Electronic Filing- Recived, Clerk's Office: OB/05/2013 

BEFORE THE ILLII'IOIS POLLUTION CONTROL BOARD 

ILLINOIS PO\VER HOLDIKGS. LLC and ) 

AMERENENERGY MEDINA VALLEY l 

COGEN, LLC: ) 

) 

Petitioners, ) 

) 

AMERENENERGY l 

RESOURCES.LLC ) 

) PCB No. 14-10 

Co-Petitioner. ) (Variance- Air) 

) 

V. ) 

) 

ILLINOIS ENVIRONMENTAL ) 

PROTECTION AGENCY. ) 

) 

Respondent. ) 

NOTICE OF FILING 

To: ALL PERSONS ON THE ATTACHED SERVICE LIST 

Please take notice that today we have electronically filed with the Office of the Clerk of 

the Illinois Pollution Control Board Petitioners' Responses to the Illinois Pollution Control 

Board's Questions for Petitioners. copies of which are herewith served upon you. 

1 1 / ' 

Dated: September 5. 2013 

BRO\V~, HAY & STEPHENS, LLP 

Claire A. Manning 

William D. Ingersoll 

205 S. Fifth Street. Suite 700 

P.O. Box 2459 

Springfield. IL 62705-2459 

(217) 544-8491 

Fax: (217) 241-3111 

. 'i . UI{L d !tta: t£/tLc/ 

Claire A. Mannin@ 

SCHIFF HARDIN, LLP 

Renee Cipriano 

Amy Antoniolli 

233 South Wacker Drive, Suite 6600 

Chicago, Illinois 60606 

(312) 258-5550 

Fax: (312) 258-5600 

q ATTACHMENT __ _ 
EIBctronic Filing- RBcivE!d, CIBrk's OfficE!: 08/05/2013 

CERTIFICATE OF SERVICE 

L the undersigned, certify that on this 5th day of September, 2013. l have served 

electronically the attached Illinois Pollution Control Board Petitioners' Responses to the Illinois 

Pollution Control Board's Questions for Petitioners, upon the following persons: 

John Therriault, Assistant Clerk 

Illinois Pollution Control Board 

James R. Thompson Center 

Suite 11-500 

100 West Randolph 

Chicago, lllinois 60601 

and by first class mail, postage affixed upon: 

Carol Webb, Hearing Officer 

Illinois Pollution Control Board 

1021 North Grand Avenue, East 

Springfield, Illinois 62794-9276 

Gina Roccaforte, Assistant Counsel 

Division of Legal Counsel 

Illinois Environmental Protection Agency 

1021 North Grand Avenue, East 

P.O. Box 19276 

Springfield, Illinois 62794-9276 

Faith E. Bugel 

Andrew Armstrong 

Environmental Law & Policy Center 

35 E. Wacker Drive 

Chicago. Illinois 60601 

BROWN, HAY & STEPHE~S, LLP 

Claire A. Manning 

William D. Ingersoll 

205 S. Fifth Street Suite 700 

P.O. Box 2459 

Springfield, 11 62705-2459 

(217) 544-8491 

Fax: (217)241-3111 

!leu dvf'-~"-),/ Claire A. Manning ( ) 

SCHIFF HARDIN, LLP 

Renee Cipriano 

Amy Antoniolli 

233 South Wacker Drive, Suite 6600 

Chicago, Illinois 60606 

(312) 258-5550 

Fax: (312) 258-5600 
Electronic Filing- Recived, Clerk's Office: 08/05/2013 

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

ILLINOIS POWER HOLDINGS, LLC and ) 

AMERENENERGY MEDINA VALLEY ) 

COGEN, LLC; ) 

AMEREN ENERGY 

RESOURCES, LLC 

Petitioners, 

Co-Petitioner, 

v. 

ILLINOIS ENVIRONMENTAL 

PROTECTION AGENCY, 

Respondent. 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

PCB No. 14-10 

(Variance- Air) 

PETITIONERS' RESPONSES TO THE 

ILLINOIS POLLUTION CONTROL BOARD'S QUESTIONS FOR PETITIONERS 

Petitioners Illinois Power Holdings, LLC ("IPH") and AmerenEnergy Medina Valley 

Cogen, LLC ("Medina Valley") and Co-Petitioner Ameren Energy Resources, LLC ("AER") 

seek a variance from the multi-pollutant standard ("MPS") otherwise applicable to seven coalflred power plants located in seven downstate counties (the "MPS Group") and found at Sections 

225.233(e)(3)(C)(iii) and 225.233(e)(3)(C)(iv) of the Illinois Pollution Control Board's 

("Board") rules. The instant variance petition mirrors the variance that the Board granted 

relevant to this MPS Group in PCB 12-126 on September 20, 2012. That variance decision 

provided prospective relief- specifically changing the triggering date for the emission rate set 

forth in Section 225.233(e)(3)(C)(iii) to December 31, 2019 (from January 1, 2015) and 

changing the triggering date for the emission rate set forth in Section 225.233(e)(3)(C)(iv) to 

1 
Electronic Filing- Recived. Clerk's Office: 09/05/2013 

January 1, 2020 (from January 1, 2017). The requested relief is necessary because of a planned 

change in ownership of the MJ>S Group prior to those triggering dates. 

Petitioners respectfully offer the following pre-hearing responses to questions posed by 

the Board on August 14, 2013, through Order of Hearing Officer Carol Webb. The Order directs 

a response on or before September 5, 2013. Below, the Petitioners set forth the Board questions 

requiring responses from Petitioners in bold italics and provide an answer immediately following 

each question. The answers are followed by affidavits attesting to these responses by: Robert C. 

Flexon, Chief Executive Officer and President of Dynegy Inc. and IPH; Daniel P. Thompson, . 

Vice President and General Manager for Dynegy Midwest Generation, LLC and Vice President 

of IPH; Aric D. Diericx, Senior Director - Environmental Compliance for Dynegy Operating 

Company; and Steve Whitworth, Director of Environmental Services, Ameren Services 

Company. See Attachments A- D. 

QUESTIONS FOR PETITIONERS 

Proposed Variance Conditions 

1. To demonstrate a "net benefit" of 7, 778 tons S02from 2013 through 2020, petitioners 

present a table accounting for "Variance S02 Tons," "S02 Reduced Tons," and 

"Cumulative Reductions in S02 Variance Tons." Pet. at 3, Exit. 10, Table 2. Although 

the proposed variance includes limits on 'tlte S02 annual emission rates consistent with 

Table 2, petitioners did not propose a cap on annual S01 mass emissions in tons that 

would also be consistent with Table 2 to ensure that the proposed "net benefit" is 

realized. The Board included conditions capping the annual system-wide S02 mass 

emissions, and requiring the petitioner to report annuallv to the Agencv its system-wide 

mass SO, emissions, in granting the variance in PCB 13-24. !Wdwest Generation v. 

!EPA, PCB 13-24, slip op. at 82 (Apr. 4, 2013). 

(a) Please comment on revising the proposed conditions in the variance request as 

follows: 

If at any time, Illinois Power Holdings, LLC (IPH) acquires ownership or 

control of the jive operating power stations in the Ameren MPS Group, IPH 

must assure compliance with Condition 2 of this Order and must comply with 

an overall S02 annual emission rate of 0.35 lblmmBtu through December 31, 

2019, and beginning January 1, 2020, must comply with an overall S02 annual 

2 
RESPONSE: 

Electronic Filing- Recived. Clerk's Office: 08/05/2013 

emission rate of0.23/blmmBtu. In addition, through December 31,2016. IPH 

must limit svstem-wide SO, emissions to no more than 51.289 tons; and from 

January 1. 2017 through December 31, 2019, IPH must limit svstem-wide SOz 

emissions to no more than 51,879 tons. For the purposes of this variance, 

"svstem-wide" and "the five operating power stations in the Ameren MPS 

Group" entail: Coffeen, Duck Creek, E.D. Edwards, Joppa, and Newton 

Energy Centers. IPH must also report to the Agency its svstem-wide mass so, 

emissions each vear o(the variance with its Annual Emissions Report. 

Petitioners appreciate the careful review conducted by the Board, as is evident in this and 

the following questions. · While nothing in the Act or the Board's rules requires Petitioners to 

demonstrate a "net benefit" to the environment when requesting a variance, IPH remains open to 

considering possible alternative approaches to address the Board's interest in ensuring a "net 

benefit" and, in that vein, has engaged in discussions with the Illinois Environmental Protection 

Agency ("IEPA") related to reducing overall emissions in illinois. Significantly, JEPA and IPH 

have executed a Memorandum of Agreement ("MOA") which will have the benefit of reducing 

the environmental footprint of Dynegy subsidiary plants in lilinois, including the operating MPS 

Group plants anticipated to be acquired in the underlying transaction. Specifically, as relevant to 

the MPS Group, IPH has agreed to retire E.D. Edwards Unit 1 as soon as allowed to do so by the 

Midcontinent Independent Transmission System Operator, Inc. ("MISO"). 

IPH would accept a Board condition, consistent with the MOA, which would make the 

retirement of E.D. Edwards Unit 1 an enforceable condition of the variance. Other environmental 

benefits resulting fTOm the MOA, ancillary to the requested variance but nonetheless, in part, 

subject to closing on the underlying transaction, are the permanent retirement of the air operating 

permits at Stallings (Madison Connty) and Oglesby (LaSalle County) Combustion Turbine 

Facilities and the installation of Advanced Gas Path Technology at Kendall Power Station 

(Kendall County). Petitioners assert that the proposed compliance plan, enhanced by the agreed 

3 
EIBctronic Filing - RBcivBd, CIBrk's OfficB: 08/05/2013 

approach in the MOA, is more appropriate than imposition of annual emission caps for the 

following reasons. 

First, Petitioners seek continuity for the variance granted in PCB 12-126, which the 

Board already recognized provides a net benefit. Annual mass emissions caps were not part of 

the variance granted in PCB 12-126. As it is prospectively triggered, Petitioners reasonably' 

transacted with the understanding that the MPS Group's S02 emission limits would remain annual 

system-wide emission rates and that relief had been granted by the Board in a manner that would 

allow a reasonable and necessary period of time for market conditions to recover prior to required 

completion of the FGD Project at the Newton Energy Center. 

The projected net environmental benefit resulting from the variance request, should the 

request be granted, is constructed and demonstrated pursuant to the same methodology deemed 

appropriate by AER and the IEPA, and accepted by the Board in PCB 12-126. In developing 

Table 2, the Petitioners here used an annualized heat input over the time period deemed 

appropriate in the above-referenced methodology. The baseline heat input is thus believed to be 

reasonable for purposes of this Petition, as the baseline heat input and projected mass emissions in 

tons S02 were deemed reasonable for purposes of the variance petition in PCB 12-126. The 

Petitioners recognize that in a down energy market the actual heat inputs may be lower than those 

utilized to develop Table 2, thus resulting in fewer actual tons of S02 generated than allowed 

under the MPS and greater environmental benefit than set forth in Table 2. While Petitioners 

fully expect that emissions will be consistent with the numbers provided in Table 2, Petitioners at 

this time do not support annual emission caps relative to the MPS Group, for the reasons 

expressed above. 

4 
Elsctronic Filing - Rscivsd, Clsrk's Offics: 08/05/2013 

However, as to reporting of the annual emissions for the five operating power plants, IPH 

would accept a proposed Board condition similar to that suggested in the final sentences of the 

Board's question, requiring that it report the mass S02 emissions of the five plants it will acquire 

in the underlying transaction, such as: 

IPH must report to the Agency the mass S02 emissions each year of the variance 

with its Annual Emissions Report. For purpose of this condition the mass so2 

emissions would be the combined tons of S02 emitted by the five operating power 

stations in the Ameren MPS Group: Coffeen. Duck Creek, E.D. Edwards, Joppa 

and Newton Energy Centers. 

Second, as set forth in the Petition at pages 5 -10, a cap on annual S02 mass emissions in 

tons is contrary to the spirit and intent of the underlying MPS. After much negotiation, Ameren 

and IEPA agreed that for the Ameren MPS Group, a system-v.-ide rate-based regulatory structure, 

based upon rate of emissions, presented the best approach. The MPS regulatory approach 

establishes limits that are numeric S02 emission rates in pounds per million Btu (lbs/mmBtu) or 

emission rates based on a percent reduction Imposing additional annual emission caps would 

rewrite the MPS to eliminate operating flexibility intrinsic in the rate-based MPS regulatory 

structure, particularly where the "net benefit" of reductions in the requested variance is reflected 

over the entire variance term. 

The Petitioners recognize that limitations on mass emissions were part of Midwest 

Generation's compliance plan in PCB 13-24. However, we understand that Midwest Generation 

proposed annual mass S02 emissions caps for its own reasons to demonstrate that the company 

would achieve a net environmental benefit within the original timeframe of the Combined 

Pollutant Standard ("CPS"). By doing so, Midwest Generation planned all of its requests for 

relief in conjunction with the various compliance plan components and within its predicted 

operational circumstances. Nonetheless, the mass emissions linlitations incorporated in the 

5 
Elactronic Filing - Racivad, Clark's Offica: OB/0512013 

variance order in PCB 13-24 are duplicative in purpose and are not consistent with the CPS and 

MPS. AER took a different approach in PCB 12-126 by accepting a voluntary lower interim 

emission rate (consistent with the system rate structure of the MPS) and a construction schedule 

for the Newton FGD Project in exchange for more time to comply with the MPS. 

Thus, in lieu of the emissions cap approach taken by Midwest Generation, Petitioners 

here assert that the proposed compliance plan provides sufficient assurance of achieving betterthan-otherwise-required emissions reductions, and already incorporates features not anticipated or 

required under the MPS. 

Further, in its recommendation, filed on September 5, 2013, the IEPA states that it 

"agrees with Petitioners that there will be a continued net environmental benefit if the Board were 

to grant the requested relief subject to the terms and conditions contained in the Petition." 

Recommendation, at p. 29. Nonetheless, IEPA recommends three additional conditions in order 

to "ensure and enhance this environmental benefit." !d. The Petitioners have briefly reviewed 

those recommendations and believe that they are consistent with the approach taken in the 

requested variance. 

The condition related to the closure of E.D. Edwards Unit 1 has been agreed to in the 

MOA and, as stated above, IPH would accept its inclusion as a variance condition, consistent with 

the MOA. The other proposed conditions each relate to the operations of specific stations in the 

MPS Group (use of low sulfur coal and operational efficiencies). IPH would not object to the 

inclusion of appropriate language concerning these proposed conditions in a Board Order. Given 

the above, the Petitioners continue to believe that the imposition of annual emissions caps is 

neither warranted nor appropriate. 

6 
Electronic Filing - Recived. Clerk's Office: 08/05/2013 

(b) Please comment on including a condition of tlze variance that would cap S02 

mass emissions on an annual basis from tlze E.D. Edwards station at 2012 

levels of 11,803 tons until Unit 1 is permanently retired. Pet. Exit. 6. 

RESPONSE: 

For the reasons discussed above, Petitioners do not at this time support an annual S02 

mass emissions cap for the E.D. Edwards station. Although E.D. Edwards is located in an area 

that the U.S. EPA has recently designated as nonattaimnent with the 1-hour S02 National 

Ambient Air Quality Standard ("NAAQS"), the Board's suggested annual 802 emissions cap 

would not provide assurance of compliance with the short-term !-hour 802 NAAQ8 or even 

assure progress toward attaimnent of the standard. Moreover, should the nonattainment area 

designation become applicable, the IEP A will need to perform an air emissions modeling 

analysis to determine culpable sources and would then need to determine an appropriate 

emission limit or control measures as part of its state implementation plan ("SIP") attainment 

plan. 1 Thus, an annual S02 emissions cap on the E.D. Edwards station at this time is premature 

and not warranted. 

In addition, Petitioners respectfully respond that the Board's suggested use of the E.D. 

Edwards station's 2012 actual 802 emissions as an annual cap for the term of the variance is not 

representative of the station's normal operations, since in 2012 the station's operations were 

lower than usual due to reduced demand and other operational issues. Specifically, the E.D. 

Edwards station's 2012 heat input was approximately 18% lower than the station's 2007-201 I 

annual average heat input. 

(c) Please comment on including a condition after Unit 1 is permanently retired 

that would cap annual S02 mass emissions from the E.D. Edwards station at a 

lower level to reflect tlze operation of only Units 2 and 3. 

1 Notably, the E.D. Edwards station is only one of several major sources that, as identified U.S. EPA, may contribute 

to the 1-hour S02 NAAQS exceedance monitored in the Pekin, Illinois area. 

7 
Electronic Filing - Recived. Clerk's Office: 08/05/2013 

RESPONSE: 

An annual SOz emissions cap is not believed to be appropriate for the reasons discussed 

above. 

New PMl.s National Ambient Air Ouafif!, Standard (NAAOSI 

2. Please provide a copy oftlte memorandum referenced in footnote 33 on page 66 oftlze 

petition: "USEPA Memorandum, From: Gina McCarthy, Assistant Administrator, To: 

Regional Administrators, Regions 1-10, Subject: Initial Area Designations for tlze 2012 

Revised Primary Annual Fine Particulate National Ambient Air Quality Standard 

(Apri/16, 2013)." 

RESPONSE: 

A copy of the requested memorandum is attached hereto. See Attachment E. 

QUESTIONS FOR THE PETITIONERS AND THE AGENCY2 

Effect on PCB 12-126 Variance 

6. Please address the ongoing legal effect, if any, of tlze variance granted in Ameren 

Energy·Resources, PCB 12-126 (Sept. 20, 2012), if tlte requested variance in the 

instant case is granted and the transaction by which IPH would acquire AER 's active 

coal-fired power plants goes forward. 

RESPONSE: 

The variance relief granted in PCB 12-126 will be superseded by the Board's granting of 

the relief requested here following the closing of the transaction and the transfer of ov.'llership of 

the Ameren MPS Group to the Petitioners IPH and Medina Valley. If that scenario does not 

occur, Petitioners understand that the Order in PCB 12-126 will remain effective as to AER 

without change. 

2 As Questions 3 - 5 were directed solely to the JEP A, the Petitioners do not here provide a response to those 

questions. 

8· 
Electronic Filing - Recived, Clerk's Office: 08/05/2013 

CONCLUSION 

If the Board members or staff require further information and/or have follow-up 

questions related to these responses, the Petitioners would be happy to provide such and 

respectfully suggest that to the extent such questions can be provided in advance of the hearing, 

the better equipped the Petitioners will be to provide an informed and thorough response. 

Respectfully submitted, 

ILLINOIS POWER HOLDINGS, LLC 

/) . 11 . 

LA Ltfi /f · !Zl[tl lttt By: 

One of Its Attorneys / 

BROWN, HAY & STEPHENS, LLP 

Claire A. Manning 

William D. Ingersoll 

205 S. Fifth Street, Suite 700 

P.O. Box 2459 

Springfield, IL 62705-2459 

(217) 544-8491 

Fax: (217) 241-3111 

cmanningfalbhslaw.com 

wingersollfalbhslaw.com 

'" 

9 

AMEREN ENERGY RESOURCES, LLC 

and AMERENENERGY MEDINA 

VALLEY COG EN, LLC , 

SCHIFF HARDIN, LLP 

Renee Cipriano 

Amy Antoniolli 

233 South Wacker Drive, Suite 6600 

Chicago, Illinois 60606 

(312) 258-5550 

Fax: (312) 258-5600 

rcipriano@schiffhardin.com 

aantoniolli@schiffuardin.com 
Elsctronic Filing- Rscivsd, Clsrk's OfficB: 08/05/2013 

ATTACHMENT A 

A-FFIDAVIT OF ROHERT C. FLEXON 

My name is Robert C. flexon. I am the President and Chief Executive Officer ofDyncgy 

Inc. (''Dyncgy'"). I am also the President and Chief Executive Officer of lllinoi' Power 

Holdings, LLC {"JPH"), an indirect. wholly O\\lled subsidiary ofDynegy. My business address 

io 601 Travis Street, Suite 1400, Houston, Texas 77002. I make this affidavit based on personal 

knowledge or on knowledge I have obtained through inquiry of individuals employed by Dynegy 

or its affiliates. 

I have reviewed the Board's questions that have been presented in the llearing Officer 

Order dated August 14,2013. I have also reviewed the Petitioners' responses to those questions, 

have assisted in their development, and concur in these responses. To the best of my knowledge 

and belief, the facts contained therein are true und correct. 

fURTHER, Affiant saycth not. 

DATED: qj 

~i' 

b /1 ~ 

Subscribed and sworn to 

before me this S"T"-' day 

of September 20) 3. 

