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Draft Technical Support Document

WEST VIRGINIA

Area Designations For the 

2010 SO2 Primary National Ambient Air Quality Standard

Summary

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

either “unclassifiable,” “attainment,” or “nonattainment” for the 2010 1-hour sulfur dioxide 

(SO2) primary national ambient air quality standard (NAAQS). The CAA defines a 

nonattainment area as one that does not meet the NAAQS or that contributes to poor air quality 

in a nearby area that does not meet the NAAQS. Table 1 below identifies the counties or 

portions of counties in the State of West Virginia (“West Virginia” or “WV”) that EPA intends 

to initially designate nonattainment based on monitored violations. 

Table 1. Nonattainment Area Designations for West Virginia

Area

West Virginia’s 

Recommended Designation

of Areas/Counties

EPA’s Intended 

Designation of 

Areas/Counties

Steubenville, OH-WV* 

Brooke, WV

Jefferson, OH (partial)—Cross Creek, 

Steubenville, Warren and Wells Townships

Nonattainment

N/A

Nonattainment

Nonattainment

Wheeling, WV-OH*

Marshall, WV

Belmont, OH (partial)—Mead Township

Nonattainment

N/A

Nonattainment

Nonattainment

* This is a multi-state nonattainment area. Additional information on boundary 

recommendations and analyses can be found in the draft technical support document for the State 

of Ohio.

Background

On June 2, 2010, EPA revised the primary SO2 NAAQS (75 FR 35520) by establishing a new 1-

hour standard at a level of 75 parts per billion (ppb) which is attained when the 3-year average of 

the 99th percentile of daily maximum 1-hour average concentration at each monitor in an area 

does not exceed 75 ppb. EPA has determined that this is the level necessary to provide 

protection of public health with an adequate margin of safety, especially for children, the elderly 

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

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

evaluated over 24-hours, and 30 ppb evaluated over an entire year because the standards will not 

add additional public health protection given a 1-hour standard at 75 ppb. Accordingly, EPA is 

not designating areas in this process on the basis of either of these two prior primary standards. 
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Similarly, the secondary standard for SO2 has not been revised, so EPA is not designating areas 

in this process on the basis of the secondary standard.

EPA’s SO2 Designation Approach

Section 107(d) of the CAA requires that no later than one year after promulgation of a new or 

revised NAAQS, state Governors must submit their recommendations for designations and 

boundaries to EPA. This deadline was in June 2011. Section 107(d) also requires EPA to 

provide a notification to states of no less than 120 days prior to promulgating an initial area 

designation that is a modification of a state’s recommendation. If a state or tribe did not submit 

designation recommendations, EPA will promulgate the designations that it deems appropriate. 

If a state or tribe disagrees with EPA’s intended area designations, they have an opportunity to 

demonstrate why any proposed modification is inappropriate.

Designations guidance was issued by EPA through a March 24, 2011 memorandum from 

Stephen D. Page, Director, U.S. EPA, Office of Air Quality Planning and Standards, to Air 

Division Directors, U.S. EPA Regions I-X. This memorandum identifies factors EPA intends to 

evaluate in determining boundaries for areas designated nonattainment. These 5 factors include: 

1) Air quality data; 2) Emissions and emissions-related data (location of sources and potential 

contribution to ambient SO2 concentrations); 3) Meteorology (weather/transport patterns); 4) 

Geography/topography (mountain ranges or other air basin boundaries); and 5) Jurisdictional 

boundaries (e.g., counties, air districts, pre-existing nonattainment areas, reservations, 

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

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

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

boundary unless additional provided information justifies a larger or smaller boundary than that 

of the county. EPA believes it is appropriate to evaluate each potential area on a case-by-case 

basis, and to recognize that area-specific analyses conducted by states, tribes and/or EPA may 

support a different boundary than a default county boundary.

In this TSD, EPA discusses its review and technical analysis of the recommendations submitted 

by West Virginia for designations of the 1-hour SO2 standard and any modifications from these 

recommendations regarding areas for which there are monitored violations of the NAAQS. 

Definitions of important terms used in this document:

1) Designated “nonattainment” area – an area which EPA has determined, based on a state 

recommendation and/or on the technical analysis included in this document, has violated the 

2010 SO2 NAAQS, based on the most recent three years of air quality monitoring data, or 

contributes to a violation in a nearby area. 

2) Recommended nonattainment area – an area a State or Tribe has recommended to EPA be 

designated as nonattainment.
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3) Violating monitor – an ambient air monitor meeting all methods, quality assurance and citing 

criteria and requirements whose valid design value exceeds 75 ppb, as described in Appendix T 

of 40 CFR part 50.

4) 2010 SO2 NAAQS – 75 ppb, national ambient air quality standard for SO2 promulgated in 

2010. Based on the 3-year average of the 99th percentile of the annual distribution of daily 

maximum 1-hour average concentrations

5) Design Value – a statistic that describes the air quality status of a given area relative to the 

level of the NAAQS. 

Nonattainment Designations

Introduction

In West Virginia’s designation recommendation letter to EPA, dated May 23, 2011, Randy 

Huffman, Secretary of the West Virginia Department of Environmental Protection (WVDEP), 

recommended that Brooke, Hancock, Marshall, Monongalia, and Wood counties be designated 

as nonattainment for the 2010 SO2 NAAQS based on monitored air quality data from 2008-2010. 

