Ms. Mary A. Gade Regional Administrator U.S. Environmental Protection Agency Region V 77 WestJackson Boulevard Chicago, IL 60604-3950 

### IDEM INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT We ProtectHoosiers andOurEnvironment. 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 DearMs. Gade: The Indiana Department ofEnvironmental Management (IDEM) prepared a draft Redesignation Petition and Maintenance Plan for 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 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 commentperiod 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 andMaintenance Plan • A formal requestthatthe Southwestern Indiananonattainment 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 September4, 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 ofand response to substantive oral and written comments.

RecycledPaper 

# * An Equal Opportunity Employer Please Recycle 

### 0M. Gade Page 2 Motor Vehicle Emissions Budgets

• Contained in the Redesignation Petition is a new Motor Vehicle Emissions Budgetfor 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 ofMotorVehicles 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 staffunder separate cover. IDEM hereby requests thatthe U.S. EPA proceed with final review and approval ofthis submittal. Ifyou 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 FORREDESIGNATION AND MAINTENANCE PLAN UNDER THE ANNUAL**NATIONAL_>-~** 

# AMBIENT AIR QUALITY

# r£~ "1

# 'I"\l~ STANDARD FORFINE PARTICL IS**~?""('s~s\'riBBPS\\C\-1'** /\IBE.\\\f08v BE.GION5 t"'**\J.S.E.I'F>-·"~-**



# Southwestern Indiana Area



# Prepared By: 

# The IndianaDepartment ofEnvironmental Management

March 2008This page intentionally left blank

11TABLE OF CONTENTS (page numbers subjectto 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 MotorVehicle Emission Budget. 26

111

### 6.0 CONTROL MEASURES AND REGULATIONS 26 6.1 Reasonably Available Control Technology (RACT) 26 6.2 Implementation ofPast SIP Revisions 27 6.3 Nitrogen Oxides(NOx) Rule 27 6.4 Measures Beyond Clean AirAct 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 UpperAir Conditions Present during High Fine Particle Concentration Days 39 7.8 Analysis ofAtmospheric Conditions during High Fine Particle Concentration Days .40 7.9 Summary ofMeteorological Analysis for SouthwestIndiana .41 

### 8.0 CORRECTIVE ACTIONS 41 8.1 Commitmentto 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 IndianaNonattainment 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 IndianaArea 7 Table 4.1 Comparison of2005 Estimated and 2020 Projected Emission Estimates Southwestern IndianaArea 22 Table 5.1 Emissions Estimates for On-Road Mobile Sources 25

IVTable 5.2 MotorVehicle Emission Budgets in Tons perYear 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 AirInterstate Rule .32 Table 7.2 LADCO's Round 5 Modeling Results for the Clean Air Interstate Rule .33 Table 7.3 SouthwestIndianaDesign Value Comparison With and Without 2007 .34 Table 7.4 LADCO's Round 5 SMATModeling Results .36 Table 7.5 Ranking ofHighestNumber ofDays at AQI Levels ofHealth Concern 41 GRAPHS Graph 3.1 Design Values for the Southwestern IndianaNonattainment Area for Fine Particles 7 Graph 3.2 SouthwesternIndianaAnnual Fine Particle Trends, 2000 through 2006 8 Graph 4.1 SouthwesternIndianaAreaNOxPoint Source Emissions Trends 10 Graph4.2 SouthwesternIndianaArea S02 Point Source Emissions Trends 11 Graph4.3 SouthwesternIndianaAreaDirect PM2 .5Point Source Emissions Trends 11 Graph4.4 NOx Emissions Trends, All Sources in the Southwestern IndianaArea 12 Graph4.5 S02 Emissions Trends, All Sources in the Southwestern IndianaArea 13 Graph 4.6 Direct PM2 .5Emissions Trends, All Sources in the SouthwesternIndianaArea 13 Graph 4.7 NOx Emissions from Electric Generating Units, 1996 to 2006 15 Graph 4.8 S02Emissions from Electric Generating Units, 1996 to 2006 , · 17 Graph4.9 Comparison of2005 Estimated and 2010 and 2020 ProjectedNOx Emissions for the Southwestern IndianaArea 20 Graph 4.10 Comparison of2005 Estimated and 2010 and 2020 Projected S02Emissions for the SouthwesternIndianaArea , 21 Graph4.11 Comparison of2005 Estimated and 2010 and 2020 ProjectedDirectPM2.5 Emissions for SouthwesternIndianaArea 21 Graph 4.12 Comparison of2005 Estimated and 2010 and 2020ProjectedDirectPM2.5 Emissions Trends for the Southwestern IndianaArea 22 Graph 7.1 Modeling Results for Southwest IndianaPM2.5Monitors for 2009, 2012 and 2018 .35 CHARTS Chart 7.1 Regional/Emission SectorPSAT Results Jasper, Dubois CountyPM2 .5Monitor .37 Chart 7.2Species Modeled Contributions to Jasper, Dubois CountyPM2
.5Monitor .38 Chart 7.3 Species Modeled Contributions to University ofEvansville PM2.5 Monitor .38 Chart 7.4 Distribution ofPM2.5 ConcentrationDays on the AQI Levels ofHealth Concern .40 APPENDICES A Air Quality System (AQS) andIDEM MonitorDataValues (2004-2006) B Air Quality System (AQS) and IDEM MonitorDataValues (2005-2007) C University ofEvansville Incomplete PM2.5Monitoring DataAnalysis D 2005-2007 Indiana Monitoring Data Summary Supplement

