Workshop Q Kentucky: Major Air Permitting, Regulatory & - PDF document

Workshop Q Kentucky: Major Air Permitting, Regulatory & Compliance Developments Tuesday, March 27, 2018 2 p.m. to 3:15 p.m.

Biographical Information Sean Alteri, Director, Kentucky Division for Air Quality 200 Fair Oaks Lane, 1 st Floor, Frankfort, KY 40601 502.564.3999 Fax 502.564.4666 Sean.Alteri@ky.gov Mr. Alteri is currently serving as the Director of the Division for Air Quality. The Division is comprised of 166 full-time employees divided into 4 technical branches and 20 specialized sections and is responsible for carrying out the Clean Air Act requirements on behalf of the Commonwealth. During his 20-year career with the Division, Mr. Alteri has worked as a permit engineering assistant, Regulation Development Supervisor, Technical Services Branch Manager, and the Assistant Director. Currently, he is also serving as a board member of the Association of Air Pollution Control Agencies (AAPCA) and the Southeastern States Air Resources Managers (SESARM). Mr. Alteri is a graduate of the University of Kentucky College of Engineering (BS Chemical, 1997) and resides on a family farm in Anderson County. Carolyn M. Brown, Partner, Dinsmore & Shohl LLP 250 West Main Street, Suite 1400, Lexington, KY 40507 859.425.1092 Fax 859.425.1099 carolyn.brown@dinsmore.com Carolyn Brown is a partner with Dinsmore & Shohl LLP and chairs the firm’s Environmental Practice Group. Her practice focuses on all areas of environmental law and includes counseling on regulatory requirements, permitting and transactional issues as well as environmental litigation. She received her B.S. from the University of Kentucky in 1979 and her J.D. from the University of Kentucky in 1982. She currently chairs the Kentucky Chamber of Commerce Energy and Environment Policy Council. She previously chaired the Energy, Environment and Resources Law Section of the Kentucky Bar Association and has served on the Commerce Lexington Public Policy Council. She is a fellow in the American College of Environmental Lawyers and serves on the Executive Committee. Carolyn is resident in the firm’s Lexington office. Philip A. Imber, Manager Air Section, Environmental Affairs, LG&E and KU 220 W. Main Street, Louisville, KY 40202 M: 502-552-6070 O: 502-627-4144 F: 502-217-2809 philip.imber@lge-ku.com Philip Imber spent the first his career in the chemical process industry as a chemical engineer. In 2001, he transitioned into the electric utility sector, joining LG&E and KU (LKE) as a chemical engineer. He was promoted to Manager of Major Capital Projects in 2010. During his first fifteen years at LG&E, Philip developed, permitted, and constructed large capital projects across LKE’s electric generating fleet to add generation capacity and improve the environmental performance of the fleet. In 2016, Philip transitioned to the Environmental Affairs department at LKE to manage the team responsible for the company’s regulatory compliance and strategy for Air Programs. Philip received a bachelor’s degree in chemical engineering from the University of Michigan and a master’s degree of business from Bellarmine University. Philip is married (Allison) with three children – Louise (12), Beatrice (11), and Henry (8). Philip is active in volunteer and athletic endeavors.

Kentucky: Major Air Permitting, Regulatory & Compliance Developments 27 th Annual Business and Industry’s Sustainability and Environmental Health and Safety Symposium March 27, 2018 Sean Alteri, Director Kentucky Division for Air Quality

Mission To protect human health and the environment by achieving and maintaining acceptable air quality through: • Operation of a comprehensive air monitoring network; • Creating effective partnerships with air pollution sources and the public; • Timely dissemination of accurate and useful information and data; • Judicious use of program resources; and • Maintenance of a reasonable and effective compliance program. 2

Emission Trends 3

Emission Trends 4

Emission Trends 5

Emission Trends 6

Emission Trends

Emission Trends

2008 Ozone NAAQS • July 5, 2017 ‐ EPA finalized rule redesignating the Kentucky portion of the Cincinnati, OH‐KY‐IN area to attainment. • All areas within Kentucky are attaining the 2008 Ozone Standard. 9

2008 Ozone NAAQS February 28, 2018 – SIP Submittal to EPA • The Division for Air Quality demonstrates that criteria pollutants that contribute to the formation of ozone in the state of Kentucky: • Do not contribute significantly to nonattainment of the NAAQS in any other state; and • Do not interfere with maintenance of the NAAQS in any other state. • Parallel Processing • Public comment period began March 1, 2018 • Public hearing scheduled for March 30, 2018 10