On January 22, 2013, West Virginia submitted a revised recommendation letter to EPA 

indicating that subsequent air monitoring data (2010-2012) suggests that the air quality has 

significantly improved in three of those counties: monitors in Hancock, Monongalia, and Wood 

are no longer showing violations of the 2010 1-hour SO2 standard. The letter indicated that the 

data had been uploaded into EPA’s Air Quality System (AQS).

Based on EPA’s technical analysis, EPA intends to initially designate two areas as nonattainment 

(Table 1) based on monitored violations of the NAAQS. The Steubenville, OH-WV

Nonattainment Area consists of Brooke County, WV and a portion of Jefferson County, OH 

(Cross Creek, Steubenville, Warren and Wells Townships). The Wheeling Nonattainment Area 

consists of Marshall County, WV and a portion of Belmont County, OH (Mead Township). 

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

1. Air quality data. This factor considers the SO2 air quality monitoring data from EPA’s 

Air Trends website (see http://www.epa.gov/airtrends/values.html), including the design 

values (in ppb) calculated for each monitor in the area for the most recent 3-year period.

A monitor’s design value indicates whether that monitor violates a specified air quality 

standard. The 2010 SO2 NAAQS is met at a monitoring site when the identified design 

value is valid and less than or equal to 75 ppb as described in Appendix T of 40 CFR part 

50. An ambient air monitor whose valid design value exceeds 75 ppb, as described in 

Appendix T of 40 CFR part 50, is deemed a violating monitor. A design value is only 

valid if minimum data completeness criteria are met. An SO2 design value that meets the 

NAAQS is generally considered valid if it encompasses 3 years of complete data. A year 

is complete when all 4 quarters are complete. A quarter is complete when 75% of the 

days are complete. A day is complete when it has 75% of its hours. Data substitution 

tests are described in Appendix T of 40 CFR part 50. Areas where monitoring data 
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indicate a violation of the 1-hour, 75 ppb primary SO2 standard will be designated as 

nonattainment. 

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

ambient SO2 concentrations). We reviewed data from the 2008 National Emissions 

Inventory (NEI), version 2 (v2), which was the most current version of the national 

inventory available in 2011 when these data were compiled for the designations process,

(see http://www.epa.gov/ttn/chief/net/2008inventory.html) or other relevant sources of 

data, such as state inventories or inventories from other federal sources. EPA recognizes

that there might be no new information on any changes in emissions that may have 

occurred after 2008, but would consider more recent years if available. For example, 

certain large sources of emissions in or near an area may have installed emission controls 

or otherwise significantly reduced emissions since 2008. Also any additional information 

we receive on federally-enforceable emissions control that are not reflected in recent 

inventories but which will require compliance before final designations are issued were 

considered. Two source categories from the 2008 NEI were examined: the point source 

inventory and the nonpoint source inventory. Generally, the point source inventory 

represents the bulk of the SO2 emissions in EPA Region III.

Additionally, a source screening analysis, involving an emissions by distance (Q/d) 

methodology, was used to assess the need to examine point sources for further review 

which are located within 50 kilometers of a violating monitor. North Carolina’s 

Prevention of Significant Deterioration (PSD) Guidance document

(http://www.ncair.org/permits/mets/psd_guidance.pdf) describes a screening 

methodology used to identify point sources to be specifically included in a modeled 

impact analysis. According to this method, a source is considered to be significant and, 

therefore, included in the modeling analysis if its annual emissions are greater than or 

equal to twenty (20) times the distance between the source and the point of interest 

(Q/d≥20 or Q/20d≥1), or as used in this case, the violating monitor. While not used for 

the same purpose, this methodology was used to identify point sources near a violating 

monitor for further review. 

Point source emissions data are needed to perform the Q/d analysis. Three sources of 

emissions data were considered for this screening analysis: emissions recorded in the 

2008 NEI, the 2011 Clean Air Markets Division (CAMD) reported emissions, and the 

sources’ permitted emission limits. CAMD emissions were limited to sources with 

continuous emissions monitors (CEMs). Point source emission information from the 

2008 NEI and 2010 CAMD represent actual yearly emission totals, and these values are 

probably less than a point source’s allowable or permitted emission limit. Permitted 

emission limits are generally unavailable since most states lack a central repository or 

permit database at this time. Emissions used in the Q/d screening analysis were chosen 

following the steps outlined below in Figure 1. 
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Figure 1. Emission Decision Tree

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

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

of sources contributing to ambient SO2 concentrations. The National Weather Service 

maintains surface and upper air monitoring sites across the United States. Automated 

Surface Observing System (ASOS) (http://www.weather.gov/asos) sites collect hourly 

averaged wind measurements including wind direction and wind speed. Upper air 

measurements (rawinsonde) are collected at a limited number of sites where vertical wind 

profiles are taken using weather balloons. Measurements taken at ASOS and rawinsonde 

sites are often used in dispersion modeling analyses using EPA’s AERMOD modeling 

system. 

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

and run through AERMOD’s preprocessor AERMINUTE to produce hourly averaged 

wind fields. This data was then run through Lakes Environmental’s WRPLOT software 

to produce wind roses for the airports, showing predominant wind patterns in the area.

