_02, CONLV_03, CONLV_04, CONLV_05, CONLV_06, CONLV_07, CONLV_08, CONLV_09, CONLV_10, 

CONLV_11, CONLV_12, 

 CONLV_13, CONLV_14, CONLV_15, CONLV_16, CONLV_17, CONLV_18, 

 NORFOLK NORFK_01, NORFK_02, NORFK_03, NORFK_04, NORFK_05, NORFK_06, NORFK_07, NORFK_08, NORFK_09, NORFK_10, 

NORFK_11, NORFK_12, 

 NORFK_13, NORFK_14, NORFK_15, NORFK_16, NORFK_17, NORFK_18, NORFK_19, NORFK_20, NORFK_21, NORFK_22, 

NORFK_23, NORFK_24, 

 

 

SUMMARY OF MAXIMUM ANNUAL ( 1 YRS) RESULTS *** 

 ALL 1ST HIGHEST VALUE IS 0.92564 AT ( 322805.00, 4685985.00 

 CSX 1ST HIGHEST VALUE IS 0.90488 AT ( 322805.00, 4685985.00 

 SEVERSTA 1ST HIGHEST VALUE IS 0.00449 AT ( 322805.00, 4685985.00 

 CONLIVER 1ST HIGHEST VALUE IS 0.00381 AT ( 322805.00, 4685985.00 

 NORFOLK 1ST HIGHEST VALUE IS 0.00598 AT ( 322805.00, 4685985.00 

 CONRIVER 1ST HIGHEST VALUE IS 0.00227 AT ( 322805.00, 4685985.00 

 DELRAY 1ST HIGHEST VALUE IS 0.00055 AT ( 322805.00, 4685985.00 

 USSTEEL 1ST HIGHEST VALUE IS 0.00486 AT ( 322805.00, 4685985.00 
2005 AERMOD SUMMARY – SWHS MONITOR LOCATION 

RAILYARD REDUCTIONS 

*** AERMOD - VERSION 07026 *** *** DEARBORN MONITOR IMPACTS *** 

04/29/08 

 *** VOLUME SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- 

 

 CSX_01 0 0.36060E-02 322524.0 4686057.0 192.0 4.25 23.26 3.95 NO 

 CSX_02 0 0.36060E-02 322545.0 4686012.0 192.0 4.25 23.26 3.95 NO 

 CSX_03 0 0.36060E-02 322566.0 4685966.0 192.0 4.25 23.26 3.95 NO 

 CSX_04 0 0.36060E-02 322587.0 4685921.0 192.0 4.25 23.26 3.95 NO 

 CSX_05 0 0.36060E-02 322607.9 4685876.0 192.0 4.25 23.26 3.95 NO 

 CSX_06 0 0.36060E-02 322628.9 4685830.0 192.0 4.25 23.26 3.95 NO 

 CSX_07 0 0.36060E-02 322649.9 4685785.0 192.0 4.25 23.26 3.95 NO 

 CSX_08 0 0.36060E-02 322670.9 4685740.0 192.0 4.25 23.26 3.95 NO 

 CSX_09 0 0.36060E-02 322691.9 4685694.0 192.0 4.25 23.26 3.95 NO 

 CSX_10 0 0.36060E-02 322712.9 4685649.0 192.0 4.25 23.26 3.95 NO 

 CSX_11 0 0.36060E-02 322733.9 4685603.0 192.0 4.25 23.26 3.95 NO 

 CSX_12 0 0.36060E-02 322754.8 4685558.0 192.0 4.25 23.26 3.95 NO 

 CSX_13 0 0.36060E-02 322775.8 4685513.0 192.0 4.25 23.26 3.95 NO 

 CSX_14 0 0.36060E-02 322796.8 4685467.0 192.0 4.25 23.26 3.95 NO 

 CSX_15 0 0.36060E-02 322817.8 4685422.0 192.0 4.25 23.26 3.95 NO 

 CSX_16 0 0.36060E-02 322838.8 4685377.0 192.0 4.25 23.26 3.95 NO 

 SEVER_01 0 0.29250E-03 321271.3 4686627.0 192.0 4.25 23.26 3.95 NO 

 SEVER_02 0 0.29250E-03 321240.7 4686588.0 192.0 4.25 23.26 3.95 NO 

 SEVER_03 0 0.29250E-03 321210.1 4686548.0 192.0 4.25 23.26 3.95 NO 

 SEVER_04 0 0.29250E-03 321179.5 4686509.0 192.0 4.25 23.26 3.95 NO 

 SEVER_05 0 0.29250E-03 321148.9 4686469.0 192.0 4.25 23.26 3.95 NO 

 SEVER_06 0 0.29250E-03 321118.3 4686430.0 192.0 4.25 23.26 3.95 NO 

 SEVER_07 0 0.29250E-03 321087.7 4686390.0 192.0 4.25 23.26 3.95 NO 

 SEVER_08 0 0.29250E-03 321057.1 4686350.0 192.0 4.25 23.26 3.95 NO 

 SEVER_09 0 0.29250E-03 321026.5 4686311.0 192.0 4.25 23.26 3.95 NO 

 SEVER_10 0 0.29250E-03 320995.8 4686271.0 192.0 4.25 23.26 3.95 NO 

 SEVER_11 0 0.29250E-03 320965.3 4686232.0 192.0 4.25 23.26 3.95 NO 

 SEVER_12 0 0.29250E-03 320934.7 4686192.0 192.0 4.25 23.26 3.95 NO 

 SEVER_13 0 0.29250E-03 320904.0 4686153.0 192.0 4.25 23.26 3.95 NO 

 SEVER_14 0 0.29250E-03 320873.4 4686113.0 192.0 4.25 23.26 3.95 NO 

 SEVER_15 0 0.29250E-03 320842.8 4686074.0 192.0 4.25 23.26 3.95 NO 

 CONLV_01 0 0.73150E-03 324682.3 4687492.0 192.0 4.25 23.26 3.95 NO 

 CONLV_02 0 0.73150E-03 324731.7 4687500.0 192.0 4.25 23.26 3.95 NO 

 CONLV_03 0 0.73150E-03 324781.0 4687508.0 192.0 4.25 23.26 3.95 NO 

 CONLV_04 0 0.73150E-03 324830.4 4687516.0 192.0 4.25 23.26 3.95 NO 

 CONLV_05 0 0.73150E-03 324879.8 4687524.0 192.0 4.25 23.26 3.95 NO 

 CONLV_06 0 0.73150E-03 324929.1 4687532.0 192.0 4.25 23.26 3.95 NO 

 CONLV_07 0 0.73150E-03 324978.4 4687540.0 192.0 4.25 23.26 3.95 NO 

 CONLV_08 0 0.73150E-03 325027.8 4687548.0 192.0 4.25 23.26 3.95 NO 

 CONLV_09 0 0.73150E-03 325077.2 4687556.0 192.0 4.25 23.26 3.95 NO 

 *** VOLUME SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- 

 

 CONLV_10 0 0.73150E-03 325126.5 4687564.0 192.0 4.25 23.26 3.95 NO 

 CONLV_11 0 0.73150E-03 325175.9 4687572.0 192.0 4.25 23.26 3.95 NO 

 CONLV_12 0 0.73150E-03 325225.2 4687580.0 192.0 4.25 23.26 3.95 NO 

 CONLV_13 0 0.73150E-03 325274.6 4687588.0 192.0 4.25 23.26 3.95 NO 

 CONLV_14 0 0.73150E-03 325323.9 4687596.0 192.0 4.25 23.26 3.95 NO 

 CONLV_15 0 0.73150E-03 325373.3 4687604.0 192.0 4.25 23.26 3.95 NO 

 CONLV_16 0 0.73150E-03 325422.7 4687612.0 192.0 4.25 23.26 3.95 NO 

 CONLV_17 0 0.73150E-03 325472.0 4687620.0 192.0 4.25 23.26 3.95 NO 

 CONLV_18 0 0.73150E-03 325521.4 4687628.0 192.0 4.25 23.26 3.95 NO 

 NORFK_01 0 0.59770E-03 319338.3 4682375.0 192.0 4.25 23.26 3.95 NO 

 NORFK_02 0 0.59770E-03 319386.9 4682387.0 192.0 4.25 23.26 3.95 NO 

 NORFK_03 0 0.59770E-03 319435.4 4682399.0 192.0 4.25 23.26 3.95 NO 

 NORFK_04 0 0.59770E-03 319484.0 4682411.0 192.0 4.25 23.26 3.95 NO 

 NORFK_05 0 0.59770E-03 319532.5 4682423.0 192.0 4.25 23.26 3.95 NO 

 NORFK_06 0 0.59770E-03 319581.1 4682435.0 192.0 4.25 23.26 3.95 NO 

 NORFK_07 0 0.59770E-03 319629.6 4682447.0 192.0 4.25 23.26 3.95 NO 

 NORFK_08 0 0.59770E-03 319678.2 4682459.0 192.0 4.25 23.26 3.95 NO 

 NORFK_09 0 0.59770E-03 319726.8 4682471.0 192.0 4.25 23.26 3.95 NO 

 NORFK_10 0 0.59770E-03 319775.3 4682483.0 192.0 4.25 23.26 3.95 NO 

 NORFK_11 0 0.59770E-03 319823.8 4682495.0 192.0 4.25 23.26 3.95 NO 

 NORFK_12 0 0.59770E-03 319872.4 4682507.0 192.0 4.25 23.26 3.95 NO 

 NORFK_13 0 0.59770E-03 319921.0 4682518.0 192.0 4.25 23.26 3.95 NO 

 NORFK_14 0 0.59770E-03 319969.5 4682530.0 192.0 4.25 23.26 3.95 NO 

 NORFK_15 0 0.59770E-03 320018.1 4682542.0 192.0 4.25 23.26 3.95 NO 

 NORFK_16 0 0.59770E-03 320066.6 4682554.0 192.0 4.25 23.26 3.95 NO 
 NORFK_17 0 0.59770E-03 320115.2 4682566.0 192.0 4.25 23.26 3.95 NO 

 NORFK_18 0 0.59770E-03 320163.8 4682578.0 192.0 4.25 23.26 3.95 NO 

 NORFK_19 0 0.59770E-03 320212.3 4682590.0 192.0 4.25 23.26 3.95 NO 

 NORFK_20 0 0.59770E-03 320260.8 4682602.0 192.0 4.25 23.26 3.95 NO 

 NORFK_21 0 0.59770E-03 320309.4 4682614.0 192.0 4.25 23.26 3.95 NO 

 NORFK_22 0 0.59770E-03 320358.0 4682626.0 192.0 4.25 23.26 3.95 NO 

 NORFK_23 0 0.59770E-03 320406.5 4682638.0 192.0 4.25 23.26 3.95 NO 

 NORFK_24 0 0.59770E-03 320455.1 4682650.0 192.0 4.25 23.26 3.95 NO 

 NORFK_25 0 0.59770E-03 320503.6 4682662.0 192.0 4.25 23.26 3.95 NO 

 NORFK_26 0 0.59770E-03 320552.2 4682674.0 192.0 4.25 23.26 3.95 NO 

 NORFK_27 0 0.59770E-03 320600.7 4682686.0 192.0 4.25 23.26 3.95 NO 

 NORFK_28 0 0.59770E-03 320649.3 4682698.0 192.0 4.25 23.26 3.95 NO 

 NORFK_29 0 0.59770E-03 320697.8 4682709.0 192.0 4.25 23.26 3.95 NO 

 NORFK_30 0 0.59770E-03 320746.4 4682721.0 192.0 4.25 23.26 3.95 NO 

 NORFK_31 0 0.59770E-03 320794.9 4682733.0 192.0 4.25 23.26 3.95 NO 

 *** VOLUME SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- 

 

 NORFK_32 0 0.59770E-03 320843.5 4682745.0 192.0 4.25 23.26 3.95 NO 

 NORFK_33 0 0.59770E-03 320892.1 4682757.0 192.0 4.25 23.26 3.95 NO 

 NORFK_34 0 0.59770E-03 320940.6 4682769.0 192.0 4.25 23.26 3.95 NO 

 NORFK_35 0 0.59770E-03 320989.2 4682781.0 192.0 4.25 23.26 3.95 NO 

 NORFK_36 0 0.59770E-03 321037.7 4682793.0 192.0 4.25 23.26 3.95 NO 

 NORFK_37 0 0.59770E-03 321086.3 4682805.0 192.0 4.25 23.26 3.95 NO 

 NORFK_38 0 0.59770E-03 321134.8 4682817.0 192.0 4.25 23.26 3.95 NO 

 NORFK_39 0 0.59770E-03 321183.4 4682829.0 192.0 4.25 23.26 3.95 NO 

 NORFK_40 0 0.59770E-03 321231.9 4682841.0 192.0 4.25 23.26 3.95 NO 

 NORFK_41 0 0.59770E-03 321280.5 4682853.0 192.0 4.25 23.26 3.95 NO 

 NORFK_42 0 0.59770E-03 321329.1 4682865.0 192.0 4.25 23.26 3.95 NO 

 NORFK_43 0 0.59770E-03 321377.6 4682877.0 192.0 4.25 23.26 3.95 NO 

 NORFK_44 0 0.59770E-03 321426.2 4682888.0 192.0 4.25 23.26 3.95 NO 

 CONRV_01 0 0.33760E-03 323622.3 4682108.0 192.0 4.25 23.26 3.95 NO 

 CONRV_02 0 0.33760E-03 323608.6 4682060.0 192.0 4.25 23.26 3.95 NO 

 CONRV_03 0 0.33760E-03 323594.9 4682012.0 192.0 4.25 23.26 3.95 NO 

 CONRV_04 0 0.33760E-03 323581.2 4681964.0 192.0 4.25 23.26 3.95 NO 

 CONRV_05 0 0.33760E-03 323567.5 4681916.0 192.0 4.25 23.26 3.95 NO 

 CONRV_06 0 0.33760E-03 323553.8 4681868.0 192.0 4.25 23.26 3.95 NO 

 CONRV_07 0 0.33760E-03 323540.1 4681820.0 192.0 4.25 23.26 3.95 NO 

 CONRV_08 0 0.33760E-03 323526.4 4681772.0 192.0 4.25 23.26 3.95 NO 

 CONRV_09 0 0.33760E-03 323512.7 4681724.0 192.0 4.25 23.26 3.95 NO 

 CONRV_10 0 0.33760E-03 323498.9 4681675.0 192.0 4.25 23.26 3.95 NO 

 CONRV_11 0 0.33760E-03 323485.3 4681627.0 192.0 4.25 23.26 3.95 NO 

 CONRV_12 0 0.33760E-03 323471.5 4681579.0 192.0 4.25 23.26 3.95 NO 

 CONRV_13 0 0.33760E-03 323457.8 4681531.0 192.0 4.25 23.26 3.95 NO 

 CONRV_14 0 0.33760E-03 323444.1 4681483.0 192.0 4.25 23.26 3.95 NO 

 CONRV_15 0 0.33760E-03 323430.4 4681435.0 192.0 4.25 23.26 3.95 NO 

 CONRV_16 0 0.33760E-03 323416.7 4681387.0 192.0 4.25 23.26 3.95 NO 

 CONRV_17 0 0.33760E-03 323403.0 4681339.0 192.0 4.25 23.26 3.95 NO 

 CONRV_18 0 0.33760E-03 323389.3 4681291.0 192.0 4.25 23.26 3.95 NO 

 CONRV_19 0 0.33760E-03 323375.6 4681243.0 192.0 4.25 23.26 3.95 NO 

 CONRV_20 0 0.33760E-03 323361.9 4681195.0 192.0 4.25 23.26 3.95 NO 

 CONRV_21 0 0.33760E-03 323348.2 4681147.0 192.0 4.25 23.26 3.95 NO 

 CONRV_22 0 0.33760E-03 323334.5 4681098.0 192.0 4.25 23.26 3.95 NO 

 CONRV_23 0 0.33760E-03 323320.8 4681050.0 192.0 4.25 23.26 3.95 NO 

 CONRV_24 0 0.33760E-03 323307.0 4681002.0 192.0 4.25 23.26 3.95 NO 

 CONRV_25 0 0.33760E-03 323293.3 4680954.0 192.0 4.25 23.26 3.95 NO 

 CONRV_26 0 0.33760E-03 323279.6 4680906.0 192.0 4.25 23.26 3.95 NO 

 DELRAY_1 0 0.62690E-03 325953.7 4683583.0 192.0 4.25 23.26 3.95 NO 

 *** VOLUME SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- 

 

 DELRAY_2 0 0.62690E-03 325931.9 4683538.0 192.0 4.25 23.26 3.95 NO 

 DELRAY_3 0 0.62690E-03 325910.2 4683493.0 192.0 4.25 23.26 3.95 NO 

 DELRAY_4 0 0.62690E-03 325888.4 4683448.0 192.0 4.25 23.26 3.95 NO 

 DELRAY_5 0 0.62690E-03 325866.6 4683403.0 192.0 4.25 23.26 3.95 NO 

 DELRAY_6 0 0.62690E-03 325844.8 4683358.0 192.0 4.25 23.26 3.95 NO 

 DELRAY_7 0 0.62690E-03 325823.1 4683313.0 192.0 4.25 23.26 3.95 NO 

 USSTL_01 0 0.23420E-02 323661.1 4679390.0 192.0 4.25 23.26 3.95 NO 

 USSTL_02 0 0.23420E-02 323690.8 4679430.0 192.0 4.25 23.26 3.95 NO 

 USSTL_03 0 0.23420E-02 323720.5 4679471.0 192.0 4.25 23.26 3.95 NO 

 USSTL_04 0 0.23420E-02 323750.3 4679511.0 192.0 4.25 23.26 3.95 NO 

 USSTL_05 0 0.23420E-02 323780.0 4679551.0 192.0 4.25 23.26 3.95 NO 

 USSTL_06 0 0.23420E-02 323809.7 4679591.0 192.0 4.25 23.26 3.95 NO 

 USSTL_07 0 0.23420E-02 323839.4 4679631.0 192.0 4.25 23.26 3.95 NO 

 USSTL_08 0 0.23420E-02 323869.2 4679672.0 192.0 4.25 23.26 3.95 NO 

 USSTL_09 0 0.23420E-02 325180.8 4681844.0 192.0 4.25 23.26 3.95 NO 

 USSTL_10 0 0.23420E-02 325230.7 4681841.0 192.0 4.25 23.26 3.95 NO 

 USSTL_11 0 0.23420E-02 325280.7 4681838.0 192.0 4.25 23.26 3.95 NO 

 USSTL_12 0 0.23420E-02 325330.6 4681836.0 192.0 4.25 23.26 3.95 NO 

 USSTL_13 0 0.23420E-02 325380.5 4681833.0 192.0 4.25 23.26 3.95 NO 

 USSTL_14 0 0.23420E-02 325430.4 4681830.0 192.0 4.25 23.26 3.95 NO 
 USSTL_15 0 0.23420E-02 325480.3 4681827.0 192.0 4.25 23.26 3.95 NO 

GROUP ID SOURCE IDs 

 

 ALL CSX_01 , CSX_02 , CSX_03 , CSX_04 , CSX_05 , CSX_06 , CSX_07 , CSX_08 , CSX_09 , CSX_10 , CSX_11 

, CSX_12 , 

 CSX_13 , CSX_14 , CSX_15 , CSX_16 , SEVER_01, SEVER_02, SEVER_03, SEVER_04, SEVER_05, SEVER_06, 

SEVER_07, SEVER_08, 

 SEVER_09, SEVER_10, SEVER_11, SEVER_12, SEVER_13, SEVER_14, SEVER_15, CONLV_01, CONLV_02, CONLV_03, 

CONLV_04, CONLV_05, 

 CONLV_06, CONLV_07, CONLV_08, CONLV_09, CONLV_10, CONLV_11, CONLV_12, CONLV_13, CONLV_14, CONLV_15, 

CONLV_16, CONLV_17, 

 CONLV_18, NORFK_01, NORFK_02, NORFK_03, NORFK_04, NORFK_05, NORFK_06, NORFK_07, NORFK_08, NORFK_09, 

NORFK_10, NORFK_11, 

 NORFK_12, NORFK_13, NORFK_14, NORFK_15, NORFK_16, NORFK_17, NORFK_18, NORFK_19, NORFK_20, NORFK_21, 

NORFK_22, NORFK_23, 

 NORFK_24, NORFK_25, NORFK_26, NORFK_27, NORFK_28, NORFK_29, NORFK_30, NORFK_31, NORFK_32, NORFK_33, 

NORFK_34, NORFK_35, 

 NORFK_36, NORFK_37, NORFK_38, NORFK_39, NORFK_40, NORFK_41, NORFK_42, NORFK_43, NORFK_44, CONRV_01, 

CONRV_02, CONRV_03, 

 CONRV_04, CONRV_05, CONRV_06, CONRV_07, CONRV_08, CONRV_09, CONRV_10, CONRV_11, CONRV_12, CONRV_13, 

CONRV_14, CONRV_15, 

 CONRV_16, CONRV_17, CONRV_18, CONRV_19, CONRV_20, CONRV_21, CONRV_22, CONRV_23, CONRV_24, CONRV_25, 

CONRV_26, DELRAY_1, 

 DELRAY_2, DELRAY_3, DELRAY_4, DELRAY_5, DELRAY_6, DELRAY_7, USSTL_01, USSTL_02, USSTL_03, USSTL_04, 

USSTL_05, USSTL_06, 

 USSTL_07, USSTL_08, USSTL_09, USSTL_10, USSTL_11, USSTL_12, USSTL_13, USSTL_14, USSTL_15, 

 CSX CSX_01 , CSX_02 , CSX_03 , CSX_04 , CSX_05 , CSX_06 , CSX_07 , CSX_08 , CSX_09 , CSX_10 , CSX_11 

, CSX_12 , 

 CSX_13 , CSX_14 , CSX_15 , CSX_16 , 

 SEVERSTA SEVER_01, SEVER_02, SEVER_03, SEVER_04, SEVER_05, SEVER_06, SEVER_07, SEVER_08, SEVER_09, SEVER_10, 

SEVER_11, SEVER_12, 

 SEVER_13, SEVER_14, SEVER_15, 

 CONLIVER CONLV_01, CONLV_02, CONLV_03, CONLV_04, CONLV_05, CONLV_06, CONLV_07, CONLV_08, CONLV_09, CONLV_10, 

CONLV_11, CONLV_12, 

 CONLV_13, CONLV_14, CONLV_15, CONLV_16, CONLV_17, CONLV_18, 

 NORFOLK NORFK_01, NORFK_02, NORFK_03, NORFK_04, NORFK_05, NORFK_06, NORFK_07, NORFK_08, NORFK_09, NORFK_10, 

NORFK_11, NORFK_12, 

 NORFK_13, NORFK_14, NORFK_15, NORFK_16, NORFK_17, NORFK_18, NORFK_19, NORFK_20, NORFK_21, NORFK_22, 

NORFK_23, NORFK_24, 

 

 

SUMMARY OF MAXIMUM ANNUAL ( 1 YRS) RESULTS *** 

 ALL 1ST HIGHEST VALUE IS 0.04822 AT ( 326344.00, 4685318.00 

 CSX 1ST HIGHEST VALUE IS 0.01734 AT ( 326344.00, 4685318.00 

 SEVERSTA 1ST HIGHEST VALUE IS 0.00076 AT ( 326344.00, 4685318.00 

 CONLIVER 1ST HIGHEST VALUE IS 0.00598 AT ( 326344.00, 4685318.00 

 NORFOLK 1ST HIGHEST VALUE IS 0.00248 AT ( 326344.00, 4685318.00 

 CONRIVER 1ST HIGHEST VALUE IS 0.00117 AT ( 326344.00, 4685318.00 

 DELRAY 1ST HIGHEST VALUE IS 0.00730 AT ( 326344.00, 4685318.00 

 USSTEEL 1ST HIGHEST VALUE IS 0.01331 AT ( 326344.00, 4685318.00 
2005 AERMOD SUMMARY – WYANDOTTE MONITOR 

LOCATION 

RAILYARD REDUCTIONS 

*** AERMOD - VERSION 07026 *** *** DEARBORN MONITOR IMPACTS *** 

04/29/08 

 *** VOLUME SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- 

 

 CSX_01 0 0.36060E-02 322524.0 4686057.0 192.0 4.25 23.26 3.95 NO 

 CSX_02 0 0.36060E-02 322545.0 4686012.0 192.0 4.25 23.26 3.95 NO 

 CSX_03 0 0.36060E-02 322566.0 4685966.0 192.0 4.25 23.26 3.95 NO 

 CSX_04 0 0.36060E-02 322587.0 4685921.0 192.0 4.25 23.26 3.95 NO 

 CSX_05 0 0.36060E-02 322607.9 4685876.0 192.0 4.25 23.26 3.95 NO 

 CSX_06 0 0.36060E-02 322628.9 4685830.0 192.0 4.25 23.26 3.95 NO 

 CSX_07 0 0.36060E-02 322649.9 4685785.0 192.0 4.25 23.26 3.95 NO 

 CSX_08 0 0.36060E-02 322670.9 4685740.0 192.0 4.25 23.26 3.95 NO 

 CSX_09 0 0.36060E-02 322691.9 4685694.0 192.0 4.25 23.26 3.95 NO 

 CSX_10 0 0.36060E-02 322712.9 4685649.0 192.0 4.25 23.26 3.95 NO 

 CSX_11 0 0.36060E-02 322733.9 4685603.0 192.0 4.25 23.26 3.95 NO 

 CSX_12 0 0.36060E-02 322754.8 4685558.0 192.0 4.25 23.26 3.95 NO 

 CSX_13 0 0.36060E-02 322775.8 4685513.0 192.0 4.25 23.26 3.95 NO 

 CSX_14 0 0.36060E-02 322796.8 4685467.0 192.0 4.25 23.26 3.95 NO 

 CSX_15 0 0.36060E-02 322817.8 4685422.0 192.0 4.25 23.26 3.95 NO 

 CSX_16 0 0.36060E-02 322838.8 4685377.0 192.0 4.25 23.26 3.95 NO 

 SEVER_01 0 0.29250E-03 321271.3 4686627.0 192.0 4.25 23.26 3.95 NO 

 SEVER_02 0 0.29250E-03 321240.7 4686588.0 192.0 4.25 23.26 3.95 NO 

 SEVER_03 0 0.29250E-03 321210.1 4686548.0 192.0 4.25 23.26 3.95 NO 

 SEVER_04 0 0.29250E-03 321179.5 4686509.0 192.0 4.25 23.26 3.95 NO 

 SEVER_05 0 0.29250E-03 321148.9 4686469.0 192.0 4.25 23.26 3.95 NO 

 SEVER_06 0 0.29250E-03 321118.3 4686430.0 192.0 4.25 23.26 3.95 NO 

 SEVER_07 0 0.29250E-03 321087.7 4686390.0 192.0 4.25 23.26 3.95 NO 

 SEVER_08 0 0.29250E-03 321057.1 4686350.0 192.0 4.25 23.26 3.95 NO 

 SEVER_09 0 0.29250E-03 321026.5 4686311.0 192.0 4.25 23.26 3.95 NO 

 SEVER_10 0 0.29250E-03 320995.8 4686271.0 192.0 4.25 23.26 3.95 NO 

 SEVER_11 0 0.29250E-03 320965.3 4686232.0 192.0 4.25 23.26 3.95 NO 

 SEVER_12 0 0.29250E-03 320934.7 4686192.0 192.0 4.25 23.26 3.95 NO 

 SEVER_13 0 0.29250E-03 320904.0 4686153.0 192.0 4.25 23.26 3.95 NO 

 SEVER_14 0 0.29250E-03 320873.4 4686113.0 192.0 4.25 23.26 3.95 NO 

 SEVER_15 0 0.29250E-03 320842.8 4686074.0 192.0 4.25 23.26 3.95 NO 

 CONLV_01 0 0.73150E-03 324682.3 4687492.0 192.0 4.25 23.26 3.95 NO 

 CONLV_02 0 0.73150E-03 324731.7 4687500.0 192.0 4.25 23.26 3.95 NO 

 CONLV_03 0 0.73150E-03 324781.0 4687508.0 192.0 4.25 23.26 3.95 NO 

 CONLV_04 0 0.73150E-03 324830.4 4687516.0 192.0 4.25 23.26 3.95 NO 

 CONLV_05 0 0.73150E-03 324879.8 4687524.0 192.0 4.25 23.26 3.95 NO 

 CONLV_06 0 0.73150E-03 324929.1 4687532.0 192.0 4.25 23.26 3.95 NO 

 CONLV_07 0 0.73150E-03 324978.4 4687540.0 192.0 4.25 23.26 3.95 NO 

 CONLV_08 0 0.73150E-03 325027.8 4687548.0 192.0 4.25 23.26 3.95 NO 

 CONLV_09 0 0.73150E-03 325077.2 4687556.0 192.0 4.25 23.26 3.95 NO 

 *** VOLUME SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- 

 

 CONLV_10 0 0.73150E-03 325126.5 4687564.0 192.0 4.25 23.26 3.95 NO 

 CONLV_11 0 0.73150E-03 325175.9 4687572.0 192.0 4.25 23.26 3.95 NO 

 CONLV_12 0 0.73150E-03 325225.2 4687580.0 192.0 4.25 23.26 3.95 NO 

 CONLV_13 0 0.73150E-03 325274.6 4687588.0 192.0 4.25 23.26 3.95 NO 

 CONLV_14 0 0.73150E-03 325323.9 4687596.0 192.0 4.25 23.26 3.95 NO 

 CONLV_15 0 0.73150E-03 325373.3 4687604.0 192.0 4.25 23.26 3.95 NO 

 CONLV_16 0 0.73150E-03 325422.7 4687612.0 192.0 4.25 23.26 3.95 NO 

 CONLV_17 0 0.73150E-03 325472.0 4687620.0 192.0 4.25 23.26 3.95 NO 

 CONLV_18 0 0.73150E-03 325521.4 4687628.0 192.0 4.25 23.26 3.95 NO 

 NORFK_01 0 0.59770E-03 319338.3 4682375.0 192.0 4.25 23.26 3.95 NO 

 NORFK_02 0 0.59770E-03 319386.9 4682387.0 192.0 4.25 23.26 3.95 NO 

 NORFK_03 0 0.59770E-03 319435.4 4682399.0 192.0 4.25 23.26 3.95 NO 

 NORFK_04 0 0.59770E-03 319484.0 4682411.0 192.0 4.25 23.26 3.95 NO 

 NORFK_05 0 0.59770E-03 319532.5 4682423.0 192.0 4.25 23.26 3.95 NO 

 NORFK_06 0 0.59770E-03 319581.1 4682435.0 192.0 4.25 23.26 3.95 NO 

 NORFK_07 0 0.59770E-03 319629.6 4682447.0 192.0 4.25 23.26 3.95 NO 

 NORFK_08 0 0.59770E-03 319678.2 4682459.0 192.0 4.25 23.26 3.95 NO 

 NORFK_09 0 0.59770E-03 319726.8 4682471.0 192.0 4.25 23.26 3.95 NO 

 NORFK_10 0 0.59770E-03 319775.3 4682483.0 192.0 4.25 23.26 3.95 NO 

 NORFK_11 0 0.59770E-03 319823.8 4682495.0 192.0 4.25 23.26 3.95 NO 

 NORFK_12 0 0.59770E-03 319872.4 4682507.0 192.0 4.25 23.26 3.95 NO 

 NORFK_13 0 0.59770E-03 319921.0 4682518.0 192.0 4.25 23.26 3.95 NO 

 NORFK_14 0 0.59770E-03 319969.5 4682530.0 192.0 4.25 23.26 3.95 NO 
 NORFK_15 0 0.59770E-03 320018.1 4682542.0 192.0 4.25 23.26 3.95 NO 

 NORFK_16 0 0.59770E-03 320066.6 4682554.0 192.0 4.25 23.26 3.95 NO 

 NORFK_17 0 0.59770E-03 320115.2 4682566.0 192.0 4.25 23.26 3.95 NO 

 NORFK_18 0 0.59770E-03 320163.8 4682578.0 192.0 4.25 23.26 3.95 NO 

 NORFK_19 0 0.59770E-03 320212.3 4682590.0 192.0 4.25 23.26 3.95 NO 

 NORFK_20 0 0.59770E-03 320260.8 4682602.0 192.0 4.25 23.26 3.95 NO 

 NORFK_21 0 0.59770E-03 320309.4 4682614.0 192.0 4.25 23.26 3.95 NO 

 NORFK_22 0 0.59770E-03 320358.0 4682626.0 192.0 4.25 23.26 3.95 NO 

 NORFK_23 0 0.59770E-03 320406.5 4682638.0 192.0 4.25 23.26 3.95 NO 

 NORFK_24 0 0.59770E-03 320455.1 4682650.0 192.0 4.25 23.26 3.95 NO 

 NORFK_25 0 0.59770E-03 320503.6 4682662.0 192.0 4.25 23.26 3.95 NO 

 NORFK_26 0 0.59770E-03 320552.2 4682674.0 192.0 4.25 23.26 3.95 NO 

 NORFK_27 0 0.59770E-03 320600.7 4682686.0 192.0 4.25 23.26 3.95 NO 

 NORFK_28 0 0.59770E-03 320649.3 4682698.0 192.0 4.25 23.26 3.95 NO 

 NORFK_29 0 0.59770E-03 320697.8 4682709.0 192.0 4.25 23.26 3.95 NO 

 NORFK_30 0 0.59770E-03 320746.4 4682721.0 192.0 4.25 23.26 3.95 NO 

 NORFK_31 0 0.59770E-03 320794.9 4682733.0 192.0 4.25 23.26 3.95 NO 

 *** VOLUME SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- 

 

 NORFK_32 0 0.59770E-03 320843.5 4682745.0 192.0 4.25 23.26 3.95 NO 

 NORFK_33 0 0.59770E-03 320892.1 4682757.0 192.0 4.25 23.26 3.95 NO 

 NORFK_34 0 0.59770E-03 320940.6 4682769.0 192.0 4.25 23.26 3.95 NO 

 NORFK_35 0 0.59770E-03 320989.2 4682781.0 192.0 4.25 23.26 3.95 NO 

 NORFK_36 0 0.59770E-03 321037.7 4682793.0 192.0 4.25 23.26 3.95 NO 

 NORFK_37 0 0.59770E-03 321086.3 4682805.0 192.0 4.25 23.26 3.95 NO 

 NORFK_38 0 0.59770E-03 321134.8 4682817.0 192.0 4.25 23.26 3.95 NO 

 NORFK_39 0 0.59770E-03 321183.4 4682829.0 192.0 4.25 23.26 3.95 NO 

 NORFK_40 0 0.59770E-03 321231.9 4682841.0 192.0 4.25 23.26 3.95 NO 

 NORFK_41 0 0.59770E-03 321280.5 4682853.0 192.0 4.25 23.26 3.95 NO 

 NORFK_42 0 0.59770E-03 321329.1 4682865.0 192.0 4.25 23.26 3.95 NO 

 NORFK_43 0 0.59770E-03 321377.6 4682877.0 192.0 4.25 23.26 3.95 NO 

 NORFK_44 0 0.59770E-03 321426.2 4682888.0 192.0 4.25 23.26 3.95 NO 

 CONRV_01 0 0.33760E-03 323622.3 4682108.0 192.0 4.25 23.26 3.95 NO 

 CONRV_02 0 0.33760E-03 323608.6 4682060.0 192.0 4.25 23.26 3.95 NO 

 CONRV_03 0 0.33760E-03 323594.9 4682012.0 192.0 4.25 23.26 3.95 NO 

 CONRV_04 0 0.33760E-03 323581.2 4681964.0 192.0 4.25 23.26 3.95 NO 

 CONRV_05 0 0.33760E-03 323567.5 4681916.0 192.0 4.25 23.26 3.95 NO 

 CONRV_06 0 0.33760E-03 323553.8 4681868.0 192.0 4.25 23.26 3.95 NO 

 CONRV_07 0 0.33760E-03 323540.1 4681820.0 192.0 4.25 23.26 3.95 NO 

 CONRV_08 0 0.33760E-03 323526.4 4681772.0 192.0 4.25 23.26 3.95 NO 

 CONRV_09 0 0.33760E-03 323512.7 4681724.0 192.0 4.25 23.26 3.95 NO 

 CONRV_10 0 0.33760E-03 323498.9 4681675.0 192.0 4.25 23.26 3.95 NO 

 CONRV_11 0 0.33760E-03 323485.3 4681627.0 192.0 4.25 23.26 3.95 NO 

 CONRV_12 0 0.33760E-03 323471.5 4681579.0 192.0 4.25 23.26 3.95 NO 

 CONRV_13 0 0.33760E-03 323457.8 4681531.0 192.0 4.25 23.26 3.95 NO 

 CONRV_14 0 0.33760E-03 323444.1 4681483.0 192.0 4.25 23.26 3.95 NO 

 CONRV_15 0 0.33760E-03 323430.4 4681435.0 192.0 4.25 23.26 3.95 NO 

 CONRV_16 0 0.33760E-03 323416.7 4681387.0 192.0 4.25 23.26 3.95 NO 

 CONRV_17 0 0.33760E-03 323403.0 4681339.0 192.0 4.25 23.26 3.95 NO 

 CONRV_18 0 0.33760E-03 323389.3 4681291.0 192.0 4.25 23.26 3.95 NO 

 CONRV_19 0 0.33760E-03 323375.6 4681243.0 192.0 4.25 23.26 3.95 NO 

 CONRV_20 0 0.33760E-03 323361.9 4681195.0 192.0 4.25 23.26 3.95 NO 

 CONRV_21 0 0.33760E-03 323348.2 4681147.0 192.0 4.25 23.26 3.95 NO 

 CONRV_22 0 0.33760E-03 323334.5 4681098.0 192.0 4.25 23.26 3.95 NO 

 CONRV_23 0 0.33760E-03 323320.8 4681050.0 192.0 4.25 23.26 3.95 NO 

 CONRV_24 0 0.33760E-03 323307.0 4681002.0 192.0 4.25 23.26 3.95 NO 

 CONRV_25 0 0.33760E-03 323293.3 4680954.0 192.0 4.25 23.26 3.95 NO 

 CONRV_26 0 0.33760E-03 323279.6 4680906.0 192.0 4.25 23.26 3.95 NO 

 DELRAY_1 0 0.62690E-03 325953.7 4683583.0 192.0 4.25 23.26 3.95 NO 

 *** VOLUME SOURCE DATA *** 

 

 NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE 

 SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY 

 ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

- 

 

 DELRAY_2 0 0.62690E-03 325931.9 4683538.0 192.0 4.25 23.26 3.95 NO 

 DELRAY_3 0 0.62690E-03 325910.2 4683493.0 192.0 4.25 23.26 3.95 NO 

 DELRAY_4 0 0.62690E-03 325888.4 4683448.0 192.0 4.25 23.26 3.95 NO 

 DELRAY_5 0 0.62690E-03 325866.6 4683403.0 192.0 4.25 23.26 3.95 NO 

 DELRAY_6 0 0.62690E-03 325844.8 4683358.0 192.0 4.25 23.26 3.95 NO 

 DELRAY_7 0 0.62690E-03 325823.1 4683313.0 192.0 4.25 23.26 3.95 NO 

 USSTL_01 0 0.23420E-02 323661.1 4679390.0 192.0 4.25 23.26 3.95 NO 

 USSTL_02 0 0.23420E-02 323690.8 4679430.0 192.0 4.25 23.26 3.95 NO 

 USSTL_03 0 0.23420E-02 323720.5 4679471.0 192.0 4.25 23.26 3.95 NO 

 USSTL_04 0 0.23420E-02 323750.3 4679511.0 192.0 4.25 23.26 3.95 NO 

 USSTL_05 0 0.23420E-02 323780.0 4679551.0 192.0 4.25 23.26 3.95 NO 

 USSTL_06 0 0.23420E-02 323809.7 4679591.0 192.0 4.25 23.26 3.95 NO 

 USSTL_07 0 0.23420E-02 323839.4 4679631.0 192.0 4.25 23.26 3.95 NO 

 USSTL_08 0 0.23420E-02 323869.2 4679672.0 192.0 4.25 23.26 3.95 NO 

 USSTL_09 0 0.23420E-02 325180.8 4681844.0 192.0 4.25 23.26 3.95 NO 

 USSTL_10 0 0.23420E-02 325230.7 4681841.0 192.0 4.25 23.26 3.95 NO 

 USSTL_11 0 0.23420E-02 325280.7 4681838.0 192.0 4.25 23.26 3.95 NO 

 USSTL_12 0 0.23420E-02 325330.6 4681836.0 192.0 4.25 23.26 3.95 NO 
 USSTL_13 0 0.23420E-02 325380.5 4681833.0 192.0 4.25 23.26 3.95 NO 

 USSTL_14 0 0.23420E-02 325430.4 4681830.0 192.0 4.25 23.26 3.95 NO 

 USSTL_15 0 0.23420E-02 325480.3 4681827.0 192.0 4.25 23.26 3.95 NO 

GROUP ID SOURCE IDs 

 

 ALL CSX_01 , CSX_02 , CSX_03 , CSX_04 , CSX_05 , CSX_06 , CSX_07 , CSX_08 , CSX_09 , CSX_10 , CSX_11 

, CSX_12 , 

 CSX_13 , CSX_14 , CSX_15 , CSX_16 , SEVER_01, SEVER_02, SEVER_03, SEVER_04, SEVER_05, SEVER_06, 

SEVER_07, SEVER_08, 

 SEVER_09, SEVER_10, SEVER_11, SEVER_12, SEVER_13, SEVER_14, SEVER_15, CONLV_01, CONLV_02, CONLV_03, 

CONLV_04, CONLV_05, 

 CONLV_06, CONLV_07, CONLV_08, CONLV_09, CONLV_10, CONLV_11, CONLV_12, CONLV_13, CONLV_14, CONLV_15, 

CONLV_16, CONLV_17, 

 CONLV_18, NORFK_01, NORFK_02, NORFK_03, NORFK_04, NORFK_05, NORFK_06, NORFK_07, NORFK_08, NORFK_09, 

NORFK_10, NORFK_11, 

 NORFK_12, NORFK_13, NORFK_14, NORFK_15, NORFK_16, NORFK_17, NORFK_18, NORFK_19, NORFK_20, NORFK_21, 

NORFK_22, NORFK_23, 

 NORFK_24, NORFK_25, NORFK_26, NORFK_27, NORFK_28, NORFK_29, NORFK_30, NORFK_31, NORFK_32, NORFK_33, 

NORFK_34, NORFK_35, 

 NORFK_36, NORFK_37, NORFK_38, NORFK_39, NORFK_40, NORFK_41, NORFK_42, NORFK_43, NORFK_44, CONRV_01, 

CONRV_02, CONRV_03, 

 CONRV_04, CONRV_05, CONRV_06, CONRV_07, CONRV_08, CONRV_09, CONRV_10, CONRV_11, CONRV_12, CONRV_13, 

CONRV_14, CONRV_15, 

 CONRV_16, CONRV_17, CONRV_18, CONRV_19, CONRV_20, CONRV_21, CONRV_22, CONRV_23, CONRV_24, CONRV_25, 

CONRV_26, DELRAY_1, 

 DELRAY_2, DELRAY_3, DELRAY_4, DELRAY_5, DELRAY_6, DELRAY_7, USSTL_01, USSTL_02, USSTL_03, USSTL_04, 

USSTL_05, USSTL_06, 

 USSTL_07, USSTL_08, USSTL_09, USSTL_10, USSTL_11, USSTL_12, USSTL_13, USSTL_14, USSTL_15, 

 CSX CSX_01 , CSX_02 , CSX_03 , CSX_04 , CSX_05 , CSX_06 , CSX_07 , CSX_08 , CSX_09 , CSX_10 , CSX_11 

, CSX_12 , 

 CSX_13 , CSX_14 , CSX_15 , CSX_16 , 

 SEVERSTA SEVER_01, SEVER_02, SEVER_03, SEVER_04, SEVER_05, SEVER_06, SEVER_07, SEVER_08, SEVER_09, SEVER_10, 

SEVER_11, SEVER_12, 

 SEVER_13, SEVER_14, SEVER_15, 

 CONLIVER CONLV_01, CONLV_02, CONLV_03, CONLV_04, CONLV_05, CONLV_06, CONLV_07, CONLV_08, CONLV_09, CONLV_10, 

CONLV_11, CONLV_12, 

 CONLV_13, CONLV_14, CONLV_15, CONLV_16, CONLV_17, CONLV_18, 

 NORFOLK NORFK_01, NORFK_02, NORFK_03, NORFK_04, NORFK_05, NORFK_06, NORFK_07, NORFK_08, NORFK_09, NORFK_10, 

NORFK_11, NORFK_12, 

 NORFK_13, NORFK_14, NORFK_15, NORFK_16, NORFK_17, NORFK_18, NORFK_19, NORFK_20, NORFK_21, NORFK_22, 

NORFK_23, NORFK_24, 

 

 

SUMMARY OF MAXIMUM ANNUAL ( 1 YRS) RESULTS *** 

 ALL 1ST HIGHEST VALUE IS 0.04822 AT ( 326344.00, 4685318.00 

 CSX 1ST HIGHEST VALUE IS 0.01734 AT ( 326344.00, 4685318.00 

 SEVERSTA 1ST HIGHEST VALUE IS 0.00076 AT ( 326344.00, 4685318.00 

 CONLIVER 1ST HIGHEST VALUE IS 0.00598 AT ( 326344.00, 4685318.00 

 NORFOLK 1ST HIGHEST VALUE IS 0.00248 AT ( 326344.00, 4685318.00 

 CONRIVER 1ST HIGHEST VALUE IS 0.00117 AT ( 326344.00, 4685318.00 

 DELRAY 1ST HIGHEST VALUE IS 0.00730 AT ( 326344.00, 4685318.00 

 USSTEEL 1ST HIGHEST VALUE IS 0.01331 AT ( 326344.00, 4685318.00 
Appendix I 

A CONCEPTUAL MODEL FOR AMBIENT FINE PARTICULATE 

MATTER OVER SOUTHEAST MICHIGAN 

HIGH CONCENTRATION DAYS

SUPPORT DOCUMENTATION 

FOR THE

FINE PARTICULATE SIP 

May 2008 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 1

1 

2 

3 

4 A CONCEPTUAL MODEL FOR AMBIENT FINE PARTICULATE 

5 MATTER OVER SOUTHEAST MICHIGAN: 

6 HIGH CONCENTRATION DAYS 

7 

8 

9 

10 

11 Revision 0.2 (Draft Final Report) 

12 April 23, 2008 

13 

14 

15 

16 

17 Prepared by 

18 Jay R. Turner 

19 Washington University 

20 Campus Box 1180, One Brookings Drive 

21 St. Louis, MO 63130-4899 

22 telephone: 314-935-5480 

23 facsimile: 314-935-7211 

24 email: JRTURNER @WUSTL.EDU 

25 

26 

27 

28 

29 Prepared for 

30 Southeast Michigan Council of Governments (SEMCOG) 

31 535 Griswold Street, Suite 300 

32 Detroit, MI 48226-3602 

33 telephone: 313-961-4266 

34 facsimile: 314-961-4869 

35 email: INFOCENTER@SEMCOG.ORG 

36 

37 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 2

38 A CONCEPTUAL MODEL FOR AMBIENT FINE PARTICULATE MATTER

39 OVER SOUTHEAST MICHIGAN: HIGH CONCENTRATION DAYS 

40 

41 Revision 0.2 (Draft Final Report); April 23, 2008 

42 

Prepared by Jay R. Turner* 43 , Washington University in St. Louis 

44 Prepared for Southeast Michigan Council of Governments (SEMCOG) 

45 

46 

47 EXECUTIVE SUMMARY 

48 

49 In 2006, the USEPA promulgated revisions to the National Ambient Air Quality Standard 

50 (NAAQS) for particulate matter (PM) which tightened the 24-hour (daily) PM2.5 standard from 

65 Pg/m3

 to 35 Pg/m3 51 . This revision profoundly increased the frequency of exceedance days 

52 observed in Southeast Michigan with fourteen of the fifteen compliance monitors violating the 

53 standard for the period 2004-2006. An understanding of the drivers for high PM2.5 days is 

54 needed to support the development of effective controls strategies; this study seeks to provide 

55 insights into such drivers. 

