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 PM 2

. 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 PM 2

. 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.govSteubenville, 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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### 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 PM 2.5 monitoring ................................................................................................................... ....... 10 24-Hour PM 2.5 NAAQS ................................................................................................................ 10 Ambient data quality assured .................................................................................................. .... 11 Three complete years of data .................................................................................................. ... 11 Commitment to continue monitoring ........................................................................................... 1 7

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 PM 2.5 , SO 2 , and NO x sources ........................................................................................... 48

Chapter Seven Public participation .......................................................................................................... ............ 49

Chapter Eight Conclusions ................................................................................................................... ............. 50ii 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 . 26Table 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 SO 2 and NO x EGU Emissions Between 2008 and 2009. ............. 29 Table 11 Reductions in SO 2 and NO x EGU Emissions Between the First Half of 2008 and 2010.... ......................................................................................................... 30 Table 12 Jefferson County, Ohio PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2025 (tpy) – Without CAIR. ............... 32 Table 13 Brooke County, West Virginia PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2025 (tpy) – With CSAPR. ....... 32 Table 14 Hancock County, West Virginia PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2025 (tpy) – With CSAPR. ....... 32 Table 15 Steubenville-Weirton Area PM 2.5 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 NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2025 (tpy) – With CAIR ..................... 33 Table 17 Brooke County, West Virginia NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2025 (tpy) – With CSAPR ........ 33 Table 18 Hancock County, West Virginia NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2025 (tpy) – With CSAPR. ....... 34 Table 19 Steubenville-Weirton Area NO x 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 SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2025 (tpy) – With CAIR ..................... 34iii Table 21 Brooke County, West Virginia SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2025 (tpy) – With CSAPR ........ 35 Table 22 Hancock County, West Virginia SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2025 (tpy) – With CSAPR ........ 35 Table 23 Steubenville-Weirton Area SO 2 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 PM 2.5 Nonattainment Area D LADCO Technical Support Document and WVDAQ Nonroad Modeling E Incomplete Monitoring Data Substitution Analysis F Public Participation Documentationiv This page left intentionally blankREDESIGNATION REQUEST AND MA INTENANCE PLAN FOR THE OHIO PORTION OF THE STEUBENVILLE-WEIRTON OH-WV 24-HOUR PM 2.5 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 PM 2.5 1 National Ambient Air Q uality Standard (NAAQS) to develop State Implementation Plans (SIPs) to expeditiously attain and maintain the standard. The United Stat es Environmental Protection Agency (U.S. EPA) revised the NAAQS for particu late matter in 2006. In 2006, U.S. EPA strengthened the pr imary 24-hour PM 2.5 NAAQS from 65 μg/m 3 to 35 μg/m 3 , and retained the current primary annual PM 2.5 NAAQS at 15.0 μg/m 3

. The revised 24-hour PM 2.5 standard was published on October 17, 2006 (71 FR 61144) and became effective on Dece mber 18, 2006. The standard is based on the 3-year average of the 98 th percentile of 24-hour concentrations.

On November 13, 2009, U.S. EPA pr omulgated (74 FR 58688) the initial PM 2.5 nonattainment areas desi gnations for the 24-hour PM 2.5 standard across the country (effective December 14, 2009). Unlike Subpart 2 of the CAA Amendments of 1990 which defi ned five ozone nonattainment classifications for the areas that exceed the NAAQS ba sed on the severity of the ozone levels, PM 2.5 nonattainment designations are simply labeled “nonattainment.” The CAA Amendm ents require states with PM 2.5 nonattainment areas to submit a plan with in three years of the effective date of the designations (December 14, 2012) detailing how the PM 2.5 standard will be attained by December 14, 2014. Howe ver, areas that attain before the required date for submitting a plan ma y 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 pr ovided 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 c hemicals, metals, soil or dust particles, and allergens (such as fragments of pollen or mold spores). Fine particle pollution or PM 2.5 describes particulate matter that is 2.5 micrometers in diameter and smaller - 1/30th the diameter of a human hair. Fine pa rticle pollution can be emitted directly or formed secondarily in the atmosphere.2 redesignated from nonattain ment to a ttainment:

• A determination that the area has attained the PM 2.5 standard.

• An approved State Implementati on Plan (SIP) for the area under Section 110(k).

• A determination that the improv ement 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 Sectio n 110 and Part D requirements have been met.

This document addresses each of t hese requirements, and provides additional information to support cont inued compliance with the 24-hour PM 2.5 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 PM 2.5 standard 2 . The proposed determination is based upon quality assured, quality controlled, and certified ambient air monitoring data showing the area has monitored attainment bas ed on 2008 through 2010 data.

The Steubenville-Weirton area has previously been subject to nonattainment area rulemakings for the 1997 fine particl e NAAQS. Ohio wa s 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 PM 2.5 standard of 65 μ g/m3. In April, 2012, Ohio EPA submitted a redesignation request and maintenance plan for the Steubenville-Weirton 1997 annual standard nonattainment area.

Geographical Descrip tion and Background The current Steubenville -Weirton nonattainment area is located on the eastern border of Ohio and includes the following c ounties: 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 PM 2.5 designations, U.S. EPA designated the Steubenville-Weirton area nonat tainment for the 35 μ g/m 3 24-hour standard, and Ohio EPA is required to develop a pl an to reduce oxides of nitrogen (NO x ), sulfur dioxide (SO 2 ) and direct PM 2.5 emissions and to demonstrate that the area will meet the federal 24-hour air qual ity 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 PM 2.5 components are primary particles (organic carbon, crustal material , and elemental carbon), SO 2 and NO x , which were included in the attain ment demonstration analysis for the 1997 annual PM 2.5 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 PM 2.5 (although controls for VOCs have been implemented for ozone nonatta inment). This is consistent with U.S. EPA’s “Clean Ai r Particle Implementati on Rule” [74 FR 20856] (hereafter referred to as “1997 Im plementation Rule”). In the 1997 Implementation Rule U. S. EPA presumes NH 3 emissions are not a PM 2.5 attainment plan precursor and that St ates are not required to address VOC unless the State or U.S. EPA makes a technical demon stration that emissions of VOCs significantly contri bute to nonattainment of the PM 2.5 standard. This is also consistent with U.S. EPA’s “I mplementation Guidance for the 2006 24- Hour Fine Particle (PM 2.5 ) National Ambient Air Quality Standards (NAAQS)” memorandum issued on March 2, 2012 (hereafter referred to as “2006 Implementation Memo”). In this me morandum, U.S. EPA recommends that “the projected attainment inventory for the nonattainment area includes direct PM 2.5 , SO 2 , presumptively NO x , as well as other precursors that have been determined to be significant through t he area’s SIP development process.” Furthermore, the 2006 Implementation Memo indicates that U.S. EPA believes the overall framewor k and policy approach of the 1997 Implementation Rule “continues to pr ovide effective and appropriate guidance on the EPA’s interpretation of the general statutory requirements that states should address in their SI Ps” and that they are “rel evant to t he statutory requirements” for the 2006 24-hour PM 2.5 standard.

