# - dep

west virginia department of environmental protection

Executive Office 601 57th Street SE Charleston, WV 25304

Mr. Shawn M. Garvin (3RAOO) Regional Administrator US EPA Region 3 1650 Arch Street Philadelphia, PA 19103-2029 June 8, 2012 Earl Ray Tomblin

, Governor Randy C. Huffman

, Cabinet Secretary www.wvdep.org



### Re: Redesignation Request and Maintenance Plan for the West Virginia Portion of the Steubenville, OH-WV 2006 PM 2

. 5 

### Nonattainment Area

Dear Administrator Garvin:

The State of West Virginia is requesting that EPA redesignate the West Virginia portion of the Steubenville-Weirton, OH-WV 2006 PM 25 Nonattainment Area to attainment pursuant to the provisions of the Clean Air Act, Section 107. The State is also requesting that EPA concurrently
approve , as a revision to the State Implementation Plan (SIP), the related CAA, Section 175A maintenance Plan which demonstrates that the area will continue to maintain the PM 25 air quality standards for at least ten more years.

The request is detailed in the enclosed hardcopy: Redesignation R e quest and Maintenance Plan for the West Virginia Portion oft he Steubenville-Weirton, OH-WV 2006 P M 2

. 5 No nattainment Area and the supporting documentation is provided in electronic format

, on the enclosed compact discs. We certify that the electronic copies include exact duplicates of the hard copy. The electronic cop ies also furnish additional information which has not been presented in hardcopy form. We certify that the public hearing required by 40 CFR §51.1 02(a) was held in accordance with the applicable state laws and the requirements of 40 CFR §51.1 02( d). EPA and the state of Ohio were notified at the beginning of the public comment period. Please contact John Benedict, Director

, Division of Air Quality at (304) 926-0462

, if you have any questions or need additional information.

E nclosur e s

cc: Diana Es her (3APOO) John Benedict Sincerely

,

Randy C. Cabinet Secretary

Promoting a healthy environment.west virginia department of environmental protection



# REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE WEST VIRGINIA PORTION OF THE STEUBENVILLE-WEIRTON, OH-WV

2006 PM 2.5 

# NONATTAINMENT AREA

FINAL June 2012

Promoting a healthy environment.Page intentionally left blank.

Page iiTable of Contents

I. INTRODUCTION

..................................................... Page 1 A. Request . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 1 B. Background

....................................................... Page 1 C. Geographic Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 3

II. REDESIGNATION CRITERIA

.......................................... Page 4 A. The Weirton Area has attained the 2006 PM 2.5 Standard . . . . . . . . . . . . . . . . . . . . Page 4 B. The Weirton Area has a Fully Approved SIP Under Section 110(k) of the CAA . Page 10 C. The Weirton Area’s Air Quality Improvement is Due to Permanent and Enforceable Emissions Reductions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 11 D. The State has Developed a Maintenance Plan for the Weirton Area Which Ensures Attainment of the 2006 PM 2.5 Standard for at least 10 Years . . . . . . . . . . . . . . . . Page 11 E. The Weirton Area Has Met All Relevant Requirements under CAA Section 110 and Part D............................................................... Page 12 1. Section 110(a) requirements

...................................... Page 12 2. Section 172(c) requirements

...................................... Page 13 3. Conformity

.................................................... Page 13

III. MAINTENANCE PLAN

............................................ Page 14 A. PM 2.5 Emissions Demonstrations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 19 B. NO
x Emissions Demonstrations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 21 C. SO 2 Emissions Demonstrations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 23 D. Summary of PM 2.5 , NO
x , and SO 2 Emission Reductions . . . . . . . . . . . . . . . . . . . . Page 25 E. Air Quality Improvement is Based on Permanent and Enforceable Emission Reductions

................................................................ Page 26 F. Emissions Tracking . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 27

IV. TRANSPORTATION ANALYSIS

...................................... Page 28 A. Onroad Emission Estimations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 28 B. Onroad Mobile Emissions Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 29 C. Emissions Model . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 30 D. Temperature and Relative Humidity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 30 E. Onroad Mobile Emission Estimations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 32

V. CONTROL MEASURES AND REGULATIONS

........................... Page 39 A. Reasonably Available Control Measures (RACM) and Reasonably Available Control Technology (RACT)

............................................... Page 39 B. Inventory of Actual Emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 40 C. Evidence that control measures required in past PM 2.5 SIP revisions have been fully implemented. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 40 1. NO
x SIP Call, CAIR and CSAPR

.................................. Page 40

Page iii Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance Plan2. Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards

.... Page 42 3. Heavy-Duty Diesel Engines

....................................... Page 42 4. Clean Air Non-road Diesel Rule

................................... Page 42 D. Assurance that existing control measures will remain in effect

.............. Page 42

VI. SUPPLEMENTAL MODELING ANALYSES

.......................... Page 43 A. EPA Modeling for the Cross State Air Pollution Rule (Final Transport Rule) . . . Page 43 B. EPA Modeling for Proposed Transport Rule 2010

........................ Page 45

VII. CONTINGENCY MEASURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 48 A. Maintenance Plan Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 48 B. Corrective Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 48 1. Warning Level Response

......................................... Page 48 2. Action Level Response

.......................................... Page 48 3. Control Measure Selection and Implementation

....................... Page 49 C. Potential Contingency Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 49 D. PM 2.5 , SO 2 , and NO
x sources potentially subject to future additional control requirements.

................................................................ Page 49

VIII. PUBLIC PARTICIPATION

......................................... Page 50

IX. CONCLUSIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 51

Page iv Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanList of Tables

Table 1: Weirton Nonattainment Area Design Values for the 2006 Annual and 24-hr PM 2.5 NAAQS

............................................................. Page 6 Table 2: Reductions in SO 2 and NO
x EGU Emissions Between 2008 and 2010

........ Page 16 Table 3: Brooke County, WV PM 2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 19 Table 4: Hancock County, WV PM 2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 20 Table 5: Jefferson County, OH PM 2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 20 Table 6: Weirton Nonattainment Area PM 2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy)

.......................................................... Page 21 Table 7: Brooke County, WV NO
x Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 21 Table 8: Hancock County, WV NO
x Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 22 Table 9: Jefferson County, OH NO
x Emission Inventory Totals for 2005, 2008, and 2015 and 2025 (tpy)

........................................................... Page 22 Table 10: Weirton Nonattainment Area NO
x Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy)

........................................................... Page 23 Table 11: Brooke County, WV SO 2 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 23 Table 12: Hancock County, WV SO 2 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 24 Table 13: Jefferson County, OH SO 2 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 24 Table 14: Weirton Nonattainment Area SO 2 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy)

........................................................... Page 25 Table 15: West Virginia Portion of the Weir ton Area Comparison of 2008 attainment year and 2015 and 2025 projected emission estimates (tpy)

........................... Page 25 Table 16: Ohio Portion of the Weirton Area Comparison of 2008 attainment year and 2015 and 2025 projected emission estimates (tpy)

................................... Page 25 Table 17: Weirton Area Comparison of 2008 attainment year and 2015 and 2025 projected emission estimates (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 26 Table 18: Weirton Area Comparison of 2005 Base Year and 2008 Attainment Year Reductions by Sector . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 27 Table 19: MOVES Inputs

................................................. Page 31 Table 20: Brooke County, WV Emissions Estimations for Onroad Mobile Sources

.... Page 32 Table 21: Hancock County, WV Emissions Estimations for Onroad Mobile Sources . . . Page 32 Table 22: Summary of West Virginia Emissions Estimations for Onroad Mobile Sources

................................................................... Page 32 Table 23: Jefferson County, OH Emissions Estimations for Onroad Mobile Sources . . . Page 33Table 24: Emissions Estimate Totals for the Onroad Mobile Source Sector for the SteubenvilleWeirton, OH-WV Area

................................................ Page 33

Page v Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanTable 25: Percentage of Steubenville-Weirton, OH-WV Emissions Attributable to Mobile Sources in 2005, 2008, 2015 and 2025

.................................... Page 34 Table 26: CSAPR 24-Hour PM 2.5 Design Values (μg/m3) . . . . . . . . . . . . . . . . . . . . . . . . Page 44 Table 27: Proposed Transport Rule 24-Hour PM 2.5 Design Values (μg/m3) . . . . . . . . . . Page 46

Page vi Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanList of Figures

Figure 1: Map of the Steubenville-Weirton, OH-WV nonattainment area and monitor locations

.................................................................... Page 5 Figure 2: West Virginia 24-Hou PM 2.5 Design Values, 1999-2001 through 2008-2010. . . Page 8 Figure 3: Ohio 24-Hour PM 2.5 Design Values, 1999-2001 through 2007-2009.

........ Page 9 Figure 4: PM 2.5 Annual Mean National Trends

................................ Page 10 Figure 5: Analysis of Exceedances by Quarter

................................. Page 15 Figure 6: Steubenville-Weirton, OH-WV non-attainment area

.................... Page 28 Figure 7: Steubenville-Weirton, OH-WV NAA NO
x Emissions by Sector . . . . . . . . . . . Page 36 Figure 8: Steubenville-Weirton, OH-WV NAA PM 2.5 Emissions by Sector . . . . . . . . . . Page 36 Figure 9: Steubenville-Weirton, OH-WV NAA SO 2 Emissions by Sector . . . . . . . . . . . Page 37 Figure 10: Onroad NO
x Emissions Tons per Year . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 38

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Page viii Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanList of Appendices

Appendix A: Air Monitoring Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page A - 1

Appendix B: Emissions Inventory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page B - 1

Appendix C: On-Road Mobile Emissions Inventory Documentation . . . . . . . . . . . . . Page C - 1

Appendix D: LADCO Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page D - 1

Appendix E: Federal Consent Decrees and State Consent Orders . . . . . . . . . . . . . . . Page E - 1

Appendix F: Public Participation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page F - 1

Appendix G: Jefferson County, Ohio Emissions Inventory Summary . . . . . . . . . . . . Page G - 1

Appendix H: Redesignation Request and Maintena nce Plan for the Ohio Portion of the Steubenville-Weirton OH-WV 24-Hour PM2.5 Nonattainment Area, Jefferson County, Ohio . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page H - 1

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Page x Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanREDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE WEST VIRGINIA PORTION OF THE STEUBENVILLE-WEIRTON, OH-WV 2006 PM 2.5 NONATTAINMENT AREA

I. INTRODUCTION

The Steubenville-Weirton, OH-WV PM 2.5 nonattainment area (Weirton area) is a multi-state nonattainment area, comprising Brooke and Hancock Counties in West Virginia, and Jefferson County in Ohio. The area monitored atta inment of the 2006 fine particle (PM 2.5 ) standard with a 24- hour design value for 2008-2010 of 31 μg/m 3 , and 2009-2011 of 29 μg/m 3 . The State of West Virginia herein requests redesignation by the Unite d States Environmental Protection Agency (EPA) of Brooke and Hancock Counties to attainment relative to the 2006 PM 2.5 National Ambient Air Quality Standard. The State of Ohio also plan s to request redesignation of Jefferson County, Ohio to attainment relative to the 2006 PM 2.5 National Ambient Air Quality Standard.

A. Request

The State of West Virginia is requesting that the EPA redesignate the West Virginia Portion of the Steubenville-Weirton, OH-WV 2006 PM 2.5 Nonattainment Area to a ttainment pursuant to the provisions of the Clean Air Act, section 107. The State is also requesting that EPA concurrently approve the associated maintenance plan as a revision to the State Implementation Plan (SIP), meeting the requirements of Clean Air Act, section 175A, which demonstrates that the area will continue to meet the current PM 2.5 air quality standards for at least ten more years.

B. Background

On October 17, 2006, based on its review of the air quality criteria and NAAQS for PM 2.5 , EPA revised the primary and secondary NAAQS to provide increased protection of public health and welfare. With regard to the primary standards for PM 2.5 EPA revised the level of the 24-hour standard to 35 μg/m 3 , and retained the level of the annual standard at 15 μg/m 3 . With regard to the secondary standard, EPA revised the existing 24-hour PM 2.5 standard by making it identical to the revised 24- hour primary standard, retaining the annual PM 2.5 and 24-hour PM 10 secondary standards, and revoking the annual PM 10 secondary standard.

On November 13, 2009, EPA promulgated the initial PM 2.5 nonattainment areas designations for the PM 2.5 standards across the country for the 2006 24-hour PM 2.5 NAAQS, with an effective date of December 14, 2009 [74 FR 58688]. The basis for establishing these areas as nonattainment was monitored air quality for 2006-2008 indicating a violation of the NAAQS. The CAA Amendments require states with PM 2.5 nonattainment areas to submit a plan w ithin three years of the effective date of the designations (December 14, 2009) detailing how the PM 2.5 standards would be attained by December 14, 2012.

