1

Technical Support Document for the Modeling Portions of the State of West Virginia ’s

Regional Haze State Implementation Plan (SIP) Entitled “ West Virginia Regional Haze State Implementation Plan to Preserve, Protect and Improve

Visibility in Class I Federal Areas Final June 2008 ”

TSD Prepared February , 201 1 Todd A. Ellsworth Office of Air Monitoring and Anal ys is, 3AP 40 U.S. Environmental Protection Agency , Region 3

1650 Arch Street Philadelphia, Pennsylvania 19103

______________________ /s/

______________________ Reviewed b y Walter Wilkie, Associate Director, Office of Air Monitoring and Anal ys is (3AP40)

_________ 3/11/2011

________ Date Signed2



### Technical Support Docum ent for the Modeling Portion s o f the State of West Virginia ’s Regional Haze State Im plementation Plan

(SIP) Entitled “ West Virginia Regional Haze State Im plementation Plan to Preserve, Protect and Im prove

Visibility in Class I Federal Areas

Final June 2008 ” Purpose of the Technical Support Document This Technical Support Document (TSD) describes the Environmental Protection Agency ’s (EPA’s) evaluation of the modeling portion s of West Virginia ’s State Implementation Plan (SIP) revision entitled “ West Virginia Regional Haze State I mplementation Plan to Preserve, Protect and Improve Visibility in Class I Federal Areas Final June 2008 ”. T his SIP revision will h ereafter be referred to as the West Vi rginia (WV) Haze SIP

. The purpose of this TSD is to provide more detailed information than can be contained in the official notice published in the Federal Register . Readers who need more information than we provide in this TSD or want to review the mode ling in more detail should read the above referenced West Virginia Haze SIP

. 

### The Regulatory Fram ew ork In section 169A(a)(1) of the 1977 Amendments to the CAA, Congress created a program for protecting visibility

in the nation’s national parks and wilde rness areas. This section of the CAA establishes as a national goal the “prevention of an y future, and the remed yi ng of an y existing, impairment of visibility in mandatory

Class I Federal areas 1 which impairment results from manmade air pollution.” On De cember 2, 1980, EPA promulgated regulations to address visibility impairment in Class Iareas that is “reasonabl y attributable” to a single source or small group of sources, i.e., “reasonabl y attributable visibility

impairment” (RAVI)

. See 45 FR 80084. T hese regulations

1 Areas designated as mandatory Class I Federal areas consist of national parks exceeding 6000 acres, wilderness areas and national memorial parks exceeding 5000 acres, and all international parks that were in existence on August 7, 1977 (42 U.S.C. 7472(a)). In accordance with s ection 169A of the CAA , EPA , in consultation with the Department of Interior, promulgate d a list of 156 areas where visibility is identified as an important value ( see 44 FR 69122, November 30, 1979). The extent of a mandatory Class I area includes subsequent changes in boundaries, such as park expansions (42 U.S.C. 7472(a)). Altho ugh states and tribes may designate as Class I additional areas which they consider to have visibility as an important value , the requirements of the visibility program set forth in section 169A of the CAA apply only to ‘‘mandatory Class I Federal areas.” Each mandatory Class I Federal area is the responsibility of a ‘‘Federal Land Manager’’ (FLM)

. (42 U.S.C. 7602(i))3

represented the first phase in addressing visibility impairment. EPA deferred action on regional haze that emanates from a variet y of sources until monitoring, modeling and scientific knowledge about the relationships between pollutants a nd visibility

impairment were improved. Congress added section 169B to the CAA in 1990 to address regional haze issues. EPA promulgated a rule to address regional haze on July 1, 1999 ( see 64 FR 35713), the Regional Haze Rule ( RHR) . The RHR revised th e existing visibility regulations to integrate into the regulation provisions addressing regional haze impairment and established a comprehensive visibility protection program for Class I areas. The requirements for regional haze, found at 40 CFR 51.308 and 51.309, are included in EPA’s visibility

protection regulations at 40 CFR 51.300

- 309. The RH R addressed the combined visibility effects of various pollution sources over a wide geographic region. 40 CFR 51.308(b) requires states to submit the first implementation plan addressing regional haze visibility impairment no later than December 17, 2007. Consequently , all 50 states , including those without Class Iareas , Washington, D.C., and the Virgin Islands, are required to submit Regional Haze SIPs 2

