In February 2004, Kentucky recommended that Fayette County be designated attainment for the PM2.5 standard for the Lexington, KY MSA, and the remaining MSA counties be designated attainment. EPA agrees that Fayette County should be designated nonattainment for PM2.5 due to a violating monitor ( South Limestone). EPA is modifying Kentucky's recommendation to 6 203 include the MSA counties of Clark, Madison and Woodford and the adjacent county of Mercer in the Lexington nonattainment area. Clark and Madison Counties are included significant emissions. Madison County also has relatively high population and population growth, and relatively high VMT. Woodford County as nonattainment due to the level of emissions. We have included in our recommended nonattainment area Mercer County that is adjacent to the Lexington MSA with a violating monitor, that is generally rural in character, and that contains an identifiable large emitting facility ( e. g., power plants) which we believe contributes to the nearby nonattainment problem. We have included this county in our initial recommendations in order to ensure that a sufficient portion of this county, including such a large facility, is included within the boundaries of the nonattainment area as part of the final designations. We invite you to submit to us a recommendation as to what portion of this adjacent county, encompassing the large facility, should be designated nonattainment. EPA agrees that the remaining MSA Counties of Bourbon, Jessamine, and Scott in Kentucky be designated attainment/ unclassifiable due to their relatively low emissions, low populations, low VMT, low numbers of commuters into the violating counties, and small point sources.

EPA agrees that the adjacent county of Pulaski should be designated attainment/ classifiable for the PM2.5 standard, although it has significant emissions due to a power plant. This county has relatively low population, low population growth, and low VMT. Further, the commuting patterns and distance from the violating monitors indicate that this county does not contribute to the violations in the area. The other adjacent counties do not contribute and therefore, will be designated as attainment/ unclassifiable.

The recommendations of EPA and Kentucky are summarized in the table below.

Area EPA Recommendation State Recommendation Lexington, KY Full counties: Fayette County Clark County Madison County Mercer County Woodford County Full counties: Fayette Drop: Bourbon, Clark, Madison, Jessamine, Woodford and Scott Counties The following is a brief summary of the nine criteria for the Lexington, KY area. These analyses were based on existing available data.

Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has the 2001 PM2.5, SOx, NOx, VOC, and ammonia emissions in tons and Weighted Emissions Scores for the counties in the Lexington MSA and surrounding counties. ( MSA counties in Kentucky are in bold.)

County PM SOx NOx VOC Amm Score Cum. Score Fayette ( KY) 1703 3925 13620 15720 606 31.4 31.4 Clark ( KY) 1132 9647 6622 2374 398 25.7 57.1 6 204 Madison ( KY) 867 1189 5512 4215 641 13.6 70.7 Woodford ( KY) 559 2663 3530 2852 427 9.5 80.2 Scott ( KY) 627 260 3629 6041 481 7.9 88.1 Jessamine ( KY) 504 323 2189 2436 242 7.6 95.7 Bourbon ( KY) 444 147 1424 1352 597 4.3 100.0 Mercer ( KY) 3136 49269 9145 1686 409 83.8 N/ A Pulaski ( KY) 2403 25156 10996 3901 877 56.8 N/ A Laurel ( KY) 770 1044 4564 3823 439 14.6 N/ A Nelson ( KY) 781 497 2134 7923 1147 10.3 N/ A Based on the analysis for this factor, the following counties appear to have significant emissions ( over 10,000 tons per year of any pollutant): Fayette, Mercer and Pulaski. Clark, Madison, and Woodford also have significant level of emissions. Although Pulaski County This factor did not appear significant for the remaining counties listed in this table.

Factor 2: Air quality in potentially included versus excluded areas County 2001 2003 design value Fayette ( KY) 15.7 Madison ( KY) 13.5 Laurel ( KY) 12.6 Based on the analysis for this factor, only Fayette County's South Lomestone monitoring data exceeds the standard. The Newtown Pike monitor, also in Fayette County, is attaining at 14.9. Madison County and the adjacent county of Laurel have monitors with readings well below the standard. This factor is not significant for the remaining counties listed in the area.

Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table has the populations for the counties in the Lexington MSA and adjacent counties with significant emissions. The total MSA 2002 population is 489,717. ( MSA counties are in bold.)

County 2002 Population Percent of Total MSA Population Population Density Fayette ( KY) 263,618 53.83 925 Clark ( KY) 33,726 6.89 133 Madison ( KY) 73,334 14.97 166 Woodford ( KY) 23,403 4.78 123 Scott ( KY) 35,320 7.21 124 Jessamine ( KY) 40,740 8.32 235 Bourbon ( KY) 19,576 4.0 67 Mercer ( KY) 21,047 84 Laurel ( KY) 54,313 125 Nelson ( KY) 38,823 92 Fayette County's population is roughly 3 11 times higher than the other counties listed. Madison County has the second highest of the MSA counties and surrounding counties with significant 6 205 weighted emissions scores. Based on an analysis of this factor, no other Kentucky counties, with the exception of Madison County, have populations significant to indicate a potential contribution to the PM2.5 violations in Fayette County.

Factor 4: Traffic and commuting patterns Commuting Information Total number of workers in Fayette County, KY: 136,793 Commuters in Fayette County, KY who work in Fayette County, KY: 117,584 ( 86%)

Total number of workers in Bourbon County, KY: 9,103 Commuters in Bourbon County, KY who work in Bourbon County, KY: 4,764 ( 52%) Commuters from Bourbon County, KY to Fayette County, KY: 2,600 ( 29%)

Total number of workers in Clark County, KY: 15,487 Commuters in Clark County, KY who work in Clark County, KY: 8,492 ( 55%) Commuters from Clark County, KY to Fayette County, KY: 4,777 ( 31%)

Total number of workers in Jessamine County, KY: 18,885 Commuters in Jessamine County, KY who work in Jessamine County, KY: 8,721 ( 46%) Commuters from Jessamine County, KY to Fayette County, KY: 8,748 ( 46%)

Total number of workers in Madison County, KY: 34,494 Commuters in Madison County, KY who work in Madison County, KY: 24,061 ( 70%) Commuters from Madison County, KY to Fayette County, KY: 6,870 ( 20%)

Total number of workers in Scott County, KY: 16,536 Commuters in Scott County, KY who work in Scott County, KY: 10,148 ( 61%) Commuters from Scott County, KY to Fayette County, KY: 4,287 ( 26%)

Total number of workers in Woodford County, KY: 12,377 Commuters in Woodford County, KY who work in Woodford County, KY: 5,591 ( 45%) Commuters from Woodford County, KY to Fayette County, KY: 4,308 ( 35%)

Total number of workers in Laurel County, KY: 21,180 Commuters in Laurel County, KY who work in Laurel County, KY: 16,286 ( 77%)

Total number of workers in Mercer County, KY: 9,610 Commuters in Mercer County, KY who work in Mercer County, KY: 5,235 ( 54%) Commuters from Mercer County, KY to Fayette County, KY: 1,319 ( 14%)

Total number of workers in Nelson County, KY: 17,594 Commuters in Nelson County, KY who work in Nelson County, KY: 11,189 ( 64%) 6 206 Madison County has the largest number of workers commuting into Fayette County ( 6,870 commuters), which is relatively insignificant for such a large county as Fayette. Laurel and Nelson County workers do not commute into the Lexington MSA at all. Based on the analysis for this factor, there are no counties with commuting data showing a potential to contribute to the PM2.5 violations in Fayette County.

Vehicle Miles Traveled:

The following table has the vehicle miles traveled ( thousand miles) for the counties in the Lexington MSA and adjacent counties with significant emissions. ( Kentucky MSA counties are in bold.)

County 2002 VMT Fayette ( KY) 2764 Clark ( KY) 523 Madison ( KY) 944 Woodford ( KY) 311 Scott ( KY) 645 Jessamine ( KY) 362 Bourbon ( KY) 204 Mercer ( KY) 224 Laurel ( KY) 852 Nelson ( KY) 427 Fayette County's VMT is substantially higher than the other MSA counties. Although Madison and Laurel Counties have the second and third highest VMT of the counties analyzed, commuting data do not indicate significant ( or any) contributions to Fayette County. Further, Laurel County is a significant distance from Fayette County and does not contribute to Fayette County through its commuting patterns. Based on the analysis for this factor, no other Kentucky counties, with the exception of Madison County, have VMT and commuting data with a potential to contribute to the PM2.5 violations in Fayette County.

Factor 5: Expected growth The following table has the population and population growth figures for the Lexington MSA and adjacent counties with significant emissions. ( MSA counties are in bold.)

County 2002 Population growth ( 90 00) % growth ( 90 00) Fayette ( KY) 263618 35,146 16 Clark ( KY) 33726 3,648 12 Madison ( KY) 73334 13,364 23 Woodford ( KY) 23403 3,253 16 Scott ( KY) 35320 9,194 39 Jessamine ( KY) 40740 8,533 28 Bourbon ( KY) 19576 124 1 Mercer ( KY) 21047 1,669 9 6 207 Laurel ( KY) 54313 9,277 21 Nelson ( KY) 38823 7,767 26 Fayette County's population is substantially higher than the MSA counties and adjacent counties with significant weighted emissions scores, and grew the most during the 1990 2000 time period. Madison County is the third fastest growing county in the MSA based on a percent growth rate with the second largest population and the second largest population increase. Thus, Madison County's population growth is significant enough to contribute to PM2.5 violations in Fayette County. None of the other MSA and adjacent counties listed above have population characteristics which appear to be contributing to the PM2.5 violations in Fayette County.

Factor 6: Meteorology The following meteorological information was provided by Kentucky. The figure referenced is a wind rose for April 1 October 31 for the 1988 1992 period that is provided in Kentucky's PM2.5 recommendations submittal. The text below is the same for Fayette, Bourbon, Clark, Jessamine, Scott, and Woodford Counties.

" Wind speed/ wind direction information shows that the majority of the time for the period 1988   1992, the wind in the... County area came from the southwest and typically from 7 10 knots. ( See figure 1 A) The mean high temperature for July for the area from 1961 through 1990 was 86

F and the mean low was 66

F. The mean precipitation for the same period was 4.8 inches." ( Source: KY submittal)

For Madison County, the following statement preceded the excerpted paragraph above:

Due to the close proximity of Lexington, Kentucky, meteorological data from Lexington was used for the Madison county area."

This factor did not play a significant role in the decision making process. The submitted information was only for the summertime winds.

Factor 7: Geography/ topography Based on an analysis of this factor, there are no significant topographical issues associated with this MSA.

Factor 8: Jurisdictional boundaries No county in the Lexington MSA was designated nonattainment for the 8 hour ozone standard on April 15, 2004. This factor did not play a significant role in the decision making process. 6 208 Factor 9: Level of control of emission sources The following information was provided by Kentucky for Fayette, Bourbon, Clark, Jessamine, Madison, Scott, Woodford Counties.

" Point sources located within... County are subject to PSD requirements, CTG RACT requirements, Maximum Achievable Control Technology ( MACT) requirements for sources of Hazardous Air Pollutants, and New Source Performance Standards ( NSPS)." ( Source: KY PM2.5 submittal)

This factor did not play a significant role in the decision making process.

Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States EPA's initial nonattainment recommendations on June 29, 2004, include the MSA counties of Clark, Madison, and Woodford and the adjacent county of Mercer. Upon further review of additional information provided by Kentucky, EPA is revising its recommendations and designating Clark, Madison, and Woodford Counties as attainment/ unclassifiable. EPA is designating a portion of Mercer County as nonattainment and the remainder of the county as attainment/ unclassifiable.

