west virginia department of environmental protection

REDESIGNATION REQUEST

AND

MAINTENANCE PLAN

FOR THE

WEST VIRGINIA PORTION

 OF THE

WHEELING, WV-OH 

1997 PM2.5 NONATTAINMENT AREA

FINAL

March 2012

Promoting a healthy environment.
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Page ii
Table of Contents

I. INTRODUCTION ..................................................... Page 1

A. Request . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 1

B. Background ....................................................... Page 1

C. Geographic Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 2

II. REDESIGNATION CRITERIA .......................................... Page 4

A. The Wheeling Area has attained the 1997 PM2.5 Standard . . . . . . . . . . . . . . . . . . . Page 4

B. The Wheeling Area has a Fully Approved SIP Under Section 110(k) of the CAA

................................................................. Page 9

C. The Wheeling Area’s Air Quality Improvement is Due to Permanent and Enforceable

Emissions Reductions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 10

D. The State has Developed a Maintenance Plan for the Wheeling Area Which Ensures

Attainment of the 1997 PM2.5 Standard for at least 10 Years . . . . . . . . . . . . . . . . Page 10

E. The Wheeling Area Has Met All Relevant Requirements under CAA Section 110 and

Part D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 10

1. Section 110(a) requirements ...................................... Page 10

2. Section 172(c) requirements ...................................... Page 11

3. Conformity .................................................... Page 11

III. MAINTENANCE PLAN ............................................ Page 12

A. PM2.5 Emissions Demonstrations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 17

B. NOx Emissions Demonstrations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 19

C. SO2 Emissions Demonstrations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 21

D. Summary of PM2.5, NOx, and SO2 Emission Reductions . . . . . . . . . . . . . . . . . . . . Page 23

E. Air Quality Improvement is Based on Permanent and Enforceable Emission Reductions

................................................................ Page 25

F. Emissions Tracking . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 26

IV. TRANSPORTATION ANALYSIS ...................................... Page 27

A. Onroad Emission Estimations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 27

B. Onroad Mobile Emissions Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 27

C. Emissions Model . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 28

E. Onroad Mobile Emission Estimations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 31

V. CONTROL MEASURES AND REGULATIONS ........................... Page 38

A. Reasonably Available Control Measures (RACM) and Reasonably Available Control

Technology (RACT) ............................................... Page 38

B. Reasonable Further Progress . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 39

C. Inventory of Actual Emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 40

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

implemented. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 40

Wheeling, WV 1997 PM Page iii 2.5 Redesignation and Maintenance Plan
1. NOx SIP Call, CAIR and CSAPR .................................. Page 40

2. Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards .... Page 41

3. Heavy-Duty Diesel Engines ....................................... Page 42

4. Clean Air Non-road Diesel Rule ................................... Page 42

E. New Source Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 42

F. Assurance that existing control measures will remain in effect .............. Page 42

VI. SUPPLEMENTAL MODELING ANALYSES .......................... Page 43

A. EPA Modeling for the Cross State Air Pollution Rule (Final Transport Rule) . . . Page 43

B. EPA Modeling for Proposed Transport Rule 2010 ........................ Page 45

C. VISTAS/ASIP Emissions and Air Quality Modeling to Support PM2.5 and 8-hour Ozone

State Implementation Plans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 46

D. EPA’s CAIR Modeling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 48

VII. CONTINGENCY MEASURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 50

A. Maintenance Plan Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 50

B. Corrective Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 50

1. Warning Level Response ......................................... Page 50

2. Action Level Response .......................................... Page 50

3. Control Measure Selection and Implementation ....................... Page 51

C. Potential Contingency Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 51

D. PM2.5, SO2, and NOx sources potentially subject to future additional control requirements.

................................................................ Page 51

VIII. PUBLIC PARTICIPATION ......................................... Page 52

IX. CONCLUSIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 53

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page iv
List of Tables

Table 1: Wheeling Nonattainment Area Design Values for the 1997 Annual and 24-hr PM2.5

NAAQS ............................................................. Page 5

Table 2: Reductions in SO2 and NOx EGU Emissions Between 2008 and 2010 ........ Page 13

Table 3: Marshall County, WV PM2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2022

(tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 17

Table 4: Ohio County, WV PM2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2022

(tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 18

Table 5: Belmont County, OH PM2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2022

(tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 18

Table 6: Wheeling Nonattainment Area PM2.5 Emission Inventory Totals for 2005, 2008, 2015

and 2022 (tpy) ....................................................... Page 19

Table 7: Marshall County, WV NOx Emission Inventory Totals for 2005, 2008, 2015 and 2022

(tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 19

Table 8: Ohio County, WV NOx Emission Inventory Totals for 2005, 2008, 2015 and 2022 (tpy)

................................................................... Page 20

Table 9: Belmont County, OH NOx Emission Inventory Totals for 2005, 2008, and 2015 and

2022 (tpy) ........................................................... Page 20

Table 10: Wheeling Nonattainment Area NOx Emission Inventory Totals for 2005, 2008, 2015

and 2022 (tpy) ....................................................... Page 21

Table 11: Marshall County, WV SO2 Emission Inventory Totals for 2005, 2008, 2015 and 2022

(tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 21

Table 12: Ohio County, WV SO2 Emission Inventory Totals for 2005, 2008, 2015 and 2022 (tpy)

................................................................... Page 22

Table 13: Belmont County, OH SO2 Emission Inventory Totals for 2005, 2008, 2015 and 2022

(tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 22

Table 14: Wheeling Nonattainment Area SO2 Emission Inventory Totals for 2005, 2008, 2015

and 2022 (tpy) ....................................................... Page 23

Table 15: West Virginia Portion of the Wheeling Area Comparison of 2008 attainment year and

2015 and 2022 projected emission estimates (tpy) ........................... Page 23

Table 16: Ohio Portion of the Wheeling Area Comparison of 2008 attainment year and 2015 and

2022 projected emission estimates (tpy) ................................... Page 23

Table 17: Wheeling Area Comparison of 2008 attainment year and 2015 and 2022 projected

emission estimates (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 24

Table 18: Wheeling Area Comparison of 2005 Base Year and 2008 Attainment Year Reductions

by Sector . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 25

Table 19: MOVES Inputs ................................................. Page 30

Table 20: Marshall County, WV Emissions Estimations for Onroad Mobile Sources . . . Page 31

Table 21: Ohio County, WV Emissions Estimations for Onroad Mobile Sources ...... Page 31

Table 22: Summary of West Virginia Emissions Estimations for Onroad Mobile Sources

................................................................... Page 31

Table 23: Belmont County, OH Emissions Estimations for Onroad Mobile Sources .... Page 32

Table 24: Emissions Estimate Totals for the Onroad Mobile Source Sector for the Wheeling,

WV-OH Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 32

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page v
Table 25: Percentage of Wheeling, WV-OH Emissions Attributable to Mobile Sources in 2005,

2008, 2015 and 2022 .................................................. Page 33

Table 26: CSAPR Annual PM2.5 Design Values (μg/m3) . . . . . . . . . . . . . . . . . . . . . . . . Page 44

Table 27: Proposed Transport Rule Modeling Results from EPA - 2010 ............. Page 45

Table 28: VISTAS/ASIP 2009, 2012 and 2018 Modeling Results (with CAIR) ....... Page 47

Table 29. EPA CAIR Modeling Results ...................................... Page 48

Wheeling, WV 1997 PM Page vi 2.5 Redesignation and Maintenance Plan
List of Figures

Figure 1: Map of the Wheeling, WV-OH nonattainment area and monitor locations .... Page 5

Figure 2: West Virginia PM2.5 Annual Design Values, 1999-2001 through 2008-2010. . . Page 7

Figure 3: Ohio PM2.5 Annual Design Values, 1999-2001 through 2007-2009. ......... Page 8

Figure 4: PM2.5 Annual Mean National Trends ................................. Page 9

Figure 5. Belomar Region . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 27

Figure 6: Wheeling, WV-OH NOx Emissions by Sector . . . . . . . . . . . . . . . . . . . . . . . . . Page 35

Figure 7: Wheeling, WV-OH NAA PM2.5 Emissions by Sector . . . . . . . . . . . . . . . . . . . . Page 35

Figure 8: Wheeling, WV-OH NAA SO2 Emissions by Sector . . . . . . . . . . . . . . . . . . . . . Page 36

Figure 9: Onroad NOx Emissions Tons per Year . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 37

Wheeling, WV 1997 PM Page vii 2.5 Redesignation and Maintenance Plan
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Wheeling, WV 1997 PM Page viii 2.5 Redesignation and Maintenance Plan
List of Appendices

Appendix A: Air Monitoring Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page A - 1

Appendix B: Emissions Inventory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page B - 1

Appendix C: On-Road Mobile Emissions Inventory Documentation . . . . . . . . . . . . . Page C - 1

Appendix D: LADCO Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page D - 1

Appendix E: Federal Consent Decrees and State Consent Orders . . . . . . . . . . . . . . . Page E - 1

Appendix F: Public Participation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page F - 1

Appendix G: Belmont County, Ohio Emissions Inventory Summary . . . . . . . . . . . . Page G - 1

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page ix
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Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page x
REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE WEST

VIRGINIA PORTION OF THE WHEELING, WV-OH 

1997 PM2.5 NONATTAINMENT AREA

I. INTRODUCTION

The Wheeling, WV-OH PM2.5 nonattainment area (Wheeling area) is a multi-state nonattainment

area, comprising Marshall and Ohio Counties in West Virginia, and Belmont County in Ohio. The

area monitored attainment of the 1997 PM2.5 standard with a design value for 2006-2008 of 14.2

μg/m3

, 2007-2009 of 13.4 μg/m3, 2008-2010 of 13.1 μg/m3 and 2009-2011 of 13.0 μg/m3 . The State

of West Virginia herein requests redesignation by the United States Environmental Protection

Agency of Marshall and Ohio Counties to attainment relative to the 1997 PM2.5 National Ambient

Air Quality Standard. The State of Ohio also plans to request redesignation of Belmont County, Ohio

to attainment relative to the 1997 PM2.5 National Ambient Air Quality Standard.

A. Request

The State of West Virginia is requesting that the United States Environmental Protection Agency

(EPA) redesignate the West Virginia Portion of the Wheeling (WV-OH) 1997 PM2.5 Nonattainment

Area to attainment pursuant to the provisions of the Clean Air Act, section 107. The State is also

requesting that EPA concurrently approve the associated maintenance plan as a revision to the State

Implementation Plan (SIP), meeting the requirements of Clean Air Act, section 175A, which

demonstrates that the area will continue to meet the current PM2.5 air quality standards for at least ten

more years.

B. Background

The Clean Air Act (CAA) requires areas failing to meet a National Ambient Air Quality Standard

(NAAQS) to develop State Implementation Plans (SIPs) to expeditiously attain and maintain the

standard. The EPA revised the NAAQS for particulate matter in July 1997. It replaced the existing

PM10 standard with a health based PM2.5 standard and retained the PM10 standard as a “coarse”

standard protecting welfare. The 1997 PM2.5 standards include an annual standard set at 15.0

micrograms per cubic meter (μg/m3

), based on the 3-year average of annual mean PM2.5

concentrations and a 24-hour standard of 65 μg/m3, based on the 3-year average of the 98th percentile

of 24-hour concentrations.

The revised NAAQS were legally challenged in the U.S. Court of Appeals for the District of

Columbia Circuit (D.C. Circuit). On May 14, 1999, the D.C. Circuit remanded, without vacatur, the

standard back to EPA. The remand did not question the level at which EPA set the standards but

rather the constitutionality of the CAA provision that authorizes EPA to set national air quality

standards. EPA requested a rehearing which the D.C. Circuit denied. Therefore, in December 1999,

EPA appealed the D.C. Circuit decision to the U.S. Supreme Court. The U.S. Supreme Court issued

a decision on February 27, 2001 that unanimously affirmed the constitutionality of the CAA

provision but did remand several other issues back to the D.C. Circuit, including the issue of whether

EPA acted arbitrarily and capriciously in establishing the specific levels of the standards.

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 1
The D.C. Circuit heard arguments in this remanded case in December 2001, and issued its decision

on March 26, 2002. The D.C. Circuit rejected the claims that the EPA had acted arbitrarily and

capriciously in setting the levels of the standards. 

On December 17, 2004, EPA promulgated the initial PM2.5 nonattainment areas designations for the

PM2.5 standards across the country. Modifications to those designations were made and an effective

date was set at April 5, 2005. Unlike Subpart 2 of the CAA Amendments of 1990 which defined five

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

the ozone levels, PM2.5 nonattainment designations are simply labeled “nonattainment.” The CAA

Amendments require states with PM2.5 nonattainment areas to submit a plan within three years of the

effective date of the designations (April 5, 2008) detailing how the PM2.5 standards would be attained

by April 5, 2010.

On November 20, 2009 [74 FR 60199] EPA determined that three areas in West Virginia designated

nonattainment for the 1997 fine particulate (PM2.5) National Ambient Air Quality Standard (NAAQS)

had attained the 1997 PM2.5 NAAQS [Clean Data Determination]. These were the

Martinsburg-Hagerstown, WV-MD nonattainment area; the Parkersburg-Marietta, WV-OH

nonattainment area; and the Wheeling, WV-OH nonattainment area. These determinations were based

upon complete, quality assured, quality controlled, and certified ambient air monitoring data that

show that these areas monitored attainment of the 1997 PM2.5 NAAQS during the 2006-2008

monitoring period. Available monitoring data for 2009, 2010 and 2011 are consistent with continued

attainment of the standard. The intended effect of this action was to finalize the attainment

determinations for these areas. With these final determinations, the requirements for the state to

submit an attainment demonstration for these areas, associated reasonably available control measures,

a reasonable further progress plan, contingency measures, and other planning State Implementation

Plans (SIPs) related to attainment of the standard are suspended for so long as the areas continue to

meet the 1997 PM2.5 NAAQS.

