# OZONE MAINTENANCE PLANSIP REVISION FOR THE PADUCAH 

# 8-HOUROZONE ATTAINMENT 1 HOUROZONE MAINTENANCE AREA

Prepared by the KENTUCKY DIVISION FORAIRQUALITY

Submitted by KENTUCKY ENVIRONMENTAL ANDPUBLIC PROTECTION CABINET November 2007TABLE OF CONTENTS

INTRODUCTION .... .. ...... ...... ...... ........................................ ...... .. .. . . .. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. ......... . . .1 BACKGROUND...... ...... ............ ...... .. .... .. .... .. .. . . .. .. . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. .. .. ............. .. .. . . . . .. . . .1 MAINTENANCE OF AIRQUALITY STANDARD. . . . :. . . . . . . . . . . . .. . . . . .. .. ........... ...... .. .. . . . . . . . . . . . . . . . . . . . . .2 PERMANENT ANDENFORCEABLE EMISSION REDUCTIONS .. .. . . . . .. . . . . . . . . . . . . . . . . . . . . . .. .. . . .. .. . .3 Highway Mobile Source Reductions..... ...... .. .. .. .. .. . . .. .. . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. ................. . . .4 Point Source Reductions .. . . . . .. . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. ................ .. ... . .. .. . . . . . .7 Area Source Reductions . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . .. . . . . .. .. . . .. .. . ... .. ...... ................ .. .. . . . . .. . . . . . . . . . . . . . . . .11 Non-Highway Mobile Source Reductions ............................ ...... .. .. . . . . . . . . . . . . . . . . . . . . . . .. .. ....... . 12 MAINTENANCE PLAN. .. . . . . . . . . . . .. . . . . . . . . . . .. . . . . .. . . . . .. .. . . .. .. . . .. .. . . .. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . .. . .14 2002 MAINTENANCE AREA EMISSIONS INVENTORY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . .. .. . . . . . . . . . . . . 14 EMISSION PROJECTION METHODOLOGY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ". . . . ". . . . . . .. .. " . .. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Point Source Projections ................. ...... .. .... .. .. . . .. .. . . .. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . .. ............ . .. .. . .18 Area Source Projections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. . ... .. ........... .. .. . . . . . . . . . . . . . . . . . . . .19 Non-Highway Mobile Source Projections . ...... ...... ................. .. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. ...... . 19 Highway Mobile Source Projections......... .. ... . .. .. . . .. .. . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. ................ .. .20 Total ofAll Emissions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. . ..... ................ .. .. . . . . . . . . . . .20 PLANTOMAINTAINAIRQUALITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. . . . . . . . . . . . . . . . . . . . . . . .21 EXISTING MONITORINGNETWORK . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . .. .. . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .22 CONTINGENCY MEASURES . . . .. .. . . .. .. . . .. .. . . .. .. . . .. .. . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. . . . . .. .22 PUBLIC PARTICIPATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . .. . . . . .. .. . . .. .. ...... ................ ...... .. .. . . . . . . . . . . . . . . . . . . .24 REFERENCES . . . . . .. .. .... .. .... .. .... .. .... .. ...... ...... .................................. .... . . .. .. . . . . . . . . . . . . . . . . . . . . . .. . . . . .. .. ... . . .25APPENDICES

A- Ambient Air Quality Monitoring Information B- Map ofArea Ozone Monitors C- 2002 Area Emissions Inventory Methodology &Documentation D- Emission Projections Summary E- Point Source Emission Projection Methodology &Documentation F- Area Source Emission Projection Methodology &Documentation G- Non-HighwayMobile Source Emission Projection Methodology &Documentation H- Highway Mobile Source Emission Projection Methodology &Documentation I- Public Hearing Announcement &Documentation J- Response to Comments Received During Public Comment Period K- Updated Consumer Product Guidance L- 401 KAR50:012. General ApplicationTABLE SUMMARY

TABLEI-SUMMARYOFOZONEEXCEEDANCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . """"""""""""""""""""""""""""""" 2 TABLE 2-PADUCAHAREAMONITORDESIGNVALUES . . . . . . . . . . . . . . . . . . . . . . . . . . """"""""""""""""""""""" 3 TABLE 3 - 1990 &2002 VOCEMISSIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 TABLE4-PROJECTEDVOCEMISSIONS . . . . . . . . . . . . . . . . . . . . . . """""""""""""""""""""""""""""""""""""""""""" 16 TABLE 5- PROJECTEDCO EMISSIONS . . . . . . . . . . . . . . . . . . . . . . . """""""""""""""""""""""""""""""""""""""""""""" 17 TABLE 6-PROJECTEDNOXEMISSIONS . . . . . . . . . . . . . . . . . . . . . """""""""""""""""""""""""""""""""""""""""""""" 17 TABLE 7-1990-2002-2020EMISSIONS COMPARISONS . . . . . . . . . . . . . . . . . . . . . . """""""""""""""""""""" 21INTRODUCTION

