west virginia department of environmental protection



# REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE WEST VIRGINIA PORTION OF THE WHEELING, WV-OH 1997 PM 2.5 

# NONATTAINMENT AREA

FINAL March 2012

Promoting a healthy environment.Page intentionally left blank.

Page iiTable 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 PM 2.5 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 PM 2.5 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. PM 2.5 Emissions Demonstrations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 17 B. NO x Emissions Demonstrations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 19 C. SO 2 Emissions Demonstrations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 21 D. Summary of PM 2.5 , NO x , and SO 2 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 PM 2.5 SIP revisions have been fully implemented. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 40

Page iii Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance Plan1. NO x 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 PM 2.5 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. PM 2.5 , SO 2 , and NO x sources potentially subject to future additional control requirements.

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

VIII. PUBLIC PARTICIPATION

......................................... Page 52

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

Page iv Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanList of Tables Table 1: Wheeling Nonattainment Area Design Values for the 1997 Annual and 24-hr PM 2.5 NAAQS

............................................................. Page 5 Table 2: Reductions in SO 2 and NO x EGU Emissions Between 2008 and 2010

........ Page 13 Table 3: Marshall County, WV PM 2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2022 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 17 Table 4: Ohio County, WV PM 2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2022 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 18 Table 5: Belmont County, OH PM 2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2022 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 18 Table 6: Wheeling Nonattainment Area PM 2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2022 (tpy)

....................................................... Page 19 Table 7: Marshall County, WV NO x Emission Inventory Totals for 2005, 2008, 2015 and 2022 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 19 Table 8: Ohio County, WV NO x Emission Inventory Totals for 2005, 2008, 2015 and 2022 (tpy)

................................................................... Page 20 Table 9: Belmont County, OH NO x Emission Inventory Totals for 2005, 2008, and 2015 and 2022 (tpy)

........................................................... Page 20 Table 10: Wheeling Nonattainment Area NO x Emission Inventory Totals for 2005, 2008, 2015 and 2022 (tpy)

....................................................... Page 21 Table 11: Marshall County, WV SO 2 Emission Inventory Totals for 2005, 2008, 2015 and 2022 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 21 Table 12: Ohio County, WV SO 2 Emission Inventory Totals for 2005, 2008, 2015 and 2022 (tpy)

................................................................... Page 22 Table 13: Belmont County, OH SO 2 Emission Inventory Totals for 2005, 2008, 2015 and 2022 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 22 Table 14: Wheeling Nonattainment Area SO 2 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

Page v Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 25: Percentage of Wheeling, WV-OH Emissi ons Attributable to Mobile Sources in 2005, 2008, 2015 and 2022

.................................................. Page 33 Table 26: CSAPR Annual PM 2.5 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

Page vi Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanList of Figures Figure 1: Map of the Wheeling, WV-OH nonattainment area and monitor locations

.... Page 5 Figure 2: West Virginia PM 2.5 Annual Design Values, 1999-2001 through 2008-2010. . . Page 7 Figure 3: Ohio PM 2.5 Annual Design Values, 1999-2001 through 2007-2009.

......... Page 8 Figure 4: PM 2.5 Annual Mean National Trends

................................. Page 9 Figure 5. Belomar Region . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 27 Figure 6: Wheeling, WV-OH NO x Emissions by Sector . . . . . . . . . . . . . . . . . . . . . . . . . Page 35 Figure 7: Wheeling, WV-OH NAA PM 2.5 Emissions by Sector . . . . . . . . . . . . . . . . . . . . Page 35 Figure 8: Wheeling, WV-OH NAA SO 2 Emissions by Sector . . . . . . . . . . . . . . . . . . . . . Page 36 Figure 9: Onroad NO x Emissions Tons per Year . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 37

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Page viii Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanList 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

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Page x Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanREDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE WEST VIRGINIA PORTION OF THE WHEELING, WV-OH 1997 PM 2.5 NONATTAINMENT AREA

