# 0 I Environmental Protection Agency

John R. Kasich, Governor Mary Taylor, Lt. Governor
Scott J. Nally, Director



### FEB 2.9 

### ZOIZ

Ms. Susan Hedman Regional Administrator U.S. EPA Region 5 

### 77 W. Jackson Blvd. Chicago, IL 

### 60604

Re: PM 2

_ 5 redesignation Request for the 

### 1997 PM 2

_ 5 Annual Standard for the Parkersburg-Marietta Area

Dear Administrator Hedman:

I am writing to formally request a redesignation to attainment of the Ohio portion of the Parkersburg-Marietta area (Washington County, Ohio) with respect to the 

### 1997 PM 2

_ 5 annual standard. The enclosed submittal combines the redesignation request and the required maintenance plan for this area.

Monitoring of existing air quality indicates that the 

### 1997 National Ambient Air Quality Standard (NAAQS) for PM2.s has been attained throughout this area based on 

### 2008- 2010 air quality data. Emissions projections indicate that current controls, existing State rules, existing federal rules, and Ohio's PSD program will be more than sufficient to maintain the NAAQS indefinitely into the future. These programs will, therefore, constitute the attainment and maintenance plan for the Parkersburg-Marietta area.

The enclosed information, compiled by the Ohio Environmental Protection Agency (Ohio EPA) in cooperation with the Ohio Department of Transportation (Ohio DOT), the West Virginia Department of Environmental Protection (WVDEP), and the West Virginia Department of Transportation (WVDOT), shows significant emission reductions in point and mobile sources since ambient exceedances have occurred. A significant portion of the improved air quality can be attributed to federal programs for the mobile source sector, the regional reductions associated with the NOx Trading Program, and the Clean Air Interstate Rule (CAIR).

Ohio EPA notified the public of the draft and the opportunity to provide comments on January 

### 12, 2012. This notice was also published in a newspaper of general circulation in Marietta, Ohio on January 

### 17, 2012. The public hearing for this package was held on

50 West Town Street, Suite 700 P.O. Box 1049 Columbus, OH 43216-1049 614 I 644 3020 614 I 644 3184 (fax) www.epa.ohio.govFebruary 16, 2012 in Marietta, Ohio. No testimony was provided, nor were any comments received.

If you have questions, please contact Jennifer Dines in our Division of Air Pollution Control at (614) 644-3696.

Sincerely,

# r~ Scott J. Nally Director

Cc: Bob Hodanbosi, Chief, Division of Air Pollution Control, Ohio EPA

Enclosure

# REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE OHIO PORTION OF THE PARKERSBURG-MARIETTA, WV-OH ANNUAL PM 2.5 

# NONATTAINMENT AREA

Washington County, Ohio

Prepared by: Ohio Environmental Protection Agency Division of Air Pollution Control

February 2012This page left intentionally blanki 

### TABLE OF CONTENTS

Chapter One Introduction .................................................................................................................. ................. 1 Geographical description and background ................................................................................... 2 Status of air quality ......................................................................................................... .............. 3

Chapter Two Requirements for redesignation ................................................................................................ .... 4

Chapter Three PM 2.5 monitoring ................................................................................................................... ......... 8 Annual PM 2.5 NAAQS .................................................................................................................... 8 Ambient data quality assured ........................................................................................................ 9 Three complete years of data .................................................................................................. ..... 9 Commitment to continue monitoring ........................................................................................... 1 2

Chapter Four Emission inventory ............................................................................................................ .......... 13 Base year inventory ........................................................................................................... ......... 13 Emission projections .......................................................................................................... ......... 14 Demonstration of maintenance .................................................................................................. . 22 Permanent and enforceable emissions reductions ..................................................................... 31 Provisions for future update .................................................................................................. ...... 32

Chapter Five Control measures and regulations .............................................................................................. 33 Nonattainment areas to implement RACM and RACT ................................................................ 33 Show Reasonable Further Progress (RFP) ................................................................................ 35 Emission inventories .......................................................................................................... ......... 35 Implementation of past SIP revisions .......................................................................................... 36 New source review provisions ................................................................................................. .. 38 Assurance of continued controls ............................................................................................... .. 39

Chapter Six Contingency measures .......................................................................................................... ..... 40 Commitment to revise plan ..................................................................................................... .... 40 Commitment for contingency measures ..................................................................................... 40 Potential contingency measures ................................................................................................ . 41 List of PM 2.5 , SO 2 , and NO x sources ........................................................................................... 42

Chapter Seven Public participation .......................................................................................................... ............ 43

Chapter Eight Conclusions ................................................................................................................... ............. 44ii FIGURES

Figure 1 Map of the Parkersburg-Marietta, WV-OH, nonattainment area and monitor locations ................................................................................................................... 9 Figure 2 PM 2.5 Annual Mean Trends LADCO States ............................................................ 11 Figure 3 PM 2.5 Annual Mean Trends Midwest States ........................................................... 11 Figure 4 PM 2.5 Annual Mean National Trends ..................................................................... 12

TABLES

Table 1 Monitoring Data for Parkersburg-Marietta, WV-OH area for 2008 – 2010 ............. 10 Table 2 Washington County, Ohio Emission Estimations for On-road Mobile Sources ...... 19 Table 3 Summary of Ohio Emissions Estimations for On-road Mobile Sources ................. 20 Table 4 Wood County, West Virginia Emission Estimations for On-road Mobile Sources ................................................................................................................. 20 Table 5 Pleasants County (partial only), West Virginia Emission Estimations for On-road Mobile Sources ........................................................................................ 20 Table 6 Summary of West Virginia Emission Estimations for On-Road Mobile Sources .... 20 Table 7 Emission Estimations Totals for On-road Mobile Sources for the Parkersburg-Marietta Area ..................................................................................... 20 Table 8 Percent of Mobile Emissions for the Parkersburg-Marietta Area in 2015 and 2022 – With Apportionment Analysis fo r partial nonattainment areas ........ 21 Table 9 Reductions in SO 2 and NO x EGU Emissions Between 2008 and 2009. ................ 24 Table 10 Reductions in SO 2 and NO x EGU Emissions Between the First Half of 2008 and 2010.... ............................................................................................................ 24 Table 11 Washington County, Ohio PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. .................. 26 Table 12 Wood County, West Virginia PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CSAPR. ......... 26 Table 13 Pleasants County, West Virginia PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CSAPR .......... 27 Table 14 Parkersburg-Marietta Area PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR (Ohio) and With CSAPR (West Virginia). ................................................................................. 27 Table 15 Washington County, Ohio NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ........................ 27 Table 16 Wood County, West Virginia NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CSAPR .................... 28 Table 17 Pleasants County, West Virginia NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CSAPR .......... 28 Table 18 Parkersburg-Marietta Area NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR (Ohio) and With CSAPR (West Virginia). ................................................................................. 28 Table 19 Washington County, Ohio SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ........................ 29 Table 20 Wood County, West Virginia SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CSAPR .................... 29 Table 21 Pleasants County, West Virginia SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CSAPR .......... 29iii Table 22 Parkersburg-Marietta Area SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR (Ohio) and With CSAPR (West Virginia) .................................................................................. 30 Table 23 Parkersburg-Marietta Area Comparison of 2008 Attainment Year and 2015 and 2022 Projected Emission Estimates (tpy) ............................................................... 30 Table 24 Parkersburg-Marietta Area Combined Comparison of 2005 Base Year and 2008 Attainment Year On-Road and EGU Reductions ................................................... 31

APPENDICES

A Air Quality System (AQS) Data B Ohio 2005 SIP Base Year Inventory Discussion C Mobile Source Emissions Inventory for t he Parkersburg-Marietta PM2.5 Nonattainment Area D LADCO Technical Support Documents E Analysis of Insignificance of Mobile Emissions F Public Participation Documentationiv This page left intentionally blankREDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE OHIO PORTION OF THE PARKERSBURG-MARIETTA ANNUAL PM 2.5 NONATTAINMENT AREA

Washington County, Ohio



### CHAPTER ONE

Introduction The Clean Air Act (CAA), as amended, requi res each State with areas failing to meet the annual PM 2.5 1 National Ambient Air Qua lity Standard (NAAQS) to develop State Implementation Plans (SIPs) to expeditiously attain and maintain the standard. The United St ates Environmental Protection Agency (U.S. EPA) revised the NAAQS for particulate matte r in July 1997. It replaced the existing PM 10 standard with a health-based PM 2.5 standard and retained the PM 10 standard as a particulate standard protecting welfare. The stan dards include an annual standard set at 15.0 microgr ams per cubic meter (μg/m 3 ), based on the 3-year average of annual mean PM 2.5 concentrations and a 24-hour standard of 65 μg/m 3 , based on the 3-year average of the 98 th percentile of 24-hour concentrations.

The revised NAAQS was legally challenged in the U.S. Court of Appeals for the District of Columbia Circuit (the D.C. Circuit). On May 14, 1999, the D.C. Circuit remanded, without vacatur, the standard ba ck to U.S. EPA. The remand did not question the level at wh ich U.S. EPA set the st andards but rather the constitutionality of the CAA provision that authorizes U.S. EPA to set national air quality standards. U.S. EPA requested a rehearing wh ich the D.C. Circuit denied. Therefore, in December 1999, U.S. EPA appealed the D.C. Circuit decision to the U.S. Supreme Court. T he U.S. Supreme Court issued a decision on February 27, 2001 that unanimously affi rmed the constitutionality of the CAA provision but did remand several other iss ues back to the D.C. Circuit, including the issue of whether U.S. EPA acted arbitrarily and capr iciously in establishing the specific levels of the standards.

The D.C. Circuit heard arguments in this remanded case in December 2001, and issued its decision on March 26, 2002. The D. C. Circuit rejected the claims that the U.S. EPA had acted arbitr arily and capriciously in setting the levels of the standards.

1 Particle pollution is a mixture of microscopic solids and liquid droplets suspended in air. This pollution, also known as particulate matter, is made up of a number of components, including acid s (such as nitrates and sulfates), organic chemicals, metals , soil or dust particles, and allergens (such as fragments of pollen or mold spores). Fine particle pollution or PM 2.5 describes particulate matter that is 2.5 micrometers in diameter and smaller - 1/30th the diam eter of a human hair. Fine particle pollu tion can be emitted directly or formed secondarily in the atmosphere.2 On December 17, 2004, U.S. EPA promulgated the initial PM 2.5 nonattainment areas designations for the PM 2.5 standards across the country. Modifications to those designations were made and an effect ive date was set at April 5, 2005. Unlike Subpart 2 of the CAA Amendment s of 1990 which defined five ozone nonattainment classifications for the ar eas that exceed the NAAQS based on the severity of the ozone levels, PM 2.5 nonattainment designations are simply labeled “nonattainment.” The CAA Amendments require states with PM 2.5 nonattainment areas to submit a plan within three years of the effective date of the designations (April 5, 2008) detailing how the PM 2.5 standards will be attained by April 5, 2010. Ohio EPA subm itted its attainment demonstration for the entire State of Ohio on July 16, 2008.

