Ms. Heather McTeer-Toney 

Regional Administrator 

U.S. EPA, Region 4 

Sam Nunn Atlanta Federal Center 

61 Forsyth Street, SW 

Atlanta, Georgia 30303 

April 15, 2015 

RE: Revision to the Kentucky State Implementation Plan (SIP) submittal for Sections 182(a)(l) Emissions 

Inventory 

and 182(a)(3)(B) Emissions Statement 

Dear Ms. McTeer-Toney: 

The Kentucky Energy and Environment Cabinet (Cabinet) hereby submits to the U.S. Environmental 

Protection Agency (EPA) a proposed revision to the State Implementation Plan (SIP). Specifically, this SIP revision 

documents the Clean Air Act requirements for Sections 182(a)(l) Emissions Inventory and 182(a)(3)(B) Emissions 

Statement addressing the nonattainment areas classified as Marginal for the 2008 8-hour ozone National Ambient Air 

Quality Standard. 

To expedite the review and approval of this SIP revision, the Cabinet requests EPA parallel process this 

submittal. One paper copy of the proposed revision is enclosed, and an electronic copy on compact disc that is 

identical to the paper copy. A public hearing notice, which indicates the time and location of a public hearing to 

receive comments on this SIP revision are enclosed. The Cabinet's response to information received during the public 

comment period will be provided in a subsequent submittal. 

Your prompt consideration of this request is appreciated. If you have any questions or comments 

concerning this matter, please contact Ms. Melissa Duff at the Division for Air Quality at (502) 564-3999. 

Sincerely Yours, 

rdn!fk: 

Secretary 

Enclosures 

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LOCATED WITHIN THE 

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8-HOUR OZONE NONATTAINMENT AREA 

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Prepared by 

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Submitted by 

ENERGY AND ENVIRONJ.\-IENT CABINET 

Proposed 

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BACKGROUND 

The CAA establishes a process for air quality management through the NAAQS. Area 

designations are required after promulgation of a new or revised NAAQS. On March 12, 2008, 

EPA revised both the primary and secondary ozone standards to a level of0.075 ppm, measured 

over an 8-hour period. In Federal Register notice (77 FR 30088) published on May 21, 2012, the 

EPA designated the Cincinnati, OH-KY-IN area as marginal nonattainment for the 8-hour ozone 

NAAQS, effective July 20, 2012. This nonattainment area includes portions of the Kentucky 

counties of Boone, Campbell, and Kenton. 

These Kentucky counties were previously redesignated to attainment (maintenance) for the 1997 

8-hour ozone NAAQS by EPA (75 FR 47218). The monitors located in Boone and Campbell 

counties in Kentucky did not show an ozone design value above the 8-hour NAAQS (2008 

Ozone). However, EPA concluded that portions of Boone, Campbell, and Kenton counties in 

Kentucky must be included in the Cincinnati, OH-KY-IN nonattainment area because they 

contribute to a violation in a nearby area. Specifically, from the Technical Support Document 

developed for the Cincinnati, Ohio-Kentucky-Indiana 2008 Ozone Designations, EPA states, 

"The total VOC and NOx emissions in each of Boone, Campbell and Kenton counties for 2008 

were determined by EPA to be significant contributors to the high ozone concentrations in the 

Cincinnati, OH-KY-IN nonattainment area for the 2008 8-hour ozone NAAQS." 

EPA's proposed 2008 ozone standard SIP requirements rule recommends states use 2011 as the 

base year to fulfill the Emission Inventory requirements. The year 2011 is also a required 

reporting year for the EPA National Emissions Inventory (NEI) submission under the existing 

Air Emissions Reporting Requirements (AERR) Rule. The 2011 NEI houses emissions for many 

pollutants including volatile organic compounds (VOC) and nitrogen oxides (NOx), both of 

which are ozone precursors. 

The Kentucky Division for Air Quality (DAQ) collects data, calculates, and stores emissions for 

point sources on an annual basis in the Kentucky Emissions Inventory System (KYEIS). These 

point source emissions are uploaded to the NEI each year. In addition, DAQ accepts the annual 

NEI estimates for area, event, non-road, and on-road mobile source emissions as calculated by 

EPA. Point source data for the 2011 base year emissions inventory was extracted from the DAQ 

emissions inventory database. Emission inventory estimates for area, nonroad, and on-road 

mobile sources for the 2011 base year emissions inventory were extracted from the NEI. 

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BASE YEAR EMISSIONS INVENTORY 

EPA's proposed 2008 ozone standard SIP requirements rule recommends the use of2011 as the 

base year to fulfill the Emission Inventory requirements. Calendar year 2011 is also a required 

reporting year for the EPA National Emissions Inventory (NEI) submission under the existing 

Air Emissions Reporting Requirements (AERR) Rule. The 2011 NEI houses emissions for many 

pollutants including volatile organic compounds (VOC) and nitrogen oxides (NOx), both of 

which are ozone precursors. 

