## The Kentucky Fine Particulate Matter (PM 2.5 

## ) Attainment
Demonstration for the Louisville, KY-IN,Cincinnati-Middletown, OH-KY-IN, and HuntingtonAshland, WV-KY-OH PM 2.5 

## Nonattainment Areas

Prepared by: Kentucky Division for Air Quality Submitted by Kentucky Energy and Environment Cabinet

November 2008PREFACE This document contains Kentucky’s modeling demonstr ation that the three multi -state areas currently designated as not attaining the annual fine particle National Ambient Air Quality Standard will attain the standard by April, 2010.

The three areas are:
The Huntington-Ashland, WV-KY-OH annual PM 2.5 nonattainment area is a multi-state nonattainment area, comprising:

• Cabell, Wayne and a portion of Mason County, West Virginia;

• Boyd County and a portion of La wrence County, Kentucky; and

• Lawrence, Scioto, and portions of Ad ams and Gallia Counties in Ohio.

The Louisville, KY-IN annual PM 2.5 nonattainment area is a multi-state nonattainment area, comprising:

• Bullitt and Jefferson Counties, Kentucky, and

• Clark and Floyd Counties and a portion of Jefferson County in Indiana.

The Cincinnati-Middletown OH-KY-IN annual PM 2.5 nonattainment area is a multi-state nonattainment area as well, comprising:

• Butler, Clermont, Hamilton and Warren Counties, Ohio;

• Boone, Campbell and Kenton Counties, Kentucky; and

• A portion of Dearborn County in Indiana.

VISTAS Background

When EPA promulgated regional haze regulations on July 1, 1999, it estab lished requirements that states and tribes submit implementation plans to demonstrate reasonable progress towards the ultimate visibility goals of the rule. The first demonstration of reasonab le progress is to be made for the year 2018 and state implementation plans were due December 2007. EPA also offered an optional approach that groups of states might collaborate in regional analyses of the haze problem. This option showed promise in allowing more cost-effective analyses and the southeastern states opted to follow this option. Southeastern States Air Resource Managers Inc. (SESARM) accepte d responsibility for regional planning organization work tasks on behalf it its member ag encies pursuant to this option.
The member agencies of SESARM de termined that it was appropriate to expand the collaborative effort for the regional haze program beyond their member bounda ries and invited Virginia and West Virginia to join the group. A memorandum of agreement was arranged among the agencies and executed on August 22, 2001. The effort was named the Visibility Improveme nt State and Tribal Association of the Southeast (VISTAS). Since that time, the agencies have worked together to organize thei r efforts, develop work task lists and schedules, procure professional services, and support ad ministrative operations. Bylaws were developed and agreed upon by the participating me mbers. An organizational structure was created including an oversight committee, an operations committee, and various work groups. This early planning has served the project well a nd much progress has been made.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, ii and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 ASIP Project Background
On December 17, 2004, EPA made fine particle (PM 2.5 ) nonattainment determinations for at least one area in seven of the states participating in the VISTAS regional haze project. They are Alabama, Georgia, North Carolina, Kentucky, Tennessee, Virginia, and We st Virginia. In addition, South Carolina has one three-county area that was designated as unclassifiable in the same act ion. EPA’s Clean Air Interstate Rule (CAIR) modeling indicated that certain nonattain ment areas may still be in nonattainment after full implementation of CAIR. These areas include Jefferson County, Al abama, and Clayton and Fulton Counties in Georgia.

The PM 2.5 compliance date is April 2010 unles s a state demonstrates that more time is necessary in which case up to five additional years may be grante d. The nonattainment designations triggered the requirement for development of state implementation plans (SIPs) that will be due in April 2008. The guidance from EPA indicates that a significant requirement of PM 2.5 SIPs will be attainment demonstrations using, at least in part, modeling analys es to define effective em issions control strategies and confirm that attainment can be achieved after implementation of the strategies. 2009 is the modeling year for the PM 2.5 attainment demonstration and also is an in terim analysis year fo r the VISTAS regional haze demonstration.
In April of 2004, EPA determined areas that were not meeting the 8-hour ozone st andard. States having one or more 8-hour ozone nonattainment areas in th e Southeast are Alabama, Georgia, Kentucky, North Carolina, South Carolina, Tennessee, Virginia, and West Virginia. EPA required attainment of the 8-hour ozone standard in basic nonattainment areas by J une 15, 2009, and in moderate nonattainment areas by June 15, 2010. This required states with basic 8- hour ozone nonattainment areas to model 2008 as the SIP modeling demonstration year while moderate nona ttainment areas will requi re 2009 as the modeling year. Given that North Carolina and Virginia have two-year SIP approval processes, there is an immediate need to complete an analysis of ozone attainment using air quality modeling.
The states participating in the VI STAS project (the SESARM EPA Re gion 4 states plus Virginia and West Virginia from Region 3) concl uded that a collaborative process was the most efficient approach for the collective states to develop information upon which to base the PM 2.5 and 8-hour ozone attainment demonstrations. The local air regulatory agenci es for Jefferson County, AL, Jefferson County, KY, Mecklenburg County, NC, Forsythe County, NC, K nox County, TN, and Shelby County, TN, also became signatory parties to this co llaborative effort. SESARM coordi nated activities among participating agencies and oversaw the performance of the invent ory and modeling tasks in parallel with the VISTAS regional haze project tasks.

The name of this collaborative effort is the Associ ation for Southeastern Inte grated Planning (ASIP). SESARM was awarded a grant from EPA on February 8, 2005, to conduct what was originally called the fine particle SIP development support pr oject but has become known as ASIP.

The VISTAS-ASIP contact informa tion is at www.vistas-sesarm.org.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, iii and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 

### EXECUTIVE SUMMARY
INTRODUCTION

Fine particulate matter, also known as fine particles and PM 2.5 , refers to airborne pa rticles less than or equal to 2.5 micrometers (μm) in diameter. Fine part icles are treated as though they are a single pollutant, but they come from many different sources an d are composed of many different compounds. PM 2.5 exposure adversely affects human hea lth, especially respiratory and card iovascular systems. Individuals particularly sensitive to PM 2.5 exposure include children, people with heart and lung disease, and older adults.

A variety of meteorological and geog raphic factors influence the concentr ation levels of fine particles, including both the regional and local distribution of urbanized areas, primary and precursor emissions sources, and natural features su ch as oceans and forests. PM 2.5 concentrations can also be high and exceed the national ambient air quality standards (NAAQS ) for fine particulate matter at any time of the year. Therefore, the United Stat es Environmental Protection Agency (USEPA) mandates the year round monitoring of PM 2.5 concentrations throughout the country (40 CFR 58.App. D, 4.7).

NATIONAL AMBIENT AIR QUALITY STANDARD

In 1997, the USEPA promulgated the primary (h ealth) and secondary (welfare) NAAQS for PM 2.5 (40 CFR 50.7), setting the standard at a 15.0 micrograms per cubic meter (μg/m 3 ) annual average and at a 65 μg/m 3 daily or 24-hour av erage. In 2006, the US EPA revised the daily standard from 65 μg/m 3 to 35 μg/m 3 . A violation of the annual PM 2.5 NAAQS occurs when the annual average PM 2.5 concentration averaged over a three-consecutive-year pe riod is equal to or greater than 15.1 μg/m 3 . A violation of the daily PM 2.5 NAAQS occurs when the annual 98 th percentile of daily PM 2.5 concentration averaged over a three-consecutive-year period is equal to or greater than 36 μg/m 3 . The annual or daily PM 2.5 design value for a nonattainment area is the highest monitor’s design value in that area.

The USEPA designated areas as nonattainment for the annual PM 2.5 NAAQSs based upon air quality monitoring data measured during 2001, 2002, and 2003. Th e effective date of nonattainment designations was April 5, 2005. USEPA is in the process of designating areas for the revised daily PM 2.5 NAAQS which will occur in December 2008. This attainment demonstration does not address the 2006 24-hour average NAAQS.

NATURE OF PROBLEM IN KENTUCKY

In Kentucky, there were thre e areas designated as nonattainm ent for violating the annual PM 2.5 standard (Figure 1). All areas of Kent ucky met the original daily PM 2.5 standard. This PM 2.5 attainment demonstration submittal covers the Louisville, KY-IN PM 2.5 nonattainment area (Bullitt and Jefferson counties), the Cincinnati-Middlet own, OH-KY-IN nonattainment area (Boone, Campbell, and Kenton counties), and the Huntington-Ashland PM 2.5 nonattainment area (Boyd and a portion of Lawrence counties). This submittal covers only the Kentuc ky portion of these nonattainment areas for which Kentucky has jurisdiction. However, the appendices associated with this documentation include modeling results for all areas a nd the demonstrations for other states for their areas.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, iv and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Figure 1. Annual PM 2.5 Nonattainment Counties for Kentucky (Louisville, KY-IN, area counties denoted by blue boxes, Cincinna ti- Middletown, OH-KY-IN, area counties denoted by gray boxes, and Huntington-Ashland, WV-KY-OH, area counties denoted by green boxes.)

The annual PM 2.5 concentrations in these nonattainment areas are analyzed by the percentages of their individual component sp ecies. In Cincinnati- Middletown, OH- KY-IN, and Huntington-Ashland, WVKY-OH, the organic carbon (OC) and sulfate (SO 4 ) components each account fo r approximately one-third of the total PM 2.5 mass. The ammonium component makes up approximately ten percent of the total PM 2.5 mass, and the remaining nitrate (NO 3 ), elemental carbon, crustal mate rial, and particle bound water components each contribute approximately five percent or less of the total PM 2.5 mass. The percentages of species contribution fluctuat e throughout the year with the most signi ficant changes to SO 4 and NO 3 . SO 4 is more pronounced in the summertime or warm season months than during the wintertime. NO 3The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, v and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 fluctuates from almost undetectable in the summertime to as much as ten percent contribution of the total PM 2.5 mass during the coldest po rtion of the winter.

In Louisville, KY-IN, the organic carbon (OC) and sulfate (SO 4 ) components each account for approximately one-fourth of the total PM 2.5 mass, the ammonium and the nitrate (NO 3 ) components make up approximately ten percent of the total PM 2.5 mass, and elemental carbon, crus tal material, and particle bound water components each contribute approximately five percent or less of the total PM 2.5 mass. The percentages of species contribution fluctuate throughout the year with the most significant changes to SO 4 and NO 3 . SO 4 is more pronounced in the summertime or warm season months than during the wintertime. NO 3 fluctuates from under five percent in the summertime to as much as twenty-four percent contribution of the total PM 2.5 mass during the coldest po rtion of the winter.

The speciated analysis of the PM 2.5 concentrations in the Louisville , KY-IN, the Cincinnati- Middletown, OH-KY-IN, and the Huntingt on-Ashland, WV-KY-OH, PM 2.5 nonattainment areas de monstrates that the OC and SO 4 components are the most important portions of the total PM 2.5 mass throughout the year. OC contributors are predominately attributed to biogenic emissions sources. SO 4 is associated with sulfur dioxide (SO 2 ) emissions. When evaluated across Kentuc ky and also throughout all three nonattainment areas and surrounding regions, the SO 2 is primarily from the point sour ce sector. For this reason, SO 2 emissions controls from point source s are believed to be the most appr opriate strategy for addressing the PM 2.5 nonattainment issues for these areas.

CONTROLS APPLIED

Several control measures already in place or bei ng implemented over the next few years will reduce stationary point, highway mobile, and nonroad mobile sources emissions. Expected federal and state control measures were modeled for the attainment year of 2009.

The federal control measures that were modeled incl uded the Tier 2 vehicle standards, the heavy-duty gasoline and diesel highway vehicle standards, low sulfur gasoline and diesel fuels, large nonroad diesel engines standards, the nonroad sp ark-ignition engines and recreational engines st andard, and the Clean Air Interstate Rule (CAIR).

The State control measures that were modeled are the NOx SIP Call Rule, which will reduce summertime NOx emissions from power plants and other industr ies, and also CAIR. Additional information is contained in Section 5 in the main narrative.

ATTAINMENT TEST RESULTS

A modeling assessment was done to determine if the c ontrol strategies currently being implemented and proposed would lead to attainment of the annual PM 2.5 NAAQS by the attainment year of 2009. The air quality modeling was applied in a re lative sense, similar to the mode ling assessment preformed for 8-hour ozone attainment demonstrations in previous years. Reviewi ng the modeling results of how PM 2.5 concentrations decrease in future years, and in add ition the geographic extent of these reductions, plays an important role for the State in determining if additional controls should be considered.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, vi and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 A modeled attainment test was appl ied to the air quality modeling results to determine if the annual PM 2.5 NAAQS will be met by 2009. The baseline period for the air quality modeling was 2002, the midpoint of the three years used for nonattainment designations. The future year of 2009 was selected for the air quality modeling projections becau se it is the attainment year.

The first step of the PM 2.5 modeled attainment test breaks down baseline PM 2.5 mass concentrations into the individual component species by calendar quarter fo r each federal reference m onitor (FRM) site in the nonattainment area. The Speciated Modeled Attainment Test, commonly referred to as SMAT, was used to calculate future quarterly mean concentration estim ates from the air quality modeling for each of these component species determined in step one. The future quarterly mean PM 2.5 values were then averaged to produce a future year annual average PM 2.5 concentration for each of the FRM sites. Finally, these future annual PM 2.5 values were compared to the annual PM 2.5 NAAQS (15.0 μg/m 3 ) to determine if the modeling exercise predicted at tainment of the standard.

For all Kentucky FRM sites in the Louisville, KY-IN, Cincinnati- Mi ddletown, OH-KY-IN, and Huntington-Ashland, WV-KY-OH, PM 2.5 nonattainment areas, the future annual PM 2.5 concentrations derived from the modeled attainment test were ≤ 15.0 μg/m 3 (Table 1).

During the comment period following the draft SIP submittal, it was noted by EPA that while the EPA’s Modeled Attainment Test Software (MATS) was not available during SIP development, the new tool is now available. In October, DAQ received MATS va lues from the VISTAS contractor and have added them to the table above. The MATS values were incorporated in the table above to compare SMAT with MATS; note that in all cases th e design values are less than ≤ 15.0 μg/m 3

. Therefore, the most recent modeling assessment tools av ailable indicate that the Kentucky portions of all three nonattainment areas will attain the annual PM 2.5 NAAQS by 2009.

Section 6 in the narrative provides modeled 2009 design values for the entire nonattainment areas. In addition further discussion of both SMAT and MATS is presented. Table 1. Summary of Current and Future Predicted Annual PM 2.5 Concentrations in VISTAS/ASIP Modeling

AIRS ID State County 2002 Annual DVC 2009 12 km CONC of PM SMAT 2009 12 km CONC of PM MATS 21-019-0017 KY Boyd 14.9 12.8 12.6 21-029-0006 KY Bullitt 14.9 13.1 13.0 21-111-0044 KY Jefferson 16.6 14.8 14.5 21-111-0048 KY Jefferson 16.1 14.2 14.0 21-111-0051 KY Jefferson 15.4 13.6 13.4 21-037-0003 KY Campbell 13.8 12.0 11.6 21-117-0007 KY Kenton 14.9 12.7 12.6The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, vii and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 The Kentucky Division for Air Quality (KYDAQ) provides in th is document a strong set of supplemental analyses further supporting that the Louisvil le, KY-IN, Cincinnati- Middletown, OH-KY-IN, and Huntington-Ashland, WV-KY-OH, PM 2.5 nonattainment areas will attain the annual PM 2.5 NAAQS by 2009. These analyses included investigating current air quality data trends along with the emission reductions that have recently occurred and still ye t to occur by 2009, and considering air quality modeling results from other regional and national modeling exercises.

The KYDAQ believes that the modeling attainment demonstration, in c onjunction with the supplemental analyses, provides the necessary evidence that th e Louisville, KY-IN, Cinc innati- Middletown, OH-KYIN, and Huntington-Ashland, WV-KY-OH, PM 2.5 nonattainment areas will attain the annual PM 2.5 NAAQS by the prescribed attainment date.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, viii and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, ix and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 

### TABLE OF CONTENTS

EXECUTIVE SUMMARY iii
1.0 INTRODUCTION 1 1.1 What is fine particulate matter? .......................................................................................... .. 1 1.2 What is the National Ambient Air Quality Standard? .......................................................... 2 1.3 Nature of Problem in Kentucky ............................................................................................ 2 1.4 Major Contributors to PM 2.5 in the Kentucky Nonattainment Areas .................................... 6 1.4.1 Conceptual Description of PM 2.5 ................................................................................... 7 1.5 Clean Air Act Requirements ................................................................................................ . 9
2.0 SIGNIFICANCE OF PM 2.5 PRECURSOR POLLUTANTS 11 2.1 PM 2.5 Component Species Analysis .................................................................................... 11 2.2 Attribution of Emissions Sources ....................................................................................... 14 2.3 Clean Air Fine Particulate Implementation Ru le Presumptions on Precursor Pollutants ... 17
3.0 ATTAINMENT DEMONSTRAT ION METHODS AND INPUTS 18 3.1 Analysis Method ........................................................................................................... ...... 18 3.2 Model Selection ........................................................................................................... ....... 19 3.2.1 Selection of Air Quality Model .................................................................................... 19 3.2.2 Selection of Meteorological Model .............................................................................. 20 3.2.3 Selection of Emissions Processing System .................................................................. 21 3.3 Selection of the Modeling Year .......................................................................................... 2 3 3.4 Modeling Domains .......................................................................................................... .... 24 3.4.1 Horizontal Modeling Domain ...................................................................................... 24 3.4.2 Vertical Modeling Domain .......................................................................................... 25 3.5 Baseline Emissions Inventory ............................................................................................. 25 3.5.1 Stationary Point Sources .............................................................................................. 2 7 3.5.2 Stationary Area Sources ............................................................................................... 2 8 3.5.3 Off-Road Mobile Sources ............................................................................................ 29 3.5.4 Highway Mobile Sources ............................................................................................. 30 3.5.5 Biogenic Emission Sources .......................................................................................... 30
4.0 MODEL PERFORMANCE EVALUATION 31 4.1 Modeling Performance Goals, and Criteria ........................................................................ 32 4.1.2 Domain-Wide Model Performance .............................................................................. 33 4.1.3 Nonattainment Area Model Performance .................................................................... 35 4.1.4 Air Quality Model Pe rformance Summary .................................................................. 35
5.0 CONTROLS APPLIED 37 5.1 Federal Control Measures .................................................................................................. . 37 5.1.1 Tier 2 Vehicle Standards .............................................................................................. 3 7The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, x and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 5.1.2 Heavy-Duty Gasoline and Diesel Highway Vehicles Standards ................................. 37 5.1.3 Large Nonroad Diesel Engines Rule ............................................................................ 37 5.1.4 Nonroad Spark-Ignition Engines and Recreational Engines Standard ........................ 38 5.1.5 NOx SIP Call in Surrounding States ............................................................................ 38 5.1.6 Clean Air Interstate Rule .............................................................................................. 39 5.1.7 Industrial Boiler/Proce ss Heater/RICE MACTs .......................................................... 44 5.1.8 Combustion Turbine MACTs ...................................................................................... 48 5.1.9 VOC 2-, 4-, 7-, and 10-year MACT Standards ............................................................ 48 5.1.10 Consent Agreements .................................................................................................. 48 5.2 State Control Measures .................................................................................................... ... 49 5.2.1 NOx SIP Call Rule ....................................................................................................... 49 5.2.2 Open Burning Bans ...................................................................................................... 50 5.2.3 Clean Air Interstate Rule .............................................................................................. 50 5.2.4 Fugitive Emissions ...................................................................................................... . 50
6.0 ATTAINMENT DEMONSTRATION 52 6.1 Attainment Test Introduction .............................................................................................. 52 6.2 Attainment Test Results ................................................................................................... ... 53 6.3 Supplemental Analyses and Weight of Evidence ............................................................... 55 6.3.1 Air Quality Modeling Metrics ...................................................................................... 55 6.3.2 Other Modeling Results ............................................................................................... 58 6.4 Unmonitored Area Analysis ................................................................................................ 64 6.5 Data Access ............................................................................................................... .......... 67
7.0 CLEAN AIR ACT SECTION 172C REQUIREMENTS 69 7.1 Reasonably Available Control Measures (RACM) ............................................................ 69 7.4 Reasonable Further Progress ............................................................................................... 71 7.5 Actual Emissions Inventory ................................................................................................ 71 7.6 Periodic Emissions Inventory ............................................................................................. 71 7.7 Other Measures ............................................................................................................ ....... 71 7.8 Compliance with Section 110(a)(2) .................................................................................... 72 7.9 Equivalent Techniques ..................................................................................................... ... 72 7.10 Contingency Measures ..................................................................................................... . 72
8.0 MOTOR VEHICLE EMISSIONS BUDGETS 73 8.1 Transportation Conformity ................................................................................................. 73 8.2 Pollutants to be Considered ............................................................................................... .. 73
9.0 REFERENCES 86The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, xi and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 

### LIST OF APPENDICES

Appendix A: Policy and Memorandums

Appendix B: Stakeholders Correspondence Re garding Motor Vehicle Emissions Budgets

Appendix C: Air Quality Data: Appendix C1 Ambient Air Data Appendix C2 Air Quality Data used for Modeling Attachment C1 Review & Assessment of Ambient Data to Support Model Performance Evaluation Appendix C3 AQS PM 2.5 Data for all Kentucky sites 2000-2007
Appendix D: Mode ling Protocol

Appendix E: Emissions Inventory Summary used in the VISTAS-ASIP Modeling

Appendix F: Emissions Inventory Documentation

Appendix G: Emissions Inventory Quality Assurance Project Plan

Appendix H: Emissions Modeling and Related

Appendix I: Meteorological Development Documentation

Appendix J: Model Performance Evaluation

Appendix K: Modeling Results

Appendix L: Attainment Test

Appendix M: State and Local Control Measures

Appendix N: Conceptual Description

Appendix O: OH, IN, and WV Submittals

Appendix P: Supporting Documentat ion from VISTAS and ASIP

Appendix Q: Public Hearing and Related

Appendix R: Statement of ConsiderationThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, xii and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 1 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 

### 1.0 INTRODUCTION

1.1 What is fine particulate matter?
Fine particulate matter, also known as fine particles and PM 2.5 , refers to airborne particles less than or equal to 2.5 micrometers (μm) in diameter. Fine particles are treated as though they are a single pollutant, but they come from many different sources and are composed of many different compounds. PM 2.5 exposure adversely affects human h ealth, especially respiratory and cardiovascular systems. Individua ls particularly sensitive to PM 2.5 exposure include children, people with heart and lung di sease, and older adults.

PM 2.5 can be liquid, solid, or can have a solid core surro unded by liquid. PM 2.5 can include material produced by combustion, or photochemi cal reactions, and can contain salt from sea spray and soil-like particles. Particles are di stinguished based on the method of formation. Primary particles are particles directly emitted into the atmosphere and retain the same chemical composition as when they were released. Second ary particles are those formed through chemical reactions involving atmospheric ox ygen, water vapor, ammonia, hydrox yl radical, nitrates, sulfur dioxide (SO 2 ), oxides of nitrogen (NO x ), and organic gases from natural and anthropogenic sources. PM 2.5 can therefore be composed of varying amounts of differe nt species, including:

• Sulfates

• Nitrates (usually found in the form of ammonium nitrate)

• Ammonium

• Hydrogen ion

• Particle bound water

• Elemental carbon

• Organic compounds

o Primary organic species (cooki ng and combustion processses)

o Secondary organic compounds

• Crustal material (includes calcium, aluminum, silicon, magnesium, and iron)

• Sea salt (generally only found at coastal monitoring sites)

• Transitional metals

• Potassium (generally from wood burning or cooking)

The most significant sources of PM 2.5 and its precursors are coal-f ired power plants, industrial boilers, and other combustion sources. These emissions are often transported over large distances. Other sources of PM 2.5 emissions include mobile sources, area sources, biogenic sources, fires, wind blown dust, and oceans.

A variety of meteorological and geographic factors influence the concentration levels of fine particles, including both the regional and loca l distribution of urbani zed areas, primary andThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 2 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 precursor emissions sources, and natural fe atures such as oceans and forests. PM 2.5 concentrations can also be high and exceed th e national ambient air quality standards (NAAQS) for fine particulate matter at any time of the year. Therefore the United States Environmental Protection Agency (USEPA) mandates the year round monitoring of PM 2.5 concentrations throughout the country ( 40 CFR 58.App. D, 4.7).

