1

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Technical Support Document (TSD)

Kentucky

Area Designations For the 

2010 SO2 Primary National Ambient Air Quality Standard

Summary

Pursuant to section 107(d) of the Clean Air Act (CAA), EPA must designate areas as either 

“nonattainment,” “attainment,” or “unclassifiable” for the 2010 1-hour sulfur dioxide (SO2) primary 

national ambient air quality standard (NAAQS). The CAA defines a nonattainment area as one that does 

not meet the NAAQS or that contributes to poor air quality in a nearby area that does not meet the 

NAAQS. Table 1 below identifies the counties or portions of counties (or areas of Indian Country) in 

Kentucky that EPA is initially designating “nonattainment” based on monitored violations. EPA is not 

yet prepared to designate other areas in Kentucky.

Table 1. Nonattainment Area Designations for Kentucky

Area (listed alphabetically)

Kentucky Recommended 

Designation of 

Areas/Counties

EPA’s Designation of 

Areas/Counties

Campbell-Clermont, KY-OH*

 Campbell County, KY (partial)

 Clermont County, OH (partial)

Attainment/ Unclassifiable

N/A

Nonattainment

Jefferson County, KY

 Jefferson County (partial) Nonattainment Nonattainment

* This is a multi-region nonattainment area. Additional information on boundary recommendations and 

analyses can be found in the State of Ohio’s technical support document.
2

Background

On June 2, 2010, EPA revised the primary SO2 NAAQS (75 FR 35520, June 22, 2010) by establishing a 

new 1-hour standard at a level of 75 parts per billion (ppb) which is met at an ambient air monitoring 

site when the 3-year average of the annual 99th percentile of the daily maximum 1-hour average 

concentrations is less than or equal to 75 ppb, as determined in accordance with Appendix T of 40 CFR 

part 50. 40 CFR 50.17(a)-(b). EPA has determined that this is the level necessary to provide protection 

of public health with an adequate margin of safety, especially for children, the elderly and those with 

asthma. These groups are particularly susceptible to the health effects associated with breathing SO2.

The Agency is revoking the two prior primary standards of 140 ppb evaluated over 24-hours, and 30 ppb 

evaluated over an entire year because the standards will not add additional public health protection given 

a 1-hour standard at 75 ppb. Accordingly, EPA is not designating areas in this process on the basis of 

either of these two prior primary standards. Similarly, the secondary standard for SO2 has not been 

revised, so EPA is not designating areas in this process on the basis of the secondary standard.

EPA’s SO2 Designation Approach

Section 107(d) of the CAA provides that not later than 1 year after promulgation of a new or revised 

NAAQS, state Governors may submit their recommendations for designations and boundaries to EPA. 

This deadline was in June 2011. Section 107(d) also requires EPA to provide a notification to states of 

no less than 120-days prior to promulgating an initial area designation that is a modification of a state’s 

recommendation. EPA has reviewed the State’s recommendations and has notified the Governor

through a letter signed by the Regional Administrator of any intended modifications. While language in 

section 107 specifically addresses states, we followed the same process for tribes, pursuant to section 

301(d) of the CAA and Tribal Authority Rule (40 CFR Part 49). Therefore, we are designating areas of 

Indian Country, in consultation with the tribes, on the same schedule as state designations. Kentucky 

does not have any tribes affected by this designation. If a state or tribal government did not submit 

designation recommendations, EPA is promulgating the designations that it deems appropriate. If a state 

or tribe disagreed with EPA’s intended area designations as released on February 7, 2013, it had an 

opportunity to demonstrate why any proposed modification was inappropriate.

Designations guidance was issued by EPA through a March 24, 2011, memorandum from Stephen D. 

Page, Director, U.S. EPA, Office of Air Quality Planning and Standards, to Air Division Directors, U.S. 

EPA Regions I-X. This memorandum identifies factors EPA intends to evaluate in determining 

boundaries for areas designated nonattainment. These 5 factors include: 1) air quality data; 2) 

emissions and emissions-related data (location of sources and potential contribution to ambient SO2

concentrations); 3) meteorology (weather/transport patterns); 4) geography/topography (mountain 

ranges or other air basin boundaries); and 5) jurisdictional boundaries (e.g., counties, air districts, preexisting nonattainment areas, reservations), among any other information deemed relevant to 

establishing appropriate area designations and boundaries for the 1-hour SO2 NAAQS.

