1 Draft Technical Support Document

Ohio Area Designations For the

2010 SO 2 Primary National Ambient Air Quality Standard

Summary

Pursuant to section 1 07(d) of the Clean Air Act , EPA must initially designate areas as either “unclassifiable”, “attainment”, or “nonattainment” for the 2010 one

- hour sulfur dioxide (SO 2 ) 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 ( part ial ): Center Township Washington County ( part ial ): Waterford Township Nonattainment

Nonattainment Nonattainment

Nonattainment

Steubenville OH

- WV * Jefferson County, OH (part ial ): Cross Creek, Steubenville, Warren, and Wells Townships 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 (part ial )

Census tracts 533.01, 529, 531, 519.03, 519.01 Clermont County, OH (part ial ): 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 document s for West Virginia and Kentucky

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

.2 Background

On June 3, 2010, EPA revised the primary SO 2 NAAQS (75 F R 35520, published on June 22, 2010). EPA revised the primary SO 2 standard by establishing a new one

- hour standard at a level of 75 parts per billion (ppb) which is attained when the three

- year average of the 99 th percentile of one

- hour daily maximum concentrations does not exceed 75 ppb. EPA has determined that this is the level necessary to provide protection of public health with an adequate margin of safety, especially for children, the elderly and those with asthma. These groups are particularly susceptible to the health effects associated with breathing SO 2

. EPA is revoking the two prior primary standards of 140 ppb evaluated

over 24 hours, and 30 ppb evaluated over an entire year because 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 E PA is not designating areas in this process on the basis of the secondary standard.

EPA’s SO 2 Designation Approach

Section 107(d) of the Clean Air Act requires that not later than one year after promulgation of a new or revised NAAQS, state Governors m ust 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 st ate’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 th e 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

propose d 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 in tends 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 SO 2 concentrations) ; 3) me teorology (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 organiza tion) , 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 prov ided 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 SO 2 standard and any modifications from these recommendations.

Definition of important terms used in this document:3

1) Designated nonattainment area

– an area which EPA has determined, based on a s tate
recommendation and/ or on the technical analysis included in this document, has violat ed the 2010 SO 2 NAAQS

, based on the most recent three years of air quality monitoring data, or contributes to a violation in a nearby area.

2 ) Recommended nonattainment area

– an area a s tate or t ribe 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 exceed s 75 ppb, as described in Appendix T of 40 CFR part 50.

4 ) 20 10 SO 2 NAAQS

– The NAAQS for SO 2 promulgated in 20 10

. This NAAQS is 75 ppb, b ased on

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

- hour average concentrations. See 40 CFR Part 50.17.

5) Design Value

- a statistic computed according to the data handling procedures of the NAAQS (in 40 CFR 50 Appendix T) that , by comparison to the level of the NAAQS , indicates whether the area is violating the NAAQS

.

A. Technic al analysis for Lake County , OH

Introduction

This technical analysis for the Lake County Area identifies the monitor that violate d the 2010 SO 2 NAAQS, and evaluates nearby counties for contributions to SO 2 concentrations in the area. EPA has

evaluated this county and nearby counties based on the evidence for the factors recommended in the March 24, 2011 EPA guidance

. This county is listed above in Table 1.

Figure 1 shows the proposed nonattainment area and the monitor location.4

Figure 1. Map of Lake County , OH Nonattainment Area.

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

- 2010. EPA intends to designate Lake County , O hio as nonattainment for the 2010 SO 2 NAAQS, based upon currently available information , including the monitored design value for 2009

- 2011.

