1

Draft Technical Support Document

Ohio

Area Designations For the 

2010 SO2 Primary National Ambient Air Quality Standard

Summary

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

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

national ambient air quality standard (NAAQS). The Clean Air Act 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. 

Table 1 below identifies the counties or portions of counties in Ohio that EPA intends to designate 

“nonattainment” based on monitored violations. 

Table 1. Nonattainment Area Designations for Ohio

Area 

Ohio’s Recommendation of 

Areas/Counties

EPA’s Intended Designated 

Nonattainment Areas/Counties

Lake County, OH

 Lake County Nonattainment Nonattainment

Muskingum River, OH

 Morgan County (partial): 

 Center Township

 Washington County (partial):

 Waterford Township

Nonattainment

Nonattainment

Nonattainment 

Nonattainment

Steubenville OH-WV*

 Jefferson County, OH (partial): 

 Cross Creek, Steubenville, Warren, and Wells

 Townships

 Brooke County, WV

Nonattainment

Nonattainment**

Nonattainment

Nonattainment

Wheeling WV-OH*

 Marshall County, WV

 Belmont County, OH (partial): 

 Mead Township

Nonattainment**

Unclassifiable 

Nonattainment 

Nonattainment

Campbell County KY-OH*

 Campbell County, KY (partial)

 Census tracts 533.01, 529, 531, 519.03, 519.01

 Clermont County, OH (partial):

 Pierce Township

Unclassifiable**

Unclassifiable

Nonattainment

Nonattainment

* This is a multi-state nonattainment area. Additional information on boundary recommendations 

and analyses can be found in the draft technical support documents for West Virginia and Kentucky.

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

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

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

per billion (ppb) which is attained when the three-year average of the 99th percentile of one-hour daily 

maximum concentrations does not exceed 75 ppb. EPA has determined that this is the level necessary 

to provide protection of public health with an adequate margin of safety, especially for children, the 

elderly and those with asthma. These groups are particularly susceptible to the health effects 

associated with breathing SO2. EPA is revoking the two prior primary standards of 140 ppb evaluated 

over 24 hours, and 30 ppb evaluated over an entire year because they will not add additional public 

health protection given a one-hour standard at 75 ppb. Accordingly, EPA is not designating areas in 

this process on the basis of either of these two primary standards. Similarly, the secondary standard 

for SO2 has not been revised, so EPA is not designating areas in this process on the basis of the 

secondary standard. 

EPA’s SO2 Designation Approach

Section 107(d) of the Clean Air Act requires that not later than one year after promulgation of a new or 

revised NAAQS, state Governors must submit their recommendations for designations and boundaries 

to EPA by 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. EPA was to promulgate initial area designations within two years of promulgation 

of the revised primary standard, although EPA has extended this deadline for one additional year due 

to having insufficient information to promulgate the designations. If a state did not submit designation 

recommendations, EPA will promulgate the designations that it deems appropriate. If a state or tribe 

disagrees with EPA’s intended designations, they have an opportunity to demonstrate why any 

proposed modification is 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 intends to evaluate in determining 

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

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

concentrations); 3) meteorology (weather/transport patterns); 4) geography/topography (mountain ranges 

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

nonattainment areas, reservations, metropolitan planning organization), among any other criteria deemed to 

be relevant to establishing appropriate area designations and boundaries for the one-hour SO2 NAAQS.

The March 24, 2011, memo recommended that area boundaries default to the county boundary unless 

information provided by the state or tribe justifies a larger or smaller boundary than that of the county. 

EPA believes it is appropriate to evaluate each potential area on a case-by-case basis, and to recognize that 

area-specific analyses conducted by states, tribes and/or EPA may support a differing boundary than a 

county boundary.

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

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

one-hour SO2 standard and any modifications from these recommendations. 

Definition of important terms used in this document:
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1) Designated nonattainment area – an area which EPA has determined, based on a state 

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

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

violation in a nearby area.

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

as nonattainment.

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

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

CFR part 50.

