Lynn Buhl 

Regional A-dmhistrator 

U.S. EPA, Region V 

77 West Jackson Boulevard 

Chicago, Illinois 60604 

Re: State Implementation Plan Submittal for Indiana Regarding Alternative Monitoring Requirements under 

326 IAC 3-5-l(c)(2)(A)(iii) for Indianapolis Power & 

Light - Harding Street Generating Station. 

(CO #' 2008-02) 

Dear Ms. Buhl: 

Pursuant to Section 1 10 of the 1990 Clean Air Act Amendments and Title 13 of the Indiana 

Code, the Indiana Department of Environmental Management (IDEM) herewith submits an c amendment to the Indiana state implementation plan. 

The request consists of a Commissioner's Order for Indianapolis Power & Light (IPL) - 

Harding Street Generating Station, 3700 South Harding Street, Indianapolis, Indiana. IPL submitted 

a request to IDEM under 326 IAC 3-5-l(c)(2)(A)(iii) for an alternative monitoring plan. This rule 

permits a source to use alternative monitoring when installation of an opacity monitoring system 

would not provide accurate determinations of emissions as a result of interference fiom condensed 

water vapor. The continuous opacity monitoring system (COMS) currently being operated on the 

scrubbed stack associated with Unit 7 is located in ductwork prior to the unit's scrubber. A COMS 

located after the scrubber would be unreliable due to presence of condensed, uncombined water 

vapor. IPL has requested approval to monitor emissions using a particulate matter continuous 

emissions monitor system (PM CEMS) instead. IDEM has approved an alternative monitoring plan for IPL through a Commissioner's Order and is submitting the alternative monitoring plan for SIP approval pursuant to 326 IAC 3-5-l(c)(2)(A)(iv). This request for SIP approval is very similar to the 

request submitted on February 21,2008, for Alcoa Power Generating, Inc. on April 25,2008. 

Pursuant to the new public hearing procedures under 40 CFR 5 1.102, IDEM notified the 

public of an opportunity to request a public hearing on this action on November 12,2008. No 

, requests for a public hearing and no comments on the Commissioner's Order were received by 

L. IDEM. 

An Equal Opportunity Employer 
Throughout the development of this Commissioner's Order, staff of the Office of Air Quality 

worked closely with your staff to ensure that any potential problems that might exist with this 

requested state implementation plan revision would be resolved. I request that U.S. EPA approve 

this amendment to Indiana's SIP. If you have any questions regarding this submittal, please contact 

Scott Deloney, Air Programs Branch Chief, Office of Air Quality at 3 17-233-5694. 

Assistant ~opsioner 

DMIsb Attachments: Supporting Documents 

cc: John Mooney, U.S. EPA 

Steve Rosenthal, U.S. EPA 

Susan Bem, IDEM 

SIP file 

Recycled Paper @ An Equal Opportunity Employer 

(I' .I 

Please Recycle Q 
pp

y 

g 

Attachment C: Administrative Checklist Commissioner's Order # 2008-02 (40 CFR 5 1, 

Appendix V) 
ATTACHMENT A 
STATE OF INDIANA 1 BEFORE THE INDIANA DEPARTMENT 

1 SS: OF ENVIRONMENTAL MANAGEMENT 

COUNTY OF MARION ) 

IN THE MATTER OF: 1 

ORDER OF THE COMMISSIONER 1 

' PURSUANT TO 326 IAC 3-5-l(c)(2)(A) 1 

FOR INDIANAPOLIS POWER & LIGHT COMPANY - ) 

HARDING STREET GENERATING STATION 1 

1 

1 

1 1 1 1. 