The March 24, 2011, memo recommended that area boundaries be defaulted to the county boundary 

unless additional information justifies a larger or smaller boundary than that of the county. EPA 

believes it is appropriate to evaluate each potential area on a case-by-case basis, and to recognize that 
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area-specific analyses conducted by states, tribal governments and/or EPA may support a different

boundary than a default county boundary.

In this TSD, EPA discusses its review and technical analysis of the recommendations regarding areas 

with violating monitors submitted by the state for designations of the 1-hour SO2 standard and any 

modifications from these recommendations.

Definition of important terms used in this document:

1) Designated “nonattainment” area – an area which EPA has determined, based on a state 

recommendation and/or on the technical analysis included in this document, has violated the 2010 SO2

NAAQS, based on the most recent three years of air quality monitoring data, or contributes to a 

violation in a nearby area. 

2) Recommended nonattainment area – an area that a state or tribal government has recommended to 

EPA to be designated as nonattainment.

3) Violating monitor – an ambient air monitor meeting all methods, quality assurance and citing criteria 

and requirements whose valid design value exceeds 75 ppb, as described in Appendix T of 40 CFR part 

50.

4) 2010 SO2 NAAQS - 75 ppb, national ambient air quality standard for SO2 promulgated in 2010. 

Based on the 3-year average of the 99th percentile of the annual distribution of daily maximum 1-hour 

average concentrations

5) Design Value – a statistic that describes the air quality status of a given area relative to the level of 

the NAAQS.
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Nonattainment Designations

Technical Analysis for Campbell County Area

Introduction 

This technical analysis for the Campbell County Area identifies the partial county with a monitor that 

violates the 2010 SO2 NAAQS based on 2009-2011 data, and evaluates nearby counties for 

contributions to SO2 concentrations in the area. EPA has evaluated this county and nearby counties 

based on the weight of evidence of the factors recommended in the March 24, 2011, issued EPA 

guidance.

Figure 1 is a map of the area analyzed showing the locations and design values of air quality monitors in 

the area, and the counties surrounding any violating air quality monitors.

Figure 1 Campbell-Clermont KY-OH SO2 Nonattainment Area

In June 2011, Secretary Leonard K. Peters recommended that 119 counties and one partial county be 

designated as “unclassifiable” or “attainment” for the 2010 SO2 NAAQS based on monitored air quality 

data from 2008-2010. At that time, the monitor in Campbell County, Kentucky was meeting the SO2
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NAAQS and thus the Commonwealth of Kentucky did not provide a nonattainment boundary 

recommendation to EPA for Campbell County. Letter from Leonard K. Peters, Secretary, Kentucky 

Energy and Environment Cabinet, to Gwendolyn Keyes Fleming, Regional Administrator, USEPA, 

Region 4 (June 2, 2011) (on file with USEPA Region 4 Regulatory Development Section). Kentucky 

confirmed the earlier recommendations in a letter dated March 6, 2013.

Figure 2. Nonattainment Area

Campbell-Clermont, KY-OH SO2 Nonattainment Area

Based on EPA’s technical analysis described below, EPA is initially designating a portion of Campbell 

County as nonattainment for the 2010 SO2 NAAQS, based upon currently available information. This 

partial county is listed above in Table 1. The partial county boundary for Campbell County includes the

area bordered by KY Hwy 1566 from Ohio River to KY Hwy 9 (AA Highway) to the Southeast; KY 

Hwy 9 (AA Highway) from Hwy 1566 to I-275 to the Southwest; I-275 to Hwy 2345 (John’s Hill 

Road), Hwy 2345 to US-27, US-27 to I-275, I-275 to Ohio River to the Northwest; and the Ohio River 

from I-275 to KY Hwy 1566 to the Northeast. Also in this Area, EPA is initially designating a portion 

of Clermont County, Ohio in association with Campbell County, Kentucky. Refer to EPA’s TSD for 

Ohio for more information on the Clermont County, Ohio portion of this Area. EPA is not yet prepared 
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to designate other areas in Kentucky, apart from Jefferson County discussed later. In a subsequent 

round of designations we will make final designations decisions for areas that are not currently included 

in this nonattainment area designation.

