APPENDIX E
2011,	2014,	2017,	2020,	2022	and	

2027	SO2	On‐Road	Emissions	

Inventory	for	Campbell‐Clermont	

Counties,	

KY‐OH	1‐HOUR	SO2

Nonattainment	Area	

REVISED	

January	2015	

Prepared for the Ohio Environmental Protection Agency and Kentucky Division for Air Quality

by		

OKI Regional Council of Governments
2 On‐Road SO2Emissions Inventory for Campbell‐Clermont Counties, KY‐OH SO2Nonattainment Area,

January 2015
3 On‐Road SO2Emissions Inventory for Campbell‐Clermont Counties, KY‐OH SO2Nonattainment Area,

January 2015

Acknowledgments

Title 2011, 2014, 2017, 2020, 2022 and 2027 SO2 On‐Road Emissions Inventory

for Campbell‐Clermont Counties, KY‐OH 1‐HOUR SO2 Nonattainment Area

Abstract This report was prepared for the Ohio Environmental Protection Agency.  

The SO2 Nonattainment Area includes a portions of Campbell County

Kentucky and Clermont County Ohio.  EPA’s Motor Vehicle Emission

Simulation (MOVES) 2014 was used to generate the emission inventory.

Date January 2015

Agency Ohio‐Kentucky‐Indiana Regional Council of Governments

Mark Policinski, Executive Director

Robert Koehler, P.E., Deputy Director

   

Project Manager Andrew J. Reser, AICP

Project Staff Larry Buckler

   

   

The preparation of this document was financed cooperatively by the Federal Highway Administration,

the Federal Transit Administration, the Commonwealth of Kentucky Transportation Cabinet, the Ohio

Department of Transportation, and the units of local and county government in the OKI region. The

opinions, findings, and conclusions expressed in this document are those of the OKI Regional Council of

Governments and are not necessarily those of the U.S. Department of Transportation. This report does

not constitute a standard, specification, or regulation.   
4 On‐Road SO2Emissions Inventory for Campbell‐Clermont Counties, KY‐OH SO2Nonattainment Area,

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5 On‐Road SO2Emissions Inventory for Campbell‐Clermont Counties, KY‐OH SO2Nonattainment Area,

January 2015

2011, 2014, 2017, 2020, 2022 and 2027 SO2 On‐Road

Emissions Inventory for Campbell‐Clermont Counties,

KY‐OH 1‐HOUR SO2

This report was prepared for the Ohio Environmental Protection Agency and the Kentucky Department

for Air Quality.    The SO2 nonattainment area includes a portion of Campbell County Kentucky and a

portion of Clermont County Ohio.  EPA’s Motor Vehicle Emissions Simulator (MOVES) 2014 model was

used to generate the vehicle emission inventory.   Details on the various county data inputs used to

generate the SO2 inventory are described in Tables 2 and 3.   

Table 1 shows daily (tons per summer day) and annual (tons per year) on‐road SO2 emissions for the

Nonattainment Area.  Emissions within each state portion of the Nonattainment Area are also shown.    

Vehicle miles traveled (VMT) in the nonattainment area ranges from 510 million per year in 2011 to 570

million per year in 2027.  Information on OKI’s process for developing forecasts of future travel patterns

is provided.

Table 1

Campbell‐Clermont KY‐OH SO2 Nonattainment Area ‐ Daily On‐Road Emissions (tons per summer day)

   2011 2014 2017 2020 2022 2027

Campbell‐Clermont

SO2 Daily Mobile

Emissions  

0.006 0.006 0.006 0.006 0.006 0.005

Campbell, KY (partial) 0.005 0.005 0.005 0.005 0.005 0.004

Clermont, OH (partial) 0.001 0.001 0.001 0.001 0.001 0.001

               

Campbell‐Clermont KY‐OH SO2Nonattainment Area ‐ Annual On‐Road Emissions (tons per year)

   2011 2014 2017 2020 2022 2027

Campbell‐Clermont

SO2 Annual Mobile

Emissions  

1.887 1.837 1.757 1.702 1.668 1.537

Campbell, KY (partial) 1.547 1.506 1.441 1.396 1.368 1.260

Clermont, OH (partial) 0.340 0.331 0.316 0.306 0.300 0.277
6 On‐Road SO2Emissions Inventory for Campbell‐Clermont Counties, KY‐OH SO2Nonattainment Area,

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Mobile Source Emission Forecast Process

Emission Factor Model

OKI’s inventory assessment utilized U.S.EPA’s emissions model MOVES2014 to generate SO2 emissions.  

Table 3 summarizes the settings used in the MOVES run specification file.  Table 4 lists the data used in

the MOVES County‐Data Manager.    Further technical details on the use of MOVES are found in the

appendix to the OKI report “Mobile Source Emissions Inventory for Cincinnati PM2.5 Nonattainment

Area”, revised December 2010.

Table 2

MOVES Run Specications  Parameter Settings

MOVES 2014 default database 20141021

Scale County, Emission Rates

Time Span Time aggregation = Hour

July and April weekday, July meteorological

data and annual average meteorological data

used in place of April data

All hours of day selected

Weekdays only  

Geographic Bounds One Custom Domain for 3 Kentucky counties

Vehicles/Equipment All vehicle source types.  Fuel types=gasoline,

diesel, ethanol and CNG

Road Type All road types including off‐network

Pollutants and Processes SO2.  No emissions from refueling.  

Strategies Default

General Output Units= grams, joules and miles

Output Emissions Time = hour, Location =county, on‐road

emission rates by road type and source use

type.

Advanced Performance none
7 On‐Road SO2Emissions Inventory for Campbell‐Clermont Counties, KY‐OH SO2Nonattainment Area,

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Table 3

MOVES County Data Manager Data Source

Source Type Population Local and default.  Local data from KYTC (2013) and ODOT (2010)

from motor vehicle registration data.  Default data used for source

types 41, 61 and 62 in Ohio and types 61 and 62 in Kentucky.  

Growth factor applied for future years.   

Vehicle Type VMT Local and default.  HPMSVTypeYear VMT=daily VMT from OKI travel

demand model with EPA’s daily to annual VMT converter applied.  

monthVMTFraction = default. dayVMTFraction=default,

hourVMTFraction=local.

I/M Programs No I/M program.

Fuel Formulation Default MOVES2014 fuel formulations.  Reflects RFG program in KY.

Fuel Supply Default

Meteorology Data Local.  MOBILE6 converted values for Ohio and Kentucky values

from Kentucky Division for Air Quality.

Ramp Fraction Local. OKI travel demand model.

Road Type Distribution Local. OKI travel demand model.

Age Distribution Local and default.  Local data from KYTC (2013) and ODOT (2010)

from motor vehicle registration data.  Default data used for source

types 41, 61 and 62 in Ohio and types 61 and 62 in Kentucky.

Average Speed Distribution Local.  OKI travel demand model.

OKI Travel Demand Model

Vehicle miles traveled and vehicle hours were estimated using the OKI Travel Demand Model Version

7.6. The OKI Travel Demand Model is composed of CUBE Voyager programs and a series of FORTRAN

programs written by OKI. It is a state of the practice model that uses the standard four phase sequential

modeling approach of trip generation, distribution, modal choice and assignment. The model uses

demographic and land use data and capacity and free‐flow speed characteristics for each roadway

segment in the network to produce a “loaded” highway network with forecasted traffic volumes with

revised speeds based on specified speed/capacity relationships.   

Travel analysis zones are the basic geographic unit for estimating travel in the OKI model. The OKI region

is subdivided into 1608 traffic analysis zones to permit detail as well as manageability. A variety of

socioeconomic data items are used in the OKI transportation planning process. These data are used

primarily to forecast future travel patterns by serving as independent variables in OKI trip generation

equations. The following categories of planning data are utilized:

• Population (household and group quarter)

• Households
8 On‐Road SO2Emissions Inventory for Campbell‐Clermont Counties, KY‐OH SO2Nonattainment Area,

January 2015

• Household vehicles

• Employment (by employment category and zone of work)

• Labor force participation (by zone of residence)

• Area type

The principal data requirements of the OKI travel demand forecasting model are population and

employment. From these variables, other characteristics including households, labor force, and personal

vehicles may be derived. Chapter 3 of OKI 2040 Regional Transportation Plan Update provides a

complete demographic overview of the region.   

OKI utilizes both base year (2005), past year (2010) and future year data (2015, 2020, 2030, and 2040) in

the planning process. Planning data are maintained at the Traffic Analysis Zone (TAZ) level, and originate

in the 2000 Census of Population and Housing. Base year 2005 and future year data for each variable are

developed through various methods. More detailed explanation of base year and future year data

generation for each of the above‐mentioned categories of planning data follows. All of the variables

represent the latest OKI planning assumptions.

Population

Base and Future Year Data:  Population data for base year 2005, past year 2010 and future years 2015,

2020, 2030, and 2040 originate with the 2000 Census of Population and Housing. Utilizing ArcGIS,

population data at the zonal level for 2000 was derived from the area proportion allocation of block

level population.  

As a tri‐state regional planning agency, OKI uses the most current county level projections as prepared

by the respective state data centers (Ohio Department of Development Office of Strategic Research,

Kentucky State Data Center and Indiana Business Research Center) as control totals. Projections (years

2005 to 2040) were released by the Ohio state data center in 2011, the Indiana state data center in 2007

and the Kentucky State Data Center in 2009. Population projections at the zonal level are calculated by

multiplying household size by the projected zonal households. Household size is factored so that, in each

county, the sum of the zonal populations equals the control total.  

Households

Base Year Data:  Household data for base year 2005 originates with the 2000 Census of Population and

Housing. Utilizing the geographic information system ArcGIS, household data at the zonal level for 2000

was derived from the area proportion allocation of block level households. Year 2000 household data

was updated to 2005 with residential building permits issued between January 2000 and December

2004. The residential building locations were geo‐coded in ArcGIS, and then aggregated to the TAZs. The

housing unit totals for each TAZ were converted to households by applying a vacancy rate, an

adjustment for permitted but unbuilt units, and subtracting demolitions (where data was available).
9 On‐Road SO2Emissions Inventory for Campbell‐Clermont Counties, KY‐OH SO2Nonattainment Area,

January 2015

These households were then added to the year Census 2000 zonal household total to arrive at 2005

households for each TAZ.  

Future Year Data: The preparation of household projections was accomplished by calculating the

number of households for a projected county population using ratios of householders to total

population by age specific cohorts derived from the 2000 Census for each analysis year. Disaggregation

to TAZs was determined by historical trends, existing and future land use, topography, flood plain

information, availability of land, local knowledge and other factors.

Household Vehicles

Base and Future Year Data:  Base and future year household vehicle data were obtained from the 2000

Census of Population and Housing. The 2000 Census was the only source of household vehicle data

available at the block group level at the time the data was developed. Average vehicles per household

were calculated for block groups then applied to the TAZs associated with each block group. The 2005,

2010, 2020, 2030 and 2040 vehicles per household level was held at the 2000 level based on the fact

that, since 2002, the number of vehicles per household has exceeded the number of drivers per

household.  

Labor Force

Base and Future Year Data:  The OKI labor force is a function of the population as determined by a labor

force participation ratio (the number of employed persons in the labor force per persons 16 and over).

