# Appendix R

Statement of Consideration1 STATEMENT OF CONSIDERATION

RELATING TO SIP REVISION FOR THE KENTUCKY FINE PARTICULATE MATTER (PM 2.5 ) ATTAINMENT DEMONSTRATION FOR THE KENTUCKY PORTION OF THE LOUISVILLE, KY-IN, CINCINNATI-MIDDLETOWN, OH-KY-IN, AND HUNTINGTON-ASHLAND, WV-KY-OH AREAS

Amended After Comments



# Energy and Environmental Cabinet

Department for Environmental Protection Division for Air Quality

(1) The Kentucky Energy and Environment Cabi net conducted a public hearing on August 13, 2008, at 1:30 p.m. (EDT) in the Conferen ce Room of the Kentucky Division for Air Quality, 803 Schenkel Lane, Frankfort, Kentuc ky. This hearing is wa s held to receive comments on a proposed attainment demonstr ation for the Kentucky portion of the Louisville KY-IN, Cincinna ti-Middletown OH-KY-IN, a nd Huntington-Ashland WVKY-OH PM 2.5 Nonattainment Area. Written comments were received during the public comment period.

(2) The following individuals attended and/or provided written comments:

Name and Title Organization Jimmy Keeton Kentucky Power Co. Gary Revlett EON –US

Jon Trout Lou-Metro APCD

Lauren Anderson Lou-Metro APCD

(3) The following individuals from the Kent ucky Environmental and Public Protection Cabinet attended or responded to the comments:

John Gowins, Environmental Control Supervisor Division for Air Quality Shea Hogan, Environmental Technologi st I* Division for Air Quality Martin Luther, Division for Air Quality Ty Martin, Environmental Technolo gist I Division for Air Quality Susan Weaver, Environmental Technol ogist III Division for Air Quality

* Agency moderator2 Response to Comments on the proposed a ttainment demonstration for the Kentucky portion of the Northern Kentucky, Louisville, and Ashland areas as attainment for the National Ambient Air Quality Standard (NAAQS) for annual PM 2.5

1. (a) Comment: The Court vacated the CAIR and its associated Federal Implementation Plan in their entirety. Pending the appeals pro cess and until the courts mandate issues, EPA will not take any action on submitted SIPs. Therefore, EPA encourages you to examine options your state has to provide the required emissions reductions should the CAIR be officially vacated. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet acknowledges this comme nt and is encouraged by the recent September 2008 petition filed by EPA, envir onmental groups, and industry organizations before the U.S. Court of Appeals for the D. C. Circuit seeking a rehearing of the court

decision that vacated CAIR. Kentucky’s NO

x SIP Call regulations are still in effect and

can be utilized to maintain NO

x reductions in the ozone season.

2. (a) Comment: The State Implementation Plan (SIP) Narrative could document the specific controls, emission units, emission rates and redu ctions used in the m odeling for the states in the multistate nonattainment areas (NAAs), not just for the Kentucky portion of the

NAAs. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet references, in Appendix O, the individual submittals for other

states in the three nonattainment areas.

3. (a) Comment: The SIP Narrative should document th e likelihood of the NAA states’ CAIRrelated controls actually being implemented to achieve attainment and the mechanism that make the emission rates and operati on of controls federally enforceable. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet is encouraged by th e recent September 2008 petition filed by EPA, environmental groups, and industry orga nizations before the U. S. Court of Appeals for the D.C. Circuit seeking a rehearing of the court decision that vacated CAIR. Expanded discussion regarding CAIR cont rols was added to Section 5.1.6.

4. (a) Comment: Documentation of controls relied upon from upwind states and proposed to be subject to CAIR is recommended. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet listed and expanded, in S ection 5, the federal control measures (e.g fuels and engines, MACTs, consent decree s), in addition to CAIR, relied upon by all states for reductions to particul ates and precursors to fine part iculates. As well, Section 5 includes the open burning and fugitive dust emi ssion regulations for the state and the local

agency.3 5. (a) Comment: Any sensitivity modeling that documents the impact of CAIR-related controls

in the formation of PM2.5 is recommended. And sensitivity analyses , if available, is recommended to document the improvement in PM2.5 formation and air quality, as expected from controls imp lemented in 2008 and 2009. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet has added to the na rrative a discussion provided by the contractor regarding CAIR controls and imp lications of CAIR vacatur based on available emissions sensitivity modeling. See the revised Section 5.1.6.