56 

57 At most sites in Southeast Michigan, exceedances occur predominantly – and in some cases 

58 exclusively – on days when the entire network is exhibiting high PM. For thirteen of the fifteen 

59 monitors, at least 85% of exceedances from 1999 to 2006 occurred on days when the entire 

60 network was exhibiting high PM. Drivers for network-wide high PM are regional transport, poor 

61 atmospheric ventilation across the network, or both of these conditions. Two monitors in 

62 particular – Dearborn and Wyandotte – frequently had exceedances on days when the entire 

63 network was not exhibiting high PM with 38% of the Dearborn exceedances and 27% of the 

64 Wyandotte exceedances occurring on such days. On these days, these sites are significantly 

65 influenced by nearby emission sources. Dearborn continues to be influenced by nearby emission 

66 sources which drive exceedances (or near exceedances) on days when the network-wide base 

concentration is as much as 15 Pg/m3 67 below the standard, although the frequency of such days 

68 appears to be decreasing. In contrast, at Wyandotte all of the days for which nearby emission 

69 sources were disproportionately contributing to exceedances (or near exceedances) of the 

70 standard were prior to 2004. At those sites not significantly impacted by plumes from nearby 

71 emission sources, high PM days are most often observed when the area is experiencing a 

72 multiday high PM episode. 

73 

74 Seasonal variations in surface winds can explain the seasonal differences in frequency of site75 specific high PM days between sites in the greater Wayne County area. Sites such as Allen Park, 

76 which are relatively free of impacts from nearby sources, exhibit similar seasonal behavior with 

77 high PM days most frequent in the summer followed by the winter. The monthly distribution of 

78 high PM days is distorted for sites with significant nearby emission sources since there is a 

79 strong seasonality to the surface winds distributions. For example, Dearborn has as many high 

80 PM days in the winter as in the summer, with the winter season having a stronger contribution 

81 from nearby sources located to the southwest of the site. 

 

*

 Campus Box 1180, Washington University, One Brookings Drive, St. Louis, MO 63130-4899. 

 telephone: 314-935-5480, facsimile 314-935-7211, email JRTURNER @WUSTL.EDU 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 3

82 

83 Network-wide high PM days have disproportionately high contributions from the major ions 

84 (sulfate, nitrate, and ammonium) compared to other days. Summertime events are dominated by 

85 sulfate and wintertime events are dominated by ammonium nitrate. However these so-called 

86 high nitrate days typically have ammonium sulfate concentrations that are at least 50% of the 

87 ammonium nitrate concentration. The role of sulfate on such days should not be overlooked 

88 when considering the impact of SO2-based regional control strategies. In general, network-wide 

PM base concentrations above ~20 Pg/m3 89 tend to be disproportionately influenced by major ion 

90 contributions and are indicative of a disproportionately high influence from regional sources. 

91 On network-wide high PM days the sulfate and nitrate concentrations are typically several times 

92 higher than the corresponding monthly median concentrations. In contrast, EC is on average 

93 only 1.3 times higher. This pattern suggests that network-wide high PM days are primarily 

94 influenced by regional transport and are to a lesser extent influenced by increased levels of 

95 urban-scale emissions arising from poor atmospheric ventilation. As previously stated, emission 

96 sources near the monitoring sites can still exert significant plume impacts regardless of the 

97 network-wide PM behavior driven by regional and urban-scale contributions. 

98 

99 Many network-wide high PM days coincide with high nitrate, and in some cases there is 

100 substantial variability in PM mass concentration across the network on these days. It is 

101 important to determine whether the variability is real or a measurement artifact, because these 

102 days can influence the site-specific design values and in general can explain many of the 

103 exceedingly high PM levels observed at certain sites that otherwise do not appear to be 

104 disproportionately impacted by nearby local emission source plumes on high PM days. 

105 

106 A conceptual model for fine PM over central Southeast Michigan includes four elements. The 

107 largest contributor to annual average PM is regionally transported material that is temporally 

108 varying but spatially homogeneous over the domain (indeed, this defines the spatial extent of the 

109 domain for the conceptual model which in this case excludes the distant sites such as Luna Pier 

110 and Port Huron). On some days, regionally transported PM contributions can be sufficiently 

111 high to cause exceedances of the daily standard when coupled with average contributions from 

112 urban- and finer-scale emission sources and, in relatively rare cases, the regionally transported 

113 PM alone can cause exceedances of the daily standard. Urban-scale emission sources (mobile, 

114 area, and point sources) create a spatial PM gradient across central Southeast Michigan. For 

115 winds from a fixed direction, these contributions create an “urban plume” with decreasing 

116 impacts with increasing distance from the zone of highest emissions activity. The spatial 

117 gradients can be clearly discerned when binning data from days with common wind patterns and 

118 become smeared, to some extent, when averaging over periods with varying wind patterns. At 

119 many sites (e.g., Linwood, East 7 Mile) a PM plume emanating from the Detroit commercial / 

120 industrial zone, which is nominally Dearborn and areas to its southeast towards the Detroit River, 

121 including Zug Island, can be distinguished from the aforementioned urban plume. At sites 

122 further downwind, such as New Haven, these two plumes have essentially merged into a single 

123 urban plume. Average impacts from these plumes depend on the monitoring site location 

124 relative to the Detroit population and commercial/industrial core zones and the frequency that 

125 winds from these zones transport the plumes to the monitoring site. Finally, certain monitors in 

126 the Detroit commercial/industrial zone are significantly impacted by emissions from nearby 

127 sources that ultimately contribute to the distant PM plume emanating from this zone. At 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 4

128 Dearborn and Wyandotte these sources are located southwest of the monitoring sites and 

129 historically have contributed to exceedances (or nears exceedances) of the daily standard. These 

130 sources also disproportionately influence the annual standard because they are oriented upwind 

131 of the sites for prevailing winds from the southwest. 

132 

133 The analyses presented in this report exploited the relatively high spatial and temporal PM2.5

134 FRM measurement density across Southeast Michigan. Each site provided added value to the 

135 analysis. Future reductions in either spatial or temporal measurement density would likely affect 

136 the ability to update this analysis towards tracking the accountability of emission control 

137 programs. 

138 

139 In summary, emission controls that reduce regionally transported PM are needed to reduce the 

140 frequency of violations of the 24-hour PM2.5 standard. Emission reductions from a few specific 

141 point sources, especially near Dearborn, are also needed. While regional and point source 

142 controls will decrease annual average PM2.5 concentrations for standardized synoptic weather 

143 patterns, relatively small but significant decreases could also be realized by controls on other 

144 urban emission sources such as mobile, area, and other point sources.
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 5

145 1. MOTIVATION 

146 

147 In 2006, the USEPA promulgated revisions to the National Ambient Air Quality Standard 

148 (NAAQS) for particulate matter (PM) which tightened the 24-hour (daily) PM2.5 standard from 

65 Pg/m3

 to 35 Pg/m3 149 . This revision profoundly increased the frequency of exceedance days 

observed in Southeast Michigan. For fifteen monitors over the time period 1999-20061 150 , there 

151 were 7 and 179 exceedance days (days with one-or-monitors in the area with concentration 

greater than or equal to 35 Pg/m3 152 ) under the old and new standards, respectively. While none of 

153 the monitors violated the old standard, for the period 2004-2006 fourteen of the fifteen monitors 

154 violated the new standard. Only one of the eleven sites elsewhere in the state – Grand 

155 Rapids – violated the standard for the 2004-2006. This behavior motivates the need for a refined 

156 understanding of the drivers for high concentration days in Southeast Michigan. In particular, a 

157 detailed description is needed of the emissions, meteorology and atmospheric processes that 

158 modulate PM concentrations. This “conceptual model”, with explicit emphasis on understanding 

159 PM2.5 high mass concentration days over the Southeast Michigan, could be utilized towards 

160 developing effective control strategies. 

161 

162 The conceptual model presented in this document is focused on the information needed to 

163 support the development and implementation of control strategies to meet the 24-hour PM2.5

164 NAAQS. It intentionally excludes a detailed treatment of annual average concentration patterns 

165 and instead focuses on the subset of days exhibiting high concentrations. Figure 1-1 shows the 

166 elements that go into the development of a conceptual model which is necessarily dynamic and 

167 must be refined as new knowledge becomes available. Content and presentation of the 

168 conceptual model for PM2.5 over Southeast Michigan loosely follows the framework used by 

169 Vickery (2004) for nine North American geographic regions and as revisited by Allen and 

170 Turner (2008). A conceptual model for PM2.5 over St. Louis was recently developed which 

171 included the following elements: annual and seasonal levels of PM2.5 in relation to the mass172 based standards; compositional analysis of PM2.5; meteorological influences; atmospheric 

173 processes contributing to PM2.5; sources and source regions contributing to the principle 

174 chemicals of concern; and implications to policy makers (Turner and Garlock, 2007). For this 

175 study, the framework has been modified to accommodate the emphasis on those days with high 

176 PM concentrations. 

177 

178 An assessment of the drivers for high concentration days, compared to annual average behavior, 

179 is complicated by several factors. First, high concentration days are relatively infrequent and 

180 thus there is limited data to probe. Second, while the standard defines a bright line for 

181 exceedance days, the use of threshold concentration values to censor data can mask some of the 

182 key features. The sensitivity of key findings to the operational definition of a high concentration 

183 day is important and care has been taken in this study to ensure the results are resistant to the 

184 selection of the threshold concentration. 

185 

 

1

 Some of these monitors did not operate for the entire eight year period, and the monitors collect samples with 

frequency from every day to every sixth day. 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 6

refinements as new knowledge emerges

186 

187 Figure 1-1. Development of a conceptual model (adapted from Vickery, 2004). 

188 

189 

190 This conceptual model is grounded in an analysis of eight years of PM2.5 FRM mass 

191 concentration data and allied data for particle speciation and meteorology. Nonetheless, it 

192 should be treated as a living document, to be periodically updated as additional data becomes 

193 available (in particular to capture temporal trends) and revised as more-detailed analysis is 

194 performed on the existing data. 

195 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 7

196 2. APPROACH 

197 

198 Extensive monitoring and data analysis has been performed for Southeast Michigan. From a 

199 regulatory context, most of the data analysis effort has focused on the annual-average NAAQS. 

200 This work focuses on the drivers for exceedances of the daily (24-hour) NAAQS. This metric 

201 presents certain challenges to the characterization effort. In contrast to the annual average 

202 NAAQS, which requires an understanding of the average contribution of sources to observed 

203 burdens, consideration of the daily standard must necessarily focus on a much smaller number of 

204 days and with interest in the drivers of the concentrations specifically on those days. Many of 

205 the data analysis tools, such as receptor modeling by positive matrix factorization (PMF), are 

206 most powerful when considering the average behavior; estimates for high concentration days are 

207 less reliable and indeed in many analyses extreme values are down-weighted to improve the 

208 stability of the solution. Air quality surveillance is relatively sparse with sustained daily FRM 

209 measurements at only one site (Allen Park); this provides a challenge to placing an observed 

210 exceedance day in a temporal context. However, the Southeast Michigan FRM network is 

211 relatively dense, and this greatly facilitated the ability to the analyses presented in this report. 

212 Semicontinuous PM mass and composition measurements certainly provide considerable insight 

213 and in the future their deployment should be very beneficial in refining our knowledge of high 

214 concentration events. 

215 

216 A significant body of work has been assembled to characterize PM in Southeast Michigan with 

217 most-recent emphasis on the annual average PM2.5 NAAQS. Indeed, efforts currently underway 

218 to address the annual average standard are expected to improve the area’s status with regard to 

219 the daily standard. However, additional measures might be needed to eliminate violations and 

220 bring the area into attainment with the daily standard. Thus, the key findings from this analysis 

221 are compared and contrasted with the Weight-of-Evidence (WOE) developed for the annual 

222 standard to more fully understand the synergies between the drivers and control strategies. 

223 

224 Many questions can be raised towards characterizing an observed exceedance of the daily 

225 standard. Was it driven by local emissions, regional transport, or both? Did it arise from an 

226 exceptional event, such as a structural fire or unusual industrial emission, or was it the 

227 conventional mix of emission sources with their contributions amplified by poor atmospheric 

228 ventilation conditions such as a persistent stagnation? Exceptional events will be experienced 

229 that cannot be explained with the typical types and levels of surveillance. For example, 

230 documented exceptional events at the St. Louis – Midwest Supersite in East St. Louis, IL, 

231 included nearby structural fires that in some cases were captured by the images from an on-site 

232 camera and in other cases were visually observed by site operators. The ability to identify 

233 exceptional events in the East St. Louis time series decreased as the site operations became 

234 routine and staff spent less time at the site. It is possible the observed high concentrations are 

235 more susceptible to measurement error (indeed, in some cases even result solely from 

236 measurement error) and uncontrollable measurement bias. We will examine this issue in the 

237 context of spatial variability in FRM values on high nitrate days. The Regional Haze Rule 

238 construct of isolating the 20% worst days – whether visibility or mass concentration – is closer in 

239 spirit to the information needed for examining drivers for high concentration days. However, in 

240 its most-commonly applied form it is inadequate because the average behavior on the 20% worst 

241 days might not represent the condition on an actual day if there are a variety of drivers for high 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 8

242 concentration days. The separation of contributions emanating from different spatial scales 

243 (e.g., regional-, urban-, and even finer local-scales) is particularly challenging and the data 

244 analysis approaches adopted for this study have been customized to elucidate the contributions 

245 from these scales to the extent practicable. In consideration of the above issues, it is apparent 

246 that analyses to capture the drivers for high concentration days must focus on distributions of 

247 behavior rather than average (central tendency) behavior. The data analysis methods reflect this 

248 consideration. 

249 

250 There are many possible drivers for intraurban variability in PM2.5 mass, including the following 

251 six factors: local sources of primary PM emissions; transient emission events; topographic 

252 barriers that isolate subregions of the urban area; meteorological phenomena that vary on spatial 

253 scales within the urban area; differences in behavior of semi-volatile components; and 

254 measurement error (Pinto et al. 2004; Turner and Allen, 2008). While this analysis does not 

255 definitively identify which of these factors are responsible for observed differences across the 

256 network, it does reflect upon these factors to explain the observed differences. 

257 

258 Figure 2-1 shows a conceptualization of intraurban variability arising from PM emission sources 

259 acting on various spatial scales. The air mass is transecting the domain with persistent surface 

260 winds from the left. Panel (a) shows the emission sources where the regional-scale contributions 

261 are assumed to be homogeneous across the domain (this assumption neglects interactions 

262 between regionally transported material and urban area emissions, such as urban plume 

263 processing of regionally-transported PM precursor gases). Urban-scale emissions from mobile 

264 sources, area sources, and point sources distributed across the metro core contribute to an 

265 increase in PM mass concentration (dashed line) which is skewed towards the downwind end of 

266 the domain. Neighborhood- and finer-scale emissions create local hot spots which disperse 

267 downwind and become part of the urban-scale contributions. The red line in panel (b) shows the 

268 concentration profile that would be observed along the transect. Monitor locations will dictate 

269 which features of the profile are captured. For example, panel (c) shows the location of five 

270 monitors (the “network-wide baseline” will be discussed later in this report). Monitor A is 

271 located upwind of the urban area and measures the regional contributions. However, a wind 

272 reversal would render it downwind of the urban area and in this case it might be impacted by the 

273 urban plume (such as monitor D). Monitor B is impacted by both a local plume and upwind 

274 urban contributions. The plume would miss the site with a wind reversal. Monitor C is located 

275 near the core of the urban area (from an urban-scale emissions perspective). For this scenario it 

276 is not impacted by local plumes but measures the cumulative contributions from upwind sources, 

277 including point sources in the urban area. A wind reversal, however, might render monitor C

278 impacted by a local plume. Monitor D is outside the urban area emissions zone but nonetheless 

279 is impacted by the “urban plume” as it is advected downwind, while monitor E is far enough 

280 downwind that the urban plume has dispersed to the extent that the urban PM mass contributions 

281 cannot be distinguished from the underlying regional contributions. A wind reversal would 

282 render monitors D and E upwind of the urban area. This spatial concentration field represents a 

283 snapshot in time which becomes smeared for a 24-hour sample as winds shift during the day, and 

284 becomes further smeared when averaging results over many days. It is also a 1-D representation 

285 of a 2-D surface which adds complexity. That said, it does motivate the use of surface winds as 

286 a discriminator for studying site-specific PM mass trends to place each monitor in an emissions 

287 field context. 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 9

conc.

surface 

winds regional-scale contributions

urban-scale contributions

metro core (emissions perspective) downwind 

distance

neighborhood- and finer-scale 

contributions (e.g., point sources)

conc.

surface 

winds regional-scale contributions

urban-scale contributions

metro core (emissions perspective) downwind 

distance

neighborhood- and finer-scale 

contributions (e.g., point sources)

conc.

surface 

winds

metro core (emissions perspective) downwind 

distance

network-wide 

baseline

A B C D E

(a)

(b)

(c)

288 

289 

290 Figure 2-1. The influence of emissions acting on various spatial scales to observed concentrations at 

291 monitoring sites.
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 10

292 The report is structured as follows. Section 3 presents an overview of the monitoring network 

293 and key descriptive statistics and trends, including but not limited to the regulatory metrics. 

294 Section 4 examines the drivers for high concentration days by taking advantage of the relatively 

295 dense compliance monitoring network and particle speciation data. Section 5 refines the 

296 understanding of local emission source contributions by exploiting spatial and temporal 

297 variability within the network. Key findings, policy-relevant implications and recommendations 

298 for future work are summarized in Section 6. 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 11

299 3. SOUTHEAST MICHIGAN PM2.5 FRM NETWORK AND CONCENTRATION 

300 TRENDS 

301 

302 The PM2.5 FRM monitoring network used in this analysis is summarized in Figures 3-1 and 3-2 

303 and Table 3-1. For the PM2.5 compliance monitoring period of 1999-2006, there were fifteen 

304 PM2.5 FRM monitoring sites in Southeast Michigan; three sites had collocated PM2.5 FRM 

305 samplers. All FRM monitoring sites in the Detroit-Warren-Flint CSA are included except Flint. 

306 For the purpose of this report, the spatial zone of Wayne County with highest population density 

307 (>10 persons/acre) shall be called the Detroit population core and the spatial zone which includes 

308 the Detroit central business district and industrialized zones to the south through west (e.g., 

309 Dearborn, Zug Island) shall be called the Detroit commercial/industrial core. This latter zone 

310 roughly includes the area covered by the five tightly clustered monitors in Figures 3-1 and 3-2 

311 (Dearborn, Southwest High School, FIA/Lafayette, Newberry, and Linwood). Greater Wayne 

312 County sites shall refer to the monitoring sites located in Wayne County plus the Oak Park 

313 monitor site which is just across the county line in Oakland County. 

314 

315 Daily measurements have been maintained at Allen Park through the eight year period; most 

316 other sites operated on a 1-in-3 day schedule although some were cut back to 1-in-6 day in recent 

317 years due to budget constraints. There were 2,782 days with valid data reported for one-or-more 

318 sites (95.2% of days), with this high temporal data density driven by the daily sampling at Allen 

319 Park. There were 14,044 sampling events (neglecting collocated measurements). The historical 

320 compliance status of each site with respect to the 24-hour PM2.5 NAAQS is presented in 

321 Table 3-2. Exceedances of the 24-hour standard were observed on 179 days which is 6.1% of 

322 the days with one-or-more monitors reporting valid data. There were 546 total exceedances 

323 which correspond to 3.9% of all sampling events. 

324 

325 This report reflects on the conditions and drivers for high PM2.5 mass concentration days 

326 (hereafter called “high PM days”). We are interested in both the frequency and intensity 

327 (magnitude) of high concentration days since both factors are important in establishing the 

328 design value. Figure 3-3 shows the site-specific frequencies of high concentration days using 

thresholds of 25, 30, and 35 Pg/m3 329 . Exceedances were observed on 2-8% of sample days with 

5-14%, and 8-24% of sample days having concentrations above 30 Pg/m3

 and 25 Pg/m3 330 , 

331 respectively. Dearborn exhibits the highest frequency of high concentration days, followed by 

332 SW High School and Wyandotte. The remaining monitors in Greater Wayne County exhibit 

333 similar behavior. The frequencies for FIA/Lafayette and Newberry sites might be impacted by 

334 the relatively short sampling histories at these sites and caution should be used in comparing and 

335 contrasting these sites to the rest of the network. Ann Arbor and New Haven exhibit the lowest 

336 frequencies of high concentration days; they are 50-60 km from the Detroit commercial / 

337 industrial core to the west and northeast, respectively. However, these two sites do not represent 

338 the spatial extents of the SE Michigan network with Luna Pier ~70 km to the southwest and Port 

339 Huron ~80 km to the northeast. 

340 

341 Figure 3-4 shows the frequency of PM2.5 high concentration days by month for Allen Park, 

342 Dearborn, Southwest High School and New Haven (frequency plots for all sites are presented in 

343 Figure A-1, Appendix A). The pattern for Allen Park is generally representative of those 

344 Greater Wayne county sites with relatively modest impacts from nearby sources, as will be 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 12

345 

346 Figure 3-1. Southeast Michigan PM2.5 FRM monitoring sites superposed on county boundaries and 2000 

347 census tracts. The red rectangle includes a portion of Wayne County. 

348 

349 

350 Figure 3-2. Southeast Michigan PM2.5 FRM monitoring sites (excluding Luna Pier and Port Huron) 

351 superposed on 2000 census tract level population density data.

Wayne

County
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 13

352 Table 3-1. Southeast Michigan PM2.5 monitoring network as of December 2006, including 

exceedances days for the NAAQS daily PM2.5 standard of 35 Pg/m3 353 .

(A) (B) (C) (D) (E) (F) (G)

Site Name AIRS ID

Sampling 

Dates

Maximum 

Sampling 

Frequency

Number of 

Sampling Days

Number of 

Exceedance 

Days

Speciation Site 

(Dates)? 

Allen Park 261630001 05/99-- daily 2497 92 12/00-

Ann Arbor 261610005 06/99-12/05 1-in-3 day 714 13 no

Dearborn 261630033 02/99-- 1-in-3 day 879 67 05/02--

E 7 Mile 261630019 04/00-- 1-in-3 day 724 29 12/00-04/02

FIA/Lafayette 261630039 08/05-- 1-in-3 day 155 1 no

Linwood 261630016 05/99-- daily 2273 102 no

Livonia 261630025 08/99-- 1-in-3 day 777 28 no

Luna Pier 261150005 12/99-- 1-in-3 day 804 28 05/02--

New Haven 260990009 01/99-- 1-in-3 day 878 22 no

Newberry 261630038 12/04-- 1-in-3 day 161 6 no

Oak Park 261250001 01/99-- 1-in-3 day 793 32 no

Port Huron 261470005 01/99-- 1-in-3 day 841 32 no

SW High Sch. 261630015 02/99-- 1-in-3 day 881 41 no

Wyandotte 261630036 02/99-- 1-in-3 day 838 35 no

Ypsilanti 261610008 08/99-- 1-in-3 day 829 18 06/03-- 354 

355 

356 

357 

358 discussed later in this report. High concentration days are most frequent in the summer months 

359 followed by the winter months, while high concentration days are relatively infrequent in the 

360 spring. Dearborn exhibits higher frequencies of high concentration days for all months with the 

361 winter frequencies comparable to the summer frequencies. Southwest High School monthly 

362 frequencies fall between Allen Park and Dearborn, while New Haven has relatively few high 

363 concentration days but with the same overall pattern as Allen Park – highest frequencies in the 

364 summer followed by the winter. 

365 

366 

367 Table 3-2. Southeast Michigan PM2.5 monitoring network compliance status for the daily PM2.5 NAAQS 

368 (POC = 1 samplers only). 

Three-Year Averages of 98th Percentiles

Site AIRS ID 1999 2000 2001 2002 2003 2004 2005 2006 99-01 00-02 01-03 02-04 03-05 04-06

Allen Park 261630001 43.7 38.6 44.2 39.6 40.5 36.9 43.0 34.1 42 41 41 39 40 38

Ann Arbor 261610005 38.2 33.1 38.5 31.3 33.3 28.4 39.1 37 34 34 31 34 34

Dearborn 261630033 45.1 45.1 43.2 45.7 42.8 39.4 50.2 43.1 44 45 44 43 44 44

E 7 Mile 261630019 --- 42.0 42.0 34.4 37.1 35.0 52.3 36.2 42 39 38 36 41 41

FIA/Lafayette 261630039 --- --- --- --- --- --- 43.9 32.4 --- --- --- --- --- 38

Linwood 261630016 44.5 40.3 40.9 42.7 46.2 38.3 51.8 36.9 42 41 43 42 45 42

Livonia 261630025 38.4 35.9 44.7 32.7 38.1 32.2 40.2 30.4 40 38 39 34 37 34

Luna Pier 261150005 18.1 37.2 39.2 42.7 34.7 35.0 49.3 32.6 32 40 39 37 40 39

New Haven 260990009 31.9 33.2 42.0 35.6 31.8 31.9 41.5 34.4 36 37 36 33 35 36

Newberry 261630038 --- --- --- --- --- 36.8 57.5 28.6 --- --- --- --- --- 41

Oak Park 261250001 42.8 40.7 39.4 38.4 36.6 32.5 52.2 33.0 41 40 38 36 40 39

Port Huron 261470005 44.5 33.1 40.5 35.3 37.2 32.2 47.6 37.9 39 36 38 35 39 39

SW High Sch. 261630015 50.2 44.5 42.9 38.2 33.6 36.0 49.7 36.2 46 42 38 36 40 41

Wyandotte 261630036 45.0 42.7 46.6 34.1 34.8 32.3 46.7 33.2 45 41 39 34 38 37

Ypsilanti 261610008 40.6 30.3 39.7 30.9 38.8 31.5 52.1 31.3 37 34 36 34 41 38

Annual 98th Percentiles 

369 370 

371 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 14 Allen Park Ann Arbor Dearborn E 7 Mile FIA/Lafayette Linwood Livonia Luna Pier New Haven Newberry Oak Park Port Huron SW High Sch. Wyandotte Ypsilantipercentage of total sampling days above threhold concentration

0

5

10

15

20

25

30

> 35 ug/m3

> 30 ug/m3

> 25 ug/m3

1999-2006

372 

373 (a) Allen Park Ann Arbor Dearborn E 7 Mile FIA/Lafayette Linwood Livonia

Luna Pier

New Haven

Newberry

Oak Park

Port Huron

SW High Sch.

Wyandotte

Ypsilanti

percentage of total sampling days above threhold concentration

0

5

10

15

20

25

30

> 35 ug/m3

> 30 ug/m3

> 25 ug/m3

2004-2006

374 

375 (b)

376 

377 Figure 3-3. Site-specific frequency of total sampling days above the designated concentration for 

378 periods: 1999-2006 (a); and 2004-2006 (b), 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 15

Allen Park

fraction of days greater than threshold

0.00

0.05

0.10

0.15

0.20 > 35 ug/m3

> 30 ug/m3

379 

Dearborn

fraction of days greater than threshold

0.00

0.05

0.10

0.15

0.20

380 

Southwest High Sch.

fraction of days greater than threshold

0.00

0.05

0.10

0.15

0.20

381 

New Haven

Month

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

fraction of days greater than threshold

0.00

0.05

0.10

0.15

0.20

382 

383 Figure 3-4. Distribution of PM2.5 high concentration days by month for Allen Park (top) and Dearborn 

384 (second from top), Southwest High School (second from bottom), and New Haven (bottom), 1999-2006. 

385 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 16

386 Surface winds dictate the coupling between local emission sources and the monitoring sites. 

387 The wind rose for hourly values from Detroit Metropolitan Wayne County Airport is shown in 

388 Figure 3-5 for the period 1999-2006. Prevailing surface winds are from the southwest with 

389 frequent winds also from the west. Winds from the east are relatively infrequent. Hourly surface 

390 winds distributions exhibit a distinct seasonality (Figure 3-6) albeit with some degree of 

391 year-to-year variation (Figure B-1, Appendix B). Fall and winter months are more advective 

392 with a pronounced southwesterly component while spring and summer months have lighter 

393 winds and less distinct prevailing features. Seasonal variations in surface winds can explain the 

394 seasonal differences in frequency of high PM days between the Greater Wayne County sites. For 

395 example, Dearborn has a disproportionately higher frequency of high PM days in the winter 

396 compared to Allen Park. This is consistent with the increased frequency of surface winds from 

397 the southwest during the winter and the location of nearby emission sources in this direction (and 

398 indeed located between Dearborn and Allen Park). 

399 

400 

401 

402 Figure 3-5. Wind rose for non-calm hours, observations at Detroit Metropolitan Wayne County Airport 

403 (DTW), 1999-2006. Calms (wind speeds less than 2 mph) were 11% of total hours. 

404 

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

Winter Spring Summer Fall 

6% 10% 13% 12% 

405 

406 

407 Figure 3-6. Seasonal wind roses for non-calm hours, observations at Detroit Metropolitan Wayne 

408 County Airport (DTW), 1999-2006. Calms (wind speeds less than 2 mph) are listed to the lower-left of 

409 each wind rose. The wind speed scales are shown in the legend for Figure 3-5. 

>2 - 4

>4 - 8

>8 - 16

>16

WS (mph)
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 17

410 4. CLIMATOLOGY OF NETWORK-WIDE HIGH PM DAYS 

411 

412 As previously described, a high fine PM mass concentration day at a given site can arise from 

413 regional contributions, local contributions, or a combination of these factors. The climatology of 

414 network-wide high PM days was examined to understand the drivers for such days. Regionally 

415 transported materials might be higher or atmospheric ventilation might be poorer. The extent to 

416 which these drivers act synergistically is not clear. For example, a summertime high pressure 

417 system advecting regionally transported PM might stall out over the area. However, the lower 

418 winds speeds might be partially offset by a large mixing layer depth on such days. While we 

419 cannot make definitive statements about such coupling, this section provides a perspective on 

420 these issues. 

421 

422 Descriptive analyses, including but not limited to those summarized in the previous section, 

423 demonstrate a high coherence in high PM days across the network. Thus, an exploratory 

424 analysis was performed to determine the frequency and nature of network-wide high PM days. 

425 A subset of sampling days with network-wide high PM mass concentrations was identified by 

426 first identifying those days with at least ten of the twelve Southeast Michigan FRM monitor sites 

reporting a valid PM2.5 FRM mass concentration value2 427 ; these days are called valid network 

428 days. Subsequently, the valid network days were screened to include only those days with at 

429 least 2/3 of the reporting monitors having a PM concentration greater than a threshold value 

(e.g., 30 Pg/m3 430 ); these days are called network-wide high PM days. Table 4-1 summarizes the 

431 characteristics of the valid network days and network-wide high PM days data sets. For the 

432 period 1999-2006 there were 727 sampling days with ten-or-more FRM monitor sites reporting 

433 valid PM2.5 concentrations (valid network days). 41 of these days (5.6%) had at least 2/3 of the 

monitors above 30 Pg/m3 434 (network-wide high PM days) and all of these days had one-or-more 

435 monitor exceedance. Exceedances were also observed at one-or-more monitors on 35 days 

436 (5.1%) that were below the network-wide high PM threshold; these days likely have stronger 

437 influences from nearby emission sources impacting one or at most two sites. Figure 4-1 shows 

438 the distribution of network-wide high PM days by month. The days are concentrated in the 

439 summer followed by the winter, with few days in the seasonal transition months of April, May, 

440 and November. This pattern is insensitive to the concentration threshold used to define network441 wide high PM days. 

442 

443 Table 4-1. Valid network days and network-wide high PM days by year.

Year Valid Network Days Network-Wide High PM Days

1999 014 01 7%

2000 084 04 5%

2001 104 10 10%

2002 101 04 4%

2003 113 05 4%

2004 117 05 4%

2005 121 09 7%

2006 073 03 4%

444 total 727 41 6%

 

2

 Ann Arbor, FIA/Lafayette and Newberry were excluded form this analysis due to their limited period of operation. 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 18

Month

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

# days with at least 2/3 monitors 

above stated concentration

0

2

4

6

8

10

12

14

16

> 35 ug/m3

> 30 ug/m3

> 25 ug/m3

445 

446 Figure 4-1. Frequency of network-wide high PM days by month using three different thresholds for 

defining a high PM day:t25; t30; and t35 Pg/m3 447 . 

448 

449 

450 The relevance of this analysis to understanding drivers for exceedances of the 24-hour standard 

451 is demonstrated in Table 4-2. Valid network days, as defined above, capture 27-92% of all 

452 sampling days (column D). The capture is relatively low at sites with daily sampling (Allen 

453 Park, Linwood) because ten-or-more monitors must report valid data for the day to be designated 

454 a valid network day. However, the percentage of total exceedances that fall on a valid network 

455 day (column E) is nearly identical to the percentage capture of all sampling days by valid 

456 network days (column D) and we conclude that the subset of sampling days captured by valid 

457 network days is representative of all sampling days. Having established the representativeness 

458 of valid network days, we observed that at most sites exceedances occur predominantly – and in 

459 some cases exclusively – on days when the entire network is exhibiting high PM (column F). For 

460 example, 96% of the exceedances at Allen Park on valid network days occurred on days when 

461 the entire network was exhibiting high PM. Assuming the valid network days are representative 

462 of all sampling days at Allen Park, we would assign 88 of the 92 total observed exceedances to 

463 days with network-wide high PM. Similarly, 100% of the exceedances at Ypsilanti on valid 

464 network days occurred on days when the entire network was exhibiting high PM. Assuming the 

465 valid network days are representative of all sampling days at Ypsilanti, we would assign all of 

the 18 total observed exceedances to days with network-wide high PM.3 466 Dearborn represents the 

467 other extreme of behavior with only 62% of exceedances occurring on network-wide high PM 

468 days. In summary: (1) For nine of the fifteen monitors, more than 90% of the exceedances 

469 occurred on days when the entire network was exhibiting high PM; (2) Four monitors in the core 

470 region had a high frequency of exceedances on days when the entire network was not exhibiting 

471 high PM (Dearborn – 38%, Wyandotte – 27%, East 7 Mile – 15%, Linwood – 13%); and (3) At 

472 Luna Pier and Port Huron, which are located at the geographic extents of the Southeast Michigan 

 

3

 In contrast to Allen Park where only 25 of the 92 exceedances were captured by valid network days (27%), at 

Ypsilanti 16 of the 18 exceedances where captured by valid network days (89%) and the assertion that the valid 

network days are representative of all sampling days is not even necessary. 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 19

473 Table 4-2. Site-specific exceedance trends on valid network days. 

(A) (B) (C) (D) (E) (F)

Site Name

Number of Sampling 

Days

Number of 

Exceedance Days

% Sampling Days 

on Valid Network 

Days

% Exceedances on Valid 

Network Days

% Network Day 

Exceedances on NetworkWide High PM Days

Allen Park 2497 92 27.2% 27.2% 96.0%

Ann Arbor 714 13 82.9% 92.3% 100.0%

Dearborn 879 67 77.1% 77.6% 61.5%

E 7 Mile 724 29 92.1% 89.7% 84.6%

FIA/Lafayette 155 1 68.4% 100.0% 100.0%

Linwood 2273 102 29.5% 29.4% 86.7%

Livonia 777 28 87.1% 89.3% 92.0%

Luna Pier 804 28 82.8% 85.7% 87.5%

New Haven 878 22 80.4% 86.4% 100.0%

Newberry 161 6 71.4% 100.0% 100.0%

Oak Park 793 32 82.0% 75.0% 91.7%

Port Huron 841 32 81.8% 81.3% 88.5%

SW High Sch. 881 41 78.4% 73.2% 93.3%

Wyandotte 838 35 80.2% 85.7% 73.3%

474 Ypsilanti 829 18 82.8% 88.9% 100.0%

475 

476 

477 region, 12-13% of the exceedances were on days when the entire network was not exhibiting 

478 high PM. It is possible the construct of network-wide high PM days is less robust for these sites 

479 since they might not always be bathed in the same regional air mass as the core region. 

480 

481 The threshold concentration used to define a network-wide high PM day does not itself capture 

482 the network-wide baseline PM level on that day (it is merely the bright line used to identify the 

483 days). Thus, for the purposes of this report a base concentration for each valid network day was 

defined as the 5th 484 lowest concentration value across the network. Since at least ten monitors 

must have valid data for the day to be designated a valid network day, the 5th 485 lowest 

486 concentration is no higher than the median concentration and ensures the base concentration is 

487 not significantly influenced by the monitors at the geographic extents (Luna Pier and Port Huron) 

488 which might be bathed in different air masses on certain days, and removes the influence of 

489 one-or-two anomalously low concentration values. The base concentration includes regionally 

490 transported PM and some portion of the urban-scale contributions. Excess mass at a given site, 

491 relative to the base concentration, can be negative for cases such as monitors A and E in 

492 Figure 2-1c. 

493 

494 Figure 4-2 shows the network-wide maximum and second maximum concentrations as a 

495 function of the base concentration for valid network days. The maximum concentration is often 

496 much greater than the base concentration and on these days there is a large local excess at the 

497 maximum concentration site. However, the second maximum concentration is typically within 

5 Pg/m3 498 of the base concentration and thus on a given day there is typically at most one site with 

499 a large local excess, regardless of the base concentration. This behavior holds at both high and 

 

7

 Typically synoptic winds would be analyzed to identify days conducive to regional transport but sulfate and nitrate 

will be used as a surrogate for regional transport in this work since the sulfate at Allen Park is overwhelmingly from 

regional transport and the nitrate is dominated by regional transport. 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 20

base concentration, ug/m3

0 10 20 30 40 50 60 70 80

maximum concentration, ug/m3

0

10

20

30

40

50

60

70

80

(a)

base concentration, ug/m3

0 10 20 30 40 50 60 70 80

second maximum concentration, ug/m3

0

10

20

30

40

50

60

70

80

(b)

500 

501 Figure 4-2. Network-wide maximum concentration (a) and second maximum concentration (b) for each 

502 valid network day compared to the respective network-wide base concentration. The analysis excludes 

503 three sites – Ann Arbor, Lafayette/FIA, and Newberry. The solid line is the base concentration (1:1 line) 

and the dashed line is 5 Pg/m3 504 above the base concentration. 

505 

506 low base concentrations; the extreme maximum values possibly arise from nitrate hot spots or 

507 measurement artifacts as will be described later in this report. 

508 

509 Day- and site-specific concentrations are compared to the base concentrations in Figure 4-3 for 

510 valid network days. Most sites had a few exceedances days with concentrations in large excess 

511 of the base concentration. Assuming poor atmospheric ventilation affects the sites similarly and 

512 thus contributes to the base concentration, the extreme excursions above the base concentrations 

513 likely arose from nearby emission source plumes, exceptional events (including but not limited 

514 to releases from the local emission sources) or measurement error including but not limited to a 

515 possible nitrate artifact. With the exception of Dearborn and Wyandotte, most exceedances were 

516 clustered about the base concentration. Dearborn and Wyandotte had exceedances on days with 

base concentrations as low as 20 Pg/m3 517 demonstrating significant excess above the base 

518 concentration. 

519 

520 The analysis so far has primarily focused on the relative frequency of network-wide high PM 

521 days and their associations with exceedances. Figure 4-4 captures the influence of the extreme 

values observed at each site (Figure 4-3), showing the 5th 522 highest maximum excess and the 

523 median excess compared to the base concentration for exceedance days falling on valid network 

days. Several sites have low excess for the 5th 524 highest maximum (yellow bars), although this 

metric is sensitive to sampling frequency. Most sites have median excess below 5 Pg/m3 525 . 

526 Excluding Dearborn and Wyandotte, and pooling the site-specific highest three excess 

527 concentrations across the remaining ten sites, 23 of the 30 values occurred on only three days – 

528 3/1/2003, 2/3/2005 and 2/6/2005. On all three days the network exhibited high and variable 

529 concentrations, and the latter two days were the highest nitrate at Allen Park over all valid 

530 network days (no speciation data for 3/1/2003). Further inspection of network-wide behavior on 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 21

base concentration, ug/m3

0 10 20 30 40 50 60 70 80

site-specific concentration, ug/m3

0

10

20

30

40

50

60

70

80

Allen Park

base concentration, ug/m3

0 10 20 30 40 50 60 70 80

site-specific concentration, ug/m3

0

10

20

30

40

50

60

70

80

Dearborn

531 

base concentration, ug/m3

0 10 20 30 40 50 60 70 80

site-specific concentration, ug/m3

0

10

20

30

40

50

60

70

80

East 7 Mile

 base concentration, ug/m3

0 10 20 30 40 50 60 70 80

site-specific concentration, ug/m3

0

10

20

30

40

50

60

70

80

Linwood

532 

base concentration, ug/m3

0 10 20 30 40 50 60 70 80

site-specific concentration, ug/m3

0

10

20

30

40

50

60

70

80

Livonia

 base concentration, ug/m3

0 10 20 30 40 50 60 70 80

site-specific concentration, ug/m3

0

10

20

30

40

50

60

70

80

Luna Pier

533 

534 

535 Figure 4-3. Site-specific concentrations versus base concentrations for valid network days. Solid line is 

the base concentration (1:1 line) and dashed line is 35 Pg/m3 536 . 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 22

base concentration, ug/m3

0 10 20 30 40 50 60 70 80

site-specific concentration, ug/m3

0

10

20

30

40

50

60

70

80

New Haven

 base concentration, ug/m3

0 10 20 30 40 50 60 70 80

site-specific concentration, ug/m3

0

10

20

30

40

50

60

70

80

Oak Park

537 

base concentration, ug/m3

0 10 20 30 40 50 60 70 80

site-specific concentration, ug/m3

0

10

20

30

40

50

60

70

80

Port Huron

 base concentration, ug/m3

0 10 20 30 40 50 60 70 80

site-specific concentration, ug/m3

0

10

20

30

40

50

60

70

80

SW High Sch.

538 

base concentration, ug/m3

0 10 20 30 40 50 60 70 80

site-specific concentration, ug/m3

0

10

20

30

40

50

60

70

80

Wyandotte

 base concentration, ug/m3

0 10 20 30 40 50 60 70 80

site-specific concentration, ug/m3

0

10

20

30

40

50

60

70

80

Ypsilanti

539 

540 

541 Figure 4-3 (continued). Site-specific concentrations versus base concentrations for valid network days. 

Solid line is the base concentration (1:1 line) and dashed line is 35 Pg/m3 542 . 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 23

0

5

10

15

20

Allen Park

Dearborn

E 7 Mile

Linwood

Livonia

Luna Pier

New Haven

Oak Park

Port Huron

SW High Sch.

Wyandotte

Ypsilanti

site conc. in excess of network-wide base conc., ug/m3

5th max

50th percentile

543 

Figure 4-4. Site-specific exceedance days: 5th 544 -highest excess concentration compared to base 

concentration (yellow); and 50th 545 -precentile excess concentration compared to base concentration (green). 

546 

547 high nitrate days shows the spatial variability can range from nearly homogeneous to quite 

548 heterogeneous (such as the above noted days). It is likely that nitrate is driving the variability on 

549 such days and is responsible for many of the outlier mass concentrations at high base 

550 concentrations in Figure 4-3. There are at least two possible explanations for this behavior. 

551 First, there might be nitrate hot spots on high nitrate days. These hot spots are most likely to 

552 occur on days with a liquid aerosol due to high humidity. A qualitative inspection of surface 

553 weather on high nitrate days suggests they often coincide with fog events. The aerosol state 

554 (liquid versus dry), and degree of water content if wet, might vary across the network due to 

555 micrometeorology and this could influence nitrate uptake. Spatial variations in crustal material 

556 could also influence the pH of the liquid aerosol which in turn influences nitrate uptake. Second, 

557 there might be varying nitrate measurement artifact on certain high nitrate days. Even if the 

558 ambient nitrate concentration is spatially homogeneous, perhaps the Teflon filters are retaining 

559 nitrate to varying degrees and this artificially induces a spatial variability in both nitrate in FRM 

560 mass. A better understanding of the drivers for high spatial variability in FRM mass on high 

561 nitrate days is needed since only a few such events can dramatically affect the site-specific 

562 design values for the 24-hour standard. When such patterns are observed, perhaps the Teflon 

563 filters could be analyzed for nitrate by IC to determine the extent of nitrate retention; this would 

564 be particularly insightful for days coinciding with speciation sampler operation. 

