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--------------------------------------------------------------------------------------------------------------------- Technical Support Document

WEST VIRGINIA Area Designations For the

2010 SO 2 Primary National Ambient Air Quality Standard

Summary

Pursuant to section 107(d) of the Clean A ir Act (CAA), EPA must designate areas as either “nonattainment,” “attainment,” or “unclassifiable” for the 2010 1

- hour sulfur dioxide (SO 2 ) primary national ambient air quality standard (NAAQS). The CAA defines a nonattainment area as one that does not meet the NAAQS or that contributes to poor air quality in a nearby area that does not meet the NAAQS. Table 1 below identifies the counties or portions of counties in West Virginia that EPA is initially designating “nonattainment” based on monitored violations. EPA is not prepared to designate other areas in West Virginia , and will address them in a future final designations action

.

West Virginia submitted designation recommendations on May 23, 2011 and submitted supplemental information on January 22, 2013. On February 6, 2013, EPA sent out a letter with

intended initial designations for West Virgi nia. West Virginia responded in a letter dated April 5

, 2013. In West Virginia’s April 5, 2013 letter, they also indicated some areas in Ohio which they

felt should be nonattainment. These are discussed later in this Technical Support Document ( TS D )

. I nformation on the Ohio portions of the St eu benville OH

- WV area is included in the

TSD for Ohio.

Table 1. Nonattainment Area Designations for West Virginia

Area West Virginia’s

Recommended Designation of

Areas/Counties EPA’s

Nonattainment Designat ions of

Areas/Counties
Steubenville, OH

- WV Brooke County, WV (partial)

— Cross

Creek Tax District

Jefferson County , OH (partial)

— Cross Creek, Steubenville, Warren and Wells Townships Nonattainment

Nonattainment* Nonattainment

Nonattainment

Marshall, WV Marshall County, WV (partial)

— Clay, Franklin and Washington Tax Districts Nonattainment Nonattainment

* Recommendations and technical analyses for and by Ohio can be found in Ohio’s technical support document.2

Background

On June 2, 2010, EPA revised the primary SO 2 NAAQS (75 FR 35520) by establishing a new 1

- hour standard at a level of 75 parts per billion (ppb) which is met at an ambient air quality monitoring site when the 3

- year average of the annual 99 th percentile of the daily maximum 1

- hour average concentration s does not exceed 75 ppb , as determined in accordance with Appendix T of 40 CFR part 50 40 CFR 50.17(a)

- (b). EPA has determined that this is the level necessary to provide protection of public health with an a dequate margin of safety, especially for children, the elderly and those with asthma . T hese groups are particularly susceptible to the health effects associated with breathing SO 2

. The Agency is revoking the two prior primary standards of 140 ppb evaluat ed over 24

- hours, and 30 ppb evaluated over an entire year because the standards will not add additional public health protection given a 1

- hour standard at 75 ppb. Accordingly, EPA is not designating areas in this process on the basis of either of these two prior primary standards. Similarly, the secondary standard for SO 2 has not been revised, so EPA is not designating areas in this process on the basis of the secondary standard.

EPA’s SO 2 Designation Approach

Section 107(d) of the CAA provides that no later than one year after promulgation of a new or revised NAAQS, state Governors must submit their recommendations for designations and boundaries to EPA. This deadline was in June 2011. Section 107(d) also requires EPA to provide a notification to states of no less than 120 days prior to promulgating an initial area designation that is a modification of a state’s recommendation. EPA reviewed the State’s

recommendations and has notified the S tate through a letter signed by the Regional

Administr ator on February 6, 2013, of any intended modifications. While language in section 107 specifically addresses States, we intend to follow the same process for tribal governments, pursuant to section 301(d) of the CAA and the Tribal Authority Rule (40CFR Pa rt 49). Therefore, we are designating areas of tribal government , in consultation with the tribal government, on the same schedule as State designations. West Virginia does not have any tribal governments affected by this designation. If a state or tribal government does not submit designation recommendations, EPA will promulgat e the designations that it deems appropriate. If a State or tribal government disagrees with EPA’s intended area designations, it has an opportunity to demonstrate why any proposed modification is inappropriate.

