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 77W. Jackson Blvd. Chicago, IL

### 60604

Re: PM2.5 Redesignation Requestforthe 

### 1997 PM2

.5Annual Standard forthe Wheeling, WV-OH Area

DearAdministrator Hedman:
I am writing to formally request a redesignation to attainment ofthe Ohio portion ofthe Wheeling, WV-OH area (Belmont County, Ohio) with respect to the 

### 1997 PM2

.5annual standard. The enclosed submittal combines the redesignation request and the required maintenance plan forthis 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 airqualitydata. 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 attainmentand maintenance plan fortheWheeling area. The enclosed information, compiled bythe Ohio Environmental Protection Agency (Ohio EPA) in cooperation with the Ohio Department ofTransportation (Ohio DOT), the West Virginia Department of Environmental Protection (WVDEP), and the West Virginia Department ofTransportation (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 noticewas also published in a newspaperofgeneral circulation in Martins Fetty, Ohio. The public hearing forthis package was held on April 

### 5, 2012 in Martins Ferry, Ohio. Notestimonywas provided, norwere anycomments received.

50 West Town street,**Su~e** 700 P.O. Box 1049 Columbus,OH 43216-1049 614I644 3020 61416443184 (fax) www.epa.ohio.govIf 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 ofAir Pollution Control, Ohio EPA
Enclosure

# REDESIGNATION REQUESTAND MAINTENANCE PLAN FOR THE OHIO PORTION OF THE WHEELING, WV-OH ANNUAL PM2
.5 

# NONATTAINMENTAREA
Belmont County, Ohio

Prepared by: Ohio Environmental Protection Agency Division ofAir Pollution Control

April 2012This page left intentionallyblank

### TABLE OF CONTENTS ChapterOne Introduction 1 Geographical description and background 2 Status ofairquality 3 ChapterTwo Requirementsfor redesignation 4 ChapterThree PM2

.5monitoring 8 Annual PM2

. 5NAAQS 8 Ambient data quality assured 9 Three completeyears ofdata 9 Commitmentto 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 forfuture update 32 Chapter Five Control measures and regulations 33 Nonattainmentareasto implement RACM and RACT 33 Show Reasonable Further Progress (RFP) 35 Emission inventories 35 Implementation ofpastSIP revisions 36 New source review provisions 38 Assurance ofcontinued controls 39 Chapter Six Contingency measures 40 Commitmentto revise plan 40 Commitmentfor contingency measures 40 Potential contingency measures 41 Listof PM25, S02, and NOxsources 42 Chapter Seven Public participation 43 Chapter Eight Conclusions 44Figure 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 oftheWheeling WV-OH nonattainmentarea and monitorlocations 9 PM25Annual Mean Trends LADCO States 11 PM25Annual Mean Trends Midwest States 11 PM2

. 5Annual Mean National Trends 12
TABLES Monitoring Data forWheeling WV-OH Area for2008

- 2010 10 Belmont County, Ohio Emission EstimationsforOn-road Mobile Sources 19 SummaryofOhio Emissions EstimationsforOn-road Mobile Sources 19 Marshall County, WestVirginia Emission EstimationsforOn-road Mobile Sources 19 Ohio County, WestVirginia Emission Estimations forOn-road Mobile Sources.20 SummaryofWestVirginia Emission EstimationsforOn-Road Mobile Sources .20 Emission Estimations TotalsforOn-road Mobile Sources forthe Wheeling Area 20 PercentofMobile EmissionsfortheWheeling Area in 2015 and 2022 20 Reductions in S02 and NOxEGU Emissions Between 2008 and 2009 23 Reductions in S02 and NOx EGU Emissions Between the First Halfof2008 and 2010 24 Belmont County, Ohio PM25 Emission InventoryTotalsfor BaseYear2005, Estimated 2008, and Projected 2015 and 2022 (tpy) - Without CAIR. 26 Marshall County, WestVirginia PM25 Emission InventoryTotalsfor BaseYear 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

- With CSAPR.

.......26 Ohio County, WestVirginia PM25 Emission InventoryTotals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) - With CSAPR.

