!!!� 

Protection Agency 

AUG 11 2015 

Ms. Susan Hedman 

Regional Administrator 

U.S. EPA, Region 5 

77 West Jackson Blvd. 

Chicago, Illinois 60604 

John R. Kasich, Governor 

Mary Taylor, Lt. Governor 

Craig W. Butler, Director 

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

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

Standard Nonattainment Area 

Dear Administrator Hedman: 

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

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

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

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

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

nonattainment area. The enclosed submittal combines the redesignation request and 

the required maintenance plan for this area. 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

not contribute to monitored or modeled violations in the area. 

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

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

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

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

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

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

http://ww.epa.ohio.gov/dapc/SI P/so2.aspx under the heading "Redesignations and 

Maintenance Plans." 

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

Control at (614) 644-3696. 

Sincerely, 

Craig Butler 

Director 

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

Enclosure 
REDESIGNATION REQUEST AND

MAINTENANCE PLAN FOR

THE OHIO PORTION OF THE 

CAMPBELL-CLERMONT COUNTIES,

KY-OH 1-HOUR SO2

NONATTAINMENT AREA

Partial Clermont County, Ohio

Prepared by:

Ohio Environmental Protection Agency

Division of Air Pollution Control

August 2015
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TABLE OF CONTENTS

CHAPTER ONE: Introduction......................................................................................... 1

History ......................................................................................................................... 1

Geographical Description and Background ................................................................. 2

Status of Air Quality..................................................................................................... 2

CHAPTER TWO: Requirements for Redesignation......................................................... 3

1. Attainment of the standard (CAA Section 107(d)(3)(E)(i)) .................................... 3

2. Approved SIP for the area under CAA Section 110(k) (CAA Section 

107(d)(3)(E)(ii))..................................................................................................... 4

3. Permanent and enforceable improvement in air quality (CAA Section 

107(d)(3)(E)(iii)).................................................................................................... 4

4. Maintenance plans (CAA Section 107(d)(3)(E)(iv)) .............................................. 4

5. Section 110 and Part D requirements (CAA Section 107(d)(3)(E)(v)) .................. 5

a. Section 110(a) requirements........................................................................... 5

b. Part D requirements........................................................................................ 6

i. Section 172(c) requirements........................................................................... 6

ii. Conformity ................................................................................................. 7

CHAPTER THREE: SO2 Monitoring................................................................................ 9

Requirement 1 of 4: A demonstration that the NAAQS for 1-hour SO2, as published in 

40 CFR 50.17, has been attained................................................................................ 9

Requirement 2 of 4: Ambient monitoring data quality assured in accordance with 40 

CFR 58.10, recorded in the AQS database, and available for 

public view. ................................................................................................................ 10

Requirement 3 of 4: A commitment that once redesignated, the state will continue to 

operate an appropriate monitoring network to verify the 

maintenance of the attainment status........................................................................ 11

Requirement 4 of 4: Supplemental U.S. EPA-approved air quality modeling to show 

monitors are located in the area of maximum concentration. .................................... 11

CHAPTER FOUR: Emission Inventory.......................................................................... 16

Requirement 1 of 4: A comprehensive emission inventory of SO2 completed for the 

base year and a projection of the emission inventory to a year at 

least 10 years following redesignation....................................................................... 16

Requirement 2 of 4: A demonstration that the projected level of emissions is sufficient 

to maintain the SO2 standard..................................................................................... 18

Requirement 3 of 4: A demonstration that improvement in air quality between the 

year violations occurred and the year attainment was achieved is 

based on permanent and enforceable emission reductions and 

not on temporary adverse economic conditions or unusually 

favorable meteorology. .............................................................................................. 20

Requirement 4 of 4: Provisions for future annual updates of the inventory to enable 
tracking of the emission levels, including an annual emission 

statement from major sources. .................................................................................. 23

Requirement 1 of 6: Section 172(c)(1) of the 1990 Clean Air Act Amendments 

requires states with nonattainment areas to implement RACM 

and RACT.................................................................................................................. 24

Requirement 2 of 6: Section 172(c)(2) of the 1990 CAA Amendments requires 

attainment demonstration SIPs for nonattainment areas to show 

RFP. .......................................................................................................................... 25

Requirement 3 of 6: Section 172(c)(3) requires states to submit a comprehensive 

inventory of actual emissions..................................................................................... 25

Requirement 4 of 6: Evidence that control measures required in past SO2 SIP 

revisions have been fully implemented. ..................................................................... 26

Requirement 5 of 6: Acceptable provisions to provide for new source review. ......... 27

Requirement 6 of 6: Assure that all existing control measures will remain in effect 

after redesignation unless the state demonstrates through 

modeling that the standard can be maintained without one or 

more control measures. ............................................................................................. 28

CHAPTER SIX: Contingency Measures........................................................................ 28

Requirement 1 of 4: A commitment to submit a revised plan eight years after 

redesignation. ............................................................................................................ 29

Requirement 2 of 4: A commitment to expeditiously enact and implement additional 

contingency control measures in response to exceeding 

specified predetermined levels (triggers) or in the event that 

future violations of the ambient standard occur. ........................................................ 29

Requirement 3 of 4: A list of potential contingency measures that would be 

implemented in such an event. .................................................................................. 30

Requirement 4 of 4: A list of SO2, sources potentially subject to future additional 

control requirements.................................................................................................. 32

CHAPTER SEVEN: Public Participation........................................................................ 33

CHAPTER EIGHT: Conclusions.................................................................................... 34
FIGURES

Figure 1 Map of the Campbell-Clermont KY-OH nonattainment area and monitor 

location ...............................................................................................................9

Figure 2 2012 to 2014 Walter C. Beckjord and William H. Zimmer hourly emissions 

with hourly SO2 monitoring data ............................................................. 13

Figure 3 2014 Walter C. Beckjord and William H. Zimmer hourly emissions with 

hourly SO2 monitoring data......................................................................14

Figure 4 Walter C. Beckjord SO2 emissions by unit and entire facility ...................21

Figure 5 Walter C. Beckjord SO2 emissions for units B005 and B006 in 2014.......22

TABLES

Table 1 Monitoring data for the Campbell-Clermont KY-OH area for 2012 –

2014.... .....................................................................................................10

Table 2 Ohio portion SO2 emission inventory totals for base year 2011, attainment 

2014, and projected 2020 and 2027 (tpy) ................................................17

Table 3 Kentucky portion SO2 emission inventory totals for base year 2011, 

attainment 2014, and projected 2020 and 2027 (tpy) ..............................18

Table 4 Combined Campbell-Clermont area SO2 emission inventory totals for base 

tear 2011, attainment 2014, and projected 2020 and 2027 (tpy) .............18

Table 5 Campbell-Clermont area comparison of 2014 attainment year and 2020 

and 2027 projected emission estimates (tpy)...........................................19

Table 6 Campbell-Clermont KY-OH area comparison of 2011 base year and 2014

attainment year EGU reductions..............................................................20

Table 7 Ohio’s 2011 base year inventory .............................................................26

APPENDICES

A-1 Kentucky DAQ Air Quality Data Certification

A-2 2012 to 2014 Air Quality Data

B Letter of Notification of Permanent Shutdown of Walter C. Beckjord Facility

C Emissions Summary and Projections

D Campbell County, Kentucky SO2 Monitor 21-037-3002 2010-2014 Exceedance 

Analysis

E 2011, 2014, 2017, 2020, 2022 and 2027 SO2 On-Road Emissions Inventory for 

Campbell-Clermont Counties, KY-OH 1-hour SO2 Nonattainment Area

F Background Analysis

G Walter C. Beckjord’s SO2 Emissions for 2008 to 2014

H Public Notice and Comment Documents

I Letter of Notification of Permanent Shutdown of Walter C. Beckjord Facility, 

Combustion Turbines

J Supplemental Modeling Demonstration, William H. Zimmer Facility

K Analysis of Monitor Values, Emissions, and Wind Direction Data, January 1, 

2012-February 28, 2015

L Letter of Notification of Permanent Shutdown of the Miami Fort Power Station 

Unit 6
 

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REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE OHIO 

PORTION OF THE CAMPBELL-CLERMONT KY-OH 

1-HOUR SO2 NONATTAINMENT AREA

Partial Clermont County, Ohio

CHAPTER ONE: Introduction

History

The Clean Air Act (CAA), as amended, requires each state with areas failing 

to meet the 1-hour sulfur dioxide (SO2) National Ambient Air Quality Standard 

(NAAQS) to develop State Implementation Plans (SIPs) to expeditiously 

attain and maintain the standard. The United States Environmental 

Protection Agency (U.S. EPA) promulgated the revised NAAQS for SO2 on 

June 2, 2010. U.S. EPA replaced the 24-hour and annual standards with a 

new short-term 1-hour standard of 75 parts per billion (ppb). The new 1-hour 

SO2 standard was published on June 22, 2010 (75 FR 35520) and became 

effective on August 23, 2010. The standard is based on the three-year 

average of the annual 99th percentile of 1-hour daily maximum 

concentrations.

