Ms. Mary A. Gade

Regional Administrator

U.S. Environmental Protection Agency

Region V

77 West Jackson Boulevard

Chicago, IL 60604-3950

IDEM INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

We Protect Hoosiers and Our Environment.

Mitchell E. Daniels Jr. 100 North Senate Avenue

Governor Indianapolis. Indiana 46204

(317) 232-8603

Thomas W. Easterly Toll Free (800) 451-6027

Commissioner ~: N.gov

RECE.\\lEO

April 3, 2008

Re: Redesignation Petition and Maintenance

Plan for Southwestern Indiana; Final

Submittal

Dear Ms. Gade:

The Indiana Department ofEnvironmental Management (IDEM) prepared a draft

Redesignation Petition and Maintenance Plan for the Southwestern Indiana Area of Dubois,

Vanderburgh and Warrick Counties; Montgomery Township in Gibson County, Ohio Township in

Spencer County, and Washington Township in Pike County which was designated as

nonattainment ofthe annual standard for fine particles on AprilS, 2005. IDEM conducted a

public hearing concerning the Redesignation Petition and Maintenance Plan on March 27,2008

and the public comment period concluded on March 31, 2008.

Attached hereto is the final Redesignation Petition and Maintenance Plan for Southwestern

Indiana. This final version documents the public review process, including a detailed summary of

and response to substantive comments.

The attached document consists ofthe following:

Redesignation Petition and Maintenance Plan

• A formal request that the Southwestern Indiana nonattainment area for fine particles be

redesignated attainment and reclassified to maintenance. It contains and meets the

requirements set forth in Section 107 ofthe Clean Air Act and in the Redesignation Guidance

issued September 4, 1992.

• A maintenance year of2020 is established and 2010 is analyzed as an interim year.

• The appendices ofthe document contain historic air quality trend data, projected emission

inventory data and thorough documentation ofthe mobile emissions analysis.

• A summary of and response to substantive oral and written comments.

Recycled Paper*

An Equal Opportunity Employer Please Recycle 0
M. Gade

Page 2

Motor Vehicle Emissions Budgets

• Contained in the Redesignation Petition is a new Motor Vehicle Emissions Budget for 2010

and 2020. The Evansville Urban Transportation Study's travel demand model and MOBILE6

were used to determine emissions for the annual fine particle nonattainment area.

• A conservative margin ofsafety was applied to the 2010 and 2020 projected emissions.

• The Travel Demand Model was updated with the best available assumptions.

• Vehicle Registration data gathered from the Indiana Bureau ofMotor Vehicles was used to

replace the MOBILE6 default vehicle age distribution.

IDEM is yet to receive the transcript ofthe Public Hearing conducted on March 27,2008.

Upon receipt ofthe transcript, a copy will be forwarded to your staff under separate cover.

IDEM hereby requests that the U.S. EPA proceed with final review and approval ofthis

submittal. If you have any questions or need additional information, please contact Shawn Seals,

ofthe Air Programs Branch, at (317) 233-0425.

DM/sad/sms

Attachments

cc: Jay Bortzer, US EPA (no enclosures)

John Mooney, US EPA (no enclosures)

Cheryl Newton, US EPA (no enclosures)

Pat Morris, US EPA (w/enclosures)

Steve Rosenthal, US EPA (w/enclosures)

Scott Deloney, IDEM

Shawn Seals (IDEM)
REQUEST FOR REDESIGNATION AND

MAINTENANCE PLAN

UNDER THE ANNUAL NATIONAL_>-~

AMBIENT AIR QUALITY r£~ "1 'I"\l~ STANDARD FOR FINE PARTICL IS ~?""('s~s\'riBBPS\\C\-1' /\IBE.\\\f08v BE.GION 5 t"' \J.S.E.I'F>-·"~-

Southwestern Indiana Area

Prepared By:

The Indiana Department ofEnvironmental Management

March 2008
This page intentionally left blank

11
TABLE OF CONTENTS (page numbers subject to change)

1.0 INTRODUCTION 1

1.1 Background 2

1.2 Geographical Description 3

1.3 Status ofAir Quality 3

2.0 REQUIREMENTS FOR REDESIGNATION 3

2.1 General 3

2.2 Fine Particles Monitoring 3

2.3 Emission Inventory 4

2.4 Modeling Demonstration 4

2.5 Controls and Regulations 4

2.6 Corrective Actions for Potential Future Violations ofthe Fine Particles Standard 5

3.0 FINE PARTICLES MONITORING 5

3.1 Fine Particles Monitoring Network. 5

3.2 Ambient Fine Particles Monitoring Data 6

3.3 University ofEvansville Incomplete Monitoring Data 9

3.4 Quality Assurance 9

3.5 Continued Monitoring 9

4.0 EMISSION INVENTORY 9

4.1 Emission Trends 10

4.2 Base Year Inventory 19

4.3 Emission Projections 19

4.4 Demonstration ofMaintenance 23

4.5 Permanent and Enforceable Emission Reductions 23

4.6 Provisions for Future Updates 24

5.0 TRANSPORTATION CONFORMITY BUDGETS 24

5.1 On-Road Emission Estimations 24

5.2 Overview 25

5.3 Analysis years 25

5.4 Emission Estimations 25

5.5 Motor Vehicle Emission Budget. 26

111
6.0 CONTROL MEASURES AND REGULATIONS 26

6.1 Reasonably Available Control Technology (RACT) 26

6.2 Implementation of Past SIP Revisions 27

6.3 Nitrogen Oxides(NOx) Rule 27

6.4 Measures Beyond Clean Air Act SIP Requirements 28

6.5 Controls to Remain in Effect 30

6.6 New Source Review Provisions 31

7.0 MODELING AND METEOROLOGy .31

7.1 Summary ofModeling Results to Support Rulemakings 31

7.2 LADCO's Round 5 Speciated Modeled Attainment Test Results 35

7.3 LADCO's Round 5 Particulate Source Apportionment Results 36

7.4 Summary ofExisting Modeling Results .38

7.5 Meteorological Analysis for Southwest Indiana 39

7.6 Surface Air Conditions Present during High Fine Particle Concentration Days .39

7.7 Upper Air Conditions Present during High Fine Particle Concentration Days 39

7.8 Analysis of Atmospheric Conditions during High Fine Particle Concentration Days .40

7.9 Summary ofMeteorological Analysis for Southwest Indiana .41

8.0 CORRECTIVE ACTIONS 41

8.1 Commitment to Revise Plan 41

8.2 Commitment for Contingency Measures .42

8.3 Contingency Measures 42

9.0 PUBLIC PARTICIPATION 43

10.0 CONCLUSIONS 44

FIGURES

Figure 3.1 Southwest Indiana Nonattainment Area 6

Figure 4.1 Regional NOxEGU Reductions between 2002 and 2006 .16

Figure 4.2 Regional S02 EGU Reductions between 2002 and 2006 18

TABLES

Table 1.1 National Ambient Air Quality Standards for Fine Particles 2

Table 3.1 Monitoring Data for the Southwestern Indiana Area 7

Table 4.1 Comparison of2005 Estimated and 2020 Projected Emission Estimates Southwestern

Indiana Area 22

Table 5.1 Emissions Estimates for On-Road Mobile Sources 25

IV
Table 5.2 Motor Vehicle Emission Budgets in Tons per Year 26

Table 6.1 Trends in EGU NOx Emissions Statewide in Indiana 28

Table 7.1 Modeling Results from U.S. EPA for the Clean Air Interstate Rule .32

Table 7.2 LADCO's Round 5 Modeling Results for the Clean Air Interstate Rule .33

Table 7.3 Southwest Indiana Design Value Comparison With and Without 2007 .34

Table 7.4 LADCO's Round 5 SMAT Modeling Results .36

Table 7.5 Ranking ofHighest Number ofDays at AQI Levels ofHealth Concern 41

GRAPHS

Graph 3.1 Design Values for the Southwestern Indiana Nonattainment Area for Fine Particles 7

Graph 3.2 Southwestern Indiana Annual Fine Particle Trends, 2000 through 2006 8

Graph 4.1 Southwestern Indiana Area NOx Point Source Emissions Trends 10

Graph 4.2 Southwestern Indiana Area S02 Point Source Emissions Trends 11

Graph 4.3 Southwestern Indiana Area Direct PM2.5Point Source Emissions Trends 11

Graph 4.4 NOx Emissions Trends, All Sources in the Southwestern Indiana Area 12

Graph 4.5 S02 Emissions Trends, All Sources in the Southwestern Indiana Area 13

Graph 4.6 Direct PM2.5Emissions Trends, All Sources in the Southwestern Indiana Area 13

Graph 4.7 NOx Emissions from Electric Generating Units, 1996 to 2006 15

Graph 4.8 S02 Emissions from Electric Generating Units, 1996 to 2006 , · 17

Graph 4.9 Comparison of2005 Estimated and 2010 and 2020 Projected NOx Emissions for the

Southwestern Indiana Area 20

Graph 4.10 Comparison of2005 Estimated and 2010 and 2020 Projected S02 Emissions for the

Southwestern Indiana Area , 21

Graph 4.11 Comparison of2005 Estimated and 2010 and 2020 Projected Direct PM2.5 Emissions

for Southwestern Indiana Area 21

Graph 4.12 Comparison of 2005 Estimated and 2010 and 2020Projected Direct PM2.5 Emissions

Trends for the Southwestern Indiana Area 22

Graph 7.1 Modeling Results for Southwest Indiana PM2.5 Monitors for 2009, 2012 and 2018 .35

CHARTS

Chart 7.1 Regional/Emission Sector PSAT Results Jasper, Dubois County PM2.5 Monitor .37

Chart 7.2 Species Modeled Contributions to Jasper, Dubois County PM2.5Monitor .38

Chart 7.3 Species Modeled Contributions to University ofEvansville PM2.5 Monitor .38

Chart 7.4 Distribution ofPM2.5 Concentration Days on the AQI Levels ofHealth Concern .40

APPENDICES

A Air Quality System (AQS) and IDEM Monitor Data Values (2004-2006)

B Air Quality System (AQS) and IDEM Monitor Data Values (2005-2007)

C University ofEvansville Incomplete PM2.5 Monitoring Data Analysis

D 2005-2007 Indiana Monitoring Data Summary Supplement

v
E NOx, S02 and Direct PM2.5 Point Source Emissions (2002-2005)

F NOx, S02 and Direct PM2.5Emission Trends, All Sources (2002-2005)

G NOx and S02 Emissions from Electric Generating Units, Southwest Indiana Area

H NOx and S02 Emissions from Electric Generating Units, Six State Region

I NOx, S02 and Direct PM2.5 2005 Base Year Emissions Inventory and 2010 and 2020

Projected Emissions

J Example Mobile Source Input/Output Calculation Files

K IDEM Area Source Inventory - Standard Operating Procedure

L Lake Michigan Air Directors Consortium Emission Estimates Technical Support

Document

M Lake Michigan Air Directors Consortium Round 5 Modeling Technical Support

Document

N Public Participation Process Documents
REQUEST FOR REDESIGNATION AND MAINTENANCE PLAN

UNDER THE ANNUAL NATIONAL AMBINET AIR

QUALITY STANDARD FOR FINE PARTICLES

SOUTHWESTERN INDIANA AREA

1.0 INTRODUCTION

This document is intended to support Indiana's request that Dubois, Vanderburgh and

Warrick Counties; Montgomery Township in Gibson County, Ohio Township in Spencer

County, and Washington Township in Pike County (herein referred to as the

"Southwestern Indiana Area"), be redesignated from nonattainment to attainment ofthe

annual standard for fine particles. The Southwestern Indiana Area has recorded three (3)

years of quality assured ambient air quality monitoring data for the years 2004 through

2006 demonstrating attainment with the annual standard for fine particles, and is thereby

eligible for redesignation.