This document is intended to support Ohio’s request that the Ohio portions of the Steubenville-Weirt on area be redesignated from nonattainment to attainment for the 24-hour PM 2.5 standard. In addition, the State of West Virginia may also submit a request fo r their respective portions of the Steubenville-Weirton area.

Status of Air Quality PM 2.5 complete quality-assured ambient air quality monitoring data for the three (3) years, 2008 through 2010, demonstr ate that the air quality has met the NAAQS for 24-hour PM 2.5 in this nonattainme nt area. The NAAQS attainment, accompanied by decreases in emission levels discussed in Chapter Four, supports a redesignation to attainm ent for the SteubenvilleWeirton area based on the re quirements in Section 107(d)(3)(E) of the CAA as amended.4 

### CHAPTER TWO

Requirements for Redesignation U.S. EPA has published detailed gui dance in a document entitled Procedures for Processing Requests to Redesignate Areas to Attainment (redesignation guidance), issued Septem ber 4, 1992, to Regional Air Directors. The redesignation request and maintenance plan are based on the redesignation guidance, supplemented wit h additional guidance received from staff of U.S. EPA Region 5.

Below is a summary of each redesignat ion 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 compon ent relies on ambient air quality data. The data that are used to demonstrate attainment should be the product of ambient monitori ng that is representative of the area of highest concentration . The data should be collected and quality-assured in acco rdance 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 nece ssary” for particulate matter redesignations. Appendix C and Appendix D contai ns the most recent modeling results sho wing future attainment and maintenance are provided. C hapter Three discusses this requirement in more detail a nd provides the attainment demonstration.

ii.) Permanent and enforceable improvem ent in air quality (CAA Section 107(d)(3)(E)(iii)) The state must be able to reas onably attribute the improvement in air quality to emission r eductions which are permanent and enforceable. The stat e should estimate the percent reduction achieved from federal measures as well as control measures that have been adopted and impl emented by the state.

It was not necessary for Ohio to adopt or implement control measures for these counties bey ond the federal measures.

Ohio EPA has adopted several rule s recently that will have an impact on statewide PM 2.5 emissions in the future:5 • Clean Air Interstate Rule (CAIR)

• NO x SIP Call Rules

Ohio was also subject to a Federal Implement ation Plan under the CAIR replacement rule, the Cross-State Air Pollution Rule (CSAPR) that could have result ed in even greater reductions than the CAIR program. Howeve r, on December 30, 2011, the D.C. Circuit Court stayed CSAPR and ordered U.S. EPA to continue administering CAIR pendi ng the court’s resolution.

In addition, since the initial designations were made federally enforceable consent decrees have resulted in reductions in emissions from utilities withi n 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 requirem ents (CAA Section 107(d)(3)(E)(v)) For purposes of redesignatio n, a state must meet all requirements of Section 110 and Part D that were applicable prior to submittal of the co mplete redesignation request.

Subpart 1 of Part D consists of general requirements applicable to all areas which are desig nated 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 PM 10 ). However, for the purpose of implementing the PM 2.5 standard, U.S. EPA’s 1997 Implementation Rule st ated Subpart 1, rather than Subpart 4, is appropriate for the purpos e of implementing PM 2.5 .[72 FR 20589]

Section 110(a) requirements Section 110(a) of Title I of the CAA contains the general requirements for a SIP. Sect ion 110(a)(2) provides that the implementation plan submi tted 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 li mitations and other control measures, means or techniques necessary to meet the requirements of the CAA; pr ovide for establishment and operation of appropriate dev ices, 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 any6 stationary source within the areas covered by the plan; include provisions for the implementation of Part C, prevention of significant det erioration (PSD) and Part D, NSR permit programs; includ e criteria for stationary source emission control measures, monitoring, and reporting; include provisions for air quality modeling; and provide for public and loca l agency participation in planning and emission contro l rule development. In Ohio’s December 5, 2007 and September 4, 2009 infrastructure SIP submissions , Ohio verified that the State fulfills the r equirements of Section 110(a)(2) of the Act.

Section 110(a)(2)(D) also requi res 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 SO 2 and NO x emissions from large el ectric generating units (EGU). Ohio has met the r equirements of the federal CAIR to reduce NO x and SO 2 emissions contributing to downwind states. On Febr uary 1, 2008, U.S. EPA approved Ohio’s CAIR program , which can be found in Ohio Administrative Code (OAC) Chapter 3745-109 3 . On July 6, 2011, U.S. EPA finaliz ed a replacement to the CAIR program, the CSAPR. CS APR could further assist States in addressing their obli gations regarding regionally transported pollution by pr oviding reductions in NO x and SO 2 emissions in 2012 and 2014. However, on December 30, 2011, the D.C. Circuit Court stayed CSAPR and ordered U.S. EPA to cont inue administering CAIR pending the court’s resolution.

iv.) Section 172(c) requirements This Section contains general requirements for nonattainment plans. The requirements for r easonable further progress, identification of certain em issions increases, and other measures needed for attain ment will not apply for redesignations because they onl y have meaning for areas not

3 http://www.epa.ohio.gov/dapc/regs/regs.aspx#3745-1097 attaining the standard. The r equirements for an emission inventory will be satisfied by t he 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 redesignat ion 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) stipulat es that for an area to be redesignated, U.S. EPA must fully approve a maintenance plan that meets the requirement s 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 contai n 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 Ad ministrator deems necessary to ensure prompt correction of any violation of the NAAQS. At a minimum, the contingency m easures 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 r equired under 40 CFR Part 51,8 Subpart A. We expect that for m any nonattainment areas, these annual inventories will serve as an appropriate starting point for the emission inventories used fo r SIP development. In contrast with the 1997 annual PM 2.5 NAAQS, where states rely only on annual inventories in the impl ementation process, the 2006 24- hour PM 2.5 NAAQS is designed to protect against peak exposures. Thus, for the 2006 24-hour PM 2.5 NAAQS, there are some circumstances in which EPA believes that seasonal inventories may be useful fo r SIP planning purposes. For example, we have observed that in some nonattainment areas, all of the highest fine particle conc entrations 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 ye ars, we recommend that states develop a seasonal inventory and that they use this inventory for SIP planning purposes....

