1 ----------------------------------------------------------------------------------------------------------------------------- - DRAFT Technical Support Document (TSD)

Kentucky Area Designations For the

2010 SO 2 Primary National Ambient Air Quality Standard

Summary

Pursuant to section 107(d) of the Clean Air Act (CAA) , EPA must initially designate areas as either “unclassifiable”, “attainment”, or “nonattainment” for the 2010 1

- hour sul fu r dioxide (S O 2 ) primary national ambient air quality standard ( NAAQS )

. The CAA defines a nonattainment area as one that does

not meet the NAAQS or that contributes to poor air quality in a nearby area that does not meet the NAAQS

. Table 1 below identifies the counties or portions of counties (or areas of Indian Country ) in Kentucky that EPA intends to initially designate “nonattainment” based on monitored violations

.

Table 1. Nonattainment Area Designations for Kentucky

Area (listed alphabetically) Kentucky Recommended Designation of

Areas/Counties EPA’s Intended Designation of

Areas/Counties

Campbell , KY

- OH*

Campbell County, KY (partial)

Clermont County , OH (partial) Attainment / Unclassifiable

N/A Nonattainment

Jefferson County , KY Jefferson County (partial) Nonattainment Nonattainment

* This is a multi

- region nonattainment area. Additional information on boundary recommendations and analyses can be found in the State of Ohio’s and the State of Indiana’s draft technical support

document s

.

Background

On June 2, 2010, EPA revised the primary SO 2 NAAQS (75 FR 35520, June 22, 2010) by establishing a

new 1

- hour standard at a level of 75 parts per billion (ppb) which is attained when the 3

- year average of

the 99 th percentile of the daily maximum 1

- hour average concentration at each monitor in an area does not exceed 75 ppb

. EPA has determined that this is the level necessary to provide protection of public health with an adequate margin of safety, especially for c hildren, the elderly and those with asthma. These groups are particularly s usceptible to the health effects associated with breathing SO 2

. The Agency is revoking the two prior primary standards of 140 ppb evaluated over 24

- hours, and 30 ppb

evaluated ove r an entire year because the standards will not add additional public health protection given

a 1

- hour standard at 75 ppb. Accordingly, EPA is not designating areas in this process on the basis of either of these two prior primary standards. Similarly, t he secondary standard for SO 2 has not been revised, so EPA is not designating areas in this process on the basis of the secondary standard

.2 EPA ’s SO 2 Designation Approach

Section 107(d) of the CAA requires that not later than 1 year after promulgation of a new or revised NAAQS, state Governors must submit their recommendations for designations and boundaries to EPA.

This deadline was in June 2011. Section 107(d) also requires EPA to provide a notification to states of

no less than 120

- days prior to promulgat ing an initial area designation that is a modification of a state’s

recommendation. EPA has reviewed the State’s recommendations and has notified the G o v er nor through letter signe d by the Regional Administrator of any intended modifications. While language in section 107 specifically addresses states, we intend to follow the same process for tribes, pursuant to section 301(d) of the CAA and Tribal Authority Rule (40 CFR Part 49). Therefore, we intend to designate areas of Indian C ountry, in consultation with the tribes, on the same schedule as state designations. If a State or Tribe did not submit designation recommendations, EPA will promulgate the designations that it deems app ropriate. If a S tate or Tribe disagrees with EPA’s intended area designations, it has an opportunity to demonstrate why any proposed modification is inappropriate. Kentucky does not have any tribes affected by this intend ed designation.

Designations guid ance was issued by EPA through a March 24, 2011, memorandum from Stephen D. Page, Director, U.S. EPA, Office of Air Quality Planning and Standards, to Air Division Directors, U.S. EPA Regions I

- X. This memorandum identifies factors EPA intends to evaluate in determining boundaries for areas designated nonattainment. These 5 factors include: 1) Air quality data; 2)

Emissions and emissions

- related data (location of sources and potential contribution to ambient SO 2 concentrations) ; 3) Meteorology (weather/transport patterns); 4) Geography/topography (mountain ranges or other air basin boundaries); and 5) Jurisdictional boundaries (e.g., counties, air districts, pre

existing nonattainment areas, reservations), among any other inform ation deemed relevant to establishing appropriate area designations and boundaries for the 1

- hour SO 2 NAAQS

.