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

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

average concentrations. See 40 CFR Part 50.17.

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

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

violating the NAAQS.

A. Technical analysis for Lake County, OH

Introduction 

This technical analysis for the Lake County Area identifies the monitor that violated the 2010 SO2

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

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

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

Figure 1 shows the proposed nonattainment area and the monitor location.
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Figure 1. Map of Lake County, OH Nonattainment Area.

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

on monitored air quality data from 2008-2010. EPA intends to designate Lake County, Ohio as 

nonattainment for the 2010 SO2 NAAQS, based upon currently available information, including the 

monitored design value for 2009-2011.

Detailed Assessment

Air Quality Data 

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

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

2009-2011 period. The 2010 SO2 NAAQS design value for Lake County is shown in Table 2.
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Table 2. Air Quality Data for Lake County Nonattainment Designations 

County

State 

Recommended 

Nonattainment?

Monitor Air 

Quality 

System ID

Monitor Location

SO2 Design 

Value, 

2009 - 2011

(ppb)

Cuyahoga No 39-035-0038 Cleveland 71

No 39-035-0045 Cleveland 42

No 39-035-0060 Cleveland 73*

No 39-035-0065 Newburgh Hts 38

Lake Yes 39-085-0003 Eastlake 33

Yes 39-085-0007 Painesville 157

Ashtabula No 39-007-0001 Conneaut 24

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

*Data for 2009 is incomplete.

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

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

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

counties as candidates for nonattainment status. 

Emissions and Emissions-Related Data

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

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

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

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

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

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

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

contributing counties in and around Lake County, and sources emitting (or anticipated to contribute)

greater than 100 tons per year of SO2 according to the 2008 NEI. Lake County is shown in bold. 

Most of the facilities in Ashtabula and Cuyahoga Counties are over 40 kilometers from the Lake 

County monitors. Given their moderate level of SO2 emissions and their distance from the Lake 

County monitor, these sources are not judged to be nearby sources contributing to the violation in Lake 

County.
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Table 3. SO2 Emissions for the Lake County Area

County

Facility 

Located in 

State 

Recommended 

Nonattainment

Area?

Facility Name

Facility Location/ 

Distance from 

violating monitor 

(km)

Facility Total SO2

Emissions 

(tons per year)

Lake

Yes Eastlake Power Plant Willoughby/17 50521.0

Yes Painesville Municipal 

Electric Plant

Painesville/1 7212.0

Yes Carmeuse Lime – Grand 

River Operations

Grand River/4 910.0

Yes Lubrizol Corporation Painesville/3 23.0

Yes Lubrizol Corporation –

Wickliffe Facility

Wickliffe/23 6.7

Cuyahoga

No Lake Shore Power Plant Cleveland/39 4582.0

No The Medical Center 

Company

Cleveland/41 2203.0

No Cleveland Thermal LLC Cleveland/45 1332.0

No ArcelorMittal Cleveland, 

Inc.

Cleveland/46 718.0

No Charter Steel – Cleveland, 

Inc.

Cleveland/47 61.0

Ashtabula

No FirstEnergy Ashtabula 

Plant

Ashtabula/44 3850.0

No Millennium Organic 

Chemicals, Inc. Plant 2

Ashtabula/44 20.0

No Millennium Organic 

Chemicals, Inc. Plant 1

Ashtabula/45 6.4

No USA Waste Geneva 

Landfill

Geneva/28 2.9

Emission Controls 

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

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

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

controls put into place after 2008.

Meteorology (weather/transport patterns)

While meteorological records for Cleveland indicate that winds blow predominantly from the 

southwest, the winds in this area can come from any direction. Near Lake Erie, a diurnal lake/land 

breeze pattern may occur. Therefore, sources in all directions can have some potential contribution. 

This factor did not play a significant role in determining the nonattainment boundary. 