' > 

___ _.L(1f=.94~ ,<j 

NOTARY PUBLIC 

~~~j c :J{j£) ~ Robert C. Flexozy 
EIBctronic Filing- RBcivBd, CIBrk's OfficB: 08/0512013 

ATTACHMENT B 

AFFIDAVIT OF DANIEL P. THOMPSON 

My name is Daniel P. Thompson. I am Vice President and General Manager lor Dynegy 

:v!idwest Generation, LLC ("DMG"), an indirect, wholly owned subsidiary of Dynegy Inc. 

("Dynegy''). I also serve as Vice President of Illinois Power Holdings, LLC ("!PH"), which is 

also an indirect, wholly owned subsidiary of Dynegy. My business address is 604 Pierce Blvd., 

O'Fallon, llli.nois, 62269. I make this affidavit based on personal knowledge or on knowledge I 

have obtained through inquiry of individuals employed by Dynegy or its affiliates. 

As Vice President of DMG, I am responsible for the safe and efficient operation of 

Dynegy's coal-fired electric generating fleet in Illinois. My responsibilities include oversight of 

enviromnental compliance at Dynegy's Illinois coal fleet. Subject to the IPH-Ameren 

transaction closing, this responsibility will include the five plants in the Ameren MPS Group that 

are the subject of the requested variance. I have reviewed the Board's questions that have been 

presented in the Hearing Officer Order dated August 14, 2013. I have also reviewed the 

Petitioners' responses to those questions, have assisted in their development, and concur in these 

responses. To the best of my knowledge and belief, the facts contained therein are true and 

correct. 

FURTHER, Affiant sayeth not. 

DATED: --~__;::3,::...._ __ 

Subscribed and swam to /) 

before me this Y-1:':: day ; 

~fS~~~~~~er 2013.~~--

.NOTARY PUBLIC 

GLENN AARON COWI.ES 

NOTARY PUBliC, STATE OfMI 

GOWTY OF VAll BUREN 

MY COMMISSION EXPIRES Aug 16,2017 

ACTING IN COUNTY OF 11 B ;.._ ( vc. 11 H -, o . 

o;G1iel P. Thompson 

l 
EIBctronic Filing- RBcivBd, CIBrk's DfficB: 08/0512013 

ATTACHMENT C 

AFFIDAVIT OF AR1C D. DIERICX 

\1y name is Anc D. Diericx. l am the Senior Directc>r- Environmental Compliance for 

Dynegy Operating Company. Dynegy Operating Company. an artiliate of Dynegy Inc. 

("Dynegy"), provides business services to Dynegy's operating subsidiaries, including Illinois 

Power Holdings, LLC (''!PJ-T'} and Dynegy \1idwesl Generation, LLC ("DMG"). My business 

address is 604 Pierce Blvd., O'Fallon, Illinois, 62269. I make this affidavit based on personal 

knowledge or on knowledge I have obtained through inquiry of individuals employed by Dynegy 

o:· its affiliates. 

1 have been employed with Dynegy in my current position or similar enviromnental 

compliance positions for the past 13 years. As Senior Director- Environmental Compliance, my 

responsibilities include oversight ol' penni!ting. regulatory and policy development, and 

compliance for air, water, waste and orher envirorunental matters at D\1G's coal-fired power 

plants in 111inois. as well as Dynegy's power plants in other states. Subject to the IPH-Ameren 

transaction closing, this responsibility will include the five plants in the Amercn MPS Group that 

are the subject of the requested vilriance. I have reviewed the Board's questions that have been 

presented in the Hearing Ofilcer Order dated August 14. 2013. 1 have reviewed the Petitioners' 

response to those questions, have assisted in their development, and concur in these responses. 

To the best of my knowledge and belief, the facts contained therein are true and correct. 

FURTHER, Afiiant saycth not. 

' I 

ED -11 :;:> . '7 :i D AT : I .· ._) - _;/ I·,.,!_ __ _ 

Subscribed and sworn to ., .· belorc me this _S ' ' day 

ofSeptembe _flr:f.:=j- s··1 

- .</ 

/ 

~-~ ~ '-...._ 2==z--rv""'\.--'< -...._ 

-~OTARY PUBLIC ) 

........_____ ___ -- ------ .. 

_ ..... --·-

"OFFICIAL SEAL" 

DANE SCHICKF.DANZ 

NotaJy Public • State o11JIIoolo 

My Commission ;xp~ras June 14, 2016 
EIBctronic Filing- RBcivBd. CIBrk's OfficB: OB/05/2013 

ATTACHMENT D 

AFFIDAVIT OF STEVEN C. WHITWORTH 

I. My name is Steven C. Whitworth, and I am employed by Ameren Services 

Company as Director, Enviromnental Services. Ameren Services Company provides business 

services to Ameren Corporation's operating companies including Ameren Energy Resources 

("AER") and its subsidiary companies, Ameren Energy Generating Company ("GENCO") and 

AmerenEnergy Resources Company. I have been employed with Ameren Services Company 

since I 998 following the merger of Central Illinois Public Services Company and Union Electric 

. Company. During the course of my career I have worked in the environmental air quality and 

pennitting arena since 1989. I have been in my current position since 2007. In addition to 

supervising staff personnel, I am responsible for implementing policies and procedures relating 

to enviromnental compliance. In this capacity, I am responsible for representing the Ameren 

Companies before regulatory and administrative bodies with respect to state and federal 

pennitting conditions and regulatory requirements. 

2. I have read the Petitioners' Response to the Illinois Pollution Control Board's 

Questions tbr Petitioners, to which this affidavit is attached. 

" 
Electronic Filing - Recived, Clerk's Office: 08/0512013 

3. 1 attest that the statemertts of facts contained in the Petitiorters' response to the 

Illinois Pollution Control Board's first question are true and correct to the best of my knowledge 

and belief 

Further affiant sayeth not. 

Subscribed and sworn to before me 

this 5th day of September, 2013. 

CHl\13~89809.1 

LYNNM SMITH Nat~ry Pvbl1c- Notary Seal 

STATE OF MiSSOURi 

Commission for St. louis City 

My CorrHnl:;slon E:qJires St!pt. 28. 2.014 

Co·nm!ssion #i0402618 
Electronic Filing- Recived, Clerk's Office: 08/05/2013 

ATTACHMENT E 

UNITED STATES ENVI.RONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

APR 1 6 2013 

MEMORANlHlM 

OFFICE OF 

A;lR AND Rr~Dir\TlON 

SUBJECI': Initial Area Designations tbr the 2012 Revised Primary Annual Fine Particle 

National Ambient Air Quality S.tandard · 

FROM: Gina McCarthy c:A~") Assistlmt Admin€f-ato~· . ~· 

TO: Regional Adminislrators, Regions l-1 0 

This memorandum provides irum.matiort on the schedule and pro:cess tor initially designating 

areas for the pmpose of implementing the 2()12 r~vlsed prim!lry annual fine particle (PM2.!) 

nalional ambient air quality standard (NAAQS). ln. addition, tltis nte111orandmn:Jaentiiios 

important factors that the EPA intends to .evaluatdn making tina! nonattainment area boundary 

dectsions for this standard. The EPA reeomm~nds :tharstates and 1rlbes also· consider these factors 

in making their recommendations for area·designations and nonattainnient area boundaries. As in 

prior designations for the PM2.5 NAAQS, the EPA will alSo consider ariy other relevant 

information for this purpose. Please share this inj'ormati:on with state and tribal agencies in your 

Region. 

On December 14, 20!2, tbe EPA promulgated li revised primary.anntlal PM2.5 NAAQS (78 FR 

3086, January 15, 2013). In that action, the EPA revised the ptiumry annual Pl\ch.; standard, 

strengthening it from I 5.0 micrograms per cubic meter. (~g/m } to 12.0 ~lg/m ; retained the 

existing 24-bmu· PM2.; stand•)rd at 35· j.lglm3

; retnihed the existing 24-hourPM10 (coarse pmticle) 

rrtandard at 150 11g!m\ and retained ·tile current silite of secondary l'lvr st>1ndards. The EPA 

revised the prim My mmual PM25 standard based on an integrated ·assessment of an extensive body 

of new scientific evidence, which·substaritially strengthens our body of knowledge regarding 

PM2 .. ,-related health effects. The revised primary annual PM,,, standard will provide increased 

protection ·Jor children, older adults, persons wiih pre-existing heart: and lung disease, and other 

at-risk populations ''gainst an array ofPM1.s-re!ated adverse itea!th effeets, including J:>remature 

-------morWTJty,!ncreaswnospltal adnussions and·elnergency d,piil:tment vi,~its, and development and 

exacerbation of clrronic respiratory disease. 

Clean Air Act Requirements 

Section 107(d) oflhe Clean Air Act (CAA) governs the process for initial area designations ~fter 

ti1e EPA establishes a new OJ' revised NAAQS. lJnder section 1 07(d), states arc required to submit 

area designation l'ecornmendations to the EPA, by a date speci11ed by the EPA, which cannot be 

lnhHTiot Addms,') (UHL} ~ http:/1\'tww.apa.gov 

P.coychui/Rooyclr:ab!,_ • f'l!!ltoa with 1/ogolflbl'l Oi Bat!l}d Ink~ Otl FlPGyclcd Pnpor (M!nlmum !lO'% Postr.ontllfMtJ 
Electronic Filing - Recived, Clerk's Office: 08/0512013 

sooner than I 20 days after promulgation. of the new or revised NAAQS and cannot be later than 

l year after the promulgation of the NAAQS. If, after careful consideration of these 

recommendations, the EPA be.lieves tlw.t it.ili necessary to modify a state'·s recommendation and 

to promulgate n.designation different from a slate's .rccon:imendation, then the EPA must notify 

the state at least I 20 days prior to promulgating the final designation and ti1e EPA must provide 

the state an opportunity to comment on the potelithtl modification. These modifications. may relate 

either to the designation of an area or to· the boundaries ofan ar.ea. The CAA requires the EPA to 

complete the initial d!:signation process within 2 y~ars of promulgation of a new or revised 

NAAQS, unless the Administrator has insufficient information to make initial designation 

decisions io the 2-year time franlc. In such circumstances, the EPA may take up to I additional 

year to make initial area designation decisious (i.e., no later than 3 years after promulgation of the 

standard). While section I 07(d) of the CAA specitlcaJly addresses the designations process 

between the EPA and .st~1:tes, ·the .EPA intends to. follow the same process to the extent practicable 

for tribes that choose to make initial designation recommendations pursuant to section 30 l (d) of 

the CAA regarding tribal authority, and ih,e Tribal Authority Rule (TAR) (63 FR 7254; 

February 12, 199.8). To provide clarity"·.and consistei)cy, ln December20 I! the EPA ·issued a 

guidance memorandum conceming collaboration between th<)EPA and tribes during the 

designations process. 1 ln aecordanc~ with. the TAR and the December 2011 tribal designations 

guidance memorandum, and .in eonsu!tation.wiih the· tribes .• ;the· EPA intends to designate tribal 

areas on the same schedule as stat.e designatio~'ls. !fa state or tribe does not submit designation 

recommendations .• then the EPA will promu\gate the initial designations that it deems appropriate. 

Schedule for PM,.. Initi&l Area Designations 

Consis.tent with the schedule in se.ction.l07{d)0) of the CAA, as stated in the PM2,5 NAAQS final 

mlc, state Governors are requi.red to ·submit; .and.tr.ibcs can choose to. submit, their initial 

designation recomniendations.to tlie"EPAtbrthe 2012 ann~;t.al PM2.s NAAQS to the EPA no later 

than! year following promulgation ofthe.:revised NAAQS; or by Decemb~r 13,2013. Because of 

the form of the 2012 annual Fi\12.5 NAAQS, the ·EPA believes that these recommendations should 

be based on air quality dtita from the three most recent y.cars ofmoniloriltg data available at that 

time, i.e., 2010 to 2012 .. Ba~ed l!JlOn these monitoring data, States should identify areas as 

attainment, nonattainment, oi· uncla~sifiable on the.basis of ava,ilable inforn>'<Jction.2 If the EPA 

believes it is necessary to make any modificat.icms. to a state's or tribe's initial t•ecommendatlons, 

including area boundaries, then.the El' A. is Tequited ·to notifY the state or tribe of this fact by ·letter 

no later than 120 days prior to finalizing the d~..signation. The EPA intends to issue this "120-day 

1 Guidance to Regi<ms for Worldngwith Tdbes<luring the National. Ambient Air Quality Standards (NAAQS) 

Dcsi_gnations Process. Memorandum H·om S~ephen D, Pagc1 D'irect-or.,.EPA OAQPS to Regional Administrators, 

Regions 1-X. DeMmber 20,2011. Avaiilib!e at 

hlrp:!lwwrv. cpa.govlttnloarpgll 1 !mcmwrani/a12"Ql21J I J 7 naaqsguidonce.pclf ----· · .. _- __ __;;_Forihdnh'tnFP·M-arca--dcsi·g~ti_o.ns-irr260S-"C'l997-tmnttni-PMiTki1Uifdn!'tl}-arlti-2009"-(200-6Pt-=limifl'M~.s ~tai'ruara;;··· · ~ ---···---

\he EPA used a des"igwation category Df' 11U1)c}ass!"f1abi~/atta1nmc:ntu for ~reas that nre mon'itol'·lng attair1ment and for 

arm1s that do not )lu-ve monitors but fol' which tb~.EPAhas reosml to- be.Uev.e.are "likely nrtaintuent and (Ire not 

contl'ibuting to nearby viOlations. Tho .EPA reser\ted th~ ~ategory 11Unclas"siflablc:: 11 for areas where the EPA cn[mot 

dt:::termine"basod On available infOrmation wlrcthc_!' the ar¢a is meetin_g.o1· not·meeti~g 11)~ NAAQS or wherC lh~ EPA 

has not dctnt'minod that the area contdbut.es to a tfeniby vloJntion. WJ1ile states tan sl1bmit recommendations 

identifying urens flS "~tttainment," the E-PA cip6ct"s to continue to usc the 11 ttnclassifiable/artainment" categot"y for 

de•ig11ations for the 1012 ·onnuai·PM;s 1'-lAAQS. 

Page 2 of34 
EIBctronic Filing- RBcivBd, CIBrk's OfficB: 08/05/2013 

letter" no later than August 14, 2014. If a state or tribe has additional information relevant to the 

area that it wants the EPA to consider with respect to a designation recommendation that the EPA 

plans to modify, then the EPA i·cqutlsts that such information be submitted no later than 60 clays 

from the date of the EPA's J 20-qay le\Jer~ Tliis schedule will ensure that the El' A can fully 

considex any Sllch .additional information prior to issuing final designations. Also,. although 

section 1 07(d) explicitly exempts the des\ghaliori process fi·om the normal public notice and 

comment rulemaldng process, ilie EPA docs intend to consider public input in the designation 

process. Accordingly, we plail to provide~~ 30-day public comment period immediately foJlowing 

issuance of the EPA's letters responding to the designatiOil recommendations from states and 

tribes.3 Attachment I summarizes this anticlpated schedule. 

Defining Nonattainment Areas 

Section 1 07(d)(l) of the CAA dir~cts the EPA to designate an area "non.atiainment" i.f it is 

violating the NAAQS or if it is contributing to a violation ofthc NAAQS i;1 a pearby area. To 

start th~ initial area designations proc~ss, stares and th¢ ,EPA mustidentify the areas that are 

violating the NAAQS. Thus, the first step in designating .nonattaimnent areas is to identify air 

quality monitoring sites with data th~t show a violation qfth0 2012 annual PMu NAAQS. For 

this purpose, the EPA intends to eva!u.ate areas 11sing the most.recent complete three consectnive 

calendar years of quality-assured, certified air qtlallty data in the EPA's Air Quality System 

(AQS). 4 In general, violations are idenlifiep lising data from. Feqeral Reference Meth<id (FRM), 

Federal Equivalent Method ·(FEM), and/or Approved Regional Method (ARM) monitors that are 

sited and operated in accorcj£;J1Ce with 40 CFR Part 58, Pi·ocedures fon1sing the air quality datu to 

determine·whethcr a violation has occurred are.giveli in40 CFR Part 50 Appendix N, as revised 

by a final action published in tbeFedera/Register .Qn JAnuary !.5, 2013 (78 FR 3086), We expect 

that in providing designation recommendations to the·EPA by December 13, 2013, states and 

tribes will also review air quality data from 2010 to 2012, However, prior to the EPA makin.g 

final designation decision.s, quality~assured, certified air quality monitoring data from 2013 may 

be available, If so, the EPA's fmal designation decisions w1lllie based on data from 20 ll to 2013. 

States may also update their designation recommendation~ when these new data become 

available. The EPA notes that the process .for evaluating areas that are not themselves violating 

the NAAQS, but are nearbyarcas contributing to the violations of"the NAAQS in a violating area, 

is discussed in more detail below in cot\nectio.n with the process for determining appt:opriate 

nonattuinment a:rea. boundaries. 

Ambient Air Monitoring Requirements in Near-Road Environments 

'

1 Section 1 07(d)(2) ·explicitly proVides that do-.signal.ions -o·1·e exempt frorn the notice nnd conuncnt provisions of the 

Admini}itrntive Prclc-Cdure Act (APA}. Likewise, de:.;igno.tions undtw section 1 07(d) nrc 11ot ftlnong the Jist of actions 

----•thnl-ar.c...subject-t.o-the...twtice.and-comtJWI~t-proc~m:cs-o..t:secr.iml-3-Q-:7{d},..':J:hus:rne-ithor-the-GAA-nar-HH1-A.:P--A-r.t:~qulre-----. -· --·-·-

notice and commentrulemaking_fol' .promUig~tion of the cJesi~nf1tions for thfs or- !lilY otherNAAQS. Haw eYe-r, the 

EPA intends to solicit direct public comnH:~it bn its responses to 'the initial arc-a designation recommen.d[ltloos of the 

states 011d tribes beouuse we believe this proce~s\vlll be l!Seful to gl)ther udditionnl informqtion aod to nssure tl1at the 

Agency is more clire.ctly aware.- of iSsues raised bY initial area desi.gnations. Despite the. EPA's intet\tion to provide a 

public comment period, however, the process for ioitlal area de:;;ignations un~er the 2012 p1·imnry annllal PM:t.s 

NAAQS is not on oction subject to notice and comment undo•• either CAA 307(d) or U1C APA. 

'

1 This int01'r11a!'ion is -available on the IZPA•s·wcbsitc at www.epa.gov/trnlairslair.wqd. 

Page 3 of34 
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EIBctronic Filing - RBcivBd, CIBrk's OfficE!: 08/0512013 

In the final rule for the revised primary annual PM2s standard, the EPA also finalized changes to 

the ambient air monitoring, reporting, and network design requirements applicable to the PM 

NAAQS, including the addition of anear•road component to the PM2.s monitoring network. 

Because the EPA is requiring placement of the first phase ofn$ar-i'oad monitors by Jammry 1, 

20 !55

, we do not anticipate having·sufficient data available ftom any of the newly-required 

monitors in time for consideration il1the initial des\gnatiotJS for the 2012 annual PM2.s NAAQS in 

2014. The EPA belleves that given the form of the NAAQS, it is tiecessary to have three complete 

calendar years of quality-assUl'ed, certitled alrqualily monitoring data from a l'M2.s monitor for 

that monitor to be used forcom]'llitmce purposes alid.in particular for designations purposes.6 The 

EPA docs not expect to have.a comptete set ofPMz.; air qualily data from these new monitors 

until2018. 

Exceptional Events and .Dcsignathms 

Exceptional events have the potential to. influence.-regu!atory decisions, including it1itia! area 

designations for the 2012 annu~l PMuNAAQ$· .. Air quality motJ.i!oring data affected by 

exceptional events may be excluded from use.in identifying n. violation at.a monitor if the data 

meet the criteria for exclusion, as specified in the .Final Rule oil. the Treatment of Data Influenced 

by Exceptional Events ('72 FR ·13560; March 22,2007). In the 2012 PM NAAQS ±lnal r.ule, the 

EPA established schedules for.air agencies . .to. flag data inJ:Juettc.ed.by exceptional. events and 

submit rehited documentation sp.ecrtically !or PM data collected from 2010 through 2013 that will 

be use.d in the initial designations process for tl1e 2.012 annual PM1..s NAAQS. Although some of 

these deadlines are accelerated, they Were promulgated: to align closely with the timing of the 

initial designations recommendatiOtlS from ·states nnd tribes in Dccembct 2013 and/or the EPA's 

potential issuance of 120-day letters pertaining to designations in August 2014. Thes~ schedules 

reflect the EPA's interest in ensurlng:-that we can futly consider exceptional events claims, as 

appropriate, in the tina! designations deCisions. The EPA regional offices a.re encouraged to work 

with states and tribes with exceptional event .claims to prioritize and expedite the demonstration 

development and rev.iew 11roccss for tb.ose c!<Ums having the potentia! to influence regulatory 

decisions such as the i.nitial desigMtionspi·oce.ss. Sitililarly, the EPA encom·ages states. and tribes 

to co.ntact and collaborate with the appropriate EPA regional oil'ice aftel'ldentifying any 

exceptional event influencing ambient air quality concentrat1ons in a way that could potentially 

affect compliance with the 2012 anm1al PM2.s NMQS. The promulgated exceptional event 

schedules are identified in Attachment 2. TheEl' A has also developed interim exceptional events 

implementation guidance documents that air agencies can use when reviewing potential 

exceptional events and developing appropriate exceptional event demonstrations. Additional 

in.fom1ation and examples of exceptional event submi.~sions and best practice components can be 

found at the EPA's excepiional events website located at 

=======~-----·----····--·--·---·· 

'lulhe p1·omulgated PM NAAQS (78 FR 30g6),the EPA fmalb.ed a phased schedule for deployment of the I'Mu 

monitors at near-road stations and requjie(l collocating tl niinhnurn of one PMz.s monitor in each Core Based 

Statis\icnl Area (CBSA) with a population ;:.2.5 million with a ne01·-road NO, monitoring station by January 1. 2015. 

PM2..s monitors nl nearwroad stations must be cnlloca1ed and ·operational at the t·emaining Cl3SAs (i.e., those CBSAs 

witil populations ;:1 million, but less than 2.5milli<m)-by January I, 2017. 6 Data completeness crlteria, including data substituti0nlncthodol6gie!i1 ·are specified in Appendix N of 40 CFR part 

50. 

Page 4 of34 
EIBctronic Filing- RBcivBd, CIBrk's OfficB: 08/05/2013 

http:/ lwww. epa.govlttn/cmalysis/exevents. him. 

NonRttainment Area Analyses mid Bonndlwy Determinatinn 

The EPA believes that the boundaries for each nonattainmcnt area should be evaluated and 

determined on a case-by-case basis considering the.specific facts and clrcumstanc~s unique l\} the 

area. Section I 07(d) explicitly requires that the EPA designate as nonattainment not only the. area 

that is violating the standard at issl!e, bui .also those 1iearby are.as that contribute to the violatiDii in 

the violating area. After identifying each.rncmitor or· groUp 0'£ mollitors that indicate a violation of 

the standard in an area, the· EPA intends tO bt')gin its analysis of wh~t.areas contribute to that 

violath1g area by considering those cbtmties in the entiremetropoliianarea (e.g., Core Based 

Statistical Area (CBSA) or Combined Statistical Area (CSA)) ·in which the violating monJtor(s) is 

(arc) I ocated. The EPA also intep.ds tu .evaluate .an.y a<:ljaeeJjt'counties to the CBSA or CSA that 

have the potential to contrib\lte. The EPA believes thati't is appropriate to stl!ft the analysis with 

the relevant CBSA or CSA for the area bec.ause measured ambient.PM25 concentrations across 

urban-scale distances tehd to be highly correlated and .comp1;lsed of direct emissions ~nc! multiple 

secondarily-formed pollutants attribJ.ltable to a variety ofsources commonly found throughout 

urbanized areas. 7 In other words, violations ofthe aniiual PM~.s NAAQS are usmil!y the result of 

emissions from a broad variety of sources that are typically located across a rn.etropolitan area, 

and the CBSA or CSA ior that area is thus.a, reaso.nabkstarting point fur an analysis of what 

nearby u.reas may be contributing' to the·violationofthe NAAQS al'a given monitor or monitors in 

a violating m·ea. Although the CBSA or CSA, as appmpri'ute, is :the starting pointfor the EPA's 

evaluation of contribution, the EPA does not intend it to be. a presmned nonattainmcnt area 

boundary. The nonattainmcnt area boundary; or mui.tiplc nonMtalnment area boundaries, will 

encompass the arca(s) that violate(s) th!' standard and tho nearby areas that contribute to the 

violations. In relatively 1Jrbanizcd.areas this may include an entire metropolitan area (e.g., CBSA 

or CSA); in rural locations the nonatlaimnent area .boundary could include .. several small towns, 

each with a few sources that contribute to a Violating monitor..S As described in more. detail in this 

section and in the attachments to this memorandum, the EPA believes that·lhe weight of evidence 

approach to determining area boundaries for initial nonatttllnmentarea decisions could, under 

proper circumstances, result i11 nonattainroent,arcas ·consisting .of single counties or partial 

counties. 

As a framework fot· area-specific analyses, the EPA n:cornmends that states and tribes base their 

boundary recommendations on an evaluation of information relevant to five factors: air quality 

7 U.S. El' A (2009). Integrated Science Assessment l'ilr Pa1ticulnte Matter: Final Hepmt. National Center fm· 

Environmental A~:~essmont·RTP Division, Office of Research r.nd Dcvelopm~nt, Research Triangle Park, NC. 

EPN&OO/R-081139F. December 2009, Chapter Z·, I>· 2-8; Chapter 3, iJ •. ;!·4, 3-7, 3-70, 3· 108. Available ut 

ht!p:fh.,•ww.epa.govittnlnaaqs!standardslpml:'i_pnl_2007 _isa.hrml, .. -. -----'-O.Ml3-lidopted.stalldar.ds.£oJcdcfininl!-11lelrop~)jtno.and .. mit:r.Ojio>lltan.sll\tistical.al<>a&<>n.Decemoer..;2.(,j000-(6,~.FJ< .. --------

B2229). These standards established the terms Cl:lSAs and CSt;.s. ln 2010, OMB adopted revised standard~ ftll' 

del inc»ting met1·o.politnn und micnipoliton stotistkal uroas (75 fR 37246; June .28, 201 0). OMB will use tho 20 i 0 

smndards When it updates the list ofCBSAs andCSAs, antkipated in hmc 2013. Tbe cwrcnt list of CBSAs and 

CSAs and the;ir geographic -cOmponents is provided in a Qeeember 1, 2009 update. available at 

hffp:!IWW'rP. ceris'us. gov/papulatlonlmetro/jit:e.\'/lists/2009/Ust 1.1.\'t and 

ht1p:l/www.ceJ1SUs.gov/populdtiorilmetro/jifesllists!2009/Llst6.txl. ·The EPA intends to use tho December 1, 2009 

updafe· in ~his designations process. 

Page 5 of34 
EIBctronic Filing- RBcivBd, CIBrk's OfficB: 08/05/2013 

data, emissions and emissions-related data, meteorology, geography/topography, and 

jurisdictional boundaries. Attachment 3. 4escribes these factors in geneml and provides guidance 

regarding.analyses relevant to each of these factors that are consfstetlt with those used in the 

designations process for the 1997 and 2006 PM2.s standwcls and in designations for other 

NAAQS.9 Additionally, states .and tribes may identify ood.evallmte other relevant information or 

circmnstances specifi~;r·io a particular area to suppo11 nonaita!nment area boundary 

recommendations. For cases in which stat¢s .alld trib~s choose .not to conduct a sufficient anaJysis 

justifying their boundary recommendation, the. EPA wiUpropose. those boundaries tlmt it 

determines to be appropriate based upon th9 five factor .analyses and any other relevant 

intom1ation for a given m·ea . 

.While the EPA generally believes it is appro_priate to jr~c(tide the. entirety of a violating or 

contributing county in a PM2.s nonattainmeni·area, we recognizethat. in some cases, an 

assessment of relevant inform~tion may supp{irt inclusion of only pwt of a county. For example, 

as has. been the case in past PM2.s designations, there may be low elevation areas (e.g., valleys) 