Detailed Assessment

Air Quality Data 

This factor considers the SO2 air quality monitoring data from a Federal Equivalent Method (FEM) 

monitor, including the design values (in ppb) calculated for all air quality monitors in Campbell County

and the surrounding area based on data for the 2009-2011 period.

The 2011 SO2 NAAQS design values for Campbell County and the surrounding area are shown in Table 

2.

Table 2. Air Quality Data for Nonattainment Designations in Kentucky

County

State

Recommended

Nonattainment?

Monitor Name Monitor Air Quality

System ID Monitor Location

SO2 Design Value,

2009-2011

(ppb)

Campbell 

County, KY No

North Kentucky 

University 

(NKU)

210373002-

42401-1

Highland 

Heights, KY

Lat 39.021806

Long

-84.474453

89

Monitors in Bold have the highest 2009-2011 design value in the respective county.

Campbell County shows a violation of the 2010 SO2 NAAQS. Therefore, some area in this county and 

possibly additional areas in surrounding counties must be designated nonattainment. The absence of a 

violating monitor alone is not a sufficient reason to eliminate nearby counties as candidates for 

nonattainment status. Each area has been evaluated based on the weight of evidence of the five factors 

and other relevant information.

Emissions and Emissions-Related Data

Evidence of SO2 emissions sources in the vicinity of a violating monitor is an important factor for 

determining whether a nearby area is contributing to a monitored violation. For this factor, EPA 

evaluated county level emissions data for SO2 and any growth in SO2 emitting activities since the date 

represented by those emissions data.

Emissions

EPA recognizes that there may be important new information on emissions levels for the period after 

2008, and would consider more recent information if available. Kentucky did not provide updated 

emissions information, therefore EPA relied on the 2008 National Emissions Inventory (NEI) emissions 

data (NEI08V3).
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Table 3 shows total emissions of SO2 (given in tons per year (tpy)) for violating and potentially 

contributing counties in and around the Campbell County area, including sources emitting greater than 

100 tons per year of SO2 according to the 2008 NEI. The Campbell County portion of the nonattainment 

area for the 2010 SO2 NAAQS is wholly comprised within Campbell County and is therefore shown in 

bold. 

Table 3. Annual SO2 Emissions [NEI08V3]

County Facility >100 tpy 

(EIS or State Facility ID) Facility Emissions (tpy)

Total County SO2

Emissions

(tpy)

Campbell County, KY*

Lafarge North America 0.916417

37.7

Suez - Degs of Silver 

Grove LLC 0.385927

Northern Kentucky 

University 0.2439053

Barrett Paving Materials 0.176844

Sara Lee Foods - Claryville 

Facility 0.074461

Fischer Special Mfg Co 0.00061662

Wendling Printing 0.0001035

ADM Grain Co 0.0000135

Clermont County, OH Walter C. Beckjord 

Generating Station** 26,403.8 43272.8

* There are no 100 tpy or greater SO2 sources in Campbell County. Total 2008 Campbell County SO2

emissions were 37.7 tpy.

** This facility is located in Clermont County, OH.

Since the 2008 NEI, EPA emissions inventory data shows that SO2 emissions have been increasing at 

the Walter C. Beckjord Generating Station. See Table 4 below.

Table 4. SO2 Emissions

Emissions Controls

The emissions data used by EPA in this technical analysis and provided in Table 3 represent emissions 

levels taking into account any control strategies implemented on stationary sources in Campbell County, 

Kentucky and Clermont County, Ohio up to and including 2008. EPA has not received any additional 

information from the Commonwealth of Kentucky regarding emissions reductions resulting from 

controls put into place after 2008.

Walter C Beckjord Generating Station - Clermont County, 

OH

Year 2008 2009 2010 2011 2012 

Emissions tpy (EPA Clean 

Air Markets Division 

(CAMD) data) 26400.5 41964.5 69156.3 90834.5 67068.8
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The Duke Energy W.C. Beckjord facility, located in Clermont County, Ohio, has six coal/steam units 

and is located 10 miles from the violating monitor. This is a 60 year old plant with no SO2 controls. 