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

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

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

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

nonattainment boundary. 
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Jurisdictional Boundaries 

There are no current SO2 nonattainment areas in Lake County and the surrounding region. The 

recommended nonattainment area for the 2010 SO2 NAAQS is Lake County. The SO2 sources which 

are believed to be the main contributors to the monitored violations are located within this county. The 

SO2 ambient air quality monitors are also located within Lake County. EPA finds the county 

boundaries to be a suitably clear basis for defining nonattainment area boundaries. 

Other Relevant Information

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

this area.

Conclusion

After considering the factors described above, EPA intends to find that it is appropriate to designate 

Lake County as a nonattainment area for the 2010 SO2 NAAQS. The air quality monitors in Lake 

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

year of SO2 (based on 2008 data). The large facilities in the neighboring counties are 40 kilometers or 

more from the violating Lake County monitor, and are not judged to contribute significantly to the 

monitored violation. EPA believes that Lake County encompasses the appropriate initial 

nonattainment area based on the monitored violation of the 2010 SO2 NAAQS.

B. Technical Analysis for the Muskingum River, OH Area 

Introduction 

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

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

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

the March 24, 2011 EPA guidance. 

Figure 2 shows a map of the proposed nonattainment area including the monitor location.
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Figure 2. Map of Muskingum River, OH Nonattainment Area.

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

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

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

Electric Power’s Muskingum River Power Plant. EPA intends to designate 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. 

Detailed Assessment

Air Quality Data 

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

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

County is shown in Table 4.

Table 4. Air Quality Data for the Muskingum River Area 

County

State 

Recommended 

Nonattainment?

Monitor Air 

Quality 

System ID

Monitor Location

SO2 Design 

Value, 

2009 - 2011

(ppb)

Morgan Yes 39-115-0004 Hackney, OH 180
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Morgan County shows a monitored violation of the 2010 SO2 NAAQS. Therefore, some area in this 

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

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

candidates for nonattainment status. 

Emissions and Emissions-Related Data

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

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

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

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

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

analysis of Ohio’s SO2 designation recommendations.

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

counties in and around the Muskingum River Area and sources emitting (or anticipated to contribute)

greater than 100 tons per year of SO2 according to the 2008 NEI. There are no significant sources of 

SO2 within Morgan County, except that a portion of the Muskingum River power plant, which is 

generally inventoried as part of Washington County, is physically located in Morgan County. Ohio 

considered all SO2 sources within 50 kilometers of the violating monitor. Listed below are the sources 

which are considered most likely to impact the Morgan County SO2 monitor. They are all located 

within 5 to12 kilometers of the monitor. There are two additional sources over 100 tons per year in 

Washington County, but they are 37 kilometers from the Morgan County monitor and, at less than 

3000 tons per year each, are not judged to be nearby sources contributing to the monitored violation in 

Morgan County. There are two sources which emit over 100 tons per year in two other neighboring 

counties, but they are over 40 kilometers from the Morgan County monitor. Given their distance, and 

the fact that they each emit less than 500 tons per year, they are not judged to be nearby sources 

contributing to the violation in Morgan County. Therefore, EPA agrees that the nonattainment 

boundaries proposed by Ohio for the Muskingum River Area encompass all the sources which are 

judged to contribute significantly to the monitored violation in this area.

Table 5. SO2 Emissions for the Muskingum River Area

County

Facility 

Located in 

State 

Recommended 

Nonattainment

Area?

Facility Name

Facility 

Location/ 

Distance from 

monitor

Facility total 

SO2 Emissions 

(tons per year)

Washington

Yes Muskingum River Power 

Plant

Waterford/5 133,338.0

Yes Globe Metallurgical Waterford/5 1190.6

Yes Washington Energy 

Facility

Beverly/6 0.81

Yes AEP/Columbus Southern

Waterford Plant

Waterford/12 0.66
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Emission Controls 

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

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

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

resulting from controls put into place after 2008.

Meteorology (weather/transport patterns)

Winds in this general area tend to blow most often from the southwest, but can come from any 

direction. Therefore, sources in all directions can have some potential contribution. This factor did 

not play a significant role in determining the nonattainment boundary. 

