west virginia department of environmental protection

Final West Virginia 

State Implementation Plan Revision for 

Clean Air Act Section 110(a)(2)(A)-(M) Requirem

For Ozone and Fine Particulates 

October 1, 2009 

West Virginia Division of Air Quality 

601 57th Street, SE 

Charleston, W.Va. 25304 

Promoting a healthy environment 
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Final West Virginia State Implementation Plan Revision for 

Clean Air Act Section 110(a)(2)(A)-(M) Requirements for Ozone and Fine Parti

A State Implementation Plan (SIP) is a plan for each state that identifies how that state will attain and/or maintain thNational Ambient Air Quality Standards (NAAQS). The SIP is a complex, fluid document containing regulations, sorequirements, non-regulatory items such as plans and inventories, and in some cases additional requirements promulEnvironmental Protection Agency (EPA). The initial SIPs for states were approved by EPA on May 31, 1972. SIPs cwith EPA approval as necessary. The federally enforceable SIP for West Virginia is compiled in 40 CFR Part 52, Suto the SIP, West Virginia is demonstrating that it has adequate resources and authority to implement the 2006 PM2.5 hour ozone NAAQS. Additionally, the state is supplementing its existing Section 110(a)(2)(A)-(M) infrastructure SI8-hour ozone NAAQS, only with respect to the enforcement authority requirements under CAA Section 110(a)(2)(CThis SIP revision addresses requirements of Section 110(a)(2)(A)-(M) of the Clean Air Act (CAA) many of which hother SIP revisions. It is a compilation of elements that demonstrate how the 2006 fine particulate (PM2.5) and the 20

NAAQS (and with respect to CAA Section 110(a)(2)(C), the 1997 ozone and fine particle NAAQS) are being implemenforced in West Virginia. The elements of this SIP revision, once approved by EPA, will provide a federally enforcWest Virginia will continue to comply with the Section 110(a)(2) requirements of the CAA. In 1961, the State Legislature passed the Air Pollution Control Law of West Virginia, making West Virginia the sixtstatewide air pollution control law. The law provided for a separate state agency composed of a seven member Commstaff. The powers, authorities and funding of the original Commission were subsequently conveyed to the Office of Athe Division of Air Quality (DAQ) within the West Virginia Department of Environmental Protection (DEP). Staffinauthorities now incorporate over 90 full time staff, with a multi-million dollar annual budget and over 40 legislative of substantial funding sources, including construction/modification permit fees, Title V operating permit fees, non-T

general State revenue and federal grant monies. The agency has demonstrated the ability to implement state and fednearly fifty years as most recently evidenced by federally approved 1997 ozone standard maintenance SIPs, submittethe 1997 ozone and fine particle standards (which EPA has found complete) and EPA approved state adoption of the Interstate Rule (CAIR). Legislative authority for the West Virginia air quality program relating to the responsibilities 

codified in the West Virginia Air Pollution Control Act, W.Va. Code §22-5, more specifically §22-5-1, which gives primary responsibility for assuring air quality pursuant to the CAA. Many elements of Section 110(a)(2)(A)-(M) already exist in the approved SIP or recently submitted SIP revisions fo

revision may reiterate and/or reinforce some of these previously submitted and/or approved elements. Some requirements, such as those for intergovernmental consultation, air quality modeling and compliance with part fulfilled during the development and submission to EPA, as a SIP revision, of attainment plans and related requiremeand, in the case of ozone, Subpart 2 of the CAA. 
Section 

110(a) element The implementation plan shall: West Virginia Implementation 

§110(a)(2)(A) include enforceable emission 

limitations and other control measures, means, or techniques (including economic incentives such as fees, marketable permits, and auctions of emissions rights), as well as schedules and timetables for compliance as may be necessary or appropriate to meet the applicable requirements of this Act. 

