# OZONE MAINTENANCE PLAN SIP REVISION FOR THE OWENSBORO 8-HOUR OZONE ATTAINMENT I HOUROZONE MAINTENANCE AREA

Prepared by the KENTUCKY DIVISION FORAIRQUALITY

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

INTRODUCTION. . . . . . .. . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. . . . . . . . . . . . . . . . . . . . . . . .1 BACKGROUND. . . . . . . . . . . . .. . . . . .. .. . . . . .. . . . . .. . . . . .. . . .. .. . . . . .. . . . . .. . . .. .. . . .. .. . . .. .. . . .. .. . . .. .. . . .. .. . . . . .. . . . . . . . . . . .. .. . . .. .. . . . . .2 MAINTENANCE OF AIRQUALITY STANDARD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., . .. .2 PERMANENT ANDENFORCEABLE EMISSION REDUCTIONS . . . . . . . . .. . . . . .. . . . ., . . . . . . . . . . . . . ., . 3 POST-1990 EMISSION REDUCTION PROGRAMS . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . 3 Highway Mobile Source Reductions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4 Point Source Reductions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . .. . . .. .. . . . . .. . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7 Area Source Reductions .. .. .. .. . . .. .. .. .. .. . . .. .. . . .. .. . . .. . . . . .. . . . . .. . . . . . . . . . . . . . . . . .. . . . . .. .. . . .. .. . . .. .. . . . . . . . . . . . . . .11 Non-Highway Mobile Source Reductions . . . . . .. . . .. .. . . . . .. . . .. .. . . .. .. . . .. .. . , .. . . ., . . . . . . . .. . . . . .. ., .,12 MAINTENANCE PLAN. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . .. . . . .14 2002 MAINTENANCE AREA EMISSIONS INVENTORY. . . . . . . . . . . . . . . . . . . . 14 EMISSION PROJECTION METHODOLOGY. . .. . . . . . . . . . . .. . . .. ._. . ., . . . . . . . . . ., . 15 Point Source Projections . . . . . .. . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . .. .. . . . . . . . . . . ..18 Area Source Projections .. . . . . .. . . . . .. . . .. .. . . . . . . . . . . .. . . . . .. .. .. .. . . .. .. . . .. .. .. .. .. . . .. .. .. .. .. . . . . . . . . . . . . . . . . . . . . . . .. . .19 Non-Highway Mobile Source Projections .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. . . .. ., . . . . .. .,19 Highway Mobile Source Projections. .. .. . . . . .. . . .. .. . . .. .. . . .. .. . . .. .. . . .. .. . . .. .. . . .. .. . . .. .. . . . . . . . . . . . . . . . . . . . . . .20 Total ofAll Emissions. . . . . . . . . . . .. . . . . . . . . . . . . . . . . .. . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. . . .. .. . . .. .. . . ..20 PLANTOMAINTAIN AIRQUALITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .21 EXISTING MONITORING NETWORK . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .22 CONTINGENCY MEASURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . .. .. . . .. .. . . . . .. . . .. .. . . .. .. . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . .22 PUBLIC PARTICIPATION. . . . . . . . . . . .. . . . . .. . . . . . . . . . . .. . . . . .. . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. . . . . .. . . .. .. .24 REFERENCES . . . . . . . . . . . . . . . . . . . . . . .. . . . . .. .. . . .. .. . . .. .. . . .. .. . . .. .. .. .. .. . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. . . .. .. . . . . .. . . . . . . . . . .25APPENDICES

A- Ambient Air Quality Monitoring Information B- Map ofArea Ozone Monitors C- 2002 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 Products Guidance L- 401 KAR50:012. General ApplicationTABLE SUMMARY

TABLE 1 -SUMMARY OF OZONE EXCEEDANCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 TABLE 2 -OWENSBORO AREA MONITOR DESIGN VALUES . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. . . .. .. . . . . .. . . . . . . . . . . 3 TABLE 3 -1990 &2002 VOCEMISSIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 TABLE 4-PROJECTEDVOCEMISSIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , 16 TABLE 5-PROJECTEDCOEMISSIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 TABLE 6 - PROJECTEDNOXEMISSIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 TABLE 7 - 1990 - 2002 - 2020 EMISSIONS COMPARISONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21INTRODUCTION

On April 30, 2004 (69 FR 23858), the Environmental Protection Agency (EPA) designated and classified areas for the 8-hour Ozone National Ambient Air Quality Standard (NAAQS) . For most areas, these designations became effective June 15, 2004. EPA also published the final phase 1 rule for implementation ofthe 8-hour ozone NAAQS on April 30, 2004 (69 FR 23951) .