6. (a) Comment: The Kentucky (VISTAS-ASIP) based m odeling does not indi cate attainment for the Cincinnati NAA. This modeling pr edicts a 15.4 ug/m3 design value for the

nonattainment area. The Louisville and H untington-Ashland nonattainment areas have design values of 14.9 ug/m3 and 14.8 ug/m3, respectively. All three areas require additional weight of evidence to supp ort a control strategy of attainment. Richard Schutt, USEPA, Region 4

(b) Response: Analysis has been added to the narrativ e to further substantiate the Cabinet’s position that the area will attain the standard.

7. (a) Comment: Modeling results appear to contradict each other. The VISTAS-ASIP modeling predicts nonattainment in 2009 for the Cincinnati NAA and close to

nonattainment for the Louisville and H untington-Ashland areas. While the CMAQ modeling predicts attainment for Cincinna ti and Huntington by 2010 and nonattainment

for Louisville in 2010 and 2015. Richard Schutt, USEPA, Region 4

(b) Response: The weight of evidence relies on the Lake Michigan Air Director Consortium (LADCO) modeling which predicts attain ment for all three areas in 2009.

8. (a) Comment: Contradicting results of attainment for the three multistate nonattainment areas are presented in the MRPO and VIST AS-ASIP modeling. With the contradictory modeling results and the uncertainty of exp ected reductions from CA IR, it is difficult to determine how to assess the State’s conclusion for attainment for the three areas, or

whether or not an extension of the attainment date is needed. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet’s position is that the LADCO modeling shows attainment in

2009. See Section 6.3.2. The cont radictory results are due to two separate base years used in the MRPO-LADCO modeling and th e VISTAS-ASIP modeling. The VISTASASIP modeling relied on 2002 base year emissions. The MRPO-LADCO modeling relied on the more recent 2005 base year emissions. Overall the MRPO-LADCO modeling included more recent ambient data to predict future year design values. Additionally, LADCO used the CAMX model, and VISTAS used the CMAQ model.

Areas that show nonattainment us ing the older base year also show a ttainment using the4 more recent updated data.

9. (a) Comment: Air quality data (e.g. design value trends ) are recommended to be included in the SIP for the Ohio, Indiana, and West Vi rginia monitors in the NAAs. Recommended as well is the addition of expanded discussion on emission trends analysis and especially reduction expected in the 2008-2009 period. Richard Schutt, USEPA, Region 4

(b) Response: The ambient air data for monitors in Oh io, Indiana, and Kentucky has been

included in Section 6.3.3.

10. (a) Comment: The NOx SIP Call was cited as a sour ce of emission reductions for the

controls modeled for attainment in 2009 fo r the three multistate NAAs. At a minimum,

EPA recommends that the SIP reference the c itations for the enforcement of this program

in KY. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet has inserted into Sec tion 5.2.1, the citation providing the legal authority for the enforcement of the NO

x SIP Call program. The statutory authority to adopt and implement programs, and for prom ulgation of regulation, is granted to the Kentucky Energy and Environmental Cabine t by KRS 224.10-100 Powers and duties of cabinet found at www.lrc.ky.gov/KRS/224-10/100.PDF

11. (a) Comment: Modeling results for the non-Kentucky monitors in the three PM2.5 NAAs

need to be included in the docum entation in the SIP Narrative, and Appendices C and L. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet added modeling results fo r the non-Kentucky monitors to Table 6.3.2-2 in the SIP narrative. Appendix C c ontains the AQS ambient data for the nonattainment areas. Appendix L is the Attainment Test data for Kentucky. Appendix O

will reference the Attainment Test narratives for the other states as available.

12. (a) Comment: Modeled Attainment Software (MATS) incorporates updated procedures and information since the tool is used in the CAIR modeling. EPA recommends the State use the MATS tool in addressing the PM2.5 test. Richard Schutt, USEPA, Region 4

(b) Response: ENVIRON has now provided 2009 Best an d Final results using MATS tool. The file is posted on the ENVIRON ftp si te at ftp://ftp.environ.org/pub/webaccess/ASIP

. The file name is VISTAS_PM1 2km_02gt2_09_12_18gt4_MATS2.01. The ASIP contractor provided the KY, IN, OH, and WV data spreadsheets now included in Appendix L. As well in Appendix L, there are unmonitored area maps for each of the three nonattainment areas to provide visual illustration of the MA TS projections. The MATS tool predicts all KY site s will be below 14.5 in 2009.5 13. (a) Comment: The Executive Summary needs to provide supplemental weight of evidence analyses to explain why high 2009 model-pr edicted design values from Kentucky and Ohio monitors ranging from 14.8 to 15.6 are reflective of a control strategy that will

achieve attainment in 2009. Richard Schutt, USEPA, Region 4

(b) Response: Control strategies are discussed in Section 5.0 with expa nded discussion of CAIR and the boiler/process heater MACT.