The additional analysis provided by Kentucky indicated that there is a strong localized effect on the violating monitor in Fayette County. Fayette County has two monitors located in Lexington, Kentucky which are 1.9 miles apart, with one violating at a design value of 15.6 and one attaining at a design value of 14.9. The supplemental submittals from Kentucky provided additional data and analysis to demonstrate that the monitor located on the University of Kentucky's ( UK) campus is violating due to localized impacts. These local impacts include: emissions from 112 UK boilers fueled by coal and natural gas; 13 major construction projects on the UK campus which began as early as December 1999 and have just been completed or are in process; and several, nearby downtown construction projects in Lexington. All of the construction projects in the area are one to six blocks from the violating monitor.

Clark County, KY:

Clark County's population of 33,726 people and VMT of 523,000 are very small in comparison to those of Fayette County, whose population, commuters, and VMT are substantially higher than those of the other MSA counties. In contrast, Fayette County, with one violating monitor, has a population of 263,618 and VMT of 2,764,000. Clark County has no monitor. Clark County's population comprises only 6.9% of the total MSA population. In addition, Clark County has a low number of workers ( 4,777) commuting to the violating MSA County of Fayette and whose 15,487 workers account for just 6.4% of the total number of MSA workers.

Clark County's total emissions are, in tpy ( and % of the MSA emissions): 1,132 PM ( 19.4%), 9,647 SO2 ( 53.1%), 6,622 NOx ( 18.1%), and 2,374 VOC ( 6.8%). Clark County does contain a small outlying power plant, East Kentucky Power, with 2001 emissions of 6,846 tpy of SO2 and 6 209 1,910 tpy of NOx. These factors in combination with Kentucky's localized impact analysis indicate Clark County's emissions are not contributing to the PM2.5 violation at the one monitor in Fayette County.

Madison County, KY:

Madison County has no large point sources and the design value of its attaining monitor is 13.4. The County has a relatively small population of 73,334 and a low number of VMT of 944,000 in comparison to Fayette, the violating county, whose population is 263,618 and VMT is 2,764,000. Madison County workers account for only 14.2% of the total number of commuters in the MSA. In addition, 70% of the County's workers commute within Madison County.

Woodford County, KY:

Woodford County has relatively low emissions and no monitor. Specifically, County emission totals are, in tpy ( and % of the MSA emissions): 559 tpy PM ( 9.6%), 2,663 tpy SO2 ( 14.7%), 3,530 tpy NOx ( 9.7%), and 2,852 tpy VOC ( 8.2%). While there is a small Kentucky Utilities power plant, the highest emissions from this plant are only 1,117 tpy NOx and 2,087 tpy SO2. In addition, the County has a very small population of 23,403 and accounts for only 5.1% of all the commuters in the MSA. Only 5,020 workers from Woodford County commute to other counties in the MSA. These factors in combination with Kentucky's localized impact analysis indicate Woodford County's emissions are not contributing to the PM2.5 violation at the one monitor in Fayette County.

Mercer County, KY:

In the June 29, 2004, letters from EPA to the States responding to their designation recommendations, EPA recommended the designation of a number of counties primarily because of high pollutant emissions from power plants. Most of these plants were located in nearby counties adjacent to the metropolitan area ( as defined either by the 1999 or 2003 OMB metropolitan area definitions). EPA suggested that a State could provide a partial county boundary that would encompass the relevant power plant to include it in the nonattainment area. Mercer County is one of those counties.

Mercer County has low population ( 21,047 compared to 263,618 in Fayette County where the city of Lexington is located), low population density ( 84 people per square mile compared to 925 in Fayette County), low VMT ( 224,000 compared to 2,764,000 in Fayette County), and the only large point source is Kentucky Utilities' E. W. Brown facility. Mercer County has no monitor.

A number of states responded to this suggestion with a series of connected townships or other unique boundaries. Some states also suggested an alternative approach in which partial county areas for power plants in some cases could be small " free standing" boundaries that are considered part of the nearby nonattainment area. In this way, it would not be necessary to include additional townships or other minor civil divisions comprising an odd shaped " land connector" extending from the main part of the nonattainment area to the power plant. The 6 210 Commonwealth of Kentucky subsequently submitted a partial county recommendation that included the E. W. Brown facility.

After considering these comments from the States, EPA agrees that such an approach is preferable in cases where a partial county nonattainment boundary has not already been established for that source ( e. g. partial county boundaries recently established for 8 hour ozone nonattainment areas). For purposes of consistency, EPA has decided that free standing portions of nonattainment areas should be based on a pre existing boundary for a minor civil division ( such as a township or tax district) or other boundary defined for governmental use ( such as a census block group or census tract). Accordingly, this kind of partial county boundary should not be defined simply as the boundary of the facility. Therefore, EPA is designating the census block group identifier ( StateFIPs CoFIPs Tract# Block Group#) 21 167 9605 1 portion of Mercer County as part of the Lexington nonattainment area.

Corrections to TSD for Lexington MSA:

<IP_ADDRESS>  Preamble:

The following corrections are noted to the preamble to the factors text above:

" In February 2004, Kentucky recommended that Fayette County be designated attainment nonattainment ..."

" Clark and Madison Counties are included due to significant emissions..."

" Woodford County is recommended as nonattainment..."

<IP_ADDRESS>  Factor 1 The following corrections are noted to the text after the emissions table:

"... have significant levels of emissions. Although Pulaski County This factor..."

<IP_ADDRESS>  Factor 2 The following correction is noted to the text after the design value table:

"... South LomestoneLimestone monitoring..."

<IP_ADDRESS>  Factor 2 The 2001 2003 design values in the Factor 2 table for Fayette and Madison Counties are corrected to read as follows: 6 211 County 2001 2003 design value Fayette ( KY) 15.6 Madison ( KY) 13.4 Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following counties as nonattainment for the Lexington, KY area: Fayette and Mercer ( Partial).

<IP_ADDRESS> Huntington Ashland Area The Huntington Ashland MSA contains the Kentucky Counties of Boyd, Carter, and Greenup; the West Virginia Counties of Cabell and Wayne; and Lawrence County, Ohio. The following MSA and adjacent counties are violating the PM2.5 standard: Cabell County, West Virginia ( MSA) and Lawrence ( MSA) and Scioto ( adjacent) Counties, Ohio.

In February 2004, Kentucky recommended that the PM2.5 designation for Boyd County be deferred and that Greenup and Carter Counties be designated attainment for the Huntington Ashland MSA. EPA is modifying Kentucky's recommendeation to include Boyd County and Lawrence Counties in Kentucky in the Huntington Ashland nonattainment area. The following factors played a significant role in this decision for Boyd County: attaining monitor reading of 15.0, at the standard; significant SOx, NOx, and PM emissions; proximity to the violating MSA counties; controls with anticipated, substantial SOx, NOx, and PM emission reductions will not be implemented until the end of 2005, well after designations are made. Lawrence County, Kentucky is included due to significant emissions of SOx and NOx from a power plant and its close proximity to the violating counties in the MSA. We have included in our recommended nonattainment area this County that is adjacent to the Huntington Ashland MSA with a violating monitor, that is generally rural in character, and that contains an identifiable large emitting facility ( e. g., power plant) which we believe contributes to the nearby nonattainment problem. We have included this county in our initial recommendations in order to ensure that a sufficient portion of this county, including such a large facility, is included within the boundaries of the nonattainment area as part of the final designations. We invite you to submit to us a recommendation as to what portion of this adjacent county, encompassing the large facility, should be designated nonattainment.

EPA agrees that Greenup and Carter Counties in Kentucky should be designated attainment/ unclassifiable due to their relatively low emissions, low populations, low VMT, low numbers of commuters into the violating counties, and small point sources.

The recommendations of EPA and Kentucky are summarized in the table below. 6 212 Area EPA Recommendation for KY State Recommendation Huntington Ashland, WVKY OH Full counties: Boyd County Lawrence County ( adjacent) Full counties: Boyd ( Defer Designation)

The following is a brief summary of the nine criteria for the Kentucky portion of the Huntington Ashland, WV KY OH area. These analyses were based on existing available data.

Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has the 2001 PM2.5, SOx, NOx, VOC, and ammonia emissions in tons per year and weighted emissions scores for the counties in the Huntington Ashland MSA and surrounding counties. ( MSA counties are in bold; Kentucky MSA counties are in bold italics.)

County PM SOx NOx VOC Amm Score Cum. Score Cabell ( WV) 2,365 5,155 27,903 7,080 181 40.3 40.3 Boyd ( KY) 2,314 11,740 13,478 8,620 467 25.2 65.5 Wayne ( WV) 550 1,023 6,485 2,620 56 9.6 75.1 Greenup ( KY) 477 2,519 4,336 1,795 156 9.5 84.6 Lawrence ( OH) 770 841 4,399 4,366 207 8.6 93.2 Carter ( KY) 506 237 2,615 1,996 223 6.8 100.0 Gallia ( OH) 10,010 164,984 61,079 1,839 300 141.4 Adams ( OH) 6,417 125,136 52,992 1,508 431 102.4 Putnam ( WV) 4,395 80,150 39,795 3,752 97 72.7 Mason ( WV) 3,610 70,053 31,327 2,831 264 60.0 Lawrence ( KY) 2,903 56,066 21,265 919 56 48.3 Scioto ( OH) 1,053 2,790 5,566 4,703 350 12.5 Lewis ( KY) 429 469 2,873 990 222 8.1 Pike ( OH) 425 4,203 2,081 1,311 149 6.8 Rowan KY 336 313 1,691 1,535 91 5.7 Mingo ( WV) 437 281 2,842 1,379 150 5.5 Jackson ( OH) 404 461 1,320 1,717 165 4.7 Martin ( KY) 281 661 1,236 706 762 4.0 Lincoln ( WV) 259 67 1,314 1,128 37 4.0 Elliott ( KY) 164 115 393 313 42 3.1 Based on the analysis for this factor, the following Kentucky counties appear to have significant emissions ( over 10,000 tons per year of any pollutant): Boyd and Lawrence. This factor is not significant for the remaining Kentucky counties listed in this table. 6 213 Factor 2: Air quality in potentially included versus excluded areas County 2001 2003 design value Cabell ( WV) 16.6 Boyd ( KY) 15.0 Lawrence ( OH) 15.8 Carter ( KY) 12.2 Scioto ( OH) 17.2 There are four monitors in the MSA, with two of them in the Kentucky Counties of Boyd and Carter. The Kentucky monitors are monitoring attainment. Three monitors in the MSA and surrounding counties are violating: Cabell County, West Virginia; Lawrence County, Ohio; and the adjacent Scioto County, Ohio. Based on the analysis for this factor for Kentucky only, Boyd County has attaining monitoring data very close to the standard, thus indicating a potential to contribute to the PM2.5 violations in the area. This factor is not significant for the remaining Kentucky counties.

Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table has the populations for the counties in the Huntington Ashland MSA and adjacent counties with significant emissions. The total MSA 2002 population is 313,239. ( MSA counties are in bold; Kentucky MSA counties are in bold italics.)

County 2002 Population Percent of Total MSA Population 2002 Population Density Cabell ( WV) 95,266 30.41 338 Boyd ( KY) 49,603 15.84 310 Wayne ( WV) 42,382 13.53 84 Greenup ( KY) 36,761 11.74 106 Lawrence ( OH) 62,172 19.85 137 Carter ( KY) 27,055 8.64 66 Gallia ( OH) 31,301 67 Adams ( OH) 27,804 48 Putnam ( WV) 52,230 151 Mason ( WV) 26,004 60 Scioto ( OH) 78,041 128 Based on the analysis for this factor for Kentucky only, Boyd County has the third largest population in the MSA and the second largest population density, indicating a potential to contribute to the PM2.5 violations in the area. This factor is not significant for the remaining Kentucky counties.

