STEVEN L. BESHEAR

GOVERNOR

Ms. Gwendolyn Keyes Fleming Regional Administrator

U.S. EPA, Region 4

Sam Nunn Atlanta Federal Center

61 Forsyth Street, SW
Atlanta, Georgia 30303 

### ENERGY AND ENVIRONMENT CABINET

OFFICE OF THE SECRETARY

500 MERO STREET

12TH FLOOR, CAPITAL PLAZA TOWER

FRANKFORT, KY 40601

TELEPHONE: 502-564-3350

FACSIMILE: 502-564-3354

February 9, 2012

RE: Redesignation ofKentucky Portion ofthe Huntington-Ashland WV-KY-OH

Fine Particulate Nonattainment Area

Dear Ms. Fleming: LECNARD K. PETERS

SECRETARY

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

the Kentucky portion of the Huntington-Ashland WV-KY-OH PM 2

. 5 nonattainment area (Boyd and a portion ofLawrence County) as attainment for the PM 2

. 5 National Ambient Air Quality Standard.

A public hearing to receive comments on this revision was scheduled for December 22, 2011, at 6:00 p.m. in

the Conference Room of the Ashland-Boyd County Health Department, 2916 Holt Street, Ashland, Kentucky. No request

for a public hearing was received, and the hearing was cancelled. Comments were received during the 30-day comment period. A copy of the public hearing notice and the statement of consideration are included in this submittal.

West Virginia and Ohio are making separate redesignation requests for their respective portions of the metropolitan area and have submitted those demonstrations to U.S. EPA, Region 5.

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

this matter, please contact Andrea Smith with the Division for Air Quality at (502) 564-3999.

Enclosures

cc: Beverly Banister

R. Scott Davis Sincerely yours,

Leonard K. Peters
Secretary

# REDESIGNATION REQUEST AND

MAINTENANCE PLAN FOR

THE KENTUCKY PORTION OF THE

HUNTINGTON

- ASHLAND

, OH

- KY

- WV

ANNUAL PM 2.5 

# NONATTAINMENT AREA

Boyd and a portion of Lawrence Counties, Kentucky

Prepared b y: Energy and Environment Cabinet Kentucky Division for Air Quality

February 8

, 201 22 

### Th is page left intentionally blank3 

### TABLE OF CONTENTS

Chapter One

- Introduction

................................ ................................ ................................ ........ 7 Geographical description and background

................................ ................................ ................. 8

Status of air quality

................................ ................................ ................................ ..................... 9

Clean Data Determination

................................ ................................ ................................ .......... 9

Chapter Two

- Requirements for redesignation

................................ ................................ ..... 1 1

Chapter Three

- PM 2.5 monitoring

................................ ................................ ............................ 1 6 Ambient data quality assured

................................ ................................ ................................ ... 1 6 Data handling guidelines

................................ ................................ ................................ .......... 1 6 Commitment to continue monitoring

................................ ................................ ......................... 20

Chapter Four

- Emission inventory

................................ ................................ ......................... 2 1

Base y ear i nventory

................................ ................................ ................................ .................. 2 1

Emission p rojections

................................ ................................ ................................ ................ 2 2

Demonstration of maintenance

................................ ................................ ................................ . 3 1

Permanent and en forceable emissions reductions

................................ ................................ ... 4 7

Provision for future inventory update

................................ ................................ ........................ 4 8

Chapter Five

- Control measures and regulations

................................ ................................ . 4 9

N onattainment areas to implement RACM and RACT

................................ .............................. 4 9

Show Rea sonable Further Progress (RFP)

................................ ................................ .............. 50

Emission inventories

................................ ................................ ................................ ................ 50 Implementation of p revious SIP r evisions

................................ ................................ ................. 5 1 New source review provisions

................................ ................................ ................................ . 5 9

As surance of continued controls

................................ ................................ .............................. 5 9

Chapter Six

- Contingency measures

................................ ................................ ..................... 60

Commitment to revi ew maintenance plan

................................ ................................ ................. 60

Commitm ent for contingency measures to be implemented

................................ ..................... 60

P otential contingency measures

................................ ................................ ............................... 61

List of PM 2.5 , SO 2 , and NO

x sourc es

................................ ................................ ......................... 6 2

Chapter Seven Public participation

................................ ................................ ................................ ................... 6 3

Chapter Eight

Conclusions

................................ ................................ ................................ ............................. 6 44 FIGURES

Figure 1 Map of the Huntington

- Ashland , OH

- KY

- WV nonattainment area and monitor locations

.............................. 1 7 Figure 2 PM 2.5 Annual Mean National Trends

................................ ................................ ................................ .............. 20

TABLES

Table 1

............ Monitoring Data for Huntington

- Ashland, OH

- KY

- WV area for 2008

- 2010

................................ .... 1 9

Table 2

............ Adams County, Ohio Emission Estimations for On

- road Mobile Sources

................................ ....... 2 8

Table 3

............ Gallia County, Ohio Emission Estimations for On

- road Mobile Sources

................................ ......... 2 8

Table 4

............ Lawrence County, Ohio Emission Estimations for On

- road Mobile Sources

................................ ... 2 8

Table 5

............ Scioto County, Ohio Emission Estimations for On

- road Mobile Sources

................................ ......... 2 8

Table 6

............ Summary of Ohio Emissions Estimations for On

- road Mobile Sources

................................ .......... 2 8

Table 7

............ B oyd County, Kentucky Emission Estimations for On

- road Mobile Sources

................................ ... 2 9

Table 8

............ Lawrence Coun ty (partial) , Kentucky Emission Estimations for On

- road Mobile

Sources

................................ ................................ ................................ ................................ .......... 2 9

Table 9

............ Summary of Kentucky Emission Estimations for On

- Road Mobile Sources

................................ .... 2 9

Table 10

............ Cabell County, West Virginia Emission Estimations for On

- road Mobile Sources

........................... 2 9

Table 11

............ Mason County (partial) , West Virginia Emission Estimations for On

- road Mobile

Sources

................................ ................................ ................................ ................................ .......... 30

Table 12

............ Wayne County, West Virginia Emission Estimati ons for On

- road Mobile Sources

.......................... 30

Table 13

............ Summary of West Virginia Emissions Estimatio ns for On

- road Mobile Sources

............................ 30

Table 1 4

............ Emission Estimations Totals for On

- road Mobile Sources for Huntington

- Ashland

Area

................................ ................................ ................................ ................................ .......... 30

Table 1 5

............ Percent of M obile Emissions for the Huntington

- Ashland Area in 2015 and 2022

........................... 3 1

Table 1 6

............ Reductions in SO 2 and NO
x EGU Emissions Between 1990 and 20 1 0.

................................ .......... 3 4

Table 1 7

............ Adams County, Ohio PM 2.5 Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 2015 and 2022 (tpy)

– Without CAIR.

................................ ............ 3 6

Table 1 8

............ Gallia County, Ohio PM 2.5 Emission Inventory Total for Base Year 2005, Estimated

2008, and Projected 2015 and 2022 (tpy)

– Without CAIR.

................................ ............................. 3 6

Table 19

............ Lawrence County, Ohio PM 2.5 Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 2015 a nd 2022 (tpy)

– Without CAIR.

................................ ............ 3 6

Table 2 0

............ Scioto County, Ohio PM 2.5 Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 2015 a nd 2022 (tpy)

– Without CAIR.

................................ ............ 3 7

Table 2 1

............ Bo yd County, Kentucky PM 2.5 Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 2015 a nd 2022 (tpy)

– Without CAIR.

................................ ............ 3 7

Table 2 2

............ Lawrence County, Kentucky PM 2.5 Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 2015 a nd 2022 (tpy)

– Without CAIR.

................................ ............ 3 7

Table 2 3

............ Cabell County, West Virginia PM 2.5 Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 2015 and 2022 (tpy)

– Without CAIR

................................ ............. 3 8

Table 2 4

............ Mason County, West Virginia PM 2.5 Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 2015 and 2022 (tpy)

– Without CAIR

................................ ............. 3 8

Table 2 5

............ Wayne County, West Virginia PM 2.5 Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 2015 and 2022 (tpy)

– Without CAIR

................................ ............. 3 8

Table 2 6

............ Huntington

- Ashland Area PM 2.5 Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 2015 a nd 2022 (tpy)

– Without CAIR.

................................ ............ 3 9

Table 2 7

............ Adams County, Ohio NO
x Emission Inventory Total for Base Year 2005, Estimated

2008, and Projected 20 15 and 2022 (tpy)

– With CAIR

................................ ................................ ... 3 9

Table 2 8

............ Gallia County, Ohio NO
x Emission Inventory Total for Base Year 2005, Estimated

2008, and Projected 2015 and 2022 (tpy)

– With CAIR

................................ ................................ .. 3 9

Table 29

............ Lawrence County, Ohio NO
x Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 201 5 and 2022 (tpy)

– With CAI R.

................................ ................. 40

Table 3 0

............ Scioto County, Ohio NO
x Emission Inventory Total for Base Year 2005, Estimated

2008, and Projected 201 5 and 2022 (tpy)

– With CAIR.

................................ ................................ .. 40

Table 3 1

............ Bo yd County, Kentucky NO
x Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 2015 and 2022 (tpy)

– With CAIR.

................................ ................. 40

Table 3 2

............ Lawrence County, Kentucky NO
x Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 20 15 and 2022 (tpy)

– With CAIR

................................ .................. 4 1

Table 3 3

............ Cabell County, West Virginia NO
x Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 201 5 and 2022 (tpy)

– With CAIR.

................................ ................. 415 Table 3 4

............ Mason County, West Virginia NO
x Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 20 15 and 2022 (tpy)

– With CAIR.

................................ ................. 41

Table 3 5

............ Wayne County, West Virginia NO
x Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 201 5 and 2022 (tpy)

– Wi th CAIR.

................................ ................. 4 2

Table 3 6

............ Huntington

- Ashland Area NO
x Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 201 5 and 2022 (tpy)

– With CAIR.

................................ ................. 42

Table 3 7

............ Adams County, Ohio SO 2 Emission Inventory Total for Base Year 2005, Estimated

2008, and Projected 20 15 and 2022 (tpy)

– With CAIR

................................ ................................ ... 42

Table 3 8

............ Gallia County, Ohio SO 2 Emission Inventory Total for Base Year 2005, Estimated

2008, and Projected 2015 and 2022 (tpy)

– With CAIR

................................ ................................ ... 4 3

Table 39

............ Lawrence County, Ohio SO 2 Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 2015 and 2022 (tpy)

– With CAIR

................................ .................. 43

Table 4 0

............ Scioto County, Ohio SO 2 Emission Inventory Total for Base Year 2005, Estimated

2008, and Projected 2015 and 2022 (tpy)

– With CAI R

................................ ................................ ... 4 3

Table 4 1

............ Boyd County, Kentucky SO 2 Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 201 5 and 2022 (tpy)

– With CAIR.

................................ ................. 4 4

Table 4 2

............ Lawrence County, Kentucky SO 2 Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 20 15 and 2022 (tpy)

– With CAIR

................................ .................. 4 4

Table 4 3

............ Cabell County, West Virginia SO 2 Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 2015 and 2022 (tpy)

– With CAIR

................................ .................. 4 4

Table 4 4

............ Mason County, West Virginia SO 2 Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 2015 and 2022 (tpy)

– With CAIR

................................ .................. 4 5

Table 4 5

............ Wayne County, West Virginia SO 2 Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 2015 and 2022 (tpy)

– Wit h CAIR

................................ .................. 4 5

Table 4 6

............ Huntington

- Ashland Area SO 2 Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 2015 and 2022 (tpy)

– With CAIR

................................ .................. 4 5

Table 4 7

............ Huntington

- Ashland Comparison of 2008 attainment year and 2015 and 2022

proje cted emission estimates (tpy)

................................ ................................ ................................ .. 4 6

Table 4 8

............ Huntington

- Ashland Area Combined Comparison of 2005 base year and 2008

attainment y ear on

- road , non

- road and EGU reductions

................................ ................................ . 4 8

APPENDICES

A

............ Air Quality System (AQS ) Data and Federal Registers

B

............ Kentucky 2005 SIP Base Year Inventory Discussion , S preadsheets

,

and QAPP letter

C

............ Mobile Source Emissions Inventory for the Huntington

- Ashland PM 2.5

Nonattainment Area and USEPA Finding of Insignificance letter,

March 2 3, 2010

D

............ VISTA and LADCO Technical Support Document s
E

............ Kentucky’s PM 2.5 Attainment Demonstration submitted December 31,

2008 ( provided as electronic copy on disc) and Federal Register

F

............ Public Participation Documentation and Statement of Consideration6 

### This page left intentionally blank7 

### REDESIGNATION REQUEST AND MAINTENANCE PLAN

FOR THE KENTUCKY PORTION OF THE HUNTINGTON

- ASHLAND

, OH

- KY

- WV

ANNUAL PM 2.5 

### NONATTAINMENT AREA

Boyd and a portion of Lawrence Counties

, Kentucky



## CHAPTER ONE

- I NTRODUCTION

The Clean Air Act (CAA) requires each State with areas failing to meet the

annual National Ambient Air Quality Standard s (NAAQS) to develop State Implementation Plans (SIPs) to expeditiously attain and maintain the

standard s

. T he United States Enviro nmental Protection Agency (U.S. EPA )

revised the NAAQS for particulate matter in July 1997. It replaced the existing PM 10 

### standard with a health based PM 2.5 1 

### standard and retained

the PM 10 

### standard as a particulate standard protecting welfare. The

standar ds include an annual standard set at 15 .0 micrograms per cubic

meter (μg/m 3 

### ) , based on the 3

- year average of annual mean PM 2.5 

### concentrations and a 24

- hour standard of 65 μg/m 3 

### , based on the 3

- year average of the 98 th 

### percentile of 24

- hour concentrations

.

The revised NAAQS was legally challenged in the U.S. Court of Appeals for the District of Columbia Circuit ( the D.C. Circuit). On May 14, 1999, the D.C. Circuit remanded, without vacatur, the standards back to U.S. EPA.