Section 107(d)(3)(E) of the CAA allows st ates to request nonattainment areas to be redesignated to attainment provided cert ain criteria are met. The following are the criteria that must be met in or der for an area to be redesignated from nonattainment to attainment:

• A determination that the area has attained the PM 2.5 standard.

• An approved State Implementation Plan (SIP) for the area under Section 110(k).

• A determination that the improv ement in air quality is due to permanent and enforceable reductions in emissions resulting from implementation of the SI P and other federal requirements.

• A fully approved maintenance plan under Section 175(A).

• A determination that all Sect ion 110 and Part D requirements have been met.

This document addresses each of these requirements, and provides additional information to support continued compliance with the annual PM 2.5 standard.

Geographical Description and Background The current Parkersburg-Marietta nonattain ment area is located in south-eastern Ohio and includes the following countie s: Washington in Ohio; and Pleasants (partial nonattainment of Grant Tax distri ct) and Wood in West Virginia. This area is shown in Figure 1 under Chapter Three.

The Parkersburg-Marietta area has not previously been subject to nonattainment area rulemakings for fine particles.

As a result of the 2005 PM 2.5 designations, U.S. EPA designated the Parkersburg-Marietta area nona ttainment for the 15.0 μg/m 3 annual standard 2

, and Ohio EPA was required to develop a pl an to reduce oxides of nitrogen (NO x ), sulfur dioxide (SO 2 ) and direct PM 2.5 emissions and to demonstrate that

2 There were no monitors in Ohio that violated the 1997 24-hour PM 2.5 standard of 65μg/m 3

.3 the area will meet the federal annual air quality standard by April 5, 2010. Ohio’s main PM 2.5 components are primary particles (o rganic carbon, crustal material, and elemental carbon), SO 2 and NO x , which were included in the attainment demonstration analysis. Volatile or ganic compounds (VOCs) and ammonia (NH3) were not included in the analysis si nce they were not part of Ohio’s current attainment strategy for PM 2.5 (although controls for VOCs have been implemented for ozone nonattainment). This is consistent with U.S. EPA’s “Clean Air Particle Implementation Rule” [ 74FR 20856] (hereafter referred to as “Implementation Rule”). In the Implem entation Rule U.S. EPA presumes NH3 emissions are not a PM 2.5 attainment plan precurso r and that States are not required to address VOC unless the St ate or U.S. EPA makes a technical demonstration that emissions of VOCs si gnificantly contribute to nonattainment of the annual PM 2.5 standard.

This document is intended to support Ohio’s request that the Ohio portions of the Parkersburg-Marietta area be redesignated from nonattainment to attainment for the annual PM 2.5 standard. In addition, the State of West Virginia may also submit a request for their respective porti ons of the Parkersburg-Marietta area.

Status of Air Quality PM 2.5 complete quality-assured ambient ai r quality monitoring data for the most recent three (3) years, 2008 through 2010, demonstrate that the air quality has met the NAAQS for annual PM 2.5 in this nonattainment area. The NAAQS attainment, accompanied by decreases in emission levels discussed in Chapter Four, supports a redesignation to attainm ent for the Parkersburg-Marietta area based on the requirements in Section 107( d)(3)(E) of the CAA as amended.4 

### CHAPTER TWO

Requirements for Redesignation U.S. EPA has published detailed gui dance in a document entitled Procedures for Processing Requests to Redesignate Areas to Attainment (redesignation guidance), issued September 4, 1992, to Regional Air Directors. The redesignation request and maintenance pl an are based on the redesignation guidance, supplemented with additional guidanc e received from staff of U.S. EPA Region 5.

Below is a summary of each redesignat ion criterion as it applies to the Parkersburg-Marietta area.

i.) Attainment of the standard (CAA Section 107(d)(3)(E)(i)) There are two components involved in making this demonstration. The first component relies on ambi ent air quality dat a. The data that are used to demonstrate atta inment should be the product of ambient monitoring that is repr esentative of t he area of highest concentration. The data should be collected and quality-assured in accordance with 40 CFR 58 and re corded in the Air Quality System (AQS) in order for it to be avail able to the public for review.

The second component relie s upon supplemental U.S. EPAapproved air quality modeling. While no modeling is required for redesignating nonattainment areas , the redesignation guidance states it is “generally necessary” for particulate matter redesignations. Appendix C and A ppendix D contains the most recent modeling results sho wing future attainment and maintenance are provided. C hapter Three discusses this requirement in more detail and provides the attainment demonstration.

ii.) Permanent and enforceable improvem ent in air quality (CAA Section 107(d)(3)(E)(iii)) The state must be able to reasonabl y attribute the improvement in air quality to emission reductions which are permanent and enforceable. The state should es timate the percent reduction achieved from federal m easures as well as control measures that have been adopted and implement ed by the state.

It was not necessary for Ohio to adopt or implement control measures for these counties beyond the federal measures.

Ohio EPA has adopted several rule s recently that will have an impact on statewide PM 2.5 emissions in the future:5 • Clean Air Interstate Rule (CAIR)

• NO x SIP Call Rules

Ohio was also subject to a Feder al Implementation Plan under the CAIR replacement rule, the Cr oss-State Air Pollution Rule (CSAPR) that could have resulted in even greater reductions than the CAIR program. However, on December 30, 2011, the D.C. Circuit Court stayed CSAPR and ordered U.S. EPA to continue administering CAIR pending the court’s resolution.

In addition, since the initial des ignations were made federally enforceable consent decrees hav e resulted in reductions in emissions from utilities within Washington County and across the state, including this area.

Chapters Four and Five discuss this requirement in more detail.

iii.) Section 110 and Part D requirements (CAA Section 107(d)(3)(E)(v)) For purposes of redesignation, a state must meet all requirements of Section 110 and Part D that were applicable prior to submittal of the complete redesignation request.

Subpart 1 of Part D consists of general requirements applicable to all areas which are designated nonat tainment based on a violation of the NAAQS. Subpart 4 of Part D consists of more specific requirements applicable to particulate matter (specifically to address PM 10 ). However, for the pur pose of implementing the 1997 PM 2.5 standard, U.S. EPA’s Impl ementation Rule stated Subpart 1, rather than Subpart 4, is appropriate for the purpose of implementing PM 2.5 .[72 FR 20589]

Section 110(a) requirements Section 110(a) of Title I of the CAA contains the general requirements for a SIP. Secti on 110(a)(2) provides that the implementation plan submitted by a state must have been adopted by the state after reasonable public notice and hearing, and that, among other things, it must include enforceable emission limitat ions and other control measures, means or techniques necessary to meet the requirements of the CAA; pr ovide for establishment and operation of appropriate devic es, methods, systems and procedures necessary to m onitor ambient air quality; provide for implementation of a source permit program to regulate the modification and cons truction of any stationary source within the areas cove red by the plan; include provisions for the implementati on of Part C, prevention of6 significant deterioration (PSD) and Part D, NSR permit programs; include criteria fo r stationary source emission control measures, monitori ng, and reporting; include provisions for air quality m odeling; and provide for public and local agency participation in planning and emission control rule development. In Ohio’s December 5, 2007 and September 4, 2009 infrastructure SIP submissions, Ohio verified that the State fulfills the requirements of Section 110(a)(2) of the Act.

Section 110(a)(2)(D) also requi res State plans to prohibit emissions from within t he State which contribute significantly to nonattainment or maintenance areas in any other State, or which interf ere with programs under Part C to prevent significant deterio ration of air quality or to achieve reasonable progress towa rd the national visibility goal for Federal class I areas (national parks and wilderness areas). In order to assist States in addressing their obligations regarding r egionally transported pollution, U.S. EPA finalized CAIR to reduce SO 2 and NO x emissions from large electric generating units (EGU). Ohio has met the requirements of the f ederal CAIR to reduce NO x and SO 2 emissions contributing to downwind states. On February 1, 2008, U.S. EPA approved Ohio’s CAIR program, which can be found in Ohio Administrative Code (OAC) Chapter 3745-109 3 . On July 6, 2011, U.S. EPA finalized a replacement to t he CAIR program, the CSAPR. CSAPR could further assist States in addressing their obligations regarding regiona lly transported pollution by providing reductions in NO x and SO 2 emissions in 2012 and 2014. However, on December 30, 2011, the D.C. Circuit Court stayed CSAPR and order ed U.S. EPA to continue administering CAIR pending the court’s resolution.

iv.) Section 172(c) requirements This Section contains general r equirements for nonattainment plans. The requirements for reasonable furt her progress, identification of certain emissions increases , and other measures needed for attainment will not apply for redesi gnations because they only have meaning for areas not attaining t he standard. The requirements for an emission inventory will be satisfi ed by the inventory requirements of the maintenance plan. Chapt ers Four and Five discuss this requirement in more detail.

3 http://www. epa.ohio.gov/dapc/regs /regs.aspx#3745-1097 v.) Conformity The state must work with U.S. EPA to show t hat its SIP provisions are consistent with the Section 176( c)(4) conformity requirements. The redesignation request should in clude conformity procedures, if the state already has t hese procedures in place. If a state does not have conformity procedures in place at the time that it submits a redesignation request, the state mu st commit to follow U.S. EPA’s conformity regulation upon issuance, as applicable.

vi.) Maintenance plans (CAA Section 107(d)(3)(E)(iv)) Section 107(d)(3)(E) stipulates t hat for an area to be redesignated, U.S. EPA must fully approve a ma intenance plan that meets the requirements of Section 175( A). The maintenance plan will constitute a SIP revision and must provide for maintenance of the relevant NAAQS in the area for at least 10 years after redesignation. Section 175 (A) further states t hat the plan shall contain such additional measures, if any, as may be necessary to ensure such maintenance.

In addition, the maintenance plan shall contain such contingency measures as the Administrator deems necessary to ensure prompt correction of any violation of t he NAAQS. At a minimum, the contingency measures must include a requirement that the state will implement all measures contained in the nonattainment SIP prior to redesignation.

States seeking redesignation of a nonattainment area should consider the following provisions:

a.) attainment inventory; b.) maintenance demonstration; c.) monitoring network; d.) verification of continued attainment; and e.) contingency plan.

