Mitchell E. Daniels, Jr.

Governor

Thomas W. Easterly

Commissioner

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

We make Indiana a cleaner, healthierplace to live.

100 North Senate Avenue

Indianapolis, Indiana 46204

(3 t7) 232-8603

(800) 45 t-6027

www.idernJN.gov

October 10, 2006

Mr. Bharat Mathur

Acting Regional Administrator

U.S. EPA, Region 5

77 W. Jackson Blvd.

Chicago, IL 60604

Re: Clean Air Act Section 110(1)

Demonstration and State

.Implementation Plan Revision for

.Clark and Floyd Counties, Indiana

DearMr.Math~: ::'.'-

Enclosed is arevislon to the Requ~stfor;Redesignationand Maintenance Planfor

Attainment in the Indiana Portion ofthe Louisville Basic Nonattainment Area. Also enclosed for

your review, please find a non-interference demonstration consistent with Section 110(1) ofthe

Clean Air Act to support the discontinuation ofthevehicle inspection and maintenance program

for C~ark and Floyd counties. IDEM has revised the petition and maintenance plan in order to

move the vehicle inspection and maintenance program from Section 6.2, where itwas listed as a

measure to remain in place over the course ofthe maintenance plan, to Section 8.0, where it islisted as a contingency measure. IDEM has also revised Section 6.0 to clarify that local and

statewide RACT rules have applied to new/existing VOC emission sources locating in Clark and

Floyd Counties as required by Section 172 ofthe CAAA.

Indiana House Enrolled Act No. 1798, effective on July 1., 2003, amended IC 13-17-5 to

eliminate the applicability ofthe vehicle emissions testing rule to Clark and Floyd counties after

December 31,.2006, and prohibit the Indiana Air Pollution Control Board from adopting rules to

extend the program in those counties after that date.

RecycledPaper (i) An Equal Opportunity Employer Please Recycle 0

. - .. _..----------------------_......
B. Mathur

Page 2.

In order to support the discontinuation ofthe vehicle inspection and maintenance program

in Clark and Floyd counties,. IDEM has prepared a demonstration that meets the requirements of

Section 110(1) ofthe Clean Air Act, hereinafter referred to as the Section 110(1) demonstration.

This demonstration is supported by photochemical modeling. Photochemical modeling shows that

NOx and VOC emissions will slightly increase with the discontinuatio'n ofthe vehicle inspection

and maintenance program. Despite this fact, 2007 total emissions are projected to be less than the

total 2003 (base year) emission levels. The 2010 and 2020 total emission levels are also projected

to be less than total 2003 emissions levels. Therefore, the discontinuation ofthe vehicle emissions

testing program will not interfere with attainment ofthe 8-hour ozone standard in Clark and Floyd

counties. Furthermore, this demonstration shows that the discontinuation ofthe vehicle emissions

testing program will not interfere with the area's reasonable progress towards attainment ofthe

National Ambient Air Quality Standard for fine particles (PM 2.5).

The revised 8,.Hour Redesignation Petition and Maintenance Plan for Clark and FlQYQ .

counties, as well as the Section 110(1) demonstration, are enclosed. These documents are cUffeptly

subject to public review. Apublic hearing concerning this matter is scheduled for NovemJ>er 6;

2006, and IDEM willsubmit the final documents to the U.S. EPA by December 1, 2006. IPEM,

requests that the U.S. EPA parallel process the revised State lJnplementation Plan. ;, .

,

If you have any commellts or questions regardingthi~request, please contact Ms.,Kathy

Watson, Branch Chiefin the Office o(Air Quality, at (317)2:33-5694 or lvlI'. G~.le.,EerPs,,;. '

Environmental Manager, at (317) 234-3653. .

omas W. Easterly

, Commissioner

Attachments

cc; Steve Rosenthal, US EPA (w/enc]osures)

Jay Bortzer, U.S. EPA (w/enclosures)

John Mooney, U.S. EPA (w/enclosures)
Clean Air Act Section 110(1) Demonstration

To Support

Discontinuation ofthe Vehicle Inspection and Maintenance Program

in Clark and Floyd counties, Indiana

Ovezview

The Indiana Department ofEnvironmental Management (IDEM) has prepared a revision to the

Redesignation Petition and Maintenance Plan for Clark and Floyd counties in conjunction with

the 8-hour ozone standard. This revision is to accommodate the discontinuation ofthe vehicle

inspection and maintenance program for Clark and Floyd counties. Section 110(1) ofthe Clean

Air Act states that the Administrator (ofthe United States Environmental Protection Agency)

shall not approve a revision of a plan (State Implementation Plan or SIP) ifthe revision would

interfere with any applicable requirement concerning attainment or reasonable further progress

(of a National Ambient Air Quality Standard). Therefore, IDEM has also prepared a

demonstration that shows that the discontinuation ofthe vehicle emissions testing program will

not interfere with the applicable requirements ofthe National Ambient Air Quality Standards for

8-hour ozone and fine particles.

Backgro~d

IDEM r~seJ,1tly submitted an 8-Hour Ozone Redesignation Petition and Maintenance Plan for

Clark and Floyd counties (dated July 2006) to the U.S. EPA requesting that these counties be

redesignated to attainment ofthe standard. Clark and Floyd counties, along with the remaining

portion ofthe Louisville nonattainment area, have attained the NAAQS standard for ozone.

Indiana has performed an analysis that shows the air quality improvements are due to permanent

and enforceable measures and that significant regional NOx reductions following implementation

ofPhase II ofthe NOx SIP Call and the Clean Air Interstate Rule will ensure continued

compliance (maintenance) with the standard.

