1

---------------------------------------------------------------------------------------------- ----------------------------- Technical Support Document (TSD)

Indiana Area Designations For the

2010 SO 2 Primary National Ambient Air Quality Standard

Summary

Pursuant to section 107(d) of the Clean Air Act (CAA), EPA must designate areas as either

“ nonattainment, ” “attainment

, ” or “ unclassifiable ” for the 2010 one

- hour sulfur dioxide (SO 2 ) primary national ambient air quality standard (NAAQS)

. The CAA defines a nonattainment area as one that does not meet the NAAQS or that contributes to poor air quality in a nearby area that does not meet the NAAQS. Table 1 below identifies the counties or portions of counties (or tribal areas) in Indiana that

EPA inte nds to designate “nonattainment” for the primary 2010 SO 2 NAAQS.

Indiana submitted designation recommendations on May 11, 2011 with supplemental

r ecommendations on January 6, 2012 and April 26, 2012. On February 6, 2013, EPA sent a letter with

intended d esignations for Indiana. Indiana responded with March 11, 2013 and March 28, 2013

recommendations. Table 1 below lists Indiana’s final recommendations and identifies the counties or portions of counties in Indiana that EPA is initially designating “nonattainment” based on monitored

violations . EPA is not yet prepared to designate other areas in Indiana, and will address such areas and their sources in a subsequent round of final designations.

Table 1. Nonattainment Area Designation s for Indiana

Area Indiana’s Recommended Designation of Areas/Counties EPA’s Nonattainment Designation of Areas/Counties Indianapolis, IN Marion County (partial)

- Wayne, Center and Perry Townships Nonattainment Nonattainment

Morgan County, IN Morgan County (partial)

- Clay and Washington Townships Nonattainment Nonattainment

Southwest Indiana, IN Daviess County (partial)

- Veale Township Pike County (partial)

- Washington Township Nonattainment

Nonattainment Nonattainment

Nonattainment

Terre Haute, IN Vigo County (partial)

- Fayette and Harrison Township Nonattainment Nonattainment

Background

On June 3 , 2010, EPA revised the primary SO 2 NAAQS (75 FR 35520, June 22, 2010) by establishing

a new 1

- hour standard at a level of 75 parts per billion (ppb)

, which is met at an ambient air quality monitoring site when the 3

- year average of the annual 99 th percentile of the daily maximum 1

- hour

ave rage concentration at each monitor in an area does not exceed 75 ppb , as determined in accordance with Appendix T of 40 CFR part 50. 40 CFR 50.17(a)

- (b). EPA has determined that this is the level necessary to provide protection of public health with an a dequate margin of safety, especially for2

children, the elderly and those with asthma. These groups are particularly susceptible to the health effects associated with breathing SO 2 . The Agency is revoking the two prior primary standards of 140 ppb evaluat ed over 24

- hours, and 30 ppb evaluated over an entire year because the standards will not add additional public health protection given a 1

- hour standard at 75 ppb. Accordingly, EPA is not designating areas in this process on the basis of either of these two prior primary standards. Similarly, the secondary standard for SO 2 has not been revised, so EPA is not designating areas in this process on the basis of the secondary standard.

EPA’s SO 2 Designation Approach

Section 107(d) of the CAA provides that not later than 1 year after promulgation of a new or revised NAAQS, state Governors may submit their recommendations for designations and boundaries to EPA

. For the 2010 SO 2 NAAQS, this deadline was June 3, 2011. Section 107(d) also requires EPA to provide a notification to states of no less than 120

- days prior to promulgating an initial area designation that is a modification of a state’s recommendation. EPA has reviewed the State’s recommendations and has notified the State Commissioner through letter signed by the Regional Administrator of any intended modifications. [While language in section 107 specifically addresses states, we intend to follow the same process for tribes, pursuant to section 301(d) of the CAA and Tribal Authority Rule (40 C FR Part 49). Therefore, we intend to designate tribal areas, in consultation with the tribes, on the same schedule as state designations.] If a State or Tribe did not submit designation recommendations, EPA is to promulgate the designations that it deems appropriate. If a state or tribal government disagrees with EPA’s intended area designations, it had an opportunity to demonstrate why any proposed modification is inappropriate.