.......27 Wheeling Area PM25 Emission InventoryTotal for Base Year2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

- Without CAIR (Ohio) and With CSAPR (WestVirginia) 27 Belmont County, Ohio NO, Emission InventoryTotal for Base Year2005, Estimated 2008, and Projected 2015 and 2022 (tpy) - With CAIR 27 Marshall County, WestVirginia NO, Emission InventoryTotal for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

- With CSAPR.

.......28 Ohio County, WestVirginia NO, Emission InventoryTotal for Base Year2005, Estimated 2008, and Projected 2015 and 2022 (tpy) - With CSAPR. 28 Wheeling Area NO, Emission InventoryTotal forBase Year2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

- With CAIR (Ohio) and With CSAPR (WestVirginia) 28 Belmont County, Ohio S02 Emission InventoryTotal for BaseYear2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

- With CAIR 29 Marshall County, WestVirginia S02 Emission InventoryTotal for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

- With CSAPR.

.......29 Ohio County, WestVirginia S02 Emission InventoryTotal for Base Year2005, Estimated 2008, and Projected 2015 and 2022 (tpy)

- With CSAPR 29 Wheeling Area S02 Emission InventoryTotalsfor Base Year2005, Estimated 2008, and Projected 2015 and 2022 (tpy) - With CAIR (Ohio) and With CSAPR (WestVirginia) 30 iiTable 23
Table 24 Wheeling Area Comparison of2008 Attainmentyearand 2015 and 2022 Projected Emission Estimates (tpy) 30 Wheeling Area Combined Comparison of2005 BaseYearand 2008 Attainment YearOn-Road and EGU Reductions 32

APPENDICES
A Air Quality System (AQS) Data B Ohio 2005 SIP BaseYear Inventory Discussion C Mobile Source Emissions InventoryfortheWheeling PM25 NonattainmentArea D LADCO Technical Support Documents E Public Participation Documentation

iiiThis page left intentionallyblank

ivREDESIGNATION REQUESTAND MAINTENANCE PLAN FORTHE OHIO PORTION OF THE WHEELING, WV-OH ANNUAL PM2.5 NONATTAINMENTAREA
BelmontCounty, Ohio



### CHAPTER ONE
Introduction The Clean 

### AirAct (CAA), as amended, requires each State with areas failing to meetthe annual PM2.51 National AmbientAir 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 PM10standard 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 percubic 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-yearaverage ofthe 98th percentile of24-hourconcentrations.
The revised NAAQS was legally challenged in the U.S. Court ofAppeals 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 airquality 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 arbitrarilyand capriciously in establishing the specific levels ofthe 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 ormold spores). Fine particle pollution or PM'.5 describes particulate matter that is 2.5 micrometers in diameter and smaller

- 1/30ththe diameterof a human hair. Fine particle pollution can be emitted directly orformed secondarily in the atmosphere.claims that the U.S. EPA had acted arbitrarily and capriciously in setting the levels ofthestandards. On December 17, 2004, U.S. EPA promulgated the initial PM2

.5 nonattainment areas designations forthe PM2

.5standards across the country. Modifications to those designations were made and an effective datewas set at April 5, 2005. Unlike Subpart 2 of the CM Amendments of 1990 which defined five ozone nonattainment classifications forthe 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

.5nonattainment areas to submit a plan within three years ofthe effective date ofthe designations (April 5, 2008) detailing howthe PM2

.5 standards will be attained by April 5, 2010. Ohio EPA submitted its attainmentdemonstration forthe entire StateofOhio on July 16, 2008. Section 107(d)(3)(E) ofthe CM allows statesto request nonattainmentareas 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 nonattainmentto attainment:
• A determination that the area has attained the PM2

.5 standard.

• An approved State Implementation Plan (SIP) for the area underSection 11 O(k). • A determination that the improvement in airquality is due to permanentand enforceable reductions in emissions resulting from implementation of the SIP and other federal requirements. • Afullyapproved maintenance plan underSection 175(A). • Adetermination thatall Section 110and 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 underChapterThree.
The Wheeling area has not previously been subject to nonattainment area rulemakings forfine particles.

