Environmental 

Protection Agency 

John r~. \\s-sichF Governor 

l\lle~~·v Lt. Governor 

Director 

MAY 2 5 Z012 

Ms. Susan Hedman 

Regional Administrator 

U.S. EPA Region 5 

77 W. Jackson Blvd. 

Chicago, IL 60604 

Re: Redesignation Request for the 24-Hour PM2.s Standard for the SteubenvilleWeirton Area 

Dear Administrator Hedman: 

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

Steubenville-Weirton, WV-OH area (Jefferson County, Ohio) with respect to the 2006 

24-Hour PM2.5 standard. The enclosed submittal combines the redesignation request 

and the required maintenance plan for this area. 

Monitoring of existing air quality indicates that the 2006 National Ambient Air Quality 

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

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

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

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

constitute the attainment and maintenance plan for the Steubenville-Weirton area. 

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

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

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

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

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

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

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

Clean Air Interstate Rule (CAIR). 

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

April 11, 2012. This notice was also published in a newspaper of general circulation in 

Steubenville, Ohio. The public hearing for this package was held on May 16, 2012 in 

50 West Town street. Su~e 700 

P.O. Box 1049 

Columbus. OH 43216-1049 

614 1 644 3020 

614 1644 3184 (fax) 

www.epa.ohio.gov 
Steubenville, Ohio. No testimony was provided at the hearing. Ohio EPA did receive 

one written comment from the Ohio Utility Group in support of this request. 

If you have questions, please contact Jennifer Dines in our Division of Air Pollution 

Control at (614) 644-3696. 

Sincerely, 

CJ, 

Director 

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

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 i 

TABLE OF CONTENTS 

Chapter One 

Introduction ................................................................................................................................... 1 

Geographical description and background ................................................................................... 2 

Status of air quality ....................................................................................................................... 3 

Chapter Two 

Requirements for redesignation .................................................................................................... 4 

Chapter Three 

PM2.5 monitoring .......................................................................................................................... 10 

24-Hour PM2.5 NAAQS ................................................................................................................ 10 

Ambient data quality assured ...................................................................................................... 11 

Three complete years of data ..................................................................................................... 11 

Commitment to continue monitoring ........................................................................................... 17 

Chapter Four 

Emission inventory ...................................................................................................................... 18 

Base year inventory .................................................................................................................... 18 

Emission projections ................................................................................................................... 19 

Demonstration of maintenance ................................................................................................... 27 

Permanent and enforceable emissions reductions ..................................................................... 37 

Provisions for future update ........................................................................................................ 38 

Chapter Five 

Control measures and regulations .............................................................................................. 39 

Nonattainment areas to implement RACM and RACT ................................................................ 39 

Show Reasonable Further Progress (RFP) ................................................................................ 41 

Emission inventories ................................................................................................................... 41 

Implementation of past SIP revisions .......................................................................................... 42 

New source review provisions ................................................................................................... 44 

Assurance of continued controls ................................................................................................. 45 

Chapter Six 

Contingency measures ............................................................................................................... 46 

Commitment to revise plan ......................................................................................................... 46 

Commitment for contingency measures ..................................................................................... 47 

Potential contingency measures ................................................................................................. 47 

List of PM2.5, SO2, and NOx sources ........................................................................................... 48 

Chapter Seven 

Public participation ...................................................................................................................... 49 

Chapter Eight 

Conclusions ................................................................................................................................ 50 
 ii 

FIGURES 

Figure 1 Steubenville- Weirton 24-Hour PM 2.5 Exceedances......................................9 

Figure 2 Map of the Steubenville-Weirton, OH-WV, nonattainment area and monitor 

locations .............................................................................................................. 11 

Figure 3 Ohio 24-Hour PM 2.5: Design Values 1999-2001 Through 2008-2010 ................ 15 

Figure 4 West Virginia 24-Hour PM 2.5 Design Values 1999-2001 Through 2008-2010 .... 16 

Figure 5 PM 2.5 24- Hour Mean National Trends ................................................................ 16 

TABLES

Table 1 Monitoring Data for Steubenville-Weirton, OH-WV area for 2008 – 2010 ........... 13 

Table 2 98th Percentile and Design Value Before and After Imputation .......................... 14 

Table 3 Jefferson County, Ohio Emission Estimations for On-road Mobile Sources ....... 25 

Table 4 Summary of Ohio Emissions Estimations for On-road Mobile Sources .............. 25 

Table 5 Brooke County, West Virginia Emission Estimations for On-road Mobile 

 Sources ............................................................................................................... 25 

Table 6 Hancock County, West Virginia Emission Estimations for On-road Mobile 

Sources ............................................................................................................... 25 

Table 7 Summary of West Virginia Emission Estimations for On-Road Mobile Sources . 26 

Table 8 Emission Estimations Totals for On-road Mobile Sources for the SteubenvilleWeirton Area ....................................................................................................... 26 

Table 9 Percent of Mobile Emissions for the Steubenville-Weirton Area in 2015 

 and 2025 .... ........................................................................................................ 26 

Table 10 Reductions in SO2 and NOx EGU Emissions Between 2008 and 2009. ............. 29 

Table 11 Reductions in SO2 and NOx EGU Emissions Between the First Half of 2008 

 and 2010.... ......................................................................................................... 30 

Table 12 Jefferson County, Ohio PM2.5 Emission Inventory Totals for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2025 (tpy) – Without CAIR. ............... 32 

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

2005, Estimated 2008, and Projected 2015 and 2025 (tpy) – With CSAPR. ....... 32 

Table 14 Hancock County, West Virginia PM2.5 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2025 (tpy) – With CSAPR. ....... 32 

Table 15 Steubenville-Weirton Area PM2.5 Emission Inventory Totals for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2025 (tpy) – Without CAIR (Ohio) and 

With CSAPR (West Virginia). .............................................................................. 33 

Table 16 Jefferson County, Ohio NOx Emission Inventory Totals for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2025 (tpy) – With CAIR ..................... 33 

Table 17 Brooke County, West Virginia NOx Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2025 (tpy) – With CSAPR ........ 33 

Table 18 Hancock County, West Virginia NOx Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2025 (tpy) – With CSAPR. ....... 34 

Table 19 Steubenville-Weirton Area NOx Emission Inventory Totals for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2025 (tpy) – With CAIR (Ohio) and With 

CSAPR (West Virginia). ...................................................................................... 34 

Table 20 Jefferson County, Ohio SO2 Emission Inventory Totals for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2025 (tpy) – With CAIR ..................... 34 
 iii 

Table 21 Brooke County, West Virginia SO2 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2025 (tpy) – With CSAPR ........ 35 

Table 22 Hancock County, West Virginia SO2 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2025 (tpy) – With CSAPR ........ 35 

Table 23 Steubenville-Weirton Area SO2 Emission Inventory Totals for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2025 (tpy) – With CAIR (Ohio) and With 

CSAPR (West Virginia) ....................................................................................... 35 

Table 24 Steubenville-Weirton Area Comparison of 2008 attainment year and 2015 and 

2025 Projected Emission Estimates (tpy) ............................................................ 36 

Table 25 Steubenville-Weirton Area Combined Comparison of 2005 Base Year and 2008 

Attainment Year On-Road and EGU Reductions ................................................ 38 

APPENDICES 

A Air Quality System (AQS) Data 

B Ohio 2005 SIP Base Year Inventory Discussion 

C Mobile Source Emissions Inventory for the Steubenville-Weirton PM2.5 Nonattainment 

Area

D LADCO Technical Support Document and WVDAQ Nonroad Modeling 

E Incomplete Monitoring Data Substitution Analysis 

F Public Participation Documentation
 iv 

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REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE OHIO 

PORTION OF THE STEUBENVILLE-WEIRTON OH-WV 

24-HOUR PM2.5 NONATTAINMENT AREA 

Jefferson County, Ohio 

CHAPTER ONE 

Introduction 

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

to meet the 24-hour PM2.5

1

 National Ambient Air Quality Standard (NAAQS) to 

develop State Implementation Plans (SIPs) to expeditiously attain and 

maintain the standard. The United States Environmental Protection Agency 

(U.S. EPA) revised the NAAQS for particulate matter in 2006. In 2006, U.S. 

EPA strengthened the primary 24-hour PM2.5 NAAQS from 65 μg/m3 to 35 

μg/m3, and retained the current primary annual PM2.5 NAAQS at 15.0 μg/m3. 

The revised 24-hour PM2.5 standard was published on October 17, 2006 (71 

FR 61144) and became effective on December 18, 2006. The standard is 

based on the 3-year average of the 98th percentile of 24-hour concentrations. 

 

On November 13, 2009, U.S. EPA promulgated (74 FR 58688) the initial 

PM2.5 nonattainment areas designations for the 24-hour PM2.5 standard 

across the country (effective December 14, 2009). Unlike Subpart 2 of the 

CAA Amendments of 1990 which defined five ozone nonattainment 

classifications for the areas that exceed the NAAQS based on the severity of 

the ozone levels, PM2.5 nonattainment designations are simply labeled 

“nonattainment.” The CAA Amendments require states with PM2.5

nonattainment areas to submit a plan within three years of the effective date 

of the designations (December 14, 2012) detailing how the PM2.5 standard will 

be attained by December 14, 2014. However, areas that attain before the 

required date for submitting a plan may be exempt from certain otherwise 

applicable requirements. 

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

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

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

 

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

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

nitrates and sulfates), organic chemicals, metals, soil or dust particles, and allergens (such as 

fragments of pollen or mold spores). 

Fine particle pollution or PM2.5 describes particulate matter that is 2.5 micrometers in diameter and 

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

secondarily in the atmosphere. 
 2 

redesignated from nonattainment to attainment: 

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

standard.

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

under Section 110(k).

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

permanent and enforceable reductions in emissions resulting 

from implementation of the SIP and other federal 

requirements.