vE NOx, S02 and Direct PM2 .5Point Source Emissions (2002-2005) F NOx, S02 and DirectPM2 .5Emission Trends, All Sources (2002-2005) G NOxand S02 Emissions from Electric Generating Units, SouthwestIndianaArea H NOx and S02Emissions from Electric Generating Units, Six State Region I NOx, S02 and DirectPM2 .52005 Base YearEmissions Inventory and 2010 and 2020 Projected Emissions J Example Mobile Source Input/Output CalculationFiles K IDEM Area Source Inventory

- Standard Operating Procedure L Lake Michigan AirDirectors ConsortiumEmission Estimates Technical Support Document M Lake Michigan AirDirectors ConsortiumRound 5 Modeling Technical Support Document N Public ParticipationProcess DocumentsREQUEST FORREDESIGNATION AND MAINTENANCE PLAN UNDERTHE 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 IndianaArea"), be redesignated from nonattainment to attainment ofthe annual standard for fine particles. The Southwestern Indiana Areahas recorded three (3) years ofquality assured ambient air quality monitoring datafor the years 2004 through 2006 demonstrating attainment with the annual standard for fine particles, and is thereby eligible for redesignation. Section 107 ofthe Clean AirAct (CAA) establishes specific requirements to be met in order for an areato be considered for redesignation including: (a) A determination that the areahas attained the annual standard for fine particles. (b) An approved State Implementation Plan (SIP) for the areaunder Section 11O(k). (c) A determination that the improvement in airquality 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 planprovides for the continued attainment ofthe air quality standard by an area for aperiod often years afterthe United States Environmental Protection Agency (U.S. EPA) has formally redesignated the areato attainment. The plan also provides assurances that even ifthere is a subsequent exceedance ofthe airquality 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.

11.1 Background The Clean Air Act Amendments of 1990 (CAAA) requires areas designated nonattainment for the National AmbientAir Quality Standard (NAAQS) for particulate matterto 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 bythe U.S. Supreme Court in February of2001. In 1999 Indianabegan monitoring for fine particles. The U.S. EPA designated areas in Indianaunderthe standards for fine particles on December 17, 2004 as attainment, nonattainment orunclassifiable, with an effective date ofAprilS, 2005

.. Table 1.1 National AmbientAir 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-hourNAAQS 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 underthe 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 IndianaArea 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 subjectto Section 107 CAA requirements, including the development ofa plan to reduce oxides ofnitrogen (NOx), sulfur dioxide (S02) and direct PM2 .5 emissions and a demonstration that the area will meetthe annual standard for fine particles by April 15, 2010. There were no monitors in Indianathat violated the 1997 24-hour standard for fine particles. The Southwestern IndianaArea as defined in Sections 1.1 and 1.2 has notpreviously been subject to nonattainment arearulemakings for fine particles. However, Vanderburgh and Warrick Counties had been subjectto nonattainment arearulemakings 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.

21.2 Geographical Description The Southwestern IndianaArea 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 metthe annual NAAQS for fine particles in the nonattainment area. This fact, accompanied by the permanent and enforceable reductions in emission levels discussed in Section4.0,justifies a redesignation to attainment for the subject areabased 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 entitledProceduresfor ProcessingRequests to RedesignateAreas toAttainment, issued September4, 1992, to Regional Air Directors. This document is hereafterreferred to as "Redesignation Guidance". This Request for Redesignation and Maintenance Plan is based on the Redesignation Guidance, supplemented with additional guidance received from staffof the Regulatory Development Section ofU.S. EPA Region V. The subsections belowrefer in greaterdetail 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 thatthe 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) Ambientmonitoring 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 thatthe three-year average ofannual values, based on data from all monitoring sites inthe area or its affected downwind environs, do not exceed 15.0 micrograms per cubic meter (llg/m3). 

### This showing must rely onthree complete, consecutive calendaryears ofquality assured data. 4) A commitmentthat, once redesignated, the State will continue to operate an appropriate monitoring networkto verify the maintenance ofthe attainment status. 2.3 Emission Inventory 1) A comprehensive emission inventory ofdirect fine particles and the precursors offine particles completed for the base year (2005 inthis case). 2) A projection ofthe emission inventory to ayear at least ten years following redesignation. 3) A demonstration that the projected level ofemissions is sufficientto 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 orunusually 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 inpast SIP revisions have been fully implemented.



