Environmental

Protection Agency

John FL ~<Bsichi Governor

0/T2~'V , Lt. Governor

~,;cott .1. Director

APR 182012

Ms. Susan Hedman

Regional Administrator

U.S. EPA Region 5

77 W. Jackson Blvd.

Chicago, IL 60604

Re: PM2.5 Redesignation Request for the 1997 PM2.5Annual Standard for the Wheeling,

WV-OH Area

Dear Administrator Hedman:

I am writing to formally request a redesignation to attainment of the Ohio portion of the

Wheeling, WV-OH area (Belmont County, Ohio) with respect to the 1997 PM2.5 annual

standard. The enclosed submittal combines the redesignation request and the required

maintenance plan for this area.

Monitoring of existing air quality indicates that the 1997 National Ambient Air Quality

Standard (NAAQS) for PM2.5 has been attained throughout this area based on 2008-

2010 air quality data. Emissions projections indicate that current controls, existing State

rules, existing federal rUles, and Ohio's PSD program will be more than sufficient to

maintain the NMQS indefinitely into the future. These programs will, therefore,

constitute the attainment and maintenance plan for the Wheeling area.

The enclosed information, compiled by the Ohio Environmental Protection Agency (Ohio

EPA) in cooperation with the Ohio Department of Transportation (Ohio DOT), the West

Virginia Department of Environmental Protection (WVDEP), and the West Virginia

Department of Transportation (WVDOT), shows significant emission reductions in point

and mobile sources since ambient exceedances have occurred. A significant portion of

the improved air quality can be attributed to federal programs for the mobile source

sector, the regional reductions associated with the NOx Trading Program, and the

Clean Air Interstate Rule (CAIR).

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

February, 292012. This notice was also published in a newspaper of general circulation

in Martins Fetty, Ohio. The public hearing for this package was held on April 5, 2012 in

Martins Ferry, Ohio. No testimony was provided, nor were any comments received.

50 West Town street, Su~e 700

P.O. Box 1049

Columbus,OH 43216-1049

614 I 644 3020

61416443184 (fax)

www.epa.ohio.gov
If you have questions, please contact Jennifer Dines in our Division of Air Pollution

Control at (614) 644-3696.

Sincerely,

<:]?"y

Director

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

Enclosure
REDESIGNATION REQUEST AND

MAINTENANCE PLAN FOR

THE OHIO PORTION OF THE

WHEELING, WV-OH

ANNUAL PM2.5

NONATTAINMENT AREA

Belmont County, Ohio

Prepared by:

Ohio Environmental Protection Agency

Division of Air Pollution Control

April 2012
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TABLE OF CONTENTS

Chapter One

Introduction 1

Geographical description and background 2

Status of air quality 3

Chapter Two

Requirements for redesignation 4

Chapter Three

PM2.

5monitoring 8

Annual PM2.

5NAAQS 8

Ambient data quality assured 9

Three complete years of data 9

Commitment to continue monitoring 12

Chapter Four

Emission inventory 13

Base year inventory 13

Emission projections 14

Demonstration of maintenance 21

Permanent and enforceable emissions reductions 31

Provisions for future update 32

Chapter Five

Control measures and regulations 33

Nonattainment areas to implement RACM and RACT 33

Show Reasonable Further Progress (RFP) 35

Emission inventories 35

Implementation of past SIP revisions 36

New source review provisions 38

Assurance of continued controls 39

Chapter Six

Contingency measures 40

Commitment to revise plan 40

Commitment for contingency measures 40

Potential contingency measures 41

List of PM25, S02, and NOx sources 42

Chapter Seven

Public participation 43

Chapter Eight

Conclusions 44
Figure 1

Figure 2

Figure 3

Figure 4

Table 1

Table 2

Table 3

Table 4

Table 5

Table 6

Table 7

Table 8

Table 9

Table 10

Table 11

Table 12

Table 13

Table 14

Table 15

Table 16

Table 17

Table 18

Table 19

Table 20

Table 21

Table 22

FIGURES

Map of the Wheeling WV-OH nonattainment area and monitor locations 9

PM25 Annual Mean Trends LADCO States 11

PM25 Annual Mean Trends Midwest States 11

PM2.

5Annual Mean National Trends 12

TABLES

Monitoring Data for Wheeling WV-OH Area for 2008 - 2010 10

Belmont County, Ohio Emission Estimations for On-road Mobile Sources 19

Summary of Ohio Emissions Estimations for On-road Mobile Sources 19

Marshall County, West Virginia Emission Estimations for On-road Mobile

Sources 19

Ohio County, West Virginia Emission Estimations for On-road Mobile Sources .20

Summary ofWest Virginia Emission Estimations for On-Road Mobile Sources .20

Emission Estimations Totals for On-road Mobile Sources for the Wheeling

Area 20

Percent of Mobile Emissions for the Wheeling Area in 2015 and 2022 20

Reductions in S02 and NOx EGU Emissions Between 2008 and 2009 23

Reductions in S02 and NOx EGU Emissions Between the First Half of 2008 and

2010 24

Belmont County, Ohio PM25 Emission Inventory Totals for Base Year 2005,

Estimated 2008, and Projected 2015 and 2022 (tpy) - Without CAIR. 26

Marshall County, West Virginia PM25 Emission Inventory Totals for Base Year

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) - With CSAPR........ 26

Ohio County, West Virginia PM25 Emission Inventory Totals for Base Year

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) - With CSAPR........ 27

Wheeling Area PM25 Emission Inventory Total for Base Year 2005, Estimated

2008, and Projected 2015 and 2022 (tpy) - Without CAIR (Ohio) and With

CSAPR (West Virginia) 27

Belmont County, Ohio NO, Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 2015 and 2022 (tpy) - With CAIR 27

Marshall County, West Virginia NO, Emission Inventory Total for Base Year

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) - With CSAPR........28

Ohio County, West Virginia NO, Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 2015 and 2022 (tpy) - With CSAPR. 28

Wheeling Area NO, Emission Inventory Total for Base Year 2005, Estimated

2008, and Projected 2015 and 2022 (tpy) - With CAIR (Ohio) and With CSAPR

(West Virginia) 28

Belmont County, Ohio S02 Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 2015 and 2022 (tpy) - With CAIR 29

Marshall County, West Virginia S02 Emission Inventory Total for Base Year

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) - With CSAPR........29

Ohio County, West Virginia S02 Emission Inventory Total for Base Year 2005,

Estimated 2008, and Projected 2015 and 2022 (tpy) - With CSAPR 29

Wheeling Area S02 Emission Inventory Totals for Base Year 2005, Estimated

2008, and Projected 2015 and 2022 (tpy) - With CAIR (Ohio) and With CSAPR

(West Virginia) 30

ii
Table 23

Table 24

Wheeling Area Comparison of 2008 Attainment year and 2015 and 2022

Projected Emission Estimates (tpy) 30

Wheeling Area Combined Comparison of 2005 Base Year and 2008 Attainment

Year On-Road and EGU Reductions 32

APPENDICES

A Air Quality System (AQS) Data

B Ohio 2005 SIP Base Year Inventory Discussion

C Mobile Source Emissions Inventory for the Wheeling PM25 Nonattainment Area

D LADCO Technical Support Documents

E Public Participation Documentation

iii
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iv
REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE OHIO

PORTION OF THE WHEELING, WV-OH

ANNUAL PM2.5 NONATTAINMENT AREA

Belmont County, Ohio

CHAPTER ONE

Introduction

The Clean Air Act (CAA), as amended, requires each State with areas failing

to meet the annual PM2.51 National Ambient Air Quality Standard (NAAQS) to

develop State Implementation Plans (SIPs) to expeditiously attain and

maintain the standard. The United States Environmental Protection Agency

(U.S. EPA) revised the NAAQS for particulate matter in July 1997. It replaced

the existing PM10 standard with a health-based PM2.5 standard and retained

the PM10 standard as a particulate standard protecting welfare. The

standards include an annual standard set at 15.0 micrograms per cubic meter

(lJg/m3), based on the 3-year average of annual mean PM2.5 concentrations

and a 24-hour standard of 65 IJgfm3

, based on the 3-year average of the 98th

percentile of 24-hour concentrations.

The revised NAAQS was legally challenged in the U.S. Court of Appeals for

the District of Columbia Circuit (the D.C. Circuit). On May 14, 1999, the D.C.

Circuit remanded, without vacatur, the standard back to U.S. EPA. The

remand did not question the level at which U.S. EPA set the standards but

rather the constitutionality of the CAA provision that authorizes U.S. EPA to

set national air quality standards. U.S. EPA requested a rehearing which the

D.C. Circuit denied. Therefore, in December 1999, U.S. 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 provision but did remand several other issues

back to the D.C. Circuit, including the issue of whether U.S. EPA acted

arbitrarily and capriciously in establishing the specific levels of the standards.

The D.C. Circuit heard arguments in this remanded case in December 2001,

and issued its decision on March 26, 2002. The D.C. Circuit rejected the

1 Particle pollution is a mixture of microscopic solids and liqUid droplets suspended in air. This pollution.

also known as particulate matter, is made up of a number of components, including acids (such as

nitrates and sUlfates), organic chemicals. metals, sailor dust particles, and allergens (such as

fragments of pollen or mold spores).

Fine particle pollution or PM'.5 describes particulate matter that is 2.5 micrometers in diameter and

smaller - 1/30th the diameter of a human hair. Fine particle pollution can be emitted directly or formed

secondarily in the atmosphere.
claims that the U.S. EPA had acted arbitrarily and capriciously in setting the

levels ofthe standards.

On December 17, 2004, U.S. EPA promulgated the initial PM2.5

nonattainment areas designations for the PM2.

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 CM Amendments of 1990 which

defined five ozone nonattainment classifications for the areas that exceed the

NMQS based on the severity of the ozone levels, PM2.5 nonattainment

designations are simply labeled "nonattainment." The CM Amendments

require states with PM2.5 nonattainment areas to submit a plan within three

years of the effective date of the designations (April 5, 2008) detailing how the

PM2.5 standards will be attained by April 5, 2010. Ohio EPA submitted its

attainment demonstration for the entire State of Ohio on July 16, 2008.

