Environmental ProtectionAgency .!t')hn FL ;(2;skh, Governor iV;",y Lt. Governor SCU'c'L j, Director



## APR 16

## Z012

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

### 5 77W. Jackson Blvd. Chicago, IL

### 60604

Re: PM2.5 Redesignation Request for the 

### 1997 PM2

.5 Annual Standard for the Steubenville-Weirton Area

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

### 1997 PM2.5 annual 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 (NMQS) 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 forthe Steubenville-Weirton 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 Steubenville, Ohio. The public hearing forthis package was held on April, 3 

### 2012 in

50 West Town street, Suite 700 P.O. Box 1049 Columbus,OH 43216-1049 614 I644 3020 61416443184 (fax) www.epa,ohio.govSteubenville, Ohio. No testimonywas provided atthe hearing and one written comment was received in favorofthe redesignation request.
If you have questions, please contact Jennifer Dines in our Division of Air Pollution Control at (614) 644-3696. Sincerely,

ScottJ. Nally Director
Cc: Bob Hodanbosi, Chief, Division ofAir Pollution Control, Ohio EPA
Enclosure

# REDESIGNATION REQUESTAND MAINTENANCE PLAN FOR THE OHIO PORTION OF THE STEUBENVILLE-WEIRTON OH-WV ANNUAL PM2

.5 

# NONATTAINMENTAREA
Jefferson County, Ohio

Prepared by: Ohio Environmental Protection Agency Division ofAir Pollution Control

April 2012This page left intentionally blank

### TABLE OF CONTENTS ChapterOne Introduction 1 Geographical description and background 

### 2 Status ofairquality 3 ChapterTwo Requirementsfor redesignation .4 ChapterThree PM2
. 5monitoring 8 Annual PM25 NAAQS 8 Ambient data qualityassured 9 Three complete years ofdata 9 Commitmentto continue monitoring 14 Chapter Four Emission inventory 15 Base yearinventory 15 Emission projections 16 Demonstration ofmaintenance 24 Permanent and enforceable emissions reductions 34 Provisionsforfuture update 35 Chapter Five Control measures and regulations 36 Nonattainmentareasto implement RACM and RACT 36 Show Reasonable Further Progress (RFP) 38 Emission inventories 38 Implementation ofpast SIP revisions 39 Newsource review provisions 41 Assurance ofcontinued controls 42 ChapterSix Contingency measures 43 Commitmentto revise plan 43 Commitmentfor contingency measures .43 Potential contingency measures 44 List of PM2

.5

, S02, and NO, sources 45 ChapterSeven Public participation 46 Chapter Eight Conclusions 47Figure 1 Figure 2 Figure 3 Figure 4

Table 1 Table 2
Table 3 Table 4 Table5
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 FIGURES Map ofthe Steubenville-Weirton, OH-WV, nonattainmentarea and monitor locations 9 PM25Annual Mean Trends LADCO States 12 PM2

.5Annual Mean Trends Midwest States 13 PM2

. 5Annual Mean National Trends 13
TABLES Monitoring Datafor Steubenville-Weirton, OH-WV area for2008

- 2010 11 Comparison Between Original and Imputed Values for Monitor39-081-0017 from 2004 to 201 0 12 Jefferson County, Ohio Emission Estimations for On-road Mobile Sources 22 SummaryofOhio Emissions EstimationsforOn-road Mobile Sources 22 Brooke County, WestVirginia Emission EstimationsforOn-road Mobile Sources 22 HancockCounty, WestVirginia Emission Estimations forOn-road Mobile Sources 22 SummaryofWestVirginia Emission EstimationsforOn-Road Mobile Sources.23 Emission Estimations TotalsforOn-road Mobile Sourcesforthe SteubenvilleWeirton Area 23 Percentof Mobile Emissions forthe Steubenville-Weirton Area in 2015 and 2025 23 Reductions in S02 and NOxEGU Emissions Between 2008 and 2009 26 Reductions in S02 and NOxEGU Emissions Between the First Halfof2008 and 2010 27 Jefferson County, Ohio PM2

.5Emission InventoryTotalsfor BaseYear2005, Estimated 2008, and Projected 2015 and 2025 (tpy)

- WithoutCAIR. 29 Brooke County, WestVirginia PM2

.5Emission InventoryTotalsfor Base Year 2005, Estimated 2008, and Projected 2015 and 2025 (tpy)

- With CSAPR. 29 HancockCounty, WestVirginia PM25 Emission InventoryTotalsfor BaseYear 2005, Estimated 2008, and Projected 2015 and 2025 (tpy)

- With CSAPR. 29 Steubenville-Weirton Area PM2
.5Emission InventoryTotalsfor Base Year2005, Estimated 2008, and Projected 2015 and 2025 (tpy)

- Without CAIR (Ohio) and With CSAPR (WestVirginia) 30 Jefferson County, Ohio NOx Emission InventoryTotals for Base Year2005, Estimated 2008, and Projected 2015 and 2025 (tpy)

- With CAIR 30 Brooke County, WestVirginia NOxEmission InventoryTotalsfor Base Year 2005, Estimated 2008, and Projected 2015 and 2025 (tpy)

- With CSAPR. 30 HancockCounty, WestVirginia NOx Emission InventoryTotalsfor BaseYear 2005, Estimated 2008, and Projected 2015 and 2025 (tpy)

- With CSAPR. 31 Steubenville-Weirton Area NOx Emission InventoryTotalsfor Base Year2005, Estimated 2008, and Projected 2015 and 2025 (tpy)

- With CAIR (Ohio) and With CSAPR (WestVirginia) 31 Jefferson County, Ohio S02 Emission InventoryTotals for Base Year2005, Estimated 2008, and Projected 2015 and 2025 (tpy)

- With CAIR 31 Brooke County, WestVirginia S02 Emission InventoryTotalsfor Base Year 2005, Estimated 2008, and Projected 2015 and 2025 (tpy)

- With CSAPR. 32 iiTable 22
Table 23

Table 24
Table 25 HancockCounty, WestVirginia S02 Emission InventoryTotalsfor Base Year 2005, Estimated 2008, and Projected 2015 and 2025 (tpy)

- With CSAPR. 32 Steubenville-Weirton Area S02 Emission InventoryTotalsfor Base Year2005, Estimated 2008, and Projected 2015 and 2025 (tpy)

- With CAIR (Ohio) and With CSAPR (WestVirginia) 32 Steubenville-Weirton Area Comparison of2008 attainmentyearand 2015 and 2025 Projected Emission Estimates (tpy) 33 Steubenville-Weirton Area Combined Comparison of2005 Base Yearand 2008 Attainment YearOn-Road and EGU Reductions 35

APPENDICES
A AirQuality System (AQS) Data B Ohio 2005 SIP BaseYear Inventory Discussion C Mobile Source Emissions Inventoryforthe Steubenville-Weirton PM2

. 5 Nonattainment Area D LADCO Technical Support Document and WVDAQ Nonroad Modeling E Incomplete Monitoring Data Substitution Analysis F Public Participation Documentation

iiiThis page left intentionally blank

ivREDESIGNATION REQUESTAND MAINTENANCE PLAN FORTHE OHIO PORTION OF THE STEUBENVILLE·WEIRTON OH·WV ANNUAL PM2

.5 NONATTAINMENTAREA
Jefferson County, Ohio



### CHAPTER ONE
Introduction The Clean AirAct (CAA), as amended, requires each State with areas failing to meetthe annual PM2

