### 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.idem.IN.gov

January 25, 2011

Ms. Susan Hedman Regional Administrator U.S. Environmental Protection Agency Region 5 77 West Jackson Boulevard Chicago, IL 60604-3950 Re: Request for Redesignation Petition and Maintenance Plan for the Indiana Portion (Lawrenceburg Township, Dearborn County) of the Cincinnati-Hamilton, OHKY-IN Fine Particle Nonattainment Area

Dear Ms. Hedman:

The Indiana Department of Environmental Management (IDEM) submits a Redesignation Petition and Maintenance Plan for the Indiana portion (Lawrenceburg Township, Dearborn County) of the Cincinnati-Hamilton, OH-KY-IN Area, which was designated as nonattainment of the annual standard for fine particles on April 5,2005. IDEM conducted a public hearing concerning the Redesignation Petition and Maintenance Plan on January 5, 2011, and the public
comment period concluded on January 7, 2011.

This submittal documents the public review process, including a detailed summary of and
response to substantive comments.

The attached document consists of the following:
Redesignation Petition alUl Maintenance Plan
• A formal request that the Indiana Portion (Lawrenceburg Township, Dearborn County) of the Cincinnati-Hamilton, OH-KY-IN Area be redesignated to attainment and reclassified

as maintenance. It contains and meets the requirements set forth in Section 107 of the Clean Air Act and in U.S. EPA Redesignation Guidance.

• A maintenance year of 2021 is established and 2015 is analyzed as an interim year.

• The appendices of the document contain historical air quality trend data, projected emission inventory data and thorough documentation of the mobile emissions analysis.

• A summary of, and response to, all comments.

Recycled Paper 

### $ An Equal Opportunity Employer Please Recycle 

### 0Ms. Hedman, Page 2

Motor Vehicle Emissiolls Blldgets

• Contained in the Redesignation Petition is a new Motor Vehicle Emissions Budget for 2010 and 2021. The Ohio-Kentucky-Indiana Regional Council of Governments (OKI)'s travel demand forecasting model and the United States Environmental Protection Agency (U.S. EPA)'s software program referred to as Motor Vehicle Emission Simulator (MOVES) were used to determine emissions for the annual fine particle nonattainment

area.

• A conservative margin of safety was applied to the 20 I0 and 2021 projected emissions.

• The travel demand model was updated with the best available assumptions.

• Vehicle registration data gathered from the Indiana Bureau of Motor Vehicles were used to replace the MOVES default vehicle age distribution.

IDEM requests that the U.S. EPA proceed with review and approval of this submittal. If
you have any questions or need additional information, please contact Scott Deloney, Chief, Air Programs Branch, at (317) 233-5694.

Sincerely,

# pB.~r Keith Baugues Assistant Commissioner Office of Air Quality



### KB/sadlskr Enclosures:
Request for Redesignation Petition and Maintenance Plan for the Indiana Portion (Lawrenceburg Township, Dearborn County) of the Cincinnati-Hamilton, OH-KY-IN Fine Particle Nonattainment Area

Cc: John Mooney, U.S. EPA Region 5 (wI enclosures) John Summerhays, U.S. EPA Region 5 (wI enclosures) Cheryl Newton, U.S. EPA Region 5 (no enclosures) Pat Morris, U.S. EPA Region 5 (no enclosures) Scott Deloney, IDEM (no enclosures) Christine Pedersen, IDEM (no enclosures) Sarah Raymond, IDEM (wI enclosures)

# REQUEST FOR REDESIGNATION AND MAINTENANCE PLAN UNDER THE ANNUAL NATIONAL AMBIENT AIR QUALITY STANDARD FOR FINE PARTICLES



# For the Indiana Portion of the

Cincinnati – Hamilton, OH-KY-IN Nonattainment Area for Fine Particles

Lawrenceburg Township, Dearborn County, Indiana

Prepared By: The Indiana Department of Environmental Management

January 2011This page intentionally left blank

iiTABLE OF CONTENTS

1.0 INTRODUCTION ....................................................................................................................1 1.1 Background ................................................................................................................ ................1 1.2 Geographical Description .................................................................................................. ........2 1.3 Status of Air Quality ..................................................................................................... .............3

2.0 REQUIREMENTS FOR REDESIGNATION ......................................................................3 2.1 General ................................................................................................................... ....................3 2.2 Fine Particles Monitoring ................................................................................................. .........4 2.3 Emission Inventory ........................................................................................................ ............4 2.4 Modeling Demonstration .................................................................................................... .......4 2.5 Controls and Regulations .................................................................................................. .........5 2.6 Corrective Actions for Potential Future Viol ations of the Fine Particles Standard ...................5

3.0 FINE PARTICLES MONITORING .....................................................................................5 3.1 Fine Particles Monitoring Network ......................................................................................... ..5 3.2 Ambient Fine Particles Monitoring Data ...................................................................................7 3.3 Quality Assurance ......................................................................................................... ...........10 3.4 Continued Monitoring ...................................................................................................... ........10

4.0 EMISSION INVENTORY ....................................................................................................10 4.1 Emission Trends ........................................................................................................... ............11 4.2 Base Year Inventory ....................................................................................................... .........22 4.3 Emission Projections ...................................................................................................... ..........23 4.4 Demonstration of Maintenance .............................................................................................. ..29 4.5 Permanent and Enforceable Emission Reductions ..................................................................29 4.6 Provisions for Future Updates ............................................................................................. ....30

5.0 MOBILE SOURCE EMISSIONS BUDGET ......................................................................30 5.1 Onroad Emission Estimates ................................................................................................. ....30 5.2 Overview .................................................................................................................. ................30 5.3 Emission Estimates ........................................................................................................ ..........31

6.0 CONTROL MEASURES AND REGULATIONS ..............................................................33 6.1 Reasonably Available Control Technology (RACT) ...............................................................33 6.2 Implementation of Past SIP Revisions .....................................................................................3 3 6.3 Nitrogen Oxides (NO x ) Rule ....................................................................................................33 6.4 Measures Beyond Clean Ai r Act SIP Requirements ...............................................................34 6.5 Controls to Remain in Effect .............................................................................................. .....38 6.6 New Source Review Provisions .............................................................................................. .38

iii7.0 MODELING AND METEOROLOGY ................................................................................39 7.1 Summary of Modeling Results to Support Rulemakings ........................................................39 7.2 LADCO’s Round 5 Particulate Source Apportionment Results ..............................................43 7.3 Summary of Existing Modeling Results ..................................................................................46 7.4 Meteorological Analysis for Southeastern Indiana ..................................................................46 7.4.1 Surface Air Conditions Present during High Fine Particles Concentrations Days ...............46 7.4.2 Upper Air Conditions Present during High Fine Particles Concentration Days ...................47 7.4.3 Analyses of Atmospheric Conditi ons for Fine Particles Build-Up .......................................47 7.5 Summary of Air Quality Index Days in Southeastern Indiana ................................................48 7.6 Summary of Meteorological Analys is for Southeastern Indiana .............................................49

8.0 CORRECTIVE ACTIONS ...................................................................................................49 8.1 Commitment to Revise Plan ................................................................................................. ...49 8.2 Commitment for Con tingency Measures .................................................................................49 8.3 Contingency Measures ...................................................................................................... .......50

9.0 PUBLIC PARTICIPATION ................................................................................................51

10.0 CONCLUSIONS ..................................................................................................................51

FIGURES

Figure 3.1 Cincinnati Basic Nonattainment Area ............................................................................6

CHARTS

Chart 7.1 Regional/Emission Sect or PSAT Results at Murray Road in Hamilton County ...........44 Chart 7.2 Species Modeled Contributions to Murray Road PM 2.5 Monitor ..................................45 Chart 7.3 Species Modeled Contribu tions to Seymour & Vine St. PM 2.5 Monitor .......................45 Chart 7.4 Species Modeled C ontributions to 101 West 8 th Street PM 2.5 Monitor .........................45 Chart 7.5 Species Modeled Contributions to University College PM 2.5 Monitor..........................46 Chart 7.6 Distribution of PM 2.5 Concentration Days on the AQI Levels of Health Concern ........48

ivTABLES

Table 1.1 National Ambient Air Quality Standards for Fine Particles ............................................2 Table 3.1 Monitoring Data for the Cincinnati Area (Annual Average and 2007 – 2009 Design Values ................................................................................................................. .................7 Table 4.1 Comparison of 2008 Estimated and 2021 Projected Emission Estimates Lawrenceburg Township, Dearborn C ounty, Indiana (Tons Per Year) .........................................28 Table 4.2 Comparison of 2008 Estimated a nd 2021 Projected Emission Estimates Entire Cincinnati-Hamilton, OH-KY-IN N onattainment Area (Tons Per Year) ...........................29 Table 5.1 Emission Estimations for Onroad Mobile Sources for the Cincinnati-Hamilton OH-KY-IN PM 2.5 Nonattainment Area ..........................................................................................31 Table 5.2 Mobile Source Emission Budgets for the Ohio and Indiana Portions of the Cincinnati PM 2.5 Nonattainment Area ............................................................................................31 Table 6.1 Trends in EGU NO x Emissions Statewide in Indiana....................................................34 Table 7.1 Transport Rule Modeling Results from U.S. EPA - 2010 .............................................40 Table 7.2 LADCO’s Round 6 Modeling Results for the Cincinnati Area .....................................42 Table 7.3 Ranking and Percentage of Highest Number of Days at AQI Levels of Health Concern ....................................................................................................................... ...................49

GRAPHS

Graph 3.1 Design Values for the Cincinnati Area for Fine Particles, 2003 through 2009 .............9 Graph 3.2 Cincinnati Area Annual Fine Particles Trends, 2005 through 2009 ...............................9 Graph 4.1 Dearborn County, IN NO x Point Source Emission Trends, 2005 and 2008 .................11 Graph 4.2 Dearborn County, IN SO 2 Point Source Emission Trends, 2005 and 2008 ..................12 Graph 4.3 Dearborn County, IN PM 2.5 Point Source Emission Trends, 2005 and 2008 ...............12 Graph 4.4 Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area NO x Point Source Emission Trends, 2005 and 2008 .......................................................................................13 Graph 4.5 Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area SO 2 Point Source Emission Trends, 2005 and 2008 .......................................................................................13 Graph 4.6 Entire Cincinnati-Hamilton, OH-KY- IN Nonattainment Area Direct PM 2.5 Point Source Emission Trends, 2005 and 2008 .............................................................................14 Graph 4.7 NO x Emission Trends, All Sources in Dearborn County, IN, 2005 and 2008-With CAIR ................................................................................................................ ............16 Graph 4.8 SO 2 Emission Trends, All Sources in Dearborn County, IN, 2005 and 2008-With CAIR ................................................................................................................ ............16 Graph 4.9 Direct PM 2.5 Emission Trends, All Sources in Dearborn County, IN, 2005 and 2008-With CAIR ............................................................................................................ .........17 Graph 4.10 NO x Emission Trends, All Sources in Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area, 2005 and 2008-With CAIR ......................................................17

vGraph 4.11 SO 2 Emission Trends, All Sources in Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area, 2005 and 2008-With CAIR ......................................................18 Graph 4.12 Direct PM 2.5 Emission Trends, All Sources in Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area, 2005 and 2008-Without CAIR .................................................18 Graph 4.13 Lawrenceburg Townshi p, Dearborn County, Indiana NO x Emissions from EGUs, 1999 to 2009 ............................................................................................................ ...........20 Graph 4.14 Entire Cincinnati-Hamilt on OH-KY-IN Nonattainment Area NO x Emissions from EGUs, 1999 to 2009 ....................................................................................................... .......21 Graph 4.15 Lawrenceburg Townshi p, Dearborn County, Indiana SO 2 Emissions from EGUs, 1999 to 2009 ............................................................................................................ ...........21 Graph 4.16 Entire Cincinnati-Hamilt on, OH-KY-IN Nonattainment Area SO 2 Emissions from EGUs, 1999 to 2009 ....................................................................................................... .......22 Graph 4.17 Comparison of 2008, 2015 and 2021 Projected NO x Emissions, Lawrenceburg Township, Dearborn County, Indiana-With CAIR ................................................24 Graph 4.18 Comparison of 2008, 2015 and 2021 Projected SO 2 Emissions, Lawrenceburg Township, Dearborn County, Indiana-With CAIR ................................................25 Graph 4.19 Comparison of 2008, 2015 and 2021 Projected Direct PM 2.5 Emissions, Lawrenceburg Township, Dearborn County, Indiana-With CAIR ................................................25 Graph 4.20 Comparison of 2008, 2015 and 2021 Projected SO 2 , NO x and Direct PM 2.5 Emissions, Lawrenceburg Township, D earborn county, Indiana-With CAIR ....................26 Graph 4.21 Comparison of 2008, 2015 and 2021 Projected NO x Emissions for the Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area-With CAIR ..................................26 Graph 4.22 Comparison of 2008, 2015 and 2021 Projected SO 2 Emissions for the Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area-With CAIR ..................................27 Graph 4.23 Comparison of 2008, 2015 and 2021 Projected Direct PM 2.5 Emissions for the Entire Cincinnati-Hamilton, OH-KY -IN Nonattainment Area-Without CAIR .................27 Graph 4.24 Comparison of 2008, 2015 and 2021 Projected SO 2 , NO x and Direct PM 2.5 Emissions for the Entire Cincinnati -Hamilton, OH-KY-IN Nonattainment Area-(NO x and SO 2 With CAIR, PM 2.5 Without CAIR) ...............................................................28 Graph 7.1 PM 2.5 Design Value Trends for Cincinnati Area: 1999 - 2009 .....................................41 Graph 7.2 Modeling Results (without CAIR) for the Cincinnati Area PM 2.5 Monitors ................43

viAPPENDICES

A Air Quality System (AQS) and Indiana De partment of Environmental Management (IDEM) Monitor Data Values for the Cincinnati-Hamilton OH-KY-IN Nonattainment Area (2000-2009) B Nitrogen Oxides (NO x ), Sulfur Dioxides (SO 2 ) and Direct Fine Particulate Matter (PM 2.5 ) Point Source Emissions (2005 and 2008) for the Cincinnati-Hamilton, OH-KY-IN Nonattainment Area C Nitrogen Oxides (NO x ), Sulfur Dioxides (SO 2 ) and Direct Fine Particulate Matter (PM 2.5 ) (2005 and 2008) Emission Trends, All Sour ces, Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area D Nitrogen Oxides (NO x ) and Sulfur Dioxides (SO 2 ) Emissions from Electric Generating Units, Lawrenceburg Township, Dearborn County, Indiana and Entire CincinnatiHamilton, OH-KY-IN Nonattainment Area E 2008 Base Year Emissions Inventory and 2015 and 2021 Projected Emissions Inventory for Nitrogen Oxides (NO x ), Sulfur Dioxides (SO 2 ) and Direct Fine Particulate Matter (PM 2.5 ) in Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area F Mobile Source Input/Output Calculation Files G Indiana Department of Environmental Management (IDEM) Area Source Inventory Standard Operating Procedure H Lake Michigan Air Directors Consor tium Emission Estimates Technical Support Document I Lake Michigan Air Directors Consor tium (LADCO) Round 5 Modeling Technical Support Document (Round 5 Photochemical Modeling Based on “Base M” Emissions inventory, revised version of “Base K”) J Public Participation Process Documents

vii1 REQUEST FOR REDESIGNATION AND MAINTENANCE PLAN UNDER THE ANNUAL NATI ONAL AMBIENT AIR QUALITY STANDARD FOR FINE PARTICLES

