Technical Support Document (TSD) for the

Redesignation Request and Maintenance Plan

For the Charleston, WV

2006 PM2.5 Nonattainment Area

Submitted December 2012 by the West Virginia 

Department of Environmental Protection 

TSD Prepared August 2013 by

Jessica L. Fry

Office of Air Monitoring and Analysis, 3AP40

U.S. Environmental Protection Agency, Region 3

1650 Arch Street

Philadelphia, Pennsylvania 19103

/s/

____________________________________________

Reviewed by Alice H. Chow, Associate Director

Office of Air Monitoring and Analysis (3AP40)

8/29/2013

_________________

Date Signed
I. Introduction

The purpose of this document is to provide a technical summary of the Office of Air Monitoring 

and Analysis (OAMA) review of the emissions inventories submitted with the Redesignation 

Request and Maintenance Plan for the Charleston,WV 2006 PM2.5 Nonattainment Area by the 

West Virginia Department of Environmental Protection (WVDEP). This review does not 

determine the approvability of the redesignation request or maintenance plan. Emissions 

inventories in a redesignation request are used to show permanent and enforceable emission 

reductions between the year the area was designated as a nonattainment area and the year the 

area came into attainment. In a maintenance plan, the emissions inventories are used to reflect 

the emissions during the time the area came into attainment and are then projected to show that 

the area will remain in attainment. Any questions pertaining to this technical summary should be 

directed to Alice H. Chow, Associate Director, Office of Air Monitoring and Analysis, at 215-

814-2144 or via email at chow.alice@epa.gov. 

II. Emissions Inventories for Redesignation Request 

2005 Nonattainment Year Inventory 

In a redesignation request, emissions inventories are used to support the States claim that 

the area has permanent and enforceable emissions reductions. In order to do this, the state 

should estimate the percent reduction (from the year that was used to determine the design value 

for designation and classification) achieved from federal and state control measures; this is 

usually termed as the nonattainment year inventory. The 2005 nonattainment year inventory 

contains primary PM2.5 emissions (including condensibles), SO2 and NOx. WVDEP did not 

include VOC and NH3 emissions having determined them to be insignificant. This section will 

discuss the 2005 base/nonattainment year inventory that was used in the Charleston, WV

Redesignation Request and Maintenance Plan submitted by WVDEP.

WVDEP compiled emissions inventories for the nonattainment area which consists of 

Kanawha and Putnam Counties. 

The 2005 point source inventory contained emissions for electric generating units 

(EGUs) and Non-EGU sources in Kanawha and Putman Counties. EPA guidance for emissions 

inventory development provides that actual emissions should be used for purposes of the base 

year inventory. WVDEP used WV Department of Air Quality’s (DAQ) 2005 annual emissions 

inventory submitted to EPA’s National Emissions Inventory (NEI) database and EPA’s Clean 

Air Markets Division (CAMD) database to compile their inventory. Much of the work in

developing the inventory involved realigning the EGUs and Non-EGUs from the 2005 dataset 

submitted to the NEI with the CAMD dataset.

For the 2005 nonpoint emissions, WVDEP used 2005 NEI v2 data developed by the 

EPA. 
For 2005 nonroad mobile sources, WVDEP generated the emissions using EPA’s 

NONROAD model. Since marine, air and rail/locomotive (MAR) emissions are not part of the 

NONROAD model, they were calculated separately outside of the NONROAD model. 

The 2005 onroad mobile source inventory was developed using EPA’s highway mobile 

source emissions model MOVES2010a. The analysis was performed by Michael Baker Jr. Inc., 

under contract to the WV Department of Transportation (WVDOT) and the responsible 

Metropolitan Organization (MPO), the Regional Intergovernmental Council (RIC). In order to 

develop local data inputs the latest planning assumptions and regional planning tools were used. 

Data used to develop inputs was obtained from WVDOT, DEP, RIC and other national/local 

sources. 

OAMA staff reviewed the files and the emission results provided by WVDEP and found 

them to be acceptable.