### 43) Acceptable provisions to provide for new source review. 4) Assurances that existing controls will remain in effect afterredesignation, unless the State demonstrates through photochemical modeling thatthe standard can be maintained without one or more controls. 5) Ifappropriate, a commitmentto adopt a requirementthat all transportation plans conform with and are consistentwith the SIP. 2.6 Corrective Actions for Potential Future Violations ofthe Fine Particles Standard 1) A commitmentto submita revisedplan eight (8) years afterredesignation. 2) A commitmentto expeditiously enact and implement additional contingency control measures in response to exceeding specified predetermined levels (triggers) or in the eventthat future violations ofthe ambient standard occur. 3) A list ofpotential contingency measures that would be implemented in such an event. 4) A list ofNOx, S02, and direct PM2.5 sources potentially subjectto 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 monitorreadings 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 Indianageographic area that collectbackground fine particle concentrations. While these monitors are notused to determine attainment with the annual fine particles standardthe monitoring locations are included as supporting material.



### 5Figure 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 DataHandling 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 (orthe design value) is less than or equal to 15.0**~g/m3.** When this occurs, the site is saidto be in attainment. While calculating design values, three significant digits mustbe 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 concentrationthat 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 meetthe NAAQS. The air quality design value for the area is the highest design value among all sites inthe 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 inthe SouthwesternIndianaArea.


### 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 NonattainmentArea 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 IndianaNonattainment 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 overthis 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 cementkilns. Indiana's NOxRule 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 conclusionthat attainment ofthe standard as of2006 is not the result ofunusually 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.



### 83.3 University ofEvansville 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 of68%. 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 of2005 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 of14.8 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 staffpriorto making changes to the existing monitoring network, should changes become necessary in the future. IDEM will continue to quality assure the monitoring datato meet the requirements of40 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 ofprecursor emissions for fine particles (SOz, direct

### PM 

### z

.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. Indianamust also demonstrate that the improvement in airquality between the yearthat violations occurred and the yearthat attainment was achieved is based on permanent and enforceable emission reductions. Other emission inventory related requirements: include a projection ofthe emission inventory to ayear at least ten (10) years following redesignation; a demonstration that the projected level ofemissions is sufficientto maintain the annual fine particles standard; and a commitmentto provide future updates ofthe inventory to enable tracking ofemission levels during the ten (10) yearmaintenance period. Consistentwith the federal implementationrule for fine particles, Indianadoes notconsider volatile organic compounds or ammoniato be significant contributors to fine particles. The following subsections address each ofthese requirements.

94.1 Emission Trends 

### PointSources 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 IndianaAreahad 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 thatmost companies did not submittheir direct PM2
.5 emissions data in 2002 but did submitdirect 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 ofPM2 .5 emissions from all anthropogenic sources. Regional NOx emission reductions affect fine particle levels in the Southwestern IndianaAreafar more so thanNOx emission reductions within the area itself. As Graph 4.7 illustrates, SouthwestIndianaNOx emissions from electric generating units have decreased substantially during this time period as well. Graphs and data tables ofemissions from each source category are available in Appendix F. Graph 4.1 Southwestern Indiana Area NOxPoint 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 DirectPMl.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 

### I

## mDirect PM2.51

11AllAnthropogenicSources 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 overtime but as can be seen from the graphs there is a downward trend inNOx and direct PM2 .5emissions from 2002 to 2005. The decrease in NOxcan be largely attributed to those EGUs located within and surrounding the SouthwesternIndianaAreathathave reduced theirNOx emissions as a result ofthe NOx SIP Call. Graphs and datatables ofemissions from each source category are available in Appendix F. 

### Graph 4.4 NOx

### Emission 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 S02Emission 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 DirectPM2 .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 ii 

## g 6,000 +----------------------------l 

### 3,000 +---- 

### 0-1---- 2002 

### I Direct 

## PM2.sl

13 

### 2005

### EGUSources Graphs 4.7 and 4.8 depict the trends inNOx and S02 emissions from SouthwestIndiana 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. BothNOx 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 onthe formation offine particles. These data were taken from U.S. EPA's Clean AirMarkets database!, Data are available sooner for these units than otherpoint sources in the inventory because ofthe NOx SIP Call budget and trading requirements. Information from 2003 is significantbecause some EGUs started operation oftheirNOx SIP Call controls in orderto generate Early Reduction Credits for theirfuture yearNOx budgets. The first season ofthe SIP Call budgetperiod began May 31, 2004. As part ofthe NOx SIP Call, the states were required to adopt into theirrules a budgetfor 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 budgetrepresents a statewide cap on NOx emissions. Although each unit is allocated emissions based upon historic heat input, utilities can meetthis budgetby over-controlling certainunits orpurchasing credits from the marketto account for overages at other units. To summarize, NOx emissions have dramatically decreased overthe years represented on these graphs. These emissions, capped bythe 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 apossibility 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 IndianaAir 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, significantreductions ofNOx associated with the NOx SIP Call and preparation for CAIRhave been achieved statewide as well as regionally. Forthe 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