Designations guidance was issued by EPA through a March 24, 2011 memorandum from Stephen D. Page, Director, U.S. EPA, Office of Air Quality Planning and Standards, to Air Division Directors, U.S. EPA Regions I

- X. This memor andum identifies factors EPA intends to

evaluate in determining boundaries for areas designated nonattainment. These 5 factors include: 1) Air quality data; 2) Emissions and emissions

- related data (location of sources and potential

contribution to ambien t SO 2 concentrations); 3) Meteorology (weather/transport patterns); 4) Geography/topography (mountain ranges or other air basin boundaries); and 5) Jurisdictional boundaries (e.g., counties, air districts, pre

- existing nonattainment areas, reservations,3

me tropolitan planning organization), among any other information deemed relevant to establishing appropriate area designations and boundaries for the 1

- hour SO 2 NAAQS.

The March 24, 2011 memo recommended that area boundaries be defaulted to the county

bound ary unless additional provided information justifies a larger or smaller boundary than that of the county. EPA believes it is appropriate to evaluate each potential area on a case

- by

- case basis, and to recognize that area

- specific analyses conducted by S t ates, tribal governments and/or EPA may support a different boundary than a default county boundary.

In this technical support document ( TSD ) , EPA discusses its review and technical analysis of the recommendations submitted by West Virgi nia regarding area s within West Virginia in response

to EPA’s proposed nonattainment area designation s for West Virginia for the 1

- hour SO 2 standard which were also made available for public comment ( 78 FR 11124 ) on February 15,

2013

. The response to comment document also contains information related to West Virginia’s response to EPA’s proposed nonattainment designations. Information related to Ohio may be found in the Response to Comment document and also in the Ohio TSD.

Definition s of important terms used in this document:

1) Designated “nonattainment” area

– an area which EPA has determined, based on a state recommendation and/or on the technical analysis included in this document, has violated the

2010 SO 2 NAAQS, based on three y ears of air quality monitoring data, or contributes to a violation in a nearby area.

2 ) Recommended nonattainment area

– an area a State or tribal government has recommended to EPA be designated as nonattainment.

3 ) Violating monitor

– an ambient air monitor meeting all methods, quality assurance and citing criteria and requirements whose valid design value exceeds 75 ppb, as described in Appendix T of 40 CFR part 50.

4 ) 2010 SO 2 NAAQS

– 75 ppb, national ambient air quality standard for SO 2 promulgated in

2010. Based on the 3

- year average of the 99 th percentile of the annual distribution of daily

maximum 1

- hour average concentrations

5 ) Design Value

– a statistic that describes the air quality status of a given area relative to the

level o f the NAAQS.

Nonattainment Designations

Introduction

In West Virginia’s designation recommendation letter to EPA, dated May 23, 2011, Randy Huffman, Secretary of the West Virginia Department of Environmental Protection (WVDEP),4

recommended that Broo ke, Hancock, Marshall, Monongalia, and Wood C ounties be designated

as nonattainment for the 2010 SO 2 NAAQS based on monitored air quality data from 2008

- 2010. On January 22, 2013 , West Virginia submitted a revised recommendation letter to EPA indicating that s ubsequent air monitoring data (2010

- 2012) suggests that the air quality has significantly improved in three of those counties: monitors in Hancock, Monongalia, and Wood are no longer showing violations of the 2010 1

- hour SO 2 standard. EPA took this information into consideration when it responded to West Virginia’s original nonattainment

recommendations. On April 5 , 2013, West Virginia submitted a response to EPA’s 120

- day letter and recommended that a portion of Brooke County (Cross Creek Tax Distr ict) as well as a portion of Marshall County (Clay, Franklin and Washington Tax Districts) be designated as nonattainment. West Virginia also recommended that a portion of Belmont County, Ohio (Mead Township ) as well as a portion of Monroe County, Ohio (O hio Township) be designated as nonattainment.

Based on EPA’s technical analysis, EPA is initially designating two areas as nonattainment (Table 1) based on monitored violations of the NAAQS

. The Steubenville , OH

- WV

Nonattainment Area consists of a portion of Brooke County, WV (Cross Creek Tax District) and a portion of Jefferson County, OH (Cross Creek, Steubenville, Warren and Wells Townships).

The Marshall N onattainment Area consists of a portion of Marshall County, WV ( Washington,

Franklin and Clay Tax Districts)

. The TSD for Ohio and Response to Comment document contain a detailed discussion about the Ohio portion of the Steubenville

, OH

- WV Nonattainment

A rea as well as information regarding the status of M ead Township in Belmont C ounty Ohio and Ohio Township in Monroe County Ohio

.