On April 30, 2004 (69 FR 23858), the Environmental Protection Agency (EPA) designated and classified areas for the 8-hour Ozone National Ambient Air Quality Standard (NAAQS) . For most areas, these designations became effective June 15, 2004. EPA also published the final phase 1 rule for implementation ofthe 8-hour ozone NAAQS on April 30, 2004 (69 FR 23951) . Section 51 .905 (c) and (d), established in that rulemaking, set forth requirements for antibacksliding purposes for areas designated attainment for the 8-hour standard. These provisions require these areas to submit a 10-year maintenance plan under section 110(a)(1) of the Clean Air Act (CAA) if they also were a nonattainment area, or an attainment/unclassifiable area with a section 175A maintenance plan, under the previous 1-hour ozone standard. The Paducah Area, which includes Marshall County and a portion of Livingston County, was redesignated to attainment in April 1995 for the 1-hour National Ambient Air Quality Standard (NAAQS) for ozone and is also designated attainment for the 8-hour ozone standard. This revision to Kentucky's State Implementation Plan (SIP) is based on six (6) years of ozone monitoring data that indicate continued maintenance of the 8-hour ozone standard, the implementation ofcertain permanent and enforceable reductions in ozone precursor emissions in the area, and a maintenance plan that continues to showan emissions level that runs through 2020 . BACKGROUND In accordance with the Clean Air Act Amendments (CAAA) of 1990, Marshall County and aportion of Livingston County ofthe Paducah Area was designated as marginal nonattainment for

the 1-hour ozone standard effective on January 6, 1992.1 (November 6, 1991 FR notice) . In a February 7, 1995, Federal Register notice, the U .S. EPA approved the redesignation of the PaducahArea frommarginal nonattainment to attainment for the 1-hour ozone standard effective on April 10, 19952

. On April 30, 2004 (69 FR 23858), the Environmental Protection Agency (EPA) designated and classified areas for the 8-hour ground-level ozone National Ambient Air Quality Standard (NAAQS) . These areas are required to submit a 10-year maintenance plan under section 110(a)(1) of the CAA if they also were a nonattainment area, or an attainment/unclassifiable area with a section 175A maintenance plan, under the 1-hour ozone standard. MAINTENANCE OF AIRQUALITY STANDARD The ambient air quality data for the ozone monitors in the Paducah Maintenance Area (i .e., Marshall County and a portion of Livingston County) indicate continued maintenance of the 8- hour ozone standard. The following table is a summary of the days in which the 8-hour ozone standard was exceeded in the Paducah Area.

TABLE 1

SUMMARY OF PADUCAHMAINTENANCE AREA'S 8-HOUR OZONE EXCEEDANCES

COUNTY 100 101 `02 `03 `04 `05 `06 `07 LIVINGSTON* 3 4 12 1 0 1 0 0 *Portion of county.TABLE 2 PADUCAHAREAMONITORDESIGNVALUES MONITOR 100 101 `02 ~03 `04 ~05 `06 `07 LiVINGSTON, DOT 0 .090 0 .087 0 .084 0 .084 0 .080 0 .075 0 .072 0 .074 LIVINGSTON, BLOODWORTH* O .0gG 0.083 X X X X X X *Monitor was discontinued in 2002. This same monitoring information for this area is contained in the U .S. EPA's Aerometric Information Retrieval System (AIRS) database (Please see Appendix Afor ozone monitoring information for this area) . The ambient ozone monitoring data was collected at sites that were selected with assistance fromthe U .S. EPAand are considered to be representative ofthe area of highest concentration. The collected data were quality-assured in accordance with 40 CFR Part 58 and recorded in the U .S. EPA's AIRS database. It is anticipated that the remaining monitor will remain at its current location for the duration of the maintenance plan period (2002-2020)

. Maps indicating the location ofthe monitor in Livingston County are included in Appendix B . PERMANENT ANDENFORCEABLE EMISSION REDUCTIONS The continued improvement and maintenance of the air quality in the Paducah Maintenance Area, as verified by the lack of exceedances of the 8-hour ozone standard, is due to the implementation of permanent and enforceable emission reductions. Emission reductions (in tons per day, or tpd) are described fromvarious programs and initiatives. The following categories of sources have shown or are expected to showemission reductions in volatile organic compounds (VOC), carbon monoxide (CO), and oxides of nitrogen (NOX) emissions due to regulatory measures implemented since the passage of the 1990 Clean Air Act Amendments or since the area was designated attainment .For this SIP revision, Kentucky chose to use 2002 as the year for developing a new

comprehensive ozone precursor emissions inventory fromwhich projected emissions could be developed for 2005, 2008, 2011, 2014, 2017 and 2020 . Maintenance is demonstrated by comparing the attainment year emissions to the emissions in the years listed above. The attainment year mobile emissions were recalculated using MOBILE 6 .2 in order to allowan accurate comparison to mobile emissions in the years listed above. All relative planning scenarios for the mobile modeling were held constant . The following information outlines emission reduction measures that have occurred from 1990 through 2002, and those implemented after 2002 and projected to 2020 . Highway Mobile Source Reductions Federal Motor Vehicle Control Program(FMVCP) 

