1

Technical Support Document

Ohio

Area Designations For the 

2010 SO2 Primary National Ambient Air Quality Standard

Summary

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

“nonattainment,” “attainment,” or “unclassifiable” for the 2010 one-hour sulfur dioxide (SO2) primary 

national ambient air quality standard (NAAQS). The CAA defines a nonattainment area as one that 

does not meet the NAAQS or that contributes to a violation in a nearby area. 

Ohio submitted designation recommendations on June 3, 2011, and submitted supplemental 

information and amended recommendations on June 29, 2011, April 12, 2012, and January 18, 2013. 

On February 6, 2013, EPA sent out a letter with intended designations for some areas in Ohio. Ohio

responded in letters dated March 13, 2013 and April 26, 2013. Ohio also provided additional 

information on June 19, 2013. Table 1 below identifies the counties or portions of counties in Ohio 

that EPA is initially designating “nonattainment” based on monitored violations. EPA is not yet 

prepared to designate other areas in Ohio, and will address such areas and their sources in a future 

round of final designations. 

Table 1. Nonattainment Area Designations for Ohio

Area 

Ohio’s Recommendation of 

Areas/ Counties

EPA’s Nonattainment 

Designation of Areas/Counties 

Lake County, Ohio

 Lake County Nonattainment Nonattainment

Muskingum River, Ohio

 Morgan County (partial): 

 Center Township

 Washington County (partial):

 Waterford Township

Nonattainment 

Nonattainment

Nonattainment 

Nonattainment

Steubenville OH-WV

 Jefferson County, OH (partial): 

 Cross Creek, Steubenville, Warren, 

 and Wells Townships and Steubenville

 City

 Brooke County, WV (partial):

 Cross Creek Tax District

Nonattainment

Nonattainment*

Nonattainment

Nonattainment

Campbell-Clermont County KY-OH

 Campbell County, KY (partial)

 (See KY TSD)

 Clermont County, OH (partial):

 Pierce Township

Unclassifiable*

Unclassifiable

Nonattainment

Nonattainment

*Recommendation by West Virginia or Kentucky; Ohio made no recommendation outside Ohio.
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Background

On June 3, 2010, EPA revised the primary SO2 NAAQS (75 FR 35520, published on June 22, 2010). 

EPA revised the primary SO2 standard by establishing a new one-hour standard at a level of 75 parts 

per billion (ppb), which is met at an ambient air quality monitoring site when the three-year average of 

the annual 99th percentile of one-hour daily maximum concentrations does not exceed 75 ppb. EPA 

has determined that this is the level necessary to provide protection of public health with an adequate 

margin of safety, especially for children, the elderly and those with asthma. These groups are 

particularly susceptible to the health effects associated with breathing SO2. EPA is revoking the two 

prior primary standards of 140 ppb evaluated over 24 hours, and 30 ppb evaluated over an entire year 

because they will not add additional public health protection given a one-hour standard at 75 ppb. 

Accordingly, EPA is not designating areas in this process on the basis of either of these two primary 

standards. Similarly, the secondary standard for SO2 has not been revised, so EPA is not designating 

areas in this process on the basis of the secondary standard. 

EPA’s SO2 Designation Approach

Section 107(d) of the CAA provides that not later than one year after promulgation of a new or revised 

NAAQS, state Governors may submit their recommendations for designations and boundaries to EPA. 

For the 2010 SO2 NAAQS, this date was in June 2011. Section 107(d) also requires EPA to provide 

notification to states no less than 120 days prior to promulgating an initial area designation that is a 

modification of a state’s recommendation. If a state did not submit designation recommendations, 

EPA is promulgating the designations that it deems appropriate. If a states or tribe disagreed with 

EPA’s intended designations, it had an opportunity to demonstrate why it believed any proposed 

modification was inappropriate.

Designations guidance was issued by EPA through a March 24, 2011, memorandum from Stephen D. 

Page, Director, U.S. EPA, Office of Air Quality Planning and Standards, to Air Division Directors, 

U.S. EPA Regions I-X. This memorandum identifies factors EPA evaluated in determining boundaries 

for areas designated nonattainment. These five factors include: 1) air quality data; 2) emissions and 

emissions-related data (location of sources and potential contribution to ambient SO2 concentrations); 

3) meteorology (weather/transport patterns); 4) geography/topography (mountain ranges or other air 

basin boundaries); and 5) jurisdictional boundaries (e.g., counties, air districts, pre-existing 

nonattainment areas, reservations, metropolitan planning organization), among any other information

deemed to be relevant to establishing appropriate area designations and boundaries for the one-hour 

SO2 NAAQS.

The March 24, 2011, designation guidance memo recommended that area boundaries default to the 

county boundary unless information provided by the state or tribe justifies a larger or smaller boundary 

than that of the county. EPA believes it is appropriate to evaluate each potential area on a case-by-case 

basis, and to recognize that area-specific analyses conducted by states, tribes and/or EPA may support 

a differing boundary than a county boundary.

In this technical support document (TSD), EPA discusses its review and technical analysis of the 

recommendations regarding areas with monitored violations submitted by Ohio for designations for the 

one-hour SO2 standard and any modifications from these recommendations. 
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Definition of important terms used in this document:

1) Designated nonattainment area – an area which EPA has determined, based on a state 

recommendation and/or on the technical analysis included in this document, has violated the 2010 SO2

NAAQS, based on the most recent three years of air quality monitoring data, or contributes to a 

violation in a nearby area.

2) Recommended nonattainment area – an area that a state or tribe has recommended to EPA to be 

designated as nonattainment.

3) Violating monitor – an ambient air monitor meeting all methods, quality assurance and siting 

criteria and requirements whose valid design value exceeds 75 ppb, as described in Appendix T of 40 

CFR part 50.