Page 1 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanTwo areas in West Virginia were included in the initial PM 2.5 nonattainment area designations:

• Charleston, WV – Kanawha and Putnam Counties – with a 2006 - 2008 design value of 36 μg/m 3 ; and

• Steubenville-Weirton, OH-WV – Brooke and Hancock Counties in West Virginia and Jefferson County in Ohio – with a 2006 - 2008 design value of 41 μg/m 3

. The Clean Air Act (CAA) requires areas failing to meet a National Ambient Air Quality Standard (NAAQS) to develop State Implementation Plans (SIPs) to expeditiously attain and maintain the standard. However, areas that attain before the re quired date may be exempt from certain otherwise applicable requirements.

On February 14, 2011, West Virginia requested that EPA make a formal finding, based on 2008-2010 data, that the two areas are attaining the 2006 PM 2.5 NAAQS.

On October 4, 2011 [76FR61291], EP A proposed to determine that the two-state SteubenvilleWeirton, OH-WV nonattainment area has clean data for the 2006 PM 2.5 NAAQS. The proposed determination is based upon quality assured, quality controlled, and certified ambient air monitoring data showing that the area has m onitored attainment of the 2006 PM 2.5 NAAQS based in the 2008- 2010 data available in EPA’s Air Quality System (AQS) database.

On March 2, 2012, Stephen Page, Dir ector of EPA’s Office of Air Quality Planning and Standards (OAQPS) issued Implementation Guidance for the 2006 24-Hour Fine Particle (PM 2.5 ) National Ambient Air Quality Standards (NAAQS) . This memorandum provides guidance regarding the development of state implementation plans (SIPs) to demonstrate attainment with the 2006 24-hour PM 2.5 NAAQS.

The Weirton area has previously been subject to nonattainment area rulemakings for the 1997 PM 2.5 NAAQS.

The EPA revised the NAAQS for particulate matter 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 “coarse” standard protecting welfare. The 1997 PM 2.5 standards include an annual standard set at 15.0 micrograms 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 1997 PM 2.5 NAAQS were legally challenged in the U. S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit). On May 14, 1999, the D.C. Circuit remanded, without vacatur, the standard back to EPA. The remand did not que stion the level at which EPA set the standards but rather the constitutionality of the CAA provision that authorizes EPA to set national air quality standards. EPA requested a reh earing which the D.C. Circuit denied. Therefore, in December 1999, EPA appealed the D.C. Circuit decision to the U.S. Supreme Court. The U.S. Supreme Court issued a decision on February 27, 2001 that unanimously affirmed the constitutionality of the CAA

Page 2 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance Planprovision but did remand several other issues back to the D.C. Circuit, including the issue of whether EPA acted arbitrarily and capriciously in establishing the specific levels of the standards.

The D.C. Circuit heard arguments in this rema nded case in December 2001, and issued its decision on March 26, 2002. The court rejected the claims that the EPA had acted arbitrarily and capriciously in setting the levels of the standards.

On December 17, 2004, EPA promulgated the initial 1997 PM 2.5 nonattainment areas designations for the PM 2.5 standards across the country. Modifications to those designations were made and an effective date was set at April 5, 2005. Unlike Subpart 2 of the CAA Amendments of 1990 which defined five ozone nonattainment classifications for the areas that exceed the NAAQS based on the severity of the ozone levels, PM 2.5 nonattainment designations are simply labeled “nonattainment.” The CAA Amendments required 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 would be attained by April 5, 2010.

On June 24, 2009, West Virginia submitted an attainment demonstration for the WeirtonSteubenville, WV-OH area as a revision to the Stat e Implementation Plan to meet the obligations under the Clean Air Act and the Federal Clean Air Fine Particle Implementation Rule.

On September 14, 2011 [76 FR 56641] EPA determined that the Steubenville-Weirton, OH-WV area had attained the 1997 PM 2.5 NAAQS (Clean Data Determination). This determination was based on complete, quality-assured and certified ambient air monitoring data for the three year periods, 2007- 2009 and 2008-2010. EPA also determined, in accordance with EPA’s PM 2.5 Implementation Rule of April 25, 2007 [72FR20664], that the area had attained the 1997 annual PM 2.5 NAAQS by the applicable attainment date of April 5, 2010. This determination suspended the state’s requirement to submit an attainment demonstration, Reasonably Available Control Measures (RACM), including Reasonably Available Control Technology (RACT) , Reasonable Further Progress (RFP) plan, contingency measures, and other planning SIP revisions related to attainment of the 1997 PM 2.5 NAAQS for so long as the area continues to attain the 1997 PM 2.5 NAAQS.

On March 2, 2012, West Virginia proposed that EPA redesignate the West Virginia portion of the Weirton-Steubenville, WV-OH 1997 PM 2.5 Nonattainment Area to attainment pursuant to the provisions of the Clean Air Act, Section 107. The St ate also proposed that EPA concurrently approve, as a revision to the SIP, the related CAA, Sec tion 175A maintenance plan which demonstrates that the area will continue to meet the 1997 PM 2.5 air quality standards for at least ten more years.

C. Geographic Description

The Steubenville-Weirton, OH-WV PM 2.5 nonattainment area (Weirton area) is a multi-state nonattainment area, comprising Brooke and Hancock Counties in West Virginia, and Jefferson County in Ohio. This area is shown in Figure 1 under Section II.A.

Page 3 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanII. REDESIGNATION CRITERIA

Pursuant to Section 107(d)(3)(E) of the CAA states must sufficiently address five issues to obtain redesignation of a nonattainment area to attainment:

A. determinate that the area has attained the applicable NAAQS; B. have a fully approved implementation plan under CAA section 110(k); C. show that the improvement in air quality is due to permanent and enforceable emission reductions; D. submit an EPA approvable maintenance plan which ensures attainment of the NAAQS for at least ten years beyond redesignation; and E. show that the area has met the applicable requirements of CAA section 110 and part D.

The State of West Virginia herein affirmatively comp letes all five of the required elements as detailed below.

A. The Weirton Area has attained the 2006 PM 2.5 Standard [See Appedix A]

The following information is taken from EPA’s “Guideline on Data Handling Conventions for the PM NAAQS,” U.S. EPA-454/R-99-008, April 1999.

In accordance with the CAA Amendments, three comp lete years of monitoring data are required to demonstrate attainment at a monitoring site.

The 24-hour PM 2.5 primary and secondary ambient air quality standards are met when the three-year average of the 98 th percentile values for PM 2.5 at each monitoring site is less than or equal to 35 μg/m 3 . While calculating design values for 24-hour average PM 2.5 concentrations one decimal place must be carried in the computations, with final results rounded to the nearest 1 μg/m 3 . Decimals 0.5 or greater are rounded up, and those less than 0.5 are rounded down, so that 35.49 μg/m 3 is the largest concentration that is less than or equal to 35 μg/m 3 . Values at or below 35 μg/m 3 meet the standard; values greater than 35 μg/m 3 exceed the standard. An individual site’s 3-year average of the 98 th percentile values is also called the site’s design va lue. The air quality design value for the area is the highest design value among all sites in the area.

The annual PM 2.5 primary and secondary ambient air quality standards are met when the three-year average of the annual aver age is less than 15.0 μg/m 3 . While calculating design values, three significant digits must be carried in the computations, with final values rounded to the nearest 0.1 μg/m 3 . Decimals 0.05 or greater are rounded up, a nd 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 individual site’s 3-year average of the annual averag e concentrations is also called the site’s design value.

Page 4 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanThere are five (5) monitors measuring PM 2.5 concentrations in the Weirton, OH-WV nonattainment area. Three (3) monitors are located in West Virg inia and operated by the West Virginia Division of Air Quality (DAQ). Two (2) of the monitors are located in Ohio and operated by the Ohio Environmental Protection Agency (OEPA). The location of the monitoring sites for this nonattainment area are shown in Figure 1. A listing of the design values based on the three-year average of the annual mean concentrations from 2001-2003 through 2009-2011 for the West Virginia monitors is shown in Table 1. The data for all five monitors is located in Appendix A.

The data in Appendix A has been quality a ssured, up through 2011 in accordance with 40 CFR 58.10 and all other federal requirements. The data has b een recorded in the AQS database and, therefore, the data are available to the public. Table 1 shows the monitoring data for 2001-2011 that were retrieved from the EPA AQS.

Figure 1: Map of the Steubenville-Weirton, OH-WV nonattainment area and monitor locations

Page 5 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanTable 1: Weirton Nonattainment Area Design Values for the 2006 Annual and 24-hr PM 2.5 NAAQS
2006 NAAQS 24 hr 3 yr 98% = 35 2006 Annual NAAQS = 15

FRM Site 01

- 03 02

- 04 03

- 05 04

- 06 05

- 07 06

- 08 07

- 09 08

- 10 09

- 11 01

- 03 02

- 04 03

- 05 04

- 06 05

- 07 06

- 08 07

- 09 08

- 10 09

- 11

54- 009- 0005 42 44 42 40 37 37 34 31 27 16.8 16.5 16.8 16.4 16.4 15.4 14.4 13.7 13.0

54- 009- 0011 46 47 45 43 44 41 37 31 29 16.2 15.8 16.4 15.7 16.1 14.9 14.0 13.1 11.6

54- 029- 1004 45 44 41 40 41 36 35 31 28 17.4 17.0 16.6 15.4 15.2 14.3 13.4 12.4 11.7

39- 081- 0016 * 44 --- --- --- --- --- --- --- --- 17.8 --- --- --- --- --- --- --- ---

39- 081- 0017 a --- --- 42 40 40 37 34 30 28 --- --- 15.8 15.4 15.5 14.8 14.2 13.0 12.5

39- 081- 1001 43 45 46 43 38 34 31 28 24 17.8 16.9 17.2 16.3 16.1 14.8 13.6 12.7 11.8

Source: EPA Air Quality System (AQS); http://www.epa.gov/ttn/airs/airsaqs/index.htm Notes: Green shading indicates meeting the standa rd, all monitors in the area monitor attainment. Pale green shading indicates that the mon itor did not meet the completeness criteria.

* The Steubenville, Ohio monitor (039-081-0016) was moved in 2003 and the site number was changed to 039- 081-0017

The design values calculated for the We irton area demonstrate that the 2006 PM 2.5 NAAQS has been attained. The area’s design values have trended downward as emissions have declined due to such factors as cleaner automobiles and fuels, and controls for EGUs, at the national, regional and local level. However, one monitor site in Jefferson County, Ohio (039-081-0047) did not comply with the 75% data capture requirement for the 2008-2010 and 2009-2011 periods. Specifically, the fourth quarter (October, November, and December) of 2008 had only 73% data capture. This monitoring site experienced an instrument malfunction, missing a total of eight (8) 1-in-3 day PM 2.5 FRM runs, resulting in the low percentage of data capture.

Under 40 CFR Part 50, Appendix N, the use of less than complete data may be approved by U.S. EPA considering such factors as monitoring site closures/moves, monitoring dilligence, and nearby concentrations in determining whether to use such data. However, in order to further demonstrate that this monitor has attained the standard, Ohio EP A prepared a statistical analysis of the 24-hour standard using multiple imputations. Ohio EPA ha s imputed missing values for the site and then performed an ordinary analysis as if the im puted values were real measurements. Multiple imputations use random draws from the conditional dist ribution of the target variable given the other variables. When a regression model is used for imputation, the process involves using a random residual to the “best guess” for missing values, to yi eld the same conditional variance as the original variable. Appendix E, of the Ohio Redesignation Request and Maintenance Plan for the Ohio Portion

Page 6 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance Planof the Steubenville-Weirton OH-WV 24-Hour PM 2.5 Nonattainment Area (contained in Appendix H of the West Virginia submittal), describes, and includes, the full statistical analyses performed to show that the three-year average (2008 to 2010) of the 98 th percentile 24-hour values, based on missing data imputations, is 30 μg/m 3 , well below the 35 μg/m 3 24-hour standard.

National monitoring for PM 2.5 began in 1999. There has been a clear downward trend in design values for all monitors in West Virginia and Oh io, as shown in Figures 2 and 3. Design values have also trended downward nationally, as shown in Figure 4.

On May 14, 2012 [77FR26264] EPA determined that the Steubenville-Weirton, OH-WV area has attained the 24-hour 2006 PM 2.5 NAAQS [Clean Data Determination]. This proposed determination is based upon complete, quality assured, and certified ambient air monitoring data showing that the area has monitored attainment of the 2006 PM 2.5 NAAQS based on data for the 2008-2010 monitoring period.

Preliminary PM 2.5 ambient air quality monitoring data for the recent three (3) year period 2009 through 2011, demonstrate that the air quality con tinues to meet the NAAQS for both the 2006 annual and 24-hour PM 2.5 in this nonattainment area. The NAAQS attainment, accompanied by decreases in emission levels discussed in Chapter Four, support a redesignation to attainment for the Weirton area based on the requirements in Section 107(d)(3)(E) of the CAA.

DAQ commits to continue monitoring PM 2.5 levels at the West Virginia sites indicated in Figure 1 and Table 1. DAQ will consult with EPA Region III prior to making changes to the existing monitoring network, should changes become necessa ry in the future. DAQ will continue to quality assure the monitoring data to meet the requirement s of 40 CFR 58 and all other federal requirements. Connection to a central station and updates to th e DAQ web site will provide real time availability of the data and knowledge of any exceedances. DAQ will enter all data into AQS on a timely basis in accordance with federal guidelines.