Section 107(d)(3)(E) of the CM allows states to request nonattainment areas

to be redesignated to attainment provided certain criteria are met. The

following are the criteria that must be met in order for an area to be

redesignated from nonattainment to attainment:

• A determination that the area has attained the PM2.5

standard.

• An approved State Implementation Plan (SIP) for the area

under Section 11 O(k).

• A determination that the improvement in air quality is due to

permanent and enforceable reductions in emissions resulting

from implementation of the SIP and other federal

requirements.

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

• A determination that all Section 110 and Part D requirements

have been met.

This document addresses each of these requirements, and provides

additional information to support continued compliance with the annual PM2.5

standard.

Geographical Description and Background

The current Wheeling nonattainment area is located in eastern Ohio and

includes the following counties: Belmont in Ohio and Ohio and Marshall in

West Virginia. Belmont County is bordered by Ohio and Marshall Counties to

the east. This area is shown in Figure 1 under Chapter Three.

The Wheeling area has not previously been subject to nonattainment area

rulemakings for fine particles.

2
As a result of the 2005 PM2.5 designations, U.S. EPA desi~nated the

Wheeling area nonattainment for the 15.0 IJg/m3 annual standard , and Ohio

EPA was required to develop a plan to reduce oxides of nitrogen (NOx), sulfur

dioxide (S02) and direct PM2.5 emissions and to demonstrate that the area will

meet the federal annual air quality standard by April 5, 2010. Ohio's main

PM2.5 components are primary particles (organic carbon, crustal material, and

elemental carbon), S02 and NOx, which were included in the attainment

demonstration analysis. Volatile organic compounds (VOCs) and ammonia

(NH3) were not included in the analysis since they were not part of Ohio's

current attainment strategy for PM2.5 (although controls for VOCs have been

implemented for ozone nonattainment). This is consistent with U.S. EPA's

"Clean Air Particle Implementation Rule" [74FR 20856] (hereafter referred to

as "Implementation RUle"). In the Implementation Rule U.S. EPA presumes

NH3 emissions are not a PM2.5 attainment plan precursor and that States are

not required to address VOC unless the State or U.S. EPA makes a technical

demonstration that emissions of VOCs significantly contribute to

nonattainment of the annual PM2.5standard.

This document is intended to support Ohio's request that the Ohio portions of

the Wheeling area be redesignated from nonattainment to attainment for the

annual PM2.5standard. In addition, the State of West Virginia may also submit

a request for their respective portions of the Wheeling area.

Status of Air Quality

PM2.5 complete quality-assured ambient air quality monitoring data for the

most recent three (3) years, 2008 through 2010, demonstrate that the air

quality has met the NAAQS for annual PM2.5 in this nonattainment area. The

NAAQS attainment, accompanied by decreases in emission levels discussed

in Chapter Four, supports a redesignation to attainment for the Wheeling area

based on the requirements in Section 107(d)(3)(E) of the CAA as amended.

2 There were no monitors in Ohio that violated the 1997 24-hour PM,.5 standard of 65~g/m3.

3
CHAPTER TWO

Requirements for Redesignation

U.S. EPA has published detailed guidance in a document entitled Procedures

for Processing Requests to Redesignate Areas to Attainment (redesignation

guidance), issued September 4, 1992, to Regional Air Directors. The

redesignation request and maintenance plan are based on the redesignation

guidance, supplemented with additional guidance received from staff of U.S.

EPA Region 5.

Below is a summary of each redesignation criterion as it applies to the

Wheeling area.

L) Attainment of the standard (CM Section 107(d)(3)(E)(i))

There are two components involved in making this

demonstration. The first component relies on ambient air quality

data. The data that are used to demonstrate attainment should

be the product of ambient monitoring that is representative of

the area of highest concentration. The data should be collected

and quality-assured in accordance with 40 CFR 58 and

recorded in the Air Quality System (AQS) in order for it to be

available to the public for review.

The second component relies upon supplemental U.S. EPAapproved air quality modeling. While no modeling is required for

redesignating nonattainment areas, the redesignation guidance

states it is "generally necessary" for particulate matter

redesignations. Appendix C and Appendix D contains the most

recent modeling results showing future attainment and

maintenance are provided. Chapter Three discusses this

requirement in more detail and provides the attainment

demonstration.

ii.) Permanent and enforceable improvement in air quality (CM Section

107(d)(3)(E)(iJJ»

The state must be able to reasonably attribute the improvement

in air quality to emission reductions which are permanent and

enforceable. The state should estimate the percent reduction

achieved from federal measures as well as control measures

that have been adopted and implemented by the state.

It was not necessary for Ohio to adopt or implement control

measures for these counties beyond the federal measures.

4
Ohio EPA has adopted several rules recently that will have an

impact on statewide PM2.5 emissions in the future:

• Clean Air Interstate Rule (CAIR)

• NO, SIP Call Rules

Ohio was also subject to a Federal Implementation Plan under

the CAIR replacement rule, the Cross-State Air Pollution Rule

(CSAPR) that could have resulted in even greater reductions

than the CAIR program. However, on December 30, 2011, the

D.C. Circuit Court stayed CSAPR and ordered U.S. EPA to

continue administering CAIR pending the court's resolution.

In addition, since the initial designations were made federally

enforceable consent decrees have resulted in reductions in

emissions from utilities within Belmont County and across the

state, including this area.

Chapters Four and Five discuss this requirement in more detail.

iii.) Section 110 and Part D requirements (CAA Section 107(d)(3)(E)(v»)

For purposes of redesignation, a state must meet all

requirements of Section 110 and Part D that were applicable

prior to submittal of the complete redesignation request.

Subpart 1 of Part D consists of general requirements applicable

to all areas which are designated nonattainment based on a

violation of the NAAQS. Subpart 4 of Part D consists of more

specific requirements applicable to particulate matter

(specifically to address PM10). However, for the purpose of

implementing the 1997 PM2.5 standard, U.S. EPA's

Implementation Rule stated Subpart 1, rather than Subpart 4, is

appropriate for the purpose of implementing PM2.5.[72 FR

20589]

Section 110(a) requirements

Section 11 O(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 hearing, and that, among other things, it must

include enforceable emission limitations and other control

measures, means or techniques necessary to meet the

requirements of the CAA; provide for establishment and

operation of appropriate devices, methods, systems and

5
procedures necessary to monitor ambient air quality;

provide for implementation of a source permit program to

regulate 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 deterioration (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

provide for public and local agency participation in

planning and emission control rule development. In

Ohio's December 5, 2007 and September 4, 2009

infrastructure SIP submissions, Ohio verified that the

State fulfills the requirements of Section 110(a)(2) of the

Act.

Section 110(a)(2)(D) also 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 prevent significant deterioration of air quality or

to achieve reasonable progress toward the national

visibility goal for Federal class I areas (national parks and

wilderness areas). In order to assist States in addressing

their obligations regarding regionally transported

pOllution, U.S. EPA finalized CAIR to reduce S02 and

NOx emissions from large electric generating units

(EGU). Ohio has met the requirements of the federal

CAIR to reduce NOx and S02 emissions contributing to

downwind states. On February 1, 2008, U.S. EPA

approved Ohio's CAIR program, which can be found in

Ohio Administrative Code (OAC) Chapter 3745-1093

. On

July 6, 2011, U.S. EPA finalized a replacement to the

CAIR program, the CSAPR. CSAPR could further assist

States in addressing their obligations regarding regionally

transported pollution by providing reductions in NOx and

S02 emissions in 2012 and 2014. However, on

December 30, 2011, the D.C. Circuit Court stayed

CSAPR and ordered U.S. EPA to continue administering

CAIR pending the court's resolution.

iv.) Section 172(c) requirements

This Section contains general requirements for nonattainment

plans. The requirements for reasonable further progress,

3 http://www.epa.ohio.gov/dapc/regs/regs.aspX#3745-109

6
identification of certain emissions increases, and other

measures needed for attainment will not apply for

redesignations because they only have meaning for areas not

attaining the standard. The requirements for an emission

inventory will be satisfied by the inventory requirements of the

maintenance plan. Chapters Four and Five discuss this

requirement in more detail.

v.) Conformity

The state must work with U.S. 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

procedures in place. If a state does not have conformity

procedures in place at the time that it submits a redesignation

request, the state must commit to follow U.S. EPA's conformity

regulation upon issuance, as applicable.

vL) Maintenance plans (CAA Section 107(d)(3)(E)(iv»

Section 107(d)(3)(E) stipulates that for an area to be

redesignated, U.S. 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 maintenance 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.

States seeking redesignation of a nonattainment area should

consider the following provisions:

a.) attainment inventory;

b.) maintenance demonstration;

c.) monitoring network;

d.) verification of continued attainment; and

e.) contingency plan.

Chapter Six discusses this requirement in more detail.

7
CHAPTER THREE

PM2.5 MONITORING

CM Section 107(d)(3)(E)(i)

Requirement 1 of 4

A demonstration that the NAAQS for annual PM2.5, as published in 40 CFR

50.7, has been attained.

Background

There are no monitors measuring PM2.

5 concentrations in Belmont

County. As shown in Figure 1 the two monitors used for measuring

PM2.5 concentrations for the entire nonattainment area are located in

Ohio County and Marshall County, West Virginia. The monitors are

operated by the West Virginia Department of Environmental Protection

(DEP), Division of Air Quality (DAQ). A listing of the design values

based on the three-year average of the annual mean concentrations

from 2008 through 2010 are shown in Table 1. The locations of the

monitoring sites for this nonattainment area are shown on Figure 1.

8
Demonstration

Figure 1 - Map of the Wheeling WV-OH Nonattainment Area and Monitor

Locations

11o","".".

• l f~J~ ') '"'''''' "_~/".r: >~.......-,,,,jil.. j.r"'t.jer.;::' r,

! ti\.., '..~-- ... "~,-,,,j"- .~

="...lll'!!j~""'~m'n..¥'(":!tml.'!tl ':\. .._,_,,~ ~&====::::::::==s=±::==b:.::;;;;;;;j

Requirement 2 of 4

Ambient monitoring data quality assured in accordance with 40 CFR 58.10,

recorded in the U.S. EPA air quality system (AQS) database, and available

for pUblic view.

