Steven L. Beshear 

Governor 

James I. Palmer, Jr. 

Regional Administrator 

U.S. EPA, Region 4 

Atlanta Federal Center 

6 1 Forsyth Street, SW 

Atlanta, Georgia 30365 

ENERGY AND ENVIRONMENT CABINET 

Capital Plaza Tower 

500 Mero Street, I zth lo or 

Frankfort, Kentucky 40601 

Phone: (502) 564-71 92 

Fax: (502) 564-7484 

December 3,2008 

Leonard K. Peters 

Secretary 

Dear Mr. Palmer: 

Enclosed for your consideration is the final revision to Kentucky's State Implementation 

Plan: Kentucky's Attainment Demonstration for areas not meeting the annual PM2.5 Standard. 

These areas include: the Kentucky counties of Jefferson and Bullitt that are part of the Louisville, 

KY-IN PM2.5 Nonattainment Area, the Kentucky counties of Boone, Campbell, and Kenton that 

are part of the Cincinnati-Middletown, OH-KY-IN PM2.5 Nonattainment Area, and the Kentucky 

counties of Boyd and a portion of Lawrence, that are part of the Huntington-Ashland WV-KYOH PM2.5 Nonattainment Area. 

The attainment demonstration, based on modeling performed by the Visibility 

Improvement State and Tribal Association of the Southeast and the Association of Southeastern 

Integrated Planning (VISTASIASIP) provides documentation that each area will attain the 

annual PM2,5 standard by April 5, 2010. Ohio, Indiana, and West Virginia are making separate 

attainment demonstrations for their respective portions of the metropolitan areas and have 

submitted those demonstrations to U.S. EPA, Regions 5 and 3. The Ohio and Indiana 

demonstrations, which also document attainment for the entire nonattainment area, are based on 

modeling performed by LADCO (Lake Michigan Air Directors Consortium). 

A public hearing to receive comments on this revision was held on July 31,2008, at 1 :30 

p.m. EDT at the offices of the Kentucky Division for Air Quality in Frankfort, Kentucky. A 

copy of the public hearing notice and the statement of consideration is included in this submittal. 

An Equal Opportunity Employer M/F/D 
James I. Palmer, Jr. 

Page 2 

Your prompt consideration of this request is appreciated. If you have any questions or 

comments, please contact Mr. John Gowins at the Division for Air Quality at (502) 573-3382. 

Sincerely, 

Leonard K. Peters 

Secretary 

An Equal Opportunity Employer MIFID 
Steven L. Beshear 

Governor 

Leonard K. Peters 

Secretary 

Energy and Environment Cabinet 

Department for Environmental Protection 

Division for Air Quahty 

200 Fair Oaks Lane, 1" Floor 

Frankfort, Kentucky 40601-1403 

May 26,201 1 

Richard Schutt, Chief 

Air Planning Branch, U.S. EPA, Region 4 

Sam Nunn Atlanta Federal Center 

61 Forsyth Street, SW 

Atlanta, Georgia 30303 

RE: Clarification regarding the December 3,2008 Attainment Demonstration for areas not 

meeting the 1997 annual PM2 5 NAAQS 

Dear Mr. Schutt: 

This letter is to clarify the mobile source insignificant finding for the HuntingtonAshland WV-KY-OH area that was included in the PM2.5 attainment demonstration that the 

Kentucky Division for Air Quality (division) submitted to U.S. EPA on December 3, 2008. 

The demonstration compared the mobile emissions (Section 8.0) for the nonattainment 

portion of Lawrence County, to the point, area, and nonroad sectors of the entire county 

(Section 3.5). Based on guidance from Region 4, the division has revised the emissions from 

all sectors to reflect the Kentucky portion of the nonattainment area and provided a summary 

of the percentage of mobile emissions in Table 1. The differences are miniscule due to the 

large contribution of emissions from the Big Sandy power plant. 