CINCINNATI-HAMILTON OH-KY-IN AREA

1.0 INTRODUCTION

This document supports Indiana’s request that Lawrenceburg Township in Dearborn County, Indiana, which is part of the Cincinnati-Ham ilton OH-KY-IN fine partic les nonattainment area (herein referred to as the Cinc innati area), be redesignated from nonattainment to attainment of the 1997 annual standard for fine particles. Th ere are no monitors for fine particles in the Indiana portion of the Cincinnati area. However, because the Cincinnati area has recorded three years of quality assured ambien t air quality monitoring data for the years 2007 through 2009, demonstrating attainment with th e annual standard for fine partic les, the Indiana portion of the Cincinnati area is eligib le for redesignation.

Section 107 of the Clean Air Act (CAA) establishe s specific requirements to be met in order for an area to be considered fo r redesignation, including:

(a) A determination that the area has attained the annual standard for fine particles. (b) An approved State Implementation Plan (SIP) for the area under Section 110(k). (c) A determination that the improvement in air quality is due to permanent and enforceable reductions in emissions resul ting from implementation of the SIP and other federal requirements. (d) A fully approved maintenance plan under Section 175A. (e) A determination that all Section 110 and Part D requirements have been met.

A maintenance plan provides for the continued atta inment of the air quality standard by an area for a period of ten years after the United Stat es Environmental Protection Agency (U.S. EPA) has formally redesignated the area to attainment. The plan also pr ovides assurances that even if there is a subsequent exceedance of the air quality standard, measures in the maintenance plan will prevent any future occurrences through con tingency measures that would be triggered.

This document addresses each of these requireme nts, and provides additional information to support continued compliance with the a nnual standard for fine particles.

1.1 Background

The CAA requires states with areas designate d nonattainment of th e applicable National Ambient Air Quality Standard (NAAQS) for fine particles to develop SI Ps to expeditiously attain and maintain the standar d. In 1997, U.S. EPA set daily and annual air quality standards for fine particles (PM 2.5 ), as shown in Table 1.1. The sta ndards were legally challenged and upheld by the U.S. Supreme Court in February of 2001. In 1999, Indiana began monitoring for2 fine particle concentrations. The U.S. EPA desi gnated areas in Indiana un der the fine particle standards on December 17, 2004, as attainment, nonattainment, or unclass ifiable, with an effective date of April 5, 2005.

Table 1.1 National Ambient Air Quality Standards for Fine Particles

Annual 24-Hour

1997 Fine Particles

Standard (PM 2.5 ) 15 μg/m 3 Annual arithmetic mean, averaged over three years 65 μg/m 3 24-hour average, 98 th percentile, averaged over three years

2006 Fine Particles

Standard (PM 2.5 ) 15 μg/m 3 Annual arithmetic mean, averaged over three years 35 μg/m 3 24-hour average, 98 th percentile, averaged over three years
Note: The Cincinnati area meets the 1997 and 2006 24-hour NAAQS for fine particles. Since this area is solely designated nonattainment under the 1997 annual standard for fine particles, this document only addresses the annual standard.

On December 17, 2004, based on 2001 through 2003 monitoring data, U.S. EPA designated the Cincinnati-Hamilton OH-KY-IN area as nonattainment of the annual st andard for fine particles, and subject to CAA, Part D, Title 1, Secti on 172 of Subpart 1 requirements, including the development of a plan to reduce nitrogen oxides (NO x ), sulfur dioxide (SO 2 ), and direct PM 2.5 emissions and a demonstration that the area will meet the annual standard for fine particles by April 5, 2010. In order to satisfy these requirements, Indiana submitted an attainment demonstration to U.S. EPA on April 3, 2008, demons trating that with the combination of clean air measures and the implementation of local and federally required control measures, air quality in the nonattainment area would meet the annual NAAQS for fine particles by April 5, 2010, and provide for an ample margin of safety. The Cincinnati-Hamilton OH-KY-IN area monitors have met the annual NAAQS for fine particles since the end of 2009.

There were no monitors in th e Cincinnati-Hamilton OH-KY-IN fi ne particles nonattainment area that violated the 1997 24-hour standard for fine particles and or curr ently violates the 2006 24- hour standard for fine particles. As a result , the Cincinnati-Hamilton OH-KY-IN fine particles nonattainment area was designa ted nonattainment solely unde r the 1997 annual standard. Therefore, this document pertains only to the 1997 annual standard for fine particles.

The Cincinnati-Hamilton OH-KY-IN fine particle s nonattainment area, as defined in Section 1.2, has not previously been subject to nonattainment area rulemakings for fine particles. However, the area had been subject to nonattainment ar ea rulemakings under the 1-hour and the 8-hour ozone standards. The 1-hour ozone standard was revoked on June 15, 2005, and the Cincinnati area was redesignated to attainment of the 1997 ozone standard on May 11, 2010.

1.2 Geographical Description

The entire Cincinnati fine particles nonattainment area consists of: Lawrenceburg Township in Dearborn County, Indiana; Butler, Clermont, Hamilton, and Warren counties, Ohio; Boone, Campbell, and Kenton counties, Kentucky; and cont ains such cities as Cincinnati, Hamilton, and3 Middletown, all in Ohio. This ar ea is depicted in Figure 3.1.

The agencies responsible for assuring the fine particles nonattainment area complies with the CAA requirements are:

 The Ohio Environmental Protection Agency (Ohio EPA), which is responsible for Butler, Clermont, Clinton, Hamilt on, and Warren counties, Ohio.

 The Kentucky Department for Environmental Protection, (KDEP) which is responsible for Boone, Campbell, and Kenton counties, Kentucky.

 The Indiana Department of Environm ental Management (IDEM), which is responsible for Lawrenceburg Town ship, Dearborn County, Indiana.

These three state agencies have worked coope ratively with U.S. EPA Regions IV and V to address attainment planning issues.

Although the three agencies, in the three states, have worked together on a comprehensive plan for the multi-state nonattainment areas, each state is re quired to make a separate submittal for its portion of the planning components to U.S. EPA. Attainment demonstrations are SIP submittals and U.S. EPA action on them is taken separately. As such, this submittal only covers Lawrenceburg Township in Dearborn County, Indiana.

1.3 Status of Air Quality

Monitoring data for fine particles for the th ree years, 2007 through 2009, demonstrates that air quality has met the annual NAAQS for fine partic les in the Cincinnati area. This fact, accompanied by the permanent and enforceable reductions in emission levels discussed in Section 4.0, justifies a redesignati on to attainment for the Indi ana portion of the CincinnatiHamilton, OH-KY-IN nonattainment area base d on Section 107(d)(3 )(E) of the CAA.

2.0 REQUIREMENTS FOR REDESIGNATION

2.1 General

Section 110 and Part D of the CAA list a num ber of requirements that must be met by nonattainment areas prior to consideration for rede signation to attainment. In addition, U.S. EPA has published detailed guidance in a document entitled Procedures for Processing Requests to Redesignate Areas to Attainment , issued September 4, 1992, to Re gional Air Directors. This document is hereafter referred to as “Redesigna tion Guidance.” This Request for Redesignation and Maintenance Plan is based on the Redesi gnation Guidance, supplemented with additional guidance received from staff of the Air Planni ng and Maintenance Section of U.S. EPA Region V. The specific requirements fo r redesignation are listed below.4 2.2 Fine Particles Monitoring

1) A demonstration that the annual standard for fine particles, as published in 40 CFR 50.13, has been attained. Fine partic les monitoring data must show that violations of the annual ambient standard are no longer occurring.

2) Ambient monitoring data quality a ssured in accordance with 40 CFR 58.15, recorded in the U.S. EPA Air Quality Sy stem (AQS) database, and available for public view.

3) A showing that the three-year average of annual values, based on data from all monitoring sites in the area or its aff ected downwind environs, do not exceed 15.0 micrograms per cubic meter (μg/m 3 ). This showing must rely on three complete, consecutive calendar years of quality assured data.

4) A commitment that, once redesignated, the state will continue to operate an appropriate monitoring network to veri fy the maintenance of the standard.

2.3 Emission Inventory

1) A comprehensive emissi on inventory of direct PM 2.5 and the precursors of fine particles completed for the base year (2008 in this case).

2) A projection of the emission inventory to a year at least ten years following redesignation.

3) A demonstration that the pr ojected level of emissions is sufficient to maintain the annual standard for fine particles.

4) A demonstration that improvement in air quality between th e year violations occurred and the year attainment wa s achieved is based on permanent and enforceable emission reductions a nd not on temporary adverse economic conditions or unusually favorable meteorology.

5) Provisions for future annual updates of the inventory to enable tracking of the emission levels, including an annual em ission statement from major sources.

2.4 Modeling Demonstration

While no modeling is required for redesignating nonattainment areas, IDEM has evaluated the results of federal control-case modeling to demonstrate that compliance with the standard will be maintained.5 2.5 Controls and Regulations

1) A U.S. EPA-approved SIP control stra tegy that includes Reasonably Available Control Technology (RACT) requirements fo r existing stationary sources covered by Control Technology Guidelines (CTG ) and non-CTG RACT for all major

sources.

2) Evidence that control measures required in past SIP revisi ons have been fully implemented.

3) Acceptable provisions to pr ovide for new source review.

4) Assurances that existing controls will remain in effect after redesignation, unless the state demonstrates through photochemical modeling that the standard can be maintained without one or more controls.

5) If appropriate, a commitment to adopt a requirement that all transportation plans conform with and are cons istent with the SIP.

2.6 Corrective Actions for Potential Future Vi olations of the Fine Particles Standard

1) A commitment to submit a revised plan eight years af ter redesignation.

2) A commitment to expeditiously enact and implement additional contingency control measures in response to excee ding specified predetermined levels (triggers) or in the event that future vi olations of the ambient standard occur.

3) A list of potential contingency measures that would be implemented in such an
event.

4) A list of Nitrogen Oxides (NO x ), Sulfur Dioxide (SO 2 ) and direct PM 2.5 sources potentially subject to future controls.

3.0 FINE PARTICLES MONITORING

3.1 Fine Particles Monitoring Network

There are currently 12 Federal Reference Me thod monitors measuring fine particle concentrations for the Cincinnati area. Fine particle monitors are located in Campbell and Kenton counties in Kentucky and Butler, Clermont, Warren, and Hamilton counties in Ohio. There are no monitors for fine particles in the Indiana porti on of the Cincinnati nonattainment area. The highest levels of fine particle concentrations have been typically monitored at the Seymour and Vine Street monitor (39-0061-0014) in Hamilton County, Ohio. The locations of the monitoring sites for the Cincinnati area ar e shown in Figure 3.1. A listing of the monitor readings from 2007 through 2009, is shown in Tabl e 3.1 and Appendix A. The monitor readings6 were retrieved from the U.S. EP A’s Air Quality System (AQS).

The Wilwood and Winneste Ave. monitors in Oh io were discontinued on December 31, 2005. The Alexandria Park monitor in Kentuc ky was discontinued on December 31, 2006. The Hook Field Airport monitor in Ohio was discontinued on December 31, 2007. Therefore, these discontinued monitors are not shown in Figure 3.1.

Figure 3.1 Cincinnati Basic Nonattainment Area

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# μ Date: 5/17/2010

Map Projection: UTM Zone 16 N Map Datum: NAD83 0 10 5 mi

0 10 5 km University College ID# 21-117-0007 W. 8th St. ID# 39-061-0042 Nilles Rd. ID# 39-017-0016 Southeast St. ID# 39-165-0007

Murray Rd. ID# 39-061-8001

Howard Taft ID# 39-061-0040 Grooms Rd. ID# 39-061-0006

Sherman Ave. ID# 39-061-7001 Bonita & St. John ID# 39-017-0003

Seymour & Vine St. ID# 39-061-0014

John Hill Rd. ID# 21-037-3002 Clermont Dr. ID# 39-025-0022

Legend

! PM 2.5 Monitors State Boundary

Attainment Area

Nonattainment Area Butler

Hamilton Warren

Kenton Lawrenceburg Township Clermont

Campbell Boone7 3.2 Ambient Fine Particles Monitoring Data

The following information summarizes U.S. EP A's "Guideline on Data Handling Conventions for the annual fine particles NAAQS," U.S. EPA-454/R-99-008, April 1999. Three complete years of fine particles monitori ng data are required to demonstr ate 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 of th e annual average of fine particle concentrations is less than or equal to 15.0 μg/m 3 . When this occurs, the site is said to be in attainment. While calculating design values, three sign ificant digits must be carried in the computations, with final values rounded to the nearest 0.1 μg/m 3 . Decimals 0.05 or greater are rounded up, and those less than 0.05 are rounded down, so that 15.049 μg/m 3 is the largest concentration that is less than or equal to 15.0 μg/m 3 . Values at or below 15.0 μg/m 3 meet the standard. Values equal to or greater than 15.1 μg/m 3 exceed the standard.