### Permanent and enforceable emission reductions have been and continue to be achieved each year through this program

. In recent years, stricter federal requirements have been imposed on automobile manufacturers for improved fuel-efficiency and extended warranties for emission control devices. Documentation ofthese emission reductions is contained in the highway mobile modeling runs (See Appendix H) . Fleet Turnover ofAutomobiles Permanent and enforceable emission reductions have occurred in the Paducah Maintenance Area as a result of fleet turnover ofautomobiles. As newer, more efficient models replace older, less efficient automobiles, the emissions decrease on a per mile basis. Quantification of these reductions is contained in the highway mobile modeling runs.LowerReid Vapor Pressure

The 1990 CAAA mandated that the Reid Vapor Pressure (RVP) ofgasoline decrease from 10.5 pounds per square inch (psi) in 1988, to 9.0 psi in 1992 during the ozone season. Recent guidance fromU

.S. EPA (Region 4 and the National Vehicle and Fuel Emissions Laboratory in Ann Arbor) indicated that a RVP of 8.6 should be used, based on information from EPA's National Inventory Model (NIM)

. With EPA concurrence, Kentucky has used 8 .6 as input for the highway mobile model (i .e., MOBILE 6.2) . Quantification of these reductions is contained in the mobile modeling. Tier 2Motor Vehicle Emissions and FuelStandards Permanent and enforceable reductions have occurred through this program . The overall Tier 2 programfocuses on reducing the passenger car and light truck emissions most responsible for causing ozone. In 2004, the Tier 2 standards began to phase in for the first time a single set of federal tailpipe emission standards that apply to all passenger cars, light trucks, and larger passenger vehicles (including sport utility vehicles, minivans, vans, and pickup trucks) operated on any fuel . In 2007, when the new standards will be fully phased in, U.S. EPA projects that nationwide NOx reductions fromcars and trucks will be 856,471 tons per year (tpy) . U .S. EPA further projects a NOx reduction of 1,236,000 tpy by 2010, and reductions reaching an estimated 2,220,000 tpy in 2020 . Quantification of these reductions for Kentucky is contained in the highway mobile model runs (Appendix H) . Heavy-Duty Gasoline andDiesel Highway Vehicles Standards New USEPA standards designed to reduce NOx and VOC emissions fromheavy-duty gasoline and diesel highway vehicles began to take effect in 2004. A second phase of standards andtesting procedures, which began in 2007, will reduce particulate matter from heavy-duty

highway engines, and will also reduce highway diesel fuel sulfur content to 15 ppmsince the sulfur damages emission control devices. The total program is expected to achieve a 90% reduction in particulate matter (PM) emissions and a 95% reduction in NOx emissions for these new engines using lowsulfur diesel, compared to existing engines using higher-content sulfur diesel . Large Nonroad Diesel Engines Rule In May 2004, the USEPA promulgated new rules for large nonroad diesel engines, such as those used in construction, agricultural, and industrial equipment, to be phased in between 2008 and 2014. The nonroad diesel rules also reduce the allowable sulfur in nonroad diesel fuel by over 99% . Nonroad diesel fuel currently averages about 3,400 ppmsulfur. The rule limits nonroad diesel sulfur content to 500 ppmin 2006 and 15 ppm in 2010 . The combined engine and fuel rules will reduce NOx and PMemissions fromlarge nonroad diesel engines by over 90%, compared to current nonroad engines using higher-content sulfur diesel . Nonroad Spark-Ignition Engines and Recreational Engines Standard The newstandard, which became effective in January 2003, regulates NOx, HC and CO for groups of previously unregulated nonroad engines. This standard applies to all new engines sold in the United States and imported after these standards begin and will apply to large sparkignition engines (forklifts and airport ground service equipment), recreational vehicles (offhighway motorcycles and all-terrain-vehicles), and recreational marine diesel engines. The regulation varies based upon the type ofengine or vehicle. The large spark-ignition engines contribute to ozone formation and ambient COand PM levels in urban areas. Tier 1 ofthis standard was implemented in 2004 and Tier 2 is scheduled to start in2007. Like the large spark-ignition, recreational vehicles contribute to ozone formation and

ambient CO and PM levels. For the off-highway motorcycles and all-terrain-vehicles, model year 2006, the new

exhaust emissions standard was phased-in by 50% and for model years 2007 and later at 100%

. Recreational marine diesel engines over 37 kilowatts are used in yachts, cruisers, and other types of pleasure craft. Recreational marine engines contribute to ozone formation and PMlevels, especially in marinas. Depending on the size of the engine, the standard began phasing-in in 2006 . When all of the nonroad spark-ignition engines and recreational engines standards are fully implemented, an overall 72%reduction in HC, 80% reduction in NOx, and 56%reduction in CO emissions are expected by 2020 . These controls will help reduce ambient concentrations of ozone, CO, and fine PM . Point Source Emission Reductions Kentucky has determined that creditable emission reductions in VOCemissions have occurred since the early 1990s. The Paducah Area achieved the following point source emission reductions between 1990 and 2000 . Documentation for these applicable facilities is provided as follows: Air Products and Chemicals - 21-157-00009 As the result ofan Agreed Order (DAQ-95112) with the Kentucky Division for Air Quality and Air Products and Chemicals, the company since 1990 has reduced its VOC emissions. Any permanent and enforceable emission reductions are reflected in the emissions presented in this document .Reasonably Available ControlMeasures (RACM)