Designations guidance was issued by EPA through a March 24, 2011, memoran dum from Stephen D. Page, Director, U.S. EPA, Office of Air Quality Planning and Standards, to Air Division Directors, U.S. EPA Regions I

- X. This memorandum identifies factors EPA intends to evaluate in determining boundaries for areas designated nonattai nment. These 5 factors include: 1) Air quality data; 2)

Emissions and emissions

- related data (location of sources and potential contribution to ambient SO 2 concentrations); 3) Meteorology (weather/transport patterns); 4) Geography/topography (mountain

ra nges or other air basin boundaries); and 5) Jurisdictional boundaries (e.g., counties, air districts, pre

existing nonattainment areas, reservations, metropolitan planning organization), among any other information deemed relevant to establishing appropria te area designations and boundaries for the 1

- hour SO 2 NAAQS.

The March 24, 2011, designations guidance memo recommended that area boundaries be defaulted to the county boundary unless additional provided information justifies a larger or smaller boundary than that of the county. EPA believes it is appropriate to evaluate each potential area on a case

- by

- case basis, and to recognize that area

- specific analyses conducted by states, tribes and/or EPA may support a different boundary than a default county bo undary.

In this TSD, EPA discusses its review and technical analysis of the recommendations submitted by

Indiana for designations of the 1

- hour SO 2 standard and any modifications from these

recommendations.

Definition of important terms used in this document:3

1) Designated nonattainment area

– an area which EPA has determined, based on a state recommendation and/or on the technical analysis included in this document, has violated the 2010 SO 2 NAAQS, based on the most recent three years of air quality monitoring data from 2009

- 2011, or contributes to a violation in a nearby area.

2 ) Recommended nonattainment area

– an area that a s tate or tribal government has recommended to EPA to be designated as nonattainment.

3 ) Violating monitor

– an ambient a ir monitor meeting all methods, quality assurance and citing criteria and requirements whose valid design value exceeds 75 ppb, as described in Appendix T of 40 CFR part 50.

4 ) 2010 SO 2 NAAQS

- 75 ppb, national ambient air quality standard for SO 2 promulgated in 2010.

Based on the 3

- year average of the 99 th percentile of the annual distribution of daily maximum 1

- hour average concentrations

5 ) Design Value

– a statistic computed according to the data handling procedures of the NAAQS (in

40 CFR 5 0 Appendix T) that , by comparison to the level of the NAAQS , indicates whether the area is violating the NAAQS

.

Technical analysis for the Indianapolis , IN Area

Introduction

This technical analysis for the Indianapolis , IN Area identifies Marion County with a monitor that

violate s the 2010 SO 2 NAAQS

, and evaluates nearby counties for contributions to SO 2 concentrations

in the area. EPA has evaluated this county and nearby counties based on a review of the evidence for

the factors recommended in t he March 24, 2011 EPA designations guidance

.

Figure 1 is a map of the area showing the locations and design values of air quality monitors in the area, and the counties surrounding any violating air quality monitors.4

Figure 1. Map of Indianapolis , IN area sources and monitors

For the Indianapolis , IN area, Indiana recommended that a portion of Marion County consisting of Center, Perry, and Wayne Townships be designated nonattainment.

Based on EPA's technical analysis described below, EPA agrees with the State’s recommendation.
Thus, EPA is initially designating the three recommended townships in Marion C ount y in Indiana as nonattainment for the 2 010 SO 2 NAAQS to define the Indianapolis nonattainment area. Areas and

sources that we are no t prepared to conclude are contributing to the monitored violations or to possible

other violations are not included in this initial nonattainment area. Such areas and sources will be further addressed in a subsequent round of final designations.

Detaile d Assessment

Air Quality Data

This factor considers the SO 2 air quality monitoring data, including the design values (in ppb )

calculated for all air quality monitors in Marion C ount y in the Indianapolis area and the surrounding

area based on data for the 2009 to 2011 period

.