2As 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 EPAwas required to develop a plan to reduce oxides of nitrogen (NOx ), sulfur dioxide (S02) and direct PM2

.5emissions and to demonstratethatthe areawill meet the federal annual air quality standard by April 5, 2010. Ohio's main PM2.5 components are primary particles (organiccarbon, 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 atechnical demonstration that emissions of VOCs significantly contribute to nonattainmentofthe annual PM2

.5standard.
This document is intended to support Ohio's requestthat the Ohio portions of the Wheeling area be redesignated from nonattainment to attainment for the annual PM2

.5standard. In addition, the State ofWestVirginia may also submit a requestfortheir respective portions ofthe Wheeling area. Status ofAirQuality 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 metthe 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 attainmentforthe Wheeling area based on the requirements in Section 107(d)(3)(E) ofthe CAAas amended.

2There were no monitors in Ohio thatviolated the 1997 24-hour PM,.5 standard of**65~g/m3.** 3

### CHAPTERTWO Requirementsfor Redesignation U.S. EPA has published detailed guidance in adocument entitled Procedures forProcessing Requests to RedesignateAreas 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) Attainmentofthe standard (CM Section 107(d)(3)(E)(i)) There are two components involved in making this demonstration. Thefirst component relies on ambient airquality data. The data that are used to demonstrate attainment should be the product of ambient monitoring that is representative of the area ofhighest 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 publicforreview.
The second component relies upon supplemental U.S. EPAapproved airquality 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 bythe state.
It was not necessary for Ohio to adopt or implement control measuresforthese counties beyond thefederal measures.
4Ohio EPA has adopted several rules recently that will have an impacton 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, includingthis area. Chapters Fourand Five discussthis requirement in more detail.
iii.) Section 110 and Part D requirements (CAASection 107(d)(3)(E)(v») For purposes of redesignation, a state must meet all requirements of Section 110 and Part D that were applicable priorto submittal ofthe 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, ratherthan Subpart4, is appropriate for the purpose of implementing PM2

.5

.[72 FR 20589]Section 110(a) requirements Section 11

### O(a) ofTitle I ofthe 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 othercontrol measures, means or techniques necessary to meet the requirements of the CAA; provide for establishment and operation of appropriate devices, methods, systems and 5procedures necessary to monitor ambient air quality; provide for implementation ofa 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) ofthe 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 Cto prevent significant deterioration of airquality or to achieve reasonable progress toward the national visibilitygoal for Federal class I areas (national parks and wilderness areas). In orderto 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) Chapter3745-1093

. On July 6, 2011, U.S. EPA finalized a replacement to the CAIR program, the CSAPR. CSAPR could furtherassist States in addressing theirobligations regarding regionally transported pollution by providing reductions in NOxand 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 6identification 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 (CAASection 107(d)(3)(E)(iv» Section 107(d)(3)(E) stipulates that for an area to be redesignated, U.S. EPA mustfully 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 ofthe 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 maybe necessaryto ensure such maintenance.
In addition, the maintenance plan shall contain such contingency measures astheAdministratordeems necessaryto 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 nonattainmentSIP priorto redesignation. States seeking redesignation of a nonattainment area should considerthe following provisions: a.) attainment inventory; b.) maintenance demonstration; c.) monitoring network; d.) verification ofcontinued attainment; and e.) contingencyplan. Chapter Sixdiscusses this requirement in more detail.

7

### CHAPTERTHREE
PM2
.5 MONITORING CM Section 107(d)(3)(E)(i) Requirement 1 of4 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

.5concentrations for the entire nonattainment area are located in Ohio County and Marshall County, West Virginia. The monitors are operated bythe WestVirginia 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 forthis nonattainmentarea are shown on Figure 1.

8Demonstration Figure 1 - Map oftheWheeling WV-OH NonattainmentArea 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**  Requirement2 of4 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 forpUblicview.
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 availabletothe public. Requirement3 of4 A showing that the three-year average ofthe 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 calendaryears ofqualityassured 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.