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

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

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

help define boundaries. Maps depicting elevations and point sources were constructed 

and evaluated to determine the effects of the topography on point source emissions.

5. Jurisdictional boundaries (e.g., counties, air districts, pre-existing nonattainment areas, 

reservations, metropolitan planning organizations). Once the geographic area associated 

with the area violating the SO2 standard and the nearby area contributing to violations 

were determined, we considered existing jurisdictional boundaries for the purposes of 

providing a clearly defined legal boundary for carrying out the air quality planning and 

enforcement functions for the nonattainment area. If an existing jurisdictional boundary 

is used to help define the nonattainment area, it encompasses all of the area that has been 

identified as meeting the nonattainment definition. These existing boundaries may 
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include an existing nonattainment or maintenance area boundary, a county or township 

boundary, a metropolitan area boundary, an air management district, or an urban planning 

boundary established for coordinating business development or transportation activities. 

Where existing jurisdictional boundaries are not adequate to describe the nonattainment 

area, other clearly defined and permanent landmarks or geographic coordinates are used.

West Virginia recommended the county boundary for all its nonattainment area 

boundaries, which was the recommended default boundary as per EPA’s March 24, 2011

designations guidance. In addition to considering the county boundary, we also 

examined use of Metropolitan Statistical Areas (MSAs) as the jurisdictional boundary. 

The U.S. Office of Management and Budget (OMB) defines metropolitan and 

micropolitan statistical areas according to published standards that are applied to Census 

Bureau data. The general concept of a metropolitan or micropolitan statistical area is that 

of a core area containing a substantial population nucleus, together with adjacent 

communities having a high degree of economic and social integration with that core

(http://www.census.gov/population/www/metroareas/aboutmetro.html). Finally, 

previously established Air Quality Control Regions (AQCRs) were considered as well.

The five factor descriptions above are a combination of descriptions from the March 24, 2011 

memo and other relevant information pertaining to this TSD. 

Technical Analysis for the Steubenville, OH-WV Nonattainment Area

This technical analysis for the Steubenville, OH-WV Nonattainment Area identifies the whole 

county with a monitor that violates the 2010 SO2 NAAQS, and evaluates nearby counties for 

contributions to SO2 concentrations in the area. For this area, Brooke County has a violating 

monitor. EPA has evaluated this county and nearby counties based on the weight of evidence of 

the factors recommended in the March 24, 2011 guidance issued by EPA. 

Based on EPA's technical analysis described below, EPA intends to expand upon West 

Virginia’s recommendation and initially designate, based on the violating monitor in Brooke 

County in West Virginia, all of Brooke County and a portion of Jefferson County, Ohio as 

nonattainment for the 2010 SO2 NAAQS as part of the Steubenville, OH-WV Nonattainment 

Area. The analysis in this TSD is primarily for the West Virginia portions of the nonattainment 

area. The analysis for the Ohio portion (Jefferson County) can be found in the TSD for Ohio.

Air Quality Data 

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

based on certified data for the 2009-2011 period. Figure 2 depicts the area analyzed and the 

locations of the violating air quality monitors based on 2009-11 data. The 2010 1-hour SO2

design values for all the monitors located in Brooke County are shown in Table 2.
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 Figure 2.

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

Monitor ID 99th % Design Value Design Value

2007 2008 2009 2010 2011 2008-10 2009-11

Mahan Lane 54-009-0005 131 168 82 131 143 127 119

McKims 54-009-0007 168 137 81 92 75 103 83

Marland 

Heights

54-009-0011 169 159 143 143 219 148 174

All three monitors in Brooke County violated based on both 2008-10 and 2009-11 data. Onehour SO2 monitor design values within Brooke County range from about 140% to almost twice 

the 1-hour SO2 NAAQS. There are significant differences in Brooke County’s design values. 

These differences occur between monitors that are generally within ten kilometers of one another 

and suggest substantial 1-hour SO2 gradients exist in the northwest portion of Brooke County 

where the monitors are located. 

An additional monitor in Jefferson County, Ohio is also showing a monitored violation of the 

2010 SO2 NAAQS, as discussed in the TSD for Ohio. Based on evidence that violations are 

occurring in Brooke County, West Virginia and Jefferson County, Ohio, EPA intends to initially 

designate a nonattainment area that includes the sources in the area that contribute to these 

monitored violations. 
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Emissions and Emissions-Related Data

Evidence of SO2 emissions sources in the vicinity of a violating monitor is an important factor 

for determining whether a nearby area is contributing to a monitored violation. For this factor, 

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

since the date represented by those emissions data.

Emissions 

EPA recognizes that there might be no new information on any changes in emissions that may 

have occurred after 2008, but would consider more recent years if available. West Virginia did 

not provide updated emissions information, therefore EPA relied on the 2008 NEI emissions data

(NEI08V2). 

Table 3 shows total emissions of SO2 in tons per year (tpy) for violating and potentially 

contributing counties in and around the Steubenville, OH-WV Nonattainment Area and sources 

emitting greater than 100 tpy of SO2 according to the 2008 NEI. Similar information for the 

Ohio portion of this nonattainment area can be found in the TSD for Ohio.