Page 7 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanFigure 2: West Virginia 24-Hou PM2.5Design Values, 1999-2001 through 2008-2010.Data Source:http://www.epa.gov/airtrends/values.html, from Excel spreadsheet: PM25dv20082010Final.xlsPage 8Weirton, WV 2006 24-Hour PM2.5Redesignation and Maintenance PlanWV24-HourPM2.5DesignValues1999-2001through2008-20105+------------------------------------------------------------------099-0100-0201-0302-04 03-05 04-06 05-0706-0807-09..,._540030003-540090005-+-540090011-*""540110006.....540291004-540330003-t-540390009-540390010-540390011..,._540391005-540490006-+-540511002-*""540550002.....540610003......540690008--1-540690010-540810002-540890001..,._54107100208-10Figure 3: Ohio 24-Hour PM2.5Design Values, 1999-2001 through 2007-2009.Data Source:http://www.epa.gov/airtrends/values.html, from Excel spreadsheet: PM25dv20082010Final.xlsPage 9Weirton, WV 2006 24-Hour PM2.5Redesignation and Maintenance Plan50454035M'E'ba30.=...::J25c..c20!;."'15105099-0100-0201-03OH24-hrPM2.5DesignValues1999-2001through2008-201002-0403-0504-0605-07200624-hrStd=35ug/m306-0807-0908-10--390030009-&-390170003--390250022--390350013--390350027390350034-&-390350038--390351002--390490024--390490025--390610041--390610042--390851001--390853002-&-390930016-390932003--390950026391030003--391130014-391130031391130032391351001391510017391510020391530017 391530023391550005391550007391650007390950028391450013Figure 4: PM 2.5 Annual Mean National Trends

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

B. The Weirton Area has a Fully Approved SIP Under Section 110(k) of the CAA

On November 13, 2009 EPA promulgated the initial PM 2.5 nonattainment area designations for the 2006 PM 2.5 standards across the country, including the Steubenville-Weirton OH-WV area. An effective date was set at December 14, 2009. 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 (December 14, 2009) detailing how the PM 2.5 standards would be attained, by December 14, 2012.

On October 4, 2011 [76FR61291]EPA proposed to de termine that the Steubenville-Weirton, OH-WV area had attained the 2006 24-hour PM 2.5 NAAQS [Clean Data Determina tion]. This proposal is based upon complete, quality assu red, quality controlled, and certified ambient air monitoring data that showed that the area monitored attainment of the 2006 24-hour PM 2.5 NAAQS during the 2008-2010 monitoring period. This Clean Data Determination when finalized will suspend the requirement for the state to submit an attainment demonstration, associated reasonably available control measures, a reasonable further progress plan, contingency measures, and other planning SIPs related to attainment of the standard for as long as the area continues to meet the 2006 PM 2.5 NAAQS.

Page 10 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanOn December 17, 2004, EPA promulgated the initial PM 2.5 nonattainment areas designations for the 1997 PM 2.5 standards across the country, including the Steubenville-Weirton, OH-WV area. Modifications to those designations were made and an effective date was set at April 5, 2005. Unlike Subpart 2 of the CAA Amendments of 1990 which defined five ozone nonattainment classifications for the areas 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 year s of the effective date of the designations (April 5, 2008) detailing how the PM 2.5 standards would be attained by April 5, 2010. The DEP submitted a revision to the SIP for the State of West Virginia to meet its obligations under the CAA and the Federal Clean Air Implementation Rule for the Steubenville-Weirton, OH-WV area on June 24, 2009. The submittal expressly addressed the pertinent requi rements of the CAA, Part D and the associated requirements of the Fine Particle Implementa tion Rule beginning at 40 CFR 51.1000. EPA notified the DEP that the SIP submittal was technically and administratively complete by letter dated November 10, 2009. On September 14, 2011, in accordan ce with Section 179(c)(1) of the CAA, EPA determined that the Steubenville-Weirton, OH-WV PM 2.5 nonattainment area had attained the 1997 annual PM 2.5 NAAQS by the applicable attainment date of April 5, 2010 [76FR56641]. This Clean Data Determination suspended the requirement for the state to submit an attainment demonstration, associated reasonably available control measures , a reasonable further progress plan, contingency measures, and other planning SIPs related to atta inment of the standard for as long as the area continues to meet the 1997 PM 2.5 NAAQS. Furthermore, on March 2, 2012 DEP submitted a proposed request to EPA to redesignate the area to attainment and concurrently approve, as a revision to the SIP, the related maintenance plan which dem onstrates that the area will continue to meet the 1997 PM 2.5 NAAQS for at least ten more years. The DE P believes that all applicable requirements under CAA section 110(k) have been met.

C. The Weirton Area’s Air Quality Improveme nt is Due to Permanent and Enforceable Emissions Reductions

Several federally enforceable control measures have been implemented during the past decade which contribute to the air quality improvement, and will continue to reduce emissions in the future. These are discussed in detail in Section V - Control Measures and Regulations.

D. The State has Developed a Maintenance Plan for the Weirton Area Which Ensures Attainment of the 2006 PM 2.5 Standard for at least 10 Years

Section 107(d)(3)(E) of the CAAA sti pulates that for an area to be redesignated to attainment EPA must approve a maintenance plan that meets th e requirements of Section 175A. A state may submit both the redesignation request and maintenance plan at the same time, and the plan adoption process, including rule-making or public hearing proceedings , may proceed on a parallel track. West Virginia is herein submitting a request to redesignate the Weirton area to attainment and is also requesting that EPA concurrently process this request and the accompanying maintenance plan.

Page 11 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanE. The Weirton Area Has Met All Rele vant Requirements under CAA Section 110 and Part D

For purposes of redesignation, a state must meet a ll requirements of Section 110 and Part D that were applicable prior to submittal of the complete redesignation request.

The March 2, 2012 Implementation Guidance for the 2006 24-Hour Fine Particle (PM 2.5 ) National Ambient Air Quality Standards (NAAQS) states:

In April 2007, the U. S. Environmental Protection Agency issued a detailed implementation rule to assist states with the development of SIPs to demonstrate attainment with the annual and 24-hour 1997 PM 2.5 NAAQS (the “2007 PM 2.5 Implementation Rule”). We believe that the overall framework and policy of the 2007 PM 2.5 Implementation Rule continues to provide effective and appropriate guidance on the EPA’s interpretation of the general statutory requirements that states should address in their SIPs. In general, the EP A believes that the interpretations of the statute in the framework of the 2007 PM 2.5 Implementation Rule are relevant to the statutory requirements for the 2006 24-hour PM 2.5 NAAQS, for which SIPs are due by December 14, 2012. . . .

Subpart 1 of Part D consists of general requireme nts applicable to all areas which are designated nonattainment based on a violation of the NAAQS. Subpa rt 4 of Part D consists of more specific requirements applicable to particulate matter (specifically to address PM 10 ). However, for the purpose of implementing the 1997 PM 2.5 standard, EPA’s Implementation Rule stated that Subpart 1, rather than Subpart 4, is appropriate for the purpose of implementing PM 2.5 [72 FR 20589].

1. Section 110(a) requirements Section 110(a) of Title I of the CAA contains the general requirements for a SIP. Section 110(a)(2) provides that the implementation plan submitted by a state must have been adopted by the state after reasonable public notice and hear ing, and that, among other things, it must include enforceable emission limitations and other contro l measures, means or techniques necessary to meet the requirements of the CAA; provide for establishment and operation of appropriate devices, methods, systems and procedures necessa ry to monitor ambient air quality; provide for implementation of a source permit program to re gulate the modification and construction of any stationary source within the areas covered by the plan; include provisions for the implementation of Part C, prevention of significant deterior ation (PSD) and Part D, NSR permit programs; include criteria for stationary source emission control measures, monitoring, and reporting; include provisions for air quality modeling; and pr ovides for public and local agency participation in planning and emission control rule developm ent. In West Virginia’s December 11, 2007, and October 1, 2009 infrastructure SIP submissions and March 18, 2010 certification, West Virginia verified that the State fulfills the requirements of Section 110(a)(2) of the Act.

Section 110(a)(2)(D) also requires State plans to prohibit emissions from within the State which contribute significantly to nonattainment or maintenance areas in any other State, or which interfere with programs under Part C to preven t significant deterioration of air quality or to achieve reasonable progress toward the national visibility goal for Federal class I areas (national

Page 12 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance Planparks and wilderness areas). In order to assist States in addressing their obligations regarding regionally transported pollution, EPA finalized CAIR to reduce SO 2 and NO
x emissions from large electric generating units (EGU). West Virginia has met the requirements of the federal CAIR to reduce NO
x and SO 2 emissions contributing to dow nwind states. On August 4, 2009, EPA approved West Virginia's CAIR progr am [74FR38536], which were found in West Virginia’s Code of State Rules at 45 CSR39, 45CSR40, and 45CSR41. On July 6, 2010, EPA proposed a replacement to the CAIR program, th e Transport Rule [75 FR 45210]. The Transport Rule, or the Cross-State Air Pollution Rule (C SAPR) as it is now called, was finalized on July 6, 2011, and published in the Federal Register on August 8, 2011 [76FR48208]. Under the CSAPR, EPA adopted Federal Implementation Plans (FIPs) for each state covered by the rule, including West Virginia. The CSAPR further assists states in addressing their obligations regarding regionally transported po llution by providing reductions in NO
x and SO 2 emissions in 2012 and 2014. On December 30, 2011 the United States Court of Appeals for the District of Columbia stayed the implementation of CSAPR, indefinitely reinstating CAIR.

2. Section 172(c) requirements Section 172(c) contains general requirements for nonattainment plans. The requirements for reasonable further progress, identification of certain emissions increases, and other measures needed for attainment will not apply for redesigna tions because they only have meaning for areas not attaining the standard. The requirements fo r an emission inventory will be satisfied by the inventory requirements of the maintenance plan. Sections III and V discuss these requirements in more detail.

3. Conformity The state must work with EPA to show that its SIP provisions are consistent with the Section 176(c)(4) conformity requirements. The redesignation request should include conformity procedures, if the state already has these procedur es in place. If a stat e does not have conformity procedures in place at the time that it submits a redesignation request, the state must commit to follow EPA’s conformity regulation upon issuance, as applicable. EPA approved West Virginia’s Transportation Conformity SIP detailing confor mity procedures effective June 2, 2008 [73 FR 24175].Section IV discusses this requirement in more detail.

Page 13 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanIII. MAINTENANCE PLAN (CAA Section 107(d)(3)(E)(iv))

Section 107(d)(3)(E) stipulates that for an area to be redesignated, EPA must fully approve a maintenance plan that meets the requirements of Section 175(A). The maintenance plan will constitute a SIP revision and must provide for ma intenance of the relevant NAAQS in the area for at least 10 years after redesignation. Section 175 (A) further states that 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 the 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.

The March 2, 2012, Implementation Guidance for the 2006 24-hour Fine Particle (PM 2.5 ) National Ambient Air Quality Standards (NAAQS) memo from Stephen Page, Director of OAQPS, states:

As mentioned earlier in this memorandum, statewide annual emission inventories are required under 40 CFR Part 51, Subpart A. We expect that for many nonattainment areas, these annual inventories will serve as an appropriate starting point for the emission inventories used for SIP devel opment. In contrast with the 1997 annual PM 2.5 NAAQS, where states rely only on annual inventories in the implementation process, the 2006 24-hour PM 2.5 NAAQS is designed to protect against peak exposures. Thus, for the 2006 24-hour PM 2.5 NAAQS, there are some circumstances in which EPA believes that seasonal inve ntories may be usef ul for SIP Planning purposes. For example, we have observed that in some nonattainment areas, all of the highest fine particle concentrations over the course of a year occur in one season.

If exceedances occur during only one s eason for each of the years on which the nonattainment designation is based, and this is the case for all subsequent years, we recommend that states develop a seasonal inve ntory and that they use this inventory for SIP planning purposes. . . .

West Virginia DAQ analyzed the PM 2.5 monitoring data for the Weirton area to determine whether the exceedances occurred in only one season. As can be seen in Figure 5 below, exceedances between 2006 and 2008, the years on which the nonattainment designation is based, occurred in the first, second, third and fourth quarters. During s ubsequent years, 2009 through 2011, exceedances have occurred in the first, third and fourth quarters. Ba sed on this analysis and in consultation with EPA and Ohio EPA, it was determined that an annual inventory would be suffici ent for SIP planning, and that a seasonal inventory would not be required.

Page 14 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanFigure 5: Analysis of Exceedances by Quarter

In consultation with EPA and Ohio EPA, West Vi rginia DAQ selected the year 2025 as the end year of the maintenance plan for this redesignation re quest. This document contains projected emissions inventories for 2015 and 2025. Although the three y ear time period 2006-2008 was the basis of the nonattainment designation, 2005 was selected as the nonattainment year, since the design value for 2005-2007 was also above the standard and a 2005 SIP quality inventory had already been developed and used for the 1997 PM 2.5 Redesignation Request and Maintenance Plan. Thus, the pertinent inventory years are: 2005 (nonattainment year), 2008 (attainment year and maintenance plan base year), 2015 (interim year) and 2025 (maintenance plan end year). Three specific emissions inventory demonstrations should be made:

1. The attainment year (2008) emissions of PM 2.5 , NO
x and SO 2 must each be less than the corresponding emissions in the nonattainment year (2005). The reductions must be attributable to federally enfo rceable emission reductions (as discussed in Section III.E and Section V).