. T he USEPA designated five Regional Planning Organizations (RPOs) to assist with the coordination and cooperation needed to address the visibility issue. West Virginia is among those states that make up the southeastern portion of the contiguous United State s known as VISTAS (Visibility Improvement

– State and Tribal Association of the Southeast), and includes the eastern band of the Cherokee Indians in addition to the following states: Alabama, Florida, Georgia, Kentucky , Mississippi, North Carolina, South C arolina, Tennessee, and Virginia (See Figure 1)

. Studies show that West Virginia significantl y contributes visibility impairment in the following Class I areas: Dolly Sods Wilderness Area, Otter Creek Wilderness Area, James River Face Wilderness Area, Linville Gorge Wilderness Area, and Shenandoah National Park. With the help of the Visibility Improvement

- State and Tribal Association of the Southeast (VISTAS) RPO, West Virginia has developed a SIP to address visibility impairment in all of these Class I Federal Areas

. Figure 2 shows the 18 mandatory Federal Class I areas in the VISTAS Region

.

2 Albuquerque/Bernalillo County in Ne w Mexico must also submit a regional haze SIP to completely satisfy the requirements of section 110(a)(2)(D) of the CAA for the entire State of Ne w Mexico under the New Mexico Air Quality Control Act (section 74

- 2

- 4).4

Figure 1. Geographical Areas of Regional Planning Organizations

Figure 2. Class I Areas in the VISTAS Region5



### Introduction to West Virginia ’ s Visibility State Implementation Plan EPA promulgated a rule to address regional haze on July 1, 1999 ( see 64 FR 35713), the RHR. The RH R addressed the combined visibility effects of various pollution sources over a wide geographic region. 40 CFR 51.308(b) requires states to submit the first implementation plan addressing regional haze visibility impairment no later than December 17, 2007. This SIP was developed based on consultations and work

- products of the VISTAS Regional Planning Organization (RPO). It encompasses 1) monitoring strategies for evaluating visibility impacts, 2) baselines and trends, 3) long

- term strategies (LTS), 4) how West Virginia meets its fair share of the “reasonable progress goals” (RPG) towards reducing visibility impairment in Class I areas, and 5) Best Available Retrofit Technology (BART). VISTAS states agreed upon a ≥ 1 percent sulfate attribution to a Class I area in order for an upwind state to meet the definition of “significantly contributing” to visibility impairment for that Class I area. Studies show that West Virginia significantly contributes visibility impairment in the following Class I area s: Dolly Sods Wilderness Area, Otter Creek Wilderness Area, James River Face Wilderness Area, Linville Gorge Wilderness Area, and Shenandoah National Park. Therefore, this SIP focuses on how West Virginia’s control measures will improve visibility i n these areas. The West Virginia Division of Air Quality ( WV DAQ ) believes their Haze SIP demonstrates that West Virginia has met its BART, RPG and LTS oblig ations for the first visibility impairment planning period through existing West Virginia/Federal regulations and on

- the

books/on

- the

- way

federal emission controls. In addition to extensive consultation with the VISTAS states, West Virginia has consulted w ith Federal Land Managers (FLMs) responsible for the Class I areas, and the EPA in the development of this SIP. 

### W hat Are The Components Of A Modeled Regional Haze Dem onstration ? Modeling Process Overview The goal of the regional haze program is to return to natural conditions by 2064, and States are required to demonstrate, by the end of the first planning period ( by 2018), reasonable progress toward meeting that goal. West Virginia is a member of the VI STAS RPO . The VI STAS RPO was tasked with the assignment of preparing a PM 2.5 modeling platform that all member states could use to model their LTS s to demonstrate re asonable progress by 2018 in meeting the ultimate goal of natural visibility

conditions by

2064. The regional haze modeling was coordinated b y the Southeast Regional Planning Organization, Visibility

Improvement State and Tribal Association of the Southeast ( VI STAS), which is comprised of the ten Southeast States (Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee, Virginia and West Virginia) and the local programs and tribal agencies located within these states. VI STAS contracted with Environ International Corp, Alpine Geophy sics, LLC and the Universit y6

of California Riverside to perform the emissions and air qualit y modeling for this r egional haze state and tribal implementation plans. The VISTAS RPO used the Community Multi