The 5 factors were used to analyze the nonattainment areas for 1

- hour SO 2 designations :

1. Air quality data. This factor considers the SO 2 air quality monitoring data from EPA’s Air Trends website (see http://www.epa.gov/airtrends/values.html ), primarily including the design values (in ppb) calculated for each monitor in the area for the 2009

- 201 1

three

- year period

. Additional information on monitored values for 2010

- 2012 provided by West Virgin i a was also considered. A monitor’s design value indicates whether that

monitor violates a specified air quality standard. The 20 10 SO 2 NAAQS is met at a monitoring site when the identified design value is vali d and less than or equal to 75 ppb as described in Appendix T of 40 CFR part 50

. An ambient air monitor, whose valid design value exceeds 75 ppb, as described in Appendix T of 40 CFR part 50

, is deemed a violating monitor. A design value is only valid if minimum data completeness criteria

are met. A n SO 2 design value that meets the NAAQS is generally considered valid if it

encompasses 3 years of complete data. A year is complete when all 4 quarters are complete. A quarter is complete when 75% of the da ys are complete. A day is complete

when it has 75% of its hours. Data substitution tests are described in Appendix T of 40 CFR part 50 . Areas where monitoring data indicate a violation of the 1

- hour, 75 ppb primary SO 2 standard are being designated as n onattainment.

2. Emissions and em issions

- related data (location of sources and potential contribution to

ambient SO 2 concentrations). EPA reviewed data for the point source and non point source categories from version 3 of the 2008 National Emissions Inve ntory (NEI ) which

is the most current version of the national inventory now availabl e (s ee5

http://www.epa.gov/ttn/chief/net/2008inventory.html )

, as well as emissions information

West Virginia provided

. Generally, the point source inventory represents the bulk of the

SO 2 emissions in EPA Region III.

3. Meteorology (weather/transport patterns). EPA evaluated meteorological data to help determine how weather conditions, including wind sp eed and direction, affect the plume of sources contributing to ambient SO 2 concentrations. The National Weather Service maintains surface and upper air monitoring sites across the United States. Automated Surface Observing System (ASOS) ( http://www.weather.gov/asos ) sites collect hourly averaged wind measurements including wind direction and wind speed. Upper air measurements (rawinsonde) are collected at a limited number of sites where vertical wind profiles are taken using weather balloons. Measurements taken at ASOS and rawinsonde sites are often used in dispersion modeling analyses using EPA’s AERMOD modeling

system.

One

- minute meteorological wind fields for an area’s nearby airport(s) were downloaded

and run through AERMOD’s preprocessor AERMINUTE to produce hourly averaged wind fields. This data was then run through Lakes Environmental’s WRPLOT software to produce wind roses for the airports, showing pre vailing wind patterns in the area.

4. Geography/topog raphy (mountain ranges or other air basin boundaries) . EPA examined the physical features of the land that might affect the distribution of SO 2 over an area. Mountains or other physical features may affect the distribution of emissions, and may help defi ne boundaries. Maps depicting elevations and point sources were constructed and evaluated to determine the effects of the topography on point source emissions.

5. Jurisdictional boundaries As discussed in the West Virginia TSD that was included in the

docke t as part of EPA’s proposal for nonattainment areas (78 FR 11124) on February 15,

2013

, EPA reviewed several possible boundaries but used county boundaries for the proposed W est V irginia portions of proposed nonattainment area s. In response to EPA’s

prop osal, West Virginia recommended that the boundaries for W est V irginia portions of

nonatt a inment areas be based on partial counties and that boundaries could be determined

based on the 2013 version of the tax district boundaries within its counties.

The five factor descriptions above are a combination of descriptions from the March 24, 2011 memo and other relevant information pertaining to this TSD.

Technical Analysis for the Steubenville

, OH

- WV Nonattainment Area

In EPA’s 120

- day letter, EPA pr oposed that the Steubenville, OH

- WV Nonattainment A rea include Brooke County, WV in its entirety and a portion of Jefferson County, OH. In response

to EPA’s 120

- day letter West Virginia recommended that only a portion of Brooke County (Cross Creek Tax Dis trict) be included in the nonattainment area. In West Virginia’s response to6

the 120

- day letter, West Virginia included an analysis supporting its recommendation of a portion of Brooke County to be included in the Steubenville, OH

- WV Nonattainment Area.