565 

566 Figure 4-5 shows the same data as Figure 4-3 for Dearborn and Wyandotte but stratified to 

567 isolate the period 2004-2006 (the most-recent three-year period for the data set used in this 

study). Focusing on those days with base concentration below 35 Pg/m3 568 (to the left of the 

vertical solid line) but with site-specific concentrations approaching or greater than 35 Pg/m3 569 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 24

base concentration, ug/m3

0 10 20 30 40 50 60 70 80

site-specific concentration, ug/m3

0

10

20

30

40

50

60

70

80

Dearborn

(a)

base concentration, ug/m3

0 10 20 30 40 50 60 70 80

site-specific concentration, ug/m3

0

10

20

30

40

50

60

70

80

Wyandotte

(b)

570 

571 

572 Figure 4-5. Site-specific concentrations versus base concentrations for valid network days at Dearborn 

573 (a) and Wyandotte (b) stratified by year: 1999-2003 (red markers); and 2004-2006 (green markers). Solid 

574 diagonal line is the base concentration (1:1 line), and the solid vertical line and dashed horizontal line are 

35 Pg/m3 575 . 

576 

577 

578 (above the dashed horizontal line), these days correspond to cases where nearby local emission 

579 sources are likely significant contributors to an exceedance (or near exceedance) that otherwise 

580 would not occur. For Dearborn (Figure 4-4a), there has been a decrease in frequency of such 

581 local plume days but they are certainly still present for the 2004-2006 period. For Wyandotte 

582 (Figure 4-4b), however, virtually all of the days with local source plumes driving an exceedance 

583 (or near exceedance) of the standard were prior to 2004. For the most recent data (2004-2006), 

584 Wyandotte does not appear to be disproportionately influenced by local plumes on exceedance 

585 (or near exceedance) days. Again, these figures do not represent all sample days but rather the 

586 subset of days with ten-or-more reporting monitors such that network-wide behavior could be 

587 characterized; however, as previously demonstrated, this subset of days does appear to be 

588 representative of the overall data set. 

589 

590 The analysis presented to this point clearly demonstrates that exceedances at most sites 

591 correspond to days when the entire network is exhibiting high PM concentrations and the rare 

592 extreme values are likely due to exceptional events or possibly a nitrate hot spot or measurement 

593 artifact. Some sites, especially Dearborn and Wyandotte, have a significant excess superposed 

594 on the base concentration leading to exceedances when the base concentration is as low as 

20 Pg/m3 595 . It would be helpful to determine whether the day-to-day variability in the base 

596 concentration is driven by regional transport, poor atmospheric ventilation of urban-scale 

597 emissions, or a combination of these factors. There is no direct methodology to partition these 

598 influences but insights can be obtained by examining the PM speciation data and surface winds 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 25

FRM mass concentration, ug/m3

0 10 20 30 40 50 60 70

total ion concentration, ug/m3

0

10

20

30

40

50

60

70

December - April

May - November 

599 

600 Figure 4-6. Total major ion concentration (sulfate, nitrate and ammonium) versus FRM mass at Allen 

601 Park, stratified by season. 

602 

603 

distributions.7 604 Figure 4-6 shows the contribution of major ions (sulfate, nitrate, and ammonium) 

605 to FRM mass at Allen Park for the period December 2002 through December 2006. There were 

606 valid FRM and speciation data for 21 of the 71 exceedances observed at Allen Park during this 

607 time period. Six (29%) of these 21 exceedances days exhibited major ion concentrations greater 

than 35 Pg/m3

 and thus the major ions alone were sufficient to cause the exceedance.8 608 Over all 

609 21 exceedance days the major ion contribution was 56-112% of the standard (median 84%) and 

610 53-85% of the FRM PM2.5 mass concentration (median 71%). At Allen Park the major ions are 

611 more than half of the PM on all exceedance days and, since Allen Park is representative of the 

612 network-wide base concentration (Figure 4-3), the major ions are deemed the dominant PM 

613 component at all sites with small local plume impacts. 

614 

615 Aerosol composition at Allen Park was examined in more detail for the network-wide high PM 

616 days. Speciation data was available for 31 of the 41 days. Figure 4-7 is a scattergram for sulfate 

617 and nitrate on these days with all sulfate assumed to be ammonium sulfate and all nitrate 

618 assumed to be ammonium nitrate. Summertime events typically exhibit high sulfate and 

619 relatively low nitrate. Wintertime events exhibit high nitrate but sulfate is typically ~50% or 

620 more of the nitrate concentration. Thus, while the wintertime events are often called high nitrate 

621 days, it should be noted that sulfate is also quite significant on these days. Overall, 55% of these 

 

8

 This assumes nitrate does not appreciably volatile from the FRM Teflon filter; in practice, the major ion 

concentration will be lower due to nitrate volatilization. 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 26

0

5

10

15

20

25

30

35

40

0 10 20 30 40

sulfate as ammonium sulfate, Pg/m3

nitrate as ammonium nitrate ,Pg/m3

May-November

December-April 1:1

2:1

1:2

622 

623 Figure 4-7. Ammonium nitrate and ammonium sulfate concentrations at Allen Park on network-wide 

624 high PM days. 

625 

626 

627 31 days have a combined ammonium sulfate plus ammonium nitrate concentration exceeding 

25 Pg/m3 628 although, as previously mentioned, the contribution of these ions will be less on certain 

629 days after correcting for ammonium nitrate loss from the FRM Teflon filters. 

630 

631 Previous work has demonstrated that sulfate at Allen Park is overwhelmingly from regional 

632 transport; nitrate is likely dominated by regional transport but the precise split between regional 

633 and local sources remains unknown. Assuming the sulfate and nitrate are regionally transported, 

634 the total contribution from regional sources would likely be larger than the sum of the major ions 

635 (after correction for nitrate loss), but cannot be further quantified because organic matter likely 

636 has significant regional and local contributions and at this time the organic matter concentrations 

637 in Southeast Michigan cannot be apportioned to regional and local contributions on an average 

638 basis, no less a day-to-day basis. A multivariable linear regression was performed to explain the 

639 observed organic carbon (OC) in terms of observed sulfate and elemental carbon (EC). The 

unconstrained regression yielded (R2

 = 0.50, all units in Pg/m3 640 ); 

641 

642 OC (1.53 r 0.22)  (0.176 r 0.029)SO4  (2.49 r 0.26)EC

643 

644 where the 95% confidence interval for each regression parameter is reported. There are many 

645 caveats to this very simple approach to apportioning the OC. For example OC associated with 

646 sulfate would likely vary by season due to differences in secondary formation rates. The 

647 approach is merely intended as a crude way to assign OC to a component that associates with 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 27

648 local, primary emissions (OC associating with EC) and a component that scales with sulfate. 

649 The results should not be over-interpreted. Assuming an OM/OC ratio of 1.8, the scaling factor 

650 for organic matter associated with sulfate would be 0.32uSO4. Figure 4-8 shows the 

651 contribution of major ions measured at Allen Park to the base concentration on valid network 

652 days (Figure 4-8a) and the contribution of the major ions plus this crude estimate of the OM 

653 associated with sulfate (Figure 4-8b). The inclusion of associated OM substantially closes the 

654 mass balance on the base concentration. High base concentrations can largely be explained by 

655 regionally transported material alone and any concomitant increase in urban- and finer-scale 

656 contributions (for example, due to poorer atmospheric ventilation) might be relatively modest. 

657 From Figure 4-8a it can also be discerned that the major ion contribution deviates positively from 

the median contribution at base concentrations above ~ 20 Pg/m3 658 ; it is above this value that 

659 major ions – and thus presumably regional transport – disproportionately influences the 

660 observed PM2.5 mass concentrations. 

661 

662 Concentration enhancements in surrogates for regional transport (sulfate and nitrate as 

663 surrogates) and urban-scale local emissions (EC as surrogate) were examined for the 

664 network-wide high PM days. For each valid network day with speciation data at Allen Park, 

665 concentrations for the major aerosol components were compared to the monthly median values 

666 obtained by pooling over all valid network days and over all years. Sulfate was on average 

667 4.5 times higher and nitrate was on average 2.8 times higher on network-wide high concentration 

668 days compared to the corresponding monthly median value. In contrast, EC was on average only 

669 1.3 times higher on network-wide high concentration days compared to the corresponding 

monthly median EC concentration.9 670 Using the EC enhancement as an indicator for the 

671 atmospheric ventilation of urban-sale emissions, this analysis suggests reduced atmospheric 

672 ventilation on network-wide high PM days does indeed increase the urban- and-finer scale 

673 contributions but, in the absence of direct plume hits from near-field sources, the enhancement is 

674 much smaller than observed for the major ions which are associated with regional transport. OC 

675 was on average 1.6 times higher on network-wide high PM days compared respective monthly 

676 median concentration (1.8 times higher if the OC data is blank-corrected). This enhancement is 

677 between the values ascribed to regionally transported material and urban-scale emissions, 

678 consistent with OC contributions from a combination of local (urban or finer-scale) primary 

679 sources and secondary formation (whether local or regional in origin). 

680 

681 Lastly, the daily FRM sampling at Allen Park is exploited to determine whether high PM days at 

682 each site correspond to a spatially- and temporally- isolated excursion (high PM not observed at 

683 Allen Park which, as shown in Figure 4-3, largely captures the network-wide PM base 

684 concentration), a temporally-isolated excursion (high PM also observed at Allen Park on that day 

685 but not the preceding or following day), or a multiday PM episode (high PM observed at Allen 

686 Park on adjacent days). Multiday PM episodes are stratified into two groups – two successive 

687 high PM days at Allen Park, and three-or-more successive high PM days at Allen Park. Two 

688 successive high PM days could arise from a brief event that straddles midnight, while 

689 three-or-more more successive high PM days clearly indicate an episode with temporal 

690 persistence, whether caused by regional transport or sustained areawide air mass stagnations. 

 

9

 EC has a day-of-week trend at Allen Park (higher on weekdays) so the analysis was repeated by first stratifying 

days as weekends and weekdays and then calculating the day-specific enhancement compared to the respective 

weekend or weekday monthly median value. The same average enhancement – a factor of 1.3 – was obtained. 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 28

High PM conditions were defined as >30 Pg/m3

 for the interrogated site and >25 Pg/m3 691 for the 

692 reference site (Allen Park). Figure 4-9 shows the site-specific distributions. Dearborn has the 

693 highest frequency of spatially- and temporally-isolated high PM days (red bars; dates for all sites 

694 listed in Appendix C). As previously described, nearby emission sources are most important at 

695 this site and can drive high PM days even when the network-wide base concentration is as low as 

20 Pg/m3 696 . Relatively high frequencies of spatially- and temporally-isolated high PM days were 

697 also observed at Wyandotte, Southwest High School, and East 7 Mile. At all sites except 

698 Dearborn, high PM days most frequently correspond to multiday PM episodes (blue plus green 

699 bars) and most frequently to longer-persistence episodes (three- or-more days with high PM at 

700 Allen Park). 

701 

702 In summary – 

703 x Network-wide high PM days are observed primarily in the summertime but are also 

704 observed in the wintertime. 

705 x Network-wide high PM days in the summer typically have high sulfate and relatively low 

706 ambient nitrate. The nitrate contributions to FRM mass will be even lower after 

707 accounting from ammonium nitrate volatilization from the Teflon filter. 

708 x Network-wide high PM days in the winter typically have high nitrate but ammonium 

709 sulfate is typically at least 50% of the ammonium nitrate mass so these events are 

710 actually high nitrate and high sulfate. 

711 x Network-wide high PM days are primarily driven by regional transport with 

712 intensification of urban-scale emissions due to low atmospheric ventilation being 

713 relatively less important. Plume impacts from nearby emission sources are superposed 

714 on the network-wide baseline. 

715 x Site-specific high PM days are most often observed when the area is experiencing a 

716 multiday high PM episode. 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 29

0

10

20

30

40

50

60

70

0 10 20 30 40 50 60 70

FRM mass, ug/m3

total ion concentration, ug/m3

all valid network days

network-wide high PM day

1:1

median mass 

fraction

717 

718 (a)

0

10

20

30

40

50

60

70

0 10 20 30 40 50 60 70

FRM mass, ug/m3

total ion concentration plus associated OM, ug/m3

all valid network days

network-wide high PM day

1:1

median mass 

fraction

719 

720 (b)

721 

722 Figure 4-8. Allen Park species contributions to the base concentration on valid network days: major ions 

723 only (a); and major ions plus associated organic matter (b). 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 30

724 

725 

Dearborn

East 7 Mile

Linwood

Livonia

Luna Pier

New Haven

Oak Park

Port Huron

Southwest HS

Wyandotte

Ypsilanti

fraction in stated category

0.0

0.2

0.4

0.6

0.8

1.0

AP < 25 ug/m3 on same day

AP > 25 ug/m3 on same day only

AP > 25 ug/m3 on two consecutive days

AP > 25 ug/m3on three-or-more consecutive days

726 

Figure 4-9. Classification of high PM days (PM2.5 > 30 Pg/m3 727 ) at each site in Southeast Michigan by the 

728 time series behavior of daily PM2.5 at Allen Park. 

729 

730 

731 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 31

732 5. RELATIONSHIPS BETWEEN SITE-SPECIFIC EXCESS MASS AND SURFACE 

733 WINDS

734 

735 The previous section demonstrates that exceedances of the 24-hour PM2.5 NAAQS at most sites 

736 in Southeast Michigan are primarily driven by an enhancement of regionally transported material 

737 which elevates the concentration baseline upon which local contributions are superposed. There 

738 is typically a modest enhancement in the urban-scale contributions on high PM days, presumably 

739 due to coincident air mass stagnations. This does not imply that urban-scale contributions are 

740 small, but rather they are not significantly modulated on high PM days. At a few sites, plumes 

741 from nearby emission sources can substantially contribute to exceedances and near exceedances. 

742 

743 This section presents relationships between the excess mass (relative a reference concentration 

744 that should capture regional- and larger-scale influences, and to some extent urban-scale 

745 influences) and surface winds for each site. This analysis does not focus on excess mass 

746 observed on high PM days exclusively, but rather excess mass over the entire concentration 

747 distribution. While in principle there might be different local sources contributing on high PM 

748 days compared to all other days, the previous analyses do not provide any evidence for such 

749 preferential behavior and there is much statistical power to be gained from using the entire data 

750 set. Allen Park was initially chosen as a reference site for generating the times series of excess 

751 mass. Figure 4-3 demonstrates that Allen Park is indeed highly correlated with the network-wide 

752 base concentration on most days, although it is modestly influenced by nearby emissions for 

753 winds from the northeast (Dearborn) (Wade et al. 2008). Thus, the calculated excess mass 

754 concentrations at other sites might be biased low for winds from the northeast and sources in this 

755 direction might be damped or even missed. This limitation does not significantly affect the 

756 results for other bearings. Certain analyses were repeated using the network-wide base 

757 concentration as the reference for calculating excess mass. This reduces the number of sample 

758 days used in the analyses but removes any issues with directional bias introduced by using a 

759 single site as the reference. Finally, this methodology also relies on having representative 

760 surface winds at the site. It is not clear that hourly winds from Detroit Metropolitan Wayne 

761 County Airport will be representative for sites such as Luna Pier and Port Huron; however, the 

762 excess mass construct using Allen Park or the entire Southeast Michigan network to define a 

763 base concentration is perhaps an equally limiting factor when examining these distant sites. 

764 

765 Relationships between excess mass and surface winds were probed using Conditional Probability 

766 Function (CPF) and 1-D Nonparametric Wind Regression (NWR) plots. A brief summary of the 

767 methods and their utility is presented in Appendix D. The stability of CPF and NWR results 

768 was examined in various ways. Many analyses were run with the entire data set (1999-2006) and 

769 the most recent three years (2004-2006) since greatest interest is in current conditions. The 

770 former includes substantially more data and is less susceptible to spurious results. The threshold 

771 for high excess mass in the CPF analysis was chosen as the top quartile and each analysis was 

772 repeated using the top decile. Finally, sensitivity to days with high excess mass at the reference 

773 site (Allen Park) was examined by running most of the analyses on the full data set and then 

774 repeating the analyses with the data censored to exclude days where the excess mass was less 

than -2 Pg/m3 775 . This threshold is based on two times the propagated collocated precision for the 

concentration difference using a collocated precision of 0.7 Pg/m3 776 for a single measurement. 

777 Since the excess mass concentration is a 24-hour integrated parameter but the surface winds data 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 32

778 are hourly, care must be taken in handling calm hours. Calms days (operationally defined as 

779 six-or-more calm hours in the day) were retained but calm hours (wind speeds less than 2 mph) 

were removed.11 780 

781 

782 Figure 5-1 shows the CPF analysis results for each site using the top decile of the excess mass 

783 distribution as the threshold for a high concentration and for the period 1999-2006. Plots for 

784 Luna Pier, New Haven and Oak Park are excluded because they were either sensitive to the 

785 methodology or indistinguishable from the CPF plot for the absolute mass concentration at the 

786 site. The plots were nearly identical when using 1999-2006 data and 2004-2006 data only, 

787 which means the bearings of sources driving the excess mass have not changed over time. 

788 Dearborn, Newberry, and Wyandotte CPF plots all implicate sources to the southwest. These are 

789 likely nearby sources and, recalling that the prevailing wintertime surface winds are from the 

790 southwest (Figures 3-4 and 3-5) it is not surprising that the analyses in Section 4 implicated local 

791 sources as significant contributors to the excess mass at these sites given the favorable wind 

792 directions for advecting emissions from the sources to these sites. East 7 Mile, Linwood, and 

793 Southwest High School CPF plots exhibit higher frequency of excess mass with winds from the 

794 south/southwest, albeit weaker signatures than observed for Dearborn / Newberry / Wyandotte. 

795 Ann Arbor and Ypsilanti have a higher frequency of high excess mass when the winds are from 

796 the east and Livonia has a higher frequency of high excess mass when the winds are from the 

797 southeast. All three of these cases correspond to bearings in the direction of the Detroit 

798 population and/or commercial/industrial cores. However, surface winds from the east are not 

799 common and thus these sites are rarely downwind of the urban core zones. The CPF plot for 

800 Port Huron implicates sources at bearings east through south of the site which is consistent with 

801 the industrial zones along the U.S./Canada border including but not limited to petroleum 

802 refineries. In summary, the CPF plots are consistent with the local source impacts identified in 

803 Section 4 and consistent with known emission source regions. It appears this analysis can pick 

804 up the urban plume advected from Detroit to sites that are outside the urban emissions zone. 

805 

806 NWR plots show the expected excess concentration as a function of wind direction. Several 

807 analyses were performed using Allen Park data for the reference concentrations (see footnote 

808 #11). Subsequently, NWR plots were constructed using the network-wide base concentration 

809 estimates for the reference concentrations and those results, which were generally consistent with 

810 the results that were obtained using Allen Park as a reference, are presented here. Yearly box 

811 plots were generated for the excess PM2.5 mass at each site compared to the network-wide base 

812 concentration. FRM data for 2007 was also included in these time series plots but have not been 

813 examined in sufficient detail for incorporation into wind regression analyses. Given the seasonal 

814 and year-to-year variability in surface winds, the representativeness of valid network days was 

815 assessed by comparing to the annual surface winds for all days. Figure B-2 shows annual wind 

816 roses for all days and valid network days. 

 

11 The following analyses were performed with results available upon request: CPF for top quartile of absolute 

concentration distribution (no subtraction of Allen Park concentration values), 1999-2006; CPF for top decile of 

entire excess mass distribution, 1999-2006; CPF for top quartile of entire excess mass distribution, 1999-2006; CPF 

for top quartile of censored excess mass distribution, 1999-2006; CPF for top decile of entire excess mass 

distribution, 2004-2006; CPF for top quartile of entire excess mass distribution, 2004-2006; NWR for entire excess 

mass distribution, 1999-2006; NWR for entire excess mass distribution, 2004-2006; and NWR for censored excess 

mass distribution, 1999-2006. 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 33

0

45

90

135

180

225

270

315

15

30

60

75

105

120

150

195 165

210

240

255

285

300

330

345

0 0.1 0.2 0.3 0.4

Ann Arbor

0

45

90

135

180

225

270

315

15

30

60

75

105

120

150

195 165

210

240

255

285

300

330

345

0 0.1 0.2 0.3 0.4

Dearborn

0

45

90

135

180

225

270

315

15

30

60

75

105

120

150

195 165

210

240

255

285

300

330

345

0 0.1 0.2 0.3 0.4

E 7 Mile

0

45

90

135

180

225

270

315

15

30

60

75

105

120

150

195 165

210

240

255

285

300

330

345

0 0.1 0.2 0.3 0.4

FIA/Lafayette

0

45

90

135

180

225

270

315

15

30

60

75

105

120

150

195 165

210

240

255

285

300

330

345

0 0.1 0.2 0.3 0.4

Linwood

0

45

90

135

180

225

270

315

15

30

60

75

105

120

150

195 165

210

240

255

285

300

330

345

0 0.1 0.2 0.3 0.4

Livonia

Newberry

0

45

90

135

180

225

270

315

15

30

60

75

105

120

150

195 165

210

240

255

285

300

330

345

0 0.1 0.2 0.3 0.4

Port Huron 0

45

90

135

180

225

270

315

15

30

60

75

105

120

150

195 165

210

240

255

285

300

330

345

0 0.1 0.2 0.3 0.4

SW High Sch.0

45

90

135

180

225

270

315

15

30

60

75

105

120

150

195 165

210

240

255

285

300

330

345

0 0.1 0.2 0.3 0.4

817 

Wyandotte

0

45

90

135

180

225

270

315

15

30

60

75

105

120

150

195 165

210

240

255

285

300

330

345

0 0.1 0.2 0.3 0.4

Ypsilanti

0

45

90

135

180

225

270

315

15

30

60

75

105

120

150

195 165

210

240

255

285

300

330

345

0 0.1 0.2 0.3 0.4

818 

819 

820 Figure 5-1. Conditional probability function plots for excess mass at each site relative to Allen Park, 

821 1999-2006. Probabilities are for the top decile of the excess mass distribution.
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 34

822 Data for 1999 were excluded from the concentration time series because the network was being 

823 phased in during that year; there were only 14 valid network days and the valid network days 

824 winds distribution was markedly different from the 1999 annual surface winds distribution. For 

825 the remaining years the annual wind roses for valid network days showed good agreement with 

826 the annual wind roses for all days (Figure B-2), including 2006 which had a relatively low 

827 number of valid network days (also seasonally biased towards the first quarter) due to a 

828 reduction in sampling frequency at certain sites. These favorable comparisons demonstrate the 

829 representativeness in using valid network days to capture annual average behavior for the site830 specific excess mass. 

831 

832 Figure 5-2 shows annual distributions of the network-wide base concentration. Similar 

833 distributions were observed for the first four years (2000-2003) with substantial year-to-year 

834 variability for the subsequent four years (2004-2007). The lowest median value was in 2004, 

835 followed by a relatively high mean value in 2005. 

836 

837 Excess mass annual time series and NWR plots were generated for each site with selected results 

838 presented in this report. NWR was performed after stratifying the data into two time periods: 

839 2000-2003 and 2004-2006. Hourly surface winds distributions, Figure 5-3, exhibit a lower 

840 frequency of winds from the southwest for the 2004-2006 period compared to the 2000-2003 

841 period. However, the NWR results are presented as the expected concentration value for each 

842 wind direction and thus are not influenced by the frequency distribution of wind direction. An 

843 apportionment of the average excess mass to wind sectors (and thus emission sources in that 

844 sector) would require a weighting of the sector-specific expected concentration by the sector845 specific frequency of wind direction. This step is discussed in Section 6 as a recommendation 

846 for future work. For the purpose of identifying whether emission source strengths have changed 

847 over time, the expected concentration as presented in this section is appropriate since it is not 

848 influenced by year-to-year differences in the distribution of surface wind directions. 

849 

850 

2000 2001 2002 2003 2004 2005 2006 2007

network-wide baseline concentration, ug/m3

0

5

10

15

20

25

30

35

40

( 84) (104) (101) (113) (117) (121) ( 73) (120)

851 

Figure 5-2. Annual distributions of the network-wide base concentration. Open circles are 5th and 95th 852 

853 percentile values; the red and black lines are mean and median values (solid within box for yearly, dashed 

854 for entire data set); and the number of samples is in parenthesis at the top of each plot. 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 35

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

10% 11% 

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

855 

856 (a) 2000-2003 (b) 2004-2006 

857 

858 Figure 5-3. Wind rose for non-calm hours, observations at Detroit Metropolitan Wayne County Airport 

859 (DTW): (a) 2000-2003; and (b) 2004-2006. Calms (wind speeds less than 2 mph) are listed to the 

860 lower-left of each wind rose. 

861 

862 

863 Ann Arbor, FIA/Lafayette, Newberry were excluded because sampling was not sustained over 

864 the 2000-2006 time period. Luna Pier and Port Huron were excluded because they are at the 

865 spatial extents of the geographic domain and both the base concentration estimates and surface 

866 winds might not be representative. Figures 5-4 through 5-7 show the time series and NWR plots 

867 for Dearborn, Wyandotte, Southwest High School and Linwood, respectively. NWR results as 

polar plots are presented with the radial concentration units in Pg/m3 868 ; the red line is the average 

869 contribution and the pink lines are the 95% confidence intervals. NWR results were also 

870 generated after first censoring the data to remove extreme values and thereby stabilize the 

expected concentration estimates.12 871 The bottom plot in each panel of Figure 5-4 shows the NWR 

872 results for censored data, and includes the difference in expected concentration values between 

873 the two time periods (blue line). Figure E-1 (Appendix E) presents NWR results for all sites as 

874 Cartesian plots for all data and censored data. 

875 

876 Dearborn (Figure 5-4) exhibits the average highest average excess mass. Both the mean and 

877 median excess mass decreased beginning in 2005 despite an increase that year in the mean base 

878 concentration (Figure 5-2). The time series for the annual base concentration and excess mass 

879 concentration are decoupled which adds confidence that the decreases in excess mass are real. 

Expected mass concentrations of at least 2 Pg/m3 880 were observed for all wind directions (center 

881 and bottom plots in Figure 5-4) with elevated excess mass for bearings 120-300qN and a 

maximum in the expected concentration at ~225qN of with concentrations 9 and 7 Pg/m3 882 for 

2000-2003 and 2004-2006, respectively. The excess mass floor of ~2 Pg/m3 883 might be real since 

884 the Detroit population core, perhaps a surrogate for mobile source and area emissions, is to the 

 

12 Extreme values were defined as those values exceeding the upper outer fences (UOF) and lower outer fences 

(LOF) of the nonparametric distribution of excess mass: CUOF = C75 + 3uCIQR; and CLOF = C25 - 3uCIQR where Ci is 

concentration i, subscripts 25 and 75 denote 25th and 75th percentiles, and IQR is the interquartile range (C75 - C25). 

>2 - 4

>4 - 8

>8 - 16

>16

WS (mph)
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 36

885 DEARBORN

2000 2001 2002 2003 2004 2005 2006 2007

excess above network-wide baseline, ug/m3

-5

0

5

10

15

20

( 76) ( 98) ( 96) (105) (105) (114) ( 70) (114)

Dearborn

2000-2003 2004-2006

0 2 4 6 8 10

9

60

30

0

330

300

70

240

210

180

150

120

0 2 4 6 8 10

9

60

30

0

330

300

70

240

210

180

150

120

-2

0

2

4

6

8

10

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, Pg/m3

Dearborn, 2000-2003

Dearborn, 2004-2006

[2004-2006] minus [2000-2003]

886 

887 Figure 5-4. Excess PM2.5 mass compared to the network-wide base concentration. Top: box plots of 

annual excess mass concentration distributions. Open circles are 5th and 95th 888 percentile values; the red 

889 and black lines are mean and median values (solid within box for yearly, dashed for entire data set); and 

890 the number of samples is in parenthesis. Center: 1-D NWR for excess mass at each site relative to the 

891 network-wide baseline concentration for 2000-2003 (left) and 2004-2006 (right). Average concentrations 

and 95% confidence intervals are red and pink lines, respectively, and radial units are Pg/m3 892 . Bottom: 

893 1-D NWR expected excess mass concentrations after censoring the data to remove extreme values. 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 37

894 WYANDOTTE

2000-2003 2004-2006

2000 2001 2002 2003 2004 2005 2006 2007

excess above network-wide baseline, ug/m3

-5

0

5

10

15

20 Wyandotte

( 82) ( 99) ( 90) (100) (107) (112) ( 69) (116)

012345

9

60

30

0

330

300

70

240

210

180

150

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012345

9

60

30

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330

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120

2000-2003 2004-2006

-2

0

2

4

6

8

10

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, Pg/m3

Wyandotte, 2000-2003

Wyandotte, 2004-2006

[2004-2006] minus [2000-2003]

895 

896 Figure 5-5. Excess PM2.5 mass compared to the network-wide base concentration. Top: box plots of 

annual excess mass concentration distributions. Open circles are 5th and 95th 897 percentile values; the red 

898 and black lines are mean and median values (solid within box for yearly, dashed for entire data set); and 

899 the number of samples is in parenthesis. Center: 1-D NWR for excess mass at each site relative to the 

900 network-wide baseline concentration for 2000-2003 (left) and 2004-2006 (right). Average concentrations 

and 95% confidence intervals are red and pink lines, respectively, and radial units are Pg/m3 901 . Bottom: 

902 1-D NWR expected excess mass concentrations after censoring the data to remove extreme values. 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 38

903 SOUTHWEST HIGH SCHOOL

2000-2003 2004-2006

2000 2001 2002 2003 2004 2005 2006 2007

excess above network-wide baseline, ug/m3

-5

0

5

10

15

20 Southwest High Sch.

( 82) ( 102) ( 94) (105) (110) (114) ( 70) (113)

012345

9

60

30

0

330

300

70

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120

012345

9

60

30

0

330

300

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210

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120

-2

-1

0

1

2

3

4

5

6

7

8

9

10

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, Pg/m3

SW High Sch., 2000-2003

SW High Sch., 2004-2006

[2004-2006] minus [2000-2003]

904 

905 Figure 5-6. Excess PM2.5 mass compared to the network-wide base concentration. Top: box plots of 

annual excess mass concentration distributions. Open circles are 5th and 95th 906 percentile values; the red 

907 and black lines are mean and median values (solid within box for yearly, dashed for entire data set); and 

908 the number of samples is in parenthesis. Center: 1-D NWR for excess mass at each site relative to the 

909 network-wide baseline concentration for 2000-2003 (left) and 2004-2006 (right). Average concentrations 

and 95% confidence intervals are red and pink lines, respectively, and radial units are Pg/m3 910 . Bottom: 

911 1-D NWR expected excess mass concentrations after censoring the data to remove extreme values. 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 39

912 LINWOOD

2000-2003 2004-2006

2000 2001 2002 2003 2004 2005 2006 2007

excess above network-wide baseline, ug/m3

-5

0

5

10

15

20 Linwood

( 80) ( 98) ( 91) (106) (105) (110) ( 66) (111)

0.0 0.5 1.0 1.5 2.0 2.5

9

60

30

0

330

300

70

240

210

180

150

120

0.0 0.5 1.0 1.5 2.0 2.5

9

60

30

0

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300

70

240

210

180

150

120

-2

0

2

4

6

8

10

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, Pg/m3

Linwood, 2000-2003

Linwood, 2004-2006

[2004-2006] minus [2000-2003]

913 

914 Figure 5-7 Excess PM2.5 mass compared to the network-wide base concentration. Top: box plots of 

annual excess mass concentration distributions. Open circles are 5th and 95th 915 percentile values; the red 

916 and black lines are mean and median values (solid within box for yearly, dashed for entire data set); and 

917 the number of samples is in parenthesis. Center: 1-D NWR for excess mass at each site relative to the 

918 network-wide baseline concentration for 2000-2003 (left) and 2004-2006 (right). Average concentrations 

and 95% confidence intervals are red and pink lines, respectively, and radial units are Pg/m3 919 . Bottom: 

920 1-D NWR expected excess mass concentrations after censoring the data to remove extreme values. 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 40

921 north and east and the site is located in the Detroit commercial/industrial core. It is possible, 

922 however, that the excess mass floor reflects contamination in the NWR analysis from using 

923 daily-integrated FRM mass together with hourly winds which might vary over the course of the 

924 day and thus smear short duration, high intensity contributions from the local emission sources 

925 across other wind directions. The period 2004-2006 does indeed exhibit lower excess mass 

926 concentrations compared to 2000-2003, consistent with Figure 4-5, with maximum reductions of 

~2 Pg/m3 927 from ~195-255qN. The Dearborn NWR results were insensitive to the censoring of 

928 data to remove extreme values (Figure E-1). In summary, Dearborn is significantly influenced 

929 by local emission sources to the southwest of the site. This is also the direction of the prevailing 

930 wind and thus emission controls on these sources would have a dramatic impact on observed 

931 concentrations at the Dearborn site. There is also a significant urban scale contribution 

regardless of wind direction with expected concentration greater than 2 Pg/m3 932 (the excess mass 

floor is 2 Pg/m3 933 plus there are urban-scale contributions to the base concentration) although the 

934 relative contributions of mobile, area, and dispersed point source emissions is not clear. 

935 

936 Wyandotte and Southwest High School have similar mean and median excess mass, second after 

937 Dearborn. Let us first consider Wyandotte. The top plot in Figure 5-5 shows a dramatic and 

938 steady reduction in mean and median excess mass starting in 2004. Expected mass 

concentrations were lowest for wind directions from the east/southeast (indeed, ~0 Pg/m3 939 for 

940 2004-2006) which is consistent with the orientation of the site relative to local sources and the 

941 Detroit population and commercial / industrial cores. There are two sectors with high expected 

942 excess mass concentrations. One sector is broadly to the north/northwest with expected excess 

mass concentrations ~2 Pg/m3 943 for 2000-2003 and with ~50% decrease for 2004-2006. This 

944 bearing is consistent with the location of the Detroit population and commercial / industrial cores 

945 which are north of Wyandotte. The other sector is to the southwest with a maximum excess 

mass concentration of nearly 4 Pg/m3 946 for 2000-2003 and with ~50% decrease for 2004-2006. 

947 Given both the alignment of this sector with the prevailing wind direction and the magnitude of 

948 the expected concentrations, the emission reductions achieved from this sector are most 

949 responsible for the observed decrease in the excess mass concentration over time. Local 

950 emission sources in this sector include a large quarry. Like Dearborn, the NWR results are 

951 relatively insensitive to the censoring of extreme values (Figure E-1). In summary, the wind 

952 direction dependence of expected excess mass concentration at Wyandotte is consistent with 

953 known emission sources / source regions. Expected concentrations have decreased over the past 

954 few years for two wind distinct bearings – north and southwest of the site – which suggest that 

955 emission reductions have taken place in both sectors. The reductions from the southwest are 

956 more significant to both annual average concentrations and high PM days. 

957 

958 Annual mean and median excess mass concentrations at Southwest High School also decreased 

959 starting in 2005 (Figure 5-6). NWR polar plots suggest the excess mass decrease was driven by 

960 emission reductions to the south/southwest. However, NWR results for all data and censored 

961 data (Figure E-1) demonstrate that a few extreme events were driving the higher expected mass 

962 from the south/southwest for 2000-2003 compared to 2004-2006. Indeed, the NWR plot for 

963 censored data (Figure 5-6, bottom) shows essentially no difference in expected excess mass at 

964 the location of the maximum (~190qN). Emission reductions might be driving small differences 

965 in expected excess concentration between 2000-2003 and 2004-2006 at bearings of ~105, 

250-300, and 355qN. The expected excess mass concentration floor was ~2 Pg/m3 966 for 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 41

967 2000-2003 and was modestly lower for 2004-2006. This floor is similar to the excess mass 

968 concentration floor observed at Dearborn which is consistent with their close proximity. In 

969 summary, in contrast to Dearborn and Wyandotte, individual local sources contributing to excess 

970 mass at Southwest High School appear to have smaller average impact and are potentially more 

971 numerous. Highest expected concentrations are from bearing of ~190qN and with extreme 

972 events realized primarily in the period 2000-2003. Based on Figure 4-3 these events typically 

occurred on relatively clean days (base concentrations 10-20 Pg/m3 973 ) and were not sufficiently 

974 high to cause exceedances. Like Dearborn, there is a relatively high floor for the excess mass 

975 over all wind directions but the relative contributions of mobile, area, and dispersed point source 

976 emissions is not known. 

977 

978 Linwood is located near the northeast corner of the Detroit industrial core. There are no 

979 discernible changes in the excess mass distribution over time (Figure 5-7). NWR polar plots 

980 show different features for the 2000-2003 and 2004-2006 time periods; the differences are driven 

981 by extreme values and NWR on the censored data yields very consistent concentrations profiles 

982 for the two time periods (Figure 5-7, bottom plot). The excess mass concentration floor is 

~0.5 Pg/m3 983 with perhaps modestly lower values for bearings to the east/northeast (60-105qN). 

984 Increased excess mass is observed over the range 120-240qN with a broad maximum at 150-

985 210qN. This behavior suggests that Linwood is at the fringe of the high emissions zone in the 

986 Detroit commercial/industrial core. Excess mass concentrations when the winds are from the 

southwest approach 1.5-2 Pg/m3 987 , consistent with the floors at Dearborn and Southwest High 

988 School. For other wind directions, the expected concentrations are lower. 

989 

990 The above detailed analysis of four sites – Dearborn ,Wyandotte, Southwest High School, and 

991 Linwood – contributes to our understanding of local and urban-scale emissions contributions to 

992 observed PM mass. Local point source impacts are historically large at both Dearborn and 

993 Wyandotte but have been decreasing. In both cases, the largest contributors are located 

994 southwest of the sites, which is consistent with the prevailing winds. Dearborn and Southwest 

High School have expected excess mass concentrations of a least 1.5-2 Pg/m3 995 from all wind 

996 directions, while the minimum expected mass concentrations are lower at Wyandotte and 

997 Linwood. Thus, Dearborn and Southwest High School appear to be within the high emissions 

998 zone with contributions from multiple point sources and possibly significant contributions from 

999 area and mobile sources. The plume from this high emissions zone is advected downwind, 

1000 consistent with the higher expected excess mass concentrations at Wyandotte and Linwood for 

1001 winds from the north and south/southwest, respectively. Thus plume is superposed on the 

1002 broader urban-scale emissions contributions from mobile, area, and possibly other point sources, 

1003 which presumably also disperse as advected downwind. 

1004 

1005 This conceptual model is tested by examining excess mass patterns at sites outside the 

1006 commercial/industrial core. Figure 5-8 shows the Allen Park, Dearborn, Linwood, East 7 Mile, 

1007 and New Haven NWR results for 2004-2006 censored data (note the concentration scale range is 

1008 different than Figures 5-4 to 5-7). These five sites fall roughly along a transect oriented ~225qN 

1009 and thus can be examined using the framework of Figure 2-1. The right figure shows that Allen 

1010 Park (black line) and Linwood (red line) concentration profiles are nearly mirror images 

spanning the range 0.25-2 Pg/m3 1011 with a Linwood maximum and Allen Park minimum at 

1012 180-220qN. These sites are on opposite ends, and nearly equidistant, from Dearborn (clearly a 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 42

1013 

-2

-1

0

1

2

3

4

5

6

7

8

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, Pg/m3

Allen Park, 2004-2006

Dearborn, 2004-2006

Linwood, 2004-2006

East 7 Mile, 2004-2006

New Haven, 2004-2006

-2.0

-1.5

-1.0

-0.5

0.0

0.5

1.0

1.5

2.0

2.5

3.0

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, Pg/m3

Allen Park, 2004-2006

Linwood, 2004-2006

East 7 Mile, 2004-2006

New Haven, 2004-2006

1014 

1015 Figure 5-8. NWR expected concentrations for excess PM2.5 mass compared to the network-wide base 

1016 concentration, 2004-2006 data censored to remove extreme values as described in footnote #12. 

1017 

1018 hot spot, left figure) and the industrialized zone to its southeast. This suggests there is an 

1019 emissions plume emanating from Dearborn and industrial areas to its southeast, extending to the 

1020 Detroit River, which impact Allen Park and Linwood similarly in terms of expected 

1021 concentrations. Average mass contributions to these sites will differ with the frequency 

1022 distribution of wind directions. The expected concentration from this plume decreases at more 

1023 distant sites. It is still evident at East 7 Mile and is barely discernible from the baseline at New 

1024 Haven. In addition to this plume from the Detroit commercial/industrial core, there appears to be 

1025 a broader urban scale emissions profile as evidenced by the decreasing excess mass 

1026 concentration floors with increasing distance from the Detroit population core. Expected excess 

mass concentrations for bearings outside the commercial / industrial core plume are ~ 0.5 Pg/m3 1027 

at Allen Park and Linwood, ~0 Pg/m3 at East 7 Mile, and about -1 Pg/m3 1028 at New Haven. Recall 

1029 that the base concentration includes regional and some urban-scale contributions and the 

negative excess concentrations at New Haven suggest a maximum of at least 1.5Pg/m3 1030 (based on 

-1 Pg/m3

 at New Haven and +0.5 Pg/m3 1031 at Allen Park/Linwood) for the urban-scale 

1032 contributions within the metro area. 

1033 

1034 Six sites – Allen Park, East 7 Mile, Livonia, New Haven, Oak Park, and Ypsilanti – are 

1035 considered from a complementary perspective. Figure 4-3 demonstrates that large excess mass 

1036 excursions above the network-wide base concentration are relatively rare at these sites. There 

1037 are occasional extreme excess values which are both positive and negative with respect to the 

1038 base concentration, so the excess mass distributions were stabilized by censoring to remove 

extreme values.12 1039 NWR results for all these sites using both all data and censored data are 

1040 presented in Figure E-1. For each site, all expected concentrations were scaled so the lowest 

1041 expected concentration as a function of wind direction was zero (concentrations are negative 

1042 when the expected concentration is below the base concentration) and the normalized to a 

1043 maximum expected concentration of unity. Figure 5-9 shows the scaled NWR concentration 

1044 plots are superposed on 2000 census tract level population density data. The plots are ordered 

1045 clockwise about Detroit area starting with Ypsilanti and ending with Allen Park. The following 

1046 features are observed. 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 43

YPSILANTI LIVONIA

1047 

OAK PARK EAST 7 MILE

1048 

NEW HAVEN ALLEN PARK

1049 

1050 Figure 5-5. 1-D NWR for excess mass at each site (green circle) relative to the network-wide 

1051 baseline concentration for 2004-2006, censored to remove extreme values according to footnote 

1052 #12. NWR results are superposed on 2000 census tract population density data.
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 44

1053 

x Ypsilanti. The expected excess mass concentration ranged from -1 to +1 Pg/m3 1054 . 

1055 Bearings of highest excess mass concentration correspond to an urban plume emanating 

1056 from the east, consistent with the Detroit population and commercial/industrial cores. 

x Livonia. The expected excess mass concentration ranged from -1 to +1 Pg/m3 1057 . Bearings 

1058 of highest excess mass concentration correspond to an urban plume emanating from the 

1059 Detroit population and commercial/industrial cores with potentially larger impacts from 

1060 the latter core. 

x Oak Park. The expected excess mass concentration ranged from -0.5 to +1 Pg/m3 1061 . The 

1062 higher floor is consistent with this site being closer to the Detroit population and 

1063 commercial/industrial cores than Ypsilanti and Livonia. Bearings of highest excess mass 

1064 concentration range from due east to due south, consistent with the Detroit population 

1065 and commercial/industrial cores. 

x East 7 Mile. The expected excess mass concentration ranged from 0 to +1 Pg/m3 1066 . 

1067 Highest concentration bearings are to southwest with elevated expected concentrations 

1068 also to the west, consistent with the Detroit commercial/industrial and population cores, 

1069 respectively. 

x New Haven. The expected excess mass concentration is nearly constant at -1 Pg/m3 1070 . A 

1071 bearing of modestly elevated expected excess mass concentrations is to the southwest, 

1072 aligned with the Detroit commercial/industrial and population core. 

x Allen Park. The expected excess mass concentration ranged from 0.5 to +2 Pg/m3 1073 . 

1074 High concentration bearings are to the north through east of the site, consistent with the 

1075 Detroit population and commercial/industrial cores. 

1076 

1077 These six sites completely surround the Detroit population and commercial / industrial cores and 

1078 in each case demonstrate highest expected excess mass for winds from the core zones. This 

1079 analysis clearly demonstrates the ability to decouple excess mass concentrations from the 

1080 network-wide base and to draw a consistent interpretation from the results across all sites. 

1081 Ypsilanti, Livonia and New Haven all have expected excess mass concentrations of about -

1 Pg/m3 1082 when the sites are upwind of the Detroit population and commercial/industrial cores. 

1083 Thus a reasonable estimate for the average urban-scale contribution to the average network-wide 

base is about 1 Pg/m3. The 2004-2006 average base concentration of 13.5 Pg/m3 1084 could be 

apportioned as 12.5 Pg/m3

 from regional sources and a 1 Pg/m3 1085 portion of the urban-scale 

contributions. Urban-scale emissions contribute, on average, up to 3 Pg/m3 1086 depending on 

1087 location within the Greater Wayne County area and the specified wind pattern. They appear to 

1088 be greatest in the Detroit commercial/industrial core and might include significant contributions 

1089 from point sources that are either far enough from the monitor and/or low enough in emissions to 

1090 not be distinguished from the urban-scale contributions. Large local emission sources can exert 

1091 significant influence on near-field monitors as demonstrated for Dearborn and Wyandotte. 

1092 

1093 In summary, analyses of PM2.5 mass concentrations – separated into network-wide base and 

1094 site-specific excess mass components – together with surface winds provide the following model 

1095 for PM2.5 mass concentrations over Southeast Michigan (excluding the distant sites of Ann 

1096 Arbor, Luna Pier, and Port Huron): 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 45

1097 x At most sites, high PM days coincide with network-wide high PM levels and typically 

1098 occur when the area is experiencing a multiday high PM episode (Section 4). 