Table 3. SO2 Emissions in Steubenville, OH-WV Nonattainment Area

County

Facility 

Located in 

State

Recommended 

Nonattainment 

Area?

Facility Total 

Facility SO2

Emissions 

(tpy)

Total 

County SO2

Point 

Emissions 

Name EIS (tpy)

Coordinates

(lat, long)

Brooke, WV Yes Mountain State 

Carbon, LLC

4864311 40.34361,

-80.60667

731 767

Jefferson, 

OH

Yes W.H. Sammis 

Plant

8190811 40.5308,

-80.6311

102,195 136,297

Jefferson, 

OH

Yes Cardinal Power 

Plant

8115711 40.2522,

-80.6486

33,317 136,297

Jefferson, 

OH

Yes Severstal

Wheeling, Inc.

8190711 40.31974,

-80.6042

700 136,297

Beaver, PA Yes First Energy Gen 

Corp/Bruce 

Mansfield Plant

3853711 40.6344,

-80.42

11,019 17,584

Beaver, PA Yes AES Beaver Valley 

LLC

8141311 40.6558,

-80.3556

3,113 17,584

Beaver, PA Yes Horsehead 

Corp/Monaca 

Smelter

7991511 40.67058,

-80.3365

3,320 17,584

Lawrence, 

PA

No Orion Power 

Midwest/New 

Castle Power Plant

3776611 40.9378,

-80.3681

12,923 14,532

Lawrence, 

PA

No ESSROC/

Bessemer

6595011 40.9745,

-80.49011

910 14,532

Lawrence, 

PA

No CEMEX/Wampum 

Cement Plant

6621611 40.87825,

-80.3247

674 14,532
9

Allegheny, 

PA

Yes Bay Valley Foods, 

LLC

8521211 40.45343,

-79.98584

487 35,844

Allegheny, 

PA

Yes Shenango Inc 7407611 40.492,

-80.07968

333 35,844

Washington, 

PA

Yes Langeloth 

Metallurgical

4778911 40.36346,

-80.401

186 3,746

Greene, PA No Consol PA Coal Co 

LLC/Bailey Prep 

Plant

3746711 39.97286,

-80.41215

581 160,808

Using point source emissions data, the emissions by distance (Q/d) screening methodology was 

used to identify sources within 50 kilometers (km) of a violating monitor in Brooke County for 

further review. 

A total of eleven point sources emitting more than 100 tpy (from the 2008 NEI v2) are located 

within 50 km of at least one of the nonattainment monitors in the county. Of these eleven point 

sources, one source is located in Brooke County; one source is located in Hancock; three sources 

are in neighboring Jefferson County, OH; three are located in Beaver County, PA; and one 

source emitting more than 100 tpy is located in each of the following PA counties: Allegheny, 

Greene, and Washington County. Following the Q/d methodology, eight of the eleven sources 

were identified for further review. These sources are W.H. Sammis Plant, Arcelormittal 

Weirton, Inc., Mountain State Carbon, LLC, Serverstal Wheeling, Inc., Cardinal Power Plant, 

First Energy Gen Corp/Bruce Mansfield Plant, AES Beaver Valley LLC, and the Horsehead 

Corp/Monaca Smelter.

 

Figure 3.

 
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Figure 4.

CAMD Emissions Analysis

Emissions from sources included in EPA’s CAMD database 

(http://camddataandmaps.epa.gov/gdm/index.cfm?fuseaction=emissions.wizard) were reviewed 

to determine if more recent emissions are available for sources near the violating monitors.

Not all emissions sources within 50 km of the violating monitors are included in the CAMD 

database. The sources who did report their annual emissions to CAMD are listed in Table 4.

Table 4. CAMD 2008-11 Emissions Summary of SO2 Emissions in tpy

Facility County

CAMD2008CAMD2009CAMD2010CAMD2011

AES Beaver Valley Beaver Not 

Available

3,500 1,491 3,086

First Energy/Bruce 

Mansfield 

Beaver 11,117 17,704 8,971 21,196

W.H. Sammis Plant Jefferson 102,619 73,614 12,761 4,202

Orion Power/New 

Castle Power Plant

Lawrence 12,923 7,629 5,442 7,510

Cardinal Power Plant Jefferson 32,497 34,751 32,522 25,116
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Emissions Controls

Under this factor, the existing level of control of emission sources is taken into consideration. 

The emissions data used by EPA in this technical analysis represent emissions levels taking into 

account any control strategies implemented on stationary sources in the Steubenville, OH-WV

Nonattainment Area up to and including 2008. Although EPA has not received any additional 

information on emissions reductions resulting from controls put into place after 2008, EPA has 

collected additional information from the 2008 NEI and CAMD. 

Four sources have Flue Gas Desulfurization (FGD) units installed on them. Two sources, the H. 

W. Sammis and Cardinal power plants, both in Jefferson County, OH, have installed controls in 

a phased-in approach since 2008. Both the Bruce Mansfield power plant in Beaver County and 

the AES Beaver Valley plant have had controls on-line since the facilities became operational in 

the mid 1970’s. Additionally, the Bruce Mansfield power plant has recently completed upgrades 

to its controls.