On August 15, 2013, U.S. EPA published (78 FR 47191) the initial SO2

nonattainment area designations for the 1-hour SO2 standard across the 

country (effective October 4, 2013). Unlike Subpart 2 of the CAA 

Amendments of 1990 which defined five ozone nonattainment classifications 

for the areas that exceed the NAAQS based on the severity of the ozone 

levels, SO2 nonattainment designations are simply labeled “nonattainment.” 

The CAA Amendments require states with SO2 nonattainment areas to submit 

a plan within eighteen months of the effective date of the designations (April 

4, 2015) detailing how the SO2 standard will be attained by October 4, 2018

(referred to as an “attainment demonstration”). However, areas that attain 

before the required date for submitting a plan may be exempt from certain 

otherwise applicable requirements.

Section 107(d)(3)(E) of the CAA allows states to request nonattainment areas 

to be redesignated to attainment provided certain criteria are met. The 

following are the criteria that must be met in order for an area to be 

redesignated from nonattainment to attainment: 

1. A determination that the area has attained the SO2

standard. (CAA Section 107(d)(3)(E)(i))

2. An approved SIP for the area under Section 110(k). (CAA 

Section 107(d)(3)(E)(ii))

3. A determination that the improvement in air quality is due 

to permanent and enforceable reductions in emissions 
Campbell-Clermont KY-OH SO2 Redesignation Request and Maintenance Plan

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resulting from implementation of the SIP, federal 

requirements, and other permanent and enforceable 

reductions. (CAA Section 107(d)(3)(E)(iii))

4. A fully approved maintenance plan, including a 

contingency plan, under Section 175A. (CAA Section 

107(d)(3)(E)(iv))

5. A determination that all Section 110 and Part D 

requirements have been met. (CAA Section 

107(d)(3)(E)(v))

Each of these criteria is discussed in more detail under Chapter Two with a 

detailed analysis in subsequent chapters. This document is intended to 

support Ohio’s request that the Ohio portion of the Campbell-Clermont KYOH area be redesignated from nonattainment to attainment for the 1-hour 

SO2 standard. This document addresses each of above requirements, and 

provides additional information to support continued compliance with the 1-

hour SO2 standard.

Geographical Description and Background

The current Campbell-Clermont KY-OH nonattainment area is located in 

southwestern Ohio and the following area in Campbell County, Kentucky that 

lies south and west of the Ohio River: beginning at geographic coordinates 

38.9735 North Latitude, 84.3017 West Longitude (NAD 1983) on the edge of 

the Ohio River running southwesterly to KY Highway 1566; thence continuing 

running southwesterly along KY Highway 1566 to KY Highway 9 (AA 

Highway); thence running north westerly along KY Highway 9 (AA Highway) 

from Hwy 1566 to Interstate 275; thence running northeasterly along 

Interstate 275 to Highway 2345 (John’s Hill Road), Hwy 2345 to US–27, US–

27 to I–275, I–275 to the Ohio River; thence running southeasterly along the 

Ohio River from Interstate 275 to geographic coordinates 38.9735 North 

Latitude, 84.3017 West Longitude (NAD 1983). This area is shown in Figure 

1 under Chapter Three. 

The Campbell-Clermont KY-OH area has not previously been subject to 

nonattainment area rulemakings for the SO2 NAAQS. 

Status of Air Quality

SO2 complete quality-assured ambient air quality monitoring data for the three 

(3) years, 2012 through 2014, demonstrate that the air quality has met the 1-

hour SO2 standard in this nonattainment area. (See Chapter Three) The 

NAAQS attainment, accompanied by decreases in emission levels discussed 

in Chapter Four, supports a redesignation to attainment for the CampbellClermont KY-OH area based on the requirements in Section 107(d)(3)(E) of 

the CAA as amended.
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CHAPTER TWO: Requirements for Redesignation

U.S. EPA has published detailed guidance in a document entitled Procedures 

for Processing Requests to Redesignate Areas to Attainment (redesignation 

guidance), issued September 4, 1992, to Regional Air Directors. U.S. EPA 

has also published guidance specific to SO2 in a document entitled Guidance 

for 1-Hour SO2 Nonattainment Area SIP Submissions (SO2 nonattainment 

area SIP guidance), issued April 23, 2014, to Regional Air Division Directors. 

This redesignation request and maintenance plan is based on the 

redesignation guidance and SO2 nonattainment area SIP guidance, 

supplemented with additional guidance received from U.S. EPA Region 4 and 

Region 5 staff.

Below is a summary of each redesignation criterion as it applies to the 

Campbell-Clermont KY-OH area.

1. Attainment of the standard (CAA Section 107(d)(3)(E)(i)) 

There are two components involved in making this demonstration. 

The first component relies on ambient air quality data. For SO2, all available 

monitoring data in the area should indicate the standard is being met 

according to 40 CFR 50.17 and 40 CFR Part 50, Appendix T. Analyses 

should indicate whether any of the monitors located in the nonattainment area 

are located in the area of maximum concentration. 

Demonstration: Chapter Three discusses this requirement in more detail and 

provides the demonstration.

The second component relies upon supplemental U.S. EPA-approved air 

quality modeling. Where a monitor is located in the area of maximum 

concentration, a determination of attainment may be made based on 

monitoring data alone without the need for additional air quality modeling. 

When a nonattainment area has no monitors, or monitors not located in the 

area of maximum concentration, air quality dispersion modeling is generally

needed to estimate SO2 concentrations in the area. 

Demonstration: Chapter Three discusses this requirement in more detail 

(Requirement 4 of 4) and provides the demonstration.
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2. Approved SIP for the area under CAA Section 110(k) (CAA Section 

107(d)(3)(E)(ii))

The SIP for the nonattainment would need to be fully approved and satisfy all 

applicable requirements for the area. U.S. EPA approval of SIP elements and 

redesignation requests may occur simultaneously.

Demonstration: Ohio EPA has submitted all required SIP elements for this 

area in either previous submittals, or as a part of this submittal. 

3. Permanent and enforceable improvement in air quality (CAA Section 

107(d)(3)(E)(iii))

The state must be able to reasonably attribute the improvement in air quality 

to emission reductions which are permanent and enforceable. The state 

should estimate the percent reduction achieved from federal measures as 

well as control measures that have been adopted and implemented by the 

state.

Demonstration: Chapter Four discusses this requirement in more detail 

(Requirement 4 of 5) and provides the demonstration.

4. Maintenance plans (CAA Section 107(d)(3)(E)(iv))

Section 107(d)(3)(E) stipulates that for an area to be redesignated, U.S. EPA 

must fully approve a maintenance plan that meets the requirements of 

Section 175A. The maintenance plan will constitute a SIP revision and must 

provide for maintenance of the relevant NAAQS in the area for at least ten

years after redesignation along with a commitment to review the plan. 

Section 175A further states that the plan shall contain such additional 

measures, if any, as may be necessary to ensure such maintenance.

In addition, the maintenance plan shall contain such contingency measures 

as the Administrator deems necessary to ensure prompt correction of any 

violation of the NAAQS. At a minimum, the contingency measures must 

include a requirement that the state will implement all measures contained in 

the nonattainment SIP prior to redesignation.