I. INTRODUCTION The Wheeling, WV-OH PM 2.5 nonattainment area (Wheeling area) is a multi-state nonattainment area, comprising Marshall and Ohio Counties in We st Virginia, and Belmont County in Ohio. The area monitored attainment of the 1997 PM 2.5 standard with a design value for 2006-2008 of 14.2 μg/m 3 , 2007-2009 of 13.4 μg/m 3 , 2008-2010 of 13.1 μg/m 3 and 2009-2011 of 13.0 μg/m 3 . The State of West Virginia herein requests redesignation by the United States Environmental Protection Agency of Marshall and Ohio Counties to attainment re lative to the 1997 PM 2.5 National Ambient Air Quality Standard. The State of Ohio also plans to request redesignation of Belmont County, Ohio to attainment relative to the 1997 PM 2.5 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 PM 2.5 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 associ ated 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 PM 2.5 air quality standards for at least ten more years. B. Background The Clean Air Act (CAA) requires areas failing to meet a Nationa l Ambient Air Quality Standard (NAAQS) to develop State Implementation Plans (SIPs) to expeditiously attain and maintain the standard. The EPA revised the NAAQS for particul ate matter in July 1997. It replaced the existing PM 10 standard with a health based PM 2.5 standard and retained the PM 10 standard as a “coarse” standard protecting welfare. The 1997 PM 2.5 standards include an annual standard set at 15.0 micrograms per cubic meter (μg/m 3 ), based on the 3-year average of annual mean PM 2.5 concentrations and a 24-hour standard of 65 μg/m 3 , based on the 3-year average of the 98 th 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, th e D.C. Circuit remanded, without vacatur, the standard back to EPA. The remand did not ques tion 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 reh earing 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.

Page 1 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanThe D.C. Circuit heard arguments in this rema nded case in December 2001, and issued its decision on March 26, 2002. The D.C. Circuit rejected the cl aims that the EPA had acted arbitrarily and capriciously in setting the levels of the standards. On December 17, 2004, EPA promulgated the initial PM 2.5 nonattainment areas designations for the PM 2.5 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, PM 2.5 nonattainment designations are simply labeled “nonattainment.” The CAA Amendments require states with PM 2.5 nonattainment areas to submit a pl an within three years of the effective date of the designations (April 5, 2008) detailing how the PM 2.5 standards would be attained by April 5, 2010. On November 20, 2009 [74 FR 60199] EPA determined th at three areas in West Virginia designated nonattainment for the 1997 fine particulate (PM 2.5 ) National Ambient Air Quality Standard (NAAQS) had attained the 1997 PM 2.5 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 PM 2.5 NAAQS during the 2006-2008 monitoring period. Available monitoring data fo r 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 m easures, 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 PM 2.5 NAAQS. On December 2, 2011 [76FR75464] EP A determined that the Parkersburg-Marietta, WV-OH area and the Wheeling, WV-OH area had attained the 1997 annual PM 2.5 NAAQS by their applicable attainment date of April 5, 2010. These determina tions 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 PM 2.5 nonattainment area (Wheeling area) is a multi-state nonattainment area, comprising Marshall and Ohio Counties in We st Virginia, and Belmont County in Ohio. This area is shown in Figure 1 under Section II.A. The Wh eeling 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/m 3 annual standard as a result of the Clean Data Determination West Vi rginia DEP was not required to develop a plan to reduce oxides of nitrogen (NO x ), sulfur dioxide (SO 2 ) and direct PM 2.5 emissions and demonstrate that the area would meet the federal annual air quality standard by April 5, 2010.

Page 2 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanThis 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 PM 2.5 standard. In addition, the State of Ohio also plans to submit a request for their portion of the Wheeling area.

