Steven L. Beshear 

Governor 

Ms. Heather McTeer Toney 

Regional Administrator 

US EPA, Region 4 

ENERGY AND ENVIRONMENT CABINET 

OFFICE OF THE SECRETARY 

500 Mero Street 

12111 Floor, Capital Plaza Tower 

Frankfort, Kentucky 40601 

Phone: (502) 564-3350 

Fax: (502) 564-7484 

http://eec.ky.gov 

October 29, 2014 

Sam Nunn Atlanta Federal Center 

61 Forsyth St, SW 

Atlanta, GA 30303-8960 

RE: Kentucky response to 120-day letter for 2012 PMz.s designations 

Dear Ms. McTeer Toney: 

Leonard K. Peters 

Secretary 

Thank you for your letter dated August 19, 2014, notifying Governor Beshear of the 

Administrator's intention to modify the Commonwealth's recommendations of air 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) of the Clean Air Act, the purpose of this letter is to 

inform the Administrator that the proposed 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 a portion of Bullitt County in the Louisville area 

and for portions of Boone, 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 a pending 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). If EPA is willing to use the 

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Ms. Heather McTeer Toney 

Page No.2 

October 29, 2014 

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 pending March 5, 2012 redesignation request. 

In responding to your request for additional information related to EPA's modification of 

Kentucky's recommendation, the Louisville Metro Air Pollution Control District (LMAPCD) also 

performed a review of the 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 that total NH3 

decreased by 72 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 occur in the area as a result of two significant 

emission reduction projects in progress at Louisville Gas & Electric's (LG&E) Mill Creek and Cane 

Run facilities. LG&E is 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 of 299.2 tons/year of PMz.s and 14,208.6 tons/year in S02 are expected when the 

project is completed in 2016. Further reductions of 52 tons/year of PMz.s. 10,572 tons/year of SOz. and 

4,823.2 tons/year ofNOx are expected by mid-2015 from the conversion of the Cane Run facility from 

three coal-fired boilers to a natural gas-fired combustion turbine plant. 

In light of these significant emissions reductions, along with the downward trend of ambient air 

monitor results for PMz.s concentrations, the Commonwealth strongly recommends EPA to classify the 

Louisville area as attainment/unclassifiable once Indiana certifies and submits 2014 ambient air 

monitoring data demonstrating the area achieves the NAAQS. 

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) should be exempted from comparison to the annual standard due to the 

close proximity of several facilities. Table 5, NEI 2011 Point Source Emissions (tons/year) in the 

technical support document provides a column that indicates the distance to the monitor of the listed 

sources. For Butler County, Ohio, the distances from sources to the monitor range from 15 to 23 miles. 

However, it appears that there are some potential particulate matter sources at distances much closer to 

the ambient monitor: 

• a load out from Martin Marietta Aggregates is only approximately 0.19 miles; 

~ the conveyor load 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 McTeer Toney 

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 of Kentucky emissions. 

For the ambient air monitor station identified by 39-061-0042, closer inspection identifies a large 

rail switch yard within approximately 0.69 miles of the violating monitor. In addition, a large 

confluence of interstates and local primary arteries are within approximately 1.61 miles of the violating 

monitor. And lastly, this violating monitor is within approximately 0.42 miles of the river and by barge 

traffic. 

Additionally, monitor 39-061-0014 is located within approximately 0.03 miles (158 feet) of a rail 

line. It is within approximately 0.18 miles of significant roadways, and it is within approximately 0.09 

miles (475 feet) of a manufacturing plant. 

After reviewing the ambient air monitor results spatially from South to North (Kentucky to 

Ohio), the pattern of monitoring values demonstrate attainment, nonattainment, and then attainment. For 

this reason and the reasons 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 

of Kentucky stationary sources. 

Factor 2: Emissions and emissions-related data 

Please note the percentage of emissions that the TSD attributes to Kentucky for 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 of the Kentucky County's contribution is less than 10% of the total 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 of 3 violating monitors, but also upwind of 7 

attaining monitors. Disregarding the Butler County, Ohio monitor due to the proximity of several 

significant sources of particulate matter, it does not seem likely that emissions from Kentucky randomly 

impact certain monitors while not impacting other monitors. If Kentucky were a significant cause for 

the violations, one would expect that all of the monitors in the area would show nonattainment. 

Factor 4: Geography/topography 

As stated previously under Factor 1, each monitor in violation of the PM2.s standard has 

significant sources located much closer than the northern portions of Kenton and Campbell Counties, 

Kentucky. 
Ms. Heather McTeer Toney 

Page No.4 

October 29, 2014 

Factor 5: Jurisdictional boundaries. Kentucky has no comment with regard to Factor 5. 

Relating to the summary of the letter, Kentucky notes that EPA indicates that Kenton County has 

5% of the vehicle miles travelled (vmt) for the entire proposed nonattainment area, Boone County 4%, 

and Campbell County 3%. With all of the information provided above, and including the fact that the 

monitor located in Campbell County meets the standard, Kentucky finds that the portions of Boone, 

Campbell, and Kenton counties that EPA proposes to designate as non attainment should be designated 

attainment/unclassifiable for the 2012 PMz.s standard. 

Kentucky appreciates the opportunity to provide additional documentation regarding the 

proposed nonattainment boundaries contained in your letter. Your prompt attention to this letter is 

appreciated. If you have any questions or need additional information, please contact me at (502) 564-

3350, or have your staff contact Mr. Sean Alteri, Director of the Kentucky Division for Air Quality, at 

(502) 564-3999. 

Sincerely yours, 

c: Beverly Banister/R. Scott Davis