Factor 4: Traffic and commuting patterns Commuting Information Total number of workers in Boyd County, KY: 19,106 6 214 Commuters in Boyd County, KY who work in Boyd County, KY: 13,816 ( 72%) Commuters from Boyd County, KY to Cabell County, WV: 1,157 ( 6%) Commuters from Boyd County, KY to Lawrence County, OH: 540 ( 3%)

Total number of workers in Carter County, KY: 10,258 Commuters in Carter County, KY who work in Carter County, KY: 5,641 ( 55%) Commuters from Carter County, KY to Boyd County, KY: 1,401 ( 14%) Commuters from Carter County, KY to Cabell County, WV: 237 ( 2%)

Total number of workers in Greenup County, KY: 13,798 Commuters in Greenup County, KY who work in Greenup County, KY: 5,930 ( 43%) Commuters from Greenup County, KY to Boyd County, KY: 4,147 ( 30%) Commuters from Greenup County, KY to Cabell County, WV: 473 ( 3%) Commuters from Greenup County, KY to Lawrence County, OH: 443 ( 3%) Commuters from Greenup County, KY to Scioto County, KY: 1,252 ( 9%)

Total number of workers in Lawrence County, KY: 4,899 Commuters in Lawrence County, KY who work in Lawrence County, KY: 2,483 ( 51%) Commuters from Lawrence County, KY to Boyd County, KY: 575 ( 12%) Commuters from Lawrence County, KY to Cabell County, WV: 193 ( 4%) Commuters from Lawrence County, KY to Lawrence and Scioto Counties, OH: 0 ( 0%)

Based on commuting data above, none of the Kentucky counties appear to be contributing a significant level of onroad mobile source emissions to the area.

Vehicle Miles Traveled:

The following table has the vehicle miles traveled ( thousand miles) for the counties in the Huntington Ashland MSA and some adjacent counties with significant emissions. ( MSA counties are in bold; Kentucky MSA counties are in bold italics.)

County 2002 VMT ( thousand miles/ year) Cabell ( WV) 1,030 Boyd ( KY) 411 Wayne ( WV) 377 Greenup ( KY) 264 Lawrence ( OH) 796 Carter ( KY) 665 Gallia ( OH) 266 Adams ( OH) 283 Putnam ( WV) 578 Mason ( WV) 270 Scioto ( OH) 633 Based on the total VMT of the Kentucky counties only, there appears to be a potential contribution of onroad mobile source emissions to the area from Boyd and Carter Counties. 6 215 However, the analysis of the commuting data above shows that a low number of workers commute from these Kentucky counties into the violating counties. Thus, this factor is not significant for the Kentucky counties listed above when VMT and commuting data are analyzed together.

Factor 5: Expected growth The following table has the population and population growth figures for the Huntington Ashland MSA and adjacent counties with significant emissions. ( MSA counties are in bold; Kentucky MSA counties are in bold italics.)

County 2002 Population growth ( 90 00) % growth ( 90 00) Cabell ( WV) 95,266  43  0 Boyd ( KY) 49,603  1,398  3 Wayne ( WV) 42,382 1,267 3 Greenup ( KY) 36,761 149 0 Lawrence ( OH) 62,172 485 1 Carter ( KY) 27,055 2,549 10 Gallia ( OH) 31,301 115 0 Adams ( OH) 27,804 1,959 8 Putnam ( WV) 52,230 8,754 20 Mason ( WV) 26,004 779 3 Scioto ( OH) 78,041  1,132  1 Based on an analysis of this factor for Kentucky only, there appears to be relatively significant population growth in Carter County to indicate a potential air quality contribution. However, Carter County's population is low. Boyd and Greenup Counties have a negative or zero population growth rate. Thus, this factor is not significant for the Kentucky counties.

Factor 6: Meteorology The following meteorological information was provided by Kentucky. The text below is the same for Boyd, Carter, and Greenup Counties in Kentucky. The figure referenced is a wind rose for April 1 October 31 for the 1988 1992 period that is provided in Kentucky's PM2.5 recommendations submittal.

Meteorological Information " Due to the close proximity of Huntington, West Virginia, meteorological data from Huntington was used for this Kentucky area. Wind speed/ wind direction information shows that the majority of the time for the period 1988   1992, the wind in the Huntington Ashland area came from the southwest and typically from 4 6 knots. ( See figure 1 A) The mean high temperature for July for the area from 1961 through 1990 was 85

F and the mean low was 65

F. The mean precipitation for the same period was 4.5 inches." ( Source: Kentucky PM2.5 submittal) 6 216 Based on an analysis of this factor, the information provided is not sufficient to provide a compelling argument to exclude counties based on prevailing winds. The information provided was for only the summertime winds.

Factor 7: Geography/ topography Based on an analysis of this factor, there are no significant topographical issues associated with this MSA.

Factor 8: Jurisdictional boundaries The following MSA counties were designated nonattainment for the 8 hour ozone standard on April 15, 2004: Boyd County, Kentucky; the West Virginia Counties of Cabell, Wayne, and Putnam; and no counties in Ohio. This factor did not play a significant role in the decisionmaking process.

Factor 9: Level of control of emission sources The following information was provided by Kentucky for Boyd, Carter, and Greenup Counties. " Point sources located within... County are subject to PSD requirements, CTG RACT requirements, Maximum Achievable Control Technology ( MACT) requirements for sources of Hazardous Air Pollutants, and New Source Performance Standards ( NSPS)." This factor did not play a significant role in the decisionmaking process for these counties Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States Lawrence County, KY:

In the June 29, 2004, letters from EPA to the States responding to their designation recommendations, EPA recommended the designation of a number of counties primarily because of high pollutant emissions from power plants. Most of these plants were located in nearby counties adjacent to the metropolitan area ( as defined either by the 1999 or 2003 OMB metropolitan area definitions). EPA suggested that a State could provide a partial county boundary that would encompass the relevant power plant to include it in the nonattainment area. Lawrence County, Kentucky, is one of those counties.

Lawrence County, Kentucky, has low population ( 15,784 compared to 95,266 and 62,172 in the violating MSA counties of Cabell, West Virginia and Lawrence, Ohio, respectively), low population density ( 38 people per square mile compared to 338 in Cabell, West Virginia and 137 in Lawrence, Ohio), low VMT ( 163,000 compared to 1,030,000 and 796,000 in Cabell, West Virginia and Lawrence, Ohio), and the only large point source is the Big Sandy Power Plant. Lawrence County, Kentucky, has no monitor. 6 217 A number of states responded to this suggestion with a series of connected townships or other unique boundaries. Some states also suggested an alternative approach in which partial county areas for power plants in some cases could be small " free standing" boundaries that are considered part of the nearby nonattainment area. In this way, it would not be necessary to include additional townships or other minor civil divisions comprising an odd shaped " land connector" extending from the main part of the nonattainment area to the power plant. The Commonwealth of Kentucky subsequently submitted a partial county recommendation that included the Big Sandy Power Plant.

After considering these comments from the States, EPA agrees that such an approach is preferable in cases where a partial county nonattainment boundary has not already been established for that source ( e. g. partial county boundaries recently established for 8 hour ozone nonattainment areas). For purposes of consistency, EPA has decided that free standing portions of nonattainment areas should be based on a pre existing boundary for a minor civil division ( such as a township or tax district) or other boundary defined for governmental use ( such as a census block group or census tract). Accordingly, this kind of partial county boundary should not be defined simply as the boundary of the facility. Therefore, EPA is designating the census block group identifier ( StateFIPs CoFIPs Tract# Block Group#) 21 127 9901 6 portion of Lawrence County, Kentucky as part of the Huntington Ashland nonattainment area and the remainder of the county as attainment/ unclassifiable.

Corrections to TSD to Huntington Ashland MSA:

<IP_ADDRESS>  Factor 1: Deletion: ( over 10,000 tons per year of any pollutant)

<IP_ADDRESS>  Factor 2:

The design value for Boyd County is corrected to read as follows:

County 2001 2003 design value Boyd, KY 14.9 <IP_ADDRESS>  Factor 3: The following information is inserted into the population data table:

County 2002 Population Percent of Total MSA Population 2002 Population Density Lawrence ( KY) 15,784 38 <IP_ADDRESS>  Factor 4: The following information is inserted into the VMT data table: 6 218 County 2002 VMT ( thousand miles/ year)

Lawrence ( KY) 163 <IP_ADDRESS>  Factor 5: The following information is inserted into the population growth table:

County 2002 Population growth ( 90 00) % growth ( 90 00)

Lawrence ( KY) 15,784 1,571 11 Insert the following statements regarding Lawrence County, KY as follows ( additions are in italics, deletions are in strikeout).

Based on an analysis of this factor for Kentucky only, there appears to be relatively significant population growth in Carter and Lawrence Countyies in Kentucky to indicate a potential air quality contribution. However, the populations of Carter and Lawrence Countyies population is are low.

Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following counties as nonattainment for the Huntington   Ashland, WV KY OH area: Boyd and Lawrence ( Partial).

<IP_ADDRESS> Boyd County Area Kentucky anticipates that emissions of PM2.5, SOx, and NOx will decrease substantially within Boyd County over the next two years. These anticipated emission decreases are due to source modernization and new controls being implemented at two major sources in Boyd County: the Marathon Ashland Refinery and Calgon Carbon Corporation.

For the Marathon Ashland Refinery, the facility modifications are anticipated to be completed by the end of 2005. According to Kentucky, based on 2002 emissions data, this would mean an approximate reduction of 1,571 tons per year of SO2, a 761 ton per year reduction in NOx, and a 32 ton per year reduction in particulate matter.

For Calgon Carbon Corporation, the May 2003 shutdown of two of their activator lines resulted in SO2 emissions being reduced from this facility by approximately 187 tons in 2003. Before these lines can be reactivated, scrubbers, with SO2 and PM control efficiencies of 90% will be required to be installed on these units. If brought back into operation, these units will have controls in place to reduce emissions of SO2 from these two lines to approximately 32 tons per year.

Based on an analysis of this factor, these controls will not be implemented in a timeframe early enough to influence the decision for Boyd County on PM2.5 designations.

Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following 6 219 counties as nonattainment for the Huntington   Ashland, WV KY OH area: Boyd and Lawrence ( Partial).

6.4.4 EPA 9 Factor Analyses for North Carolina for the Designation of Nonattainment Areas for PM2.5 <IP_ADDRESS> Greensboro Winston Salem High Point Area In February 2004, North Carolina recommended that the entire county of Davidson, be designated as nonattainment for the Fine Particulate Matter Standard. The table below shows the State recommendations and EPA modifications for the Particulate Matter( PM 2.5) nonattainment area in Greensboro Winston Salem High Point, NC. EPA is recommending Davidson County be designated nonattainment because it has a violating PM 2.5 monitor. The MSA counties of Guilford, Stokes, Forsyth and Randolph are also being recommended as nonattaiment. Guilford, Forsyth and Randolph counties are adjacent to Davidson County and have large populations and large emissions. Stokes has significant power plant emissions. EPA agrees that Alamance, Davie, Yadkin, Rowan, Chatham, Rockingham, and Iredell Counties be designated attainment/ unclassifiable. Alamance is an MSA county with an attaining monitor of 13.7 micrograms per cubic meter ( µ g/ m3), 75 % of the commuters remain in Alamance County and the county has low emissions. Davie and Yadkin are MSA counties that do not contain PM 2.5 monitors, have low populations, and low commuting into Davidson. There is significant distance between the violating monitor and the counties of Iredell and Yadkin. Rowan and Iredell are adjacent to the MSA, do not contain PM 2.5 monitors and are a part of the Charlotte Gastonia Rock Hill nonattainment area for ozone. Rowan and Rockingham both have small power plants and there are attaining monitors in counties between the SO2/ NOx sources in Rowan and Rockingham counties and the violating monitor. Chatham is an adjacent county to the Greensboro Winston Salem High Point MSA with an attaining monitor of 12.2 µ g/ m3, has low population, and part of the county is in the Raleigh Durham Chapel Hill nonattainment area for ozone. The remaining adjacent counties all have low emissions, low population and low VMT, indicating they should be attainment/ unclassifiable.