Household data for base year 2005 originates with the 2000 Census of Population and Housing. Utilizing

the geographic information system ArcGIS, household data at the zonal level for 2000 was derived from

the area proportion allocation of block group level employed labor force. The labor force projections for

2005, 2010, 2015, 2020, 2030, and 2040 were based on the most recent projections of national labor

force participation rates by age and sex cohorts from the U.S. Department of Labor, Bureau of Labor

Statistics for each of those years. These rates were then applied to the projected county age/sex cohorts

and adjusted to eliminate the unemployed to arrive at a county employed labor force control total.  

Employed labor force at the zonal level is calculated by multiplying the labor force participation rate by

the zonal population. The labor force participation rate is adjusted so that, in each county, the sum of

the zonal labor force counts equals the control total.  

Employment

Base Year Data:  Quarterly Census of Employment and Wages (QCEW or ES202) data for 2005 was

utilized as the primary tool to calculate employment at the zonal level. Individual business records

containing physical location, number of employees and North American Industry Classification System

(NAICS) code were geocoded through ArcGIS and aggregated to the TAZ level. This data set was

supplemented by other sources of data to complete the commuting employment picture in the OKI

region. Each zone’s employment was divided according to the NAICS code into three classes (retail,

office, industrial) based upon the potential for generating trips.  
10 On‐Road SO2Emissions Inventory for Campbell‐Clermont Counties, KY‐OH SO2Nonattainment Area,

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Future Year Data:  For future year employment projection, calculation was first made of the

employment at the regional level. At the regional level, employment is a calculation of the region’s

employed labor force minus workers who live in the region but commute out to work, plus workers who

live outside the region but commute in to work. The regional total was disaggregated first to the county

level based on historic trends and expected changes in the county’s share of the region’s employment

and then to the TAZ level. Disaggregation to TAZs was determined by historical trends, existing and

future land use, topography, flood plain information, availability of land, local knowledge and other

factors.

Area Type

Base and Future Year Data:  For each analysis year, each TAZ is assigned an area type designation as

CBD, Urban, Suburban or Rural based on population and employment densities.  

Model Calibration

OKI’s Travel Demand Model has been validated to observed traffic volumes for the model base year

2005. The modeling network encompasses the entire ozone Maintenance area with the exception of

Clinton County, Ohio. The modeling network also includes Greene, Miami and Montgomery counties in

Ohio and the remainder of Dearborn County Indiana. The difference between estimated vehicle miles

traveled (VMT) and 2005 observed VMT is less than 1%. A highway screenline analysis compares the

screenline observed and simulated traffic volume discrepancies with the ODOT standard of maximum

desirable deviation.  The comparison shows that the model performs at a satisfactory level and all the

errors were under the ODOT curve. Further information can be found in OKI’s 2007 report, “OKI/MVRPC

Travel Demand Model Methodology/Validation Report”.  For the calibration, OKI used over 3000 traffic

counts collected through 2006 by the Ohio Department of Transportation (ODOT), the Kentucky

Transportation Cabinet, many county and local governments, transportation engineering consultants,

and OKI. These traffic counts cover nearly 50% percent of the links in the OKI portion of the modeling

network. The methodology provides consistency with past emission inventory and conformity analysis

work performed by OKI.  

Local Inputs and Post‐Model Processing

OKI incorporates a variety of sources of local data to both improve and confirm the accuracy of VMT, as

well as other travel‐related parameters. Free flow speeds used on the highway and transit networks are

based on travel time studies performed locally. The OKI post‐processing program, IMPACT, uses the

loaded highway network to generate VMT by hour, VMT by speed distribution and VMT by facility type.

These tables are then included as input into MOVES.  Two separate sets of VMT tables are generated:

one for the four Ohio counties plus Dearborn County Indiana, and a second for the three Kentucky

counties.  The VMT by hour tables utilize hourly traffic distribution and directional split factors for

different roadway types as developed by OKI. The main source of the data was the permanent traffic

counting stations located throughout the OKI region for the years of 2004‐2006. This data was

supplemented with data collected at coverage count stations (locations with counts taken on only one‐
11 On‐Road SO2Emissions Inventory for Campbell‐Clermont Counties, KY‐OH SO2Nonattainment Area,

January 2015

two days). The stations were classified by area type: urban and rural, and functional classification:

freeway, arterial and collector. Speeds representing various “loaded” conditions (with traffic volumes)

are estimated using techniques from the 1997 Highway Capacity Manual. This permits the estimation of

speeds as conditions vary from hour to hour on the different facility types throughout the region. The

IMPACT program performs the appropriate summation by area and roadway type as well as regional

totals. OKI has also developed seasonal conversion factors to adjust traffic volumes to summer

conditions. The factors were derived from local data collected at permanent traffic counting stations

during 2004‐2007 utilizing the average daily traffic monthly conversion factors for June, July and August.   

Use of SO2 Nonattainment Area District in Post‐Model Processing

U.S.EPA defined the census tracts included in the Campbell‐Clermont KY‐OH SO2 Nonattainment area.   

These same census tract boundaries were used to establish a “reporting district” in the OKI post‐model

processing.  Average speed and VMT distribution by month, hour, vehicle type and road type were

generated for the SO2 nonattainment area and used in the emission calculation.  Emissions were further

split into Kentucky and Ohio portions based on the percentage of calculated nonattainment area VMT

within each state.
APPENDIX F
Appendix F

Background Concentration Determination for Non-Attainment Area

January 23, 2015

U.S.EPA issued the “Guidance for 1-Hour SO2 Nonattainment Area SIP Submissions”

on April 23, 2014. In Appendix A of the guidance, several approaches for determining 

the SO2 background concentrations are suggested. In this appendix, Ohio EPA, working 

with the Kentucky DAQ, has applied the methods suggested in U.S. EPA’s guidance to 

identify the potential SO2 background concentration in the Campbell County KY-OH,

nonattainment area for the 1-hour SO2 National Ambient Air Quality Standard (NAAQS).

According to the guidance, a “first tier” approach uses a uniform monitored background 

contribution based on the overall highest hourly background SO2 concentration from a 

representative monitor. However, this approach is identified as “... conservative in many 

cases and may also be prone to reflecting source-oriented impacts, increasing the 

potential for double-counting of monitored contribution.” Therefore, U.S.EPA 

recommends a less conservation “first tier” method based on the monitored design 

values for the latest 3-year period. From the design value report (See Appendix A-2 of 

the Redesignation Request and Maintenance Plan) at Monitor 21-037-3002 for 2012-

2014, the 3-year design value is 72 ppb, which is slightly less than the 2010 1-hour SO2

NAAQS. Thus, both of the “first tier” methods are overly conservative and are not 

appropriate for determining the background concentration of this area.

As discussed in U.S. EPA’s guidance, Section 8.2.2.b of Appendix W provides another 

option:

“Use air quality data in the vicinity of the source to determine the background 

concentration for the averaging times of concern. Determine the mean 

background concentration at each monitor by excluding concentrations when the 

source in question is impacting the monitor...For shorter time periods, the 

meteorological conditions accompanying concentrations for concern should be 

identified. Concentrations for meteorological conditions of concern, at monitors, 

not impacted by the source in question, should be averaged for separate 

averaging time to determine the average background value. Monitoring sites 

inside a 90 degree sector downwind of the source may be used to determine the 

area of impact.”

The Kentucky monitor 21-037-3002 is the only monitor located in the vicinity of our 

study area suitable for this analysis. Two major SO2 emission sources, Duke Energy’s 

W.C. Beckjord (Beckjord) and W. H. Zimmer (Zimmer) facilities were considered as a 

part of this analysis and concentrations were excluded when these sources in question 

were impacting the monitor.

Google Earth tools were used to determine an arc of 90 degrees when these two

sources in question are impacting the monitor, and the hourly meteorological data 

(WBAN: 93814) was downloaded via ftp://ftp.ncdc.noaa.gov/pub/data/noaa/isd-lite. As 

can be seen in the Figure 1 below, these two sources would impact the monitor when 
the wind blows from 74.81° to 164.81°. Therefore, the hourly monitoring data with the 

recorded wind directions within the range were eliminated. 

Figure 1

The average SO2 concentration was then calculated for each year in the 2010-2014 

dataset which was retrieved from U.S. EPA’s Air Quality System (AQS). Data for 2014 

was only available through August 31, 2014 at the time of this analysis. In addition, to 

be more conservative, the annual average SO2 concentrations for non-zero values 

were calculated. The results show the highest value, 4.40 ppb, is the background 

concentration for this area using this approach (see Table 1).

Table 1

Year Background Concentration (all data) 

(unit: ppb)

Background Concentration (nonzero) (unit: ppb)

2010 3.82 4.36

2011 2.12 4.10

2012 1.16 3.91

2013 1.01 4.40

201411.86 2.89

 

1

Through August 31, 2014
Because it has been determined that Beckjord is the only source impacting this monitor, 

and given their proximity to the monitor and the predominant wind directions potentially 

impacting the monitor, the same analysis was also conducted and concentrations were 

excluded only when Beckjord was impacting the monitor. Again, Google Earth tools 

were used to determine an arc of wind directions to exclude from the background 

determination. In this instance, a reduced arc of 45 degrees was used instead of 90 

degrees. It was determined that an exclusion arc of 90 degrees relative to the monitor 

would potentially eliminate any potential contributions of Zimmer emissions to monitor 

values. The reduced arc allows for the exclusion of Beckjord emission impacts, the 

inclusion of Zimmer impacts, and provides an additional measure of conservatism to the 

background determination. The hourly meteorological data (WBAN: 93814) was

downloaded via ftp://ftp.ncdc.noaa.gov/pub/data/noaa/isd-lite. As can be seen in the 

Figure 2 below, Beckjord would impact the monitor when the wind blows from 81° to 

126°. Therefore, the hourly monitoring data with the recorded wind directions within the 

range were eliminated. 

Figure 2

The average SO2 concentration was then calculated for each year in the 2010-2014 

dataset. Again, to be more conservative, the annual average SO2 concentrations for 

non-zero values were calculated. The results show the highest value, 4.76 ppb, is the 

background concentration for this area using this approach (see Table 2).
Table 2

Year Background Concentration (all data) 

(unit: ppb)

Background Concentration (nonzero) (unit: ppb)

2010 3.82 4.49

2011 1.94 4.28

2012 1.03 4.29

2013 0.8 4.76

201421.66 2.91

In summary, the background concentration for this area can be conservatively 

estimated at 4.76 ppb without double-counting emissions from Beckjord based on the 

above analysis.

To preserve conservatism in the background and to demonstrate further that the 

shutdown of the Walter C. Beckjord facilities provides for attainment, Ohio EPA 

conducted an analysis of hourly SO2 concentrations recorded at monitor 21-037-3002, 

wind direction data from the Cincinnati weather station located at the Cincinnati 

Northern Kentucky Airport, and emissions from both the Walter C. Beckjord and William 

H. Zimmer facilities for years 2012 through February 28, 2015. The full analysis is 

presented in detail in Appendix K of the redesignation request. Briefly, Ohio EPA 

compiled 2,939 non-zero monitor values for which SO2 emissions from the Walter C. 