1.2 What is the National Am bient Air Quality Standard?
In 1997, the USEPA promulgated the primary (h ealth) and secondary (welfare) NAAQS for PM 2.5 (40 CFR 50.7), setting the standard at a 15.0 micrograms per cubic meter (μg/m 3 ) annual average and at a 65 μg/m 3 daily or 24-hour average. In 2006, the USEPA revised the daily standard from 65 μg/m 3 to 35 μg/m 3 . A violation of the annual PM 2.5 NAAQS occurs when the annual average PM 2.5 concentration averaged over a three-c onsecutive-year period is equal to or greater than 15.1 μg/m 3 . A violation of the daily PM 2.5 NAAQS occurs when the annual 98 th percentile of daily PM 2.5 concentration averaged over a three-consecutive-year period is equal to or greater than 36 μg/m 3 . The annual or daily PM 2.5 design value for a nonattainment area is the highest monitor’s design value in that area.

Since the 1977 amendments to the Clean Air Act (CAA), areas of the country th at violated the ambient standard for a particular pollutant were formally designated as nonattainment for that pollutant. This formal designation concept was retained in the 1990 Amendments (CAAA). With the implementation of the PM 2.5 standard, areas not meeting the standard were designated under Section 172 of the CAAA (subpart 1) and have five years from designation to attain the standard.

The USEPA designated areas as nonattainment for the annual PM 2.5 NAAQSs based upon air quality monitoring data measured during 2001, 2002, and 2003. The effective date of nonattainment designations was April 5, 2005. USEP A is in the process of designating areas for the revised daily PM 2.5 NAAQS, which will occur in D ecember 2008. This attainment demonstration does not addre ss the 2006 24-hour average NAAQS.

1.3 Nature of Problem in Kentucky
In Kentucky, there are three areas desi gnated as nonattainment for the annual PM 2.5 standard (Figure 1.3-1). All areas of Ke ntucky met the original daily PM 2.5 standard. This PM 2.5 attainment demonstration submittal covers the Louisville, KY-IN, PM 2.5 nonattainment area (Bullitt and Jefferson counties), the Cincinnati- Middl etown, OH-KY-IN, PM 2.5 nonattainment area (Boone, Campbell, and Kenton counties), and the Huntington-Ashland, WV-KY-OH, PM 2.5 nonattainment area (Boyd and a po rtion of Lawrence counties). The Indiana, Ohio, and West Virginia portions of the nonattainment ar eas are established in the appendices.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 3 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Figure 1.3-1. Annual PM 2.5 Nonattainment Bounda ries for Kentucky

Figure 1.3-2 displays the distribution of the PM 2.5 monitoring sites across Kentucky. A closer view of the PM 2.5 federal reference method (FRM) monito ring sites in the Louisville, KY-IN, Cincinnati-Middletown, OH-KY-IN, and Huntington-Ashland, WV-KY-OH, PM 2.5 nonattainment areas is found in Figure 1.3-3.

Figure 1.3-2. PM 2.5 Monitoring Sites In Kentucky Jefferson County

Bullitt County Boone County Kenton County

Campbell County

Boyd County

Lawrence County (Portion)The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 4 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Figure 1.3-3. PM 2.5 FRM Monitoring Sites in the Kentuc ky portion of the Louisville, KYIN, Cincinnati-Middletown, OH-KY-IN , and Huntington-Ashland, WV-KY-OH, Nonattainment Areas

Table 1.3-1 contains the quart erly and annual average PM 2.5 concentrations for these FRM monitors in the PM 2.5 nonattainment areas for the three-year period used in the nonattainment designation determinations. Table 1.3-1 also presents the 2002-2004 PM 2.5 design value for the FRM monitors based on these quarterly and annual averages. The historic quarterly, yearly, and design value air quality data for the FRM monitors in the three PM 2.5 nonattainment areas can be found in Appendix C.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 5 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Table 1.3-1. PM 2.5 Concentrations and Design Values for the FRM monitors in the Louisville, KY-IN, Cincinnati- Middl etown, OH-KY-IN, and Huntington-Ashland, WV-KY-OH, PM 2.5 Nonattainment Areas

As mentioned in Section 1.1, PM 2.5 is composed of many species from varying sources. Figure 1.3-4 presents the Kentuc ky statewide averaged PM 2.5 speciation data from the speciation trends network (STN) monitors for the year 2004. The figure presents sulfates (SO 4 ) and organic carbons (OC) as the main contributors to PM 2.5 , sulfates with 29%, organic carbon with 25%; ammonium (NH 4 ) contributes 11%; nitrates (NO 3 ) contribute 10%; elemental carbon (EC) is approximately 4%; and crustal material is 3% of the total PM 2.5 mass. The “other” portion of the PM 2.5 that accounts for 18% of the mass can be attributed to water (H 2 O), and other trace materials captured with the STN monitors. County FRM Monitoring Site Year 1st Quarter (Q1) 2nd Quarter (Q2) 3rd Quarter (Q3) 4th Quarter (Q4) Annual Average Design Value

Bullitt 21-029-0006 2002 11.57 15.45 20.66 11.09 14.69 14.2 2003 12.92 13.74 20.30 10.53 14.37
2004 11.61 13.66 18.10 11.12 13.62

Jefferson 21-111-0043 2002 12.0 16.4 26.4 13.9 17.2 15.9 2003 14.6 16.3 20.9 12.0 16.0
2004 12.5 14.5 18.0 13.0 14.5

Jefferson 21-111-0044 2002 12.14 17.63 26.47 13.57 17.45 15.6 2003 14.70 15.05 20.17 11.59 15.38
2004 12.43 13.50 17.77 12.50 14.05

Jefferson 21-111-0048 2002 10.93 16.00 25.31 13.46 16.43 15.2 2003 13.93 14.63 21.27 12.30 15.53
2004 10.84 13.85 18.21 11.95 13.71

Jefferson 21-111-0051 2002 11.08 17.88 20.94 13.00 15.73 14.4 2003 13.48 14.87 20.85 10.48 14.92
2004 11.05 12.19 16.71 10.59 12.64

Campbell 21-037-0003 2002 11.36 15.31 21.91 10.65 14.81 13.7 2003 12.26 13.27 18.22 9.94 13.42
2004 11.27 12.80 16.57 10.47 12.78

Kenton 21-117-0007 2002 10.83 14.95 22.18 12.29 15.06 14.3 2003 13.69 14.06 18.94 10.50 14.30
2004 11.79 13.26 17.86 10.77 13.42

Boyd 21-019-0017 2002 12.00 17.89 21.59 10.69 15.54 14.3 2003 12.39 13.12 19.39 10.83 13.93
2004 11.42 13.00 17.90 10.85 13.29The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 6 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 

### Kentucky PM 2.5 Speciated Trends Network 2004 Average Percentage Composition

Nitrate

10%

Sulfate 29%

Ammonium 11% Organic carbon 25% Elemental carbon 4% Crustal component 3% Other 18%

Figure 1.3-4. Kentucky PM 2.5 Speciation for 2004

1.4 Major Contributors to PM 2.5 in the Kentucky Nonattainment Areas

When the annual PM 2.5 concentrations in Kentucky’s nonattainment areas are analyzed by the percentages of their individua l component species, a similar distribution of components are found. The SO 4 component accounts for approximately one-third of the total PM 2.5 mass; the OC component accounts for approxima tely one-fourth of the total PM 2.5 mass; NH 4, NO 3, and the remaining EC, crustal material, and partic le bound water components each contribute approximately ten percent or less of the total PM 2.5 mass. Individual plots of the speciated PM 2.5 data (similar to Figure 1.3-4) from the PM 2.5 monitoring locations in the nonattainment areas can be found in Appendix C.

The percentages of species contribution fluctuat e throughout the year with the most significant changes to SO 4 and NO 3 . SO 4 is more pronounced in the summertime or warm season months than during the wintertime. NO 3 fluctuates from under five pe rcent in the summertime to as much as twenty-four percent contribution of the total PM 2.5 mass during the coldest portion of the winter.

The speciated analysis of the PM 2.5 concentrations in the L ouisville, KY-IN, CincinnatiMiddletown, OH-KY-IN, and Huntington-Ashland, WV-KY-OH, PM 2.5 nonattainment areas demonstrates that the OC and SO 4 components are the most important portions of the total PM 2.5 mass throughout the year. OC is predominately at tributed to biogenic emissions sources. SO 4 isThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 7 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 associated with SO 2 emissions. When evaluated across Kentucky and also throughout both nonattainment areas and su rrounding regions, the SO 2 is primarily from th e point source sector. For this reason, SO 2 emissions controls from point s ources are believed to be the most appropriate strategy for addressing the PM 2.5 nonattainment issues for Kentucky’s annual PM 2.5 nonattainment areas.

1.4.1 Conceptual Description of PM 2.5 Further details on the nature of the PM 2.5 problem in the PM 2.5 nonattainment areas are discussed in Section 2 and can also be f ound in the “Conceptual Description of Fine Particulate Matter in Kentucky” section of Appendix N.

1.4.1.1 Speciated PM 2.5 in Kentucky nonattainment areas

EPA’s Speciated Trend Network (STN) PM2.5 monito rs collect filter-based 24-hr samples every third or sixth day; filters are analyzed to provide total PM2.5 mass a nd mass of individual. Sulfate (SO4) and particulate organic matter (P OM, also called Organi c Carbon, OC) are the dominant contributors to PM2.5 mass in these n onattainment areas. Sulfate peaks in the third quarter are primarily responsible for the peak PM 2.5 values in the third quarter. Sulfate levels are highest in the third quarter and lowest in th e first and fourth quarter s, ranging spatially and seasonally from 3-10 μ g/m3.

In contrast, organic carbon levels are fairly cons tant across the quarters, varying spatially and seasonally from 3-7 μ g/m3. Organic carbon speciation in urban areas suggests higher contributions from fuel combustion from mobile sources and primary carbon sources than in the Class I areas.

Nitrate (NO3) has a significant contributio n to PM2.5 in the KY nonattainment areas, particularly in the first quarter. Ammonium (NH4 ) is associated with sulfate or nitrate. Higher amounts of NO 3 are present in the cooler months, with very low concentrations in the third quarter. NH 4 NO 3 levels are higher in KY than in other no nattainment areas in the southeastern US, in part due to cooler winter time temperatures and in part due to closer proximity to the large source region for ammonia in the midwestern and central states.

Secondary pollutants (SO4, NO3, and OC) are the major contributors to PM2.5. Primary components (EC, soil) are relatively minor c ontributors. Thus precursors of secondary components (e.g. SO2, NOx, biogenic VOC) are mo re important contributors to PM2.5 mass than primary PM2.5 sources.

Collectively, these monitoring and modeling re sults confirm the conclusion that emissions control strategies to reduce emissions of SO2 cont ributing to sulfate would be most effective in reducing PM2.5 in Kentucky nonattainment areas. Re ducing anthropogenic emissions of primary PM2.5 contributing to particulate organic matter and of nitrous oxides and ammonia contributing to ammonium nitrate would likely reduce PM2 .5 concentrations more on winter days than summer days.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 8 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 1.4.1.2 Meteorological Contribution to Kentucky PM 2.5
Across the southeastern US, days with elevated PM2.5 c oncentrations most frequently occurred on days with high temperatures, high relative humidity, low wind speeds, and elevated PM2.5 mass on the previous day at upwind urban areas.

1.4.1.3 Emissions Contributing to Kentucky PM 2.5
Point source (electric utility and industry) SO2 emissions are the predominant precursors for ammonium sulfate, accounting for 96-98% of the total SO2 emissions in 2002 in the Kentucky nonattainment areas. (See Appendix E, Emissions Inventory Summary Tabl es) Ground level and point sources of nitrogen oxides and agricu ltural emissions of ammonia are the primary precursors for ammonium nitrate. Fossil fuel combustion and wood burning are the most important contributors to elemen tal carbon. Fine soil might be fr om construction or agricultural activities or windblown dust.

A combination of sources contri bute to organic carbon mass, in cluding wood burning, vegetative emissions, and fossil fuel combustion by industria l point sources, on road vehicles, and non road engines, and meat cooking. Car bon isotope studies indicated that modern sources of carbon, e.g. wood burning and vegetative emissions, are larger contributors to measur ed carbon than fossil (anthropogenic) sources of carbon (e.g. gasoline, diesel , coal). Elevated levels of carbon in the winter are likely due to wood burning (from fore st fires, prescribed fires, land clearing, agricultural burning, or residentia l, commercial or industrial w ood use). Elevated levels in summer are likely due to vegetative carbon em issions. Contributions from fossil fuel combustion (gasoline and diesel) are greater in urban areas than in rural areas.

1.4.1.4 Emission Sensitivity Analyses

To evaluate changes in PM2.5 mass loadings in response to changes in 2009 emissions from specific source and pollutant categories, emi ssions sensitivities were run using the CMAQ regional air quality model, the ASIP 2009 Base D inventory, and episodes selected in summer (Jun 1-Jul 10) and late fall (Nov 19-Dec 19) 2002.

Emissions in 2009 for several combinations of po llutants and source sectors were reduced by 30 percent in separate sensitivity runs for each stat e in the VISTAS region and for the other RPOs in the VISTAS 12 km modeling grid.

The first observation from these da ta is that the responses to em issions reductions are larger in the summer than in the winter. The greatest reductions in PM2.5 mass would be accomplished by further reducing SO2 emissions from electri c utilities and industr ial point sources beyond 2009 levels.

For the Louisville and Cincinnati nonattainment areas, SO2 reductions from EGU in KY and the MRPO states would have the greatest bene fits. For the Huntington-Ashland area, SO2 reductions from KY, TN, and WV would have the greatest benefits. SO2 reductions from EGUThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 9 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 and non-EGU in other southeastern states would al so be beneficial in reducing PM2.5 in the KY nonattainment areas. The largest response to SO2 emissions reductions in the winter is projected from SO2 emissions outside the ASIP 12 km modeling domain (Boundary Conditions). SO2 emissions from outside the 12 km domain are a significant, but smalle r contribution in the summer episode. This suggests that continenta l and/or intercontinen tal transport of SO2 emissions can have impacts comparable to or gr eater than impacts from local sources of NOx or primary carbon.

The model projects very little benefit to total PM2.5 of reduci ng emissions of nitrogen oxides from either ground or point sources in Kentucky in either winter or summe r. In the Southeast, ammonium nitrate levels are generally limited by availability of ammonia, so reducing ammonia emissions would be a more effective strategy to reduce ammonium nitrate than reducing nitrogen oxide emissions.

In both summer and winter the model projects some benefits from reducing local sources of primary carbon from ground (on road vehicles, o ff road engines, area sources) and point (industrial and electric u tility) sources and from fire emission s. Ground sources of primary PM are more important in Louisville and Cincinnati than in Huntington-Ashland and more important than point sources in all areas. Because bioge nic emissions dominate Volatile Organic Carbon (VOC) emissions, the model indicates little redu ction in total PM2.5 in winter and no reduction in summer from reducing anthropogenic VOC emissions.

In summary, SO2 reductions from electric utilities and industrial point s ources are likely to be most effective in reducing PM2.5 in Kentucky nona ttainment areas. From the mobile sector, reductions of primary carbon from local sources would be more e ffective than reductions of either VOC or NOx.

1.4.1.5 General Summary of Conceptual Description

In summary, sulfate and particulate organic matter are the most important contributors to PM2.5 in the Kentucky nonattainment areas. PM2.5 composition and mass are similar across the monitoring sites. Sulfate and carb on can be elevated due to contri butions from local sources. Emissions sensitivity results demonstrate the gr eatest benefits in redu cing PM2.5 from further reducing SO2 emissions from electric utilities and industrial point sources. Benefits of reducing primary carbon emissions from gro und sources are projected to be greater than reducing primary carbon from point sources; however this does not consider the difficulty in implementing controls for mobile versus point sources. Reduc ing regional emissions of ammonia is projected to reduce wintertime nitrate levels.

The complete conceptual description with techni cal data analysis, exceptions to generalizations, and illustrative charts is located in Appendix N.

1.5 Clean Air Act Requirements
Section 172(c) as amended, contains the genera l requirements for nonattainment areas. These requirements are listed below and are disc ussed in more deta il in Section 7.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 10 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Section 172(c) Nonattainment Plan Provisions (1) Reasonably available control measures (RACM) (2) Reasonable further progress (RFP) (3) Actual emissions inventory and periodic emissions inventory (4) New source review (NSR) (5) Permit requirements for new and modified sources (6) Other measures as may be necessary to pr ovide attainment by specified attainment date (7) Compliance with Section 110(a)(2) (8) Equivalent techniques (9) Contingency measuresThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 11 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 

### 2.0 SIGNIFICANCE OF PM 2.5 

### PRECURSOR POLLUTANTS As suggested in Section 1.4, SO 2 emissions are believed to be th e most appropriate strategy for addressing the PM 2.5 nonattainment issues for the Louisv ille, KY-IN, Cinci nnati-Middletown, OH-KY-IN, and Huntington-Ashland, WV-KY-OH, nona ttainment areas. This finding is based on several factors including:

• An analysis of the percen tage contribution of the PM 2.5 component species annually and seasonally within the nonattainment areas

• Attribution of emissions sources to these PM 2.5 component species

• Clean Air Fine Particulate Implementation Rule presumptions on precursor pollutants

2.1 PM 2.5 Component Species Analysis
The Federal Reference Method (FRM) monitoring data is used for demonstrating compliance with the PM 2.5 annual standard. Even though the Speciated Trend Network (STN) data provides speciation of PM 2.5 components, the STN data are not dire ctly comparable to the FRM data because slightly different monitoring and analy tical methods are used in the two networks. Relative contributions from sulf ate, nitrate, ammonium, organic carbon, elemental carbon, and soils (crustal) using the STN data were discu ssed in Section 1.4. The STN network provides a contribution assessment for specific components of PM 2.5 but the data cannot be used to demonstrate compliance with the PM 2.5 standard.

To provide a means to relate the two data sets in order to assign specific concentrations of the components of PM 2.5 to the FRM data, Neil Frank with the USEPA developed an approach to use the raw STN PM 2.5 data to appropriately es timate the components of PM 2.5 as measured by the FRM monitors. The approach is termed the “ S ulfate, A djusted N itrate, D erived W ater, I nferred C arbonaceous material balance approac H ”, method or SANDWICH.

The SANDWICH approach is discusse d in greater detail in Appendix L

Using the SANDWICH approach, it is possible to analyze the pe rcentage contribution of the individual PM 2.5 component species relative to the total FRM PM 2.5 mass. Figures 2.1-1 through 2.1-3 present the speciated mass c ontributions of the component species at representative FRM monitors in the Loui sville, KY-IN, Cincinnati, KY-OH, and Huntington-Ashland, KY-OH-WV, PM 2.5 non attainment areas. The speciated mass cont ributions displayed in these figures are for the 2002 baseline year used throughout this attainment demonstrati on. These figures illustrate daily speciated mass contributions from left to right according to the calendar year with the farthest right bar of the charts represen ting the 2002 annual averaged speciated mass contributions. Trends for these three monitors are the same as for other monitors in the same nonattainment area. From each of the three 2002 PM 2.5 speciated mass contribution plots, it is clear that SO 4 and OC are the dominant PM 2.5 components throughout the year. SO 4 is most pronounced during the summertime, but remains a reasonably importa nt component of the total PM 2.5 mass in any of the seasons. NO 3 contributions are important on several days in the first and fourth quarters and almost undetectable in the second and third quarters. NH 4 and H 2 O areThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 12 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 less dominant than SO 4 and OC but are reasonably consiste nt in each season. EC and crustal material are much less prevalen t at any time of the year.

Figure 2.1-1. 2002 PM 2.5 Speciated Mass Contribution at Jefferson County, KY, (Louisville 21-111-0048) using SANDWICH tec hnique to speciate FRM mass 2002 PM2.5 Speciated Mass Contributions at Jefferson Co. KY (21-111-0048)

0 5 10 15 20 25 30 351/14/20021/26/20022/7/20022/19/20023/3/20023/15/20023/27/20024/8/20024/20/20025/2/20025/14/20025/26/20026/19/20027/1/20027/13/20027/25/20028/6/20028/18/20028/30/20029/11/20029/23/200210/5/200210/17/200210/29/200211/10/200211/22/200212/4/200212/16/2002_Avg.

DateMass (μg m-3) Crustal EC OC H2O NH4 NO3 SO4The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 13 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Figure 2.1-2. 2002 PM 2.5 Speciated Mass Contribution at Kenton Co, KY, (Cincinnati, OH, non attainment area) us ing SANDWICH technique to speciate FRM mass 2002 PM 2.5 Speciated Mass Contributions at Kenton Co., KY 21-117-007

0 5 10 15 20 25 30 35 401/14/20021/26/20022/7/20022/19/20023/9/20023/21/20024/2/20024/14/20024/26/20025/20/20026/1/20026/25/20027/7/20027/19/20027/31/20028/12/20028/24/20029/5/20029/17/20029/29/200210/11/200210/23/200211/4/200211/16/200211/28/200212/10/200212/28/2002_Avg.

DateMass (μg m-3) Crust a EC OC H2O NH4 NO3 SO4The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 14 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Figure 2.1-3. 2002 PM 2.5 Speciated Mass Contribution at Boyd County, KY, in the Huntington-Ashland, KY-OH-WV, non-attainme nt area using SANDWICH technique to speciate FRM mass

2.2 Attribution of Emissions Sources
Precursor pollutants to PM 2.5 can be emitted directly, such as in smoke from a fire, or they can form from chemical reactions of gases such as SO 2 , nitrogen dioxide, and some organic gases. Sources of these precursor pollu tants include power plants, gaso line and diesel engines, wood combustion, and high-temperature industrial processe s such as smelters and steel mills. Other sources of the PM 2.5 precursor pollutants include mobile s ources, area sources, biogenics, fires, wind blown dust, and oceans.

The speciated analysis of the PM 2.5 concentrations in the L ouisville, KY-IN, CincinnatiMiddletown, OH-KY-IN, and Huntington-Ashland, WV-KY-OH PM 2.5 nonattainment areas presented above demonstrat es that the OC and SO 4 components are the mo st important portions of the total PM 2.5 mass throughout the year at all monitori ng locations. OC is predominately attributed to biogenic VOC emissions. SO 4 is associated with SO 2 emissions. NH 4 can have a variety of sources includi ng both industrial and natural processes. What little NO 3 is present in the PM 2.5 nonattainment areas throughout the year are attributed to NOx from combustion sources. Of all these components a nd associated emission sources, SO 4 is the only significant PM 2.5 component species found throughout the year that is attributed to a set of emissions source (SO 2 ) that are controlled through regulatory acti ons by the Kentucky Division for Air Quality (KYDAQ). 2002 PM2.5 Speciated Mass Contributions at Bo y d Count y , KY (21-019-0017)

0 5 10 15 20 25 30 35 40 45 501/14/20022/1/20022/13/20022/25/20023/9/20023/21/20024/2/20024/14/20024/26/20025/8/20025/20/20026/1/20026/13/20026/25/20027/7/20027/19/20027/31/20028/12/20028/24/20029/5/20029/17/20029/29/200210/11/200210/23/200211/4/200211/16/200211/28/200212/10/200212/28/2002_Avg.

DateMass (μg m-3) Crust a EC OC H2O NH4 NO3 SO4The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 15 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 When evaluated throughout the nonattain ment areas and across Kentucky, SO 2 is primarily from the point source sector. Figures 2.2-1, 2.2-2, and 2.2-3 present the SO 2 emissions from the various source sectors in the Louisville, KY-IN, Cincinnati- Midd letown, OH-KY-IN, and Huntington-Ashland, WV-KY-OH, PM 2.5 nonattainment areas, respectively. The magnitude of the point source sector completely masks the SO 2 emissions from all other source categories. When SO 2 emissions by source category are eval uated across Kentucky (Figure 2.2-4), the vertical axis scale is signifi cantly larger than the axis scal e used for the nonattainment area SO 2 emissions plots. Again, the magnitude of the point source sector completely masks the SO 2 emissions from all other source sectors.

Figure 2.2-1. Louisville, KY-IN, PM 2.5 Nonattainment Area SO 2 Emissions in 2002 Louisville Area SO 2 Emissions by Source Category

0 5000 10000 15000 20000 25000 30000 35000 40000 45000

Point A rea Mobile Nonroad Emissions (TPY)The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 16 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Figure 2.2-2. Cincinnati-Mi ddletown, OH-KY-IN, PM 2.5 Nonattainment Area SO 2 Emissions in 2002

Figure 2.2-3. Huntington-Ashland, WV-KY-OH, PM 2.5 Nonattainment Area SO 2 Emissions in 2002 NKY SO 2 Emissions by Source Categor y

0 2000 4000 6000 8000 10000 12000 14000 16000 18000

Point A rea Mobile Nonroad Emissions (TPY)

Ashland Area SO 2 Emissions by Source Categor y

0 10000 20000 30000 40000 50000 60000 70000

Point A rea Mobile Nonroad Emissions (TPY)The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 17 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Figure 2.2-4. Kentucky Total PM 2.5 Nonattainment Area SO 2 Emissions in 2002

2.3 Clean Air Fine Particulate Implementation Rule Presumptions on Precursor Pollutants

The USEPA’s Clean Air Fine Particulate Implementation Ru le (72 FR 20586), commonly referred to as the PM 2.5 Implementation Rule, guides States as they develop state implementation plans in response to annual and/or daily PM 2.5 nonattainment. It establishes a hierarchy of precursor pollutants: SO 2 is always considered a precursor, NOx is presumptively a precursor, and VOCs and ammonia are presumed not to be precursors. Kentucky considers SO 2 and NOx to be pollutant precursors.

