west virginia department of environmental protection

Appendix Q

Public Participation

Documentation

Promoting a healthy environment.

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 1
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Table of Contents

Public Notice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Appendix Q Page - 5

Transmittal Letters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Appendix Q Page - 9

Legal Ads . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Appendix Q Page - 15

Public Hearing Transcript . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Appendix Q Page - 25

Public Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Appendix Q Page - 35

EPA Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Appendix Q Page - 37

Response to Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Appendix Q Page - 51

Attachment 1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Appendix Q Page - 69

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Public Notice

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NOTICE OF PUBLIC HEARING AND PUBLIC COMMENT PERIOD

The West Virginia Department of Environmental Protection (DEP) is offering an opportunity for

public comment, and will hold a public hearing, on a proposed revision to the State

Implementation Plan (SIP) to attain and maintain the national ambient air quality standards

(NAAQS) for fine particulate matter (PM2.5). In this proposed revision to the SIP, DEP

demonstrates that the West Virginia portion of the Weirton-Steubenville (WV-OH) PM2.5

nonattainment area, comprising Brooke and Hancock Counties, will meet the annual PM2.5

standard by the mandatory date of April 2010. Further, DEP shows that the expected air quality

improvement will be achieved through federally enforceable emission reduction measures. The

area was designated as nonattainment with the 1997 PM2.5 annual NAAQS in the January 5, 2005

Federal Register [70 FR 944], effective April 5, 2005.

Once finalized, the Attainment Demonstration for the Annual National Ambient Air Quality

Standard for Fine Particulate Matter (PM2.5) State Implementation Plan for the Weirton, West

Virginia Nonattainment Area, Comprising Brooke and Hancock Counties will be submitted to 

U.S. EPA for approval and incorporation as a revision to the State Implementation Plan (SIP).

Written and oral comments will be accepted until the close of the public hearing and will be

made part of the formal record. Please identify the document to which the comments apply, the

commenter’s name, address, and telephone number. 

Written comments will also be accepted for inclusion in the formal record by mail, facsimile

(304-926-0479), e-mail (Tammy.L.Mowrer@wv.gov) or other delivery to the Division of Air

Quality if received by the close of business on April 21, 2009. Transmit written comments to

John A. Benedict, Director of the Division of Air Quality at the following address:

WV Department of Environmental Protection

Division of Air Quality

601 57th Street, SE

Charleston, WV 25304

The public hearing shall be held beginning at 6:00 p.m. on April 21, 2009 at the following

location:

WV Department of Environmental Protection

Conference Room (room 122)

131-A Peninsula Street

Wheeling, West Virginia 26003

Copies of the proposed SIP revision may be viewed on weekdays between 8:30 a.m. and 4:30

p.m. at the DEP Wheeling office located at the above address. Copies will also be available for

public review at the Division of Air Quality, 601 57th SE, Charleston, WV 25304. The proposed

SIP revision may also be accessed via the following web address:

http://www.wvdep.org/item.cfm?ssid=8&ss1id=376

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 7
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Transmittal Letters

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west virginia department of environmental protection 

Division of Air Quality 

601 57fi Street SE 

Charleston, WV 25304 

Phone: 304.926.0475 + Fax: 304.926.0479 

Joe Manchin 111, Governor 

Randy C. Huffman, Cabinet Secretary 

www.wvdep.org 

March 19,2009 

Judith M. Katz, Director 

Air Protection Division 

U.S. EPA Region I11 

1650 Arch Street (3AP00) 

Philadelphia, PA 191 03-2029 

Re: Proposed Revision to the West Virginia SIP to Demonstrate Attainment of the Annual 

PM,,, NAAQS for the West Virginia Portion of the Weirton-Steubenville (WV-OH) 

Nonattainment Area 

Dear Ms. Katz: 

The West Virginia Department of Environmental Protection, Division of Air Quality is 

herein submitting for your review and comment the enclosed Attainment Demonstration for the 

Annual National Ambient Air Quality Standard for Fine Particulate Matter (PM,.J State 

Implementation Plan for the Weirton, West Virginia Nonattainment Area, Comprising Brooke 

and Hancock Counties (proposed). We are providing a hard copy of the primary narrative but the 

supporting documentatioii is being supplied on a digital compact disk because of the extremely 

large volume of a comparable print out. 

As you know, the Weirton-Steubenville (WV-OH) PM,,, nonattainment area is a multi-state 

nonattainrnent area, comprising Brooke and Hancock Counties in West Virginia, and Belmont 

County in Ohio. The area was designated as nonattainment with the 1997 PM,,, National 

Ambient Air Quality Standard (NAAQS) in the January 5,2005 Federal Register [70 FR 9441, 

effective April 5,2005. Upon finalization, the State of West Virginia plans to request that the 

EPA approve the Weirton attainment demonstration, with a projected attainment date of April 

2010, as a revision to the state implementation plan (SIP). 

Promoting a healthy environment. 

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 11
Letter to Judith M. Katz 

March 19,2009 

Page 2 

Written and oral comments will be accepted until the close of the public hearing and will be 

made part of the formal record. The public hearing shall be held beginning at 6:00 p.m. on April 

2 1,2009 in the DEP Conference Room (room 122), 13 1 -A Peninsula Street, Wheeling, West 

Virginia 26003. Written comments will also be accepted for inclusion in the formal record by 

mail, facsimile (304-926-0479), e-mail (Tammy.L.Mowrer@,wv.aov) or other delivery to the 

Division of Air Quality if received by the close of business on April 2 1,2009. 

Send written comments to be included in the formal record to John A. Benedict, Director, 

Division of Air Quality via any of the mechanisms noted above. Mail should be sent to the 

address shown in the letterhead. Please identify the document to which the comments apply, the 

commenter's name, address, and telephone number 

If you or your staff have any questions, have any difficulty reading the CD or would like 

additional information, please feel free to contact Fred Durham, Deputy Director, at the address 

shown in the letterhead or at (304) 926-0499, ext. 1242. 

./%hn A. Benedict, Director 

Division of Air Quality 

Enclosures 

Promoting a healthy environment, 

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 12
-- -- -- - -- - 

west virginia department of environmental protection - - -- - pp 

Division of Air Quality 

601 57~ Street SE 

Charleston, WV 25304 

Phone: 304.926.0475 + Fax: 304.926.0479 

Joe Manchin 111, Governor 

Randy C. Huffman, Cabinet Secretary 

www.wvdep.org 

March 19,2009 

Bob Hodanbosi, Director 

Division of Air Pollution Control 

Ohio EPA 

50 West Town Street 

Suite 700 

Columbus, OH 4321 5 

Re: Proposed Revision to the West Virginia SIP to Demonstrate Attainment of the Annual 

PM,,, NAAQS for the West Virginia Portion of the Weirton-Steubenville (WV-OH) 

Nonattainment Area 

Dear Mr. Hodanbosi: 

The West Virginia Department of Environmental Protection, Division of Air Quality is 

herein submitting for your review and comment the enclosed Attainment Demonstration for the 

Annual National Ambient Air Quality Standard for Fine Particulate Matter (PM,,J State 

Implementation Plan for the Weirton, West Virginia Nonattainment Area, Comprising Brooke 

and Hancock Counties (proposed). We are providing a hard copy of the primary narrative but the 

supporting documentation is being supplied on a digital compact disk because of the extremely 

large volume of a comparable print out. 

As you know, the Weirton-Steubenville (WV-OH) PM2,3 nonattainment area is a multi-state 

nonattainment area, comprising Brooke and Hancock Counties in West Virginia, and Belmont 

County in Ohio. The area was designated as nonattainment with the 1997 PM,,, National 

Ambient Air Quality Standard (NAAQS) in the January 5,2005 Federal Register [70 FR 9441, 

effective April 5,2005. Upon finalization, the State of West Virginia plans to request that the 

EPA approve the Weirton attainment demonstration, with a projected attainment date of April 

20 10, as a revision to the state implementation plan (SIP). 

Promoting a healthy environment. 

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 13
Letter to Bob Hodanbosi 

March 19,2009 

Page 2 

Written and oral comments will be accepted until the close of the public hearing and will be 

made part of the formal record. The public hearing shall be held beginning at 6:00 p.m. on April 

2 1,2009 in the DEP Conference Room (room 122), 13 1 -A Peninsula Street, Wheeling, West 

Virginia 26003. Written comments will also be accepted for inclusion in the formal record by 

mail, facsimile (304-926-0479), e-mail (Tammv.L.Mowrer@,wv.gov) or other delivery to the 

Division of Air Quality if received by the close of business on April 21,2009. 

Send written comments to be included in the formal record to John A. Benedict, Director, 

Division of Air Quality via any of the mechanisms noted above. Mail should be sent to the 

address shown in the letterhead. Please identify the document to which the comments apply, the 

commenter's name, address, and telephone number 

If you or your staff have any questions, have any difficulty reading the CD or would like 

additional information, please feel free to contact Fred Durham, Deputy Director, at the address 

shown in the letterhead or at (304) 926-0499, ext. 1242. 

p45bh.n A. Benedict, Director 

Division of Air Quality 

Enclosures 

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 14
Legal Ads

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 15
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Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 16
WEST

VIRGINIA

REGISTER

Volume XXVI

Issue 12

March 20, 2009

Pages 485 - 517

A Weekly Publication

Administrative Law Division

Judy Cooper, Manager

Natalie E. Tennant

Secretary of State

Administrative Law Division

Bldg. 1, Suite 157K

1900 Kanawha Blvd. E.

Charleston, WV 25305-0770

(304) 558-6000

WWW.wvsos.com

Published by the Office ofthe Secretary of State

CONTENTS

I. Chronological Index

II. Open Govemment Meetings Listing

Ill. Price List

IV. Rule Monitor

V. Notices

a. Legislative Rules

b. Interpretive Rules

c. Procedural Rules

d. Emergency Rules

e. Legislative Rule-Making Review Committee

VI. Legislative Interims

VII. Orders

VIII. Ethics Commission Opinions

IX. Office of Tax Appeal Decisions

X. Other Documents or Information Filed

XI. Publication Deadlines and Publication Dates

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 17
INDEX

AGENCY

Administration, Dept. of

Affordable Housing Trust Fund

Air Quality

Auditor's Office

Blue Ridge Community and Technical College

Concord University

Criminal Justice Services, WV Division of

Development Office, WV

Environmental Protection

Glenville State College

GSC Board of Governors

Health and Human Resources

Health Care Authority

Higher Education Policy Commission

Highland Hospital Association

Infrastructure & Jobs Development Council

Insurance Commission

Investment Management Board, WV

Labor

Landscape Architects, Board of

Lottery

Marion County Health Department

Medicallmaging & Radiation Therapy Technology Board

Medicine, Board of

Miners' Health, Safety & Training

Natural Resources, Division of

Oil and Gas Inspectors' Examining Board, Environmental Protection

Osteopathic Medicine, WV School of, Board of Governors

PEIA

Public Defender Corporation 9th judicial Circuit

Public Health, Office of Environmental Health Services

Public Service Commission

Regional Jail and Correctional Facility Authority

Registered Professional Nurses, WV Board of Examiners

Ron Yost Personal Assistance Services (RYPAS) Board

Statewide Independent Living Council, WV

Surface Mine Board

Waste Management

West Virginia Northern Community College

WorkForce West Virginia

PAGElS)

486

486

514-15

486

486

486

486

515

516

487

487

516

487,517

487

487

487

488

488

488

488

488,510-11

488

489

489,513

489

489

489

489

489

489

490

490

490

511

490

490

513

512

491

491

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 18
FIL.EL.

