Page 1 of 31 

## Louisville , Kentucky

- Indiana Area Designations for the 2012 Primary Annual PM 2.5 

## National Ambient Air Quality Standard s

Technical Support Document

1.0 Summary

In accordance with s ection 107(d) of the Clean Air Act (CAA), the EPA must promulgate designations for all areas of the country. In particular, the EPA must identify those areas that are violating a National Ambient Air Quality Standard ( NAAQS ) or contributing to a violati on of the NAAQS in a nearby area. The EPA must complete this process within 2 years of promulgating a new or revised NAAQS, or may do so within 3 years under circumstances not relevant to these designations. 1 This technical support document (TSD) describes th e EPA’s decision to designate areas in Kentucky and Indiana as nonattainment for the 2012 primary annual fine particle NAAQS (2012 annual PM 2.5 NAAQS). 2

Consistent with section 107(d), states were required to submit area designation recommendations to the EPA for
the 2012 annual PM 2.5 NAAQS no later than 1 year following promulgation of the standard, or by December 13,
2013. In December 2013

, Kentucky recommended that all counties in the Commonwealth be designated as
attainment or attainment/unclassifiable

. Additionally, in December 2013 , Indiana recommended that all monitored counties in Indiana be designated attainment and all remaining counties be designated as unclassifiable

. After considering these recommendations and based on the EPA’s technical analysis as described in this TSD, the EPA is designat ing the areas listed in Table 1 as no n attain ment for the 2012 annual PM 2.5 NAAQS

. The EPA must designate an area nonattainment if it has an air quality monitor ing site 3 that is violating
the standard or if it has sources of emissions that are contributing to a violation of the NAAQS in a nearby area. Legal descriptions (e.g., county boundaries, townships and ranges) of these areas are found below in the supporting technical analysis for e ach area. As provided in CAA section 188(a), the EPA is initially classify ing
all nonattainment areas as “Moderate” nonattainment areas.

1 Section 107(d) of th e CAA requires the EPA to complete the initial designation process within 2 years of promulgation of a new or revised NAAQS

, unless the Administrator has insufficient information to make initial designation decisions in the
2

- year time frame. In such circumstances

, the EPA may take up to 1 additional year to make initial area designation decisions (i.e., no later than 3 years after promulgation of the standard)

.

2 On December 14, 2012, the EPA promulgated a revised primary annual PM 2.5 NAAQS (78 FR 3086, January 15, 2013). In that action, the EPA revised the primary annua l PM 2.5 standard, strengthening it from 15.0 micrograms per cubic meter (μg/m 3 ) to 12.0 μg/m 3

.

3 In accordance with 40 CFR 50 Appendix N, PM 2.5 measurements from the primary monitor and suitable collocated PM 2.5 F ederal R eference M ethod (FRM)

, Federal Equ ivalent Method (FEM) or Approved Regional Methods (ARM) may be used in a “combined site data record” to establish a PM 2.5 design value to determine whether the NAAQS is met or not met at a particular PM 2.5 monitoring site.Page 2 of 31

Table 1

. Kentucky

- Indiana Recommended Nonattainment Areas and the EPA’s Final Designated
Nonattainment Areas for the 2012 A nnual PM 2.5 NAAQS

Area States ’ Recommended

Nonattainment Counties The EPA’s Final Designated Nonattainment Counties

Louisville ( KY side) None Jefferson Bullitt (partial)

Louisville (IN side) None Clark Floyd

In its recommendation letter, Kentucky recommended that the EPA designate as “ attainment” or “unclassifiable/attainment” all counties of the Commonwealth. With the exception of a portion of Bullitt County, and the entire ty of Jefferson Count y in Kentucky, a s identified in Table 1, and the counties in the Cincinnati Area, the EPA agrees with Commonwealth ’s recommendation and is designat ing the remainder of Kentucky as unclassifiable/attainment . This designation is based on the Commonwealth ’s recommendation,

ambient monitoring data collected during the 2011

- 2013 period showing compliance with the 2012 annual

PM 2.5 NAAQS, and Kentucky ’s determination/assessment that areas within the Commonwealth are not likely contributing to nearby violations

. 4

, 5

In its recomm endation letter, Indiana recommended that the EPA designate as “ attainment” or “unclassifiable/attainment” all counties in Indiana. With the exception of Clark and Floyd C ounties, a s identified in Table 1, the EPA agrees with Indiana’s recommendation and is designat ing the remainder of
Indiana as unclassifiable/attainment based on the S tate ’ s recommendation, ambient monitoring data collected during the 2011

- 2013 period showing compliance with the 2012 annual PM 2.5 NAAQS, and the

4 Unless a state or tribe has specifically identified jurisdictional boundaries in their area recommendations, when determining “remainder of the state,” The EPA will use Federal Information Processing Standard (FIPS) codes maintained by the National Instit ute of Standards and Technology (NIST), which are used to identify counties and county equivalents (e.g., parishes, boroughs) of the United States an d its unincorporated territories (e.g., American Samoa, Guam, Northern Mariana Islands, Puerto Rico, and th e US Virgin Islands) . Available on the EPA’s Envirofacts website at http://www.epa.gov/envirofw/html/codes/state.html

.

5 The EPA uses a designation category of "unclassifiable/ attainment" for areas that are monitoring attainment and for areas that do not have monitor ing sites but w hich the EPA believe s are likely attainment and does not have emissions sources that are contributing to nearby violations based on the five factor analysis and o ther available information

.Page 3 of 31

Commonwealth ’s determinatio n/assessment that areas within the Commonwealth are not likely contributing to nearby vi olations. 6

, 7

2.0 Nonattainment Area Analyses and Final Boundary Determination

The EPA evaluate d and determined the final boundaries for each nonattainment area on a case

- by

- case basis considering the specific facts and circumstances unique to the area. In accordance with the CAA section 107(d),
the EPA is designat ing as nonattainment not only the area with the monitoring sit e s that violate t he 2012 annual

PM 2.5 NAAQS, but also those nearby areas with emissions sources that contribute to the violation in the
nonattainment area . As described in the EPA guidance

, 8 after identifying each monitor ing site indicat ing a violation of the standard in an area, the EPA analyzed those areas with emissions contribut ing to that violating area by considering those counties in the entire metropolitan area (e.g., Core Based Statistical Area (CBSA) or Combined Statistical Area (C SA)) in which the violating monitor ing site is located. The EPA also evaluate d
counties adjacent to the CBSA or CSA that have emissions sources with the potential to contribute to the
violation

. The EPA uses the CBSA or CSA as a starting point for the cont ribution analysis because those areas are nearby for purposes of the PM 2.5 NAAQS. Based upon relevant facts and circumstances in each area, the designated nonattainment area could be larger or smaller tha n the CBSA or CSA. The EPA’s analytical approach is described in section 3 of this TSD

.

3.0 Technical Analysis

In this technical analysis, the EPA us ed the latest data and information available to the EPA (and to the states and tribes through the PM 2.5 Designations Mapping Tool 9 and the EPA PM Designations Guidance and Data web page 10 ) and/or data provided to the EPA by states or tribes. This technical analysis identifies the area s with
monitor ing site s that violate the 2012 annual PM 2.5 NAAQS

. The EPA evaluated these area s and o ther nearby

areas with emissions sources or activities that potentially contribute to ambient fine particle concentrations at the violating monitor s in the area based on the weight of evidence of the five factors recommended in the EPA guidance and any oth er relevant information.

6 Unless a state or tribe has specifically identified jurisdictional boundaries in their area recommendations, when determining “remainder of the state,” EPA will use FIPS codes maintained by the NIST, which are used to identif y counties and county equivalents (e.g., parishes, boroughs) of the United States an d its unincorporated territories (e.g., American Samoa, Guam, Northern Mariana Islands, Puerto Rico, and the US Virgin Islands) . Available on the EPA’s Envirofacts website at http://www.epa.gov/envirofw/html/codes/state.html

.

7 The EPA uses a designation category of “ unclassifiable/ attainment ” for areas that are monitoring attainment and for areas that do no t have monitor ing sites but w hich the EPA believe s are likely attainment and does have not emissions sources that are contributing to nearby violations based on the five factor analysis and other available information

.

8 The EPA issued guidance on April 16, 2013, that identified important factors that the EPA intended to evaluate, in making a recommendation for area designations and nonattainment boundaries for the 2012 annual PM 2.5 NAAQS. Available at http://www.epa.gov/pmdesignations/2012standards/docs/april2013guidance.pdf

.