Area EPA Recommendation State Recommendation Greensboro Winston Salem High Point, NC Full Counties: Stokes, Guilford, Davidson, Forsyth, and Randolph Full Counties: Davidson 6 220 Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has 2001 PM2.5, SO2, NOx, VOC, and Ammonia ( Amm) emissions in tons, and weighted emissions scores for the Greensboro Winston Salem High Point Area and surrounding counties. The MSA counties are in bold.

PM 2.5 SO2 NOx VOC Amm Weighted emissions score Cumulative Weighted emissions score NC Stokes 4,821 83,409 35,936 2,566 357 32.8 32.8 NC Guilford 2,418 2,833 19,068 34,464 1,178 17.6 50.4 NC Davidson 1,951 1,398 11,281 14,970 632 12.9 63.3 NC Forsyth 1,559 5,885 14,552 20,679 722 11.7 75.0 NC Randolph 1,370 907 5,898 10,307 4,014 9.5 84.5 NC Alamance 1,181 749 5,618 8,967 730 8.2 92.7 NC Yadkin 606 318 2,061 2,247 896 4.0 96.7 NC Davie 508 205 1,959 3,278 448 3.3 100.0 NC Rowan 2,012 12,465 11,681 11,323 726 13.4 NC Chatham 1,714 11,605 5,823 4,734 3,012 11.7 NC Rockingham 1,555 6,263 12,227 8,770 523 11.2 NC Iredell 1,537 1,365 11,065 10,346 2,090 10.8 NC Surry 1,224 1,238 5,055 7,478 1,811 8.5 VA Pittsylvania 980 1,828 7,490 4,149 581 7.2 NC Moore 956 409 3,197 6,519 2,396 6.9 NC Wilkes 966 647 2,890 5,097 5,300 6.6 NC Orange 857 756 6,264 6,751 572 6.4 VA Henry 818 535 3,811 10,517 197 5.6 NC Stanly 795 3,129 2,891 4,581 1,460 5.3 NC Montgomery 516 484 1,631 4,175 1,246 3.6 NC Caswell 483 199 1,071 1,622 155 3.2 VA Patrick 408 176 1,039 1,363 214 2.8 VA Carroll 378 509 2,305 1,986 441 2.7 VA Grayson 291 95 819 952 405 2.0 NC Alleghany 217 190 379 590 425 1.4 Based on the analysis for this factor, there appears to be emissions in Stokes, Guilford, Forsyth, and Randolph counties that contribute to the air quality in Davidson County, resulting in a violating monitor there. This analysis shows that the adjacent counties of Rowan, Chatham, Rockingham, and Iredell have emissions that may contribute to the violation in Davidson County. However, these counties are more distant from the violating monitor. Chatham County has an attaining monitor and is part of the Raleigh MSA. Rowan and part of Iredell County are in the Charlotte ozone nonattainment area. 6 221 Factor 2: Air Quality in potentially included versus excluded areas 2001 2003 Design Value NC Guilford 14.1 NC Davidson 15.8 NC Forsyth 14.6 NC Alamance 13.7 NC Chatham 12.2 NC Orange 13.1 NC Montgomery 12.1 NC Caswell 13.3 There are six monitors in the MSA ( two in Guilford, and two in Forsyth counties and one in Davidson, and Alamance counties) and five monitors in the adjacent counties. The monitor in Davidson County, is violating the Particulate Matter Standard of 15.0 micrograms per cubic meter ( µ g/ m3). All other monitors in this area are attaining the Particulate Matter Standard.

Factor 3: Population Density and Degree of Urbanization including commercial development in included versus excluded areas The following table has the populations for the counties in the Greensboro Winston Salem High Point area and adjacent counties with significant weighted emissions scores.

2002 Population % Population of MSA Population Density ( pop./ mi2)

NC Stokes 44,984 3.5 100 NC Guilford 430,937 33.5 663 NC Davidson 151,238 11.6 274 NC Forsyth 314,933 24.5 768 NC Randolph 134,217 10.4 170 NC Alamance 135,893 10.6 315 NC Yadkin 37,329 2.9 111 NC Davie 36,734 2.9 139 NC Rowan 133,359 261 NC Chatham 53,893 79 NC Rockingham 92,778 164 NC Iredell 130,178 227 Based on the analysis for this factor, there appears to be significant populations in Guilford, Forsyth, Davidson, Rowan, Iredell, Randolph and Alamance counties, indicating potential contribution.

Factor 4: Traffic and commuting patterns Commuting Information Total commuters in Davidson County: 72,893 6 222 Commuters in Davidson County, NC, who work in Davidson County: 40,621 ( 56%)

Total commuters in Forsyth County: 147,838 Commuters in Forsyth County, NC, who work in Forsyth County: 119,233 ( 81%) Commuters from Forsyth County, NC to Davidson County, NC: 4,136 ( 3%)

Total commuters in Guilford County: 213,079 Commuters in Guilford County, NC, who work in Guilford County: 187,150 ( 88%) Commuters from Guilford County, NC to Davidson County, NC: 2,982 ( 1%)

Total commuters in Randolph County: 65,803 Commuters in Randolph County, NC, who work in Randolph County: 38,637 ( 59%) Commuters from Randolph County, NC to Davidson County, NC: 2,607 ( 4%)

Total commuters in Stokes County: 21,709 Commuters in Stokes County, NC, who work in Stokes County: 6,330 ( 29%) Commuters from Stokes County, NC to Davidson County, NC: 252 ( 1%)

The counties of Davie and Rowan have a small number of commuters and very few of them commute to Davidson County. Chatham, Yadkin, Iredell, and Rockingham counties have a low number of commuters and most of them stay within their counties.

Based on commuting patterns, Forsyth and Guilford appear to have the most impact on the violating monitor in Davidson County. However, the impact on the monitor from commuting appears to be small.

The following table contains the vehicle miles traveled ( VMT) for the counties in the Greensboro Winston Salem High Point area and some adjacent counties with significant emissions. ( MSA counties are in bold).

2002 VMT ( thousands of miles) NC Stokes 415 NC Guilford 5,096 NC Davidson 1,765 NC Forsyth 3,832 NC Randolph 1,486 NC Alamance 1,575 NC Yadkin 520 NC Davie 476 NC Rowan 1,654 NC Chatham 434 NC Rockingham 923 NC Iredell 1,901 Based on total VMT, there appears to be contribution to air quality in Davidson County from Guilford, Davidson, Forysth, Rowan, Iredell, Randolph and Alamance counties. However, there 6 223 is very low or no commuting into Davidson County from Rowan. Iredell, and Alamance Counties Factor 5: Expected growth The following table has the population and population growth on a percentage basis figures for counties in the Greensboro Winston Salem High Point MSA and some adjacent counties with significant emissions. As noted above, Chatham County is part of the Raleigh MSA, and Iredell and Rowan Counties are in the Charlotte rather than the Greensboro ozone nonattainment area.

2002 Population Growth ' 90' 00 % Change ' 90' 00 NC Stokes 44,984 7,488 20 NC Guilford 430,937 73,628 21 NC Davidson 151,238 20,569 16 NC Forsyth 314,933 40,189 15 NC Randolph 134,217 23,908 22 NC Alamance 135,893 22,587 21 NC Yadkin 37,329 5,860 19 NC Davie 36,734 6,976 25 NC Rowan 133,359 19,735 18 NC Chatham 53,893 10,570 27 NC Rockingham 92,778 5,864 7 NC Iredell 130,178 29,729 32 Based on the analysis for this factor, there appears to be significant growth in Davidson, Guilford, Forsyth, Alamance, Randolph, Rowan, Chatham, and Iredell counties indicating a potential contribution to the air quality in Davidson County.

Factor 6: Meteorology The following meteorological information was provided by North Carolina. This summarizes the wind directions for the MSA during the time periods when PM2.5 values are the highest.

Summertime: southwesterly winds and recirculating patterns dominate. Main urban areas of influence include Charlotte, the Triad, and Hickory.

Wintertime: More northerly and stronger northwesterly winds observed that during the summer. High PM2.5 is generally observed prior to frontal passages when high pressure is in control or during strong nocturnal low level temperature inversions. Year round trajectories indicate influence from nearby states.

The information provided is not sufficient to provide a compelling argument to exclude counties based on prevailing winds.

Factor 7: Geography/ topography 6 224 There are no significant topographical issues associated with this MSA. Chatham, Iredell, and Rockingham counties are one or more counties away from Davidson county. Additionally, there is one or more attaining monitors between the major emissions sources in these counties and the violating monitor, indicating no contribution.

Factor 8: Jurisdictional boundaries The 8 hour nonattainment boundary designation for the Greensboro Winston Salem High Point area includes the entire counties of Davidson, Davie, Forsyth, Guilford, Alamance, Caswell, Randolph, and Rockingham. Davie, Alamance, Caswell, and Rockingham were designated nonattainment for ozone because they contained violating monitors not because they were found to be contributing. Rowan county and a portion of Iredell county were designated nonattainment for the ozone standard as apart of the Charlotte Gastonia Rock Hill MSA area. Due to significant NOx controls, Stokes County was determined not to contribute to the ozone violations.

Factor 9: Level of control of emission sources Belews Creek is the largest coal burning station owned by Duke Power located in Stokes County, NC. Duke Power completed the first phase of its massive Selective Catalytic Reduction ( SCR) project at Belews Creek Steam Station that will reduce the power plant's nitrogen oxide emissions by over 90 percent. No scrubbers are installed at this time, but are scheduled to be installed in 2009.

The state initiatives are listed below: NOx SIP Call The Clean Smokestacks Act Clean Air Bill On Board Diagnostics II Emissions Inspection Program PM2.5 Forecasting Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States EPA's initial recommendations on June 29, included Forsyth, Randolph and Stokes Counties as part of the Greensboro nonattainment area. Upon further review of additional information provided by the State, EPA is revising its recommendation and is designating Forsyth, Randolph and Stokes Counties as attainment/ unclassifiable.

The State of North Carolina has taken a proactive approach to solving its air pollution problems. Several programs have been implemented and will continue to be implemented to control PM2.5 precursors. The State has a robust PM2.5 monitoring network. The Clean Smokestacks Act requires NOx SIP Call controls to be operated year round and requires significant emission reductions of SO2 from power plants. These NOx and SO2 reductions must occur within the boundaries of North Carolina. As a statewide effort, several mobile source controls have been implemented. The On Board Diagnostics II Emissions Inspection and Maintenance ( I/ M) 6 225 program has expanded to now encompass 48 counties, including all MSA counties and covering 82% of all statewide vehicles. EPA and State grants have been used to support of their efforts to reduce emissions from mobile sources which include Alternate Fuel Vehicle Infrastructure, Compressed Natural Gas Stations, bike racks on buses, and a Mobile Source Abatement Program.