4) 2010 SO2 NAAQS – The NAAQS for SO2 promulgated in 2010. This NAAQS is 75 ppb, based on 

the three year average of the 99th percentile of the annual distribution of daily maximum one-hour 

average concentrations. See 40 CFR Part 50.17.

5) Design Value - a statistic computed according to the data handling procedures of the NAAQS (in 40 

CFR 50 Appendix T) that, by comparison to the level of the NAAQS, indicates whether the area is 

violating the NAAQS.

A. Technical Analysis for the Lake County, Ohio Area

Introduction 

This technical analysis for the Lake County, Ohio Area identifies the monitor that violated the 2010 

SO2 NAAQS, and evaluates nearby counties for contributions to SO2 concentrations in the area. EPA 

has evaluated this county and nearby counties based on the evidence for the factors recommended in 

the March 24, 2011 EPA designations guidance. This county is listed above in Table 1. 

Ohio recommended that Lake County be designated as nonattainment for the 2010 SO2 NAAQS based 

on monitored air quality data from 2008-2010. EPA agrees with Ohio’s recommendation. EPA is 

initially designating Lake County, Ohio as nonattainment for the 2010 SO2 NAAQS, based upon 

currently available information, including the monitored design value for 2009-2011. Areas and 

sources that we are not prepared to conclude are contributing to the monitored violations or to other 

possible violations are not included in this initial nonattainment area, and will be addressed in a future 

round of final designations. Figure 1 shows the nonattainment area and the monitor location.
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Figure 1. Map of Lake County, Ohio Nonattainment Area.

Detailed Assessment

Air Quality Data 

This factor considers the SO2 air quality monitoring data, including the design values (in ppb) 

calculated for all air quality monitors in Lake County and the surrounding area based on data for the 

2009-2011 period. The 2010 SO2 NAAQS design value for Lake County is shown in Table 2.

Table 2. Air Quality Data for Lake County Nonattainment Designations 

County

State 

Recommended 

Nonattainment?

Monitor Air 

Quality 

System ID

Monitor Location

SO2 Design 

Value, 

2009 - 2011

(ppb)

Cuyahoga No 39-035-0038 Cleveland 71

No 39-035-0045 Cleveland 42

No 39-035-0060 Cleveland 73*

No 39-035-0065 Newburgh Hts 38

Lake Yes 39-085-0003 Eastlake 33

Yes 39-085-0007 Painesville 157

Ashtabula No 39-007-0001 Conneaut 24

Monitor in Bold has the highest 2009-2011 design value in the area. 

*Data for 2009 is incomplete.

Lake County shows a violation of the 2010 SO2 NAAQS at one of its monitors. Therefore, some area 

in Lake County and possibly additional areas in surrounding counties must be designated 

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

counties as candidates for nonattainment status. 
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Emissions and Emissions-Related Data

Evidence of SO2 emissions in the vicinity of a violating monitor is an important factor for determining 

whether a nearby area is contributing to a monitored violation. For this factor, EPA considered county

emissions data for SO2 and data for sources within 50 kilometers of violating monitors. Ohio provided 

this data in its June 3, 2011 submittal. Ohio’s emissions data came from facility reports to the state, 

which were the basis for Ohio’s submittal to the 2008 National Emissions Inventory (NEI). EPA 

relied primarily on this data for its analysis of Ohio’s SO2 designation recommendations.

Table 3 shows the annual emissions of SO2 (given in tons per year) for violating and potentially 

contributing counties in and around Lake County, and sources emitting greater than 100 tons per year 

of SO2 according to the 2008 NEI. Lake County is shown in bold. Most of the facilities in Ashtabula 

and Cuyahoga Counties are over 40 kilometers from the Lake County monitors. Given their distance 

from the Lake County monitor, we are not yet prepared to conclude that emissions from these sources 

are contributing to the monitored violation in Lake County. We will further address these sources in a 

future round of designations.

Table 3. SO2 Emissions for the Lake County Area (NEI08V3)

County

Facility 

Located in 

State 

Recommended 

Nonattainment

Area?

Facility Name

Facility Location/ 

Distance from 

violating monitor 

(km)

Facility Total SO2

Emissions 

(tons per year)

Lake

Yes Eastlake Power Plant Willoughby/17 50521.0

Yes Painesville Municipal 

Electric Plant

Painesville/1 7212.0

Yes Carmeuse Lime – Grand 

River Operations

Grand River/4 910.0

Yes Lubrizol Corporation Painesville/3 23.0

Yes Lubrizol Corporation –

Wickliffe Facility

Wickliffe/23 6.7

Cuyahoga

No Lake Shore Power Plant Cleveland/39 4582.0

No The Medical Center 

Company

Cleveland/41 2203.0

No Cleveland Thermal LLC Cleveland/45 1332.0

No ArcelorMittal Cleveland, 

Inc.

Cleveland/46 718.0

No Charter Steel – Cleveland, 

Inc.

Cleveland/47 61.0

Ashtabula

No FirstEnergy Ashtabula 

Plant

Ashtabula/44 3850.0

No Millennium Organic 

Chemicals, Inc. Plant 2

Ashtabula/44 20.0

No Millennium Organic 

Chemicals, Inc. Plant 1

Ashtabula/45 6.4

No USA Waste Geneva 

Landfill

Geneva/28 2.9
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Emission Controls 

The emissions data used by EPA in this technical analysis and provided in Table 3 represent emissions 

levels taking into account any control strategies implemented on stationary sources up to and including 

2008. EPA has not received any additional information on emissions reductions resulting from 

controls put into place after 2008.

