# REDESIGNATION REQUEST AND

MAINTENANCE PLAN FOR

THE OHIO PORTION OF THE

CAMPBELL

- CLERMONT COUNTIES,

KY

- OH 1

- HOUR SO 2 

# NONATTAINMENT AREA

Partial Clermont County, Ohio

Prepared by: Ohio Environmental Protection Agency

Division of Air Pollution Co ntrol

August 2015Th is page left intentionally blankTABLE OF CONTENTS

CHAPTER ONE: Introduction

................................ ................................ ......................... 1

History

................................ ................................ ................................ ......................... 1 Geographical Description and Background

................................ ................................ . 2 Status of Air Quality

................................ ................................ ................................ ..... 2

CHAPTER TWO: Requirements for Redesignation

................................ ......................... 3

1. Attainment of the standard (CAA Section 107(d)(3)(E)(i))

................................ .... 3

2. Approved SIP for the area under CAA Section 110(k) (CAA Section 107(d)(3)(E)(ii))

................................ ................................ ................................ ..... 4

3. Permanent and enforceable improvement in air quality (CAA Section 107(d)(3)(E)(iii))

................................ ................................ ................................ .... 4

4. Maintenance plans (CAA Section 107(d)(3)(E)(iv))

................................ .............. 4

5. Section 110 and Part D requirements (CAA Section 107(d)(3)(E)(v))

.................. 5

a. Section 110(a) requirements

................................ ................................ ........... 5

b. Part D requirements

................................ ................................ ........................ 6

i. Section 172(c) r equirements

................................ ................................ ........... 6

ii. Conformity

................................ ................................ ................................ . 7

CHAPTER THREE: SO 2 Monitoring

................................ ................................ ................ 9

Requirement 1 of 4: A demonstration that the NAAQS for 1

- hour SO 2 , as published in 40 CFR 50.17, has been attained.

................................ ................................ ............... 9 Requirement 2 of 4: Ambient monitoring da ta quality assured in accordance with 40 CFR 58.10, recorded in the AQS database, and available for public view.

................................ ................................ ................................ ................ 10 Requ irement 3 of 4: A commitment that once redesignated, the state will continue to operate an appropriate monitoring network to verify the

maintenance of the attainment status.

................................ ................................ ....... 11 Requirement 4 of 4: Supplemental U.S. EPA

- approved air quality modeling to show

monitors are located in the area of maximum concentration.

................................ .... 11

CHAPTER FOUR: Emission Inventory

................................ ................................ .......... 16

Requirement 1 of 4: A comprehensive emission inventory of SO 2 completed for the base year and a projection of the emission inventory to a year at least 10 years following redesignation.

................................ ................................ ...... 16 Requirement 2 of 4: A demonstration tha t the projected level of emissions is sufficient

to maintain the SO 2 standard.

................................ ................................ .................... 18 Requirement 3 of 4: A demonstration that improvement in air quality between th e year violations occurred and the year attainment was achieved is based on permanent and enforceable emission reductions and not on temporary adverse economic conditions or unusually favorable meteorology.

................................ ................................ .............................. 20 Requirement 4 of 4: Provisions for future annual updates of the inventory to enabletracking of the emission levels, including an annual emission

statement from major sources.

................................ ................................ .................. 23 Requirement 1 of 6: Section 17 2(c)(1) of the 1990 Clean Air Act Amendments requires states with nonattainment areas to implement RACM

and RACT.

................................ ................................ ................................ ................. 24 Requirement 2 of 6: Section 172(c)(2) of the 1990 CAA Amendments requires

attainment demonstration SIPs for nonattainment areas to show

RFP.

................................ ................................ ................................ .......................... 25 Requirement 3 of 6: Section 172(c)(3) requires states to submit a comprehensive inventory of actual emissions.

................................ ................................ .................... 25

R equirement 4 of 6: Evidence that control measures required in past SO 2 SIP revisions have been fully implemented.

................................ ................................ ..... 26 Requirement 5 of 6: Acceptab le provisions to provide for new source review.

......... 27 Requirement 6 of 6: Assure that all existing control measures will remain in effect after redesignati on unless the state demonstrates through modeling that the standard can be maintained without one or

more control measures.

................................ ................................ ............................. 28

CHAPTER SIX: Contingency Measures

................................ ................................ ........ 28

Requirement 1 of 4: A commitment to submit a revised plan eight years after redesignation.

................................ ................................ ................................ ............ 29 Requirement 2 of 4: A commitment to expeditiously enact and implement additional contingency control measures in response to exceeding specified predetermined levels (triggers) or in the event that

future violations of the ambient standard occur.

................................ ........................ 29 Requireme nt 3 of 4: A list of potential contingency measures that would be implemented in such an event.

................................ ................................ .................. 30 Requirement 4 of 4: A list of SO 2 , sources potentially subject to future additional control requirements.

................................ ................................ ................................ . 32

CHAPTER SEVEN: Public Participation

................................ ................................ ........ 33

CHAPTER EIGHT: Conclusions

................................ ................................ .................... 34FIGURES

Figure 1 Map of the Campbell

- Clermont KY

- OH nonattainment area and monitor

location

................................ ................................ ................................ ............... 9 Figure 2 2012 to 2014 Walter C. Beckjord and William H. Zimmer h ourly e missio ns

with h ourly SO 2 m onitoring d ata

.... ................................ ......................... 1 3
Figure 3 2014 Walter C. Beckjord and William H. Zimmer hourly emissions with

hourly SO 2 monitoring data

................................ ................................ .. ....1 4
Figure 4 Walter C. Beckjord SO 2 emissions by unit and entire facility

................ ... 21
Figure 5 Walter C. Beckjord SO 2 emissions for units B005 and B006 in 2014

.... ... 22

TABLES

Table 1 Monitoring data for the Campbell

- Clermont KY

- OH area for 2012

–

2014....

................................ ................................ ................................ ..... 10

Table 2 Ohio portion SO 2 emission inventory totals for base year 2011, attainment

2014, and projected 2020 and 2027 (tp y)

................................ ............ ....1 7

Table 3 Kentucky portion SO 2 emission inventory totals for base year 2011,

attainment 2014, and projected 2020 and 2027 (tpy)

.......................... ....1 8

Table 4 Combined Campbell

- Clermont area SO 2 emission inventory totals for base

tear 2011, attainment 2014, and projec ted 2020 and 2027 (tpy)

......... ....1 8

Table 5 Campbell

- Clermont area comparison of 2014 attainment year and 2020

and 2027 projected emission estimates (tpy)

................................ ....... ....1 9

Table 6 Campbell

- Clermont KY

- OH a rea c omparison of 20 11 base year and 20 14

attainment year EGU reductio ns

................................ .......................... .... 20

Table 7 Ohio’s 2011 base year inventory

................................ ......................... .... 2 6

APPENDICES

A

- 1 Kentucky DAQ Air Quality Data Certification

A

- 2 2012 to 2014 Air Quality Data

B Letter of Notification of Permanent Shutdown of Walter C. Beckjord Facility

C Emissions Summary and Proj ections

D Campbell County, Kentucky SO 2 M onitor 21

- 037

- 3002 2 010

- 2014 E xceedance

A nalysis

E 2011, 2014, 2017, 2020, 2022 and 2027 SO 2 On

- R oad E missions I nventory for Campbell

- Clermont Counties, KY

- OH 1

- hour SO 2 N onattainment A rea
F Background Analysis

G Wa lter C. Beckjord’s SO 2 E missions for 2008 to 2014

H Public Notice and Comment Documents

I Letter of Notification of Permanent Shutdown of Walter C. Beckjord Facility,

Combustion Turbines

J Supplemental Modeling Demonstration, William H. Zimmer Facility

K A nalysis of Monitor Values, Emissions, and Wind Direction Data, January 1,

2012

- February 28, 2015

L Letter of Notification of Permanent Shutdown of the Miami Fort Power Station

Unit 6This page left intentionally blan kCampbell

- Clermont KY

- O H SO 2 Redesignation Request and Maintenance Plan

P a g e | 1 REDESIGNATION REQUEST A ND MAINTENANCE PLAN FOR THE OHIO

PORTION OF THE CAMPBELL

- CLERMONT KY

- OH

1

- HOUR SO 2 NONATTAINMENT AREA

Partial Clermont County , Ohio



### CHAPTER ONE : I ntroduction

History The Clean Air Act (CAA ), as amended

, requires each s tate with areas failing

to meet the 1

- hour sulfur dioxide ( SO 2 ) National Ambient Air Quality Standard (NAAQS) to develop State Implementation Plans (SIPs) to expeditiously

attain and maintain the standard

. T he United States Enviro nmental

Protection Agency (U.S. EPA) promulgated the rev ised NAAQS for SO 2 o n June 2, 20 10. U.S. EPA replaced the 24

- hour and annual standards with a

new short

- term 1

- hour standard of 75 parts per billion (ppb) . The new 1

- hour

SO 2 standard was published on June 22, 2010 ( 75 FR 35520) and became

effective on Au gust 23, 2010

. The standard is based on the three

- year average of the annual 99th percentile of 1

- hour daily maximum

concentrations

.

