OZONE MAINTENANCE PLAN SIP REVISION FOR 

THE 

PADUCAH 

8-HOUR OZONE ATTAINMENT 

1 HOUR OZONE MAINTENANCE AREA 

Prepared by the 

KENTUCKY DIVISION FOR AIR QUALITY 

Submitted by 

KENTUCKY ENVIRONMENTAL AND PUBLIC PROTECTION CABINET 

November 2007 
TABLE OF CONTENTS 

INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1 

BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1 

MAINTENANCE OF AIR QUALITY STANDARD . . . . : . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 

PERMANENT AND ENFORCEABLE 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 of All Emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .20 

PLAN TO MAINTAIN AIR QUALITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .21 

EXISTING MONITORING NETWORK. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .22 

CONTINGENCY MEASURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .22 

PUBLIC PARTICIPATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24 

REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25 
APPENDICES 

A- Ambient Air Quality Monitoring Information 

B- Map of Area 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-Highway Mobile 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 KAR 50:012 . General Application 
TABLE SUMMARY 

TABLEI-SUMMARYOFOZONEEXCEEDANCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . """"""""""""""""""""""""""""""" 2 

TABLE 2-PADUCAHAREA MONITOR DESIGN VALUES . . . . . . . . . . . . . . . . . . . . . . . . . . """"""""""""""""""""""" 3 

TABLE 3 - 1990 & 2002 VOC EMISSIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 

TABLE4-PROJECTEDVOCEMISSIONS . . . . . . . . . . . . . . . . . . . . . . """""""""""""""""""""""""""""""""""""""""""" 16 

TABLE 5- PROJECTED CO EMISSIONS . . . . . . . . . . . . . . . . . . . . . . . """""""""""""""""""""""""""""""""""""""""""""" 17 

TABLE 6-PROJECTED NOXEMISSIONS . . . . . . . . . . . . . . . . . . . . . """""""""""""""""""""""""""""""""""""""""""""" 17 

TABLE 7-1990-2002-2020EMISSIONS COMPARISONS . . . . . . . . . . . . . . . . . . . . . . """""""""""""""""""""" 21 
INTRODUCTION 

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 of the 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 of certain permanent and enforceable reductions in ozone precursor emissions in 

the area, and a maintenance plan that continues to show an emissions level that runs through 

2020. 

BACKGROUND 

In accordance with the Clean Air Act Amendments (CAAA) of 1990, Marshall County and a 
portion of Livingston County of the 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 

Paducah Area from marginal 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 AIR QUALITY 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 PADUCAH MAINTENANCE 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 

PADUCAH AREA MONITOR DESIGN VALUES 

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 A for ozone monitoring 

information for this area). The ambient ozone monitoring data was collected at sites that were 

selected with assistance from the U.S . EPA and are considered to be representative of the 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 of the monitor in Livingston County are included in Appendix B. 

PERMANENT AND ENFORCEABLE 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 from various programs and initiatives. 

The following categories of sources have shown or are expected to show emission 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 from which 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 allow an 

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 of these emission reductions is contained in the highway mobile 

modeling runs (See Appendix H). 

Fleet Turnover of Automobiles 

Permanent and enforceable emission reductions have occurred in the Paducah Maintenance Area 

as a result of fleet turnover of automobiles. 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. 
Lower Reid Vapor Pressure 

The 1990 CAAA mandated that the Reid Vapor Pressure (RVP) of gasoline decrease from 10.5 

pounds per square inch (psi) in 1988, to 9 .0 psi in 1992 during the ozone season. Recent 

guidance from U.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 2 Motor Vehicle Emissions and Fuel Standards 

Permanent and enforceable reductions have occurred through this program. The overall Tier 2 

program focuses 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 from cars 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 and Diesel Highway Vehicles Standards 

New USEPA standards designed to reduce NOx and VOC emissions from heavy-duty gasoline 

and diesel highway vehicles began to take effect in 2004. A second phase of standards and 
testing 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 ppm since 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 low sulfur diesel, compared to existing engines using higher-content sulfur 

diesel . 

Large Non road 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 ppm sulfur. The rule limits nonroad 

diesel sulfur content to 500 ppm in 2006 and 15 ppm in 2010. The combined engine and fuel 

rules will reduce NOx and PM emissions from large 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 new standard, 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 of engine or vehicle. 

The large spark-ignition engines contribute to ozone formation and ambient CO and PM levels in 

urban areas. Tier 1 of this standard was implemented in 2004 and Tier 2 is scheduled to start in 
2007. 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 PM levels, 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 VOC emissions 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 of an 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 Control Measures (RACM) 

401 KAR 50:012, Section 1(2) requires that all major air contaminant sources shall as a 

minimum apply control procedures that are reasonable, available, and practical." See Appendix 

K for the full text of 401 KAR 50:012. 

Maximum Available Control Technology (MACT) 

The Clean Air Act requires U.S . EPA to review and 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 law requires U.S . EPA to develop standards 

requiring those industries to achieve emission reduction equivalent to putting into place what is 

known as "maximum achievable control technology" (MACT). Many of the HAPS under these 

industrial categories of controls 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 VOC emissions. 

Additional Reductions - NOx SIP Call Reductions 

Although Kentucky is not claiming credit for these source reductions regarding the attainment 

status of the county, it is important to note ongoing and significant emission trends of any ozone 

precursors (ie., NO,) that occurred during the current 2002-2006 years of ozone monitoring data. 

The NOx emission reductions achieved from the 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 of the 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 

CLEAN AIR INTERSTATE 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 NOX SIP 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 of precursors of fine 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 219,000 MWh, whichever is greater, to any utility power distribution system for sale . 

