Protect!!!~ ion Agency 

AUG 11 2015 

Ms. Susan Hedman 

Regional Administrator 

U.S. EPA, Region 5 

77 West Jackson Blvd. 

Chicago, Illinois 60604 

John R. Kasich, Governor 

Mary Taylor, Lt. Governor 

Craig W. Butler, Director 

Re: Redesignation Request and Maintenance Plan for the Ohio Portion of the 

Campbell-Clermont KY-OH 2010 Sulfur Dioxide National Ambient Air Quality 

Standard Nonattainment Area 

Dear Administrator Hedman: 

On August 15, 2013, U.S. EPA published (78 FR 47191) the initial sulfur dioxide (S02) 

nonattainment area designations for the 1-hour S02 national ambient air quality 

standard (NAAQS) across the country (effective October 4, 2013). Four areas of Ohio 

were designated nonattainment. I am writing to formally request a redesignation to 

attainment of the Ohio portion (Pierce Township) of the Campbell-Clermont KY-OH 

nonattainment area. The enclosed submittal combines the redesignation request and 

the required maintenance plan for this area. 

Monitoring of existing air quality indicates that the 2010 NAAQS for S02 has been 

attained throughout this area based on 2012-2014 air quality data. The nonattainment 

area was comprised of one significant source of S02 emissions, the Walter C. Beckjord 

power plant. The Walter C. Beckjord facility permanently ceased operations as of 

September 1, 2014 and since that time S02 air monitoring data has shown a significant 

decline. Ohio's analyses indicate that Walter C. Beckjord emissions were the cause of 

nonattainment, and that with the permanent shutdown of this facility maintenance of the 

NAAQS will be ensured indefinitely into the future even when taking into consideration 

other sources of S02 emissions within the vicinity of the nonattainment borders. 

In accordance with U.S. EPA's March 20, 2015 memorandum entitled "Updated 

Guidance for Area Designations for the 2010 Primary Sulfur Dioxide National Ambient 

Air Quality Standard", Ohio EPA is requesting this area be redesignated to "attainment" 

and not "unclassifiable" or "unclassifiable/attainment." Ohio EPA has provided more 

than sufficient evidence that violations are not occurring in the area since the shutdown 

of Walter C. Beckjord, no other significant sources exist in the within the area boundary 

50 West Town Street • Suite 700 • P.O. Box 1049 • Columbus, OH 43216-1049 

www.epa.ohio.gov • (614) 644-3020 • (614) 644-3184 (fax) 
that may contribute to a violation, and that emission sources outside of the boundary will 

not contribute to monitored or modeled violations in the area. 

Ohio 

March 

EPA notified the public of the draft and the opportunity to provide comments on 

12, 2015. The public hearing for this package was held on April 16, 2015 in 

Cincinnati, Ohio. Included in this submittal are comments received, testimony that was 

provided, and Ohio EPA's response to those comments. 

This submittal consists of one (1) hard copy of the required documentation. An exact 

duplicate electronic version of the submittal in PDF format is available at 

http://www.epa.ohio.gov/dapc/SIP/so2.aspx under the heading "Redesignations and 

Maintenance Plans." 

If you have questions, please contact Jennifer Van Vlerah in our Division of Air Pollution 

Control at (614) 644-3696. 

Sincerely, 

Craig Butler 

Director 

Cc: Bob Hodanbosi, Chief, Division of Air Pollution Control, Ohio EPA 

Enclosure