1 Technical Support Document

Ohio Area Designations For the

2010 SO 2 Primary National Ambient Air Quality Standard

Summary

Pursuant to section 1 07(d) of the Clean Air Act (CAA) , EPA must designate areas as either

“nonattainment

, ” “attainment

, ” or “ unclassifiable” for the 2010 one

- hour sulfur dioxide (SO 2 ) 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 1 3 , 2013 and April 2 6 , 2013

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

that EPA i s 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 N onattainment Designation of Areas/Counties

Lake County , Ohio Lake County Nonattainment Nonattainment
Muskingum River , Ohio Morgan County (part ial ): Center Township Washington County (part ial ): Waterford Township Nonattainment

Nonattainment Nonattainment

Nonattainment

Steubenville OH

- WV Jefferson County, OH (part ial ): 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 (part ial ) (See KY TSD) Clermont County, OH (part ial ): Pierce Township Unclassifiable *

Unclassifiable Nonattainment

Nonattainment

*Recommendation by West Virginia or Kentuc ky; Ohio made no recommendation outside Ohio.2 Background

On June 3, 2010, EPA revised the primary SO 2 NAAQS (75 FR 35520, published on June 22, 2010). EPA revised the primary SO 2 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 99 th 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 SO 2

. EPA is revoking the two prior primary standards of 140 ppb evaluated over 24 hours, and 30 ppb evaluated over an entire year

because the y 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 SO 2 has not bee n revised, so EPA is not designating areas in this process on the basis of the secondary standard.

EPA’s SO 2 Designation Approach

Section 107(d) of the CAA provides that not later than one year after promulgation of a new or revised NAAQS, state Govern ors 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 promulgat ing the designations that it deems appropriate

. If a s tate s or tribe disagreed with EPA’s intended designations, i t 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

- relate d data (location of sources and potential contribution to ambient SO 2 concentrations); 3) meteorology (weather/transport patterns); 4) geography/topography (mountain ranges or other air basin boundaries); and 5) jurisdictional boundaries (e.g., counties, a ir 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, 201 1, 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 tec hnical analysis of the recommendations regarding areas with monitored violations submitted by Ohio for designations for the

one

- hour SO 2 standard and any modifications from these recommendations.3

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 SO 2 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 designate d as nonattainment.

3 ) Violating monitor

– an ambient air monitor meeting all methods, quality a ssurance and siting criteria and requirements whose valid design value exceed s 75 ppb, as described in Appendix T of 40 CFR part 50.

4 ) 20 10 SO 2 NAAQS

– The NAAQS for SO 2 promulgated in 20 10

. This NAAQS is 75 ppb, b ased 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 compariso n to the level of the NAAQS , indicates whether the area is violating the NAAQS

.

A. Technical A nalysis for the Lake County , O hio Area

Introduction

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

SO 2 NAAQS, and evaluates nearby counties for contributions to SO 2 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 s guidance

. This county is listed above in Table 1.

Ohio recommended that Lake County be designated as nonattainment for the 2010 SO 2 NAAQS based on monitored air quality data from 2008

- 2010. EPA agrees with Ohio’s recommendation. EPA i s initially designating Lak e County , Ohio as nonattainment for the 2010 SO 2 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.4

Figure 1. Map of Lake County , O hio Nonattainment Area.

Detailed Assessment

Air Quality Data

This factor considers the SO 2 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

200 9

- 2011 period. The 2010 SO 2 NAAQS design value for Lake Co unty 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 SO 2 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 ha s the highest 2009

- 2011 design value in the area

. * Data for 2009 is incomplete

.

Lake C ounty shows a violation of the 2010 SO 2 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 st atus.5

Emissions and Emissions

- Related Data

Evidence of SO 2 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 count y emission s data for SO 2 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 th e 2008 National Emissions Inventory ( NEI ) . EPA relied primarily on this data for its analysis of Ohio’s SO 2 designation recommendations.