Table 1 

( 2002 1 2002 Partial 1 Difference 1 2009 1 2009 Partial 1 Difference 

KY MobileKY Portion 

KY MobilelEntire 

6.58% 

KY MobileKY Portion 

KY MobileIEntire 

KY MobileKY Portion 

KY MobileIEntire 

Nonattainment 

6.75% 

0.10% 

2002 

1.30% 

0.40% 

0.17% 

0.14% 

2002 Partial 

1.43% 

0.43% 

7.10% 

0.04% 

Difference 

0.13% 

0.03% 

7.43% 

0.02% 

0.33% 

2009 

0.90% 

0.20% 

0.02% 0.00% 

2009 Partial 

0.97% 

0.18% 

Difference 

0.07% 

-0.02% 
Mr. Richard Schutt 

May 26,201 1 

Page 2 

The division has attached updated Tables 8.2-3 to 8.2-5 to provide a detail of the 

emissions inventory for the nonattainment portion of Lawrence County. Columns have been 

added to the tables to indicate the emissions of the nonattainment area for point, area, and 

nonroad sectors and then a revised emissions total has been added to the end of the table. 

The point sector emissions for the nonattainment area were determined by removing those 

facilities that are located outside the nonattainment area. The area and nonroad emissions of 

the nonattainment were updated based on a population apportionment. The population of the 

census tract is 1,050 and the population of the entire county is 15,569. Therefore, the census 

tract of the nonattainment area is 7% of the population of the county, and the area and 

nonroad emissions in the nonattainment area were reduce to 7.0% of the entire county 

emissions. 

As stated earlier, the differences in emissions are inconsequential, and continue to 

support a finding of insignificance for mobile emissions budgets. If you have any questions 

or comments concerning this matter, please contact Andrea Smith with the Division for Air 

Quality at (502) 564-3999. 

Enclosures 

c: Beverly Banister 

Royce Dansby-Sparks 
Table 8.2-3 Huntington Ashland 2002 and 2009 NOx Emissions Inventory (tons per year) 

NOx 2002 NOx 2009 

Pomt Pomt Nonatt Area b 

WEST VTRGINlA 

WV Total 

Lawrence 

(OH Total 

l~otal Emissions 

Revised 051251201 1 
Table 8.2-4 Huntington Ashland 2002 and 2009 SOX Emissions Inventory (tons per year) 

Mason 85418 119 32 83 85652 56691 122 4 14 56830 

Wayne 288 479 48 162 977 277 517 5 34 832 

WV Total 85830 2018 203 356 88407 57091 2167 2 1 66 59345 

OHIO 

Adam 137,241 43 44 45 137373 22422 55 4 8 22489 

Galha 106,286 37 42 45 106410 2 1807 50 4 8 2 1869 

Lawrence ------~ 0 70 112 86 268 0 94 11 15 120 

Sc~oto 25 77 96 137 335 918 108 9 25 1060 

OH Total 243552 227 294 313 244386 45 147 307 28 56 45538 

Total Emlss~ons 387966 64 2883 58098 123641 392666 91 392,497 160,408 62 3,153 50 5925 55436 164,175 72 164,030 

Revised 051251201 1 
Revised 05/25/201 I 

Table 8.2-5 Huntington Ashland 2002 and 2009 PM Emissions Inventory (tons per year) 

WEST VIRGINIA 

Cabell 

Mason 

Wayne 

WV Total 

OHIO 

Adams 

Galha 

Lawrence 

Scloto 

OH Total 

Total Em~sslons 

319 

23 7 

50 

607 

952 

670 

0 

30 

1652 

3849 86 

865 

391 

523 

1779 

315 

226 

163 

337 

1041 

3748 46 

48 

12 

18 

79 

17 

16 

3 8 

36 

107 

221 06 

82 

70 

125 

277 

25 

22 

36 

71 

154 

592 19 

1315 

710 

717 

2743 

1309 

934 

237 

474 

2954 

841 1 57 8,lM 

339 

287 

54 

680 

3696 

3905 

2 

92 

7695 

10,043 39 

857 

380 

485 

1722 

323 

230 

165 

339 

1057 

3,746 17 

3 1 

9 

11 

50 

12 

11 

26 

24 

73 

148.38 

74 

60 

114 

248 

20 

19 

29 

60 

128 

525 

1301 

73 5 

664 

2701 

405 1 

4165 

222 

515 

8953 

14,462 941 14,220.QI