Based on EPA's technical analysis described below, EPA intends to initially design a te

, based on the violating monitors in Brooke County in West Virginia, a portion of Brooke County (Cross Creek Tax District) and a portion of Jefferson County, Ohio ( Cross Creek, Steubenville, Warren and Wells Townships ) as nonattainment for the 2 010 1

- hour SO 2 NAAQS as part of the

Steubenville

, OH

- WV N onattainment A rea

. The analysis in this TSD is primaril y for the West Virginia portion of the nonattainment area. The anal ysis for the Ohio portion (Jefferson Count y )

can be found in the TSD for Ohio.

Air Quality Data

This factor considers the SO 2 design values (in ppb ) for air quality monitors in Brooke County

based on certified data for the 200 9

- 20 11 period

. The 2010 1

- hour SO 2 design values for all the

monitors located in Brooke Count y are shown in Table 2. In West Virginia’s response to EPA’s

120

- day letter, EPA was informed that all the monitor s are located in the Cross Creek Tax District of Brooke County

Table 2. Brooke County Monitor Trends : 1

- Hour SO 2 99 th % and Design Values in ppb

Monitor ID 99 th % Design Value Design

Value

2007 2008 2009 2010 2011 2008

- 10 2009

- 11

Mahan Lane 54

- 009

- 0005 131 168 82 131 143 127 119

McKims 54

- 009

- 0007 168 137 81 92 75 103 83

Marland Heights 54

- 009

- 0011 169 159 143 143 219 ** 148 174 **

** Incomplete 2 nd and 3 rd quarters of 2011 data do not meet requirements in Appendix T of 40 CFR Part 50

All monitors with complete data in Brook e County showed violations using both 200 8

- 1 0 and

20 09

- 1 1 data . W est V irginia provided data for 2010

- 2012 which still showed violations in Brooke County. An additional monitor in Jefferson County, Ohio is also showing a monitored

violation of the 2010 1

- ho ur SO 2 NAAQS, as discussed in the TSD for Ohio . Based on evidence that violations are occurring in Brooke County, West Virginia and Jefferson County, Ohio, EPA

is initially desig nating a nonattainment area that includes the sources in the area that we are currently prepared to conclude contribute to these monitored violations. Information re lated to

the monitoring locations which were provided by West Virginia in its response to EPA’s 120

- day letter shows that the area of concern with respect to the monitoring data is limited to the Cross Creek Tax District of Brooke County.

Emissions and Emissions

- Related Data

Evidence of SO 2 emissions sources in the vicinity of a violating monitor is an important factor for determining whether a nearby area is c ontributing to a monitored violation. For this factor,7

EPA evaluated county

- level emissions data for SO 2 and any change in SO 2 emitting activities since the date represented by those emissions data

. Areas and sources that we are not yet prepared to concl ude are contributing to the monitored violation are not included in this initial

nonattainment area. These areas and sources will be addressed in a future final designations

action.

Emissions

In its response to EPA’s 120

- day letter, West Virginia provi de d updated emissions information

from th eir draft 2011 NEI. EPA also re viewed v3 of the 2008 NEI as well as the draft 2011 NEI

data provided by W est V irginia

.

Table 3 shows total emissions of SO 2 in tons per year (tpy) for sources emitting greater than 100 tpy of SO 2 according to the 2008 NEI in Brooke County in WV. The Ohio TSD provides a discussion of those sources in the Ohio portion of the nonattainment area.

Table 3

. SO 2 Emissions in Steubenville, OH

- WV Nonattainment Area

County Facility

Located in

State

Recommended

Nonattainment

Area? Facility Name Total Facility

SO 2 Emissions

from 20 08

NEI (tpy) Draft 2011

NEI SO 2 Emissions (tpy)

Brooke , WV Yes Mountain State Carbon,

LLC 731 697‡

‡ Draft 2011 NEI provided by WV DEP

Currently, all sources of SO 2 in Brooke County are located in the Cross Creek Tax District. In terms of emissions, the Cross Creek Tax District is the only area of concern for Brooke County.