Detailed Assessment

Air Quality Data

This factor considers the SO 2 air quality monitoring data, including the design values (in ppb )

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

200 9

- 2011 period. The 2010 SO 2 NAAQS design value for Lake Co unty is shown in Table 2

.5

Table 2 . Air Quality Data for Lake County Nonattainment Designations

County State

Recommended

Nonattainment? Monitor Air

Quality System ID Monitor Location SO 2 Design Value,

2009

- 2011 (ppb)

Cuyahoga No 39

- 035

- 0038 Cleveland 71

No 39

- 035

- 0045 Cleveland 42

No 39

- 035

- 0060 Cleveland 73 *

No 39

- 035

- 0065 Newburgh Hts 38

Lake Yes 39

- 085

- 0003 Eastlake 33

Yes 39

- 085

- 0007 Painesville 157

Ashtabula No 39

- 007

- 0001 Conneaut 24

Monitor in Bold ha s the highest 2009

- 2011 design value in the area

. * Data for 2009 is incomplete

.

Lake C ounty shows a violation of the 2010 SO 2 NAAQS at one of its monitors . Therefore, some area in Lake County and possibly additional areas in surrounding counties must be designated

nonattainment

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

counties as candidates for nonattainment status.

Emissions and Emissions

- Related Data

Evidence of SO 2 emissions in the vicinity of a violating monitor is an important factor for determining whether a nearby area is contribut ing to a monitored violation. For this factor, EPA considered count y emission s data for SO 2 and data for sources within 50 kilometers of violating monitors

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

, which were the basis for Ohio’s submittal to the 2008 National Emissions Inventory ( NEI ) . EPA relied primarily on this data for its analysis of Ohio’s SO 2 designation recommendations.

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

contribu ting counties in and around Lake County, and sources emitting (or anticipated to contribute) greater than 100 t ons per year of SO 2 according to the 2008 NEI. Lake County is shown in bold

. Mo st of the facilities in Ashtabula and Cuyahoga Counties are over 40 kilometers from the Lake County monitors. Given their moderate level of SO 2 emissions and their distance from the Lake County monitor, these sources are not judged to be nearby sources co ntributing to the violation in Lake County.6

Table 3

. SO 2 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 SO 2

Emissions (tons per year)

Lake Yes Eastlake Power Plant Willoughby /17 505 2 1.0

Yes Painesville Municipal

Electric Plant Painesville /1 721 2 .0

Yes Carmeuse Lime

– Grand

River Operations Grand River / 4 910.0

Yes Lubrizol Corporation Painesville / 3 23.0

Yes Lubrizol Corporation

–

Wickliffe Facility Wickliffe /23 6.7

Cuyahoga No Lake Shore Power Plant Cleveland/39 4582.0

No The Medical Center

Company Cleveland/41 2203.0

No Cleveland Thermal LLC Cleveland / 45 1332.0

No ArcelorMittal Cleveland,

Inc. Cleveland /46 718.0

No Charter Steel

– Cleveland,

Inc. Cleveland /47 61.0

Ashtabula No FirstEnergy Ashtabula

Plant Ashtabula /4 4 3850.0

No Millennium Organic

Chemicals, Inc. Plant 2 Ashtabula /44 20.0

No Millennium Organic

Chemicals, Inc. Plant 1 Ashtabula /45 6.4

No USA Waste Geneva

Landfill Geneva /28 2.9

Emission C

ontrols

The emissions data used by EPA in this technical analysis and provided in Table 3 represent emiss ions levels taking into account any control strategies implemente d on stationary sources up to and including

2008

. EPA has not received any additional information on emissions reductions resulting from controls put into place after 2008.

Meteorology (weather/transport patterns)

While meteorological records for Cleveland i ndicate 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. T herefore, sources in all directions can have some potential contribution.

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

Geography/

T opography (mountain ranges or other air basin boundaries)

Lake County is adjacent to Lake Erie . The area can experience lake and land breezes, but the geographical and topographical features of the area are not considered to significantly limit air pollution transport. Therefore, this factor did not play a significant role in determining the nonattainment boundary.7

Jurisdictional B oundaries

There are no current SO 2 nonattainment areas in Lake County and the surrounding region. The

recommended nonattainment area for the 2010 SO 2 NAAQS is Lake County. The SO 2 sources which

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

SO 2 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 boundar ies

.

