1
BOYD
COUNTY,
KENTUCKY
Boyd
County
is
part
of
the
Huntington­
Ashland
Metropolitan
Statistical
Area
(
MSA)
and
is
located
to
the
south­
southeast
of
Greenup
County,
Kentucky,
and
to
the
east­
northeast
of
Carter
County,
Kentucky,
and
north
of
Lawrence
County,
Kentucky.

EPA s
June
29,
2004
proposal
on
appropriate
designations
for
Kentucky
included
Boyd
County
as
nonattainment
based
on
the
following
criteria:

 
EPA
indicates
that
Boyd
County
has
significant
SOx,
NOx,
and
PM
emissions,
in
close
proximity
to
the
violating
MSA
monitors
and
that
anticipated
controls
would
not
be
implemented
until
after
designations
are
made;

 
Even
though
Boyd
County
has
monitoring
data
very
close
to
the
standard,

EPA
states
that
this
indicates
a
potential
to
contribute
to
the
PM2.5
violations
in
the
area;

 
EPA
indicates
that
the
population
and
population
density
of
Boyd
County
has
a
potential
to
contribute
to
the
PM2.5
violations
in
the
area.

Emissions
Data
In
Kentucky s
February
recommendations,
1999
NEI
data
was
used
in
the
original
analysis.
As
stated
in
the
General
Comments
portion
of
this
document,
EPA
had
recommended
that
states
use
the
1999
data
since
it
was
the
latest
available
to
states
at
that
time.

It
is
important
to
note
here
that
EPA,
in
their
review,
used
the
2001
NEI
data
which
provided
different
data
than
what
EPA
had
recommended
that
states
use.
The
2001
NEI
data,
nor
the
methodology
used
in
the
calculations
for
that
inventory
have
been
made
available
to
states
for
review.

However,
in
EPA s
June
29,
2004
letters
to
states,
EPA
looked
outside
the
original
MSA
boundaries
to
determine
if
large
emissions
contributions
from
adjacent
areas
were
having
an
impact
on
PM2.5
levels
in
many
of
the
areas.
Specifically,
in
the
Huntington­
Ashland
metropolitan
area,
EPA
in
a
separate
letter
to
Ohio,
has
also
recommended
that
Adams,
Gallia,
and
Scioto
Counties
in
Southeastern
Ohio
also
be
included
as
nonattainment
areas
due
to
the
substantial,
significant
emissions
of
SOx,
NOx,
and
PM
from
those
counties.

Adams
and
Gallia
Counties
alone
contribute
80%
of
all
SOx
within
the
counties
EPA
has
recommended
as
nonattainment
for
PM2.5.
By
comparison,
Boyd
County
emits
only
3%
of
SOx
emissions
from
the
counties
recommended
by
EPA
as
having
the
potential
to
impact
the
violating
monitors.
A
similar
comparison
2
can
be
made
with
both
NOx
and
PM.
Boyd
County s
NOx
emissions
rank
at
7%
of
the
total
EPA
recommended
areas,
and
PM
at
9%.
In
a
detailed
review
of
EPA s
recommended
areas
to
be
designated
nonattainment,
Boyd
County
ranks
consistently
at
less
than
10%
of
combined
emissions
contributions
within
EPA s
proposed
nonattainment
boundaries.
See
Figures
1­
4
below.

Figure
1
Ashland
Area
SOx
Emissions
in
EPA
Proposed
Nonattainment
Counties
Scioto,
OH
1%
Lawrence,
OH
0%

Cabell,
WV
1%
Wayne,
WV
0%
Boyd,
KY
3%
Lawrence,
KY
15%
Adams,
OH
34%
Gallia,
OH
46%

Figure
2
Ashland
Area
NOx
Emissions
in
EPA
Proposed
Nonattainment
Counties
Scioto,
OH
3%
Lawrence,
OH
2%
Lawrence,
KY
11%
Adams,
OH
27%
Gallia,
OH
33%