Meteorology (weather/transport patterns)

Evidence of source-receptor relationships between specific emissions sources and high SO2 values at 

violating monitors is another important factor in determining the appropriate contributing areas and the 

appropriate extent of the initial nonattainment area. As shown in Figure 2, meteorological records for 

the nearest meteorological station, in Cleveland, indicate that winds blow predominantly from the 

southwest, the winds in this area can come from any direction. 

Figure 2: Wind Rose for Lake County, OH

Source: OEPA Software: WRPLOT-Lakes Environmental Software

Near Lake Erie, a diurnal lake/land breeze pattern may occur. Therefore, sources in all directions can 

have some potential contribution. Lake County’s two largest sources, Painesville Municipal Electric 

Plant and Eastlake Power Plant, are to the west and southwest, frequent wind directions. 

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

Lake County is adjacent to Lake Erie. The area can experience lake and land breezes, but the 

geographical and topographical features of the area are not considered to significantly limit air 

pollution transport. Therefore, this factor did not play a significant role in determining the 

nonattainment boundary. 
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Jurisdictional Boundaries 

Once the geographic area associated with the area violating the SO2 standard and the nearby areas 

contributing to the monitored violations are determined, we considered existing jurisdictional 

boundaries for the purpose of providing a clearly defined legal boundary for carrying out the air quality 

planning and enforcement functions of the area. There are no current SO2 nonattainment areas in Lake 

County and the surrounding region for the prior SO2 NAAQS. The recommended nonattainment area 

is Lake County. The SO2 sources which are likely to be the main contributors to the violating 

monitor’s design value are located within this county. The violating SO2 ambient air quality monitor is

also located within Lake County. EPA finds the county boundaries to be a suitably clear basis for 

defining nonattainment area boundaries. 

Other Relevant Information

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

this area.

Conclusion

After considering the factors described above, EPA is initially designating Lake County as a 

nonattainment area for the 2010 SO2 NAAQS. An air quality monitor in Lake County shows

violations of the 2010 SO2 NAAQS. Lake County facilities emit over 58,000 tons per year of SO2

(based on 2008 data). The large facilities in the neighboring counties are 40 kilometers or more from 

the violating Lake County monitor. Given their distance from the violating Lake County monitor, we 

are not yet prepared to conclude that emissions from these sources contributing to the violation in Lake 

County or to other possible violations, and will further address these sources in the future. Therefore, 

EPA finds that Lake County encompasses the appropriate initial nonattainment area based on the 

violating monitor. In a subsequent round of designations, we will make final designation decisions for 

areas and their sources in Ohio not included in the nonattainment area designations addressed in this 

TSD.

B. Technical Analysis for the Muskingum River, OH Area 

Introduction 

This technical analysis for the Muskingum River Area identifies the monitor that violates the 2010 SO2

NAAQS, and evaluates nearby counties for contributions to SO2 concentrations in the area. EPA has 

evaluated this county and nearby counties based on the evidence for the factors recommended in the 

March 24, 2011 EPA designations guidance. 

Ohio recommended that Center Township in Morgan County and Waterford Township in Washington 

County be designated as nonattainment for the 2010 SO2 NAAQS. For clarity, EPA will refer to this 

nonattainment area as the Muskingum River Area, since the primary source in the area is American 

Electric Power’s Muskingum River Power Plant. EPA is initially designating Center Township in 

Morgan County and Waterford Township in Washington County in Ohio as the Muskingum River 

nonattainment area, based upon currently available information. These partial counties are listed 

above in Table 1. Areas and sources that we are not prepared to conclude are contributing to the 

monitored violations or to other possible violations are not included in this initial nonattainment area, 
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and will be further addressed in a future round of final designations. Figure 3 shows a map of the 

nonattainment area including the monitor location.

Figure 3. Map of Muskingum River, OH Nonattainment Area.

Detailed Assessment

Air Quality Data 

This factor considers SO2 air quality monitoring data and the design value (in ppb) calculated for the 

air quality monitor in Morgan County for 2009-2011. The 2010 SO2 NAAQS design value for Morgan 

County is shown in Table 4.

Table 4. Air Quality Data for the Muskingum River Area 

County

State 

Recommended 

Nonattainment?

Monitor Air 

Quality 

System ID

Monitor Location

SO2 Design 

Value, 

2009 - 2011

(ppb)

Morgan Yes 39-115-0004 Hackney, OH 180

Morgan County shows a monitored violation of the 2010 SO2 NAAQS. Therefore, some area in this 

county and possibly additional areas in surrounding counties must be designated nonattainment. The

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

candidates for nonattainment status. 
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Emissions and Emissions-Related Data

Evidence of SO2 emissions in the vicinity of a violating monitor is an important factor for determining 

whether a nearby area is contributing to a monitored violation. For this factor, EPA considered county

emissions data for SO2 and data for sources within 50 kilometers of violating monitors. Ohio provided 

this data in its June 3, 2011 submittal. Ohio’s emissions data came from facility reports to the state, 

which were the basis for Ohio’s submittal to the 2008 NEI. EPA relied primarily on this data for its 

analysis of Ohio’s SO2 designation recommendations.

Table 5 shows the annual emissions of SO2 (given in tons per year) for potentially contributing 

counties in and around the Muskingum River Area and sources emitting greater than 100 tons per year

of SO2 according to the 2008 NEI. There are no such sources of SO2 within Morgan County, except 

that a portion of the Muskingum River power plant, which is generally inventoried as part of 

Washington County, is physically located in Morgan County. Ohio considered all SO2 sources within 

50 kilometers of the violating monitor. Listed below are the sources which are considered most likely 

to impact the Morgan County SO2 monitor’s design value. They are all located within 5

to12 kilometers of the monitor. There are two additional sources that emit over 100 tons per year in 

Washington County, but they are 37 kilometers from the Morgan County monitor. There are two 

sources which emit over 100 tons per year in two other neighboring counties, but they are over 40 

kilometers from the Morgan County monitor. Based on the distance of these sources from the 

violating monitor, EPA is not yet prepared to conclude that these sources in neighboring counties 

contribute to the monitored violation in Morgan County or to other possible violations. We will

further address these sources and areas in a future round of final designations.