Demonstration

West Virginia has quality assured all data shown in Appendix A in

accordance with 40 CFR 58.10 and all other federal requirements.

West Virginia has recorded the data in the AQS database and

therefore, the data are available to the public.

Requirement 3 of 4

A showing that the three-year average of the annual mean values, based on

data from all monitoring sites in the area or its affected downwind environs,

are below 15.0 jJg/m3

. (This showing must rely on three complete,

consecutive calendar years of quality assured data.)

Background

The following information is taken from U.S. EPA's "Guideline

on Data Handling Conventions for the PM NAAQS," U.S. EPA454/R-99-008, April 1999.

9
In accordance with the CM Amendments, three complete years

of monitoring data are required to demonstrate attainment at a

monitoring site. The annual PM2.5 primary and secondary

ambient air quality standards are met at an ambient air quality

monitoring site when the three-year average of the annual

average is less than 15.0 j.Jg/m3. While calculating design

values, three significant digits must be carried in the

computations, with final values rounded to the nearest 0.1

j.Jg/m3

• Decimals 0.05 or greater are rounded up, and those less

than 0.05 are rounded down, so that 15.049 j.Jg/m3 is the largest

concentration that is less than, or equal to 15.0 j.Jg/m3 . Values

at or below 15.0 j.Jg/m3 meet the standard; values equal to or

greater than 15.1 j.Jg/m3 exceed the standard. An area is in

compliance with the annual PM2.5 NMOS only if every

monitoring site in the area meets the NMOS. An individual

site's 3-year average of the annual average concentrations is

also cal/ed the site's design value. The air quality design value

for the area is the highest design value among al/ sites in the

area.

Table 1 shows the monitoring data for 2008 - 2010 that were

retrieved from the U.S. EPA AOS.

Demonstration

Table 1 - Monitoring Data for the Wheeling WV-OH area for 2008 -

2010

Annual Standard

Site County Year Averalle

2008 2009 2010 2008·2010

54·051·1002 Marshall, WV 13.1 12.2 14.1 13.1

54·069·0010 Ohio, WV 12.8 11.5 12.9 12.4

Less than 75% capture in atleast one quarter

Source: U.S. EPA Air Quality System (AQS); http://www.epa.gov/ttn/alrs/alrsaqs/lndex.htm

The design value calculated for the Wheeling area demonstrates that

the annual PM2.5NMOS has been attained. The area's design value

has trended downward as emissions have declined due to such factors

as cleaner automobiles and fuels, and controls for EGUs, at the

national, regional and localleve/.

National monitoring for PM2.5began in 1999. With respect to each of

the Lake Michigan Air Directors Consortium (LADCO) states, there has

been a clear downward trend in design values:

10
Figure 2 • PM2.5 Annual Mean Trends LADeo States

PM2.5 Annual Mean Trends, LADCO States, 1999-20C9

20..------------------------,

51,---.--.---.---.--.--.--.--.---,----1

1999 2003 2001 2002 2003 2004 2005 2005 2007 = 2009

...... Illinois

~Ohio

Indiana ..... Michigan

e-o-<;o Wisconsin

trerds lor m::m\lolS with at least 8 Ye61$ oj data

Source: LADCO; Recent Ozone and PM2.5 Trends - Aug 262010.pptx

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

Figure 3 • PM2.5 Annual Mean Trends Midwest States

PM2.5 Annual Mean Trends, Midwest States, 1999-2009

N V ,f--

N

o

1999 20XJ 2001 = 2003 2004 2005 2006 2cY37 2008 2009

25

Trerds lor rronnors wlth at leas\ g vealS oj data

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

Design values have also trended downward nationally:

11
Figure 4 • PM2.5 Annual Mean National Trends

PM2.5 Air Quality, 2000·2008

(Based on Seasonally-Weighted Annual Average)

National Trend based on 728 Sites

30.,.-----------------------,

25

::J 20

C

o

"" 15 Nafic:",J mooitairg lex- FM2.5 began in tl9il

10

c

o

U 5

O+---.-r-,--..,-,---.---,-..-.....,.--,--,--.,.--,--.-r-,----,,----I

11111 1 1 1 1 122 2 2 2 2 2 2 2

999 999 999 9 0 0 0 0 0 0 000

999 999 999 9 0 0 0 0 0 0 0 0 0

0123456789012345678

2000 to 2008: 19% decrease in National Average

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

Requirement 4 of 4

A commitment that once redesignated, the state will continue to operate an

appropriate monitoring network to verify the maintenance of the attainment

status.

Demonstration

Ohio EPA does not currently operate any monitors in this area. Ohio

EPA will consult with U.S. EPA Region 5 prior to making changes to

the existing monitoring network, should changes become necessary in

the future.

12
CHAPTER FOUR

EMISSION INVENTORY

CM Section 107(d)(3)(E)(iii)

U.S. EPA's redesignation guidance requires the submittal of a comprehensive

inventory of PM2.5 precursor emissions (primary particles (organic carbon,

crustal matter, and elemental carbon), S02 and NO/) representative of the

year when the area achieves attainment of the annual PM2.5 air quality

standard. Ohio also must demonstrate that the improvement in air quality

between the year that violations occurred and the year that attainment was

achieved is based on permanent and enforceable emission reductions. Other

emission inventory related requirements include a projection of the emission

inventory to a year at least 10 years following redesignation; a demonstration

that the projected level of emissions is sufficient to maintain the annual PM2.5

standard; and a commitment to provide future updates of the inventory to

enable tracking of emission levels during the 10-year maintenance period.

The emissions inventory development and emissions projection discussion

below, with the exception of the mobile (on-road) emissions inventory and

projections, identifies procedures used by Ohio EPA and the LADCO

regarding emissions from Ohio's portion of the Wheeling area. Specific

emissions data are provided for all counties, including those in Ohio and West

Virginia. West Virginia emissions data were obtained though the West

Virginia Department of Environmental Protection (WVDEP). All of these

inventories and emissions projections were prepared using similar

methodologies, unless otherwise noted. Mobile emissions inventories and

projections for all counties were prepared by the Belmont-Ohio-Marshal

Regional Council (Belomar) and the Ohio Department of Transportation

(ODOT), with data provided by Ohio EPA, West Virginia Department of

Transportation (WVDOT), and WVDEP.

Requirement 1 of 5

A comprehensive emission inventory of PM2.5, S02 and NOx completed for the

base year.

Background

The 2005 periodic inventory has been identified as one of the

preferred databases for SIP development and coincides with

nonattainment air quality in the Wheeling area.

Periodic inventories, which include emissions from all sectors

are prepared every three years by Ohio EPA. Ohio's 2005

4 vac and NH, are not addressed.

13
emissions data for all sources (Electrical Generating Unit (EGUPoint); Non-Electrical Generating Unit (Non-EGU); Non-road

Mobile (Non-road); Other Area (Area); and Marine; Aircraft; Rail

(MAR» are derived from this inventory. Ohio's point source data

derived from this periodic inventory is actual source reported

emissions under Ohio's annual emissions reporting program.

West Virginia's point source data are taken from U.S. EPA's

CSAPR estimates (EGU) and actual reported data under West

Virginia's emissions reporting program (non-EGUs). West

Virginia's emissions data for MAR and Area is derived from the

2005 National Emissions Inventory (NEI) while Non-road

emissions are derived from NONROAD modeling conducted by

WVDAQ.

Demonstration

Ohio's 2005 inventory is used as the base year for the purpose

of this submittal and was submitted to U.S. EPA with Ohio's

PM2.5attainment demonstration SIP submitted on July 18, 2008

and revised on June 7, 2010. The detailed emission inventory

information for Ohio's portion of the Wheeling area is provided

in Appendix B. Emissions of PM2.5, S02 and NOx for 2005 are

identified under Requirement Three of this Chapter.

Requirement 2 of 5

A projection of the emission inventory to a year at least 10 years following

redesignation.

Background

Ohio EPA prepared a comprehensive inventory for the Ohio portion of

the Wheeling area including area, mobile, and point sources for PM2.5,

S02 and NOx for base year 2005. The 2005 inventory was submitted to

U.S. EPA on July 18, 2008 as part of Ohio's PM2.5 attainment

demonstration SIP for this area. The information below describes the

procedures Ohio EPA used to generate the 2005 base year inventory

and to develop SIP-ready modeling inventories and future year

projections (Pechan Report5

) based on a 2005 base year inventory.

The report by Pechan generated future year estimates of annual

emissions for each source sector using accepted growth surrogates.

These inventories were provided to the LADCO and have been

processed to develop average daily emissions for use in the air quality

5

hltp:llwww.ladco.org/tech/emis/r5/reports/LADCO%202005%20Base%20Yr%20Growth%20and%20Co

ntrols%20Report_Flnal.pdf

14
analyses. These processed modeling inventories have been identified

as the correct iteration of the inventory for use in the redesignation. In

this document, references to LADCO include the Midwest Regional

Planning Organization. Note, that the on-road mobile source sector

was addressed by specific modeling as discussed below.

• Area source and MAR emissions were taken from the

Ohio 2005 periodic inventory submitted to U.S. EPA.

These projections were made from the U.S. Department

of Commerce Bureau of Economic Analysis (BEA)

growth factors, with some updated local information.

• Mobile source emissions were calculated from

MOVES2010 produced emission factors. Only PM2.5 and

NOx necessitate an emissions inventory analysis. Ohio

EPA in consultation with U.S. EPA determined mobile

sources are insignificant contributors for S02. Consistent

with Ohio EPA's attainment demonstration, Ohio EPA

continues to consider mobile source S02 to be an

insignificant contributor to fine particles for this

nonattainment area. Based on the results of mobile

source emissions projections prepared as part of this

redesignation and maintenance plan, Ohio EPA is also

making a finding that the regional highway emissions

PM2.5 and NOx are insignificant contributors to the

nonattainment problem in this area, as discussed below.

• Point source information was compiled from Ohio EPA's

2005 annual emissions inventory database and the 2005

U.S. EPA Air Markets acid rain database6

•

• Biogenic emissions are not included in these summaries.