Enforceable Emission Limitations:45CSR2 - This SIP approved rule (68FR47473) establishes emiss

smoke and particulate matter which are discharged from fuel burning 45CSR3 - The purpose of this SIP approved rule (67FR63270particulate matter emission limitations for hot mix asphalt plants and t

45CSR5 - The purpose of this SIP approved rule (67FR62379) is to p

air pollution from the operation of coal preparation plants, coal handlicoal refuse disposal areas. 45CSR6 - This SIP approved rule (74FR12560) establishes emissparticulate matter and requirements for activities involving incineratioare not subject to, or are exempted from regulation under a federspecific combustion sources. 45CSR7 - The purpose of this SIP approved rule (50FR26732) is to 

matter air pollution from manufacturing processes and associated ope45CSR10 - The purpose of this SIP approved rule (68FR33002) pollution from the emission of sulfur oxides. 45CSR21 - The purpose of this SIP approved rule (60FR6022) is to available control technology for VOC sources located in Putnam County, Cabell County, Wayne County, and Wood County West Virgi45CSR29 - This SIP approved rule (60FR39855) requires the submiNOX emissions statements for sources in Putnam, Kanawha, Cabe

and Greenbrier counties. West Virginia received approval of its CAIR SIP revision on 

(74FR38536) which contained three State Rules; 45CSR39, 45CSRThese rules also contain the monitoring, recordkeeping and reporunder 40 CFR Part 75. 
Pursuant to West Virginia Code, §22-5-1 declares the state’s public primary responsibility for assuring air quality pursuant to the ‘Federal 

amended.” The Secretary has the authority under W.Va. Code §§22-5-4(a)(1) ways and means for the regulation and control of pollution of the ai“conduct such studies and research relating to air pollution and abatement”. The Secretary has the authority under W.Va. Code §§22-1-3(a), 22-54(a)(17) to promulgate rules in accordance with the Administrative (W.Va. Code §§ 29A3-1 et seq.) Approximately forty rules revised uof the APCA are currently in effect and codified at Title 45 of the Coincluding the ambient air quality standards for criteria pollutants conta

§110(a)(2)(B) provide for establishment and 

operation of appropriate devices, methods, systems, and procedures necessary to monitor, compile, and analyze data on ambient air quality, and upon request, make such data available to the Administrator; 

Establishment of Monitoring System: Pursuant to West Virginia C“protecting the environment is fundamental to the health and wecitizens,” and, the state “has a duty to provide and maintain a health

our citizens.” Under §22-1-1(a)(2), “the state has the primary protecting the environment.” §22-1-1(b) “declares that the esdepartment of environmental protection is in the public interest” and of the state .....to use all practical means and measures to prevent o

the environment and biosphere, to create and maintain conditions and nature can exist in productive harmony, .....” Additionally, §22-5-1 declares the state’s public policy “to fulfill its prifor assuring air quality pursuant to the ‘Federal Clean Air Act’, as am

As set forth in §22-1-1(b)(5), the WVDEP, “insofar as federal envirorequire state participation” must “endeavor to obtain and continue sadministration of such federally-mandated programs,.....and to appropriate federal agencies to meet environmental goals.” 

Under §22-1-6(a), the WVDEP Cabinet Secretary “is the chdepartment” with the powers, duties and authority pursuant to §§22-5The Secretary has the authority under W.Va. Code §§22-5-4(a)(1) ways and means for the regulation and control of pollution of the a“conduct such studies and research relating to air pollution anabatement”. Therefore, under manifold statute authority, West Virginia operates 
§110(a)(2)(B) (continued) 

established network of ambient air monitors in West Virginia fo

assessing compliance with the National Ambient Air Quality Congress provided for in the CAA, and such standards promulgated 

the health and welfare of individual citizens. West Virginia has committed within the 103 grant document to variouand reporting requirements. Additionally, the state has committed wdocument to monitoring and reporting data for SO2, CO, O3, PM10, an

In general, the existing network and procedures for the 1997 oconsidered adequate for the revised 2008 ozone NAAQS, as unchanged; only the standard (or level) is different. Similarly, the existing network and procedures for the PM2.5 NAAQ

adequate for the revised 2006 PM2.5 NAAQS, as the pollutant is un

standard is different. Monitoring System Operation: To assess NAAQS compliance, network of monitors in West Virginia that have been designated Federal Reference or Federal Equivalent monitors. All ambient subjected to the Quality Assurance requirements of 40 CFR ParAdditionally all monitors have met the minimum siting requiremAppendix E. Availability of Data: In order to keep EPA informed of planne

monitoring network, WVDEP provides EPA Region III with adequatDetails of these changes and anticipated approvals of the changes to EPA. On an annual basis, WVDEP submits to EPA a network deunder 40 CFR §58.10, of any changes to the network. This plan adescription of each change, the reason for each change, and any relevant to the change. As provided in West Virginia Code, §§22-5-4(a)(2) and 22-5-10, Wreports to EPA ambient air quality data for SO2, CO, O3, PM10, and 