- scale Air Quality

model (CMAQ) version 4. 5.1 as its photochemical grid model . The model use s simulations o f chemical reactions, emission of PM 2.5 and PM 2.5 precursors and a sophisticated meteorological model ( The P ennsylvania State University /National Center for Atmospheric Research Mesoscale Meteorological Model (MM5) ) to produce speciated PM 2.5 concentrati ons over the eastern United States. The meteorological data used in the meteorological model was for the 2002 base ye ar
. The photochemical grid model was run with the base year meteorology

and base ye ar emissions to determin e if the model performance was satisfactory . Once the model performance was determined to be adequate, PM 2.5 concentrations were modeled b y running the model with projected emissions for 2009 and 20 18 and the original 2002 meteorology

. The meteorolog y was held constant so that the re sults of changing the emissions would not be influenced b y changing meteorology. The EPA modeling guidance 3 recommend s that modeling be used to develop relative response factors for each of 6 components of particulate matter between a base period (2000

- 20 04) and a future 5

- ye ar period which will be reviewed in 2018. PM c omponents used for regional haze

- related applications are:

- mass associated with sulfates;

- mass associated with nitrates;

- mass associated with organic carbon;

- mass associated with elemental carbon;

- mass associated with fine soil (i.e., crustal material);

- mass associated with coarse particulate matter (i.e., PM 10 - PM 2.5 ). Current speciated measurements in a Class I area are used in an empirically derived equation to estimate li ght extinction for each day with measurements. Days are ranked according to their resulting light extinction (measured in deciviews). This ranking is used to identify

the 20% of day s with worst and 20% of day s with best visibility during each ye ar in the b ase period. The 20% worst and best day s are examined to estimate appropriate observed concentrations for the components of PM on “best” and “worst” day s. Observed component concentrations are multiplied by the corresponding relative response factors to est imate future concentrations for each component on “best” and “worst” day s. Future component concentrations are then inserted into the equation relating light extinction to concentrations of particulate matter. The resulting estimates for future light extin ction on “best” and “worst” day s are compared with observations made during the base period to a ssess the future year visibility improvement and demonstrate reasonable progress b y 2018 in meeting the ultimate goal of natural visibility conditions by

2064.

3 Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze, EPA
- 454 /B

- 07

- 002 , April 20077

Steps Required in Model ing Future Year Visibility Improvement The modeling guidance lists nine steps for preparing modeling to demonstrate re asonable progress toward visibility improvement goals. 1. Develop a conceptual description of the problem to be addressed. 2 . Select an appropriate model to support the demonstration. 3 . Select appropriate meteorological time periods to model. 4 . Choose an appropriate area to model with appropriate horizontal/vertical resolution and establish the initial and boundary conditions that are suitable for the application. 5 . Generate meteorologica l inputs to the air quality model. 6 . Generate emissions inputs to the air quality model. 7 . Run the air quality

model with base case emissions and evaluate the performance. Perform diagnostic tests to improve the model, as necessary

. 8 . Perform future year modeling (including additional control strategies, if necessary) and use the results to calculate future ye ar visibility and visibility

improvement. 

### H ow Did West Virginia Address All Of The Com ponents a Modeled Dem onstration Of Future Year Vis ibility Improvem ent ? The West Virginia Haze SIP addresses each of the required elements of a model ing anal ys is used to predict visibility improvement that is expected by 2018. Conceptual D escription of the P roblem A conceptual model describes how weather patterns affect the formation and transport of PM 2.5 , accounting for emissions and photochemistry. The conceptual model for the West Virginia PM 2.5 SIP is described in Appendix B of the WV Haze SIP. Air Resources Specialists, Inc (ARS) was contracted b y VISTAS to develop a conceptual description of the current visibility in the VISTAS area as it relates to meteorology

and source distribution. Th is document was prepared in accordance with EPA guidance. Ammonium sulfate is the largest contributor to v isibility impairment on the 20% haziest day s in the baseline 2000

- 2004 period (69

- 74%) at all the IMPROVE sites in the VI STAS region except Everglades National Park in Florida, where Ammonium sulfate is a close second to Particulate Organic Material ( POM ) (40 and 45%, respectively). Particulate Organic Material (also referred to as organic carbon) is the second largest contributor to aerosol extinction at all other sites, contributing to between 13 and 18% of aerosol extinction on the worst day s. Baseline conditions for 20% worst day s at the inland sites (182.2