Section 51 .905 (c) and (d), established in that rulemaking, set forth requirements for antibacksliding purposes for areas designated attainment for the 8-hour standard. These provisions require areas to submit a 10-year maintenance plan under section 110(a)(1) ofthe Clean Air Act (CAA) if they also were a nonattainment area, or an attainment/unclassifiable area with a section 175A maintenance plan, underthe previous 1-hour ozone standard. The Owensboro Area, which includes Daviess County and a portion of Hancock County, was redesignated to attainment in January 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 ofozone monitoring data that indicates continued maintenance of the 8-hour ozone standard, the implementation ofcertain permanent and enforceable reductions in ozone precursor emissions in the area, and a maintenance plan that continues to showan emissions level that runs through 2020 .BACKGROUND

In accordance with the Clean Air Act Amendments (CAAA) of 1990, Daviess County and a portion of Hancock County of the Owensboro Metropolitan Statistical Area was designated as marginal nonattainment for the 1-hour ozone standard effective on January 6, 19921 (November 6, 1991, FR notice)

. In a November 3, 1994, Federal Register notice, the U .S. EPAapproved the redesignation of the Owensboro Area frommarginal nonattainment to attaimnent for the I-hour ozone standard effective on January 3, 19952 . On April 30, 2004 (69 FR 23858), the Environmental Protection Agency (EPA) designated and classified areas for the 8-hour groundlevel ozone National Ambient Air Quality Standard (NAAQS) . These areas are required to submit a 10-year maintenance plan under section I10(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 I-hour ozone standard. MAINTENANCE OF AIRQUALITY STANDARD The ambient air quality data for all ozone monitors in the Owensboro Maintenance Area (i .e., Daviess County and a portion of Hancock County) indicates continued maintenance of the 8- hour ozone standard. Table 1 is a summary of the days in which the 8-hour ozone standard was exceeded in Daviess County and Hancock County, and Table 2 shows the design values for these monitors.TABLE 1 SUMMARYOF OWENSBOROMAINTENANCE AREA'S 8-HOUR OZONE EXCEEDANCES

COUNTY `00 `01 `02 `03 `04 `05 `06 `07 DAViESS 0 1 4 0 0 2 1 6 HANCOCK* 0 1 7 0 1 0 1 2 *Portion of county. TABLE 2 OWENSBOROAREA MONITORDESIGNVALUES MONITOR 100 101 `02 `03 `04 `05 `06 `07 DAVIESS 0.083 0 .079 0 .077 0 .076 0 .073 0 .072 0 .074 0 .081 HANCOCK 0 .089 0 .083 0 .083 0 .082 0 .080 0 .073 0 .073 0 .076

This same monitoring information for this area is contained in the U .S. EPA's Aerometric Information Retrieval System (AIRS) database (Please see Appendix Afor ozone monitoring informationfor this area) . The ambient ozone monitoring data was collected at sites that were selected with assistance fromthe U .S. EPAand are considered to be representative ofthe area of highest concentration. The collected data were quality-assured in accordance with 40 CFR Part 58 and recorded in the U.S. EPA's AIRS database. It is anticipated that these monitors will remain at their current locations for the duration of the maintenance plan period (2002-2020) . Maps indicating the location of the monitors in the Owensboro Area counties are included in Appendix B

. PERMANENT AND ENFORCEABLE EMISSION REDUCTIONS POST-1990 EMISSION REDUCTION PROGRAMS The continued improvement and maintenance ofthe air quality in the Owensboro Maintenance Area, as verified by the lack of exceedances of the 8-hour ozone standard, is due to theimplementation ofpermanent and enforceable emission reductions.