Meteorology (weather/transport patterns)

Evidence of sour ce

- receptor relationships between specific emissions sources and high SO 2 values at violating monitors is another important factor in determining the appropriate contributing areas and the appropriate extent of the nonattainment area boundary. For this fa ctor,
EPA considered data from sites that collected hourly averaged wind measurements including wind direction and speed for 5 years. The two closest meteorological monitoring sites currently operating near the violating monitors in Brooke County are at t he Wheeling/Ohio County Airport and the Pittsburgh International Airport. An ASOS and rawinsonde site is located at the Pittsburgh International Airport. The Washington County Airport in P ennsylvania was also

included

. H owever, the data recovery at this site was not as complete as at the Pittsburgh and Wheeling sites. One

- minute meteorological wind fields for the Pittsburgh and Wheeling ASOS8

sites w ere downloaded and run through AERMOD’s preprocessor AERMINUTE to produce hourly averaged wind fields. These data along with the Washington County data recovered from the Pennsylvania State Climatologists Office were then run through Lakes Environmental’s

WR PLOT software to produce wind roses for the surface sites nearest the Brooke County

monitors

. Figure 1 depict s the ASOS wind roses for the ASOS sites closest to the Brooke County monitors.

Figure 1

. ASOS Monitoring Sites

Wind rose plots for Pittsburgh International, Wheeling/Ohio County and Washington County airports show there are slightly different wind distribution patterns. At Pittsburgh International airport, the prevailing surface winds are predominantly out of the west with secondary peaks out of the southwest and northwest, whereas the winds at the Wheeling, Ohio County airport are predominantly out of the southwest. These slightly different wind patterns between the sites are probably due to differences in local topography.

Give n this information

, with a dominant southwest wind at the Wheeling, Ohio County airport, EPA is not prepared to conclude that smaller sources in Hancock County and the l arge sources located northeast of the violating monitors

, are likely to be contributing to the violating Brooke County monitors. (These sources and areas will be addressed in a future final designations action.) These prevailing wind patterns, however, show that the emissions from large sources in Jefferson County are likely impacting the v iolat ing monitors in Brooke County. In West Virginia’s response to EPA’s 120

- day letter, it was recommended that the Buffalo Tax district in West Virginia be removed from the nonattainment area because there are no sources in that tax9

district , therefore no transport of emissions origin ating from that area can occur. In terms of transport, the Cross Creek Tax District is therefore Brooke County’s most likely area of concern.

Geography/topography (mountain ranges or other air basin boundaries)

Brooke Co unty lies on the easter n side of the Ohio River. The C ounty’s elevated terrain contrasts with the lower elevations of the Ohio River and its tributaries that pass through the counties. This creates sharp contrasts in elevation with the Ohio River sitting around 200 meters above mean sea level and the adjacent mountains exceeding 350 meters.

Most of the large (>100 tpy) point sources in this region reside within the Ohio River Valley. It should be noted that the three surface meteorological sites reviewe d in the previous section are located at higher elevations than most of the point sources, and therefore sources may be subject to different wind patterns, which could influen ce local dispersion patterns. It is unlikely, however that this would impact the transport of pollutants from large sources west of the violating monitors given that the emissions from those sources are significant. In response to

EPA’s 120

- day letter, West Virginia concurred with EPA’s characterization that geography/topography are not significant in determining the nonattainment boundary.

Jurisdictional boundaries

EPA provided information about all boundaries considered prio r to proposing nonatt a inment

areas and this i nformation can be found in the W est Virginia TSD as part of the docket on proposed designations (78 FR 11124) and is not restated here. EPA originally proposed including all of Brooke C ounty in the nonattainment area. However

, additional information provided by West Virginia in respo n se to EPA’s proposal demonstrates that the monitors and

so urces of concern in this area of West Virginia are all located in the Cross Creek T ax D istrict within Brooke County. Therefore, EPA is including only the Cross Creek T ax D istrict within

Brooke County, WV in th e initial nonattainment area.

Conc lusion for the Steubenville, OH

- WV Nonattainment Area

After considering t he factors described above, EPA find s that the boundary for the portion of Brooke County, WV with violating monitors is a multi

- state nonattainme nt area consisting of the

Cross Creek Tax District of Brooke County an d a portion of Jefferson County in Ohio (Cross Creek, Steubenville, Warren and Wells Townships) as identified in Table 1 with the area name Steubenville , OH

- WV Nonattainment A rea for the 2010 SO 2 NAAQS . Refer to Figure 2 for a depiction of the nonattainment area.

The air quality monitors in the Cross Creek Tax District of Brooke County show violation s of the

2010 SO 2 NAAQS, based on certified 200 9

- 201 1 air quality data

. Jefferson County , Ohio is a nearby area with sources that EPA finds contribute to the SO 2 concentrations in Brooke Count y

. Available emissions, m eteorological data, and geographical data suggest that large emission s sources west and southwest of the monit ors likely impact the monitors and contribute to SO 210

NAAQS violations in Brooke County. Since there are no sources located in the Buffalo Tax District (the only other tax district in Brooke County), which is located south of the violating monitors, this t ax district was not included in the S t eubenville, OH

- WV Nonattainment Area.