.5

1 National Ambient AirQuality 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 percubic meter**(~g/m3),** based on the 3-year average of annual mean PM2.5 concentrations and a 24-hourstandard of65**~g/m3,** based on the 3-yearaverage ofthe 98th percentile of24-hourconcentrations.
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 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 ofmicroscopicsolids 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, soii or dust particles, and allergens (such as fragments ofpollen ormold spores). Fine particle pollution or PM,., describes particulate matter that is 2.5 micrometers in diameter and smaller

- 1/3Oth the 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 ofthe standards. On December 17, 2004, U.S. EPA promulgated the initial PM2.5 nonattainment areas designationsforthe PM2

.5standards across the country. Modifications to those designations were made and an effective date was set at April 5, 2005. Unlike SUbpart 2 of the CAA Amendments of 1990 which defined five ozone nonattainment classifications forthe areas that exceed the NAAQS based on the severity of the ozone levels, PM2

.5 nonattainment designations are simply labeled "nonattainment." The CAA Amendments require states with PM2

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

.5standards 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 CAA allows states to 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 11O(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. • Afullyapproved maintenance plan underSection 175(A). • Adetermination thatall 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 Steubenville-Weirton nonattainment area is located on the eastern borderof Ohio and includes the following counties: Jefferson in Ohio and Hancock and Brooke in West Virginia. This area is shown in Figure 1 underChapterThree.
The Steubenville-Weirton area has not previously been subject to nonattainmentarea rulemakingsforfine particles.

2As a result of the 2005 PM2.5 designations, U.S. EPA designated the Steubenville-Weirton area nonattainmentforthe 15.0 1J9/m3annual standard2

, 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 thatthe area will meetthefederal annual airqualitystandard byApril 5, 2010. Ohio's main PM2

.5components 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 theywere not part of Ohio's current attainment strategyfor PM2.5 (although controls forVOCs 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

.5attainment plan precursorand 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 nonattainmentofthe annual PM2.5standard.
This document is intended to support Ohio's request thatthe Ohio portions of the Steubenville-Weirton area be redesignated from nonattainment to attainment for the annual PM2

.5 standard. In addition, the State of West Virginia may also submit a request for their respective portions of the Steubenville-Weirton 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 met the NMQS 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 forthe SteubenvilleWeirton area based on the requirements in Section 107(d)(3)(E) ofthe CAA as amended.

2 There were no monitors in Ohio thatviolatedthe 199724-hourPM2.5 standard of**65~g/m3.** 3

### CHAPTERTWO Requirementsfor Redesignation U.S. EPA has published detailed guidance in a documententitled Procedures forProcessing 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 asummaryofeach redesignation criterion as itappliestothe Steubenville-Weirton area. i.) Attainmentofthe standard (CAASection 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 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 availabletothe publicfor review. 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.) Permanentand enforceable improvement in airquality (CAA Section 107(d)(3)(E)(iii» 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. Ohio EPA has adopted several rules recently that will have an impacton statewide PM2.5emissions in thefuture: 4• Clean Air Interstate Rule (CAIR)

• NOxSIP 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 Jefferson County and across the state, includingthis area. Chapters Fourand Five discussthis requirement in moredetail. iiL) Section 110and 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 priorto submittal ofthe complete redesignation request. Subpart 1 of Part Dconsists ofgeneral 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 11O(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 procedures necessary to monitor ambient air quality; provide for implementation of a source permit program to regulate the modification and construction of any 5stationary source within the areas covered by the plan; include provisions for the implementation of Part C, prevention of significant deterioration (PSD) and Part 0, 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 C to prevent significant deterioration of air quality 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 OhioAdministrative Code (OAC) Chapter3745-1093

. On July 6, 2011, U.S. EPA finalized a replacement to the CAIR program, the CSAPR. CSAPR could further assist 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. EPAto 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, identification of certain emissions increases, and other measures needed for attainment will not apply for redesignations because they only have meaning for areas not

3http://www.epa.ohio.gov/dapc/regs/regs.aspX#3745-109 6attaining the standard. The requirements for an emission inventory will be satisfied by the inventory requirements ofthe maintenance plan. Chapters Four and Five discuss this requirement in moredetail. 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, asapplicable. 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 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 asthe Administratordeems 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 considerthefollowing provisions: a.) attainment inventory; b.) maintenancedemonstration; c.) monitoring network; d.) verification ofcontinued attainment; and e.) contingency plan. ChapterSixdiscussesthis requirement in more detail.

7

### CHAPTERTHREE
PM2

.5 MONITORING CM Section 107(d)(3)(E)(i) Requirement 1 of4 A demonstration that the NMOS for annual PM2.5, as published in 40 CFR 50.7, has been attained. Background There are 5 monitors measuring PM2
.5 concentrations in this nonattainment area. Two monitors in Jefferson County, Ohi04

, two in Brooke County, WV and one in Hancock County, WV. A listing ofthe design values based on the three-year average of the annual mean concentrations from 2008 through 2010 is shown in Table 1. The locations ofthe monitoring sites forthis nonattainmentarea are shown on Figure 1.

4 Operated by Ohio EPADivision ofAir Pollution Control, Southeast DistrictOffice. 8Demonstration Figure 1 - Map ofthe Steubenville-Weirton, OH-WV Nonattainment Area and Monitor Locations

o H I (I

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 for publicview.
Demonstration Ohio EPA has quality assured all data shown in Appendix A in accordance with 40 CFR 58.10 and all other federal requirements. Ohio EPA has recorded the data in the AQS database and, therefore, the data are available tothe 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 IJg/m3. (This showing must rely on three complete, consecutive calendaryears ofqualityassured data.)

9Background

. The following information istaken from U.S. EPA's "Guideline on Data Handling Conventionsforthe PM NAAQS," U.S. EPA454/R-99-008, April 

### 1999.
In accordancewith the CAAAmendments, 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 IJg/m3
• While calculating design values, three significant digits must be carried in the computations, with final values rounded to the nearest 

### 0.1 IJg/m3

. Decimals 

### 0.05 orgreaterare rounded up, and those less than 

### 0.05 are rounded down, sothat 

### 15.049 IJg/m3 isthe largest concentration that is lessthan, orequal to 

### 15.0 IJg/m3
•Values at or below 

### 15.0 IJg/m3 meet the standard; values equal to or greater than 

### 15.1 IJg/m3 exceed the standard. An area is in compliance with the annual PM2

.5 NAAQS only if every monitoring site in the area meets the NAAQS. An individual site's 3-year average of the annual average concentrations is also called the site's design value. The air quality design value for the area is the highest design value among all sites in the area. Table 

### 1 shows the monitoring data for 

### 2008

- 2010 that were retrieved from the U.S. EPAAQS.