9 The EPA’s PM 2.5 Designations Mapping Too l can be found at http://geoplatform2.epa.gov/PM_MAP/index.html

.

10 The EPA’s PM Designations Guidance and Data web page can be found at http://www.epa.gov/pmdesignations/2012standards/techinfo.htm

.Page 4 of 31

These five factors are:

Factor 1: Air Quality Data

. The air quality data analysis involve s examining available ambient PM 2.5 air quality monitoring data at, and in the proximity of, the violating monitoring locations. This include s reviewing the design value s (DV) calculated for each monitoring location in the area based on air quality data for the most recent complete 3 consecutive calendar years of quality

- assured, certified air quality data in the EPA’s Air Quality System (AQS). In general, the EPA identifies violations using data from suitable FRM, FEM, and/or ARM monitors sited and operated in accordance with 40 CFR Part 58. 11 Procedures for using the air quality
data to determine whether a violation ha s occurred are given in 40 CFR p art 50 Appendix N, as revised by a final action published in the Federal Register on January 15, 2013 (78 FR 3086). 12 In addition to reviewing data from violating monitor sites

, the EPA also assesses the air quality data from other monitoring locations to help ascertain the potential contribution of sources in areas near by to the violating monitor ing site . Examples include using chemical speciation data to help characterize contributing emissions sources and the determination of nearby contributions through analyses that differentiate local and regional source contributions.

Factor 2: Emissions and emissions

- related data

. The emissions analysis examine s identified sources of direct

PM 2.5 , the major components of direct PM 2.5 , e.g., primary organic ca rbon (POC) and PM 2.5 organic mass ( P OM) , elemental carbon (EC) , crustal material (and/or individual trace metal compounds)), primary nitrate and primary sulfate, and precursor gaseous pollutants (e.g., sulfur dioxide ( SO 2 ), nitrogen oxides ( NO x) , total
vola tile organic compounds ( VOC ) , and ammonia ( NH 3 ). Emissions data are generally derived from the most recent National Emissions Inventory (NEI) (i.e., 2011 NEI version 1 ) , and are given in tons per year. In some cases, the EPA may also evaluate emissions information from states, tribes, or other relevant sources that may not be reflected in the NEI. One example of “other information” could include an inventory or assessment of local/regional area sources that individually does not meet the current threshold for reporting to the NEI but collectively contributes to area PM 2.5 concentrations. Emissions data indicate the potential for a source to contribute to observed violations, making it useful in assessing boundaries of nonattainment areas.

Factor 3: Meteorology

. E valuatin g meteorological data help s to determine the effect on the fate and transport of emissions contributing to PM 2.5 concentrations and to identify areas potentially contributing to the violat ions at
monitor ing sites . The Factor 3 analysis include s assessing potential source

- receptor relationships in the area identified for evaluation using summaries of air trajectories, wind speed, wind direction

, and other meteorological data

, as available

.
Factor 4: Geography/topography . The geography/topography analysis include s examin ing the physical features of the land that might define the airshed and, therefore, affect the formation and distribution of PM 2.5 over an area. Mountains or other physical fe atures may influence the fate and transport of emissions and PM 2.5

11 Suitable monitors include all FEM and / or ARMs except those specific continuous FEMs / ARMs used in the monitoring agency's network where the data are not of sufficient quality such that data ar e not to be compared to the NAAQS in accordance with 40 CFR part 58.10(b)(13) and approved by the EPA Regional Administrator per 40 CFR part 58.11(e).

12 As indicated in Appendix N to 40 CFR part 50, Interpretation of the National Ambient Air Quality Stand ards for PM 2.5 , section 3(a) indicates “Except as otherwise provided in this appendix, all valid FRM/FEM/ARM PM 2.5 mass concentration data produced by suitable monitors that are required to be submitted to AQS, or otherwise available to EPA, meeting the requirements of part 58 of this chapter including appendices A, C, and E shall be used in the DV (design value) calc ulations. Generally, EPA will only use such data if they have been certified by the reporting organization (as prescribed by § 58.15 of this chapter); however, data not certified by the reporting organization can nevertheless be used, if the deadline for c ertification has passed and EPA judges the data to be complete and accurate.”Page 5 of 31

concentrations. Additional analyses may consider topographical features that cause local stagnation episodes via inversions, such as valley

- type features that effectively “trap” air polluti on, leading to periods of elevated PM 2.5 concentrations.

Factor 5: Jurisdictional boundaries . The analysis of jurisd ictional boundaries identifie s the governmental planning and organizational stru cture of an area that may be relevant for designations purposes. These jurisdictional boundaries provide insight into how the governing air agencies conduct or might conduct air quality planning and enforcement in a potential nonattainment area. Examples of jurisdictional boundaries include counties, air districts, areas of Indian country, CBSA or CSA, metropolitan planning organizations, and existing nonattainment areas.

3.1 Area Background and Overview for the Louisville, Kentucky

- Indiana Area

Figure 1 is a map of the EPA’s final nonattainment boundary for the Louisville CBSA . The map shows the location and design values of ambient air quality monitor ing locations , county and other jurisdictional
boundaries

.

Counties in the Louisville, KY

- IN Area include: Bullitt, Henr y, Jefferson, Meade, Nelson, Oldham, Shelby, Spencer and Trimble counties in Kentucky, and Clark, Floyd, Harrison and Washington counties in Indiana. For purposes of the 1997 annual PM 2.5 NAAQS, portions of this area were designated nonattainment. The boun dary
for the nonattainment area for the 1997 annual PM 2.5 NAAQS included the entire counties of Jefferson and Bullitt in Kentucky ; and Clark, Floyd and a portion of Jefferson counties in Indiana

. For this area, the
boundaries for the 1997 annual PM 2.5 NAAQS and the 2012 annual PM 2.5 NAAQS differs, in that a portion of
Bullitt , Kentucky and a portion of Jefferson County, Indiana are not included in the 2012 annual PM 2.5 NAAQS area boundary.Page 6 of 31

Figure 1. The EPA’s Final Nonattainment Boundaries for the Louisville , K entuc k y - I ndiana Area

The EPA must designate as nonattainment areas that violate the NAAQS and nearby areas that contribute to the
violation. Clark County

, I ndiana shows a violation of the 2012 PM 2.5 NAAQS, therefore this c ounty is included
in the nonattainment area. The EPA evaluated each county without a violating monitor ing site located near the county with a violating monitor ing site based on the five factors and other relevant information and determine d
that Floyd County, Indiana, and Jefferson County and the urbanized portion of Bullitt County in Kentucky contribute to the nearby violation. Data in the Jefferson County, Kentucky portion of this area is invalid because of significant problems with the collection and analysis of PM 2.5 filter

- based samples. EPA and Kentucky audits of the Louisville (Jefferson County) air quality agency found systemic issues with PM 2.5 lab operations, data handling, record keeping, and quality assurance . However, the EPA evaluated Jefferson County based on the five factors, and on this basis determined that the county contributes to the violation at the Clark County

, Indiana monitor

. The following sections describe this five factor analysis process. While the factors a re presented individually, they are not independent. The five factor analysis process carefully considers their
interconnections and the dependence of each factor on one or more of the others.Page 7 of 31

Factor 1: Air Quality Data

All data collected during the year are important when determining contributions to an annual standard such as
the 2012 annual PM 2.5 NAAQS. Compliance with an annual NAAQS is dependent upon monitor readings throughout the year, including days with monitored ambient concentrations below the level of the NAAQS. For
the 2012 annual PM 2.5 NAAQS , the annual mean is calculated as the mean of quarterly means. A high quarter can drive the mean for an entire year, which, in turn, can drive an elevated 3

- year DV. Although all data are important , seaso nal or episodic emissions can provide insight as to relative contributors to measured PM 2.5 concentrations. For these reasons, for the Factor 1 a ir q uality analysis, the EPA assesse d and characterize d air quality at, and in the proximity of, the violating monitor ing site locations first, by evaluating trends and the spatial extent of measured concentrations at monitors in the area of analysis, and then, by identifying the conditions most associated with high average concentration levels of PM 2.5 mass in the area of analysis.

