1
LAWRENCE
COUNTY,
KENTUCKY
Lawrence
County
is
south
of
the
Huntington­
Ashland
Metropolitan
Statistical
Area
(
MSA)
and
is
located
to
the
south
of
Boyd
County
and
to
the
southwest
of
Huntington,
West
Virginia.
The
Big
Sandy
River
forms
its
eastern
border.

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

 
EPA
indicates
that
Lawrence
County
has
significant
SO
x,
and
NO
x
emissions
from
a
power
plant
and
its
close
proximity
to
the
violating
MSA
monitors.

Emissions
Data
Lawrence
County,
Kentucky,
was
not
discussed
in
Kentucky s
February
recommendations.
Based
on
the
original
guidance
from
U.
S.
EPA
in
April
2003,
states
were
required
to
review
possible
emissions
contributions
for
counties
within
an
MSA
boundary,
if
a
monitor
within
the
MSA
was
in
violation
of
the
PM2.5
standard.
Later,
EPA
suggested
that
states
look
outside
the
MSA
boundaries
if
there
was
the
possibility
that
emissions
from
a
county
outside
the
MSA
were
having
a
significant
impact
on
monitors
within
the
MSA.
It
is
also
important
to
note
that
EPA
also
used
the
2001
NEI
data
which
provided
different
data
than
the
data
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
has
also
recommended
that
Adams,
Gallia,
and
Scioto
Counties
in
Southeastern
Ohio
and
Lawrence
County,
Kentucky,
also
be
included
as
nonattainment
areas
due
to
the
emissions
of
SOx,
NOx,
and
PM.

Adams
and
Gallia
Counties
alone
contribute
80%
of
all
SOx
within
the
counties
EPA
has
recommended
as
nonattainment
for
PM2.5.
By
comparison,
Lawrence
County
emits
only
15%
of
SOx
emissions
from
the
counties
recommended
by
EPA
as
having
the
potential
to
impact
the
violating
monitors.
A
similar
comparison
can
be
made
with
both
NOx
and
PM.
Lawrence
County s
NOx
and
PM
emissions
rank
at
11%
of
the
total
EPA
recommended
areas.
In
a
detailed
review
of
EPA s
recommended
nonattainment
areas,
Lawrence
County
ranks
consistently
at
less
than
or
equal
to
15%
of
combined
emissions
contributions
within
EPA s
proposed
nonattainment
boundaries.
See
Figures
1­
4
below.
2
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
Lawrence
County,
Kentucky
A
factor
not
taken
into
account,
either
in
the
1999
nor
2001
NEI
data
sets,
was
the
implementation
of
NO
x
controls
at
the
Big
Sandy
Power
Plant
in
Lawrence
County.
In
2003,
NO
x
emissions
were
dropped
substantially
by
the
installation
of
SCR
on
Unit
#
2
and
over
Fire
Air
Technology
employed
on
Unit
#
1.
The
operation
of
these
control
technologies
was
responsible
for
2,880
ton
reduction
in
NO
x
emissions
during
the
summer
ozone
season,
which
includes
the
quarters
where
Kentucky
typically
records
the
highest
PM2.5
levels.
The
implementation
of
these
controls
at
that
facility
even
further
reduces
the
potential
emission
contribution
to
monitors
in
question
in
Southeastern
Ohio
and
West
Virginia.

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).

The
first
phase
of
compliance
under
the
CAIR
rule
to
reduce
both
SO2
and
NOx
emissions
would
be
required
by
2010,
allowing
substantial
emission
reductions
in
the
area,
by
the
proposed
attainment
date
for
PM2.5
nonattainment
areas.

Monitoring
Data
and
Trends
As
can
been
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,

Lawrence
County,
Kentucky,
contributes
only
15%
of
the
SO2
in
the
area,
and
only
10%
of
the
organic
carbon
in
the
area
of
EPA
proposed
nonattainment
counties.
5
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
Lawrence,
KY
10%
Adams,
OH
20%

Gallia,
OH
30%

Lawrence,
OH
4%
Scioto,
OH
5%
Cabell,
WV
18%
Wayne,
WV
4%
Boyd,
KY
9%

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
14.9
µ
g/
m
3.
In
addition
to
showing
attainment
with
the
standard,
the
annual
6
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
Lawrence
County
does
not
have
a
monitor,
however,
the
PM2.5
levels
throughout
the
entire
region
have
been
steadily
decreasing
over
the
last
four
years.
Monitored
levels
have
decreased
by
11%
in
Boyd
County,
17%
in
Carter
County,
12%
in
Cabell
County,
WV,
17%
in
Lawrence
County,
OH,
and
30%
in
Scioto
County,
OH
(
See
Figure
10
below).
7
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%

Conclusions
Based
on
the
factors
discussed
above,
Kentucky
believes
that
Lawrence
County,
Kentucky
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.
Lawrence
County
would
not
have
the
potential
to
significantly
contribute
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.
8
 
Substantial
NO
x
emission
reductions
have
already
occurred
from
the
installation
of
controls
at
the
Big
Sandy
Power
Plant
in
Lawrence
County.

 
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.

To
have
this
county
designated
nonattainment
would
invoke
additional,
substantial,
and
unnecessary
requirements
on
local
government
planning
agencies.
Substantial
local
NO
x
emission
reductions
from
Lawrence
County
have
already
occurred.
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,
and
the
air
monitoring
data
demonstrating
attainment
of
the
PM2.5
Standard,
lead
to
the
conclusion
that
Lawrence
County,
Kentucky,
should
be
designated
attainment
for
the
PM2.5
Standard.