Data handling procedures are applied on an indi vidual basis at each monitor in the area. An individual site’s three-year av erage of the annual average fine particles concentr ation is also called the site’s design value . An area is in compliance w ith the annual NAAQS for fine particles only if all monitoring sites meet the NAAQS. The air quality design value for the area is the highest design value among all sites in the area. Table 3.1 shows the annual fine particle values by site and the 2007 through 2009 design valu es for the 12 active fine particle monitoring sites in the Cincinnati area.

Table 3.1

Monitoring Data for the Cincinnati Area (Annual Average and 2007-2009 Design Values)

SITE ID STATE COUNTY SITE NAME YEAR Annual Average (μg/m 3 ) 2007-2009 Average (μg/m 3 ) 21-037-3002 Kentucky Campbell John Hill Rd. 2007 14.36

12.51 21-037-3002 Kentucky Campbell John Hill Rd. 2008 11.83 21-037-3002 Kentucky Campbell John Hill Rd. 2009 11.34 21-117-0007 Kentucky Kenton Univ. College 2007 14.20

12.41 21-117-0007 Kentucky Kenton Univ. College 2008 11.99 21-117-0007 Kentucky Kenton Univ. College 2009 11.04
39-017-0003 Ohio Butler Bonita & St. John 2007 15.41

13.93 39-017-0003 Ohio Butler Bonita & St. John 2008 13.69
39-017-0003 Ohio Butler Bonita & St. John 2009 12.68
39-017-0016 Ohio Butler Niles Rd. 2007 14.94

13.92 39-017-0016 Ohio Butler Niles Rd. 2008 13.75
39-017-0016 Ohio Butler Niles Rd. 2009 13.08 39-017-1004 Ohio Butler Hook Fld. Airport 2007 14.63

N/A 39-017-1004 Ohio Butler Hook Fld. Airport 2008 39-017-1004 Ohio Butler Hook Fld. Airport 2009
39-025-0022 Ohio Clermont Clermont Dr. 2007 14.01

12.26 39-025-0022 Ohio Clermont Clermont Dr. 2008 11.75
39-025-0022 Ohio Clermont Clermont Dr. 2009 11.018 39-061-0006 Ohio Hamilton Grooms Rd. 2007 14.63

13.07 39-061-0006 Ohio Hamilton Grooms Rd. 2008 12.48
39-061-0006 Ohio Hamilton Grooms Rd. 2009 12.11 39-061-0014 Ohio Hamilton Seymour & Vine St. 2007 16.59

15.04 39-061-0014 Ohio Hamilton Seymour & Vine St. 2008 15.12 39-061-0014 Ohio Hamilton Seymour & Vine St. 2009 13.40
39-061-0040 Ohio Hamilton Howard Taft 2007 15.09

13.48 39-061-0040 Ohio Hamilton Howard Taft 2008 12.62
39-061-0040 Ohio Hamilton Howard Taft 2009 12.73
39-061-0042 Ohio Hamilton W. 8th St. 2007 15.90

14.67 39-061-0042 Ohio Hamilton W. 8th St. 2008 14.40
39-061-0042 Ohio Hamilton W. 8th St. 2009 13.71 39-061-0043 Ohio Hamilton Kemper Rd. 2007 14.85

N/A 39-061-0043 Ohio Hamilton Kemper Rd. 2008 13.32 39-061-0043 Ohio Hamilton Kemper Rd. 2009
39-061-7001 Ohio Hamilton Sherman Ave. 2007 15.09

13.93 39-061-7001 Ohio Hamilton Sherman Ave. 2008 13.74
39-061-7001 Ohio Hamilton Sherman Ave. 2009 12.97 39-061-8001 Ohio Hamilton Murray Rd. 2007 16.07

14.64 39-061-8001 Ohio Hamilton Murray Rd. 2008 14.40 39-061-8001 Ohio Hamilton Murray Rd. 2009 13.44
39-165-0007 Ohio Warren Southeast St. 2007 13.98

12.53 39-165-0007 Ohio Warren Southeast St. 2008 11.92
39-165-0007 Ohio Warren Southeast St. 2009 11.70
Value Above the Annual PM 2.5 Standard

Graph 3.1 visually demonstrates the 2003 throug h 2009 design values for the Cincinnati area.9 Graph 3.1 Design Values for the Cincinnati Area for Fine Particles, 2003 through 2009

Note: The AlexandriaPark monitor in Kentucky was disconti nued on December 31, 2006. Th e Wilwood and Winneste Ave. monitors in Ohio were discontinued on De cember 31, 2005. The Hook Field Airport monitor in Ohio was discontinued on December 31, 2007.

Graph 3.2 Cincinnati Area Annual Fine Particles Trends, 2005 through 2009

Note: The Alexandria Park monitor in Kentucky was discontinued on December 31, 2006. The Wilwood and Winneste Ave. monitors in Ohio were discontinued on De cember 31, 2005. The Hook Field Airpor t monitor in Ohio was discontinued on December 31, 2007. 0 5 10 15 20 25

2005 2006 2007 2008 2009

Alexandria Pk. John Hill Rd. Univ. College Bonita & St. John Nilles Rd. Wilwood Hook Field Airport Clermont Dr. Grooms Rd. Seymour & Vine St. Howard Taft Winneste Ave. W. 8th St Kemper Rd. Sherman Ave.μg/m3 0.0 2.0 4.0 6.0 8.0 10.0 12.0 14.0 16.0 18.0 20.0AlexandriaPk.JohnHillRd.Univ.CollegeBonita&St....NillesRd.WilwoodHookField...ClermontDr.GroomsRd.Seymour&...HowardTaftWinnesteAve.W.8thStKemperRd.ShermanAve.MurrayRd.SoutheastSt.

03

‐ 05 04

‐ 06 05

‐ 07 06

‐ 08 07

‐ 09μg/m310 The design values for the Cincinnati area demons trate that the annual NAAQS for fine particles has been attained. Refer to Appendix A for the complete fine particles monitoring data summary for the years 2000 to 2009.

Graph 3.1 shows the trend in design values, wh ile Graph 3.2 shows the trend for annual fine particles. A comprehensive list of the fine part icles monitoring sites’ design values over this period is outlined in Appendix A. The area's de sign values have recently trended downward, as emissions have declined due to programs su ch 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 Pa rts 51, 72, 75 and 96, published on October 17, 1998 and referred to as the “NO x SIP Call”) has significantly reduced emissions from large electric generating units (EGUs), industrial boile rs, and cement kilns. Indiana's NO x SIP Call Rule was adopted into the Indiana Admi nistrative Code on June 6, 2001 at 326 IAC 10-3 and 326 ICA 10- 4. The elevated fine particle values for 2005 are considered an abnormal occurrence. An analysis of meteorological conditions and monitoring values is included in Section 7.0 and supports the conclusion that attainment of the st andard as of 2009 is not the result of unusually favorable meteorological conditions. It is expected that this dow nward trend will continue as the above programs continue and the U.S. EPA’s proposed Transport Rule is implemented.

3.3 Quality Assurance

Kentucky and Ohio have quality assured all da ta shown in Appendix A in accordance with 40 CFR 58.10 and recorded the data in the AQS databa se and, thus, the data is available to the public.

3.4 Continued Monitoring

Ohio and Kentucky commit to continue monitoring c oncentrations of fine particles at the active sites indicated in Table 3.1 and Appendix A. Ther e are no monitors in the Indiana portion of the Cincinnati-Hamilton, OH-KY-IN nonattainment ar ea, however, IDEM will consult with U.S. EPA Region V staff should changes to the existing Indiana monitoring network become necessary in the future.

4.0 EMISSION INVENTORY

U.S. EPA Redesignation Guidance and Implementation Rules require the submittal of a comprehensive inventory of precursor emissions for fine particles (NO x , SO 2 , and direct PM 2.5 ) representative of the year wh en the area achieved attainment of the annual NAAQS for fine particles (base year). IDEM is using 2008 as the base year. IDEM must also demonstrate that the improvement in air quality between the year that violations occurred and the year that attainment was achieved is based on permanen t and enforceable emission reductions. Other requirements related to the emissi ons inventory include: a projecti on of the emission inventory to a year at least ten years following redesignation; a demonstration that the projected level of emissions is sufficient to maintain the annual stan dard for fine particles; and, a commitment to provide future updates of the inventory to enable tracking of emission leve ls during the ten year11 maintenance period. Consistent with the implemen tation rule for fine particles, IDEM and U.S. EPA do not consider volatile organi c compounds (VOCs) or ammonia (NH 3 ) to be significant contributors to fine particles. The following subsections addre ss each of these requirements.

4.1 Emission Trends

Point Sources

Graphs 4.1, 4.2 and 4.3 show that the tr end in point source emissions of NO x , SO 2, and direct PM 2.5 respectively for Lawrenceburg Township, D earborn County, Indiana, generally correspond to the years of monitored values used in this redesignation petition. The point source data are taken from Indiana's emissions reporting pr ogram. While an increase in direct PM 2.5 point source emissions for Lawrenceburg Township in Dearborn County, Indiana is noted, the increase in direct PM 2.5 emissions from 2005 to 2008 is due to previously unreported emissions from companies that did not submit their direct PM 2.5 emissions data in 2005, but did submit direct PM 2.5 data in the 2008 emissions inventory. Gr aphs 4.4, 4.5 and 4.6 show the trend in point source emissions for the entire Cincinnati-Ham ilton, OH-KY-IN nonattainment area. The entire Cincinnati area had a 14.6% reduction in NO x point source emissions, a 52.1% reduction in SO 2 point source emissions, and a 9.5% reduction in direct PM 2.5 point source emissions. Point source data for the entire Cinci nnati area is the combination of data from Indiana, Kentucky, and Ohio’s annual emissions reporting program. Graphs and data tables of emissions for the point source category can be found in Appendix B.

Graph 4.1 Dearborn County, IN NO x Point Source Emission Trends, 2005 and 2008

9,100 9,200 9,300 9,400 9,500 9,600 9,700 9,800 9,900 10,000 10,100

2005 2008TonsperYear

Year NOX12 Graph 4.2 Dearborn County, IN SO 2 Point Source Emission Trends, 2005 and 2008

Graph 4.3 Dearborn County, IN Direct PM 2.5 Point Source Emission Trends, 2005 and 2008 ‐ 2,500 5,000 7,500 10,000 12,500 15,000 17,500 20,000 22,500 25,000 27,500 30,000 32,500 35,000 37,500 40,000 42,500 45,000 47,500 50,000 52,500

2005 2008TonsperYear

Year SO2

660 680 700 720 740 760 780 800 820 840 860 880

2005 2008TonsperYear

Year Direct PM 2.513 Graph 4.4 Entire Cincinnati-Hamilton, OH-K Y-IN Nonattainment Area NO x Point Source Emission Trends, 2005 and 2008

Graph 4.5 Entire Cincinnati-Hamilton, OH-K Y-IN Nonattainment Area SO 2 Point Source Emission Trends, 2005 and 2008 50,000 52,000 54,000 56,000 58,000 60,000 62,000 64,000 66,000 68,000

2005 2008TonsperYear

Year NOX

50,000 70,000 90,000 110,000 130,000 150,000 170,000 190,000 210,000 230,000 250,000

2005 2008TonsperYear

Year SO214 Graph 4.6 Entire Cincinnati-Hamilton, OH-KY- IN Nonattainment Area Direct PM 2.5 Point Source Emission Trends, 2005 and 2008

All Anthropogenic Sources

Periodic inventories, which include emissions fr om all sectors (mobile, area, nonroad, and point source), were prepared for 2005 and 2008. Th e 2008 data was extrapolated from the 2005 emission inventory. Graphs 4.7, 4.8, and 4.9 show the trends for total NO x , SO 2 , and direct PM 2.5 emissions for all anthropogenic source categor ies in Lawrenceburg Township in Dearborn County, Indiana for 2005 and 2008. While an increase in direct PM 2.5 anthropogenic source emissions for Lawrenceburg Township in Dearbor n County, Indiana is noted, the increase in direct PM 2.5 emissions from 2005 to 2008 is due to previously unreported emissions from companies that did not submit their direct PM 2.5 emissions data in 2005, but did submit direct PM 2.5 data in the 2008 emissions inventory. Graphs 4.10, 4.11, and 4.12 show the trends for total NO x , SO 2 , and direct PM 2.5 emissions for all anthropogenic source categories for the entire Cincinnati-Hamilton, OH-KY-IN nonattainment ar ea for 2005 and 2008. These emissions trends roughly follow the years of monitored trends discussed in Section 3.0. There is a downward trend in NO x and SO 2 emissions from 2005 to 2008. The decrease in NO x can be largely attributed to the impact of the NO x SIP Call. As can be seen by Graph 4.12, overall the direct PM 2.5 anthropogenic source emissions for the entire Cincinnati-Hamilton, OH-KY-IN nonattainment area have substantia lly decreased. Graphs and data tables of emissions from each source category are available in Appendix C. 2,900 3,000 3,100 3,200 3,300 3,400 3,500

2005 2008TonsperYear

Year Direct PM 2.515 Mobile emissions inventories and projections for all countie s were prepared by the OhioKentucky-Indiana Regional Council of Governments (OKI) and is e xplained in further detail in Section 5.0. All 2005 data for the entire Cinci nnati-Hamilton, OH-KY-IN nonattainment area is from the 2005 periodic inventory wh ich has been identified as one of the preferred databases for SIP development. For the 2008 attainment year , emissions were extrapolated from the 2005 Lake Michigan Air Directors Consortium (L ADCO) modeling invent ory, using LADCO’s growth factors, for all sections except point sources (electrical ge nerating units and non-electrical generating units). Point source emissions for 2008 were compiled from Indiana, Kentucky, and Ohio’s annual emissions inventory databases.