Beckjord facility were zero. The 99th percentile value of these hourly data is the 29th

highest hourly value, or 11 ppb. Note that 11 ppb represents the 99th percentile of all 

hours, not of maximum daily values and is therefore more conservative than an actual 

design value for this period. Additionally, by not attempting to account for plume travel 

time from the Walter C. Beckjord facility to the monitor, it is likely that some hours in this 

dataset represent impacts of emissions from the Walter C. Beckjord facility, and 

therefore carry an additional measure of conservatism. As noted in Appendix K of the 

redesignation request, no exceedances of the standard were recorded at any hour for 

which emissions from Walter C. Beckjord were zero. 

 

2

Through August 31, 2014
APPENDIX G
Walter C. Beckjord SO2 Emissions

Source: Clean Air Markets Division

Unit ID Year SO2 (tons)

Total for

Year (tons) Unit January February March April May June July August September Octob

1 2008 2,431.54 5 2312.89 1233.69 1841.44 1965.11 288.49 6.11 1348.93 119.98 0.00 02 2008 1,738.06 6 5010.98 3795.20 3667.22 3549.07 0.00 5.74 4817.56 2640.04 0.00 03 2008 3,554.09 Facility 7323.87 5028.90 5508.66 5514.18 288.49 11.85 6166.49 2760.01 0.00 0

4 2008 4,985.545 2008 4,712.976 2008 8,978.32 26,400.52

1 2009 2,097.942 2009 2,527.043 2009 3,347.044 2009 6,756.475 2009 7,566.786 2009 19,669.24 41,964.51

1 20102 20103 20104 2010 4,492.465 2010 17,719.176 2010 46,944.64 69,156.26

1 20112 2011 44.333 2011 42.044 2011 2,884.315 2011 30,555.616 2011 57,308.22 90,834.50

1 20122 20123 2012 1,732.394 2012 2,697.965 2012 19,639.146 2012 42,999.34 67,068.83

1 20132 20133 20134 2013 1,546.015 2013 19,324.966 2013 31,029.36 51,900.33

1 20142 20143 20144 20145 2014 9,116.646 2014 23,485.80 32,602.44
APPENDIX H
Public Notice 

Ohio Environmental Protection Agency 

Redesignation and Maintenance Plan for the 

Ohio Portion of the Campbell-Clermont KY-OH 502 Nonattainment Area 

Pierce Township in Clermont County 

Notice is hereby given that the Director of the Ohio Environmental Protection Agency, 

(Ohio EPA) is requesting that the United States Environmental Protection Agency (U.S. 

EPA) revise the current air quality designation for the Ohio portion, Pierce Township in 

Clermont County, of the Campbell-Clermont KY-OH nonattainment area to attainment 

with respect to the 2010 1-hour S02 national ambient air quality standard (NAAQS). Air 

quality monitoring data collected between 2012 and 2014 in the nonattainment area 

demonstrates attainment of the NAAQS and there is evidence that the improved air 

quality is due to permanent, enforceable emission reductions. In addition, existing 

requirements are sufficient to maintain the 2010 1-hour S02 standard in this area at 

least ten years into the future. 

The permanent shutdown of the Walter C. Beckjord power plant in this area has 

resulted in significant S02 emission reductions. Ohio EPA proposes to utilize existing 

emission inventory information and projections of future emissions as the 

demonstration of the ability to maintain the NAAQS in the Campbell-Clermont KY-OH 

area in the future. 

The State of Ohio proposes to: 

1. Request the U.S. EPA redesignate the Ohio portion, Pierce Township in 

Clermont County, of the Campbell-Clermont KY-OH area to attainment with 

respect to the 2010 1-hour S02 NAAQS and incorporate the maintenance plan. 

This request will document that existing enforceable control measures are 

responsible for the observed improvement in air quality; and 

2. Designate existing controls (permanent shutdown) as sufficient to maintain the 

NAAQS into the future. 

These actions must be noticed to allow public comment and to satisfy USEPA 

requirements for public involvement in SIP related activities. This notice addresses Ohio 

EPA's reliance on the emission projections as evidence of attainment and maintenance. 

Written comments will be received on or before April 16, 2015 at the following address: 

E-mail: Erica.Fetty@epa.state.oh.us 

Mailing address: Erica Fetty 

Ohio Environmental Protection Agency, DAPC 

Lazarus Government Center 
P.O. Box 1049 

Columbus, Ohio 43216-1049 

Pursuant to Section 119.03 of the Ohio Revised Code, a public hearing on this 

redesignation request will be conducted as follows April 16, 2015 at 3:00 PM, at the 

Pierce Twp. Administration Building, 950 Locust Corner Rd., Cincinnati, OH 45245. 

All interested persons are entitled to attend or be represented at the hearings and give 

written or oral comments on these changes. All oral comments presented at the 

hearing, and all written statements submitted at the hearing or to the above address by 

the close of business on April 16, 2015 will be considered by Ohio EPA prior to final 

action on this redesignation. Written statements submitted after April 16, 2015 may be 

considered as time and circumstances permit, but will not be part of the official record 

of the hearing. 

This redesignation and maintenance request is available on Ohio EPA DAPC's Web 

page for electronic downloading at: http://ww

.epa.ohio.gov/dapc/SIP/so2.aspx. 

Questions regarding accessing the web site should be directed to Paul Braun at 614-

644-3734; other questions or comments about this document should be directed to 

either Erica Fetty, (614)-644-2310, Erica.Fetty@epa.ohio.gov or Jennifer Van Vlerah at 

(614) 644-3696, Jennifer.vanvlerah@epa.ohio.gov or mailed to Erica Fetty or Jennifer 

Van Vlerah at the above address. 
Ohio EPA 

Division of Air Pollution Control 

Response to Comments 

Redesignation Request and Maintenance Plan for the Campbell-Clermont 

KY-OH Sulfur Dioxide (S02) Nonattainment Area 

Agency Contacts for this Project 

Division Contact: (Jennifer Van Vlerah, Division of Air Pollution Control, 614-644-3696, 

jennifer. vanvlerah@epa.ohio.gov) 

Ohio EPA held a public hearing in Cincinnati, OH on April 16, 2015, regarding the 

Redesignation Request and Maintenance Plan for the Campbell-Clermont KY-OH S02 

nonattainment area. This document summarizes the comments and questions received 

at the public hearing and during the associated comment period, which ended on April 

16, 2015. 

Ohio EPA reviewed and considered all comments received during the public comment 

period. By law, Ohio EPA has authority to consider specific issues related to protection 

of the environment and public health. 

In an effort to help you review this document, the questions are grouped by topic and 

organized in a consistent format. The name of the commenter follows the comment in 

parentheses. 

Comment 1: The Utilities support Ohio EPA's request for redesignation of 

Pierce Township in Clermont County. Of note one the 

redesignation requests, the Walter C. Beckjord facility 

ceased operation on September 1, 2014 and Ohio EPA was 

notified of the permanent shutdown on October 14, 2014. 

There is no other significant source located in the area. 

Ohio EPA has determined that the violations at the monitor 

were likely cause by the Beckjord facility. Since there are no 

longer any significant sources impacting this monitor, the 

Utilities believe that it is appropriate to redesignate this area 

as attainment for the one-hour S02 NAAQS. (Cheri A. 

Budzynski, Shumaker, Loop & Kendrick, LLP on behalf 

of the Ohio Utility Group) 
Response 1: 

Comment2: 

Thank you for your comment and support on Ohio's request. 

Ohio EPA agrees the area should be designated to 

"attainment" and will be requesting the "attainment" 

designation in lieu of an "unclassifiable" designation. 

Attaining the standard: 

The key test here is whether, on the basis of available 

evidence, we can conclude that the entirety of the 

nonattainment area is now attaining the standard. Please do 

not suggest that EPA Regions 4 and 5 agreed with a 

determination that an analysis of maximum concentration 

location was not warranted. To the extent that Zimmer is the 

most significant remaining source anywhere near the area, 

that would suggest that the maximum concentration location 

would be the portion of the area closest to Zimmer. Thus, to 

that extent, the question instead would be whether the 

monitor provides a sufficient representation of 

concentrations throughout the non attainment area to be able 

to conclude that the entire area, including portions of the 

area closer to Zimmer, are attaining the standard. Modeling 

of Beckjord of course is unnecessary, but Ohio needs to 

make more of a case that modeling of other sources is not 

necessary to determine that even concentrations even at the 

maximum concentration location in the nonattainment area 

are below the standard. 

The trajectory analysis is a key part of this evaluation, even 

though the work was done more to determine contribution at 

the monitor location rather than impacts throughout the 

nonattainment. An important point is that trajectories in 

which winds do not carry emissions from Zimmer to the 

monitor also represent trajectories that largely do not carry 

emissions from Zimmer to any of the rest of the 

nonattainment area, either. Another important point is that 

Zimmer is sufficient distance from the nonattainment area to 

conclude that impacts at the nearest edge of the 

nonattainment area are likely to be similar to impacts at the 

monitor. (For making this point. it would be useful to 

compare the distance from Zimmer to the nonattainment 

area versus the distance from Zimmer to the monitor.) This 

would support an argument that, with Beckjord emissions at 

zero, concentrations throughout the nonattainment area are 

relatively uniform, such that concentrations elsewhere in the 

nonattainment area would not likely be significantly higher. 

It would also be useful to examine air quality data in relation 

to emissions from Beckjord, for example to examine air 
quality for the portions of 2014 when emissions were low or 

even zero. You analyze average concentrations with and 

without the two units at Beckjord, but it would be useful to 

analyze more of a peak statistic for the period, e.g. the ggth 

percentile (if this statistic is adequately robust). Data 

collected so far in 2015 may be useful for this purpose. I 

recognize that these periods did not constitute an entire 

year, but these data would likely provide strong support for 

the hypothesis that a scenario in which Beckjord emissions 

are zero can be expected to have attaining air quality 

throughout the area, even in portions of the nonattainment 

that might have more impact from sources like Zimmer that 

are outside the nonattainment area. 

Figure 3 is intended to illustrate the relationship between 

emissions at Beckjord and Zimmer and air quality, but 

several aspects of this figure obscure the relationship. First, 

it is not clear which label applies to which of the three 

graphs. Second, it is not clear what an "18 per. Mov. Avg." 

is or why this statistic was used. I presume it is an average 

of 18 hours of data, but the use of this statistic would seem 

to obscure the level of the peak concentrations that are of 

most concern. Finally, this set of graphs is difficult to 

interpret. Given the importance of demonstrating that the 

shutdown of Beckjord has had and will have a dramatic 

impact on 802 concentrations in the area, it is worth the 

effort to improve the presentation of the information that can 

be obtained from the data used in preparing these graphs. 

Appendix D focuses on Zimmer. Ohio should also address 

whether any sources elsewhere, such as in Hamilton 

County, are prone to have significant impacts anywhere in 

the nonattainment area. The trajectories suggest not, but 

this is an important point to address. 

I am stressing this point because we have other areas 

around the country that are seeking clean data 

determinations. I am aware of another case where a 

relatively small nonattainment area has only one source, 

which has shut down, but several other nearby sources are 

continuing to operate, and we seem likely to reject the clean 

data determination in absence of evidence, presumably in 

the form of modeling, to demonstrate that the (clean) monitor 

adequately represents the maximum concentration location 

with respect to the remaining sources. Your submittal for the 

Campbell-Clermont area must address the issue of whether 

data from the monitor provides adequate evidence that the 
Response 2: 

Comment3: 

Response 3: 

entire area is attaining. (U.S. EPA Region V, submitted via 

email) 

Ohio EPA has incorporated several additional changes to 

our request to address evidence of attainment of the 

standard. Several clarifications and additional analyses are 

incorporated into the body of the redesignation document, 

additional revisions were incorporated into the background 

analysis (Appendix F), an additional monitor analysis 

(Appendix K) was performed, and an additional modeling 

analysis (Appendix J) was also performed. These revisions 

clearly shows that the shutdown of Beckjord will ensure 

attainment throughout the entire nonattainment area taking 

into consideration the potential impact of other sources 

within the vicinity but located outside the nonattainment 

area. 