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

• A determination that all Section 110 and Part D requirements 

have been met. 

This document addresses each of these requirements, and provides 

additional information to support continued compliance with the 24-hour PM2.5

standard. 

On October 4, 2011, U.S. EPA proposed (76 FR 61291) to determine that the 

Steubenville-Weirton nonattainment area has clean data for the 24-hour PM2.5 

standard2. The proposed determination is based upon quality assured, quality 

controlled, and certified ambient air monitoring data showing the area has 

monitored attainment based on 2008 through 2010 data. 

 The Steubenville-Weirton area has previously been subject to nonattainment 

area rulemakings for the 1997 fine particle NAAQS. Ohio was only subject to 

requirements to address the annual standard under the 1997 fine particle 

NAAQS as there were no monitors in Ohio that violated the 1997 24-hour 

PM2.5 standard of 65 μg/m3. In April, 2012, Ohio EPA submitted a 

redesignation request and maintenance plan for the Steubenville-Weirton 

1997 annual standard nonattainment area. 

Geographical Description and Background 

The current Steubenville-Weirton nonattainment area is located on the 

eastern border of Ohio and includes the following counties: Jefferson in Ohio 

and Hancock and Brooke in West Virginia. This area is shown in Figure 2 

under Chapter Three. 

As a result of the 2009 PM2.5 designations, U.S. EPA designated the 

Steubenville-Weirton area nonattainment for the 35 μg/m3 24-hour standard, 

and Ohio EPA is required to develop a plan to reduce oxides of nitrogen 

(NOx), sulfur dioxide (SO2) and direct PM2.5 emissions and to demonstrate 

that the area will meet the federal 24-hour air quality standard by December 

 

2 This proposal was based on a February 14, 2011 request submitted by the West Virginia 

Division of Air Quality. 
 3 

14, 2014. Ohio’s main PM2.5 components are primary particles (organic 

carbon, crustal material, and elemental carbon), SO2 and NOx, which were 

included in the attainment demonstration analysis for the 1997 annual PM2.5 

NAAQS submitted to U.S. EPA on July 16, 2008. Volatile organic compounds 

(VOCs) and ammonia (NH3) were not included in the analysis since they 

were not part of Ohio’s attainment strategy for PM2.5 (although controls for 

VOCs have been implemented for ozone nonattainment). This is consistent 

with U.S. EPA’s “Clean Air Particle Implementation Rule” [74 FR 20856] 

(hereafter referred to as “1997 Implementation Rule”). In the 1997 

Implementation Rule U.S. EPA presumes NH3 emissions are not a PM2.5

attainment plan precursor and that States are not required to address VOC 

unless the State or U.S. EPA makes a technical demonstration that emissions 

of VOCs significantly contribute to nonattainment of the PM2.5 standard. This 

is also consistent with U.S. EPA’s “Implementation Guidance for the 2006 24-

Hour Fine Particle (PM2.5) National Ambient Air Quality Standards (NAAQS)” 

memorandum issued on March 2, 2012 (hereafter referred to as “2006 

Implementation Memo”). In this memorandum, U.S. EPA recommends that 

“the projected attainment inventory for the nonattainment area includes direct 

PM2.5, SO2, presumptively NOx, as well as other precursors that have been 

determined to be significant through the area’s SIP development process.” 

Furthermore, the 2006 Implementation Memo indicates that U.S. EPA 

believes the overall framework and policy approach of the 1997 

Implementation Rule “continues to provide effective and appropriate guidance 

on the EPA’s interpretation of the general statutory requirements that states 

should address in their SIPs” and that they are “relevant to the statutory 

requirements” for the 2006 24-hour PM2.5 standard. 

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

the Steubenville-Weirton area be redesignated from nonattainment to 

attainment for the 24-hour PM2.5 standard. In addition, the State of West 

Virginia may also submit a request for their respective portions of the 

Steubenville-Weirton area. 

Status of Air Quality 

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

three (3) years, 2008 through 2010, demonstrate that the air quality has met 

the NAAQS for 24-hour PM2.5 in this nonattainment area. The NAAQS 

attainment, accompanied by decreases in emission levels discussed in 

Chapter Four, supports a redesignation to attainment for the SteubenvilleWeirton area based on the requirements in Section 107(d)(3)(E) of the CAA 

as amended. 
 4 

CHAPTER TWO 

Requirements for Redesignation 

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

for Processing Requests to Redesignate Areas to Attainment (redesignation 

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

redesignation request and maintenance plan are based on the redesignation 

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

EPA Region 5. 

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

Steubenville-Weirton area. 

i.) Attainment of the standard (CAA Section 107(d)(3)(E)(i)) 

 There are two components involved in making this 

demonstration. The first component relies on ambient air quality 

data. The data that are used to demonstrate attainment should 

be the product of ambient monitoring that is representative of 

the area of highest concentration. The data should be collected 

and quality-assured in accordance with 40 CFR 58 and 

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

available to the public for review. 

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

redesignating nonattainment areas, the redesignation guidance 

states it is “generally necessary” for particulate matter 

redesignations. Appendix C and Appendix D contains the most 

recent modeling results showing future attainment and 

maintenance are provided. Chapter Three discusses this 

requirement in more detail and provides the attainment 

demonstration. 

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

107(d)(3)(E)(iii)) 

 The state must be able to reasonably attribute the improvement 

in air quality to emission reductions which are permanent and 

enforceable. The state should estimate the percent reduction 

achieved from federal measures as well as control measures 

that have been adopted and implemented by the state. 

It was not necessary for Ohio to adopt or implement control 

measures for these counties beyond the federal measures. 

Ohio EPA has adopted several rules recently that will have an 

impact on statewide PM2.5 emissions in the future: 
 5 

• Clean Air Interstate Rule (CAIR) 

• NOx SIP Call Rules 

 Ohio was also subject to a Federal Implementation Plan under 

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

(CSAPR) that could have resulted in even greater reductions 

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

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

continue administering CAIR pending the court’s resolution. 

 In addition, since the initial designations were made federally 

enforceable consent decrees have resulted in reductions in 

emissions from utilities within Jefferson County and across the 

state, including this area. 

 Chapters Four and Five discuss this requirement in more detail. 

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

 For purposes of redesignation, a state must meet all 

requirements of Section 110 and Part D that were applicable 

prior to submittal of the complete redesignation request. 

 Subpart 1 of Part D consists of general requirements applicable 

to all areas which are designated nonattainment based on a 

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

specific requirements applicable to particulate matter 

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

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

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

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

20589] 

 Section 110(a) requirements 

Section 110(a) of Title I of the CAA contains the general 

requirements for a SIP. Section 110(a)(2) provides that 

the implementation plan submitted by a state must have 

been adopted by the state after reasonable public notice 

and hearing, and that, among other things, it must 

include enforceable emission limitations and other control 

measures, means or techniques necessary to meet the 

requirements of the CAA; provide for establishment and 

operation of appropriate devices, methods, systems and 

procedures necessary to monitor ambient air quality; 

provide for implementation of a source permit program to 

regulate the modification and construction of any 
 6 

stationary source within the areas covered by the plan; 

include provisions for the implementation of Part C, 

prevention of significant deterioration (PSD) and Part D, 

NSR permit programs; include criteria for stationary 

source emission control measures, monitoring, and 

reporting; include provisions for air quality modeling; and 

provide for public and local agency participation in 

planning and emission control rule development. In 

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

infrastructure SIP submissions, Ohio verified that the 

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

Act. 

Section 110(a)(2)(D) also requires State plans to prohibit 

emissions from within the State which contribute 

significantly to nonattainment or maintenance areas in 

any other State, or which interfere with programs under 

Part C to prevent significant deterioration of air quality or 

to achieve reasonable progress toward the national 

visibility goal for Federal class I areas (national parks and 

wilderness areas). In order to assist States in addressing 

their obligations regarding regionally transported 

pollution, U.S. EPA finalized CAIR to reduce SO2 and 

NOx emissions from large electric generating units 

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

CAIR to reduce NOx and SO2 emissions contributing to 

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

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

Ohio Administrative Code (OAC) Chapter 3745-1093

. On 

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

CAIR program, the CSAPR. CSAPR could further assist 

States in addressing their obligations regarding regionally 

transported pollution by providing reductions in NOx and 

SO2 emissions in 2012 and 2014. However, on 

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

CSAPR and ordered U.S. EPA to continue administering 

CAIR pending the court’s resolution. 

iv.) Section 172(c) requirements 

 This Section contains general requirements for nonattainment 

plans. The requirements for reasonable further progress, 

identification of certain emissions increases, and other 

measures needed for attainment will not apply for 

redesignations because they only have meaning for areas not 

 

3 http://www.epa.ohio.gov/dapc/regs/regs.aspx#3745-109 
 7 

attaining the standard. The requirements for an emission 

inventory will be satisfied by the inventory requirements of the 

maintenance plan. Chapters Four and Five discuss this 

requirement in more detail. 

v.) Conformity 

The state must work with U.S. EPA to show that its SIP 

provisions are consistent with the Section 176(c)(4) conformity 

requirements. The redesignation request should include 

conformity procedures, if the state already has these 

procedures in place. If a state does not have conformity 

procedures in place at the time that it submits a redesignation 

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

regulation upon issuance, as applicable. 

vi.) Maintenance plans (CAA Section 107(d)(3)(E)(iv)) 

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

redesignated, U.S. EPA must fully approve a maintenance plan 

that meets the requirements of Section 175(A). The 

maintenance plan will constitute a SIP revision and must 

provide for maintenance of the relevant NAAQS in the area for 

at least 10 years after redesignation. Section 175 (A) further 

states that the plan shall contain such additional measures, if 

any, as may be necessary to ensure such maintenance. 