Ohio EPA analyzed the PM 2.5 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 We st Virginia Division of Air Quality (WVDAQ), it was determined that an annual invent ory would be sufficient for SIP planning, and that a seasonal inventory would not be required.9 Figure 1 – Steubenville-Weirton 24-hour PM 2.5 Exceedances

Chapter Six discusses this requirement in more detail. 1 3 4

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### CHAPTER THREE

PM 2.5 MONITORING CAA Section 107(d)(3)(E)(i)

Requirement 1 of 4 A demonstration that t he NAAQS for 24-hour PM 2.5 , as published in 40 CFR 50.7, has been attained.

Background There are 5 monitors measuring PM 2.5 concentrations in this nonattainment area. Two monito rs in Jefferson County, Ohio 4

, two in Brooke County, WV and one in Hancock County, WV. A listing of the design values base d on the three-year average of the annual mean concentrations from 2008 through 2010 and a listing of the design values base d on the three-year average of the 98 th percentile are shown in Table 1. The locations of the monitoring sites for this nona ttainment area are shown on Figure 2.

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The following information is take n from U.S. EPA's "Guidelineon Data Handling Conventions for the PM NAAQS," U.S. EPA454/R-99-008, April 1999.

In accordance with the CAA Am endments, three complete years of monitoring data are required to demonstrate attainment at a monitoring site. The 24-hour PM 2.5 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 μ g/m 3 . While calculating design values, one decim al place must be carried in the computations, with final va lues rounded to the nearest 1
μ g/m 3 . Decimals 0. 5 or greater are rounded up, and those less than 0. 5 are rounded dow n, so that 35.349 μ g/m 3 is the largest concentration that is le ss than, or equal to 35 μ g/m 3 . Values at or below 35 μ g/m 3 meet the standard; va lues greater than 35
μ g/m 3 exceed the standard. An area is in compliance with the 24-hour PM 2.5 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 des ign value for the area is the highest design value among all sites in the area.

Table 1 shows the monitoring da ta for 2008 - 2010 that were retrieved from t he 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 2008-2010 Site County 2008 2009 2010 2008 2009 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 moni tor 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/air s/airsaqs/index.htm

The design value calculated for the Steubenvill e-Weirton area demonstrates that the 24-hour PM 2.5 NAAQS has been attained. However, one monitor site in Jefferson County (site 39-081-0017), did not comply with the 75% data captur e requirement for the 2008-2010 period. Specifically, the fourth quarter (October, November, and December) of 2008 has only 73% c apture. This monitoring site experienced instrument malfuncti on during the low percentage capture missing a total of 8 missing 1-in-3 day PM2.5 FRM runs.

Under 40 CFR Part 50, A ppendix N, the use of less than complete data may be approved by U.S. EPA consi dering such factors as monitoring site closures/moves, monitoring diligence, and nearby concentrations in determining whether to use such dat a. 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 imputati ons 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 st atistical analyses performed to show that the three-year av erage (2008 to 2010) of the 98 th percentile14 24-hour values, based on missi ng data imputations, is 30 μ g/m 3 , below the 35 μ g/m 3 24-hour standard.

Table 2 shows site 39-081-0017 bef ore and after the imputation of missing data. Also the “new” site (with imputed values) shows a passing 24-hour design va lue for 2008 to 2010 of 30 μ g/m 3

.

Table 2 - 98 th 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 PM 2.5 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

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‐ 2006 2005

‐ 2007 2006

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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

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heet:17 Requirement 4 of 4 A commitment that once redesignated, th e state will continue to operate an appropriate monitoring network to verify the maintenance of the attainment status.

Demonstration Ohio EPA commits to continue monitoring PM 2.5 levels at the Ohio sites indicated in Figur e 2 and Table 1. Ohio EPA will consult with U.S. EPA Region 5 pr ior to making changes to the existing monitoring network, s hould changes become necessary in the future. Ohio EPA will continue to quality assure the monitoring data to meet the requ irements of 40 CFR 58 and all other federal requirem ents. Connection to a central station and updates to the Ohio EPA web site 5 will provide real time availability of the data and knowledge of an y exceedances. Ohio EPA will enter all data into AQS on a timely basis in accordance with federal guidelines.

5 www.epa.ohio.gov/dapc18 

### CHAPTER FOUR

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

U.S. EPA’s redesignation guidance require s the submittal of a comprehensive inventory of PM 2.5 precursor emissions (primary particles (organic carbon, crustal matter, and elemental carbon), SO 2 and NO x 6 ) representative of the year when the area achieves attainment of the 24-hour PM 2.5 air quality standard. Ohio also must demonstrate that the improvement in air quality between the year that viol ations occurred and the ye ar that attainment was achieved is based on permanent and enfo rceable emission reductions. Other emission inventory related requirements include a projection of the emission inventory to a year at least 10 year s following redesignati on; a demonstration that the projected level of emissions is sufficient to main tain the 24-hour PM 2.5 standard; and a commitment to provide future updates of the inventory to enable tracking of emission levels duri ng the 10-year main tenance 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 Oh io’s portion of the Steu benville-Weirton area. Specific emissions data are provided for all counties, including those in Ohio and West Virginia. West Virginia em issions data were obtained though the West Virginia Department of Environment al 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 pr epared by the Brooke-Hancock-Jefferson Metropolitan Planning Commission (BHJ ) and the Ohio Department of Transportation (ODOT), with data provid ed by Ohio EPA, West Virginia Department of Transportation (WVDOT), and WVDEP.