Indiana's petition includes a long-term maintenance plan that will be implemented to ensure

that the area continues to meet the 8-hour standard for ground-level ozone through the year

2020. Indiana also committed to maintain all emission control measures necessary to ensure

continued compliance with the standard following redesignation.

The vehicle inspection and maintenance program was first initiated in 1984 in accordance

with the Clean Air Act (CAA). This program was augmented in 1997 to a fully enhanced

vehicle inspection and maintenance program and wasincorporated within Indiana's I-hour

ozone State Implementation Plan in 1996. Although the U.S. EPA revoked the I-hour ozone

standard on June 15, 2005, Clark and Floyd counties were designated nonattainment for the

eight-hour ozone standard effective June 15,2004. Therefore, the program is required to be

in place until all applicable Clean Air Act requirements are met. The vehicle inspection and

maintenance program is authorized by state statute, IC 13-17-5, paid for by the general fund,

and implemented through rules promulgated by the Air Pollution Control Board at 326 lAC
13-1.1. This program tests approximately 7% ofthe registered automobiles in the Greater

Louisville Basic Ozone Nonattainment Area and costs the State ofIndiana approximately

one million dollars per yearto operate and maintain. The program yields less than a 1%

reduction in total NOx and VOC emissions for the nonattainment area.

On July 1, 2003, an amendment to IC 13-17-5 became effective that terminates Indiana's vehicle

inspection and maintenance rule for Clark and Floyd counties after December 31,2006, and

directs the Air Pollution Control Board to amend 326 lAC 13-1.1 to reflect this change. IDEM is

in the process ofamending the state rule to accommodate the discontinuation ofthe vehicle

inspection and maintenance program in Clark and Floyd counties. IDEM has also revised the 8-

Hour Redesignation Petition and Maintenance Plan for Clark and Floyd counties in order to

move the vehicle inspection and maintenance program from Section 6.2 where it was listed as a

measure to remain in place over the course ofthe maintenance plan, to Section 8.0 where it is

listed as a contingency measure. IDEM has also revised Section 6.0 to clarify that Indiana in the

mid-1990s promulgated rules specific to Clark and Floyd counties that require RACT for

new/existing emission sources ofVOCs locating in these counties.

In order to support the revision to the 8-Hour Redesignation Petition and Maintenance Plan for

Clark and Floyd counties, IDEM has prepared a demonstration the meets the requirements of

Section 110(1) ofthe Clean Air Act, hereinafter referred to as the Section 110(1) demonstration.

This demonstration is supported by photochemical modeling and an emissions analysis.

Photochemical modeling shows that NOx emissions will increase by 0.78 tons per summer day

and 0.82·tons per winter day with the discontinuation ofthe vehicle inspection and maintenance

program. VOC emissions will also increase by 0.79 tons per summer day and 1.49 tons per

winter day. Despite this fact 2007 total emissions are projected to be less than the total 2002

emission levels (base year for PM 2.5), 2003 total emission levels (base year for the ozone

maintenance plan), and 2009 total emission levels (deadline for monitoring attainment under the

PM 2.5 standard). The 2010 and 2020 total emission levels referenced in the ozone maintenance

plan are also projected to be less than the total 2003 emissions levels. Therefore, the

discontinuation ofthe vehicle emissions testing program will not interfere with attainment ofthe

8-hour ozone standard in Clark and Floyd counties, or elsewhere within the nonattainment area.

Furthermore, this demonstration shows that the discontinuation ofthe vehicle emissions testing

program will not interfere with the area's reasonable progress towards attainment ofthe National

Ambient Air Quality Standard for fine particles (PM 2.5)

The vehicle inspection and maintenance program was implemented as a volatile organic

compound (VOC) emission control measure specifically in association with the I-hour ozone

standard (revoked effective June 15, 2005). The program does not fail motor vehicles for

exceeding tailpipe standards for oxides ofnitrogen (NOx) emissions. However, since VOC and

NOx are precursors for ozone, IDEM's 110(1) demonstration ~ssesses the potential impact of

both precursors on future ozone concentrations. Although the vehicle inspection and maintenance

program was not implemented as a control mechanism for particulate matter or fine particles,

IDEM's 110(1) demonstration assesses the potential impact that the discontinuation ofthe

program may have on the area's ability to attain the annual standard for fine particles. However,
since VOC is not considered a precursor for fine particles, NOx is the only precursor included in

the assessment, even though the vehicle inspection and maintenance program does not serve as a

NOx control measure.

Section 110(1) Technical Support Document

Introduction for Photochemical Modeling for Ozone and PM2.5 Assessment

IDEM's Office of Air Quality conducted photochemical modeling to determine whether the

discontinuation ofthe vehicle inspection and maintenance program in Clark and Floyd counties

would adversely affect the area's ability to attain or maintain compliance with applicable

National Ambient Air Quality Standards. The discontinuation ofthe vehicle inspection and

maintenance program does result in the loss ofNOx and VOC emission reductions, and thus

could affect ozone and fine particle concentrations. This potential increase in emissions was

determined using local travel demand model data and emission factors deriving from MOBILE6.

The increased emissions were added to the existing emission profiles for Clark and Floyd

counties and were modeled and compared to the previous modeling results that included the

vehicle inspection and maintenance program in Clark and Floyd counties. Any difference

between the two model runs represents the impact on future year design values for ozone or

PM2.5 monitors located in Clark and Floyd counties.