In most cases, the EPA assessed air quality data on a seasonal, or quarterly, basis

. 13 The EPA also identifie d the spatial extent of these high PM 2.5 concentrations

. The mass and composition at the design value location represents contri butions from various emission sources including local, area

- wide (which may comprise nearby urban and rural areas) and regional sources. To determine the source mix (by mass) at the design value monitoring site, the EPA examined the chemical composition of the monitored PM 2.5 concentrations by pairing each violating FRM/FEM/ARM monitoring site with a collocated or nearby Chemical Speciation Network (CSN) monitoring site or sites . Then, the EPA contrasted the approximated mass composition at the design
value monitoring site with data collected at IMPROVE 14 and other monitoring locations whose data are representative o f regional background. This comparison of local / area

- wide chemical composition data to regional chemical composition data derives an “ urban increment, ” 15

, 16 which helps differentiate the influence of

13 Although compliance with the annual NAAQS depends on contributions from all days of the year, examin ing data on a quarterly or seasonal basis can inform the relationship betwe en the temporal variability of emissions and mete o rology and the resulting PM 2.5 mass and composition . In some areas of the country where there may be noticeable month

- to

- month variations in average PM 2.5 , the quarterly averages may not adequately represen t seasonal variability. In these areas, air quality data may be aggregated and presented by those months that best correspond to the local “seasons” in these areas.

14 IMPROVE stands for Interagency Monitoring for Protected Visual Environments and is an a erosol monitoring network in mostly rural and remote areas.

15 The “urban increment” analysis assesses and characterizes the increase in seasonal and annual average PM 2.5 mass and chemical constituents observed at violating monitoring site(s) relative to m onitoring sites outside the area of analysis (which represent background concentrations). Developing the urban increment involves pairing a violating FRM/FEM/ARM monitor with a collocated monitor or nearby monitor with speciation data. The EPA made every e ffort to pair these data to represent the same temporal and spatial scales. However, in some cases, the paired violating and CSN “urban” monitoring locations were separated by some distance such that the included urban CSN site(s) reflect(s) a
different mi xture of emissions sources, which could lead to misinterpretations. To generally account for differences in
PM 2.5 mass between the violating site and the nearby CSN site(s), the EPA determined material balance of the PM 2.5 composition at the violating site by assigning the extra measured PM 2.5 mass to the carbon components of PM 2.5 . Where the general urban increment approach may be misleading, or in situations where non

- carbonaceous emissions are believed to be responsible for a local PM 2.5 concentration gr adient, the EPA used alternative analyses to reflect the mix of urban and rural sources contributing to the measured concentrations at violating monitoring sites.

16 The urban monitors were paired with any rural sites within a 150 mile radius of an urban site to calculate spatial means of the quarterly averages of each species. If there were no rural sites within 150 miles, then the nearest rural site was use dPage 8 of 31

more distant emissions sources from the influence of closer emissions sources

, thus representing the portion of the measured violation that is associated with nearby emission contributions. 17

, 18

, 19

P M 2.5 Design Values and Total Mass Measurements

– The EPA examin ed ambient PM 2.5 air quality monitoring data represented by the DV s at the violating monitoring site and at other monitors in the area of analysis

. The
EPA calculate d DVs based on air quality data for the most recent 3 consecutive calendar years of quality

assured, certified air quality data from suitable FEM/FRM/ARM monitor ing sites in the EPA’s AQS. For this designations analysis, the EPA used data for the 201 1

- 201 3 peri od (i.e., the 201 3 design value), which are the most recent years with fully

- certified air quality data. A monitor’s DV is the metric or statistic that indicates whether that monitor attains a specified air quality standard. The 2012 annual PM 2.5 NAAQS is met at a
monitor ing site when the 3

- year average annual mean concentration is 12.0 (μg/m 3 ) or less (e.g., 12.1 μg/m 3 or greater is a violation)

. A DV is only valid if minimum data completeness criteria are met or when other regulatory data processing prov isions are satisfied (See 40 CFR part 50 Appendix N ) . Table 2 identifies the current design value (s) (i.e., the 201 3 DV ) and the most recent two design values based on all monitor ing s ites
in the area of analysis for the Louisville nonattainment area. 20

Table 2

. Air Quality Data C ollected at Regulatory Monitors (all DV levels in μg/m 3 ) a,b

County , State Monitor Site ID State Rec NA? 09

- 11 DV 10

- 12 DV 11

- 13 DV

Bullitt, KY 210290006 No Monitor shut down 2011

Clark, IN 180190006 No 13. 5 13. 2 12.1

Clark, IN 180190008 No 11.4 11.0 10.0
Floyd , IN 180431004 No 12.3 11.8 10.7

Jefferson, KY 211110043 No Invalid data (awaiting EPA decision)

Jefferson, KY 211110044 No Invalid data (awaiting EPA decision)

Jefferson, KY 211110051 No Invalid data (awaiting EPA decision)

alone. That rural mean was then subtracted from the quarterly mean of the urban site to get the i ncrement. Negative values were simply replaced with zeros.

17 In most, but not all, cases, the violating design value monitoring site is located in an urban area. Where the violating monitor is not located in an urban area, the “urban increment” represents the difference between local and other nearby emission sources in the vicinity of the violating monitoring location and more regional sources.

18 Hand, et. al. Spatial and Seasonal Patterns and Temporal Variability of Haze and its Constituents in the United States: Report V, June 2011. Chapter 7

– Urban Excess in PM 2.5 Speciated Aerosol Concentrations, http://vista.cira.colostate.edu/improve/Publications/Reports/2011/PDF/Chapter7.pdf

19 US EPA, Office of Air Quality Planning and Standards, December 2004. (2004) Area Designations for 1997 Fine Particl e (PM 2.5 ) Standards, Technical Support Document for State and Tribal Air Quality Fine Particle (PM 2.5 ) Designations, Chapter 3, Urban Excess Methodology. Available at www.epa.gov/pmdesignations/1997standards/documents/final/TSD/Ch3.pdf

20 In certain circumstances, one or more monitoring locations within a monitoring network may not meet the network technical requirements set forth in 40 CFR 58.11(e), which states, “ S tate and local governments must assess data from Class III PM 2.5 FEM and ARM monitors operated within their network using the performance criteria described in table C

4 to subpart C of part 53 of this chapter, for cases where the data are identified as no t of sufficient comparability to a collocated FRM, and the monitoring agency requests that the FEM or ARM data should not be used in comparison to the NAAQS. These assessments are required in the monitoring agency's annual monitoring network plan described in §58.10(b) for cases where the FEM or ARM is identified as not of sufficient comparability to a collocated FRM ....”Page 9 of 31

County , State Monitor Site ID State Rec NA? 09

- 11 DV 10

- 12 DV 11

- 13 DV

Jefferson, KY 211110067 No Invalid data (awaiting EPA decision)

a Where a county has more than one monitoring location, the county design value is indicated in red type.

b Th is design value do es not include data from Class III FEM monitors that are not eligible for comparison to the NAAQS

, as approved by the EPA pursuant to 40 CFR 58.11(e).

The Figure 1 map, shown previously, identifies the Louisville, KY

- IN area final nonattainment area, the CBSA boundary

, and monitoring locations with 2011

- 2013 violating DV s . As indicated on the map, there is one monitoring location that is violating the NAAQS in Jeffersonville in Clark County . This monitor has consistently had a higher DV in the region inclu ding the 1997 PM 2.5 design ation. There is a second monitor in
Clark County to the northeast and one monitor to the west in Floyd County ; data from both of these monitors show compliance with the NAAQS. As described previously, t here are four monitors in Je fferson County,

K entucky and all have invalid data for this subject time period.

Seasonal variation can highlight those conditions most associated with high average concentration levels of

PM 2.5

. Figure 2 shows quarterly mean PM 2.5 concentrations for the most recent 3

- year period for the highest DV

m onitor ing sites and other, non

- violating, monitoring sites in each county within the area of analysis

. This graphical representation is particularly relevant when assessing air quality da ta for an annual standard, such as
the 2012 annual PM 2.5 NAAQS, because , as previously stated, the annual mean is calculated as the mean of quarterly means and a high quarter can drive the mean for an entire year, which, in turn, can drive an elevated 3

- ye ar DVPage 10 of 31

Figure 2. Louisville PM 2.5 Quarterly Means for 20 1 0

- 201 2

As shown, q uarterly values across the period vary by 5 μ g/m 3 at the Clark County site , with consistent a nnual peaks occurring in Q3.