- 241.4 Mm

- 1) average higher WV Regional Haze SIP Appendix B.1

– 494 3

- 18 than conditions measured at the coastal sites (116.4

- 147.3 Mm

- 1). Ammonium sulfate is also the largest contributor to vis ibility impairment on the 20% best day s (45

- 59%), with large contributions from ammonium nitrate (9

- 21%) POM (11

- 19%). Sea salt is not a factor on the 20% worst day s, but for the 20% best day s it contributes to between 2 and 7% of the aerosol extinction at the VI STAS coastal sites. Ammonium sulfate, Coarse Mass( CM ) and POM are the largest contributors to total mass on the 20% best and worst day s. CM, although it is a factor for total mass, has a low extinction efficiency and does not contribute significantl y to aerosol extinction.8

Ammonium sulfate contributes more significantly to aerosol extinction because it readil y absorbs water vapor in the air.
For most inland sites , the 20% haziest day s are most likely to occur in the summer, and the 20% best day s o ccur most frequently during the winter. For coastal site s , the 20% haziest day s can occur y ear round, with the summer day s being dominated by ammonium sulfate, while the worst day s that occur between October and February have large contributions from ammon ium sulfate, POM and sometimes ammonium nitrate Sulfate is the key

particle constituent from the standpoint of designing control strategies to improve visibility

conditions in the VI STAS states . Significant further reductions in ambient sulfate levels are achievable, though they will require more than proportional reductions in SO 2 emissions.
Modeling Platform Currently one regional

- scale air qualit y models ha s been evaluated and used by VI STAS to perform air quality

simulations. Th is is the Community Mu lti

- scale Air Quality modeling s ys tem (CMAQ; By un and Ching, 1999)

. CMAQ was developed by USEPA

. CMAQ has undergone extensive community development and peer review (Amar et al., 2005) and has been successfully used in a number of regional air quality s tudies (Bell and Ellis, 2003; Hogrefe et al., 2004; Jimenez and Baldasano, 2004; Mao and Talbot, 2003; Mebust et al., 2003). Modeling for regional haze was performed b y VIS TAS for the ten Southeastern states, including West Virginia. The sections below o utline the methods and inputs used by VI STAS for the regional modeling. Additional details are provided in Appendices C, D and M of the WV Haze SIP

. Meteorological T ime P eriods U sed in the M odeling VI STAS selected all days in the y ear 2002 as the modeling time period for this demonstration. Meteorological inputs were developed for 2002 using the meteorological model. Emissions inventories were also developed for 2002 and processed through the emissions model. These inputs were then used in the air qualit y model to predict fine particle mass and visibility . The 2002 base ye ar represents the baseline period from 2000 to 2004

. CMAQ s imulations were performed for the 2002 Base Case, 2009 and 2018 Base Case, and 2009 and 2018 Control Case. All scenarios adopt the same meteorological field (2002) and boundary conditions, varying onl y emission inputs. Meteorological D ata U sed in the A ir Q uality M odel The VI STAS states decided to use a prognostic meteorological model that provid es life

like meteorological inputs to the photochemical grid model

. The P ennsylvania State University

/National Center for Atmospheric Research Mesoscale Meteorological Model (MM5) version 3.6 was chosen for the modeling analy sis

. The MM5 model provide s a reasonable representation of weather conditions at the surface and aloft.9

Domain of the M odel, H orizontal/V ertical R esolution and the I nitial and B oundary C onditions VI STAS has adopted the Inter

- RPO domain description for its modeling runs. This 36

- km domain covers the continental Un ited States, southern Canada and northern Mexico. The dimensions of this domain are 145 and 102 cells in the east

- west and north

south directions, respectively (see Figure 3)

. To achieve finer spatial resolution in the VI STAS states, a one

- way nested high resolution (12

- km grid resolution) was used. Figure 4 shows the 12

- km grid, modeling domain for the VISTAS region. This is the modeling domain for which the reasonable progress goals are assessed. Figure 3. The MM5 horizontal domain is the outer most, bl ue grid, with the CMAQ 36
- km domain nested in the MM510