Emissions Estimation and Photochemical Modeling Methodologies

IDEM is a member ofthe Midwest Regional Planning Organization (MRPO), which uses

photochemical modeling to determine emission control strategies for attainment State

Implementation Plans (SIPs) for Indiana, Illinois, Michigan, Wisconsin and Ohio. The Lake

Michigan Air Directors Consortium (LADCO) supports the MRPO and supplied emissions,

meteorological and chemistry files as well as photochemical model source codes used in this

analysis. Indiana followed the U.S. EPA guidance in all modeling and attainment demonstration

methods for this analysis.

Emissions Estimation Methodology

IDEM's Office ofAir Quality adjusted the emissions in order to determine the impact ofthe

discontinuation ofthe vehicle inspection and maintenance program in Clark and Floyd counties.

LADCO provided the 2002 base case emissions and future year emissions for 2009 as well as the

weighting factors to interpolate 2007 emissions between the 2002 and 2009 emissions. Future

year 2009 emissions were created to account for economic growth and emission control

strategies that will be in place by 2009 for all emissions sectors. Modeling results show the

downward trend for each modeled year and validates this analysis:

LADCO provided a computer software patch to calculate 2007 emissions for all emissions

sectors. The emissions adjustments for 2007 were an estimation of all emission sectors between

the known (2002) and calculated (2009) future emission levels. The weighting factor consists of

the fraction ofthe number of years from each time period. The weighting factors used for

determining the 2007 emissions are 0.285 (2/7thS ofthe emissions from 2002) for 2002 emissions

and 0.714 (5/7ths ofthe emissions from 2009) for 2009 emissions. The weight~ng factors were

applied to the motor vehicle, low-level point, area sources (marine-air-rail, nonroad and other)

and ammonia emissions. The weighting factors were not applied to the elevated point source

1
emissions because no significant emission changes are expected to that particular source sector

between 2007 and 2009. Therefore, 2009 elevated point source emissions were used. Each'

emission sector file was quality assured to determine specific pollutant emissions in grammoles/day, kilograms/day and tons/day. Once emission adjustments were made, all emissions

sectors were merged to create 2007 emissions.

LADCO has a computer program that adjusts emissions for a specific county and emission

sector. For the purpose ofthis analysis, the discontinuation ofthe vehicle inspection and

maintenance program in Clark and Floyd counties only affected mobile emissions; therefore the

mobile emissions were the only emission sector analyzed. The difference between the total 2007

emissions and the total 2007 emissions with Clark and Floyd counties emissions zeroed-out,

represent the mobile emissions for Clark and Floyd counties. Table 1.1 shows the modeled

mobile source emissions for Clark and Floyd counties for the years 2002,2007 and 2009. All

emissions data include the vehicle inspection and maintenance program in Clark and Floyd

counties. The quality assured results ofthese emissions adjustments can be found in Appendix

A. Also referenced in Appendix A are the total 2007 emissions, 2007 emissions minus the Clark

County emissions and the 2007 emissions minus the Floyd County emissions.

M d t . f r I

Table 1.1

2002 2007 , and 2009 Moleb·1 SourceE·· missions rom o e 1112 nven ones

2002 - summer . 2007 - summer 2009 - summer

Clark Floyd Clark Floyd Clark Floyd

tons/day tons/day tons/day tons/day tons/day tons/day

NOx 12km 13.74 5.43 10.4 3.95 8.43 3.37

36km 20.96 5.38 15.45 3.88 13.26 3.28

VOC 12km 9.46 4~00 7.93 3.03 6.11 2.65

36km 12.63 3.38 9.77 2.54 8.65 2.21

2002 - winter 2007 - winter 2009 - winter

Clark Floyd Clark Floyd Clark Floyd

tons/day tons/day tons/day tons/day tons/day tons/day

NOx 36km 23.6 6.09 17.39 4.39 14.93 3.72

VOC 36km 13.73 3.67 10.63 2.76 9.39 2.39

Based on the MOBILE6 emission modeling conducted to determine the impact on NOx and

VOC emissions from the discontinuation ofthe vehicle inspection and maintenance program in

Clark and Floyd counties, for the year 2007, the increase in NOx emissions was 0.78 tons per

summer day and 0.82 tons ofNOx per winter day. VOC emissions were calculated to increase

by 0.79 tons per summer day and 1.49 tons per winter day. This change in the NOx and VOC

emissions was then used to determine multipliers in order to adjust the mobile inventory in the

modeling files. The multipliers were for both Clark and Floyd counties: NOx - 1.047 for

summer and 1.048 for winter; VOC - 1.125 for summer and 1.134 for winter. The emission

estimates were calculated for the six winter months ofOctober, November, December, January,

February and March and the six summer months ofApril, May, June, July, August and

September. The emission adjustments were then made to the 2007 mobile modeling files with

2
Clark County NOx and VOC emissions adjusted first and the Floyd County NOx and VOC

emissions adjusted second to account for the discontinuation ofthe vehicle inspection and

maintenance program in those counties. This created the new 2007 mobile emission files which

were quality assured and pre-processed with the other emission source categories for use in

CAMx.

Photochemical Modeling Methodology

The Comprehensive Air Quality Model with extensions (CAMx) was the photochemical model

used; this model is accepted by the U.S. EPA. The meteorology used was the summer of2002

for ozone and the entire year of 2002 for PM2.5. Three separate modeling runs were conducted;

one model run to determine base year (2002) concentrations, one future year (2007) model run

included additional NOx and VOC emissions from the discontinuation ofthe vehicle inspection

and maintenance program (without 11M), and one future year (2007) model run with the NOx and

VOC emission reductions associated with the vehicle inspection and maintenance program (with

11M). The 2007 ozone and PM2.5modeled results were post-processed and evaluated using the

U.S. EPA's attainment test guidelines. Future year design values were calculated from the

modeling runs with and without the vehicle inspection and maintenance program being in place.