The Greensboro area Early Action Compact ( EAC) includes the counties of Alamance, Caswell, Davidson, Davie, Forsyth, Guilford, Randolph, Rockingham, Stokes, Surry and Yadkin. As an EAC area, all 11 counties are adopting policies to encourage and promote diesel retrofits. Less polluting vehicles area expected to result in a reduction in emissions of 1.1 tpy of VOC and 0.9 tpy of NOx. An increase in ridership on regional bus services is projected to decrease VOC emissions by 8.9 tpy and NOx emissions by 7.3 tpy. All diesel vehicles will be converted to biodiesel. In addition, an increase in telecommuting is expected to lead to a decrease of VOC and NOx emissions by 189 tpy and 155 tpy, respectively. Through the use of non motorized transportation, all Triad EAC Counties are also expected to decrease VOC emissions by 279 tpy and NOx by 229 tpy. As part of Duke Energy's initiative to cleaner air, implementation of a Meter Reading Optimizing program will reduce Vehicle Miles Traveled ( VMT) in all 11 EAC Counties.

Stokes County, NC:

The Belews Creek Steam Station is the major source of the County's emissions. However, Duke Power, as part of the NOx SIP Call, has completed the Selective Catalytic Reduction ( SCR) project and began operation on unit one in 2003 and unit two in 2004. Additionally, unit two had burner technology installed. NOx emissions at the Belews Creek Steam Station were reduced by 36,545 tons per year ( tpy) to 7,022 TPY by the end of 2004. Per the Clean Smokestacks Legislation, SCR must be operated year round by 2009. In addition, the Belews Creek Power Plant will complete the installation of state of the art scrubbers on both units by 2008, reducing sulfur dioxide ( SO2) emissions by 90% to 10,805 TPY and achieve an emission rate of 0.15 lb/ mmBTU emission rate. Stokes County rates low for other factors, such as population, population density, commuting patterns, and VMT.

Duke Power has committed to work with the State of North Carolina to expeditiously place the schedule for compliance with the Clean Smokestacks requirements ( SO2 & NOx) into the title V permit. This schedule will include installation of state of the art scrubbers by 2008.

Forsyth County, NC:

Forsyth County has two attaining monitors at 14.0 and 14.6 micrograms/ cubic meter. Forsyth emissions in tons per year are as follows: PM emissions 1,559 tpy ( 11% of MSA), SO2 emissions 5,885 tpy ( 6% of MSA), NOx emissions 14,552 TPY ( 15% of MSA). Even though Forsyth County has the second highest MSA population with 314,933 people representing 24.5% of the MSA, it is substantially less than Guilford County with a population of 430,937. Of 147,838 commuters in Forsyth County, 119,233 ( 80.7%) commuters stay within the county. The majority of emissions are from mobile sources. These emissions are controlled ( or addressed) as described above. 6 226 Wind direction and pollution roses for the Greensboro area were more predominant in the direction of Guilford County than Forsyth County.

Randolph County, NC:

Randolph County's emissions represent a small percentage of the total emissions for the MSA. Randolph County's total emissions in tons per year ( tpy) are: PM 1,370 ( 9.5% of the MSA), SO2 907 ( 0.9% of the MSA), NOx 5,898 ( 6.1% of the MSA). The population of Randolph County, 134,217, is low compared to Guilford County with a population of 430,937 and Randolph County's VMT of 1,486 is one of the lowest in the MSA as compared to 5,096 thousands of miles.

Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following counties as nonattainment for the Greensboro Winston Salem   High Point, NC area: Davidson and Guilford .

<IP_ADDRESS> Hickory Morganton Lenoir Area The following is the nine factor analysis for Hickory Morganton Lenoir, NC. The Hickory Morganton Lenoir, NC Metropolitan Statistical Area ( MSA) contains the counties of Catawba, Caldwell, Burke, and Alexander.

In February 2004, North Carolina recommended that the Unifour Metropolitan Planning Organization's ( MPO) Planning Boundary in Catawba County, be designated as nonattainment. The table below shows State Recommendations and EPA recommended modifications for the Particulate Matter 2.5 ( PM 2.5) nonattainment area in the Hickory Morganton Lenoir area. EPA is modifying the recommendation to include the entire county of Catawba and partial county boundaries in Burke and Caldwell Counties. Catawba County has a violating PM 2.5 monitor. The partial county boundaries in Burke and Caldwell Counties follow the MPO boundary lines which were the boundaries determined in the 8 hour ozone designation in April 2004 for the two counties. Over 20 percent of the commuters from Burke and Caldwell counties commute to Catawba County and both counties contain population levels that indicate contribution. EPA agrees that the MSA county of Alexander and the adjacent counties of Rutherford, Iredell, Cleveland, and Wilkes be designated attainment/ unclassifiable. These counties have low population, and are low commuting into Catawba County, distant from the violating monitor in Catawba County. The remaining adjacent counties all have low emissions and low population, indicating they should be attainment/ unclassifiable.

Area EPA Recommendation State Recommendation 6 227 Hickory Morganton Lenoir Full Counties: Catawba Partial Counties: Burke and Caldwell Full Counties: None Partial Counties: Catawba The following is a brief summary of the 9 criteria for the Hickory Morganton Lenoir MSA and surrounding counties. These analyses were based on existing available data.

Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has 2001 PM2.5, SO2, NOx, VOC, and Ammonia ( Amm) emissions in tons, and weighted emissions scores for the Hickory Morganton Lenoir Area and surrounding counties. The Metropolitan Statistical Area ( MSA) counties are in bold.

PM 2.5 SO2 NOx VOC Amm Weighted emissions score Cumulative Weighted emissions score Catawba 5,153 78,620 27,968 19,760 886 59.7 59.7 Caldwell 1,104 634 3,530 11,122 391 18.1 77.8 Burke 1,198 877 4,601 7,721 562 17.0 94.8 Alexander 365 349 988 3,312 1,217 5.1 99.9 Rutherford 2,323 30,023 12,135 4,847 254 28.4 Iredell 1,537 1,365 11,065 10,346 2,090 25.3 Cleveland 1,258 1,261 4,975 6,591 1,240 18.4 Wilkes 966 647 2,890 5,097 5,300 15.3 Mc Dowell 751 373 3,675 4,230 214 13.6 Lincoln 785 513 2,880 4,556 645 10.8 Watauga 541 352 1,523 2,370 341 8.5 Avery 269 163 730 985 77 4.4 Based on the analysis for this factor, there appears to be emissions in the MSA counties of Caldwell and Burke, counties that contribute to the violation in Catawba County. Although there are large SO2 emissions in Rutherford county, adjacent to Burke, the source is distant from the violating monitor. 6 228 Factor 2: Air Quality in potentially included versus excluded areas 2001 2003 Design Value Catawba 15.5 Mc Dowell 14.2 Watauga 10.9 There is one monitor in this area, in Catawba County, which is violating the particulate matter standard of 15.0 micrograms per cubic meter ( µ g/ m3). Two adjacent counties contain monitors attaining the standard.

Factor 3: Population Density and Degree of Urbanization The following table has the populations for the counties in the Hickory Morganton Lenoir area and adjacent counties with significant emissions. ( MSA counties are in bold.)

2002 Population % Population of MSA Population Density ( pop./ mi2)

Catawba 146,690 42.0 367 Caldwell 78,513 22.5 166 Burke 89,638 25.7 177 Alexander 34,400 9.8 132 Rutherford 63,287 112 Iredell 130,178 227 Cleveland 97,960 211 Wilkes 66,773 88 Based on the analysis for this factor, there appears to significant populations in Catawba, Iredell, Cleveland, Caldwell and Burke counties, indicating potential contribution.

Factor 4: Traffic and commuting patterns Commuting Information Total commuters in Catawba County: 73, 984 Commuters in Catawba County, NC, who work in Catawba County: 62, 459 ( 84%) 6 229 Total commuters in Rutherford County: 27, 673 Commuters in Rutherford County, NC, who work in Rutherford County: 21, 812 ( 79%) Commuters from Rutherford County, NC to Burke County, NC: 305 ( 1%)

Total commuters in Caldwell County: 38, 970 Commuters in Caldwell County, NC, who work in Caldwell County: 26, 932 ( 69 %) Commuters from Caldwell County, NC to Catawba County, NC: 8,011 ( 21 %)

Total commuters in Burke County: 42,214 Commuters in Burke County, NC, who work in Burke County: 29, 123 ( 69%) Commuters from Burke County, NC to Catawba County, NC: 8,366 ( 20%)

Total commuters in Alexander County: 31, 041 Commuters in Alexander County, NC, who work in Alexander County: 24, 270 ( 51%) Commuters from Alexander County, NC to Catawba County, NC: 5,679 ( 32%)

Most of the commuters in Iredell, Cleveland and Wilkes counties commute within their counties and very few of them commute to Davidson County.

Based on commuting patterns, Caldwell, Alexander and Burke counties appear to have the most potential impact on the violating monitor in Catawba county.

The following table contains the vehicle miles traveled ( VMT) for the counties in the Hickory Morganton Lenoir MSA and some adjacent counties with significant weighted emissions scores. ( MSA counties are in bold.)

2002 VMT ( thousands of miles) Catawba 2,048 Caldwell 738 Burke 1,112 Alexander 229 Rutherford 606 Iredell 1,901 Cleveland 1,125 Wilkes 619 Based on the analysis for this factor, Burke County has VMT that appears to contribute to the air quality in Catawba County. Although the adjacent counties of Iredell and Cleveland have significant levels of VMT, there is little commuting to Catawba County from these counties. 6 230 Factor 5: Expected growth The following table has the population and population growth figures for counties in the Hickory Morganton Lenoir MSA and some adjacent counties with significant emissions.

2002 Population Growth ' 90' 00 Pct change ' 90' 00 Catawba 146,690 23,273 20 Caldwell 78,513 6,706 9 Burke 89,638 13,404 18 Alexander 34,400 6,059 22 Rutherford 63,287 5,981 11 Iredell 130,178 29,729 32 Cleveland 97,960 11,573 14 Wilkes 66,773 6,239 11 Based on the analysis for this factor, there appears to be significant growth on a percentage in Catawba and Alexander Counties in the MSA and adjacent Iredell County, indicating a potential contribution to the air quality in Catawba County. Although the percentage growth is high for the Iredell County, it is more closely associated with the Charlotte area.

Factor 6: Meteorology The following meteorological information was provided by North Carolina. This summarizes the wind directions for the MSA during the time periods when PM2.5 values are the highest.

Summertime: southwesterly winds and recirculating patterns dominate. Main urban areas of influence include Charlotte, the Triad, and Hickory.

Wintertime: More northerly and stronger northwesterly winds observed that during the summer. High PM2.5 is generally observed prior to frontal passages when high pressure is in control or during strong nocturnal low level temperature inversions. Year round trajectories indicate influence from nearby states.

The information provided is not sufficient to provide a compelling argument to exclude counties based on prevailing winds.

Factor 7: Geography/ topography 6 231 There are no significant topographical issues associated with this MSA.

Factor 8: Jurisdictional boundaries The 8 hour nonattainment boundary designation for the Hickory Morganton Lenoir area includes the entire counties of Alexander and Catawba and partial counties of Burke and Caldwell. The nonattainment designation in Burke and Caldwell counties are along the Unifour Metropolitan Planning Organization boundaries. Catawba County is located geographically between Alexander and Lincoln Counties, which both have monitors violating the 8 hour ozone standard.