Requirement 1 of 5 A comprehensive emission inventory of PM 2.5 , SO 2 and NO x completed for the base year.

Background The 2005 periodic inv entory has been identified as one of the preferred databases for SIP dev elopment and coincides with nonattainment air quality in t he Steubenville-Weirton area.

Periodic inventories, which incl ude emissions from all sectors are prepared every three years by Ohio EPA. Ohio’s 2005

6 VOC and NH 3 are not addressed.19 emissions data for all sources (E lectrical Generating Unit (EGUPoint); Non-Electrical Generat ing Unit (Non-EGU); Non-road Mobile (Non-road); Other Area (A rea); and Marine; Aircraft; Rail (MAR)) are derived from this invent ory. Ohio’s point source data derived from this periodic invent ory 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 MA R and Area is derived from the 2005 National Emissions Inventory (NEI) while Non-road emissions are derived from NO NROAD modeling conducted by WVDAQ.

Demonstration Ohio’s 2005 inventory is used as the base year for the purpose of this submittal and was submi tted to U.S. EPA with Ohio’s PM 2.5 attainment demonstration SI P 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 PM 2.5, SO 2 and NO x for 2005 are identified under Requirem ent Three of this Chapter.

Requirement 2 of 5 A projection of the emissi on inventory to a year at least 10 years following redesignation.

Background Ohio EPA prepared a comprehensive inv entory for the Ohio portion of the Steubenville-Weirton area includ ing area, mobile, and point sources for PM 2.5 , SO 2 and NO x for base year 2005. The 2005 inventory was submitt ed to U.S. EPA on July 18, 2008 as part of Ohio’s PM 2.5 attainment demonstration SIP for this area. The information below describes the procedures Ohio EPA used to generate the 2005 base year inv entory and to develop SIP-ready modeling inventories and future year projections (Pechan Report 7 ) based on a 2005 base year inventory. The report by Pechan generated future year estimates of annual emi ssions 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/LA DCO%202005%20Base%20Yr%20Growth%20and%20Co ntrols%20Report_Final.pdf20 for use in the air quality analyses. These processed modeling inventories have been identif ied as the correct iter ation of the inventory for use in the redesignation. In this document, references to LADCO include the Midwest Regional Planni ng Organization. Note, that the onroad mobile source sector was addressed by specific PM 2.5 and NO x 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 PM 2.5 and NO x necessitate an emissions inventory analysis. Ohio EPA in consultation with U.S. EPA determined mobile sources are insignific ant contributors for SO 2 . Consistent with Ohio EPA’s attainment demonstration, Ohio EPA continues to consider mobile source SO 2 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 r egional highway emissions PM 2.5 and NO x 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 database 8

.

• Biogenic emissions are not included in these summaries.

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

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

• Area source and MAR emissions were compiled from the 2008 NEI and 2015 and 2025 proj ections were grown using Workforce data.

• Mobile source emissions we re 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/acidrain21 • Non-EGU point source information was compiled from West Virginia’s 2008 act ual emissions inventory and 2015 and 2025 projections were grown using Workforce data.

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

Demonstration

On-Road Emission EstimationsThe ODOT, Division of Transportation System DevelopmentModeling and Forecasting Sect ion and the Brooke-HancockJefferson Metropolitan Planning Commission (BHJ) defined the underlying planning assump tions for the annual PM 2.5 on-road mobile source emission invent ories 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 rang e planning tool to evaluate the transportation system including de termination of locations where additional travel capacity may be needed and to determine the infrastructure requirements necessa ry to meet that need. It is also used as a tool for air qualit y 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 (V MT), 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 Feder al Register notice 9 of availability on March 2, 2010, to approve MOVES2010 (Motor Vehicle Emissions Simulator), hereafte r referred to as MOVES. Upon publication of the Federal Regi ster notice, MOVES became U.S. EPA’s approved motor vehicle emission factor model for estimating VOCs, NO x , CO, PM 10 and PM 2.5 and other pollutants and precursors from cars, trucks, motorcycles, and buses by state and local agencies. MO VES is a computer program designed by the U.S. EPA to es timate air pollution emissions

9 http://www.regulations.gov/search/Regs/ home.html#documentDetail?R=0900006480ab1f9822 from mobile sources. MOVES r eplaces U.S. EPA’s previous emissions model for on-road m obile 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 emissi on models. MOVES represents the Agency’s most up-to-date assessm ent 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 m ade to the Agency by the National Academy of Sciences.

U.S.EPA believes that MOVES s hould be used in ozone, CO, PM, and nitrogen dioxide SIP devel opment 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 avail able when a SIP is developed. Regarding transportation conformi ty, U.S. EPA and U.S. DOT intend to establish a two-year grace period before MOVES is required for new transportati on conformity analyses.

The MOVES more detailed approa ch (when compared with the previous MOBILE model) to mode ling allows U.S. EPA to easily incorporate large amounts of in-u se data from a wide variety of sources, such as data from vehicle inspection and maintenance (I/M) programs, remote sens ing device (RSD) testing, certification testing, portabl e emission measurement systems (PEMS), etc. This approach also allows users to incorporate a variety of activity data to bette r 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 pr ovides users much greater flexibility regarding output choice s. Unlike earlier models which provided emission factors in gr ams-per-mile in fixed output formats, MOVES output can be expressed as total mass (in tons, pounds, kilograms, or gram s) or as emission factors (grams-per-mile and in some ca ses grams-per-vehicle). Output can be easily aggregated or disaggregated to examine emissions in a range of scales, from national emissions impacts23 down to the emissions impacts of individual transportation projects. The database-centered des ign also allows U.S. EPA to update emissions data incorporat ed in MOVES more easily and will allow users to in corporate a much wider array of activity data to improve estimation of loca l emissions. For example, the improvements in MOVES will allow project-level PM2.5 emissions to be estimated.