15Figure 4.1 Regional NOx Reductions Between 2002 and 2006



## NOx Difference 2006 - 2002

Difference in Tons PerYear

• > -9430.0

• -9429.9

- -4864.0

• -4863.9

- -1.0 -0.9 -1.0 .1.1-7.0

• 7.1

- 1468.0 • > 4051.0

16As demonstrated by Figure 4.2, reductions ofregional S02from upwind EGUs have also been achieved. Forthe 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 overtime, as shown in Graph 4.8, there are moderate reductions to date. As notedby Graph 4.10 we do expectto see significantreductions in S02 emissions from CAIR and BART (Best Available Retrofit Technology), once implemented. As a result ofCAIR, five EGU's will achieve significantreductions 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 atthose facilities. Edwardsport is replacing all ofthe coal fired boilers with an Integrated Gasification Combined Cycle (IGCC) system which will result in a slight increase inNOx of32.49 tons peryear and a huge reduction in S02 of9,834 tons peryear. Also, as a result ofa 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

17Figure 4.2 Regional 

### S02Reductions 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

184.2 Base YearInventory IDEM prepared a comprehensive inventory for the Southwestern IndianaArea, 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 submittedto 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 yearvalues.

• 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 aboutthe accuracy ofsome ofthe categories in U.S. EPA's nonroad emissions model, the Lake Michigan AirDirectors' 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 motorboatpopulation 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 datatables and graphs ofall these emissions. 4.3 Emission Projections In consultation with the U.S. EPA and other stakeholders, IDEM selected the year 2020as the maintenance year for this redesignation request. This document contains projected emission inventories for 2010 and 20203 for the Southwestern IndianaArea. These emissionprojections were prepared by IDEM, with assistance from LADCO and the Evansville Metropolitan Planning Organization. The detailed inventory information for the Southwestern IndianaArea 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 IndianaArea which are summarized below. Graphs 4.9,4.10 and 4.11 visually compare 2005 (base year) NOx, 

### S02 and direct PM

### 2 .5

19estimated emissions with the 2010 and 20202 projected emissions for the Southwestern IndianaArea. 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 IndianaNOx 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 Outlook2007 (AEO 2007) using the National Energy Modeling System. 

### Graph 4.9 Comparison of2005 Estimated and 2010 and 20203 

### Projected NOx 

### Emissions for the Southwestern Indiana Area
NOx Trends- AllAnthropogenic Sources SouthwesternIndiana Area 120,000 100,000 rIJ 

# = 80,000 Q I 60,000 -; 

## = 

# = = 40,000 

### < 20,000 0 2005 2010

## I~NOxl 2020

2 EGU emissionprojections for the year 2020 are based on 2018 emission estimates
20

### Graph 4.10 Comparison of2005 Estimated and 2010 and 20203

### Projected SOz Emissions for the Southwestern Indiana Area
SOz Trends- All Anthropogenic Sources SouthwesternIndiana 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 of2005 Estimated and 2010 and 20204 

### Projected DirectPMZ • 5 

### Emissions for the Southwestern Indiana Area
DirectPMZ• 5 

### Trends- AllAnthropogenic Sources SouthwesternIndiana Area 6,000 S,OOO <Il 

# = 4,000 Q 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 of2005 

### Estimated and 2010 

### and 20204 

### Projected S02, NOx, 

### and Direct PM2
.5 

### Emission Trends for the Southwestern Indiana Area

Trends

- All Anthropogenic Sources SouthwesternIndiana 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 of2005 

### 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 IndianaArea 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 Ruleand Non-Road Diesel Engine Rule are

4 EGU emission projections for the year 2020 are based on 2018 emission estimates
22factored into the changes. Further, due to implementation ofthe NOx SIP Call across the eastern United States, NOx and ozone levels entering this areawill also be decreased. Since CAIR is aregional cap and trade program, it cannotbe predicted atthis time what effectthis will have on EGU units located in the Southwestern IndianaArea or other upwind counties. Therefore, potential reductions are not included in Graph 4.9 or Table 4.1. S02 emissions within the Southwestern IndianaArea 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 bythe significant S02 and NOxreductions. 4.4 Demonstration ofMaintenance Ambient air quality data from all the monitoring sites indicate that airquality in the Southwestern IndianaAreamet 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 ofa pollutant or its precursors will not exceed the level ofthe attainment inventory, orby 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 supportthese conclusions. Therefore, air quality should meet the NAAQS for annual fine particles throughthe 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 ifS02 potential to emit is greater than 2,500 (see 326 lAC 2-6-3(a)(l)(D» tons orthe NOx potential to emit is greaterthan 2,500 tons, in accordance withthe Emission StatementRule, 326 IAC 2-6. IDEM prepares a new periodic inventory for all precursor emission sectors everythree (3) years. These precursoremission 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 comparedto 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 SouthwesternIndiana

5 EGU emission projections for the year 2020 are based on 2018 emission estimates 23Area, as well as the implementation status ofeach measure. 4.6 Provisions for Future Updates As required by Section 175A(b) ofthe CAAA, Indianacommits to submit to the Administrator, eightyears 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 yearperiod afterredesignation.