Emission reductions (in tons per day, or tpd) are described fromvarious programs and initiatives. The following categories of sources have shown or are expected to showemission reductions in volatile organic compounds (VOC), carbon monoxide (CO), and oxides of nitrogen (NO,) emissions due to regulatory measures implemented since the passage of the 1990 Clean Air Act or since the area was designated attainment. For this SIP revision, Kentucky chose to use 2002 as the year for developing a new comprehensive ozone precursor emissions inventory fromwhich projected emissions could be developed for 2005, 2008, 2011, 2014, 2017 and 2020 . Maintenance is demonstrated by comparing the attainment year emissions to the emissions in the years listed above . The attainment year mobile emissions were recalculated using MOBILE 6.2 in order to 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 ControlProgram(FMVCP) Permanent and enforceable emission reductions have been and continue to be achieved each year through this program

. In recent years, stricter federal requirements have been imposed on automobile manufacturers for improved fuel-efficiency and extended warranties for emission control devices. Documentation ofthese emission reductions is contained in the highway mobilemodeling runs (See Appendix H) .

Fleet Turnover ofAutomobiles Permanent and enforceable emission reductions have occurred in the Owensboro Maintenance Area as a result of fleet turnover of automobiles. As older, less efficient automobiles are replaced by newer, more efficient models, the emissions decrease on a per mile basis. Quantification ofthese reductions is contained in the highwaymobile modeling runs. LowerReid VaporPressure The 1990 CAAA mandated that the Reid Vapor Pressure (RVP) of gasoline decrease from10.5 pounds per square inch (psi) in 1988, to 9 .0 psi in 1992 during the ozone season. Recent guidance fromU

.S. EPA (Region 4 and the National Vehicle and Fuel Emissions Laboratory in Ann Arbor) indicated that a RVP of 8.6 should be used, based on information from EPA's National Inventory Model (NIM) . With EPAconcurrence, Kentucky has used 8 .6 as input for the highway mobile model (i .e., MOBILE 6.2). Quantification ofthese reductions is contained in the highway mobile modeling runs. Tier 2Motor Vehicle Emissions and FuelStandards Permanent and enforceable reductions have occurred through this program . The overall Tier 2 programfocuses on reducing the passenger car and light truck emissions most responsible for causing ozone. In 2004, the Tier 2 standards began to phase in for the first time a single set of federal tailpipe emission standards that apply to all passenger cars, light trucks, and larger passenger vehicles (including sport utility vehicles, minivans, vans, and pickup trucks) operated on any fuel . In 2007, when the new standards will be fully phased in, U .S. EPA projects that nationwide NOx reductions fromcars and trucks will be 856,471 tons per year (tpy) . U .S. EPAfurther projects a NO,, reduction of 1,236,000tpy 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) . HeavyDuty Gasoline and Diesel Highway Vehicles Standards NewUSEPA standards designed to reduce NOx and VOC emissions fromheavy-duty gasoline and diesel highway vehicles began to take effect in 2004. A second phase of standards 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 ppmsince the sulfur damages emission control devices. The total program is expected to achieve a 90% reduction in particulate matter (PM) emissions and a 95% reduction in NOx emissions for these new engines using lowsulfur diesel, compared to existing engines using higher-content sulfur diesel . LargeNonroad Diesel Engines Rule In May 2004, the USEPA promulgated new rules for large nonroad diesel engines, such as those used in construction, agricultural, and industrial equipment, to be phased in between 2008 and 2014. The nonroad diesel rules also reduce the allowable sulfur in nonroad diesel fuel by over 99% . Nonroad diesel fuel currently averages about 3,400 ppmsulfur. The rule limits nonroad diesel sulfur content to 500 ppmin 2006 and 15 ppm in 2010 . The combined engine and fuel rules would reduce NOx and PM emissions from large nonroad diesel engines by over 90%, compared to current nonroad engines using higher-content sulfur diesel . NonroadSparkIgnition Engines andRecreational EnginesStandard The newstandard, which became effective in January 2003, regulates NOx, HC and CO forgroups of previously unregulated nonroad engines. This standard applies to all new engines sold in the United States and imported after these standards began and applies to large spark-ignition engines (forklifts and airport ground service equipment), recreational vehicles (off-highway motorcycles and all-terrain-vehicles), and recreational marine diesel engines. The regulation varies based upon the type ofengine orvehicle. The large spark-ignition engines contribute to ozone formation and ambient COand PM levels in urban areas. Tier 1 ofthis standard was implemented in 2004 and Tier 2 is scheduled to start 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 PMlevels, especially in marinas. Depending on the size of the engine, the standard began phasing-in in 2006 . When all of the nonroad spark-ignition engines and recreational engines standards are fully implemented, an overall 72%reduction in HC, 80% reduction in NOx, and 56% reduction in CO emissions are expected by 2020 . These controls will help reduce ambient concentrations of ozone, CO, and fine PM . (Appendix E) . Point Source Emission Reductions In the 1990 emissions inventory, the Hancock County point sources were misidentified as being located inside the former nonattainment portion of Hancock County. The point sources were actually located outside the former nonattainment portion of Hancock County and as reflected inthis SIP revision have been removed . One of the point sources in question, (Williamette Industries 21-091-00002) closed its operation on September 30, 2002. Even though this source is outside the maintenance area portion of Hancock County, its closure will assist the area with continued maintenance ofthe 1-hour ozone standard. Reasonably Available ControlMeasures (RACM) 401 KAR 50:012, Section 1(2) requires that all major air contaminant sources shall as a minimumapply control procedures that are reasonable, available, and practical ." See Appendix Kfor the full text of401 KAR50:012. Maximum