Table 5. SO2 Emissions for the Muskingum River Area (NEI08V3)

County

Facility 

Located in 

State 

Recommended 

Nonattainment

Area?

Facility Name

Facility 

Location/ 

Distance from 

monitor

Facility total 

SO2 Emissions 

(tons per year)

Washington

Yes Muskingum River Power 

Plant

Waterford/5 133,338.0

Yes Globe Metallurgical Waterford/5 1190.6

Yes Washington Energy 

Facility

Beverly/6 0.81

Yes AEP/Columbus Southern

Waterford Plant

Waterford/12 0.66

Emission Controls 

The emissions data used by EPA in this technical analysis and provided in Table 5 represent emissions 

levels taking into account any control strategies implemented on stationary sources in the area up to 

and including 2008. EPA has not received any additional information on emissions reductions 

resulting from controls put into place after 2008.

Meteorology (weather/transport patterns)

Evidence of source-receptor relationships between specific emissions sources and high SO2 values at 

violating monitors is another important factor in determining the appropriate contributing areas and the 
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appropriate extent of the nonattainment area. Shown in Figure 4, winds in this general area tend to 

blow most often from the southwestern directions, but can come from any direction. 

Figure 4: Wind Rose for Muskingum River Area

Source: OEPA Software: WRPLOT-Lakes Environmental Software

All four sources in Washington County are south-southwest of the monitor, which is a frequent wind 

direction. 

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

The Muskingum River recommended nonattainment area does not have any geographical or 

topographical barriers significantly limiting air pollution transport. Therefore, this factor did not play a 

significant role in determining the nonattainment boundary.

Jurisdictional Boundaries 

Once the geographic area associated with the area violating the SO2 standard and the nearby areas 

contributing to the monitored violations are determined, we considered existing jurisdictional 

boundaries for the purpose of providing a clearly defined legal boundary for carrying out the air quality 

planning and enforcement functions of the area. There are no current SO2 nonattainment areas in 

Morgan and Washington Counties under the prior NAAQS. The state recommended Muskingum 

River nonattainment area for the 2010 SO2 NAAQS consists of the two adjacent townships in Morgan 

and Washington Counties which contain the SO2 sources contributing to the monitored violations. The 

SO2 ambient air quality monitor is also located within this area. Townships in Ohio have well 

established boundaries and EPA finds that they are suitable for defining Ohio’s nonattainment areas. 
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Other Relevant Information

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

this area.

Conclusion

After considering the factors described above, EPA agrees with Ohio’s recommendation and is initially 

designating Center Township in Morgan County and Waterford Township in Washington County as 

the Muskingum River nonattainment area for the 2010 SO2 NAAQS. An air quality monitor in 

Morgan County is violating the 2010 SO2 NAAQS based on monitored air quality data from 2009-

2011. The sources that are considered most likely to impact the Morgan County SO2 monitor’s design 

value are all located within 5 to12 kilometers of the monitor within Ohio’s recommended boundary. 

Therefore, EPA finds that the boundaries described herein encompass the appropriate initial 

nonattainment area for the 2010 SO2 NAAQS. EPA is not yet ready to conclude that the emissions 

from sources located outside the nonattainment area boundary contribute to the monitored violation or 

to other possible violations. In a subsequent round of designations, we will make final designation 

decisions for areas and sources in Ohio not included in the nonattainment area designations addressed 

in this TSD.

Interstate Areas

The next two technical analyses discuss nonattainment designations that cross state boundaries. The 

Steubenville, OH-WV Interstate Area and the Campbell-Clermont, KY-OH Interstate Area are 

adjacent to the Ohio River, which forms the boundary between Ohio and West Virginia, and between

Ohio and Kentucky. The location of the main SO2 sources and the monitors are such that Ohio, West 

Virginia, and Kentucky sources can cause or contribute to air quality impacts on the opposite side of 

the Ohio River. Therefore, these nonattainment areas should be treated as interstate areas. Ohio did 

not specifically address interstate issues when addressing these areas in its June 3, 2011 submittal. 

This TSD focuses on the Ohio portion of these interstate nonattainment areas. 1

EPA’s “120-day letter” to Ohio, sent on February 6, 2013, expressed the intent to include a portion of 

Belmont County, Ohio, as part of an area then called the Wheeling, WV-OH Area that EPA intended 

to designate nonattainment. Ohio responded by providing information in support of a recommendation 

not to include any portion of Belmont County in this nonattainment area. EPA agrees with this 

recommendation and is designating an area now called the Marshall WV nonattainment area that 

includes no portion of Ohio. As a result, this document is not discussing this area in detail, and the 

primary discussion of this area is in the TSD for West Virginia areas. A detailed review of the 

information provided by Ohio is provided in the response to comments document. 

C. Technical Analysis for the Steubenville, OH-WV Interstate Area 

Introduction 

This technical analysis for the Ohio portion of the Steubenville, OH-WV Interstate Area identifies the 

monitors that violate the 2010 SO2 NAAQS and evaluates nearby counties for contributions to SO2

 

1 More detailed information regarding the portions of the nonattainment areas within West Virginia and Kentucky are 

provided in technical support documents for these states.
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concentrations in the area. EPA has evaluated this county and nearby counties based on the evidence 

for the factors recommended in the March 24, 2011 EPA designation guidance. 