comply with the federal requirements of 40 CFR §58.16. The data ivalidated, and entered into the EPA air quality system (AQS) for upprescribed AQS procedures. The EPA AQS receives each report wthe end of the quarterly reporting period. Data is certified annually as CFR §58.15. WVDEP analyzes such air quality data to determine attainment statdemonstrated by the 8-hour ozone redesignation and maintenansubmitted and approved during calendar years 2006, 2007, 2008 a2009.
§110(a)(2)(C) include a program to provide for 

the enforcement of the measures described in subparagraph (A) and regulation of the modification and construction of any stationary source within the areas covered by the plan as necessary to assure that national ambient air quality standards are achieved, including a permit program as required in parts C and D; 

Enforcement of Emission Limitations and Control Measures fo

and 8-hour ozone NAAQS, the 2006 PM2.5 NAAQS, and the 20

NAAQS: Pursuant to §22-1-6(a), the WVDEP Cabinet Secretary “is 

the department” with the powers, duties and authority pursuant to §§5-4. The Secretary has the authority under W.Va. Code §§22-1-3(a), 22-54(a)(17) to promulgate rules in accordance with the Administrative (W.Va. Code §§ 29A3-1 et seq.) The Secretary has the authority under W.Va. Code §22-5-4(a)(5) requiring compliance with the provisions of this article and tpromulgated hereunder.” The Secretary has the authority under W.Va. Code §22-5-4(a)(9) “to any property, premise or place .... for the purpose of ascertaincompliance with this article and the rules promulgated under the article.” The Secretary has the authority under W.Va. Code §22-5-4(a)(16) necessary and convenient to prepare and submit a plan oimplementation, maintenance and enforcement of the Federal Clean AThe Secretary also has the authority under W.Va. Code §22-5-5 directing a person to cease and desist activity which violates the proet seq and the rules promulgated pursuant thereto. Pursuant to W.Va. Code §22-5-6, violators of the provisions of §22-5rules promulgated pursuant thereto are subject to civil penalty. The federally approved provisions of West Virginia's VOC control State Rules 45CSR21 (60FR6022). SIP approved rule 45CSR29 (60FR39855) requires the submission 

emissions statements for sources in Putnam, Kanawha, Cabell, WGreenbrier counties. West Virginia received approval of its CAIR SIP revision on 

(74FR38536) which contained three State Rules; 45CSR39, 45CSRThese rules also contain the monitoring, recordkeeping and reporunder 40 CFR Part 75. 
Regulation of the Modification and Construction of Stationary Virginia's current permitting program includes three SIP approved 45CSR13 (68FR9559) which provides a permitting program for modification of minor sources; PSD rule 45CSR14 (71FR64470) wprevention of significant deterioration permit program requirements CAA; and major NNSR rule 45CSR19 (71FR64468) which satisfies area new source review permit program requirements in Part D. West Virginia submitted 45CSR14 to EPA as a final PSD SIP revision This fully-adopted rule includes NOX as a precursor to ozone. 

§110(a)(2)(D) contain adequate provisions - 

(i) prohibiting, consistent with the provisions of this title, any source or other type of emissions activity within the state from emitting any air pollutant in amounts which will-  (I) contribute significantly to nonattainment in, or interfere with maintenance by, any other state with respect to any such national primary or secondary ambient air quality standard, or  (II) interfere with measures required to be included in the applicable implementation plan for any other State under part C to prevent significant deterioration of air quality or to protect visibility, (ii) ensuring compliance with the applicable requirements of sections 126 and 115 (relating to interstate and international pollution abatement); 

Prohibiting Interference with Measures for PSD or Visibility45CSR14 (71FR64470), “.....all applications filed by any person to cor modified stationary air pollution sources, intending to locate in arworse than the levels set to protect the public health and welfare, o

those areas, must adequately meet the pre-construction review conditions of the Clean Air Act as amended ....”. This rule includrequirements which ensure that new or modified sources do measures to prevent significant deterioration of air quality. 