Demonstration: States seeking approval of a maintenance plan for a 

nonattainment area should consider the following provisions:

 attainment inventory (Chapter Four contains the discussion and 

demonstration);
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 maintenance demonstration (Chapter Four contains the discussion and 

demonstration);

 monitoring network (Chapter Three contains the discussion and 

demonstration);

 verification of continued attainment (in Chapter Four (Requirement 5 of 

5) contains the discussion and demonstration); and

 contingency plan (Chapter Six contains the discussion and 

demonstration).

5. Section 110 and Part D requirements (CAA Section 107(d)(3)(E)(v))

For purposes of redesignation, a state must meet all requirements of Section 

110 and Part D that were applicable prior to submittal of the complete 

redesignation request but not those that come due after submittal of the 

redesignation request.

a. Section 110(a) requirements

Section 110(a) of Title I of the CAA contains the general requirements

for a SIP. Section 110(a)(1) generally directs states to submit a SIP

that provides for implementation, maintenance, and enforcement of the 

air quality standards to the U.S. EPA after reasonable notice and 

public hearing. Section 110(a)(2) provides that the infrastructure SIP

submitted by a state must have been adopted by the state after

reasonable public notice and hearing, and that, among other things, it

must include enforceable emission limitations and other control 

measures1, means or techniques necessary to meet the requirements 

of the CAA; provide for establishment and operation of appropriate 

devices, methods, systems and procedures necessary to monitor 

ambient air quality; provide for implementation of a source permit 

program to regulate the modification and construction of any stationary 

source within the areas covered by the plan; include provisions for the

implementation of Part C, prevention of significant deterioration (PSD)

and Part D, new source review (NSR) permit programs; include criteria 

for stationary source emission control measures, monitoring, and 

reporting; include provisions for air quality modeling; and provide for 

public and local agency participation in planning and emission control 

rule development.

 

1 Other than nonattainment emission limitations and measures which are a part of 

nonattainment area plans and subject to the timing requirements of Section 172 of the CAA.
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Demonstration: In Ohio’s June 7, 2013 infrastructure SIP submission, 

Ohio verified that the state fulfills the requirements of Section 110(a)(1) 

and Section 110(a)(2) of the CAA with respect to the 2010 SO2

NAAQS. Ohio’s June 7, 2013 infrastructure SIP for the 2010 1-hour 

SO2 standard contains SIP approved Ohio Administrative Code 

Chapter 3745-18, through which SO2 emissions are directly regulated. 

Section 110(a)(2)(D) also requires state plans to prohibit emissions 

from within the state which contribute significantly to nonattainment or 

maintenance areas in any other state, or which interfere with programs 

under Part C to prevent significant deterioration of air quality or to 

achieve reasonable progress toward the national visibility goal for 

Federal class I areas (national parks and wilderness areas). 

Demonstration: In order to assist states in addressing their obligations 

regarding regionally transported pollution, U.S. EPA finalized the Clean 

Air Interstate Rule (CAIR) and then the Cross State Air Pollution Rule 

(CSAPR) to reduce SO2 and NOx emissions from large electric 

generating units (EGU). Ohio has met the requirements of the federal 

CAIR to reduce NOx and SO2 emissions contributing to downwind 

states. On February 1, 2008, U.S. EPA approved Ohio’s CAIR 

program, which can be found in Ohio Administrative Code (OAC) 

Chapter 3745-1092. On July 6, 2011, U.S. EPA finalized a 

replacement to the CAIR program, the CSAPR. CSAPR will further 

assist states in addressing their obligations regarding regionally

transported pollution by providing reductions in NOx and SO2

emissions in 2015 and 2017

3.

 

b. Part D requirements 

Subpart 1 of Part D consists of general requirements applicable to all 

areas which are designated nonattainment based on a violation of the

NAAQS. Subpart 5 of Part D consists of more specific requirements 

applicable to SO2

4

.

i. Section 172(c) requirements

 

2

http://www.epa.ohio.gov/dapc/regs/regs.aspx#3745-109

3

Timeline for implementation of CSPAR was adjusted from 2012 and 2014 to 2015 and 2017. 

(79 FR 71663)

4

Subpart 5 of Part D identifies requirements related only to plan submission deadlines and 

attainment dates. SIP submittal and attainment dates are discussed in the introduction of this 

submittal.
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This Section contains general requirements for nonattainment 

plans. The requirements for reasonable further progress (RFP), 

identification of certain emissions increases, and other 

measures needed for attainment will not apply for 

redesignations because they only have meaning for areas not 

attaining the standard. The requirements for an emission 

inventory will be satisfied by the inventory requirements of the 

maintenance plan. 

Demonstration: The emissions inventory is discussed in 

Chapter Four and the maintenance plan is discussed below. 

The requirements of the Part D NSR program will be replaced 

by the PSD program once the area has been redesignated. The 

PSD program is discussed in Chapter Five (Requirement 5 of 

6). The demonstrations are provided in these locations.

ii. Conformity

The state must work with U.S. EPA to show that its SIP 

provisions are consistent with the Section 176(c)(4) conformity 

requirements. The redesignation request should include 

conformity procedures, if the state already has these 

procedures in place. If a state does not have conformity 

procedures in place at the time that it submits a redesignation 

request, the state must commit to follow U.S. EPA’s conformity 

regulation upon issuance, as applicable. 

Demonstration: Ohio EPA meets all of U.S. EPA’s conformity 

procedures. Ohio EPA commits to following the general 

conformity requirements of 40 CFR 93.150 to 93.165. On 

August 20, 2014, Ohio EPA submitted signed Memorandums of 

Understanding (MOUs) to U.S. EPA establishing transportation 

conformity procedures for inclusion in Ohio’s SIP. U.S. EPA 

issued a direct final rulemaking approving the MOUs on March 

2, 2015 (80 FR 11133) with an effective date of May 1, 2015.

As described in the SO2 nonattainment area SIP guidance, due 

to the relatively small, and decreasing, amounts of sulfur in 

gasoline and on-road diesel fuel, the U.S. EPA's transportation

conformity rules provide that they do not apply to SO2 unless 

transportation conformity budgets exist for other reasons, such 

as that SO2 is found to be a significant contributor to a PM2.5

nonattainment problem, or if the SIP has established an 

approved or adequate budget for such emissions as part of the 

RFP, attainment or maintenance strategy. Neither of these 
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circumstances applies here. As discussed in Ohio EPA’s 

December 9, 20105redesignation request and maintenance 

plan for the Cincinnati-Hamilton OH-KY-IN area under the 1997 

PM2.5 standard, mobile SO2 was found to be an insignificant 

contributor to the PM2.5 nonattainment problem. All of Campbell 

County, KY and all of Clermont County, OH were included in 

that historical nonattainment area and no SO2 budgets exist for 

these counties. Therefore, mobile source SO2 emission 

budgets are not required for this area.

 

5

http://www.epa.ohio.gov/portals/27/SIP/Cincinnati_PM25_annual_redesignation-FINAL.pdf
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CHAPTER THREE: SO2 Monitoring

CAA Section 107(d)(3)(E)(i)

Requirement 1 of 4: A demonstration that the NAAQS for 1-hour SO2, as 

published in 40 CFR 50.17, has been attained.

There is one monitor measuring SO2 concentrations in this nonattainment 

area. This monitor is operated by the Kentucky Division for Air Quality. The

location of the monitoring site for this nonattainment area is shown in Figure 

1. 

Figure 1 - Map of the Campbell-Clermont KY-OH nonattainment area and 

monitor location
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In accordance with 40 CFR Part 50, Appendix T, three complete years of 

monitoring data are required to demonstrate attainment at a monitoring site. 

The 1-hour SO2 standard is met at an ambient air quality monitoring site when 

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

concentrations is less than or equal to 75 ppb. The three-year average of the 

annual 99th percentile of 1-hour daily maximum concentrations is also called 

the site's “design value.” To be complete, at least 75 percent of the days in 

each quarter of each of the three consecutive years must have at least one 

reported hourly value. Hourly SO2 data are reported to U.S. EPA’s Air Quality 

System (AQS). While calculating design values, one decimal place must be 

carried in the computations, with final values rounded to the nearest 1 ppb. 