In addition, the maintenance plan shall contain such 

contingency measures as the Administrator deems necessary to 

ensure prompt correction of any violation of the NAAQS. At a 

minimum, the contingency measures must include a 

requirement that the state will implement all measures 

contained in the nonattainment SIP prior to redesignation. 

States seeking redesignation of a nonattainment area should 

consider the following provisions: 

 a.) attainment inventory; 

 b.) maintenance demonstration; 

 c.) monitoring network; 

 d.) verification of continued attainment; and 

 e.) contingency plan. 

 

 U.S. EPA’s 2006 Implementation Memo states: 

As mentioned earlier in this memorandum, statewide annual 

emission inventories are required under 40 CFR Part 51, 
 8 

Subpart A. We expect that for many nonattainment areas, these 

annual inventories will serve as an appropriate starting point for 

the emission inventories used for SIP development. In contrast 

with the 1997 annual PM2.5 NAAQS, where states rely only on 

annual inventories in the implementation process, the 2006 24-

hour PM2.5 NAAQS is designed to protect against peak 

exposures. Thus, for the 2006 24-hour PM2.5 NAAQS, there are 

some circumstances in which EPA believes that seasonal 

inventories may be useful for SIP planning purposes. For 

example, we have observed that in some nonattainment areas, 

all of the highest fine particle concentrations over the course of 

a year occur in one season. 

If exceedances occur during only one season for each of the 

years on which the nonattainment designation is based, and this 

is the case for all subsequent years, we recommend that states 

develop a seasonal inventory and that they use this inventory 

for SIP planning purposes.... 

Ohio EPA analyzed the PM2.5 monitoring data for the SteubenvilleWeirton area to determine whether the exceedances occurred in only 

one season. As can be seen in Figure 2 below, exceedances between 

2006 and 2008, the years on which the nonattainment designation is 

based, occurred in the first, second, third and fourth quarters. During 

subsequent years, 2009 through 2010, exceedances have occurred in 

the first, third and fourth quarters. Based on this analysis and in 

consultation with U.S. EPA and the West Virginia Division of Air Quality 

(WVDAQ), it was determined that an annual inventory would be 

sufficient for SIP planning, and that a seasonal inventory would not be 

required. 
 9 

Figure 1 – Steubenville-Weirton 24-hour PM2.5 Exceedances 

 

 Chapter Six discusses this requirement in more detail. 

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2007

2008

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2010
 10 

CHAPTER THREE 

PM2.5 MONITORING 

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

Requirement 1 of 4 

A demonstration that the NAAQS for 24-hour PM2.5, as published in 40 CFR 

50.7, has been attained. 

Background

 There are 5 monitors measuring PM2.5 concentrations in this 

nonattainment area. Two monitors in Jefferson County, Ohio4

, 

two in Brooke County, WV and one in Hancock County, WV. A 

listing of the design values based on the three-year average of 

the annual mean concentrations from 2008 through 2010 and a 

listing of the design values based on the three-year average of 

the 98th percentile are shown in Table 1. The locations of the 

monitoring sites for this nonattainment area are shown on 

Figure 2. 

 

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Background

 

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

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

 In accordance with the CAA Amendments, three complete years 

of monitoring data are required to demonstrate attainment at a 

monitoring site. The 24-hour PM2.5 primary and secondary 

ambient air quality standards are met at an ambient air quality 

monitoring site when the three-year average of the 24-hour 98th 

percentile values are less than or equal to 35 μg/m3

. While 

calculating design values, one decimal place must be carried in 

the computations, with final values rounded to the nearest 1 

μg/m3

. Decimals 0. 5 or greater are rounded up, and those less 

than 0. 5 are rounded down, so that 35.349 μg/m3 is the largest 

concentration that is less than, or equal to 35 μg/m3

. Values at 

or below 35 μg/m3 meet the standard; values greater than 35 

μg/m3

 exceed the standard. An area is in compliance with the 

24-hour PM2.5 NAAQS only if every monitoring site in the area 

meets the NAAQS. An individual site's 3-year average of the 24-

hour 98th percentile concentrations is also called the site's 

design value. The air quality design value for the area is the 

highest design value among all sites in the area. 

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

retrieved from the U.S. EPA AQS. 
 13 

Demonstration

Table 1 - Monitoring Data for the Steubenville-Weirton, OH-WV 

area for 2008 – 2010 

 Annual Standard 24-Hour Standard 

 Year Average 

2008-2010 

Year Average 

Site County 2008 2009 2010 2008 2009 2010 2008-2010 

39-081-

0017 (a) Jefferson, 

OH 

14.3 12.1 12.7 13.0 35.2 24.7 29.8 30 

39-081-

1001 14.1 11.2 12.7 12.7 35.0 23.3 25.1 28 

54-009-

0005 Brooke, 

WV 

14.7 12.2 14.1 13.7 38.9 23.2 29.8 31 

54-009-

0011 13.8 11.9 13.5 13.1 34.9 26.3 31.6 31 

54-029-

1004 

Hancock, 

WV 13.3 11.2 12.6 12.4 35.8 25.2 31.2 31 

 Less than 75% capture in at least one quarter 

(a) This site has a 73% capture, resulting in one day of missed data. Based on the data from previous 

years, this site shows a decreasing tren in monitor readings. Ohio believes that had the missing data 

been collected it would not have resulted in a design value that would exceed the standard. 

Source: U.S. EPA Air Quality System (AQS); http://www.epa.gov/ttn/airs/airsaqs/index.htm 

The design value calculated for the Steubenville-Weirton area 

demonstrates that the 24-hour PM2.5 NAAQS has been attained. 

However, one monitor site in Jefferson County (site 39-081-0017), did 

not comply with the 75% data capture requirement for the 2008-2010 

period. Specifically, the fourth quarter (October, November, and 

December) of 2008 has only 73% capture. This monitoring site 

experienced instrument malfunction during the low percentage capture 

missing a total of 8 missing 1-in-3 day PM2.5 FRM runs. 

Under 40 CFR Part 50, Appendix N, the use of less than complete data 

may be approved by U.S. EPA considering such factors as monitoring 

site closures/moves, monitoring diligence, and nearby concentrations 

in determining whether to use such data. However, in order to further 

demonstrate that this monitor has attained the standard, Ohio EPA 

prepared a statistical analysis of the 24-hour standard using multiple 

imputations. Ohio EPA has imputed missing values for this site and 

then performed an ordinary analysis as if the imputed values were real 

measurements. Multiple imputations use random draws from the 

conditional distribution of the target variable given the other variables. 

When a regression model is used for imputation, the process involves 

adding a random residual to the “best guess” for missing values, to 

yield the same conditional variance as the original variable. Appendix 

E describes, and includes, the full statistical analyses performed to 

show that the three-year average (2008 to 2010) of the 98th percentile 
 14 

24-hour values, based on missing data imputations, is 30 μg/m3, below 

the 35 μg/m3 24-hour standard. 

Table 2 shows site 39-081-0017 before and after the imputation of 

missing data. Also the “new” site (with imputed values) shows a 

passing 24-hour design value for 2008 to 2010 of 30 μg/m3. 

Table 2 - 98th Percentile and Design Value Before and After Imputation 

With the data imputation analysis and results, Requirement 3 of 4 has 

been met. 

The area’s design values have trended downward as emissions have 

declined due to cleaner automobiles and fuels, and controls for EGUs. 

National monitoring for PM2.5 began in 1999. There has been a clear 

downward trend in design values for all monitors in Ohio and West 

Virginia, as shown in Figures 3 and 4. Design values have also 

trended downward nationally, as show in Figure 5. 

39‐081‐0017 2003 2004 2005 2006 2007 2008 2009 2010 2003‐2005 2004‐2006 2005‐2007 2006‐2008 2007‐2009 2008‐2010

OLD Creditable 17 104 94 115 111 106 112 108

OLD 98th 39.6 43.8 43.8 32.1 43.5 35.2 24.7 29.8

New Creditable 119 120 121 115 111 121 112 108

New 98th 30.4 43.9 40.3 32.1 43.5 35.2 24.7 29.8

less than 75% capture in at least one quarter

Year includes one or more quarters with imputed values

37 34 30

38 39 39 37 34 30

42 40 40

YEAR 24‐Hour Design Value
F

S

Figure 3 - O

2

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Figure 4 - W

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Figure 5 - P

 

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Through 20

EP: http://ww

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ww.epa.gov/ai

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pa.gov/airtrends

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 17 

Requirement 4 of 4 

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

appropriate monitoring network to verify the maintenance of the attainment 

status. 

Demonstration

 Ohio EPA commits to continue monitoring PM2.5 levels at the 

Ohio sites indicated in Figure 2 and Table 1. Ohio EPA will 

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

existing monitoring network, should changes become necessary 

in the future. Ohio EPA will continue to quality assure the 

monitoring data to meet the requirements of 40 CFR 58 and all 

other federal requirements. Connection to a central station and 

updates to the Ohio EPA web site5

 will provide real time 

availability of the data and knowledge of any exceedances. Ohio 

EPA will enter all data into AQS on a timely basis in accordance 

with federal guidelines. 

 

5 www.epa.ohio.gov/dapc 
 18 

CHAPTER FOUR 

EMISSION INVENTORY

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

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

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

crustal matter, and elemental carbon), SO2 and NOx

6

) representative of the 

year when the area achieves attainment of the 24-hour PM2.5 air quality 

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

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

achieved is based on permanent and enforceable emission reductions. Other 

emission inventory related requirements include a projection of the emission 

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

that the projected level of emissions is sufficient to maintain the 24-hour PM2.5

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

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

The emissions inventory development and emissions projection discussion 

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

projections, identifies procedures used by Ohio EPA and the LADCO 

regarding emissions from Ohio’s portion of the Steubenville-Weirton area. 

