west virginia department of environmental protection

Maintenance Plan Updates

for the

Charleston (Kanawha & Putnam Counties), 

Huntington (Cabell & Wayne Counties), 

Parkersburg (Wood County), 

Weirton (Brooke and Hancock Counties) and

Wheeling (Marshall & Ohio Counties), 

West Virginia 

1997 8-hour Ozone

 Maintenance Areas

Final

March 2011

Promoting a healthy environment.
Maintenance Plan Updates

for the

Charleston (Kanawha & Putnam Counties), 

Huntington (Cabell & Wayne Counties), 

Parkersburg (Wood County), 

Weirton (Brooke and Hancock Counties) and 

Wheeling (Marshall & Ohio Counties), 

West Virginia 

1997 8-hour Ozone

 Maintenance Areas

Final

March 2011

TABLE OF CONTENTS

I. REQUEST . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . page 1

II. MAINTENANCE PLAN REVISIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . page 1

III. CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . page 11

Five WV 1997 8-hour Ozone Maintenance Plan Updates: Final March 2011 ii
Maintenance Plan Updates

for the

Charleston (Kanawha & Putnam Counties), 

Huntington (Cabell & Wayne Counties), 

Parkersburg (Wood County), 

Weirton (Brooke and Hancock Counties) and 

Wheeling (Marshall & Ohio Counties), 

West Virginia 

1997 8-hour Ozone

 Maintenance Areas

Final

March 2011

I. REQUEST

The State of West Virginia is requesting that the United States Environmental Protection

Agency (EPA) approve revisions to the 8-hour ozone maintenance plans for the five West

Virginia 1997 8-hour Ozone Maintenance Areas, including Charleston, Huntington, Parkersburg,

Weirton and Wheeling. These revisions simply reallocate emissions from the existing “safety

margins” in each of the maintenance plans to increase the available motor vehicle emission

budgets (MVEB) for highway vehicles. These revisions do not establish budgets for pollutants

and pollutant precursors for air quality standards other than the 1997 8-hour ozone standard (e.g.,

not the 2008 8-hour ozone standard or particulate matter standards). 

The MVEBs are being increased in anticipation of mandatory use of EPA’s most recently

approved highway vehicle emissions model, the Motor Vehicle Emission Simulator (MOVES),

in future transportation conformity determinations. MOVES implements a significantly different

approach to emissions estimation than the previous model (MOBILE6.2). Preliminary use of the

new model indicates that emission estimates can be considerably different than similar

calculations using MOBILE6.2, which was used to create the original MVEBs.

Although the individual maintenance plans were originally submitted to EPA and approved

separately from one another, these revisions have been bundled together into one document

because similar changes are being made to all of the plans, and to reduce the procedural burden

on both the state and EPA. If EPA cannot approve one or more of the revisions, we ask that the

remainder be processed and approved on their individual merits.

II. REVISIONS to the MAINTENANCE PLANS

The table below summarizes the submittal and approval dates for each of the five areas’

ozone maintenance plans (and two subsequent updates). Each maintenance plan established 

Five WV 1997 8-hour Ozone Maintenance Plan Updates: Final March 2011 1
motor vehicle emission budgets (MVEB) for nitrogen oxides (NOx) and Volatile Organic

Compounds (VOC) which are precursors of ozone. The budgets were developed in consultation

with the Metropolitan Planning Organizations (MPO) responsible for transportation planning in

each area and relied on emission factors for highway vehicles that were developed using the

approved EPA model at the time, MOBILE6.2. The Division of Air Quality does not currently

have the resources to completely redo the highway emissions estimates using the new approved

model, MOVES, with the level of detail required for State Implementation Plans (SIP).

However, all of the existing maintenance plans have adequate “safety margins” to significantly

increase the approved MVEBs and still leave adequate remaining safety margins.