West Virginia’s Regional Haze SIP was submitted on June 18, 200law, it became technically and administratively complete on or ab2008. Ensuring Compliance with Sections 126 and 115: West Virgin

subject to requirements under sections 115 and 126. 
§110(a)(2)(E)(i) provide 

(i) necessary assurances that the state (or, except where the 

Administrator deems inappropriate, the general purpose local government or governments, or a regional agency designated by the state or general purpose local governments for such purpose) will have adequate personnel, funding, and authority under state (and, as appropriate, local) law to carry out such implementation plan (and is not prohibited by any provision of federal or state law from carrying out such implementation plan or portion thereof); 

Legal Authority: The West Virginia Air Pollution Control Act (APCA)5-1, declares the state's policy "to fulfill its primary responsibility for a

pursuant to the CAA. The WVDEP Cabinet Secretary is authorized 

§§22-1-6(c)(1) and 22-5-4(a)(12) to carry out and represent the stmatters pertaining to the implementation plan. The Secretary is also W.Va. Code §22-5-4(a)(16) to do all things necessary and convenisubmit a plan. The Secretary is not prohibited by any provision of ffrom carrying out the implementation plan or portion thereof. The Secretary has the authority under W.Va. Code §§22-1-3(a), 22-4(a)(17) to promulgate rules in accordance with the Administrativ(W.Va. Code §§ 29A3-1 et seq.) Approximately forty rules revised uof the APCA are currently in effect and codified at Title 45 of the Coincluding the ambient air quality standards for criteria pollutants contaStatutory permitting requirements are set forth in W.Va. Code §§2Virginia has an EPA-approved air permitting program for both facilities, under state rules 45CSR13, 45CSR14, 45CSR19 aapplicable). Personnel: WVDEP has demonstrated adequate personnel implementation plan with respect to 8-hour ozone and PM2.5 NAAQS 

Secretary employs adequate personnel and retains specialists unde5-4(a)(8) that are "necessary, incident or convenient" to accommandate to carry out the implementation plan. Funding: The APCA provides adequate funding under W.Va. Code §2-5-4(a)(17) to carry out the implementation plan. W.Va. Code §22-statutory operating permit requirements for stationary sources under 45CSR30 establishes fees sufficient to cover the direct and administering the air pollution control planning process, Title V program, and support the air pollution control program authorizeAPCA also authorizes the establishment of fees to cover non-Title under 45CSR22. The air quality program also receives revenupenalties (Air Pollution Control Fund) and federal funds under Sectithe CAA, special federal funds for PM2.5, and state general appropria

§110(a)(2)(E)(ii) (ii) requirements that the state 

comply with the requirements respecting state boards under section 128, and 

State Boards Under Section 128: Because West Virginia does not happroves permits or enforcement orders, this element is not applicabl
§110(a)(2)(E)(iii) (iii) necessary assurances that, 

where the state has relied on a local or regional government, agency, or instrumentality for the implementation of any plan provision, the state has responsibility for ensuring adequate implementation of such plan provision; 

Responsibility for Implementation of Assured Local Plan Provi

modeling and consequent determination regarding the attainment staPanhandle counties relied on federal interstate transport programs omeasures contained in the EAC (70FR48287), West Virginia did nregional entities for the reductions required for attainment. The state will retain primacy for future plans that rely local or regiagencies or instrumentalities. 

§110(a)(2)(F) require, as may be prescribed by 

the Administrator -  (i) the installation, maintenance, and replacement of equipment, and the implementation of other necessary steps by owners or operators of stationary sources to monitor emissions from such sources,  (ii) periodic reports on the nature and amounts of emissions and emissions-related data from such sources, and  (iii) correlation of such reports by the state agency with any emission limitations or standards established pursuant to this Act, which reports shall be available at reasonable times for public inspection; 

Monitoring: W.Va. Code §22-5-4(a)(15) authorizes the Secretainstallation, maintenance and replacement of equipment, and the other necessary steps by owners or operators of stationary soemissions from such sources as the Secretary may prescribe. UnWest Virginia requires the installation, maintenance, and replacemequipment at stationary sources through permits issued under 45C45CSR19, 45CSR30, and via compliance orders. The state’s NOx S45CSR26) and CAIR rules (45CSR39, 45CSR40 & 45CSR41) installation, maintenance, and replacement of monitoring equipment. Reporting: W.Va. Code §§22-5-4(a)(15) authorizes the Secretary reports on the nature and amounts of emissions and emissionsowners or operators of stationary sources (monitoring data). Pursua