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

and West Virginia. West Virginia emissions data were obtained though the 

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

inventories and emissions projections were prepared using similar 

methodologies, unless otherwise noted. Mobile emissions inventories and 

projections for all counties were prepared by the Brooke-Hancock-Jefferson 

Metropolitan Planning Commission (BHJ) and the Ohio Department of 

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

Department of Transportation (WVDOT), and WVDEP. 

Requirement 1 of 5 

A comprehensive emission inventory of PM2.5, SO2 and NOx completed for the 

base year. 

Background

The 2005 periodic inventory has been identified as one of the 

preferred databases for SIP development and coincides with 

nonattainment air quality in the Steubenville-Weirton area. 

Periodic inventories, which include emissions from all sectors 

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

 

6 VOC and NH3 are not addressed. 
 19 

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

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

(MAR)) are derived from this inventory. Ohio’s point source data 

derived from this periodic inventory is actual source reported 

emissions under Ohio's annual emissions reporting program. 

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

CSAPR estimates (EGU) and actual reported data under West 

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

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

2005 National Emissions Inventory (NEI) while Non-road 

emissions are derived from NONROAD modeling conducted by 

WVDAQ.

Demonstration

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

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

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

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

information for Ohio’s portion of the Steubenville-Weirton area is 

provided in Appendix B. Emissions of PM2.5, SO2 and NOx for 

2005 are identified under Requirement Three of this Chapter. 

Requirement 2 of 5 

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

redesignation. 

Background

Ohio EPA prepared a comprehensive inventory for the Ohio portion of 

the Steubenville-Weirton area including area, mobile, and point 

sources for PM2.5, SO2 and NOx for base year 2005. The 2005 

inventory was submitted to U.S. EPA on July 18, 2008 as part of 

Ohio’s PM2.5 attainment demonstration SIP for this area. The 

information below describes the procedures Ohio EPA used to 

generate the 2005 base year inventory and to develop SIP-ready 

modeling inventories and future year projections (Pechan Report7

) 

based on a 2005 base year inventory. The report by Pechan generated 

future year estimates of annual emissions for each source sector using 

accepted growth surrogates. These inventories were provided to the 

LADCO and have been processed to develop average daily emissions 

 

7 

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

ntrols%20Report_Final.pdf 
 20 

for use in the air quality analyses. These processed modeling 

inventories have been identified as the correct iteration of the inventory 

for use in the redesignation. In this document, references to LADCO 

include the Midwest Regional Planning Organization. Note, that the onroad mobile source sector was addressed by specific PM2.5 and NOx

modeling as discussed below. 

• Area source and MAR emissions were taken from the 

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

These projections were made from the U.S. Department 

of Commerce Bureau of Economic Analysis (BEA) 

growth factors, with some updated local information. 

• Mobile source emissions were calculated from 

MOVES2010 produced emission factors. Only PM2.5 and 

NOx necessitate an emissions inventory analysis. Ohio 

EPA in consultation with U.S. EPA determined mobile 

sources are insignificant contributors for SO2. Consistent 

with Ohio EPA’s attainment demonstration, Ohio EPA 

continues to consider mobile source SO2 to be an 

insignificant contributor to fine particles for this 

nonattainment area. Based on the results of mobile 

source emissions projections prepared as part of this 

redesignation and maintenance plan, Ohio EPA is also 

making a finding that the regional highway emissions 

PM2.5 and NOx are insignificant contributors to the 

nonattainment problem in this area, as discussed below 

• Point source information was compiled from Ohio EPA’s 

2005 annual emissions inventory database and the 2005 

U.S. EPA Air Markets acid rain database8. 

• Biogenic emissions are not included in these summaries. 

• Non-road emissions were derived from NONROAD 

modeling conducted by WVDAQ, as found in Appendix 

D. 

West Virginia emission projections were provided by the 

WVDAQ as summarized below. 

 

• Area source and MAR emissions were compiled from the 

2008 NEI and 2015 and 2025 projections were grown 

using Workforce data. 

• Mobile source emissions were calculated using the same 

methodology as described above for Ohio’s portion. 

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

EPA’s CSAPR inventories. 

 

8 http://www.epa.gov/airmarkets/acidrain 
 21 

• Non-EGU point source information was compiled from 

West Virginia’s 2008 actual emissions inventory and 

2015 and 2025 projections were grown using Workforce 

data. 

• Non-road emissions were derived from NONROAD 

modeling conducted by WVDAQ, as found in Appendix 

D. 

 

 

Demonstration

On-Road Emission Estimations 

The ODOT, Division of Transportation System DevelopmentModeling and Forecasting Section and the Brooke-HancockJefferson Metropolitan Planning Commission (BHJ) defined the 

underlying planning assumptions for the annual PM2.5 on-road 

mobile source emission inventories for the Steubenville-Weirton, 

OH-WV nonattainment area. 

In coordination with the ODOT, BHJ utilizes a regional travel 

demand forecast model to simulate traffic in the area and to 

forecast traffic flows for given growth expectations. The model 

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

transportation system including determination of locations where 

additional travel capacity may be needed and to determine the 

infrastructure requirements necessary to meet that need. It is 

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

emissions of pollution caused by vehicles in the area. The 

travel demand forecasting model is used to predict traffic 

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

EPA computer program called MOVES is used to calculate 

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

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

Overview 

U.S.EPA published a Federal Register notice9 of availability on 

March 2, 2010, to approve MOVES2010 (Motor Vehicle 

Emissions Simulator), hereafter referred to as MOVES. Upon 

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

EPA’s approved motor vehicle emission factor model for 

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

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

state and local agencies. MOVES is a computer program 

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

 

9 http://www.regulations.gov/search/Regs/home.html#documentDetail?R=0900006480ab1f98 
 22 

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

emissions model for on-road mobile sources, MOBILE6.2. 

MOVES can be used to estimate exhaust and evaporative 

emissions as well as brake and tire wear emissions from all 

types of on-road vehicles. 

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

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

and measures vehicle emissions to make sure the Agency has 

the best possible understanding of mobile source emissions. 

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

EPA’s mobile source emission models. MOVES represents the 

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

emissions. MOVES also incorporates several changes to the 

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

based upon recommendations made to the Agency by the 

National Academy of Sciences. 

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

PM, and nitrogen dioxide SIP development as expeditiously as 

possible. The CAA requires that SIP inventories and control 

measures be based on the most current information and 

applicable models that are available when a SIP is developed. 

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

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

required for new transportation conformity analyses. 

The MOVES more detailed approach (when compared with the 

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

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

sources, such as data from vehicle inspection and maintenance 

(I/M) programs, remote sensing device (RSD) testing, 

certification testing, portable emission measurement systems 

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

variety of activity data to better estimate emission differences 

such as those resulting from changes to vehicle speed and 

acceleration patterns. MOVES has a graphical user interface 

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

MOVES database-centered design provides users much greater 

flexibility regarding output choices. Unlike earlier models which 

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

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

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

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

can be easily aggregated or disaggregated to examine 

emissions in a range of scales, from national emissions impacts 
 23 

down to the emissions impacts of individual transportation 

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

update emissions data incorporated in MOVES more easily and 

will allow users to incorporate a much wider array of activity 

data to improve estimation of local emissions. For example, the 

improvements in MOVES will allow project-level PM2.5 

emissions to be estimated. 

BHJ utilized U.S.EPA’s emissions model MOVES to develop 

emissions factors for SO2, NOx and PM2.5. Further details on the 

use of MOVES are found on Appendix C. BHJ maintains a 

validated region wide Travel Demand Model (TDM) that 

employs a four-step modeling process consisting of trip 

generation, trip distribution, mode choice, and route assignment. 

The current BHJ TMD validation year is 2000. The model uses 

comparable average daily traffic count data, updated socialeconomic variables for each of the analysis years by either 

updating existing or known land use commitment for 2008, 

2009, and 2014, or projected 2014 and 2020 variables based on 

a straight line extrapolation between 2009 set of variables and 

the Horizon Year 2030 variables. These networks represent all 

planned federal-aid projects as well as any regionally significant 

projects found in the BHJ TIP and LRTP expected to be open 

for traffic by the end of each respective analysis year. 

Identifying projected growth centers and understanding urban 

and rural population changes are essential to determine future 

transportation needs in a given study area. Travel forecasting 

procedures require the user delineates the TDM study area into 

geographic areas called Traffic Analysis Zones. Typically, these 

Zones are based on factors such as land use, area types 

(urban, suburban or rural), or political government units such as 

cities, villages, or townships. The BHJ collects and reviews the 

TDM independent variables that characterize current and future 

estimates of the metropolitan area’s social and economic 

activities that may influence land use development patterns. 

 The following categories of planning data are utilized: 

- Population. 

- Households. 

- Household vehicles. 

- Employment. 

- Labor force participation. 

- Area type. 

The principal data requirements of the BHJ travel demand 
 24 

forecasting model are population and employment, from these 

variables other characteristics including household, labor force, 

and personal vehicles may be derived. 

BHJ utilizes both base year (2005) and future year data (2010, 

2020 and 2030) in the planning process. Planning data are 

maintained at the Traffic Analysis Zone (TAZ) level, and 

originate in the 2000 Census of Population and Housing. Base 

year 2005 and future yare data for each variable are developed 

through various methods. The MOVES model generated the 

emissions factor files for base year 2005 and attainment year 

2008 representing transportation improvement programs 

implemented in the BHJ Region. The model also generated 

emission factors for two future year scenarios 2015 and 2025. 

The single season approach for temperature and relative 

humidity uses weather data collected by the National Oceanic 

and Atmospheric Administration (NOAA) National Climatic Data 

Center (NCDC). The data used in this report, taken from the 

Pittsburgh International Airport collection center, is 

representative of 12 months in 2009. 