Cabell,
WV
14%
Wayne,
WV
3%
Boyd,
KY
7%
3
Figure
3
Ashland
Area
PM
Emissions
in
EPA
Proposed
Nonattainment
Counties
Lawrence,
OH
3%
Scioto,
OH
4%
Cabell,
WV
9%
Wayne,
WV
2%
Boyd,
KY
9%
Lawrence,
KY
11%
Adams,
OH
24%
Gallia,
OH
38%

Figure
4
0
20,000
40,000
60,000
80,000
100,000
120,000
140,000
160,000
T
o
n
s
P
e
r
Y
e
a
r
Adams,
OH
Gallia,
OH
Lawrence,
OH
Scioto,
OH
Cabell,
WV
Wayne,
WV
Boyd,
KY
Lawrence,
KY
EPA
Proposed
Nonattainment
Counties
Emissions
2001
PM
SOx
NOx
VOC
NH3
Carbon
Crustal
4
Additional
Emission
Reductions
in
Boyd
County
EPA s
response
to
Kentucky
also
stated
that
the
additional
controls
documented
in
the
February
submittal
at
Calgon
Carbon
and
Catlettsburg
Refining,
LLC
were
not
being
considered
due
to
the
implementation
date
being
at
the
end
of
2005,
well
after
designations
are
made.
Kentucky
offers
the
following
additional
information.

Calgon
Carbon
Corporation
Emission
reductions
documented
at
Calgon
Carbon
occurred
in
2002
with
the
shut
down
of
the
C
line
activators.

Additional
sulfur
dioxide
emission
limits
and
operating
restrictions
have
been
imposed
on
Calgon
Carbon
Corporation,
a
facility
that
has
the
potential
to
contribute
to
PM2.5
levels
in
the
area,
by
the
issuance
of
Title
V
permit
V­
00­
015,
issued
April
27,
2004.
Calgon
Carbon
shutdown
its
C­
Line
Activators
in
2002
thus
creating
significant
actual
SO2
reductions
which
have
not
been
documented
in
the
2001
NEI
data
used
by
U.
S.
EPA
in
the
June
emissions
analysis.

Additionally,
the
current
permit
requires
that
sulfur
dioxide
controls
of
at
least
90%
efficiency,
which
results
in
304
tons
per
year
decrease,
be
in
place
if
these
Activators
are
ever
re­
started.
In
addition,
the
Package
Boiler s
allowable
SO2
emissions
have
been
reduced
by
the
requirement
that
only
natural
gas
be
used
as
fuel.
Previously
the
use
of
fuel
oil
was
permitted.
See
reductions
noted
in
Table
1
and
Figure
5
below.

This
permit
can
be
found
on
the
Kentucky
Division
for
Air
Quality
website
at:
http://
www.
air.
ky.
gov/
NR/
rdonlyres/
C2470F5E­
8021­
43E6­
BF33­
5268DB5503F1/
0/
FinalR2_
3104.
pdf
Table
1
Reductions
for
Calgon
Carbon
Corporation
Pollutant
Original
Actual
(
tpy)
New
Permitted
Actual
(
tpy)
Actual
Emission
Reductions
(
tpy)

PM
10
897
159
738
SO
2
822
121
701
NOx
204
154
50
VOC
11
4
7
5
Figure
5
0
100
200
300
400
500
600
700
800
900
T
o
n
s
P
e
r
Y
e
a
r
Original
Actual
Original
Potential
Revision
2
Actual
Revision
2
Potential
Calgon
Carbon
Reductions
in
2004
Title
V
Permit
PM
10
SO
2
NOx
VOC
Although
there
is
some
indication
that
the
NOx
emissions
in
the
latest
permit
have
the
potential
to
increase,
actual
NOx
emissions
are
anticipated
to
remain
below
the
original
potential
emissions
levels.
Additionally,
speciation
monitoring
data
for
the
Ashland
area
show
that
the
PM
2.5
levels
in
the
area
are
primarily
SOx
and
carbon
related.