2. The interim year (2015) emissions of each of the three pollutants should be less than the maintenance plan base year (2008).

3. The end year (2025) emissions of each of the three pollutants should be less than the maintenance plan base year (2008).

Page 15 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanAs can be seen in Table 2 below, West Virginia has seen a significant state-wide decline of the 467,081 tons of SO 2 and 159,481 tons of NO
x emitted by EGUs in 2005. In 2008 and 2009, facilities began preparing for and implementing control programs to address CAIR and consent orders. Significant reductions occurred regionally and na tionally. Data available for 2010, show the SO 2 and NO
x reductions which were implemented under CAIR.

Table 2: Reductions in SO 2 and NO
x EGU Emissions Between 2008 and 2010

SO 2 NO
x 2008 2010 % Change 2008 2010 % Change
West Virginia 301,574 106,088 -65% 97,331 51,393 -47%

Ohio 709,444 570,045 -20% 235,018 104,574 -56%

National 7,616,449 5,119743 -33% 2,996,594 2,061,062 -31% Source: Clean Air Markets, Data and Maps , Quick Reports, State Level Emissions Quick Report and Program Level Emissions Quick Report, Acid Rain Program

Further, Tables 3- 18 clearly show total emissions from all sectors decreased in the period from 2005 to 2008 in the West Virginia and Ohio portions of the nonattainment area. As outlined below, the reductions are enforceable and should continue in the future.

On March 10, 2004, EPA promulgated the CAIR. Beginning in 2009, EPA’s CAIR rule required EGUs in 28 eastern states and the District of Columbia to significantly reduce emissions of NO
x and SO 2 . CAIR replaced the NO
x SIP Call for EGUs. The intent of the CAIR program was for national NO
x emissions to 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 require d to submit a CAIR SIP as part of this effort. West Virginia DEP submitted a CAIR SIP to EP A on June 1, 2006. Revisions to the CAIR SIP were submitted on April 22, 2008. The revised CAIR SI P was approved on August 4, 2009 (74 FR 38536). As a result of CAIR, EPA project ed that in 2009 emissions of NO
x would decrease from a baseline of 179,000 tons per year to 63,000 tons pe r year while in 2010 emissions of SO 2 would decrease from a baseline of 582,000 tons per year to 250,000 tons per year, within West Virginia. And by 2015, EPA projected emissions of NO
x would decrease to 44,000 tons per year while emissions of SO 2 would decrease to 118,000 tons per year, within West Virginia.

On December 23, 2008, EPA’s CAIR program was re manded without vacatur by the D.C. Circuit Court.

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

“Based on emissions monitoring data, EPA has observed substantial reductions in emissions from 2005 to 2010 as companies installed more controls, electric demand declined, and low natural gas prices made combined-cycle gas-fi red units more competitive in several parts of the country. Thus, even after CAIR’s vacatur and subsequent remand in late 2008, the controls in place generally have continued to operate, helping to drive continued progress in
Page 16 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance Planreducing emissions. However, allowance prices of SO 2 have been relatively low since 2008, raising concerns that coal-fired units could burn dirtier fuels, operate scrubbers at reduced efficiency, or even bypass scrubbers altogether, instead relying on banked allowances (because there is not an existing large bank of NO
x allowances, NO
x allowance prices have not been affected as significantly). For these reasons, EPA is tracking SO 2 and NO
x emissions closely each quarter to evaluate further progress and assess whether backsliding may be occurring and, if so, where it may be taking place.” [ http://www.epa.gov/airmarkets/background.htm ]

On July 6, 2010, EPA proposed a replacement to th e CAIR program, the Transport Rule [75 FR 45210]. On July 6, 2011, EPA finalized the Transport Rule, now commonly referred to as the CrossState Air Pollution Rule (CSAPR) [76 FR 48208, 08 AUG 2011] in time for reductions to begin in 2012. As finalized, the CSAPR will preserve the initial reductions achieved under CAIR and provide more reductions in NO
x and SO 2 emissions in 2012 and 2014, ahead of the 2015 CAIR Phase 2.

West Virginia DAQ is in agreement with the anal ysis by U.S. EPA that th e CAIR program provided real reductions. We believe these reductions have assisted with PM 2.5 attainment in this nonattainment area and throughout West Virginia. It is also the DAQ’s belief that the CSAPR will continue to provide the necessary reductions, and likely even greater reductions, that will be necessary for maintenance of the annual PM 2.5 standard to continue. As stated by EPA regarding the final Transport Rule or CSAPR:

This rule will prohibit all significant contribution to nonattainment and interference with respect to the annual and 24-hour PM 2.5 . In addition, it will resolve air quality issues at most nonattainment and maintenance receptors iden tified by EPA. EPA projects that unresolved nonattainment and maintenance issues will remain in only a few downwind states after promulgation and implementation of the Transport Rule. For the annual PM 2.5 standard, EPA projects that this rule will he lp assure that all areas in the east fully resolve their nonattainment and maintenance concerns. This ru le will also help a number of areas achieve the standard earlier than they may have otherwise. [76 FR 48247]

However, on December 30, 2011 the United States Court of Appeals for the District of Columbia stayed the implementation of CSAPR, indefinitely reinstating CAIR.

Although there are no electric generating units in the West Virginia portion of the SteubenvilleWeirton, OH-WV area, the DAQ believes that CA IR, or any likely replacement for CAIR, will constrain nearby EGU NO
x and SO 2 emissions sufficiently to ensure that maintenance level emissions are not exceeded during the maintenance period.

As shown in Section VI - Supplemental Modeling Analyses, recent modeling -- CAIR, proposed Transport Rule, CSAPR (Final Transport Rule), including base cases where CAIR and CSAPR were not considered to be applicable requirements, and the VISTAS/ASIP modeling (which includes CAIR) -- all show that the Steubenville-Weirton, OH-WV area will continue to maintain the 2006 PM 2.5 NAAQS.

Page 17 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanEmission projections for the Weirton area were performed using the following approaches:

• Emissions inventories are required to be project ed to future dates to assess the influence of future growth and controls.

• NonEGU Point, Area, and Locomotive/Marine Source inventories for 2015 and 2025 were developed by DAQ based on the 2008 inventory using Workforce West Virginia economic forecasts (http://www.workforcewv.org/ LMI/indproj/longterm/WV.htm ). The Workforce WV projections were in terms of North American Industrial Classification System (NAICS) codes while the WV 2008 v1.5 data is in terms of S CCs. A list of SCCs contained in the 2008 WV inventory was compiled and the associated with each NAICS code for which there was a Workforce WV growth factor. Then directly proportional growth factors were calculated and applied to Workforce WV’s 2018 growth fact or to calculate 2015 and 2025 emissions. The final estimates reflect both positive and negative growth. The 2008 NEI data were downloaded from EPA’ s CHIEF webpage at http://www.epa.gov/ttn/chief/ net/2008inventory.html

. • Nonroad mobile source inventories for those categories calculated by the model were developed by DAQ personnel using monthl y NONROAD Model runs for 2015 and 2025, and summing the monthly data to obtain annual data.

• Ohio provided the emission estimates for th e Ohio portion of the area, based on LADCO developed growth and control files for Poin t, Area, and Nonroad categories. Appendix D contains LADCO’s technical support document detailing the analysis used to project emissions (Base M ) [ www.ladco.org/tech/emis/current/index.php ].

• As performed by ODOT, Onroad mobile source emission projections are based on the EPA MOVES model. The analysis is described in more detail in Appendix C. All projections were made using federally approved interagency consultation procedures. As discussed in Section IV, DAQ determined that the mobile em ission contribution as a percent of the total emission inventory from the area is not significant.

The detailed inventory information for the West Virginia portion of the Weirton area for 2005 is contained in Appendix B. Emission trends are an important gauge for continued compliance with the PM 2.5 standard. Therefore, West Virginia DAQ performed an initial comparison of the inventories for the base year and maintenance years.

Sectors included for West Virginia in the followi ng tables are: Electrical Generating Unit (EGU); Non-Electrical Generating Units including Airports (Non-EGU); Non-road Mobile (Nonroad); Other Area (Area); Locomotive and Marine (LM); and Onroad Mobile (Onroad).

Sectors included for Ohio in the following ta bles are: Electrical Generating Unit (EGU); Non-Electrical Generating Unit (Non-EGU); Non-road Mobile (Nonroad); Other Area (Area); Marine; Aircraft; Rail (MAR); and Onroad Mobile (Onroad).

Maintenance is demonstrated when the future-year (2025) projected emission totals of each of the relevant pollutants are below the 2008 attainment year totals. Page 18 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanThe West Virginia emissions data in the tables below are based on the following data sources:

• All On-Road data developed by ODOT for WWW. • 2005 and 2008 EGU and non-EGU Point Source fr om certified data submitted by industry to West Virginia DAQ’s 2005 and 2008 annual emissions inventory database and subsequently submitted to EPA. • WV Nonroad data developed by DAQ using EPA’s Nonroad Model v2008.1.0. • All other West Virginia data developed by DAQ based on Workforce WV economic projections. • All Ohio data provided by OEPA.

A. PM 2.5 Emissions Demonstrations

The 2005 and 2008 actual PM 2.5 EGU and NonEGU emissions data below reflects PM 2.5 -primary emissions. Although some facilities repor ted both PM 2.5 -pri and the PM fraction emissions, not all facilities reported PM 2.5 -pri emissions. When PM 2.5 -pri was not reported by sources, WV DAQ applied PM augmentation procedures in accordance with EPA procedures as documented in EPA’s CSAPR technical support document (TSD), “ Emissions Inventory Final Rule TSD , June 28, 2011” and discussed in more detail in Appendix B a nd with further technical support provided by EPA’s Emission Inventory and Analysis Group (EIAG).

Table 3: Brooke County, WV PM 2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy)

Sector 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin

EGU 0 00 0 0 0

NonEGU 155 167 156 11 142 25

Area 208 220 218 2 216 4

LM 17 4 4 0 4 0

Nonroad 11 9 6 3 4 6

Onroad 19 14 7 7 4 10

TOTAL 411 414 391 24 370 45

Page 19 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanTable 4: Hancock County, WV PM 2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy)

Sector 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin

EGU 0 00 0 0 0

NonEGU 182 91 84 7 75 16

Area 314 233 230 3 230 3

LM 26 18 19 0 19 0

Nonroad 10 8 6 3 3 5

Onroad 19 14 7 7 4 9

TOTAL 550 364 345 19 331 33

Table 5: Jefferson County, OH PM 2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy)

Sector 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin

EGU 1,308 1,373 1,405 133 1,450 -77

NonEGU 462 461 438 24 414 48

Area 110 111 108 2 106 5

MAR 8 75 3 1 7

Nonroad 24 23 17 5 11 11

Onroad 73 61 32 29 16 44
TOTAL 1,985 2,036 2,005 30 1,998 38

Page 20 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanTable 6: Weirton Nonattainment Area PM 2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy)
County 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin
Brooke, WV 411 414 391 24 370 45
Hancock, WV 550 364 345 19 331 33

WV PM 2.5 Total 961 778 735 43 700 78
Jefferson, OH 1,985 2,036 2,005 30 1,998 38

Combined PM 2.5 Total 2,946 2,814 2,741 73 2,698 116

B. NO
x Emissions Demonstrations

Table 7: Brooke County, WV NO
x Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy)

Sector 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin

EGU 0 00 0 0 0

NonEGU 693 790 742 48 679 110

Area 311 119 118 1 116 3

LM 445 113 114 -1 115 -2

Nonroad 205 169 88 81 59 110

Onroad 540 412 175 237 62 350
TOTAL 2,194 1,603 1,237 367 1,032 572

Page 21 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanTable 8: Hancock County, WV NO
x Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy)

Sector 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin

EGU 0 00 0 0 0

NonEGU 1,181 575 525 50 463 112

Area 1,447 158 157 1 115 3

LM 695 535 538 -3 543 -8

Nonroad 135 119 75 45 51 68

Onroad 483 360 149 211 52 308
TOTAL 3,942 1,747 1,443 304 1,264 483

Table 9: Jefferson County, OH NO
x Emission Inventory Totals for 2005, 2008, and 2015 and 2025 (tpy)

Sector 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin

EGU 41,047 35,487 19,488 15,999 12,632 22,855

NonEGU 1,992 1,992 1,939 53 1,864 128

Area 251 253 252 1 252 2

MAR 317 301 203 98 71 230

Nonroad 234 208 131 76 97 111

Onroad 2,106 1,758 870 888 323 1,435
TOTAL 45,947 39,999 22,884 17,115 15,238 24,761