Chapter Six discusses this requirement in more detail.8 

### CHAPTER THREE

PM 2.5 MONITORING CAA Section 107(d)(3)(E)(i)

Requirement 1 of 4 A demonstration that the NAAQS for annual PM 2.5 , as published in 40 CFR 50.7, has been attained.

Background There is one monitor measuring PM 2.5 concentrations in this nonattainment area located in Wood County, West Virginia. This monitor is operated by the WVDAQ (West Virginia Division of Air Quality). A listing of the design values based on the three-year average of the annual mean conc entrations from 2008 through 2010 is shown in Table 1. The location of the monitoring site for this nonattainment area is shown on Figure 1.9 Demonstration

Figure 1 - Map of the Parkersburg-Marietta, WV-OH nonattainment area and monitor locations

Requirement 2 of 4 Ambient monitoring data quality assur ed in accordance with 40 CFR 58.10, recorded in the U.S. EPA air quality syst em (AQS) database, and available for public view.

Demonstration West Virginia has quality assured all data shown in Appendix A in accordance with 40 CFR 58.10 and all other federal requirements. West Virginia has recorded the data in the AQS database and, therefore, the data are available to the public.

Requirement 3 of 4 A showing that the three-year aver age of the annual mean values, based on data from the monitoring si te in the area or its affected downwind environs, are below 15.0 μg/m 3 . (This showing must rely on three complete, consecutive calendar years of quality assured data.)10 Background The following information is taken from U.S. EPA's "Guidelineon Data Handling Conventions for the PM NAAQS," U.S. EPA454/R-99-008, April 1999.

In accordance with the CAA Amendm ents, three comp lete years of monitoring data are required to demonstrate attainment at a monitoring site. The annual PM 2.5 primary and secondary ambient air quality standards are met at an ambient air quality monitoring site when the three-year aver age of the annual average is less than 15.0 μg/m 3 . While calculating design values, three significant digits must be carried in the co mputations, with final values rounded to the nearest 0.1 μg/m 3 . Decimals 0.05 or greater are rounded up, and those less than 0. 05 are rounded down, so that 15.049 μg/m 3 is the largest concentration that is less than, or equal to 15.0 μg/m 3 . Values at or below 15.0 μg/m 3 meet the standard; values equal to or greater than 15.1 μg/m 3 exceed the standard. An area is in comp liance with the annual PM 2.5 NAAQS only if every monitoring site in the area meets the NAAQS. An individual site's 3-year average of the annual average concentrations is also called the site's design value. T he air quality design value for the area is the highest design value among all sites in the area.

Table 1 shows the monitoring data for 2008 – 2010 that were retrieved from the U.S. EPA AQS.

Demonstration

Table 1 - Monitoring Data for the Parkersburg-Marietta, WV-OH area for 2008 – 2010

Source: U.S. EPA Air Quality System (AQS); http:// www. epa.gov/ttn/airs/airsaqs/index.htm

The design value calculated for the Parkersburg-Marietta area demonstrates that the annual PM 2.5 NAAQS has been attained. The area's design value has trended downw ard as emissions have declined due to such factors as cleaner autom obiles and fuels, and controls for EGUs, at the national, regional and local level.

National monitoring for PM 2.5 began in 1999. With respect to each of the Average

2008 2009 2010 2008-2010

54-029-1002 Wood, WV 13.8 12.0 13.4 13.1 Less than 75% capture in at least one quarte r Annual Standard

Site County Yea r11 Lake Michigan Air Directors Consortium (LADCO) states, there has been a clear downward trend in design values:

Figure 2 - PM 2.5 Annual Mean Trends LADCO States

Source: LADCO; Recent Ozone and PM2.5 Trends – Aug 26 2010.pptx

The same trend can be seen within the Midwest States as a whole:

Figure 3 - PM 2.5 Annual Mean Trends Midwest States

Source: LADCO; Recent Ozone and PM2.5 Trends - Aug 26 2010.pptx

Design values have also trended downward nationally:12 Figure 4 - PM 2.5 Annual Mean National Trends

Source: http://www. epa.gov/airtrends/pm.html

Requirement 4 of 4 A commitment that once redesignated, the state will cont inue to operate an appropriate monitoring network to verify the maintenance of the attainment status.

Demonstration Ohio EPA does not curr ently operate any monitors in this area. Ohio EPA will consult with U.S. EPA Region 5 prior to making changes to the existing monitoring network, should changes become necessary in the future.13 

### CHAPTER FOUR

EMISSION INVENTORY CAA Section 107(d)(3)(E)(iii)

U.S. EPA’s redesignation guidance require s the submittal of a comprehensive inventory of PM 2.5 precursor emissions (primary par ticles (organic carbon, crustal matter, and elemental carbon), SO 2 and NO x 4 ) representative of the year when the area achieves attainment of the annual PM 2.5 air quality standard. Ohio also must demonstrate that the improvement in air qualit y between the year that violations occurred and the year that attainment was achieved is based on permanent and enforceable em ission reductions. Other emission inventory related requirements include a projection of the emission invent ory to a year at least 10 years following redesignation; a demonstration that t he projected level of emissions is sufficient to maintain the annual PM 2.5 standard; and a commitment to provide future updates of the inventory to enable tracking of emission levels during the 10-year maintenance period.

The emissions inventory development and emissions projection discussion below, with the exception of the mob ile (on-road) emi ssions inventory and projections, identifies procedures us ed by Ohio EPA and the LADCO regarding emissions from Ohio’s por tion of the Parkersburg-Marietta area. Specific emissions data are provided for all countie s, including those in Ohio and West Virginia. West Virginia emissions dat a were obtained though the West Virginia Department of Environmental Protection (WVDEP). All of these inv entories and emissions projections were prepared using similar methodologies, unless otherwise noted. Mobile emi ssions inventories and projections for all counties were prepared by the W ood-Washington-Wirt Interstate Planning Commission (WWW) and the Ohio Department of Trans portation (ODOT), with data provided by Ohio EPA, West Virginia Departm ent of Transportation (WVDOT), and WVDEP.

Requirement 1 of 5 A comprehensive emission inventory of PM 2.5 , SO 2 and NO x completed for the base year.

Background The 2005 periodic inventory has been identified as one of the preferred databases for SIP development and coincides with nonattainment air quality in the Parkersburg-Marietta area.

Periodic inventories, which include emissions from a ll sectors are prepared every three years by Oh io EPA. Ohio’s 2005 emissions

4 VOC and NH 3 are not addressed.14 data for all sources (Electrical G enerating Unit (EGU-Point); NonElectrical Generating Unit (N on-EGU); Non-road Mobile (Nonroad); Other Area (Area); and Ma rine; Aircraft; Rail (MAR)) are derived from this inventory. Ohio ’s point source data derived from this periodic inventory is actual source reported emissions under Ohio's annual emissions reporting program.

West Virginia’s point source data are taken from U.S. EPA’s CSAPR estimates (EGU) and act ual reported data under West Virginia’s emissions reporti ng program (non-EGUs). West Virginia’s emissions data for MAR and Area is derived from the 2005 National Emissions Inventory (NEI) while Non-road emissions are derived from NO NROAD modeling conducted by WVDAQ.

Demonstration Ohio’s 2005 inventory is used as the base year for the purpose of this submittal and was submitt ed to U.S. EPA with Ohio’s PM 2.5 attainment demonstration SIP submitted on July 18, 2008 and revised on June 7, 2010. The det ailed emission inventory information for Ohio’s portion of the Parkersburg-Marietta area is provided in Appendix B. Emissions of PM 2.5, SO 2 and NO x for 2005 are identified under Requirem ent Three of this Chapter.

Requirement 2 of 5 A projection of the emission inventory to a year at least 10 years following redesignation.

Background Ohio EPA prepared a comprehensive invent ory for the Ohio portion of the Parkersburg-Marietta area including area, mobile, and point sources for PM 2.5 , SO 2 and NO x for base year 2005. The 2005 inventory was submitted to U.S. EPA on July 18, 2008 as part of Ohio’s PM 2.5 attainment demonstration SIP for this area. The information below describes the procedures Ohio EPA us ed to generate the 2005 base year inventory and to develop SIP-ready m odeling inventories and future year projections (Pechan Report 5 ) based on a 2005 base year inventory. The report by Pechan generated future year estimates of annual emissions for each source sector using accepted gr owth surrogates. These inventories were provided to the LADCO and have been processed to develop average daily emissions for use in the air quality analyses. These

5 http://www.ladco.org/tech/emis/r5/r eports/LADCO%202005%20Base%20Yr%20Growth%20and%20Con trols%20Report_Final.pdf15 processed modeling inventories hav e been identified as the correct iteration of the inventory for use in the redesignation. In this document, references to LADCO include the Midwest Regional Planning Organization. Note, that the on-road m obile source sector was addressed by specific modeling as discussed below.

• Area source and MAR emissions were taken from the Ohio 2005 periodic inventory submi tted to U.S. EPA. These projections were made from the U.S. Department of Commerce Bureau of Economic Analysis (BEA) growth factors, with some updated local information.

• Mobile source emissions were calculated from MOVES2010 produced emission factor s. In Ohio’s July 6, 2008 PM 2.5 Attainment Demonstration SIP 6 , Ohio found that the regional highway emissions of PM 2.5 , NO x , and SO 2 were insignificant contri butors to the nonattainment problems and, therefore, none of the three pollutants necessitated emissions inventory analysis. As documented in Ohio EPA’s attainment dem onstration SIP, Ohio EPA in consultation with U.S. EPA determined that the Parkersburg-Marietta nonattainment area is not significantly impacted by on-road mobile emissions as compared to other source emissions; in addition, mobile source emissions in the area were expected to decrease. Based on the results of mobile s ource emission projections prepared as a part of this redesignation and maintenance plan, Ohio EPA is again making a finding that the regional highway emissions of PM 2.5 , NO x , and SO 2 continue to be insignificant contributor to the nonattainment problems in this area, as discussed below.

• Point source information wa s compiled from Ohio EPA’s 2005 annual emissions invent ory database and the 2005 U.S. EPA Air Markets acid rain database 7

.

• Biogenic emissions are not included in these summaries.

• Non-road emissions were generated using U.S. EPA’s National Mobile Inventory M odel (NMIM) 2002 application. To address concerns about the accuracy of some of the categories in U.S. EPA’s non-road emissions model, LADCO contracted with two (2) companies to review the base data and make recomm endations. One of the contractors also estimated emi ssions for three (3) non-road categories not included in U.S. EPA’s non-road model. Emissions were estimated fo r aircraft, commercial marine

6 http://www. epa.ohio.gov/portals /27/SIP/Attain/P M2_5/PM25Doc.pdf 7 http://www. epa.gov/airmarkets/acidrain16 vessels, and railroads. Recreat ional motorboat population and spatial surrogates (used to assign emissions to each county) were significantly updated. The populations for the construction equipment cat egory were reviewed and updated based upon surveys completed in the Midwest, and the temporal allocation fo r agricultural sources also was updated.