Catlettsburg
Refining,
L.
L.
C.

Catlettsburg
Refining,
L.
L.
C.
is
undergoing
a
project
entitled
the
Refinery
Modernization
Project,
which
involves
new
operational
and
emissions
limitations.
The
proposed
Refinery
Modernization
Project
involves
installation
of
new
equipment
and
upgrading
of
existing
equipment.
This
will
allow
the
refinery
to
produce
cleaner­
burning
transportation
fuels,
to
improve
yields,
to
utilize
a
wider
range
of
purchased
feed
materials,
and
to
reduce
fixed
and
operating
costs.
In
addition,
the
project
will
substantially
reduce
emissions
of
SO2
and
NOx
from
the
refining
operations
mainly
due
to
the
fact
that
the
new
catalytic
cracker
will
now
be
subject
to
much
more
stringent
New
Source
Performance
Standards.

The
following
actual
emission
reductions
are
expected
to
occur
by
2006
(
see
Figure
6
below):
PM
­
33
tons
per
year
(
decrease)
PM10
­
33
tons
per
year
(
decrease)
SO2
­
3,605
tons
per
year
(
decrease)
NOX
­
730
tons
per
year
(
decrease)
CO
­
4
tons
per
year
(
decrease)

VOC
­
64
tons
per
year
(
decrease)
6
The
most
recent
modification
to
the
permit
that
requires
these
limitations
was
issued
June
4,
2004,
and
can
be
found
on
the
Kentucky
Division
for
Air
Quality
website
at:
http://
www.
air.
ky.
gov/
NR/
rdonlyres/
6EB5FA41­
A66E­
4097­
A763­
7936B5FB6EFF/
0/
DraftR2.
pdf
Figure
6
­
4000
­
3500
­
3000
­
2500
­
2000
­
1500
­
1000
­
500
0
T
o
n
s
P
e
r
Y
e
a
r
PM
10
SO
2
NOx
VOC
Catlettsburg
Refining,
L.
L.
C.
Reductions
in
Permit
VF­
02­
001
Revision
2
2004
Reduction
Although
these
controls
will
not
be
implemented
before
designations,
the
reductions
are
an
ongoing
process
and
will
be
implemented
before
any
control
strategies
are
required
to
be
submitted
to
U.
S.
EPA
in
2008.

Additional
Regional/
National
Controls
The
implementation
of
new
federal
rules
to
decrease
the
amount
of
sulfur
in
both
gasoline
and
diesel
fuel
will
significantly
decrease
the
amount
of
SO2
in
the
entire
area.
Because
of
the
Low
Sulfur
Diesel
Rule,
in
2007,
new
clean
engines
operating
on
15­
ppm
sulfur
diesel
fuel
will
reduce
NOx
emissions
by
50%,
and
reduce
PM
emissions
by
more
than
90%.
Due
to
the
Tier
2
Vehicle
and
Gasoline
Sulfur
program,
by
2006
average
national
gasoline
sulfur
levels
will
be
90%
lower.

Upon
implementation
of
the
Clean
Air
Interstate
Rule
(
CAIR)
SO2
emissions
from
power
plants
will
be
reduced
nationwide
by
3.6
million
tons
in
2010
(
approximately
40
percent
below
current
levels)
and
by
another
2
million
tons
per
year
when
the
rules
are
fully
implemented
(
approximately
70
percent
below
current
levels).
NOx
emissions
would
be
cut
by
1.5
million
tons
nationwide
in
2010
and
1.8
million
tons
annually
in
2015
(
about
65
percent
below
today s
levels).
7
The
first
phase
of
compliance
under
the
CAIR
rule
to
reduce
both
SO2
and
NOx
emissions
would
be
required
by
2010,
the
proposed
attainment
date
for
PM2.5
nonattainment
areas,
allowing
substantial
emission
reductions
in
the
area.