• Non-road emissions were generated using U.S. EPA's

National Mobile Inventory Model (NMIM) 2002

application. To address concerns about the accuracy of

some of the categories in U.S. EPA's non-road emissions

model, LADCO contracted with two (2) companies to

review the base data and make recommendations. One

of the contractors also estimated emissions for three (3)

non-road categories not included in U.S. EPA's non-road

model. Emissions were estimated for aircraft, commercial

marine vessels, and railroads. Recreational motorboat

population and spatial surrogates (used to assign

emissions to each county) were significantly updated.

The populations for the construction equipment category

were reviewed and updated based upon surveys

6 hltp:/lwww.epa.gov/airmarkels!acidrain

15
completed in the Midwest, and the temporal allocation for

agricultural sources also was updated.

West Virginia emission projections were provided by the

WVOAQ as summarized below:

• Area source and MAR emissions were compiled from the

2008 NEI and 2015 and 2022 projections were grown

using Workforce data.

• Mobile source emissions were calculated using the same

methodology as described above for Ohio's portion.

• EGU point source information was compiled from U.S.

EPA's CSAPR inventories.

• Non-EGU point source information was compiled from

West Virginia's 2008 actual emissions inventory and

2015 and 2022 projections were grown using Workforce

data.

• Non-road emissions were generated are derived from

NONROAO modeling conducted by WVOAQ.

Demonstration

On-Road Emission Estimations

In coordination with the OOOT, Belomar utilizes a regional travel

demand forecast model to simulate traffic in the area and to

forecast traffic flows for given growth expectations. The model

is primarily used as a long range planning tool to evaluate the

transportation system including determination of locations where

additional travel capacity may be needed and to determine the

infrastructure requirements necessary to meet that need. It is

also used as a tool for air quality purposes to estimate the total

emissions of pollution caused by vehicles in the area. The

travel demand forecasting model is used to predict traffic

volumes vehicle miles traveled (VMT), travel speeds, and a U.S.

EPA computer program called MOVES is used to calculate

emissions per mile. The product of these is the total amount of

pollution emitted by the on-road vehicles for the area.

Overview

U.S.EPA published a Federal Register notice? of availability on

March 2, 2010, to approve MOVES2010 (Motor Vehicle

Emissions Simulator), hereafter referred to as MOVES. Upon

publication of the Federal Register notice, MOVES became U.S.

EPA's approved motor vehicle emission factor model for

7 http://www.regulations.gov/search/Regs/home.html#documentDetaiI?R=0900006480ab1f98

16
estimating VOCs, NOx, CO, PM10 and PM2.5 and other pollutants

and precursors from cars, trucks, motorcycles, and buses by

state and local agencies. MOVES is a computer program

designed by the U.S. EPA to estimate air pollution emissions

from mobile sources. MOVES replaces U.S. EPA's previous

emissions model for on-road mobile sources, 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.

The CAA requires U.S. EPA to regularly update its mobile

source emission models. U.S. EPA continuously collects data

and measures vehicle emissions to make sure the Agency has

the best possible understanding of mobile source emissions.

This assessment, in turn, informs the development of U.S.

EPA's mobile source emission models. MOVES represents the

Agency's most up-to-date assessment of on-road mobile source

emissions. MOVES also incorporates several changes to the

U.S. EPA's approach to mobile source emission modeling

based upon recommendations made to the Agency by the

National Academy of Sciences.

U.S.EPA believes that MOVES should be used in ozone, CO,

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.

Regarding transportation conformity, U.S. EPA and U.S. DOT

intend to establish a two-year grace period before MOVES is

required for new transportation conformity analyses.

The MOVES more detailed approach (when compared with the

previous MOBILE model) to modeling allows U.S. EPA to easily

incorporate large amounts of in-use data from a wide variety of

sources, such as data from vehicle inspection and maintenance

(11M) programs, remote sensing device (RSD) testing,

certification testing, portable emission measurement systems

(PEMS), etc. This approach also allows users to incorporate a

variety of activity data to better estimate emission differences

such as those resulting from changes to vehicle speed and

acceleration patterns. MOVES has a graphical user interface

which allows users to more easily set up and run the model.

MOVES database-centered design provides users much greater

flexibility regarding output choices. Unlike earlier models which

provided emission factors in grams-per-mile in fixed output

formats, MOVES output can be expressed as total mass (in

17
tons, pounds, kilograms, or grams) or as emission factors

(grams-per-mile and in some cases grams-per-vehicle). Output

can be easily aggregated or disaggregated to examine

emissions in a range of scales, from national emissions impacts

down to the emissions impacts of individual transportation

projects. The database-centered design also allows U.S. EPA to

update emissions data incorporated in MOVES more easily and

will allow users to incorporate a much wider array of activity data

to improve estimation of local emissions. For example, the

improvements in MOVES will allow project-level PM2.5

emissions to be estimated.

Belomar's report presents the latest population and land use

data available that calibrated the modeling process used to

calculate the vehicle emissions for the mobile emissions budgets

as well as the input values for MOVES. Travel analysis zones

and external roadway "stations" are the basic geographic unit for

estimating travel patterns in the Belomar model. The Belomar

region is divided into 269 traffic analysis zones and 31 external

roadway "stations". Socioeconomic data used to forecast these

patterns include household population, school enrollment,

vehicle registrations, labor force participation, and employment

by category and location.

Belomar utilized U.S.EPA's emissions model MOVES to

develop emissions factors for S02, NOx and PM2.

5• Further

details on the use of MOVES are found on Appendix C. A travel

demand model (TOM) is the traditional forecasting tool used to

examine potential changes in future travel patterns. The

Wheeling area travel demand model network covers about 1500

miles of streets and highways in the 3-county area including all

collector and arterial streets, and has been validated to

observed traffic for year 2000. Land use data comes from the

Census, ES202 employment reporting, and local vehicle

registrations.

The interagency consultation process, as previously discussed,

established the following model years for Ohio and Marshall

Counties, WV and Belmont County, OH that reflected the most

recent correspondence from the U.S. EPA:

Analysis Year 2005 - Baseline Emissions

Analysis Year 2008 - Attainment Year

Analysis Year 2015 -Interim Year

Analysis Year 2022 - Maintenance Year

18
The MOVES model generated the emission factor files were for

base year-2005 and attainment year-2008 representing the

transportation improvement programs implemented in the

Belomar Region. The model also generated emission factors for

two future year scenarios 2015 and 2022.

The annual emission estimates were based on a single-season

approach for temperature and relative humidity. The data used

in this report, taken from the Wheeling Airport collection center,

is representative of 12 months in 2009. Data entered into a

spreadsheet provided by U.S. EPA converted the Mobile6 to get

the correct data for the MOVES model.

On-Road Mobile Emission Estimations

Tables 2 through 7 contain the results of the emissions analysis for the

appropriate years. All emissions estimations are expressed in tons per

year (tpy).

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

2005 2008 2015 2022

PM2.• (tpy) 105.74 88.66 45.08 26.32

NOx (tpy) 3,179.52 2,593.58 1,279.25 587.61

502 (tpy) 30.84 9.38 6.72 6.21

Annual VMT 2,460,632 2,475,401 2,537,302 2,599,818

Table 3 - Summary of Ohio Emissions Estimations for On-Road

Mobile Sources

2005 2008 2015 2022

PM2.• (tpy) 105.74 88.66 45.08 26.32

NOx (tpy) 3,179.52 2,593.58 1,279.25 587.61

502 (tpy) 30.84 9.38 6.72 6.21

Annual VMT 2,460,632 2,475,401 2,537,302 2,599,818

Table 4 - Marshall County, West Virginia, Emissions Estimations

for On-Road Mobile Sources

2005 2008 2015 2022

PM... (tpy) 26.37 19.75 9.75 6.86

NOx (tpy) 735.22 574.29 249.11 131.14

502 (tpy) 9.31 2.85 2.08 1.90

AnnualVMT 717,730 732,645 761,241 787,271

19
Table 5 - Ohio County, West Virginia, Emissions Estimations for

On-Road Mobile Sources

2005 2008 2015 2022

PM2.• (tpy) 40.46 35.73 18.29 13.03

NOx (tpy) 1,229.69 1,103.54 486.29 270.94

S02 (tpy) 15.55 5.55 4.12 3.94

AnnualVMT 1,217,316 1,508,349 1,612,721 1,745,734

Table 6 - Summary of West Virginia Emissions Estimations for

On-Road Mobile Sources

2005 2008 2015 2022

PM2.• (tpy) 66.83 55.48 28.04 19.89

NOx (tpy) 1,964.91 1,677.83 735.40 402.08

S02 (tpy) 24.86 8.40 6.20 5.84

Annual VMT 1,935,046 2,240,994 2,373,962 2,533,005

Table 7 - Emissions Estimations Totals for On-Road Mobile

Sources f h or the W eeling Area

2005 2008 2015 2022

PM2.. (tpy) 172.57 144.14 73.12 46.21

NOx (tpy) 5,144.43 4,271.41 2,014.65 989.69

S02 (tpy) 55.70 17.78 12.92 12.05

Annual VMT 4,395,678 4,716,395 4,911,264 5,132,823

The following table identifies the percentage of mobile emissions of all

emissions, for each pollutant in the entire Wheeling area for 2015 and

2022.

Table 8 - Percent of Mobile Emissions for the Wheeling Area in

2015 and 2022

NO, S0, PM2•5

2015 2022 2015 2022 2015 2022

Total (tpy) 16,204.07 15,390.49 36,843.35 31,486.60 3,436.15 3,472.33

Wheeflng Mobile (tpy) 2,014.65 989.69 12.92 12.05 73.12 46.21 Area

% Mobile 12.43% 6.43% 0.04% 0.04% 2.13% 1.33%

Total (tpy) 6,369.93 5,803.97 8,885.54 6,157.16 387.93 331.83

Ohio Mobile (tpy) 1,279.25 587.61 6.72 6.21 45.08 26.32 Portion

%Mobile 20.08% 10.12% 0.08% 0.10% 11.62% 7.93%

20
S02 constitutes less than one percent «1%) of the area's

total S02 emissions in the 2015 and 2022 horizon years.