On August 15, 2013 , U.S. EPA published (7 8 FR 47191 ) the initial SO 2 nonattainment area designations for the 1

- hour SO 2 st andard across the country (effective October 4, 2013 ). Unlike Subpart 2 of the CAA

Amendments of 1990 which defined five ozone nonattainment classifications for the areas that exceed the NAAQS based on the severity of the ozone
levels, SO 2 nonattainment de signations are simply labeled “nonattainment.” The CAA Amendments require states with SO 2 nonattainment areas to submit a plan within eighteen months of the effective date of the designations ( April
4, 2015 ) detailing how the SO 2 standard will be attained by October 4, 2018 (referred to as an “attainment demonstration”) . However, areas that attain before the required date for submitting a plan may be exempt from certain otherwise applicable requirements

.

Section 107(d)(3)(E) of the CAA allows states to req uest nonattainment areas

to be redesignated to attainment provid ed certain criteria are met. The following are the criteria that must be met in order for an area to be redesignated from nonattainment to attainment:

1. A determination that the area has attai ned the SO 2 standard. (CAA Section 107(d)(3)(E)(i))

2. An approved SIP for the area under Section 110(k). (CAA Section 107(d)(3)(E)(ii))

3. A determination that the improvement in air quality is due to permanent and enforceable reductions in emissionsCampbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 2 resulting from implementation of the SIP

, federal

requirements , and other permanent and enforceable

reductions

. (CAA Section 107(d)(3)(E)(iii))

4. A fully approved maintenance plan , including a contingency plan, under Section 175 A. (CAA Section 107(d)(3)(E)(iv))

5. A dete rmination that all Section 110 and Par t D requirements have been met. (CAA Section 107(d)(3)(E)(v))

Each of these criteria is discussed in more detail under Chapter Two with a detailed analysis in subsequent c hapters. T his document is intended to
support Ohio’s request that the Ohio portion of the Campbell

- Clermont KY

OH area be redesignated from nona ttainment to attainment for the 1

- hour

SO 2 s tandard

. This document addresses each of above requirements, and provides additional information to support cont inued compliance with the 1

- hour SO 2 standard.

Geographical Description and Background

The current Campbell

- Clermont KY

- OH nonattainment area is located in

south we stern Ohio and the following area in Campbell County, Kentucky that

lies south and west o f the Ohio River : b eginning at geographic coordinates 38.9735 North Latitude, 84.3017 West Longitude (NAD 1983) on the edge of the Ohio River running southwesterly to KY Highway 1566; thence continuing running southwesterly along KY Highway 1566 to KY High way 9 (AA Highway); thence running north westerly along KY Highway 9 (AA Highway) from Hwy 1566 to Interstate 275; thence running northeasterly along Interstate 275 to Highway 2345 (John’s Hill Road), Hwy 2345 to US

– 27, US

– 27 to I

– 275, I

– 275 to the Ohio Ri ver; thence running southeasterly along the Ohio River from Interstate 275 to geographic coordinates 38.9735 North
Latitude, 84.3017 West Longitude (NAD 1983)

. This area is shown in Figure

1 under Chapter Three.

The Campbell

- Clermont KY

- OH a rea has no t previously been subject to nonattainment area rulemakings for the SO 2 NAAQS

.

Status of Air Quality

SO 2 complete quality

- assured ambient air quality monitoring data for the three (3) years, 20 12 through 201 4 , demonstrate that the air quality has m et th e 1

- hour SO 2 standard in this nonattainment area . (See Chapter Three) The NAAQS attainment, accompanied by decreases in emission lev els discussed in Chapter Four, supports a redesignation to attainment for the Campbell

Clermont KY

- OH area based on the requ irements in Section 107(d)(3)(E) of

the CAA as amended

.Campbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 3 

### C HAPTER TWO : Requirements for Redesignation

U.S. EPA has published detailed guidance in a document entitled Procedures for Processing Requests to Redesignate Areas to Attainment (redesignation

g uid ance ), issued September 4, 1992 , to Regional Air Directors. U.S. EPA has also published guidance specific to SO 2 in a document entitled Guidance

for 1

- Hour SO 2 Nonattainment Area SIP Submissions (SO 2 nonattainment area SIP guidance), issued April 23, 2014 , to Regional Air Division Directors.

Th is redesignation request and maintenance plan is based on the redesignation g uidance and SO 2 nonattainment area SIP guidance

, supplemented with additional guidance re ceived from U.S. EPA Region 4 and Region 5 staff

.

Below is a summary of each redesignation criterion as it applies to the Campbell

- Clermont KY

- OH area.

1. Attainment of the standard (CAA Section 107(d)(3)(E)(i))

There are two components involve d in making this demonstration.

T he first component relie s on ambient air quality data. For SO 2 , all available monitoring data in the area should indicate the standard is being met according to 40 CFR 50.17 and 40 CFR Part 50, Appendix T

. Analyses should indicate whether any of the monitors located in the nona ttainment area

are located in the area of maximum concentration

.

Demonstration : Chapter Three discusses this requirement in more detail and provides the demonstration

.

The second component relies upon supplemental U.S. EPA

- approved air quality modeling

. Where a monitor is located in the area of maximum concentration, a determination of attainment may be made based on monitoring data alone without the need for additional air quality modeling. When a nonattainment area has no monitors, or monitors not lo cated in the area of maximum concentration, air quality dispersion modeling is generally

needed to estimate SO 2 concentrations in the area

.

Demonstration : Chapter Three discusses this requirement in more detail (Requirement 4 of 4 ) and provides the demo nstration

.Campbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 4 2. Approved SIP for the area under CAA Section 110(k) (CAA Section 107(d)(3)(E)(ii))

The SIP for the nonattainment would need to be fully approved and satisfy all applicable requirements for the area. U.S. EPA approval of SIP elements and

red esignation requests may occur simultaneously.

Demonstration : Ohio EPA has submitted all required SIP elements for this area in either previous submittals, or as a part of this submittal.

3. Permanent and enforceable improvement in air quality (CAA Sectio n 107(d)(3)(E)(iii))

The state must be able to reasonably attribute the improvement in air quality to emission reductions which are permanent and enforceable. The state should estimate the percent reduction achieved from federal measures as

well as contr ol measures that have been adopted and implemented by the

state.

Demonstration : Chapter Four discusses this requirement in more detail (Requirement 4 of 5) and provides the demonstration

.

4. Maintenance plans (CAA Section 107(d)(3)(E)(iv))

Section 107(d) (3)(E) stipulates that for an area to be redesignated, U.S. EPA must fully approve a maintenance plan that meets the requirements of

Section 175 A. The maintenance plan will constitute a SIP revision and must provide for maintenance of the relevant NAAQS i n the area for at least ten years after redesignation along with a commitment to review the plan. Section 175A further states that the plan shall contain such additional measures, if any, as may be necessary to ensure such maintenance.

In addition, the m aintenance plan shall contain such contingency measures as the Administrator deems necessary to ensure prompt correction of any violation of the NAAQS. At a minimum, the contingency measures must include a requirement that the state will implement all mea sures contained in the nonattainment SIP prior to redesignation.