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

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

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

significant role in determining the nonattainment boundary.

Jurisdictional Boundaries 

There are no current SO2 nonattainment areas in Morgan and Washington Counties. The 

recommended Muskingum River nonattainment area for the 2010 SO2 NAAQS consists of the two 

adjacent townships in Morgan and Washington Counties which are believed to enclose all SO2 sources 

contributing to the monitored violations. The SO2 ambient air quality monitor is also located within 

this area. Townships in Ohio have well established boundaries and EPA finds that they are suitable for 

defining Ohio’s nonattainment areas. 

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 intends to find that it is appropriate to designate 

the portions of Morgan and Washington Counties listed in Table 1 as the Muskingum River, OH

nonattainment area for the 2010 SO2 NAAQS. EPA believes that the boundaries described herein 

encompass the appropriate nonattainment area for the 2010 SO2 NAAQS.
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Interstate Areas

The next three technical analyses discuss a set of nonattainment designations that cross state

boundaries. The Steubenville OH-WV Interstate Area, the Wheeling WV-OH Interstate Area, and the 

Campbell County KY-OH Interstate Area are all adjacent to the Ohio River, which forms the boundary 

between Ohio and West Virginia, and between Ohio and Kentucky. The location of the main SO2

sources and the monitors are such that Ohio, West Virginia, and Kentucky sources can be culpable to 

air quality impacts on the opposite side of the Ohio River. Therefore, these nonattainment areas should 

be treated as interstate areas.1 Ohio did not specifically address interstate issues when addressing these 

areas in its June 3, 2011 submittal. This TSD focuses on the Ohio portion of these interstate 

nonattainment areas.

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

Introduction 

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

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

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 guidance.

Figure 3 shows a map of the proposed nonattainment area and the monitor location.

 

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

provided in technical support documents for these states.
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Figure 3. Map of the Steubenville OH-WV Interstate Nonattainment Area

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

designated as nonattainment for the 2010 SO2 NAAQS. West Virginia recommended that Brooke 

County, West Virginia, also be designated nonattainment. Brooke County is located across the Ohio 

River from Steubenville. The full analysis for the West Virginia portion of this area can be found in 

the TSD for West Virginia. EPA believes that these areas should be combined to form the 

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

intending to designate Cross Creek, Steubenville, Warren, and Wells Townships in Jefferson County as 

nonattainment for the 2010 SO2 NAAQS, in conjunction with Brooke County in West Virginia.

Detailed Assessment

Air Quality Data 

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

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

Table 6. Air Quality Data for the Steubenville OH-WV Interstate Area

County

State 

Recommended 

Nonattainment?

Monitor Air Quality 

System ID Monitor Location

SO2 Design Value, 

2009 – 2011

(ppb)

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

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

Brooke, WV Yes 54-009-0007 McKims 83

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

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

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

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

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

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

and Brooke County, West Virginia, EPA intends to designate a nonattainment area that includes the 

sources in the area that contribute to these violations.

Emissions and Emissions-Related Data

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

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

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

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

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

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

designation recommendations.

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

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

Steubenville OH-WV Interstate Area nonattainment area for the 2010 SO2 NAAQS. 
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Table 7. Ohio SO2 Emissions for the Steubenville OH-WV Interstate Area

County

Facility 

Located in 

State 

Recommended 

Nonattainment

Area?

Facility Name

Facility Location/ 

Distance from 

Monitor (km)

Total SO2 Emissions 

(tons per year)

Jefferson

No FirstEnergy

W.H. Sammis Power Plant

Stratton, OH/18 102,197.0*

Yes American Electric 

Power/Buckeye Power 

Cardinal Power Plant

Brilliant, OH/13 33,317.0

Yes Severstal Wheeling, Inc Steubenville/ Mingo 

Junction, OH/5

700.0

Yes Severstal Wheeling, Inc Yorkville, OH/15 0.24

Yes Mingo Junction Energy 

Center

Mingo Junction, 

OH/5

82.0

No Titanium Metals Corp. Toronto, OH/9 0.20

Columbiana No Heritage – WTI, Inc East Liverpool, 

OH/30

3.60

Belmont No Severstal Wheeling, Inc. Martins Ferry, 

OH/28

0.06

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

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

2008 NEI.

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

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

monitor in Jefferson County, and is not considered to contribute to the Jefferson County monitor. The 