10Demonstration
Table 1 - Monitoring Data for the Steubenville-Weirton, OH-WV areafor2008 - 2010 Annual Standard Site County Year Al.€rage 2008 2009 2010 2008-2010 39-081-0017 [aj Jefferson, OH 14.3 12.1 12.7 13.0 39-081-1001 14.1 11.2 12.7 12.7 54-009-0005 Brooke, WV 14.7 12.2 14.1 13.7 54-009-0011 13.8 11.9 13.5 13.1 54-029-1 004 Hancock, WV 13.3 11.2 12.6 12.4 Less than 75% capture in at least one quarter [ajThissitehasa73% capture, resulting inonedayofnisseddata. Basedonthedata fromprevious years, this siteshows adecreasingtrend in rronitor readings. Ohio believesthathadthe nissingdatabeencollected itWouid not haveresulted ina design valuethatwould exceedthestandard. Source: U.S. EPAAirQualitySystem (AQS); http://www.epa.gov/ttn/alrs/alrsaqs/index.htm

The design value calculated for the Steubenville-Weirton area demonstrates that the annual PM2
.5 NMOS has been attained. However, one monitor site in Jefferson County (site 39-081-0017), did not comply with the 75% data capture requirement for the 2008-2010 period. Specifically, the fourth quarter (October, November, and December) of 2008 has only 73% capture. This monitoring site experienced instrument malfunction during the low percentage capture missing atotal of8 missing 1-in-3 day PM2.5 FRM runs. Under40 CFR Part 50, Appendix N, the useoflessthan complete data may be approved by U.S. EPA considering such factors as monitoring site closures/moves, monitoring diligence, and nearby concentrations in determining whetherto use such data. Therefore, in orderto further demonstrate that the monitor has attained the standard, Ohio EPA prepared a statistical analysis using multiple imputations. Ohio EPA has imputed missing values for this site and then performed an ordinary analysis as if the imputed values were real measurements. Multiple imputations use random drawsfrom the conditional distribution of the target variable given the other variables. When a regression model is used for imputation, the process involves adding a random residual to the "best guess" for missing values, to yield the same conditional variance as the original variable. Appendix E describes and includes the full statistical analyses performed to show that the three-yearaverage (2008 to 2010) ofthe annual mean value based on missing data imputations, are below 15.0 IJg/m3

.
11Table 

### 2 shows site 

### 39-081-0017 before and after the imputation of missing data. Also the "new" site (with imputed values) shows a passing design valuefor

### 2008 to

### 2010 of lessthan 

### 13.3 Ilg/m3
• Table 2 - Comparison Between Original and Imputed Values for Monitor39-081-0017from 2004to2010 Annual Design Value
Site Year 2004- 2005- 2006- 2007- 2008- 2004 2005 2006 2007 2008 2009 2010 2006 2007 2008 2009 2010 OLD 39-081-0017 15.9 16.4 13.8 16.2 14.3 12.1 12.7 15.4 15.5 14.7 14.2 13.0 NEW 39-081-0017 15.8 16.7 14.1 16.7 14.5 12.4 13.2 15.5 15.8 15.1 14.5 13.3 incompletedata (quarterwith <75%capture) With the data imputation analysis and results, Requirement 3 of4 has been met.

National monitoring for PM2.5 began in 

### 1999. With respect to each of the Lake Michigan Air Directors Consortium (LADCO) states, there has been a cleardownward trend in design values: Figure 2 - PM2

.5Annual Mean Trends LADCO States
PM2.5 Annual Mean Trends, LADCO States, 1999-2ClO:l 20.,-----------------------,

5',--.,....--.,....--.,....--.,....--.,....---,---,---,---,---/ 1999 2000 2001 2002 2003 2004 2005 2005 2007 2008 2009

...... Illinois

....... Ohio ....... Indiana

........ Michigan**~Wisconsin**
trends for rrorilOrs with at liest 8 yoo.rs of data
Source: LADeO; Recent Ozone and PM2.5 Trends-Aug 26 2010.pptx

12The sametrend can be seen within the Midwest States as awhole: Figure 3 • PM2.5Annual Mean Trends Midwest States
PM2,5 Annual Mean Trends, Midwest States, 1999-2009



# N V "'-.,

## 'l--'1 N

o 1999 2000 2001 2002 2003 2004 2005 2006 2Cff1 2008 2009 25

20 

## g 15 

## Ii 

## j 10 

# ]

5

TllOln:lS for rrcnitors with 6l least 8 yeall> 01 dala Source: LADeO; Recent Ozone and PM2,5Trends

- Aug 26 2010,pplx Design values have alsotrended downward nationally: Figure 4 •PM2 ,5Annual Mean National Trends



### PM2.5 AirQuality, 2000

- 2008 (Based on Seasonally-Weighted Annual Average) National Trend based on 728 Sites 30,..--------------------,

«) 25

:::; 20 c' o 

### 1a 15 NaliO"lai t"l'<O"Iuit'(.1 fer PM2.5**b~an** in "£00
10 c o U 5
o-',-,--,-.....,--,-,-,---r---r---,-,---,.-,.--,--,--,---,----,--!

111 111 1 1 1 1 2 222 2 222 2 99999 9 9 9 9 9 0 0 0 0 000 0 0 999 9 9 9 9 9 9 9 0 0 0 0 000 0 0 0123456789012345678

2000 to 2008: 19% decrease in National Averaqe Source: http://www.epa.gov/airtrends/pm.html

13Requirement4 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 commits to continue monitoring PM2
.5 levels at the Ohio sites indicated in Figure 1 and Table 1. Ohio EPA will consult with U.S. EPA Region 5 priorto making changes to the existing monitoring network, should changes become necessary in the future. Ohio EPA will continue to quality assure the monitoring data to meet the requirements of40 CFR 58 and all otherfederal requirements. Connection to a central station and updates to the Ohio EPA web site5 will provide real time availabilityofthe data and knowledge ofanyexceedances. Ohio EPAwill enterall data into AQS on atimely basis in accordance with federal guidelines.

5www.epa.ohio.gov/dapc 14

### CHAPTER FOUR
EMISSION INVENTORY CAA Section 107(d)(3)(E)(iii) U.S. EPA's redesignation guidance requires the submittal ofacomprehensive inventory of PM2.5 precursor emissions (primary particles (organic carbon, crustal matter, and elemental carbon), S02 and NOx 6) 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 permanentand enforceable emission reductions. Other emission inventory related requirements include a projection of the emission inventoryto ayearat least 10 years following redesignation; a demonstration thatthe projected level ofemissions is sufficientto maintain the annual PM2.5 standard; and a commitment to provide future updates of the inventory to enabletracking ofemission levels during the 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 Steubenville-Weirton area. Specific emissions data are provided for all counties, including those in Ohio and West Virginia. West Virginia emissions data were obtained though the WestVirginia Departmentof Environmental Protection (WVDEP). All ofthese inventories and emissions projections were prepared using similar methodologies, unless otherwise noted. Mobile emissions inventories and projections for all counties were prepared by the Brooke-Hancock-Jefferson Metropolitan Planning Commission (BHJ) and the Ohio Department of Transportation (ODOT), with data provided by Ohio EPA, West Virginia DepartmentofTransportation (WVDOT), and WVDEP.