The March 24, 2011, memo recommended that area boundaries be defaulted to the county boundary

unless additional information justifies a larger or smaller boundary than that of the county. EPA believes it is appropriate to evaluate each potential area on a case

- by

- case basis, and to recognize that

area

- specific analyses conducted by states, tribes and/or EPA may support a differ ent boundary than a

d efault county boundary.

In this TSD, EPA discusses its review and technical analysis of the recommendations regarding areas with violating monitors submitted by the states and/or tribes for designations of the 1

- hour SO 2 standard and any modifications fro m these recommendations.

Definition of important terms used in this document:

1) Designated “nonattainment” area

– an area which EPA has determined, based on a s tate recommendation and/or on the technical analysis included in this document, has violated the 2010 SO 2 NAAQS, based on the most recent three years of air quality monitoring data, or contributes to a violation in a nearby area.

2 ) Recommended nonattainment area

– an area a State or T ribe has recommended to EPA be designated as nonattainment.3 3 ) Violating monitor

– an ambient air monitor meeting all methods, quality assurance and citing criteria and requirements whose valid design value exceeds 75 ppb, as described in Appendix T of 40 CFR part

50.

4 ) 2010 SO 2 NAAQS

- 75 ppb, n ational a mbient a ir q uality s tandard for SO 2 promulgated in 2010.

Based on the 3

- year average of the 99 th percentile of the annual distribution of daily maximum 1

- hour average concentrations

5 ) Design Value

– a statistic that describes the air quality status of a given area relative to the level of the NAAQS

.4 Nonattainment Designations

Technical analysis for Campbell County Area

Introduction

Th is technical analysis for the Campbell County A rea identifies the partial county with a monitor that

violate s the 2010 SO 2 NAAQS based on 2009

- 2011 data

, and evaluates nearby counties for

contributions to SO 2 concentrations in the area. EPA has evaluated this county and nearby counties based on the weight of evidence of the factors recommended in the March 24, 2011, issued EPA guidance

.

Figure 1 is a map of the area analyzed showing the location s and design value s of air quality monitor s in the area, and the counties surrounding any violating air quality monitors

.

Figure 1

In June 2011, Secretary Leonard K. Peters recommended that 119 counties and one partial county be designated as “unclassifiable” or “attainment” for the 2010 SO 2 NAAQS based on monitored air quality

data from 2008

- 2010

. At that time, the monitor in Campbell County, Kentucky was attaining the SO 25 NAAQS and thus the Commonwealth of Kentucky did not provide a nonattainment boundary

recommend ation to EPA for Campbell County. Letter from Leonard K. Peters, Secretary, Kentucky Energy and Environment Cabinet, to Gwendolyn Keyes Fleming, Regional Administrator, USEPA, Region 4 (June 2, 2011) (on file with USEPA Region 4 Regulatory Development Section).

Figure 2. Proposed Nonattainment Area

Based on EPA’ s technical analysis described below, EPA is intending to initially designate Campbell County (partial) a s nonattainment for the 2 010 SO 2 NAAQS as the Campbell County nonattainment

area
, based upon currently available information

. Th i s count y is listed above in Table 1

. The partial county boundary for Campbell includes the following census tracks : 519.01; 519.03; 529.00; 531.00;

and 533.01

. Also in this Area, EPA intends to designate a portion of Clermont County, Ohio in association with Campbell County, Kentucky. Refer to EPA’s TSD for Ohio for more information on

the C lermont Coun ty, Ohio portion of this Area.6 Detailed Assessment

Air Q uality D ata

This factor considers the SO 2 air quality monitoring data from a Federal Equivalent Method (F E M)

monitor , including the design values (in ppb ) calculated for all air quality monitors in Campbell C ounty
and the surrounding area based on data for the 2009

- 2011 period.