Page 3 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanII. 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 comp letes all five of the required elements as detailed below. A. The Wheeling Area has attained the 1997 PM 2.5 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 comp lete years of monitoring data are required to demonstrate attainment at a monitoring site. The annual PM 2.5 primary and secondary ambient air quality standards are met at an ambient air quality m onitoring site when the three-year average of the annual average is less than 15.0 μg/m 3 . While calculating design valu es, three significant digits must be carried in the computations, with final values rounded to the nearest 0.1 μg/m 3 . Decimals 0.05 or greater are rounded up, and those less th an 0.05 are rounded down, so that 15.049 μg/m 3 is the largest concentration that is less than, or equal to 15.0 μg/m 3 . Values at or below 15.0 μg/m 3 meet the standard; values equal to or greater than 15.1 μg/m 3 exceed the standard. An area is in compliance with the annual PM 2.5 NAAQS only if every monitoring site in the area meets the NAAQS. An individual site’s 3-year average of the annual averag e 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 PM 2.5 concentrations in the Wheeling, WV-OH nonattainment area. The monitors are located in West Virginia and operated by the West Vi rginia Division of Air Quality (DAQ). The location of the monitoring site s for this nonattainment area are shown in Figure 1. A listing of the design values ba sed 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 preliminar y 2011 data that will be certified and recorded in the AQS database in accordance with 40 CFR 58.10.

Page 4 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance Plan107-1002 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 PM 2.5 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 standa rd, all monitors in the area monitor attainment. 2011 data is preliminary, and has not yet been certified. 069-0010

051-1002

Page 5 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanThe design values calculated for the Wheeling area demonstrate that the 1997 PM 2.5 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, a nd controls for EGUs, at the national, regional and local level. National monitoring for PM 2.5 began in 1999. There has been a clear downward trend in design values for all monitors in West Virginia and Oh io, 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 PM 2.5 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 PM 2.5 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 PM 2.5 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 PM 2.5 ambient air quality monitoring data for the recent three (3) year period 2008 through 2010, and preliminary data fo r the 2009 through 2011 period, demonstrate that the air quality continues to meet the NAAQS for annual PM 2.5 in this nonattainment area. The NAAQS attainment, accompanied by decreases in emi ssion 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 PM 2.5 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 necessa ry in the future. DAQ will continue to quality assure the monitoring data to meet the requirement s of 40 CFR 58 and all other federal requirements. Connection to a central station and updates to th e 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.

Page 6 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanFigure 2: West Virginia PM2.5Annual Design Values, 1999-2001 through 2008-2010.Data Source:http://www.epa.gov/airtrends/values.html, from Excel spreadsheet: PM25dv20082010Final.xls1997 Annual Std = 15 ug/m3Page 7Wheeling, WV 1997 PM2.5Redesignation and Maintenance PlanFigure 3: Ohio PM2.5Annual Design Values, 1999-2001 through 2007-2009.Data Source:http://www.epa.gov/airtrends/values.html, from Excel spreadsheet: PM25dv20082010Final.xls1997 Annual Std = 15 ug/m3Page 8Wheeling, WV 1997 PM2.5Redesignation and Maintenance PlanFigure 4: PM 2.5 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 PM 2.5 nonattainment areas designations for the PM 2.5 standards across the country, including the Wheeling, WV-OH area. Modifications to those designations were made and an effective date wa s set at April 5, 2005. Unlike Subpart 2 of the CAA Amendments of 1990 which defined five ozone nona ttainment classifications for the areas that exceed the NAAQS based on the severity of the ozone levels, PM 2.5 nonattainment designations are simply labeled “nonattainment.” The C AA Amendments require states with PM 2.5 nonattainment areas to submit a plan within three years of th e effective date of the designations (April 5, 2008) detailing how the PM 2.5 standards would be attained by April 5, 2010. On November 20, 2009 determined that the Wheeling area had monito red 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 pla nning SIPs related to attainment of the standard for as long as the area continues to meet the 1997 PM 2.5 NAAQS. On December 2, 2011, in accordance with Section 179(c)(1) of the CAA, EPA determined that the Wheeling, WV-OH PM 2.5 nonattainment area had attained the 1997 annual PM 2.5 NAAQS by the applicable attainment date of April 5, 2010 [76FR75465]. The DEP believes that a ll applicable requirements under CAA section 110(k) have been met.

