## Clifty Creek Station

Madison, Indiana

Evaluation of Compliance wi th the 1-hour NAAQS for SO 2


## September 17, 2015

Conducted by:

Steven Klafka, P.E., BCEE

Wingra Engineering, S.C.

Madison, WisconsinEvaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 2

1. Introduction

Wingra Engineering, S.C. was hi red by Sierra Club to conduct an air modeling impact analysis to help the U.S. Environmental Prot ection Agency (USEPA), state an d local air agencies identify
facilities that are likely causing exceedances of the 1-hour su lfur dioxide (SO 2 ) national ambient air quality standard (NAAQS). This doc ument describes the results and procedures for an evaluation conducted for the Clifty Cree k Station located in Madison, Indi ana.

To ensure the modeling analysis reflected the cumulative concen tration of SO 2 emissions, it included
emissions from the followi ng additional sources of SO 2 , which are located w ithin 50 kilometers of the Clifty Creek Station:

 Trimble County Generating S tation – Bedford, Kentucky

 Ghent Generating Station – Ghent, Kentucky

The dispersion modeling analysis predicted ambient air concentr ations for comparison with the 1-
hour SO 2 NAAQS. The modeling was performe d using the most recent versi on of AERMOD, AERMET, and AERMINUTE, with data provided to Sierra Club by reg ulatory air agencies or obtained through other publicly-a vailable sources as documented below. The analysis was
conducted in adherence to all ava ilable USEPA guidance for eval uating source impacts on
attainment of the 1-hour SO 2 NAAQS via aerial dispersion m odeling, including the AERMOD Implementation Guide; USEPA’s A pplicability of Appendix W Model ing Guidance for the 1-hour
SO 2 National Ambient Air Qual ity Standard, August 23, 2010; modeli ng guidance promulgated by USEPA in Appendix W to 40 CFR Part 51; USEPA’s March 2011 Model ing Guidance for SO 2 NAAQS Designations; 1 and USEPA’s December 2013 SO 2 NAAQS Designations Technical
Assistance Document. 2

2. Compliance with the 1-hour SO 2 NAAQS

2.1 1-hour SO 2 NAAQS

The 1-hour SO 2 NAAQS takes the form of a t hree-year average of the 99 th -percentile of the annual distribution of daily maximum 1- hour concentrations, which cann ot exceed 75 parts per billion (ppb). 3 Compliance with this standar d was verified using USEPA’s AERM OD air dispersion model, which produces air concentr ations in units of μg/m 3 . The 1-hour SO 2 NAAQS of 75 ppb equals 196.2 μg/m 3 , and this is the value used for determining whether modeled im pacts exceed the

1 http://www.epa.gov/scram001/ so2_modeling_guidance.htm

2 http://www.epa.gov/oaqps001/sulfurdioxide/pdfs/SO2ModelingTAD. pdf

3 USEPA, Applicability of Appendix W Modeling Guidance for the 1- hour SO 2 National Ambient Air Quality Standard, August 23, 2010.Evaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 3

NAAQS. 4 The 99 th -percentile of the annual dist ribution of daily maximum 1-hour concentrations corresponds to the fourth-highest value at each receptor for a given year.

2.2 Modeling Results

Modeling results for Clifty Cr eek, Trimble County, and Ghent Ge nerating Stations are summarized
in Table 1. It was determined t hat based on either current allo wable emissions or measured actual emissions, the Clifty Creek Sta tion is estimated to create down wind SO 2 concentrations which exceed the 1-hour NAAQS.

More specifically, the modeling results presented in Table 1, s how exceedances of the NAAQS by the plant’s allowable and actua l emissions. “Allowable” is the peak emission rate from each unit as approved by the current air quali ty operation permit for the fa cility. “Actual” are the measured emissions for each hour between January 1, 2012 and December 31 , 2014 as taken from USEPA Air Markets Program Data

. 5

In addition, the emissions from the Trimble County and Ghent Ge nerating Stations, both individually and cumulatively, s ignificantly contribute to the ambient SO2 concentration in the area impacted by Clifty Cree k Generating Station.

Air quality impacts in India na are based on a background concen tration of 41.7 μg/m 3 . This is the 2011-13 design value for Vanderburgh County, Indiana - the lowe st measured background
concentration in the state. This is the most recently availabl e design value. See S ection 5 for further discussion of the background concen trations used for this analy sis.