14. (a) Comment: With the vacatur of CAIR, it is unclear how the SIP could rely now on the assumption that CAIR equals RACT and not address all required PM2.5 precursor

emissions. Richard Schutt, USEPA, Region 4

(b) Response: The majority of Kentucky’s utilities have controls NO

x , SO

x and particulate matter. Several EGU sources will be adding additional controls in the future per BART and consent decrees. Section 5.1.6 was expa nded to discuss the vacatur of CAIR.

15. (a) Comment: EPA recommends including tables in an appendix to present the results of the RACT analysis performed by Louisville’s Fine Particle Air Qual ity Task Force. Richard Schutt, USEPA, Region 4

(b) Response: The RACT analysis by Louisville entitled “Fine Particle Air Quality Task Force Report and Plan of Action, January 16, 2008” ha s been added to Appendix M,

State and Local Control Measures.

16. (a) Comment: The Fine Particle Air Quality Ta sk Force studied the four companies mentioned on page 52 of the SIP Narrativ e, and EPA recommends including in the narrative the implementation date of the contro ls, the source reductions expected from the controls, and when controls representin g RACT will be submitted for review and

inclusion in the SIP. Richard Schutt, USEPA, Region 4

(b) Response: The RACT analysis by Louisville entitled “Fine Particle Air Quality Task Force Report and Plan of Action, January 16, 2008” has been added to Appendix M,

State and Local Control Measures.

17. (a) Comment: Section 7.2 on page 52 states that RACM is addressed for certain controls in Chapter 5. EPA recommends identifying those measures that are considered RACM in Chapter 5 as it is currently unclear which meas ures the State is considering to be RACM. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet acknowledges this comment.

18. (a) Comment: The SIP does not clearly state what pollutants are considered precursor pollutants for the attainment demonstration in the SIP.6 Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet considers NO

x and SO

x to be precursor pollutants and has

inserted a statement into Section 2.3.

19. (a) Comment: The title of Figure 1.3-1 states that the annual PM 2.5 nonattainment boundaries for Kentucky are presented. EP A recommends that, for completeness and clarity, the non-Kentucky countie s in the three multi-state NAAs are also presented. Richard Schutt, USEPA, Region 4

(b) Response: For clarity the map in Figure 1 of the Executive Summary has been changed

to reflect entire nonattainment area counties. However Figure 1.3-1 continues to reflect

the associated narr ative in Section 1.3.

20. (a) Comment: The end of Section 1.4 states that the conceptual descrip tion for the nature of the PM2.5 problem in Kentucky is presented in Appendices D and O. Unable to locate a conceptual description discussion in Appendi x D or O, there is such a discussion in Appendix N. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet edited the narrative to correctly reflect the location of the conceptual description in Appendix N.

21. (a) Comment: EPA recommends the SIP Narrative include a brief summary of the conceptual description for the three NAAs. Richard Schutt, USEPA, Region 4

(b) Response: Expanded discussion in the narrative is located in Section 1.4.1. The Kentucky conceptual descrip tion as provided by the VISTA contractor is located in Appendix N. Conceptual descriptions for ot her states in the nonattainment areas are in demonstrations developed by those states.

22. (a) Comment: EPA recommends that the data pr esented in Figures 2.2-1, 2.2-2, and 2.2-3 also be provided in tabular format. The inventory data for the non-Kentucky states

should also be included. The data could be sub-totaled for each state and totaled for the

entire multistate nonattainment areas. Richard Schutt, USEPA, Region 4

(b) Response: The data numbers for bar graph Figures 2.2.1, 2.2.2, and 2.2.3 are located in Appendix E, where each pollutant and each source category for all nonattainment area

counties for all states are both totaled and sub- totaled. A statement has been added to the

narrative to reference the data being located in Appendix E.

23. (a) Comment: EPA recommends that the units of th e emissions presented in Tables 8.2-3 through 8.2-5 should be added. Richard Schutt, USEPA, Region 47 (b) Response: The units of the emissions have been added to Tables 8.2-3 through 8.2-5.