Decimals 0.5 or greater are rounded up, and those less than 0.5 are rounded 

down. Values at or below 75 ppb meet the standard. Values greater than 75

ppb exceed the standard. An area is in compliance with the 1-hour SO2

standard only if every monitoring site in the area meets the NAAQS. The air 

quality design value for the area is the highest design value among all sites in 

the area. 

Demonstration: The three-year average of the annual 99th percentile of 1-

hour daily maximum concentrations, based on data from the monitoring site in 

the area, is 72 ppb. A listing of the design value for 2012 through 2014 is 

shown in Table 1. 

Table 1 - Monitoring data for the Campbell-Clermont KY-OH area for 

2012 – 2014

Year (ppb) Average 2012-

Site County 2012 2013 2014 2014 (ppb)

21-037-3002 Campbell, 

KY 85 71 61 72

Less than 75% capture in at least one quarter

Source: U.S. EPA Air Quality System (AQS); http://www.epa.gov/ttn/airs/airsaqs/index.htm

Requirement 2 of 4: Ambient monitoring data quality assured in 

accordance with 40 CFR 58.10, recorded in the AQS database, and 

available for public view.

Demonstration: Kentucky DAQ has quality assured all data shown in 

Appendix A in accordance with 40 CFR 58.10 and all other federal 

requirements. Kentucky DAQ has recorded the data in the AQS database 

and, therefore, the data are available to the public.
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Requirement 3 of 4: A commitment that once redesignated, the state 

will continue to operate an appropriate monitoring network to verify the 

maintenance of the attainment status.

Demonstration: This monitor is located in Kentucky. Ohio EPA consulted 

with Kentucky DAQ and Kentucky DAQ assures Ohio EPA they commit to 

continue monitoring SO2 levels at the Kentucky site indicated in Figure 1 and 

Table 1. Kentucky DAQ assures Ohio EPA they will consult with U.S. EPA 

Region 4 prior to making changes to the existing monitoring network, should 

changes become necessary in the future. Kentucky DAQ assures Ohio EPA 

they will continue to quality assure the monitoring data to meet the 

requirements of 40 CFR 58 and all other federal requirements. 

Requirement 4 of 4: Supplemental U.S. EPA-approved air quality 

modeling to show monitors are located in the area of maximum 

concentration. 

Where a monitor is located in the area of maximum concentration, a 

determination of attainment may be made based on monitoring data alone 

without the need for additional air quality modeling. When a nonattainment 

area has no monitors, or monitors not located in the area of maximum 

concentration, air quality dispersion modeling is generally needed to estimate 

SO2 concentrations in the area. 

Demonstration: Ohio EPA analysis demonstrates violations at this monitor 

were caused by emissions from the Walter C. Beckjord facility located along 

the Ohio River in Ohio east of the monitor (see Figure 1). On September 1, 

20146, the Walter C. Beckjord facility ceased operations of all EGUs and by 

the end of 2014 the remaining oil-fired units. Ohio EPA was notified of the 

permanent shutdown of the entirety of the facility on October 14, 2014 and 

May 28, 2015. (Appendix B, Appendix I) There are no other significant point 

sources of SO2 emissions located in the nonattainment area. Within the 

portion of Campbell County, KY that is a part of this area there are 11 sources 

which combined emit less than one ton per year (tpy) of SO2. (Appendix C) 

There are no other point sources of SO2 emissions in the portion of Clermont 

County, OH that is a part of this area. 

Located south (and slightly east) of the monitor, but outside of the 

nonattainment area, is the William H. Zimmer facility (see Figure 1). It was 

 

6

The letter contained in Appendix B identifies the permanent shutdown of all units occurred 

on October 1, 2014. However, a review of CAMD emissions showed that all the units ceased 

operation by September 1, 2014.
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determined during the nonattainment designation process that emissions from 

the William H. Zimmer facility likely do not impact the violating monitor at 

question, and therefore, the nonattainment area was not expanded to 

encompass this facility. To support the previous conclusion, Ohio EPA 

performed an extensive meteorology, emissions and back trajectory analysis 

and has included this analysis as Appendix D. This analysis concludes that it 

was in fact the Walter C. Beckjord facility that caused the violations and not 

the William H. Zimmer facility. The back trajectory analysis also 

demonstrates that emissions from the William H. Zimmer facility likely do not 

impact the nonattainment area as a whole. 

This conclusion is further supported by an air quality trend analysis of the 

monitoring site. Figure 2 shows both Walter C. Beckjord and William H. 

Zimmer SO2 rolling hourly emissions7for the 2012 to 2014 period along with 

rolling hourly SO2 concentrations at the monitor. For clarity in the 

demonstration of the long-term trend, the emissions and monitor values are 

presented as rolling 168 hour averages. Elevated monitor concentrations are 

associated with elevated emissions from Walter C. Beckjord throughout this 

three-year period. During this period there were significant fluctuations and 

changes in Walter C. Beckjord’s SO2 emissions. However, emissions 

remained stable at the William H. Zimmer facility. Requirement 3 of 4 under 

Chapter 4 identifies more specific emission trends from the Walter C. 

Beckjord facility’s six emissions units. As can be seen in that section, 

emissions at Walter C. Beckjord have steadily declined due to operation of 

the four smaller EGUs ceasing between 2009 and 2013 and lastly the two 

larger EGUs in 2014. 

 

7 Only the EGU emissions at Walter C. Beckjord were analyzed. The SO2 emissions from the 

oil-fired units are trivial in comparison. For example, in 2014 total SO2 emissions were 

32,602.44 tons for the facility. Of that total, less than 0.03 tons were reported for all non-EGU 

sources at the facility.
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Figure 2: 2012 to 2014 Walter C. Beckjord and William H. Zimmer hourly 

emissions with hourly SO2 monitoring data

Only the two larger EGUs remained in operation during 2014 and completely 

ceased operation on September 20, 2014. In addition, from May 5 to June 

29, 2014, these EGUs also did not operate. Figure 3, also presented as a 

rolling average of 18 hours to more clearly illustrate the-long term trend,

shows an obvious downward trend in monitored SO2 concentrations during 

these periods even though operations at William H. Zimmer remained 

consistent.
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Figure 3: 2014 Walter C. Beckjord and William H. Zimmer hourly 

emissions with hourly SO2 monitoring data

An analysis of the 2014 hourly monitoring data shows that the average hourly 

monitored SO2 level was 2.27 ppb during periods of operation of the two 

remaining EGUs at the Walter C. Beckjord facility while during the May 5 to 

June 29, 2014 period and the post September 20, 2014 period the average 

hourly monitored SO2 level was 0.72 ppb. The long term trend clearly 

indicates that reductions in emissions at the Walter C. Beckjord facility have 

led to reductions in monitored concentrations. Further analyses, presented 

below demonstrate the impacts of reduced emissions on peak monitor values.

Because there are no longer any significant point sources of emissions 

impacting this monitor, it was determined an air quality dispersion modeling 

analysis to determine the area of maximum concentration would not be 

relevant or necessary for this redesignation request. However, Ohio EPA 

conducted a conservative modeling analysis to demonstrate that

concentrations throughout the nonattainment area will be relatively uniform 

and that the point of maximum concentration in the nonattainment area 

resultant from emissions from the William H. Zimmer facility will not exceed 

the standard. This additional analysis is included as Appendix J. This 
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analysis shows a maximum worst-case 99th percentile value of 52.4 ppb 

within the nonattainment area. As noted in Appendix J, this design value is 

likely an over estimation but allows Ohio EPA to demonstrate in a highly 

conservative manner that emissions from the William H. Zimmer facility will 

not cause an exceedance of the standard in this nonattainment area. This is 

further supported by both the back trajectory analysis and the analysis of 

emissions and monitor values above. Also included in the Appendix J 

analysis is a demonstration that the point of maximum impact is located 

approximately 1.4 km southeast of the William H. Zimmer facility, and the 

point of maximum in the nonattainment area represents an approximately 

84% reduction from the overall maximum impact.