Meteorology (weather/transport patterns)

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

values at violating monitors is another important factor in determining the appropriate 

contributing areas and the appropriate extent of the nonattainment area boundary. For this factor, 

EPA considered data from sites that collected hourly averaged wind measurements including 

wind direction and speed for 5 years. The two closest meteorological monitoring sites currently 

operating near the violating monitors in Brooke County are at the Wheeling/Ohio County Airport 

and the Pittsburgh International Airport. An ASOS and rawinsonde site is located at the 

Pittsburgh International Airport. The Washington County Airport in PA was also included.

However, the data recovery at this site was not as complete as at the Pittsburgh and Wheeling 

sites. One-minute meteorological wind fields for the Pittsburgh and Wheeling ASOS sites was 

downloaded and run through AERMOD’s preprocessor AERMINUTE to produce hourly 

averaged wind fields. These data along with the Washington County data recovered from the 

Pennsylvania State Climatologists Office were then run through Lakes Environmental’s 

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

monitors.
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Figure 5.

Wind rose plots for Pittsburgh International, Wheeling/Ohio County and Washington County 

airports show there are slightly different wind distribution patterns. At Pittsburgh International 

airport, the prevailing surface winds are predominantly out of the west with secondary peaks out 

of the southwest and northwest, whereas the winds at the Wheeling, Ohio County airport are 

predominantly out of the southwest. These slightly different wind patterns between the sites are 

probably due to differences in local topography. 

Given this information, with a dominant southwest wind at the Wheeling, Ohio County airport, 

EPA is not prepared to conclude that smaller sources in Hancock County and the large sources 

located northeast of the violating monitors, specifically those in Lawrence and Beaver Counties 

(ie. ESSROC/Bessemer and Orion Power Midwest/New Castle Power Plant, First Energy Gen 

Corp/Bruce Mansfield Plant, AES Beaver Valley LLC, Horsehead Corp/Monaca Smelter) are 

likely to be contributing to the violating Brooke County monitors. These prevailing wind 

patterns, however, show that the emissions from large sources in Jefferson County are likely 

impacting the violating monitors in Brooke County. 

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

Figure 6 below depicts elevations and locations of point sources near Brooke County, which lies 

on the eastern side of the Ohio River. The county’s elevated terrain contrasts with the lower 

elevations of the Ohio River and its tributaries that pass through the counties. This creates sharp 

contrasts in elevation with the Ohio River sitting around 200 meters above mean sea level and 

the adjacent mountains exceeding 350 meters.
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Most of the large (>100 tpy) point sources in this region reside within the Ohio River Valley. It 

should be noted that the three surface meteorological sites reviewed in the previous section are 

located at higher elevations than most of the point sources, and therefore sources may be subject 

to different wind patterns, which could influence local dispersion patterns. It is unlikely, 

however that this would impact the transport of pollutants from large sources west of the 

violating monitors given that the emissions from those sources are significant.

 Figure 6.

Jurisdictional boundaries 

Although there is no existing maintenance boundary (i.e. a previous nonattainment area) in 

Brooke County for the 1971 primary SO2 NAAQS, there are two other possible pre-existing 

boundaries that can be considered: the Weirton-Steubenville, WV-OH MSA and the 

Steubenville-Weirton-Wheeling AQCR. The Weirton-Steubenville, WV-OH MSA contains 

Brooke County and Hancock County, WV along with Jefferson County, OH. The SteubenvilleWeirton-Wheeling AQCR consists of Hancock, Brooke, Ohio, and Marshall Counties in West

Virginia along with Columbiana, Jefferson, Belmont and Monroe Counties in Ohio.

The Weirton-Steubenville, OH-WV MSA lies within the 50 kilometer buffer extending from 

both the Brooke County monitors. Drawing the nonattainment boundary along the WeirtonSteubenville, WV-OH MSA would bring in all of the large sources identified in the emissions 

screening analysis presented earlier that likely impact the violating monitors in Brooke County. 

Although this boundary is a viable option for the nonattainment area boundary, using this 

boundary would also bring sources into the nonattainment area that might not be contributing to 

the violating monitors in Brooke County. For these reasons, it would be practical at this point to 
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only initially include the portions of the county with the large sources contributing to the 

violating monitors in Brooke County in the nonattainment area. 

 

 Figure 7.

The Steubenville-Weirton-Wheeling Interstate AQCR, codified in the Code of Federal 

Regulations (CFR) § 81.33, is another possible nonattainment boundary. The area is much larger 

than the Weirton-Steubenville, WV-OH and includes eight counties, four each in Ohio and West 

Virginia. The Steubenville-Weirton-Wheeling Interstate AQCR includes sources which EPA is 

not prepared to conclude are likely to contribute to the monitored violations in Brooke County. 

For this reason it would not be practical to use the AQCR as the initial nonattainment boundary 

that is based on the violating monitors. 

 
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Figure 8.

Conclusion for the Steubenville, OH-WV Nonattainment Area

After considering the factors described above, EPA intends to find that the appropriate initial 

boundary for the Brooke County, WV locations with violating monitors is a multi-state 

nonattainment area consisting of Brooke County and a portion of Jefferson County in Ohio as 

identified in Table 1 with area name Steubenville, OH-WV Nonattainment Area for the 2010 

SO2 NAAQS. 