BHJ utilized U.S.EPA’s emi ssions model MOVES to develop emissions factors for SO 2 , NO x and PM 2.5 . Further details on the use of MOVES are found on Append ix 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 y ear is 2000. The model uses comparable average daily tra ffic count data, updated socialeconomic variables for each of the analysis years by either updating existing or known la nd use commitment for 2008, 2009, and 2014, or proj ected 2014 and 2020 va riables based on a straight line extrapolation bet ween 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 TI P 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 st udy area. Travel forecasting procedures require the user deli neates the TDM study area into geographic areas called Traffic A nalysis Zones. Typically, these Zones are based on factors su ch as land use, area types (urban, suburban or rural), or polit ical government units such as cities, villages, or townships. The BHJ collects and reviews the TDM independent variables that c haracterize 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 requirement s of the BHJ travel demand24 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 A nalysis Zone (TAZ) level, and originate in the 2000 Census of Populati on and Housing. Base year 2005 and future yare data for each variable are developed through various methods. T he MOVES model generated the emissions factor files for bas e year 2005 and attainment year 2008 representing transportati on improvement programs implemented in the BHJ Region . The model also generated emission factors for two futu re year scenarios 2015 and 2025.

The single season approach fo r temperature and relative humidity uses weather data collected by the National Oceanic and Atmospheric Administration (N OAA) 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 vari ety of sources of local data to both improve and confirm the accura cy 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 gen erate VMT by hour, VMT by speed distribution, and VMT by fa cility type. These tables are then included as input into MOVES.

On-Road Mobile Emission Estimations Tables 2 through 8 contain the result s of the emissions analysis for the appropriate years. All emissions esti mations are expressed in tons per year (tpy).25Table 3 - Jefferson County, OH, Emissions Estimations for OnRoad Mobile Sources

2005 2008 2015 2025

PM 2.5 (tpy) 73.17 60.97 31.88 16.49

NO x (tpy) 2105.85 1758.04 870.17 322.71

SO 2 (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 Emi ssions Estimations for On-Road Mobile Sources

2005 2008 2015 2025

PM 2.5 (tpy) 73.17 60.97 31.88 16.49

NO x (tpy) 2105.85 1758.04 870.17 322.71

SO 2 (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

PM 2.5 (tpy) 19.41 14.42 6.97 4.34

NO x (tpy) 540.40 412.02 174.71 62.47

SO 2 (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

PM 2.5 (tpy) 18.63 13.51 6.53 4.10

NO x (tpy) 482.75 360.25 149.00 52.09

SO 2 (tpy) 6.58 1.92 1.36 1.10

Annual VMT 180,767,718 177,219,697 180,298,107 174,534,36126 Table 7 – Summary of West Virg inia Emissions Estimations for On-Road Mobile Sources

2005 2008 2015 2025

PM 2.5 (tpy) 38.04 27.93 13.5 8.44

NO x (tpy) 1023.15 772.27 323.71 114.56

SO 2 (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 Estimation s Totals for On-Road Mobile Sources for the Steubenville-Weirton Area

2005 2008 2015 2025

PM 2.5 (tpy) 111.21 88.9 45.38 24.93

NO x (tpy) 3129 2530.31 1193.88 437.27

SO 2 (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 perc entage of mobile emissions of all emissions, for each pollutant in the entire Steubenvi lle-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

NO x SO 2 PM 2.5

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%

NO x constitutes less than five percent (4.67%) of the area’s total NO x emissions in the 2015 horizon year and less than three percent (2. 49%) of the area’s total NO x emissions in the 2025 horizon year.

SO 2 constitutes less than one percent (<1%) of the area’s total SO 2 emissions in the 2015 and 2025 horizon years.

PM 2.5 constitutes less than two percent (1.66%) of the area’s total PM 2.5 emissions in the 2015 horizon year and27 less than one percent (0.92% ) of the area’s total PM 2.5 emissions in the 2025 horizon year.

Therefore, the Ohio EPA is herein making a finding that the area’s highway emissions for PM 2.5 , NO x , and SO 2 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, NO x , and SO 2 . 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, NO x , and SO 2 for a PM 2.5 NAAQS violation to occur. Moreover, Ohio EPA dem onstrates that the percentage of motor vehicle emissions in the contex t of the total SIP inventory, the current state of air quality as determined by monitoring data, the absence of SIP motor vehicle contro l measures, and historical trends and future projections of the growth of motor vehicle emissions, are evidence enough to consider mobile source PM2.5, NO x , and SO 2 insignificant contribut ors to fine particles.

Requirement 3 of 5 A demonstration that t he projected level of emissions is sufficient to maintain the PM 2.5 standard.

Background In consultation with U.S. EPA, Oh io 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 bas ed on the U.S. EPA MOVES model. The analysis is described in more detail in Appendix C. All pr ojections were made in accordance with “Procedures for Preparing Emissions Projections” U.S. EPA-45/4-91-019. As di scussed 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 r equired 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 ar ea 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 consis tent with mode ling performed in the future. Appendix D contains LADCO’s technical support document detailing the analysis used to project emissions (Base M 10 ).

• For the 2008 attainment year emissions were grown from the 2005 LADCO modeling inv entory, using LADCO’s growth factors, for all se ctors 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 grow th factors, for all sectors except non-EGU PM 2.5 . The 2025 maintenance year is based on emissions estimate s from the 2018 LADCO modeling, for all sect ors except non-EGU PM 2.5 . NonEGU PM 2.5 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 regardi ng 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. Circ uit 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 em issions projections will be conservative.

On March 10, 2004, the U.S. EPA promulgated the CAIR. Beginning in 2009, U.S. EPA’s CA IR rule requires EGUs in 28 eastern states and the District of Columbia to significantly reduce emissions of NO x and SO 2 . 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.php29 NO x 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. Re visions to the CAIR SIP were again submitted on July 15, 2009. The revised CAIR SIP was approved as a direct final acti on on September 25, 2009 (74 FR 48857). As a result of CAIR, U.S. EPA projects that in 2009 emissions of NO x will decrease from a baseline of 264,000 tons per year to 93,000 tons per year while in 2010 emissions of SO 2 will decrease from a baseline of 1,373,000 tons per year to 298,000 tons per year, within Oh io. And by 2015 U.S. EPA projects emissions of NO x will decrease to 83,000 tons per year while emissions of SO 2 will decrease to 208,000 tons per year, within Ohio 11 . On December 23, 2008, U.S. EPA’s CAIR program was remanded without va catur by the D.C. Circuit Court.

As can be seen in Tabl e 9 below, Ohio has seen a significant decline in the 264, 000 tons of NO x and 1,373,000 tons of SO 2 emitted in 2005. In 2008 and 20 09 facilities began preparing for and implementing control programs to address CAIR 12 and consent decrees.