PM 2.5 Composition Measurements

- To assess potential emission s contribution s for each violating monitor ing
location , the EPA determined the various chemical species comprising total PM 2.5 to identify the chemical
constituents over the analysis area , which can provide insight into the types of emission sources impacting the
monitor ed concentration

. To best describe the PM 2.5 at the violating monitoring location, the EPA first adjusted
the chemical speciation measurement data from a monitoring location at or near the violating FRM monitoring
site using the SANDWICH approach to account for the amount of PM 2.5 mass constituents retained in the FRM

0.0 2.0 4.0 6.0 8.0 10.0 12.0 14.0 16.0 18.0

'10 Q1 '10 Q2 '10 Q3 '10 Q4 '11 Q1 '11 Q2 '11 Q3 '11 Q4 '12 Q1 '12 Q2 '12 Q3 '12 Q4 PM2.5 Concentrations

μ g/m3 

## Louisville PM 2.5 

## Quarterly Means 2010

- 2012

Clark Clark FloydPage 11 of 31

measurement. 21

, 22

, 23

, 24 In particular, this approach accounts for losses in fine particle nitrate and increases in sulfate mass associated with particle bound water. Figure 3 a illustrates the fraction of each PM 2.5 chemical
constituent at the Clark County (180190006) monitor ing site based on annual averages for the years 201 0

- 201 2

.

F igure 3a shows the PM 2.5 chemical constituent annual average for DV monitor from Clark County monitor.

Figure 3a. Louisville, KY

- IN Area Annual Average PM 2.5 Chemical Constituents (2010

- 2012)

Figure 3b shows annual and quarterly chemical composition profiles and illustrates seasonal and episodic
contributors to PM 2.5 mass. This “ increment analysis

, ” combin ed with the other factor analyses, can provide

21 SANDWICH stands for measured S ulfate, A djusted N itrate, D erived W ater, I nferred C arbonaceous mass H ybrid Material Balance Approach.” The SANDWICH adjustment uses an FRM mass construction methodology that results in reduced nitrates (relative to the amount measured by routine speciation networks), higher mass associated with sulfates (reflecting water included in gravimetric FRM measurement s) and a measure of organic carbonaceous mass derived from the difference between measured PM 2.5 and its non

- carbon components. This characterization of PM 2.5 mass also reflects crustal material and other minor constituents. The resulting characterization provides a complete mass closure for the measured FRM PM 2.5 mass , which can be different than the data provided directly by the speciation measurements from the CSN network.

22 Frank, N. H., SANDWICH Material Balance Approach for PM 2.5 Data Analysis, National Air Monitoring Conference, Las Vegas, Nevada, November 6

- 9, 2006. http://www.epa.gov/ttn/amtic/files/2006conference/frank.pdf

.

23 Frank, N. H., The Chemica l Composition of PM 2.5 to support PM Implementation, the EPA State /Local/Tribal Training Workshop: PM 2.5 Final Rule Implementation and 2006 PM 2.5 Designation Process, Chicago IL, June 20

- 21, 2007, http://www.epa.gov/ttn/naaqs/pm/presents/pm2.5_chemical_composition.pdf

.

24 Frank, N. H. Retained Nitrate, Hydrated Sulfates, and Carbonaceous Mass in Federal Reference Method Fine Particulate Matter for Six Eastern U.S. Citie s . J. Air & Waste Manage. Assoc. 2006 56:500

– 511. 5.01

0.85 0.88 5.36 0.93 

# Annual Average PM2.5 Chemical
Constituents 2010

- 2012 ( μ g/m3)

Organic Mass Elemental Carbon Nitrates Sulfates CrustalPage 12 of 31

additional insight as to which sources or factors ma y contribute at a greater level. Simply stated, t his analysis

can help identify nearby sources of emissions that contribute to the violation at the violating monitoring site

.
Figure 3 b

. Louisville, KY

- IN Area Annual and Quarterly Average PM 2.5 Species ( 2010

- 2012 ) a

a Adjusted to FRM Total PM 2.5 indicates that the speciation profile and total mass depicted in this figure are the result of the urban increment calculation for the particular FRM monitor.

Figure s 3a and 3b show that sulfate and organic mass are the predominant species overall. Crustal and elemental
carbon comprise a small percentage in all four quarters. Sulfate peaks in quarter three

. Nitrate is a relatively small component in all quarters , but is slightly higher in Q 1 & 4

. It is likely that the large sulfate component is 0.00 2.00 4.00 6.00 8.00 10.00 12.00 14.00 16.00

Annual Q1 Q2 Q3 Q4 μg/m3 

### Annual and Quarterly Average PM 2.5 

### Species

2010

- 2012 Adjusted to FRM Total PM 2.5

Organic Mass Elemental Carbon Nitrates Sulfates Crustal

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Annual Q1 Q2 Q3 Q4

Organic Mass Elemental Carbon Nitrates Sulfates CrustalPage 13 of 31

caused by SO 2 emissions from large electric generating units in the area. High levels of organic mass are typically associated with mobile sources, wood or biomass burning and localized combustion sources. 25

The EPA assessed seasonal and annual average PM 2.5 constituents at monitoring sites within the area relative to monitoring sites outside of the analysis area to account for the difference between regional background
concentrations of PM 2.5 , and the concentrations of PM 2.5 in the area of analysis, also known as the “urban increment.” This analysis differentiates between the influences of emissions from sources in nearby areas and in
more distant areas on the violating monitor

. Estimating the urban inc rement in the area helps to illuminate the amount and type of particles at the violating monitor that are most likely to be the result of sources of emissions in nearby areas, as opposed to impacts of more distant or regional sources of emissions. Figure 4 a includes pie charts showing the annual and quarterly chemical mass co nstituents of the urban increment. The quarterly pie
chart s correspond to the high

- concentration quarters identified in Figure 2 . Evaluating these high concentration quarters can help i dentify composition of PM 2.5 during these times. Note that in these charts, s ulfates and

n itrates have been adjusted to represent their mass in measured PM 2.5

.

Figure 4 a
. Louisville, KY

- IN Area Urban Increment Analysis for 2010

- 2012

.

25 The EPA Guidance Memorandum, “Initial Area Designations for the 2012 Revised Primary Annual Fire Particulate National Ambient Air Quality Standard,” dated April 16, 2013, Attachment 3. 47%

13% 5% 20% 15% 

## Annual Average Urban Increment

2010

- 2012 ( μ g/m3)

Organic Mass

Elemental
Carbon Nitrates

Sulfates

CrustalPage 14 of 31

Figure 4 b

. Louisville, KY

- IN Area Average Urban Increment Analysis for 2010

- 2012

. 2.34

0.53 0.35 0.33 0.38 

# Q

- 1 Average Urban

Increment 2010

- 2012 

# ( μ g/m3)

Organic Mass

Elemental Carbon

Nitrates

Sulfates

Crustal 1.02

0.40 0.00 0.55 0.42 

# Q

- 2 Average Urban

Increment 2010

- 2012 ( μ g/m3)

Organic Mass

Elemental Carbon

Nitrates

Sulfates

Crustal

0.74

0.24 0.00 1.20 0.42 

# Q

- 3 Average Urban

Increment 2010

- 2012 ( μ g/m3)

Organic Mass

Elemental Carbon

Nitrates

Sulfates 1.93

0.49 0.35 0.52 0.65 

# Q

- 4 Average Urban

Increment 2010

- 2012 ( μ g/m3)

Organic Mass

Elemental Carbon

Nitrates

Sulfates

0.00 0.50 1.00 1.50 2.00 2.50 3.00 3.50 4.00 4.50

Annual Q1 Q2 Q3 Q4



## Average Urban Increment 2010

- 2012 ( μ g/m3)

Organic Mass Elemental Carbon Nitrates Sulfates CrustalPage 15 of 31

Clark C ount y has one monitoring site with a DV exceeding the NAAQS

. The urban increment calculated for the Clark County violating monitor reveals a seasonal peak in ambient PM 2.5 concentrations in quarters 1 and

4.

A comparison of the average urban increment to the total measured PM 2.5 for the Louisville, KY

- IN area
indicates that the urban increment is less than one

- third of the total. This indicates a significant contributio n from regional sources. Looking at speciated components of the urban increment for the Louisville, KY

- IN area DV monitor, the organic mass component appears to have the largest urban contribution for quarters 1 and 4.
Sulfate is second highest annual urb an increment c omponent and peaks during quarter 3, showing a potential contribution from local SO2 sources. Elemental carbon has a large increment in quarters 1, 2, and 4. During all quarters of the year, there is also a relatively high organic mass to e lemental carbon ratio, which potential ly indicates contribution from wood combustion or biomass burning sources. This analysis points to contribution from both regional and local PM 2.5 source s

.