with poor <tir quality in violation.ofthe NAAQS due to restricted atmospheric dispersion where 

higher elevations (e.g., mountainous. areas) in tl;e same cow1ty can be shown not to have sources 

of emissions that contribute to. the violation. Al'teinative)y, partial county boundaries may be 

appropriate in situations where the soui•ces locate.(! in·.a contributing county are located only in a 

small portion of a large C·Otmty that is ()therwige :not contributing to the new·by violations . .In such 

circumstances, the EPA has also previously c<ii1sidercd designating onl)' poitions of cont,ributing 

counties that are not contiguous tb the violating area a11 acceptable. approach, in appropriate 

circumstalwes. For de.fining. partial \'Ounty bo"ndarics, the· EPA recommencls the·use of wcll.-

detlned legal jurisdictional boundaries, such 'as townships; tax maps; or immovable landmarks, 

such as major roadways; or other permanent and readily identifiable boundaries. 

In addition to nearby areas with·somces.contl'ibuting to nonattaimnent, PM2.5 concentrations in an 

area with a violating monitor riuty be Uffecled'by long-raJJge or regiomil transpmt ofPM2.; and its 

precursors (e.g., nitrogen oxides (NOx), sulfur dioxide (S02), volatile organic compounds (VOC), 

and ammonia (NH3)).' 0 Wherethi:S is .the case, the CAA does n.ot require that all contributing 

areas ·be designated nonatiainmei'lt,· Dtity the·contrib\t!ing areas that are nearby, 

As provided in CAA section 188(a),.the EPA will initiall)iclassify all nonattainmem areas as 

"Moderate" nonattaimuei1\ areas when ii promulgates the initial area designations for the 2012 .. 

annual PM2.s NAAQS. 11 In accordance with CAA section l88(c), the attainment date for each 

Modernte m·ea shall be as exped·itiously as practicable but no later than the end of tbe·sixth 

'In the designation guidance for the 1991 PM,,, standards and the 2006 PM2J standards, lhe SPA Identified nine 

fltctms lo consider in making dcsignatioilrecomtn~ndations: emissions data, air quality duta, population density nnd 

. __________ _____degt:e-e..of.w:bani.zntio.llrtr:af-fle-and-cqJutniltin~-patt-emsr.,g.rowth--Hl~n.d-·~ntternsnne!eoro1ogy-;----·--·-----

geographyltopo.g-taphy, jut·isdictioll"l bou11darles., and level of conti'Ol of emission source. In April and Mny of20 12, 

whan the .EPA promulgated designations JOt· the 2008 ozone strtndard;:, the EPA gr[)-l]ped·the emissions-rela!ed factors 

together in t11e e1n iss ions and emissions·reJnted datn facto!\ 'resulting .in five overall faCtors. 10 ·nw muin prc~ursor gases associated with fine par·Jcle fonrilition nre SO:;,, NOxl volatile orgnnlc. compounds. and 

nmmonia. (Seen FR 20586 at 20589, Apr1t 25, 2007). Unless other•wlse .noted, nit references to PM,, precursors in 

this memOrandum and its aH«duuetus refer to at leasnhese !Our gases. 11 Nalui'Ct! Resources Defimse Council and Sierl'll Club v. EPA, No. 08-1250 (D.C. Cir. JaJ). 4, 20'l3). 

Page 6 of34 
EIBctronic Filing - RBcivBd, CIBrk's OfficB: 08/0512013 

calendar year after the designation. 

This memorandum provides the EPA's preliminary views on the process for initial area 

designations and for boundary d,terminations for the 2012 a·nnual PM2.5 designations process. 

Any guidance <:ontained 'herein is not binding on states, tribes, the public, or the EPA. The EPA 

will make the actual designations det_erminations and decisions concerning nonat(ltinment area 

boundary issues in the final action that designates all areas for the 2012 annual PM2.s standard. 

When the EPA promulgates the initiai nrea designatio1ls, those dctem1inations will be bindit1g on 

states, tribes, the public, and the EPA as a.mat.ter of l_aw. 

Four attachments provide addi.tio.oal-infbn'nation relevant to the initial area designations process. 

Attachment I is an anticipated time line of iinportant milestones in the initial area designations 

process for !he 2012 annual Pl\~b:s NAAQS. AWtchment 2 identities the-promulgated exceptional 

event schedule for initial data flagging and Stibrttlssi'On of exceptional event demonstrations. 

Attachment 3 identifies the five. general factors that the 'EPA in1ends to consider ih eva:Juating and 

making decisions on nonatta,inment .area bo>mdari<;s and provides guidance regarding analyses 

relevant to support each of1hese factors. Attachinenl4 provides additional 'information o.n 

preparing and running a HYSPLlT {HYbrid Singl~"Partiqlii Lagrangian Integrated Trajectory) 

modeling analysi.s that niay be relevant to designations evaluations. 

Staff in the EPA's Oflice of Air Quality Planning and Standards m·e available for assistance and 

consultation throughout the initial area designation process. Quesiiotls on -this guidance may be 

directed to Beth Palma at 919-541-5432 or Martha Keating at 919-541·9407. 

Attachments: 4 

__________ .............. ------------------------- ·--.... --·-··----

Page 7 of34 
Elsctronic Filing - Rscivsd, Clsrk's Offics: 08/0512013 

cc: Stephen D. Page, OAQPS 

Scott Mathias, OAQPS 

Anna Wood, OAQPS 

Lydia Wegman, OAQ::?S 

Richard Wayland~ OAQPS 

Greg Green, OAQPS 

Peter Tsirigotis, OAQPS 

Air Division Directors, Regions I-X 

Christopher Grundler, OTAQ 

Saruh Dunham, OAP 

Page 8 of34 

-------- -------------
EIBctronic Filing- RBcivBd, CIBrk's OfficB: OB/0512013 

A'i:'TACHl\1ENT 1 

ANTICiPATED TIMitLINJ<; FOR 20.12 ANNllAL PM1.; NAAQS DESIGNATION 

PROCESS 

- Milestone Date 

The EPA promulgates 2012 PM2.s NAAQS rule ' • I December 14, 2012 

Sta:tes and tribes submit recommendations for PMu No .later than December 13, 2013 designations to the EPA 

The EPA notifies states and tribes concerning any No later than August 14,2014 (J 20 

intended modifications to .thcit recortunendations days pr.ior to tina! PM1.s area 

( 120-day letters) designations) 

The EPA publishes public notice of stl\te 

recommendations and the EPA's intended No later than August 29., 2014 mod.ifications, if any, and initiates 30-day public 

comment .pe.riod 

End nf 30-day pub]ic comment·period No lati:rthanSeptcntber 29,2014 

States and tribes submit additimml information, if 

any, to respond to the EPA's modification of a No late!' than October 29, 2014 

recommended designatiqn 

The EPA promulgates final PM2.

5 area designations No later than December 12,2014 

----·--------· ..... --. 

Page 9 of34 
Electronic Filing- Recived. Clerk's Office: DB/05/2013 

ATTACHMENT 2 

Revised Schedule for Exceptinnal Event FJaggh1g and Documentntion Submissit~n for Data 

to be Used in !nitial Al'ca Designations Jor the 26l1 Ann.unl PM2.s NAAQS 

Air Quality Data - r NAAQS l'ollutnnt! Eve[lt Flagging & Detailed 

Standanl/(Lcvel)/ Collected for l.nitlaiJ)escription Documentation 

Promuleation Date Calendar Y car pcadHnc Submission.Dead{iue 

PMu/ 

J>dmary Anrmal 

2010 and 20H July 1, 2.013 December 12, 2013 

Standard 2012 July I, 2Q13' December 12, 20 I 3 (12.0 p.g/m3

) I Ju\y 1, 20!4' 

. Promulgated ! Dccombcr 14,2012 2013 August l, 2014 

- - "This date is provided bY the general schedule in 40 CFR 50.14(c)(2)(iii). 

Note: The table of revised deadlines only applies to data the EPA will use to establish the initial 

area designations for the 2..012 Nvisoa primary ~nual PM2.s NAAQS. The general schedule 

applies for all other purposes; most notably, fox data used by the EPA for redesignations to 

attainment. 

--·---·· .. --·----

Page 10 ofJ4 
EIBctronic Filing- RBcivBd, CIBrk's OfficB: 08/0512013 

ATTACHMENT3 

Factors the EPA Plans to Consl~eJ· in Determining Nonnttainmcnt Area Boundaries in 

Deslgnntions for the 2012 Annual PM;,,5 NAAQS and Gni(lancc un Analyses to Support 

th!)so F~ctors 

For init.ial area designations for the 2012aimnal PM2.s NAAQS, the EPA will rely on monitoring 

data to identify areas to b!' designated no11attainmeilt <iue to n1.ohitored violations of the standard. 

Consistent with the directives of the CAA and with previous .area designation !)rocesses, the EPA 

will then determine the appropriate nearby aj·etL~ io include within in the nonattai.nment area 

boundary for the violating area, based on emissknt~ that contri,mte to these violations. For each 

monitor or group of monitors indicating. a viola\ion, the EPA intends to assess information related 

to tlve factors for the purpose of establishing_ the ilppropriategeqgniphic boundaries for 

desi!,'llated PM2.5 nooattainment areas. The 'EPA will evaluate rdevat1t information. from the entire 

urbanized area (i.e., ·CBSAfCSA) containiilg the violafi;Jg lllOJu(or.(s) and any adjacent coU)lties 

that have the potential to contribute. Forthose.·portiOils nftlie urbanized area where an evaluation 

ofthe available information·clearly establishes that emissions sources in that portion of the ar.ea 

do not contribute to exceedaoce§ atthe·vioiating monitor(s), the EPA believes it would be 

appropriate to exclude that portion oftbe ar.ea :from the nonattainrnent area. This weight of 

evidence approach to detennining area boundaries. coul.d result in nonattainmeilt·areas c6nsisting 

of the entire Utbanized area, sin,!lle couhties, or, in cases Sl:!Jlported by relevant evidence, partial 

counties, including partial counties within-larger urban areas. While technical assessment~ can 

help to define the magnitude and relative magt1itude of contribution from nearby areas, the EPA is 

not setting u threshold contrfbutionl~vcJ or bright Jlne test for dct<mnining whether-an area shou]d 

be included withiil the boundaries of.a given nonilttainmen) area. Section l 07(d) of the CAA does· 

not require the EPA to set a threshold contl'ibi.ition and the EPA does not believe that such a 

threshold is helpfnl as it could be cither·ovei'· .or under inclusive. As a general example, a 

threshold contTibutionJeveJ would not Identify contribut1on Ji·om sources located upwind of a 

nonattainment area but for which tltere is no downwind monitor. For these reasons and as was 

done h1 prior designations for the ) 997 and 2006 PM2;s NAAQS, the EPA believes that the 

contribution determination should· be made ihrou!fh a c;Isc-by·case evalti~tion of the relevm1t facts 

and ci.rcumstances in each nonattainrnent area. · 

As u framework for area·specific analyses to support nonatta\nment area boundary 

recommendations and final boundary det&ln1inations, the EPA believes it is appropriate to 

evaluate the following five factors: 

I. air quality data 

2. emissions and emissions-related data 

:l. meteoJ:Ology -----·------·---·· 

4. geography/topography 

5. jurisdictional boundaries 

····------·-·----

The EPA notes that these llve f\tctors arc comparab-le to the factors that stutes and tribes and tl1e 

EPA have used successfully fot analytical purposes in prior designations for the 1997 and 2006 

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Electronic Filing - Recived, Clerk's Office: 08/0512013 

PM2.5 NAAQS. The recommendatioJrof these factors is not intended to indicate tl1at other 

relevant info1mation should not be conslder.ed hi tlte initial area designations process, as 

appropriate. The EPA will also evaluate·any other relevant area-specitk information not included 

within the tive factor analysis in cases where those assessments are provided by states ?Jld ll'ibes. 

This attaclunent is intended to provide. descriptive guid~nce regarding available data that states 

and tribes may wish to assess when evaluating these five facto i-s. This guidance also provides 

insight into the EPA's subseq\lent review.and evaluation ·of the state and. tribal non attainment area 

boundary recommendations: The guid,u;ce·offel's suggestiol1S about techniques and approaches; it 

does not contain requirements to be strictly foliowect··atld should not be read as prescriptive \vith 

respect to the specific techniques recommended. 

The EPA recognizes that some of the ·recommended assessments can be resource .intensive. To 

mitigate this potential cot1cern, the .EPA.intends,. Wlierevqr .possible, to provide the relevant data to 

facilitate the analyses. Table 3-I below outlines the aatasets that tile EPA expects to make 

available to the. public on the P:tvh.~ designq.tions websit!'. at hllp:!lwww.epa.gov/pmdesignationsl 

and the expected date or availability. The EPA tnay update tl1iS website during !he initial area 

designations process as other relevant dataseis·areidentifi.ed. 

Table 3-1. Datnsets the EJ>A will Provide via the EPA PM Designations Website 

Dataset -·- Expecteil Avail~biHIY J?ate ___ l 

Current annual PM....u_ dcsjgn values Aori12~13 

CSN speciation da!u (raw and SAN])\V!CHBD) AerJI20 13 --

lM~ROVE speciation data (mw and Apri1.20J 3 

SANDWICHED) 

National .Emissions lnventmy (NEI) emissions Aprll 20!3 

~paries 

· Gridded emissions* 

---· Aptil2013 

Urban tncrements_ TBD 

Wind speed/direction data April20!3 

{· Wind toses Aori12013 

HYSP~IT b·n~'l:..!!n\a .....6Eill.:?.Q13 . * Provtded as part of web·based mappmg to.ol. 

This guidance also otTers recommend.ations concemii1g how states and tribes may wish to 

describe the basis for their initial del\ignatioilsrecoimnendathms. Tlle EPA anticipates that states 

and tribes will elect to provide an atticulatecl explanation f·or those recommendations in a 

narrative format. Thus, this guidance provides ·some direction regarding the content and sequence 

of the narrative states and tribes may wish to develop when describ.ing the nonattaimnent problem 

in an area \.lith monitored violations of the NAAQS .. A comprehensiv<Jnarrdtive should atticulate 

----:a..conGGl>tllal-meael-of-P-M,::;-nenottail)lllent-thitt-e~p!ailJ.s-the·natur.;am:l-cm~es-oitiWPJii!2.5liir---- ------· 

quality problem in the specific area, icle.ntily the ·scope and scale of the air quality problem in that 

area, and describe all nearby emiss.io11 sources thai contribute to. the problem. The EPA 

encourages regions (and states and tribes) to work.collnhora:tively to d.evelop a single narrative for 

m11iti-state, or multi·regi-on, nonattainment areas. However, the EPA anliGipates that states or 

tribes with al'eas contributing to potchtial multi-.state designated noni\ttainment areas would 

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EIBctronic Filing- RBcivBd, CIBrk's DfficB: 08/05/2013 

develop a conceptual model that describes only the contribution from their ~rea to the larger 

nonattaimnent area, rather than at\empting to desc1·ibe the scope and scale of the air quality 

problem throughout the entire area artd in the j)lrisdiction wfth the violating monitor. The 

underlying analytical framework ofthe,recoinm·erjocd n;u:rative carj be S1.munarlzed as follows: 

• Determine violating monitorhig sites ·and gather data that enables an assessment of 

potential nearby contribQting areas arid the ·sources ·in those areas. 

• Assess and characterize air quality pattems at, and in the proximi\y ot; the violating 

monitoring s.ite. Identify the conditions th:at.are lnosras.so.ciated with high average 

concentration levels ofPivh~ in the area·by season of the year. Furlher, idenfify the spatial 

extent of the high PM2.5 concentr(!tions.. This analysi\'3. will ptovide a basic construct from 

which to evaluate :potential contributing sources. 

• Assess and characterize the PM2,

5.spec]es that are most prevalent over the analysis area. 

Determine the fractional magnitudes Oftotal PM2.5 by component, noting that efforts will 

need to be made to ensure that speciaJion data ·are adjusted to reflect FRM mass at the 

violating site(s). All parts of the year are imj:mrtant in determining contributions to the 

annual average COJlcetltration .. However; a seasonal or episodic compositional increment 

analysis in con;tbinatio·n with other fflctor info1mation may provide addmonal insight as to 

wbid1 sources or factof'S may c·ont.dbute at-·a·_greaier level. This analysis can be .an 

important first step in linking specific ,riearby sources of emissions to the violation. 

• Assess-and characterize the increase in seasonal and-annual average PM2.s _thot is observed 

at the violating m_onito.ring site(s) r1Jlative to monitori!lg sites outside the area under 

evaluation that reflect regio1ial backgrout)d c.oncentr~tio,ns .. This "urban increment" 

analysis will he-lp to ·differentiate. the influence from more distant emission sources fl·om 

the inJ1uence of closer·emiBslons sotu·ces,-and thus l<i identify the i'elative magnitude of 

contributions from nearby emissions sourc.es. 

• Assess and characterize the spatial and temporal ditl'erences in PM2.s co.ncentmtions 

within an urban area using FRM/FEM ·data as well as (lata from non-regulatory PM2.s 

monitodng sites. · 

• Once the air quality factor unalyscs identified in the previous bullets are compiled they 

can be evaluated ·in COI\itu1ction With emissions data and emissions-related data (e.g., 

vehicle m.iles traveled, population) to determine which source categories and sourc-e 

regions are most likely to contribute to the monitored viol~tions. 

----•--Once.the-~m~sslons.and.ai.J:.qua~ity-<Js~essn.lents .. h<t><e.bcen-e¥?.!.~ated,..it-is-v.al.uat>l~t\l-lhen 

assess the mcteorological.charaoteristic:s·of air qtiality thtoughout the year in the violating 

area. In many locations, the- weather pattcms will have a large .impact on the eventual 

determination of which source cat_e-go.ries·and·smu·ce regions in the area are most likely to 

contribute. This analysis will further help to identify the re1ative magnitude of 

coutributions from emission sources in netu'by areas. 

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Electronic Filing- Recived, Clerk's Office: 08/0512013 

• lt may be useful to assess any geographic/topographic orjmisdictional considerations that 

are relevant in the identification ofthe nonattainment area boundary. 

o Finally, all ofthe above assessments mL\.St be aggregated or synthesized into a consistent 

nanative that describes the relationship belween.so·urces in the analysis area and the 

measured violation. This synthesis should represellt a collective "weight of evidei1ce" 

regarding the most appropriate boundaries for the nonattainment area. 

While the general five factor framework is expected to be comprehensive and provide the 

foundation for each .assessment of boundary aren.s, the extent cif the analyses may v~ry on an areaby-area basis bas~d on the nature, cause, and :extent oft)le violating PM2.s air quality problem. 

This guidance suggests analy$es of certairi data 'SetS fuat can· he useful to assess which nearby 

areas contribute to nonattaimnent in .. n given area. [n ca~es where more highly-resolved ot n.ewer 

data sets are available that are not expiicitly mentioned in.this guidance, states and tribes should 

consider dleir use, as appropriate. rr these data .are.(lsed, the EPA recommends that the states or 

tribes fully describe the data and. its derivation in their sttpport'inwdocumentation for the 

designation recommendation. 

The following sections provide more d.etall on the specific.live·factor analyses and th.e 

supplemental synthesis approaches 'that the EPA plans to consider when evaluating state 

recommendations and determining nonattaillinen! area boundaries -for the a1\nual PM2.sNAAQS, 

l. Air Quality Data 

The initial area designation process for PMu shot!ld begin with. an evaluati011 of available 

ambient air quality measuretnents to detennin~ the location and magnitude of violations of dle 

st11ndard. In addition to data from violating monitors, the air: quality duta from other I1lonitors can 

add to the weight of evidence in assessing ihe C9l1tribution ofsomccs in areas outside the 

violating county. Examples include the use o:f chemical speciation data to help characterize 

contributing emissions SOllfces and ·the determination ofnearby contributions through analyses 

that differentiate local and regional source contrihutions. 

a. PML< Design Values and Intra-anntlll! Pnttcrt)S 

The first. step in ide.ntifying an area fuat must be designated "nonattainment" and to determine an 

appropriate nonattainment area boundary is to identify all monitored violations of the revised 

<mmtal standard using the most recemly available air quality data. The EPA determines NAAQS 

eompliance by cons'ideril)g the "design valuc"ftKeach air quality monitoring site. The design 

. _____ vac..l.,.tt~. for the 201.2 ~~Lt,al :l\1u~AAQ§_is tl.le~:xear average (~"¥u,2.QlD,J]tiQJ2)..oi1he_t:nuua!--·---"-­

mean concenttahons. fh1s requ\res calcttlatmg ammal PM2.5 des\gll values b@sed on amb1ent mr 

I:!: The specific methodology tbr calculflting·the PMu ·des·i_gn valuos; ·Including computational fiJrmulas and data 

completeness requirementS~ is described in 40 .CFR P.art 50, Appendix N. For bitsic instructions on calculating annual 

mean va.lues, see Guideline on Data Handling Conventions for· the PM NAAQS. EPA-454/R·99·00S April 1999 

located at hrrp:!/www.upa.gov/trn!nuaqs/pmlpm25_jfuide.hrml. Design values al'e computed and publishcG annually 

Page 14 of34 
EIBctronic Filing - RBcivBd, CIBrk's OfficB: 08/05/2013 

quality datu from the most recent three c.alendar year pedod (i.e., December 2013 designatioJ1S 

recommendations should focus on data frotn 2010 to 2012) :from all Federal Reference MethOd 

(FRM), Federal Equivulent Method (FEM), and Appt•pved Regional Method (ARM) moniiors. 

The EPA will designate as 11onattnininent all areas with o.ne o.r more ambieilt PM;ts air quulity 

monitors with a design value greatei· than the rumual stMdard of 12.0 f!gim3

• 

Because of the form of the NMQS, monitored umbiet!tPM~.slevels throughout the entire 3-year 

period, including monitored levels below t!1e n.umedcaUev.el of the NAAQS, are integral to the 

calculation of the design value of the monitor, and hence integral to determining whether til~re is 

a violation of the NMQS. The amotmt by which moniiored )evels exceed the NAAQS 

througholtl the period can be an important considerli~io.\1 in determining appropriate boundaries 

for the nonattainment area because the monitored" level ·indicates. the magnitude of emissions 

contributions that result in such exceedance levels and whether there is a likelihood of influences 

from summnding areas. Accordingly, contributions to monitor~d ambient PMz.s at a violating 

monitor throughout the enti1·e 3wearpel'iod ru-e relevant to determi'ning the approptiate 

bound!u'ies for a 11011atta.fnment aj:ea. 

Only PM2.5 measurements produced atllRM/VEMlARMmopitoring sites can be used for 

NAAQS comparisons. The EPA usesFRMIFEM/ARM measurement data residing in \he EPA's 

Air Quality System (AQS) to calculate the annmil PMudes:ign values. 13 Individual measurements 

that the EPA determines to be. "exceptional'' in accordance with the Exceptional Events Rule 14 

(such as days with poor air quality caused by wildfire or dust events) are not included in these 

calculatio .. os. State~ local, and tribal rnonitorit1g agencies are requb·ed to certify data submitted to 

AQS on an annual basis, by May 1" ofthe subsequent yeat, The EPA typically extracts ambient 

data fr\lm AQS and calculates official design values for regulatory purposes shortly al'tor that 

ccrtiftcation due date (e.g., typically 'by Jufy 15'h) .and then pcfsts NAAQS design values tor each 

monitor on a pnblic website. 

In addition to identifying monitor sites ·where the most recent dcsig11 val~tes violate· the 2012 

anmral PM,·.s NAAQS, exan1ining'trends in l'i\1z.l air quality values (including.design values) can 

improve our understaodin,g ofth·e JJatilre of!l)e:J'M2J ambient air quality prol:iletu in a violaiing 

area and thereby inform decisions regm'ding the· sufficient size and shape of the nonattainment 

area boundary. Analyzing design voJt\e trends, paiticulai'ly across.multlple monitors in an area 

being evaluated, can show how PM2.s com:entrations ·h~><e changed.and whether the recent design 

value is consistent with that trend. Additionally these trends analyses can show haw frequently 

the design value a1 the 'deiining' site (i.e., the monitoring site with the highest design val>le tor 

the area) has occurred at ot1Jer monitoring locatioJ.lS in tllC <irca under consideration,'and whether 

the design value trend across the evaluation area is homogeneo\tS. ·This information can help to 

------by-tlle-.SJWIM'jHie..'obHt--t;!ttality-l'lattlling·i!lld-$ttrndntd>r<iltd"l'eviewed-Jtt-conjtmotiun-witlrthe·Ei'A-rogionai----------· 

offices. When desig11 values are used in a regulatory nction1 they nre bused on !he latest nvallable information nne! 

vnl id diJtu tb2>.t suppot't that action. Cui-rent dOsig.11 ,;alues atld histOrical1rcnd infol1tJ<liion are uvai!ablc at 

http:!:\vww. c.pa.govlaif'tNmdr!values. html. 13 Information Jtom non.-F'.R.M/FEM/ ARM monitors an~ ai1· quali.!y modeHng, where awtilable, mny help d~fine an 

appropriate boundary tbr areas contributhtg to FRMIF[lMIARM-based monitored violations, but are nol valid for 

dctenninlng official violations ofthc i'M2., NAAQS. 1

'

1 Final Rule on the 'l'reatlhenl offJatR Influenced by Exccptionul Events, 72 PR 13 560; March 22, 2007. 

Page 15 of34 
EIBctronic Filing - RBcivBd, CIBrk's OfficB: 08/0512013 

identify spatial and temporal patterns in the des.il!;n values and, when combined with other 

information from the five factor review, can help identify ne~rby areas with emissions source~ 

contributing to an area with a monitored violatioJl. 

Under normal circumstances, the mere fact-that a nearby area has a monitor with a design value 

below the level of the NAAQS wo.uld noi answer the question o.f whether that area was 

contTibuting to violations at..a monitor-in<~nother area, SL!.Ch an area inight contain sources 

releasing very large a:nounts -of emissions that together wW1 emissions from nearby-sources 

combine to cause the violation at themonitol'. However, there may be circumstauces_in which the 

trettd in emissions at the t'\M•violating monitor ill th~ potenti'all)' contributing area could be 

relevant to the evaluation of cmttributim\. Fer .example, a monitor on .the .border of. a nearby 

county may show a downward trend in l'Nhs design values below the level of the standard 

although a neighboring county has a clearly violacl11g monitol' for the current design value period. 

While the county with the violating mon)torwHl be pc;5ignated as "nonattainmeni;" the downward 

trend in the monitor on the harder of a· nearby county·ma)', rilong with other evidence from the 

five factor analysis, support a w~ight o±)Vidence conch!sion !O. exclude the nearby county from 

being included as part ofthe·nonatta.inment area. Sin1ilarly,.an upward trending site may be 

indicative of growth in nearby contriputing-emissions source£ and provide more weight toward 

inclusion. 

In addition to covaluating trends·Jn annual PM4s values, the magnitude of quarterly or daily 

