# A TTACHMENT 

# E

## Missing Monitoring Data Imputation Analysis Monitoring Site 39-057-0005 Greene County, Ohio



## Ohio Environmental Protection Agency Lazarus Government Center 50 West Town Street, Suite 700 Columbus Ohio 43215

Prepared by Ohio EPA Division of Air Pollution Control State Implementation Plan Section March 20112 

## Dayton-Springfield PM2.5 Nonattainment Area Incomplete Monitoring Data Substitution Analysis The current Dayton-Springfield nonattainment area is located in southwest Ohio and includes the following counties: Clark, Greene, and Montgomery. The area has three monitors measuring PM 2.5 concentrations, which are operated by the Regional Air Polluti on Control Agency (RAPCA) 1 , which is part of the Montgomery County Health Department. A listing of t he design values based on the three-year average of the annual mean concentrations fr om 2008 through 2010 is shown in Table 1. The design values calculated for the Da yton-Springfield area shows that the annual PM 2.5 NAAQS has been attained. Table 1 - Monitoring Data for the Dayton-Springfield area for 2008 – 2010 Average 2008 2009 2010 2008-2010 39-023-0005 Clark 12.7 12.4 13.1 12.7 39-057-0005 Greene 11.6 11.5 13.2 12.1 39-113-0032 Montgomery 13.2 12.4 14.0 13.2 Less than 75% capture in at least one quarter Annual Standard Site County Year

Source: U.S. EPA Air Quality System (AQS); http://www.epa.gov/ttn/a irs/airsaqs/index.htm However, based on Section 10 7(d)(3)(E)(i) of the Clean Air Act (CAA) the PM2.5 monitoring has to show that the three-year average of t he annual mean values, based on data from all monitoring sites in the ar ea or its affected downwind environs, are below 15.0/m 3 . Moreover, in accordance with the CAA Amendments, three complete years of monitoring data are required to demons trate attainment at a monitoring site. In addition, U.S. EPA regulations require at l east 75% data capture in each quarter of a consecutive 3-year period in order for a design value to be valid. Table 1 shows that the monitor site in Greene County (site 39-057- 0005) did not comply with the 75% data capture requirement in 2010. Specifically, the third quarter (July, August, and September) of 2010 has only 45% capt ure. This monitoring site underwent roof repairs (reroofing) from 08/12/2010 thr ough 09/29/2010 for a total of 17 missing 1- in-3 day PM2.5 FRM runs. In 2010 there were scheduled a total of 122 scheduled runs. It is important to mention that this site is also the lowest reading site for PM 2.5 . In order to comply with U.S.EPA 75% capture requirements, Ohio EPA prepared a statistical analysis using mult iple imputations. Imputing mi ssing values for site 39-057-

1 RAPCA is a Local Air Agency that contracts with Ohio EPA and receives grants from U.S. EPA to enforce state and local air pollution control regulations in the six-county region (Preble, Darke, Miami, Montgomery, Clarke, and Greene).3 0005 and then doing an ordinary analysis as if the imputed values were real measurements (this approach is usually bette r than excluding subjec ts with incomplete data). Most methods for accounting for havi ng incomplete data can be complex; the bootstrapping method however, is an easy method to implement even though the computations can be slow. To use the bootst rap, to correctly estimate variances of regression coefficients, one must repeat th e imputation process and the model fitting perhaps 1000 times using a resampling procedure. Multiple imputations use random draws from the conditional distribution of the target variable given the other variables. When a regr ession model is used for imputation, the process involves adding a rand om residual to the “best guess” for missing values, to yield the same conditional variance as the original variable. To properly account for variability due to unknown values, the imputation will be repeated 1000 times. Imputing missing data for Dayton-Sp ringfield PM2.5 nonattainment area For simplification purposes we will call Si te 39-057-0005 Site A, Site 39-023-0005 Site B, and Site 39-113-0032 Site C. 1. Dayton-Springfield Annual PM2.5 Design Value History Table 2 – Historic Design Values for the Dayton-Springfield area from 1999 to 2010 Site Site County Annual Design Value 1999- 2001 2000- 2002 2001- 2003 2002- 2004 2003- 2005 2004- 2006 2005- 2007 2006- 2008 2007- 2009 2008- 2010 39-057-0005 A Greene 12.4 13.2 13.6 12.3 12.1 12.1 39-023-0005 B Clark 15.6 15.4 14.7 14.2 14.8 14.4 14.8 13.5 13.2 12.7 39-113-0032 C Montgomery 16.0 15.5 15.9 15.2 15.5 14.1 13.7 13.2 incomplete data (quarter with <75% capture) violating DV From Table 2, all three sites have design values (DV) that m eet the PM2.5 annual standard since 2006-2008 per iod. However, site A has not proven clean data in 2010 and therefore it makes the ent ire nonattainment area non-eligib le for redesignation. As mentioned before, the lack of clean data in 2010 is due to the low percentage of data capture in one or more quarters of 2010. Multiple imputations and boot strapping methods will help to generate the necessary missing data to determine 2010 completene ss and recalculate the 2008-2010 DV. 2. Correlation, Quarterly Data Capture, and Data Site Pairing Linear regression analyzes the relationshi p between two variables, X and Y. For each subject, there is a known X and Y and we want to find the best straight line through the data. The goal of linear regression is to find the line t hat best predicts Y from X. Linear4 regression does this by finding the line that minimizes the sum of the squares of the vertical distances of the points from the li ne. To determine which site combination (A and B or A and C) has the best data (best fit) from which to impute missing data for site A we determine the correlation between si tes A and B and the correlation between A and C. The correlation value (R 2 ) is useful because it descri bes the degree of relationship between two variables 2 (variables or site concentra tions in sites A, B and C). R 2 is only a descriptive statistics. Roughly speaki ng, we associate a high value of R 2 with a good fit of the regression line and associate a low value of R 2 with a poor fit. The mean of the quarterly dat a captured (the mean of the percentage captured) will allow verifying the central tendency of each site , which will help to determine what site (B or C) has a more data completeness to impute for site A. Finally, although not as statistica lly significant as the correla tion, or as the mean of the percentage captured, pairing the site data see ks to reduce variability in order to make more precise comparisons with fewer obs ervations. Pairing the data will help to determine which site, B or C, hav e more data when paired with A. Below are the results for sites A vs. B and for sites A vs. C

