State Of Ohio 2010 Revised Sulfur Dioxide 

National Ambient Air Quality Standard

Recommended Source Area Designation:

General James M. Gavin and Kyger Creek

Station Power Plants

Prepared by:

Ohio Environmental Protection Agency

Division of Air Pollution Control

September, 2015
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TABLE OF CONTENTS

CHAPTER ONE: ............................................................................................................. 1

General Discussion ......................................................................................................... 1

History...................................................................................................................... 1

Requirements........................................................................................................... 1

Ohio EPA’s Approach ..................................................................................................... 2

Factor 1: Dispersion Modeling.............................................................................. 3

Factor 2: Emissions Data ..................................................................................... 3

Factor 3: Meteorology .......................................................................................... 4

Factor 4: Topography and Land Use/Land Cover................................................ 5

Factor 5: Jurisdictional Boundaries ...................................................................... 5

CHAPTER TWO: ............................................................................................................ 6

Analysis........................................................................................................................... 6

Discussion:............................................................................................................... 6

Factor 1: Dispersion Modeling.............................................................................. 6

Factor 2: Emissions.............................................................................................. 9

Factor 3: Meteorology ........................................................................................ 11

Factor 4: Topography and Land Use/Land Cover.............................................. 14

Factor 5: Jurisdictional Boundaries .................................................................... 14

APPENDICES

Appendix A: Dispersion Modeling Analysis for General James M. Gavin Source Area

As referenced in Appendix A:

Appendix B: Emissions Determination: General James M. Gavin and Kyger 

Creek Station

Appendix C: Model Performance Evaluation

Appendix D: Questions from the States and Answers from Region 5 on Designation 

Modeling- June 3, 2015

Appendix E: Background Analysis

Appendix F: Modeling Protocol

As referenced in Appendix F:

Appendix G: Questions from Indiana Department of Environmental Management 

on the Consent Decree “Down Payment” modeling and answers from EPA 

Region 5

Appendix H: U.S. EPA AQS Design Value Report

Appendix I: Appalachian Power Phillip Sporn Shutdown Notification
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State Of Ohio 2010 Revised Sulfur Dioxide National Ambient Air Quality 

Standard

Recommended Designation:

General James M. Gavin and Kyger Creek Station Power Plants

CHAPTER ONE: 

General Discussion

History

The United States Environmental Protection Agency (U.S. EPA) promulgated

the revised National Ambient Air Quality Standard (NAAQS) for sulfur dioxide 

(SO2) on June 2, 2010. U.S. EPA replaced the 24-hour and annual standards 

with a new short-term one-hour standard of 75 parts per billion (ppb). The new 

one-hour SO2 standard was published on June 22, 2010 (75 FR 35520) and 

became effective on August 23, 2010. The standard is based on the three-year 

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

concentrations.

On August 15, 2013, U.S. EPA published (78 FR 47191) the initial SO2

nonattainment area designations for the one-hour SO2 standard across the 

country (effective October 4, 2013). On March 2, 2015, the U.S. District Court 

for the Northern District of California accepted as an enforceable order an 

agreement between the U.S. EPA and Sierra Club and the Natural Resources 

Defense Council to resolve litigation concerning the deadline for completing 

designations. The court’s order directs U.S. EPA to complete designations in 

three steps: the first by July 2, 2016; the second by December 31, 2017 and the 

third by December 31, 2020. As part of the first round of designations, U.S. EPA 

has identified areas with newly monitored violations of the standard, or areas 

that contain stationary sources that emitted more than 16,000 tons of SO2 in 

2012 or emitted more than 2,600 tons of SO2 and had an emission rate of at 

least 0.45 lbs SO2/MMBtu in 2012. The U.S. EPA has identified two facilities in 

Ohio as meeting one or more of the emissions thresholds: the General James 

M. Gavin Plant and the W.H. Zimmer Generating Station. Ohio EPA must 

submit designation recommendations to U.S. EPA by September 18, 2015.

Requirements

Pursuant to section 107(d) of the Clean Air Act (CAA), U.S. EPA must initially 

designate areas as either “unclassifiable”, “attainment”, or “nonattainment” for 

the 2010 one-hour SO2 standard. Since the original 2011 state submittals of 

designation recommendations and pursuant to the March 2, 2015 court order, 
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new information may be relevant for future designations. CAA Section 107(d) 

does not require states to submit updated recommendations. However, U.S. 