Table 1 - SO 2 Modeling Results for Clifty Creek Station Modeling Analysis

Emission Rates Averaging Period 99 th Percentile 1-hour Daily Maximum (μg/m 3 ) Complies with NAAQS? Impact Background Total NAAQS

Allowable Clifty Creek 1,681.8 47.1 1,728.9 196.2 No

Actual 234.3 47.1 281.4 196.2 No

Actual Trimble 33.5 47.1 80.6 196.2 Yes

Actual Ghent 76.0 47.1 123.1 196.2 Yes

Actual All Plants 236.5 47.1 283.6 196.2 No

4 The ppb to μg/m 3 conversion is found in the source code to AERMOD v. 14134, sub routine Modules. The conversion calculation is 75/0.3823 = 196.2 μg/m 3

. 5 http://ampd.epa.gov/ampd/Evaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 4

The emissions used for the mode ling analysis are summarized in Table 2.

Table 2 - Modeled SO 2 Emissions from Clifty Creek Station 6

Stack

ID Unit
ID Allowable Emissions 30-day Average (lbs/hr)

S13 Unit 1 14,054.9 Unit 2 14,054.9 Unit 3 14,054.9 Subtotal 42,164.7

S46 Unit 4 14,054.9 Unit 5 14,054.9 Unit 6 14,054.9 Subtotal 42,164.7 Facility Total 84,329.4

Based on the modeling results, Table 3 provides the emission re ductions from current allowable rates necessary to achieve com pliance with the 1-hour NAAQS. T his assumes a one-hour averaging period for the emission rate and that the emission rate is bind ing at all times. However, given the conservative aspects of this modeling protocol, it is extremely likely that this limit is too high to protect the NAAQS. For example , startup or shutdown periods wer e not evaluated. During these periods, decreased gas velocities and temperatures may lead to greater ambient impacts at ground level. Further, the hypothetic al emission limitation in Table 3 would allow Clifty Creek Station to consume the entire NAAQS, leav ing little to no room for any oth er source of SO 2 in the area. No margin of safety has been incl uded in the hypothetical emission limitation.

Table 3 - Required Emission Redu ctions from the Clifty Creek Generating Station for Compliance
with the 1-hour NAAQS for SO 2 Acceptable Impact (NAAQS - Background) 99th Percentile 1-hour Daily Max (μg/m 3 ) Required Total Facility Reduction Based on Allowable Emissions (%) Required Total Facility Emission Rate (lbs/hr) Required Total Facility 1-hour Average Emission Rate

(lbs/mmbtu)
149.1 91% 7,476.2 0.67

Predicted exceedances of the 1-hour NAAQS for SO 2 based on allowable emissions extend throughout the region to a maxim um distance of 50 kilometers.

6 Indiana Department of Environmental Management,Part 70 Operati ng Permit Renewal, Operation Permit No. T077- 29920-00001, July 7, 2001. Allowa ble emissions for Units 1 to 6 are 7.52 lbs per million BTU.Evaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 5

Figure 1 shows the extent of NAA QS violations based on allowabl e emissions from Clifty Creek Generating Station.

Figure 2 shows the extent of NAA QS violations based on actual h ourly emissions from all sources.

2.3 Conservative Modeling Assumptions

A dispersion modeling analysis requires the selection of numero us parameters which affect the predicted concentrations. For the enclosed analysis, several pa rameters were selected which underpredict facility impacts.

Assumptions used in this modeli ng analysis which likely under-e stimate concentrations include the following:

 Allowable emissions are base d on a limitation with an averaging period which is greater than the 1-hour average used for the SO 2 air quality standard. Emissions and impacts during any 1-hour period may be higher than assumed for the modeling analy sis.

 No consideration of facility operation at less than 100% load. Stack parameters such as exit flow rate and temperature are typically lower at less than full load, reducing pollutant dispersion and increasing predic ted air quality impacts.

 No consideration of building or s tructure downwash. These downw ash effects typically increase predicted concentr ations near the facility.

 Except for Trimble County and Ghent Generating Stations, no con sideration of off-site

sources. Any other sources of SO 2 will increase the predicted impacts.Evaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 6

Figure 1 - Regional View of Impacts Due to Allowable Emissions from Clifty Creek StationEvaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 7

Figure 2 - Regional View of Impacts Due to Actual Emissions for the 2012-14 Period from All SourcesEvaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 8

3. Modeling Methodology

3.1 Air Dispersion Model

The modeling analysis used U SEPA’s AERMOD program, v. 14134. A ERMOD, as available from the Support Center for Regulator y Atmospheric Modeling (SCRAM) website, was used in conjunction with a third-par ty modeling software program, AERMOD View , sold by Lakes
Environmental Software.