Meteorology (weather/transport patterns)

Evidence of source-receptor relationships between specific emissions sources and high SO2 values at 

violating monitors is another important factor in determining the appropriate contributing areas and the 

appropriate extent of the nonattainment area boundary. For this factor, EPA considered recent hourly 

meteorological data from the National Weather Service (NWS) sites nearest to the violating monitor to 

determine which wind vectors were associated with 1-hour SO2 exceedances. For the Campbell Area, 

2009-2011 meteorological data from the Cincinnati Municipal Airport (ID #724297-93812) and data 

from the Cincinnati/Northern Kentucky International Airport (ID# 724210-93814) were evaluated. 

Figure 3 shows a map of the SO2 monitor location, meteorological data locations, and the major 

emissions sources in the area. The Cincinnati Municipal Airport is approximately 10 kilometers 

northeast of the violating monitor. The Cincinnati/Northern Kentucky International Airport is 

approximately 17 kilometers west of the violating monitor. The primary SO2 emissions source is the 

Duke Energy, Walter C. Beckjord Generating Station facility, which is located approximately 18 

kilometers east of the violating monitor.

Figure 3. Map of SO2 monitor location, meteorological data locations, and the major 

emissions sources in the area
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Figure 4 shows a wind rose of the hours exceeding the 1-hr SO2 NAAQS (75 ppb) at the Campbell 

County violating monitor. The wind rose was developed using wind data from the Cincinnati Municipal 

Airport site. 

EPA has determined that the wind data from the Cincinnati municipal airport is not likely to be 

representative of winds at the monitor location in Campbell County. The reason is that the Municipal 

Airport is located in the Little Miami River valley, which is approximately 2 kilometers wide with steep 

hills approximately 300 feet high on both sides of the valley and oriented in Northeast to Southwest 

direction. See Figure 5 for a topographic map of the Area. The river valley is likely influencing the 

surface level winds measured at the airport by "channeling" them in the Northeast to Southwest 

direction. 

Figure 4. Wind Rose of 2009-2011 hours exceeding the 1-hr 

SO2 NAAQS at the violating monitor with wind data from 

the Cincinnati Municipal Airport.

WRPLOT View - Lakes Environmental Software

WIND ROSE PLOT:

Campbell County, KY - Cincinnati Municipal Airport

2009-2011 Exceedance Hours - Monitor AQS ID# 21-037-3002

COMMENTS: COMPANY NAME:

U.S. EPA Region 4

MODELER:

Rick Gillam, 

APTMD/APB/AQMTS

DATE:

8/3/2012

PROJECT NO.:

NORTH

SOUTH

WEST EAST

6%

12%

18%

24%

30%

WIND SPEED 

(m/s)

 >= 11.1

 8.8 - 11.1

 5.7 - 8.8

 3.6 - 5.7

 2.1 - 3.6

 0.5 - 2.1

Calms: 0.00%

TOTAL COUNT:

18 hrs.

CALM WINDS:

0.00%

DATA PERIOD:

Start Date: 11/13/2009 - 14:00

End Date: 8/30/2011 - 13:00

AVG. WIND SPEED:

2.23 m/s

DISPLAY:

 Wind Speed

Direction (blowing from)
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Since the wind data from the Cincinnati Municipal Airport is not likely representative of winds at the 

violating monitor, EPA evaluated winds from the Cincinnati/Northern Kentucky Airport, which is 

located in similar terrain to the violating monitor location.

Figure 7 shows a wind rose of the hours exceeding the 1-hr SO2 NAAQS (75 ppb) at the violating 

monitor. The wind rose was developed using wind data from the Cincinnati/Northern Kentucky Airport. 

Since the Cincinnati Municipal Airport wind data is not likely representative of the winds at the 

violating monitor location, EPA evaluated wind data from the Cincinnati/Northern Kentucky Airport. 

As can be seen in Figure 5, the relatively flat terrain near the Cincinnati/Northern Kentucky Airport 

makes it likely to be generally representative of the wind patterns in the area. Figure 6 provides a wind 

rose of the 2009-2011 hours exceeding the 1-hr SO2 NAAQS at the violating monitor with wind data 

from the Cincinnati/Northern Kentucky Airport site.