Factor 2: Emissions and emissions

- related data
In th is designations process, for the area with a violating monitor ing site

, the EPA evaluate d the emissions data from nearby areas using emissions

- related data for the relevant counties to assess each county’s potential
contribution to PM 2.5 concentrations at th e violating monitor ing site in the area under evaluation

. Similar to the air quality analysis, these data were examined on a seasonal basis. The EPA examine d emissions of identified

sources or source categories of direct PM 2.5 , the major components of direct PM 2.5 ( POM)

, EC, , crustal material (and/or individual trace metal compounds)), primary nitrate and primary sulfate, and pr ecursor gaseous pollutants (i.e. , SO 2 , NO x , total VOC, and NH 3 ). The EPA also considered t he distance of those sources of
emis sions from the violating monitor ing site

. While d irect PM 2.5 emissions and its major carbonaceous
components are generally associated with sources near violating PM 2.5 monitoring sites, t he gaseous precursors
tend to have a more regional influence (although the EPA is mindful of the potential local NO x and VOC
emissions contributions to PM 2.5 from mobile and stationary sources) and transport from neighboring areas can contribute to higher PM 2.5 levels at the violating monitor ing site s.

Emissions Da ta

For this factor, the EPA reviewed data from the 2011 NEI version 1 ( s ee http://www.epa.gov/ttn/chief/net/2011inventory.html ). For each county in the area of analysis, the EPA
examin ed the magnitude of county

- level emissions reported in the NEI. These county

- level emissions represent the sum of emissions from the following general source categories: point sources, non

- point (i.e., area) sources, nonroad mobile, on

- road mobile, and fires. The EPA also looked at the geographic distrib ution of major point sources of the relevant pollutants. 26 Significant emissions levels from sources in a nearby area indicate the potential for the area to contribute to monitored violations.

To further analyze area emissions data, the EPA also developed a summary of direct PM 2.5 , components of
direct PM 2.5 , and precursor pollutants, which is available at http://www.epa.gov/pmdesignations/2012standards/docs/nei2011v1 pointnei2008v3county.xlsx

.

26 For purposes of this designations effort, “major” point sources are those whose sum of PM precursor emissions ( PM 2.5 + NOx + SO 2 + VOC + NH 3 ) are greater than 500 tons per year based on NEI 2011v1

.Page 16 of 31

When considered with the urban increment analysis in Factor 1, evaluating the components of direct PM 2.5 and

precursor gases can help identify specific sources or source types contributing to elevated concentrations at violating monitor ing sites and thus assist in identifying appropriate area boundaries. In general, directly emitted
POC and VOCs 27 contribute to P O M; directly emitted EC contributes to PM 2.5 EC; NO x , NH 3 and directly
emitted nitrate contribute to PM 2.5 nitrate mass (PNO 3 ) ; SO 2 , NH 3 and directly emitted sulfate contribute to

PM 2.5 sulfate mass (PSO 4 ) ; and directly emitted crustal material and metal oxides contribute to PM 2.5 crustal

matter (PCrustal)

. 28

, 29 The EPA believes that the quantities of those nearby emissions as potential contributors
to the PM 2.5 violating monitor s are somewhat proportional to the PM 2.5 chemical constituents in the estimated urban increment. Thus, directly emitted POC is more important per ton than SO 2 , partially because POC
emissions are already PM 2.5 whereas SO 2 must conver t to PM 2.5 and not all of the emitted SO 2 undergoes this
conversion.

Table 3a provides a county

- level emissions summary (i.e., the sum of emissions from the following general source categories: point sources, non

- point (i.e., area) sources, nonroad mobile, on

- road mobile, and fires) of directly emitted PM 2.5 and precursor species for the county with the violating monitoring site and nearby
counties considered for inclusion in the Louisville, KY

- IN area

. Table 3b summari zes the directly emitted components of PM 2. 5 for the same counties in the area of analysis for the Louisville, KY

- IN area

. This information will be paired with the Urban Increment composition previously shown in Figures 4a and 4b.

Table 3a

. County

- Level Emissions of Directly Emitted PM 2.5 and Precursors (tons/year) 30

County , State Total NH 3 Total NOx Total Direct
PM 2.5 Total

SO 2 Total VOC Total

Jefferson , KY 915 39315 8163 39233 26406 114

, 032

Jefferson, IN 468 11841 973 74124 1940 89

, 348

Nelson, KY 1037 1414 470 247 8268 11

, 435

Clark, IN 824 4158 1137 1577 3260 10

, 956

Bullitt, KY 137 3406 590 447 4965 9

, 544
Floyd, IN 127 3235 375 3027 1694 8

, 458

Trimble, KY 129 2579 174 3155 493 6

, 529

Harrison, IN 1654 1760 601 29 1682 5

, 726

27 As previously mentioned, nearby VOCs are presumed to be a less importan t contributor to P OM M than POC.

28 See , Seinfeld J. H. and Pandis S. N. (2006) Atmospheric Chemistry and Physics: From Air Pollution to Climate Change

, 2nd edition, J. Wiley, New York. See also, Seinfeld J. H. and Pandis S. N. (1998) Atmospheric Chemistry and Physics: From Air Pollution to Climate Change , 1st edition, J. Wiley, New York.

29 USEPA Report (2004), The Particle Pollution Report: Current Understanding of Air Quality and Emissions through 2003, found at: http://www.epa.gov/airtrends/aqtrnd04/pm.html

.

30 In response to the EPA’s intended designations, Kentucky in a letter dated October 29, 2014, stated that they compared the 2011 NEI to the updated 2012 NEI for Jefferson County, Kentuck y, and noted that the emissions for NH 3 decreased by 72 tons/year; SO 2 by 1,322 tons/year and NOx by 3,491 tons/year. The EPA has considered this update information in relation to the contribution analysis for the violating monitor in Indiana and still concludes that emissions in Jefferson County contribute to the violations at the Indiana monitor.Page 17 of 31

County , State Total NH 3 Total NOx Total Direct
PM 2.5 Total

SO 2 Total VOC Total

Shelby, KY 629 2539 391 16 2054 5

, 629 Washington,
IN 1261 874 481 23 1309 3

, 949

Oldham, KY 179 1797 285 13 1271 3

, 544

Meade, KY 484 1013 291 98 1371 3

, 257
Henry, KY 407 1270 193 11 802 2

, 683
Spencer, KY 133 396 167 7 512 1

, 215

Table 3b. County

- Level Emissions for Components of Directly Emitted PM 2.5 (tons/year) 31

County , State POM EC PSO 4 PNO 3 P C rustal Residual Total Direct

Jefferson, KY 2330 715 443 13 2091 2570 8

, 163 Clark, IN 406 107 51 12 291 272 1

, 137 Jefferson, IN 398 77 32 4 218 245 973 Harrison, IN 306 62 7 1 106 118 601 Bullitt, KY 274 107 7 1 78 122 590 Washington, IN 258 47 3 2 86 85 481 Nelson, KY 203 63 7 1 83 114 470 Shelby, KY 146 69 7 1 69 99 391 Floyd, IN 170 65 6 1 55 78 375 Meade, KY 125 36 3 1 57 69 291 Oldham, KY 134 61 3 1 38 48 285 Henry, KY 79 35 2 0 39 38 193 Trimble, KY 48 35 8 1 32 50 174 Spencer, KY 87 20 1 1 27 32 167

Table 3b breaks down the d irect PM 2.5 emissions value from Table 3a into its components. Th e data were compared with the previously presented Urban Increment composition.

Using the previously described relationship between directly emitted and precursor gases and the measured mass to evaluate data presented in T ables 3a and 3b, the EPA identified the following components warranting
additional review: NOx, POM and SO 2

. The EPA then looked at the contribution of these constituents of interest from each of the counties included in the area of analysis as shown in Tables 4 a

- c.