The emissions inventory development and emissi ons projection discussion below, with the exception of the mobile emissions inventory and projections, identify procedures used by Ohio EPA and LADCO regarding emissions from Ohio’s portion of the counties in the CincinnatiHamilton, OH-KY-IN nonattainment area that di ffer from procedures used by Kentucky and Indiana. Indiana and Kentucky emissions da ta were obtained thr ough the LADCO emission inventory and projections which were prepared using similar methodologies.

For Ohio, the 2005 and 2008 actual PM 2.5 emissions data below generally contains filterable fraction emissions only and not the condensable fractions, because Ohio EPA did not have a consistent reporting requirement in those years. U.S. EPA In tegrated Planning Model(IPM) modeling was used to generate future year EGU emissions with the Clean Air Interstate Rule (CAIR) program. The IPM modeling added additional PM 2.5 condensible emissions into future years. Therefore, comparing base and attainment year emissions with the future year predictions is not accurate in the IPM CAIR modeling. This step leads to a false perception of significant PM 2.5 emissions increase. Modeling performed by LADCO, without CAIR, did not incorporate added condensable fraction emissions. Although Ohio EPA has stated that it is most appropriate to evaluate future year emissions that include th e CAIR program, because of this flaw, it is more accurate and appropriate for the purposes of PM 2.5 to evaluate future year emissions without the CAIR program. Therefore all numbers for Ohio for PM 2.5 in this document are without CAIR, while all numbers for Ohio for NO x and SO 2 are with CAIR. Both Indiana and Kentucky have used numbers for NO x , SO 2 , and PM 2.5 with CAIR. Emissions tables and charts in this document are labeled accordingly and can also be found in Appendix C.16 Graph 4.7 NO x Emission Trends, All Sources in De arborn County, IN, 2005 and 2008-With CAIR

Graph 4.8 SO 2 Emission Trends, All Sources in De arborn County, IN, 2005 and 2008-With CAIR 10,200 10,400 10,600 10,800 11,000 11,200 11,400 11,600

2005 2008TonsperYear

Year NOX

‐ 10,000 20,000 30,000 40,000 50,000 60,000

2005 2008TonsperYear

Year SO217 Graph 4.9 Direct PM 2.5 Emission Trends, All Sources in Dearborn County, IN, 2005 and 2008-With CAIR

Graph 4.10 NO x Emission Trends, All Sources in En tire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area, 2005 and 2008-With CAIR 740 760 780 800 820 840 860 880 900 920 940

2005 2008TonsperYear

Year

Direct PM 2.5

135,000 140,000 145,000 150,000 155,000 160,000 165,000 170,000

2005 2008TonsperYear

Year NOX18 Graph 4.11 SO 2 Emission Trends, All Sources in En tire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area, 2005 and 2008-With CAIR

Graph 4.12 Direct PM 2.5 Emission Trends, All Sources in En tire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area, 2005 and 2008-Without CAIR ‐ 50,000 100,000 150,000 200,000 250,000 300,000

2005 2008TonsperYear

Year SO2

8,600 8,700 8,800 8,900 9,000 9,100 9,200 9,300 9,400 9,500

2005 2008TonsperYear

Year Direct PM 2.519 EGU Sources

Both NO x and SO 2 emissions are decreasing substantiall y in response to national programs affecting all EGUs such as th e Acid Rain program and the NO x SIP Call. Other sectors of the inventory also impact the formation of fine part icles, but large regional sources such as EGUs have a substantial impact on the formation of fine particles.

The data was taken from U.S. EPA's Clean Air Markets database 1

. Data are available sooner for these units than other point sources in the inventory because of the NO x SIP Call budget and trading requirements. Information from 2003 is significant because some EGUs started operation of their NO x SIP Call controls in order to gene rate Early Reduction Credits for their future year NO x budgets. The first season of the NO x SIP Call budget period began May 31, 2004.

As part of the NO x SIP Call, the states were required to adopt into their rules a budget for all large EGUs. Indiana’s budget is referenced in 326 IAC 10-4. The budget represents a statewide cap on NO x emissions. Although each unit is allocated emissions based upon hi storic heat input, utilities can meet this budget by over-controlling certain units or purchasing credits from the market to account for overages at other units. To summarize, NO x emissions have dramatically decreased over the years represented on these graphs.

These emissions, capped by the state rule, are exp ected to remain near these levels throughout the maintenance period covered by this request. The state cap for the NO x SIP Call remained in place through 2008, at which time the CAIR program superseded it. CAIR, issued in March 2005, adopted by the Indiana Air Pollution Control Board on November 1, 2006, and implemented beginning in 2010, will continue to reduce regional EGU NO x emissions statewide by approximately another 17% by 2015 and 57% for EGU SO 2 emissions by 2015. The D.C. Circuit court’s vacatur of CAIR in July of 2008 and subsequent remand without vacatur in December of 2008 directs U.S. EPA to revise the CAIR rule in the future. The proposed Clean Air Transport Rule (Transport Ru le) (CAIR’s replacement rule) will result in similar or greater emission reductions than assumed within the current emission i nventories once it is implemented.

There is one EGU located in the Indiana por tion (Lawrenceburg Township, Dearborn County, Indiana) of the Cincinnati area: American Electric Power (AEP)- Tanner’s Creek. Graphs 4.13 and 4.15 depict the trends in NO x and SO 2 emissions from the EGU in Lawrenceburg Township, Dearborn County, Indiana for the years 1999 to 2009. AEP-Tanner’s Creek entered into a Consent Decree with U.S. EPA on October 9, 2007. For NO x , the Consent Decree calls for lowNOx burners and overfire air. Further, they installed Selective Non-Catalytic Reduction (SNCRs) on Units 1, 2, and 3 in 2008 to meet CAIR requirements. As a general rule, low NO x burners are around 40% control and SNCRs are an additional 30%. AEP-Tanner’s Creek’s permit does not require operation of these units, bu t they need to operate the controls to meet CAIR allowances for now, and the proposed Transpor t Rule will control when it is effective. For SO 2 , the Consent Decree and the permit state AEP-Tanner’s Creek has to burn coal not exceeding 1.2% sulfur. With the Consent Decree in place these contro ls are, therefore,

1 http://www.epa.gov/airmarkets20 considered permanent and enforceable and can be associated with the downward trend in NO x and SO 2 emissions from AEP-Tanner’s Creek. Gr aphs 4.14 and 4.16 depict the trends in NO x and SO 2 emissions from the entire Cincinnati -Hamilton, OH-KY-IN nonattainment area for the years 1999 to 2009. Graphs and data tables of em issions from the EGU source category can be found in Appendix D.

Graph 4.13

Lawrenceburg Township, Dearborn County, Indiana NO x Emissions from EGUs, 1999 to 2009

0.0 5,000.0 10,000.0 15,000.0 20,000.0 25,000.0 30,000.0 35,000.0 40,000.0

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Total NOx Emissions, tons / year21 Graph 4.14 Entire Cincinnati-Hamilton OH-K Y-IN Nonattainment Area NO x Emissions from EGUs, 1999 to 2009

Graph 4.15 Lawrenceburg Township, Dearborn County, Indiana SO 2 Emissions from EGUs, 1999 to 2009 0.0 20,000.0 40,000.0 60,000.0 80,000.0 100,000.0 120,000.0 140,000.0

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Total NOx Emissions, tons / year

0.0 10,000.0 20,000.0 30,000.0 40,000.0 50,000.0 60,000.0 70,000.0 80,000.0

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009
Total SO2 Emissions, tons / year22 Graph 4.16 Entire Cincinnati-Hamilton OH-K Y-IN Nonattainment Area SO 2 Emissions from EGUs, 1999 to 2009

4.2 Base Year Inventory

IDEM prepared a comprehensive inventory for the Cincinnati area, in cluding area, mobile, nonroad, and point sources for direct PM 2.5 and precursors of fine particles (NO x and SO 2 ) for 2005 (the year with the most complete emission s inventory available at this time). The 2008 data was extrapolated from the 2005 emission invent ory to represent a base year for maintenance purposes. The 2007 implementation rule for the a nnual fine particles sta ndard states that NO x , SO 2 , and direct PM 2.5 are the regulated precursors of fine particles. Ammonia and VOCs are not required to be addressed unless the state or U.S. EPA makes a technical demonstration that emissions of these pollutants from sources in the state significantly contribute to PM 2.5 concentrations in a given nonattainment area. U.S. EPA and Indiana have not determined ammonia or VOCs to be significant contributors to fine particles formation in the State of Indiana. Indiana’s 2008 base year invent ory was determined by the following:

 Area sources were extrapolated from the Indiana 2005 periodic inventory submitted to U.S. EPA.

 Mobile source emissions were calculated fr om U.S. EPA’s Motor Vehicle Emissions Simulator (MOVES) model-produced emission factors and data ex tracted from the region’s travel-demand model. These emissions were then interpolated as needed to determine 2008 base year values. 0.0 50,000.0 100,000.0 150,000.0 200,000.0 250,000.0 300,000.0

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009
Total SO2 Emissions, tons / year23  Point source information was compiled from IDEM’s emissions statement database and U.S. EPA's Clean Air Mark ets acid rain database.

 Biogenic emissions are not included in these summaries.

 Nonroad emissions were extrapolated fr om the 2005 National Emissions Inventory (NEI). To address concerns about the accuracy of some of the categories in U.S. EPA’s nonroad emissions model, LADCO contracted with two companies to review the base data and make recommendations. One of th e contractors also estimated emissions for two nonroad categories not included in U.S. EPA's nonroad model. Emissions were estimated for commercial marine vessels a nd railroads. The recreational motorboat population and spatial surrogates (used to as sign emissions to each) were significantly updated. The populations for the constructi on 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 es timation model was provided by U.S. EPA for the 2005 analysis.

● The emissions data referenced for Kentuc ky’s portion of the nonattainment area were pulled from LADCO’s emissions inventory files. This i nventory was prepared using similar methodologies. The 2008 data wa s extrapolated from the 2005 emission inventory to represent a base year for maintenance purposes.

4.3 Emission Projections

In consultation with the U.S. EPA and other stakeholders, IDEM selected the year 2021 as the maintenance year for this redesignation request . This document contai ns projected emission inventories for 2015 and 2021. Emission projections were pr epared for Dearborn County, Indiana, as well as for the entire nonattainme nt area. IDEM, with assistance from LADCO, prepared emission projections for 2015 a nd 2021 for the entire nonattainment area.

The detailed 2015 and 2021 emissions inventory for the entire Cincinnati-Hamilton, OH-KY-IN nonattainment area can be found in Appendix E. Emission trends are an important gauge for continued compliance with the annu al standard for fine particles. Therefore, IDEM performed an initial comparison of the inventories for th e base year (2008-extr apolated from the 2005 emission inventory), interim year (2015-inter polated from 2009 emissions and 2018 emissions estimates) and maintenance year (2021-extrapolated from 2018 emission estimates) for Dearborn County, Indiana and the entire Cincinnati -Hamilton OH-KY-IN nonattainment area.

For the 2008 attainment year, emissions we re extrapolated from the 2005 LADCO modeling inventory, using LADCO’s growth factors, for all sections except point sources (electrical generating units and non-electri cal generating units). Point source emissions for 2008 were compiled from Indiana, Kentucky, and Ohio’s a nnual emissions inventory databases. The 2015 interim year emissions were estimated ba sed on the 2009 and 2018 LADCO modeling inventory, using LADCO’s growth factors, for all sect ors. The 2021 maintenance year is based on emissions estimates from the 2018 LADCO modeling.24 Graphs 4.17, 4.18, 4.19, and 4.20 visually compare 2008 (base year) NO x , SO 2 , and direct PM 2.5 estimated emissions with the 2015 and 2021 projected emissions for Lawrenceburg Township, Dearborn County, Indiana. Graphs 4.21, 4.22, 4.23, and 4.24 visually compare the 2008 (base year) NO x , SO 2 and direct PM 2.5 estimated emissions with the 2015 and 2021 projected emissions for the entire Cincinnati-Hamilton, OH-KY-IN nonattainment area. AEP-Tanner’s Creek accounts for over 80% of Lawrenceburg Township’s total emissions. However, Lawrenceburg Township accounts for a minor portion (14%) of th e total nonattainment ar ea emissions. While an increase can be seen in the projected em issions for Lawrenceburg Township, Dearborn County, Indiana for NO x , SO 2 and direct PM 2.5 , overall emissions in the entire CincinnatiHamilton, OH-KY-IN nonattainment area are decreasi ng substantially as can be seen in Graphs 4.21, 4.22, 4.23 and 4.24. Mobile source emission inve ntories are further de scribed in Section 5.0. In addition to LADCO’s estimates, point source emissions were projected based upon the statewide EGU NO x budgets from the Indiana NO x rule. It should be noted that EGU emission estimates for 2015 and 2021 were projected utiliz ing the Department of Energy Information’s Annual Energy Outlook Supplemental tables for the year 2018. These tables were generated for the reference case of the Annual Energy Ou tlook 2007 (AEO 2007) using the National Energy Modeling System. Future year actual emissions for Lawrenceburg Township may vary based upon the consent decree for AEP which incl udes Tanner’s Creek. Additionally, the SO 2 and NO x allocations for AEP-Tanner’s Creek for 201 4 and beyond within the proposed Transport Rule are less than 2008 actual emissions. Graphs and data tables of emissions from the EGU source category can be found in Appendix D.