The air quality monitors in Brooke County show violations of the 2010 SO2 NAAQS, based on 

certified 2009-2011 air quality data. Jefferson County is a nearby area with sources that EPA 

finds contribute to the SO2 concentrations in Brooke County. Available emissions, 

meteorological data, and geographical data suggest that large emission sources west and 

southwest of the monitors likely impact the monitors and contribute to SO2 NAAQS violations in 

Brooke County. 

Based on the consideration of all the relevant and available information, as described above, 

EPA believes that the boundaries described herein encompass the appropriate initial 

nonattainment area based on violating monitors in Brooke County in West Virginia. 
16

Figure 9.

Technical Analysis for the Wheeling, WV-OH Nonattainment Area

This technical analysis for the Wheeling, WV-OH Nonattainment Area identifies the whole 

county with a monitor that violates the 2010 SO2 NAAQS, and evaluates nearby counties for 

contributions to SO2 concentrations in the area. For this area, Marshall County, WV has a 

violating monitor. EPA has evaluated this county and nearby counties based on the weight of 

evidence of the factors recommended in the March 24, 2011 guidance issued by EPA. 

Based on EPA's technical analysis described below, EPA is intending to expand upon West 

Virginia’s recommendation and initially designate based on the monitored violations in Marshall 

County in West Virginia and a portion of Belmont County (Mead Township), OH as 

nonattainment for the 2010 SO2 NAAQS as part of the Wheeling, WV-OH Nonattainment Area. 

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

although some information for the Ohio portion may be included. The full analysis for the Ohio 

portion can be found in the TSD for Ohio.

Air Quality Data

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

calculated for all air quality monitors in Marshall County, WV in the Wheeling, WV-OH

Nonattainment Area based on certified 2009-11 data. Figure 10 depicts the area analyzed and 
17

the location of the violating air quality monitor. The data for the monitor located in Belmont 

County, Ohio is presented in the TSD for Ohio.

Figure 10.

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

5.

Table 5. Marshall County Monitor Trend: 1-Hour SO2 99th % and Design Value in Parts 

Per Billion (ppb)

Monitor 

Name

Monitor Air 

Quality 

System ID

99th % Design 

Value

Design 

Value

2007 2008 2009 2010 2011 2008-10 2009-11

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

One-hour SO2 design values appear to be generally falling over the last four years though there is 

insufficient data to clearly establish a definitive trend. The Marshall County monitor’s 99th % 

concentration for 2009 is significantly lower than its other values. The severe recession during 

2009 or decreases in local source emissions in the vicinity of the monitor could have contributed 

to the monitor’s lower concentrations in that year. 
18

Emissions and Emissions-Related Data

Evidence of SO2 emissions sources in the vicinity of a violating monitor is an important factor 

for determining whether a nearby area is contributing to a monitored violation. For this factor, 

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

since the date represented by those emissions data.

Emissions 

EPA recognizes that there might be no new information on any changes in emissions that may 

have occurred after 2008, but would consider more recent years if available. West Virginia did 

not provide updated emissions information, therefore EPA relied on the 2008 NEI emissions data

(NEI08V2). 

Table 6 shows total emissions of SO2 in tons per year (tpy) for violating and potentially 

contributing counties in and around the Wheeling Nonattainment Area and sources emitting 

greater than 100 tpy of SO2 according to the 2008 NEI. This information for the Ohio portion 

(Belmont County) of this nonattainment area can be found in the TSD for Ohio.

Table 6. SO2 Emissions in the Wheeling Nonattainment Area

County

Facility Located in 

State

Recommended 

Nonattainment 

Area?

Facility Total 

Facility 

SO2

Emissions 

(tpy)

Total 

County 

SO2 Point 

Emissions 

Name EIS (tpy)

Coordinates

(lat, long)

Marshall, 

WV

Yes Ohio Power –

Kammer 

Plant

6902411 39.8464,

-80.8189

32,050 51,576

Marshall, 

WV

Yes PPG 

Industries, 

Inc.

4878711 39.74694,

-80.8542

7,693 51,576

Marshall, 

WV

Yes Rain CII 

Carbon 

Moundesville 

Calcining

4985611 39.83694,

-80.81889

7,630 51,576

Marshall, 

WV

Yes Ohio Power -

Mitchell 

Plant

6902311 39.8297,

-80.8153

3,024 51,576

Marshall, 

WV

Yes Columbian 

Chemicals 

Company

5002011 39.79917,

-80.82139

1,180 51,576

Belmont, OH Yes R.E. Burger 

Plant

8120011 39.9094,

-80.7608

15,126 15,126

Jefferson, OH Yes Cardinal 

Power Plant

8115711 40.2522,

-80.6486

33,332 136,297
19

Monroe, OH No Ormet 

Primary 

Aluminum

7983111 39.70444,

-80.84222

2,442 2,442

Greene, PA No Consol PA 

Coal Co 

LLC/Bailey 

Prep Plant

3746711 39.97286,

-80.41215

581 160,808

Brooke, WV Yes Mountain 

State Carbon, 

LLC

4864311 40.34361,

-80.60667

731 767

Jefferson, OH Yes Severstal 

Wheeling, 

Inc.