Table 10 - Reductions in SO 2 and NO x EGU Emissions Between 2008 and 2009
SO 2 NO x 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 Tracking 13

Significant reductions also occurr ed regionally and nationally as can be seen from the abov e table. Data is al so available for the first two quarters of 2010, the year SO 2 reductions are to be implemented under CAIR:

11 http://www.epa.gov/CAIR/oh.html 12 Under CAIR, NOx reductions are to occur begin ning in 2009 while SO2 reductions are to occur beginning in 2010. 13 http://www.epa.gov/airmarkets/quarterlytracking.html30 Table 11 – Reductions in SO 2 and NO x EGU Emissions Between the First Half of 2008 and 2010
SO 2 NO x 2008 (1 st half) 2010 (1 st half) Change 2008 (1 st half) 2010 (1 st 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 Tracking 14

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

“Based on emissions monito ring data, EPA has observed substantial reductions in SO 2 emissions from 2005 to 2009 and in the first two quarters of 2010 as companies installed more controls, electric demand declin ed, 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 agree ment 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 PM 2.5 attainment in this nonattainment area and throughout Ohio.

On July 6, 2011, U.S. EPA finali zed a replacement to the CAIR program, the CSAPR. CSAPR woul d preserve those initial reductions achieved under CA IR and provide even greater reductions in NO x and SO 2 emissions in 2012 and 2014, ahead of the 2015 CAIR Phase 2. As a result of CSAPR, U.S. EPA projected that in 20 12 emissions of NO x will decrease to 90,842 tons per year and in 2014 to 85,744 tons per year while SO 2 will decrease to 304,022 tons per y ear 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, t he 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 be lief 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.htm31 emissions is sufficient to maintain the 24-hour PM 2.5 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 PM 2.5 standard. Therefore, Ohio EPA performed an initial comparison of the inventor ies for the base year and maintenance years. Mobile so urce emission inventories are described in Appendix C.

Sectors included in the follow ing tables are: Electrical Generating Unit (EGU-Point); N on-Electrical Generating Unit (Non-EGU); Non-road Mobile (N on-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 be low the 2008 atta inment year totals.

Demonstration

PM 2.5

The 2005 and 2 008 actual PM 2.5 emissions data below generally contains particulate fraction emi ssions only and not the condensable fractions as Ohio EPA did not have a consistent r eporting requirement during those years. U.S. EPA IP M modeling was used to generate future year EGU emissions with t he CAIR program. The IPM modeling added additional PM 2.5 condensable emissions into future years. Therefore, comparing base and atta inment year emissions with the future year predictions is not accura te in the IPM CAIR modeling. This step leads to a false perc eption of significant PM 2.5 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 ev aluate future year emissions that include the CAIR program, because of th is flaw it will be more accurate and appropriate for the purposes of PM 2.5 to evaluate future year emissions without t he CAIR program.32 Table 12 - Jefferson County, Ohio PM 2.5 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 PM 2.5 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 PM 2.5 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 33.4233 Table 15 – Steubenville-Weirton Area PM 2.5 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 PM 2.5 TOTAL 2,946.39 2,813.98 2,740.52 2,698.00 115.98

NO x
Table 16 - Jefferson County, Ohio NO x Emission Inventory Totals for Base Year 2005, Estima ted 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 NO x 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 1,031.61 571.5034 Table 18 - Hancock County, West Virginia NO x 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 NO x 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

SO 2
Table 20 - Jefferson County, Ohio SO 2 Emission Inventory Totals for Base Year 2005, Estima ted 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 90,566.9435 Table 21 - Brooke County, West Virginia SO 2 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 SO 2 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 SO 2 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 90,821.2436 PM 2.5 , NO x , and SO 2

Table 24 - Steubenville-Weirt on 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 PM 2.5 2,813.98 2,740.52 73.46 2,698.00 115.98 NO x 43,349.31 25,563.36 17,785.95 17,533.17 25,816.14 SO 2 138,266.82 74,806.60 63,460.22 47,445.58 90,821.24

As shown in the table above (Table 23), PM 2.5 emissions in the nonattainment area are projected to decrease by 73.46 tpy in 2015 and 115.98 tpy in 2025. NO x emissions in the nonattainment area are projected to decrease by 17,785.95 tpy in 2015 and 25,816.14 tpy in 2025. SO 2 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-EG U source emissions show a decrease. Cleaner vehicles an d fuels are expected to be in place in 2009 and 201 8, and the CSAPR will be implemented in 2012 and 2014 and these programs should cause an overall drop in all three pollutants emi ssions. Decreases from U.S. EPA rules covering EGUs, Tier 2 Mo tor Vehicle Emissions Standards and Gasoline Sulfur C ontrol Requirements 16 , Highway HeavyDuty Engine Rule 17 , and the Non-Road Diesel Engine Rule 18 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 sc rubbers, and a restricted SO 2 allowable emission rate was in corporated into a federally enforceable permit demonstrati ng they will not cause or contribute to a violation of a NAAQS and/or Prevention of Significant Deterioration incr ement 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 enforc eable consent decree to operate

16 http://www.epa.gov/fedrgstr/EPA- AIR/2000/February/Da y-10/a19a.htm 17 http://www.epa.gov/fedrgstr/EPA-AI R/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 fa cility’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 SO 2 emissions in the future. The permit-to-install these scrubbers will require a restricted SO 2 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 bet ween the year violations occurred and the year attainment wa s achieved is bas ed on permanent and enforceable emission r eductions and not on temporary adverse economic conditions or unusually favorable meteorology.

Background Ambient air quality data fr om all monitoring sites indicate that air quality met the NAAQS for PM 2.5 in 2008-2010. U.S. EPA’s redesignation guidance (p 9) st ates: “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 c ause a violation of the NAAQS.”