Graph 4.17 Comparison of 2008, 2015 and 2021 Projected NO x Emissions, Lawrenceburg Township, Dearborn County, Indiana-With CAIR

Refer to Section 4.3 above for explanat ion of projected increase in emissions. ‐ 2,000 4,000 6,000 8,000 10,000 12,000 14,000 16,000

2008 2015 2021TonsperYear

Year NOX25 Graph 4.18 Comparison of 2008, 2015 and 2021 Projected SO 2 Emissions, Lawrenceburg Township, Dearborn County, Indiana-With CAIR

Refer to Section 4.3 above for expl anation of projected increase in emissions.

Graph 4.19 Comparison of 2008, 2015 and 2021 Projected Direct PM 2.5 Emissions, Lawrenceburg Township, Dearborn Co unty, Indiana-With CAIR

Refer to Section 4.3 above for explanation of projected increase in emissions. ‐ 5,000 10,000 15,000 20,000 25,000 30,000 35,000 40,000 45,000

2008 2015 2021TonsperYear

Year SO2

860 880 900 920 940 960 980 1,000 1,020

2008 2015 2021TonsperYear

Year Direct PM 2.526 Graph 4.20 Comparison of 2008, 2015 and 2021 Projected SO 2 , NO x and Direct PM 2.5 Emissions, Lawrenceburg Township, Dearbo rn County, Indiana-With CAIR

Graph 4.21 Comparison of 2008, 2015 and 2021 Projected NO x Emissions for the Entire CincinnatiHamilton, OH-KY-IN Nonattainment Area-With CAIR ‐ 5,000.00 10,000.00 15,000.00 20,000.00 25,000.00 30,000.00 35,000.00 40,000.00 45,000.00

2008 2015 2021TonsperYear

NOX SO2 Direct PM2.5

‐ 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000

2008 2015 2021TonsperYear

Year NOX27 Graph 4.22 Comparison of 2008, 2015 and 2021 Projected SO 2 Emissions for the Entire CincinnatiHamilton, OH-KY-IN Nonattainment Area-With CAIR

Graph 4.23 Comparison of 2008, 2015 and 2021 Projected Direct PM 2.5 Emissions for the Entire Cincinnati-Hamilton, OH-KY-IN No nattainment Area-Without CAIR ‐ 20,000 40,000 60,000 80,000 100,000 120,000 140,000

2008 2015 2021TonsperYear

Year SO2

7,800 8,000 8,200 8,400 8,600 8,800 9,000

2008 2015 2021TonsperYear

Year Direct PM2.528 Graph 4.24 Comparison of 2008, 2015 and 2021 Projected SO 2 , NO x and Direct PM 2.5 Emissions for the

Entire Cincinnati-Hamilton, OH-K Y-IN Nonattainment Area-(NO x and SO 2 With CAIR, PM 2.5 Without CAIR)

NO x emissions within the entire Cincinna ti-Hamilton, OH-KY-IN nonattainment area are projected to decline by 46.9% between 2008 and 2021. Emission reduction benefits from U.S. EPA rules covering the NO x SIP Call, Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements, Hi ghway Heavy-Duty Engine Rule, and Nonroad Diesel Engine Rule are factored into the changes. Additionally, due to implementation of the NO x SIP Call across the eastern United States, NO x and fine particle levels en tering the Cincinnati area will also be decreased. SO 2 emissions within the Cincinnati area are projected to decline by 24.3% between 2008 and 2021. Direct PM 2.5 emissions from 2008 to 2021 are also projected to decline by 5.6% within the Cincinnati area, see Tables 4.1 and 4.2.

Table 4.1 Comparison of 2008 Estimated and 2021 Proj ected Emission Estimates Lawrenceburg Township, Dearborn County, Indiana (Tons Per Year) 2008 2021 Change % Change NO x 10,621.35 13,767.56 3,146.21 29.6% SO 2 27,164.52 38,261.63 11,097.11 40.9% Direct PM 2.5 920.29 1,011.29 91.00 9.9% ‐ 20,000.00 40,000.00 60,000.00 80,000.00 100,000.00 120,000.00 140,000.00 160,000.00

2008 2015 2021TonsperYear

NOX SO2 Direct PM2.529 Table 4.2 Comparison of 2008 Estimated and 2021 Projected Emission Estimates Entire CincinnatiHamilton, OH-KY-IN Nonattainme nt Area (Tons Per Year) 2008 2021 Change % Change NO x 148,706.15 78,819.18 -69,886.97 -46.9% SO 2 116,966.42 88,540.12 -28,426.30 -24.3% Direct PM 2.5 8,687.22 8,202.63 -484.59 -5.6%

4.4 Demonstration of Maintenance

Quality assured ambient air quality data from all the monitoring sites indicat e that air quality in the Cincinnati area met the annual NAAQS for fine particles for the three-year period ending in 2009. U.S. EPA’s Redesignation Guidance (Page 9) states, “A state may generally demonstrate maintenance of the NAAQS by either showing th at future emissions of a pollutant or its precursors will not exceed the level of the attain ment inventory, or by modeling to show that the future mix of sources and emissions rate s will not cause a viol ation of the NAAQS.” Emissions projections outlined in Section 4.0 of this document clearly illustrate that regional NO x and SO 2 emissions in the area will continue to declin e leading to local reduc tions between 2008 and 2021 (maintenance plan horizon). Section 7.0 further discusses the implications of these emission trends and provides an analysis to support these conclusions.

In Indiana, major point sources in all counties are required to submit air emissions information once every three years, or annually, if the NO x or SO 2 potential to emit is greater than 2,500 tons per year in accordance with the Emission Reporting Rule, 326 IAC 2-6. IDEM prepares a new periodic inventory for all precurs or emission sectors every three y ears. These precursor emission inventories will be prepared for 2011, 2014, a nd 2017, as necessary, to comply with the inventory reporting requirements established in the CAA. Emissions information will be compared to the 2008 base year and the 2021 proj ected maintenance year inventories to assess emission trends, as necessary, to assure continue d compliance with the a nnual standard for fine particles.

4.5 Permanent and Enforceable Emission Reductions

Permanent and enforceable reductions of NO x and SO 2 have contributed to th e attainment of the annual standard for fine particles. Some of th ese reductions were due to the implementation of the NO x SIP Call and some were due to the applica tion of tighter federal standards on motor vehicles and fuels.

Section 6.0 identifies the emission control measur es specific to Dearborn County, Indiana, as well as the implementation status of each measure.

4.6 Provisions for Future Updates30 As required by Section 175A(b) of the CAA, Indi ana commits to submit to the Administrator, eight years after redesignation, an additional revi sion of this SIP. The revision will contain Indiana's plan for maintaining the national primary fine particles air quality standard for ten years beyond the first ten-year pe riod after re designation.

5.0 MOBILE SOURCE EMISSION BUDGETS

U.S. EPA requirements outlined in 40 CFR 93.118(e )(4) stipulate that mobile source emissions budgets for PM 2.5 and NO x be established as part of a SIP. The mobile source emissions budgets are necessary to demonstrate conformance of transportation plans and improvement programs with the SIP.

The following is a summary of the detailed mobile input and output calcul ation files located in Appendix F.

5.1 Onroad Emissions Estimates

The Ohio-Kentucky-Indiana Regional Council of Governments (OKI) is the Metropolitan Planning Organization (MPO) for the Cinci nnati-Hamilton OH-KY-IN area which includes: Dearborn County in Indiana; Butler, Clermont , Hamilton, and Warren counties in Ohio; and, Boone, Campbell, and Kenton counties in Kentuc ky. This organization maintains a travel demand forecasting model that is used to simulate the traffic in the area and to predict what traffic would be in future years given growth exp ectations. The model is used mostly to identify where travel capacity will be needed and to de termine the infrastructure requirements necessary to meet that need. It is also used to support the calculation of mobile source emissions. The travel demand forecasting model is used to predic t the total daily vehicle miles traveled (VMT) and the U.S. EPA software program referred to as MOVES is used to produce emission factors to calculate the emissions per mile. The product of these two outputs, once combined, is the total amount of pollution emitted by onroad vehicles for the particular analyzed area.

5.2 Overview

Broadly described, MOVES is used to genera te “emission factors,” which are the average emissions per mile (grams/mile) for direct PM 2.5 and PM 2.5 precursors, including NO x and SO 2
. There are numerous variables that can affect the emission factors. The ve hicle-fleet (vehicles on the road) age and the vehicle types have a major a ffect on the emission factors. The facility-type the vehicles are traveling on (MOVES facility-t ypes are Freeway, Arterial, Local, and Ramp) and the vehicle speeds also affect the emission f actor values. Meteorological factors such as air temperature and humidity affect the emission factors, as does fuel type, such as low Reid Vapor Pressure (RVP) gasoline. These data are estimated using the best available data to generate emission factors for direct PM 2.5 and PM 2.5 precursors, including NO x and SO 2 . After emission factors are generated, the emission factors must be multiplied by the VMT to determine the quantity of vehicle-related emissions. This info rmation derives from the travel demand model (TDM).31 It should be noted that each year analyzed will have different emission factors, volumes, speeds, and likely some additional links. MOVES input a nd output files can all be found in Appendix F.

5.3 Emission Estimates

Table 5.1 outlines the onroad emission estimates for the Ohio and Indiana portions of the nonattainment area for the years 2005, 2008 (Att ainment Year), 2015 (Interim Year), and 2021 (Horizon Year). The following emission estimates are based on the actual TDM network runs for the years 2005, 2008, 2015, and 2021.

Table 5.1 Emission Estimates for Onroad Mobile Sources for the Cincinnati-Hamilton OH-KY-IN PM 2.5 Nonattainment Area

Cincinnati-Hamilton OHKY-IN NA Area 2005 2008 2015 2021

PM 2.5 (tons/year) 2,272.50 2,034.23 1,598.67 1,128.35

NO x (tons/year) 58,423.36 51,357.02 31,064.20 18,911.05

Lawrenceburg Township (Dearborn County Indiana) subtotal

PM 2.5 (tons/year) 33.98 29.89 25.14 18.11

NO x (tons/year) 865.46 748.81 482.33 297.95

Lawrenceburg Township subtotal %
PM 2.5 (tons/year) 1.50 1.47 1.57 1.61

NO x (tons/year) 1.48 1.46 1.55 1.58

Table 5.2 contains the 2015 and 2021 regional mob ile source emissions budgets for the Ohio and Indiana portions of the nonattainment area.

Table 5.2 Mobile Source Emission Budgets for the Ohio and Indiana Portions of the Cincinnati PM 2.5 Nonattainment Area

2015 2021 PM 2.5 (tons/year) 1,678.60 1,241.19 NO x (tons/year) 35,723.83 21,747.71

Consistent with the federal im plementation rule for fine part icles, IDEM does not consider mobile SO 2 to be a significant contributor to fine particles for this nona ttainment area, as SO 232 constitutes less than one percen t (<1%) of the area’s total anthropogenic emi ssions for the years 2005, 2008, 2015, or 2021.

This document creates an interim year budge t for 2015 and a horizon year budget for 2021 for the Ohio and Indiana portions of the nonattainment area. Th ese budgets are based on the 2008 onroad emission inventory used to support photoc hemical modeling for the same year, and has incorporated an appropriate safety margin as described below. A similar document was created for the Kentucky portion of the nonattainment area.

Initial Base M (2005) Comprehensive Air Qual ity Model with Extension (CAMx) modeling results indicated a worst case future design value in the Cincinnati-Hamilton OH-KY-IN nonattainment area of 84 ppb. In an effort to accommodate future variations in TDMs and vehicle miles traveled forecast when no change to the network is planned, IDEM consulted with the interagency consultation gr oup, including U.S. EPA – Region 5, to determine a reasonable approach to address this variation. The inte ragency consultation group approved a five percent (5%) safety margin for PM 2.5 mobile source emissions estimates for the year 2015, a ten percent (10%) safety margin for PM 2.5 mobile source emissions estimates for the year 2021, and a fifteen percent (15%) safety margin for NO x mobile source emissions estimates for the years 2015 and 2021.

Safety margins are appropriate b ecause: 1) there is an acknowl edged potential variation in VMT forecast and potential estimated mobile source em issions due to expected modifications to TDM and mobile emissions models; and 2) the total decrease in emissions from all sources is sufficient to accommodate the safety margin allocations detailed above to mobile sources while still continuing to maintain total emissions in the Cincinnati-Hamilton OH-KY-IN area well below the 2008 attainment level of emissions. These safety margins were calculated by adding a straight-line percentage to the mobile source emission estimates for the years 2015 and 2021. Safety margin, as defined by the conformity rule, looks at the total emissions from all sources in the nonattainment area. The resulting 2015 and 2021 budgets for PM 2.5 and NO x emissions remain well below the 2005 base year emissions referenced in Table 5.1.

In summary, for all three states combined, the mobile budget safety margin allocation translates into:

 An allocation of 98.49 tons/year for PM 2.5 and 5,709.06 tons/year for NO x for 2015.

 An allocation of 140.38 tons/year for PM 2.5 and 3,799.82 tons/year for NO x for 2021.

The federal rule at 40 CFR 93.101 defines safety margin as the amount by which the total projected emissions from all sources of a given pollutant are less than the total emissions that would satisfy the applicable requirement for reasonable further progress, attainment, or maintenance. When compared to the overall safety margin as defined by 40 CFR 93.101, it is evident this allocation to mobile sources is si gnificantly below the total safety margin for all sources in the Cincinnati-Hamilton OH-KY -IN area as detailed in Table 4.2.

While IDEM believes that this is sufficient to support the requested increase, IDEM and its partners will be conducting additional air quality modeling which will include the adjusted on-33 road mobile emissions as well as any additiona l corrections and modifications that may be necessary due to the constant review and evaluation of the model inputs.

All methodologies, latest planning assumptions, and margins of safety were determined appropriate through the interage ncy consultation process.

6.0 CONTROL MEASURES AND REGULATIONS

This section provides specific information on the control measures that have been or will be implemented in Dearborn County, Indiana, includ ing CAA requirements and additional state or local measures implemented beyond CAA requirements.