8190711 40.31974,

-80.6042

700 136,297

Monongalia, 

WV

Yes Consol 

Blacksville 

#2 Prep Plant

6773711 39.71056,

-80.2942

191 83,325

Q/d Screening Analysis

Using point source emissions data, the emissions by distance (Q/d) screening methodology was 

used to identify sources within 50 km of a violating monitor in Marshall County for further 

review. A total of 12 point sources emitting more than 100 tpy (from the 2008 NEI v2) are 

located within 50 km of the monitor in Marshall County. Of these 12 point sources, five are 

located in Marshall County, WV; two sources emitting more than 100 tpy are in neighboring 

Jefferson County, OH; one source is located in each of the following counties: Belmont County, 

OH; Monroe County, OH; Brooke County, WV; Monongalia County, WV; and Greene County, 

PA. Following the Q/d methodology, we determined that nine of the twelve sources should be 

further reviewed. These sources are R.E. Burger Plant; Ohio Power/Kammer Plant; Ohio 

Power/Mitchell Plant; Columbian Chemicals Company; Rain CII Carbon Moundsville 

Calcining; PPG Industries, Inc.; Ormet Primary Aluminum; Cardinal Power Plant; and Consol 

PA Coal Co. LLC/Bailey Prep Plant.
20

Figure 11.

 Figure 12.
21

CAMD Emissions Analysis

Emissions from sources included in EPA’s CAMD database 

(http://camddataandmaps.epa.gov/gdm/index.cfm?fuseaction=emissions.wizard) were used to 

determine if lower emissions could have been responsible for the significant drop in the 2009 

99th % 1-hour SO2 concentrations at the Marshall County monitor.

Not all emissions sources within 50 km of the Marshall County monitor are included in the 

CAMD database; only four sources within 50 km of the Marshall County monitor reported their 

SO2 emissions to the CAMD database, including two sources located in Ohio. These sources 

and their reported annual emissions are listed in Table 7 along with their distance from the 

Marshall County monitor.

Table 7. CAMD 2008-11 Emissions Summary of SO2 Emissions in tpy

Facility County Distance*

CAMD2008CAMD2009CAMD2010CAMD2011

R.E. Burger Plant Belmont 2.4 15,126 5,988 12,719

Not 

available

OH Power -

Kammer Plant Marshall 10.6 32,044 16,756 14,127 16,712

OH Power -

Mitchell Plant Marshall 11.8 3,019 3,173 4,448 4,518

Cardinal Power 

Plant Jefferson 38.1 32,497 34,751 32,522 25,116

* Distance from Marshall County, WV SO2 monitor in kilometers.

SO2 emissions at the four CAMD sources show some interesting patterns. The Cardinal and 

Mitchell power plants have had relatively stable emissions between 2008 and 2010 but emissions 

at the Cardinal plant showed a decrease in 2011. CAMD emissions at the Kammer Power Plant 

have declined by about 50%. The R.E. Burger power plant had a significant drop (over 50%) in 

emissions in 2009. This drop in emissions seems to be responsible for the sudden decline in SO2

monitoring levels in 2009. This conclusion is based on the CAMD emission trends and the 

relatively short distance between the facility and the Marshall County monitor. It also appears 

that the R.E. Burger Plant is the primary source impacting the Marshall County monitor.

Emissions Controls

Under this factor, the existing level of control of emission sources is taken into consideration. 

The emissions data used by EPA in this technical analysis represents emissions levels while 

accounting for any control strategies implemented on stationary sources in the Wheeling, WVOH Nonattainment Area up to and including 2008. Although EPA has not received any 

additional information on emissions reductions resulting from controls put into place after 2008, 

EPA has evaluated additional information from the 2008 NEI and CAMD. 
22

Two sources (Cardinal and Mitchell power plants) have recently installed FGD units on them. 

Additionally, two sources (R.E. Burger and Kammer Power Plants) have planned to shut down

portions of or all of their coal units. If the R.E. Burger Power Plant shuts down its coal units, 

based on monitoring trends and the CAMD information reviewed here, it is quite probable that 

the monitor in Marshall County will no longer detect violations of the 1-hour SO2 NAAQS.

Meteorology (weather/transport patterns)

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

values at violating monitors is another important factor in determining the appropriate 

contributing areas and the appropriate extent of the nonattainment area boundary. For this factor, 

EPA considered data from sites that collected hourly averaged wind measurements including 

wind direction and speed for 5 years. There appears to only be one ASOS and one rawinsonde 

site located near the violating monitor in Marshall County. The closest surface site is the 

Wheeling/Ohio County Airport approximately 30 kilometers north of the Marshall County 

monitor. A rawinsonde site is located at the Pittsburgh International Airport located 

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

Wheeling/Ohio County Airport site was downloaded and run through AERMOD’s preprocessor 

AERMINUTE to produce hourly averaged wind fields. This data was then run through Lakes 

Environmental’s WRPLOT software to produce wind roses for the Wheeling, Ohio County 

Airport, the surface site nearest the Marshall County monitor.

 

 Figure 13.
23

The wind rose indicates that at the Wheeling/Ohio County Airport, the prevailing surface winds 

are predominantly out of the southwest and west. Given this information, the sources west and 

southwest of the violating monitor, particularly those within close proximity of the violating 

monitor, are likely to have the greatest impact on the violating monitor in Marshall County. EPA 

is not prepared to conclude that sources north and east (ie. Cardinal Power Plant and Consol PA 

Coal Co LLC/Bailey Prep Plant) are likely to contribute to the violating monitor in Marshall 

County.

