UNITED STATES ENVIRONMENTALPROTECTION AGENCY REGION 4 ATLANTAFEDERALCENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960 

## JUN 2 9 

### 2004

Honorable Ernie Fletcher Governor of Kentucky State Capitol 700 Capitol Avenue Frankfort, KY 40601 Dear Governor Fletcher: Fine-particle pollution represents one of the most significantbarriers to clean air facing our nation today. These tiny particles - about l/30th the diameter of a human hair -have been scientifically linked to serious human health problems. Their ability to be suspended in air for long periods of time makes them a public health threat far beyond the source of emissions. An important part of our nation's commitment to clean, healthy air deals with reducing levels ofthis fineparticle or PM2.5 pollution. In February, your State submitted its recommended boundaries for PM2.5 attainment and nonattainment areas. We have thoroughly reviewed your recommendations and the technical information you have submitted to support your recommendations. We appreciate the effort your State has made to develop this supporting information. Consistent with the Clean Air Act, this letter is to notify you that based on the information contained in your submittal, EPA intends to make modifications to recommended designations and boundaries in your State. The detailed enclosure contains a description of areas where EPA intends to modify your State recommendations, and the basis for such modification. Should you have additional information that you wish to be consideredby EPA in this process, we request that you provide it to us by September 1. You will hear from us again in November when EPA takes the final step in the PM2.5 designation process and determines those areas that are in attainment and meet the fine particle standards and those areas that do not meet them. For areas in attainment, the challenge will be not only to maintain, but also to continue the progress you have made toward clean air. It is a commitment to no backsliding in your State's clean air status for fine particles. EPA will also issue a proposed fine particle implementation rule prior to final designations, which will allow you to proceed with planning to achieve clean air. The Bush Administration is addressing fine particle pollution with a comprehensive national clean air strategy. This strategy includes EPA's recent rule to reduce pollution from nonroad diesel engines, and the proposed rule to reduce pollution from power plants in the

Internet Address (URL) http://www.epa.gov Recycled/Recyclable Plintedwith Vegetable Oil Based Inkson RecydedPaper (Minimum30% Postconsumer)eastern U.S. These two rules are important components ofEPA's efforts to help States and localities meet the more protective national fine-particle and 8-hour ozone air quality standards. Together these rules will help all areas of the country achieve cleaner air. Should you or your staff have any questions, I invite you to contact Beverly 

### H. Banister, Director, Air Pesticides and Toxics Management Division, at 4041562-9077, or Kay T. Prince, Chief, Air Planning Branch, at 4041562-9026. We look forward to a continued dialogue with you as we work together to implement the PM2.5 standards. Sincerely, 

# s4

.I. Palmer, Jr. Regional Administrator Enclosure

cc: LaJuana Wilcher, KYDEP John Lyons, KYDEP Art Williams, Jefferson CountyUNITED STATES ENVIRONMENTAL PROTECTIONAGENCY REGION 4 ATLANTAFEDERALCENTER 61 FORSYTH STREET ATLANTA, GEORGlA 30303-8960

LaJuana Wilcher, Secretary Environmental and Public

Protection Cabinet Capital Plaza Tower, 5IhFloor Frankfort, KY 4060 1 Dear Ms. Wilcher: Fine-particle pollution represents one of the most significant barriers to clean air facing our nation today. These tiny particles -about 1 /30ththe diameter of a human hair -have been scientifically linked to serious human health problems. Their ability to be suspended in air for long periods of time makes them a public health threat far beyond the source of emissions. An important part of our nation's commitment to clean, healthy air deals with reducing levels ofthis fine particle or PM2.5 pollution. In February, your State submitted its recommended boundaries for PM2.5 attainment and nonattainment areas. We have thoroughly reviewed your recommendations and the technical information you have submitted to support your recommendations. We appreciate the effort your State has made to develop this supporting information. Consistent with the Clean Air Act, this letter is to notify you that based on the information contained in your submittal, EPA intends to make modifications to recommended designations and boundaries in your State. Your Governor was sent a letter today notifying him that EPA is modifying the State's recommendation. This letter contains a more detailed enclosure containing a description of areas where EPA intends to modify your Staterecommendations, and the basis for such modification. Shouldyou have additional information that you wish to be considered by EPA in this process, we request that you provide it to us by September 1,2004. You will hear from us again in November when EPA takes the final step in the PM2.5 designation process and determines those areas that are in attainment and meet the fine particle standards and those areas that do not meet them. For areas in attainment, the challenge will be not only to maintain, but also to continue the progress you have made toward clean air. It is a commitment to no backsliding in your State's clean air status for fine particles. EPA will also issue a proposed fine particle implementation rule prior to final designations, which will allow you to proceed with planning to achieve clean air. The Bush Administration is addressing fine particle pollution with a comprehensive national clean air strategy. This strategy includes EPA's recent rule to reduce pollution from

Internet Address (URL) http://www.epa.gov RecycledlRecyclable Printedwith Vegetable Oil Based Inks on Recyded Paper (Mlnimum 30% Postconsumer)nonroad diesel engines, and the proposed rule to reduce pollution from power plants inthe eastern U.S. These two rules are important components of EPA's efforts to help States and localities meet the more protective national fine-particle and 8-hour ozone air quality standards. Together these rules will help all areas ofthe country achieve cleaner air. Should you or your staffhave any questions, 

### I inviteyou to contact Beverly 

### H. Banister, Director, Air, Pesticides and ToxicsManagement Division, at 4041562-9077, or Kay T. Prince, Chief, Air Planning Branch, at 4041.562-9026. We look forward to a continued dialogue with you as we work together to implement the PM2.5 standards. Sincerely,

Regional Administrator Enclosure cc: John Lyons, KYDEP Art Williams, Jefferson County

### Enclosure for 120 Day Letter Justification for Modification to State Recommendations PM2.5 

### Nonattainment Areas Commonwealth of Kentucky An Explanation ofEPA9s 9-Factor Analysis: Factor 1.

### Emissions in areas potentiallyincluded versus excluded from the nonattainment area: The analysis forfactor 

### I looks at emissions of carbonaceous particles ("'carbon'?, inorganic particles ("crustal

### '7, SO2 , 

### andNOx. EPA computed a composite emission score for each county by multiplying the county's emissions as a fraction ofthe metropolitan area emissions for each ofthese pollutants times a corresponding air quality weighting factor. The air quality weighting factors for each area are given below and reflect the percentages ofthe total estimated "urban excess" value found as, respectively, carbonaceous particles, miscellaneous inorganic particles ("'crustal material1% ammonium sulfate, and ammonium nitrate. These scores add to 100 for the metropolitan area counties. Composite scores were also calculated for counties adjacent to the metropolitan area. Tables presented under factor 

### Ipresent the emissions of carbonaceous particles, inorganic particles, SO2 ,

### andNOx and the composite emission scores for the counties in the corresponding metropolitan area and adjacent counties. Metropolitan area counties are inbold. Emissions data indicate thepotentialfor a county to contribute to observed violations, ojenmaking the emissions data the most important factor inassessing boundaries of nonattainment areas. "Urban excess" values are derived by comparing urban monitored component concentrations against rural monitored component concentrations. Concentrations of the four PM2.5 components are obtainedfrom local data if

### available (or, ifnecessary, from the nearest available urban site), and are comparedto available rural

concentrations. The monitoring sites used for thispurpose are identified below. Although this information is air quality information, it ispresented underFactor 1 due to its integration into the analysis of emissions information. Factor 2. Air quality in potentiallyincluded versus excluded areas: The air quality analysis looks at the annual averaged design value for each area based on data for 2001 to2003. Factor 3.