NOTICE OF PUBLIC HEARING ANDPUBLIC COMMENTPJt~R \6 PM 2:46

The ~est VirginiaDep~rtment ofEn~ironmental Protection (DEP~ i~ offeringan qQ!l~J1.!Ini.tY; ~o~.r·IGiNIA

pubhc comment, andwill hold a pubhc hearing, on a proposed revision to the Stat~~0~~T~Jfi Or- STATE

Implementation Plan(SIP)to attainand maintainthe nationalambientair qualitystIlrtd'lll"d§

(NAAQS) for fineparticulate matter(pMl.$)' In this proposed revisionto the SIP, DEP

demonstrates that the WestVirginiaportionof the Weirton-Steubenville (WV-OH)PM1.s

nonattainment area, comprising BrookeandHancockCounties, wili meetthe annualPM1.s

standard bythemandatory date of April 20IO. Further,DEPshowsthat the expectedair quality

improvement willbe achievedthroughfederally enforceable emissionreduction measures. The

areawas designated as nonattainment withthe 1997PMu annualNAAQSin the January5, 2005

Federal Register[70FR 944], effectiveAprilS, 2005.

Oncefinalized, theAttainment Demonstrationfor theAnnualNational AmbientAir Quality

StandardforFineParticulate Maller(pMl,,) StateImplementation Planfor the Weirton. West

Virginia Nonattainment Area,Comprising Brooke andHancockCounties will be submitted to

U.S. EPAfor approval and incorporation as a revisionto the StateImplementation Pian(SIP).

Writtenandoral comments wili be accepteduntilthe closeof the publichearingand wiilbe

madepartofthe formal record.Pleaseidentifythe documentto whichthe comments apply,the

commenter'sname,address,and telephonenumber.

OTHER Public Notice

The publicIs hereby notlfled that the Departmentof Healthand HumanResources,

OffIce of Matemal, Child and Family Health(OMCFH), and WV Birth to Three Is posting

the Stste's application for FFY2009 funds under Pert C ofthe Indlvlduais withDisabilities

EducetlonAct,for publiccomment, The grent appllcetion Is requiredbythe U.S.

DepartmentofEducation, OffIce of Special EducationPrograms as a condition of

funding. The appllcstlonIs availablefor reviewat any WV Birth to Three Regional

Administrative Unit(MU), the WV Developmental Disabilities Council, the West VIrginia

Secretsry of State's Office, or onlineat www.WVdhhr.orolblrtb23 fromMarch 14, 2009

through May14, 2009. Persons wantingto submitwrittencomments on the state's

appllcstlon for FY2009 funds under Part C ofIDEA, may do so by emailto

dhhrwvbt!@WV.gov or by mallto: Pam Roush, Director, WV Birth to Three, 350 Capitol

Street, Room427, Charleston,WV 25301. Comments are due priorto May14, 2009.

c.n

.....

en

Writtencomments will also be acceptedforinclusion in the formalrecordby mail,facsimile

(304-926-0479), e-mailITammy.L.Mowrer@wv,goy) or otherdeliveryto the Division of Air

QualityIfreceived bythe close of businesson April21, 2009.Transmitwrittencomments to

JohnA. Benedict, Directorof the Divisionof Air Qualityat the following address:

WVDepartment of Environmental Protection

Division of AirQuality

601 57th Street,SE

Charleston, WV25304

The public hearing shall be held beginning at 6:00 p.m, on April 21, 2009at the following

location:

WVDepartment of Environmental Protection

Conference Room(room 122)

131-A Peninsula Street

Wheeling, WestVirginia26003

. Copiesof theproposed SIP revisionmay be viewedon weekdays between8:30a.m. and4:30

p.m.at the DEPWheeling office locatedat the aboveaddress. Copieswiil also be availablefor

publicreviewat the Divisionof Air Quality,60I 5~ SE,Charleston, WV25304.The proposed

SIP revision mayalso be accessedvia the following web address:

http·/lwlVw.wydep,orgljtel11,cfm'?ssjd=8&ss! jd=376

.....

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Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 19
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Weirton, WV 1997 PM2.5 SIP 

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Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 22


Public Hearing Transcript

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 25
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Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 26
WEST VIRGINIA DEPARTMENT OF ENVIRONMENTAL PROTECTION 

DIVISION OF AIR QUALITY 

In re: 

Attainment Demonstration for the Annual National Ambient Air 

Qua1 i ty Standard for Fine Particulate Matter (PM,.,) State 

Imp1 ementation Pl an for the Wei rton, West Vi rgi ni a 

Nonattainment Area, Comprising Brooke and Hancock Counties 

* * * CERTIFIED ORIGINAL 

Tuesday, Apri 1 21 , 2009 

6:07 p.m. - 6:15 p.m. 

131 -A Peninsula Street 

Wheel i ng , West Vi rgi ni a 

Present and on behalf of the 

West Virginia Department of Environmental Protection, 

Division of Air Quality 

Lawrence E. Engl i sh , Assistant Di rector 

Eri c P . Wei senborn, Envi ronmental Resources Speci a1 i st 

an Sommer LeCron, Registered Professional Reporter 

Serving West Virginia and Ohio 

F? 0. Box 634 

St. Clairsville, Ohio 43950 

(740) 699-0321 Fax (740) 699-0346 

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 27
PROCEEDINGS 

MR. ENGLISH: This public hearing will now 

come to order this 21st day of April, 2009, at the 

West Vi rgi ni a Department of Envi ronmental 

Protection, DEP, Regional Office located at 131-A 

Peni nsul a Street, Wheel i ng , West Vi rgi ni a. The 

time is 6:07 p.m. 

A notice of public hearing was sent to the 

Wheeling Intelligencer, the Charleston Gazette and 

the State Register to be published on March 20th, 

2009, and posted on the Division of Air Quality's 

websi te. 

This public hearing is being held pursuant 

to the provisions of 29A of the West Virginia Code 

and Section 110 of the Clean Ai r Act. 

My name is Larry English. I'm an Assistant 

Director with the West Virginia Department of 

Envi ronmental Protection, Division of Ai r Qua1 i ty. 

With me tonight is Eric Wei senborn, an 

Envi ronmental Resource Program Manager, a1 so with 

the West Virginia DEP, Division of Air Quality. 

The recorder for this public hearing is 

Susan Sommer LeCron. 

This public hearing is being held to a1 low 

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 28
an opportunity for public comment on a proposed 

revision to State Implementation Plan (SIP) to 

attain and maintain the national ambient air 

qua1 i ty standards (NAAQS) for fine particulate 

matter (PM,.,). In the proposed revision to the 

SIP, DEP demonstrates that West Virginia portion of 

the Wei rton-Steubenvi 11 e (Ohio and West Vi rgi ni a) 

PM,., nonattai nment area, comprised of Brooke and 

Hancock Counties, will meet the annual PM,., 

standard by the mandatory date of April 2010. 

Further, DEP shows the expected ai r quality 

improvements will be achieved through federally 

enforceable emission reduction measures. The area 

was designated nonattainment with the 1997 PM,., 

annual NAAQS in January 2005 in the Federal 

Register [70 FR 9441 , effective April 5th, 2005. 

Once finalized, the Attainment Demonstration 

for the Annual National Air Quality Standard for 

Fine Particulate Matter (PM,.,) State Imp1 ementation 

Plan for the Wei rton, West Vi rginia, Nonattai nment 

Area, Comprising Brooke and Hancock Counties, wi 11 

be submitted to the U.S. EPA for approval and 

incorporation as a revision to the State 

Imp1 ementati on Pl an (SIP) . 

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 29
4of 5- 

Written and oral comments will be accepted 

until the close of the public hearing and will be 

made part of the normal record. 

At this time, we will open this hearing for 

any public comments. 

(Silence for approximately five minutes) 

MR. ENGLISH: Let the record show it is now 

6:15. There has been no public participation or 

attendance by the general public. 

This hearing is now closed at 6: 15 p.m. on 

April 21st, 2009. 

*** 

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 30
S of SSTATE OF WEST VIRGINIA: 

SS: CERTIFICATE 

COUNTY OF OHIO: 

I, Susan Sommer LeCron , Regi stered Professional 

Reporter and Commissioner within and for the State of West 

Vi rgi nia, duly cornmi ssioned and qua1 ified, do hereby certify 

that the foregoing Transcri p t o f Proceedings i s a transcript 

of verbatim stenotype notes taken during the hearing. Said 

Transcript of Proceedings constitutes a1 1 the testimony taken 

during these proceedings. 

I do further certify that this hearing was taken at 

the time and place in the foregoing caption specified. 

I do further certify that I am not a relative, 

counsel or attorney of either party, or otherwise interested 

in the event of this action. 