The remand did not question the lev el at which U.S. EPA set the standards but rather the constitutionality of the CAA provision that authorizes U.S. EPA to set national air quality standards. U.S. EPA requested a rehearing

which the D.C. Circuit denied. Therefore, in December 1999, U.S. EP A appealed the D.C. Circuit decision to the U.S. Supreme Court. The U.S. Supreme Court issued a decision on February 27, 2001 that unanimously affirmed the constitutionality of the CAA provision but did remand several other issues back to the D.C. Circuit, including the issue of whether U.S. EPA acted arbitrarily and capriciously in establishing the specific levels of

the standards.

The D.C. Circuit heard arguments in this remanded case in December 2001, and issued its decision on March 26, 2002. The D.C. Circuit rejected the claims that the U.S. EPA had acted arbitrarily and capriciously in setting the levels of the standards.

1 Particle pollution is a mixture of microscopic solids and liquid droplets suspended in air. This pollution, also known as particulate matter, is made up of a number of components, including acids (such as nitrates and sulfates), organic chemicals, metals, soil or dust particles, and allergens (such as fragments of pollen or mold spores). Fine particle pollution or PM 2.5 describes particulate matter that is 2.5 micrometers in diameter and

smaller

- 1/30th the diameter of a human hair. Fine particle pollution can be emitted directly or formed secondarily in the atmosphere.8



### On December 17, 2004, U.S. EPA promulgated the initial PM 2.5 

### nonattainment areas designations for the PM 2.5 

### standards across the country. Modifications to those designations were made and an effective date was set at April 5, 2005. 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 s everity of the ozone levels, PM 2.5 

### nonattainment designations are simply labeled “nonattainment.” The CAA Amendments require states with PM 2.5 

### nonattainment areas to submit a plan within three years of the effective date of the designations (April 5, 2008) detailing how the PM 2.5 

### standards wi ll be attained by April 5, 2010.

The Kentucky Division for Air Quality (KYDAQ) submitted its attainment

demonstration for the entire state on December 3, 2008.

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

areas to be redesignated to attainment provid ed certain criteria are met. The following are the criteria that must be met in ord er for an area to be redesignated from nonattainment to attainment:

i) A determination that the area has attained the PM 2.5 

### standard. ii) An approved State Implementation Plan (SIP) for the area

under Sectio n 110(k ). iii) A determination that the improvement in air quality is due to permanent and enforceable reductions in emissions resulting from implementation of the SIP and other federal requirements. iv) A fully approved maintenance plan under Section 175(A). v) A determination that all Section 110 and Part D requirement s have been met.

This document addresses each of these requirements, and provides additional information to support continued compliance with the annual

PM 2.5 

### standard.

Geographical Description and Background

The current Huntington

- Ashland nonattainmen t area is located in eastern Kentucky and includes the following counties : Boyd and Lawrence (partial

nonattainment of Lawrence County described by U.S. Census 2000 block group identifier 21

- 127

- 9901

- 6 ) in Kentucky ; Adams (partial nonattainment

of Monroe and Sprigg t ownship s only), Gallia (partial nonattainment of

Cheshire Township only), Lawrence and Scioto in Ohio; and Cabell, Wayne and Mason (partial nonattainment of Graham Tax District only), in West Virginia

. This area is shown in Figure 1 under Chapter Three.9



### As a result of th e 2005 PM 2.5 

### designations, U.S. EPA designated the Huntington

- Ashland area nonatt ainment for the 15.0 μg/m 3 

### annual

standard 2 

### , and KYDAQ was required to develop a plan to reduce oxides of nitrogen (NO

x 

### ), sulfur dioxide (SO 2 

### ) and direct PM 2.5 

### emissions and to demonstrate that the area will meet the federal annual air quality standard by April 5, 2010. Kentucky ’s main PM 2.5 

### components are primary particles (organic carbon, crustal material, and elemental carbon), SO 2 

### and NO

x 

### , which were included in the attainment demonstration analysis. V olatile organic compounds (VOCs) and ammonia (NH 3 

### ) were not included in the analysis since they were not part of Kentucky ’s current attainment strategy

for PM 2.5 

### (although controls for VOCs have been implemented for ozone nonattainment). This is consistent with U.S. EPA’s Clean Air Particle Implementation Rule [7 2 FR 205 8 6] (hereafter referred to as “Implementation Rule”). In the Implementation Rule

, U.S. EPA pres umes
NH 3 

### emissions are not a PM 2.5 

### attainment plan precursor and that States are not required to address VOC unless the State or U.S. EPA makes technical demonstration that emissions of VOCs significantly contribute to

nonattainment of the annual PM 2.5 

### sta ndard

.

T his document is intended to support Kentucky ’s request that the Kentucky portion of the Huntington

- Ashland area be redesignated from

nona ttainment to attainment for the annual PM 2.5 

### s tandard

. In addition, the

States of Ohio and West Virginia also intend to submit requests for their respective portions of the Huntington

- Ashland area. The Ohio Environmental Protection Agency submitted their proposed redesignation of the Ohio portion on May 4, 2011. The U. S. EPA published that proposal in the Federal Register on December 22, 2011. (see Appendix A)

Status of Air Quality

PM 2.5 

### complete quality

- assured ambient air monitoring data for the m ost recent three (3) years, 2008 through 2010 , demonstrate that the air quality

has m et the NAAQS for annual PM 2.5 

### in this nonattainment area. The NAAQS attainment, accompanied by decreases in emission lev els discussed in Chapter Four, supports a redesignation to attainment for the Kentucky portion of the Huntington

- Ashland area based on t he requirements in Section 107(d)(3)(E) of the CAA as amended

.

Clean Data Determination

In the Federal Register [76 FR 55542 ] published September 7, 2011 (Appendix A) , U.S. EPA made making two determinations regarding the Huntington

- Ashland PM 2.5 

### nonattainment area

. First, that the area has

attained the 1997 annual PM 2.5 

### NAAQS based upon data available in U.S. EPA’s Air Quality System (AQS)

. T his determination suspended the requi rements for the area to submit attainment demonstrations and

associ ated reasonabl y available control measures (RACM) , a reasonable

2 There were no monitors in Kentucky that violated the 1997 24

- hour PM 2.5 standard of 65 μg/m 3

.10



### further progress (RFP) plan, contingency measures, and other planning SIP revisions related to attainment of the standard for so long as the area

continues to attain the annual PM 2.5 

### standard. Second, based on qualityassured and certified monitoring data for the 2007-2009 period, the area has attained the NAAQS by its applicable attainment data of April 15, 2010.11



## C HAPTER TWO

– R EQUIREMENTS FOR REDESIGNATION

U.S. EPA has published detailed guidance in a document entitled Procedures for Processing Requests to Redesignate Areas to Attainment (redesignation g uidance ), issued September 4, 1992 , to Regional Air Directors. The redesignation request and maintenance plan are based on the redesignation g uidance, supplemented with additional guidance

re ceived from staff of U.S. EPA Region 4

.

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

- Ashland area.

i.) 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. The data that is used to demonstrate attainment should be the product of ambient monitoring that is representative of the area of highest concentration. The data should be collected and quality

- assured in accordance with

40 CFR 58 and recorded in the AQS in order for it to be available to the public for review.

The second component relies upon supplemental U.S. EPA

approved air quality modeling but is not required

. Therefore,

no modeling was included in this redesignat ion request

.

ii.) Permanent and enforce able 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 enforce able. The state should estimate the percent reduction achieved f rom federal measures as well as

from control measures that have been adopted and implemented by the state.

For this PM 2.5 

### redesignation, it was not necessary for Kentucky to adopt or implement local control measures

b eyond the federal measures.

KYDAQ adopted several rules that will have an impact on statewide PM 2.5 

### emissions in the future:

Clean Air Interstate Rule (CAIR)

NO

x 

### SIP Call Rules12 

### In addition, since the initial PM 2.5 

### designations were made

, federally enforceable consent decrees have resulted in

reductions in emissions from utilities across the state.

Chapter Four discuss es th ese reductions in more detail in the

demonstration of maintenance portion

, Requirement 3 of 5 (page 31)

.

iii .) 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.

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 4 of Part D consists of more specific requirements applicable to particulate matter (specifically to address PM 10 

### ). How ever, for the purpose of implementing the 1997 PM 2.5 

### standard, U.S. EPA’s Implementation Rule stated Subpart 1, rather than Subpart 4, is appropriate for the purpose of implementing

PM 2.5 

### [72 FR 20589]

.

i.) Section 110(a) requirements Section 110(a) of T itle I of the CAA contains the general requirements for a SIP . Section 110(a)(2) provides that the implementation plan 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 measures, 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 monit or 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 P art C,

p revention of s i gnificant d eterioration (PSD) and P art D, new source review ( NSR ) permit programs; include criteria for stationary source emission control

measures, mon itoring and reporting; include provisions for air quality modeling; and provide for public and

local age ncy participation in planning and emission control rule development. In Kentucky ’s September 8,13 

### 2009, infrastructure SIP submissions, Kentucky

verified that the S tate fulfills the requirements of Section 110(a)(2) of the Act.

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 t o achieve reasonable progress toward the national visibility goal for Federal class I areas (national parks and wilderness areas). In order to assist States in addressing their obligations regarding regionally transported pollution, U.S. EPA finalized CAIR to
reduce SO 2 

### and NO

x 

### emissions from large electric generating units (EGU). Kentucky ha d met the requirements of the federal CAIR to reduce NO

x 

### and

SO 2 

### emissions contributing to downwind states. On February 2 , 200 7

, Kentucky ’s Administrative Regulatio ns ( KAR) 401 KAR 51:210, 401 KAR 51:220,

and 401 KAR 51:220 became effective

. The CAIR replacement rule was finalized on July 6, 2011, as the

Cross

- State Air Pollution Rule (CSAPR) and will further assist States in addressing their obligations regarding regionally transported pollution by providing

reductions in NO

x 

### and SO 2 

### emissions in 2012 and

2014.

In the interim, the Kentucky regulations are still providing reductions. According to U.S. EPA in the

Nation al Program & Grant Guidance (Draft, February

2 5, 2011, Publication EPA

- 440

- 11

- 001) page 12

state s :

“ 2009 was the first compliance season for the

CAIR seasonal NO

x 

### program. There were 3,279 affected units: 3,071 electricity generating units (EGUs) and 208 industrial units. Through a wide range of pollution control strategies and an

active seasonal NO

x 

### allowance trading market, emissions by the affected sources have

continued to decrease. Between 2008 and 2009, ozone season NO

x 

### emissions fell in DC and every state of the 25 states participating in

the CAIR NO

x 

### seasonal program. Units in the14 

### program reduced their overall NO

x 

### emissions from 689,000 tons to 495,000 ton s. ”

Thus, the overall NO

x 

### emissions of 495,000 in 2009 is a 28% reduction from the previous level of 689,000 tons per year in 2008.

ii.) Section 172(c) requirements This Section contains general requirements for nonattainment plans. The requirements for reasonable further progress, 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. Chapters Four and Five discuss this requirement

in more detail.

i i i.) 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 st ate 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.

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

S ection 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 175(A). The maintenance plan will constitute a SIP revision and must provide for maintenance of the re levant NAAQS in the area for at least 10 years after redesignation. Section 175 (A) 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 contai n 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 a15 

### requirement that the state will implement all measures

contained in the nona ttainment SIP prior to redesignation.

States seeking redesignation of a nonattainment area should consider the following provisions:

a) attainment inventory; b) maintenance demonstration; c) monitoring network; d) verifi cation of continued attainment; and e) contingency plan.

Chapter Six discusses this requirement in more detail.16



## CHAPTER THREE

– PM 2.5 

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

PM 2.5 

### Monitoring, Requirement 1 of 4

A d emonstration that the NAAQS for annual PM 2.5 

### , as published in 40 CFR
50.7, has been attained.

Demonstration

There are currently four Federal R eference Method monitors

measuri ng PM 2.5 

### concentrations in th e Huntington

- Ashland

no nattainm ent area. One is located in Kentucky 3 

### and is operated by the Kentucky Division for Air Quality

. The locations of the monitoring sites for this nonattainment area

are shown on Figure 1

. A listing of the design values based

on the three

- year average of the annual mean concentration s from 200 8 through 20 10 is shown in Table 1. Monitor readings for 2008 through 2010 were retrieved from AQS and are located in Appendix A.

Ambient Data Q uality

- A ssured, Requirement 2 of 4 Ambient monitoring data quality assured in accordance with 40 CFR 58.10,

recorded in the U.S. EPA AQS data base, and available for public view.

Demonstration KYDAQ has quality assured all data shown in Appendix A in accordance with 40 CFR 58.10 and all other federal requirements. KYDAQ has recorded the data in the AQS database and, therefore,

the data are available to the public.

Data Handling G uidelines, A nnual PM 2.5 

### NAAQS, R equirement 3 of 4 A showing that the three

- year average of the annual mean values, based on data from all monitoring sites in the area or its affected downwind environs, are below 15.0 μ g/m 3



### . ( This showing must rely on three complete, consecutive calendar years of quality assured data. )

3 The three re maining PM 2.5 monitors are located in Ohio (two) and West Virginia (one) respectively

.17 

### Figure 1

- Map of the Huntington

- Ashland, OH

- KY

- WV nonattainment

area and monitor locations

Background

The following information is taken from U.S. EPA's Guideline on Data Handling Conventions for the PM NAAQS , U.S. E PA

454/R

- 99

- 008, April 1999.