### Population density and degree of urbanization including commercial development in included versus excluded areas: Tables presented under factor 3 show the 2003population for each metropolitan area, as well as thepopulation density for each county in that area. Population data indicate the likelihood ofpopulation-based emissions that might contribute to violations.

### Factor 4. 

### Traffic and commuting patterns: 

### The traffic and commuting analysis looks at the number ofcommuters in each county who drive toanother county within the metropolitan area ("Number"),the percent of total commuters in each county who commute toother counties within the metropolitan area ((percent 

## '7

## *, as well as the total Vehicle Miles Traveled(VMT) 

### for each county in thousands ofmiles. A 

### county with numerous commuters isgenerally an integralpart of the area, and would be an appropriate part ofthe domain ofsome mobile source strategies, thus warranting inclusion in the nonattainment area. *Note that thepercent ofcommuters traveling to counties within the metropolitan area is basedon the total numberofcommutersfrom that county. This total includes commuters who may travel outside the metropolitan area from their county oforigin. Factor 

### 5.Expected growth: 

### The expected growth analysis looks at the percent growth for counties in each metropolitan area from 1990 to 2000. Factor 6. Meteorology: 

### The meteorology analysis looks at wind data gathered over a tenyearperiod by the National WeatherService. Tables presented under factor 6 

### list theyear round average prevailing wind directions by quadrant for each county inthe corresponding metropolitan area. Thesedata show that annual average PM2.5 concentrations are influenced by emissions in any direction at various times, but these data may also suggesi that emissions insome directions relative to the violationmay be moreprone to contribute thanemissions in other directions. 

# actor 7.Geographyltopography: 

### Thegeographyhopography analysis looks atphysicalfeatures ofthe land that might have an effect on the airshed, and therefore, the distribution ofparticulate matter over an area. The Commonwealth has no such features that significantly influencedEPA 's recommended nonattainment areas. Factor 

### 8.Jurisdictional boundaries: 

### Theanalysis ofjurisdictional boundaries looks at theplanning and organizational structure ofan area to determine ifthe implementationofcontrols inapotential nonattainment area can be carried out ina cohesive manner. Factor 9. 

### Level ofcontrol of emission sources: 

### The level ofcontrol analysis looks at what controls are currently implemented in each

### area.


### PM 2.5 Nine Factor Analysis for 

### Cincinnati-Hamilton 

### OH-MY-INMSA The MSA contains the Kentucky Counties of Boone, Campbell, Kenton, Grant, Pendleton, Gallatin; the Ohio Counties of Hamilton, Clermont, Butler, Warren, Brown; and the Indiana Counties of Dearborn and Ohio. The following counties are violating the PM2.5 standard: Hamilton County, Ohio; Butler County, Ohio; and Montgomery County, Ohio. In February 2004, Kentuckyrecommended that all Kentucky counties in the CincinnatiHamilton MSA be designated attainment for the PM2.5 standard. EPA is modifying Kentucky's recommendation to include Boone, Campbell and Kenton Counties in the Cincinnati-Hamilton nonattainment area. Boone County has significant emissions, relatively high population growth, and a large (>10,000tons per year S02)power plant located in the County. Campbell and Kenton Counties have significantVMT, significant numbers of commuters into violating Hamilton County, and both counties part of the Cincinnati 1 

### -hour ozone nonattainment area due to violating monitors. Kenton County also has monitoring data close to the standard. EPA agrees that the remaining KY MSA counties of Gallatin, Grant, and Pendleton shouldbe designated as attainment/unclassifiabledue to low emissions, very low population relative to the area, and very low numbers of commuters into the violating counties. EPA agrees that the adjacent counties ofCarroll and Mason shouldbe designated attainment/classifiablefor the PM2.5 standard, althoughthey have significant emissions due to power plants. These counties have relatively low populations, low population growth, and low VMT


### . Further, their commuting patterns and distance from the violating monitors indicate that these counties do not contributeto the violations in the area. The other adjacent counties do not contribute and therefore, will be designated as attainmenthnclassifiable.

Factor 1: 

### Emissions in areas potentially included versus excluded from the Area Cincinnati-Hamilton, OH-KY-IN

The following is a brief summary of the nine criteria for the Cincinnati-Hamilton,OHKY-IN area. These analyses were based on existing available data. EPA Recommendation Full counties: Boone County Campbell County Kenton County State Recommendation Full counties: 

### none

### nonattainment area The following table has the 2001 PM2.5, SOX, NOx, VOC, and ammonia emissions in tons and weighted emissions scores for the counties in the Cincinnati-HamiltonMSA and surrounding counties. (MSA counties are in bold; Kentucky MSA counties in bold 

### italics.) 

### County Amrn 

# I Score 

# I Cum. Score 

# *

I 

### Hamilton, OH 

# 1 7,601 I 

### Clermont, OH 

## ) 6,443 

# TGG&FpK

Butler, OH 3,153 

### Boone,KY 

# 1 1,946 Warren, OH 

# 1 1,844 

### Kenfon,KY 

# 1 741 I 

### Campbell,KY 

# 1 590 I 

### Brown, OH 

# 1 748 I 

### Grant, 

### KY 

# 1 381 

### Pendleton,KY 

# 1 363

Gallatin,KY 367

Montgomery, 

## 12.542

Carroll, KY 

# 1 3,547 Mason, KY 

# 1 2,3 16 Greene, OH 

# 1 1,516 Preble, OH 

# 1 963 Ripley, 

### IN 

# 1 743
310 NIA I 

### Scott, KY 

# 1 627 I 

### Fayette, OH 

# 1 883 Decatur, 

### IN 

# 1

X!: Clinton, OH

Rush, IN 

### 1,003I I I I I I I



### Based on the analysis for this factor for Kentucky only, Boone, Carroll, and Mason Countieshave significant emissions which could indicate a potential emissions contributionto the PM2.5 violations in the area. This factor is not significant for the remaining Kentucky counties listed in this table. Owen, KY 

# 1 236 Switzerland,IN



### Bracken,IN

Union, IN Robertson,KY

Factor 2: Air qualityin wotentiallv included versus excluded areas 57 

# 1 572 

# 1 566 

# 1 245 

### ( 1.1 

# 1 N/A

The following table contains the design value for the MSA and adjacent counties that contain PM2.5 monitors. Design values followedby "a" indicatethat the value is based on incomplete monitoring data. (MSA counties are in bold; Kentucky MSA counties in bold italics.) 

### 257 174 343 74



# I Hamilton, OH 

# I 17.8 

# I 25

### B

52 58 12

County 200 1 -2003 design value 

# I Kenton,KY 

# I 15.0 

# I 1,554

570 548 112

I 

# 1 Campbell,KY 

# I 14.5 

# I Butler, OH



### Montgomery, OH Greene, OH Preble, OH 13.5a 776 479 705 107

16.2



### Based on 

### an analysis of this factor for Kentucky only,the Campbell and Kenton County monitors are attaining. The Kenton County monitor reading of 15.0 indicates that there may be a potential emissions contributionfrom the County to the area. This factor is not significant for the remaining Kentucky counties. Factor 3: Population densitv and degree of urbanization including commercial development in included versus excluded areas 364 134 266

65 1 .O 

### 0.7 0.6 0.3 NIA N/A N/A N/A

### The following table has the populations for the counties in the Cincinnati-Hamilton MSA and some adjacent counties with violating monitors and those with significant emissions. The total MSA 2002 population is 2,009,679. (MSA counties are in bold; Kentucky MSA counties in bold italics.)