2 An R 2 value of 0.0 means that knowing X does not help to predict Y, there is no linear relationship between X and Y. When R2 equals 1.0, all points lie exac tly on a straight line with no scatter; knowing X predicts Y perfectly.5Linear Regression and Correlation for Site A vs. Site BRegressionStatisticsMultipleR0.961043954RSquare0.923605481AdjustedRSquare0.92351105StandardError1.780706901Observations811CoefficientsStandardErrortStatP‐valueLower95%Upper95%Intercept0.5215176320.1369766113.807348050.000151080.2526461590.790389106XVariable10.8731909880.0088292398.8977501700.8558600870.890521889ANOVAdfSSMSFSignificanceFRegression131013.9946331013.994639780.7649890Residual8092565.2719073.170917067Total81033579.266546Linear Regression and Correlation for Site A vs. Site CRegressionStatisticsMultipleR0.940886234RSquare0.885266906AdjustedRSquare0.885120562StandardError2.193683537Observations786CoefficientsStandardErrortStatP‐valueLower95%Upper95%Intercept0.817159950.1711894314.7734252312.16082E‐060.4811161.153203844XVariable10.812956870.01045241777.7769292600.7924390.833474906ANOVAdfSSMSFSignificanceFRegression129110.4914329110.491436049.2507250Residual7843772.8020074.812247458Total78532883.293447 Table 3 - Quarterly Data Capture Monitoring Sites A B CQuarterlyDataCapture2003‐2010 2003 Q1 ‐ 100% 87% 2003 Q2 ‐ 93% 96% 2003 Q3 ‐ 100% 100% 2003 Q4 73% 100% 89% 2004 Q1 71% 100% 100% 2004 Q2 93% 100% 90% 2004 Q3 100% 97% 97% 2004 Q4 90% 100% 90% 2005 Q1 97% 100% 100% 2005 Q2 97% 100% 100% 2005 Q3 100% 100% 100% 2005 Q4 100% 90% 97% 2006 Q1 100% 100% 100% 2006 Q2 97% 100% 97% 2006 Q3 94% 100% 100% 2006 Q4 100% 100% 97% 2007 Q1 97% 100% 100% 2007 Q2 93% 100% 100% 2007 Q3 100% 100% 100% 2007 Q4 93% 100% 97% 2008 Q1 97% 97% 93% 2008 Q2 100% 87% 98% 2008 Q3 94% 100% 98% 2008 Q4 100% 100% 95% 2009 Q1 100% 100% 94% 2009 Q2 100% 97% 100% 2009 Q3 100% 100% 90% 2009 Q4 97% 100% 100% 2010 Q1 97% 100% 97% 2010 Q2 100% 100% 100% 2010 Q3 45% 100% 97% 2010 Q4 100% 100% 100%

MEAN 94% 99% 97% Table 4 - Paired Data Site

29 ‐ Quarter look (2003 Q4 ‐ 2010 Q4) Site Site pairs Q1 pairs Q2 pairs Q3 pairs Q4 Total

A B 197 199 191 224 811 A C 186 194 188 218 7868 The correlation between A and B is 0.9236 and the correlation between A and C is 0.8853. This shows that the relationshi p between A and B is stronger than the relationship between A and C. From the mean of the quarterly data captured (Table 3), we can observe that Site B has more dat a completeness (99%) than Site C (97%); therefore Site B has a more co mplete data from where to im pute for site A. In addition, from the data site pairing (T able 4) it can be observed that Site A and B have more paired data (in each quarter and in total) to establish a be tter relationship than Site A and Site C. Finally, based on the above results, it was determined that Site B has the best data, statistically significant (greater correlation, larger data completeness, and larger paired data) from which to impute mi ssing data for Site A. Therefor e, we will use multiple imputations and bootstrapping me thods to generate the necessary data from Site B to impute on Site A missing values. 3. Bootstrapping and Imputation The bootstrapping method randoml y applies real residuals from the linear regression to the imputed current-period Site A values. A 1000 bootstrap runs adds a random residual to the “best guess” missing values yielding the same conditional variance as the original variable. A summary of the bootstrapping stat istics is presented in Table 5, where the bootstrapping residual is -929.0569514e -6