1099 x Hot spots of high PM concentration arise near large emission sources and, in the cases of 

1100 Dearborn and Wyandotte, can drive exceedances (or near exceedances) of the daily 

1101 standard. In both cases, the high emissions zones are located to the southwest of the 

1102 monitoring sites. This is consistent with the prevailing winds from the southwest 

1103 exacerbating the frequency of high impact days. Expected concentration contributions 

1104 from these zones have decreased in recent years, presumably due to emission reductions. 

1105 x An idealized conceptual model for PM behavior, that explains, both daily and annual PM 

1106 mass trends, consists of four layers: (1) regionally transported PM with average 

concentration of about 12.5 Pg/m3 1107 over the 2004-2006 period; (2) urban-scale emissions 

from mobile, area, and point sources that contribute up to 3 Pg/m3 1108 for specific surface 

1109 winds patterns, depending on location, with less impact when averaged over the 

1110 distribution of wind directions impacting a given site; (3) a PM plume from the Detroit 

1111 commercial/industrial core that remains distinct from the other urban-scale contributions 

1112 for sites as distant as East 7 Mile and possible New Haven; and (4) localized hot spots for 

1113 cases when certain monitoring sites are directly impacted by emission plumes from 

1114 nearby sources with high potentially impacts on a given day and less impact when 

1115 averaged of the distribution of wind directions impacting such sites. 

1116 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 46

1117 6. SUMMARY, POLICY-RELEVANT IMPLICATIONS, AND RECOMMENDATIONS 

1118 

1119 Summary

1120 

1121 At most sites in Southeast Michigan, exceedances occur predominantly – and in some cases 

1122 exclusively – on days when the entire network is exhibiting high PM. For thirteen of the fifteen 

1123 monitors, at least 85% of exceedances occurred on days when the entire network was exhibiting 

1124 high PM. Drivers for network-wide high PM are regional transport, poor atmospheric ventilation 

1125 across the network, or both of these conditions. Two monitors in particular – Dearborn and 

1126 Wyandotte – frequently had exceedances on days when the entire network was not exhibiting 

1127 high PM with 38% of the Dearborn exceedances and 27% of the Wyandotte exceedances 

1128 occurring on such days. On these days, these sites are significantly influenced by nearby 

1129 emission sources. Dearborn continues to be influenced by nearby emission sources which drive 

1130 exceedances (or near exceedances) on days when the network-wide base concentration is as 

much as 15 Pg/m3 1131 below the standard, although the frequency of such days appears to be 

1132 decreasing. In contrast, at Wyandotte all of the days for which nearby emission sources were 

1133 disproportionately contributing to exceedances (or near exceedances) of the standard were prior 

1134 to 2004. At those sites not significantly impacted by plumes from nearby emission sources, high 

1135 PM days are most often observed when the area is experiencing a multiday high PM episode. 

1136 

1137 Seasonal variations in surface winds can explain the seasonal differences in frequency of high 

1138 PM days between sites in the Greater Wayne County area. Sites such as Allen Park, which are 

1139 relatively free of impacts from nearby sources, exhibit similar seasonal behavior with high PM 

1140 days most frequent in the summer followed by the winter. The monthly distribution of high PM 

1141 days is distorted for sites with significant nearby emission sources since there is a strong 

1142 seasonality to the surface winds distributions. For example, Dearborn has as many high PM days 

1143 in the winter as in the summer, with the winter season having a stronger contribution from 

1144 nearby sources located to the southwest of the site. 

1145 

1146 Network-wide high PM days have disproportionately high contributions from the major ions 

1147 (sulfate, nitrate, and ammonium) compared to other days. Summertime events are dominated by 

1148 sulfate and wintertime events are dominated by ammonium nitrate. However these so-called 

1149 high nitrate days typically have ammonium sulfate concentrations that are at least 50% of the 

1150 ammonium nitrate concentration. The role of sulfate on such days should not be overlooked 

1151 when considering the impact of SO2-based regional control strategies. In general, network-wide 

PM base concentrations above ~20 Pg/m3 1152 tend to be disproportionately influenced by major ion 

1153 contributions and are indicative of a disproportionately high influence from regional sources. 

1154 On network-wide high PM days the sulfate and nitrate concentrations are typically several times 

1155 higher than the corresponding monthly median concentrations. In contrast, EC is on average 

1156 only 1.3 times higher. This pattern suggests that network-wide high PM days are primarily 

1157 influenced by regional transport and are to a much lesser extent influenced by a increased levels 

1158 of urban-scale emissions arising from poor atmospheric ventilation. As previously stated, 

1159 emission sources near the monitoring sites can still exert significant plume impacts regardless of 

1160 the network-wide PM behavior driven by regional and urban-scale contributions. 

1161 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 47

1162 Many network-wide high PM days coincide with high nitrate, and in some cases there is 

1163 substantial variability in PM mass concentration across the network on these days. It is 

1164 important to determine whether the variability is real or a measurement artifact, because these 

1165 days can influence into the site-specific design values and in general can explain many of the 

1166 exceedingly high PM levels observed at certain sites that otherwise do not appear to be 

1167 disproportionately impacted by nearby local emission source plumes on high PM days. 

1168 

1169 A conceptual model for fine PM over central Southeast Michigan includes four elements. The 

1170 largest contributor to annual average PM is regionally transported material that is temporally 

1171 varying but spatially homogeneous over the domain (indeed, this defines the spatial extent of the 

1172 domain for the conceptual model which in this case excludes the distant sites such as Luna Pier 

1173 and Port Huron). On some days, regionally transported PM contributions can be sufficiently 

1174 high to cause exceedances of the daily standard when coupled with average contributions from 

1175 urban- and finer-scale emission sources and, in relatively rare cases, the regionally transported 

1176 PM alone can cause exceedances of the daily standard. Urban-scale emission sources (mobile, 

1177 area, and point sources) create a spatial PM gradient across central Southeast Michigan. For 

1178 winds from a fixed direction, these contributions create an “urban plume” with decreasing 

1179 impacts with increasing distance from the zone of highest emissions activity. The spatial 

1180 gradients can be clearly discerned when binning data from days with common wind patterns and 

1181 become smeared, to some extent, when averaging over periods with varying wind patterns. At 

1182 many sites (e.g., Linwood, East 7 Mile) a PM plume emanating from the Detroit commercial / 

1183 industrial zone, which is nominally Dearborn and areas to its southeast towards the Detroit River, 

1184 including Zug Island, can be distinguished from the aforementioned urban plume. At sites 

1185 further downwind, such as New Haven, these two plumes have essentially merged into a single 

1186 urban plume. Average impacts from these plumes depend on the monitoring site location 

1187 relative to the Detroit population and commercial/industrial core zones and the frequency that 

1188 winds from these zones transport the plumes to the monitoring site. Finally, certain monitors in 

1189 the Detroit commercial/industrial zone are significantly impacted by emissions from nearby 

1190 sources that ultimately contribute to the distant PM plume emanating from this zone. At 

1191 Dearborn and Wyandotte these sources are located southwest of the monitoring sites and 

1192 historically have contributed to exceedances (or nears exceedances) of the daily standard. These 

1193 sources also disproportionately influence the annual standard because they are oriented upwind 

1194 of the sites for prevailing winds from the southwest. 

1195 

1196 In summary, emission controls that reduce regionally transported PM are needed to reduce the 

1197 frequency of violations of the 24-hour PM2.5 standard. Emission reductions from a few specific 

1198 point sources, especially near Dearborn, are also needed. While regional and point source 

1199 controls will decrease annual average PM2.5 concentrations for standardized synoptic weather 

1200 patterns, relatively small but significant decreases could also be realized by controls on other 

1201 urban emission sources such as mobile, area, and other point sources. 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 48

1202 Policy-Relevant Implications

1203 

The policy-relevant implications are framed using the Weight-of-Evidence (WOE)13 1204 prepared in 

1205 support of the control strategy package for the attaining the PM2.5 annual average standard. The 

1206 WOE elements are in regular typeface with comments, based on this work, added in italics. 

1207 

1208 

1209 I. Inventory 

1210 x I(c)... National stationary source controls, including CAIR and the NOx SIP call, are expected to 

1211 reduce point source NOx emissions by 40% and SO2 emissions by 15% between 2002 and 2009. 

1212 These reductions are very important to the daily standard control strategy because exceedances of 

1213 the daily standard tend to occur on days with network-wide high PM from regional transport of 

1214 species including but likely not limited to ammonium sulfate and ammonium nitrate.

1215 x I(c)... [There] is compelling evidence that areas in Southeast Michigan that are currently attaining the 

1216 [annual] standard will remain in compliance. For the period 2004-2006, only one monitor in 

1217 Southeast Michigan was in compliance with the 24-hour standard. While reductions in local 

1218 emissions should prevent backsliding, daily exceedances are coupled to the frequency and severity of 

1219 regional transport episodes which can vary from year to year. For example, 2005 was severe in 

terms of regional transport and this is reflected in the elevated 98th 1220 percentile concentrations across 

1221 all sites in Southeast Michigan.

1222 x I(d)... While these [programmed] reductions are already having a significant, positive impact in 

1223 Southeast Michigan and will continue to do so in future, we cannot assume that they will result in 

1224 attainment at Dearborn and Southwestern High School (SWHS), the two monitoring sites that are still 

1225 exceeding the annual standard. Additional reductions in the vicinity of these sites are needed. 

1226 Dearborn is currently the design value site for the daily standard. This study has demonstrated that 

1227 contributions from certain local emission source have decreased in recent years. In contrast, the 

1228 magnitude of the urban plume, which includes a broader range of emission sources, has not 

1229 significantly decreased in recent years as evidenced by expected concentration patterns observed at 

1230 sites such as East 7 Mile and Linwood. 

1231 x I(e)... The area surrounding the two non-attaining monitors in Southeast Michigan contains a 

1232 complex array of emission sources. Some of these sources may be significant contributors because 

1233 their emissions occur closer to ground level and/or because of their proximity to a monitor. However, 

1234 many of these are area sources that are exempt from MDEQ’s emissions inventory reporting 

1235 requirements so their exact contribution is unknown. In addition, many of these smaller sources have 

1236 little or no emission controls while larger sources already have controls in place. At these sites and a 

1237 few other sites, the analysis in Section 5 point towards the bearings where efforts should be focused 

1238 to refine emission estimates – in particular, zones southwest of the monitoring sites due to prevailing 

1239 wintertime surface winds lead to lead to higher PM than the rest of the Southeast Michigan network. 

1240 x I(f)... A number of industrial facilities in the area surrounding the Dearborn, Southwestern High 

1241 School, and Wyandotte monitors have either closed or scaled back their operations since 2002. These 

1242 changes are likely contributing to the more rapid decrease in PM2.5 levels observed at industrial 

1243 monitoring sites. While we have indeed identified decreased local emission source contributions at 

1244 some sites. 

1245 x I(g)... In addition to changes that have already taken place, significant local PM2.5 reductions will be 

1246 achieved from controls that are currently being phased in at the Severstal and U.S Steel facilities as 

1247 well as the Marathon oil refinery. All three of these facilities are less than three miles from the 

 

13 “Weight of Evidence for the Southeast Michigan PM2.5 Attainment Strategy”, 8/28/2007 draft, prepared by 

SEMCOG and MDEQ. 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 49

1248 monitors measuring the highest PM2.5 concentrations in the region - Dearborn and Southwestern High 

1249 School. Based on a recent EPA study as well as permit application data, MDEQ estimates these 

1250 controls will provide a combined PM2.5 emission reduction of 330 tons per year. These reductions 

1251 should reduce the frequency of high PM days that occur at these sites when the network-wide 

1252 baseline concentration is relatively low, thereby reducing the frequency of spatially isolate 

1253 exceedances and near exceedances. Conditions on network-wide high PM days will also be 

1254 improved. Note that in these cases the sources are located at bearings where prevailing winds can 

1255 favor plume impacts at the monitoring sites, especially in the wintertime. Impacts can be tracked by 

1256 periodically updating the NWR plots and the evaluating shifts in the distribution of site-specific high 

1257 PM days by month. For example, if local source impacts at Dearborn are indeed reduced, we would 

1258 expect the distribution of high PM days by month for Dearborn to shift to more-closely resembling 

1259 Allen Park. Intersite differences between Allen Park and Dearborn should also decrease for the 

1260 relevant species in the CSN data.

1261 x I(h)... There are a significant number of storage piles, unpaved lots, and parcels of barren land in the 

1262 vicinity of the Dearborn and SWHS monitors. While most emissions from these sources are larger 

1263 than 2.5 microns, their collective impact is cause for concern. As part of a previous particulate SIP, a 

1264 number of facilities in the area do have fugitive dust plans. However, many others do not. The 

1265 contribution of fugitive dust to high PM days was not explicitly examined. 

1266 II. Monitoring: 

1267 x II(a)...PM2.5 in Southeast Michigan is comprised largely of sulfates, nitrates, and organic carbon. At 

1268 the Dearborn monitoring site, there is also a significant “crustal” component, which is largely iron. 

1269 The excess iron at Dearborn is largely related to steelmaking operations and efforts to reduce these 

1270 emissions will reduce the local source impacts on exceedance and near exceedance days at 

1271 Dearborn.

1272 x II(b)... Southeast Michigan’s current nonattainment designation pertains to the annual standard, not 

1273 the daily standard. Developing a control strategy to address an annual standard is complicated 

1274 because sources may be significant contributors on certain days or during certain times of the year but 

1275 not during others. However, recent source apportionment studies show that the source contributions to 

1276 PM2.5 on an annual average basis are similar to those on high PM2.5 concentration days. This suggests 

1277 that a strategy designed to reduce annual average PM2.5 concentrations will also be effective in 

1278 reducing high daily PM2.5 concentrations. Strategies targeting regional sulfate and nitrates will be 

1279 important towards meeting both standards; in the absence of significant sulfate reduction it might be 

1280 very challenging to meet the daily standard, even with aggressive local source controls. SO2

1281 reductions might not be fully realized as PM reductions if ammonium nitrate formation is ammonia 

1282 limited. 

1283 x II(c)... The entire Southeast Michigan area has been designated nonattainment. However, the only 

1284 monitors measuring violations of the standard are located in a small portion of eastern Wayne 

1285 County. For 2004-2006 all Southeast Michigan sites except Ann Arbor violated the daily standard. 

1286 However, based on 2005-2007 data several sites were in compliance. This demonstrates the year-to1287 year variations that can be induced by synoptic weather patterns which in turn include the frequency 

1288 and severity of regional transport events.

1289 x II(f)... Since 2000, PM2.5 concentrations at all sites in the region have steadily declined. The 3-year 

average concentration dropped 1.6 ȝg/m3 1290 between 2002 and 2006.. The largest decreases have 

occurred at the sites with the highest concentrations: Dearborn (2.69 ȝg/m3), SWHS (2.16 ȝg/m3 1291 ), and 

Wyandotte (3.04 ȝg/m3). Dramatic year-to-year swings in the 98th 1292 percentile concentration are 

1293 observed throughout the Southeast Michigan network due to varying impacts from regional transport. 

1294 In this sense the daily stand is more “volatile” and it is harder to discern long term trends.

1295 x II(g)... PM2.5 concentrations at monitoring sites in the industrial core of Southeast Michigan’s 

1296 nonattainment area (Dearborn, SWHS & Wyandotte) have been decreasing faster than other sites. 

1297 This is likely due to changes in emissions in the industrial area. Reduced impacts from local emission 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 50

1298 sources at Dearborn and especially Wyandotte have indeed been demonstrated in this study; average 

1299 reductions are smaller at SWHS and are coupled to a lower frequency of extreme events which might 

1300 have been caused by upsets at industrial facilities. Of course, any future industrial activity expansions 

1301 that increase emissions could at least partially reverse these trends.

1302 x II(k)... At the time Southeast Michigan was designated nonattainment, monitoring data showed the 

1303 Luna Pier monitor in Monroe County was violating the annual standard. This monitor is located in the 

1304 southeastern corner of the county, one mile north of the Ohio border. In its February 2004 PM2.5 

1305 nonattainment designation recommendation to EPA, MDEQ argued strongly that Monroe and Wayne 

1306 counties should be designated as separate nonattainment areas because PM2.5 levels at the Luna Pier 

1307 monitor tracked far more closely with those in Toledo. Many regional events operate on a large 

1308 enough spatial scale to similarly impact Luna Pier and the Wayne County area. Indeed, the behavior 

1309 at these two areas appears coupled on high PM days. That said, Figure 4-3 demonstrates that Luna 

1310 Pier and Port Huron have the greatest dispersion about the network-wide base concentration – 

1311 including many days that are lower than the base concentration – and thus they are not fully coupled. 

1312 x II(l)... MDEQ and SEMCOG also showed that levels at the site had been decreasing in recent years 

1313 and trend data indicated the monitor would likely measure attainment by the end of 2004. This was 

1314 an accurate prediction. Levels at the site have continued to track those in Toledo and monitors in 

1315 both areas have measured attainment of the standard since 2004. In 2005, EPA redesignated the 

1316 Toledo area as attainment. Luna Pier continues to violate the daily standard (2004-2006 data).

1317 x II(m)... In addition, as of 2006, monitors at Allen Park, Linwood and Wyandotte are now measuring 

1318 attainment [of the annual average NAAQS]. Allen Park, Linwood and Wyandotte continue to violate 

1319 the daily standard (2004-2006 data). 

1320 x II(n)... The area where the two remaining violating monitors (Dearborn and SWHS) are located is 

1321 one with a history of particulate matter problems, associated with local industrial sources. [...] the 

1322 areas are nearly identical. The primary source of the former PM10 problem was determined to be a 

1323 few local industrial sources. Emissions from these sources were reduced and the region came into 

1324 compliance in 1996. The overlap of the Total Suspended Particulate (TSP) and PM10 nonattainment 

1325 areas with the PM2.5 nonattainment area, and the successful attainment of those standards after the 

1326 application of local controls, suggests that the most effective attainment strategy is to focus on local 

1327 emission reductions from sources in this area. Reductions in local emissions near Dearborn have 

1328 decreased the frequency of high PM days resulting from local emission sources (Figure 4-5) and the 

1329 programmed emission reductions should further help to lower the local emission source influences. 

1330 Local emissions near SWHS frequently lead to near exceedances when the network-wide PM levels 

1331 are otherwise low but, unlike Dearborn and Wyandotte, the local source contributions appear to be 

1332 just low enough to avoid exceedances on otherwise relatively clean days. 

1333 x II(o)... Various analyses of both local and regional monitoring data all indicate that Southeast 

1334 Michigan’s nonattainment problem is caused by a combination of regional transport and local 

1335 emissions from sources in the vicinity of the violating monitors. This has also been demonstrated for 

1336 the daily standard in this study with local source impacts driving the frequency of exceedances at a 

1337 few sites and regional transport contributing to exceedances at all sites. 

1338 x II(o)(3)... Lake Michigan Air Directors Consortium (LADCO) analysis of rural background 

1339 concentrations versus urban excess in the Midwest shows that the vast majority of PM2.5 measured in 

1340 our region is coming from outside Southeast Michigan. This pattern is certainly the case on network1341 wide high PM days that coincide with the most frequent exceedances of the daily standard. 

1342 x II(o)(6)... A wind rose for the iron component of PM2.5 at Dearborn points directly to the 

1343 southwest. Conversely, the iron wind rose for Allen Park, while measuring much lower levels, 

1344 points to the northeast. The Allen Park monitor is approximately five miles southwest of Dearborn. 

1345 Additional wind direction analysis shows that, when winds are from the southwest average crustal 

concentrations at Dearborn are over 2.5 μg/m3 1346 higher than those at Allen Park and are sometimes as 

much as 6 μg/m3 1347 higher. This clearly indicates a significant local iron source directly between these 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 51

1348 two sites (which are approximately five miles apart) and closer to the Dearborn monitor. The 

1349 importance of local emission sources to the southwest of Dearborn has been demonstrated in this 

1350 study. These sources likely lead to the high frequency of wintertime high PM days at Dearborn 

1351 compared to the Allen Park and the rest of the network since the prevailing surface winds are from 

1352 the southwest during the winter.

1353 x II(p)... The localized nature of Southeast Michigan’s nonattainment problem makes broad-based 

1354 application of control measures throughout the official seven-county nonattainment area an 

1355 ineffective and unproductive strategy for bringing the region into compliance. All available data 

1356 show that targeted local organic carbon emission reductions, coupled with the iron reductions 

1357 resulting from planned steel mill controls, will be the most cost-effective way to bring the region into 

1358 attainment. Similarly, while the relative roles of regional- and urban-scale contributions have not 

1359 been quantified in this study, it has been shown that regionally transported species concentrations 

1360 are enhanced much more than urban-scale tracer species on high PM days. 

1361 x II(y)... The difference in PM2.5 is highest from the southwest and west wind directions when nearby 

1362 monitors are subtracted out of the Dearborn concentration. This would indicate that there is a large 

1363 local source [or sources] between the Dearborn and “background” monitors (Allen Park, Luna Pier & 

1364 Ypsilanti). This was clearly demonstrated in Section 5 of this study. 

1365 

1366 Recommendations for Future Work 

1367 

1368 Projects currently funded by LADCO will likely provide considerable refinements to this 

1369 analysis. For example, sampling for organics speciation and the planned data analysis – 

1370 including source apportionment – should inform the assignment of organic carbon to local and 

1371 regional sources. . MDEQ is deploying semicontinuous monitors for particle speciation and 

1372 high time resolution data can be particularly powerful for identifying source contributions. 

1373 Results from the summer 2007 USEPA/ORD measurement intensive should be particularly 

1374 insightful since PM elements were measured at high time resolution. Outdoor measurement data 

1375 from USEPA’s DEARS project could also be exploited. 

1376 

1377 A background monitoring site would be helpful, but care is needed to ensure it is sufficiently 

1378 coupled to the Detroit area in terms of air mass behavior. The site needs to be far enough away 

1379 to not be influenced by the urban area, but close enough to still be similarly impacted by regional 

1380 transport. This is even more critical if measurements will be conducted for 24-hour periods once 

1381 every few days as the “snapshots” at each monitor must be synchronized across the domain. For 

1382 example, the background site effectively used for St. Louis is about 100 km to the south which 

1383 places it upwind of the city for the prevailing surface winds. Perhaps more importantly, 

1384 however, the line connecting this site to the urban area is nearly perpendicular the direction of 

1385 summertime synoptic air mass flows which lead to high PM in St. Louis (St. Louis is often on 

1386 the backside of a high pressure system located over the Great Lakes, which lead to regional 

1387 transport from the east/southeast). This orientation might actually be preferred as an upwind site 

1388 – from the surface winds perspective – because the sites will be impacted at the same time for 

1389 regional air masses with spatial extents greater than the site separation. 

1390 

1391 A better understanding of the drivers for high spatial variability in FRM mass on high nitrate 

1392 days is needed since only a few such events can dramatically affect the site-specific design 

1393 values for the 24-hour standard. When such patterns are observed, perhaps the Teflon filters 

1394 could be analyzed for nitrate by IC to determine the extent of nitrate retention; this would be 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 52

1395 particularly insightful for days coinciding with speciation sampler operation to place the Teflon 

1396 filter nitrate levels in context of the ambient concentrations. 

1397 It might be possible to better characterize the spatial pattern of urban-scale emission source 

1398 contributions by performing reflectrometry measurements on archived PM2.5 FRM samples. The 

1399 parameter from these measurements is typically highly correlated with thermo-optical EC. Thus, 

1400 it provides an inexpensive approach to characterizing EC spatial profiles which might be a 

1401 reasonable surrogate for urban-scale emission sources. 

1402 

1403 FIA/Lafayette and Newberry sites were excluded from this analysis because they commenced 

1404 operation relatively recently. The analysis used concentration percentiles across the network to 

1405 define network-wide behavior and thus it was necessary to use a temporally consistent subset of 

1406 the network. The base concentrations generated from this work could be applied to the 

1407 FIA/Lafayette and Newberry data to split observed concentrations into base and excess mass 

1408 components, and then nonparametric wind regression (NWR) could be used to determine 

1409 expected excess mass concentrations as a function of wind direction. This work, which is 

1410 relatively modest in level of effort, could significantly contribute to our understanding of PM 

1411 behavior in the Detroit commercial/industrial core. 

1412 

1413 Relatively little attention has been given to the behavior at Luna Pier and Port Huron on high 

1414 concentration days. The analysis approach taken in this report has limitations when applied to 

1415 sites at such large distances from the Greater Wayne County area. Locally-collected surface 

1416 winds should be used to examine behavior at these sites. Luna Pier and Port Huron must also be 

1417 considered within the context of emissions from Toledo and Sarnia, respectively. 

1418 

1419 NWR results are presented in Section 5 in terms of the expected concentration of excess mass 

1420 observed at a site when the winds are from a given direction. This has proven to be insightful 

1421 because the results do not depend on the frequency distribution of wind directions which can 

1422 vary from year-to-year and confound the identification of temporal changes in emissions. From 

1423 this analysis we can state that emissions from a certain wind sector have been modulated by a 

1424 certain amount over time. However, we are also interested in an apportionment of the 

1425 contributions of such emission sources to the PM burden at the monitoring site. This would 

1426 require weighting the expected concentrations by the frequency of winds from each direction 

1427 sector. We have developed a conceptual model based on the network behavior for various 

1428 surface wind patterns. The next step is to incorporate the observed distribution of wind patterns 

1429 to quantify how the observed PM levels are being modulated. We have shown that a PM plume 

1430 from the Detroit commercial/industrial core impacts Linwood. By incorporating the observed 

1431 distribution of surface wind directions we could quantify the annual-average PM mass from this 

1432 plume impacting the site. This analysis would extend the focus of this report on high PM days to 

1433 more robustly characterize annual average behavior and could be instrumental in providing a 

1434 framework for assessing the effectiveness of emission control programs. 

1435 

1436 

1437 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 53

1438 7. REFERENCES 

1439 

1440 Allen, D.T.; Turner, J.R. (2008) “Transport of Atmospheric Fine Particulate Matter: Part 1. 

1441 Findings from Recent Field Programs on the Extent of Regional Transport within North 

1442 America”, J. Air Waste Manage. Assoc., 58, 254-264. 

1443 Pinto, J.P.; Lefohn, A.S.; Shadwick, D.S. (2004) “Spatial variability of PM2.5 in urban areas in 

1444 the United States”, J. Air Waste Manage. Assoc., 54, 440-449. 

1445 Turner, J.R.; Allen, D.T.; (2008) “Transport of Atmospheric Fine Particulate Matter: Part 2. 

1446 Findings from Recent Field Programs on the Intraurban Variability in Fine Particulate Matter”, 

1447 J. Air Waste Manage. Assoc., 58, 196-215. 

1448 Turner, J.R.; Garlock, J.L. (2007) “A conceptual model for ambient fine particulate matter over 

1449 the St. Louis area”, Revision 3.0 (10/10/2007), prepared by the Air Quality Laboratory at 

1450 Washington University in St. Louis, submitted to the Missouri Department of Natural Resources. 

1451 Vickery, J.S. (2004) “Conceptual Models of PM for North American Regions”, Chapter 10 in 

1452 Particulate Matter Science for Policy Makers: A NARSTO Assessment, P.H. McMurry, M.F. 

1453 Shepherd, J.S. Vickery, eds., Cambridge University Press. 

1454 Wade, K.S.; Turner, J.R.; Brown, S.G; Garlock, J.L., Hafner, H.R. (2008) “Data analysis and 

1455 source apportionment of PM2.5 in selected Midwestern cities”, Report # STI-907018.03-3264-FR 

1456 (February 2008), prepared by Sonoma Technology, Inc. (Petaluma, CA), submitted to the Lake 

1457 Michigan Air Directors Consortium (LADCO). 

1458 

1459 ACKNOWLEDGEMENTS 

1460 The analysis summarized in this report benefited from constructive input provided by members 

1461 of the Southeast Michigan Ozone Study (SEMOS) group and project management provided by 

1462 Ms. Joan Weidner and Mr. Chuck Hersey (SEMCOG). Technical assistance provided by 

1463 Michigan DEQ staff (especially Mary Ann Heindorf, Cindy Hodges and Amy Robinson) and 

1464 Ms. Ann Burns (SEMCOG) is also gratefully acknowledged. 

1465 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 54

1466 APPENDIX A: PM2.5 HIGH CONCENTRATION DAYS BY MONTH 

1467 Allen Park

Month

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

fraction of days greater than threshold 0.00

0.05

0.10

0.15

0.20

East 7 Mile

Month

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

fraction of days greater than threshold 0.00

0.05

0.10

0.15

0.20

Dearborn

Month

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

fraction of days greater than threshold 0.00

0.05

0.10

0.15

0.20

Luna Pier

Month

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

fraction of days greater than threshold 0.00

0.05

0.10

0.15

0.20

New Haven

Month

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

fraction of days greater than threshold 0.00

0.05

0.10

0.15

0.20

Oak Park

Month

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

fraction of days greater than threshold 0.00

0.05

0.10

0.15

0.20

1468 

Wyandotte

Month

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

fraction of days greater than threshold 0.00

0.05

0.10

0.15

0.20

Ypsilanti

Month

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

fraction of days greater than threshold 0.00

0.05

0.10

0.15

0.20

Livonia

Month

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

fraction of days greater than threshold 0.00

0.05

0.10

0.15

0.20

Southwest High Sch.

Month

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

fraction of days greater than threshold 0.00

0.05

0.10

0.15

0.20

Linwood

Month

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

fraction of days greater than threshold 0.00

0.05

0.10

0.15

0.20

Port Huron

Month

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

fraction of days greater than threshold 0.00

0.05

0.10

0.15

0.20

1469 

1470 Figure A-1. Distribution of PM2.5 high concentration days by month, 1999-2006. Ann Arbor, 

1471 FIA/Lafayette, and Newberry are excluded because FRM data was not collected at these sites over the 

1472 entire time period.
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 55

1473 APPENDIX B: HOURLY WIND ROSES 

1474 

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

Dec98-Feb99 

Winter Spring Summer Fall 

Mar99-May99 Jun99-Aug99 Sep99-Nov99 

Dec99-Feb00 Mar00-May00 Jun00-Aug00 Sep00-Nov00 

2011% 14% 13% 

7% 10% 11% 10% 

1475 

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

Dec00-Feb01 

Winter Spring Summer Fall 

Mar01-May01 Jun01-Aug01 Sep01-Nov01 

Dec01-Feb02 Mar02-May02 Jun02-Aug02 Sep02-Nov02 

4% 9% 13% 9% 

4% 7% 15% 11% 

1476 1477 Figure B-1. Seasonal wind roses for non-calm hours, observations at Detroit Metropolitan Wayne 

1478 County Airport (DTW). Calms (wind speeds less than 2 mph) are listed to the lower-left of each wind 

1479 rose. 

>2 - 4

>4 - 8

>8 - 16

>16

WS (mph)
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 56

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

Dec02-Feb03 

Winter Spring Summer Fall 

Mar03-May03 Jun03-Aug03 Sep03-Nov03 

Dec03-Feb04 Mar04-May04 Jun04-Aug04 Sep04-Nov04 

6% 11% 17% 11% 

7% 7% 9% 16% 

1480 

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

Dec04-Feb05 

Winter Spring Summer Fall 

Mar05-May05 Jun05-Aug05 Sep05-Nov05 

Dec05-Feb06 Mar06-May06 Jun06-Aug06 Sep06-Nov06 

7% 11% 14% 12% 

6% 12% 14% 12% 

1481 

1482 Figure B-1 (continued). Seasonal wind roses for non-calm hours, observations at Detroit Metropolitan 

1483 Wayne County Airport (DTW). Calms (wind speeds less than 2 mph) are listed to the lower-left of each 

1484 wind rose. 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 57

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

1999 

11% 

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

2000

9% 

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

2001

9% 

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

2002 

10% 

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

1999 

19% 

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

2000

9% 

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

2001

9% 

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

2002 

10% 

All Days Valid Network Days

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

2003 

11% 

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

2004 

10% 

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

2005 

11% 

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

2006

11% 

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

2003 

11% 

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

2004 

10%

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

2005 

11% 

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

2006

11% 

All Days Valid Network Days

1485 

 

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

2007 

13% 

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

N

0% 5% 10% 15%

2007 

13% 

1486 

1487 

1488 

1489 Figure B-2. Annual wind roses for non-calm hours, observations at Detroit Metropolitan Wayne County 

1490 Airport (DTW) for all days and valid network days. Calms (wind speeds less than 2 mph) are listed to the 

1491 lower-left of each wind rose. 

>2 - 4

>4 - 8

>8 - 16

>16

WS (mph)
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 58

1492 APPENDIX C: SITE-SPECIFIC HIGH PM DAYS NOT OBSERVED THROUGHOUT 

1493 THE NETWORK, 1999-2006 

1494 

Dearborn E 7 Mile Linwood Livonia Luna Pier Oak Park Port Huron SWHS Wyandotte

07/05/1999 (2) 05/12/2000 (1) 11/18/1999 (2) 12/17/2000 (1,2) 05/10/2001 (1,2) 11/25/2006 (1) 05/07/2005 (1,2) 09/27/1999 (2) 07/05/1999 (2)

01/01/2000 (2) 04/18/2004 (1,2) 12/08/1999 (2) 03/12/2002 (2) 07/18/2005 (1,2) 07/17/2000 (1,2) 05/06/2000 (1)

01/31/2000 (2) 01/28/2005 (1,2) 01/02/2000 (2) 04/02/2002 (1,2) 02/09/2001 (1,2) 05/12/2000 (1)

02/24/2000 (1,2) 05/07/2005 (1,2) 02/24/2000 (1,2) 11/02/2003 (1) 05/10/2001 (1,2) 12/26/2000 (1,2)

03/07/2000 (1,2) 08/23/2001 (1) 01/10/2001 (1,2)

05/06/2000 (1,2) 02/14/2003 (1) 01/28/2001 (1)

05/12/2000 (1) 08/25/2003 (1) 07/09/2001 (1)

06/08/2000 (1,2) 11/02/2003 (1) 08/23/2001 (1)

09/09/2000 (1) 12/29/2003 (1,2) 11/28/2002 (1,2)

12/23/2000 (1,2) 03/25/2004 (1,2) 03/19/2003 (1,2)

01/10/2001 (1,2) 04/30/2004 (1) 08/25/2003 (1)

01/28/2001 (1) 02/16/2006 (1) 02/06/2004 (1)

03/02/2001 (1,2) 12/13/2006 (1) 07/18/2005 (1)

08/23/2001 (1) 12/06/2005 (1,2)

12/27/2001 (1,2) 12/21/2005 (1,2)

01/05/2002 (2) 02/10/2006 (1)

01/08/2002 (1,2)

02/07/2002 (1,2)

03/06/2002 (1)

11/13/2002 (1,2)

11/28/2002 (1,2)

01/18/2003 (1,2)

02/08/2003 (1,2)

02/14/2003 (1)

02/20/2003 (1,2)

04/15/2003 (1,2)

11/11/2003 (1,2)

03/25/2004 (1,2)

04/30/2004 (1)

10/15/2004 (1)

12/02/2004 (1,2)

03/29/2005 (1,2)

04/19/2005 (1,2)

07/18/2005 (1,2)

10/31/2005 (1,2)

12/06/2005 (1,2)

02/16/2006 (1)

09/08/2006 (1,2)

1495 12/13/2006 (1,2)

1496 * Ann Arbor, FIA/Lafayette and Newberry excluded from the analysis. 

1497 * No high PM days meeting these criteria for New Haven and Ypsilanti. 

(1) denotes site concentration >30 Pg/m3 while Allen Park <25 Pg/m3 1498 . 

(2) denotes site concentration >30 Pg/m3 while network-wide base <25 Pg/m3 1499 (limited to those days which are valid 

1500 network days) (red bars in Figure 4-9). 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 59

APPENDIX D: CPF AND NWR PLOTS14 1501 

1502 PM2.5 mass concentrations (both absolute and excess with respect to a reference site) were 

1503 examined using Conditional Probability Function (CPF) plots and 1-D Nonparametric Wind 

1504 Regression (NWR) plots. Kim and Hopke (2004) compared and contrasted the CPF and NWR 

1505 methodologies and demonstrated that they provide complementary and largely consistent 

1506 information. CPF plots provide insights into the bearing of emission sources impacting the 

1507 monitoring site from a perspective that is not biased by the prevailing wind patterns. The plots 

1508 address the question: “for the ensemble of hourly winds from a given direction, what fraction of 

1509 these hours corresponds to high concentration days?”. The threshold for defining a “high 

concentration day” is typically chosen as the top 25th 1510 percentile of the concentration distribution 

1511 (either absolute concentrations or mass fractions). For example, Figure D-1(a) shows the CPF 

1512 plot for the PMF-resolved copper factor at the Springfield site in Chicago. Nearly 70% of the 

1513 hours with winds from 180qN coincided with a daily contribution in the top quartile of the 

1514 concentration distribution for the copper factor contributions. This pattern suggests a copper 

1515 source south of the monitoring site but it does not address the magnitude of the impacts which 

1516 depend on source strength, dispersion characteristics and the frequency of winds from this 

1517 direction. 

1518 One dimensional nonparametric wind regression estimates the expected value of concentration as 

1519 a function of wind direction (Kim and Hopke, 2004). It is similar to a pollution rose but with 

1520 more robust mathematical support. NWR results can be multiplied by the wind direction 

1521 frequency distribution to determine the contribution of each wind direction to average PM mass. 

1522 Figure D-1(b) shows the NWR plot for the PMF-resolved copper factor at the Springfield site in 

1523 Chicago. Factor contributions (red line) for winds from 180qN are three times greater than the 

1524 study-average factor contribution (pink circle). In aggregate the CPF and NWR plots provide 

1525 insights into both the location of emission sources and their impacts. 

1526 0

45

90

135

180

225

270

315

15

30

60

75

105

120

150

195 165

210

240

255

285

300

330

345

0 0.2 0.4 0.6 0.8 0.0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8

9

60

30

0

330

300

270

240

210

180

150

120

(a) (b)

1527 

1528 Figure D-1. Surface wind analyses for the PMF-resolved copper factor at the Springfield site in Chicago: 

1529 (a) conditional probability function plot for the top quartile of absolute contributions; and (b) 1-D 

nonparametric wind regression plot (radial units in Pg/m3 1530 ) where the red line denotes the observed 

1531 contributions from each bearing and the pink circle denotes the study-average contribution. 

 

14 Adapted from Wade et al. (2008). 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 60

1532 APPENDIX E: 1-D NWR ON PM2.5 EXCESS MASS

-1.0

-0.5

0.0

0.5

1.0

1.5

2.0

2.5

3.0

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, ug/m3

Allen Park, 2000-2003

Allen Park, 2004-2006

[2004-2006] minus [2000-2003]

-1.0

-0.5

0.0

0.5

1.0

1.5

2.0

2.5

3.0

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, ug/m3

Allen Park, 2000-2003

Allen Park, 2004-2006

[2004-2006] minus [2000-2003]

-2

0

2

4

6

8

10

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, Pg/m3

Dearborn, 2000-2003

Dearborn, 2004-2006

[2004-2006] minus [2000-2003]

-2

0

2

4

6

8

10

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, Pg/m3

Dearborn, 2000-2003

Dearborn, 2004-2006

[2004-2006] minus [2000-2003]

-2.0

-1.5

-1.0

-0.5

0.0

0.5

1.0

1.5

2.0

2.5

3.0

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR source apportionment on excess mass, ug/m3

E. 7 Mile, 2000-2003

E. 7 Mile, 2004-2006

[2004-2006] minus [2000-2003]

-2.0

-1.5

-1.0

-0.5

0.0

0.5

1.0

1.5

2.0

2.5

3.0

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR source apportionment on excess mass, ug/m3

E. 7 Mile, 2000-2003

E. 7 Mile, 2004-2006

[2004-2006] minus [2000-2003]

-2.0

-1.5

-1.0

-0.5

0.0

0.5

1.0

1.5

2.0

2.5

3.0

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, ug/m3

Linwood, 2000-2003

Linwood, 2004-2006

[2004-2006] minus [2000-2003]

ALL DATA CENSORED DATA

-2.0

-1.5

-1.0

-0.5

0.0

0.5

1.0

1.5

2.0

2.5

3.0

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, ug/m3

Linwood, 2000-2003

Linwood, 2004-2006

[2004-2006] minus [2000-2003]

1533 

1534 Figure E-1 (continued). 1-D NWR results for PM2.5 excess mass relative to the network-wide base for 

1535 all network days (left column) and censored to remove extreme values as defined in footnote #12 (right 

1536 column). The blue line is the change between 2004-2006 and 2000-2003 and the error bands are 95% 

1537 confidence intervals. 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 61

ALL DATA CENSORED DATA

-1.5

-1.0

-0.5

0.0

0.5

1.0

1.5

2.0

2.5

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, ug/m3

Livonia, 2000-2003

Livonia, 2004-2006

[2004-2006] minus [2000-2003]

-1.5

-1.0

-0.5

0.0

0.5

1.0

1.5

2.0

2.5

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, ug/m3

Livonia, 2000-2003

Livonia, 2004-2006

[2004-2006] minus [2000-2003]

-1.5

-1.0

-0.5

0.0

0.5

1.0

1.5

2.0

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, ug/m3

Luna Pier, 2000-2003

Luna Pier, 2004-2006

[2004-2006] minus [2000-2003]

-1.5

-1.0

-0.5

0.0

0.5

1.0

1.5

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, ug/m3

Luna Pier, 2000-2003

Luna Pier, 2004-2006

[2004-2006] minus [2000-2003]

-3.5

-3.0

-2.5

-2.0

-1.5

-1.0

-0.5

0.0

0.5

1.0

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, ug/m3

New Haven, 2000-2003

New Haven, 2004-2006

[2004-2006] minus [2000-2003]

-3.50

-3.00

-2.50

-2.00

-1.50

-1.00

-0.50

0.00

0.50

1.00

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, ug/m3

New Haven, 2000-2003

New Haven, 2004-2006

[2004-2006] minus [2000-2003]

-1.5

-1.0

-0.5

0.0

0.5

1.0

1.5

2.0

2.5

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, ug/m3

Oak Park, 2000-2003

Oak Park, 2004-2006

[2004-2006] minus [2000-2003]

-1.5

-1.0

-0.5

0.0

0.5

1.0

1.5

2.0

2.5

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, ug/m3

Oak Park, 2000-2003

Oak Park, 2004-2006

[2004-2006] minus [2000-2003]

1538 

1539 Figure E-1 (continued). 1-D NWR results for PM2.5 excess mass relative to the network-wide base for 

1540 all network days (left column) and censored to remove extreme values as defined in footnote #12 (right 

1541 column). The blue line is the change between 2004-2006 and 2000-2003 and the error bands are 95% 

1542 confidence intervals. 
PM2.5 High Concentration Days over Southeast Michigan 

Washington University in St. Louis April 23, 2008 62

ALL DATA CENSORED DATA

-3.0

-2.5

-2.0

-1.5

-1.0

-0.5

0.0

0.5

1.0

1.5

2.0

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, ug/m3

Port Huron, 2000-2003

Port Huron, 2004-2006

[2004-2006] minus [2000-2003]

-3.0

-2.5

-2.0

-1.5

-1.0

-0.5

0.0

0.5

1.0

1.5

2.0

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, ug/m3

Port Huron, 2000-2003

Port Huron, 2004-2006

[2004-2006] minus [2000-2003]

-1

0

1

2

3

4

5

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, Pg/m3

SW High Sch., 2000-2003

SW High Sch., 2004-2006

[2004-2006] minus [2000-2003]

-1

0

1

2

3

4

5

000 045 090 135 180 225 270 315 360

wind direction, o

N

1-D NWR excess mass expected concentration, ug/m3

SW High Sch., 2000-2003

SW High Sch., 2004-2006

[2004-2006] minus [2000-2003]

-1

0

1

2

3

4

5

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, Pg/m3

Wyandotte, 2000-2003

Wyandotte, 2004-2006

[2004-2006] minus [2000-2003]

-2.0

-1.5

-1.0

-0.5

0.0

0.5

1.0

1.5

2.0

2.5

3.0

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, ug/m3

Ypsilanti, 2000-2003

Ypsilanti, 2004-2006

[2004-2006] minus [2000-2003]

-1

0

1

2

3

4

5

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, Pg/m3

Wyandotte, 2000-2003

Wyandotte, 2004-2006

[2004-2006] minus [2000-2003]

-2.0

-1.5

-1.0

-0.5

0.0

0.5

1.0

1.5

2.0

2.5

3.0

000 030 060 090 120 150 180 210 240 270 300 330 360

wind direction, o

N

1-D NWR excess mass expected concentration, ug/m3

Ypsilanti, 2000-2003

Ypsilanti, 2004-2006

[2004-2006] minus [2000-2003]

1543 

1544 Figure E-1 (continued). 1-D NWR results for PM2.5 excess mass relative to the network-wide base for 

1545 all network days (left column) and censored to remove extreme values as defined in footnote #12 (right 

1546 column). The blue line is the change between 2004-2006 and 2000-2003 and the error bands are 95% 

1547 confidence intervals. 
 

MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY 

AIR QUALITY DIVISION 

April 19, 2007 

PERMIT TO INSTALL 

182-05B 

ISSUED TO 

SEVERSTAL NORTH AMERICA, INC 

LOCATED AT 

3001 Miller Road 

Dearborn, Michigan 

IN THE COUNTY OF 

Wayne 

STATE REGISTRATION NUMBER 

A8640 

The Air Quality Division has approved this Permit to Install, pursuant to the delegation of authority 

from the Michigan Department of Environmental Quality. This permit is hereby issued in 

accordance with and subject to Section 5505(1) of Article II, Chapter I, Part 55, Air Pollution 

Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. 

Pursuant to Air Pollution Control Rule 336.1201(1), this permit constitutes the permittee’s 

authority to install the identified emission unit(s) in accordance with all administrative rules of the 

Department and the attached conditions. Operation of the emission unit(s) identified in this Permit 

to Install is allowed pursuant to Rule 336.1201(6). 