EPA will consider such information. For the round of designations to be 

completed by July 2, 2016, U.S. EPA requests that states submit updated 

recommendations and supporting information for consideration by September 

18, 2015. If U.S. EPA intends to modify any state’s designation 

recommendation, original or updated, the state will be notified no later than 120 

days prior to promulgating the final designations. For the designations due to be 

promulgated on or before July 2, 2016, this notification will occur no later than 

March 2, 2016. Although not required by statute, U.S. EPA will provide a 30-day 

public comment period immediately following issuance of the 120-day letters.

Section 107(d)(1) of the CAA defines an area as “nonattainment” if it is violating 

the NAAQS or if it is contributing to a violation in a nearby area. The first step in 

making designation decisions is to identify areas for which monitoring or 

appropriate modeling information indicate a violation of the NAAQS. U.S. EPA 

may designate an area as attainment if it is clear that that it meets the SO2

NAAQS and does not contribute to a violation in a nearby area.

U.S. EPA’s Data Requirements Rule for the 2010 1-Hour Sulfur Dioxide (SO2) 

Primary National Ambient Air Quality Standard (NAAQS); Final Rule (80 FR 

51051), herein referred to as the Data Requirements Rule, references the

December 2013 Draft SO2 NAAQS Designations Modeling Technical Assistance 

Document. This document indicates that the purpose of the modeling is to 

assess actual, current air quality and that those recommendations could include 

modeling the source area as attaining the standard. Areas designated as 

unclassifiable or attainment may be subject to additional and continued analysis 

to assess attainment over time. 

Ohio EPA’s Approach

This submittal is Ohio’s recommendation for the designation of the area 

surrounding the General James M. Gavin Power Plant located in Gallia County, 

Ohio. This facility was identified by U.S. EPA as meeting the criteria established 

in the March 2, 2015 court order. In accordance with U.S. EPA’s final rule, and a 

March 20, 2015 memorandum Updated Guidance for Area Designations for the 

2010 Primary Sulfur Dioxide National Ambient Air Quality Standard, the starting 

point for the area designations would be the county boundary associated with a

violation or around the SO2 source(s) in question, unless additional information 

is provided to U.S. EPA demonstrating a different boundary is appropriate. U.S. 

EPA’s SO2 Designation Guidance states that U.S. EPA generally believes that in 

the absence of other relevant information, it is appropriate to use county 

boundaries to define nonattainment areas, but they recognize that the five-factor 

analysis and other information may support designating only a portion of a 
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county as nonattainment. U.S. EPA states that modeling could be used to 

address several of these factors simultaneously. Ohio used the five-factor 

analysis approach and conducted additional modeling analysis as a part of this 

submittal. While using this approach, the SO2 Designation Guidance states this 

analysis should show that: 1) violations are not occurring in nearby portions that 

are excluded from the designation area; and 2) the excluded portions do not 

contain emission sources that contribute to the monitored or modeled violations, 

if observed.

The following summarizes the major factors included in Ohio’s analysis for the 

designation recommendation for the area surrounding the General James M.

Gavin Power Plant. Specifically, Ohio has used the five factor analysis 

approach, including refined dispersion modeling, as recommended in the SO2 

Designation Guidance, to support the boundary recommendation. Ohio

understands, based on the both the December 2013 Draft SO2 NAAQS 

Designations Modeling Technical Assistance Document and the March 20, 2015 

memorandum, that dispersion modeling accounts simultaneously for multiple 

elements of the five-factor analysis. As such, Ohio believes that the modeling 

analysis presented in Appendix A and summarized in this document should 

carry significant weight in the designation process. Where appropriate, Ohio is 

providing additional supporting information with respect to the five-factor 

designation approach.

Factor 1: Dispersion Modeling and Air Quality Data

Ohio conducted a refined dispersion modeling analysis following the guidance 

issued by U.S. EPA in the December 2013 Draft SO2 NAAQS Designations 

Modeling Technical Assistance Document, the March 20 memorandum, and the 

proposed Data Requirements Rule. The modeling analysis was based on 2012 

to 2014 actual emissions from the General James M. Gavin Power Plant and 

representative meteorological data from the same period. In addition to the 

General James M. Gavin Power Plant, Ohio simultaneously modeled actual 

emissions from Kyger Creek Station1,located to the south-west of the General 

James M. Gavin Power plant approximately 2.5 kilometers distant, over the 

same period. The methodology and results of the analysis are provided in 

Appendix A. Evaluation of model performance against air quality monitoring 

data is provided in Appendix C. Ohio also examined air quality monitoring data 

for relevant monitors near the General James M. Gavin source area. 