SO2 sources in Carroll County and Belmont County within 50 kilometers are also very low in SO2

emissions, less than 10 tons per year, and are located at a similar distance. EPA agrees with Ohio that 

these sources do not merit inclusion in the Steubenville OH-WV Interstate Area. Most of the 

significant sources within Jefferson County are located in the townships that Ohio recommended be 

designated nonattainment. The exception is the FirstEnergy’s W.H. Sammis power plant, which is 

located 18 kilometers north of the Jefferson County monitor and a similar distance from the violating 

monitors in Brooke County. The W.H. Sammis power plant significantly reduced its emissions after 

installing pollution controls in 2010. The Columbiana County SO2 monitor in East Liverpool, about 

14 kilometers north of the power plant, has measured a noticeable drop in SO2 concentrations since 

2010. Its SO2 design value (three year average of 99th percentile concentrations) was 117 ppb for 

2007-2009, when the 2007 99th percentile value was 128 ppb. For 2008-2010, the design value had 

fallen to 90 ppb, with a 99th percentile value of 47 in 2010. For 2009-2011, the design value was 

62 ppb, with a 99th percentile value of 27 ppb in 2011. The W.H. Sammis power plant is not judged to 

be a nearby source contributing to the violations at the Jefferson County monitor or the Brooke County 

monitors and therefore does not merit inclusion in the Steubenville OH-WV Interstate Area.

Emission Controls 

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

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

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

resulting from controls put into place after 2008, but the Clean Air Markets Division database suggests 
14

that the W.H. Sammis Power Plant has reduced its emissions significantly. For example, in 2011, the 

company reported emissions from Sammis of 4,202 tons.

Meteorology (weather/transport patterns)

For this area, winds can be from any direction. Therefore, sources in all directions can have some 

potential contribution. This factor did not play a significant role in determining the nonattainment 

boundary. 

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

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

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

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

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

determining the nonattainment boundary. 

Jurisdictional Boundaries 

There are no current SO2 nonattainment areas in Jefferson County. The recommended nonattainment 

area for the 2010 SO2 NAAQS for the Ohio portion of the Steubenville area consists of the four

townships along the Ohio River in Jefferson County which are believed to enclose all SO2 sources 

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

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

are a suitable administrative basis for defining Ohio’s nonattainment areas. 

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 intends to find that it is appropriate to designate 

Cross Creek, Steubenville, Warren, and Wells Townships in Jefferson County as the Ohio portion of 

the Steubenville OH-WV Interstate SO2 nonattainment area. EPA intends to combine this Ohio 

portion with Brooke County in West Virginia to form a single bi-state nonattainment area. EPA 

believes that the boundaries described herein encompass the entire area that does not meet or that

contributes to ambient air quality that does not meet the 2010 SO2 NAAQS.

D. Technical Analysis for the Wheeling WV-OH Interstate Area 

This technical analysis for Belmont County identifies the monitor that violated the 2010 SO2 NAAQS

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

this county and nearby counties based on the evidence for the factors recommended in the March 24, 

2011 EPA guidance. 

Figure 5 shows a map of the proposed nonattainment area and the monitor location.
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Figure 5. Map of the Wheeling WV-OH Interstate Nonattainment Area.