Section 107 ofthe Clean Air Act (CAA) establishes specific requirements to be met in

order for an area to be considered for redesignation including:

(a) A determination that the area has attained the annual standard for fine

particles.

(b) An approved State Implementation Plan (SIP) for the area under Section

11O(k).

(c) A determination that the improvement in air quality is due to permanent

and enforceable reductions in emissions resulting from implementation of

the SIP and other federal requirements.

(d) A fully approved maintenance plan under Section 175A.

(e) A determination that all Section 110 and Part D requirements have been

met.

A maintenance plan provides for the continued attainment ofthe air quality standard by

an area for a period often years after the United States Environmental Protection Agency

(U.S. EPA) has formally redesignated the area to attainment. The plan also provides

assurances that even ifthere is a subsequent exceedance ofthe air quality standard that

measures in the maintenance plan will prevent any future occurrences through

contingency measures that would be triggered.

This document addresses each ofthese requirements, and provides additional information

to support continued compliance with the annual standard for fine particles.

1
1.1 Background

The Clean Air Act Amendments of 1990 (CAAA) requires areas designated

nonattainment for the National Ambient Air Quality Standard (NAAQS) for particulate

matter to develop SIPs to expeditiously attain and maintain the standard. In 1997, U.S.

EPA set daily and annual air quality standards for fine particles (fine particulate matter),

as shown in Table 1.1 below. The standards were legally challenged and upheld by the

U.S. Supreme Court in February of 2001. In 1999 Indiana began monitoring for fine

particles. The U.S. EPA designated areas in Indiana under the standards for fine particles

on December 17, 2004 as attainment, nonattainment or unclassifiable, with an effective

date ofAprilS, 2005..

Table 1.1

National Ambient Air Quality Standards for Fine Particles

Annual 24-Hour

1997 Fine Particles 15 J1g1m3 65 J1g1m3

Standards (PM2.5)

Annual arithmetic mean, 24-hour average, 98th percentile,

averaged over 3 years averaged over 3 years

2006 Fine Particles 15 J1g1m3 35 J1g1m3

Standards (PM2.5)

Annual arithmetic mean, 24-hour average, 98th percentile,

averaged over 3 years averaged over 3 years

Note: The Southwestern Indiana Area meets the 1997 and 2006 annual and 24-hour NAAQS for

fine particles. The 24-hour design value for the area at the close of2006 is 34 ~g/m3. Since this

area is solely designated nonattainment under the 1997 annual standard for fme particles, this

document addresses only addresses the annual standard.

On December 17,2004, based on 2001-2003 monitoring data, U.S. EPA designated the

Southwestern Indiana Area ofDubois, Vanderburgh and Warrick Counties; Montgomery

Township in Gibson County, Ohio Township in Spencer County, and Washington

Township in Pike County as nonattainment ofthe annual standard for fine particles, and

subject to Section 107 CAA requirements, including the development of a plan to reduce

oxides ofnitrogen (NOx), sulfur dioxide (S02) and direct PM2.

5 emissions and a

demonstration that the area will meet the annual standard for fine particles by April 15,

2010. There were no monitors in Indiana that violated the 1997 24-hour standard for fine

particles.

The Southwestern Indiana Area as defined in Sections 1.1 and 1.2 has not previously been

subject to nonattainment area rulemakings for fine particles. However, Vanderburgh and

Warrick Counties had been subject to nonattainment area rulemakings under the I-hour

and 8-hour ozone standards. The I-hour ozone standard was revoked on June 15,2005

and both Vanderburgh and Warrick Counties were redesignated to attainment and

classified as maintenance under the 8-hour ozone standard on January 30, 2006.

2
1.2 Geographical Description

The Southwestern Indiana Area includes Dubois, Vanderburgh and Warrick Counties and

Montgomery Township in Gibson County, Ohio Township in Spencer County, and

Washington Township in Pike County and contains such cities as Evansville, Jasper,

Yankeetown, Inglefield, Boonville, Huntingburg, Petersburg, Owensville, Ferdinand,

Rockport, Chandler, Newburgh and Kasson. This area is depicted in Figure 3.1.

1.3 Status ofAir Quality

Monitoring data for fine particles for the three (3) years, 2004 through 2006,

demonstrates that air quality has met the annual NAAQS for fine particles in the

nonattainment area. This fact, accompanied by the permanent and enforceable reductions

in emission levels discussed in Section 4.0, justifies a redesignation to attainment for the

subject area based on Section 107(d)(3)(E) ofthe CAAA.

2.0 REQUIREMENTS FOR REDESIGNATION

2.1 General

Section 110 and Part D ofthe CAAA list a number ofrequirements that must be met by

nonattainment areas prior to consideration for redesignation to attainment. In addition,

U.S. EPA has published detailed guidance in a document entitled Proceduresfor

Processing Requests to Redesignate Areas to Attainment, issued September 4, 1992, to

Regional Air Directors. This document is hereafter referred to as "Redesignation

Guidance". This Request for Redesignation and Maintenance Plan is based on the

Redesignation Guidance, supplemented with additional guidance received from staff of

the Regulatory Development Section ofU.S. EPA Region V.

The subsections below refer in greater detail to the requirements listed in Section 1.0 of

this document. Each subsection describes how the requirement has been met.

2.2 Fine Particles Monitoring

1) A demonstration that the annual standard for fine particles, as published in

40 CFR 50.4, has been attained. Fine particles monitoring data must show

that violations ofthe annual ambient standard are no longer occurring.

2) Ambient monitoring data quality assured in accordance with 40 CFR

58.10, recorded in the U.S. EPA Air Quality System (AQS) database, and

available for public view.

3
3) A showing that the three-year average of annual values, based on data

from all monitoring sites in the area or its affected downwind environs, do

not exceed 15.0 micrograms per cubic meter (llg/m3). This showing must

rely on three complete, consecutive calendar years of quality assured data.

4) A commitment that, once redesignated, the State will continue to operate

an appropriate monitoring network to verify the maintenance ofthe

attainment status.

2.3 Emission Inventory

1) A comprehensive emission inventory of direct fine particles and the

precursors offine particles completed for the base year (2005 in this case).

2) A projection ofthe emission inventory to a year at least ten years

following redesignation.

3) A demonstration that the projected level of emissions is sufficient to

maintain the annual fine particles standard.

4) A demonstration that improvement in air quality between the year

violations occurred and the year attainment was achieved is based on

permanent and enforceable emission reductions and not on temporary

adverse economic conditions or unusually favorable meteorology.

5) Provisions for future annual updates ofthe inventory to enable tracking of

the emission levels, including an annual emission statement from major

sources.

2.4 Modeling Demonstration

While no modeling is required for redesignating nonattainment areas, the Indiana

Department ofEnvironmental Management (IDEM) has evaluated the results offederal

control-case modeling to demonstrate compliance with the standard will be maintained.

2.5 Controls and Regulations

1) A U.S. EPA-approved SIP control strategy that includes Reasonably

Available Control Technology (RACT) requirements for existing

stationary sources covered by Control Technology Guidelines (CTG) and

non-CTG RACT for all major sources.

2) Evidence that control measures required in past SIP revisions have been

fully implemented.

4
3) Acceptable provisions to provide for new source review.

4) Assurances that existing controls will remain in effect after redesignation,

unless the State demonstrates through photochemical modeling that the

standard can be maintained without one or more controls.

5) If appropriate, a commitment to adopt a requirement that all transportation

plans conform with and are consistent with the SIP.

2.6 Corrective Actions for Potential Future Violations ofthe Fine Particles Standard

1) A commitment to submit a revised plan eight (8) years after redesignation.

2) A commitment to expeditiously enact and implement additional

contingency control measures in response to exceeding specified

predetermined levels (triggers) or in the event that future violations ofthe

ambient standard occur.

3) A list of potential contingency measures that would be implemented in

such an event.

4) A list ofNOx, S02, and direct PM2.5 sources potentially subject to future

controls.

3.0 FINE PARTICLES MONITORING

3.1 Fine Particles Monitoring Network

There are currently four Federal Reference Method monitors measuring fine particle

concentrations in this nonattainment area. These monitors are located as follows: Dubois

County (Jasper, Indiana), Vanderburgh County (Mill Road, Civic Center, University of

Evansville; Evansville, Indiana). The four monitors are operated by IDEM's Office of

Air Quality (OAQ). A listing ofthe monitor readings from 2004 through 2006 are shown

in Table 3.1 and Appendix A and were retrieved from the U.S. EPA's Air Quality System

(AQS). The locations ofthe monitoring sites for this nonattainment area are shown on

Figure 3.1.

IDEM's OAQ also operates three monitors in the Southwestern Indiana geographic area

that collect background fine particle concentrations. While these monitors are not used to

determine attainment with the annual fine particles standard the monitoring locations are

included as supporting material.

5
Figure 3.1

Southwest Indiana Nonattainment Area

Legend

6. PM 2.5 Monitor

• Background PM 2.5 Monitor

- Interstate Highway

- U. S. Highway

PM 2.5 Counties

o Attainment

o PM 2.5 Nonattainment

Crawford

3.2 Ambient Fine Particles Monitoring Data

The following information summarizes U.S. EPA's "Guideline on Data Handling

Conventions for the PM NAAQS," U.S. EPA-454/R-99-008, April 1999. Three complete

years offine particles monitoring data are required to demonstrate attainment at a

monitoring site. The annual ambient air quality standard for fine particles is met at an

ambient air quality monitoring site when the three year average ofthe annual average of

fine particle concentrations (or the design value) is less than or equal to 15.0 ~g/m3.

When this occurs, the site is said to be in attainment. While calculating design values,

three significant digits must be carried in the computations, with final values rounded to

the nearest 0.1 ~g/m3. Decimals 0.05 or greater are rounded up, and those less than 0.05

are rounded down, so that 15.049 ~g/m3 is the largest concentration that is less than, or

equal to 15.0 ~g/m3. Values at or below 15.0 ~g/m3meet the standard; values equal to or

greater than 15.1 ~g/m3 exceed the standard.

Data handling procedures are applied on an individual basis at each monitor in the area.

An individual site's three year average ofthe annual average fine particles concentration

is also called the site's design value. An area is in compliance with the annual NAAQS

for fine particles if, and only if, all monitoring sites meet the NAAQS. The air quality

design value for the area is the highest design value among all sites in the area. Table 3.1

outlines the annual fine particles values by site and the 2004 through 2006 design values

for the four active fine particles monitoring sites in the Southwestern Indiana Area.

