1

---------------------------------------------------------------------------------------------------------------------

---------------------------------------------------------------------------------------------------------------------

Technical Support Document

WEST VIRGINIA

Area Designations For the 

2010 SO2 Primary National Ambient Air Quality Standard

Summary

Pursuant to section 107(d) of the Clean Air Act (CAA), EPA must designate areas as either 

“nonattainment,” “attainment,” or “unclassifiable” for the 2010 1-hour sulfur dioxide (SO2) 

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 Virginia. 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 

(TSD). Information on the Ohio portions of the Steubenville 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 

Designations 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 SO2 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 99th percentile of the daily maximum 1-

hour average concentrations 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 adequate margin of safety, especially for children, the 

elderly and those with asthma. These groups are particularly susceptible to the health effects 

associated with breathing SO2. The Agency is revoking the two prior primary standards of 140 

ppb evaluated 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 SO2 has not been revised, so EPA is not designating areas 

in this process on the basis of the secondary standard.

EPA’s SO2 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 State through a letter signed by the Regional 

Administrator 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 Part 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 promulgate 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 memorandum 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 ambient SO2 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

metropolitan planning organization), among any other information deemed relevant to 

establishing appropriate area designations and boundaries for the 1-hour SO2 NAAQS.

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

boundary 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 States, 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 Virginia regarding areas within West Virginia in response 

to EPA’s proposed nonattainment area designations for West Virginia for the 1-hour SO2

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. 

Definitions 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 SO2 NAAQS, based on three years 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 SO2 NAAQS – 75 ppb, national ambient air quality standard for SO2 promulgated in 

2010. Based on the 3-year average of the 99th 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 of 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 Brooke, Hancock, Marshall, Monongalia, and Wood Counties be designated 

as nonattainment for the 2010 SO2 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 subsequent 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 SO2 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 District) 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 (Ohio 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 Nonattainment 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 

Area as well as information regarding the status of Mead Township in Belmont County Ohio and 

Ohio Township in Monroe County Ohio.

The 5 factors were used to analyze the nonattainment areas for 1-hour SO2 designations:

1. Air quality data. This factor considers the SO2 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 2009-2011

three-year period. Additional information on monitored values for 2010-2012 provided 

by West Virginia was also considered. A monitor’s design value indicates whether that 

monitor violates a specified air quality standard. The 2010 SO2 NAAQS is met at a 

monitoring site when the identified design value is valid 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. An SO2 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 days 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 SO2 standard are being designated as nonattainment. 

2. Emissions and emissions-related data (location of sources and potential contribution to 

ambient SO2 concentrations). EPA reviewed data for the point source and non point

source categories from version 3 of the 2008 National Emissions Inventory (NEI) which

is the most current version of the national inventory now available (see
5

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 

SO2 emissions in EPA Region III.

3. Meteorology (weather/transport patterns). EPA evaluated meteorological data to help 

determine how weather conditions, including wind speed and direction, affect the plume 

of sources contributing to ambient SO2 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 prevailing wind patterns in the area.

4. Geography/topography (mountain ranges or other air basin boundaries). EPA examined 

the physical features of the land that might affect the distribution of SO2 over an area. 

Mountains or other physical features may affect the distribution of emissions, and may 

help define 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 

docket 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 West Virginia portions of proposed nonattainment areas. In response to EPA’s 

proposal, West Virginia recommended that the boundaries for West Virginia portions of 

nonattainment 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 proposed that the Steubenville, OH-WV Nonattainment Area 

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 District) be included in the nonattainment area. In West Virginia’s response to 
6

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 designate, 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 2010 1-hour SO2 NAAQS as part of the 

Steubenville, OH-WV Nonattainment Area. The analysis in this TSD is primarily for the West 

Virginia portion of the nonattainment area. The analysis for the Ohio portion (Jefferson County) 

can be found in the TSD for Ohio.