24. (a) Comment: EPA recommends section 3.5.1.1 on pages 23-24 provide a reference for the documentation of the applicati on and results of th e Integrated Planni ng Model (IPM) to develop electrical generating unit (EGU) em issions. We recommend this reference provides details on how CAIR was considered in the development of the EGU emissions. Richard Schutt, USEPA, Region 4

(b) Response: The EGU emissions were developed and documented in Appendix H and I

of the “ Documentation of the Base G2 and Best & Final 2002 Base Year, 2009 and

2018 Emission Inventories ” provided by the contractor a nd included in Appendix F of the SIP entitled “Emission Inventory Docume ntation”. This reference was added to the

narrative in Section 3.5.1.1.

25. (a) Comment: Model performance for the attainment demonstration was completed in 2004

with a much earlier version of the 2002 base year inventory th an is currently used in the modeling. This information should be incorporated into in chapter 4. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet referenced this situation in the second paragr aph of Section 4.

26. (a) Comment: EPA recommends the SIP Narrative contain a summary of the model

Performance for the three multistate nonattain ment areas. Appendix J could still be referenced for the full presentation. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet acknowledges this comment.

27. (a) Comment: EPA recommends including in the SIP narrative a brief summary of controls modeled from the non-Kentucky states in the three NAAs and that t hose modeled control reductions are further noted in tons per ye ar for the individual nonattainment areas. Additionally, including a discussi on of the implementation dates of the controls presented in Chapter 5 is recommended. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet acknowledges this comment.

28. (a) Comment: It is unclear how the NOx SIP Call wa s modeled in the modeling domain in general and in the entire multi-state NAAs in particular. Clarification needs to be expanded beyond a description of the program. Richcard Schutt, USEPA, Region 4

(b) Response : Implementation of the NOx SIP Call was projected by Integrated Planning Model (IPM). The MACTEC emissions inve ntory report describe s the IPM methods,8 and in that same report in Table 2.1-5 the EGU NO

x emissions by state in 2009. Link to MACTEC Emission Inventory report:

http://www.vistas-sesar m.org/documents/VISTABF2003-20-2008.pdf

29. (a) Comment: Table 8.2-2 states that th is mobile source emission is for the CincinnatiMiddletown OH-KY-IN area. Since this budget is only for the Kent ucky portion of the area, please rename the table as such and also in the associated discussion that follows the

table. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet renamed Table 8.2-2 to re flect it refers only the Kentucky portion of the NAA and modified the di scussion following the table as well.

30. (a) Comment: The SIP Narrative states that it expe cts EPA to re-promulgate the industrial boiler/process heater/recipro cating internal combustion en gines (RICE) MACT by 2018.

This does not address the stat e’s reliance reductions modele d from this MACT for 2009

attainment. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet acknowledges this comment . Additional narrative has been provided to address the concerns w ith the vacating of the boiler MACT.

31. (a) Comment: The SIP Narrative states that the MACT emissions represented only two percent of total PM emissions for Kentucky. EPA recommends the SIP details on how reductions from this vacated control program were allocated throughout the three

nonattainment areas and their associated emissions. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet acknowledges this comm ent and has provided details that show the vacature does not impact the modeling result. The Cabinet removed the statement referring to two percent.

32. (a) Comment: It is unclear how the SIP supports th e conclusion that reductions amounting to only 2 percent for Kentucky would not af fect the modeled results. The SIP should

show the basis of this conclusion. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet acknowledges this comment. See response to comment 31

above.

33. (a) Comment: EPA recommends section 5.1.10 provide more details on the East KY Power Cooperative (EKPC) and the Amer ican Electric Power (AEP) plants’ PM2.5 precursor emissions and their expected level of reductions that are subject to either a consent decree, best available retrofit technology (BART), or CAIR. We also9 recommend adding the implementation date(s) of the control(s) implementation that are being relied upon for attainment in a specifi c nonattainment area (identify the NAA). Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet acknowledges this comment and has revised the discussion in

Section 5.1.10.

34. (a) Comment: It is unclear what the phrase “wit hout a permit” means at the bottom of page 35 and if this affects the federa l enforceability of the consent decree. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet removed this statement.