3.2 Control Options

The AERMOD model was run with t he following control options:

 1-hour average air concentrations

 Regulatory defaults

 Flagpole receptors

To reflect a representative i nhalation level, a flagpole height of 1.5 meters was used for all modeled receptors. This parameter was added to the receptor file when running AERMAP, as described in
Section 4.4.

An evaluation was conducted to det ermine if the modeled facilit y was located in a rural or urban setting using USEPA’s methodology outlined in Section 7.2.3 of the Guideline on Air Quality
Models. 7 For urban sources, the URBANOPT option is used in conjunction with the urban population from an appropriate ne arby city and a default surfac e roughness of 1.0 meter. Methods
described in Section 4.1 were used t o determine whether rural o r urban dispersion coefficients were appropriate for the modeling analysis.

3.3 Output Options

The AERMOD analysis was based on three years of recent meteorol ogical data. The modeling analyses used one run with three ye ars of sequential meteorolog ical data from 2012-2014. Consistent with USEPA’s Modeling Guidance for SO 2 NAAQS Designations, AER MOD provided a table of fourth-high 1-hour SO 2 impacts concentrations consiste nt with the form of the 1-hour SO 2 NAAQS. 8

Please refer to Table 1 for the modeling results.

7 USEPA, Revision to the Guidelin e on Air Quality Models: Adopti on of a Preferred General Purpose (Flat and Complex Terrain) Dispersion Model and Other Revisions, Appendix W to 40 CFR Part 51, November 9, 2005.

8 USEPA, Area Designations for the 2010 Revised Primary Sulfur Di oxide National Ambient Air Quality Standards, Attachment 3, March 24, 2011, pp. 24-26.Evaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 9

4. Model Inputs

4.1 Geographical Inputs

The “ground floor” of all air dis persion modeling analyses is e stablishing a coordinate system for identifying the geographical loc ation of emission sources and r eceptors. These geographical
locations are used to determine local characteristics (such as land use and elevation), and also to ascertain source to receptor di stances and relationships.

The Universal Transverse Merca tor (UTM) NAD83 coordinate system was used for identifying the easting (x) and northing (y) coordi nates of the modeled sources and receptors. Stac k locations were obtained from facility permits and prior modeling files provide d by the state regulatory agency. The
stack locations were then veri fied using aerial photographs.

The facility was evaluated to de termine if it should be modeled using the rural o r urban dispersion coefficient option in AERMOD. A Geographic Information System (GIS) was used to determine whether rural or urban dispersi on coefficients apply to a site. Land use within a three-kilometer radius circle surrounding the f acility was considered. USEPA gu idance states that urban dispersion
coefficients are used if more t han 50% of the area within 3 kil ometers has urban land uses. Otherwise, rural dispersion c oefficients are appropriate. 9

USEPA’s AERSURFACE v. 13016 was use d to develop the meteorologi cal data for the modeling analysis. This model was also us ed to evaluate surrounding land use within 3 kilometers. Based on the output from the AERSURFAC E, approximately 11.6% of surround ing land use around the modeled facility was of urban l and use types including Type 21 – Low Intensity Residential, Type 22 – High Intensity Residential and Type 23 – Commercial / Indu strial / Transportation.

This is less than the 50% value c onsidered appropriate for the use of urban dispersion coefficients. Based on the AERSURFACE analysis, i t was concluded that the rur al option would be used for the modeling summarized in this re port. Please refer to Section 4. 5.3 for a discussion of the AERSURFACE analysis.

9 USEPA, Revision to the Guidelin e on Air Quality Models: Adopti on of a Preferred General Purpose (Flat and Complex Terrain) Dispersion Model and Other Revisions, Appendix W to 40 CFR Part 51, November 9, 2005, Section 7.2.3.Evaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 10

4.2 Emission Rates and Source Parameters

The modeling analyses only considered SO 2 emissions from the Gibson, Trimble County, and Ghent
facilities. Other off-site sour ces were not considered. Concent rations were predicted for the scenarios
shown in Tables 1 and 2:

1) allowable emissions based on t he current permit issued by th e regulatory agency, and

2) actual hourly emissions meas ured each hour between January 1 , 2012 and December 31,
2014 as taken from USEPA Air Markets Program Data

. 10

Stack parameters and emissions use d for the modeling analysis a re summarized in Table 4.