### County Hamilton, OH Clermont, OH

I I I



### Boone,KY 

# / 93,290 4.64 

# 1 379 

# ( Dearborn, 

### IN

Butler, OH 2002 Population 833,721 183,352 47,333 340,543

I I I 

### Percent of Population of MSA 41.49

9.12

Warren, OH 

# 1 175,133 I I I 

### 2002 Population Density 2,048 406 2.36 16.95
8.71 

# 1 438 Kenton, KY 

# 1 152,164 I I I 

### 155 729

7.57 

# 1 934 Campbell, KY 

# 1 88,604 I I I 

### 4.41 

# / 583 

### Brown, OH 

# 1 43,464 I I I



### Ohio, 

### IN 

# 1 5,804 

# I 0.29 

# 1 67 

# I 2.16 

# 1 88 Grant, KY 

# 1 23,620 1 I I



### Adams, OH 

# 1 27,804 

# I I 48 

# 1 1.18 

# I 91 Pendleton,KY 

# I 14,815



### Based on the analysis for this factor, the populations for the Kentucky counties are much smaller than those inthe Ohio Counties of Hamilton, Butler, and Montgomery. The Kentucky Counties of Boone, Kenton, and Campbell have population values of some significance ascompared to the much smaller MSA Kentucky Counties of Grant, Gallatin, and Pendleton. This factor isnot significant for the remaining Kentucky counties in this table. 0.74



### Montgomery, OH Carroll, KY Mason, KY

Factor 4: Traffic and commuting patterns 53



### Commuting Information 554,470 10,223 16,916 1,200 79 7 0

### Total number ofworkers in Boone County, KY: 44,507 Commuters in Boone County, KY who work in Boone County, KY: 23,589 (53%) Commuters from Boone County, KY to Hamilton County, OH: 8,35 1 (19%) Commuters fiom Boone County, KY to Butler County, OH: 641 (1%) Total number ofworkers in Kenton County, KY: 76,169 Commuters in Kenton County, KY who work in Kenton County, KY: 30,771 (40%) Commuters from Kenton County, KY to Boone County, KY: 17,053 (22%) Commuters from Kenton County, KY to Hamilton County, OH: 20,200 (27%) Commuters fiom Kenton County, KY to Butler County, OH: 908 (1%) Total number ofworkers in Campbell County, KY: 42,820 Commuters in Campbell County, KY who work in Campbell County, KY: 15,474 (36%) Commuters fiom Campbell County, KY to Boone County, KY: 4,062 (9%) Commuters from Campbell County, KY to Hamilton County, OH: 14,946 (35%) Commuters from Campbell County, KY to Butler County, OH: 652 (2%) Total number of workers in Gallatin County, KY: 3,589 Commuters in Gallatin County, KY who work in Gallatin County, KY: 1,317(37%) Commuters from Gallatin County, KY to Boone County, KY: 1,038 (29%) Commuters from Gallatin County, KY to Hamilton County, OH: 196 (5%) Total number ofworkers in Grant County, KY: 10,262 Commuters in Grant County, KY who work in Grant County, KY: 4,18 1 (41%) 

### Commuters from Grant County, KY to Boone County, KY: 2,852 (28%) Commuters fiom Grant County, KY to Hamilton County, OH: 716(7%) Total number ofworkers in Pendleton County, KY: 6,467 Commuters in Pendleton County, KY who work in Pendleton County, KY: 2,482 (38%) Commuters from Pendleton County, KY to Boone County, KY: 789 (12%) Commuters from Pendleton County, KY to Hamilton County, OH: 785 (12%) Commuters fiom Pendleton County, KY to Butler County, OH: 101 (2%)
Total number ofworkers in Carroll County, KY: 4,466 Commuters in Carroll County, KY who work in Carroll County, KY: 3,475 (78%) Commuters from Carroll County, KY to Boone County, KY: 54 (1%) Commuters from Carroll County, KY to Hamilton County, OH: 48 (1%) Total number of workers in Mason County, KY: 7,560 Commuters in Boone County, KYwho work in Boone County, KY: 5,978 (79%) Commuters from Mason County, KY to Hamilton County, OH: 95 (1%) 

### A notable number of commuters from Kenton and Campbell Counties commute into violating Hamilton County. Although these numbers are far less than the number of

### commuters in Hamilton County,in conjunction with VMT data analyzed below, they indicate some potential for contributing to the mobile source emissions in the area. Although 47% of Boone's 44,507 workers commute into other counties in the MSA, a relatively small number commute into the violating counties. In Carroll County, 78% of the 4,466 workers commute within the County. Similarly,in Mason County, 79% of the 7,560 workers commute within the County. Thus, onroad mobile source emissions from commuting patterns for Boone, Carroll, and Mason Countiesdo not appear to be contributingto violations in the area. This factor is not significant for the remaining Kentucky counties listed above. Vehicle Miles Traveled: The following table has the vehicle miles traveled (thousand miles) for the counties in the Cincinnati-HamiltonMSA and some adjacent counties with significant emissions. (MSA counties are in bold; Kentucky MSA counties in 

### bold italics.)
County 

### Hamilton, OH Clermont, OH

I



### Boone,KY 

# 1 842 2002 VMT (thousandmileslyear) 

### 8,420 1,649 Dearborn,IN

Butler, OH

I 

### Warren, OH 

# 1 1,354 607 2,610

I 

### Kenton,KY 

# 1 1,816 I 

### Campbell,KY 

# 1 1,097 I 

### Brown, OH 

# 1 417 I 

### Grant, 

### KY 

# 1 379

I 

### Ohio, IN 

# 1 56 

### Pendleton,KY

Gallatin,KY

I 

### Adams, OH 

# 1 283 

### 169 254

I 

### Montgomery, OH 

# 1 5,668 Carroll, KY Mason, KY 213 178Based on an analysis of this factor for Kentuckyonly, the VMT for Boone, Kenton, and Campbell Counties are in the relatively moderateto high range as compared to the counties listed above, with the exception of the the violating Ohio counties of Hamilton, Butler, and Montgomery. Boone, Kenton, and Campbell VMT data indicate some potential to contribute to the PM2.5 violations in the area. VMT values for Carroll and Mason are very low and do not indicate a potential contribution. This factor is not significant for the remaining Kentucky counties listed in this table. Factor 5: Expected growth The following table has the population and population growth figures for the CincinnatiHamilton MSA and some adjacent countieswith significant emissions. (MSA counties are in bold; Kentucky MSA counties in 

### bold italics.)



### County

Hamilton, OH I I I 

### 2002 Population 833,721 Clermont, OH 

# 1 183,352 Dearborn, 

### IN

Butler, OH 

### Boone,KY Warren, OH 

### Kenton,KY Campbell,KY

Brown, OH



### Grant,KY 27,790 

# 1 19



### Pendleton,KY

Gallatin, K Y growth (90-00) -20,925 47,333 340,543 

### 93,290 175,133 

### 152,164 88,604 43,464 

### 23,620

I I I %

### growth (90-00) -2



### 14,815 7,836 Ohio, 

### IN 

# 1 5,804 I I I 

### 7,274 41,328 

### 28,402 44,474

9,433 

### 4,750 7,319 6,647

308 

# 1 6 Adams, OH 

## 1 27,804 I I I

Mason, 

### KY 

# 1 16,916 

# 1 134 

# 1 1 

### 19 14 

### 49 39

7 

### 6 21 42 

### 2,354 2,477
1,959

## 1 8 Montgomery,OH 

# / 554,470 Carroll, KY 

# 1 10,223

While the Kentucky Counties of Boone, Grant, and Gallatinhave the highest population growth rates from 1990-2000 than all ofthe counties in the MSA, only Boone County's resulting population increase of 28,402, (third highest increasein the MSA), is significant enough to indicate a potential to contribute to violations in the area. The population 

### 20 46

-14,747

# 1 -3 863

# 1 9

### growth rates of Carroll and Mason Counties are relatively very low and thus, do not indicate a potential to contribute to the area's violations. This factor is not significant for the remaining Kentucky counties listed in this table.