In accordance with the CAA Amendments, three complete years of monitoring data are required to demonstrate attainment at a monitoring site. The annual PM 2.5 

### primary and secondary ambient air quality standards are met at an ambient air quality monitoring site when the three

- year average of the annual average is less than 15.0 μ g/ m 3



### . While calculating design values, three significant digits must be carried in the computations, with final values rounded to the nearest 0.1 μg/m 3 

### . Decimals 0.05 or greater are rounded up,

and those les s than 0.05 are rounded down, so that 15.049 μg/m 3 

### is the largest concentration that is less than, or equal to 15.0 μg/m 3 

### . Values at or below 15.0 μg/m 3 

### meet the standard; values equal to or greater than 15.1 μg/m 3 

### exceed the

standard. An area is in compliance with the annual PM 2.518 

### NAAQS only if every monitoring site in the area meets the
NAAQS. An individual site's 3

- year average of the annual average concentrations is also called the site's design value. The air quality design value for the area is the highest design value among all sites in the area. Table 1 shows the monitoring data for 2008

- 2010 that were retrieved from AQS.19 

### D emonstration

Table 1

- Monitoring Data for the Huntington

- Ashland , OH

- KY

WV area for 2008

– 2010

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



### The design values calculated for the Huntington

- Ashland a rea demonstrate that the annual PM 2.5 

### NAAQS has been attained. The area's design values have trended downward as emissions have

declined due to such factors as cleaner automobiles and fuels

, and controls for EGUs, at the national, regional and local level

. U.S. EPA published the clean data determination for the area on September 7, 2011; the rule is effective October 7, 2011 (Appendix A). Further, n ational monitoring for PM 2.5 

### began in 1999 and t here

has been a clear downward trend overall in design values (Figure 2).20 

### Figure 2

- PM 2.5 

### Annual Mean National Trends

Source: http://www.epa.gov/airtrends/pm.html



### Commitment to Continue Monitoring, Requirement 4 of 4

A commitmen t that once redesignated, the s tate will continue to operate an appropriate monitoring network to verify the maintenance of the attainment

status.

Demonstration Kentucky commits to continue moni toring PM 2.5 

### levels at the Kentucky site indicated in Figure 1 and Table 1

. KYDAQ will

consult with U.S. EPA Region IV prior to making changes to the existing monitoring network, should changes become necessary in the future. KYDAQ will continue to quality assure the monitoring data to meet the requirements of 40

CF R 58 and all other federal requirements. KYDAQ will enter all data into AQS on a timely basis in accordance with federal guidelines.21



## CHAPTER FOUR

– EMISSION INVENTORY
CAA Section 107(d)(3)(E)(iii) and 107(d)(3)(E)(iv)

INTRODUCTION U.S. EPA’s redesignation g uidance requires the submittal of a comprehensive inventory of PM 2.5 

### precursor emissions . The precursors

consist of primary particles (organic carbon, crustal matter, and elemental carbon), SO 2 

### and NO

x 

### and are representative of the year when the area

achi eves attainment of the annual PM 2.5 

### air quality standard 4



### . Kentucky

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 emissio n reductions . Other emission inventory related requirements include a projection of the emission

invent ory to a year at least 10 years following redesignation; a demonstration that the projected level of emissions is sufficient to maintain

the annual PM 2.5 

### standard; and a commitment to provide future updates of the inventory to enable tracking of emis sion levels during the 10

- year maintenance period.

The emissions inventory development and emissions projection discussion below, with the exception of the mo bile (on

- road) emissions inventory and projections, identifies procedures used by KYDAQ

, VISTAS

, and the

LADCO regarding emissions from Kentucky ’s portion of the counties in the Huntington

- Ashland area. Specific emissions data are provided for all

countie s, including those in Kentucky , Ohio and West Virginia

. Ohio and West Virginia emissions data were also obtained though the LADCO emissions inventory and projections. All of these inventories and emissions projections were prepared using similar methodologies. Ohio

and West Virginia have submitted separate redesignation request s an d maintenance plan s for their portion s of the nonattainment area. Mobile emissions inventories and projections for all counties were prepared by Kimley

- Horn and Associates Inc. on behalf of the Kentucky

- Ohio

- West Virginia In Interstate Planning Commission ( KYOVA ) , with data provided by KYOVA, Ohio Department of Transportation ( ODOT ) , Ohio EPA, West Virginia Department of Transportation ( WVDOT )

, West Virginia Department of Environmental Protection ( WVDEP )

, Kentucky Transportation Cabinet ( KYTC ) , and Kentucky Division for Air Quality ( K Y DAQ )

.

Base Year Emission Inventory, Requirement 1 of 5 A comprehensive emission inventory of PM 2.5 

### , SO 2 

### and NO

x 

### completed for the base year.

Background The point source data for the 2005 base year and 2008 attainment year is from Kentucky 's emission inventory system

4 VOC and NH 3 are not addressed.22 

### (KyEIS). This agency has a Quality Assurance Project Plan (QAPP) that was reviewed and approved by U.S. EPA in a

letter (Appendix B ) dated August 18, 2010 by the Chief of the Air Quality Modeling and Transportation Section, R. Scott

Davis.

Demonstration

The stationary source inventory for th e Kentucky portion used

2005 and 2008 point source emissions from the Kentucky EIS

database. The years 2015 and 2022 were interpolated and extrapolated from those EIS years.

VISTAS provided 2009 and 2018 inventory numbers for the nonroad and area sources, upon which Kentucky interpolated and extrapolated for the 2005 base year

, the 2008 attainmen t

year

, the 2015 interim year, and the 2022 maintenance year

.

All mobile numbers were generated by MOVES with input from KYOVA (MPO), the Kentucky Division for Air Quality, and the Kentucky Transportation Cabinet.

T he detailed emission inventory information for the Kentucky portion of the Huntington

- Ashland area is provided in Appendix B. Emissions of PM 2.5, 

### SO 2 

### and NO

x 

### are identified in the demonstration of maintenance, requirement 3 of 5 of this chapter

.

Emission Projections, Requirement 2 of 5 A projection of the emission inventory to a year at least 10 years following redesignation.

Background
KYDAQ prepare d a comprehensive inventory for the Kentucky portion of the Huntington

- Ashland area including area, mobile, and point sources for PM 2.5 

### , S O 2 

### and NO

x 

### for base year 2005. The 2005 inventory was submitted to U.S. EPA on December 3, 2008 as part

of Kentucky ’s PM 2.5 

### attainment demonstration SIP for this area (Appendix E , document provided electronically on disc )

.

The information below describes the procedures KYDAQ used to generate the 2005 base year inventory and to develop SIP

- ready modeling inventories and future year projections

.

Point source emissions for Kentucky for 2009, 2015

and 2022 were interpolated and extrapolated from the23 

### 2005 and 2008 emissions in the Kentucky EIS inventory.

Area sources and non

- road emissions were interpolated for 2005

- 2008

- 2015

- 2022 from the inventory emissions provided by VISTA S (2002

- 2 009

- 2018). See Appendix B

. The on

- road mobile source sector was addressed by

s pecific PM 2.5 

### and NO

x 

### modeling

. Mobile source

emissions were calculated from MOVES201 0

- produced emission factors. In Kentucky ’s December 3

, 2008 PM 2.5 

### a ttainment d emonstration SIP (provided electronically in Appendix E)

, Kentucky found that the regional highway emissions of PM 2.5


### , NO

x 

### , and SO 2



### were insignificant contributors to the nonattainment problems and, therefore, n one of the three pollutants

necessitate d emissions inventory analysis. As

documented in Kentucky ’ s attainment demonstration SIP, KYDAQ in consultation with U.S. EPA (Appendix C) determined that the Huntington

- Ashland nonattainment area is not significantly impacted by on

road mobile emissions a s compared to other source

emissions . I n addition, mobile source emissions in the

area were expected to decrease. Based on the results of mobile source emission projections prepared as a part of this redesignation and maintenance plan,
KYDAQ is again making a finding that the regional highway emissions of PM 2.5 

### , NO

x 

### , and SO 2 

### continue to

be insignificant contributors to the nonattainment problems in this area, as discussed in the

demonstration section

. Biogenic emissions are not included in t hese

summaries.

Ohio’s point source information was compiled by the contractor, E.H.

Pechan & Associates, from Ohio’s annual emissions inventory

database

, and the 2005 U.S. EPA Air Markets acid rain database. This report by Pechan (Appendix B) generated a 2005 base year inventory and future year estimates of annual emissions for each source sector using accepted growth surrogates. These inventories were provided to LADCO (in cooperation with the Midwest Planning Organization) and have been processed to develop average daily emissions for use in the air quality analyses. These processed modeling inventories have been identified as the correct iteration of the inventory for use in the Ohio redesignation request.24 

### D emonstration

On

- Road Emission Estimati ons The Huntington

- Ashland nonattainment area for the on

- road emission estimation analysis is divided into a modeled area composed of Cabell, Wayne, and Mason (partial) Counties in West Virginia ; Lawrence, Scioto, Adams (partial), and Gallia (partial) Coun ties in Ohio ; and Boyd and Lawrence (partial) Counties in Kentucky. Cabell County and Wayne Count ies in WV, and Lawrence County, OH are represented within the

KYOVA Travel Demand Model by the KYOVA Interstate Planning Commission (MPO) . Boyd County, KY is represented by the KYTC’s Ashland Regional Travel Demand Model. For these areas, information from the travel demand models combined with Highway Performance Monitoring Systems (HPMS) county

- level data from each respective area

were used in the emissions a nalysis. For the full or partial counties not encompassed within the available travel demand models, HPMS data was relied upon more heavily for the

travel characteristics. Appendix C of this redesignation
request provides a full description of the data sources and analysis p rocedures used in this analysis effort.

MOVES

U.S. EPA publish ed a Federal Register notice of availability on
March 2, 2010, to approve MOVES 2010 ( Mo tor Vehicle Emissions Simulator)

, hereafter referred to as MOVES . Upon publication of the Federal Register notice, MOVES bec a me U.S. EPA’s approved motor vehicle emission factor model for estimating VOCs, NO

x 

### , CO, PM 10 

### and PM 2.5 

### and other pollutants and precursors from cars, trucks, motorcycles, and buses by state and local agencies. MOVES is a computer program designed by the U

. S

. EPA to estimate air pollution emissions from mobile sources. MOVES replaces U.S. EPA’s previous emissions model for on

- road mobile sources,

MOBILE6.2. MOVES can be used to estimate exhaust an d evaporative emissions as well as brake and tire wear emissions from all types of on

- road vehicles.

An updated version of this software, MOVES2010a, was used for the purposes of this analysis. MOVES2010a is a minor update to MOVES2010. MOVES2010a includes general performance improvements from MOVES2010, and also

allows users to account for emissions under new car and light truck energy and greenhouse gas standards.

The CAA requires U.S. EPA to regularly update its mobile25 

### source emission models. U.S. EPA continuously collects data

and measures vehicle emis sions to make sure the Agency has the best possible understanding of mobile source emissions. This assessment, in turn, informs the development

of U.S. EPA’s mobile source emission models. MOVES represents the Agency’s most up

- to

- date assessment of on

road mobile source emissions. MOVES also incorporates several changes to the U.S. EPA’s approach to mobile source emission modeling based upon recommendations made to the Agency by the National Academy of Sciences.

U.S. EPA requires that MOVES should be used i n VOC

, CO

, PM, and NO

x 

### SIP development. The CAA requires that SIP

inventories and control measures be based on the most current information and applicable models that are available when a SIP is developed.

Regarding transportation conformity, U.S. EPA and U.S. DOT

establish ed a two

- year grace period before MOVES is required for new transportation conformity analyses.

The MOVES more detailed approach (when compared with the previous MOBILE model) to modeling allows U.S. EPA to easily incorporate large amounts of in

- use data from a wide variety of sources, such as data from vehicle inspection and maintenance (I/M) programs, remote sensing device (RSD) testing, and certification testing, portable emission
measurement system s (PEMS), etc. This approach also allows users to incorporate a variety of activity data to better estimate emission differences such as those resulting from changes to vehicle speed and acceleration patterns. MOVES has a graphical user interface which all ows users to more easily set up and run the model. MOVES database

- centered design provides users much greater flexibility regarding output choices. Unlike earlier models which provided emission factors in grams

- per

- mile in fixed output formats, MOVES
outpu t can be expressed as total mass (in tons, pounds, kilograms, or grams) or as emission factors (grams

- per

- mile and in some cases grams

- per

- vehicle). Output can be easily aggregated or disaggregated to examine emissions in a range of scales, from national e missions impacts down to the emissions impacts of indi vidual transportation projects. The

database

- centered design also allows U.S. EPA to update emissions data incorporated in MOVES more easily and will allow users to incorporate a much wider array of ac tivity data to improve estimation of local emissions. For example, the26 

### improvements in MOVES will allow project

- level PM2.5

emissions to be estimated

.

KYOVA and KYTC Travel Demand Model The latest planning assumptions available for the Huntington

Ashland non

- attainment area were used. Both the KYOVA Travel Demand Model and the KYTC Ashland Regional Travel Demand Model are the most recent and approved regional travel demand models for their respective areas. For each travel demand model, model validation is a joint process between KYOVA and the appropriate state review agencies.

The KYOVA Travel Demand Model is a three step model. Trip generation, trip distribution, and trip assignment components are included in the model. Mode choice is not an

element of the current model. The Travel Demand Model

covers Cabell and Wayne Count ies , WV, and Lawrence County, OH. The current base year for the travel demand

model is 2000. Socioeconomic data was forecasted to the year 2035 as a part of the most recent regional metropolitan transportation plan. The QRS II modeling platform was used

to develop this model. The KYOVA Interstate Planning Commission’s currently adopted transportation plan, titled Huntington

- Ironton Area Transportation Study (HIATS), The Year 2035 Long

- Range Transportation Plan was prepared i n May 2009. Appendix C of this do cument contains the assumptions and methodology used to develop the Travel

Demand Model.

Similar to the KYOVA Travel Demand Model, the Ashland Regional Travel Demand Model is a traditional three

- step model. The model includes trip generation, trip distribution, and trip assignment components. Transit operations are not included in the model; as a result, there is no mode choice component. The Travel Demand Model covers Boyd and Greenup Counties in Kentucky. Updated in 2007, this model has a base year of 2007 and a final horizon year of 2040. Forecast years of 2010, 2020, and 2030 were also incorporated into the model. The TransCAD modeling platform was used to develop this model. The document titled Ashland Regional Travel Demand Model, Model Update Report wa s developed in January 2008 for K YTC . This document contains the assumptions and m ethodology used to develop the current Travel Demand Model.27 

### For areas of the modeling region within a c ounty with a travel demand model, information from this model was applied for the analysis. Specifically, VMT data in the HPMS vehicle

class format and ramp fractions for rural and urban restricted roadways were obtained from the travel demand models. For areas outside of the travel demand model extents, ramp

fractions were assumed to mirror those seen in their respective states. HPMS vehicle class VMT s for areas

outside the travel demand model limits were derived and

forecasted from current HPMS traffic data in those areas.