IN WITNESS THEREOF, I have hereunto set my hand and 

affixed my seal of office at St. Clairsville, Ohio, on the 

22nd day of April, 2009. 

rofessional Reporter 

Commissioner within and for the 

State of West Vi rginia 

My commi ssi on expi res : 7/17/2012 

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 31
1 of 2 

I Attainment [z] - 1 :5, ENGLISH 121 - 2:2, 4:7 M 5:6 

3:17 ENVIRONMENTAL [I] - PROCEEDINGS [I] - 1 :9 

attendance [i] - 4:9 1:l proceedings [I] - 5:6 

110[1]- 2115 attorney [i] - 5: 10 Environmental 151 - maintain [I] - 3:3 Professional [2] - 53, 1 131-A121 - 1114, 215 

1997[1]-3:14 

1:17, 1:20, 2:4, 2:18, Manager [I] -2:20 518 

B 2:20 mandatory [i] - 3: 10 Program [I] - 2:20 

EPA [I] - 3122 

2 Eric [z] - 1:20, 2:19 

behalf [i] - 1 :17 event[i] - 5.11 

March 111 - 2:10 proposed [z] - 3:1, 3:5 

Matter 121 - 1 :5, 3.1 9 PROTECTION [I] - 1 :1 

matter [I] - 3:5 Protection [3] - 1 : 17, 

Brooke p] - 1 :6, 3:8, expected [I] - 3:11 measures [I] - 3:13 2:5, 2:18 2005 [2] - 311 5, 3116 3:21 expires [I] - 5:20 meet [I] - 3:9 provisions [I] - 2: 14 

2009 151 - 1112, 2:3, minutes [I] - 4:6 public[io] - 2:2, 2:8, 2:11, 4:11, 5:13 c F MR [z] - 212,417 2:13, 2:22, 2:24, 3:1, 

2010[1] - 3:lO 

20th [I] - 2:10 4:2, 4:5, 4:8, 4:9 I caption [I] - 5:8 published [I] - 2:lO 

21 111- 1:12 Federal [I] - 3:15 pursuant [I] - 2:13 

21st 121 - 2:3, 4.1 1 certify 131 - 5:4, 5:8, 510 federally - 3:12 

22nd [I] - 5:13 Charleston [i] - 2:9 finalized [I] - 3:17 NAAQS [z] - 3:4, 3:15 1 

29A [I] - 2114 Clainville 111 - 5:13 fine [I] - 3:4 name [i] - 2:16 Q 

Clean[i] -2:15 Fine [z] - 15, 3:19 National [2] - 1 :5, 3:18 

5 close [I] - 4:2 five [I] - 4:6 national [I] - 3:3 qualified [i] - 5:4 

closed 111 - 4:10 foregoing 121 - 55, 5:8 Nonattainment 121 - 1 :6, quality 121 - 34, 3.1 1 I Code (11 - 2:14 FR[i] - 3116 3:20 QUALITY [I] - 1 :I 5th [I] - 3116 comment [I] - 3:l nonattainment121- 3:8, Quality 151 - 1:5, 1:18, 

comments [z] - 4:1, 4:5 G 3:14 

6 2:18, 2:21, 3:18 commission [I] - 5:20 normal [i] - 4:3 Quality's [I] - 2:11 

commissioned [I] - 5:4 notes 111 - 5:5 

6:07[2]- 1:13, 2:7 Commissioner [z] - 5:4, Gazette [i] - 2:9 notice [I] - 2:8 

6:15[3]- 1:13, 4:8, 4.10 5:19 , general [i] - 4:9 

comprised [I] - 3:8 

Comprising [z] - 1 :6, H 0 

re [I] - 1 :4 

7 

-p OF[5]- l:l, l:l, 1:9, constitutes [I] - 5:6 

7/17/2012 [I] - 5120 Hancock 131 - 1 :6, 3:9, counsel [I] - 5:10 5:1, 5:2 

Counties 131 - 1 :6, 3:9, office[il - 5:13 

hand [i] - 5:12 Office (11 - 2:5 

record 121 - 4:3, 4:7 

recorder [I] - 2:22 

reduction [I] - 3:13 

Regional [I] - 2:5 

Register (21 - 2:10, 3:16 

Registered [2] - 53, 

5:18 

Once [I] - 3:17 

944111 - 3.16 open [I] - 4:4 

opportunity [I] - 3:l 

A date [I] - 3:10 oral [I] - 4:1 hereunto [I] - 512 

demonstrates [I] - 3:6 order [I] - 2:3 

relative [I] - 5: 10 

Reporter [z] - 5:4, 5.18 

Resource [I] - 2:20 

Resources [I] - 1 :20 

revision [3] - 3:2, 3:5, 

Demonstration [z] - 1 :5, I otherwise [I] - 5:10 

accepted [I] - 4:l 3:23 

3:17 

Act111 

achieved[i] 

- 2.15 

- 3:12 

I DEP 3:11 

141 - 215, 2:21, 316, Implementation 141 - 

- 

P s 

seal 111 - 5:13 

Section [I] - 2:15 

sent [I] - 2:8 

set[?] -512 

show [I] - 417 

shows [I] - 3:11 

Silence [I] - 4:6 

SIP 121 - 3:2, 3:6 

SIP) [I] - 3:24 

Sommer 131 - 2:23, 5:3, 

5:18 

Specialist[i] - 120 

specified [I] - 5:8 

SS [i] - 5:l 

action [I] - 311 DEPARTMENT [I] - 1 : 1 1:6, 3:2, 3:19, 3:24 

improvements[1] - 3:12 p.m 141 - 1:13, 2:7, 4:10 

IN [I] - 5112 part[i] - 4:3 

incorporation [I] - 3:23 - 43 

Intelligencer[i] - 2:9 Particulate [2] - l:5, 

affixed 111 - 513 Department 131 - 1 :17, 

Area 121 - 1 :6, 3:21 either111 - 5:10 Lawrence [I] - 1 :19 portion [I] - 3:6 St[l] - 5113 

AIR [i] - 1 :I 

air121 - 3:3, 3.1 1 

Air171-1:5,1:18,2:11, 

Assistant 121 - 1 :ig, 

2:16 

2:4, 2:17 

designated [I] - 3:14 

Director[2]-1:19,2:17 2115, 2:18, 2121, 3118 

emission [I] - 3:13 LeCron 131 - 2:23, 5:3, posted [I] - 2:11 standard [I] - 3: 10 

enforceable [I] - 3:13 5:18 

DIVISION - I ;Iinterested [i] - 5:10 

allow (11 - 2:24 Division 141 - 1 : 18, 2: 11, particulate [I] - 3:4 

Ambient [I] - 1 :5 2:18, 2:21 party [I] - 5:lO 

ambient [I] - 3:3 duly [I] - 5:4 Peninsula 121 - 1 :14, 2:6 

annual [z] - 3:9, 3:15 during [z] - 55, 5:6 place [I] - 5:8 January [I] - 3:15 Annual [z] - 1 :5, 3:18 Plan (41 - 1:6, 3:2, 3:20, 

approval [I] - 3:22 E L 3:24 

April [6] - 1:12, 2:3, PM2.5 151 - 15, 3:8, 3:9, 

3:10, 3:16, 4:11, 5:13 3:14, 3:19 

area [z] - 3:8, 3:13 effective [I] - 3:16 '1 Larry[i] - 2:16 PM2.5) [I] - 315 

Present [I] - l:17 

attain [I] - 3:3 

Standard 121 - 1:5, 3:18 

English121 -1:19, 2:16 located 111 - 2:s Proceedings [z] - 5:5, standards [I] - 3:4 

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 32
State [7] - 1:5, 2:10, 3:2, 

3:19, 3:23, 5:4, 5:19 

STATE [I] - 5: 1 

stenotype [I] - 5:5 

Steubenville [I] - 3:7 

Street [z] - 1 :I 4, 2:6 

submitted [I] - 3:22 

Susan [3] - 2:23, 5:3, 

5:18 

testimony [I] - 5:6 

THEREOF [I] - 5:12 

tonight[i] - 2:19 

TRANSCRIPT [I] - 1 :9 

Transcript [z] - 5:5, 5:6 

transcript [i] - 5:5 

Tuesday [I] - 1:12 

verbatim [i] - 5:5 

VIRGINIA[z] - 1:1, 5:l 

Virginia[i3] - 1:6, 1:15, 

1:17, 2:4, 2:6, 2:14, 

2:17, 2:21, 3:6, 3:7, 

3:20, 5:4, 5:19 

website111 - 2:12 

Weirton [3] - 1:6, 3:7, 

3:20 

Weirton-Steubenville 

[1] - 3:7 

Weisenborn [z] - 1 :20, 

2:19 

WEST[z] - 1:1, 511 

West[i3] - 1:6, 1:15, 

1:17, 2:4, 2:6, 2:14, 

2:17, 2:21, 3:6, 3:7, 

3:20, 5:4, 5:19 

Wheeling [3] - 1 :I 5, 2:6, 

2:9 

WITNESS [I] - 5:12 

Written [I] - 4:l 

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 33
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Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 34
Public Comments

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 35
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Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 36
EPA Comments

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 37
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Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 38
,TED 

."*a "'t 

1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

$ we: REGION Ill 

t 1650 Arch Street 

++r 4' 

41 pR6tG Philadelphia, Pennsylvania 191 03-2029 

Mr. John A. Benedict, Director 

Division of Air Quality 

West Virginia Department of Environmental Protection 

601 57th St. SE 

Charleston, WV 25304 

Dear Mr. Benedict: 

Thank you for the opportunity to comment on West Virginia's proposed Attainment Plan 

for the West Virginia portion of the Steubenville-Weirton OH-WV nonattainment area. The 

Environmental Protection Agency (EPA) comments are provided in the enclosures to this letter. 

We look forward to working with you to resolve these comments. Should you have any 

questions pertaining to these comments, please do not hesitate to contact me, or have your staff 

person contact Ms. Marilyn Powers of my staff at (2 15) 8 14-2308. 

Sincerely, 

Diana Esher, Acting Director 

Air Protection Division 

Enclosures 

cc: Fred Durham, WVDEP 

rn 

tS Printed on 100% recycled/recyclable paper with 100% post-consumer fiber and process chlorine free. 

Weirton, WV 1997 PM2.5 SIP

Customer Service Hotline: 1-800-438-2474 

Appendix Q Page - 39
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Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 40
Enclosure (1) 

EPA Region 3 Comments 

Proposed Attainment Demonstration for the Steubenville-Weirton OH-WV PM2.5 

Nonattainment Area 

1. The title for the SIP is misleading. The plan must be for attainment of the PM2.5 national 

ambient air quality standard, not just the annual standard. The nonattainment designations 

were made for PM2.5 and did not specify only the annual standard. The PM2.5 

Implementation Rule (72 Fed. Reg. 20600, April 25,2007) explicitly refers to determining 

attainment of the annual and 24-hour standards. The Federal Regulations of 40 CFR 5 1 reads 

(in part) 

51.1007 Attainment demonstration and modeling requirements. 

(a) For any area designated as nonattainment for the PM2 5 NAAQS, the State must 

submit an attainment demonstration showing that the area will attain the annual and 24- 

hour standards as expeditiously as practicable. The demonstration must meet the 

requirements of $5 1.1 12 and Appendix W of this part and must include inventory data, 

modeling results, and emission reduction analyses on whch the State has based its 

projected attainment date. The attainment date justified by the demonstration must be 

consistent with the requirements of 95 1.1004(a). The modeled strategies must be 

consistent with requirements in 95 1.1009 for RFP and in 95 1.10 10 for RACT and 

RACM. Tkie attainment demonstration and supporting air quality modeling should be 

consistent with EPA's PM2.5 modeling guidance." 

Also, references to the nonattainment area should be consistent throughout the document. 