 DATE OF RECEIPT OF ALL INFORMATION REQUIRED BY RULE 203: 

January 11, 2007 

 DATE PERMIT TO INSTALL APPROVED: 

April 19, 2007 

SIGNATURE: 

G. Vinson Hellwig 

 DATE PERMIT VOIDED: SIGNATURE: 

 DATE PERMIT REVOKED: SIGNATURE: 

 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 1 of 83 

 

PERMIT TO INSTALL 

Table of Contents 

Section Page 

Alphabetical Listing of Common Abbreviations / Acronyms ................................................................................ 2

General Conditions ................................................................................................................................................. 3

Special Conditions .................................................................................................................................................. 5

Emission Unit Identification ................................................................................................................................... 5

Flexible Group Identification.................................................................................................................................. 6

TABLE E-01.01 COAL HANDLING EQUIPMENT............................................................................................ 7

TABLE E-01.02 B BLAST FURNACE CAST HOUSE OPERATIONS........................................................... 10

TABLE E-01.03 B BLAST FURNACE STOVE ................................................................................................ 17

TABLE E-01.04 C BLAST FURNACE CAST HOUSE OPERATIONS........................................................... 19

TABLE E-01.05 C BLAST FURNACE STOVE ................................................................................................ 28

TABLE E-01.06 RELADLING - BOF ................................................................................................................ 31

TABLE E-01.07 DESULFURIZATION OPERATION...................................................................................... 36

TABLE E-01.08 BASIC OXYGEN FURNACE................................................................................................. 42

TABLE E-01.09 BOF DESUFURIZATION BY-PRODUCTS ‘DESULF’ PROCESS ..................................... 49

TABLE E-01.10 LADLE REFINING FACILITY No. 1 .................................................................................... 51

TABLE E-01.11 LADLE REFINING FACILITY No. 2 .................................................................................... 55

TABLE E-01.12 ANNEALING FURNACES..................................................................................................... 60

TABLE F-01.01 B & C BLAST FURNACE CAST HOUSE OPERATIONS ................................................... 62

TABLE F-01.02 B AND C BLAST FURNACE STOVES................................................................................. 64

TABLE F-01.03 BASIC OXYGEN FURNACE (BOF)/RELADLING SOUTH & NORTH BOF.................... 66

TABLE F-01.04 SLAB REHEAT FURNACES 1, 2, & 3 AT HOT STRIP MILL BUILDING........................ 73

TABLE F-01.05 FGFACILITY........................................................................................................................... 75

Appendix 1.3.1 Monitoring Continuous Emission Monitoring System (CEMS) Requirements......................... 76

Appendix 1.3.2 Continuous Opacity Monitoring System (COMS) Requirements.............................................. 77

Appendix 1.7. Emission Calculations.................................................................................................................. 79
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 2 of 83 

 

Common Abbreviations / Acronyms 

Common Acronyms Pollutant/Measurement Abbreviations 

AQD Air Quality Division Btu British Thermal Unit 

ANSI American National Standards Institute °C Degrees Celsius 

BACT Best Available Control Technology CO Carbon Monoxide 

CAA Clean Air Act dscf Dry standard cubic foot 

CEM Continuous Emission Monitoring dscm Dry standard cubic meter 

CFR Code of Federal Regulations °F Degrees Fahrenheit 

COM Continuous Opacity Monitoring gr Grains 

EPA Environmental Protection Agency Hg Mercury 

EU Emission Unit hr Hour 

FG Flexible Group H2S Hydrogen Sulfide 

GACS Gallon of Applied Coating Solids hp Horsepower 

GC General Condition lb Pound 

HAP Hazardous Air Pollutant m Meter 

HVLP High Volume Low Pressure * mg Milligram 

ID Identification mm Millimeter 

LAER Lowest Achievable Emission Rate MM Million 

MACT Maximum Achievable Control Technology MW Megawatts 

MAERS Michigan Air Emissions Reporting System NOx Oxides of Nitrogen 

MAP Malfunction Abatement Plan PM Particulate Matter 

MDEQ Michigan Department of Environmental Quality PM-10 Particulate Matter less than 10 microns diameter 

MIOSHA Michigan Occupational Safety & Health 

Administration 

pph Pound per hour 

MSDS Material Safety Data Sheet ppm Parts per million 

NESHAP National Emission Standard for Hazardous Air 

Pollutants 

ppmv Parts per million by volume 

NSPS New Source Performance Standards ppmw Parts per million by weight 

NSR New Source Review psia Pounds per square inch absolute 

PS Performance Specification psig Pounds per square inch gauge 

PSD Prevention of Significant Deterioration scf Standard cubic feet 

PTE Permanent Total Enclosure sec Seconds 

PTI Permit to Install SO2 Sulfur Dioxide 

RACT Reasonable Available Control Technology THC Total Hydrocarbons 

ROP Renewable Operating Permit tpy Tons per year 

SC Special Condition Number μg Microgram 

SCR Selective Catalytic Reduction VOC Volatile Organic Compounds 

SRN State Registration Number yr Year 

TAC Toxic Air Contaminant Hg Mercury 

VE Visible Emissions Mn Manganese 

Cr Chromium Pb Lead 

 

* For High Volume Low Pressure (HVLP) applicators, the pressure measured at the HVLP gun air cap shall not exceed ten 

(10) pounds per square inch gauge (psig). 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 3 of 83 

GENERAL CONDITIONS 

1. The process or process equipment covered by this permit shall not be reconstructed, relocated, or 

modified, unless a Permit to Install authorizing such action is issued by the Department, except to the 

extent such action is exempt from the Permit to Install requirements by any applicable rule. 

[R336.1201(1)] 

2. If the installation, construction, reconstruction, relocation, or modification of the equipment for which 

this permit has been approved has not commenced within 18 months, or has been interrupted for 18 

months, this permit shall become void unless otherwise authorized by the Department. Furthermore, the 

permittee or the designated authorized agent shall notify the Department via the Supervisor, Permit 

Section, Air Quality Division, Michigan Department of Environmental Quality, P.O. Box 30260, 

Lansing, Michigan 48909, if it is decided not to pursue the installation, construction, reconstruction, 

relocation, or modification of the equipment allowed by this Permit to Install. [R336.1201(4)] 

3. If this Permit to Install is issued for a process or process equipment located at a stationary source that is 

not subject to the Renewable Operating Permit program requirements pursuant to R336.1210, operation 

of the process or process equipment is allowed by this permit if the equipment performs in accordance 

with the terms and conditions of this Permit to Install. [R336.1201(6)(b)] 

4. The Department may, after notice and opportunity for a hearing, revoke this Permit to Install if evidence 

indicates the process or process equipment is not performing in accordance with the terms and 

conditions of this permit or is violating the Department’s rules or the Clean Air Act. [R336.1201(8), 

Section 5510 of Act 451, PA 1994] 

5. The terms and conditions of this Permit to Install shall apply to any person or legal entity that now or 

hereafter owns or operates the process or process equipment at the location authorized by this Permit to 

Install. If the new owner or operator submits a written request to the Department pursuant to R336.1219 

and the Department approves the request, this permit will be amended to reflect the change of 

ownership or operational control. The request must include all of the information required by subrules 

(1)(a), (b), and (c) of R336.1219. The written request shall be sent to the District Supervisor, Air 

Quality Division, Michigan Department of Environmental Quality. [R336.1219] 

6. Operation of this equipment shall not result in the emission of an air contaminant which causes injurious 

effects to human health or safety, animal life, plant life of significant economic value, or property, or 

which causes unreasonable interference with the comfortable enjoyment of life and property. 

[R336.1901] 

7. The permittee shall provide notice of an abnormal condition, start-up, shutdown, or malfunction that 

results in emissions of a hazardous or toxic air pollutant which continue for more than one hour in 

excess of any applicable standard or limitation, or emissions of any air contaminant continuing for more 

than two hours in excess of an applicable standard or limitation, as required in Rule 912, to the 

Department. The notice shall be provided not later than two business days after start-up, shutdown, or 

discovery of the abnormal condition or malfunction. Written reports, if required, must be filed with the 

Department within 10 days after the start-up or shutdown occurred, within 10 days after the abnormal 

conditions or malfunction has been corrected, or within 30 days of discovery of the abnormal condition 

or malfunction, whichever is first. The written reports shall include all of the information required in 

Rule 912(5). [R336.1912] 

8. Approval of this permit does not exempt the permittee from complying with any future applicable 

requirements which may be promulgated under Part 55 of 1994 PA 451, as amended or the Federal 

Clean Air Act. 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 4 of 83 

9. Approval of this permit does not obviate the necessity of obtaining such permits or approvals from other 

units of government as required by law. 

10. Operation of this equipment may be subject to other requirements of Part 55 of 1994 PA 451, as 

amended and the rules promulgated thereunder. 

11. Except as provided in subrules (2) and (3) or unless the special conditions of the Permit to Install 

include an alternate opacity limit established pursuant to subrule (4) of R336.1301, the permittee shall 

not cause or permit to be discharged into the outer air from a process or process equipment a visible 

emission of density greater than the most stringent of the following. The grading of visible emissions 

shall be determined in accordance with R336.1303. [R336.1301] 

a) A six-minute average of 20 percent opacity, except for one six-minute average per hour of not 

more than 27 percent opacity. 

b) A visible emission limit specified by an applicable federal new source performance standard. 

c) A visible emission limit specified as a condition of this permit to install. 

12. Collected air contaminants shall be removed as necessary to maintain the equipment at the required 

operating efficiency. The collection and disposal of air contaminants shall be performed in a manner so 

as to minimize the introduction of contaminants to the outer air. Transport of collected air contaminants 

in Priority I and II areas requires the use of material handling methods specified in R336.1370(2). 

[R336.1370] 

13. The Department may require the permittee to conduct acceptable performance tests, at the permittee’s 

expense, in accordance with R336.2001 and R336.2003, under any of the conditions listed in 

R336.2001. [R336.2001] 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 5 of 83 

SPECIAL CONDITIONS 

Emission Unit Identification

Unit/Group ID Emission 

Unit/Process 

Group 

Description 

Installation/ 

Modification 

Date 

Control Device 

Description 

Stack/ Vent ID Requirement 

Table No. 

EUCOALHANDLING Raw coal silo, 

pulverized coal 

silo, rail car 

unloading 

shed, coal 

pulverizer, & 

two 25 

MMBtu/hr 

natural gasfired heaters 

 4 Baghouses NA E-01.01 

EUBBFCASTHOUSE B Blast furnace 

cast house 

operations 

1/1/1922 Baghouse ROOF 

MONITORS, 

SVBFCE 

E-01.02 

F-01.01 

EUBFCESTOVE Blast Furnace 

B stove 

1/1/1922 Low-NOx 

technology 

SVBFCESTOVE E-01.03 

F-01.02 

EUCBFCASTHOUSE C Blast furnace 

cast house 

operations 

1/1/48 Baghouse ROOF 

MONITORS, 

SVCFCE 

E-01.04 

F-01.01 

EUCFCESTOVE Blast Furnace 

C stove 

1/1/48 Low-NOx 

technology 

SVCFCESTOVE E-01.05 

F-01.02 

EURELADLINGBOF Reladling 

south and north 

- BOF 

1/1/75 Baghouse SVRELADLEBA

G, 

SVBOFBH 

E-01.06 

F-01.03 

EUDESULFURIZATION Desulfurization 

operation 

1/1/81 Baghouse SVDESULF E-01.07 

EUBOF Basic oxygen 

furnace (BOF), 

2 vessels 

1/1/64 Electrostatic 

precipitator, 

baghouse 

SVBOFESP, 

SVBOFBH 

E-01.08 

F-01.03 

EUDESULFWATERINGS

TATION 

BOF 

desulfurization 

by-product 

material 

“desulf” 

watering 

station located 

at the south 

end of the BOF 

building. Levy 

digs the desulf 

materials with 

a front-end 

loader, brings 

them to an 

open area for 

4/17/95 NA NA E-01.09 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 6 of 83 

Unit/Group ID Emission 

Unit/Process 

Group 

Description 

Installation/ 

Modification 

Date 

Control Device 

Description 

Stack/ Vent ID Requirement 

Table No. 

cooling using 

water spray 

and for fugitive 

dust control. 

After thorough 

cooling, Levy 

loads the 

materials into 

trucks for 

processing off 

site. 

EULADLEREFINE1 No. 1 Ladle 

refining 

facility 

1/1/90 Baghouse SVLADLEREFIN

E1 

E-01.10 

EULADLEREFINE2 No. 2 Ladle 

refining 

facility 

1/1/95 Baghouse SVLADLEREFIN

E2 

E-01.11 

EUANNEALFURNACES 34 annealing 

furnaces 

 NA NA E-01.12 

EUSREHEATFURNACE1 Slab reheat 

furnace 1 

1/1/79 NA SVHSMREHEAT

FCE11 

SVHSMREHEAT

FCE21 

F-01.04 

EUSREHEATFURNACE2 Slab reheat 

furnace 2 

1/1/74 NA SVHSMREHEAT

FCE21 

SVHSMREHEAT

FCE22 

F-01.04 

EUSREHEATFURNACE3 Slab reheat 

furnace 3 

1/1/74 NA SVHSMREHEAT

FCE31 

SVHSMREHEAT

FCE32 

F-01.04 

Flexible Group Identification

Flexible Grouping ID Emission Unit/Process Groups Included in Flexible 

Grouping 

Requirement 

Table No. 

FGB&CCASTHOUSES EUBBFCASTHOUSE, EUCBFCASTHOUSE F-01.01 

FGB&CSTOVES EUBFCESTOVE, EUCFCESTOVE F-01.02 

FGBOFSHOP EUBOF, EURELADLINGBOF F-01.03 

FGSREHEATFURNACE123 EUSREHEATFURNACE1, EUSREHEATFURNACE2, 

EUSREHEATFURNACE3 

F-01.04 

FGFACILITY All equipment at the stationary source including equipment 

covered by other permits, grandfathered equipment and exempt 

equipment. 

F-01.05 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 7 of 83 

 

TABLE E-01.01 COAL HANDLING EQUIPMENT 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

EMISSION GROUP EUCOALHANDLING 

Flexible Grouping ID NA 

I. DESIGN PARAMETERS 

A. Pollution Control 

Equipment 

4 Baghouses 

B. Stack/Vent Parameters NA 

Stack/Vent ID a. Minimum 

Height 

(feet) 

b. Maximum 

Exhaust Dimension 

(inches) 

c. Temp. 

(°F) 

d. Air 

Flow Rate 

(acfm) 

Applicable 

Requirement 

SVTRACKHOPPER NA NA NA 30,000 NA 

SVRAWCOALSILO NA NA NA 1,800 NA 

SVFINECOALSILO NA NA NA 6,200 NA 

SVPULVERIZER NA NA NA 16,000 NA 

C. Other Design Parameters 

NA 

II. MATERIAL USAGE/EMISSION LIMITS 

A. Material Maximum Usage Rate 

Natural gas 1. 214.7 MMscf per 12-month rolling time period in the pulverizer hot gas 

generator. (40 CFR 52.21(b)(3)) 

2. 214.7 MMscf per 12-month rolling time period in the rail car shed 

heater. (40 CFR 52.21(b)(3))

B. Pollutant Maximum Emission Limit

1. PM 1. 0.005 gr/dscf from the track hopper baghouse (40 CFR 52.21(b)(3), 

R336.1331(c)) 

2. 0.005 gr/dscf from the raw coal silo baghouse (40 CFR 52.21(b)(3), 

R336.1331(c)) 

3. 0.005 gr/dscf from the fine coal silo baghouse (40 CFR 52.21(b)(3), 

R336.1331(c)) 

4. 0.005 gr/dscf from the coal pulverizer baghouse (40 CFR 52.21(b)(3), 

R336.1331(c)) 

2. PM10 1. 0.005 gr/dscf from the track hopper baghouse (R336.1205(1)(a) & (b))

2. 0.005 gr/dscf from the raw coal silo baghouse (R336.1205(1)(a) &(b)) 

3. 0.005 gr/dscf from the fine coal silo baghouse (R336.1205(1)(a) &(b))

4. 0.005 gr/dscf from the coal pulverizer baghouse (R336.1205(1)(a) & 

(b)) 

3. Visible emissions 1. 10% opacity from the track hopper baghouse (R336.1301(1)(c)) 

2. 10% opacity from raw coal silo baghouse (R336.1301(1)(c)) 

3. 10% opacity from the fine coal silo baghouse (R336.1301(1)(c)) 

4. 10% opacity from the coal pulverizer baghouse (R336.1301(1)(c)) 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 8 of 83 

TABLE E-01.01 COAL HANDLING EQUIPMENT 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. 

A. MONITORING/RECORDKEEPING 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping 

NA 

2. Process Monitoring System 

and Recordkeeping 

NA 

3. Other Monitoring and/or 

Recordkeeping 

1. The permittee shall perform a Method 9 certified visible emission 

observation of each baghouse at least once a month during processing 

activity. The permittee shall initiate corrective action upon observation 

of visible emissions in excess of the applicable visible emission 

limitation and shall keep a written record of each required observation 

and corrective action taken. (R336.1910)

 

2. Permittee shall periodically inspect each baghouse to determine the 

operational and physical condition of the baghouse at least once per 

month, and immediately after observing visible emissions in excess of 

the applicable limitation. Each baghouse shall be inspected as necessary 

immediately after a malfunction or failure of the baghouse or the 

process equipment to determine the reason for the malfunction or 

failure. Written records of each inspection and corrective action taken, 

if any, shall be maintained. (R336.1910) 

3. The permittee shall keep, in a satisfactory manner, monthly and 

previous 12-month fuel usage records for the rail car shed heater and 

the pulverizer hot gas generator. The permittee shall keep all records on 

file at the facility for a period of at least five years and make them 

available to the Department upon request. (R336.1205(1)(a) & (b), 40 

CFR 52.21(b)(3)

B. TESTING/RECORDKEEPING 

1. Parameter to be Tested/ 

Recorded 

NA 

2. Method/Analysis NA 

3. Frequency and Schedule of 

Testing/Recordkeeping 

NA 

IV. REPORTING 

Reports and Schedules NA 

V. OPERATIONAL PARAMETERS 

1. The permittee shall not operate the coal pulverizer unless the baghouse is installed, maintained, and operated 

in a satisfactory manner. (R336.1205(1)(a) & (b), R336.1301, R336.1331(c), R336.1910, 40 CFR 

52.21(b)(3))

2. The permittee shall not load coal into the raw coal silo unless the baghouse is installed, maintained, and 

operated in a satisfactory manner. (R336.1205(1)(a) & (b), R336.1301, R336.1331(c), R336.1910, 40 CFR 

52.21(b)(3))
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 9 of 83 

TABLE E-01.01 COAL HANDLING EQUIPMENT 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

3. The permittee shall not load coal into the fine coal silo unless the baghouse is installed, maintained, and 

operated in a satisfactory manner. (R336.1205(1)(a) & (b), R336.1301, R336.1331(c), R336.1910, 40 CFR 

52.21(b)(3))

4. The permittee shall not load coal into the track hopper unless the baghouse is installed, maintained, and 

operated in a satisfactory manner. (R336.1205(1)(a) & (b), R336.1301, R336.1331(c), R336.1910, 40 CFR 

52.21(b)(3))

VI. OTHER REQUIREMENTS 

NA 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 10 of 83 

TABLE E-01.02 B BLAST FURNACE CAST HOUSE OPERATIONS 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

EMISSION GROUP EUBBFCASTHOUSE 

Flexible Grouping ID FGB&CCASTHOUSE 

I. DESIGN PARAMETERS 

A. Pollution Control 

Equipment 

Natural gas suppression system prior to installation of baghouse. 

Baghouse after June 30, 2008 

B. Stack/Vent Parameters NA 

Stack/Vent ID a. Minimum 

Height 

(feet) 

b. Maximum 

Exhaust Dimension 

(inches) 

c. Temp. 

(°F) 

d. Air 

Flow Rate 

(acfm) 

Applicable 

Requirement 

SVBBFROOFMONEAST 75.2 NA NA NA R336.1225 

SVBBFROOFMONWEST 75.2 NA NA NA R336.1225 

SVBFCE 200 111 150 250,000 R336.1225 

C. Other Design Parameters 

NA 

II. MATERIAL USAGE/EMISSION LIMITS 

A. Material Maximum Usage Rate 

NA NA 

B. Pollutant Maximum Emission Limit

1. PM 1. 0.003 gr/dscf from baghouse stack (40 CFR 52.21(b)(3) 

R336.1331, 40 CFR 63 Subpart FFFFF) 

2. 5.59 lb/hr from baghouse stack (40 CFR 52.21(b)(3)) 

2. PM-10 1. 0.0015 gr/dscf from baghouse stack (R336.1205(1)(a) & (b)) 

2. 2.85 lb/hr from baghouse stack (R336.1205(1)(a) & (b)) 

3. Opacity from roof monitors 20% (R336.1358 (1))

4. Secondary emissions exiting 

any opening in the casthouse 

20% (6-minute average) (40 CFR 63.7790(a))

5. Opacity from baghouse stack 10% (R336.1361)

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. 

A. MONITORING/RECORDKEEPING 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping 

NA 

2. Process Monitoring System 

and Recordkeeping 

1. If applicable, the permittee shall install, maintain, and operate a 

Continuous Parametric Monitoring System (CPMS) for the baghouse 

capture system according to the requirements of 40 CFR 63.7830(a) 

and 40 CFR 63.7831(e). (40 CFR 63.7830(a)) 

3. Other Monitoring and/or 

Recordkeeping 

1. Prior to installation of the B blast furnace casthouse baghouse, the 

permittee shall perform a Method 9 certified visible emission 

observation of roof monitors at least once a week during the blast 

furnace operation for a minimum of one entire cast. After installation of 

the B blast furnace casthouse baghouse, the permittee shall perform 

non-certified visible emission observation for the roof monitors at least 

once a week during blast furnace processing activity and a Method 9 

certified visible emission observation of roof monitors at least once 

every month during blast furnace processing activity. The permittee 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 11 of 83 

TABLE E-01.02 B BLAST FURNACE CAST HOUSE OPERATIONS 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

shall initiate corrective action upon observation of visible emissions in 

excess of the applicable visible emission limitation and shall keep a 

written record of each required observation and corrective action taken. 

(R336.1358(1))

2. The permittee shall maintain a copy of each notification and report 

submitted under 40 CFR Part 63, Subpart FFFFF, including all 

documentation supporting the initial notification or notification of 

compliance status submitted according to 40 CFR 63.10(b)(2)(xiv)). 

(40 CFR 63.7842(a)(1))

3. The permittee shall maintain the records required for startup, shutdown 

and malfunction under 63.6(e)(3)(iii) through (v). 

(40 CFR 63.7842(a)(2)) 

4. The permittee shall maintain records associated with performance tests, 

and performance evaluations as required by 40 CFR 63.10(b)(2)(viii). 

(40 CFR 63.7842(a)(3)) 

5. Except as allowed in S.C. 8 permittee shall install, operate, and 

maintain a bag leak detection system meeting the following 

specifications on the baghouse control: (40 CFR 63.7831(f)) 

a. Certified by the manufacturer to be capable of detecting emissions 

of particulate matter at concentrations of 10 milligrams per actual 

cubic foot (0.0044 grains per actual cubic foot). 

(40 CFR 63.7831(f)(1)) 

b. Provides output of relative changes in particulate matter loadings. 

 (40 CFR 63.7831(f)(2)) 

c. Is equipped with an alarm, located such that it is heard by 

appropriate plant personnel, that sounds an alarm when an increase 

in relative particulate loadings is detected over a preset level. 

 (40 CFR 63.7831(f)(3)) 

d. Initially adjusted by establishing the baseline output by adjusting 

the sensitivity (range) and the averaging period of the device and 

setting the alarm set points and alarm delay time. 

(40 CFR 63.7831(f)(5))

6. Following the initial adjustment of the bag leak detection system, the 

permittee shall not adjust the sensitivity or range, averaging period, 

alarm set points or alarm delay time except as specified in the 

operation and maintenance plan. This requirement does not apply if 

the permittee installs a COMS as specified in S.C. 8. (40 CFR 

63.7831(f)(6))

7. If the sensitivity of the bag leak detection system is changed beyond 

the limits established pursuant to 40 CFR 63.7831(f)(6), a copy of a 

written certification by a responsible official shall be included in the 

semiannual compliance report for that period. This requirement does 

not apply if the permittee installs a COMS as specified in S.C. 8. (40 

CFR 63.7833(c)(2))
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 12 of 83 

TABLE E-01.02 B BLAST FURNACE CAST HOUSE OPERATIONS 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

8. If permittee does not install and operate a bag leak detection system, 

the permittee shall install, operate, and maintain a COMS according to 

the requirements in 40CFR Sec. 63.7831(h) and monitor the hourly 

average opacity of emissions exiting each control device stack 

according to the requirements in 40 CFR 63.7832. (40 CFR 63.7832)

9. The permittee shall monitor the pressure drop across each baghouse 

compartment daily to ensure that the pressure drop is within the normal 

operating range identified in the manual. (40 CFR 63.7830(b)(1)) 

10. The permittee shall confirm that dust is being removed from hoppers on 

a weekly basis through visual observations or other means of 

determining the proper functioning of the removal mechanisms. 

(40 CFR 63.7830(b)(2)) 

11. The permittee shall confirm that the compressed air supply to the pulsejet baghouse is operating properly on a daily basis. 

(40 CFR 63.7830(b)(3)) 

12. The permittee shall monitor the cleaning cycles of the baghouse to 

ensure proper operation using appropriate technology. (40 CFR 

63.7830(b)(4)) 

13. The permittee shall check the bag cleaning mechanisms for proper 

functioning through monthly visual inspections or equivalent means. 

 (40 CFR 63.7830(b)(5))

14. The permittee shall inspect the baghouse to confirm the physical 

integrity of the baghouse through quarterly inspections of the interior of 

the baghouse for air leaks. (40 CFR 63.7830(b)(7)) 

15. The permittee shall inspect fans for wear, material buildup, and 

corrosion on a quarterly basis using visual inspections, vibration 

detectors, or equivalent means. (40 CFR 63.7830(b)(8)) 

16. The permittee shall monitor the process as required by this table, except 

during monitoring malfunctions, out-of-control periods, associated 

repairs, and required quality assurance or control activities (including 

calibration checks and required zero and span adjustments). (40 CFR 

63.7832(a)) 

17. Data recorded during monitoring malfunctions, associated repairs, and 

required quality assurance or control activities shall not be used in data 

averages and calculations used to report emission or operating levels or 

to fulfill minimum data availability requirements. (40 CFR 63.7832(b))

18. The permittee shall prepare, and operate at all times according to, a 

written operation and maintenance plan for the baghouse capture 

system. The plan shall address each of the following: 

(40 CFR 63.7800(b))
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 13 of 83 

TABLE E-01.02 B BLAST FURNACE CAST HOUSE OPERATIONS 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

a. Weekly inspections of the equipment that is important to the 

performance of the total capture system, including, but not limited 

to, observations of the physical appearance of the equipment and 

requirements to repair any defect or deficiency in the capture 

system before the next scheduled inspection; (R336.1301, 

R336.1358(1), 40 CFR 63.7800(b)(1))

b. Operating limit parameters appropriate for the capture system 

design that are representative and reliable indicators of the 

performance of the capture system including, but not limited to, 

operating limit parameters that indicate the level of the ventilation 

draft and the damper position settings for the capture system when 

operating to collect emissions, including revised settings for 

seasonal variations. Appropriate operating limit parameters for 

ventilation draft include, but are not limited to, volumetric flow rate 

through each separately ducted hood, total volumetric flow rate at 

the inlet to the control device to which the capture system is 

vented, fan motor amperage, or static pressure. 

(40 CFR 63.7800(b)(3)) 

19. If applicable, the permittee shall monitor the hourly average actual 

volumetric flow rate through each separately ducted hood and the 

average hourly total volumetric flow rate at the inlet to the baghouse 

according to the requirements in 40 CFR 63.7832. (40 CFR 

63.7830(a)) 

20. If applicable, the permittee shall develop and make available for 

inspection upon request by AQD a site-specific monitoring plan that 

addresses all of the following requirements for the baghouse capture 

system: (40 CFR 63.7831(a))

a. Installation of the CPMS sampling probe or other interface at a 

measurement location relative to each hooded emission point such 

that the measurement is representative of capture of the exhaust 

emissions; (40 CFR 63.7831(a)(1))

b. Performance and equipment specifications for the sample interface, 

the parametric signal analyzer, and the data collection and 

reduction system; (40 CFR 63.7831(a)(2))

c. Performance evaluation procedures and acceptance criteria; 

(40 CFR 63.7831(a)(3))

d. Ongoing operation and maintenance procedures in accordance with 

the general requirements of 40 CFR 63.8(c)(1), (c)(3), (c)(4)(ii), 

(c)(7), and (c)(8); (40 CFR 63.7831(a)(4))

e. Ongoing data quality assurance procedures in accordance with the 

general requirements of 40 CFR 63.8(d); and 

(40 CFR 63.7831(a)(5)) 

f. Ongoing recordkeeping and reporting procedures in accordance the 

general requirements of 40 CFR 63.10(c), (e)(1), and (e)(2)(i). 

 (40 CFR 63.7831(a)(6)) 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 14 of 83 

TABLE E-01.02 B BLAST FURNACE CAST HOUSE OPERATIONS 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

21. If applicable, the permittee shall operate and maintain the capture 

system CPMS in continuous operation according to the site-specific 

monitoring plan. Unless otherwise specified, the CPMS shall: (40 CFR 

63.7831(b))

a. Complete a minimum of one cycle of operation for each successive 

15-minute period and collect a minimum of three of the required 

four data points to constitute a valid hour of data; 

(40 CFR 63.7831(b)(1))

b. Provide valid hourly data for at least 95 percent of every averaging 

period; and (40 CFR 63.7831(b)(2))

c. Determine and record the hourly average of all recorded readings.

(40 CFR 63.7831(b)(3)) 

22. The permittee shall operate the baghouse capture system at or above the 

lowest value or settings established for the operating limits in the 

operation and maintenance plan and collect, reduce, and record the 

monitoring data for each of the operating limit parameters. (40 CFR 

63.7833(b)) 

B. TESTING/RECORDKEEPING 

1. Parameter to be Tested/ 

Recorded 

1. Opacity 

2. PM 

3. PM-10 

2. Method/Analysis Approved Method 

3. Frequency and Schedule of 

Testing/Recordkeeping 

1. Within 180 operating days after commencement of trial operation of the 

B blast furnace casthouse baghouse, verification of PM and PM10 

emission rates from the B-Blast Furnace baghouse stack, by testing at 

owner's expense, in accordance with Department requirements, will be 

required. No less than 60 days prior to testing, a complete test plan 

shall be submitted to the AQD. The final plan must be approved by the 

AQD prior to testing. Verification of emission rates includes the 

submittal of a complete report of the test results to the AQD within 60 

days following the last date of the test. (R336.1205, R336.1331(c), 

R336.2001, R336.2003, R336.2004, 40 CFR 52.21(b)(3)) 

2. The permittee shall conduct a performance test to demonstrate initial 

compliance with the applicable emission and opacity limitations of 40 

CFR Part 63, Subpart FFFFF, contained in this table within 180 days of 

the startup of “B” BF casthouse baghouse. (40 CFR 63.7820(a)) 

3. Permittee shall conduct performance tests for particulate matter 

emissions and opacity at least once per permit term. (40 CFR 

63.7821) 

4. The permittee shall demonstrate compliance with the opacity limitation 

in II.B.4 with a certified observer of Method 9 visible emissions using 

Method 9. The performance test for visible emissions shall consist of 
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TABLE E-01.02 B BLAST FURNACE CAST HOUSE OPERATIONS 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

30 6-minute block averages during tapping of the furnace. 

(40 CFR 63.7823(c)(1) and (2)) 

5. The permittee shall maintain records of visible emissions observations 

required by 40 CFR Part 63, Subpart FFFFF. (40 CFR 63.7842(c) 

6. The permittee shall sample for an integral number of furnace tapping 

operations to obtain at least 1 hour of sampling for each test run. (40 

CFR 63.7822(e)) 

7. The permittee shall maintain records of the time corrective action was 

initiated, the corrective action taken, and the date when corrective 

actions were completed in response to a bag leak detection system 

alarm. (40 CFR 63.7842(d) and 40 CFR 63.7833(c)(1))

8. Performance tests for visible emissions shall be conducted such that the 

opacity observations overlap with the performance tests for particulate. 

(40 CFR 63.7823(b)) 

9. The permittee shall certify that the baghouse capture system operated 

during the performance test at the site-specific operating limits 

established in the operation and maintenance plan using the following 

procedures: (40 CFR 63.7824(a)) 

a. Concurrent with all opacity observations, measure and record 

values for each of the operating limit parameters in the capture 

system operation and maintenance plan according to the monitoring 

requirements specified in §63.7830(a). (40 CFR 63.7824(a)(1))

b. For any dampers that are manually set and remain at the same 

position at all times the capture system is operating, the damper 

position shall be visually checked and recorded at the beginning 

and end of each opacity observation period segment. 

(40 CFR 63.7824(a)(2)) 

c. Review and record the monitoring data and identify and explain 

any times the capture system operated outside the applicable 

operating limits. (40 CFR 63.7824(a)(3))

d. Certify in the performance test report that during all observation 

period segments, the capture system was operating at the values or 

settings established in the capture system operation and 

maintenance plan. (40 CFR 63.7824(a)(4)) 

10. The permittee may change the operating limits for the baghouse capture 

system if the following requirements are met: (40 CFR 63.7824(d)) 

a. Submit a written notification to the Administrator requesting to 

conduct a new performance test to revise the operating limit. 

(40 CFR 63.7824(d)(1)) 
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TABLE E-01.02 B BLAST FURNACE CAST HOUSE OPERATIONS 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

b. Conduct a performance test to demonstrate compliance with the 

applicable operating limitation. (40 CFR 63.7824(d)(2))

c. Establish revised operating limits according to the applicable 

procedures in 40 CFR 63.7824, paragraphs (a) through (c) for a 

capture system. (40 CFR 63.7824(d)(3)) 

IV. REPORTING 

Reports and Schedules 1. Permittee shall report the results of the initial performance test in the 

notification of compliance status. (40 CFR 63.7820(a), 40 CFR 

63.7825(c) and 40 CFR 63.7840(e)) 

2. Permittee shall submit a notification of intent to perform any 

performance testing under 40 CFR Part 63, Subpart FFFFF at least 60 

calendar days before testing is to begin. (40 CFR 63.7840(d)) 

3. Any time an action taken by the permittee during a startup, shutdown, 

or malfunction of an affected source (including actions taken to correct 

a malfunction) is not consistent with the procedures in the startup, 

shutdown, and malfunction plan, the permittee shall comply with all 

requirements of 63.10(d)(5)(ii). (40 CFR Part 63.7841(c))

V. OPERATIONAL PARAMETERS 

1. After June 30, 2008, B Blast Furnace Cast House shall not be operated unless the baghouse is installed, 

maintained and operated in a satisfactory manner. (R336.1205(1)(a) & (b), R336.1225, R336.1331(c), 

R336.1910, 40 CFR 52.21(b)(3), MDEQ Consent Order AQD No. 6-2006 Paragraph 10.B)

2. Prior to installation of the baghouse, the B Blast Furnace Cast House shall not be operated unless the natural 

gas fired fume suppression system is installed and operating properly. (R336.1910) 

3. Prior to installation of the baghouse, the permittee shall operate and maintain a flow indication system for 

natural gas to the suppression system when the B Blast Furnace Casthouse is operated. (R336.1910)

 

4. The B Blast Furnace Cast House shall be operated and maintained in a manner consistent with good air 

pollution control practices for minimizing emissions. (40 CFR 63.7800(a) and 40 CFR 63.6(e)(1)(i))

5. The permittee shall develop and implement a written startup, shutdown and malfunction plan for the B Blast 

Furnace Cast House. (40 CFR 63.7810(c), 40 CFR 63.7835(b) and 40 CFR 63.6(e)(3)) 

6. By January 31, 2008, the permittee shall provide the B blast furnace casthouse baghouse capture system 

design plans and a signed certification from the designer, certifying that the baghouse capture system is 

designed to achieve no less than 98% collection efficiency. (R336.1205(1)(a) & (b), 40 CFR 52.21(b)(3)) 

VI. OTHER REQUIREMENTS 

1. Records required under 40 CFR Part 63, Subpart FFFFF and specified in this table shall be retained for five 

years. The records must be maintained onsite for the two most recent years of the five year period. Records 

from the remaining three years of the five year period may be keep offsite. (40 CFR 63.7843(b) and (c))
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 17 of 83 

TABLE E-01.03 B BLAST FURNACE STOVE 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

FLEXIBLE GROUPING FGB&CSTOVES 

Emission Unit/Process Group EUBFCESTOVE 

I. DESIGN PARAMETERS 

A. Pollution Control 

Equipment 

Low-NOx technology; scrubber and mechanical collector for blast furnace 

gas precleaning 

B. Stack/Vent Parameters NA 

Stack/Vent ID a. Minimum 

Height 

(feet) 

b. Maximum 

Exhaust Dimension 

(inches) 

c. Temp. 

(°F) 

d. Air 

Flow Rate 

(acfm) 

Applicable 

Requirement 

SVBSTOVE 190 99 750 NA R336.1225, 40 

CFR 52.21(c) & 

(d) 

C. Other Design Parameters 

NA 

II. MATERIAL USAGE/EMISSION LIMITS 

A. Material Maximum Usage Rate 

NA NA 

B. Pollutant Maximum Emission Limit

1. NOx 1. 36.0 lb/hr (R336.1205(1)(a) & (b)) 

2. 136.6 ton/12-month rolling period (R336.1205(1)(a) & (b))

2. SO2 1. 70.9 lb/hr. (40 CFR 52.21(c) & (d), 40 CFR 52.21(j)) 

3. CO 1. 661.1 lb/hr (40 CFR 52.21(d)) 

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. 

A. MONITORING/RECORDKEEPING 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping 

NA

2. Process Monitoring System 

and Recordkeeping 

1. The permittee shall keep, in a satisfactory manner, daily fuel usage 

records for EUBFCESTOVE. The permittee shall keep all records on 

file at the facility for a period of at least five years and make them 

available to the Department upon request. (R336.1205(1)(a) & (b), 

40 CFR 52.21(b)(3), (c), & (d)) 

2. Following the performance testing required in S.C. III.B.3.1 of this 

table, the permittee shall determine compliance with emission limits in 

S.C. II.B.1.2 of this table by establishing emission factors based up on 

the BFCE stove stack testing and applying these emission factors to the 

daily fuel usage recorded in S.C. III.A.2.1, as outlined in Appendix 1.7. 

(R336.1205(1)(a) & (b)) 
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TABLE E-01.03 B BLAST FURNACE STOVE 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

3. Following the performance testing required in S.C. III.B.3.1 of Table 

E-01.05, the permittee shall determine compliance with the emission 

limit in S.C. II.B.3.1 of this table by establishing an emission factor 

based upon the CFCE stove stack testing and applying this emission 

factor to the daily fuel usage recorded in S.C. III.A.2.1, as outlined in 

Appendix 1.7. (40 CFR 52.21 (d)) 

3. Other Monitoring and/or 

Recordkeeping 

NA 

B. TESTING/RECORDKEEPING 

1. Parameter to be Tested/ 

Recorded 

1. NOx 

2. SO2 

2. Method/Analysis Approved method 

3. Frequency and Schedule of 

Testing/Recordkeeping 

1. Within 180 operating days after commencement of trial operation of 

the B blast furnace casthouse baghouse, verification of NOx and SO2 

emission rates from the B-Blast Furnace stove stack, by testing at 

owner's expense, in accordance with Department requirements, will be 

required. No less than 60 days prior to testing, a complete test plan 

shall be submitted to the AQD. The final plan must be approved by 

the AQD prior to testing. Verification of emission rates includes the 

submittal of a complete report of the test results to the AQD within 60 

days following the last date of the test. (R336.2001, R336.2003, 

R336.2004, 40 CFR 52.21(c) & (d), 40 CFR 52.21(j)) 

IV. REPORTING 

Reports and Schedules NA 

V. OPERATIONAL PARAMETERS 

1. After completion of C-FCE modification, the permittee shall not operate EUBFCESTOVE unless the lowNOx technology is installed, maintained, and operated in a satisfactory manner. (R336.1205(1)(a) & (b), 

R336.1910)

2. The permittee shall not fire blast furnace gas in EUBFCESTOVE unless the scrubber and mechanical 

collector for pre-combustion gas cleaning are installed, maintained, and operated in a satisfactory manner.

 (R336.1205(1)(a) & (b), R336.1910, 40 CFR 52.21(b)(3)) 

VI. OTHER REQUIREMENTS 

NA 
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Permit No. 182-05B Page 19 of 83 

TABLE E-01.04 C BLAST FURNACE CAST HOUSE OPERATIONS 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

EMISSION GROUP EUCBFCASTHOUSE 

Flexible Grouping ID FGB&CBFCASTHOUSE 

I. DESIGN PARAMETERS 

A. Pollution Control 

Equipment 

Baghouse. 

B. Stack/Vent Parameters NA 

Stack/Vent ID a. Minimum 

Height 

(feet) 

b. Maximum 

Exhaust Dimension 

(inches) 

c. Temp. 

(°F) 

d. Air 

Flow Rate 

(acfm) 

Applicable 

Requirement 

SVCBFROOFMONEAST 75.2 NA NA NA R336.1225

SVCBFROOFMONWEST 75.2 NA NA NA R336.1225

SVCFCE 200 153 150 500,000 R336.1225 

C. Other Design Parameters 

NA 

II. MATERIAL USAGE/EMISSION LIMITS 

A. Material Maximum Usage Rate 

NA NA 

B. Pollutant Maximum Emission Limit

1. PM 1. 0.003 gr/dscf from baghouse stack (40 CFR 52.21(b)(3), 

R336.1331, 40 CFR 63 Subpart FFFFF) 

2. 11.17 lb/hr from baghouse stack (40 CFR 52.21(b)(3))

2. PM-10 1. 0.0015 gr/dscf from baghouse stack (R336.1205(1)(a) & (b)) 

2. 5.70 lb/hr from baghouse stack (R336.1205(1)(a) & (b))

3. Opacity from roof monitors 20% (R336.1358 (1))

4. Secondary emissions exiting 

any opening in the casthouse 

20% (6-minute average) (40 CFR 63.7790(a))

5. Opacity from baghouse stack 10% (R336.1361)

6. SO2 from baghouse stack 1. 23.03 lb/hr (40 CFR 52.21 (c) & (d), 40 CFR 52.21 (j)) 

2. 91.79 ton per 12-month rolling time period (40 CFR 52.21 (c), (d), 

& (j))

7. NOx from baghouse stack 1. 2.45 lb/hr (R336.1205(1)(a) & (b)) 

2. 9.77 ton per 12-month rolling time period (R336.1205(1)(a) & (b))

8. VOC from baghouse stack 1. 6.77 lb/hr (R336.1702(a))

9. Mn 1. 0.00256 lb/hr from baghouse stack (R336.1225) 

10. Pb 1. 0.00015 lb/hr from baghouse stack (40 CFR 52.21(d)) 

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. 

A. MONITORING/RECORDKEEPING 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping 

NA 

2. Process Monitoring System 

and Recordkeeping 

1. If applicable, the permittee shall install, maintain, and operate a 

Continuous Parametric Monitoring System (CPMS) for the baghouse 

capture system according to the requirements of 40 CFR 63.7830(a) 

and 40 CFR 63.7831(e). (40 CFR 63.7830(a)) 
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TABLE E-01.04 C BLAST FURNACE CAST HOUSE OPERATIONS 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

3. Other Monitoring and/or 

Recordkeeping 

1. Prior to installation of the C blast furnace casthouse baghouse, the 

permittee shall perform a Method 9 certified visible emission 

observation of roof monitors at least once a week during the blast 

furnace operation for a minimum of one entire cast. After installation of 

the C blast furnace casthouse baghouse, the permittee shall perform 

non-certified visible emission observation for the roof monitors at least 

once a week during blast furnace processing activity and a Method 9 

certified visible emission observation of roof monitors at least once 

every month during blast furnace processing activity. The permittee 

shall initiate corrective action upon observation of visible emissions in 

excess of the applicable visible emission limitation and shall keep a 

written record of each required observation and corrective action taken. 

(R336.1358(1))

2. The permittee shall maintain a copy of each notification and report 

submitted under 40 CFR Part 63, Subpart FFFFF, including all 

documentation supporting the initial notification or notification of 

compliance status submitted according to 40 CFR 63.10(b)(2)(xiv)). 

(40 CFR 63.7842(a)(1))

3. The permittee shall maintain the records required for startup, shutdown 

and malfunction under 63.6(e)(3)(iii) through (v). 

 (40 CFR 63.7842(a)(2))

4. The permittee shall maintain records associated with performance 

tests, and performance evaluations as required by 40 CFR 

63.10(b)(2)(viii). (40 CFR 63.7842(a)(3)) 

5. Except as allowed in S.C. 8, permittee shall install, operate, and 

maintain a bag leak detection system meeting the following 

specifications on the baghouse control: (40 CFR 63.7831(f)) 

a. Certified by the manufacturer to be capable of detecting emissions 

of particulate matter at concentrations of 10 milligrams per actual 

cubic foot (0.0044 grains per actual cubic foot). 

(40 CFR 63.7831(f)(1)) 

b. Provides output of relative changes in particulate matter loadings. 

(40 CFR 63.7831(f)(2)) 

c. Is equipped with an alarm, located such that it is heard by 

appropriate plant personnel, that sounds an alarm when an increase 

in relative particulate loadings is detected over a preset level. 

 (40 CFR 63.7831(f)(3)) 

d. Initially adjusted by establishing the baseline output by adjusting 

the sensitivity (range) and the averaging period of the device and 

setting the alarm set points and alarm delay time. 