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 ofeastern 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 ofGibson and Posey. The Evansville MPO maintains a travel demand model that was updated and improved in 2003. The model incorporates the road network ofa 5-county area, which includes the Indiana counties ofVander burgh, Warrick, Gibson and Posey, and Henderson County in Kentucky. Incorporated into the travel demand model is a post-processorthat 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 meetthat need. It is also used to support the calculation of mobile source emissions. The travel demand model is used to predictthe 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 ofpollution emittedby 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 underthejurisdiction ofEMPO. In cases such as this, the IndianaDepartment 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 throughoutthe state on a regular basis under a certainregulated method. This

24HPMS data was collected and provided bythe INDOT and was used for these three areas beyond Evansville MPO'sjurisdiction. 5.2 Overview Broadly described, MOBILE 6.2 is used to determine "emission factors", which are the average emissions permile (grams/mile) for direct PM2
. 5 and PM2
. 5precursors including NOx and S02. There are numerous variables that can affect the emission factors. The vehicle-fleet (vehicles onthe road) age and the vehicle types have a majoreffect 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 airtemperature 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 meetthe requirements specifiedby the Clean AirAct and the

# u.s. EPA. The emissions estimates outlined in Section4 ofthis document include the 2005, 2010 and 2020 mobile source emissions datareferenced 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

255.5 MotorVehicle 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

- MotorVehicle Emission Budgets in Tons perYear 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 sulfurdioxide (S02) to be a significant contributorto 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. Throughthe 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 of5% and 10% respectively. Margins ofsafety are used to accommodate the wide array ofassumptions that are factored into the calculationprocess. Since assumptions change overtime, 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, latestplanning assumptions and margins ofsafety were determined appropriate through the interagency consultation process.


### 6.0 CONTROL MEASURES AND REGULATIONS This sectionprovides 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 bythe CAAA such as RACT for existing sources beyond statewide rules for the Southwestern

26IndianaArea as defined in Sections 1.1 and 1.2. Statewide RACT rules have applied to all new sources locating in Indiana since thattime. The Indiana rules are found in 326 lAC 8. The following is a listing ofapplicable 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 EmissionLimitations SolventDegreasing Operations Petroleum Sources Miscellaneous Operation Organic SolventEmission Limitations Since the Southwestern IndianaArea attained the annual standard for fine particles prior to an Attainment SIP or RACT SIP being due, and since the implementationrule for fine particles stipulates that states are only required to draft and implement RACT rules for the precursor emissionreductions necessary to attain the standard, no further RACT rules are required for this area. 6.2 Implementation ofPast SIP Revisions The area was only recently designated nonattainment for the annual standard for fine particles and the areahas now attained the standard well in advance ofits attainment deadline of201O. As a result, Indiana is no longerrequired 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 cementkilns in the eastern United States. Indiana adopted this rule in 2001. Beginning in 2004, this rule accounts for a reduction ofapproximately thirty-one percent (31 %) ofall 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 SouthwesternIndianaNonattainment Areabecause ofthe number ofaffected 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 datataken from the U.S. EPA Clean Air Markets Web site, quantifies the gradual NOx reductions thathave occurred in Indiana as a result of Title IV (Acid Rain) ofthe Clean AirAct 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 ofgreaterthan 1 ton perday) stationary internal combustion engines. In Indiana, the rule decreases emissions statewide from natural gas compressor

27stations by 4,263 tons during the ozone season. The IndianaPhase II NOx SIP Call rule became effective February 26,2006 and implementationbegan 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 AirAct SIP Requirements Reductions infine particleprecursoremissions have occurred, orare anticipatedto 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 of0.07 grams ofNOx permile. Implementation began in 2004, and completely phased in by 2007. The TierII standards also coverpassenger vehicles over 8,500 pounds gross vehicle weightrating (the largerpickup trucks and SUVs). Forthese 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% cleanerthan those on the road today. The Tier II standards also reduce the sulfur content ofgasoline to 30 ppm starting in January 2006 in orderto reduce interference with the operation ofcatalytic converters. Most gasoline sold in Indianapriorto January 2006 had a sulfur content ofabout 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 orderto mitigate damage by sulfurto 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 2890% reduction in direct particulate matter emissions and a 95% reduction inNOx emissions for these new engines using low sulfurdiesel, 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 contentto 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 currentnon-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 ofpreviously 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 ofengine 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 othertypes ofpleasure 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 inNOx and 56% reduction in CO emissions are expected by 2020. These controls will help reduce ambient concentrations ofozone, CO and fine particulate matter.