On December 2, 2011 [76FR75464] EPA determined that the Parkersburg-Marietta, WV-OH area

and the Wheeling, WV-OH area had attained the 1997 annual PM2.5 NAAQS by their applicable

attainment date of April 5, 2010. These determinations were based on complete, quality-assured, and

certified ambient air monitoring data for the 2007-2009 monitoring period. 

C. Geographic Description

The Wheeling, WV-OH PM2.5 nonattainment area (Wheeling area) is a multi-state nonattainment

area, comprising Marshall and Ohio Counties in West Virginia, and Belmont County in Ohio. This

area is shown in Figure 1 under Section II.A. The Wheeling area has not previously been subject to

nonattainment area rulemakings for fine particles. 

Although EPA designated the Wheeling area nonattainment for the 15.0 μg/m3

 annual standard as

a result of the Clean Data Determination West Virginia DEP was not required to develop a plan to

reduce oxides of nitrogen (NOx), sulfur dioxide (SO2) and direct PM2.5 emissions and demonstrate

that the area would meet the federal annual air quality standard by April 5, 2010. 

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 2
This document is intended to support West Virginia’s request that the West Virginia portions of the

Wheeling area be redesignated from nonattainment to attainment for the 1997 PM2.5 standard. In

addition, the State of Ohio also plans to submit a request for their portion of the Wheeling area. 

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 3
II. REDESIGNATION CRITERIA

Pursuant to Section 107(d)(3)(E) of the CAA states must sufficiently address five issues to obtain

redesignation of a nonattainment area to attainment: 

A. determinate that the area has attained the applicable NAAQS;

B. have a fully approved implementation plan under CAA section 110(k);

C. show that the improvement in air quality is due to permanent and enforceable emission

reductions;

D. submit an EPA approvable maintenance plan which ensures attainment of the NAAQS for at

least ten years beyond redesignation; and

E. show that the area has met the applicable requirements of CAA section 110 and part D. 

The State of West Virginia herein affirmatively completes all five of the required elements as detailed

below.

A. The Wheeling Area has attained the 1997 PM2.5 Standard

[See Appedix A]

The following information is taken from EPA’s “Guideline on Data Handling Conventions for the

PM NAAQS,” U.S. EPA-454/R-99-008, April 1999.

In accordance with the CAA Amendments, three complete years of monitoring data are required to

demonstrate attainment at a monitoring site. The annual PM2.5 primary and secondary ambient air

quality standards are met at an ambient air quality monitoring site when the three-year average of the

annual average is less than 15.0 μg/m3. While calculating design values, three significant digits must

be carried in the computations, with final values rounded to the nearest 0.1 μg/m3. Decimals 0.05 or

greater are rounded up, and those less than 0.05 are rounded down, so that 15.049 μg/m3

 is the largest

concentration that is less than, or equal to 15.0 μg/m3. Values at or below 15.0 μg/m3 meet the

standard; values equal to or greater than 15.1 μg/m3 exceed the standard. An area is in compliance

with the annual PM2.5 NAAQS only if every monitoring site in the area meets the NAAQS. An

individual site’s 3-year average of the annual average concentrations is also called the site’s design

value. The air quality design value for the area is the highest design value among all sites in the area. 

There are two monitors measuring PM2.5 concentrations in the Wheeling, WV-OH nonattainment

area. The monitors are located in West Virginia and operated by the West Virginia Division of Air

Quality (DAQ). The location of the monitoring sites for this nonattainment area are shown in Figure

1. A listing of the design values based on the three-year average if the annual mean concentrations

from 2001-2003 through 2009-2011 is shown in Table 1.

The DAQ has quality assured all data shown in Appendix A, up through 2010 in accordance with 40

CFR 58.10 and all other federal requirements. DAQ has recorded the data in the AQS database and,

therefore, the data are available to the public. Table1 shows the monitoring data for 2001-2010 that

were retrieved from the EPA AQS, and preliminary 2011 data that will be certified and recorded in

the AQS database in accordance with 40 CFR 58.10. 

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 4
107-1002

Figure 1: Map of the Wheeling, WV-OH nonattainment area and monitor locations 

Table 1. Monitoring Data for the Wheeling, WV-OH area for 2000 - 2011

Table 1: Wheeling Nonattainment Area Design Values for the 1997 Annual and 24-hr PM2.5 NAAQS

1997 NAAQS 24 hr 3 yr 98% = 65 1997 Annual NAAQS = 15

FRM

Site

01

-

03

02

-

04

03

-

05

04

-

06

05

-

07

06

-

08

07

-

09

08

-

10

09

-

11

01

-

03

02

-

04

03

-

05

04

-

06

05

-

07

06

-

08

07

-

09

08

-

10

09

-

11

051-

1002

37 36 33 34 35 34 31 29 29 15.7 15.1 15.3 15.0 15.2 14.2 13.4 13.1 13.0

069-

0010

36 35 32 31 32 31 29 26 26 15.2 14.7 14.9 14.2 14.6 13.7 13.2 12.4 11.9

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

Notes: Green shading indicates meeting the standard, all monitors in the area monitor attainment.

2011 data is preliminary, and has not yet been certified.

069-0010

051-1002

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 5
The design values calculated for the Wheeling area demonstrate that the 1997 PM2.5 NAAQS has

been attained. The area’s design values have trended downward as emissions have declined due to

such factors as cleaner automobiles and fuels, and controls for EGUs, at the national, regional and

local level. 

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

values for all monitors in West Virginia and Ohio, as shown in Figures 2 and 3. Design values have

also trended downward nationally, as shown in Figure 4.

On November 20, 2009 [74 FR 60199] EPA determined that the Wheeling, WV-OH area had attained

the 1997 PM2.5 NAAQS [Clean Data Determination]. This determination was based upon complete,

quality assured, quality controlled, and certified ambient air monitoring data that showed that the area

monitored attainment of the 1997 PM2.5 NAAQS during the 2006-2008 monitoring period.

On December 2, 2011 [76FR75464] EPA determined that the Wheeling, WV-OH area had attained

the 1997 annual PM2.5 NAAQS by the applicable attainment date of April 5, 2010. This determination

was based on complete, quality-assured, and certified ambient air monitoring data for the 2007-2009

monitoring period. 

Complete quality-assured PM2.5 ambient air quality monitoring data for the recent three (3) year

period 2008 through 2010, and preliminary data for the 2009 through 2011 period, demonstrate that

the air quality continues to meet the NAAQS for annual PM2.5 in this nonattainment area. The

NAAQS attainment, accompanied by decreases in emission levels discussed in Chapter Four, support

a redesignation to attainment for the Wheeling area based on the requirements in Section

107(d)(3)(E) of the CAA.

DAQ commits to continue monitoring PM2.5 levels at the West Virginia sites indicated in Figure 1

and Table 1. DAQ will consult with EPA Region III prior to making changes to the existing

monitoring network, should changes become necessary in the future. DAQ will continue to quality

assure the monitoring data to meet the requirements of 40 CFR 58 and all other federal requirements. 

Connection to a central station and updates to the DAQ web site will provide real time availability

of the data and knowledge of any exceedances. DAQ will enter all data into AQS on a timely basis

in accordance with federal guidelines. 

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 6
Figure 2: West Virginia PM2.5 Annual Design Values, 1999-2001 through 2008-2010.

Data Source: http://www.epa.gov/airtrends/values.html, from Excel spreadsheet: PM25dv20082010

1997 Annua

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan 
Figure 3: Ohio PM2.5 Annual Design Values, 1999-2001 through 2007-2009.

Data Source: http://www.epa.gov/airtrends/values.html, from Excel spreadsheet: PM25dv20082010Final.xls

1997 Annual Std = 15 

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan 
Figure 4: PM2.5 Annual Mean National Trends

Source: http://www.epa.gov/airtrends/pm.html

B. The Wheeling Area has a Fully Approved SIP Under Section 110(k) of the CAA

On December 17, 2004, EPA promulgated the initial PM2.5 nonattainment areas designations for the

PM2.5 standards across the country, including the Wheeling, WV-OH area. Modifications to those

designations were made and an effective date was set at April 5, 2005. Unlike Subpart 2 of the CAA

Amendments of 1990 which defined five ozone nonattainment classifications for the areas that

exceed the NAAQS based on the severity of the ozone levels, PM2.5 nonattainment designations are

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

areas to submit a plan within three years of the effective date of the designations (April 5, 2008)

detailing how the PM2.5 standards would be attained by April 5, 2010. On November 20, 2009

determined that the Wheeling area had monitored attainment of the 1997 PM2.5 NAAQS during the

2006-2008 time period. This determination suspended the requirement for the state to submit an

attainment demonstration, associated reasonably available control measures, a reasonable further

progress plan, contingency measures, and other planning SIPs related to attainment of the standard

for as long as the area continues to meet the 1997 PM2.5 NAAQS. On December 2, 2011, in

accordance with Section 179(c)(1) of the CAA, EPA determined that the Wheeling, WV-OH PM2.5

nonattainment area had attained the 1997 annual PM2.5 NAAQS by the applicable attainment date of

April 5, 2010 [76FR75465]. The DEP believes that all applicable requirements under CAA section

110(k) have been met.

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 9
C. The Wheeling Area’s Air Quality Improvement is Due to Permanent and Enforceable

Emissions Reductions

Several federally enforceable control measures have been implemented during the past decade which

contribute to the air quality improvement, and will continue to reduce emissions in the future. These

are discussed in detail in Section V - Control Measures and Regulations.

D. The State has Developed a Maintenance Plan for the Wheeling Area Which Ensures

Attainment of the 1997 PM2.5 Standard for at least 10 Years

Section 107(d)(3)(E) of the CAAA stipulates that for an area to be redesignated to attainment EPA

must approve a maintenance plan that meets the requirements of Section 175A. A state may submit

both the redesignation request and maintenance plan at the same time, and the plan adoption process,

including rule-making or public hearing proceedings, may proceed on a parallel track. West Virginia

is herein submitting a request to redesignate the Wheeling area to attainment and is also requesting

that EPA concurrently process this request and the accompanying maintenance plan.

E. The Wheeling Area Has Met All Relevant Requirements under CAA Section 110 and

Part D

For purposes of redesignation, a state must meet all requirements of Section 110 and Part D that were

applicable prior to submittal of the complete redesignation request.

Subpart 1 of Part D consists of general requirements applicable to all areas which are designated

nonattainment based on a violation of the NAAQS. Subpart 4 of Part D consists of more specific

requirements applicable to particulate matter (specifically to address PM10). However, for the purpose

of implementing the 1997 PM2.5 standard, EPA’s Implementation Rule stated Subpart 1, rather than

Subpart 4, is appropriate for the purpose of implementing PM2.5.[72 FR 20589]

1. Section 110(a) requirements

Section 110(a) of Title I of the CAA contains the general requirements for a SIP. Section

110(a)(2) provides that the implementation plan submitted by a state must have been adopted by

the state after reasonable public notice and hearing, and that, among other things, it must include

enforceable emission limitations and other control measures, means or techniques necessary to

meet the requirements of the CAA; provide for establishment and operation of appropriate

devices, methods, systems and procedures necessary to monitor ambient air quality; provide for

implementation of a source permit program to regulate the modification and construction of any

stationary source within the areas covered by the plan; include provisions for the implementation

of Part C, prevention of significant deterioration (PSD) and Part D, NSR permit programs;

include criteria for stationary source emission control measures, monitoring, and reporting;

include provisions for air quality modeling; and provides for public and local agency participation

in planning and emission control rule development. In West Virginia’s December 11, 2007, and

October 1, 2009 infrastructure SIP submissions and March 18, 2010 certification, West Virginia

verified that the State fulfills the requirements of Section 110(a)(2) of the Act.

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 10
Section 110(a)(2)(D) also requires State plans to prohibit emissions from within the State which

contribute significantly to nonattainment or maintenance areas in any other State, or which

interfere with programs under Part C to prevent significant deterioration of air quality or to

achieve reasonable progress toward the national visibility goal for Federal class I areas (national

parks and wilderness areas). In order to assist States in addressing their obligations regarding

regionally transported pollution, EPA finalized CAIR to reduce SO2 and NOx emissions from

large electric generating units (EGU). West Virginia has met the requirements of the federal

CAIR to reduce NOx and SO2 emissions contributing to downwind states. On August 4, 2009,

EPA approved West Virginia's CAIR program [74FR38536] , which were found in West

Virginia’s Code of State Rules at 45 CSR39, 45CSR40, and 45CSR41. On July 6, 2010, EPA

proposed a replacement to the CAIR program, the Transport Rule [75 FR 45210]. The Transport

Rule, or the Cross-State Air Pollution Rule (CSAPR) as it is now called, was finalized on July

6, 2011, and published in the Federal Register on August 8, 2011 [76FR48208]. Under the

CSAPR, EPA adopted Federal Implementation Plans (FIPs) for each state covered by the rule,

including West Virginia. The CSAPR further assists states in addressing their obligations

regarding regionally transported pollution by providing reductions in NOx and SO2 emissions in

2012 and 2014. On December 30, 2011 the United States Court of Appeals for the District of

Columbia stayed the implementation of CSAPR, indefinitely reinstating CAIR.

2. Section 172(c) requirements

Section 172(c) contains general requirements for nonattainment plans. The requirements for

reasonable further progress, identification of certain emissions increases, and other measures

needed for attainment will not apply for redesignations because they only have meaning for areas

not attaining the standard. The requirements for an emission inventory will be satisfied by the

inventory requirements of the maintenance plan. Sections III and V discuss these requirements

in more detail.