The PM 2.5 Implementation Rule allows states to exempt NOx by demonstrating that NOx emissions are not a significan t contributor to an area's PM 2.5 nonattainment problem and that the area is not a source of a PM 2.5 transport problem. The PM 2.5 precursor NOx, and direct PM 2.5 have been deemed insignificant in the Hunti ngton-Ashland, WV-KY-OH, nonattainment area for mobile budgets for conformity as discusse d in a later section in this document. Kentucky Total SO 2 Emissions by Source Category

0 20000 40000 60000 80000 100000 120000 140000

Point A rea Mobile Nonroad Emissions (TPY)The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 18 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 

### 3.0 ATTAINMENT DEMONSTRAT ION METHODS AND INPUTS The attainment modeling for the Louisville , KY-IN, Cincinnati- Middletown, OH-KY-IN, and Huntington-Ashland, WV-KY-OH, PM 2.5 nonattainment areas was performed in conjunction with the regional haze modeling being done by the Southeast Regional Planning Organization (RPO), Visibility Improvement State and Tribal Association of the Sout heast (VISTAS), and the PM 2.5 and ozone (O 3 ) modeling being done by the Associa tion of Southeastern Integrated Planning (ASIP). VISTAS and AS IP are run by the ten Southeas t states (Alabama, Florida, Georgia, Kentucky, Mississippi , Kentucky, South Carolina, Te nnessee, Virginia and West Virginia). Since the regional haze and PM 2.5 modeling use annual simulations and includes an intermediate year that is the attainment year required for the Louisv ille, KY-IN, CincinnatiMiddletown, OH-KY-IN, and Hunt ington-Ashland, WV-KY-OH, PM 2.5 nonattainment areas, the KYDAQ decided to use this modeling for its attainment demonstration. The sections below outline the methods and inputs used by VISTAS/ASIP for the regional modeling.

3.1 Analysis Method
The modeling analysis is a complex technical eval uation that begins by se lection of the modeling system. VISTAS decided to use the following modeling system:

• Meteorological Model: The Pennsylvania State University/National Center for Atmospheric Research (PSU/NCAR) Meso scale Meteorological Model (MM5) is a nonhydrostatic, prognostic meteorological model r outinely used for urban- and regionalscale photochemical, fine particulate matte r, and regional haze regulatory modeling studies.

• Emissions Model: The Sparse Matrix Oper ator Kernel Emissions (SMOKE) modeling system is an emissions modeling system that generates hourly gridded speciated emission inputs of mobile, nonroad mobile, area, point , fire, and biogenic emission sources for photochemical grid models.

• Air Quality Model: The USEPA’s Models-3/ Community Multiscale Air Quality (CMAQ) modeling system is a “One-Atmosphe re” photochemical grid model capable of addressing O 3 , particulate matter, visibility, and acid deposition at regional scale for periods up to one year.

Additionally, a historical year was selected to model that re presented typical meteorological conditions in the Southeast when high ozone, high PM 2.5 , and poor visibility were observed throughout the region. Once the hist orical year is selected, mete orological inputs are developed using the meteorological model. Emission inventories are also deve loped for the historical year and processed through the emissions model. These inputs are used in th e air quality model to predict ozone, PM 2.5 , and visibility, with the results compar ed to the historic data. The model performance is evaluated by comparing the modele d predicted data to the historic air quality data.

Once model performance is deemed adequate, typi cal baseline and future year emissions are processed through the emissions model. For this demonstration, the base line year was 2002, which corresponds with the same year as the historic meteorology used in the modeling. The attainment future year KYDAQ is using for th is demonstration is 2009, since the mandatoryThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 19 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 attainment date for the Louisville, KY-IN, Cincinnati- Middletown, OH-KY-IN, and HuntingtonAshland, WV-KY-OH, PM 2.5 nonattainment areas is April 5, 2010. The attainment date is set prior to the completion of the 2010 calendar year; therefore the a ttainment of the NAAQS would have to be met by the end of the 2009. These emissions are pr ocessed through the air quality model with the meteorological inputs. The air quality modeling results are used to determine a relative reduction in future ozone, which is used in the attainment demonstration.

The complete modeling protocol used for th is analysis can be found in Appendix D.

3.2 Model Selection
To ensure that a modeling study is defensible, care must be taken in the selection of the models to be used. The models selected must be scie ntifically appropriate for the intended application and be freely accessible to all stakeholders. Scie ntifically appropriate means that the models address important physical and chemical phenomen a in sufficient detail, using peer-reviewed methods. Freely accessible means that model form ulations and coding ar e freely available for review and that the models are available to stak eholders, and their consul tants, for execution and verification at no or low cost.

The following sections outline the criteria for sel ecting a modeling system that is both defensible and capable of meeting the study's goals. These criteria were used in selecting the modeling system used for this modeli ng attainment de monstration.

3.2.1 Selection of Air Quality Model

3.2.1.1 Criteria For an air quality model to qualify as a candidate for use in an attainment demonstration, a State needs to show that it meets several general criteria:

• The model has received a scientific peer review.

• The model can be demonstrated applicable to the problem on a theoretical basis.

• Data bases needed to perform the analysis are available and adequate.

• Available past appropriate performance evalua tions have shown the model is not biased toward underestimates or overestimates.

• A protocol on methods and procedures to be followed has been established.

• The developer of the model must be willing to make the source code available to users for free or for a reasonable cost, and the model cannot otherwise be proprietary.

3.2.1.2 Overview of CMAQ The air quality model selected for this study was CMAQ version 4.5, which was the most recent release at the point the attainment modeling ex ercise started. For more than a decade, the USEPA has been developing the Models-3 CMAQ modeling system with the overarching aim of producing a “One-Atmosphere” air quality modeling system capable of addressing ozone, fineThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 20 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 particulate matter, visibilit y, and acid deposition within a co mmon platform. The original justification for the Models-3 development em erged from the challenges posed by the CAAA and the USEPA’s desire to develop an a dvanced modeling framework for “holistic” environmental modeling utilizing state-of-science representations of atmospheric processes in a high performance computing environment. The USEPA completed the initial stage of development with Models-3 and released the CMAQ model in mid 1999 as the initial operating science model under the Models-3 framework.

Another reason for choosing CMAQ as the atmo spheric model is the ability to do oneatmospheric modeling. Since KYDAQ will be usi ng the same modeling exercise for the ozone and PM 2.5 attainment demonstration state implementa tion plans (SIPs), as well as the regional haze SIP, having a model that can handle both oz one and particulate matte r is essential. A number of features in CMAQ’s theoretical form ulation and technical implementation make the model well suited for annual PM 2.5 modeling.

The configuration used for this modeling demonstra tion, as well as a more detailed description of the CMAQ model, can be found in Appendix D.

3.2.2 Selection of Meteorological Model

3.2.2.1 Criteria Meteorological models, either through objective, diagnostic, or prognostic analysis, extend available information about the state of the at mosphere to the grid upon which photochemical grid modeling is to be carried out. The criteria for selecting a meteorological model are based on both the models ability to accurately replicate important meteorological phenomena in the region of study, and the model's ability to interface with the rest of the modeling systems, particularly the air quality model. With these issues in mi nd, the following criteria we re established for the meteorological model to be used in this study:

• Non-Hydrostatic Formulation

• Reasonably current, peer reviewed formulation

• Simulates Cloud Physics

• Publicly available at no or low cost

• Output available in I/O API format

• Supports Four Dimensional Data Assimilation

• Enhanced treatment of Planetary Bo undary Layer heights for AQ modeling

3.2.2.2 Overview of MM5 The non-hydrostatic MM5 model is a three-dime nsional, limited-area, primitive equation, prognostic model that has been used widely in re gional air quality model applications. The basic model has been under continuous development, improvement, testing, and open peer-review for more than 20 years and has been used worldw ide by hundreds of scientists for a variety of mesoscale studies.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 21 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 MM5 uses a terrain-following non-dimensionalized pressure, or "sigma", vertical coordinate similar to that used in many ope rational and research models. In the non-hydrostatic MM5, the sigma levels are defined according to the initial hydrostatically balanced re ference state so that the sigma levels are also time-invariant. Th e gridded meteorological fields produced by MM5 are directly compatible with th e input requirements of “one atmo sphere” air-quality models using this coordinate. MM5 fields can be easily used in other regional air quality models with different coordinate systems by performi ng a vertical interpolation, followed by a mass-conservation readjustment.

Distinct planetary boundary layer parameterizati ons are available for air-quality applications, both of which represent sub-grid -scale turbulent fluxes of heat , moisture and momentum. One scheme uses a first-order eddy diffusivity formul ation for stable and neutral environments and a modified first-order scheme fo r unstable regimes. The other scheme uses a prognostic equation for the second-order turbulent kinetic energy, while diagnosing the other key boundary layer terms.
Initial and lateral boundary conditio ns are specified for real-dat a cases from mesoscale threedimensional analyses performed at 12-hour interv als on the outermost grid mesh selected by the user. Surface fields are analyzed at three-hour intervals. A Cre ssman-based techni que is used to analyze standard surface and radiosonde obse rvations, using the National Meteorological Center's spectral analysis, as a first guess. The lateral boundary data are introduced using a relaxation technique applied in the outermost five rows and columns of the coarsest grid domain.

Results of detailed performance evaluations of the MM5 modeling system in regulatory air quality application studies have been widely reported in the literature (e.g., Emery et al., 1999; Tesche et al., 2000, 2003) and many have involved comparisons with other prognostic models such as the Regional Atmospheric Modeling Sy stem (RAMS) and the Systems Application International Mesoscale Model. The MM5 enjoys a far richer applicatio n history in regulatory modeling studies compared with RAMS or other m odels. Furthermore, in evaluations of these models in over 60 recent regional scale air quali ty application studies since 1995, it has generally been found that the MM5 model tends to produce somewhat better photoch emical model inputs than alternative models.

The configuration used for this modeling demonstra tion, as well as a more detailed description of the MM5 model, can be found in Appendix I.

3.2.3 Selection of Emissions Processing System

3.2.3.1 Criteria The principal criterion for an emissions processi ng system is that it accurately prepares emissions files in a format suitable for the phot ochemical grid model being used. The following list includes clarification of this criterion and add itional desirable criteria for effective use of the system.

• File System Compatibility with the I/O API

• File PortabilityThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 22 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 • Ability to grid emissions on a Lambert Conformal projection

• Report Capability

• Graphical Analysis Capability

• MOBILE6 Mobile Source Emissions

• Biogenic Emissions Inventory System version 2 (BEIS-3)

• Ability to process emissions for the proposed domain in a reasonable amount of time.

• Ability to process control strategies

• No or low cost for acquisition and maintenance

• Expandable to support other species and mechanisms

3.2.3.2 Overview of SMOKE The Sparse Matrix Operator Kernel Emissi ons (SMOKE) Modeling System was originally developed at the Micro-computing Center of Nort h Carolina. As with most emissions models, SMOKE is principally an emission processing system and not a true emissions modeling system in which emissions estimates are simulated from “f irst principles”. This means that, with the exception of mobile and biogenic sources, its purpose is to provide an efficient, modern tool for converting emissions inventory data into the fo rmatted emission files required by an air quality simulation model. For mobile sources, SMOKE actually simulates emissions rates based on input mobile-source activity da ta, emission factors and output s from transportation traveldemand models.

SMOKE was originally designed to allow emissions data processing methods to utilize emergent high-performance-computing as applied to sparse-matrix algor ithms. Indeed, SMOKE is the fastest emissions processing tool currently availa ble to the air quality modeling community. The sparse matrix approach utilized throughout SMOKE permits both rapid and flexible processing of emissions data. The processing is rapid because SMOKE utilizes a series of matrix calculations instead of less efficient algorithms us ed in previous systems. The processing is flexible because the processing steps of tempor al projection, controls, chemical speciation, temporal allocation, and spatial allocation have been separate d into independent operations wherever possible. The results from these steps are merged together at a final stage of processing.

SMOKE contains a number of ma jor features that make it an attractive component of the modeling system. The model supports a variet y of input formats from other emissions processing systems and models. It supports bot h gridded and county total land use scheme for biogenic emissions modeling. SMOKE can accommodate emissions files from up to 10 countries and any pollutant can be processed by the system.

For additional information about the SM OKE model please refer to Appendix D.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 23 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 3.3 Selection of the Modeling Year
A crucial step to SIP modeling is the selection of the period of time to model to represent current air quality conditions and to project changes in air quality in re sponse to changes in emissions. The year 2002 was selected as the base year for several reasons.

The USEPA’s April 2007 Guidance on the use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goal s for Ozone, PM2.5, and Regional Haze (Attainment Modeling Guidance) identifies specific goals to consider wh en selecting one or more episodes for use in demonstrating reasonable progress in attaining th e regional haze air quality goals. The USEPA recommends that episode selection de rive from four pr incipal criteria:

• Simulate a variety of me teorological conditions

• Model time periods in which observed concen trations are close to the appropriate baseline design value or visibility impairment

• Model periods for which extensive air qua lity/meteorological data bases exist

• Model a sufficient number of da ys so that the modeled atta inment test applied at each monitor violating the NAAQS is based on multiple days

VISTAS adopted a logical, stepwise approach in implementing the Attainment Modeling Guidance in order to identify the most preferab le, representative modeling year. These steps include the following:

• Representativeness of Meteorological Conditions: The VISTAS meteorological contractor (BAMS) identified important meteor ological characteristics and data sets in the VISTAS region directly relevant to the evaluation of candidate annual modeling episodes.

• Initial Episode Typing: At the time of selection in 2003, meteorological and air quality data were available for 2002 for model i nputs and model performance evaluation. VISTAS used Classification and Regression Tree (CART) analyses to evaluate the candidate modeling years. The year 2002 was f ound to be representative of conditions in the other years. Subsequently, these analyses were repeated with the meteorological and air quality monitoring data for 2000 to 2004 to evaluate how well the 2002 modeling year represented the full 2000-2004 baseline period. This analysis confirmed that visibility and PM 2.5 concentrations in 2002 were representative of the fi ve-year baseline period. This analysis is discussed in more deta il in the project report in Appendix I.

• Data Availability: In parallel with the CART analysis , episode characterization analyses, collaborative investigations by VISTAS st ates (e.g., NCDAQ, Georgia DNR, FL DEP) intensively studied the availability of PM 2.5 , meteorological, and emissions data and representativeness of alternative baseline mode ling periods from a regulatory standpoint. Additionally, 2002 was the year that the USEPA was requiring states to provide emissions inventory data for the Comprehe nsive Emissions Reporting Rule (CERR), it made sense to use 2002 as the modeling year to take advantage of the 2002 inventory.

• Years to be used by other RPOs: VISTAS also considered what years other RPOs would be modeling, and several had already chosen calendar year 2002 as the modeling year.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 24 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 • After a lengthy process of integrated studies, the episode selection process culminated in the selection of calendar year 2002 (1 January through 31 December) as the most current, representative, and pragmatic choice for modeling. All of the USEPA criteria for model year selection were directly considered in this process together with many other considerations (e.g., timing of new emissions or aerometric data deliveries by the USEPA or the states to the modeling teams).

3.4 Modeling Domains
3.4.1 Horizontal Modeling Domain The CMAQ model was run in one-way nested grid mode. This allowed the larger outer domains to feed concentration data to the inner nested domain. One-way nesting is believed to be appropriate for the generally stagnant conditions experienced during Kentucky ozone episodes. Two-way nesting was not considered due to numer ical and computational uncertainty associated with the technique.

The horizontal coarse grid modeling domain boundaries were determined through a national effort to develop a common grid projection and boundary. A smaller 12-km grid, modeling domain was selected in an attempt to balance loca tion of areas of interest, such as ozone and fine particulate matter nonattainment areas. Processi ng time was also a factor in choosing a smaller 12-km grid, modeling domain.

The coarse 36-km horizontal grid domain covers th e continental United States. This domain was used as the outer grid domain for MM5 modeling with the CM AQ domain nested within the MM5 domain. Figure 3.4.1-1 shows the MM5 horizontal domain as the outer most, blue grid with the CMAQ 36-km domain nested in the MM5 domain.

Figure 3.4.1-1. The MM5 and CMAQ 36-km Horizontal DomainsThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 25 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 To achieve finer spatial resolution in the VIST AS states, a one-way ne sted high resolution (12- km grid resolution) was used. Figure 3.4.1-2 s hows the 12-km grid, modeling domain for the VISTAS region. This is the modeling domain on which the attainment te st results are based.

Figure 3.4.1-2. VISTAS 12-km Modeling Domain

3.4.2 Vertical Modeling Domain The vertical grid used in the MM5 modeling primar ily defines the CMAQ vertical structure. The MM5 model employed a terrain following coordi nate system defined by pressure, using 34 layers that extend from the surface to the 100 mb. A layer-averaging scheme was used to generate 19 vertical layers for CMAQ to reduce the computational cost of the CMAQ simulations. The effects of layer averaging we re evaluated in conjunction with the modeling effort and were found to have a relatively minor effect on the model performance metrics when both the 34 layer and a 19 layer CMAQ models we re compared to ambient monitoring data.

3.5 Baseline Emissions Inventory
The CAAA revised many of the provisions of the CAA related to attainment of the NAAQS and the protection of visibility in mandatory Class I Federal areas (certain national parks and wilderness areas). These revisions establishe d new emission inventory requirements applicable to certain areas that were de signated nonattainment for certain pollutants. In the case of particulate matter, the emission inventory provisions are in the general provision s under Section 172(c)(3). An inventory was developed for th e baseline year 2002 and projected to 2009. The pollutants inventoried include volatil e organic compounds (VOC), NOx, PM 2.5 , coarse particulate (PM 10 ), ammonia (NH 3 ) and SO 2 . Table 3.5-1 show the t ypical annual emissions from the various source sectors for the Loui sville, KY-IN, Cincinnati- Middletown, OH-KY-IN, and Huntington-Ashland, WV-KY-OH PM 2.5 nonattainment areas respectively for 2002. The values for Lawrence County are for the entire county, not just the census block that U.S.EPA designated as nonattainme nt. The baseline emissions in ventory for 2002 wa s developed forThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 26 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Kentucky following the methods described in Appe ndix F. Comprehensive tables of emissions for all counties and all polluta nts and all categories for the three nonattainment areas for 2002 and 2009 is located in Appendix E

Table 3.5-1. 2002 Annual Emission Summaries (in tons per year)

County VOC NOx SOx PM NH3

Point Area Mobile Non road Point Area Mobile Non road Point Area Mobile Non road Point Area Mobile Nonroad Point Area Mobile Non road

Boone 884 3,136 2,306 1,621 6,703 1,893 4,088 3,973 15,769 1,048 150 557 140 1,174 68 303 34 124 153 1
Campbell 186 1,882 1,313 519 55 532 1,979 1,989 1 467 78 277 85 474 33 88 0 93 84 0
Kenton 264 3,448 2,368 832 20 1,585 3,682 2,832 18 1,190 155 310 11 972 60 131 2 94 155 1
Bullitt 2,689 984 1,483 506 221 51 2,979 578 391 93 89 50 56 804 43 44 0 94 81 0
Jefferson 4,959 3,205 14,567 4,171 25,915 234 25,864 10,989 41,483 0 917 1,429 830 1,083 369 720 42 166 816 4
Boyd 3,083 780 991 312 7,046 40 1,213 3,319 9,711 542 54 482 1,256 712 21 131 336 38 44 0
Lawrence 98 374 409 223 17,129 87 785 726 48,874 96 30 85 335 216 14 30 31 28 20 0

There are five different emission inventory sour ce classifications: stationary point and area sources, off-road and on-road mob ile sources, and biogenic sources. Stationary point sources are those sources that emit greater than a specified tonnage per year, with data provided at the facility level. Electric gene rating utilities and i ndustrial sources are th e major categories for stationary point sources. Stationary area sour ces are those sources whose individual emissions are relatively small, but due to the large numbe r of these sources, the collective emissions from the source category could be signifi cant (i.e., dry cleaners, service stations, agricultural sources, fire emissions, etc.). These types of emissi ons are estimated on a countywide level. Biogenic sources are the natural sources like trees, crops, grasses, and natural decay of plants. The emissions from these sources are estimated on a countywide level.

Non-road (or off-road) mobile s ources are equipment that can have internal combustion engines but do not use the roadways, i.e., lawn mowers , construction equipment, railroad locomotives, aircraft, etc. The emissions from these sources , like stationary area sources, are estimated on a countywide level. On-road mobile sources are au tomobiles, buses, trucks, and motorcycles that use the roadway system. The emissions from th ese sources are estimate d by vehicle type and road type, and are summed to the countywide level.

In addition to the various source classifications , there are also various types of emission inventories. The first is the actua l base year inventory. This inve ntory is the base year emissions that correspond to the meteorological data used, which for this modeling effort is data from 2002. These emissions are used for evaluati ng the air quality model performance.

The second type of inventory is the typical base y ear inventory. This inventory is similar to the actual base year inventory, excep t that for sources whose emissions change significantly from year to year, a more typical emission value is used. In this modeling effort, typical emissions were developed for the electric generating units (EGUs) and the wildland fire emissions. The air quality modeling runs using the typical base y ear inventory are used to calculate relative reduction factors used in the at tainment demonstration test.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 27 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 The future year base inventor y is an inventory developed fo r some future year for which attainment of the PM 2.5 standard is needed. For this modeli ng project, the future year inventory will be 2009, the first complete year for which the sta ndard must be attained. It is the future base year inventory that control strategies and sensi tivities are applied to determine what controls, beyond those measures already included in the fu ture year base inventory, to which source classifications must be made in orde r to attain and ma intain the annual PM 2.5 standard.

The detailed discussions of the emissions inve ntory development can be found in Appendix E, and emission summaries by county for the entire Louisville, KY-IN, Ci ncinnati-Middletown, OH-KY-IN, and Huntington-Ashland, WV-KY-OH, nona ttainment areas are in Appendix F.

In the sections that follow, a synopsis of the in ventories used for each source classification is included. Below is an overview of the invent ories used for each source classification.

3.5.1 Stationary Point Sources

Point source emissions are emissions from indi vidual sources that are in a fixed location. Generally, these sources must have permits in order to construct and/ or operate and their emissions are inventoried on an annual basis. All sources emitting VOC are inventoried in Marshall, Livingston, Edmonson, Daviess, Ha ncock, Jefferson, Fayette, Scott, Boyd, Greenup, Boone, Kenton, Campbell and Christian counties. In the remaining counties, sources emitting greater than or equal to 100 tons per year, or sources that have between 25 and 100 tons per year that have a federal regulation requirement ar e inventoried on an annua l basis. Large NOx sources having minimum capacity to emit 100 tons pe r year (tpy) of a criteria pollutant, 10 tpy of a single hazardous air pollutant (HAP), or 25 tpy total of multiple HAPs are inventoried annually. Smaller sources have been inventorie d less frequently. For the purposes of this modeling, point source emissions data can be grouped into EGU sources and other non-EGU sources. Appendix F.1 documents the point sour ce modeling inventory development, including LMAPD inventory procedures, in more detail.

3.5.1.1 Electric Generating Units The actual base year inventory for the EGU sour ces used 2002 continuous emissions monitoring (CEM) data reported to the USEPA’s Acid Ra in program or 2002 hourly emissions data provided by stakeholders. These data provide hourly emissions profiles for SO 2 and NOx that can be used in air quality modeling. Emissions profiles are used to estimate emissions of other pollutants (VOC, carbon monoxide, NH 4 , PM 2.5 , soil-based on measured emissions of SO 2 and NOx.

Emissions from EGUs vary daily and seasonally as a function of variability in energy demand and utilization and outage schedu les. Since emissions from E GUs represent a significant portion of the emission inventory, a typical base year emissions inventory was developed to avoid anomalies in future-year emissions due to variability in meteorology, economic, and outage factors in 2002. This approach is consistent with the Attainment Modeling Guidance. To develop a typical year 2002 emi ssions inventory for EGU sources, each unit’s average CEM heat input for 2000 through 2004 was divided by the 2002 actua l heat input to generate a unit specific normalizing factor. This normalizing factor was then multiplied by the 2002 actual emissions.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 28 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 The heat inputs for the period 2000 through 2004 were used because the modeling current design values use monitored data from this same 5-y ear period. If a unit was shut down for an entire year during the 2000 through 2004 period, the averag e of the years the un it was operational was used. If a unit was shut down in 2002, but not permanently shutdown, the emissions and heat inputs from 2001 (or 2000) were used in the normalizing calculations.