The impact on the future year design values for ozone and PM2.5 monitors in Clark and Floyd

counties was determined.

Photochemical Modeling Results for Ozone

Theresults ofthe 8-hour ozone attainment test compared the 2007 design values for Clark and

Floyd counties with the vehicle inspection and maintenance program in place to the 2007 design

values for Clark and Floyd counties assuming the discontinuation ofthe vehicle inspection and

maintenance program. The difference in the future year design values were modeled at the

Charlestown, Clark County and New Albany, Floyd County ozone monitors, as well as for the

additional sites within the nonattainment area. The difference is an increase in the future year

design value for ozone of+0.0001 ppm at the Charlestown ozone monitor. No difference in the

future year design value for the New Albany site or other sites within the nonattainment area was

determined. All design values are projected to be below the standard of 0.085 ppm. Table 1.2

lists the modeled results from the ozone attainment test and the difference in future year design

values as a result ofthe discontinuation ofthe vehicle inspection and maintenance program for

Clark and Floyd counties. Since only the third significant digit is used in computation and the

modeled difference for the Charlestown site affects the fourth significant digit, there is virtually

no difference in the modeled design values for any monitoring site. IDEM used the average of

three design values (2000-2002, 2001-2003, and 2002-2004) for this assessment. The period of

time associated with the average design value encompasses the design value that was used in

designating the area nonattainment (2001-2003) and the design value used to support IDEM's

redesignation petition for Clark and Floyd counties (2003-2005, with 2003 representing the base

year).

3
Table 1.2

8-hour Ozone Attainment Results for Nonattainment Area

2007

2007 No 1M Difference

MonitorlD ST County 00 02 01 03 02 04 AVGDV RRF FYDV FYDV

ppm ppm ppm ppm ppm ppm ppm

1801900031 IN Clark 0.090 0.092 0.088 0.090 0.93 0.083 0.083 +0.0001

1804310041 IN Floyd 0.083 0.086 0.084 0.084 0.93 0.078 0.078 0.0000

2102900061 KY Bullitt 0.085 0.081 0.076 0.080 0.94 0.076 0.076 0.0000

2111100271 KY Jefferson 0.085 0.079 0.075 0.086 0.94 0.075 0.075 0.0000

2111100511 KY Jefferson 0.084 0.084 0.080 0.084 0.94 0.077 0.077 0.0000

2111110211 KY Jefferson 0.083 0.079 0.076 0.083 0.94 0.074 0.074 0.0000

2118500041 KY Oldham 0.087 0.086 0.083 0.085 0.93 0.079 0.079 0.0000

00_02 - design value from (2000-2002),

01_03 - design value from (2001-2003),

02_04 - design value from (2002-2004),

AVGDV - average ofth~ 3 design values,

RRF - relative reduction factor - ratio offuture year and base year modeling,

2007 FYDV - future year design value with Clark/Floyd I&M program, and

2007 No 1M FYDV - future year design value without Clark/Floyd I&M program,

Difference - the part per million differences between the future year design values.

It should be noted that the ozone model performance is within the u.s. EPA guidance and is

considered State Implementation Plan (SIP) quality. Information on the attainment test,

calculating relative reduction factors and other additional 8-hour ozone documentation was taken

from the "Guidance on the Use ofModels and Other Analyses in Attainment Demonstrations for

the 8-hour Ozone NAAQS.

Photochemical modeling was conducted by the U.S. EPA and LADCO in support ofthe Clean

Air Interstate Rule (CAIR). The modeling results show future year design values for 8-hour

ozone well within the 8-hour ozone NAAQS of 0.085 parts per million (ppm). Table 1.3 shows

the U.S. EPA modeling results for CAIR. All sites in Clark and Floyd counties and in Bullitt,

Jefferson and Oldham Counties in Kentucky are predicted to have future year design values in

2010 and 2015 below 0.085 ppm and will be in attainment.

AOItt t R I

Table 1.3

8H- our ozone M do er102 ResuIts fjrom U S° • EPA fior the CIean lr n ers a e ue

Future Future

Design Value Design Value Design Value

County State MSAlCMSA 1999-2003 2010 with CAIR 2015 with CAIR

(ppm) (ppm) (ppm)

Clark Indiana Louisville 0.0893 0.0784 0.0735

Floyd Indiana Louisville 0.0837 0.0752 0.0703

Bullitt Kentueky Louisville 0.0837 0.0731 0.0693

Jefferson Kentucky Louisville 0.0843 0.0749 0.0711

Oldham Kentucky Louisville 0.0880 0.0756 0.0710

4
Table 1.4 shows the LADCO - Round 4 modeling results for CAIR. All sites in Clark and Floyd

counties and in Bullitt, Jefferson and Oldham Counties in Kentucky are predicted to have future

year design values in 2009,2012 and 2018 below 0.085 ppm and will be in attainment.