average PM2.s concentrations over the cOtirse of eaCh year . .can also provide clues to fhe nature of 

the contributing emissions sources. MotJthly and seasonal proft:Jes of daily average PM2.

5 

concentrations may illustrate the presence{or lack) of seasonal conditions conducive to PM2.

5 

formation, and/or seasonally importnnt_ernissions ·sources. A review of the trend in daily PM2.s 

concentrations, including speciated rneastU'elJJent data as elaborated on in the next section, could 

identify a distinct S<Y<Jsonal or episodic pattet·n of daily exceed<i;Jces'that is tl1e main-driver tor the 

annual desig11 value violation. lfthese.seasonalepisodes ultimateJy iniluence the annuat design 

value calculation, then evaluating_ the emission sources and other factors described in tllis 

guidance as they relate -to lhese episodes could help defin~>.contributing areas. For example, the 

occurrence of high levels of ammonium nitro,te during certain winter days, when meteorological 

conditions. enhance its formation, could contribute to .. annuaL design vah1e exceed.ances in cc11ain 

areas. In combination with the ui·harilhcrern()nt ~md emissions data analyses described below, this 

type of trenct analysis of monitor. data.could prov\de further insight and evidence of specific 

contributing influences on the violating monitor sites. 

b. PM2.s Compositiomi! Analysis 

Measurements or esrimates of the components of ambient PM2.5 can be "sed to determine what 

chemic~~pecies consti~:_:t:_J:.M2.s in the Pru:\i~l!}-~_area of iht~rest amllor at1~Jicldlar vig_@ti.ng _____ _ 

-------·-----rn:omto.t·s. IdentiTying the chen1\cul components of the PMz5ruass in the area (e.g., sulfate, nitrate, 

organic carbrn mass, elemental carbon, and c.rustalmaterial) can help to give insight i11to the 

types of emission sources that.are contributing to the monitored PM2.s concentrntions at the 

violating monitor, either throngh dlr~cl PM2.s emissions or fh.rongh emissions ofPM2.

5 precursor 

emissions. However, analysis of PMu composition at the violating monitor alone will generally 

not be able to distinguish between local/nearby source contributions al\d regional background 

Page 16 of34 
Elsctronic Filing- Rscivsd, Clsrk's Offics: OB/0512013 

contl'ibutions. This assessment. is therefore only one step .in establishing a link between nearby 

emission sources to violating monitors (i.e., the SDllrce typesthat.appear to be important to the 

violations in the area but not specific facilities). Detennining the specific facilities and emission 

sources that are contributing·. to the viqlations requir~s the sy.ntl1es!s of results t\·om an "urban 

increment" analysis, emissions data analysis, and an assessment of meteorological information as 

explained in subsequent sections. 15 · 

The PM speciation measurements for some locations me available from the routine urban and 

rural speciation monitoring networks·- the Chemkru SpecJatjon Network (CSN) and Interagency 

Monitoring of Protected Visual Environments (IMPROVE), respectively. There may not always 

be a co-located speciation monitor at tbe eX:aci ·location of u violating n1onitor site; in these cases, 

and where there are other nearby ~peciation monitors available, measuremet\t data from these 

nearby monitors can be considered for:use in a manner (e.g., through a distance- weighted 

average) that best represents tl)c conditions anbe violating monitor site. Where speciation 

monitors are not available at.all, or vihete·s1.1.Pplem~htal.coverage of speciation data is needed, 

additional limited measurements may b£; a1so avail!!ble fh)ttt lmalyzing FRM/FEM moititor filters. 

While FRMIFEM Teflon® filters normally arc not chemically analyzed for PM2.s species; it is 

possible to perfom1 certain types ofchemical filter analysis. A technical report describing the 

Tetlon® filter analysis based on previous appliaations related to the 2006 PM4.5 standards 

provides information em general procedmes· and ·lintitations of.lhe.filter analysis. 16 

Evaluating the raw speciation monitoi;data eM provide insight into source contributions related to 

that monitor site, but because of differences·in measurement tech.niqu.es, the data must be sdjusted 

when attempting to compare it directlylo violating. FRM/FEM. monitor values. 'the FRM PM2•5 

mass measw·ement does not retait:r.all ammonium nitrate.~nd other semi-volatile materials, but lt 

does include particle-boun(l w~ter,assoeiated with sulfates, nitrates nnci other hygroscopic species, 

which result in concentrations and percent ctmlributions to PM2.5 mass that may be different than 

the measurements of ambient levels of some PM2.s chemical constituents. ·n,erefore, to relate 

speciation data to FRM PM2.s concentrations, iris neceooary to account for the·actual PM2.; mass 

meas~tred at the FRM monitors, which does not include all PM2}; chemical constituents. Tu 

address this inconsistency, speciation measurement data· should be adjusted using the EPAdevelored "SANDWICH" p.rocedure to represcnt.the chemical oonstitue11ts ofFRM PM2.s 

mass. 1 .tiThe SANDWICH technique stands for measured Sulfate, Adjusted Nitrate, Derived 

Water, Inferred Carbonaceous mass Hybrid.Matcrial.Balauce Approach." A full description of 

15 Rao, V. and N. Fnmk,.A. Rush, F . .D.immick Chemical SpeciatiOn ofPM2..5 in Urban nnd Rural Areas. Special 

Studies, National Air Quality and Emi>siOJis To·erids Report, 2003. Available at 

htlp:llwww.epa.govfalrtrendsl.stlidfes.html. 

----·---~eehnieal-••oporron-Hlter-mlOIJ'•is-can-be-foimd·a . ----·-· -----·-·--

http:llwnn,l'. epa.govlllnlna(tqslpmldocslavailahle _new _ .. ~pecialio.n._ dara._ph12. 5 _naa.ptj{. . 

l1 Ft·ank, N. H.J SANDWICH Material Balance ApproaCh for PM2.5 Drita Analysis.~ National Air Monitoring 

Conference, Las Vegas, Ncvnda, November 6-9,2006. http:l/wur.,,.epa,IJOV/tlnlomtidjflesl2006cm1f•rencelji·ank.pdj: 

18 Frank, N.H.. The Chemical Composition o!'PM2.5 to support.PM lmpiementation, EPA Slate I Local /Tribal 

Training Wo.rkshop: PM 2.5 F·illal Rule lmple.mentation and 2006 PM 2:s 

Designoiion Process., Chichgo .IL, .J~mi! ~W~21, 2007, 

hllp://wv.• w. e.p•t g av/ tl nina aqslpml pres enlslpm 2. 5 .... ohcm.i col_ comp o.~ ition.pt[{ 

Page 17 of34 
Electronic Filing- Recived, Clerk's Office: 08/0512013 

the SANDWICH procedure is proVided in Frank (2006). 19 The purpose of the SANDWICH 

technique ls to provide estimates ofPM:;.s components as measured by the Plvh.s FRM.20 These 

estimates can be different than the data provided directly by. the speciation measurements from 

the CSN network. 

c. Urban Increment Analyses 

PM2.

5 mass concentrations are gene:rally higlier in urban areas compared to sunoundlng regions. 

This "urban increment," also known as·Lhe "urban excess,.''i.s due to locally generated and largely 

directly-emitted PM2.s in addition to regional contri(Jutlons. Al)wng the major contributors to 

PM:u mass, stilfate tei}ds to originate.from rcgionril sources; o~;ganic carbon and nitrate. originate 

.ti·om regional and local sources, while black cat'lion, .assoC'iated soot and crustal material tend to 

originate from local souJ'ccs. 

The goal offue. urban.increment analysisjs to estimate the local contribution to urban l'M2s as 

measured at violating FRM/FE!Yl! ARM monitonites :and fu·ereby provide additional evidence to 

consider in deciding whicluiearby areas with so'LU·ces contributing· to tl1e monitored violations in 

the area t:o include within the boundary· of the designated nonattainnwnt area. The urban 

increment analysis is a key part of'llw itirquality d~ta factor evaluation because it can suggest 

spatial and temporal con·elations between contributing influences and areas by ii1tegrating 

information from violating monitors and PM2.s composiiional;:Jata as described in the previous 

sections. 

An urban increment analysis can also be desi·gned to differentiate local'contributions ft·om 

regional contributions as well a.s to differentiate·i/ilraturl>an difl'erences; these basic approaches 

are described below. Analyses of these differentspaiial layers (.rural, urban and sub-mban) of 

PM2.s mass and· components can hclp'isolate and hetter explain the contributions 1l·om urban and 

nem monitor emissions, separate f'rpm the .regilmal background contributi?nS. 

UrbanlncrementAnalysis to identify Regionql vs. Locaf.Co,ntribution 

An urban increment analysis is b<Jsed on the premise that rural conc.entrations of PM2.

5 

concentrations r.esult il·om a r'e!,'\onal geographic distri.btition of contributing sources that result 

from·atmospheric formation ofsecondary aerosols and long-range transport. Therefore, rural 

PM1:' concentmtiort5 typically do not vary as much as url)an concentratioiiS and are less impacted 

by local source emissioJ\s. Also, tural concentrations ofthe major components ofPM2.s tend to be 

more spatially homogenous than the urban concentrations. Due to t11ese altributes, the urban 

l'l Frank, N.H. Retained Nitrate, llydrafeilBulfotes, and Cal'bo'naC&ou~ Mass in Federal Refaremfe Method fine 

-·-----·--_J!.aJ:tJculat<Mmte!'{<Ji'-SiX-Eilst<>Fi>-!/.S..Gitle&·J7Air-&-Wnote-M·1111age:-mso"C;"Z0611"'5·6;SOO=:;rr,--------·· · · 

w The SANDW.TCH adjustment u:-eS an FRM mass construCtiGn methodology that results in reduced nitrates (l'clativc 

to the amount measured by routine speciation networks)) higher mass ussocfa1cd with sulfates (reflecting water 

included in gnwimct.ric ·PRM measurements) and a measure of·organic carbonaceous mnss dt!rivcd fmm the 

diffcnmcc between meast.tred PM2.s and its non-carbon components. This ch'arflt;terizatiOn ofPM2.

5 mass also reflects 

crust~l material and other minor -constitu~nts. The resulting chm"n.'cterization provides a complete mnss closurt~ for the 

measured FRM I)M2,$ mass. 

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EIBctronic Filing- RBcivBd. CIBrk's OfficE!: 08/05/2013 

increment analysisprovides a first-order indication of the type, size, and spatial patterns of nearby 

or local emission sources that are cm:itrib\tti.ngto tbenonnttainment conc~ntratio.ns experienced at 

the urban monitors. 21 

The basic approach for the urbaJ) increment. analysis is to calculate the d.ifferencc between the 

ambient PM2.5 level at an urban area monitoring site and -the ambient PM2.s level at a nearby rural 

area monitoring site(s). Local contributions(<> PMz.s mass can be estimated by subtracting the 

rural con.centration from the measurQd·\U:ban .conoeritnttion.Asstuning that the rur~l · 

concentrations represent the regional background ·copcet1tration, th1s difference is defined as the 

urban increment and calculated .as follows: 

l 1t"b·at• tn~..~r !'om v.v" · ' '• 1 u ~ '•P-MZ.Ij l,C"~·("t"'.i .:r.;;:>'I-VI~;t~-

:: 1J r ba:'t c·o )'\-.t.~ntt·atio.1~ $\\!'!.t"·('t-JH;1 •.H' .:t-:>1~'".{.'~-:r) 

- R~g! 01-tcil Ba.(!kt:t·;•r.; tt-,~d C 0"~"-~t:C',.!tr·ati~n.. P;~.,f 5 (Nt.:.~-.n· ;r;:,~.:tu) 

In the equation above, the 'Urban-Concentration' .should preferably come from the same site as 

the violating PM2.s design value monitor, a representative site, or -oombi.naticin of sites consistent 

with conditions at the violating monitorsite in cases where· a speciation monitor is not co-located 

with the violating PNh.s design value monitor. The calculation of the 'ltegional Background 

Concentration' should be prepared by s_patially averaging across nntlfiple -rural monitm sites, 

where available, in order to best represent t11e.rcgional CO!Jtr-ibutions to ·PM:u mass. Monitors in 

net1rby smaller urban arens may also" be· considered in assessing contributio.ns to the upwind 

concentrations that are part of the regional.backgro.und.-The selected rural aud.upwind urban. 

monitors should fall within a pre-determlnetl.radius ofthe violating PM2.s monitor site to 

reasonably reflect background influendng areas m1d·J.t1ust'have measurement data available for 

days cons-istent witl1 the violating mot1ito!' data being a·milyzed. There are seveml suitable 

averaging approaches to construct the urban inci'j)meht. Fot example, an inverse-distance 

weighted average of the urban incrcmeiit.across-ihe se.lect-ed· ntra1 monitors can then be calculated 

to account for differences in the distances that sepatate the rural monrtor site~ from tl1e violating 

urban monitor site. Averaging based on multiple m01iitors lessens 1111)' bias issues that may be 

as·sociated with selecting only a sing1.1lar·ruralfw'banmonitor pairit1g for calculathtg the urban 

increment and should be more representative of the-regional influence. 

As shown in the equation above, th.e.urban increment call be estimated on either a total Pl\hs 

basis, or on a PMu species component basis (i.e., comparing species of urban increments of 

vmious violating monitors in .the area). This cal1 be a pow~rfu\ analytical tool for examining the 

influence of spatial patterns oLsoi!rce-specific emissions on monitor s.ites that are violating the 

2012 annual PM2.; NAAQS. Linking the previously descrlbe!i PM2.s compositional assessment 

with the urban increment ~alysis can also help iderrtify tire )ike)y cot1tributing emission source 

-----typgs.t<NJle-!Gcai-Gr.!r.tcarf;y2-ooacAAirat-iGa-inG-Fii>tll<'nt~1=his-iJ;-~ossihl!i!-be&au~e-differ-ent-----------·--·-·­

measured components ofihe PM2.s mass can b.e·Jmked fo spec1fic types of emission sourcos. For 

example, large stationary sources such as electric genemting units (EGUs) are preclominm1t 

"Rno, V. and N. Ft'ank, A. Rush, F. Dimmick. Chomical Specl>\tlon ofPM2.l in Urban •nd Rllrol Areas. Speclol 

Stt!dios, Nntionul Air Quality and- Emissions Trends Rcpot"t, .2003, Available at 

lit tp; 1/Ww\>V .epa. govl a i rtrendslsludi es. ht m l. 

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EIBctronic Filing - RBcivBd, CIBrk's OfficB: 08/05/2013 

contributors to the sulfate component ofJ?M2.5 •. High nitrate levels (i.e., both oxides of.nitrogen 

(NOx) and ammonia (Nrh)) often indicate the presence of localized mobile sources, local or 

regional tuel-combustion sot.trces, or a iegional contribution from agricultural sources .. or a 

combination of these sources, Carbonaceous mass .is typically associ.ated with mol)ile sources, 

wood or biomass burning,. and localized combustion SO\Jrces. Carbonaceous mas's is commonJ.y a 

substantial componentDf' urban cxce-~s. A high ekmental carbon to organic c~rbon.mass ratio can 

be a·signature of diesel combustion solu"Ce cantrilmtions, such as diesel trucks, construction 

engines and vehicles, ships and trains. A high o'ganic carbon to.clemcntal carbon ratio, on the 

other hand, is often a signature of biomass burning. 

States and tribes with areas qxperiencing seasonal and episodic t1uctuations in PM2.s 

collccntrations may find it useful to pcrfoi'm a cornpositi'orml analysiS of the urban increments 

during these specific periods and conlparc th.ose results to other periods ofthe year !hat 

experience lower or less varial:>le 'PM2.5 colicentratiDns. While all parts of the year are .important to 

consider to determine t'.Ontribmions tO'. the anntral a'ver<\ge concentration, a seasonal or episodic 

compositi<mal increment analysi~ in combination witl1 other: factor information ma.y provide 

addiiional insight into contributing sour~-es and/or contl'ibutihgfactors(e.g., local meteorology) 

influencing monitored violation~. For example, residential wood combu&'tion has a unique PM 

signature and can contribute appreCiably to the organic frat<tiqll·ofwirit.er-ti:me PM2.

5. Likc>Vise, a 

compositional tmalysis showlnghigh weekday nitrat~ levels may be associate<;! with increased 

vehic.Je traffic during the tra.clitional work we~k. A revievi()fboth the t.trban increment results and 

the seasonal or episodic emi~sfon invehtOJY for the area can be an important synthesis analysis to 

better ur1d.crstand what specific emlssi.on sources, and therefote areas, may be contributing to a 

violating monitor. Previous guidance prepared for the designations for the 2006 24-hr PM1.

5 

NAAQS is relevant to the~e seasonal and episodi-c evaluations.22 The 2006 guidm1ce illustrates 

l1ow the l'IPA derives fine particle colnpos.itioli .associated with PM2.s nJassmeasurements, how 

the typ.ical high day and average composition vades spatially and temporally, and how these data 

relate to potential emission sources. 

Incremem Analysis to Define Intra-Urban D/ffffrences 

In addition to looking at the rura.l versus u1'ban gradient, an Infra-urban analysis may be useful to 

·urtderstand emerging "within m•ban" gradients nem: the violating monitor site, which become 

more apparent as regional concentrations decline. ··n1is analysis can help fUJ'ther diti'erentiate aud 

isolate nearby contributing in:fluences to the violating monitDr site(s), particulm·ly those that may 

be more evident at a refined seale such as localizect·pJumes or Stiburban intlucnces. This refined 

characterization of contribllting emi.ssi.on influences within the immediate urban area may ill turn 

hdp to further identify the relative importance o.fsurrou!).ding areas in terins of their contribution 

to the violuti11g monitor. In combinatiOll,·al'lalyzing the three: spatial layers (rural., urban and suburban) ofP!'v1,,5 mass and C()mponents can prol'jde a moN CQ..m..illlli».JJ!ldemtsnding o:Lthe.....--

----·----- contributTi1g urban and neat' monitor emissions, separate !him the regional contributions. The 

ability to conduct an intra-urban. a,nalysis, however, is predicated on having data f'rom·multipfc 

"Frank, N. H. '/'he Chemical Composition of PM,,, to support PM Implem<mlalion, Presentation at EPA State I Local 

I Tribal T1·aining Workshop: PM2..s Fh1al Rule lmpiemetHation and 2006 PM~.s Designation Process, Junc20~2l, 2007. 

Availubie ut: htrp :IA1'ww. epa.govlttn!naaqslpmlpm25 .:)006 _rechiqfo. 11tmf. 

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Elsctronic Filing - Rscivsd, Clsrk's Offics: OB/0512013 

monitors, preferably PM2s speciation monitors, within the urban study 1\fca, whkh may not be 

feasible for some areas being evalualed. 

With very few exceptions, the PM1.sniass concent1:atioo~ haW been reported to be quite 

uoifonnly distributed across urban monitoringJocations. 23 However, this .finding is dependent on 

the PM2.s composition in a pmticular metropoiitan area, the season of the year, and. the relative 

amounts ofits chemical constituents thnl originate fr.01:n regional or local emission sources. 

There arc many possible drivers for intrJFiJtbatl variubillty in1'M2.s mass, including the following 

influences: local sources of primary P!-.'1 ei:nis.sions; iransie.!lt emission events; topographic 

barriei-s that isolate sub-regions ofthe urban area; tn<:teoro!ogical phenomena that vary on spatial 

scales within the m·ban area; differences in behavior of semi-volatile components; a11d 

measurement error. 24 

The larger the contribution of regional sourc.es, ·the.rnore ·uniform is tlw .intra-urban PM2,;. 

ReQognizing that the amow1t of regional and or locaL contributions are expected to continue to 

decli11e in response to regional and local control progralliS"(bUi.\Je.thaps at different rates), intramban spatial variability of PM2.s and. its constituents ·may increase in the future. This potential 

change in intra-lU'ban variability may be ciiffe)'ent among areas. 

2. Emissions and Emissions-Related Datu 

The sources and levels of emission.s ofPM2.5-re]atedpollutmJts is an important factor in the initial 

area designations process. As noted above, ambient PM2:l is· formed thxough complex 

atmospheric processes with contributions fromdi!·eet.emissions ofpalticles and from secondarilyformed particles that result ti·om rnullipkPM2.s precursor~. Air quality in a nonattaimnent area is 

also typically the resuh of a combination of regional anc!Jocal eniissions. ln the designations 

process, for each metropolitan .are~ with a v-iolating monitol', the'EPA evaluates the emissions 

data from nearby counties to assess each cotlDty's c011t1'ibotkm to PM2.s concentrations at the 

violating monitor or monitors in the .arealmder evaluation. Be.cause PM2.s compb)leats such as 

S\llfates and nitrates are formed through atmosp'her.ic processes :and can be transported many 

hundreds of miles, sources of emissions outside the cotmties comprising the metropolitan area 

(CBSA or CSA) may also influence the regional contribution measured at a pa1ticular site, but 

may not be considered in 1he designation determinat'ion to be "nearby" sources. Thus, the. 

cvaluali(lll of the area is also a means to differentiate b.etweeu.thbse transported pollutants ·!\·om 

more distai1t sources of emissions and·lhose sources o-f emissions in nearby areas that should be 

pati of1hc designated nonattahm1entarea because they are p~rt o:flhe local nonattainment 

ptoblem. 

For initial area designations associated wi!b the20 12 annual PMz.s NAAQS, we intend to 

--------exai'i'ilne emiSSlOns oT1ilcmifieasoul'ces ot'"d1recrPMn, me· maJor components ol'airect P111'l,S11 U.S. EPA. lntegmted ScienceAsses:.:m.ent for Particulate Mattr;r (Firml Repo.rt). U.S. Evvironmenta1 Protection 

Agency, Washington, DC, BP A/600/R-0811 39F, 2009. 

" Tm'ner, J.R. A Conceptual Model ftJr Ambient Fin. Parli,7JIIite Matter Over Southeast Michigan; High 

Concentmtion Day.\~. Version 1.0. Prcpar6d for Southeast Michigan Council of Governments, Detroit, Ml. October I, 

2008. 

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EIBctronic Filing- RBcivBd, CIBrk's OfficB: 08/05/2013 

(organic carb:on, elemental carbon, crustaltnateriat(andlor individual tmce metal compotmds)), 

primary nitrate and primary sulfate, and precursor gaseous pollat!!Ilts (e.g., S02, NOx, total VOC, 

and NH3). Direct PM2,; emissions·are expected to be generally local in nature· and influence 

monitored values in a more direct fashion with little long-range transpmt, The gaseous precursors, 

on the other hand, are ex.pected to be more regiorii:llln natw'e (although the EPA also expects 

some local NOx and. VOC emissions contributions from mobile and srationary sources) and 

transport from neighboring areas can contribute to higher PM2.5leve!s at the vi.oJati!lg monitors. 

Analyses should include reviewing data from the latest National Emissions Inven.tory (NEI) or 

other relevant sources if available, The analysis should· also in<;:Jude examining the magnitude of 

relevant, county-level emission~ and ihe geographic locations of sources of·thc relevant 

pollutants. · 

Analyzing the magnitude and spatial extent. of emissions further informs tile analysis of the 

urban/rural ambient relationship discu.ssed eadH:r. Iil; addition, colrtb.ining· these analyses (e.g., 

magnitude of emissions and poillt of release) with meteorological information coi1 inform the 

evaluation ofthe degree of contrlbl.!tion from nearby· areas. The EPA will-also consider any 

additional infonnation we receiv.e 011 changes to ettrissiohs tewls that are not reflected in the most 

recent emissions inventories. These changes may include emissions reductions-due to permanent 

and enforceable emis·sioils controls that·Wtll be in pl~ce before final designatiops are issued, and 

likewise may include emissions i11creases from .now sources or increases ·ar existing somces. 

For the initial area designations for the 2012 annual PM2.; NAAQS, the EPA believes tJmt it will 

be appropriate to use 2011 NEI version I data b.ecause that will be the most recent emissi<ms 

inventory infonnation available at the bcginnhtg of this designations process. The NEI represents 

data, generally, on an annual basis.at the county !.eye!. Emi~sio.ns ·fi'om large stationary sources m-e 

available at a point ln space; emissions from large fires .are available in day-specific format. More 

detailed inventories (higher resolution-than <!otmty estimates) are also available, although not in 

the NE!.25 For the initial area dcsignations.:t:or'the 2012 mm.ual PM2.s NAAQS, gridded emissions 

data (at 12 km grid resolution) ure also available.for 2007,2009, and 2010 for tbe contiguous 48 

states, and may potentially be ·useful in areas where partial counties need to be considered in 

nonattainment area boundary detenniliations, These gri-clded eniissions data can be provided on m1 

annual basis or for shorter time periods. The EPA does not have gridded emissions .for Alaska or 

Hawaii, but the EPA would reconunend that these states u~e gridded data, as appropriate, i:l'theyare available. Any data submitted in this fashion to the EPA will be reviewed against emissions 

estimates developed by the EPA. 

Population den.l'ily and degree of urbanization (including commercictl development) 

As noted in footnote 8, the EPA has -consolidated several !actors (e.g. population densit)', degree 

of urbanization, and transportation arteries) within the "Emissions and Eruissions-&ll.ru~_dJ)Jltn'_' ______ _ 

·!actor as these elements stipplement and help to infoi'm the analysis of emissions data. The EPA 

intends to provide tl1ese data as available although the <EPA expects that states and ttibes may 

3

s The r:::PA. develops griddecl emissions by npplying temporal (e.g., seasonal variations in emissions o.s reponed to the 

NEJ) and spatial (e.g., incorparntes latitude and rongitude location information as reported to the NEJ) adjustments to 

the countyHbased NEJ estimates to produce the mo1·e fincfyresolved gridded emissions. 

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Elsctronic Filing - Rscivsd, Clsrk's OfficB: 08/05/2013 

have independently developed datasets to better inform.these elements, which are not available to 

the El' A. The EPA recommends that. population density analyses examine the locatiOil and trends 

in population growth and the patterns of r~idential and commerciitl development as potential 

indicators of the probable location anc\Jnagnitudc ·ofemissi<ins sources that may contribute to 

PM1.s concentrations in a givennonattainment ar.ea. 

l11e NET also contains county-l()vel aggregate ·estimates ofsmaller statio11ary area a11d mobile 

sources emissions (gddded emissions. as well.as sub-annual emissions come from. spatially and 

temporal.ly allocating the NE! emissions), An analysis of population density, degree of 

urbanization, and transportation arteries may provide. the location of this emission-related activity 

within the large.r cotmty, and thus may serve. as a proxy for the ~pa;iaLdistribution of County-level 

emissions. The EPA believes that·areas of dense population and commerdal development are an 

indicator of potentially higher levels tlfsta:tionary aren·~ourc~ ax,d.moblle source emissions that 

may contribute to PM2.s formation iii a given area. Rapid poptila1ion growth in a COUJlty on the 

