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, th e 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 1motor 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 2Area 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. Ch arleston, 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 3Table 2 - CHARLESTONArea 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 4Table 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 - HUNTINGTONArea 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 5Table 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 6Table 8 - WEIRTONArea 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 - WEIRTONTotal 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 7Table 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 8Air 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 9Emissions 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 orslightly 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 10III. 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, Hun tington, 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 increasedin 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