The Division for Air Quality (DAQ) collects data and calculates emissions for point sources on 

an annual basis. The point source emissions are uploaded to the NEI each year. In addition, 

DAQ accepts NEI estimates for area and nonroad mobile emissions as calculated by EPA. For 

this submittal, DAQ requested on-road emissions for the nonattainment area from the OhioKentucky-Indiana Regional Council of Governments (OKI). 

The 2011 base year emissions inventory is broken down into four components: point, area, 

nonroad mobile, and on-road mobile sources. Summaries of the emissions for the Kentucky 

portions of the designated nonattairunent area by county, pollutant and category are shown in 

Table 1 through Table 3. 

Table 1 

Summary of Boone County- 2011 NOx and VOC Emissions 

Emissions Summer Day Annual Summer Day Annual 

Category NOx (tpd) NOx (tpy) voc (tpd) voc (tpy} 

Point 7.19 2698.61 1.73 556.27 

Area 1.46 531.34 10.13 3696.32 

Nonroad 1.76 641.36 2.47 903.10 

Mobile 

On-road 7.53 2615.43 3.44 1085.72 

Mobile 

Table 2 

Summary of Campbell County- 2011 NOx and VOC Emissions 

Emissions Summer Day Annual Summer Day Annual 

Category NOx (tpd} NOx (tpy) voc {tpd) voc (tpy} 

Point 0.16 61.16 0.22 65.41 

Area 0.69 253.13 4.87 1775.95 

Nonroad 0.38 138.79 0.40 145.96 

M

bil
BASE YEAR EMISSION INVENTORY •.•.•••••••..••.•....•........•....•.•.•••••..••..•••..••.•.•.........•••••••.•••...•. 2 

Point Sources ..................................................................................................................................... 3 

Area Sources •..••..••.•..•.••.••...•..•...••••••.••......•.......•.......•••••••.•....•..........•.•.......••.....••••••..••••.....•....••••.. 4 

N onroad Mobile Sources •••.•....•.....•.••••.•••.••••.•...•.•...•....•...•••..••.•••••••••••..•.....•.............•••.•••.••.••....•.• 5 

On-road Mobile Sources .••••••••...•••.•••........••••••••.•......•.•.•••.•.....••.••••.••••••.•••.•••.•................•..•••••.•.•••. 5 

PERIODIC EMISSION INVENTORY •.....•.••.•••••...••....•.............•...•...•.••..•••••..•.•...........•..••.•..•..... 7 

EMISSION STATEI\.mNT PROGRAM ••...•.••..•....•••••.•......•......•...••....•••..•.•....••...............•...•.•••.. 8 

PUBLIC PARTICIPATION .....•.•..•••..•.••..................•••.••••..••.•••..•.....•.......•.•••••••••.••••.•..............•••.•• 10 

REFERENCES .........•.....•...................•....•.......................•.....•............•......•......•...........•................... ll 
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Table Summary 

TABLE 1-SUMMARY OF BOONE COUNTY- 2011 NOx AND VOC EMISSIONS ••••••••• 2 

TABLE 2- SUMMARY OF CAMPBELL COUNTY - 2011 NOX AND VOC EMISSIONS •• 2 

TABLE 3-SUMMARY OF KENTON COUNTY- 2011 NOX AND VOC EMISSIONS •••••• 3 TABLE 4- 2011 NOX AND VOC EMISSIONS FOR POINT SOURCES- 80°/o RULE 

EFFECTIVENESS APPLIED •••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• 3 

TABLE 5-2011 NOX AND VOC EMISSIONS FOR POINT SOURCES- 100% RULE 

EFFECTIVENESS APPLIED •••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• 4 

TABLE 6- 2011 NOX AND VOC EMISSIONS FOR AREA SOURCES ............................ 4 

TABLE 7-2011 NOx AND VOC EMISSIONS FOR NONROAD MOBILE SOURCES •••••• 5 

TABLE 8-2011 NOx AND VOC EMISSIONS FOR ON-ROAD MOBILE SOURCES ••••••• 6 

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v 
Mobile 

On-road 7.65 2659.44 3.50 1103.99 

Mobile 

The following sections describe the methods for determining the emissions for each category. 

Point Sources 

For this inventory purpose, point sources are defined as stationary sources that emit greater than 

10 tons per year (tpy) ofVOCs, or 100 tpy ofNOx. The source emissions are calculated from 

data collected annually from the sources. This information is stored in the KYEIS database and 

the information is uploaded into the NEI system annually. 

This specific base year point source emissions inventory was determined by taking the emissions data from the KYEIS database for Boone, Campbell, and Kenton counties, determining the 

physical boundary of the partial county nonattainment area using available latitude and longitude 

coordinates, and eliminating those sources that were not located inside the nonattainment area. 