BHJ and ODOT incorporates a variety of sources of local data to 

both improve and confirm the accuracy of VMT, as well as other 

travel-related parameters. Free flow speeds used on the 

highway and transit networks are based on travel time studies 

performed locally. A BHJ post-processing program uses the 

loaded highway network to generate VMT by hour, VMT by 

speed distribution, and VMT by facility type. These tables are 

then included as input into MOVES. 

On-Road Mobile Emission Estimations 

Tables 2 through 8 contain the results of the emissions analysis for the 

appropriate years. All emissions estimations are expressed in tons per 

year (tpy). 
 25 

Table 3 - Jefferson County, OH, Emissions Estimations for OnRoad Mobile Sources 

 2005 2008 2015 2025 

PM2.5 (tpy) 73.17 60.97 31.88 16.49

NOx (tpy) 2105.85 1758.04 870.17 322.71

SO2 (tpy) 18.18 5.65 3.93 3.56

Annual VMT 562,071,084 557,286,295 544,597,475 572,657,778

Table 4 – Summary of Ohio Emissions Estimations for On-Road 

Mobile Sources 

 2005 2008 2015 2025 

PM2.5 (tpy) 73.17 60.97 31.88 16.49

NOx (tpy) 2105.85 1758.04 870.17 322.71

SO2 (tpy) 18.18 5.65 3.93 3.56

Annual VMT 562,071,084 557,286,295 544,597,475 572,657,778 

Table 5 – Brooke County, WV, Emissions Estimations for OnRoad Mobile Sources 

 2005 2008 2015 2025 

PM2.5 (tpy) 19.41 14.42 6.97 4.34

NOx (tpy) 540.40 412.02 174.71 62.47

SO2 (tpy) 7.01 2.11 1.51 1.26

Annual VMT 212,244,639 212,778,859 219,881,355 216,619,184

 

Table 6 – Hancock County, WV, Emissions Estimations for OnRoad Mobile Sources 

 2005 2008 2015 2025 

PM2.5 (tpy) 18.63 13.51 6.53 4.10

NOx (tpy) 482.75 360.25 149.00 52.09

SO2 (tpy) 6.58 1.92 1.36 1.10

Annual VMT 180,767,718 177,219,697 180,298,107 174,534,361
 26 

Table 7 – Summary of West Virginia Emissions Estimations for 

On-Road Mobile Sources 

 2005 2008 2015 2025 

PM2.5 (tpy) 38.04 27.93 13.5 8.44

NOx (tpy) 1023.15 772.27 323.71 114.56

SO2 (tpy) 13.59 4.03 2.87 2.36

Annual VMT 393,012,357 389,998,556 400,179,462 390,998,315

Table 8 – Emissions Estimations Totals for On-Road Mobile 

Sources for the Steubenville-Weirton Area 

 2005 2008 2015 2025 

PM2.5 (tpy) 111.21 88.9 45.38 24.93

NOx (tpy) 3129 2530.31 1193.88 437.27

SO2 (tpy) 31.77 9.68 6.80 5.92

Annual VMT 955,083,441 947,284,851 944,776,937 963,656,093 

The following table identifies the percentage of mobile emissions of all 

emissions, for each pollutant in the entire Steubenville-Weirton area 

and Ohio’s portion of this area for 2015 and 2025. 

Table 9 – Percent of Mobile Emissions for the SteubenvilleWeirton Area in 2015 and 2025 

NOx SO2 PM2.5

2015 2025 2015 2025 2015 2025

Steubenville‐

Weirton

Area

Total (tpy) 25,563.36 17,533.17 74,806.60 47,445.13 2,740.52 2,698.00

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

% Mobile 4.67% 2.49% 0.009% 0.012% 1.66% 0.92% 

Ohio Portion

Total (tpy) 22,883.61 15,237.65 73,080.25 45,861.72 2,005.04 1,997.72

Mobile (tpy) 870.17 322.71 3.93 3.56 31.88 16.49 

% Mobile 3.80% 2.12% 0.005% 0.008% 1.59% 0.83% 

NOx constitutes less than five percent (4.67%) of the 

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

less than three percent (2.49%) of the area’s total NOx

emissions in the 2025 horizon year. 

SO2 constitutes less than one percent (<1%) of the area’s 

total SO2 emissions in the 2015 and 2025 horizon years. 

PM2.5 constitutes less than two percent (1.66%) of the 

area’s total PM2.5 emissions in the 2015 horizon year and 
 27 

less than one percent (0.92%) of the area’s total PM2.5

emissions in the 2025 horizon year. 

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

highway emissions for PM2.5, NOx, and SO2 are insignificant 

contributors to the nonattainment problem of the Steubenville-Weirton 

area, as agreed upon as a part of the interagency consultation 

process. Because of this finding it is not necessary to establish mobile 

emission budgets for this area in the 2015 and 2025 horizon years. 

The nonattainment area meets the 40 CFR 93.109(m) criteria for 

PM2.5, NOx, and SO2. Throughout this document, Ohio EPA 

demonstrates that it would be unreasonable to expect that the 

Steubenville-Weirton area would experience enough motor vehicle 

emissions growth in PM2.5, NOx, and SO2 for a PM2.5 NAAQS violation 

to occur. Moreover, Ohio EPA demonstrates that the percentage of 

motor vehicle emissions in the context of the total SIP inventory, the 

current state of air quality as determined by monitoring data, the 

absence of SIP motor vehicle control measures, and historical trends 

and future projections of the growth of motor vehicle emissions, are 

evidence enough to consider mobile source PM2.5, NOx, and SO2

insignificant contributors to fine particles. 

Requirement 3 of 5 

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

the PM2.5 standard. 

Background

In consultation with U.S. EPA, Ohio EPA selected the year 2025 

as the maintenance year for this redesignation request. This 

document contains projected emissions inventories for 2015 

and 2025. 

Emission projections for the Steubenville-Weirton area were 

performed using the following approaches: 

• As performed by ODOT and BHJ, mobile source 

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

model. The analysis is described in more detail in 

Appendix C. All projections were made in accordance 

with “Procedures for Preparing Emissions Projections” 

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

determined that the mobile emission contribution as a 

percent of the total emission inventory from the area is 

not significant. 
 28 

• Emissions inventories are required to be projected to 

future dates to assess the influence growth and future 

controls will have. LADCO has developed growth and 

control files for point and area categories. These files 

were used to develop Ohio’s portion of this 

nonattainment area future-year emissions estimates used 

in this document. This was done so the inventories used 

for redesignation are consistent with modeling performed 

in the future. Appendix D contains LADCO’s technical 

support document detailing the analysis used to project 

emissions (Base M10). 

• For the 2008 attainment year emissions were grown from 

the 2005 LADCO modeling inventory, using LADCO’s 

growth factors, for all sectors except point sources 

(electrical generating units and non-electrical generating 

units). Point source emissions for 2008 were compiled 

from Ohio EPA’s 2008 Annual emissions inventory 

database. The 2015 interim year emissions were 

estimated based on the 2009 and 2018 LADCO modeling 

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

except non-EGU PM2.5. The 2025 maintenance year is 

based on emissions estimates from the 2018 LADCO 

modeling, for all sectors except non-EGU PM2.5. NonEGU PM2.5 emissions for 2015 and 2025 were grown 

from 2005 and 2009 emissions estimates. 

Ohio EPA is identifying emissions projections for 2015 and 2025 

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

has raised concerns regarding the CAIR program and its 

remand. However, Ohio EPA believes these are the most 

appropriate and accurate future projections. Although CSAPR 

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

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

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

provide even greater reductions in emissions than the CAIR 

program once resolved; therefore, these emissions projections 

will be conservative. 

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

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

eastern states and the District of Columbia to significantly 

reduce emissions of NOx and SO2. CAIR replaced the NOx SIP 

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

 

10 http://www.ladco.org/tech/emis/current/index.php 
 29 

NOx emissions to be cut from 4.5 million tons in 2004, to a cap 

of 1.5 million tons by 2009, and 1.3 million tons in 2018 in 28 

states. States were required to submit a CAIR SIP as part of 

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

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

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

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

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

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

per year to 93,000 tons per year while in 2010 emissions of SO2

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

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

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

while emissions of SO2 will decrease to 208,000 tons per year, 

within Ohio11. On December 23, 2008, U.S. EPA’s CAIR 

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

Court. 

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

decline in the 264,000 tons of NOx and 1,373,000 tons of SO2

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

and implementing control programs to address CAIR12 and 

consent decrees. 

Table 10 - Reductions in SO2 and NOx EGU Emissions 

Between 2008 and 2009 

SO2 NOx

2008 2009 Change 2008 2009 Change 

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

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

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

Source: Clean Air Markets Quarterly Emissions Tracking13

Significant reductions also occurred regionally and nationally as 

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

first two quarters of 2010, the year SO2 reductions are to be 

implemented under CAIR: 

 

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

12 Under CAIR, NOx reductions are to occur beginning in 2009 while SO2 reductions are to occur 

beginning in 2010.

13 http://www.epa.gov/airmarkets/quarterlytracking.html
 30 

Table 11 – Reductions in SO2 and NOx EGU Emissions 

Between the First Half of 2008 and 2010 

SO2 NOx

2008 

 (1st half) 

2010 

(1st half) Change 2008 

(1st half) 

2010 

(1st half) Change 

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

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

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

Source: Clean Air Markets Quarterly Emissions Tracking14

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

Division: 

“Based on emissions monitoring data, EPA has observed 

substantial reductions in SO2 emissions from 2005 to 2009 and 

in the first two quarters of 2010 as companies installed more 

controls, electric demand declined, and low natural gas prices 

made combined-cycle gas-fired units more competitive in 

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

and subsequent remand in late 2008, the controls in place 

generally have continued to operate, helping to drive continued 

progress in reducing emissions.15” 

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

CAIR program is providing real reductions at this time, Ohio 

believes these reductions have assisted with PM2.5 attainment in 

this nonattainment area and throughout Ohio. 