PM2.5 constitutes just over two percent (2.13%) of the

area's total PM2.5 emissions in the 2015 horizon year and

less than two percent (1.33%) of the area's total PM2.5

emissions in the 2022 horizon year.

NOxemissions are under thirteen percent (12.43%) of the

area's total NOx emissions in the 2015 horizon year and

less than seven percent (6.43%) in the 2022 horizon

year.

Therefore, the Ohio EPA is herein making a finding that the area's

highway emissions for PM2.5, NOx, and S02 are insignificant

contributors to the nonattainment problem of the Wheeling area, as

agreed upon as a part of the interagency consultation process.

Because of this finding it is not necessary to establish mobile emission

budgets for this area in the 2015 and 2022 horizon years. The

nonattainment area meets the 40 CFR 93.109(m) criteria for PM2.5,

NOx, and S02. Throughout this document Ohio EPA demonstrates that

it would be unreasonable to expect that the Wheeling area would

experience enough motor vehicle emissions growth in PM2.5, NOx, and

S02 for a PM2.5 NMOS violation to occur. Moreover, Ohio EPA

demonstrates that the percentage of motor vehicle emissions in the

context of the total SIP inventory, the current state of air quality as

determined by monitoring data, the absence of SIP motor vehicle

control measures, and historical trends and future projections of the

growth of motor vehicle emissions, are evidence enough to consider

mobile source PM2.5, NOx, and S02 insignificant contributors to fine

particles.

Requirement 3 of 5

A demonstration that the projected level of emissions is sufficient to maintain

the PM2.5standard.

Background

In consultation with U.S. EPA, Ohio EPA selected the year 2022

as the maintenance year for this redesignation request. This

document contains projected emissions inventories for 2015

and 2022.

Emission projections for the Wheeling area were performed

using the following approaches:

21
• As performed by ODOT and Belomar, mobile source

emission projections are based on the U.S. EPA MOVES

model. The analysis is described in more detail in

Appendix C. All projections were made in accordance

with "Procedures for Preparing Emissions Projections"

U.S. EPA-45/4-91-019. As discussed above, it was

determined that the mobile emission contribution as a

percent of the total emission inventory from the area is

not significant.

• Emissions inventories are required to be projected to

future dates to assess the influence growth and future

controls will have. LADCO has developed growth and

control files for point, area, and non-road categories.

These files were used to develop Ohio's portion of this

nonattainment area future-year emissions estimates used

in this document. This was done so the inventories used

for redesignation are consistent with modeling performed

in the future. Appendix 0 contains LADCO's technical

support document detailing the analysis used to project

emissions (Base M8).

• For the 2008 attainment year emissions were grown from

the 2005 LADCO modeling inventory, using LADCO's

growth factors, for all sectors except point sources

(electrical generating units and non-eiectrical generating

units). Point source emissions for 2008 were compiled

from Ohio EPA's 2008 annual emissions inventory

database. The 2015 interim year emissions were

estimated based on the 2009 and 2018 LADCO modeling

inventory, using LADCO's growth factors, for all sectors

except non-EGU PM2.5. The 2022 maintenance year is

based on emissions estimates from the 2018 LADCO

modeling, for all sectors except non-EGU PM2.5. NonEGU PM2.5 emissions for 2015 and 2022 were grown

from 2005 and 2009 emissions estimates.

Ohio EPA is identifying emissions projections for 2015 and 2022

for EGUs with implementation of the CAIR program. U.S. EPA

has raised concerns regarding the CAIR program and its

remand. However, Ohio EPA believes these are the most

appropriate and accurate future projections. Although CSAPR

has been stayed by the D.C. Circuit Court (December 30, 2011),

8 http://www.ladco.org/tech/emis/currentlindex.php

22
the Court has ordered U.S. EPA to continue administering CAIR

pending the court's resolution. It is believed that CSAPR will

provide even greater reductions in emissions than the CAIR

program once resolved; therefore, these emissions projections

will be conservative.

On March 10, 2004, the U.S. EPA promulgated the CAIR.

Beginning in 2009, U.S. EPA's CAIR rule requires EGUs in 28

eastern states and the District of Columbia to significantly

reduce emissions of NOx and S02. CAIR replaced the NOx SIP

Call for EGUs. The intent of the CAIR program is for national

NOx 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 required to submit a CAIR SIP as part of

this effort. Ohio submitted a CAIR SIP which was approved by

U.S. EPA on February 1,2007. Revisions to the CAIR SIP were

again submitted on July 15, 2009. The revised CAIR SIP Was

approved as a direct final action on September 25, 2009 (74 FR

48857). As a result of CAIR, U.S. EPA projects that in 2009

emissions of NOx will decrease from a baseline of 264,000 tons

per year to 93,000 tons per year while in 2010 emissions of S02

will decrease from a baseline of 1,373,000 tons per year to

298,000 tons per year, within Ohio. And by 2015 U.S. EPA

projects emissions of NOx will decrease to 83,000 tons per year

while emissions of S02 will decrease to 208,000 tons per year,

within Ohi09

. On December 23, 2008, U.S. EPA's CAIR program

was remanded without vacatur by the D.C. Circuit Court.

As can be seen in Table 9 below, Ohio has seen a significant

decline in the 264,000 tons of NOx and 1,373,000 tons of S02

emitted in 2005. In 2008 and 2009 facilities began preparing for

and implementing control programs to address CAIR10 and

consent decrees.

Table 9 • Reductions in 502 and NOx EGU Emissions

Between 2008 and 2009

Source. Clean Air Markets Quarterly Emissions Tracking

S02 NOx

2008 2009 Channe 2008 2009 Chanae

Ohio 709,444 601,101 15% 235,018 96,351 59%

LADCO States 2,019,036 1,620,071 20% 702,384 393,930 44%

National 7,616,262 5,747,353 25% 2,996,287 1,990,385 34%

."

9 http://www.epa.gov/CAIR/oh.html

10 Under CAIR, NOx reductions are to occur beginning in 2009 while 802 reductions are to occur

beginning in 2010.

11 http://www.epa.gov/airmarkets/quarterlytracking.html

23
Significant reductions also occurred regionally and nationally as

can be seen from the above table. Data is also available for the

first two quarters of 2010, the year S02 reductions are to be

implemented under CAIR:

Table 10 - Reductions in 802 and NOx EGU Emissions

Between the First Half of 2008 and 2010

SO, NO.

2008 2010 Change 2008 2010 Change (1" half) (1" half) (1" half) (1" half)

Ohio 373,798 279,854 25% 130,598 53,187 59%

lADCO States 1,190,497 854,282 28% 419,114 220,907 47%

National 3,895,472 2,502,965 36% 1,487,179 930,148 37%

Source. Clean Air Markets Quarterly EmissIons Tracking

The following was reported by U.S. EPA's Clean Markets

Division:

"Based on emiSSions monitoring data, EPA has observed

substantial reductions in S02 emissions from 2005 to 2009 and

in the first two quarters of 2010 as companies installed more

controls, electric demand declined, and low natural gas prices

made combined-cycle gas-fired units more competitive in

several parts of the country. Thus, even after CAIR's vacatur

and subsequent remand in late 2008, the controls in place

generally have continued to operate, helping to drive continued

progress in reducing emissions.13"

Ohio EPA is in agreement with the analysis by U.S.EPA that the

CAIR program is providing real reductions at this time, Ohio

believes these reductions have assisted with PM2.5 attainment in

this nonattainment area and throughout Ohio.

On July 6, 2011, U.S. EPA finalized a replacement to the CAIR

program, the CSAPR. CSAPR would preserve those initial

reductions achieved under CAIR and provide even greater

reductions in NOx and S02 emissions in 2012 and 2014, ahead

of the 2015 CAIR Phase 2. As a result of CSAPR, U.S. EPA

projected that in 2012 emissions of NOx will decrease to 90,842

tons per year and in 2014 to 85,744 tons per year while S02 will

decrease to 304,022 tons per year in 2012 and 134,333 tons

per year in 2014, within Ohio. In addition, U.S. EPA projections

indicated that as a result of implementation of CSAPR, there will

be no maintenance issues within this entire nonattainment area.

Furthermore, modeling conducted as part of CSAPR projects

12 http://www.epa.gov/airmarkets/quarterlytracking.html

13 http://www.epa.gov/airmarkets/background.htm

24
the counties within this area will not have maintenance issues in

2012 or 2014 even without CSAPR (or CAIR)14 However, on

December 30, 2011, the D.C. Circuit Court stayed CSAPR and

ordered U.S. EPA to continue administering CAIR pending the

court's resolution.

Therefore, it is Ohio EPA's belief it is most appropriate to

evaluate Ohio EPA's demonstration that the projected level of

emissions is sufficient to maintain the annual PM2.5 standard by

assessing future year emissions that include the CAIR program.

The detailed inventory information for the Ohio portion of the

Wheeling area for 2005 is in Appendix B. Emission trends are

an important gauge for continued compliance with the PM2.5

standard. Therefore, Ohio EPA performed an initial comparison

of the inventories for the base year and maintenance years.

Mobile source emission inventories are described in Appendix

C.

Sectors included in the following tables are: Electrical

Generating Unit (EGU-Point); Non-Electrical Generating Unit

(Non-EGU); Non-road Mobile (Non-road); Other Area (Area);

Marine, Aircraft, Rail (MAR); and On-road Mobile (On-road).

Maintenance is demonstrated when the future-year (2022)

projected emission totals are below the 2008 attainment year

totals.

Demonstration

PM2.5

The 2005 and 2008 actual PM2.5 emiSSions data below generally

contains particUlate fraction emissions only and not the condensable

fractions as Ohio EPA did not have a consistent reporting requirement

during those years. U.S. EPA IPM modeling was used to generate

future year EGU emissions with the CAIR program. The IPM modeling

added additional PM2.5 condensable emissions into future years.

Therefore, comparing base and attainment year emissions with the

future year predictions is not accurate in the IPM CAIR modeling. This

step leads to a false perception of significant PM2.5emissions growth.