In addition to the information above, numerous additional data

sources were consulted to obtain the needed information for

the MO VES software. Source type population and vehicle age distribution data were obtained from ODOT, WVDEP, and

KYTC by each state

. The ODOT and KYTC provided data about hourly vehicle distributions. Guidance and data for meteorological, fuel supply, and fuel formulation data was

obtained from ODOT and K Y DAQ. The KYOVA supplied information on the transit vehicle population for the region.

The analysis was performed using the emission rates method. As a result, post

- processing of the data was required to arr ive at the overall emissions output. To do this, the rate per distance and rate per vehicle output data were matched with the appropriate geographic area, analysis year, source types, pollutant types, road types, modeling hours, and speed

classes and then aggregated with the corresponding source type population and vehicle miles traveled information. The resulting information was summarized by pollutant type for each full or partial county being analyzed to generate the overall emissions in tons per year.

Appendix C provides additional detail on the data sources gathered, modeling assumptions, and post

- processing steps.

The KYOVA document from the MPO planning organization, page A

- 2, Appendix C

, d iscusses methods for all mobile inventory years developed using MOVES.

On

- Road Mobile Emission Estimations Tables 2 through 12 contain the results of the emissions analysis for the appropriate years. All emissions estimations are expressed in tons per year (tpy).28 

### Table 2

- Adams (partial) County, Ohio Emissions Estimations

for On

- Road Mobile Sources

2005 2008 2015 2022

NO

x (tpy) 122. 49 103.66 54.82 26.21

SO 2 (tpy) 2.10 0.71 0.32 0.32

PM 2.5 (tpy) 4.20 3.69 2.17 1.39

Annual VMT 34,049,176 35,647,156 39,080,671 42,602,717



### Table 3

– Gallia (partial) County, Ohio Emissions Estimations

for On

- Road Mobile Sources

2005 2008 2015 2022

NO

x (tpy) 59.34 50.43 26.89 12.94

SO 2 (tpy) 1.02 0.34 0.16 0.16

PM 2.5 (tpy) 2.03 1. 81 1.06 0.68

Annual VMT 16,493,759 17,341,207 19,175,027 21,051,915



### Table 4

– Lawrence County, Ohio Emissions Estimations for

On

- Road Mobile Sources

2005 2008 2015 2022

NO

x (tpy) 1,692.81 1,403.49 759.82 397.98

SO 2 (tpy) 28.08 9.16 4.14 4.48

PM 2.5 (tpy) 57.15 48.87 28.76 20.08

Annual VMT 449,711,752 457,366,121 503,049,909 595,949,049



### Table 5

– Scioto County, Ohio Emissions Estimations for On

Road Mobile Sources

2005 2008 2015 2022

NO

x (tpy) 2,081.20 1,761.97 983.09 486.95

SO 2 (tpy) 34.53 11.52 5.39 5.47

PM 2.5 (tpy) 70.26 61.40 37.35 24.56

Annual VMT 552,962,632 575,354,151 655,158,989 728,816,580



### Table 6

– Summary of Ohio Emissions Estimations for On

- Road

Mobile Sources

2005 2008 2015 2022

NO

x (tpy) 3,955.84 3,319.55 1,824.62 924.08

SO 2 (tpy) 65.73 21.73 10.01 10.43

PM 2.5 (tpy) 133.64 115.77 69.34 46.71

Annual VMT 1,053,217,319 1,085,708,635 1,216,464,596 1,388,420,26129 

### Table 7

– Boyd County, Kentucky Emissions Estimations for

On

- Road Mobile Sources

2005 2008 2015 2022

NO

x (tpy) 2,673.25 2,172.59 1,154.59 647.64

SO 2 (tpy) 11.89 11.62 11.89 12.12

PM 2.5 (tpy) 1 14.31 97.91 51.16 29.08

Annual VMT 488,758,339 473,274,668 510,947,840 560,930,984



### Table 8

– Lawrence (partial) , Kentucky Emissions Estimations

for On

- Road Mobile Sources

2005 2008 2015 2022

NO

x (tpy) 170.69 139.16 70.54 37.96

SO 2 (tpy) 0.76 0.74 0.73 0.71

PM 2.5 (tpy) 7.30 6.27 3.12 1.69

Annual VMT 31,232,092 3 0 ,348,1 32 31,171,751 32,686,140



### Table 9

– Summary of Kentucky Emissions Estimations for On

Road Mobile Sources

2005 2008 2015 2022

NO

x (tpy) 2,843.94 2,311.75 1,225.13 685.60

SO 2 (tpy) 12.65 12.36 12.62 12.83

PM 2.5 (tpy) 121.61 104.18 54.28 30.77

Annual VMT 519,990,431 503,622,800 542,119,591 593,617,124



### Table 10

– Cabell County, West Virginia Emissions Estimations

for On

- Road Mobile Sources

2005 2008 2015 2022

NO

x (tpy) 4,262.48 3,504.59 1,702.34 847.76

SO 2 (tpy) 81.13 21.95 9.39 9.13

PM 2.5 (tpy) 173.92 151.98 80.07 43.32

Annual VMT 960,538,915 989,243,546 1,059,033,672 1,140,870,56330 

### Table 1 1

– Mason County (partial) , West Virginia Emissions

Estimations for On

- Road Mobile Sources

2005 2008 2015 2022

NO

x (tpy) 31.12 27. 36 15.33 8.72

SO 2 (tpy) 0.54 0.16 0.07 0.08

PM 2.5 (tpy) 1.19 1.09 0.64 0.38

Annual VMT 6,176,333 6,741,932 8,005,850 9,286,512



### Table 1 2

– Wayne County, West Virginia Emissions Estimations

for On

- Road Mobile Sources

2005 2008 2015 2022

NO

x (tpy) 1720.01 1,432.79 676.93 386.80

SO 2 (tpy) 32.87 9.02 3.76 4.26

PM 2.5 (tpy) 70.36 62.37 32.03 20.13

Annual VMT 389,577,827 407,030,689 424,609,965 533,508,781



### Table 1 3

– Summary of West Virginia Emissions Estimations for

On

- Road Mobile Sources

2005 2008 2015 2022

NO

x (tpy) 6,013.61 4,964.74 2,394.60 1,243.28

SO 2 (tpy) 114.54 31.13 13.22 13.47

PM 2.5 (tpy) 245

. 47 215.44 112.74 63.83

Annual VMT 1,356,293,075 1,403,016,167 1,491,649,487 1,683,665,856



### Table 1 4

– Emissions Estimations Totals for On

- Road Mobile

Sources for the Huntington

- Ashland Area

2005 2008 2015 2022

NO

x (tpy) 12,813.39 10,596.04 5, 444.35 2,852.96

SO 2 (tpy) 192.92 65.22 35.85 36.73

PM 2.5 (tpy) 500.72 435.39 236.36 141.31

Annual VMT 2,929,500,825 2,992,347,602 3,250,233,674 3,665,703,241



### The following table identifies the percentage of mobile emissions of all emissions, as indentified under Demonstration of Maintenance ( Requirement 3 of 5 ) below, for each pollutant in the entire Huntington

- Ashland area and Kentucky ’s portion of this area for

2015 and 2022.31 

### Table 15

– Percent of Mobile Emissions for the Huntington

Ashland Area in 2015 and 2022

NO
x SO 2 PM 2.5

2015 2022 2015 2022 2015 2022

Huntington

Ashland

Area Total (tpy) 9 5,137.30 71,097.29 149, 647.27 113, 654.75 10,100.29 9, 928.94

Mobile (tpy) 5,444.35 2,852.96 35.85 36.73 236.36 141.31

% Mobile 5.7 % 4.0 % 0.0 % 0.0 % 2.3 % 1.4 %

Kentucky

Portion KY Total (tpy) 14,622.66 12,776.03 32,578.86 24,761.97 2,540.30 2508.47

Mobile (tpy) 1,225.13 685.60 12.62 12.83 54.28 30.77

% Mobile 8.4 % 5.4 % 0.0 % 0.0 % 2.1 % 1.2 %



### NO

x 

### constitutes less than nine percent (< 9 %) of the

area’s total NO

x 

### emissions in the 2015 and 2022 horizon years

.

SO 2 

### constitutes less than one percent (< 1 %) of the

area’s total SO 2 

### emissions in the 2015 and 2022 horizon years

.

PM 2.5 

### constitutes less than t hree percent (< 3 %) of the area’s

total PM 2.5 

### emissions in the 2015 and 2022 horizon years.

Therefore , the KYDAQ i s herein making a finding that the area’s highway emissions for PM 2.5 

### , NO

x 

### , and SO 2 

### continue to be insignificant contributors to the nonattainment problem of the Huntington

- Ashland area , as agreed upon as a part of the interagency consultation process

. In a letter (Appendix C) to KYDAQ dated March 23, 2010, U.S. EPA agreed with Kentucky’s finding of insignificance for direct PM 2.5 

### and NO

x 

### regarding the Huntington

- Ashland area attainment demonstration submitted December 3, 2008 (Appendix E)

. Because of this finding it is not necessary to establish mobile emission budgets for this area in the 2015 and 2022 horizon years

.

Demonstration of Maintenance, Requirement 3 of 5 A demonstration that the projected level of emissions is sufficient to

maintain the PM 2.5 

### standard.

Background

In consultation with U.S. EPA

, Kentucky selected the year

2022 as the maintenance year for this redesignation request. This document contains projected emissions inventories for

2015 and 2022

.

Emission projections for the Huntington

- Ashland area were performed using the following approaches :32 

### As performed by Kimley

- Horn and Associates Inc.

, m obile source emission projections are based on the

U.S. EPA MOVES model. The analysis is described in more detail in Appendix C . All projections were made

in accordance with Procedures for Preparing Emissions Projections

, U.S. EPA

- 45/4

- 91

- 019. As discussed above, i t was determined that the mobile

emission contribution a s a percent of the total emission inventory from the area is not si gnificant.

Emissions inventories are required to be projected to future dates to assess the influence growth and future

controls will have. VISTAS has developed growth and

control files for area and non

- road categories. These files were used to develop the future

- year emissions

estimates used in t his document. This was done so the inventories used for redesignation are consistent with modeling performed in the future. Appendix D contains VISTAS technical support document detailing the analysis used to project emissions.

Point source emissions for 2005 and 2008 were compiled from KYDAQ’s 2005 and 2008 emissions inventory database . The 2015 interim year emissions

were estimated ba sed on the 2009 and 2018 VISTAS modeling inventory, using a straight line interpolation

method . The 2022 maintenance year is based on extrapolating emissions estimates from the VISTAS inventory using 2009 and 2018

.

The det ailed inventory information for the Kentucky portion of the Huntington

- Ashland area is in Appendix B

. Emission trends are an important gauge for continued compliance with

the PM 2.5 

### standard. Therefore, KYDAQ performed a comparison of the inventories for the base year and

maintenance years . Mobile source emission inventories are

described in Section 5 of Appendix C

.

Sectors included in the following tables are Point, Nonroad, Area, and Mobile for Kentucky

. Electrical Generating Unit (EGU

- Point), Non

- Electrical Generating Unit (Non

- E GU),

Non

- road Mobile (Non

- road), Other Area (Other), Marine; Aircraft; Rail (MAR), and On

- road Mobile (On

- road) sectors

are included for Ohio and West Virginia.33 

### Ohio is identifying PM 2.5 

### emissions projections for 2015 and 2022 for EGUs without implement ation of the CAIR program. KYDAQ is identifying PM 2.5 

### emissions projections for 2015 and 2022 for EGUs with implementation of the CAIR program. This is further discussed in the demonstration of

PM 2.5



### . U.S. EPA has raised concerns regarding the CAIR

pro gram and its remand. However, as discussed below, with the CAIR replacement rule (CSAPR) finalized, these are the most appropriate and accurate future projections.

On March 10, 2004 , the U.S. EPA promulgated the CAIR

. Beginning in 2009, U.S. EPA’s CAIR rule require d EGUs in

28 eastern states and the District of Columbia to significantly

reduce emissions of NO

x 

### and SO 2 

### . CAIR replace d the NOx

SIP Call for EGUs. The intent of the CAIR program for NO

x



### wa s for national emissions to be cut from 4.5 million tons in

2004 to 1.5 million tons by 2009 and to 1.3 million tons in

2018

. States were required to submit a CAIR SIP as part of

this effort. KYDAQ submitted a CAIR SIP to U.S. EPA on July 19, 2007

. T he CAIR SIP w as approved as a d irect final action on October 4, 2007 [ 74 FR 48857 ]

. The Kentucky administrative regulations developed for the CAIR SIP became effective December 3, 2007 ( 401 KAR 51:210, 220,

230 ). As a result of CAIR, U.S. EPA project ed that in 2009

emissions of NO

x 

### decrease d from a baseline of 176 ,000 tons

per year (tpy) to 107 ,000 tons per year (tpy) while in 2010

emissions of SO 2 

### decrease d from a baseline of 447 ,000 t py

to 341 ,000 t py , within Kentucky

. U.S. EPA projects by 2015

NO

x 

### emissions will decrease to 77 ,000 t py while emissions of

SO 2 

### will decrease to 270 ,000 t py , within Kentucky 5



### .

On December 23, 2008, U.S. EPA’s CAIR program was remanded without vacatur by the D.C. Circuit Court. As mentioned above, KYDAQ has not incorporated these expected CAIR reductions for PM 2.5 

### into this redesignation request. It shou ld also be noted that Kentucky ’s SIP

approved NOx SIP Call program and regulations are still in place , and reductions in NO

x 

### and SO 2 

### have occurred. In

200 9 and 20 10 facilities began preparing for and implementing control programs to address requirements implemented due to CAIR 6 

### and consent decrees.

5 http://www.epa.gov/CAIR/ ky .html

6 Under CAIR, NOx reductions were to occur beginning in 2009 while SO2 reductions were to occur beginning in 2010.34 

### The following was reported by U.S. EPA’s Clean Markets

Division:

“ Based on emissions monitoring data, U.S. EPA has

observed substantial reductions in SO 2 

### emissions from 2005 to 2009 and in the first two quarters of 2010 as companies installed more controls, electric demand declined, and low natural gas prices made combined

- cycle gas

- fired units more competitive in several parts of the country. Thus, even after CAIR's vacatur and subsequent remand in late 2008, the controls in place generally have continued to operate, helping to drive continued progress in reducing emissions

. ” The significant emissio n reductions are illustrated in Table 16.