This rule provides annual state caps for NOx and S02 in two phases, with the Phase I caps for 

NOx and S02 starting 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 program if 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 CAIR program. 

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 2009-2014 and 

69,337 tons for 2015 and each year thereafter ; 
" Ozone season NOx: 36,109 tons for 2009-2014 and 

30,651 tons for 2015 and each year thereafter; 

" Annual S02: 188,773 tons for 2010-2014 and 

132,141 tons for 2015 and each year thereafter. 

The State's NOx allocations have been distributed based on allocation methodologies in 401 

KAR 52:210 and 220. USEPA will determine the S02 allocations, which are based on the acid 

rain program. 

The Kentucky CAIR regulations became effective June 13, 2007. 

Area Source Reductions 

Several control programs have been implemented to substantially reduce area source emissions . 

from the following source categories. 

Aerosol Coatings, Architectural and Industrial Maintenance Coatings, and Commercial/Consumer Products 

In 1998 the U.S. EPA offered a guidance document promulgating federal regulations to reduce 

the VOC emissions from the 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 memorandum to 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) of the Clean Air Act (see 

Appendix J) . These rules will establish or amend VOC content limits for (1) aerosol coatings 
(new rule), architectural and industrial maintenance (AIM) coatings (amendments), and (3) 

household and institutional consumer products (amendments) . EPA estimates that the amended 

Federal AIM rule will achieve a reduction of 31% from the 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 be January 1, 2009. This 

will reduce the VOC emissions 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 from non-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 from these 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 percent 
reduction in hydrocarbons and NO, . 

Large spark-ignition engines - In 2004, these emission standards began phasing in to reduce 

NOx and CO for 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 from 2002 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 ppm sulfur . The rule limits nonroad diesel sulfur content to 500 ppm in 

2006 and 15 ppm in 2010. The combined engine and fuel rules will reduce NOx and PM 

emissions from large 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 

PADUCAH 8-HOUR OZONE MAINTENANCE AREA 

VOC EMISSIONS FOR 1990, 2002, & 2004 

(TONS PER DAY) 

SOURCE CATEGORY 

1990 

ATTAINMENT YEAR 

2002 

NEW PLAN 

2004 

LAST YEAR 

OLD PLAN 

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 VOC emissions in tons per day (tpd), from 1990 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 new ozone 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 

14 
C. This 2002 emissions inventory reflects any emission controls applicable for the area. The 

2002 emissions inventory was developed in accordance with EPA guidance 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 System model 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 EPA guidance; 

(2) utilizing where applicable previous EPA emission inventory guidance; and 

(3) utilizing inventory guidance obtained directly from EPA Region 4 personnel (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 from these 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 show the 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 

PADUCAH 8-HOUR OZONE MAINTENANCE AREA 

1990, 2002, AND PROJECTED VOC EMISSIONS 

(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 .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 

PADUCAH 8-HOUR OZONE MAINTENANCE AREA 

1990, 2002, AND PROJECTED CO EMISSIONS 

(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 

S 11 

50.27 47.67 41 .32 40.63 40.44 9.8-2 _j9-.66 39.92 

TO TAL .51.68 49.64 42.92 42.11 41 .85 41 .17 40.98 41.24 

*Portion of county. 

TABLE 6 

PADUCAH 8-HOUR OZONE MAINTENANCE AREA 

1990, 2002, AND PROJECTED NO, EMISSIONS 

(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 0.01 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 how growth factors for each emission 

category were obtained and used follows. The documentation showing how emissions 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) of VOC, or 100 tpy or more of NO, or CO. Emissions are calculated from 

data collected annually from point sources. Point source information is stored in an existing 

Kentucky TEMPO database and certain information from this 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 SIC codes used to determine a short title description that matched 

the corresponding description found in the BEA data. The application of growth factors for each 

projection was then used for point sources. Appendix E provides information on how point 

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 Center 3 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 minimum and maximum summer 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 

19 
Appendix C for 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 from the 

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 how these 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 (Please see Appendix 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 VOC for 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 VOC emissions offsets an increase in total NOx 

emissions, thus demonstrating continued maintenance of the 8-hour ozone standard . 

20 
Additionally, the Division for Air Quality anticipates NO,, emission reductions from internal 

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 

PADUCAH 8-HOUR OZONE MAINTENANCE AREA 

1990 - 2002 - 2020 PADUCAH EMISSIONS COMPARISONS 

VOC EMISSIONS 

(TONS PER DAY) 

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 MAINTAIN AIR QUALITY 

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 from reducing emission controls following 

the redesignation of the area. 

" All new major VOC or 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 DAQ PSD regulations ; 

" Federal Motor Vehicle Control Standards apply in Kentucky; 

21 
" Prevention of Significant 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 VOC content 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 new federal regulations to further control the emission of Hazardous Air 

Pollutants that are VOCs (40 Code of Federal Regulations 63, NESHAPS) . Also, on March 10, 

2005, the U.S. EPA finalized the Clean Air Interstate Rule (CAIR). NOx emissions from power 

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 CFR Part 58 . 

CONTINGENCY MEASURES 

Future reviews of actual 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 

22 
projected 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 of the 8-hour ozone standard in this maintenance area, the 

Commonwealth commits to adopt, within nine months, one or more of the 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 of certain roads or lanes to, or construction of such 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 of emission 

concentration, particularly during periods of peak use; 

" Programs for new construction 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 on January 22, 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, Federal Register 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, Federal Register Notice. Approval of Revision to 1-hour Maintenance 

Plan - Correct/Revise Motor Vehicle Emissions Budgets (MVEBs) for the Paducah Area 

- Effective on October 19, 2001 . 

3 . University of Louisville - State Data Center - Population Projections for Kentucky.