401 KAR 50:012, Section 1(2) requires that all major air contaminant sources shall as a minimumapply control procedures that are reasonable, available, and practical ." See Appendix Kfor the full text of 401 KAR50:012. Maximum

Available Control Technology (MACT) The Clean Air Act requires U .S. EPAto reviewand update its lists of categories of industries that emit one or more of 188 listed toxic air pollutants, or Hazardous Air Pollutants (HAPS) . For listed categories of major industrial sources, the lawrequires U .S. EPA to develop standards requiring those industries to achieve emission reduction equivalent to putting into place what is known as "maximumachievable control technology" (MACT) . Many of the HAPS under these industrial categories ofcontrols are also VOCs, and compliance with these new MACT standards as they are being promulgated will decrease VOC emissions from the affected industries. Additionally, U.S. EPA is now promulgating residual risk requirements for some point and area source categories. These requirements will further reduce VOCemissions. Additional Reductions - NOxSIPCall Reductions Although Kentucky is not claiming credit for these source reductions regarding the attainment status ofthe county, it is important to note ongoing and significant emission trends ofany ozone precursors (ie., NO,) that occurred during the current 2002-2006years ofozone monitoring data. The NOx emission reductions achieved fromthe NOx SIP Call throughout the entire region and the state of Kentucky, effective May 2004, will continue to contribute to the area's continued maintenance ofthe 8-hour ozone standard and future compliance with the ozone NAAQS.In accordance with Kentucky regulation 401 KAR 51 :180, the Division had determined from

Kentucky's compliance supplement pool that electric-generating units (EGUs) had 13,469 tons available for Early Reduction Credits (ERCs) . Of the 13,469 tons for EGUs, 20%(2,694) was available for emission reductions achieved in 2001, 30%(4,041) was available for emission reductions achieved in 2002, and the remaining 50% (6,734) was available for emission reductions in 2003. Per 401 KAR 51 :180, the ERCs were used for compliance with NOx emission standards in 401 KAR 51 :160 during the 2004 and 2005 control period. However, overall the sources in each year requested allowances for a much larger number of ozone season NOx tons reductions. Referring to the graph below, you can compare the annual source reductions to the allowances actually available under the NOx SIP Call . These reductions benefited the nonattainment area and demonstrate on-going NOx emission reductions throughout the state. Graph 4 . 2001-2003 Early Reduction Credits (ERCs) for Sources in Kentucky 25000 20000 Ozone Season 15000 NOx Tons 10000

5000 0 2001 2002 2003

Year

CLEANAIRINTERSTATE RULE 'r "Requested ~ I "Granted

On May 12, 2005, the USEPA promulgated ("Rule To Reduce Interstate Transport of Fine Particulate Matter and Ozone (Clean Air Interstate Rule) ; Revisions to Acid Rain Program ;Revisions to the NOXSIP Call'), referred to as CAIR . This rule established the requirement for states to adopt rules limiting the emissions of NOx and sulfur dioxide (S02) and a model rule for the states to use in developing their programs. The purpose of CAIR is to reduce interstate transport ofprecursors offine particulate and ozone. CAIR applies to (1) any stationary, fossil-fuel-fired boiler or stationary, fossil-fuel-fired 

### combustion turbine serving at any time, since the start-up of a unit's combustion chamber, a generator with nameplate capacity of more than 25 MWe producing electricity for sale and (2) for a unit that qualifies as a cogeneration unit during the 12-month period starting on the date that the unit first produces electricity and continues to qualify as a cogeneration unit, a cogeneration unit serving at any time a generator with nameplate capacity of more than 25 MWe and supplying in any calendar year more than one-third of the unit's potential electric output capacity or 219,000MWh, whichever is greater, to anyutility power distribution systemfor sale. This rule provides annual state caps for NOx and S02 in two phases, with the Phase I caps for NOx and S02starting in 2009 and 2010, respectively. Phase II caps become effective in 2015. The USEPA is allowing the caps to be met through a cap and trade programif a state so chooses to participate in the program . Kentucky chose to continue the non-EGUs previously included in the NOx SIP seasonal program in the seasonal CAIRprogram . In response to the USEPA's CAIR, Kentucky developed rules to implement CAIR . Under the rule, Kentucky has caps as follows: " Annual NOx: 83,205 tons for 2009-2014and

69,337 tons for2015 and each year thereafter;" Ozone season NOx: 36,109 tons for 2009-2014and 30,651 tons for 2015 and each yearthereafter; " Annual S02

: 188,773 tons for 2010-2014and 132,141 tons for 2015 and each year thereafter. The State's NOx allocations have been distributed based on allocation methodologies in 401 KAR52:210 and 220

. USEPAwill determine the S02 allocations, which are based on the acid rain program

. The Kentucky CAIRregulations became effectiveJune 13, 2007. Area Source Reductions 

### Several control programs have been implemented to substantially reduce area source emissions . fromthe following source categories. Aerosol Coatings, Architectural and Industrial Maintenance Coatings, and Commercial/Consumer Products In 1998 the U