Table 3 shows the annual emissions of SO 2 (given in tons per year) for violating and potentially

contribu ting countie s in and around Lake County, and sources emitting greater than 100 t ons per year of SO 2 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 monitor s. 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 designation s.

Table 3

. SO 2 Emissions for the Lake County Area (NEI08 V3 )

County Facility

Located in

State

Recommended

Nonattainment

Area ? Facility Name Facility Location /

Distance from violating monitor (km) Facility Total SO 2

Emissions (tons per year)

Lake Yes Eastlake Power Plant Willoughby /17 505 2 1.0

Yes Painesville Municipal

Electric Plant Painesville /1 721 2 .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 /4 4 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 2.96

Emission C

ontrols

The emissions data used by EPA in this technical analysis and provided in Table 3 represent emiss ions levels taking into account any control strategies implemente d 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 S O 2 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. T herefore, 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, freque nt wind directions.

Geography/

T opography (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 considere d to significantly limit air pollution transport. Therefore, this factor did not play a significant role in determining the nonattainment boundary.7

Jurisdictional B oundaries

Once the geographic area associated with the area violating the SO 2 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 SO 2 nonattainment areas in Lake County and the surrounding region for the prior SO2 NAAQS . The recommended nonattainment area is Lake County. The SO 2 sources which are likely to be the main contributors to the violating monitor’s design value are located within this county . The violating SO 2 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 boundar ies

.

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

nonatta inment area for the 2010 SO 2 NAAQS

. An air quality monitor in Lake County show s violation s of the 20 10 SO 2 NAAQS . Lake County facilities emit over 58,000 tons per year of SO 2 (based on 2008 data)

. The large facilities in the neighboring counties are 40 kilometers or more from

the violating Lake Co unty 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 encompass es 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 M uskingum River , OH Area

Introduction

This technical analysis for the Muskingum River A rea identifies the monitor that violate s the 2010 SO 2 NAAQS

, and evaluates nearby counties for contributions to SO 2 concentrations in the area. EPA has

evaluated this county and nearby counties based on the evidence for the factors recommended in t he March 24, 2011 EPA designation s guida nce.

Ohio recommended that Center Township in Morgan County and Waterford Township in Washington County be designated as nonattainment for the 2010 SO 2 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 contribu ting to the monitored violations or to other possible violations are not included in this initial nonattainment area,8

and will be further addressed in a future round of final designations. Figure 3 shows a map of the nonattainment area including the monit or location.

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

Detailed Assessment

Air Quality Data

This factor considers SO 2 air quality monitoring data and the design value (in ppb ) calculated for the air quality monitor in Morgan C ount y for 2009

- 2011

. The 2010 SO 2 NAAQS design value for Morgan

C ounty 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 SO 2 Design Value,

200 9

- 20 11 ( ppb )
Morgan Yes 39

- 115

- 0004 Hackney, OH 180

Morgan County show s a monitored violation of the 2010 SO 2 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.9

Emissions and Emissions

- Related Data

Evidence of SO 2 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 count y emission s data for SO 2 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 SO 2 designation r ecommendations.

Table 5 shows the annual emissions of SO 2 (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 SO 2 according to the 2008 NEI

. There are no such sources of SO 2 within Morgan County , except that a portion of the Muskingum River power plant, which is generally inventori ed as part of Washington County , is physically located in Morgan County . Ohio considered all SO 2 sources within

5 0 kilometers of the violating monitor. Listed below are the sources which are considered most likely to impact the Morgan County SO 2 monitor ’s design value . They are all located within 5

to 12 kilometers of the monitor. There are two additional sources t hat 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 Cou nty 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

. SO 2 Emissions for the Muskingum River Area (NEI08 V3 )

County Facility

Located in

State

Recommended

Nonattainment

Area ? Facility Name Facility

Location /

Distance from

monitor Facility total

SO 2 Emissions (tons per year)

Washington Yes Muskingum River Power

Plant Waterford /5 133,3 38. 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 C

ontrols

The emissions data used by EPA in this technical analysis and provided in Table 5 represent emiss ions levels taking into account any control strategies implemente d 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 SO 2 values at violating monitors is another important factor in determining the appropriate contributing areas and the10

appropriate extent of the nonattainment area. Shown in Figure 4

, w inds in this general area tend to

b low most often from the southwest ern 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 t he monitor, which is a frequent wind

direction.