The 2010 SO 2 NAAQS design value s for Marion County, Indiana in the Indianapolis , IN area is shown

in Table 2

.5

Table 2 . Air Quality Data for Monitors in Marion County
County State Recommended

Nonattainment? Monitor Air Quality System ID Monitor Location SO 2 Design Value,

2009

- 2011 ( ppb )

Marion Yes 18

- 097

- 0057 39.749,

- 86.1836 8 0

Marion No 18

- 097

- 0073 39.7895,

- 86.0608 56

Marion No 18

- 097

- 0078 39.8111,

- 86.1145 40 *

* Data are inc o mplete.

Monitor in Bold has the highest 200 9

- 2011 design value in the respective county.

Center Township in Marion County show s a monitored violation of the 2010 SO 2 NAAQS. Therefore

, some area in th is count y and possibly additional areas in surrounding counties must be designated

nonattainment

. The absence of a violating monitor alone is not a sufficient reason to eliminate nearby

counties as candidates for nonattainment status. Each area has been evaluated based on the evidence

for the five factors and other relevant information.

Emissions and Emissions

- Related Data

Evidence of SO 2 emissions sources in the vicinity of a violating monitor is an important factor for determining whether a nearby area is contributing to a monitored violation. For this factor, EPA evaluated county level emission data for SO 2 and any growth in SO 2 emitti ng activities since the date represented by those emissions data

.

Emissions

EPA recognize s that there might be no new information on any changes in emissions that may have

occurred after 2008, but would consider more recent years if available

. Indiana did not provide updated emissions information, therefore EPA relied on the 2008 N ational E missions I nventory (NEI)

emissions data ( NEI08V3 ).

Table 3 shows total emissions of SO 2 (given in tons per year) for violating and potentially contributing

counti es in and around the Indianapolis area and sources emitting greater than 100 ton s per year of SO 2 according to the 2008 NEI.

Table 3 . SO 2 Emission s ( NEI08 V3 )
County Facility Located in

State

Recommended

Nonattainment Area? Facility

– Total SO 2 Air

Emissions NEI08V3 (tons per year) Facility Location Total County

SO 2 Emissions (tons per year)

Marion, IN Yes IPL Harding Street Station

19,578 39.7119,

- 86.1975 26,544

Yes C C Perry K Steam Plant

4,493 39.7622,

- 86.1667

Yes Rolls

- Royce Corporation

Plant 5 & 8

- 142 39.7245,

- 86.2696

Yes Covanta Indianapolis Inc

110 39.7337,

- 86.1888

Partial Indianapolis Intl Airport

102 39.7066,

- 86.321

The four sources that are fully in the nonattainment area recommended by the s tate are relatively near

the violating monitor. The Indianapolis International Airport has relatively low emissions and is6

located approximately 13 kilometers from the violating monitor

. However, Indiana recommended

boundaries for administrative convenie nce that include some but not all of this airport

.

Emissions Controls

The emissions data used by EPA in this technical analysis and provided in Table 3 represent emissions levels taking into account any control strategies implemented on stationary sources in the Indianapolis area up to and including 2008. EPA has not received any additional information on emissions reductions resulting from controls put into place after 2008.

Meteorology (weather/transport patterns)

Evidence of source

- receptor relationships between specific emissions sources and high SO 2 values at violating monitors is another important factor in determining the appropriate contributing areas and the appropriate extent of the nonattainment area. Figure 2 shows the prevalent wind direction for the Indianapolis area.

Figure 2: Wind Rose for Indianapolis, IN

Source: IDNR Software: WRPLOT

- Lakes Environmental Software

The wind rose above shows that winds are most likely to come from the southwest but occasionally

come from the northeast and other directions. This shows that a source from any direction could

contribute to the violation at the monitor. The wind blows mo re frequently from the IPL Harding Street Station southwest of the monitor, but also blows past the C C Perry K Steam Plant to the

northeast.7

Geography/topography (mountain ranges or other air basin boundaries)

The Indianapolis area does not have any g eographical or topographical barriers significantly limiting

air

- pol lution transport within its air shed. Therefore, this factor did not play a significant role in determining the nonattainment boundary.

Jurisdictional boundaries Once the geographic area associated with the area violating the SO 2 standard and the nearby areas contributing to the violations are determined, we considered existing jurisdictional boundaries for the purpose of providing a clearly defined legal boundary for carrying out the air quality planning and

enforcement functions of the area. Indiana did not have any nonattainment areas under the prior SO 2 NAAQS . EPA finds that county or township boundaries in Indiana provide a suitable administrative basis for formulating nonattainment area boundaries.