Available Control Technology (MACT) The Clean Air Act requires U.S. EPA to reviewand update its lists of categories of industries that emit one or more of 188 listed toxic air pollutants, or Hazardous Air Pollutants (HAPS) . For listed categories of major industrial sources, the lawrequires U .S. EPA to develop standards requiring those industries to achieve emission reduction equivalent to putting into place what is known as "maximumachievable control technology" (MACT) . Many ofthe HAPS under these industrial categories ofcontrols are also VOCs, and compliance with these new MACT standards as they are being promulgated will decrease VOC emissions from the affected industries. Additionally, U

.S. EPA is now

promulgating residual risk requirements for some point and area source categories. These requirements will further reduce VOCemissions. Additional Reductions - 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 ofany ozone precursors (ie., NO,) that occurred during the current 2002-2006years ofozone monitoring data.The NOx emission reductions achieved fromthe NOx SIP Call throughout the entire region and

the state of Kentucky, effective May 2004, will continue to contribute to the area's continued maintenance ofthe 8-hour ozone standard and future compliance with the ozone NAAQS. In accordance with Kentucky regulation 401 KAR 51 :180, the Division had determined from Kentucky's compliance supplement pool that electric-generating units (EGUs) had 13,469 tons available for Early Reduction Credits (ERCs) . Of the 13,469 tons for EGUs, 20%(2,694) was available for emission reductions achieved in 2001, 30%(4,041) was available for emission reductions achieved in 2002, and the remaining 50% (6,734) was available for emission reductions in 2003. Per 401 KAR 51 :180, the ERCs were used for compliance with NOx emission standards in 401 KAR 51 :160 during the 2004 and 2005 control period. However, overall the sources in each year, requested allowances for a much larger number ofozone 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 , "Requested : "Granted - 11 2001 2002 2003

YearClean AirInterstate Rule

On May 12, 2005, the USEPA promulgated "Rule To Reduce Interstate Transport of Fine Particulate Matter and Ozone (Clean Air Interstate Rule) ; Revisions to Acid Rain Program ; Revisions to the NOXSIP Call ", referred to as CAIR. This rule established the requirement for states to adopt rules limiting the emissions ofNOx 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 utilitypower 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 programif a state so chooses to participate in the program . Kentucky chose to continue the non-EGUs previously included in the NOx SIP seasonal programin 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: 36,109tons 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 KAR52:210 and 220

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

. The Kentucky CAIRregulations became effective June 13, 2007. Area Source Reductions Several control programs have been implemented to substantially reduce area source emissions fromthe following source categories. Aerosol Coatings, Architectural and Industrial Maintenance Coatings, and Commercial/Consumer Products In 1998 the U

.S. EPAoffered a guidance document promulgating federal regulations to reduce the VOC emissions fromthe application of Architectural and Industrial Maintenance Coatings (e.g. traffic paints and coatings for bridges), Auto Body Refinishing, and Commercial Consumer Products. At that time a 20%reduction was allowed, and these are the reductions included in the projections in this submittal . On May 30, 2007, the EPA published a memorandumto provide guidance concerning credit that States can take for reductions associated with three Federal rulesbeing promulgated this calendar year under authority ofsection 183 (e) ofthe Clean Air Act (see