3. Conformity

The state must work with EPA to show that its SIP provisions are consistent with the Section

176(c)(4) conformity requirements. The redesignation request should include conformity

procedures, if the state already has these procedures in place. If a state does not have conformity

procedures in place at the time that it submits a redesignation request, the state must commit to

follow EPA’s conformity regulation upon issuance, as applicable. Section IV discusses this

requirement in more detail.

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 11
III. MAINTENANCE PLAN

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

Section 107(d)(3)(E) stipulates that for an area to be redesignated, EPA must fully approve a

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

constitute a SIP revision and must provide for maintenance of the relevant NAAQS in the area for

at least 10 years after redesignation. Section 175 (A) further states that the plan shall contain such

additional measures, if any, as may be necessary to ensure such maintenance.

In addition, the maintenance plan shall contain such contingency measures as the Administrator

deems necessary to ensure prompt correction of any violation of the NAAQS. At a minimum, the

contingency measures must include a requirement that the state will implement all measures

contained in the nonattainment SIP prior to redesignation.

In consultation with EPA and Ohio EPA, West Virginia DAQ selected the year 2022 as the end year

of the maintenance plan for this redesignation request. This document contains projected emissions

inventories for 2015 and 2022. Thus, the pertinent inventory years are: 2005 (nonattainment year),

2008 (attainment year and maintenance plan base year), 2015 (interim year) and 2022 (maintenance

plan end year). Three specific emissions inventory demonstrations should be made:

1. The attainment year (2008) emissions of PM2.5, NOx and SO2 must each be less than the

corresponding emissions in the nonattainment year (2005). The reductions must be

attributable to federally enforceable emission reductions (as discussed in Section III.E and

Section V).

2. The interim year (2015) emissions of each of the three pollutants should be less than the

maintenance plan base year (2008).

3. The end year (2022) emissions of each of the three pollutants should be less than the

maintenance plan base year (2008).

As can be seen in Table 2 below, West Virginia has seen a significant state-wide decline of the

467,081 tons of SO2 and 159,481 tons of NOx emitted by EGUs in 2005. In 2008 and 2009 facilities

began preparing for and implementing control programs to address CAIR and consent orders.

Significant reductions occurred regionally and nationally. Data available for 2010, show the SO2 and

NOx reductions which were implemented under CAIR.

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 12
Table 2: Reductions in SO2 and NOx EGU Emissions Between 2008 and 2010

SO2 NOx

2008 2010 %

Change

2008 2010 %

Change

West Virginia 301,574 106,088 -65% 97,331 51,393 -47%

Ohio 709,444 570,045 -20% 235,018 104,574 -56%

National 7,616,449 5,119743 -33% 2,996,594 2,061,062 -31%

Source: Clean Air Markets, Data and Maps, Quick Reports, State Level Emissions Quick Report and Program Level

Emissions Quick Report, Acid Rain Program

Further, Tables 3- 18 clearly show total emissions from all sectors decreased in the period from 2005

to 2008 in the West Virginia and Ohio portions of the nonattainment area. As outlined below, the

reductions are enforceable and should continue in the future.

On March 10, 2004, EPA promulgated the CAIR. Beginning in 2009, EPA’s CAIR rule required

EGUs in 28 eastern states and the District of Columbia to significantly reduce emissions of NOx and

SO2. CAIR replaced the NOx SIP Call for EGUs. The intent of the CAIR program was for national

NOx emissions to be cut from 4.5 million tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3

million tons in 2018 in 28 states. States were required to submit a CAIR SIP as part of this effort. 

West Virginia DEP submitted a CAIR SIP to EPA on June 1, 2006. Revisions to the CAIR SIP were

submitted on April 22, 2008. The revised CAIR SIP was approved on August 4, 2009 (74 FR 38536). 

As a result of CAIR, EPA projected that in 2009 emissions of NOx would decrease from a baseline

of 179,000 tons per year to 63,000 tons per year while in 2010 emissions of SO2 would decrease from

a baseline of 582,000 tons per year to 250,000 tons per year, within West Virginia. And by 2015

EPA projected emissions of NOx would decrease to 44,000 tons per year while emissions of SO2

would decrease to 118,000 tons per year, within West Virginia. 

On December 23, 2008, EPA’s CAIR program was remanded without vacatur by the D.C. Circuit

Court.

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

“Based on emissions monitoring data, EPA has observed substantial reductions in emissions

from 2005 to 2010 as companies installed more controls, electric demand declined, and low

natural gas prices made combined-cycle gas-fired units more competitive in several parts of

the country. Thus, even after CAIR’s vacatur and subsequent remand in late 2008, the

controls in place generally have continued to operate, helping to drive continued progress in

reducing emissions. However, allowance prices of SO2 have been relatively low since 2008,

raising concerns that coal-fired units could burn dirtier fuels, operate scrubbers at reduced

efficiency, or even bypass scrubbers altogether, instead relying on banked allowances

(because there is not an existing large bank of NOx allowances, NOx allowance prices have

not been affected as significantly). For these reasons, EPA is tracking SO2 and NOx emissions

closely each quarter to evaluate further progress and assess whether backsliding may be

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 13
occurring and, if so, wher e it may be taking place.”

[http://www.epa.gov/airmarkets/background.htm] 

On July 6, 2010, EPA proposed a replacement to the CAIR program, the Transport Rule [75 FR

45210]. On July 6, 2011, EPA finalized the Transport Rule, now commonly referred to as the CrossState Air Pollution Rule (CSAPR) [76FR48208, 08AUG2011] in time for reductions to begin in

2012. As finalized, the CSAPR will preserve the initial reductions achieved under CAIR and provide

more reductions in NOx and SO2 emissions in 2012 and 2014, ahead of the 2015 CAIR Phase 2.

West Virginia DAQ is in agreement with the analysis by U.S. EPA that the CAIR program provided

real reductions. We believe these reductions have assisted with PM2.5 attainment in this nonattainment

area and throughout West Virginia. It is also the DAQ’s belief that the CSAPR will continue to

provide the necessary reductions, and likely even greater reductions, that will be necessary for

maintenance of the annual PM2.5 standard to continue. As stated by EPA regarding the final

Transport Rule or CSAPR: 

This rule will prohibit all significant contribution to nonattainment and interference with

respect to the annual and 24-hour PM2.5. In addition, it will resolve air quality issues at most

nonattainment and maintenance receptors identified by EPA. EPA projects that unresolved

nonattainment and maintenance issues will remain in only a few downwind states after

promulgation and implementation of the Transport Rule. For the annual PM2.5 standard, EPA

projects that this rule will help assure that all areas in the east fully resolve their

nonattainment and maintenance concerns. This rule will also help a number of areas achieve

the standard earlier than they may have otherwise. [76 FR 48247] 

However, on December 30, 2011 the United States Court of Appeals for the District of Columbia

stayed the implementation of CSAPR, indefinitely reinstating CAIR.

DAQ has considered the Integrated Planning Model (IPM) emission projections for the EGUs

(Kammer and Mitchell Power Stations) in the Wheeling area under CAIR and CSAPR. On their

website [http://www.epa.gov/airmarkets/progsregs/epa-ipm/index.html] EPA states:

EPA uses the Integrated Planning Model (IPM) to analyze the projected impact of

environmental policies on the electric power sector in the 48 contiguous states and the District

of Columbia. Developed by ICF Consulting, Inc. and used to support public and private sector

clients, IPM is a multi-regional, dynamic, deterministic linear programming model of the U.S.

electric power sector. It provides forecasts of least-cost capacity expansion, electricity

dispatch, and emission control strategies for meeting energy demand and environmental,

transmission, dispatch, and reliability constraints. IPM can be used to evaluate the cost and

emissions impacts of proposed policies to limit emissions of sulfur dioxide (SO2), nitrogen

oxides (NOx), carbon dioxide (CO2), and mercury (Hg) from the electric power sector. The

IPM was a key analytical tool in developing the proposed Transport Rule.

Under CAIR for 2020 EPA projected 5,597 tons of NOx and 16,085 tons of SO2. Under CSAPR, for

the same facilities in 2020, IPM projected 6,215 tons of NOx and 13,645 tons of SO2

[http://www.epa.gov/airmarkets/progsregs/epa-ipm/cair/index.html, see IPM Parsed File EPA Final

CAIR parsed for year 2020 (Final CAIR modeling)]. While the projections do not match exactly, they

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 14
are consistent and the DAQ believes that CAIR or any likely replacement for CAIR, will constrain

NOx and SO2 emissions sufficiently to ensure that maintenance level emissions are not exceeded

during the maintenance period.

Furthermore, as shown in Section VI - Supplemental Modeling Analyses, recent modeling -- CAIR,

proposed Transport Rule, CSAPR (Final Transport Rule), including base cases where CAIR and

CSAPR were not considered to be applicable requirements, and the VISTAS/ASIP modeling (which

includes CAIR) -- all show that the Wheeling area will continue to maintain the 1997 PM2.5 NAAQS. 

Therefore, it is West Virginia DAQ’s belief it is most appropriate to evaluate West Virginia’s

demonstration that the projected level of emissions is sufficient to maintain the annual PM2.5 standard

by assessing future year emissions that include the CSAPR program. Furthermore, modeling

conducted as part of the Transport Rule development (both the proposed Transport Rule and the Final

Transport Rule, or CSAPR) projects the counties within this area will not have maintenance issues

in 2014 even without the Transport Rule (proposed or final) or CAIR.

Therefore, West Virginia DAQ is identifying emissions projections for 2015 and 2022 for EGUs with

implementation of the CSAPR program.

Emission projections for the Wheeling area were performed using the following approaches:

• Emissions inventories are required to be projected to future dates to assess the influence of

future growth and controls. 

• NonEGU Point, Area, and Locomotive/Marine Source inventories for 2015 and 2022 were

developed by DAQ based on the 2008 inventory using Workforce West Virginia economic

forecasts (http://www.workforcewv.org/LMI/indproj/longterm/WV.htm). The Workforce WV

projections were in terms of North American Industrial Classification System (NAICS) codes

while the WV 2008 v1.5 data is in terms of SCCs. A list of SCCs contained in the 2008 WV

inventory was compiled and the associated with each NAICS code for which there was a

Workforce WV growth factor. Then directly proportional growth factors were calculated and

applied to Workforce WV’s 2018 growth factor to calculate 2015 and 2022 emissions. The

final estimates reflect both positive and negative growth. The 2008 NEI data were

downloaded from EPA’s CHIEF webpage at http://www.epa.gov/ttn/chief/

net/2008inventory.html.

• Nonroad mobile source inventories for those categories calculated by the model were

developed by DAQ personnel using monthly NONROAD Model runs for 2015 and 2022, and

summing the monthly data to obtain annual data.

• Ohio provided the emission estimates for the Ohio portion of the area, based on LADCO

developed growth and control files for Point, Area, and Nonroad categories. Appendix D

contains LADCO’s technical support document detailing the analysis used to project

emissions (Base M ) [www.ladco.org/tech/emis/current/index.php].

• As performed by ODOT, Onroad mobile source emission projections are based on the EPA

MOVES model. The analysis is described in more detail in Appendix C. All projections

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 15
were made using federally approved interagency consultation procedures. As discussed in

Section IV, DAQ determined that the mobile emission contribution as a percent of the total

emission inventory from the area is not significant.

The detailed inventory information for the West Virginia portion of the Wheeling area for 2005 is

contained in Appendix B. Emission trends are an important gauge for continued compliance with

the PM2.5 standard. Therefore, West Virginia DAQ performed an initial comparison of the

inventories for the base year and maintenance years.

Sectors included for West Virginia in the following tables are: Electrical Generating Unit (EGU);

Non-Electrical Generating Units including Airports (Non-EGU); Non-road Mobile (Nonroad); Other 

Area (Area); Locomotive and Marine (LM); and Onroad Mobile (Onroad).

Sectors included for Ohio in the following tables are: Electrical Generating Unit (EGU);

Non-Electrical Generating Unit (Non-EGU); Non-road Mobile (Nonroad); Other Area (Area);

Marine; Aircraft; Rail (MAR); and Onroad Mobile (Onroad).

Maintenance is demonstrated when the future-year (2022) projected emission totals of each of the

relevant pollutants are below the 2008 attainment year totals.

The West Virginia emissions data in the tables below are based on the following data sources:

• All On-Road data developed by ODOT for WWW.

• 2005 and 2008 EGU and non-EGU Point Source from certified data submitted by industry

to West Virginia DAQ’s 2005 and 2008 annual emissions inventory database and

subsequently submitted to EPA.

• 2015 EGU data from IPM runs prepared for EPA for CSAPR.

• 2022 EGU data interpolated from 2020 and 2030 IPM runs prepared for EPA for CSAPR.

• WV Nonroad data developed by DAQ using EPA’s Nonroad Model v2008.1.0.

• All other West Virginia data developed by DAQ based on Workforce WV economic

projections.

• All Ohio data provided by OEPA.

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 16
A. PM2.5 Emissions Demonstrations

The 2005 and 2008 actual PM2.5 EGU and NonEGU emissions data below reflects PM2.5-primary

emissions. Although some facilities reported both PM2.5-pri and the PM fraction emissions, not all

facilities reported PM2.5-pri emissions. When PM2.5-pri was not reported by sources, WV DAQ

applied PM augmentation procedures in accordance with EPA procedures as documented in EPA’s

CSAPR technical support document (TSD), “Emissions Inventory Final Rule TSD, June 28, 2011”

and discussed in more detail in Appendix B and with further technical support provided by EPA’s

Emission Inventory and Analysis Group (EIAG).