Ohio EPA conducted a second analysis of monitor values, wind directions, 

and emissions for all hours in which SO2 emissions from the Walter C. 

Beckjord facility were zero to illustrate the impact of the shutdown of the 

Walter C. Beckjord facility on peak monitor values. This analysis indicates 

that for those identified hours, the maximum recorded concentration was 34 

ppb, and that the 99th percentile of nonzero monitored values for the same 

period was 11 ppb. This analysis, presented in Appendix K, also 

demonstrates that the primary wind directions impacting the monitor in the 

absence of Walter C. Beckjord emissions were from the West and Northwest, 

where sources are located 30 to 35 km distant from the monitor, and will have 

SO2 reductions of approximately 66% from 2014 levels as of June 1, 2015. 

The large distances between these sources and the monitor location, as well 

as the nonattainment area as a whole, would indicate that there is unlikely to 

be a significant concentration gradient, and thus the monitor is determined to 

be representative of ambient SO2 concentrations across the nonattainment 

area. 

In addition to the above, U.S. EPA has requested Ohio EPA and Kentucky 

DAQ perform an analysis of background concentration for this nonattainment 

area to determine predicted concentrations in the future and ensure that 

maintenance would be achieved. This analysis is included in Requirement 2 

of 4 under Chapter Four. 
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CHAPTER FOUR: Emission Inventory

CAA Section 107(d)(3)(E)(iii)

U.S. EPA’s redesignation guidance requires the submittal of a comprehensive 

inventory of SO2 emissions representative of the year when the area achieves 

attainment of the 1-hour SO2 air quality standard. Ohio also must

demonstrate that the improvement in air quality between the year that 

violations occurred and the year that attainment was achieved is based on 

permanent and enforceable emission reductions. Other emission inventory 

related requirements include a projection of the emission inventory to a year 

at least 10 years following redesignation; a demonstration that the projected 

level of emissions is sufficient to maintain the 1-hour SO2 standard; and a 

commitment to provide future updates of the inventory to enable tracking of 

emission levels during the 10-year maintenance period.

Requirement 1 of 4: A comprehensive emission inventory of SO2

completed for the base year and a projection of the emission inventory 

to a year at least 10 years following redesignation.

Periodic inventories, which include emissions from all sectors - mobile, area, 

non-road, and point sources - are prepared every three years. The 2011 

periodic inventory has been identified as one of the preferred databases for 

SIP development and coincides with nonattainment air quality in the 

Campbell-Clermont area. The 2011 inventory is used as the base year for the 

purpose of this submittal and is being submitted to U.S. EPA with this 

document to fulfill all emissions inventory requirements under the 2010 SO2

standard. 

For the attainment year, 2014 was selected since it corresponds to one of the 

years in the design value showing attainment (2012 – 2014). The 2014 

attainment year also corresponds to the year where the permanent and 

enforceable improvement in air quality leading to attainment occurred due to 

the entirety of the Walter C. Beckjord facility permanently ceasing operations.

In consultation with U.S. EPA, Ohio EPA selected the year 2027 as the 

maintenance year for this redesignation request. This document contains 

projected emissions inventories for 2020 (interim year) and 2027. 

The information below describes the procedures Kentucky DAQ, Ohio EPA

and the Ohio, Kentucky, Indiana Council of Governments (OKI) used to 

generate future year emission projections based on the 2011 base year 

inventory. 
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In summary, projections were developed for each sector as follows: 

 Area source and non-road8emissions were compiled from the 2011 

National Emissions Inventory (NEI) and projections were developed 

according to the analysis contained in Appendix C.

 On-road or mobile source emission projections are based on U.S. EPA’s

MOVES model and were provided by the OKI. Mobile source emissions 

were calculated from MOVES2014b-produced emission factors. The 

analysis and projections methods are described in more detail in Appendix 

E. 

 Non-EGU point source information was compiled from both Ohio and 

Kentucky Emissions Inventory databases and EGU point source 

information was compiled from the 2014 data in U.S. EPA’s Clean Air 

Markets Division (CAMD)9database. Projections were developed

according to the analysis contained in Appendix C.

 Biogenic emissions are not included in these summaries because they are

negligible.

Demonstration: Sectors included in the following tables are: Electrical 

Generating Unit (EGU-Point); Non-Electrical Generating Unit (Non-EGU); 

Non-road Mobile (Non-road); Other (Area); and On-road Mobile (On-road). 

Table 2 - Ohio portion SO2 emission inventory totals for base year 2011, 

attainment 2014, and projected 2020 and 2027 (tpy)

Sector 2011 Base

2014 

Attainment

2020 

Interim

2027 

Maintenance

EGU Point 90,834.50 32,602.44 0.00 0.00

Non-EGU 0.00 0.00 0.00 0.00

Non-road 0.17 0.17 0.18 0.18

Other 7.50 7.62 7.87 8.00 

On-road 0.34 0.33 0.31 0.28 

TOTAL 90,842.51 32,610.56 8.36 8.46

 

8

Includes Marine; Aircraft; and Rail (MAR).

9

http://www.epa.gov/airmarkets/acidrain
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Table 3 – Kentucky portion SO2 emission inventory totals for base year 

2011, attainment 2014, and projected 2020 and 2027 (tpy)

Sector

2011 

Base

2014 

Attainment

2020 

Interim

2027 

Maintenance

EGU Point 0.00 0.00 0.00 0.00

Non-EGU 0.78 0.78 0.79 0.78

Non-road 0.20 0.20 0.20 0.20 

Other 6.03 6.05 6.08 6.03

On-road 1.55 1.51 1.40 1.26 

TOTAL 8.56 8.54 8.47 8.27

Table 4 – Combined Campbell-Clermont area SO2 emission inventory 

totals for base year 2011, attainment 2014, and projected 2020 and 

2027 (tpy)

SO2 2011 Base

2014 

Attainment 2020 Interim

2027 

Maintenance

Ohio 

Portion 90,842.51 32,610.56 8.36 8.46

Kentucky 

Potion 8.56 8.54 8.47 

8.27

COMBINED 

SO2 TOTAL 90,851.07 32,619.10 16.83 16.73

As part of the redesignation request and maintenance plan, motor vehicle 

emission budgets must be established unless it is determined mobile sources 

are insignificant contributors for a specific pollutant. As discussed under 

Section 5.b.ii of Chapter Two, mobile SO2 emissions are considered an 

insignificant contributor under the 2010 SO2 NAAQS for this area.

Requirement 2 of 4: A demonstration that the projected level of 

emissions is sufficient to maintain the SO2 standard.

Maintenance is demonstrated either by showing that future emissions of SO2

will not exceed the level of the attainment inventory at levels that could cause 

a violation of the NAAQS, or by modeling to show that the future mix of 

sources and emission rates will not cause a violation of the NAAQS. 
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A maintenance demonstration should also include a listing of all SO2 control 

measures being implemented in the area by sector (See Chapter Five).

Demonstration: As discussed under Requirement 4 of 4 in Chapter Three, it 

was determined a modeling analysis of maximum concentration location 

would not be warranted given the unique circumstances of this specific 

redesignation request. Ohio EPA conducted a conservative analysis of the 

maximum concentration in the nonattainment area and demonstrated that an 

exceedance of the standard would not occur at any point in the nonattainment 

area. (Appendix J) As of September 1, 2014 (when the Walter C. Beckjord 

facility ceased operations), there are no significant point sources of SO2

emissions located in the nonattainment area.

Emission trends are an important gauge for continued compliance with the 

SO2 standard. Therefore, to meet this requirement, Ohio EPA performed an 

initial comparison of the inventories for the base year and maintenance years 

identified in Requirement 1 of 4 of this Chapter. Maintenance is demonstrated 

when the future-year (2027) projected emission totals are below the 2014 

attainment year totals.

Table 5 – Campbell-Clermont area comparison of 2014 attainment year 

and 2020 and 2027 projected emission estimates (tpy)

2014

Attainment

2020

Interim

2020

Projected 

Decrease

2027

Maintenance

2027

Projected 

Decrease

SO2 32,619.10 16.83 -32,602.27 16.73 -32,602.37

As shown in the Table 5 above, SO2 emissions in the nonattainment area are 

projected to decrease by 32,602 tpy in both 2020 and 2027. This drop in 

emissions from the attainment year in conjunction with the fact that the entire 

nonattainment area’s total emissions will be 16.73 tpy to 16.83 tpy after the 

attainment year demonstrates maintenance.