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

program, the CSAPR. CSAPR would preserve those initial 

reductions achieved under CAIR and provide even greater 

reductions in NOx and SO2 emissions in 2012 and 2014, ahead 

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

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

tons per year and in 2014 to 85,744 tons per year while SO2 will 

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

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

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

be no maintenance issues within this entire nonattainment area. 

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

CSAPR and ordered U.S. EPA to continue administering CAIR 

pending the court’s resolution. 

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

evaluate Ohio EPA’s demonstration that the projected level of 

 

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

15 http://www.epa.gov/airmarkets/background.htm
 31 

emissions is sufficient to maintain the 24-hour PM2.5 standard by 

assessing future year emissions that include the CAIR program. 

The detailed inventory information for the Ohio portion of the 

Steubenville-Weirton area for 2005 is in Appendix B. Emission 

trends are an important gauge for continued compliance with 

the PM2.5 standard. Therefore, Ohio EPA performed an initial 

comparison of the inventories for the base year and 

maintenance years. Mobile source emission inventories are 

described in Appendix C. 

Sectors included in the following tables are: Electrical 

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

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

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

Maintenance is demonstrated when the future-year (2025) 

projected emission totals are below the 2008 attainment year 

totals. 

Demonstration

PM2.5 

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

contains particulate fraction emissions only and not the condensable 

fractions as Ohio EPA did not have a consistent reporting requirement 

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

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

added additional PM2.5 condensable emissions into future years. 

Therefore, comparing base and attainment year emissions with the 

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

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

Modeling performed by LADCO, without CAIR, did not incorporate 

added condensable fraction emissions. Although Ohio EPA has stated 

that it is most appropriate to evaluate future year emissions that 

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

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

emissions without the CAIR program. 
 32 

Table 12 - Jefferson County, Ohio PM2.5 Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2025 (tpy) – Without CAIR

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2025 

Maintenance 

Safety 

Margin 

EGU Point 1,307.90 1,372.80 1,405.39 1,449.64 -76.84 

Non-EGU 461.57 461.42 437.63 413.69 47.73 

Non-road 24.30 22.50 17.15 11.25 11.25 

Area 110.12 110.60 108.49 105.97 4.63 

MAR 8.07 7.25 4.50 0.68 6.57 

On-road 73.17 60.97 31.88 16.49 44.48 

TOTAL 1,985.13 2,035.54 2,005.04 1,997.72 37.82 

Table 13 - Brooke County, West Virginia PM2.5 Emission 

Inventory Totals for Base Year 2005, Estimated 2008, 

and Projected 2015 and 2025 (tpy) – With CSAPR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2025 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00 

Non-EGU 155.12 166.68 155.84 141.59 25.09 

Non-road 11.04 9.46 6.47 3.76 5.70 

Area 208.48 219.93 217.55 216.00 3.93 

MAR 17.07 3.85 3.87 3.91 -0.06 

On-road 19.41 14.42 6.97 4.34 10.08 

TOTAL 411.12 414.34 390.70 369.60 44.74 

Table 14 - Hancock County, West Virginia PM2.5 Emission 

Inventory Totals for Base Year 2005, Estimated 2008, 

and Projected 2015 and 2025 (tpy) – With CSAPR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2025 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00 

Non-EGU 182.02 90.97 83.84 74.81 16.16 

Non-road 9.61 8.20 5.57 3.10 5.10 

Area 313.70 232.96 230.26 229.92 3.04 

MAR 26.18 18.46 18.58 18.75 -0.29 

On-road 18.63 13.51 6.53 4.10 9.41 

TOTAL 550.14 364.10 344.78 330.68 33.42 

 
 33 

Table 15 – Steubenville-Weirton Area PM2.5 Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

projected 2015 and 2025 (tpy) – Without CAIR (Ohio) 

and With CSAPR (West Virginia) 

PM2.5 2005 Base 2008 

Attainment 

2015 

Interim 

2025 

Maintenance 

Safety 

Margin 

Jefferson 1,985.13 2,035.54 2,005.04 1,997.72 37.82

Hancock, WV 550.14 364.10 344.78 330.68 33.42

Brooke, WV 411.12 414.34 390.70 369.60 44.74

COMBINED 

PM2.5 TOTAL 2,946.39 2,813.98 2,740.52 2,698.00 115.98

NOx 

Table 16 - Jefferson County, Ohio NOx Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and Projected 

2015 and 2025 (tpy) – With CAIR 

Sector 2005 

Base 

2008 

Attainment 2015 Interim 2025 Maintenance

Safety 

Margin 

EGU Point 41,046.61 35,486.86 19,488.27 12,631.73 22,855.13 

Non-EGU 1,991.85 1,991.96 1,938.71 1,863.75 128.21 

Non-road 234.30 207.68 131.49 96.59 111.09 

Area 251.38 253.45 252.46 251.93 1.52 

MAR 317.3 300.96 202.51 70.94 230.02 

On-road 2,105.85 1,758.04 870.17 322.71 1,435.33 

TOTAL 45,947.29 39,998.95 22,883.61 15,237.65 24,761.30 

Table 17 - Brooke County, West Virginia NOx Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2025 (tpy) – With CSAPR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2025 

Maintenance

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00 

Non-EGU 692.76 789.79 742.21 679.29 110.50 

Non-road 204.75 169.37 88.18 59.17 110.20 

Area 311.36 119.10 117.87 116.12 2.98 

MAR 444.99 112.83 113.54 114.56 -1.73 

On-road 540.40 412.02 174.71 62.47 349.55 

TOTAL 2,194.26 1,603.11 1,236.51 1,031.61 571.50 
 34 

Table 18 - Hancock County, West Virginia NOx Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2025 (tpy) – With CSAPR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2025 

Maintenance

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00 

Non-EGU 1,181.15 574.68 524.80 462.67 112.01 

Non-road 135.47 119.41 74.58 51.49 67.92 

Area 1,446.78 158.02 156.60 154.58 3.44 

MAR 695.36 534.89 538.26 543.08 -8.19 

On-road 482.75 360.25 149.00 52.09 308.16 

TOTAL 3,941.51 1,747.25 1,443.24 1,263.91 483.34 

 

Table 19 - Steubenville-Weirton Area NOx Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2025 (tpy) – With CAIR (Ohio) and 

With CSAPR (West Virginia) 

NOx 2005 

Base 

2008 

Attainment 

2015 

Interim 

2025 

Maintenance

Safety 

Margin 

Jefferson 45,947.29 39,998.95 22,883.61 15,237.65 24,761.30

Hancock, WV 3,941.51 1,747.25 1,443.24 1,263.91 483.34

Brooke, WV 2,194.26 1,603.11 1,236.51 1,031.61 571.50

COMBINED 

NOx TOTAL 52,083.06 43,349.31 25,563.36 17,533.17 25,816.14

SO2

Table 20 - Jefferson County, Ohio SO2 Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and Projected 

2015 and 2025 (tpy) – With CAIR

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2025 

Maintenance

Safety 

Margin 

EGU Point 225,594.94 135,506.74 72,203.22 45,073.14 90,433.60 

Non-EGU 849.92 782.87 757.91 692.85 90.02 

Non-road 17.31 3.09 0.40 0.45 2.64 

Area 110.89 109.15 101.75 91.69 17.46 

MAR 26.16 21.61 13.04 0.48 21.13 

On-road 18.18 5.65 3.93 3.56 2.09 

TOTAL 226,617.40 136,429.11 73,080.25 45,862.17 90,566.94 
 35 

Table 21 - Brooke County, West Virginia SO2 Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2025 (tpy) – With CSAPR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2025 

Maintenance

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00 

Non-EGU 620.55 766.54 718.43 654.91 111.63 

Non-road 12.13 2.17 0.27 0.30 1.87 

Area 167.98 163.76 156.62 146.42 17.34 

MAR 20.32 6.34 6.38 6.44 -0.10 

On-road 7.01 2.11 1.51 1.26 0.85 

TOTAL 827.99 940.92 883.21 809.33 131.59 

Table 22 - Hancock County, West Virginia SO2 Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2025 (tpy) – With CSAPR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2025 

Maintenance

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00 

Non-EGU 1,480.85 613.04 572.55 519.57 93.47 

Non-road 9.72 1.73 0.21 0.23 1.50 

Area 728.92 248.63 237.35 221.22 27.41 

MAR 32.27 31.47 31.67 31.96 -0.49 

On-road 6.58 1.92 1.36 1.10 0.82 

TOTAL 2,258.34 896.79 843.14 774.08 122.71 

 

Table 23 - Steubenville-Weirton Area SO2 Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2025 (tpy) – With CAIR (Ohio) and 

With CSAPR (West Virginia) 

SO2 2005 Base 2008 

Attainment 

2015 

Interim 

2025 

Maintenance 

Safety 

Margin 

Jefferson 226,617.40 136,429.11 73,080.25 45,862.17 90,566.94

Hancock, WV 2,258.34 896.79 843.14 774.08 122.71

Brooke, WV 827.99 940.92 883.21 809.33 131.59

COMBINED 

SO2 TOTAL 229,703.73 138,266.82 74,806.60 47,445.58 90,821.24
 36 

PM2.5, NOx, and SO2

Table 24 - Steubenville-Weirton Area Comparison of 2008 

Attainment Year and 2015 and 2025 Projected 

Emission Estimates (tpy) 

 

2008 Base 2015 

Interim 

2015 

Projected 

Decrease 

2025 

Maintenance

2025 

Projected 

Decrease 

PM2.5 2,813.98 2,740.52 73.46 2,698.00 115.98

NOx 43,349.31 25,563.36 17,785.95 17,533.17 25,816.14

SO2 138,266.82 74,806.60 63,460.22 47,445.58 90,821.24

 

As shown in the table above (Table 23), PM2.5 emissions in the 

nonattainment area are projected to decrease by 73.46 tpy in 

2015 and 115.98 tpy in 2025. NOx emissions in the 

nonattainment area are projected to decrease by 17,785.95 tpy 

in 2015 and 25,816.14 tpy in 2025. SO2 emissions in the 

nonattainment area are projected to decline by 63,460.22 tpy in 

2015 and 90,821.24 tpy in 2025. 