For example, Section 1.0 refers to "The Weirton-Steubenville, WV-OH annual PM2.5 

nonattainment area.. .", while the document title and Section 6.1 .b. refers to the "Weirton 

Area" in both the introductory text and in Tables 2.2-1,6.1-1, and 6.3-1. The area was 

designated as the "Steubenville-Weirton OH-WV" nonattainment area in keeping with the 

Census Bureau's Combined Statistical Area (CSA) nomenclature. 

2. The first sentence of the Introduction incorrectly states, "The Weirton-Steubenville, WV-OH 

annual nonattainrnent area is a multi-state nonattainment area, comprising Brooke and Hancock 

Counties, West Virginia, and Jefferson County, Ohio.", and the last sentence incorrectly states 

"The area was designated as nonattainment with the 1997 annual PM2.5 National Ambient Air 

Quality Standard (NAAQS) in the January 5,2005 Federal Register [70 FR 0441, effective April 5, 

2005 ." The area was designated as nonattainment for the fine particle NAAQS, not just the annual 

NAAQS. Although most of the designations were made because of annual NAAQS violations no 

distinction was made between annual and 24-hour areas. The fact that the 24-hour NAAQS was 

revised in 2006 and will be addressed with designations and subsequent SIP requirements does not 

relieve West Virginia fi-om the obligation of demonstrating attainment with both the annual and 

24-hour (1997 version) NAAQS. It is noted that the attainment demonstration contained in ths 

document does address both averaging periods. 

3. The last sentence on page 5 of section 1.4 reads, "The design values for the Weirton 

nonattainment area for both the annual and 24-hour standards are presented in Table 1.4-1 ." Table 

1.4.1 is incomplete. The document must, in addition, demonstrate that all of the CAA 

requirements associated with the 1997 PM2.5 NAAQS have been met; and that the SteubenvilleWeirton OH-WV nonattainment area will attain compliance with the 1997 PM2.5 NAAQS as 

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 41
Enclosure (1) 

EPA Region 3 Comments 

Proposed Attainment Demonstration for the Steubenville-Weirton OH-WV PMz.5 

Nonattainment Area 

expeditiously as practicable, and not later than 2010. Design values for all monitors in the 

nonattainment area, including those in Ohio, must also be included in the document. See also the 

first comment in Enclosure (2). 

4. The paragraph after Table 1.4-1 includes information that pertains to the 2006 daily 

standard: "A violation of the daily 2006 NAAQS for PM2.5 occurs when the annual 9gth 

percentile concentration, averaged over three years, is greater than 35 pg/m3." This 

discussion is not pertinent to this document; it is suggested that it be removed or revised to 

refer to the daily 1997 PM2.5 standard. 

5. The third paragraph of Section 8.7 states: "The WVDAQ believes that with the exception of 

110(a)(2(G) concern discussed above, through West Virginia's certification efforts and the Section 

11 0(a)(2) infrastructure SIP revision, along wit11 this attainment demonstration address the relevant 

requirements of Section 110(a)(2)." This statement does not appear to be consistent with the 

certification submitted to EPA by WVDEP regarding the section 1 10(a)(2)(G) requirements. As 

part of the State's obligation to address section 110(a)(2) infrastructure requirements, on July 14, 

2008, WVDEP submitted a letter that certifies that West Virginia satisfies the requirements of 

Section 110(a)(2)(G), therefore the language in Section 8.7 of the attainment plan should be 

revised. 

6. The first paragraph of Section 8.9.a states: "All measures and other elements in the SIP must 

be enforceable by the statellocal governments andlor EPA [See Section 172(c)(6) and 110(a)(2)(A 

of the Act and 57 FR 13556." This language infers that state-enforceable only measures and other 

elements may be part of the SIP. However, to be included as part of the attainment plan SIP, these 

must be enforceable by both the statellocal and EPA. 

7. In Table 6.6-1, please include the associated regulations that were adopted by the State for 

Point source measures 6.1 .a. 1 .and 6.1 .a. 1 .D. Also please correct the information for area source 

measure 6.2.a.l for Open Burning Restrictions - this is a State rule, not a federal mandate. 

8. The measures identified to meet contingency requirements are the emission reductions achieved 

from controls on specific power plants that are located within the area of influence as shown in 

Section 8.9. For the West Virginia portion of the Steubenville-Weirton nonattainment area, the 

contingency requirement is met through the controls that are scheduled to be installed on the Ft. 

Martin Power Station starting in 2010. The plan notes that "These reductions were not included in 

the modeled attainment demonstration and are therefore creditable." However, the fifth paragraph 

on page 11 1 notes that this facility is ". . .installing wet scrubbers to meet the SOz reduction 

requirements of CAIR..". If these are being installed to meet CAR, and if CAR was included in 

the modeling, there seems to be an inconsistency in the document that should be explained in more 

detail. 

9. Section 8.9.e provides a discussion of the equivalency ratios that were determined based on the 

attainment modeling that was completed for the Steubenville-Weirton nonattainment area, and 

which are proposed for purposes of contingency requirements. EPA notes that these interpollutant 

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 42
Enclosure (1) 

EPA Region 3 Comments 

Proposed Attainment Demonstration for the Steubenville-Weirton OH-WV 

Nonattainment Area 

equivalencies are not allowable for purposes of interpollutant trading to comply with NSR offset 

requirements. EPA's May 16,2008 regulation entitled "Implementation of the New Source 

Review (NSR) Program for Particulate Matter Less Than 2.5 Micrometers (PM2.5)" sets forth 

preferred interpollutant trading ratios that may be used for PM2.5 offsets (see page 28339), and 

recommended that States use these trading ratios in their interpollutant trading programs to provide 

consistency and streamline the trading process. States that choose to develop their own 

hierarchiesltrading ratios would be required to provide modeling andlor other technical 

demonstrations of the net air quality benefit for PM2 5 ambient concentrations which would be 

required to be approved by EPA into the State's SIP. 

10. The Weirton submittal refers to two types of base year emission inventories - an actual base 

year and a typical base year (using a normalization methodology for EGUs and Wildfires). Are the 

numbers in the tables in section 4.1 .d, (Table 4.1 .d-1) of the SIP and in Appendix C representative 

of "typical" annual emissions? If so, the CAA states: 

"..the State shall submit a comprehensive, accurate, current inventory of actual emissions 

from all sources, as described in section 7502 (c)(3) of this title, in accordance with 

guidance provided by the Administrator." 

Also, the 2005 Guidance Document entitled "Emission Inventory Guidance for Implementation of 

Ozone and Particulate Matter National Ambient Air Quality Standards (NAAQS) and Regional 

Haze Regulations" also reiterates that "the base year inventory be comprehensive, accurate, and 

current for all actual emissions". 

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 43
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Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 44
Enclosure (2) 

Steubenville-Weirton, OH-WV Annual PM-2.5 SIP 

Comments from EPA Region 3 Air-Quality Analysis Branch 

April 2009 

Section 1.4 

Design values for the entire Steubenville-Weirton, OH-WV nonattainment area should be 

included in the SIP. There are two (2) additional monitors in Ohio's Jefferson County 

that were not presented or acknowledged in West Virginia's SIP. PM-2.5 concentrations 

for these two monitors are summarized in the following table fiom information provided 

by the OH EPA. WV DEP is encouraged to verify this information and include it in their 

final SIP. 

Jefferson County, OH PM-2.5 Values 

Section 2.1 

The figures included in this section indicate very high PM-2.5 concentrations at the end 

of June and the beginning of July 2002. Did WV DEP flag any of its data due to the 

Quebec fires that occurred during the summer of 2002? 

Section 2.4b and 2.4~ 

It would be useful to show 2002 and 2009 emission breakdowns for SOz and NO,. 

Similar analyses were shown for VOC and Ammonia in sections 2.4d and 2.4e. 

Section 7.1 and Appendix J 

The data WV DEP used to in its Voronoi Neighbor Averaging (VNA) analysis does not 

include any speciation data from the West Virginia Panhandle area. The nearest 

speciated monitor to the Steubenville-Weirton nonattainment area used in this analysis 

appears to be in western Pennsylvania (Florence, PA), which began collecting data in 

April of 2002 (PA DEP Annual Ambient Air Quality Report, 2004). Our concern is West 

Virginia's estimation method, though used in accordance with current EPA modeling 

guidelines, may "smooth out" any peaks in the speciated data generated by local sources. 

Any "missed" local peaks could cause an underestimation of West Virginia's projected 

PM-2.5 design concentrations. WV DEP could examine speciation data collected at 

Ohio's Steubenville monitor (39-081-0017) to determine if there are any local peaks that 

were not resolved in the regional analysis. 

Section 7.2 

Attainment test results for the 24-hour PM-2.5 standard should also be included in this 

section. This information would be useful in gauging this region's possible attainment of 

EPA's revised (2006) PM-2.5 National Ambient Air Quality Standard (NAAQS). 

Weirton, WV 1997 PM2.5 SIP

Page 1 of 6 

Appendix Q Page - 45
Enclosure (2) 

Steubenville-Weirton, OH-WV Annual PM-2.5 SIP 

Comments from EPA Region 3 Air-Quality Analysis Branch 

April 2009 

West Virginia's projected 2009 design values are higher than the 2006-2008 design 

values; a projected 2009 max design value of 14.2 pg/m3 vs. an actual 2006-2008 design 

value of 15.4 pg/m3. WV DEP may also want to compare projected quarterly values to 

actual quarterly values. This apparent under prediction of annual PM-2.5 concentrations 

should be discussed. 

Section 7.3.b 

PM-2.5 concentrations in the WV portion of the Steubenville-Weirton, OH-WV 

nonattainment area do appear to be declining. To determine if these declines are 

statistically significant, data from Appendix A was analyzed using the R statistical 

software package version 2.8.1 (http://www.r-proiect.ord). 

R was used to analyze the annual PM-2.5 concentrations at the Follansbee (54-009-0005) 

monitor located in Brooke County, WV. This monitor is the current design monitor in 

the Steubenville-Weirton, OH-WV nonattainment area (hghest annual design value). A 

"best fit" line was calculated with R using a 95% confidence interval. The following 

figure shows Follansbee's annual averages from 1999 through 2008 along with the "best 

fit" line, the equation for the line and its R~ value. 

F~l~ansbee, WV Annual PM9.5 

0 

CU r 

P 

E 5x 

m 

U 

s 

0 

22 

5' 

I 1 I I I 

2000 2002 ZDO4 2006 2008 

Year 

Weirton, WV 1997 PM2.5 SIP

Page 2 of 6 

Appendix Q Page - 46
Enclosure (2) 

Steubenville-Weirton, OH-WV Annual PM-2.5 SIP 

Comments from EPA Region 3 Air-Quality Analysis Branch 

April 2009 

Statistical tests and the R~ values indicate a slight downward trend in Follansbee's annual 

PM-2.5 concentrations. This tend, however, appears to have only been recently 

established and upon closer examination is isolated to certain periods of the year. 