1 

NOTICE, ORDER, AND VARIANCE OF THE 

COMMISSIONER OF THE 

DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

To: 

This Notice, Order, and Variance of the Commissioner of the Department of 

Environmental Management ("Ordery7) is issued pursuant to IC 1 3- 14- 1 -9, IC 1 3- 14-2- 1, IC 13- 

14-8-8, and IC 13-14-2-1, and is based on 326 IAC 3-5-l(c)(2)(A)(iii). During the 

commissioner's review it was determined that the Petitioner met all requirements of 326 LAC 3-5- 

l(c)(2)(A)(iii) according to the terms specified below: 

An Equal Opportunity Employer 
2. Pursuant to 326 IAC 3

5

l(c)(2)(A)(iii), the Petitioner is requesting approval to 

demonstrate compliance with applicable particulate matter (PM) limits by continuously 

monitoring PM emissions fkom the scrubbed stack associated with Unit 7 at the 

Harding Street Generating Station in lieu of the requirement to monitor opacity at 326 

IAC 3-5-1(~)(2)(A). 

3. 326 IAC 3-5-l(c)(2)(A)(iii) provides that IDEM may approve an alternative 

requirement when "installation of an opacity monitoring system would not provide 

accurate determinations of emissions as a result of interference from condensed 

uncombined water vapor." 

4. The continuous opacity monitoring system (COMS) currently being operated on the 

scrubbed stack associated-with Unit 7 is located in ductwork prior to the unit's scrubber. To locate a-COM in the stack after the scrubber would be unacceptable due 

to the presence of condensed, uncombined water vapor. The Petitioner claims that this 

location provides unrepresentative data because operation of the scrubber removes 1 particulate emissions. Therefore, the Petitioner believes that an alternative monitoring 

plan to monitor particulate emissions using a PM continuous emissions monitoring i 

system (CEMS) on the Unit 7 scrubbed stack is acceptable. i 

FINDINGS 

CONDITIONS OF APPROVAL 

1. IDEM agrees that a COMS installed after the Petitioner's wet scrubber control device 

would not provide accurate determinations of opacity due to the interference from 

condensed, uncombined water with a COMYs light beam. IDEM also agrees that a PM 

1. The Petitioner shall install and operate an approved PM CEMS on the Unit 7 

scrubbed stack. 

,I 

2. The alternative monitoring plan shall consist of the following two phases to cover the 

period between the granting of a variance to allow discontinuation of COMS i .. 

operation (see below) and U.S. EPA State Implementation Plan (SIP) approval of the 

alternate opacity monitoring plan. 

I 

! 

CEMS installed and calibrated according to the requirements of PS-1 1 and any other 

applicable requirements is the preferred way to determine the particulate emission rate 

after a wet scrubber. 
Environmental Adjudication on October 20,2008. The COMS will continue 

operation during this period. . 

B) After completion of the PM CEMS certification, but prior to SIP approval of the 

alternative opacity monitoring plan, operation of the COMS and the compliance 

monitoring provisions applicable to Unit 7's scrubbed stack in Conditions D. 1.1 1 

and D. 1.12 .will be discontinued and compliance with PM limits will be 

demonstrated using a certified PM CEMS and all associated PM CEMS 

requirements, i.e., U.S. EPA Performance Specification 11 (PS-1 I). 

3. Upon successful completion of the certification of the PM CEMS, the Petitioner 

shall submit all required certification testing information to the IDEM Ofice of Air 

Quality. From that point on, PM compliance will be continuously monitored by the 

associated PM CEMS; and Harding Street Station's Title V permit will be amended 

to reflect this change and include all applicable operation, quality assurance and 

averaging requirements. 

ORDER 

1. This Order approves the petition submitted by the Petitioner subject to the Conditions 

of the Approval and allows Petitioner to operate according to an alternative 

monitok plan for PM CEMS for Unit 7's'scrubbed stack at Harding Street 

Generating Station in lieu of monitoring opacity with a COMS in accordance with 326 

IAC 3-5- 1 (c)(2)(A)(iii). 

2. This Order shall apply to and be binding upon the Petitioner, its successors and 

assigns. No change in ownership, corporate, or partnership status of the Petitioner 

shall in any way alter its status or responsibilities under this Order. 

VARLANCE 

Pursuant to 326 LAC 3-5-1(c)(2) fossil-fuel fired steam generators of greater than 100 

hundred million BTU per hour heat input capacity are required to monitor for opacity, unless an 

alternative monitoring request has been granted by the department. The rule also states that an 

alternative monitoring request granted by the department shall be submitted to U.S. EPA as a SIP 

revision and shall not be in effect until approved as a SIP revision. 