Table 1 6

– Annual Reductions Nationwide in SO 2 

### and NO
x



### EGU Emissions B etween 1990 and 2010 

## 1990 through 2010 Emission National Comparisons, Annual

Acid Rain Program Emissions at National Level
(All Units).

1990 through 2008 data are final, 2010 are preliminary data

submitted
to EPA from sources as of February 8, 2011.

1990 2000 2005 2008 Preliminary

2010

SO 2 (million tons) 15.73 11.20 10.22 7.62 5.11

NO

x (million tons) 6.66 5.10 3.63 3.00 2.05

Source: Clean Air Markets Quarterly Emissions Tracking

– EPA will update as it receives and verifies data.



### On July 6, 2011, U.S. EPA finalized the new Air Transport Rule,

CSAPR

, which includes reductions scheduled to begin in 2012. As

finalized

, C SAPR will preserve those initial reductions achieved under CAIR and provide more reductions in NO

x 

### and SO 2 

### emissions

in 2012 and 2014

, ahead of the 2015

, Phase 2 requirements of the

CAIR

.

The e mission reductions under t he first phase of compliance begins January 1, 2012 for SO2 and annual NO

x 

### reductions and May 1,

2012 for ozone season NO

x 

### reductions. The second phase of SO 2 

### reductions begins January 1, 2014. By 2014, CSAPR and other state and U.S. EPA actions will reduce power plant SO 2 

### emissions by 73 % from 2005 levels. Power plant NO

x 

### emissions will drop by

54 %

.

KYDAQ is in agreement with the analysis by U.S.EPA that the CAIR

program provided real reductions in emissions

. T hese reductions

have assisted with PM 2.5 

### attainment in this nonattainment area and throughout Kentucky . Further CSAPR will c ontinue to provide for even greater reductions for maintenance of the annual PM 2.535 

### standard. This was additionally supported in the proposed CSAPR [75 FR 45345] , “

... the results of the air quality modeling indicate

that all but one site 7 

### is projected to be in attainment and only one

site 8 

### is projected to have a maintenance pr oblem for annual PM 2.5 

### in 2014 with the emissions reductions expected from this proposal.”

Demonstration



## PM 2.5



### The 2005 and 2008 PM 2.5 

### emissions data below contains particulate fraction emissions and the condensable fractions.

Area and nonroad emissions were taken from the U.S. EPA 2008 National Emissions Inventory (NEI). As stated above, Kentucky utilized Point source information using KYDAQ’s annual emissions inventory database and the U.S. EPA Air

Markets acid rain database.

Maintenance is demonstrated when the future

- year (2022) projected emission totals are below the 2008 attainment year

totals.

The Kentucky emissions data in the tables below are based on the following data sources:

- All On

- Road data source: Kimley

- Horn and Associates

Inc.

- All other data source: Visibility Improvement

- State and Tribal Association of the Southeast (VISTAS)

.

Tables 17 through 25 provide the PM 2.5 

### county emissions for each sector for the 2005 base year to the maintenance year of 2022. Table 26 provides the summary for each county and demonstrates maintenance of the area. Similarly, Tables 27 through 36 illustrate maintenance for NO x, 

### and Tables 3 7 through 46 illustrate maintenance for SO 2 

### emissions.

7 Allegheny, PA

8 Birmingham, AL36 

### PM 2.5



### Table 1 7

- Adams County, Ohio PM 2.5 

### Emission Inventory Totals

for Base Year 2005, Estimated 2008, and Projected

2015 and 2022 (tpy)

– With out CAIR

Sector 2005

Base 2008

Attainment 2015

Interim 2022

Maintenance Safety

Margin

EGU Point 3344.63 3585.29 3569.95 3544.65 40.64

Non

- EGU 6.90 7.28 13.13 15.64

- 8.36

Non

- road 15.62 13.28 8.70 4.04 9.24

Area 247.97 278.00 285.55 282.69

- 4.69

MAR 7.39 6.79 4.21 1.74 5.05

On

- road 4.20 3.69 2.17 1.39 2.30

TOTAL 3,626.71 3,894.33 3,883.71 3,850.15 44.18



### Table 1 8

- Gallia County, Ohio PM 2.5 

### Emission Inventory Totals

for Base Year 2005, Estimated 2008, and Projected

2015 and 2022 (tpy)

– With out CAIR

Sector 2005 Base 2008

Attainmen

t 2015

Interim 2022

Maintenance Safety

Margin

EGU Point 1,011.49 1,031.94 1,073.20 1,100.12

- 68.18

Non

- EGU 0.00 0.00 0.00 0.00 0.00

Non

- road 11.87 10.33 7.22 4.07 6.26

Area 132.22 168.24 181.29 182.52

- 14.28

MAR 7.50 6.91 4.32 1.84 5.07

On

- road 2.03 1.81 1.06 0.68 1.13

TOTAL 1, 165.11 1,219.23 1,267.09 1,289.23

- 70.00



### Table 19

- Lawrence County, Ohio PM 2.5 

### Emission Inventory

Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

– With out CAIR

Sector 2005

Base 2008

Attainment 2015

Interim 2022

Maintenance Safety

Margin

EGU Point 0.00 0.94 0.69 0.14 0.80

Non

- EGU 1.21 1.39 1.75 1.90

- 0.51

Non

- road 13.78 11.67 7.90 4.02 7.65

Area 134.89 134.73 131.79 129.08 5.65

MAR 20.16 17.97 10.67 3.57 14.40

On

- road 57.15 48.87 28.76 20.08 28.79

TOTAL 227.19 2 15.57 181.56 158.79 56.7837 

### Table 2 0

- Scioto County, Ohio PM 2.5 

### Emission Inventory Totals

for Base Year 2005, Estimated 2008, and Projected

2015 and 2022 (tpy)

– With out CAIR

Sector 2005

Base 2008

Attainment 2015

Interim 2022

Maintenance Safety

Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non

- EGU 84.20 138.92 111.08 102.50 36.42

Non

- road 37.43 33.07 22.69 12.33 20.74

Area 199.12 290.87 327.40 330.38

- 39.51

MAR 37.29 32.74 18.94 5.44 27.30

On

- road 70.26 61.40 37.35 24.56 36.8 4

TOTAL 428.30 55 7.00 517.46 475.21 81.79



### Table 2 1

- Boyd County, Kentucky PM 2.5 

### Emission Inventory

Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

– With out CAIR

Sector 2005

Base 2008

Attainment 2015

Interim 2022

Maintenance Safety

Margin

Point 10467.19 9103.06 5920.08 2737.1 6365.96

Non

- road 126.47 122.34 118.93 116.57 5.77

Area 726.35 742.11 783.40 825.44

- 83.33

On

- road 114.31 97.91 51.16 29.08 68.83

TOTAL 11,434.32 10,065.42 6,873.57 3,708.19 6357.23



### Table 2 2

- Lawrence County, Kentucky PM 2.5 

### Emission

Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

– With out CAIR

Sector 2005

Base 2008

Attainment 2015

Interim 2022

Maintenance Safety

Margin

Point 3986.51 3226.75 1453.96 1453.96 1772.79

Non

- road 1.98 1.91 1.67 1.41 0.5

Area 14.35 14.66 15.20 15.72

- 1.06

On

- road 7.3 6.27 3.12 1.69 4.58

TOTAL 4010.14 3249.59 1473.95 1472.78 1776.8138 

### Table 2 3

- Cabell County, West Virginia PM 2.5 

### Emission

Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

– With out CAIR

Sector 2005

Base 2008

Attainment 2015

Interim 2022

Maintenance Safety

Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non

- EGU 316.84 345.42 408.05 440.72

- 95.30

Non

- road 31.58 30.57 22.72 15.39 15.18

Area 356.40 353.80 357.80 360.85

- 7.05

MAR 44.99 42.41 31.61 21.25 21.16

On

- road 173.92 151.98 80.07 43.32 108.66

TOTAL 923.73 9 24.18 900.25 881.53 42.65



### Table 2 4

- Mason County, West Virginia PM 2.5 

### Emission

Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

– With out CAIR

Sector 2005

Base 2008

Attainment 2015

Interim 2022

Maintenance Safety Margin

EGU Point 245.67 244.58 259.80 266.33

- 21.75

Non

- EGU 5.80 5.73 6.49 6.81

- 1.08

Non

- road 16.45 13.94 9.38 4.70 9.24

Area 135.88 136.83 139.42 141.99

- 5.16

MAR 47.73 46.01 35.53 25.66 20.35

On

- road 1.19 1.09 0.64 0.38 0.71

TOTAL 452.72 448.18 451.26 445.87 2.31



### Table 2 5

- Wayne County, West Virginia PM 2.5 

### Emission

Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

– With out CAIR

Sector 2005

Base 2008

Attainment 2015

Interim 2022

Maintenance Safety Margin

EGU Point 3.36 3.85 1.16 0.01 3.84

Non

- EGU 48.01 51.14 54.62 56.11

- 4.97

Non

- road 11.09 9.62 6.97 4.24 5.38

Area 188.18 185.27 182.15 178.69 6.58

MAR 107.34 104.45 81.73 60.51 43.94

On

- road 70.36 62.37 32.03 20.13 42.24

TOTAL 428.34 416.70 358.66 319.69 97.0139 

### Table 2 6

– Huntington

- Ashland Area PM 2.5 

### Emission Inventory

Totals for Base Year 2005, Estimated 2008, and projected 2015 and 2022 (tpy)

– With out CAIR

PM 2.5 2005

Base 2008

Attainment 2015

Interim 2022

Maintenance Safety

Margin

Adams, OH 3,626.71 3,894.33 3,883.71 3,850.15 44.18

Gallia, OH 1,165.11 1,219.23 1,267.09 1,289.23

- 70

Lawrence, OH 227.19 215.57 181.56 158.79 56.78

Scioto, OH 428.3 557 517.46 475.21 81.79

Boyd, KY 11,434.32 10,065.42 6,873.57 3,708.19 6357.23

Lawrence, KY 4010.14 3249.59 1473.95 1472.78 1776.81

Cabell, WV 923.73 924.18 900.25 881.53 42.65

Mason, WV 452.72 448.18 451.26 445.87 2.31

Wayne, WV 428.34 416.7 358.66 319.69 97.01

COMBINED PM 2.5 TOTAL 22,696.56 20,990.20 15,907.51 12,601.44 8,388.76



## N O

x 

### Table 2 7

- Adams County, Ohio NO
x 

### Emission Inventory Totals

for Base Year 2005, Estimated 2008, and Projected

2015 and 2022 (tpy)

– With CAIR

Sector 2005 Base 2008

Attainment 2015

Interim 2022

Maintenance Safety

Margin

EGU Point 30,205.82 31,258.94 25,671.39 23,276.73 7,982.21

Non

- EGU 665.42 703.45 1,266.52 1,770.27

- 1,066.82

Non

- road 142.28 128.52 92.82 57.47 71.05

Area 127.85 132.58 134.84 137.93

- 5.35

MAR 325.30 307.93 199.67 97.77 210.16

On

- road 122.49 103.66 54.82 26.21 77.45

TOTAL 31,589.1 6 32,635.08 27, 420.06 25,366.38 7,268.70



### Table 2 8

- Gallia County, Ohio NO
x 

### Emission Inventory Totals

for Base Year 2005, Estimated 2008, and Projected

2015 and 2022 (tpy)

– With CAIR

Sector 2005 Base 2008

Attainment 2015

Interim 2022

Maintenance Safety

Margin

EGU Point 57,523.60 59,688.25 24,476.65 9,385.96 50,302.29

Non

- EGU 0.00 0.00 0.00 0.00 0.00

Non

- road 110.23 96.65 67.88 38.85 57.80

Area 122.81 128.27 131.45 135.53

- 7.26

MAR 316.92 299.78 194.41 95.18 204.60

On

- road 59.34 50.43 26.89 12.94 37.49

TOTAL 58,1 32.90 60,263.38 24,897.28 9,668.46 50,594.9240 

### Table 29

- Lawrence County, Ohio NO
x 

### Emission Inventory

T otals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

– With CAIR

Sector 2005 Base 2008

Attainment 2015

Interim 2022

Maintenance Safety

Margin

EGU Point 0.00 96.19 105.90 110.06

- 13.87

Non

- EGU 68.51 77.46 97.06 154.65

- 77.19

Non

- road 165.50 142.30 92.01 41.36 100.94

Area 232.73 235.97 238.92 242.31

- 6.34

MAR 785.48 736.28 477.77 232.77 503.51

On

- road 1,692.81 1,403.49 759.8 2 397.98 1,005. 5 1

TOTAL 2,945.03 2,691.69 1,771.48 1,179.13 1,512.56



### Table 3 0

- Scioto County, Ohio NO
x 

### Emission Inventory Totals

for Base Year 2005, Estimated 2008, and Projected

2015 and 2022 (tpy)