.S. EPAoffered a guidance document promulgating federal regulations to reduce the VOCemissions fromthe application of Architectural and Industrial Maintenance Coatings (e.g. traffic paints and coatings for bridges), Auto Body Refinishing, and Commercial Consumer Products. At that time a 20%reduction was allowed, and these are the reductions included in the projections in this submittal . On May 30, 2007, the EPA published a memorandumto provide guidance concerning credit that States can take for reductions associated with three Federal rules being promulgated this calendar year under authority of section 183 (e) ofthe CleanAir Act (see Appendix J) . These rules will establish or amend VOC content limits for (1) aerosol coatings(newrule), architectural and industrial maintenance (AIM) coatings (amendments), and (3)

household and institutional consumer products (amendments) . EPAestimates that the amended Federal AIM

rule will achieve a reduction of 31% fromthe post-1998 Federal rule baseline. The amount of reduction from the Commercial/Consumer Product emission reduction credit was calculated at 29%

. The compliance date for the three Federal rules will beJanuary 1, 2009. This will reduce the VOCemissions in the area further documentation of continued maintenance of the standard in the area. Non-Highway Mobile Source Reductions Certain federal rules have been implemented since the early 1990s that have resulted in permanent and enforceable emission reductions from nonroad sources (e.g., small engines, construction equipment) . The reductions were determined using the U .S. EPA's Nonroad model and are reflected in the emissions provided in this document . Until the mid-1990s, emissions fromnon-highway engines were largely uncontrolled. The nonhighway category includes outdoor power equipment, recreational vehicles (ie., scooters, mopeds, all-terrain bikes, snowmobiles, etc.), marine vessels, personal watercraft, farm and construction machinery, lawn and garden equipment, locomotives, and many other applications. Certain federal rules have been implemented since the early 1990's that have resulted in permanent and enforceable emission reductions fromthese nonroad sources. Implemented during the 2002-2005 timeframe were: Small spark-ignition engines - This set of emissions standards for handheld applications (such as leaf blowers and chainsaws) phases in 2002 - 2007 and will result in an additional 70 percentreduction in hydrocarbons and NO,.

Large spark-ignition engines - In 2004, these emission standards began phasing in to reduce NOx and COfor many applications of industrial equipment, including forklifts, airport service equipment, generators, compressors, and welders. Locomotives - The Tier 1 emissions standards apply to locomotives and locomotive engines manufactured from2002 through 2004, and will reduce NO, emissions by two thirds as new engines are placed in service. Land-based diesel engines - More stringent standards to reduce NO, emissions apply to all engine sizes and are being phased in between 2001 - 2006. Included in this change is construction equipment such as backhoes, agricultural equipment such as tractors, material handling equipment such as heavy forklifts, industrial equipment such as airport service vehicles, and utility equipment such as generators and pumps. In addition, nonroad diesel rules also reduce the allowable sulfur in nonroad diesel fuel by over 99% . Nonroad diesel fuel currently averages about 3,400 ppmsulfur. The rule limits nonroad diesel sulfur content to 500 ppmin 2006 and 15 ppmin 2010 . The combined engine and fuel rules will reduce NOx and PM emissions fromlarge nonroad diesel engines by over 90%, compared to current nonroad engines using higher-content sulfur diesel . These reductions were determined using the U .S. EPA's nonroad model and are reflected in the emissions provided in this document (Appendix G) .TABLE 3 PADUCAH8-HOUR OZONE MAINTENANCE AREA VOCEMISSIONS FOR1990, 2002, &2004

(TONS PERDAY)

SOURCE CATEGORY 1990 ATTAINMENT YEAR 2002 NEW PLAN 2004

LAST YEAR OLDPLAN POINT 96.47 67.90 85.58 AREA 1 .85 2 .28 1 .93 HIGHWAY MOBILE 5.23 2.16 3.17 NON-HwY MOBILE 1 .29 5.12 1 .34 TOTAL EMISSIONS 104.84 77.47 92.02

Table 2 summarizes VOCemissions in tons per day (tpd), from1990 and 2002, and also includes any growth in emissions that may have occurred since the 1990 attainment year. In addition, included in the Table 2 emissions are any permanent and enforceable emission reductions achieved in the area. MAINTENANCE PLAN The maintenance plan includes an emissions inventory for the year 2002, projected inventories through 2020, a commitment to maintain the existing monitoring system, and contingency measures that will become effective should the area fail to continue to maintain the 8-hour ozone standard. 2002 MAINTENANCE AREA EMISSIONS INVENTORY As the part of this SIP revision, a newozone precursor emissions inventory for 2002 was developed for Marshall County and a portion of Livingston County. A copy of the 2002 maintenance area emissions inventory methodology and documentation is included as Appendix 14C

. This 2002 emissions inventory reflects any emission controls applicable for the area. The 2002 emissions inventory was developed in accordance with EPAguidance as follows: (1) utilizing where feasible EPA's Emissions Inventory Improvement Program and EPA National Emission Inventory (NEI) guidance. As recommended in EPA's NEI development guidance, where applicable the FAA's Emission and Dispersion and Modeling Systemmodel was utilized to calculate commercial aircraft emissions for 2002, 2005, 2008, 2011, 2014, 2017, 2020, EPA's Nonroad Model (Core Model Version 2005a, February, 2006) was used to determine certain other nonroad (i .e., other Non-Highway) mobile source category emissions for 2002, 2005, 2008, 2011, 2014, 2017 and 2020, MOBILE 6