Figure 5. Topographic Map showing the Cincinnati Municipal Airport in the Little Miami River Valley
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Figure 6 shows that the majority of the exceeding hours have winds blowing from the east with 

generally moderate wind speeds. As can be seen in Figure 3, the Duke Energy Beckjord facility is 

located approximately 18 kilometers east of the monitor. No other major sources are located near the 

violating monitor in the east direction. Therefore, the Duke Energy Beckjord facility is likely the major 

contributor to the violating monitor’s design value. 

In order to further evaluate potential contribution to the violating monitor, EPA performed a wind backtrajectory analysis using the National Oceanic and Atmospheric Administration (NOAA) Hybrid SingleParticle Lagrangian Integrated Trajectory (HYSPLIT)

1 model. The HYSPLIT back-trajectories were 

created using NOAA’s archived Eta Data Assimilation System, 40 kilometer grid resolution 

meteorological dataset (EDAS 40 kilometers). The back trajectories originated at the violating monitor 

location on each hour that corresponds to a measured exceedance of the 1-hr SO2 NAAQS and were 

 

1 Draxler, R.R. and Rolph, G.D., 2012. HYSPLIT (HYbrid Single-Particle Lagrangian Integrated Trajectory) Model access via 

NOAA ARL READY Website (http://ready.arl.noaa.gov/HYSPLIT.php). NOAA Air Resources Laboratory, Silver Spring, MD.

Figure 6. Wind Rose of 2009-2011 hours exceeding the 1-hr 

SO2 NAAQS at the violating monitor with wind data from 

the Cincinnati/Northern Kentucky Airport site.

WRPLOT View - Lakes Environmental Software

WIND ROSE PLOT:

Campbell County, KY - Cincinnati/Northern Kentucky Airport

2009-2011 Exceedance Hours - Monitor AQS ID# 21-037-3002

COMMENTS: COMPANY NAME:

U.S. EPA Region 4

MODELER:

Rick Gillam, 

APTMD/APB/AQMTS

DATE:

8/3/2012

PROJECT NO.:

NORTH

SOUTH

WEST EAST

5%

10%

15%

20%

25%

WIND SPEED 

(m/s)

 >= 11.1

 8.8 - 11.1

 5.7 - 8.8

 3.6 - 5.7

 2.1 - 3.6

 0.5 - 2.1

Calms: 34.38%

TOTAL COUNT:

30 hrs.

CALM WINDS:

34.38%

DATA PERIOD:

Start Date: 11/13/2009 - 18:00

End Date: 8/30/2011 - 17:00

AVG. WIND SPEED:

2.42 m/s

DISPLAY:

 Wind Speed

Direction (blowing from)
12

initialized at 100 meters above ground level with the “Model Vertical Velocity” model option. Figure 7

shows the results of the back-trajectory analysis. 

As can be seen in Figure 7, the results of the back-trajectory analysis generally agree with the surfacelevel wind analysis shown in the wind rose in Figure 6. The trajectory analysis shows that winds blow 

primarily from the east during hours exceeding the 1-hr SO2 NAAQS. This analysis supports the 

conclusion presented above that the Duke Energy Beckjord facility is likely the major contributor to the 

violating monitor’s design value. 

Figure 7. HYSPLIT Back-trajectory analysis of 2009-2011 hours exceeding the 1-hr SO2 NAAQS at the 

violating monitor
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Geography/Topography (mountain ranges or other air basin boundaries)

Campbell County does not have any geographical or topographical barriers significantly limiting airpollution transport within its air shed. Therefore, this factor did not play a significant role in 

determining the nonattainment boundary.

Jurisdictional Boundaries 

Once EPA identified the general areas that the Agency anticipated would be included in the 

nonattainment area, EPA then considered existing jurisdictional boundaries for the purposes of 

providing a clearly defined legal boundary and to help identify the areas appropriate for carrying out the 

air quality planning and enforcement functions for nonattainment areas. With regard to the 2010 SO2

NAAQS, EPA believes that the appropriate jurisdictional boundaries to be considered to include

counties, air districts, pre-existing nonattainment areas, reservations, among any other information 

deemed relevant to establishing appropriate area designations and boundaries for the 1-hour SO2

NAAQS.

No area in Campbell County has been or is currently designated nonattainment for a prior SO2 NAAQS, 

so EPA had no boundary related to a previous nonattainment designation to consider for this area. 

Additionally, this area does not include Indian Country. Therefore, EPA has identified major and 

established highways as well as a portion of the Ohio River to define a clearly identifiable boundary for 

the Kentucky portion of the nonattainment area.