Other Relevant Information

EPA did not receive additional information relevant to establishing a nonattainment area boundary for

this area.

Conclusion

After considering the factors described above, EPA is initially designating , based on monitored violations, Wayne, Center

, and Perry Townships in Marion County as the Indianapolis , IN

nonattainment area for the 2010 SO 2 NAAQS

. An air quality monitor in Ce nter Township within Marion County shows a violation of the 20 10 SO 2 NAAQS, based on 2009 to 2011 air quality data

. EPA finds these three townships include the sources that contribute to this monitored violation

. Based

on the consideration of all the relevant and available information, as described above, EPA believes that the boundaries described herein encompass the appropriate initial nonattainment area addressing

t h e monitored violation

. EPA is not ready to conclude that the emissions from sources located outside the boundary recommended by Indiana contribute to the monitored violation or to other possible

violations . In a subsequent round of designations, we will make final initial designation decisions for

areas in Indiana not included in the nona ttainment area designations addressed in this TSD.

Technical analysis for Morgan County , IN

Introduction

This technical analysis for Morgan County , IN identifies Morgan C ount y with a monitor that violate s the 2010 SO 2 NAAQS

, and evaluates nearby counties for contributions to SO 2 concentrations in the

area. EPA has evaluated this county and nearby counties based on the evidence for the factors

recommended in the March 24, 2011 EPA designations guidance

.

Figure 3 is a map of the area showing the locations and design values of air quality monitors in the area, and the counties surrounding any violating air quality monitors.8

Figure 3. Map of Morgan County , IN area sources and monitors

For the Morgan County , IN area, Indiana recommended that a portion of Morgan County consisting of Clay and Washington Townships be designated nonattainment.

Based on EPA's technical analysis described below, EPA agrees with the State’s recommendation for

the Morgan County nonattainment area, based upon currently available information. Thus, EPA is initially designating the recommended townships as nonattainment for the 2010 SO 2 NAAQS as the Morgan County, IN area. These townships are listed above in Table 1

. Areas and sourc es that we are not prepared to conclude are contributing to the monitored violations are not included in this initial

nonattainment area , and will be addressed in a subsequent round of final designations

.

Detailed Assessment

Air Quality Data

This factor considers the SO 2 air quality monitoring data, including the design values (in ppb )

calculated for all air quality monitors in Morgan C ount y in the Morgan County area and the surrounding area based on data for the 200 9 to 20 1 1 period

.

The 2010 SO 2 NAAQS design values for Morgan County, Indiana in the Morgan County area are shown in Table 4

.9

Table 4 . Air Quality Data for Nonattainment Designations in Morgan County
County State Recommended

Nonattainment? Monitor Air Quality System ID Monitor Location SO 2 Design Value,

200 9

- 20 1 1 ( ppb ) Morgan Yes 18

- 109

- 1001 39.515,

- 86.3917 100
Monitors in Bold have the highest 2009 to 2011 design value in the respective county.

Clay Township in Morgan County shows a violation of the 2010 SO 2 NAAQS. Therefore

, some area in this county and possibly additional areas in surrounding counties must be designated nonattainment

. The absence of a violating monitor alone is not a sufficient reason to eliminate nearby counties as

candidates for nonatta inment status.

Emissions and Emissions

- Related Data

Evidence of SO 2 emissions sources in the vicinity of a violating monitor is an important factor for determining whether a nearby area is contributing to a monitored violation. For this factor, EPA evaluated county level emission data for SO 2 and any growth in SO 2 emitting activities since the date represented by those emissions data

.

Emissions

EPA recognize s that there might be no new information on any changes in emissions t hat may have

occurred after 2008, but would consider more recent years if available

. Indiana did not provide updated emissions information, therefore EPA relied on the 2008 N ational E missions I nventory (NEI)

emissions data ( NEI08V3 ).

Table 5 shows total emissions of SO 2 (given in tons per year) for violating and potentially contributing

counties in and around the Morgan County area and sources emitting greater than 100 ton s per year of

SO 2 according to the 2008 NEI.