9In 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 orgreaterare 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. EPAAOS.
Demonstration
Table 

### 1

- Monitoring Data forthe Wheeling WV-OH area for2008

- 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 Lessthan 75% capture in atleastone quarter Source: U.S. EPAAirQualitySystem (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 acleardownward trend in design values:

10Figure 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-<;oWisconsin

trerds lor m::m\lolS with at least 8 Ye61$ oj data Source: LADCO; Recent Ozone and PM2.5Trends

- Aug 262010.pptx

The same trend can be seen within the Midwest States as awhole: Figure 3 •PM2
.5 Annual Mean Trends MidwestStates
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\ gvealS oj data Source: LADCO; RecentOzone and PM2.5 Trends

- Aug 26 2010.pptx
Design values have alsotrended downward nationally: 11Figure4 •

### 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-FM2.5began 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 of4 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 requiresthe submittal ofa 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 inventoryto ayear at least 10 years following redesignation; a demonstration that the projected level of emissions is sufficientto maintain the annual PM2

.5 standard; and a commitment to provide future updates of the inventory to enabletracking ofemission levels duringthe 10-yearmaintenance 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 forall 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 of5 A comprehensive emission inventoryof PM2

.5

, S02and NOxcompleted forthe base year. Background The 2005 periodic inventory has been identified as one of the preferred databases for SIP development and coincides with nonattainmentairquality in theWheeling area. Periodic inventories, which include emissions from all sectors are prepared every three years by Ohio EPA. Ohio's 2005

4vac and NH, are notaddressed. 13emissions 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 underOhio'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 underWest 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 yearforthe 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 NOxfor 

### 2005 are identified under RequirementThree ofthis Chapter.

Requirement2 of5 A projection of the emission inventory to a year at least 

### 10 years following redesignation. Background Ohio EPA prepared a comprehensive inventoryforthe Ohio portion of the Wheeling area including area, mobile, and point sources for PM2

.5

, S02and NOxfor base year

### 2005. The 

### 2005 inventorywas 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 dailyemissions 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 14analyses. These processed modeling inventories have been identified as the correct iteration ofthe 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 byspecific 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, asdiscussed below.

• Point source information was compiled from Ohio EPA's 2005 annual emissions inventorydatabase and the 2005 U.S. EPAAirMarketsacid rain database6•
• Biogenic emissions are notincluded 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 ofthe 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 forthe construction equipment category were reviewed and updated based upon surveys

6 hltp:/lwww.epa.gov/airmarkels!acidrain 15completed in the Midwest, and thetemporal 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 usingWorkforce data.

• Mobile source emissions were calculated using the same methodologyasdescribed aboveforOhio'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 byWVOAQ.

Demonstration On-Road Emission Estimations In coordination with the OOOT, Belomarutilizes 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 locationswhere additional travel capacity may be needed and to determine the infrastructure requirements necessary to meet that need. It is also used as atool for airquality purposes to estimate the total emissions of pollution caused by vehicles in the area. The travel demand forecasting model is used to predict traffic volumesvehicle miles traveled (VMT), travel speeds, and a U.S. EPA computer program called MOVES is used to calculate emissions per mile. The product ofthese is the total amount of pollution emitted bythe on-road vehiclesforthe 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 ofthe Federal Register notice, MOVES became U.S. EPA's approved motor vehicle emission factor model for

7http://www.regulations.gov/search/Regs/home.html#documentDetai I?R=0900006480ab1f98 16estimating VOCs, NOx, CO, PM10and 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 ofon-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 AcademyofSciences. 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 newtransportation conformityanalyses.
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 17tons, 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. EPAto update emissions data incorporated in MOVES more easily and will allow users to incorporate a much widerarrayofactivitydata to improve estimation of local emissions. For example, the improvements in MOVES will allow project-level PM2.5 emissionsto be estimated.
Belomar's report presents the latest population and land use data available that calibrated the modeling process used to calculatethe vehicle emissionsforthe mobileemissions budgets as well as the input values for MOVES. Travel analysis zones and external roadway "stations" are the basicgeographic unitfor 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 bycategoryand location.
Belomar utilized U.S.EPA's emissions model MOVES to develop emissions factors for S02, NOx and PM2

. 5• Further details on the useof MOVES arefound on AppendixC. Atravel demand model (TOM) is the traditional forecasting tool used to examine potential changes in future travel patterns. The Wheeling areatravel demand model networkcovers 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 correspondencefrom the U.S. EPA: Analysis Year2005

- Baseline Emissions Analysis Year2008

- AttainmentYear Analysis Year2015 -Interim Year Analysis Year2022

- MaintenanceYear

18The MOVES model generated the emission factorfiles 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 twofuture year scenarios2015 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 correctdataforthe MOVES model. On-Road Mobile Emission Estimations Tables 2through 7 contain the results ofthe emissions analysis forthe 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 forOn-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