Page 22 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanTable 10: Weirton Nonattainment Area NO
x Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy)
County 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin
Brooke, WV 2,194 1,603 1,237 367 1,032 572
Hancock, WV 3,942 1,747 1,443 304 1,264 483

WV NO
x Total 6,136 3,350 2,680 671 2,296 1,055
Jefferson, OH 45,947 39,999 22,884 17,115 15,238 24,761

Combined NO
x Total 52,083 43,349 25,563 17,786 17,533 25,816

C. SO 2 Emissions Demonstrations

Table 11: Brooke County, WV SO 2 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy)

Sector 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin

EGU 0 00 0 0 0

NonEGU 621 797 718 48 655 112

Area 168 164 157 7 146 17

LM 20 6 6 0 6 0

Nonroad 12 2 0 2 0 2

Onroad 7 22 1 1 1

TOTAL 828 941 883 58 809 132

Page 23 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanTable 12: Hancock County, WV SO 2 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy)

Sector 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin

EGU 0 00 0 0 0

NonEGU 1,481 613 573 40 520 93

Area 729 249 237 11 221 27

LM 32 31 32 0 32 0

Nonroad 10 2 0 2 0 1

Onroad 7 21 1 1 1
TOTAL 2,258 897 843 54 774 123

Table 13: Jefferson County, OH SO 2 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy)

Sector 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin

EGU 225,595 135,507 72,203 63,304 45,073 90,434

NonEGU 850 783 758 25 693 90

Area 111 109 102 2 92 19

MAR 26 22 13 9 0 21

Nonroad 17 3 0 3 0 3

Onroad 18 6 4 2 4 2
TOTAL 226,617 136,429 73,080 63,344 45,862 90,568

Page 24 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanTable 14: Weirton Nonattainment Area SO 2 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy)
County 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin
Brooke, WV 828 941 883 58 809 132
Hancock, WV 2,258 897 843 54 774 123

WV SO 2 Total 3,086 1,838 1,726 111 1,583 254
Jefferson, OH 226,617 136,431 73,087 63,344 45,862 90,568

Combined SO 2 Total 229,703 138,268 74,813 63,455 47,446 90,823

D. Summary of PM 2.5 , NO
x , and SO 2 Emission Reductions

Table 15: West Virginia Portion of the Weirton Area Comparison of 2008 attainment year and 2015 and 2025 projected emission estimates (tpy)

2008 Attainment 2015 Interim 2015 Projected Decrease 2025 Maintenance 2025 Projected Decrease

PM 2.5 778 735 43 700 78

NO
x 3,350 2,680 671 2,296 1,055

SO 2 1,838 1,726 111 1,583 254

Table 16: Ohio Portion of the Weirton Area Comparison of 2008 attainment year and 2015 and 2025 projected emission estimates (tpy)

2008 Attainment 2015 Interim 2015 Projected Decrease 2025 Maintenance 2025 Projected Decrease

PM 2.5 2,036 2,005 30 1,998 38

NO
x 39,999 22,884 17,115 15,238 24,761

SO 2 136,431 73,087 63,344 45,862 90,568

Page 25 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanTable 17: Weirton Area Comparison of 2008 attainment year and 2015 and 2025 projected emission estimates (tpy)

2008 Attainment 2015 Interim 2015 Projected Decrease 2025 Maintenance 2025 Projected Decrease

PM 2.5 2,814 2,741 73 2,698 116

NO
x 43,349 25,563 17,786 17,533 25,816

SO 2 138,268 74,813 63,455 47,446 90,823

As shown in the table above (Table 17), PM 2.5 emissions in the nonattainment area are projected to decrease by 73 tons in 2015 and 116 tons in 2025. NO
x emissions in the nonattainment area are projected to decrease by 17,786 tons in 2015 and 25,816 tons in 2025. SO 2 emissions in the nonattainment area are projected to decline by 63,455 tons in 2015 and 47,446 tons in 2025.

The Weirton area shows a net reduction in PM 2.5 , NO
x and SO 2 emissions, cleaner vehicles and fuels are expected to be in place in 2015 and 2025, and the CAIR Replacement Rule should be implemented by 2015 and these programs should cause an overall drop in all three pollutants emissions. Decreases from EPA rules covering Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements [65FR 6698,10FEB2000], Highway Heavy-Duty Engine Rule [62FR54694, 21OCT1997], and the Non-Road Diesel Engine Rule [63FR56968, 23OCT1998] are factored into the changes.

E. Air Quality Improvement is Based on P ermanent and Enforceable Emission Reductions

A demonstration that improvement in air quality be tween the year violations occurred and the year attainment was achieved is based on permanent and enforceable emission reductions and not on temporary adverse economic conditions or unusually favorable meteorology.

Ambient air quality data from all monitoring s ites indicate the air quality met the 2006 NAAQS for PM 2.5 in 2008-2010 and preliminary data for 2009-2011 indi cate the air quality continues to meet the NAAQS. EPA’s redesignation guidance (Policy Memo from John Calcagni, Director, Air Quality Management Division to Regional Air Directors: Air Procedures for Processing Requests to Redesignate Areas to Attainment ), dated September 4, 1992 (p. 9) states: “A state may generally demonstrate maintenance of the NAAQS by either show ing that future 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.”

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 highway heavy-duty engines (Control of Emissions of Air Pollution from Highway Heavy Duty Engines) and Nonroad diesel engines (Control of Emissions of Air Pollution from Nonroad Diesel Engines), the application of tighter federal standards on new

Page 26 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance Planvehicles (Control of Air Pollution from New Mo tor Vehicles: Tier 2 Motor Vehicle Emission Standards and Gasoline Sulfur Control Requirements), Title IV of the CAA, the NO
x SIP Call, CAIR, CSAPR, and federal consent decrees requiring reductions of SO 2 and NO
x emissions from utility sources. Reductions achieved are discussed in greater detail under Section V.

Table 18: Weirton Area Comparison of 2005 Base Year and 2008 Attainment Year Reductions by Sector

2005 2008 Decrease

EGU NO
x 41,047 35,487 5,560

EGU PM 2.5 1,308 1,373 (65)

EGU SO 2 225,595 135,507 90,088

Onroad NO
x 3,129 2,530 599

Onroad PM 2.5 111 89 22

Onroad SO 2 32 10 22

Nonroad NO
x 575 496 78

Nonroad PM 2.5 45 40 5

Nonroad SO 2 39 7 32

F. Emissions Tracking

Provisions for future annual updates of the invent ory to enable tracking of the emission levels, including an annual emission statement from major sources.

In West Virginia, major point sources in all coun ties are required to submit air emissions information annually. West Virginia DAQ prepares a new periodic inventory for all PM 2.5 precursor emission sectors every three years in accordance with EP A’s Air Emissions Reporting Requirements (AERR). These PM 2.5 precursor inventories will be prepared for fu ture years as necessary to comply with the inventory reporting requirements established in th e CFR. Emissions information will be compared to the 2005 base year and the 2025 projected maintena nce year inventories to assess emission trends, as necessary, and to assure continued compliance with the annual PM 2.5 standard.

Page 27 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanIV. TRANSPORTATION ANALYSIS

A. Onroad Emission Estimations

The air quality analyses and underlying planning assumptions were developed by the Ohio Department of Transportation (ODOT), Division of Transportation System Development-Modeling and Forecasting Section and the Brooke-Hanco ck-Jefferson Metropolitan Planning Commission (BHJMPC or BHJ), in coordinati on with the Ohio Environmental Protection Agency (OEPA) and West Virginia Department of Environmental Prot ection (WVDEP). This evaluation represents the latest population and land use data available that calibrated the modeling process used to calculate the vehicle emissions for the mobile emissions budge ts as well as the input values for U.S. EPA's most recent emissions software (MOVES) for this attainment demonstration.

The BHJ Region is comprised of the counties of Brooke and Hancock in the north panhandle of West Virginia and Jefferson in east-central Ohio. The BHJMPC serves as the Metropolitan Planning Organization (MPO). The MPO submitted the nece ssary Travel Demand Model networks along with all land use and social-economic demographics . The ODOT Modeling and Forecasting section performed the MOVES runs to generate travel de mand model based emission factors as well as the complete air quality analyses for the metropolitan area.

Figure 6: Steubenville-Weirton, OH-WV non-attainment area

Page 28 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanB. Onroad Mobile Emissions Summary

A Travel Demand Model (TDM) is the traditional fo recasting tool used to examine potential changes in future travel patterns for a specific study area, in this case the Brooke-Hancock-Jefferson Metropolitan Area. The BHJ MPO, with the assi stance of ODOT Modeling & Forecasting, maintains a validated region-wide TDM that employs a four-step modeling process consisting of trip generation, trip distribution, mode choice, and r oute assignment performed with the Cube Voyager software package. The model Outputs generate d from the TDM are link-by-link directional 24-hour traffic volumes for simulating Base Year and Horizon Year travel patterns generated by the LRTP transportation network.

The current BHJ TDM Validation Y ear is 2000. The model uses comparable Average Daily Traffic count data, updated social-economic variables fo r each of the analysis years by either updating existing or known land use commitment for 2008, 2009, and 2014, or projected 2014 and 2020 variables based on a straight-line extrapolation between 2009 set of variables and the Horizon Year 2030 variables. These networks represent all pla nned federal-aid projects as well as any regionally significant projects found in the BHJ TIP and LRTP e xpected to be open for tr affic by the end of each respective analysis year. The interagency consultati on process, as previously discussed, established the following model years for Brooke and Hancock counties, WV and Jefferson County, OH that reflected the most recent correspondence from the U.S. EPA:

Analysis Year 2005 – Baseline Emissions Analysis Year 2008 – Attainment Year (Also maintenance plan base year) Analysis Year 2015 – Interim Year Analysis Year 2025 – Maintenance Plan End Year

Identifying projected growth centers and unders tanding urban and rural population changes are essential to determine future transportation needs in a given study area. Critical elements include an understanding of the past and anticipated future shifts in the region’s economy, population, land use patterns, and other environmental factors over time. In turn, these factors are useful for predicting future transportation patterns and justify transportation improvements over the next twenty years.. Travel forecasting procedures require the user delineate the TDM study area into geographic areas called Traffic Analysis Zones (TAZ s). Typically, TAZs are based on factors such as land use, area types (urban, suburban or rural), or political government units such as cities, villages, or townships. TAZs represent centers of travel generators or a ttractors based on a set of demographic variables. The BHJ MPO collects and reviews the TDM independent variables that characterize current and future estimates of the metropolitan area’ social a nd economic activity that may influence land-use development patterns. In all, there are 376 TAZs in the BHJ model represented by 60 TAZs for Brooke County, 78 TAZs for Hancock County, and 237 TAZs for Jefferson County.

Page 29 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanC. Emissions Model

MOVES (Motor Vehicle Emissions Simulator) is a computer program designed by the EPA to estimate air pollution emissions from highway mobile sources. EPA published a Federal Register notice of availability [75 FR 9411] on March 2, 2010, to approve MOVES2010, hereafter referred to as MOVES. Upon publication of the Federal Register notice, MOVES became EPA’s approved motor vehicle emission factor model for use by state and local agencies to estimate VOCs, NO
x , CO, PM 10 and PM 2.5 and other pollutants and precursors from cars, trucks, motorcycles, and buses. MOVES replaces EPA’s previous emissions mode l, MOBILE6.2. MOVES can be used to estimate exhaust and evaporative emissions as well as brake and tire wear emissions from all types of on-road vehicles. An updated version of this software, MOVES2010a, was used for this analysis. MOVES2010a is a minor update to MOVES 2010. MOVES2010a includes general performance improvements to MOVES2010, and also allows users to account for emissions under new car and light truck energy and greenhouse gas standards.

EPA believes that MOVES should be used in oz one, carbon monoxide, PM, and nitrogen dioxide SIP development as expeditiously as 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.

The MOVES model generated the emission factor f iles for base year-2005 and attainment year-2008 representing the transportation improvement progr ams implemented in the BHJ Region. The model also generated emission factors for two future year scenarios 2015 and 2025. Table 19 summarizes the settings used in the MOVES run specification file and the MOVES County-Data Manager.

D. Temperature and Relative Humidity

Meteorological conditions, especially temperature and humidity, significantly affect on-road vehicle emissions. A series of Inter-Agency Consultation (IA C) conference calls were held during the winter of 2010/2011 which established two important conclusions, among others. First, this redesignation effort required the use of MOVES software for a ll mobile source emission analyses. And second, the annual emission estimates would be based upon a si ngle-season temperature/ humidity approach. The single season approach for temperature and relative humidity uses weather data collected by the National Oceanic and Atmospheric Administration (NOAA) National Climatic Data Center (NCDC). The data used in this report, taken from the Pittsburgh International Airport collection center, is representative of 12 months in 2009.

Other factors which may significantly affect ve hicle emissions are roadway attributes, fleet characteristics and operational conditions. The appropriate inputs for such parameters were determined through the IAC process and are detailed in Appendix C.