Factor 2: Emissions Data

 

1 Ohio EPA intends this submittal to fulfill the future requirements for monitoring or modeling of Kyger 

Creek Power State per U.S,. EPA’s final Data Requirements Rule.
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Emissions of SO2 for 2014 were determined from Ohio EPA’s Fee Emission 

Reports (FERs) which are the basis for Ohio’s 2014 NEI submittal. Emissions 

data for nearby sources in West Virginia were provided by the West Virginia 

Department of Environmental Protection. Tables identified in this analysis show

stationary sources with reported SO2 emissions in tons per year (TPY) at the 

facility level within each county relevant to the area around the General James 

M. Gavin facility. U.S. EPA’s Designations Modeling Technical Assistance 

Document suggests sources greater than the thresholds established under the

Data Requirements Rule located within 50 kilometers of the General James M. 

Gavin facility should be considered in the analysis of emissions data. Further, 

U.S. EPA Region 5 indicated to the Region 5 states that sources retired prior to 

the promulgation of a designation for a particular area do not need to be 

modeled. (Appendix D) This is consistent with the language of the Data 

Requirements Rule. Therefore, Ohio will consider the reduction in SO2

emissions due to retirements as part of its recommended designation, if 

applicable. In addition to the emissions from sources meeting the above criteria, 

the impact of the General James M. Gavin Power Plant and Kyger Creek Station 

are directly modeled as a part of Ohio’s designation recommendation analysis. 

Emissions data for both facilities were provided to Ohio EPA by American 

Electric Power. 

Factor 3: Meteorology

The meteorology review looks at wind data gathered at stations in and near Ohio 

by the National Weather Service (NWS). Information presented under this 

factor is indicative of annual average winds. These data may also suggest that 

emissions originating from some directions may be more prone to contribute 

than emissions in other directions. 

Ohio is located in what is meteorologically termed the Mid-Latitudes. For 

pollutant dispersion, the most important meteorological parameter is wind speed 

and wind direction. In this region, surface weather systems predominantly 

travel from west to east, guided by either the sub-tropical or polar jet streams. 

The resulting surface transport winds associated with these systems will 

generally have a western component with additional southern components in the 

summer and northern components in the winter, although, on any given day, 

winds can blow from any direction. Discussions regarding this factor will show 

representative wind roses for the source area and SO2 sources surrounding the 

General James M. Gavin facility.

 

The major geographic feature affecting winds in the area surrounding the 

General James M. Gavin facility is the hilly terrain and the Ohio River valley. 

This area has significant forested areas which modify the surface roughness 

lengths and can impact wind speed and wind direction. The Huntington airport 
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wind roses best illustrate the range of wind directions and wind speeds 

associated with this area.

A significant portion of this factor is accounted for by the dispersion modeling 

analysis conducted for this area. The AERSURFACE preprocessor component 

of the AERMOD model accounts for land use and its impact on surface 

roughness lengths, albedo, and Bowen ratio. The meteorological inputs to 

AERMOD itself are taken from measurements at the Huntington airport. 

Factor 4: Topography and Land Use/Land Cover

The topography and land use/land cover analysis looks at physical features and 

land use or land cover that might have an effect on the airshed and, therefore, 

the distribution of pollutants over an area. The General James M. Gavin Power 

Plant is located in the Ohio River valley, and therefore some portions of the area 

may experience inversions. However, the geographical and topographical 

features of the area are not likely to limit or impact the transport of SO2 in a 

significant manner. Furthermore, the topography of the region is accounted for 

in the dispersion modeling analysis via the AERMAP preprocessor, and the 

impact of land use is accounted for via the AERSURFACE preprocessor. As 

such, Ohio does not consider topography and land use to be a significant factor 

for this analysis beyond what is analyzed directly via the refined dispersion 

modeling analysis. 