On June 3, 2011, Ohio recommended that Mead, Pease, Pultney, and York Townships in Belmont 

County be designated as nonattainment for the 2010 SO2 NAAQS. This recommendation was based 

on a monitored violation in Belmont County for the period 2008-2010. However, for the period 2009-

2011, the design value of the Belmont County SO2 monitor was below the 2010 SO2 NAAQS. Ohio

amended its designation recommendation for Belmont County to unclassifiable in a letter dated April 

12, 2012. EPA reviewed the SO2 sources and monitor locations in Marshall and Belmont Counties, 

and concluded that Mead Township in Belmont County should remain in the Wheeling WV-OH 

Interstate Area, because it contains a large SO2 source which may contribute to violations at the 

Marshall County SO2 monitor. In June 2011, West Virginia recommended that Marshall County, West 

Virginia, be designated nonattainment. Marshall County is across the Ohio River from Belmont 

County. EPA believes that these areas should be combined to form the Wheeling WV-OH Interstate 

Area. The full analysis for the West Virginia portion of this area can be found in the TSD for West 

Virginia.

Detailed Assessment

Air Quality Data 

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

calculated for the air quality monitor in Belmont County. The design values for Belmont and Marshall 

Counties are shown in Table 8.
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Table 8. Air Quality Data for Belmont County

County

State 

Recommended 

Nonattainment?

Monitor Air 

Quality 

System ID

Monitor Location

SO2 Design

Value,

2009-2011

(ppb)

Belmont, OH Yes 39-013-3002 Shadyside, OH 61

Marshall, WV Yes 54-051-1002 Moundsville, WV 80

Marshall County shows a monitored violation of the 2010 SO2 NAAQS for 2009-2011. Monitoring 

data Belmont County does not show a violation of the 2010 SO2 NAAQS for 2009-2011. However,

the absence of a violating monitor alone may not be a sufficient reason to eliminate a county as a 

candidate for nonattainment status. 

Emissions and Emissions-Related Data

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

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

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

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

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

analysis of Ohio’s SO2 designation recommendations.

Table 9 shows the emissions of SO2 in Ohio and West Virginia which may contribute to a monitored 

violation in Marshall County. Listed below for Belmont County are the sources within 20 kilometers 

of the Marshall County monitor. The other sources in Belmont County emit less than one ton per year 

of SO2 and are located over 30 kilometers from the Marshall County monitor. These sources are not 

judged to be nearby sources contributing to the monitored violation in Marshall County. There is a 

large source in Jefferson County, the Cardinal Power Plant, which is about 40 kilometers from the 

Marshall County monitor. It is already included in the Steubenville OH-WV Interstate Area. The 

Belmont County sources in Table 9 are located along the Ohio River near Shadyside and Martins 

Ferry, Ohio. The R.E. Burger power plant is two kilometers from the Marshall County monitor in 

Moundsville, West Virginia, and about seven kilometers from the Belmont County monitor, and is 

located in the town of Shadyside, Ohio. It is the closest large source to either monitor, and therefore it 

is considered likely to be an important potential contributor to the monitored SO2 concentrations. The 

two facilities in Martins Ferry, Ohio, are about 15 kilometers from the Marshall County monitor and 

emit much less than one ton per year of SO2. These two facilities do not warrant being judged to be 

nearby sources contributing to the monitored violation in Marshall County, West Virginia. There is 

one source in Monroe County, Ohio, which emits about 2400 tons per year and is located over 30 

kilometers from the Marshall County monitor. It is also judged not to be a nearby source contributing 

to the monitored violation. Table 9 includes sources in Marshall County, West Virginia, which are 

included in the West Virginia portion of the Wheeling WV-OH Interstate Area. 
17

Table 9. SO2 Emissions in the Wheeling WV-OH Interstate Area

County

Facility 

Located in 

State 

Recommended 

Nonattainment

Area?

Facility Name 

Facility Location/ 

Distance from 

Violating Monitor 

(km)

Facility SO2 Air

Emissions 

(tons per year)

Belmont

No* FirstEnergy R. E. Burger 

Power Plant Shadyside, OH/2 15,126.0

No Severstal Wheeling, Inc., 

Martins Ferry Martins Ferry, OH/15 0.06

No Nickles Bakery Martins Ferry, OH/15 0.01

Marshall

Yes Ohio Power (AEP) Kammer 

Plant Moundsville, WV 32050.0

Yes PPG Industries New Martinsville, 

WV

7693.0

Yes Rain CII Carbon 

Moundsville Calcining Moundsville, WV 7630.0

Yes Ohio Power (AEP) Mitchell 

Plant Moundsville, WV 3024.0

Yes Columbian Chemicals 

Company Moundsville, WV 1180.0

*Facility is located in EPA-recommended nonattainment area.