West Virginia emission projecti ons were provided by the WVDAQ as summarized below:

• Area source and MAR emissions were compiled from the 2008 NEI and 2015 and 2022 projecti ons were grown using Workforce data.

• Mobile source emissions were calculated using the same methodology as described above for Ohio’s portion.

• EGU point source informati on was compiled from U.S. EPA’s CSAPR inventories.

• Non-EGU point source informa tion was compiled from West Virginia’s 2008 actual emissions inventory and 2015 and 2022 projections were grown using Workforce data.

• Non-road emissions were generated are derived from NONROAD modeling conducted by WVDAQ.

Demonstration

On-Road Emission Estimations The ODOT, Division of Transpor tation System DevelopmentModeling and Forecasting Secti on and the Wood-Washington-Wirt Interstate Planning Commission (WWW), defined the underlying planning assumptions for the annual PM 2.5 on-road mobile source emission inventories for the Parkersburg-Marietta, OH-WV nonattainment area. The WWW Region is comprised of Washington County, Ohio, Wood C ounty, West Virginia, and the Grant Tax district of Pleasant count y, West Virginia. The Grant Tax district in Pleasant County, West Virginia (shown above and adjacent to Wood County) is considered a “doughnut area” for planning purposes. For the most part, roadways within this district are not included in the travel demand model network. The WVDOT provided WWW with the VMT on the roads in this district by federal functional class fo r the year 2004. Based upon the advice of the WVDAQ, the modeling area’s growth factor was used to calculate future year VMT withi n this Tax district by functional class.17 In coordination with the OD OT and WVDOT, WWW utilizes a regional travel demand forecast model to simulate traffic in the area and to forecast traffic flows for given growth expectations. The model is primarily used as a long range planning tool to evaluate the transportation system including determination of locations where additional trav el capacity may be needed and to determine the infrastructure require ments necessary to meet that need. It is also used as a tool fo r air quality purposes to estimate the total emissions of pollution c aused by vehicles in the area. The travel demand forecasting model is used to predict traffic volumes vehicle miles traveled (V MT), travel speeds, and a U.S. EPA computer program called MOVES is used to calculate emissions per mile. The product of these is the total amount of pollution emitted by the on-road vehicles for the area.

Overview U.S.EPA published a Federal Register notice 8 of availability on March 2, 2010, to approve MOVES2010 (Motor Vehicle Emissions Simulator), hereafter referred to as MOVES. Upon publication of the Federal Register notic e, MOVES became U.S. EPA’s approved motor vehicle emission factor model for estimating VOCs, NO x , CO, PM 10 and PM 2.5 and other pollutants and precursors from cars, trucks, mo torcycles, and buses by state and local agencies. MOVES is a com puter program designed by the U.S. EPA to estimate air pollution emissions from mobile sources. MOVES replaces U.S. EPA’s prev ious emissions model for onroad mobile sources, MOBI LE6.2. MOVES can be used to estimate exhaust and evaporative em issions as well as brake and tire wear emissions from all types of on-road vehicles.

The CAA requires U.S. EPA to regul arly update its mobile source emission models. U.S. EPA c ontinuously collects data and measures vehicle emissions to ma ke sure the Agency has the best possible understanding of mobile source emissions. This assessment, in turn, informs the development of U.S. EPA’s mobile source emission models. MOVES represents the Agency’s most up-to-date assessment of on -road mobile source emissions. MOVES also incorporates seve ral changes to the U.S. EPA’s approach to mobile source emission modeling based upon recommendations made to the A gency by the National Academy of Sciences.

U.S.EPA believes that MOVES shoul d be used in ozone, CO, PM, and nitrogen dioxide SIP developm ent as expeditiously as

8 http://www.r egulations.gov/search/Regs/hom e.html#document Detail?R=0900006480ab1f9818 possible. The CAA requires that SIP inventories and control measures be based on the most current information and applicable models that are available when a SIP is developed. Regarding transportation conformity, U.S. EPA and U.S. DOT intend to establish a two-year grace per iod before MOVES is required for new transportation conformity analyses.

The MOVES more detailed appr oach (when compared with the previous MOBILE model) to mode ling allows U.S. EPA to easily incorporate large amounts of in-u se data from a wide variety of sources, such as data from v ehicle inspection and maintenance (I/M) programs, remote sensing dev ice (RSD) testing, certification testing, portable emission meas urement systems (PEMS), etc. This approach also allows users to incorporate a variety of activity data to better estimate emissi on differences such as those resulting from changes to vehicl e speed and acceleration patterns. MOVES has a graphical user interfac e which allows users to more easily set up and run the m odel. MOVES database-centered design provides users much gr eater flexibility regarding output choices. Unlike earlier models whic h provided emission factors in grams-per-mile in fixed output formats, MOVES output can be expressed as total mass (in tons, pounds, kilograms, or grams) or as emission factors (grams-per-m ile and in some cases grams-pervehicle). Output can be easily aggregated or disaggregated to examine emissions in a range of scales, from national emissions impacts down to the emissions impac ts of individual transportation projects. The database-centered des ign also allows U.S. EPA to update emissions data incorporat ed in MOVES more easily and will allow users to incorporate a much wider array of activity data to improve estimation of local emissions. For example, the improvements in MOVES will allow pr oject-level PM2.5 emissions to be estimated.

The annual on-road inventory runs meet the latest planning assumption requirement, utilizing the latest population and land use data available. WWW’s utiliz ed U.S.EPA’s emissions model MOVES to develop emissions factors for SO 2 , NO x and PM 2.5

. Further details on the use of MOVES are found on Appendix C. Travel analysis zones (376 in t he 2-county area) and external roadway “stations” (34) are the basic geographic units for estimating travel patterns. Soci oeconomic data used to forecast these patterns include household population, household vehicles, and employment by category and loca tion. Sources for year 2000 data include the 2000 Census and QCEW/ES202 employment data adjusted to Year 2005 county-level control totals. All data sources were geocoded to the zone level. Future year data for each19 variable were projected through va rious methods. The forecasted distribution of land use by indus try and traffic zone was developed in 2003 by WWW staff working in conjunction with West Virginia University’s Regional Research In stitute and a consulting firm, as documented in their 2002 Transportation Plan update

A travel demand model (TDM) is the traditional tool used to examine potential changes in future travel patterns. The road networks within them include all planned federal-aid projects as well as any regionally signifi cant projects found in the Transportation Improvement Program (TIP) and Long Range Transportation Plan (LRTP) expect ed to be open for traffic by the end of each respective analysis year. All projects identified in the LRTP having an impact on travel time and/or vehicle carrying capacity regardless of funding sour ce were included in the air quality analysis.

The WWW region area TDM network covers about 1000 miles of streets and highways in the 2-c ounty area including all collector and arterial streets, and has been va lidated to observed traffic for year 2005. The hourly distribution of trips by trip purpose and direction are constrained to match the hourly distribution of traffic counts. Trip distribution also begins with a trip-length distribution by purpose borrowed from another urban area and adjusted to ensure modeled VMT matched HPMS estimates of VMT within 1% in the model base year of 2005. (Home-based work trips were separately constrained to a ta rget average value based on the 2000 Census.)

On-Road Mobile Emission Estimations Tables 2 through 7 contain the result s of the emissions analysis for the appropriate years. All emissions esti mations are expressed in tons per year (tpy).

Table 2 - Washington County, Ohio Emissions Estimations for OnRoad Mobile Sources

2005 2008 2015 2022

PM 2.5 (tpy) 90.45 75.52 41.68 25.22
NO x (tpy) 2,687.09 2,247.41 1,200.52 572.25
SO 2 (tpy) 26.97 8.54 6.46 6.31
Annual VMT 787,956,160 804,042,805 880,728,940 947,254,20520 Table 3 – Summary of Ohio Emissions Estimations for On-Road Mobile Sources

2005 2008 2015 2022

PM 2.5 (tpy) 90.45 75.52 41.68 25.22
NO x (tpy) 2,687.09 2,247.41 1,200.52 572.25
SO 2 (tpy) 26.97 8.54 6.46 6.31
Annual VMT 787,956,160 804,042,805 880,728,940 947,254,205

Table 4 – Wood County, West Virginia Emissions Estimations for On-Road Mobile Sources

2005 2008 2015 2022

PM 2.5 (tpy) 81.43 66.32 33.62 24.16
NO x (tpy) 2,459.26 2,122.62 992.62 538.59
SO 2 (tpy) 31.13 10.37 7.88 7.70
Annual VMT 878,434,550 987,566,995 1,089,633,405 1,175,437,970

Table 5 – Pleasants County (partial only), West Virginia Emissions Estimations for On-Road Mobile Sources

2005 2008 2015 2022

PM 2.5 (tpy) 1.61 1.20 0.55 0.37
NO x (tpy) 54.17 42.41 19.05 9.96
SO 2 (tpy) 0.69 0.22 0.18 0.15
Annual VMT 22,094,910 22,362,455 22,984,415 23,568,050

Table 6 – Summary of West Virginia Emissions Estimations for On-Road Mobile Sources

2005 2008 2015 2022

PM 2.5 (tpy) 83.04 67.52 34.17 24.53
NO x (tpy) 2,513.43 2,165.03 1,011.67 548.55
SO 2 (tpy) 31.82 10.59 8.06 7.85
Annual VMT 900,529,460 1,009,929,450 1,112,617,820 1,199,006,020

Table 7 – Emissions Estimations Totals for On-Road Mobile Sources for the Parkersburg-Marietta Area

2005 2008 2015 2022

PM 2.5 (tpy) 173.49 143.04 75.85 49.75
NO x (tpy) 5,200.52 4,412.44 2,212.19 1,120.80
SO 2 (tpy) 58.79 19.13 14.52 14.16
Annual VMT 1,688,485,620 1,813,972,255 1,993,346,760 2,146,260,22521 The following table identif ies the percentage of mobile emissions of all emissions, as identified under Appendix E, for each pollutant in the entire Parkersburg-Marietta area and Ohio’s portion of this area for 2015 and 2022.