As part of the air quality modeling, VISTAS, in cooperation with the other eastern RPOs, contracted with ICF Resources, L.L.C., to generate future year emission inventories for the electric generating sector of the contiguous Un ited States using the Integrated Planning Model (IPM). IPM is a dynamic linear op timization model that can be us ed to examine air pollution control policies for various pollu tants throughout the contiguous Un ited States for the entire electric power system. The dynamic nature of IP M enables projection of the behavior of the power system over a specified future period. Op timization logic in IPM determines the leastcost means of meeting electric generation an d capacity requirements while complying with specified constraints including air pollution re gulations, transmission bottlenecks, and plantspecific operational constraints. The versatility of IPM allows users to specify which constraints to exercise, and to populate IP M with their own datasets.

The IPM modeling runs took into consideration the USEPA’s Clean Air Interstate Rule (CAIR) implementation. The EGU emissions were deve loped and documented in Appendix H and I of the “ Documentation of the Base G2 and Best & Final 2002 Base Year, 2009 and 2018 Emission Inventories ” provided by the contractor an d that documentation is incl uded in Appendix F of this SIP entitled “Emission Inventory Documentation”.

3.5.1.2 Other Industrial Point Sources For the non-EGU sources, the same inventory is us ed for both the actual and typical base year emissions inventories. The non-EGU category uses annual emissions as reported under the CERR for the year 2002. These emissions are temporally allocated to month, day, and hour using source category code (SCC)-b ased allocation factors.

The general approach for assembling future year data was to use recently updated growth and control data consistent with the USEPA’s CAIR analyses. Th is data was supplemented with state-specific growth factors and st akeholder input on growth assumptions.

3.5.2 Stationary Area Sources Stationary area sources are sources whose individua l emissions are relatively small, but due to the large number of these sources, the collectiv e emissions could be sign ificant (i.e., combustion of fuels for heating, structure fires, service stations, etc.). Emissions are estimated by multiplying an emission factor by some known indi cator of collective activity, such as fuel usage, number of households, or population. Sta tionary area source emissions are estimated at the countywide level.

A small portion of the 2002 area s ource base year inventory for ozone precursors in eleven Kentucky ozone nonattainment or maintenan ce areas was developed by the KYDAQ and provided to the VISTAS contract or. The VISTAS contractor cal culated the remaining portion ofThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 29 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 the area source inventory. The sources estima ted by the contractor include emissions from animal husbandry, wildland fires, and particulate matter from paved and unpaved roads. For the other states or local air program s within the modeling domain, either state-supplied data or data reported under CERR for 2002 was used.

The actual base year inventory wi ll serve as the typical base y ear inventory for all area source categories except for wildland fires. For wildland fires, a typical year inventory was used to avoid anomalies in wildfire activ ity in 2002 compared to longer-term averages. Development of a typical year fire inventory provided the capability of using a comparable data set for both the base year and future years. Thus, fire emissions remain the same for air quality modeling in both the base and any future years. The VISTAS Fire Special Interest Work Group used State records to ratio the number of acres bu rned over a longer period (three or more years, as available from state records) to 2002. Based on these ratios, the 2002 ac reage was then scaled up or down to develop a typical year inventory.

For categories other than wildland fires, the VISTAS/ASIP contractor generated the future base year emissions inventory used in the attain ment demonstration mode ling. Growth factors supplied from the states or the USEPA’s CAIR em ission projections were applied to project the controlled emissions to the appropriate year. In some cases, the USEPA’s Economic Growth and Analysis System Version 5 growth factors were used if no growth factor was available from either the states or the CAIR growth factor f iles. Appendix F.2 provides a detailed discussion of the area source inventory.

3.5.3 Off-Road Mobile Sources Off-road (or non-road) mobile sources are equi pment that are motorized but do not use the roadways, such as construction equipment, airc raft, railroad locomotiv es, lawn and garden equipment, etc. For the majority of the non -road mobile sources, the emissions for 2002 were estimated using the USEPA’s NONROAD2005c m odel. For the three source categories not included in the NONROAD model, i.e., aircraft engines, railroad locomotives, and commercial marine, more traditional methods of estimating th e emissions were used. The same inventory is used for both the actual and typical ba se year emissions inventories.

For the source categories estimated using the USEPA’s NONROAD model, the model growth assumptions were used to create the 2009 futu re year inventory. The NONROAD model takes into consideration regulations a ffecting emissions from these s ource categories. For the three largest airports in Kentucky, the Federal Aviatio n Administration’s Termin al Area Forecast was used to project growth in aircraft emissions. For the commercial marine, railroad locomotives, and the remaining airport emissions, the VISTAS/A SIP contractor calculated the future growth in emissions using detailed inve ntory data (both before and after controls) for 1996 and 2010, obtained from the CAIR Technical Support Document . When available, st ate-specific growth factors were used. Appendix F.2 provides a de tailed discussion of the nonroad mobile source inventoryThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 30 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 3.5.4 Highway Mobile Sources For onroad vehicles, the newest version of the MOBILE model, MOBILE6.2, was used. Key inputs for MOBILE include information on the age of vehicles on the ro ads, the average speeds on the roads, the mix of vehicl es on the roads, any programs in place in an area to reduce emissions for motor vehicles (such as emi ssions inspection programs), and temperature.

The MOBILE model takes into consideration regulati ons that affect emissions from this source sector. The same MOBILE run is used to repres ent the actual and typical year emissions for onroad vehicles using input data reflective of 2002. The MOBI LE model is then run for the 2009 inventory using input data re flective of that year. The 2002 vehicle miles traveled (VMT), speeds, vehicle age, and vehicle mix data we re obtained from the Kentucky Transportation Cabinet (KYTC). For several urban areas in Ke ntucky that run travel demand models (TDMs), VMT and speed data from TDMs was obtained by KYDAQ and Louisville APCD and provided to the VISTAS contractor.

For a detailed discussion about the mobile source inventory devel opment used in the attainment demonstration modeling, please refer to Appendix F.3.

3.5.5 Biogenic Emission Sources Biogenic emissions were prepared with th e SMOKE-BEIS3 (Biogeni c Emission Inventory System 3 version 0.9) preprocessor. SMOKE-BEIS3 is a modified version of the Urban Airshed Model (UAM)-BEIS3 model. Modifications incl ude use of MM5 data, gridded land use data, and improved emissions characterization. The em ission factors that are used in SMOKE-BEIS3 are the same as the emission factors as in UAM-B EIS3. The basis for the gridded land use data used by BEIS3 is the county la nd use data in the Biogenic Emissions Landcover Database version 3 (BELD3) provided by th e USEPA. A separate land classification scheme, based upon satellite (AVHRR, 1 km spatial resolution) and census information aided in defining the forest, agriculture, and urban por tions of each county.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 31 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 

### 4.0 MODEL PERFORMA NCE EVALUATION The initial modeling effort focused on evalua ting previous regional air quality modeling applications and testing candi date model configurations for the SMOKE emissions and CMAQ model for the VISTAS 36-km and 12-km modeling domains. This effort resulted in a report recommending the model configuration for the a nnual emissions and air quality modeling, which is included as part of the VIST AS Emissions and Air Quality M odeling Protocol. The evaluation of the meteorological modeling configuration ca n be found in Appendix F.1, with a summary of the final meteorological and air quality mode ling configuration in the modeling protocol contained in Appendix E and Appendix C, respectively.

Air quality model performance for the 2002 modeling year was initially test ed in 2004 using an early version of the VISTAS emi ssions inventory. In keeping w ith the one-atmosphere objective of the CMAQ modeling platform, model perfor mance was evaluated based on measured ozone, fine particles, and acid deposition in the Ai r Quality System (AQS), IMPROVE, Speciated Trends Network (STN), Southeastern Aeroso l Research and Characterization (SEARCH), National Acid Deposition Program (NADP) a nd Clean Air Status and Trends Network (CASTNet) monitoring netw orks (Figure 4.0-1).

Figure 4.0.1: Monitoring Networks used for VISTAS 2002 model performance evaluation, and their location within the VISTAS 12km domain.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 32 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Overall, the KYDAQ believes that the meteorological model perfor mance is adequate for this modeling exercise and should produce credible inputs for the air quality modeling for the attainment demonstration for the Louisville , KY-IN, Cincinnati- Mi ddletown, OH-KY-IN, and Huntington-Ashland, WV-KY-OH PM 2.5 nonattainment areas.

4.1 Modeling Performance Goals, and Criteria
In 2004, VISTAS/ASIP established model performan ce goals and criteria for components of fine particle mass (Table 4.2.1-1) based on previous m odel performance for ozone and fine particles. The Attainment Modeling Guidance for fine partic ulate matter at the time noted that PM models might not be able to achieve the same leve l of performance as ozone models. VISTAS’ evaluation considered several stat istical performance measures and displays. Fractional bias and mean fractional error were selected as the most appropriate metrics to summarize model performance; other metrics were also calculated and are included for FRM and STN monitors in the full model performance evaluation found in Appendix J.

Table 4.1-1. Established Model Pe rformance Goals and Criteria for the PM 2.5 Component Species
Fractional Bias Mean Fractional Error Comment

< 15 percent < 35 percent Goal for PM 2.5 model performance based on ozone model performance, considered excellent performance

< 30 percent < 50 percent Goal for PM 2.5 model performance, considered good performance

< 60 percent < 75 percent Criteria for PM 2.5 model performance, considered average performance. Exceeding this level of performance indicates fundamental concerns with the modeling system and trigge rs diagnostic evaluation.

An additional way to evaluate model performance statistics is to visua lize performance based on these fractional bias and mean fractional error go als via “soccer plots” and “bugle plots”. The soccer plot is so named because the dotted lines re semble a soccer goal. The soccer plot is useful as both bias and error are shown on a single plot. As bias and e rror approach zero, the points are plotted closer to or within the “goal” , represented here by the dashed boxes.

The bugle plot, named for the shape formed by the criteria and goal lines. The bugle plots are shaped as such because the goal and criteri a lines are adjusted based on the average concentration of the observed species. As the average concentration becomes smaller, the criteria and goal lines become la rger to adjust for the model’s poor ability to predict at low concentrations.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 33 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 The analysis of bugle plots dem onstrated that greater emphasis should be placed on performance of those components with the greatest contribution to PM 2.5 mass (e.g. SO 4 and OC) and that greater bias and error could be accepted for com ponents with smaller contributions to total PM 2.5 mass (e.g. EC, NO 3 , and soil). The soccer plots and bugle plots have been included as suggested model performance evaluation displays in the Attainment Modeling Guidance.

4.1.2 Domain-Wide Model Performance As a summary of model performance, soccer and bugle plots for the all of the VISTAS STN and FRM monitors are included here . Plots have been developed for the average monthly concentrations and the performance statistics for all of the PM 2.5 component species (SO 4 , NO 3 , NH 4 , OC, and EC) and reconstructed PM 2.5 total mass from the STN monitoring sites (Figures 4.2.2-1 and 4.2.2-2), as well as the total FRM PM 2.5 mass (Figures 4.1.2-3 and 4.1.2-4).

The soccer plots for monthly average component performance for all the VISTAS/ASIP STN sites shows generally good model pe rformance for most species of PM 2.5 and total PM 2.5 . The exception is the prediction of NO 3 values, which most values fall outside the criteria goal (Figure 4.1.2-1). There are a few months that fall on the crit eria level goal, which is better seen in the zoomed view presented in the image on the right in Figure 4.1.2-1. However, when the very low concentration of NO 3 is taken into consideration, as pr esented in the bugle plots (Figures 4.1.2- 2), NO 3 performance largely falls within the criteria and goal model performance lines. One can still note a general tendenc y for under prediction in NO 3 , and other species in right hand image in Figure 4.1.2-2, which leads to a slight unde r prediction in total reconstructed PM 2.5 . Monthly total PM 2.5 concentration performan ce at all the VISTAS/ASIP FRM monitors largely falls within goal level thresholds, with onl y two months falling just outside goal level performance (Figure 4.1.2-3). Figure 4.1.2-4 suggests a slight negative bias in PM 2.5 prediction for most of the year, with mean fractional error values remaining within goal levels across the year.

STN VISTAS Sites CMAQ 12km - 2002 Monthly

0.0 20.0 40.0 60.0 80.0 100.0 120.0 140.0 160.0 180.0 200.0

-180.0 -120.0 -60.0 0.0 60.0 120.0 180.0 Fractional BiasMean Fractional Error Sulfate
Nitrate
Ammon. Organics
EC PM2.5
Criteria
Goal STN VISTAS Sites CMAQ 12km - 2002 Monthly

0.0 10.0 20.0 30.0 40.0 50.0 60.0 70.0 80.0 90.0 100.0

-75.0 -25.0 25.0 75.0 Fractional BiasMean Fractional Error Sulfate
Nitrate
Ammon. Organics
EC PM2.5
Criteria
Goal

Figure 4.1.2-1. VISTAS STN Soccer Plots The image on the left is a soccer pl ot depicting both the mean fraction al error and fractional bias for component concentration for all VISTAS STN monitori ng sites. The image on the right is a zoomed view of the soccer plot on the left to better depict the area inside the criteri a/goal lines. Each point represents a monthly value as compared to the mo del performance criteria (red box) and modeling performance goals (green box).The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 34 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 STN VISTAS Sites CMAQ 12km - 2002 Monthly

-200.0 -150.0 -100.0 -50.0

0.0 50.0 100.0 150.0 200.0

0.0 4.0 8.0 12.0 16.0 20.0 Average Concentration ( μ g/m 3 )Mean Fractional Bias Sulfate Nitrate Ammon. Organics EC PM2.5 (+) Criteria (+) Goal (-) Goal (-) Criteria STN VISTAS Sites CMAQ 12km - 2002 Monthly

0.0 50.0 100.0 150.0 200.0

0.0 4.0 8.0 12.0 16.0 20.0 Average Concentration ( μ g/m 3 )Mean Fractional Error Sulfate
Nitrate
Ammon. Organics
EC PM2.5
Criteria
Goal

Figure 4.1.2-2. VISTAS STN Bugle Plots The image on the left is a bugle plot of the mean fraction bias for particulate matter and its component concentrations for all VISTAS STN monito ring sites. The image on the right is a bugle plot of mean fraction error for particulate matt er and its component species for all VISTAS STN monitoring sites. Each point represents a monthly mean fraction bias value as compared to the model performance criteria (red lines) and modeling performance goals (green lines).

FRM VISTAS Sites CMAQ 12km - 2002 Monthly

0.0 20.0 40.0 60.0 80.0 100.0 120.0 140.0 160.0 180.0 200.0

-180.0 -120.0 -60.0 0.0 60.0 120.0 180.0 Fractional BiasMean Fractional Error

PM2.5

Criteria

Goal FRM VISTAS Sites CMAQ 12km - 2002 Monthly

0.0 10.0 20.0 30.0 40.0 50.0 60.0 70.0 80.0 90.0 100.0

-75.0 -25.0 25.0 75.0 Fractional BiasMean Fractional Error

PM2.5

Criteria

Goal

Figure 4.1.2-3. VISTAS FRM Soccer Plots Soccer plots depicting both the mean fractional error and fractional bias for component concentration for all the VISTAS FRM Monitoring sites. The image on the right is a zoomed view of the soccer plot on the left to better depict the ar ea inside the criteria/goal lines. Each point represents a monthly value as compared to the mo del performance criteria (red box) and modeling performance goals (green box).The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 35 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 FRM VISTAS Sites CMAQ 12km - 2002 Monthly

-200.0 -150.0 -100.0 -50.0

0.0 50.0 100.0 150.0 200.0

0.0 4.0 8.0 12.0 16.0 20.0 Average Concentration ( μ g/m 3 )Mean Fractional Bias

PM2.5
(+) Criteria
(+) Goal
(-) Goal
(-) Criteria FRM VISTAS Sites CMAQ 12km - 2002 Monthly

0.0 50.0 100.0 150.0 200.0

0.0 4.0 8.0 12.0 16.0 20.0 Average Concentration ( μ g/m 3 )Mean Fractional Error

PM2.5

Criteria

Goal

Figure 4.1.2-4. VISTAS FRM Bugle Plots The image on the left is a bugle plot of the mean fraction bias for particulate matter and its component species concentrations for all the VISTAS FRM Monitoring sites. The image on the right is a bugle plot of mean fraction error for partic ulate matter and its component species for all the VISTAS FRM Monitoring sites. Each point rep resents a monthly mean fraction bias value as compared to the model performance criteria (red lines) and modeling performance goals (green lines).
Overall, the general tendency is for the m odel to have some difficulty in predicting NO 3 , as the monthly average values tend to fall outside the criteria goals for performance in the soccer plots. Part of this under prediction lies in the fact that NO 3 are generally found in low concentrations across the southeast, an d the model generally has difficulties representing any compound with low atmospheric concentrations. The bugl e plots are more encouraging with NO 3 performance, as these plots take into consideration the co ncentration of the component when evaluating performance. The bugle plots show all components and total PM 2.5 falling within criteria levels, if not goal levels, of model performa nce. The weaker performance of NO 3 accounts for the slight negative bias in both the total reconstructed PM 2.5 mass from STN sites as well as FRM total PM 2.5 data.

4.1.3 Nonattainment Area Model Performance

The statistical metrics were calculated for th e Louisville, KY-IN, Cincinnati- Middletown, OHKY-IN, and Huntington-Ashland, WV-KY-OH, STN monitors to demonstrate model performance for the components of PM 2.5 in and near the PM 2.5 nonattainment areas. Model performance statistics for the STN sites were calculated on a component and total PM 2.5 basis for the entire base year. Plots ha ve been developed for the average monthly concentrations of PM 2.5 and its component species at the STN sites, and for total PM 2.5 from FRM monitors for all Kentucky STN sites collectively, and for other monitoring sites within the PM 2.5 nonattainment areas, and are included in Appendix J.

4.1.4 Air Quality Model Performance Summary Overall, the model performance for the entire nonattainment area, as well as the Kentucky portion, through the 2002 baseline modeling year is reasonably good. For the most part, mean normalized bias and mean normalized gross error are within the recommended limits for good model performance for most of com ponent species as well as total PM 2.5 mass. Overall performance was good for sulfate and organic carbon, which are th e largest constituents of PM 2.5 for Kentucky. Nitrate performance across the nonatta inment areas was less than ideal, especiallyThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 36 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 during the summer months. This is likely due to the generally low atmospheric concentrations seen in the nonattainment areas, including Kentuc ky. When the performance is weighted by the concentration, as in the bugle plot s, the performance metrics indica te better model performance. The model also does a good job capturing PM 2.5 component and total c oncentrations through various episode-clean out cycles (see Appendix J). Overall, th e KYDAQ believes that the model performance is well within the limits of acceptabl e performance established in the Attainment Modeling Guidance.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 37 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 

### 5.0 CONTROLS APPLIED
Several control measures already in place or be ing implemented over the next few years will reduce stationary point, highway mobile, and nonr oad mobile source emissions. The federal and state control measures that have impacts on air quality in Kentucky were modeled for all of the future years and are discussed in the sections below. Although al l the controls listed below may not directly reduce PM 2.5 concentrations in Kentucky, the modeling assessment in this submittal was based on one atmosphere modeling comple ted for ozone and fine particulate matter attainment demonstrations and regional haze plans.

5.1 Federal Control Measures

5.1.1 Tier 2 Vehicle Standards Federal Tier 2 vehicle standards will require al l passenger vehicles in a manufacturer’s fleet, including light-duty trucks and sport utility vehicles (SUVs), to meet an average standard of 0.07 grams of NOx per mile. Implementation began in 2004, and should be completely phased in by 2007. The Tier 2 standards will also cover pa ssenger vehicles over 8,500 pounds gross vehicle weight rating (the larger pickup trucks and SU Vs), which are not covered by the current Tier 1 regulations. For these vehicles , the standards will be phased in beginning in 2008, with full compliance in 2009. The new standards require vehicl es to be 77% to 95% cleaner than those on the road today. The Tier 2 rule also reduced th e sulfur content of gasoline to 30 parts per million (ppm) starting in January of 2006. Most gasolin e sold in Kentucky prio r to January 2006 had a sulfur content of about 300 ppm. Sulfur occurs naturally in gaso line, but interferes with the operation of catalytic converters on vehicles, re sulting in higher NOx emissions. Lower-sulfur gasoline is necessary to achieve the Tier 2 vehicle emission standards.

5.1.2 Heavy-Duty Gasoline and Diesel Highway Vehicles Standards New USEPA standards designed to reduce NOx and VOC emissions from heavy-duty gasoline and diesel highway vehicles be gan to take effect in 2004. A second phase of standards and testing procedures, which began in 2007, will reduce particulate matter from heavy-duty highway engines, and will also reduce highway dies el fuel sulfur content to 15 ppm because the sulfur damages emission control devices. The total program is expected to achieve a 90% reduction in particulate matter (PM) emissions and a 95% reduction in NOx emissions for these new engines using low sulfur di esel, compared to existing engi nes using higher-content sulfur diesel.

5.1.3 Large Nonroad Diesel Engines Rule In May 2004, the USEPA promulgated new rules for large nonroad diesel e ngines, such as those used in construction, ag ricultural, and industrial equipment, to be phased in between 2008 and 2014. The nonroad diesel rules also reduce the allo wable sulfur in nonroad diesel fuel by over 99%. Nonroad diesel fuel curre ntly averages about 3,400 ppm sulf ur. The rule limits nonroad diesel sulfur content to 500 ppm in 2006 and 15 ppm in 2010. The combined engine and fuel rules would reduce NOx and PM emissions from large nonroad diesel engines by over 90%, compared to current nonroad engine s using higher-content sulfur diesel.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 38 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 5.1.4 Nonroad Spark-Ignition Engines a nd Recreational Engines Standard The new standard, effective in July 2003, regulates NOx, hydrocarbons (HC), and carbon monoxide (CO) for groups of previously unregulat ed nonroad engines. Th e new standard will apply to all new engines sold in the United Stat es and imported after these standards began and apply to large spark-ignition engines (forkl ifts and airport groun d service equipment), recreational vehicles (off-highway motorcycles and all-terrain-vehi cles), and recreational marine diesel engines. The regulation varies ba sed upon the type of engine or vehicle.

The large spark-ignition engines co ntribute to ozone formation and ambient CO and PM levels in urban areas. Tier 1 of this standard was im plemented in 2004 and Tier 2 started in 2007. Like the large spark-ignition engines, recreational vehi cles contribute to ozone formation and ambient CO and PM levels. For the off-highway motorc ycles and all-terrain-vehicles, model year 2006, the new exhaust emissions standard was phased-in by 50% and for model ye ars 2007 and later at 100%. Recreational marine diesel engines over 37 kilowatts are us ed in yachts, cruisers, and other types of pleasure craft. Recreational marine engines contri bute to ozone formation and PM levels, especially in marinas. Depending on the size of the engine, the st andard began phasing-in in 2006.

When all of the nonroad spark-ignition engines and recreational engines standards are fully implemented, an overall 72% reduction in HC, 80% reduction in NOx, and 56% reduction in CO emissions are expected by 2020. These controls will help reduce ambient concentrations of ozone, CO, and fine PM.

5.1.5 NOx SIP Call in Surrounding States In October 1998, the USEPA made a finding of si gnificant contribution of NOx emissions from certain states and published a ru le that set ozone season NOx budge ts for the purpose of reducing regional transport of ozone (63 FR 57356). This rule, referred to as the NOx SIP Call, called for ozone season controls to be put on utility and i ndustrial boilers, as well as internal combustion engines in 22 states in the Eastern United States . A NOx emissions budget was set for each state. A NOx trading program was established, allowi ng sources to buy credits to meet their NOx budget as opposed to actually installing controls. The emission budgets were to be met by the beginning of 2004. Even with th e trading program, the amount of ozone season NOx emissions has decreased significantly in and around Kentucky.

Implementation of the NOx SIP Call was project ed by Integrated Planning Model (IPM). The MACTEC emissions inventory report describes the IPM methods, and in Table 2.1-5 of that report, the EGU NO x emissions by state in 2009. Link to MACTEC Emission Inventory Report:

http://www.vistas-sesar m.org/documents/VISTABF2003-20-2008.pdfThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 39 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 5.1.6 Clean Air Interstate Rule On May 12, 2005, the USEPA promulgated the “Rule To Reduce Interstate Transport of Fine Particulate Matter and Ozone (C lean Air Interstate Rule); Revisions to Acid Rain Program; Revisions to the NO X SIP Call”, referred to as CAIR. This rule established the requirement for States to adopt rules limiting the emissions of NOx and sulfur dioxide (SO 2 ) and a model rule for the states to use in developing their rules. The purpose of the CAIR is to reduce interstate transport of precursors to fine particulate and ozone.