The following meteorological information was provided by Kentucky for the MSA Kentucky Counties of Boone, Campbell, Kenton, Gallatin, Pendleton, and Grant. (The figurereferenced is a wind rose for April 1 -October 31

### for the 1988-1 992period that is provided in Kentucky's PM2.5 recommendations submittal.) Meteorological Information "Due to the close proximity of Cincinnati, Ohio, meteorological data from Cincinnatiwas used for this Kentucky area. Wind speedlwinddirection information shows that the majority ofthe time for the period 1988-1992, the wind in the


### ... County area came from the southwest and typically from 7- 10knots. (See figure 1 -A) The mean high temperature for July for the area from 1961 through 1990was 86" F, the mean low was 66" 

### F. The mean precipitation for the sameperiod was 3.8 inches." (Source: Kentucky 

### PM2.5 submittal) 

### Based on an analysisofthis factor, the information provided isnot sufficient to provide a compelling argument to exclude counties based on prevailing winds. This information was provided only for the summertime winds. Factor 7: Geographvltopogravhy Based on 

### an analysis of this factor,there are no significant topographical issues associated with this MSA. For the adjacent Carroll and Mason Counties in Kentucky with significant emissions,both counties are two countiesremoved from the nearest county with a violating monitor (Hamilton, Ohio), with attaining monitors inbetween in Kenton and Campbell Counties in Kentucky. Factor 8: Jurisdictional boundaries The followingMSA counties were designatednonattainrnent for the 8-hour ozone standard on April 15,2004:the Kentucky Counties ofBoone, Campbell, and Kenton;the Indiana County of Dearborn; and the Ohio Countiesof Hamilton, Clermont, Butler, Warren, Montgomery, Greene, Clinton. This factor did not play a significant role in the decision-making process. Factor 9: Level of control of emission sources The following informationwas provided by Kentucky for Boone, Campbell, Kenton, Grant, Gallatin and Pendleton Counties.

### "Pointsources located within..

.

### County are subject to PSD requirements, CTG RACT requirements,Maximum Achievable Control Technology (UACT) requirements for sources ofHazardousAir Pollutants, and New Source Performance Standards (NSPS). Any controls imposed as a result ofprevious nonattainment designationsare required to remain in

...

### County. " 

### For Boone County only: "Additionally, substantial

### NOx reductions have occurred during the lastyearfrom East Bend Power Plant which would further lower the contribution ofNOx emissi~ns from Boone County." 

### This factor did not play a significantrole inthe decision-making process.

### PM 2.5 Nine Factor Analysis for Louisville, KY-IN MSA 

### The LouisvilleMSA contains the Kentucky CountiesofJefferson, Bullitt, and Oldham; and the Indiana Counties ofFloyd, Clark, Harrison, and Scott. Jefferson County, Kentucky and Clark County,Indiana are violating the PM2.5 standard. The adjacent Kentucky County of Carroll has relatively high emissions for the area, however,it was evaluated as part ofthe Cincinnati area. In 

### February 2004, Kentucky recommended that Jefferson County be designated nonattainment and that Bullitt and Oldham Countiesbe designated attainment for the PM2.5 standard for the LouisvilleMSA. EPA agrees that the Kentucky MSA County of Oldharnbe designated attainmenthnclassifiable

### due to low emissions and relatively lowpopulation. EPA agrees that Jefferson County be designatednonattainment due to four violating monitors in the County and ismodifying Kentucky's recommendationto include Bullitt County in the Louisville nonattainment area due to a relatively high number of commuters into violating JeffersonCounty, a monitored PM2.5 value of 15.0that is very close to the standard, and relatively high population growth. EPA agrees that the adjacent counties should be designated as attainment/unclassifiable 

### due to low population growth, a low percentage of workers commuting intothe Louisville MSA, relatively low emissions, and large distance from the violating monitors in the area.

The followingis a brief summary ofthe nine criteria for the Louisville, KY area. These analyses were based on existing available data.

Area Louisville, KY



### Factor 1: Emissions in areas potentiallv included versus excluded from the nonattainment area EPA Recommendationfor KY Full counties: 

### Jefferson County Bullitt County

The following table has the 2001 PM2.5, SOX, NOx, VOC, and ammonia emissions in tons and weighted emissions scores for the counties in the LouisvilleMSA and surrounding counties. (MSA counties are in bold; 

### Kentucky MSA counties in bold italics.) State Recommendation Full counties: 

### Jefferson

### County 

### Jefferson,KY Floyd, IN Clark, IN Bullitt,

### KY Harrison, IN Oldham,KY

Scott, IN Carroll, KY Jefferson, IN 

### Hardin, KY Lawrence, IN

Jackson, 

### IN Nelson, KY Trimble, KY Breckinridge, KY Grayson, KY Meade, KY Shelby,KY Franklin, KY Jennings,

### IN

Hart, KY Washington, 

### IN 

### PM 

# I Sox 

# 1 NQx 

# I VQC 

### ( Arnm 

# I Score 

# 1 Cum. 

### Score 7,385 62,526 81,398 55,376 1,539 51.5 51.5

, 

### Taylor, KY 408 632 3,642 1,609 46

### 1 3.1 Crawford, 

### IN 319 536 3,842 1,237 192 2.9 Orange, 

### IN 475 86 2,017 2,599 313 2.9 Anderson, 335 443 1,535 2,648 164 2.5 KY

### Based on the analysis for this factor for Kentucky only, the Kentucky Counties of Jefferson and Carroll have significant emissions. Bullitt County has emissions with a potential to contribute to the PM2.5 violations in the area. This factor isnot significant for the remaining Kentucky counties listed in this table. 

### Factor 

### 2: Air quality in potentially included versus excluded areas

County 

### Jefferson,KY

I 

### Clark, 

### IN 16.2 

# 1 200 1-2003design value 

### 16.9 I

I 

### Bullitt,

### KY 15.0 

# 1 Floyd,

### IN 14.9

I 

# 1 Hardin, KY 14.1 I



### There are four counties in the MSA with PM2.5 monitors, two of which have violating design values (Jefferson County, Kentucky and Clark, Indiana). Bullitt County, Kentucky has 

### an attaining monitor whose design value is close to the standard (15.0), which indicates that there is a potential to contribute to the PM2.5 violations in area. The adjacent Kentucky Counties ofHardin and Franklin are monitoring attainment and thus, do not indicate emissions contributions. This factor is not significant for the remaining Kentucky counties listed in this table. Franklin, KY



### Factor 3: 

### Population density and de~ree of urbanization including commercial development in included versus excluded areas 13.6

The following table has the populations for the counties in the Louisville MSA and adjacent counties with significant emissions. The total MSA 2002 population is

### 1,039,599. (MSA counties are in bold;

### Kentucky MSA counties are in bold italics.)



# I Hardin, KY 

# I 95,724 

# I N/A 

# I 152 Scott, 

### IN 

# 1 23,334



### Based onthe analysis for this factor for Kentucky only, Jefferson County's population of 698,080 is approximately 6-30 times higher than all the other MSA counties. Hardin County's population is the third largest ofthe counties analyzed, however, it is still relatively insignificant in comparison to Jefferson County's population. Thus, this factor is not significant for the Kentucky counties listed in this table with the exception of Jefferson County. 2.24 