Figure 4 . A M ore D etailed V iew of the 12
- km G rid O ver the VISTAS R egion

Vertical resolution is the number of lay ers and the size of each lay er in the model. The lay ers in the p hotochemical grid model were set up to be compatible with the model that produced meteorological conditions for the photochemical grid model. T he vertical resolution used in the modeling exercise followed EPA’s modeling guidance and therefore adequatel y r epresent s the atmosphere where PM 2.5 and its precursors are emitted and transported. Baseline and Future Year Emission Inventories for Modeling Section 51.308(d)(3)(iii) of EPA’s Regional Haze Rule requires the State s t o identify the baseline emission inventory on which strategies are based. The baseline inventory is intended to be used to assess progress in making emission reductions. Based on EPA guidance entitled, 2002 Base Year Emission Inventory SIP Planning: 8

- hour Ozone, PM 2.5, and Regional Haze Programs, which identifies 2002 as the anticipated baseline emission inventory

y ear for regional haze, VI STAS and the State of West Virginia are using 2002 as the baseline y ear. Future y ear inventories were developed for 2009 and 2018 based on the 2002 ba se year. The future ye ar emission inventory include emissions growth due to projected increases in economic activity as well as the emissions reductions due to the implementation of control measures. The 2002 emissions were first generated b y the individ ual states in the VI STAS area. The VI STAS contractor generated the future y ear emissions inventories for 2009 and 2018 for11

the regional haze modeling. The 2002 emissions from non

- VI STAS areas within the modeling domain were obtained from other Regional Planning Organizations for their corresponding areas. These Regional Planning Organizations included the Mid

Atlantic/Northeast Visibility Union, the Midwest Regional Planning Organization and the Central Regional Air Planning Association. The complete inve ntory

and discussion of the methodology is contained in Appendix D of the West Virginia Haze SIP

. Model Performance Evaluation VISTAS CMAQ modeling was conducte d for year 2002 CMAQ Performance for PM 2.5 species and visibility was examined based on this C MAQ run on a 12 km resolution domain. Measurements from IMPROVE and STN networks were paired with model predictions by location and time for evaluation. The goal and the criteria for PM 2.5 evaluation suggested by Boylan and Baker (2004) were adopted by eve ry RPO for SIP modeling. The perfor mance goals are: Mean Fractional Error (MFE) ≤ +50%, and Mean Fraction Bias (MFB) ≤ ±30%; while the criteria are proposed as: MFE ≤ +75%, and MFB ≤ ±60%. CMAQ prediction of PM 2.5 species from STN sites and IMPROVE sites within the VISTAS Region were paired with measurements and statistically analyzed to generate MFE and MFB values. Considering CMAQ performance in terms of MFE and MFB goals, sulfate, nitrate, OC, EC, and PM 2.5 all had the majority of data points within the goal curve, some were between the g oal and acceptable criteria, and only a few were outside the criteria curve. Only fine soil has the majority of points outside the criteria curve, but there were some sites still within the goal. For the VISTAS region, CMAQ performs best for PM 2.5 sulfate, followed by PM 2.5 , EC, nitrate, OC, and then fine soil. Regional haze modeling also requires CMAQ performance evaluation for aerosol extinction coefficient (B ext ) and the haze index. Modeled daily aerosol extinction at each improve site was calculated f ollowing the IMPROVE formula with modeled daily

PM 2.5 species concentration and relative humidity factors from IMPROVE. The approach used natural background visibility estimates and the haze index following EPA Guidance. The modeled B ext showed a near 1:1 linear relationship with IMPROVE observed B ext . Overall, WVDAQ found model performance to fall within acceptable limits. The WVDAQ further asserts that the one atmosphere modeling performed b y the VISTAS contractors is representative of conditions in the southeastern states and is applicable for use in setting reasonable progress goals for the Class I areas. Uniform Rate o f Progress Goals The key difference between SIPs from States with Class Iareas and those States without Class Iareas , but may

have s ources that impact visibility on Class I areas , is the calculation of the baseline and natural visibility for their Class I areas and the determination of uniform rate of progress goals

- expressed in deciviews

- that provide for reasonable progress toward s achieving natural visibility by 2064. It is the Class I states responsibility

assess these calculations. The Class IStates must also consult with those States, which may

reasonabl y be anticipated to cause or contribute to visibility impairment in their Class Iareas (40 CFR 51.308 (d)(1)(i