. Table 5 - Bootstrapping Summary Statistics Average -929.0569514e -6 SD 0.0356 Max 0.103 Min -0.137 Finally to impute the missing data using the bootstrapping residual we use the following equation, based on the linear regre ssion from Site A vs. Site B: Site A concentration = Intercept + x Variable * Site B concentration + bootstrapping residual

Where: Intercept = 0.521517632 (fro m linear regression) x Variable = 0.873190988 (f rom linear regression) Bootstrapping residual = -929.0569514e -6 Site B concentration = values in Site B After applying the above equati on to all missing data in Site A, we recalculated the design values based on the th ree-year average of the annual mean concentrations for9 all existing years in Site A (Site 39-057-0005 ). Table 6 shows Site 39-057-0005 before and after the imputation of mi ssing data. Also the “new” site (with imputed values) shows a “new” passing DV for 2008-2010. Table 6 – Comparison Between Original and Imputed Values for Monitor 39-057- 0005 from 2004 to 2010 Annual Design Value Site Year 2004

‐ 2006 2005

‐ 2007 2006

‐ 2008 2007

‐ 2009 2008

‐ 2010 2004 2005 2006 2007 2008 2009 2010 OLD 39-057-0005 12.1 15.5 11.9 13.3 11.6 11.5 13.2 13.2 13.6 12.3 12.1 12.1 NEW 39-057-0005 11.7 15.2 11.9 13.5 11.6 11.5 12.2 12.9 13.5 12.3 12.2 11.8 incomplete data (quarter with <75% capture) As we said before, the bootstrapping method randomly applies real residuals from the linear regression to the imput ed current-period Site A va lues. A 1,000 bootstrap runs provided a 95% confidence interval for the imputed current-period des ign value. Table 7 shows that, since the R 2 value between Site A and Site B was strong, predicting its relationship almost perfectly (R 2 = 0.9236), there is small variation between DV interval (as well as residual intervals) and it was needed to provide at least 3 significant decimals to show the different intervals. Table 7 shows that the DV = 11.763 has the most occurrences, confirming that the “new” DV 2008-2010 of 11.8, in Table 6, is the best guess of imputed data. Table 7 - Bootstrapping Residu als and DV Calculations Residual Design Value Frequency -0.14 11.754 3 -0.115 11.755 3

-0.09 11.757 20 -0.065 11.758 87

-0.04 11.760 179 -0.015 11.761 252

0.01 11.763 262 0.035 11.764 143

0.06 11.766 42 0.085 11.767 9

Ohio EPA believes that the above analysi s has generated the mo st statistically significant results yielding to the “best” missing data statisti cally possible. This analysis should also satisfy US EPA requirements in terms of total percentage data capture and design values under the PM 2.5 annual standard (15.0μg/m 3 ).10 References: Brownstone, David and Robert Valleta. 20 00. Draft for JEP Econometrics Symposium. “The bootstrap and multiple imputations”. Harrel, Frank E. Jr. 2001. Spri nger Series in Statistics. “R egression modeling strategies: with applications to linear models, logist ic regression, and survival analysis”. Mooney, Christopher Z., Robert D. Duval, Robert Duval. 1993 . Sage Publications Inc. “Bootstrapping: a nonparametri c approach to statistical in ference” Issues 94-95.