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

Figure 14 below depicts elevations and locations of point sources near Marshall County. 

Marshall County lies on the eastern side of the Ohio River. The county’s elevated terrain 

contrasts with the lower elevations of the Ohio River and its tributaries that pass through the 

county. This creates sharp differences in elevation with the Ohio River sitting just under 200 

meters above mean sea level and the adjacent mountains often exceeding 350 meters. Nearly all 

of the point sources within 50 kilometers of the Marshall County monitor lie along the Ohio 

River. Although the surface meteorological site reviewed in the previous section may be located 

at a somewhat higher elevation than most of the point sources, the difference in elevation is not 

significant enough where it is likely that there would be substantial differences in wind patterns 

between the two locations. Therefore, local dispersion patterns are likely predominantly from 

the southwest/west as well and sources located southwest and west of the monitor are likely to 

contribute to nonattainment in Marshall County.

 Figure 14.
24

Jurisdictional boundaries 

There is no existing nonattainment/maintenance boundary for the previous 1971 primary SO2

NAAQS for the Wheeling, WV-OH Nonattainment Area. However, there are other possible 

boundaries that can be considered: the Wheeling, WV-OH MSA and the Steubenville-WeirtonWheeling AQCR. The Wheeling, WV-OH MSA contains Marshall County and Ohio County, 

WV along with Belmont County, OH. The Steubenville-Weirton-Wheeling AQCR consists of 

Hancock, Brooke, Ohio, and Marshall Counties in West Virginia along with Columbiana, 

Jefferson, Belmont and Monroe Counties in Ohio.

The Wheeling, WV-OH MSA lies within the 50 kilometer buffer extending from the Marshall 

County monitor. Drawing the nonattainment boundary along the Wheeling, WV-OH MSA 

would bring in several sources identified in the emissions screening analysis presented earlier 

and the nonattainment monitor located in Belmont County, OH. Although this boundary is a 

viable option for the nonattainment area boundary, using this boundary would bring small 

sources (less than 100 tpy) into the nonattainment area that EPA is not prepared to conclude are 

likely to be contributing to the violating monitor in Marshall County. For these reasons, it would 

be practical to only initially include the portions of Belmont County which contain the large 

sources contributing to the violating monitor in Marshall County in the nonattainment area.

 Figure 15.

The Steubenville-Weirton-Wheeling Interstate AQCR, codified in the Code of Federal 

Regulations (CFR) § 81.33, is another possible nonattainment boundary. The area is much larger 
25

than the Wheeling, WV-OH MSA and includes eight counties, four each in Ohio and West 

Virginia. The Steubenville-Weirton-Wheeling Interstate AQCR includes sources which EPA is 

not prepared to conclude are likely to contribute to the violating monitor in Marshall County. 

For this reason, it would not be practical to use the AQCR as the initial nonattainment boundary 

based on the violating monitor.

Figure 16.

Conclusion for the Wheeling, WV-OH Nonattainment Area

After considering the factors described above, EPA intends to find that the appropriate initial 

boundary for the Marshall County, WV location with the violating monitor is a multi-state 

nonattainment area consisting of Marshall County, WV and a portion of Belmont County, OH as 

identified in Table 1 with area name Wheeling, WV-OH Nonattainment Area for the 2010 SO2

NAAQS. 

The air quality monitor in Marshall County, WV shows a violation of the 2010 SO2 NAAQS, 

based on certified 2009-2011 air quality data. Belmont County, OH is a nearby area with 

sources that EPA finds likely to contribute to the SO2 concentrations in Marshall County. The 

monitor in Marshall County shows high concentrations of SO2 emissions in the vicinity. 

Meteorological data suggests that emissions from large sources southwest/west of the monitor 

(located in both Marshall County, WV and Belmont County, OH) likely impact the monitor and 

contribute to SO2 NAAQS violations in Marshall County. Available emissions data further 

suggests that the large sources most likely contributing to nonattainment in Marshall County are 
26

those nearest (for example, the R.E. Burger Plant) the violating monitor in Marshall County. 

Based on the consideration of all the relevant and available information, as described above, 

EPA believes that the boundaries described herein encompass the appropriate initial 

nonattainment area indicated by the violating monitor in Marshall County. 

Figure 17.

EPA’s Area Designations Conclusion for West Virginia

EPA has reviewed the information above and intends to find that it is appropriate to initially 

designate based on violating monitors the counties and/or portions of counties listed in Table 1 

as nonattainment for the 2010 SO2 NAAQS. EPA intends to designate Brooke and Marshall

Counties (see Table 1), as nonattainment after considering the factors and information described 

in this technical support document. The nonattainment area boundaries that EPA describes 

above are based on the five factors which include: air quality data, emissions-related data, 

meteorology, geography/topography, and jurisdictional boundaries. Based on the consideration 

of all the relevant and available information, as described above, EPA believes that the 

boundaries described herein encompass sufficient initial areas that do not meet (or that contribute 

to ambient air quality in a nearby area that does not meet) the 2010 SO2 NAAQS based on the 

monitored violations.