35. (a) Comment: Adding the locations of the Spurlock, Dale and Cooper EKPC power plants and the nearest nonattainment area that is impacted by their respective reductions

is recommended. Richard Schutt, USEPA, Region 4

(b) Response: The locations of the power plants have been added to the narrative while noting that the nearest impacted NAA is Huntington-Ashland, WV-KY-OH. Spurlock is located in Mason County, Dale is in Clar k County, and Cooper is in Pulaski County.

36. (a) Comment: The vacatur of CAIR appears to requi re additional discussion on why CAIR is equal to SO2 reasonably available c ontrol technology (RACT) and no other PM2.5 precursors need to be analyzed. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet believes EPA will proceed with a substantive version of the

CAIR rule to address the issues of the Court. Therefore the contro ls implemented to meet CAIR will be federally enforceable. Th e majority of Kentucky’s utilities have controls

NO

x , SO

x and particulate matter. Several EGU sources will be adding additional

controls in the future per BART and consent decrees.

37. (a) Comment: Source-specific data are recommended for inclusion in the SIP. In addition to emission summary totals by counties in the SIP Narrative and Appendix E, EPA recommends that specific point source 2002 em issions be presented. Similarly, the area

source and nonroad mobile source 2002 emissi ons are recommended to be presented by source category for the KY NAA counties. Richard Schutt, USEPA, Region 4

(b) Response: The 2002 and 2009 source-specific emi ssions, by county, by category, and by nonattainment area are summarized in comprehensive tables in Appendix E.

38. (a) Comment: Appendix L only addresses the appli cation of the speciated monitored attainment test for the Kentucky PM2.5 monito rs in the three nonattainment areas in all but two tables and figures. Th ere is no discussion of the de velopment of data for applying10 this test at the Indiana, Oh io and Illinois monitors in th e three NAA as applicable to a specific nonattainment area. The SIP should do cument the applicati on of the speciated monitored attainment test (SMAT) fo r each monitor in the entire multistate

nonattainment area. Richard Schutt, USEPA, Region 4

(b) Response: The ASIP contractor has provided maps illustrating the MATS tool results for 2002 for the entire southeast and 2009g4 for the individual nonattainment areas. These have been included in Appendix L.

39. (a) Comment: It is unclear why 2001 was used as the base (“current”) year for the attainment demonstration modeling. Section IV.A on page 47. Th is is particularly confusing since 2002 is used in the spatial inte rpolation field’s discus sion of section B on pages 35-38. Richard Schutt, USEPA, Region 4

(b) Response: This appears to be a typographical error in the draft CAIR SMAT document located in Attachment L1, in Appendix L to the Kentucky SIP document. The Cabinet has now included MATS projections in the current Kentucky SIP document.

40. (a) Comment: Speciated profiles from the CAIR SMAT tool were used to speciate the

FRM monitor data. This was done because EPA’s Model Attainment Test Software (MATS) was not available when the KY SIP was being developed. We recommend that the State provide the informa tion and/or a reference for the location and documentation of the speciation profiles for the three nonattainment areas’ monitors and the CAIR

SMAT. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet included the CAIR SMAT Attachment L1, in Appendix L to the Kentucky SIP document.

41. (a) Comment: Given the status of CAIR and the dist ribution of a new MATS tool by EPA, the state should consider using the EPA tool in their application of the attainment test. Many updates have been made in the specia tion section of the tool since the CAIR

SMAT tool. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet acknowledges this commen t and added MATS results to the

SIP document.

42. (a) Comment: Attachment L1 provides an in-depth description of the CAIR SMAT approach. A discussion of how it was actually used is recommended. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet acknowledges this comment.11 43. (a) Comment: Only one of the four metrics listed on Appendix L, page 13 and recommended by the EPA modeling guidance was modeled in the supplemental analyses. This was the percent improvement in the number of grid cells >= 15 ug/m3. It is unclear why Table 3-1 did not show the improveme nt of grid cell >= 15 ug/m3 instead of lumping the grid cells equal to 15 ug/m3 in with those cells less than 15 ug/m3. As presented, it appears to show that very littl e improvement in the reduction of grid cells with high concentrations actually resulted in th e application of the c ontrol strategies for

the three NAAs. Richard Schutt, USEPA, Region 4

(b) Response : The Cabinet acknowledges this commen t. Whether the contractor grouped 15.0 with values greater than or less than 15 does not change th e conclusion. There are fewer hours greater than 15.0 and more hours less than 15.0.