6
Table 3.1

Monitoring Data for the Southwestern Indiana Area

(Annual Average and Design Values)

SITE In COUNTY SITE NAME YEAR Annual Average 2004-2006

J.L2Im3 Average J.L2Im3

18-037-2001 Dubois Jasper 2004 14.42

18-037-200I Dubois Jasper 2005 16.92

18-037-200I Dubois Jasper 2006 13.54 15.0

18-163-0006 Vanderburgh Civic Center 2004 13.23

18-163-0006 Vanderburgh Civic Center 2005 16.49

18-163-0006 Vanderburgh Civic Center 2006 13.72 14.5

18-163-0012 Vanderburgh Mill Road 2004 13.46

18-163-0012 Vanderburgh Mill Road 2005 16.29

18-163-0012 Vanderburgh Mill Road 2006 14.05 14.6

18-163-0016 Vanderburgh Univ ofEvansville 2004 13.68

18-163-0016 Vanderburgh Univ ofEvansville 2005 16.67

18-163-0016 Vanderburgh Univ ofEvansville 2006 14.15 14.8*

*incomplete data, see Appendix C

The graph below visually demonstrates the 2004 through 2006 design values for this

nonattainment area.

Graph 3.1

Design Values for the Southwestern Indiana Nonattainment Area for Fine Particles,

2000 through 2006

Three-Year Design Values For Fine Particles

17.0 .,-----------------------,

16.5

16.0 'E 15.5

0, 15.0 ..........- ::J 14.5

14.0

13.5

13.0 +-'-.....&-..............

200 W 6th St Ci~c Center

Jasper Ewns~lIe

WMiIIRd

Ewns~lIe

Univof

Ewns~lIe

Ewns~lIe

2000-2002" c:::::J 2001-2003 c::::::J 2002-2004 2003-2005 _ 2004-2006 - Standard

7
Graph 3.2

Southwestern Indiana Annual Fine Particle Trends, 2000 through 2006

Annual Fine Particle Trends

18.00

17.00

16.00

15.00

14.00

13.00

12.00

2000 2001 2002 2003 2004 2005 2006

-+- Jasper ....Civic Center Mill Road ""*"" U of Evansville

The design values calculated for the Southwestern Indiana Nonattainment Area

demonstrates that the annual NAAQS for fine particles has been attained.

Graph 3.1 shows the trend in design values for the region, while graph 3.2 shows the

annual fine particle trends. A comprehensive list ofthe four fme particle monitoring

sites' design values over this period is outlined within Appendices A and B. The area's

design values have recently trended downward, as emissions have declined due to such

programs as the Acid Rain program and cleaner automobiles and fuels both regionally

and locally. U.S. EPA's rule to control nitrogen oxides from specific source categories

(40 CFR Parts 51, 72, 75 and 96, published on October 17, 1998 and referred to as the

"NOx SIP Call") has significantly reduced emissions from large electric generating units

(EGUs), industrial boilers, and cement kilns. Indiana's NOx Rule was adopted on June 6,

2001 (326 lAC 10-3 and 10-4). The elevated value for 2005 is considered an abnormal

occurrence. An analysis ofmeteorological conditions and monitoring values is included

in Section 7.0 and supports the conclusion that attainment ofthe standard as of2006 is

not the result of unusually favorable meteorological conditions. It is expected that this

downward trend will continue as the above programs continue and the U.S. EPA Clean

Air Interstate Rule is implemented.

8
3.3 University of Evansville Incomplete Monitoring Data

During the second quarter of2005 the University ofEvansville (UE) monitor located in

Vanderburgh County, Indiana, Site ID 18-163-0016, recorded an overall Valid Data

Return (VDR) for fine particles of 68%. According to U.S. EPA guidance, the

monitoring data for 2004-2006 (14.8 Ilglm3) for the University ofEvansville monitor

located in Vanderburgh County, Indiana is incomplete. The U.S. EPA required VDR is

75%. Therefore, an analysis ofmissing data during the second quarter of 2005 was

conducted and is detailed in Appendix C. According to the Guideline on Data Handling

Conventionsfor the PMNAAQS, issued April 1999, U.S. EPA states that the incomplete

design value of 14.8 Ilglm3, is still identified as the monitors true design value.

3.4 Quality Assurance

IDEM has quality assured all data shown in Appendices A and B in accordance with 40

CFR 58.10 and the Indiana Quality Assurance Manual. IDEM has recorded the data in

the AQS database and, thus, the data are available to the public.

3.5 Continued Monitoring

Indiana commits to continue monitoring concentrations offine particles at the sites

indicated in Table 3.1 and Appendices A and B. IDEM will consult with U.S. EPA

Region V staff prior to making changes to the existing monitoring network, should

changes become necessary in the future. IDEM will continue to quality assure the

monitoring data to meet the requirements of 40 CFR 58. IDEM will enter all data into

AQS on a timely basis in accordance with federal guidelines.

4.0 EMISSIONS INVENTORY

U.S. EPA's Redesignation Guidance and Implementation Rule requires the submittal ofa

comprehensive inventory of precursor emissions for fine particles (SOz, direct PMz.

5 and

NOx ) representative ofthe year when the area achieves attainment ofthe NAAQS for

annual fine particles (base year). Indiana is using 2005 as the base year because it

represents the center ofthe three-year design value. Indiana must also demonstrate that

the improvement in air quality between the year that violations occurred and the year that

attainment was achieved is based on permanent and enforceable emission reductions.

Other emission inventory related requirements: include a projection ofthe emission

inventory to a year at least ten (10) years following redesignation; a demonstration that

the projected level of emissions is sufficient to maintain the annual fine particles

standard; and a commitment to provide future updates ofthe inventory to enable tracking

of emission levels during the ten (10) year maintenance period. Consistent with the

federal implementation rule for fine particles, Indiana does not consider volatile organic

compounds or ammonia to be significant contributors to fine particles. The following

subsections address each ofthese requirements.

9
4.1 Emission Trends

Point Sources

Graphs 4.1, 4.2 and 4.3 below show the trend in point source emissions ofNOx, S02 and

direct PM2.5 respectively that generally correspond to the years ofmonitored values used

in this report. The point source data are taken from Indiana's annual emissions reporting

program. The Southwestern Indiana Area had a 32% reduction in NOx point source

emissions, and a slight increase (4.8%) in S02point source emissions. A moderate

increase in direct PM2.5 point source emissions is noted, but this increase in direct PM2.5

emissions from 2002 to 2005 is due to the fact that most companies did not submit their

direct PM2.5 emissions data in 2002 but did submit direct PM2.5 data in the 2005

emissions inventory. Though a moderate increase in direct PM2.5 point source emissions

is depicted, the total anthropogenic direct PM2.5 emissions have remained consistent

within this period. See Graph 4.6 depicting the trend of PM2.5 emissions from all

anthropogenic sources. Regional NOx emission reductions affect fine particle levels in

the Southwestern Indiana Area far more so than NOx emission reductions within the area

itself. As Graph 4.7 illustrates, Southwest Indiana NOx emissions from electric generating

units have decreased substantially during this time period as well. Graphs and data tables

of emissions from each source category are available in Appendix F.

Graph 4.1

Southwestern Indiana Area NOx Point Source Emission Trends

2002 and 2005

Southwest Indiana NOx Point Source

Emission Trends

150,000 -,------------------.

120,000 +----

90,000 +----

ca 60,000 +---

c 30,000 +----

0+---

2002

10

2005
Graph 4.2

Southwestern Indiana Area SOl Point Source Emission Trends

2002 and 2005

Southwest Indiana S02 Point Source

Emission Trends

400,000 --r---------------------,

In 320,000 -+---

c

o

I-;" 240,000 -+---

ftS

I 160,000 -+---- c

c( 80,OOO-+---

0+---

2002 2005

Graph 4.3

Southwestern Indiana Area Direct PMl.5 Point Source Emission Trends

2002 and 2005

Southwest Indiana Direct PM2.5 Point Source

Emission Trends

5,000 ,----------------------,

! 4,000 +-----------------------1

o

I-;" 3,000 +-------------

ftS 2,000 +----

C

c( 1,000 -1---

o -t----

2002 2005

ImDirect PM2.51

11
All Anthropogenic Sources

Periodic inventories, which include emissions from all sectors (mobile, area, non-road,

and point sources), were prepared for 2002 and 2005. Graphs 4.4, 4.5 and 4.6 show the

trends for the total emissions for all anthropogenic source categories in these years, for

NOx, S02 and direct PM2.5, which also roughly follow the years ofmonitored trends

discussed in Section 3. Graph 4.5 shows a slight increase in S02 over time but as can be

seen from the graphs there is a downward trend in NOx and direct PM2.5 emissions from

2002 to 2005. The decrease in NOx can be largely attributed to those EGUs located

within and surrounding the Southwestern Indiana Area that have reduced their NOx

emissions as a result ofthe NOx SIP Call. Graphs and data tables of emissions from each

source category are available in Appendix F.

Graph 4.4

NOxEmission Trends, All Sources in the Southwestern Indiana Area

2002 and 2005

NOx Trends- All Anthropogenic Sources

Southwestern Indiana Area

160,000 -r----------------------,

120,000 +----

o

... 'iii 80,000 +----

C

40,000 +---,

o -+--__---J

2002

12

2005
Graph 4.5

S02 Emission Trends, All Sources in the Southwestern Indiana Area

2002 and 2005

S02 Trends- All Anthropogenic Sources

Southwestern Indiana Area

400,000 ..,.....---------------------,

tn 320,000 +----

c

240,000 +----

ca

160,000 +----

c

c( 80,000 +----

0-+----

2002 2005

Graph 4.6

Direct PM2.5 Emission Trends, All Sources in the Southwestern Indiana Area

2002 and 2005

Direct PM2.5 Trends- All Anthropogenic Sources

Southwestern Indiana Area

15,000 -r---------------------,

12,000 +------------------------1

9,000 +-----------------------1

iig 6,000 +----------------------------l

3,000 +----

0-1----

2002

I Direct PM2.sl

13

2005
EGUSources

Graphs 4.7 and 4.8 depict the trends in NOx and S02 emissions from Southwest Indiana

EGUs for the years 1999 to 2006. While fine particles and its precursors are transported

into this region from outside the area, this information does provide some indication of

the impact that Indiana EGU sources may have on the nonattainment area. Both NOx and

S02 emissions are decreasing substantially in response to national programs affecting all

EGUs such as the Acid Rain program and the NOx SIP Call. Other sectors ofthe

inventory also impact the formation offine particles, but large regional sources such as

EGUs have a substantial impact on the formation offine particles.

These data were taken from U.S. EPA's Clean Air Markets database!, Data are available

sooner for these units than other point sources in the inventory because ofthe NOx SIP

Call budget and trading requirements. Information from 2003 is significant because some

EGUs started operation oftheir NOx SIP Call controls in order to generate Early

Reduction Credits for their future year NOx budgets. The first season ofthe SIP Call

budget period began May 31, 2004.

As part ofthe NOx SIP Call, the states were required to adopt into their rules a budget for

all large EGUs. Indiana's budget is referenced in 326 IAC 10-4, and first season ofthe

SIP Call budget period began May 31, 2004. The budget represents a statewide cap on

NOx emissions. Although each unit is allocated emissions based upon historic heat input,

utilities can meet this budget by over-controlling certain units or purchasing credits from

the market to account for overages at other units. To summarize, NOx emissions have

dramatically decreased over the years represented on these graphs.