urbanperimctermay signify increas.itlg integration.wlth the core urban area, which likely will be 

the same as the CBSA or CSA in question, and may indicate that tbe associated area and molJile 

source emissions may be appropriate to include In the nonattainment area. 

Th>.Uic and commuting pal/ems 

As with the previous factors di.scussed above; these factors arc also secondary in nature to the 

act1ml emissions that the EPA will pxovide. Traffic and conimuting pattern data can help assess 

the influence of mobile source emissions in a ·given m·ea. Analyses should examine the location of 

major transportation arteries and information on. traffic vol.ume and commuting in and around the 

area containing a violating monitor. This may include examining the number of commuters in 

each nearby county who drive to a cow1ty within ~he· area that. has a violating monitor, the percent 

of total commuters in each cotmty. who comrtlu.teto·.o.thcr counties witlH.iolating monitors· within 

tl1e metropolitan area, ·and the total Vehicle Miles Traveled (VMT) foJ' each county. Areas with 

higher VMT and commuting levels can be an indicator of the location of mobile source emissions 

that may contribute to PM2.5 concentralions·at·the ~ieila!lng.t)lDnitOI'. 

The NET is one source of the county-wide VMT data and facilitates relMive comparisons of traffic 

and commuting patterns between counties in a larger ru'ea.i6 However; more detailed assessments 

provided by states or tribes could. help to hlghllght the magnitude and location of emissions 

activity. If the EPA provides g;ridded emissions, then the EPA can also provide gridded VMT 

data; bowever, as mentioned previously, these estimates may not COITespond directly with statebased. VMT data to which individ,ml areas already ll1!l.Y have access. 'fable 3.1 details all the 

datasets that the EPA will provide for use in this process. 

3. Meteorology 

26 NEI countyMlovel VM1 estimates arc developed ·ii1 n wp·iiown ilppro.ach from Federal Highway Administration 

estimates of statewide VMT by road class that f!re allocated t.o counties based ·on sun·ogatcs. Accordingly. the NEI 

c:stimntes do nor always compm·e well to dc.utiled areaw.spedfi<: studrcs that arc de-veloped in a more robust way (e.g., 

lmvel demand mode:! data). 

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-----·---
EIBctronic Filing- RBcivBd, CIBrk's OfficB: OB/0512013 

• 

The evaluation ofmeteorological data helps to det!"tmine t)le effect 011 the Jltte.and transport of 

emissions contributing to PM .~ concentrations alld:to identify areas._p6tentia!ly contributing to the 

monitored violations. This section oflhe gliidance._provides recommendations for summarizi~1g 

meteorological data and results iii snppott (Jf nppropiiatc·nonattainment area boundaiies. One 

basic type of meteorological analysis involves assessing potential source-receptor relatio'nsliips in 

the area using summaries of emieysiO\JS, wind.speed, acid '\Yind direction data. A more sophisticated 

assessment ilwo.lves modeling air parce'l trajectories. 

A simplified meteorological assessment imiy i11c.ll1de identifying the fi·equency of surface level 

wind speed and direction on days wi.th high observed PM~,s·eoncentratlons and comparing this 

frequency to the frequency of wind sp_eecl'and direction for other·meteorologica.l periods, years or 

seasons, for example. 

A more sophisticated meteorological assessment woilld employ trajectory models to help 

understand complex transport sit\lations by illustrating the:three-dimensional paths traveled by air 

parcels to violating monitor. '!1\e HYSP!Xt (B.Yb:dd Sln:gl-e-ParticleLagrangian Integrated 

Tr~jectory) modeling system may be useful for some areas to· prod.uce air parcel trajectories. 

Attachment 4 contains additional inf6rmation on conducting meaningfnl mctcorol.ogical analyses, 

including HYS.i'JAT modeling and source apportionme1ii modeling. 

4. Geography/topography 

Consideration of-geography or: topography c.fli:l provide additional information relevant to defining 

nonattainment area boundaries. Analyses sh6ufd examine the physical .features of the lat1d that 

might detlne the au·shed and, tlterefore, affect t)le fO!'Jl).ation and distribution ofPM2.s 

concentrations over an area. Mountains or-other physic-al features may 'influence the· fate and 

transpmt of emissions at1d.'PM2.s concentrations; Additional analyses may consider topographical 

features that cause local stagn~tion episodes via· inversions .. Valley-type. f~atures can cause loesl 

cold-air drainage patterns .and ·vertical temperature inversi.ons.that effectively "trap".air pollution. 

Under these conditions emissions can accumulate leadin·g·tQJJeriods of elevated PM:u 

concentrations. These air drainage pattet·ns and Inversions may be limited in extent and thereJbre 

may need to be separated from regions with more conventi()nal air flow and PM2.

5 concentration 

patterns. Similarly, the absence of >my such geographic or topographic fealttres may also be a 

relevant consideration in. a given nonattainment ar~a. 

5. Jurisdictional boundarl~s 

Once the geogmphic extent of the area violating the.PM2.s standmd.and the nearby area 

contributing to violations is.deteJmined, the EPA intends to consider existing jurisdictional 

boundaries for the purposes of providing a clearly defined !~gal boundary and carrying out the air 

quality planning and enforcement .functions for nonattainmerit areas. Examples of jurisdictional 

boundaries include, but are not limited to: cotmties, air districts, areas of Indian country, 

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Electronic Filing - Recived. Clerk's Office: 08/05/2013 

metropolitan planning organizations, and existing nonattainment areas, If an existing 

jurisdictional boundary is used to help define ihe nonattnhJ.tnent.area, it must encompass all of the 

area that has been identified as meeting the nonattainment definition. Where existing 

jtu·isdlctional botmdaries are not adequate to describe the n0nattatl1U1ent area, other cleal'ly 

defined and permanent landmarks or geographic coordinates should be used. 

, __________ _ 

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Synthesizing the .Five Factors 

fn making designations·recommendations for vioLating areas or contributing areas, and the 

nonattainment area boundaries for such areas, the EPA recommends that states and tribes consider 

the five recommended factors together and \!Sea weight of-evidence approach tbr tbis analysis. 

As explained above .. the ~tnrting poiilt for evaluating the factors is the air quality analysis. Of 

particular importance is the locatltin(s) ofthe violatilig monitm(s) based on20l0-20l2 data and 

the characteristics oftho.sc violations (e.g., speeiatlofl. and urban increment analyses). Once the 

chnracteristics of the violations are.establishe(i; one can beg!n to assess Which nearby emissions 

sources or source categories ana source t'eg(ons.may .have contriblJted to those violations. This 

contribution evaluation should generally consider ihe locutio'n an~ magnitude of emissions, and 

the potential for these emissions to .contribnte to the ambient.conditions at the violating mon.itol's 

as informed by the meteorolog1cal .and geographical!topqgraphical analysis factors. T11e guiding 

principle for this evaluation should be to include within the boundaries of the nonattainment area, 

any nearby areas with emissions of PM2.l or PM2,s precursors (e.g., S02,NOx, VOC, and NI-b) 

that have the potential to qe transported lo the violatilig monitor. The final factor, jurisdictional 

boundaries, should be considered to refine the nonaitainment area.boundary to ensure meaningful 

ait· quality planni11g and regulati~n dljring the NAAQS.iniplementation phase. As in prior 

designations for the [ 997 and :2006 PMt.s NAAQS, the EPA generally believes that it is 

appropriate to use existing legal boiuidaries where ·possible,. to assure effective planning and 

implementation. 

The EPA believes that the five factor analysis described here is generally comprehensive and 

intends to usc a weight of evidence approach based OJJ the$.e five factors in establishing the 

nonattainment boundaries for the 2012 annua!·PMn NAAQS .. In some cases, howevel', the EPA 

recognizes that it may also be useful to emploY one ofthe additional analytical approaches 

described below to fwther evaluate information relevant to the factors, such as emissions data, air 

quality inloimation, and meteorology .in an .cffo1t to bettcr.evaluatc contribi1tion from nearby 

areas. The EPA does not expect to complete, nor. do we expccJ.Staies or tribes to complete the 

additional analyses in all cases. Ratl1ex, we li11tlcipa(e undertaki1ig this effort when the .analysis 

based on the five factors WO\lld benefit from an. (idditional. analytical method to further 

qualitatively or quantitatively identify relative co)ltriqutions froiJ1 source regions to violating 

monitors. 

The EPA also recognizes the·potential v.alue or additional analytical methods not already 

specified in this guidance (e.g., pollution roses) that may b.e used to q11alitatively describe or 

quantify tho relative contribu.tioti.s from contrlbuting areas to violatLIJg monitors. By their na.ture, 

some of these supplemental methodologies may synthesize air quality, emissions, and 

meteorological data into_gtl~t~~itutive estimate$ of the. contributions from specifi.u!l:e.as. ... J:his__ ____ . ____ ._ 

g\Jidance document provides limited inibrmation regardii1g.rhree specific quantitative techniques 

that can be used to assist any individual states or l:ribes choosing to employ one or more of these 

approaches. As noted earlier, the EPA does .not require siates or tribes to C<mduct these analyses 

as part of the ir1itial area designations process for the 2012 annual PM2.s NAAQS. 

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EIBctronic Filing - RBcivBd, CIBrk's OfficB: 08/0512013 

The EPA has conside1·cd three such approaches in past designation efforts: (i) the weighted 

emissions score (WES); (ii) the corrtributing emissions scorc(CES); a11d (iii) source 

appottio.nment modeling (SAM). 'rhe EPA has used two ·ofthe'se techniques, the WES and CES, 

to suppm1 previous PM2.s designations. St!\tes may find them useful, with some rnoditications, in 

preparing designations recommendtitio11S for the 2012. PMi.s standard. Some states usad the third 

technique, SAM, in their boundary determin:ations for the 2oOS Ozone NAAQS. Tiw EPA does 

not plart to provide WES, CBS, or SAM assessm.ents for any areas as .part of the illi.tial area 

designations process for the 2012 annual PM2,

5 NAAQS. Like other aspects of the !actor analyses, 

these three aggregation techniques produce inf0rmatioil lhaL.can help to detcm1ine potential 

boundaries for tile area that should be desJgnated nomtttalnment for the 2012 ann11al PM2.

5 

NAAQS in a given area. The restllts oJthese synthesis approaches should be considered just one 

part of an overall assessment of the potential nonattaininent ·are& boundaries. The EPA also 

recognizes that there are partic11lar uncertainti¢S associatl:d ~vith. int~rpretlng the outputs of each 

of these methods; however; they can be·useftit teehnicjues for comparing the relative contributiDn 

of county by county emissions of'PM ptecursor em'issio.ils ·in a simplified way. 

States and tribes may tllso Wi\!1( to conside.r the potential value ofadditional methods beyond 

those described below, .such .as receptor ·madding techniques (e.g., .Positive·Matrix Factorization 

[PMFJ tmd Chemical Mass Balance fCMB])and ad\!MMdStati.stical Malyses (e.g., nonparametric regression and cJuster·Malyses) to·bettenmderstand contributing influeRccs.to the air 

quality. Because of the EPA'> limited·,experience a·pplyi·n:g s\1ch techniques to tlie designations 

factor analysis, states· and tribes intending to use such methods should consult with their EPA 

regional office regarding their usage illld intended applications. 

In considering the synthesis approaches identified·in tllis .guidance docllinent, it is important to 

remember tlHtl the assessmetll of potential nonattainment area .boundari·es i·s based on all of the 

information available to the Agency for·all oftlHi :lactors iden'Cified in the EPA's guidance. The 

EPA will base lts fmal decisions on attainment arid no:ilnttaimnent tlreas on the collective 

assessment' ofthe five factors. 

a. Weighted Emissions Score (WES) 

The WES analysis takes the urban. increment compositional fractions ofPM.z.s determined through 

the technique described in Section Lb and c, and ·<IJ:lPlics them to each county's fractiOJ< of total 

emissions in the urban area for each PM species. In this. manner it attempts to evaluate the level of 

contribution of a couaty's emissions to ·a violating monitor site. by weighting each county's 

emissions by the fhwtional componc11t observed at the violating mo.nitor. The basic steps arc as 

follows: 

----~,S,_tcp t The counties to be analyzed in rcla~.o.!l.c~O each urban area are first identified. 

Step 2. For each analysis area, the ul'ban incremerit compositional fraction ofPM2,5 mass is 

calculated according to the methodologies described in Section 1 .band 1 ,c above. 

Step 3. The next step involves calculating, for each p'o!Jutmlt, the percentage of.analysis area 

emissio11s attributable to each county (counties within and adj'aceJlt to CBSA/CSA as applicable). 

Page 27 of34 
EIBctronic Filing- RBcivBd, CIBrk's OfficE!: 08/0512013 

Step 4. The county's percentage of analysis area emissiorm for each poJ!utant is then multiplied by 

the corTcsponding PM2.5 component percentage of urban incremetlt mass. 

St!W...i_S um the results for each PM2.s species within each county to get the county WES 

The.WES should be regarded simply 8$ one iilol to evaluate the relative importance of multipollutant emissions from one county to others in the·same nbnattainment area The WES•score of 

a county in one nonattainment area is :not a suitable point of comparison to the WES score of a 

county in another nonattninment area; the WES is only arneaningful tool to evaluate the relative 

contribution of conn ties within the samc·nonaitainmi:mt area, The weighted emissions score 

combines air quality and emissi011s :information, but does,so fn a less rigorous way than the 

contributing emissions score described ~elow .. 'rhis >U1alysjs m\jst be considered in combination 

with other air quality and emi~sions-related information,' as well as information supporting the 

meteorology and geography factors, to support more speciJ!c conclusi.ons.27 

b. Contributing Emissions Score (CES) 

The CBS method is intended to be a more dctitiled· n1odel of the actual processes that affect the 

contribution linkage between a monitored violation ii1 a violating county and emission sources in 

a nearby potentially contributing county. ,[he CES is a metric that takes into consideration 

emissions data, meteorologictil data, distance, and air' quality .monitoring infonnation to provide a 

relative ranking of the contrjbution ·potential 9f·counties in and .near an area. Designed speciticai!y 

for the 24-honr FM2.5 NAAQS, it expands on the methodology for calculatingthc WES by adding 

considerations for episodic variatiotm in emissions, meteorology, and emiss.ions transport 

distances. These consideration.~. may be 'relevant to designations for a 24;hour PM!.s NAAQS, but 

are not as useful for evaluating contribltlion 'for- jlltrposes of an annual PM2.5 NAAQS for which 

monitored values on every moiiitored tiayare p~rt oftht' calcll)ations necessary to determine 

wh~ther there is a violation ofihe NAAQS at a partictllar monitor. The CES represents the 

relative maximum influence that.cmissions in that county haw on a county with a violating 

monitor. While the CES is a metric, it is. aJso a genel'al methoqo[ogy for considering many of the 

recommended factor'S: 

The CES28 for each co1mty is derived by incorporating similar infonnation used or developed for 

other analyses in the tlve-factor analytical fran1ewpr-k: 

• Major PM,.s ambient components~ total carbon (organic carbon (OC) and elemental 

carbon (EC)), sulfate, ni\J'atc, m1d inorganic pat1icles (crustal). 

0 Directl}'.J'mil£~4 Plvh,;. and ~.Qt.(Jl. .. g..,_SQ:z.J,!Q.,_Y.Oc,..and.Nl{'l}..e.missions-fot~the--···--·------­

highest (e.g., top 5-1 0%) PM2.s ainbi.et1t concentration days (herein called "high d~ys") 

within each season. 

27 For mere in/brmation about the WES procedures See: http://www.epa.govlpmdesignationsll99?standards/tcch.hJm. 

<!S For more intbt·mation on the bt~sic CES p·mcedufes.see: 

hup:llwvrw.epa.govlttn!naaqs/pmldocsl!sd_ces~methodology.pcf(. 

Page 21l of 34 
Elsctronic Filing- Rscivsd, Clsrk's Offics: OB/05/2013 

• Meteorology on high days using the NOAA HYSPLIT model for detcnnining trajectories 

of air masses f-or specified days. 

~ The "urban increment" associated \'lith a violating monitor on high days, which is the 

mban l'Ml.s concentration that kin uddition to a regional background f>MJ.~ 

concentration, determined for each PM1 .. 5 component. 

• Distance JJ·om each potentially oontrib~tting county to a county with a violating monitor. 

lt should be noted that the CBS guidance proced\ires listed het;e were designed aro~ind a 24-hour 

PM2.5 standard analysis. However, calculated apnual.PM25 concent.l'atii:ms v.~ll.be impacted by the 

trends in concentration levels throughout the year; pilrticularJy seasonal periods and days When 

concentrations peak during the year. The CES procedl!l'e can thus stilt b.e applied'io assess these 

short term periotls, or it c>tn be 1n9~ifled to appJy to .broader temporal periods (e.g, the e0tire 

year) for the analysis of anarn)ual PM25 standard. Like the WES, the CES should be regarded as 

one tool to evaluate the relative. impori&nce ofnmfli-pollutant em.issions from one county to 

others in th c same nonattainrrieo.t .area. The CES score of a cotuity. in one nonattaimnent area is 

not a so.itable point of compal'isoil to the CES score of a county. in Mother nonattainment area; the 

CES is only a meaningful tool to evaluate the relative contribution of ~ounties within the same 

nonattainment area. 

c. Source Apportionm()nt Modeling 

Source apportionment modeling i·s -a third aggregation technique which may be uset\tl to assess 

contribution to elevated P1hslcvels and thm,;:by to help identify possible areas for inclttslon in 

the nonattainment area because of their contrib11tion.to violations innem'by areas with violating 

monitors. Source apportionment mode.ling can track the contribution of directly etnitted PMz.s and 

PM2s precursors (e.g., S07.,.J\IO,, VOC, and NHJ} at a receptor tfotn any numberofuser-def.ined 

source regions. Emil>sions .are tracked with source apportionnient through PM2.5 formation, 

transport, and deposition p1·ocesses in the host·photoc;hemicalmodel (Yarwood, ct al., 2007). 

Source app0rtiomnent modeling <:·orn[)ines into a ~.i'hgie analysis several of the factors that the. 

EPA believes arc impottant for determining ·nonattaJnmcnt area boundaries; emissions, 

meteorology, and geography/tbpography. 

If a state chooses to conduct source apportionment modeling, the .EPA recommends that at least 

one entire year be modeled to captru;e as many source-receptor transport patterns as possible. 

Further, we recommend that states and tribes follow the relevant EPA guidanc·e Jbr photochemical 

modeling attainment demonstrations (USBPA, 20'07) whe11 eStablishing their source 

_..'!.02Q!·tionrnent IlJOQ~;I in g .ll]_att'Q!'m,. fn~S<@oh.Ushj~~Jl<lt=l.\U:S-OW.o.urc.e...~p,por.ti.oun=j___ _______ _ 

modeling exercise it would be expected that the violating monitors would establish the receptors 

in the analysis. The source regi6ns'Sho·uJd include-any and all nearby contributing m·eas broken 

out into appropriate jurisdictional areas (e.g., all C:BSA/C:SA c.ounties and adjacent counties 

associated with the violation). When -summadzing·lhe outputs from the source apportionment 

modeling, it is sugge.sted ·ihat the relative contributkms fi·orn nearby SO\lrce regions be compared 

against one another. lt is expected that the primary metTic :!rom tlie SAM modeling would be tl1c 

Page 29 of34 
Elsctronic Filing - Rscivsd. Clark's Offics: 08/0512013 

source region's contribution to the PM2.5 annual mean. While it is not possible to estabLish an a 

priori threshold contribution level, a reladve.cmnparison of source regions.should ensure 

capturing the majority of potential contributing sources within the nonattahunent area. 

-----------·-·-···----

Page 30 of34 
EIBctronic Filing - RBcivBd, CIBrk's OfficB: 08/05/2013 

ATTACHMENT 4 

Preparing and Running a HYSPLIT modeling unaly~ls f!Jr Ev.nlulltingNonattaimncnt Area 

Boundarie_~ for the 20.12 Annual PM2.s NAAQS Designations 

a. Wind Speed and Direction Sumniaries!Wind Roses 

A basic component of the meteorology factor ls a simple assessment of the wind dlrection.~nd 

speed fox the location under el(.amination, with the most frequently occurring wind direction and 

speed on days with high PM2.s concentrati\lnS biting compaced to the most .frequently occurring 

wind direction and-speed at other times, Many di_ff~rJ)nt combip'!tipns of monitors and data 

periods-season, sing'Je year, all data years-~ xnay be compar(id, Some comparioons may reveal 

clear relationships between particular wind·pattems and PMz.~ concentra.!\(Jns, and other 

comparisons may be inconclusive. Theresufts ofthese ecirnparisollS may inform the multi-factor 

analysis in assessxnents associated with deterniinmg·no.nattahrrrientarea boundaries. 

A basic wind ~ssessmcnt ·can he constructed fr<im houtJy observations of wind direction and 

speed. Hourly observations for many National Weather Sen<ice locations are available fi·om the 

National Climate Data Center.29 Additiimally, some air quality monitoring .sites have collocated 

meteorological sampling stations, and wind observaWons at H1ese sites that may be avai.lable via 

AQS. (Some wind data may not be reported hourly.) .In many cases, there are fewer wind 

observation sites than there are uir quality monitors in im area.)0 

Hourly wind data may be summarized in a-basic histogtam.or any other display of fi·equenqy 

distribution for direction and speed. lfis not appi'O]>riate to arithmetically average wind directions 

to obtain a mean wind direction as-representative ofa gener~l wind direction. The n)ode, not the 

mean., of wind d'irections is an appropriate statistic. 

A common i1lt1stration of frequency of wind 'direction and speed ls a wind ·rose, Most wind rose 

tools convert a table of hourly wind speeds .•md dfr.ections in.to a·fl:equency distribution for speed 

and direction, which can be illustrated in table form Ol: in 'the graphic known ns a \'.1nd . .rosc. The 

EPA does not recommend a·specifictool for producing wind roses, and there are many such tools 

available. However, as with any too·I 11sed in these assessments, the results snould be 

reproducible. Tile underlying data tiscd to· populate a wind rose should he made av.a'ilable along 

with fmy analysis that reHes upon the results o{the wind rose. Long-term (annual m· longer) wind 

speed and direction in l11e vicinity of the Violating mo.nitor(s) ·can be informative, especially in the 

case of standards ofthe annua:! average torm. However; more detailed analyses will usually be 

required to complete the picture of riJ~~_orology's cffect~on th~!!':1.2,s concentratimls in the area. 

29 ftp.ncdc. noatt.goy/pub/datalnoaa ur 

hlrp:l!gis, ned c. noaa.gov!map/viewerl#app:::-cdo&ofg"""'cdO&t heme=hourlyi.~ layers= J &node= gls Quality .ass;urance of 

lhe National Vleathcr Service datn is described here: hllp .. ·!lwwwl .ncdc.nnira.gov!pub/datalinvei1torieslish-qc.pdf 

:w Quality assmance ofthc collocated metcorologict~l datn is descdbed liere: 

htrp:I/WIVw.epa. go\•lafrlwiba(/pdfsll!.PA%10QA %20H andbook%20 Voft<me%20 Version I .0%201 1. 0 I. 06.pdj 

Page 31 of 34 
EIBctronic Filing- RBcivBd, CIBrk's OfficB: 08/0512013 

b. HYSI>LJT Trajectory Modeling 

Atmospheric trajectory models use meteorological data and mathematical equations to simulate 

three-dimensional transport in the utlllbspherc. Generally, the position of particles or parcels of air 

with time are calculated bascdunmeteorological data such as wind speed and direction, 

temperature, hmnidity, and pressure. Model results depend on the spatial and temporal resolution 

oft.he atmospheric data used; and also·otlthe complexity ofthe model itself The 

HYSPLIT (HYbrid Single-Particle Lagraugi:art Integrated Trajectory) model31 is frequently used 

to produce trajectories for assessments associate(! with.determining nonattainment area 

boundaries. HYSPLIT contains models for trajecioty;. dispersion, and deposition, however, 

analyses here only use the..t:rajec~orycomponent. The ·trajectory model, which uses existing 

meteorological foreca~t fiel!js fro11i regi'ohal 9i· glo'bal.m.or!l.els 'to compute advection (i.e., the rate 

of change of an atmos,phe<ic property caused qy the horlzoni:almovcme!lt of air) and stability, is 

designed to support a wide range of-simulations related to the atmospheric transport of pollutants. 

HYSPLIT tmjectories may be.prOcltJced for various combinations of time and locations, and those 

trajectories can be compared in Ina11ners similar to wind rose comparisons. When HYSPLJT 

trajectories· are produced for specific monitor...locations for d~ys -of high PM25 concentrations., the 

results illustrate the potential source region for the' air parcel tl1at affected the monitor on the day 

of the hlgh concentration. 

:while HYSPLIT is a useful tool for identifying meteorological patterns associated with 

exceedance events, HYSPLIT trajectories aione do not .conclusively indicate contribution to 

meosured high concentrations of PM2.S· Tberefore, they crmnot be used in isolation to determine 

inclusion or exclusion of an area within a ncmattainm¢lnt boundBl:y. While a HYSPLIT trajectory 

analysis alone cannot yield a conclusi.on .that" pitrticu Jar region contributes to PM2.s 

concentrations, it may be conceivable that a set of HYSPLIT trajectories that show no ·wind t1ow 

from a partic.ularreg,jo·n on aoy day with high PM1.s concent~ation measurements might supp01t 

disconnting that region as contl'ibuting to J'M ,;.conc~>ntrations. HYSP.LlT trajectories are very 

useful in GOmbination with 'information on the urban increment ofPM2.s, the typical species of 

PM2.s from local sources,-and the magnitude '81\d location ofthesectnissions sotJrccs. 

c. Interpreting HYSPLIT Results 

A HYSPLIT backward trajectory, ihc most commonttajecte>ry used in assessments nssociuted 

with dete.rminiug nonattaimnent.nrea boundatics, is-usually depl'cted brt a standard map as a single 