CAIR applies to (1) any stati onary, fossil-fuel-fired boiler or stationary, fossil-fuel-fired combustion turbine serving at any time, since the start-up of a unit’s combustion chamber, a generator with nameplate capacity of more than 25 Megawatt hours (MWh) producing electricity for sale and (2) for a unit that qualifies as a cogeneration unit during the 12-month period starting on the date that the unit first produces electricity and continues to qualify as a cogeneration unit, a cogeneration unit serving at a ny time a generator with namepl ate capacity of more than 25 MWh and supplying in any calendar year more th an one-third of the unit’s potential electric output capacity or 219,000 MWh, whichever is greate r, to any utility power distribution system for sale.

This rule provides annual state caps for NOx and SO 2 in two phases, with the Phase I caps for NOx and SO 2 starting in 2009 and 2010, respectively. Ph ase II caps become ef fective in 2015. The USEPA is allowing the caps to be met through a cap and trade program if a state so chooses to participate in the program. When fully implemented, the CAIR will reduce SO 2 emissions in the eastern United States by over 70 percent an d NOx emissions by over 60 percent from 2003 levels.

The following is a discussion of CAIR Controls a nd implications of the vacatur of CAIR based on available emissions sensitivity data.

On July 11, 2008, the DC Circuit Court vacated the Clean Air Interstate Rule that required large scale reductions of SO 2 and NO x emissions from Electric Gene rating Units (EGU). The Court cited several reasons for vacating CAIR including the inability of the emission trading programs to assure that the states’ obligations under Section 110a2D of the Clean Air Act not to significantly contribute to nonattainment conditions in downwind states would be met. In September 2008 EPA petitioned the Court to re hear the case and in October 2008 the Court asked the original litigants to respond by November 6, 2008 whethe r the Court should vacate the rule in its entirety or remand portions of the rule to allow the initial control requirements to stand while EPA addressed the Court’s concerns. A d ecision by the Court is expected in December, 2008.

Kentucky’s 2009 modeling demons tration for the annual PM 2.5 State Implementation Plan relied on emissions reductions required by CAIR in Ke ntucky and the eastern United States. If the Court were to uphold the CAIR vacatur, then not all the controls th at were modeled in Kentucky’s SIP demonstration woul d be legally enforceable. In August 2008 the VISTAS states reviewed the emissions controls assumed unde r the 2009 Best and Final EGU inventory to determine which were controls were still legally enforceable if CAIR were to be vacated. Legally enforceable controls were defined as being subject to:The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 40 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 1. State rule 2. Consent decree 3. Permit condition

VISTAS states provided legally enforceable controls and emissions for 2009, 2012, and 2018 for EGU in VISTAS states by early September 20 08. We also asked the MRPO and MANE-VU states to provide the same information for their states. We anticipate receiving this information for the MRPO and MANE-VU states in mid Nove mber. At that point we will rerun the 2009 SMOKE emissions and CMAQ air quality models using legally enforceable EGU emission controls to determine how the 2009 PM 2.5 design values for PM 2.5 nonattainment areas in the VISTAS states might change as a result of the CAIR vacatur. We do not expect to have those modeling results un til January 2009.

In the meantime, we can use emission sensitiv ity analyses performed using CMAQ, the 2009 Base D inventory, and two month-long episodes in summer (Jun 1-Jul 10) and late fall (Nov 19- Dec 19) 2002 to evaluate how emissions chan ges under the CAIR vacatur might affect PM 2.5 concentrations in nonattainment areas. These emissions sensitivities were performed in 2006 by Georgia Institute of Technology and addressed ch anges in 2009 emissions for specific source categories and pollutant categories. The episode periods were selected using Classification and Regression Tree analyses to represent th e annual 2002 base year conditions for PM 2.5 in nonattainment areas in the southeastern US. Emissions in 2009 for several combinations of pollutants and source sectors were reduced by 30 percent in separa te sensitivity runs for each state in the VISTAS region and for the other RP Os in the VISTAS 12 km modeling grid. The pollutant contributions th at were evaluated were:

• SO 2 from Electric Generating Units (EGU) sources in each VISTAS state, other RPOs in the VISTAS 12 km grid, and Boundary Conditions from outside the 12 km domain.

• SO 2 from non-EGU point sources in each VI STAS state, other RPOs, and Boundary Conditions

• NO x from ground level (on-road plus non-road plus area) sources in each VISTAS state and other RPOs

• NO x from point (EGU plus non-EGU) sources in each VISTAS state and other RPOs

• NH 3 from all sources in VISTAS and other RPOs

• Volatile Organic Compounds from anthropogenic and biogenic sources in the 12 km modeling domain

• Primary Carbon from all ground level source s in each VISTAS state and other RPOs

• Primary Carbon from all point sources in each VISTAS state and other RPOs

• Primary Carbon from all fires in ea ch VISTAS state and other RPOs

Sensitivity results SO 2 from EGU and NO x from point sources for the summer and winter episodes and for annual average PM 2.5 (calculated as average of th e summer and winter episode responses) provide a basis to interpret potential impacts of the CAIR vacatur for the three PM 2.5 nonattainment areas in Kentucky. Th e discussion below focuses on SO 2 because the emissionsThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 41 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 sensitivity analyses show th e greatest reductions in PM 2.5 in nonattainment areas comes from reducing EGU SO 2 emissions in Kentucky and eastern states.

All three PM2.5 non-attainment areas in Kentucky are multi-state areas with counties and partial counties in more than on e state as listed below:

Louisville, KY-IN: KY - Bullitt and Jefferson Counties; IN - Clark, Floyd, and Jefferson Counties

Cincinnati-Hamilton, KY-IN-OH: OH- Butler, Clermont, Hamilton, and Warren Counties; IN - Dearborn County; KY - Boone, Campbell, and Kenton Counties

Huntington-Ashland, KY-OH-WV: WV - Cabell and Wayne Counties, and parts of Mason County; Ky - Boyd County and parts of Lawrence County; OH - Lawrence and Scioto Counties, and parts of Adams and Gallia County.

The ASIP 2009 Best and Final mo deling results delivered in spri ng 2008 demonstrated that all monitors in the Huntington-As hland, KY-OH-WV would attain with only the Scioto County monitor in Ohio projected to be above 14.5 μ g/m 3 . In the Louisville, KY-IN nonattainment area, none of the monitors are projected to be above 14.5 μ g/m 3 . All the Kentucky monitors in the Cincinnati, KY-IN-OH nonattainment ar ea are projected to be below 13 μ g/m 3 while the Hamilton County, OH monitors are closer to the st andard. We expect that all monitors except Hamilton County, OH would continue to demonstr ate attainment even if the CAIR vacatur resulted in increases in projected PM2.5 of 0.1-3 μ g/m 3 in 2009.

Table 1 details the emissions a ssumptions used to estimate the potential change in the 2009 PM 2.5 design value in the Kentucky nonattainment areas if CAIR were to be vacated. The ASIP Best and Final 2009 EGU SO 2 inventories for Kentucky were 271,662 tons/yr under CAIR and 310,840 tons/yr under the No CAIR (legally enfor ceable) scenario. This is a 39,178 tons/yr difference in SO 2 emissions from KY or a 14.4% incr ease over the 2009 Best and Final EGU SO 2 emissions. The ASIP Base D 2009 EGU SO 2 inventory for Kentucky was 342,678 tons/yr SO 2 (higher emissions because Base D inventory was developed in 2005 prior to major utility consent decrees). The 30% 2009 Base D EGU SO 2 emissions reduction modeled in the sensitivity was equal to 102,803 tons/yr. The di fference between CAIR and No CAIR scenarios in the 2009 Best and Final EGU SO 2 inventory is 38.1% of the re duction tested in the 2009 Base D EGU SO 2 emissions sensitivity run. Therefore th e response to the CAIR vacatur might be assumed to be 38.1% of the response to a 30% reduction in KY 2009 Base D EGU SO 2 emissions.

The CAIR vacatur would affect not only KY, bu t all eastern states. The 2009 Best and Final EGU SO 2 emissions for the VISTAS states were 243,460 tons/yr greater for the No CAIR scenario (2,691,917 tons/yr) than th e CAIR Best and Final EGU SO 2 inventory (2,448,457 tons/yr). This is a 9.9% increase in EGU SO 2 emissions across the VIST AS states in the 2009 No CAIR scenario. In contrast, a 30% reduction in the 2009 Base D EGU SO 2 inventory was 690,169 tons/yr. So the change in the 2009 EGU SO 2 emissions for the ten VISTAS states dueThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 42 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 to the CAIR vacatur would be 35.3% of the SO 2 emissions reductions te sted for the 2009 Base D inventory.

Table 1.

2009 No CAIR Legally Enforceable 2009 Best and Final 2009 Difference No CAIR - CAIR 2009 Base D 2009 30% Reduction Base D Ratio No CAIR to Base D emissions chan g e AL 405,164 377,993 27,171 314,899 FL 339,645 287,633 52,013 206,851 GA 406,312 406,312 0 396,187 KY 310,840 271,662 39,178 342,678 102,803 0.381 MS 76,633 76,633 0 76,864 NC 227,433 227,433 0 139,499 SC 177,278 125,364 51,914 146,502 TN 255,141 255,141 0 280,189 VA 224,520 151,336 73,185 150,039 WV 268,950 268,950 0 246,853 VISTAS 2,691,917 2,448,457 243,461 2,300,563 690,169 0.353 EGU SO2 Emissions

Table 2 defines the projected change in 2009 PM 2.5 concentration calculated for the No CAIR scenario based on the 2009 emi ssions sensitivity runs.

Table 2. PM2.5 Response to EGU SO2 Emissions Changes 2009 Response to Base D emissions (μ/m3) 2009 Response to No CAIR emissions (μ/m3) Louisville, KY-IN KY 0.143 0.054 VISTAS states 0.318 0.112 Cincinnati, OH-KY-IN KY 0.144 0.055 VISTAS states 0.291 0.103 Huntington-Ashland, WV-KY-OH KY 0.083 0.032 VISTAS states 0.315 0.111The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 43 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 For the Louisville, KY-IN nonattainment area (monitor 21-111-0043), the response to a 30% reduction in KY 2009 Base D EGU SO 2 emissions was 0.143 μ g/m 3 PM 2.5 . The response for Louisville, KY-IN to the CAIR vacatur for KY EGU might be assumed to be 0.381 times 0.143 μ g/m 3 or 0.054 μ g/m 3 PM 2.5 . The response for Louisville, KY-IN to a 30% reduction in 2009 Base D EGU SO 2 emissions for all the VISTAS states was 0.318 μ g/m 3 . Thus the response to the CAIR vacatur for EGU in all the VISTAS states might be assumed to be 0.353 times 0.318 μ g/m 3 or 0.112 μ g/m 3 PM 2.5 in Louisville, KY-IN. We do not know what emissions changes would result if CAIR were v acated from legally enforceable EGU controls for the CENRAP, MANE-VU, and MRPO states.

For the Cincinnati, KY-IN-OH nonattainment area, using the difference in VISTAS SO 2 emissions between the 2009 Best and Final CAIR EGU inventory and the NO CAIR scenario, the emission reduction tested in the 2009 Base D EGU SO 2 sensitivity run as described above, and the PM 2.5 responses to the 2009 EGU SO 2 sensitivity run (0.291 μ g/m 3 ), we would project a 0.103 μ g/m 3 increase in PM 2.5 in 2009 in the Cincinnati, KY-IN-OH) nonattainment area (monitor 21-117-0007) due to the CAIR vacatur for E GU sources in the VISTAS states. Of that amount, we calculate that 0.0548 μ g/m 3 would be attributable to CAIR vacatur for EGU sources in KY. Using similar logic, we would project a 0.111 μ g/m 3 increase in PM 2.5 in 2009 in the Huntington-Ashland, KY-OH-WV nonattainment ar ea (monitor 21-019-0017) due to the CAIR vacatur for EGU sources in the VISTAS states . Of that amount, we calculate that 0.0315 μ g/m 3 might be attributable to the CAIR vacatur for EGU sources in Kentucky. West Virginia EGU are projected to retain the same SO 2 controls under the NO CAIR scenario as the 2009 Best and Final CAIR scenario.

While we do not know the emissions changes due to legally enforceable EGU controls in the CENRAP, MANE-VU, and MRPO states, if we assume that the increases in EGU SO 2 in these regions were equivalent to the increases projec ted for the VISTAS states (10%), then we can estimate their combined impacts on the KY n onattainment areas. For Louisville, KY, the combined effect of a 30% change in EGU SO2 emissions from CENRAP, MANE-VU, and MRPO states resulted in a 0.273 μ g/m 3 response in PM 2.5 . If we assume that the CAIR vacatur would increase SO2 emissions from these regi ons by 10 to 30%, then if CAIR were vacated, there might be an increase of 0.09 to 0.27 μ g/m 3 PM 2.5 at the Louisville, KY monitor due to EGU in the CENRAP, MANE-VU, and MRPO states . For Huntington-Ashland, KY-OH-WV a 10 to 30% increase in EGU SO 2 emissions from CENRAP, MRPO, and MANE-VU states due to the CAIR vacatur might increase PM 2.5 by 0.06 to 0.17 μ g/m 3 . For Cincinnati, KY, a 10 to 30% increase in EGU SO 2 emissions from CENRAP, MRPO, and MANE-VU states due to the CAIR vacatur might increase PM 2.5 by 0.11 to 0.33 μ g/m 3 . SO 2 emissions from outside the 12 km domain are a significant, but smaller contribution to PM 2.5 in the KY nonattainment areas than contributions from within the 12 km domain. Th ere is insufficient information to estimate how these boundary conditions would cha nge if CAIR were vacated.

If CAIR were vacated, summe r-time nitrogen oxides (NO x ) emissions controls would still be required under the NO x SIP call and the only emissions reduc tions that would not be legally enforceable would be year-round op eration of already installed NO x control equipment. TheThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 44 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 2009 NO x sensitivity runs projects very little benefit to total PM 2.5 of reducing NO x emissions from either ground-level (primarily mobile) sources or point sources in Kentucky or the VISTAS states in either winter or summer. Ammonium nitrate is a very small component of total PM 2.5 in the summer and roughly 5-10% of total PM 2.5 in winter in the KY nonattainment areas. The 2009 emissions sensitiv ity results suggest th at reducing ammonia emissions would be a more effective strategy to reduce wintertime ammonium nitrate than reducing nitrogen oxide emissions.

These analyses combined suggest that Hun tington-Ashland, KY-OH-WV and Louisville, KY-IN should continue to attain the annual PM2.5 standard even if CAIR is vacated. It is not clear if the Hamilton County, KY monitors would attain if CAIR were vacated. As stated above, VISTAS is preparing for a CMAQ run using legally enforceable EGU controls to resolve this question.

5.1.7 Industrial Boiler/Process Heater/RICE MACTs EPA’s industrial boiler/process heater MACT (40 CFR 63 Subpart DDDDD) was vacated in June 2007, yet the final ASIP 2009 inventory and m odeling demonstration for attainment of the PM 2.5 annual standard included emissions reductions attributable to the vacated rule. For Kentucky a total of 259 tons/yr of SO 2 and 156 tons/yr of primary PM 2.5 were attributed to the vacated boiler MACT in the 2009 inventory. Total 2009 emissions for Kentucky are 428,733 tons/yr for SO 2 and 83,480 tons/yr primary PM 2.5 . Emission reductions attributed to the vacated boiler MACT compromise 0.06% of total state wide SO 2 emissions and 0.19% of total state wide primary PM 2.5 . The emissions reductions attributable to the boiler MACT are insignificant fraction of total SO 2 and primary PM 2.5 emissions contributing to KY nonattainment areas, and including these reductions in th e 2009 modeling demonstration doe s not change the attainment conclusions.

Table 1 outlines the 2009 SO 2 emissions in each county in th e two PM2.5 nonattainment areas in Kentucky affected by boiler MACT assump tions; Table 2 outlines 2009 primary PM 2.5 emissions in these two areas. The boiler MACT assumptions affect 2009 emissions in three Kentucky counties and one West Virginia co unty; no sources in Ohio or I ndiana were affected. For the Huntington-Ashland, KY-OH-WV area, 40 tons/yr of SO 2 from sources in Boyd County, KY and Wayne County, WV, or 0.025% of all SO 2 emissions from point sources in the nonattainment area were attributed to the boiler MACT. For primary PM 2.5 , 23 tons/yr or 0.01% of total primary PM 2.5 emissions from point sources in nona ttainment area were attributed to the boiler MACT. For the Louisville, KY -IN nonattainment area, 51 tons/yr SO 2 from sources in Bullitt and Jefferson, KY counties, or 0.11% of KY point source SO 2 emissions and 0.06% of all point source SO 2 emissions in the Louisville nonattainme nt area were attributed to the boiler MACT. For primary PM 2.5 , 23 tons/yr or 2.4% of KY primary PM 2.5 point source emissions and 0.7% of total primary PM 2.5 point source emissions in the nonattainment area were attributed to the boiler MACT. No sources in the Cincinnati, KY-IN-OH nonattainment area were affected in 2009 by the boiler MACT.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 45 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 ASIP emissions sensitivity analyses demonstrated the responses of PM 2.5 in nonattainment areas to reductions in SO 2 and primary PM 2.5 emissions in 2009. These anal yses indicate that a 30% reduction in 2009 SO 2 non-EGU point source emissions in Kentucky (from 36, 418 SO 2 tons /yr to 25,493 tons/yr) would reduce PM 2.5 in Louisville, KY (monitor 21-111-0043) by 0.0212 μ g/m 3 . The SO 2 emissions reduction attributed to th e boiler MACT amounted to 2.4% of the SO 2 reduction modeled for the KY non-EGU point source emissions sensitivity. These SO 2 emission reductions might underestimate the PM 2.5 concentration in Lousiville, KY by 0.0005 μ g/m 3 . Further the PM 2.5 non-EGU point emissions were re duced by 4.44% compared to the Kentucky non-EGU PM 2.5 reduction tested in the emissions sensitivity, possibly underestimating the PM 2.5 concentration in the Louisville, KY PM 2.5 nonattainment area by an additional 0.002 μ g/m 3 . The combined SO 2 and primary PM 2.5 contribution to PM 2.5 in the Louisville, KY nonattainment area that is attributab le to the vacated boiler MACT is 0.0025 μ g/m 3 . This concentration difference is less than model accur acy and does not change the conclusion that Louisville will attain the annual PM 2.5 standard in 2009.

Similarly, for the Huntington-Ashland, KY-OH-WV PM 2.5 nonattainment area (monitor 21-019- 0017), the emissions sensitivity results indicat e that the SO 2 and primary PM 2.5 emissions assumed under the vacated boiler MACT would result in an additional 0.006 μ g/m 3 PM 2.5 from SO 2 emissions and an additional 0.0003 μ g/m 3 from primary PM 2.5 emissions, for a total increase of PM 2.5 in the Huntington-Ashlan d nonattainment area of 0.0009 μ g/m 3 attributable to the vacated boiler MACT. These values are below the accuracy of the model and do not change the conclusion that the Huntington-Ashl and area will attain the annual PM 2.5 standard in 2009.

Table 1. 2009 SO 2 emissions in Louisville, KY-IN and Huntington-Ashland, KY-OH-WV PM 2.5 nonattainment areas from the draft PM 2.5 SIP and corrected SO 2 emissions accounting for emissions that would not be controlled 2009 due to the vacatur of the boiler MACT.

Louisville, KY-IN SOx
Corrected Point Corrected Total Point Area Mobile Nonroad Total

KENTUCKY

Bullitt 401 97 14 8 520 410 529

Jefferson 43,688 14,585 112 921 59,306 43,730 59,348

KY Total 44,089 14,682 126 929 59,826 44,140 59,877

INDIANA

Clark 3,459 687 17 49 4,212

Floyd 28,295 659 11 14 28,979The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 46 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Jefferson 14,563 334 5 9 14,911

IN Total 46,317 1,680 33 72 48,102

Total Emissions 90,406 16,362 159 1,001 107,928 90,364 107,970

Huntington-Ashland, KY-OH-WV SOx
Corrected Point Corrected Total Point Area Mobile Nonroad Total

KENTUCKY

Boyd 10,432 578 6 380 11,396 10,460 11,424

Lawrence 47,739 102 4 52 47,897

KY Total 58,171 680 10 432 59,293 58,199 59,321

WEST VIRGINIA

Cabell 123 1,528 13 19 1,682

Mason 56,691 122 4 14 56,830

Wayne 277 517 5 34 832 289 844

WV Total 57,091 2,167 21 66 59,345 57,103 59,357

OHIO

Adams 22,422 55 4 8 22,489

Gallia 21,807 50 4 8 21,869

Lawrence 0 94 11 15 120

Scioto 918 108 9 25 1,060

OH Total 45,147 307 28 56 45,538

Total Emissions 160,409 3,154 59 554 164,176 160,449 164,216The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 47 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Table 2. 2009 primary PM 2.5 emissions in Louisville, KY-IN and Huntington-Ashland, KY-OHWV PM 2.5 nonattainment areas from the draft PM 2.5 SIP and corrected SO2 emissions accounting for emissions that would not be controlled 2009 due to the vacatur of the boiler MACT.

Louisville, KY-IN PM2.5
Corrected Point Corrected Total Point Area Mobile Nonroad Total

KENTUCKY

Bullitt 57 826 35 39 957

Jefferson 899 4,365 241 649 6,154 922 6,177

KY Total 956 5,191 276 688 7,111 979 7,134

INDIANA

Clark 641 939 41 96 1,717

Floyd 419 731 28 42 1,220

Jefferson 1,293 516 12 27 1,848

IN Total 2,353 2,186 81 165 4,785

Total Emissions 3,309 7,377 357 853 11,896 3,331 11,919

Huntington-Ashland, KY-OH-WV

KENTUCKY

Boyd 1,255 748 15 121 2,139 1,278 2,162

Lawrence 413 219 10 28 670

KY Total 1,668 967 25 149 2,809 1,691 2,832

WEST VIRGINIA

Cabell 339 857 31 74 1,301The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 48 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Mason 287 380 9 60 735

Wayne 54 485 11 114 664

WV Total 680 1,722 50 248 2,701

OHIO

Adams 3,696 323 12 20 4,051

Gallia 3,905 230 11 19 4,165

Lawrence 2 165 26 29 222

Scioto 92 339 24 60 515

OH Total 7,695 1,057 73 128 8,953

Total Emissions 10,043 3,746 148 525 14,463 10,066 14,486

5.1.8 Combustion Turbine MACTs The projection inventorie s do not include the NOx co-benefit effects of the MACT regulations for Gas Turbines or stationary Reciprocating Internal Combustion Engines, which the USEPA estimates to be small compared to the overall inventory.

5.1.9 VOC 2-, 4-, 7-, and 10- year MACT Standards Various point source MACTs and associated emission reductions were implemented. Reductions occurring before 2002 were assumed to be accounted for in the 2002 base year inventory.

5.1.10 Consent Agreements East Kentucky Power Cooperative (EKPC), a coal-f ired electric utility, has agreed to spend approximately $650 million on pollution contro ls and pay a $750,000 penalty to resolve violations of the Clean Air Act at its three plants in Kentucky known as Spurlock, Dale, and Cooper. The agreement will reduce harmful ai r pollutants by more than 60,000 tons per year according to EPA. The company will install stat e-of-the-art pollution control equipment to reduce emissions of pollutants that cause acid rain and smog. The controls will reduce annual emissions of smog-forming nitrogen oxides by a pproximately 8,000 tons and sulfur dioxide by more than 54,000 tons per year from EKPC’s S purlock, Dale, and Cooper plants when the controls are fully implemented. This consent decree will facilitate that SO2 scrubbers are installed for EKPC’s Spurlock Units 1 and 2 and Cooper Units 1 and 2 for BART. The SO2The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 49 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 scrubbers for EKPC Spurlock Units 1 and 2 have been included in this SIP’s PM 2.5 modeling results for 2009.

This consent decree will facilitate that a SO 2 scrubber will be installed for AEP Big Sandy’s Unit 2 by December 31, 2015, per the consent d ecree. Although not reflected in the 2009 modeling, the AEP Big Sandy Unit 2 scrubber will sign ificantly reduce emi ssions of visibility impairing pollutants and assist in the maintenance of the PM 2.5 NAAQS.

American Electric Power (AEP) has agreed to cut 813,000 tons of air pollutants annually (654,000 tons of SO2 and 159,000 tons of NOx) at an estimated cost of mo re than $4.6 billion, pay a $15 million penalty, and spend $60 million on proj ects to mitigate the a dverse effects of its past excess emissions. The agreement imposes caps on emissions of pollutants from 16 plants located in five states. Th e facilities are located in Moundsville (2 faciliti es), St. Albans, Glasgow, and New Haven (2 facilities), West Virginia; Lo uisa, Kentucky; Glen Lyn and Carbo, Virginia.; Brilliant, Conesville, Cheshire , Lockburne, and Beverly, Ohio; and Rockport and Lawrenceburg, Indiana. AEP will install pollution control eq uipment to reduce and cap sulfur dioxide and nitrogen oxide emissions by more than 813,000 tons per year when fully implemented. By installing these pollution control measures, the plants will emit 79 percent less sulfur dioxide and 69 percent less nitrogen oxides, as compared to 2006 emissions.