- vi)).12

The baseline visibility

conditions are calculated for the baseline period between 2002 and 2004. The average impairment for the 20 most and 20 least impaired day s are determined for each calendar ye ar and comp iled into the average of three annual averages (40 CFR 51.308 (d)(2)(i)). The natural visibility conditions are determined for the same baseline period with the most and least impaired day s determined by available monitoring data or an appropriate data ana ly sis technique (40 CFR 51.308 (d)(iii

- iv)). U.S. Environmental Protection Agency (EPA) released guidance on June 7, 2007 to use in setting reasonable progress goals. The goals must provide improvement in visibility for the most impaired day s, and ensure no degradation in visibility for the least impaired day s over the State Implementation Plan (SIP) period. The State must also provide an assessment of the number of years it would take to attain natural visibility condition if improvement continues at the rate represented b y the reasonable progress goal. Figure 5 illustrates an example of how Uniform Rate of Progress is calculated

. Figure 5 . Example c alculation of Uniform Rate of Progress

Modeled Visibility Projections for 2018 The CMAQ air qualit y m odel was used to simulate base period emissions and future emissions. T he modeling result s for the base year period (2002) and the year representing the end of the first planning period (2018) are used to develop relative response factors (RRF) for each component of particulate matter identified previously in this TSD. T he relative response factors are multiplied by the measured species concentration dat a during the base period (for the measured 20% best and worst day s). This results in daily future y ear species concentrations data. The projected concentrations are then used to derive daily visibility in deciviews and are averaged across all best and wors t day s to create the projected future visibility . The results of this procedure are plotted along with the uniform progress glide slope in Appendix M of the West Virginia Haze SIP

.13

The modeling results presented in Appendix M of the West Virginia Haze SIP show a ll VI STAS sites are projected to meet or exceed the uniform rate of progress goal s for 2018 on the 20 percent worst day s. In addition, no site anticipates increases in visibility impairment relative to the baseline on the 20 percent best day s
. Summary of Photochemical Grid Modeling Results In summary , the photochemical grid modeling , presented in the West Virginia Haze SIP , follow EPA’s modeling guidance and is acceptable to EPA. All VI STAS Class I sites are projected to meet or exceed the uniform rate of progress goal for 2018 on the 20 percent worst day s. In addition, no site anticipates increases in visibility imp airment relative to the baseline on the 20 percent best day s
. 

### Contribution Assessment The 1999 Regional Haze Rule requires States and Tribes to submit State Implementation Plans (SIPs) to the U.S. Environmental Protection Agency (USEPA) for approval by J anuary 2008 at the latest. The haze SIPs must include a “contribution assessment” to identify those states or regions that may be influencing speciall y protected federal lands known as Federal Class I areas. 4 These states or regions would then be subject t o the consultation provisions of the Haze Rule. The Haze Rule also requires a “pollution apportionment” anal ys is as part of the long

- term emissions management strategy for each site. As described in the Conceptual Description portion of this TSD, s ulfate alone accounts for an ywh ere from one

- half to two

- thirds of total fine particle mass on the 20 percent haziest day s at VI STAS Class Isites. As a result of the dominant role of sulfate in the formation of regional haze in the VI STAS area , VISTAS concluded that an effective emissions management approach would rel y heavily on broad

- based regional SO2 control efforts in the eastern United States. Area of Influence for VISTAS Class I Areas There are 20 Class I areas located in the VI STAS area

. The objective of the VI STAS Area of Influence anal ys is is to identify the geographic source regions that are c ontributing to visibility

impairment at the Class I areas on the worst 20 percent visibility day s. This information is being used by the VISTAS states as part of the evaluation and demonstration of reasonable progress toward visibility improvement in Class Iareas. In order to identify

states whose emissions are most likely to influence visibility

in VI STAS Class Iareas, VI STAS prepared a report entitled “ VI STAS A rea of Influence Anal ys es ” located in Appendix M of the West Virginia Haze SIP

. Based on that work, VI STAS concluded that it was appropriate to define an “Area of In fluence” (AOI) including all of the states participating in VI STAS plus other states outs ide VI STAS for which anal ys es indicated they contributed at least one percent ( 1 %) of the sulfate ion in VI STAS Class Iareas in 2002. Contribution Assessment Results
4 The Class I designation applies to national parks exceeding 6,000 acres, wilderness areas and national memorial parks exceeding 5,000 acres, and all international parks that were in existence prior to 1977.14