Demonstration Permanent and enforceable reductions of PM 2.5 , NO x , and SO 2 emissions have contributed to the attainment of the 24-hour PM 2.5 standard. Some of these reducti ons were realized due to the application of tighter federal standar ds on non-road diesel vehicles (Clean Air Non-road Diesel Rule) and t he application of tighter federal standards on new vehicles. Also Title IV of the CAA, the NO x SIP Call, CAIR, and federal consent decrees required the reductions of SO 2 and NO x emissions from utility source s. Reductions achieved are discussed in greater de tail under Chapter Five.38 Table 25 - Steubenville-Weirton Area Comparison of 2005 Base Year and 2008 Attainment Ye ar On-Road, Non-Road and EGU Reductions 2005 2008 On-road PM 2.5 111.21 88.90 On-road NO x 3,129.00 2,530.31 On-road SO 2 31.77 9.68 Non-road PM 2.5 44.95 40.16 Non-road NO x 574.51 496.47 Non-road SO 2 39.16 6.99 EGU PM 2.5 1,307.90 1,372.80 EGU NO x 41,046.61 35,486.86 EGU SO 2 225,594.94 135,506.74

Requirement 5 of 5 Provisions for future annual updates of the inventory to enable tracking of the emission levels, including an annual emi ssion statement from major sources.

Demonstration In Ohio, major point sources in all counties are required to submit air emissions informati on annually, in accordance with U.S. EPA’s Consolidated Emissions Reporting Rule (CERR). Ohio EPA prepares a new periodic inventory for all PM 2.5 precursor emission sectors ev ery three years. These PM 2.5 precursor inventories will be prepared for future years as necessary to comply with the inventory reporting requirements established in the CFR. Emissi ons information will be compared to the 2005 base year and the 20 25 projected maintenance year inventories to assess emission trends, as necessary, and to assure continued compliance with the 24-hour PM 2.5 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 t he 1990 Clean Air Act Amendmen ts 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 nonattainm ent 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 ex isting sources in the area as may be obtained through the adopti on, at a minimum, of reasonable available control technology).

U.S. EPA’s 1997 Im plementation Rule interprets this requirement in great detail. U nder U.S. EPA’s approach, RACT is determined as part of th e broader RACM analysis and identification of all measures (f or stationary, mobile, and area sources) that are technically a nd economically f easible, 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 r easonable, (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 th eir CAIR emission reduction requirements, EGU compliance with CAIR is equivalent to RACM/RACT.

Demonstration In 1972, 1980, and 1991, Ohio pr omulgated rules requiring reasonably available controls measures for particulate emissions from stati onary 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 enf orcement program to address40 violations discovered by field offi ce staff. The Ohio RACT rules for particulate matter are found in OAC Chapter 3745-17 20

. In addition, Ohio EPA promulgated NO x SIP Call rules (OAC Chapter 3745-14 21 ), CAIR (OAC Chapter 3745-109 22 ), and NO x Reasonably Available Control Te chnology rules (OAC Chapter 3745-110 23 ) over the past five year s. 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 NO x , PM 2.5 , and SO 2 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 bot h ozone precursors and PM 2.5 precursors in Ohio, Illinois, Indiana, Michigan, and Wisconsin area. The first consultant, MACTEC, prepared a series of white
papers 24 researching different stati onary source categories. The results were compiled into two reports 25 . The second consultant, Environ, investigated control options for mobile sources. The results were compiled into two reports 26 . The stationary and mobile source sectors (and asso ciated 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 asse ss the air quality benefit of the candidate control measur es and a modeling report was developed 27 . Based on the results, the LADCO project team felt it would not be possible to advance the attainment date for PM 2.5 . Ohio EPA, in its attainm ent 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_report s/identification_and_evalua tion_of_candidate_control_m easures_i_april_2005.pdf; http://www.ladco.org/reports/control/final_report s/identification_and_evalua tion_of_candidate_control_m easures_ii_june_2006.pdf 26 http://www.ladco.org/reports/control/final_report s/final_report_evaluation_of _candidate_mobile_source_ control_measures_february_2006.pdf; http://www.ladco.org/reports/control/final_report s/final_report_evaluation_of _candidate_mobile_source_ control_measures_for_ladco_stat es_in_2009_and_2012_march_2007.pdf 27 http://www.ladco.org/reports/cont rol/modeling/round4_modeling.pdf41 approach) that attainment woul d be achieved in this area by 2009. Because of a projected 2009 a ttainment date, it would not have been reasonably possible or practicable for Ohio to develop RACT/RACM requirement s, promulgate regulations and implement a control program prior to the projected attainment date.

Requirement 2 of 6 Section 172(c)(2) of the 1990 C AA Amendments requires attainment demonstration SIPs for nonattainment areas to show reasonable further progress (RFP).

Background U.S. EPA’s 1997 Impl ementation Rule requi res RFP only for any area which a State projec ts an attainment date beyond 2014. If a State demonstrates atta inment 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 require ment to submit an attainment demonstration, 2012, an attain ment demonstration is not required.

Demonstration The Steubenville-Weirt on area has attained the standard prior to the deadline for submitting an a ttainment 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 emission s in the area, including the requirement for periodic revisions as determined necessary. 40 CFR 51.1008 requires such inv entory 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 inventor y was submitted to U.S. EPA with Ohio’s PM 2.5 attainment demonstrat ion 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 statem ents). 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 (Require ment 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 PM 2.5 SIP revisions have been fully implemented.

Background In addition to the historic RACT requirements for PM, the U.S. EPA NO x SIP Call required 22 states to pass rules that would result in significant emission reductions from large EGUs, industrial boilers, and cement kiln s in the eastern United States. Ohio passed this rule in 2001. NOx SIP Call r equirements are incorporated into permits along with monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio EPA also has an active enf orcement program to address violations discovered by field offi ce staff. Compliance is tracked through the Clean Air Market s data monitoring program. Beginning in 2004, this rule accounts for a reduction of approximately 31 pe rcent of all NO x 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 CA IR rule requires EGUs in 28 eastern states and the District of Columbia to significantly reduce emissions of NO x and SO 2 . CAIR replaced the NOx SIP Call for EGUs. National NO x 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 effo rt. 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 NO x SIP Call formally commenced May 31, 2004. Emissions cover ed by this program have been generally trending downward si nce 1998 with larger reductions occurring in 2002 and 2003. Data taken from the U.S. EPA43 Clean Air Markets web si te, quantify the gradual NO x reductions that have occurred in Ohio as a re sult of Title IV of the 1990 CAA Amendments and the beginning of the NO x SIP Call Rule. Ohio developed the NO x Budget Trading Program rules in OAC Chapter 3745-14 28 in response to the SIP Call. OAC Chapter 3745-14 regulates EGUs and ce rtain 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 NO x emissions from non-EGUs, compared to historical levels. This cap was in place thro ugh 2008, at which ti me the CAIR program superseded it as discussed above . Requirement 3 of 5 under Chapter 4 above discussed the r eductions Ohio has seen as a result of CAIR.