Table 5 . SO2 Emissio n s ( NEI08V3 )
County Facility Located in

State

Recommended

Nonattainment Area ? Facility

– Total SO 2 Air

Emissions NEI0 8 V3 (tons per year) Facility Location Total County

SO 2 Emissions (tons per year)

Morgan, IN Yes IPALCO

- Pritchard Station

13,102 39.4867,

- 86.4165 13,819

Yes Hydraulic Press Brick Co.

- 515 39.538744,

- 86.370648

Emissions Controls

The emissions data used by EPA in this technical analysis and provided in Table 5 represent emissions levels taking into account any control strategies implemented on stationary sources in the Morgan County area up to and including 2008. EPA has not received any additional information on emissions reductions resulting from controls pu t into place after 2008.10

Meteorology (weather/transport patterns)

Evidence of source

- receptor relationships between specific emissions sources and high SO 2 values at violating monitors is another important factor in determining the appropriate contributing areas and the appropriate extent of the nonattainment area. Due to the proximity of the areas, the wind rose in Figure 2 for the Indianapolis Area is sti ll an appropriate representation of the wind patterns for the Morgan County Area. Therefore, given that the wind is likely from any direction, the wind is most frequently from the southwest near the IPALCO

- Pritchard Station, but is still possible from th e northeast past the Hydraulic Press Brick Company.

Geography/topography (mountain ranges or other air basin boundaries)

The Morgan County area does not have any geographical or topographical barriers significantly limiting air

- pol lution transport within its air shed. Therefore, this factor did not play a significant role

in determining the nonattainment boundary.

Jurisdictional boundaries

Once the geographic area associated with the area violating the SO 2 standard and the nearby areas contributing to the violations are determined, we considered existing jurisdictional boundaries for the purpose of providing a clearly defined legal boundary for carrying out the air quality planning and

enforcement functions of the area. Indiana did not have any nonattainment areas under the prior SO 2 NAAQS standard. EPA finds that county and township boundaries are a suitable administrative basis for defining a nonattainment area.

Other Relevant Information

EPA did not receive additional information relevant to establishing a nonattainment area boundary for

this area.

Conclusion

After considering the factors described above, EPA is initially designating Clay and Washington Townships within Morgan County (as listed in Table 1) to comprise the Morgan County , IN

nonattainment area for the 2010 SO 2 NAAQS , based on a monitored violation in the county.

The air quality monitor in Morgan County shows a violation of the 20 10 SO 2 NAAQS, based on 200 9

to 2011 air quality data

. EPA finds these two townships include the sources that contribute to this

monitored violation

. Based on the consideration of all the relevant and available information, as described above, E PA believes that the boundaries described herein encompass the appropriate initial

nonattainment area for the 20 10 SO 2 NAAQS. EPA is not ready to conclude that the emissions from

sources located outside this boundary contribute to the monitored violation o r to other possible

violations . In a subsequent round of designations, we will make final initial designation decisions for areas in Indiana not included in the nonattainment area designations addressed in this TSD.11 T echnical ana lysis for Southw est Indiana

, IN

Introduction

This technical analysis for Southw est Indiana

, IN identifies Daviess and Pike C ount ies with monitor s that violate the 2010 SO 2 NAAQS

, and evaluates nearby counties for contributions to SO 2 concentrations in the area. EPA has evaluated this county and nearby counties based on the evidence

for the factors recommended in the March 24, 2011 EPA designations guidance

.

Figure 4 is a map of the area analyzed showing the locations and design values of air quality monitors

in the area, and the counties surrounding any violating air quality monitors.

Figure 4 . Map of Southwest Indiana area sources and monitors

For the Southwest Indiana , IN area, Indiana recommended that Veale Township within Daviess County and Washington Township within Pike County be designated nonattainment.