Additionally, in response to EPA’s 120

- day letter, West Virginia provided supporting information as referenced in the five factor analysis that assisted EPA in concluding that on ly a portion of Brooke County be included in the initial Steubenville, OH

- WV N onattainment A rea.

Based on the consideration of all the relevant and available information, as described above, EPA believes that the boundaries described herein encompass the appropriate initial nonattainment area based on violating monitors in Brooke County in West Virginia. In a subsequent round of designations we will make final designation decisions for areas that are not currently included in the nonattainment area de signations addressed in this TSD.

Figure 2

. Steubenville

, OH

- WV Nonattainment Area11

Technical Analysis for the Marshall
, WV Nonattainment Area (Previously proposed as the Wheeling, WV

- OH Nonattainment Area )

In EPA’s 120

- day letter, EPA originally proposed that an area called the Wheeling, WV

- OH Nonattainment Area include Marshall County, WV in its entirety and a portion of Belmont County, OH. In response to EPA’s 120

- day letter West Virginia recommended that a portion of

Marshall County , WV (Washington, Clay, and Franklin Tax Districts ) , a portion of Belmont County, OH (Mead Township), as well as a portion of Monroe County, OH (Ohio Township) be included in the Wheeling, WV

- OH Nonattainment Area . In West Virginia’s response to the 120

- d ay letter, West Virginia included an analysis supporting its boundary recommendations for the Wheeling, WV

- OH Nonattainment Area

. While EPA agrees with some of West Virginia’s recommendations, EPA does not agree with all of them.

EPA’s technical analysis for th is Area, now known as th e Marshall

, WV No nattainment Area,

identifies a portion of the C ounty with a monitor that violates the 2010 SO 2 NAAQS, and evaluates nearby counties for contributions to SO 2 concentrations in the A rea. For this area, a porti on of Marshall County, WV has a violating monitor. EPA has evaluated this C ount y and nearby counties based on the weight of evidence of the factors recommended in the March 24, 2011 guidance issued by EPA.

Based on the technical analysis described below, EPA is initially designating a portion of Marshall County (Washington, Clay and Franklin Tax Districts) in West Virginia as nonattainment for the 2 010 SO 2 NAAQS as part of the Marshall

, WV N onattainment A rea

. The analy sis in this TSD is primarily for the West Virginia portion of the nonattainment area.
D etailed information expla i ning why Mead Township in Belmont C ounty in Ohio was removed

from the p r oposed area along with additional information about Monroe County is included in

the Response To Comments and the TSD for Ohio

. Areas and sources that we are not yet prepared to conclude are contributing to the monitored violation are not included in this initial

nona ttainment area , and will be addressed in a future final designations action

.

Air Quality Data

This factor considers the SO 2 air quality monitoring data, including design values (in ppb )

calculated for all air quality monitors in Marshall C ounty, WV and primarily based on certified

2009

- 20 11 data

. West Virginia provided monitoring data for 2010

- 2012 which was also considered and indicates that the monitor in this county is not yet attaining the SO 2 NAAQS.

The 2010 1

- hour SO 2 design value f or the monitor located in Marshall County is shown in Table

4

.

Table 4

. Marshall County Monitor Trend : 1

- Hour SO 2 99 th % and Design Value in Parts

per Billion (ppb)

Monitor

Name Monitor Air

Quality System ID 99 th % Design

Value Design

Value

2007 2008 2009 2010 2011 2008

- 10 2009

- 11

Moundsville 54

- 051

- 1002 161 113 61 101 79 92 8012

One

- hour SO 2 design values appear to be generally falling over the last four years though there is insufficient data to clearly establish a definitive trend. The Marshall County monitor’s 99 th % concentration for 2009 is significantly lower than its other values. The severe recession during 2009 or decreases in local source emissions in the vicinity of the monitor could have contributed

to the monitor’s lower conc entrations in that year

. In response to EPA’s 120

- day letter, West Virginia informed EPA that the violating monitor is located in the Washington Tax District. This information provided by West Virginia shows that the area of concern with respect to the

m onitoring data is limited to the Washington Tax District of Marshall County.

Emissions and Emissions

- Related Data

Evidence of SO 2 emissions sources in the vicinity of a violating monitor is an important factor for determining whether a nearby area is contributing to a monitored violation. For this factor, EPA evaluated county

- level emission s data for SO 2 and any change in SO 2 emitt ing activities since the date represented by those emissions data

.