Monitoring
Data
&
Trends
As
can
be
seen
in
Figure
7
below,
the
speciation
data
from
Kentucky s
Ashland
speciation
monitor
indicates
that
sulfate
and
organic
carbon
are
the
major
components
of
the
PM2.5
values.
In
Figure
1
above
and
Figure
8
below,
Boyd
County,
Kentucky,
contributes
only
3%
of
the
SO2
in
the
area,
and
only
9%
of
the
organic
carbon
within
EPA s
proposed
nonattainment
counties.

Figure
7
Ashland
Speciation
Data
12/
9/
01
­
12/
11/
03
Average
Concentration
(
µ
g/
m
³
)

Elemental
carbon
4%
Crustal
component
3%

Organic
carbon
28%
Ammonium
10%
Sulfate
32%
Nitrate
7%
Other
16%

Figure
8
Ashland
Area
Carbon
Emissions
in
EPA
Proposed
Nonattainment
Counties
Boyd,
KY
9%

Wayne,
WV
4%

Cabell,
WV
18%

Scioto,
OH
5%
Lawrence,
OH
4%
Gallia,
OH
30%
Adams,
OH
20%
Lawrence,
KY
10%

As
EPA
notes
in
its
June
29,
2004
letter,
the
monitor
located
in
Boyd
County
shows
attainment
with
the
PM2.5
standard,
with
a
2001­
2003
design
value
of
8
14.9
µ
g/
m
3
.
In
addition
to
showing
attainment
with
the
standard,
the
annual
concentrations
continue
to
show
a
downward
trend
as
depicted
in
Figure
9
below,
which
utilized
data
from
the
year
2000
through
April
2004.

Figure
9
Ashland
Area
PM
2.5
Trend
Utilizing
Most
Current
Available
Data
9.0
11.0
13.0
15.0
17.0
19.0
21.0
23.0
2000
2001
2002
2003
2004
Year
A
n
n
u
a
l
A
r
i
th
m
e
t
i
c
M
e
a
n
(
m
ic
r
o
g
r
a
m
s
/
c
u
b
i
c
m
e
t
e
r
)

Boyd,
KY
Carter,
KY
Cabell,
WV
Lawrence,
OH
Scioto,
OH
PM2.5
levels
throughout
the
entire
region
have
been
steadily
decreasing
over
the
last
four
years.
Specifically,
the
PM2.5
levels
in
Boyd
County
have
decreased
by
11%,
Carter
County s
levels
have
decreased
by
17%,
12%
in
Cabell
County,
17%
in
Lawrence
County,
and
30%
in
Scioto
County
(
See
Figure
10
below).
9
Figure
10
0.0
5.0
10.0
15.0
20.0
25.0
Boyd,
KY
Carter,
KY
Cabell,
WV
Lawrence,
OH
Scioto,
OH
Decline
in
PM
Values
for
Ashland
Area
2000
2001
2002
2003
2000­
2003
shows
decrease
of
11%
2000­
2003
shows
decrease
of
17%
2000­
2003
shows
decrease
of
12%
2000­
2003
shows
decrease
of
17%
2000­
2003
shows
decrease
of
30%

Population
Density
and
Growth
EPA
stated
that
2002
population
levels
indicated
Boyd
County
had
the
potential
to
impact
PM2.5
violations
in
the
area.
Although
Boyd
County
has
the
third
largest
population
in
the
MSA,
it
makes
up
only
16%
of
the
population
in
the
entire
MSA
and
only
12%
when
compared
to
the
West
Virginia
and
Ohio
counties
proposed
for
nonattainment,
see
Figure
11
below.