Ohio has recommended that four townships in Jefferson County, near the city of Steubenville, Ohio, be 

designated as nonattainment for the 2010 SO2 NAAQS. Ohio subsequently clarified its intent that 

Steubenville City is part of its recommended nonattainment area. West Virginia recommended that the 

Cross Creek Tax District in Brooke County, West Virginia, also be designated nonattainment. Brooke 

County is located across the Ohio River from Steubenville. The full analysis for the West Virginia 

portion of this area can be found in the TSD for West Virginia. EPA is combining these areas to form 

the Steubenville, OH-WV Interstate Area. Based on EPA's technical analysis described below, EPA is 

initially designating Cross Creek, Steubenville, Warren, and Wells Townships and Steubenville City in 

Jefferson County and the Cross Creek Tax District in Brooke County, West Virginia as nonattainment 

for the 2010 SO2 NAAQS. Areas and sources that we are not yet prepared to conclude are contributing 

to the monitored violations or to other possible violations are not included in this initial nonattainment 

area, and will be further addressed in a future round of final designations. Figure 5 shows a map of the 

nonattainment area and the monitor location.

Figure 5. Map of the Steubenville, OH-WV Interstate Nonattainment Area

Detailed Assessment

Air Quality Data 
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This factor considers SO2 air quality monitoring data for the monitors in Jefferson and Brooke

Counties. The SO2 NAAQS design values for these counties are shown in Table 6.

Table 6. Air Quality Data for the Steubenville, OH-WV Interstate Area (NEI08V3)

County

State 

Recommended 

Nonattainment?

Monitor Air Quality 

System ID Monitor Location

SO2 Design Value, 

2009 – 2011

(ppb)

Jefferson, OH Yes 39-081-0017 Steubenville, OH 109

Brooke, WV Yes 54-009-0005 Mahan Lane (Follansbee) 119

Brooke, WV Yes 54-009-0007 McKims 83

Brooke, WV Yes 54-009-0011 Marland Heights (Weirton) 174

Jefferson County shows a monitored violation of the 2010 SO2 NAAQS. Therefore, some area in this 

county must be designated nonattainment. The absence of a violating monitor alone is not a sufficient 

reason to eliminate nearby counties as candidates for nonattainment status. Additional monitors in 

Brooke County, West Virginia, are also showing violations of the 2010 SO2 NAAQS, as discussed in 

the West Virginia TSD. Based on evidence that violations are occurring in Jefferson County, Ohio, 

and Brooke County, West Virginia, EPA is initially designating a nonattainment area that includes the 

sources in the area that contribute to these monitored violations.

Emissions and Emissions-Related Data

Evidence of SO2 emissions in the vicinity of a violating monitor is an important factor for determining 

whether a nearby area is contributing to a monitored violation. For this factor, EPA considered county

emissions data for SO2 and data for sources within 50 kilometers of violating monitors. Ohio provided 

this data with respect to Ohio sources in its June 3, 2011 submittal. Ohio’s emissions data came from 

facility reports to the state, which were the basis for Ohio’s submittal to the 2008 NEI. EPA relied 

primarily on these data and corresponding West Virginia data for its analysis of Ohio’s SO2

designation recommendations.

Table 7 shows the emissions of SO2 in Ohio which may contribute to violations in and around the 

Steubenville, OH-WV Interstate Area. The county shown in bold contains the Ohio portion of the 

Steubenville, OH-WV Interstate Area nonattainment area for the 2010 SO2 NAAQS. 
14

Table 7. Ohio SO2 Emissions for the Steubenville, OH-WV Interstate Area

County

Facility 

Located in 

State 

Recommended 

Nonattainment

Area?

Facility Name

Facility Location/ 

Distance from 

Monitor (km)

Total SO2 Emissions 

(tons per year)

Jefferson

No FirstEnergy

W.H. Sammis Power Plant

Stratton, OH/18 102,197.0*

Yes American Electric 

Power/Buckeye Power 

Cardinal Power Plant

Brilliant, OH/13 33,317.0

Yes Severstal Wheeling, Inc Steubenville/ Mingo 

Junction, OH/5

700.0

Yes Severstal Wheeling, Inc Yorkville, OH/15 0.24

Yes Mingo Junction Energy 

Center

Mingo Junction, 

OH/5

82.0

No Titanium Metals Corp. Toronto, OH/9 0.20

Columbiana No Heritage – WTI, Inc East Liverpool, 

OH/30

3.60

Belmont No Severstal Wheeling, Inc. Martins Ferry, 

OH/28

0.06

Carroll No Summitville Tiles, Inc. Minerva, OH/33 7.0

* The W.H. Sammis plant has recently reduced its emissions pursuant to a consent decree. Data shown above is from the 

2008 NEI.

Parts of four counties in Ohio lie within 50 kilometers of the Jefferson County monitor. Columbiana 

County has one SO2 source, emitting 3.6 tons per year. The source is located 30 kilometers from the 

violating monitor in Jefferson County. The SO2 sources in Carroll County and Belmont County within 

50 kilometers are also very low in SO2 emissions, less than 10 tons per year, and are located at a 

similar distance. Based on the level of emissions from these sources and their distance from the 

violating Jefferson County monitor, EPA is not yet prepared to conclude that these sources contribute 

to the monitored violation or to other possible violations, and will further address these sources in a

future round of final designations. Most of the significant sources within Jefferson County are located 

in the townships that Ohio recommended be designated nonattainment. The exception is the 

FirstEnergy’s W.H. Sammis power plant, which is located 18 kilometers north of the Jefferson County 

monitor and a similar distance from the violating monitors in Brooke County, West Virginia. The 

W.H. Sammis power plant significantly reduced its emissions after installing pollution controls in 