In Catawba County, a second monitor was operated approximately 10 miles southwest of the current violating Hickory monitor. This monitor was further removed from a major highway. The location of this monitor at a rescue squad and was not able to continue at that location. While in existence for seven quarters, this monitor showed an average of 1.89 µ g/ m3 lower than the current violating monitor. Therefore, the state believes that this monitor would have continued to show attainment/ unclassifiable if it remained in existence to collect three years of data.

Factor 9: Level of control of emission sources Duke Power  Marshall Steam Station ( Catawba County)

No scrubbers are installed at this time. However, in 2004, Duke Power began installation of flue gas desulfurization ( scrubber) equipment. This equipment will lower sulfur dioxide emissions by approximately 90 percent. The project is scheduled for completion in 2007.

The state initiatives are listed below: NOx SIP Call The Clean Smokestacks Act Clean Air Bill On Board Diagnostics II Emissions Inspection Program PM2.5 Forecasting Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States EPA's initial nonattainment recommendations on June 29, 2004, included a portion of Burke and Caldwell Counties. Upon further review of additional information provided by the State, EPA is revising its recommendation and is designating Burke and Caldwell Counties as attainment/ unclassifiable.

The State of North Carolina has taken a proactive approach to solving its air pollution problems. Several programs have been implemented and will continue to be implemented to control PM2.5 pollution. The State has a robust PM2.5 monitoring network. The Clean Smokestacks Act requires NOx controls to be operated year round and requires substantial SO2 reductions from 6 232 power plants. The NOx and SO2 reductions must be generated within the State. As a statewide effort, several mobile source controls have been implemented including I/ M programs in Burke and Caldwell Counties beginning July 1, 2005. Burke County has expected decreases in NOx of 1.29 tpd and VOC of 0.23 tpd while Caldwell County has expected decreases in NOx of 0.20 tpd and VOC of 0.17 tpd. Additionally, Burke and Caldwell Counties are in the Unifour Early Action Compact and this area shows attainment of the 8 hour ozone NAAQS with 2004 data.

Burke County, NC:

Most of the MSA emissions are generated in Catawba County. Burke emissions in tons per year are as follows: PM emissions 1,198 TPY ( 15.3% of MSA), SO2 emissions 877 TPY ( only 1.1% of MSA), NOx emissions 4,601 TPY ( 12.4% of MSA). Burke County has a population of 89,638 as compared to Catawba County's population of 146,690 people. In addition, Burke has a VMT of 1,112 thousand miles as compared to Catawba County's VMT of 2,048. Of 42,214 ( 24% of MSA) commuters in Burke County, 29,123 ( 69.0%) commuters stay within the county. There are no large point sources of precursor emissions and the majority of emissions are due to mobile emissions, which are controlled as described above.

Caldwell County, NC:

Most of the MSA emissions are generated in Catawba County. Caldwell emissions in tons per year are as follows: PM emissions 1,104 TPY ( 14.1% of MSA), SO2 emissions 634 TPY ( only 0.8% of MSA), NOx emissions 3,530 TPY ( 9.5% of MSA). Caldwell County has a population of 78,513 as compared to Catawba County's population of 146,690 people. In addition, Caldwell has a VMT of 738 thousands of miles as compared to Catawba County's VMT of 2,048. Of 38,970 ( 23% of MSA) commuters in Caldwell County, 26,932 ( 69.1%) commuters stay within the county. There are no large point sources and the majority of emissions are due to mobile emissions, which are controlled as described above.

Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following county as nonattainment for the Hickory   Morganton   Lenoir, NC area: Catawba.

6.4.5 EPA 9 Factor Analyses for South Carolina for the Designation of Nonattainment Areas for PM2.5 <IP_ADDRESS> Greenville Spartanburg Anderson Area In February 2004, South Carolina recommended that the entire state be designated attainment. Currently, all monitors with three years of complete data are attaining the Particulate Matter standard of 15.0 micrograms per cubic meter ( µ g/ m3). However, Greenville County has a monitor that has not been in operation for three years, but is indicating potential to violate the PM 2.5 standard. Anderson and Spartanburg counties have emissions and population levels that potentially contribute to the high levels at the Greenville monitor in question. Therefore, EPA is modifying the State's recommendation to designate Anderson, Greenville and Spartanburg counties as unclassifiable. Once the monitor has operated for three full years, EPA in 6 233 conjunction with the State will reassess the situation and revise the designation based on three years of data.

Area EPA Recommendation State Recommendation Greenville Spartanburg Anderson, SC Full Counties: Anderson, Greenville, and Spartanburg as unclassifiable Full Counties: None Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area Region 4' s analysis for factor 1 looks primarily at PM2.5, SOx, NOx, VOC, ammonia emissions and weighted emissions data. A score is assigned for each county reflecting the speciation profile of the urban increment and the corresponding weighted emissions of the MSA/ CMSA. These scores add to 100 for the MSA/ CMSA counties and are referred to as weighted emissions scores. Counties adjacent to the CSA can then be assigned an weighted emissions score based on the MSA/ CMSA as a way to compare the emissions from those counties the MSA/ CMSA counties.

The following table has 2001 PM2.5, SO2, NOx, VOC and Ammonia ( Amm) emissions in tons, and weighted emissions scores for the Greenville Spartanburg Anderson Area and surrounding counties. The Metropolitan Statistical Area ( MSA) counties are in bold.

PM SO2 NOx VOC Amm Weighted emissions score Cumulative Weighted emissions score SC Spartanburg 3070 2351 19046 23897 821 29.7 29.7 SC Greenville 2793 3369 15407 28867 861 27.4 57.1 SC Anderson 2904 9903 11559 13621 1090 22.9 80.0 SC Pickens 1428 1239 5153 7489 274 12.5 92.5 SC Cherokee 834 1270 4121 3538 301 7.4 SC York 2525 9714 12206 15064 1325 22.5 NC Rutherford 2323 30023 12135 4847 254 17.0 NC Cleveland 1258 1261 4975 6591 1240 11.4 SC Newberry 979 353 3682 3813 1357 11.0 SC Laurens 1027 597 5262 4846 414 10.2 NC Henderson 1068 419 4088 7066 358 10.1 SC Greenwood 1095 624 3680 4353 404 10.0 SC Oconee 1058 298 3561 4867 1457 9.7 NC Jackson 588 303 1344 1846 216 6.7 NC Macon 555 307 1164 1798 262 6.3 SC Union 549 849 2027 2047 197 5.8 GA Habersham 651 103 1757 2201 3031 5.6 NC Transylvania 449 3259 2824 3388 106 5.4 GA Rabun 455 66 943 1606 341 5.1 SC Abbeville 474 208 1384 1538 203 4.7 GA Elbert 410 71 1357 1280 343 3.8 GA Franklin 449 84 2068 1813 4128 3.7 GA Stephens 406 277 1480 2075 976 3.5 GA Hart 505 63 1321 1595 1516 3.2 6 234 NC Polk 266 105 1299 1149 256 3.1 Based on the analysis for this factor, there appears to be emissions in Spartanburg and Anderson counties that contribute to the air quality in Greenville County. The emissions in Pickens and Cherokee Counties are much less and father from the Greenville monitor with potential violation.

Factor 2: Air Quality in potentially included versus excluded areas 2001 2003 Design Value SC Spartanburg 13.7 SC Greenville 14.5 SC York 14.0 SC Greenwood 13.1 SC Oconee 10.6 NC Jackson 13.0 All of the monitors in this area with three years of complete data are attaining the particulate matter standard. However, there is a monitor in Greenville County, SC with less than three years of data that indicates a potential to violate the stardard of 15.0 µ g/ m3.

Factor 3: Population Density and Degree of Urbanization The following table has the populations for the counties in the Greenville Spartanburg Anderson area and adjacent counties with significant weighted emissions scores.

2002 Population % Population of MSA Population Density ( pop./ mi2)

SC Spartanburg 259,322 26.3 320 SC Greenville 391,334 39.6 494 SC Anderson 170,578 17.3 238 SC Pickens 113,097 11.4 228 SC Cherokee 53,524 5.4 136 SC York 173,755 254 NC Rutherford 63,287 112 Based of the analysis for this factor, there appears to be significant populations to indicate a contribution by Spartanburg and Anderson counties.

Factor 4: Traffic and commuting patterns Commuting Information Total commuters in Greenville County: 185,461 Commuters in Greenville County, SC who work in Greenville County: 24,270 ( 87%)

Total commuters in Spartanburg County: 117,096 Commuters in Spartanburg County, SC, who work in Spartanburg County: 95,496 ( 82%) 6 235 Commuters from Spartanburg County, SC to Greenville County, SC: 14,586 ( 12%)

Total commuters in Anderson County: 76,098 Commuters in Anderson County, SC, who work in Anderson County: 52,133 ( 69%) Commuters from Anderson County, SC to Greenville County, SC: 13,766 ( 18%)

Total commuters in Pickens County: 52,130 Commuters in Pickens County, SC, who work in Pickens County: 28,951 ( 56%) Commuters from Pickens County, SC to Greenville County, SC: 15,095 ( 29%)

Total commuters in Cherokee County: 22,999 Commuters in Cherokee County, SC, who work in Cherokee County: 16,052 ( 70%) Commuters from Cherokee County, SC to Greenville County, SC: 431 ( 2%)

Greenville County has the largest number of commuters in Greenville Spartanburg Anderson MSA. There appears to be significant commuting from Spartanburg, Anderson, and Pickens Counties to indicate a contribution to the monitor in Greenville County.

The following table has the vehicle miles traveled ( thousands of miles) for the counties in the Greenville Spartanburg Anderson area and some adjacent counties with significant weighted emissions scores. ( MSA counties are in bold).

2002 VMT SC Spartanburg 3,509 SC Greenville 3,664 SC Anderson 2,163 SC Pickens 1,180 SC Cherokee 754 SC York 1,860 NC Rutherford 606 Based on the analysis for this factor, there is contribution to air quality in Spartanburg, Greenville, Anderson, Pickens, and York counties.

Factor 5: Expected Growth The following table has the population and population growth figures for counties in the Greenville Spartanburg Anderson area and some adjacent counties with significant weighted emissions scores.

2002 Population Growth ' 90` 00 % Change ' 90` 00 SC Spartanburg 259,322 26,991 12 SC Greenville 391,334 59,449 19 SC Anderson 170,578 20,544 14 SC Pickens 113,097 16,863 18 SC Cherokee 53,524 8,031 18 6 236 SC York 173,755 33,117 25 NC Rutherford 63,287 5,981 11 Based on the analysis for this factor, there appears to be significant growth in Greenville, Spartanburg, Anderson, Pickens and York counties indicating a potential contribution to the air quality in Greenville County.

Factor 6: Meteorology No meteorological information was provided by South Carolina. This factor did not play a significant role in the decision making process.

Factor 7: Geography/ topography The counties of Greenville, Spartanburg, Pickens, and York are located on the northern border of South Carolina, which borders the state of North Carolina.

No geographical or topographical data was provided by South Carolina.

This factor did not play a significant role in the decision making process.

Factor 8: Jurisdictional boundaries This factor did not play a significant role in the decision making process.

Factor 9: Level of control of emission sources South Carolina is subject to the NOx SIP Call and the Greenville Spartanburg Anderson MSA is participating in Early Action Compacts.

This factor did not play a significant role in the decision making process.

Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following counties as unclassifiable for the Greenville Spartanburg, SC area: Anderson, Greenville, and Spartanburg.