Rerunning R without 2008 data removes any statistically significant trend in Follansbee's 

annual PM-2.5 concentrations. The next figure shows R-analysis results using annual 

concentrations from 1999 through 2007. Note the lower slope and R~ values indicating 

less of a trend in the data. 

Follansbee, W Annual PM-2.5 

w 

CU 

8 

Cd e 

0 .- 

'ijj 

E 

C 

z 

U 

? 

z I I I I 

2090 2002 2004 2006 

Year 

Trends in Follansbee's quarterly average PM-2.5 values, which are used to determine the 

annual PM-2.5 values, show that downward trends are largely limited to the 2nd and 4~ 

quarters. There is a slight downward trend in the lSt quarter and no trend in the 3Td 

quarter. The figure on the following page shows the results of the R analysis for 

Follansbee's quarterly PM-2.5 concentrations. 

Follansbee's data seem to indicate that the overall downward trend is due to declines in 

its 2nd and 4~ quarter PM-2.5 concentrations. Only a slight downward trend is noted in 

the 1 st quarter and absolutely no trend is observed during the 3rd quarter when PM-2.5 

concentrations tend to be the highest. While not fully accounted for here, peak 

Weirton, WV 1997 PM2.5 SIP

Page 3 of 6 

Appendix Q Page - 47
Enclosure (2) 

Steubenville-Weirton, OH-WV Annual PM-2.5 SIP 

Comments from EPA Region 3 Air-Quality Analysis Branch 

April 2009 

summertime (3'd quarter) PM-2.5 concentrations tend to be driven by sulfates. Sulfates 

are primarily formed from SOz emissions from nearb coal-fired power plants along the '7 Ohio River. The lack of any trend in Follansbee's 3' quarter PM-2.5 concentrations 

would seem to indicate that any long-term SO2 reductions through the acid rain program 

alluded to in WV DEP's SIP (if they are occurring at all) are not having much of an 

impact on local PM-2.5 concentrations. Persistently high PM-2.5 concentrations during 

the 3'd quarter may actually be offsetting reductions observed in the other quarters. 

Definitive downward trends in the other quarters may be due to reductions from the 

mobile-source sector since at these times of year monitors tend to be more affected by 

local emissions partially in response to the higher frequency of terrain-induced 

temperature inversions. 

Follansbte, WV 1st Quarter Falrans bee, W 2nd Quarter 

Year Year 

Follansbee, WV 3rd Quarter Frrllansbae, WY 4th Quarter 

XClO 2Oa4 26Q3 MOO 2MB 

Year Yebr I 

Third quarter trends could be established in the future once sufficient SOz reductions via 

the U.S. EPA's CAR program are actually achieved. Many flue-gas desulphurization 

(FGD) installations are due to come on line with the next year or so. Definitive 

downward trends in 3rd quarter PM-2.5 concentrations should have a significant impact 

on annual design values since this quarter largely drives monitor annual averages. 

Weirton, WV 1997 PM2.5 SIP

Page 4 of 6 

Appendix Q Page - 48
Enclosure (2) 

Steubenville-Weirton, OH-WV Annual PM-2.5 SIP 

Comments from EPA Region 3 Air-Quality Analysis Branch 

April 2009 

Declining 3rd quarter concentrations should also have an impact on 24-hour PM-2.5 

design values since there would then be statistically significant declines throughout the 

year. Care must be taken to show that emission declines are in response to the 

implementation of emission control programs and not due to poor economic conditions. 

R Statistical Summary of Follansbee, WV Monitor 

R software (http://www.r-project.org/) was used to determine trends in the Follansbee, 

WV monitor data and to analyze for statistical significance. Linear trend lines were 

generated by R, including the "best fit" line, its R~ value and associated equation (slope, 

0, and intercept, Po). Standard t and P statistics were then generated using a 95% 

confidence interval. The t and P statistics were used to test the null hypothesis, Ho. A 

statistical summary for the Follansbee monitor is shown in the following table. 

Follansbee R-Statistical Analysis Table 

81 80 R~ t-value P>ltl 

Annual Avg (99-08) -0.2404 498.2190 0.5197 -2.942 0.0187 

Annual Avg (99-07) -0.1765 370.2639 0.3475 -1.931 0.0948 

1st Quarter (99-08) -0.2715 558.5286 0.4072 -2.344 0.0471 

2nd Quarter (99-08) -0.4014 821.3818 0.6819 -4.141 0.0032 

3rd Quarter (99-08) 0.09248 -165.0854 0.0191 0.395 0.703 1 

4th Quarter (99-08) -0.3809 777.3204 0.5598 -3.190 0.0128 

t-value and P calculated for 95% confidence interval 

For the null hypothesis (Ho or possibility of zero slope) to be false it is generally accepted 

that t values for the 95% confidence interval will be outside of the following interval, 

-2.0150 < t < 2.0150, and P values will be such that P < .05. From the table above it is 

clear that the null hypothesis (Ho) is probably false for the full suite of Follansbee's 

annual concentrations (1 999-2008) along with 2"d quarter and 4th quarter PM-2.5 

concentrations. Therefore there is a statistically significant (downward) trend in these 

data. The null hypothesis (Ho) can not be ruled out for a smaller subset of the annual 

concentrations (1999-2007), the 3rd quarter and possibly the 1" quarter, thus indicating 

there are no statistically significant trends in these data. 

Weirton, WV 1997 PM2.5 SIP

Page 5 of 6 

Appendix Q Page - 49
Enclosure (2) 

Steubenville-Weirton, OH-WV Annual PM-2.5 SIP 

Comments from EPA Regon 3 Air-Quality Analysis Branch 

April 2009 

Section 8.9~ and 8.9d 

WV DEP is relying on the installation of FGD units on the Ft. Martin Power Station 

located east of the Steubenville-Weirton, OH-WV nonattainment areti as part of its 

contingency measures. WV DEP contends that SO2 emission reductions from the Ft. 

Martin Power Station will provide more than sufficient emission reductions to meet its 

contingency requirements. The tables presented in the SIP should account for any 

projected increases in emissions within the area of influence established by WV DEP. 

The proposed Longview Power Plant (Longview) being constructed near Maidsville, WV 

is within the Weirton area of influence. Projected emissions from this new facility are 

-1739 tpy NO,, -2417 tpy SO2 and - 482 tpy of PM. Longview is scheduled to begin 

operations sometime after 2010. 

Comment on SIP Appendices 

The appendices used in the WV DEP's Weirton, WV SIP appear to be similar to those it 

used in its Huntington, WV SIP. EPA has provided comments regarding some of these 

appendices for Huntington. Will any changes to these appendices in response to our 

comments also be made for the Weirton, WV SIP? Does WV DEP intend to have 

identical appendices for all of its PM-2.5 SIPS? 

Weirton, WV 1997 PM2.5 SIP

Page 6 of 6 

Appendix Q Page - 50
Response to Comments

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 51
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Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 52
West Virginia 

1997 Fine Particle Matter (PM2.5) State Implementation Plan

for the West Virginia Portion of the 

Weirton Nonattainment Area, 

Comprising Brooke and Hancock Counties

RESPONSE TO COMMENTS

On March 20, 2009, the Department of Environmental Protection, Division of Air Quality

(WVDAQ) commenced the public comment period and subsequently held a public hearing on April

21, 2009 to accept oral comments on the proposed Attainment Demonstration for the Annual

National Ambient Air Quality Standard for Fine Particulate Matter (PM2.5) State Implementation

Plan for the Weirton, West Virginia Nonattainment Area, Comprising Brooke and Hancock

Counties. Written comments were also accepted through 6:00 PM on Tuesday, April 21, 2009. 

There was no attendance at the hearing by the general public, so no oral comments were received. 

The United States Environmental Protection Agency (EPA) submitted written comments on the

proposed SIP. WVDAQ addresses these comments below.

I. United Stated Environmental Protection Agency (EPA)

COMMENT A:

The title for the SIP is misleading. The plan must be for attainment of the PM2.5 national

ambient air quality standard, not just the annual standard. The nonattainment designations

were made for PM2.5 and did not specify only the annual standard. The PM2.5 Implementation

Rule (72 FR 20600, April 25, 2007) explicitly refers to determining attainment of the annual

and 24-hour standards. The Federal Regulations of 40 CFR 51 reads (in part):

51.1007 Attainment demonstration and modeling requirements.

(a) For any area designated as nonattainment for the PM2.5 NAAQS, the State must

submit an attainment demonstration showing that the area will attain the annual and

24-hour standards as expeditiously as practicable. The demonstration must meet the

requirements of §51.112 and Appendix W of this part and must include inventory

data, modeling results, and emissions reduction analyses on which the State has

based its projected attainment date. The attainment date justified by the

demonstration must be consistent with the requirements of §51.1004(a). The modeled

strategies must be consistent with requirements in §51.1009 for RFP and in

§51.1010 for RACT and RACM. The attainment demonstration and supporting air

quality modeling should be consistent with EPA’s PM2.5 modeling guidance.

Weirton, WV PM2.5 SIP Response to Comments Page 1

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 53
Also, references to the nonattainment area should be consistent throughout the document.

For example, Section 1.0 refers to the “The Weirton-Steubenville, WV-OH annual PM2.5

nonattainment area...”, while the document title and Section 6.1.b refers to the “Weirton

Area” in both the introductory text and in Tables 2.2-1, 6.1-1 and 6.3-1. The area was

designated as the “Steubenville-Weirton OH-WV” nonattainment area in keeping with the

Census Bureau’s Combined Statistical Area (CSA) nomenclature.

RESPONSE A:

The title of the SIP has been changed to: West Virginia 1997 Fine Particle Matter (PM2.5)

State Implementation Plan for West Virginia Portion of the Steubenville-Weirton, OH-WV

Nonattainment Area, Comprising Brooke and Hancock Counties. As EPA noted in comment

B below, the attainment demonstration contained in the SIP addresses both the 1997 annual

and 24-hour averaging periods. 

The first reference to the “West Virginia Portion of the Steubenville-Weirton, OH-WV

Nonattainment Area” in the SIP narrative has been changed to read “West Virginia Portion

of the Steubenville-Weirton, OH-WV Nonattainment Area (Weirton Area).” 