2010. The Columbiana County SO2 monitor in East Liverpool, about 14 kilometers north of the power 

plant, has measured a noticeable drop in SO2 concentrations since 2010. Its SO2 design value (three 

year average of annual 99th percentile concentrations) was 117 ppb for 2007-2009, when the 2007 99th

percentile value was 128 ppb. For 2008-2010, the design value had fallen to 90 ppb, with a 99th

percentile value of 47 in 2010. For 2009-2011, the design value was 62 ppb, with a 99th percentile 

value of 27 ppb in 2011. While that monitor is in a different direction from the W.H. Sammis plant 

than the violating monitors being addressed here, this information provides suggestive evidence that 

the impact of the W.H. Sammis plant at the monitors in the Steubenville, OH-WV area that are 

monitoring violations has also probably declined significantly. Based on this information, considering 

the potential impact of the remaining emissions of this plant in light of the distance of the plant from 

the violating monitors, EPA is not yet prepared to conclude that the W.H. Sammis power plant is 

contributing to the violations at the Jefferson County monitor or the Brooke County monitors or to 

other possible violations, and will further address this source in a future round of final designations.
15

Emission Controls 

The emissions data used by EPA in this technical analysis and provided in Table 7 represent emissions 

levels taking into account any control strategies implemented on stationary sources in the area up to 

and including 2008. Ohio did not submit any additional information on actual emissions reductions 

resulting from controls put into place after 2008, but the EPA Clean Air Markets Division database 

indicates that the W.H. Sammis Power Plant has reduced its emissions significantly after installing 

pollution controls in 2010. For example, in 2011, the reported SO2 emissions were 4,202 tons. 

Meteorology (weather/transport patterns)

Evidence of source-receptor relationships between specific emissions sources and high SO2 values at 

violating monitors is another important factor in determining the appropriate contributing areas and the 

appropriate extent of the nonattainment area. As shown in Figure 6, winds are most frequently from 

the west and southwest directions. 

Figure 6: Wind Rose for Steubenville, OH-WV Interstate Area

Source: OEPA Software: WRPLOT-Lakes Environmental Software

The wind is more likely from the south than the north, so the much larger Cardinal Power Plant to the 

south of the monitors is more likely to affect air quality at the violating monitors than the smaller, 

further Sammis Power Plant to the north. 

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

The recommended nonattainment portion of Jefferson County lies along the Ohio River, in the 

foothills of the Appalachians. While the river valley can experience nighttime inversions and air flow 

into and out of the valley, the geographical and topographical features of the area are not considered to 

significantly limit air pollution transport. Therefore, this factor did not play a significant role in 

determining the nonattainment boundary. 
16

Jurisdictional Boundaries 

Once the geographic area associated with the area violating the SO2 standard and the nearby areas 

contributing to the monitored violations are determined, we considered existing jurisdictional 

boundaries for the purpose of providing a clearly defined legal boundary for carrying out the air quality 

planning and enforcement functions of the area. There are no current SO2 nonattainment areas in 

Jefferson County for the prior SO2 NAAQS. The recommended nonattainment area for the 2010 SO2

NAAQS for the Ohio portion of the Steubenville, OH-WV area consists of the four townships along 

the Ohio River in Jefferson County as well as Steubenville City, which contain SO2 sources that 

contribute to the monitored violations. The SO2 ambient air quality monitors within Ohio are also 

located within this area. Townships in Ohio have well established boundaries and EPA finds that they 

are a suitable administrative basis for defining Ohio’s nonattainment areas, in conjunction with city 

boundaries in selected cases. 

Other Relevant Information

In its April 12, 2012 recommendations, Ohio recommended a nonattainment area defined on the basis 

of townships, to include Steubenville Township but not separately to specify the inclusion of 

Steubenville City. EPA concurred with these recommendations based on an assumption that the 

contributing sources in Steubenville City were included in Steubenville Township. The map of EPA’s 

intended nonattainment area demonstrates EPA’s intent that this area, including the area within 

Steubenville City, be included in the nonattainment area. Upon further review, EPA believes that 

Steubenville City is defined as a separate administrative unit that is not part of Steubenville Township. 

EPA consulted with Ohio, and Ohio has clarified its intent that the area within the outer boundaries of 

the four listed townships be designated nonattainment, i.e. that Ohio recommended that Steubenville 

City as well as the four listed townships be designated nonattainment. EPA’s designation is consistent 

with this clarified recommendation.

Conclusion

A monitor in Jefferson County, OH shows a monitored violation of the SO2 NAAQS based on air 

quality data from 2009-2011. Additional monitors in Brooke County, West Virginia are also showing 

violations of the SO2 NAAQS, as discussed West Virginia TSD. After considering the factors 

described above, EPA is initially designating Cross Creek, Steubenville, Warren, and Wells Townships 

and Steubenville City in Jefferson County as the Ohio portion of the Steubenville, OH-WV interstate 

SO2 nonattainment area. EPA is combining this Ohio portion with the Cross Creek Tax District in

Brooke County in West Virginia to form a single bi-state nonattainment area. The area includes the 

violating monitors and nearby areas with sources that we can presently determine contribute to the 

violations of the 2010 SO2 NAAQS. EPA is not yet ready to conclude that the emissions from sources 

located outside the nonattainment boundary contribute to the monitored violations or to other possible 

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

and sources in Ohio not included in the nonattainment area designations addressed in this TSD.
17

D. Technical Analysis for the Campbell-Clermont, KY-OH Interstate Area

Introduction 

This technical analysis for the Ohio portion of the Campbell-Clermont, KY-OH interstate area 

identifies the monitor that violates the 2010 SO2 NAAQS and evaluates the adjacent Ohio counties for 

contributions to SO2 concentrations in the area. EPA has evaluated this county and nearby counties 

based on the evidence for the factors recommended in the March 24, 2011 EPA designations guidance.