Table 1.4

LADCO's Round 4 8-Hour Ozone Modeling Results for the Clean Air Interstate Rule

2009 Future 2012 Future 2018 Future

Design Value Design Value Design Value Design Value

Monitor ID County State 2000-2004 with CAIR with CAIR with CAIR

(ppm) (ppm) (ppm) (ppm)

180190003 Clark Indiana 0.0900 0.0825 0.0792 0.0763

180431004 Floyd Indiana 0.0843 0.0774 0.0757 0.0725

210290006 Bullitt Kentucky 0.0807 0.0748 0.0720 0.0680

211110027 Jefferson Kentucky 0.0797 0.0739 0.0709 0.0680

211110051 Jefferson Kentucky 0.0827 0.0763 0.0744 0.0708

211111021 Jefferson Kentucky 0.0793 0.0733 0.0717 0.0691

211850004 Oldham Kentucky 0.0853 0.0776 0.0743 0.0715

Table 1.5 compares projected 2007 total emissions for Clark and Floyd counties with 2003 total

emissions for Clark and Floyd counties. The 2007 and 2009 emission projections account for the

discontinuation ofthe vehicle inspection and maintenance program. The base year for Indiana's

request for Clark and Floyd counties to be redesignated to attainment under the 8-hour ozone

standard is 2003. As Table 1.5 illustrates, the total emissions for 2007 and 2009 are projected to

be less than 2003 emission levels, despite the mobile source VOC and NOx emissions.increasing

by less than a ton each per summer day. The 2010 and 2020 emissions referenced in the

maintenance plan remain below 2003 emissions as well, and have not been revised since the

vehicle emissions testing program was excluded from the calculations. As illustrated in Table

1.6, once the 2007 emission reduction benefit for the vehicle emissions testing program is

compared to the 2003 (base year) total emissions for the entire nonattainment area, the program

yields well less than a 1% emission reduction benefit for VOC and NOx. Historically,

photochemical modeling sensitivity tests have shown that a local reduction of 15%-25% VOC is

required to reduce ozone by 1 ppb.

Table 1.5

2003 and 2007 Emissions Comparison

Clark and Floyd counties (tons per summer day)

2003 2007 2009

VOC 29.26 28.59 26.33

NOx 51.77 41.89 38.84

Note: 2003 emissions include the vehicle inspection and maintenance program, 2007 emissions exclude

the program.

5
Table 1.6

Percentage Impact of 11M Emission Reduction on Base Yea.; Emissions for

Entire Nonattainment Area (tons per summer day)

2003 Total 11M Benefit % Impact

voe 133.11 0.79 0.6%

NOx 238.77 0.78 0.3%

Photochemical Modeling Results for Fine Particles

The attainment test for PM2.5 compared the 2007 design values for Clark and Floyd counties with

the vehicle inspection and maintenance program in place to the 2007 design values for Clark and

Floyd counties assuming the discontinuation ofthe vehicle inspection and maintenance program.

This test was also conducted for the other sites within the nonattainment area. The difference in

the future year design values was modeled at the Jeffersonville, Clark County and New Albany,

Floyd County PM2.5monitors as well as for the additional sites in Bullitt and Jefferson Counties

in Kentucky. Table 1.7 lists the modeled results from the PM2.5 attainment test and the

difference in future year design values as a result ofthe discontinuation ofthe vehicle inspection

and maintenance program. The attainment test for PM2.5 offered speciation ofthe PM2.5 .

composition. This speciation includes sulfates, nitrates, organic and elemental carbon, ammonia

and soil. The impact on the annual future year design value for PM2.5 was -0.1 ug/m3 at the

Jeffersonville and New Albany PM2.5 monitors, as well as at several ofthe Kentucky sites. These

results reflect an insignificant benefit resulting from the photochemical sensitivity associated

with the affected species. The speciated modeling results of PM2.5 mass showed a minor impact

for nitrates and ammonia from discontinuation ofthe vehicle inspection and maintenance

program for Clark and Floyd counties. There are no 24-hour PM2.5 nonattainment areas in

Indiana, so the 24-hour PM2.5 future year design values were not calculated.

6
Table 1.7

AnnuaI PM2.5 At· t amment ResuIts fior CIark d an FIOyld counfles

2007

2002 2007 NolM

Monitor 10 51 County Winter Spring Summer Fall BYDV FYDV FYDV Difference

ug/m3 ug/m3 ug/m3 ug/m3 ug/m3 ug/m3 ua/m3 ua/m3

180190005 IN Clark 15.9 16.7 20.5 15.5 17.2 15.7 15.6 -0.1

180431004 IN Floyd 13.4 14.8 19.5 11.9 14.9 13.4 13.3 -0.1

210290006 KY Bullitt 13.2 15 19.9 11.4 14.9 13.5 13.4 -0.1

211110043 KY Jefferson 13.1 15.8 21.8 12.9 15.9 14.4 14.4 0.0

211110044 KY Jefferson 14.2 16.1 22.5 13.5 16.6 15.1 15.0 -0.1·

211110048 KY Jefferson 13.3 15.5 22.2 13.2 16.1 14.6 14.5 -0.1

Winter - Winter quarterly modeled average for Base Year,

Spring - Spring quarterly modeled average for Base Year,

Summer - Summer quarterly modeled average for Base Year,

Fall- Fall quarterly modeled average for Base Year,

BYDV - Modeled Base Year Design Value,

2007 FYDV - future year design value with Clark/Floyd I&M program,

2007 No 1M FYDV - future/year design value without Clark/Floyd I&M program, and

Difference - the microgram per cubic meter differences between the future year design values.

It is worth noting that thePM2.5 model performance is outside the bounds for the bias, error,

fractional bias and fractional error matrices, as per U.S. EPA photochemical modeling criteria.

Improvement in the PM2.5 model performance is necessary. These modeling results may change

with improved model performance, however, the impacts on the annual PM2.5 future year design

values are expected to be minimal. The information on the attainment test and other additional

PM2.5 documentation was taken from the "Guidance for Demonstrating Attainment ofAir

Quality Goals for PM2.5 and Regional Haze".

Photochemical modeling was conducted by the U.S. EPA and LADCD in support ofthe Clean

Air Interstate Rule (CAIR). The modeling results show future year design values for annual

PM2.5 within the annual PM2.5 NAAQS of 15.0 micrograms per cubic meter (ug/m3). Table 1.8

shows the U.S. EPA modeling results for CAIR. Floyd County in Indiana and Bullitt County in

Kentucky are projected to attain the annual PM2.

