west virginiadepartment of environmental protection



# Appendix Q Public Participation Documentation

Promoting a healthy environment.[This page intentionally left blank.]

### 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[This page intentionally left blank.]

# Public Notice[This page intentionally left blank.]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) PM 2.5 nonattainment area, comprising Brooke and Hancock Counties, will meet the annual PM 2.5 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 PM 2.5annual 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 (PM 2.5) 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 57 thStreet, 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 57 thSE, 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[This page intentionally left blank.]

# Transmittal Letters[This page intentionally left blank.]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.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,-- -- -- - -- - 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.

### 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

# Legal Ads[This page intentionally left blank.]

# 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 of the 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 DatesINDEX 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

## FIL.EL.

NOTICE OF PUBLIC HEARING ANDPUBLIC COMMENT**PJt~R** \6 PM 2: 46
The**~est** Virginia**Dep~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 quality stIlrtd'lll"d§ (NAAQS) for fine particulate 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 annual PM1.s standard bythe mandatory date of April 20I O. Further,DEPshowsthat the expectedair quality improvement willbe achievedthrough federally enforceable emissionreduction measures. The area was designated as nonattainment withthe 1997PM u annualNAAQSin the January5, 2005 Federal Register[70FR 944], effectiveAprilS, 2005. Once finalized, theAttainment Demonstration for theAnnual National AmbientAir Quality StandardforFine Particulate Maller (pMl,,) State Implementation Planfor the Weirton. West Virginia Nonattainment Area, Comprising Brooke andHancockCounties will be submitted to U.S. EPAfor approval and incorporation as a revisionto the State Implementation 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 with Disabilities EducetlonAct,for publiccomment, The grent appllcetion Is requiredbythe U.S. Departmentof Education, 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 from March 14, 2009 through May14, 2009. Persons wantingto submitwrittencomments on the state's appllcstlon for FY2009 funds under Part C of IDEA, 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 acceptedfor inclusion in the formalrecordby mail, facsimile (304-926-0479), e-mail ITammy.L.Mowrer@wv,goy) or otherdeliveryto the Division of Air QualityIfreceived bythe close of businesson April21, 2009.Transmitwritten comments to JohnA. Benedict, Directorof the Divisionof Air Qualityat the following address: WV Department of Environmental Protection Division of AirQuality 601 57 th Street,SE Charleston, WV25304 The public hearing shall be held beginning at 6:00 p.m, on April 21, 2009at the following location: WV Department of Environmental Protection Conference Room(room 122) 131-A Peninsula Street Wheeling, WestVirginia26003 . Copiesof the proposed SIP revisionmay be viewedon weekdays between8:30a.m. and4:30 p.m.at the DEP Wheeling office locatedat the above address. 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 ..... = enQ = 

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# Public Hearing Transcript[This page intentionally left blank.]

### 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 Plan 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 

### Director 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

### PROCEEDINGS 

### MR. 

### ENGLISH: This public hearing 

### will now
come to order this 21st day of April, 2009, at the West Vi rgini a Department of Envi ronmental Protection, DEP, 

### Regional Office located at 131-A Peni nsula Street, Wheel 

### i ng 

## , West Vi rgini 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

### 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 

### 11e (Ohio and West Vi rgini 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 Imp1ementation Plan for the Wei rton, West Vi rginia, Nonattainment 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 Plan (SIP)


# .

### 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. 

## ***

### 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 ssion expi res : 

### 7/17/2012

### 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, 131-A121 - 1114, 215 

# 1

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] 

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### 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] 

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### 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 achieved[i] - 3:12 - DEP 141 - 215, 2:21, 316, Act111 - 2.15 

## I 3:11 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,

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2:16 2:4, 2:17 designated [I] - 3:14 Director[2]-1:19,2:17 2115, 2:18, 2121, 3118

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### - 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 Larry[i]- 2:16 PM2.5) [I] - 315 

# '1

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] - 3:4State [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[This page intentionally left blank.]

# Public Comments[This page intentionally left blank.]

# EPA Comments[This page intentionally left blank.],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. Customer Service Hotline: 1-800-438-2474[This page intentionally left blank.]