Other Relevant Information

EPA did not r eceive 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 SO 2 NAAQS

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

. The large facilities in the neighboring counties are 40 kilometers or more from the violating Lake Co unty monitor, and are not judg ed to contribute significantly to the

monitored violation. EPA believes that Lake County encompass es the appropriate initial

nonattainment area based on the monitored viola tion of the 20 10 SO 2 NAAQS.

B. Technical Analysis for the M uskingum River , OH Area

Introduction

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

SO 2 NAAQS

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

has evaluated this county and nearby counties based on the evidence for the factors recommended in the March 24, 2011 EPA guidance

.

Figure 2 shows a map of the proposed nonattainment area including the monitor location.8

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 fo r the 2010 SO 2 NAAQS. For clarity, EPA will refer to this nonattainment area as the Muskingum River Area, since the primary source in the area is American Electric Power’s Muskingum River Power Plant. EPA intends to designate Center Township in Morgan C ounty and Waterford Township in Washington County in Ohio as the Muskingum River

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

above in Table 1

.

Detailed Assessment

Air Quality Data

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

- 2011

. The 2010 SO 2 NAAQS design value for Morgan

C ounty is shown in Table 4

.

Table 4 . Air Quality Data for the Muskingum River Area

County State

Recommended

Nonattainment? Monitor Air

Quality System ID Monitor Location SO 2 Design Value,

200 9

- 20 11 ( ppb )
Morgan Yes 39

- 115

- 0004 Hackney, OH 1809

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

, some area in this

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

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

candidates for nonatta inment status.

Emissions and Emissions

- Related Data

Evidence of SO 2 emissions in the vicinity of a violating monitor is an important factor for determining whether a nearby area is contributing to a monitored violation. For this factor, EPA considered count y emission s data for SO 2 and data for sources within 50 kilometers of violating monitors

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

, which were the basis for Ohio’ s submittal to the 2008 NEI. EPA relied primarily on this data for its analysis of Ohio’s SO 2 designation r ecommendations.

Table 5 shows the annual emissions of SO 2 (given in tons per year) for potentially contributing

counties in and around the Muskingu m River Area and sources emitting (or anticipated to contribute) greater than 100 tons per year of SO 2 according to the 2008 NEI

. There are no significant sources of

SO 2 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 SO 2 sources within 50 kilometers of the violating monitor. Listed below are the sources which are considered most likely to impact the Mor gan County SO 2 monitor. They are all located

within 5 to 12 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 moni tor. 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

. SO 2 Emissions for the Muskingum River Area

County Facility

Located in

State

Recommended

Nonattainment

Area ? Facility Name Facility

Location /

Distance from

monitor Facility total

SO 2 Emissions (tons per year)

Washington Yes Muskingum River Power

Plant Waterford /5 133,3 38. 0

Yes Globe Metallurgical Waterford /5 1190.6

Yes Washington Energy

Facility Beverly /6 0.81

Yes AEP /Columbus Southern

Waterford Plant Waterford /12 0.6610

Emission C

ontrols

The emissions data used by EPA in this technical analysis and provided in Table 5 represent emiss ions levels taking into account any control strategies implemente d on stationary sources in the area up to and including 2008

. EPA has not received any additional information on emissions reductions resulting from controls put into place after 2008.

Meteorology (weather/transport patterns)

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/

T opogra phy (mountain ranges or other air basin boundaries)

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

Jurisdictional B oundaries

There are no current SO 2 nonattainment areas in Morgan and Washington Counties. The recommended Muskingum River nonattainment area for the 2010 SO 2 NAAQS consists of the two adjacent townships in Morgan and Washington Counties which are believed to enclose all SO 2 sources contributing to the monitored violations. The SO 2 ambient air quality monitor is also located within this area. Townships in Ohio have well established bou ndaries 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 SO 2 NAAQS