Table 3: Marshall County, WV PM2.5 Emission Inventory Totals for 2005, 2008, 2015 and

2022 (tpy)

Sector 2005

(Base)

2008

Attainment

2015

Interim

2015 Safety

Margin

2022

Maintenance

2022 Safety 

Margin

EGU 3,826 4,440 2,121 2,319 2,271 2,169

NonEGU 525 410 316 94 272 137

Area 316 263 258 5 259 4

LM 25 8 8 0 9 0

Nonroad 12 11 7 3 5 5

Onroad 26 20 10 10 7 13

TOTAL 4,731 5,152 2,721 2,432 2,824 2,329

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 17
Table 4: Ohio County, WV PM2.5 Emission Inventory Totals for 2005, 2008, 2015 and

2022 (tpy)

Sector 2005

(Base)

2008

Attainment

2015

Interim

2015 Safety

Margin

2022

Maintenance

2022 Safety 

Margin

EGU 0 00 0 0 0

NonEGU 11 4 4 0 4 0

Area 263 293 290 3 289 4

LM 38 0 0 0 0 0

Nonroad 21 19 15 4 11 9

Onroad 40 36 18 17 13 23

TOTAL 372 352 328 25 317 36

Table 5: Belmont County, OH PM2.5 Emission Inventory Totals for 2005, 2008, 2015 and

2022 (tpy)

Sector 2005

(Base)

2008

Attainment

2015

Interim

2015 Safety

Margin

2022

Maintenance

2022 Safety 

Margin

EGU 94 70 21 49 0 70

NonEGU 3 34 -1 4 -1

Area 308 305 297 8 289 16

MAR 6 63 2 1 4

Nonroad 27 24 17 7 11 14

Onroad 106 89 45 44 26 62

TOTAL 5,648 6,001 3,436 2,565 3,472 2,529

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 18
Table 6: Wheeling Nonattainment Area PM2.5 Emission Inventory Totals for 2005, 2008,

2015 and 2022 (tpy) 

County 2005

(Base)

2008

Attainment

2015

Interim

2015

Safety

Margin

2022

Maintenance

2022

Safety 

Margin

Marshall, WV 4,731 5,152 2,721 2,432 2,824 2,329

Ohio, WV 372 352 328 25 317 36

WV PM2.5 Total 5,103 5,505 3,048 2,456 3,141 2,364

Belmont, OH 545 497 388 109 332 165

Combined PM2.5

Total

5,648 6,001 3,436 2,565 3,472 2,529

B. NOx Emissions Demonstrations

Table 7: Marshall County, WV NOx Emission Inventory Totals for 2005, 2008, 2015 and

2022 (tpy)

Sector 2005

(Base)

2008

Attainment

2015

Interim

2015 Safety

Margin

2022

Maintenance

2022 Safety 

Margin

EGU 31,541 23,269 6,067 17,202 6,366 16,903

NonEGU 3,131 2,759 2,341 418 2,166 593

Area 184 81 84 -2 86 -5

LM 671 249 250 -2 252 -3

Nonroad 113 108 86 22 69 38

Onroad 735 574 249 325 131 443

TOTAL 36,375 27,040 9,077 17,692 9,070 17,969

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 19
Table 8: Ohio County, WV NOx Emission Inventory Totals for 2005, 2008, 2015 and 2022

(tpy)

Sector 2005

(Base)

2008

Attainment

2015

Interim

2015 Safety

Margin

2022

Maintenance

2022 Safety 

Margin

EGU 0 00 0 0 0

NonEGU 6 66 0 6 0

Area 613 151 152 -1 152 -2

LM 972 0 0 0 0 0

Nonroad 170 158 113 45 87 71

Onroad 1,230 1,104 486 617 271 833

TOTAL 2,991 1,418 757 661 516 901

Table 9: Belmont County, OH NOx Emission Inventory Totals for 2005, 2008, and 2015

and 2022 (tpy)

Sector 2005

(Base)

2008

Attainment

2015

Interim

2015 Safety

Margin

2022

Maintenance

2022 Safety 

Margin

EGU 4,150 4,168 4,478 -310 4,738 -570

NonEGU 23 21 20 0 19 2

Area 285 287 287 0 287 0

MAR 262 247 161 87 79 168

Nonroad 222 197 146 51 93 103

Onroad 3,180 2,594 1,279 1,314 588 2,006

TOTAL 8,121 7,513 6,370 1,143 5,804 1,709

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 20
Table 10: Wheeling Nonattainment Area NOx Emission Inventory Totals for 2005, 2008,

2015 and 2022 (tpy)

County 2005

(Base)

2008

Attainment

2015

Interim

2015

Safety

Margin

2022

Maintenance

2022

Safety 

Margin

Marshall, WV 36,375 27,040 9,077 17,962 9,070 17,969

Ohio, WV 2,991 1,418 757 661 516 901

WV NOx Total 39,366 28,457 9,834 18,623 9,587 18,871

Belmont, OH 8,121 7,513 6,370 1,143 5,804 1,709

Combined NOx

Total

47,487 35,971 16,204 19,767 15,390 20,580

C. SO2 Emissions Demonstrations

Table 11: Marshall County, WV SO2 Emission Inventory Totals for 2005, 2008, 2015 and

2022 (tpy)

Sector 2005

(Base)

2008

Attainment

2015

Interim

2015 Safety

Margin

2022

Maintenance

2022 Safety 

Margin

EGU 96,378 35,074 14,008 21,066 12,797 22,276

NonEGU 19,110 16,503 13,692 2,811 12,285 4,218

Area 102 64 62 2 60 4

LM 31 13 13 0 13 0

Nonroad 10 2 0 2 0 2

Onroad 9 32 1 2 1

TOTAL 115,641 51,658 27,777 23,881 25,158 26,500

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 21
Table 12: Ohio County, WV SO2 Emission Inventory Totals for 2005, 2008, 2015 and 2022

(tpy)

Sector 2005

(Base)

2008

Attainment

2015

Interim

2015 Safety

Margin

2022

Maintenance

2022 Safety 

Margin

EGU 0 00 0 0 0

NonEGU 1 11 0 1 0

Area 232 183 175 9 166 17

LM 44 0 0 0 0 0

Nonroad 15 3 0 2 0 2

Onroad 16 6 4 1 4 2

TOTAL 308 193 180 12 172 21

Table 13: Belmont County, OH SO2 Emission Inventory Totals for 2005, 2008, 2015 and

2022 (tpy)

Sector 2005

(Base)

2008

Attainment

2015

Interim

2015 Safety

Margin

2022

Maintenance

2022 Safety 

Margin

EGU 37,330 15,126 8,783 6,343 6,065 9,061

NonEGU 0 00 0 0 0

Area 93 92 87 5 82 10

MAR 23 16 7 9 3 13

Nonroad 22 8 1 7 0 8

Onroad 31 9 7 3 6 3

TOTAL 37,499 15,252 8,886 6,367 6,157 9,095

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 22
Table 14: Wheeling Nonattainment Area SO2 Emission Inventory Totals for 2005, 2008,

2015 and 2022 (tpy)

County 2005

(Base)

2008

Attainment

2015

Interim

2015

Safety

Margin

2022

Maintenance

2022

Safety 

Margin

Marshall, WV 115,641 51,658 27,777 23,881 25,158 26,500

Ohio, WV 308 193 180 12 172 21

WV SO2 Total 115,949 51,851 27,958 23,893 25,329 26,522

Belmont, OH 37,499 15,252 8,886 6,367 6,157 9,095

Combined SO2

Total

153,448 67,103 36,843 30,260 31,487 35,617

D. Summary of PM2.5, NOx, and SO2 Emission Reductions

Table 15: West Virginia Portion of the Wheeling Area Comparison of 2008 attainment

year and 2015 and 2022 projected emission estimates (tpy)

2008

Attainment

2015

Interim

2015

Projected

Decrease

2022

Maintenance

2022

Projected

Decrease

PM2.5 5,505 3,048 2,457 3,141 2,364

NOx 28,457 9,834 18,623 9,587 18,870

SO2 51,851 27,958 23,893 25,329 26,522

Table 16: Ohio Portion of the Wheeling Area Comparison of 2008 attainment year and

2015 and 2022 projected emission estimates (tpy)

2008

Attainment

2015

Interim

2015

Projected

Decrease

2022

Maintenance

2022

Projected

Decrease

PM2.5 497 388 109 332 165

NOx 7,513 6,370 1,143 5,804 1,709

SO2 15,252 8,886 6,366 6,157 9,095

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 23
Table 17: Wheeling Area Comparison of 2008 attainment year and 2015 and 2022

projected emission estimates (tpy)

2008

Attainment

2015

Interim

2015

Projected

Decrease

2022

Maintenance

2022

Projected

Decrease

PM2.5 6,001 3,436 2,565 3,472 2,529

NOx 35,971 16,204 19,767 15,390 20,581

SO2 67,103 36,843 30,260 31,487 35,616

As shown in the table above (Table 17), PM2.5 emissions in the nonattainment area are projected to

decrease by 2,565tons in 2015 and 2,529 tons in 2022. NOx emissions in the nonattainment area are

projected to decrease by 19,767 tons in 2015 and 20,581 tons in 2022. SO2 emissions in the

nonattainment area are projected to decline by 30,260 tons in 2015 and 35,616 tons in 2022.

The Wheeling area shows a net reduction in PM2.5, NOx and SO2 emissions, cleaner vehicles and fuels

are expected to be in place in 2015 and 2022, and the CAIR Replacement Rule should be

implemented by 2015 and these programs should cause an overall drop in all three pollutants

emissions. Decreases from EPA rules covering Tier 2 Motor Vehicle Emissions Standards and

Gasoline Sulfur Control Requirements [65FR6698,10FEB2000], Highway Heavy-Duty Engine Rule

[62FR54694, 21OCT1997], and the Non-Road Diesel Engine Rule [63FR56968, 23OCT1998] are

factored into the changes. 

In addition, the Mitchell Power Station (AEP) in Marshall County, WV implemented changes in 2007

and 2008. Mitchell, which has two 800 megawatt (MW) units, was required by a federal consent

decree (see Appendix E) to operate their FGD continuously to reduce SO2 emissions beginning

December 31, 2007 and to operate their SCR continuously to reduce NOx emissions beginning

January 1, 2009.

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 24
E. Air Quality Improvement is Based on Permanent and Enforceable Emission Reductions

A demonstration that improvement in air quality between the year violations occurred and the year

attainment was achieved is based on permanent and enforceable emission reductions and not on

temporary adverse economic conditions or unusually favorable meteorology.

Ambient air quality data from all monitoring sites indicate that air quality met the NAAQS for PM2.5

in 2007-2009 and in 2008-2010. EPA’s redesignation guidance (Policy Memo from John Calcagni,

Director, Air Quality Management Division to Regional Air Directors: Air Procedures for Processing

Requests to Redesignate Areas to Attainment), dated September 4, 1992 (p. 9) states: “A state may

generally demonstrate maintenance of the NAAQS by either showing that future emissions of a

pollutant or its precursors will not exceed the level of the attainment inventory, or by modeling to

show that the future mix of sources and emissions rates will not cause a violation of the NAAQS.”

Permanent and enforceable reductions of PM2.5, NOx, and SO2 emissions have contributed to the

attainment of the annual PM2.5 standard. Some of these reductions were realized due to the

application of tighter federal standards on highway heavy-duty engines (Control of Emissions of Air

Pollution from Highway Heavy Duty Engines) and Nonroad diesel engines (Control of Emissions of

Air Pollution from Nonroad Diesel Engines), the application of tighter federal standards on new

vehicles (Control of Air Pollution from New Motor Vehicles: Tier 2 Motor Vehicle Emission

Standards and Gasoline Sulfur Control Requirements), Title IV of the CAA, the NOx SIP Call, CAIR, 

CSAPR, and federal consent decrees requiring reductions of SO2 and NOx emissions from utility

sources. Reductions achieved are discussed in greater detail under Section V.

Table 18: Wheeling Area Comparison of 2005 Base Year and 2008

Attainment Year Reductions by Sector

2005 2008 Decrease

EGU NOx 35,691 27,437 8,254

EGU PM2.5 3,920 4,510 (590)

EGU SO2 133,708 50,200 83,508

Onroad NOx 5,145 4,272 873

Onroad PM2.5 172 145 27

Onroad SO2 56 18 38

Nonroad NOx 505 463 42

Nonroad PM2.5 60 54 6

Nonroad SO2 47 13 34

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 25
F. Emissions Tracking

Provisions for future annual updates of the inventory to enable tracking of the emission levels,

including an annual emission statement from major sources.

In West Virginia, major point sources in all counties are required to submit air emissions information

annually. West Virginia DAQ prepares a new periodic inventory for all PM2.5 precursor emission

sectors every three years in accordance with EPA’s Air Emissions Reporting Requirements (AERR). 

These PM2.5 precursor inventories will be prepared for future years as necessary to comply with the

inventory reporting requirements established in the CFR. Emissions information will be compared

to the 2005 base year and the 2022 projected maintenance year inventories to assess emission trends,

as necessary, and to assure continued compliance with the annual PM2.5 standard.

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 26
IV. TRANSPORTATION ANALYSIS

A. Onroad Emission Estimations

The air quality analyses and underlying planning assumptions were develped by the Ohio Department

of Transportation (ODOT), Division of Transportation System Development-Modeling and

Forecasting Section and the Belomar Regional Council, in coordination with the Ohio Environmental

Protection Agency (OEPA) and West Virginia Department of Environmental Protection (WVDEP). 

