Steven L. Beshear Governor

Ms. Heather McTeerToney Regional Administrator US EPA, Region 4 ENERGY AND ENVIRONMENT CABINET OFFICE OFTHE SECRETARY 500 Mero Street 12111 Floor, CapitalPlazaTower

Frankfort, Kentucky 40601 Phone: (502) 564-3350

Fax: (502) 564-7484

http://eec.ky.gov October 29, 2014

SamNunn AtlantaFederal Center 61 Forsyth St, SW Atlanta, GA 30303-8960 RE: Kentucky response to 120-dayletter for 2012 PMz.s designations DearMs. McTeerToney: Leonard K. Peters Secretary

Thank you for your letter dated August 19, 2014, notifying Governor Beshear ofthe Administrator's intention to modify the Commonwealth's recommendations ofair quality designations for the 2012 revised primary annual fine particle (PM2.5) National Ambient Air Quality Standard (NAAQS). As afforded in Section 107(d)(l)(B)(ii) ofthe Clean Air Act, thepurpose ofthis letter is to informthe Administrator that theproposed modifications to Kentucky's recommendations are inappropriate. The Commonwealth disagrees with EPA's intention to modify the recommended area designations to nonattainment for Jefferson County and aportion ofBullitt County in the Louisville area and for portions ofBoone, Campbell, and Kenton Counties in the Northern Kentucky area. Louisville Area With regard to the Louisville area, I understand and appreciate EPA's concerns and approach related to the data quality issues associated with the ambient air monitoring data collected in Jefferson County, Kentucky. However, I want to express concern with the inconsistent approach EPA is applying when evaluating PM2.5 ambient air quality data collected in the Louisville area. Currently, EPA is reviewing apending redesignation request for the area that was submitted on March 5, 2012. In on-going conversations on the matter, EPA indicates that it is unable to finalize the redesignation to attainment status for the 1997 PM2.5 standard (15**~g/m )**  due to the data quality issues related to ambient air monitoring data collected in Jefferson County, Kentucky. However, in this modification to Kentucky's recommendation, EPA intends to base its nonattainment designation on the design value monitor located in Clark County, Indiana (18-019-0006). IfEPA is willing to use the

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Clark County, Indiana ambient air monitoring data for the PM2.5 nonattainment designation for the 2012 standard, then EPA should also use the data to finalize the attainment designation for the 1997 standard. 

### It should be noted that the Clark County monitor has served as the design value monitor for the Louisville area since 2007. As such, we request that EPA use the Clark County monitor design value in taking final action on the pendingMarch 5, 2012 redesignation request. In responding to your request for additional information related to EPA's modification of Kentucky's recommendation, theLouisville Metro Air Pollution ControlDistrict (LMAPCD) also performed a review ofthe data provided in the Technical Support Document (TSD) by comparing the emissions in the 2011 NEI with the emissions in the 2012 NEI. This review showed thattotal NH3 decreased by72 tons/year, total S02 decreased by 1,322 tons/year, and total NOx decreased by 3,491 tons/year. Additional reductions in PMz.s. 

### SOz. and NOx will occurinthe area as aresult oftwo significant emission reduction projects in progress at Louisville Gas & Electric's (LG&E) Mill Creek and Cane Run facilities. LG&Eis modifying the control devices for four electric generation units (EGUs) at its Mill Creek facility to include particulate matter control systems and flue gas desulfurization for each of the EGUs. Reductions of299.2 tons/year ofPMz.s and 14,208.6 tons/year in S02are expected when the project is completed in 2016. Furtherreductions of52 tons/year ofPMz.s. 10,572 tons/year of

### SOz. and 4,823.2 tons/year ofNOx are expectedby mid-2015 from the conversion ofthe Cane Run facility from three coal-firedboilers to a natural gas-fired combustion turbine plant. Inlight ofthese significant emissions reductions, along with the downward trend ofambient air monitor results for PMz.s concentrations, the Commonwealth stronglyrecommends EPA to classify the Louisville area as attainment/unclassifiable once Indiana certifies and submits 2014 ambient air monitoring data demonstrating the area achieves theNAAQS. Northern Kentucky Area To address the Cincinnati-Hamilton, Ohio-Kentucky area, Kentucky reviewed EPA's five factor analysis. Factor 1: Air Quality Data Kentucky acknowledges and agrees with EPA that the ambient air monitoring site in Butler County, Ohio (39-017-0020) shouldbe exempted from comparison to the annual standard due to the close proximity of several facilities. Table 5, NEI 2011 Point SourceEmissions (tons/year) in the technical support document provides a column that indicates the distance to the monitor ofthe listed sources. For Butler County, Ohio, the distances from sources to the monitorrange from 15 to 23 miles. However, it appears that there are somepotential particulate matter sources at distances much closer to the ambient monitor:

• a load outfrom Martin Marietta Aggregates is only approximately 0.19 miles;**~** the conveyorload out for Martin Marietta Aggregates is approximately 0.3 miles; • DMK Sandblasting Services is approximately 0.67 miles; and • the AK Steel Blast Furnace is approximately 1.05 miles from the violating monitor.Ms. Heather McTeerToney Page No.3 October 29, 2014

With two monitors to the northwest and northeast demonstrating compliance, Kentucky finds that the localized emissions from the surrounding stationary sources are contributing to the violation at this monitor and not from contribution ofKentucky emissions. Forthe ambient air monitor station identified by 39-061-0042, closerinspection identifies a large rail switch yard within approximately 0.69 miles ofthe violating monitor. In addition, a large confluence ofinterstates and local primary arteries are within approximately 1.61 miles ofthe violating monitor. And lastly, this violating monitor is within approximately 0.42 miles ofthe river and bybarge traffic. Additionally, monitor 39-061-0014 is located within approximately0.03 miles (158 feet) ofa rail line. Itis within approximately 0.18 miles of significantroadways, and it is within approximately0.09 miles (475 feet) ofa manufacturing plant. After reviewing the ambient air monitorresults spatially from South to North (Kentucky to Ohio), the pattern ofmonitoring values demonstrate attainment, nonattainment, and then attainment. For this reason and thereasons cited above, Kentucky finds that it is the localized emissions from the nearby stationary sources that are contributing to the violating monitor and not from any significant contribution ofKentucky stationary sources. Factor 2: Emissions and emissions-related data Please note the percentage ofemissions that the TSD attributes to Kentuckyfor the nonattainment area:



### • NOx =Boone: 9%, Campbell: 3%, Kenton: 5%; 

### • PM=Boone: 4%, Campbell: 2%, Kenton: 3%; 

### • POM = Boone: 8%, Campbell: 4%, Kenton: 6%; and • EC =Boone: 8%, Campbell: 3%, Kenton: 6%. Each ofthe Kentucky County's contribution is less than 10% ofthetotal in the nonattainment area. Kentucky determines that emissions from Kentucky are negligible in causing nonattainment at the monitors in Ohio. Factor 3: Meteorology Under this factor, EPA states that the wind direction is predominantly from the south to southwesterly. As shown in the TSD Kentucky is upwind of3 violating monitors, but also upwind of7 attaining monitors. Disregarding the Butler County, Ohio monitor due to the proximity ofseveral significant sources ofparticulate matter, it does not seemlikely that emissions from Kentucky randomly impact certain monitors while not impacting other monitors. IfKentucky were a significant cause for the violations, one would expect that all ofthe monitors in the area would show nonattainment. Factor4: Geography/topography As stated previously under Factor 1, each monitor in violation ofthe PM2.s standard has significant sources located much closer than the northern portions ofKenton and Campbell Counties, Kentucky.Ms. HeatherMcTeerToney Page No.4 October 29, 2014

Factor 5: Jurisdictional boundaries. Kentucky has no comment with regard to Factor 5. Relating to the summary ofthe letter, Kentucky notes thatEPAindicates that Kenton Countyhas 5% ofthe vehicle miles travelled (vmt) for the entire proposed nonattainment area, Boone County4%, and Campbell County 3%. With all ofthe information provided above, and including the fact that the monitor located in Campbell County meets the standard, Kentucky finds that the portions ofBoone, Campbell, and Kenton counties that EPAproposes to designate as nonattainment should be designated attainment/unclassifiablefor the 2012 PMz.s standard. Kentucky appreciates the opportunity to provide additional documentation regarding the proposed nonattainmentboundaries contained in your letter. Your prompt attention to this letteris appreciated. Ifyou have any questions or need additional information, please contact me at (502) 564- 3350, orhave your staffcontact Mr. Sean Alteri, Director ofthe Kentucky Division for Air Quality, at (502) 564-3999. Sincerelyyours,

c: Beverly Banister/R. ScottDavis