Modeling performed by LADCO, without CAIR, did not incorporate

added condensable fraction emissions. Although Ohio EPA has stated

14 See supplemental table "Impacts of the Proposed Transport Rule on Counties with Monitors

Projected to have Ozone and/or Fine Particle Air Quality Problems."

25
that it is most appropriate to evaluate future year emiSSions that

include the CAIR program, because of this flaw it will be more accurate

and appropriate for the purposes of PM2.5 to evaluate future year

emissions without the CAIR program.

Table 11 - Belmont County, Ohio PM2.5 Emission Inventory Totals

for Base Year 2005, Estimated 2008, and Projected

2015 and 2022 (toyl - Without CAIR

2005 2008 2015 2022 Safety

Base Attainment Interim Maintenance Margin

EGU Point 93.85 69.58 20.87 0.00 69.58

Non-EGU 3.39 3.39 3.94 4.40 -1.01

Non-road 27.39 24.15 17.38 10.53 13.62

Area 307.93 305.38 297.20 289.22 16.16

MAR 6.21 5.65 3.46 1.36 4.29

On-road 105.74 88.66 45.08 26.32 62.34

TOTAL 544.51 496.81 387.93 331.83 164.98

Table 12 - Marshall County, West Virginia PM2.5 Emission

Inventory Totals for Base Year 2005, Estimated 2008,

and Proiected 2015 and 2022 (tpyl- With CSAPR

Sector 2005 2008 2015 2022 Safety

Base Attainment Interim Maintenance Margin

EGU Point 3,825.84 4.440.39 2,121.29 2,271.39 2,169.00

Non-EGU 525.15 409.68 315.60 272.24 137.44

Non-road 12.48 10.57 7.30 5.19 5.38

Area 315.92 263.37 258.15 259.44 3.93

MAR 25.16 8.43 8.49 8.54 -0.11

On-road 26.37 19.75 9.75 6.86 12.89

TOTAL 4,730.92 5,152.19 2,720.58 2,823.66 2,328.53

26
Table 13· Ohio County, West Virginia PM2.5 Emission Inventory

Totals for Base Year 2005, Estimated 2008, and

Proiected 2015 and 2022 (tov) - With CSAPR

Sector 2005 2008 2015 2022 Safety

Base Attainment Interim Maintenance Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 10.63 4.01 4.08 4.15 -0.14

Non-road 20.76 19.27 14.84 10.55 8.72

Area 262.77 293.45 290.43 289.11 4.34

MAR 37.56 0.00 0.00 0.00 0.00

On-road 40.46 35.73 18.29 13.03 22.70

TOTAL 372.18 352.46 327.64 316.84 35.62

Table 14 - Wheeling Area PM2.5 Emission Inventory Totals for

Base Year 2005, Estimated 2008, and projected 2015

and 2022 (tpy) - Without CAIR (Ohio) and With CSAPR

(West Vlrainial

PM2.5 2005 2008 2015 2022 Safety

Base Attainment Interim Maintenance Margin

Belmont 544.51 496.81 387.93 331.83 164.98

Marshall, WV 4,730.92 5,152.19 2,720.58 2,823.66 2,328.53

Ohio,WV 372.18 352.46 327.64 316.84 35.62

COMBINED

PM2.5 TOTAL 5,647.61 6,001.46 3,436.15 3,472.33 2,529.13

NO~

Table 15 • Belmont County, Ohio NOx Emission Inventory Totals

for Base Year 2005, Estimated 2008, and Projected

2015 and 2022 (tpv) - With CAIR

Sector 2005 2008 2015 2022 Safety

Base Attainment Interim Maintenance Margin

EGU Point 4,149.93 4,167.94 4,477.58 4,738.00 -570.06

Non-EGU 22.76 20.67 20.19 18.90 1.77

Non-road 222.46 196.86 145.51 93.37 103.49

Area 284.66 286.90 286.77 287.15 -0.25

MAR 261.85 247.24 160.63 78.94 168.30

On-road 3,179.52 2,593.58 1,279.25 587.61 2,005.97

TOTAL 8,121.18 7,513.19 6,369.93 5,803.97 1,709.22

27
Table 16 • Marshall County, West Virginia NOx Emission Inventory

Totals for Base Year 2005, Estimated 2008, and

Projected 2015 and 2022 (tpy) - With CSAPR

Sector 2005 2008 2015 2022 Safety

Base Attainment Interim Maintenance Margin

EGU Point 31,540.79 23,268.59 6,067.05 6,365.68 16,902.91

Non-EGU 3,130.92 2,758.97 2,341.27 2,165.90 593.07

Non-road 112.88 107.77 85.87 69.45 38.32

Area 184.10 81.12 83.55 85.98 -4.86

MAR 671.24 248.79 250.36 251.93 -3.14

On-road 735.22 574.29 249.11 131.14 443.15

TOTAL 36,375.15 27,039.53 9,077.21 9,070.08 17,969.45

Table 17 . Ohio County, West Virginia NOx Emission Inventory

Totals for Base Year 2005, Estimated 2008, and

Projected 2015 and 2022 (tpy) - With CSAPR

Sector 2005 2008 2015 2022 Safety

Base Attainment Interim Maintenance Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 5.65 5.62 5.72 5.83 -0.21

Non-road 170.06 157.81 113.22 87.17 70.64

Area 613.18 150.84 151.63 152.43 -1.59

MAR 972.48 0.07 0.Q7 0.07 0.00

On-road 1,229.69 1,103.54 486.29 270.94 832.60

TOTAL 2,991.06 1,417.88 756.93 516.44 901.44

Table 18 • Wheeling Area NOx Emission Inventory Totals for Base

Year 2005, Estimated 2008, and Projected 2015 and

2022 (tpy) - With CA/R (Ohio) and With CSAPR (West

Virginia)

NOx 2005 2008 2015 2022 Safety

Base Attainment Interim Maintenance Margin

Belmont 8,121.18 7,513.19 6,369.93 5,803.97 1,709.22

Marshall, WV 36,375.15 27,039.53 9,077.21 9,070.08 17,969.45

Ohio, WV 2991.06 1417.88 756.93 516.44 901.44

COMBINED

NOxTOTAL 47,487.39 35,970.60 16,204.07 15,390.49 20,580.11

28
Table 19 - Belmont County, Ohio 502 Emission Inventory Totals

for Base Year 2005, Estimated 2008, and Projected

2015 and 2022 CtDvl- With CAIR

Sector 2005 2008 2015 2022 Safety

Base Attainment Interim Maintenance Margin

EGU Point 37,329.95 15,126.00 8,783.33 6,065.04 9,060.96

Non-EGU 0.13 0.07 0.10 0.11 -0.04

Non-road 21.98 8.13 1.37 0.31 7.82

Area 93.50 92.24 87.16 82.29 9.95

MAR 22.84 16.33 6.86 3.20 13.13

On-road 30.84 9.38 6.72 6.21 3.17

TOTAL 37,499.24 15,252.15 8,885.54 6,157.16 9,094.99

Table 20 - Marshall County, West Virginia 502 Emission Inventory

Totals for Base Year 2005, Estimated 2008, and

Proiected 2015 and 2022 ItDvl- With C5APR

Sector 2005 Base 2008 2015 2022 Safety

Attainment Interim Maintenance Margin

EGU Point 96,377.83 35,073.59 14,007.73 12,797.38 22,276.21

Non-EGU 19,110.36 16,502.76 13,692.13 12,285.14 4,217.62

Non-road 10.49 1.80 0.16 0.17 1.63

Area 101.60 64.42 62.30 60.19 4.23

MAR 31.27 12.93 13.02 13.10 -0.17

On-road 9.31 2.85 2.08 1.90 0.95

TOTAL 115,640.86 51,658.35 27,777.42 25,157.88 26,500.47

Table 21 - Ohio County, West Virginia 502Emission Inventory

Totals for Base Year 2005, Estimated 2008, and

Proiected 2015 and 2022 ltpvl- With C5APR

Sector 2005 Base 2008 2015 2022 Safety

Attainment Interim Maintenance Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 1.47 1.21 1.24 1.26 -0.05

Non-road 14.76 2.60 0.30 0.32 2.28

Area 231.93 183.41 174.73 166.04 17.37

MAR 44.14 0.00 0.00 0.00 0.00

On-road 15.55 5.55 4.12 3.94 1.61

TOTAL 307.85 192.77 180.39 171.56 21.21

29
Table 22 • Wheeling Area S02 Emission Inventory Totals for Base

Year 2005, Estimated 2008, and Projected 2015 and

2022 (tpy) - With CAIR (Ohio) and With CSAPR (West

Virginia)

S02 2005 2008 2015 2022 Safety

Base Attainment Interim Maintenance Margin

Belmont 37,499.24 15,252.15 8,885.54 6,157.16 9,094.99

Marshall, WV 115,640.86 51,658.35 27,777.42 25,157.88 26,500.47

Ohio,WV 307.85 192.77 180.39 171.56 21.21

COMBINED

S02TOTAL 153,447.95 67,103.27 36,843.35 31,486.60 35,616.67

PMg.5, NOll' and SOg

Table 23 • Wheeling Area Comparison of 2008 Attainment Year and

2015 and 2022 Projected Emission Estimates (tpy)

2008 Base 2015 2015 Projected 2022 2022 Projected

Interim Decrease Maintenance Decrease

PM,., 6,001.46 3,436.15 2,565.31 3,472.33 2,529.13

NOx 35,970.60 16,204.07 19,766.53 15,390.49 20,580.11

SO, 67,103.27 36,843.35 30,259.92 31,486.60 35,616.67

As shown in the table above (Table 23), PM2.

5 emissions in the

nonattainment area are projected to decrease by 2,565.31 tpy in

2015 and 2,529.13 tpy in 2022. NOx emissions in the

nonattainment area are projected to decrease by 19,766.53 tpy

in 2015 and 20,580.11 tpy in 2022. 802 emissions in the

nonattainment area are projected to dedine by 30,259.92 tpy in

2015 and 35,616.67 tpy in 2022.