.2 was utilized to determine highway mobile source emissions for 2002, 2005, 2008, 2011, 2014, 2017 and 2020, and the U .S. EPA's 1997 biogenic emission estimates for Kentucky counties were included in the 2002 emissions inventory per EPAguidance; (2) utilizing where applicable previous EPAemission inventory guidance; and (3) utilizing inventory guidance obtained directly fromEPA Region 4personnel (e.g., phone calls, e-mails) . EMISSION PROJECTION METHODOLOGY The 2002 Maintenance Area Emissions Inventory for Marshall County and a portion of Livingston County was used to project emissions into the future. Kentucky believes this inventory to be a comprehensive inventory of actual emissions for the area with the best basis for which to make any future projections.Tables detailing the category projection inventory that predicts emissions for VOC, CO, and NO,,

for years 2005, 2008, 2011, 2014, 2017 and 2020 are included for the Paducah Area in Appendix D . Biogenic emissions have been excluded fromthese tables. Biogenic emissions for 2002 can be found in Appendix C . Based on information received from EPA, biogenic emissions are expected to remain stable throughout the projection period. Tables 3-5 showthe projection of emissions through 2020 . The Paducah Area's projected 2020 total VOC emissions are well below the 2002 total VOC emissions, thus demonstrating continued maintenance of the 8-hour ozone standard. The significant decrease in total VOC emissions offsets an increase in total NOx emissions. TABLE 4 PADUCAH8-HOUR OZONE MAINTENANCE AREA 1990, 2002, ANDPROJECTEDVOCEMISSIONS

(TONS PERDAY) 1990-2020 COUNTY 1990 2002 2005 2008 2011 2014 2017 2020 POINT 0

.00 0

.00 0.00 0

.00 0

.00 0

.00 0

.00 0

.00 AREA 0.09 0 .14 0

.14 0.14 0

.14 0

.14 0

.14 0

.14 HIGHWAY 0

.20 0

.09 0

.07 0.06 0

.05 0

.04 0

.04 0

.04 Norr-HwY 0

.05 0

.25 0

.23 0

.21 0.19 0

.17 0

.17 0

.16 LIVINGSTON 0

.34 0

.49 0

.44 _ 0

.41 0

.38 0

.35 0

.35 0

.34 POINT 96.47 67.90 70.62 73.48 75.66 78.46 81 .36 84.34 AREA 1 .76 2.14 2 .16 2.22 2.25 2 .28 2.31 2

.36 HIGHWAY 5.03 2.07 1 .55 1 .41 1 .27 1 .10 1 .00 0 .90 Norr-HwY 1 .24 4.87 5.42 5.42 5.11 4.66 4.10 3.70 MARSHALL 104.50 76 .98 79.75 82.53 84.29 86.50 88.77 91 .30 TOTAL 104.84 77.47 80.19 82.94 84.67 86.85 89.12 91 .64 *Portion of county.TABLE 5 PADUCAH8-HOUR OZONE MAINTENANCE AREA 1990, 2002, ANDPROJECTEDCOEMISSIONS

(TONS PER DAY) 1990-2020 COUNTY 1990 2002 2005 2008 2011 2014 2017 2020 POINT 0

.00 0

.00 0

.00 0

.00 0

.00 0

.00 0

.00 0

.00 AREA 0

.00 0

.08 0

.08 0

.08 0

.08 0

.08 0

.08 0

.08 HIGHWAY 1 .13 1 .17 0 .81 0

.71 0

.66 0

.61 0

.58 0

.58 Nolv-HwY 0

.28 0

.72 0

.71 0

.69 0

.67 6

_ .66

__6

._66 0

.66 LIVINGSTON 1.41 1.97 1 .60 1.48 1 .41 1 .35 1 .32 1.32 POINT 13.49 2 .04 2

.12 2.20

_ 2

.25 2.36 2.44 2.52 AREA 1 .48 1 .73 1 .76 i.78

__ 1

_ .83

__

1

_ .85

_1

_

.88 1 .91 HIGHWAY 28.85 27.59 19.35 17.36 16.26 15.13 14.73 14.68 NON-Hwy 645 16.31 18.09 19.29 20 . 10 5

.48 --Y-

0 .61 -20

.81 MARSHALL 11 S 50.27 47.67 41 .32 40.63 40.44 9 .8-2 _j9-

.66 39

.92 TAL TO .51.68 49.64 42.92 42.11 41 .85 41 .17 40.98 41 .24 *Portion of county. TABLE 6 PADUCAH8-HOUR OZONE MAINTENANCE AREA 1990, 2002, ANDPROJECTEDNO, EMISSIONS