III. Emissions Inventories for Maintenance Plan

2008 Attainment Year Inventory and Maintenance Plan Base Year Inventory

Under section 172(c)(3) states are required to submit a comprehensive, accurate, current 

accounting of actual emissions from all sources (point, nonpoint, nonroad, and onroad) in the 

nonattainment area. This inventory contains primary PM2.5 emissions (including condensibles),

SO2, NOx, VOC, and NH3. In a Maintenance Plan, states are required to submit an inventory used 

for the year of attainment, which is called the attainment year inventory and can also be referred 

to as the maintenance plan base year inventory. This inventory is used as the basis for the 

projected inventories that are used to show the area will remain in attainment. The base year 

inventory submitted by WVDEP contains primary PM2.5 emissions (including condensibles), 

SO2 and NOx. Emissions for VOC and NH3 for the nonattainment area have been supplemented 

with emissions from the 2008 NEI v1.5 NEI. This section will discuss the 2008 emissions 

inventory that was used in the Charleston, WV Redesignation Request and Maintenance Plan in 

order to fulfill the 172(c)(3) and attainment year emissions inventory requirements.

The 2008 point source inventory contained emissions for EGU and Non-EGU sources in 

Kanawha and Putman Counties. EPA guidance for emissions inventory development provides 

that actual emissions should be used for purposes of the base year inventory. WVDEP used 

WVDAQ 2008 annual emissions inventory submitted to EPA’s NEI database and EPA’s CAMD 

database to compile their inventory. Much of the work in developing the inventory involved 

realigning the EGUs and Non-EGUs from the 2008 dataset submitted to the NEI with the CAMD 

dataset.

For the 2008 nonpoint emissions, WVDEP used 2008 NEI v1.5 data developed by the 

EPA. Commercial marine vessels and locomotive emissions contained in the 2008 NEI v1.5 

were moved to the non-road data category.
For 2008 nonroad mobile sources, WVDEP generated the emissions using EPA’s 

NONROAD model. Since marine, air and rail/locomotive (MAR) emissions are not part of the 

NONROAD model, they were calculated separately outside of the NONROAD model. 

The 2008 onroad mobile source inventory was developed using EPA’s highway mobile 

source emissions model MOVES2010a. The analysis was performed by Michael Baker Jr. Inc., 

under contract to the WVDOT and the responsible RIC. In order to develop local data inputs the 

latest planning assumptions and regional planning tools were used. Data used to develop inputs 

was obtained from WVDOT, DEP, RIC and other national/local sources. 

OAMA staff reviewed the files and the emission results provided by WVDEP and found 

them to be acceptable.

2018 and 2025 Projection Emission Inventories

Projection inventories are used to show that the area will remain in attainment. WVDEP 

used 2018 and 2025 emission projections for the interim and maintenance plan end year, 

respectively. 

WVDEP used EPA’s Integrated Planning Model (IPM) projections to support the Cross 

State Air Pollution Rule (CSAPR). IPM projections of 2014 (released as 2014, the projected 

future year data provided with this platform is generally representative of several years around 

2012 and 2014 such as 20181), 2020 and 2030 were used. WVDEP compiled point source EGUs 

from EPA’s CSAPR inventories of 2018 and 2025 was interpolated between 2020 and 2030 

inventories. WVDEP acknowledges the D.C. Circuit Court ruling which vacated and remanded 

CSAPR and ordered EPA to continue administering the Clean Air Interstate Rule (CAIR) and 

explains in their plan that even without the implementation of CSAPR there will be sufficient 

reductions to remain in attainment of the standard. Non-EGU point source emissions, 

inventories for 2018 and 2025 were grown from the 2008 inventory using Workforce West 

Virginia economic forecasts. 

Nonpoint source emissions for 2018 and 2025 were based on the 2008 inventory using 

Workforce West Virginia economic forecasts. The Workforce WV projections were selected 

because their projections were based more on local data, provided more coverage of various 

categories, and a wider range of years based on 2008 emissions data. WVDEP compiled and 

associated Workforce WV’s growth factors with North American Industrial Classification 

System codes with WVDEP’s Source Classification Codes. Calculations were made and final 

estimates reflected both positive and negative growth.

Nonroad source emissions for 2018 and 2025 were developed using monthly NONROAD 

model runs and summarizations of monthly data to obtain annual data values. MAR emissions 

for 2018 and 2025 were based on the 2008 inventory using Workforce WV economic forecasts. 

 

1

Posted June 29, 2011, 2014 Emissions Data Files, 

ftp://ftp.epa.gov/EmisInventory/2005v4_2/2014emis/readme_2005v4_2_CAP_BAFM_HAPs_inventories_2014_inp

uts.txt
The same methodology was used to project MAR emissions as was discussed previously for 

nonpoint sources.

Onroad mobile projection emissions for 2018 and 2025 were calculated from 

MOVES2010a produced emission factors as performed by Michael Baker Jr. Inc., under contract 

to the WVDOT and RIC.

OAMA staff reviewed the methodologies provided by WVDEP and found them to be 

acceptable.