2008 Ozone NAAQS Reformulated Gasoline September 13, 2017 – SIP Revision to EPA • The Division for Air Quality demonstrates that the removal of the federal reformulated gasoline (RFG) requirements in Boone, Campbell, and Kenton Counties: • Does not interfere with any applicable requirement concerning attainment and reasonable further progress in nonattainment or maintenance areas. • Includes updated on‐road and non‐road source emissions inventories reflecting the removal of RFG as a control measure for the Northern Kentucky area, and replaced those emissions inventories previously submitted with the redesignation request for the 2008 8‐hour Ozone NAAQS. 11

2008 Ozone NAAQS Reformulated Gasoline February 14, 2018 – EPA Proposed Approval • “EPA is proposing to approve this SIP revision and the corresponding non‐interference demonstration because EPA has preliminarily determined that the revision is consistent with the applicable provisions of the CAA.” 12

2015 Ozone NAAQS November 16, 2017 – Initial Designations • Designated 101 of the 120 Kentucky counties. • All areas in this round were designated Attainment/Unclassifiable. • Counties not designated in this round: Louisville, KY‐IN: Bullitt, Hardin, Henry, Jefferson, Larue, o Meade, Nelson, Oldham, Shelby, Spencer, Trimble. Cincinnati, OH‐KY‐IN: Boone, Bracken, Campbell, Gallatin, o Grant, Kenton, Mason, Pendleton. 13

2015 Ozone NAAQS December 20, 2017 – “120 Day” letter notifies states of EPA’s proposed designations for remaining areas. • Counties will be designated as nonattainment if there is monitoring data showing a violation or if the EPA determines that the area is contributing to a violation of the standards in a nearby area. Louisville, KY‐IN: Bullitt, Jefferson, Oldham. o Cincinnati, OH‐KY‐IN: Portions of Boone, Campbell, Kenton. o All remaining counties will be designated o Attainment/Unclassifiable . 14

2015 Ozone NAAQS Louisville, KY‐IN Monitoring Data (ppm) Design Value County/Site Name AQS Site ID 2014 2015 2016 State 2014‐2016 KY Bullitt – Shepherdsville 21‐029‐0006 0.065 0.067 0.067 0.066 KY Hardin – Elizabethtown 21‐093‐0006 0.062 0.066 0.068 0.065 KY Jefferson – Bates 21‐111‐0027 0.065 0.071 0.073 0.069 KY Jefferson – Watson 21‐111‐0051 0.069 0.069 0.070 0.069 KY Jefferson – Cannons 21‐111‐0067 0.070 0.076 0.076 0.074 KY Oldham – Buckner 21‐185‐0004 0.068 0.073 0.069 0.070 IN Clark – Charlestown 18‐019‐0008 0.066 0.074 0.072 0.070 IN Floyd – New Albany 18‐043‐1004 0.068 0.067 0.073 0.069 15

2015 Ozone NAAQS Cincinnati, OH‐KY‐IN Monitoring Data (ppm) Design State County/Site Name AQS Site ID 2014 2015 2016 Value 2014‐2016 KY Boone – East Bend 21‐015‐0003 0.062 0.062 0.065 0.063 KY Campbell – NKY 21‐037‐3002 0.071 0.071 0.069 0.070 OH Butler – Hamilton 39‐017‐0004 0.070 0.070 0.076 0.072 OH Butler – Middletown 39‐017‐0018 0.069 0.070 0.074 0.071 OH Butler – Oxford 39‐017‐9991 0.069 0.068 0.072 0.069 OH Clermont – Batavia 39‐025‐0022 0.068 0.070 0.073 0.070 OH Clinton – Laurel Oaks 39‐027‐1002 0.070 0.070 0.071 0.070 OH Hamilton – Sycamore 39‐061‐0006 0.071 0.072 0.075 0.072 OH Hamilton – Colerain 39‐061‐0010 0.073 0.070 0.073 0.072 OH Hamilton – Taft 39‐061‐0040 0.069 0.071 0.073 0.071 OH Warren ‐ Lebanon 39‐165‐0007 0.071 0.071 0.074 0.072 16

2010 SO 2 NAAQS • Round 1: Designations based on monitoring data. o Campbell County – Redesignated to Attainment, March 10, 2017. o Jefferson County – Currently nonattainment. 2014‐2016 2014 2015 2016 DV Jefferson ‐ Watson Ln 148.6 54.2 26.1 76 * 1‐hour standard is 75 parts per billion (ppb) calculated as the 3‐ year average of the 99 th percentile of the annual distribution of daily maximum 1‐hour average concentrations. 17

2010 SO 2 NAAQS 18

2010 SO 2 NAAQS • Round 2: Designated areas with 1) Newly violating monitors; or 2) areas with stationary sources emitting more than 16,000 tons of SO 2 in 2012 or more than 2,600 tons of SO 2 with an emissions rate of at least 0.45 lbs SO 2 /mmbtu in 2012. o Ohio County – D.B. Wilson Generating Station o Pulaski County – John S. Cooper Power Station June 20, 2016 – Both counties designated as unclassifiable. 19