6.4.6 EPA 9 Factor Analyses for Tennessee for the Designation of Nonattainment Areas for PM2.5 <IP_ADDRESS> Chattanooga Area The Chattanooga MSA contains the following Tennessee counties: Marion and Hamilton; and the following Georgia Counties: Dade, Walker, and Catoosa. Based on air quality data for 2001 2003, the monitor with the highest design value in Hamilton County has a design value of 16.1 and the monitor in Walker County has a design value of 15.6. No other counties in the MSA contain ambient air monitors. The State of Tennessee recommended as nonattainment the county 6 237 of Hamilton and the State of Georgia recommended as nonattainment the county of Walker. The States have recommended that all other counties be designated attainment. The State of Tennessee submitted some justification for this recommendation, however, they indicated that the detailed emission information would be provided at a later date. EPA is modifying the State of Tennessee's recommendation and will review the additional information during the 120 day period following the notification letter.

EPA has received some information from the State of Tennessee that Marion ( MSA) County should be designated attainment for the PM2.5 standard and no justification from the State of Georgia indicating that any other counties should be included or excluded from the Chattanooga PM2.5 nonattainment area. Adjacent counties with significant emissions include McMinn and Roane Counties which are attached to the Knoxville nonattainment area and Floyd County which is a separate nonattainment area.

Additionally we have included in our recommended nonattainment area Jackson County, AL, that is adjacent to the Chattanooga MSA, that is generally rural in character, and that contains an identifiable large emitting facility or facilities ( e. g., power plants) which we believe contribute to the nearby nonattainment problem. We have included this county in our initial recommendations in order to ensure that a sufficient portion of this county, including such large facilities, is included within the boundaries of the nonattainment area as part of the final designations. We invite you to submit to us a recommendation as to what portion of this adjacent county, encompassing the large facility or facilities, should be designated nonattainment. Therefore EPA is modifying the States' recommendations to include all of the counties in the MSA and the adjacent county of Jackson, Alabama.

Area EPA Recommendation States Recommendations Chattanooga Full counties: Marion, Hamilton, TN; Dade, Walker, Catoosa, GA; Jackson, AL Full counties: Hamilton and Walker Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table contains the 2001 PM2.5, SOx, NOx, VOC, and ammonia emissions in tons and weighted emissions scores for the counties in the Chattanooga MSA and some adjacent counties. ( MSA counties are in bold.) 6 238 County PM SOx NOx VOC Amm Weighted Emissions Score Cumulative Weighted Emissions Score Hamilton 1,498 5,300 20,048 27,150 1,022 49.5 49.5 Walker 856 632 2,798 4,516 958 17.9 67.4 Marion 679 477 3,156 2,640 501 14.1 81.5 Catoosa 617 167 3,085 3,601 680 11.9 93.4 Dade 302 107 2,415 1,574 285 6.5 99.9 Roane 4967 92331 30865 4300 285 296.9 Jackson, AL 4389 44333 31502 4742 1494 176.1 Floyd, GA 10057 31821 22736 7139 976 154.0 McMinn 3348 10216 10829 5546 1268 73.3 Whitfield, GA 2732 1747 7283 7386 991 54.2 Rhea 1405 302 2625 3643 149 31.2 Loudon 804 4035 5899 5338 360 24.3 DeKalb, AL 1193 741 4776 5867 5765 21.3 Bradley 1233 419 4230 7551 1916 21.1 Warren 1164 1189 1869 3675 446 20.7 Monroe 743 154 2387 3420 554 16.4 Gordon, GA 872 200 3645 4019 2630 15.8 Fannin, GA 614 65 887 1266 283 14.2 Franklin 644 482 2100 2929 1512 13.4 Chattooga, GA 450 1228 1834 1634 197 11.7 Murray, GA 576 130 2067 1700 910 11.4 Polk 295 2066 900 949 553 11.3 Cherokee, NC 428 143 921 1753 111 10.6 Grundy 202 164 1000 1150 1170 4.8 Bledsoe 203 31 475 528 335 4.5 Meigs 198 112 885 871 118 4.3 Sequatchie 140 22 304 591 173 3.4 Van Buren 118 178 291 320 74 3.3 Based on the analysis for this factor there appears to be emissions in all MSA counties and the adjacent county of Jackson, AL, which show a potential to contribute. Other adjacent counties with large emissions ( McMinn and Roane, TN and Floyd, GA) are included in other nonattainment areas.

Factor 2: Air quality in potentially included versus excluded areas The following table contains the 2001 2003 PM2.5 Design Values for all Chattanooga MSA Counties and adjacent counties. ( MSA counties are in bold.)

County 2001 2003 design value Hamilton 16.1 Walker 15.6 Roane 14.2 Floyd, GA 15.7 6 239 McMinn 14.6 Loudon 15.4 * DeKalb, AL 14.7 * Incomplete data that is not sufficient to determine attainment/ nonattainment. Data substitution does not apply.

Based on this factor, Hamilton County, TN and Walker and Floyd Counties in GA are violating the PM 2.5 standard. Catoosa County, GA is located between violating monitors in Hamilton and Walker Counties.

Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table contains the populations for the counties in the Chattanooga MSA and some adjacent counties. Urban population figures were not available. ( MSA counties are in bold.) County 2002 Population Percent of MSA Population ( 2002) 2002 Population Density ( people/ mile^ 2) Hamilton 309,321 65.7 570 Walker 61,949 13.2 139 Marion 27,654 5.9 55 Catoosa 56,341 12.0 348 Dade 15,615 3.3 90 Roane 52,316 145 Jackson, AL 54,035 50 Floyd, GA 92,606 181 McMinn 50,051 116 Whitfield, GA 87,037 300 Based on the analysis for this factor, there appears to be population sufficient to indicate a contribution by the following MSA counties: Hamilton, Walker, and Catoosa. The five adjacent counties also have population with a potential to contribute.

Factor 4: Traffic and commuting patterns Commuting Information Hamilton has a working population of 146, 824   Commuters who remain in Hamilton: 133,644 ( 91%)

Marion has a working population 11766.   Commuters who remain in Marion: 5596 ( 48%)   Commuters from Marion to Hamilton: 4271 Dade has a working population of 6983.   Commuters who remain in Dade: 2363   Commuters from Dade to Hamilton: 3091 ( 44%)   Commuters from Dade to Walker: 747 6 240 Catoosa has a working population of 26710.   Commuters who remain in Catoosa: 7167   Commuters from Catoosa to Hamilton: 12320 ( 46%)   Commuters from Catoosa to Walker: 1937 Walker has a working population of 27223.   Commuters who remain in Walker: 11244 ( 41%)   Commuters from Walker to Hamilton: 9098 Whitfield, GA has a working population of 38,909   Commuters who remain in Whitfield: 33,796 ( 87%)   Remaining commuters do not commute to the Chattanooga MSA DeKalb, AL has a working population of 7798   Commuters who remain in DeKalb: 5179 ( 66%)   Remaining commuters do not commute to the Chattanooga MSA The following table contains the vehicle miles traveled ( thousand miles) for the counties in the Chattanooga MSA and some adjacent counties with significant weighted emissions scores. ( MSA counties are in bold.)

County 2002 VMT ( thousand miles/ year) Hamilton 3,743 Walker 742 Marion 654 Catoosa 810 Dade 512 Roane 784 Jackson, AL 786 Floyd, GA 948 McMinn 787 Whitfield, GA 1423 Based on the analysis for this factor the VMT for all MSA counties indicate a potential to contribute. Although Whitfield County has a relatively high VMT, none of the commuters go to the Chattanooga MSA.

Factor 5: Population Growth 6 241 The following table has the population and population growth figures for the Chattanooga MSA and some adjacent counties with significant weighted emissions scores. ( MSA counties are in bold.)

County 2002 Population Growth ( 90 00) % Growth ( 90 00) Hamilton 309,321 22360 8 Walker 61,949 2713 5 Marion 27,654 2916 12 Catoosa 56,341 10818 25 Dade 15,615 2007 15 Roane 52,316 4683 10 Jackson, AL 54,035 6130 13 Floyd, GA 92,606 9314 11 McMinn 50,051 6632 16 Whitfield, GA 87,037 11063 15 Based on the analysis for this factor, there appears to be significant growth on a percentage basis in Catoosa County that indicates a contribution to the air quality in the Chattanooga MSA.

Factor 6: Meteorology This factor did not play a significant role in the decision making process.

Factor 7: Geography/ topography The Chattanooga area does not have any geographical or topographical boundaries limiting its airshed.

Factor 8: Jurisdictional boundaries Hamilton and Meigs Counties, TN and Catoosa County, GA were designated nonattainment for the 8 hour ozone standard on April 15, 2004.

This factor did not play a significant role in the decision making process.

Factor 9: Level of control of emission sources Sources in the Chattanooga area are subject to Prevention of Significant Deterioration ( PSD) requirements, Control Technology Guidelines Reasonable Available Control Technology ( CTG RACT)  ( Hamilton County only), Maximum Achievable Control Technology ( MACT) for Hazardous Air Pollutants ( HAP), New Source Performance Standards ( NSPS), and the NOx SIP call.

This factor did not play a significant role in the decision making process.

Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States 6 242 EPA's initial nonattainment recommendation on June 29, 2004 included Marion County, TN as part of the Chattanooga nonattainment area. Upon further analysis, including the review of additional material submitted by the state, EPA is revising its recommendation and designating Marion County as attainment/ unclassifiable.

Marion County, TN Marion County has a small population ( 27,654) and population density ( 55 people/ mile2). There are no large point sources and the County only contributes 17.2 percent of the total MSA PM2.5 emissions ( 679 tpy), 7.1 percent of the total SO2 emissions ( 477 tpy), and 10.0 percent of the total NOx emissions ( 3156 tpy). In addition, the topography analysis indicates that the Lookout Mountain Ridge ( 2100 feet) separates the Marion County emissions from the violating monitors. The County is located to the west of the ridge while the violating monitors reside to the east of the ridge.

McMinn County, TN See the McMinn County Section in the Knoxville, TN TSD.

Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following county as nonattainment for the Chattanooga, TN GA area: Hamilton.

<IP_ADDRESS> Knoxville Area The Knoxville, TN MSA contains the counties of Anderson, Blount, Knox, Loudon, Sevier and Union. Based on air quality data for 2001 2003 the following MSA counties contain PM2.5 ambient air monitors ( Design values are included in parenthesis): Knox County ( 16.8), Blount County ( 14.4), and Loudon County ( 15.4). Two adjacent Tennessee counties also contain PM2.5 monitors: Roane County ( 14.2), and McMinn County ( 14.6).

In a February 12, 2004 letter, the State recommended that Knox, Roane, and McMinn Counties be designated nonattainment based on 2000 2002 monitoring data. The State revised its recommendation on May 7, 2004, to recommend that McMinn and Roane Counties be designated attainment due to 2001 2003 data. Therefore, the State's current recommendation for the Knoxville MSA PM2.5 nonattainment area only includes Knox County and recommends that all other MSA and adjacent counties be designated attainment. The State submitted some justification for this recommendation, however, they indicated that the detailed emission information would be provided at a later date. Union County has very small amounts of PM2.5 and precursor emissions, indicating no contribution. Therefore, EPA agrees that Union County should be designated attainment/ unclassifiable. Roane and McMinn, counties adjacent to the MSA, currently contain attaining ambient air monitors, however, Roane and McMinn counties have significant SO2 and NOx emissions which contribute to the violations. EPA is modifying the State's recommendation and will review the additional information during the 120 day period following the notification letter. 6 243 We have included in our recommended nonattainment area Roane County that is adjacent to the Knoxville MSA with a violating monitor, that is generally rural in character, and that contains an identifiable large emitting facility or facilities ( e. g., power plants) which we believe contributes to the nearby nonattainment problem. We have included this county in our initial recommendations in order to ensure that a sufficient portion of the county, including such large facilities, is included within the boundaries of the nonattainment area as part of the final designations. We invite you to submit to us a recommendation as to what portion of this adjacent county, encompassing the large facility or facilities, should be designated nonattainment.