Adequate SIP: 

More important than the infrastructure SIP is all your rules in 

OAC 3745-18, most notably 3745-18-19 and perhaps 3745-

18-37. 

I presume that the reason biogenic emissions are not 

included is because you believe these emissions to be 

negligible, not because you didn't want to take the effort to 

compute them or because you didn't want us to 

know. Although Kentucky emissions are low, it would be 

worth explaining why non-EGU emissions become zero by 

2020. I'm not sure what the "safety margin" column 

signifies. Perhaps this column would have meaning if you 

were compiling conformity budgets, but I understand you are 

finding that no conformity budget is needed. 

In light of the recent Sixth Circuit decision in relation to the 

redesignation of the Cincinnati area for PM2.5, Ohio may or 

may not be "obligated to submit RACM and RACT." This 

makes Ohio's second rationale, relating to the absence of 

major point sources, more important. A better way of 

arguing that Ohio has satisfied these requirements is to state 

that in absence of major point sources, no point source 

emission controls are possible. Ohio should also address 

minor source measures, presumably to conclude that no 

further measures constitute RACM on the minor sources that 

remain. (U.S. EPA Region V, submitted via email) 

Ohio EPA has incorporated additional information in Chapter 

5, Requirement 4 of 6, to identify the importance of the OAC 
Comment4: 

Response 4: 

Comment 5: 

3745-18 regulations. Ohio EPA has also provided 

clarification regarding the negligible biogenic emissions in 

Chapter 4, Requirement 1 of 4. In addition, the tables in this 

section were corrected for rounding errors and the accidental 

omission of non-EGU emissions in 2020 and 2027 and to 

remove the "safety margin" column which has no significant 

meaning. 

With respect to RACM/RACT, additional clarification was 

incorporated into Requirement 1 of 6 under Chapter 5. 

Permanent and enforceable cause of air quality 

improvement: 

Discussion of the permanence and enforceability of 

Beckjord's shutdown should be included in this 

section. After noting that the letter from the company results 

in the termination of the permit that authorizes them to 

operate, you should identify the provisions in state regulation 

that the state and EPA could enforce that prohibit operating 

without such a permit. Discussion of the relationship 

between the decline and cessation of Beckjord's emissions 

and air quality (as discussed above in relationship to air 

quality) would also help make the case that the air quality 

improvement seen so far, from 2011 to present, is 

attributable to the shutdown of Beckjord. This section should 

clarify that the entirety of Beckjord is required not to operate, 

i.e. that allowable emissions from the entire facility are now 

zero. (U.S. EPA Region V, submitted via email) 

Ohio EPA has made clarification throughout the request 

regarding the permanence of Beckord's shutdown of the 

major coal fired units and more recent permanent shutdown 

of the minor oil-fired units (see newly added Appendix 1). It 

should be noted that the minor oil-fired units contributed little 

to no sulfur dioxide emissions. This now represents 

shutdown of the entirety of the facility. 

Ohio EPA has also provided clarification on how the state 

and U.S. EPA could enforce the prohibition of operating 

without a permit and/or after notification of permanent 

shutdown. This clarification is provided in Requirement 3 of 

4 under Chapter 4. 

Maintenance: 

Modeling or having emissions below the attainment 

inventory are not the only options for demonstrating 
Response 5: 

maintenance. In particular, I am much less convinced of 

maintenance by having future emissions below 32,619 tpy 

than I am by having emissions at 16 tpy. For S02, I would 

not say (especially for a nonattainment area) that 

"maintenance is demonstrated [when emissions are below 

2014 levels.]" Similarly, the fact that you consulted with EPA 

regions 4 and 5 is not a good reason to forgo 

modeling. Clearly, you have reasons to forgo modeling, 

beyond simply that "unique circumstances" exist, and you 

should articulate those reasons. 

Perhaps I was not clear why we recommended analyzing 

background concentrations. If you "model" Beckjord as 

having zero emissions, and there are no other sources with 

impacts not represented in the background concentration, 

then the background concentration is the entirety of the 

future "modeled" (predicted) concentration. That is, it 

appears that you may reasonably assert that you anticipate 

future design values to be on the order of 5 ppb. In these 

circumstances, a reasonable anticipation of design values 

around 5 ppb is a stronger argument for maintenance than 

the anticipation of emissions being below 32,619 tpy. 

We acknowledge (and it would be worth stating explicitly) 

that the absence of sources with any evident potential to 

cause violations means that Ohio cannot anticipate what 

might cause a violation in this area and thus what 

contingency measures might exist that might help address 

any future violation. Nevertheless, Ohio should specify what 

event (e.g., what monitored concentration) would trigger the 

process of investigating and adopting contingency measures 

and what timetable Ohio would expect to operate under. 

(U.S. EPA Region V, submitted via email) 

Ohio EPA has provided clarification in Requirement 2 of 4 

under Chapter 4 regarding the demonstration of 

maintenance. In addition, several additional analyses were 

incorporated, as discussed in response 2 above, to assist in 

further demonstrating both attainment and maintenance. 

In addition, Requirement 2 of 4 under Chapter 4 provides 

additional summaries and analyses regarding background 

concentrations. 

Lastly, Ohio EPA has incorporated additional clarification 

and triggering events for contingency measures under 

Requirement 2 of 4 and Requirement 3 of 4 under Chapter 

6. 
Comment6: 

Response 6: 

Comment 7: 

Response 7: 

CommentS: 

Satisfaction of section 11 0 and Part D: 

Discussion of the satisfaction of section 110 and Part D 

should include discussion of the satisfaction of section 

110(a)(1). These provisions, which work in concert with the 

provisions of Part D and most notably require providing for 

attainment, are at least as important to address as the 

"infrastructure" provisions of section 11 O(a)(2). {U.S. EPA 

Region V, submitted via email) 

Ohio EPA has added additional clarification under Chapter 2 

(5.a) to address the importance of section 11 O(a)(1 ). 

I guess I would like to provide testimony. I would like to ask 

that the State of Ohio EPA hold this in abeyance until you 

receive an answer to whether the peaking units that are in 

the east end of the Beckjord plant will be decommissioned 

and never used. I'd like a response from that. And also I'd 

like to know whether they have been calculated in the sulfur 

dioxide output, and whether they are presently able to burn 

low sulfur and whether this is a consideration that has been 

included in this, because the notice simply indicates that the 

Walter C. Beckjord plant is being closed that is the coal fire 

plant, and there is a major peaking unit on the east end of 

the plant that is referred to as the oil plant and I would like to 

know whether that is actually also being closed and would 

like to know whether they do burn low sulfur oil and whether 

that consideration is involved in this decision. I ask that you 

not make the decision until that is answered because of that 

and that is actually definitively addressed. My name is Daniel 

Owens, I'm a resident of Pierce Township, I'm an attorney, 

and I was a trustee here for 16 years. And I am part of an 

environmental agreement with Duke Energy, that is in the 

28th year of its existence, concerning the Beckjord plant. 

Thank you very much. (Daniel Owens, Hearing Testimony) 

As discussed in response 4, the entirety of the Beckjord 

facility is permanently shutdown. 

My name is Alan Freeman, a Pierce Township resident, I just 

wanted to make sure that I understood that this attainment is 

on for S02, not for any other ozone related compounds; is 

that correct? 

The important thing is that we are going to be hopefully in 

the future in attainment for sulphur dioxide only, not for the 

VOCs or the NOxs. That's important to this area, because 
Response 8: 

quite frankly we have some issues with regard to some other 

agencies that are applying for federal dollars for other ozone 

type related contaminants, we want to make sure those 

won't be harmed in any way and want to move forward with 

those, so that also we can eventually be in attainment for 

ozone related contaminants as well. So moving forward we 

really are hopeful that we can put this on the record that it is 

true that this is only for that one component, not for the 

others, so that we will be able to talk to some of the funders 

in the area, so we will continue to be eligible for those 

appropriate funds without exception. (Alan Freeman, 

Hearing Testimony) 

This submittal does not address ozone but only sulfur 

dioxide. 

End of Response to Comments 
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BEFORE THE OHIO EPA 

PUBLIC INTEREST CENTER 

Proposed Redesignation and Maintenance Plan 

for Pierce Twp. - Pierce Township Bldg. 

(Clermont County) 

April 16, 2015 

PUBLIC COMMENTS 

1 
1 BEFORE: 

2 Ohio EPA Public Interest Center 

Darla Peel1ee 

3 Public Involvement Coordinator 

Northwest and Southwest District Offices 

4 50 W. Town Street 

Columbus, Ohio 4 3215 

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Ohio EPA - Division of Air Pollution Control 

Erica Fetty and Mengyu Cai 

50 W. Town Street 

Columbus, Ohio 43215 

2 
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1 MS. PEELLE: The purpose of this hearing today 

2 is to accept public comments on Ohio EPA's proposed request 

3 to officially recognize that air quality in Pierce Township 

4 for Clermont County, meets the Federal air quality standard 

5 for sulphur dioxide. 

6 Pierce Township is part of the Campbell Township 

7 Kentucky/Ohio non-attainment area for the 2010 one-hour 

8 sulphur dioxide national ambient air quality standard. 

9 Air quality monitoring data collected between 2012 

10 and 2014 demonstrates the area is now meeting the standard. 

11 Ohio EPA believes the improved air quality is due to the 

12 permanent emission reductions following the shutdown of the 

13 Walter C. Beckjord Power Plant. 

14 Ohio EPA published a public notice to announce the 

15 hearing and public comment period regarding the proposed 

16 redesignation in newspapers in the area. 

17 This notice was issued in Ohio EPA's Weekly Review, 

18 which is a publication that lists by county all Agency 

19 activities and actions taking place in the State of Ohio. 

20 Written and oral comments received as part of the 

21 official record are reviewed by Ohio EPA prior to a final 

22 action of the Director. To be included in the official 

23 record, written comments must be received by Ohio EPA by the 

24 close of business today, April 16th, 2015. Comments received 

25 after today may be considered as time and circumstances would 
4 

1 permit, but will not be apart of the official record for this 

2 hearing. 

3 Written comments can be filed with us today or can 

4 be e-mailed to Erica Fetty at erica.fetty@epa.ohio.gov. You 

5 can get that from either of us at the end of the hearing. 

6 All comments whether written or spoken are given 

7 the same consideration. 

8 Questions and comments made during the hearing will 

9 be responded to in a document known as a response to 

10 comments. Program staff recommendations and comments made by 

11 the public will be taken into consideration. 

12 Once a decision is made by the director the final 

13 decision and response to comments will be made available to 

14 anyone who requests a copy. 

15 If you have questions ask them on the record during 

16 the hearing and the Agency will respond to them in writing 

17 within the responsiveness suR�ary. 

18 Final actions of the Director are appealable to the 

19 Environmental Review Appeals Committee, also known as ERAC. 

20 The board is separate from Ohio EPA and reviews cases in 

21 accordance with Ohio's environmental laws and rules. 