6.1 Reasonably Available Control Technology (RACT)

As required by Section 172 of the CAA, Indi ana in the mid-1990s promulgated rules requiring RACT for emissions of VOCs. There were no specific rules required by the CAA, such as RACT for existing sources, beyond st atewide rules. Statewide RACT rules have applied to all new sources locating in Indiana since that time. The Indiana rules are found in 326 IAC 8. The following is a listing of applicable rules:

326 IAC 8-1-6 BACT fo r Non-Specific Sources 326 IAC 8-2 Surface Coating Emission Limitations 326 IAC 8-3 Solvent Degreasing Operations 326 IAC 8-4 Petroleum Sources 326 IAC 8-5 Miscellaneous Operation 326 IAC 8-6 Organic Solvent Emission Limitations

Since Dearborn County, Indiana, attained the annual NAAQS for fine particles prior to an Attainment SIP or RACT SIP being due, and sin ce the Implementation Rule for fine particles stipulates that states are only required to draft and implemen t RACT rules for the precursor emission reductions necessary to attain the sta ndard, no further RACT rules are required for this area. These Indiana rules are CAA requirement s already in the SIP and provide secondary benefits for PM 2.5
. 6.2 Implementation of Past SIP Revisions

The Cincinnati area was only recent ly designated nonattainment for the annual standard for fine particles and the area has attained the standard well in advance of its attainment deadline of 2010. As a result, Indiana is no longer required to develop and submit an Attainment SIP or RACT SIP for this area under the an nual NAAQS for fine particles.

6.3 Nitrogen Oxides (NO x ) Rule34 The U.S. EPA NO x SIP Call required twenty-two states to adopt rules that would result in significant emission reductions from large EGUs, industrial boilers, and cement kilns in the eastern United States. Indiana adopted this rule in 2001. Beginni ng in 2004, this rule accounted for a reduction of approximately thirty-one percent (31%) of all NO x 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 nonattai nment area because of th e number of affected units within the region. From Graphs 4.13 and 4.14, it can be seen that emissions covered by this program have been trending downward since 1999. Table 6.1, compiled from data taken from the U.S. EPA Clean Air Markets We b site, quantifies the gradual NO x reductions that have occurred in Indiana as a result of Titl e IV (Acid Rain) of the CAA and the NO x SIP Call Rule. The NOx SIP Call cap stayed in place through 2008, at which time the caps in the CAIR program superseded it. Since CAIR is a regiona l cap and trade program, it cannot be predicted at this time what effect this will have on EGU units located in the nonattainment area or other upwind counties.

Further, U.S. EPA published Phase II of the NO x SIP Call that estab lishes a budget for large (emissions of greater than 1 ton pe r day) stationary internal combus tion engines. In Indiana, the rule decreases emissions statewide from natural gas compressor stations by 4,263 tons during the ozone season (May through September). The Indiana Phase II NOx SIP Call Rule became effective February 26, 2006 and im plementation began in 2007.

Table 6.1 Trends in EGU NO x Emissions Statewide in Indiana Year NO x Emissions (tons /year) 1999 347,216.5 2000 334,522.1 2001 315,419.7 2002 281,146.1 2003 260,980.0 2004 224,311.3 2005 207,981.6 2006 202,728.0 2007 196,553.1 2008 196,134.5 2009 110,968.9 Budget 2009-2014 108,935 Budget 2015 and later 90,779

6.4 Measures Beyond CAA SIP Requirements

Reductions in fine particles precurs or emissions have occurred, or are anticipated to occur, as a result of local and federal programs. These additional control measures include: Tier 2 Vehicles Standards 2
Federal Tier 2 motor vehicle st andards require all passenger ve hicles in a manufacturer’s35 fleet, including light-duty trucks and sport util ity vehicles (SUVs), to meet an average standard of 0.07 grams of NO x per mile. Implementation began in 2004 and was completed in 2007. The Tier 2 standards al so cover passenger vehicles over 8,500 pounds gross vehicle weight ra ting (larger pickup trucks and SUVs), which are not covered by the current Tier 1 standards. For these vehicles, the standards were phased in beginning in 2008, with full compliance in 2009. The new standards require vehicles to be 77% to 95% cleaner than those on the road prior to the program. The Tier 2 standards also reduced the sulfur content of gasolin e to 30 parts per million (ppm) beginning in January 2006. Most gasoline sold in Indian a prior to January 2006 had a sulfur content of about 500 ppm. Sulfur occurs naturally in gasoline, but interfer es with the operation of catalytic converters on ve hicles resulting in higher NO x emissions. Lower sulfur gasoline is necessary to achieve the Ti er 2 vehicle emissions standards.

Heavy-Duty Gasoline and Diesel Highway Vehicle Standards 3 New U.S. EPA standards designed to reduce NO x and VOC emissions from heavy-duty gasoline and diesel highway vehicles took e ffect in 2004. A second phase of standards and testing procedures th at began in 2007, reduced PM 2.5 emissions from heavy-duty highway engines and also reduced highway diesel fuel sulfur content to 15 ppm since the sulfur can damage emissions control devices. The total program is expected to achieve a 90% reduction in direct PM 2.5 emissions and a 95% reduction in NO x emissions for these new engines using low sulfur diesel, compared to existing engines using higher sulfur content diesel. There will also be SO 2 reductions from these rules. The U.S. EPA has not quantified the expected reductions.
Large Nonroad Diesel Engine Standards 4 In May 2004, U.S. EPA promulgated new rules fo r large nonroad diesel engines, such as those used in construction, agri cultural and indu strial equipment, to be phased in between 2008 and 2014. The nonroad diesel rules also reduce the allowable sulfur in nonroad diesel fuel by over 99%. Nonroad diesel fuel currently averages approximately 3,400 ppm sulfur. This rule limits nonroad dies el sulfur content to 500 ppm in 2006 and 15 ppm in 2010. The combined engine and fuel rules will reduce NO x and PM 2.5 emissions from large nonroad diesel engines by over 90%, compared to current nonroad engines using higher sulfur content diesel.
Nonroad Spark-Ignition Engines an d Recreational Engines Standards This standard, effective in July 2003, regulates NO x , VOCs, and carbon monoxide (CO) for groups of previously unre gulated nonroad engines. The standard applies to all new engines sold in the United States and importe d after the standards went into effect. The standard applies to large spark-ignition e ngines (forklifts and airport ground service equipment), recreational vehicles (off-highway motorcycles and all-te rrain vehicles), and recreational marine diesel engines. The re gulation varies based upon the type of engine and vehicle.

2 http://www.epa.gov/fedrgstr/EPA-AI R/2000/February/Day-10/a19a.htm
3 http://www.epa.gov/fedrgstr/EPA-AI R/1997/October/Day-21/a27494.htm
4 http://www.epa.gov/fedrgstr/EPA-AI R/1998/October/Day-23/a24836.htm36 The large spark-ignition engines contribute to ozone formation and ambient CO and PM 2.5 levels in urban areas. Tier 1 of this standard was implemented in 2004 and Tier 2 started in 2007. Like the large spark-ignition engines, recreational vehicles contribute to ozone and fine particles formation and ambient CO and PM 2.5 levels. For model year 2006 off-highway motorcycles and all-terrain ve hicles, at least 50% of a manufacture’s fleet was required to meet the new exhaust emissions standard and 100% of the fleet was required to meet the standards in 2007. Recreational marine diesel engines over 37 kilowatts are used in yachts, cruisers and ot her types of pleasure craft. Recreational marine engines contribute to ozone formation and PM 2.5 levels, especially surrounding marinas.

When all of the nonroad spark-ignition engines and recreat ional engine standards are fully implemented, an overall 72% re duction in VOCs, 80% reduction in NO x, and 56% reduction in CO emissions are expected by 2020.

Reciprocating Internal Combustion Engine Standards 5 This new standard, effective in May 2010, re gulates air toxics emissions from existing diesel powered stationary reciprocating inte rnal combustion engine s that meet specific siting, age, and size criteria. These engines ar e typically used at i ndustrial facilities (e.g. power, chemical, and manufacturing plants) to generate electricity for compressors and pumps and to produce electricity to pump water for flood and fire control during emergencies.

The standard applies to stationary diesel engi nes: (1) used at area sources of air toxics emissions and constructed or reconstructed before June 12, 2006; (2) used at major sources of air toxics emissions, having a site rating of less th an or equal to 500 horsepower, and constructed or reconstructed before June 12, 2006; and, (3) used at major sources of air toxics for non-emergenc y purposes, having a site rating of greater than 500 horsepower, and constructed or reconstructed before December 19, 2002.

Operators of existing engines wi ll be required to: (1) insta ll emissions control equipment that would limit air toxics up to 70% for st ationary non-emergency engines with a site rating greater than 300 horsepower; (2) perfor m emissions tests to demonstrate engine performance and compliance with rule requirements; and, (3) bur n ultra-low sulfur fuel in stationary non-emergency engines with a si te rating greater than 300 horsepower.

When all of the reciprocating internal com bustion engine standards are fully implemented in 2013, U.S. EPA estimates that emissions fr om these engines will reduce air toxics by approximately 1,000 tons per year (tpy), PM 2.5 by 2,800 tpy, carbon monoxide by 14,000 tpy, and volatile organic compounds by 27,000 tpy.

5 http://www.epa.gov/ttn/atw/rice/fr03mr10.pdf37 Category 3 Marine Diesel Engine Standards 6 This new standard, effective in June 2010, pr omulgates more stringent exhaust emission standards for new large marine diesel engines with per-cylinder displacement at or above 30 liters (commonly referred to as Category 3 compression-ignition marine engines) as part of a coordinated strategy to address emi ssions from all ships that affect U.S. air quality. These emission standards are equivale nt to those adopted in the amendments to Annex VI to the International Convention for the Prevention of Pollution from Ships (MARPOL Annex VI). The emission sta ndards apply in two stages—near-term standards for newly built engines will a pply beginning in 2011; long-term standards requiring an eighty percen t (80%) reduction in NO X emissions will begin in 2016.

U.S. EPA is adopting changes to the diesel fuel program to allow for the production and sale of diesel fuel with up to 1,000 ppm sulf ur for use in Category 3 marine vessels. The regulations generally forbid pr oduction and sale of fuels with more than 1,000 ppm sulfur for use in most U.S. waters, unless operator s achieve equivalent emission reductions in other ways. U.S. EPA is also adopting pr ovisions to apply some emission and fuel standards to foreign-flagged a nd in-use vessels that are c overed by MARPOL Annex VI.

When this strategy is fully implemen ted in 2030, U.S. EPA estimates that NO x and PM emissions in the U.S. will be reduced by approximately 1.2 million tpy and 143,000 tpy, respectively.

Clean Air Interstate Rule (CAIR) On May 12, 2005, the U.S. EPA promulgated the “Rule to Reduce Interstate Transport of Fine Particulate Matter and Oz one (Clean Air Interstate Rule ); Revisions to Acid Rain Program; Revisions to the NO x SIP Call”; Final Rule. (40 CFR Parts 51, 72, 75 and 96) This rule established the requirement for stat es to adopt rules limiting the emissions of NO x and SO 2 and provided a model rule for the states to use in developing their rules to meet federal requirements. The purpose of CAIR is to reduce interstate transport of precursors to fine particles and ozone.

CAIR applies to: (1) any stati onary fossil-fuel-fired boiler or stationary fossil-fuel-fired combustion turbine, a genera tor with nameplate capacity of more than 25 megawatt electrical (MWe) producing el ectricity for sale; and, (2) a unit that qualifies as a cogeneration unit during the 12-month period starting on the date that the unit first produces electricity and continues to qualify as a cogeneration unit, a cogeneration unit serving at any time a generator with a na meplate capacity of more than 25 MWe and supplying in any calendar year more than one-t hird of the unit’s poten tial electric output capacity or 219,000 MWh (megawatt hours), whic hever is greater to any utility power distribution system for sale.

6 http://www.regulations.gov/search/Regs/ home.html#documentDetai l?R=0900006480ae43a638 This rule provides annual state caps for NO x and SO 2 in two phases, with the Phase I caps for NO x and SO 2 starting in 2009 and 2010, respectively. Phase II caps become effective in 2015. The U.S. EPA is allowing the caps to be met through a cap and trade program if a state chooses to participate in the program.

In response to U.S. EPA’s rulemaking, IDEM adopted a state rule in 2006 based on the model federal rule. IDEM’s rule includes an annual and seasonal NO x trading program and an annual SO 2 trading program. This rule requi res compliance effective January 1, 2009.

On March 10, 2005, the U.S. EPA finalized CAIR. SO 2 emissions from power plants in the 28 eastern states and the District of Columbia covered by CAIR will be cut by 4.3 million tons by 2009 and reduced by an additional 5.4 million tons in 2015. NO x emissions will be cut by 1.7 million tons by 2009 and reduced by an additional 1.3 million tons in 2015. The D.C. Circuit cour t’s vacatur of CAIR in July of 2008 and subsequent remand without vacatur of CAIR in December of 2008 directs U.S. EPA to revise/replace CAIR in order to properly address the deficiencies outlined by the court.

Since the court’s opinion made it clear that CAIR is deficient and must be revised/replaced, the program cannot be defined as permanent and enforceable for SIP purposes. On July 6, 2010, U.S. EPA proposed the Clean Air Transport Rule to replace CAIR. The Transport Rule will result in even further benefits above and beyond CAIR than what is assumed within the emission inventories and modeling.

Together, these rules will substantially reduce local and regional sour ces of fine particle precursors. The modeling analyses discussed in Section 7.0 include thes e rules and show the reductions in annual fine particle concentrations expected to result from the implementation of these rules.

6.5 Controls to Remain in Effect

Indiana commits to maintain the control measur es listed above after redesignation, or submit to U.S. EPA, as a SIP revision, any changes to its rules or emission limits applicable to NO x , SO 2, or direct PM 2.5 sources as required for maintenance of th e annual standard for fine particles in Dearborn County, Indiana.