Under 40 CFR 93.101, the term safety margin means the difference between the attainment

level (from all sources) and the projected level of emissions (from all sources) in the

maintenance plan. The attainment level is the level of emissions during one of the years in which

the area met the NAAQS for the pollutant of concern. The safety margin (or a portion of the

safety margin) can be allocated to the transportation sector. However, the total emissions must

remain below the attainment level. In this case the allocation from the safety margin accounts for

uncertainty in the projections expected from changes caused by using a new model, MOVES. In

many respects, these might be characterized as “artificial changes” because the actual vehicle

emissions have not changed. Rather, the model used to estimate emissions has changed and can

result in significantly higher emissions estimates, especially for NOx. In any case, the state

MVEBs are constrained to ensure that the total emissions (i.e., all source categories) do not

exceed the 2004 attainment year emissions of either NOx or VOC thereby ensuring continued

maintenance of the 1997 ozone standards.

Table 1

1997 8-hour Ozone 

West Virginia Maintenance Plans

Area SIP

Submittal

Date

EPA Federal

Register Final

Approval

Effective

Date

Responsible

Metropolitan

Planning

Organization

Charleston 11/30/2005 71 FR 39001,

11 JUL 2006

8/10/2006 Regional

Intergovernmental

Council

Huntington 5/17/2006 71 FR 54421,

15 SEP 2006

10/16/2006 KYOVA

Interstate Planning

Commission

Parkersburg 9/8/2006 72 FR 25967,

08 MAY 2007

6/7/2007 WoodWashington-Wirt

Interstate Planning

Commission

Five WV 1997 8-hour Ozone Maintenance Plan Updates: Final March 2011 2
Area SIP

Submittal

Date

EPA Federal

Register Final

Approval

Effective

Date

Responsible

Metropolitan

Planning

Organization

Weirton 8/3/2006 72 FR 27060,

14 MAY 2007

6/13/2007 Broke-HancockJefferson

Metropolitan

Planning

Commission

Wheeling 7/24/2006 72 FR 27247,

15 MAY 2007

6/14/2007 BELOMAR

Regional

Council

Charleston

Plan Update

1/8/2007 73 FR 2156

14 JAN 2008

3/14/2008 Regional

Intergovernmental

Council

Parkersburg

Plan Update

8/29/08 73 FR 64548

30 OCT 2008

12/29/2008 WoodWashington-Wirt

Interstate Planning

Commission

The revisions to the maintenance plans are detailed in the tables below and are presented in

alphabetical order by principal city, i.e. Charleston, Huntington, Parkersburg, Weirton and

Wheeling, in that order. There are two tables for each area. One specifies the MVEBs before and

after the reallocation while the other shows the total emissions for all sources combined in the

area.

Five WV 1997 8-hour Ozone Maintenance Plan Updates: Final March 2011 3
Table 2 - CHARLESTON Area Reallocation of Safety Margin to the MVEBs - (Tons/day)

2004

Base Year

2009

Projection

2018

Projection

Current MVEBs in the Approved Maintenance Plan

VOC 16.1 12.9 7.5

NOx 26.4 22.9 9.5

Proposed MVEBs in the Revised Maintenance Plan

VOC 16.1 16.7 13.7

NOx 26.4 38.9 17.1

Table 3 - CHARLESTON Area Total Emissions (Point, Area and Mobile) Before and After

Reallocation of the Safety Margin to the MVEBs - Tons/Day

2004

Base Year

(Maintenance

Level)

2009

Projection

2018

Projection

Current Total Emissions in the Approved Maintenance

Plan

VOC 52.3 48.1 45.4

NOx 129.4 105.5 81.9

Proposed Total Emissions in the Revised Maintenance

Plan

VOC 52.3 51.9 51.6

NOx 129.4 121.5 89.5

Five WV 1997 8-hour Ozone Maintenance Plan Updates: Final March 2011 4
Table 4 - HUNTINGTON Area Reallocation of Safety Margin to the MVEBs - (Tons/day)