5NAAQS by 2010. All sites in Clark and Floyd

counties and in Bullitt County in Kentucky are predicted to have future year design values in

2015 below 15.0 ug/m3 and will be in attainment. Jefferson County in Kentucky is predicted to

exceed the annual PM2.5NAAQS. However, it is within 3% ofthe standard in 2010 and 1% of

the standard in 2015.

7
Table 1.8

AnnuaIPM2.5 M do em2 r ResuIts from U S. .EPA fior the CIean A·lr Itt n ers a et R I ue

Future Future

Design Value Design Value Design Value

County State MSAlCMSA 1999-2003 2010 with CAIR 2015 with CAIR

(ug/m3) . (ug/m3) (ug/m3)

Clark Indiana Louisville 16.90 15.15 14.79

Floyd Indiana Louisville 15.35 13.54 13.27

Bullitt Kentucky Louisville 15.61 13.67 13.13

Jefferson Kentucky Louisville 17.07 15.44 15.13

Table 1.9 shows the LADCO - Round 4 modeling results for CAIR. All sites in Clark and Floyd

counties and in Bullitt, Jefferson and Oldham Counties in Kentucky are predicted to have future

year design values in 2009,2012 and 2018 below 15.0 ug/m3 and in attainment.

Table 1.9

LADeo's Rd4A oun nnuaI PM2.5 M do em2 r ResuIts fior the CIean A'lr Itt n ers a et R I ue

2009 Future 2012 Future 2018 Future

Design Value Design Value Design Value Design Value

Monitor ID County State 2000-2004 with CAIR with CAIR with CAIR

(ug/m3) (ug/m3) (ug/m3) (uq/m3)

180190006 Clark Indiana 16.5, 14.5 14.0 13.7

180431004 Floyd Indiana 14.9 13.2 12.8 12.3

210290006 Bullitt Kentucky 15.0 13.3 12.8 12.2

211110043 Jefferson Kentucky 16.8 14.2 13.8 13.3

211110044 Jefferson Kentucky 16.5 14.8 14.4 13.7

211110048 Jefferson Kentucky 16.0 14.3 13.9 13.9

Table 1.10 summarizes total NOx emissions for Clark and Floyd counties for the years 2002

(base year for the PM2;5 standard with 11M in place), 2007 (assuming the discontinuation ofthe

11M program), and 2009 (the deadline for monitoring attainment ofthe standard). As Table 1.10

illustrates, total NOx emissions for the years 2007 and 2009, with the reductions associated with

the vehicle emissions testing program excluded, are less than the total NOx emissions in 2002

(the base year for the standard) when the program was in place.

Table 1.10

NOx Emissions Analysis for PM2.5

Clark and Floyd counties (tons per day)

2002 2007 I 2009

INOx 57.59 41.89 I 38.82

8
Conclusions

iDEM's Office ofAir Quality conducted an ozone and PM2.5 assessment to determine ifthere

would be impacts from additional mobile source VOC and NOx emissions as a result ofthe

discontinuation ofthe vehicle inspection and maintenance program for Clark and Floyd counties.

Photochemical modeling was conducted for the summer of 2002 for ozone and the entire year of

2002 for PM2.5. CAMx is the U.S. EPA accepted photochemical model used in conjunction with

emissions and chemistry files obtained from the MRPO. Emission adjustments were made to the

200212009 emission files in order to create a 2007 emissions profile. The motor vehicle

emissions for Clark and Floyd counties were determined and the anticipated increase in NOx and

VOC emissions were added to the 2007 emissions inventory.

Modeling results were used in the U.S. EPA attainment tests for 8-hour ozone and annual PM2.5

to determine if additional VOC and NOx emissions associated with the discontinuation ofthe

vehicle inspection and maintenance program would impact the ozone and PM2.5 monitors in the

nonattainment area. Based on the attainment tests, there was an increase of+0.0001 ppm for the

future year ozone design value at the Charlestown ozone monitor. Since only the third

significant digit is used in computation and the modeled difference for the Charlestown site

affects the fourth significant digit (.0001), there is virtually no difference in the modeled design

values for either site in Clark and Floyd counties. The projected design value for 2007(.084 ppm)

is below the 8-hour ozone standard and identical to the design value that serves as the base year

in the redesignation petition and maintenance plan (2003-2005, with 2003 serving as the base

year). More importantly, once the discontinuation ofthe vehicle inspection and maintenance

program is accounted for, 2007 VOC and NOx emissions are projected to be lower than 2003

NOx and VOC emission levels. Therefore, the discontinuation ofthe vehicle inspection and

maintenance program for Clark and Floyd counties will not interfere with attainment ofthe 8-

hour ozone standard (or any other applicable requirement ofthe Clean Air Act).

A difference of-0.1 ug/m3 ofthe annual future year design values for several monitors within

the nonattainmeht area was found, with the difference coming from nitrate concentrations.