Demonstration : States seeking approval of a maintenance plan for a nonattainment area should consider the following provisions:

 attainment inventory (Chapter Four contains the discussion an d

demonstration );Campbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 5  maintenance demonstration (Chapter Four contains the discussion and

demonstration );

 monitoring network (Chapter Three contains the discussion and

demonstration );

 verification of continued attainment (in Chapter Four (Requirement 5 of 5) c ontains the discussion and demonstration) ; and

 contingency plan (Chapter Six contains the discussion and

demonstration ).

5. Section 110 and Part D requirements (CAA Section 107(d)(3)(E)(v))

For purposes of redesignation, a state must meet all requirements of Section 110 and Part D that were applicable prior to submittal of the complete redesignation request but not those that com e due after submittal of the redesignation request

.

a. Section 110(a) requirements

Section 110(a) of T itle I of the CAA contains t he general requirements

for a SIP. Section 110(a)(1) generally directs states to submit a SIP that provides for implementation, maintenance, and enforcement of the air quality standards to the U.S. EPA after reasonable notice and public hearing. Section 110(a)(2) provides that the infrastructure SIP submitted by a state must have been adopted by the state after reasonable public notice and hearing, and that, among other things, it

must include enforceable emission limitations and other control

measures 1

, means or techniques necessary to meet the requirements of the CAA; provide for establishment and operation of appropriate devices, methods, systems and procedures necessary to monitor

ambient air quality; provide for implementation of a source permit

progr am to regulate the modification and construction of any stationary

source within the areas covered by the plan; include provisions for the implementation of P art C, p revention of s ignificant d eterioration (PSD)

and P art D, new source review ( NSR ) permit pr ograms; include criteria for stationary source emission control measures, mon itoring, and reporting; include provisions for air quality modeling; and provide for public and local agency participation in planning and emission control rule development.

1 Other than nonattainment emission limitations and measures which are a part of nonattainment area plans and subject to the timing requirements of Section 172 of the CAA.Campbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 6 Dem onstration : In Ohio’s June 7, 2013 infrastructure SIP submission,

Ohio verified that the state fulfills the requirements of Section 110(a)(1)

and Section 110(a)(2) of the CAA with respect to the 2010 SO 2 NAAQS

. Ohio’s June 7, 2013 infrastructure SIP for t he 2010 1

- hour

SO 2 standard contains SIP approved Ohio Administrative Code Chapter 3745

- 18, through which SO 2 emissions are directly regulated.

Section 110(a)(2)(D) also requires state plans to prohibit emissions

from within the state which contribute s ignificantly to nonattainment or maintenance areas in any other state , or which interfere with programs under Part C to prevent significant deterioration of air quality or to achieve reasonable progress toward the national visibility goal for

Federal class I areas (national parks and wilderness areas).

Demonstration : In order to assist state s in addressing their obligations regarding regionally transported pollution, U.S. EPA finalized the Clean

Air Interstate Rule (C AIR ) and then the Cross State Air Poll ution Rule (CSAP R ) to reduce SO 2 and NO

x emissions from large electric generating units (EGU). Ohio has met the requirements of the federal

CAIR to reduce NO

x and SO 2 emissions contributing to downwind states. On February 1, 2008, U.S. EPA approved Ohio’s CAIR program, which can be found in Ohio Administrative Code (OAC) Chapter 3745

- 109 2 . On July 6, 2011 , U.S. EPA finalized a replacement to the CAIR program, the CSAPR

. CSAPR will further

assist state s in addressing their obligations regarding regionally transported pollution by providing reductions in NO

x and SO 2 emissions in 201 5 and 201 7 3

.

b. Part D requirements

Subpart 1 of Part D consists of general requirements applicable to all areas which are designated nonattainment based on a violation of the NAAQS. Subpart 5 of Part D consists of more specific requirements applicable to SO 2 4

.

i. Section 172(c) requirements

2 http://www.epa.ohio.gov/da pc/regs/regs.aspx#3745

- 109

3 Timeline for implementation of CSPAR was adjusted from 2012 and 2014 to 2015 and 2017. (79 FR 71663)

4 Subpart 5 of Part D identifies requirements related only to plan submission deadlines and

attainment dates. SIP submittal a nd attainment dates are discussed in the introduction of this

submittal.Campbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 7 This Section contains general requirements for nonattainment

plans. The requirements for reasonable further progress (RFP)

, identificati on of certain emissions increases, and other measures needed for attainment will not apply for redesignations because they only have meaning for areas not attaining the standard. The requirements for an emission inventory will be satisfied by the inventory requirements of the maintenance plan.

Demonstration : The emissions inventory is discussed in Chapter Four and the maintenance plan is discussed below. The requirements of the Part D NSR program will be replaced

b y the PSD program once the area has be en redesignated. The PSD program is discussed in Chapter Five (Requirement 5 of 6). The demonstrations are provided in these locations.

ii. Conformity

The state must work with U.S. EPA to show that its SIP provisions are consistent with the Section 176(c)(4 ) conformity requirements. The redesignation request should include conformity procedures, if the state already has these procedures in place. If a state does not have conformity procedures in place at the time that it submits a redesignation request, the state must commit to follow U.S. EPA’s conformity regulation upon issuance, as applicable.

Demonstration: Ohio EPA meets all of U.S. EPA’s conformity procedures. Ohio EPA commits to following the general conformity requirements of 40 CFR 93.150 to 93.1 65. On August 20, 2014, Ohio EPA submitted signed Memorandums of Understanding (MOUs) to U.S. EPA establishing transportation conformity procedures for inclusion in Ohio’s SIP . U.S. EPA issued a direct final rulemaking approving the MOUs on March
2, 2015 (80 FR 11133) with an effective date of May 1, 2015.

As described in the SO 2 nonattainment area SIP guidance, d ue to the relatively small, and decreasing, amounts of sulfur in gasoline and on

- road diesel fuel, the U.S. EPA's transportation conformity rul es provide that they do not apply to S O 2 unless transportation conformity budgets exist for other reasons, such

as that SO 2 is found to be a significant contributor to a PM 2.5 nonattainment problem, or if the SIP has established an approved or adequate bud get for such emissions as part of the RFP, attainment or maintenance strategy. Neither of theseCampbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 8 circumstances applies here. As discussed in Ohio EPA’s

December 9, 2010 5 redesignation request and maintenance plan for the Cincinnati

- Hamilton OH

- KY

- IN area un der the 1997

PM 2.5 standard, mobile SO 2 was found to be an insignificant

contributor to the PM 2.5 nonattainment problem. All of Campbell County, KY and all of Clermont County, OH were included in

that historical nonattainment area and no SO 2 budgets exist for these counties. Therefore, mobile source SO 2 emission budgets are not required for this area.

5 http://www.epa.ohio.gov/portals/27/SIP/Cincinnati_PM25_annual_redesignation

- FINAL.pdfCampbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 9 

### CHAPTER THREE : SO 2 

### M onitoring
CAA Section 107(d)(3)(E)(i)

Requirement 1 of 4 : A demonstration that the NAAQS for 1

- hour SO 2 , as published in 40 CFR 50. 1 7, has been attained.

There is one monitor measuring SO 2 concentrations in this nonattainment

area . Th is monitor is operated by the Kentucky Division for Air Quality

. The location of the monitoring site for this nonattainment area is shown i n Figure

1

.

Figure 1

- Map of the Campbell

- Clermont KY

- OH nonattai nment area and

monitor locationCampbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 10 In accordance with 40 CFR Part 50, Appendix T, three complete years of monitoring data are required to demonstrate attainment at a monitoring site.

The 1

- hour SO 2 stan dard is met at an ambient air quality monitoring site when

the three

- year average of the annual 99th percentile of 1

- hour daily maximum

concentrations is less than or equal to 75 ppb

. The three

- year average of the

annual 99th percentile of 1

- hour daily ma ximum concentrations is also called the site's “design value.” To be complete, at least 75 percent of the days in each quarter of each of the three consecutive years must have at least one reported hourly value. Hourly SO 2 data are reported to U.S. EPA’s Air Quality System (AQS )

. While calculating design values, one decimal place must be carried in the computations, with final values rounded to the nearest 1 ppb

. Decimals 0.5 or greater are rounded up, and those less than 0.5 are rounded

down

. Values a t or below 75 ppb meet the standard

. V alues greater than 75 ppb exceed the standard. An area is in compliance with the 1

- hour SO 2 standard only if every monitoring site in the area meets the NAAQS. The air quality design value for the area is the highest design value among all sites in

the area.