Based on EPA's technical analysis described below, EPA agrees with the s tate’s recommendation for

the boundaries of the Morgan County nonattainment area for the 2 010 SO 2 NAAQS

. Thus, EPA is initially designating the two recommended townships in Morgan C ount y as nonattainment for the 2 010

SO 2 NAAQS to define the Morgan County, IN nonattainment area. The townships included in the

nonattainment area are listed above in Table 1. Are as and sources that we are not yet prepared to conclude are contributing to the monitored violations are not included in this initial nonattainment

area , and will be addressed in a subsequent round of final designations

.12

Detailed Assessment

Air Quality Data

This factor considers the SO 2 air quality monitoring data, including the design values (in ppb )

calculated for all air quality monitors in Daviess and Pike counties in the Southwest Indiana area and the surrounding area based on data for the 2009 to 2011 period

.

The 2010 SO 2 NAAQS design values for Daviess and Pike C ount ies , Indiana in the Southw est Indiana

area are shown in Table 6

.

Table 6 . Air Quality Data for Nonattainment Designations in Southwest Indiana
County State Recommended

Nonattainment? Monitor Air Quality System ID Monitor Location SO 2 Design Value,

2009

- 2011 (ppb)

Daviess Yes 180270002 38.5728,

- 87.2147 118

Pike Yes 181250005 38.5192,

- 87.2497 175
Monitors in Bold have the highest 2009 to 2011 design value in the respective county.

Veale Township within Daviess County and Washington Township within Pike County show

monitored violation s of the 2010 SO 2 NAAQS. Therefore

, some area in these counties and possibly additional areas in surrounding c ounties must be designated nonattainment

. The absence of a violating

monitor alone is not a sufficient reason to eliminate nearby counties as candidates for nonattainment

status.

Emissions and Emissions

- Related Data

Evidence of SO 2 emissions sources in the vicinity of a violating monitor is an important factor for determining whether a nearby area is contributing to a monitored violation. For this factor, EPA evaluated county level emission data for SO 2 and any growth in SO 2 emitting activities since the date represented by those emissions data

.

Emissions

EPA recognize s that there might be no new information on any changes in emissions that may have

occurred after 2008, but would consider more recent years if available

. I ndiana did not provide updated emissions information, therefore EPA relied on the 2008 N ational E missions I nventory (NEI)

emissions data ( NEI08V3 ).

Table 7 shows total emissions of SO 2 (given in tons per year) for violating and potentially contributing

counties in and around the Southw est Indiana area and sources emitting greater than 100 ton s per year of SO 2 according to the 2008 NEI. T he counties that contain the Southwest Indiana n onattainment

area for the 2010 SO 2 NAAQS are shown in bold

. Both sources in Pike County are located in Washington Township.13

Table 7 . SO2 Emission s ( NEI08V3 )

County Facility Located in State

Recommended

Nonattainment Area ? Facility

– Total SO 2 Air

Emissions NEI08V3 (tons per year) Facility Location Total County

SO 2 Emissions (tons per year)

Pike Yes Hoosier Energy

- Ratts

Station

- 27,334 38.5183,

- 87.2722 49,846

Yes IPL Petersburg Generating

Station

- 22,494 38.5267,

- 87.2525

Daviess None 142

Emissions Controls

The emissions data used by EPA in this technical analysis and provided in Table 7 represent emissions levels taking into account any control strategies implemented on stationary sources in the Southwest Indiana area up to and including 2008. EPA has not received any additional information on emissions reductions resulting from controls put into place after 2008.

Meteorology (weather/transport patterns)

Evidence of source

- receptor relationships between specific emissions sources and high SO 2 values at violating monitors is another important factor in determining the appropriate contributing areas and the appropriate extent of the nonattainment area. Below , in Figure 5, is a wind rose depicting the wind patterns for Southwest Indiana. The wind data is based out of Evansville, Indiana, which is not in the nonattainment area, but has close enough proximity to show representative data for the southwest

Indiana Area.

Figu re 5 : Wind Rose for Southwest Indiana

Source: IDNR Software: WRPLOT

- Lakes Environmental Software14

Figure 5 shows that winds are most prevalent from the south to southwest, northwest, and northeast.
However, wind appears likely from any direction. The refore, both sources are likely to contribute to

both violating monitors despite varied proximity.

Geography/topography (mountain ranges or other air basin boundaries)

The Southwest Indiana area does not have any geographical or topographical barriers significantly limiting air

- pol lution transport within its air shed. Therefore, this factor did not play a significant role

in determining the nonattainment boundary.