# 1 123



### Factor 4: Traffic and commutinp gatterns Commuting Information Total number ofworkers in Jefferson County, KY: 329,091 Commuters in Jefferson County, KY who work in Jefferson County, KY: 303,624 (92%) Commuters fromJefferson County, KY to Clark County, IN: 7,047 (2%) Total number ofworkers in Bullitt County, KY: 30,648 Commuters in Bullitt County, KY who work in Bullitt County, KY: 8,419 (27%) Commuters from Bullitt County, KY to Jefferson County, KY: 19,730 (64%) Commuters from Bullitt County, KY to Clark County, IN: 41 8 (1%) Total number ofworkers in Oldham County, KY: 27,7 16 Commuters in Oldham County, KY who work in Oldham County, KY: 7,207 (33%) Commuters from Oldham County, KY to Jefferson County, KY: 12,684 (58%) Commuters from Oldham County, KY to Clark County, IN: 326 (1%)Total number of workers in Hardin County, KY: 44,815 Commutersin Hardin County, KY who work in Hardin County, KY: 36,030 (80%) Commuters from Hardin County, KY to Jefferson County, KY: 5,347 (12%) Based on the commuting data for the Kentucky counties listed above, there appears to be potentially significant on-road mobile source emissions contributions from Bullitt and Oldhamto Jefferson County, which has over 300,000resident commuters. A large percent (78%-80%) ofthe workers in Carroll and Hardin Counties, respectively, commute within their resident counties. Thus, with the exceptionof Bullitt, Jefferson, and Oldham Counties, this factor is not significant for the remaining Kentucky counties listed above.


### Vehicle Miles TraveledNMT): The following table has the vehicle miles traveled (thousand miles) for the counties in the LouisvilleMSA and the adjacent county of Hardin due to its relatively high VMT and population. (MSA counties are in 

### bold; Kentucky MSA counties are in bold italics.)



### Floyd, IN 

# 1 843 County Jefferson, 

### KY 2002 VMT (thousandmileslyear) 7,149

Based on the analysis for this factor, the VMT for Jefferson County far exceeds the 

### Clark, IN Bullitt, 

### KY Harrison, IN Oldham, 

### KY

Scott, IN Hardin, KY
VMT 

### 1,262 849 

### 528 507 

### 364 1,333

ofthe MSA and surrounding counties. Although Hardin County has a relatively high VMT, 80% of its workers commute within the County, with an additional 12% commuting into Jefferson County, Kentucky. Based on the analysisfor this factor, Hardin County does not appear to significantly contribute on-road mobile source emissions to Jefferson County. Thus, with the exception of Jefferson County, this factor is not significant for the remaining Kentucky counties listed in this table. 

### Factor 

### 5: Ex~ected prowth The following table has the population and population growth figures for the Louisville MSA and the adjacent Hardin County due to its relativelyhigh VMT and population.(MSA counties are in 

### bold;Kentucky MSA counties are in boM italics.) County Jefferson, 

### KY Floyd, IN Clark,IN Bullitt, 

### KY Harrison,IN 

# 1 35,244

Hardin, KY 

# 1 95,724 

# I 4,934 

# 1 6 2002 Population 698,080 

### 71,633 98,198 63,800 

### 4,435 

# 1 15 Oldham,

### KY

Scott,IN

Based on the analysis for this factor for Kentucky only, the population growth in Bullitt and Oldham Counties indicatethat these counties may contribute to the PM2.5 issuesin Jefferson County. Although Jefferson County's growth rate is fairly low, the magnitude of its population increase is the highest in the MSA and is approximatelytwice that of the increases in Bullitt and Oldham. Although Hardin County's population is the third largest of the counties analyzed above, its population growth is relatively low.Thus,with the exceptionof Bullitt, Jefferson, and Oldham Counties,this factoris not significantfor the remaining Kentuckycounties listed in this table. 

### Factor 6: 

### Meteorolo~v growth (90-00) 28,667



### 6,419 8,695 13,669 

### 49,310 23,334

The followingmeteorological informationwas provided by Kentucky for Jefferson, Bullitt, and Oldham. % growth (90-00) 

### 4 10 10 29

Wind speedwind direction information shows that the majority of the time for the period 1988-1992, the wind in the


### ... County area came fromthe south southwest and typically at 7-10 knots. The mean high temperature for July for the area from 1961through 1990was 87"

### F and the mean low was 70"F. The mean precipitation for the same period was 4.3 inches. 

### 12,915 1,969

The information provided is not sufficient to provide a compelling argumentto exclude countiesbased on prevailing winds. The information provided was based only on summertimewinds. 

### 39 9



### Factor 7: 

### Geoyraphvltopo~raphv Based on an analysis of this factor, there are no significant geographical or topographical issues associated with this MSA. boundary.

### Factor 8: 

### .lurisdictionalboundaries The followingMSA countieswere designated nonattainment for the 8-hour ozone standard on April 15,2004: the Kentucky Counties of Jefferson, Bullitt, and Oldham; and the Indiana Counties of Floyd, Clark, and Jackson. This factor did not play a significant role in the decision-makingprocess for these counties. 

### Factor 

### 9: Level ofcontrol ofemission sources The followinginformation was provided by Kentucky for Bullitt, Oldham, and Jefferson Counties: "Point sourceslocated within


### ... County are subject to Prevention of Significant Deterioration (PSD) requirements, Control Technology GuidelinesReasonable Available Control Technology (CTG RACT) requirements, MaximumAchievable Control Technology (MACT) requirements for sourcesof HazardousAir Pollutants (HAP), and New SourcePerformance Standards(NSPS)." This factor did not play a significantrole in the decision-makingprocess for these counties.

### PM2.5 Nine Factor Analysis for Lexington, KY 

### MSA TheLexington MSA contains the Counties of Fayette, Bourbon, Clark, Jessamine, Madison, Scott, and Woodford. Fayette County is violating the PM2.5 standard. In February 2004, Kentucky recommended that Fayette County be designated attainment for the PM2.5 standard for the Lexington, KY MSA, and the remaining MSA counties be designated attainment. EPA agrees that Fayette County should be designated nonattainment for PM2.5 due to a violating monitor (South Limestone). EPA is modifying Kentucky's recommendation to include the MSA counties of Clark, Madson and Woodford and the adjacent county of Mercer in the Lexington nonattainment area. Clark and Madison Counties are included significant emissions. Madison County also has relatively high population and population growth, and relatively high VMT. Woodford County as nonattainment due tothe level of emissions. We have included in our recommended nonattainment area Mercer County that is adjacent to the Lexington MSA with a violating monitor, that is generally rural in character, and that contains an identifiable large emitting facility (e.g., power plants) which we believe contributes to the nearby nonattainment problem. We have included this county in our initial recommendations in order to ensure that a sufficientportion of this county, including such a large facility, is included within the boundaries of the nonattainment area as part of the final designations. We invite you to submit to us a recommendation as to what portion of this adjacent county, encompassing the large facility, should be designated nonattainment. EPA agrees that the remaining MSA Counties of Bourbon, Jessamine, and Scott in Kentuckybe designated attainment/unclassifiabledue to their relatively low emissions, low populations, low VMT, low numbers of commuters into the violating counties, and small point sources. EPA agrees that the adjacent county of Pulaski should be designated attainmentklassifiablefor the PM2.5 standard, although it has significant emissions due to apower plant. This countyhas relatively low population, low population growth, and low VMT


### . Further, the commutingpatterns and distance from the violating monitors indicate that this county does not contributeto the violations in the area. The other adjacent counties donot contribute and therefore, will be designated as attainment/unclassifiable. Therecommendations of EPA and Kentucky are summarized in the table below.



### Area Lexington, 

### KY EPA Recommendation Full counties: Fayette County Clark County Madison County Mercer County Woodford County 

### StateRecommendation Full counties: Fayette 

### Drop: Bourbon, Clark,Madison, Jessamine, W oodford and Scott CountiesThefollowing is a brief summary of the nine criteria for the Lexington, KY area. These analyses were based on existing available data. 