Demonstration : The three

- year average of the annual 99th percentile of 1

- hour daily maximum concentrations , based on data from the monitoring site in the area, is 72 ppb

. A listing of the design value for 20 12 t hrough 201 4 is

shown in Table 1.

Table 1

- Monitoring d ata for the Campbell

- Clermont KY

- OH area for

20 12

– 20 1 4

Year (ppb) Average 2012

- 2014 (ppb) Site County 2012 2013 2014

21

- 037

- 3002 Campbell

,

KY 85 71 61 72

Less than 75% capture in at le ast one quarter

Source: U.S. EPA Air Quality System (AQS) ; http://www.epa.gov/ttn/airs/airsaqs/index.htm

Requirement 2 of 4 : Ambient monitoring data quality assured in

accordance with 40 C FR 58.10, recorded in the AQS database, and available for public view.

Demonstration : Kentucky DAQ has quality assured all data shown in Appendix A in accordance with 40 CFR 58.10 and all other federal requirements. Kentucky DAQ has recorded the data in t he AQS database and, therefore, the data are available to the public.Campbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 11 Requirement 3 of 4 : A commitment that once redesignated, the state will continue to operate an appropriate monitoring network to verify the

maintenance of the attainment status.

Demo nstration : This monitor is located in Kentucky. Ohio EPA consulted with Kentucky DAQ and Kentucky DAQ assures Ohio EPA they commit to

continue moni toring SO 2 levels at the Kentucky site indicated in Figure 1 and

Table 1

. Kentucky DAQ assures Ohio EPA they will consult with U.S. EPA Region 4 prior to making changes to the existing monitoring network, should changes become necessary in the future. Kentucky DAQ assures Ohio EPA they will continue to quality assure the monitoring data to meet the requirements of 40 CF R 58 and all other federal requirements.

Requirement 4 of 4: Supplemental U.S. EPA

- approved air quality modeling to show monitors are located in the area of maximum

concentration.

Where a monitor is located in the area of maximum concentrat ion, a determination of attainment may be made based on monitoring data alone without the need for additional air quality modeling. When a nonattainment area has no monitors, or monitors not located in the area of maximum concentration, air quality disper sion modeling is generally needed to estimate

SO 2 concentrations in the area.

Demonstration : Ohio EPA analysis demonstrates violations at this monitor

wer e caused by emissions from the Walter C. Beckjord facility located along

the Ohio River in Ohio ea st of the monitor (see Figure 1). On September 1,

2014 6 , the Walter C. Beckjord facility ceased operations of all EGUs and by the end of 2014 the remaining oil

- fired units . Ohio EPA was notified of the permanent shutdown of the entirety of the facility on October 14, 2014 and May 28, 2015

. (Appendix B , Appendix I ) There are no other significant point

sources of SO 2 emissions located in the nonattainment area. Within the

po r tion of Campbell County, KY that is a part of this area there are 11 sources which combined emit less than one ton per year (tpy) of SO 2 . (Appendix C )

There are no other point sources of SO 2 emissions in the portion of Clermont County, OH that is a part of this area.

Located south (and slightly east) of the monitor, but outside of th e nonattainment area, is the William H. Zimmer facility (see Figure 1). It was

6 The letter contained in Appendix B identifies the permanent shutdown of all units occurred on October 1, 2014. However, a review of CAMD emissions showed that all the units ceased operation by September 1, 2014.Campbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 12 determined during the nonattainment designation process that emissions from the William H. Zimmer facility likely do not impact the violating monitor at question

, and therefore , the nonattainment area was not expanded to encompass this facility. To support the previous conclusion, Ohio EPA performed an extensive meteorology, emissions and back trajectory analysis and has included this analysis as Appendix D . This analysis conc ludes that it was in fact the Walter C. Beckjord facility that caused the violations and not the William H. Zimmer facility. The back trajectory analysis also demonstrates that emissions from the William H. Zimmer facility likely do not impact the nonatt ainment area as a whole.

This conclusion is further supported by an air quality trend analysis of the monitoring site. Figure 2 shows both Walter C. Beckjord and William H.

Zimmer SO 2 rolling hourly emissions 7 for the 2012 to 2014 period along with

ro lling hourly SO 2 concentrations at the monitor. For clarity in the demonstration of the long

- term trend, the emissions and monitor values are presented as rolling 168 hour averages. Elevated monitor concentrations are

associated with elevated emissions fr om Walter C. Beckjord throughout this

three

- year period. During this period there were significant fluctuations and changes in Walter C. Beckjord’s SO 2 emissions . However, emissions remained stable at the William H. Zimmer facility. Requirement 3 of 4 under Chapter 4 identifies more specific emission trend s from the Walter C. Beckjord facilit y’s six emissions units. As can be seen in that section, emissions at Walter C. Beckjord have steadily declined due to operation of

the four smaller EGUs ceasing between 2009 and 2013 and lastly the two larger EGUs in 2014

.

7 Only the EGU emission s at Walter C. Beckjord were analyzed. The SO 2 emissions from the

oil

- fired units are trivial in comparison. For example, in 2014 total SO 2 emissions were
32, 602.44 tons for the facility. Of that total, less than 0.03 tons were reported for all non

- EGU sources at the facility.Campbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 13 Figure 2 : 2012 to 2014 Walter C. Beckjord and William H. Zimmer h ourly

e missions with h ourly SO 2 m onitoring d ata

Only the two larger EGUs rema ined in operation during 2014 and completely ceased operation on September 20, 2014. In addition, from May 5 to June
29, 2014, these EGUs also did not operate. Figure 3 , also presented as a rolling average of 18 hours to more clearly illustrate the

- long term trend,

shows an obvious downward trend in monitored SO 2 concentrations during these periods even though operations at William H. Zimmer remained

consistent.Campbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 14 Figure 3 : 2014 Walter C. Beckjord and William H. Zimmer h ourly

e missions with h o urly SO 2 m onitoring d ata

An analysis of the 2014 hourly monitoring dat a shows that the average hourly

monitored SO 2 level was 2.27 ppb during periods of operation of the two remaining EGUs at the Walter C. Beckjord facility w hile during the May 5 to June 29, 2014 period and the post September 20, 2014 period the average hourly monitored SO 2 level was 0.72 ppb. The long term trend clearly

indicates that reductions in emissions at the Walter C. Beck jord facility have

led to red uctions in monitored concentrations. Further analyses, presented below demonstrate the impacts of reduced emissions on peak monitor values.

Because there are no longer any significant point sources of emissions impacting this monitor, it was determined a n air quality dispersion modeling analysis to determine the area of maximum concentration would not be relevant or necessary for this redesignation request. However, Ohio EPA conducted a conservative modeling analysis to demonstrate that

concentrations thr oughout the nonattainment area will be relatively uniform

and that the point of maximum concentration in the nonattainment area

resultant from emissions from the William H. Zimmer facility will not exceed the standard. This additional analysis is included as A ppendix J

. ThisCampbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 15 analysis shows a maximum worst

- case 99 th percentile value of 5 2. 4 ppb

with in the nonattainment area. As noted in Appendix J

, this design value is likely an over estimation but allows Ohio EPA to demonstrate in a highly

conservative ma nner th at emissions from the William H. Zimmer facility will

not cause an exceedance of the standard in this nonattainment area. This is further supported by both the back trajectory analysis and the analysis of

emissions and monitor values above. A lso i ncluded in the Appendix J analysis is a demonstrat ion that the point of maximum impact is located approximately 1.4 km southeast of the William H. Zimmer facility, and the point of maximum in the nonattainment area represents an approximately

84% reduction from the overall maximum impact.