Page 30 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanTable 19: MOVES Inputs RunSpec Parameter Settings MOVES Version 2010/08/26 Scale Custom Domain MOVES Modeling Technique Emission Factor Method Rates per Distance, Rates per Vehicle Time Span Time Aggregation: Hour 1 Month representing average annual temperatures All hours of day selected 16 speed bins, Weekdays only Geographic Bounds Brooke, Ha ncock, and Jefferson counties Vehicles/Equipment All source types, gasoline and diesel Road Type All road types including off-network Pollutants and Processes NO
x , All PM 2.5 categories, SO 2 , Total Energy Consumption Strategies None General Output Units = grams, joules and miles

Output Emissions Time = hour, Location = custom area, on-road emission rates by road type and source use type.

County Data Manager Sources Source Type Population Combination of local and default data Local data (Ohio and West Virginia) from motor vehicle registration Default data used for source types 51, 52, 53, 61, and 62 Future year growth rate based on MPO model Household growth rate.

Vehicle Type VMT Combination of local and default data HPMSVTypeYear VMT = daily VMT from travel demand model monthVMTFraction = default dayVMTFraction=default hourVMTFraction=local I/M Program None Fuel Formulation Default Fuel Supply Default Meteorology Data Local data obtained from NOAA National Climatic Data Center Data will consist of monthly high and low temperatures and daily relative humidity for 2002. Ramp Fraction Using the base year travel demand model for VHT fractions. Road Type Distribution Use ODOT and WV Division of Highways county summary VMT categorized by federal functional classes Age Distribution Combination of local and default data. Local data (Ohio and West Virginia) from motor vehicle registration Default data used for source types 41, 42, 43, 51, 52, 53, 61, and 62 The same age distribution will be used for all analysis years

Average Speed Distribution Default Alternative Fuel Type Default

Page 31

Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanE. Onroad Mobile Emission Estimations

Tables 20 through 24 contain the results of the emissions analysis for the appropriate years. All emissions estimations are expressed in tons per year (tpy).

Table 20: Brooke County, WV Emissions Es timations for Onroad Mobile Sources

2005 2008 2015 2025

NO
x (tpy) 540.40 412.02 174.71 62.47

PM 2.5 (tpy) 19.41 14.42 6.97 4.34

SO 2 (tpy) 7.01 2.11 1.51 1.26

Annual VMT 212,244,639 212,778,859 219,881,355 216,619,184

Table 21: Hancock County, WV Emissions Estimations for Onroad Mobile Sources

2005 2008 2015 2025

NO
x (tpy) 482.75 360.25 149.00 52.09

PM 2.5 (tpy) 18.63 13.51 6.53 4.10

SO 2 (tpy) 6.58 1.92 1.36 1.10

Annual VMT 180,767,718 177,219,697 180,298,107 174,534,361

Table 22: Summary of West Virginia Emissions Estimations for Onroad Mobile Sources

2005 2008 2015 2025

NO
x (tpy) 1,023.15 772.27 323.71 114.56

PM 2.5 (tpy) 38.04 27.93 13.50 8.44

SO 2 (tpy) 13.59 4.03 2.87 2.36

Annual VMT 393,012,357 389,998,556 400,179,462 391,153,545

Page 32 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanTable 23: Jefferson County, OH Emissions Estimations for Onroad Mobile Sources

2005 2008 2015 2025

NO
x (tpy) 2,105.85 1,758.04 870.17 322.71

PM 2.5 (tpy) 73.17 60.97 31.88 16.49

SO 2 (tpy) 18.18 5.65 3.93 3.56

Annual VMT 562,071,084 557,286,295 544,597,475 572,657,778

Table 24: Emissions Estimate Totals for the Onroad Mobile Source Sector for the Steubenville-Weirton, OH-WV Area

2005 2008 2015 2025

NO
x (tpy) 3,129.00 2,530.31 1,193.88 437.27

PM 2.5 (tpy) 111.22 88.89 45.37 24.93

SO 2 (tpy) 31.77 9.68 6.79 5.91

Annual VMT 955,083,441 947,284,851 944,776,937 963,811,323

Page 33 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanThe following table shows the emissions totals, by sector, for eachcounty in the nonattainment area. For a more detailed analysis seeAppendix C.Table 25: Percentage of Steubenville-Weirton, OH-WV Emissions Attributable to Mobile Sources in 2005, 2008, 2015 and 20252005 2008 2015 2025 2005 2008 2015 2025 2005 2008 2015 2025WeirtonBrookeCo.,WV Point‐EGU 0 0 0 0 0 0 0 0 0 0 0 0BrookeCo.,WV Point‐NonEGU 693 790 742 679 155 167 156 142 621 767 718 655BrookeCo.,WV Area 311 119 118 116 208 220 218 216 168 164 157 146BrookeCo.,WV LM 445 113 114 115 17 4 4 4 20 6 6 6BrookeCo.,WV NonRoad 205 169 88 59 11 9 6 4 12 2 0 0BrookeCo.,WV OnRoad540 412 175 62 19 14 7 4 7 2 2 1BrookeCo.,WV Subtotal 2,194 1,603 1,237 1,032 411 414 391 370 828 941 883 809HancockCo.,WV Point‐EGU 0 0 0 0 0 0 0 0 0 0 0 0HancockCo.,WV Point‐NonEGU 1,181 575 525 463 182 91 84 75 1,481 613 573 520HancockCo.,WV Area 1,447 158 157 155 314 233 230 230 729 249 237 221HancockCo.,WV LM 695 535 538 543 26 18 19 19 32 31 32 32HancockCo.,WV NonRoad 135 119 75 51 10 8 6 3 10 2 0 0HancockCo.,WV OnRoad483 360 149 52 19 14 7 4 7 2 1 1JeffersonCo.,OH Subtotal 3,942 1,747 1,443 1,264 550 364 345 331 2,258 897 843 774Total 6,136 3,350 2,680 2,296 961 778 735 700 3,086 1,838 1,726 1,58316.68% 23.05% 12.08% 4.99% 3.96% 3.59% 1.84% 1.21% 0.44% 0.22% 0.17% 0.15%SteubenvilleJeffersonCo.,OH Point‐EGU 41,047 35,487 19,488 12,632 1,308 1,373 1,405 1,450 225,595 135,507 72,20345,073JeffersonCo.,OH Point‐NonEGU 1,992 1,992 1,939 1,864 462 461 438 414 850 783 758693JeffersonCo.,OH Area 251 253 252 252 110 111 108 106 111 109 10292JeffersonCo.,OH MAR 317 301 203 71 8 7 5 1 26 22 130JeffersonCo.,OH NonRoad 234 208 131 97 24 23 17 11 17 3 00JeffersonCo.,OH OnRoad2,106 1,758 870 323 73 61 32 16 18 6 44JeffersonCo.,OH Subtotal 45,947 39,999 22,884 15,238 1,985 2,036 2,005 1,998 226,617 136,429 73,080 45,8624.58% 4.40% 3.80% 2.12% 3.69% 3.00% 1.59% 0.83% 0.01% 0.00% 0.01% 0.01%OnroadSubtotal 3,129 2,530 1,194 437 111 89 45 25 32 10 7 6Total 52,083 43,349 25,563 17,533 2,946 2,814 2,741 2,698 229,704 138,267 74,807 47,4466.01% 5.84% 4.67% 2.49% 3.77% 3.16% 1.66% 0.92% 0.01% 0.01% 0.01% 0.01%SO2Steubenville‐Weirton,OH‐WVNAAOnroadPercentageNAA County SectorWVPortionofNAAWVOnroadPercentageOHPortionOnroadPercentageSteubenville‐Weirton,OH‐WVNAASteubenville‐Weirton,OH‐WVNAANOx PM2.5Page 34Weirton, WV 2006 24-Hour PM2.5Redesignation and Maintenance PlanOnroad mobile source SO 2 constitutes less than one tenth of one percent (<0.1%) of the area’s total SO 2 emissions in the 2015 and 2025 horizon years.

Onroad mobile source NO
x constitutes less than five per cent(<5%) of the area’s total NO
x emissions in the 2015 and 2025 horizon years.

Onroad mobile source PM 2.5 constitutes less than two percent (<2%) of the area’s total PM 2.5 emissions in the 2015 and 2025 horizon years.

The federal Transportation Conformity rule allows pollutants/precursors to be exempt from conformity analysis under certain circumstances.

40CFR93.109(k) Areas with insignificant motor vehicle emissions. Notwithstanding the other paragraphs in this section, an area is not requi red to satisfy a regional emissions analysis for §93.118 and/or §93.119 for a given pollutant/pr ecursor and NAAQS, if EPA finds through the adequacy or approval process that a SIP demonstrates that regional motor vehicle emissions are an insignificant contributor to the air quality problem for that pollutant/precursor and NAAQS. The SIP would have to demonstrate that it would be unreasonable to expect that such an area would experience enough motor vehicle emissions growth in that pollutant/precursor for a NAAQS violation to occur. Such a finding would be based on a number of factors, including the per centage of motor vehicle emissions in the context of the total SIP inventory, the current state of air quality as determined by monitoring data for that NAAQS, the absence of SIP moto r vehicle control measures, and historical trends and future projections of the growth of motor vehicle emissions. . . [emphasis added]

For the reasons outlined below, the DEP is here in making a finding that regional highway emissions of PM 2.5 , NO
x and SO 2 are insignificant contributors to the nonattainment problem for the Weirton area. The finding will become final if EPA concurs and approves this SIP.

First, the regional highway pollutant/precursor emi ssions constitute a relativ ely small fraction (<10%) of the overall emissions in all cas es, as shown in Table 25, above. Th erefore, DEP believes that the low contribution of both precursors and PM to the emissions inventory, in concert with the considerations detailed below, clearly warrants an insignificance finding with respect to transportation conformity.

Another consideration is the significant emission decreases that are projected not only for the highway sector but also for the total emissions i nventory. As the charts below clearly demonstrate, all three pollutants decrease over the period of the maintenance plan and the percent contribution of highway emissions decrease as well.

Page 35 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanFigure 7: Steubenville-Weirton, OH-WV NAA NO
x Emissions by Sector

Figure 8: Steubenville-Weirton, OH-WV NAA PM 2.5 Emissions by Sector

Page 36 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanFigure 9: Steubenville-Weirton, OH-WV NAA SO 2 Emissions by Sector

Second, the current air quality (CY 2011) is represented by a design value of 29 ug/m 3 . This value is significantly lower than the 41 ug/m 3 design value (2006-2008) upon which the nonattainment designation was based, and is comfortably below the NAAQS. Figure 2 on page 6 shows the general improvement of PM 2.5 concentrations from the year 2001 to date. The design values went from 41
μ g/m 3 (2006-2008) to 37 μ g/m 3 (2007-2009) to 31 μ g/m 3 (2008-2010) and reached a low of 29 μ g/m 3 (2009-2011). This air quality improvement may be attr ibuted to an overall decrease in sulfates from SO 2 reductions mandated by the Acid Rain Program, and preliminary implementation of controls to meet CAIR and is expected to continue under th e CAIR replacement rule, CSAPR. Overall, the PM concentrations have improved since the beginning of the decade, as show n in Figure 2. EPA has proposed to determine [76 FR 61291, 04OCT2012] th at based on 2008-2010 ambient air quality data, the Steubenville-Weirton nonattainment area has attained the 2006 24-hour PM 2.5 NAAQS. This determination, in accordance with 40 CFR 52.1004(c). DAQ s ubmitted a pr oposed Redesignation Request and Maintenance Plan for the area on March 2, 2012 for the 1997 PM 2.5 NAAQS. The area is designated as attainment for all other criteria pollutants.

Given the relatively small contribution of the highw ay emissions to the total SIP inventory, highway emissions are not likely to contribute significantly to the local PM 2.5 mass concentrations. Among other factors, this is largely due to the dominance of sulfates in the overall PM mass, coupled with the very low contribution of highway sources to those sulfate totals.

Third, historically there have been no West Virginia SIP requirements for motor vehicle control measures. The Weirton area is subject to Trans portation Conformity for the 8-hour ozone standard, with SIP-approved, seasonal budgets for NO
x and Volatile Organic Compounds (VOC). Further, the entire nonattainment area is currently subject to Transportation Conformity for the PM 2.5 standard. Page 37 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanEmissions analysis has been mandatory for a nnual highway emissions of direct PM and NO
x . However, upon a positive adequacy review or appr oval of this SIP submittal, no highway emissions analysis will be required under the annual PM 2.5 standard. Highway analysis of seasonal ozone precursors would continue to be mandatory. And, PM 2.5 hot-spot analyses woul d continue to apply for required projects under 40CFR93.116 and 93.123(b) of the Transportation Conformity Rule.

Fourth, BHJ has extensively researched the area local historical trends and growth patterns to develop the LRTP/TIP and support transportation conform ity evaluations. There is no reason to expect highway motor vehicle emissions gr owth that would lead to a PM 2.5 NAAQS violation. BHJ and ODOT have estimated emissions out, at least, to the calendar year 2035 c onfirming this, based on federally approved conformity determinations. The conformity analysis for the Weirton area took into account all the regional capacity projects, which are scheduled for implementation through the transportation plan horizon year and the four year TIP.

