Governor 

Ms. Heather McTeer Toney 

Regional Administrator 

US EPA, Region 4 

Sam Nunn Atlanta Federal Center 

61 Forsyth St, SW 

Atlanta, Georgia 30303-8960 

500 Mero Street 

l21h Floor, Capital Plaza Tower 

Frankfort, Kentucky 40601 

Phone: (502) 564-3350 

Fax: (502) 564-7484 

http://eec.ky .gov 

September 16, 2015 

Secretary 

RE: Submission of additional information for Kentucky's recommendations relating to the 

2010 1-hour S02 NAAQS 

Dear Ms. McTeer Toney: 

In accordance with Section 107(d)(l)(A) of the Clean Air Act (CAA), states must submit 

to U.S. EPA (EPA), within one year following promulgation of a new or revised National 

Ambient Air Quality Standard (NAAQS), a list of all areas in the state, recommending 

designations for each as attainment, nonattainment, or unclassifiable. In a letter dated March 28, 

2011, I was informed that the proposed designation recommendations for Kentucky were due 

June 3, 2011, for the 1-hour NAAQS for sulfur dioxide (S02) published in the Federal Register 

June 22, 2010 (75 FR 35520). On June 2, 2011, I provided EPA with recommended designations 

for all areas of the state relative to the revised S02 NAAQS. 

In a letter dated March 20, 2015, Acting Assistant Administrator Janet McCabe updated 

Commissioner Bruce Scott on the status of U.S. EPA's progress in implementing the primary 

NAAQS for S02. The letter detailed the agreement between EPA, the Sierra Club, and the 

Natural Resources Defense Council that was accepted as an enforceable order by the U.S. 

District Court for the Northern District of California. The court's order and the agreement direct 

EPA to complete designations in three additional rounds, with the first round due by July 2, 

2016. 

In the first additional round of area designations, EPA will designate two groups of areas: 

(1) areas that have newly monitored violations of the 2010 S02 NAAQS, and 2) areas that 
recommendations and supporting information no later than the September 18, 2015 deadline, as 

established in the court order. 

As stated in its March 20, 2015 letter, EPA identified two electric generating sources as 

meeting the criteria established in the court order, DB Wilson Generating Station located in Ohio 

County and JohnS. Cooper Power Station located in Pulaski County. As requested by 

Kentucky's Division for Air Quality, the identified sources provided significant, technical 

information to characterize the air quality in the areas surrounding their sources. 

In a memorandum dated March 20,2015, from Stephen D. Page to the Regional Air 

Division Directors ("Updated Guidance for Area Designations for the 2010 Primary Sulfur 

Dioxide NAAQS"), the EPA recommended that states use five factors in making designation 

recommendations: 1) ambient air quality data or dispersion modeling, 2) emissions and 

emissions-related data, 3) meteorology, 4) geography/topography, and 5) jurisdictional 

boundaries. Kentucky used these factors as well as the EPA's guidance on the use of source 

modeling as outlined in the SOz NAAQS Designations Modeling Technical Assistance 

Document (Modeling TAD). 

In summary, the following modeled results of the areas' concentrations of S02, which 

included the recommended factors set forth by the March 20, 2015 memorandum, indicate that 

the identified facilities are in compliance with the 1-hour S02 NAAQS: 

Averaging NAAQS Maximum Facility Location Impact Period (~g!m3) 

(~g!m3) 

D. B. Ohio Wilson 

Generating County, 1-Hour 196 186.5 

Station KY 

JohnS. Pulaski Cooper County, 1-Hour 196 173.1 Power 

Station KY 

As a result of the information provided above and accompanying this submittal, 

Kentucky finds that the two facilities located within Ohio and Pulaski Counties are in 
downloaded at the following URL: 

ftp://eec121321R2:5rdxCFTA7ygv@ftp.cot.ky.gov/EECDAQ121321/eecdagJM/KYS02DEMO 

Pursuant to 40 CFR 51.1204,the Division for Air Quality will establish federallyenforceable emission limitations through the source's title V permits, respectively, to ensure 

compliance with the 2010 S02 NAAQS. We look forward to continued dialogue with you and 

your staff as we work together to implement the 2010 SOz NAAQS. If you should have any 

questions or need additional information regarding the designations for the 2010 SOz NAAQS, 

please do not hesitate to contact me or Mr. Sean Alteri, Director for the Division for Air Quality 

at (502) 564-3999. 

Secretary 

LKP/mrwlbac