Ohio EPA conducted a second analysis of monitor values, wind directions,

and emissions for all hours in which SO 2 emissions from the Walter C. Beckjord facility were zero to illustrate the impact of the shutdown of the

Wa lter C. Beckjord facility on peak monitor values . This analysis indicates that for those identified hours, the maximum recorded concentration was 34 ppb, and that the 99 th percentile of nonzero monitored values for the same period was 11 ppb. This anal ys is, presented in Appendix K , also demonstrates that the primary wind directions impacting the monitor in the absence of Walter C. Beckjord emissions were from the West and Northwest, where sources are located 30 to 35 km distant from the monitor, and will have

SO 2 reductions of approximately 66% from 2014 levels as of June 1, 2015. The large distances between these sources and the monitor location, as well as the nonattainment area as a whole, would indicate that there is unlikely to be a significant conce ntration gradient, and thus the monitor is determined to be representative of ambient SO 2 concentrations across the nonattainment

area.

In addition to the above, U.S. EPA has requested Ohio EPA and Kentucky DAQ perform an analysis of background concentra tion for this nonattainment area to determine predicted concentrations in the future and ensure that maintenance would be achieved. This analysis is included in Requirement 2

of 4 under Chapter Four.Campbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 16 

### CHAPTER FOUR : E mission Inventory
CAA Section 107(d)(3 )(E)(iii)

U.S. EPA’s redesignation g uidance requires the submittal of a comprehensive inventory of SO 2 emissions representative of the year when the area achieves

attainment of the 1

- hour SO 2 air quality standard. Ohio also must demonstrate that the impr ovement in air quality between the year that violations occurred and the year that attainment was achieved is based on permanent and enforceable emission reductions . Other emission inventory related requirements include a projection of the emission invent o ry to a year

at least 10 years following redesignation; a demonstration that the projected

level of emissions is sufficient to maintain the 1

- hour SO 2 standard; and a commitment to provide future updates of the inventory to enable tracking of

emis sion leve ls during the 10

- year maintenance period.

Requirement 1 of 4 : A comprehensive emission inventory of SO 2

c ompleted for the base year and a projection of the emission inventory to a year at least 10 years following redesignation.

Periodic inventories, wh ich include emissions from all sectors

- mobile, area,

non

- road, and point sources

- are prepared every three years. The 2011 periodic inventory has been identified as one of the preferred databases for SIP development and coincides with nonattainment air quality in the Campbell

- Clermont area. The 2011 inventory is used as the base year for the purpose of this submittal and is being submitted to U.S. EPA with this document to fulfill all emissions inventory requirements under the 2010 SO 2 standard.

For the attainment year, 2014 was selected since it corresponds to one of the years in the design value showing attainment (2012

– 2014). The 2014 attainment year also corresponds to the year where the permanent and enforceable improvement in air quality lead ing to attainment occurred due to the entirety of the Walter C. Beckjord facility permanently ceasing operations.

In consultation with U.S. EPA , Ohio EPA selected the year 2027 as the maintenance year for this redesignation request. This document contain s projected emissions inventories for 2020 (interim year) and 2027

.

The information below describes the procedures Kentucky DAQ, Ohio EPA

and the Ohio, Kentucky, Indiana Council of Governments ( OKI ) used to
generate future year emission projections based on the 2011 base year inventory

.Campbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 17 In summary, projections were developed for each sector as follows:

 Area source and non

- road 8 emissions were compiled from the 2011 National Emissions Inventory (NEI) and projections were developed according to the a nalysis contained in Appendix C

.

 On

- road or m obile source emission projections are based on U.S. EPA ’s

MOVES model and were provided by the OKI

. Mobile source emissions

were calculated from MOVES2014 b

- produced emission factors

. The analysis and projection s methods are described in more detail in Appendix

E

.

 Non

- EGU p oint source information was compiled from both Ohio and Kentucky Emissions Inventory databases a nd EGU point source information was compiled from the 201 4 data in U.S. EPA’s Clean Air

Marke ts Division (CAMD) 9 database . Projections were developed according to the analysis contained in Appendix C

.

 Biogenic emissions are not included in these summaries because they are negligible

.

Demonstration : Sectors included in the following tables are: Electrical Generating Unit (EGU

- Point); Non

- Electrical Generating Unit (Non

- EGU);

Non

- road Mobile (Non

- road); Other ( Area ) ; and On

- road Mobile (On

- road).

Table 2

- Ohio p ortion SO 2 emission i nventory t otals for b ase y ear 2011

, a ttainment 2014, and p roj ected 2020 and 2027 (tpy)

Sector 2011 Base 2014

Attainment 2020

Interim 2027

Maintenance

EGU Point 90,834.50 32,602.44 0.00 0.00

Non

- EGU 0.00 0.00 0.00 0.00

Non

- road 0.17 0.1 7 0.18 0.1 8

Other 7.5 0 7.6 2 7.8 7 8.00

On

- road 0.34 0.33 0.31 0.28

TOTAL 90,842.5 1 32,610.5 6 8.3 6 8.4 6

8 Includes Marine; Aircraft; and Rail (MAR ).

9 http://www.epa.gov/airmarkets/acidra inCampbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 18 Table 3

– Kentucky portion SO 2 emission inventory totals fo r base year 2011, attainment 2014, and projected 2020 and 2027 (tpy)

Sector 2011

Base 2014

Attainment 2020

Interim 2027

Maintenance

EGU Point 0.00 0.00 0.00 0.00

Non

- EGU 0.78 0.78 0.79 0.78

Non

- road 0.20 0.20 0.20 0.20

Other 6.03 6.0 5 6.08 6.0 3

On

- road 1.55 1.51 1.40 1.26

TOTAL 8.56 8.5 4 8.47 8.27

Table 4

– Combined Campbell

- Clermont a rea SO 2 e mission i nventory

t otals for b ase y ear 2011

, a ttainment 2014, and p rojected 2020 and 2027 (tpy)

SO 2 2011 Base 2014

Attainment 2020 Interim 2027

Maintenance

Ohio

Portion 90,842.5 1 32,610.5 6 8.3 6 8.4 6

Kentucky

Potion 8.56 8.5 4 8.47 8.27

COMBINED

SO 2 TOTAL 90,851.0 7 32,619.1 0 16.83 16.73

As part of the redesignation request and maintenance plan, motor vehicle emission budgets must be established unless it is determined m obile sources are insignificant contributors for a specific pollut ant. As discussed under Section 5.b.ii of Chapter Two, mobile SO 2 emissions are considered an insignificant contributor under the 2010 SO 2 NAAQS for this area.

Requirement 2 of 4: A demonstration that the projected level of

emissions is sufficient to mai ntain the SO 2 standard.

Maintenance is demonstrated either by showing that future emissions of SO 2 will not exceed the level of the attainment inventory at levels that could cause
a violation of the NAAQS , or by modeling to show that the future mix of

sou rces and emission rates will not cause a violation of the NAAQS.Campbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 19 A maintenance demonstration should also include a listing of all SO 2 control measures being implemented in the area by sector (See Chapter Five )

.

Demonstration : As discussed under Requir ement 4 of 4 in Chapter Three , it

was determined a modeling analysis of maximum concentration location would not be warranted given the unique circumstances of this specific redesignation request. Ohio EPA conducted a conservative analysis of the

maximum concentration in the nonattainment area and demonstrated that an exceedance of the standard would not occur at any point in the nonattainment area. (Appendix J) As of September 1, 2014 (when the Walter C. Beckj ord facility ceased operations ) , t here are no significant point sources of SO 2 emissions located in the nonattainment area.

Emission trends are an important gauge for continued compliance with the

SO 2 standard. Therefore, to meet this requirement, Ohio EPA performed an initial comparison of the inve ntories for the base year and maintenance years identified in Requirement 1 of 4 of this Chapter

. Maintenance is demonstrated

when the future

- year (2027) projected emission totals are below the 2014 attainment year totals.