The Petitioner states that compliance with the COMS requirement while waiting for U.S. (C EPA SIP approval of the Commissioner's Order #2008-02 would be an "undue hardship or 

burden" for the reasons presented below and has requested a variance from the requirement of 326 
of the alternative monitoring plan approved by IDEM above. In this interim period, the 

Petitioner would discontinue use of their COMS and associated compliance monitoring 

requirements applicable to Unit 7's scrubbed stack in Conditions D. 1.1 1 and D. 1.12 and 

agrees to demonstrate compliance with the Unit 7 scrubbed stack PM limit using the PM 

CEMS. 

2. Operating COMS in the ductwork prior to the Unit 7 scrubber would not be 

representative of actual emissions since the scrubber removes particulate emissions. 

Opacity is a surrogate measurement for continuous compliance with the PM limits. 

Since PM will be measured continuously with CEMS, the monitoring of opacity should 

not be necessary. 

In making a decision on a variance'request, and whether compliance with the rule 

constitutes an undue burden or hardship, IDEM considers the environmental impact of the 

variance request, the presence of unique circumstances that set the situation apart fiom the others 

who must comply with the rule, and the financial impact on the company. 

c Based on the foregoing information, IDEM finds the following: 

1. IDEM is, under Commissioner's Order #2008-02, granting approval of the alternative 

monitoring plan that will be in place once the Unit 7 scrubber stack PM CEMS system is certified but, prior to formal SIP approval by the U.S. EPA. The alternative 

monitoring plan will ensure that the source is monitoring for compliance with 

,particulate matter emission limitations while U.S. EPA is approving the plan into the 

SIP. 

2. A PM CEMS installed and calibrated according to the requirements of PS-I 1 and any 

other applicable requirements is the preferred way to determine the particulate emission 

rate after a wet scrubber. I I 

3. This variance from opefating a COMS on Unit 7's scrubbed stack and compliance with 

the requirements applicable to Unit 7's scrubbed stack in Conditions D. 1.1 1 and D. 1.12 

1. 

is granted for the time period between successful certification of a PM CEMS and U.S. 

EPA approval of the alternative monitoring plan. 

Based on these findings, the Office of Air Quality, IDEM, has determined that the request 

submitted by the Petitioner satisfies the criteria delineated in IC 13-14-8-8 for granting a variance. 

The issuance of this variance is subject to the conditions in Commissioner's Order #2008-02 for 

an alternative monitoring plan for PM CEMS for Unit 7 at Harding Street Generating Station. 

This variance expires one (1) year fiom the effective date. This is a variance-fiom state law only ( and does not change federally approved SIP requirements. i 

! 

4 

i 

1 
affected by this order. 

Pursuant to 40 CFR 5 1.102, this Order will be submitted to the U.S. Environmental 

Protection Agency as a revision to the Indiana state implementation plan. Upon approval by the 

U.S. Environmental Protection Agency, this Order will be part of the Indiana state implementation 

plan. th 

This Order becomes effective on the eighteenth (1 8 ) day after this Order and notice of 

decision are deposited in the U.S. mail. Under IC 4-2 1.5-3-2(e), IC 4-21 53-5, and IC 4-2 1.5-3- 

7(a)(3) this Order may be appealed by filing a petition for review within eighteen (1 8) days after 

the date that affected persons were given notice through service by U.S. mail. A petition for 

review must be submitted to the Office of Environmental Adjudication (OEA), 100 North Senate Avenue, Room N-501 E, Indianapolis, Indiana 46204 as required by IC 4-21.5-3-7. The petition 

must contain facts demonstrating you are either the applicant, the person aggrieved or adversely 

affected by this decision, or otherwise entitled to review by law. Pursuant to IC 4-2 1.5-3-5(d), the Administrative Law Judge will provide parties who request review with notice of prehearing 

r conferences, preliminary hearings, stays or orders disposing of all proceedings. L, Persons seeking judicial review of this Order or Variance may do so in accordance with IC 

4-2 1.5-5. 