Factor 5: Jurisdictional Boundaries

The analysis of jurisdictional boundaries looks at the planning and organizational 

structure of an area to determine if the implementation of controls in a potential 

nonattainment area can be carried out in a cohesive manner. Core Based 

Statistical Areas (CBSAs), comprised of Metropolitan Statistical Areas (MSAs) 

and Combined Statistical Areas (CSAs), boundaries were considered for these 

recommendations. 
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CHAPTER TWO: 

Analysis

Discussion:

Based on the five factor analysis below, Ohio is recommending Gallia County in 

its entirety and the portion of Meigs County including Bedford, Columbia, 

Rutland, Salem, Salisbury, and Scipio Townships be designated as attainment 

for the 2010 one-hour SO2 standard. The following discussion and information is 

relevant to those townships in Meigs County listed above as well as the entirety 

of Gallia County. 

As detailed under Factor 1, Ohio EPA modeled actual SO2 emissions from the 

General James M. Gavin and Kyger Creek Power Plants, years 2012-2014. No 

exceedances of the standard were modeled inclusive of a conservative 10 ppb 

background concentration. Derivation of the background concentration is 

detailed in Appendix E of this submittal.

Factor 1: Dispersion Modeling and Air Quality Data

Ohio EPA modeled actual emissions from the General James M. Gavin Power 

Plant and Kyger Creek Station for years 2012-2014, inclusive of a 10 ppb 

background. The full details of the modeling analysis are presented in Appendix 

A of this submittal. Appendix F includes the modeling protocol, and an 

evaluation of model performance is presented in Appendix C. For this analysis, 

the maximum modeled 3-year design value, years 2012-2014, was 162.16913

g/m3(188.32660 g/m3, including background). Note that Ohio ensured that the 

maximum combined impacts were captured by the finest receptor grid included 

in the modeling domain, as described in Appendix A of this submittal. An area 

meets the standard of 75 ppb if a concentration of 196.2 g/m3or lower is 

modeled, inclusive of background. Thus, no exceedance of the standard was 

modeled. The results of this analysis are shown in Figure 1. Note that for 

clarity, only design values of 150 g/m3or greater, inclusive of background, are 

displayed.
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Figure 1: Maximum SO2 impacts, General James M. Gavin and Kyger Creek 

facilities, 2012-2014. Concentrations are shown in g/m3 including 

background. 

The maximum 3-year design value was modeled approximately 1,200 meters 

from the fenceline of Kyger Creek Station and approximately 1,800 meters from 

the largest SO2 source at Kyger Creek. The spatial distribution of modeled 

concentrations greater than or equal to 150 g/m3 were located in a 5 to 9 

kilometer radius of the primary emissions sources, as detailed in Appendix A. 

As shown in Figure 1, the distribution of highest impacts is clearly and strongly 

influenced by the Ohio River valley. It should be noted that Ohio’s modeling 

analysis was conducted over a 50 x 50 kilometer modeling domain to 

encompass relevant jurisdictional boundaries. 

In addition to the modeling analysis, Ohio examined monitor data from the five 

SO2 monitors located around Gallia County and the General James M. Gavin 

source area. The monitor data, years 2012-2014, is summarized in Table 1. 

2012-2014 Monitored SO2 Design Values: General James M. Gavin Source Area

Monitor ID County 2012-2014 DV (ppb) Distance from Gavin Plant (km)

39-105-0003* Meigs 30 13

39-087-0012 Lawrence 17 67

39-145-0013 Scioto 9 72

39-145-0020 Scioto 27 71

39-145-0022 Scioto 19 73

Table 1: SO2 design values, Gallia County and General James M. Gavin source 

area. *Background derived from monitor 39-105-0003.
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The AQS monitoring data retrievals are included as Appendix H. With the 

exception of monitor 39-105-0003, located 13 kilometers to the Northeast of the 

General James M. Gavin Plant, these monitors are located approximately 70 

kilometers to the Southwest of the General James M. Gavin facility and 

approximately 30 kilometers distant from the nearest border of Gallia County. 

The location of these monitors and the explicitly modeled sources are shown in 

Figure 2. 

Figure 2: SO2 monitors surrounding the General James M. Gavin source area. 