These emissions, capped by the state rule, are expected to remain near these levels

throughout the maintenance period covered by this request. However, since EGUs can

purchase allowances from out ofstate, there is a possibility for NOX emissions to

increase. The state cap for the NOx SIP Call will stay in place through 2008, at which

time the Clean Air Interstate Rule (CAIR) program will supersede it. The Clean Air

Interstate Rule (CAIR), issued in March 2005, adopted by the Indiana Air Pollution

Control Board on November 1,2006, and to be implemented by 2010, will reduce

regional EGU NOx emissions statewide by approximately another 17% in 2015.

As demonstrated by Figure 4.1, significant reductions ofNOx associated with the NOx

SIP Call and preparation for CAIR have been achieved statewide as well as regionally.

For the six state (Arkansas, Indiana, Illinois, Kentucky, Missouri and Tennessee) region

shown in Figure 4.1 within the area south oflatitude 38 and west oflongitude -87 (the

southwest quadrant denoted by brown lines), there has been a reduction in upwind EGU

emissions ofmore than 72,000 tons ofNOx from 2002 to 2006. The specific EGU

emissions for NOx and S02 from the southwest quadrant, as well as the change in

emissions from 2002 to 2006 are listed in Appendix G.

1 http://www.epa.gov/airmarkets

14
Graph 4.7

NOll Emissions from Electric Generating Units, 1999 to 2006

Southwest IN NOx Emissions from EGUs

160,000,--------------------------,

140,000

120,000

100,000

(I)

80,000 .... 60,000

40,000

20,000

o

1999 2000 2001 2002 2003 2004 2005 2006

15
Figure 4.1 Regional NOx Reductions Between 2002 and 2006

NOx Difference 2006 - 2002

Difference in Tons Per Year

• > -9430.0

• -9429.9 - -4864.0

• -4863.9 - -1.0

-0.9 -1.0

.1.1-7.0

• 7.1 - 1468.0

• > 4051.0

16
As demonstrated by Figure 4.2, reductions ofregional S02 from upwind EGUs have also

been achieved. For the six state (Arkansas, Indiana, Illinois, Kentucky, Missouri and

Tennessee) region shown in Figure 4.2 in the area south oflatitude 38 and west of

longitude -87 (the southwest quadrant denoted by the brown lines), there has been a

reduction ofupwind EGU emissions ofnearly 15,000 tons ofS02from 2002 to 2006.

The specific EGU emissions for NOx and S02 from the southwest quadrant, as well as the

change from 2002 to 2006 are listed in Appendix G.

Although there are minor fluctuations in the S02 emissions over time, as shown in Graph

4.8, there are moderate reductions to date. As noted by Graph 4.10 we do expect to see

significant reductions in S02 emissions from CAIR and BART (Best Available Retrofit

Technology), once implemented. As a result ofCAIR, five EGU's will achieve

significant reductions in S02. ALCOA will install scrubbers on all units by 2008 that will

result in a 90% reduction in S02 emissions. Cayuga, Clifty Creek and Wabash Valley are

in the process ofinstalling Flue Gas Desulfurization (FGD) systems which will also result

in 90% reductions in S02 at those facilities. Edwardsport is replacing all ofthe coal fired

boilers with an Integrated Gasification Combined Cycle (IGCC) system which will result

in a slight increase in NOx of 32.49 tons per year and a huge reduction in S02 of9,834

tons per year. Also, as a result of a recent settlement agreement, AEP Rockport is

installing scrubbers to achieve a 90% reduction in S02. Appendix E shows detailed

emissions for the point source emissions, and Appendix G shows detailed emissions for

the Electric Generating Units.

Graph 4.8

802 Emissions from Electric Generating Units, 1999 to 2006

80uthvvest IN 802 Emissions from EGUs

II)

c

o

....

1,000,000,-----------------------,

900,000

800,000

700,000

600,000

500,000

400,000

300,000

200,000

100,000

o

1999 2000 2001 2002 2003 2004 2005 2006

IF!ilS02J

17
Figure 4.2 Regional S02 Reductions Between 2002 and 2006

502 Difference 2006 - 2002

Difference in Tons Per Year

• > -17600.0

• -17599.9 - -6300.0

• -6299.9 - -1.0

-0.9 -1.0

• 1.1 - 2100.0

• 2100.1 - 8400.0

• 8400.1 - 30350.0

18
4.2 Base Year Inventory

IDEM prepared a comprehensive inventory for the Southwestern Indiana Area, including

area, mobile, non-road and point sources for direct PM2.5 and precursors offine particles

for base year 2005 (the middle year ofthe area's attainment design value).

• Area sources were grown from the Indiana 2002 periodic inventory submitted to

U.S. EPA.

• Mobile source emissions were calculated from MOBILE 6.2 produced emission

factors and data extracted from the region's travel-demand model. These

emissions were then interpolated as needed to determine 2005 base year values.

• Point source information was compiled from IDEM's annual emissions statement

database.

• Biogenic emissions are not included in these summaries.

• Nonroad emissions were grown from the 2002 National Emissions Inventory

(NEI). To address concerns about the accuracy ofsome ofthe categories in U.S.

EPA's nonroad emissions model, the Lake Michigan Air Directors' Consortium

(LADCO) (Midwest Regional Planning Organization), contracted with two (2)

companies to review the base data and make recommendations. One ofthe

contractors also estimated emissions for two (2) nonroad categories not included

in U.S. EPA's nonroad model. Emissions were estimated for commercial marine

vessels and railroads. Recreational motorboat population and spatial surrogates

(used to assign emissions to each) were significantly updated. The populations for

the construction equipment category were reviewed and updated based upon

surveys completed in the Midwest and the temporal allocation for agricultural

sources was also updated. A new nonroad estimation model was provided by U.S.

EPA for the 2002 analysis.

Appendix F contains data tables and graphs of all these emissions.

4.3 Emission Projections

In consultation with the U.S. EPA and other stakeholders, IDEM selected the year 2020 as

the maintenance year for this redesignation request. This document contains projected

emission inventories for 2010 and 20203 for the Southwestern Indiana Area. These

emission projections were prepared by IDEM, with assistance from LADCO and the

Evansville Metropolitan Planning Organization.

The detailed inventory information for the Southwestern Indiana Area for 2010 and 2020

is in Appendix I. Emission trends are an important gauge for continued compliance with

the annual standard for fine particles. Therefore, IDEM performed an initial comparison

ofthe inventories for the base year (2005), interim year (2010), and maintenance year

(2020) inventories for the Southwestern Indiana Area which are summarized below.

Graphs 4.9,4.10 and 4.11 visually compare 2005 (base year) NOx, S02 and direct PM2.5

19
estimated emissions with the 2010 and 20202 projected emissions for the Southwestern

Indiana Area. Mobile source emission inventories are described in Section 5.0. In

addition to LADeO's estimates, point source emissions were projected based upon the

statewide EGU NOx budgets from the Indiana NOx rule. It should be noted that EGU

emission estimates for 2010 and 2020 (Le. 2018) were projected utilizing the Department

ofEnergy Information's Annual Energy Outlook Supplemental tables. These tables were

generated for the reference case ofthe Annual Energy Outlook 2007 (AEO 2007) using

the National Energy Modeling System.

Graph 4.9

Comparison of 2005 Estimated and 2010 and 20203 Projected NOx Emissions for the

Southwestern Indiana Area

NOx Trends- All Anthropogenic Sources

Southwestern Indiana Area

120,000

100,000

rIJ

=Q 80,000

I

-; 60,000 =

=

= 40,000 <

20,000

0

2005 2010

I~NOxl

2020

2 EGU emission projections for the year 2020 are based on 2018 emission estimates

20
Graph 4.10

Comparison of 2005 Estimated and 2010 and 20203 Projected SOz Emissions for the

Southwestern Indiana Area

SOz Trends- All Anthropogenic Sources

Southwestern Indiana Area

400,000 ,..------------------------,

3S0,000 +---

<Il 300,000 +---

=2S0,000 +---

..!. 200,000-J--- = ISO,OOO +---

« 100,000 +---

SO,OOO -J---

0+---

200S 2010

I~S021

2020

Graph 4.11

Comparison of 2005 Estimated and 2010 and 20204 Projected Direct PMZ•5

Emissions for the Southwestern Indiana Area

Direct PMZ•5 Trends- All Anthropogenic Sources

Southwestern Indiana Area

6,000

S,OOO

<Il

=Q 4,000

Eo-I

3,000 =

=

=2,000 «

1,000

0

200S 2010

1 Direct PM2.sl

2020

3 EGU emission projections for the year 2020 are based on 2018 emission estimates

21
Graph 4.12

Comparison of 2005 Estimated and 2010 and 20204 Projected S02, NOx, and Direct

PM2.5 Emission Trends for the Southwestern Indiana Area

Trends - All Anthropogenic Sources

Southwestern Indiana Area

400,000

350,000

300,000

= 250,000 Q

-

= 200,000 === 150,000 -<

100,000

50,000

°

2005 2010

IOJ S02 • NOx 0 Direct PM2.5!

2020

Table 4.1

Comparison of 2005 Estimated and 20205 Projected Emission Estimates

Southwestern Indiana Area (Annual-Tons)

2005 2020 Change % Change

NOx 100,738.05 33,920.55 -66,817.5 66.33% decrease

802 367,861.51 133,918.53 -233,942.98 63.60% decrease

Direct PM2.5 4,566.88 4,688.54 121.66 2.66% increase

NOx emissions within the Southwestern Indiana Area are projected to decline by 66.33%

between 2005 and 20205

• Emission reduction benefits from U.S. EPA rules covering the

NOx SIP Call, Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control

Requirements, Highway Heavy-Duty Engine Rule and Non-Road Diesel Engine Rule are

4 EGU emission projections for the year 2020 are based on 2018 emission estimates

22
factored into the changes. Further, due to implementation ofthe NOx SIP Call across the

eastern United States, NOx and ozone levels entering this area will also be decreased.

Since CAIR is a regional cap and trade program, it cannot be predicted at this time what

effect this will have on EGU units located in the Southwestern Indiana Area or other

upwind counties. Therefore, potential reductions are not included in Graph 4.9 or Table

4.1. S02 emissions within the Southwestern Indiana Area are projected to decline by

63.60% between 2005 and 20205. The nominal 2.66% increase in direct PM2.5 emissions

from 2005 to 20205is outweighed by the significant S02 and NOx reductions.

4.4 Demonstration ofMaintenance

Ambient air quality data from all the monitoring sites indicate that air quality in the

Southwestern Indiana Area met the annual standard for fine particles for the three-year

period ending in 2006. U.S. EPA's Redesignation Guidance (Page 9) states, "A state may

generally demonstrate maintenance ofthe NAAQS by either showing that future

emissions of a pollutant or its precursors will not exceed the level ofthe attainment

inventory, or by modeling to show that the future mix ofsources and emissions rates will

not cause a violation ofthe NAAQS." Emissions projections outlined in Section 4.0 of

this document clearly illustrate that regional NOx, S02 and direct PM2.5emissions will

continue to decline leading to local reductions between 2005 (base year) and 20205

(maintenance plan horizon). Section 7.0 further discusses the implications ofthese

emission trends and provides an analysis to support these conclusions. Therefore, air

quality should meet the NAAQS for annual fine particles through the projected years of

2010 and 2020.