22 Any ERAC decision is appealable to the Franklin 

23 County Court of Appeals. Any order of the Court of Appeals 

24 is appealable to the Supreme Court of Ohio. 

25 Each individual may testify only once and speak for 
1 five minutes, so please use your time wisely. 

2 What I would like to do since this is a small 

3 group, if you would like to provide testimony, if you would 

4 raise your hand, and once you are recognized please proceed 

5 

5 to give your testimony. Please stand in this area so that we 

6 can get a good recording. So if you would like to provide 

7 testimony please come forward at this time. 

8 MR. OWENS: I guess I would like to provide 

9 testimony. I would like to ask that the State of Ohio EPA 

10 hold this in abeyance until you receive an answer to whether 

11 the peaking units that are in the east end of the Beckjord 

12 plant will be decommissioned and never used. 

13 response from that. 

I'd like a 

14 And also I'd like to know whether they have been 

15 calculated in the sulphur dioxide output, and whether they 

16 are presently able to burn low sulphur and whether this is a 

17 consideration that has been included in this, because the 

18 notice simply indicates that the Walter C. Beckjord plant is 

19 being closed that is the coal fire plant, and there is a 

20 major peaking unit on the east end of the plant that is 

21 referred to as the oil plant and I would like to know whether 

22 that is actually also being closed and would like to know 

23 whether they do burn low sulphur oil and whether that 

24 consideration is involved in this decision. 

25 I ask that you not make the decision until that is 
1 answered because of that and that is actually definitively 

2 addressed. 

3 My name is Daniel Owens, I'm a resident of Pierce 

4 Township, I'm an attorney, and I was a trustee here for 16 

6 

5 years. And I am part of an environmental agreement with Duke 

6 Energy, that is in the 28th year of its existence, concerning 

7 the Beckjord plant. Thank you very much. 

8 MS. PEELLE: Thank you. Mr. Owens. Would 

9 anybody else like to provide testimony? 

10 

11 

All right. If there are no further requests for 

testimony we will end the hearing. Please remember that 

12 written comments will be accepted through the close of 

13 business today, April 16th. They can be sent to Erica Fetty 

14 at erica.fetty@epa.ohio.gov. 

15 We do appreciate you coming this afternoon in 

16 helping with the decision-making process. The time is now 

17 3:18 p.m., and the hearing is adjourned, but we will stick 

18 around for a while in case someone shows up. 

19 MR. FREEMAN: My name is Alan Freeman, a 

20 Pierce Township resident, I just wanted to make sure that I 

21 understood that this attainment is on for S02, not for any 

22 other ozone related compounds; is that correct? 

23 

24 

MS. PEELLE: We can't answer questions. 

MR. FREEMAN: Okay. Let it reflect they 

25 nodded their heads. Roll it back I can take care of that. 
1 

2 

3 then. 

MS. PEELLE: (Inaudible.) We can't do that. 

MR. FREEMAN: All right. I will roll it back 

4 The important thing is that we are going to be 

5 hopefully in the future in attainment for sulphur dioxide 

6 only, not for the VOCs or the NOs. 

7 That's important to this area, because quite 

8 frankly we have some issues with regard to some other 

9 agencies that are applying for federal dollars for other 

10 ozone type related contaminants, we want to make sure those 

11 won't be harmed in any way and want to move forward with 

12 those, so that also we can eventually be in attainment for 

13 ozone related contaminants as well. 

7 

14 So moving forward we really are hopeful that we can 

15 put this on the record that it is true that this is only for 

16 that one component, not for the others, so that we will be 

17 able to talk to some of the funders in the area, so we will 

18 continue to be eligible for those appropriate funds without 

19 exception. Works for me. 

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1 CERTIFICATE 

2 - - -

Page: 8 of 9 

3 I, Cheryl D. Edwards, Certified Professional 

Reporter, and Notary Public in and for the State of Ohio, 

4 do certify that the foregoing is a transcript of the 

audio recording in this matter of the proceedings taken 

5 on April 16, 2015. 

6 That I am not an attorney for or relative of 

either party and have no interest whatsoever in the 

7 outcome of this matter. 

8 IN W ITNESS WHEREOF, I have hereunto set my 

hand and official seal of office at Columbus, Ohio, this 

9 24th day of April, 2015. 

10 

11 

Cheryl D. Edwards, 

Notary Public in and for 

the State of Ohio 

12 My commission expires 11/05/18 

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StenoCAT 32 Sample Template 
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9 
SHUMAKER 

Shwnaker, Lo & Kenchick,LLP 

Cl-!HlH A BUDZYNSKI 

419.321.1332 

cbud:-:ynski@:<lk.-law.com 

Huntington Center 

41 South High Street 

Suite 2400 

Columbus, Ohio 43215-6104 

614.463.94<!1 

614.463.1108 fax 

www.slk-Jaw.com 

VIA EMAil. AND U.S. MAIL 

Erica Fetty 

Ohio Environmental Pmtection Agency 

Division of Air Pollution Control 

P.O. Box 1049 

Columbus, Ohio 4321601049 

Erica.Fettv@epa.state.oh.us 

April 16, 2015 

Re: Request for Redesignation of the Ohio Portion of the Campbell-Clermont KYOH Area to Attainment of the 2010 One-Hour Sulfm· Dioxide National 

Ambient Air Quality Standard 

011r File No. 043591 

Dear Ms. Blakley: 

In March 2015, Ohio EPA requested to redesignate the Ohio portion of the CampbellClumont KY-OH Area to Attainment of the 2010 One-Hour Sulfur Dioxide ("S02") National 

Ambient Air Quality Standard ("NAAQS"). The following comments are submitted on behalf of 

the Ohio Utility Group and its member companies ("OUG" or "the Utilities"), 1 which is an 

association of individual electric utilities in the State of Ohio. The electric utilities own and operate 

power plants and other facilities that generate electricity for residential, commercial, industrial, and 

institutional customers. These power plants and other facilities are subject to the Clean Air Act. 

OUG's pmpose, in part, is to participate collectively on behalf of its members in administrative 

proceedings under various environmental laws, including the Clean Air Act and in litigation arising 

from those proceedings that affect electric generatm:s. Thus, the notice affects the members of 

OUG. 

The Utilities support Ohio EPA's reqnest for redesignation of Pierce Township in Clermont 

County. Of note on the redesignation requests, the Walter C. Beckjord facility ceased operation on 

September l, 2014 and Ohio EPA was notified of the permanent shutdown on October 14, 2014. 

There is no other significant source located in d1e area. Ohio EPA has determined that the 

1 The member companies include: AEP Generation Resources Inc., Buckeye Power, Inc., The 

Dayton Power and Light Company, Duke Energy Ohio, FirstEnergy Solutions, and Ohio Valley 

Electric Corporation. 

COLUMBUS I TOLEDO ! TAMPA CHARLOTTE 
Erica Fetty 

April16, 2015 

Page 2 

violations at the monitor were likely caused by the Beckjord facility. Since there are no longer any 

significant sources impacting this monitor, the Utilities believe that it is appropriate to redesignate 

dus area as attainment for the one-hour S02 NAA QS. 

The Utilities appreciate the opportunity to comment on the proposed rule. If you have any 

questions regarding these comments, please contact me. 

V ety truly yours, 

Cheri A. Budzynski 

CAB\bd 

Sl K __ TOL:#256h&Wvl 
Van Vlerah, Jennifer 

From: 

Sent: 

To: 

Cc: 

Subject: 

Summerhays, John <Summerhays.John@epa.gov> 

Friday, April17, 2015 5:31PM 

Fetty, Erica; Van Vlerah, Jennifer 

Bradley, Twunjala; Aburano, Douglas; Portanova, Mary; Blakley, Pamela 

Clermont-Campbell Draft Redesignation Request 

Please consider the following as you proceed toward completing this package. 

1. Attaining the standard: 

The key test here is whether, on the basis of available evidence, we can conclude that the entirety of the nonattainment 

area is now attaining the standard. Please do not suggest that EPA Regions 4 and 5 agreed with a determination that an 

analysis of maximum concentration location was not warranted. To the extent that Zimmer is the most significant 

remaining source anywhere near the area, that would suggest that the maximum concentration location would be the 

portion of the area closest to Zimmer. Thus, to that extent, the question instead would be whether the monitor 

provides a sufficient representation of concentrations throughout the nonattainment area to be able to conclude that 

the entire area, including portions of the area closer to Zimmer, are attaining the standard. Modeling of Beckjord of 

course is unnecessary, but Ohio needs to make more of a case that modeling of other sources is not necessary to 

determine that even concentrations even at the maximum concentration location in the nonattainment area are below 

the standard. 

The trajectory analysis is a key part of this evaluation, even though the work was done more to determine contribution 

at the monitor location rather than impacts throughout the nonattainment. An important point is that trajectories in 

which winds do not carry emissions from Zimmer to the monitor also represent trajectories that largely do not carry 

emissions from Zimmer to any of the rest of the nonattainment area, either. Another important point is that Zimmer is 

sufficient distance from the nonattainment area to conclude that impacts at the nearest edge of the nonattainment area 

are likely to be similar to impacts at the monitor. (For making this point, it would be useful to compare the distance 

from Zimmer to the nonattainment area versus the distance from Zimmer to the monitor.) This would support an 

argument that, with Beckjord emissions at zero, concentrations throughout the nonattainment area are relatively 

uniform, such that concentrations elsewhere in the nonattainment area would not likely be significantly higher. 

It would also be useful to examine air quality data in relation to emissions from Beckjord, for example to examine air 

quality for the portions of 2014 when emissions were low or even zero. You analyze average concentrations with and 

without the two units at Beckjord, but it would be useful to analyze more of a peak statistic for the period, e.g. the gg'h 

percentile (if this statistic is adequately robust). Data collected so far in 2015 may be useful for this purpose. I recognize 

that these periods did not constitute an entire year, but these data would likely provide strong support for the 

hypothesis that a scenario in which Beckjord emissions are zero can be expected to have attaining air quality throughout 

the area, even in portions of the nonattainment that might have more impact from sources like Zimmer that are outside 

the nonattainment area. 

Figure 3 is intended to illustrate the relationship between emissions at Beckjord and Zimmer and air quality, but several 

aspects of this figure obscure the relationship. First, it is not clear which label applies to which of the three 

graphs. Second, it is not clear what an "18 per. Mov. Avg." is or why this statistic was used. I presume it is an average of 

18 hours of data, but the use of this statistic would seem to obscure the level of the peak concentrations that are of 

most concern. Finally, this set of graphs is difficult to interpret. Given the importance of demonstrating that the 

shutdown of Beckjord has had and will have a dramatic impact on 502 concentrations in the area, it is worth the effort 

to improve the presentation of the information that can be obtained from the data used in preparing these graphs. 

1 
Appendix D focuses on Zimmer. Ohio should also address whether any sources elsewhere, such as in Hamilton County, 

are prone to have significant impacts anywhere in the nonattainment area. The trajectories suggest not, but this is an 

important point to address. 

I am stressing this point because we have other areas around the country that are seeking clean data determinations. 

am aware of another case where a relatively small nonattainment area has only one source, which has shut down, but 

several other nearby sources are continuing to operate, and we seem likely to reject the clean data determination in 

absence of evidence, presumably in the form of modeling, to demonstrate that the (clean) monitor adequately 

represents the maximum concentration location with respect to the remaining sources. Your submittal for the 

Campbell-Clermont area must address the issue of whether data from the monitor provides adequate evidence that the 

entire area is attaining. 