On April 21, 2004, U.S. EPA published Phase II of the NO x SIP Call that establishes a budget fo r large (greater than 1 ton per day emissions) stationary intern al combustion engines. Ohio EPA’s OAC rule 37 45-14-12 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 NO x 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 fi nalized 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, lo wer sulfur gasoline. This rule will apply nationwide. The f ederal rules will phase in between 2004 and 2009. U.S. EPA has estimated that NO x 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. VO C 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.aspx44 Heavy-Duty Diesel Engines In July 2000, U.S. EPA issued a final rule for Highway Heavy Duty Engines, a program which in cludes low-sulfur diesel fuel standards, which will be phased in from 2004 through 2007. This rule applies to heavy-dut y gasoline and diesel trucks and buses. This rule will result in a 40 percent reduction in NO x from diesel trucks and buses, a large sector of the mobile sources NO x 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 dies el 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 emi ssions from non-road diesel engines by more than 90 percent. Non-road diesel equipment, as described in this rule, current ly accounts for 47 percent of diesel particulate matter (PM) and 25 percent of NO x frommobile sources nationwide. Sulfur levels will be reduced in nonroad diesel fuel by 99 percent from current levels, from approximately 3,000 parts per m illion (ppm) now to 15 ppm in 2009. New engine st andards take effect, based on engine horsepower, starting in 2008. Together, these rules will substantially reduce local and regional sources of PM 2.5 precursors.

Requirement 5 of 6 Acceptable provisions to provide for new source review.

Background Ohio has a longstanding and fu lly implemented New Source Review (NSR) program. This is addressed in OAC Chapter 3745-31 29 . 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 Octobe r 10, 2001 (66 FR 51570) and received final approval on J anuary 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.aspx45 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 meas ures 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 PM 2.5 , SO 2 , and NO x as required for maint enance of the 24-hour PM 2.5 standard in the Steubenvil le-Weirton area, wil l 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. Afte r redesignation, it intends to continue enforcing all rules that relate to the emission of PM 2.5 precursors in the St eubenville-Weirton area.46 

### CHAPTER SIX

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

Requirement 1 of 4 A commitment to submit a revised pl an 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 ex ceeding specified predetermined levels (triggers) or in the event that future violations of the am bient 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 shal l be prompted whenever the 98 th percentile 24-hour PM 2.5 concentration of 35.5 μ g/m 3 occurs in a single calendar year within the maintenance area. A warning level response will consist of a study to determine whether the PM 2.5 value indicates a trend toward higher PM 2.5 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 fo r implementation as well as economic and social consider ations. Implementation of necessary controls in response to a warning level response trigger will take place as expe ditiously 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 implem entation outlined under “action level response” shall be followed.

Action Level Response: An action level response sha ll be prompted whenever a twoyear average of the 98 th percentile 24-hour PM 2.5 concentration of 35.0 μ g/m 3 or greater occurs within the maintenance area. A47 violation of the standard (t hree-year average of the 98 th percentile 24-hour PM 2.5 concentration of 35.0 μ g/m 3 or greater) shall also prompt an action level re sponse. 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, Oh io EPA in conjunction with the metropolitan planning organizati on or regional council of governments, will determine additi onal control measures needed to assure future attainm ent of the NAAQS for 24-hour PM 2.5 . 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 includ ed as part of the maintenance provisions will be im plemented in a timely manner and will constitute our response.

Control Measure Sele ction and Implementation Adoption of any additional control measures is subject to the necessary administrative and lega l 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 q uality, additional loca l 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 conti ngency measures that would be implemented in such an event.

Demonstration Contingency measures to be considered will be selected from a comprehensive list of meas ures deemed appropriate and effective at the time the select ion is made. The selection of measures will be based on cost -effectiveness, emission reduction potential, economic and so cial considerations or other factors that Ohio EPA deems appr opriate. Ohio EPA will solicit input from all interested and affected persons in the maintenance area prior to sele cting appropriate contingency measures. Because it is not possi ble at this time to determine48 what control measures will be appropriate at an unspecified time in the future, the list of conti ngency measures outlined below is not exhaustive.

1) Diesel reduction emission strategies. 2) Alternative fuel (e.g., li quid propane and compressed natural gas) and diesel retrofit program s for fleet vehicle operations. 3) Tighter PM 2.5 , SO 2 , and NO x 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 NO x RACT statewide.

No contingency measure s hall 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 PM 2.5 , SO 2 , and NO x sources potentially subjec t to future additional control requirements.

Demonstration The following is a list of PM 2.5 , SO 2 , and NO x sources potentially subject to future controls.

• ICI Boilers - SO 2 and NO x 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 redesignati on petition and maintenance plan in the widely distributed county publications.

The public hearing to receive comm ents on the redesi gnation request was held on May 16, 2012, at the Steubenvi lle Library – Schi appa Branch, 4141 Mall Drive, Steubenville, Oh io. The public comment per iod 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-W eirton 24-hour PM 2.5 nonattainment area has attained the 2006 24-hour NAAQS for PM 2.5 and complied with the appl icable provisions of the 1990 Amendments to the CAA regarding redesignations of PM 2.5 nonattainment areas. Documentation to t hat 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, t he Steubenville-Weirton 24-hour PM 2.5 nonattainment area meets the requirem ents for redesignation under the CAA and U.S. EPA guidance. Ohio has perfo rmed an analysis that shows the air quality improvements are due to pe rmanent and enforceabl e measures. Furthermore, because this area is subject to significant trans port of pollutants, significant regional SO 2 and NO x reductions will ensure continued compliance (maintenance) with the st andard with an increasing margin of safety.

The State of Ohio hereby requests that the Steubenvil le-Weirton 24-hour PM 2.5 nonattainment area be redesignated to attainment simultaneously with U.S. EPA approval of the maintenance plan provisions contained herein.This page left intentionally blank