(40 CFR 63.7831(f)(5))

6. Following the initial adjustment of the bag leak detection system, the 

permittee shall not adjust the sensitivity or range, averaging period, 

alarm set points or alarm delay time except as specified in the 
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TABLE E-01.04 C BLAST FURNACE CAST HOUSE OPERATIONS 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

operation and maintenance plan. This requirement does not apply if 

the permittee installs a COMS as specified in S.C. 8. (40 CFR 

63.7831(f)(6))

7. If the sensitivity of the bag leak detection system is changed beyond 

the limits established pursuant to 40 CFR 63.7831(f)(6), a copy of a 

written certification by a responsible official shall be included in the 

semiannual compliance report for that period. This requirement does 

not apply if the permittee installs a COMS as specified in S.C. 8. (40 

CFR 63.7833(c)(2))

8. If permittee does not install and operate a bag leak detection system, 

the permittee shall install, operate, and maintain a COMS according to 

the requirements in 40 CFR Sec. 63.7831(h) and monitor the hourly 

average opacity of emissions exiting each control device stack 

according to the requirements in 40 CFR 63.7832. (40 CFR 63.7832)

9. The permittee shall monitor the pressure drop across each baghouse 

compartment daily to ensure that the pressure drop is within the normal 

operating range identified in the manual. (40 CFR 63.7830(b)(1)) 

10. The permittee shall confirm that dust is being removed from hoppers on 

a weekly basis through visual observations or other means of 

determining the proper functioning of the removal mechanisms. 

(40 CFR 63.7830(b)(2)) 

11. The permittee shall confirm that the compressed air supply to the pulsejet baghouse is operating properly on a daily basis. 

(40 CFR 63.7830(b)(3)) 

12. The permittee shall monitor the cleaning cycles of the baghouse to 

ensure proper operation using appropriate technology. (40 CFR 

63.7830(b)(4)) 

13. The permittee shall check the bag cleaning mechanisms for proper 

functioning through monthly visual inspections or equivalent means. 

(40 CFR 63.7830(b)(5))

14. The permittee shall inspect the baghouse to confirm the physical 

integrity of the baghouse through quarterly inspections of the interior of 

the baghouse for air leaks. (40 CFR 63.7830(b)(7)) 

15. The permittee shall inspect fans for wear, material buildup, and 

corrosion on a quarterly basis using visual inspections, vibration 

detectors, or equivalent means. (40 CFR 63.7830(b)(8)) 

16. The permittee shall monitor the process as required by this table, except 

during monitoring malfunctions, out-of-control periods, associated 

repairs, and required quality assurance or control activities (including 

calibration checks and required zero and span adjustments). (40 CFR 

63.7832(a)) 
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TABLE E-01.04 C BLAST FURNACE CAST HOUSE OPERATIONS 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

17. Data recorded during monitoring malfunctions, associated repairs, and 

required quality assurance or control activities shall not be used in data 

averages and calculations used to report emission or operating levels or 

to fulfill minimum data availability requirements. (40 CFR 63.7832(b))

18. The permittee shall prepare, and operate at all times according to, a 

written operation and maintenance plan for the baghouse capture 

system. The plan shall address each of the following: 

(40 CFR 63.7800(b))

a. Weekly inspections of the equipment that is important to the 

performance of the total capture system, including, but not limited 

to, observations of the physical appearance of the equipment and 

requirements to repair any defect or deficiency in the capture 

system before the next scheduled inspection; (R336.1301, 

R336.1358(1), 40 CFR 63.7800(b)(1))

b. Operating limit parameters appropriate for the capture system 

design that are representative and reliable indicators of the 

performance of the capture system including, but not limited to, 

operating limit parameters that indicate the level of the ventilation 

draft and the damper position settings for the capture system when 

operating to collect emissions, including revised settings for 

seasonal variations. Appropriate operating limit parameters for 

ventilation draft include, but are not limited to, volumetric flow rate 

through each separately ducted hood, total volumetric flow rate at 

the inlet to the control device to which the capture system is 

vented, fan motor amperage, or static pressure. 

(40 CFR 63.7800(b)(3)) 

19. If applicable, the permittee shall monitor the hourly average actual 

volumetric flow rate through each separately ducted hood and the 

average hourly total volumetric flow rate at the inlet to the baghouse 

according to the requirements in 40 CFR 63.7832. (40 CFR 

63.7830(a)) 

20. If applicable, the permittee shall develop and make available for 

inspection upon request by AQD a site-specific monitoring plan that 

addresses all of the following requirements for the baghouse capture 

system: (40 CFR 63.7831(a))

a. Installation of the CPMS sampling probe or other interface at a 

measurement location relative to each hooded emission point such 

that the measurement is representative of capture of the exhaust 

emissions; (40 CFR 63.7831(a)(1))

b. Performance and equipment specifications for the sample interface, 

the parametric signal analyzer, and the data collection and 

reduction system; (40 CFR 63.7831(a)(2))

c. Performance evaluation procedures and acceptance criteria; 

(40 CFR 63.7831(a)(3))
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TABLE E-01.04 C BLAST FURNACE CAST HOUSE OPERATIONS 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

d. Ongoing operation and maintenance procedures in accordance with 

the general requirements of 40 CFR 63.8(c)(1), (c)(3), (c)(4)(ii), 

(c)(7), and (c)(8); (40 CFR 63.7831(a)(4))

e. Ongoing data quality assurance procedures in accordance with the 

general requirements of 40 CFR 63.8(d); and 

(40 CFR 63.7831(a)(5)) 

f. Ongoing recordkeeping and reporting procedures in accordance the 

general requirements of 40 CFR 63.10(c), (e)(1), and (e)(2)(i). 

 (40 CFR 63.7831(a)(6)) 

21. If applicable, the permittee shall operate and maintain the capture 

system CPMS in continuous operation according to the site-specific 

monitoring plan. Unless otherwise specified, the CPMS shall: (40 CFR 

63.7831(b))

a. Complete a minimum of one cycle of operation for each successive 

15-minute period and collect a minimum of three of the required 

four data points to constitute a valid hour of data; 

(40 CFR 63.7831(b)(1))

b. Provide valid hourly data for at least 95 percent of every averaging 

period; and (40 CFR 63.7831(b)(2))

c. Determine and record the hourly average of all recorded readings.

(40 CFR 63.7831(b)(3)) 

22. The permittee shall operate the baghouse capture system at or above the 

lowest value or settings established for the operating limits in the 

operation and maintenance plan and collect, reduce, and record the 

monitoring data for each of the operating limit parameters. (40 CFR 

63.7833(b)) 

23. The permittee shall keep a daily record of the amount of iron cast from 

the furnace. (R336.1205(1)(a) & (b), R336.1225)

24. The permittee shall keep, in a satisfactory manner, monthly and 

previous 12-month records of SO2 and NOx emission calculations for 

C blast furnace casthouse baghouse, using emission factors developed 

during the testing required in SC III.B.3.1, using the method shown in 

Appendix 1.7. The permittee shall keep all records on file at the 

facility for a period of at least five years and make them available to the 

Department upon request. (R336.1205(1)(a) & (b), 40 CFR 52.21(c) 

and (d))

B. TESTING/RECORDKEEPING 

1. Parameter to be Tested/ 

Recorded 

1. Opacity 

2. PM 

3. PM-10 

4. SO2 
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TABLE E-01.04 C BLAST FURNACE CAST HOUSE OPERATIONS 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

5. NOx 

6. VOC 

7. Mn 

8. Pb 

2. Method/Analysis Approved Method 

3. Frequency and Schedule of 

Testing/Recordkeeping 

1. Within 180 days after commencement of trial operation, verification of 

PM, PM10, NOx, VOC, and SO2 emission rates from the C-Blast 

Furnace baghouse stack, by testing at owner's expense, in accordance 

with Department requirements, will be required. No less than 60 days 

prior to testing, a complete test plan shall be submitted to the AQD. 

The final plan must be approved by the AQD prior to testing. 

Verification of emission rates includes the submittal of a complete 

report of the test results to the AQD within 60 days following the last 

date of the test. (R336.1205, R336.702, R336.2001, R336.2003, 

R336.2004, 40 CFR 52.21(c) & (d), 40 CFR 52.21(j)) 

2. The permittee shall conduct a performance test to demonstrate initial 

compliance with the applicable emission and opacity limitations of 40 

CFR Part 63, Subpart FFFFF contained in this table within 180 days of 

startup. (40 CFR 63.7820(a)) 

3. Permittee shall conduct performance tests for particulate matter 

emissions and opacity at least once per permit term. (40 CFR 

63.7821) 

4. The permittee shall demonstrate compliance with the opacity limitation 

in II.B.4 with a certified observer of Method 9 visible emissions using 

Method 9. The performance test for visible emissions shall consist of 

30 6-minute block averages during tapping of the furnace. 

(40 CFR 63.7823(c)(1) and (2)) 

5. The permittee shall maintain records of visible emissions observations 

required by 40 CFR Part 63, Subpart FFFFF. (40 CFR 63.7842(c) 

6. The permittee shall sample for an integral number of furnace tapping 

operations to obtain at least 1 hour of sampling for each test run. (40 

CFR 63.7822(e)) 

7. The permittee shall maintain records of the time corrective action was 

initiated, the corrective action taken, and the date when corrective 

actions were completed in response to a bag leak detection system 

alarm. (40 CFR 63.7842(d) and 40 CFR 63.7833(c)(1))
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TABLE E-01.04 C BLAST FURNACE CAST HOUSE OPERATIONS 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

8. Performance tests for visible emissions shall be conducted such that the 

opacity observations overlap with the performance tests for particulate. 

(40 CFR 63.7823(b)) 

9. The permittee shall obtain an analysis of the C Blast Furnace Casthouse 

baghouse dust once per calendar month during the 1st year after the 

modification of C blast furnace and quarterly thereafter, or less 

frequently if approved in writing by the Air Quality Division. The 

analysis shall determine the percentage of Pb and Mn in the collected 

PM dust from the baghouse. The permittee shall submit an acceptable 

protocol for baghouse dust sampling and analysis methods to the Air 

Quality Division, at least 60 days prior the initial performance emission 

test. (R336.1225, R336.1228, 40 CFR 52.21(d)) 

10. Within 60 days of achieving the maximum production rate, but not later 

than 180 days after commencement of trial operation, the permittee 

shall verify and quantify Mn and Pb emission rates and the ratio of Mn 

and Pb concentrations in the baghouse dust to the actual amount of Mn 

and Pb emitted from the C Blast Furnace Casthouse by testing at 

owner's expense, in accordance with Department requirements. No less 

than 60 days prior to testing, the permittee shall submit a complete test 

plan to the AQD. The AQD must approve the final plan prior to 

testing. Verification of emission rates includes the submittal of a 

complete report of the test results to the AQD within 60 days following 

the last date of the test. (R336.1225, R336.1228, R336.2001, 

R336.2003, R336.2004, 40 CFR 52.21(b)(3)) 

11. The permittee shall certify that the baghouse capture system operated 

during the performance test at the site-specific operating limits 

established in the operation and maintenance plan using the following 

procedures: (40 CFR 63.7824(a)) 

a. Concurrent with all opacity observations, measure and record 

values for each of the operating limit parameters in the capture 

system operation and maintenance plan according to the monitoring 

requirements specified in §63.7830(a). (40 CFR 63.7824(a)(1))

b. For any dampers that are manually set and remain at the same 

position at all times the capture system is operating, the damper 

position shall be visually checked and recorded at the beginning 

and end of each opacity observation period segment. 

(40 CFR 63.7824(a)(2)) 

c. Review and record the monitoring data and identify and explain 

any times the capture system operated outside the applicable 

operating limits. (40 CFR 63.7824(a)(3))

d. Certify in the performance test report that during all observation 

period segments, the capture system was operating at the values or 

settings established in the capture system operation and 

maintenance plan. (40 CFR 63.7824(a)(4)) 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 26 of 83 

TABLE E-01.04 C BLAST FURNACE CAST HOUSE OPERATIONS 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

12. The permittee may change the operating limits for the baghouse capture 

system if the following requirements are met: (40 CFR 63.7824(d)) 

a. Submit a written notification to the Administrator requesting to 

conduct a new performance test to revise the operating limit. 

(40 CFR 63.7824(d)(1))

b. Conduct a performance test to demonstrate compliance with the 

applicable operating limitation. (40 CFR 63.7824(d)(2))

c. Establish revised operating limits according to the applicable 

procedures in 40 CFR 63.7824, paragraphs (a) through (c) for a 

capture system. (40 CFR 63.7824(d)(3)) 

IV. REPORTING 

Reports and Schedules 1. Permittee shall report the results of the initial performance test in the 

notification of compliance status. (40 CFR 63.7820(a), 40 CFR 

63.7825(c) and 40 CFR 63.7840(e)) 

2. Permittee shall submit a notification of intent to perform any 

performance testing under 40 CFR Part 63, Subpart FFFFF at least 60 

calendar days before testing is to begin. (40 CFR 63.7840(d)) 

3. Any time an action taken by the permittee during a startup, shutdown, 

or malfunction of an affected source (including actions taken to correct 

a malfunction) is not consistent with the procedures in the startup, 

shutdown, and malfunction plan, the permittee shall comply with all 

requirements of 63.10(d)(5)(ii). (40 CFR Part 63.7841(c))

V. OPERATIONAL PARAMETERS 

1. After completion of C-FCE modification, C Blast Furnace Cast House shall not be operated unless the 

baghouse is installed, maintained and operated in a satisfactory manner. (R336.1205(1)(a) & (b), 

R336.1225, R336.1331, R336.1910, 40 CFR 52.21(b)(3))

2. The permittee shall install a baghouse dust collector for C blast furnace casthouse according to the following 

schedule: 

a. Complete construction and place in operation by January 31, 2008 or startup of enhanced C-FCE, 

whichever is sooner. (R336.1205(1)(a) & (b), 40 CFR 52.21(b)(3)) 

3. The permittee shall keep on file a copy of the CFCE baghouse capture system design plans and a signed 

certification from the designer, certifying that the baghouse capture system is designed to achieve no less 

than 98% collection efficiency. (R336.1205(1)(a) & (b), 40 CFR 52.21(b)(3))

4. The C Blast Furnace Cast House shall be operated and maintained in a manner consistent with good air 

pollution control practices for minimizing emissions. (40 CFR 63.7800(a) and 40 CFR 63.6(e)(1)(i))

5. The permittee shall develop and implement a written startup, shutdown and malfunction plan for the C Blast 

Furnace Cast House. (40 CFR 63.7810(c), 40 CFR 63.7835(b) and 40 CFR 63.6(e)(3)) 

6. The iron production from C Blast Furnace Casthouse shall not exceed a maximum of 10,000 tons per day 

based on a calendar week average. (R336.1225, 40 CFR 52.21(c) & (d)) 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 27 of 83 

TABLE E-01.04 C BLAST FURNACE CAST HOUSE OPERATIONS 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

VI. OTHER REQUIREMENTS 

1. Records required under 40 CFR Part 63, Subpart FFFFF and specified in this table shall be retained for five 

years. The records must be maintained onsite for the two most recent years of the five year period. Records 

from the remaining three years of the five year period may be keep offsite. (40 CFR 63.7843(b) and (c)) 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 28 of 83 

TABLE E-01.05 C BLAST FURNACE STOVE 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

FLEXIBLE GROUPING FGB&CSTOVES 

Emission Unit/Process Group EUCFCESTOVE 

I. DESIGN PARAMETERS 

A. Pollution Control 

Equipment 

Low-NOx technology; venturi scrubber and mechanical collector for blast 

furnace gas precleaning 

B. Stack/Vent Parameters NA 

Stack/Vent ID a. Minimum 

Height 

(feet) 

b. Maximum 

Exhaust Dimension 

(inches) 

c. Temp. 

(°F) 

d. Air 

Flow Rate 

(acfm) 

Applicable 

Requirement 

SVCSTOVE 210 129 750 NA R336.1225, 40 

CFR 52.21(c) & 

(d) 

C. Other Design Parameters 

NA 

II. MATERIAL USAGE/EMISSION LIMITS 

A. Material Maximum Usage Rate 

NA NA 

B. Pollutant Maximum Emission Limit

1. NOx 1. 106.3 lb/hr (R336.1205(1)(a) & (b)) 

2. 439.18 ton/12-month rolling period (R336.1205(1)(a) & (b))

2. SO2 1. 275.1 lb/hr 1. (40 CFR 52.21(c) & (d), 40 CFR 52.21(j)) 

2. 1,096.1 ton/12-month rolling period (40 CFR 52.21(j)) 

3. CO 1. 2195.5 lb/hr (40 CFR 52.21(d) & (j)) 

2. 8760 ton/12-month rolling period. (40 CFR 52.21(d) & (j))

4. PM 14.16 lb/hr (40 CFR 52.21(b)(3), R336.1331)

5. PM-10 14.16 lb/hr (R336.1205(1)(a) & (b)) 

6. Mn 0.0154 lb/hr (R336.1225) 

7. Hg 0.000414 lb/hr (R336.1201(3), R336.1228, R336.1901) 

8. Pb 0.0141 lb/hr (40 CFR 52.21(d)) 

1

 This limit is based on a 24-hour average. 

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. 

A. MONITORING/RECORDKEEPING 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping 

Continuous emission monitor for SO2 emissions (R336.1205(1)(a) 

& (b), 40 CFR 52.21(c), (d), & (j)) 

2. Process Monitoring System 

and Recordkeeping 

1. The permittee shall install, calibrate, maintain and operate in a 

satisfactory manner a device to monitor and record the SO2 emissions 

from EUCFCESTOVE on a continuous basis. The permittee shall 

install and operate each CEM system to meet the timelines, 

requirements and reporting detailed in Appendix 1.3.1. and shall use 

the CEM data for determining compliance with Special Conditions 

II.B.2.1 and II.B.2.2 (R336.1205, 40 CFR 52.21 (c), (d), & (j))
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 29 of 83 

TABLE E-01.05 C BLAST FURNACE STOVE 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

2. The permittee shall keep, in a satisfactory manner, daily fuel usage 

records for FGB&CSTOVES. The permittee shall keep all records on 

file at the facility for a period of at least five years and make them 

available to the Department upon request. (R336.1205(1)(a) & (b), 

40 CFR 52.21(b)(3), (c), & (d)) 

3. Following the performance testing required in S.C. III.B.3.1 of this 

table, the permittee shall determine compliance with the emission limits 

in S.C. II.B.1.2 and II.B.3.2 of this table by establishing emission 

factors based upon the CFCE stove stack testing and applying these 

emission factors to the daily fuel usage recorded in S.C. III.A.2.2, as 

outlined in Appendix 1.7. (R336.1205(1)(a) & (b), 40 CFR 52.21 (d))

3. Other Monitoring and/or 

Recordkeeping 

NA 

B. TESTING/RECORDKEEPING 

1. Parameter to be Tested/ 

Recorded 

1. NOx 

2. SO2 

3. CO 

4. PM 

5. PM-10 

6. Mn 

7. Hg 

8. Pb 

2. Method/Analysis Approved method 

3. Frequency and Schedule of 

Testing/Recordkeeping 

1. Within 180 days after commencement of trial operation, verification of 

NOx, SO2, CO, PM, PM-10 Mn, Hg, and Pb emission rates from the 

C-Blast Furnace stove stack, by testing at owner's expense, in 

accordance with Department requirements, will be required. The 

permittee shall record the sulfur content of the coal and coke 

combusted in C blast furnace averaged over the duration of the test. 

No less than 60 days prior to testing, a complete test plan shall be 

submitted to the AQD. The final plan must be approved by the AQD 

prior to testing. Verification of emission rates includes the submittal 

of a complete report of the test results to the AQD within 60 days 

following the last date of the test. (R336.2001, R336.2003, 

R336.2004, 40 CFR 52.21(c) & (d), 40 CFR 52.21(j))

IV. REPORTING 

Reports and Schedules NA 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 30 of 83 

TABLE E-01.05 C BLAST FURNACE STOVE 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

V. OPERATIONAL PARAMETERS 

1. After completion of C-FCE modification, the permittee shall not operate EUCFCESTOVE unless the lowNOx technology is installed, maintained, and operated in a satisfactory manner. (R336.1205(1)(a) & (b), 

R336.1910)

2. The permittee shall not fire blast furnace gas in EUCFCESTOVE unless the venturi scrubber and 

mechanical collector for pre-combustion gas cleaning are installed, maintained, and operated in a 

satisfactory manner. (R336.1205(1)(a) & (b), R336.1910, 40 CFR 52.21(b)(3)) 

VI. OTHER REQUIREMENTS 

1. The permittee shall maintain a complete copy of the coke analysis, including the sulfur content, as supplied 

by the coke vendor, for each shipment of coke. All records shall be kept on file for a period of at least five 

years and made available to the Department upon request. (R336.1225, 40 CFR 52.21(c) & (d))

2. The permittee shall maintain a complete copy of the coal analysis, including the sulfur content, as supplied 

by the coal vendor, for each shipment of coal. All records shall be kept on file for a period of at least five 

years and made available to the Department upon request. (R336.1225, 40 CFR 52.21(c) & (d))
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 31 of 83 

TABLE E-01.06 RELADLING - BOF 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

EMISSION GROUP EURELADLINGBOF (includes South and North Reladling) 

Flexible Grouping ID NA 

I. DESIGN PARAMETERS 

A. Pollution Control 

Equipment 

Baghouse 

B. Stack/Vent Parameters NA 

Stack/Vent ID a. Minimum 

Height 

(feet) 

b. Maximum 

Exhaust Dimension 

(inches) 

c. Temp. 

(°F) 

d. Air 

Flow Rate 

(acfm) 

Applicable 

Requirement 

SVBOFBH (After C-FCE 

modification) 

200 222 150 1,000,000 R336.1225 

SVRELADLEBAG (until CFCE modification) 27 69 175 130,000 R336.1225 

C. Other Design Parameters 

NA 

II. MATERIAL USAGE/EMISSION LIMITS 

A. Material Maximum Usage Rate 

NA NA 

B. Pollutant Maximum Emission Limit

1. Opacity from hot metal transfer 

operation stack. 

20% R336.1365(1)

2. Opacity from fugitive 

emissions from hot metal transfer 

operation building or enclosure. 

20% R336.1365(2) and 40 CFR 63.7790(a)(Table 1, Item 12) 

 

3. PM 1. 0.01 grain per dry standard cubic foot from the reladling south 

baghouse prior to C-FCE modification (40 CFR 63.7790(a)(Table 1, 

Item 10), R336.1331) 

2. 6.31 ton per 12 month rolling time period from the roof monitors 

(40 CFR 52.21(b)(3))

4. PM10 1. 3.22 ton per 12 month rolling time period from the roof monitors 

(R336.1205(1)(a) & (b)) 

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. 

A. MONITORING/RECORDKEEPING 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping 

NA 

2. Process Monitoring System 

and Recordkeeping 

3. Other Monitoring and/or 

Recordkeeping 

1. The permittee shall maintain a copy of each notification and report 

submitted under 40 CFR Part 63, Subpart FFFFF, including all 

documentation supporting the initial notification or notification of 

compliance status submitted according to 40 CFR 63.10(b)(2)(xiv)). 

 (40 CFR 63.7842(a)(1)) 

2. The permittee shall maintain the records required for startup, shutdown 

and malfunction under 63.6(e)(3)(iii) through (v). 

(40 CFR 63.7842(a)(2)) 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 32 of 83 

TABLE E-01.06 RELADLING - BOF 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

3. The permittee shall maintain records associated with performance tests 

and performance evaluations as required by 40 CFR 63.10(b)(2)(viii). 

 (40 CFR 63.7842(a)(3)) 

4. Except as allowed in S.C. 7, permittee shall install, operate, and 

maintain a bag leak detection system meeting the following 

specifications on the baghouse control: 

 (40 CFR 63.7831(f)) 

a. Certified by the manufacturer to be capable of detecting emissions 

of particulate matter at concentrations of 10 milligrams per actual 

cubic foot (0.0044 grains per actual cubic foot). (40 CFR 

63.7831(f)(1)) 

b. Provides output of relative changes in particulate matter loadings. 

(40 CFR 63.7831(f)(2)) 

c. Is equipped with an alarm, located such that it is heard by 

appropriate plant personnel, that sounds an alarm when an increase 

in relative particulate loadings is detected over a preset level. (40 

CFR 63.7831(f)(3)) 

d. Initially adjusted by establishing the baseline output by adjusting 

the sensitivity (range) and the averaging period of the device and 

setting the alarm set points and alarm delay time. (40 CFR 

63.7831(f)(5)) 

5. Following the initial adjustment of the bag leak detection system, the 

permittee shall not adjust the sensitivity or range, averaging period, 

alarm set points or alarm delay time except as specified in the 

operation and maintenance plan. This requirement does not apply if 

the permittee installs a COMS as specified in S.C. 7. (40 CFR 

63.7831(f)(6))

6. If the sensitivity of the bag leak detection system is changed beyond the 

limits established pursuant to 40 CFR 63.7831(f)(6), a copy of a written 

certification by a responsible official shall be included in the 

semiannual compliance report for that period. This requirement does 

not apply if the permittee installs a COMS as specified in S.C. 7. (40 

CFR 63.7833(c)(2))

7. If permittee does not install and operate a bag leak detection system, 

the permittee shall install, operate, and maintain a COMS according to 

the requirements in 40 CFR Sec. 63.7831(h) and monitor the hourly 

average opacity of emissions exiting each control device stack 

according to the requirements in 40 CFR 63.7832. (40 CFR 63.7832)

8. The permittee shall monitor the pressure drop across the baghouse 

compartment daily to ensure that the pressure drop is within the normal 

operating range identified in the manual. (40 CFR 63.7830(b)(1)) 

9. The permittee shall confirm that dust is being removed from hoppers on 

a weekly basis through visual observations or other means of 

determining the proper functioning of the removal mechanisms. 

(40 CFR 63.7830(b)(2)) 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 33 of 83 

TABLE E-01.06 RELADLING - BOF 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

10. The permittee shall perform monthly visual checks of bag tension on 

the shaker-type baghouse to ensure that bags are not kinked (kneed or 

bent) or lying on their sides. If the shaker-type baghouse uses selftensioning (spring-loaded) devices, the visual checks are not required. 

 (40 CFR 63.7830(b)(6)) 

11. The permittee shall monitor the cleaning cycles of the baghouse to 

ensure proper operation using appropriate technology. 

(40 CFR 63.7830(b)(4) 

12. The permittee shall check the bag cleaning mechanisms for proper 

functioning through monthly visual inspections or equivalent means. 

 (40 CFR 63.7830(b)(5)) 

13. The permittee shall inspect the baghouse to confirm the physical 

integrity of the baghouse through quarterly inspections of the interior of 

the baghouse for air leaks. (40 CFR 63.7830(b)(7)) 

14. The permittee shall inspect fans for wear, material buildup, and 

corrosion on a quarterly basis using visual inspections, vibration 

detectors, or equivalent means. (40 CFR 63.7830(b)(8)) 

15. The permittee shall monitor the process as required by this table, except 

during monitoring malfunctions, out-of-control periods, associated 

repairs, and required quality assurance or control activities (including 

calibration checks and required zero and span adjustments). (40 CFR 

63.7832(a)) 

16. Data recorded during monitoring malfunctions, associated repairs, and 

required quality assurance or control activities shall not be used in data 

averages and calculations used to report emission or operating levels or 

to fulfill minimum data availability requirements. (40 CFR 63.7832(b))

17. Using the method shown in Appendix 1.7, the permittee shall calculate 

and record by the end of each calendar month the following from the 

BOF roof monitors:

 a. emissions of PM 

 b. emissions of PM-10 (R336.1205(1)(a) & (b), 40 CFR 52.21(b)(3)) 

18. The permittee shall keep a daily record of the amount of iron 

throughput to the Reladling South and North Operations. 

(R336.1205(1)(a) & (b), R336.1225)

B. TESTING/RECORDKEEPING 

1. Parameter to be Tested/ 

Recorded 

1. Opacity 

2. PM 

2. Method/Analysis Approved Method 

3. Frequency and Schedule of 

Testing/Recordkeeping 

1. Sampling during the performance tests will occur only when the 

operations being controlled are in operation. (40 CFR 63.7822(h)) 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 34 of 83 

TABLE E-01.06 RELADLING - BOF 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

2. The permittee shall maintain records of the time corrective action was 

initiated, the corrective action taken, and the date when corrective 

actions were completed in response to a bag leak detection system 

alarm. (40 CFR 63.7842(d) and 40 CFR 63.7833(c)(1)) 

3. The permittee shall demonstrate compliance with the opacity limitation 

in II.B.2. with a certified observer of Method 9 visible emissions using 

Method 9 with the following exceptions: (40 CFR 63.7823(d)(1)(i))

a. Record observations to the nearest 5 percent at 15-second intervals 

for at least three steel production cycles rather than using the 

procedure specified in Section 2.4 of Method 9. 

(40 CFR 63.7823(d)(1)(ii)) 

b. Determine the 3-minute block average opacity from the average of 

12 consecutive observations recorded at 15-second intervals. (40 

CFR 63.7823(d)(1)(iii)) 

4. Performance tests for visible emissions shall be conducted such that 

the opacity observations overlap with the performance tests for 

particulate. (40 CFR 63.7823(b))

5. Permittee shall conduct performance tests for particulate matter 

emissions and opacity at least once per permit term. (40 CFR 

63.7821)

IV. REPORTING 

Reports and Schedules 1. Permittee shall submit a notification of intent to perform any 

performance testing under 40 CFR Part 63, Subpart FFFFF at least 60 

calendar days before testing is to begin. (40 CFR 63.7840(d))

2. When actions taken by the permittee during a startup, shutdown, or 

malfunction of an affected source (including actions taken to correct a 

malfunction) are not consistent with the procedures in the startup, 

shutdown, and malfunction plan, the permittee shall comply with the 

requirements of 63.10(d)(5)(ii). (40 CFR Part 63.7841(c))

V. OPERATIONAL PARAMETERS 

1. The Reladling South Operation and the associated baghouse shall be operated and maintained in a manner 

consistent with good air pollution control practices for minimizing emissions at least to the levels required 

by 40 CFR Part 63, Subpart FFFFF. (40 CFR 63.7800(a) and 40 CFR 63.6(e)(1)(i)) 

2. The permittee shall develop and implement a written startup, shutdown and malfunction plan for the 

Reladling South Operation and the associated emission control system and operate in accordance with the 

plan during periods of startup, shutdown, and malfunction. 

 (40 CFR 63.7810(c), 40 CFR 63.7835(b), and 40 CFR 63.6(e)(3))

3. Until the modification of C-FCE, the permittee shall not operate Reladling South Operation unless the 

baghouse dust collector is installed, maintained, and operated in a satisfactory manner. After modification of 

C-FCE, the permittee shall not operate Reladling South Operation unless the emissions are directed to the 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 35 of 83 

TABLE E-01.06 RELADLING - BOF 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

BOF baghouse secondary dust collector and the BOF baghouse secondary dust collector is installed, 

maintained, and operated in a satisfactory manner. (R336.1205(1)(a) & (b), R336.1225, R336.1910, 

40 CFR 52.21(b)(3))

4. Upon rerouting the Reladling South Operations exhaust to the BOF baghouse secondary dust collector, 

Special Conditions II.B.1, II.B.3.1, III.A.3.4 through III.A.3.16, and III.B.1.2 of this table shall no longer 

apply. Thereafter the permittee shall comply with the identical or more stringent emission, monitoring, 

testing, and recordkeeping requirements of Table F-01.03 that supersede the above Special Conditions. (40 

CFR 63 Subpart FFFFF)

5. The permittee shall not use the Reladling North Operations (i.e. the North Hole) of the Basic Oxygen 

Furnace Shop for emergency hot metal transfer, hot metal desulfurization, or beaching of molten iron, 

without installation and operation of appropriate control technology which prevents emissions in excess of 

the applicable Michigan SIP Rule or additional requirements that are promulgated under Section 112 of the 

Clean Air Act, 42 U.S.C. Section 7412, or are incorporated in a permit. (USEPA Civil Action 

Nos. 0075452 and 0075454 Consent Decree, Paragraph 16) 

6. Unless necessary for emergency, health or safety reasons, including to allow for safe shutdown of 

operations, the permittee shall not use the North Hole of the Basic Oxygen Furnace Shop for emergency hot 

metal transfer, hot metal desulfurization, or beaching of molten iron, without installation and operation of 

appropriate control technology which prevents emissions in excess of the applicable Michigan SIP Rule or 

additional requirements that are promulgated under Section 112 of the Clean Air Act, 42 U.S.C. Section 

7412, or are incorporated in a permit. If the North Hole is used for emergency reasons, the permittee shall 

report any such use in its next semiannual report. The report shall include the following information for 

each such prohibited use of the North Hole without the appropriate control technology:

 a. date 

 b. start time 

 c. stop time 

 d. duration of use 

 e. reason for use. 

 (R336.1201(3)) 

7. Upon routing the Reladling North Operations exhaust to the new BOF baghouse secondary dust collector, 

the permittee may utilize the Reladling North Operations in compliance with the applicable requirements of 

Table E-01.06, and with the emission, monitoring, testing, and recordkeeping requirements of Table F-01.03 

(40 CFR 63 Subpart FFFFF)

VI. OTHER REQUIREMENTS 

1. The permittee shall comply with the emission limitations and operation and maintenance requirements from 

40 CFR Part 63, Subpart FFFFF specified in Table E-01.06, except during periods of startup, shutdown and 

malfunction. (40 CFR 63.7810(a)) 

2. Records required under 40 CFR Part 63, Subpart FFFFF and specified in this table shall be retained for five 

years. The records must be maintained onsite for the two most recent years of the five year period. Records 

from the remaining three years of the five year period may be keep offsite. (40 CFR 63.7843(b) and (c))
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 36 of 83 

TABLE E-01.07 DESULFURIZATION OPERATION 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

EMISSION GROUP EUDESULFURIZATION 

Flexible Grouping ID NA 

I. DESIGN PARAMETERS 

A. Pollution Control 

Equipment 

Baghouse 

B. Stack/Vent Parameters NA 

Stack/Vent ID a. Minimum 

Height 

(feet) 

b. Maximum 

Exhaust Dimension 

(inches) 

c. Temp. 

(°F) 

d. Air 

Flow Rate 

(acfm) 

Applicable 

Requirement 

SVDESULF 37 66 225 94,500 R336.1225 

C. Other Design Parameters 

NA 

II. MATERIAL USAGE/EMISSION LIMITS 

A. Material Maximum Usage Rate 

 

B. Pollutant Maximum Emission Limit

1. Opacity from desulfurization 

stack. 

20% (R336.1366(1))

2. Opacity from fugitive 

emissions from desulfurization 

operations. 

20% (R336.1366(2)) 

3. Opacity from BOF Shop 

Building 

20% (three minute average) (40 CFR 63.7790(a)(Table 1, Item 12))

4. PM 1. 0.01 grain per dry standard cubic foot from baghouse (40 CFR 

52.21(b)(3), 40 CFR 63.7790(a)(Table 1, Item 10), R336.1331) 

2. 2.09 lb/hr from baghouse (40 CFR 52.21(b)(3)) 

3. 36.2 ton per 12-month rolling time period from roof monitors (40 

CFR 52.21(b)(3))

5. PM10 1. 0.0074 grain per dry standard cubic foot from baghouse 

(R336.1205(1)(a) & (b)) 

2. 1.55 lb/hr from baghouse (R336.1205(1)(a) & (b)) 

3. 6.88 ton per 12-month rolling time period from roof monitors 

(R336.1205(1)(a) & (b))

6. Manganese 1. 0.00064 lb/hr from baghouse stack (R336.1225) 

7. Pb 1. 0.000278 lb/hr from baghouse stack (40 CFR 52.21(d)) 

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. 

A. MONITORING/RECORDKEEPING 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping 

NA 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 37 of 83 

TABLE E-01.07 DESULFURIZATION OPERATION 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

2. Process Monitoring System 

and Recordkeeping 

NA 

3. Other Monitoring and/or 

Recordkeeping 

1. The permittee shall maintain a copy of each notification and report 

submitted under 40 CFR Part 63, Subpart FFFFF, including all 

documentation supporting the initial notification or notification of 

compliance status submitted according to 40 CFR 63.10(b)(2)(xiv)). 

(40 CFR 63.7842(a)(1))

2. The permittee shall maintain the records required for startup, shutdown 

and malfunction under 63.6(e)(3)(iii) through (v). 

(40 CFR 63.7842(a)(2))

3. The permittee shall maintain records associated with performance tests 

and performance evaluations as required by 40 CFR 63.10(b)(2)(viii). 

(40 CFR 63.7842(a)(3)) 

4. Except as allowed in S.C. 7, permittee shall install, operate, and 

maintain a bag leak detection system meeting the following 

specifications on the baghouse control: (40 CFR 63.7831(f)) 

a. Certified by the manufacturer to be capable of detecting emissions 

of particulate matter at concentrations of 10 milligrams per actual 

cubic foot (0.0044 grains per actual cubic foot). (40 CFR 

63.7831(f)(1))

b. Provides output of relative changes in particulate matter loadings. 

(40 CFR 63.7831(f)(2)) 

c. Is equipped with an alarm, located such that it is heard by 

appropriate plant personnel, that sounds an alarm when an increase 

in relative particulate loadings is detected over a preset level. (40 

CFR 63.7831(f)(3)) 

d. Initially adjusted by establishing the baseline output by adjusting 

the sensitivity (range) and the averaging period of the device and 

setting the alarm set points and alarm delay time. (40 CFR 

63.7831(f)(5))

5. Following the initial adjustment of the bag leak detection system, the 

permittee shall not adjust the sensitivity or range, averaging period, 

alarm set points or alarm delay time except as specified in the 

operation and maintenance plan. This requirement does not apply if 

the permittee installs a COMS as specified in S.C. 7. (40 CFR 

63.7831(f)(6))

6. If the sensitivity of the bag leak detection system is changed beyond the 

limits established pursuant to 40 CFR 63.7831(f)(6), a copy of a written 

certification by a responsible official shall be included in the 

semiannual compliance report for that period. This requirement does 

not apply if the permittee installs a COMS as specified in S.C. 7. (40 

CFR 63.7833(c)(2))
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TABLE E-01.07 DESULFURIZATION OPERATION 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

7. If permittee does not install and operate a bag leak detection system, the 

permittee shall install, operate, and maintain a COMS according to the 

requirements in 40CFR Sec. 63.7831(h) and monitor the hourly average 

opacity of emissions exiting each control device stack according to the 

requirements in 40 CFR 63.7832. (40 CFR 63.7832)

8. The permittee shall monitor the pressure drop across each baghouse 

compartment daily to ensure that the pressure drop is within the normal 

operating range identified in the manual. (40 CFR 63.7830(b)(1)) 

9. The permittee shall confirm that dust is being removed from hoppers on 

a weekly basis through visual observations or other means of 

determining the proper functioning of the removal mechanisms. 

 (40 CFR 63.7830(b)(2)) 

10. The permittee shall perform monthly visual checks of bag tension on 

the shaker-type baghouse to ensure that bags are not kinked (kneed or 

bent) or lying on their sides. If the shaker-type baghouse uses selftensioning (spring-loaded) devices, the visual checks are not required. 

 (40 CFR 63.7830(b)(6)) 

11. The permittee shall monitor the cleaning cycles of the baghouse to 

ensure proper operation using appropriate technology. 

(40 CFR 63.7830(b)(4)) 

12. The permittee shall check the bag cleaning mechanisms for proper 

functioning through monthly visual inspections or equivalent means. 

 (40 CFR 63.7830(b)(5)) 

13. The permittee shall inspect the baghouse to confirm the physical 

integrity of the baghouse through quarterly inspections of the interior of 

the baghouse for air leaks. (40 CFR 63.7830(b)(7)) 

14. The permittee shall inspect fans for wear, material buildup, and 

corrosion on a quarterly basis using visual inspections, vibration 

detectors, or equivalent means. (40 CFR 63.7830(b)(8))

15. The permittee shall monitor the process as required by this table, except 

during monitoring malfunctions, out-of-control periods, associated 

repairs, and required quality assurance or control activities (including 

calibration checks and required zero and span adjustments). (40 CFR 

63.7832(a)) 

16. Data recorded during monitoring malfunctions, associated repairs, and 

required quality assurance or control activities shall not be used in data 

averages and calculations used to report emission or operating levels or 

to fulfill minimum data availability requirements. (40 CFR 7832(b))
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Permit No. 182-05B Page 39 of 83 

TABLE E-01.07 DESULFURIZATION OPERATION 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

17. The permittee shall obtain an analysis of the Desulfurization baghouse 

dust once per calendar month during the 1st year after the modification 

of C blast furnace and quarterly thereafter, or less frequently if 

approved in writing by the Air Quality Division. The analysis shall 

determine the percentage of Pb and Mn in the collected PM dust from 

the baghouse. The permittee shall submit an acceptable protocol for 

baghouse dust sampling and analysis methods to the Air Quality 

Division, at least 60 days prior the initial performance emission test. 

(R336.1225, R336.1228, 40 CFR 52.21(b)(3)) 

18. Using the method shown in Appendix 1.7, the permittee shall calculate 

and record by the end of each calendar month the following from the 

BOF roof monitors:

a. emissions of PM 

b. emissions of PM-10 (R336.1205(1)(a) & (b), 40 CFR 52.21(b)(3))

19. The permittee shall keep a daily record of the amount of iron 

throughput to the Desulfurization Operations. (R336.1205(1)(a) & (b), 

R336.1225) 

B. TESTING/RECORDKEEPING 

1. Parameter to be Tested/ 

Recorded 

1. Opacity 

2. PM 

3. PM-10 

4. Mn 

5. Pb 

2. Method/Analysis Approved method. 

3. Frequency and Schedule of 

Testing/Recordkeeping 

1. Sampling during the performance tests will occur only when the 

operations being controlled are in operation. (40 CFR 63.7822(h))

2. The permittee shall maintain records of the time corrective action was 

initiated, the corrective action taken, and the date when corrective 

actions were completed in response to a bag leak detection system 

alarm. (40 CFR 63.7842(d) and 40 CFR 63.7833(c)(1)) 

3. The permittee shall demonstrate compliance with the opacity limitation 

in II.B.3. with a certified observer of Method 9 visible emissions using 

Method 9 with the following exceptions: (40 CFR 63.7823(d)(1)(i))

a. Record observations to the nearest 5 percent at 15-second intervals 

for at least three steel production cycles rather than using the 

procedure specified in Section 2.4 of Method 9. 

(40 CFR 63.7823(d)(1)(ii)) 

b. Determine the 3-minute block average opacity from the average of 

12 consecutive observations recorded at 15-second intervals. (40 

CFR 63.7823(d)(1)(iii)) 
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Permit No. 182-05B Page 40 of 83 

TABLE E-01.07 DESULFURIZATION OPERATION 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

4. Performance tests for visible emissions shall be conducted such that 

the opacity observations overlap with the performance tests for 

particulate. (40 CFR 63.7823(b))

5. Within 60 days of achieving the maximum production rate, but not later 

than 180 days after commencement of trial operation, the permittee 

shall verify and quantify Mn and Pb emission rates from the 

desulfurization operation and the ratio of Mn and Pb concentrations in 

the baghouse dust to the actual amount of Mn and Pb emitted from the 

desulfurization operation, by testing at owner's expense, in accordance 

with Department requirements. No less than 60 days prior to testing, 

the permittee shall submit a complete test plan to the AQD. The AQD 

must approve the final plan prior to testing. Verification of emission 

rates includes the submittal of a complete report of the test results to the 

AQD within 60 days following the last date of the test. (R336.1225, 

R336.1228, R336.2001, R336.2003, R336.2004, 40 CFR 52.21(b)(3)) 

6. Within 180 days after commencement of trial operation, the permittee 

shall verify PM and PM10 emission rates from the Desulfurization 

operation by testing at owner's expense, in accordance with Department 

requirements. No less than 60 days prior to testing, the permittee shall 

submit a complete test plan to the AQD. The AQD must approve the 

final plan prior to testing. Verification of emission rates includes the 

submittal of a complete report of the test results to the AQD within 60 

days following the last date of the test. (R336.1205(1)(a) & (b), 

R336.2001, R336.2003, R336.2004, 40 CFR 52.21(b)(3)) 

7. Permittee shall conduct performance tests for particulate matter 

emissions and opacity at least once per permit term. (40 CFR 

63.7821)

IV. REPORTING 

Reports and Schedules 1. Permittee shall submit a notification of intent to perform any 

performance testing under 40 CFR Part 63, Subpart FFFFF at least 60 

calendar days before testing is to begin. (40 CFR 63.7840(d))

2. When actions taken by the permittee during a startup, shutdown, or 

malfunction of an affected source (including actions taken to correct a 

malfunction) are not consistent with the procedures in the startup, 

shutdown, and malfunction plan, the permittee shall comply with the 

requirements of 63.10(d)(5)(ii). (40 CFR Part 63.7841(c))

V. OPERATIONAL PARAMETERS 

1. The permittee shall operate and maintain the desulfurization control system in a manner as to control 

emissions from the desulfurization operation in compliance with the opacity limits. (R336.1910) 

2. The Desulfurization Operation and the associated baghouse shall be operated and maintained in a manner 

consistent with good air pollution control practices for minimizing emissions at least to the levels required 

by 40 CFR Part 63, Subpart FFFFF. (40 CFR 63.7800(a) and 40 CFR 63.6(e)(1)(i)) 
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TABLE E-01.07 DESULFURIZATION OPERATION 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

 

3. The permittee shall develop and implement a written startup, shutdown and malfunction plan for the 

Desulfurization Operation and the associated emission control system and operate in accordance with the 

plan during periods of startup, shutdown, and malfunction. (40 CFR 63.7810(c), 40 CFR 63.7835(b), and 

40 CFR 63.6(e)(3)) 

 

4. The permittee shall not operate the Desulfurization Operation unless the baghouse dust collector is installed, 

maintained, and operated in a satisfactory manner. (R336.1205(1)(a) & (b), R336.1225, R336.1910, 40 

CFR 52.21(b)(3)) 

VI. OTHER REQUIREMENTS 

1. The permittee shall comply with the emission limitations and operation and maintenance requirements from 

40 CFR Part 63, Subpart FFFFF specified in Table E-01.07, except during periods of startup, shutdown and 

malfunction. (40 CFR 63.7810(a)) 

2. Records required under 40 CFR Part 63, Subpart FFFFF and specified in this table shall be retained for five 

years. The records must be maintained onsite for the two most recent years of the five year period. Records 

from the remaining three years of the five year period may be keep offsite. (40 CFR 63.7843(b) and (c))
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 42 of 83 

TABLE E-01.08 BASIC OXYGEN FURNACE (BOF) 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

EMISSION GROUP EUBOF 

Flexible Grouping ID NA 

I. DESIGN PARAMETERS 

A. Pollution Control 

Equipment 

Electrostatic Precipitator, Baghouse 

B. Stack/Vent Parameters NA 

Stack/Vent ID a. 