Table 5

– Campbell

- Clermont a re a c omparison of 20 14 attainment year

and 20 2 0 and 202 7 projected emission estimates (tpy)

20 14

Attainment 20 20

Interim 20 20

Projected

Decrease 202 7

Maintenance 202 7

Projected

Decrease

SO 2 32,619.1 0 16. 83

- 32,60 2

. 27 16.73

- 32,60 2.37

As shown in the Table 5 above

, SO 2 emissions in the nonattainment area are projected to decrease by 32,6 0 2 tpy in both 20 20 and 202 7

. This drop in emissions from the attainment year in conjunction with the fact that the entire

nonattainment area’s total emissions will be 16.73 tpy to 16.83 tpy after the attainment year demonstrates maintenance.

In addition to the above, U.S. EPA has requested Ohio EPA and Kentucky DAQ perform an analysis of background concentration for this nonattainment area to determine predicted conce ntrations in the future and ensure that maintenance would be achieved. Ohio EPA and Kentucky DAQ have

determined a conservative average background concentration for this area is

4.76 ppb , and a conservative 99 th percentile background or this area is 11 ppb . The analysis to support this determination is included in Appendix F and Appendix K

. The analysis follows procedures for multiple tiers of calculation options for background as outlined in U.S. EPA’s SO 2 nonattainment area SIP guidance. The analysis o f a 4.76 ppb average background concentrationCampbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 20 and a conservative 99 th percentile concentration of 11 ppb further supports

maintenance will be achieved.

Requirement 3 of 4: A demonstration that improvement in air quality between the year violations occur red and the year attainment was achieved is based on permanent and enforceable emission reductions and not on temporary adverse economic conditions or unusually favorable meteorology.

Permanent and enforceable reductions should be a result of emission

lim itations in the SIP . In making this showing, sufficient quantitative information about emission reductions should be provided to demonstrate the improvement in air quality is attributed to permanent and enforceable

measures.

Demonstration : Permanent a nd enforceable reductions of SO 2 emissions

have contr ibuted to the attainment of the 1

- hour SO 2 stan dard in this area

.

As demonstrated in Table 6 below, p ermanent and enforceable reductions

were realized in this area due to the permanent shut down of t he entirety of the Walter C. Beckjord facility

.

Table 6

– Campbell

- Clermont KY

- OH a rea c omparison of 20 11 base year

and 20 14 attainment year EGU reductions

2011 20 14

EGU SO 2 90,834.50 32,602.44

As discussed under Requirement 4 of 4 in Chapter Th ree, violations at this monitor were determined to be caused by emissions from the Walter C. Beckjord facility which ceased operations of EGUs beginning September 1,

2014 and the remaining oil

- fired units by the end of 2014 . Ohio EPA was notified of the pe rmanent shutdown on October 14, 2014 and May 28, 2015 thereby making the reductions permanent and enforceable. (Appendix B

, Appendix I ) When an owner or operator notifies Ohio EPA of the permanence of shut down, the facility cannot resume operations with out being considered a new facility and being subject to the NSR requirements. OAC Chapter 3745

- 31 10 contains Ohio’s Permits

- to

- Install New Sources and

Permit

- to

- Install and Operate Program rules. OAC rule 3745

- 31

- 02 prevents installation or modification, and subsequent operation of new sources without properly obtaining appropriate permits. A new source is defined in OAC rule

10 http://epa.ohio.gov/dapc/regs/3745_31.aspxCampbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 21 3745

- 31 as any air contaminant source for which an owner or operator undertakes a continuing program of installation or modificatio n, wherein a modification is defined as any physical change in, or change in the method of operation of any air contaminant source that results in an increase in the allowable emissions. In addition, it has been Ohio’s longstanding policy and

memorialized under OAC Chapter 3745

- 31 that for any emission unit that is permanently shut down (physically removed from service or altered in such a way that it can no longer operate without a subsequent “modification” or installation), authorization to operate the a ffected emissions unit shall cease upon the date certified by the authorized official that the emissions unit was permanently shut down. No emission unit certified by the authorized official as being permanently shut down may resume operation without firs t applying for and obtaining a permit pursuant to OAC Chapter 3745

- 31. Thus, the cessation of emissions from the Walter C. Beckjord facility is permanent and enforceable, and that this cessation has been demonstrated to markedly improve ambient air qualit y. (Appendix K)

The Walter C Beckjord facility was comprised of six EGUs : B001 and B002

were 94 m egawatts (MW) each; B003 was 128 MW; B004 was 150 MW, B005 was 238 MW; and B006 was 414 MW. Emissions of SO 2 , by unit and for the entire facility, from 20 11 through 2014 can be seen in Figure 4 below.

Figure 4 : Walter C. Beckjord SO 2 e missions by u nit and e ntire f acility

B001 last operated in 2009, B002 in 2011, B003 in 2012, B004 in 2013, and both B005 and B006 ceased operation on September 1, 2014 as indicated in Figure 5 below.

- 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000 90,000 100,000

2011 2012 2013 2014 SO2 (TPY)

Year 1

2

3

4

5

6

FacilityCampbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 22 Figure 5 : Walter C. Beckjord SO 2 e missions f or u nits B005 and B006 in

2014

Inventories of Walter C. Beckjord’s SO 2 emissions for 2008 to 2014 can be

found in A ppendix G

.

In addition to the above , emissions of S O 2 are l imited by new source performance standards (NSPS) under Sections 111 and 129 of the CAA; and the national emission standards for hazardous air pollutants (NESHAP) under Section 112 of the CAA. Several recent U.S. EPA air quality regulations on

EGUs and oth er large sources (such as various types of boilers and incinerators) have the potential to significantly reduce SO 2 emissions further, for example, the Mercury and Air Toxics Standards (MATS). Under MATS, EGUs meeting specific criteria may choose to demon strate compliance with

alternative SO 2 emission limits in lieu of demonstrating compliance with HCl

emission limits. Also Title IV of the CAA, CAIR, CSAPR and federal consent decrees required the reduction of SO 2 emissions from EGUs throughout the

nation and will continue to achieve further reductions. U.S. EPA notes that for facilities subject to the previously listed MACT and regional interstate transport rules (such as CAIR and CSAPR), additional control measures may not be necessary to demonstrate com pliance with the 1

- hour SO 2 NAAQS.

In addition to permanent and enforceable reductions for point sources, several regulations have led, and will continue to lead, to further reductions of

SO 2 from other sectors. Examples include the application of tighte r federal

standards on non

- road diesel vehicles (Clean Air Non

- road Diesel Rule), requirements to reduce the sulfur content of various motor fuels including low

sulfur diesel fuel standards phased in from 2004 through 2007 for larger on

0 1000 2000 3000 4000 5000 6000 7000 8000 SO2 (TPY)

Month in 2014 5

6

FacilityCampbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 23 road vehicles ( High way Heavy Duty Engines Rule)

, and the application of tighter federal standards on new vehicles.

Requirement 4 of 4: Provisions for future annual updates of the inventory to enable tracking of the emission levels, including an annual

emission statement from major sources.

Demonstration : In Ohio, major point sources in all counties are required to

submit air emissions information annually, in accordance with U.S. EPA’s Consolidated Emissions Reporting Rule (CERR). Ohio EPA prepares a new periodic invent ory for all SO 2 emission sectors every three years. These SO 2 inventories will be prepared for future years as necessary to comply with the inventory reporting req uirements established in the CFR

. Emissions information will be compared to the 2011 base ye ar and the 20 27 projected maintenance year inventories to assess emission trends, as necessary, and to assure continued compliance with the 1

- hour SO 2 standard.Campbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 24 

### CHAPTER FIVE : Control Measures and Regulations

CAA Section 107(d)(3)(E)(ii), 107(d)(3)(i ii ), and 107(d)(3)(E)(v)

Requirement 1 of 6 : Section 172(c)(1) of the 1990 Clean Air Act Amendments requires states with nonattainment areas to implement

RACM and RACT.

Section 172(c)(1) requires states with nonattainment areas to submit a SIP providing fo r implementation of all RACMs as expeditiously as practicable (including such reductions in emissions from existing sources in the area as may be obtained through the adoption, at a minimum, of RACT ). The SO 2 nonattainment area SIP guidance also provides that to the exten t that U.S. EPA has promulgated national and regional rules that will require significant

SO 2 emission reductions in the period after areas are designated as nonattainment, “expeditious attainment” may in many cases mean that

attainment wi ll be possible earlier than the attainment date.