In Indiana, major point sources in all counties are required to submit air emissions

information once every three years or annually if S02 potential to emit is greater than

2,500 (see 326 lAC 2-6-3(a)(l)(D» tons or the NOx potential to emit is greater than 2,500

tons, in accordance with the Emission Statement Rule, 326 IAC 2-6. IDEM prepares a

new periodic inventory for all precursor emission sectors every three (3) years. These

precursor emission inventories will be prepared for 2008, 2011, 2014 and 2017 as

necessary to comply with the inventory reporting requirements established in the CAAA.

Emissions information will be compared to the 2005 base year and the 20206 projected

maintenance year inventories to assess emission trends, as necessary, to assure continued

compliance with the annual fine particles standard.

4.5 Permanent and Enforceable Emission Reductions

Permanent and enforceable reductions ofsulfur dioxides, direct PM2.5 and oxides of

nitrogen have contributed to the attainment ofthe annual standard for fine particles.

Some ofthese reductions were due to the implementation ofthe NOx SIP Call, and some

were due to the application oftighter federal standards on motor vehicles and fuels.

Section 6.0 identifies the emission control measures specific to the Southwestern Indiana

5 EGU emission projections for the year 2020 are based on 2018 emission estimates

23
Area, as well as the implementation status of each measure.

4.6 Provisions for Future Updates

As required by Section 175A(b) ofthe CAAA, Indiana commits to submit to the

Administrator, eight years after redesignation, an additional revision ofthis SIP. The

revision will contain Indiana's plan for maintaining the national primary fine particles air

quality standard for ten years beyond the first ten year period after redesignation.

5.0 TRANSPORTATION CONFORMITY BUDGETS

5.1 On-Road Emission Estimations

The Evansville Metropolitan Planning Organization (EMPO) is the Metropolitan

Planning Organization (MPO) for the Evansville area. The EMPO study area contains

approximately 650 square miles in Indiana, including the City ofEvansville,

Vanderburgh County, Warrick County, and a very small area of eastern Posey County. In

Kentucky, the study area encompasses approximately 440 square miles which includes

the City ofHenderson and Henderson County. Additionally, the Indiana Department of

Transportation and the EMPO have executed an agreement for the EMPO to provide

planning assistance in the rural counties of Gibson and Posey.

The Evansville MPO maintains a travel demand model that was updated and improved in

2003. The model incorporates the road network of a 5-county area, which includes the

Indiana counties ofVanderburgh, Warrick, Gibson and Posey, and Henderson County in

Kentucky. Incorporated into the travel demand model is a post-processor that uses the

U.S. EPA-required emissions estimation model MOBILE6.2 to calculate total emissions.

The EMPO travel demand model simulates traffic in the area and is used to predict what

traffic would be like in future years given growth expectations. The model is used mostly

to identify where travel capacity will be needed and to determine the infrastructure

requirements necessary to meet that need. It is also used to support the calculation of

mobile source emissions. The travel demand model is used to predict the total daily

Vehicle Miles Traveled (VMT) and MOBILE 6.2 is used to calculate the emissions per

mile. The product ofthese two outputs, once combined, is the total amount of pollution

emitted by the on-road vehicles for the particular analyzed area.

Dubois County, Ohio Township in Spencer County and Washington Township in Pike

County were Indiana areas included in U.S. EPA's nonattainment designations for fine

particles and do not fall under the jurisdiction ofEMPO. In cases such as this, the

Indiana Department ofTransportation (INDOT) uses Highway Performance Monitoring

System (HMPS) baseline data to estimate and project mobile source emissions. This is a

national program that requires state Departments ofTransportation to collect traffic

counts throughout the state on a regular basis under a certain regulated method. This

24
HPMS data was collected and provided by the INDOT and was used for these three areas

beyond Evansville MPO's jurisdiction.

5.2 Overview

Broadly described, MOBILE 6.2 is used to determine "emission factors", which are the

average emissions per mile (grams/mile) for direct PM2.5 and PM2.5 precursors including

NOx and S02. There are numerous variables that can affect the emission factors. The

vehicle-fleet (vehicles on the road) age and the vehicle types have a major effect on the

emission factors. The facility-type the vehicles are traveling on (MOBILE 6.2 facilitytypes are Freeway, Arterial, Local and Ramp) and the vehicle speeds also affect the

emission factor values. Meteorological factors such as air temperature and humidity can

also affect the emission factors. After emission factors are determined, the emission

factor(s) must be multiplied by the VMT to determine the quantity ofvehicle-related

emIssIons.

It should be noted that each year analyzed will have different emission factors, volumes,

speeds and likely some additional links such as roads. MOBILE6.2 input and output

files can be found in Appendix J.

5.3 Analysis Years

The travel demand model contains road networks that are time specific. The EMPO has

modeled the years 2002, 2010, 2015, 2025, and 2035. Information, including emissions,

has also been interpolated from 2002 and 20I0 for the year 2005 and from 2015 and 2025

for the year 2020. This Redesignation Petition provides emission inventory estimates for

2002,2005,2010 and 2020 to meet the requirements specified by the Clean Air Act and

the u.s. EPA. The emissions estimates outlined in Section 4 ofthis document include the

2005, 2010 and 2020 mobile source emissions data referenced below in Table 5.1.

5.4 Emission Estimations

Table 5.1 outlines predicted VMT and on-road emissions estimates for the entire

nonattainment area for the years 2005, 2010 and 2020.

Table 5.1 - Emission Estimates for On-Road Mobile Sources

2005 2010 2020

VMT (miles/day) 8,402,660 8,739,730 9,973,260

Direct PM2.5 (tons/year) 152.88 77.15 54.61

NOx (tons/year) 8,114.37 4,212.01 2,092.15

25
5.5 Motor Vehicle Emission Budget

Table 5.2 contains the motor vehicle emissions budgets (Budgets) for the entire

nonattainment area for the years 2010 and 2020.

Table 5.2 - Motor Vehicle Emission Budgets in Tons per Year

Year 2010 2020

PM2.5 81.01 60.07

NOx 4,422.61 2,301.37

Consistent with the federal implementation rule for fine particles, Indiana does not

consider mobile source sulfur dioxide (S02) to be a significant contributor to fine

particles for this nonattainment area, as S02 constitutes less than one percent «1%) of

the area's total anthropogenic emissions.

These Budgets include the emissions estimates calculated for 2010 and 2020. The

emission estimates are derived from the EMPO travel demand model and MOBILE6.2 as

described above. Through the interagency consultation process, it was determined that an

interim Budget for the year 2010, in addition to the Budget for the year 2020, would be

appropriate. A reasonable margin ofsafety has been applied to the 2010 and 2020

Budgets in the amount of 5% and 10% respectively. Margins ofsafety are used to

accommodate the wide array of assumptions that are factored into the calculation process.

Since assumptions change over time, it is necessary to have a margin ofsafety that will

accommodate the impact ofrefined assumptions in the process. The resulting 2010 and

2020 Budgets for total direct PM2.5 and NOx emissions remain well below the 2005 base

year emissions referenced in Table 5.1.

All methodologies, latest planning assumptions and margins ofsafety were

determined appropriate through the interagency consultation process.

6.0 CONTROL MEASURES AND REGULATIONS

This section provides specific information on the control measures implemented in the

Southwestern Indiana Area, including CAAA requirements and additional state or local

measures implemented beyond CAAA requirements.

6.1 Reasonably Available Control Technology (RACT)

As required by Section 172 ofthe CAAA, Indiana in the mid-1990s promulgated rules

requiring RACT for emissions ofVOCs. There were no specific rules required by the

CAAA such as RACT for existing sources beyond statewide rules for the Southwestern

26
Indiana Area as defined in Sections 1.1 and 1.2. Statewide RACT rules have applied to

all new sources locating in Indiana since that time. The Indiana rules are found in 326

lAC 8. The following is a listing of applicable rules:

326 lAC 8-1-6

326 lAC 8-2

326 lAC 8-3

326 lAC 8-4

326 lAC 8-5

326 lAC 8-6

BACT for non-specific sources

Surface Coating Emission Limitations

Solvent Degreasing Operations

Petroleum Sources

Miscellaneous Operation

Organic Solvent Emission Limitations

Since the Southwestern Indiana Area attained the annual standard for fine particles prior

to an Attainment SIP or RACT SIP being due, and since the implementation rule for fine

particles stipulates that states are only required to draft and implement RACT rules for

the precursor emission reductions necessary to attain the standard, no further RACT rules

are required for this area.

6.2 Implementation of Past SIP Revisions

The area was only recently designated nonattainment for the annual standard for fine

particles and the area has now attained the standard well in advance ofits attainment

deadline of201O. As a result, Indiana is no longer required to develop and submit an

Attainment SIP or RACT SIP for this area under the annual NAAQS for fine particles.

6.3 Nitrogen Oxides CNOJ Rule

The U.S. EPA NOx SIP Call required twenty-two states to adopt rules that would result in

significant emission reductions from large EGUs, industrial boilers, and cement kilns in

the eastern United States. Indiana adopted this rule in 2001. Beginning in 2004, this rule

accounts for a reduction of approximately thirty-one percent (31%) of all NOx emissions

statewide compared to previous uncontrolled years.

Twenty-one other states have also adopted these rules. The result is that significant

reductions have occurred regionally and within the Southwestern Indiana Nonattainment

Area because ofthe number of affected units within the region. From Graphs 4.7 and 4.8

it can be seen that emissions covered by this program have been trending downward since

1999. Table 6.1, compiled from data taken from the U.S. EPA Clean Air Markets Web

site, quantifies the gradual NOx reductions that have occurred in Indiana as a result of

Title IV (Acid Rain) ofthe Clean Air Act Amendments and the NOx SIP Call Rule. The

NOx SIP Call cap will stay in place through 2008, at which time the caps in the CAIR

program will supersede it.

Further, U.S. EPA has recently published Phase II ofthe NOx SIP Call that establishes a

budget for large (emissions of greater than 1 ton per day) stationary internal combustion

engines. In Indiana, the rule decreases emissions statewide from natural gas compressor

27
stations by 4,263 tons during the ozone season. The Indiana Phase II NOx SIP Call rule

became effective February 26,2006 and implementation began in 2007.

Table 6.1

Trends in EGU NOx Emissions Statewide in Indiana

Year NOx Emissions (tons Iyear)

1999 347,217

2000 334,522

2001 315,420

2002 281,146

2003 260,980

2004 224,311

2005 207,982

2006 202,728

Budget 2009-2014 108,935

Budget 2015 and later 90,779

6.4 Measures Beyond Clean Air Act SIP Requirements

Reductions in fine particle precursor emissions have occurred, or are anticipated to occur, as

a result oflocal and federal programs. These additional control measures include:

Tier II Vehicles Standards6

Federal Tier II vehicle standards require all passenger vehicles in a manufacturer's

fleet, including light-duty trucks and sport utility vehicles (SUVs), to meet an

average standard of 0.07 grams ofNOx per mile. Implementation began in 2004,

and completely phased in by 2007. The Tier II standards also cover passenger

vehicles over 8,500 pounds gross vehicle weight rating (the larger pickup trucks

and SUVs). For these vehicles, the standards will be phased in beginning in 2008,

with full compliance in 2009. The new standards require vehicles to be 77% to

95% cleaner than those on the road today. The Tier II standards also reduce the

sulfur content of gasoline to 30 ppm starting in January 2006 in order to reduce

interference with the operation of catalytic converters. Most gasoline sold in

Indiana prior to January 2006 had a sulfur content of about 500 ppm.