The 2011 SO 2 NAAQS design values for Campbell County and the surrounding area are shown in Table

2

.

Table 2 . Air Quality Data for Nonattainment Designations in Kentucky

County State

Recommended

Nonattainment? Monitor Name Monitor Air Qualit System ID Monitor Location SO 2 Design Value

2009

- 2011 (ppb)

Campbell County, KY No North Kentucky University

(NKU) 210373002

- 42401

- 1 Highland Heights, KY

Lat 39.021806 Long

- 84.474453 89

Monitors in Bold have the highest 2009

- 2011 design value in the respective county.

Campbell County shows a violation of the 2010 SO 2 NAAQS. T herefore, some area in this county and possibly additional areas in surrounding counties must be designated nonattainment. The absence of a violating monitor alone is not a sufficient reason to eliminate nearby counties as candidates for

nonattainment status. Each area has been evaluated based on the weight of evidence of the five factors

and other relevant information.

Emissions and Emissions

- Related Data

Evidence of SO 2 emissions sources in the vicinity of a violating monitor is an important factor for determining whether a nearby area is contribu ting to a monitored violation. For this factor, EPA evaluated county level emission s data for SO 2 and any growth in SO 2 emitting activities since the date represented by those emissions data

.

Emissions

EPA recognizes that there may be important new information on emissions levels for the period after 2008, and would consider more recent information if available. Kentucky did not provide updated emissions information, therefore EPA relied on the 2008 N ational E missions I nventory (NEI) emissions

da ta ( NEI08V2 )

.

Table 3 shows total emissions of SO 2 (given in tons per year (tpy) ) for violating and potentially contributing counties in and around the Campbell County a rea , including s ources emitting greater than

100 ton s per year of SO 2 according to the 2008 NEI

. The proposed Campbell County no nattainment area

for the 2010 SO 2 NAAQS is wholly comprised within Campbell County and is therefore shown in bold

.7 Table 3

. Annual SO 2 Emissions [ NEI08V 2 ]

County Facilit y >100 tpy (EIS or State Facility ID) Facility Emissions (tpy) Total County SO 2 Emissions ( tpy )

Campbell County, KY* Lafarge North America 0.916417

88.8 Suez

- Degs of Silver

Grove LLC 0.385927 Northern Kentucky University 0.2439053 Barrett Paving Materials 0.176844

Sara Lee Foods

- Claryville Facility 0.074461 Fischer Special Mfg Co 0.00061662 Wendling Printing 0.0001035

ADM Grain Co 0.0000135

Clermont County, OH Walter C. Beckjord Generating Station ** 26,403.8 42,913.8

* There are no 100 tpy or greater SO 2 sources in Campbell County . Total 2008 Campbell County SO 2 emissions were 88. 8 tpy. ** This facility is located in Clermont County, OH

.

Since the 2008 NEI, EPA emissions inventory data shows that SO 2 emissions have been increasing at

the Walter C. Bec kjord Generating Station. See Table 4 below.

Table 4. SO 2 Emissions

Emissions Controls

The emissions data used by EPA in this technical analysis and provided in Table 3 represent emiss ions levels taking into account any control strategies implemente d on stationary sources in Campbell County, Kentucky and Clermont County, Ohio up to and including 2008. EPA has not received any additional information from the Commonwealth of Kentucky regarding emissions reductions resulting from controls put into place after 2008.