Demonstration : RACM and RACT requirements are established as part of the attainment demonstration SIPs due in April of 2015. Because this area
attained the standard, this area is eligible for redesignatio n without submitting

the RACM and RACT attainment plan elements. In addition, because there are no longer any significant point sources located in the nonattainment area no further point source emissions controls are possible therefore RACM and RACT for p oint sources is irrelevant.

In 1979, 1987 and 1996 , Ohio promulgated rules requiring reasonably

available controls measures for SO 2 from stationary sources.

Statewide RACT rules have been applied to all new sources locating in Ohio

since that time. RACT requirements are incorporated into permits along with monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio EPA also has an active enforcement program to address violations discovered by field office staff. The Ohio R ACT rules for SO 2 are found in OAC Chapter 3745

- 18 11

.

In addition, Ohio EPA promulgated and implemented CAIR (OAC Chapter

3745

- 109 12 ) over the past six years. Emissions from EGUs make up a significant contribution to Ohio’s inventory. Beginning in 2009, Ohi o implemented CAIR which provide d for significant reductions in SO 2

. Beginning in 2015, the more restrictive CSAPR will be implemented and more significant reductions in SO 2 will be realized

.

11 http://www.epa.ohio.gov/dapc/regs/3745_18.aspx

12 http://www.epa.ohio.gov/dapc/regs/3745_109.aspxCampbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 25 Requirement 2 of 6 : Section 172(c)(2) of the 1990 CAA Amendm ents requires attainment demonstration SIPs for nonattainment areas to

show RFP.

Section 171( 1 ) defines RFP as “such annual incremental reductions in emissions of the relevant air pollutant as are required by this part (part D) or may reasonable be requ ired by the EPA for the purposes of ensuring attainment of the applicable NAAQS by the applicable attainment date.” The

SO 2 nonattainment area SIP guidance explains that this definition is most appropriate for pollutants emitted by numerous and diverse so urces where inventory

- wide reductions are often needed to attain a standard. Furthermore, the definition is generally less pertinent to pollutants like SO 2 that usually have a limited number of sources affecting areas and where

emissions controls for such sources result in swift and dramatic improvement in air quality. Therefore, U.S. EPA explained that RFP is best construed as “adherence to an ambitious compliance schedule.”

Demonstration : RFP requirements are established as part of the attainment

demo nstration SIPs due in April of 2015. Because this area attained the standard prior to the due date, Ohio EPA is not obligated to submit the RFP

attainment demonstration elements. Regardless, the only source of emissions in the area for which RFP would ap ply according to U.S. EPA guidance would have been the Walter C. Beckjord facility and considering the permanent shut down occurred four years prior to the attainment date, the requirement for an ambitious compliance schedule would have been met.

Requir ement 3 of 6 : Section 172(c)(3) requires states to submit a comprehensive inventory of actual emissions.

Section 172(c)(3) requires states to submit a comprehensive inventory of actual emissions in the area, including the requirement for periodic revisi ons as determined necessary. 40 CFR 51.1008 requires such inventory to be submitted within three years of designation and requires a baseline emission inventory for a suitable year to be used for attainment planning.

The SO 2 nonattainment area SIP guidanc e provides the SO 2 inventory requirements for attainment demonstration SIPs.

The inventory should also include an attainment year inventory with projected

emissions for all SO 2 sources. The inventory should also include the best

available information on current enforceable SO 2 emission rates (allowable or permitted rates) for the SO 2 sources located in the nonattainment area.Campbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 26 Demonstration : Although this area attained the standard prior to the due date of attainment demonstrations SIPs, Ohio EPA is sti ll obligated to submit inventory elements. Many of these elements overlap the inventory requirements for the redesignation request and maintenance plan.

The Campbell

- Clermont KY

- OH area comprehensive inventory is being

submitted to U.S. EPA with this r edesignation request and maintenance plan

. The inventory is discussed in Chapter Four along with documentation on how the inventory was generated. For purposes of establishing a base year, the

2011 nonattainment year was selected.

The following identifi es Ohio’s inventory for the Ohio portion of the Campbell

Clermont KY

- OH area:

Table 7

– Ohio’s 2011 base year inventory

Sector 2011 Base (TPY)

EGU Point

Sources: Walter C. Beckjord Power Plant 90,834.50

Non

- EGU

Sources:

None 0.00

Non

- road 0 .17

Other 7.5 0

On

- road 0.34

TOTAL 90,842.5 1

Ohio also updates its inventory in accordance with U.S. EPA’s CERR rule (i.e. emissions statements). Ohio EPA submitted its emissions statement SIP on March 18, 1994 which was approve d by U.S. EPA on October 13, 1995 (59 FR 51863). As discussed in Chapter Four (Requirement 4 of 4 ), Ohio EPA submits, and commits to submit, emission inventories (statements) every three years.

Requirement 4 of 6 : Evidence that control measures requir ed in past

SO 2 SIP revisions have been fully implemented.

D emonstration : In addition to the historic RACM and RACT requirements for

SO 2 , Ohio has fully implemented the OAC Chapter 3745

- 18 regulations and CAIR requirements.Campbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 27 On March 10, 2004 , the U.S. EP A promulgated the CAIR

. Beginning in 2009, U.S. EPA’s CAIR rule requires EGUs in 28 eastern states and the District of

Columbia to significantly reduce emissions of NO

x and SO 2 . Ohio submitted a CAIR SIP which was approved by U.S. EPA on February 1, 2007

. Revisions to the CAIR SIP were again submitted on July 15, 2009. The revised CAIR SIP was approved as a direct final action on September 25, 2009 (74 FR 48857). CAIR was replaced by the more stringent CSAPR requirements beginning in 2015.

OAC Chapte r 3745

- 18 13 is Ohio’s SIP approved rules for the regulation of

SO 2

. This set of rules contains general requirements for the entire state along with facility specific requirements for significant emitters of SO 2. Specifically,

O AC rule 3745

- 18

- 19 regulates emissions from Clermont County while OAC

rule 3745

- 18

- 37 regulates emissions from Hamilton County (to the west).

Requirements are incorporated into permits along with monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio EPA also has an active enforcement program to address violations discovered by field office staff.

Requirement 5 of 6 : Acceptable provisions to provide for new source review

.

Demonstration : Ohio has a longstanding and fully implemented NSR program. Thi s is addressed in OAC Chapter 3745

- 31 14 . The Chapter includes provisions for the PSD permitting program in OAC rules 3745

- 31

- 01 to 3745

- 31

- 20. Ohio's PSD program was conditi onally approved on October 10, 2001 (66 FR 51570 ) and received final approval on Jan uary 22, 2003 (68 FR 2909 ) by U.S. EPA as part of the SIP

. The latest revisions to OAC Chapter 3745

- 31 were approved into Ohio’s SIP on February 20, 2013 (78 FR 11748).

Any facility that is not listed in the 2011 emission inventory, or for the closing

of which credit was taken in demonstrating attainment, will not be allowed to construct, reopen, modify, or reconstruct without meeting all applicable NSR requirement s . Once the area is redesignated, Ohio EPA will implement NSR through the PSD program

.

13 http://www.epa.ohio.gov/dapc/regs/3745_18.aspx

14 http://www.epa.ohio.gov/dapc/regs/3745_31.aspxCampbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 28 Requirement 6 of 6 : Assure that all existing control measures will remain in effect after redesignation unless the state demonstrates through modeling that the standard can be maintained without one or

more control measures.

Demonstration : Ohio commits to maintaining the aforementioned control measures after redesignation. Ohio hereby commits that any changes to its rules or emission limits applicable to SO 2 as required for maintenance of the

1

- hour SO 2 standard in the Ohio portion of the Campbell

- Clerm ont KY

- OH

area , will be submitted to U.S. EPA for approval as a SIP revision.

Ohio, through Ohio EPA’s Legal office and the Ohio Attorney General’s office

, has the legal authority and necessary resources to actively enforce any

violations of its rules or permit provisions. After redesignation, it intends to continue enforcing all rules that relate to the emission of SO 2 precursors in

the Campbell

- Clermont KY

- OH area.