Heayy-Duty Gasoline and Diesel Highway Vehicle Standards7

New U.S. EPA standards designed to reduce NOx and VOC emissions from

heavy-duty gasoline and diesel highway vehicles began to take effect in 2004. A

second phase ofstandards and testing procedures, which began in 2007, will

reduce fine particle emissions from heavy-duty highway engines, and will also

reduce highway diesel fuel sulfur content to 15 ppm in order to mitigate damage

by sulfur to emission control devices. The total program is expected to achieve a

6 http://www.epa.gov/fedrgstr/EPA-AIR/2000/February/Day-lO/a19a.htm

7 http://www.epa.gov/fedrgstr/EPA-AIR/1997/0ctober/Day-21/a27494.htm

28
90% reduction in direct particulate matter emissions and a 95% reduction in NOx

emissions for these new engines using low sulfur diesel, compared to existing

engines using higher-content sulfur diesel.

Large Nonroad Diesel Engine Standards8

In May 2004, U.S. EPA promulgated new rules for large non-road diesel engines,

such as those used in construction, agricultural and industrial equipment, to be

phased in between 2008 and 2014. The non-road diesel rules also reduce the

allowable sulfur in non-road diesel fuel by over 99%. Non-road diesel fuel

currently averages approximately 3,400 ppm sulfur. This rule limited non-road

diesel sulfur content to 500 ppm in 2006 and 15 ppm in 2010. The combined

engine and fuel rules would reduce NOx and PM emissions from large non-road

diesel engines by over 90%, compared to current non-road engines using highercontent sulfur diesel.

Nonroad Spark-Ignition Engines and Recreational Engines Standards

The new standard, effective in July 2003, regulates NOx, VOCs and carbon

monoxide (CO), for groups of previously unregulated non-road engines. The new

standard applies to all new engines sold in the United States and imported after

the standards went into effect. The standard applies to large spark-ignition

engines (e.g. forklifts and airport ground service equipment), recreational vehicles

(off-highway motorcycles and all-terrain vehicles), and recreational marine diesel

engines. The regulation varies based upon the type of engine and vehicle.

Large spark-ignition engines contribute to ozone formation and ambient CO and

PM levels in urban areas. Tier I ofthis standard was implemented in 2004 and

Tier II started in 2007. Like the large spark-ignition engines, recreational vehicles

contribute to ozone formation and ambient CO and PM levels. For off-highway

motorcycles and all-terrain vehicles, the new exhaust emission standard was

phased-in by 50% for model year 2006, and 100% for model year 2007 and later.

Recreational marine diesel engines over 37 kilowatts are used in yachts, cruisers,

and other types of pleasure crafts. Recreational marine engines contribute to ozone

formation and PM levels, especially surrounding marinas. Depending on the size

ofthe engine, the standard for recreational marine diesel engines began phasing-in

in 2006.

When all ofthe non-road spark-ignition engines and recreational engine standards

are fully implemented, an overall 72% reduction in VOCs, 80% reduction in NOx

and 56% reduction in CO emissions are expected by 2020. These controls will

help reduce ambient concentrations of ozone, CO and fine particulate matter.

8 http:JJwww.epa.gov/fedrgstr/EPA-AIRl1998/0ctober/Day-23/a24836.htm

29
Clean Air Interstate Rille (CAIR)

On May 12,2005, the U.S. EPA promulgated the "Rule to Reduce Interstate

Transport ofFine Particulate Matter and Ozone (Clean Air Interstate Rule);

Revisions to Acid Rain Program; Revisions to the NOx SIP Call", referred to as

CAIR. This rule established the requirement for States to adopt ru1es limiting the

emission ofNOx and sulfur dioxide (S02) and a model rule for the states to use in

developing their rules. The purpose ofCAIR is to reduce interstate transport of

precursors to fine particles and ozone.

CAIR applies to (1) any stationary, fossil-fuel-fired boiler or stationary, fossilfuel-fired combustion turbines, a generator with nameplate capacity ofmore than

25 MWe producing electricity for sale and (2) for a unit that qualifies as a

cogeneration unit during the 12-month period starting on the date that the unit first

produces electricity and continues to qualify as a cogeneration unit, a cogeneration

unit serving at any time a generator with a nameplate capacity ofmore than 25

MWe and supplying in any calendar year more than one-third ofthe unit's

potential electric output capacity or 219,000 MWh, whichever is greater to any

utility power distribution system for sale.

This rule provides annual State caps for NOx and S02 in two phases, with the

Phase I caps for NOx and S02 starting in 2009 and 2010, respectively. Phase II

caps become effective in 2015. The U.S. EPA is allowing the caps to be met

through a cap and trade program if a state chooses to participate it the program.

In response to U.S. EPA's rulemaking, IDEM adopted its state rule in 2006 based

on the federal rule. IDEM's rule includes an annual and seasonal NOx trading

program, and an annual S02 trading program. This rule requires compliance

beginning in 2009.

Together, these rules will substantially reduce local and regional sources offine particle

precursors. The modeling analyses discussed in Section 7.0 include these rules and show

the reductions in annual fine particle concentrations expected to result from the

implementation ofthese rules.

6.5 Controls to Remain in Effect

Indiana commits to maintain the control measures listed above after redesignation, or

submit to U.S. EPA as a SIP revision any changes to its rules or emission limits

applicable to S02, NOx, or direct PM2.5 sources as required for maintenance ofthe fine

particles standard in the Southwestern Indiana Area.

Indiana, through IDEM's Office ofAir Quality and its Office ofEnforcement, has the

legal authority and necessary resources to actively enforce any violations ofits rules or

permit provisions. After redesignation, it intends to continue enforcing all rules that relate

30
to the emission offine particles and fine particle precursors in the Southwestern Indiana

Area.

6.6 New Source Review Provisions

Indiana has a long standing and fully implemented New Source Review (NSR) program

that is outlined in rule 326 lAC 2. The rule includes provisions for the Prevention of

Significant Deterioration (PSD) permitting program in 326 lAC 2-2. Indiana's PSD

program was conditionally approved on March 3, 2003 (68 FR 9892) and received final

approval on May 20, 2004 (69 FR 29071) by U.S. EPA as part ofthe SIP.

Any facility that is not listed in the 2002 emission inventory, or for emission reductions

which credit through closing was taken in demonstrating attainment, will not be allowed

to construct, reopen, modify, or reconstruct without meeting all applicable permit rule

requirements. The review process will be identical to that used for new sources. Once

the area is redesignated, OAQ will implement NSR through the PSD program, which

requires an air quality analysis to evaluate whether the new source will threaten the

NAAQS.

7.0 MODELING AND METEOROLOGY

Although U.S. EPA's redesignation guidance does not require modeling for fine particle

nonattainment areas seeking redesignation, extensive modeling has been performed

covering the Southwestern Indiana region to determine the effect of national emission

control strategies on fine particle levels. These modeling analyses determined that

Southwestern Indiana including Vanderburgh, Warrick, Dubois Counties and

Montgomery Township in Gibson County, Ohio Township in Spencer County and

Washington Township in Pike County are significantly impacted by regional transport of

particulate matter and its precursors, and that regional S02 and NOx reductions are an

effective way to attain the annual fine particles standard in this area. Future year modeled

annual fine particle concentrations are expected to be reduced by 8% to 24% from

baseline design values. Examples ofthese modeling analyses are described below.

7.1 Summary of Modeling Results to Support Rulemakings

U.S. Modeling for Clean Air Interstate Rule (CAIR), 2005

On March 10,2005, the U.S. EPA finalized the Clean Air Interstate Rule (CAIR). S02

emissions from power plants in the 28 eastern states and the District ofColumbia covered

by CAIR, will be cut by 4.3 million tons by 2009 and reduced by an additional 5.4 million

tons in 2015. NOx emissions will be cut by 1.7 million tons by 2009 and reduced by an

additional 1.3 million tons in 2015. Indiana will reduce S02 emissions from the

implementation ofCAIR in 2009 by 222,000 tons from the 2009 emissions projections

31
without CAIR and by 2015, will be reduced by an additional 178,000 tons from the 2015

emissions projections without CAIR. Indiana will reduce NOx emissions from the

implementation ofCAIR in 2009 by 113,000 tons from the 2009 emissions projections

without CAIR and by 2015, will be reduced by one 149,000 tons from the 2015 emissions

projections without CAIR.

U.S. EPA perfonned modeling to support the emission reductions associated with CAIR.

U.S. EPA used the Community Multiscale Air Quality Model (CMAQ) applied to the

2001 meteorology, as processed by Mesoscale Model (MM5). Emissions input into

CMAQ included sulfur dioxide, nitrogen oxides, volatile organic compounds, ammonia

and direct PM2.5 for 2001. The modeling was based on the annual fine particulate design

values calculated from 1999 through 2003. Future year modeling was conducted,

including the Southwestern Indiana counties, and the future year design values for 2010

and 2015 were evaluated for attainment ofthe annual fine particles NAAQS of 15 Jlg/m3

,

as shown below in Table 7.1. Daviess County in Kentucky is considered an upwind

county from the Southwestern Indiana Area and will be reviewed along with the

Southwestern Indiana fine particulate nonattainment areas. Modeled results for Daviess

County have been included in the modeling analysis. Fine particle concentrations are

accounted for through CAIR by modeling both the base future year emissions and then

the emissions reductions associated with CAIR. U.S. EPA found model perfonnance met

suggested benchmark performance goals and within the range or better than other

comparable modeling applications.

Table 7.1

Modeling Results from U.S. EPA for the Clean Air Interstate Rule

Future Future

Future Design Design Future Design Design

Design Value Value 2010 Value 2010 Value 2015 Value 2015

County MSNCMSA 1999-2003 Base withCAIR without CAIR withCAIR

(J..lg/mJ

) (J..lg/mJ

) (llg/mJ) (llg/mJ) (llg/mJ)

Vanderbur.lili Evansville, IN 15.60 15.54 14.26 15.56 14.17

Spencer 14.43 13.96 12.63 13.84 12.28

Knox 13.83 13.55 12.1 13.37 11.83

Dubois 16.02 15.73 14.37 15.66 14.16

Daviess Co., KY Owensboro, KY 14.94 14.15 12.88 14.05 12.65

Modeling results showed that the base future year modeling without CAIR accounts for

approximately 0.1 to 0.5 Jlg/m3 decreases in concentrations for 2010 and approximately

0.04 to 0.6 Jlg/m3 decreases in concentrations for 2015. The future year modeling showed

that emissions reductions associated with CAIR would account for approximately 1.3 to

1.8 Jlg/m3 decreases in concentrations for 2010 and approximately 1.4 to 2.0 Jlg/m3

decreases in concentrations for 2015. Therefore, impacts from CAIR equate to

approximate decreases of 1.0 to 1.3 Jlg/m3 by 2010 and 1.3 to 1.4 Jlg/m3 by 2015.

32
Results ofthe U.S. EPA CAIR modeling show that all Southwestern Indiana counties will

attain the annual fine particles NAAQS in 2010 with modeled impacts reduced by 8 % to

14%, and remain below 15 Jlg/m3

• With further reductions projected in CAIR for 2015,

all design values decrease by 9% to 15% and continue to attain the fine particles NAAQS.