§§22-5-4(a)(14), the Secretary is authorized to require such inSecretary may require in a form or manner prescribed by the Seinventory program). Under this authority, West Virginia requires perinature and amounts of emissions and emissions-related data from through permits issued under 45CSR13, 45CSR14, 45CSR19, 4compliance orders. The state’s CAIR rules (45CSR39, 45CSR40 require periodic reporting of emissions data. Correlation of Reports: W.Va. Code §22-1-6(d)(3) authorizes “investigate for violations of statutes or rules which the departmeenforcing.” §22-5-4(a)(3) authorizes the Secretary to correlate preports with any emission limitations or standards established purs

45CSR14, 45CSR19, 45CSR30 or the CAA. As set forth in W.Va. CSecretary makes available at reasonable times for public inspe

emissions reported under §§22-5-4(a)(14) & (15). The Secretary haof making all records, reports or information obtained by the Departat public hearings under the provisions of the APCA available to ththe extent the records, reports or information are protected by conf

to 45CSR31. The types of records DEP routinely provides a
notifications, inspection reports, notices of violation, enforcement opermit review letters, sample results, monitoring reports, permits, appthat would relate to §110(a)(2)(F). WVDEP generally makes informpublic access through its website, but also makes hard copy repowritten request. 

§110(a)(2)(G) provide for authority comparable 

to that in section 303 and adequate contingency plans to implement such authority; 

Comparable Authority: W.Va. Code §22-5-5 authorizes the Secorder to cease and desist any activity that violates the Air PollutioSecretary may also suspend, modify or revoke a source’s permit. U

Secretary may also institute lawsuits for civil penalties. §22-5

Secretary to seek applications for injunctive relief. §22-5-8 authoriwith the written authorization of the governor, to shut down a 

preventing the emission of air pollutants which substantially 

emergency that requires immediate action to protect public health. AVirginia Code, §§22-5-4(a)(2) and 22-5-10, the Secretary may coaffirm accuracy of any information considered while executing author

-6, -7 or -8. Contingency Plans: SIP approved rule 45CSR11 (58FR34526) provto prevent the buildup of ozone and PM10 concentrations during p

meteorological conditions in which air pollutants may accumulate, the occurrence of an emergency due to the effects of these pollutachieve this purpose, three (3) stages of criteria (pollutant concentbeen established and specific emission reduction plans will be deveinitiated at each criteria stage to prevent further deterioration of the aquality region or substantial portion thereof. West Virginia satisfies the criteria to be classified a Priority III Reg§51.150(f) for particulate matter. As set forth in 40 CFR §51.150(c), Priority III do not need to develop episode (contingency) plans. To 

promulgated a classification system under the current 8 hour ozone a

§110(a)(2)(H) provide for revision of such plan- 

(i) from time to time as may be necessary to take account of revisions of such national primary or secondary ambient air quality standard or the availability of improved or more expeditious methods of attaining 

Revision of NAAQS: W.Va. Code §22-5-4(a)(16) authorizes the Sthings necessary and convenient to prepare and submit a plan. WVD

revised, and will continue to revise its NAAQS rules as necessary 

revisions of the national primary or secondary ambient air quality stanor more expeditious methods of attaining the standards. West Virginia submitted a NAAQS SIP revision on April 25, 2008. On West Virginia received full SIP approval of its NAAQS rule 45CSR8 rule contains ambient air quality standards for all criteria pollutants, 
such standard, and (ii) except as provided in paragraph (3)(C), whenever the Administrator finds on the basis of information available to the Administrator that the plan is substantially inadequate to attain the national ambient air quality standard which it implements, or to otherwise comply with any additional requirements established under this Act; 

PM2.5 NAAQS, equivalent to the national primary and secondary a

standards established under Section 109 of the Clean Air Act, and pUnited States Environmental Protection Agency under 40 CFR Part 2007. West Virginia submitted a NAAQS SIP revision (45CSR8) on Juadopts the 2008 8-hour ozone standard. Inadequate Plan: When, if ever, EPA finds the SIP is substantially in

the NAAQS which it implements or otherwise to comply with the CAArevise the plan as necessary for adequacy. 