Indiana, through IDEM’s Office of Air Quality and its Compliance and Enforcement Branch, has the legal authority and necessary resources to act ively enforce any violations of its rules or permit provisions. After redesignati on, it intends to continue enforci ng all rules that relate to the emission of fine particles and fine partic le precursors in Dearborn County, Indiana.

6.6 New Source Review Provisions

Indiana has a long standing and fully implemente d New Source Review (NSR) program that is outlined at 326 IAC 2. The rule includes provisions for the Prevention of Significant Deterioration (PSD) permitting program in 326 IAC 2-2. Indiana's PSD program was39 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 of the SIP.

Any facility that is not listed in the 2005 emission inventory, or for which credit through the shutdown or curtailment was taken in demonstrating attainment, will not be allowed to construct, reopen, modify, or reconstruct without meeting a ll applicable permit rule requirements. The review process will be identical to that used for new sources. Once the area is redesignated, OAQ will implement NSR through the PSD program, wh ich requires an air quality analysis to evaluate whether the new sour ce will threaten the NAAQS.

7.0 MODELING AND METEOROLOGY

Although U.S. EPA Redesignation Guidance does not require modeling for nonattainment areas seeking redesignation, extensive modeling has be en performed covering the Cincinnati, Ohio region to determine the effect of national emission control strategies on fine particle levels. These modeling analyses determined that the Cincinnati area, includ ing Dearborn County in southeastern Indiana is significantly impacted by regional transport of fi ne particles and its precursors, and that regional SO 2 and NO x reductions are an effectiv e way to attain the annual standard for fine particles in th is area. Future year modeled a nnual fine particle concentrations are expected to be reduced by 0.6 to 1.3 μg/m 3 . Examples of these modeling analyses are described below.

7.1 Summary of Modeling Results to Support Rulemakings

U.S. EPA Modeling for Transport Rule, 2010

U.S. EPA performed modeling to support the emission re ductions associated with the Transport Rule. U.S. EPA used Comprehensive Air Qual ity Model with Extension (CAMx, Version 5), applied to the 2005 meteorology, as processed by the Mesoscale Model (MM5), Version 3.7.4. Emissions input into CAMx included SO 2 , NO x , volatile organic compounds (VOC), ammonia, and direct PM 2.5 for 2005. The modeling was based on the annual fine particles design values calculated from 2003 through 2005, 2004 through 2006, and 2005 through 2007. Future year modeling was conducted, which included the Cincinna ti area, and the future year design values for 2012 and 2014 were evaluated for attainment of the annual NAAQS for fine particles of 15 μg/m 3 , as shown in Table 7.1. Fine particle con centrations are accounted for by modeling both the base future year emissions and then the em issions reductions associat ed with the Transport Rule. U.S. EPA found model performance met s uggested benchmark performance goals within or close to the ranges found in other compar able modeling applica tions (Technical Support Document for the Transport Ru le – Air Quality Modeling).

7 http://www.epa.gov/airquality/transp ort/pdfs/TR_AQModeling_TSD.pdf40 Table 7.1 Transport Rule Modeling Results from U.S. EPA – 2010

County Monitor ID Design Value 2003-2007 Future Design Value 2012 Base Future Design Value 2014 Base (μg/m 3 ) (μg/m 3 ) (μg/m 3 ) Butler County 39-017-0016 15.74 15.25 14.76 Butler County 39-017-0017 15.36 14.93 14.48 Butler County 39-017-1004 14.90 14.51 14.06 Hamilton County 39-061-0006 14.84 14.36 13.88 Hamilton County 39-061-0014 17.29 16.69 16.14 Hamilton County 39-061-0040 15.50 15.03 14.51 Hamilton County 39-061-0042 16.85 16.33 15.80 Hamilton County 39-061-0043 15.55 15.05 14.56 Hamilton County 39-061-7001 16.17 15.65 15.12 Hamilton County 39-061-8001 17.54 16.93 16.38 Campbell County 21-037-0003 13.67 13.30 12.81

Kenton County 21-117-0007 14.36 13.98 13.50

Modeling results show that the base future year modeling with emi ssion reductions from the Transport Rule accounts for approximately 0.4 to 0.6 μg/m 3 decreases in concentrations for 2012 and approximately 0.8 to1.2 μg/m 3 decreases in concentrations fo r 2014 in the Cincinnati area.

While results of U.S. EPA’s Transport Rule m odeling show modeled con centrations above the standard using base case emissions at several PM 2.5 monitoring sites in Hamilton County, Ohio, it should be noted that base ye ar design value used by U.S. EPA was taken from 2003 through 2007 and considered higher than current 2005 th rough 2009 design values in the area. Graph 7.1 shows the downward trend of the design values from 1999 through 2009 for the PM 2.5 monitors in the Cincinnati area. The resulting decreases of the 2003 through 2007 design values to the 2005 through 2009 design value at the Murray Road PM 2.5 monitor is 1.75 μg/m 3 , the decrease at the Seymour and Vine Street monitor is 1.27 μg/m 3 and 1.39 μg/m 3 at the West 8 th Street monitor. The results decrease from all the area monitors ranged from 1.05 μg/m 3 to 1.75 μg/m 3

. Therefore, U.S. EPA’s Transport Rule mode ling, using current 2005 through 2009 design values, would show lower modeled concentrations approa ching the annual fine pa rticle standard of 15.0 μg/m 3

.41 Graph 7.1 PM 2.5 Design Value Trends for Cincinnati Area: 1999 - 2009

Results of the U.S. EPA Transport Rule modeling show that the Cincinnati area will approach the annual fine particles NAAQS in 2012 with modeled impacts reduced by 3% to 4%. The 2014 projected design values will decrease by 6% to 7% from the 2003 through 2007 design values. If using current design values, U.S. EPA’s CAIR modeling would show the Cincinnati area would approach the current a nnual fine particles standard.

LADCO Modeling for CAIR

LADCO conducted modeling to determine the imp act of CAIR in the Midwest. LADCO’s modeling used the CAMx model applied to th e year 2005 meteorology, as processed by the MM5. Emissions input into CAMx included SO 2 , NO x , VOC, ammonia, and direct PM 2.5 for 2005. The modeling was based on 2003 through 2007 design values. Future year modeling for 2009, 2012, and 2018 was conducted and the future y ear design values were determined without the emission reductions associated with CAIR (Round 6), as shown in Table 7.2.42 Table 7.2 LADCO’s Round 6 Modeling Result s for the Cincinnati Area

Monitor ID Monitor Name County Design Value 2003-2007 Base-case 2012 Base-case 2018 (μg/m 3 ) (μg/m 3 ) (μg/m 3 ) 390170003 Bonita & St. John Butler 16.0 15.0 14.7 390170016 Nilles Rd Butler 15.7 14.9 14.7 390170017 3300 Wilwood Butler 16.1 15.1 14.9 390171004 Hook Field Airport Butler 14.9 14.0 13.7 390250022 400 Clermont Dr Clermont 14.7 13.8 13.6 390610006 Grooms Rd Hamilton 15.4 14.5 14.3 390610014 Seymour & Vine St Hamilton 17.3 16.3 16.1 390610040 Howard Taft Hamilton 15.5 14.6 14.4 390610041 5300 Winneste Ave Hamilton 15.4 14.7 14.5 390610042 101 W. 8th St Hamilton 16.9 15.9 15.7 390610043 254 Kemper Rd Hamilton 15.5 14.6 14.5 390617001 Sherman Ave Hamilton 16.2 15.2 15.0 390618001 Murray Rd Hamilton 17.5 16.5 16.3 210370003 Alexandria Park Campbell 13.3 13.2 13.0 211170007 University College Kenton 14.4 13.5 13.4

Results of the LADCO Round 6 modeling show that all but five of the fifteen monitors in the Cincinnati area continue to attain the annual NAAQS for fine particles of 15 μg/m 3 in 2012. Modeled concentrations at the five fine partic le monitors, Murray Road, Seymour & Vine Street, Wilwood, Sherman Avenue and West 8 th Street were above the fine particles standard. Table 7.2 shows future year modeled annual fine partic le results without CAIR emission reductions. Concentrations for 2009 will be 5% to 6% lowe r than baseline annual fine particles design values, 6% to 8% lower in 2018. A graphical representation of the modeling results is shown in Graph 7.2. Modeled results for the Cincinnati area would approach the current annual fine particle standard would be lo wer if the current 2005 through 2009 design values, as shown in Graph 7.1, were used.43 Graph 7.2 Modeling Results (without CAIR) for the Cincinnati Area PM 2.5 Monitors

7.2 LADCO’s Round 5 Particulate Source Apportionment Results

Particulate Source Apportionment (PSAT) modeli ng was conducted by LADCO. The results of the PSAT Round 5 modeling shows the regional contributions by emission sectors on each monitor that was modeled. Chart 7.1 shows the PSAT modeling results for the Murray Road fine particles monitor in Hamilton County in southw est Ohio. Ohio was the biggest regional contributor to the Murray Road fine particles monitor with In diana, Kentucky, the Visibility Improvement State and Tribal Association of the Southeast (VISTA S) Regional Planning Organization (Alabama, Florida, Georgia, Kentucky, Mississippi, No rth Carolina, South Carolina, Tennessee, Virginia and West Virginia and the Eastern Band of the Cherokee Indians), the Central Regional Air Planning Associati on (CENRAP) Regional Planning Organization (Nebraska, Kansas, Oklahoma, Texas, Minnesota, Iowa, Missouri, Arkansas, and Louisiana), the Western Regional Air Partne rship (WRAP) Regional Pla nning Organization (Arizona, California, Colorado, Idaho, Nevada, New Mexi co, Oregon, Utah, Wyoming) and Pennsylvania also contributing.

The sector emissions are de scribed as EGU, non-EGU, NH 3 – ammonium emission sources, offroad emission sources includi ng marine, air travel and rail road emission sources, onroad mobile emission sources, area, and boundary conditions.

The PSAT modeling results show the majority of Indiana’s emission sector contributions come from EGUs, ammonium, onroad, offroad (including marine, aircraft and railroad), non-EGU, and area sources. Other contributions resulted mainly from EGU, non-EGU, and ammonium emissions from other regional areas. 12 13 14 15 16 17 18

2003-2007 D.V. 2009 2012 2018Concentratins (ug/m3)

Future Year

Bonita & St. John Nilles Rd 3300 Wilwood Hook Field Airport 400 Clermont Dr Grooms Rd Seymour & Vine St Howard Taft 5300 Winneste Ave 101 W. 8th St 254 Kemper Rd Sherman Ave Murray Rd Alexandria Park University College44 Chart 7.1 Regional/Emission Sector PSAT Result s at Murray Road in Hamilton County

The following pie charts depict the species contribu tions to fine particle concentrations at the Cincinnati area monitors. The pie charts incl ude both the observed 2005 contributions and future year 2009 modeled contributions for each monitor. Since the monitors are in close proximity of each other, results are fairly similar in the di stribution of species concentrations among the monitors. Charts 7.2 through 7.5 cover the three fine particle monitors in southwestern Ohio and one fine particles monitor in northern Kentuc ky with the highest con centrations used to determine compliance with the annu al fine particles NAAQS of 15 μg/m 3

. The speciation listed in the pie charts include SO 4 – sulfate mass, NO 3 – nitrate mass, OC – organic carbon mass, EC – elemental carbon mass, Soil – crustal material mass, NH 4 – ammonium mass, PBW – partic les bound water mass, BLAN – passively collected mass.45 Chart 7.2 Species Modeled Contributions to Murray Road PM 2.5 Monitor

Chart 7.3 Species Modeled Contributions to Seymour & Vine St. PM 2.5 Monitor

Chart 7.4 Species Modeled Contributions to 101 West 8th Street PM 2.5 Monitor Observed 2005 Contributions at Murray Road PM2.5 Monitor

so4 33%

no3 8%

oc 26% ec 4% soil 2% nh4 13% pbw 11% blan 3%

so4

no3

oc

ec
soil

nh4 pbw

blan 2009 Modeled Contributions at Murray Road PM2.5 Monitor

so4 37%

no3 7% oc 22% ec 3% soil 2% nh4 14% pbw 13% blan 2%

so4

no3

oc

ec
soil

nh4 pbw

blan

Observed 2005 Contributions at Seymour & Vine St. PM2.5 Monitor

so4 34%

no3 8%

oc 25% ec 4% soil 2% nh4 13% pbw 11% blan 3%

so4

no3

oc

ec
soil

nh4 pbw

blan 2009 Modeled Contributions at Seymour & Vine St. PM2.5 Monitor

so4 37%

no3 7% oc 22% ec 3% soil 2% nh4 14% pbw 13% blan 2%

so4

no3

oc

ec
soil

nh4 pbw

blan

Observed 2005 Contributions at 101 West 8th St. PM2.5 Monitor

so4 34%

no3 8%

oc 25% ec 4% soil 2% nh4 13% pbw 11% blan 3%

so4

no3

oc

ec
soil

nh4 pbw

blan 2009 Modeled Contributions at the 101 West 8th St. PM2.5 Monitor

so4 39%

no3 6% oc 21% ec 3% soil 2% nh4 14% pbw 13% blan 2%

so4

no3

oc

ec
soil

nh4 pbw

blan46 Chart 7.5 Species Modeled Contributions to University College PM 2.5 Monitor

Results of the Round 5 PSAT modeling for the Cinci nnati area fine particle monitors show the highest pollutant contributors to base case and future year fine particle concentrations are sulfate, organic carbon, ammonium and nitrate. Future year modeling shows decreases in organic carbon, nitrates and elemental carbon . The future year modeling di d show increases in sulfates, particles bound water and a mmonium from the base-cas e modeled concentrations.