Emission Controls

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

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

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

resulting from controls put into place after 2008.

Meteorology (weather/transport patterns)

For this area, winds can be from any direction. Therefore, sources in all directions can have some 

potential contribution. This factor did not play a significant role in determining the nonattainment 

boundary. 

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

The recommended nonattainment portion of Belmont County is on 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. 

Jurisdictional Boundaries 

Ohio does not have any current SO2 nonattainment areas. For Belmont County, the intended 

nonattainment area consists of one township along the Ohio River which encloses both the Belmont 

County SO2 ambient air quality monitor and an Ohio SO2 source which is believed to contribute to the 

monitored violations in Marshall County, West Virginia. Townships in Ohio have well established 
18

boundaries and EPA finds that they are a suitable administrative basis for defining Ohio’s 

nonattainment areas. 

Other Relevant Information

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

this area.

Conclusion

After considering the factors described above, EPA intends to find that it is appropriate to designate 

Mead Township in Belmont County as nonattainment for the 2010 SO2 NAAQS, as part of the 

Wheeling WV-OH Interstate nonattainment area. EPA believes that this partial-county area, in 

conjunction with Marshall County, West Virginia, encompasses the appropriate nonattainment area for 

the 2010 SO2 NAAQS.

E. Technical Analysis for the Campbell County KY-OH Interstate Area

Introduction 

This technical analysis for the Ohio portion of the Campbell County KY-OH Interstate area identifies 

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

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

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

Figure 7 is a map of the proposed Campbell County KY-OH Interstate Area, showing the location of 

the air quality monitor.
19

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

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

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

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

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

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

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

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

nonattainment designation recommendation was necessary. However, after reviewing emissions and 

meteorological data for the region surrounding the Campbell County monitor, EPA believes that one 

township in Clermont County, Ohio, and five census tracts within Campbell County, Kentucky, should 

be designated as nonattainment for the 2010 SO2 NAAQS, to form the Campbell County KY-OH 

Interstate Area. 

Detailed Assessment

Air Quality Data 

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

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

Campbell County is shown in Table 10. The nearest Ohio SO2 monitor is located in Hamilton County 

near Cleves, about 30 kilometers northwest of the Campbell County monitor. 
20

Table 10. Air Quality Data for Campbell County

County

State 

Recommended 

Nonattainment?

Monitor Air

Quality System 

ID

Monitor Location

SO2 Design 

Value, 

2009 - 2011

(ppb)

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

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

*EPA intends to designate as part of the nonattainment area.

**The 2010 data were incomplete at this monitor.

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

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

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

candidates for nonattainment status. 

Emissions and Emissions-Related Data

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

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

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

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

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

monitor. The W.C. Beckjord Station emitted over 26,000 tons of SO2 in 2008 (NEI08v2), and more 

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

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

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

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

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

At this distance, with emissions much lower than from the W.C. Beckjord Station, EPA believes that 

Zimmer Generating Station does not warrant being judged to be a nearby source contributing to the 

violation at the Campbell County monitor. There are eight facilities in southern Hamilton County 

which are located to the north or northwest of the Campbell County monitor, at distances of 

13 kilometers or more. Of the sources closest to the monitor, only two emit more than 1,000 tons of 

SO2; the others emit 100-600 tons of SO2. These facilities are not judged to be nearby sources 

contributing to the violation in Campbell County. The largest facility in Hamilton County, Duke 

Energy’s Miami Fort Station, emits about 25,000 tons of SO2, but is located 30 kilometers from the 

violating monitor. Given that distance, EPA does not believe that the Miami Fort Station is 

contributing significantly to violations at the Campbell County monitor. Therefore, EPA believes that 

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

should be designated nonattainment and combined with portions of the neighboring Campbell County, 

Kentucky, to form the Campbell County KY-OH Interstate Area. 