LADCO Modeling for Clean Air Interstate Rule (CAIR)

The Lake Michigan Air Directors Consortium (LADCO) conducted modeling to

determine the impact ofCAIR in the Midwest. LADCO's modeling used the

Comprehensive Air Quality Model with extensions (CAMx) applied to the year 2005

meteorology, as processed by Mesoscale Model (MM5). Emissions input into CAMx

included sulfur dioxide, nitrogen oxides, volatile organic compounds, ammonia and direct

PM2.5 for 2005. The modeling was based on 2003 through 2006 design values. Future

year modeling for 2009,2012, and 2018 was conducted and the future year design values

were determined, as shown below in Table 7.2.

Table 7.2

LADCO's Round 5 Modeling Results for the Clean Air Interstate Rule

Basecase Basecase Basecase

Monitor Design Value with CAIR- with CAIR- withCAIRMonitor ID Name County 2003-2006 2009 2012 2018

(I.l.g/m3

) (I.l.glm3) (llglm3

) (llglm3)

181630006 Civic Center Vanderbur~ 14.8 12.5 12.4 11.9

181630012 W. Mill Rd. Vanderburgh 14.9 12.4 12.3 11.8

181630016 Univ.ofEvansville Vanderburgh 15.1 12.8 12.7 12.2

181470009 Dale Spencer 14.4 11.7 11.6 11.2

180372001 Jasper Post Office Dubois 15.3 12.4 12.3 11.7

1803700041 Sports Complex Dubois 13.6 11.1 11.1 10.6

1803700051 Jasper GolfCourse Dubois 13.7 11.2 11.2 10.7

180830004 SW Purdue Ag. Knox 14.1 11.6 11.5 11.1

210590005 Owensboro Daviess - KY 14.4 12.1 12.0 11.6

210590014 Wesleyan College Daviess - KY 13.0 11.0 11.0 10.6

The CAIR modeling test was based on the 3 most current 3-year design values, centered

around 2005 (2003-2005, 2004-2006, 2005-2006). The fine particle modeling used 2005-

2006 as the third design value because 2007 data was not available at the time ofthe

modeling. 2007 data has since been made available and review ofthe 2007 annual values

shows that the 2005-2006 average design values for the Southwest Indiana were higher

than the 2005-2007 design values with the exception ofSports Complex and Jasper Golf

Course in Dubois County. Those two monitors began operation in 2006 and only have

two years ofmonitoring data available. The higher design values will not lead to

modeled values above 15.0 ug/m3. The Jasper monitor has data throughout the baseyear

design value period and shows modeled concentrations at 12.4 ug/m3. Therefore, the

33
modeled attainment test using the 2003-2006 design value periods is conservative and an

accepted method for modeling future year design values.

Table 7.3

Southwest Indiana Design Value Comparison with and without 2007

Design Design

Monitor Monitor Value Value

ID Name County 2003-2006 2003-2007

(J,lg/m3

) (J,lg/m3)

1803700041 Sports Complex Dubois 13.6 8 14.13 b

1803700051 Golf Course Dubois 13.7 8 14.35 b

1803720011 Jasper Dubois 15.3 15.20

1814700091 Dale Spencer 14.4 14.32

1816300061 Civic Center Vanderburgh 14.8 14.69

1816300121 W. Mill Road Vanderburgh 14.9 14.82

1816300161 Dniv.ofEvansville Vanderburgh 15.1 15.00

8 Represents a one-year design value

b Represents a two-year design value

Results ofthe LADCO CAIR modeling show that all Southwest Indiana Counties will

attain the annual NAAQS for fine particles of 15 Ilg/m3 by 2009. As shown in Figure 7.1,

future year modeled annual fine particle concentrations for 2009 will be 15% to 19%

lower than baseline annual fine particles design values, 16% to 20% lower in 2012 and

19% to 24% lower in 2018 and will continue to decrease, thereafter.

34
Graph 7.1

Modeling Results for Southwest Indiana PM2.5 Monitors for 2009, 2012 and 2018

18

17

16

c;;-

.e

15

III

c

0 14 ;:

I!

-

c

fD 13 u

C

0

0 12

11

10

2005 2009

Modeled Year

2012 2018

-+-Sports Col1lllex ---Golf Course

- U. of Evansville Dale

Jasper

-Knox Co.

Civic center ---lIE- W. Mil Rd

- vvyndall Shpg Ctr. Baskett Rre Dept.

7.2 LADCO'S Round 5 Speciated Modeled Attainment Test Results

The Speciated Modeled Attainment Test (SMAT) is the attainment test for annual fine

particles. To determine the future year annual fine particle concentrations, speciated data

is calculated. The different species that were modeled and are associated with fine

particles include sulfates, nitrates, organic carbon, elemental carbon, ammonium, particle

bound water, "other" primary inorganic fine particles and passively collected mass. The

SMAT results from LADCO's Round 5 modeling are listed below. Percent ranges ofthe

model results from the five fine particle monitors in Southwest Indiana were broken

down into these speciated constituents offine particle emissions. The percent change

from the observed speciated data in 2005 to the future year modeled results for 2009 are

listed below in Table 7.2.

35
Table 7.4

LADeO's Round 5 SMAT Modeling Results for Southwest Indiana

(percent change from observed to modeled concentrations)

Species of PM2.5 2009

Sulfates 24%-29%

Nitrates 0%-8%

Organic Carbon 0%-4%

Elemental Carbon 0%-20%

Ammonium 16%- 26%

Particle Bound Water 19% - 31%

The results show that sulfate, ammonium and particle bound water concentration

decreases are projected to occur by at least 16% in the future year 2009. Lesser nitrate

reductions are projected to occur, up to 8%, with organic carbon reductions occurring up

to 4%. LADCO modeling shows good performance for sulfates and elemental carbon

predicted baseline concentrations, slight over-prediction for nitrate concentrations and

under-predictions of organic carbon concentrations. Overall, model performance is

adequate for State Implementation Plan (SIP) planning and gives a good idea ofthe

effects of emissions reductions from national emission control measures on Southwest

Indiana.

7.3 LADCO'S Round 5 Particulate Source Apportionment Results

Particulate Source Apportionment (PSAT) modeled was conducted by LADCo. The

results ofthe PSAT Round 5 modeling show the contributions from regional and

emission sectors on each monitor that was modeled. Chart 7.1 below shows the regional

and emission sector contributions for the Jasper, Dubois County fine particle monitor;

Civic Center, West Mill Road and University ofEvansville fine particle monitors in

Vanderburgh County; Dale, Spencer County fine particle monitor and the Knox County

fine particle monitor. Indiana was the biggest regional contributor to the Jasper, West

Mill Road and the Dale fine particle monitors. Kentucky was the biggest regional

contributor to the Civic Center and University ofEvansville fine particle monitors with

Illinois as the biggest regional contributor to the Knox County fine particle monitor. The

PSAT Round 5 modeling results show the majority ofIndiana's emission sector

contributions to fine particle concentrations at come from electric generating units

(EGUs), ammonium emission sources, ,off-road (including marine, aircraft and railroad)

and non-EGU sources. These results are considered to be representative ofthe entire

Southwest Indiana area as EGU, ammonium and non-EGU emissions impact the entire

area.

36
Chart 7.1

RegionallEmission Sector PSAT Results Jasper, Dubois Co. PM2•5 Monitor

Jasper, Dubois Co. Civic Center, Evansville &stat.Dame - &countyDame : (]lU372DOll baseM3 I:stateuame _ IccotmtyDame : (:BmaOO061 bali8M3

I'Ktor ... BCU _ nonECt1 - ... onrc.d... __

•

nb3

Be ·°_-1

..... Cone _ 12.8 .....3

nb3

Be ·°_-1

West Mill Road, Evansville r.staloDame - 1<",)\",._ , {1I1630012~ basoM3

nb'

Be

• -

... BCU... nonECU _

· ....... -

University ofEvansville &:stateDame - &co1UltyDame (18maOO'&1) baseM3

I

I

....n-------------------,

~=g~~=. DUno.

WiICOIWIn

nb'

Be l'«:tor - ECU... nonECU ... _ onrcr-d_ .....

;;.,----- -

Canc:enbation (up3)

Dale, Spencer Co. Ir:stateD81D8 - IccouDtyname ; (BU.700091 b898M3

Knox Co. I<"""""'e - lkco1IDIyDomo , (1B0830004~ basoM3

nb'

Be

_ ECU.. non!CU ...

• oouood •

•

...

• ~d

ECU..... nonBCU __... nb'

Be ·°_-1 l·elM

•

_-..,-----------------...., Mi;:~: r!!!I!I--C~=~-_ D1ino.

WilCotUIln

Ill_Chi_NA

lnd_Chi_NA

o.troi,tNA

FIInN1ylftftia ~-:2'~ E!I-_r=~- ""-m VISTAS

"""",-vu CBNlW'_WRAP

10_ I Mi.....- I em'"BCI-_-...__..,..._--,~-......__......- .......-_.._J

Concentrw.tion (up]) Conc:entnlbon lUP:!)

Below are pie charts depicting the species contributions to fine particle concentrations at

the Southwest Indiana monitors. The pie charts include both the observed 2005

contributions and future year 2009 modeled contributions for each monitor. Since the

monitors are in close proximity of each other, results are fairly similar in the distribution

ofspecies concentrations among the monitors. Charts 7.2 and 7.3 cover the fine particle

monitors in the Southwest Indiana area with the highest monitored concentrations that are

37
used to determine compliance with the annual NAAQS.

Chart 7.2

Pie Charts - Species Modeled Contributions to Jasper, Dubois Co. PM2.5 Monitor

(Observed Concentrations = 15.3) (Modeled Concentrations =12.4)

Ob.lWd 2_COnlrfbullonlIt W. tath U PMU Monitor blon

... 2009 Modlild COnlrlbullonlll W. tath U PM2.& Monitor

blon

...

..003-

COC

cec

.... ... cnM ... • pbw

CbIon

a_

.003

Coc

Cec

.... .......

.pbw

Cblon

Chart 7.3

Pie Charts - Species Modeled Contributions to University of Evansville PM2.5

Monitor

(Observed Concentrations = 15.1) (Modeled Concentrations =12.8)

Observed 2_ COnlrlbulionsIt WIshlngton Plrk PM2.& Monitor

blon

3...

...

...

oc

,....

..003-

COC

cec

....

cnM

.pbw

Cblon

2009 Modlled COnlrfbullonl It WIshlngton Perk PMU Monitor blon

....

a_

.003

Coc

Cec

.... cnM

.pbw

Cblon

Results ofthe Round 5 PSAT modeling for Southwest Indiana fine particle monitors

show the highest pollutant contributors to basecase and future year fine particle

concentrations are sulfate, organic carbon, ammonium and nitrate. Future year modeling

show decreases in sulfates (due to the emission reductions from CAIR) and ammonium.

The future year modeling did show slight increases in organic carbon and nitrates from

the basecase modeled concentrations.

7.4 Summary ofExisting Modeling Results

u.S. EPA and LADCO modeling for future year design values have consistently shown

that existing national emission control measures will bring the Southwestern Indiana

counties into attainment ofthe annual NAAQS for fine particles. Emission control

measures to be implemented in the next several years will provide even greater assurance

that air quality will continue to meet the standard into the future. Modeling support for

38
the Clean Air Interstate Rule has shown that future year design values for the

Southwestern Indiana counties will continue to attain the annual standard for fine

particles with modeled future year design values below 15 Jlg/m3

• U.S. EPA future year

modeling of national emission control strategies showed the Southwestern Indiana

counties will attain the annual NAAQS for fine particles without additional national

emission controls. Future national and local emission control strategies will ensure that

each Southwestern Indiana county's fine particles attainment area will be maintained with

an increasing margin ofsafety over time.