Appendix J) . These rules will establish or amend VOC content limits for (1) aerosol coatings (newrule), architectural and industrial maintenance (AIM) coatings (amendments), and (3) household and institutional consumer products (amendments) . EPAestimates that the amended Federal AIM

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

. The compliance date for the three Federal rules will 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 fromnon-highway engines were largely uncontrolled. The nonhighway category includes outdoor power equipment, recreational vehicles (ie., scooters, mopeds, all-terrain bikes, snowmobiles, etc .), marine vessels, personal watercraft, farm and construction machinery, lawn and garden equipment, locomotives, and many other applications. Certain federal rules have been implemented since the early 1990's that have resulted in permanent and enforceable emission reductions fromthese nonroad sources.Implementedduring the 2002-2005timeframewere:

Small spark-ignition engines - This set of emissions standards for handheld applications (such as leaf blowers and chainsaws) phases in 2002 - 2007 andwill result in an additional 70percent reduction in hydrocarbons and NO,, . Large spark-ignition engines - In 2004, these emission standards began phasing in to reduce NOx and COfor many applications of industrial equipment, including forklifts, airport service equipment, generators, compressors, andwelders. Locomotives - The Tier 1 emissions standards apply to locomotives and locomotive engines manufactured from2002 through 2004, and will reduce NOX 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, the nonroad diesel rules also reduce the allowable sulfur in nonroad diesel fuel by over 99% . Nonroad diesel fuel currently averages about 3,400 ppmsulfur. The rule limits nonroad diesel sulfur content to 500 ppmin 2006 and 15 ppmin 2010 . The combined engine and fuel rules would reduce NOx and PM emissions fromlarge nonroad diesel engines by over 90%, compared to current nonroad engines using higher-content sulfur diesel . These reductions were determined using the U.S. EPA's nonroad model and are reflected in the emissions provided in this document (Appendix G) . 13TABLE 3 OWENSBORO8-HOUR OZONE MAINTENANCEAREA VOCEMISSIONS FOR1990, 2002, &2004

(TONS PERDAY)

SOURCE CATEGORY 1990 ATTAINMENTYEAR 2002 NEW PLAN 2004

LAST YEAR OLD PLAN POINT 16.52 6 .30 16.11 AREA 5.37 5.37 5.21 HIGHWAY MOBILE 11 .43* 4.08 6 .64 NoN-xwYMOBILE 3.93 __ 3.22 3.81 TOTAL EMISSIONS 37.25 18.97 31 .77 *Recalculated using MOBILE 6 .2 Table 3 summarizes VOCemissions in tons perday (tpd), from1990 and 2002, and also includes any growth in emissions that may have occurred since the 1990 attainment year. The mobile emissions numbers were generated using MOBILE 6 .2. In addition, included in the Table 3 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 a part of this SIP revision, a newozone precursor emissions inventory for 2002 was developed for the Owensboro Area (i .e., Daviess County and a portion of Hancock County) . A copy of the 2002 maintenance area emissions inventory methodology and documentation isincluded as Appendix 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 National NEI development guidance, the FAA's Emission and Dispersion and Modeling Systemmodel was utilized to calculate commercial aircraft emissions for 2002, 2005, 2008, 2011, 2014, 2017, and 2020, EPA's Nonroad Model (Core Model Version 2005a, February, 2006) was used to determine certain other nonroad (i .e., other Non-Highway) mobile source category emissions for 2002, 2005, 2008, 2011, 2014, 2017 and 2020, MOBILE 6.2 was utilized to determine highway mobile source emissions for 2002, 2005, 2008, 2011, 2014, 2017 and 2020, and the U .S. EPA's 1997 biogenic emission estimates for Kentucky counties were included in the 2002 emissions inventory per EPAguidance; (2) utilizing where applicable previous EPAemission inventory; and (3) utilizing inventory guidance obtained directly fromEPA Region 4 personnel (e.g., phone calls, e-mails) . EMISSION PROJECTION METHODOLOGY The 2002 Maintenance Area Emissions Inventory for Daviess County and a portion of Hancock 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 makeany 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 Owensboro Area in Appendix D

. Biogenic emissions have been excluded fromthese tables. Biogenic emissions for 2000 can be found in Appendix C . Based on information received from EPA, Region 4, biogenic emissions are expected to remain stable throughout the projection period. Tables 4-6 showthe projection of emissions through 2020 . The Owensboro Area's projected 2020 total VOC emissions are well belowthe 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 OWENSBORO8-HOUROZONE MAINTENANCE AREA 1990, 2002, ANDPROJECTEDVOCEMISSIONS