Based on EPA's analysis of the available information, EPA is modifying the recommended nonattainment area to include all of the MSA counties, except Union, and the adjacent counties of Roane and McMinn.

Area EPA Recommendation State Recommendation Knoxville, TN Full counties: Anderson, Blount, Knox, Loudon, Sevier, Roane, and McMinn Full counties: Knox Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table contains the 2001 PM2.5, SOx, NOx, VOC, and ammonia emissions in tons per year and weighted emissions scores for the counties in the Knoxville MSA and some adjacent counties. ( MSA counties are in bold.)

County PM SOx NOx VOC Amm Weighted Emissions Score Cumulative Weighted Emissions Score 6 244 Knox 1995 3005 23648 29966 1220 28.6 28.6 Anderson 2891 45986 23020 5328 265 27.5 56.1 Blount 3535 2999 5282 8250 606 22.4 78.5 Sevier 711 433 2838 4756 472 9.4 87.9 Loudon 804 4035 5899 5338 360 8.8 96.7 Union 325 156 1057 1067 184 3.2 99.9 Roane 4967 92,331 30865 4300 285 38.0 McMinn 3348 10216 10829 5546 1268 27.0 Rhea 1405 302 2625 3643 149 18.1 Haywood, NC 1218 8701 8669 4923 547 14.8 Jefferson 1407 183 3220 4194 662 14.4 Scott 1113 122 1338 1813 294 11.1 Monroe 743 154 2387 3420 554 9.6 Cumberland 682 181 3682 3989 532 8.6 Whitley, KY 521 675 3646 3017 171 8.1 Campbell 527 268 3323 3323 161 7.5 Claiborne 509 165 1420 2554 475 6.0 McCreary, KY 346 188 1414 904 52 5.8 Cocke 400 247 2507 2361 357 5.5 Swain, NC 12.93 28 141 567 1210 199 5.3 Morgan 288 98 1252 929 222 4.3 Graham, NC 209 70 377 981 47 3.2 Grainger 288 80 893 1647 287 3.2 Meigs 198 112 885 871 118 2.4 Based on the analysis of emissions, there appears to be very small emissions in Union County for all the relevant pollutants. The other counties in the MSA and the counties of McMinn and Roane have significant emissions of some or all of the relevant pollutants, indicating contribution to the violations.

Factor 2: Air quality in potentially included versus excluded areas The following table contains the 2001 2003 PM2.5 Design Values for all Knoxville MSA Counties and adjacent counties. ( MSA counties are in bold.) 6 245 County 2001 2003 design value Knox 16.8 Blount 14.4 Loudon 15.4 *

Roane 14.2 McMinn 14.6 Haywood, NC 13.6 Swain, NC 12.9 * Incomplete data that is not sufficient to determine attainment/ nonattainment. Data substitution does not apply.

There are two monitors in the MSA that are violating and one MSA monitor ( Blount County) that is attaining. The four monitors in adjacent counties are attaining.

Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table contains the populations for the counties in the Knoxville MSA and some adjacent counties with significant weighted emissions scores. ( MSA counties are in bold.)

County 2002 Population Percent of MSA Population ( 2002) Population Density ( People/ mile2) Knox 389327 55.3 765 Anderson 71627 10.2 212 Blount 109849 15.6 197 Sevier 74456 10.6 126 Loudon 40631 5.8 177 Union 18541 2.6 83 Roane 52316 145 McMinn 50051 116 6 246 Based on the analysis for this factor, there appears to be population sufficient to indicate a contribution by Knox, Anderson, Blount, and Sevier Counties and the adjacent counties of Roane and McMinn. Union County has very low population and population density supporting an attainment/ unclassifiable designation.

Factor 4: Traffic and commuting patterns Commuting Information  Following is an analysis of the commuting in the Knoxville MSA. Knox County has the most commuters of any of the MSA counties. As described below, 86 % of the Knox County commuters remain in Knox County, contributing 79 % of the commuting in Knox County. People from Blount and Anderson Counties commute to Knox County contributing approximately 7% and 4 %, respectively, with the remaining MSA counties contributing 3 % or less. Union County has the smallest number of commuters and the least contribution to the Knox County monitor.

Knox County, the core MSA county, has a total of 184,824 commuters.  Commuters who remain in Knox County: 158,292 Anderson County, an MSA county has a total of 30,688 commuters  Commuters that remain in Anderson County: 20,029  Commuters from Anderson County to Knox County: 8,115 Blount County, an MSA county, has a total of 49,250 commuters  Commuters that remain in Blount County: 31,298  Commuters from Blount County to Knox County: 13,611 Loudon County, an MSA county, has a total of 17,671 commuters.  Commuters who remain in Loudon County: 8,951  Commuters from Loudon County to Knox County: 4,580 Sevier County, an MSA county, has a total of 34,389 commuters  Commuters who remain in Sevier County: 25,388  Commuters from Sevier County to Knox County: 6,522 Union County, an MSA county, has a total of 7,302 commuters  Commuters who remain in Union County: 2,573  Commuters from Union County to Knox County: 3,873 The following table contains the vehicle miles traveled ( thousands of miles) for the counties in the Knoxville MSA and some adjacent counties. 6 247 County 2000 VMT ( thousand miles/ year)

Knox 5135 Anderson 875 Blount 1205 Sevier 724 Loudon 728 Union 126 Roane 784 McMinn 787 Knox and Blount counties contain 58 % and 14 % of the VMT of the MSA VMT, respectively. The remaining counties contribute less than 10 % each of the MSA VMT with Union County contributing 1 %. The small contribution from Union County supports an attainment/ unclassifiable designation. The adjacent counties each contribute an amount equivalent to 9 % of the total MSA VMT. ( The VMT from the adjacent counties was not used to calculate the total MSA VMT.)

Factor 5: Expected growth The following table has the population and population growth figures for the Knoxville MSA counties and some adjacent counties with significant weighted emissions scores.

County 2002 Population Growth ( 90 00) % Change ( 90 00) Knox 389327 46283 14 Anderson 71627 3080 5 Blount 109849 19854 23 Sevier 74456 20127 39 Loudon 40631 7831 25 Union 18541 4114 30 Roane 52316 4683 10 McMinn 50051 6632 16 The population growth has been relatively high for all of the MSA counties on a percentage basis, except Anderson, indicating potential contribution to the particulate matter levels in the MSA. Anderson County contributed only 3 % of the MSA growth. Although the percent growth in Union County was 30 %, its contribution to the MSA growth was only 4 %. McMinn and Roane Counties ( adjacent) have a percent growth of 16 % and 10 %, respectively. 6 248 Factor 6: Meteorology This factor did not play a significant role in the decision making process.

Factor 7: Geography/ topography This factor did not play a significant role in the decision making process.

Factor 8: Jurisdictional boundaries Knox, Anderson, Blount, Jefferson, Loudon, Sevier Counties and a portion of Cocke County were designated nonattainment for the 8 hour ozone standard.

This factor did not play a significant role in the decision making process.

Factor 9: Level of control of emission sources Anderson, Blount, Jefferson, Loudon, Sevier Subject to Prevention of Significant Deterioration ( PSD) requirements, Control Technology Guidelines Reasonable Available Control Technology ( CTG RACT, Maximum Achievable Control Technology ( MACT) for Hazardous Air Pollutants ( HAP), New Source Performance Standards ( NSPS)

This factor did not play a significant role in the decision making process.

Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States EPA's initial nonattainment recommendation on June 29, 2004 included McMinn, Roane, and Sevier Counties, TN as part of the Chattanooga nonattainment area. Upon further analysis, including the review of additional material submitted by the state, EPA is revising its recommendation and designating McMinn County as unclassifiable and Sevier County as attainment/ unclassifiable. EPA is designating a portion of Roane County that encompasses the TVA Kingston power plant as nonattainment. The remainder of Roane County will be designated as attainment/ unclassifiable.

McMinn County, TN The McMinn County emissions, represented in the table below, indicate that the county does not contribute to the violations in Knoxville. The county is located outside of the Metropolitan Statistical Area, has a small population ( 50,051), and low population density ( 116 people/ mile2). McMinn County and the State of Tennessee submitted additional information, correcting the emissions for Bowater Newsprint and for McMinn County. The corrected emissions data for McMinn County emissions are represented in tons per year in the following table:

County PM 2.5 SO2 NOx VOC Ammonia McMinn 1479 5775 10701 5004 1250 6 249 Based on incomplete monitoring data and data substitution not being a viable alternative, EPA has changed its June 2004 recommendation of nonattainment and is designating McMinn County unclassifiable. The county had monitoring data for 2000 2002 that was violating and has incomplete data for 2001 2003. Applying the data substitution policy will not confirm attainment.

Sevier County, TN Sevier County has low emissions. The data indicate that the county only contributes 7.0 percent of the total MSA PM2.5 emissions ( 711 tpy), 0.8 percent of the total SO2 emissions ( 433 tpy), and 4.6 percent of the total NOx emissions ( 2838 tpy). The County is located within the Metropolitan Statistical Area, however it has a small population ( 74,456), 10.6 percent of the MSA population. Additionally, the County has a population density of 126 people/ mile2 which is low compared to Knox County that has a population density of 765 people/ mile2.

Roane County, TN In the June 29, 2004, letters from EPA to the States responding to their designation recommendations, EPA recommended the designation of a number of counties primarily because of high pollutant emissions from power plants. Most of these plants were located in nearby counties adjacent to the metropolitan area ( as defined either by the 1999 or 2003 OMB metropolitan area definitions). EPA suggested that a State could provide a partial county boundary that would encompass the relevant power plant to include it in the nonattainment area. Roane County, Tennessee is one of those counties. Roane County has low population ( 52,316 compared to 389,327 in Knox County, the predominant county in the Knoxville MSA), low population density ( 145 people per square mile compared to 765 in Knox County), low VMT ( 784,000 miles compared to 5,135,000 in Knox County ), and the only large point source is the Kingston Fossil Plant. Additionally, Roane County has a monitor that is indicating attainment with a design value of 14.2 ( 2001 2003).

A number of states responded to this suggestion with a series of connected townships or other unique boundaries. Some states also suggested an alternative approach in which partial county areas for power plants in some cases could be small " free standing" boundaries that are considered part of the nearby nonattainment area. In this way, it would not be necessary to include additional townships or other minor civil divisions comprising an odd shaped " land connector" extending from the main part of the nonattainment area to the power plant. The State of Tennessee subsequently submitted a partial county recommendation that included the Kingston Fossil Plant.

After considering these comments from the States, EPA agrees that such an approach is preferable in cases where a partial county nonattainment boundary has not already been established for that source ( e. g. partial county boundaries recently established for 8 hour ozone nonattainment areas). For purposes of consistency, EPA has decided that free standing portions of nonattainment areas should be based on a pre existing boundary for a minor civil division ( such as a township or tax district) or other boundary defined for governmental use ( such as a census block group or census tract). Accordingly, this kind of partial county boundary should not 6 250 be defined simply as the boundary of the facility. Therefore, EPA is designating the census block group identifier ( StateFIPs CoFIPs Tract# Block Group#) 47 145 0307 2 portion of Roane County as part of the Knoxville nonattainment area.

Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following counties as nonattainment for the Knoxville, TN area: Anderson, Blount, Knox, Loudon, and Roane ( Partial).

Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following county as unclassifiable for the McMinn County, TN area: McMinn.