If you have procedural or scheduling questions regarding your request for review you may 

contact the Office of Environmental Adjudication at (3 17) 232-8591. If you have questions about 

this Order or Variance, please contact Susan Bem, Rules Development Section, Office of Air 

Quality, (3 17) 233-5697 or (800) 451-6027, press 0 and ask for extension 3-5697 (in Indiana) or 

email at sbem(iiidem.in.gov. 

Dated at Indianapolis, Indiana, this / Sy of ocp&008. 

%mas W. Easterly 

Commissioner 
ATTACHMENT B 
IPL? in Marion Count 

located at 370q ~bu* ,","$# :%gnbt;lan4$:$ :I. orl~lies ill ~intice 

All interisted persons are invited and will tie d&n 

reasonable op ortun~ty )N 01' C:I-IAl<GEs to express thet yews 

concerning- the r6posed revisioiltothe S& IJ coli111111s svldc ctlllals mI;?.(I ctll~~r.~lr~~t The pur ose of thls no- - tlq 1s [b- soll~lt publlc ;~$sy;[oqnh~S~&@~ 3 cents per line 

acconipllshed f EQ~- 

giqgeG: t:ge hr notices conlaining rule and liguie work (50 per cent of ~8%'; approval of ~ie -1s- nount) ~,d~em~~&~~~~~~~ ra proois of pilblicstion iSI.00 I~JI eacll ()~t~ofi~~ Cxcess of 1s~~) 

Order allows IRL to bper- ate a particulate matter continuous emlssidhs AMOUNT (.)F CLAIM 

monitor system (PM CEMS) in place of a cbn- ;!~y~;(~g$@~rp& IMPUTING COST 

a7 the, Hard!" Street Geqeratln Sth8~n pur. column 7.83 cms Size of type 17 poi111 sua t t~ ?he.:av$mflve hon?torjo re u rn nb in 326 IA!! ~5% (2)IA). . . The dlskontlgua .n ,pf tlOns l.O the OQM8 :' II $ e .ln- Etedti:,e tgi,'y;tF,; poti.i~,,~.r ,~;~ipe,~ohir.r q/'<.:ht~~,~er iji. ir,.v ,4[~~.i~, certified by IDWI. This thal the foregoing account is just and col.l-ccl, that the ;unount cla~med 1s legally dtlc, afler zFrfiFt$$ed l credits, and tliat no part of the same has been aid. U.S. EPA for ap mval as a revision-tb the.%^. X&g:ER:GL y,nig: 

am ased pl?hrevislon.on 

or lef&wU.ecember 12 -- -.- 

2008. dtten capmenti - should be dl&ted f~ 5usan Bern Mail Code .61- :008 50 0ffic~.of 4ir Quality - - Cle~ k ~ndiana ne artment .of 

Environinenkl ' Manage. 

Title 

ment 100 North Senate 

~venlje Indiana 011s In- 049 diana 4'6204. or fix j17) PUBLISHER'S AFFIDAVIT 233-2341. emad at lndlanapolis Central '~1- sbem@~dem.~n.~ov. Inter brary 40 .East St. Cla!r ested atties may also street Indianapolis. tndl. Slate or l~ldiillia . SS: presen! oral or wrlmn an1 4k204. . , klARlON Counly comments. pt the pyljlic The ,Commlss~oner's Or- hearing:df@ld. . , - der IS also available on ~dilrelsi~ a ptllllc hear the IDEM webilte at: IJerson;~llv ;~ppe;lrcd before me. 3 notary ~!ilbllc ~n 311d for said COIIII~Y a~ld slalc. ing on the @ropqed Slpl ht$//ww.in.gov/ldem/ revlslon: ,Requests far a 4 6.htmpco. public hearlrig must be For add~tional informa. submitted on or before tlon please contact Su- tlie llntlersiglled I<cl-ry Dotlto!~ who, bei~~g tlllly sworll, says Illat SHE IS clerk December 12 2008. If no san'8em Rules Seetion 