Table 8 – Percent of Mobile Emissi ons for the Parkersburg-Marietta Area in 2015 and 2022 – With Apportionment Analysis for Partial Nonattainment Areas

NO x SO 2 PM 2.5

2015 2022 2015 2022 2015 2022

ParkersburgMarietta Area Total (tpy) 18,491.26 12,968.52 77,293.31 48,438.63 3,536.75 3,446.56 Mobile (tpy) 2,212.19 1,120.80 14.52 14.16 75.85 49.75

% Mobile 11.96% 8.64% 0.02% 0.03% 2.14% 1.44%

Ohio Portion Total (tpy) 11,439.41 6,417.53 67,625.84 37,351.17 1,198.61 1,181.01 Mobile (tpy) 1,200.52 572.25 6.46 6.31 41.68 25.22

% Mobile 10.49% 8.92% 0.01% 0.02% 3.48% 2.14%

SO 2 constitutes less than one per cent (<1%) of the area’s total SO 2 emissions in the 2015 and 2022 horizon years.

PM 2.5 constitutes just over two per cent (2.14%) of the area’s total PM 2.5 emissions in the 2015 horizon year and less than two percent (1.44%) of the area’s total PM 2.5 emissions in the 2022 horizon year.

NO x emissions are just under tw elve percent (11.96%) of the area’s total NO x emissions in the 2015 horizon year and less than nine percent (8.64%) in the 2022 horizon year.

Therefore, the Ohio EPA is herein making a finding that the area’s highway emissions for PM 2.5 , NO x , and SO 2 continue to be insignificant contributors to the nonattainment probl em of the Parkersburg-Marietta area, as agreed upon as a part of the interagency consultation process. Because of this finding it is not nece ssary to establish mobile emission budgets for this area in the 2015 and 2022 horizon years. The nonattainment area meets the 40 CFR 93.109(m) criteria for PM 2.5 , NO x , and SO 2 . Throughout this document Ohio EPA demonstrates that it would be unreasonable to expect that the Pa rkersburg-Marietta area would experience enough motor vehicle emissions growth in PM 2.5 , NO x , and SO 2 for a PM 2.5 NAAQS violation to occur. Moreover, Ohio EPA demonstrates that the percentage of motor vehicle emissions in the context of the total SIP inventory, the current st ate of air quality as determined by monitoring data, the abs ence of SIP motor vehicle control measures, and historical trends and futu re projections of the growth of22 motor vehicle emissions, are evidenc e enough to consider mobile source PM 2.5 , NO x , and SO 2 insignificant contributors to fine particles.

Requirement 3 of 5 A demonstration that the projec ted level of emissions is sufficient to maintain the PM 2.5 standard.

Background In consultation with U.S. EPA, Ohio EPA selected the year 2022 as the maintenance year for th is redesignation request. This document contains projected em issions inventories for 2015 and 2022.

Emission projections for the Pa rkersburg-Marietta area were performed using the following approaches:

• As performed by ODOT and WWW (for the entire nonattainment area), mobile s ource emission projections are based on the U.S. EPA MO VES model. The analysis is described in more detail in A ppendix C. All projections were made in accordance with “P rocedures for Preparing Emissions Projections” U.S. EPA-45/4-91-019. As discussed above, it was det ermined that the mobile emission contribution as a per cent of the total emission inventory from the area is not significant.

• Emissions inventories are requi red to be projected to future dates to assess the influence growth and future controls will have. LADCO has developed growth and control files for point, area, and non-road categorie s. These files were usedto develop Ohio’s portion of this nonattainment area futureyear emissions estimates used in this document. This was done so the inventories us ed for redesignation are consistent with modeling performed in the future. Appendix D contains LADCO’s techni cal support document detailing the analysis used to project emissions (Base M 9 ).

• For the 2008 attainment year emissions were grown from the 2005 LADCO modeling inv entory, using LADCO’s growth factors, for all se ctors except point sources (electrical generating units and non-electrical generating units). Point source emi ssions for 2008 were compiled from Ohio EPA’s 2008 annual emissions inventory

9 http://www.ladco.org/tech/emis/current/i ndex.php23 database. The 2015 interim year emissions were estimated based on the 2009 and 2018 LADCO modeling inventory, using LADCO’s growth factors, for all sectors except nonEGU PM 2.5 . The 2022 maintenance year is based on emissions estimates from the 2018 LADCO modeling, for all sectors except non-EGU PM 2.5 . Non-EGU PM 2.5 emissions for 2015 and 2022 were grown from 2005 and 2009 emissions estimates.

Ohio EPA is identifying emissi ons projections for 2015 and 2022 for EGUs with implementation of the CAIR program. U.S. EPA has raised concerns regarding the CA IR program and its remand. However, Ohio EPA believes thes e are the most appropriate and accurate future projections. Although CSAPR has been stayed by the D.C. Circuit Court (December 30, 2011), the Court has ordered U.S. EPA to continue administe ring CAIR pending the court’s resolution. It is believed that CSAPR will provide even greater reductions in emissions than t he CAIR program once resolved; therefore, these emissions pr ojections will be conservative.

On March 10, 2004, the U.S. EPA promulgated the CAIR. Beginning in 2009, U.S. EPA’s CAIR rule requires EGUs in 28 eastern states and the District of Co lumbia to significantly reduce emissions of NO x and SO 2 . CAIR replaced the NOx SIP Call for EGUs. The intent of the CAIR program is for national NO x emissions to be cut from 4.5 milli on tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3 million tons in 2018 in 28 states. States were required to submit a CA IR SIP as part of this effort. Ohio submitted a CAIR SIP wh ich was approved by U.S. EPA on February 1, 2007. Revisions to the CAIR SIP were again submitted on July 15, 2009. The revised CAIR SIP was approved as a direct final action on Sept ember 25, 2009 (74 FR 48857). As a result of CAIR, U.S. EPA projec ts that in 2009 emissions of NO x will decrease from a baseline of 264,000 tons per year to 93,000 tons per year while in 2010 emissions of SO 2 will decrease from a baseline of 1,373,000 tons per y ear to 298,000 tons per year, within Ohio. And by 2015 U.S. EPA projects emissions of NO x will decrease to 83,000 tons per y ear while emissions of SO 2 will decrease to 208,000 tons per year, within Ohio 10 . On December 23, 2008, U.S. EPA’s CAIR pr ogram was remanded without vacatur by the D.C. Circuit Court.

As can be seen in Table 9 below, Ohio has seen a significant decline in the 264, 000 tons of NO x and 1,373,000 tons of SO 2

10 http://www. epa.gov/CAIR/oh.html24 emitted in 2005. In 2008 and 2009 facilities began preparing for and implementing control programs to address CAIR 11 and consent decrees.

Table 9 - Reductions in SO 2 and NO x EGU Emissions Between 2008 and 2009
SO 2 NO x 2008 2009 Change 2008 2009 Change Ohio 709,444 601,101 15% 235,018 96,351 59% LADCO States 2,019,036 1,620,071 20% 702,384 393,930 44% National 7,616,262 5,747,353 25% 2,996,287 1,990,385 34% Source: Clean Air Markets Quarterly Emissions Tracking 12

Significant reductions also occu rred regionally and nationally as can be seen from the above table. Data is also available for the first two quarters of 2010, the year SO 2 reductions are to be implemented under CAIR:

Table 10 – Reductions in SO 2 and NO x EGU Emissions Between the First Half of 2008 and 2010
SO 2 NO x 2008 (1 st half) 2010 (1 st half) Change 2008 (1 st half) 2010 (1 st half) Change

Ohio 373,798 279,854 25% 130,598 53,187 59% LADCO States 1,190,497 854,282 28% 419,114 220,907 47% National 3,895,472 2,502,965 36% 1,487,179 930,148 37% Source: Clean Air Markets Quarterly Emissions Tracking 13

The following was reported by U.S. EPA’s Clean Markets Division:

“Based on emissions monitoring data, EPA has observed substantial reductions in SO 2 emissions from 2005 to 2009 and in the first two quarters of 2010 as companies installed more controls, electric demand declined, and low natural gas prices made combined-cycle gas-fired units more competitive in several parts of the country. Thus, even after CAIR's vacatur and subsequent remand in late 2008, t he controls in place generally have continued to operate, helping to drive continued progress in reducing emissions. 14 ”

Ohio EPA is in agreement with t he analysis by U.S.EPA that the CAIR program is providing real reductions at this time, Ohio

11 Under CAIR, NOx reductions are to occur begi nning in 2009 while SO2 reductions are to occur beginning in 2010. 12 http://www. epa.gov/airmarkets/quarterlytracking.html 13 http://www. epa.gov/airmarkets/quarterlytracking.html 14 http://www. epa.gov/airmarkets/background.htm25 believes these reductions have assisted with PM 2.5 attainment in this nonattainment area and throughout Ohio.

On July 6, 2011, U.S. EPA finaliz ed a replacement to the CAIR program, the CSAPR. CSAPR woul d preserve those initial reductions achieved under CAIR and provide even greater reductions in NO x and SO 2 emissions in 2012 and 2014, ahead of the 2015 CAIR Phase 2. As a result of CSAPR, U.S. EPA projected that in 2012 emissions of NO x will decrease to 90,842 tons per year and in 2014 to 85,744 tons per year while SO 2 will decrease to 304,022 tons per y ear in 2012 and 134,333 tons per year in 2014, within Ohio. In addition, U.S. EPA projections indicated that as a result of implementation of CSAPR, there will be no maintenance issues within th is entire nonattainment area. Furthermore, modeling conducted as part of CSAPR projects the counties within this area will not have maintenance issues in 2012 or 2014 even without CSAPR (or CAIR) 15

. However, on December 30, 2011, the D.C. Cir cuit Court stayed CSAPR and ordered U.S. EPA to continue administering CAIR pending the court’s resolution.

Therefore, it is Ohio EPA’s belief it is most appropriate to evaluate Ohio EPA’s demonstration that the projected le vel of emissions is sufficient to maintain the annual PM 2.5 standard by assessing future year emissions that include the CAIR program.

The detailed inventory informati on for the Ohio portion of the Parkersburg-Marietta area for 2005 is in Appendix B. Emission trends are an important gauge for continued compliance with the PM 2.5 standard. Therefore, Oh io EPA performed an initial comparison of the inventories fo r the base year and maintenance years. Mobile source emissi on inventories are described in Appendix C.

Sectors included in the following tabl es are: Electrical Generating Unit (EGU-Point); Non-Electrical Generating Unit (Non-EGU); Nonroad Mobile (Non-road); Other Ar ea (Area); Marine; Aircraft; Rail (MAR); and On-road Mobile (On-road).

Maintenance is demonstrated w hen the future-year (2022) projected emission totals are below the 2008 attainment year totals.