line extending i.n two dimensional (x,y) space from a starting point, regressing backwal'd in time 

as the line extend.s fi·om the starting point. An individual trajectory can have only one startil)g 

height; HYSPLIT can plot traj.ectcnies of differ~nt starting heights at the same latituclc!longitude 

starting point on the smi1e ~nap, automatica~1 using different colors far the difi~tm:tihg ____ . _______ _ 

·----- ne)ghts. HYSi'LIT will also include ·a vertical plot of the trajectories in time, with colors 

corresponding to the same trajectory in the (x,y) plot. This display catt be easily misinterpreted as 

having finer accm·acy than the llllclerlyin·g model and data, 

·' 

1 http:llready. arl.noaa.gov!JJYSP LJT.php 

Page 32 o£34 
EIBctronic Filing- RBcivBd, CIBrk's OfficB: 08/0512013 

It is important to observe the overall size ofihe plot, its width and lengthinkilometers,.and 

consider the size of an individual grid cell in the jt1jl\lt meteorologi1;al data set. These input grid 

cells are usually 40 km in width and length,.so the total area of~ tr~jectory plot may sometimes 

represent only a few meteorological grid cells. Jt is also Hnportatit to understand the trajectory line 

itself. The line thickness is predetermined as a use.r option, so ,{ril.oes not imply covemge other 

than to represent the .centerline of an air parcel's.rnotion calculated to arrive at the startin.g 

location at the starting time. Uncertainties·are clearly :presenHn these. results, and these 

uncertainties can be thought to. be a range on eitber side of the center linein which the a'ir parcel 

may he tbund, Further back·in time along the trajectmy p.ath, that range may be assumed.to 

increase. !n other words, one should avoid conch1ding a.rcgion is not along a n·ajectory's path if 

that tr!\jectory missed the region by a relatively small dista!)ce. As mentioned in the beginning of 

this section. the same cautions thai apply to ·intcrptetation·ofwim:lroses apply to interpretation of 

HYSJ>L!T trajectories. 

Detailed information for downloading, installing, and operating HYSPLIT .can be .found at'these 

websites: 

http://ready. arl.noaagov/HYSP LTJ:php 

http.;l/www. art. noaa.govldocumentslreportslhysplit,_ user _guide,pdj 

http:llwww.arl.noaa.gov/document.vlreports/cir/-i24.pdf 

HYSPL!T's many setup options allow great flexibility and. versatllity. However, careful selection 

and recording of these options is necessary to provide 1oevlewers the ability to reproduce the 

model results. The. fo1Jowing paragraphs describe the options that should be recorded, at u 

minimum, to reproduce a HYSPUT model nm. 

Model Version. If the HYSPLIT trajectory is produced vla the· NOAA Air Resources Laboratory 

(ARL) website (hltp:l/i'eady. ail.noaa.gov/HYSPJ.JT_iraj.php), ·note the "Modified:" date in the 

lower-left corner of .the webpage, a$ well ilirthe dat.e'the trajqctoty was produced. If the n·ajeat.ory 

is produced using a stand-alone version ofHYSPLlT, note the release date, which will be. 

displayed after exiting the main GUI screen, 

Basic Trajectory Information. Note the starring time (YY MM DD HR), the dw·alion ofihe 

lrajeclory in hours, and whether ihe trajectory is· backward or forward Note the latitude and 

longitude, as well as the starting height, for each slart]ng location. Starting heigh\ is given by 

defau.lt in meters above grpund level (AGL) unless another·option is selected. S:tarting heights are 

typically no less than 100 metersAGL to avoid direct "interference of terrain, and are typically no 

greater than 1500 meters AGL to confine the air p~rcel V{ithin tlie mixed layer, Some trajectories 

can escape the mixed layer, and ttiis result would be con.~idei:ed in the interpretation. 

Starting height and starting location will id~>ntil)' the three-dimensional location of the trajectory's 

latest endpoint in time if a backward trajectarx.:I:s selected (i.e. the s1a~_2:f_a traj~ctory goin,g _______ _ 

backward in time). 

Input Met•orologlcal Data Set. Note the input meteorological dala set used in the HYSPLJT 

model 1'\111. The origlmll file mune provides suflicient informatioJl to ldenti.cy the data set. 

Meteorological data fields to run tire model are already available for access through the HYSPLIT 

menu system, or by direct l'TP fi·om ARL. The ARL web server contains several meteorological 

Page 33 of34 
Elsctronic Filing- Rscivsd. Clsrk's Offics: 09/05/2013 

model data sets already converted into a HYSPUT comp1;1tible f<mnat.in the public directories. 

Direct access via FTP to these data files is built Into HYSPLIT's graphical user interface. The 

data files arc automatically updated on the server witP each new forecast cycle. Only an email 

address is required for the .password to access the server. ·The ARL analysis data archive ocnsists 

of output from the Global Data Analysis Sygfem (GPAS)and the NAM Data.Analysis System 

(NDAS -previously called EDAS) covering nmch ofNortb. America. Both data archives are 

availabie from 1997 in semi-monthly files (SM). The ED AS was saved at 80 kmresolution every 

3-h through 2003, and then a:t 40 km tesotution starting in. 2004. 

Detailed information on ~1! meteorological data available for use in HYSPLIT can be.found in the 

H YS.PLIT4 Users Guide (hltp:llwww:drl. noaa,gov/do.cumentskeports/hysplit_user_gulde.pdf). 

Vertical Motion Options. HYSPUT c.an employ one of 5 different methods for computing 

vertical motion. A sixth method is to accept.the vertical :motion values e;oil:tained within the input 

meteorological data ~et, effectively. using the vertical motion method used by theometeorological 

model that created the dataset Note whfch method was.selecteil as well us the vaTue chosen for 

the top of the model, inmet~rs AGL. 

Trajectory Display Options; The HYSPLIT trajectory model generates a text output ±lle of endpoint positions. The cnd.,point pos.ltion file; is:processcd by a\lother HYSPL!T modl.lle to produce 

a Postscript display ·file ot output files in nther display formats. Bomc parameters, such as map 

pl'ojcction and size, can be automatically computed base.d on the.Jocation and length of the 

trajectory, or they can be mat1uaUy set bji.the user. White these dispfay options do 110\ directly 

affect the trajectory information itself, noting these options will eliminate possible 

misinterpretation of identical trajectories because of differing display options, An .important 

display option is the choice of vertical coordinate, usually set to meters AGL for these 

assessments. 

Page 34 of34 
ILLINOIS POLLUTION CONTROL BOARD 

September 12, 20 13 

ILLINOIS POWER HOLDINGS. LLC AND 

AMERENENERGY MEDINA VALLEY 

COGEN,LLC, 

Petitioners, 

AMEREN ENERGY RESOURCES, LLC, 

Co-Petitioner, 

v. 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

ILLINOIS ENVIRONMENTAL PROTECION) 

AGENCY, ) 

Respondent. 

) 

) 

) 

) 

PCB 14-10 

(Variance- Air) 

HEARING OFFICER ORDER 

RECeiVED 

CLERK'S OFFrCE 

SEP 1 2 LUI::! 

STATE OP ILLINOIS 

Polfulion Control Board 

1J ORIGINAL 

On September 5, 2013, the Illinois Environmental Protection Agency (IEPA) filed its 

recommendation (Agency Rcc.) and both Petitioners and IEPA filed responses to questions posed by 

the Board on August 14, 20 13 through the Hearing Officer (Pet. Resp. to Aug. 8, 2013 Hearing 

Officer Order; Agency Resp. to Aug. 14, 20!3 Hearing Officer Order). In their response, Petitioners 

suggested the Board provide any additional or follow-up questions related to the response in advance 

of the hearing so that Petitioners might be beller equipped to provide an informed and thorough 

response. PeL Resp. to Aug. 14, 2013 Hearing Officer Order at 9. The hearing is scheduled for 

September 17,2013 in Springfield. 

As such, follow-up questions to the responses from the Board's staff are provided in 

Attachment A. Petitioners and TEPA are dire.cted to respond to the attached questions no later than 

10:00 a.m. on September 16, 2013. The responses may be filed through the Clerk's Office On-Line 

(COOL) on the Board's website at www.jpcb.statc.jl.us. The "mailbox rule" (35111. Adm. Code 

I 0 1.300(b )(2)) does not apply to the filing of these responses. Therefore, the Clerk must receive 

responses to the attached questions by 10:00 am on Monday, September 16,2013. The responses 

must also be served on those persons on the PCB 14-to service list, which is available on COOL 

IT IS SO ORDERED. 

ATTACHMENT_/_O __ 
2 

CERTIFICATE OF SERVICE 

It is hereby certified that true copies of the foregoing order were mailed, first 

class, on September 12, 2013, to each of the persons on the attached service list. 

It is hereby certified that a true copy of the foregoing order was hand delivered to 

the following on September 12, 2013: 

John T. Therriault 

Illinois Pollution Control Board 

James R. Thompson Center 

100 W. Randolph St., Ste. 11-500 

Chicago, Illinois 60601 

Carol Webb 

Hearing Officer 

Illinois Pollution Control Board 

1021 North Grand Avenue East 

P.O. Box 19274 

Springfield, Illinois 62794-9274 

217/524-8509 

Carol.Webb@illinois.gov 
-- . 

PCB 2014-010 

William D. Ingersoll 

Brown, Hay & Stephens LLP 

205 South Fifth Street, Suite 700 

P.O. Box 2459 

Springfield, IL 62705-2459 

PCB 2014-010 

Renee Cipriano 

Schiff Hardin, LLP 

6600 Willis Tower 

233 S. Wacker Drive 

Chicago, IL 60606-64 73 

PCB 2014-010 

Gina Roccaforte 

IEPA 

1021 North Grand Avenue East 

P.O. Box 19276 

Springfield, IL 62794-9276 

3 

PCB 2014-010 

Claire A. Manning 

Brown, Hay & Stephens LLP 

205 South Fifth Street, Suite 700 

P.O. Box 2459 

Springfield, IL 62705-2459 

PCB 2014-010 

Amy Antoniolli 

Schiff Hardin, LLP 

6600 Willis Tower 

233 S. Wacker Drive 

Chicago, IL 60606-64 73 

.. 
PCB 14-10 

ILLINOIS Pm'VER HOLDINGS, LLC and 

AlVIERENENERGY MEDINA VALLEY COGEN, LLC 

Attachment A 

QUESTIONS FOR PETITION"ERS 

Annual Emissions 

1. Petitioners present Tables 1 and 2 in Exhibit I 0 of the petition to demonstrate a "net 

benefit to the environment" of 74,303 tons in reduced S02 emissions from 20 I 0 through 

2020, and 7,778 tons in reduced S02 emissions from 2013 through 2020. Pet. E:<h. 10. 

(a) Petitioners state that lPH and Ameren anticipate closing on the transaction in the 

fourth quarter of 2013. Pet. at 31. Please present a revised version of Table 2 in 

the petition that takes into account only the emissions attributable to the fourth 

quarter of 2013 through the end of 2020 and the emission reductions attributable 

to retirernentofE.D. Edwards Unit 1 as early as 2017. 

(b) In PCB 12-126, Ameren Energy Resources (AER) provided a table showing the 

projected emissions during the years 2013 through 2019 using a revised heat input 

and emission reductions to reflect the closures of the Meredosia and Hutsonville 

plants. See PCB 12-126 AER's Resp. to [IPCB} Technical Unit's Questions filed 

July 30, 2012 at 8-9, Table 2. Please provide a similar table for projected 

emissions from the fourth qumter of 2013 through the end of 2020 that also 

includes the projected retirement ofE.D. Edwards Unit 1 as early as 2017. 

2. In response to question #1 in the August 14,2013 Hearing Officer Order, petitioners 

state, "'vVhilc Petitioners fully expect that emissions will be consistent with the numbers 

provided in Table 2, Petitioners at this time do not support annual emission caps relative 

to the MPS Group .... " Pet. Resp. to Aug. 14, 2013 Hearing Officer Order. Please 

comment on whether the current air permits for the five operating stations in. the MPS 

Group include a limitation on heat in. put, operating hours, or mass emissions. 

Proposed Variance Conditions 

3. !EPA's Recommendation suggested three additional conditions for the variance. See 

Agency Rec. at 30. Please comment on including these conditions in the requested 

variance. 

IPH-Ameren Transaction 

4. Assume for purposes of this question that the Board grants the variance requested in this 

matter and petitioners timely accept it. Please address t!Je legal effect on such a variance 

if after its acceptance the transaction through which lPH would acquire AER's active 

coal-fu·ed power plants never closes. 

5. The first condition in petitioners' proposed variance order begins as follows: "lf at any 

time [lPH] acquires ownership or control of the five operating power stations in the 
-. 

Ameren MPS group, IPH must assure compliance .... " Pet. at 69. Please address 

whether this contingency or threshold includes approval by the Federal Energy 

Regulatory Commission of the transaction by which IPH would acquire AER' s active 

coal .fired power plants. 

QUESTION FOR THE AGENCY 

SIP Revisions 

6. Please comment on whether SIP revisions that would include the requested variance 

would require assessing annual mass emissions under the variance. If so, please 

comment on the merits of including an annual mass emissions cap consistent with 

petitioners' projections in Table 2 of the petition along with the proposed mitigation S02 

emission rate in the variance conditions (as mentioned in the August 14, 2013 Hearing 

Ofticer Order question #1). 

EIBctronic Filing- RBcivBd. CIBrk's OfficB: 08/IB/2013 

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

ILLINOIS POWER HOLDINGS, LLC and ) 

AMERENENERGY MEDINA VALLEY ) 

COG EN, LLC, ) 

) 

Petitioners, ) 

) 

AMEREN ENERGY RESOURCES, LLC, ) 

) 

Co-Petitioner, ) 

) 

v. ) 

) 

ILLINOIS ENVIRONMENTAL ) 

PROTECTION AGENCY, ) 

) 

Respondent. ) 

PCB 14-10 

(Variance - Air) 

NOTICE 

TO: John Therriault, Clerk 

Illinois Pollution Control Board 

James R. Thompson Center 

I 00 West Randolph St., Suite 11-500 

Chicago, IL 6060 I 

SEE ATTACHED SERVICE LIST 

PLEASE TAKE NOTICE that I have today filed with the Office of the Pollution Control 

Board the ILLINOIS ENVIRONMENTAL PROTECTION AGENCY'S RESPONSE TO TilE 

ILLINOIS POLLUTION CONTROL BOARD'S QUESTION, a copy of which is herewith 

served upon you. 

DATED: SeptClllber 16,2013 

I 021 North Grand Avenue East 

P.O. Box 19276 

Springfield!, lllinois 62794-9276 

217.782.5544 

217.782.9143 (TDD) 

ILLINOIS ENVIRONMENTAL 

PROTECTION AGENCY 

By: ~- -p{tJ..c-~~-...s-­ Gina Roccaforte 

Assistant Counsel 

Division of Legal Counsel 

THIS FILING IS SUBMITTED 

ON RECYCLED PAPER 

f[ 

ATTACHMENT----
' . 

El8ctronic Filing - R8civ8d, Cl8rk's Offic8 : 08/1612013 

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

ILLINOIS POWER HOLDINGS, LLC and ) 

AMERENENERGY MEDINA VALLEY ) 

COGEN, LLC, ) 

) 

Petitioners, ) 

) 

AMEREN ENERGY RESOURCES, LLC, ) 

) PCB 14-10 

Co-Petitioner, ) (Variance - Air) 

) 

v. ) 

) 

ILLINOIS ENVIRONMENTAL ) 

PROTECTION AGENCY, ) 

) 

Respondent. ) 

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY'S RESPONSE TO THE 

ILLINOIS POLLUTION CONTROL BOARD'S QUESTION 

NOW COMES the Illinois Environmental Protection Agency ("Illinois EPA"), by its 

attorney, and pursuant to the Hearing Officer's Order dated September 12, 2013, respectfully 

submits the Illinois EPA's Response to the Illinois Pollution Control Board's follow-up question 

provided in Attachment A of that Order. 

QUESTION FOR THE AGENCY 

SIP Revisions 

6. Please comment on whether SIP revisio11s that would include the requested varia11ce 

would require assessi11g annual mass emissions under the variance. If so, please 

comme11t 011 the merits of ittcludillg an a11nualmass emissions cap consistellt with 

petitioners' projections itt Table Z of the petition alottg with the proposed mitigatio11 

S02 emission rate itt tlte varia11ce co11ditio11s (as mentioned itt the August 14, 2013 

Heari11g Officer Order question #1). 

Yes, as was required in the SIP revision for the previously granted Ameren variance, the 

Illinois EPA would need to assess annual mass S02 emissions in a revised SIP revision 

for the requested variance. However, there is no increase in S02 emissions from the 

requested variance over what is currently allowed in the variance previously granted to 

Ameren. Therefore, the Illinois EPA does not need to rely upon any annual mass 

emissions cap associated with the requested variance for approval of a SIP revision. In 
EIEH::tronic Filing- RBcivBd, CIBrk's OfficB: 08/16/2013 

fact, the Illinois EPA believes that the additional S02 reductions from the shutdown of 

E. D. Edwards Unit 1 will provide even greater S02 reductions than those contained in the 

previous SIP submittal for the already granted Ameren variance. 

DATED: September 16,2013 

I 021 North Grand Avenue East 

P. 0. Box 19276 

Springfield, IL 62794-9276 

2171782-5544 

2 

Respectfully submitted, 

ILLINOIS ENVIRONMENTAL 

PROTECTION AGENCY 

By: r;ii;-J~- Gina Roccaforte 

Assistant Counsel 

Division of Legal Counsel 
Electronic Filing- Recived. Clerk's Office: 08/16/2013 

BEFORE THE lLLINOIS POLLUTlON CONTROL BOARD 

ILLINOIS POWER HOLDINGS, LLC and ) 

A.MERENENERGY MEDINA VALLEY ) 

COGEN, LLC, ) 

) 

Petitioners, ) 

) 

AMEREN ENERGY RESOURCES, LLC, ) 

) 

Co-Petitioner, ) 

) 

v. ) 

) 

ILLINOIS ENVIRONMENTAL ) 

PROTECTION AGENCY, ) 

) 

Respondent. ) 

PCB 14-10 

(Variance - Air) 

AFFIDAVIT 

I, Jim Ross, under oath, hereby state that I am the Manager of the Division of Air 

Pollution Control in the Bureau of Air of the Illinois Environmental Protection Agency. I 

assisted in preparing and have reviewed the Illinois Environmental Protection Agency's 

Response to the Illinois Pollution Control Board's Question and the facts stated therein are true 

and correct to the best of my knowledge and belief. 

{3;. nager 

Division of Air Pollution Control 

SUBSCRIBED AND SWORN TO BEFORE ME 

Thisj}~of .S~fe.Mbe._r , 2013 

Bureau of Air 

Illinois Environmental Protection Agency 
.. ' EIBctronic Filing- RBcivBd. CIBrk's OfficB: 08/16/2013 

STATE OF ILLINOIS 

COUNTY OF SANGAMON 

) 

) 

) 

) 

) 

ss 

CERTIFICATE OF SERVICE 

I, the undersigned, an attorney, state that I have served electronically the attached 

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY'S RESPONSE TO THE ILLINOIS 

POLLUTION CONTROL BOARD'S QUESTION upon the following person: 

John Therriault, Clerk 

Illinois Pollution Control Board 

James R. Thompson Center 

I 00 West Randolph St., Suite 11-500 

Chicago, IL 60601 

and electronically and by mailing it by first-class mail from Springfield, Illinois, with sufficient 

postage afflXed to the fullowing persons: 

SEE ATTACHED SERVICE LIST 

DATED: September 16,2013 

1 02'1 North Grand A venue East 

P.O. Box 19276 

Springfield, IL 62794-9276 

217.782.5544 

217.782.9143 (TDD) 

ILLINOIS ENVIRONMENTAL 

PROTECTION AGENCY, 

~-~- Gina Roccaforte 

Assistant Counsel 

Division of Legal Counsel 
Electronic Filing- Recived. Clerk's Office: DS/16/2013 

Carol Webb, Hearing Officer 

Illinois Pollution Control Board 

I 021 N. Grand Ave. East 

P.O. Box 19274 

Springfield, IL 62794-9274 

Claire A. Manning 

William D. Ingerso II 

Bro,vn, Hay & Stephens, LLP 

205 S. Fifth Street, Suite 700 

P .0. Box 2459 

Springfield, IL 62705-2459 

SERVICE LIST 

Renee Cipriano 

Amy Antoniolli 

Schiff Hardin LLP 

233 South Wacker Drive, Suite 6600 

Chicago, IL 60606 

Faith Bugel 

Andrew Armstrong 

Environmental Law and Policy Center 

35 East Wacker Drive, Suite 1600 

Chicago, IL 6060 I 
EIBctronic Filing - RBcivBd, CIBrk's OfficB : 08/16/2013 

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

ILLINOIS POWER HOLDINGS, LLC and · ) 

AMERENENERGY MEDINA VALLEY ) 

COG EN, LLC; ) 

) 

Petitioners, ) 

) 

AMERENENERGY ) 

RESOURCES, LLC ) 

) PCB No. 14-10 

Co-Petitioner, ) (Variance- Air) 

) 

v. ) 

) 

ILLINOIS ENVIRONMENT.I\L ) 

PROTECTION AGENCY, ) 

) 

Respondent. ) 

NOTICE OF FILING 

To: ALL PERSONS ON THE ATTACHED SERVICE LIST 

Please take notice that today we have electronically filed with the Office of the Clerk of 

the Illinois Pollution Control Board Petitioners' and Co-Petitioner's Response to Illinois 

Pollution Control Board's Questions Set Forth in Hearing Officer Order of September 12, 

2013, copies of which are herewith served upon you. 

Dated: September 16,2013 

BROWN, HAY & STEPHENS, LLP 

Claire A. Manning 

William D. Ingersoll 

205 S. Fifth Street, Suite 700 

P.O. Box 2459 

Springfield, IL 62705-2459 

(217) 544-8491 

Fax: (217) 241-3111 

cmanning@bhslaw.com 

wingersoll@bhslaw.com 

/s/ Claire A. Manning 

Claire A. Manning 

SCHIFF HARDIN, LLP 

Renee Cipriano 

Amy Antoniolli 

233 South Wacker Drive, Suite 6600 

Chicago, Illinois 60606 

(312) 258-5550 

Fax: (312) 258-5600 

rcipriano@schiffhardin.com 

aantonio!li@schiffhardin.com 

/~ ATIACHMENT---
EIBctronic Filing- RBcivBd, CIBrk's DfficB: DB/1612013 

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

ILLINOIS POWER HOLDINGS, LLC and ) 

AMERENENERGY MEDINA VALLEY ) 

COGEN, LLC; ) 

AMEREN ENERGY 

RESOURCES, LLC 

Petitioners, 

Co-Petitioner, 

v. 

ILLINOIS ENVIRONMENTAL 

PROTECTION AGENCY, 

Respondent. 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

PCB No. 14-10 

(Variance- Air) 

PETITIONERS' AND CO-PETITIONER'S RESPONSE TO ILLINOIS POLLUTION 

CONTROL BOARD'S QUESTIONS SET FORTH IN HEARING OFFICER ORDER OF 

SEPTEMBER 12, 2013 

Petitioners Illinois Power Holdings, LLC ("IPH") and AmerenEnergy Medina Valley 

Cogen, LLC ("Medina Valley") and Co-Petitioner Ameren Energy Resources, LLC ("AER") 

provide the following response to questions posed by the Illinois Pollution Control Board in a 

Hearing Officer Order dated September 12, 2013. 

QUESTIONS FOR PETITIONERS 

Annual Emissions 

1. Petitioners present Tables 1 and 2 in Exhibit 10 of the petition to demonstrate a "net 

benefit to the environment" of 74,303 tons in reduced so2 emissions from 2010 

through 2020, and 7,778 tons in reduced S02 emissions from 2013 through 2020. Pet. 

Exh.JO. 

(' .. 

(a) Petitioners state that !PH and Ameren anticipate closing on the transaction in 

the fourth quarter of2013. Pet. at 31. Please present a revised version of Table 

2 in the petition that takes into account only the emissions attributable to the 

1 
Elsctronic Filing- Rscivsd. Clsrk's Offics: 08/16/2013 

fourth quarter of 2013 through the end of 2020 and the emission reductions 

attributable to retirement of E.D. Edwards Unit 1 as early as 2017. 

(b) In PCB 12-126, Ameren Energy Resources (AER) provided a table showing the 

projected emissions during the years 2013 through 2019 using a revised heat 

input and emission reductions to reflect the closures of the Meredosia atrd 

Hutsonville plants. See PCB 12-126 AER's Resp. to [IPCB] Technical Unit's 

Questions filed July 30, 2012 at 8-9, Table 2. Please provide a similar table for 

projected emissions from the fourth quarter of 2013 through the end of 2020 

that also includes the projected retirement of E.D. Edwards Unit 1 as early as 

2017. 

RESPONSE: 

The Tables, with some modifications explained below, are attached as Attachment A 

(responsive to !.a) and Attachment B (responsive to l.b). The Petitioners and Co-Petitioner 

understand from the nature of the Board's question that these Tables would begin with the period 

of Petitioners' ownership of the plants. In preparing the Petition, Petitioners and Co-Petitioner 

took the very same approach and methodology approved by the Board in the AER variance, as 

developed through discussions AER had with IEPA in advance of its filing (and as developed by 

IPH with IEP A in advance of this filing). Thus, in a very real sense, the environmental benefits 

recognized by the Board in granting the variance to the MPS Group in PCB 12-126 would 

continue under IPH' s ownership of the five operating plants in the MPS Group, as sho'\\'11 in 

Tables I and 2 of the Petition (Pet., Ex. 10-1 and 2). However, the Board's question focuses 

solely on the period of time of IPH's O'\\>nership, and Petitioners believe that to be the wrong 

regulatory analysis. Nonetheless, in furtherance of its environmental commitment, IPH would 

agree to accept as an additional condition of the variance order a cap on tonnage S02 emissions 

over the period 4th Quarter 2013 - 2020 to ensure that the environmental benefit identified in the 

Petition (i.e., a reduction of S02 emissions of 7,778 tons) is achieved solely during the IPH 

o'\\'llership period. Specifically, as identified in the attached tables, provided in response to 

2 
EIBctronic Filing - RBcivBd, CIBrk's DfficB: DB/1612013 

questions 1 (a) and l(b ), IPH proposes to accept a cap of 327,996 tons of S02 over the period 4th 

Quarter 2013 - 2020, which is 7,778 tons below the MPS baseline S02 tons. Such a cap is 

significantly more stringent than the terms of the existing variance. 

IPH will meet the proposed emission cap at the end of the variance term by a variety of 

methods, many of which have been identified in the Petition but were not quantified, and are not 

quantifiable, due to the difficulty in doing so at this time. For example, the additional 

commitments recommended by the IEP A and accepted by IPH, use of low sulfur coal, operation 

of the Duck Creek and Coffeen FGD systems at 98% removal efficiency, and closure of Edwards 

Unit I (see answer to question 3), are expected to result in additional S02 emission reductions 

during the term of the variance. 

The construction of the FGD system at Newton also will garner emission reductions in 

advance of the end of the variance term, which have not been provided for in Tables 1 and 2 of 

the Petition (Pet. Ex. 10-1 and 2). Construction will not be immediate, as each unit must be 

non-operational during the installation of its FGD system. Thus, emission reductions will occur 

during the fmal phase of construction. On the basis of the above, as well as other methods, 

including management of unit utilization, IPH believes it can agree to the emission cap proposed 

in the attached Tables, which would demonstrate an environmental benefit during the period 4th 

Quarter 2013 - 2020 that equates to the environmental benefit identified in Table 2 of the 

Petition. (Pet. Ex. 1 0-2). 

Although not directly responsive to the Board's question, IPH would be remiss if it did 

not also point out, as IEPA advised the Board in the IEPA Recommendation, that IPH and 

Dynegy executed a Memorandum of Agreement ("MOA") with the IEPA on September 4, 2013. 

3 
Electronic Filing- Recived. Clerk's Office: 08/1612013 

The MOA memorializes the commitment to close E.D. Edwards Unit 1 and, as well, provides the 

following environmental benefits: 

• Implementation of Advanced Gas Path Technology at Kendall Power Station; and 

• Permanent Retirement of the air permits for the Stallings and Oglesby 

Combustion Turbine Facilities. 

This MOA again demonstrates IPH and Dynegy's commitment to environmental progress. 

2. In response to question #I in the August 14, 2013 Hearing Officer Order, petitioners 