§110(a)(2)(I) In the case of a plan or plan 

revision for an area designated as a nonattainment area, meet the applicable requirements of part D (relating to nonattainment areas); 

Non-Attainment Area SIPs: The Secretary is also authorized unde5-4(a)(16) to do all things necessary and convenient to prepare aunder the CAA. In the case of a implementation plan or plan redesignated as a non-attainment area, the Secretary shall implementation plan or plan revision meets the applicable requiremPart D of the CAA. 

§110(a)(2)(J) meet the applicable requirements 

of section 121 (relating to consultation) and section 127 (relating to public notification) 

Consultation: The APCA provides adequate authority under W.Va. Cfor West Virginia’s practices of consultation with local governments, Land Managers with respect to SIP development. WVDEP also centities regarding implementation plans for air quality maintenapreconstruction review of direct sources, nonattainment requiremenof significant deterioration. As an example, WVDEP consulted Managers on the development of West Virginia’s Regional Haze provided an additional 30-day review and comment period beyond review period.Notification: W.Va. Code §22-1-12 provides authority for the pu

NAAQS violations and education efforts as required by CAA SectioWVDEP issues a comprehensive Air Quality Annual Report, which coair quality data with the NAAQS, and tracks the Air Quality Index. T

emissions information and air quality highlights from the previous ypublic awareness of criteria pollutants and their effects on health; elinks to tips that improve air quality, links to technical websites anWest Virginia has also implemented an anti-idling program to reduschool buses and vehicles at public schools. 
Measures for PSD or Visibility: under SIP rule 45CSR14 (71applications filed by any person to construct major new or modpollution sources, intending to locate in areas with air quality worse to protect the public health and welfare, or that might impact tadequately meet the pre-construction review procedures and condAir Act as amended ....”. This rule includes specific federal requiremthat new or modified sources do not interfere with measures to deterioration of air quality. West Virginia’s Regional Haze SIP was submitted on June 18, 200law, it became technically and administratively complete on or ab2008. 

§110(a)(2)(K) provide for: 

(i) the performance of such air quality modeling as the Administrator may prescribe for the purpose of predicting the effect on ambient air quality of any emissions of any air pollutant for which the Administrator has established a national ambient air quality standard, and (ii) the submission, upon request, of data related to such air quality modeling to the Administrator; 

Air Quality Modeling: West Virginia Code, §§22-5-4(a)(1) & (Secretary to “develop ways and means for the regulation and controair of the state” and “conduct such studies and research relating to acontrol and abatement”. Inherent in West Virginia's authority to meet conduct studies and research is the obligation for WVDEP to perequired under the CAA to demonstrate attainment of the NAAQS, as Administrator. WVDEP participates in regional planning organizaAssociation for Southeastern Integrated Planning (ASIP), which modeling for member states. West Virginia will continue to perfrequired under the CAA to demonstrate attainment of the NAAQS. Submission of Data: W.Va. Code §§22-5-4(a)(2), 22-5-10 authorizes the Secretary to submit, upon request by the Administrapredicting the effect on ambient air quality of any emissions of an

which the Administrator has established a national ambient air qua

Virginia will continue to submit the air quality modeling data as part submissions and through Federal grant commitments or in other wrequest. 

§110(a)(2)(L) require the owner or operator of 

each major stationary source to pay to the permitting authority, as a condition of any permit required under this Act, a fee sufficient to cover- (i) the reasonable costs of reviewing and acting upon any 

Permit Fees for Review Cost: EPA has SIP approved PSD (71FR64470) and major NSR rule 45CSR19 (71FR64468) (consProgram permit fees are contained in the rules. Permit Fees for Implementing and Enforcing Permit Conditions: 

an approved Title V operating permit program under 45CSR30 (66FR

permit fees are contained in the rule. 
application for such a permit, and 

(ii) if the owner or operator receives a permit for such source, the reasonable costs of implementing and enforcing the terms and conditions of any such permit (not including any court costs or other costs associated with any enforcement action), until such fee requirement is superseded with respect to such sources by the Administrator's approval of a fee program under title V; 

§110(a)(2)(M) provide for consultation and 

participation by local political subdivisions affected by the plan; 

Consultation: W.Va. Code §22-5-4(a)(2), authorizes the Secretary and cooperate with local political subdivisions affected by the im

West Virginia consults with local governments, organizations and Larespect to SIP development. WVDEP also consults with such implementation plans for air quality maintenance requirements, precof direct sources, nonattainment requirements, and preventideterioration.