Annual emissions totals and summer day emissions for each facility were calculated with 80% 

rule effectiveness and 100% rule effectiveness. These summaries are show in Tables 4 and Table 

5. Details of facility 2011 NOx and VOC emissions data are provided in Appendix A. 

County 

Boone 

Campbell 

Kenton 

Table 4 

2011 NOx and VOC Emissions for Point Sources 

80% Rule Effectiveness Applied 

Summer Day AnnualNOx Summer Day 

NOx (tpd) (tpy) voc (tpd) 

17.62 6650.07 2.68 

0.16 60.16 0.22 0.02 7.99 1.27 

3 

AnnualVOC 

(tpy) 

898.18 

65.41 

354.95 
0 

County 

Boone 

Campbell 

Kenton 

Area Sources 

0 

Table 5 

2011 NOx and VOC Emissions for Point Sources 

100% Rule Effectiveness Applied 

Summer Day AnnualNOx Summer Day 

NOx (tpd) _(tpy) voc (tpd) 

7.19 2698.61 1.73. 

0.16 60.16 0.22 0.01 2.43 0.51 

AnnualVOC 

(tpy) 

556.27 

65.41 

77.44 

Area sources are stationary sources that do not meet the reporting requirements for point sources. 

The area source category includes, but is not limited to degreasing, residential, 

commercial/institutional, and industrial fuel use; commercial cooking; aviation fuel use; dry 

cleaners; storage tanks; and consumer and industrial coatings. DAQ does not have the resources 

to collect, develop and house this type of emissions inventory. As a result, DAQ has reviewed 

and accepted the annual NEI estimates for Kentucky area source emissions as calculated by 

EPA. 

This specific base year emissions inventory for area sources was calculated using the total county 

emissions ofNOx and VOC from the 2011 NEI for Boone, Campbell, and Kenton counties, and 

applying a percentage representative of the physical nonattainment area portions of the counties. 

The measurement function in Google Earth was used to approximate the percentage of each 

county that was determined to be in the designated nonattainment area. This percentage was 

then applied to the total county annual emissions obtained from the 2011 NEI for both NOx and 

VOC. The percentages used for each county are as follows: Boone County - 94%, Campbell 

County - 56%, Kenton County - 54%. The summer day emissions in tons per day (tpd) were 

derived by taking the calculated annual emissions totals and dividing by 365 days/yr. 

A summary of the 20 11 area source emissions inventory data for the partial Kentucky counties in 

the 2008 8-hr Ozone nonattainrnent are is presented in Table 6. 

Table 6 

2011 NOx and VOC Emissions for Area Sources 

County Summer Day Annual NOx Summer Day AnnualVOC NOx (tpd) (tpy) voc (tpd) (tpy) 

Boone 1

46 531

34 10

13 3696

32 
This specific base year emissions inventory for nonroad mobile sources was calculated using the 

total county emissions ofNOx and VOC from the 2011 NEI for Boone, Campbell; and Kenton 

counties, and applying a percentage representative of the physical nonattainment area portions of 

the counties. The measurement function in Google Earth was used to approximate the 

percentage of each county that was determined to be in the designated nonattainment area. This 

percentage was then applied to the total county annual emissions obtained from the 2011 NEI for 

both NOx and VOC. The percentages used for each county are as follows: Boone County94%, Campbell County- 56%, Kenton County- 54%. The summer day emissions in tons per 

day {tpd) were derived by taking the calculated annual emissions totals and dividing by 365 

days/yr. 

A summary of the 2011 area source emissions inventory data for the partial Kentucky counties in 

the 2008 8-hr Ozone nonattainment are is presented in Table 7. 

Table 7 

2011 NOX and VOC Emissions for Nonroad Mobile Sources 

County Summer Day Annual Summer Day Annual NOx (tpd) NOx (tpy) voc (tpd) voc (tpy) 

Boone 1.76 641.36 2.47 903.10 

Campbell 0.38 138.79 0.40 145.96 

Kenton 0.77 281 .52 0.62 226.20 

On-road Sources 

On-road mobile source emissions generally consist of vehicles traveling on public roadways, 

namely automobiles, motorcycles, trucks or other motor vehicles. Emissions for on-road mobile 

sources were obtained from the Ohio-Kentucky-Indiana Regional Council of Governments 

(OKI) using U.S. EPA's MOVES mobile emissions model. This organization is the metropolitan 

planning organization for the Greater Cincinnati area. The on-road emissions inventory 

represents only the nonattainment area portions of the counties. 

A summary of the 2011 area source emissions inventory data for the partial Kentucky counties in 

the 2008 8-hr Ozone nonattainment are is presented in Table 8. 