2004

Base Year

2009

Projection

2009

Projection

Current MVEBs in the Approved Maintenance Plan

VOC 6.0 4.6 3.0

NOx 11.5 8.7 4.1

Proposed MVEBs in the Revised Maintenance Plan

VOC 6.0 7.4 6.6

NOx 11.5 14.0 13.5

Table 5 - HUNTINGTON Area Total Emissions (Point, Area and Mobile) Before and After

Reallocation of the Safety Margin to the MVEBs - Tons/Day

2004

Base Year

(Maintenance

Level)

2009

Projection

2018

Projection

Current Total Emissions in the Approved

Maintenance Plan

VOC 23.7 20.6 19.7

NOx 37.4 31.5 27.0

Proposed Total Emissions in the Revised

Maintenance Plan

VOC 23.7 23.4 23.3

NOx 37.4 36.8 36.4

Five WV 1997 8-hour Ozone Maintenance Plan Updates: Final March 2011 5
Table 6 - PARKERSBURG Area Reallocation of Safety Margin to the MVEBs - (Tons/day)

2004

Base Year

2009

Projection

2018

Projection

Current MVEBs in the Revised Maintenance Plan

VOC 4.00 3.8 2.4

NOx 5.66 5.5 2.7

Proposed MVEBs in the Revised Maintenance Plan

VOC 4.00 5.5 4.7

NOx 5.66 7.3 7.3

Table 7 - PARKERSBURG Area Total Emissions (Point, Area and Mobile) Before and After

Reallocation of the Safety Margin to the MVEBs - Tons/Day

2004

Base Year

(Maintenance

Level)

2009

Projection

2018

Projection

Current Total Emissions in the Approved Maintenance

Plan

VOC 16.7 14.8 14.1

NOx 15.2 13.2 10.1

Proposed Total Emissions in the Revised Maintenance

Plan

VOC 16.7 16.5 16.4

NOx 15.2 15.0 14.7

Five WV 1997 8-hour Ozone Maintenance Plan Updates: Final March 2011 6
Table 8 - WEIRTON Area Reallocation of Safety Margin to the MVEBs - (Tons/day)

2004

Base Year

2009

Projection

2018

Projection

Current MVEBs in the Approved Maintenance Plan

VOC 2.6 2.0 1.0

NOx 3.6 2.8 1.2

Proposed MVEBs in the Revised Maintenance Plan

VOC 2.6 3.4 1.9

NOx 3.6 4.2 3.9

Table 9 - WEIRTON Total Emissions (Point, Area and Mobile) Before and After Reallocation

of the Safety Margin to the MVEBs - Tons/Day

2004

Base Year

(Maintenance

Level)

2009

Projection

2018

Projection

Current Total Emissions in the Approved Maintenance

Plan

VOC 13.5 12.0 12.5

NOx 18.2 16.6 15.2

Proposed Total Emissions in the Revised Maintenance

Plan

VOC 13.5 13.4 13.4

NOx 18.2 18.0 17.9

Five WV 1997 8-hour Ozone Maintenance Plan Updates: Final March 2011 7
Table 10 - WHEELING Area Reallocation of Safety Margin to the MVEBs - (Tons/day)

2004

Base Year

2009

Projection

2018

Projection

Current MVEBs in the Approved Maintenance Plan

VOC 2.8 2.5 1.4

NOx 4.7 4.3 1.7

Proposed MVEBs in the Revised Maintenance Plan

VOC 2.8 10.4 9.1

NOx 4.7 7.7 3.1

Table 11 - WHEELING Total Emissions (Point, Area and Mobile) Before and After

Reallocation of the Safety Margin to the MVEBs - Tons/Day

2004

Base Year

(Maintenance

Level)

2009

Projection

2018

Projection

Current Total Emissions in the Approved Maintenance

Plan

VOC 23.5 14.7 14.9

NOx 101.2 72.9 34.5

Proposed Total Emissions in the Revised Maintenance

Plan

VOC 23.5 22.6 22.6

NOx 101.2 76.3 35.9

Five WV 1997 8-hour Ozone Maintenance Plan Updates: Final March 2011 8
Air Quality