Requirement 1 of5 Acomprehensive 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 the Steubenville-Weirton area. Periodic inventories, which include emissions from all sectors are prepared every three years by Ohio EPA. Ohio's 2005

6vac and NH3 are not addressed. 15emissions datafor all sources (Electrical Generating Unit (EGUPoint); Non-Electrical Generating Unit (Non-EGU); Non-road Mobile (Non-road); OtherArea (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 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 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 forOhio's portion ofthe Steubenville-Weirton area is provided in Appendix B. Emissions of PM2

.5

, S02 and NOxfor 2005 are identified underRequirementThree 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 inventoryfor the Ohio portion of the Steubenville-Weirton 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-readx modeling inventories and future year projections (Pechan Report) based on a2005 base yearinventory. The report by Pechan generated future yearestimates ofannual emissionsforeach source sector using accepted growth surrogates. These inventories were provided to the LADCO and have been processed to develop average daily emissions

7 http://www.ladco.org/tech/emis/r5/reports/LADCO%202005%20Base%20Yr%20Growth%20and%20Co ntrols%20ReportJinal.pdf 16for use in the air quality analyses. These processed modeling inventories have been identified asthe correct iteration ofthe inventory for use in the redesignation. In this document, references to LADCO includethe Midwest Regional Planning Organization. Note, thatthe onroad mobile source sector was addressed by specific PM2

.5and NOx 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 inventory database and the 2005 U.S. EPAAir Markets acid rain databases.

• Biogenicemissions are not included inthese summaries.

• Non-road emissions were derived from NONROAD modeling conducted by WVDAQ, as found in Appendix D.

West Virginia emission projections were provided by the WVDAQ as summarized below.

• Area source and MAR emissions were compiled from the 2008 NEI and 2015 and 2025 projections were grown usingWorkforce data.

• Mobile source emissions were calculated using the same methodologyas described aboveforOhio's portion.

8 http://www.epa.gov/airmarkets/acidrain 17• 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 2025 projections were grown using Workforce data.

• Non-road emissions were derived from NONROAD modeling conducted by WVDAQ, as found in Appendix 

### D.

Demonstration On-Road Emission Estimations The ODOT, Division of Transportation System DevelopmentModeling and Forecasting Section and the Brooke-HancockJefferson Metropolitan Planning Commission (BHJ) defined the underlying planning assumptions for the annual PM2.5 on-road mobile source emission inventoriesforthe Steubenville-Weirton, OH-WV nonattainmentarea. In coordination with the ODOT, BHJ 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 oflocationswhere additional travel capacity may be needed and to determine the infrastructure requirements necessary to meet that need. It is also used as a tool forairquality 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 milestraveled (VMT), travel speeds, and a U.S. EPA computer program called MOVES is used to calculate emissions per mile. The product ofthese isthe total amount of pollution emitted bythe on-road vehicles forthe area. Overview U.S.EPA published a Federal Register notice9 of availability on March 2, 2010, to approve MOVES2010 (Motor Vehicle Emissions Simulator), hereafter referred to as MOVES. Upon publication ofthe Federal Registernotice, MOVES became U.S. EPA's approved motor vehicle emission factor model for estimating VOCs, NOx, CO, PM1Q and PM2

.5and otherpollutants and precursors from cars, trucks, motorcycles, and buses by

9 http://www.regulations.gov/search/Regs/home.html#documentDetaiJ?R=0900006480ab1f98 18state 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 ofon-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 fornewtransportation conformity analyses.
The MOVES more detailed approach (when compared with the previous MOBILE model) to modeling allows U.S. EPAto 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 tons, pounds, kilograms, or grams) or as emission factors (grams-per-mile and in some cases grams-per-vehicle). Output 19can be easily aggregated or disaggregated to examine emissions in a range ofscales, 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 easilyand will allow users to incorporate a much wider array of activity data to improve estimation of local emissions. Forexample, the improvements in MOVES will allow project-level PM2.5 emissionsto be estimated.
BHJ utilized U.S.EPA's emissions model MOVES to develop emissions factors forS02, NOxand PM2.5. Furtherdetails on the use of MOVES are found on Appendix C. BHJ maintains a validated region wide Travel Demand Model (TOM) that employs a four-step modeling process consisting of trip generation, trip distribution, mode choice, and route assignment. The current BHJ TMO validation year is 2000. The model uses comparable average daily traffic count data, updated socialeconomic variables for each of the analysis years by either updating existing or known land use commitment for 2008, 2009, and 2014, orprojected 2014 and 2020variables based on a straight line extrapolation between 2009 set of variables and the Horizon Year 2030 variables. These networks represent all planned federal-aid projects as well as any regionally significant projects found in the BHJ TIP and LRTP expected to be open fortraffic bythe end ofeach respective analysis year. Identifying projected growth centers and understanding urban and rural population changes are essential to determine future transportation needs in a given study area.,Travel forecasting procedures require the userdelineatesthe TOM study area into geographic areas called TrafficAnalysis Zones. Typically, these Zones are based on factors such as land use, area types (urban, suburban or rural), orpolitical government units such as cities, villages, ortownships. The BHJ collects and reviews the TOM independent variables that characterize current and future estimates of the metropolitan area's social and economic activities that may influence land usedevelopment patterns. Thefollowing categories ofplanning data are utilized:

- Population. Households. Household vehicles.

- Employment.

- Laborforce participation.

- Area type. 20The principal data requirements of the BHJ travel demand forecasting model are population and employment, from these variables other characteristics including household, laborforce, and personal vehicles maybe derived.
BHJ utilizes both base year (2005) and future year data (2010, 2020 and 2030) in the planning process. Planning data are maintained at the Traffic Analysis Zone (TAZ) level, and originate in the 2000 Census of Population and Housing. Base year 2005 and future yare data for each variable are developed through various methods. The MOVES model generated the emissions factor files for base year 2005 and attainment year 2008 representing transportation improvement programs implemented in the BHJ Region. The model also generated emission factorsfortwofuture yearscenarios 2015 and 2025.
The single season approach for temperature and relative humidity uses weather data collected by the National Oceanic and Atmospheric Administration (NOAA) National Climatic Data Center (NCDC). The data used in this report, taken from the Pittsburgh International Airport collection center, is representative of 12 months in 2009.
BHJ and ODOT incorporates avarietyofsources oflocal datato both improve and confirm the accuracyofVMT, as well as other travel-related parameters. Free flow speeds used on the highway and transit networks are based on travel time studies performed locally. A BHJ post-processing program uses the loaded highway network to generate VMT by hour, VMT by speed distribution, and VMT by facility type. These tables are then included as input into MOVES. On-Road Mobile Emission Estimations Tables 3through 9 contain the results ofthe emissions analysisforthe appropriate years. All emissions estimations are expressed in tons per year(tpy).