2. Adequate SIP 

More important than the infrastructure SIP is all your rules in OAC 3745-18, most notably 3 745-18-19 and perhaps 3745-

1 8-37. 

I presume that the reason biogenic emissions are not included is because you believe these emissions to be negligible, 

not because you didn't want to take the effort to compute them or because you didn't want us to know. Although 

Kentucky emissions are low, it would be worth explaining why non-EGU emissions become zero by 2020. I'm not sure 

what the "safety margin" column signifies. Perhaps this column would have meaning if you were compiling conformity 

budgets, but I understand you are finding that no conformity budget is needed. 

In light of the recent Sixth Circuit decision in relation to the redesignation of the Cincinnati area for PM2.5, Ohio may or 

may not be "obligated to submit RACM and RACT." This makes Ohio's second rationale, relating to the absence of major 

point sources, more important. A better way of arguing that Ohio has satisfied these requirements is to state that in 

absence of major point sources, no point source emission controls are possible. Ohio should also address minor source 

measures, presumably to conclude that no further measures constitute RACM on the minor sources that remain. 

3. Permanent and enforceable cause of air quality improvement 

Discussion of the permanence and enforceability of Beckjord's shutdown should be included in this section. After noting 

that the letter from the company results in the termination of the permit that authorizes them to operate, you should 

identify the provisions in state regulation that the state and EPA could enforce that prohibit operating without such a 

permit. Discussion of the relationship between the decline and cessation of Beckjord's emissions and air quality (as 

discussed above in relationship to air quality) would also help make the case that the air quality improvement seen so 

far, from 2011 to present, is attributable to the shutdown of Beckjord. This section should clarify that the entirety of 

Beckjord is required not to operate, i.e. that allowable emissions from the entire facility are now zero. 

4. Maintenance 

Modeling or having emissions below the attainment inventory are not the only options for demonstrating 

maintenance. In particular, I am much less convinced of maintenance by having future emissions below 32,619 tpy than 

1 am by having emissions at 16 tpy. For S02, I would not say (especially for a nonattainment area) that "maintenance is 

demonstrated [when emissions are below 2014 levels.]" Similarly, the fact that you consulted with EPA regions 4 and 5 

is not a good reason to forgo modeling. Clearly, you have reasons to forgo modeling, beyond simply that "unique 

circumstances" exist, and you should articulate those reasons. 

Perhaps I was not clear why we recommended analyzing background concentrations. If you "model" Beckjord as having 

zero emissions, and there are no other sources with impacts not represented in the background concentration, then the 

background concentration is the entirety of the future "modeled" (predicted) concentration. That is, it appears that you 

may reasonably assert that you anticipate future design values to be on the order of 5 ppb. In these circumstances, a 

reasonable anticipation of design values around 5 ppb is a stronger argument for maintenance than the anticipation of 

emissions being below 32,619 tpy. 

2 
We acknowledge (and it would be worth stating explicitly) that the absence of sources with any evident potential to 

cause violations means that Ohio cannot anticipate what might cause a violation in this area and thus what contingency 

measures might exist that might help address any future violation. Nevertheless, Ohio should specify what event (e.g., 

what monitored concentration) would trigger the process of investigating and adopting contingency measures and what 

timetable Ohio would expect to operate under. 

5. Satisfaction of section 110 and Part D 

Discussion of the satisfaction of section 110 and Part D should include discussion of the satisfaction of section 

110(a)(1). These provisions, which work in concert with the provisions of Part D and most notably require providing for 

attainment, are at least as important to address as the "infrastructure" provisions of section 110(a)(2). 

3 
APPENDIX I
����GY. 

OHIO 

May 28, 2015 

Mr. Christopher Beekman 

Ohio EPA - DAPC 

Lazarus Government Center 

50 West Town St., Suite 700 

Columbus, Ohio 43215 

RE: Duke Energy Ohio, Inc., W.C. Beckjord Station 

Facility ID No.: 1413100008 

Emissions Units: B007, B008, B009, and BOlO 

Dear Mr. Beekman: 

Duke Energy Ohio, Inc. 

139 E. 4th Streel 

Cincinnati, OH 45202 

This letter is to inform you that, as of December 31, 2014, the four oil-fired emissions units at 

W.C. Beckjord Station (B007, B008, B009, and BOlO) are permanently shut down and removed 

from service. It is the understanding of Duke Energy Ohio, Inc. that authorization to operate the 

affected units has ceased as of December 31, 2014 and the permittee shall not be required to 

meet any Title V permit requirements applicable to these emissions units, except for any residual 

requirements, such as the quarterly deviation reports and annual compliance certification 

covering the period during which the emissions units last operated. 

Please call Andrew Roebel at 513-287-2356 if you should have any questions regarding this 

information. 

Based on information and belief formed after reasonable inquiry, I certify that all factual 

statements in this transmittal are true, accurate and complete to the best of my knowledge. 

Very truly yours, 

'f

�JS� 

Mark J. Schmidt 

Manager - Reg Plant Demo & Retirement 
APPENDIX J
Appendix J

Supplemental Modeling Demonstration, William H. Zimmer 

Facility

Introduction

This document supports the redesignation request for the Campbell-Clermont partial 

nonattainment area in the State of Ohio and the Commonwealth of Kentucky. This 

nonattainment area encompasses emissions from the Walter C. Beckjord facility. There 

are no other significant sources of SO2 emissions within the nonattainment area that 

warrant inclusion in the modeling analysis. As can be seen from the inventory included 

in the redesignation request, the SO2 emissions from the point sources comprise 

99.95% of the 2014 SO2 emissions in the entire nonattainment area. Notably, violations 

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

facility located along the Ohio River in Ohio east of the monitor. On September 1, 

20141, the Walter C. Beckjord facility ceased operations. Ohio EPA was notified of the 

permanent shutdown on October 14, 2014. (Appendix B and I of the redesignation 

request) There are no other significant point sources of SO2 emissions located in the 

nonattainment area. Within the portion of Campbell County, KY that is a part of this area 

there are 11 sources which combined emit less than one ton per year (tpy) of SO2. 

(Appendix C of the redesignation request) There are no other point sources of SO2

emissions in the portion of Clermont County, OH that is a part of this area. 

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

is the William H. Zimmer facility (see Figure 1). It was determined during the 

nonattainment designation process that emissions from the William H. Zimmer facility 

likely do not impact the violating monitor at question, and therefore, the nonattainment 

area was not expanded to encompass this facility. To support the previous conclusion, 

Ohio EPA performed an extensive meteorology, emissions and back-trajectory analysis 

and has included this analysis as Appendix D of the redesignation request. This 

analysis concludes that it was in fact the Walter C. Beckjord facility that caused the 

violations and not the William H. Zimmer facility.

 

1

The letter contained in Appendix B identifies the permanent shutdown of all units occurred on October 1, 

2014. However, a review of CAMD emissions showed that all the units ceased operation by September 

1, 2014.
Figure 1: Location of monitor 21-037-3002 the William H. Zimmer Station.

In support of this conclusion, Ohio EPA conducted a supplemental modeling analysis to 

determine the location of maximum impact from emissions originating from the William 

H. Zimmer facility as well as a conservative extrapolation of monitored values to the 

point of maximum impact. The supplemental modeling was performed due to the

proximity of the William H. Zimmer facility to the nonattainment area and the level of 

emissions from this source. Ohio EPA determined that the significant distance (30 to 35 

km), prevailing winds, and emission reductions from sources located to the west of the 

nonattainment area did not warrant the inclusion of these sources in a supplemental 

modeling analysis. This is consistent with U.S. EPA’s Ohio Area Designations For the

2010 SO2 Primary National Ambient Air Quality Standard technical support document. 

The analysis presented in this document further demonstrates that emissions from 

William H. Zimmer do not impact the nonattainment area to a significant degree and that 

emissions from William H. Zimmer are not likely to cause exceedances both at the 

monitor location or in the entirety of the nonattainment area. 

Modeling Approach

Per U.S. EPA’s SO2 nonattainment area SIP guidance,

“Appendix A of this document contains modeling guidance supplemental to that 

provided in the preamble to the final rulemaking promulgating the 2010 S02 

NAAQS and in 40 CFR part 51, Appendix W. Appendix A of this document has 

also been updated to respond to issues raised during the comment period related
to the September 2011 draft SO2 Guidance Document. This guidance clarifies 

the EPA's recommendations on how to conduct refined dispersion modeling 

under Appendix W to support the implementation of the 2010 SO2 NAAQS.”

Per the SO2 nonattainment area SIP guidance, five years of National Weather Service 

data is sufficient to represent attainment of the standard. The purpose of this 

demonstration, determining the location of maximum impact of emissions from William 

H. Zimmer and demonstrating that these emissions will not cause exceedances in the 

nonattainment area, necessitates that the limited period of time for which monitor data is 

available after the shutdown of the Walter C. Beckjord facility is replicated by the 

modeling analysis. As such, five years of meteorological data was not used, but a 

limited meteorological dataset from August 30, 2014 to February 28, 2015, inclusive, 

was modeled. This period of time represents the most recent period of time for which 

the Walter C. Beckjord facility is shutdown and data is available. As a full three years of 

data are not available, the modeled form of the standard is expressed as the 99th

percentile of the available 192 maximum daily values. For a time period of 192 days, 

the form of the standard of both monitored and modeled values is represented by the 

second highest maximum daily value. 

The recommended dispersion model for SIP modeling for SO2 is the American 

Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD) 

modeling system. There are two input data processors that are regulatory components 

of the AERMOD modeling system: AERMET, a meteorological data preprocessor that 

incorporates air dispersion based on planetary boundary layer turbulence structure and 

scaling concepts, and AERMAP, a terrain data preprocessor that incorporates complex 

terrain using United States Geological Survey (USGS) Digital Elevation Data. 

Additionally, Ohio EPA utilized the AERMINUTE module to incorporate 1-minute ASOS 

meteorological data into the hourly surface input file. Ohio EPA utilized the most up-todate versions of AERMOD and the associated preprocessors available at the time of the 

modeling analyses. These are as follows: AERMOD version 14134, AERMET version 

14134, AERMINUTE version 14237, and AERMAP version 11103.

The intent of this supplemental modeling is to demonstrate that the William H. Zimmer 

facility does not cause or contribute to an exceedance of the standard not only at the 

violating monitor, but across the entirety of the nonattainment area. For this purpose, 

Ohio EPA collected monitor data for the August 30, 2014 through February 28, 2015 

period, when the entirety of the Walter C. Beckjord facility is known to have zero 

emissions. Using this monitor data, Ohio EPA modeled all sources at the William H. 

Zimmer facility at 1 gram per second. Using the modeled impacts at receptors across 

the nonattainment area, as well as the location of the monitor, Ohio EPA scaled the 99th

percentile of monitor data for this period to represent a maximum predicted impacted in 

the nonattainment area as a whole. As described below, this modeling is conservative 

in its treatment of constant emissions, the assumption that a one-to-one ratio between 

monitored concentrations and impacts in the nonattainment area is present, and its 

consideration of only the spatial, and not temporal, relationship between monitor and 

modeled values.
 