Air Quality Data 

This factor considers the SO2 design values (in ppb) for air quality monitors in Brooke County

based on certified data for the 2009-2011 period. The 2010 1-hour SO2 design values for all the 

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

120-day letter, EPA was informed that all the monitors are located in the Cross Creek Tax 

District of Brooke County 

Table 2. Brooke County Monitor Trends: 1-Hour SO2 99th % and Design Values in ppb

Monitor ID 99th % 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 2nd and 3rd quarters of 2011 data do not meet requirements in Appendix T of 40 CFR Part 50

All monitors with complete data in Brooke County showed violations using both 2008-10 and 

2009-11 data. West Virginia 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-hour SO2 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 designating a nonattainment area that includes the sources in the area that we are 

currently prepared to conclude contribute to these monitored violations. Information related 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 SO2 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, 
7

EPA evaluated county-level emissions data for SO2 and any change in SO2 emitting activities 

since the date represented by those emissions data. Areas and sources that we are not yet 

prepared to conclude 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 provided updated emissions information 

from their draft 2011 NEI. EPA also reviewed v3 of the 2008 NEI as well as the draft 2011 NEI 

data provided by West Virginia.

Table 3 shows total emissions of SO2 in tons per year (tpy) for sources emitting greater than 100 

tpy of SO2 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. SO2 Emissions in Steubenville, OH-WV Nonattainment Area

County

Facility 

Located in 

State

Recommended 

Nonattainment 

Area?

Facility Name 

Total Facility 

SO2

Emissions

from 2008

NEI (tpy)

Draft 2011 

NEI SO2

Emissions 

(tpy) 

Brooke, WV Yes Mountain State Carbon, 

LLC

731 697‡

‡ Draft 2011 NEI provided by WV DEP

 

Currently, all sources of SO2 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 source-receptor relationships between specific emissions sources and high SO2

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. The two closest meteorological monitoring sites currently 

operating near the violating monitors in Brooke County are at the 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 Pennsylvania was also 

included. However, 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 ASOS 
8

sites were 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 

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

monitors. Figure 1 depicts 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. 

Given 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 large 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 violating 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 tax 
9

district, therefore no transport of emissions originating 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 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 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 reviewed 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 influence 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 prior to proposing nonattainment

areas and this information can be found in the West 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 County in the nonattainment area. However, additional information 

provided by West Virginia in response to EPA’s proposal demonstrates that the monitors and 

sources of concern in this area of West Virginia are all located in the Cross Creek Tax District 

within Brooke County. Therefore, EPA is including only the Cross Creek Tax District within 

Brooke County, WV in the initial nonattainment area. 

Conclusion for the Steubenville, OH-WV Nonattainment Area

After considering the factors described above, EPA finds that the boundary for the portion of 

Brooke County, WV with violating monitors is a multi-state nonattainment area consisting of the 

Cross Creek Tax District of Brooke County and 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 Area for the 2010 SO2 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 violations of the 

2010 SO2 NAAQS, based on certified 2009-2011 air quality data. Jefferson County, Ohio is a 

nearby area with sources that EPA finds contribute to the SO2 concentrations in Brooke County. 

Available emissions, meteorological data, and geographical data suggest that large emissions 

sources west and southwest of the monitors likely impact the monitors and contribute to SO2
10

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 tax district was not included in the Steubenville, 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 only a 

portion of Brooke County be included in the initial Steubenville, OH-WV Nonattainment Area. 

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 designations addressed in this TSD.

Figure 2. Steubenville, OH-WV Nonattainment Area 
11

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-

day 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 this Area, now known as the Marshall, WV Nonattainment Area,

identifies a portion of the County with a monitor that violates the 2010 SO2 NAAQS, and 

evaluates nearby counties for contributions to SO2 concentrations in the Area. For this area, a 

portion of Marshall County, WV has a violating monitor. EPA has evaluated this County 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 2010 SO2 NAAQS as part of the Marshall, WV Nonattainment Area. The 

analysis in this TSD is primarily for the West Virginia portion of the nonattainment area. 

Detailed information explaining why Mead Township in Belmont County in Ohio was removed 

from the proposed 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 

nonattainment area, and will be addressed in a future final designations action. 

Air Quality Data

This factor considers the SO2 air quality monitoring data, including design values (in ppb) 

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

2009-2011 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 SO2 NAAQS. 

The 2010 1-hour SO2 design value for the monitor located in Marshall County is shown in Table

4.