8 http:JJwww.epa.gov/fedrgstr/EPA-AIRl1998/0ctober/Day-23/a24836.htm
29Clean Air Interstate Rille (CAIR) On May 12,2005, the U.S. EPA promulgatedthe "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 theirrules. The purpose ofCAIR is to reduce interstate transport of precursors to fine particles and ozone. CAIR applies to (1) any stationary, fossil-fuel-fired boileror stationary, fossilfuel-fired combustion turbines, a generator with nameplate capacity ofmore than 25 MWe producing electricity for sale and (2) for a unitthat qualifies as a cogeneration unit during the 12-monthperiod starting on the date thatthe 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 calendaryear more than one-third ofthe unit's potential electric output capacity or 219,000 MWh, whicheveris greaterto any utility powerdistribution 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 ifa state chooses to participate itthe 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 expectedto result from the implementation ofthese rules. 6.5 Controls to Remain in Effect Indianacommits to maintain the control measures listed above afterredesignation, or submitto U.S. EPA as a SIP revision any changes to its rules oremission limits applicable to S02, NOx, or direct PM2.5 sources as required for maintenance ofthe fine particles standard inthe Southwestern IndianaArea. 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 permitprovisions. Afterredesignation, it intends to continue enforcing all rules thatrelate



### 30to 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 SignificantDeterioration (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, orfor emissionreductions which credit through closing was taken in demonstrating attainment, will not be allowed to construct, reopen, modify, orreconstruct without meeting all applicable permitrule requirements. The review process will be identical to that used for new sources. Once the area is redesignated, OAQ will implementNSR through the PSD program, which requires an airquality analysis to evaluate whetherthe 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 Indianaregion to determine the effect ofnational 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 yearmodeled 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 ofModeling Results to Support Rulemakings U.S. Modeling for Clean AirInterstate Rule (CAIR), 2005 On March 10,2005, the U.S. EPA finalized the Clean Air Interstate Rule (CAIR). S02 emissions from powerplants in the 28 eastern states and the District ofColumbiacovered by CAIR, will be cutby 4.3 million tons by 2009 andreduced by an additional 5.4 million tons in 2015. NOx emissions will be cutby 1.7 million tons by 2009 and reduced by an additional 1.3 million tons in 2015. Indianawill reduce S02 emissions from the implementation ofCAIR in 2009 by 222,000 tons from the 2009 emissions projections

31without CAIR and by 2015, will be reduced by an additional 178,000 tons from the 2015 emissions projections without CAIR. Indianawill 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 supportthe emissionreductions 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 yearmodeling was conducted, including the Southwestern Indianacounties, and the future yeardesign values for 2010 and 2015 were evaluated for attainment ofthe annual fine particles NAAQS of15 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 Indianafine 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 yearemissions and then the emissions reductions associated with CAIR. U.S. EPA found model perfonnance met suggested benchmarkperformance goals and withinthe range or betterthan 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 yearmodeling 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 yearmodeling 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 of1.0 to 1.3 Jlg/m3 by 2010 and 1.3 to 1.4 Jlg/m3by 2015.

32Results ofthe U.S. EPA CAIRmodeling showthat 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 AirDirectors 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 CAIRmodeling test was based on the 3 most current 3-yeardesign 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 atthe time ofthe modeling. 2007 datahas since been made available and review ofthe 2007 annual values shows that the 2005-2006 average design values for the SouthwestIndianawere 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 Jaspermonitorhas datathroughout the baseyear design value period and shows modeled concentrations at 12.4 ug/m3. Therefore, the

33modeled attainmenttest 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 without2007 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 GolfCourse 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 bRepresents a two-year design value Results ofthe LADCO CAIR modeling showthat all SouthwestIndiana Counties will attain the annual NAAQS for fine particles of 15 Ilg/m3 by 2009. As shown in Figure 7.1, future yearmodeled 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 SouthwestIndiana PM2.5 Monitors for 2009, 2012 and 2018 18 17 16 c;;- 

## .e 15 III c 14 0 ;: I! 

# - c 13 fD 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 attainmenttest 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. Percentranges ofthe model results from the five fine particle monitors in SouthwestIndianawere 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.