# A TTACHMENT 

# FPublic Notice Ohio Environmental Protection Agency Redesignation and Maintenance Plan for the Dayton-Springfield Annual PM 2.5 Nonattainment Area Clark, Green, and Montgomery Counties Notice is hereby given that the Director of the Ohio Environment al Protection Agency (Ohio EPA) is requesting that the United States Environment al Protection Agency (U.S. EPA) revise the current air quality designation for the Dayton-Springfield area, including Clark, Green, and Montgomery counties to a ttainment with respect to the 1997 annual PM 2.5 national ambient air quality standard (N AAQS). Air quality monitoring data collected between 2008 and 2010 in the region demonstrate atta inment of the NAAQS and there is evidence that the improved air quality is due to permanent, enforceable emission reductions. In addition, existing requi rements are sufficient to maintain the 1997 annual PM 2.5 standard in this area at least ten years into the future. Computer models show that existing stat e and federal emission reduction requirements are sufficient to attain and maintain the NAAQS in the Dayton-Springfield area. Therefore, Ohio EPA proposes to utilize ex isting emission inventory information and projections of future emissions as the dem onstration of the abilit y to maintain the NAAQS in the Dayton-Springfield area in the future. The Dayton-Springfield area is currently designated as nonattainment for the 1997 annual PM 2.5 standard. As part of an acceptable maintenance plan, Ohio EPA is required to develop a contingency plan to provi de for additional emission reductions if a violation of the NAAQS is monitored afte r the area has been redes ignated. The plan which Ohio EPA is proposing to USEPA as part of this redesignation contains reductions which will help alleviate any am bient problem until a revised SIP can be developed. The State of Ohio proposes to: 1. Request the U.S. EPA redes ignate the Dayton-Springfield area to attainment with respect to the 1997 annual PM 2.5 NAAQS and revise the maintenance plan. This request will document that exis ting enforceable control m easures are responsible for the observed improvement in air quality. 2. Designate existing controls as sufficient to maintain the NAAQS into the future. 3. Commit to the proposed contingency plan. These actions must be noticed to allo w public comment and to satisfy USEPA requirements for public involvement in SIP-re lated activities. This notice addresses Ohio EPA’s reliance on the emission projections as evidence of attainment and maintenanceand the commitment to instit ute contingency measures if ambient exceedances or violations trigger the contingency plan r equirements. Written comments will be received on or before INSERT DATE at the following address: E-mail: Carolina.Prado@epa.state.oh.us Mailing address: Carolina Prado Ohio Environmental Protection Agency, DAPC Lazarus Government Center P.O. Box 1049 Columbus, Ohio 43216-1049 Phone: (614) 728-1743 Pursuant to Section 119.03 of the Ohio Revised Code, a public hearing on this redesignation request will be conducted as follo ws: May 3, 2011 at 1:30 PM, at Ohio EPA’s Southwest District Office located at 401 E. Fifth Street in Dayton, Ohio. All interested persons are entitled to att end or be represented at the hearing and give written or oral comments on these changes. All oral comments presented at the hearing, and all written statements submitted at the hearing or to the above address by the close of business on May 3, 2011 will be considered by Ohio EPA prior to final action on this redesignation. Written statements submitted after May 3, 2011 may be considered as time and circumstances permit, but will not be part of the official record of the hearing. This redesignation and maintenance request is available on Ohio EPA, DAPC’s web page for electronic downloading at: http://www.epa.ohio.gov/dapc/SIP/annual.aspx

. Questions regarding accessing the web site should be directed to Arunee Niamlarb at 614-728-1342; other questions or comments about this document should be directed to either Carolina Pr ado, (614) 644-2310, Carolina.Prado@epa.state.oh.us or Jennifer Hunter at (614) 644-3696, Jennifer.Hunter@epa.state.oh.us or mailed to Carolina Prado or Jennifer Hunter at the above address.

## REGIONAL AIR POLLUTION CONTROL AGENCY Serving Clark, Darke, Greene, Miami, Montgomery & Preble Counties 117 South Main Street, Dayton, Ohio 45422-1280 (937) 225-4435

- Fax: (937) 225-3486 www.rapca.org

May 3, 2011 Ms. Carolina Prado Ohio EPA Lazarus Government Center P.O. Box 1049 Columbus, Ohio 43216-1049

Dear Ms. Prado: The Regional Air Pollution Control Agency (RAPCA) appreciates the opportunity to submit comments on Ohio EPA's preliminary Redesignation Request and Maintenance Plan for the Dayton-Springfield Annual PM-2.5 Nonattainment Area. RAPCA personnel appreciate very much the time and work effort Ohio EPA personnel have put into the preparation of these recommendations. Following U.S. EPA guidance document Procedures for Processing Requests to Redesignate Areas to Attainment, Ohio EPA has assessed the following criteria to determine if redesignation of the DaytonSpringfield Area to attainment for the annual PM-2.5 National Ambient Air Quality Standard (NAAQS) is warranted: 1. Attainment of the standard 2. Approved State Implementation Plan 3. Determination that air quality improvement is due to permanent and enforceable reductions in emissions 4. A fully approved maintenance plan 5. Determination that Section 110 and Part D requirements have been met. Applying these criteria to the Dayton-Springfield area, Ohio EPA is proposing that the counties of Montgomery, Greene, and Clark be redesignated to attainment for the annual PM-2.5 NAAQS. While RAPCA fully supports Ohio EPA's decision to propose redesignation of the Dayton-Springfield to attainment for the annual PM-2.5 NAAQS, a detailed review of emissions data and monitoring data indicate that the evidence supporting the redesignation request is even stronger than has been stated by Ohio EPA. In the main document, tables 17 and 21 list current and projected emission inventories for NOx and S02 in Clark, Greene, and Montgomery Counties. These data in tons per year, along with the STARS2 Title 5 S02 emission inventory for RAPCAjurisdiction are summarized in the following table.2005 2008 2015 2022 Total NOx 39,234 32,624 20,905 14,390 Total S02 11,232 9,849 9,829 9,556 Title 5 S02 9,074 6,576 

# --- --- Approximately 75% of the total NOx reduction is attributable to onroad mobile source controls. However, the S02 inventory is dominated by large stationary sources, and since projections evidently are based on modeling conducted by staff at the Lake Michigan Air Directors Consortium (LADCO), very little reductions in S02 emissions are projected. However, Title 5 data show that large decreases in S02 are occurring in RAPCAjurisdiction. The LADCO modeling technical support document is attached as Appendix D to the redesignation request. It is dated September 12, 2008 and has projected inventories and modeled ozone and PM-2.5 concentrations for 2009, 2012, and 2018. The modeled concentrations can be compared to the actual monitored values for 2009. Annual PM-2.5 at Dayton Library 2005 2009 2012 2018 LADCO model (w/CAIR) 15.5 13.2 12.9 12.4 RAPCA monitor 17.4 12.4 