. EPA believes that the boundaries described herein encompass the appropriate nonattainment area for the 20 10 SO 2 NAAQS.11 Interstate Areas

The next three technical analyses discuss a set of nonattainment designations that cross state
boundaries. T he Steubenville OH

- WV Interstate Area, the Wheeling WV

- OH Interstate Area, and the Campbell County KY

- OH Interstate A rea are all adjacent to the Ohio River, which forms the boundary between Ohio and West Virginia , and between Ohio and Kentucky . The locati on of the main SO 2

sources and the monitors are such that Ohio , W est 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

monitor s that violate the 2010 SO 2 NAAQS and evaluates nearby counties fo r contributions to SO 2 concentrations in the area. EPA has evaluated this county and nearby counties based on the evidence

for the factors recommended in the March 24, 2011 EPA 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.12

Figure 3. Map of the Steubenville OH

- WV Interstate Nonattainment Area

O hio has recommended that four townships in Jefferson County , near the city of Steubenville, Ohio, be designated as nonattainment for the 2010 SO 2 NAAQS. 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 t o form the

Steubenville OH

- WV Interstate Area. Based on EPA's technical analysis described below, EPA is intending to designate Cross Creek, S teubenville, Warren, and Wells Townships in Jeffers on County as nonattainment for the 2 010 SO 2 NAAQS , in conjunction with Brooke County in West Virginia.

Detailed Assessment

Air Quality Data

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

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

.

Table 6 . Air Quality Data for the Steubenville OH

- WV Interstate A rea

County State

Recommended

N onattainment? Monitor Air Quality

System ID Monitor Location SO 2 Design Value,

20 0 9

– 201 1 ( ppb )

Jefferson , OH Yes 39

- 081

- 0017 Steubenville, OH 109
Brooke, WV Yes 54

- 009

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

- 009

- 0007 McKims 83
Brooke, WV Yes 54

- 009

- 0011 Marland Heights (Weirton) 174

Jefferson County shows a monitored violation of the 2010 SO 2 NAAQS. Therefore

, some area in this

c ounty must be designated nonattainment

. The absence of a violating monitor alone is not a sufficient

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

Brooke Count y, West Virginia

, are also showing violations of the 2010 SO 2 NAAQS, as discussed in the West Virginia TSD

. Based on evidence that violations are occurring in Jefferson County, Ohio, and Brooke County, West Virginia, EPA 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 SO 2 emissions in the vicinity of a violating monitor is an important factor for determining whether a nearby area is contributing to a monitored violation. For this factor, EPA considered count y emission s data for SO 2 and data for sources within 50 kilometers of violating monitors

. Ohio provided

this data with respect to Ohio sources in its June 3, 2011 submittal. Ohio’s emissions data came from facility reports to the state , which were the basis for Ohio’s submittal to the 2008 NEI. EPA relied primarily on these data and corresponding West Virginia data for its analysis of Ohio’s SO 2 designation recommendations.

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

Steubenv ille OH

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

Steubenville OH

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

.13

Table 7

. Ohio SO 2 Emissions for the Steubenville OH

- WV Interstate Area

County Facility

Located in

State

Recommended

Nonattainment

Area ? Facility Name Facility Location /

Distance from Monitor (km) Total SO 2 Emissions

(tons per year)

Jefferson No FirstEnergy

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

Yes American Electric

Power/Buckeye Power

Cardinal Power Plant Brilliant, OH /13 33,3 17 .0

Yes Severstal Wheeling, Inc Steubenville/ Mingo Junction, OH /5 700.0

Yes Severstal Wheeling, Inc Yorkville, OH /15 0.24

Yes Mingo Junction Energy

Center Mingo Junction,

OH /5 82. 0

No Titanium Metals Corp. Toronto, OH /9 0.20

Columbiana No Heritage

– WTI, Inc East Liverpool,

OH /30 3.60

Belmont No Severstal Wheeling, Inc. Martins Ferry,

OH /28 0.06

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

* The W.H. Sammis plant has recently reduced its emissions 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 SO 2 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