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Table 8 

2011 NOx and VOC Emissions for On-road Mobile Sources 

County Summer Day Annual NOx Summer Day AnnuaiVOC NOx (tpd) (tpy) voc (tpd) .(tpy) 

Boone 7.53 2615.43 3.44 1085.72 

Campbell 4.36 1513.90 1.99 628.45 

Kenton 7.64 2659.44 3.50 1103.99 
inventory for developing the periodic nonattainment area emissions inventory for point source, 

area, nonroad mobile and on-road mobile emissions. 

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EMISSION STATEMENT PROGRAM 

An emissions statement program requires that the owner or operator of each stationary source of 

NOx or VOC provide a statement showing the actual emissions of those pollutants annually. 

The statement must also contain a certification that the information is accurate to the best 

knowledge of the individual certifying the statement. Kentucky does not have a stand-alone 

regulation for the Emissions Statement requirements of the CAA. Rather, the requirement for an 

errussions statement program is listed within our permitting regulations. 

Kc;ntucky is submitting only the specific sections of each individual regulation as a revision to 

the approved SIP to satisfy Section 182(a)(3)(B) of the CAA, as follows: 

401 KAR 52:020. Title V permits. 

Section 22. Annual Emissions Certification. An annual emission certification shall be submitted 

to the cabinet by sources subject to this administrative regulation. 

Section 23. Certification by Responsible Official. A responsible official shall certify that, based 

on information and belief formed after reasonable inquiry, the statements and information 

contained in the following documents are true, accurate, and complete: 

( 4) Emissions certifications. 

401 KAR 52:030. Federallv-en(orceable permits (or IIOillltajol' sources. 

Section 3. General Provisions. 

(4) Sources that are located in ozone nonattainment areas and emit or have the potential to emit 

25 tpy or more ofVOC or NOx shall submit an annual emission certification pursuant to Section 

25(2) of this administrative regulation. 

Section 22. Certification by Responsible Official. A responsible official shall certify that, based 

on information and belief formed after reasonable inquiry, the statements and information 

contained in the following documents are true, accurate, and complete: 

(4) Emissions certifications. 

Section 25. Sources Subject to Title V. (1) Unless exempted in a future rulemaking by the U.S. 

EPA, sources that are subject to federal standards promulgated under 42 USC 7411 (NSPS) or 42 

USC 7412 (NESHAP) shall: 

(c) Submit annual emissions certifications pursuant ~o subsection (2) of this section; 

(2) During the first quarter of each calendar year, the cabinet shall survey each source to 

determine its actual emissions during the preceding calendar year, and the source shall provide 

and certify the information requested and return the updated survey to the cabinet within thirty 

(30) days from the date that the survey is mailed to the source. 

401 KAR 52:040. State-Origi11 Permits. 

Section 3

General Provisions
401 KAR 52:070. Registration o[desig11ated sources. 

Section 3. General Provisions. 

(2) Sources that are located in ozone nonattainment areas and emit or have the potential to emit 

twenty-five (25) tpy or more of VOC or NOx shall submit an annual emission certification as 

follows: 

(a) During the first quarter of each calendar year, the cabinet shall survey these sources to 

determine their actual emissions during the preceding calendar year and the source shall: 

1. Make the appropriate additions or corrections to the survey; 

2. Return the updated survey to the cabinet within thirty (30) days of the date that the 

survey is mailed to the source. 

,-

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PUBLIC PARTICIPATION 

Kentucky will publish notification for a public hearing and solicitation for public comment 

concerning the proposed SIP revision in the widely distributed county publications to provide at 

least thirty (30) days notice of the hearing. 

The public hearing to receive comments on this proposed SIP revision will be held on TBD at 

the offices of the Northern Kentucky Area Development District. A copy of the public hearing 

notice is included in Appendix B. 
3. May 21, 2012, Federal Register notice, Implementation of the 2008 National Ambient 

Air Quality Standards for Ozone: Nonattaimnent Area Classifications Approach, 

Attainment Deadline and Revocation of the 1997 Ozone Standards for Transportation Conformity Purposes, Final Rule. 

4. June 6, 2013, Federal Register notice, Implementation of the 2008 National Ambient Air 

Quality Standards for Ozone: State Implementation Plant Requirements, Proposed Rule. 

5. April 11, 2014, DRAFT - Emissions Inventory Guidance for Implementation of Ozone 

[and Particulate Matter] National Ambient Air Quality Standards (NAAQS) and Regional 

Haze Regulations. 

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This report was generated using SAS software. 

The headers pertinent to this submittal are: 

VTNY = VOC in tons per year VTND = VOC in tons per day 

NTNY = NOx in tons per year NTND = NOx in tons per day 

Other than the headers for Facility Name, facility ID or SIC code, the remaining headers are 

utilized by the Division for Air Quality to perform quality assurance on the data and do not 

factor into the emissions totals. 
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