The air quality analysis contained in the report was the basis for the most recent federally approved conformity determination. The PM conformity tests were performed for calendar years 2008, 2014, 2018, 2025 and 2035. For each of those years, vehi cle miles traveled (VMT) and Speed were developed by the Federal Functional Class codes, wh ich are derived from the regional traffic model assignments that are made for each of those years. Pursuant to the Transportation Conformity interim tests, NO
x and direct PM were evaluated. The anal ysis employed the MOBILE6.2 emissions factor model. West Virginia (Brooke & Hancock Countie s) NOx emissions decrease dramatically from 787.5 tons/year [2008] to 414.0 t py [2014] to 306.8 tpy [2018] to 195.9 tpy [2025]. The decrease continues to the last value to to 176.6 [2035], which is less than one-fourth of the 2008 level. Direct PM dropped from 13.8 to 5.78 tpy [2035] . DEP believes this result solidly demonstrates that highway emissions will remain insignificant in the future.

Figure 10: Onroad NO
x Emissions Tons per Year

Page 38 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanV. CONTROL MEASURES AND REGULATIONS CAA Section107 (d)(3)(E)(ii), 107(d)(3)(iv), and 107(d)(3)(E)(v)

A. Reasonably Available Control Measures (RACM) and Reasonably Available Control Technology (RACT)

Section 172(c)(1) of the 1990 Clean Air Act Amendm ents (CAA) requires states with nonattainment areas to implement reasonably available control m easures (RACM) and reasonably available control technology (RACT). States with nonattainment areas must submit a SIP providing for implementation of all reasonably available control measures as expeditiously as practicable (including such reductions in emissions from existing sources in the area as may be obtained through the adoption, at a minimum, of reasonable available control technology).

EPA’s PM 2.5 Implementation Rule [72FR20586, 29APR2007] interprets this requirement in great detail. Under EPA’s approach, RACT is determined as part of the broader RACM analysis and identification of all measures (for stationary, mobile, and Area sources) that are technically and economically feasible, and that would collectively c ontribute to advancing the attainment 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 identify the attainment date that is as expeditious as practicable, and (3) selects the appropriate RACT and RACM.

Since the area attained the standard in 2008-2010, well in advance of the attainment date of December 14, 2014, there is no need for additional measur es to advance the attainment date, therefore the RACM/RACT requirements do not apply.

Furthermore, EPA states on their webs ite regarding the Clean Data Policy [ www.epa.gov/airquality/urbanair/sipstatus/policy_details.html ]:

Under EPA’s Clean Data Policy and the regulations that embody it, 40 CFR 51.918 (1997 8-hour ozone) and 51.1004(c) (PM-2.5), an EPA rulemaking determination that an area is attaining the relevant standard suspends th e area’s obligations to submit an attainment demonstration, reasonable available control m easures (RACM), reasonable further progress, contingency measures and other planning requirements related to attainment for as long as the area continues to attain. EPA’s statutory interpretation of the Clean Data Policy is described in the “Final Rule to Implemen t the 8-hour Ozone National Ambient Air Quality Standard—Phase 2” (Phase 2 Final Rule). 70 FR 71612, 71644-46 (Nov. 29, 2005) (ozone); See also 72 FR 20585, 20665 (Apr. 25, 2007) (PM-2.5). EPA believes that the legal bases set forth in detail in our Phase 2 Final rule, our May 10, 1995 memorandum from John S. Seitz, entitled “Reasonable Further Progress, Attainme nt Demonstration, and Related Requirements for Ozone Nonattainment Areas Meeting the Ozone National Ambient Air Quality Standard,” and our December 14, 2004 memorandum from Ste phen D. Page entitled “Clean Data Policy for the Fine Particle National Ambient Air Quality Standards” are equally pertinent to all NAAQS. EPA has codified the Cl ean Data Policy for 1997 8-hour ozone and PM-2.5, and has also applied it in individual rulemakings for 1-hour ozone and PM-10.

Under the Clean Data Policy, EPA may issue a determination of attainment (known informally as a Clean Data Determination) after notice and comment rulemaking determining Page 39 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance Planthat a specific area is attaining the relevant st andard. For such areas the requirement to submit to EPA those SIP elements related to attaining the NAAQS is suspended for so long as the area continues to attain the standard. These planning elements include reasonable further progress (RFP) requirements, attainment dem onstrations, RACM, con tingency measures, and other state planning requirements related to attainment of the NAAQS. The determination of attainment is not equivalent to a redesignation, and the state must still meet the statutory requirements for redesignation in order to be redesignated to attainment. A determination of attainment for purposes of the Clean Data Policy/regulations is also not linked to any particular attainment deadline, and is not nece ssarily equivalent to a determination that an area has attained the standard by its applicable attainment deadline, e.g., under section 181(b).

On October 4, 2011, in accordance with Section 179(c )(1) of the CAA, EPA proposed to determine that the Steubenville-Weirton, OH-WV PM 2.5 nonattainment area had attained the 2006 24-Hour PM 2.5 NAAQS, this proposal [76 FR 61291] is based upon three years of complete, quality assured, quality-controlled data for the 2008-2010. Preliminary data for 2009 through 2011, demonstrate that the air quality continues to meet the NAAQS for annual PM 2.5 in this nonattainment area. Therefore, once the Clean Data Determination is finalized RACM, including RACT, will longer apply.

B. Inventory of Actual Emissions

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

In accordance with the Consolidated Emissions Reporting Rule (CERR), West Virginia 2002 and 2005 statewide comprehensive emissions inventorie s were submitted to EPA's CDX site on April 29, 2005 and June 1, 2007, respectively. The West Virginia 2008 comprehensive emissions inventory was submitted to the CDX on May 30, 2010 consistent with the requirements of the Air Emissions Reporting Requirements (AERR). We are here by resubmitting the 2005, and 2008 comprehensive inventories for the Weirton nonattainment area.

West Virginia will continue to provide updates to future inventories in accordance with EPA’s AERR rule. As discussed in Section III.F, West Virginia DAQ submits, and commits to submit, emission inventories every three years.

C. Evidence that control measures required in past PM 2.5 SIP revisions have been fully implemented.

1. NO
x SIP Call, CAIR and CSAPR The EPA NO
x SIP Call required 22 states to pass rules that would result in significant emission reductions from large EGUs, industrial boilers, and cement kilns in the eastern United States. West Virginia passed this rule in 2002. NO
x SIP Call requirements are incorporated into permits along with monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. West Virginia DAQ also has an active enforcemen t program to address violations discovered by field office staff. Compliance is tracked thr ough the Clean Air Markets data monitoring program. In West Virginia, this rule accounted for a reduction from 2003 levels of approximately 57 Page 40 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance Planpercent of NO
x emissions by 2008 from sources subject to the rule. The other 21 states also adopted these rules.

On March 10, 2004, the EPA promulgated the CAIR. Beginning in 2009, EPA’s CAIR rule required EGUs in 28 eastern states and the Distri ct of Columbia to significantly reduce emissions of NO
x and SO 2 . CAIR replaced the NO
x SIP Call for EGUs. National NO
x emissions were expected to 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 require d to submit a CAIR SIP as part of this effort. West Virginia submitted an initial CAIR SI P on June 1, 2006. Subsequently, WV submitted an abbreviated CAIR SIP on June 8, 2007, which request ed authority to allocate CAIR allowances. Final revisions to the CAIR SIP were subm itted on April 22, 2008. The revised CAIR SIP was approved in a direct final action on August 2, 2009 (74FR38536 ).

On July 6, 2010, EPA proposed a replacement to th e CAIR program, the Transport Rule [75 FR 45210]. On July 6, 2011, EPA finali zed the Transport Rule, now commonly referred to as the Cross-State Air Pollution Rule (CSAPR) [ 76FR48208, 08AUG2011] in time for reductions to begin in 2012. As finalized, the CSAPR would have preserved the initial reductions achieved under CAIR and provided more reductions in NO
x and SO 2 emissions in 2012 and 2014, ahead of the 2015 CAIR Phase 2.

EPA states on their Cross-State Air Pollution Ru le homepage: “By 2014, power plants in states common to both the Cross-State Air Pollution Rule and CAIR will achieve annual SO 2 emissions around 1.8 million tons lower and annual NO
x emissions around 76,000 tons lower than what would have been achieved at that time under CAIR.” ( www.epa.gov/airtransport/basic.html )

Controls for EGUs under the NO
x SIP Call formally commenced May 31, 2004. Emissions covered by this program have been genera lly trending downward since 1998 with larger reductions occurring in 2002 and 2003. Data taken from the EPA Clean Air Markets web site, quantify the gradual NOx reductions that have occurred in West Virginia as a result of Title IV of the 1990 CAA Amendments and the beginning of the NO
x SIP Call Rule. West Virginia developed the NO
x Budget Trading Program rules in 45CSR 1 and 26 in response to the SIP Call. 45CSR1 regulated EGUs and 45CSR26 regulated certain non-EGUs under a cap and trade program based on an 77 percent reduction of NO
x emissions from EGUs and a 60 percent reduction of NO
x emissions from non-EGUs, compared to hist orical levels. This cap was in place through 2008, at which time the CAIR program superseded it as discussed above. Section III above discussed the reductions West Virginia has seen as a result of CAIR.

On April 21, 2004, EPA published Phase II of the NO
x SIP Call that established a budget for large (greater than 1 ton per day emissions) stationary internal combustion engines. 45CSR1 addresses stationary internal combustion engines, all used in natural gas pipeline transmission. EPA approved this revision to the SIP on November 27, 2006. An 82 percent NO
x reduction from 1995 levels was anticipated. Approval of the comp liance plans occurred by August 4, 2006, and March 1, 2007 and the compliance demonstration began May 1, 2007.

Page 41 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance Plan2. Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards [65FR6698, 10FEB2000] In February 2000, EPA published a federal rule to significantly reduce emissions from cars and light trucks, including sport utility vehicles (SUVs). Under this proposal, automakers will be required to sell cleaner cars, and refineries will be required to make cleaner, lower sulfur gasoline. This rule applies nationwide. The federal rules phased in between 2004 and 2009. EPA estimated that NO
x emission reductions will be approximately 77 percent for passenger cars, 86 percent 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 approximately 12 percent for passenger cars, 18 percent for smaller SUVs, light trucks, and minivans, and 15 percent for larger SUVs, vans, and heavier trucks.

3. Heavy-Duty Diesel Engines [65FR59896, 06OCT2000] In October 2000, EPA published a final rule for Hi ghway Heavy Duty Engines, a program which includes low-sulfur diesel fuel standards, which were phased in from 2004 through 2007. This rule applies to heavy-duty gasoline and diesel truc ks and buses. This rule resulted 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 estimated the level of sulfur in highway diesel fuel would be reduced by 97 percent by mid-2006.

4. Clean Air Non-road Diesel Rule [69FR38958, 29JUN2004] In June 2004, EPA published the Clean Air Non-road Diesel Rule. This rule applies to diesel engines used in industries such as construction, ag riculture, and mining. It also contains a cleaner fuel standard similar to the highway diesel pr ogram. 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 percent 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 2004 levels, from approximately 3,000 parts per million (ppm) to 15 ppm in 2009. New engine standards took effect, based on engi ne horsepower, starting in 2008. Together, these rules will substantially reduce local and regional sources of PM 2.5 precursors.
D. Assurance that existing control measures will remain in effect

West Virginia commits to maintaining the aforementioned control measures after redesignation. West Virginia hereby commits that any changes to its rules or emission limits applicable to PM 2.5 , SO 2 , and NO
x as required for maintenance of the annual PM 2.5 standard in the Weirton area, will be submitted to EPA for approval as a SIP revision.

West Virginia, through the Division of Environmen tal Protection, DAQ, has the legal authority and necessary resources to actively enforce any violations of its rules or permit provisions. After redesignation, it intends to continue enforcing all rules that relate to the emission of PM 2.5 precursors in the Weirton Area.

Page 42 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanVI. SUPPLEMENTAL MODELING ANALYSES

Although EPA’s Redesignation Guidance does not re quire modeling nonattainment areas seeking redesignation, extensive modeling has been pe rformed covering the Steubenville-Weirton, OH-WV area to determine the effect of national emission control strategies on PM 2.5 concentrations. These modeling analyses determined that the Steube nville-Weirton, OH-WV area is significantly impacted by regional transport of PM 2.5 and its precursors, and that regional SO 2 and NO
x reductions are an effective way to attain the annual standards for PM 2.5 in this area. Future year modeled 24-hour PM 2.5 concentrations are expected to be reduced by 11% to 36% from baseline design values. Examples of these modeling analyses are described below.

A. EPA Modeling for the Cross State Air Pollution Rule (Final Transport Rule)

EPA performed modeling to support the emission reduc tions associated with the Final Transport Rule or the Cross State Air Pollution Ru le (CSAPR), as it is currently called. EPA used the Comprehensive Air Quality Model with Extension (CAMx) versi on 5.3 applied to the 2005 meteorology as processed by the Mesoscale Model (MM5), Version 3.7.4. Em issions input into the CAMx included SO 2 , NO
x , VOC, NH 3 and direct PM 2.5 for 2005. The modeling was based on the annual fine particle design values calculated from 2003 through 2005, 2004 through 2006, and 2005 through 2007. Future year modeling was conducted, and the future year design values for 2012 and 2014 were evaluated for attainment of the 24-hour NAAQS for PM 2.5 of 35 μg/m 3 , as shown in Table 26. The Brooke County monitors (54-019-0005, 54-009-0011) and the Hancoc k County monitor (54-029-1004) represent the Weirton area.