VI STAS States decided that any state or region that contributed at least 1 percent of t otal sulfate observed on 20 percent worst visibility days in 2002 is contributing significantl y to the haze problem in that particular Class I area. With respect to sulfate, the Contribution Assessment estimated emissions from within VI STAS in 2002 contributed significantly to the total sulfate at Class I areas located within and nearb y to the VI STAS region ( see Appendix M of the West Virginia Haze SIP ). The contribution of sulfate at these Class I areas from other regions outside the VI STAS were also si gnificant. Studies showed that West Virginia “contributes” to the following Class I areas: Dolly Sods Wilderness Area, Otter Creek Wilderness Area, James River Face Wilderness Area, Linville Gorge Wilderness Area, and Shenandoah National Park. Therefore, this SIP focuses on how West Virginia’s control measures will improve visibility in these areas.

BART On July 6, 2005 (70 FR 39104) EPA finalized 40 CFR 51

– Regional Haze Regulations and Guidelines for Best Available Retrofit Technology (BART) D eterminations addressing the issues from the Circuit Court decisions. The BART requirements were most recentl y updated on October 5, 2006. BART is defined as an emission limitation based on the degree of reduction achievable through the application of the best sy stem of continuous emission reduction for each pollutant, which is emitted by a BART

- eligible source. The changes to the rule included how the States would identify the best sy stem of continuous emission control technology and by which States can co nsider an individual facility ’s contribution to regional haze when determining to require controls, and what the level of control should be met. The rule changes also clarified the requirements associated with demonstrating how emissions trading or alternative programs may be used as an alternative to applying Best Available Retrofit Technology (BART) Requirements. Congress defined sources potentially subject to BART

- as major stationary sources, including reconstructed sources; from one of 26 identifie d source categories which included utility

and industrial boilers, and large industrial plants such as pulp mills, refineries and smelters; which have the potential to emit 250 tons per y ear or more of an y air pollutant, and which were placed in operation between August 1962 and August 1977. [CAA 169A (b)(2)(A) & (g)(7)]. Five Factor Analysis for Each BART Source States are required to determine BART for each BART

- eligible source. According to 40 CFR 51.308(e)(1)(ii)(A) the determination of BART must be b ased on an anal ys is of the best sy stem of continuous emission control technology available and associated emission reductions achievable. 40 CFR 51.308(e)(1)(ii)(A) requires the anal ys is to take into consideration the following five factors for the technol ogy available : 1) The costs of compliance, 2) The energy

and non

- air quality

environmental impacts of compliance, any15

3) Pollution control equipment in use at the source, 4) The remaining useful life of the source, and 5) The degree of improvement in visibility which may

reasonably

be anticipated to result from use of the technology

. Under the BART Guidelines, WVDAQ may consider exempting some sources from BART if it is found that they do not cause or contribute to visibility impairment in a Class I area. In accordance with the BART guidelines, WVDAQ chose to perform source - specific anal ys es to determine which sources cause or contribute to visibility impairment using the California Puff Model ( CALPUFF ) . The CALPUFF modeling protocol used for deter

mining which facilities are subject to BART is included in Appendix H of the WV Haze SIP . In accordance with the Guidelines, a contribution threshold of less than 0.5 deciviews was employ ed for determining which sources were exempt from BART. CALPUFF is a multi

- layer, multi

- species, non - steady s tate puff dispersion model which can simulate the time and space varying meteorological conditions on pollutant transport, transformation and removal. CALPUFF uses three dimensional meteorological fields developed b y the meteorological processing program CALMET. CALPUFF contain algorithms for near source effects such as building downwash, traditional plume rise, partial plume penetration, sub

- grid scale terrain interactions, as well as long range effects such as pol lutant removal (dry and wet deposition), chemical transformation, vertical wind shear, over

- water transport, and coastal interaction effects. The CALPUFF modeling performed for all of West Virginia ’s BART sources conforms to EPA modeling guidance. Ad etai led description of the CALPUFF modeling can be found in Appendix H of the West Virginia Haze SIP