This evaluation represents the latest population and land use data available that calibrated the

modeling process used to calculate the vehicle emissions for the mobile emissions budgets as well

as the input values for U.S. EPA's most recent emissions software (MOVES) for this attainment

demonstration. The Belomar Region is comprised of the counties of Ohio and Marshall in the north

panhandle of West Virginia and Belmont in east-central Ohio. Figure 5 displays the geographic extent

of the Belomar region non-attainment area.

Figure 5. Belomar Region

B. Onroad Mobile Emissions Summary

A travel demand model (TDM) is the traditional tool used to examine potential changes in future

travel patterns. It generates travel characteristics which are then input into the emissions estimation

model. Ultimately, that output is further input into a post processor to make the final emissions

estimates. The road networks within the TDM include all planned federal-aid projects as well as any

regionally significant projects found in the Transportation Improvement Plan (TIP) and the Long

Range Transportation Plan (LRTP) expected to be open for traffic by the end of each respective

analysis year. All projects identified in the LRTP having an impact on travel time and/or vehicle

carrying capacity regardless of funding source were included in the air quality analysis. Trip

generation figures by zone, with some exceptions, are assumed to change linearly with time between

2000 and the Plan Horizon year of 2035.

The Wheeling area travel demand model network covers about 1500 miles of streets and highways

in the 3-county area including all collector and arterial streets, and has been validated to observed

traffic for year 2000. Land use data comes from the Census, ES202 employment reporting, and local

vehicle registrations. A trip generation model was borrowed from another urban area and adjusted

as needed for local land use data. The hourly distribution of trips by trip purpose and direction are

constrained to match the hourly distribution of traffic counts. Trip distribution also begins with a

trip-length distribution by purpose borrowed from another urban area and adjusted to ensure modeled

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 27
VMT matched HPMS estimates of VMT within 1% in the model base year of 2000. (Home-based

work trips were separately constrained to a target average value based on the 2000 Census.)

The 3-county major street network used in the modeling was developed from the local planning

agency's digital street network (originating from the U.S. Geological Survey). The modeling

software program utilizes hourly saturation flow rates that are calculated based on road inventory

data, roadway type, and the 2000 version of the Highway Capacity Manual (HCM). Coded speeds

by street segment are a function of road type and posted speed limits and are based on the Ohio

statewide travel time study conducted in 2000 using the "run time" version of speeds without

intersection delays. (a vailable on the web at:

http://www.dot.state.oh.us/urban/data/statewid/report.doc) The model software program internally

estimates additional travel times for vehicles that stop for traffic control (stop signs and red lights)

based on HCM methods and modeled traffic patterns. The traffic assignment RMS (root mean

square) error meets FHWA/ODOT standards for all specified volume groups. Overall modeled VMT

for 2000 was less than 1% different than HPMS estimated VMT. Freeways (federal functional class

codes 1, 11, and 12) were within 2% of estimated VMT.

The interagency consultation process, as previously discussed, established the following model years

for Ohio and Marshall counties, WV and Belmont County, OH that reflected the most recent

correspondence from the U.S. EPA:

Analysis Year 2005 - Baseline Emissions

Analysis Year 2008 - Attainment Year

Analysis Year 2015 - Interim Year

Analysis Year 2022 - Maintenance Year

Travel analysis zones (269 in the 3-county area) and external roadway “stations” (31) are the basic

geographic units for estimating travel patterns. Socioeconomic data used to forecast these patterns

include household population, school enrollment, vehicle registrations, labor force participation, and

employment by category and location. Sources for year 2000 data include the 2000 Census

(primarily SF1 block data), state vehicle registration files, and QCEW/ES202 employment data. All

data sources were geocoded to the zone level. Future year data for each variable were projected

through various methods. More detailed explanation of base year and future year data generation for

each of the above-mentioned categories of planning data is outlined in Appendix C. 

C. Emissions Model

MOVES (Motor Vehicle Emissions Simulator) is a computer program designed by the EPA to

estimate air pollution emissions from highway mobile sources. EPA published a Federal Register

notice of availability [75 FR 9411] on March 2, 2010, to approve MOVES2010, hereafter referred

to as MOVES. Upon publication of the Federal Register notice, MOVES became EPA’s approved

motor vehicle emission factor model for use by state and local agencies to estimate VOCs, NOx, CO,

PM10 and PM2.5 and other pollutants and precursors from cars, trucks, motorcycles, and buses.

MOVES replaces EPA’s previous emissions model, 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. An updated version of this software, MOVES2010a, was used for this analysis.

MOVES2010a is a minor update to MOVES2010. MOVES2010a includes general performance

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 28
improvements to MOVES2010, and also allows users to account for emissions under new car and

light truck energy and greenhouse gas standards.

EPA believes that MOVES should be used in ozone, carbon monoxide, PM, and nitrogen dioxide SIP

development as expeditiously as possible. The CAA requires that SIP inventories and control

measures be based on the most current information and applicable models that are available when

a SIP is developed. 

The MOVES model generated the emission factor files for base year-2005 and attainment year-2008

representing the transportation improvement programs implemented in the Belomar Region. The

model also generated emission factors for two future year scenarios 2015 and 2022. Table 19

summarizes the settings used in the MOVES run specification file and the MOVES County-Data

Manager.

D. Temperature and Relative Humidity

Meteorological conditions, especially temperature and humidity, significantly affect on-road vehicle

emissions. A series of Inter-Agency Consultation conference calls were held during the winter of

2010/2011 which established two important conclusions, among others. First, this redesignation effort

required the use of MOVES software for all mobile source emission analyses. And second, the annual

emission estimates would be based upon a single-season temperature/humidity approach. The single

season approach for temperature and relative humidity uses an annual average of weather data

collected by the National Oceanic and Atmospheric Administration (NOAA) National Climatic Data

Center (NCDC). The data used in this report, taken from the Wheeling Airport collection center, is

representative of all 12 months in 2009. 

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 29
Table 19: MOVES Inputs

RunSpec Parameter Settings

 MOVES Version 2010/08/26

 Scale Custom Domain

 MOVES Modeling Technique Emission Factor Method

 Rates per Distance, Rates per Vehicle

 Time Span Time Aggregation: Hour

 1 Month representing average annual temperatures

 All hours of day selected

 16 speed bins, Weekdays only

 Geographic Bounds Washington OH, Wood WV, Pleasant WV counties

 Vehicles/Equipment All source types, gasoline and diesel 

 Road Type All road types including off-network

 Pollutants and Processes NOx, All PM2.5 categories, SO2, Total Energy Consumption

 Strategies None

 General Output Units = grams, joules and miles

Output Emissions Time = hour, Location = custom area, on-road emission rates by road 

 type and source use type.

County Data Manager Sources

 Source Type Population Combination of local and default data

 Local data (Ohio and West Virginia) from motor vehicle registration 

 Default data used for source types 51, 52, 53, 61, and 62

 Future year growth rate based on MPO model Household growth rate.

 Vehicle Type VMT Combination of local and default data

 HPMSVTypeYear VMT = daily VMT from travel demand model 

 monthVMTFraction = default

 dayVMTFraction=default

 hourVMTFraction=local

 I/M Program None

 Fuel Formulation Default

 Fuel Supply Default

 Meteorology Data Local data obtained from NOAA National Climatic Data Center Data 

will consist of monthly high and low temperatures and daily relative 

humidity for 2002.

 Ramp Fraction Using the base year travel demand model for VHT fractions.

 Road Type Distribution Use ODOT and WV Division of Highways county summary VMT 

categorized by federal functional classes

 Age Distribution Combination of local and default data.

 Local data (Ohio and West Virginia) from motor vehicle registration

 Default data used for source types 41, 42, 43, 51, 52, 53, 61, and 62

 The same age distribution will be used for all analysis years

 Average Speed Distribution Default

 Alternative Fuel Type Default

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 30
E. Onroad Mobile Emission Estimations

Tables 20 through 24 contain the results of the emissions analysis for the appropriate years. All

emissions estimations are expressed in tons per year (tpy). 

Table 20: Marshall County, WV Emissions Estimations for Onroad Mobile Sources

2005 2008 2015 2022

NOx (tpy) 735.22 574.29 249.11 131.14

PM2.5 (tpy) 26.37 19.75 9.75 6.86

SO2 (tpy) 9.31 2.85 2.08 1.90

Annual VMT 717,730 732,645 761,241 787,271

Table 21: Ohio County, WV Emissions Estimations for Onroad Mobile Sources

2005 2008 2015 2022

NOx (tpy) 1,229.69 1,103.54 486.29 270.94

PM2.5 (tpy) 40.46 35.73 18.29 13.03

SO2 (tpy) 15.55 5.55 4.12 3.94

Annual VMT 1,217,316 1,508,349 1,612,721 1,745,734

Table 22: Summary of West Virginia Emissions Estimations for Onroad Mobile Sources

2005 2008 2015 2022

NOx (tpy) 1,964.90 1,677.83 735.40 402.08

PM2.5 (tpy) 66.83 55.48 28.03 19.89

SO2 (tpy) 24.86 8.40 6.21 5.84

Annual VMT 1,935,046 2,240,994 2,373,962 2,533,005

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 31
Table 23: Belmont County, OH Emissions Estimations for Onroad Mobile Sources

2005 2008 2015 2022

NOx (tpy) 3,179.52 2,593.58 1,279.25 587.61

PM2.5 (tpy) 105.74 88.66 45.08 26.32

SO2 (tpy) 30.84 9.38 6.72 6.21

Annual VMT 2,460,632 2,475,401 2,537,302 2,599,818

Table 24: Emissions Estimate Totals for the Onroad Mobile Source Sector for the

Wheeling, WV-OH Area

2005 2008 2015 2022

NOx (tpy) 5,144.42 4,271.41 2,014.65 989.70

PM2.5 (tpy) 172.57 144.14 73.11 46.21

SO2 (tpy) 55.70 17.78 12.92 12.05

Annual VMT 4,395,678 4,716,395 4,911,264 5,132,823

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 32
The following table shows the emissions totals, by sector, for each county in the nonattainment area. For a mo

Appendix C.Table 25: Percentage of Wheeling, WV-OH Emissions Attributable to Mobile Sources in 2005, 2008, 2015 

2005 2008 2015 2022 2005 2008 2015 2022 2005 2008 

Wheeling Marshall Co., WV Point ‐ EGU 31,541 23,269 6,067 6,366 3,826 4,440 2,121 2,271 96,378 35,074 

Marshall Co., WV Point ‐ NonEGU 3,131 2,759 2,341 2,166 525 410 316 272 19,110 16,503 

Marshall Co., WV Area 184 81 84 86 316 263 258 259 102 64 

Marshall Co., WV LM 671 249 250 252 25 8 8 9 31 13 

Marshall Co., WV NonRoad 113 108 86 69 12 11 7 5 10 2 

Marshall Co., WV OnRoad 735 574 249 131 26 20 10 7 9 3 

Marshall Co., WV Subtotal 36,375 27,040 9,077 9,070 4,731 5,152 2,721 2,824 115,641 51,658 

Ohio Co., WV Point ‐ EGU 0 0 0 0 0 0 0 0 0 0 

Ohio Co., WV Point ‐ NonEGU 6 6 6 6 11 4 4 4 1 1 

Ohio Co., WV Area 613 151 152 152 263 293 290 289 232 183 

Ohio Co., WV LM 972 0 0 0 38 0 0 0 44 0 

Ohio Co., WV NonRoad 170 158 113 87 21 19 15 11 15 3 

Ohio Co., WV OnRoad 1,230 1,104 486 271 40 36 18 13 16 6 

Ohio Co., WV Subtotal 2,991 1,418 757 516 372 352 328 317 308 193 

Total 39,366 28,457 9,834 9,587 5,103 5,505 3,048 3,141 115,949 51,851 

4.99% 5.90% 7.48% 4.19% 1.31% 1.01% 0.92% 0.63% 0.02% 0.02% 

Belmont Co. Belmont Co., OH Point ‐ EGU 4,150 4,168 4,478 4,738 94 70 21 0 37,330 15,126 

Belmont Co., OH Point ‐ NonEGU 23 21 20 19 3 3 4 4 0 0 

Belmont Co., OH Area 285 287 287 287 308 305 297 289 93 92 Belmont Co., OH MAR 262 247 161 79 6 6 3 1 23 16 Belmont Co., OH NonRoad 222 197 146 93 27 24 17 11 22 8 Belmont Co., OH OnRoad 3,180 2,594 1,279 588 106 89 45 26 31 9 

Belmont Co., OH Subtotal 8,121 7,513 6,370 5,804 545 497 388 332 37,499 15,252 

39.15% 34.52% 20.08% 10.12% 19.42% 17.85% 11.62% 7.93% 0.08% 0.06% 

Onroad Subtotal 5,144 4,271 2,015 990 173 144 73 46 56 18 

Total 47,487 35,971 16,204 15,390 5,648 6,001 3,436 3,472 153,448 67,103 

10.83% 11.87% 12.43% 6.43% 3.06% 2.40% 2.13% 1.33% 0.04% 0.03% 

NAA County Sector

NOx PM2.5 SO

WV Onroad Percentage

OH Portion Onraod PercentageWheeling, WV‐OH NAA Onroad Percentage

Wheeling, WV‐OH NAAWV Portion of NAA

Wheeling, WV‐OH NAA

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan 
Onroad mobile source SO2 constitutes less than one tenth of one percent (<0.1%) of the area’s

total SO2 emissions in the 2015 and 2022 horizon years.

Onroad mobile source NOx constitutes less than twelve and a half percent (<12.5%) of the

area’s total NOx emissions in the 2015 and 2022 horizon years.