Geography/

T opography (mountain ranges or other air basin boundaries)

The Muskingum River recommended nonattainment area does not have any geographical or topographical barr iers significantly limiting air pollution transport. Therefore, this factor did not play a significant role in determining the nonattainment boundary.

Jurisdictional B oundaries

Once the geographic area associated with the area violating the SO 2 standard and the nearby areas

contribut ing 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 cur rent SO 2 nonattainment areas in Morgan and Washington Counties under the prior NAAQS . The state recommended Muskingum

River nonattainment area for the 2010 SO 2 NAAQS consists of the two adjacent townships in Morgan and Washington Counties which contain th e SO 2 sources contributing to the monitored violations. The

SO 2 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.11

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 i s initially designating Center Township in Morgan County and Waterford Township in Washington County as the Muskingum River nonattainment area for the 2010 SO 2 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 SO 2 monitor ’s design

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

. Therefore, EPA fin d s that t he boundaries described herein encompass the appropriate initial

nonattainment area for the 20 10 SO 2 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. T he

Steubenville

, OH

- WV Interstate Area and the Campbell

- Clermont

, KY

- OH Interstate A rea 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 SO 2 sources and the monitors are such that Ohio , W est 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 t hese 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 nona ttainment. 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 nonattain ment 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

monitor s that violate the 2010 SO 2 NAAQS and evaluates nearby counties for contributions to SO 2

1 More detaile d information regarding the portions of the nonattainment areas within West Virginia and Kentucky are provided in technical support documents for these states.12

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

.

O hio has recommended that four townships in Jefferson County, near the city of Steubenville, Ohio, be designated as nonattainment for the 2010 SO 2 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 th is 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 SO 2 NAAQS. Areas and sources that we are not yet prepared to conclude are contributing

to the monitored viol ations 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 Data13

This factor considers SO 2 air quality monitoring data for the monitor s in Jefferson and Brooke

Counties. The SO 2 NAAQS design value s for these counties are shown in Table 6

.

Table 6 . Air Quality Data for the Steubenville

, OH

- WV Interstate A rea (NEI08 V3 )

County State

Recommended

N onattainment? Monitor Air Quality

System ID Monitor Location SO 2 Design Value,

20 0 9

– 201 1 ( 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 SO 2 NAAQS. Therefore

, some area in this

c ounty 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 Count y, West Virginia

, are also showing violations of the 2010 SO 2 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 i s initially designating a nonattainm ent area that includes the

sources in the area that contribute to these monitored violations.

Emissions and Emissions

- Related Data

Evidence of SO 2 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 count y emission s data for SO 2 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 correspon ding West Virginia data for its analysis of Ohio’s SO 2 designation recommendations.

Table 7 shows the emissions of SO 2 in Ohio which may contribut e to violations in and around the

Steubenville

, OH

- WV Interstate Area. The co unt y shown in bold contains the Ohio portion of the

Steubenville

, OH

- WV Interstate Area nonattainment area for the 2010 SO 2 NAAQS

.14

Table 7

. Ohio SO 2 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 SO 2 Emissions

(tons per year)

Jefferson No FirstEnergy

W.H. S ammis Power Plant Stratton, OH /18 102,19 7 .0 *

Yes American Electric

Power/Buckeye Power

Cardinal Power Plant Brilliant, OH /13 33,3 17 .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 SO 2 source , emitting 3.6 tons per year

. The source is located 30 kilometers from the violating monitor in Jefferson County

. The SO 2 source s in Carroll County and Belmont County within

50 kilometers are also very low in SO 2 emissions, less than 10 tons per year

, and are located at a
similar distance

. Based on the level of emissi ons 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 p ower p lant, 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. T he Columbia na County SO 2 monitor in East Liverpool