Jurisdictional boundaries

Onc e the geographic area associated with the area violating the SO 2 standard and the nearby areas contributing to the violations are determined, we considered existing jurisdictional boundaries for the purpose of providing a clearly defined legal boundary for carrying out the air quality planning and

enforcement functions of the area. Indiana did not have any nonattainment areas under the prior SO 2 NAAQS. EPA finds that township and county boundaries provide a suitable administrative basis for defining a nonattainment area.

Other Relevant Information

EPA did not rece ive additional information relevant to establishing a nonattainment area boundary for

this area.

Conclusion

After considering the factors described above, EPA is initially designating Veale Township with in

Daviess County and Washington Township within Pi ke C ounty as the Southwest Indiana , IN

nonattainment area for the 2010 SO 2 NAAQS

.

The air quality monitor s in Veale Township within Daviess County and Washington Township within Pike County show violation s of the 20 10 SO 2 NAAQS, based on 2009 to 2011 air quality data

. EPA finds Washington Township in Pike County include the sources that contribute to this monitored

violation

. Based on the consideration of all the relevant and available information, as described above,

EPA is initially designating th ese two townships nonattainment for the 20 10 SO 2 NAAQS. EPA is not ready to conclude that the emissions from sources located outside the boundary recommended by

Indiana contribute to the monitored violation or to other possible violations . In a subsequent round of designations, we will make final initial designation decisions for areas in Indiana not included in the nonattainment area designations addressed in this TSD.15 Technical analysis for Terre Haute

, IN

Introduction

This technical analysis for Terre Haute

, IN identifies Vigo County with monitor s that violate the 2010

SO 2 NAAQS and evaluates nearby counties for contributions to SO 2 concentrations in the area. EPA

has evaluated this county and nearby counties based on the evidence for the factors recommended in the March 24, 2011 EPA designation s guidance

.

Figure 6 is a map of the area showing the locations and design values of air quality monitors in the area, and the counties surrounding any violating air quality monitors.

Figure 6. Map of Terre Haute , IN area sources and monitors

For the Terre Haute , IN area, Indiana initially recommended that a portion of Vigo County consisting of Harrison Township be designated nonattainment. In EPA’s February 6, 2013 letter, EPA stated the intention to designate Fayette and Otter Creek Townships in addition to Harrison Township. Indiana responded in a March 11, 2013 letter stating that Indiana agrees with the inclusion of Fayette Township t o encompass the PSI Energy’s Wabash River plant, but does not agree with the inclusion of

Otter Creek Township for continuity purposes because there are no sources and low population. EPA agrees with the assessment of Otter Creek Township and is not inclu ding that township in the area initially being designated nonattainment.

Based on EPA's technical analysis described below, EPA is initially designating Harrison and Fayette townships in Vigo County in Indiana as nonattainment for the 2 010 SO 2 NAAQS as the Terre Haute

n onattainment a rea, based upon currently available information. These townships are listed above in16

Table 1

. Areas and sources that we are not prepared to conclude are contributing to the monitored

violations are not included in this initial nonattainment area , and will be addressed in a subsequent round of final designations

.

Detailed Assessment

Air Quality Data

This factor considers the SO 2 air quality monitoring data, including the design values (in ppb )

calculated for all air quality monitors in Vigo County in the Terre Haute , IN Area and the surround ing

area based on data for the 2009 to 2011 period

.

T he 2010 SO 2 NAAQS design values for county in the Terre Haute area is shown in Table 8

.

Table 8 . Air Quality Data for Nonattainment Designations in Vigo County, Indiana
County State Recommended

Nonattainment? Monitor Air Quality System ID Monitor Location SO 2 Design Value,

2009

- 2011 ( ppb ) Vigo, IN Yes 181671014 39.5147,

- 87.4078 150

Yes 181670018 39.4861,

- 87.4014 90

Monitor in Bold ha s the highest 2009

- 2011 design value in the county.

Fayette Township in Vigo County show s monitored violation s of the 2010 SO 2 NAAQS. Therefore

, some area in this county and possibly additional areas in surrounding counties must be designated

nonattainment

. The absence of a violating monitor alone is not a sufficient reason to eliminate nearby

counties as candi dates for nonattainment status.