state, "While Petitioners fully expect that emissions will be consistent with tlze numbers 

provided in Table 2, Petitioners at this time do not support annual emission caps 

relative to the MPS Group .... " Pet. Resp. to Aug. 14, 2013 Hearing Officer Order. 

Please comment on whether tlze current air permits for the jive operating stations in 

the MPS Group include a limitation on heat input, operating hours, or mass emissions. 

RESPONSE: 

The five operating stations in the MPS Group are permitted for operation at 100% 

capacity, 8760 hours per year and do not have heat input or operating hour restrictions. 

However, all of the plants have air permits with mass emissions limits for S02 in accordance 

with state regulations (Coffeen, Edwards and Joppa; lb/hr limit on a plant-wide basis) or federal 

regulations (Duck Creek and Newton; NSPS Subpart D emission rate limits on a unit basis; the 

Newton Unit 2 primary air duct burners are also subject to pounds per hour and ton per year 

limits). The relevant conditions of the air permits for the five operating stations in the MPS 

Group, responsive to question 2, are provided as Attachment C. 

3. IEPA 's Recommendation suggested three additional conditions for the variance. See 

Agency Rec. at 30. Please comment on including these conditions in the requested 

variance. 

4 
EIBctronic Filing - RBcivBd, CIBrk's OfficB: 08/16/2013 

RESPONSE: 

The IEPA's recommendation sought the following commitments from IPH and, 

additionally, requested that the Board include those commitments as variance conditions. The 

conditions are as follows: 

i. Petitioner IPH must operate the existing FGD systems at the Duck Creek and 

Coffeen Energy Centers at an S02 removal rate of at least 98 percent; 

n. Petitioner IPH must continue to burn low sulfur coal (no more than 0.55 

sulfur/mmBtu) from the Powder River Basin at the E. D. Edwards, Joppa and 

Newton Energy Centers; and 

iii.· Petitioner IPH must permanently retire E.D. Edwards Unit 1 as soon as MISO 

allows E.D. Edwards Unit 1 to be retired (as early as 2017). 

IPH consents to include each of these commitments as variance conditions for which IPH 

is responsible. As the Hearing Officer's Order did not provide sufficient time for IPH and IEP A 

to discuss appropriate language to malce these conditions enforceable, IPH will propose such 

language in its Post-Hearing Comments, following discussions with IEP A. 

4. Assume for purposes of this question that the Board grants the variance requested in 

this matter and petitioners timely accept it. Please address the legal effect on such a 

variance if after its acceptance the transaction through which !PH would acquire 

AER 's active coal-fired power plants never closes. 

RESPONSE: 

Petitioners and Co-Petitioner anticipate that at the time the Board grants the requested 

variance, there will be no remaining contractual conditions or regulatory approvals which would 

preclude the closing of the transaction. Petitioners and Co-Petitioner continue to believe that the 

Federal Energy Regulatory Commission ("FERC") will approve the transaction in the fourth 

quarter of 2013. As such, closing is expected to occur shortly after the Board issues its order. At 

5 
Electronic Filing- Recived. Clerk's Office: DB/1612013 

closing, the Petitioners will execute a signed certificate of acceptance. Consistent with 35 Ill. 

Adm. Code 104.240, the signed acceptance renders all terms and conditions of the variance relief 

granted in the Board's order in docket PCB 14-10 as effective, enforceable, final and 

binding. The signed certificate of acceptance will be filed with the Board and served on the 

Agency. Upon execution of the certificate of acceptance, the order granting variance relief in 

docket PCB 12-126 Vl'ill be superseded by the order granting variance relief in docket PCB 14-10 

and the order in docket PCB 12-126 will be void. A draft of the acceptance form is included for 

the Board's use as Attachment D. Further, Conditions 1 and 2 of the proposed Board order can 

be modified as follows: 

I. If at any time Illinois Power Holdings, LLC (IPH) acqffires ewnersffip er centre! 

ef tfie five eperating pevrer statiens in 1he 1\rneren A4PS Greup, IPH must assure 

compliance with Condition 2 of this Order and must comply with an overall S02 annual 

emission rate of 0.35 lb/mmBtu through December 31, 2019, and beginning January 1, 

2020, must comply with an overall S02 annual emission rate of 0.23 lb/mmBtu. 

2. At any titne AmerenEnergy Medina Valley Cogen, LLC acquires evrnership er 

eentrel ef tfie Mereelesia anel Hutsenville Fewer Statiens, it shall not operate the 

electrical generating units at the Meredosia and Hutsonville Power Stations these plants 

until after December 31, 2020. The FutureGen project at the Meredosia Energy Center is 

exempt from this restriction. 

Assuming hypothetically that the transaction does not close, the certificate of acceptance 

would not be executed, and AER would continue to ovm the active and inactive energy centers 

and would continue to comply with the order issued in PCB 12-126. 

5. The first condition in petitioners' proposed variance order begins as follows: "If at 

any time [IPH] acquires ownership or control of the five operating power stations in 

6 
EIBctronic Filing - RBcivBd. CIBrk's OfficE!: 08/1612013 

the Ameren MPS group, IPH must assure compliance . ... " Pet. at 69. Please address 

whether this contingency or threshold includes approval by the Federal Energy 

Regulatory Commission of the tra1zsaction by which IPH would acquire AER 's active 

coal-fired power plants. 

RESPONSE: 

FERC approval of the transaction is a mandatory regulatory and contractual condition. 

Such approval is pending and expected, as the Applicants have satisfied FERC's criteria for the 

transfer of ownership of the active coal plants to Dynegy and the inactive coal plants to Medina 

Valley. Again, the certification of acceptance of the variance will not be executed until after 

FERC approval occurs. 

Respectfully submitted, 

ILLINOIS POWER HOLDINGS, LLC 

By: /s/ Claire A. Manning 

One of!ts Attorneys 

BROWN, HAY & STEPHENS, LLP 

Claire A. Manning 

Daniel K. Wright 

William D. Ingersoll 

205 S. Fifth Street, Suite 700 

P.O. Box 2459 

Springfield, IL 62705-2459 

(217) 544-8491 

Fax: (217) 241-3111 

cmanning@bhslaw.com 

wingersoll@bhslaw.com 

7 

AMEREN ENERGY RESOURCES, LLC 

and AMERENENERGY MEDINA 

VALLEY COGEN, LLC 

By: /s/ Renee Cipriano 

One of Their Attorneys 

SCHIFF HARDIN, LLP 

Renee Cipriano 

Amy Antoniolli 

233 South Wacker Drive, Suite 6600 

Chicago, illinois 60606 

(312) 258-5550 

Fax: (312) 25 8-5600 

rciprianolalschiffhardin.com 

aantoniollilalschiffhardin.com 
Elsctronic Filing- Rscivsd, Clsrk's OfficB: DB/1612013 

CERTIFICATE OF SERVICE 

I, the undersigned, certify that on this 16th day of September, 2013, I have served 

electronically the attached Petitioners' and Co-Petitioner's Response to Illinois Pollution 

Control Board's Questions Set Forth in Hearing Officer Order of September 12, 2013, upon 

the following persons: 

John Therriault, Assistant Clerk 

Illinois Pollution Control Board 

James R. Thompson Center 

Suite I 1-500 

100 West Randolph 

Chicago, Illinois 60601 

and by first class mail, postage affixed upon: 

Carol Webb, Hearing Officer 

Illinois Pollution Control Board 

1021 North Grand Avenue, East 

Springfield, Illinois 62794-9276 

Gina Roccaforte, Assistant Counsel 

Division of Legal Counsel 

lllinois Environmental Protection Agency 

1021 North Grand Avenue, East 

P.O. Box 19276 

Springfield, Illinois 62794-9276 

Faith E. Bugel 

Andrew Armstrong 

Environmental Law & Policy Center 

35 E. Wacker Drive 

Chicago, lilinois 60601 

./ s/ Claire A. Manning 

Claire A. Manning 

8 
Electronic Filing- Recived, Clerk's Office: 08/16/2013 

AFI<li>A VIT OF DANIEL P. THOMPSON 

My name is Daniel P. Thompson. I am Vice President and General Manager for Dynegy 

Midwest Generation, LLC ("DMG"), an indirect, wholly owned subsidiary of Dynegy Inc. 

("Dynegy"). I also serve as Vice President of Illinois Power Holdings, LLC ("!PH"), which is 

also an indirect, wholly owned subsidiary ofDynegy. My business address is 604 Pierce Blvd., 

O'Fallon, Illinois, 62269. I make this affidavit based on personal knowledge or on knowledge I 

have obtained through inquiry of individuals employed by Dynegy or its affiliates. 

As Vice President of DMG, I am responsible for the safe and efficient operation of 

Dynegy's ccal-fired electric generating fleet in Illinois. My responsibilities include oversight of 

environmental compliance at Dynegy' s Illinois coal fleet. Subject to the IPH-Ameren 

transaction closing, this responsibility will include the five plants in the Ameren MPS Group that 

are the subject of the requested variance. I have reviewed the Board's questions that have been 

presented in the Hearing Officer Order dated September 12, 2013. l have also reviewed the 

Petitioners' responses to those questions, have assisted in their development, and concur in these 

responses. To the best of my knowledge and belief, the facts contained therein are true and 

correct. 

FURTHER, Affiant sayeth not. 

1

1 ,· ~ 

DA'I"ED·. , ~· ) ' n-'- ·I llJ,.~.L_J I 7 7 ~I) ~( --+"'"4"-~ .!.____:__:o__c--'------ 1 

Subscribed and sworn, to 

before me this I (_o·l'i-1 day 

o(St(ptember 201~. , l\ 

c~J /Jtl/rufJt;; .~l clrlt{iliL /f Ne\TARYP B IC 

'. 

OFFICIAL SEAL u JENNIFER L. POWERS 

NOTARY PUBUC, STATE OF ILLINOIS. 

w;>IIV;.;C:;;O;;;MM;;;ISS~ION;;;.:;EX:;;Po;IR:,:,ES.,_.:•·\8;2015 

~ Danit9Thompson 
Electronic Filing - Recived, Clerk's Office: 08/16/2013 

ATTACHMENT A 
Baseline Heat Input 

MMBtu ' 

' 

Eh:Jctronic Filing - Recived, Clerk's Office: 08/1612013 

Response Table 1(a) 

MPS Baseline S02 

S02 I I 

Varianqe S021 Reduced Net Variance 

Note for the "Cumulative Reductions in S02 Variance Tons" column, a positive number indicates an emission decrease (benefit)_ 

{1) Reduced tons shown for 2013-2020 are based on not operating Hutsonville and Meredosia. Reduced tons in 2017-2020 are less nearly t

worst-case potential S02 emissipns from FutureGen 2.0. Tons shown for 2013-2016 do not include any S02 emissions for FutureGen 2.0 b

FutureGen 2.0 is not scheduled to begin operations until mid-2017. Beginning in 2017, reduced tons shown include the emissions reduction

the projected retirement of E.D. Unit 1 (as early as 2017). 
EIBctronic Filing- RBcivBd, CIBrk's OfficB: 08/1612013 

ATTACHMENTB 
Baseline Heat I, MP8 802 

Input Rate 

Electronic Filing- Recived, Clerk's Office: 08/1612013 

Baseline 

802 

Response Table 1(b) 

Variance 802 

Rate I Adjusted Heat Input! Variance 802 Cumulative 

Note for the "Cumulative Reductions in S02 Variance Tons" column, a positive nUmber indicates an emission decrease (benefit). 

Table includes the projecled retirement of E.D. Edwards Unit 1 as early as 2017. 
l:lectronic Filing - Recived, Clerk's Office: 08/16/2013 

ATTACHMENT C 
r) 

0 

EIBctronic Filing- RBcivE!d, CIBrk's OfficE!: 08/1612013 

.c.-_. , I 

ILliNOIS ENVIRONMENTAL PROTECTION AGENCY 

P.O. Box 19506, SPRINGFIELD, illiNOI> 62794-9506 

RENEE CiPRI~NO, DIRECTOR 

Y< <' CV //1 j.;>c:, 

Rf\-L.. 

CDfj 

217/782-2113 

l'ERMITTEE 

Ameren Energy Generating Company (CIPS) 

Attn: Michael L. Menne, l1anager Environmental, Safety and Health 

1901 Chouteau Avenue 

P.O. Box 66149, MC602 

St. Louis, Missouri 63IG6-6149 

I.P. No.: 143805AAG 

Date Received: June l0 1 2004 

Expiration Date: June 30, 2005 

7800 South Cilco Lane, Bartonville~ Peoria county 

Permit is hereby granted to the above-designated Permittee to OPERATE 

emission source(s) and/or air pollution control equipment consisting of 

Boiler Nos. 1, 2, and 3 with electrostatic precipitators, low NOx burner 

combustion system, flue gas conditioning systems, fuel handling facilities, 

and fuel storage tanks as described in the above~~eferenced application. 

This permit is subject to standard conditions attached hereto and the 

following special condition(s): 

la. The average S01 emissions from Boilers 1, 2 and 3 as a group shall not 

exceed 4.7~ lb/mmBtu of actual heat input, on a daily basis 1 pursuant 

to 35 IAC 214.56l{a). 

b. The average SO: emissions from each boiler shall not exceed 5.6 pounds 

of so2 per mmBtu of actual heat input on a daily basis, pursuant to 35 

IAC 2H. 561 (b). 

c. S02 emissions from Boilers ~, 2 and 3, as a group, shall not exceed 

34,613 pounds per hour, on a 24-hour average basis, pursuant to 35 IAC 

214.561 (c). 

Note: The above limit reflects a site-specific determination of the 

applicable limit adopted by the Illinois Pollution Control Board 

in Regulatory Proceeding R02-21. 

2. Emissions of particulate matter from the boilers shall not exceed the 

following limits in any one-hour period: 

Boiler 1 

Boiler 2. 

Boiler 3 

Limit (Lb/mmBtu) 

0.20" 

0.15" 

0.10 

Rule 

35 IAC 212.203(a) 

35 IAC 212.203 (a) 

35 IAC 212.202 

This limit reflects a site-specific determination of the 

applicable limit adopted by the Illinois Pollution Control Board 

in Regulatory Proceeding RB2-1. 

Roo R. BlAGOIEYICH, GOVERNOR 

PRINTED ON RECYCleD PArER 
l:lsctronic 1-iling - l~scivsd, ~lsrk's UtticB: UB/1612013 

Page 2 

3. Except as provided by Conditions 1 and 2, emissions and opacity from 

the boilers shall compl~ with the standards of general applicebility 

for existing coal-fired boiler including the new requirements of the NO~ 

trading Program~ 

4a~ .The Permittee shall submit a quarterly excess emission report of 

emissions in excess of those allowed Py Title 35 subtitle a for each 

boiler as indicated in 35 Ill. Adm. Code 201.405. This report shall be 

p~stmarked within forty-five days after the end of each calendar 

quarter and shall be based on data from the Continuous Emissions 

Monitor System (CEMS). 

i. EXcess emission and monitor performance reporting shall include 

the following, 

A. The starting date and time of the excess emissions; 

B. The duration of the excess emissions; 

c. The magnitude of the excess emissions; 

D. The oause of the excess emissions; if known; 

E. Corrective actions taken to lessen the emissions; and 

F. The operating status of the monitoring system including the 

dates and times of any periods during which it was 

inoperative. 

ii. This report shall be effective beginning with the first Quarter, 

1995 (January lst through March 31st, 1995} 

iii. If there were no excess emissions during the reporting period, 

the report shall so state and include information about the 

operating status of the monitoring equipment during that pe~iod. 

b. All records produced by the continuous systems shall be retained by the 

Permittee for a period of not less than two (2) years. 

Sa. Operation in excess of applicable opacity, particulate matter, and 

carbon monoxide emission standards 1 is allowed during periods of 

startup, malfunction 1 and breakdown. 

b. ~he Permittee shall keep a record of each startup, including 

information as to the length of time that such operation exceeded 

applicable standards and limitations, and a justification for the 

length of startup. 

c. The Permittee a·hall notify tl'ie ··Illinois EPA's Regional Office by 

telephone as soon as possible during normal working hours upon the 

occurrence of excess emissions due to malfunctions or breakdowns. The 

Permittee shall comply with all reasonable and safe directives of the 

Regional Office regarding such malfunctions and breakdowns. 
) 

EIBctronic Filing- RBcivBd, CIBrk's OfficB: 08/1612013 

Page 3 

d. The Permittee shall maintain records of excess emissions during 

malfunctions and breakdowns. As a minimum, these records shall 

include: 

i. The date and duration of the malfunction or breakdown. 

ii. A full and detailed explanation of the cause for such emissions. 

iii. The type and quantity of contaminants emitted. 

iv. The measures used to reduce the quantity of emissions and the 

duration of the occurrence. 

v. The steps taken to prevent similar malfunctions or breakdowns 

and/or to reduce their frequency and severity. 

e. The Permittee shall retain the records required by this special 

condition for a period of at least two (2) years following an event. 

These records shall be maintained at a readily accessible location at 

the plant and shall be made available to representatives of the 

Illinois EPA during normal working and/or operating hours. 

f. The Permittee shall not continue operation during malfunction or 

breakdown beyond such time as is necessary to prevent injury to persons 

or severe damage to equipment or to provide essential services. 

Ga. Organic liquid by-products or waste materials other than those 

permitted by Condition 6(b) and (c) shall not be burned in Boilers 1, 

2, and 3 without written permission from this Illinois EPA. 

b. Waste oils fitting the following description may be burned in the above 

referenced boilers! 

i. Lubricating oil from coal mills, coal handling machinery, fan 

motors, pumps, turbines, and internal combustion engines. 

ii. Hydraulic fluids. 

iii. Mineral oil dielectric fluids containing less than two {2) ppm 

PCBS. 

iv. Used grease. 

c. Boiler chemical cleaning wastes may be burned in the above referenced 

boilers. 

d. The Permittee sh~ll analyze, on an annual basis, a representative 

sample of the materials listed in condition 6(b) above for arsenic,· 

chromium, cadmiuml lead, flash point, total halogens, and heat content. 

e. The Permittee shall analyze, on an annual basis, a representative 

sample of the materials listed in Condition 6(c) above for pH, flash 

point, heat content, total halogens, arsenic, barium, mercu:r;y 1 

chromium, lead, selenium, and silver. 
( 

tiBctronic t-iling- I~BcivBd, ~IBrk's Uttic8: U~/11:1/LUI::J 

Page 4 

7a. 

None of the waste materials described in Conditions G{b) and (c) shall 

be hazardous. 

i. Upon written request by the Illinois EPA, the particulate matter 

concentrations in the effluent streams of Boiler{s} shall be 

measured by an approved testing service, during conditions which 

are representative of full load. 

ii. The following methods and procedures shall be used for testing of 

emissions, unless another method is approved by the Illinois EPA: 

Refer to 40 CFR Go, Appendix A for USEPA test methods. 

Location of Sample Points 

Gas Flow and Velocity 

Particulate Matter 

US!lPA Method l 

US!lPA Method 2 

US6PA Method 5 

b. Prior to carrying out these tests, the lllinois EPA - Air Compliance 

section and Illinois EPA - Air Regional Field Office, shall be notified 

a minimum of thirty (30} days prior to the expected date of these tests 

and further notified a minimum of five (5) working days prior to the 

test of the exact date, time, and place of these tests. to enable the 

Illinois EPA to witness these tests. 

i. Illinois EPA- Air Compliance Section 

Illinois Environmental Protection Agency 

Bureau of Air 

Compliance & gnforcement Section (MC 40) 

P.O. Box l92?6 

Springfield, Illinois 62794-9276 

ii. Illinois £PA - Air Regional Field Office 

Illinois Environmental Protection Agency 

Division of Air Pollution control 

5415 North University 

Peoria, Illinois 51614 

c. Three (3) copies of t.he Final Report(s) for these tests shall be 

submitted to the Illinois EPA within l4 days of the compiling and 

finalizing of the test results. 

B. The Illinois EPA shall be allowed to sample all coal at the station and 

shall be furnished replicate coal samples upon request. 

9a. This permit allows for· the burning of sub bituminou·s coal from Powder 

River Basin (PRE) in the boilers (not to exceed 120 days) of 

operational and emissions testing purposes~ as described in the 

Permittee's letter of June 4, 2004 1 such that the boiler continues to 

comply with applicable rules and regulations governing air pollution 

and with the conditions set: fol:"th in this operating permit. 
.~·· ~"\ 

(~, .. ) 

Elsctronic Filing- Rscivsd, Clsrk's OfficB: 08/16/2013 

Page s 

b. i. The ~ermittee shall notify the Illinois BPA in writing at least 

fourteen (l4) days prior to initial burning of any coal from a 

new mine. This notification shall be sent to the Illinois EPA's 

Regional Office and the Illinois EPA's Source Emission Test 

Specialist and shall include as a minimum! Information regarding 

fuel analyses, quantities and types of fuel(s) to be burned, 

planned start time and date, duration of test period, and a 

description of the test plan. The duration of any teat burn 

shall not exceed 120 days unless the Illinois EPA has approved a 

longer period. 

ii. Notwithstanding the 120-day period specified above, the Permittee 

may conduct an evaluation or trial burn of sub bituminous coal 

from the Powder River Basin until July 30, 2004. 

c. Prior to revising this operating permi~ to allow for the continued 

burning of coal from a new mine in significant amount or a specific 

alternative fuel, the Illinois SPA may require appropriate emission 

testing to be carried out in accordance with the provisions of 

Condition 7. 

It should be noted that this permit has been revised to address changes in 

the coal supply to the boilers and reflect current emission standards for the 

boilers. 

(--,\ !f you haV'e any questions on this permit~ please contact Kunj Patel at 

' \._j ' Zl7 I 7 B 2-2113. 

Donald E. Sutton, P.E. 

Manager 1 Permit Section 

Division of Air Pollution Control 

DES:KP:jar 

cc: Region 2 
electronic Hling - l~ecived, ~lerk's Uttice 

STATE Or ILLINOIS 

ENVIP.OUMSUThL PROTECTION ~G&NCY 

DlVISlON Of' AIR POLLU'.riON CONTROL 

P.O. BOX 19506 

SPRlNGFIELD, ILLINOIS 62794·9Sd6 

U~/ll:i/LUid 

.. L) -----------::==-=::==-----------, STANDARD CONDI~IONS 

FOR 

OPt~~IN~ PERMITS 

May, 1~9J 

The Illinois Environmental Protection A.ct {Illinois Revised Statutes, Chapter 111-1/2, Section 

1039) grants the Environmental Protection Ag~ncy authority to 1~pose conditions on per.mits which it 

i:Jsues. 

The following condition~ are applicable unless ~uper~eded by special pe~it conditions{s). 

1. The issuance of this permit doe" not release the !?a..rmittee £tom compliance \fith .state and 

tederal regulations Which are part of the Illinois State Implernentation E'le.n, as wall as With 

other applicable statues and re9ulations of the United States or thG State of Illinois or with 

applicable local law3, ordinances Dnd regulations. 

2 I The Illinois EPA has issued this permit based upon the infornta.tion submitted oy the Permittee 

in the permit application. Any m!sinto.rrnation 1 false .,t~tement or mi.srepresentation in the 

application shall be ;round for revocation under 35 Ill. Adm. Code 201.166. 

3. a. The Permittee shall not authorize, cau~e, direct or allow any modification, 3S defined in 

35 Ill. A.dm. Code 201.102, of equipment, operations or practices which are reflected in 

the permit application a.s submitted unless a new application or .tequest for rev:i.$ion of 

the existing permit is filed with the Illinoi5 EPA and unless a new petrnit or revision of 

the existing permit{s} is issued for such modification. 

b. This permit only cov~ks ~ission source~ and control equipment while physically present at 

the indicated plant location (s). Unless the permit .5pecifically provides for equipment 

relocation, this permit is void for ~n ite~ of Qquipment on the day it is removed from th~ 

perm~tted location{s) or if all equipment is removed, notwithstanding the expiration date 

specified on the permit. 

4. The Permittee shall allow any duly authorized agent of the Illinois tPA, upon the presentation 

of credentials, at reasonable times: 

a. To enter the Pern'.ittee' s p:;oparty where actual or potential effluent, emission or noise 

sources are located or where any activity i$ to be conducted pursuant to this permit; 

b. 'to have access to aod to copy any records required to be kept undet the terrn.s and 

conditions of this permit; 

c. 'l'o inspect, including du.ring any hours of opet"ation of equipment constructed or operated 

under this permit, such equipment and any equipment required to be kept, used, operated, 

calibrated and ~intalned under this permit; 

d. To obtain and remove samples of any discha~ge or emission of pollutant~; and 

e. To enter and utilize any photographic, recording, testing, monitoring or other equipment 

for the purpos.e. of presQrving, te3ting, monitor.l.ng or recording any activity1 discharge o_r 

emiss"!Oh authorized by this pe:crn.it. 

5. The issuance of this permit: 

a. Shall not be consider.ed as in any manner affecting the title of the premises upon which 

the pennitted facilities Bre located; 

S12-022~ 090-005 

1\f'C 161 Rev. Hat-ch, 2C}Gl 

PRINTED ON RECYCLED ~APER 
EIBctronic Filing- RBcivBd, CIBrk's OfficE!: DB/16/2013 

.· 

' ' .. .. 

Directory 

Environmental Protection Agency 

Bureau of Air 

May :Z:Z, :ZOOJ 

For assistance in preparing a permit 

applfcation, contact the Permit Section: 

Illinois EPA 

Division of Air Pollution Control 

Permit Section 

1 iili N, Grand Ave E. 

P .0. Box 19506 

Springfield, Illinois 62794·9506 

:mnB2-:Z11J 

Or contact ;z regional office of the Flelt1 

Operaticms Secfi'tm. The regional 

offices and tlleir areas ofresponslbUizy 

are shown on the map. The IU!dresses 

,.·-··)!elephone numbers of the regional 

t...., .• ces flnasft>ltom: 

Illinois EPA 

Region 1 

Bureau of Air, FOS 

9511 West Harrison 

Des Plalnes,IUinols 600lG 

84 7/l94-4000 

lllinolsEPA 

R~glon :Z 

5415 North Un!viverilty 

Peoria, Illinois 61614 

30!1/693·5461 

Illinois EPA 

Region3 

2009 Mall Street 

Colliusville, Illinois 622~_ 

618/346-5120 

'• 

.. 

;. ·-· 
tlectronic riling- l<ecived, L;ierk's Uttice: U~/11:i/LU1:5 

Rece.tvd /ti-tf-2oos- Sct-J 

n'le: Aeii .3./.1/...J 

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY 

1021 NoRTH GRAND AveNue EAST, P.O. Box 19506, SPRINGFIELD, IlliNOIS 52794-9506-1 2171 782-2113 

ROD R. BLACOJEVICH, GOVERNOR DoUGlAS P. ScoTT, DIRECTOR 

217/782-2113 

CLE~ AIR ACT PERMIT PROGRAM (CAAPP) PERMIT 

PERMITTEE 

AmerenEnergy Resources Generating Company 

Attn: Michael L. Menne 

1901 Chouteau Avenue 

St. Louis, Missouri 63101 

Application No.: 95070026 I.D. No.: l43805AAG 

Applicant's Designation: Date Received: July 10, 1995 

Operation of: Electrical Power Generation at Edwards plant 

Date Issued: September 29, 2005 Expiration Date': September 29, 2010 

source Location: 7800 South CILCO Lane. Bartonville. Peoria County 

Responsible Official: Gregory T. Russell, Manager Edwards Power Station 

This per.mit is hereby granted to the above-designated Permittee to OPERATE an 

electrical power generation station, pursuant to the above referenced permit 

application. This per.mit is subject to the conditions contained herein. 