15 See supplemental table “Impacts of the Proposed Transport Rule on Counties with Monitors Projected to have Ozone and/or Fine Particle Air Quality Problems.”26 Demonstration

PM 2.5

The 2005 and 2008 actual PM 2.5 emissions data below generally contains particulate fraction emissions only and not the condensable fractions as Ohio EPA did not have a consistent reporting requirement during those years. U.S. EPA IPM modeling was used to generate future year EGU emissions with the CAIR program . The IPM modeling added additional PM 2.5 condensable emissions into future years. Therefore, comparing base and attainment year emissions with the future year predictions is not accurate in the IPM CAIR modeling. Th is step leads to a false perception of significant PM 2.5 emissions growth. Modeling performed by LADCO, without CAIR, did not incorporate added condensable fraction emissions. Although Ohio EPA has stated that it is most appropriate to evaluate future year emissions that include the CAIR program, because of this flaw it will be more accurate and appropr iate for the purposes of PM 2.5 to evaluate future year emissions without the CAIR program.

Table 11 - Washington County, Ohio PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin EGU Point 384.81 392.62 407.19 418.67 -26.05
Non-EGU 472.37 471.72 470.21 468.70 3.02
Non-road 35.53 30.63 21.19 11.55 19.08
Area 148.43 222.16 251.82 254.36 -32.20
MAR 11.76 10.70 6.52 2.51 8.19
On-road 90.45 75.52 41.68 25.22 50.30
TOTAL 1,143.35 1,203.35 1,198.61 1,181.01 22.34

Table 12 - Wood County, West Virginia PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CSAPR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin EGU Point 0.00 0.00 0.00 0.00 0.00
Non-EGU 176.51 182.34 174.02 166.12 16.22
Non-road 36.85 33.25 25.02 17.51 15.7427 Area 921.41 694.95 686.19 684.48 10.47
MAR 46.05 25.56 25.72 25.88 -0.32
On-road 81.43 66.32 33.62 24.16 42.16
TOTAL 1,262.25 1,002.42 944.57 918.15 84.27

Table 13 - Pleasants Count y, West Virginia PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CSAPR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenanc

e Safety Margin

EGU Point 1,360.23 1,287.83 1,330.92 1,286.59 1.24
Non-EGU 198.72 159.57 143.78 141.49 18.08
Non-road 8.32 8.19 5.96 3.73 4.46
Area 143.43 121.73 116.47 113.48 8.25
MAR 28.83 12.30 12.38 12.45 -0.15
On-road 1.61 1.20 0.55 0.37 0.83
TOTAL 1,741.14 1,590.82 1,610.06 1,558.11 32.71

Table 14 – Parkersburg-Marietta Area PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and projected 2015 and 2022 (tpy) – Without CAIR (Ohio) and With CSAPR (West Virginia)

PM2.5 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin
Washington 1,143.35 1,203.35 1,198.61 1,181.01 22.34

Wood, WV 1,262.25 1002.42 944.57 918.15 84.27

Pleasants, WV 1,741.14 1,590.82 1,610.06 1,558.11 32.71
COMBINED PM 2.5 TOTAL 4,146.74 3,796.59 3,753.24 3,657.27 139.32

NO x
Table 15 - Washington County, Ohio NO x Emission Inventory Totals for Base Year 2005, Estimate d 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin EGU Point 16,137.09 17,168.69 7,505.59 3,364.26 13,804.43
Non-EGU 1,748.86 1,941.94 2,019.31 2,052.47 -110.53
Non-road 425.97 356.74 224.17 88.88 267.86
Area 168.44 178.66 183.96 191.01 -12.35
MAR 500.78 472.52 305.86 148.66 323.86
On-road 2,687.09 2,247.41 1,200.52 572.25 1,675.16
TOTAL 21,668.23 22,365.96 11,439.41 6,417.53 15,948.4328 Table 16 - Wood County, West Virginia NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CSAPR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin EGU Point 0.00 0.00 0.00 0.00 0.00
Non-EGU 943.43 859.44 818.79 780.12 79.32
Non-road 406.22 361.87 231.95 168.36 193.51
Area 704.32 397.82 393.72 389.62 8.20
MAR 1,246.83 754.15 758.90 763.65 -9.50
On-road 2,459.26 2,122.62 992.62 538.59 1,584.03
TOTAL 5,760.06 4,495.90 3,195.98 2,640.34 1,855.56

Table 17 - Pleasants County, West Virginia NO x Emission Inventory Totals for Base Year 2005, Es timated 2008, and Projected 2015 and 2022 (tpy) – With CSAPR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin EGU Point 12,318.14 8,251.74 3,733.99 3,798.80 4,452.94
Non-EGU 639.94 156.90 22.73 21.64 135.26
Non-road 38.49 37.72 31.31 26.65 11.07
Area 174.42 43.54 42.80 42.07 1.47
MAR 799.88 362.14 364.42 366.70 -4.56
On-road 54.17 42.41 19.05 9.96 32.45
TOTAL 14,025.04 8,894.45 4,214.30 4,265.82 4,628.63

Table 18 - Parkersburg-Marietta Area NO x Emission Inventory Totals for Base Year 2005, Estimate d 2008, and Projected 2015 and 2022 (tpy) – With CAIR (Ohio) and With CSAPR (West Virginia)

NOx 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin
Washington 21,668.23 22,365.96 11,439.41 6,417.53 15,948.43

Wood, WV 5,760.06 4,495.90 3,195.98 2,640.34 1,855.56

Pleasants, WV 14,025.04 8,894.45 4,214.30 4,265.82 4,628.63
COMBINED NOx TOTAL 41,453.33 35,756.31 18,849.69 13,323.69 22,432.62

SO 229 Table 19 - Washington County, Ohio SO 2 Emission Inventory Totals for Base Year 2005, Estimate d 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin
EGU Point 140,957.01 133,348.05 61,849.00 31,206.55 102,141.50
Non-EGU 5,200.90 5,372.72 5,744.96 6,122.46 -749.74
Non-road 41.04 15.08 2.47 0.49 14.59
Area 9.78 10.56 10.51 10.15 0.41

MAR 44.48 31.29 12.44 5.21 26.08
On-road 26.97 8.54 6.46 6.31 2.23
TOTAL 146,280.18 138,786.24 67,625.84 37,351.17 101,435.07

Table 20 - Wood County, West Virginia SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CSAPR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin
EGU Point 0.00 0.00 0.00 0.00 0.00
Non-EGU 5,231.51 3,175.37 3,018.61 2,869.59 305.78
Non-road 31.18 5.53 0.67 0.72 4.81
Area 715.82 521.01 493.53 466.05 54.96
MAR 58.80 39.60 39.85 40.09 -0.49
On-road 31.13 10.37 7.88 7.70 2.67
TOTAL 6,068.44 3,751.88 3,560.54 3,384.15 367.73

Table 21 - Pleasants Count y, West Virginia SO 2 Emission Inventory Totals for Base Year 2005, Es timated 2008, and Projected 2015 and 2022 (tpy) – With CSAPR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin

EGU Point 52,295.78 15,803.98 6,090.44 7,687.48 8,116.50
Non-EGU 5,623.32 1,175.69 1.11 1.08 1,174.61
Non-road 2.42 0.47 0.12 0.13 0.34
Area 97.76 55.40 52.50 49.60 5.80
MAR 38.47 19.29 19.41 19.53 -0.24
On-road 0.69 0.22 0.18 0.15 0.07
TOTAL 58,058.44 17,055.05 6,163.76 7,757.97 9,297.0830 Table 22 - Parkersbur g-Marietta Area SO 2 Emission Inventory Totals for Base Year 2005, Estimate d 2008, and Projected 2015 and 2022 (tpy) – With CAIR (Ohi o) and With CSAPR (West Virginia)

SO2 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin

Washington 146,280.18 138,786.24 67,625.84 37,351.17 101,435.07

Wood, WV 6,068.44 3,751.88 3,560.54 3,384.15 367.73

Pleasants, WV 58,058.44 17,055.05 6,163.76 7,757.97 9,297.08
COMBINED SO2 TOTAL 210,407.06 159,593.17 77,350.14 48,493.29 111,099.88

PM 2.5 , NO x , and SO 2
Table 23 - Parkersburg-Marietta Area Comparison of 2008 Attainment Year and 2015 and 2022 Projected Emission Estimates (tpy)

2008 Attainment 2015 Interim 2015 Projected Decrease 2022 Maintenance 2022
Projected Decrease

PM 2.5 4,146.74 3,753.24 393.50 3,657.27 489.47

NO x 35,756.31 18,849.69 16,906.62 13,323.69 22,432.62

SO 2 159,593.17 77,350.14 82,243.03 48,493.29 111,099.88

As shown in the t able above (Table 23), PM 2.5 emissions in the nonattainment area are proj ected to decrease by 393.50 tpy in 2015 and 489.47 tpy in 2022. NO x emissions in the nonattainment area are projected to decr ease by 16,906.62 tpy in 2015 and 22,432.62 tpy in 2022. SO 2 emissions in the nonattainment area are projected to decline by 82,243.03 tpy in 2015 and 111,099.88 in 2022.

In general, EGU source emissions show decreases due to the CAIR program. Cleaner vehicles and fuels are expected to be in place in 2009 and 2018, and the C SAPR will be implemented in 2012 and 2014 and these programs shoul d cause an overall drop in all three pollutants emissions . Decreases from U.S. EPA rules covering Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements 16 , Highway Heavy-Duty Engine Rule 17 , and the Non-Road Diesel Engine Rule 18 are factored into

16 http://www. epa.gov/fedrgstr/EPA-AIR/2000/ February/Day-10/a19a.htm 17 http://www. epa.gov/fedrgstr/EPA-AIR/1997 /October/Day-21/a27494.htm31 the changes.

In addition to the above, additional reductions from Ohio’s utilities have been occurring:

• Muskingum River AEP Station in Washington County has implemented important changes in 2008. Unit #5 (as required through a federally enforc eable consent decree) began continuous operation of their advanced NO x control device. Unit #5 is the largest (600 MW) of five units at this facility. The remaining four units are 205 to 240 MWs (2 each). In addition, by the close of 2015, all units at the Muskingum River AEP Station are required to re tire, repower or retrofit the unit (as required through a f ederally enforceable consent decree) and initial plans i ndicate AEP will install advanced SO 2 controls (FGD scrubber) on unit #5.

• R.H.Gorsuch AMP Station in Washington County permanently shut down at the end of 2010. This facility operated four 53 MW units.

Requirement 4 of 5 A demonstration that improvement in air quality bet ween the year violations occurred and the year attainment wa s achieved is based on permanent and enforceable emission reductions and not on temporary adverse economic conditions or unusually favorable meteorology.