### CHAPTER SIX : Contingency MeasuresCampbell

- Clermont KY

- OH SO 2 Redesignation Request and Maintenance Plan

P a g e | 29 CAA Section 107(d)(3)(E)(v)

R equirement 1 of 4 : A commitment to submit a revised plan eight years after redesignation.

Demonstration : Ohio hereby commits to review its maintenance p lan eight years after redesignat ion, as required by Section 175 A of the CAA

.

Requirement 2 of 4 : A c ommitment to expeditiously enact and implement additional contingency control measures in response to exceeding specified predetermined levels (triggers) or in the event that

future violations of the ambient standard occur.

Section 175A(d) requires contin gency provisions to promptly correct any

violation of the SO 2 NAAQS that occur after redesignation. Unlike Section 172(c)(9), Section 175A does not explicitly require contingency measures take effect without further action by the state. Rather the mainten ance plan should ensure contingency measures are adopted and implemented as expeditiously as practicable once they are triggered. The plan should clearly identify the measures to be adopted, provide a schedule and associated procedures for adoption and im plementation, and provide a specific time limit

for action.

The General Preamble for the Implementation of Title I of the Clean Air Act

Amendments of 1990 (April 16, 1992, 57 FR 13498) and the SO 2 nonattainment area SIP guidance (page 41 to 42) provides further discussion on contingency measures specifically for SO 2 . In many cases, attainment revolves around compliance of a single source, or small set of sources, with

emission limits show n to provide for attainment. In those cases, U.S. EPA interprets co ntingency measures to mean the state has a comprehensive program to identify sources of violations of the SO 2 NAAQS and to undertake an aggressive follow

- up for compliance and enforcement, including expedited procedures for establishing enforceable consent agreements pending the adoption of revised SIPs. (57 FR 13547)

Demonstration : As discussed in this submittal, since the permanent shutdown of Walker C. Beckjord there are no other sources in the nonattainment area with potential to cause a violation. B ecause of the absence of sources with a potential to cause a violation, Ohio cannot anticipate any future cause of a violation in this area and thus what contingency measures might be warranted to help address any future

violation . However, as discussed el sewhere, Ohio EPA also has an active enforcement program to address violations and Ohio EPA will continue toCampbell

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P a g e | 30 operate a comprehensive program to identify sources of violations of the SO 2 NAAQS and to undertake an aggressive follow

- up for compliance and

enfo rcement, including expedited procedures for establishing enforceable consent agreements pending the adoption of revised SIPs. Ohio hereby commits to adopt and expeditiously implement necessary corrective actions in

the event of a violation.

In the even t a doption of any additional control measures is necessary, they

are subject to Ohio’s administrative and legal process. This process will include publication of notices, an opportunity for public hearing, and other measures required by Ohio law for rulema king.

If a new measure/control is already promulgated and scheduled to be implemented at the federal or s tate level, and that measure/control is

determined to be sufficient to address a violation of the SO 2 NAAQS

, additional local measures may be unneces sary. Furthermore, Ohio will submit

to U.S. EPA an analysis to demonstrate the proposed measures are adequate to return the area to attainment.

Requirement 3 of 4 : A list of potential contingency measures that would be implemented in such an event.

De monstration : Given that there are no other significant point sources in the
area at this time, it is not possible to determine what control measure s will be appropriate at an unspecified time in the future . Potential measures could include tighter SO 2 em issions offsets for new and modified major sources or

additional SO 2 RACT for affected sources in the area. The absence of sources with any evident potential to cause violations means that Ohio cannot anticipate what might cause a violation in this area, and thus what contingency measures might exists that would address any future violation.

Regardless, Ohio hereby commits to adopt and expeditiously implement necessary corrective actions in the following

circumstances:

Warning Level Response: A warning level r esponse shall be prompted whenever the annual average 99 th percentile maximum daily 1

- hour SO 2 concentration of 7 9 ppb occurs in a single calendar year within the maintenance area. A warning level r esponse will consist of a study to determine whethe r the SO 2 value indicates a trend toward higher SO 2 values or whether emissions appear to be increasing. The study will evaluate whether the trend, if any, is likely to continue and, if so, the control measures necessary toCampbell

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P a g e | 31 reverse the trend taking into co nsideration ease and timing for implementation as well as economic and social considerations. Implementation of neces sary controls in response to a warning

level r esponse trigger will take place as expeditiously as possible, but in no event later than 12 m onths from the

conclusion of the most recent calendar year.

Action Level Response : An action level response shall be prompted whenever a two

year average of the 99 th percentile maximum daily 1

- hour SO 2 concentration s of 7 6 ppb or greater occurs within the maintenance area. A violation of the standard (the three

- year average of the 99 th percentile maximum daily 1

- hour value SO 2 concentration of 75 ppb or greater) shall also prompt an action level response. In the event that the action level is triggered and is not found to be due to an exceptional event, malfunction, or noncompliance with a permit condition or rule requirement, Ohio EPA in conjunction with the metropolitan planning organization or regional council of governments, will determine additional

control measures needed to assure future attainment of the
NAAQS for 1

- hour SO 2 . In this case, measures that can be implemented in a short time will be selected in order to be in place within 18 months from the close of the calendar year that prompted th e action level. Ohio EPA will also consider the timing of an action level trigger and determine if additional, significant new regulations not currently included as part of the maintenance provisions will be implemented in a timely manner

and will constitu te our response.

Contingency measures to be considered will be selected from a comprehensive list of measures deemed appropriate and effective at the time

the selection is made. The select ion of measures will be based on cost

effectiveness, emission redu ction potential, economic and social

considerations or other factors t hat Ohio EPA deems appropriate. Ohio EPA will solicit input from all interested and affected persons in the maintenance area prior to selecting app ropriate contingency measures.

No co ntingency measure shall be implemented without providing the opportunity for full public participation during which the relative costs and benefits of individual measures, at the time they are under consideration, can be fully evaluated.Campbell

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P a g e | 32 Requirement 4 of 4 : A list of SO 2 , sources potentially subject to future additional control requirements.

Demonstration : Given that there are no other significant point sources in the
area at this time, it is not possible to provide a list of potentially subject

sou rces.Campbell

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### CHAPTER SEVEN : P ublic Participation

Ohio published notification for a public hearing and solicitation for publi c comment concerning the draft redesignation petition and maintenance plan in

a widely distributed county pub lication

.

The p ublic hea ring to receive comments on the redesignation request was

held on April 16, 2015 , at the Pierce Twp. Administration Building, 950 Locust Corner Road, Cincinnati , Ohio 45245 . The public comment period closed on April 16, 2015

. Appendix H includes a copy of the public notice, the transcript from the public hearing , and when applicable, a response to

comments document

.Campbell

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### CHAPTER EIGHT : Conclusions

The Campbell

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- OH SO 2 nonattainment area has attained the

2010 1

- hour NAAQS for SO 2 and complied wi th the applicable provisions of

the 1990 Amendments to the CAA regarding redesignations of SO 2 nonattainment areas. Documentation to that effect is contained herein. Ohio EPA has prepa red a redesignation request and maintenance p lan that meet the requireme nt s of Section 110 (a)(1) of the 1990 CAA

.

Based on this presentation, the Campbell

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- hour SO 2 nonattainment area meets the requirements for redesignation under the CAA

and U.S. EPA guidance. Ohio has performed an analysis that shows the air quality improvements are due to permanent and enforceable measures. Furthermore, because th e only contributing source in this area has permanently shut down, continued compliance (maintenance) with the standard with an increasing margin of safety is e nsured

. Ohio has also demonstrated that sources surrounding the nonattainment ar ea will not cause

an exceedance of the standard at any point in the nonattainment area or are

located at sufficient distance to ensure that concentrations at the monitor are

r epresentative of the nonattainment area as a whole.

The State of Ohio hereby requests that the Campbell

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- hour

SO 2 nonattainment area be redesignated to attainment simultaneously with U.S. EPA approval of the maintenance plan provisions con tained herein.This page left intentionally blank