7.5 Meteorological Analysis for Southwest Indiana

Meteorological conditions are one ofthe most important factors that influence

development and transport offine particles. Stagnant surface conditions during any time

ofthe year and upper air ridging provides conducive conditions for development and

transport offine particles. Ultimately, passage ofsurface cold fronts with a clean air

mass change will lower fine particle readings in the Southwestern Indiana Area.

7.6 Surface Air Conditions Present during High Fine Particle Concentrations Days

Higher annual concentrations offine particles tend to correlate with warmer temperatures

and lighter wind speeds, although high fine particle episodes can occur in the summer or

winter. It should be noted that higher annual fine particle concentrations are driven by

individual days with higher fine particle concentrations throughout the monitored year.

Therefore, it is difficult to attribute higher fine particle concentrations to annualized

meteorological rankings. Review ofseveral ofthe higher fine particle concentration

episodes over the past few years shows conditions were hot in the summer with

temperatures in the middle 800s F or higher and average wind speeds were fairly light.

Fall and winter days with higher fine particle concentrations had near normal

temperatures but wind speeds were very light.

7.7 Upper Air Conditions Present during High Fine Particle Concentrations Days

Upper air ridges and more stagnant surface wind conditions predominately affect

development and build up offine particles. Slow moving upper air ridges can effectively

suppress mixing within the many levels ofthe atmosphere and cause pollutants to build

up over time. Inversions or increases in temperature with a rise in altitude will prevent

mixing with air from the upper atmosphere. These conditions can occur at any time of

the year and are evident in elevated fine particle episodes in spring, summer, fall and

winter months. Review ofsurface and upper air features of higher fine particle

concentration days showed stagnant surface conditions and upper air ridges existed on

those days and helped in the buildup offine particle concentrations.

39
7.8 Analyses ofAtmospheric Conditions during High Fine Particle Concentration Days

Analyses have been conducted to determine the atmospheric conditions that are most

prevalent during higher fine particle concentration days in Indiana. LADCD applied a

Classification and Regression Tree (CART) analysis to data from Indiana that correlated

different levels offine particle concentrations to meteorological conditions from 1999-

2004. (Donna Kenski, 2005). This type of analysis looks at the meteorological

conditions, such as temperature, pressure, wind speed, wind direction, relative humidity

and dewpoint temperatures at the surface as well as morning and evening mixing heights

in the upper atmosphere which were present when higher concentrations offine particles

were monitored. Results ofthis CART analysis indicated factors that played a larger role

in higher fine particle concentrations in Indiana were warm-weather conditions with high

dew points, southwest winds and high evening mixing heights. Previous day's

concentrations offine particles playa key role in higher impacts as well.

Fine particles are made up ofseveral constituents, including direct PM2.5, sulfates,

nitrates, ammonium, organic carbon and elemental carbon. Depending on the time ofthe

year, concentrations of particulate constituents vary, with nitrates being more prevalent in

the winter and sulfates more prevalent in the summer. Emission reductions ofsulfates

and nitrates appear to have the biggest impact on lower future year fine particle

concentrations.

Chart 7.4 shows by year, the percentage ofthe number of days during which fine particle

levels reached the Air Quality Index ranges for "Good" (0 to 15 flg/m\ "Moderate" (15.4

flg/m3 to 40.4 flg/m3

) and "Unhealthy for Sensitive Groups (USG)"(40.5 flg/m3 to 65.4

flg/m3

). There were no days during which fine particle levels reached the "Unhealthy"

level of 65.5 flg/m3 to150.4 flg/m3

•

Chart 7.4

Distribution ofPM2.5 Concentration Days on the AQI Levels ofHealth Concern

100% ~_I"'"""'~~-__~--r-"-~~---==::r--.,.......,........,

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

2001 2002 2003 2004 2005 2006 2007

40

USG

o Moderate

• Good
Table 7.4 shows how the years ranked for the 3 AQI ranges. 2005 had the most

"moderate" and "Unhealthy for Sensitive Group" concentration days during the year with

2001,2002 and 2003 having the next highest amount ofdays.

Table 7.S

Ranking of Highest Number of Days at AQI Levels of Health Concern

Ranking Good Moderate Unhealthy for

Sensitive Grou

1st 2004 2005 2005

2Dd 2006 2001 20011200212003

3rd 2003 2002 2006

4tb 2002 200312006 2004

Stb 2001 2004

6t 2005

Based on the rankings for the AQI Levels ofHealth Concerns, 2005 had the most high

fine particle monitored days in Southwest Indiana with fine particle readings in the

moderate and USG levels and the lowest number of days in the Good level.

7.9 Summary ofMeteorological Analysis for Southwest Indiana

Annual fme particle concentrations in the Southwestern Indiana Area are driven by higher

fme particle concentration days that can occur during any time ofthe year. Conditions

that are most prevalent during higher fine particle concentration days are lighter winds,

higher relative humidity and above average temperatures in the summer and near normal

temperatures in the fall, winter or spring. Upper air weather patterns generally include

ridging over the area with stagnant conditions at the surface. Surface winds from any

direction can transport pollutants from surrounding areas into the Southwestern Indiana

Area. Nitrates are bigger contributors to fine particle concentrations in the winter and

sulfates are bigger contributors to fine particle concentrations in the summer.

8.0 CORRECTIVE ACTIONS

8.1 Commitment to Revise Plan

As noted in Section 4.6 above, Indiana hereby commits to review and revise as

appropriate its Maintenance Plan eight years after redesignation, as required by Section

175A ofthe CAAA.

41
8.2 Commitment for Contingency Measures

Indiana will monitor fine particle concentrations to determine whether trends indicate

higher values or whether emissions appear to be increasing. Ifit is determined that fine

particle levels and emissions are increasing and action is necessary to reverse that trend,

Indiana will take action to reverse the noted trend, prior to a violation ofthe standard

occurnng.

Indiana hereby commits to adopt and expeditiously implement necessary corrective action

in the following circumstance:

Action Level Response

An Action Level Response shall be prompted whenever a violation ofthe standard

(three (3)-year average annual arithmetic mean value of 15.1 Ilg/m3 or greater)

occurs. In the event that the Action Level is triggered and is not found to be due

to an atypical unfavorable meteorological condition, exceptional event,

malfunction, or noncompliance with a permit condition or rule requirement,

IDEM will determine additional control measures needed to assure future

attainment ofNAAQS for fine particles. In this case, measures that can be

implemented in a short time will be selected in order to be in place within

eighteen (18) months from the close ofthe fine particles season that prompted the

Action Level.

Control Measure Selection and Implementation

Adoption of any additional control measures is subject to the necessary

administrative and legal process. This process will include publication of notices,

an opportunity for public hearing, and other measures required by Indiana law for

rulemaking by state environmental boards.

If a new measure or control is already promulgated and scheduled to be implemented at

the federal or state level, and that measure or control is determined to be sufficient to

address the upward trend in air quality, additional local measures may be unnecessary.

Furthermore, Indiana will submit to u.S. EPA an analysis to demonstrate the proposed

measures are adequate to return the area to attainment.

8.3 Contingency Measures

Contingency measures to be considered will be selected from a comprehensive list of

measures deemed appropriate and effective at the time the selection is made. Listed

below are example measures that may be considered. The selection ofmeasures will be

based upon cost-effectiveness, emission reduction potential, economic and social

considerations or other factors that IDEM deems appropriate. IDEM will solicit input

from all interested and affected persons in the maintenance area prior to selecting

42
appropriate contingency measures. All ofthe listed contingency measures are potentially

effective or proven methods ofobtaining significant reductions offine particle precursor

emissions. Because it is not possible at this time to determine what control measure will

be appropriate at an unspecified time in the future, the list of contingency measures

outlined below is not comprehensive. Indiana anticipates that if contingency measures

should ever be necessary, it is unlikely that a significant number (i.e., all those listed

below) will be required.

1) Alternative fuel and diesel retrofit programs for fleet vehicle operations.

2) Require NOx or S02 controls on new minor sources (less than 100 tons).

3) Wood stove change out program.

4) Idle restrictions.

5) Broader geographic applicability of existing measures.

6) One or more transportation control measures sufficient to achieve at least a

half a percent (0.5%) reduction in actual area wide precursor emissions.

Transportation measures will be selected from the following, based upon the

factors listed above, after consultation with affected local governments:

a. Trip reduction programs, including, but not limited to, employer-based

transportation management plans, area-wide rideshare programs, work

schedule changes, and telecommuting.

b. Transit improvements.

c. Traffic flow improvements.

d. Other new or innovative transportation measures not yet in widespread

use that affects state and local governments deemed appropriate.

No contingency measure shall be implemented without providing the opportunity for

full public participation during which the relative costs and benefits ofindividual

measures, at the time they are under consideration, can be fully evaluated.

9.0 PUBLIC PARTICIPATION

In accordance with Section 100 (a) (2) ofthe CAAA, notice of availability ofthe fine

particulate redesignation documents and the time and date ofthe public hearing was

published in the Indianapolis Star (Indianapolis), the Evansville Courier (Evansville) and

in the Herald (Jasper) for the Southwestern Indiana nonattainment area on February 26,

2008.

The public hearing to receive comments on the redesignation request was held on March

27,2008, in the Multi-Purpose Room at the McCollough Branch ofthe Evansville

Vanderburgh Public Library, located at 5115 Washington Avenue, Evansville, Indiana.

The public comment period closed on March 31, 2008. As this submittal is due to U.S.

EPA on AprilS, 2008, the transcript ofthe Public Hearing and a summary ofthe

comments received and IDEM's responses will be forwarded to U.S. EPA under separate

43
cover. Appendix M includes a copy ofthe public notice, certifications of publication, and

verification ofthe public hearing location.

10.0 CONCLUSIONS

The Southwestern Indiana Area has attained the annual NAAQS for fine particles. This

petition demonstrates that the Southwestern Indiana Area has complied with the

applicable provisions ofthe 1990 Amendments to the Clean Air Act regarding

redesignation ofnonattainment areas for fine particles. IDEM has prepared a State

Implementation and Maintenance Plan that meets the requirement of Section 110 (a)(l) of

the 1990 Clean Air Act.

Indiana has performed an analysis that shows the air quality improvements are due to

permanent and enforceable measures and that additional significant regional NOx

reductions following implementation of Phase II NOx SIP Call and CAIR will ensure

continued compliance (maintenance) with the standard. Furthermore, because this area is

subject to significant transport of pollutants, significant regional S02 and NOx reductions

will ensure continued compliance (maintenance) with the standard with an increasing

margin ofsafety. Based on this presentation, the Southwestern Indiana Nonattainment

Area for fine particles meets the requirements for redesignation under the CAA (Section

107 (d) (3» and U.S. EPA guidance.

Consistent with the authority granted to the U.S. EPA, the State ofIndiana hereby

requests that the Southwestern Indiana Area Nonattainment Area for fine particles be

redesignated to attainment simultaneously with U.S. EPA approval ofthe Indiana State

Implementation and Maintenance Plan provisions contained herein.

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