## --- --- Daily PM-2.5 at Dayton Library 2005 2009 2012 2018 LADCO model (w/CAIR) 37.8 30 30 30 RAPCA monitor 45.0 26.8 

# --- ---

While all of the LADCO modeling scenarios (there are three other scenarios less stringent than the (w/CAIR) scenario) show PM-2.5 design values below the NAAQS in 2009 and into the future for the Dayton Area, the modeling doesn't appear to capture all of the reductions in PM-2.5 concentrations that are occurring in the Midwest. This issue may be much more important in larger metropolitan areas such as Cleveland and Chicago. We repeat our appreciation of the time and effort that Ohio EPA personnel put into the preparation of these preliminary recommendations and we look forward to the opportunity to discuss our comments in a future meeting. Please address any questions on these comments to either the writer or Andy Roth Sincerely,

# ~dPJ John A. Paul, RAPCA AdministratorTestimony of John A. Paul, Administrator Regional Air Pollution Control Agency Dayton, Ohio

Regarding Ohio EPA's Proposed Redesignation of Clark, Greene, and Montgomery Counties To Attainment for the Annual National Ambient Air Quality Standard for PM-2.5

May 3, 2011 Pa e 

### 1Pa e 2

Good afternoon, my name is John A. Paul and I am the Administrator of the Regional Air Pollution Control Agency (RAPCA) of Dayton, Ohio. RAPCA is the local agency responsible for air pollution control activities in the Ohio counties of Clark, Darke, Greene, Miami, Montgomery, and Preble. This testimony is offered in support of Ohio EPA's proposal for redesignation of Clark, Greene, and Montgomery Counties as attainment of the annual National Ambient Air Quality Standard (NAAQS) for PM-2.5. We commend Ohio EPA for the completeness ofthe redesignation package, and offer both this testimony and written comments as supplemental support. The Ohio EPA proposal discusses the five criteria for redesignation from USEPA's 

### Procedures for Processing Requests to Redesignate Areas to Attainment. RAPCA staff reviewed the complete OHIO EPA document and offer the following in support. RAPCA operates four PM-2.5 air quality monitoring stations. Three-year average PM-2.5 concentrations, along with the applicable standards are shown in the following two figures. "Montgomery" are data from the urban core of Dayton, and represent the highest concentrations ofPM-2.5 in RAPCAjurisdiction. "Greene" is located in the Village of Yellow Springs, Greene County, which is downwind of Dayton. "Clark" is located on the roof of a fire station in the City of Springfield, Clark County, which is an urban location. Our rural upwind site denoted "Preble" represents PM-2.5 levels transported into RAPCA jurisdiction.

""{/" '''Clark 

### '""*- Preble -STANDARD

04·06 05·07 06·08 07·09 08·10Pa e 3

06-08 07-09 08-10 ontgomery

As can be seen from these graphs, the monitored data are clearly below the standard and are trending downward. The monitored data clearly show attainment. We believe these monitored data reflect decreases in both direct emissions ofPM-2.5 and precursors (802 and N02) from both stationary and mobile sources. These decreases in emissions are within RAPCA's six counties, as well as state-wide and nation-wide as is shown in the following figures. Emissions Inventory

- extracted from 2002, 2005, 2008 National Emission Inventory

2002 RAPCA 

### stationary**~'Ources**

IIIPM2.5 111802 cNOx

2005

### Pa e 4

O+-

...... 2002 

## u.s. stationary sourees

2008 IIiPM2.5 -802 f'NOx2002 

### RAPCAmobile sources

2005 200S mPM2.5 IIIS02 i3NOx 

### Pa e 5



### Ohio mobile sow'ces 00 -,---------------------------- 450000+---------------- 400000 350000**--~--­** 300000 -/----- 250000 -t---- 200000 -1--- 150000 100000-1---- 50000 

# 0+-.

....... - mpM2.5 "'S02 LNOx

2002 2005 2008Pa 

### e 6

These emissions reductions are due to adopted rules and consent decrees which are enforceable and projected to produce further reductions into the future. Additional major rules are on schedule for adoption. Examples of such rules and consent decrees are as follows. Rules

• Tier II Vehicle and Gasoline sulfur program

• Heavy Duty Diesel Engines rule (includes low sulfur diesel for highway vehicles)

• Clean Air Non-road diesel rule (includes 99% sulfur reduction in non-road diesel fuel: 15ppm in 2010, down from 3,000ppm)

• NOx SIP Call (OAC 3745-14)

• CAIR (OAC 3745-109)

• Federal Transport Rule (anticipated to be finalized this summer)

• Federal EGU MACT Rule (anticipated to be finalized this fall)

• ICI Boiler MACT (recently adopted)

• NOx RACT rule (OAC 3745-110) Enforcement/Consent Decrees

• Apri12011-TVA

• January 2011

- Northern Indiana Public Service Company

• February 2011

- CEMEX

• July 2010

- Hoosier Energy Rural Electric Cooperative

• May 2010

- American Municipal Power

• Dec 2009 Duke Energy, Gallagher Plant

• Sept 2009

- East Kentucky PowerPit e 7

• August 2009

- Ohio Edison (First Energy)

• October 2007

- American Electric Power

• July 2007

- East Kentucky Power

• June 2003

- Southem Indiana Gas & Electric Descriptions for each of these enforcement actions, including a copy of the consent decrees, are available at http://cfpub.epagov/compliance/cases/.