Background Ambient air quality data from all monito ring sites indicate that air quality met the NAAQS for PM 2.5 in 2008-2010. U.S. EPA’s redesignation guidance (p 9) states: “A state ma y generally demonstrate maintenance of the NAAQS by either showing that fu ture emissions of a pollutant or its precursors will not exceed the level of the attainment inventory, or by modeling to show that the future mix of sources and emissions rates will not cause a violation of the NAAQS.”

Demonstration Permanent and enforceable reductions of PM 2.5 , NO x , and SO 2 emissions have contributed to the attainment of the annual PM 2.5 standard. Some of these reductions were realized due to the application of tighter federal standards on new vehicles. Also Title IV of the CAA, the NO x SIP Call, CAIR, and federal consent decrees required the reductions of SO 2 and NO x emissions from utility sources. Reductions achieved are discussed in greater detail under Chapter Five.

18 http://www. epa.gov/fedrgstr/EPA-AIR/1998 /October/Day-23/a24836.htm32 Table 24 - Parkersburg-Marietta Area Comparison of 2005 base year and 2008 attainment year on-road and EGU reductions
2005 2008

On-road PM 2.5 173.49 143.04 On-road NO x 5,200.52 4,412.44 On-road SO 2 58.79 19.13 EGU PM 2.5 1,745.04 1,680.45 EGU NO x 28,455.23 25,420.43 EGU SO 2 193,252.79 149,152.03

Requirement 5 of 5 Provisions for future annual updates of the inventory to enable tracking of the emission levels, including an annual emissi on statement from major sources.

Demonstration In Ohio, major point sources in a ll counties are required to submit air emissions information annually, in accordance with U.S. EPA’s Consolidated Emissions Reporting Rule (CERR). Ohio EPA prepares a new periodic inventory for all PM 2.5 precursor emission sectors every three years. These PM 2.5 precursor inventories will be prepared for future years as necessary to comply with the inventory reporting requirement s established in the CFR. Emissions information will be compared to the 2005 base year and the 2022 projected maintenance y ear inventories to assess emission trends, as necessary, and to assure continued compliance with the annual PM 2.5 standard.33 

### CHAPTER FIVE

CONTROL MEASURES AND REGULATIONS CAA Section107 (d)(3)(E)(ii), 107( d)(3)(iv), and 107(d)(3)(E)(v)

Requirement 1 of 6 Section 172(c)(1) of the 1990 Clean Air Act Amendments requires states with nonattainment areas to implement RACM and RACT.

Background Section 172(c)(1) of the 1990 Cl ean Air Act Amendments requires states with nonattainment areas to submit a SIP providing for implementation of all reasonably av ailable control measures and as expeditiously as practicable (including such reductions in emissions from existing sources in the area as may be obtained through the adoption, at a mini mum, of reasonable available control technology).

U.S. EPA’s Implementati on Rule interprets this requirement in great detail. Under U.S. EPA’s appr oach, RACT is determined as part of the broader RACM analysi s and identification of all measures (for stationary, mob ile, and area sources) that are technically and economically feasib le, and that would collectively contribute to advancing the attain ment date (i.e. by one year or more). States are required to use a combined approach to RACT and RACM, that (1) identifies potential measures that are reasonable, (2) uses modeling to i dentify the attainment date that is as expeditious as practicabl e, and (3) selects the appropriate RACT and RACM.

The Implementation Rule also prov ides for a presumption that in States that fulfill their CAIR em ission reduction requirements, EGU compliance with CAIR is equivalent to RACM/RACT.

Demonstration In 1972, 1980, and 1991, Ohio pr omulgated rules requiring reasonably available controls meas ures for particulate emissions from stationary sources.

Statewide RACT rules have been applied to all new sources locating in Ohio since that time. RACT requirements are incorporated into permits along wit h monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio EPA also has an active enforcement program to address violations34 discovered by field office sta ff. The Ohio RACT rules for particulate matter are found in OAC Chapter 3745-17 19

. In addition, Ohio EPA promulgated NO x SIP Call rules (OAC Chapter 3745-14 20 ), CAIR (OAC Chapter 3745-109 21 ), and NO x Reasonably Available Control Technology rules (OAC Chapter 3745-110 22 ) over the past five years. Emissions from EGUs make up a significant contribution to Oh io’s inventory. Beginning in 2009, Ohio implemented CAIR which has, and will, provide for significant reductions in NO x , PM 2.5 , and SO 2 until such time CSAPR is implemented. Then the CSAPR will provide for even greater reductions.

As part of a larger initiative , LADCO, in consultation with two contractors, performed a series of studies exploring control measures for reducing bot h ozone precursors and PM 2.5 precursors in Ohio, Illinois, I ndiana, Michigan, and Wisconsin area. The first consultant, MACTEC, pr epared a series of white papers 23 researching different stationary source categories. The results were compiled into two reports 24 . The second consultant, Environ, investigated control options for m obile sources. The results were compiled into two reports 25 . The stationary and mobile source sectors (and associated control m easures) were selected by the LADCO States based on several fa ctors presented in the report (See Chapter 2).

Photochemical modeling was t hen conducted (as part of LADCO Round 4 modeling) to assess t he air quality benefit of the candidate control measures and a modeling report was developed 26 . Based on the results, the LA DCO project team felt it would not be possible to advance the attainment date for PM 2.5

. Ohio EPA, in its attainment dem onstration submitted on July 18, 2008, demonstrated (using a weight of evidence approach) that

19 http://www. epa.ohio.gov/dapc/r egs/3745_17.aspx 20 http://www. epa.ohio.gov/dapc/r egs/3745_14.aspx 21 http://www. epa.ohio.gov/dapc/r egs/3745_109.aspx 22 http://www. epa.ohio.gov/dapc /regs/3745_110.aspx 23 http://www.ladco.org/r eports/control/white_papers 24 http://www.ladco.org/r eports/control/final_reports/identificat ion_and_evaluation_of_candi date_control_meas ures_i_april_2005.pdf; http://www.ladco.org/r eports/control/final_reports/identificat ion_and_evaluation_of_candi date_control_meas ures_ii_june_2006.pdf 25 http://www.ladco.org/r eports/control/final_reports/final_report _evaluation_of_candidat e_mobile_source_cont rol_measures_february_2006.pdf; http://www.ladco.org/r eports/control/final_reports/final_report _evaluation_of_candidat e_mobile_source_cont rol_measures_for_ladc o_states_in_2009_and_2012_march_2007.pdf 26 http://www.ladco.org/r eports/control/mode ling/round4_modeling.pdf35 attainment would be achieved in this area by 2009. Because of a projected 2009 attainment date, it would not have been reasonably possible or practicable for Ohio to develop RACT/RACM requirements, promulgate regulat ions and implement a control program prior to the proj ected attainment date.

Requirement 2 of 6 Section 172(c)(2) of the 1990 CAA Amendments requires attainment demonstration SIPs for nonattainment areas to show reasonable further progress (RFP).

Background U.S. EPA’s Implementation Rule requires RFP only for any area which a State projects an atta inment date beyond 2010. The RFP would provide emission reductions showing linear progress between 2002 and 2009. If a State dem onstrates attainment will occur by 2010 or earlier, U.S. EPA considers the attainment demonstration to demonstrat e achievement of RFP.

Demonstration In Ohio’s attainment demonstrat ion submitted on July 18, 2008, Ohio demonstrated (using a weight of evidence approach) that attainment would be achieved in this area by 2009; and therefore, it was not necessary to submit a separate RFP plan.

Requirement 3 of 6 Section 172(c)(3) requires states to subm it a comprehensive inventory of actual emissions.

Background Section 172(c)(3) requires states to submit a comprehensive inventory of actual emissions in the area, including the requirement for periodic revisi ons as determined necessary. 40 CFR 51.1008 requires such inventor y to be submitted within three years of designation and requires a baseline emission inventory for calendar year 2002 or other suitable year to be used for attainment planning.

Demonstration The 2005 comprehensive inventory was submitted to U.S. EPA with Ohio’s PM 2.5 attainment demonstrati on SIP submitted on July 18, 2008. It was then subsequently revised and resubmitted on June 7, 2010.36 Ohio also updates its inventor y in accordance with U.S. EPA’s CERR rule (i.e. emissions stat ements). Ohio EPA submitted its emissions statement SIP on Ma rch 18, 1994 which was approved by U.S. EPA on October 13, 1995 ( 59 FR 51863). As discussed in Chapter 4 (Requirement 4), Ohio EPA submits, and commits to submit, emission inventories (sta tements) every three years.

Requirement 4 of 6 Evidence that control meas ures required in past PM 2.5 SIP revisions have been fully implemented.

Background In addition to the historic RACT requirements for PM, the U.S. EPA NO x SIP Call required 22 states to pass rules that would result in significant emissi on reductions from large EGUs, industrial boilers, and cement kiln s in the eastern United States. Ohio passed this rule in 2001. NOx SIP Call requirements are incorporated into permits along wit h monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio EPA also has an active enforcement program to address violations discovered by field office staff. Compliance is tracked through the Clean Air Markets data monitori ng program. Beginning in 2004, this rule accounts for a reduction of approximately 31 percent of all NO x emissions statewide compar ed to previous uncontrolled years. The other 21 states al so have adopted these rules.

On March 10, 2004, the U.S. EPA promulgated the CAIR. Beginning in 2009, U.S. EPA’s CAIR rule requires EGUs in 28 eastern states and the District of Co lumbia to significantly reduce emissions of NO x and SO 2 . CAIR replaced the NOx SIP Call for EGUs. National NO x emissions will be cut from 4.5 million tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3 million tons in 2018 in 28 states. States were r equired to submit a CAIR SIP as part of this effort. Ohio submi tted a CAIR SIP which was approved by U.S. EPA on February 1, 2007. Revisions to the CAIR SIP were again submitted on July 15, 2009. The revised CAIR SIP was approved as a direct final acti on on September 25, 2009 (74 FR 48857).

Demonstration Controls for EGUs under the NO x SIP Call formally commenced May 31, 2004. Emissions cover ed by this program have been generally trending downward since 1998 with larger reductions occurring in 2002 and 2003. Data ta ken from the U.S. EPA Clean Air Markets web site, quantify the gradual NO x reductions that37 have occurred in Ohio as a resu lt of Title IV of the 1990 CAA Amendments and the beginning of the NO x SIP Call Rule. Ohio developed the NO x Budget Trading Program rules in OAC Chapter 3745-14 27 in response to the SI P Call. OAC Chapter 3745-14 regulates EGUs and certain non-EGUs under a cap and trade program based on an 85 percent reduc tion of NOx emissions from EGUs and a 60 percent reduction of NO x emissions from nonEGUs, compared to historical le vels. This cap was in place through 2008, at which time the CAIR program superseded it as discussed above. Requirement 3 of 5 under Chapter 4 above discussed the reductions Ohio has seen as a result of CAIR.