, about 14 kilometers north of the power plant , has measured a noticeable drop in SO 2 concentrations since 2010. Its SO 2 design value (three year average of annual 99 th percentile concentrations) was 117 ppb for 2007

- 2009, when the 2007 99 th
percentile value was 128 ppb. For 2008

- 2010, the design value had fallen to 90 ppb, with a 99 th
percentile value of 47 in 2010. For 2009

- 2011, th e design value was 62 ppb, with a 99 th percentile value of 27 ppb in 2011. While t hat 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 t he W.H. Sammis power plant is contributing to the violation s at the Jefferson County monitor or the Brooke County monitors or to other possible violations, and w ill further address this source in a future round of final desig nations

.15

Emission C

ontrols

The emissions data used by EPA in this technical analysis and provided in Table 7 represent emiss ions levels taking into account any control strategies implemente d on stationary sources in the area up to and including 2008

. O hio 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 significant ly after installing pollution controls in 2010

. For example, in 2011, the reported SO 2 emissions were 4,202 tons.

Meteorology (weather/transport patterns)

Evidence of source

- receptor relationships between specific emissions sources and high SO 2 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 dire ctions.

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/

T opography (mountain ranges or other air basin boundaries)

The recommen ded 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 B oundaries

Once the geographic area associated with the area violating the SO 2 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 pl anning and enforcement functions of the area. There are no current SO 2 nonattainment areas in Jefferson County for the prior SO 2 NAAQS . The recommended nonattainment area for the 2010 SO 2 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 SO 2 sources that

contribut e to the monitored violations. The SO 2 ambient air quality monitors within Ohio are also

located within thi s 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 Apr il 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 a ssumption 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 non attainment 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 bo undaries 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.

Con clusion

A monitor in Jefferson County, OH shows a monitored violation of the SO 2 NAAQS based on air quality data from 2009

- 2011 . Additional monitors in Brooke C ounty, West Virginia are also showing

violations of the SO 2 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

, O H

- WV i nterstate
SO 2 nonattainment area

. EPA i s combin ing this Ohio portion with the Cross Creek Tax District in

Brooke Count y in West Virginia t o form a single bi

- state nonattainment area

. T he area includes the violating monitors and nearby areas with so urces that we can presently determine contribute to the

violations of the 20 10 SO 2 NAAQS

. EPA is not yet ready to conclude that the emissions from sources

located outside the nonattainment boundary contribute to the monitored violation s 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 i nterstate area
i dentifies the monitor that violate s the 2010 SO 2 NAAQS and evaluates the adjacent Ohio counties for

contributions to SO 2 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 s guidance

.

Campbell County, Kentucky, is adjacent to a nd 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 i s violating the 2010 SO 2 NAAQS for the 2009

- 2011 period. Because the Campbell County SO 2 monitor was not violating the

2010 SO 2 NAAQS for 2008

- 2010, Kentucky did not include it in its June 2, 2011 SO 2 designation

recommendations. See EPA’s TSD for Kentucky. Ohio did not includ e a discussion of the Cincinnati area in its June 3, 2011 letter, since the SO 2 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 mon itor, EPA determined that one township in Clermont County

, Ohio , and a portion of Campbell County, Kentucky, should be designated as nonattainment for the 2010 SO 2 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. Th e 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 Camp bell

- Clermont

, KY

- OH nonattainment area for the 2010 SO 2 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, a nd 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 SO 2 air quality monitoring data and the 200 9

- 20 1 1 design value (in ppb )

calculated for the air quality monitor in Campbell County. The 2010 SO 2 NAAQS design value for Campbell C ounty is shown in Table 8

. The nearest Ohio SO 2 monitor is located in Hamilton County

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

Table 8 . Air Quality Data for Campbell County

County State

Recommended

Nonat tainment? Monitor Air

Quality System

ID Monitor Location SO 2 Design Value,

200 9

- 20 11 ( ppb )
Campbell Co, K Y No 21

- 037

- 3002 Highland Heights, KY 89

Hamilton Co, OH No 39

- 061

- 0010 Cleves, OH 69 *

* The 20 10 data were incomplete at this monitor.