Table 4a. County

- Level NOx Emissions (tons/year)

Emissions in average tons/yr
County, State NO x Pct. Cumulative %
Jefferson, KY 39315 52% 52%

Jefferson, IN 11841 16% 68%

31 Data are based on the 2011 and 2018 Emissions Modeling Platform Data Files and Summaries ( ftp://ftp.epa.gov/EmisInventory/2011v6/v1platform ) available at: http://www.epa.gov/ ttn / chief/emch/index.html#2011 (accessed 02/26/14)

.Page 18 of 31 Emissions in average tons/yr
County, State NO x Pct. Cumulative %
Clark, IN 4158 6% 73%

Bullitt, KY 3406 5% 78%
Floyd, IN 3235 4% 82%

Trimble , KY 2579 3% 85%
Shelby , KY 2539 3% 89%

Oldham KY 1797 2% 91%

Harrison , IN 1760 2% 93%

Nelson , KY 1414 2% 95%

Henry , KY 1270 2% 97%

Meade, KY 1013 1% 98%
Washington , IN 874 1% 99%
Spencer, KY 396 1% 100%

Table 4b. County

- Level POM Emissions

Emissions in average tons/yr
County, State POM Pct. Cumulative %

Jefferson, KY 2330 47% 47%

Clark, IN 406 8% 55%

Jefferson, IN 398 8% 63%

Harrison, IN 306 6% 69%

Bullitt, KY 274 6% 75%
Washington, IN 258 5% 80%

Nelson, KY 203 4% 84%
Floyd, IN 170 3% 88%
Shelby, KY 146 3% 90%

Oldham, KY 134 3% 93%

Meade, KY 125 3% 96%
Spencer, KY 87 2% 97%

Henry, KY 79 2% 99%

Trimble, KY 48 1% 100%

Table 4 c . County

- Level SO 2 Emissions
Emissions in average tons/yr
County, State SO 2 Pct. Cumulative %

Jefferson, IN 74124 61% 61%

Jefferson, KY 39233 32% 93%

Trimble, KY 3155 3% 95%
Floyd, IN 3027 2% 98%Page 19 of 31 Emissions in average tons/yr
County, State SO 2 Pct. Cumulative %

Clark, IN 1577 1% 99%

Bullitt, KY 447 <1% 100%

Nelson, KY 247 <1% 100%

Meade, KY 98 <1% 100%

Harrison, IN 29 <1 % 100%
Washington, IN 23 <1 % 100%
Shelby, KY 16 <1 % 100%

Oldham, KY 13 <1 % 100%

Henry, KY 11 <1 % 100%

Spencer, KY 7 <1 % 100%

In addition to reviewing county

- wide emissions of PM 2.5 and PM 2.5 precursors in the area of analysis, the EPA also reviewed emissions from major point sources located in the area of analysis. The magnitude and location of
these sources can help inform nonattainment boundaries. Table 5 provides facility

- level emissions of direct

PM 2.5 , components of direct PM 2.5 , and precursor pollutants (given in tons per year) from major point sources
located in the area of analysis for the Loui sville, KY

- IN area

. Table 5 also shows the distance from the facility to the DV monitor for the respective county.

Table 5 . NEI 2011 v1 Point Source Emissions (tons/year)

Distance NEI 2011 v1 Emissions

- Tons/Year

County , State Facility Name (Facility ID) m o n i t o r (m iles ) NH 3 NOx PM 2.5 SO 2 VOC Total

Bullitt , KY Four Roses Distillery Inc (2102900004) 26

- - - - 1,216 1,216

Bullitt , KY Jim Beam Brands Co

- Clermont Plant

(2102900005) 25

- 86 6 187 1,487 1,766

Clark , IN ESSROC CEMENT CORP.( 00008) 9 0 1,153 217 1,545 60 2,974

Floyd , IN DUKE ENERGY INDIANA

– GALLAGHER

(000040 5 1 1,344 12 3,010 11 4,378

Jefferson , IN IKEC

- CLIFTY CREEK STATION (00001) 36 2 10,938 281 74,086 85 85,392

Jefferson , KY Louisville Gas & Electric Co., Cane Run Station

(0126) 10 0 5,596 420 7,824 48 13,888

Jefferson, KY Kosmos Cement Company (0060) 19 22 1,097 114 187 51 1,472

Jefferson, KY Ford Motor Company, Kentucky Truck Plant (0073) 11 2 69 17 0 698 787

Jefferson, KY Louisville Gas & Electric Co., Mill Creek Station

(0127) 18 0 8,495 2,780 29,945 130 41,350

Jefferson, KY American Synthetic Rubber Company (0011) 7 1 549 30 137 256 973

Jefferson, KY Brown

- Forman Distilleries, Early Times (0244) 6 0 80 13 258 1,416 1,767

Jefferson, KY Heaven Hill Distilleries (0243) 3 0 15 2 0 1,400 1,417

Jefferson, KY Reynolds Packaging Group, Foil Plant (0186) 4 0 14 3 0 1,306 1,323

Jefferson, KY Diageo Americas Supply, Inc. (0167) 6 0 1 0 0 1,616 1,617

Jefferson, KY Louisville Medical Center Steam Plant (148) 2 0 161 31 476 1 669

Jefferson, KY Louisville Intl

- Standif 7

- 1,421 26 136 148 1,732Page 20 of 31 Distance NEI 2011 v1 Emissions

- Tons/Year

County , State Facility Name (Facility ID) m o n i t o r (m iles ) NH 3 NOx PM 2.5 SO 2 VOC Total

Nelson , KY Heaven Hill Distilleries (2117900005) 37

- 1 0 0 1,853 1,855

Nelson , KY Jim Beam Brands Co

- Boston Nelson Co

(2117900014) 33

- 72 31 181 2,429 2,712

Nelson , KY Barton Distillery (2117900020) 36

- 17 2 45 1,403 1,467

Trimble , KY Louisville Gas & Electric Co

- Trimble Co

Generating Station ( 2122300002 28 26 2,088 55 3,112 132 5,413

The IKEC

- Clifty Creek Station facility located in Jefferson County, Indiana, stands out in Table 5 as having a large level of SO 2 emissions reported in the 2011 NEI (74,086 tpy). Recently, the Clifty Creek facility has installed both flue gas desulfurization systems, as well as selective catalytic reduction systems on mult iple units in order to satisfy federal rules controlling SO 2 for transport as well as rules for controlling mercury and air
toxics. SO 2 emissions at the facility have decreased from 2011 levels of 36,391 total tpy for units 1, 2, 3, and 37,694 total tpy for units 4, 5, 6 to levels in 2014 of 3,745 and 3,351 total tpy, respectively. The lower levels of emissions in combination with the large distance to the violating monitor and a low frequency of winds blowing from the facility toward the monitor, led to the conclusion that the facility is not contributing to the monitor
violation.

Figure 5 shows the major point source emissions (from the 2011 NEI in tons per year) in the area of analysis for
the Louisville, KY

- IN area and the relative distances of these s ources from the violating monitoring location , as depicted by red dot in the center of the map . The actual distance from the point sources to the DV monitoring
location is presented in Table 5 )

. The distance from the violating monitor ing location is particularly important
for dir ectly emitted PM 2.5 . The influence of directly emitted PM 2.5 on ambient PM 2.5 diminishes more than that
of gaseous precursors as a function of distance. 32

As indicated in Figure 5 , there are 20 major point sources lo cated with in 37 miles of the violating monitor. Eleven of these point sources are located in Jefferson County, K entucky

.

32 B aker, K

. R. and K . M. Foley

. A nonlinear regression model es timating single source concentrations of primary and secondarily formed PM 2.5

. Atmospheric Environment. 45 (2011) 3758

- 3767.Page 21 of 31

Figure 5. Major Point Source Emissions in the Area of Analysis for the Louisville, KY

- IN Area

.

In summary, the EPA’s analysis of relevant county

- level emissions and the geographic locations of the relevant pollutants showe d both Jefferson County in K entucky

, and Clark and Floyd Counties in Indiana had the highest
overall emissions. Jefferson County in Indiana also has large emissions, 95% derived from the point source at Clifty Creek Station. Emissions controls has reduced SO2 and NOx emissions by 73% since 2011. Clifty Creek is 36 miles away from the violating monitor and the rest of Jefferson County has low non

- point, road and on

road emi ssions compared to the point source at Clifty Creek. EPA concludes that Jefferson County, Indiana, is not contributing to the violating monitor.

SO 2 are the predominant pollutant emissions in the area. Three of the four largest SO 2 point source emissions

are within 18 miles of the violating monitor

. With the exception of Nelson County

, Kentucky , county emissions
level s for the rest of the counties in the CBSA are lower the further away it is from the violating monitor.
Nelson County ’s emissions consist pri marily of VOCs , most ly from three point sources. The total VOC emissions from Nelson County are less than one

- third of the VOC emissions from Jefferson County and are less
than 15 percent of the total VOC emissions in the CBSA. The large distance from Nels on County to the violating monitor and the low frequency of winds blowing from the southeast east, led to the EPA’s conclusion that Nelson County is not contributing to the violating Clark County, Indiana, monitor.Page 22 of 31

Population density and degree of urbanization

In this part of the factor analysis, the EPA evaluated the population and vehicle use characteristics and trends of the area as indicators of the probable location and magnitude of non

- point source emissions. Rapid population growth in a count y on the urban perimeter signifies increasing integration with the core urban area, and indicates that it may be appropriate to include the county associated with area source and mobile source emissions as part of the nonattainment area. Table 6 shows the 2000 and 2010 population , population growth since 2000, and population density for each county in the area.