21Table 3 - Jefferson County, OH, Emissions Estimations for OnRoad Mobile Sources 2005 2008 2015 2025 PM2 .• (tpy) 73.17 60.97 31.88 16.49 NO, (tOY) 2105.85 1758.04 870.17 322.71 S02 (tOY) 18.18 5.65 3.93 3.56 AnnualVMT 562,071,084 557,286,295 544,597,475 572,657,778
Table 4 - Summary of Ohio Emissions Estimations for On-Road Mobile Sources 2005 2008 2015 2025 PM2 .•(tpy) 73.17 60.97 31.88 16.49 NO, (tpy) 2105.85 1758.04 870.17 322.71 S02 (tpy) 18.18 5.65 3.93 3.56 Annual VMT 562,071,084 557,286,295 544,597,475 572,657,778

Table 5 - Brooke County, WV, Emissions Estimations for OnRoad Mobile Sources 2005 2008 2015 2025 PM2 .• (tpvl 19.41 14.42 6.97 4.34 NOx (tpy) 540.40 412.02 174.71 62.47 S02 (tpy) 7.01 2.11 1.51 1.26 Annual VMT 212,244,639 212,778,859 219,881,355 216,619,184

Table 6 - Hancock County, WV, Emissions Estimations for OnRoad Mobile Sources 2005 2008 2015 2025 PM2 .• (tOY) 18.63 13.51 6.53 4.10 NO, (tOY) 482.75 360.25 149.00 52.09 S02 (tpy) 6.58 1.92 1.36 1.10 Annual VMT 180,767,718 177,219,697 180,298,107 174,534,361

22Table 7 - Summary of West Virginia Emissions Estimations for On-Road Mobile Sources 2005 2008 2015 2025 PM2•• (tpy) 38.04 27.93 13.5 8.44 NOx(tpy) 1023.15 772.27 323.71 114.56 502 (tpy) 13.59 4.03 2.87 2.36 Annual VMT 393,012,357 389,998,556 400,179,462 390,998,315
Table 8 - Emissions Estimations Totalsfor On-Road Mobile Sourcesforthe Steubenville-Weirton Area 2005 2008 2015 2025 PM2.• (tpy) 111.21 88.9 45.38 24.93 NOx(tpy) 3129 2530.31 1193.88 437.27 502 (tpy) 31.77 9.68 6.80 5.92
AnnualVMT 955,083,441 947,284,851 944,776,937 963,656,093

The following table identifies the percentage of mobile emissions of all emissions, for each pollutant in the entire Steubenville-Weirton area and Ohio's portion ofthis area for

### 2015 and 

### 2025.
Table 9 - Percent of Mobile Emissions for the SteubenvilleWeirton Area in 2015 and 2025 NO, S0, PM2,5 2015 2025 2015 2025 2015 2025
Steubenville- Total (tpy) 25,563.36 17,533.17 74,806.60 47,445.13 2,740.52 2,698.00

Weirton Mobile(tpy) 1,193.88 437.27 6.80 5.92 45.38 24.93

Area %Mobile 4.67% 2.49% 0.009% 0.012% 1.66% 0.92% Total (tpy) 22,883.61 15,237.65 73,080.25 45,861.72 2,005.04 1,997.72
Ohio Portion Mobile(tpy) 870.17 322.71 3.93 3.56 31.88 16.49 %Mobile 3.80% 2.12% 0.005% 0.008% 1.59% 0.83%
NOx constitutes less than five percent (4.67%) of the area's total NOxemissions in the 

### 2015 horizon year and less than three percent (2.49%) of the area's total NOx emissions in the 

### 2025 horizon year. S02 constitutes lessthan one percent «1 %) ofthe area's total S02 emissions in the 

### 2015 and 

### 2025 horizon years. PM2.5 constitutes less than two percent (1.66%) of the area's total PM2.5emissions in the 

### 2015 horizon year and 23less than one percent (0.92%) of the area's total PM2.5 emissions in the2025 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 ofthe Steubenville-Weirton 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 2025 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 Steubenville-Weirton area would experience enough motor vehicle emissions growth in PM2.5, NOx, and S02fora PM2

.5NMOS 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 motorvehicle 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 insignificantcontributorstofine particles.
Requirement 3of5 A demonstration thatthe projected level of emissions is sufficient to maintain the PM2

.5standard. Background In consultation with U.S. EPA, Ohio EPAselected the year2025 as the maintenance year for this redesignation request. This document contains projected emissions inventories for 2015 and 2025. Emission projections for the Steubenville-Weirton area were performed using thefollowing approaches:

• As performed by OOOT and BHJ, 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.

24• 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 and area categories. These files were used to develop Ohio's portion of this nonattainmentareafuture-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 D contains LADCO's technical support document detailing the analysis used to project emissions (Base M10).

• Forthe 

### 2008 attainmentyearemissions were grown from the 

### 2005 LADCO modeling inventory, using LADCO's growth factors, for all sectors except point sources (electrical generating units and non-electrical 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 

### 2025 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 

### 2025 were grown from 

### 2005 and 

### 2009 emissionsestimates. Ohio EPA is identifying emissions projectionsfor

### 2015 and 

### 2025 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. Circuit Court (December

### 30, 2011), the 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 

### '0 http://www.ladco.org/tech/emis/currentlindex.php 25NOx 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. EPAon February 1, 2007. Revisionsto the CAIR SIP were again submitted on July 15, 2009. The revised CAIR SIP was approved as adirectfinal action on September25,2009 (74 FR 48857). As a result of CAIR, U.S. EPA projects that in 2009 emissions of NOxwill decrease from a baseline of264,000 tons peryearto 93,000 tons peryearwhile in 2010 emissions ofS02 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 83,000 tons peryear while emissions of S02 will decrease to 208,000 tons peryear, within Ohi011

. 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 10 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 CAIR12 and consentdecrees.

Table 10 • Reductions in 

### S02 and NOx EGU Emissions Between 2008 and 2009

Source. Clean Air Markets Quarterly EmissionsTracking S02 NOx 2008 2009 Chanae 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% 

# .... Significant 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:

11 http://www.epa.gov/CAIRloh.html 12 UnderCAIR, NOx reductions areto occurbeginning in 2009 while 802 reductions areto occur beginning in 2010. 13 http://www.epa.gov/airmarkets/quarterlytracking.html 26Table 11

- Reductions in 

### 502 and NOx EGU Emissions Between the First Halfof2008 and 2010 SO, NOx 2008 2010 Change 2008 2010 Change 11s' halfl (1 S
' halfl W' halfl (1 S
' halfl 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 AirMarkets Quarterly EmissionsTracking 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.1s" Ohio EPA is in agreementwith the analysis by U.S.EPAthatthe CAIR program is providing real reductions at this time, Ohio believesthese reductions have assisted with PM2,sattainment in this nonattainmentarea and throughout Ohio. 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 

### 2014to 

### 85,744tons peryearwhile S02will 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 of implementation ofCSAPR, therewill be no maintenance issueswithin this entire nonattainmentarea. 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

14ht1p:llwww.epa.gov/airmarkets/quarterly1racking.html 15 ht1p:llwww.epa.gov/airmarkets/background.htm 27emissions is sufficient to maintain the annual PM2.5 standard by assessing future yearemissionsthat includethe CAIR program. The detailed inventory information for the Ohio portion of the Steubenville-Weirton 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 (2025) projected emission totals are below the 2008 attainment year totals.