Onroad mobile source PM2.5 constitutes less than two and a half percent (<2.5%) of the area’s

total PM2.5 emissions in the 2015 and 2022 horizon years.

The federal Transportation Conformity rule allows pollutants/precursors to be exempt from

conformity analysis under certain circumstances.

40CFR93.109(k) Areas with insignificant motor vehicle emissions. Notwithstanding the other

paragraphs in this section, an area is not required to satisfy a regional emissions analysis for

§93.118 and/or §93.119 for a given pollutant/precursor and NAAQS, if EPA finds through

the adequacy or approval process that a SIP demonstrates that regional motor vehicle

emissions are an insignificant contributor to the air quality problem for that

pollutant/precursor and NAAQS. The SIP would have to demonstrate that it would be

unreasonable to expect that such an area would experience enough motor vehicle emissions

growth in that pollutant/precursor for a NAAQS violation to occur. Such a finding would be

based on a number of factors, including the percentage of motor vehicle emissions in the

context of the total SIP inventory, the current state of air quality as determined by monitoring

data for that NAAQS, the absence of SIP motor vehicle control measures, and historical

trends and future projections of the growth of motor vehicle emissions. . . [emphasis added]

For the reasons outlined below, the DEP is herein making a finding that regional highway emissions

of PM2.5, NOx and SO2 are insignificant contributors to the nonattainment problem for the Wheeling

area. The finding will become final if EPA concurs and approves this SIP. 

First, the regional highway pollutant/precursor emissions constitute a relatively small fraction (<10%)

of the overall emissions in most cases, as shown in Table 25, above. The exception is NOx, which

contributes 11.87% in 2008 and 12.43% in 2015. Previous guidance from U.S. EPA regarding PM2.5

attainment demonstrations indicated that 10% is a benchmark for precursors and 5% is a benchmark

for direct PM. Therefore, DEP believes that the low contribution of both PM and SO2 to the 

emissions inventory, in concert with the considerations detailed below, clearly warrants an

insignificance finding with respect to transportation conformity The larger NOx contribution requires

more justification with respect to insignificance. 

40CFR93.109(k) says that emissions should be reviewed “in the context of the total SIP inventory”

which may include emission percentages, emission trends and, implicitly, the effectiveness of the

pollutant in forming PM. This last item is the reason that the benchmark for direct PM is considerably

less than the benchmark for the precursors. Further, the SEMAP atmospheric modeling for the

Wheeling area shows that NOx reductions are significantly less effective in reducing PM

concentrations than are reductions in SO2 or direct PM. This difference varies by season, such that

in summer it takes about 37 tons of NOx to equal one ton of PM. Annually, about 109 tons of NOx

reductions are equivalent to a one ton reduction in PM. In winter, NOx reductions may actually cause

a disbenefit because atmospheric chemistry creates more sulfates under reduced NOx conditions.

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 34
Therefore, in the context of transportation conformity, NOx is less important than PM or SO2 and its

percent emission contribution may be higher without adversely affecting air quality.

Another consideration is the significant emission decreases that are projected not only for the

highway sector but also for the total emissions inventory. As the charts below clearly demonstrate,

all three pollutants decrease over the period of the maintenance plan and the percent contribution of

highway emissions decrease as well.

Figure 6: Wheeling, WV-OH NOx Emissions by Sector 

Figure 7: Wheeling, WV-OH NAA PM2.5 Emissions by Sector 

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 35
Figure 8: Wheeling, WV-OH NAA SO2 Emissions by Sector 

Second, the current air quality (CY 2011) is represented by a design value of 13.0 ug/m3. This value

is significantly lower than the 15.1 ug/m3 design value (2002-2004) upon which the nonattainment

designation was based. Figure 2 on page 6 shows the general improvement of PM2.5 concentrations

from the year 2001 to date. The annual values dropped from 16.1 μg/m3

 in 2001 to 15.6 and 15.4, in

2002 and 2003, respectively. This may be attributed to an overall decrease in sulfates from SO2

reductions mandated by the Acid Rain Program, and preliminary implementation of controls to meet

CAIR. The design value then fluctuated from 14.4 to 16.2 during the 2004-2007 period. This

fluctuation was due to the year to year variability in PM2.5. It is common to many monitoring sites

and, in fact, is comparable to the year to year variability exhibited by several other West Virginia

sites. The values then dropped to 13.10 mg/m3 in 2008, 12.19 in 2009, 14.14 and 12.56 in 2010 and

2011, respectively. This may be attributed to SO2 and NOx decreases reductions mandated by the NOx

SIP Call, CAIR and the CAIR replacement rule, CSAPR. Overall, the PM concentrations have

improved since the beginning of the decade, as shown in Figure 2. On November 20, 2009, in

accordance with Section 179(c)(1) of the CAA, EPA determined that the Wheeling, WV-OH PM2.5

nonattainment area has attained the 1997 annual PM2.5 NAAQS by the applicable attainment date of

April 5, 2010 [74 FR 75465] The area is designated as attainment for all other criteria pollutants.

Given the relatively small contribution of the highway emissions to the total SIP inventory, highway

emissions are not likely to contribute significantly to the local PM2.5 mass concentrations. Among

other factors, this is largely due to the dominance of sulfates in the overall PM mass, coupled with

the very low contribution of highway sources to those sulfate totals.

Third, historically there have been no West Virginia SIP requirements for motor vehicle control

measures. The Wheeling area is subject to Transportation Conformity for the 8-hour ozone standard,

with SIP-approved, seasonal budgets for NOx and Volatile Organic Compounds (VOC). Further, the

entire nonattainment area is currently subject to Transportation Conformity for the PM2.5 standard.

Emissions analysis has been mandatory for annual highway emissions of direct PM and NOx. 

However, upon a positive adequacy review or approval of this SIP submittal, no highway emissions

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 36
analysis will be required under the annual PM2.5 standard. Highway analysis of seasonal ozone

precursors would continue to be mandatory. And, PM2.5 hot-spot analyses would continue to apply

for required projects under 40CFR93.116 and 93.123(b) of the Transportation Conformity Rule.

Fourth, Belomar has extensively researched the area local historical trends and growth patterns to

develop the LRTP/TIP and support transportation conformity evaluations. There is no reason to

expect highway motor vehicle emissions growth that would lead to a PM2.5 NAAQS violation.

Belomar and ODOT have estimated emissions out, at least, to the calendar year 2035 confirming this,

based on federally approved conformity determinations. The conformity analysis for the Wheeling

area took into account all the regional capacity projects, which are scheduled for implementation

through the transportation plan horizon year and the four year TIP.

The air quality analysis contained in the report was the basis for the most recent federally approved

conformity determination. The PM conformity tests were performed for calendar years 2002, 2009,

2018, 2025 and 2035. For each of those years, vehicle miles traveled (VMT) and Speed were

developed by the Federal Functional Class codes, which are derived from the regional traffic model

assignments that are made for each of those years. Pursuant to the Transportation Conformity interim

tests, NOx and direct PM were evaluated. The analysis employed the MOVES emissions factor

model. Despite monotonically increasing VMT, NOx emissions decrease dramatically from 4505.3

tons/year [2002] to 2691.8 tpy [2009] to 1171.9 tpy [2018] to 810.4 tpy [2025]. The decrease

continues to the last value to 665.7 tpy [2030], which is less than one-fourth of the 2009 level. DEP

believes this result solidly demonstrates that highway emissions will remain insignificant in the

future. Finally, DAQ notes that adequate safety margins (see Table 17) exist to potentially set NOx

motor vehicle emission budgets that are more than double the estimated emissions. Under that

scenario, there would never be any potential difficulty in demonstrating conformity but the MPO

would still have to devote resources to developing emission estimates in meaningless effort that

would provide no environmental benefit.

Figure 9: Onroad NOx Emissions Tons per Year

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 37
V. CONTROL MEASURES AND REGULATIONS

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

A. Reasonably Available Control Measures (RACM) and Reasonably Available Control

Technology (RACT)

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

to implement reasonably available control measures (RACM) and reasonably available control

technology (RACT).

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

to submit a SIP providing for implementation of all reasonably available control measures as

expeditiously as practicable (including such reductions in emissions from existing sources in the area

as may be obtained through the adoption, at a minimum, of reasonable available control technology).

EPA’s PM2.5 Implementation Rule [72FR20586, 29APR2007] interprets this requirement in great

detail. Under EPA’s approach, RACT is determined as part of the broader RACM analysis and

identification of all measures (for stationary, mobile, and Area sources) that are technically and

economically feasible, and that would collectively contribute to advancing the attainment date (i.e.

by one year or more). States are required to use a combined approach to RACT and RACM, that (1)

identifies potential measures that are reasonable, (2) uses modeling to identify the attainment date

that is as expeditious as practicable, and (3) selects the appropriate RACT and RACM.

Since RACT/RACM is determined based upon the emissions reductions needed for expeditious

attainment of the standard, and West Virginia monitored attainment of the 1997 PM2.5 NAAQS with

a 3-year design value of 14.2 μg/m3 for the 2006-2008 time period, and continued to monitor

attainment with a design value of 13.4 μg/m3

 for the 2007-2009 time period and 13.1 μg/m3 for the

2008-2010 time period, no further reductions are required for attainment of the standard. Therefore,

the Wheeling area is considered to be implementing all necessary RACM/RACT.

Furthermore, as EPA states on their website regarding the Clean Data Policy

[www.epa.gov/airquality/urbanair/sipstatus/policy_details.html]: 

Under EPA’s Clean Data Policy and the regulations that embody it, 40 CFR 51.918 (1997

8-hour ozone) and 51.1004(c) (PM-2.5), an EPA rulemaking determination that an area is

attaining the relevant standard suspends the area’s obligations to submit an attainment

demonstration, reasonable available control measures (RACM), reasonable further progress,

contingency measures and other planning requirements related to attainment for as long as

the area continues to attain. EPA’s statutory interpretation of the Clean Data Policy is

described in the “Final Rule to Implement the 8-hour Ozone National Ambient Air Quality

Standard—Phase 2" (Phase 2 Final Rule). 70 FR 71612, 71644-46 (Nov. 29, 2005) (ozone);

See also 72 FR 20585, 20665 (Apr. 25, 2007) (PM-2.5). EPA believes that the legal bases set

forth in detail in our Phase 2 Final rule, our May 10, 1995 memorandum from John S. Seitz,

entitled “Reasonable Further Progress, Attainment Demonstration, and Related Requirements

for Ozone Nonattainment Areas Meeting the Ozone National Ambient Air Quality Standard,”

and our December 14, 2004 memorandum from Stephen D. Page entitled “Clean Data Policy

for the Fine Particle National Ambient Air Quality Standards” are equally pertinent to all

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 38
NAAQS. EPA has codified the Clean Data Policy for 1997 8-hour ozone and PM-2.5, and has

also applied it in individual rulemakings for 1-hour ozone and PM-10.

Under the Clean Data Policy, EPA may issue a determination of attainment (known

informally as a Clean Data Determination) after notice and comment rulemaking determing

that a specific area is attaining the relevant standard. For such areas the requirement to submit

to EPA those SIP elements related to attaining the NAAQS is suspended for so long as the

area continues to attain the standard. These planning elements include reasonable further

progress (RFP) requirements, attainment demonstrations, RACM, contingency measures, and

other state planning requirements related to attainment of the NAAQS. The determination of

attainment is not equivalent to a redesignation, and the state must still meet the statutory

requirements for redesignation in order to be redesignated to attainment. A determination of

attainment for purposes of the Clean Data Policy/regulations is also not linked to any

particular attainment deadline, and is not necessarily equivalent to a determination that an

area has attained the standard by its applicable attainment deadline, e.g., under section 181(b).

On November 20, 2009 EPA determined that the Wheeling, WV-OH area had attained the 1997 PM2.5

NAAQS for the three-year period, 2006-2008. On December 2, 2011, in accordance with Section

179(c)(1) of the CAA, EPA determined that the Wheeling, WV-OH PM2.5 nonattainment area has

attained the 1997 annual PM2.5 NAAQS by the applicable attainment date of April 5, 2010 [74 FR

75465]. The determination was based upon complete, quality assured and certified ambient air

monitoring for the 2007-2009 monitoring period and EPA’s determination was in accordance with

the PM2.5 Implementation Rule of April 5, 2007 [72FR20664]. Complete quality-assured PM2.5

ambient air quality data for the most recent three (3) years, 2008 through 2010,and preliminary data

for 2009 through 2011, demonstrate that the air quality continues to meet the NAAQS for annual

PM2.5 in this nonattainment area. Therefore, RACM, including RACT, no longer applies.

B. Reasonable Further Progress

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

nonattainment areas to show reasonable further progress (RFP). 

EPA’s Implementation Rule requires RFP only for any area which a State projects an attainment date

beyond 2010. The RFP would provide emission reductions showing linear progress between 2002

and 2009. If a State demonstrates attainment will occur by 2010 or earlier, EPA considers the

attainment demonstration to demonstrate achievement of RFP.

On November 20, 2009 EPA determined that the Wheeling, WV-OH area had attained the 1997 PM2.5

NAAQS for the three-year period, 2006-2008. On December 2, 2011, in accordance with Section

179(c)(1) of the CAA, EPA determined that the Wheeling, WV-OH PM2.5 nonattainment area has

attained the 1997 annual PM2.5 NAAQS by the applicable attainment date of April 5, 2010 [74 FR

75465]. The determination was based upon complete, quality assured and certified ambient air

monitoring for the 2007-2009 monitoring period and EPA’s determination was in accordance with

the PM2.5 Implementation Rule of April 5, 2007 [72FR20664]. Complete quality-assured PM2.5

ambient air quality data for the most recent three (3) years, 2008 through 2010,and preliminary data

for 2009 through 2011, demonstrate that the air quality continues to meet the NAAQS for annual

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 39
PM2.5 in this nonattainment area. Therefore, RACM, including RACT, no longer applies. Therefore,

RFP is not required as long as the area continues to monitor attainment of the standard.