Table 11 shows the total emissions of SO2 for potentially contributing sources emitting (or anticipated 

to contribute) more than 100 tons per year of SO2 according to the 2008 NEI, in Hamilton and 

Clermont Counties, Ohio.

Table 11. Ohio SO2 Emissions for the Campbell County (KY) Area

County

Facility Located in 

State 

Recommended 

Facility Name

Facility 

Location/ 

Distance from 

Total SO2

Emissions 

(tons per 
21

Nonattainment

Area?

monitor (km) year)

Hamilton

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

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

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

No University of Cincinnati Cincinnati/13 616.0

No INEOS ABS (USA) Corporation Addyston/24 472.0

No Emerald Performance Materials, 

LLC Cincinnati/27 306.0

No Rock-Tenn Converting Company Cincinnati/16 257.0

No Caraustar Mill Group, Inc Cincinnati/13 118.0

Clermont

No*

Duke Energy

W.C. Beckjord Station

New 

Richmond/16 26,404.0**

No Duke Energy

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

No ZF Batavia LLC (Ford)*** Batavia 118.0

*Facility is located in EPA-recommended nonattainment area.

** EPA Clean Air Markets Division information for 2010-2011 indicates that the W.C. Beckjord Station has 

increased its SO2 emissions to over 70,000 tons per year in recent years.

***ZF Batavia (Ford) closed in late 2008.

Emission Controls 

The emissions data used by EPA in this technical analysis and provided in Table 11 represent 

emissions levels taking into account any control strategies implemented on stationary sources in the 

area up to and including 2008. EPA has not received any additional information on emissions 

reductions resulting from controls put into place after 2008. EPA believes that at least one SO2 source 

in Clermont County has been closed since 2008, and at least one Clermont County source may have 

significantly increased its emissions.

Meteorology (weather/transport patterns)

EPA analyzed the wind data in the vicinity of the Campbell County monitor in an effort to determine 

which areas outside Campbell County should be included in the designated nonattainment area. Wind 

data were considered from several meteorological measurement sites, including an air quality 

monitoring site in Cincinnati, Ohio and two airports in the Cincinnati area. The data suggested that 

Clermont County SO2 sources, such as the W.C. Beckjord Station power plant, could contribute to the 

SO2 NAAQS violation at the Campbell County monitor. Data from Cincinnati/Northern Kentucky 

International Airport indicated that during the hours when the monitor showed exceedances of the 

2010 SO2 NAAQS, the wind was blowing from the east and east-southeast. This meteorological data 

is expected to be generally representative of Campbell County. EPA also used the HYSPLIT 

Trajectory Model to create wind trajectories showing the path that winds may have followed over 

several hours. This model uses a forecast meteorological dataset instead of surface wind observations. 

The trajectories indicated that airflow tended to come from the east during the hours with monitored 

SO2 NAAQS exceedances, which also supported the inclusion of a portion of Campbell County in the 

nonattainment area. Full details of this meteorological analysis can be found in the TSD for Kentucky. 

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

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

and air flow into and out of the valley, the geographical and topographical features of the area are not 
22

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

role in determining the nonattainment boundary. 

Jurisdictional Boundaries 

Clermont County is not currently nonattainment for SO2. EPA is recommending designating Pierce 

Township in Clermont County, because it contains a large SO2 source which is believed to contribute 

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

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

defining Ohio’s nonattainment areas.

Other Relevant Information

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

this area.

Conclusion

After considering the factors described above, based on a monitored violation, EPA intends to 

designate Pierce Township in Clermont County in Ohio as nonattainment for the 2010 SO2 NAAQS, as 

part of the Campbell County KY-OH Interstate Area. EPA believes that this partial-county area, in 

conjunction with portions of Campbell County, Kentucky, encompasses the appropriate nonattainment 

area for the 2010 SO2 NAAQS.