Demonstration

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 PM2.5 emissions growth. Modeling performed by LADCO, without CAIR, did not incorporate added condensable fraction emissions. Although Ohio EPA has stated that it is most appropriate to evaluate future year emissions that include the CAIR program, because ofthis flaw itwill be more accurate and appropriate for the purposes of PM2.5 to evaluate future year emissions withoutthe CAIR program.

28Table 

### 12· Jefferson County, Ohio PM2.5 Emission Inventory Totals for Base Year 

### 2005, Estimated 

### 2008, and Projected 

### 2015 and 

### 2025 (tpy)- Without CAIR
Sector 2005 Base 2008 2015 2025 Safety Attainment Interim Maintenance Margin EGU Point 1,307.90 1,372.80 1,405.39 1,449.64 -76.84 Non-EGU 461.57 461.42 437.63 413.69 47.73 Non-road 24.30 22.50 17.15 11.25 11.25 Area 110.12 110.60 108.49 105.97 4.63 MAR 8.07 7.25 4.50 0.68 6.57 On-road 73.17 60.97 31.88 16.49 44.48 TOTAL 1,985.13 2,035.54 2,005.04 1,997.72 37.82

Table 13· Brooke County, West Virginia PM2.5 Emission Inventory Totals for Base Year 

### 2005, Estimated 

### 2008, and Projected 

### 2015 and 

### 2025 (hy)- With CSAPR
Sector 2005 Base 2008 2015 2025 Safety Attainment Interim Maintenance Margin EGU Point 0.00 0.00 0.00 0.00 0.00 Non-EGU 155.12 166.68 155.84 141.59 25.09 Non-road 11.04 9.46 6.47 3.76 5.70 Area 208.48 219.93 217.55 216.00 3.93 MAR 17.07 3.85 3.87 3.91 -0.06 On-road 19.41 14.42 6.97 4.34 10.08 TOTAL 411.12 414.34 390.70 369.60 44.74

Table 14· HancockCounty, West Virginia PM2.5 Emission InventoryTotalsfor BaseYear

### 2005, Estimated 

### 2008, and Projected 

### 2015 and 

### 2025 (tPy)- With CSAPR
Sector 2005 Base 2008 2015 2025 Safety Attainment Interim Maintenance Margin EGU Point 0.00 0.00 0.00 0.00 0.00 Non-EGU 182.02 90.97 83.84 74.81 16.16 Non-road 9.61 8.20 5.57 3.10 5.10 Area 313.70 232.96 230.26 229.92 3.04 MAR 26.18 18.46 18.58 18.75 -0.29 On-road 18.63 13.51 6.53 4.10 9.41 TOTAL 550.14 364.10 344.78 330.68 33.42

29Table 

### 15

- Steubenville-Weirton Area PM2.5 Emission Inventory Totals for Base Year 

### 2005, Estimated 

### 2008, and projected 

### 2015 and 

### 2025 (tpy)

- Without CAIR (Ohio) and With CSAPR (WestVirginia) PM2.5 2005 Base 2008 2015 2025 Safety Attainment Interim Maintenance Margin Jefferson 1,985.13 2,035.54 2,005.04 1,997.72 37.82 Hancock,WV 550.14 364.10 344.78 330.68 33.42 Brooke,WV 411.12 414.34 390.70 369.60 44.74 COMBINED 2,946.39 2,813.98 2,740.52 2,698.00 115.98 PM2
.5TOTAl

Table 16

- Jefferson County, Ohio NOx Emission InventoryTotals for Base Year 

### 2005, Estimated 

### 2008, and Projected 

### 2015 and 

### 2025 (tpy)

- With CAIR Sector 2005 2008 2015 Interim 2025 Safety Base Attainment Maintenance Margin EGU Point 41,046.61 35,486.86 19,488.27 12,631.73 22,855.13 Non-EGU 1,991.85 1,991.96 1,938.71 1,863.75 128.21 Non-road 234.30 207.68 131.49 96.59 111.09 Area 251.38 253.45 252.46 251.93 1.52 MAR 317.3 300.96 202.51 70.94 230.02 On-road 2,105.85 1,758.04 870.17 322.71 1,435.33 TOTAL 45,947.29 39,998.95 22,883.61 15,237.65 24,761.30
Table 17

- Brooke County, West Virginia NOx Emission Inventory Totals for Base Year 

### 2005, Estimated 

### 2008, and Projected 

### 2015 and

### 2025 (tpy)

- With CSAPR Sector 2005 Base 2008 2015 2025 Safety Attainment Interim Maintenance Margin EGU Point 0.00 0.00 0.00 0.00 0.00 Non-EGU 692.76 789.79 742.21 679.29 110.50 Non-road 204.75 169.37 88.18 59.17 110.20 Area 311.36 119.10 117.87 116.12 2.98 MAR 444.99 112.83 113.54 114.56 -1.73 On-road 540.40 412.02 174.71 62.47 349.55 TOTAL 2,194.26 1,603.11 1,236.51 1,031.61 571.50

30Table 

### 18
- Hancock County, WestVirginia NOx Emission Inventory Totals for Base Year 

### 2005, Estimated 

### 2008, and Projected 

### 2015 and 

### 2025 (tpy)- With CSAPR
Sector 2005 Base 2008 2015 2025 Safety Attainment Interim Maintenance Margin EGU Point 0.00 0.00 0.00 0.00 0.00 Non-EGU 1,181.15 574.68 524.80 462.67 112.01 Non-road 135.47 119.41 74.58 51.49 67.92 Area 1,446.78 158.02 156.60 154.58 3.44 MAR 695.36 534.89 538.26 543.08 -8.19 On-road 482.75 360.25 149.00 52.09 308.16 TOTAL 3,941.51 1,747.25 1,443.24 1,263.91 483.34

Table 19 - Steubenville-Weirton Area NOx Emission Inventory Totals for Base Year 

### 2005, Estimated 

### 2008, and Projected 

### 2015 and 

### 2025 (tpy) - With CAIR (Ohio) and With CSAPR (WestVir inial
NOx 2005 2008 2015 2025 Safety Base Attainment Interim Maintenance Margin Jefferson 45,947.29 39,998.95 22,883.61 15,237.65 24,761.30 Hancock, WV 3,941.51 1,747.25 1,443.24 1,263.91 483.34 Brooke, WV 2,194.26 1,603.11 1,236.51 1,031.61 571.50 COMBINED 52,083.06 43,349.31 25,563.36 17,533.17 25,816.14 NOxTOTAL

Table 

### 20
- Jefferson County, Ohio S02 Emission Inventory Totals for Base Year 

### 2005, Estimated 

### 2008, and Projected 

### 2015 and 

### 2025 (tpy) - With CAIR
Sector 2005 Base 2008 2015 2025 Safety Attainment Interim Maintenance Margin EGU Point 225,594.94 135,506.74 72,203.22 45,073.14 90,433.60 Non-EGU 849.92 782.87 757.91 692.85 90.02
Non-road 17.31 3.09 0.40 0.45 2.64
Area 110.89 109.15 101.75 91.69 17.46 MAR 26.16 21.61 13.04 0.48 21.13 On-road 18.18 5.65 3.93 3.56 2.09 TOTAL 226,617.40 136,429.11 73,080.25 45,862.17 90,566.94