Minimum 

Height 

(feet) 

b. Maximum 

Exhaust Dimension 

(inches) 

c. 

Temp. 

(°F) 

d. Air Flow 

Rate 

(acfm) 

Applicable 

Requirement 

SVBOFESP 213 204 300 841,000 R336.1225 

SVBOFBH 200 222 150 1,000,000 R336.1225 

C. Other Design Parameters 

1. Permittee shall not operate the basic oxygen furnace (BOF) controlled by an electrostatic precipitator 

control system unless each transformer-rectifier set of the electrostatic precipitator is equipped with a 

saturable core reactor, silicon-controlled rectifier linear reactor, or equivalent type automatic control system 

approved by the AQD District Supervisor. (R336.1330(1))

2. Each automatic controller shall be set to provide maximum power, or optimal power if operating in a 

sparking mode, from its respective transformer-rectifier set. (R336.1330(1))

3. Each transformer-rectifier set shall be capable of operating in a spark-limited mode and shall meter and 

display the primary RMS voltage and amperage, the average secondary amperage, and the average spark 

rate. (R336.1330(2)) 

II. MATERIAL USAGE/EMISSION LIMITS 

A. Material Maximum Usage Rate 

NA NA 

B. Pollutant Maximum Emission Limit

1. PM. 1. 0.0152 gr/dscf from ESP stack (R336.1331, 40 CFR 63.7790(a), 

40 CFR 52.21(b)(3)) 

2. 50.94 lb/hr from ESP stack (40 CFR 52.21(b)(3)) 

 

3. 15.88 ton per 12-month rolling time period from roof monitors 

(40 CFR 52.21(b)(3) 

2. PM-10. 1. 0.0113 gr/dscf from ESP stack (R336.1205(1)(a) & (b)) 

2. 37.70 lb/hr from ESP stack (R336.1205(1)(a) & (b)) 

3. 7.25 ton per 12-month rolling time period from roof monitors 

(R336.1205(1)(a) & (b) 

3. Opacity from roof monitors 20% (R336.1364(2))

4. Opacity from BOF Shop 

Building 

20% (3 minute average) 

 (R336.1364(2), (40 CFR 63.7790(a)) 

5. Opacity from ESP stack No greater than 10% on an hourly average basis (40 CFR 63.7790(b)(3)) 

6. NOx 1. 52.94 lb/hr from the ESP stack. (R336.1205(1)(a) & (b)) 

7. CO 1. 3,057.4 lb/hr from ESP stack (40 CFR 52.21(d)) 
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TABLE E-01.08 BASIC OXYGEN FURNACE (BOF) 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. 

A. MONITORING/RECORDKEEPING 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping 

1. Continuous opacity monitor on ESP stack. 

(R36.1301(1)(c), 40 CFR 63.7830(d)) 

2. Process Monitoring System 

and Recordkeeping 

1. The permittee shall install, operate and maintain a continuous opacity 

monitor on the ESP stack and monitor the hourly average opacity of the 

stack continuously when the process is in operation. The COMS shall 

provide valid 1 hour averages for at least 95 percent of process 

operating hours for every quarterly reporting period. The permittee shall 

operate the COM system to meet the timelines, requirements and 

reporting detailed in Appendix 1.3.2. (R336.1301(1)(c), 

40 CFR 63.7830(d), 40 CFR 63.7831(h), and 40 CFR 63.7832(a)) 

2. Data recorded during monitoring malfunctions, associated repairs, and 

required quality assurance or control activities shall not be used in data 

averages and calculations used to report emission or operating levels or 

to fulfill minimum data availability requirements. All other data 

collected during all other periods must be used in assessing compliance. 

(40 CFR 63.7832(b)) 

3. Other Monitoring and/or 

Recordkeeping 

1. Prior to installation of the BOF secondary emissions collection 

baghouse, the permittee shall perform a Method 9 certified visible 

emission observation of roof monitors at least once a week during BOF 

operation for a minimum of one complete heat. After installation of the 

BOF secondary emissions collection baghouse, the permittee shall 

perform non-certified visible emission observation for the BOF roof 

monitors (including reladling and desulfurization operations) at least 

once a week during BOF operations and a Method 9 certified visible 

emission observation of the BOF roof monitors (including reladling 

and desulfurization operations) at least once every month during BOF 

operations. The permittee shall initiate corrective action upon 

observation of visible emissions in excess of the applicable visible 

emission limitation and shall keep a written record of each required 

observation and corrective action taken. (R336.1364(2)) 

2. The permittee shall maintain a copy of each notification and report 

submitted under 40 CFR Part 63, Subpart FFFFF, including all 

documentation supporting the initial notification or notification of 

compliance status submitted according to 40 CFR 63.10(b)(2)(xiv)). 

(40 CFR 63.7842(a)(1)) 

3. The permittee shall maintain the records required for startup, shutdown 

and malfunction under 63.6(e)(3)(iii) through (v). (40 CFR 

63.7842(a)(2))

4. The permittee shall maintain records associated with performance tests, 

performance evaluations, and opacity observations as required by 40 

CFR 63.10(b)(2)(viii). (40 CFR 63.7842(a)(3)) 
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TABLE E-01.08 BASIC OXYGEN FURNACE (BOF) 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

5. The permittee shall maintain records of the following for the 

continuous opacity monitor: 

a. Periods when the monitor is malfunctioning or inoperative; 

(40 CFR 63.7842(b)(1) and 40 CFR 63.10(b)(2)(vi)) 

b. All required measurements necessary to demonstrate compliance 

with a standard (including, but not limited to, 15-minute averages 

of monitoring data, raw performance testing measurements, and 

raw performance evaluation measurements, that support data that 

the source is required to report); (40 CFR 63.7842(b)(1) and 40 

CFR 63.10(b)(2)(vii))

c. All results of performance tests, monitor performance evaluations 

and opacity and visible emission observations; 

 (40 CFR 63.7842(b)(1) and 40 CFR 63.10(b)(2)(viii))

d. All measurements necessary to determine the conditions of 

performance tests and evaluations; (40 CFR 63.7842(b)(1), 

40 CFR 63.10(b)(2)(ix)) 

e. All monitor calibration checks; (40 CFR 63.7842(b)(1) and 

40 CFR 63.10(b)(2)(x)) 

f. All adjustments and maintenance performed on the continuous 

monitor; (40 CFR 63.7842(b)(1) and 40 CFR 63.10(b)(2)(xi)) 

g. Monitoring data produced during performance testing; (40 CFR 

63.7842(b)(2)) 

h. Superceded versions of the performance evaluation plan; and (40 

CFR 63.7842(b)(3) and 40 CFR 63.8(d)(3)) 

i. The date and time each deviation started and stopped and whether 

the deviation occurred during a period of startup, shutdown, 

malfunction, or during another period. (40 CFR 63.7842(b)(4)) 

6. The permittee shall perform preventative maintenance on the ESP as 

specified in the operation and maintenance plan for the ESP. 

 (40 CFR 63.7834(a)(2)) 

7. The permittee shall comply with the recordkeeping requirement as 

specified in 40 CFR Part 63 Subpart FFFFF 63.7842(a), (b), (c) and 

(d). (40 CFR 63.7842(a), (b), (c) and (d))

8. The permittee shall monitor the process as required by this table, except 

during monitoring malfunctions, out-of-control periods, associated 

repairs, and required quality assurance or control activities (including 

calibration checks and required zero and span adjustments). (40 CFR 

63.7832(a))

 

9. Data recorded during monitoring malfunctions, associated repairs, and 

required quality assurance or control activities shall not be used in data 

averages and calculations used to report emission or operating levels or 

to fulfill minimum data availability requirements. 

(40 CFR 63.7832(b)) 
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TABLE E-01.08 BASIC OXYGEN FURNACE (BOF) 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

10. The permittee shall keep 12-month rolling time period records of the 

amount of scrap and fragmented scrap charged to the BOF. The 

permittee shall keep all records on file at the facility for a period of at 

least five years and make them available to the Department upon 

request. (R336.1201(3), R336.1225, R336.1228, R336.1901) 

11. The permittee shall obtain an analysis of the BOF ESP dust once per 

calendar month during the 1st year after the modification of C blast 

furnace and quarterly thereafter, or less frequently if approved in 

writing by the Air Quality Division. The analysis shall determine the 

percentage of Pb, Hg, and Mn in the collected PM dust from the ESP. 

The permittee shall submit an acceptable protocol for baghouse dust 

sampling and analysis methods to the Air Quality Division, at least 60 

days prior the initial performance emission test. (R336.1225, 

R336.1228, 40 CFR 52.21(d)) 

12. Using the method shown in Appendix 1.7, the permittee shall calculate 

and record by the end of each calendar month the following from the 

BOF roof monitors: 

a. emissions of PM 

b. emissions of PM-10 (R336.1205(1)(a) & (b), 40 CFR 52.21(b)(3))

13. The permittee shall keep a daily record of the amount of steel produced 

in the Basic Oxygen Furnace. (R336.1205(1)(a) & (b), R336.1225)

B. TESTING/RECORDKEEPING 

1. Parameter to be Tested/ 

Recorded 

1. Opacity 

2. PM 

3. PM-10 

4. NOx 

5. CO 

2. Method/Analysis Approved method. 

3. Frequency and Schedule of 

Testing/Recordkeeping 

1. The permittee shall demonstrate compliance with the opacity limitation 

for the BOF Shop Building in II.B.4. with a certified observer of 

Method 9 visible emissions using Method 9 with the following 

exceptions: (40 CFR 63.7823(d)(1)(i)) 

a. Record observations to the nearest 5 percent at 15-second 

intervals for at least three steel production cycles rather than using 

the procedure specified in Section 2.4 of Method 9. (40 CFR 

63.7823(d)(1)(ii))

b. Determine the 3-minute block average opacity from the average of 

12 consecutive observations recorded at 15-second intervals. (40 

CFR 63.7823(d)(1)(iii)) 
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TABLE E-01.08 BASIC OXYGEN FURNACE (BOF) 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

2. Opacity observations from the roof monitors must cover at least three 

steel production cycles. A production cycle begins when scrap is 

charged and ends three minutes after slag is emptied from the vessel 

into the slag pot. (40 CFR 63.7823(d)(4)) 

3. Permittee shall determine and record the starting and stopping times of 

the steel production cycle. (40 CFR 63.7823(d)(5))

4. The permittee shall maintain a copy of the current operation and 

maintenance plans required in this table onsite and available for 

inspection. (40 CFR 63.7834(b))

5. The permittee shall maintain records of the monitoring data from the 

continuous opacity monitor. (40 CFR 63.7842(d))

6. Within 180 days after commencement of trial operation, the permittee 

shall verify PM, PM10, NOx, and CO emission rates from the ESP 

stack by testing at owner's expense, in accordance with Department 

requirements. No less than 60 days prior to testing, the permittee shall 

submit a complete test plan to the AQD. The AQD must approve the 

final plan prior to testing. Verification of emission rates includes the 

submittal of a complete report of the test results to the AQD within 60 

days following the last date of the test. (R336.1205(1)(a) & (b), 

R336.2001, R336.2003, R336.2004, 40 CFR 52.21(b)(3), 40 CFR 

52.21(d)) 

7. Permittee shall conduct overlapping performance tests for particulate 

matter emissions and opacity from the BOF roof monitor at least twice 

per permit term. (40 CFR 63.7821) 

IV. REPORTING 

Reports and Schedules 1. Permittee shall report the results of the initial performance test in the 

notification of compliance status. (40 CFR 63.7820(a), 40 CFR 

63.7825(c) and 40 CFR 63.7840(e)) 

2. Permittee shall submit a notification of intent to perform any 

performance testing under 40 CFR Part 63, Subpart FFFFF at least 60 

calendar days before testing is to begin. (40 CFR 63.7840(d))

3. Any time an action taken by the permittee during a startup, shutdown, 

or malfunction of an affected source (including actions taken to correct 

a malfunction) is not consistent with the procedures in the startup, 

shutdown, and malfunction plan, the permittee shall comply with all 

requirements of 63.10(d)(5)(ii). (40 CFR Part 63.7841(c))

V. OPERATIONAL PARAMETERS 

1. The permittee shall not operate the Basic Oxygen Furnace unless the electrostatic precipitator (ESP) dust 

collector is installed and operating properly. (R336.1301, R336.1331(c), R336.1910)

2. After completion of C-FCE modification, the permittee shall not operate the Basic Oxygen Furnace unless 

the baghouse secondary emission dust collector is installed, maintained, and operated in a satisfactory 

manner. (R336.1205(1)(a) & (b), R336.1225, R336.1910, 40 CFR 52.21(b)(3))
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TABLE E-01.08 BASIC OXYGEN FURNACE (BOF) 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

3. The Basic Oxygen Furnace off-gas conditioning system which provides additional air-atomized water spray, 

shall be maintained as part of the off gas conditioning system. (R336.1910) 

4. The BOF vessels and ESP shall be operated and maintained in a manner consistent with good air pollution 

control practices for minimizing emissions at least to the levels required by 40 CFR Part 63, Subpart FFFFF. 

 (40 CFR 63.7800(a) and 40 CFR 63.6(e)(1)(i))

5. The permittee shall operate the BOF vessels and ESP according to an operation and maintenance plan that 

meets the requirements of 40 CFR 63.7800(b)(1)-(5). (40 CFR 63.7800(b) and 40 CFR 63.6(e)(3)) 

6. The permittee shall develop and implement a written startup, shutdown and malfunction plan for the BOF 

vessels and the associated emission control system. (40 CFR 63.7810(c), 40 CFR 63.7835(b) and 40 CFR 

63.6(e)(3)) 

7. The permittee shall not produce more than 12,200 tons of steel per day based on a calendar week average 

nor 4,052,230 tons of steel per 12-month rolling time period from the BOF (R336.1205(1)(a) & (b), 

R336.1225, 40 CFR 52.21(b)(3)) 

8. The permittee shall not charge more than 21,882 tons of fragmented scrap in the BOF per 12-month rolling 

time period. (R336.1201(3), R336.1228, R336.1901) 

VI. OTHER REQUIREMENTS 

1. The permittee shall comply with the emission limitations and operation and maintenance requirements from 

40 CFR Part 63, Subpart FFFFF specified in Table E-01.08, except during periods of startup, shutdown and 

malfunction. (40 CFR 63.7810(a)) 

2. Records required under 40 CFR Part 63, Subpart FFFFF and specified in this table shall be retained for five 

years. The records must be maintained onsite for the two most recent years of the five year period. Records 

from the remaining three years of the five year period may be keep offsite. (40 CFR 63.7843(b) and (c))

3. If the hourly average opacity of the electrostatic precipitator exceeds the operating limit in S.C. II.B.5, the 

permittee shall implement the following procedures: (40 CFR 63.7833(g))

a. Permittee shall initiate corrective action to determine the cause of the exceedance within 1 hour. During 

any period of corrective action, the permittee shall continue to monitor and record all required operating 

parameters for equipment that remains in operation. Within 24 hours of the exceedance, the permittee 

shall measure and record the hourly average operating parameter value for the emission unit on which 

corrective action was taken. If the hourly average parameter value meets the applicable operating limit, 

then the corrective action was successful and the emission unit is in compliance with the applicable 

operating limit. (40 CFR 63.7833(g)(1))

b. If the initial corrective action required in paragraph (a) of this condition was not successful, the 

permittee shall complete additional corrective action within the next 24 hours (48 hours from the time of 

the exceedance). During any period of corrective action, the permittee shall continue to monitor and 

record all required operating parameters for equipment that remains in operation. After this second 24-

hour period, the permittee shall again measure and record the hourly average operating parameter value 

for the emission unit on which corrective action was taken. If the hourly average parameter value meets 

the applicable operating limit, then the corrective action was successful and the emission unit is in 

compliance with the applicable operating limit. (40 CFR 63.7833(g)(2)) 
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TABLE E-01.08 BASIC OXYGEN FURNACE (BOF) 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

c. For purposes of paragraphs (a) and (b) of this condition, in the case of an exceedance of the hourly 

average opacity operating limit for the electrostatic precipitator, measurements of the hourly average 

opacity based on visible emission observations in accordance with Method 9 (40 CFR part 60, appendix 

A) may be taken to evaluate the effectiveness of corrective action. (40 CFR 63.7833(g)(3))

d. If the second attempt at corrective action required in paragraph (b) of this condition was not successful, 

the permittee shall report the exceedance as a deviation in the next semiannual compliance report 

according to 40 CFR 63.7841(b). (40 CFR 63.7833(g)(4))

4. The permittee shall not increase the iron production rate of FGB&CCASTHOUSE to more than 8125 tons 

of liquid iron per day based on a calendar week average unless the on-site screening procedure and material 

management plan, or alternate plan(s) are approved in writing by the AQD District Supervisor. The plan(s) 

shall be implemented and maintained immediately after approval. The on-site screening procedure and 

material management plan will facilitate the permittee’s efforts in controlling mercury and/or other toxics 

and VOC emissions by eliminating unacceptable scrap and eliminating or reducing scrap with mercury 

contaminated materials. The permittee shall require all suppliers document that mercury-containing devices 

and switches have been removed from the scrap. (R336.1201(3), R336.1228, R336.1901)

5. The permittee shall record the specific information as required in the on-site screening procedure and scrap 

management plan. All such records shall be kept on file for a period of at least five years and made available 

to the Air Quality Division upon request. (R336.1201(3), R336.1228, R336.1901)
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 49 of 83 

TABLE E-01.09 BOF DESULFURIZATION BY-PRODUCTS “DESULF” PROCESS 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

EMISSION GROUP EUDESULFWATERINGSTATION 

BOF desulfurization by-product material “desulf” watering station located 

at the south end of the BOF building. Levy or any other winning bidder in 

the future for the service, digs the desulf materials with a front-end loader, 

brings them to an open area for cooling using water spray and for fugitive 

dust control. After thorough cooling, Levy or any other winning bidder in 

the future for the service, loads the materials into trucks for processing off 

site. Note: Levy currently has the contract to buy this material and, 

consequently, currently operates the Desulf Watering Station. 

Flexible Grouping ID NA 

I. DESIGN PARAMETERS 

A. Pollution Control 

Equipment 

Water spray system 

B. Stack/Vent Parameters NA 

Stack/Vent ID a. Minimum 

Height 

(feet) 

b. Maximum 

Exhaust Dimension 

(inches) 

c. Temp. 

(°F) 

d. Air 

Flow Rate 

(acfm) 

Applicable 

Requirement 

NA NA NA NA NA NA 

C. Other Design Parameters 

NA 

II. MATERIAL USAGE/EMISSION LIMITS 

A. Material Maximum Usage Rate 

NA NA 

B. Pollutant Maximum Emission Limit

1. Opacity of fugitive dust 

emissions from sources other than 

roads, lots, or storage pile 

20% (3 minute average) (R324.5524(2)) 

2. Opacity of fugitive dust 

emissions from material handling 

activities at a storage pile and 

from building openings other than 

roof monitors 

10% (3 minute average) (R324.5524(8), R336.1301(c)) 

3. Opacity of fugitive dust 

emissions from roof monitors 

20% (R336.1301) 

III. COMPLIANCE EVALUATION 

A. MONITORING/RECORDKEEPING 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping 

NA 

2. Process Monitoring System 

and Recordkeeping 

NA 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 50 of 83 

TABLE E-01.09 BOF DESULFURIZATION BY-PRODUCTS “DESULF” PROCESS 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

3. Other Monitoring and/or 

Recordkeeping 

The permittee shall perform a Method 9D certified visible emission ob 

servation of the desulf watering station at least once every two weeks for a 

minimum of 15 minutes during the dumping, watering and loading 

operation. The permittee shall initiate corrective action upon observation of 

visible emissions in excess of the applicable visible emission limitation and 

shall keep a written record of each required observation and corrective 

action taken. (R336.1213(3), R336.1910) 

B. TESTING/RECORDKEEPING 

1. Parameter to be Tested/ 

Recorded 

NA 

2. Method/Analysis NA 

3. Frequency and Schedule of 

Testing/Recordkeeping 

NA 

IV. REPORTING 

Reports and Schedules NA

V. OPERATIONAL PARAMETERS 

To control fugitive dust when processing the desulf material, the permittee shall not process the desulf material 

outside the BOF building without cooling off the material thoroughly with the water spray system. (R336.1910, 

R336.1901)

VI. OTHER REQUIREMENTS 

NA 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 51 of 83 

TABLE E-01.10 LADLE REFINING FACILITY No. 1 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

EMISSION GROUP EULADLEREFINE1 

Flexible Grouping ID NA 

I. DESIGN PARAMETERS 

A. Pollution Control 

Equipment 

Baghouse 

B. Stack/Vent Parameters NA 

Stack/Vent ID a. Minimum 

Height 

(feet) 

b. Maximum 

Exhaust Dimension 

(inches) 

c. Temp. 

(°F) 

d. Air 

Flow Rate 

(acfm) 

Applicable 

Requirement 

SVLADLEREFINE1 148 108 150 175,000 NA 

C. Other Design Parameters 

NA 

II. MATERIAL USAGE/EMISSION LIMITS 

A. Material Maximum Usage Rate 

NA NA 

B. Pollutant Maximum Emission Limit

1. Opacity from ladle refining 

facility roof monitors. 

1. 0% (R336.1301(c), 

40 CFR 63.7790(a))

2. Opacity from ladle refining 

facility baghouse. 

5%. (R336.1301(c))

3. PM from ladle refining facility 

baghouse. 

1. 0.005 grains per dry standard cubic foot (R336.1331(c), 40 CFR 

52.21(b)(3), 40 CFR 63.7790(a)) 

2. 6.8 lb/hr (R336.1331(c), 40 CFR 52.21(b)(3)) 

4. PM10 1. 0.005 grains per dry standard cubic foot (R336.1205(1)(a) & (b)) 

2. 6.8 lb/hr. (R336.1205(1)(a) & (b))

5. Pb 1. 0.0224 lb/hr. (40 CFR 52.21(d)) 

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. 

A. MONITORING/RECORDKEEPING 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping 

NA 

2. Process Monitoring System 

and Recordkeeping 

NA 

3. Other Monitoring and/or 

Recordkeeping 

1. The permittee shall maintain a copy of each notification and report 

submitted under 40 CFR Part 63, Subpart FFFFF, including all 

documentation supporting the initial notification or notification of 

compliance status submitted according to 40 CFR 63.10(b)(2)(xiv)). 

(40 CFR 63.7842(a)(1))

2. The permittee shall maintain the records required for startup, shutdown 

and malfunction under 63.6(e)(3)(iii) through (v). 

 (40 CFR 63.7842(a)(2))

3. The permittee shall maintain records associated with performance 

tests, and performance evaluations as required by 40 CFR 

63.10(b)(2)(viii). (40 CFR 63.7842(a)(3)) 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 52 of 83 

TABLE E-01.10 LADLE REFINING FACILITY No. 1 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

4. Except as allowed in S.C. 7, permittee shall install, operate, and 

maintain a bag leak detection system meeting the following 

specifications on the baghouse control: (40 CFR 63.7831(f)) 

a. Certified by the manufacturer to be capable of detecting emissions 

of particulate matter at concentrations of 10 milligrams per actual 

cubic foot (0.0044 grains per actual cubic foot). 

(40 CFR 63.7831(f)(1)) 

b. Provides output of relative changes in particulate matter loadings. 

 (40 CFR 63.7831(f)(2)) 

c. Is equipped with an alarm, located such that it is heard by 

appropriate plant personnel, that sounds an alarm when an increase 

in relative particulate loadings is detected over a preset level. 

 (40 CFR 63.7831(f)(3)) 

d. Initially adjusted by establishing the baseline output by adjusting 

the sensitivity (range) and the averaging period of the device and 

setting the alarm set points and alarm delay time. 

(40 CFR 63.7831(f)(5))

5. Following the initial adjustment of the bag leak detection system, the 

permittee shall not adjust the sensitivity or range, averaging period, 

alarm set points or alarm delay time except as specified in the 

operation and maintenance plan. This requirement does not apply if 

the permittee installs a COMS as specified in S.C. 7. (40 CFR 

63.7831(f)(6))

6. If the sensitivity of the bag leak detection system is changed beyond 

the limits established pursuant to 40 CFR 63.7831(f)(6), a copy of a 

written certification by a responsible official shall be included in the 

semiannual compliance report for that period. This requirement does 

not apply if the permittee installs a COMS as specified in S.C. 7.

 (40 CFR 63.7833(c)(2))

7. If permittee does not install and operate a bag leak detection system, 

the permittee shall install, operate, and maintain a COMS according to 

the requirements in 40 CFR Sec. 63.7831(h) and monitor the hourly 

average opacity of emissions exiting each control device stack 

according to the requirements in 40 CFR 63.7832. (40 CFR 63.7832)

8. The permittee shall monitor the pressure drop across each baghouse 

compartment daily to ensure that the pressure drop is within the normal 

operating range identified in the manual. (40 CFR 63.7830(b)(1)) 

9. The permittee shall confirm that dust is being removed from hoppers on 

a weekly basis through visual observations or other means of 

determining the proper functioning of the removal mechanisms. 

(40 CFR 63.7830(b)(2)) 

10. The permittee shall confirm that the compressed air supply to the pulsejet baghouse is operating properly on a daily basis. 

(40 CFR 63.7830(b)(3)) 

11. The permittee shall monitor the cleaning cycles of the baghouse to 

ensure proper operation using appropriate technology. 

(40 CFR 63.7830(b)(4)) 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 53 of 83 

TABLE E-01.10 LADLE REFINING FACILITY No. 1 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

12. The permittee shall check the bag cleaning mechanisms for proper 

functioning through monthly visual inspections or equivalent means. 

 (40 CFR 63.7830(b)(5))

13. The permittee shall inspect the baghouse to confirm the physical 

integrity of the baghouse through quarterly inspections of the interior of 

the baghouse for air leaks. (40 CFR 63.7830(b)(7)) 

14. The permittee shall inspect fans for wear, material buildup, and 

corrosion on a quarterly basis using visual inspections, vibration 

detectors, or equivalent means. (40 CFR 63.7830(b)(8)) 

15. The permittee shall monitor the process as required by this table, except 

during monitoring malfunctions, out-of-control periods, associated 

repairs, and required quality assurance or control activities (including 

calibration checks and required zero and span adjustments). (40 CFR 

63.7832(a)) 

16. Data recorded during monitoring malfunctions, associated repairs, and 

required quality assurance or control activities shall not be used in data 

averages and calculations used to report emission or operating levels or 

to fulfill minimum data availability requirements. (40 CFR 63.7832(b))

B. TESTING/RECORDKEEPING 

1. Parameter to be Tested/ 

Recorded 

1. Opacity 

2. PM 

3. PM-10 

4. Pb 

2. Method/Analysis Approved method. 

3. Frequency and Schedule of 

Testing/Recordkeeping 

1. Sampling during the performance tests will occur only when the 

operations being controlled are in operation. (40 CFR 63.7822(h)) 

2. The permittee shall maintain records of the time corrective action was 

initiated, the corrective action taken, and the date when corrective 

actions were completed in response to a bag leak detection system 

alarm. (40 CFR 63.7842(d) and 40 CFR 63.7833(c)(1))

3. The permittee shall demonstrate compliance with the opacity limitation 

in II.B.1 with a certified observer of Method 9 visible emissions using 

Method 9 with the following exceptions: (40 CFR 63.7823(d)(1)(i))

a. Record observations to the nearest 5 percent at 15-second 

intervals for at least three steel production cycles rather than 

using the procedure specified in Section 2.4 of Method 9. 

 (40 CFR 63.7823(d)(1)(ii)) 

b. Determine the 3-minute block average opacity from the average 

of 12 consecutive observations recorded at 15-second intervals. 

(40 CFR 63.7823(d)(1)(iii)) 

4. Performance tests for visible emissions shall be conducted such that 

the opacity observations overlap with the performance tests for 

particulate. (40 CFR 63.7823(b)) 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 54 of 83 

TABLE E-01.10 LADLE REFINING FACILITY No. 1 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

5. Within 180 days after commencement of trial operation, the permittee 

shall verify PM, PM10, and Pb emission rates from the Ladle Refining 

Facility No. 1 by testing at owner's expense, in accordance with 

Department requirements. No less than 60 days prior to testing, the 

permittee shall submit a complete test plan to the AQD. The AQD 

must approve the final plan prior to testing. Verification of emission 

rates includes the submittal of a complete report of the test results to 

the AQD within 60 days following the last date of the test. 

(R336.1205(1)(a) & (b), R336.2001, R336.2003, R336.2004, 40 CFR 

52.21(b)(3)) 

6. Permittee shall conduct performance tests for particulate matter 

emissions and opacity at least once per permit term. (40 CFR 

63.7821) 

IV. REPORTING 

Reports and Schedules 1. Permittee shall submit a notification of intent to perform any 

performance testing under 40 CFR Part 63, Subpart FFFFF at least 60 

calendar days before testing is to begin. (40 CFR 63.7840(d))

2. When actions taken by the permittee during a startup, shutdown, or 

malfunction of an affected source (including actions taken to correct a 

malfunction) are not consistent with the procedures in the startup, 

shutdown, and malfunction plan, the permittee shall comply with the 

requirements of 63.10(d)(5)(ii). (40 CFR Part 63.7841(c)) 

V. OPERATIONAL PARAMETERS 

1. The Ladle Refining Facility No. 1 shall not be operated unless the main baghouse is installed and operating 

properly. (R336.1331(c), R336.1910, R336.1201(3)) 

2. Ladle Refining Facility No. 1 and associated baghouse shall be operated and maintained in a manner 

consistent with good air pollution control practices for minimizing emissions at least to the levels required 

by 40 CFR Part 63, Subpart FFFFF. (40 CFR 63.7800(a) and 40 CFR 63.6(e)(1)(i)) 

3. The permittee shall develop and implement a written startup, shutdown and malfunction plan for the Ladle 

Refining Facility No. 1 and the associated emission control system and operate in accordance with the plan 

during periods of startup, shutdown, and malfunction. 

 (40 CFR 63.7810(c), 40 CFR 63.7835(b), and 40 CFR 63.6(e)(3))

VI. OTHER REQUIREMENTS 

1. The permittee shall comply with the emission limitations and operation and maintenance requirements from 

40 CFR Part 63, Subpart FFFFF specified in Table E-01.10, except during periods of startup, shutdown and 

malfunction. (40 CFR 63.7810(a)) 

2. Records required under 40 CFR Part 63, Subpart FFFFF and specified in this table shall be retained for five 

years. The records must be maintained onsite for the two most recent years of the five year period. Records 

from the remaining three years of the five year period may be keep offsite. (40 CFR 63.7843(b) and (c))
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 55 of 83 

TABLE E-01.11 LADLE REFINING FACILITY No.2 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

EMISSION GROUP EULADLEREFINE2 

Flexible Grouping ID NA 

I. DESIGN PARAMETERS 

A. Pollution Control 

Equipment 

Baghouse 

B. Stack/Vent Parameters Exhaust gases shall be discharged unobstructed vertically upwards unless 

otherwise noted.

Stack/Vent ID a. Minimum 

Height 

(feet) 

b. Maximum 

Exhaust Dimension 

(inches) 

c. Temp. 

(°F) 

d. Air 

Flow Rate 

(acfm) 

Applicable 

Requirement 

1. SVLADLEREFINE2 150 72 150 100,000 R336.1225 

C. Other Design Parameters 

NA 

II. MATERIAL USAGE/EMISSION LIMITS 

A. Material Maximum Usage Rate 

NA NA 

B. Pollutant Maximum Emission Limit

1. PM 1. 0.005 grains per dry standard cubic foot (R336.1331(c), 

40 CFR 52.21(b)(3), 40 CFR 63.7790(a)) 

2. 3.87 lb/hr (R336.1331(c), 40 CFR 52.21(b)(3)) 

2. Visible emissions from 

baghouse stack 

1. Shall not exceed a 6-minute average of 5% opacity. 

(R336.1201(3))

3. Opacity from the Ladle 

Refining No. 2 Building 

1. 0% (R336.1301(c), 40 CFR 63.7790(a)) 

4. PM10 1. 0.005 grains per dry standard cubic foot (R336.1205(1)(a) & (b)) 

2. 3.87 lb/hr. (R336.1205(1)(a) & (b))

5. Pb 1. 0.0128 lb/hr. (40 CFR 52.21(d)) 

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. 

A. MONITORING/RECORDKEEPING 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping 

NA 

2. Process Monitoring System 

and Recordkeeping 

NA 

3. Other Monitoring and/or 

Recordkeeping 

1. The permittee shall maintain a copy of each notification and report 

submitted under 40 CFR Part 63, Subpart FFFFF, including all 

documentation supporting the initial notification or notification of 

compliance status submitted according to 40 CFR 63.10(b)(2)(xiv)). 

(40 CFR 63.7842(a)(1))

2. The permittee shall maintain the records required for startup, shutdown 

and malfunction under 63.6(e)(3)(iii) through (v). 

 (40 CFR 63.7842(a)(2))
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 56 of 83 

TABLE E-01.11 LADLE REFINING FACILITY No.2 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

3. The permittee shall maintain records associated with performance tests 

and performance evaluations as required by 40 CFR 63.10(b)(2)(viii). 

(40 CFR 63.7842(a)(3)) 

4. Except as allowed in S.C. 7, permittee shall install, operate, and 

maintain a bag leak detection system meeting the following 

specifications on the baghouse control: (40 CFR 63.7831(f)) 

a. Certified by the manufacturer to be capable of detecting emissions 

of particulate matter at concentrations of 10 milligrams per actual 

cubic foot (0.0044 grains per actual cubic foot). 

 (40 CFR 63.7831(f)(1)) 

b. Provides output of relative changes in particulate matter loadings. 

 (40 CFR 63.7831(f)(2)) 

c. Is equipped with an alarm, located such that it is heard by 

appropriate plant personnel, that sounds an alarm when an increase 

in relative particulate loadings is detected over a preset level. 

 (40 CFR 63.7831(f)(3)) 

d. Initially adjusted by establishing the baseline output by adjusting 

the sensitivity (range) and the averaging period of the device and 

setting the alarm set points and alarm delay time. 

 (40 CFR 63.7831(f)(5)) 

5. Following the initial adjustment of the bag leak detection system, the 

permittee shall not adjust the sensitivity or range, averaging period, 

alarm set points or alarm delay time except as specified in the 

operation and maintenance plan. This requirement does not apply if 

the permittee installs a COMS as specified in S.C. 7. (40 CFR 

63.7831(f)(6))

6. If the sensitivity of the bag leak detection system is changed beyond the 

limits established pursuant to 40 CFR 63.7831(f)(6), a copy of a written 

certification by a responsible official shall be included in the 

semiannual compliance report for that period. This requirement does 

not apply if the permittee installs a COMS as specified in S.C. 7. (40 

CFR 63.7833(c)(2))

7. If permittee does not install and operate a bag leak detection system, 

the permittee shall install, operate, and maintain a COMS according to 

the requirements in 40CFR Sec. 63.7831(h) and monitor the hourly 

average opacity of emissions exiting each control device stack 

according to the requirements in 40 CFR 63.7832. (40 CFR 63.7832)

8. The permittee shall monitor the pressure drop across each baghouse 

compartment daily to ensure that the pressure drop is within the normal 

operating range identified in the manual. (40 CFR 63.7830(b)(1))

9. The permittee shall confirm that dust is being removed from hoppers on 

a weekly basis through visual observations or other means of 

determining the proper functioning of the removal mechanisms. 

 (40 CFR 63.7830(b)(2)) 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 57 of 83 

TABLE E-01.11 LADLE REFINING FACILITY No.2 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

10. The permittee shall confirm that the compressed air supply to the pulsejet baghouse is operating properly on a daily basis. 

 (40 CFR 63.7830(b)(3))

11. The permittee shall monitor the cleaning cycles of the baghouse to 

ensure proper operation using appropriate technology. 

 (40 CFR 63.7830(b)(4)

12. The permittee shall check the bag cleaning mechanisms for proper 

functioning through monthly visual inspections or equivalent means. 

 (40 CFR 63.7830(b)(5))

13. The permittee shall inspect the baghouse to confirm the physical 

integrity of the baghouse through quarterly inspections of the interior of 

the baghouse for air leaks. (40 CFR 63.7830(b)(7))

14. The permittee shall inspect fans for wear, material buildup, and 

corrosion on a quarterly basis using visual inspections, vibration 

detectors, or equivalent means. (40 CFR 63.7830(b)(8)) 

15. The permittee shall monitor the process as required by this table, except 

during monitoring malfunctions, out-of-control periods, associated 

repairs, and required quality assurance or control activities (including 

calibration checks and required zero and span adjustments). (40 CFR 

63.7832(a))

 

16. Data recorded during monitoring malfunctions, associated repairs, and 

required quality assurance or control activities shall not be used in data 

averages and calculations used to report emission or operating levels or 

to fulfill minimum data availability requirements. (40 CFR 7832(b)) 

B. TESTING/RECORDKEEPING 

1. Parameter to be Tested/ 

Recorded 

1. Opacity 

2. PM 

3. PM-10 

4. Pb 

2. Method/Analysis Approved method. 

3. Frequency and Schedule of 

Testing/Recordkeeping 

1. Sampling during the performance tests will occur only when the 

operations being controlled are in operation. (40 CFR 63.7822(h))

2. The permittee shall maintain records of the time corrective action was 

initiated, the corrective action taken, and the date when corrective 

actions were completed in response to a bag leak detection system 

alarm. (40 CFR 63.7842(d) and 40 CFR 63.7833(c)(1)) 

3. The permittee shall demonstrate compliance with the opacity limitation 

in II.B.3.1. with a certified observer of Method 9 visible emissions 

using Method 9 with the following exceptions: 

(40 CFR 63.7823(d)(1)(i))
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 58 of 83 

TABLE E-01.11 LADLE REFINING FACILITY No.2 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

a. Record observations to the nearest 5 percent at 15-second intervals 

for at least three steel production cycles rather than using the 

procedure specified in Section 2.4 of Method 9. 

(40 CFR 63.7823(d)(1)(ii)) 

b. Determine the 3-minute block average opacity from the average of 

12 consecutive observations recorded at 15-second intervals. (40 

CFR 63.7823(d)(1)(iii)) 

4. Performance tests for visible emissions shall be conducted such that 

the opacity observations overlap with the performance tests for 

particulate. (40 CFR 63.7823(b))

5. Within 180 days after commencement of trial operation, the permittee 

shall verify PM, PM10, and Pb emission rates from the Ladle Refining 

Facility No. 2 by testing at owner's expense, in accordance with 

Department requirements. No less than 60 days prior to testing, the 

permittee shall submit a complete test plan to the AQD. The AQD 

must approve the final plan prior to testing. Verification of emission 

rates includes the submittal of a complete report of the test results to 

the AQD within 60 days following the last date of the test. 

(R336.1205(1)(a) & (b), R336.2001, R336.2003, R336.2004, 40 CFR 

52.21(b)(3))

6. Permittee shall conduct performance tests for particulate matter 

emissions and opacity at least once per permit term. (40 CFR 

63.7821)

IV. REPORTING 

Reports and Schedules 1. Permittee shall submit a notification of intent to perform any 

performance testing under 40 CFR Part 63, Subpart FFFFF at least 60 

calendar days before testing is to begin. (40 CFR 63.7840(d))

2. When actions taken by the permittee during a startup, shutdown, or 

malfunction of an affected source (including actions taken to correct a 

malfunction) are not consistent with the procedures in the startup, 

shutdown, and malfunction plan, the permittee shall comply with the 

requirements of 63.10(d)(5)(ii). (40 CFR Part 63.7841(c))

V. OPERATIONAL PARAMETERS 

1. The permittee shall not operate the Ladle Refining Facility No. 2 unless the 100,000 ACFM baghouse dust 

collector is installed and operating properly. (R336.1201(3), R336.1331(c), R336.1910) 

2. Ladle Refining Facility No. 2 and the associated baghouse shall be operated and maintained in a manner 

consistent with good air pollution control practices for minimizing emissions at least to the levels required 

by 40 CFR Part 63, Subpart FFFFF. (40 CFR 63.7800(a) and 40 CFR 63.6(e)(1)(i)) 

 

3. The permittee shall develop and implement a written startup, shutdown and malfunction plan for the Ladle 

Refining Facility No. 2 and the associated emission control system and operate in accordance with the plan 

during periods of startup, shutdown, and malfunction. 

 (40 CFR 63.7810(c), 40 CFR 63.7835(b), and 40 CFR 63.6(e)(3)) 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 59 of 83 

TABLE E-01.11 LADLE REFINING FACILITY No.2 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

VI. OTHER REQUIREMENTS 

1. The permittee shall comply with the emission limitations and operation and maintenance requirements from 

40 CFR Part 63, Subpart FFFFF specified in Table E-01.11, except during periods of startup, shutdown and 

malfunction. (40 CFR 63.7810(a)) 

2. Records required under 40 CFR Part 63, Subpart FFFFF and specified in this table shall be retained for five 

years. The records must be maintained onsite for the two most recent years of the five year period. Records 

from the remaining three years of the five year period may be keep offsite. (40 CFR 63.7843(b) and (c))
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 60 of 83 

TABLE E-01.12 ANNEALING FURNACES 

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GROUPING NA 

Emission Unit / Process Group EUANNEALFURNACES 

I. DESIGN PARAMETERS 

A. Pollution Control 

Equipment 

NA 

B. Stack/Vent Parameters NA 

Stack/Vent ID a. Minimum 

Height 

(feet) 

b. Maximum 

Exhaust Dimension 

(inches) 

c. Temp. 

(°F) 

d. Air 

Flow Rate 

(acfm) 

Applicable 

Requirement 

NA NA NA NA NA NA 

C. Other Design Parameters 

NA 

II. MATERIAL USAGE/EMISSION LIMITS 

A. Material Maximum Usage Rate 

NA NA 

B. Pollutant Maximum Emission Limit

Nitrogen Oxide 1. 140 lb/ MMscf natural gas fired (R336.1205(1)(a) & (b)) 

PM 1. 10 lb/MMscf natural gas fired. (40 CFR 52.21(b)(3)) 

PM10 1. 10 lb/MMscf natural gas fired. (R336.1205(1)(a) & (b)) 

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. 

A. MONITORING/RECORDKEEPING 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping 

NA 

2. Process Monitoring System 

and Recordkeeping 

The permittee shall keep a record of the following for the annealing 

furnaces: 

1. Total natural gas consumption per month. (R336.1205(1)(a) & (b)

3. Other Monitoring and/or 

Recordkeeping 

NA 

B. TESTING/RECORDKEEPING 

1. Parameter to be Tested/ 

Recorded 

1. NOx 

2. PM 

3. PM-10 

2. Method/Analysis Approved method 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 61 of 83 

TABLE E-01.12 ANNEALING FURNACES 

FLEXIBLE GROUPING REQUIREMENTS

3. Frequency and Schedule of 

Testing/Recordkeeping 

Within 180 days after commencement of trial operation, the permittee shall 

verify NOx, PM, and PM-10 emission rates from a representative annealing 

furnace from EUANNEALFURNACES by testing at owner's expense, in 

accordance with Department requirements. No less than 60 days prior to 

testing, the permittee shall submit a complete test plan to the AQD. The 

AQD must approve the final plan prior to testing. Verification of emission 

rates includes the submittal of a complete report of the test results to the 

AQD within 60 days following the last date of the test. (R336.1205(1)(a) & 

(b), R336.1331, R336.2001, R336.2003, R336.2004, 40 CFR 52.21(b)(3))

IV. REPORTING 

Reports and Schedules NA 

V. OPERATIONAL PARAMETERS 

1. Oil shall not be used as fuel in the annealing furnaces. (R336.1205(1)(a) & (b)) 

VI. OTHER REQUIREMENTS 

NA 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 62 of 83 

TABLE F-01.01 B & C BLAST FURNACE CASTHOUSE OPERATIONS 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

FLEXIBLE GROUPING FGB&CBFCASTHOUSES 

Emission Unit/Process Group EUBBFCASTHOUSE, EUCBFCASTHOUSE 

I. DESIGN PARAMETERS 

A. Pollution Control 

Equipment 

Baghouse control of fugitive emissions (one for each operating casthouse) 

B. Stack/Vent Parameters NA 

Stack/Vent ID a. Minimum 

Height 

(feet) 

b. Maximum 

Exhaust Dimension 

(inches) 

c. Temp. 

(°F) 

d. Air 

Flow Rate 

(acfm) 

Applicable 

Requirement 

SVBBFROOFMONEAST 75.2 NA NA NA R336.1225 

SVBBFROOFMONWEST 75.2 NA NA NA R336.1225 

SVBFCE (baghouse) 200 111 150 250,000 R336.1225 

SVCBFROOFMONEAST 75.2 NA NA NA R336.1225 

SVCBFROOFMONWEST 75.2 NA NA NA R336.1225 

SVCFCE (baghouse) 200 153 150 500,000 R336.1225 

C. Other Design Parameters 

NA 

II. MATERIAL USAGE/EMISSION LIMITS 

A. Material Maximum Usage Rate 

NA NA 

B. Pollutant Maximum Emission Limit

1. PM 1. 19.93 tpy1 from roof monitors (40 CFR 52.21(b)(3))

2. PM-10 1. 10.16 tpy1 from roof monitors (R336.1205(1)(a) & (b))

3. SO2 from baghouse stacks 1. 29.94 lb/hr (40 CFR 52.21 (c) & (d), 40 CFR 52.21 (j)) 

2. 91.79 ton per 12-month rolling time period (40 CFR 52.21 (c), (d), 

& (j))

4. NOx from baghouse stacks 1. 3.19 lb/hr (R336.1205(1)(a) & (b)) 

2. 9.77 ton per 12-month rolling time period (R336.1205(1)(a) & (b))

5. VOC from baghouse stacks 1. 8.81 lb/hr (R336.1702(a))

6. Mn 1. 0.00385 lb/hr total from baghouse stacks (R336.1225) 

2. 0.00602

 lb/hr from roof monitors (R336.1225) 

7. Pb 1. 0.000223 lb/hr total from baghouse stacks (40 CFR 52.21(d)) 

2. 0.0000871

 lb/hr from roof monitors (40 CFR 52.21(d))

1

 These limits are based on a 12-month rolling time period. 