 

Although these monitors are likely not impacted by emissions from the General 

James M. Gavin Plant and Kyger Creek Station, they are indicative of SO2

concentrations that would be transported into Gallia County and the source area 

via the prevailing winds of the area, as described in Factor 3 of this analysis. As 

shown in Table 1, all monitors are well below the standard of 75 ppb. Further, 

with the exception of monitor 39-145-0013, these monitors are sited to 

specifically monitor significant SO2 sources. Thus, it is anticipated that 

dispersion over the approximately 30 kilometers distance to Gallia County will 

reduce the concentration of SO2 transported into Gallia County below what is 

conservatively accounted for by background, and certainly well below the 75 ppb 

standard. Ohio believes that, in addition to the modeling results and the 

absence of significant SO2 sources (Factor 2), this provides strong evidence that 

the 75 ppb standard is attained throughout Gallia County. 

Monitor 39-105-0003, located 13 kilometers to the Northeast of the General 
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James M. Gavin Plant in Meigs County, has a 2012-2014 SO2 design value of 

30 ppb. This monitor was sited specifically to monitor the impacts of emissions 

from both the General James M. Gavin Plant and Kyger Creek Station. Taking 

into account the meteorology of the area and the absence of other SO2 sources 

not explicitly modeled, it is unlikely that SO2 concentrations above the standard 

would occur to the North or West of this monitor. Further, modeling results 

indicate that the highest modeled concentrations are strongly oriented along the 

Ohio River valley (Figure 1), and that areas outside of the valley are not strongly 

impacted by emissions from the General James M. Gavin and Kyger Creek 

Station facilities. As such, Ohio is including the Western portion of Meigs 

County in its recommended designation of attainment. 

 

Factor 2: Emissions

In 2014, there were 65,681 TPY of actual SO2 emissions from Ohio and West 

Virginia sources within 50 kilometers of the General James M. Gavin facility 

(inclusive) from sources that might potentially need to be modeled under the 

requirements of the Data Requirements Rule. 50,621 TPY of actual 2014 SO2

emissions are within Gallia County itself. These sources are shown in Table 2.
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State County Facility ID Facility Name

2014 SO2 

Emissions (TPY)

Distance from General 

J.M. Gavin (km)

OH Gallia 0627010056 General James M. Gavin Power Plant 36,873 --

OH Gallia 0627000003

Ohio Valley Electric Company, Kyger 

Creek Station 13,748 2.5

Gallia Total 50,621

WV Mason 6760811

Appalachian Power Mountaineer 

Plant 4,411 16.7

WV Mason 6760711

Appalachian Power Phillip Sporn 

Plant 10,649 17.2

Mason Total 15,060

Grand Total 65,681

Table 2: 2014 annual SO2 emissions, General James M. Gavin Plant and nearby sources.
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A significant aspect of Ohio’s recommended designation and selection of 

sources explicitly modeled is the cessation of operations at the Phillip Sporn 

Plant as of June 1, 2015. (Appendix I) This represents an emission reduction of 

approximately 16% from the area surrounding the General James M. Gavin

facility. Per U.S. EPA Region 5, sources retired prior to the promulgation of a 

designation for a particular area do not need to be modeled (Appendix D). As 

such, the impacts of emissions from the Phillip Sporn Plant were not considered 

in this analysis. The distance between the remaining facilities and the area 

impacted by emissions from the General James M. Gavin Plant, as well as the 

meteorology of the area (Factor 3) were considered. The distance between 

Kyger Creek Station and the General James M. Gavin Plant, 2.5 km, 

necessitated that Kyger Creek Station emissions be explicitly modeled. Ohio 

EPA also determined that the relatively low emissions from the Mountaineer 

Plant, considering meteorology (discussed below) and its distance from the 

General James M. Gavin Plant (4,411 TPY, 16.7 km), would not necessitate 

they be explicitly modeled as they are unlikely to impact ambient SO2

concentrations in the source area beyond what is accounted for in the 

background concentration. This conclusion is supported by the fact that 

emissions from the General James M. Gavin Plant and Kyger Creek Station, 

which were approximately 11 times higher than Mountaineer Power Plant in 

2014, did not demonstrate modeled exceedances of the standard, and had 

maximum impacts relatively close to the facilities, as described in Factor 1. 

Further, Ohio EPA’s model performance evaluation demonstrated that modeled 

impacts at the location of air quality monitor 30-105-0003, located approximately 

13 kilometers distant and sited to monitor emissions from the General James M. 

Gavin and Kyger Creek Station facilities, had a maximum modeled design value 

of 46 ppb, including background. It is therefore unlikely that the relatively low 

emissions from Mountaineer Power Plant, located approximately 17 kilometers 

distant, would cause a significant concentration gradient beyond what is 

accounted for in background.