Emissions and Emissions

- Related Data

Evidence of SO 2 emissions sources in the vicinity of a violating monitor is an important factor for determining whether a nearby area is contributing to a monitored violation. For th is factor, EPA evaluated county level emission data for SO 2 and any growth in SO 2 emitting activities since the date represented by those emissions data

.

Emissions

EPA recognize s that there might be no new information on any changes in emissions that may have

occurred after 2008, but would consider more recent years if available

. Indiana did not provide updated emissions information, therefore EPA relied on the 2008 N ational E missions I nventory (NEI)

emissions data ( NEI08V3 ).

Table 9 shows total emissions of SO 2 (given in tons per year) for the violating and contributing count y in and around the Terre Haute Area and sources emitting greater than 100 ton s per year of SO 2 according to the 2008 NEI

. The county that contain s all of the Terre Haute no nattainment area for the

2010 SO 2 NAAQS is shown in bold

.17

Table 9 . SO2 Emissions NEI0 8 V3
County Facility Located in

State Recommended

N A Area ? Facility

– Total SO 2 Air

Emissions NEI08V3 (tons per year) Facility Location Total County

SO 2 Emissions (tons per year) Vigo, IN Yes PSI Energy

- Wabash River

75,823 39.53,

- 87.4247 78,287

Yes International Paper Co

- 1,215 39.4408,

- 87.42295

Yes W abash R iver C ombined C ycle

P lant

- 414 39.530785

, - 87.424787

No Danisco Sweeteners

- 370 39.361448

, - 87.413742

The most significant source in the area, the PSI Energy

– Wabash River facility, is located in Fayette Township, just northwest of Harrison Township. Considering the meteorology of the area, discussed below, t his facility clearly contributes to the violation in Vigo County and must be included in the

nonattainment area.

Emissions Controls

The emissions data used by EPA in this technical analysis and provided in Table 9 represent emissions levels taking into account any control strategies implemented on stationary sources in the Terre Haute area up to and including 2008. EPA has not received any additional information on emissions reductions resulting from controls put into place after 2008.

Meteorology (weather/transport patterns)

Evidence of source

- receptor relationships between specific emissions sources and high SO 2 values at violating monitors is another important factor in determining the appropriate contributing areas and the appropriate extent of the nonattainment area. Due to the proximity of the areas, the wind rose in Figure 2 for the Indianapolis Area is als o an appropriate representation of the wind patterns for the Terre Haute, IN Area. Therefore, given that the wind is likely from any direction, the wind is most frequently from the southwest near the International Paper Co, but is still possible from the northwest past the larger emitter, PSI Energy

- Wabash River.

Geography/topography (mountain ranges or other air basin boundaries)

The Terre Haute Area does not have any geographical or topographical barriers significantly limiting

air

- pol lution transp ort within its air shed. Therefore, this factor did not play a significant role in determining the nonattainment boundary.

Jurisdictional boundaries

Once the geographic area associated with the area violating the SO 2 standard and the nearby areas contributing to the violations are determined, we considered existing jurisdictional boundaries for the purpose of providing a clearly defined legal boundary for carrying out the air quality planning and

enforcement functions of the area. Indiana did not have any nonattainment areas under the prior SO 2 NAAQS. EPA finds that township and county boundaries provide a suitable administrative basis for defining a nonattainment area.18

Conclusion

After considering the factors desc ribed above, EPA is initially designating Harrison and Fayette Townships within Vigo County as the Terre Haute , IN nonattainment area for the 2010 SO 2 NAAQS

. The air quality monitor s in Harrison Township within Vigo County show violation s of the 20 10 SO 2 NAAQS, based on 2009 to 2011 air quality data

. EPA finds these two townships include the sources

that contribute to this monitored violation

. Based on the consideration of all the relevant and available information, as described above, EPA believes that the boundaries described herein encompass the appropriate initial nonattainment area for the 20 10 SO 2 NAAQS. EPA is not ready to conclude that the emissions from sources located outside the boundary recommended by Indiana contribute to the

monitored viola tion or to other possible violations . In a subsequent round of designations, we will make final initial designation decisions for areas in Indiana not included in the nonattainment area designations addressed in this TSD.