### 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) explicitlyrefers 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 PM25 

### 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

### 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 

### CARwas 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

### 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 PM25 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".[This page intentionally left blank.]

### 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).

Page 1 of 6Enclosure (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

Page 2 of 

### 6Enclosure (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 

### 3rdquarter when 

### PM-2.5 concentrations tend to be the highest. While not fully accounted for here, peak
Page 

### 3 of 

### 6Enclosure (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 SO2reductions 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 CARprogram are actually achieved. Many flue-gas desulphurization 

### (FGD) installations are due to come on line withthe next year or so. Definitive downward trends in 3rdquarter PM-2.5 concentrations should have a significant impact on annual design values since this quarter largely drives monitor annual averages.

Page 4 of 6Enclosure (2) Steubenville-Weirton, OH-WV Annual PM-2.5 SIP Comments from EPA Region 3 Air-Quality Analysis Branch April 2009 Declining 3rdquarter 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 (1999-2008) along with 2"d quarter and 4thquarter 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.

Page 5 of 6Enclosure (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 SO2emission 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?

Page 

### 6 of 

### 6

# Response to Comments[This page intentionally left blank.]

### 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 PM 2.5national ambient air quality standard, not just the annual standard. The nonattainment designations were made for PM 2.5and did not specify only the annual standard. The PM 2.5Implementation 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 PM 2.5NAAQS, 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 withthe 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 PM 2.5modeling guidance.

Weirton, WV PM 2.5SIP Response to Comments Page 1Also, references to the nonattainment area should be consistent throughout the document. For example, Section 1.0 refers to the “Th e 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 (PM 2.5

) State Implementation Plan for West VirginiaPortion 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 PM 2.5nonattainment 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 PM 2.5 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 weremade 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 fromthe 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 PM 2.5SIP Response to Comments Page 2COMMENT 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 PM 2.5NAAQS have been met; and that the Steubenville-Weirton OH-WV nonattainment area will attain compliance with the 1997 PM 2.5NAAQS 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 PM 2.5occurs when the annual 98th percentile concentration averaged over three years is greater than 35 μg/m 3.” This discussion is not pertinent to this document; it is suggested that it be removed or revised to refer to the daily 1997 PM 2.5standard.
RESPONSE D: The language has been revised to refer to the daily 1997 PM 2.5standard of 65 μg/m3

. COMMENT E: The third paragraph of Section 8.7 states: “Th e 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 ofSection 110(a)(2)(G), therefore the language in Section 8.7 of the attainment plan should be revised.

Weirton, WV PM 2.5SIP Response to Comments Page 3RESPONSE 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 elementsspecified 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 mustbe 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 NO xcontrols 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 re gulations 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.:

Weirton, WV PM 2.5SIP Response to Comments Page 4For each PM 2.5nonattainment 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 todemonstrate 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 t hat 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. MartinPower 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 SO 2reduction requirements of the CAIR. The CAIR SO 2reduction requirements begin in 2010, although the annual CAIR NOxreduction requirements began in 2009. However, since the CAIR program is a cap and trade program, with credits earned for early reductions, some CAIR SO 2controls 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 PM 2.5SIP Response to Comments Page 5online until 2010. Since the attainment date for the PM2.5NAAQS 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 (PM 2.5

)" sets forth preferred interpollutant trading ratios that may be used for PM 2.5offsets (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 PM 2.5ambient 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 PM 2.5SIP, 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."

Weirton, WV PM 2.5SIP Response to Comments Page 6Also, 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 PM 2.5SIP Response to Comments Page 7COMMENT L:
Section 2.1 The figures included in this section indicatevery 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 toshow 2002 and 2009 emission breakdowns for SO2 and NO x. Similar analyses were shown for VOC and Ammonia in sections 2.4d and 2.4e.
RESPONSE M: Tables showing the breakdowns for SO 2and NOxwere 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 A veraging (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), wh ich 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 Virgin ia'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 PM 2.5SIP Response to Comments Page 8also 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 PM 2.5projections were made using EPA's Modeled Attainment Test Software (MATS) that was developed by EPA specificallyfor states to use in making PM 2.5projections for their SIPs. For the unmonitored area analysis, MATSwas used to interpolate current year PM 2.5 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 PM2.5NAAQS 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/m 3vs. an actual 2006-2008 design value of 15.4 μg/m 3. 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 PM 2.5State Implementation Plans (SIPs) are addressing the 1997 PM 2.5NAAQS that have thresholds of 15.0 μg/m3annual and 65 μg/m324-hour PM 2.5concentrations. Currently all FRM monitors in ASIP states attain the 65 μg/m324-hour PM 2.5NAAQS so projections are only made for the annual PM2.5NAAQS. Note that in 2006 EPA revised the 24-hour PM 2.5NAAQS with a new threshold