(TONS PERDAY) 1990-2020 COUNTY 1990 2002 2005 2008 2011 2014 2017 2020 POINT 0

.00 0

.00 0

.00 0

.00 0

.00 0

.00 0

.00 0

.00 AREA 0.00 0 .01 0

.01 0

.01 0

.01 0

.01 0

.01 0

.01 HIGHWAY 0

.14 0

.17 0

.14 0

.12 0

.10 0

.07 0

.06 0

.05 NON-HwY 0

.03 0

.07 0

.07 0

.07 0

.06 0

.06 0

.05 0

.05 LIVINGSTON 0

.17 0

.25 0

.22 0

.20 0

.17 0

.14 0

.12 0

.11 POINT 5.88 3.03 3.15 3.28 3.39 3.50 3.62 3.76 AREA 0

.11 0

.13 0

.13 0.13 0

.14 0

.14 0

.14 0

.14 HIGHWAY 3.68 4 .04 3.22 2.88 2.39 1 .83 1 .45 1 .22 NON-HwY 1 .31 0 .95 0

.93 0

.87 0

.80 0

.72 0

.65---6

- .59 MARSHALL 10

.98 8.15 7.43 7.16 6 .72 6

.19 5

.86 5.71 TOTAL 11 .15 8.40 7.65 7.36 6 .89 6

.33 5

.98 5.82 *Portion of county.The emissions inventory is broken down into four components: point, area, highway mobile, and

non-highway mobile sources. Using 2002 as the new base emissions year, the subsequent years were chosen at three-year or longer intervals that project maintenance for at least a 10-year period pending approval of the revision to the SIP . Necessary calculations for the projections were made using EXCEL software. A description of howgrowth factors for each emission category were obtained and used follows. The documentation showing howemissions were grown is included in Appendices E through H . Point Source Projections For this inventory purpose, point sources are defined as stationary sources that emit 10 tons or more per year (tpy) ofVOC, or 100tpy or more of NO, or CO . Emissions are calculated from data collected annually frompoint sources. Point source information is stored in an existing Kentucky TEMPOdatabase and certain information fromthis database has been provided for the U .S. EPA's NEI . Utilizing Standard Industrial Codes (SIC), all point source emission projections were based on growth factors calculated using Bureau of Economic Analysis (BEA) projection data for employment, as suggested by the U.S. EPA and utilized for previous point source projections. The point source data provided SICcodes used to determine a short title description that matched the corresponding description found in the BEAdata. The application of growth factors for each projection was then used for point sources. Appendix E provides information on howpoint source projections were determined.Area Source Projections

Area sources can be defined as those sources that are generally too small and/or too numerous to be handled individually in the point source inventory. Emissions are estimated by multiplying an emission factor by a known indicator of collective activity such as number of employees or population. For area source emission projections, population growth factors for each chosen year were calculated using an exponential formula in the ExCEL software. The application of these growth factors for each projection was then used for area sources. Information used to calculate growth factors, including population information used to project area sources was provided by the University of Louisville Urban Data Center3 and can be found in Appendix F. Non-Highway Mobile Source Projections The non-highway mobile category is broken down into three groups that include 2 and 4-cycle gasoline engines and diesel engines (other non-highway engines), railroad locomotives, and aircraft. Emissions are estimated by multiplying the base year inventory by a known indicator of collective activity such as fuel consumed or landing/takeoff operations. For locomotive and aircraft emission projections, population growth factors for each chosen year were calculated using the before mentioned formula . The application of these growth factors for each projection was then used for each of these non-highway categories. For other non-highway categories (e.g., industrial equipment, tractors, leaf blowers), the U .S. EPA's nonroad model was used to determine the future year projections. Nonroad model and non-highway projection information can be found in Appendix G . Updated minimumand maximumsummer temperatures and ambient temperatures were utilized for input into the nonroad model . EPA Volume IV mobile source guidance was followed in determining the updated temperature data. Please see 19Appendix Cfor specific temperature documentation.

Highway Mobile Source Projections To calculate highway mobile source emissions, the Division obtained data on Daily Vehicle Miles Traveled (DVMT) and speeds for 2002, 2005, 2008, 2011, 2014, 2017 and 2020 fromthe Kentucky Tranportation Cabinet. The Division ran EPA's MOBILE 6.2 model, the latest highway mobile source emission factor estimation modeling software approved by EPA, to derive appropriate projection year emission factors that were multiplied by the corresponding DVMT to determine the projected highway mobile source emissions. The 1990 mobile emissions were recalculated using the updated MOBILE 6.2 emissions model in order to standardize the comparison of the 1990 numbers with the 2002 and 2020 mobile emissions developed using this model . These data and documentation on howthese projections were performed can be found in Appendix H, including MOBILE 6.2 input and output files used to compute the highway mobile source 2002 emissions and subsequent emission projections. Updated minimum and maximum summer temperatures were used for the highway mobile source calculations (PleaseseeAppendix C for specific temperature information) .

TOTAL OF ALL EMISSIONS It is important to recognize the differences between the 1990 tpd for VOC and the projected tpd for VOCfor the year 2020 . Table 6 that follows shows that the Paducah area projected 2020 VOC emissions are significantly less than the 1990 attainment year VOC emissions. The significant decrease in total VOCemissions offsets an increase in total NOx emissions, thus demonstrating continued maintenance of the 8-hour ozone standard. 20Additionally, the Division for Air Quality anticipates NO,, emission reductions frominternal

combustion engines per Phase Il of the NO, SIP Call . If applicable, Phase lI controls could lower the NO, emissions in the area. TABLE 7 PADUCAH8-HOUR OZONE MAINTENANCE AREA 1990 - 2002 - 2020 PADUCAHEMISSIONS COMPARISONS VOCEMISSIONS (TONS PERDAY) 1990 2002 2020 VOC CO NOX VOC CO NOX VOC CO NOX POINT 96.47 13.49 5.88 67.90 2.04 3.03 84.34 2 .52 3.76 AREA 1 .85 1 .48 0 .11 2.28 1 .81 0 .14 2.50 1 .99 0 .15 HIGHWAY MOBILE 5.23 29.98 3.82 2.16 28.76 4 .21 0