COMMENT B:

The first sentence of the Introduction incorrectly states, “The Weirton-Steubenville, WV-OH

annual PM2.5 nonattainment area is a multi-state nonattainment area, comprising Brooke

and Hancock Counties, West Viginia and Jefferson County Ohio.”, and the last sentence

incorrectly states, “The area was designated as nonattainment with the 1997 annual PM2.5

NAAQS in the January 5, 2005 Federal Register [70 FR 044], effective April 5, 2005". The

area was designated as nonattainment for the fine particle NAAQS not just the annual

NAAQS. Although most of the designations were made because of annual NAAQS violations,

no distinction was made between annual and 24-hour areas. The fact that the 24-hour

NAAQS was revised in 2006 and has been addressed with designations and subsequent SIP

requirements does not relieve West Virginia from the obligation of demonstrating attainment

with both the annual and 24-hour (1997 version) NAAQS. It is noted that the attainment

demonstration contained in this document does address both averaging periods.

RESPONSE B:

We have deleted the word “annual” from the first and last sentences of the Introduction.

Weirton, WV PM2.5 SIP Response to Comments Page 2

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 54
COMMENT C:

The last sentence on page 5 of Section 1.4 reads, “The design values for the Weirton

nonattainment area for both the annual and 24-hour standards are presented in Table 1.4-

1.” Table 1.4-1 is incomplete. The document must, in addition, demonstrate that all of the

CAA requirements associated with the 1997 PM2.5 NAAQS have been met; and that the

Steubenville-Weirton OH-WV nonattainment area will attain compliance with the 1997

PM2.5 NAAQS as expeditiously as practicable, and not later than 2010. Design values for all

monitors in the nonattainment area, including those in Ohio, must also be included in the

document. See also the first comment in Enclosure (2). [Comment K, below] 

RESPONSE C:

We have added the data for the Ohio monitors to Table 1.4-1 and Appendix A. The data

confirms attainment of the 1997 24-hour standard of 65 μg/m3. Section 7.2 of the SIP

narrative demonstrates attainment of both the 1997 annual and 24-hour NAAQS.

COMMENT D:

The paragraph after Table 1.4-1 includes information that pertains to the 2006 daily

standard: “A violation of the daily 2006 NAAQS for PM2.5 occurs when the annual 98th

percentile concentration averaged over three years is greater than 35 μg/m3.” This

discussion is not pertinent to this document; it is suggested that it be removed or revised to

refer to the daily 1997 PM2.5 standard.

RESPONSE D:

The language has been revised to refer to the daily 1997 PM2.5 standard of 65 μg/m3

.

COMMENT E:

The third paragraph of Section 8.7 states: “The WVDAQ believes that with the exception of

110(a)(2)(G) concern discussed above, through West Virginia’s certification efforts and the

Section 110(a)(2) infrastructure SIP revision, along with this attainment demonstration

address the relevant requirements of Section 110(a)(2).” This statement does not appear to

be consistent with the certification submitted to EPA by WVDEP regarding Section

110(a)(2)(G) requirements. As part of the State’s obligation to address Section 110(a)(2)

infrastructure requirements, in July 14, 2008 WVDEP submitted a letter that certifies that

West Virginia satisfies the requirements of Section 110(a)(2)(G), therefore the language in

Section 8.7 of the attainment plan should be revised.

Weirton, WV PM2.5 SIP Response to Comments Page 3

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 55
RESPONSE E:

DAQ has removed the referenced statement from the SIP Narrative, and added the following

language: 

On October 22, 2008, EPA published a finding that West Virginia

had submitted a complete State Implementation Plan (SIP) that

provides the basic program elements specified in section 110(a)(2) of

the Clean Air Act (CAA or Act) necessary to implement the 1997

Fine Particulate Matter (PM2.5) National Ambient Air Quality

Standards (NAAQS) [73 Federal Register 62902/62905].

COMMENT F:

The first paragraph of Section 8.9.a states: “All measures and other elements in the SIP

must be enforceable by the state/local governments and/or EPA [See Section 172(c)(6) and

110(a)(2)(A) of the CAA and 57 FR 13556.” This language infers that state-enforceable only

measures and other elements may be part of the SIP. However, to be included as part of the

attainment plan SIP, these must be enforceable by both the state/local and EPA.

RESPONSE F:

DAQ agrees that ultimately all measures must be enforceable by the state/local government

and EPA. However, the language is written to reflect the fact that this SIP includes two (2)

State Consent Orders that require year round operation of NOx controls on specific EGUs,

that are state enforceable until this SIP is approved. Upon SIP approval these state

enforceable measures become enforceable by EPA, as well as by the state/local government.

COMMENT G:

In Table 6.6-1, please include the associated regulations that were adopted by the State for

Point Source Measures 6.1.a.1 and 6.1.a.1.D. Also, please correct the information for area

source measure 6.2.a.1 for Open Burning Restriction - this is a State rule, not a federal

mandate.

RESPONSE G:

Table 6.6-1 is a summary table of the measures described in Sections 6.1 - 6.4 of the SIP

narrative.

As stated on page 81, Section 6.1.a.1.A.:

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Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 56
For each PM2.5 nonattainment area, 40 CFR §51.1010 notes that a SIP

revision demonstrating that all reasonable available control measures,

including RACT for stationary sources, necessary to demonstrate

attainment as expeditiously as practicable, have been adopted. The

section of the implementation rule goes on to state that potential

measures that are reasonably available, considering technical and

economic feasibility, must be adopted as Reasonably Available

Control Measures (RACM) if, considered collectively, they would

advance the attainment date by one year or more. As discussed in

detail in Section 9, West Virginia determined that there are no

additional measures, and those planned for implementation by 2009,

are expected to enable the area to demonstrate compliance with the

1997 PM2.5 NAAQS by the 2010 attainment date. As such, no

further action on RACT is warranted.

Table 6.6-1 identifies State Rules 45CSR2, 45CSR3, 45CSR5, 45CSR7 and 45CSR17 as

state rules which contain standards regarding fugitive dust. These requirements are discussed

in Section 6.1.a.1.D.

The reference in Table 6.6-1, to section 6.2.a.1. regarding Open Burning Restrictions has

been corrected to indicate that it is a State Mandate, not a federal mandate.

COMMENT H:

The measures identified to meet contingency requirements are the emission reductions

achieved from controls on specific power plants that are located within the area of influence

as shown in Section 8.9 For the West Virginia portion of the Steubenville-Weirton

nonattainment area, the contingency requirement is met through the controls that are

scheduled to be installed on the Ft. Martin Power Station starting in 2010. The plan notes

that “These reductions were not included in the modeled attainment demonstration and are

therefore creditable.” However, the fifth paragraph on page 111 notes that this facility is

“...installing wet scrubbers to meet the SO2 reduction requirements of CAIR..”. If these are

being installed to meet CAIR, and if CAIR was included in the modeling, there seems to be

an inconsistency in the document that should be explained in more detail.

RESPONSE H:

The controls that are currently under construction at Ft. Martin are being installed to meet

the SO2 reduction requirements of the CAIR. The CAIR SO2 reduction requirements begin

in 2010, although the annual CAIR NOx reduction requirements began in 2009. However,

since the CAIR program is a cap and trade program, with credits earned for early reductions,

some CAIR SO2 controls were installed and operational in 2008 and 2009, while others will

not be operational until 2010 or later. The controls at Ft. Martin are not scheduled to come

Weirton, WV PM2.5 SIP Response to Comments Page 5

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online until 2010. Since the attainment date for the PM2.5 NAAQS is April 2010, the

attainment demonstration modeling was done for 2009, demonstrating attainment for the full

year prior to the attainment date. Although CAIR requirements were taken into account for

the modeling, the controls were applied on a unit specific basis, based on the best

information available at the time of the modeling. The controls on Ft. Martin were not

included in the 2009 modeling, since they are not scheduled to be online until 2010.

COMMENT I:

Section 8.9.e provides a discussion of the equivalency ratios that were determined based on

the attainment modeling that was completed for the Steubenville-Weirton nonattainment

area, and which are proposed for purposes of contingency requirements. EPA notes that

these interpollutant equivalencies are not allowable for purposes of interpollutant trading

to comply with NSR offset requirements. EPA's May 16,2008 regulation entitled

"Implementation of the New Source Review (NSR) Program for Particulate Matter Less

Than 2.5 Micrometers (PM2.5)" sets forth preferred interpollutant trading ratios that may be

used for PM2.5 offsets (see page 28339), and recommended that States use these trading

ratios in their interpollutant trading programs to provide consistency and streamline the

trading process. States that choose to develop their own hierarchies/trading ratios would

be required to provide modeling andlor other technical demonstrations of the net air quality

benefit for PM2.5 ambient concentrations which would be required to be approved by EPA

into the State's SIP.

RESPONSE I:

These ratios were not proposed to be used for interpollutant trading to comply with NSR

offset requirements. The equivalencies were determined as a basis for determining the

adequacy of contingency measures based on guidance provided by EPA Region III staff in

an email, dated 5/19/2008, (see Attachment 1) in which it was recommended that the

methodology used in the Washington, DC PM2.5 SIP, as outlined in their Appendix J, be

used.

COMMENT J:

The Weirton submittal refers to two types of base year emission inventories - an actual base

year and a typical base year (using a normalization methodology for EGUs and Wildfires).

Are the numbers in the tables in section 4.1 .d, (Table 4.1 .d-1) of the SIP and in Appendix

C representative of "typical" annual emissions? If so, the CAA states:

"..the State shall submit a comprehensive, accurate, current inventory of actual

emissions from all sources, as described in section 7502 (c)(3) of this title, in

accordance with guidance provided by the Administrator."

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Also, the 2005 Guidance Document entitled "Emission Inventory Guidance for

Implementation of Ozone and Particulate Matter National Ambient Air Quality Standards

(NAAQS) and Regional Haze Regulations" also reiterates that "the base year inventory be

comprehensive, accurate, and current for all actual emissions".

RESPONSE J:

The inventory data provided in section 4.1.d (Table 4.1d-1) of the SIP and in Appendix C

reflect “actual “ emissions. During the drafting of the Proposed Weirton SIP, and after the

start of the public comment period on the Proposed Huntington SIP, it was recognized that

the typical/actual discussion in the EGU section warranted further elaboration about how 

the data were used. A similar expansion of section 4.1.d has replaced the narrative in the

current Proposed version.

COMMENT K:

Section 1.4

Design values for the entire Steubenville-Weirton, OH-WV nonattainment area should be

included in the SIP. There are two (2) additional monitors in Ohio's Jefferson County that

were not presented or acknowledged in West Virginia's SIP. PM-2.5 concentrations for these

two monitors are summarized in the following table from information provided by the OH

EPA. WV DEP is encouraged to verify this information and include it in their final SIP.