One important question is how effective the maintenance plans have been in maintaining and

improving the ozone concentrations over the past few years. Fortunately, it can be stated

unequivocally that in every case the air quality has not only continuously met the 1997 ozone

standards since 2004 (maintenance plans base year) but ozone levels have decreased to the

lowest levels in over a decade. (see chart below)

Chart - 1

West Virginia 8-hour ozone design values during the period 2000-2009

Five WV 1997 8-hour Ozone Maintenance Plan Updates: Final March 2011 9
Emissions Inventory

Another important question is how the emissions may have changed since the maintenance

plans were developed and how accurately the agency has estimated potential growth. The

emissions estimates were separated into source categories, including area (small widely

distributed sources); non-road (off road equipment, marine vessels and airplanes); on-road

(highway motor vehicles) and point ( large individual sources such as power plants,

manufacturing facilities, etc.) For this last category, DAQ has quantitative, quality-assured data

for the period 2004 (maintenance plan base) through 2008, obtained from certified emissions

reporting. County point source emission totals are summarized below.

 Point Source Emissions

Tons per

Year

NOx 2004 2005 2006 2007 2008

 Charleston Total NOx 49,680 47,253 47,359 46,322 23,638

 Huntington Total NOx 26,411 25,463 20,398 26,632 14,371

 Parkersburg Total NOx 11,115 13,908 13,351 12,696 9,265

 Weirton Total NOx 2,003 1,875 1,658 1,572 1,364

 Wheeling Total NOx 41,896 36,391 27,989 27,645 26,031

VOC 2004 2005 2006 2007 2008

 Charleston Total VOC 2,770 2,681 2,535 2,404 2,143

 Huntington Total VOC 598 698 700 848 631

 Parkersburg Total VOC 1,233 1,319 1,160 1,118 858

 Weirton Total VOC 1,711 1,483 1,361 996 855

 Wheeling Total VOC 872 693 421 329 324

The data clearly show significant decreases in point source NOx in all the areas as well as VOC

decreases in most areas. For the other categories, activity levels are primarily a function of

population, which is shown below.

 Nonattainment

Area

2004

Population

2005

Population

2006

Population

2007

Population

2008

Population

2009

Population

 Charleston 247,885 246,699 246,098 246,052 246,506 247,336

 Huntington 137,020 136,206 135,820 135,627 135,713 136,333

 Parkersburg 86,750 86,609 86,180 86,006 86,204 86,888

 Weirton 55,666 55,208 54,504 53,795 53,528 53,238

 Wheeling 79,590 78,774 78,105 77,472 76,872 76,571

It can be readily seen that population is essentially flat over time in all the areas such that related

emissions should also be relatively constant or slightly decreasing. Therefore, the DAQ has a

high degree of confidence that emissions are, and will continue to remain, below maintenance

levels in all the areas.

Five WV 1997 8-hour Ozone Maintenance Plan Updates: Final March 2011 10
III. CONCLUSION

The State of West Virginia requests that EPA act in a timely manner to approve these

revisions to the 8-hour ozone maintenance plans for the five West Virginia 1997 8-hour Ozone

Maintenance Areas, including Charleston, Huntington, Parkersburg, Weirton and Wheeling.

These revisions simply reallocate emissions from the existing “safety margins” in each of the

maintenance plans to increase the available motor vehicle emission budgets (MVEB) for

highway vehicles. The MVEBs are being increased in anticipation of mandatory use of EPA’s

most recently approved highway vehicle emissions model, the Motor Vehicle Emission

Simulator (MOVES) in future transportation conformity determinations.

Although the individual maintenance plans were originally submitted to EPA and approved

separately from one another, these revisions have been bundled together into one document

because similar changes are being made to all of the plans, and to reduce the procedural burden

on both the state and EPA. If EPA cannot approve one or more of the revisions, we ask that the

remainder be processed and approved on their individual merits.

Five WV 1997 8-hour Ozone Maintenance Plan Updates: Final March 2011 11