Meteorological Data

In order to generate meteorological input data for use with AERMOD, AERMET, along 

with AERMINUTE and AERSURFACE preprocessing for the modeling domain was 

conducted to generate the surface (.sfc) and profile (.pfl). Ohio EPA used the 

AERMINUTE pre-processing module. This module accepts as input 1-minute ASOS 

meteorological surface observations, calculates an hourly average for each hour in the 

modeled time period, and substitutes any missing values from the co-located ISHD 

surface data. Use of AERMINUTE reduces the number of calm hours present in the 

input files, and these enhanced hourly files are therefore considered more 

representative of local meteorological conditions. 

Meteorological data from August 30, 2014 through February 28, 2015 from the 

Cincinnati, OH surface station (Station # 93814) located at the Covington/Greater 

Cincinnati Airport in Kentucky and the Wilmington, OH upper air station (Station # 

13841) located at the Wilmington Airborne Park airport were used in these analyses. 

These sites were determined to be representative of the nonattainment area. 

AERSURFACE was run using twelve sectors and four seasons for the surface station 

location.

Emission Sources

Three emission sources (two egress points) from William H. Zimmer were included in 

the modeling analysis. The relevant release point parameters for the two egress points 

included in the analysis are presented in Table 1, below. As described previously, the 

emission rate of all units was set to 1 gram/second to allow for a straightforward scaling 

of modeled values to monitored concentrations. All emissions sources included in the 

modeling analysis were treated as point sources.

Source 

ID Source Description

Easting 

(X)

Northing 

(Y)

Base 

Elevation

Stack 

Height Temperature

Exit 

Velocity

Stack 

Diameter SO2

(m) (m) (m) (m) (K) (m/s) (m) (g/s)

B006_ZM Main Boiler Unit 1 Stack 740462.3 4305892 155.4 174 328 16.971 12.8 1

AUX_AB Aux Blr AB Comn Stack 740391.7 4305630 155.3 91 604 26.3 3.35 1

Table 1: Modeled SO2 emission sources, William H. Zimmer.

Receptors

A receptor grid of 1000 meter spacing was placed within the boundaries of the 

nonattainment area. Initial screening-level modeling indicated that the maximum impact 

of William H. Zimmer occurs within approximately 1 km of the facility. The center of the 

nonattainment area itself is located approximately 20 km (11.5 km at the closest point)

from the William H. Zimmer emission units, and as such, a fine receptor grid was 

deemed unnecessary to capture significant concentration gradients. Limiting the 

number of receptors was also necessary to maintain reasonable file sizes to conduct 
post-processing and analysis of modeled outputs. In addition to this grid, a single 

receptor was placed in the monitor location. A second modeling grid, using 50 meter 

spacing to 3 km, was performed to determine the location of Zimmer’s maximum 

impact. This finer grid was placed based on screening level modeling analysis.

Results

As stated previously, the modeling analysis was conducted to determine the location of 

maximum impact from emissions originating from the William H. Zimmer facility and to 

conservatively demonstrate, using monitored values, that emissions from William H. 

Zimmer will not cause an exceedance of the standard anywhere within the 

nonattainment area. The 2

nd highest modeled maximum daily value for the time period 

(99th percentile) at the receptor representing the monitor was 0.18731 g/m3. Ohio EPA 

determined that the 2

nd highest maximum modeled value across all receptors in the 

nonattainment area was 0.40866 g/m3, and used this value for the extrapolation 

analysis.

To extrapolate these values based on monitor data, Ohio EPA determined that the 2nd

highest maximum daily value recorded during the August 30, 2014 to February 28, 2015 

period to be 24 ppb. Using the modeled impacts above, Ohio EPA used a simple ratio

to scale this value to the point of maximum impact in the nonattainment area, as follows:

0.18731

24 ppb =

0.40866

X

Using the 2nd highest maximum daily value across all receptors in the nonattainment 

area, 0.40866 g/m3, in the ratio above yields a maximum concentration of 52.4 ppb. 

The conservatively extrapolated value is below the standard.

Ohio EPA considers this demonstration highly conservative for several reasons. Firstly, 

the modeling assumed continuous operation of all units at the William H. Zimmer facility, 

which is not reflective of normal operating conditions, in particular the two auxiliary 

boilers. These units operated only 676 hours in 2013 and 1,167 hours in 2014.

Secondly, the extrapolation implicitly assumes that all ambient SO2 recorded at the 

monitor location originates from William H. Zimmer. Lastly, the temporal relationship 

between the monitor data and modeled data was not considered. By accounting only for 

the spatial relationship between modeled and monitor values, the extrapolation 

assumes that the 99th percentile impacts occur simultaneously across the entirety of 

nonattainment area, including at the monitor location. This provides an additional layer 

of conservatism to the analysis. When modeled values and monitor values are paired in 

time, the first-highest maximum extrapolated impact was determined to be 30 ppb.

An additional extrapolation of modeled impacts was performed based on actual 

emissions data from the William H. Zimmer facility. The highest annual emissions from

years 2010-2014 occurred in 2010, when the William H. Zimmer facility emitted 

19,388.1 tons of SO2. This annual emission rate was converted to an average emission 
rate of 557.73 grams/second. Using this value, and the results of the extrapolation 

demonstration above, Ohio EPA used the following ratio to estimate the impacts of 

emissions from the William H. Zimmer plant at both the receptor location and at the 

point of highest impact in the nonattainment area:

2 grams/second

0.40866 ug/m3

=

557.73 grams/second

X ug/m3

The solution to this equation, 113.96 g/m3(43.56 ppb) is well below the standard of 75 

ppb and indicates that emissions from the William H. Zimmer facility are unlikely to 

cause an exceedance of the standard across the entirety of the nonattainment area. 

Substituting the modeled results at the monitor location, 0.18731 g/m3, into the above 

ratio yields an estimated impact of 52.23 g/m3(19.96 ppb). This extrapolation is 

remarkable in its consistency with the monitor data for periods when the Walter C. 

Beckjord facility was not operational and with the previous extrapolation based on 

monitor data. These results, as well as the consistency of these analyses with monitor 

values, provide strong additional support for Ohio EPA’s contention that the closure of 

the Walter C. Beckjord facility will provide for attainment of the standard in the entirety 

of the nonattainment area and that emissions from William H. Zimmer will not cause or 

contribute to an exceedance of the standard.

Analysis of wind rose data from the Covington/Greater Cincinnati Airport for the first 

highest and second highest maximum daily concentrations recorded at the monitor

during the August 30, 2014 through February 28, 2015 period support the conclusion 

that the analysis conducted by Ohio EPA is highly conservative and indicates that 

emissions from William H. Zimmer are not contributing to elevated monitor readings. 

The first highest maximum daily value recorded during this period was 34 ppb, occurring 

on January 14, 2015 at 9:00 AM. Monitor values remained elevated until 12:00 PM on 

the same day. The second highest maximum daily value of 24 ppb occurred on 

January 6, 2015 at 7:00 PM. Concentrations recorded at the monitor were elevated 

from January 6, 2015 at 5:00 AM until 12:00 AM on January 7, 2015. The wind roses 

for these periods are shown in Figure 2, below.
Figure 2: KCVG wind roses, January 6 and January 14, 2015.
The data shown in Figure 2 indicates that winds were primarily from the West and 

Northwest during the times when the highest and second highest monitored values 

were recorded. This suggests that emissions from William H. Zimmer were not 

impacting the monitor, or the nonattainment area, during these times. An analysis of 

hourly emissions, monitor values, and wind directions, presented in Appendix K of this 

redesignation submittal confirms that when emissions from the Walter C. Beckjord 

facility are eliminated from analysis, the wind directions primarily impacting the monitor 

are from the West and Northwest, and that at no time when the Walter C. Beckjord 

facility was not operating was an hourly monitor value above 34 ppb recorded. Thus, 

the extrapolation analysis performed based on modeled impacts represents a highly 

conservative estimate of the impact of emissions from William H. Zimmer on both the 

monitor and the nonattainment area as a whole. Further, Ohio EPA determined that 

point of maximum impact of emissions from Zimmer during the modeled time period 

was located approximately 1.4 km to the southeast from the largest source at the 

William H. Zimmer facility. From the point of this maximum impact to the point of 

maximum impact within the nonattainment area, there is a decrease in concentration of 

84%. 

These analyses, as well as the analysis presented in Appendix K, further support the 

results of the trajectory analysis presented in Appendix D, and demonstrate that the 

impacts of Zimmer are minimal at both the monitor location and the entirety of the 

nonattainment area. These results are consistent with the predominant winds in the 

area, which originate primarily from the south and southwest. Additional wind rose data 

is presented in Appendix K. 
APPENDIX K
Appendix K

Analysis of Monitored Concentrations and Wind Direction

Introduction

This document supports the redesignation request for the Campbell-Clermont partial 

nonattainment area in the State of Ohio and the Commonwealth of Kentucky. This 

nonattainment area encompasses emissions from the Walter C. Beckjord facility. There 

are no other significant sources of SO2 emissions within the nonattainment area that 

warrant inclusion in the modeling analysis. As can be seen from the inventory included 

in the redesignation request, the SO2 emissions from the point sources comprise 

99.95% of the 2014 SO2 emissions in the entire nonattainment area. Notably, violations 

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

facility located along the Ohio River in Ohio east of the monitor. On September 1, 

20141, the Walter C. Beckjord facility ceased operations. Ohio EPA was notified of the 

permanent shutdown on October 14, 2014. (Appendix B and I of the redesignation 

request) There are no other significant point sources of SO2 emissions located in the 

nonattainment area. Within the portion of Campbell County, KY that is a part of this area 

there are 11 sources which combined emit less than one ton per year (tpy) of SO2. 

(Appendix C of the redesignation request) There are no other point sources of SO2

emissions in the portion of Clermont County, OH that is a part of this area. 

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

is the William H. Zimmer facility (see Figure 1). It was determined during the 

nonattainment designation process that emissions from the William H. Zimmer facility 

likely do not impact the violating monitor at question, and therefore, the nonattainment 

area was not expanded to encompass this facility. To support the previous conclusion, 

Ohio EPA performed an extensive meteorology, emissions and back-trajectory analysis 

and has included this analysis as Appendix D of the redesignation request. This 

analysis concludes that it was in fact the Walter C. Beckjord facility that caused the 

violations and not the William H. Zimmer facility.

In support of this conclusion, Ohio EPA conducted an analysis of hourly SO2

concentrations recorded at monitor 21-037-3002, wind direction data from the Cincinnati 

weather station located at the Cincinnati Northern Kentucky Airport, and emissions from 

both the Walter C. Beckjord and William H. Zimmer facilities for years 2012 through 

February 28, 2015. This time period is henceforth referred to as the study period. The 

analysis presented in this document further demonstrates that emissions from William 

H. Zimmer and other sources within and outside of the nonattainment area are not likely 

to cause exceedances both at the monitor and in the entirety of the nonattainment area 

 

1

The letter contained in Appendix B identifies the permanent shutdown of all units occurred on October 1, 

2014. However, a review of CAMD emissions showed that all the units ceased operation by September 

1, 2014.
and that the shutdown of the Walter C. Beckjord facility will result in attainment of the 

standard.

Methodology

Hourly SO2 emissions data from the Walter C. Beckjord and William H. Zimmer facilities 

were collected from the U.S. EPA Clean Air Markets Database for the study period. 