In general, EGU source emissions show decreases due to the

CAIR program. Cleaner vehicles and fuels are expected to be

in place in 2009 and 2018, and the CSAPR will be implemented

in 2012 and 2014 and these programs should cause an overall

drop in all three pollutants emissions. Decreases from U.S. EPA

rules covering Tier 2 Motor Vehide Emissions Standards and

Gasoline Sulfur Control Requirements15, Highway Heavy-Duty

Engine RUle16, and the Non-Road Diesel Engine Rule17 are

factored into the changes.

15 http1/www.epa.gov/fedrgstr/EPA-AIR/2000/February/Day-10/a19a.htm

16 http://www.epa.gov/fedrgstr/EPA-AIR/1997/0ctober/Day-21/a27494.htm

17 http://www.epa.gov/fedrgstr/EPA-AIR/1998/0ctober/Day-23/a24836.htm

30
In addition to the above, R.E. Burger First Energy station in

Belmont County implemented changes in 2008. Two units, #4

and #5 installed advanced NOx Controls (SNCR) in 2008 and

by 2012, both units are required, through a federally enforceable

consent decree, to operate continuously advanced NOx controls

(SNCR) and to repower the units to burn mostly biomass (no

scrubbers are required). However, the biomass fuel project was

canceled and the two 156 MW units were permanently shut

down in December 2010. The two smaller 94 MW units will only

be used for peak demand.

Requirement 4 of 5

A demonstration that improvement in air quality between 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.

Background

Ambient air quality data from all monitoring sites indicate that air

quality met the NMOS for PM2.5 in 2008-2010. U.S. EPA's

redesignation guidance (p 9) states: "A state may generally

demonstrate maintenance of the NMOS by either showing 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 NMOS."

Demonstration

Permanent and enforceable reductions of PM2.5, NOx, and S02

emissions have contributed to the attainment of the annual PM2.5

standard. Some of these reductions were realized due to the

application of tighter federal standards on new vehicles. Also Title IV of

the CM, the NOx SIP Call, CAIR, and federal consent decrees

required the reductions of S02 and NOx emissions from utility sources.

Reductions achieved are discussed in greater detail under Chapter

Five.

31
Table 24 - Wheeling Area Comparison of 2005 Base Year and

2008 Attainment Year On-Road and EGU Reductions

2005 2008

On-road PM2.5 172.57 144.14

On-road NOx 5144.43 4271.41

On-road 802 55.70 17.78

EGU PM25 3,919.69 4,509.97

EGU NOx 35,690.72 27,436.53

EGU 802 133,707.78 50,199.59

Requirement 5 of 5

Provisions for future annual updates of the inventory to enable tracking of the

emission levels, including an annual emission statement from major sources.

Demonstration

In Ohio, major point sources in all counties are required to

submit air emissions information annually, in accordance with

U.S. EPA's Consolidated Emissions Reporting Rule (CERR).

Ohio EPA prepares a new periodic inventory for all PM2.5

precursor emission sectors every three years. These PM2.5

precursor inventories will be prepared for future years as

necessary to comply with the inventory reporting requirements

established in the CFR. Emissions information will be

compared to the 2005 base year and the 2022 projected

maintenance year inventories to assess emission trends, as

necessary, and to assure continued compliance with the annual

PM2.5standard.

32
CHAPTER FIVE

CONTROL MEASURES AND REGULATIONS

CM Section107 (d)(3)(E)(ii), 107(d)(3)(iv), and 107(d)(3)(E)(v)

Requirement 1 of 6

Section 172(c)(1) of the 1990 Clean Air Act Amendments requires states with

nonattainment areas to implement RACM and RACT.

Background

Section 172(c)(1) of the 1990 Clean Air Act Amendments

requires states with nonattainment areas to submit a SIP

providing for implementation of all reasonably available control

measures and as expeditiously as practicable (including such

reductions in emissions from existing sources in the area as

may be obtained through the adoption, at a minimum, of

reasonable available control technology).

U.S. EPA's Implementation Rule interprets this requirement in

great detail. Under U.S. 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 contribute 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.

The Implementation Rule also provides for a presumption that in

States that fulfill their CAIR emission reduction requirements,

EGU compliance with CAIR is equivalent to RACM/RACT.

Demonstration

In 1972, 1980, and 1991, Ohio promulgated rules requiring

reasonably available controls measures for particulate

emissions from stationary sources.

Statewide RACT rules have been applied to all new sources

locating in Ohio since that time. RACT requirements are

incorporated into permits along with monitoring, recordkeeping,

and reporting necessary to ensure ongoing compliance. Ohio

EPA also has an active enforcement program to address

33
violations discovered by field office staff. The Ohio RACT rules

for particulate matter are found in OAC Chapter 3745-1718.

In addition, Ohio EPA promulgated NOx SIP Call rules (OAC

Chapter 3745-1419), CAIR (OAC Chapter 3745-1092°), and NOx

Reasonab'X Available Control Technology rules (OAC Chapter

3745-1102 ) over the past five years. Emissions from EGUs

make up a significant contribution to Ohio's inventory. Beginning

in 2009, Ohio implemented CAIR which has, and will, provide

for significant reductions in NOx, PM2.5, and S02 until such time

CSAPR is implemented. Then the CSAPR will provide for even

greater reductions.

As part of a larger initiative, LADCO, in consultation with two

contractors, performed a series of studies exploring control

measures for reducing both ozone precursors and PM2.5

precursors in Ohio, Illinois, Indiana, Michigan, and Wisconsin

area. The first consultant, MACTEC, prepared a series of white

papers22 researching different stationary source categories. The

results were compiled into two reports23. The second consultant,

Environ, investigated control options for mobile sources. The

results were compiled into two reports24. The stationary and

mobile source sectors (and associated control measures) were

selected by the LADCO States based on several factors

presented in the report (See Chapter 2).

Photochemical modeling was then conducted (as part of

LADCO Round 4 modeling) to assess the air quality benefit of

the candidate control measures and a modeling report was

developed25. Based on the results, the LADCO project team felt

it would not be possible to advance the attainment date for

PM2.5. Ohio EPA, in its attainment demonstration submitted on

July 18, 2008, demonstrated (using a weight of evidence

18 http://www.epa.ohio.gov/dapc/regs/3745_17.aspx

19 http://www.epa.ohio.gov/dapclregs/3745_14.aspx

20 http://www.epa.ohio.gov/dapc/regs/3745_109.aspx

21 http://www.epa.ohio.gov/dapc/regs/3745_110.aspx

22 http://www.ladco.org/reports/control/white_papers

23

http://www.ladco.org/reports/controllfinaUeportsfidentification_and_evaluation_oCcandidate_controLm

easures_Lapril_2005.pdf;

http://www.ladco.0rgireports/controllflnaUeports/identification_and_evaluation_of_candidate_controLm

easuresJijune_2006.pdf

24

http://www.ladco.org/reports/control/final_reports/final_report_evaluation_oCcandidate_mobile_source_

controLmeasures_february_2006.pdf;

http://www.ladco.org/reports/control/final_reportslfinaUeport_evaluation_of_candldate_mobile_source_

control measures for ladco states in 2009 and 2012 march 2007.pdf

25 http;;/www.ladco.org/reports/controliiTIodenng/round4~modeling.pdf

34
approach) that attainment would be achieved in this area by

2009. Because of a projected 2009 attainment date, it would not

have been reasonably possible or practicable for Ohio to

develop RACT/RACM requirements, promulgate regulations

and implement a control program prior to the projected

attainment date.

Requirement 2 of 6

Section 172(c)(2) of the 1990 CM Amendments requires attainment

demonstration SIPs for nonattainment areas to show reasonable further

progress (RFP).

Background

U.S. EPA's Implementation Rule requires RFP only for any area

which a State projects an attainment date beyond 2010. The

RFP would provide emission reductions showing linear progress

between 2002 and 2009. If a State demonstrates attainment will

occur by 2010 or earlier, U.S. EPA considers the attainment

demonstration to demonstrate achievement of RFP.

Demonstration

In Ohio's attainment demonstration submitted on July 18, 2008,

Ohio demonstrated (using a weight of evidence approach) that

attainment would be achieved in this area by 2009; and

therefore, it was not necessary to submit a separate RFP plan.

Requirement 3 of 6

Section 172(c)(3) requires states to submit a comprehensive inventory of

actual emissions.

Background

Section 172(c)(3) requires states to submit a comprehensive

inventory of actual emissions in the area, including the

requirement for periodic revisions as determined necessary. 40

CFR 51.1008 requires such inventory to be submitted within

three years of designation and requires a baseline emission

inventory for calendar year 2002 or other suitable year to be

used for attainment planning.

Demonstration

The 2005 comprehensive inventory was submitted to U.S. EPA

with Ohio's PM2.5 attainment demonstration SIP submitted on

JUly 18, 2008. It was then subsequently revised and

resubmitted on June 7, 2010.

35
Ohio also updates its inventory in accordance with U.S. EPA's

CERR rule (Le. emissions statements). Ohio EPA submitted its

emissions statement SIP on March 18, 1994 which was

approved by U.S. EPA on October 13,1995 (59 FR 51863). As

discussed in Chapter 4 (Requirement 4), Ohio EPA submits,

and commits to submit, emission inventories (statements) every

three years.

Requirement 4 of 6

Evidence that control measures required in past PM2.5 SIP revisions have

been fully implemented.

Background

In addition to the historic RACT requirements for PM, the U.S.

EPA NOx 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.

Ohio passed this rule in 2001. NOx SIP Call requirements are

incorporated into permits along with monitoring, recordkeeping,

and reporting necessary to ensure ongoing compliance. Ohio

EPA also has an active enforcement program to address

violations discovered by field office staff. Compliance is tracked

through the Clean Air Markets data monitoring program.

Beginning in 2004, this rule accounts for a reduction of

approximately 31 percent of all NOx emissions statewide

compared to previous uncontrolled years. The other 21 states

also have adopted these rules.

On March 10, 2004, the U.S. EPA promulgated the CAIR.

Beginning in 2009, U.S. EPA's CAIR rule requires EGUs in 28

eastern states and the District of Columbia to significantly

reduce emissions of NOx and S02. CAIR replaced the NOx SIP

Call for EGUs. National NOx emissions will be cut from 4.5

million tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3

million tons in 2018 in 28 states. States were required to submit

a CAIR SIP as part of this effort. Ohio submitted a CAIR SIP

which was approved by U.S. EPA on February 1, 2007.