The Duke Ene rgy W.C. Beckjord facility

, located in Clermont County, O hio

, has six coal/steam units

and is located 10 miles from the violating monitor. This is a 60 year old plant with no SO 2 controls. Duke Energy has indicated that it will not be able to meet the Uti lity Maximum Available Control Technology requirements for this plant and

, therefore, may shut down the facility by January 1, 2015. Walter C Beckjord Generating Station

- Clermont County,
OH

Year 2008 2009 2010 2011 2012 ( January through

March ) Emissions tpy (EPA Clean

Air Markets Division (CAMD) data) 26400.5 41964.5 69156.3 90834.5 18688. 58 Meteorology (weather/transport patterns)

Evidence of source

- receptor relationships between specific emissions sources and high SO 2 values at violating monitors is another important factor in determining the appropriate contributing areas and the appropriate extent of the nonattainment area boundary. For this factor, EPA considered recent hourly

mete orological data from the National Weather Service (NWS) sites neares t to the violating monitor to
determine which wind vectors were associated with 1

- hour SO 2 exceedances. For the Campbell Area

, 2009

- 2011 meteorological data from the Cincinnati Municipal Airport (ID #724297

- 93812 ) and data from the Cincinnati/Northern Kentucky International Airport (ID# 724210

- 93814) were evaluated. Figure 3 shows a map of the SO 2 monitor location, meteorological data locations, and the major emissions sources in the area. The Cincinnati Municip al Airport is approximately 10 kilometers northeast of the violating monitor. The Cincinnati/Northern Kentucky International Airport is approximately 17 kilometers west of the violating monitor. The primary SO 2 emissions source is the Duke Energy, Walter C. Beckjord Generating Station facility, which is located approximately 18

kilometers east of the violating monitor.

Figure 4 shows a wind rose of the hours exceeding the 1

- hr SO 2 NAAQS (75 ppb) at the Campbell County violating monitor. The wind rose was developed using wind data from the Cincinnati Municipal Airport site.

Figure 3. Map of SO 2 monitor location, meteorological data location s , and the major

emissions sources in the area9 EPA has determined that the wind data from the Cincinnati municipal airport is not likely to be representative of winds at the monitor location in Campbell County. The reason is that the Municipal Airport is located in the Little Miami River valley, which is approximately 2 k ilometers wide with steep hills approximately 300 feet high on both sides of the valley and oriented in Northeast to Southwest

direction . See Figure 5 for a topographic map of the A rea. The river valley is likely influencing the

surf ace level winds measured at the airport by "channeling" them in the Northeast to Southwest

direction. Figure 4 . Wind Rose of 2009

- 2011 hours exceeding the 1

- hr
SO 2 NAAQS at the violating monitor with wind data from the Cincinnati Municipal Airport

.

WRPLOT View - Lakes Environmental Software WIND ROSE PLOT: Campbell County, KY - Cincinnati Municipal Airport 2009-2011 Exceedance Hours - Monitor AQS ID# 21-037-3002

COMMENTS: COMPANY NAME:

U.S. EPA Region 4

MODELER: Rick Gillam, APTMD/APB/AQMTS

DATE:

8/3/2012 PROJECT NO.: NORTH

SOUTH WEST EAST 6% 12% 18% 24% 30%

WIND SPEED (m/s)

>= 11.1

8.8 - 11.1

5.7 - 8.8

3.6 - 5.7

2.1 - 3.6

0.5 - 2.1

Calms: 0.00%

TOTAL COUNT:

18 hrs. CALM WINDS:

0.00% DATA PERIOD:

Start Date: 11/13/2009 - 14:00
End Date: 8/30/2011 - 13:00

AVG. WIND SPEED:

2.23 m/s DISPLAY: Wind Speed Direction (blowing from)10 Since the wind data from the Cincinnati Municipal Airport is not likely representative of winds at the violating monitor, EPA evaluated winds from the Cincinnati/Northern Kentucky Airport, which is

lo cated in similar terrain to the violating monitor location.

Figure 7 shows a wind rose of the hours exceeding the 1

- hr SO2 NAAQS (75 ppb) at the violating monitor. The wind rose was developed using wind data from the Cincinnati/Northern Kentucky Airport.