.94 15.26 1 .27 NoN-H WY MoBILE 1 .29 6 .73 1 .34 5.12 17.03 1 .02 3.86 21 .47 0 .64 TOTAL EMISSIONS 104.84 51 .68 11 .15 77.47 49.64 8.40 91 .64 41 .24 5.82

PLAN TO MAINTAINAIRQUALITY The Commonwealth of Kentucky and U .S. EPA have instituted programs that will remain enforceable and are hereby submitted as a plan to maintain air quality, which meets the NAAQS for the 8-hour ozone standard. Sources are prohibited fromreducing emission controls following the redesignation ofthe area. " All new

major VOCor NOx sources locating in Kentucky shall as a minimum apply control procedures that are reasonable, available, and practical ; " All major modifications to existing major VOC or NOx sources are subject to RACT requirements as well as the BACT requirement of the DAQPSD regulations; " Federal Motor Vehicle Control Standards apply in Kentucky; 21" Prevention ofSignificant Deterioration requirements;

" Federal Controls on certain nonroad engines (e.g. diesel and other fuel requirements, industrial diesel equipment, locomotives) after 2000; " Federal controls on the VOCcontent for Architectural and Maintenance Paints, Auto Body Shops, and Consumer Products; " The state open burning regulation to further limit types of burning in the former 1-Hour Maintenance area-Paducah.

In addition to these measures, further reductions will be achieved throughout the continued implementation of newfederal regulations to further control the emission of Hazardous Air Pollutants that are VOCs (40 Code ofFederal Regulations 63, NESHAPS) . Also, on March 10, 2005, the U

.S. EPAfinalized the Clean Air Interstate Rule (CAIR) . NOx emissions frompower plants will be cut by 1 .7 million tons by 2009 and emissions will be reduced by 1 .3 million tons in 2015 in 28 eastern states and the District of Columbia. These reductions cannot be quantified at this time, but will be reflected in future assessments. EXISTING MONITORING NETWORK In addition to the maintenance plan discussed above, the existing ozone monitoring network located within the Paducah Area has been approved by the U.S. EPA . The monitoring network will continue to remain operational in accordance with 40 CFRPart 58. CONTINGENCY MEASURES Future reviews ofactual emissions for this former maintenance area will be performed using the latest emission factors, models, and methodologies in accordance with the Consolidated Emissions Reporting Rule (CERR) . For these periodic inventories, the Commonwealth will review the assumptions made for the purpose of the maintenance demonstration concerning 22projected growth of activity levels. If any of these assumptions appear to have changed

substantially, the Commonwealth will re-project emissions. In the event that exceedances of the 8-hour ozone standard are measured in any portion of the maintenance area, or if periodic emission inventory updates reveal excessive or unanticipated growth greater than 10%in ozone precursor emissions, the state will evaluate existing control measures to see if any further emission reduction measures should be implemented at that time. In the event of a monitored violation ofthe 8-hour ozone standard in this maintenance area, the Commonwealth commits to adopt, within nine months, one or more ofthe following contingency measures to re-attain the standard. All regulatory programs will be implemented within 18 months. " Implementation of a program to require additional emission reductions on stationary sources; " Requirement for Stage I Vapor Recovery; " Requirement for Stage II Vapor Recovery; " Open burning ban during summer ozone season; " Restriction ofcertain roads or lanes to, or construction ofsuch roads or lanes for use by, passenger buses or high-occupancy vehicles; " Trip-reduction ordinances; " Employer based transportation management plans, including incentives; " Programs to limit or restrict vehicle use in downtown areas, or other areas ofemission concentration, particularly during periods of peak use; " Programs for newconstruction and major reconstructions of paths or tracks for use by pedestrians or by non-motorized vehicles when economically feasible and in the public interest . The Commonwealth also reserves the right to implement other contingency measures if new control programs should be developed and deemed more advantageous for the area.PUBLIC PARTICIPATION

Kentucky has scheduled a public hearing to receive comments on this proposed SIP revision for the Paducah Area onJanuary22, 2008, at the Kentucky Division for Air Quality's Central Office located at 803 Schenkel Lane, in Frankfort, Kentucky. A copy of the public hearing notice is included in Appendix I .REFERENCES

1 . November 6, 1991, FederalRegister Notice. Final designation of the Paducah Area (i .e., Marshall County and a portion of Livingston County) for the Ozone Standard. 2. February 7, 1995, Federal Register Notice. Approval of Redesignation to Attainment the Paducah Area - Effective on April 10, 1995. August 20, 2001, FederalRegister Notice. Approval of Revision to 1-hour Maintenance Plan - Correct/Revise Motor Vehicle Emissions Budgets (MVEBs) for the PaducahArea - Effective on October 19, 2001 . 3. University of Louisville - State Data Center - Population Projections for Kentucky.