44. (a) Comment: Regarding Table 3.2, more information on why the 2010 and 2015 CAIR modeling should override the modeling resu lts for the 2009 VISTAS-ASIP modeling is

recommended. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet acknowledges this comment. CAIR SMAT should not override the 2009 ASIP modeling projections. The CAIR SMAT for 2010 and 2015 is provided as supplemental modeling perspective to the modeling results relied upon from the newer MATS tool, and to the results from LADCO using a more recent base year. CAIR SMAT provides additional support to the Huntington-Ashland, WV-KY-OH and the Cincinnati- Middletown, OH-KY-IN nonattainment areas.

45. (a) Comment: Regarding Table 3.2, please cite the do cument and the location of the CAIR data presented. Labeling of the nonattainment areas is recommended. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet added citation for the lo cation of the data to Table 3.2 in Appendix L page 18, and to the Narrative in Table 6.3.2-1. Additionally, the link to the website for the CAIR Modeling values for 2010 is:

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

46. (a) Comment: Air quality from the non-Kentucky ambient air quality monitors in the

multi-state NAAs should be discussed. At a minimum, Table 3.5 should include data from the non-Kentucky ambient air quality monitors. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet has provided comprehens ive tables of emissions by county and by category for all counties in all thre e multistate nonattainment areas for 2002 and 2009 in Appendix E Emission Inventory Summar y. Ambient data for all monitors in the nonattainment areas is provided in the na rrative in Section 6.3.3 Air Quality Trends

and Additional Reductions in Tables 6.3.3-1 and Table 6.3.3-2.12 47. (a) Comment: The data in Appendix L
, Table 3.5 does show that air quality trends are improving in Kentucky from 2000-2006. However, there appears to be an upward trend

with the consideratio n of the 2007 data. We recomm end that the St ate provide a discussion on what reductions are expected in the 2008-2009 period to assist in the improvement in air quality and attainment in 2009. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet acknowledges this comment. The Cabinet has provided a discussion of reductions, both federal and state/local, in Section 5 Controls Applied.

Other states in the nonattainment areas are noting state/local reductions in their areas for

2008-2009.

48 (a) Comment: There is no discussion of emissions in section 3.2. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet edited Appendix L, pa ge 19 to address this comment.

49. (a) Comment: It is not clear that the density of monitors in all of the NAAs justify not applying the unmonitored attainment test. EPA highly recommends th at the State use the

EPA MATS tool with their Base G4 2009 mo deling results to address the unmonitored area analysis. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet has included in the na rrative the updated EPA MATS with

Base G4 2009 results for the unmonito red attainment test in Section 6.4.

50. (a) Comment: It is not clear if the unmonitored attainment test was used and what results were predicted, at a minimum, in all of th e counties in the three nonattainment areas. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet has included in the na rrative the updated EPA MATS with

Base G4 2009 results for the unmonito red attainment test in Section 6.4.

51. (a) Comment: EPA recommends adding the names of each nonattainment area to the tables in Appendix E. As well, the units of th e data in Appendix E should be provided. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet has modified the tabl es in Appendix E to reflect the

names of nonattainment areas and the units of the data.

52. (a) Comment: Please clarify whether the 2002 and 2009 data represent emissions inventory totals that were used in the attainment modeling. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet re-titled the cover page fo r Appendix E to reflect the emissions13 summary included was used for the VISTAS-ASIP Modeling.

53. (a) Comment: On page 3, it is unclear what th e “Base M” emissions represent. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet added the Alpine Geophys ics memorandum dated February 13, 2008, to provide clarification regarding the “B ase M” notation in the footnotes on the 2009 Emissions Inventory Summary spreadsheet in Appendix E. Base M is basically the

conversion of LADCO-MRPO Base M point source emissions into IDA format for SMOKE processing for the ASIP Best and Final modeling.

54. (a) Comment: It does not appear that the EGU and non-EGU emissi ons were combined in the point source totals for the non-VISTAS states (i.e., Indiana and Ohio). This implies that the EGU and non-EGU emissions are sepa rate for the Kentucky and West Virginia point source emissions. This statement should be revised. Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet acknowledges this commen t and revised the footnote in the summary spreadsheet.

55. (a) Comment: It is unclear why the Kentucky open burning and fugitive dust regulations are included in the SIP in Appendix M. Richard Schutt, USEPA, Region 4

(b) Response: The regulations are not new and were included because state controls

measures were discussed in the SIP. Loui sville regulations have been added as well.