timely reqtle;t for a pub- Office o( Air Quality af lic hearing 1s recelved a (317) 233-5697 toll-free '*I lllr IFl'lll~\~~\1~1~1.1~ NL'?\'SIJAPEI<S :I U:!Il.\' \'I \I? Ilcsrsp:tllcr (11 ;CIICI:I~ ~II~LII:,II~~II hearin .will not be held. at 1-800-451-60171 reSSO 

lnterested partles an and ask for 3.5697 hindl- contact.~us~n~em~a~a!the anal, or via email at printed and published in the Engl~sh langllage III the clry of INDIANAPOLIS in slate 

contac taform;)tlon sbe 1dem.ln. ov. liited -below to ser! 3 .a Indl%"als:r~q$ilng.~ea- hearin hdr; been sched- sonable-accommadatlons JII~ cui111ly aforesaid. and that llir pr111te(I lilnller a~tached hereto 1s a trilc COJI~. uled. (Ji a hearin is for partioipaU6n;'lri: this schedu ed another kgal eve"t shdirld colifact the notlce w~ll be published Ind~ana Q_e artrfient of ~',li~cll was duly ~)i~blislied insad pal~er for I I~me(s) hetween Ihe dales of. stat~ng the date tlpe ~nv~ronrnental Maria e and locatlon of thk meet: ment 4meiicans ~7th 

lng. ~isadlities A? coordina- 1 111~12008 311d 1111?12008 A copy of the Commis- tor at: sloner s Order is avall Attn: ADA Coordinator 

able to. any..pergon ,upon redusst and Is a,va~lpble for ubllc Inspydion at the Pollowing locations: Indiana .De artment of 

Environrhedil Manage- ment Ofice n Alr h*lIty lhdlana Government ~ejlter-~orth 160 North Senate ~y6nue ldth floor-East wlng. lidlanap- Rela Service 711 or 1. 011s lndlana 800-!43-3333 please rp lndkhapblls Office of En. vlde a rillhimu@ o? 7; vlronmental Services hours'notlfication. 

'2700 South pelmont &v$ (S - 11/12/08 - 5361049) 

nue Indlanapolls. lnd~ana 

462i1. rorm 65-REV 1-88 NOTARY PUBLIC My commission expires: 

STATE PRESCRIBED FORMULA 'RATE PER LINE 

7.83 PICA COLUhfN - 94 POINT PUBLISHED 1 TIME = ,339 

94 POINTS 15.7 PT. TYPE - 16.49 PUBLISHED 2 TIMES= ,509 

16.49 EMS 1250 - ,06596 SQUARES PUBLISHED 3 TIMES= ,679 

,06596 SQUARES x $5.14 - ,339 CENTS PER LINE PUBLISHED 4 TIMES= 848 
ATTACHMENT C 
agreement (

document

); in final form. 

a. Date of adoption or final issuance: November 7,2008 

b. The effective date of the plan, if different 

fiom the adoptiodissuance date. 

18 days after issuance 

3. Evidence that the State has the necessary legal authority IC 13-14-1-9 

under state law to adopt and implement the plan. IC 13-14-2-1 

4. A copy of the actual regulation or document submitted for 

approval and incorporation by reference into the plan, 

including the following: 

a. Indication of the changes made to the existing 

approved plan, where applicable. 

b. The submittal shall be a copy of the official State 

regulation or document signed, stamped, dated by the appropriate state official indicating that it is hlly 

enforceable by the State. Effective date shall be stated 

in the document itself. 

5. Evidence that the State followed all of the procedural 

requirements of the State's laws and constitution in 

conducting and completing the adoptiodissuance of the plan. 

6. Evidence that public notice was given, including date of 

proof of publication. 

7. Certification that public hearings were held in accordance 

with information provided in public hearing-notice. 

8. Compilation of public comments and State's response. 

9. Technical Support Document (if source specific change). 

Attachment A 

Attachment A 

Attachment C 

No public hearing was requested as a result of the published 

public hearing notice No comments