In addition to the above, U.S. EPA has requested Ohio EPA and Kentucky 

DAQ perform an analysis of background concentration for this nonattainment 

area to determine predicted concentrations in the future and ensure that 

maintenance would be achieved. Ohio EPA and Kentucky DAQ have 

determined a conservative average background concentration for this area is 

4.76 ppb, and a conservative 99th percentile background or this area is 11 

ppb. The analysis to support this determination is included in Appendix F and 

Appendix K. The analysis follows procedures for multiple tiers of calculation 

options for background as outlined in U.S. EPA’s SO2 nonattainment area SIP 

guidance. The analysis of a 4.76 ppb average background concentration
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and a conservative 99th percentile concentration of 11 ppb further supports 

maintenance will be achieved.

Requirement 3 of 4: A demonstration that improvement in air quality 

between the year violations occurred and the year attainment was 

achieved is based on permanent and enforceable emission reductions 

and not on temporary adverse economic conditions or unusually 

favorable meteorology.

Permanent and enforceable reductions should be a result of emission 

limitations in the SIP. In making this showing, sufficient quantitative 

information about emission reductions should be provided to demonstrate the 

improvement in air quality is attributed to permanent and enforceable 

measures. 

Demonstration: Permanent and enforceable reductions of SO2 emissions

have contributed to the attainment of the 1-hour SO2 standard in this area. 

As demonstrated in Table 6 below, permanent and enforceable reductions

were realized in this area due to the permanent shut down of the entirety of

the Walter C. Beckjord facility. 

Table 6 – Campbell-Clermont KY-OH area comparison of 2011 base year 

and 2014 attainment year EGU reductions

2011 2014

EGU SO2 90,834.50 32,602.44

As discussed under Requirement 4 of 4 in Chapter Three, violations at this 

monitor were determined to be caused by emissions from the Walter C. 

Beckjord facility which ceased operations of EGUs beginning September 1, 

2014 and the remaining oil-fired units by the end of 2014. Ohio EPA was 

notified of the permanent shutdown on October 14, 2014 and May 28, 2015

thereby making the reductions permanent and enforceable. (Appendix B, 

Appendix I) When an owner or operator notifies Ohio EPA of the 

permanence of shut down, the facility cannot resume operations without 

being considered a new facility and being subject to the NSR requirements. 

OAC Chapter 3745-3110 contains Ohio’s Permits-to-Install New Sources and 

Permit-to-Install and Operate Program rules. OAC rule 3745-31-02 prevents 

installation or modification, and subsequent operation of new sources without 

properly obtaining appropriate permits. A new source is defined in OAC rule 

 

10 http://epa.ohio.gov/dapc/regs/3745_31.aspx
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3745-31 as any air contaminant source for which an owner or operator 

undertakes a continuing program of installation or modification, wherein a 

modification is defined as any physical change in, or change in the method of 

operation of any air contaminant source that results in an increase in the 

allowable emissions. In addition, it has been Ohio’s longstanding policy and 

memorialized under OAC Chapter 3745-31 that for any emission unit that is 

permanently shut down (physically removed from service or altered in such a 

way that it can no longer operate without a subsequent “modification” or 

installation), authorization to operate the affected emissions unit shall cease 

upon the date certified by the authorized official that the emissions unit was 

permanently shut down. No emission unit certified by the authorized official 

as being permanently shut down may resume operation without first applying 

for and obtaining a permit pursuant to OAC Chapter 3745-31. Thus, the 

cessation of emissions from the Walter C. Beckjord facility is permanent and 

enforceable, and that this cessation has been demonstrated to markedly 

improve ambient air quality. (Appendix K) 

The Walter C Beckjord facility was comprised of six EGUs: B001 and B002 

were 94 megawatts (MW) each; B003 was 128 MW; B004 was 150 MW, 

B005 was 238 MW; and B006 was 414 MW. Emissions of SO2, by unit and for 

the entire facility, from 2011 through 2014 can be seen in Figure 4 below.

Figure 4: Walter C. Beckjord SO2 emissions by unit and entire facility

B001 last operated in 2009, B002 in 2011, B003 in 2012, B004 in 2013, and 

both B005 and B006 ceased operation on September 1, 2014 as indicated in 

Figure 5 below.

 -

 10,000

 20,000

 30,000

 40,000

 50,000

 60,000

 70,000

 80,000

 90,000

 100,000

2011 2012 2013 2014

SO2 (TPY)

Year

1

2

3

4

5

6

Facility
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Figure 5: Walter C. Beckjord SO2 emissions for units B005 and B006 in 

2014

Inventories of Walter C. Beckjord’s SO2 emissions for 2008 to 2014 can be 

found in Appendix G.

In addition to the above, emissions of SO2 are limited by new source 

performance standards (NSPS) under Sections 111 and 129 of the CAA; and 

the national emission standards for hazardous air pollutants (NESHAP) under 

Section 112 of the CAA. Several recent U.S. EPA air quality regulations on 

EGUs and other large sources (such as various types of boilers and 

incinerators) have the potential to significantly reduce SO2 emissions further, 

for example, the Mercury and Air Toxics Standards (MATS). Under MATS, 

EGUs meeting specific criteria may choose to demonstrate compliance with 

alternative SO2 emission limits in lieu of demonstrating compliance with HCl 

emission limits. Also Title IV of the CAA, CAIR, CSAPR and federal consent 

decrees required the reduction of SO2 emissions from EGUs throughout the 

nation and will continue to achieve further reductions. U.S. EPA notes that for

facilities subject to the previously listed MACT and regional interstate 

transport rules (such as CAIR and CSAPR), additional control measures may 

not be necessary to demonstrate compliance with the 1-hour SO2 NAAQS. 

In addition to permanent and enforceable reductions for point sources, 

several regulations have led, and will continue to lead, to further reductions of 

SO2 from other sectors. Examples include the application of tighter federal 

standards on non-road diesel vehicles (Clean Air Non-road Diesel Rule), 

requirements to reduce the sulfur content of various motor fuels including lowsulfur diesel fuel standards phased in from 2004 through 2007 for larger on0

1000

2000

3000

4000

5000

6000

7000

8000

SO2 (TPY)

Month in 2014

5

6

Facility
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road vehicles (Highway Heavy Duty Engines Rule), and the application of 

tighter federal standards on new vehicles.

Requirement 4 of 4: Provisions for future annual updates of the 

inventory to enable tracking of the emission levels, including an annual 

emission statement from major sources.

Demonstration: In Ohio, major point sources in all counties are required to 

submit air emissions information annually, in accordance with U.S. EPA’s 

Consolidated Emissions Reporting Rule (CERR). Ohio EPA prepares a new 

periodic inventory for all SO2 emission sectors every three years. These SO2

inventories will be prepared for future years as necessary to comply with the 

inventory reporting requirements established in the CFR. Emissions 

information will be compared to the 2011 base year and the 2027 projected 

maintenance year inventories to assess emission trends, as necessary, and 

to assure continued compliance with the 1-hour SO2 standard.
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CHAPTER FIVE: Control Measures and Regulations

CAA Section 107(d)(3)(E)(ii), 107(d)(3)(iii), and 107(d)(3)(E)(v)

Requirement 1 of 6: Section 172(c)(1) of the 1990 Clean Air Act 

Amendments requires states with nonattainment areas to implement 

RACM and RACT. 

Section 172(c)(1) requires states with nonattainment areas to submit a SIP 

providing for implementation of all RACMs as expeditiously as practicable 

(including such reductions in emissions from existing sources in the area as 

may be obtained through the adoption, at a minimum, of RACT). The SO2

nonattainment area SIP guidance also provides that to the extent that U.S. 

EPA has promulgated national and regional rules that will require significant 

SO2 emission reductions in the period after areas are designated as 

nonattainment, “expeditious attainment” may in many cases mean that 

attainment will be possible earlier than the attainment date.