19Table 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 

### f h Sources orthe 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 ofall emissions, for each pollutant in the entire Wheeling area for2015 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%

20S02 constitutes less than one percent «1%)ofthe 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 PM2.5emissions in the 

### 2015 horizon yearand less than two percent (1.33%) of the area's total PM2

.5 emissions in the 

### 2022 horizon year. NOxemissions are underthirteen percent (12.43%) ofthe 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 ofthis finding it is not necessaryto 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. Throughoutthis document Ohio EPAdemonstratesthat it would be unreasonable to expect that the Wheeling area would experience enough motorvehicle 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 of5 Ademonstration that the projected level of emissions is sufficientto maintain the PM2

.5standard.

Background In consultation with U.S. EPA, Ohio EPAselected 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 usingthefollowing 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 notsignificant.

• 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 nonattainmentarea future-yearemissions 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).

• Forthe 2008 attainmentyearemissionswere 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 projectionsfor2015 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 bythe D.C. CircuitCourt (December30, 2011),

8 http://www.ladco.org/tech/emis/currentlindex.php 22the Court has ordered U.S. EPAto 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 NOxand S02. CAIR replaced the NOx SIP Call for EGUs. The intent of the CAIR program is for national NOxemissions to be cutfrom 

### 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. EPAon February 

### 1,2007. Revisionsto the CAIR SIPwere again submitted on July 

### 15, 2009. The revised CAIR SIP Was approved as adirectfinal action on September

### 25, 2009 (74 FR 

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

### 2009 emissions of NOxwill decrease from a baseline of

### 264,000tons peryearto 

### 93,000tons peryearwhile 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 NOxwill decrease to 

### 83,000tons peryear while emissions of S02 will decrease to 

### 208,000 tons peryear, within Ohi09

. On December

### 23, 2008, U.S. EPA's CAIR program was remanded withoutvacatur bythe D.C. CircuitCourt.
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 

### 2009facilities began preparing for and implementing control programs to address CAIR10 and consentdecrees.
Table 9 • Reductions in 502 and NOx EGU Emissions Between 

### 2008 and 

### 2009

Source. Clean Air Markets Quarterly EmissionsTracking 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 UnderCAIR, NOx reductions are to occurbeginning in 2009while 802 reductions are to occur beginning in 2010. 11 http://www.epa.gov/airmarkets/quarterlytracking.html 23Significant reductions also occurred regionally and nationally as can be seen from the above table. Data is also available forthe first two quarters of 

### 2010, the year S02 reductions are to be implemented underCAIR:
Table 10

- Reductions in 

### 802 and NOx EGU Emissions Between the First Halfof2008 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 QuarterlyEmissIons 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 agreementwith the analysis by U.S.EPAthatthe CAIR program is providing real reductions at this time, Ohio believes these reductions have assisted with PM2

. 5 attainmentin this nonattainmentarea and throughoutOhio. On July 6, 

### 2011, U.S. EPAfinalized a replacement to the CAIR program, the CSAPR. CSAPR would preserve those initial reductions achieved under CAIR and provide even greater reductions in NOxand 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 NOxwill decrease to 

### 90,842 tons peryearand in 

### 2014 to 

### 85,744 tons peryearwhile S02 will decrease to 

### 304,022 tons per year in 

### 2012 and 

### 134,333 tons peryear in 

### 2014, within Ohio. In addition, U.S. EPA projections indicated that as a result ofimplementation ofCSAPR, there will be no maintenance issues within this entire nonattainment area. Furthermore, modeling conducted as part of CSAPR projects

12http://www.epa.gov/airmarkets/quarterlytracking.html 13 http://www.epa.gov/airmarkets/background.htm 24the 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 sufficientto maintain the annual PM2.5 standard by assessing future yearemissionsthat includethe 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 "Impactsofthe ProposedTransport Rule on Counties with Monitors Projected to have Ozone and/or Fine Particle AirQuality Problems." 25that it is most appropriate to evaluate future year emiSSions that include the CAIR program, because ofthis flaw itwill be more accurate and appropriate for the purposes of PM2
.5 to evaluate future year emissionswithoutthe CAIR program.