Since the Cincinnati Municipal Airport wind data is not likely representative of the winds at the violating monitor location, EPA evaluated wind data from the Cincinnati/Northern Kentucky Airport. As can be seen in Figure 5 , the relatively flat terrain ne ar the Cincinnati/Northern Kentucky Airport makes it likely to be generally representative of the wind patterns in the area. Figure 6 provides a wind

rose of the 2009

- 2011 hours exceeding the 1

- hr SO 2 NAAQS at the violating monitor with wind data

from the Cincinnati/Northern Kentucky Airport site. Figure 5. Topographic Map showing the Cincinnati Municipal Airport in the Little Miami River Valley11 Figure 6 shows that the majority of the exceeding hours have winds blowing from the east with generally moderate wind speeds. As can be seen in Figure 3, the Duke Energy Beckjord facility is located approximately 18 kilometers east of the monitor. No other major sources are located near the violating monitor in the east direction. Therefore, the Duke Energy Beckjord facility is likely the major

contributor to the violations at the monitor.

In order to further evaluate poten tial contribution to the violating monitor, EPA performed a wind back

trajectory analysis using the National Oceanic and Atmospheric Administration ( NOAA ) Hybrid Single

Particle Lagrangian Integrated Trajectory ( HYSPLIT ) 1 model. The HYSPLIT back

- trajector ies were created using NOAA’s archived Eta Data Assimilation System, 40 kilometer grid resolution meteorological dataset (EDAS 40 kilometers ). The back trajectories originated at the violating monitor

1 Draxler, R.R. and Rolph, G.D., 2012. HYSPLIT (HYbrid Si ngle

- Particle Lagrangian Integrated Trajectory) Model access via NOAA ARL READY Website (http://ready.arl.noaa.gov/HYSPLIT.php). NOAA Air Resources Laboratory, Silver Spring, MD. Figure 6 . Wind Rose of 2009

- 2011 hours exceeding the 1

- hr

SO 2 NAAQS at the violating monitor with wind data from the Cincinnati/Northern Kentucky Airport site

.

WRPLOT View - Lakes Environmental Software WIND ROSE PLOT: Campbell County, KY - Cincinnati/Northern Kentucky Airport 2009-2011 Exceedance Hours - Monitor AQS ID# 21-037-3002

COMMENTS: COMPANY NAME:

U.S. EPA Region 4

MODELER: Rick Gillam, APTMD/APB/AQMTS

DATE:

8/3/2012 PROJECT NO.: NORTH

SOUTH WEST EAST 5% 10% 15% 20% 25%

WIND SPEED (m/s)

>= 11.1

8.8 - 11.1

5.7 - 8.8

3.6 - 5.7

2.1 - 3.6

0.5 - 2.1

Calms: 34.38%

TOTAL COUNT:

30 hrs. CALM WINDS:

34.38% DATA PERIOD:

Start Date: 11/13/2009 - 18:00
End Date: 8/30/2011 - 17:00

AVG. WIND SPEED:

2.42 m/s DISPLAY: Wind Speed Direction (blowing from)12 location on each hour that corresponds to a measured exceedance of the 1

- hr SO 2 NAAQS and were

initialized at 100 meters above ground level with the “Model Vertical Velocity” model option

. Figure 7

shows the results of the back

- trajectory analysis.

As can be seen in Figure 7 , the results of the back

- trajectory analysis generally agree with the surface

level wind analysis shown in the wind rose in Figure 6 . The trajectory analysis shows that winds blow primarily from the east during hours exceeding the 1

- hr SO 2 NAAQS. This a nalysis supports the conclusion presented above that the Duke Energy Beckjord facility is likely the major contributor to the

violations at the monitor. Figure 7 . HYSPLIT Back

- trajectory analysis of 2009

- 2011 hours exceeding the 1

- hr SO 2 NAAQS at the violating monitor13 Geography/ Topography (mountain ranges or other air basin boundaries)

Campbell County does not have any geographical or topographical barriers significantly limiting air

pollution transport within its air shed. Therefore, this factor did not play a significant role in determining the nonattainment boundary.