Campbell County, Kentucky, is adjacent to and across the Ohio River from Hamilton and Clermont 

Counties, Ohio. The Campbell County monitor is located in Highland Heights, Kentucky, about 

11 kilometers south of Cincinnati, Ohio. The Campbell County monitor is violating the 2010 SO2

NAAQS for the 2009-2011 period. Because the Campbell County SO2 monitor was not violating the 

2010 SO2 NAAQS for 2008-2010, Kentucky did not include it in its June 2, 2011 SO2 designation 

recommendations. See EPA’s TSD for Kentucky. Ohio did not include a discussion of the Cincinnati 

area in its June 3, 2011 letter, since the SO2 monitors in that part of Ohio did not indicate a NAAQS 

violation. However, after reviewing emissions and meteorological data for the region surrounding the 

Campbell County monitor, EPA determined that one township in Clermont County, Ohio, and a 

portion of Campbell County, Kentucky, should be designated as nonattainment for the 2010 SO2

NAAQS, to form the Campbell-Clermont, KY-OH Interstate Area. EPA informed Ohio and Kentucky

of the intent to designate these areas on February 6, 2013. Kentucky responded on March 6, 2013, 

stating that Campbell County should not be included in the nonattainment area. Further discussion of 

Kentucky’s letter can be found in the Kentucky TSD. The partial county boundary for Campbell 

County includes the area bordered by KY Hwy 1566 from Ohio River to KY Hwy 9 (AA Highway) to 

the Southeast; KY Hwy 9 (AA Highway) from Hwy 1566 to I-275 to the Southwest; I-275 to Hwy 

2345 (John’s Hill Road), Hwy 2345 to US-27, US-27 to I-275, I-275 to Ohio River to the Northwest; 

and the Ohio River from I-275 to KY Hwy 1566 to the Northeast. EPA is initially designating this 

portion of Campbell County, Kentucky, and Pierce Township, Clermont County, Ohio, as the 

Campbell-Clermont, KY-OH nonattainment area for the 2010 SO2 NAAQS. Areas and sources that 

we are not yet prepared to conclude are contributing to the monitored violations or to other possible 

violations are not included in this initial nonattainment area, and will be further addressed in a future 

round of final designations. Figure 7 is a map of the Campbell-Clermont, KY-OH Interstate Area, 

showing the location of the air quality monitor.
18

Figure 7. Map of Campbell-Clermont, KY-OH Interstate Nonattainment Area. 

Detailed Assessment

Air Quality Data 

This factor considers SO2 air quality monitoring data and the 2009-2011 design value (in ppb) 

calculated for the air quality monitor in Campbell County. The 2010 SO2 NAAQS design value for

Campbell County is shown in Table 8. The nearest Ohio SO2 monitor is located in Hamilton County 

near Cleves, about 30 kilometers northwest of the Campbell County monitor. 

Table 8. Air Quality Data for Campbell County

County

State 

Recommended 

Nonattainment?

Monitor Air

Quality System 

ID

Monitor Location

SO2 Design 

Value, 

2009 - 2011

(ppb)

Campbell Co, KY No 21-037-3002 Highland Heights, KY 89

Hamilton Co, OH No 39-061-0010 Cleves, OH 69*

*The 2010 data were incomplete at this monitor.

Campbell County shows a monitored violation of the 2010 SO2 NAAQS. Therefore, some area in this 

county and possibly additional areas in surrounding counties must be designated nonattainment. The

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

candidates for nonattainment status. 

Emissions and Emissions-Related Data
19

Evidence of SO2 emissions in the vicinity of a violating monitor is an important factor for determining 

whether a nearby area is contributing to a monitored violation. For this factor, EPA considered county

emissions data for SO2 and data for sources within 50 kilometers of violating monitors. Duke 

Energy’s W. C. Beckjord Station, a coal-fired power plant, is likely to be the main Ohio source 

contributing to the violation at the Campbell County monitor. It is located 16 kilometers east of the 

monitor. The W.C. Beckjord Station emitted over 26,000 tons of SO2 in 2008 (NEI08V3), and more

recent data from EPA’s Clean Air Markets Division suggests that its SO2 emissions have increased 

significantly in more recent years. The W. C. Beckjord Station is located on the Ohio River in Pierce 

Township, near the town of New Richmond, Clermont County, Ohio. Duke Energy also operates the 

W. H. Zimmer Generating Station in Clermont County. This power plant emitted 16,000 tons of SO2

in 2008. The Zimmer Generating Station is located 27 kilometers from the Campbell County monitor. 

Based on its distance from the violating monitor and a meteorology analysis, EPA is not yet prepared 

to conclude that the Zimmer Generating Station contributes to the Campbell County violating 

monitor’s design value. We will further address this source in a future round of final designations. 

There are eight facilities in southern Hamilton County which are located to the north or northwest of 

the Campbell County monitor, at distances of 13 kilometers or more. Of the sources closest to the 

monitor, two emit more than 1,000 tons of SO2; the others emit 100-600 tons of SO2. Based on the 

distance of these sources from the violating monitor and a meteorology analysis, EPA is also not 

prepared to conclude that these sources are contributing to the monitored violation in Campbell 

County, and will likewise further address these sources in a future round of final designations. The 

largest facility in Hamilton County, Duke Energy’s Miami Fort Station, emits about 25,000 tons of 

SO2, but is located 30 kilometers west of the violating monitor. Given that distance and a 

meteorological analysis, EPA is not yet prepared to conclude that the the Miami Fort Station is 

contributing to violations at the Campbell County monitor, and will address this source in a future 

round of final designations. Therefore, within Ohio, EPA is including only Pierce Township in 

Clermont County, in which Duke Energy’s W. C. Beckjord Station is located, in the initial 

nonattainment area based on the monitored violation. EPA is designating Pierce Township in 

Clermont County nonattainment for the 2010 SO2 NAAQS and combining it with the nonattainment 

portion of Campbell County, Kentucky, to form the Campbell-Clermont, KY-OH interstate 

nonattainment area. 