(TONS PER DAY) 1990-2020 COUNTY 1990 2002 2005 2008 2011 2014 2017 2020 POINT 13.23 6 .23 6

.57 6

.95 7.21 7.58 7.98 8.36 AREA 5.29 5.23 5.28 5.34 5.44 5.51 5.59 5.67 HIGHWAY 11 .20* 3.98 2 .90 2.60 2.29 1 .95 1 .74 1 .56 Norl-HwY 3.84 3.03 2 .91 2.67 2.46 2.32 2.21 2.14 DAVIESS 33.56 18.47 17.66 17.56 17.40 17.36 17.52 17.73 POINT 3.30** 0 .07 0

.07 0

.08 0

.08 0

.08 0

.09 0

.09 AREA 0

.08 0

.14 0

.14 0

.14 0

.14 0

.14 0

.14 0

.14 HIGHWAY 0

.23* 0.10 0

.07 0

.07 0.06 0

.05 0

.04 0

.04 NON-HwY 0

.09 0

.19 0

.17 0

.15 0

.13 0

.12 0

.12 0.12 HANCOCK*** 3.70 0 .50 0

.45 0

.44 0

.41 0

.39 0

.39 0

.39 TOTAL 37.26 18.97 18.11 18.00 17.81 17.75 17.91 18.12 Recalculated using Mobile 6.2 **In the 1990 emissions inventory, the Hancock County point sources were misidentified as being located inside the former nonattainment portion of Hancock County. The point sources were actually located outside the former nonattainment portion of Hancock County . Therefore, point source emissions for the portion of Hancock County should have been zero in 1990. ***Portion of county. 16TABLE 5 OWENSBORO8-HOUR OZONE MAINTENANCE AREA 1990, 2002, AND PROJECTED COEMISSIONS

(TONS PER DAY) 1990-2020 COUNTY 1990 2002 2005 2008 2011 2014 2017 2020 POINT 2

.52 1 .33 1 .40 1 .46 1 .51 1 .55 1 .62 1 .69 AREA 2

.45 2.15 2.17 2 .20 2.24 2.27 2.30 2.33 HIGHWAY 104.40* 42.24 28.90 25.78 23.85 21 .85 20.94 20.54 NoN-Hwy 20.60 25.65 27.08 27.97 28.65 29.23 30.01 30.98 DAVIESS 129

.97 71 .37 59.55 57.41 56 .25 54.90 54.87 55.54 POINT 34.17** 0.11 0 .11 0

.12 0

.12 0.13 0.14 0 .14 AREA 0

.04 0.14 0

.14 0

.14 0

.14 0.14 0

.14 0

.14 HIGHWAY 2.52* 1 .29 0 .85 0

.76 0

.70 0.63 0

.60 0

.59 NoN-Hwy 0

.45 0.78 0

.76 0

.72 0

.65 0.58 0

.55 0

.54 HANCOCx*** 37.18 2.32 1 .86 1 .74 1 .61 1.48 1.43 1 .41 TOTAL 167.15 73.69 61 .47~ 59.15 57.86 56.38 56 .30 ~ 56

.95 I *Recalculated using Mobile 6.2 **In the 1990 emissions inventory, the Hancock County point sources were misidentified as being located inside the former nonattainment portion of Hancock County. The point sources were actually located outside the former nonattainment portion of Hancock County . Therefore, point source emissions for the portion of Hancock County should have been zero in 1990. ***Portion of county. TABLE 6 OWENSBORO8-HOUROZONE MAINTENANCE AREA 1990, 2002, ANDPROJECTEDNOXEMISSIONS

(TONS PERDAY) 1990-2020 COUNTY 1990 2002 2005 2008 2011 2014 2017 2020 POINT 39.20 34.74 36.14 37.59 38.58 39.95 41 .37 42.84 AREA 0

.22 0

.18 0

.18 0

.18 0

.18 0

.19 0

.19 0

.20 HIGHWAY 7.17* 5.97 4 .64 4.10 3.37 2 .56 2

.02 1 .68 NoN-Hwy 2.91 3.49 3.35 3.09 2.80 2 .44 2.11 1 .85 DAVIESS 49.50 44.38 44.31 44.96 44.93 45.14 45.69 46.57 POINT 42.86** 0 .05 0