Table 6

. Population Growth and Population Density

.

County , State Population

20 00 Population

2010 %

Change from 2000 Land

Area (Sq. Miles) Population

Density ( per Sq. Mile) % Cumulative %

Jefferson , KY 693,604 742,324 7.0% 385 1,928 58 56

Clark , IN 96,472 110,555 14.6% 375 295 9 65 Floyd , IN 70,823 74,657 5.4% 148 504 6 70

Bullitt , KY 61,236 74,490 21.6% 299 249 6 76

Oldham , KY 46,178 60,420 30.8% 189 319 5 81

Nelson , KY 37,477 43,594 16.3% 423 103 3 84 Shelby , KY 33,337 42,287 26.8% 384 110 3 87

Harrison , IN 34,325 39,357 14.7% 485 81 3 90
Jefferson, IN 31,705 32,455 2.4% 361 90 2 93 Washington , IN 27,223 28,265 3.8% 514 55 2 95

Meade , KY 26,349 28,695 8.9% 309 93 2 97 Spencer , KY 11,766 17,114 45.5% 186 92 1 98 Henry , KY 15,060 15,398 2.2% 289 53 1 99

Trimble , KY 8,125 8,787 8.1% 149 59 1 100

Total 1,193,680 1,318,398 Source: U.S. Census Bureau population estimates for 2000 and 2010

The four most populated counties in the area are in and adjacent to the county with the violating monitor. Jefferson and Bullitt Counties in Kentucky and Clark and Floyd Counties in Indiana account for 76% percent of the region’s population. In order of th e most Jefferson County , K entucky ha s the highest population density, about four times large r than Floyd County

, which has the second highest. The area around the violating monitor is highly urbanized. Bullitt County , K entucky is the fifth most densely populated with a n urbanized area in the
north adjacent to Louisville International Airport

. Bullitt’s population grew 21 percent to 74,490, about 6
percent of the CBSA population. EPA concludes Jefferson and Bullitt Counties in Kentucky and Clark and Floy d Counties in Indiana is contributing to the violating monitor in Clark County, Indiana.Page 23 of 31

Figure 6. 2010 County

- Level Population in the Area of Analysis for the Louisville, KY

- IN Area.

Traffic and Vehicle Miles Travelled (VMT)

H igh VMT and/or a high number of commuters associated with a county is generally an indicator that the county is an integral part of an urban area . Mobile source emissions of NO x , VOC, and direct PM 2.5 may contribute to ambient particulate matter that contributes to monitored violations of the NAAQS in the area

. In combination with the population/population density data and the location of main transportation arteries, an assessment of VMT help s identify the probable location of nonpoint source emission s that contribute to
violations in the area

. Comparatively high VMT in a county outside of the CBSA or CSA signifie s integration
with the core urban area contained within the CSA or CBSA , and indicate s that a county with the high VMT may be appropriate to include in the nonattainment area because emissions from mobile sources in that county
contribute to violations in the area

. Table 7 shows 2011 VMT while Figure 7 overlays 2011 county

- level VMT with a map of the transportation arteries. This data is from t he Federal Highway Administration

.Page 24 of 3 1

Table 7

. 2011 VMT fo r the Louisville, KY

- IN Area

. County , State Total 2011 VMT Percent Cumulative %
Jefferson , KY 7,222,527,493 53 % 53 %
Clark , IN 1,174,901,566 9% 61 % Bullitt, KY 952,778,343 7% 68 % Floyd , IN 672,638,182 5% 73 % Shelby , KY 648,551,690 5% 78 %
Harrison , IN 589,004,275 4% 82 %
Nelson , KY 492,911,504 4% 86 %
Oldham , KY 467,765,544 3 % 89 % Jefferson, IN 322,232,066 2% 92% Washington , IN 305,724,135 2% 94% Henry , KY 300,376,674 2% 96%
Meade , KY 287,931,054 2% 98% Spencer , KY 153,288,071 1% 99%
Trimble , KY 81,444,339 1% 100%

Total 13,672,074,936 http://www.census.gov/hhes/commuting/data/commuting.html

Figure 7. Overlay of 2011 County

- level VMT with Transportation Arteries

.Page 25 of 31

Jefferson County and Bullitt County in Kentucky, and Clark County in Indiana had the largest VMT. More than
half of all the VMT in the CBSA is in Jefferson County

, K entucky . It is reasonable to infer that a substantial
amount of the traffic is due to inter

- county commuters, mainly from Bullitt, Clark and Floyd C ounties

. Additional analysis for Jefferson County

, Kentucky shows that 88 percent of all commuting is from intra

- co unty
and less than 7 percent of all commuting traffic comes from Bullitt County

. The northern portion of Bullitt County is part of a conti guous, urbaniz ed area and while only 7 percent of the commuters are heading to
Jefferson County , a large portion can b e attributed to the population center s and VMT from that portion of the
county.

Clark and Floyd Counties in Indiana , and Jefferson County in Kentucky consistently rank highest in direct

PM 2.5 /key precursor emissions attributable in large part to VMT and population. Jefferson County

, Kentucky

, contributed more than 8 2 percent of SO 2 and 83 percent total PM 2.5 from stationary sources in the CBSA

. Bul litt County is mid

- ranked in emissions and mid

- ranked for population and VMT . M ost of the urbanized area of Bullitt County is adjacent to Jefferson, Kentucky

. Oldham, Nelson, Shelby, Harrison, Washington, Meade, Spencer, Henry and Trimble Counties ha ve relatively low emissions and relatively low VMT/population counts, and lack large singular point source contributors.

Factor 3: Meteorology

The EPA evaluated available meteorological data to determine how meteorological conditions, including, but not limited to, weather, transport patterns

, and stagnation conditions, could affect the fate and transport of directly emitted particulate matter and precursor emissions from sources in the area of analysis

. The EPA used two primary tools for this assessment: wind roses and kernel density estimation (KDE)

. When considered in
combi nation with area PM 2.5 composition and county

- level and facility emissions source location information

, wind roses and KDE can help to identify nearby areas contributing to violations at violating monitoring sites.

Wind roses are graphic illustrations o f the frequency of wind direction and wind speed. Wind direction can indicate the direction from which contributing emissions are transported; wind speed can indicate the force of the wind and thus the distance from which those emissions are transported. T he EPA constructed w ind roses from hourly observations of wind direction and wind speed using 2009

- 2012 data from National Weather
Service locations archived at the National Climate Data Center. 33 When developing these wind roses, the EPA
also used wind obser vations collected at meteorological sampling stations collocated at air quality monitoring
sites , where these data were available

. Figure 8 shows wind roses that the EPA generated from data relevant in
the Louisville, KY

- IN area.

33 ftp.ncdc.noaa.gov/pub/data/noaa or http://gis.ncdc.noaa.gov/map/viewe r/#app=cdo&cfg=cdo&theme=hourly&layers=1&node=gis Quality assurance of the National Weather Service data is described here: http://www1.ncdc.noaa.gov/pub/data/inventories/ish

- qc.pdfPage 26 of 31

Figure 8. Wind Ro ses in the Area of Analys is for Louisville, KY

- IN A rea.

As shown in Figure 8, there is a pattern across the CBSA of winds blowing predominantly from the south , west
and south west, and a smaller frequency from the north, mostly at low to mid

- level speeds of 2 to 6 meters per
second

.

In addition to wind roses, the EPA also generated KDE plots to represent HYSPLIT (HYbrid Single

- Particle Lagrangian Integrated Trajectory) backward trajector y frequency at violating monitor ing sites

. 34

, 35 These KDEs

are g raphical statistical estimations to determine the density of trajectory endpoints at a particular location represented by a grid cell. The EPA used KDEs to characterize and analyze the collection of individual HYSPLIT backward trajectories

. 36 Higher density values, indicated by darker blue colors, indicate a greater

34 In some past initial area designations efforts, the EPA has used HYSPLIT backward trajectories to assist in determining nonattainment area boundaries. A HYSPLIT backward trajectory is usually depicted on a standard map as a single line, representing the centerline of an air parcel’s motion, extending in two dimensional (x,y) s pace from a starting point and regressing backward in time to a point of origin. Backward trajectories may be an appropriate tool to assist in determining an air parcel’s point of origin on a day in which a short

- term standard, such as an 8

- hour standard o r a 24

- hour standard, was exceeded. However, for an annual standard, such as the 2012 annual PM 2.5 NAAQS, every trajectory on every day is important. Plotting a mass of individual daily (e.g., 365 individual back trajectories), or more frequent, HYSPLIT

tr ajectories may not be helpful as this process is likely to result in depicting air parcels originating in all directions from the violating monitoring site.