Though this reflects a potential benefit, a one-tenth of a microgram per cubic meter impact is

negligible. More importantly, an emissions analysis demonstrates that total NOx emissions for

the years 2007 and 2009, with the reductions associated with the vehicle emissions testing

program excluded, are less than the total NOx emissions in 2002 (the base year for the standard)

when the program was in place. Therefore, the discontinuation ofthe vehicle inspection and

maintenance program for Clark and Floyd counties will not interfere with the area's ability to

achieve reasonable progress towards attainment ofstandard by its assigned deadline (April 5,

2010). '

9

Appendix A

Quality Assured Emission File Results

for Summer/Winter Days - 2007


Winter Day - Mobile emissions with Winter Day - Mobile emissions with Clark

Floyd County emissions zeroed out - 36 km Floyd County emissions without I&M - 36 km

motv.020111.4rpos.36.2007K+fwin_zero.ld.bin motv.020111.4rpos.36.2007K+c_fpm.ld.bin

Floyd Co. C/F diff

Species gram-moles/day kg/day tons/day tons/day Species gram-moles/day kg/day tons/day tons/day

NO 287948672 8638461 9522 3.75 NO 288089120 8642674 9527 0.90

N02 31994834 1471762 1622 0.64 N02 32010446 1472481 1623 0.15

OLE 9960725 318743 351 0.09 OLE 9965143 318885 352 0.06

PAR 3576E;>9952 5722720 6308 1.70 PAR 357829568 5725274 6311 1.11

TOl 8030421 899407 991 0.27 TOl 8034014 899810 992 0.18

XYl 8266199 1058074 1166 0.32 XYl 8269902 1058548 1167 0.21

FORM 13317644 213082 235 0.06 FORM 13323531 213177 235 0.04

AlD2 18468482 590991 651 0.17 AlD2 18476546 591250 652 0.11

ETH 407328 13034 14 0.00 ETH 407478 13039 14 0.00

MEOH 0 0 0 0.00 MEOH 0 0 0 0.00

ETOH 1096896 35101 39 0.01 ETOH 1097389 35116 39 0.01

ISOP 279709 22377 25 0.01 ISOP 279835 22387 25 0.00

NR 25359030 405745 447 0.12 NR 25370410 405927 447 0.08

CO 5028080640 140786272 155188 0.00 CO 5028080640 140786272 155188 0.00

S02 188995 12096 13 0.00 S02 188995 12096 13 0.00

FPRM 0 0 0 0.00 FPRM 0 0 0 0.00

CPRM 0 0 0 0.00 CPRM 0 0 0 0.00

NH3 52352260 889988 981 0.00 NH3 52352260 889988 981 0.00

TERPB 0 0 0 0.00 TERPB 0 0 0 0.00

SUlF 48619 49 0 0.00 SUlF 48619 49 0 0.00

PEC 176041552 176042 194 0.00 PEC 176041552 176042 194 0.00

PN03 0 0 0 0.00 PN03 0 0 0 0.00

POA 118978376 118978 131 0.00 POA 118978376 118978 131 0.00

PS04 0 0 0 0.00 PS04 0 0 0 0.00

FCRS 0 0 0 0.00 FCRS 0 0 0 0.00

CCRS 0 0 0 0.00 CCRS 0 0 0 0.00

Summer Day - Mobile emissions with Summer Day - Mobile emissions with 'Clark Floyd County emissions zeroed out - 12km Floyd County emissions without I&M - 12 km

motv.020712.upmw.12.2007K2fwin_zero.ld.bin motv.020712.upmw.12.2007K2c1arkfloyd.ld.bin Floyd Co. C/F diff Species gram-moles/day kg/day tons/day tons/day Species gram-moles/day kg/day tons/day tons/day NO 111509512 3345286 3687 3.38 NO 111628600 3348858 3691 0.56

N02 12389948 569938 628 0.58 N02 12403185 570547 629 0.10

OLE 3749647 119989 132 0.10 OLE 3753843 120123 132 0.04

PAR 133818712 2141100 2360 1.87 PAR 133969032 2143505 2363 0.79

TOl 2993809 335307 370 0.29 TOl 2997180 335684 370 0.12

XYl 3081079 394378 435 0.35 XYl 3084549 394822 435 0.14

FORM 5032338 80517 89 0.07 FORM 5037952 80607 89 0.03

AlD2 7060891 225949 249 0.19 AlD2 7068703 226199 249 0.08

ETH 181583 5811 6 0.00 ETH 181761 5816 6 0.00

MEOH 0 0 0 0.00 MEOH 0 0 0 0.00

ETOH 407553 13042 14 0.01 ETOH 408014 13056 14 0.00

ISOP 103927 8314 9 0.01 ISOP 104045 8324 9 0.00

NR 9422213 150755 166 0.13 NR 9432855 150926 166 0.06

CO 1366784512 38269968 42185 0.00 CO 1366784512 38269968 42185 0.00

S02 67196 4301 5 0.00 S02 67196 4301 5 0.00

FPRM 0 0 0 0.00 FPRM 0 0 0 0.00

CPRM 0 0 0 0.00 CPRM 0 0 0 0.00

NH3. 16705059 283986 313 0.00 NH3 16705059 283986 313 0.00

TERPB 0 0 0 0.00 TERPB 0 0 0 0.00

SUlF 16892 17 0 0.00 SUlF 16892 17 0 0.00

PEC 71047504 71048 78 0.00 PEC 71047504 71048 78 0.00

PN03 0 0 0 0.00 PN03 0 0 0 0.00

POA 40842556 40843 45 0.00 POA 40842556 40843 45 0.00

PS04 0 0 0 0.00 PS04 0 0 0 0.00

FCRS 0 0 0 0.00 FCRS 0 0 0 0.00

CCRS 0 0 0 0.00 CCRS 0 0 0 0.00
Summer Day - Mobile emissions for Summer Day - Mobile emissions with entire modeling domain - 36km Clark County emissions zeroed out - 36km motv.020712.4rpos.36.2007K+.ld.bin motv.020712.4rpos.36.2007K+csum_zero.ld.bin