.05 0.05 0

.06 0

.06 0

.06 0

.06 AREA 0

.00 0

.01 0

.01 0.01 0

.01 0

.01 0

.01 0

.01 HIGHWAY 0

.17* 0

.18 0

.13 0

.12 0

.10 0

.07 0

.06 0

.05 NoN-Hwy 0

.16 0

.25 0

.24 0

.23 0

.21 0

.20 0

.19 0

.19 HANCOCx*** 43.19 0 .49 0

.43 0

.41 0

.38 0

.34 0

.32 0

.31 TOTAL 92.69 44.87 44.74 45.37 45.31 45 .48 46

.01 46.88 *Recalculated using Mobile 6.2 **In the 1990 emissions inventory, the Hancock County point sources were misidentified as being located inside the former nonattainment portion of Hancock County. The point sources were actually located outside the former nonattainment portion of Hancock County . Therefore, point source emissions for the portion of Hancock County should have been zero in 1990. ***Portion ofcounty. 17The emissions inventory is broken down into four components: point, area, highway mobile, and

non-highway mobile sources. Using 2002 as the new base emissions year, the subsequent years were chosen at three-year or longer intervals that project maintenance for at least a 10-year period pending approval of the revision to the SIP . Necessary calculations for the projections were made using EXCEL software. A description of howgrowth factors for each emission category were obtained and used follows. The documentation showing howemissions were grown is included in Appendices E through H . Point Source Projections For this inventory purpose, point sources are defined as stationary sources that emit 10 tons or more per year (tpy) ofVOC, or 100 tpy or more of NOX or CO . Emissions are calculated from data collected annually frompoint sources. Point source information is stored in an existing Kentucky I-Steps database and certain information fromthis database has been provided for the U .S. EPA's NEI . Utilizing Standard Industrial Codes (SIC), all point source emission projections were based on growth factors calculated using Bureau of Economic Analysis (BEA) projection data for employment, as suggested by the U .S. EPA and utilized for previous point source projections. The point source data provided SICcodes used to determine a short title description that matched the corresponding description found in the BEAdata. The application of growth factors for each projection was then used for point sources. Appendix E provides information on 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 Center3 and can be found in Appendix F. Non-Highway Mobile Source Projections The non-highway mobile category is broken down into three groups that include 2 and 4-cycle gasoline engines and diesel engines (other non-highway engines), railroad locomotives, and aircraft. Emissions are estimated by multiplying the base year inventory by a known indicator of collective activity such as fuel consumed or landing/takeoff operations. For locomotive and aircraft emission projections, population growth factors for each chosen year were calculated using the before mentioned formula. The application ofthese growth factors for each projection was then used for each of these non-highway categories. For other non-highway categories (e.g., industrial equipment, tractors, leaf blowers), the U .S. EPA's nonroad model was used to determine the future year projections. Nonroad model and non-highway projection information can be found in Appendix G . Updated minimumand maximumsummer temperatures and ambient temperatures were utilized for input into the nonroad model . EPA Volume IV mobile source guidance was followed in determining the updated temperature data. Please see 19Appendix Cfor specific temperature documentation.

Highway Mobile Source Projections To calculate highway mobile source emissions, the Division obtained data on Daily Vehicle Miles Traveled (DVMT) and speeds for 2002, 2005, 2008, 2011, 2014, 2017 and 2020 fromthe Kentucky Transportation 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 minimumand 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 7 below shows that the Owensboro area projected 2020 VOC and NOx emissions are less than the 1990 attainment year VOC and NOx emissions, thus demonstrating continued maintenance of the 8-hour ozone standard. Additionally, the Division for Air Quality has been notified by the electric utility in DaviessCounty (i .e., Owensboro Municipal Utility) that it is in the process ofcompleting installation of

NO,, emission controls to comply with the NO,{ SIP Call . This action is anticipated to lower the NO, emissions in the area. TABLE 7 OWENSBORO8-HOUR OZONE MAINTENANCE AREA 1990 - 2002 - 2020 EMISSIONS COMPARISONS