### 35Table 7.4 LADeO's Round 5 SMAT Modeling Results for Southwest Indiana (percent change from observed to modeled concentrations) Species ofPM2.5 

### 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 waterconcentration decreases are projectedto occurby at least 16% in the future year 2009. Lessernitrate reductions are projectedto 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 oforganic carbon concentrations. Overall, model performance is adequate for State Implementation Plan (SIP) planning and gives a good ideaofthe effects ofemissions reductions from national emission control measures on Southwest Indiana. 7.3 LADCO'S Round 5 Particulate Source ApportionmentResults 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. Indianawas the biggestregional contributorto the Jasper, West Mill Road and the Dale fine particle monitors. Kentucky was the biggestregional contributorto the Civic Center and University ofEvansville fine particle monitors with Illinois as the biggestregional contributorto the Knox County fine particle monitor. The PSAT Round 5 modeling results show the majority ofIndiana's emission sector contributions to fine particle concentrations atcome from electric generating units (EGUs), ammonium emission sources, ,off-road (including marine, aircraft and railroad) and non-EGU sources. These results are consideredto be representative ofthe entire SouthwestIndiana area as EGU, ammonium and non-EGU emissions impactthe 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

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

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Concentrw.tion (up]) Conc:entnlbon lUP:!) Below are pie charts depicting the species contributions to fine particle concentrations at the SouthwestIndianamonitors. The pie charts include boththe observed 2005 contributions and future year 2009 modeled contributions for each monitor. Since the monitors are in close proximity ofeach other, results are fairly similar in the distribution ofspecies concentrations among the monitors. Charts 7.2 and 7.3 coverthe fine particle monitors in the SouthwestIndiana areawith the highest monitored concentrations that are

37used 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_COnlrfbullonlItW. tath U PMU Monitor blon 

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

# . ..



# .

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# ...
• pbw CbIon a_ .003 Coc Cec 

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Chart 7.3 

### Pie Charts

- Species Modeled Contributions to University ofEvansville PM2 .5 Monitor (Observed Concentrations = 15.1) 

### (Modeled Concentrations =12.8)

Observed 2_ COnlrlbulionsItWIshlngton PlrkPM2.& Monitor blon 3

...



# ... ...

oc 

### ,.... 

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# .... cnM .pbw Cblon 2009 Modlled COnlrfbullonlItWIshlngton Perk PMU Monitor blon 

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Results ofthe Round 5 PSAT modeling for SouthwestIndiana fine particle monitors showthe highest pollutant contributors to basecase and future year fine particle concentrations are sulfate, organic carbon, ammonium and nitrate. Future yearmodeling 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 meetthe standard into the future. Modeling support for



### 38the Clean AirInterstate Rule has shown that future year design values for the Southwestern Indianacounties will continue to attainthe annual standard for fine particles with modeled future yeardesign values below 15 Jlg/m3• U.S. EPA future year modeling ofnational emission control strategies showedthe 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 Indianacounty's fine particles attainment area will be maintained with an increasing margin ofsafety overtime. 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 airridging provides conducive conditions for development and transport offine particles. Ultimately, passage ofsurface cold fronts with a clean air mass change will lowerfine particle readings in the Southwestern IndianaArea. 7.6 Surface Air Conditions Present during High Fine Particle Concentrations Days Higher annual concentrations offine particles tend to correlate with warmertemperatures and lighterwind speeds, although high fine particle episodes can occur in the summeror winter. It should be noted that higher annual fine particle concentrations are driven by individual days with higherfine particle concentrations throughout the monitored year. Therefore, it is difficultto attribute higher fine particle concentrations to annualized meteorological rankings. Review ofseveral ofthe higherfine particle concentration episodes overthe past few years shows conditions were hot in the summerwith temperatures in the middle 800s F or higher and average wind speeds were fairly light. Fall and winterdays with higher fine particle concentrations had nearnormal temperatures but wind speeds were very light. 7.7 Upper Air Conditions Present during High Fine Particle Concentrations Days Upper airridges and more stagnant surface wind conditions predominately affect development and build up offine particles. Slow moving upper airridges can effectively suppress mixing withinthe many levels ofthe atmosphere and cause pollutants to build up overtime. Inversions orincreases in temperature with a rise in altitude will prevent mixing with air from the upper atmosphere. These conditions can occurat 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 ofhigher fine particle concentration days showed stagnant surface conditions and upper air ridges existed on those days and helped in the buildup offine particle concentrations.

397.8 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 Indianathat correlated different levels offine particle concentrations to meteorological conditions from 1999- 2004. (Donna Kenski, 2005). This type ofanalysis looks atthe meteorological conditions, such as temperature, pressure, wind speed, wind direction, relative humidity and dewpointtemperatures atthe surface as well as morning and evening mixing heights in the upper atmosphere which were presentwhen higher concentrations offine particles were monitored. Results ofthis CART analysis indicated factors that played a larger role in higher fine particle concentrations in Indianawere warm-weather conditions with high dew points, southwest winds and high evening mixing heights. Previous day's concentrations offine particles playakey 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 ofparticulate constituents vary, with nitrates being more prevalentin the winter and sulfates more prevalentin the summer. Emissionreductions ofsulfates and nitrates appearto have the biggest impact on lower future year fine particle concentrations. Chart 7.4 shows by year, the percentage ofthe number ofdays during which fine particle levels reached the Air Quality Index ranges for "Good" (0 to 15 flg/m\ "Moderate" (15.4 flg/m3 to40.4 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 of65.5 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

• GoodTable 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 nexthighest amount ofdays. 