7.3 Summary of Existing Modeling Results

U.S. EPA and LADCO modeling for future year design values ha ve consistently shown that existing national emission control measures will he lp the Cincinnati area ap proach attainment of the annual NAAQS for fine part icles standard of 15 μg/m 3 . Emission control measures to be implemented in the next several years will help air quality meet the standard in the future. U.S. EPA future year modeling of national emissi on control strategies, based on current design values, showed the Cincinnati area will approach the annual NAAQS for fine particles. Future national and local emission contro l strategies will ensure that the Cincinnati fine particles nonattainment area will maintain the lo wer fine particle concentrations.

7.4 Meteorological Analysis for Southeastern Indiana

Meteorological conditions are one of the most important factors that influence development and transport of fine particles. Stagnant surface conditions and upper air ridging during any time of the year provides conducive conditions for deve lopment and transport of fine particles. Ultimately, passage of surface cold fronts with a clean air mass ch ange will lower fine particle readings in the Cincinnati area.

7.4.1 Surface Air Conditions Present during Hi gh Fine Particles Concentrations Days

Higher annual concentrations of fine particles tend to correlate with warmer temperatures and lighter wind speeds, although high fine particle ep isodes can occur in the summer fall, winter or spring. It should be noted that hi gher annual fine particle concentr ations are driven by individual days with higher fine particle concentrations throughout the m onitored year. Therefore, it is difficult to attribute higher fine particle concentrations to an nualized meteorological rankings. Review of several of the higher fine particles concentration epis odes (days with concentrations Observed 2005 Contributions at University College PM2.5 Monitor

so4 34%

no3 8%

oc 23% ec 4% soil 3% nh4 13% pbw 11% blan 4%

so4

no3

oc

ec
soil

nh4 pbw

blan 2009 Modeled Contributions at University College PM2.5 Monitor

so4 39%

no3 6% oc 20% ec 3% soil 2% nh4 14% pbw 13% blan 3%

so4

no3

oc

ec
soil

nh4 pbw

blan47 over 35 μg/m 3 ) over the past few years shows conditi ons were hot in the summer with temperatures in the middle 80 o Fahrenheit or higher and averag e wind speeds were fairly light. Fall and winter high fine particles concentrati on days had near normal temperatures but very light wind speeds with higher humidity. Surface condi tions present for higher fine particle days had a high pressure system east of the Cincinnati ar ea with a front located e ither north or west of the area.

Analysis of the Murray Road PM 2.5 monitor data on the higher c oncentration days showed over 60% occurred with maximu m temperatures above 80 o F and only 5% of the high concentration days occurred at maximum temperatures below 40 o F. The location of this monitor is considered downwind of the urban center of Cincinnati so the urban emissions are transported to the monitor. However, surface meteorological conditions would also play a large role in increased fine particle readings at the monitor.

7.4.2 Upper Air Conditions Present during Hi gh Fine Particles Concentrations Days

Upper air ridges and more stagnant surface wind conditions predominately affect development and build up of fine particles. Slow movi ng upper air ridges can effectively suppress mixing within the many levels of the atmosphere and caus e pollutants to build up over time. Inversions or increases in temperature with a rise in al titude will prevent mixing with air from the upper atmosphere. These conditions can occur at any time of the year and are evident in elevated fine particle episodes in spring, summer, fall and winter months. Review of upper air features present during higher concentration days in the Cincinnati area during the summer showed generally a ridge over the area with fairly light winds in th e upper atmosphere and warm air advection. The upper air features present during hi gher concentration days in th e fall and winter were upper air troughs with extremely light winds and moderate temperatures.

Review of surface and upper air feat ures of higher fine particles concentration days showed stagnant surface conditions and upper air ridges exis ted on those days. These conditions help in the buildup of fine particle concen trations in the Cincinnati area.

7.4.3 Analyses of Atmospheric Conditi ons for Fine Particles Build-Up

Analyses have been conducted to determine the atmospheric conditions that are most prevalent during higher fine particles con centration days in Indiana. LA DCO applied a Classification and Regression Tree (CART) analysis to data from Indiana that correla ted different le vels of fine particle concentrations to meteorological condi tions from 1999 through 2004. (Donna Kenski, 2005). This type of analysis looks at the me teorological conditions, such as temperature, pressure, wind speed, wind direction, relative hu midity and dew point temperatures at the surface, as well as lower morning and evening mixing heights in the upper atmosphere which were present when higher concentrations of fine particles were monitored. Results of this CART analysis indicated factors that played a larger role in fine particle concen trations in the southern portion of the Midwest were warm-weather cond itions with high dew points, southwest winds and low evening mixing heights as well as the previ ous day’s concentrations of fine particles.48 Fine particles are made up of severa l constituents, including direct PM 2.5 , sulfates, nitrates, ammonium, organic carbon and elemental car bon. Depending on the time of the year, concentrations of particulate cons tituents vary, with nitrates bei ng more prevalent in the winter and sulfates more prevalent in the summer. Su lfates and nitrate emissi on reductions have the biggest impact on lower future year fine particle concentrations.

7.5 Summary of Air Quality Index Days in Southeastern Indiana

An analysis was conducted to review the daily fine particle concentrations over a year to determine the Air Quality Index (AQI) trends. Chart 7.6 shows by year (2000 through 2009), the percentage number of days during which fine pa rticle concentrations re ached the AQI ranges for “Good” (0 to 15.3 μg/m 3 ), “Moderate” (15.4 μg/m 3 to 40.4 μg/m 3 ) and “Unhealthy for Sensitive Groups (USG)” (40.5 μg/m 3 to 65.4 μg/m 3 ) at the Murray Road PM 2.5 monitor in Hamilton County in Ohio. There were no da ys which the fine particle leve ls reached the “Unhealthy” level of 65.5 μg/m 3 to 150.4 μg/m 3 or above.

Chart 7.6 Distribution of PM 2.5 Concentration Days on the AQI Levels of Health Concern

Table 7.3 shows the rankings, by year, for the th ree AQI ranges. The year 2009 had the most “Good” concentration days during the 10-year period analyzed (2000 through 2009) at 61%. The year 2005 had the most “Moderate” concen trations days at 60% and “Unhealthy for Sensitive Group” concentration days at 8%. As ca n be seen, weather plays a large role in fine particle concentrations development and transport as 2000, 2001, 2004 and 2005 were conducive to PM 2.5 development which translated to moderate and unhealthy for sensitive group levels of air quality over 50% of the time. 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 USG

Moderate
Good49 Table 7.3 Ranking and Percentage of Highest Number of Days at AQI Levels of Health Concern

Ranking Good Moderate Unhealthy for Sensitive Group 1 st 2009 – 61% 2005 – 60% 2005 – 8% 2 nd 2008 – 60% 2000 – 58% 2000 – 7% 3 rd 2006 – 58% 2004 – 52% 2008 – 6% 4 th 2007 – 56% 2001 – 49% 2001 – 5% 5 th 2002 – 51% 2003 – 46% 2003 – 3% 6 th 2003 – 51% 2002 – 45% 2002 – 3% 7 th 2001 – 46% 2007 – 41% 2007 – 3% 8 th 2004 – 46% 2006 – 39% 2006 – 3% 9 th 2000 – 35% 2009 – 39% 2004 – 2% 10 th 2005 – 32% 2008 – 35% 2009 – 0%

7.6 Summary of Meteorological Anal ysis for Southeastern Indiana

Annual fine particle concentrations in the Ci ncinnati area are driven by higher fine particles concentration days that can occur during any ti me of the year. Conditions that are most prevalent during higher fine pa rticle concentration days are lighter winds, higher relative humidity and above average maximum temperat ures in the summer and lighter winds, higher relative humidity and normal temperatures in th e fall, winter or spring. Upper air weather patterns generally include ridging over the area with stagnant c onditions at the surface caused by lower mixing heights and stable conditions for su mmer episodes and ridging or troughs over the area in the fall, winter or spring episodes. Surface winds from any direction can transport pollutants from surrounding areas into the Cincinnati area. Nitrates are bigger contributors to fine particle concentrations in the winter and su lfates are bigger contributors to fine particle concentrations in the summer.

8.0 CORRECTIVE ACTIONS

8.1 Commitment to Revise Plan

As noted in Section 4.6 above, Indiana commits to review and revise as appropriate its Maintenance Plan eight years after redesignation, as require d by Section 175A of the CAA.

8.2 Commitment for Contingency Measures

IDEM will monitor fine particle concentrations to determine whether trends indicate higher values or whether emissions appear to be increasing. If it is determ ined that fine particle levels and emissions are increasing and action is necessary to reverse that trend, IDEM will take action to reverse the noted trend, prior to a violation of th e standard occurring.50 Indiana commits to adopt and expeditiously im plement necessary corrective action in the following circumstance:

Action Level Response

An Action Level Response shall be prompted wh enever a violation of the standard (three year average annual arithmetic mean value of 15.1 μg/m 3 or greater) occurs. In the event that the Action Level is trigge red and is not found to be due to an atypical unfavorable meteorological condition, exceptional event, malfunction or noncompliance with a permit condition or rule requirement, IDEM will determine additiona l control measures needed to assure future attainment of the annual NAAQS for fine particles. In this case, measures that can be implemented in a short tim e will be selected in order to be in place within eighteen months from the close of th e fine particles season that prompted the Action Level.

Control Measure Selection and Implementation

Adoption of any additional control measures is subject to the necessary administrative and legal processes. This pr ocess will include publication of notices, an opportunity for public hearing and other measures require d by Indiana law for rulemaking by state environmental boards.

If a new measure or control is already promulgated and schedul ed to be implemented at the federal or state level, and that measure or contro l is determined to be sufficient to address the upward trend in air quality, additi onal local measures may be unn ecessary. Furthermore, IDEM will submit to U.S. EPA an analysis to demonstrate the proposed measures are adequate to return the area to attainment.

8.3 Contingency Measures

Contingency measures to be considered will be se lected 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 se lection of measures will be based upon costeffectiveness, emission reduction po tential, economic and social c onsiderations, or other factors that IDEM deems appropriate. ID EM will solicit input from intere sted and affected persons in the maintenance area prior to selecting appropria te contingency measures. All of the listed contingency measures are potentially effectiv e or proven methods of obtaining significant reductions of fine particles precursor emissions. Because it is not possible at this time to determine what control measure will be appropriate at an unspecified time in the future, the list of contingency measures outlined below is not comprehensive. IDEM anticipates that if contingency measures should ever be necessary, it is unlikely th at a significant number (i.e., all those listed below) will be required.

1) Vehicle inspection an d maintenance program. 2) Alternative fuel and diesel retrofit programs for fleet vehicle operations. 3) Require NO x or SO 2 emission offsets for new and modified major sources.51 4) Require NO x or SO 2 emission offsets for new a nd modified minor sources. 5) Increase the ratio of emission of fsets required for new sources. 6) Require NO x or SO 2 controls on new minor sour ces (less than 100 tons). 7) Wood stove change-out program. 8) Require increased recovery effici ency at sulfur recovery plants. 9) Various emissions reduction measures or dus t suppressant for unpaved roads and/or parking lots. 10) Idling Restrictions. 11) Broader geographic applicab ility of existing measures. 12) One or more transportation co ntrol measures sufficient to achie ve at least a half a percent (0.5%) reduction in actual area-wide precursor emissions. Transportation measures will be selected from the following, based upon the f actors listed above, af ter consultation with affected local governments: a) Trip reduction programs, including, but not limited to, employer-based transportation management plans, area wide rideshare programs, work schedule changes and telecommuting. b) Transit improvements. c) Traffic flow improvements. d) Other new or innovative transportation measur es not yet in widespread use that affect state and local governments deemed appropriate.

No contingency measure shall be implemented w ithout providing the opportunity for full public participation during which the relative costs and be nefits of individual meas ures, at the time they are under consideration, can be fully evaluated.

9.0 PUBLIC PARTICIPATION

Indiana published notification for a public hearing and soli citation for public comment concerning the draft Redesignation Petition a nd Maintenance Plan in the Dearborn County Register on November 18, 2010.

A public hearing to receive comments concerni ng the redesignation re quest was conducted on January 5, 2011 at the Lawrenceburg Public Li brary in Lawrenceburg, Indiana. During the public comment period IDEM received minor t echnical updates from the Ohio Environmental Protection Agency (Ohio EPA) that included an updated Mobile Source Emissions Inventory. No other comments were received during the comment period. The public comment period closed on January 7, 2011. Appendix J includes a copy of the public noti ce, certifications of publication, the transcript from the public hear ing, and a summary of the minor technical updates received from Ohio EPA.

10.0 CONCLUSIONS

Lawrenceburg Township, Dearborn County, Indiana, has attained the annual NAAQS for fine particles and does not significantl y contribute to violations outs ide its portion of the Cincinnati-52 Hamilton OH-KY-IN nonattainment area. This petition demonstrates that Lawrenceburg Township, Dearborn County, Indiana, has complied with the applicable provisions of the CAA regarding redesignation of nonattainment areas for fine partic les. IDEM has prepared a State Implementation and Maintenance Plan that meet s the requirement of S ection 110(a)(1) of the CAA.

Indiana has performed an analysis that shows the air quality imp rovements are due to permanent and enforceable measures and that additional significant regional NO x and SO 2 reductions following implementation of Phase II NO x SIP Call and CAIR and/or its replacement rule or program will ensure continued compliance (maint enance) with the standard. Furthermore, emission projections indicate that NO x and SO 2 emissions will continue to decline, thus ensuring that the area continues to maintain compliance with the standard and provide for an increasing margin of safety. Based on this presenta tion, Lawrenceburg Township, Dearborn County, Indiana, meets the requirements for redesign ation under the CAA (Secti on 107(d)(3)) and U.S. EPA guidance for fine particles.

Consistent with the authority granted to the U.S. EPA, the State of Indiana requests that Lawrenceburg Township, Dearborn County, Indiana, be redesignated to attainment for the annual fine particles standard simultaneously with U.S. EPA approval of this Indiana State Implementation and Maintenance Pl an provisions contained herein.