(TONS PERDAY) 1990 2002 2020 ' SOURCE CATEGORY VOC CO NO, VOC CO NOX VOC CO ' NOX I POINT 16.52 36.69 82.05 6.30 1 .44 34.79 8.45 1 .83 42.90 AREA 5.37 2.49 0.22 5.37 2.29 0 .19 5.81 2.47 0 .21 HIGHWAY MOBILE 11 .43* 106.92* 7.34* 4 .08 43.53 6

.15 1 .60 21 .13 1 .73 NoN-HWY MOBILE 3.93 21 .05 3.07 3.22 26.43 3.74 2.26 31 .52 2.04 I TOTAL** EMISSIONS 37.25 167.15 92.68~ 18.97 ~ 73.69-1 44.87 ~ 18.12 I 56.95 I 46.88 -; * Recalculated using Mobile 6.2 **In the 1990 emissions inventory, the Hancock County point sources were misidentified as being located inside the former nonattainment portion of Hancock County. The point sources were actually located outside the former nonattainment portion of Hancock County . Therefore, point source emissions for the portion of Hancock County should have been zero in 1990. See Tables 3 - 5.

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

major 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 21requirements as well as the BACT requirement ofthe DAQPSDregulations;

Federal Motor Vehicle Control Standards apply in Kentucky; Prevention ofSignificant Deterioration requirements; " Federal Controls on certain nonroad engines (e.g. diesel and other fuel requirements, industrial diesel equipment, locomotives) after 2000 ; " Federal controls on the VOCcontent for Architectural and Maintenance Paints, Auto Body Shops, and Consumer Products; The state open burning regulation to further limit types of burning in the former 8-Hour Maintenance area-Owensboro. In addition to these measures, further reductions will be achieved throughout the continued implementation of newfederal regulations to further control the emission of Hazardous Air Pollutants that are VOCs (40 Code ofFederal Regulations 63, NESHAPS)

. Also, on March 10, 2005, the U

.S. EPAfinalized the Clean Air Interstate Rule (CAIR) . NOx emissions frompower plants will be cut by 1 .7 million tons by 2009 and emissions will be reduced by 1 .3 million tons in 2015 in 28 eastern states and the District of Columbia. These reductions cannot be quantified at this time, but will be reflected in future assessments. EXISTING MONITORING NETWORK In addition to the maintenance plan discussed above, the existing ozone monitoring network located in the Owensboro Area has been approved by the U .S. EPA . The monitoring network will continue to remain operational in accordance with 40 CFRPart 58. CONTINGENCY MEASURES Future reviews 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 22review the assumptions made for the purpose of the maintenance demonstration concerning

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 ofthe 8-hour ozone standard in the Owensboro Area, the Commonwealth commits to adopt, within nine months, one or more ofthe following contingency measures to re-attain the standard. All regulatory programs will be implemented within 18 months. Y Implementation ofa program to require additional emission reductions on stationary sources; i= Requirement for Stage I VaporRecovery; ;~ Requirement for Stage II Vapor Recovery; r Open burning ban during summer ozone season; ;~ Restriction ofcertain roads or lanes to, or construction ofsuch roads or lanes for use by, passenger buses or high-occupancy vehicles; ~ Trip-reduction ordinances; ;~ Employer based transportation management plans, including incentives; i= Programs to limit or restrictvehicle use in downtown areas, or other areas ofemission concentration, particularly during periods ofpeak use; Programs for new

construction and major reconstructions of paths or tracks for use by pedestrians or by non-motorizedvehicles 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.PUBLICPARTICIPATION

Kentucky has scheduled a public hearing to receive comments on this proposed SIP revision for the Owensboro 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 Owensboro Area (i .e., Daviess County and a portion of Hancock County) for the Ozone Standard. 2. November 3, 1994, Federal Register Notice. Approval of Redesignation to Attainment for the Owensboro Area - Effective on January 3, 1995. September 3, 1998, Federal Register Notice. Approval of Revision to the Owensboro Area Maintenance Plan - Revised Motor Vehicle Emissions Budgets (MVEBs) for the Owensboro Area - Effective on November 2, 1998. April 9, 2002, Federal Register Notice. Clarification Regarding the Year (2004) of the Revised Motor Vehicle Emissions Budgets (MVEBs) for the OwensboroArea - Effective on May 9, 2002. 3. University of Louisville - State Data Center - Population Projections for Kentucky.