56. (a) Comment: EPA recommends adding a table of contents and page numbering in Appendix H. Richard Schutt, USEPA, Region 4

(b) Response: The document in Appendix H was provide d by the contractor in a locked

PDF format with no features that are able to be ed ited by the Cabinet.

57. (a) Comment: EPA recommends that the SIP narra tive discuss the archival and access of data and modeling files used to develop the attainment demonstration. Richard Schutt, USEPA, Region 4

(b) Response: A statement has been added to Secti on 6.5 Data Access which includes the link to the VISTAS final work products whic h are relevant to the PM2.5 SIP attainment

demonstration: http://www.vistas-sesarm.or g/documents/FinalDocs.asp ;

The LADCO\Midwest RPO inform ation is at the below link: http://www.ladco.org/ ;14 and the link to the CAIR modeling values for 2010: http://www.epa.gov/cair/pdfs/finaltech02.pdf

58. (a) Comment: LMAPCD noted numerous minor gr ammatical inconsistencies and recommended editing the narrative furt her as noted in the marked-up copy. Lauren Anderson, LouMetro Air Pollution Control District

(b) Response: The Cabinet has made additional edit s for grammatical inconsistencies.

59. (a) Comment: LMAPCD suggests that a fe w paragraphs be expanded to explain the role that the District plays in deve loping information for Jefferson County.

Lauren Anderson, LouMetro Air Pollution Control District

(b) Response: The Cabinet included language suggested by LMAPCD to describe the role of the local agency in de veloping information for Jefferson County.

60. (a) Comment: In Page vii, Table 1, Site 21-111- 1041 was designated as industrial and therefore data from this site is not applicab le to NAAQS determinati ons. It is suggested

that references to this site be deleted from this document. Lauren Anderson, LouMetro Air Pollution Control District

(b) Response: The Cabinet deleted references to this site.

61. (a) Comment: Page 4,The paragraph states that Table 1.3-1 presents the 2001-2003 PM 2.5 design values for FRM Monitors. The ta ble actually contains the 2002-2004 data and design values.

Lauren Anderson, LouMetro Air Pollution Control District

(b) Response: The Cabinet has corrected this reference.

62. (a) Comment: Page 5, Table 1.3-1, The use of data from site 21-111-0043 is inconsistent throughout the document. Although it is true the site was shutdown in 2001 due to construction, sampling was resumed in 2002 and the site has met data recovery requirements since that time. Therefore, da ta after 2001 is valid. It is suggested that the

data for this site be added to the table. Lauren Anderson, LouMetro Air Pollution Control District

County FRM Monitoring

Site Year 1st Quarter

(Q1) 2nd Quarter

(Q2) 3rd Quarter

(Q3) 4th Quarter

(Q4) Annual Average Design

Value

Jefferson 21-111-0043 2002 12.0 16.4 26.4 13.9 17.2

15.9 2003 14.6 16.3 20.9 12.0 16.0

2004 12.5 14.5 18.0 13.0 14.5

(b) Response: The Cabinet added the data listed above to Table 1.3-1.15 63. (a) Comment: Page 38, Paragraphs 4 and 5 need fu rther clarification on the use of quarterly means for SMAT. The use of “DVB ,” “DVC,” “DV” and “Design Value” is inconsistent throughout the document. See pa ge 38 (paragraph 5), page 43 (paragraph 2) and page 48 (paragraphs 4 and 5). See al so Table 1, Table 6.3.2-2 and Table 6.3.3-3. Note: a base-year design value (DVB) is th e average of 3 design values for a 5 year period that straddles the model base-year. A design value (DV or DVC ) is the average of

3 consecutive annual means. Lauren Anderson, LouMetro Air Pollution Control District

(b) Response: The Cabinet does not agree. The us e of the acronyms as noted above is consistent and accurate as presented.

64. (a) Comment: Page 44, Table 6.3.2-2, The table contains ASIP/VISTAS DVBs in addition

to ASIP/VISTAS and LADCO 2009 DVFs. It is suggested that th e table’s title and column headings be revised to accurately refl ect the information presented in the table. Lauren Anderson, LouMetro Air Pollution Control District

(b) Response: The Cabinet has edited this table in several aspects fo r clarification.

65. (a) Comment: Page 44, Table 6.3.2-2, The table shoul d also include the LADCO Round 5 2009 DVF for site 21-111-0043 (12.8) and th e ASIP/VISTAS DVB for this same site (16.8). It should be noted that ASIP/VISTA S did not model DVFs for this site due to missing SMAT data (as reflec ted in Table 6.3.3-3 on page 50).