Table 4 – Facility Stack Parameters and Emissions 11

Facility Clifty Creek Ghent Trimble

Stack S13 S46 G01 G02 G04 T01 T02

Description Units 1, 2 and 3 Units 4, 5 and 6 Unit 1 Units 2 and 3 Unit 4 Unit 1 Unit 2

X Coord. [m] 637424 637433.05 670779 670554 670479 638151 63815 5
Y Coord. [m] 4289051 4289043.51 4290835 4290716 4290646 4271869 4271865
Base Elevation [m] 143.21 143.06 147.94 147.82 148.8 146.38 146 .34
Release Height [m] 299.31 299.31 201.78 176.78 201.78 231.65 23 1.65
Gas Exit Temperatu re [°K] 329.261 328.706 324.817 324.817 324.8 17 324.817 329.261

Gas Exit Velocity [m/s] 15.084 15.453 15.342 14.976 14.62 27.07 7 27.836

Inside Diameter [m] 9.504 9.504 8 .077 15.941 8.077 5.486 6.279
Allowable Emission Rate [g/ s] 5,313 5,313 - - - - -

Actual Emission Rate [g/s] - - - - - - -

The above stack parameters and emissions were obtained from reg ulatory agency documents and
databases identified in Secti on 2.2. The analysis was conducted based on 100% operating load using
maximum exhaust flow rates and t emperatures. Operation at less than full capacity loads was not considered. This assumption te nds to under-predict impacts sinc e stack parameters such as exit flow rate and temperature are typically lower at less than full load , reducing pollutant dispersion and increasing predicted air qualit y impacts. Stack location, heigh t and diameter were verified using aerial photographs, and flue gas fl ow rate and temperature were verified using combustion
calculations.

10 http://ampd.epa.gov/ampd/

11 Stack parameters were obtained from the annual survey compiled by the U.S. Energy Information Administration. http://www.eia.gov/electricity/data/eia860/Evaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 11

4.3 Building Dimensions

No building dimensions or prior dow nwash evaluations were avail able. Therefore this modeling analysis did not address the e ffects of downwash and this may u nder-predict impacts.

4.4 Receptors

For Clifty Creek Station, three receptor grids were employed:

1. A 100-meter Cartesian receptor grid centered on Clifty Creek St ation and extending out 5
kilometers.
2. A 500-meter Cartesian receptor grid centered on Clifty Creek St ation and extending out 10
kilometers. 3. A 1,000-meter Cartesian receptor grid centered on Clifty Creek Station and extending out 50 kilometers. 50 kilometers is the maximum distance accepted by U SEPA for the use of the AERMOD dispersion model. 12

A flagpole height of 1.5 meters w as used for all these receptor s.
Elevations from stacks and recep tors were obtained from Nationa l Elevation Dataset (NED) GeoTiff data. GeoTiff is a binary file tha t includes data descriptors a nd geo-referencing information necessary for extract ing terrain elevations. These elevations w ere extracted from 1 arc-second (30 meter) resolution NED files. The U SEPA software program AERMAP v. 11103 is used for these
tasks.

4.5 Meteorological Data

To improve the accuracy of the modeling analysis, recent meteor ological data for the 2012-2014 period were prepared using the U SEPA’s program AERMET which cre ates the model-ready surface and profile data files requir ed by AERMOD. Required data inpu ts to AERMET included surface meteorological measurements, t wice-daily soundings of upper air measurements, and the micrometeorological parameters surface roughness, albedo, and B owen ratio. One-minute ASOS
data were available so USEPA met hods were used to reduce calm a nd missing hours. 13 The USEPA software program AERMINUTE v. 14237 is used for these tasks.

This section discusses how the meteorological data was prepared for use in the 1-hour SO 2 NAAQS

12 USEPA, Revision to the Guideline on Air Quality Models: Adopti on of a Preferred General Purpose (Flat and Complex Terrain) Dispersion Model and Other Revisions, Appendix W to 40 CFR Part 51, Section A.1.(1), November 9, 2005.

13 USEPA, Area Designations for the 2010 Revised Primary Sulfur D ioxide National Ambient Air Quality Standards, Attachment 3, March 24, 2011, p. 19.Evaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 12

modeling analyses. The USEPA software program AERMET v. 14134 is used for these tasks.

4.5.1 Surface Meteorology

Surface meteorology was obtained for Louisville International A irport located near t he Clifty Creek Station. Integrated Surface H ourly (ISH) data for the 2012-2014 period were obtained from the National Climatic Data Center ( NCDC). The ISH surface data wa s processed through AERMET Stage 1, which performs data ex traction and quality control che cks.

