# 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

, 2015Th is page left intentionally blankTABLE 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

Fact or 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 G eneral 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 D esignation 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 a nswers from EPA Region 5 Appendix H: U.S. EPA AQS Design Value Report Appendix I: Appalachian Power Phillip Sporn Shutdown NotificationThis page left intentionally blankPage | 1

State Of Ohio 2010 Revised Sulfur Dioxide National Ambient Air Quality

Standa rd Recommended Designation : General James M. Gavin and Kyger Creek Station Power Plants



### CHAPTER ONE :

General Discussion

History

T he United States Enviro nmental Protection Agency (U.S. EPA) promulgated

the revised National Ambient Air Quality Standar d ( NAAQS ) for sulfur dioxide ( SO 2 ) o n June 2, 20 10. 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 SO 2 standard was published on June 22, 2010 ( 75 FR 35520) and

be came 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 (7 8 FR 47191 ) the initial SO 2 nonattainment area designations for the one

- hour SO 2 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 Nat ural 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 b y 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 SO 2 in

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

least 0.45 lbs SO 2 /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 Stati on. 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 “nonattai nme nt” for

the 2010 one

- hour SO 2 standard. Since the original 2011 state submittals of designation recommendations and pursuant to the March 2, 2015 court order,Page | 2

new information may be relevant for future designations. CAA Section 107(d) does not require st ates 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 considera tion 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 promulga ted 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 th e 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 in dicate a violation of the NAAQS. U.S. EPA may designate an area as attainment if it is clear that that it meets the SO 2 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 ( S O 2 ) Primary National Ambient Air Qu ality Standard (NAAQS); Final Rule ( 80 FR

51051 )

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

December 2013 Draft SO 2 NAAQS Designations Modeling Technical Assistance

Document

. This document indicate s that the purpose of the modeling is to assess actual, current air quality and that those recommendations could include modeling the source a rea 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 Ga l lia County,

Ohio

. This facility was identif ied 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 SO 2 source(s) in question, unless additional information is provided to U.S. EPA demonstrating a different boundary is app ropriate. U.S.

EPA’s SO 2 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

anal ysis and other information may support designating only a portion of aPage | 3

county as nonattainment. U.S. EPA states that modeling could be used to

address several of these factors simultane ously. Ohio used the five

- factor analysis approach and c onducted additi onal modeling analysis as a part of this

submittal

. While using this approach, the SO 2 Designation Guidance states this analysis should show that: 1) violations are not occurring in nearby portions that

are excluded fr om the designation area; and 2) the ex cluded 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 f or the area surrounding the Gen eral James M

. Gavin Power Plant . Specifically, Ohio has used the five factor analysis approach, including refined dispersion modeling, as recommended in the SO 2 Designation Gui dance, to support the boundary recommendation

. Ohio
understands, based on the both the December 2013 Draft SO 2 NAAQS Designations Modeling Technical Assistance Document and the March 20, 2015 memorandum, that dispersion modeling accounts simultaneously for multiple

elements of the five

- fac tor analysis. As such, Ohio believes that t he m odeling analysis presented in Appendix A and summarized in this document should carry significant weight in the designation p rocess. Where appropriate, Ohio is providing additional supporting information with respect to the five

- factor designation app roach.

Factor 1: Dispersion Modeling and Air Quality Data

Ohio conducted a refined dispersion modeling analysis following the guidance issued by U.S. EP A in the December 2013 Draft SO 2 NAAQS Designations Modeling Technical Assistance Document , the March 20 memorandum, and the proposed Data Requirements Rule . The modeling analysis was based on 2012

to 20 14 actual emissions from the General James M. Gavin Power Plant and representative met eorological data from the same period. In addition to the

General J ame s M. Gavin Power Plant, Ohio simultaneously modeled actual emissions from Kyger Creek Station 1

, located to the south

- west of the General James M. Gavin Power plant approximately 2.5 kilometers distant, over the same period. The methodolog y and results of the anal ysis are provided in Appendix A

. Evaluation of model performance against air quality monitorin g 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.Page | 4

Emissions of SO 2 for 2014 were determined from Ohio EPA’s Fee Emission Reports (FERs) which are the basis for Oh io’s 2014 NEI submittal. Emissions data for nearby sources in West Virginia were provided by the West Virginia Depar tment of Environmental Protection. Tables iden tified in this analysis show stationary sources with reported SO 2 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 Modelin g Technical Assistance

Document suggests sources greater than the threshold s established under the Data Requirements Rule located within 50 k ilo m eters of th e General James M.

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

U.S. EP A 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 w ith the language of the Data

R equire ments Rule. Therefore, Ohio wi ll consider the reduction in SO 2 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.

Emission s data for both facilities were provided t o Ohio EPA by American

Electric Power

.

Factor 3: Meteorology

The meteorology r eview looks at wind data gathered at stations in and near Ohio by the National Weather Service (NWS). Information presente d under this

factor is indicative of annual average winds . These data may also suggest that emissions originating from some directi o ns 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 th is 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 w ind roses for the source area and SO 2 sources surrounding th e General James M. Gavin facility.