– With CAIR

Sector 2005 Base 2008

Attainment 2015

Interim 2022

Maintenance Safety

Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non

- EGU 570.12 659.89 512.83 407.21 252.68

Non

- road 324.89 281.37 185.85 89.77 191.60

Area 240.86 254.58 262.42 272.52

- 17.94

MAR 1,337.52 1,245.14 805.82 387.53 857.61

On

- road 2,081. 20 1,76 1

. 97 983. 09 486.9 5 1,275. 02

TOTAL 4,554.59 4,202.95 2,750.01 1,64 3

. 98 2,55 8

. 97



### Table 3 1

- Boyd County

, Kentucky NO
x 

### Emission Inventory

Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

– With CAIR

Sector 2005 Base 2008

Attainment 2015

Interim 2022

Maintenance Safety

Margin

Point 5109.31 4543.57 3223.52 1903.47 2640.1

Non

- road 3228.05 3137.05 2922.28 2707.10 429.95

Area 41.82 44.68 51.53 56.98

- 12.3

On

- road 2673.25 2172.59 1,154.59 647.64 1524.95

TOTAL 11,052.43 9,897.89 7,351.92 5,315.19 4,582.7041 

### Table 3 2

- Lawrence County, Kentucky NO
x 

### Emission Inventory

Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

– With CAIR

Sector 2005 Base 2008

Attainment 2015

Interim 2022

Maintenance Safety

Margin

Point 12,000.30 13,408.95 16,695.79 19,982.63

- 6,573.68

Non

- road 47.20 45.40 40.86 36.27 9.13

Area 5.94 6.16 6.48 6.70

- 0.54

On

- road 170.69 139.16 70.54 37.96 101.20

TOTAL 12,224.13 13,599.67 16,813.67 20,063.56

- 6,463.89



### Table 3 3

– Cabell County, West Virginia NO
x 

### Emission

Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

– With CAIR

Sector 2005 Base 2008

Attainment 2015

Interim 2022

Maintenance Safety

Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non

- EGU 244.27 246.61 278.40 305.36

- 58.75

Non

- road 316.80 284.81 202.59 121.07 163.74

Area 669.93 678.75 757.21 830.23

- 151.48

MAR 1,578.63 1,566.32 1,205.55 875.99 690.33

On

- road 4,2 62.48 3, 504.59 1, 702.34 8 47.76 2,65 6.83

TOTAL 7,0 72.11 6,2 81 .0 8 4,1 46 .0 9 2,9 80.41 3, 300.67



### Table 3 4

– Mason County, West Virginia NO
x 

### Emission

Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

– With CAIR

Sector 2005 Base 2008

Attainment 2015

Interim 2022

Maintenance Safety

Margin

EGU Point 21,694.07 13,490.21 11,957.32 11,300.37 2,189.84

Non

- EGU 80.53 82.91 91.22 99.02

- 16.11

Non

- road 160.56 153.38 124.24 96.26 57.12

Area 356.63 368.52 391.32 414.58

- 46.06

MAR 1,334.41 1,303.31 971.05 663.19 640.12

On

- road 31.12 27.36 15.33 8.72 18.64

TOTAL 23, 657.32 15,4 25

. 69 13,5 50

. 48 12, 582

. 1 4 2,8 43

. 5542 

### Table 3 5

– Wayne County, West Virginia NO
x 

### Emission

Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

– With CAIR

Sector 2005 Base 2008

Attainment 2015

Interim 2022

Maintenance Safety

Margin

EGU Point 60.51 15.13 7.32 3.97 11.16

Non

- EGU 3,279.16 2,817.34 2,847.64 2,674.22 143.12

Non

- road 117.56 109.12 87.13 65.37 43.75

Area 156.84 159.33 175.43 190.56

- 31.23

MAR 2,872.80 2,846.00 2,184.79 1,579.84 1,266.16

On

- road 1,7 20.01 1,4 32

. 79 67 6

. 93 38 6

. 80 1,04 5

. 99

TOTAL 8,20 6

. 88 7,37 9 .7 1 5,9 79

. 24 4, 900

. 76 2,47 8

. 95



### Table 3 6

- Huntington

- Ashland Area NO
x 

### Emission Inventory

Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

– With CAIR

NOx 2005 Base 2008

Attainment 2015

Interim 2022

Maintenance Safety

Margin

Adams, OH 31,589.18 32,635.08 27,420.06 25,366.38 7,268.70

Gallia, OH 58,132.90 60,263.38 24,897.28 9,668.46 50,594.92

Lawrence, OH 2,945.03 2,691.69 1,771.48 1,179.13 1,512.56

Scioto, OH 4,554.59 4,202.95 2,750.01 1,643.98 2,558.97

Boyd, KY 11,052.43 9,897.89 7,351.92 5,315.19 4,582.70

Lawrence, KY 12,224.13 13,599.67 16,813.67 20,063.56

- 6,463.89

Cabell, WV 7,072.11 6,281.08 4,146.09 2,980.41 3,300.67

Mason, WV 23,657.32 15,425.69 13,550.48 12,582.14 2,843.55

Wayne, WV 8,206.88 7,379.71 5,979.24 4,900.76 2,478.95

COMBINED NOx T OTAL 159,434.57 152,377.14 104,680.23 83,700.01 68,677.13



## SO 2



### Table 3 7

- Adams County, Ohio SO 2 

### Emission Inventory Totals

for Base Year 2005, Estimated 2008, and Projected

2015 and 2022 (tpy)

– With CAIR

Sector 2005 Base 2008

Attainment 2015

Interim 2022

Maintenance Safety Margin

EGU Point 125,070.34 35,946.20 27,077.57 23,276.73 12,669.47

Non

- EGU 4.37 3.73 8.04 11.62

- 7.89

Non

- road 15.33 5.67 0.91 0.14 5.53

Area 33.56 33.54 31.73 30.08 3.46

MAR 28.54 19.33 6.61 1.79 17.54

On

- road 2.10 0.71 0.32 0.32 0.39

TOTAL 125,154.24 36,009.18 27,125.18 23,320.68 12,688.5043 

### Table 3 8

- Gallia County, Ohio SO 2 

### Emission Inventory Totals

for Base Year 2005, Estimated 2008, and Projected

2015 and 2022 (tpy)

– With CAIR

Sector 2005 Base 2008

Attainment 2015

Interim 2022

Maintenance Safety Margin

EGU Point 100,102.91 91,889.46 41,924.16 20,510.45 71,379.01

Non

- EGU 0.00 0.00 0.00 0.00 0.00

Non

- road 10.76 3.98 0.67 0.15 3.83

Area 16.36 16.60 15.91 15.35 1.25

MAR 27.78 19.07 6.90 2.26 16.81

On

- road 1.02 0.34 0.16 0.16 0.18

TOTAL 100,158.83 91,929.45 41,947.80 20,528.37 71,401.08



### T able 39

- Lawrence County, Ohio SO 2 

### Emission Inventory

Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

– With CAIR

Sector 2005 Base 2008

Attainment 2015

Interim 2022

Maintenance Safety Margin

EGU Point 0.00 0.69 0.21 0.00 0.69

Non

- EGU 0.24 0.05 0.35 0.55

- 0.50

Non

- road 18.98 6.95 1.11 0.19 6.76

Area 30.33 29.94 28.93 27.94 2.00

MAR 68.18 53.99 29.93 5.03 48.96

On

- road 28.08 9.16 4.14 4.48 4.68

TOTAL 145.81 100.78 64.67 38.19 62.59



### Table 4 0

- Scioto County, Ohio SO 2 

### Emission Inventory Totals

for Base Year 2005, Estimated 2008, and Projected

2015 and 2022 (tpy)

– With CAIR

Sector 2005 Base 2008

Attainment 2015

Interim 2022

Maintenance Safety Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non

- EGU 977.12 1,477.24 993.09 723.09 754.15

Non

- road 36.15 13.28 2.17 0.42 12.86

Area 36.63 37.53 35.89 34.61 2.92

MAR 116.50 100.91 66.76 32.41 68.50

On

- road 34.53 11.52 5.39 5.47 6.05

TOTAL 1,200.93 1,640.48 1,103.30 796.00 844.4844 

### Table 4 1

- Boyd County, Kentucky SO 2 

### Emission Inventory

Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

– With CAIR

Sector 2005

Base 2008

Attainment 2015

Interim 2022

Maintenance Safety

Margin

Point 5288.46 7857.23 13851.02 19844.81

- 11987.58

Non

- road 438.11 394.26 375.20 370.03 24.23

Area 557.59 573.14 599.93 619.94

- 46.8

On

- road 11.89 11.62 11.89 12.12

- 0.5

TOTAL 6,296.05 8,836.25 14,838.04 20,846.90

- 12,010.65



### Table 4 2

- Lawrence County, Kentucky SO 2 

### Emission Inventory

Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

– With CAIR

Sector 2005 Base 2008

Attainment 2015

Interim 2022

Maintenance Safety

Margin

Point 53,956.75 38,978.43 4,029.02 4,029.02 34,949.41

Non

- road 4.78 3.83 3.32 3.10 0.73

Area 6.59 6.78 6.70 6.57 0.21

On

- road 0.76 0.74 0.73 0.71 0.03

TOTAL 53,968.88 38,989.78 4,039.77 4,039.40 34,950.38



### Table 4 3

- Cabell County, West Virginia SO 2 

### Emission Inventory

Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

– With CAIR

Sector 2005

Base 2008

Attainment 2015

Interim 2022

Maintenance Safety

Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non

- EGU 118.63 118.03 141.50 160.39

- 42.36

Non

- road 16.75 7.30 1.75 0.56 6.74

Area 1,457.65 1,503.71 1,598.18 1,693.86

- 190.15

MAR 53.52 23.87 5.55 1.33 22.54

On

- road 81.13 21.9 5 9.39 9.13 12.8 2

TOTAL 1,727.6 8 1,674.8 6 1,756.37 1,865.27

- 190.4 145 

### Table 4 4

- Mason County, West Virginia SO 2 

### Emission Inventory

Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

– With CAIR

Sector 2005 Base 2008

Attainment 2015

Interim 2022

Maintenance Safety

Margin

EGU Point 82,132.82 50,518.10 44,094.05 41,340.89 9,177.21

Non

- EGU 1.91 1.90 2.13 2.32

- 0.42

Non

- road 10.40 4.53 1.03 0.25 4.28

Area 119.53 120.73 123.14 125.60

- 4.87

MAR 42.13 18.81 4.38 1.06 17.75

On

- road 0.54 0. 16 0. 07 0. 08 0. 08

TOTAL 82,307.33 50,664. 23 44,224.8 0 41,470.2 0 9,194.0 3



### Table 4 5

- Wayne County, West Virginia SO 2 

### Emission Inventory

Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

– With CAIR

Sector 2005 Base 2008

Attainment 2015

Interim 2022

Maintenance Safety

Margin

EGU Point 0.53 0.13 0.04 0.00 0.13

Non

- EGU 285.67 277.75 281.84 281.79

- 4.04

Non

- road 6.96 2.99 0.68 0.19 2.80

Area 490.95 507.00 540.51 574.39

- 67.39

MAR 98.34 48.22 19.46 13.44 34.78

On

- road 32.87 9.0 1 3.76 4.26 4.7 6

TOTAL 915.32 845.1 1 846.29 874.07

- 28.9 6



### Table 4 6

- Huntington

- Ashland Area SO 2 

### Emission Inventory Totals

f or Base Year 2005, Estimated 2008, and Projected 2015

and 2022 (tpy)

– With CAIR

SO 2 2005 Base 2008

Attainment 2015

Interim 2022

Maintenance Safety Margin

Adams, OH 125,154.24 36,009.18 27,125.18 23,320.68 12,688.50

Gallia, OH 100,158.83 91,929.45 41,947.80 20,528.37 71,401.08

Lawrence, OH 145.81 100.78 64.67 38.19 62.59

Scioto, OH 1,200.93 1,640.48 1,103.30 796 844.48

Boyd, KY 6,296.05 8,836.25 14,838.04 20,846.90

- 12,010.65

Lawrence, KY 53,968.88 38,989.78 4,039.77 4,039.40 34,950.38

Cabell, WV 1,727.68 1,674.86 1,756.37 1,865.27

- 190.41

Mason, WV 82,307.33 50,664.23 44,224.80 41,470.20 9,194.03

Wayne, WV 915.32 845.11 846.29 874.07

- 28.96

COMBINED SO 2 TOTAL 371,875.07 230,690.12 135,946.22 113,779.08 116,911.0446



## PM 2.5 

## , NO

x 

## , and SO 2



### Table 4 7

- Huntington

- Ashland Area Comparison of 2008 attainment year and 2015 and 2022 projected emission estimates (tpy)

2008 Base 2015

Interim 2015

Projected

Decrease 2022

Maintenance 2022

Projected

Decrease

PM 2.5 20,990.20 15,907.51 5,082.69 12,601.44 8,388.76

NO

x 152,377.14 104,680.23 47,696.91 83,700.01 68,677.13

SO 2 230,690.12 135,946.22 94,743.90 113,779.08 116,911.04



### As shown in T able 4 7 , PM 2.5 

### emissions in the nonattainment area are projected to decrease by 5,082.69 tpy in 2015 and
8,388.76 tpy in 2022 . NO

x 

### emissions in the nonattainment area are projected to decrease by 51 ,834.95 tpy in 2015 and
75,874.96 tpy in 2022 . SO 2 

### emissions in the nonattainment area are projected to decline by 85,253. 82 tpy in 2015 and
121,246. 34 in 2022

.

Area source emissions and, to a lesser extent, point sources

show a n increase due to expectations that the population will grow in this area ; ho wever, cleaner vehicles and fuels are expected to be in place in 2009 and 2018, and C SAPR will be implemented in 2012 and 2014 . T hese programs will cause an overall drop in all three pollutants emissions. Additional

d ecreases result ed from U.S. EPA rules covering Tier 2

Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements, Highway Heavy

- Duty Engine Rule

, and the Non

- Road Diesel Engine Rule

.

In addition to the above emission reductions , the Kentucky Electric Power, Big Sandy, Unit #2 will reduce SO 2 

### emissions in Boyd County through a federally enforceable

consent decree which will install a fluidized gas desulfurization unit, or SO 2 

### scrubber, to be operational by December 31, 2015.

KYDAQ notes also that in Greenup County, E. I. Dupont, through a federally enforceable consent decree will reduce

SO 2 

### emissions at four sulfuric acid pieces of equipment equivalent to Best Available Control Technology (BA C T )

, and will continue to implement best work practices at these

four pieces of eq uipment . Greenup County

, while not in the47 

### nonattainment area

, is located contiguous to the Ohio and Kentucky portions of this nonattainment area

. Geographically, Greenup County shares a common border to the southeast with Boyd County, Kentucky, and to th e northeast with both Lawrence and Scioto Counties in Ohio.

Additionally, AK Steel

– Ashland Works, Ashland, KY in Boyd County cease d all coke plant operations by June 23,

2011. Plant workers made final charges to the batteries on June 20, 2011. A s hutd own notification has been submitted
to KYDAQ.

Although Kentucky is not taking credit in the projection inventory for the reduction benefits of these consent decrees

and shutdowns , we are noting them a s significant reductions

of benefit to the nonattainment area.

KYDAQ is also anticipating the approval of Regional

Haze/ BART SIPs by the spring of 2012 which will provide regional area reductions to NO

x 

### , SO 2, 

### and PM 2.5



### .

Permanent and Enforceable Emission Reductions, Requirement 4 of 5 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.