Emissions

In its response to EPA’s 120

- day letter, West Virginia provided updated emissions information

from their draft 2011 NEI. EPA reviewed v3 of the 2008 NEI as well as the draft 2011 NEI data and some CAMD data provided by W est Virginia

.

Table 5 shows total emissions of SO 2 in tons per year (tpy) for violating and potentially contributing counties in and arou nd the Marshall

, WV Nonattainment Area and sources emitting greater than 100 tpy of SO 2 according to the 2008 NEI . EPA notes that the only significant changes in emissions from the previous TSD provided in the docket for proposed designations

for the sour ces within Marshall County were at the Kammer Plant. However, this source is still emitting significant emissions and contributing to nonattainment. Also

, any significant changes in Ohio were generally emission decreases. The Ohio TSD provides a discussi on of those sources in the Ohio portion of the nonattainment area.

Table 5

. SO 2 Emissions in the Vicinity of the Marshall

, WV Nonattainment Area

County Facility

Located in

State

Recommended

Nonattainment

Area? Facility

Name Total Facility SO 2

Emissions 2008 NEI

version 3 or CAMD2011 (tpy)

WV’s draft data CAMD 2012 SO 2 Emissions (tpy)

Marshall

, WV Yes Ohio Power

– Kammer

Plant 32,050 19,717

Marshall

, WV Yes PPG Industries,

Inc. 7,693

Marshall

, Yes Rain CII 7,63013

WV Carbon

Moundesville Calcining

Marshall

, WV Yes Ohio Power

- Mitchell

Plant 3,024 3,455

Marshall

, WV Yes Columbian

Chemicals Company 1,180

Belmont

, OH No R.E. Burger

Plant 15,126

Monroe,

OH No Ormet Primary

Aluminum 2,442

However, i n re sponse to EPA’s 120

- day letter, West Virginia recommended including the Ohio Township of Monroe County

, Ohio which is where Ormet Primary Aluminum is located. EPA’s response to comment document contains additional information as well as the Ohio TSD to

address this comme nt.

Meteorology (weather/transport patterns)

Evidence of source

- receptor relationships between specific emissions sources and high SO 2 values at violating monitors is another important factor in determining the appropriate contributing areas and the appropriate extent of the nonattainment area boundary. For this factor,

EPA considered data from sites that collected hourly averaged wind measurements including wind direction and speed for 5 years. There appear s to only be one ASOS and one rawinson de site located near the violating monitor in Marshall County (Figure 3 ) . The closest surface site is the Wheeling/ Ohio County Airport approximately 30 kilometers north of the Marshall County monitor. A rawinsonde site is located at the Pittsburgh Intern ational Airport located approximately 77 kilometers to the northeast

. One

- minute meteorological wind fields for the Wheeling / Ohio County Airport site w ere downloaded and run through AERMOD’s preprocessor AERMINUTE to produce hourly averaged wind fields. This data was then run through Lakes Environmental’s WRPLOT software to produce wind roses for the Wheeling / Ohio County Airport, the surface site nearest t he Marshall County monitor

.

Figure 3

. Marshall County, WV

- ASOS Monitoring Sites14

The wind rose indicates that a t the Wheeling / Ohio County Airport , the prevailing surface winds are predominantly out of the southwest and west

. Given this information, the sources west and southwest of the violating monitor, particularly those within close proximity of the violating monitor, are likely to have the greatest impact on the violating monitor in Marshall County. EPA is not prepared to conclude that s ources north and east are likely to contribute to the violating monitor in Marshall County. (These sources will be addressed in a future final designations action.) Since the meteoro l o gy indicates transport of SO 2 coming from the south an d west, West Virginia recommended that the Franklin Tax District be included in the Wheeling, WV

- OH

Nonattainment Area since this tax district is located south of the monitor and contains several

sources of SO 2 . Additionally

, West Virginia’s analysis of w ind direction has led them to conclude that R.E. Burger and Ormet Aluminum affect the violating monitor because these

sources are located south and west of the monitor and the prevailing winds are out of the south

and west. However, a dditional em ission r eductio ns have occurred at the B urger facility following a federally enforceable Consent Decree which makes it unlikely to contribute to continuing nonattainment at the Marshall County m onitor . T he Ormet facility is about 25 km away from the monitor and there is impeding terrain between Or met and the monitor location

. Please see the Response to C omment document and the Ohio TSD f or additional information.