Figure
11
2002
Population
of
Counties
Recommended
for
Nonattainment
for
PM2.5
by
EPA
Scioto,
OH
19%

Cabell,
WV
24%

Wayne,
WV
11%
Lawrence,
OH
15%
Lawrence,
KY
4%
Boyd,
KY
12%

Gallia,
OH
8%

Adams,
OH
7%
10
Additionally,
the
2000
census
data
indicates
Boyd
County s
population
from
1990
through
2000
decreased
by
approximately
2.7%
(
51,150
to
49,752).
The
population
is
further
projected
to
decrease
by
an
additional
3.2%
between
2000
and
2010.

Therefore,
Kentucky
believes
that
the
population
in
Boyd
County
does
not
have
the
potential
to
contribute
to
PM2.5
violations
in
the
area.

Conclusion
Based
on
the
factors
discussed
above,
Kentucky
believes
that
Boyd
County
should
be
designated
attainment
for
the
PM2.5
standard.

 
Kentucky
believes
that
EPA s
use
of
the
weighted
emissions
scoring
approach
was
skewed.
EPA
did
not
include
adjacent
county
emissions
in
the
total
emissions
being
analyzed
for
the
area.
If
the
emissions
from
the
entire
area
under
review
were
used,
vs
just
those
within
the
MSA,
a
very
different
result
in
the
weighted
emissions
scores
would
have
occurred.
Boyd
County
would
not
have
the
potential
to
contribute
significantly
to
PM2.5
levels
within
the
region.

 
PM2.5
levels
continue
to
decline
throughout
the
entire
region.
From
a
review
of
all
monitors
in
the
region,
an
average
17%
decline
in
PM2.5
levels
has
occurred
from
2000
through
2003.
Every
monitor
in
the
region
is
currently
showing
values
well
within
attainment
of
the
annual
PM2.5
standard
using
2002
through
2004
data.

 
The
population
of
Boyd
County
is
not
significant
enough
to
have
the
potential
to
impact
PM2.5
levels
in
the
region.
Population
in
this
area
has
shown
a
continuing
decline
over
the
last
several
years
and
that
decline
is
anticipated
to
continue.
Boyd
County s
population
actually
represents
only
16%
of
the
actual
MSA
and,
when
compared
with
the
population
of
the
counties
proposed
by
EPA
for
nonattainment,
only
12%
of
the
total
population.

 
Additional
emission
reductions
on
a
national
and
regional
level
will
provide
substantial
benefits
in
the
region.
The
anticipated
sulfur
reductions
due
to
the
Low
Sulfur
Diesel
Rule,
the
Tier
2
Vehicle
and
Gasoline
Sulfur
programs,
and
the
Clean
Air
Interstate
Rule
(
CAIR)
will
further
lower
pollutant
levels
within
this
region.

 
The
substantial
emission
reductions
that
have
already
occurred
from
Calgon
Carbon,
and
those
that
will
occur
at
the
Catlettsburg
Refining
operations
result
in
over
4,000
tons
of
SO2
being
removed
from
the
area
every
year,
bringing
total
for
Boyd
County
well
below
EPA s
10,000
TPY
11
significance
level
for
any
one
pollutant.
These
controls
have
been
made
permanent
and
enforceable
and
will
provide
long­
term
emission
reductions
to
the
region.

To
have
this
county
designated
nonattainment
would
invoke
additional
substantial
and
unnecessary
requirements
on
local
government
planning
agencies.
Substantial
local
emission
reductions
from
Boyd
County
have
already
occurred,
or
will
occur
well
before
attainment
dates
for
this
standard.
Drastic
emission
reductions
are
scheduled
to
occur
in
the
mobile
sector
throughout
the
next
several
years
that
will
greatly
impact
pollutant
levels
in
the
area.
In
addition,
reductions
anticipated
by
the
CAIR
provisions,
the
air
monitoring
data
demonstrating
attainment
of
the
PM2.5
Standard,
and
the
decline
in
PM2.5
levels
throughout
the
entire
region,
lead
to
the
conclusion
that
Boyd
County,
Kentucky,
should
be
designated
attainment
for
the
PM2.5
Standard.