SO 2 source s in Carroll County and Belmont County within 50 kilometers are also ver y low in SO 2 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 a re located in the townships that Ohio recommended be designated nonattainment. The exception is the FirstEnergy ’s W.H. Sammis p ower p lant, which is

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

monit ors in Brooke County . The W.H. Sammis power plant significantly reduced its emissions after installing pollution controls in 2010. T he Columbiana County SO 2 monitor in East Liverpool

, about

14 kilometers north of the power plant , has measured a noticeable drop in SO 2 concentrations since

2010. Its SO 2 design value (three year average of 99 th percentile concentrations) was 117 ppb for

2007

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

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

- 2011, th e design value was

62 ppb, with a 99 th percentile value of 27 ppb in 2011. T he W.H. Sammis power plant is no t judged to be a nearby source contributing to the violation s at the Jefferson Coun ty monitor or the Brooke County

monitors and therefore does not merit inclusion in the Steubenville OH

- WV Interstate Area.

Emission C

ontrols

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

levels taking into account any control strategies implemente d on stationary sources in the area up to and including 2008

. Ohio did not submit any additional information on actual emissions reductions resulting from controls put into place after 2008 , but the Cle an Air Markets Division database suggests14

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/

T opography (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 B oundaries

There are no current SO 2 nonattainment areas in Jefferson County. The recommended nonattainment

area for the 2010 SO 2 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 SO 2 sources contributing to the monitored violations. The SO 2 ambient air quality monitors within Ohio are also located within this area. Townships in Ohio have well es tablished 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 Intersta te SO 2 nonattainment area

. EPA intends to combine this Ohio portion with Brooke Count y in West Virginia t o 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 20 10 SO 2 NAAQS

.

D. Technical Analysis for the Wheeling WV

- OH Interstate Area

This technical analysis for Belmont County identifies the mo nitor that violate d the 2010 SO 2 NAAQS

and evaluates nearb y counties for contributions to SO 2 concentrations in the area. EPA has evaluated this county and nearby counties based on the evidence for the factors recommended in the March 24,

2011 EPA guidance

.

Figure 5 shows a map of the proposed nonattainment area and the monitor location.15

Figure 5. Map of the Wheeling WV

- OH Interstate Nonattainment Area.

On June 3, 2011, Ohio recommended that Mead, Pease, Pultney, and York T ownships in Belmont County be designated as nonattainment for the 2010 SO 2 NAAQS. This recommendation was based on a monitored violation in Belmont County for the period 2008

- 2010. However, for the period 2009

- 2011 , t he design value of the Belmont County SO 2 monitor was below the 2 0 10 SO 2 NAAQS. Ohio

a mended its designation reco mmendation for Belmont County to unclassifiable in a letter dated April
12, 2012 . EPA reviewed the SO 2 sources and monitor locations in Marshall and Belmont Counties,

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

- OH

I nterstate Area, because it contains a large SO 2 source which may contribut e to violations at the Marshall County SO 2 monitor. In June 2011, West Virginia recommended that Marshall County, West Virginia, be designated nonattainment. Marshall County is acr oss the Ohio River from Belmont County. EPA believe s 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 Assessm ent

Air Quality Data

This factor considers SO 2 air quality monitoring data and the 200 9

- 20 11 design value (in ppb )

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

C ount ies are shown in Table 8

.16

Table 8 . Air Quality Data for Belmont County

County State

Recommended

Nonattainment? Monitor Air

Quality System ID Monitor Location SO 2 Design Value,

200 9

- 20 11 ( ppb )

Belmont, OH Ye s 39

- 013

- 3002 Shadyside, OH 61

Marshall, WV Yes 54

- 051

- 1002 Moundsville, WV 80

Marshall County shows a monitored violation of the 2010 SO 2 NAAQS for 2009

- 2011

. Monitoring

data Belmont County does not show a violation of the 2010 SO 2 NAAQS for 2009

- 2011

. However

, the absence of a violating monitor alone may not be a sufficient reason to eliminate a count y as a candidate for nonattainment status.