5.2 State Control Measures

5.2.1 NOx SIP Call Rule In response to the USEPA’s NOx SIP call, Kent ucky adopted rules to c ontrol the emissions of NOx from large stationary combustion sources. Th ese rules cover (1) fossil fuel-fired stationary boilers, combustion turbines, and combined cycle systems serving a generator with a nameplate capacity greater than 25 megawatts and selling any amount of electricity, (2) fossil fuel-fired stationary boilers, combustion tu rbines, and combined cycle systems having a maximum design heat input greater than 250 million British th ermal units per hour, and (3) reciprocating stationary internal combustion engines rated at equal or greater than 2400 brake horsepower (3000 brake horsepower for diesel engines and 4400 brake horsepower for dual fuel engines). As part of the NOx SIP call, the USEPA rules established a NOx budget for sources in Kentucky and other states.

Besides amending existing NOx rules and adopti ng new NOx rules specifi cally to address the USEPA NOx SIP call, the Kentucky rules also requi re new sources to control emissions of NOx. The objective of this requiremen t is (1) to aid in meeting the NOx budget for Kentucky for minor sources and (2) to aid in attaining and maintainin g the ambient air quality standard for ozone in Kentucky.

Kentucky’s NOx SIP Call rule was predicted to reduce summertime NOx emissions from power plants and other indus tries by 68% by 2006.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 50 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 KRS 224.10-100, Powers and duties of the cab inet, provides the Kentucky Energy and Environment Cabinet with the statutory authority to adopt and implement its NO x SIP Call program. A link to KRS 224.10-100 is as follo ws: http://www.lrc.ky.gov/KRS/224-10/100.PDF.

5.2.2 Open Burning Bans In 2005 Kentucky revised the open burning regulatio n to prohibit most types of open burning in moderate ozone nonattainment ar eas within Kentucky during the period of May-September when ozone is most likely to form. LMAPCD also revised their open burning regulation in 2008.

A copy of KYDAQ’s regulat ion is located at http://www.lrc.ky.gov/kar/401/063/005.htm

A copy of Louisville’s open bur ning regulation is located at http://www.louisvilleky.gov/NR/rdonlyres/94818773-D227-4F1B-A30D-1B3D2A0D8488/0/111FV10.pdf

5.2.3 Clean Air Interstate Rule In response to the USEPA’s CAIR, the KYDAQ deve loped rules to implement CAIR. Under the rule, Kentucky has caps as follows:

• Annual NOx: 83,205 tons for 2009-2014 and 69,337 tons for 2015 and each year thereafter;

• Ozone season NOx: 36,109 tons for 2009-2014 and 30,651 tons for 2015 and each year thereafter;

• Annual SO 2 : 188,773 tons for 2010-2014 and 132,141 tons for 2015 and each year thereafter.

The State’s NOx allocations have been dist ributed based on allocation methodologies in 401 KAR 52:210 and 220. The USEPA will determine the SO 2 allocations, which are based on the acid rain program. For the most part the rule s follow the USEPA’s model rule. This rule does not preclude the DAQ from adopting additiona l emission reduction requirements for covered sources if necessary to attain or mainta in an ambient air quality standard.

The KYDAQ CAIR regulations became effectiv e February 2, 2007, and was approved to Kentucky’s SIP published October 4, 2007, (72 FR 56623) and effective December 3, 2007.

5.2.4 Fugitive Emissions Both KYDAQ and LMAPCD have a fugitive emissions regulation.

For Kentucky, 401 KAR 63:010. Fugitive emissions, provides for the control of fugitive emissions in Kentucky can be found at http://www.lrc.ky.gov/kar/401/063/010.htmThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 51 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 For LMAPCD, Regulation 1 .14, Control of Fugitiv e Particulate Emissions can be found at http://www.louisvilleky.gov/NR/rdonlyres/BBE8C0CA-F988-4885-BB59-5775C7304B63/0/114fv2.pdfThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 52 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 

### 6.0 ATTAINMENT DEMONSTRATION An attainment demonstration consists of (a) an alyses that estimate whether selected emission reductions will result in ambient concentrations that meet the NAAQS, and (b) an identified set of control measures which will result in the required emission reductions. The necessary emission reductions for both of these attainment demonstration components may be determined by relying on results obtained with air quality models.

Section 3.0 of the Attainment Modeling Gu idance recommends applying both a modeled attainment test and a subsequent screening test (or unmonitored area analysis) to the air quality modeling results to dete rmine if the annual PM 2.5 NAAQS will be met. Additional technical or corroboratory analyses may also be used as part of a “supplemental analysis” or a more stringent “weight of evidence” determination to supplement the modeled attainment test and to further support a demonstration of attainment of the NAAQS.

6.1 Attainment Test Introduction
The purpose of this modeling assessment is to de termine if control strategies currently being implemented (“on the books”) and proposed control strategies will lead to attainment of the NAAQS for PM 2.5 by the attainment year of 2009. The mo deling is applied in a relative sense, similar to the 8-hour ozone atta inment test. However, the PM 2.5 attainment test is more complicated and reflects the fact that PM 2.5 is a mixture. In the test, ambient PM 2.5 is divided into major components, with a separate relativ e response factor (RRF) and future design value (DVF) calculated for each of the PM 2.5 components. Since the attainment test is calculated on a per species basis, the attainment test for PM 2.5 is referred to as the Speciated Modeled Attainment Test (SMAT). In its entiret y, SMAT consists of four basic steps.

First, the observed quarterly mean PM 2.5 and quarterly mean composition for each monitor is calculated. This is achieved by multiplying the monitored quarterly mean concentration of PM 2.5 from FRM monitors by the monitored fractional composition of PM 2.5 species for each quarter (e.g., (20% sulfate) x (15.0 μg/m 3 PM 2.5 mass) = 3.0 μg/m 3 sulfate mass).

The monitored quarterly mean concentration of PM 2.5 from FRM monitors are the 5-year baseline design values (DVB) that are the result of averaging the 3 current design values (DVC) that straddle the modeling base year. The fractional composition of PM 2.5 species is derived from STN monitoring site data that has been pro cessed by the “sulfate, adjusted nitrate, derived water, inferred carbonaceous material balanc e approach”, or SANDWICH method, so STN and FRM masses are equivalent. The mean co mposition derived from the SANWICH method includes the percent of PM 2.5 that can be attributed to SO 4 , NO 3 , OC, EC, other primary inorganic particulates (o r crustal materials), NH 4 , and particle bound water (PBW).

The second step is to use model results to deri ve component specific RRF for each monitor for each quarter. The RRF is basically the ratio of the model’s future projections to the baseline current projections. For each component, the futu re year modeled quarte rly mean concentration predicted near the monitoring site is divide d by the base year modeled quarterly mean concentration predicted near the monitoring site.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 53 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 For the third step, the component-specific RR Fs are applied to the observed air quality concentrations of the projected qua rterly species estimate. For ea ch quarter, the current quarterly mean component concentration (step 1) are mu ltiplied by the component-specific RRF obtained in step 2. This leads to an estimated future quarterly mean concentration for each component.

The fourth step sums the quarterly components to get a quarterly mean PM 2.5 value. These quarterly mean values are then averaged to produce a future year annual average PM 2.5 estimate, or future design value (DVF), for each FRM monito ring site. This final value is then compared to the NAAQS (15.0 μg/m 3 ) to determine if attainment is reached. For a more detailed discussion of SMAT and the data at each set fo r the monitors in the nonattainment areas, see Appendix L.

6.2 Attainment Test Results
The goal of the SMAT process is to sum the quarterly mean PM 2.5 components to get annual mean for PM 2.5 values. The table below displays the quarterly mean and annual mean PM 2.5 estimates for 2009 the FRM sites in the Kentucky PM 2.5 nonattainment areas.

Table 6.2-1. Quarterly Mean and Annual Mean PM 2.5 Mass Estimates for 2009

AIRS ID County Site Name NonBlank Mass

Q1 NonBlank Mass

Q2 NonBlank Mass

Q3 NonBlank Mass

Q4 2009 Annual

DVF SMAT

21-019-0017 Boyd Ashland 11.388 12.588 15.370 9.823 12.8

21-029-0006 Bullitt Shepherdsv ille 3.034 3.155 3.807 2.569 13.1

21-037-0003 Campbell NKU 2.907 2.883 3.315 2.380 12.0

21-117-0007 Kenton Covingt on 3.006 2.916 3.650 2.613 12.7

21-111-0044 Jefferson Beecher 12.094 13.761 18.124 12.240 14.8

21-111-0048 Jefferson Barret 11.955 13.071 17.740 11.967 14.2

21-111-0051 Jefferson Watson 11.726 13.659 15.530 11.560 13.6

These 2009 annual DVFs are the final product of th e SMAT process and are then compared to the NAAQS (15.0 μ g/m 3 ) to determine if attainment goals will be reached. Values at all of the FRM sites in all the nonatta inment areas that are < 15.0 μ g/m 3 have passed the attainment test portion of the attainment demonstration.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 54 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Kentucky sites are < 15.0 μ g/m 3

. The SMATS values for the coun ties in other states will be available in Appendix O Ohio, I ndiana, and West Virginia Submittals when those documents become available.

Recently, since the draft version of the Kentucky SIP, the MATS tool became available. The MATS software is primarily intended as a tool to implement the modeled attainment tests for particulate (PM 2.5 ) and ozone (O 3 ), and to perform the uniform rate of progress analysis for regional haze (visibility). The MATS tool in corporates updated proc edures and information since the tool that was used in the CAIR modeling. As EPA recommended during the comment period, Kentucky has provided in the following tabl e the MATS attainment test values for 2009 .

MATS results have been provided by the ASIP c ontractor and are summarized in the table below and are available in Appe ndix L Attainment Test.

Table 6.2-2. Summary of Predicted VIST AS-ASIP Design Values using MATS AIRS ID State County 2002 Annual DVC 2009 VISTAS BaseG4 MATS 21-019-0017 KY Boyd 14.9 12.6 54-011-0006 WV Cabell 16.5 14.4 39-087-0010 OH Lawrence 15.7 13.7 39-145-0013 OH Scioto 17.1 14.7
21-029-0006 KY Bullitt 14.9 13.0 21-111-0044 KY Jefferson 16.6 14.5 21-111-0048 KY Jefferson 16.1 14.0 21-111-0051 KY Jefferson 15.4 13.6 18-019-0006 IN Clark 16.3 14.3 18-043-1004 IN Floyd 14.9 12.9 21-037-0003 KY Campbell 13.8 11.6 21-117-0007 KY Kenton 14.9 12.6 39-017-0003 OH Butler 16.1 14.0 39-017-0016 OH Butler 15.5 13.2 39-017-0017 OH Butler 15.3 13.3 39-061-0014 OH Hamilton 17.8 15.5 39-061-0040 OH Hamilton 15.6 13.4 39-061-0041 OH Hamilton 15.8 13.5 39-061-0042 OH Hamilton 16.8 14.3 39-061-0043 OH Hamilton 15.5 13.3 39-061-7001 OH Hamilton 16.3 14.1 39-061-8001 OH Hamilton 17.3 15.0The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 55 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 With MATS, it can be demonstrated that all c ounties in all three non-attainment areas, except one monitor in Hamilton County, Ohio, are < 15.0 μ g/m 3 . However, as discussed Section 6.3-2 to follow, the modeling completed by the Midw est Regional Planning Organization (MRPO), using a more recent base year (2005), suppor ts Hamilton County (39-061-0014) attaining the annual PM 2.5 standard.

6.3 Supplemental Analyses and Weight of Evidence
The Attainment Modeling Guidance asserts that all attainment dem onstrations should be accompanied by supplemental analysis that furt her supports the modeling conclusions. This supplemental analysis can include additional analyses of air quality, emissions, and meteorological data, and consider modeling outputs other than the re sults of the attainment test. If the attainment test results fa ll short of the standard, the resu lts of corroboratory analyses may be used in a weight of evidence determination (WOE) to show that attainment is likely despite modeled results, which may be inconclusive.

The Attainment Modeling Guidance defines the guidelines for supplemental analysis/WOE for the annual PM 2.5 standard as follows:

- Sites with a DVF less than 14.5 μ g/m 3 should submit basic supplemental analysis to confirm the outcome of the model attainment test.

- Sites with a DVF between 14.5 and 15.5 μ g/m 3 should submit a weight of evidence demonstration to aggregate supplemental an alysis to support th e model attainment demonstration.

- Sites with a DVF greater than or equal to 15.5 μ g/m 3 should consider additional control measure to ensure attainment, as more quali tative analysis is unlikely to demonstrate attainment.

The Cincinnati- Middletown, OH-KY-IN, and Huntington-Ashland, WV-KY-OH, PM 2.5 nonattainment areas have DVFs lower than 14.5 μ g/m 3 . One monitor in the Louisville, KY-IN, PM 2.5 nonattainment area has a DVF of 14.8 μ g/m 3 . The following section will be an examination of supplemental analysis to corr oborate modeling results. An additional WOE analysis section will follow to show attainment for the Louisville, KY-IN, PM 2.5 nonattainment

area.

6.3.1 Air Quality Modeling Metrics

Section 7.0 of the Attainment Modeling Guidance suggests several additional modeling exercises that can be performed as part of supplemental/ WOE analysis. One of the metrics that can be considered as part of this type of additional anal ysis is the calculation of the percent change in number of grid cells ≥ 15 μ g/m 3 within the nonattainment area.

For the Louisville, KY-IN, Cincinnati-Middl etown, OH-KY-IN, and Huntington-Ashland, WVKY-OH, nonattainment areas, the cell counts of modeling data were tallied from both the 2002The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 56 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 baseline and the 2009 attainment year modeling run for a subset of the highest day from the base year. This subset of days incl uded all days w ith an 24-hour PM 2.5 concentration greater than 30 μ g/m 3 at any of the monitoring sites in either nonattainment area, as well as the four days with the highest average daily values from each quarter. This selection process identified 28 days for presentation in this appendix, and coincides with the days us ed in the model performance evaluation (Appendix J) and in the model results section (Appendix K). A full listing of the days and the observed 24-hour PM 2.5 concentrations from the monitors in the nonattainment areas can be found in both Appendix J and Appendix K.

Data was extracted for only the grid cells th at contained portions of either of the PM 2.5 nonattainment areas. Figure 6.3.1- 1 highlights the 50 cells that encompass the Kentucky PM 2.5 nonattainment areas.

Louisville Area Northern Kentucky Huntington Ashland

Figure 6.3.1-1. Areas for which the Air Quality Metrics were Applied

The cell counts were binned based on concentration ranges of 15 μ g/m 3 intervals to help illuminate the change in severity on th e days in Kentucky with the highest PM 2.5 concentrations. Figure 6.3.1-2 presents the cell count results gra phically. The graph clearly shows a striking increase in the number of days below 15 μ g/m 3 . By 2009, 70% of cells fall in the 0 –15 μ g/m 3 range, a substantial increase from the 60% in 2002. Raw cell counts show a total of 6729 cells shifted to the 0 – 15 μ g/m 3 range between 2002 and 2009 (Table 6.3.1-1).

Figure 6.3.1-2 also shows a decrease in the number of cells in the 15 – 30 μ g/m 3 bin (5801 cell decrease) and the 30 - 45 μ g/m 3 bin (922 cell decreas e). The number of cel ls in the 45 –60 range shows a decrease to zero from 2002 to 2009. A closer examination of the daily cell counts shows that all of the cells in the highest concen tration category occur on the same day in both the 2002 and 2009 modeling. Overall, the results from the air quality modeling metric are encouraging. The metric shows a substant ial increase in the number of cells below 15 μ g/m 3

, and an increase in cells below 30 μ g/m 3

.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 57 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

2002 2009 Modeling YearPercentage of Nonattainment Area

45-60
30-45
15-30
0-15

Figure 6.3.1-2. Percentage of Cell in PM 2.5 Nonattainment Areas within Concentration Categories for 2002 and 2009.

Table 6.3.1-1. Number of Cells within Concentration Bins. Increases (decreases) in the Number of Cells within the Bins are Noted by Blue (Red) Coloration in the Last Column.

Cincinnati
Concentration 2002 2009 Difference <= 15 ug/m3 12523 15026 2503 > 15 ug/m3 - <= 30 ug/m3 11502 9437 -2065 > 30 ug/m3 - <= 45 ug/m3 795 357 -438 > 45 ug/m3 - <= 60 ug/m3 0 0 0 > 60 ug/m3 0 0 0 Huntington/Ashland
Concentration 2002 2009 Difference <= 15 ug/m3 21248 24116 2868 > 15 ug/m3 - <= 30 ug/m3 8108 5409 -2699 > 30 ug/m3 - <= 45 ug/m3 209 40 -169 > 45 ug/m3 - <= 60 ug/m3 0 0 0 > 60 ug/m3 0 0 0
Louisville
Concentration 2002 2009 Difference <= 15 ug/m3 6761 8119 1358 > 15 ug/m3 - <= 30 ug/m3 5942 4905 -1037 > 30 ug/m3 - <= 45 ug/m3 431 116 -315 > 45 ug/m3 - <= 60 ug/m3 6 0 -6 > 60 ug/m3 0 0 0The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 58 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 6.3.2 Other Modeling Results One way to acquire modeling sensitivity runs is to examine the modeling results from other RPOs or from USEPA modeling st udies. Other modeling studies may use different physical and chemical modeling options for their meteorologi cal and air quality modeling runs, which would provide a comparison or sensitivity based on these different options.

An air quality modeling exercise th at contained results for Kentucky PM 2.5 nonattainment areas is the USEPA’s modeling for the CAIR. The T echnical Support Document for the final CAIR, March 2005, provided modeling results with a nd without the implementation of CAIR. Differences between the USEPA’s modeling and the attainment demonstration are: 1) the meteorology was for 2001, 2) the DVB was the weighted design values the 1999-2003 period and 3) the modeling results were for 2010.

The DVF was calculated using the CAIR SMAT tool, so met hodologies between the CAIR DVF and the values presented in Section 6.4 are the sa me. These modeling results are listed in Table 6.3.2-1 below.

Table 6.3.2-1. USEPA’s CAIR SMAT Modeling Results

Future Year Boyd Co Bullitt Co Jefferson Co Kenton Co

2010 13.38 13.67 15.44 13.72

2015 12.95 N/A 15.13 13.26

The USEPA’s results were for the highest monitor in a county where more than one monitor is located. The USEPA’s modeling re sults predicts that the Kentuc ky nonattainment areas, except for Jefferson County, should be below the annual PM 2.5 standard by 2010.

Although 2010 is one year later th an the attainment year for these areas, the USEPA’s 2010 CAIR DVFs are approximately 0.5 μ g/m 3 higher than what the KYDAQ is showing in the attainment demonstration, but still supports that the Kentucky nonattainment areas will attain the annual PM 2.5 standard by the attainment year of 2009.

The new MATS provided opportunity to use the updated speciation section of the tool as compared to the older CAIR SMAT tool. As DAQ has already noted prev iously in Section 6.2, Jefferson is below 15 μ g/m 3 for both ASIP-VISTAS SMAT (14.8 μ g/m 3 ) and the more recent ASIP-VISTAS MATS (14.5 μ g/m 3 ).

And more significantly, the modeling comp leted by the Midwest Regional Planning Organization (MRPO), using a more recent base year (2005), also supports Jefferson County (12.8 μ g/m 3 ) being well below 15 μ g/m 3

, as discussed in the following section in more detail.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 59 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 The link to the website for the CAIR Modeling values for 2010 is:

http://www.epa.gov/cair/pdfs/finaltech02.pdf

Ohio and Indiana Modeling

Additional air quality modeling that encompassed the Ke ntucky nonattainment areas was performed by the Midwest Regional Planning Or ganization (MRPO) for both the Indiana and Ohio attainment demonstration submittals. The MRPO is made up of the five Midwest states (Illinois, Indiana, Michigan, Ohio and Wisconsin) and the Lake Michigan Air Directors Consortium (LADCO).

The air quality model selected fo r this technical anal ysis was CAMx (version 4.30), an Eulerian photochemical grid model developed by ENVIRON and approved by US EPA for this use. CAMx allows for integrated “one-atmosphere” assessment of ozone and PM 2.5 . More notable features of CAMx include flexi- nesting, which allows for reconfi guration of nested grids within the model, multiple gas phase chemistry mechan ism options, Plume-in-Grid (PiG), and Ozone Source Apportionment Technology. CAMx m odeling is performed on a Linux computing platform with a Portland Group (PGI) FORTRA N compiler to create executable files.

After the 2005 base episodes were modeled and determined to be within accuracy parameters, several future-year exercises were performed such as projecting emissions to 2008 and 2009 and modeling the projected emission re ductions from national, regional, and local control measures that are in effect or considered “on the books”. This includes the NO x SIP Call and Clean Air Interstate Rule (CAIR) as well as the la test gasoline and engine control measures.

The table below summarizes the modeling results a nd illustrates that all monitored areas in the nonattainment areas will attain the NAAQS by 2009.

Table 6.3.2-2. Summary of VISTAS MATS and LADCO 2009 Design Values
AIRS ID State County 2002 Annual DVC VISTAS BaseG4 MATS LADCO RPO 2009 Value PM Round 5

21-019-0017 KY Boyd 14.9 12.6 11.8 54-011-0006 WV Cabell 16.5 14.4 13.4 39-087-0010 OH Lawrence 15.7 13.7 12.7 39-145-0013 OH Scioto 17.1 14.7 12.2 21-029-0006 KY Bullitt 14.9 13.0 12.4 21-111-0044 KY Jefferson 16.6 14.5 12.8 21-111-0048 KY Jefferson 16.1 14.0 12.5 21-111-0051 KY Jefferson 15.4 13.4 12.1The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 60 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008

18-019-0006 IN Clark 16.8 14.9 13.6 18-043-1004 IN Floyd 14.9 13.0 12.1 21-037-0003 KY Campbell 13.8 11.6 11.6 21-117-0007 KY Kenton 14.9 12.6 11.8 39-017-0003 OH Butler 16.1 14.0 - 39-017-0016 OH Butler 15.5 13.2 13.0 39-017-0017 OH Butler 15.3 13.3 13.6 39-061-0014 OH Hamilton 17.8 15.5 14.4 39-061-0040 OH Hamilton 15.6 13.4 12.7 39-061-0041 OH Hamilton 15.8 13.5 13.0 39-061-0042 OH Hamilton 16.8 14.3 13.9 39-061-0043 OH Hamilton 15.5 13.3 12.9 39-061-7001 OH Hamilton 16.3 14.1 13.3 39-061-8001 OH Hamilton 17.3 15.0 14.6

The LADCO-RPO modeling shows attainment in 2009 for all counties in the nonattainment areas. The contradictory results (see table a bove) between the VISTAS-ASIP modeling and the LADCO-RPO modeling are due almost entirely to the separate a nd distinct base years used. The VISTAS-ASIP modeling relied on 2002 base y ear emissions. The LADCO-RPO modeling relied on the more recent 2005 base year em issions. Overall the LADCO-RPO modeling included more recent ambient data to predict fu ture year design values . Additionally, LADCO used the CAMX model, while VISTAS used th e CMAQ model. Areas that show nonattainment using the older base year also show atta inment using the more recent updated data.

6.3.3 Air Quality Trends and Additional Reductions in Emissions

Since the annual PM 2.5 designation in 2002, annual average concentrations of PM 2.5 have decreased. Table 6.3.3-1 provides the annual averag e data. These values indicate the monitors are still trending towards the NAAQS.