Table 

### 11

- Belmont County, Ohio PM2.5 Emission InventoryTotals for Base Year 

### 2005, Estimated 

### 2008, and Projected 

### 2015 and

### 2022 (toyl

- WithoutCAIR 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

26Table 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) andWith CSAPR (WestVlrainial 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 PM2.5TOTAL 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

27Table 16 •Marshall County, WestVirginia 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

28Table 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, WestVirginia 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, WestVirginia 502Emission Inventory Totals for BaseYear

### 2005, Estimated 

### 2008, and Proiected 

### 2015and 

### 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

29Table 22 •Wheeling Area 

### S02 Emission InventoryTotals 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 of2008 AttainmentYearand 2015 and 2022 Projected Emission Estimates (tpy)
2008 Base 2015 2015 Projected 2022 2022Projected 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 nonattainmentarea are projected to decrease by2,565.31 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 30In 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 afederallyenforceable consentdecree, to operate continuously advanced NOxcontrols (SNCR) and to repower the units to burn mostly biomass (no scrubbers are required). However, the biomassfuel projectwas canceled and the two 

### 156 MW units were permanently shut down in December

### 2010. Thetwo smaller94 MW units will only be used for peakdemand. Requirement 4 of5 A demonstration that improvement in air quality between the year violations occurred and the year attainmentwas achieved is based on permanent and enforceable emission reductions and not on temporary adverse economic conditions orunusuallyfavorable 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 ofthe NMOS by either showing thatfuture emissions of a pollutant or its precursors will not exceed the level of the attainment inventory, or by modeling to show thatthe future mix of sources and emissions rates will notcause aviolation ofthe 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 oftighterfederal standardson newvehicles. AlsoTitle IV of the CM, the NOx SIP Call, CAIR, and federal consent decrees required the reductions of S02 and NOxemissions from utility sources. Reductions achieved are discussed in greater detail under Chapter Five.

31Table24 - Wheeling Area Comparison of 2005 Base Year and 2008 AttainmentYearOn-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 forfuture annual updates ofthe inventoryto enabletracking ofthe emission levels, including an annual emission statementfrom majorsources. 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 of6 Section 172(c)(1) ofthe 1990 Clean AirActAmendments requires states with nonattainmentareasto 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 identifythe attainment date that is as expeditious as practicable, and (3) selectsthe appropriate RACT and RACM.
The Implementation Rule also providesfora presumption that in States that fulfill their CAIR emission reduction requirements, EGU compliancewith CAIR is equivalentto RACM/RACT.
Demonstration In 1972, 1980, and 1991, Ohio promulgated rules requiring reasonably available controls measures for particulate emissionsfrom stationarysources. 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

33violations discovered byfield office staff. The Ohio RACT rules forparticulate matterarefound 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 asignificant 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 greaterreductions.
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 ofwhite papers22 researching different stationarysource categories. The results were compiled intotwo 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 inthe report (See Chapter2). 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 projectteam 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** 34approach) that attainment would be achieved in this area by 2009. Because ofa projected 2009 attainment date, itwould 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 attainmentdate. Requirement2 of6 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 onlyforany area which a State projects an attainment date beyond 2010. The RFP would provide emission reductions showing linearprogress between 2002 and 2009. IfaState demonstrates attainmentwill occur by 2010 or earlier, U.S. EPA considers the attainment demonstrationto demonstrate achievementof 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, itwas notnecessaryto submitaseparate RFP plan. Requirement 3 of6 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 forattainment 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.

35Ohio 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. EPAon 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. Requirement4 of6 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 NOxand S02. CAIR replaced the NOxSIP Call for EGUs. National NOx emissions will be cut from 

### 4.5 million tons in 

### 2004, to acap 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 underthe NOxSIP 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 36Clean Air Markets web site, quantifythe gradual NOxreductions that have occurred in Ohio as a result of Title IV of the 1990 CM Amendments and the beginning ofthe NOxSIP Call Rule. Ohio developed the NOxBudgetTrading 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, atwhich timethe CAIR program superseded it as discussed above. Requirement 3 of 5 under Chapter 4 above discussed the reductions Ohio has seen as a resultofCAIR. On April 21, 2004, U.S. EPA published Phase II ofthe NOxSIP 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 ofthe 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, lowersulfurgasoline. This rule will apply nationwide. The federal rules will phase in between 2004 and 2009. U.S. EPA has estimated that NOxemission reductions will be approximately 77 percentfor passengercars, 86 percentfor smaller SUVs, lighttrucks, 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 largerSUVs, vans, and heaviertrucks.