The violating monitor is located in Campbell County, Kentucky; however, the largest nearby source of 

the SO2 is located across state lines in Clermont County, Ohio.

Other Relevant Information

EPA did not receive additional information, relevant to establishing a nonattainment area boundary for 

this Area.

Conclusion

After considering the factors described above, EPA finds that it is appropriate to include the portions of 

counties listed in Table 1 in the Campbell-Clermont, KY-OH area as the initial nonattainment area for 

the 2010 SO2 NAAQS, based on the violating monitor. The partial county boundary for Campbell

County includes the area contained within the following borders: 

Southeast: KY Hwy 1566 from Ohio River to KY Hwy 9 (AA Highway)

Southwest: KY Hwy 9 (AA Highway) from Hwy 1566 to I-275

Northwest: I-275 to Hwy 2345 (John’s Hill Road), Hwy 2345 to US-27, US-27 to I-275, I-275 to Ohio 

River

Northeast: Ohio River from I-275 to KY Hwy 1566
14

The air quality monitor in Campbell County shows a violation of the 2010 SO2 NAAQS, based on 2009-

2011 air quality data. Based on the consideration of all the relevant and available information, as 

described above, EPA is initially designating portions of Campbell County as described above, in 

conjunction with portions of Clermont County, Ohio, as nonattainment for the 2010 SO2 NAAQS. 

Areas and sources that we are not yet prepared to conclude are contributing to the monitored violation or 

other possible violations are not included in this initial nonattainment area. In a subsequent round of 

designations, we will further address such areas and sources and make final designations decisions for 

areas that are not currently included in the nonattainment areas addressed in this TSD.

Technical analysis for Jefferson County 

Introduction 

This technical analysis for Jefferson County identifies the monitor that violates the 2010 SO2 NAAQS 

based on 2009-2011 data, and evaluates nearby counties for contributions to SO2 concentrations in the 

area. EPA has evaluated this county and nearby counties based on the weight of evidence of the factors 

recommended in the March 24, 2011, issued EPA guidance. 

Figure 8 is a map of the area analyzed showing the location and design value of air quality monitors in 

the areas, and the counties surrounding any violating air quality monitors.

Figure 8
15

In June 2011, Secretary Leonard K. Peters recommended that Jefferson County (in its entirety) be 

designated as nonattainment for the 2010 SO2 NAAQS based on monitored air quality data from 2008-

2010. Secretary Leonard K. Peters provided an update to the original recommendation on December 20, 

2011, and January 15, 2013. In its updated recommendation, Kentucky recommended a partial county 

boundary around the Jefferson County monitor. Kentucky confirmed the earlier recommendations in a 

letter dated March 6, 2013. See Figure 9. Letter from Leonard K. Peters, Secretary, Kentucky Energy 

and Environment Cabinet, to Gwendolyn Keyes Fleming, Regional Administrator, USEPA, Region 4 

(June 2, 2011, and updated on December 20, 2011, and January 15, 2013) (on file with USEPA Region 

4 Regulatory Development Section).
16

Figure 9. Kentucky’s Proposed Nonattainment Area for Jefferson County

Based on EPA’s technical analysis described below, EPA is initially designating a portion of Jefferson 

County as nonattainment for the 2010 SO2 NAAQS based upon currently available information. The 

boundary for the Jefferson County Area is the same as recommended by Kentucky as identified in 

Figure 9 above. Areas and sources that we are not yet prepared to conclude are contributing to the 

monitored violations are not included in this initial nonattainment area.

Detailed Assessment

Air Quality Data 

This factor considers the SO2 air quality monitoring data, including the design values (in ppb) calculated 

for the air quality monitor in Jefferson County based on data for the 2009-2011period.

The 2010 SO2 NAAQS design values for Jefferson County and the surrounding area are shown in Table 

5.
17

Table 5. Air Quality Data for Nonattainment Designations in Commonwealth

County Commonwealth

Recommended

Nonattainment?

Monitor Name Monitor Air 

Quality 

System ID

Monitor 

Location

SO2 Design 

Value, 

2007 - 2009

(ppb)

SO2 Design 

Value, 

2008-2010

(ppb)

SO2 Design 

Value, 

2009-2011

(ppb)

Jefferson N/A Jefferson 211110051 117 112 112

Monitors in Bold have the highest 2009-2011 design value in the respective county.