Jurisdictional Boundaries

O nce EPA identifi ed the general areas that the Agency anticipated would be included in the nonattainment area, EPA then consider ed existing jurisdictional boundaries for the purposes of providing a clearly defined legal boundary and to help identify the areas appropriate f or carrying out the air quality planning and enforcement functions for nonattainment areas. With regard to the 2010 SO 2 NAAQS, EPA has determined that the appropriate j urisdictional boundaries to be considered to include counties, air districts, pre

- exist ing nonattainment areas, reservations, among any other information deemed relevant to establishing appropriate area designations and boundaries for the 1

- hour SO 2 NAAQS.

No area in Campbell County has been or is currently nonattainment for a SO 2 NAAQS, so EPA had no boundary related to a previous nonattainment designation to consider for this area. Additionally, this area does not include Indian Country. Therefore, this factor did not play a significant role in determining the nonattainment boundary.

The violating monitor is located in Campbell County, Kentucky ; however, the largest nearby source of

the SO 2 is located across state lines in Clermont County, O hio

.

Other Relevant Information

EPA did not receive additional information, relevant to establishing a nonattainment area boundary for

this A rea

.

Conclusion

After considering the factors described above, EPA intends to find that it is appropriate to initially

include the portions of co unties listed in Table 1 in the Campbell County area as nonattainment area for

the 2010 SO 2 NAAQS , based on the violating monitor

. The partial county boundary for Campbell

includes the following census tracks : 519.01; 519.03; 529.00; 531.00; and 533.01

.

The air quality monitor in Campbell County shows a violation of the 2010 SO 2 NAAQS, based on 2009

- 2011 air quality data. Based on the consideration of all the relevant and available information, as described above, EPA believes that the boundaries describ ed herein

, in conjunction with portions of Clermont County, Ohio, encompass a sufficient area that does not meet (or that contributes to ambient air quality in a nearby area that does not meet) the 2010 SO 2 NAAQS , based on the violating monitor

information

.14 Technical analysis for Jefferson County

Introduction

This technical analysis for Jefferson County identifies the monitor that violate s the 2010 SO 2 NAAQS

based on 2009

- 2011 data, and evaluates nearby counties for contributions to SO 2 concentrations in the

area. EPA has evaluated this county and nearby counties based on the weight of evidence of the factors

recommended in the March 24, 2011, issued EPA guidance

.

Figure 8 is a map of the area analyzed showing the location and design value of air quality monitors in

the area s , and the counties surrounding any violating air quality monitors.

Figure 8

In June 2011, Secretary Leonard K. Peters recommended that Jefferson County (in its entirety) be designated as nonattainment for the 2010 SO 2 NAAQS based on monitored air quality data from 2008

- 2010. Secretary Leonard K. Peters provided an update to the original recommendation o n December 20,

2011 , and January 15, 2013 . In its updated recommendation, Kentucky recommended a partial

bou ndary around the Jefferson County monitor. See Figure 9.15 Figure 9

. Kentucky’s Proposed Nonattainment Area for Jefferson County

Based on EPA’ s technical analysis described below, EPA is intending to initially designate Jefferson County as partial no nattainment for the 2 010 SO 2 NAAQS based upon currently available information

. The preliminary boundary for the Jefferson County Area is the same as recommended by Kentucky as identified in Fig ure 9 above.

Detailed Assessment

Air Quality Data

This factor considers the SO 2 air quality monitoring data, including the design values (in ppb ) calculated

for the air quality monitor in Jefferson County based on data for the 200 9

- 20 11 period

. The Secretary’s recommendation was based on data from two FEM monitors located in the

Commonwealth

. Letter from Leonard K. Peters, Secretary, Kentucky Energy and Environment Cabinet, to Gwendolyn Keyes Fleming, Regional Administrator, USEPA, Region 4 (June 2, 2011, and updated16 on December 20, 2011 , and January 15, 2013 ) (on file with USEPA Region 4 Regulatory Development Section).