We have full confidence that the emissions of direct PM-2.5 and its precursors will continue to decrease in future years. In conclusion, RAPCA staff believe the criteria for redesignation to attainment for PM-2.5 have been clearly met.

• The monitored air quality data show attainment; we believe these data are accurate.

• Reductions in emissions of both direct PM-2.5 and precursors have been significant and will continue into the future.

• Adoption of the federal Transport Rule, EGU MACT, and ICI Boiler MACT, combined with additional mobile source measures (including diesel fuel improvements) should assure continued emissions reductions and air quality improvement into the future. Thus, we fully support this proposal to redesignate Greene, Clark, and Montgomery Counties as attainment for the annual PM-2.5 National Ambient Air Quality Standard. Thank you for this opportunity to give this testimony. We appreciate very much the work that Ohio EPA has accomplished on this proposal. I am happy to answer any questions you might have.1

1 2 OHIO EPA PUBLIC HEARING 3

------------------------------------------------ 4 IN THE MATTER OF: 5 REDESIGNATION FOR PM-2.5, DAYTON AREA 6

------------------------------------------------- 7 EPA Hearing held Tuesday, May 3, 2011 at 1:30 8 p.m., at the Ohio EPA, 401 E. Fifth Street, 2nd 9 Floor, Dayton, Ohio before Ms. Erica Wiggins, Ohio 10 EPA Representative. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 

## * * * * * *

:r,vr;;1;'J 

## MAY 1"/ ?Ol1

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### 2 Wiggins. MS. WIGGINS: My name is Erika I am the Ohio EPA's public involvement 2

3 coordinator for the southwest district and I'll be 4 presiding over today's hearing. Thank you for 5 taking the time to attend this hearing in front of 

### 6 the EPA. The purpose of the hearing today is to 7 obtain comments from any interested person 8 regarding Ohio EPA's proposed action. 9 The state of Ohio plans to ask 10 U.S. EPA to officially recognize that air quality 11 in the Dayton area meets the 1997 federal fine 12 particulate standard. Air quality data from the 13 years 2008-2010 show that the Dayton area is 14 meeting the 1997 national fine particulate matter 15 standard. When asking for redesignation, states 16 are required to demonstrate that the metropolitan 17 area will be able to maintain compliance with the 18 fine particulate standard for 10 years. Current 19 national, state and local air pollution controls to 20 limit particulate matter-causing emissions will 21 enable the area to maintain the air quality. 22 These include lower emission from 23 coal burning power plants, additional controls on 24 diesel-powered vehicles and enforcement efforts. 25 The proposed request affects Clark, Greene, and

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1 Montgomery counties. 2 Comments on the redesignation 3 proposal can be submitted until the close of 4 business on today, May 3rd, bye-mail or mail to 5 Carolina Prado or Jennifer Hunter, Division of Air 6 Pollution Control, Ohio EPA, P.O. Box 1049, 

### 7 Columbus, Ohio 43216-1049. You can e-mail comments 8 to carolina.prado@epa.ohio.gov. 9 The proposal is available on line 10 or by calling Ohio EPA's Division of Air Pollution 11 Control at (614) 644-2270. The state of Ohio is 12 proposing to ask U.S. EPA to officially recognize 13 the four-county Dayton area as meeting the federal 14 air quality standard for fine particulate matter. 15 All interested persons are 16 entitled to attend or be represented and to present 17 oral or written comments concerning the proposed 18 action. All written and oral comments received as 19 part of the official record will be considered by 20 the Director of Ohio EPA before the final decision 21 is made. To be included in the official record, 22 written comments must be received by Ohio EPA by 23 close of business May 3, 2011. You may file 24 comments with me today or e-mail to the 25 afore-mentioned address. All written comments

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1 submitted for the record receive the same 2 consideration as oral testimony given today. 3 Written statements submitted after 4 the comment period closes may be considered as time 5 and circumstances permit, but will not be part of 6 the official record of the hearing. If you wish to 7 present oral testimony at this hearing today and 8 have not already signed the registration sheet, do 9 so at this time. The sheet is available at the end 10 of the table. People will be called in the order 11 in which they registered. 12 There is no cross examination of 13 speakers or representatives of Ohio EPA in public 14 hearings of this type. Ohio EPA hearings such as 15 this afford citizens the opportunity to provide 16 comments on the official record. Therefore, we'll 17 not be able to answer questions during the hearing. 18 However, members of Ohio EPA may ask clarifying 19 questions of the person testifying to ensure that 20 the record is as complete and accurate as possible. 21 If you'll pass me that sheet I'll 22 now read the names of those who registered at the 23 hearing and give each person an opportunity to 

### 24 testify. The first person testifying will be John 25 Paul. You can stand if you like or otherwise you

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### 1 can say your piece. 2 MR. JOHN PAUL: Good afternoon, my 3 name is John A. Paul, I'm the administrator of the 4 Regional Air Pollution Control Agency, RAPCA, of 5 