C. Inventory of Actual Emissions

Section 172(c)(3) requires states to submit a comprehensive inventory of actual emissions in the area,

including the requirement for periodic revisions as determined necessary. 40 CFR 51.1008 requires

such inventory to be submitted within three years of designation and requires a baseline emission

inventory for calendar year 2002 or other suitable year to be used for attainment planning.

In accordance with the Consolidated Emissions Reporting Rule (CERR), West Virginia 2002 and

2005 statewide comprehensive emissions inventories were submitted to EPA's CDX site on April 29,

2005 and June 1, 2007, respectively. The West Virginia 2008 comprehensive emissions inventory

was submitted to the CDX on May 30, 2010 consistent with the requirements of the Air Emissions

Reporting Requirements (AERR). We are hereby resubmitting the 2005, and 2008 comprehensive

inventories for the Wheeling nonattainment area.

West Virginia will continue to provide updates to future inventories in accordance with EPA’s AERR

rule. As discussed in Section III.F, West Virginia DAQ submits, and commits to submit, emission

inventories every three years. 

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

implemented.

1. NOx SIP Call, CAIR and CSAPR

The EPA NOx SIP Call required 22 states to pass rules that would result in significant emission

reductions from large EGUs, industrial boilers, and cement kilns in the eastern United States.

West Virginia passed this rule in 2002. NOx SIP Call requirements are incorporated into permits

along with monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. 

West Virginia DAQ also has an active enforcement program to address violations discovered by

field office staff. Compliance is tracked through the Clean Air Markets data monitoring program.

In West Virginia, this rule accounted for a reduction from 2003 levels of approximately 57

percent of NOx emissions by 2008 from sources subject to the rule. The other 21 states also

adopted these rules. 

On March 10, 2004, the EPA promulgated the CAIR. Beginning in 2009, EPA’s CAIR rule

required EGUs in 28 eastern states and the District of Columbia to significantly reduce emissions

of NOx and SO2. CAIR replaced the NOx SIP Call for EGUs. National NOx emissions were

expected 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. 

West Virginia submitted an initial CAIR SIP on June 1, 2006. Subsequently, WV submitted an

abbreviated CAIR SIP on June 8, 2007, which requested authority to allocate CAIR allowances.

Final revisions to the CAIR SIP were submitted on April 22, 2008. The revised CAIR SIP was

approved in a direct final action on August 2, 2009 (74FR38536 ). 

On July 6, 2010, EPA proposed a replacement to the CAIR program, the Transport Rule [75 FR

45210]. On July 6, 2011, EPA finalized the Transport Rule, now commonly referred to as the

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 40
Cross-State Air Pollution Rule (CSAPR) [76FR48208, 08AUG2011] in time for reductions to

begin in 2012. As finalized, the CSAPR would have preserved the initial reductions achieved

under CAIR and provided more reductions in NOx and SO2 emissions in 2012 and 2014, ahead

of the 2015 CAIR Phase 2.

EPA states on their Cross-State Air Pollution Rule homepage: “By 2014, power plants in states

common to both the Cross-State Air Pollution Rule and CAIR will achieve annual SO2 emissions

around 1.8 million tons lower and annual NOx emissions around 76,000 tons lower than what

would have been achieved at that time under CAIR.” (www.epa.gov/airtransport/basic.html) 

Controls for EGUs under the NOx SIP Call formally commenced May 31, 2004. Emissions

covered by this program have been generally trending downward since 1998 with larger

reductions occurring in 2002 and 2003. Data taken from the EPA Clean Air Markets web site,

quantify the gradual NOx reductions that have occurred in West Virginia as a result of Title IV

of the 1990 CAA Amendments and the beginning of the NOx SIP Call Rule. West Virginia

developed the NOx Budget Trading Program rules in 45CSR 1 and 26 in response to the SIP Call.

45CSR1 regulated EGUs and 45CSR26 regulated certain non-EGUs under a cap and trade

program based on an 77 percent reduction of NOx emissions from EGUs and a 60 percent

reduction of NOx emissions from non-EGUs, compared to historical levels. This cap was in place

through 2008, at which time the CAIR program superseded it as discussed above. Section III

above discussed the reductions West Virginia has seen as a result of CAIR.

On April 21, 2004, EPA published Phase II of the NOx SIP Call that established a budget for large

(greater than 1 ton per day emissions) stationary internal combustion engines. 45CSR1 addresses

stationary internal combustion engines, all used in natural gas pipeline transmission. EPA

approved this revision to the SIP on November 27, 2006. An 82 percent NOx reduction from 1995

levels was anticipated. Approval of the compliance plans occurred by August 4, 2006, and March

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

2. Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards

[65FR6698, 10FEB2000]

In February 2000, EPA published a federal rule to significantly reduce emissions from cars and

light trucks, including sport utility vehicles (SUVs). Under this proposal, automakers will be

required to sell cleaner cars, and refineries will be required to make cleaner, lower sulfur

gasoline. This rule applies nationwide. The federal rules phased in between 2004 and 2009. 

EPA estimated that NOx emission reductions will be approximately 77 percent for passenger cars,

86 percent for smaller SUVs, light trucks, and minivans, and 65 to 95 percent reductions for

larger SUVs, vans, and heavier trucks. The sulfur content of gasoline is estimated to be reduced

by up to 90 percent. VOC emission reductions will be approximately 12 percent for passenger

cars, 18 percent for smaller SUVs, light trucks, and minivans, and 15 percent for larger SUVs,

vans, and heavier trucks. 

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 41
3. Heavy-Duty Diesel Engines

[65FR59896, 06OCT2000]

In October 2000, EPA published a final rule for Highway Heavy Duty Engines, a program which

includes low-sulfur diesel fuel standards, which were phased in from 2004 through 2007. This

rule applies to heavy-duty gasoline and diesel trucks and buses. This rule resulted in a 40 percent

reduction in NOx from diesel trucks and buses, a large sector of the mobile sources NOx

inventory. It also estimated the level of sulfur in highway diesel fuel would be reduced by 97

percent by mid-2006.

4. Clean Air Non-road Diesel Rule

[69FR38958, 29JUN2004]

In June 2004, EPA published the Clean Air Non-road Diesel Rule. This rule applies to diesel

engines used in industries such as construction, agriculture, and mining. It also contains a cleaner

fuel standard similar to the highway diesel program. The new standards will cut emissions from

non-road diesel engines by more than 90 percent. Non-road diesel equipment, as described in this

rule, currently accounts for 47 percent of diesel particulate matter (PM) and 25 percent of NOx

from mobile sources nationwide. Sulfur levels will be reduced in non-road diesel fuel by 99

percent from 2004 levels, from approximately 3,000 parts per million (ppm) to 15 ppm in 2009. 

New engine standards took effect, based on engine horsepower, starting in 2008. Together, these

rules will substantially reduce local and regional sources of PM2.5 precursors.

E. New Source Review

West Virginia has a longstanding and fully implemented New Source Review (NSR) program.

45CSR14 - Permits for the Construction and Major Modification of Major Stationary Sources of Air

Pollution for the Prevention of Significant Deterioration (PSD), was originally approved by EPA as

part of the SIP with an effective date of May 12, 1986 [51FR12517]. 45CSR14 has been updated and

was last approved by EPA as part of the SIP with an effective date of December 4, 2006

[71FR64470]. 

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 reconstruct

without meeting all applicable NSR requirements. Once the area is redesignated, DAQ will

implement NSR through the PSD program. 

F. Assurance that existing control measures will remain in effect

West Virginia commits to maintaining the aforementioned control measures after redesignation. 

West Virginia hereby commits that any changes to its rules or emission limits applicable to PM2.5,

SO2, and NOx as required for maintenance of the annual PM2.5 standard in the Wheeling Area, will

be submitted to EPA for approval as a SIP revision. 

West Virginia, through the Division of Environmental Protection, DAQ, has the legal authority and

necessary resources to actively enforce any violations of its rules or permit provisions. After

redesignation, it intends to continue enforcing all rules that relate to the emission of PM2.5 precursors

in the Wheeling Area.

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 42
VI. SUPPLEMENTAL MODELING ANALYSES

Although EPA’s Redesignation Guidance does not require modeling nonattainment areas seeking

redesignation, extensive modeling has been performed covering the Wheeling, WV-OH area to

determine the effect of national emission control strategies on PM2.5 concentrations. These modeling

analyses determined that the Wheeling, WV-OH area is significantly impacted by regional transport

of PM2.5 and its precursors, and that regional SO2 and NOx reductions are an effective way to attain

the annual standards for PM2.5 in this area. Future year modeled annual PM2.5 concentrations are

expected to be reduced by 8% to 34% from baseline design values. Examples of these modeling

analyses are described below.

A. EPA Modeling for the Cross State Air Pollution Rule (Final Transport Rule)

EPA performed modeling to support the emission reductions associated with the Final Transport Rule

or the Cross State Air Pollution Rule (CSAPR), as it is currently called. EPA used the Comprehensive

Air Quality Model with Extension (CAMx) version 5.3 applied to the 2005 meteorology as processed

by the Mesoscale Model (MM5), Version 3.7.4. Emissions input into the CAMx included SO2, NOx,

VOC, NH3 and direct PM2.5 for 2005. The modeling was based on the annual fine particle design

values calculated from 2003 through 2005, 2004 through 2006, and 2005 through 2007. Future year

modeling was conducted, and the future year design values for 2012 and 2014 were evaluated for

attainment of the annual NAAQS for PM2.5 of 15 μg/m3, as shown in Table 26. The Marshall County

monitor (54-051-1002) and the Ohio County monitor (54-069-0010) represent the Wheeling area.

As indicated in the Air Quality Modeling Technical Support Document (TSD) for the CSAPR, air

quality modeling was performed for several emissions cases: a 2005 base year, a 2012 “no CAIR”

base case, a 2014 “no CAIR” base case, and the 2014 remedy case.

Modeling results for the Wheeling area (Marshall County monitor) show a 1.94 μg/m3

 (12.8%)

decrease in the average PM2.5 concentration for 2012 and a 2.44 μg/m3 (16.1%) decrease in the

average concentration for 2014, without accounting for CAIR or reductions required by the Transport

Rule or CSAPR. A reduction of 5.12 μg/m3

 (33.7%) from the 2003-2007 baseline is expected for

2014 with the implementation of the CSAPR. It should also be noted that the base year design value

used by EPA in their modeling was taken from 2003 through 2007 and is higher than the current 2009

through 2011 design value of 13.0 μg/m3

 in the area. Furthermore, the monitored design values for

2008-2010 and 2009-2011 of 13.1 and 13.0 μg/m3

, respectively, are less than the modeled base case

design vales for 2012 and 2014. Figures 2 and 3 (in Section II) show the downward trend of the

design values from 1999 through 2010 for the PM2.5 monitors in West Virginia and Ohio.

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 43
Table 26: CSAPR Annual PM2.5 Design Values (μg/m3)

Site ID County 2003-

2007

Average

Ambient

Value

2003-2007

Maximum

Ambient

Values

2012 Base

Case

Average

Values

2012 Base

Case

Maximum

Values

2014 Base

Case

Average

Values

2014 Base

Case

Maximum

Values

2

Re

Av

V

54-003-0003 Berkeley 15.93 16.19 14.09 14.32 13.70 13.92 54-009-0005 Brooke 16.52 16.80 14.33 14.58 13.84 14.09 54-009-0011 Brooke 16.04 16.37 13.87 14.15 13.39 13.66 54-011-0006 Cabell 16.30 16.57 14.71 14.94 14.05 14.28 54-029-1004 Hancock 15.76 16.64 13.73 14.51 13.28 14.03 54-033-0003 Harrison 13.99 14.19 13.17 13.36 12.71 12.90 54-039-0010 Kanawha 15.15 15.38 13.40 13.60 12.78 12.97 54-039-0011 Kanawha 13.17 13.17 11.67 11.67 11.13 11.13 54-039-1005 Kanawha 16.52 16.59 14.65 14.71 14.01 14.06 54-049-0006 Marion 15.03 15.25 14.22 14.43 13.76 13.95 54-051-1002 Marshall 15.19 15.33 13.25 13.38 12.75 12.87 54-061-0003 Monongalia 14.35 14.47 12.89 13.01 12.41 12.53 54-069-0010 Ohio 14.58 14.58 12.53 12.53 12.05 12.05 54-081-0002 Raleigh 12.90 13.03 11.22 11.33 10.70 10.80 54-107-1002 Wood 15.40 15.44 13.74 13.77 13.16 13.20 

Source: Air Quality Modeling Final Technical Support Document for the Final Cross-State Air Pollution Rule (www.epa.gov/airtransport/techinfo.html) 

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan 
B. EPA Modeling for Proposed Transport Rule 2010

EPA performed modeling to support the emission reductions associated with the Proposed Transport

Rule. EPA used the Comprehensive Air Quality Model with Extension (CAMx Version 5), applied

to the 2005 meteorology as processed by the Mesoscale Model (MM5), Version 3.7.4. Emissions

input into the CAMx included SO2, NOx, VOC, NH3 and direct PM2.5 for 2005. The modeling was

based on the annual fine particle design values calculated from 2003 through 2005, 2004 through

2006, and 2005 through 2007. Future year modeling was conducted, and the future year design values

for 2012 and 2014 were evaluated for attainment of the annual NAAQS for PM2.5 of 15 μg/m3, as

shown in Table 27. The Marshall County monitor (54-051-1002) and the Ohio County monitor (54-

069-0010) represent the Wheeling area.