Jefferson County shows a violation of the 2010 SO2 NAAQS. Therefore, some area in this county and 

possibly additional areas in surrounding counties must be designated nonattainment. The absence of a 

violating monitor alone is not a sufficient reason to eliminate nearby counties as candidates for 

nonattainment status. Each area has been evaluated based on the weight of evidence of the five factors 

and other relevant information. 

Emissions and Emissions-Related Data

Evidence of SO2 emissions sources in the vicinity of a violating monitor is an important factor for 

determining whether a nearby area is contributing to a monitored violation. For this factor, EPA 

evaluated county level emission data for SO2 and any growth in SO2 emitting activities since the date 

represented by those emissions data.

Emissions 

EPA recognizes that there may be important new information on emissions levels for the period 2008, 

and would consider more recent years if available. Kentucky provided emissions information which is 

included in Table 6 below.

Table 6 shows total emissions of SO2 (given in tpy) for violating and potentially contributing counties in 

and around Jefferson County and sources emitting (or anticipated to contribute) greater than 100 tons

per year of SO2 according to the 2008 NEI.
18

Table 6. SO2 Emissions [NEI08V3]

County Facility Located 

in 

Commonwealth

Recommended 

Nonattainment

Area?

Facility – Total 

SO2 Air

Emissions [2008 

NEI] 

(tons per year)

Facility 

Location

Total County SO2

Emissions 

(tons per year)

Jefferson Yes LGE, MCS

28,581

38.0531,

-85.91

41,333

Jefferson NoLGE, CRS

10,103

38.1828,

-85.8894

Jefferson NoOxy Vinyls

573

38.22022,

-85.82885

Jefferson NoLouisville Med

482

38.24937,

-85.74983

Jefferson NoKosmos Cement

304

38.03634,

-85.90869

Jefferson NoB-F Dist

252

38.20832,

-85.79272

Jefferson NoCarbide

150

38.22251,

-85.84046

Jefferson NoMcAlpine

145

38.27884,

-85.79078

Jefferson NoAmerican Rubber

120

38.20892,

-85.8458

Jefferson NoAirport

112

38.1846,

-85.7484

Emissions Controls

The emissions data used by EPA in this technical analysis and provided in Table 6 represent emissions 

levels taking into account any control strategies implemented on stationary sources in Jefferson County 

up to and including 2008. EPA has not received any additional information from the Commonwealth of 

Kentucky regarding emissions reductions resulting from controls put into place after 2008.

Meteorology (weather/transport patterns)

Evidence of source-receptor relationships between specific emissions sources and high SO2 values at 

violating monitors is another important factor in determining the appropriate contributing areas and the 

appropriate extent of the nonattainment area boundary. For this factor, EPA considered recent hourly 

meteorological data from the NWS site nearest to the violating monitor to determine which wind vectors 

were associated with 1-hour SO2 exceedances. For the Jefferson County Area, the meteorological data 

used in this analysis is for 2009-2011 from the Louisville Standiford Field Airport site (ID # 724230-

93821). The Louisville Standiford Field site is approximately 19 kilometers northeast of the southern 

violating monitor (AQS ID # 21-111-0051). The primary SO2 emissions source nearby the monitor is 

the Louisville Gas & Electric, Mill Creek Station facility, located approximately 1.5 kilometers 

southwest from the southern violating monitor.
19

Figure 10 shows a wind rose of the hours exceeding the 1-hr SO2 NAAQS (75 ppb) at the Jefferson 

County violating monitor (AQS ID # 21-111-0051). The wind rose was developed using wind data from 

the Louisville Standiford Field Airport site. 

Figure 10 shows that the majority of the exceeding hours have winds blowing from the southwest 

quadrant with moderate to high wind speeds. As can be seen in Figure 9 the Louisville Gas & Electric, 

Mill Creek Station facility is located approximately 1.5 kilometers southwest of the monitor. Therefore, 

the Louisville Gas & Electric, Mill Creek Station facility is likely the major contributor to the violating 

monitor’s design value. 

This analysis supports the conclusion presented above that the Louisville Gas & Electric, Mill Creek 

Station facility is likely the major contributor to the violating monitor’s design value.