Clark Co. Species gram-moles/day kg/day tons/day Species gram-moles/day kg/day tons/day tons/day NO 246790736 7403723 8161 NO 246391648 7391750 8148 13.20 N02 27421140 1261373 1390 N02 27376806 1259333 1388 2.25 OLE 8496039 271873 300 OLE 8486554 271570 299 0.33 PAR 303624512 4857993 5355 PAR 303282464 4852520 5349 6.03 TOl 6798299 761410 839 TOl 6790603 760548 838 0.95

XYl 6996867 895599 987 XYl 6988941 894585 986 1.12

FORM 11392839 182285 201 FORM 11380171 182083 201 0.22

AlD2 15943375 510188 562 AlD2 15925922 509630 562 0.62

ETH 396935 12702 14 ETH 396590 12691 14 0.01

MEOH 0 0 0 MEOH 0 0 0 0.00

ETOH 926190 29638 33 ETOH 925136 29604 33 0.04

ISOP 236180 18894 21 ISOP 235911 18873 21 0.02

NR 21412068 342593 378 NR 21387724 342204 377 0.43

CO 3101154816 86832336 95715 CO 3101154816 86832336 95715 0.00

159118 10184 11 $02 159118 10184 11 S02 0.00

0 0 FPRM 0 0 0 FPRM 0 0.00

0 0 CPRM 0 0 0 CPRM 0 0.00

888479 979 NH3 52263464 888479 979 NH3 52263464 0.00

0 0 TERPB 0 0 0 TERPB 0 0.00

·SUlF 47402 47 0 SUlF 47402 47 0 0.00

193 PEC 175457440 175457 193 PEC 175457440 175457 0.00

PN03 0 0 0 PN03 0 0 0 0.00

POA 118578632 118579 131 0.00 POA 118578632 118579 131

PS04 0.00 0 0 0 PS04 0 0 0

FCRS 0.00 0 {) 0 FCRS 0 0 0

CCRS a a 0.00 0 CCRS a a 0
S1,lmmer Day - Mobile emissions with Summer Day - Mobile emissions with Clark

Floyd County emissions zeroed out - 36km Floyd County emissions without I&M - 36 km

motv.020712.4rpos.36.2007K+fsum_zero.ld.bin motv.020712.4rpos.36.2007K+c_fpm.Id.bin

Floyd Co. C/F diff

Species gram-moles/day kg/day tons/day tons/day Species gram-moles/day kg/day tons/day tons/day

NO 246690448 7400714 8158 3.32 NO 246814160 7404425 8162 0.77

N02 27409998 1260860 1390 0.57 N02 27423748 1261493 1391 0.13

. OLE 8493574 271794 300 0.09 OLE 8497535 271921 300 0.05

PAR 303535744 4856572 5353 1.57 PAR 303678656 4858859 5356 0.95

TOl 6796303 761186 839 0.25 TOl 6799520 761546 839 0.15

XYl 6994810 895336 987 0.29 XYl 6998121 895760 987 0.18

FORM 11389541 182233 201 0.06

FORM 11394848 182318 201 0.04

AlD2 15938810 510042 562 AlD2 15946143 510277 562 0.10 0.16

ETH 396839 12699 14 ETH 396990 12704 14 0.00 0.00

MEOH 0 0 0 MEOH 0 0 0 0.00 0.00

ETOH 925917 29629 33

ETOH 926357 29643 33 0.01 0.01

ISOP 236110 18889 21

ISOP 236222 18898 21 0.00 0.01

NR 21405758 342492 NR 21415934 342655 378 0.07 378 0.11

CO 3101154816 86832336

CO 3101154816 86832336 95715 0.00 95715 0.00

S02 159118 10184 0.00 S02 159118 10184 11 0.00

11

FPRM 0 0 0.00 FPRM 0 0 0 0.00

0

CPRM 0 0.00 CPRM 0 0 0 0.00

0 0

NH3 52263464 0.00 NH3 52263464 888479 979 0.00

888479 979

TERPB 0.00 TERPB 0 0 0 0.00

0 0 0

SUlF 47402 0.00 SUlF 47402 47 0 0.00

47 0

PEC 175457440 0.00 PEC 175457440 175457 193 0.00

175457 193

PN03 0.00 PN03 0 0 0 0.00

0 0 0

POA 0.00 POA 118578632 118579 131 0.00

118578632 118579 131

PS04 0.00 PS04 0 0 0 0.00

0 0 0

FCRS 0.00 FCRS 0 0 0 0.00

0 0 0

CCRS 0.00 CCRS 0 0 0 0.00

0 0 0
Emissions by Source Category for Clark and Floyd Counties (tons per summer day)

NOx VOC

2007 2009 2007 2009

Clark Floyd Clark Floyd Clark Floyd Clark Floyd

area other 0.31 0.13 0.31 0.14 4.73 1.38 4.58 1.35

area nonroad 3.03 0.73 2.81 0.68 3.97 0.87 3.43 0.74

area mar 5.99 1.73 6.01 1.73 0.47 0.12 0.47 0.12

motv 15.45 3.88 13.26 3.28 9.77 . 2.54 8.65 2.21

lowp 0.09 0.1 0.08 0.07 1.17 0.51 1.19 0.53

PTSR nonEGU 1.23 0.28 1.23 0.28 1.56 0.62 1.56 0.62

PTSR EGU 2.75 5.41 2.75 5.41 0.05 0.03 0.05 0.03

TOTAL 28.84 12.27 26.44 11.60 21.72 6.07 19.93 5.60

No CIF I&M 0.78 0.79

2007 2009 2007 2009

Clark/Floyd TOTAL 41.89 38.82 28.59 26.33