As indicated in the Air Quality Modeling Techni cal Support Document (TSD) for the CSAPR, air quality modeling was performed for several em issions cases: a 2003-2007 base year, a 2012 “no CAIR” base case, a 2014 “no CAIR” base case, and the 2014 remedy case.

Modeling results for the Weirton area (Brooke County monitor, 54-009-0011) show a 6.4 μg/m 3 (14.6%) decrease in the average 24-hour PM 2.5 concentration for 2012 and a 7.8 μg/m 3 (17.8%) decrease in the average concentration for 2014, w ithout accounting for CAIR or reductions required by the Transport Rule or CS APR. A reduction of 15.6 μg/m 3 (35.5%) from the 2003-2007 baseline is expected for 2014 with the implementation of th e CSAPR. It should also be noted that the base year design value used by EPA in their mode ling was taken from 2003 through 2007 and is higher than the current 2009 through 2011 design value of 29 μg/m 3 in the area. Furthermore, the monitored design values for 2008-2010 and 2009-2011 of 31 and 29 μg/m 3 , respectively, are less than the modeled base case design vales for 2012 and 2014. Figures 2 and 3 (in Section II) show the downward trend of the design valu es from 1999 through 2010 for the PM 2.5 monitors in West Virginia and Ohio.

Page 43 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanTable 26: CSAPR 24-Hour PM2.5Design Values (μg/m3)Site ID County 2003-2007AverageAmbientValue2003-2007MaximumAmbientValues2012 BaseCaseAverageValues2012 BaseCaseMaximumValues2014 BaseCaseAverageValues2014 BaseCaseMaximumValues2014RemedyAverageValues2014RemedyMaximumValues54-003-0003 Berkeley 34.5 35.8 30.6 31.1 29.8 30.3 25.9 27.254-009-0005 Brooke 39.4 41.5 31.9 33.4 30.4 31.6 24.5 25.554-009-0011 Brooke 43.9 44.9 37.5 38.3 36.1 37.0 28.3 29.154-011-0006 Cabell 35.1 36.6 30.9 32.2 29.3 30.7 21.0 22.254-029-1004 Hancock 40.6 41.2 32.5 32.7 30.7 31.1 22.5 23.354-033-0003 Harrison 33.5 34.6 31.3 32.2 30.1 31.0 18.5 18.854-039-0010 Kanawha 34.7 35.5 29.8 30.4 28.4 29.0 19.9 20.954-039-0011 Kanawha 33.1 33.1 28.4 28.4 27.1 27.1 19.8 19.854-039-1005 Kanawha 36.9 37.7 32.0 32.6 30.5 31.0 22.4 23.254-049-0006 Marion 33.6 33.7 30.9 31.0 29.7 29.7 18.4 18.554-051-1002 Marshall 33.9 34.8 28.1 28.3 27.0 27.2 19.3 19.654-061-0003 Monongalia 35.6 36.2 30.3 31.0 28.3 28.9 17.2 17.954-069-0010 Ohio 32.0 32.0 26.3 26.3 25.1 25.1 18.1 18.154-081-0002 Raleigh 30.6 31.3 25.7 26.3 24.5 25.0 17.2 17.454-089-0001 Summers 31.2 31.2 26.4 26.4 25.1 25.1 17.4 17.454-107-1002 Wood 35.4 36.7 30.1 31.2 27.5 28.5 20.2 21.2Source: Air Quality Modeling Final Technical Support Document for the Final Cross-State Air Pollution Rule , pages B-90 - B-91.(www.epa.gov/airtransport/techinfo.html)Page 44Weirton, WV 2006 24-Hour PM2.5Redesignation and Maintenance PlanB. EPA Modeling for Proposed Transport Rule 2010

EPA performed modeling to support the emission reduc tions associated with the Proposed Transport Rule. EPA used the Comprehensive Air Quality M odel with Extension (CAMx Version 5), applied to the 2005 meteorology as processed by the Mesoscale Model (MM5), Version 3.7.4. Emissions input into the CAMx included SO 2 , NO
x , VOC, NH 3 and direct PM 2.5 for 2005. The modeling was based on the annual fine particle design va lues calculated from 2003 through 2005, 2004 through 2006, and 2005 through 2007. Future year modeling was conducted, and the future year design values for 2012 and 2014 were evaluated for a ttainment of the 24-hour NAAQS for PM 2.5 of 35 μg/m 3 , as shown in Table 27. The Brooke County monitors (54-009-0005, 54-009-0011) and the Hancock County monitor (54-029-1004) represent the Weirton area.

EPA stated in the preamble to the proposed Transport Rule that the “baseline analysis takes into account emissions reductions associated with the im plementation of all federal rules promulgated by December 2008 and assumes that CAIR is not in effect.” [75FR 45233, 02AUG2010]

Modeling results for the Weirton area (Brooke County monitor, 54-009-0011) show a 4 μg/m 3 (9.1%) decrease in the PM 2.5 concentration for 2012 and a 4.7 μg/m 3 (10.7%) decrease in the concentration for 2014, without accounting for CAIR or reductions required by the Transport Rule. A reduction of 7.5 μg/m 3 (17.1%) from the 2003-2007 baseline is expected for 2014 with the implementation of the Transport Rule. It should also be noted that the ba se year design value used by EPA in their modeling was taken from 2003 through 2007 and is higher than the current 2009 through 2011 design value of 29 μg/m 3 in the area. Furthermore, the monitored design values for 2007-2009, 2008-2010 and 2009-2011 of 37, 31 and 29 μg/m 3 , respectively, are less than the m odeled base case design vales for 2012 and 2014.; the monitored values for 2008-2010 and 2009-2011 are less than the 2014 Remedy Average Values. Figures 2 and 3 (in Section II) show the downward trend of the design values from 1999 through 2010 for the PM 2.5 monitors in West Virginia and Ohio.

Page 45 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanTable 27: Proposed Transport Rule 24-Hour PM2.5Design Values (μg/m3)Site ID County 2003-2007AverageAmbientValue2003-2007MaximumAmbientValues2012 BaseCaseAverageValues2012 BaseCaseMaximumValues2014 BaseCaseAverageValues2014 BaseCaseMaximumValues2014RemedyAverageValues2014RemedyMaximumValues54-003-0003 Berkeley 34.5 35.8 32.0 32.7 31.6 32.2 29.3 30.054-009-0005 Brooke 39.4 41.5 33.9 36.1 33.0 35.2 28.9 30.654-009-0011 Brooke 43.9 44.9 39.9 40.8 39.2 40.1 36.4 37.154-011-0006 Cabell 35.1 36.6 32.1 33.6 30.8 32.2 23.3 24.654-029-1004 Hancock 40.6 41.2 34.3 34.6 32.7 33.2 26.0 26.654-033-0003 Harrison 33.5 34.6 33.0 34.0 31.3 32.3 20.2 20.554-039-0010 Kanawha 34.7 35.5 32.2 32.9 30.9 31.6 22.2 22.954-039-0011 Kanawha 33.1 33.1 30.8 30.8 29.6 29.6 21.5 21.554-039-1005 Kanawha 36.9 37.7 34.3 35.1 33.0 33.7 24.5 25.554-049-0006 Marion 33.6 33.7 34.3 34.4 32.8 32.8 20.1 20.254-051-1002 Marshall 33.9 34.8 30.0 30.9 28.7 29.6 22.9 23.954-061-0003 Monongalia 35.6 36.2 33.7 34.3 31.2 31.7 20.4 21.254-069-0010 Ohio 32.0 32.0 27.9 27.9 26.9 26.9 24.0 24.054-081-0002 Raleigh 30.6 31.3 27.8 28.3 26.7 27.2 19.6 19.954-089-0001 Summers 31.2 31.2 27.9 27.9 26.6 26.6 19.2 19.254-107-1002 Wood 35.4 36.7 32.7 33.9 31.1 32.2 23.0 23.4Source: Technical Support Document for the Proposed Transport Rule, page B-78. (www.epa.gov/airquality/transport/pdfs/TR_AQModeling_TSD.pdf)Page 46Weirton, WV 2006 24-Hour PM2.5Redesignation and Maintenance PlanVII. CONTINGENCY MEASURES CAA Section 107(d)(3)(E)(v)

A. Maintenance Plan Review

West Virginia hereby commits to review its ma intenance plan eight years after redesignation, as required by Section 175(A) of the CAA.

B. Corrective Actions

West Virginia hereby commits to adopt and expeditiously implem ent necessary corrective actions in the following circumstances:

1. Warning Level Response A warning level response shall be prompted whenever the 98 th percentile 24-hour PM 2.5 concentration of 35.5 μg/m 3 occurs in a single calendar year within the maintenance 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 app ear to be increasing. The study will evaluate whether the trend, if any, is likely to c ontinue and, if so, the control measures necessary to reverse the 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 e xpeditiously 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 warning level study that action is necessary to reverse the noted trend, the procedures for control selec tion and implementation outlined under “action level response” shall be followed.

2. Action Level Response An action level response shall be prompted whenever a two-year average of the 98 th percentile 24-hour PM 2.5 concentration of 35 μg/m 3 or greater occurs within the maintenance area. A violation of the standard (t hree-year average of the 98 th percentile of 35 μg/m 3 or greater) shall also prompt an action level response. In the event that the action level is triggered and is not found to be due to an exceptional event, malf unction, or noncompliance with a permit condition or rule requirement, West Virginia DAQ in conjunction with the metropolitan planning organization or regional council of governments, will determine additional control measures needed to assure future attainment of the 2006 PM 2.5 NAAQS. In this case, measures that can be implemented in a short time will be selected in order to be in place within 18 months from the close of the calendar year that prompted the ac tion level. West Virginia DAQ will also consider the timing of an action level trigger and determ ine 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.

Page 47 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance Plan3. Control Measure Selection and Implementation Adoption of any additional control measures is s ubject to the necessary administrative and legal process. This process will include publication of notices, an opportunity for public hearing, and other measures required by West Virginia law for rulemaking.

If a new measure/control is already promulgated and scheduled to be implemented at the federal or State level, and that measure/control is determ ined to be sufficient to address the upward trend in air quality, additional local measures may be unnecessary. Furthermore, West Virginia DAQ will submit to EPA an analysis to demonstrate th e proposed measures are adequate to return the area to attainment.

C. Potential Contingency Measures

Contingency measures to be considered will be selected from a comprehensive list of measures deemed appropriate and effective at the time the se lection is made. The selection of measures will be based on cost-effectiveness, emission reduction potential, economic and social considerations or other factors that West Virginia DAQ deems appr opriate. West Virginia DAQ will solicit input from all interested and affected persons in the maintena nce area prior to selecting appropriate contingency measures. Because it is not possible at this time to determine what control measures will be appropriate at 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., liquid propane and compre ssed 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) Concrete manufacturing - upgrade wet suppression. 5) Additional NO
x RACT statewide.

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

D. PM 2.5 , SO 2 , and NO
x sources potentially subject to futu re additional control requirements.

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.

Page 48 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanVIII. PUBLIC PARTICIPATION

West Virginia published notification for a public hearing and solicitation for public comment concerning the draft redesignation petition and maintenance plan in the West Virginia Register and the Wheeling Intelligencer on April 13, 2012.

The public hearing to receive comments on the redesignation request was held at 6:00 p.m. on Tuesday, May 15, 2012, at the West Virginia Divi sion of Environmental Protection Headquarters located at 601 57 th Street, SE, Charleston, WV. The pub lic comment period closed on May 15, 2012. No oral or written comments were received. Appendix F includes a c opy of the public notice, a copy of the West Virginia Register and Wheeling Intelligencer ads, and the hearing transcript.

Page 49 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance PlanIX. CONCLUSIONS

The Weirton PM 2.5 nonattainment area has attained the 2006 annual and 24-hour NAAQS for PM 2.5 and complied with the applicable provisions of the 1990 Amendments to the CAA regarding redesignations of PM 2.5 nonattainment areas. Documentation to th at effect is contained herein. West Virginia DAQ has prepared a redesignation request a nd maintenance plan that meet the requirements of Section 110 (a)(1) of the 1990 CAA.

Based on this presentation, the West Virginia portion of the Weirton PM 2.5 nonattainment area meets the requirements for redesignation under the CAA and EPA guidance. West Virginia has performed an analyses showing the air quality improvements are due to permanent and enforceable 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 West Virginia hereby requests that the Weirton 2006 PM 2.5 nonattainment area be redesignated to attainment simultaneously with EPA approval of the CAA section 175A maintenance plan provisions contained herein.

Page 50 Weirton, WV 2006 24-Hour PM 2.5 Redesignation and Maintenance Plan