31Table 

### 21

- Brooke County, West Virginia S02 Emission Inventory Totals for Base Year 

### 2005, Estimated 

### 2008, and Projected 

### 2015 and 

### 2025 (tpy)

- With CSAPR Sector 2005 Base 2008 2015 2025 Safety Attainment Interim Maintenance Margin EGU Point 0.00 0.00 0.00 0.00 0.00 Non-EGU 620.55 766.54 718.43 654.91 111.63 Non-road 12.13 2.17 0.27 0.30 1.87 Area 167.98 163.76 156.62 146.42 17.34 MAR 20.32 6.34 6.38 6.44 -0.10 On-road 7.01 2.11 1.51 1.26 0.85 TOTAL 827.99 940.92 883.21 809.33 131.59

Table 

### 22

- Hancock County, West Virginia S02 Emission Inventory Totals for Base Year 

### 2005, Estimated 

### 2008, and Projected

### 2015 and

### 2025 (tpy)

- With CSAPR Sector 2005 Base 2008 2015 2025 Safety Attainment Interim Maintenance Margin EGU Point 0.00 0.00 0.00 0.00 0.00 Non-EGU 1,480.85 613.04 572.55 519.57 93.47 Non-road 9.72 1.73 0.21 0.23 1.50 Area 728.92 248.63 237.35 221.22 27.41 MAR 32.27 31.47 31.67 31.96 -0.49 On-road 6.58 1.92 1.36 1.10 0.82 TOTAL 2,258.34 896.79 843.14 774.08 122.71

Table

### 23

- Steubenville-Weirton Area S02 Emission Inventory Totals for Base Year 

### 2005, Estimated 

### 2008, and Projected 

### 2015 and 

### 2025 (tpy)

- With CAIR (Ohio) and With CSAPR (WestVirginia)
S02 2005 Base 2008 2015 2025 Safety Attainment Interim Maintenance Margin Jefferson 226,617.40 136,429.11 73,080.25 45,862.17 90,566.94 Hancock,WV 2,258.34 896.79 843.14 774.08 122.71 Brooke,WV 827.99 940.92 883.21 809.33 131.59 COMBINED 229,703.73 138,266.82 74,806.60 47,445.58 90,821.24 S02TOTAL

32PMgs, NO

.. and SOg
Table 24

- Steubenville-Weirton Area Comparison of 2008 Attainment Year and 2015 and 2025 Projected Emission Estimates (tpy) 2015 2015 2025 2025 2008 Base Interim Projected Maintenance Projected Decrease Decrease PM2•• 2,813.98 2,740.52 73.46 2,698.00 115.98 NOx 43,349.31 25,563.36 17,785.95 17,533.17 25,816.14 502 138,266.82 74,806.60 63,460.22 47,445.58 90,821.24 As shown in the table above (Table 

### 24), PM2.5 emissions in the nonattainment area are projected to decrease by 

### 73.46 tpy in 

### 2015 and 

### 115.98 tpy in 

### 2025. NOx emissions in the nonattainment area are projected to decrease by 

### 17,785.95 tpy in 

### 2015 and 

### 25,816.14 tpy in 

### 2025. S02 emissions in the nonattainment area are projected to decline by

### 63,460.22 tpy in 

### 2015 and 

### 90,821.24tpy in 

### 2025.
In general, EGU source emissions, and to a lesser extent, area source emissions and Non-EGU source emissions show a decrease. Cleaner vehicles and fuels are expected to be in place in 

### 2009 and 

### 2018, and the CSAPRwill be implemented in 

### 2012 and 

### 2014 and these programs should cause an overall drop in all three pollutants emissions. Decreasesfrom U.S. EPA rules covering EGUs, Tier

### 2 MotorVehicle Emissions Standards and Gasoline Sulfur Control Requirements16, Highway HeavyDuty Engine RUle17

, and the Non-Road Diesel Engine Rule18are factored intothe changes.
In addition to the above, the Cardinal Station (AEP) in Jefferson County implemented changes in late 

### 2007 and early 

### 2008. Two units, 

### #1 and 

### #2 (each 

### 600 megawatt) installed and began continuously operating scrubbers, and a restricted S02 allowable emission rate was incorporated into a federally enforceable permit demonstrating they will not cause or contribute to a violation of a NMOS and/or Prevention of Significant Deterioration increment violation based upon air dispersion modeling. These scrubbers began operating in December

### 2007 and March 

### 2008.19 Also these two units were required by a federally enforceable consent decree to operate

16 http://www.epa.gov/fedrgstr/EPA-AIR/2000/February/Day-10/a19a.htm 17 http://www.epa.gov/fedrgstr/EPA-AIR/1997/0ctober/Day-21/a27494.htm 18 http://www.epa.gov/fedrgstr/EPA-AIR/1998/0ctober/Day-23/a24836.htm 19The lower rates will be incorporated Into thefacility's TitleV operating permit at renewal. 33their SNCR continuously to control and reduce NOx emissions by January 2009. Moreover, unit #3 (630 megawatt) is undergoing construction for the installation of a scrubber, to control S02 emissions in the future. The permit-to-install these scrubbers will require a restricted S02 allowable emission rate. The scrubbers will begin operating by January 2012 in accordance with their federally enforceable consent decree. Similar to unit #1 and #2, unit #3 was required by a federally enforceable consent decree to operate SNCR continuously to control and reduce NOxemissions byJanuary2009. Requirement4 of5 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 orunusuallyfavorable meteorology. Background Ambient air quality data from all monitoring sites indicate that air quality met the NAAOS for PM2

.5 in 2008-2010. U.S. EPA's redesignation guidance (p 9) states: "A state may generally demonstrate maintenance ofthe NAAOS by eithershowing that future emissions of a pollutant or its precursors will not exceed the level of the attainment inventory, or by modeling to showthat thefuture mix of sources and emissions rateswill notcause aviolation ofthe NAAOS."
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 non-road diesel vehicles (Clean Air Non-road Diesel Rule) and the application oftighterfederal standards on newvehicles. Also Title IVofthe CAA, the NOxSIP Call, CAIR, and federal consentdecrees required the reductions ofS02 and NOx emissions from utility sources. Reductions achieved are discussed in greaterdetail underChapter Five.

34Table 25 - Steubenville-Weirton Area Comparison of 2005 Base Year and 2008 Attainment Year On-Road, Non-Road and EGU Reductions 2005 2008 On-road PM2

.5 111.21 88.90 On-road NOx 3,129.00 2,530.31 On-road S02 31.77 9.68 Non-road PM2

.5 44.95 40.16 Non-road NOx 574.51 496.47 Non-road S02 39.16 6.99 EGU PM25 1,307.90 1,372.80 EGU NOx 41,046.61 35,486.86 EGU S02 225,594.94 135,506.74
Requirement 5of5 Provisionsforfuture 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 tothe 

### 2005 base yearand the 

### 2025 projected maintenance year inventories to assess emission trends, as necessary, and to assure continued compliancewith the annual PM2.5 standard.