Table 6.3.3-1. Annual Average PM 2.5 Concentrations in the NAAs for the Past 8 Years
AIRS ID County Site Name 2000 2001 2002 2003 2004 2005 2006 2007

21

‐ 019

‐ 0017 Boyd Co., KY Ashland 15.7 15.3 15.5 13.9 13.3 16.0 13.8 14.3

54

‐ 011

‐ 0006 Cabell Co., WV Huntington 17.6 17.5 16.7 15.5 15.2 18.1 15.0 16.7

39

‐ 087

‐ 0010 Lawerence Co., OH Ironton 17.4 17.7 15.5 14.3 13.7 17.0 14.4 15.0The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 61 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 39

‐ 145

‐ 0013 Scioto Co., OH New Boston 21.1 20.3 16.7 14.7 13.0 16.2 14.3 14.0

21

‐ 029

‐ 0006 Bullitt Shepherdsville 16.4 15.6 14.7 14.4 13.6 16.3 14.1 15.3

21

‐ 037

‐ 0003 Campbell NKU 15.1 13.4 14.8 13.4 12.8 14.8 11.5 14.4

21

‐ 117

‐ 0007 Kenton Covington 16.3 15.3 15.1 14.3 13.4 15.9 13.3 14.2

39

‐ 017

‐ 0003 Butler Co., OH Middletown 17.0 16.4 16.8 15.1 14.1 19.0 14.1 15.4

39

‐ 017

‐ 0016 Butler Co., OH Fairfield 18.9 15.9 15.3 15.8 14.7 17.9 14.0 14.9

39

‐ 061

‐ 0014 Hamilton Co., OH Seymour 19.3 18.2 17.9 17.0 15.9 19.8 15.5 16.6

39

‐ 061

‐ 0040 Hamilton Co., OH Howard Taft 16.7 15.9 15.3 15.5 14.6 17.5 13.6 15.1

39

‐ 061

‐ 0042 Hamilton Co., OH W. 8th 20.6 17.6 16.8 16.7 16.0 19.1 14.9 15.9

39

‐ 061

‐ 0043 Hamilton Co., OH Sharonville 19.1 16.1 15.4 15.7 14.9 16.9 14.5 14.9

39

‐ 061

‐ 7001 Hamilton Co., OH Norwood 17.2 16.8 16.1 16.0 15.3 18.4 14.4 15.1

39

‐ 061

‐ 8001 Hamilton Co., OH St. Bernard 19.3 17.0 17.0 17.3 16.4 20.0 15.9 16.1

21

‐ 111

‐ 0043 Jefferson 37th 17.3 n/a 17.2 16.0 14.5 16.7 15.0 15.1

21

‐ 111

‐ 0044 Jefferson Beecher 16.7 17.7 17.5 15.4 14.1 16.5 15.2 14.9

21

‐ 111

‐ 0048 Jefferson Barret 16.7 16.9 16.4 15.5 13.7 16.8 14.0 15.1

21

‐ 111

‐ 0051 Jefferson Watson 16.8 16.3 15.7 14.9 12.6 16.5 13.7 15.7

18

‐ 019

‐ 0006 Clark Co., IN Jeffersonville 18.6 16.9 16.0 n/a 15.1 18.5 14.9 16.5The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 62 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 18

‐ 043

‐ 1004 Floyd Co., IN New Albany 16.0 15.8 14.6 14.5 13.71 16.7 13.3 14.7

Annual average PM 2.5 values are presented in micrograms per cubic meter (ug/m 3 ). Source: USEPA/AQS. Bolded values represent annual average values that exceed the level of the annual PM 2.5 National Ambient Air Quality Standard (i.e. greater than 15.0 ug/m 3 ). n/a ‐ The site moved mid

‐ year or did not meet 75% data recovery requireme n

Figure 6.3.3-1. Annual PM 2.5 Average Concentrations for the FRM Monitors in the Kentucky portion of Louisville, KY -IN, Cincinnati- Middletown, OH-KY-IN, and Huntington-Ashland, WV-KY- OH, Nonattainment Areas

The figure below provides a graphical represen tation of the Kentucky portion of the data.

With the improvement in annual average PM 2.5 values, there has also been an improvement in PM 2.5 design values. When one takes in to account the period of record, PM 2.5 design values improved significantly over the last 8 years. 

### Annual PM 2.5 

### Averages for Kentucky

11.0 12.0 13.0 14.0 15.0 16.0 17.0 18.0 19.0

2000 2001 2002 2003 2004 2005 2006 2007

21-019-0017 Boyd 21-029-0006 Bullitt 21-037-0003 Campbell NKU 21-117-0007 Kenton 21-111-0043 Jefferson 21-111-0044 Jefferson 21-111-0048 Jefferson 21-111-0051 JeffersonThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 63 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Like with the annual averages, the three-year design values (T able 6.6.3-2) have also begun to hover near the level of the standard for the Louisville, IN-KY monitors in recent years. It is also important to note in the Cinc innati- Middletown, OH-KY-IN, a nd the Huntington-Ashland, WVKY-OH, monitors have also maintained design values that meet the NAAQS over the past 3 design value periods (See Table 6.3.3-2).

Table 6.3.3-2. Three-Year Design Values for the FRM Monitors in the Louisville, KY-IN, Cincinnati- Middl etown, OH-KY-IN, and Huntington-Ashland, WV-KY-OH, PM 2.5 Nonattainment Areas

AIRS ID County Site Name 2000

‐ 2002 2001

‐ 2003 2002

‐ 2004 2003

‐ 2005 2004

‐ 2006 2005

‐ 2007

21

‐ 019

‐ 0017 Boyd Ashland 15.5 14.9 14.3 14.4 14.4 14.7

54

‐ 011

‐ 0006 Cabell Co., WV Huntington 17.3 16.6 15.8 16.3 16.1 16.6

39

‐ 087

‐ 0010 Lawerence Co., OH Ironton 16.8 15.8 14.5 15.0 15.0 15.4

39

‐ 145

‐ 0013 Scioto Co., OH New Boston 19.4 17.2 14.8 14.6 14.5 14.9

21

‐ 037

‐ 0003 Campbell NKU 14.4 13.9 13.7 13.7 13.1 13.6

21

‐ 117

‐ 0007 Kenton Covington 15.5 14.9 14.3 14.5 14.2 14.5

39

‐ 017

‐ 0003 Butler Co., OH Middletown 16.7 16.1 15.3 16.1 15.7 16.2

39

‐ 017

‐ 0016 Butler Co., OH Fairfield 16.7 15.7 15.3 16.1 15.5 15.6

39

‐ 061

‐ 0014 Hamilton Co., OH Seymour 18.4 17.7 16.9 17.5 17.1 17.3

39

‐ 061

‐ 0040 Hamilton Co., OH Howard Taft 16.0 15.6 15.1 15.9 15.2 15.4

39

‐ 061

‐ 0042 Hamilton Co., OH W. 8th 18.4 17.1 16.5 17.3 16.7 16.6

39

‐ 061

‐ 0043 Hamilton Co., OH Sharonville 16.9 15.7 15.3 15.8 15.4 15.4The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 64 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 39

‐ 061

‐ 7001 Hamilton Co., OH Norwood 16.7 16.3 15.8 16.6 16.0 15.9

39

‐ 061

‐ 8001 Hamilton Co., OH St. Bernard 17.8 17.1 16.9 17.9 17.4 17.3

21

‐ 029

‐ 0006 Bullitt Shepherdsville 15.6 14.9 14.2 14.8 14.7 15.3

21

‐ 111

‐ 0043 Jefferson 37th n/a n/a 15.9 15.7 15.4 15.6

21

‐ 111

‐ 0044 Jefferson Beecher 17.3 16.9 15.6 15.3 15.2 15.5

21

‐ 111

‐ 0048 Jefferson Barret 16.7 16.3 15.2 15.3 14.8 15.3

21

‐ 111

‐ 0051 Jefferson Watson 16.3 15.6 14.4 14.7 14.3 15.3

18

‐ 019

‐ 0006 Clark Co., IN Jeffersonville 17.2 n/a n/a n/a 16.2 16.6

18

‐ 043

‐ 1004 Floyd Co., IN New Albany 15.5 15.0 14.3 15.0 14.6 14.9

PM 2.5 design values are presented in micrograms per cubic meter (ug/m 3 ). Source: USEPA/AQS Bolded values represent annual average values that exceed the level of the annual PM 2.5 National Ambient Air Quality Standard (i.e. greater than 15.0 ug/m 3 ). n/a

– The site did not meet the 75% data recovery requirement.
Both KYDAQ and the Louisville Metro Air Pollution Control District have submitted exceptional events data exclus ion packages for the years 2004-2007. Upon U.S. EPA approval, high monitoring days would be excluded from th e calculations of the three-year averages demonstrating even lower design values than listed in the tables above.

The Cabinet included, in Appendix O “Ohio, Indiana, and West Virginia Submittals”, the individual submittals for other states in the th ree nonattainment areas. Where the state has not currently submitted to their respective USEPA re gional office, Kentucky w ill add the copy to the appendix as soon as one becomes available.

6.4 Unmonitored Area Analysis
Regarding the U.S. EPA guidance (Section 3) in “The Use of Models a nd Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze” (April 2007), the States are asked to review unmonitore d areas in nonattainment areas. The test is called an “unmonitored test analysis”, and is necessary in nonattainment areas where the PM 2.5 monitoring network just meets or minimally exceeds the size of the network required to report data to Air Quality System (AQS). The purpose of the analysis is to use a combination of modelThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 65 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 output and ambient data to iden tify areas that might exceed the NAAQS if monitors were located there.

This review is intended to ensure that a control strategy leads to reductions in PM 2.5 at other locations which could have baseline (and futu re) design values exceeding the NAAQS were a monitor deployed there. The unmonitored area anal ysis should identify areas where future-year design values are predicted to be greater than the NAAQS.

The unmonitored analysis area is intended to be the primary means for identifying high PM 2.5 concentrations outside of traditionally monito red locations. The spatial resolution of the modeling that is the und erlying basis of the unmonitored area analysis will determine how well it addresses primary PM hotspot issues. The finer the resolution of the grid model, the more likely that primary PM hotpots will be recognized.

Based on the monitoring guidance, it is believed that an unmonitored area analysis conducted at 12km or finer resolution is suffi cient to address unmonitored PM 2.5 for the annual NAAQS.

The ASIP modeling provided current-year (DVC) and projected future-year (DVF) PM 2.5 Design Values (ug/m 3 ) in Kentucky using the 2002 Typical and 2009 BaseG4 CMAQ 12 km modeling results. See Appendix P whic h contains various Technical Support Documents (TSD) from VISTAS and ASIP, “Chapter 4.0 PM 2.5 Projections” from the Technical Support Document provided by ENVIRON, January, 2008, discusses the DVC and the DVF.

As noted in the ENVIRON Technical Support Document, Chapter 4.0, “Section 4.7.6 Kentucky”, of the 28 FRM monitoring sites in the state, four of them have current-year PM 2.5 Design Values (DVCs) that exceed the annual PM 2.5 NAAQS. Jefferson County was the second highest DVC of 16.6 μ g/m 3 which has a projected 2009 DVF of 14.8 μ g/m 3 using 12 km CMAQ results, which is below the NAAQS.

The ASIP-VISTAS contractor provided maps to illustrate the MATS projections for the unmonitored areas. See Appendix L Attainment Test for September 18, 2008 document entitled “ASIP PM 2.5 Projections for Unmonitored Areas”.

All FRM monitoring sites in Kentucky are proj ected to be below the annual average PM 2.5. See Figure 6.3.3-2 and Figure 6.3.3-3 belo w. And Table 6.3.3-3 that follows.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 66 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Figure 6.3.3-2

Kentucky 2002 Design Value (Left) and 2009 base G2 12km projected DVF (Middle) and 2009 base G2 36km projected DVF (Right)

0 2 4 6 8 10 12 14 16 18Bell-0002Boyd-0017Bullitt-0006Campbell-0003Carter-0500Christian-0006Daviess-0014Fayette-0012Fayette-0014Franklin-0006Hardin-0006Henderson-0006Henderson-0014Jefferson-0044Jefferson-0048Jefferson-0051Kenton-0007Madison-0003McCracken-1004Perry-0003Pike-0002Warren-0007

Kentuckyug/m3 Sum of PBW Sum of NH4 Sum of Crustal Sum of EC Sum of OC Sum of NO3 Sum of SO4

Figure 6.3.3-3

Kentucky 12km 2009 Projected DVF by G4a_EXCEL(Left) and G4a_MATS (Middle) andG2a_EXCEL (Right)

0 2 4 6 8 10 12 14 16Bell-0002Boyd-0017Bullitt-0006Campbell-0003Carter-0500Christian-0006Daviess-0014Fayette-0012Fayette-0014Franklin-0006Hardin-0006Henderson-0006Henderson-0014Jefferson-0044Jefferson-0048Jefferson-0051Kenton-0007Madison-0003McCracken-1004Perry-0003Pike-0002Warren-0007

Kentuckyug/m3 PBW
NH4 Crustal EC OC NO3 SO4 blankThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 67 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Table 6.3.3-3 Current Year (DVC) and projected future-year (DVF) PM 2.5 Design Values (ug/m 3 ) in Kentucky using the 2002 Typical and 2009 Base G4 CMAQ 12 km modeling results.

2002 Annual 2009g4a Annual MATS 20092g4a MATS minus 2002gt2a AIRS ID State County DVC DVF Difference 21-013-0002 KY Bell 14.8 12.8 -2.0 21-019-0017 KY Boyd 14.9 12.6 -2.3 21-029-0006 KY Bullitt 14.9 13.0 -1.9 21-037-0003 KY Campbell 13.8 11.6 -2.2 21-043-0500 KY Carter 12.2 10.2 -2.0 21-047-0006 KY Christian 13.5 11.9 -1.6 21-059-0014 KY Daviess 14.4 12.8 -1.6 21-067-0012 KY Fayette 14.9 12.5 -2.4 21-067-0014 KY Fayette 15.6 13.2 -2.4 21-073-0006 KY Franklin 13.7 11.5 -2.2 21-093-0006 KY Hardin 14.0 12.1 -1.9 21-101-0006 KY Henderson 14.5 13.0 -1.5 21-111-0043 KY Jefferson 15.9 14.0 -2.0 21-111-0044 KY Jefferson 16.6 14.5 -2.1 21-111-0048 KY Jefferson 16.1 14.0 -2.0 21-111-0051 KY Jefferson 15.4 13.4 -2.0 21-117-0007 KY Kenton 14.9 12.6 -2.3 21-125-0004 KY Laurel 12.2 10.5 -1.7 21-145-1004 KY McCracken 13.1 11.8 -1.3 21-151-0003 KY Madison 13.5 11.4 -2.1 21-193-0003 KY Perry 13.2 11.2 -2.0 21-195-0002 KY Pike 13.7 11.6 -2.1 21-227-0007 KY Warren 13.8 12.1 -1.7 *provided by VISTAS contractor, October 2008

6.5 Data Access
The modeling input and output file s are very large and it would not be resource-efficient to submit all of these files with th e SIP attainment demonstration. These include all files used to process the emissions, meteorology and air quality models and any other files used to develop the modeling.

Here is the link to the VISTAS final work produ cts some of which are relevant to the PM2.5 SIP attainment demonstration:

http://www.vistas-sesarm.or g/documents/FinalDocs.aspThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 68 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 The LADCO-Midwest RPO information the below link:

http://www.ladco.org/

Here is the link the CAIR Modeling values for 2010:

http://www.epa.gov/cair/pdfs/finaltech02.pdfThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 69 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 

### 7.0 CLEAN AIR ACT SECT ION 172C REQUIREMENTS Section 172(c) of the CAA, as amended, contains the general requirements for nonattainment areas. These requirements are listed below and are discussed in more detail in the following sections.

Section 172(c) Nonattainment Plan Provisions

(1) Reasonably available control measures (2) Reasonable further progress (3) Actual emissions inventory and periodic emissions inventory (4) New source review (5) Permit requirements for new and modified sources (6) Other measures as may be necessary to pr ovide attainment by specified attainment date (7) Compliance with Section 110(a)(2) (8) Equivalent techniques (9) Contingency measures

7.1 Reasonably Available Control Measures (RACM)
Section 172(c)(1) of the CAA requi res SIPs to provide for the im plementation of all RACM to demonstrate attainment as expeditiously as pr acticable. A subset of RACM is reasonably available control technol ogy (RACT), which relates specifically to stationary point sources.

The CAA requires a demonstration that the State has adopted all reasonable and available control measures to demonstrate attainment as expedi tiously as practicable and that no additional measures that are reasonably availabl e will advance the attainment date.

Although regional photochemical modeling indicates that no additional control measures are necessary to achieve the annual fine partic le standard by the attainment date, KYDAQ participates in the regional pl anning effort through the Southeas t Regional Planni ng Organization (RPO), Visibility Improvement State and Tribal Association of the Sout heast (VISTAS) and the Association of Southeastern Integr ated Planning (ASIP) to evalua te potential control measures to attain the 8-hour ozone and fine particle sta ndards and achieve regional haze goals. Candidate control measures were evaluated primarily for feas ibility, cost effectiveness, and the ability to implement them in a relatively short time fr ame (i.e., January 1, 2009, for the 2009 monitoring year). Due mainly to lengthy rulemaking processe s, many of the control strategies evaluated could not be implemented by the 200 9 monitoring year and were not pursued since they were not needed to demonstrate attainment.

However, notwithstanding the f act that regional modeling demonstrates compliance for the Louisville, KY-IN, nonattainment area without the implementation of additional local measures and that no additional, SIP-creditable, meani ngful control measures could be adopted and implemented to advance the attainment date by one year, the Louisv ille Metro Mayor, Jerry Abramson, created the regional Fine Particle Air Quality Task Fo rce (Task Force) to identify,The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 70 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 evaluate, and recommend strategies for reducing PM 2.5 to achieve the annual PM 2.5 standard. Part of the Task Force’s charge was to asse ss potential RACM/RACT opportunities. To focus on meaningful RACM/RACT opportunities, the Task Fo rce reviewed stationary sources comprising at least 90% of the point source emissions of direct PM 2.5 , NO x , and SO 2 and the non-road mobile sources comprising at least 90% of the nonroad mobile source emissions of direct PM 2.5 , NO x , and SO 2 , as well as mobile sources.

With respect to RACT for stationary sources, the Task Force found that many of the larger stationary sources of direct PM 2.5 , NO x , or SO 2 already employed RACT. It is noted that the EPA, in the preamble to its Clean Air Fine Particle Implementation Rule , indicates that the EPA presumes (with certain conditions) that electric utilities that comply with the Clean Air Interstate Rule (CAIR) have met the RACT requirement for NO x and SO 2 . Further, the Task Force did not identify any new control measures to be r ecommended for inclusion in the Louisville nonattainment area’s attainment demonstration. However, the Task Force noted that the following new control measures are in the process of being implemented:

1. Gallagher Station (Duke Energy), Fl oyd County, IN, is in th e process of replacing electrostatic precipitators with more effective fabric filter collectors for all four units, to be completed by May 2008

2. General Electric, Jefferson County, KY, is replacing a backup co al-fired bo iler with a landfill gas/natural gas boiler.

3. Süd-Chemie (a ca talyst manufacturer), Jefferson County, KY, is installing high efficiency particulate air (HEPA) filters following existing fabric filter collectors to further reduce particulate emissions.

4. Kosmos (a cement kiln), Jefferson County, KY, since 2005, has re placed several fabric filter collectors and added measures to contro l fugitive dust. Kosmos is also in the process of modifying some of its existing fabric filter collec tors to increase their control efficiencies.

7.2 RACM Determination

The Kentucky PM 2.5 Nonattainment Areas will continue to implement the RACM measures already adopted and described in Section 5 of this document. The above analysis establishes that these measures contributed to the regi on being able to comply with the PM 2.5 NAAQS (1997). Therefore, this analysis demonstrates that ther e are no additional measures that are necessary to demonstrate attainment as expeditiously as pr acticable and to meet any RFP requirements and that there are no potential measures that if cons idered collectively would advance the attainment year by one year or more. The above analysis meets the applicable statutory requirements set forth at Section 172(c)(1) of the Clean Air Act a nd the applicable regula tory requirements set forth at 40 C.F.R. Section 51.1010.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 71 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 7.3 RACT Applicability

40 CFR 51.1010 notes that for each PM 2.5 nonattainment area, a SIP revision must be submitted that demonstrates all RACM, including RACT fo r stationary sources, necessary to demonstrate attainment as expeditiously as practicable, have been adopted. The secti on of the implementation rule goes on to state that potential measures th at are reasonably available considering technical and economic feasibility must be adopted as RACM if, consider ed collectively, they would advance the attainment date by one year or mo re. As discussed in Section 6.2.1, the states determined that there are no additional contro l measures that could be adopted by January 1, 2008. Further, existing measures, and those pla nned for implementation by 2009, are expected to enable the region to continue to demonstrate compliance with the PM 2.5 NAAQS (1997) through the 2009 attainment date. As such, no further actions on RACT are warranted.

7.4 Reasonable Further Progress

In the PM 2.5 Implementation Rule, the USEPA maintain ed that an area that demonstrates attainment by 2010 would be considered to have satisfied the RFP requirement and need not submit any additional material to satisfy this requirement. The USEPA will view an approved attainment demonstration as demonstrating that the area is making reasonable further progress toward attainment.

7.5 Actual Emissions Inventory
Section 172(c)(3) requires the development of a comprehensiv e, accurate, current inventory of actual emissions from all sources in the nonattain ment area. Such inventory is due two years after the effective date of the PM 2.5 nonattainment designations , i.e., April 5, 2007. The KYDAQ and the LMAPCD met this requirement through the submittal of the 2002 emission inventories under the CERR for the Kentucky counties in this nona ttainment area.

The KYDAQ submitted statewide emissions for area, nonroad mobile, and highway mobile sources. For stationary point sources, The KYDAQ submitted inventorie s for those counties without a local program. The final 2002 emi ssion inventories used in the attainment demonstration will go through the public hearing pr ocess with the full attainment demonstration, which will include any updates or revisions that are necessary since the CERR submittal.

7.6 Periodic Emissions Inventory
Section 172(c)(3) requires peri odic inventory submittals. Th e KYDAQ and the LMAPCD plan to meet this requirement through the CE RR submittals. The KYDAQ and the LMAPCD submitted the 2005 emissions inventory in the summer of 2007. Similar to the 2002 CERR submittal, the 2005 CERR submittal included point s ources for all but those counties with local programs, and statewide area, nonroad mobile, and highway mobile sources.

7.7 Other Measures
Section 1729(c)(6) requires the nonattainment SIPs to include enforceable limitations and other control measures, along with schedules for comp liance as needed to demonstrate attainment.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 72 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Section 5.0 of this document discusses in detail the Federal and State measures that were modeled to show attainment. Appendix M contains the rules.

7.8 Compliance with Section 110(a)(2)
Section 172(c)(7) requires nonattai nment SIPs to meet the app licable provisions of Section 110(a)(2). On October 2, 2007, the USEPA provi ded guidance on SIP elements required under Section 110(a)(1) and (2) fo r the 8-hour ozone and PM 2.5 NAAQSs. Regarding the PM 2.5 NAAQSs, the only SIP element of concern is 110 (a)(2)(G) which relates to emergency episodes.

The USEPA has not yet taken regulatory action to provide the necessary numerical limits and concentration levels for emergency episode action plans for PM 2.5 . The states look to the USEPA to provide this information in order to adopt the necessary rules that will protect the public health. Once the USEPA has promulgated rules setting the emergency episode limits, the KYDAQ will start the rulemaking process to adopt these limits.

The KYDAQ and the LMAPCD believe that with the exception of 110(a)(2)(G) prior rule submittals, along with this attainment demonstrati on plan, address the relevant requirements of Section 110(a)(2).

7.9 Equivalent Techniques
The KYDAQ believes that the pr ocedures for modeling, emissi ons inventory and planning follow the USEPA guidance and is not requesti ng approval for equivalent techniques, as envisioned under Section 172(c)(8).

7.10 Contingency Measures
Section 172(c)(9) requires that th e nonattainment SIPs contain speci fic measures that would take effect upon a State’s failu re to attain the PM 2.5 standard in a given area, without further action by the State or the USEPA. The contingency plan consists of Federal measures.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 73 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 

### 8.0 MOTOR VEHICLE EMISSIONS BUDGETS

8.1 Transportation Conformity
The purpose of transportation conformity is to ensure that Federal transportation actions occurring in a nonattainment area do not hinder th e area from attaining and/or maintaining the annual PM 2.5 standard. This means that the level of emissions estimated by the KYTC or the metropolitan planning organizations for the Tran sportation Implementation Plan and Long Range Transportation Plan must not exceed the motor vehicle emission budgets (MVEBs) as determined in this attainment demonstration SIP.

8.2 Pollutants to be Considered
40 CFR 93.119(f)(7) through (10) identifies the pollutants for PM 2.5 that regional emissions analysis needs to be performed for transportatio n conformity purposes. On ly primary, or direct, PM 2.5 tailpipe emissions must be considered for transportation conformity regional emissions analysis. The precursor pollutants NOx, VOC, SO 2 , and ammonia, as well as reentrained road dust only need to be considered if the KYDAQ a nd/or the USEPA has deemed the pollutant as a significant contributo r to the overall PM 2.5 nonattainment problem. The KYDAQ has determined that the precursor pollutants NOx, VOC, ammonia, and mobile source SO 2 , as well as reentrained road dust are insignifi cant contributors to the overall PM 2.5 nonattainment problem in Kentucky. Therefore, the KYDAQ is not es tablishing MVEBs for these pollutants.