Weirton, WV PM 2.5SIP Response to Comments Page 9of 35 μg/m3 . The new 35 μg/m324-hour PM 2.5NAAQS will be addressed in future PM 2.5SIP 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 PM 2.5attainment test is not currently implemented. An updated version (which includes the 24-hour PM 2.5attainment test) is currently in beta testing and will be posted when available. Note that default daily average PM 2.5ambient data sets are included in this installer package even though the 24-hour PM2.5attainment test is not yet implemented. The PM2.5files 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/m3at 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/m3at 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/m3at the Oak Street monitor (54-029-1004). So, it appears that the commenter meant to suggest that the 2009 projected values are lessthan the 2006-08 design value, implying that this indicates a model underprediction. The DAQ notes that the single-year 2008 annual PM 2.5concentration at the Follansbee monitor was 14.68 μg/m3 , at the Marland Heights monitor it was 13.79 μg/m3and 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 PM 2.5SIP Response to Comments Page 10COMMENT 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. Todetermine if these declines are statisticallysignificant, 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 R2value.

Statistical tests and the R2values 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 R2values indicating less of a trend in the data.

Weirton, WV PM 2.5SIP Response to Comments Page 11Trends 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 1 st quarter and no trend in the 3r d 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 4thquarter PM-2.5 concentrations. Only a slight downward trend is noted in the 1 st quarter and absolutely no trend is observed during the 3 rd quarter when PM-2.5 concentrations tend to be the highest. While not fully accounted for here, peak summertime (3 rd quarter) PM-2.5 concentrations tend to be driven by sulfates. Sulfates are primarily formed from SO2emissions from nearby coal-fired power plants along the Ohio River. The lack of any trend in Follansbee's 3 rd quarter PM-2.5 concentrations would seem to indicate that any long-term SO2reductions 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 inthe 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.

Weirton, WV PM 2.5SIP Response to Comments Page 12Third quarter trends could be established in the future once sufficient SO2reductions 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 3 rd quarter concentrations should alsohave 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 PM 2.5SIP Response to Comments Page 13R 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 R2value and associated equation (slope, β1and 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, H 0. A statistical summary for the Follansbee monitor is shown in the following table. Follansbee R-Statistical Analysis Table β

1 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 1 st 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 3 rd Quarter (99-08) 0.09248 -165.0854 0.0191 0.395 0.7031 4thQuarter (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 (H 0or 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 (H 0 ) is probably false for the full suite of Follansbee's annual concentrations (1999-2008) along with 2 nd quarter and 4thquarter PM-2.5 concentrations. Therefore there is a statistically significant (downward) trend in these data. The null hypothesis (H 0 ) can not be ruled out for a smaller subset of the annual concentrations (1999-2007), the 3 rd quarter and possibly the 1 st quarter, thus indicating there are no statistically significant trends in these data.

Weirton, WV PM 2.5SIP Response to Comments Page 14RESPONSE P: Commenter acknowledges that PM2.5concentrations 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 R2values 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 PM 2.5meet 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 SO2emission reductions from the Ft. Martin Power Station will provide more than sufficient em ission reductions to meet its contingency requirements. The tables presented in the SIP should account for any projected increases in emissions within the areaof 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 x , ~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 SO 2emissions. As

Weirton, WV PM 2.5SIP Response to Comments Page 15demonstrated 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 SO 2still available for contingencies. In addition, the emissions identified by the commenter are the maximum allowable emissions, not projected actual emissions. It isexpected that generation from Longview will replace generation at other EGUs or offset proj ected 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 PM 2.5SIP Response to Comments Page 16

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... 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 commentson 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 measuresare 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)814-2033Gobeail, 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, soI 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 --

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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

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