Demonstration: RACM and RACT requirements are established as part of 

the attainment demonstration SIPs due in April of 2015. Because this area 

attained the standard, this area is eligible for redesignation without submitting

the RACM and RACT attainment plan elements. In addition, because there 

are no longer any significant point sources located in the nonattainment area

no further point source emissions controls are possible therefore RACM and 

RACT for point sources is irrelevant. 

In 1979, 1987 and 1996, Ohio promulgated rules requiring reasonably 

available controls measures for SO2 from stationary sources. 

Statewide RACT rules have been applied to all new sources locating in Ohio 

since that time. RACT requirements are incorporated into permits along with 

monitoring, recordkeeping, and reporting necessary to ensure ongoing 

compliance. Ohio EPA also has an active enforcement program to address 

violations discovered by field office staff. The Ohio RACT rules for SO2 are 

found in OAC Chapter 3745-1811.

In addition, Ohio EPA promulgated and implemented CAIR (OAC Chapter 

3745-10912) over the past six years. Emissions from EGUs make up a 

significant contribution to Ohio’s inventory. Beginning in 2009, Ohio 

implemented CAIR which provided for significant reductions in SO2.

Beginning in 2015, the more restrictive CSAPR will be implemented and more 

significant reductions in SO2 will be realized. 

 

11 http://www.epa.ohio.gov/dapc/regs/3745_18.aspx

12 http://www.epa.ohio.gov/dapc/regs/3745_109.aspx
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Requirement 2 of 6: Section 172(c)(2) of the 1990 CAA Amendments 

requires attainment demonstration SIPs for nonattainment areas to 

show RFP. 

Section 171(1) defines RFP as “such annual incremental reductions in 

emissions of the relevant air pollutant as are required by this part (part D) or 

may reasonable be required by the EPA for the purposes of ensuring 

attainment of the applicable NAAQS by the applicable attainment date.” The 

SO2 nonattainment area SIP guidance explains that this definition is most 

appropriate for pollutants emitted by numerous and diverse sources where 

inventory-wide reductions are often needed to attain a standard. 

Furthermore, the definition is generally less pertinent to pollutants like SO2

that usually have a limited number of sources affecting areas and where 

emissions controls for such sources result in swift and dramatic improvement 

in air quality. Therefore, U.S. EPA explained that RFP is best construed as 

“adherence to an ambitious compliance schedule.”

Demonstration: RFP requirements are established as part of the attainment 

demonstration SIPs due in April of 2015. Because this area attained the 

standard prior to the due date, Ohio EPA is not obligated to submit the RFP 

attainment demonstration elements. Regardless, the only source of 

emissions in the area for which RFP would apply according to U.S. EPA 

guidance would have been the Walter C. Beckjord facility and considering the 

permanent shut down occurred four years prior to the attainment date, the 

requirement for an ambitious compliance schedule would have been met. 

Requirement 3 of 6: Section 172(c)(3) requires states to submit a 

comprehensive inventory of actual emissions.

Section 172(c)(3) requires states to submit a comprehensive inventory of 

actual emissions in the area, including the requirement for periodic revisions 

as determined necessary. 40 CFR 51.1008 requires such inventory to be 

submitted within three years of designation and requires a baseline emission 

inventory for a suitable year to be used for attainment planning.

The SO2 nonattainment area SIP guidance provides the SO2 inventory 

requirements for attainment demonstration SIPs. 

The inventory should also include an attainment year inventory with projected 

emissions for all SO2 sources. The inventory should also include the best 

available information on current enforceable SO2 emission rates (allowable or 

permitted rates) for the SO2 sources located in the nonattainment area.
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Demonstration: Although this area attained the standard prior to the due 

date of attainment demonstrations SIPs, Ohio EPA is still obligated to submit 

inventory elements. Many of these elements overlap the inventory 

requirements for the redesignation request and maintenance plan. 

The Campbell-Clermont KY-OH area comprehensive inventory is being 

submitted to U.S. EPA with this redesignation request and maintenance plan. 

The inventory is discussed in Chapter Four along with documentation on how 

the inventory was generated. For purposes of establishing a base year, the 

2011 nonattainment year was selected.

The following identifies Ohio’s inventory for the Ohio portion of the CampbellClermont KY-OH area:

Table 7 – Ohio’s 2011 base year inventory

Sector 2011 Base (TPY)

EGU Point

Sources:

Walter C. Beckjord Power Plant

90,834.50

Non-EGU

Sources:

None

0.00

Non-road 0.17 

Other 7.50

On-road 0.34 

TOTAL 90,842.51

Ohio also updates its inventory in accordance with U.S. EPA’s CERR rule (i.e. 

emissions statements). Ohio EPA submitted its emissions statement SIP on 

March 18, 1994 which was approved by U.S. EPA on October 13, 1995 (59 

FR 51863). As discussed in Chapter Four (Requirement 4 of 4), Ohio EPA 

submits, and commits to submit, emission inventories (statements) every 

three years. 

Requirement 4 of 6: Evidence that control measures required in past 

SO2 SIP revisions have been fully implemented.

Demonstration: In addition to the historic RACM and RACT requirements for 

SO2, Ohio has fully implemented the OAC Chapter 3745-18 regulations and

CAIR requirements.
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On March 10, 2004, the U.S. EPA promulgated the CAIR. Beginning in 2009, 

U.S. EPA’s CAIR rule requires EGUs in 28 eastern states and the District of 

Columbia to significantly reduce emissions of NOx and SO2. Ohio submitted a 

CAIR SIP which was approved by U.S. EPA on February 1, 2007. Revisions 

to the CAIR SIP were again submitted on July 15, 2009. The revised CAIR 

SIP was approved as a direct final action on September 25, 2009 (74 FR 

48857). CAIR was replaced by the more stringent CSAPR requirements 

beginning in 2015. 

OAC Chapter 3745-1813 is Ohio’s SIP approved rules for the regulation of 

SO2. This set of rules contains general requirements for the entire state along 

with facility specific requirements for significant emitters of SO2. Specifically, 

OAC rule 3745-18-19 regulates emissions from Clermont County while OAC 

rule 3745-18-37 regulates emissions from Hamilton County (to the west).

Requirements are incorporated into permits along with monitoring, 

recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio 

EPA also has an active enforcement program to address violations 

discovered by field office staff.

Requirement 5 of 6: Acceptable provisions to provide for new source 

review.

Demonstration: Ohio has a longstanding and fully implemented NSR 

program. This is addressed in OAC Chapter 3745-3114. The Chapter includes 

provisions for the PSD permitting program in OAC rules 3745-31-01 to 3745-

31-20. Ohio's PSD program was conditionally approved on October 10, 2001 

(66 FR 51570) and received final approval on January 22, 2003 (68 FR 2909) 

by U.S. EPA as part of the SIP. The latest revisions to OAC Chapter 3745-31 

were approved into Ohio’s SIP on February 20, 2013 (78 FR 11748).

Any facility that is not listed in the 2011 emission inventory, or for the closing 

of which credit was taken in demonstrating attainment, will not be allowed to 

construct, reopen, modify, or reconstruct without meeting all applicable NSR 

requirements. Once the area is redesignated, Ohio EPA will implement NSR 

through the PSD program.

 

13 http://www.epa.ohio.gov/dapc/regs/3745_18.aspx

14 http://www.epa.ohio.gov/dapc/regs/3745_31.aspx
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Requirement 6 of 6: Assure that all existing control measures will 

remain in effect after redesignation unless the state demonstrates 

through modeling that the standard can be maintained without one or 

more control measures.

Demonstration: Ohio commits to maintaining the aforementioned control 

measures after redesignation. Ohio hereby commits that any changes to its 

rules or emission limits applicable to SO2 as required for maintenance of the

1-hour SO2 standard in the Ohio portion of the Campbell-Clermont KY-OH

area, will be submitted to U.S. EPA for approval as a SIP revision. 

Ohio, through Ohio EPA’s Legal office and the Ohio Attorney General’s office, 

has the legal authority and necessary resources to actively enforce any 

violations of its rules or permit provisions. After redesignation, it intends to 

continue enforcing all rules that relate to the emission of SO2 precursors in 

the Campbell-Clermont KY-OH area.