The current federal Acid Rain Permit issued to AmerenEnergy Resources 

Generating Company by the Illinois EPA for this source is incorporated into 

this CAAPP permit (See Attachment 5). 

If you have any questions concerning this permit, please contact the Utility 

Unit at 217/782-2113 (217/782-9143 TTD). 

Donald E. Sutton, P.E. 

Manager, Permit Section 

Division of Air Pollution Control 

DES:MNP:jar 

cc: Illinois EPA, FOS, Region 2 

USEPA 

Exeept addresssd in Condition B./ of this per.mit. 

PRINTED ON RECYCLED PAPER 
Elsctronic Filing- Rscivsd, Clsrk's Offics: 08/16/2013 

7 .1. 4 Applicable Emission Standards 

a. The affected boilers shall comply with the standard in 

Condition 5.2.2(b) [35 IAC 212.123], which addresses 

the opacity of the emission of smoke or other 

particulate matter from the affected boilers. 

b. 

c. 

i. The emissions of PM from affected boiler 1 shall 

not exceed 0.20 lb/~~tu of actual heat input in 

any one hour period, pursuant to 35 IAC 212.203. 

This standard applies because the affected 

boiler qualifies for the alternative standard 

provided by this rule, as recognized by the 

Illinois Pollution Control Board in Regulatory 

Proceeding R82-l. In particular, in accordance 

with 35 IAC 212.203(a), as of April 14, 1972, 

this boiler had an hourly emission rate based on 

the stricter of the original design or equipment 

performance test conditions that was less than 

0.20 lb/mrnBtu of actual heat input, i.e., 0.15 

lb/mmBtu. Thereafter 1 under this rule, the 

emission rate is not allowed to degrade by more 

than 0.05 lb/rnrnBtu from the base emission rate, 

resulting in an emission standard of 0.20 

1b/nunBcu. 

ii. The emissions of P!.'-:1 from the affected boiler 2 

shall not exceed 0.15 lb/rnmBtu of actual heat 

input in any one hour period 1 pursuant to 35 IAC 

212.203 1 as also recognized by the Illinois 

Pollution Control Board in Regulatory Proceeding 

R82-1. As of April 14r 1972,, this boiler had an 

hourly emission rate of 0.10 lb/rnrnBtu. 

Thereafter, under this rule, the emission rate 

is not allo.,.1ed to degrade by more than 0. 0 5 

lb/mmBtu from the base emission rate, resulting 

in an emission standard of 0.15 lb/mmBtu. 

iii. The emissions of PN from affected boiler 3 shall 

not exceed 0.10 lb/mmBtu of actual heat input in 

any one hour period, pursuant to 35 IAC 212.202. 

i. The average SOz emissions from the affected 

boilers as a group shall not exceed 4.71 

lb/mmBtu of actual heat input, on a daily basis, 

pursuant to 35 IAC 214.561(a). 

The average 502 emissions from any one affected 

boiler may not exceed 6.6 pounds of so2 per 

mmBtu of actual heat input on a daily basis, 

pursuant to 35 IAC 214.561 (b). 

S02 emissions for all three affected boilers, as 

a group, may not exceed 34,613 pounds of so2 per 

hour, on a 24-hour average basis, pursuant to 35 

lAC 2l4.561(c). 

31 
tiBctronic riling- I~BcivBd, L;JBrk's Uttic8: U8/ll:i/LUI::J 

217/782-2113 

CLEAN AIR ACT PERMIT PROGRAM (CAAPP) PERMIT 

PERMITTEE 

Electric Energy, Inc. 

Attn: Manager, Technical Services 

2100 Portland Road 

Post Office Box 165 

Joppa, Illinois 62953 

Application No.: 95090120 I.D. No.: 127855AAC 

Applicant's Designation: JOPPA STEAM Date Received: September 8, 1995 

Operation of: Electric Power Plant 

Date Issued: September 29, 2005 Expiration Date 1 : September 29, 2010 

Source Location: 2100 Portland Road, Joppa 1 Massac County 

Responsible Official: Terence H Larbes, Manager, Technical Services 

This permit is hereby granted to the above-designated Per.mittee to OPERATE 

the Electric Energy, Inc. Joppa Steam Electric Station, pursuant to the above 

referenced permit application. This permit is subject to the conditions 

contained herein. 

The current federal Acid Rain Permit issued to Joppa Steam by the Illinois 

EPA for this source is incorporated into this C~PP permit (Refer to 

Attachment 5) . 

If you have any questions concerning this permit, please contact the Utility 

Unit at 217/782-2113 (217/782-9143 TDD). 

Donald E. Sutton, P.E. 

Manager, Permit Section 

Division of Air Pollution Control 

DES :MNP: jar 

cc: Illinois EPA, FOS, Region 3 

US EPA 

Except as addressed in Condition 8.7 of this permit. 
Eh:!ctronic Filing- Recived, Clerk's Office: 08/1612013 

7 .1. 4 

v. This authorization does not relieve the 

Permittee from the continuing obligation to 

minimize excess emissions during malfunction 

or breakdown. As provided by 35 IAC 201.265, 

an authorization in a permit for continued 

operation with excess emissions during 

malfunction and breakdown does not shield the 

Permittee from enforcement for any such 

violation and only constitutes a prima facie 

defense to such an enforcement action provided 

that the Permittee has fully complied with all 

terms and conditions connected with such 

authorization. 

Applicable Emission Standards 

a. The emissions of PM from each affected boiler shall 

not exceed 0.19 lb/mmBtu of actual heat input in any 

one hour period, pursuant to 35 IAC 212.203. This 

standard applies because affected boilers qualify for 

the alternative standard provided by this rule, as 

recognized by the Illinois Pollution Control Board in 

Regulatory Proceeding RB2-1. In particular, in 

accordance with 35 IAC 212.203(a), as of April 14, 

1972, the affected boilers had,hourly emission rates 

based on the stricter of the original design or 

equipment performance test conditions that were less 

than 0.20 lb/roroBtu of actual heat input, i.e., 0.14 

lb/mmBtu. Thereafter, under this rule, the emission 

rates are not allowed to degrade by more than 0.05 

lb/rnmBtu from the base emission rate, resulting in an 

emission standard of 0.19 lb/rnmBtu. 

b. The total emissions of 802 from the affected boilers 

shall not exceed 36,865 lb/hour, pursuant to 35 IAC 

214.182 and 214.184. These are the 802 emissions 

allowed by the following formula in 35 IAC 214.184, 

as selected by the Permittee, which when applied to 

the boilers at the source results in a total 

allowable S02 emission rate of 36 1 865 lb/hr: 

E ~ 0.2222H2 

Where: 

E Total emissions o.f S02, in pounds per hour, 

from all fuel combustion emission units owned 

or operated by such person and lOcated within 

1 mile from the center point of any such 

unit*; 

H and 

30 
tlsctronic riling- I~BCiVBd, [;lsrk's UtticB: U~/ll:i/LUI~ 

f'/...e_c.eiVt::t{ /0-'f-ZODb :SC.W 

File. : A~ a.J.t3. 2. 

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY 

1 021 NoRTH GR.-.ND Av<NUE EAST, P.O. Box 19506, SPRINGfiELD, ILLINOIS 62794·9506 - 1 217) 782-2113 

Roo R. 8LAGOJEVICH, GovERNOR DOUGLAS P. ScOTT, DIRECTOR 

2171782-2113 

CLEAN AIR ACT PEru{IT PROGRAM (CAAPP) PERMIT 

PERMITTEE 

Ameren Energy Generating Company 

Attn: Michael L. Menne 

1901 Chouteau Avenue 

St. Louis, Missouri 63103 

This permit is hereby granted to the above-designated Permittee to OPERATE an 

electrical power generation station, pursuant to the above referenced permit 

application. This permit is subject to the conditions contained herein. 

The current federal Acid Rain Permit issued to Ameren Energy Generating 

company by the Illinois EPA for this source is incorporated into this CAAPP 

permit (See Attachment 5) . 

If you have any questions concerning this permit, please contact the Utility 

Unit at 217/782-2113 (217/762-9143 TDD). 

Donald E. Sutton, P.E. 

Manager, Permit Section 

Division of Air Pollution Control 

DES:HNP:jar 

cc: Illinois EPA 1 FOS 1 Region 3 

USEPA 

Except as addressed in Condition 8.7 of this permit. 

PRINTED ON RECYClED PAPER 

·( 

' 
EIBctronic Filing - RBcivBd, CIBrk's OfficB: 08/1612013 

7.0 UNIT SPECIFIC CONDITIONS 

7.1 Coal Fired Boilers- Subject to NSPS, 40 CFR 60 Subpart D 

7 .1.1 

7 .1. 2 

Description 

The Permittee operates two coal-fired boilers for electric 

generation. The boilers are currently operated for base 

load generation, normally operating for weeks at a time 

between startups. The boilers, which were built in 1972 

and 1975, have nominal capacities of 5,500 mmBtu/hour each 

and served by separate stacks. These boilers also have 

the capability to fire at various modes such as 

combination of coal and fuel oil as their principal fuel. 

In addition to coal 1 these boilers fire fuel oil as 

auxiliary fuel during startup and for flame stabilization. 

Periodically small amounts of used oil or boiler cleaning 

residue are fired with the.coal in these boilers. 

Nitrogen oxide (NOx) emissions from the boilers are 

controlled by low-NOx burners and overfire air systems. 

In addition, boiler·2 is equipped with a duct burner for 

the primary air supply to facilitate control of NOx. 

Particulate matter {PM) emissions are controlled by 

electrostatic precipitators (ESP) equipped ~...-ith Flue Gas 

Conditioning (FGC) systems. The FGC systems are operated 

on an as needed basis. 

List of Emission Units and Air Pollution Control Equipment 

These unit-specific conditions address the following 

emission units: 

Boiler Descriotion Control Eauipment 

Boiler 1 Coal-fired Boiler Low NOx Burners with Overfire 

7.1.3 

NB-1 Nominal 5,500 Air, and ESP with FGC 

mmBtu/hr 

Boiler 2 Coal-fired Boiler Primary Air Duct Burners, 

NB-2 Nominal 5,500 NOx Burners with Over fire 

mmBtu/hr and ESP with FGC 

Applicability Provisions 

a, i. An ''affected boiler" for the purpose of these 

unit-specific conditions is a boiler described 

in Conditions 7.1.1 and 7.1.2. 

ii. The affected boilers are also ''affected 

facilities" for purposes of the NeH Source 

Performance Standards (NSPS) for Fossil-Fuel 

Fired Steam Generators for Nhich Construction 

Is Commenced After August 17, 1971, pursuant 

to 40 CFR 60.40. As affected facilities, the 

boilers are also subject to applicable 

requirements of the NSPS, 40 CFR 60 Subpart D 

and related requirements in the NSPS, 40 CFR 

60 Subpart A, General Provisions. 

27 

Lm<~ 

Air, 
electronic riling- l~ecived, L:lerk's Uttice: U8/ll:i/LUI~ 

7 .1. 4 

v. This authorization does not relieve the Permittee 

from the continuing obligation to minimize excess 

emissions during malfunction or breakdown. As 

provided by 35 IAC 201.265 1 an authori~ation in a 

permit for continued operation with excess 

emissions during malfunction and breakdown does 

not shield the Permittee frorn enforcement for any 

such violation and only constitutes a prima facie 

defense to such an enforcement action provided 

that the Permittee has fully co~plied with all 

terms and conditions connected with such 

authorization. 

Applicable Emission Standards 

a. Federal NSPS standards 

i. The affected boilers are subject to New source 

Performance Standards (NSPS) for Fossil Fuel Fired 

Steam Generators, 40 CFR 60, Subparts A and D. 

ii. Pursuant to the NSPS, emissions from each 

affected boiler shall not exceed the following 

emission standards: 

Standard 

Pollutant {lb/rnmBtu) ~ 

PM 0.10 40 CFR 60.42{a) {1) 

1.20 40 CFR 60.43 {a) {2) 

NOx 0.70 40 CFR 60.44{a) {3) 

iii. Opacity from each affected boiler shall not 

exceed 20 percent, as measured on a six minute 

average, except for one 6 minute period per 

hour of not more than 27 percent pursuant to 

NSPS, 40 CFR 60.42 {a) {2) . 

iv. Pursuant to 40 CFR 60.8{c) and 60.ll{c), the 

above emission limitations do not apply during 

star.tup, malfunction, and shutdown, as defined 

by 40 CFR 60.2. Notwithstanding this 

provision, pursuant to 40 C~R 60. 7{b) and (c), 

exceedances of these limitations during 

startup, malfunction, and shutdown are still 

subject to recordkeeping and reporting 

requirements under the NSPS. 

b. The emissions of PM from each affected boiler shall 

not exceed 0.10 lb/mmBtu of actual heat input in any 

one hour period, pursuant to 35 !AC 212.204. 

c. The emissions of S02 from each affected boiler shall 

no·t exceed 1.2 lb/rrunBtu of actual heat input, pursuant 

to :l5 IAC 214.121 {a I . 

30 
Electronic Filing- Recived, Clerk's Office: 08/1612013 

b. L 

.i.i . 

Th~ uuly .Cut~l;:; fl.n~u ln Lhe p.d.maxy air ctu:.-:t 

burners of affected boiler 2 shall be natural 

gds and di.:sti~lct.e fuel oil. !'!'1] 

A. 

a. 

rrbe fuel tlsage of the primnry o!l.i:t" clue t 

burners of affected boiler 2 shall not 

exceed 250 gallon.s/houl-, total~ [Tl] 

T.he t<Otel. anr..ue.l £ue:l cort5umpt.ion by 

primary air ctuct !:mxners o£ af·tected sh£J.11~ not exceed 1, GlOr 000 SJ!l.llon:r. 

the 

boiler 2 

[Tl] 

C. Fo.r thi:!i purpoee1 i£ ne.tural gc.3 i8 

burned, l1 000 stan-dard cubic feet of gas 

.shall be conside:-ecl equivalent to 7. 45 

gallons of o.il. rn; 

iii. 'l'he emissions of the primary air duct burners 

of affec:ted boile1.· 2 shall r.tot exc-'l:ad thG 

:follow-ing linli .. tations~ [TlJ 

Pcllt:rtant 

NOx 

co 

so2 

PM 

Li.mi tation 

LbiPJ.· (Each) 'l'on/Y.ear (Totel} 

5.0 16.1 

1.25 4 .o 

51.94 32.0 

0.5 1.6 

i v. Cornp.li.ance wit-h annual L:Lmi tat.ions shall be 

determined on a rncnt:hly basis £rom th~ Stlrn of the 

data for the current month plus the preceding 11 

months {running 12 .month total) . {11"1) 

Not:.e: ThB above requirentents \Vere established in 

Permit 01030065. 

7 .1. 7 Testing Requirements 

Pursuant to Section 39. 5 { 7 J (d~ ( ii) of the Act~ the 

Permittee shall have the PM end CO emissions of each 

affected boile.r measurGd as specified below: 

a. ?1-1 emission measurements ezhall .be made no 

later thar1 one vea:r. aftee the. effective date 

of thi~ condition. (Measurements made after 

December 31, 2003 may satisfy this 

requirement . ) 

ii. PM emission me-asurements shall be made within 

90 days of operating an affected boiler for more than 30 hours total in a calendar qua:r:ter 

at a loa.dW tha:t is more than 2 percent higher 

than the greatest load on the boiler, durirJg 

th~ most recent set of Pl'-1 tests on the 

affected boiler in w-hich compliance is shown 

(refer to Condition 7.1.7(e) [iii) (D)), 

provided, however, that the Illinois ZPA may 

35 
\ 

tiBctronic riling- I~BCiVBd, l.;IBrk's UtticB: U~/ll:i/LUI::J 

... 

JLUNOJS ENVIRONMENTAL PROTECTION AGENCY 

1 021 NORTH GRANO AVENUE EAST. P .0. BOX 19506, SPRINGFIELD, IU.INOJS 62794-9506 • (217) 782·2113 

PAT QUrNN, GOVERNOR JOHN J, KIM, INTERIM 0\lli:.ctOR 

217/782-2113 

CLEAN AIR ACT PSRMIT ?ROGRAM (CAAPP) PERMIT* 

PERI1ITTEE 

Ameren Energy Generating Company 

Attn: Michael L, Menne 

1901 Chouteau Avenue 

St. Louis, t.Ussouri 63101 

Application No.: 95090009 I.D. No,i l35803~AA 

Applicant's Designation: Date Received: September 01, 1995 

Operation of: Electrical Pm.,rer Generation at Coffeen 

Date Issued: September 29, 2005 

Effective Date: September 20, 2012 

Source Location: 134 C!PS Lane, Coffeen, 

Responsible Official: James L. Yiilliams, 

Expiration Date 1 : September 20, 2017 

Montgomery County 

Jr. 1 Manager, Coffeen Power Station 

This permit is hereby granted to the above-designated Permittee to OPERATE an 

electrical power generation station, pursuant to the above referenced permit 

application. This permit is s~bject to the conditions contained herein. 

The current federal Acid Rain Permit issued to Ameren Energy Generating 

Company by the Illinois EPA for this ~ource is incorporated into this CAAPP 

permit (See Attachment 5). 

rf you have any questions concerning this pe~rnit~ please contact the Utility 

Unit at 217/782-2113 (217/782-9143 TD~ 

£_~ (!,pkJ;) 'f;;fl-~\{V Edwin C. Bakowski, P.E. 

Managerr Permit Section 

Division of Air Pollution Control 

E'.CB: MNP: psj 

cct Illinois EPA, FOSf Region 2 

US EPA 

q'(:-' 

Except as addressed in Condition 8.7 of this pe~mlt 

By order of the Pollution Control Board in the matter of Ameren Energy Generating co. v. If:PA, PCB No. 06-64, the administrative SCdY of this issued CAAPP permit 1{.3$ partially 

Hfted on September 20, 2012~ ellow.:tng the uncontested conditions of the appealed perro1t eo Oscome final and effective. As d consequence ot: the Boards order~ tfJe effective c.nd 

er.piration dAtes of the permit are set forth dbova to correspond with the full term of 

the pe.rnd t 's duration, 

PRINTE.O ON REC\'GLED PAPER 
Electronic Filing -Recived, Clerk's Office: 08/16/2013 

malfunction and breakdown does not shield the 

~ermittee from enforcement for any such 

violation and only constitutes a prima facie 

defense to such an enforcement action provided 

that the Permittee has fully complied with all 

terms and conditions connected with such 

authorization. 

7. 1. 4 Applicable Emission Standards 

a, The affected boilers shall comply with the standard 

in Condition 5.2.2(b) [35 IAC 212.123], which 

addresses the opacity of the emission of smoke or 

other particulate matter from the affected boilers. 

b. i 0 The emissions of PM from the affected boiler 1 

(CBl) shall not exceed 0.19 lb/mmBtu of actual 

heat input in any one hour period, pursuant to 

35 IAC 212.203. This standard applies because 

the affected boiler qualifies for the 

alternative standard provided by tHis rule, as 

recognized by the Illinois Pollution Control 

Board in Regulatory Proceeding RB2-1. In 

particular, in accordance with 35 IAC 

212.203(a), as of April 14, 1972, the affected 

boilers had an hourly emission rate based on 

the stricter of the original design or 

equipment performance test conditions that was 

less than 0.20 lb/mmBtu of actual heat input, 

i.e., 0.14 lb/mmBtu. Thereafter, under this 

rule, the emission rate is not allowed to 

degrade by more than 0.05 lb/mmBtu from the 

base emission rate, resulting in an emission 

standard of 0.19 lb/mmBtu. 

ii. The emissions of PM from the affected boiler 

CB2 shall not e~ceed 0.15 lb/mmBtu of actual 

heat input in any one hour period, pursuant to 

35 IAC 212.203. This standard applies because 

the affected boiler qualifies for the 

alternative standard provided by this ruLe, as 

recognized by the Illinois Pollution Control 

Board in Regulatory Proceeding RB2-l, In 

particular, in accordance With 35 IAC 

2l2.203(a), as of April 14 1 1972, the affected 

boiler had an hourly emission rate based on 

the stricter of the original desi9n or 

equipment performance test conditions that was 

less than 0.20 lb/mmBtu of actual heat input, 

i.e. 1 0.10 lb/mmBtu. Thereafter, under this 

rule, the emission rate is not allowed to 

degrade by more than 0.05 lb/mmBtu from the 

base emission rate, resulting in an emission 

standard of 0,15 lb/mrnntu. 

32 
tlectronic riling- l~ecived, ~lerk's Uttice: U~/ll:i/LUI~ 

c. The total emission of 502 from the affected boilets 

combined shall not exceed 55,555 lb/hour, pursuant to 

35 IAC 214.143, 214.182, and 214.184. These are the 

SOz emissions allowed by the following formula in 35 

IAC 214.184, as selected by the Permittee: 

E 0.2222 H' 

Where; 

E = Total emissions of 8021 in pounds per hour, 

from all fuel combustion emission units owned 

or operated by such person and located within 

1 mile from the center point of any such unit. 

?ercentage of total emissions E 

emission unit i divided by 100. 

P, + • • . + P, ~ l) 

emitted from 

(Note; P1 + 

H1 Height in feet above grade of stack i. {Note; 

The height used may not exceed the good 

engineering practice [GE?] height for such 

stack. The actual height of the stacks for 

the affected boilers is 500 ft, but the GEP 

height is 213 ft.) 

d. The emissions of CO from each affected boiler shall 

not to exceed 200 ·ppm, corrected to 50 percent excess 

air, pursuant to 35 IAC 216.121. 

e. The affected boilers are subject a NO~<. emission 

standard pursuant to Section 407 of the Clean Air Act 

and 40 CFR Part 76, as addressed in Condition 6.2.2 

and Attachment 5 of this permit. 

f. The affected boilers are each subject to the 

following requirements related to NOM emissions 

pursuant to 35 !AC Part 217 Subpart V: 

i. During each ozone control period (May 1 

through September 30): 

A, The emissions of NOx from an affected 

boiler shall not exceed 0.25 lb/mrnBtu oE 

actual heat input based on a ozone 

control period average for that unit, 

~ursuant to 35 I~C 217.706(a), or 

S. If the Permittee elects to participate in 

a NOx averaging plan, the emissions of NOx 

from the affected boiler and other 

33 
Electronic Filing- Recived. Clerk's Office: DB/1612013 

Rece1ve.!.. 10-4 -2.t:>OS SCu.. 

F,'k: AG. ,3,f, IS: /.I 

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY 

1021 NORTH GRANO AVENUE fMT, P.O. 60X 1950&, SPRINGfiELD, ILLINOIS 62794-950& -I 217) 782-2113 

Roo R. BlAGOJEVICH, GOVERNOR DOUGLAS P. Scan, DIRECTOR 

217/7 82-2113 

CLEAN AIR ACT PERMIT PROGRAM (CAAPP) PERMIT 

PERMITTEE 

AmerenEnergy Resources Generating Company 

Attn: Michael L. Menne 

1901 Chouteau Avenue 

St. Louis, Illinois 53103 

Application No.: 95070025 I.D. No.: 057801AAA 

Applicant 1 s Designation: Date Received: July 10, 1995 

Operation of: Electrical Power Generation at Duck creek Plant 

Date Issued: September 29, 2005 Expiration Date': September 29, 2010 

Source Location: 1?751 North Cilco Road, Canton, Fulton County 

Respons~ble Official: James L. Luckey !II, Manager~ Duck creek Power Station 

This permit is hereby granted to the above-designated Permittee to OPERATE an 

electrical power generation station, pursuant to the above referenced permit 

application. This permit is subject to the conditions contained herein¥ 

The current federal Acid Rain Permit issued to AmerenEnergy Resources 

Generating Company by the Illinois EPA for this source is incorporated into 

this CAAPP permit (See Attachment 5) , 

If you have any questions concerning this per.mit, please contact the Utility 

Unit at 217/782-2113 (217/782-9143 TTD). 

Donald E. Sutton, P.E. Manager~ Permit Section 

Division of Air Pollution Control 

DES:MNP:jar 

cc: Illinois EPA, FOS, Region 2 

US EPA 

Except as nddreBsed in condition 8.7 of this permit. 

PRINTm ON RECYCLED PN'ER 
tiBctronic ~iling- I<BcivBd, [.;IBrk's UtticB: U1::1/lti/LUJ::J 

7.0 UNIT SPECIFIC CONDITIONS 

7,1 Coal Fired Boiler- Subject to NSPS, 40 CFR 60, Subpart D 

7 .1.1 

7' 1.2 

7 .1. 3 

Description 

The Permittee operates a coal-fired boiler for electric 

generation. The boiler is currently operated for base 

load generation, normally operating for weeks at a time 

between startups. The boiler, which was built in 1976, 

has a nominal capacity of 3713 mmBtu/hour. This boiler 

also has the capability to fire at various modes such as 

combination of coal 1 petroleum coke, and fuel oil as its 

principal fuel. In addition to coal, the boiler fires 

fuel oil as an auxiliary fuel during startup and for 

flame stabilization. Periodically small amounts of used 

oil or boiler cleaning residue are fired with the coal in 

this boiler. 

Nitrogen oxide (NOx) emissions from the boiler are 

controlled by low-NOx burners and a selective catalytic 

reduction (SCR) system. Particulate matter (PM} 

emissions are controlled by an electrostatic precipitator 

(ESP) . Sulfur dioxide (502 ) emissions are controlled by 

a flue gas desulfurization (FGD) scrubber system. The 

Permittee currently plans to operate the SCR and FGD on 

an as needed basis to comply with applicable NOx and S02 

emission standards. 

List of Emission Units and Air Pollution Control Equipment 

Emission 

Unit Description Control 

I.D. Equipment 

Boiler B-1 Riley Stoker Boiler LNB, SCR, ESP 

Nom. 3, 713 mmBtu/hr (1976) and FGD 

Applicability Provisions 

a. i. The "affected boiler'' for the purpose of these unitspecific conditions is the boiler described in 

Conditions 7 .l.l. and 7 .1. 2, 

ii. The affected boiler is also an ''affected facility" 

for purposes of the New Source Performance Standards 

(NSPS) for Fossil-Fuel Fired Steam Generators for 

Which c·ons truction Is Commenced After August 17 I 

1971, pursuant to 40 CFR 60,40. As an affected 

facility, the boile~ is subject to applicable 

re"qulrements of the NSPS, 40 CFR 60 Subpart D and 

related requirements in the NSPS, 40 CFR 60 Subpart 

A, General Provisions. 

b. Startup Provisions 

Subject to the following terms and conditions, the 

Permittee is authorized to operate the affected boiler in 

violation of the applicable standards in Condition 

27 
EIBctronic Filing- RBcivBd. CIBrk's OfficE!: 09/16/2013 

7 .1. 4 Applicable Emission Standards 

a. Federal emission standards 

i. The affected boiler is subject to the New Source 

Performance Standards (NSPS) for Fossil ~uel Fired 

Steam Generators, 40 CFR 60 D. 

ii. Pursuant to the NSPS, emissions from the affected 

boiler shall not exceed the following emission 

standards: 

Standard 

Pollutant (lbs/mmBtu) Rule 

PM 0.10 40 CFR 60.42(a) (11 

so, 1.2 40 CFR 60.43(a) (2) 

NOx 0.70 40 CFR 60.44 (a) (3) 

iii. Opacity from the affected boiler shall not exceed 20 

percent, as measured on a six minute average, except 

for one 6 minute period per hour of not more than 27 

percent pursuant to the NSPS, 40 CFR 60.42 (a) (2). 

iv. A. Pursuant to 40 CFR 60.8(c) and 60.11(c), the 

above emission limitations do not apply during 

startup1 malfunction1 and shutdown, as defined 

by 40 CFR 60.2. Notwithstanding this 

provision, pursuant to 40 CFR 60.7(b} and (c), 

exceedances of these limitations during 

startup, malfunction 1 and shutdown are still 

subject to recordkeeping and reporting 

requirements under the NSPS. 

B. At all times, the Permittee shall maintain and 

operate the affected boiler, including 

associated air pollution control equipment 1 in 

a manner consistent with good air pollution 

control practice for. minimizing emissions, as 

required pursuant to the NSPS, 40 CFR 

60.1l(d). 

b. The emissions of PM from the affected boiler shall not 

exceed 0.10 lb/rrunBtu of actual heat input tn any one hour 

period, pursuant to 35 IAC 212.204. 

c. The emissions ·of S02 from the affected hailer shall not 

exceed 1.2 lb/mmBtu of actual heat input in any one hour 

period, pursuant to 35 IAC 214.121(a). 

d. The emissions of CO from the affected boiler shall not 

exceed 200 ppm, corrected to 50 percent excess air, 

pursuant to 35 IAC 216.121. 

3D 
electronic riling- l~ecived, ~Jerk's Uttice: W:l/ll:i/LUI~ 

ATTACHMENT D 
Elsctronic Filing- Rscivsd. Clsrk's OfficB: 08/1612013 

CERTIFICATE OF ACCEPTANCE AND NOTICE OF CLOSING 

On , Ameren Corporation and Tilinois Power Holdings, LLC 

closed the transaction referenced in the Order of the illinois Pollution Control Board dated 

I (We), , having read the opinion and order 

of the Illinois Pollution Control Board in docket PCB 14-10, dated ' understand and accept the opinion and order, realizing that this acceptance renders all terms and 

conditions of the variance set forth in that order binding and enforceable. 

ILLINOIS POWER HOLDINGS, LLC 

By: 

Authorized Agent 

Title: 

Date: 

MEDINA VALLEY COGEN, LLC 

By: 

Authorized Agent 

Title: -

Date