Revisions to the CAIR SIP were again submitted on July 15,

2009. The revised CAIR SIP was approved as a direct final

action on September 25,2009 (74 FR 48857).

Demonstration

Controls for EGUs under the NOx SIP Call formally commenced

May 31, 2004. Emissions covered by this program have been

generally trending downward since 1998 with larger reductions

occurring in 2002 and 2003. Data taken from the U.S. EPA

36
Clean Air Markets web site, quantify the gradual NOx reductions

that have occurred in Ohio as a result of Title IV of the 1990

CM Amendments and the beginning of the NOxSIP Call Rule.

Ohio developed the NOxBudget Trading Program rules in OAC

Chapter 3745_1426 in response to the SIP Call. OAC Chapter

'3745-14 regulates EGUs and certain non-EGUs under a cap

and trade program based on an 85 percent reduction of NOx

emissions from EGUs and a 60 percent reduction of NOx

emissions from non-EGUs, compared to historical levels. This

cap was in place through 2008, at which time the CAIR program

superseded it as discussed above. Requirement 3 of 5 under

Chapter 4 above discussed the reductions Ohio has seen as a

result of CAIR.

On April 21, 2004, U.S. EPA published Phase II of the NOx SIP

Call that establishes a budget for large (greater than 1 ton per

day emissions) stationary internal combustion engines. Ohio

EPA's OAC rule 3745-14-12 addresses stationary internal

combustion engines, all used in natural gas pipeline

transmissions. U.S. EPA approved this revision to the SIP on

April 4, 2008. An 82 percent NOx reduction from 1995 levels is

anticipated. Completion of the compliance plan occurred by May

1, 2006, and the compliance demonstration began May 1, 2007.

Tier \I Emission Standards for Vehicles and Gasoline Sulfur

Standards

In February 2000, U.S. EPA finalized a federal rule to

significantly reduce emissions from cars and 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

will apply nationwide. The federal rules will phase in between

2004 and 2009. U.S. EPA has estimated that NOx 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.

26 htlp://www.epa.ohio.gov/dapc/regs/3745_14.aspx

37
Heavy-Duty Diesel Engines

In July 2000, U.S. EPA issued a final rule for Highway Heavy

Duty Engines, a program which includes low-sulfur diesel fuel

standards, which will be phased in from 2004 through 2007.

This rule applies to heavy-duty gasoline and diesel trucks and

buses. This rule will result in a 40 percent reduction in NOx from

diesel trucks and buses, a large sector of the mobile sources

NOx inventory. It also estimated the level of sulfur in highway

diesel fuel will be reduced by 97 percent by mid-2006.

Clean Air Non-road Diesel Rule

In May 2004, U.S. EPA issued the Clean Air Non-road Diesel

Rule. This rule applies to diesel engines used in industries such

as construction, agriculture, and mining. It also contains a

cleaner fuel standard similar to the highway diesel program.

The new standards will cut emissions from non-road diesel

engines by more than 90 percent. Non-road diesel equipment,

as described in this rule, currently accounts for 47 percent of

diesel particulate matter (PM) and 25 percent of NOx from

mobile sources nationwide. Sulfur levels will be reduced in nonroad diesel fuel by 99 percent from current levels, from

approximately 3,000 parts per million (ppm) now to 15 ppm in

2009. New engine standards take effect, based on engine

horsepower, starting in 2008. Together, these rules will

substantially reduce local and regional sources of PM2.5

precursors.

Requirement 5 of 6

Acceptable provisions to provide for new source review.

Background

Ohio has a longstanding and fully implemented New Source

Review ~NSR) program. This is addressed in OAC Chapter

3745-312 . The Chapter includes provisions for the Prevention

of Significant Deterioration (PSD) permitting program in OAC

rules 3745-31-01 to 3745-31-20. Ohio's PSD program was

conditionally approved on October 10, 2001 (66 FR 51570) and

received final approval on January 22, 2003 (68FR 2909) by

U.S. EPA as part of the SIP.

Demonstration

Any facility that is not listed in the 2005 emission inventory, or

for the closing of which credit was taken in demonstrating

attainment, will not be allowed to construct, reopen, modify, or

27 http://www.epa.ohio.gov/dapclregs/3745_31.aspx

38
reconstruct without meeting all applicable NSR requirements.

Once the area is redesignated, Ohio EPA will implement NSR

through the PSD program.

Requirement 6 of 6

Assure that all existing control measures will remain in effect after

redesignation unless the State demonstrates through modeling that the

standard can be maintained without one or more control measures.

Demonstration

Ohio commits to maintaining the aforementioned control

measures after redesignation. Ohio hereby commits that any

changes to its rules or emission limits applicable to PMZ.5, SOz,

and NOx as required for maintenance of the annual PMz.5

standard in the Wheeling area, will be submitted to U.S. EPA for

approval as a SIP revision.

Ohio, through Ohio EPA's Legal office, 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 PMz.5

precursors in the Wheeling area.

39
CHAPTER SIX

CONTINGENCY MEASURES

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

Requirement 1 of 4

A commitment to submit a revised plan eight years after redesignation.

Demonstration

Ohio hereby commits to review its maintenance plan eight years

after redesignation, as required by Section 175(A) of the CAA.

Requirement 2 of 4

A commitment to expeditiously enact and implement additional contingency

control measures in response to exceeding specified predetermined levels

(triggers) or in the event that future violations of the ambient standard occur.

Demonstration

Ohio hereby commits to adopt and expeditiously implement

necessary corrective actions in the following circumstances:

Warning Level Response:

A warning level response shall be prompted whenever the PM2.5

average of the weighted annual mean of 15.5 1J91m3 occurs in a

single calendar year within the maintenance area. A warning

level response will consist of a study to determine whether the

PM2.5 value indicates a trend toward higher PM2.5 values or

whether emissions appear to be increasing. The study will

evaluate whether the trend, if any, is likely to continue 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 expeditiously as possible, but in no

event later than 12 months from the conclusion of the most

recent calendar year.

Should it be determined through the warning level study that

action is necessary to reverse the noted trend, the procedures

for control selection and implementation outlined under "action

level response" shall be followed.

Action Level Response:

An action level response shall be prompted whenever a twoyear average of the weighted annual means of 15.0 IJg1m3 or

greater occurs within the maintenance area. A violation of the

40
standard (three-year average of the weighted annual means of

15.0 IJg/m3 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, malfunction, or

noncompliance with a permit condition or rule requirement, Ohio

EPA in conjunction with the metropolitan planning organization

or regional council of governments, will determine additional

control measures needed to assure future attainment of the

NAAQS for annual PM2.5. 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 action level. Ohio EPA will also consider the

timing of an action level trigger and determine if additional,

significant new regulations not currently included as part of the

maintenance provisions will be implemented in a timely manner

and will constitute our response.

Control Measure Selection and Implementation

Adoption of any additional control measures is subject to the

necessary administrative and legal process. This process will

include publication of notices, an opportunity for pUblic hearing,

and other measures required by Ohio law for rulemaking.

If a new measure/control is already promulgated and scheduled

to be implemented at the federal or State level, and that

measure/control is determined to be sufficient to address the

upward trend in air quality, additional local measures may be

unnecessary. Furthermore, Ohio will submit to U.S. EPA an

analysis to demonstrate the proposed measures are adequate

to return the area to attainment.

Requirement 3 of 4

A list of potential contingency measures that would be implemented in such

an event.

Demonstration

Contingency measures to be considered will be selected from a

comprehensive list of measures deemed appropriate and

effective at the time the selection is made. The selection of

measures will be based on cost-effectiveness, emission

reduction potential, economic and social considerations or other

factors that Ohio EPA deems appropriate. Ohio EPA will solicit

input from all interested and affected persons in the

maintenance 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

41
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 compressed natural

gas) and diesel retrofit programs for fleet vehicle operations.

3) Tighter PM2.5, 802, and NOx emissions offsets for new and

modified major sources.

4) Impact crushers located at recycle scrap yards - upgrade wet

suppression.

5) Concrete manufacturing - upgrade wet suppression.

6) Additional NOx 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.

Requirement 4 of 4

A list of PM2.5, 802, and NOx sources potentially sUbject to future additional

control requirements.

Demonstration

The following is a list of PM2.5, 802, and NOxsources potentially

subject to future controls.

• ICI Boilers - 802 and NOx controls;

• EGUs;

• process heaters;

• internal combustion engines;

• combustion turbines;

• other sources greater than 100 tons per year;

• fleet vehicles;

• concrete manufacturers;

• aggregate processing plants;

42
CHAPTER SEVEN

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public

comment concerning the draft redesignation petition and maintenance plan in

the widely distributed county publications.

The public hearing to receive comments on the redesignation request was

held at Martins Ferry Library in Martins Ferry, Ohio. The pUblic comment

period closed on April 5, 2012. Appendix E includes a copy of the public

notice, certification of publication, and the transcript from the public hearing.

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CHAPTER EIGHT

CONCLUSIONS

The Wheeling annual PM2.5 nonattainment area has attained the 1997 annual

NMOS for PM2.5 and complied with the applicable provisions of the 1990

Amendments to the CM regarding redesignations of PM2.5 nonattainment

areas. Documentation to that effect is contained herein. Ohio EPA has

prepared a redesignation request and maintenance plan that meet the

requirements of Section 110 (a)(1) ofthe 1990 CM.

Based on this presentation, the Wheeling annual PM2.5 nonattainment area

meets the requirements for redesignation under the CM and U.S. EPA

guidance. Ohio has performed an analysis that shows the air quality

improvements are due to permanent and enforceable measures.

Furthermore, because this area is subject to significant transport of pollutants,

significant regional S02 and NOx reductions will ensure continued compliance

(maintenance) with the standard with an increasing margin of safety.

The State of Ohio hereby requests that the Wheeling annual PM2.5

nonattainment area be redesignated to attainment simultaneously with U.S.

EPA approval of the maintenance plan provisions contained herein.

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