CHAPTER SIX: Contingency Measures
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CAA Section 107(d)(3)(E)(v)

Requirement 1 of 4: A commitment to submit a revised plan eight years 

after redesignation.

Demonstration: Ohio hereby commits to review its maintenance plan eight 

years after redesignation, as required by Section 175A of the CAA.

Requirement 2 of 4: A commitment to expeditiously enact and 

implement additional contingency control measures in response to 

exceeding specified predetermined levels (triggers) or in the event that 

future violations of the ambient standard occur.

Section 175A(d) requires contingency provisions to promptly correct any 

violation of the SO2 NAAQS that occur after redesignation. Unlike Section 

172(c)(9), Section 175A does not explicitly require contingency measures 

take effect without further action by the state. Rather the maintenance plan 

should ensure contingency measures are adopted and implemented as 

expeditiously as practicable once they are triggered. The plan should clearly 

identify the measures to be adopted, provide a schedule and associated 

procedures for adoption and implementation, and provide a specific time limit 

for action. 

The General Preamble for the Implementation of Title I of the Clean Air Act 

Amendments of 1990 (April 16, 1992, 57 FR 13498) and the SO2

nonattainment area SIP guidance (page 41 to 42) provides further discussion 

on contingency measures specifically for SO2. In many cases, attainment 

revolves around compliance of a single source, or small set of sources, with 

emission limits shown to provide for attainment. In those cases, U.S. EPA 

interprets contingency measures to mean the state has a comprehensive 

program to identify sources of violations of the SO2 NAAQS and to undertake 

an aggressive follow-up for compliance and enforcement, including expedited 

procedures for establishing enforceable consent agreements pending the 

adoption of revised SIPs. (57 FR 13547)

Demonstration: As discussed in this submittal, since the permanent 

shutdown of Walker C. Beckjord there are no other sources in the 

nonattainment area with potential to cause a violation. Because of the 

absence of sources with a potential to cause a violation, Ohio cannot 

anticipate any future cause of a violation in this area and thus what 

contingency measures might be warranted to help address any future 

violation. However, as discussed elsewhere, Ohio EPA also has an active 

enforcement program to address violations and Ohio EPA will continue to 
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operate a comprehensive program to identify sources of violations of the SO2

NAAQS and to undertake an aggressive follow-up for compliance and 

enforcement, including expedited procedures for establishing enforceable 

consent agreements pending the adoption of revised SIPs. Ohio hereby 

commits to adopt and expeditiously implement necessary corrective actions in 

the event of a violation. 

In the event adoption of any additional control measures is necessary, they 

are subject to Ohio’s administrative and legal process. This process will 

include publication of notices, an opportunity for public hearing, and other 

measures required by Ohio law for rulemaking. 

If a new measure/control is already promulgated and scheduled to be 

implemented at the federal or state level, and that measure/control is 

determined to be sufficient to address a violation of the SO2 NAAQS, 

additional local measures may be unnecessary. Furthermore, Ohio will submit 

to U.S. EPA an analysis to demonstrate the proposed measures are 

adequate to return the area to attainment. 

Requirement 3 of 4: A list of potential contingency measures that would 

be implemented in such an event.

Demonstration: Given that there are no other significant point sources in the 

area at this time, it is not possible to determine what control measures will be 

appropriate at an unspecified time in the future. Potential measures could 

include tighter SO2 emissions offsets for new and modified major sources or 

additional SO2 RACT for affected sources in the area. The absence of 

sources with any evident potential to cause violations means that Ohio cannot 

anticipate what might cause a violation in this area, and thus what 

contingency measures might exists that would address any future violation.

Regardless, Ohio hereby commits to adopt and expeditiously 

implement necessary corrective actions in the following 

circumstances:

Warning Level Response:

A warning level response shall be prompted whenever the 

annual average 99th percentile maximum daily 1-hour SO2

concentration of 79 ppb occurs in a single calendar year within 

the maintenance area. A warning level response will consist of a 

study to determine whether the SO2 value indicates a trend 

toward higher SO2 values or whether emissions appear to be 

increasing. The study will evaluate whether the trend, if any, is 

likely to continue and, if so, the control measures necessary to 
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reverse the trend taking into consideration ease and timing for 

implementation as well as economic and social considerations. 

Implementation of necessary controls in response to a warning 

level response trigger will take place as expeditiously as 

possible, but in no event later than 12 months from the 

conclusion of the most recent calendar year. 

Action Level Response:

An action level response shall be prompted whenever a twoyear average of the 99th percentile maximum daily 1-hour SO2

concentrations of 76 ppb or greater occurs within the 

maintenance area. A violation of the standard (the three-year 

average of the 99th percentile maximum daily 1-hour value SO2

concentration of 75 ppb or greater) shall also prompt an action 

level response. In the event that the action level is triggered and 

is not found to be due to an exceptional event, malfunction, or 

noncompliance with a permit condition or rule requirement, Ohio 

EPA in conjunction with the metropolitan planning organization 

or regional council of governments, will determine additional

control measures needed to assure future attainment of the 

NAAQS for 1-hour SO2. In this case, measures that can be 

implemented in a short time will be selected in order to be in 

place within 18 months from the close of the calendar year that 

prompted the action level. Ohio EPA will also consider the 

timing of an action level trigger and determine if additional, 

significant new regulations not currently included as part of the 

maintenance provisions will be implemented in a timely manner 

and will constitute our response.

Contingency measures to be considered will be selected from a 

comprehensive list of measures deemed appropriate and effective at the time 

the selection is made. The selection of measures will be based on costeffectiveness, emission reduction potential, economic and social 

considerations or other factors that Ohio EPA deems appropriate. Ohio EPA 

will solicit input from all interested and affected persons in the maintenance 

area prior to selecting appropriate contingency measures. 

No contingency measure shall be implemented without providing the 

opportunity for full public participation during which the relative costs and 

benefits of individual measures, at the time they are under consideration, can 

be fully evaluated.
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Requirement 4 of 4: A list of SO2, sources potentially subject to future 

additional control requirements.

Demonstration: Given that there are no other significant point sources in the 

area at this time, it is not possible to provide a list of potentially subject 

sources. 
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CHAPTER SEVEN: Public Participation

Ohio published notification for a public hearing and solicitation for public 

comment concerning the draft redesignation petition and maintenance plan in 

a widely distributed county publication.

The public hearing to receive comments on the redesignation request was 

held on April 16, 2015, at the Pierce Twp. Administration Building, 950 Locust 

Corner Road, Cincinnati, Ohio 45245. The public comment period closed on 

April 16, 2015. Appendix H includes a copy of the public notice, the 

transcript from the public hearing, and when applicable, a response to 

comments document.
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CHAPTER EIGHT: Conclusions

The Campbell-Clermont KY-OH SO2 nonattainment area has attained the 

2010 1-hour NAAQS for SO2 and complied with the applicable provisions of 

the 1990 Amendments to the CAA regarding redesignations of SO2 

nonattainment areas. Documentation to that effect is contained herein. Ohio 

EPA has prepared a redesignation request and maintenance plan that meet 

the requirements of Section 110(a)(1) of the 1990 CAA. 

Based on this presentation, the Campbell-Clermont KY-OH 1-hour SO2 

nonattainment area meets the requirements for redesignation under the CAA 

and U.S. EPA guidance. Ohio has performed an analysis that shows the air 

quality improvements are due to permanent and enforceable measures. 

Furthermore, because the only contributing source in this area has 

permanently shut down, continued compliance (maintenance) with the 

standard with an increasing margin of safety is ensured. Ohio has also 

demonstrated that sources surrounding the nonattainment area will not cause 

an exceedance of the standard at any point in the nonattainment area or are 

located at sufficient distance to ensure that concentrations at the monitor are 

representative of the nonattainment area as a whole.

The State of Ohio hereby requests that the Campbell-Clermont KY-OH 1-hour 

SO2 nonattainment area be redesignated to attainment simultaneously with 

U.S. EPA approval of the maintenance plan provisions contained herein. 
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