Table 4. Marshall County Monitor Trend: 1-Hour SO2 99th % and Design Value in Parts 

per Billion (ppb)

Monitor 

Name

Monitor Air 

Quality 

System ID

99th % Design 

Value

Design 

Value

2007 2008 2009 2010 2011 2008-10 2009-11

Moundsville 54-051-1002 161 113 61 101 79 92 80
12

One-hour SO2 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 99th % 

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 concentrations 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 

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

Emissions and Emissions-Related Data

Evidence of SO2 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 emissions data for SO2 and any change in SO2 emitting 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 West Virginia.

Table 5 shows total emissions of SO2 in tons per year (tpy) for violating and potentially 

contributing counties in and around the Marshall, WV Nonattainment Area and sources emitting 

greater than 100 tpy of SO2 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 sources 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 discussion of those 

sources in the Ohio portion of the nonattainment area. 

Table 5. SO2 Emissions in the Vicinity of the Marshall, WV Nonattainment Area

County

Facility 

Located in 

State

Recommended 

Nonattainment 

Area?

Facility 

Name Total Facility SO2

Emissions 2008 NEI 

version 3 or 

CAMD2011(tpy)

WV’s draft data

CAMD 2012 SO2

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 7,630
13

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, in response 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 comment. 

Meteorology (weather/transport patterns)

Evidence of source-receptor relationships between specific emissions sources and high SO2

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 appears to only be one ASOS and one rawinsonde 

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 International Airport located 

approximately 77 kilometers to the northeast. One-minute meteorological wind fields for the 

Wheeling/Ohio County Airport site 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 Wheeling/Ohio County 

Airport, the surface site nearest the Marshall County monitor.

 

 Figure 3. Marshall County, WV- ASOS Monitoring Sites
14

The wind rose indicates that at 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 sources 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 meteorology indicates transport of SO2 coming from the south and 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 SO2. Additionally, West Virginia’s analysis of wind 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, additional emission reductions have occurred at the Burger facility

following a federally enforceable Consent Decree which makes it unlikely to contribute to 

continuing nonattainment at the Marshall County monitor. The Ormet facility is about 25 km 

away from the monitor and there is impeding terrain between Ormet and the monitor location. 

Please see the Response to Comment document and the Ohio TSD for additional information. 

Therefore, EPA is not prepared to conclude that the Ormet 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 boundaries)

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 the 
15

county. This creates sharp differences in elevation with the Ohio 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 meteorological 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 EPA’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 that 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 generally located in pathways that approach the 

monitor location, other information such as emissions and source distance from the monitor do 

not provide sufficient information to conclude that sources in these areas in Ohio should be 

considered nearby contributors to the Marshall County monitor. Additional information about 

these sources can be found in the Response to Comment document and in the Ohio TSD.

Jurisdictional boundaries 

EPA provided information about all boundaries considered prior to proposing nonattainment 

areas and this information can be found in the West Virginia TSD as part of the docket on 

proposed designations (78 FR 11124) and is not 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 Tax Districts within 

Marshall County: Washington, Franklin and Clay Tax Districts. Therefore, EPA is including 

only these three tax districts within Marshall County in the initial nonattainment area and EPA is 

not 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 SO2 NAAQS, 

based on certified 2009-2011 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, due 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 described in the factors above, no areas in Ohio are 

included in this initial nonattainment area. 
16

After considering the factors described above, EPA finds that the boundary for the initial 

Marshall, WV Nonattainment Area should consist of the portions of Marshall County that 

encompass the Clay, Franklin and Washington Tax Districts. In a subsequent round of 

designations we will make final designations decisions for areas that are not currently included in 

the nonattainment area designation addressed in this TSD. A map 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 finds that it is appropriate to designate based on 

violating monitors the portions of counties listed in Table 1 as nonattainment for the 2010 SO2

NAAQS. EPA intends to designate portions of Brooke and Marshall Counties as nonattainment 

after considering the factors and information described in this technical support document. The 

nonattainment area boundaries that EPA describes above are based on the five factors which 

include: air quality data, emissions-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 encompass 
17

sufficient initial areas that do not meet (or that contribute to ambient air quality in a nearby area 

that does not meet) the 2010 SO2 NAAQS based on the monitored violations.