Table 9 shows the total emissions of SO2 for potentially contributing sources emitting more than 100

tons per year of SO2 according to the 2008 NEI, in Hamilton and Clermont Counties, Ohio.
20

Table 9. Ohio SO2 Emissions for the Campbell-Clermont (KY-OH) Area (NEI08V3)

County

Facility Located in State 

Recommended 

Nonattainment Area?

Facility Name

Facility Location/ 

Distance from 

monitor (km)

Total SO2

Emissions 

(tons per year)

Hamilton

No Duke Energy Miami Fort Station North Bend/30 24,691.0

No DEGS of St. Bernard, LLC St. Bernard/17 2,005.0

No E.I. DuPont Fort Hill Plant North Bend/31 1,143.0

No University of Cincinnati Cincinnati/13 616.0

No INEOS ABS (USA) Corporation Addyston/24 472.0

No Emerald Performance Materials, 

LLC Cincinnati/27 306.0

No Rock-Tenn Converting Company Cincinnati/16 257.0

No Caraustar Mill Group, Inc Cincinnati/13 118.0

Clermont

No*

Duke Energy

W.C. Beckjord Station

New 

Richmond/16 26,404.0

No Duke Energy

W.H. Zimmer Generating Station Moscow/27 16,513.0

No ZF Batavia LLC (Ford) Batavia/31 118.0

*Facility is located in EPA-designated nonattainment area.

Emission Controls 

The emissions data used by EPA in this technical analysis and provided in Table 9 represent emissions 

levels taking into account any control strategies implemented on stationary sources in the area up to 

and including 2008. EPA has not received any additional information on emissions reductions 

resulting from controls put into place after 2008. However, ZF Batavia (Ford) closed in late 2008. 

Also, The Beckjord Station has significantly increased its emissions since 2008. EPA Clean Air 

Markets Division information for 2010-2012 indicates that the W.C. Beckjord Station has increased its 

SO2 emissions to around 70,000 tons per year in recent years.
21

Meteorology (weather/transport patterns)

Evidence of source-receptor relationships between specific emissions sources and high SO2 values at 

violating monitors is another important factor in determining the appropriate contributing areas and the 

appropriate extent of the initial nonattainment area. EPA analyzed the wind data in the vicinity of the 

Campbell County monitor in an effort to determine which areas outside Campbell County should be 

included in the designated nonattainment area. Wind data were considered from several 

meteorological measurement sites, including an air quality monitoring site in Cincinnati, Ohio and two 

airports in the Cincinnati area. The data suggested that Clermont County SO2 sources, such as the 

W.C. Beckjord Station power plant, could contribute to the SO2 NAAQS violation at the Campbell 

County monitor. Data from Cincinnati/Northern Kentucky International Airport indicated that during 

the hours when the monitor showed exceedances of the 2010 SO2 NAAQS, the wind was blowing

from the east and east-southeast. This meteorological data is expected to be generally representative of 

Campbell County. EPA also used the HYSPLIT Trajectory Model to create wind trajectories showing 

the path that winds may have followed over several hours. This model uses a forecast meteorological 

dataset instead of surface wind observations. The trajectories indicated that airflow tended to come 

from the east during the hours with monitored SO2 NAAQS exceedances, which supports the inclusion 

of a portion of Campbell County in the nonattainment area, and is not supportive of the inclusion of 

Hamilton County sources to the north of the monitor. Full details of this meteorological analysis can 

be found in the TSD for Kentucky. 

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

Clermont County borders the Ohio River. While the river valley can experience nighttime inversions 

and air flow into and out of the valley, the geographical and topographical features of the area are not 

considered to significantly limit air pollution transport. Therefore, this factor did not play a significant 

role in determining the nonattainment boundary. 

Jurisdictional Boundaries 

Once the geographic area associated with the area violating the SO2 standard and the nearby areas 

contributing to the monitored violations are determined, we considered existing jurisdictional 

boundaries for the purpose of providing a clearly defined legal boundary for carrying out the air quality 

planning and enforcement functions of the area. Clermont County is not currently nonattainment for 

SO2 for the prior SO2 NAAQS. EPA is designating Pierce Township in Clermont County as 

nonattainment for the 2010 SO2 NAAQS , because it contains a large SO2 source which contributes to 

high concentrations at the Campbell County, Kentucky ambient air quality monitor. Townships in 

Ohio have well established boundaries and EPA finds that they are a suitable administrative basis for 

defining Ohio’s nonattainment areas.

Other Relevant Information

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

this area.

Conclusion

The air quality monitor in Campbell County, Kentucky is violating the 2010 SO2 NAAQS based on 

2009-2011 data. Therefore, some area in this county and possibly additional areas in surrounding 
22

counties must be initially designated nonattainment. After considering the factors described above, 

EPA is initially designating Pierce Township in Clermont County in Ohio and a portion of Campbell 

County, Kentucky as the Campbell-Clermont, KY-OH interstate nonattainment area. EPA finds that 

Pierce Township contains a large SO2 source that contributes to high concentrations at the Campbell 

County, Kentucky monitor. The specific boundaries of the Campbell County, Kentucky portion of this 

area are described above and in the Kentucky TSD. EPA is not yet ready to conclude that the 

emissions from sources located outside the nonattainment boundary contribute to the monitored 

violation or to other possible violations. In a subsequent round of designations, we will make final

designation decisions for areas and sources in Ohio not included in the nonattainment area designations 

addressed in this TSD.