The major geographic feature affecting winds in the area s urrounding the

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

. This area has significant forested areas which modify the surfa ce roughness lengths and can impact wind spee d and wind direction. The Huntington airportPage | 5

w ind 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 disp ersion 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 f r om 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 v alley, and therefore some portions of the area may experience inversions. However, the geographical and topographical

features of the area are n ot likely to limit or impact the transport of SO 2 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 AERS URFACE preprocessor. As such, O hio 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 o f 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), compr ised of Metropolitan Statistical Areas (MSAs) and Combined Statistical Areas (CSAs), boundaries were considered for these

recommendations.Page | 6



### C HAPTER TWO:

Analysis

Discussion:

Based on the five factor analysis below, Ohi o is recommending G allia County in its entirety and the portion of Meigs Co unty including Bedford, Columbia, Rutland, Salem, Salisbury, and Scipio Townships be designated as attainment

for the 2010 one

- hour SO 2 standard

. The following discussion and info rmation is

relevan t 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 SO 2 emissions from the General James M. Gavin and Kyger Creek Power Plants , years 2012

- 2014. No

exceedances o f the standard were modele d inclusive of a conservative 10 ppb background concentration. Derivation of the background concent ration is detailed in Appendix E of this submittal.

Factor 1: Dispersion Modeling and Air Quality Data

Ohio EPA modeled actual emis sions from the General James M. Gavin Power Plant and Kyger Creek Station for yea rs 2012

- 2014, inclusive of a 10 ppb background. The full details of the modeling analy sis are presented in Appendix

A of this submittal. Appendix F includes the modeling protocol , and an evaluation of model perfor mance is presented in Appendix C

. For this analysis,

the maximum modeled 3

- year design valu e, years 2012

- 2014, was 162 .1 6913

 g/m 3 (188.32660  g/m 3 , 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/m 3 or lower is

modeled , inclusive of background

. Thus, no exceedance of the standard was

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

cl arity, only design values of 15 0  g/m 3 or greater , inclusive of bac k g round, are displayed.Page | 7

Figure 1: Maximum SO2 impacts, General James M. Gavin and Kyger Creek
facilities, 2012-2014. Concentrati ons are shown in  g/m 3 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 SO 2 source at Kyger Creek. The spatial distribution of modeled concentrations greater than or equal to 15 0  g/m 3 were located in a 5 to 9

k ilo meter 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

SO 2 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

- 201 4 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 Sci oto 19 73

Table 1: SO 2 design values, Gallia County and General James M. Gavin source area. *Background derived from monitor 39- 105

- 0003.Page | 8

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: SO 2 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 SO 2 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

- 00 13, these monitors are sited to specifically monitor significant SO 2 sources. Thus, it is anticipated that

di spersion over the approximately 30 kilometers distance to Gallia County will

reduce the concentration of SO 2 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 SO 2 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 GeneralPage | 9

James M. Gavin Plant in Meigs County, has a 2012

- 2014 SO 2 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 a ccount the meteorology of the area and the absence of other SO 2 sources not explicitly modeled, it is unlikely that SO 2 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 includin g the Western portion of Meigs County in its recommended designation of attainment

.

Factor 2: Emissions

In 2014, there were 65,681 TPY of actual SO 2 emissions from Ohio and West Virginia sources within 5 0 k ilo m eters of the General James M. Gavin facility (inclusive) from sources that might potentially need to be modeled under the requiremen ts of the Data Requirements Rule

. 50,621 TPY of actual 2014 SO 2 emissions are within Gallia County itself

. Th ese sources are shown in Table 2

.Page | 10 State County Fa cility 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 5 0,62 1

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 SO 2 emissions, General James M. Gavin Plant and nearby sources.Page | 11

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 emiss ion reduc tion of approximately 16 % from the area s urrounding 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 Mountain eer 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 SO 2 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

2 014, 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 q uality 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 th e Factor 3 general discussion at the beginning of this document for general meteorolo gical 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 to pographical and land use features that

influ ence the meteorology of Gallia County. Of particular importance in Ohio’s designation recommendation for this area are the annual trend s and distribution of wind directions in this area, which are best represent ed by data from the

National Weather Service station locate d 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.Page | 12 Figure 3 : Huntin gton wind roses,

2012

- 2014

.Page | 13

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 SO 2 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: SO 2 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 SO 2 concentrations in Gallia County and the townships of Bedford, Columbia, Rutland, Salem, Salisbury, and Scipio in Meigs County 2 . 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 SO 2 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 o f Environmental Quality.Page | 14

dispersion modeling analysis. Wind direction data and proximity suggest s that emissions from Kyger Creek Station w ould po tentially impact ambient SO 2

conc entrations , and therefore this source was explicitly modeled. Ohio concludes that, following the c losure of the Phillip Sporn facility, the primary

source s of SO 2 in the General James M. Gavin source area are the General

James M. G avin P lant and Kyger Cre ek 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 analysi s.

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 me teorology and the dispersion of SO 2 emiss ions 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 Bou ndaries

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 Di strict Office are responsible for air quality p lanning within all

a reas of Gallia and Meigs County

. Gallia and Meigs Counties are not currently

nonat tainment for the 2010 one

- hour SO 2 standard. The dispersion modeling analysis conducted by Ohio was inclu sive of the entirety of Gallia and Meigs

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

- factor analysis, that t he entirety of Gallia County and the Western half of Meigs County inclusive of Bedford, Columbia, Rutland, Salem, Salisbury, and Scipio Townships, be designated u nclassifiable /attainment for the 2010 one

- hour SO 2 standard. Counties and Townships in Ohio have well

- established boundaries

and administration , and Ohio believes they are a suitable administrative b asis for

this recommendation.Page | 15 T his page left intentionally blan k