The 2010 SO 2 NAAQS design values for Jefferson County and the surrounding area are shown in Table

5

.

Table 5 . Air Quality Data for Nonattainment Designations in Commonwealth County Commonwealth

Recommended

Nonattainment? Monitor Name Monitor Air Quality System ID Monitor

Location SO 2 Design Value,

200 7

- 200 9 ( ppb ) SO 2 Design Value,

200 8

- 20 10 ( ppb ) SO 2 Design Value,

200 9

- 20 11 ( ppb )

Jefferson N/A Jefferson 211110051 117 112 112 Monitors in Bold have the highest 2009

- 2011 design value in the respective county.

Jefferson County shows a violation of the 2010 SO 2 NAAQS. Therefore

, some area in this county and possibly additional areas in surrounding counties must be designated nonattainment

. The absence of a violating monitor alone is not a sufficient reason to eliminate nearby counties as candidates for

nonattainment status. Each area has been evaluated based on the weight of evidence of the five factors

and other relevant information.

Emissions and Emissions

- Related Data

Evidence of SO 2 emissions sources in the vicinity of a violating monitor is an important factor for determining whether a nearby area is contributing to a monitored violation. For this factor, EPA evaluated county level emission data for SO 2 and any growth in SO 2 emitting activities since the date represented by those emissions data

.

Emissions

EPA recognize s that there may be important new information on emissions levels for the period 2008, and would consider more recent years if available. Kentucky provided emissions information which is

included in Table 6 below

.

Table 6 shows total emissions of SO 2 (given in tpy ) for violating and potentially contributing counties in

and around Jef ferson County and sources emitting (or anticipated to contribute) greater than 100 ton s per year of SO 2 according to the 2008 NEI

.17 Table 6 . SO 2 Emissions [NEI08V2]

County Facility Located

in

Commonwealth

Recommended

Nonattainment

Area ? Facility

– Total

SO 2 Air Emissions [ 2008

NEI ] (tons per year) Facility

Location Total County SO 2 Emissions (tons per year)

Jefferson Yes LGE, MCS 28,581 38.0531

,

- 85.91

41,452 Jefferson N o LGE, CRS 10,103 38.1828

,

- 85.8894

Jefferson N o Oxy Vinyls
573 38.22022,

- 85.82885

Jefferson N o Louisville Med

482 38.24937

,

- 85.74983

Jefferson N o Kosmos Cement

304 38.03634

,

- 85.90869

Jefferson N o B

- F Dist

252 38.20832

,

- 85.79272

Jefferson N o Carbide

150 38.22251

,

- 85.84046

Jefferson N o McAlpine

145 38.27884

,

- 85.79078

Jefferson N o American Rubber

120 38.20892

,

- 85.8458

Jefferson N o Airport

112 38.1846

,

- 85.7484

Emissions Controls

The emissions data used by EPA in this technical analysis and provided in Table 6 represent emiss ions

levels taking into account any control strategies implemente d on stationary sources in Jefferson County up to and including 2008

. EPA has not received any additional information from the Commonwealth of Kentucky regarding emissions reductions resulting from cont rols put into place after 2008.

Meteorology (weather/transport patterns)

Evidence of source

- receptor relationships between specific emissions sources and high SO 2 values at violating monitors is another important factor in determining the appropriate con tributing areas and the appropriate extent of the nonattainment area boundary. For this factor, EPA considered recent hourly

mete orological data from the NWS site neares t to the violating monitor to determine which wind vectors

were associated with 1

- hour SO 2 exceedances. For the Jefferson County Area

, the meteorological data used in this analysis is for 2009

- 2011 from the Louisville Standiford Field Airport site (ID # 724230

- 93821). The Louisville Standiford Field site is approximately 10 kilometers sou theast of the northern violating monitor (AQS ID # 21