On April 21, 2004, U.S. EPA published Phase II of the NO x SIP Call that establishes a budget for la rge (greater than 1 ton per day emissions) stationary internal combustion engines. Ohio EPA’s OAC rule 3745-14-12 addresses stat ionary internal combustion engines, all used in natural gas pipeline transmissions. U.S. EPA approved this revision to the SIP on April 4, 2008. An 82 percent NO x reduction from 1995 levels is ant icipated. Completion of the compliance plan occurred by May 1, 2006, and the compliance demonstration began May 1, 2007.

Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards In February 2000, U.S. EPA finalized a federal rule to significantly reduce emissions from cars and li ght trucks, including sport utility vehicles (SUVs). Under this pr oposal, automakers will be required to sell cleaner cars, and refiner ies will be required to make cleaner, lower sulfur gasoline. Th is rule will apply nationwide. The federal rules will phase in bet ween 2004 and 2009. U.S. EPA has estimated that NO x emission reductions will be approximately 77 percent for passenger cars, 86 per cent for smaller SUVs, light trucks, and minivans, and 65 to 95 percent reductions for larger SUVs, vans, and heavier trucks. The sulfur content of gasoline is estimated to be reduced by up to 90 percent. VOC emission reductions will be approxim ately 12 percent for passenger cars, 18 percent for smaller SUVs, light trucks, and minivans, and 15 percent for larger SUVs, vans, and heavier trucks.

Heavy-Duty Diesel Engines In July 2000, U.S. EPA issued a final rule for Highway Heavy Duty Engines, a program which includes low-sulfur diesel fuel standards, which will be phased in from 2004 through 2007. This rule applies to heavy-duty gasoli ne and diesel trucks and buses.

27 http://www. epa.ohio.gov/dapc/r egs/3745_14.aspx38 This rule will result in a 40 percent reduction in NO x from diesel trucks and buses, a large sector of the mobile sources NO x inventory. It also estima ted the level of sulfur in highway diesel fuel will be reduced by 97 percent by mid-2006.

Clean Air Non-road Diesel Rule In May 2004, U.S. EPA issued the Clean Air Non-road Diesel Rule. This rule applies to diesel engines used in industries such as construction, agriculture, and mining. It also contains a cleaner fuel standard similar to the highw ay diesel program. The new standards will cut emissions from non -road diesel engines by more than 90 percent. Non-road diesel equipment, as described in this rule, currently accounts for 47 perc ent of diesel particulate matter (PM) and 25 percent of NO x from mobile sources nationwide. Sulfur levels will be reduced in non -road diesel fuel by 99 percent from current levels, from appr oximately 3,000 parts per million (ppm) now to 15 ppm in 2009. New engine standards take effect, based on engine horsepower, starti ng in 2008. Together, these rules will substantially reduce lo cal and regional sources of PM 2.5 precursors.

Requirement 5 of 6 Acceptable provisions to provide for new source review.

Background Ohio has a longstanding and fu lly implemented New Source Review (NSR) program. This is addressed in OAC Chapter 3745- 31 28 . The Chapter includes provisions for the Prevention of Significant Deterioration (PSD) permitting program in OAC rules 3745-31-01 to 3745-31-20. Ohio's PSD program was conditionally approved on October 10, 2001 (66 FR 51570) and received final approval on January 22, 2003 (68FR 2909) by U.S. E PA as part of the SIP.

Demonstration Any facility that is not listed in the 2005 emission inventory, or for the closing of which credit was ta ken in demonstrating attainment, will not be allowed to construct, reopen, modify, or reconstruct without meeting all applicable NSR requirements. Once the area is redesignated, Ohio EPA will im plement NSR through the PSD program. Requirement 6 of 6

28 http://www.epa.ohio.gov/dapc/regs/3745_31.aspx39 Assure that all existing control measures will remain in effect after redesignation unless the State demonstrates thr ough modeling that the standard can be maintained without one or more control measures.

Demonstration Ohio commits to maintaining t he aforementioned control measures after redesignation. Ohio hereby commits that any changes to its rules or emission limits applicable to PM 2.5 , SO 2 , and NO x as required for maint enance of the annual PM 2.5 standard in the Parkersburg-Marietta area, will be submitted to U.S. EPA for approval as a SIP revision.

Ohio, through Ohio EPA’s Legal offi ce, has the legal authority and necessary resources to actively enf orce any violations of its rules or permit provisions. After redesi gnation, it intends to continue enforcing all rules that rela te to the emission of PM 2.5 precursors in the Parkersburg-Marietta area.40 

### CHAPTER SIX

CONTINGENCY MEASURES CAA Section 107(d)(3)(E)(v)

Requirement 1 of 4 A commitment to submit a revised pl an eight years after redesignation.

Demonstration Ohio hereby commits to review its maintenance plan eight years after redesignation, as required by Section 175(A) of the CAA

.

Requirement 2 of 4 A commitment to expeditiously enact and implement additional contingency control measures in response to ex ceeding specified predetermined levels (triggers) or in the event that future violations of the ambient standard occur.

Demonstration Ohio hereby commits to adopt and expeditiously implement necessary corrective actions in the following circumstances:

Warning Level Response: A warning level response shall be prompted whenever the PM 2.5 average of the weighted annual mean of 15.5 μg/m 3 occurs in a single calendar year within the ma intenance area. A warning level response will consist of a study to determine whether the PM 2.5 value indicates a trend toward higher PM 2.5 values or whether emissions appear to be increasi ng. The study will evaluate whether the trend, if any, is likely to continue and, if so, the control measures necessary to reverse t he trend taking into consideration ease and timing for implementation as well as economic and social considerations. Implementation of necessary controls in response to a warning level response trigger will take place as expeditiously as possible, but in no event later than 12 months from the conclusion of the most recent calendar year.

Should it be determined through the wa rning level study that action is necessary to reverse the noted trend, the procedur es for control selection and implementation outlined under “action level response” shall be followed.

Action Level Response: An action level response shall be prompted whenever a two-year average of the weighted annual means of 15.0 μg/m 3 or greater41 occurs within the maintenance area. A violation of the standard (three-year average of the we ighted annual means of 15.0 μg/m 3 or greater) shall also prompt an action level response. In the event that the action level is tri ggered and is not found to be due to an exceptional event, malfunction , or noncompliance with a permit condition or rule requirement, Ohio EPA in conjunction with the metropolitan planning organization or regional council of governments, will determine additi onal control measures needed to assure future attainment of the NAAQS for annual PM 2.5 . In this case, measures that can be impl emented in a short time will be selected in order to be in place wit hin 18 months from the close of the calendar year that prompted the action level. Ohio EPA will also consider the timing of an ac tion level trigger and determine if additional, significant new regulations not currently included as part of the maintenance provisions will be implemented in a timely manner and will constitute our response.

Control Measure Sele ction and Implementation Adoption of any additional control measures is subject to the necessary administrative and legal process. This process will include publication of notices, an opportunity for public hearing, and other measures required by Ohio law for rulemaking.

If a new measure/control is alr eady promulgated and scheduled to be implemented at the federal or State level, and that measure/control is determined to be sufficient to address the upward trend in air quality, additional local measures may be unnecessary. Furthermore, Ohio will submit to U.S. EPA an analysis to demonstrate the propos ed measures are adequate to return the area to attainment.

Requirement 3 of 4 A list of potential contingen cy measures that would be implemented in such an event.

Demonstration Contingency measures to be c onsidered will be selected from a comprehensive list of measures deemed appropriate and effective at the time the selection is m ade. The selection of measures will be based on cost-effectiveness, em ission reduction potential, economic and social cons iderations or other factors that Ohio EPA deems appropriate. Ohio EPA will solic it input from all interested and affected persons in the maintenance area prior to selecting appropriate contingency measures. Be cause it is not possible at this time to determine what cont rol measures will be appropriate at42 an unspecified time in the future, the list of contingency measures outlined below is not exhaustive.

1) Diesel reduction emission strategies. 2) Alternative fuel (e.g., li quid propane and compressed natural gas) and diesel retrofit programs for fleet vehicle operations. 3) Tighter PM 2.5 , SO 2 , and NO x emissions offsets for new and modified major sources. 4) Impact crushers located at recycle scrap yards – upgrade wet suppression. 5) Concrete manufacturing – upgrade wet suppression. 6) Additional NO x RACT statewide.

No contingency measure shall be implemented without providing the opportunity for full public partici pation during which the relative costs and benefits of individual meas ures, at the time they are under consideration, can be fully evaluated.

Requirement 4 of 4 A list of PM 2.5 , SO 2 , and NO x sources potentially subject to future additional control requirements.

Demonstration The following is a list of PM 2.5 , SO 2 , and NO x sources potentially subject to future controls.

• ICI Boilers - SO 2 and NO x controls;

• EGUs;

• process heaters;

• internal combustion engines;

• combustion turbines;

• other sources greater than 100 tons per year;

• fleet vehicles;

• concrete manufacturers;

• aggregate processing plants;43 

### CHAPTER SEVEN

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public comment concerning the draft redesignat ion petition and maintenance plan in the widely distributed county publicat ions on January 17, 2012.

The public hearing to receive comment s on the redesignation request was held on February 16, 2012, at the Marietta Public Library, Marietta, Ohio. The public comment period closed on F ebruary 16, 2012. Appendix F includes a copy of the public notice, certificat ion of publication, and the tr anscript from the public hearing.44 

### CHAPTER EIGHT

CONCLUSIONS

The Parkersburg-Marietta annual PM 2.5 nonattainment area has attained the 1997 annual NAAQS for PM 2.5 and complied with the applicable provisions of the 1990 Amendments to the CAA regar ding redesignations of PM 2.5 nonattainment areas. Documentation to that effect is contained herein. Ohio EPA has prepared a redesignation request and maintenance pl an that meet the requirements of Section 110 (a)(1) of the 1990 CAA.

Based on this presentation, t he Parkersburg-Marietta annual PM 2.5 nonattainment area meets the requirem ents for redesignation under the CAA and U.S. EPA guidance. Oh io has performed an analysis that shows the air quality improvements ar e due to permanent and enf orceable measures. Furthermore, because this area is subject to significant transport of pollutants, significant regional SO 2 and NO x reductions will ensure continued compliance (maintenance) with the standard with an increasing margin of safety.

The State of Ohio hereby requests t hat the Parkersburg-Marietta annual PM 2.5 nonattainment area be redesignated to attainment simultaneously with U.S. EPA approval of the maintenance plan provisions contained herein.This page left intentionally blank