The PM 2.5 precursor SO 2 could not be deemed insignificant to the overall PM 2.5 nonattainment problem since sulfate is such a large fraction of the PM 2.5 composition. However, the KYDAQ has determined that SO 2 emitted by the mobile source sector is insignificant. The USEPA in its Federal Register notice for PM 2.5 does not address the mobile sect or in its listi ng of significant sources of SO 2 emissions. Kentucky agrees with the following statements addressing SO 2 from on-road mobile emissions as published in the May 6, 2005, Federal Register, 70 FR 24283:

While speciated air quality data show that sulfate is a rela tively significant component (e.g., ranging from nine to 40 percent) of PM 2.5 mass in all regions of the country, emissions inventory da ta and projections show that on-r oad emissions of SOx constitute a ‘‘de minimis’’ (i.e., extremely small) portion of total SOx emissions . Emissions inventory data for 1999 for the 372 potential PM 2.5 nonattainment counties for PM 2.5 (based on 1999–2001 air quality data) show that on-road sources were responsible for only two percent of total SOx emissions.

Furthermore, EPA has already adopted two regulations that will greatly reduce emissions of SOx from on-road sources by the tim e such regulations are both in full effect in 2009. .........This regulation will reduce the sulfur content of diesel fuel by approximately 97 percent nationally when fully effective.

Although sulfate is a significant component of the PM 2.5 nonattainment problem in Kentucky, the majority of the SO 2 emissions in 2009 come from the sta tionary point source sector with the mobile source sector only contributing two tenths of one percent (0.2 %). This is consistent withThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 74 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 what the USEPA stated above. The discussion about the significance of mobile source SO 2 emissions can be found in Appendix F.3. For the reasons discussed, the KYDAQ has determined that mobile source SO 2 emissions are insignificant to the PM 2.5 nonattainment problem.

An affirmative insignificance finding from the USEPA only relieves the transportation partners from a regional emissions analysis for these pollutant emissions for these areas and does not relieve them of the other transportation conform ity requirements. The transportation partners will need to note the insignifican ce finding for these pollutants (if found adequate and approved by the USEPA) in future conformity determinations.

Louisville, KY-IN, PM 2.5 Nonattainment Area

As part of the consultation process on setting MVEBs, the KYDAQ participated in several conference calls with all of the transportation partners. The KYDAQ, Louisville Metro Air Pollution Control District (LMA PCD), Indiana Department of Environmental Management (IDEM), Kentuckiana Regional Planning and Development Agency (KIPDA), and other agencies involved in the transportation conform ity process have agreed with continuing the previously utilized approach of maintaining regional mobile source emissions budgets. The following table shows the highway mobile NOx and PM 2.5 emissions in tons per year for the Louisville, KY-IN area

Table 8.2-1 Highway Mobile Source Emi ssions for the Louisville, KY-IN, PM 2.5 Nonattainment Area

2009 Tons/Year NOx 21,575.40 PM 2.5 374.85

A reasonable buffer has been applied to the 2009 B udgets in the amount of 5%. Buffers are used to accommodate the wide array of assumptions that are factored into the calculation process. Since assumptions change over time, it is necessa ry to have a buffer that will accommodate the impact of refined assumptions in the process. With the buffe r applied to the 2009 Budget, the 2009 total PM 2.5 and NO

x emissions remain well below the 2002 base year emissions.

Therefore, a MVEB (21,575.40 t ons/year NOx, 374.85 tons/year PM 2.5 ) is established for transportation conformity purposes for the Louisville, KY-IN, PM 2.5 nonattainment area for 2009. Upon USEPA’s affirmative adequacy finding for these MVEB’s, these MVEB’s will become the applicable MVEB’s.

Cincinnati- Middletown, OH-KY-IN

As part of the consultation process on setting MVEBs, the KYDAQ participated in several conference calls with all of the transportation part ners. It was decided to have sub-area budgets for the Kentucky portion of the nonattainment area and a comb ined sub-area budget for theThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 75 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Indiana and Ohio portion of the nonattainment ar ea. The MVEBs will be set for the attainment year 2009.

Table 8.2-2 Highway Mobile Source Emission s for the Kentucky portion of the Cincinnati-Middletown, OH-KY-IN, PM 2.5 nonattainment area 2009 Tons/Year NOx 7,186.77 PM 2.5 117.45

A reasonable buffer has been applied to the 2009 B udgets in the amount of 5%. Buffers are used to accommodate the wide array of assumptions that are factored into the calculation process. Since assumptions change over time, it is necessa ry to have a buffer that will accommodate the impact of refined assumptions in the process. With the buffe r applied to the 2009 Budget, the 2009 total PM 2.5 and NO

x emissions remain well below the 2002 base year emissions.

Therefore, a MVEB (7,186.77 to ns/year NOx, 117.45 tons/year PM 2.5 ) is established for transportation conformity purposes for the Ke ntucky portion of the Ci ncinnati- Middletown, OHKY-IN, PM 2.5 nonattainment area for 2009. Upon USEPA’ s affirmative adequacy finding for these MVEB’s, these MVEB’s will b ecome the applicable MVEB’s.

Huntington-Ashland, WV-KY-OH

For PM 2.5 , the pollutant itself and all its various pr ecursors typically woul d require analysis. However, as noted in the implementation rule , ammonia and volatile organic compounds - while recognized as such precursors - are not considered as signifi cant overall to th e nonattainment problem. Therefore, they are not considered as an attainment plan precursors for SIP development purposes. Further, other polluta nts/precursors may be considered significant overall but the highway contribution to those emi ssions may be insignificant. In that case, the federal Transportation Conformity rule allows such pollutant/precursors to be exempt from conformity analysis under certain circumstances.

40CFR93.109(k) Areas with insignificant motor vehicle emissions. Notwithstanding the other paragraphs in th is section, an area is not required to satisfy a regional emissions analysis for §93.118 and/or §93.119 for a given pollutant/precursor and NAAQS, if EPA finds through the adequacy or approval process that a SIP demonstrates that regional motor vehicle emissions are an insignificant contributor to th e air quality problem for th at pollutant/precursor and NAAQS. The SIP would have to demonstr ate that it would be unreasonable to expect that such an area would e xperience enough motor vehicle emissions growth in that pollutant/precursor for a NAAQS violation to occur. Such a finding would be based on a number of factors, in cluding the percentage of motor vehicle emissions in the context of the total SIP inventory, the current state of air quality as determined by monitoring data for that NAAQS, the absence of SIP motor vehicle control measures, and historical trends and future projections of the growth of motor vehicle emissions.. . (emphasis added)The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 76 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 For the reasons outlined below, the KYDAQ is he rein making a finding th at regional highway emissions of PM 2.5 , NOx and SO 2 are insignificant contributors to the nonattainment problem for the Huntington-Ashland area. Th e finding will become final if EPA concurs and approves this SIP. First, the regional highway pollutant/precu rsor emissions constitute a relatively small fraction of the overall emissions as shown in the tables below.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 77 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Table 8.2-3 Huntington-Ashland 2002 and 2009 NOx Emissions Inventories (tons per year)

NOx 2002 NOx 2009

Point Area Mobile Nonroad Tota l Point Area Mobile Nonroad Total

KENTUCKY

Boyd 7,045.88 40.00 1,213.00 3,319.05 11,617.93 7,281 46 774 3,107 11,208

Lawrence 17,129.00 87.00 785.00 726.43 18,727.43 5,730 93 528 664 7,015

KY Total 24,174.88 127.00 1,998.00 4,045.48 30,345.36 13,011 139 1,302 3,771 18,223

KY Mobile/KY Portion 6.6% 7.1%

KY Mobile/Entire Nonattainment 1.0% 1.8%

WEST VIRGINIA

Cabell 246.54 716.32 2,987.76 1,957.64 5,908.26 250 737 1633 1849 4469

Mason 26,815.10 349.19 701.14 1,544.77 29,410.20 15238 377 439 1454 17507

Wayne 3,313.09 174.29 1,089.34 3,049.67 7,626.39 2683 180 581 2962 6406

WV Total 30,374.73 1,239.79 4,778.24 6,552.08 42,944.84 18170 1294 2653 6265 28381

OHIO

Adams 54,917.00 112.00 917.00 494.00 56,440.00 7393 123 544 458 8518

Gallia 68,963.00 112.00 864. 00 538.00 70,477.00 9437 125 514 469 10545

Lawrence 0.00 216.00 2,336.00 1,037.00 3,589.00 180 241 1352 846 2619

Scioto 755.00 220.00 1,991.00 1,706.00 4,672.00 497 242 1177 1302 3218

OH Total 124,635.00 660.00 6,108.00 3,775.00 135,178.00 17507 731 3587 3075 24900

Total Emissions 179,184.61 2,026.79 12,884.24 14,372.56 208,468.20 48,688.40 2,163.65 7,541.65 13,110.60 71,504.30The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 78 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Table 8.2-4 Huntington-Ashland 2002 and 2009 SOx Emissions Inventories (tons per year)

SOx 2002 SOx 2009

Point Area Mobile Nonroad Total Point Area Mobile Nonroad Total

KENTUCKY

Boyd 9,711 542 54 482 10,789 10,432.00 578 6 380 11,396

Lawrence 48,874 96 30 85 49,085 47,739.00 102 4 52 47,897

KY Total 58,585 638 84 567 59,874 58,171.00 680 10 432 59,293

KY Mobile/KY Portion 0.1% 0.02%

KY Mobile/Entire Nonattainment 0.0% 0.0%

WEST VIRGINIA

Cabell 124 1420 122 112 1778 123 1528 13 19 1682

Mason 85418 119 32 83 85652 56691 122 4 14 56830

Wayne 288 479 48 162 977 277 517 5 34 832

WV Total 85830 2018 203 356 88407 57091 2167 21 66 59345

OHIO

Adams 137,241 43 44 45 137373 22422 55 4 8 22489

Gallia 106,286 37 42 45 106410 21807 50 4 8 21869

Lawrence 0 70 112 86 268 0 94 11 15 120

Scioto 25 77 96 137 335 918 108 9 25 1060

OH Total 243552 227 294 313 244386 45147 307 28 56 45538

Total Emissions 387966.64 2883 580.98 1236.41 392666.91 160,408.62 3,153.50 59.25 554.36 164,175.72The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 79 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008

Table 8.2-5 Huntington-Ashland 2002 and 2009 PM Emissions Inventories (tons per year)

PM 2002 PM 2009

Point Area Mobile Nonroad Total Point Area Mobile Nonroad Total

KENTUCKY

Boyd 1,256 712 21 131 2,120 1,255 748 15 121 2,139

Lawrence 335 216 14 30 595 413 219 10 28 670

KY Total 1,591 928 35 161 2,715 1,668 967 25 149 2,809

KY Mobile/KY Anthro 1.3% 0.9%

KY Mobile/Entire Non 0.4% 0.2%

WEST VIRGINIA

Cabell 319 865 48 82 1315 339 857 31 74 1301

Mason 237 391 12 70 710 287 380 9 60 735

Wayne 50 523 18 125 717 54 485 11 114 664

WV Total 607 1779 79 277 2743 680 1722 50 248 2701

OHIO

Adams 952 315 17 25 1309 3696 323 12 20 4051

Gallia 670 226 16 22 934 3905 230 11 19 4165

Lawrence 0 163 38 36 237 2 165 26 29 222

Scioto 30 337 36 71 474 92 339 24 60 515

OH Total 1652 1041 107 154 2954 7695 1057 73 128 8953

Total Emissions 3849.86 3748.46 221.06 592.19 8411.57 10,043.39 3,746.17 148.38 525.00 14,462.94The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 80 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 From the above, it can be readily determined that the maximum highway contribution to emissions of NOx is less than eight percent (8%) in the attainment year 2009. The highway contribution to direct PM is le ss than one percent (1%) and SO 2 is two one-hundredths of one percent (0.02%). Therefore, the KYDAQ has dete rmined that the regional highway emissions contribution as a percent of the to tal SIP inventory is insignificant.

Second, the current air quality (CY 2007) is represented by a design value of 14.7 μ g/m 3 . This value is slightly higher than the 14.3 μ g/m 3 design value upon which the nonattainment designation is based. The graph below shows the level of PM 2.5 concentrations from the year 2001 to date. The values dropped from 15.5 μ g/m 3 in 2002 to 14.9 and 14.3 in 2003 and 2004, respectively. This may be attributed to an overall decrease in sulfates from SO 2 reductions mandated by the Acid Rain Program and preliminar y implementation of controls from the Clean Air Interstate Rule. The design value then fluctuated from 14.4 to 14.7 during the 2005-2007 period. This fluctuation is due to the year-to-year variability in PM 2.5 , and it is common to many monitoring sites. Overall, the PM concentrat ions have improved since the beginning of the decade. The area is designated as attainment for all other criteria pollutants.

Given the relatively small cont ribution of the highway emissions to the total SIP inventory, highway emissions are not likely to contribute significantly to the local PM 2.5 mass concentrations. Among other factors, this is largely due to the dominance of sulfates in the overall PM mass.

Boyd PM 2.5 Design Value

14 14.5

15 15.5

00-02 01-03 02-04 03-05 04-06 05-07The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 81 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Third, historically there have been no Huntin gton-Ashland area SIP requirements for motor vehicle control measures. Boyd County and a por tion of Greenup in the area is subject to Transportation Conformity for the 8-hour ozone standard, with SIP-approved, seasonal budgets for NOx and Volatile Organic Compounds (VOC). Further, the entir e nonattainment area currently is subject to Transportation Conformity for the PM 2.5 standard. Emissions analysis has been mandatory for annual highway emissions of direct PM and NOx. However, upon a positive adequacy review or approval of this SIP submittal, no highway emissions analysis will be required under the annual PM 2.5 standard. Highway analysis of seasonal ozone precursors would continue to be mandatory. And, PM 2.5 hot-spot analyses would con tinue to apply for required projects under 40 CFR 93.116 and 93.123(b) of the Transportation Conformity rule.

Fourth, Ashland Area Metropoli tan Planning Organi zation (Ashland MPO) has extensively researched the area local historical trends and growth patterns to develop the LRTP and support transportation conformity evaluations. There is no reason to expect highway motor vehicle emissions growth that would lead to a PM 2.5 NAAQS violation. The Ashland MPO has estimated emissions out, at least, to the calendar year 2030 confirming this . The transportation air quality conformity analysis for the Ashland MPO ar ea took into account all the regional capacity projects, which are scheduled for implementati on through the transportation plan horizon year and the four year TIP. Note that after compar ative runs were made by the Kentucky Division for Air Quality, the interagency consultation team (IA C) determined that there was insignificant difference in emission calculations using monthl y, quarterly, semi-annual, or annual runs. The IAC determined the region would use an annual run using July as the analysis month. The PM conformity tests were performed for cale ndar years 2002, 2009, 2015, 2020, and 2030, for July. For each of those analysis years, vehicle miles traveled (VMT) and Speed were developed by the Federal Functional Class (FC) codes within Bo yd County and Lawrence County for July, The Boyd County data were derived from the regional traffic model assignme nts that are made for each of those years. Lawrence County is not covered by a travel demand model and VMT and Speed were determined by KYTC. Pursuant to the Transportation Conformity interim tests, NOx and direct PM were evaluated.

The Ashland MPO study area includes Boyd and Greenup counties. According to the 2000 census, these counties combine for a population of 86,643, of which 56,446 is in the urbanized area. The study area includes the urban areas of Ashland, Cannonsburg, and Catlettsburg. The transportation plan is a comprehensive examinati on of the future transp ortation needs for Boyd and Greenup counties [KY]. The study area is 506.2 square miles, with Boyd County representing 160.1 square miles, with Gree nup County representing 346.1 square miles.

The PM 2.5 nonattainment area consists of Boyd County of the As hland Area MPO and the donut area which is a portion of Lawrence County.

VMT forecasts for the nonattainment portion of Lawrence County were determined in the following manner: First, using the latest tr affic count data from the Kentucky Highway Information System (HIS), VMT was determined for the specific roadways in the designated portion of Lawrence County, Kentucky - U.S. cen sus 2000 block group id entifier number 21- 127-9901-6. This VMT was summarized by FC codes. (Local mileage and VMT were calculated from the KYTC Highway Information System (HIS) data base.) Future years VMTThe Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 82 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 were estimated by using the Lawrence County proj ected VMT annual growth rate (taken from KYTC’s County Level VMT forecasts).

VMT forecasts for Boyd County were determin ed in the following manner: VMT were determined for all analysis years using the region al travel demand model detailed in the report by The Corradino Group, “Ashland Travel Model”, D ecember 2002. This travel demand model was developed using TransCAD, a Geographic Informa tion System (GIS)-based model package. The traffic analysis zone structure is described in detail in the model documentation. The model as written produced output for 2025, 2020, and 2030. Socioeconomic data for 2009 and 2015 were added to the travel demand model and the mode l was run to determine adjusted VMT for 2009 and 2015.

The model is calibrated to a 2000 ba se year, and the socioeconomic da ta and trip tables used in the travel demand model were developed using the latest planning and land-use assumptions. These assumptions include land-use, population, housing, and employment data derived from the Ashland Municipal Planning Co mmission, the Cabinet for Economic Development, the FIVCO Area Development District, and the Kentucky State Data Center.

Model output included VMT by roadway functiona l classes. The travel demand model VMT output was then reconciled to 2000 HPMS data because the original ca libration of the travel demand model was performed against 2000 HPMS data. The four major model development tasks are listed as follows:

1. Developing Highway Network Syst em and Related Attributes.

2. Developing Traffic Analysis Zone [T AZ] System and Related Attributes.

3. Deriving Internal-Internal, External-Inte rnal, and External-External Trips.

4. Model Calibration and Validation.

The output by the regional travel demand mode l was input to the MOBILE6.2 emissions model for developing the roadway class-specific emissi on factors for the base year. These emissions factors were combined with the HPMS-adjuste d VMT estimates to compute on-road emissions for each roadway class. The resulting emissions estimates were then summed to compute total regional emissions from on-road motor vehicles.

For each future year of interest (i.e., analysis yea r), the regional travel model must first be used to develop roadway-class specific VMT estimates. These estimates are then compared to the base year VMT estimates output by the travel model, to develop roadway-class specific growth rates. The base year HPMS-adjusted VMT estimates above are then multiplied by these growth rates to compute future year HPMS-adjusted VMT estimates.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 83 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Similar to the base year computation methodol ogy, congested speeds out put by the model were input to MOBILE to develop roadway class-sp ecific emissions factors. The HPMS-adjusted VMT estimates for each roadway class were then multiplied by the emissions factors output by MOBILE, and the resulting emissions estimates summed across all roadway classes to compute total regional on-road emissions. The process was followed for each selected analysis year. The above example provides one approach to comp uting HPMS-adjusted VMT estimates for each analysis year and scenario. There are, however, a number of other variations that could be pursued depending on the robustness of the availa ble data and desired level of analysis.

Table 8.2-6 shows the Daily VMT (DVMT) for the model area for the years 2002, 2009, 2015, 2020, and 2030. Appendix A [of the report] lists the VM T by facility type fo r all the above-listed years.

Table 8.2-6.

County Name Year Daily VMT (DVMT)

Boyd 2002 1,375,000 Lawrence (partial) 2002 96,111 2002 Total 1,471,111

Boyd 2009 1,598,133 Lawrence (partial) 2009 108,730 2009 Total 1,706,863

Boyd 2015 1,606,467 Lawrence (partial) 2015 126,013 2015 Total 1,732,480

Boyd 2020 1,918,593 Lawrence (partial) 2020 136,851 2020 Total 2,055,444

Boyd 2030 2,213,597 Lawrence (partial) 2030 157,974 2030 Total 2,371,571

In June 2005, EPA clarified how transportation conformity was determined in non-contiguous PM 2.5 non-attainment areas. EPA’s cl arification was as follows:The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 84 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 Noncontiguous PM 2.5 nonattainment areas (NNAs) are ar eas that contain “satellite portions” that are not contiguous with the main portion of the nonattainment area. These satellite areas are designated as part of the overall nonattainment area because they have a point source which c ontributes, via transport, to the air quality problems of the main geographic portion of the PM 2.5 nonattainment area. We believe that the satellite portions of NNAs best fit the definition of a donut area for transportation conformity purposes . Section 93.101 of the conformity rule defines “donut areas“ as “geographic area s outside a metropolitan planning area boundary, but inside the boundary of a nona ttainment or maintenance area that contains any part of a metropolitan area(s). These areas are not isolated rural nonattainment and maintenance areas.

The conformity guidance for “donut” areas was entitled Companion Guidance for the July 1, 2004, Final Transportation Conformity Rule: Conformity Implementa tion in Multi-jurisdictional Nonattainment and Maintenance Areas fo r Existing and New Air Quality Standards . The partial county of Lawrence is thus considered a “donut area” for planning purposes. As part of the PM 2.5 Air Quality analysis, a small portion of Lawr ence County [KY] was added to the Boyd County area as a “donut”. In this “donut” area there are roads with different cl assifications. The KYTC provided the Ashland Area MPO w ith the VMT on these roads [i n the “donut area”] for the analysis years listed above as described in the methodology above.

The donut area emissions were determined base d on the Functional Class VMT and associated emission factors as dete rmined from MOBILE 6.2.

The socio-economic factors were accounted for in Boyd County in the travel demand model as described above. Forecasted population growth for the nonattainment portion of Lawrence was accounted for based on Kentucky Data Center (KDC) census forecasts.

Input files were developed for modeling mobile emissions with the Mobile6.2 software by using the VMT split by functional class. The assumptions related to the deri vation of model inputs were developed as part of an interagency cons ultation process involving the following agencies:

• KYOVA Interstate Planning Commission.

• Ashland Area MPO.

• West Virginia Departme nt of Transportation.

• West Virginia Division of Air Quality

• Kentucky Transportation Cabinet

• Kentucky Division for Air Quality

• Ohio Department of Transportation

• Ohio EPA

• Federal Highway Administration

• Federal Transit Authority

• U.S. EPA.The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 85 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 The results of the Mobile 6.2 analysis yields mob ile emission rates that can be used along with the DVMT by functional class of roadway to derive estimates of total mobile source emissions for nitrogen oxides (NO x ) and PM 2.5 . The conformity results are represented in Table 8.2-7. The conformity rule required the region’s LRTP to conform to the SIP be fore FHWA approves the funding of future projects. The conformity evalua tion is determined by th e processes outlined in the conformity rule The Ashland Area PM 2.5 non-attainment area, in co njunction with the entire Huntington-Ashland PM 2.5 non-attainment area, has demonstrated conformity with the PM 2.5 transportation conformity rule using th e base year interi m emissions test.

Table 8.2-7.

Ashland PM 2.5 Area Alone (Boyd and partial Lawrence)

Year NOx (tpd) PM2.5 (tpd) NOx (Annual) % Change from base PM2.5 (Annual) % Change from base

2002 4.066 0.083 1,484.09 na 30.295 na

2009 2.609 0.057 952.29 -35.83% 20.805 -31.33%

2015 1.398 0.037 510.27 -65.62% 13.505 -55.42%

2020 1.142 0.038 416.83 -71.91% 13.870 -54.22%

2030 0.905 0.040 330.33 -77.74% 14.600 -51.81%

Entire Huntington-Ashland PM 2.5 Area

Year NOx (tpd) PM2.5 (tpd) NOx (Annual) % Change from base PM2.5 (Annual) % Change from base

2002 5.456 1.753 1,991.44 na 639.845 na

2009 3.929 1.057 1,434.09 -27.99% 385.805 -39.70%

2015 2.228 0.697 813.22 -59.16% 254.405 -60.24%

2020 1.512 0.448 551.88 -72.29% 163.520 -74.44%

2030 1.215 0.420 443.48 -77.73% 153.300 -76.04%The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 86 and Louisville, KY-IN, PM 2.5 Final Kentucky Attainment Demonstration November 2008 The forecasts clearly show that, despite any antic ipated growth in the area, significant decreases in highway emissions are expected for all anal ysis years, for both NOx and direct PM. The interim conformity tests do not require evaluation of SO 2 . However, federal heavy duty diesel engine standards and low-sulfur fuel requirements are also expected to yield substantial emission decreases commensurate with those shown above. Therefore, the Kent ucky DAQ reiterates its conclusion that highway emissions of PM 2.5 , NOx, and SO 2 are insignificant contributors to the nonattainment problem for the Ashland area and are therefore exempt from transportation conformity evaluation under 40CFR93.109(k).



### 9.0 REFERENCES Frank, N. H. Retained Nitrate, Hydrated Sulfates, a nd Carbonaceous Mass in Federal Reference Method Fine Particulate Matter for Six Eastern U.S. Cities. J. Air & Waste Manage. Assoc . 2006 56:500–511.

Tesche, T.W., et al. Operational Evaluation of the MM5 Meteorological Model Over the Continental United States: Protocol for Annual and Episodic Evaluation. Office of Air Quality Planning and Standards. AG-TS-90/158. July 2002.

USEPA Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze. EPA -454/B-07-002. April 2007.