### Table 7.S Ranking ofHighest Number ofDays at AQI Levels ofHealth Concern Ranking Good Moderate Unhealthy for Sensitive Grou 1 st 2004 2005 2005 2Dd 2006 2001 20011200212003 

### 3 rd 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 SouthwestIndianawith fine particle readings in the moderate and USG levels and the lowest number ofdays in the Good level. 7.9 Summary ofMeteorological Analysis for Southwest Indiana Annual fme particle concentrations in the Southwestern IndianaArea are driven by higher fme particle concentration days that can occur during any time ofthe year. Conditions that are mostprevalent during higher fine particle concentration days are lighterwinds, higherrelative humidity and above average temperatures in the summer and nearnormal temperatures in the fall, winter or spring. Upper air weatherpatterns generally include ridging over the area with stagnant conditions at the surface. Surface winds from any direction can transportpollutants from surrounding areas into the Southwestern Indiana Area. Nitrates are biggercontributors to fine particle concentrations in the winter and sulfates are biggercontributors to fine particle concentrations in the summer.


### 8.0 CORRECTIVE ACTIONS 8.1 Commitment to Revise Plan As noted in Section 4.6 above, Indianahereby commits to review and revise as appropriate its Maintenance Plan eightyears afterredesignation, as required by Section 175A ofthe CAAA.

418.2 Commitment for Contingency Measures Indiana will monitor fine particle concentrations to determine whethertrends indicate higher values or whether emissions appearto 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, priorto a violation ofthe standard occurnng. Indianahereby 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 of15.1 Ilg/m3 or greater) occurs. In the eventthatthe Action Level is triggered and is not found to be due to an atypical unfavorable meteorological condition, exceptional event, malfunction, ornoncompliance with a permit condition orrule requirement, IDEM will determine additional control measures needed to assure future attainment ofNAAQS for fine particles. Inthis case, measures that can be implemented in a short time will be selected in orderto be in place within eighteen (18) months from the close ofthe fine particles season thatprompted the Action Level. Control Measure Selection and Implementation Adoption ofany additional control measures is subject to the necessary administrative and legal process. This process will include publication ofnotices, an opportunity for public hearing, and othermeasures required by Indiana law for rulemaking by state environmental boards. Ifa new measure orcontrol is already promulgated and scheduled to be implemented at the federal or state level, and that measure orcontrol is determined to be sufficientto address the upward trend 

### in air quality, additional local measures may be unnecessary. Furthermore, Indiana will submitto 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 orother factors that IDEM deems appropriate. IDEM will solicit input from all interested and affected persons in the maintenance areapriorto selecting


### 42appropriate contingency measures. All ofthe listed contingency measures are potentially effective orproven methods ofobtaining significant reductions offine particle precursor emissions. Because it is notpossible at this time to determine what control measure will be appropriate at an unspecified time in the future, the list ofcontingency measures outlined below is not comprehensive. Indiana anticipates that ifcontingency 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 NOxor S02 controls on new minor sources (less than 100 tons). 3) Wood stove change out program. 4) Idle restrictions. 5) Broader geographic applicability ofexisting measures. 6) One or more transportation control measures sufficientto achieve at least a halfa 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, butnot limited to, employer-based transportation management plans, area-wide rideshare programs, work schedule changes, and telecommuting. b. Transit improvements. c. Traffic flow improvements. d. Othernew or innovative transportation measures not yet in widespread use that affects state and local governments deemed appropriate. No contingency measure shall be implemented withoutproviding 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 ofavailability 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 commentperiod 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

43cover. Appendix M includes a copy ofthe public notice, certifications ofpublication, and verification ofthe public hearing location.

10.0 CONCLUSIONS The Southwestern IndianaAreahas attained the annual NAAQS for fine particles. This petition demonstrates thatthe Southwestern IndianaAreahas complied with the applicable provisions ofthe 1990 Amendments to the Clean AirActregarding redesignation ofnonattainment areas for fine particles. IDEM has prepared a State Implementation and Maintenance Plan that meets the requirement ofSection 110 (a)(l) of the 1990 Clean AirAct. Indiana has performed an analysis that shows the air quality improvements are due to permanent and enforceable measures and that additional significantregional NOx reductions following implementation ofPhase II NOx SIP Call and CAIR will ensure continued compliance (maintenance) withthe standard. Furthermore, because this area is subjectto significanttransport ofpollutants, significantregional S02 andNOx reductions will ensure continued compliance (maintenance) with the standard with an increasing margin ofsafety. Based on this presentation, the Southwestern IndianaNonattainment Area for fine particles meets the requirements for redesignation underthe CAA (Section 107 (d) (3» and U.S. EPA guidance. Consistent with the authority granted to the U.S. EPA, the State ofIndianahereby requests thatthe Southwestern Indiana AreaNonattainment Area for fine particles be redesignated to attainment simultaneously with U.S. EPA approval ofthe Indiana State Implementation and Maintenance Plan provisions contained herein.



### 44