Hourly and one-minute wind data were collected from the National Weather Service 

station located at the Cincinnati Northern Kentucky Airport. To ensure that the most 

complete meteorological record possible was used, Ohio EPA processed the hourly 

meteorological data and one-minute ASOS data using the most recent versions of the 

AERMOD preprocessors AERMET and AERMINUTE. In addition to eliminating missing 

periods in the meteorological data, this processing provided hourly outputs that were 

more easily paired with hourly emission and monitor data. Hourly monitoring data for 

monitor 21-037-3002 were obtained from U.S. EPA’s Air Quality System.

After compiling the above hourly data, Ohio EPA binned all data based on wind 

direction data, in ten degree increments. This was done for the entirety of the study 

period. The same binning of the data by wind direction was also done for only those 

periods in which the Walter C. Beckjord facility had zero SO2 emissions. This yielded a 

substantial dataset of 10,231 hours monitoring data not impacted by emissions from the 

Walter C. Beckjord facility. It should be noted, however, that no accounting for any 

temporal overlap between any hour of zero emissions from the Walter C. Beckjord 

facility and monitor values was performed. Thus, it is likely that this dataset represents 

some impacts from Walter C. Beckjord at the monitor location. Ohio EPA believes that 

by not accounting for this overlap, any subsequent analysis of this dataset will be 

conservative.

Within each of the above datasets, Ohio EPA determined for each wind direction bin the 

highest and second-highest monitored concentration, the percentage each wind 

direction bin represents to the total, and the number and percentage of monitor values 

of 0 ppb. 

Analysis and Results

To determine the primary wind directions in which monitored concentrations are 

elevated, Ohio EPA evaluated those bins for which either the first or second highest 

monitored value represented an exceedance of the standard. Further, Ohio EPA 

included in its evaluation any bin for which the sum of the first and second highest 

monitored values within that bin exceeded the average plus the sample standard 

deviation of this value, across all bins. For the full study period, which includes impacts 

from the Walter C. Beckjord facility, Ohio EPA determined that winds originating from 

between 31° and 140° and from between 151° and 170° had the greatest impact on 

monitor concentrations. The results of this analysis are consistent with those presented 

in Appendix D of the redesignation request. The maximum concentration recorded at 

the monitor during the study period, 156 ppb, was the result of winds originating 

between 121° and 130°. This result is again consistent with the results presented in 
Appendix D of the redesignation request, which details this exceedance as the February 

20, 2012 exceedance, and is attributed to emissions from the Walter C. Beckjord facility. 

The same binning analysis described above was performed for the dataset compiled 

from hours in which emissions from the Walter C. Beckjord facility were zero. It should 

be noted that this data set of 10,231 hours encompasses 1,445 hours of 2012, 2,542 

hours of 2013, 4,828 hours of 2014, and 1,416 hours of 2015. Additionally, no 

exceedances of the standard were monitored during these hours, and the highest 

maximum hourly concentration recorded during these hours was 34 ppb. Using the 

same procedure as described above, Ohio EPA determined that for this dataset, winds 

originating between 211° and 220°, as well as those originating between 251° and 300°

had the greatest impact on monitor concentrations. This represents a significant shift in 

impacting wind directions with respect to the results of the full study period. Further, 

these wind direction bins resulted in no exceedances at the monitor over the full 2012 to 

February 28, 2015 study period. Ohio EPA contends that this is strong evidence that 

the shutdown of the Walter C. Beckjord facility will result in the attainment of the 

standard both at the monitor and across the entirety of the nonattainment area. This is 

supported by the supplemental modeling and extrapolation analysis described in 

Appendix J of the redesignation request.

The shift in impacting wind directions observed between the datasets is significant, and 

warrants further analysis. Figure 1, below, shows the location of monitor 21-037-3002 

and facilities within a 50 km radius with SO2 emissions greater than or equal to 1,000 

TPY in 2014. 
Figure 1: Facilities within 50 km of monitor 21-037-3002 with 2014 emissions >1,000 tons SO2.

As stated above, Ohio EPA determined that for the dataset excluding periods when the 

Walter C. Beckjord facility was emitting SO2, winds originating between 211° and 220°, 

as well as those originating between 251° and 300° had the greatest impact on monitor 

concentrations. Figure 1 above suggests that these wind directions would bring 

emissions from the Miami Fort Station, 30.3 km away from the monitor, and from the 

Duke Energy Kentucky East Bend facility, located 35.3 km distant from the monitor. 

Given these large distances, Ohio EPA believes that the impact of these facilities will be 

relatively uniform across the nonattainment area. Dispersion screening tests for Miami 

Fort Station would suggest that over this distance, there would be an approximately 

86% decrease from the point of maximum concentration, located within approximately 1 

km of the facility, to a point 30 km distant, and an 89% decrease at 40 km. This 

indicates that there is little concentration gradient across the nonattainment area 

associated with sources located 30 to 35 km distant. Further, as demonstrated above, 

the highest concentration recorded at the monitor with winds originating from the above 

directions is 34 ppb. Ohio EPA believes that it is highly unlikely that a future 

exceedance of the standard will be observed at the monitor location due to emissions 

from these facilities, and given the significant distances between these facilities and the 

nonattainment area it is unlikely that a significant concentration gradient across the 

nonattainment area from these facilities is present. Additionally, Ohio EPA anticipates a 

further reduction in SO2 emissions from those facilities potentially impacting the monitor 

in the future.
In 2014, the facilities above emitted 78,349 tons of SO2. The shutdown of the Walter C. 

Beckjord facility, which Ohio EPA has demonstrated in detail is the primary cause of 

monitored exceedances, will result in a 32,603 ton decrease in SO2 emissions. Miami 

Fort Unit 6 (Ohio EPA unit ID B007), an uncontrolled unit, is shutdown as of June 1, 

2016 to comply with the Mercury and Air Toxics Standards. (Appendix L of the 

redesignation request) This will result in a further 18,796 ton reduction from 2014 

levels. In total, this represents a reduction in SO2 emissions of approximately 66% from 

2014 levels. As previously demonstrated, no hourly SO2 values were above the 

standard have been recorded when emissions from the Walter C. Beckjord facility are 

eliminated from analysis, and the highest recorded monitor value across this dataset is 

34 ppb. When this is considered in light of the substantial reduction in SO2 emissions in 

and around the nonattainment area, it is highly unlikely that an exceedance of the 

standard will be monitored in the future, nor is there likely to be a significant 

concentration gradient in the nonattainment area given the significant distances 

between SO2 emission sources and the nonattainment area.

Lastly, Ohio EPA compiled the first through 30th highest hourly monitored SO2

concentrations for all hours during the 2012-February 28, 2015 period for which SO2

emissions from the Walter C. Beckjord facility were zero. These data are presented in 

Table 1, below.

Monitor 21-037-3002

Date Hour Monitor Value (ppb)

January 14, 2015 10 34

September 2, 2013 7 29

January 14, 2015 9 26

January 6, 2015 19 24

September 4, 2013 17 20

January 14, 2015 11 20

May 17, 2013 12 19

August 22, 2014 11 19

January 8, 2015 1 19

September 22, 2012 9 18

September 2, 2014 17 18

January 5, 2015 9 18

January 6, 2015 21 18

September 2, 2013 6 17

January 6, 2015 18 17

August 27, 2014 15 15

January 9, 2015 22 15

January 6, 2015 17 14

January 6, 2015 20 14

January 9, 2015 21 14

September 30, 2012 10 13
May 17, 2013 11 13

November 12, 2014 16 13

January 5, 2015 13 13

January 22, 2015 16 13

September 14, 2012 11 12

October 9, 2013 10 12

October 28, 2014 15 12

September 30, 2012 11 11

May 25, 2013 11 11

Table 1: Highest hourly monitored SO2 concentrations, 2012-February 28, 2015, monitor 21-037-

3002, Walter C. Beckjord impacts removed.

To maintain conservatism, Ohio EPA eliminated monitor values of zero from the 

percentile calculation, giving a total of 2,939 non-zero monitor values for which SO2

emissions from the Walter C. Beckjord facility were zero. Thus, the 99th percentile value 

of these data is the 29th highest hourly value. This value, 11 ppb, was recorded on 

September 30, 2012 and is highlighted in Table 1, above.

Ohio EPA has demonstrated that a significant shift in wind directions which impact 

monitor 21-037-3002 are observed when emissions from the Walter C. Beckjord facility 

are eliminated from hourly wind and monitor data. From amongst this dataset, the 

highest monitor value recorded was 34 ppb, and the 99th percentile of the non-zero 

values is 11 ppb. Further, those sources impacting the monitor in the absence of 

emissions from the Walter C. Beckjord facility are located 30 to 35 km distant from the 

monitor and are therefore unlikely to cause a significant concentration gradient across 

the nonattainment area. Thus, monitor values are considered representative of ambient 

SO2 concentrations across the entire nonattainment area. Additionally, a significant 

reduction in SO2 emissions is anticipated for those sources in and around the 

nonattainment area. Taken together, Ohio EPA contends that the monitor is 

representative of the nonattainment area, that the shutdown of the Walter C. Beckjord 

facility will bring the monitor and nonattainment area into attainment of the standard, 

and that no hourly monitored value for the January 1, 2012 to February 28, 2015 study 

period associated with periods of zero emissions from the Walter C. Beckjord was 

above the standard. 

 
APPENDIX L
Dvnegy Resour.ce , IL!LC 

1500 Eastport Plaza Drive 

Collinsville, Illinois 62234 

June 11, 2015 

Mr. Christopher Beekman 

Ohio Environmental Protection Agency 

Division of Air Pollution Control 

P.O. Box 1049 

Columbus, Oh 43216-1049 

Re: Miami Fort Power Station, ID No. 1431350093 

MATS Rule Compliance Extension for Unit 6- Final Quarterly Status Update 

Dear Mr. Beekman: 

On December 12, 2013, Ohio EPA's Division of Air Pollution Control (DAPC) approved a 

request by Duke Energy Kentucky (DEK) to extend the Mercury and Air Taxies (MATS) Rule 

compliance date for Unit 6 at Miami Fort Power Station by 47 days, to June 1, 2015. DAPC's 

approval directed DEK to submit quarterly status update reports regarding this extension within 

15 days after the end of calendar quarters. 

Though DEK remains the owner of Miami Fort Unit 6, responsibility for its operation shifted from 

Duke Energy to Dynegy on April 2, 2015. This final quarterly status update report is provided by 

Dynegy. 

During the second quarter of 2015, DEK continued to include Miami Fort Unit 6 as an eligible 

resource in its Fixed Resource Requirement (FRR) plan to meet its FRR capacity obligation, 

and offered it on a day-ahead basis into the PJM energy market until May 31, 2015. 

Consistent with the terms of DAPC's compliance extension, operation of Miami Fort Unit 6 has 

ceased, effective June 1, 2015. 

Please contact me at 513-467-5885 (Chris.Osterbrink@Dynegy.com) or Larry Waite at 618-343-

7828 (Larry.Waite@Dynegy.com) with any questions regarding this report. 

Sincerely, 

1CJ:�,u-� 

Chris Osterbrink 

Managing Director, Plant Operations 

Miami Fort Power Station 

cc: Robert Hodanbosi, Ohio EPA, DAPC, Central Office 

Brad Miller, Southwest Ohio Air Quality Agency 

J. Michael Geers, Duke Energy