Background

Ambient air quality data from all monitoring sites indicate that air quality met the NAAQS for PM 2.5 

### in 2008

- 2010 . U.S. EPA’s redesignation guidance (p 9) states: “A state may generally demonstrate maintenance of the NAAQS by either showing that future emissions of a pollutant or its precursors will not exceed the level of the at tainment inventory, or by modeling to show that the future mix of sources and
emissions rates will not cause a violation of the NAAQS. ”

Demonstration

Permanent and enforceable reductions of PM 2.5 

### , NO

x 

### , and

SO 2 

### emissions have contributed to the attainment of the

annual PM 2.5 

### stan dard. Some of these reductions were due to the application of tighter federal standards on non

- road diesel vehicles (Clean Air Non

- road Diesel Rule)

, the application of tighter federal standards on new vehicles, Title IV of the CAA, the NO

x 

### SIP Call, CAIR /CSAPR , and federal

consent decrees which required the reductions of SO 2 

### and48 

### NO

x 

### emissions from utility sources. These reductions are compared in table 48. Reductions achieved are discussed in

g reater detail under Chapter Five.

Table 4 8

- Huntington

- Ashland Area Combined Comparison of

2005 base year and 2008 attainment year on

- road,

non

- road and EGU reductions

Type 2005 2008

On

- road PM 2.5 500.72 4 35.39

On

- road NO

x 12,8 13.39 10, 596.04

On

- road SO 2 19 2.92 65. 22

Non

- road PM 2.5 158.65 142.17

Non

- road NO

x 1,566.88 1,401.13

Non

- road SO 2 127.85 50.13

EGU PM 2.5 5,005.20 5,274.28

EGU NO

x 121,991.60 109,294.19

EGU SO 2 357,165.83 219,072.36



### Provisions for Future Inventory Updates, Requirement 5 of 5 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 Kentucky , 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). KYDAQ prepares a new periodic inventory for all

PM 2.5 

### precursor emission sectors every three years. These

PM 2.5 

### precursor inventories will be prepared for future years as necessary to comply with the inventory reporting

req uirements established in the CFR

. Emissions information will be compared to the 200 8 attainment year and the 2022 projected maintenance year inventories to assess emission trends, as necessary, and to assure continued compliance

with the annual PM 2.5 

### standard.49



## CHAPTER FI VE

– CONTROL MEASURES AND

REGULATIONS

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

Nonattainment Areas to Implement RACM & RACT, Requirement 1 of 6 Section 172(c)(1) of the 1990 C AA Amendments requires states with nonattainment areas to implement reasonably available control measures ( RACM ) and reasonably available control technology ( RACT )

.

Background Section 172(c)(1) of the 1990 C AA Amendments requires states with nonattainment areas to submit a SIP providing for implementation of all RACM a s 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

.

U.S. EPA’s Implementation Rule interprets th is requirement in great detail. U.S. EPA determined RACT is part of the broader RACM analysis and identification of all measures (for stationary, mobile, and area sources) that are technically and economically feasible, and that would collectively contribute to advancing the attainment date (i.e. by one yea r or more). States are required to use a combined approach to RACT

and RACM, that identifies potential measures that are

reasonable ; uses modeling to identify the attainment date that is as expeditious as practicable ; and selects the appropriate

RACT and R ACM. The Implementation Rule also established

that t hat EGU compliance with CAIR is equivalent to

RACM/RACT for a state that fulfills the CAIR emission reduction requirements.

Demonstration

In 197 9, 1981, and 1998 K entucky promulgated rules requiring RACM for particulate emissions from stationary

sources

. Statewide RACT rules have been applied to all new sources locating in Kentucky since that time. RACT requirements are incorporated into permits along with monitoring, recordkeeping, and reporting ne cessary to ensure ongoing compliance. KYDAQ also has an enforcement program to address violations . The KYDAQ RACT rules are

found in 401 KAR Chapter 59

.

In addition, KYDAQ promulgated NO

x 

### SIP Call rules ( 401

KAR 51:1 5 0 , 51:160, 51:170 ), CAIR ( 401 KAR 51:210

, 51:220, 51:230 ), and NO

x 

### R ACT rules ( 401 KAR Chapter 59 )50 

### over the past several years. Emissions from EGUs make up a significant contribution to Kentucky ’s inventory. Beginning in
2009, Kentucky implemented CAIR which has, and will, provide for significant reductions in NO

x 

### , PM 2.5 

### , and SO 2 

### until CSPAR requirements take place which will provide even greater reductions

.

Reasonable Further Progress, Requirement 2 of 6 Section 172(c)(2) of the 1990 CAA Amendments re quires attainment

demonstration SIPs for nonattainment areas to show reasonable further progress (RFP).

Background U.S. EPA’s Implementation Rule requires RFP only for any

area which a s tate projects an attainment date beyond 2010. The RFP would provide emission reductions showing linear progress between 2002 and 2009. If a s tate demonstrates attainment will occur by 2010 or earlier, U.S. EPA considers

the attainment demonstration to demo nstrate achievement of

RFP.

Demonstration

In Kentucky ’s attainment demonstration submitted on
December 8, 2 008, Kentucky demonstrated (using a weight of evidence approach) that attainment would be achieved in this area by 2009; and therefore, it was not necessary to submit a separate RFP plan.

EMISSION INVENTORY, Requirement 3 of 6 Section 172(c)(3) requires a state to submit a comprehensive inventory of

actual emissions.

Background 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

emi ssion inventory for calendar year 2002 or other suitable year to be used for attainment planning.

Demonstration

The 200 2 comprehensive inventory was submitted to U.S.

EPA with Kentucky ’s PM 2.5 

### attainment demonstration SIP

submitted on December 3

, 2008 ( Ap pendix E , document provided electronically on disc )

. Kentucky updates the51 

### inventory in accordance with U.S. EPA’s CERR rule (i.e. emissions statements). As discussed in Chapter 4

, Provisions for Future Inventory Updates, (Requirement 5 ),
KYDAQ submits, and commits to submit, emission inventories every three years.

IMPLEMENTATION OF PREVIOUS SIP REVISIONS, Requirement 4 of 6

Evidence tha t control measures required in previous PM 2.5 

### SIP revisions have been fully implemented.

Background

In addition to the historic RACT requirements for PM, t he U.S.

EPA NO

x 

### S IP Call required 22 states to pass rules that would result in significant emission reductions from large EGUs,
industrial boilers, and cement kilns in the eastern United

States. Kentucky adopted these rule s in 2001. NOx SIP Call requirements are incorporated into permits along with monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. KYDAQ also has an enforcement program to address violations

. Compliance is tracked through the Clean Air Markets data monitoring

program. Be ginning in 2004, this rule account s for a reduction of approximately 31 % of all NO

x 

### emissions state wide compared to previous uncontrolled years. The other 21 states

also have ad opted similar rules.

On March 10, 2004 , the U.S. EPA promulgated the CAIR

. KYDAQ submitted a CAIR SIP to U.S. EPA on July 19, 2007

. The CAIR SIP was approved as a direct final action on October 4, 2007 [74 FR 48857]. The Kentucky administrative regulations developed for the CAIR SIP became effective December 3, 2007 (401 KAR 51:210, 220, 230). Those regulations are still in place.

Emission reductions required by CSAPR will begin January 1, 2012 under the first phase of compliance for SO 2 

### and an nual

NO x, 

### and May 1, 2012 for ozone season NO

x 

### reductions. The second phase of SO 2 

### reductions begins January 1, 2014. By 2014, CSAPR will reduce power plant SO 2 

### emissions by 73%

from 2005 levels. Power plant NO

x 

### emissions will drop 54%.52 

### D emonstration

Federal Control Measures

NO

x 

### SIP Call Rule

Controls for EGUs under the NO

x 

### SIP Call formally commenced May 31, 2004. E missions covered by this program have been trending downward since 1998 with larger reductions occurring in 2002 and 2003. D ata taken

from the U.S. EPA Clean Air Markets w eb site, quantif y the gradual NO

x 

### reductions that have occurred in Kentucky as a result of Title IV , 1 990 CAA Amendments and the beginning

of the NO

x 

### SIP Call Rule. Kentucky developed the NO

x 

### Budget Trading Program rules in 401 KAR Chapter 51 in response to the SIP Call. 401 KAR Chapter 51 regulates

EGUs and certain non

- EGUs under a cap and trade program

based on an 85 % reduction of NOx emissions from EGUs

and a 60 % reduction of NO

x 

### emissions from non

- EGUs, compared to historical levels. This cap was in place through 2008, at which time the CAIR program supersede d it as discussed above

. C hapter 4

, d emonstration of m aintenance,

discusse s the reductions Kentucky has seen as a result of

CAIR.

On April 21, 2004, U.S. EPA published Phase II of the NO x 

### SIP Call that establishe d a budget for large (greater than 1 ton per day emissions) stationary internal combustion engines

, and for large utility and industrial boilers

. 401 KAR

51 :150 regulates stationary internal combustion engines, and

401 KAR 51:160 regulates large utility and industrial boilers

, both were effective February 2, 2006

. U.S. EPA approved

this revisi on to the SIP on November 23, 2009.

Tier II Emission Standards for Vehicles and Gasoline Sulfur

Standards

O n February 10, 2000

, U.S. EPA finalized a federal rule [65 FR 6698] to significantly reduce emissions from cars and light trucks, including sport utility vehicles (SUVs). Under this rule

, automakers will be required to sell cleaner cars, and

refineries are required to make c leaner, lower sulfur gasoline.

The federal rule w as phase d in between 2004 and 2009.

U.S. EPA has estimated that NO

x 

### emission reductions are approxima tely 77 % for pa ssenge r cars ; 86 % for smaller SUVs, light truc ks, and minivans ; and 65 % to 95 % reductions for larger SUVs, vans, and heavier trucks. E mission

reductions of VOC are ap proximately 12 % for passen ger53 

### cars ; 18 % for smaller SUVs, light trucks, and min ivans ; and

15 % for larger SUVs, vans, and heavier trucks.

The Tier II rule also reduced th e sul f ur content of gasoline from 300 parts per million (ppm) to 30 ppm in January 2006. Most gasoline sold in Kentucky prior to January 2006 had a sulfur content of ap proximately 300 ppm. Sulfur occurs naturally in gasoline but interferes with the operation of catalytic converters on vehicles resulting in higher NO

x 

### emissions. Low sulfur gasoline was necessary to achieve the

Tier II vehicle emission standards.

H eavy

- Duty Gasoline and Diesel Highway Vehicle Standards On October 6, 2000, the U.S. EPA promulgated a rule [65 FR 59896] that began in 2004 to reduce NO

x 

### and VOC emissions

from heavy

- duty gasoline and diesel highway vehicle

. A second phase of standards and testing procedures began in 2007 to reduce particulate matter from heavy

- duty engines, and reduces highway diesel fuel sulfur content to 15 ppm since sulfur in fuel damages high efficiency catalytic exhaust

emission device s. The total program should achieve a 90% reduction in particulate matter emissions and a 95% reduction

in NO

x 

### emissions for new engines using low

- sulfur diesel, compared to existing engines using higher content sulfur

diesel.

Large Nonroad Diesel Engine s Rule On May 11, 2004, the U.S. EPA promulgated a rule [69 FR 26222] 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 rule

also reduced the allowable sulfur in nonroad diesel fuel by over 99% by 2010. The U.S. EPA estimated that affected nonroad diesel engines currently account for 44% of total

diesel PM emissions and 12% of total NO

x 

### from mobile

sources nationwide. Nonroad diesel fuel currently averages 3,400 ppm sulfur. The rule limited nonroad diesel sulfur content to 500 ppm in 2006 and 15 ppm in 2010. The combined diesel engine rules reduce NO

x 

### and PM emissions from large nonroad diesel engines by over 90%, compared to

current nonr oad engines using higher

- content sulfur diesel.

Nonroad Spark

- Ignition Engines and Recreational Engine

Standard On November 8, 2002, the U.S. EPA promulgated a rule [ 67

FR 68242 ] that regulate NOx, hydrocarbons (HC) and carbon54 

### monoxide (CO) for groups of previously unregulated nonroad engines. The 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 servic e equipment), recreational vehicles (off

- highway motorcycles and all

- terrain

- vehicles), and recreational marine diesel engines. The regulation varies based upon the type of engine or vehicle.

The large spark

- ignition engines contribute to ozone

formati on and ambient CO and PM levels in urban areas. Tier 1 of this standard was implemented in 2004 while Tier 2 began in 2007. Like the large spark

- ignition, recreational vehicles contribute to PM levels, as well ozone formation and

ambient CO. 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 othe r types of pleasure craft. Recreational marine engines contribute to PM levels and ozone formation, especially in marinas. Depending on the size of the engine, the standard began to be phased

- in during 2006.

When all of the nonroad spark

- ignition engi nes 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 PM 2.5 

### , CO, and ozone.

Re ciprocating Internal Combustion Engine Standard

On May 3, 2010, U. S. EPA promulgated a r ule [75 FR 9648]

to r egulate emissions of air toxics from existing diesel powered stationary reciprocating internal combustion engines that meet specific site rating, age, and size criteria. These engines are typically used at industrial facilities (e.g. power, chemical, and manufacturing plants) to generate electricity for compressors and pumps and to produce electricity to pump water for flood and fire control during emergencies.

The standard applies to stationary diesel engines located at

an area source of air toxics and constructed or reconstructed before June 12, 2006; located at a major source of air toxics, having a rating of less than or equal to 500 horsepower, and constructed or reconstructed before June 12, 2006; or located55 

### at a major source of air toxics for non

- emergency purposes, having a rating of greater than 500 horsepowe r, and constructed or reconstructed before December 19, 2002.

Operators of existing engines will be required to: install emissions control equipment that will limit air toxics up to 70% for stationary non

- emergency engines with rating s greater

than 300 ho rsepower; perform emission tests to demonstrate engine performance and compliance with rule requirements;

and burn ultra

- low sulfur fuel in stationary non

- emergency engines with a rating greater than 300 horsepower.

