IDEM INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

We Protect Hoosiers and Our Environment.

Mitchell E. Daniels Jr. 100 North Senate Avenue

Governor Indianapolis, Indiana 46204

(317) 232-8603

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

Commissioner www.ldem.lN.goY

t;i:G2N;:;D

DEC 09Z009

Mr. Bharat Mathur

Acting Regional Administrator

U.S. Environmental Protection Agency

Region V

77 West Jackson Boulevard

Chicago, IL 60604-3950

Dear Mr. Mathur:

December 7, 2009

Re: Technical Addendum for the Request for

Redesignation and Maintenance Plan under the

Annual Fine Particles Standard for the

Southwestern Indiana Area

The Indiana Department ofEnvironmental Management (IDEM) has prepared this technical addendum

to the Request for Redesignation and Maintenance Plan under the Annual Fine Particles Standard for the

Southwestern Indiana Area to demonstrate the future year impacts from Electric Generating Units (EGUs) in the

Southwestern Indiana Area. The final Request for Redesignation and Maintenance Plan was submitted to U.S.

EPA on April 3, 2008.

IDEM has conducted photochemical modeling in order to determine the potential impacts from EGUs in

Southwestern Indiana on fme particle concentrations. The modeling was conducted using the "Round 6"

emiSsions and meteorological files, compiled by the Lake Michigan Air Directors Consortium (LADCO) and

previously submitted by IDEM to the U.S. EPA. The Comprehensive Air Quality Model (CAMx, version 5.01)

was used to determine future year concentrations with maximum EGU emissions assumed for those located in

Southwestern Indiana. The basecase emissions and meteorological files were based on 2005 data. Table I

below lists the seven EGUs, for which IDEM increased future year emissions to maximum reported levels.

Table 1

Southwest Indiana Electric Generatin2 Units (EGUs)

County FacBityName

Dubois COWlty Jasper Municipal Electric Utility

Gibson COWlty PSI Energy - Gibson

PikeCoWlty Hoosier Ener~ - Ratts Station

IPL Petersburp; Generatinp; Station

Spencer COWlty Indiana Michigan Power - Rockport

Warrick COWlty SIGECO F.B. Culley Generatin~ Station

SIGECO Warrick Power Plant

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Mr. Mathur

Page 2 of4

The purpose ofthis modeling exercise was to detennine whether continued attainment ofthe annual

standard for fme particles would be jeopardized in Southwestern Indiana ifthe EGUs located in the area were to

unexpectedly discontinue the operation of existing emission control equipment in the future. IDEM 6elieves that

its future year emission assumptions are overly conservative due to pennanent and enforceable regulatory

programs either being or likely to be in place, including the NOx SIP Call, the Acid Rain Program, and the Clean

Air Interstate Rule/Replacement Rule.

The emissions data derive from actual emissions reported by the EGUs located in Dubois, Gibson, Pike,

Spencer and Warrick Counties. Fine particle specie emissions were adjusted in these five counties to the

maximum annual emissions reported to IDEM from 2000 to 2007 for the EGUs listed in Table 1. Ratios were

detennined using the maximum emissions compared to 2005 emissions in order to model the increase to assess

the EGUs at their maximum operation over the past eight years. These ratios, shown in Table 2, were then

applied to the future year modeling files to detennine the increase in emissions for the EGUs located in

Southwestern Indiana.

Table 2

Emission Ratios for Southwest Indiana EGUs (Tons per Year Increase)

PMl.5 Species Dubois Co. Gibson Co. Pike Co. Spencer Co. Warrick Co.

NO 2.74 3.37 1.97 1.88 9.46

N02 2.74 3.37 1.97 1.88 9.46

S02 2.72 1.44 3.82 1.29 5.76

PN03 2.74 3.37 1.97 1.88 9.46

PS04 2.72 1.44 3.82 1.29 5.74

FPRM 6.37 9.38 8.85 14.52 21.46

CPRM 5.61 6.88 12.04 11.18 36.41

CCRS 5.61 6.88 12.04 11.18 36.41

FCRS 6.37 9.38 8.85 14.52 21.46

The new modeling results were then compared to the basecase modeled results from Round 6 to

detennine impacts from the increase in EGU emissions in Southwest Indiana. The"se results are shown in Tables

3 through 5 and show annual fine particle concentrations in Southwest Indiana increased just slightly from 0.1

J!glm3 to 0.2 J!g/m3 in 2009 and from 0.1 J!g/m3 to 0.3 J!g/m3 in 2012 and 2018. The largest increase in

concentrations as a result ofthe adjusted EGU emissions occurred in Dubois and Spencer Counties. These areas

would be considered downwind ofthe majority ofEGUs in the Southwest Indiana region. Monitors outside the

Southwestern Indiana region showed modeled impacts at 0.1 J!g/m3 or less.