35 HYSPLIT

- Hybrid Single Particle Lagrangian Integrated Trajectory Model, http://www.arl.noaa.gov /HYSPLIT_info.php

36 The KDEs graphically represent the aggregate of HYSPLIT backward trajectories for the years 2010

- 2012, run every third day (beginning on the first day of monitoring), four times each day, and ending at four endpoint heights.Page 27 of 31

frequency of observed trajectory endpoints within a particular grid cell. Figure 9 shows HYSPLIT KDE plot s for the Louisville, KY

- IN area summarized by calendar quarter for the 20 10

- 2012 period . The HYSPLIT KDE s

are weighted in the south to westerly direction, indicating a greater frequency of trajectories passing over grid
cells to the south and west

.

Figure 9. HYSPLIT K ernel De nsity Estimation Plot s for the Louisville, KY

- IN Area.Page 28 of 31Page 29 of 31

In summary, for the violating monitor, the HYPSPLIT KDE plots and wind roses suggest greatest potential
contribution of emissions from Jefferson and Bullitt Counties in Kentucky, and Clark, Floyd and Harrison
Counties in Indiana. Potential emission contribution from other counties is low, including Jefferson Co. IN

, whose large point source is responsible for most SO2 and NOX emissions for that county and it has recently reduced those emissions by over 70 percent.

Factor 4: Geography/topogr aphy

To evaluate the geography/topography factor, the EPA assessed physical features of the a rea of analysis that might define the airshed and thus affect the formation and distribution of PM 2.5 concentrations over the area. The major topographic feature i n the area is the Ohio River which forms the boundary between the states of Indiana and Kentucky. The river does not form a significant valley in the area with elevation changes in the 50

- 100 meter range and does not significantly limit air pollution trans port within the air shed. Therefore, this factor did not play a significant role in this evaluation.

Factor 5: Jurisdictional boundaries In defining the boundaries of the final Louisville nonattainment area, the EPA considered existing jurisdictional
boundaries , which can provide easily identifiable and recognized boundaries for purposes of implementing the NAAQS. Existing jurisdictional boundaries often signify the state, local governmental organization with the

necessary legal authority for carrying out air quality planning and enforcement functions for the final
nonattainment area. Examples of such jurisdictional boundaries include existing/prior nonattainment area boundaries for particulate matter, county lines, air district boundaries, township bou ndaries, areas covered by aPage 30 of 31

metropolitan planning organization, state lines, and Reservation boundaries, if applicable. Where existing jurisdictional boundaries were not adequate or appropriate to describe the nonattainment area, the EPA
considered other c learly defined and permanent landmarks or geographic coordinates for purposes of identifying the boundaries of the final designated areas

.

The Louisville, KY

- IN area has previously established nonattainment boundaries associated with the 1997
annual PM 2.5 NAAQS

. The 1997 PM 2.5 nonattainment area boundary consist of Jefferson and Bullitt Counties in Kentucky, and Clark, Floyd and a portion of Jefferson County in Indiana. The partial county in Jefferson,
Indiana utilized Madison Township as the nonattainment boundary. Neither Kentucky nor Indiana have
recommended nonattainment boundaries for the 2012 annual PM 2.5 NAAQS

.

Conclusion for Louisville, KY

- IN Area

Speciation and urban increment data show high organic carbon and su lf ate content . Organic carbon and sulfate components are the most important portions of the total PM 2.5 mass throughout the year. Organic carbon may indicate biogenic emissions sources or biomass combustion sources . The predominant source of SO 2 emission s is the large point source s in the area

.

Indiana

Based on the assessment of factors described above, both individually and in combination, the EPA has concluded that the following counties of Indiana should be included as part of the Louisville nonattain ment area because they are vi olating the 2012 annual PM 2.5 NAAQS or contributing to a violation in a nearby area: Clark
and Floyd Counties . These are the same counties that are included in the Louisville nonattainment area for the
1997 annual PM 2.5 NAAQS , with the exception that Jefferson County (partial) has been removed for the reasons
discussed below

.
Clark County has one air quality monitoring site that indicate s violation of the 2012 annual PM 2.5 NAAQS based on the 2013 DV; therefore th is count y is incl uded in the nonattainment area. Clark County also has the second highest level of direct 

### PM 2.5 emissions in the CBSA with 1,137 tpy.

Floyd County is a nearby count y that do es not have a violating monitoring site, but the EPA has concluded that
the County contribute s to the particulate matter concentrations in violation of the 2012 annual PM 2.5 NAAQS through emissions from point sources and non

- point sources (e.g., area sources) and from mobile source
emissions. Floyd County ha s the fourth highest le vel of SO 2 emissions in the CBSA with 3,027 tpy . The prevailing winds blow in the direction from Floyd County toward the violating monitor, and there is a source of
SO 2 emissions (3,010 tpy), Duke Energy Indiana

– Gallagher, five miles north of the monitor

.

A small portion of Jefferson County, Indiana, was included in the nonattainment area for the 1997 annual PM 2.5 NAAQS in order to capture the emissions from the IKEC

- Clifty Creek Station facility. As described earlier in this TSD, e missions controls have been installed to satisfy federal rules requiring control of SO 2 for transport as well as rules for controlling mercury and other air toxics . These controls have resulted in SO 2 emissions
reductions of over 73 percent since 2011. Add itionally, the wind rose and KDE plots presented in the meteorology factor discussion indicate that there is low frequency of winds blowing from the direction of Jefferson County, Indiana, toward the violating monitor and thus do not support contribution. Therefore, thePage 31 of 31

EPA is not designating the portion of Jefferson County , Indiana that was previously included in the
nonattainment area as nonattainment for the 2012 annual PM 2.5 NAAQS.

Kentucky

Based on the assessment of factors described above, both individually and in combination, the EPA has concluded that the following count ies should be included as part of the Louisville nonattainment area because they are contributing to a violation in a ne arby area: Jefferson County , and the urbanized portion of Bullitt County

.
Jefferson County is a nearby county that does not have valid data from its monitoring sites. The EPA has
concluded that th is area contribute s to the particulate matter concentrations in violation of the 2012 annual

PM 2.5 NAAQS through emissions from point sources and non

- point sources (e.g., area sources), and from
mobile source emissions. Jefferson County ha s among the highest emissions of dir ectly emitted PM 2.5 and PM 2.5 precursors in the area. Jefferson County ranked relatively high for t otal emissions levels including high direct

PM 2.5 , NOx and SO 2 , number of point sources

, high population and VMT and high urbanization throughout the
county. Additionally, there is a high frequency of winds blowing from the south and the west support ing contribution from the Jefferson County emissions to the violating monitor located to the north in Clark County,
Indiana.

Bullitt County is a nearby county th at does not have a PM 2.5 air quality monitor. The EPA has concluded that emissions from the urbanized portion of the county contribute to the particulate matter concentrations in
violation of the 2012 annual PM 2.5 NAAQS

. In review of the emissions from Bullitt County in Kentucky

, the EPA determined that these emissions were primarily population

- based emissions such as mobile and nonpoint sources. Thus, the EPA determined it was most appropriate to capture the urbanized portion of Bullitt County
for inclu sion in this area. 37 The wind roses and KDE plots presented in the meteorology factor discussion indicate that the predominant wind directions in the area support inclusion of the urbanized portion of Bullitt County. The EPA is using census tracts to defin e the nonattainment boundary for Bullitt County. The following census tracts are being included within the nonattainment area: 201, 202, 203, 204, 205, 206, 207, 208 and 211. Census tract 211 also includes the two point sources identified in Table 5 (Four Roses Distillery Inc. and Jim Beam Brands Co.).

In the event Indiana elects to early certify the 2012

- 2014 air quality data and the violating Clark County monitor does not violate the 2012 annual NAAQS

, the EPA will designate the Louisville Area (with the same boundary as the nonattainment boundary identified in this TSD) as unclassifiable. The EPA would have to designate this area as unclassifiable instead of unclassifiable/attainment because of the invalid data in Jefferson County,
Kentuck y for this timeframe.

37 An Urbanized Area (UZA), as defined by the Census Bureau, consists of a central core and adjacent densely settled territory that together contain at least 50,000 people, generally with an overall population density of at least 1,000 people per square mile. Th e EPA evaluated the 2000 Census UZA data for Bullitt County in order to help define partial county boundary. The EPA overlaid the UZA areas with census tracts to determine the high population census tracts in Bullitt County, Kentucky.