Jefferson County, OH PM-2.5 Values

Site ID#

ANNUAL 24-HOUR (98th %)

2006 2007 2008 AVG 2006 2007 2008 AVG

Steubenville 39-081-0017 13.78 16.19 14.28 14.8 32.9 43.5 35.2 37

Mingo Junction 39-081-1001 14.61 15.62 14.05 14.8 31.9 35.4 35.0 34

RESPONSE K:

DAQ has included the monitoring data for Jefferson County Ohio in our final SIP.

Weirton, WV PM2.5 SIP Response to Comments Page 7

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 59
COMMENT L:

Section 2.1

The figures included in this section indicate very high PM-2.5 concentrations at the end of

June and the beginning of July 2002. Did WV DEP flag any of its data due to the Quebec

fires that occurred during the summer of 2002?

RESPONSE L:

WVDEP did not flag its data due to the Quebec fires that occurred during the summer of

2002.

COMMENT M:

Section 2.4b and 2.4c

It would be useful to show 2002 and 2009 emission breakdowns for SO2 and NOx. Similar

analyses were shown for VOC and Ammonia in sections 2.4d and 2.4e.

RESPONSE M:

Tables showing the breakdowns for SO2 and NOx were added to Section 2.4.b and 2.4.c,

similar to the analyses for VOC and Ammonia in Sections 2.4.d and 2.4.e.

COMMENT N:

Section 7.1 and Appendix J

The data WV DEP used to in its Voronoi Neighbor Averaging (VNA) analysis does not

include any speciation data fkom the West Virginia Panhandle area. The nearest speciated

monitor to the Steubenville-Weirton nonattainment area used in this analysis appears to be

in western Pennsylvania (Florence, PA), which began collecting data in April of 2002 (PA

DEP Annual Ambient Air Quality Report, 2004). Our concern is West Virginia's estimation

method, though used in accordance with current EPA modeling guidelines, may "smooth

out" any peaks in the speciated data generated by local sources. Any "missed" local peaks

could cause an underestimation of West Virginia's projected PM-2.5 design concentrations.

WV DEP could examine speciation data collected at Ohio's Steubenville monitor

(39-081-0017) to determine if there are any local peaks that were not resolved in the

regional analysis.

RESPONSE N:

There were no speciation monitors in the area in 2002. The Steubenville speciation monitor

was not installed until 2004 and started generating data beginning 8-1-2004. West Virginia

Weirton, WV PM2.5 SIP Response to Comments Page 8

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 60
also installed a speciation monitor in Moundsville (54-051-1002) in Marshall County in the

Northern Panhandle in 2004, which began generating data 6-2-2004. Both of these

speciation monitors are special purpose monitors and are not part of the Speciated Trends

Network (STN). The only STN monitor in West Virginia is the Guthrie monitor

(54-039-0011) which was installed late in 2003 and began generating data 12-3-2003.

West Virginia, through ASIP and its contractors, followed current EPA guidelines for the

modeling. EPA Region III was invited to participate in the development of the modeling and

chose not to participate, and therefore, did not express any concerns during the development. 

The PM2.5 projections were made using EPA's Modeled Attainment Test Software (MATS)

that was developed by EPA specifically for states to use in making PM2.5 projections for their

SIPs. For the unmonitored area analysis, MATS was used to interpolate current year PM2.5

Design Values using the modeled gradients interpolation option in the VNA. The effects of

any local sources are accounted for in the MATS VNA interpolation through the modeled

gradients so that any local peaks are not "missed". 

In future modeling for the 2006 PM2.5 NAAQS West Virginia will examine the speciated

data from the Northern Panhandle area, including Steubenville. 

COMMENT O:

Section 7.2

Attainment test results for the 24-hour PM-2.5 standard should also be included in this

section. This information would be useful in gauging this region's possible attainment of

EPA' s revised (2006) PM-2.5 National Ambient Air Quality Standard (NAAQS).

West Virginia's projected 2009 design values are higher than the 2006-2008 design values;

a projected 2009 max design value of 14.2 μg/m3 vs. an actual 2006-2008 design value of

15.4 μg/m3. WV DEP may also want to compare projected quarterly values to actual

quarterly values. This apparent under prediction of annual PM-2.5 concentrations should

be discussed.

RESPONSE O:

As stated in Section 4.1 of the ASIP TSD (contained in Appendix N.2):

The current PM2.5 State Implementation Plans (SIPs) are addressing

the 1997 PM2.5 NAAQS that have thresholds of 15.0 μg/m3 annual

and 65 μg/m3

 24-hour PM2.5 concentrations. Currently all FRM

monitors in ASIP states attain the 65 μg/m3 24-hour PM2.5 NAAQS

so projections are only made for the annual PM2.5 NAAQS. Note that

in 2006 EPA revised the 24-hour PM2.5 NAAQS with a new threshold

Weirton, WV PM2.5 SIP Response to Comments Page 9

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 61
of 35 μg/m3

. The new 35 μg/m3 24-hour PM2.5 NAAQS will be

addressed in future PM2.5 SIP actions.

In addition, EPA has not yet updated the MATS tool to calculate the 24-hour PM2.5

concentrations. As EPA states on their Photochemical Modeling website, as of June 15,

2009, http://www.epa.gov/scram001/modelingapps_mats.htm: 

The 24-hour PM2.5 attainment test is not currently implemented. An

updated version (which includes the 24-hour PM2.5 attainment test)

is currently in beta testing and will be posted when available. Note

that default daily average PM2.5 ambient data sets are included in this

installer package even though the 24-hour PM2.5 attainment test is not

yet implemented. The PM2.5 files will be used in later versions. 

Furthermore, as EPA stated in Comment D, above, the 2006 NAAQS standard “is not

pertinent to this document.”

DAQ notes that the commenter is incorrect in stating that the projected 2009 values are

higher than the 2006-2008 design values. In fact, the projected 2009 design value (using the

ASIP projection tool) of 13.8 μg/m3

, is less than 2006-2008 design value of 15.4 μg/m3 at

the Follansbee monitor (54-009-0005); the projected 2009 design value (using the ASIP

projection tool) of 13.1 μg/m3, is less than 2006-2008 design value of 14.9 μg/m3 at the

Marland Heights monitor (54-009-0011); and the projected 2009 design value (using the

ASIP projection tool) of 14.2 μg/m3

, is less than 2006-2008 design value of 14.3 μg/m3 at

the Oak Street monitor (54-029-1004). So, it appears that the commenter meant to suggest

that the 2009 projected values are less than the 2006-08 design value, implying that this

indicates a model underprediction.

The DAQ notes that the single-year 2008 annual PM2.5 concentration at the Follansbee

monitor was 14.68 μg/m3, at the Marland Heights monitor it was 13.79 μg/m3 and at the Oak

Street monitor it was 13.33 μg/m3

. The annual values are more consistent with the projected

2009 design values of 13.8, 13.10 and 14.2 μg/m3

, respectively.

The projected 2009 design values are based on a constant 2002 meteorology while the 2006-

2008 design values are based on actual 2006, 2007 and 2008 meteorology, so one would not

expect the projected values to necessarily replicate the actual values. In addition, the 2009

projected values take into account emissions reductions which are expected to occur in 2009,

and which had not yet occurred in 2008. The model performance is extensively documented

in Appendix N and meets EPA’s guidelines for SIP submittals. 

Weirton, WV PM2.5 SIP Response to Comments Page 10

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 62
COMMENT P:

Section 7.3.b

PM-2.5 concentrations in the WV portion of the Steubenville-Weirton, OH-WV

nonattainment area do appear to be declining. To determine if these declines are statistically

significant, data from Appendix A was analyzed using the R statistical software packageversion 2.8.1 (http://www.r-project.org/).

R was used to analyze the annual PM-2.5 concentrations at the Follansbee (54-009-0005)

monitor located in Brooke County, WV. This monitor is the current design monitor in the

Steubenville-Weirton, OH-WV nonattainment area (highest annual design value). A "best

fit" line was calculated with R using a 95% confidence interval. The following figure shows

Follansbee's annual averages from 1999 through 2008 along with the "best fit" line, the

equation for the line and its R2

 value.

Statistical tests and the R2

 values indicate a slight downward trend in Follansbee's annual

PM-2.5 concentrations. This tend, however, appears to have only been recently established

and upon closer examination is isolated to certain periods of the year. Rerunning R without

2008 data removes any statistically significant trend in Follansbee's annual PM-2.5

concentrations. The next figure shows R-analysis results using annual concentrations from

1999 through 2007. Note the lower slope and R2

 values indicating less of a trend in the data.

Weirton, WV PM2.5 SIP Response to Comments Page 11

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 63
Trends in Follansbee's quarterly average PM-2.5 values, which are used to determine the

annual PM-2.5 values, show that downward trends are largely limited to the 2nd and 4th

quarters. There is a slight downward trend in the 1st quarter and no trend in the 3rd quarter.

The figure on the following page shows the results of the R analysis for Follansbee's

quarterly PM-2.5 concentrations. 

Follansbee's data seem to indicate that the overall downward trend is due to declines in its

2nd and 4th quarter PM-2.5 concentrations. Only a slight downward trend is noted in the 1st

quarter and absolutely no trend is observed during the 3rd quarter when PM-2.5

concentrations tend to be the highest. While not fully accounted for here, peak summertime

(3rd quarter) PM-2.5 concentrations tend to be driven by sulfates. Sulfates are primarily

formed from SO2 emissions from nearby coal-fired power plants along the Ohio River. The

lack of any trend in Follansbee's 3rd quarter PM-2.5 concentrations would seem to indicate

that any long-term SO2 reductions through the acid rain program alluded to in WV DEP's

SIP (if they are occurring at all) are not having much of an impact on local

PM-2.5-concentrations. Persistently high PM-2.5 concentrations during the 3rd quarter may

actually be offsetting reductions observed in the other quarters. Definitive downward trends

in the other quarters may be due to reductions from the mobile-source sector since at these

times of year monitors tend to be more affected by local emissions partially in response to

the higher frequency of terrain-induced temperature inversions.

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Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 64
Third quarter trends could be established in the future once sufficient SO2 reductions via the

U.S. EPA's CAIR program are actually achieved. Many flue-gas desulphurization (FGD)

installations are due to come on line within the next year or so. Definitive downward trends

in 3rd quarter PM-2.5 concentrations should have a significant impact on annual design

values since this quarter largely drives monitor annual averages.

Declining 3rd quarter concentrations should also have an impact on 24-hour PM-2.5 design

values since there would then be statistically significant declines throughout the year. Care

must be taken to show that emission declines are in response to the implementation of

emission control programs and not due to poor economic conditions.