Emissions and Emissions

- Related Data

Evidence of SO 2 emissions in the vicinity of a violating monitor is an important factor for determining whether a nearby area i s contributing to a monitored violation. For this factor, EPA considered count y emission s data for SO 2 and data for sources within 50 kilometers of violating monitors

. Ohio provided this data in its June 3, 2011 submittal. Ohio’s emissions data came fro m facility reports to the state, which were the basis for Ohio’s submittal to the 2008 NEI. EPA relied primarily on this data for its analysis of Ohio’s SO 2 designation recommendations.

Table 9 shows the emissions of SO 2 in Ohio and West Virginia which may contribut e 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 pe r year of SO 2 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 Pow er 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 SO 2 concentrations. The two facilities in Martins Ferry, Ohio, are about 15 kilometers from the Marshall County monitor and

emit much less than one to n per year of SO 2 . 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 lo cated 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

. SO 2 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 SO 2 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 C

ontrols

The emissions data used by EPA in this technical analysis and provided in Table 9 represent emiss ions levels taking into account any control strategies implemente d on stationary sources in the area up to and including 2008

. EPA has not received any additional information on emissions reductions resulting from controls put into place after 2008.

Meteorology (weather/transport patt erns)

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/

T opography (mountain ran ges 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 B oundaries

Ohio does not have any current SO 2 nonattainment areas. For Belmont County, the intended

nonattainment area consists of one township along the Ohio River which encloses both the Belmont County SO 2 ambient air quality monitor and an Ohio SO 2 source which is be lieved to contribute to the monitored violations in Marshall County, West Virginia. Townships in Ohio have well established18

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

nonattainment areas.

Other Relevant I

nformation

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 2 010 SO 2 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, encompass es the appropriate nonattainme nt area for

the 20 10 SO 2 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 i dentifies

the monitor that violate s the 2010 SO 2 NAAQS and evaluates the adjacent Ohio counties for

contributions to SO 2 concentrations in the area

. EPA has evaluated this county and nearby counties

based on the evidence for the factors recommended in the March 24, 2011 EPA 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 i s violating the 2010 SO 2 NAAQS for the 2009

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

2010 SO 2 NAAQS for 2008

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

recommendations. See EPA’s TSD for Kentucky. Ohio did not include a discussion of the Cincinnati area in its June 3, 2011 letter, since the SO 2 monitors in that part of Ohio did not indicate that a nonattainment designation recommendation was necessary. However, after reviewing emiss ions 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 SO 2 NA AQS, to form the Campbell County KY

- OH

Interstate Area.

Detailed Assessment

Air Quality Data

This factor considers SO 2 air quality monitoring data and the 200 9

- 20 1 1 design value (in ppb )

calculated for the air quality monitor in Campbell County. The 2010 SO 2 NAAQS design value for Campbell C ounty is shown in Table 1 0

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

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

Table 1 0 . Air Quality Data for Campbell County

County State

Recommended

Nonattainment? Monitor Air

Quality System

ID Monitor Location SO 2 Design Value,

200 9

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

- 037

- 3002 Highland Heights, KY 89

Hamilton Co, OH No 39

- 061

- 0010 Cleves, OH 69 * *

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

** The 20 10 data were incomplete at this monitor.

Campbell County shows a monitored violation of the 2010 SO 2 NAAQS. Therefore

, some area in this

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

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

candidates for nonattainment status.