Lauren Anderson, LouMetro Air Pollution Control District

(b) Response: The Cabinet has edited this table in several aspects fo r clarification.

66. (a) Comment: Page 44, Table 6.3.2-2, Consider revising the table to include LADCO

DVBs to better illustrate the relative changes from DVBs to 2009 DVFs for both models. Note that any changes to this table should also be reflected in Table 1 on page vii of the Executive Summary

. Lauren Anderson, LouMetro Air Pollution Control District

(b) Response: The Cabinet has edited both tables for clarification, part icularly to reflect

the newer ASIP MATS tool values

67. (a) Comments: Page 45, Table 6.3.3-1, The table contai ns data for site 21-111-0043 for 2001. Due to construction, the site was shut down in March of 2001 and did not acquire enough data to meet the 75% data recovery requirement nor the minimum of 11 samples per quarter. Therefore the 17.1 value does not represent a valid annual average per 40 CFR Part 50 Appendix N secti on 4.1(b). The value should e ither be removed or noted that it was calculated using incomplete data. Lauren Anderson, LouMetro Air Pollution Control District

(b) Response: The Cabinet deleted reference to the 2001 data for this monitor.16 68. (a) Comments: Page 47, Table 6.3.3-2, Same comment as above. This would apply only

to the 2000-2002 and th e 2001-2003 design values.

Lauren Anderson, LouMetro Air Pollution Control District

(b) Response: The Cabinet adjusted Table 6 .3.3-2 to address this comment.

69. (a) Comments: Page 47, Paragraph 1 discusses the submission of exce ptional events packages. The exceptional events packages have been reviewed by EPA and a portion

of the data received concurrence with APCD’s submittal for 2004 through 2007. The approved and flagged data changes result in re latively small differences to the original annual averages in the attainment demonstr ation document. The table below reflects

the differences in those data. The first num bers in each column are the annual averages using all certified data. Th e second numbers are the annual averages if exceptional

events’ data that have been flagged for exceptional events are excluded from the

calculations. Lauren Anderson, LouMetro Air Pollution Control District

Site 2004 2005 2006 2007

Southwick 14.5/14.5 16.7/16.6 15.0/14.9 15.1/15.1 Wyandotte 14.1/14.0 16.5/16.4 15.2/15.1 14.9/14.9

Barret 13.7/13.7 16.8/16.7 14.0/13.9 15.1/15.1

Watson 12.6/12.6 16.5/16.4 13.7/13.4 15.7/15.7

(b) Response: The Cabinet acknowledges this comment.

70. (a) Comment: Page 48, Paragraph 5 references DVC and DVF values that do not match data found in Table 6.3.3-3 (VISTAS-ASIP). The values match DVB and DVF values reported in Table 6.3.2-2 (LADCO) instead. Lauren Anderson, LouMetro Air Pollution Control District

(b) Response: The Cabinet has edited these tables for clarification and to reflect the newer

MATS tool values.

71. (a) Comment: Page 50, Table 6.3.3-3 contains 2002 Typical DVCs and 2009 DVFs with no explanation of how these values diffe r from those reported in Table 6.3.2-2. Explanation provided on page 48, para graph 4 should be expanded. Lauren Anderson, LouMetro Air Pollution Control District

(b) Response: The Cabinet has edited these tables for clarification and to reflect the newer

MATS tool values.

72. (a) Comment: Page 51, It should be noted that at the time the Fine Particle Air Quality Task Force was created, ASIP/VISTAS m odeling had not demonstrated compliance of

the annual PM 2.5 standard for all monitors in the entire Louisville KY-IN nonattainment17 area (namely Clark County, IN). Though late r modeling would demonstrate compliance,

the Task Force was created with the understanding that ad ditional local controls would

be needed. Lauren Anderson, LouMetro Air Pollution Control District

(b) Response: The narrative was taken verbatim from correspondence sent to the Cabinet by the district. However, the Cabinet has now made appropriate changes to the narrative to reflect your agency’s comment above.

73. (a) Comment: Page 50, Table 6.3.3.3, The 2009 G4 modeled future design value for the Franklin County, Kentucky, monitor (21-073-0006) is 15.8 ug/m 3

. Lauren Anderson, LouMetro Air Pollution Control District

(b) Response: The ambient data for Franklin County, Kentucky, does not support the predicted model value. The current design value for Franklin County data 2005-2007 is 13.5 ug/m 3

.