### Factor 1: Emissions in areas ~otentiallv included versus excluded from the nonattainment area The following table has the 2001 PM2.5, SOX, NOx, VOC, and ammonia emissions in tons and Weighted Emissions Scores for the counties in the Lexington MSA and surrounding counties. (MSA counties in Kentucky are in bold.)

County Fayette (KY) Clark (KY) SOX PM

Madison (KY) Woodford (KY) 

### 1703 1132



## . , Scott (KY) Jessamine (KY) Bourbon (KY) NOx



### 867 559

Mercer (KY) Pulaski (KY) "
Based on the analysis for this factor,the following counties appear to have significant emissions (over 10,000tons per year of any pollutant): Fayette, Mercer and Pulaski. Clark, Madison, and Woodford also have significant level of emissions. Although Pulaslu CountyThis factor did not appear significantforthe remaining counties listed in this table. 

### 3925 9647

627 504 444

Laurel (KY) Nelson (KY)



### Factor 2: Air qualitv in potentially included versus excluded areas 1189 2663

3136 2403



# 1 2001-2003 design value 

# I VOC 

### 13620 6622

260 323 147

770 781 Amm Score



### 5512 3530

49269 25156

Based on the analysis for this factor, only Fayette County's South Lomestone monitoring data exceeds the standard. TheNewtown Pike monitor, also in Fayette County, is attaining at 14.9. Madison County and the adjacent county of Laurel have monitors with readings well below the standard. This factor is not significant for the remaining counties listed in the area. Cum. Score 

### 15720 2374

3629 2189 1424

1044 497

Fayette (KY) Madison (KY) Laurel (KY) 

### 4215 2852

9145 10996



### 15.7 13.5 12.6 

### 606 398

6041 2436 1352

4564 2134 

### 641 427

1686 3901 

### 31.4 25.7

3823 7923 

### 31.4 57.1 13.6 9.5 88.1 95.7 100.0 481 242 597 409 877 

### 70.7 80.2 7.9 7.6 4.3

439 1147 83.8 56.8 N/A N/A 14.6 10.3 N/A N/A

### Factor 

### 3: Po~ulation densitv and de~ree of urbanization including commercial development in included versus excluded areas The following table has the populations for the counties in the Lexington MSA and adjacent counties with significant emissions. The total MSA 2002 population is 489,717. (MSA counties are in 

### bold.)

County Fayette (KY) Clark (KY) 

### 2002 Population
Madison (KY) Woodford (KY) 

### 263,618 33,726

Scott (KY) Jessamine (KY) Bourbon (KY) Mercer (KY) 

# I Nelson (KY) 38,823 92 

### Percent of Total MSA Population


### 73,334 23.403



### . ,
Fayette County's population is roughly 3-11times higher than the other counties listed. Madison County has the second highest of the MSA counties and surrounding counties with significant weighted emissions scores. Based on an analysis of this factor, no other Kentucky counties, with the exception of Madison County, have populations significantto indicate apotential contribution to the PM2.5 violations in Fayette County. 

### Population Density 

### 53.83 6.89
35,320 40,740 19,576 21.047 Laurel (KY)



### Factor 

### 4: Traffic and cornrnutin~ patterns 925 133 14.97 4.78

CommutineInformation 

### 166 123 7.21 8.32 4.0 54,313

Total number of workers in Fayette County, KY: 136,793 Commuters in Fayette County, KY who work in Fayette County, KY: 117,584 (86%) 

### 124 235

67 84 125

Total number of workers in Bourbon County, KY: 9,103 Commuters in Bourbon County, KY who work in Bourbon County, KY: 4,764 (52%) Commuters from Bourbon County, KY to Fayette County, KY: 2,600 (29%) Total number of workers in Clark County, KY: 15,487 Commuters in Clark County, KY who work in Clark County, KY: 8,492 (55%) Commuters from Clark County, KY toFayette County, KY: 4,777 (31 %) Total number of workers in Jessamine County, KY: 18,885Commuters in Jessamine County, KY who work in Jessamine County, KY: 8,721 (46%) Commuters from Jessamine County, KY to Fayette County, KY: 8,748 (46%) Total number of workers in Madison County, KY: 34,494 Commuters in Madison County, KY who work in Madison County, KY: 24,061 (70%) Commuters from Madison County, KY toFayette County, KY: 6,870 (20%) Total number of workers in Scott County, KY: 16,536 Commuters in Scott County, KY who work in Scott County, KY: 10,148 (61%) Commuters from Scott County, KY to Fayette County, KY: 4,287 (26%) Total number of workers in Woodford County, KY: 12,377 Commuters in Woodford County, KY who work in Woodford County, KY: 5,591 (45%) Commuters fromWoodford County, KY to Fayette County, KY: 4,308 (35%) Total number of workers in Laurel County, KY: 21,180 Commuters in Laurel County, KY who work in Laurel County, KY: 16,286 (77%) Total number of workers in Mercer County, KY: 9,610 Commuters in Mercer County, KY who work in Mercer County, KY: 5,235 (54%) Commuters from Mercer County, KY to Fayette County, KY: 1,319 (14%) Total number of workers in Nelson County, KY: 17,594 Commuters in Nelson County, KY who work in Nelson County, KY: 11,189 (64%) Madison County has the largest number of workers commuting intoFayette County (6,870 commuters), which isrelatively insignificant for such a large county as Fayette. Laurel and Nelson County workers donot commute into the Lexington MSA at all. Based on the analysis for this factor, there are no counties with commuting data showing a potential to contribute to the PM2.5 violations in Fayette County. Vehicle Miles Traveled: The following table has the vehicle miles traveled (thousand miles) for the counties in the Lexington MSA and adjacent counties with significant emissions. (Kentucky MSA counties are in bold.)


### [ Clark 

### (KY) 523

County Favette 

### (KY) 2002 VMT 2764



### . , 

# I Scott 

### (KY) 645

Madison 

### (KY) Woodford 

### (KY) 944 311 

### [ Jessamine 

### (KY) 362Bourbon 

### (KY) Mercer (KY)

Fayette County's VMT is substantially higher than the other MSA counties. Although Madison and Laurel Counties have the second and third highest VMT of the counties analyzed, commuting data do not indicate significant (or any) contributions to Fayette County. Further, Laurel County is a significant distance from Fayette County and does not contribute to Fayette County through its commuting patterns. Based on the analysis for this factor, no other Kentucky counties, with the exception of Madison County, have VMT and commuting data with a potential to contribute to the PM2.5 violations in Fayette County. 

### 204 224 Laurel (KY) Nelson (KY)



### Factor 

### 5: Expected ~rowth 852 427

The following table has the population and population growth figures for the Lexington MSA and adjacent counties with significant emissions. (MSA counties are in bold.)

County Fayette 

### (KY) Clark 

### (KY) 2002 Population

Madison 

### (KY) Woodford 

### (KY) 

# I Bourbon 

### (KY) 

## I 19576 

## 1 124 

## 1 1 

# I 263618

33726

Scott 

### (KY) Jessamine 

### (KY) growth 

### (90-00)

73334 23403



# I Nelson (KY) 38823 

## 1 7,767 

## 1 26 

# 1 % growth



### (90-00) 35,146

3,648

35320 40740 Mercer (KY) Laurel (KY) Fayette County's population is substantially higher than the MSA counties and adjacent counties with significantweighted emissions scores, and grew the most during the 1990- 2000 time period. Madison Countyisthe third fastest growing county in the MSA based on a percent growth rate with the second largest population and the second largest population increase. Thus, Madison County's population growth is significant enough to contribute toPM2.5 violations in Fayette County. None of the other MSA and adjacent counties listed above have population characteristics which appear to be contributingto the PM2.5 violations in Fayette County. 