Therefore

, EPA is not prepared to conclud e that the O r met facility is contributing to the

monitored violation

. We will make final designation decisions for areas outside Marshall County, WV in a subsequent round of designations.

Geography/topography (mountain ranges or other air basin boundarie s)

Marshall County lies on the eastern side of the Ohio River. The county’s elevated terrain contrasts with the lower elevations of the Ohio River and its tributaries that pass through the15

county. This creates sharp differences in elevation with the Ohi o River sitting just under 200 meters above mean sea level and the adjacent mountains often exceeding 350 meters. Nearly all of the point sources within 50 kilometers of the Marshall County monitor lie along the Ohio River. Although the surface meteorolo gical site reviewed in the previous section may be located at a somewhat higher elevation than most of the point sources, the difference in elevation is not significant enough where it is likely that there would be substantial differences in wind patterns between the two locations. Therefore, local dispersion patterns are likely predominantly from the southwest/west as well and sources located southwest and west of the monitor are likely to contribute to nonattainment in Marshall County. In response to EP A’s 120

- day letter, West Virginia recommended that the tax districts to the east of the monitor and sources not be designated nonattainment because the local dispersion patterns are predominantly from the southwest/west. West Virginia also recommended tha t a portion of Belmont County and a portion of Monroe County (Ohio Township) be included in the Wheeling, WV

- OH nonattainment area because they are located along the river valley channel and are in the path of

channel flow that moves from south to north. Although EPA does not disagree that sources in Belmont County and Monroe County are gen e rally located in pathways that approach the monitor location, other information such as emissions and source distance from the monitor do not provide sufficient informa tion to conclude that source s in these areas in Ohio should be considered nearby contributors to the Marshall C ounty monitor. Additional information about

these sources can be found in the R e sponse to Comme n t document and in the Ohio T SD.

Jurisdictional boundaries

EPA provided information about all boundaries considered prior to proposing nonattainment

areas and this information can be found in the W est Virginia TSD as part of the docket on proposed designations (78 FR 11124 ) and is no t restated here. EPA originally proposed including all of Marshall County in the nonattainment area. However

, additional information provided by West Virginia in response to EPA’s proposal demonstrates that the monitor and

sources of concern in this area of West Virginia are all located in three T ax D istricts within Marshall County: Washington, Franklin and Clay Tax Districts. Therefore, EPA is including only these three tax districts w i thin Marshall Co unty in the initial nonattainment area and EPA is

no t including any areas in Ohio.

Conclusion for the Marshall

, WV Nonattainment Area

The air quality monitor in Marshall County , WV shows a violation of the 2010 SO 2 NAAQS,

based on certified 200 9

- 201 1 air quality data and data provided by West Virginia for 2010

- 2012. Information provided by West Virginia indicates that only a portion of Marshall County contains sources likely to be contributing to the monitored violation in this area. In addition

, d ue to recent
emission reductions at the R. E. Burger facility in Belmont County , OH following a federally

enforceable Consent Decree and a lack of sufficient information to show that the Ormet facility is contributing to the monitored violation as describe d in the factors above, no areas in Ohio are

included in this initial nonattainment area.16

After considering the factors descr ibed above, EPA find s that the bound ary for the initial Marshall, WV Nonattainment Area should consist of the portions of Marsha ll C ounty that encompass the C la y, Franklin and Washingt on Tax Districts. In a subsequent round of designations we will make final designatio ns decisions for areas that are not currently included in the nonattainment area designation addressed in this TSD. A m ap of the area is provided in Figure 4

.

Figure 4 : Marshall WV Nonattainment Area

EPA’s Area Designations Conclusion for West Virginia

EPA has reviewed the information above and find s tha t it is appropriate to designate based on violating monitors the portions of counties listed in Table 1 as nonattainment for the 2010 SO 2 NAAQS. EPA intends to designate portions of Brooke and Marshall Counties as nonattainment after considering the factors and information described in th is technical support document. The

nonattainment area boundaries that EPA describes above are based on the five factors which include: air quality data, emiss ions

- related data, meteorology, geography/topography, and jurisdictional boundaries. Based on the consideration of all the relevant and available information, as described above, EPA believes that the boundaries described herein encompass17

sufficient initial area s that do not meet (or that contribute to ambient air quality in a nearby area that does not meet) the 20 10 SO 2 NAAQS based on the monitored violations

.