I d· 2009

Table 3

Round6Non-CAIRAnnuaI PM2.5 M d0 er102 R I esuts fior Southwestern n lanaDesign 2009 Impact

Value 2009 Basecase from

MonitorID Monitor Name County 2003-2007 Basecase SW IN EGU SWIN

increase EGU

increase

, (llwmJ

) (llwmJ

) (llg/mJ

) (llg/mJ

)

18-163-0006 Civic Center Vanderburgh 14.7 14.5 14.6 0.1

18-163-0012 W. Mill Rd. Vanderbur~" 14.8 '14.7 14.8 0.1

18-163-0016 Univ.ofEvansville Vanderburgh 15.0 14.8 14.9 0.1

18-147-0009 Dale Spencer 14.3 14.1 14.3 0.2

18-037-2001 Jasper Post Office Dubois 15.2 14.9 15.1 0.2

18-083-0004 SW Purdue Ag. Knox 14.0 13.8 13.9 0.1
Mr. Mathur

Page 3 of4

2012

Table 4

R d6N CAIRA I PM Mod Ii R I fi S th tId' . oun on- nnua 2.5 e ne: esuts or ou wes ern Ii lana- 1 ., -. 'Design , 2012 Impact' ,- , . Value 2012 Basecase frbm' ' '.' MonitorID Monitor Name County . 2003-2007 Basecase ·SWIN SW'IN - EGU EGU

increase increase

(J,lg/m3

) (J,lg/m3

) (J,lg/m3

) (J,lg/m3)

18-163-0006 Civic Center Vanderburgh 14.7 14.4 14.5 0.1

18-163-0012 W. Mill Rd. Vanderbur~h 14.8 14.5 14.7 0.2

18-163-0016 Univ.ofEvansville Vanderburgh 15.0 14.7 14.8 0.1

18-147-0009 Dale Spencer 14.3 14.0 14.2 0.2

18-037-2001 Jasper Post Office Dubois 15.2 14.8 15.0 0.2

18-083-0004 SW Purdue Ag. Knox 14.0 13.7 13.8 0.1

2018

TableS

Round6Non-CAIRAnnuaI PM2.5 M do eID2 r ResuIts fior SouthwestId' ern n lanaDesign 2018 Impact

Value 2018 Basecase from

MonitorID Monitor Name County 2003-2007 Basecase SWIN SWIN

EGU EGU

increase increase

(J,lg/m3

) (J,lg/m3

.) (Jtg/m3

) (J,lg/m~)

18-163-0006 Civic Center Vanderburgh - 14.7 14.3 l4.4 ,0.1-

18-163-0012 W. Mill Rd. Vanderbur~ 14.8 14.4 14.5 0.,1

18-163-0016 Univ.ofEvansville Vanderburgh 15.0 14.6 14.7 0.1

18-147-0009 Dale Spencer 14.3 13.9 14.1 0.2

18-037-2001 Jasper Post Office Dubois 15.2 14.6 14.9 0.3

18-083-0004 SW Purdue Ag. Knox 14.0 13.5 13.7 0.2

The future year modeling indicates that ifall EGUs in Southwest Indiana operated at their maximum

emissions as recorded over the past eight years, all monitors in the Southwestern Indiana Nonattainment Area

would remain below the annual fine particle National Ambient Air Quality Standard of 15.0 J.lglm3

• IDEM

deems the results ofthis modeling exercise to be conservative. For example, the monitored design value for

annual fine particle concentrations within the Southwestern Indiana Nonattainment Area at the close of2008

(2006-2008) was 13.7 J.lglm3

, and the most current design value through the third quarter of2009 (2007-Qtr.3

2009) is 13.3 J.lglm3

• The highest future year modeled concentration with maximum EGU emissions factored in

was for 2009 at 15.1 J.lglm3

, which reflects a margin ofsafety between 1.4 and 1.8 J.lglm3•

IDEM believes that this technical addendum in conjunction with the previously submitted

Redesignation Request and Maintenance Plan satisfies Indiana's obligation under Section 172(c) ofthe Clean

Air Act to demonstrate how the area attained, and will continue to attain the annual NAAQS for f!ne particles.

Quality assured ambient air quality monitoring data for fine particles through third qu~er of 2009 dem~ristrates

that the Southwestern Indiana area has attained the annual NAAQS for fme particle.s for.a fo~Ji con~utive

year and. is ellgibie for redesign~tion. The resul~s ofthe, future y~ar modeling,exercise summarized above

illustrates that the Southwestern Indiana Area will continue to attain the annual standard for fine:particies well

into the future without relying on emission reductions from the Clean Air Interstate Rule. Furthermore, IDEM

has demonstrated that in the unlikely instance that the EGUs within the Southwestern Indiana Area do not

operate existing emission controls in the future, the area would still comply with the annual standard for fine

particles.
Mr. Mathur

Page 4 of4

IDEM requests that U.S. EPA proceed with final review and approval ofthe Request for Redesignation

and Maintenance Plan under the Annual Fine Particles Standard for the Southwestern Indiana Area. Ifyou have

any questions or need additional information, please feel free to contact Scott Deloney ofIDEM's Office ofAir

Quality at (317) 233-5694 or sdeloney@idem.in.gov.

. homas~~ery Commissioner

DM/sd/skr

cc: John Summerhays, U.S. EPA Region 5

Matt Rau, U.S. EPA Region 5

John Mooney, U.S. EPA Region 5

Cheryl Newton, U.S. EPA Region 5

Scott Deloney, IDEM

Christine Pedersen, IDEM

Sarah Raymond, IDEM