Table 27: Proposed Transport Rule Modeling Results from EPA - 2010

Monitor ID County Design

Value 

2003-2007

(μg/m3)

Future

Design Value

2012 Base

(μg/m3)

Future

Design Value

2014 Base

(μg/m3)

Future

Design Value

2014 Remedy

(μg/m3)

54-003-0003 Berkeley 15.93 14.95 14.64 12.44

54-009-0005 Brooke 16.52 14.95 14.51 12.02

54-009-0011 Brooke 16.04 14.49 14.05 11.56

54-011-0006 Cabell 16.30 15.25 14.65 12.09

54-029-1004 Hancock 15.76 14.34 13.93 11.48

54-033-0003 Harrison 13.99 13.82 13.30 9.94

54-039-0010 Kanawha 15.15 14.01 13.45 10.77

54-039-0011 Kanawha 13.17 12.23 11.74 9.24

54-039-1005 Kanawha 16.52 15.28 14.69 11.97

54-049-0006 Marion 15.03 14.96 14.41 10.79

54-051-1002 Marshall 15.19 13.96 13.44 10.74

54-061-1003 Monongalia 14.35 13.72 13.14 10.01

54-069-0010 Ohio 14.58 13.18 12.72 10.15

54-081-0002 Raleigh 12.90 11.88 11.40 9.01

54-107-1002 Wood 15.40 14.31 13.77 11.40

Source: Technical Support Document for the Proposed Transport Rule, pages B-52 - B-53.

(www.epa.gov/airquality/transport/pdfs/TR_AQModeling_TSD.pdf)

EPA stated in the preamble to the proposed Transport Rule that the “baseline analysis takes into

account emissions reductions associated with the implementation of all federal rules promulgated by

December 2008 and assumes that CAIR is not in effect.” [75FR 45233, 02AUG2010]

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 45
Modeling results for the Wheeling area show a 1.23 μg/m3

 (8.1%) decrease in the PM2.5 concentration

for 2012 and a 1.75 μg/m3

 (11.5%) decrease in the concentration for 2014, without accounting for

CAIR or reductions required by the Transport Rule. A reduction of 4.45 μg/m3 (29.3%) from the

2003-2007 baseline is expected for 2014 with the implementation of the Transport Rule. It should

also be noted that the base year design value used by EPA in their modeling was taken from 2003

through 2007 and is higher than the current 2009 through 2011 design value of 13.0 μg/m3

 in the area. 

Furthermore, the monitored design values for 2007-2009, 2008-2010 and 2009-2011 of 13.4, 13.1

and 13.0 μg/m3

, respectively, are less than the modeled base case design vales for 2012 and 2014. 

Figures 2 and 3 (in Section II) show the downward trend of the design values from 1999 through

2010 for the PM2.5 monitors in West Virginia and Ohio.

C. VISTAS/ASIP Emissions and Air Quality Modeling to Support PM2.5 and 8-hour Ozone

State Implementation Plans 

VISTAS/ASIP conducted modeling to determine the impact of CAIR and other control programs in

the southeast, including West Virginia. The VISTAS/ASIP modeling used Version 4.51 of the

Community Multi-scale Air Quality (CMAQ) modeling system with enhanced secondary organic

aerosol (SOA) module (SOAmods) applied to the year 2002 meteorology, as processed by MM5.

Emissions input into CMAQ included SO2, NOx, VOC, NH3 and direct PM2.5 for 2002. The modeling

was based on 2000 through 2004 design values. Future year modeling for 2009, 2012 and 2018 was

conducted and the future year design values were determined with the emission reductions associated

with CAIR, as shown in Table 28. The Transport Rule is expected to provide reductions above and

beyond CAIR. The Marshall County monitor (54-051-1002) and the Ohio County monitor (54-051-

0010) represent the Wheeling area.

The VISTAS/ASIP modeling results for the Wheeling area predicted a 2.4 μg/m3

 (15.4%) decrease

in the projected PM2.5 concentration for 2009 from the 2002 design value. As shown in Table 1, the

actual monitored design value for 2007-2009 was 13.4 μg/m3

, a 2.2 μg/m3 (14.1%) improvement,

slightly less than predicted. The modeling results show a continued improvement in the area, with

a PM2.5 concentration of 12.1 μg/m3

 by 2018, a 22.4% reduction from the 2002 design value. The

current 2009-2011 design value for the area is 13.0 μg/m3

.

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 46
Table 28: VISTAS/ASIP 2009, 2012 and 2018 Modeling Results (with CAIR)

Monitor ID County 2002 Annual

DVC

Annual DVF

2009 2012 2018

54-003-0003 Berkeley 16.2 13.5 12.9 12.3

54-009-0005 Brooke 16.7 13.6 13.3 12.6

54-011-0006 Cabell 16.5 14.4 13.7 13.3

54-029-0011 Hancock 16.0 13.0 12.6 11.9

54-026-1004 Hancock 17.3 14.0 13.7 13.0

54-033-0003 Harrison 14.0 11.6 10.7 10.4

54-039-0010 Kanawha 15.4 13.1 12.2 11.7

54-039-1005 Kanawha 17.1 14.7 13.7 13.2

54-049-0006 Marion 15.3 12.9 12.0 11.6

54-051-1002 Marshall 15.6 13.2 12.7 12.1

54-055-0002 Mercer 12.7 10.6 9.7 9.1

54-061-0003 Monongalia 14.8 12.3 11.5 11.0

54-069-0008 Ohio 15.1 12.6 12.1 11.5

54-081-0002 Raleigh 13.1 11.0 10.1 9.5

54-089-0001 Summers 10.1 8.3 7.6 7.1

54-107-1002 Wood 16.1 13.8 13.4 12.6

Source: Technical Support Document for the Association for Southeastern Integrated Planning (ASIP) Emissions and Air

Quality Modeling to Support PM2.5 and 8-Hour Ozone State Implementation Plans, March 24, 2008.

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 47
D. EPA’s CAIR Modeling

One air quality modeling exercise that contains results for West Virginia’s nonattainment areas is the

EPA’s modeling for the CAIR. The Technical Support Document for the CAIR, March 2005,

provides modeling results with and without the implementation of the CAIR. Differences between

the EPA’s modeling and VISTAS modeling are:

• The meteorology was for 2001,

• The DVB was the weighted design values for the 1999-2003 period, and

• The modeling results were for 2010.

The DVF was calculated using the CAIR SMAT tool. The CAIR modeling results are listed in Table

29.

Table 29. EPA CAIR Modeling Results

State County Average 

99-03

2010

Base

2010

CAIR

2015

Base

2015

CAIR

WV Berkeley 16.18 15.69 13.43 15.32 12.73

WV Brooke 16.96 16.63 14.42 16.51 14.05

WV Cabell 17.22 17.03 15.08 16.86 14.64

WV Hancock 17.40 17.06 14.89 16.97 14.54

WV Harrison 14.40 14.15 11.90 13.82 11.31

WV Kanawha 17.75 17.56 15.27 17.17 14.66

WV Marion 15.58 15.32 12.90 14.98 12.23

WV Marshall 16.07 15.81 13.46 15.52 12.87

WV Mercer 12.97 12.52 10.82 12.14 10.16

WV Monongalia 14.96 14.77 12.31 14.37 11.40

WV Ohio 15.37 15.14 12.81 14.84 12.22

WV Raleigh 13.54 13.19 11.33 12.80 10.66

WV Summers 10.46 10.21 8.63 9.89 8.07

WV Wood 16.88 16.66 14.14 16.69 13.88

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 48
The EPA’s results were for the highest monitor in a county where more than one monitor is located.

The EPA’s modeling results predicted that the Wheeling (Marshall and Ohio Counties) nonattainment

area would be below the annual PM2.5 standard by 2010. Although this was one year later than the

attainment year for the area, the EPA’s predicted 2010 CAIR DVF was 0.4 μg/m3 higher than the

DAQ monitored 3 year design value for 2010 of 13.1 μg/m3

, but still supports that the area will

continue to attain the annual PM2.5 standard through 2015 with a projected design value of 12.9

μg/m3

. The current 2009-2011 design value for the area is 13.0 μg/m3.

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 49
VII. CONTINGENCY MEASURES

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

A. Maintenance Plan Review

West Virginia hereby commits to review its maintenance plan eight years after redesignation, as

required by Section 175(A) of the CAA.

B. Corrective Actions

West Virginia hereby commits to adopt and expeditiously implement necessary corrective actions

in the following circumstances:

1. Warning Level Response

A warning level response shall be prompted whenever the PM2.5 average of the weighted annual

mean of 15.5 μg/m3

 occurs in a single calendar year within the maintenance area. A warning level

response will consist of a study to determine whether the PM2.5 value indicates a trend toward

higher PM2.5 values or whether emissions appear to be increasing. The study will evaluate

whether the trend, if any, is likely to continue and, if so, the control measures necessary to reverse

the trend taking into consideration ease and timing for implementation as well as economic and

social considerations. Implementation of necessary controls in response to a warning level

response trigger will take place as expeditiously as possible, but in no event later than 12 months

from the conclusion of the most recent calendar year. 

Should it be determined through the warning level study that action is necessary to reverse the

noted trend, the procedures for control selection and implementation outlined under “action level

response” shall be followed.

2. Action Level Response

An action level response shall be prompted whenever a two-year average of the weighted annual

means of 15.0 μg/m3

 or greater occurs within the maintenance area. A violation of the standard

(three-year average of the weighted annual means of 15.0 μg/m3 or greater) shall also prompt an

action level response. In the event that the action level is triggered and is not found to be due to

an exceptional event, malfunction, or noncompliance with a permit condition or rule requirement,

West Virginia DAQ in conjunction with the metropolitan planning organization or regional

council of governments, will determine additional control measures needed to assure future

attainment of the 1997 PM2.5 NAAQS. 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. West Virginia DAQ will also consider the timing of an action

level trigger and determine if additional, significant new regulations not currently included as part

of the maintenance provisions will be implemented in a timely manner and will constitute our

response.

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 50
3. Control Measure Selection and Implementation

Adoption of any additional control measures is subject to the necessary administrative and legal

process. This process will include publication of notices, an opportunity for public hearing, and

other measures required by West Virginia law for rulemaking. 

If a new measure/control is already promulgated and scheduled to be implemented at the federal

or State level, and that measure/control is determined to be sufficient to address the upward trend

in air quality, additional local measures may be unnecessary. Furthermore, West Virginia DAQ

will submit to EPA an analysis to demonstrate the proposed measures are adequate to return the

area to attainment. 

C. Potential Contingency Measures

Contingency measures to be considered will be selected from a comprehensive list of measures

deemed appropriate and effective at the time the selection is made. The selection of measures will

be based on cost-effectiveness, emission reduction potential, economic and social considerations or

other factors that West Virginia DAQ deems appropriate. West Virginia DAQ will solicit input from

all interested and affected persons in the maintenance area prior to selecting appropriate contingency

measures. Because it is not possible at this time to determine what control measures will be

appropriate at an unspecified time in the future, the list of contingency measures outlined below is

not exhaustive.

1) Diesel reduction emission strategies.

2) Alternative fuel (e.g., liquid propane and compressed natural gas) and diesel retrofit programs

for fleet vehicle operations.

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

4) Concrete manufacturing - upgrade wet suppression.

5) Additional NOx RACT statewide.

No contingency measure shall be implemented without providing the opportunity for full public

participation during which the relative costs and benefits of individual measures, at the time they are

under consideration, can be fully evaluated.

D. PM2.5, SO2, and NOx sources potentially subject to future additional control requirements.

The following is a list of PM2.5, SO2, and NOx sources potentially subject to future controls.

• ICI Boilers - SO2 and NOx controls;

• EGUs;

• process heaters;

• internal combustion engines;

• combustion turbines;

• other sources greater than 100 tons per year;

• Fleet vehicles;

• Concrete manufacturers;

• Aggregate processing plants.

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 51
VIII. PUBLIC PARTICIPATION

West Virginia published notification for a public hearing and solicitation for public comment

concerning the draft redesignation petition and maintenance plan in the State Register and the

Intelligencer, Wheeling News-Register on January 27, 2011. 

The public hearing to receive comments on the redesignation request was held at 6:00 p.m. on

February 28, 2012, at the West Virginia Division of Environmental Protection Headquarters located

at 601 57th Street, SE, Charleston, WV. There were no attendees at the public hearing. The public

comment period closed on February 28, 2012. No comments were received. Appendix F includes a

copy of the public notice, copies of the published notifications and a transcript of the hearing.

Wheeling, WV 1997 PM2.5 Redesignation and Maintenance Plan Page 52
IX. CONCLUSIONS

The Wheeling PM2.5 nonattainment area has attained the 1997 annual and 24-hour NAAQS for PM2.5

and complied with the applicable provisions of the 1990 Amendments to the CAA regarding

redesignations of PM2.5 nonattainment areas. Documentation to that effect is contained herein. West

Virginia DAQ has prepared a redesignation request and maintenance plan that meet the requirements

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

Based on this presentation, the West Virginia portion of the Wheeling PM2.5 nonattainment area 

meets the requirements for redesignation under the CAA and EPA guidance. West Virginia has

performed an analyses showing the air quality improvements are due to permanent and enforceable

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

regional SO2 and NOx reductions will ensure continued compliance (maintenance) with the standard

with an increasing margin of safety.

The State of West Virginia hereby requests that the Wheeling 1997 PM2.5 nonattainment area be

redesignated to attainment simultaneously with EPA approval of the CAA section 175A maintenance

plan provisions contained herein. 

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