. West Virginia Sources Subject to BART Twenty

- one (21) of West Virginia’s twenty

- two (22) BART

- eligible sources submitted exemption modeling demonstrations. Nineteen (19) of the twent y - one (21) s ources were able to demonstrate exemption. Additional details are available in Appendix H. Capitol Cement (003

- 00006) was the only BART

- eligible source which chose not to submit exemption modeling. Although PPG Industries initially modeled a visibility

impact greater than 0.5 deciviews on multiple Class Iareas, PPG elected to accept a permit limit on its BART eligible unit which reduces its visibility impact to below the exemption threshold of 0.5 deciviews of impact at an y Class I area. Permit, R14

- 027B, requires 4690.56 tpy of SO 2 emission reductions from Boiler #5 by May 1, 2008. Therefore, PPG is considered BART exempt. Only Dominion’s Mt. Storm Power Station in Mt. Storm was unable to demonstrate a contribution o f less than 0.5 deciview at all Class I area within 300 km from their BART eligible sources. Therefore, Mt. Storm was the only source considered to be “subject to BART” and required to submit a permit application, containing their evaluation of potential B ART options and a proposed BART determination. Mt. Storm submitted a16

BART determination on November 3, 2006. A copy of the BART determination was sent to EPA and the Federal Land Managers for review on January 22, 2007. On September 5, 2007 the compan y submitted a permit application to incorporate the results of the BART determination. The WVDAQ published a legal ad, which commenced the thirty day public comment period, on September 18, 2007. A copy of the application and draft permit were sent to the Fede ral Land Managers for review, via email, on September 17, 2007. Permit R13

- 2735 was issued December 13, 2007. [See Appendix Lfor copies of application, draft permit and final permit.] The current PM controls at Mt. Storm were determined to satisfy

BART, however, the allowable PM 10 emission rate was lowered from 0.05 lb/mmBtu to 0.03 lb/mmBtu, resulting in a reduction of up to 508 tpy per unit, or a maximum reduction of 1524 tpy

. Capitol Cement in Martinsburg chose not to submit exemption modeling, but s imply to acknowledge that Kiln 9 was BART

- subject. Capitol Cement had previously applied for and been granted a PSD (Prevention of Significant Deterioration) permit (R14

- 026, issued June 2, 2005) for the replacement of two existing long wet process cement kilns and associated clinker coolers with a modern precalciner s ys tem and associated equipment. The only

BART

- eligible unit at the facility (Kiln 9) was one of the two kilns being replaced, and the permit included a requirement for the permanent shutdown o f the existing kilns when full

- production was achieved with the replacement kilns, or no later than 180 day s after startup. Therefore, the company requested that the permit be modified to require the permanent shutdown of the Kiln 9 system b y the BART comp liance deadline or when full

- production was achieved with the replacement kilns, or no later than 180 day s after startup, whichever came first. The WVDAQ issued an Administrative Update to permit R14

- 026B on October 11, 2006, requiring that “Operation of the existing kiln 9 sy stem shall permanentl y cease after the pre

- heater

- precalciner kiln sy stem achieves full production or within 1280 day s after the pre

- heater

- precalciner kiln sy stem first becomes operational or before the BART compliance deadline (app roximately

2013) whichever comes first”. [See Appendix Lfor copies of letter and permit.] The modifications at Capitol Cement are expected to result in 1,741.51 tpy of SO 2 reductions, 1,374.81 tpy of NO x reductions, and 66.01 tpy of PM 10 reductions. 

### Su mmary of EPA’s Technical Findings The technical anal ys es and modeling used to assess uniform rate of progress and to support the L TS were successfull y developed consistent with EPA’s interim and final modeling guidance. All VI STAS sites and MANE

- VU sites, significantl y impacted b y VI STAS sources, are projected to meet or exceed the uniform rate of progress goal for 2018 on the 20 percent worst day s. In addition, no site anticipates increases visibility impairment relative to the baseline on the 20 percent best day s. The technical anal ys es and modeling used in the West Virginia Haze SIP ’s contribution assessment and prediction of visibility

impacts from BART controls comply with EPA modeling guidance and recommendations. EPA finds the VISTAS technical model ing anal ys es presented in the West Virginia Haze SIP to be acceptable because the model s that were used were applied according to EPA modeling guidance

.