26 htlp://www.epa.ohio.gov/dapc/regs/3745_14.aspx 37Heavy-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 a40 percent reduction in NOxfrom 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 by97 percent bymid-2006. Clean Air Non-road Diesel Rule In May 2004, U.S. EPA issued the Clean Air Non-road Diesel Rule. This rule appliesto 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. Sulfurlevels 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. Requirement5 of6 Acceptable provisions to providefor newsource review. Background Ohio has a longstanding and fully implemented New Source Review**~NSR)** program. This is addressed in OAC Chapter 3745-31 2

. 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. EPAas partofthe 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 38reconstruct without meeting all applicable NSR requirements. Once the area is redesignated, Ohio EPA will implement NSR through the PSD program. Requirement6 of6 Assure that all existing control measures will remain in effect after redesignation unless the State demonstrates through modeling that the standard can be maintained withoutone 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. EPAfor approval as aSIP revision. Ohio, through Ohio EPA's Legal office, has the legal authority and necessary resources to actively enforce anyviolations 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 theWheeling area.

39

### CHAPTER SIX
CONTINGENCY MEASURES CAA Section 107(d)(3)(E)(v) Requirement 1 of4 A commitmentto submita revised plan eightyears afterredesignation.
Demonstration Ohio herebycommits to reviewits maintenance plan eightyears afterredesignation, as required by Section 175(A) ofthe CAA. Requirement 2 of4 A commitment to expeditiously enact and implement additional contingency control measures in response to exceeding specified predetermined levels (triggers) orin the eventthatfuture violationsofthe ambientstandard occur.
Demonstration Ohio hereby commits to adopt and expeditiously implement necessarycorrective actions in thefollowing circumstances: Warning Level Response: Awarning level response shall be prompted wheneverthe PM2
.5 average ofthe weighted annual mean of 15.5 1J91m3occurs 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 whetherthetrend, ifany, is likelyto continue and, ifso, the control measures necessaryto 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 calendaryear. 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 befollowed.
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 40standard (three-year average ofthe 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 ofthe calendaryearthat 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 atimely manner and will constitute ourresponse. 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 lawfor rulemaking.
Ifa 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 areato attainment. Requirement3 of4 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 orother 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 whatcontrol measureswill be appropriate atan unspecified time 41in 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 programsforfleet vehicle operations. 3) Tighter PM2.5, 802, and NOx emissions offsets for new and modified majorsources. 4) Impact crushers located at recycle scrap yards

- upgrade wet suppression. 5) Concrete manufacturing

- upgradewet suppression. 6) Additional NOxRACTstatewide.

No contingency measure shall be implemented without proVidingthe opportunityforfull pUblic participation during which the relative costs and benefits of individual measures, at the time theyare underconsideration, can befully evaluated. Requirement 4 of

### 4 A list ofPM2

.5, 802, and NOxsources potentiallysUbjectto future additional control requirements.
Demonstration The following is a listofPM2
.5, 802, and NOxsources potentially subjectto future controls.

• ICI Boilers

- 802 and NOxcontrols;

• EGUs;

• process heaters;

• internal combustion engines;

• combustion turbines;

• othersources greaterthan 

### 100tons peryear;

• 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 thewidelydistributed 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 ofpublication, and thetranscriptfrom the public hearing.

43

### CHAPTER EIGHT
CONCLUSIONS
The Wheeling annual PM2.5 nonattainment area has attained the 1997 annual NMOS for PM2

.5and 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 ofSection 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 subjectto significanttransportofpollutants, significant regional S02 and NOxreductions will ensure continued compliance (maintenance) with the standard with an increasing margin ofsafety.
The State of Ohio hereby requests that the Wheeling annual PM2

.5 nonattainment area be redesignated to attainment simultaneously with U.S. EPAapproval ofthe maintenance plan provisions contained herein.

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