2

 This limit is based on a daily time period 

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. 

A. MONITORING/RECORDKEEPING 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping 

NA 

2. Process Monitoring System 

and Recordkeeping 

NA 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 63 of 83 

TABLE F-01.01 B & C BLAST FURNACE CASTHOUSE OPERATIONS 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

3. Other Monitoring and/or 

Recordkeeping 

1. Using the method shown in Appendix 1.7, the permittee shall calculate 

and record by the end of each calendar month the following from the 

casthouse roof monitors: 

a. emissions of PM 

b. emissions of PM-10 

c. emissions of Mn 

d. emissions of Pb 

 (R336.1205(1)(a) & (b), R336.1225, 40 CFR 52.21(b)(3), 

 40 CFR 52.21(d))

2. The permittee shall keep a daily record of the amount of iron cast from 

each furnace individually and combined. (R336.1205(1)(a) & (b), 

R336.1225)

3. Using the method shown in Appendix 1.7, the permittee shall calculate 

records of SO2, NOx, VOC, Mn, and Pb emissions for 

FGB&CBFCASTHOUSES (baghouses) using emission factors 

developed during the testing required in S.C. III.B.3.1 and S.C. 

III.B.3.10 of Table E-01.04, and other factors, as specified in Appendix 

1.7. The permittee shall keep all records on file at the facility for a 

period of at least five years and make them available to the Department 

upon request. (R336.1205(1)(a) & (b), 40 CFR 52.21(c) and (d))

B. TESTING/RECORDKEEPING 

1. Parameter to be Tested/ 

Recorded 

NA 

2. Method/Analysis NA 

3. Frequency and Schedule of 

Testing/Recordkeeping 

NA 

IV. REPORTING 

Reports and Schedules 1. Permittee shall report the results of the initial performance test in the 

notification of compliance status. (40 CFR 63.7820(a), 40 CFR 

63.7825(c) and 40 CFR 63.7840(e))

V. OPERATIONAL PARAMETERS 

1. The iron production from FGB&CBFCASTHOUSES shall not exceed a combined maximum of 10,000 

ton/day based on a calendar week average. (R336.1205(1)(a) & (b), R336.1225, 40 CFR 52.21(b)(3)) 

2. The iron production from FGB&CBFCASTHOUSES shall not exceed a combined maximum of 3,321,500 

tons per 12-month rolling period. (R336.1205(1)(a) & (b), R336.1225, 40 CFR 52.21(b)(3)) 

VI. OTHER REQUIREMENTS 

NA 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 64 of 83 

TABLE F-01.02 B AND C BLAST FURNACE STOVES 

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GROUPING FGB&CSTOVES 

Emission Unit/Process Group EUBFCESTOVE, EUCFCESTOVE 

I. DESIGN PARAMETERS 

A. Pollution Control 

Equipment 

Low-NOx technology, mechanical collectors and scrubbers for blast 

furnace gas precleaning 

B. Stack/Vent Parameters NA 

Stack/Vent ID a. Minimum 

Height 

(feet) 

b. Maximum 

Exhaust Dimension 

(inches) 

c. Temp. 

(°F) 

d. Air 

Flow Rate 

(acfm) 

Applicable 

Requirement 

NA NA NA NA NA NA 

C. Other Design Parameters 

NA 

II. MATERIAL USAGE/EMISSION LIMITS 

A. Material Maximum Usage Rate 

NA NA 

B. Pollutant Maximum Emission Limit

1. NOx 439.18 ton/12-month rolling period (R336.1205(1)(a) & (b))

2. SO2 1,096.1 ton/12-month rolling period (40 CFR 52.21(j)) 

3. CO 8,760 ton/12-month rolling period. (40 CFR 52.21(d) & (j))

4. PM 14.16 lb/hr (40 CFR 52.21(b)(3))

5. PM-10 14.16 lb/hr (R336.1205(1)(a) & (b)) 

6. Mn 0.0154 lb/hr (R336.1225) 

7. Total Hg 0.000414 lb/hr (R336.1201(3), R336.1228, R336.1901) 

8. Pb 0.0141 lb/hr (40 CFR 52.21(d)) 

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. 

A. MONITORING/RECORDKEEPING 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping 

NA 

2. Process Monitoring System 

and Recordkeeping 

1. The permittee shall keep, in a satisfactory manner, daily fuel usage 

records for FGB&CSTOVES. The permittee shall keep all records on 

file at the facility for a period of at least five years and make them 

available to the Department upon request. (R336.1205(1)(a) & (b), 40 

CFR 52.21(b)(3), (c), & (d))

2. Following the performance testing required in S.C. III.B.3.1 of Table 

E-01.03 and S.C. III.B.3.1 of Table E-01.05, the permittee shall 

determine compliance with emission limits in S.C. II.B.1, II.B.3, II.B.4, 

II.B.5, II.B.6, II.B.7, and II.B.8 of this table by establishing emission 

factors based up on the BFCE and CFCE stove stack testing and 

applying these emission factors to the daily fuel usage recorded in S.C. 

III.A.2.1, as outlined in Appendix 1.7. (R336.1205(1)(a) & (b), 

R336.1225, R336.1228, R336.1901, 40 CFR 52.21(b)(3), (c), & (d))
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 65 of 83 

TABLE F-01.02 B AND C BLAST FURNACE STOVES 

FLEXIBLE GROUPING REQUIREMENTS

3. Utilizing the CEMS for SO2 emissions from the C Blast Furnace 

stoves, the permittee shall determine compliance with the emission 

limits in S.C. II.B.2 by determining daily emission factors and applying 

these emission factors to the daily fuel usage recorded in S.C. III.A.2.1, 

as outlined in Appendix 1.7. (40 CFR 52.21 (c), & (d))

3. Other Monitoring and/or 

Recordkeeping 

NA 

B. TESTING/RECORDKEEPING 

1. Parameter to be Tested/ 

Recorded 

NA 

2. Method/Analysis NA 

3. Frequency and Schedule of 

Testing/Recordkeeping 

NA 

IV. REPORTING 

Reports and Schedules NA 

V. OPERATIONAL PARAMETERS 

NA 

VI. OTHER REQUIREMENTS 

 NA 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 66 of 83 

TABLE F-01.03 BASIC OXYGEN FURNACE (BOF)/RELADLING SOUTH & NORTH BOF 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

EMISSION GROUP EUBOF, EURELADLINGBOF 

Flexible Grouping ID FGBOFSHOP 

I. DESIGN PARAMETERS 

A. Pollution Control 

Equipment 

Baghouse 

B. Stack/Vent Parameters NA 

Stack/Vent ID a. Minimum 

Height 

(feet) 

b. Maximum 

Exhaust Dimension 

(inches) 

c. 

Temp. 

(°F) 

d. Air Flow 

Rate 

(acfm) 

Applicable 

Requirement 

SVBOFESP 213 204 300 841,000 R336.1225 

SVBOFBH 200 222 150 1,000,000 R336.1225 

C. Other Design Parameters 

1. NA

II. MATERIAL USAGE/EMISSION LIMITS 

A. Material Maximum Usage Rate 

NA NA 

B. Pollutant Maximum Emission Limit

1. PM. 1. 0.003 gr/dscf from baghouse stack (R336.1331(c), 40 CFR 63.7790(a), 

40 CFR 52.21(b)(3)) 

2. 7.45 lb/hr from baghouse stack (40 CFR 52.21(b)(3)) 

2. PM-10. 1. 0.00135 gr/dscf from baghouse stack. (R336.1205(1)(a) & (b)) 

2. 3.35 lb/hr from baghouse stack (R336.1205(1)(a) & (b)) 

3. NOx 1. 10.17 lb/hr from the baghouse stack. (R336.1205(1)(a) & (b)) 

4. Manganese 1. 0.101 lb/hr from baghouse and ESP stacks combined. (R336.1225) 

2. 0.0709 lb/hr from the baghouse stack. (R336.1225)

5. Total Mercury 1. 0.0125 lb/hr from the baghouse and ESP stacks combined. 

(R336.1201(3), R336.1228, R336.1901) 

6. Lead 1. 0.067 lb/hr from the baghouse and ESP stacks combined. (40 CFR 

52.21(d)) 

7. Opacity from baghouse stack. 1. 20% (R336.1364(1), R336.1365(1))

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. 

A. MONITORING/RECORDKEEPING 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping 

NA

2. Process Monitoring System 

and Recordkeeping 

1. If applicable, the permittee shall install, maintain, and operate a 

Continuous Parametric Monitoring System (CPMS) for the baghouse 

capture system according to the requirements of 40 CFR 63.7830(a) and 

40 CFR 63.7831(e). (40 CFR 63.7830(a))

3. Other Monitoring and/or 

Recordkeeping 

1. The permittee shall maintain a copy of each notification and report 

submitted under 40 CFR Part 63, Subpart FFFFF, including all 
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Permit No. 182-05B Page 67 of 83 

TABLE F-01.03 BASIC OXYGEN FURNACE (BOF)/RELADLING SOUTH & NORTH BOF 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

documentation supporting the initial notification or notification of 

compliance status submitted according to 40 CFR 63.10(b)(2)(xiv)). (40 

CFR 63.7842(a)(1)) 

2. The permittee shall maintain the records required for startup, shutdown 

and malfunction under 63.6(e)(3)(iii) through (v). (40 CFR 63.7842(a)(2))

3. The permittee shall maintain records associated with performance tests, 

performance evaluations, and opacity observations as required by 40 CFR 

63.10(b)(2)(viii). (40 CFR 63.7842(a)(3)) 

4. The permittee shall comply with the recordkeeping requirement as 

specified in 40 CFR Part 63 Subpart FFFFF 63.7842(a), (b), (c) and (d).

 (40 CFR 63.7842(a), (b), (c) and (d))

5. Except as allowed in S.C. 8, permittee shall install, operate, and maintain 

a bag leak detection system meeting the following specifications on the 

baghouse control, if applicable: (40 CFR 63.7831(f)) 

a. Certified by the manufacturer to be capable of detecting emissions of 

particulate matter at concentrations of 10 milligrams per actual cubic 

foot (0.0044 grains per actual cubic foot). (40 CFR 63.7831(f)(1)) 

b. Provides output of relative changes in particulate matter loadings. 

 (40 CFR 63.7831(f)(2)) 

c. Is equipped with an alarm, located such that it is heard by appropriate 

plant personnel, that sounds an alarm when an increase in relative 

particulate loadings is detected over a preset level. (40 CFR 

63.7831(f)(3)) 

d. Initially adjusted by establishing the baseline output by adjusting the 

sensitivity (range) and the averaging period of the device and setting 

the alarm set points and alarm delay time. (40 CFR 63.7831(f)(5)) 

6. Following the initial adjustment of the bag leak detection system, the 

permittee shall not adjust the sensitivity or range, averaging period, alarm 

set points or alarm delay time except as specified in the operation and 

maintenance plan, if applicable. This requirement does not apply if the 

permittee installs a COMS as specified in S.C. 8. (40 CFR 63.7831(f)(6))

7. If the sensitivity of the bag leak detection system is changed beyond the 

limits established pursuant to 40 CFR 63.7831(f)(6), a copy of a written 

certification by a responsible official shall be included in the semiannual 

compliance report for that period, if applicable. This requirement does not 

apply if the permittee installs a COMS as specified in S.C. 8. (40 CFR 

63.7833(c)(2))

8. If permittee does not install and operate a bag leak detection system, the 

permittee shall install, operate, and maintain a COMS according to the 

requirements in 40CFR Sec. 63.7831(h) and monitor the hourly average 

opacity of emissions exiting each control device stack according to the 

requirements in 40 CFR 63.7832. (40 CFR 63.7832)
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 68 of 83 

TABLE F-01.03 BASIC OXYGEN FURNACE (BOF)/RELADLING SOUTH & NORTH BOF 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

9. The permittee shall monitor the pressure drop across each baghouse 

compartment daily to ensure that the pressure drop is within the normal 

operating range identified in the manual, if applicable. (40 CFR 

63.7830(b)(1))

10. The permittee shall confirm that dust is being removed from hoppers on a 

weekly basis through visual observations or other means of determining 

the proper functioning of the removal mechanisms, if applicable. (40 

CFR 63.7830(b)(2)) 

11. The permittee shall confirm that the compressed air supply to the pulse-jet 

baghouse is operating properly on a daily basis, if applicable. (40 CFR 

63.7830(b)(3))

12. The permittee shall monitor the cleaning cycles of the baghouse to ensure 

proper operation using appropriate technology, if applicable. 

 (40 CFR 63.7830(b)(4))

13. The permittee shall check the bag cleaning mechanisms for proper 

functioning through monthly visual inspections or equivalent means, if 

applicable. (40 CFR 63.7830(b)(5)) 

14. The permittee shall inspect the baghouse to confirm the physical integrity 

of the baghouse through quarterly inspections of the interior of the 

baghouse for air leaks, if applicable. (40 CFR 63.7830(b)(7))

15. The permittee shall inspect fans for wear, material buildup, and corrosion 

on a quarterly basis using visual inspections, vibration detectors, or 

equivalent means, if applicable. (40 CFR 63.7830(b)(8)) 

16. The permittee shall monitor the process as required by this table, except 

during monitoring malfunctions, out-of-control periods, associated repairs, 

and required quality assurance or control activities (including calibration 

checks and required zero and span adjustments). (40 CFR 63.7832(a))

 

17. Data recorded during monitoring malfunctions, associated repairs, and 

required quality assurance or control activities shall not be used in data 

averages and calculations used to report emission or operating levels or to 

fulfill minimum data availability requirements. (40 CFR 63.7832(b)) 

18. The permittee shall obtain an analysis of the BOF baghouse dust once per 

calendar month during the 1st year after the modification of C blast 

furnace and quarterly thereafter, or less frequently if approved in writing 

by the Air Quality Division. The analysis shall determine the percentage 

of Pb, Hg, and Mn in the collected PM dust from the baghouse. The 

permittee shall submit an acceptable protocol for baghouse dust sampling 

and analysis methods to the Air Quality Division, at least 60 days prior 

the initial performance emission test. (R336.1225, R336.1228, 40 CFR 

52.21(d)) 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 69 of 83 

TABLE F-01.03 BASIC OXYGEN FURNACE (BOF)/RELADLING SOUTH & NORTH BOF 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

19. The permittee shall prepare, and operate at all times according to, a written 

operation and maintenance plan for the baghouse capture system. The plan 

shall address each of the following: (40 CFR 63.7800(b)) 

a. Weekly inspections of the equipment that is important to the 

performance of the total capture system, including, but not limited to, 

observations of the physical appearance of the equipment and 

requirements to repair any defect or deficiency in the capture system 

before the next scheduled inspection; (R336.1301, R336.1364(1), 

40 CFR 63.7800(b)(1)) 

b. Operating limit parameters appropriate for the capture system design 

that are representative and reliable indicators of the performance of the 

capture system including, but not limited to, operating limit 

parameters that indicate the level of the ventilation draft and the 

damper position settings for the capture system when operating to 

collect emissions, including revised settings for seasonal variations. 

Appropriate operating limit parameters for ventilation draft include, 

but are not limited to, volumetric flow rate through each separately 

ducted hood, total volumetric flow rate at the inlet to the control 

device to which the capture system is vented, fan motor amperage, or 

static pressure. (40 CFR 63.7800(b)(3)) 

20. If applicable, the permittee shall monitor the hourly average actual 

volumetric flow rate through each separately ducted hood for each steel 

production cycle and the average total volumetric flow rate at the inlet to 

the baghouse for each steel production cycle according to the requirements 

in 40 CFR 63.7832. (40 CFR 63.7830(a))

21. If applicable, the permittee shall develop and make available for 

inspection upon request by AQD a site-specific monitoring plan that 

addresses all of the following requirements for the baghouse capture 

system: (40 CFR 63.7831(a)) 

a. Installation of the CPMS sampling probe or other interface at a 

measurement location relative to each hooded emission point such that 

the measurement is representative of capture of the exhaust emissions;

 (40 CFR 63.7831(a)(1))

b. Performance and equipment specifications for the sample interface, 

the parametric signal analyzer, and the data collection and reduction 

system; (40 CFR 63.7831(a)(2)) 

c. Performance evaluation procedures and acceptance criteria; 

(40 CFR 63.7831(a)(3)) 

d. Ongoing operation and maintenance procedures in accordance with 

the general requirements of 40 CFR 63.8(c)(1), (c)(3), (c)(4)(ii), 

(c)(7), and (c)(8); (40 CFR 63.7831(a)(4))

e. Ongoing data quality assurance procedures in accordance with the 

general requirements of 40 CFR 63.8(d); and 

(40 CFR 63.7831(a)(5))

f. Ongoing recordkeeping and reporting procedures in accordance the 

general requirements of 40 CFR 63.10(c), (e)(1), and (e)(2)(i). 

 (40 CFR 63.7831(a)(6)) 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 70 of 83 

TABLE F-01.03 BASIC OXYGEN FURNACE (BOF)/RELADLING SOUTH & NORTH BOF 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

22. If applicable, the permittee shall operate and maintain the capture system 

CPMS in continuous operation according to the site-specific monitoring 

plan. Unless otherwise specified, the CPMS shall: (40 CFR 63.7831(b)) 

a. Complete a minimum of one cycle of operation for each successive 

15-minute period and collect a minimum of three of the required four 

data points to constitute a valid hour of data; (40 CFR 63.7831(b)(1)) 

b. Provide valid hourly data for at least 95 percent of every averaging 

period; and (40 CFR 63.7831(b)(2))

c. Determine and record the hourly average of all recorded readings.

(40 CFR 63.7831(b)(3))

23. The permittee shall operate the baghouse capture system at or above the 

lowest value or settings established for the operating limits in the 

operation and maintenance plan and collect, reduce, and record the 

monitoring data for each of the operating limit parameters. (40 CFR 

63.7833(b)) 

B. TESTING/RECORDKEEPING 

1. Parameter to be Tested/ 

Recorded 

1. Opacity 

2. PM 

3. PM-10 

4. NOx 

5. Mn 

6. Speciated Hg 

7. Pb 

2. Method/Analysis Approved method. 

3. Frequency and Schedule of 

Testing/Recordkeeping 

1. The permittee shall conduct a performance test to demonstrate initial 

compliance with the applicable emission and opacity limitations of 40 

CFR Part 63, Subpart FFFFF contained in this table within 180 days of 

startup of the baghouse. (40 CFR 63.7820(a)) 

2. Performance tests shall occur when the operations are at maximum 

routine operating conditions. (R336.2003, 40 CFR 63.7822(g) & (h))

3. Permittee shall determine and record the starting and stopping times of 

the steel production cycle. (40 CFR 63.7823(d)(5))

4. The permittee shall maintain a copy of the current operation and 

maintenance plans required in this table onsite and available for 

inspection. (40 CFR 63.7834(b))
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TABLE F-01.03 BASIC OXYGEN FURNACE (BOF)/RELADLING SOUTH & NORTH BOF 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

5. The permittee shall maintain records of the time corrective action was 

initiated, the corrective action taken, and the date when corrective actions 

were completed in response to a bag leak detection system alarm, if 

applicable. (40 CFR 63.7842(d) and 40 CFR 63.7833(c)(1)) 

6. Within 60 days of achieving the maximum production rate, but not later 

than 180 days after commencement of trial operation, the permittee shall 

verify and quantify Mn, Pb, and speciated Hg emissions rates from the 

FGBOFSHOP (baghouse and ESP simultaneously) and the ratio of Mn, 

Pb, and Hg concentrations in both the ESP dust and the baghouse dust to 

the actual amount of Mn, Pb, and Hg emitted from the baghouse and ESP, 

by testing at owner's expense, in accordance with Department 

requirements. No less than 60 days prior to testing, the permittee shall 

submit a complete test plan to the AQD. The AQD must approve the 

final plan prior to testing. Verification of emission rates includes the 

submittal of a complete report of the test results to the AQD within 60 

days following the last date of the test. (R336.1225, R336.1228, 

R336.2001, R336.2003, R336.2004, 40 CFR 52.21(d)) 

7. The permittee shall certify that the baghouse capture system operated 

during the performance test at the site-specific operating limits 

established in the operation and maintenance plan using the following 

procedures: (40 CFR 63.7824(a)) 

a. Concurrent with all opacity observations, measure and record values 

for each of the operating limit parameters in the capture system 

operation and maintenance plan according to the monitoring 

requirements specified in 40 CFR 63.7830(a). (40 CFR 63.7824(a)(1))

b. For any dampers that are manually set and remain at the same position 

at all times the capture system is operating, the damper position shall 

be visually checked and recorded at the beginning and end of each 

opacity observation period segment. (40 CFR 63.7824(a)(2))

c. Review and record the monitoring data and identify and explain any 

times the capture system operated outside the applicable operating 

limits. (40 CFR 63.7824(a)(3))

d. Certify in the performance test report that during all observation 

period segments, the capture system was operating at the values or 

settings established in the capture system operation and maintenance 

plan. (40 CFR 63.7824(a)(4)) 

8. The permittee may change the operating limits for the baghouse capture 

system if the following requirements are met: (40 CFR 63.7824(d)) 

a. Submit a written notification to the Administrator requesting to 

conduct a new performance test to revise the operating limit. 

(40 CFR 63.7824(d)(1))

b. Conduct a performance test to demonstrate compliance with the 

applicable operating limitation. (40 CFR 63.7824(d)(2))

c. Establish revised operating limits according to the applicable 

procedures in 40 CFR 63.7824, paragraphs (a) through (c) for a 

capture system. (40 CFR 63.7824(d)(3)) 
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TABLE F-01.03 BASIC OXYGEN FURNACE (BOF)/RELADLING SOUTH & NORTH BOF 

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

9. Within 180 days after commencement of trial operation, the permittee 

shall verify NOx, PM, and PM10 emission rates from the baghouse stack 

by testing at owner's expense, in accordance with Department 

requirements. No less than 60 days prior to testing, the permittee shall 

submit a complete test plan to the AQD. The AQD must approve the final 

plan prior to testing. Verification of emission rates includes the submittal 

of a complete report of the test results to the AQD within 60 days 

following the last date of the test. (R336.1205(1)(a) & (b), R336.2001, 

R336.2003, R336.2004, 40 CFR 52.21(b)(3)) 

10. Permittee shall conduct overlapping performance tests for particulate 

matter emissions from the BOF secondary baghouse and opacity from the 

BOF roof monitor at least once per permit term. (40 CFR 63.7821)

IV. REPORTING 

Reports and Schedules 1. Permittee shall report the results of the initial performance test in the 

notification of compliance status. (40 CFR 63.7820(a), 40 CFR 

63.7825(c) and 40 CFR 63.7840(e)) 

2. Permittee shall submit a notification of intent to perform any performance 

testing under 40 CFR Part 63, Subpart FFFFF at least 60 calendar days 

before testing is to begin. (40 CFR 63.7840(d))

3. Any time an action taken by the permittee during a startup, shutdown, or 

malfunction of an affected source (including actions taken to correct a 

malfunction) is not consistent with the procedures in the startup, 

shutdown, and malfunction plan, the permittee shall comply with all 

requirements of 63.10(d)(5)(ii). (40 CFR Part 63.7841(c))

V. OPERATIONAL PARAMETERS 

1. The permittee shall install a baghouse dust collector for BOF secondary emissions according to the following 

schedule: 

a. Complete construction and place in operation by January 31, 2008, or startup of enhanced C-FCE, 

whichever is sooner. (R336.1205(1)(a) & (b), 40 CFR 52.21(b)(3)) 

2. After completion of C-FCE modification, the permittee shall not operate the Basic Oxygen Furnace or the 

Reladling South Operation unless the baghouse secondary emission dust collector is installed, maintained, and 

operated in a satisfactory manner. (R336.1205(1)(a) & (b), R336.1225, R336.1331(c), R336.1910, 40 CFR 

52.21(b)(3))

3. The permittee shall keep on file a copy of the BOF secondary baghouse capture system design plans and a 

signed certification from the designer, certifying that the baghouse capture system is designed to achieve no 

less than 98% collection efficiency for both the BOF secondary emissions and the reladling south emissions. 

These design plans shall include a range of BOF vessel angles to achieve optimum emission capture. 

(R336.1205(1)(a) & (b), 40 CFR 52.21(b)(3))

VI. OTHER REQUIREMENTS 

1. Records required under 40 CFR Part 63, Subpart FFFFF and specified in this table shall be retained for five 

years. The records must be maintained onsite for the two most recent years of the five year period. Records 

from the remaining three years of the five year period may be keep offsite. (40 CFR 63.7843(b) and (c))
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 73 of 83 

TABLE F-01.04 SLAB REHEAT FURNACES 1, 2 & 3 AT HOT STRIP MILL BUILDING 

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GROUPING FGSREHEATFURNACE123 

Emission Unit / Process Group EUSREHEATFURNACE1, EUSREHEATFURNACE2, 

EUSREHEATFURNACE3 

I. DESIGN PARAMETERS 

A. Pollution Control 

Equipment 

NA 

B. Stack/Vent Parameters NA 

Stack/Vent ID a. Minimum 

Height 

(feet) 

b. Maximum 

Exhaust Dimension 

(inches) 

c. Temp. 

(°F) 

d. Air 

Flow Rate 

(acfm) 

Applicable 

Requirement 

NA NA NA NA NA NA 

C. Other Design Parameters 

NA 

II. MATERIAL USAGE/EMISSION LIMITS 

A. Material Maximum Usage Rate 

NA NA 

B. Pollutant Maximum Emission Limit

Opacity 20% (R336.1301)

Nitrogen Oxide 1. 0.11 lb/mmBTU (R336.1205(1)(a) & (b), R336.1801(4)) 

PM 1. 10 lb/MMscf natural gas fired. (40 CFR 52.21(b)(3), 

R336.1331(c)) 

PM10 1. 10 lb/MMscf natural gas fired. (R336.1205(1)(a) & (b)) 

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. 

A. MONITORING/RECORDKEEPING 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping 

NA 

2. Process Monitoring System 

and Recordkeeping 

The permittee shall keep a record of the following for furnaces 1, 2, and 3: 

1. Total natural gas consumption per month. (R336.1205(1)(a) & (b))

3. Other Monitoring and/or 

Recordkeeping 

NA 

B. TESTING/RECORDKEEPING 

1. Parameter to be Tested/ 

Recorded 

1. Opacity 

2. NOx 

3. PM 

4. PM-10 

2. Method/Analysis Approved method 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 74 of 83 

TABLE F-01.04 SLAB REHEAT FURNACES 1, 2 & 3 AT HOT STRIP MILL BUILDING 

FLEXIBLE GROUPING REQUIREMENTS

3. Frequency and Schedule of 

Testing/Recordkeeping 

1. Within 180 days after commencement of trial operation, the permittee 

shall verify NOx, PM, and PM-10 emission rates from a representative 

furnace from Slab reheat furnaces 1, 2, and 3 by testing at owner's 

expense, in accordance with Department requirements. No less than 

60 days prior to testing, the permittee shall submit a complete test plan 

to the AQD. The AQD must approve the final plan prior to testing. 

Verification of emission rates includes the submittal of a complete 

report of the test results to the AQD within 60 days following the last 

date of the test. (R336.1205(1)(a) & (b), R336.1331, R336.2001, 

R336.2003, R336.2004, 40 CFR 52.21(b)(3)) 

IV. REPORTING 

Reports and Schedules NA 

V. OPERATIONAL PARAMETERS 

1.

VI. OTHER REQUIREMENTS 

NA 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 75 of 83 

TABLE F-01.05 FGFACILITY 

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GROUPING FGFACILITY 

Emission Unit / Process Group All equipment at the stationary source including equipment covered by 

other permits, grandfathered equipment and exempt equipment. 

I. DESIGN PARAMETERS 

A. Pollution Control 

Equipment 

NA 

B. Stack/Vent Parameters NA 

Stack/Vent ID a. Minimum 

Height 

(feet) 

b. Maximum 

Exhaust Dimension 

(inches) 

c. Temp. 

(°F) 

d. Air 

Flow Rate 

(acfm) 

Applicable 

Requirement 

NA NA NA NA NA NA 

C. Other Design Parameters 

NA 

II. MATERIAL USAGE/EMISSION LIMITS 

A. Material Maximum Usage Rate 

NA NA 

B. Pollutant Maximum Emission Limit

NA NA 

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. 

A. MONITORING/RECORDKEEPING 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping 

NA 

2. Process Monitoring System 

and Recordkeeping 

NA 

3. Other Monitoring and/or 

Recordkeeping 

NA 

B. TESTING/RECORDKEEPING 

1. Parameter to be Tested/ 

Recorded 

NA 

2. Method/Analysis NA 

3. Frequency and Schedule of 

Testing/Recordkeeping 

NA 

IV. REPORTING 

Reports and Schedules NA 

V. OPERATIONAL PARAMETERS 

NA 

VI. OTHER REQUIREMENTS 

This Permit to Install shall become effective on May 22, 2007, unless the permittee files a timely request for 

review with the Administrator of the United States Environmental Protection Agency pursuant to 40 CFR 

124.15 and 124.19. (40 CFR 124.15 and 124.19)
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 76 of 83 

Appendix 1.3. Monitoring Requirements

1.3.1 SO2 Monitoring Continuous Emission Monitoring System (CEMS) Requirements 

1. Within 60 calendar days of the issuance of this permit, the permittee shall submit two copies of a 

Monitoring Plan to the AQD, for review and approval. The Monitoring Plan shall include drawings or 

specifications showing proposed locations and descriptions of the required CEMS. 

2. Within 150 calendar days of the issuance of this permit, the permittee shall submit two copies of a 

complete test plan for the CEMS to the AQD for approval. 

3. Prior to restarting the blast furnace after completion of the CFCE modification, the permittee shall 

complete the installation of the CEMS and complete testing within 180 days of restarting the blast 

furnace. 

4. Within 60 days of completion of testing, the permittee shall submit to the AQD two copies of the final 

report demonstrating the CEMS complies with the requirements of Performance Specification (PS) 2. 

5. The span value shall be 2.0 times the lowest emission standard or as specified in the federal regulations. 

6. The CEMS shall be installed, calibrated, maintained, and operated in accordance with the procedures set 

forth in 40 CFR 60.13 and PS 2 of Appendix B, 40 CFR Part 60. 

7. Each calendar quarter, the permittee shall perform the Quality Assurance Procedures of the CEMS set 

forth in Appendix F of 40 CFR Part 60. Within 30 days following the end of each calendar quarter, the 

permittee shall submit the results to the AQD in the format of the data assessment report (Figure 1, 

Appendix F) 

8. In accordance with 40 CFR 60.7(c) and (d), the permittee shall submit two copies of an excess emission 

report (EER) and summary report in an acceptable format to the AQD, within 30 days following the end 

of each calendar quarter. The Summary Report shall follow the format of Figure 1 in 40 CFR 60.7(d). 

The EER shall include the following information: 

a) A report of each exceedance above the limits specified in the conditions of this permit. This includes 

the date, time, magnitude, cause and corrective actions of all occurrences during the reporting period. 

b) A report of all periods of CEMS downtime and corrective action. 

c) A report of the total operating time of the EUCFCESTOVE during the reporting period. 

d) A report of any periods that the CEMS exceeds the instrument range. 

e) If no exceedances or CEMS downtime occurred during the reporting period, the permittee shall report 

that fact. 

All monitoring data shall be kept on file for a period of at least five years and made available to the AQD upon 

request. 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 77 of 83 

1.3.2 Continuous Opacity Monitoring System (COMS) Requirements 

1. Within 30 calendar days of the issuance of this permit, the permittee shall submit two copies of a 

Monitoring Plan to the AQD, for review and approval. 

2. Within 150 calendar days of the issuance of this permit, the permittee shall submit two copies of a 

complete test plan for the COMS to the AQD for approval. 

3. Within 180 calendar days of the issuance of this permit, the permittee shall complete the testing of the 

COMS. 

4. Within 60 days of completion of testing, the permittee shall submit to the AQD two copies of the final 

report demonstrating the COMS complies with the requirements of Performance Specification (PS) 1. 

5. The span value shall be 2.0 times the lowest emission standard or as specified in the federal regulations. 

6. The COMS shall be installed, calibrated, maintained, and operated in accordance with the procedures 

set forth in 40 CFR 60.13 and PS 1 of Appendix B, 40 CFR Part 60. 

7. The permittee shall perform an annual audit of the COMS using the procedures set forth in USEPA 

Publication 450/4-92-010, “Performance Audits Procedures for Opacity Monitors”, or a procedure 

acceptable to AQD. Within 30 days after the completion of the audit, the results of the annual audit 

shall be submitted to the AQD. 

8. In accordance with 40 CFR 60.7(c) and (d), the permittee shall submit two copies of an excess emission 

report (EER) and summary report in an acceptable format to Air Quality Division, within 30 days 

following the end of each calendar quarter. The Summary Report shall follow the format of Figure 1 in 

40 CFR 60.7(d). The EER shall include the following information: 

a) A report of each exceedance above the hourly average limits as specified in the MACT 

regulations, Section 63.7833(e) and (g). This includes the date, time, magnitude, cause and 

corrective actions of all occurrences during the reporting period. 

b) A report of all periods of COMS downtime and corrective action. 

c) A report of the total operating time of the EUBOF during the reporting period. 

d) If no exceedances or COMS downtime occurred during the reporting period, the permittee shall 

report that fact. 

9. Within 180 days of permit issuance, Severstal shall do the following: for each day that the ESP opacity 

monitor indicates a one hour average opacity above 10%, Severstal shall keep records of the total power 

input (voltage and secondary current) of the ESP fields and verify that the water flow to the evaporation 

chamber is within standard operating levels. For each day that the ESP opacity monitor indicates a one 

hour average opacity above 10%: if the total power input of the ESP fields exceeds 90% of the 

established baseline value, and water flow to the evaporation chamber is within standard operational 

levels, no further investigation of the cause of the exceedance is required. If the total power input of the 

ESP fields is less than 90% of the established baseline, or if the total power input of the ESP fields 

exceeds 90% of the established baseline value and water flow to the evaporation chamber is below 

standard operational levels, Severstal will initiate an investigation as to the cause of the exceedance. 

This investigation may include such factors as the reason for the lower total power input, the potential 

for condensation in the exhaust stack causing a false opacity exceedance (by checking parameters which 

may include the temperature of the exhaust gas at the COMS, the rate of water to the evaporation 

chamber, outside ambient temperature, operating stage of EUBOF) and performing method 9 opacity 

observations of the ESP stack. The ESP total power input baseline and standard operational evaporation 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 78 of 83 

chamber water input shall be established within 90 days of permit issuance. Upon approval by the 

MDEQ District Office, Severstal may change the parameter used to establish a baseline value, establish 

a new baseline value, and/or use a different trigger percentage of the baseline value to initiate the 

corrective actions described in this paragraph. 

All monitoring data is shall be kept on file for a period of at least five years and made available to the AQD 

upon request. 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 79 of 83 

Appendix 1.7. Emission Calculations 

Any changes proposed to this Appendix shall be submitted to the AQD Southeast Michigan District Office 

and approved, in writing, before the change is implemented. 

The permittee shall use the following calculations to determine compliance with the recordkeeping 

requirements referenced in Table E-01.03 (B-FCE Stoves): 

NOx Monthly Stove emissions = BFGBM x NOx Test Factor (pound NOx per mmcf of BFG) / 2,000 lb/ton 

NOx Annual Stove emissions = BFGBA x NOx Test Factor (pound NOx per mmcf of BFG) / 2,000 lb/ton 

CO Hourly Stove emissions = BFGBD x CO Test Factor (pound CO per mmcf of BFG) / 24 hours 

Where: 

NOx Test Factor is an emission factor based upon site specific stack test data for B-FCE and the CO Test Factor 

is an emission factor based upon available site specific stack test data for C-FCE. Permit data will also be 

evaluated in determining the appropriateness of these factors. 

 BFGBD = actual total Blast Furnace Gas combustion rate on a daily basis, based on a calendar week average, 

 in mmcf BFG for B-FCE. 

 BFGBM = actual total Blast Furnace Gas combustion rate for the previous month in mmcf BFG for B-FCE. 

 BFGBA = actual total Blast Furnace Gas combustion rate for the previous 12-month rolling time period in 

 mmcf BFG for B-FCE. 

The permittee shall use the following calculations to determine compliance with the recordkeeping 

requirements referenced in Table E-01.04 (C-FCE Casthouse): 

SO2 Monthly emissions from baghouse = CRCM x SO2 Test Factor (pound SO2 per ton of iron) / 2,000 lb/ton 

SO2 Annual emissions from baghouse = CRCA x SO2 Test Factor (pound SO2 per ton of iron) / 2,000 lb/ton 

NOx Monthly emissions from baghouse = CRCM x NOx Test Factor (pound NOx per ton of iron) / 2,000 lb/ton 

NOx Annual emissions from baghouse = CRCA x NOx Test Factor (pound NOx per ton of iron) / 2,000 lb/ton 

Where:

SO2 and NOx Test Factors are emission factors based upon site specific stack test data for C-FCE Casthouse 

Baghouse. Permit data will also be evaluated in determining the appropriateness of these factors. 

 CRCM = actual casting rate for the previous month in tons of iron for C-FCE. 

 CRCA = actual casting rate for the previous 12-month rolling time period in tons of iron for C-FCE. 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 80 of 83 

The permittee shall use the following calculations to determine compliance with the recordkeeping 

requirements referenced in Table E-01.05 (C-FCE Stoves): 

NOx Monthly Stove emissions = BFGCM x NOx Test Factor (pound NOx per mmcf of BFG) / 2,000 lb/ton 

NOx Annual Stove emissions = BFGCA x NOx Test Factor (pound NOx per mmcf of BFG) / 2,000 lb/ton 

CO Monthly Stove emissions = BFGCM x CO Test Factor (pound CO per mmcf of BFG) / 2,000 lb/ton 

CO Annual Stove emissions = BFGCA x CO Test Factor (pound CO per mmcf of BFG) / 2,000 lb/ton 

Where: 

NOx and CO Test Factors are emission factors based upon site specific stack test data for C-FCE. Permit data 

will also be evaluated in determining the appropriateness of these factors. 

 BFGCM = actual total Blast Furnace Gas combustion rate for the previous month in mmcf BFG for C-FCE. 

 BFGCA = actual total Blast Furnace Gas combustion rate for the previous 12-month rolling time period in 

 mmcf BFG for C-FCE. 

The permittee shall use the following calculations to determine compliance with the recordkeeping 

requirements referenced in Table E-01.06 (Reladling – BOF): 

PM roof monitor Annual emissions = RLD x 0.0038 pound PM per ton of iron / 2,000 lb/ton 

PM-10 roof monitor Annual emissions = RLD x 0.0019 pound PM-10 per ton of iron / 2,000 lb/ton 

Where: 

 RLD = actual throughput for the previous 12-month rolling time period in tons of iron for reladling 

 operations. 

The permittee shall use the following calculations to determine compliance with the recordkeeping 

requirements referenced in Table E-01.07 (Desulfurization Operation): 

PM roof monitor Annual emissions = DSF x 0.0218 pound PM per ton of iron / 2,000 lb/ton 

PM-10 roof monitor Annual emissions = DSF x 0.0041 pound PM-10 per ton of iron / 2,000 lb/ton 

Where: 

 DSF = actual throughput for the previous 12-month rolling time period in tons of iron for desulfurization 

 operations. 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 81 of 83 

The permittee shall use the following calculations to determine compliance with the recordkeeping 

requirements referenced in Table E-01.08 (EUBOF): 

PM roof monitor Annual emissions = BOFC x 0.006 pound PM per ton metal charged + BOFS x 0.0026 pound 

PM per ton slag tapped + BOFT x 0.0026 pound PM per ton steel tapped / 2,000 lb/ton 

PM-10 roof monitor Annual emissions = BOFC x 0.00276 pound PM-10 per ton metal charged + BOFS x 0.0012 

pound PM-10 per ton slag tapped + BOFT x 0.0012 pound PM-10 per ton steel tapped / 2,000 lb/ton 

Where: 

 BOFC = actual charging rate for the previous 12-month rolling time period in tons of metal for the BOF. 

 BOFS = actual tapping rate for the previous 12-month rolling time period in tons of slag for the BOF. 

 BOFT = actual tapping rate for the previous 12-month rolling time period in tons of steel for the BOF. 

The permittee shall use the following calculations to determine compliance with the recordkeeping 

requirements referenced in Table F-01.01 (FG B&C Furnace Casthouses): 

PM Roof Monitor emissions = CRTA x 0.012 pound PM per ton of iron / 2,000 lb/ton 

PM-10 Roof Monitor emissions = CRTA x 0.0061 pound PM-10 per ton of iron / 2,000 lb/ton 

Manganese Roof Monitor emissions = CRTD x 0.000011 pound manganese per ton of iron / 24 hours 

Lead Roof Monitor emissions = CRTA x 0.00000016 pound lead per ton of iron / 8760 hours per 12-month 

 rolling time period 

SO2 Hourly baghouse emissions = CRTD x SO2 Test Factor (in pound SO2 per ton of iron) / 24 hours 

SO2 Monthly baghouse emissions = CRTM x SO2 Test Factor (pound SO2 per ton of iron) / 2,000 lb/ton 

SO2 Annual baghouse emissions = CRTA x SO2 Test Factor (pound SO2 per ton of iron) / 2,000 lb/ton 

NOx Hourly baghouse emissions = CRTD x NOx Test Factor (in pound NOx per ton of iron) / 24 hours 

NOx Monthly baghouse emissions = CRTM x NOx Test Factor (pound NOx per ton of iron) / 2,000 lb/ton 

NOx Annual baghouse emissions = CRTA x NOx Test Factor (pound NOx per ton of iron) / 2,000 lb/ton 

VOC Hourly baghouse emissions = CRTD x VOC Test Factor (in pound VOC per ton of iron) / 24 hours 

Manganese baghouse emissions = CRTD x Mn Test Factor (in pound manganese per ton of iron) / 24 hours 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 82 of 83 

Lead baghouse emissions = CRTA x Pb Test Factor (in pound lead per ton of iron) / 8760 hours per 12-month 

 rolling time period 

Where: 

SO2, NOx, VOC, Mn and Pb Test Factors are the casthouse baghouse emission factors based upon available site 

specific stack test data for the C-FCE Casthouse Baghouse. Permit data will also be evaluated in determining 

the appropriateness of these factors. 

 CRTD = actual total casting rate on a daily basis, based on a calendar week average, in tons of iron for B-FCE 

 and C-FCE combined. 

 CRTM = actual total casting rate for the previous month in tons of iron for B-FCE and C-FCE combined. 

 CRTA = actual total casting rate for the previous 12-month rolling time period in tons of iron for B-FCE and 

 C-FCE combined. 

The permittee shall use the following calculations to determine compliance with the recordkeeping 

requirements referenced in Table F-01.02 (FG B&C Furnace Stoves - except SO2): 

NOx Annual Stove emissions = [(BFGBA x B-FCE NOx Test Factor (lb NOx per mmcf of BFG)) + (BFGCA x 

 C-FCE NOx Test Factor (lb NOx per mmcf of BFG))] / 2,000 lb/ton 

CO Annual Stove emissions = BFGTA x CO Test Factor (pound CO per mmcf of BFG) / 2,000 lb/ton 

PM Hourly Stove emissions = BFGTD x PM Test Factor (in pound PM per mmcf of BFG) / 24 hours 

PM-10 Hourly Stove emissions = BFGTD x PM10 Test Factor (in pound PM10 per mmcf of BFG) / 24 hours 

Manganese Hourly Stove emissions = BFGTD x Mn Test Factor (in pound Mn mmcf BFG) / 24 hours 

Mercury Hourly Stove emissions = BFGTA x Hg Test Factor (in pound mercury per mmcf BFG) / 8760 hours 

 per 12-month rolling time period 

Lead Hourly Stove emissions = BFGTA x Pb Test Factor (in pound Pb per mmcf BFG) / 8760 hours per 

 12-month rolling time period 

Where: 

NOx Test Factors are individual stove emission factors based on B-FCE and C-FCE stack test results. 

CO, PM, PM-10, Mn, Pb, and Hg Test Factors are emission factors based upon available site specific stack test 

data for C-FCE. Permit data will also be evaluated in determining the appropriateness of these factors. 
Severstal North America, Inc April 19, 2007 

Permit No. 182-05B Page 83 of 83 

 BFGBA = actual total Blast Furnace Gas combustion rate for the previous 12-month rolling time period in 

 mmcf BFG for B-FCE. 

 BFGCA = actual total Blast Furnace Gas combustion rate for the previous 12-month rolling time period in 

 mmcf BFG for C-FCE. 

 BFGTD = actual total Blast Furnace Gas combustion rate on a daily basis, based on a calendar week average, 

 in mmcf BFG for B-FCE and C-FCE combined. 

 BFGTM = actual total Blast Furnace Gas combustion rate for the previous month in mmcf BFG for B-FCE and 

 C-FCE combined. 

 BFGTA = actual total Blast Furnace Gas combustion rate for the previous 12-month rolling time period in 

 mmcf BFG for B-FCE and C-FCE combined. 

The permittee shall use the following calculations to determine compliance with the recordkeeping 

requirements referenced in Table F-01.02 (FG B&C Furnace Stoves - for SO2 emissions): 

SO2 Hourly Stove emissions = BFGTD x SO2 Daily Emission Factor / 24 hours 

SO2 Annual Stove emissions = 

365

1

n

T D

i

(BFG x SO2 Daily Emission Factor)

=

=

∑ / 2,000 lb/ton 

Where: 

BFGTD = actual daily total of BFG (in mmcf) combusted in B-FCE and C-FCE combined 

SO2 Daily Emission Factor = SO2 Emission Factor derived on a daily basis from the SO2 CEMS data provided 

 by the SO2 CEMS on the C-FCE stoves. 

The factor will be in pound SO2 per mmcf BFG and will be calculated either 

directly by the CEMS or by taking the daily pounds of SO2 from C-FCE stoves 

(from the CEMS) and dividing this by the amount of BFG (in mmcf) combusted 

in C-FCE in the same day.