Figure 10. Wind Rose of 2009-2011 hours exceeding the 1-

hr SO2 NAAQS at the Jefferson County violating monitor

(AQS ID # 21-111-0051).

WRPLOT View - Lakes Environmental Software

WIND ROSE PLOT:

Jefferson County, KY - Louisville Standiford Field Airport

2009-2011 Exceedance Hours - Monitor AQS ID# 21-111-0041

COMMENTS: COMPANY NAME:

U.S. EPA Region 4

MODELER:

Rick Gillam, 

APTMD/APB/AQMTS

DATE:

8/3/2012

PROJECT NO.:

NORTH

SOUTH

WEST EAST

3%

6%

9%

12%

15%

WIND SPEED 

(m/s)

 >= 11.1

 8.8 - 11.1

 5.7 - 8.8

 3.6 - 5.7

 2.1 - 3.6

 0.5 - 2.1

Calms: 0.00%

TOTAL COUNT:

49 hrs.

CALM WINDS:

0.00%

DATA PERIOD:

Start Date: 8/9/2009 - 12:00

End Date: 10/16/2011 - 16:00

AVG. WIND SPEED:

4.13 m/s

DISPLAY:

 Wind Speed

Direction (blowing from)
20

Geography/topography (mountain ranges or other air basin boundaries)

Jefferson County does not have any geographical or topographical barriers significantly limiting airpollution transport within its air shed. Therefore, this factor did not play a significant role in 

determining the nonattainment boundary.

Jurisdictional boundaries 

Once EPA identified the general areas that the Agency anticipated would be included in the initial 

nonattainment area, EPA then considered existing jurisdictional boundaries for the purposes of 

providing a clearly defined legal boundary and to help identify the areas appropriate for carrying out the 

air quality planning and enforcement functions for nonattainment areas. 

No area in Jefferson County has been or is currently designated nonattainment for a prior SO2 NAAQS, 

so EPA had no boundary related to previous nonattainment designations to consider for this area. 

Therefore, EPA has identified major and established roadways as well as a portion of the Ohio River and 

specific geographic coordinates to define a clearly identifiable boundary of the nonattainment area.

Other Relevant Information

EPA did not receive additional information, including modeling results, relevant to establishing a 

nonattainment area boundary for this area.

Conclusion

After considering the factors described above, EPA finds that it is appropriate to include the portion of 

Jefferson County listed in Table 1 as the initial nonattainment area for the 2010 SO2 NAAQS, based on 

the violating monitor information.

The air quality monitor in Jefferson County shows a violation of the 2010 SO2 NAAQS, based on 2009-

2011 air quality data. Based on the consideration of all the relevant and available information, EPA is 

initially designating the area within the boundary that borders the LGE Mill Creek Power Plant in the 

southern portion of Jefferson County as prescribed by the Commonwealth, encompassing the Watson 

Lane Monitor as shown in Figure 9 as nonattainment. The following is a complete description of the 

boundary.

The portion of Jefferson County contained within the following borders: 

North: Ethan Allen Way extended to the Ohio River at UTM Easting (m) 595738, UTM Northing 

4214086 and Dixie Highway (US60 and US31W) at UTM Easting (m) 59751, UTM Northing 

42129462; 

East: Along Dixie Highway from UTM Easting (m) 597515, UTM Northing 4212946 to UTM Easting 

(m) 595859, UTM Northing 4210678;

 

2 The UTM coordinates provided here have a reference datum of NAD 1983 UTM Zone 16N.
21

South: Near the adjacent property lines of Louisville Gas and Electric - Mill Creek Electric Generating 

Station and Kosmos Cement where they join Dixie Highway at UTM Easting (m) 595859, UTM 

Northing 4210678 and the Ohio River at UTM Easting (m) 595326, UTM Northing 4211014;

West: Along the Ohio River from UTM Easting (m) 595326, UTM Northing 4211014 to UTM Easting 

(m) 595738, UTM Northing 4214086.

Areas and sources that we are not yet prepared to conclude are contributing to the monitored violation or 

other possible violations are not included in this initial nonattainment area. In a subsequent round of 

designations, we will further address such areas and sources and make final designations decisions for 

areas and sources that are not currently included in the nonattainment area designation addressed in this 

TSD.