Weirton, WV PM2.5 SIP Response to Comments Page 13

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R Statistical Summary of Follansbee, WV Monitor

R software (http://www.r-proiect.org/) was used to determine trends in the

Follansbee, WV monitor data and to analyze for statistical significance. Linear

trend lines were generated by R, including the “best fit” line, its R2 value and

associated equation (slope, β1 and intercept, β0). Standard t and P statistics were

then generated using a 95% confidence interval. The t and P statistics were used

to test the null hypothesis, H0. A statistical summary for the Follansbee monitor is

shown in the following table.

Follansbee R-Statistical Analysis Table

β1 β0 R2 t-Value P>*t*

Annual Average (99-08) -0.2404 498.2190 0.5197 -2.942 0.0187

Annual Average (99-07) -0.1765 370.2639 0.3475 -1.931 0.0948

1st Quarter (99-08) -0.2715 558.5286 0.4072 -2.344 0.0471

2nd Quarter (99-08) -0.4014 821.3818 0.6819 -4.141 0.0032

3rd Quarter (99-08) 0.09248 -165.0854 0.0191 0.395 0.7031

4th Quarter (99-08) -0.3809 777.3204 0.5598 -3.190 0.0128

t-value and P calculated for 95% confidence interval

For the null hypothesis (H0 or possibility of zero slope) to be false it is generally

accepted that t values for the 95% confidence interval will be outside of the

following interval, -2.0150 < t < 2.0150, and P values will be such that P < .05.

From the table above it is clear that the null hypothesis (H0) is probably false for

the full suite of Follansbee's annual concentrations (1999-2008) along with 2nd

quarter and 4th quarter PM-2.5 concentrations. Therefore there is a statistically

significant (downward) trend in these data. The null hypothesis (H0) can not be

ruled out for a smaller subset of the annual concentrations (1999-2007), the 3rd

quarter and possibly the 1st quarter, thus indicating there are no statistically

significant trends in these data.

Weirton, WV PM2.5 SIP Response to Comments Page 14

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RESPONSE P:

Commenter acknowledges that PM2.5 concentrations appear to be declining. Indeed, DAQ

notes significant reductions in the observed annual design values for the Weirton

nonattainment area, from 18.2 (1999) to 14.7 (2008) μg/m3. Commenter shows that this is

statistically significant for the period. Commenter then removes the year 2008 to yield a

trend that does not show statistical significance for the annual average (1999-2007). DAQ

considers the removal to be arbitrary and insufficiently justified. One consequence of the

adjustment is a substantial decrease in R2 values from 0.5197 to 0.3475 which considerably

compromises the "best-fit" reliability. In addition, WV continues to have concerns regarding

the very small number of observations used in the commenter's statistical analysis.

Moreover, the commenter applies further analysis to quarterly data. Since the attainment

demonstration is for an annual standard, WV believes that it is misguided for the commenter

to focus on a quarter-by-quarter statistical analysis. However, even if the analyses were

appropriate, the demonstrated reductions in design values for PM2.5 meet all regulatory

requirements. Further, EPA's Clean Data Policy has no component for a test of statistical

significance and our review of 40 CFR 51, Appendix W, does not reveal a specific statistical

procedure to apply in this situation. Notwithstanding the commenter's statistical analysis,

DAQ believes that air quality in the area has improved and that the agency has met

applicable requirements for demonstrating this.

COMMENT Q:

Section 8.9c and 8.9d

WV DEP is relying on the installation of FGD units on the Ft. Martin Power Station located

east of the Steubenville-Weirton, OH-WV nonattainment area as part of its contingency

measures. WV DEP contends that SO2 emission reductions from the Ft. Martin Power

Station will provide more than sufficient emission reductions to meet its contingency

requirements. The tables presented in the SIP should account for any projected increases

in emissions within the area of influence established by WV DEP. The proposed Longview

Power Plant (Longview) being constructed near Maidsville, WV is within the Weirton area

of influence. Projected emissions from this new facility are ~1739 tpy NOx, ~2417 tpy SO2

and ~482 tpy of PM. Longview is scheduled to begin operations sometime after 20 10.

RESPONSE Q:

As commenter notes, Longview will not startup until after 2010. It is scheduled to come on

line around 2011. The requirement for contingency measures addresses the reductions to be

implemented if the area fails to attain the standard by April 2010. Therefore, Longview’s

planned startup occurs after the required emission reductions must be available and need not

be considered as offsets. Nevertheless, the referenced scrubbers at Ft. Martin are scheduled

to come online by 2010, providing the projected 36,820 ton reduction in SO2 emissions. As

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demonstrated in Section 8.9 of the SIP Narrative, this yields 35,815 tons of excess reductions

still available to be used as contingency measures. Hence, applying the equivalency ratios

used in the narrative, the emissions increases at Longview would be more than offset by this

excess, leaving 30,984 tons of SO2 still available for contingencies.

In addition, the emissions identified by the commenter are the maximum allowable

emissions, not projected actual emissions. It is expected that generation from Longview will

replace generation at other EGUs or offset projected increases in generation at other EGUs.

Longview, being a new facility, will have less emissions per unit of generation than other

older EGUs.

Furthermore, VISTAS conducted modeling for 2009, 2012 and 2018. IPM was used to

project EGU generation and emissions. IPM accounts for increases in demand in electricity

and projects installation of new EGUs. All projected new generation in West Virginia was

assigned to the Longview facility and was accounted for the modeling for 2012 and 2018.

These results are presented in Table 7.4 of the SIP Narrative and demonstrate that the

Weirton area will continue to attain the standard in 2012 and 2018.

COMMENT R:

Comment on SIP Appendices

The appendices used in the WV DEP's Weirton, WV SIP appear to be similar to those it used

in its Huntington, WV SIP. EPA has provided comments regarding some of these appendices

for Huntington. Will any changes to these appendices in response to our comments also be

made for the Weirton, WV SIP? Does WV DEP intend to have identical appendices for all

of its PM-2.5 SIPS?

RESPONSE R:

The following appendices are specific to each area: Appendices L, M, P and Q – 

Contingency Measures, RACT, Transportation Conformity and Public Participation,

respectively. The remaining Appendices were the same for the Huntington and Parkersburg

SIPs, as proposed. However, changes have been made to the Appendices in response to

comments on the Huntington SIP, and these changes have been carried through to the

Weirton SIP, and will be carried through to the Charleston SIP when it is proposed. 

Weirton, WV PM2.5 SIP Response to Comments Page 16

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 68
Attachment 1

Email from EPA regarding

Contingency Measures

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 69
[This page intentionally left blank.]

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 70
<McKinley.Gobeail@epamail.epa.gov> - Re: Contingency Measures Page 1 of 3

file://C:\Documents and Settings\L_Crowd\Local Settings\Temp\_agv0004\Re_ Contingency Meas... 4/7/2009

From: <McKinley.Gobeail@epamail.epa.gov>

To: Crowder, Laura

CC: Fernandez.Cristina@epamail.epa.gov; Kremer.Janet@epamail.epa.gov; 

Lohman.Denny@epamail.epa.gov; Powers.Marilyn@epamail.epa.gov; 

Root.Kathleen@epamail.epa.gov; Durham, Fred

Date: 5/19/2008 9:48:30 AM

Subject: Re: Contingency Measures

Hi Laura, 

There are some questions and comments on the draft contingency measures: 

1) "Contingency measures must be fully adopted rules or control measures that are ready to be 

implemented quickly upon failure to meet RFP or failure of the area to meet the standard by its 

attainment date." (72 FR 20643) 

Assuming that the contingency measures are additional measures that are not relied on for 

attainment, how and when will these contingency measures be implemented? When is the 

Cabot Plant going scheduled to be shutdown (or was it shutdown some time ago)? When is the 

replacement of coal-fired boilers with gas fired boilers scheduled at Cytec? 

2) Janet Kremer looked at the NOx, PM2.5, and SO2 numbers that WV submitted to the 2002 

CERR for Cabot. The only difference she found was in the PM2.5 numbers reported then versus 

what is being claimed in the draft contingency measures write up. 

2002 NEI PM2.5 Filterable says 29 tpy 

2002 NEI PM2.5 Primary (Fil + Con) says 32 tpy 

WV draft contingency measures document says 81 tpy 

Please confirm that 81 tpy is correct. 

3) The way in which the contingency measures are calculated is not clear. Why the 1.3 

substitution? Please refer to the way that DC calculated their contingency measures (specify 

Appendix J). 

Gobeail McKinley 

Air Quality Planning Branch 

Air Protection Division (3AP21) 

US EPA- Region III 

1650 Arch St. 

Philadelphia, PA 19103-2029 

mckinley.gobeail@epa.gov 

(215)814-2033 

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 71
Gobeail, 

 

I previously sent, for your review, a draft write-up of the Contingency Measures that I plan to 

include in the Parkersburg PM2.5 SIP. (see attached email) 

 

We are getting ready to go to public notice, so I would like any comments that you have on the 

Contingency Measures by next Wednesday, May 7th. 

 

Thank you. 

 

Laura 

 

Laura Mae Crowder 

Division of Air Quality 

phone: (304) 926-0499 ext. 1247 

fax: (304) 926-0478 

email: lcrowder@wvdep.org

----- Message from "Laura Crowder" <LCROWDER@wvdep.org> on Wed, 16 Apr 2008 15:36:55 -0400 --

---

Gobeail, 

 

Attached, for your review, is the write-up for Contingency Measures that I plan to include in the 

Parkersburg SIP. 

 

Please let me know if you have any comments. 

 

Thank you. 

 

Laura 

 

Laura Mae Crowder 

"Laura Crowder" <LCROWDER@wvdep.org>

05/02/2008 01:24 PM 

To Gobeail McKinley/R3/USEPA/US@EPA

cc Marilyn Powers/R3/USEPA/US@EPA, "Fred Durham" 

<FDURHAM@wvdep.org>

Subject Fwd: Contingency Measures

To: <mckinley.gobeail@epa.gov> 

Subject: Contingency Measures

<McKinley.Gobeail@epamail.epa.gov> - Re: Contingency Measures Page 2 of 3

file://C:\Documents and Settings\L_Crowd\Local Settings\Temp\_agv0004\Re_ Contingency Meas... 4/7/2009

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 72
Division of Air Quality 

phone: (304) 926-0499 ext. 1247 

fax: (304) 926-0478 

email: lcrowder@wvdep.org 

Attachments: Contingency Measures.pdf, Contingency Measures.wpd

<McKinley.Gobeail@epamail.epa.gov> - Re: Contingency Measures Page 3 of 3

file://C:\Documents and Settings\L_Crowd\Local Settings\Temp\_agv0004\Re_ Contingency Meas... 4/7/2009

Weirton, WV 1997 PM2.5 SIP Appendix Q Page - 73