Campbell County shows a monitored violation of the 2010 SO 2 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 Data19

Evidence of SO 2 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 count y emission s data for SO 2 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 SO 2 in 2008 ( NEI08V3 ) , and more recent data from EPA’s Clean Air Markets Division suggests that its SO 2 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 SO 2 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 t h e sources closest to the

monitor

, two emit more than 1

, 000 tons of SO 2 ; the others emit 100

- 600 tons of SO 2

. Based on the distance of these sources from the violating monitor and a meteorology analysis , EPA is also not prepared to conclude that these sourc es 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

SO 2 , 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 th e monitored violation

. EPA is designating Pierce Township in Clermont County n onattainment for the 2010 SO 2 NAAQS and combin ing it with the nonattainment portion of Campbell County, Kentucky

, to form the Campbell

- Clermont

, KY

- OH i nterstate

n onattainment a rea.

Table 9 shows the total emissions of SO 2 f or potentially contributing sources emitting more than 100

ton s per year of SO 2 according to the 2008 NEI

, in Hamilton and Clermont Counties, Ohio

.20

Table 9

. Ohio SO 2 Emissions for the Campbell

- Clermont (KY

- OH ) Area (NEI08 V3 )

County Facility Located in State

Recommended

Nonattainment Area ? Facility Name Facility Location /

Distance from monitor (km) Total SO 2

Emissions (tons per year)

Hamilton No Duke Energy Miami Fort Station North Bend /30 24

, 69 1 .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

, 51 3 .0

No ZF Batavia LLC (Ford) Batavia /31 118.0
*Facility is located in EPA

- designated nonattainment area.

Emission C

ontrols

The emissions data used by EPA in this technical analysis and provided in Table 9 represent emiss ions levels taking into account any control strategies implemente d 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 Beckj o rd Station has significantly increased its emissions since 2008. EPA Clean Air

Markets Division information for 2010

- 201 2 indicates that the W.C. Beckjord Station has increased its

SO 2 emiss ions 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 SO 2 values at violating monitors is another important factor in determinin g 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 wh ich 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 suggest ed that Clermont County SO 2 sources, such as the

W.C. Bec kjord Station power plant

, could contribute to the SO 2 NAAQS violation at the Campbell County monitor

. Data from Cincinnati /Northern Kentucky International A irport indicated that during

the hours when the monitor showed excee dances of the 2010 SO 2 NAAQS , the wind was blowing

f rom the east and east

- southeast. This meteorological data is expected to be generally representative of Campbell County. EPA also used t he HYSPLIT Trajectory Model to create w i nd trajectories showing

th e 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 SO 2 NAAQS exceedances , which support s 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/

T opography (mountain ranges or other air basin boundaries)

Clermont Count y border s 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 no t play a significant role in determining the nonattainment boundary.

Jurisdictional B oundaries

Once the geographic area associated with the area violating the SO 2 standard and the nearby areas contributing to the monitored violations are determined, w e 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 Count y is not currently nonattainment for

SO 2 for the p rior SO 2 NAAQS

. EPA is designating Pierce Township in Clermont Count y as nonattainment for the 2010 SO 2 NAAQS

, because it contains a large SO 2 source which contribute s 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 nonat tainment area boundary for

this area.

Conclusion

The air quality monitor in Campbell County , Kentucky i s violating the 2010 SO 2 NAAQS based on

2009

- 2011 data

. Therefore

, some area in this county and possibly additional areas in surrounding22

counties must be initially designated nonattainment

. After consideri ng the factors descr ibed above

, EPA is initially designating Pierce Township in Clermont Count y in Ohio and a portion of Campbell County, Kentucky as the Campbell

- Clermont

, KY

- OH i nterstate n onatta inment a rea

. EPA finds that Pierce Township contains a large SO 2 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.