### 16 12 13,364

3.253



### Factor 6: 

### Meteorolo~v 23 16 9,194 8.533 21047 54313 

### 39 28 1,669 9,277 9 2 1The following meteorological information was provided by Kentucky. The figure referenced is a wind rose for April 1-October

### 31for the 1988-1992 period that is provided in Kentucky's PM2.5recommendations submittal. The text below is the same for Fayette, Bourbon, Clark, Jessamine, Scott, and Woodford Counties. "Wind speedlwinddirection information shows that the majority of the time for the period 1988-1992, the wind in the


### ... County area came from the southwestand typically from 7-10knots. (See figure 1-A) The mean high temperature for July forthe area from 1961through 1990was 86"F and the mean low was 66" F. The mean precipitation for the same period was 4.8 inches." (Source: 

### KYsubmittal) For Madison County, the following statementpreceded the excerptedparagraph above: Due to the close proximity of Lexington,Kentucky, meteorological data from Lexington was used for the Madison county area." This factor did not play a significantrole in the decision making process. The submitted information was only forthe summertime winds. 

### Factor 7: 

### Geo~raphpltopo~raphp Based on an analysis of this factor,there are no significanttopographical issues associated with this MSA.


### Factor 8: 

### .Jurisdictional boundaries No county in the Lexington MSA was designatednonattainment forthe 8-hour ozone standard on April 15,2004. This factor did not play a significant role in the decision making process.


### Factor 

### 9: Level of control of emission sources The followinginformation was provided by Kentucky for Fayette,Bourbon, Clark, Jessamine, Madison, Scott,Woodford Counties. "Pointsources located within


### ...County are subject toPSD requirements, CTG RACT requirements, Maximum Achievable Control Technology (MACT) requirements for sources ofHazardous Air Pollutants, and New Source Pe$ormance Standards (NSPS)." (Source: KY PM2.5 submittal) This factor did not play a significant role in the decision making process.

### PM 2.5 

### Nine Factor Analysisfor Huntington-Ashland,WV-KY-OHMSA The Huntington-Ashland MSA containsthe Kentucky Countiesof Boyd, Carter, and Greenup; the West Virginia Countiesof Cabell and Wayne; and Lawrence County, Ohio. The followingMSA and adjacent counties are violatingthe PM2.5 standard: Cabell County,West Virginia (MSA) and Lawrence (MSA) and Scioto (adjacent) Counties, Ohio. In February 2004, Kentucky recommended that the PM2.5 designation for Boyd County be deferred and that Greenup and Carter Countiesbe designatedattainment for the Huntington-Ashland MSA. EPA is modifying Kentucky's recommendeation to include Boyd County and Lawrence Countiesin Kentucky in the Huntington-Ashland nonattainmentarea. The following factorsplayed a significantrole in this decision for Boyd County: attaining monitor reading of 15.0,at the standard; significant SOX, NOx, and PM emissions; proximity to the violating MSA counties; controlswith anticipated, substantialSOX, NOx, and PM emission reductions will not be implemented until the end of 2005, well after designationsare made. Lawrence County, Kentucky is included due to significant emissions of SOX and NOx from apower plant and its closeproximity to the violating countiesin the MSA. We have includedin our recommended nonattainment area this Countythat is adjacent to the Huntington-AshlandMSA with a violating monitor, that is generally rural in character, and that contains an identifiablelarge emitting facility (e.g.,power plant) which we believe contributes to the nearbynonattainment problem. We have included this county in our initial recommendations in order to ensure that a sufficientportion of this county, including such a large facility, is includedwithin the boundaries of the nonattainment area as part of the final designations. We invite you to submit to us arecommendation as to what portion of this adjacent county, encompassing the large facility, shouldbe designated nonattainment. EPA agrees that Greenup and Carter Countiesin Kentucky shouldbe designated attainment/unclassifiable due to their relatively low emissions,low populations,low VMT, low numbers of commuters into the violating counties, and small point sources. The recommendations of EPA and Kentucky are summarizedin the table below.

The following is abrief summary of the nine criteria for the Kentucky portion of the Huntington-Ashland, WV-KY-OH area. These analyses were based on existing available data.



### Area Huntington-Ashland, WV-KY-OH EPA Recommendationfor KY Full counties: Boyd County Lawrence County (adjacent) 

### State Recommendation Full counties: Boyd (DeferDesignation)Factor 

### 1: Emissions in areas ~otentiallv included versus excluded from the nonattainment area The following table has the 2001 PM2.5, SOX, NOx, VOC, and ammonia emissions in tons per year and weighted emissions scores forthe counties in the Huntington-Ashland MSA and surrounding counties. (MSA counties are in bold; Kentucky MSA counties are in bold italics.)


## I Cabell (WV) 

## 1 2.365 

## 1 5.155 

## 1 27.903 

## 1 7.080 

## 1 181 

## 1 40.3 

## 1 40.3

County 

# I Boyd 

### (KY) 

## 1 2,314 

## 1 11,740 

## 1 13,478 

### [ 8,620 

## 1 467 

## 1 25.2 

## 1 65.5 PM



### Wayne(WV) 

### Greenup

### (KY) SOX

Lawrence 

### (OH) Carter 

### (KY) Gallia (OH) 

### 550 477

Adams (OH) Putnam (WV) Mason (WV) Lawrence (KY) Scioto (OH) 

### 770 506 10,010

Lewis (KY) Pike (OH) NOx



### 1,023 2,519

6,417 4,395 3,610 2,903 1,053

Rowan KY Mingo (WV) Jackson (OH) Martin (KY) Lincoln (WV)

Based on the analysis forthis factor, the following Kentucky counties appear to have significant emissions (over 10,000tons per year of any pollutant): Boyd and Lawrence. This factor is not significantforthe remaining Kentucky counties listed in this table. VOC



### 841 237 164,984

429 425

I I I I I I I

Factor 

### 2: Air aualitv in potentiallv included versus excluded areas Cum. Score Amm



### 6,485 4,336

125,136

80,150 70,053 56,066

2,790

336 437 404 281 259 Elliott (KY) Score



### 4,399 2,615 61,079

469 4,203 

### 2,620 1,795

52,992 39,795 31,327 21,265

5,566

313 28 1 46 1 66 1

67 164 

### 4,366 1,996 1,839

2,873 2,081 

### 56 156

1,508 3,752 2,831

919 4,703
1,691 2,842 1,320 1,236 1,3 14 

### 207 223 300

990 1,311

115 

### 9.6 9.5

431

97 264

56 350
1,535 1,379 1,717

706 1,128 42 

### 75.1 84.6 

### 8.6 6.8 141.4 102.4 72.7 60.0 48.3 12.5 222 149

393 3.1 

### 93.2 100.0

8.1 6.8 9 1 150 165 762

37 313 5.7 5.5 4.7 4.O 4.0County 

### Cabell (WV) 2001-2003 design value 

### 16.6 Boyd 

### (KY) Lawrence 

### (OH)

There are four monitors in the MSA, with two of them in the Kentucky Counties of Boyd and Carter. The Kentucky monitors are monitoring attainment. Three monitors in the MSA and surrounding counties are violating: Cabell County, West Virginia; Lawrence County, Ohio; and the adjacent SciotoCounty, Ohio. Based on the analysis for this factor for Kentucky only, Boyd County has attaining monitoring data very closetothe standard, thus indicating a potential to contribute to the PM2.5 violations in the area. This factor is not significant for the remaining Kentucky counties. 