- 111

- 0041) and approximately 19 kilometers northeast of the southern violating monitor (AQS ID # 21

- 111

- 0051). The primary SO 2 emissions source nearby the monitor is the Louisville Gas & Electric, Mill Creek Station facility , located approximately 1.5 kilometers southwest from the southern violating monitor.18 Figure 10 shows a wind rose of the hours exceeding the 1

- hr SO 2 NAAQS (75 ppb) at the Jefferson County violating monitor (AQS ID # 21

- 111

- 0051). The wind rose was developed using wind data from the Louisville Standiford Field Airport site.

Figure 1 0 shows that the majority of the exceeding hours have winds blowing from the southwest quadrant with moderate to high wind speeds. As can be seen in Figure 9 the Louisville Gas & Electric, Mill Creek Station facility is located approximately 1.5 kilometers southwest of the southern monitor. Therefore, the Louisville Gas & Electric, Mill Creek Station facility is likely the major contributor to the

violations at the southern monitor.

As can be seen in Figure 1 5 , the results of the back

- trajectory analysi s generally agree with the surface

level wind analysis shown in the wind rose in Figure 15 The trajectory analysis shows that winds blow primarily from the southwest during hours exceeding the 1

- hr SO 2 NAAQS. This analysis supports the Figure 10 . Wind Rose of 2009

- 2011 hours exceeding the 1

- hr SO2 NAAQS a t the Jefferson County violating monitor ( AQS ID # 21

- 111

- 0051 )

.

WRPLOT View - Lakes Environmental Software WIND ROSE PLOT: Jefferson County, KY - Louisville Standiford Field Airport 2009-2011 Exceedance Hours - Monitor AQS ID# 21-111-0041

COMMENTS: COMPANY NAME:

U.S. EPA Region 4

MODELER: Rick Gillam, APTMD/APB/AQMTS

DATE:

8/3/2012 PROJECT NO.: NORTH

SOUTH WEST EAST 3% 6% 9% 12% 15%

WIND SPEED (m/s)

>= 11.1

8.8 - 11.1

5.7 - 8.8

3.6 - 5.7

2.1 - 3.6

0.5 - 2.1

Calms: 0.00%

TOTAL COUNT:

49 hrs. CALM WINDS:

0.00% DATA PERIOD:

Start Date: 8/9/2009 - 12:00
End Date: 10/16/2011 - 16:00

AVG. WIND SPEED:

4.13 m/s DISPLAY: Wind Speed Direction (blowing from)19 conclusion present ed above that the Louisville Gas & Electric, Mill Creek Station facility is likely the major contributor to the violations at the monitor.

Geography/topography (mountain ranges or other air basin boundaries)

Jefferson County does not have any geographica l or topographical barriers significantly limiting air

pollution transport within its air shed. Therefore, this factor did not play a significant role in determining the nonattainment boundary.

Jurisdictional boundaries

The violating monitor is located in Jefferson County, Kentucky

.

Other Relevant Information

EPA did not receive additional information, including modeling results, relevant to establishing a nonattainment area boundary for this area.

Conclusion

After considering the factors described above, EPA intends to find that it is appropriate to initially

include the portion of Jefferson County listed in Table 1 as nonattainment area for the 2010 SO 2 NAAQS , based on the violating monitor information

.

The a ir quality monitor in Jefferson County show s a violation of the 20 10 SO 2 NAAQS, based on 2009

- 2011 air quality data. Based on the consideration of all the relevant and available information, as described above, EPA believes that the boundar y described here in encompass es a sufficient area that

do es not meet (or that contribute to ambient air quality in nearby area s that do not meet) the 20 10 SO 2 NAAQS , based on the violating monitor information

. EPA proposes the boundary th at border s the LGE Mill Creek Power Plant in the southern portion of Jefferson County as prescribed by the

Commonwealth , encompassing the Watson Lane Monitor as shown in Figure 9.