### Dayton, Ohio. RAPCA is the local agency 6 responsible for air pollution control activities in 7 the Ohio counties of Clark, Darke, Greene, Miami, 8 

### Montgomery and Preble. This testimony is offered 9 in support of Ohio EPA's proposal for redesignation 10 of Clark, Greene and Montgomery County as 11 attainment of the, for the annual National Ambient 12 Air Quality Standard for PM-2.5. We commend Ohio 13 EPA for the completeness of the redesignation 14 package and offer both this testimony and written 15 comments as supplemental information. 16 The Ohio EPA proposal discusses 17 the five criteria for redesignation from U.S. EPA's 18 Procedures For Processing Requests to Redesignate 19 Areas to Attainment. RAPCA staff reviewed the 20 complete Ohio EPA document and offer the following 21 in support. 22 RAPCA operates four PM-2.5 air 23 quality monitoring stations. Three-year average 24 PM-2.5 concentrations along with the applicable 25 standards are shown in the following two figures.

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1 Montgomery are data from the urban core of Dayton 2 and represent the highest concentrations of PM-2.5 3 in RAPCA's jurisdiction. Greene is located in the 4 Village of Yellow Springs, Greene County, which is 5 downwind of Dayton. Clark is located on the roof 6 of a fire station in the city of Springfield, Clark 7 County, which is an urban location. Our rural 8 upwind site denoted Preble represents PM-2.5 levels 9 transported into RAPCA jurisdiction. 10 I'll just comment that the chart 11 is there and it shows the various levels and shows 12 those levels, the three-year averages as being 13 below the standard, the last 33-year averages for 14 Montgomery County and all of the three-year 15 averages from Greene, Clark, and Preble Counties. 16 And then the next graph shows the 24-hour PM-2.5 17 and once, again, shows the levels at each of those 18 sites. 19 As can be seen from these graphs, 20 the monitored data are clearly below the standard 21 and are trending downward. The monitored data 22 clearly show attainment. We believe these 23 monitored data reflect decreases in both direct 24 emissions of PM-2.5 and precursors S02 and N02 from 25 both point and mobile sources. These decreases in

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1 emissions are within RAPCA's six counties as we11 2 as state wide and nationwide as is shown in the 3 fo11owing figures. 4 Then we have five different charts 5 that show, in the first one the RAPCA stationary 6 sources and emissions of PM-2.5, S02 and NOx in bar 7 graphs that c1ear1y show again decreasing emissions 8 from 2002 do 2005 and 2008 and then we have a bar 9 chart that shows Ohio stationary sources. Once, 10 again, it's decreasing 2002 to 2005 to 2008 for 11 PM-2.5 and S02 and NOx. We have a graph of 

## u.s. 12 stationary sources across the country, again, shows 13 this downward trend in PM-2.5, S02, and NOx 14 emissions and have two graphs that have two mobi1e 15 sources, RAPCA mobi1e sources and then Ohio, State 16 of Ohio mobi1e source inventory. 17 Again, with mobi1e sources we pay 18 attention to the NOx emissions, and the fina1 graph 19 is showing 

## u.s. mobi1e sources and once again the 20 trend downward especia11y in 2008. These emission 21 reductions are due to adopted ru1es and consent 22 decrees which are enforceab1e and projected to 23 produce further reductions into the future. 24 Additiona1 major ru1es are on 25 schedu1e for adoption. Examp1es of such ru1es and

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1 consent decrees are as follows, and then we list 2 rules which have both been adopted and/or are to be 3 adopted or they have been adopted and being phased 4 in, and we list rules that tier II vehicle and 5 gasoline sulfur program, the heavy duty diesel 6 engine rules that includes low sulfur diesel for 

### 7 highway vehicles. The clean air non-road diesel 8 rule includes a 99 percent sulfur reduction in 9 non-road diesel fuel. 15 parts per million in 2010 10 down from 3,000 parts per million prior to 2010. 11 The NOx SIP call for E.G.U's, the Clean Air 12 Interstate Rule, the federal transport rule which 13 was adopted and then has been adjusted by, is being 14 replaced with the federal transport rule which is 15 anticipated to be finalized this summer; and the 16 federal E.G.U MACT. This is a toxic rule requiring 17 full controls on electric generator units that is 18 anticipated to be finalized this fall. 19 It was recently proposed and 20 published in the Federal Register today. The 21 Industrial Commercial and Institutional Boiler, 22 MACT rule, again, a toxic rule that was recently 23 adopted that will result in further emission 24 reductions from industrial boilers in the area, and 25 then the NOx RACT rule.