When all of the reciprocating interna l combustion engine standards are fully implemented in 2013, U.S. EPA estimates that emissions from these engines will reduce air toxics by approximately 1,000 tpy, PM 2.5 

### by 2, 800 tpy; CO by 14,000 tpy, and VOC by 27,000 tpy.

Category 3 Marine Diesel Engi ne Standards

On June 29 , 2010

, the U.S. EPA promulgated a rule [75 FR 22896] establishing more stringent exhaust emission standards for new large marine diesel engines with per

cylinder displacement at or above 30 liters (commonly referred to as Category 3 compression

- ignition marine engines) as part of a coordinated strategy to address emissions from all ships that effect U.S. air quality. These emission standards are equivalent to those adopted in the

amendments to Annex VI to the International Conventio n for the Prevention of Pollution from Ships (MARPOL Annex VI). The emission standards apply in two stages . N ear

- term standards for newly built engines will apply begin ning in 2011

and long

- term standards requiring an 80% reduction in NOx

emissions will begin in 2016.

U.S. EPA is adopting changes to the diesel fuel program to allow for the production and sale of diesel fuel with up to 1,000 ppm sulfur for use in Category 3 marine vessels. The regulation forbid s production and sale of fuels with more t han 1,000 ppm sulfur for use in most U.S. waters, unless operators achieve equivalent emission reductions in other ways. U.S. EPA is also adopting provisions to apply some emission and fuel standards to foreign

- flagged and in

- use vessels that are covered by MARPOL Annex VI.

When this strategy is fully implemented in 2030, U.S. EPA

estimates that NOx and PM 2.5 

### emissions in the U.S. will be56 

### reduced by approximately 1.2 million tpy and 143,000 tpy, respectively.

State Control Measures

New Process Operations

– 401 KAR 59:010 New Process Operations provides for the control of emissions for

affected facilities or sources located in nonattainment areas as well

as attainment areas

. This regulation will continue to apply to those

affected facilities or sources if the area is redesignated to attainment or unclassified status, unless a state implementation plan which provides for other controls is approved by the U.S. EPA.

R ACT/RACM

– 401 KAR 50:012 The Kentucky PM 2.5 

### nonattainment /maintenance areas wil l continue to implement the RACT/ RACM requirements promulgated by the regulation . The analysis in the previously submitted “Kentucky Fine Particulate Matter (PM 2.5 

### ) Attainment Demonstration for the
Louisville, KY

- IN, Cincinnati

- Middletown, OH

- KY

- IN, and

H untington

- Ashland, WV

- KY

- OH Nonattainment Areas ” (December 2008) established that these measures contribut ed to the region being able to comply with the PM 2.5 

### NAAQS (1997).

Open burning bans

– 401 KAR 63:005 In 2005 Kentucky revised the open burning regul ation t o prohibit most types of burning in PM 2.5 

### nonattainment/ maintenance areas within Kentucky during the period of May

- September.

Fugitive Emissions

– 401 KAR 63:010

This r egulation provides for the control of fugitive emissions in the

state.

Clean Air Interstate Rule

– 401 KAR 51:210

- 230 In response to the CAIR, Kentucky developed regulations 401 KAR 51:210, CAIR NO X 

### annual trading program ; 401 KAR 51:220, CAIR

NO

x 

### ozone season trading program; and 401 KAR 51:230, CAIR

SO 2 

### trading progra m. These regulations became effective February
2, 2007.

Under the rules, Kentucky has caps as follows:

Annual NOx : 83,205 tons for 2009

- 2014 and 69,337 tons for 2015 and each year thereafter;57 

### Ozone season NOx : 36,109 tons for 2009

- 2014 and
30,65 1 tons for 2015 and each year thereafter;

Annual SO 2 

### : 188,773 tons for 2010

- 2014 and 132,141 tons for 2015 and each year

thereafter.

The State’s NO

x 

### allocations have been distributed based on allocation methodologies in regulations 401 KAR 51:210 a nd 401

KAR 51:220. The U.S. EPA determine d the SO 2 

### allocations, which are based on the acid rain program. This rule does not preclude Kentucky from adopting additional emission reduction requirements for covered sources if necessary to attain or maintain a n ambient air quality standard.

The intent of the CAIR program was for national NO

x 

### emissions to be cut from 4.5 million tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3 million tons in 2018 in 28 eastern states. As a result of CAIR, the U.S. EPA projected that in 2009 Kentucky emissions of

NO

x 

### w ould decrease from a baseline of 176,00 t py per year without CAIR to 107,000 t py with CAIR. Projections also demonstrated that in 2010, emissions of SO 2 

### w ould decrease from a baseline of
447,000 t py w ithout CAIR to 341,000 t py with CAIR. T he U.S. EPA projects that by 2015 NO

x 

### emissions will decrease further to 77,000

t py while emissions of SO 2 

### will decrease to 270,000 t py within Kentucky. (Source: http:// www.epa.gov/CAIR/ky.html )

As discussed previously

, K entucky did incorporate d these expected

CAIR reduction s into the redesignation request inventories and projections regarding SO 2 

### and NO

x 

### but did not incorporate CAIR

reductions into the PM 2.5 

### inventory

. However, i t should also be noted that Kentucky’s SIP

- approved NO

x 

### SIP Call program and regulations, and the CAIR program and associated regulations, are

still in place and providing reductions. Further, the requirements of

CSAPR will ensure a dditional emission reductions. All controls noted thus far for redesignation are expected to continue into the future. Those control measures will continue providing reduction for particulate precursors and emissions throughout the maintenance period.

I n ad dition to the rule discussed above , various maximum available control technology (MACT) rules have or will be promulgated by U.S. EPA and adopted by KYDAQ

, providing additional particulate

controls. T hese include:58 

### MACT Controls

RICE MACT

The U.S. EPA published a final rule August 10, 2010 [ 75 FR 51570 ] that provided national emission standards for hazardous air pollutants (NESHAP) for existing s tationary spark ignition (SI) reciprocating internal combustion engines (RICE)

. This final rule addresses emissions from existing stationary SI engines less than or equal to 500 HP located at major sources and all existing stationary SI engines located at area sources

. E mission control technologies

that will be installed on stationary RICE units t o reduce HAP will also

reduce CO and VOC, and for rich burn engines will also reduce

NO x

. This final rule is expected to reduce emissions of NO x from stationary RICE units located at area sources by 96,000 tons per year (tpy) in the year 2013.

Major/Area Boiler MACT

On March 21 , 2011, the U. S. EPA finalized a rule [76 FR 15 608 ] that will reduce emissions of HAP from new and existing industrial, commercial, and institutional boilers and process heaters at major

source facilities. Additionally the U.S. EPA finalized a similar rule [76 FR 15554] to reduce emissions of HAP from two area source categories: industrial boilers, and commercial and institutional

boilers. The effective date of May 20, 2011 for both rules was delayed [ 76 FR 28662] until such time a s judicial review is no longer pending or until final reconsideration of the rules is completed,

whichever is earlier.

Utility MACT

O n May 3, 2011 the U.S. EPA proposed a rule that will set standards to reduce air pollution from coal and oil

- fired power plants [76 FR 24976]. All existing sources must comply in t hree years, but individual sources can obtain an additional year if technol ogy cannot

otherwise be installed in time. The proposed rule establishes emission standards for mercury, acid gases (hydrochloric acid (HCl), as a surrogate), and non

- mercury metallic toxic pollutants (PM as a surrogate with alternative surrogate of total metal air toxics). Each year this rule will:

Prevent 91% of the mercury in coal burned in power plants from being emitted to the air; Reduce acid gas emissions from power plants by 91%; and

Reduce SO 2 

### emissions from power plants by 55 percent.59



### New source review provisions, Requirement 5 of 6 Acceptable provisions to provide for new source review.

Background Kentucky has a longstanding and fully implemented SIP

approved regulation 401 KAR 51:052 that establishes air quality permit ting requirements for the construction or modification of major stationary sources located with in , or impacting upon, nonattainment area s. The regulation

ensures that the construction or modification will not contribute significant ly to Kentucky’s achievement of reasonable further progress of a NAAQS. Similarly, SIP

approved regulation 401 KAR 51:017 establishes air quality permitting requirements for the construction or modification of major stationary sources located in an area designated

attainment or unclas sifiable. The regulation e nsures that the construction or modification will not significantly deteriorate the air quality of the area.

Demonstration Any facility that wa s not listed in the 200 5 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, KYDAQ will impl ement NSR through the PSD program.

Assurance of continued controls, 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 measure s.

Demonstration Kentucky commits to maintaining the aforementioned control measures after redesignation. Kentucky h ereby commits that any changes to its rules or emission limits applicable to PM 2.5 

### , SO 2 

### , or NO

x 

### as required for maintenance of the annual PM 2.5 

### standard in the Huntington

- Ashland area , will be submitted to

U.S. EPA for approval as a SIP revision.

Kentucky has the legal authority and necessary resources to actively enforce any violations of its rules o r permit provisions. After redesignation, it intends to continue enforcing all rules that relate to the emission of PM 2.5 

### precursors in the Huntington

- Ashland area.60



## CHAPTER SIX

– CONTINGENCY MEASURES
CAA Section 107(d)(3)(E)( i v)

Commitment to Review Maintenance Plan, Requirement 1 of 4 A commitment to submit a revised plan eight years after redesignation.

Demonstration Kentucky he reby commits to review its maintenance p lan eight years after redesignation, as required by Section 175(A)

of the CAA

.

Commitment for Contingency Measures

, 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 vio lations of the ambient standard

occur.

Demonstration Kentucky hereby commits to adopt and expeditiously implement necessary corrective actions in the following

circumstances:

In the event that a measured value of the weighted annual

mean of 15.5 ug/m 3 

### per cubic meter or greater occurs in a single calendar year in any portion of the maintenance area,

the s t ate will evaluate existing control measures to determine if any further e mission reduction measures should be implemented at that time.

In the event of a monitored violation of the annual PM 2.5 

### NAAQS in the Huntington

- Ashland maintenance area, Kentucky commit s to adopt, within nine months, one or more of the following continge ncy measures to re

- attain the standard. All regulatory programs will be implemented within 18 months after the triggering monitored violation.

Control Measure Selection and Implementation Adoption of any additional control measures is subject to the necessary administrative and legal process. This process will include publication of notices, an opportunity for public hearing, and other measures required by Kentucky law for rulemaking.

If a new measure/control is already promulgated and scheduled to be implemented at the federal or s tate level, and

that measure/control is determined to be sufficient to address61 

### the upward trend in air quality, additional local measures may be unnecessary. F urthermore, Kentucky will submit to U.S.

EPA an analysis to demonstrate the proposed measures are adequate to return the area to attainment.

Potential Contingency Measures, Requirement 3 of 4 A list of potential contingency measures that would be implemented in such

an event.

Demonstration 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 select ion of

measures will be based on cost

- effectiveness, emission reduction potential, economic and social considerations or

other factors t hat KYDAQ deems appropriate. KYDAQ will solicit input from all interested and affected persons in the maintenance area prior to selecting app ropriate co ntingency

measures. Because it is not possible at this time to

determine what control measure s will be appropriate at an unspecified time in the future, the list of contingency

measures outlined below is not exhaustive

.

Implementation of a program to req uire additional emission reductions on stationary sources; Implementation of fuel programs, including incentives for alternative fuels;
Restriction of certain roads or lanes, or construction of such roads or lanes for use by passenger buses or high

- occup ancy vehicles; Trip

- reduction ordinances; Employer

- based transportation management plans, including incentives; Programs to limit or restrict vehicle use in downtown areas, or other areas of emission congestion, particularly during periods of peak use;

Pr ograms for new construction and major reconstructions of paths or tracks for use by pedestrians or non

- motorized vehicles when economically feasible and in the public interest; Diesel reduction emission strategies, including diesel retrofit

programs.

Kent ucky also reserves the right to implement other contingency measures if new control programs should be developed and deemed more advantageous for the area. No62 

### 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.

List of PM 2.5 

### , SO 2, 

### and NO
x 

### Requirement 4 of 4

A list of PM 2.5 

### , SO 2 

### , and NO

x 

### sources potentially subject to future additional

control requirement s.

Demonstration The following is a list of PM 2.5 

### , SO 2 

### , and NO

x 

### sources potentially subject to future controls.

ICI Boilers ; EGUs; process heaters; internal combustion engines;
combustion turbines; other sources greater than 100 tons per year;

fleet vehicles;

concrete manufacturers;

a ggregate processing plants63



## CHAPTER SEVEN

– PUBLIC PARTICIPATION

Kentucky published notification for a public hearing and solicitation for publi c comment concerning the draft redesignation petition and maintenance plan in the Ashland Daily Independent newspaper and on the Division for Air Quality’s website.

The p ublic hearing to receive comments on the redesignation request was

scheduled for De cember 22, 2011 at the Ashland

- Boyd County Health Department

, 2916 Holt Street, Ashland , Kentucky

. The public hearing was cancelled after this agency received no request to conduct the hearing. Written comments were received during the public comment period.

Appendix F includes a copy of the public notice, certification of publication,

and the statement of consideration.64



## CHAPTER EIGHT

- CONCLUSIONS

The Huntington

- Ashland annual PM 2.5 

### nonattainment area has attained the

1997 annual NAAQS for PM 2.5 

### and complied with the applicable provisions

of the 1990 Amendments to the CAA regarding redesignations of PM 2.5 

### nonattainment areas. U.S EPA published the clean data determination on September 7, 2011, noting the area has attained the NAAQS by its applicab le attainment date of April 5, 2010. Documentation to that effect is

contained in Appendix A

. The Kentucky Division for Air Quality has

prepa red a redesignation request and maintenance p lan that meet the requirement s of Section 110 (a)(1) of the 1990 CAA

.

Based on this presentation, the Huntington

- Ashland annual PM 2.5 

### nonattainment area meets the requirements for redesignation under the

CAA and U.S. EPA guidance. KYDAQ has performed an analysis that

demonstrates the air quality improvements are due to permanent and enforceable measures. Furthermore, since this area is subject to significant transport of pollutants, significant regional SO 2 

### and NO

x 

### reductions will ensure continued compliance (maintenance) with the standard with an increasing margin of safety.

The Commonwealth of Kentucky hereby requests that the Huntington

Ashland annual PM 2.5 

### nonattainment area be redesignated to attainment

simult aneously with U.S. EPA approval of the maintenance p lan provisions

containe d herein.