4.5.2 Upper Air Data

Upper-air data are collected by a “ weather balloon” that is rel eased twice per day at selected
locations. As the balloon is rel eased, it rises through the at mosphere, and radios the data back to the surface. The measuring and transmitting device is known as eit her a radiosonde, or rawindsonde.
Data collected and radioed back i nclude: air pressure, height, temperature, dew point, wind speed, and wind direction. The upper air data were processed through AERMET Stage 1, which performs data extraction and quality control checks.

For Clifty Creek Station, t he concurrent 2012-2014 upper air da ta from twice-daily radiosonde
measurements obtained at the most representative location were used. This location was the Wilmington, Ohio measurement station. These data are in Forecas t Systems Laboratory (FSL)
format and were downloaded in ASC II text format from NOAA’s FSL website. 14 All reporting
levels were downloaded a nd processed with AERMET.

4.5.3 AERSURFACE

AERSURFACE is a program that ex tracts surface roughness, albedo , and daytime Bowen ratio for an area surrounding a given locatio n. AERSURFACE uses land use and land cover (LULC) data in the U.S. Geological Survey’s 1992 National Land Cover Dataset t o extract the necessary micrometeorological data. LULC data was used for processing me teorological data sets used as input to AERMOD.

AERSURFACE v. 13016 was used to deve lop surface roughness, albe do, and daytime Bowen ratio values in a region surrounding the meteorological data collecti on site. AERSURFACE was used to develop surface roughness in a one kilometer radius surrounding the data collection site. Bowen ratio and albedo was developed for a 10 kilometer by 10 kilomet er area centered on the meteorological data collection si te. These micrometeorological data were processed for seasonal periods using 30-degree sectors . Seasonal moisture conditions w ere considered ave rage with winter

14 Available at: http://esrl.noaa.gov/raobs/Evaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 13

months having continuous snow cover.

4.5.4 Data Review

Missing meteorological data were not filled as the data file me t USEPA’s 90% data completeness requirement. 15 The AERMOD output file shows th ere were 0.12% missing data.

To confirm the representativene ss of the airport meteorological data, the surface characteristics of the airport data collection s ite and the modeled source locatio n were compared. Since the Louisville International Airport is locat ed close to Clifty Creek Station, this meteorological data set was considered appropriate for this modeling analysis. 16 This weather stati on provided high quality surface measurements for the most recent 3-year time, and had s imilar land use, surface characteristics, terrain featur es and climate. Finally, the met eorological data from the selected surface and upper air stations were recommended by the Indiana Department of Environmental Management for modeling facilitie s located in Jefferson County. 17

5. Background SO 2 Concentrations

Background concentrations were determined consistent with USEPA ’s Modeling Guidance for SO 2 NAAQS Designations. 18, 19 To preserve the form of the 1-hour SO 2 standard, based on the 99 th percentile of the annual distri bution of daily maximum 1-hour c oncentrations averaged across the number of years modeled, the b ackground fourth-highest daily ma ximum 1-hour SO 2 concentration
was added to the modeled fourth-h ighest daily maximum 1-hour SO 2 concentration. 20 Background
concentrations were based on the 2011-13 design value measured by the ambient monitors located in
Indiana. 21

6. Reporting

All files from the programs used for this modeling analysis are available to regulatory agencies. These include analyses prepared w ith AERSURFACE, AERMET, AERMAP , and AERMOD.

15 USEPA, Meteorological Monitoring Guidance for Regulatory Modeli ng Applications, EPA-454/R-99-05, February 2000, Section 5.3.2, pp. 5-4 to 5-5.

16 USEPA, AERMOD Implementation Guide, March 19, 2009, pp. 3-4.

17 Indiana DEM, Air Dispersion Me teorological Data, http://www.in .gov/idem/airquality/2376.htm

18 USEPA, Area Designations for the 2010 Revised Primary Sulfur D ioxide National Ambient Air Quality Standards, Attachment 3, March 24, 2011, pp. 20-23.

19 USEPA, SO 2 NAAQS Designations Modeling Te chnical Assistance Document, Dec . 2013, section 8.1, pp 27-28.

20 USEPA, Applicability of Appendix W Modeling Guidance for the 1- hour SO 2 National Ambient Air Quality Standard, August 23, 2010, p. 3.

21 http://www.epa.gov/airtrends/values.html