35

### 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 RACTand 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

36violations discovered byfield office staff. The Ohio RACT rules forparticulate matterarefound in OAC Chapter

### 3745-172 

# °.

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

### 3745-1421), CAIR (OAC Chapter 

### 3745-10922), and NOx Reasonably Available Control Technology rules (OAC Chapter 

### 3745-11023) over the past five years. Emissions from EGUs make up asignificantcontribution 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 ofwhite papers24 researching different**stationa~** source categories. The results were compiled intotwo reports2

.The second consultant, Environ, investigated control options for mobile sources. The results were compiled into two reports25

. 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 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 developed27

. 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

20 http://www.epa.ohio.gov/dapc/regs/3745_17.aspx 21 http://www.epa.ohio.gov/dapc/regs/3745_14.aspx 22 http://www.epa.ohio.gov/dapc/regs/3745_109.aspx 23 http://www.epa.ohio.gov/dapc/regs/3745_110.aspx 24 http://www.ladco.org/reports/control/white_papers 25 http://www.ladco.org/reports/control/finaLreports/identification_and_evaluation_oCcandidateJontroLm easuresJ_apriL2005.pdf; http://www.ladco.org/reports/control/finaUeports/identification_and_evaluation_oCcandidate_control_m easuresJijune_2006.pdf 26 http://www.ladco.org/reports/control/flnaUeports/finaUeport

_evaluation_ oCcandidate_mobile_source_ controLmeasures_february_2006.pdf; http://www.ladco.org/reports/control/finaLreportslfinaUeport_evaluation_oCcandidate_mobile_source_ controLmeasures_foUadco_states_in_2009_and_2012_march_2007.pdf 27 http://www.ladco.org/reports/control/modeling/round4_modeling.pdf 37approach) 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 CAA Amendments requires attainment demonstration SIPs for nonattainment areas to show reasonable further progress (RFP). Background U.S. EPA's Implementation Rule requires RFP onlyforanyarea which a State projects an attainment date beyond 2010. The RFP would provide emission reductions showing linearprogress between 2002 and 2009. Ifa State demonstrates attainmentwill occur by 2010 or earlier, U.S. EPA considers the attainment demonstration todemonstrate achievementofRFP.
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 not necessaryto submitaseparate RFP plan. Requirement 3of6 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.

38Ohio also updates its inventory in accordance with U.S. EPA's CERR rule (I.e. 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 byfield office staff. Compliance istracked 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 by2009, and 1.3 million tons in 2018 in 28 states. Stateswere 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 September25,2009 (74 FR48857).
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 39Clean Air Marketsweb site, quantifythe gradual NOxreductions that have occurred in Ohio as a result of Title IV of the 1990 CAA Amendments and the beginning ofthe NOxSIP Call Rule. Ohio developed the NOxBudget Trading Program rules in OAC Chapter 3745-1428 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 time the CAIR program superseded it as discussed above. Requirement 3 of 5 under Chapter4 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 (greaterthan 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 II Emission Standards for Vehicles and Gasoline Sulfur Standards In February 2000, U.S. EPA finalized a federal rule to significantly reduce emissions from cars and 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 NOx emission reductions will be approximately 77 percentfor passengercars, 86 percentfor smallerSUVs, 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.

28 http://www.epa.ohio.gov/dapc/regs/3745_14.aspx 40HeaVY-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 rulewill 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 dieselfuel will be reduced by97 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 levelswill 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 provisionsto providefornewsource 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. 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

29 http://www.epa.ohio.gov/dapc/regs/3745_31.aspx 41reconstruct without meeting all applicable NSR requirements. Once the area is redesignated, Ohio EPA will implement NSR through the PSD program. Requirement 6 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 ormore 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 PM2.5, S02, and NOx as required for maintenance of the annual PM2.5 standard in the Steubenville-Weirton area, will be submitted to U.S. EPAforapproval as a SIP revision. Ohio, through Ohio EPA's Legal office, has the legal authority and necessary resources to activelyenforce anyviolations of its rules or permit provisions. After redesignation, it intends to continue enforcing all rules that relate to the emission of PM2.5 precursors in the Steubenville-Weirton area.

42

### CHAPTER SIX
CONTINGENCY MEASURES CM Section 107(d)(3)(E)(v) Requirement 1 of4 Acommitmentto submita revised plan eightyears afterredesignation.
Demonstration Ohio herebycommitsto review its maintenance plan eightyears after redesignation, as required bySection 175(A) ofthe CM. Requirement2 of4 A commitment to expeditiously enact and implement additional contingency control measures in response to exceeding specified predetermined levels (triggers) or in the eventthatfutureviolationsofthe ambientstandard occur. Demonstration Ohio hereby commits to adopt and expeditiously implement necessarycorrective actions inthefollowing circumstances: Warning Level Response: Awarning level response shall be prompted wheneverthe PM2
.5 average ofthe weighted annual mean of 15.5 f.l9/m3 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 evaluatewhetherthe trend, 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 recentcalendaryear. 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 f.l9/m3 or greater occurs within the maintenance area. A violation of the 43standard (three-year average of the weighted annual means of 15.0 fJg/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 ofthe maintenance provisions will be implemented in atimely 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 othermeasures required byOhio 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 EPAwill 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 measureswill be appropriate atan unspecified time 44in 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 programsforfleetvehicle operations. 3) Tighter PM2,5, 802, and NOx emissions offsets for new and modified majorsources. 4) Impact crushers located at recycle scrap yards

- upgradewet suppression. 5) Concrete manufacturing

- upgradewet suppression. 6) Additional NOx RACT statewide.

No contingency measure shall be 'implemented without providing the opportunityforfull public participation during which the relative costs and benefits of individual measures, at the time theyare underconsideration, can befully evaluated. Requirement4 of4 A listof PM2,5, 802, and NOxsources potentiallysubjecttofuture additional control requirements.
Demonstration Thefollowing is a listof PM2.5, 802, and NOxsources potentially subjecttofuture controls.

• ICI Boilers

- 802 and NOxcontrols;

• EGUs;

• process heaters;

• internal combustion engines;

• combustion turbines;

• othersources greaterthan 

### 100tons peryear;

• fleetvehicles;

• concrete manufacturers;

• aggregate processing plants;

45

### 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 on April 3, 2012, at the Steubenville Library

- Schiappa Branch, Steubenville, Ohio. The public comment period closed on April 3, 2012. Appendix F includes a copy of the comment received, public notice, certification ofpublication, and thetranscriptfrom the public hearing.

46

### CHAPTER EIGHT
CONCLUSIONS
The Steubenville-Weirton annual PM2

.5nonattainment area has attained the 1997 annual NAAQS for PM2

.5and complied with the applicable provisions of the 1990 Amendments to the CAA 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 CAA.
Based on this presentation, the Steubenville-Weirton annual PM2.5 nonattainment area meets the requirements for redesignation underthe CAA and U.S. EPA guidance. Ohio has performed an analysis that shows the air quality improvements are due to permanent and enforceable measures. Furthermore, becausethis area is subjectto significanttransportofpollutants, significant regional S02 and NOxreductions will ensure continued compliance (maintenance) with the standard with an increasing margin ofsafety.
The State ofOhio hereby requeststhatthe Steubenville-Weirton annual PM2.5 nonattainment area be redesignated to attainment simultaneously with U.S. EPAapproval ofthe maintenance plan provisions contained herein.

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