In general, EGU source emissions, and to a lesser extent, area 

source emissions and Non-EGU source emissions show a 

decrease. Cleaner vehicles and fuels are expected to be in 

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

2012 and 2014 and these programs should cause an overall 

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

rules covering EGUs, Tier 2 Motor Vehicle Emissions Standards 

and Gasoline Sulfur Control Requirements16, Highway HeavyDuty Engine Rule17, and the Non-Road Diesel Engine Rule18 are 

factored into the changes. 

In addition to the above, the Cardinal Station (AEP) in 

Jefferson County implemented changes in late 2007 and early 

2008. Two units, #1 and #2 (each 600 megawatt) installed and 

began continuously operating scrubbers, and a restricted SO2

allowable emission rate was incorporated into a federally 

enforceable permit demonstrating they will not cause or 

contribute to a violation of a NAAQS and/or Prevention of 

Significant Deterioration increment violation based upon air 

dispersion modeling. These scrubbers began operating in 

December 2007 and March 2008.19 Also these two units were 

required by a federally enforceable consent decree to operate 

 

16 http://www.epa.gov/fedrgstr/EPA-AIR/2000/February/Day-10/a19a.htm 

17 http://www.epa.gov/fedrgstr/EPA-AIR/1997/October/Day-21/a27494.htm 

18 http://www.epa.gov/fedrgstr/EPA-AIR/1998/October/Day-23/a24836.htm 

19 The lower rates will be incorporated into the facility’s Title V operating permit at renewal.
 37 

their SNCR continuously to control and reduce NOx emissions 

by January 2009. Moreover, unit #3 (630 megawatt) is 

undergoing construction for the installation of a scrubber, to 

control SO2 emissions in the future. The permit-to-install these 

scrubbers will require a restricted SO2 allowable emission rate. 

The scrubbers will begin operating by January 2012 in 

accordance with their federally enforceable consent decree. 

Similar to unit #1 and #2, unit #3 was required by a federally 

enforceable consent decree to operate SNCR continuously to 

control and reduce NOx emissions by January 2009. 

Requirement 4 of 5 

A demonstration that improvement in air quality between the year violations 

occurred and the year attainment was achieved is based on permanent and 

enforceable emission reductions and not on temporary adverse economic 

conditions or unusually favorable meteorology. 

Background 

Ambient air quality data from all monitoring sites indicate that air 

quality met the NAAQS for PM2.5 in 2008-2010. U.S. EPA’s 

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

demonstrate maintenance of the NAAQS by either showing that future 

emissions of a pollutant or its precursors will not exceed the level of 

the attainment inventory, or by modeling to show that the future mix of 

sources and emissions rates will not cause a violation of the NAAQS.” 

Demonstration 

Permanent and enforceable reductions of PM2.5, NOx, and SO2

emissions have contributed to the attainment of the 24-hour PM2.5

standard. Some of these reductions were realized due to the 

application of tighter federal standards on non-road diesel vehicles 

(Clean Air Non-road Diesel Rule) and the application of tighter federal 

standards on new vehicles. Also Title IV of the CAA, the NOx SIP Call, 

CAIR, and federal consent decrees required the reductions of SO2 and 

NOx emissions from utility sources. Reductions achieved are 

discussed in greater detail under Chapter Five. 
 38 

Table 25 - Steubenville-Weirton Area Comparison of 2005 Base 

Year and 2008 Attainment Year On-Road, Non-Road 

and EGU Reductions 

2005 2008 

On-road PM2.5 111.21 88.90

On-road NOx 3,129.00 2,530.31

On-road SO2 31.77 9.68

Non-road PM2.5 44.95 40.16

Non-road NOx 574.51 496.47

Non-road SO2 39.16 6.99

EGU PM2.5 1,307.90 1,372.80

EGU NOx 41,046.61 35,486.86

EGU SO2 225,594.94 135,506.74

Requirement 5 of 5 

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

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

Demonstration

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

submit air emissions information annually, in accordance with 

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

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

precursor emission sectors every three years. These PM2.5

precursor inventories will be prepared for future years as 

necessary to comply with the inventory reporting requirements 

established in the CFR. Emissions information will be compared 

to the 2005 base year and the 2025 projected maintenance year 

inventories to assess emission trends, as necessary, and to 

assure continued compliance with the 24-hour PM2.5 standard. 
 39 

CHAPTER FIVE 

CONTROL MEASURES AND REGULATIONS

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

Requirement 1 of 6

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

nonattainment areas to implement RACM and RACT. 

Background

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

requires states with nonattainment areas to submit a SIP 

providing for implementation of all reasonably available control 

measures and as expeditiously as practicable (including such 

reductions in emissions from existing sources in the area as 

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

reasonable available control technology). 

U.S. EPA’s 1997 Implementation Rule interprets this 

requirement in great detail. Under U.S. EPA’s approach, RACT 

is determined as part of the broader RACM analysis and 

identification of all measures (for stationary, mobile, and area 

sources) that are technically and economically feasible, and that 

would collectively contribute to advancing the attainment date 

(i.e. by one year or more). States are required to use a 

combined approach to RACT and RACM, that (1) identifies 

potential measures that are reasonable, (2) uses modeling to 

identify the attainment date that is as expeditious as practicable, 

and (3) selects the appropriate RACT and RACM. 

The 1997 Implementation Rule also provides for a presumption 

that in States that fulfill their CAIR emission reduction 

requirements, EGU compliance with CAIR is equivalent to 

RACM/RACT. 

Demonstration

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

reasonably available controls measures for particulate 

emissions from stationary sources. 

Statewide RACT rules have been applied to all new sources 

locating in Ohio since that time. RACT requirements are 

incorporated into permits along with monitoring, recordkeeping, 

and reporting necessary to ensure ongoing compliance. Ohio 

EPA also has an active enforcement program to address 
 40 

violations discovered by field office staff. The Ohio RACT rules 

for particulate matter are found in OAC Chapter 3745-1720. 

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

Chapter 3745-1421), CAIR (OAC Chapter 3745-10922), and NOx

Reasonably Available Control Technology rules (OAC Chapter 

3745-11023) over the past five years. Emissions from EGUs 

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

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

for significant reductions in NOx, PM2.5, and SO2 until such time 

CSAPR is implemented. Then the CSAPR will provide for even 

greater reductions. 

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

contractors, performed a series of studies exploring control 

measures for reducing both ozone precursors and PM2.5 

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

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

papers24 researching different stationary source categories. The 

results were compiled into two reports25. The second consultant, 

Environ, investigated control options for mobile sources. The 

results were compiled into two reports26. The stationary and 

mobile source sectors (and associated control measures) were 

selected by the LADCO States based on several factors 

presented in the report (See Chapter 2). 

Photochemical modeling was then conducted (as part of 

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

the candidate control measures and a modeling report was 

developed27. Based on the results, the LADCO project team felt 

it would not be possible to advance the attainment date for 

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

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

 

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

21 http://www.epa.ohio.gov/dapc/regs/3745_14.aspx 

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

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

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

25 

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

easures_i_april_2005.pdf; 

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

easures_ii_june_2006.pdf 

26

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

control_measures_february_2006.pdf; 

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

control_measures_for_ladco_states_in_2009_and_2012_march_2007.pdf

27 http://www.ladco.org/reports/control/modeling/round4_modeling.pdf
 41 

approach) that attainment would be achieved in this area by 

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

have been reasonably possible or practicable for Ohio to 

develop RACT/RACM requirements, promulgate regulations 

and implement a control program prior to the projected 

attainment date. 

Requirement 2 of 6

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

demonstration SIPs for nonattainment areas to show reasonable further 

progress (RFP). 

Background

U.S. EPA’s 1997 Implementation Rule requires RFP only for 

any area which a State projects an attainment date beyond 

2014. If a State demonstrates attainment will occur by 2014 or 

earlier, U.S. EPA considers the attainment demonstration to 

demonstrate achievement of RFP. However, if a State attains 

the standard prior to the requirement to submit an attainment 

demonstration, 2012, an attainment demonstration is not 

required. 

Demonstration

The Steubenville-Weirton area has attained the standard prior to 

the deadline for submitting an attainment demonstration; and 

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

Requirement 3 of 6

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

actual emissions. 

Background

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

inventory of actual emissions in the area, including the 

requirement for periodic revisions as determined necessary. 40 

CFR 51.1008 requires such inventory to be submitted within 

three years of designation and requires a baseline emission 

inventory for calendar year 2005 or other suitable year to be 

used for attainment planning. 

Demonstration

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

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

July 18, 2008. It was then subsequently revised and 

resubmitted on June 7, 2010. 
 42 

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

CERR rule (i.e. emissions statements). Ohio EPA submitted its 

emissions statement SIP on March 18, 1994 which was 

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

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

and commits to submit, emission inventories (statements) every 

three years. 

Requirement 4 of 6

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

been fully implemented. 

Background

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

EPA NOx SIP Call required 22 states to pass rules that would 

result in significant emission reductions from large EGUs, 

industrial boilers, and cement kilns in the eastern United States. 

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

incorporated into permits along with monitoring, recordkeeping, 

and reporting necessary to ensure ongoing compliance. Ohio 

EPA also has an active enforcement program to address 

violations discovered by field office staff. Compliance is tracked 

through the Clean Air Markets data monitoring program. 

Beginning in 2004, this rule accounts for a reduction of 

approximately 31 percent of all NOx emissions statewide 

compared to previous uncontrolled years. The other 21 states 

also have adopted these rules. 