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2 enforcement/consent decrees. These are primarily 3 to new source review violations but they result in 4 best available control technology installed on the 5 sources that are listed here so I have the 6 enforcement consent decrees for TVA, Northern 7 Indiana Public Service, for CEMEX, for Hoosier 8 Energy Rural Electric Cooperative, American 9 Municipal Power, Duke Energy, East Kentucky Power; 10 and the next page, Ohio Edison, American Electric 11 Power, East Kentucky Power and again, Southern 12 Indiana Gas and Electric. 13 These are all consent decrees 14 which are resulting in further controls on electric 15 generating units and descriptions for each of these 16 enforcement actions including a copy of the consent 17 decrees are available at the web site that is 18 listed there. 19 We have full confidence that the 20 emissions of direct PM-2.5 and its precursors will 21 continue to decrease in future years; and in 22 conclusion, RAPCA staff believe that criteria for 23 redesignation to attainment for PM-2.5 have been 24 clearly met. The monitored air quality data show 25 attainment. We believe these data are accurate.

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1 Reductions in emissions of both direct PM-2.5 and 2 precursors have been significant and will continue 3 into the future and adoption of the federal 4 Transport Rule, the E.G.U MACT, the ICI Boiler MACT 5 combined with additional mobile source measures 6 including diesel fuel and improvements should 7 assure continued emissions reductions and air 8 quality improvement into the future. 9 Thus we fUlly support this 10 proposal to redesignate Greene, Clark and 11 Montgomery Counties as attainment for the annual 12 PM-2.5 National Ambient Air Quality Standard. 13 Thank you for this opportunity to give this 14 testimony. We appreciate very much the work that 15 Ohio EPA has accomplished on this proposal. I am 16 happy to answer any questions you might have. 17 MS. WIGGINS: Thank you very much. 18 The next person on my list is Brian Huxtable. 19 BRIAN HUXTABLE: I'm just 20 attending. 21 MS. WIGGINS: Matt Lindsay. 22 MATT LINDSAY: I'm just attending. 23 MS. WIGGINS: And Felicia Graham. 24 FELICIA GRAHAM: I'm attending 25 also.

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1 MS. WIGGINS: Anyone else would 2 like to speak. 3 MICHELE SIMMONS: We are 4 representing the City of Dayton and I would like to 5 make a statement that we are in support of the Ohio 6 EPA designation of Dayton and Springfield area to 7 attainment for the PM-2.5 and revising the 8 maintenance plan for Montgomery County. 9 We think that the existing 10 controls will be sufficient to maintain the NOx and 11 we are willing to commit to the proposed 12 contingency plan that's represented in your public 13 hearing notice here. 14 MS. WIGGINS: Could you state your 15 name and spell it for the record. 16 MICHELE SIMMONS: M-I-C-H-E-L-E, 17 S-I-M-M-O-N-S, and that's with the City of Dayton. 18 MS. WIGGINS: Thank you very much. 19 Anyone else wish to testify? Seeing no one else, I 20 want to remind you that written comments can be 21 submitted through 5 p.m. today and you have an 22 e-mail address that is a best bet to get it there. 23 Thank you everyone for attending. The time now is 24 1:45 p.m. We will wait 15 minutes before 25 adjourning.

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(WHEREUPON, a recess was taken.) MS. WIGGINS: The time is now 2 3 o'clock. This hearing is adjourned. 4 5 6 7 8 9 

### 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 

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1 2 3 C E R T I F I CAT E



### 4 I, Paula A. Blosser, a Registered 5 Professional Reporter and Notary Public do hereby 6 certify that the foregoing is a full, true and 7 correct transcript of my notes taken in the 8 above-styled case and thereafter transcribed by me. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

# ~\.O- Paula A. Blosser, RPR

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- (513) 651-3370Response to Comments PM 2.5 Redesignation Request for the 1997 PM 2.5 Annual Standard for the Dayton-Springfield Area Agency Contact for this Package Division Contact: (Carolina Prado, Division of Air Pollution Control, 614-644-2310, Carolina.Prado@epa.state.oh.us) Ohio EPA held a public hearing in Dayton, OH on May 3, 2011, regarding the Redesignation Request and Maintenance Plan for the Dayton-Springfield PM 2.5 Nonattainment Area. This document summarizes the comments and questions received at the public hearing and during the associated comment period, which ended on May 3, 2011. Ohio EPA reviewed and considered all comments received during the public comment period. By law, Ohio EPA has authority to consider s pecific issues related to protection of the environment and public health. In an effort to help you review this document, the questions are grouped by topic and organized in a consistent format. The name of the co mmenter follows the comment in parentheses. Ohio EPA received a letter and oral testimony from the Regional Air Pollution Control Agency (RAPCA) in support of the redesignation request for the 1997 PM 2.5 Annual Standard for the Dayton-Springfield Area. Besides supporting Ohio EPA’s redesignation request, RAPCA presented its own emission and monitoring data analysis showing that the evidence supporting the redesignation is stronger than what has been determined by Ohio EPA . RAPCA’s support documents can be found in this submittal. During the public comment period, the Ohio Department of Transportation (ODOT) advised Ohio EPA of an e rror in the MOVES post-processor assumptions utilized to generate on-road emissions in the Dayton-Sp ringfield area. ODOT, together with the Miami Valley Regional Planning Commission, corrected the errors and re-analyzed the mobile emissions using MOVES. The new an alysis resulted in an increase in the total on-road mobile emissions; however, the effect on the overall area emissions is minimal and a 15% safety margin, for transportation conformity purposes, was still allocated. Therefore, the final document does contain revised on-road mobile emissions numbers as compar ed to the draft document.

End of comments