 

Factor 3: Meteorology

Please refer to the Factor 3 general discussion at the beginning of this document

for general meteorological information applicable to Gallia County and the 

General James M. Gavin facility. Per relevant U.S. EPA guidance, dispersion 

modeling accounts for the majority of topographical and land use features that 

influence the meteorology of Gallia County. Of particular importance in Ohio’s 

designation recommendation for this area are the annual trends and distribution 

of wind directions in this area, which are best represented by data from the 

National Weather Service station located at the Huntington Tri-State Airport in 

Wayne County, West Virginia. Wind roses from this station, years 2012 to 2014, 

are shown in Figure 3, below.
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Figure 3: Huntington wind roses, 

2012-2014.
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The predominant wind directions were used, in part, to inform which facilities in 

Table 2, in addition to General James M. Gavin Power Plant and Kyger Creek 

Station, may potentially impact ambient SO2 concentrations in Gallia County not 

accounted for by background and therefore necessitate inclusion in the 

dispersion modeling analysis. As shown in Figure 3, the predominant winds in 

the source area originate from the south and southwest. Figure 4 shows the 

location of all facilities in Table 2, as well as a composite wind rose, years 2012-

2014, from the Huntington meteorological station. 

Figure 4: SO2 sources within 50 km of the General James M. Gavin Power 

Plant, with 2012-2014 composite wind rose. 

 

Considering the predominant wind directions, Ohio does not conclude the 

emissions from the Mountaineer Plant, located 16.7 km to the east-northeast of 

the General James M. Gavin Plant, impact ambient SO2 concentrations in Gallia 

County and the townships of Bedford, Columbia, Rutland, Salem, Salisbury, and 

Scipio in Meigs County2. Further, the Phillip Sporn Plant is no longer operational 

as of June 1, 2015 and therefore is not considered in this analysis. Ohio does 

not conclude that emissions from these sources impact ambient SO2

concentrations beyond the background level accounted for in the refined 

 

2 Ohio EPA also anticipates emissions from the Mountaineer Plant will not cause violations in the 

remainder of Meigs County. However, the Mountaineer Plant will be analyzed separately under U.S. 

EPA’s Data Requirements Rule in the future by the West Virginia Department of Environmental 

Quality. 
Page | 14

dispersion modeling analysis. Wind direction data and proximity suggests that 

emissions from Kyger Creek Station would potentially impact ambient SO2

concentrations, and therefore this source was explicitly modeled. Ohio 

concludes that, following the closure of the Phillip Sporn facility, the primary 

sources of SO2 in the General James M. Gavin source area are the General 

James M. Gavin Plant and Kyger Creek Station, and that the impact of those 

facilities in Table 2 not explicitly modeled or shutdown prior to promulgation of a 

designation are represented adequately and conservatively by the background 

concentration included in the Factor 1 modeling analysis.

 

Factor 4: Topography and Land Use/Land Cover

Please refer to the general discussion of Factor 4 at the beginning of this 

document. Ohio, consistent with U.S. EPA guidance, understands that the 

topography and land use characteristics influencing meteorology and the 

dispersion of SO2 emissions from the General James M. Gavin and Kyger Creek

facilities are adequately accounted for via the dispersion modeling analysis. 

Please refer to the Factor 1 section of this Chapter.

Factor 5: Jurisdictional Boundaries

The Point Pleasant, WV Micropolitan Statistical Area includes Mason County, 

West Virginia and Gallia County, Ohio. Meigs County, Ohio is not part of any 

combined statistical area or group. The Ohio EPA Central Office and the Ohio 

EPA Southeast District Office are responsible for air quality planning within all 

areas of Gallia and Meigs County. Gallia and Meigs Counties are not currently 

nonattainment for the 2010 one-hour SO2 standard. The dispersion modeling 

analysis conducted by Ohio was inclusive of the entirety of Gallia and Meigs 

Counties. In this submission, Ohio is recommending, based on a five-factor 

analysis, that the entirety of Gallia County and the Western half of Meigs County 

inclusive of Bedford, Columbia, Rutland, Salem, Salisbury, and Scipio 

Townships, be designated unclassifiable/attainment for the 2010 one-hour SO2

standard. Counties and Townships in Ohio have well-established boundaries

and administration, and Ohio believes they are a suitable administrative basis for 

this recommendation. 
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