### 15.0 

### 15.8 Carter 

### (KY) Scioto (OH)



### Factor 3: 

### Population densitv and depree - 

### ofurbanization includin~ - 

### commercial developmentin included versus excluded areas 12.2 17.2

Thefollowing table has the populations for the counties in the Huntington-Ashland MSA and adjacent counties with significant emissions. Thetotal MSA 2002 population is 313,239. (MSA counties are in 

### bold;Kentucky MSA counties are in bold italics.)

County

I I I 2002 Population 

### Cabell (WV) 

# 1 95,266 Boyd 

### (KY) Wayne (WV) 30.41 

# 1 338
Greenup 

### (KY) Lawrence 

### (OH)

Scioto (OH) 

## 1 78,041 128

# 1 Percent of Total MSA Population 

### 49,603 

### 42,382

Based on the analysis forthis factor for Kentucky only, Boyd County has the third largest population in the MSA and the second largest population density, indicating a potential to contribute to the PM2.5 violations in the area. This factor isnot significant for the remaining Kentucky counties. 2002 Population Density



### 36,761 

### 62.172 66 67 48 . , 

### 1 5.84 

### 13.53

Carter 

### (KY) Gallia (OH) Adams (OH) 

### 310 

### 84 11.74 

### 19.85 106 

### 137 2 7,055 31,301 27,804 

### 8.64

### Factor 

### 4: Traffic and commutinppatterns CommutingInformation Total number of workers in Boyd County, KY: 19,106 Commuters in Boyd County, KY who work in Boyd County, KY: 13,816 (72%) Commuters from Boyd County, KY to Cabell County, WV: 1,157 (6%) Commuters from Boyd County, KY toLawrence County, OH: 540 (3%) Total number of workers in Carter County, KY: 10,258 Commuters in Carter County, KY who work in Carter County, KY: 5,641 (55%) Commuters from Carter County, KY to Boyd County, KY: 1,401 (14%) Commuters from Carter County, KY to Cabell County, WV: 237 (2%) Total number of workers in Greenup County, KY: 13,798 Commuters in Greenup County, KY who work in Greenup County, KY: 5,930 (43%) Commuters from Greenup County, KY to Boyd County, KY: 4,147 (30%) Commuters from Greenup County, KY to Cabell County, WV: 473 (3%) Commuters from Greenup County, KY to Lawrence County, OH: 443 (3%) Commuters from Greenup County, KY to SciotoCounty, KY: 1,252 (9%) Total number of workers in Lawrence County, KY: 4,899 Commuters in Lawrence County, KY who work in Lawrence County, KY: 2,483 (51%) Commuters fromLawrence County, KY to Boyd County, KY: 575 (12%) Commuters fromLawrence County, KY to Cabell County, WV: 193(4%) Commuters from Lawrence County, KY to Lawrence and Scioto Counties, OH: 0 (0%) Based on commuting data above, none of the Kentucky counties appear to be contributing a significant level of onroad mobile source emissions to the area. 

### Vehicle Miles Traveled: The following table has the vehicle miles traveled (thousand miles) for the counties in the Huntington-Ashland MSA and some adjacent counties with significant emissions. (MSA counties are in 

### bold;Kentucky MSA counties are in bold italics.)

County 

# I Boyd (KY) 

## 1 411 2002 VMT



### Cabell (WV) (thousand mileslyear) 1,030 

### Wayne (WV) Greenup (KY) 

### Lawrence 

### (OH) 377 264 796

## I Carter

### (KY) 

## 1 665 

# I Putnam (WV) 

## 1 578

Gallia (OH) Adams (OH) 266 283

Based on the total VMT of the Kentucky counties only, there appears to be a potential contribution of onroad mobile source emissions to the area from Boyd and Carter Counties. However, the analysis of the commuting data above showsthat a low number of workers commute from these Kentucky counties into the violating counties. Thus, this factor is not significant for the Kentucky counties listed above when VMT and commuting data are analyzed together.

Mason (WV) Scioto (OH)



### Factor 5: 

### Expected mowth 270 633

The following table has the population and population growth figures for the HuntingtonAshland MSA and adjacent counties with significant emissions. (MSA counties are in 

### bold;Kentucky MSA counties are in bold italics.)

County 

### Cabell (WV) Boyd 

### (KY) 2002 Population 

### Wayne (WV) Greenup 

### (KY) Lawrence 

### (OH) 95,266 49,603

Carter 

### (KY) Gallia (OH) growth (90-00)
42,382 36,761 62,172

Adams (OH) Putnam (WV)

Based on an analysis of this factor for Kentucky only, there appears to be relatively significant population growth in Carter County to indicate a potential air quality contribution. However, Carter County's population is low. Boyd and Greenup Counties have a negative or zero population growth rate. Thus, this factoris not significant.for the Kentucky counties. % growth (90-00) -43 -1,398

27,055 31,301
Mason (WV) Scioto (OH)



### Factor 6: 

### Meteorologv -0 -3 1,267

149 485
27,804 52,230

The following meteorological information was provided by Kentucky. Thetext below is 3 0 1 2,549 115
26,004 78 ,041 10 0 1,959 8,754 8 20 779 -1,132 3

- 1the same for Boyd, Carter, and Greenup Counties in Kentucky. The figure referenced is a wind rose for April 1-October 31 for the 1988-1992period that isprovided in Kentucky's PM2.5 recommendations submittal. 

### Meteorological Information "Due to the close proximity of Huntington, West Virginia, meteorological data from Huntington was used for this Kentucky area. Wind speedwind direction information shows that the majority of the time for the period 1988-1992, the wind in the Huntington-Ashland area came from the southwest and typically from 4-6 knots. (See figure 1-A)Themean high temperature for July for the area from 1961through 1990 was 85" F and the mean low was 65" F. The mean precipitation for the same period was 4.5 inches." (Source: Kentucky PM2.5submittal) Based on an analysis of this factor, the information provided is not sufficientto provide a compelling argument to exclude counties based on prevailing winds. Theinformation provided was for only the summertime winds.


### Factor7: Geo~ra~hvlto~oeraphv Based on an analysis of this factor, there are no significant topographical issues associated with this MSA. 

### Factor 

### 8: Jurisdictional boundaries The following MSA counties were designated nonattainment for the 8-hour ozone standard on April 15,2004: Boyd County, Kentucky; the West Virginia Counties of Cabell,Wayne, and Putnarn; and no counties in Ohio. This factor did not play a significant role in the decision-malung process. 

### Factor 9: 

### Level ofcontrol of emission sources The following information was provided by Kentucky for Boyd, Carter, and Greenup Counties. "Pointsources located within



### ...Countyare subject toPSD requirements, CTGRACT requirements,MaximumAchievable Control Technology (MACT) requirements for sources ofHazardousAir Pollutants, andNew Source Pe$omzance Standards (NSPS)." This factor did not play a significant role in the decision-making process for these counties. The following information was provided by Kentucky for Boyd County. Kentucky anticipates that emissions of PM2.5, SOX,and NOx will decrease substantially within Boyd County over the next two years. These anticipated emission decreases are due to source modernization and new controls being implemented at two majorsourcesin Boyd County:the Marathon-AshlandRefinery and Calgon Carbon Corporation. For the Marathon-AshlandRefinery, the facility modifications are anticipatedto be completedby the end of 2005. According to Kentucky, based on 2002 emissions data, this would mean an approximatereduction of 1,571tons per year of S02,a 761 ton per year reduction in NOx, and a 32 ton per year reduction in particulate matter. For Calgon Carbon Corporation,the May 2003 shutdown of two of their activatorlines resulted in SO2emissions being reduced from this facilityby approximately 187tons in 2003.Before these lines can be reactivated, scrubbers,with SO2 and PM control efficienciesof 90% will be required to be installed on these units. 

### If brought back into operation,these units will have controlsin place to reduce emissions of SO2from these two lines to approximately32 tons per year. Based on an analysis of this factor, these controlswill not be implemented in a timeframe early enough to influence the decision for Boyd County on PM2.5 designations.