Emissions and Emissions

- Related Data

Evidence of SO 2 emissions in the vicinity of a violating monitor is an important factor for determining whether a nearby area is contributing to a monitored violation. For this factor, EPA considered count y emission s data for SO 2 and data for sources within 50 kilometers of violating monitors

. 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 SO 2 in 2008 (NEI08v2) , and more recent data from EPA’s Clean Air Markets Division suggests that its SO 2 emissions have increased significantly in more recent years. The W. C. Beckjord Station is located on the Ohio River in Pi erce Township, near the town of New Richmond, Clermont County, Ohio. Duke Energy also operates the W. H. Zimmer Generating Station in Clermont County. This power plant emitted 16,000 tons of SO 2 in 2008. The Zimmer Generating Station is located 27 kilom eters 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 C ampbell 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 t he sources closest to the monitor , only two emit more th an 1

, 000 tons of

SO 2 ; the others emit 100

- 600 tons of SO 2

. 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 SO 2 , 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 wh ich Duke Energy’s W. C. Beckjord Station is located

, should be designated nonattainment and combined with portion s of the neighboring Campbell County, Kentucky

, to form the Campbell Co unty KY

- OH Interstate Area.

Table 1 1 shows the total emissions of SO 2 f or potentially contributing sources emitting (or anticipated to contribute) more than 100 ton s per year of SO 2 according to the 2008 NEI

, in Hamilton and Clermont Counties, Ohio

.

Table 11

. Ohio SO 2 Emissions for the Campbell County (KY) Area

County Facility Located in

State

Recommended Facility Name Facility

Location /

Distance from Total SO 2

Emissions (tons per21 Nonattainment

Area ? monitor (km) year)

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

, 69 1 .0

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

, 005.0

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

, 143.0

No University of Cincinnati Cincinnati /13 616.0

No INEOS ABS (USA) Corporation Addyston /24 472.0

No Emerald Performance Materials,

LLC Cincinnati /27 306.0

No Rock

- Tenn Converting Company Cincinnati /16 257.0

No Caraustar Mill Group, Inc Cincinnati /13 118.0

Clermont No * Duke Energy W.C. Beckjord Station New

Richmond /16 26

, 404.0 **

No Duke Energy

W.H. Zimmer Generating Station Moscow /27 16

, 51 3 .0

No ZF Batavia LLC (Ford) *** Batavia 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 SO 2 emissions to over 70,000 tons per year in recent years.

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

Emission C

ontrols

The emissions data used by EPA in this technical analysis and provided in Table 1 1 represent
emiss ions levels taking into account any control strategies implemente d on stationary sources in the area up to and including 2008

. EPA has not received any additional information on emissions reductions resulting from controls put into place after 2008. EPA believes that at least one SO 2 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

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

data were considered from several meteorological measurement sites , including an air qualit y monitoring site in Cincinnati, Ohio and two airports in the Cincinnati area . The data suggest ed that Clermont County SO 2 sources, such as the W.C. Bec kjord Station power plant

, could contribute to the

SO 2 NAAQS violation at the Campbell County monitor

. Data from Cincinnati /Northern Kentucky

International A irport indicated that during the hours when the monitor showed exceedances of the

2010 SO 2 NAAQS , the wind was blowing f rom the east and east

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

SO 2 NAAQS exceedances , which also support ed 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/

T opography (mountain ranges or other air basin boundaries)

Clermont Count y border s the Ohio River . While the river valley can experience nighttime inversions and air flow into and out of the valley, the geographical and topographical features of the area are not22

considered to significantly limit air pollution transport. Therefore, this factor did no t play a significant role in determining the nonattainment boundary.

Jurisdictional B oundaries

Clermont Count y is not currently nonattainment for SO 2

. EPA is recommending designating Pierce Township in Clermont Count y
, because it contains a large SO 2 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 consideri ng the factors described above, based on a monitored violation, EPA intends to designate Pierce Township in Clermont Count y in Ohio as nonattainment for the 2010 SO 2 NAAQS , as part of the Campbell County KY

- OH Interstate Area . EPA believes that th is partial

- county area, in conjunction with portion s of Campbell County, Kentucky, encompass es the appropriate nonattainment

area for the 2010 SO 2 NAAQS.