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

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

eastern states and the District of Columbia to significantly 

reduce emissions of NOx and SO2. CAIR replaced the NOx SIP 

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

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

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

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

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

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

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

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

Demonstration

Controls for EGUs under the NOx SIP Call formally commenced 

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

generally trending downward since 1998 with larger reductions 

occurring in 2002 and 2003. Data taken from the U.S. EPA 
 43 

Clean Air Markets web site, quantify the gradual NOx reductions 

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

CAA Amendments and the beginning of the NOx SIP Call Rule. 

Ohio developed the NOx Budget Trading Program rules in OAC 

Chapter 3745-1428 in response to the SIP Call. OAC Chapter 

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

and trade program based on an 85 percent reduction of NOx 

emissions from EGUs and a 60 percent reduction of NOx

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

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

superseded it as discussed above. Requirement 3 of 5 under 

Chapter 4 above discussed the reductions Ohio has seen as a 

result of CAIR. 

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

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

day emissions) stationary internal combustion engines. Ohio 

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

combustion engines, all used in natural gas pipeline 

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

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

anticipated. Completion of the compliance plan occurred by May 

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

Tier II Emission Standards for Vehicles and Gasoline Sulfur 

Standards 

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

significantly reduce emissions from cars and light trucks, 

including sport utility vehicles (SUVs). Under this proposal, 

automakers will be required to sell cleaner cars, and refineries 

will be required to make cleaner, lower sulfur gasoline. This rule 

will apply nationwide. The federal rules will phase in between 

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

reductions will be approximately 77 percent for passenger cars, 

86 percent for smaller SUVs, light trucks, and minivans, and 65 

to 95 percent reductions for larger SUVs, vans, and heavier 

trucks. The sulfur content of gasoline is estimated to be 

reduced by up to 90 percent. VOC emission reductions will be 

approximately 12 percent for passenger cars, 18 percent for 

smaller SUVs, light trucks, and minivans, and 15 percent for 

larger SUVs, vans, and heavier trucks. 

 

28 http://www.epa.ohio.gov/dapc/regs/3745_14.aspx 
 44 

Heavy-Duty Diesel Engines 

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

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

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

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

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

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

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

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

Clean Air Non-road Diesel Rule 

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

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

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

cleaner fuel standard similar to the highway diesel program. 

The new standards will cut emissions from non-road diesel 

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

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

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

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

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

2009. New engine standards take effect, based on engine 

horsepower, starting in 2008. Together, these rules will 

substantially reduce local and regional sources of PM2.5

precursors. 

Requirement 5 of 6

Acceptable provisions to provide for new source review. 

Background

Ohio has a longstanding and fully implemented New Source 

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

3745-3129. The Chapter includes provisions for the Prevention 

of Significant Deterioration (PSD) permitting program in OAC 

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

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

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

U.S. EPA as part of the SIP. 

Demonstration

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

for the closing of which credit was taken in demonstrating 

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

 

29 http://www.epa.ohio.gov/dapc/regs/3745_31.aspx 
 45 

reconstruct without meeting all applicable NSR requirements. 

Once the area is redesignated, Ohio EPA will implement NSR 

through the PSD program. 

Requirement 6 of 6

Assure that all existing control measures will remain in effect after 

redesignation unless the State demonstrates through modeling that the 

standard can be maintained without one or more control measures. 

Demonstration

Ohio commits to maintaining the aforementioned control 

measures after redesignation. Ohio hereby commits that any 

changes to its rules or emission limits applicable to PM2.5, SO2, 

and NOx as required for maintenance of the 24-hour PM2.5

standard in the Steubenville-Weirton area, will be submitted to 

U.S. EPA for approval as a SIP revision. 

Ohio, through Ohio EPA’s Legal office, has the legal authority 

and necessary resources to actively enforce any violations of its 

rules or permit provisions. After redesignation, it intends to 

continue enforcing all rules that relate to the emission of PM2.5

precursors in the Steubenville-Weirton area. 
 46 

CHAPTER SIX 

CONTINGENCY MEASURES 

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

Requirement 1 of 4

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

Demonstration

Ohio hereby commits to review its maintenance plan eight years 

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

Requirement 2 of 4

A commitment to expeditiously enact and implement additional contingency 

control measures in response to exceeding specified predetermined levels 

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

Demonstration

Ohio hereby commits to adopt and expeditiously implement 

necessary corrective actions in the following circumstances: 

Warning Level Response: 

A warning level response shall be prompted whenever the 98th

percentile 24-hour PM2.5 concentration of 35.5 μg/m3 occurs in a 

single calendar year within the maintenance area. A warning 

level response will consist of a study to determine whether the 

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

whether emissions appear to be increasing. The study will 

evaluate whether the trend, if any, is likely to continue and, if so, 

the control measures necessary to reverse the trend taking into 

consideration ease and timing for implementation as well as 

economic and social considerations. Implementation of 

necessary controls in response to a warning level response 

trigger will take place as expeditiously as possible, but in no 

event later than 12 months from the conclusion of the most 

recent calendar year. 

Should it be determined through the warning level study that 

action is necessary to reverse the noted trend, the procedures 

for control selection and implementation outlined under “action 

level response” shall be followed. 

Action Level Response: 

An action level response shall be prompted whenever a twoyear average of the 98th percentile 24-hour PM2.5 concentration 

of 35.0 μg/m3

 or greater occurs within the maintenance area. A 
 47 

violation of the standard (three-year average of the 98th

percentile 24-hour PM2.5 concentration of 35.0 μg/m3 or greater) 

shall also prompt an action level response. In the event that the 

action level is triggered and is not found to be due to an 

exceptional event, malfunction, or noncompliance with a permit 

condition or rule requirement, Ohio EPA in conjunction with the 

metropolitan planning organization or regional council of 

governments, will determine additional control measures 

needed to assure future attainment of the NAAQS for 24-hour 

PM2.5. In this case, measures that can be implemented in a 

short time will be selected in order to be in place within 18 

months from the close of the calendar year that prompted the 

action level. Ohio EPA will also consider the timing of an action 

level trigger and determine if additional, significant new 

regulations not currently included as part of the maintenance 

provisions will be implemented in a timely manner and will 

constitute our response. 

 Control Measure Selection and Implementation 

Adoption of any additional control measures is subject to the 

necessary administrative and legal process. This process will 

include publication of notices, an opportunity for public hearing, 

and other measures required by Ohio law for rulemaking. 

If a new measure/control is already promulgated and scheduled 

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

measure/control is determined to be sufficient to address the 

upward trend in air quality, additional local measures may be 

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

analysis to demonstrate the proposed measures are adequate 

to return the area to attainment. 

Requirement 3 of 4

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

an event. 

Demonstration

Contingency measures to be considered will be selected from a 

comprehensive list of measures deemed appropriate and 

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

measures will be based on cost-effectiveness, emission 

reduction potential, economic and social considerations or other 

factors that Ohio EPA deems appropriate. Ohio EPA will solicit 

input from all interested and affected persons in the 

maintenance area prior to selecting appropriate contingency 

measures. Because it is not possible at this time to determine 
 48 

what control measures will be appropriate at an unspecified time 

in the future, the list of contingency measures outlined below is 

not exhaustive. 

1) Diesel reduction emission strategies. 

2) Alternative fuel (e.g., liquid propane and compressed natural 

gas) and diesel retrofit programs for fleet vehicle operations. 

3) Tighter PM2.5, SO2, and NOx emissions offsets for new and 

modified major sources. 

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

suppression. 

5) Concrete manufacturing – upgrade wet suppression. 

6) Additional NOx RACT statewide. 

No contingency measure shall be implemented without 

providing the opportunity for full public participation during which 

the relative costs and benefits of individual measures, at the 

time they are under consideration, can be fully evaluated. 

Requirement 4 of 4 

A list of PM2.5, SO2, and NOx sources potentially subject to future additional 

control requirements. 

Demonstration

The following is a list of PM2.5, SO2, and NOx sources potentially 

subject to future controls. 

• ICI Boilers - SO2 and NOx controls; 

• EGUs; 

• process heaters; 

• internal combustion engines; 

• combustion turbines; 

• other sources greater than 100 tons per year; 

• fleet vehicles; 

• concrete manufacturers; 

• aggregate processing plants; 
 49 

CHAPTER SEVEN 

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public 

comment concerning the draft redesignation petition and maintenance plan in 

the widely distributed county publications. 

The public hearing to receive comments on the redesignation request was 

held on May 16, 2012, at the Steubenville Library – Schiappa Branch, 4141 

Mall Drive, Steubenville, Ohio. The public comment period closed on May 16, 

2012. Appendix F includes a copy of the public notice, comments received, 

and the transcript from the public hearing. 

 
 50 

CHAPTER EIGHT 

CONCLUSIONS

The Steubenville-Weirton 24-hour PM2.5 nonattainment area has attained the 

2006 24-hour NAAQS for PM2.5 and complied with the applicable provisions of 

the 1990 Amendments to the CAA regarding redesignations of PM2.5 

nonattainment areas. Documentation to that effect is contained herein. Ohio 

EPA has prepared a redesignation request and maintenance plan that meet 

the requirements of Section 110 (a)(1) of the 1990 CAA. 

Based on this presentation, the Steubenville-Weirton 24-hour PM2.5 

nonattainment area meets the requirements for redesignation under the CAA 

and U.S. EPA guidance. Ohio has performed an analysis that shows the air 

quality improvements are due to permanent and enforceable measures. 

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

significant regional SO2 and NOx reductions will ensure continued compliance 

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

The State of Ohio hereby requests that the Steubenville-Weirton 24-hour 

PM2.5 nonattainment area be redesignated to attainment simultaneously with 

U.S. EPA approval of the maintenance plan provisions contained herein. 
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