Page 9 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanC. The Wheeling Area’s Air Quality Improveme nt 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 Pl an for the Wheeling Area Which Ensures Attainment of the 1997 PM 2.5 Standard for at least 10 Years Section 107(d)(3)(E) of the CAAA stipulates that fo r an area to be redesignated to attainment EPA must approve a maintenance plan that meets th e 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 Wh eeling 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 Rele vant Requirements under CAA Section 110 and Part D For purposes of redesignation, a state must meet a ll 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. Subpa rt 4 of Part D consists of more specific requirements applicable to particulate matter (specifically to address PM 10 ). However, for the purpose of implementing the 1997 PM 2.5 standard, EPA’s Implementation Ru le stated Subpart 1, rather than Subpart 4, is appropriate for the purpose of implementing PM 2.5 .[72 FR 20589] 1. Section 110(a) requirements Section 110(a) of Title I of th e 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 hear ing, and that, among other things, it must include enforceable emission limitations and other contro l measures, means or techniques necessary to meet the requirements of the CAA; provide for establishment and operation of appropriate devices, methods, systems and procedures necessa ry to monitor ambient air quality; provide for implementation of a source permit program to re gulate 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 deterior ation (PSD) and Part D, NSR permit programs; include criteria for stationary source emissi on control measures, monitoring, and reporting; include provisions for air quality modeling; and pr ovides for public and local agency participation in planning and emission control rule developm ent. 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.

Page 10 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanSection 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 SO 2 and NO x emissions from large electric generating units (EGU). West Virg inia has met the requirements of the federal CAIR to reduce NO x and SO 2 emissions contributing to downwind states. On August 4, 2009, EPA approved West Virginia's CAIR progr am [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, th e 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 Regi ster on August 8, 2011 [76FR48208]. Under the CSAPR, EPA adopted Federal Implementation Plan s (FIPs) for each state covered by the rule, including West Virginia. The CSAPR further a ssists states in addressing their obligations regarding regionally transported pollution by providing reductions in NO x and SO 2 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 redesigna tions because they only have meaning for areas not attaining the standard. The requirements fo r 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 procedur es 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.

Page 11 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanIII. 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 ma intenance 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 Vi rginia DAQ selected the year 2022 as the end year of the maintenance plan for this redesignation re quest. 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 PM 2.5 , NO x and SO 2 must each be less than the corresponding emissions in the nonattainment year (2005). The reductions must be attributable to federally enforceable emissi on 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 SO 2 and 159,481 tons of NO x 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 na tionally. Data available for 2010, show the SO 2 and NO x reductions which were implemented under CAIR.

Page 12 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 2: Reductions in SO 2 and NO x EGU Emissions Between 2008 and 2010 SO 2 NO x 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 NO x and SO 2 . CAIR replaced the NO x SIP Call for EGUs. The intent of the CAIR program was for national NO x emissions to be cut from 4.5 million tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3 million tons in 2018 in 28 states. St ates were required to submit a CAIR SIP as part of this effort. West Virginia DEP submitted a CAIR SIP to EP A on June 1, 2006. Revisions to the CAIR SIP were submitted on April 22, 2008. The revised CAIR SI P was approved on August 4, 2009 (74 FR 38536). As a result of CAIR, EPA project ed that in 2009 emissions of NO x would decrease from a baseline of 179,000 tons per year to 63,000 tons pe r year while in 2010 emissions of SO 2 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 NO x would decrease to 44,000 tons per year while emissions of SO 2 would decrease to 118,000 tons per year, within West Virginia. On December 23, 2008, EPA’s CAIR program was re manded 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-fi red 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 SO 2 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 altoge ther, instead relying on banked allowances (because there is not an existing large bank of NO x allowances, NO x allowance prices have not been affected as significantly). For these reasons, EPA is tracking SO 2 and NO x emissions closely each quarter to evaluate further pr ogress and assess whether backsliding may be Page 13 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance Planoccurring 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, 08A UG2011] 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 NO x and SO 2 emissions in 2012 and 2014, ahead of the 2015 CAIR Phase 2. West Virginia DAQ is in agreement with the anal ysis by U.S. EPA that the CAIR program provided real reductions. We believe these reductions have assisted with PM 2.5 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 PM 2.5 standard to continue. As stated by EPA regarding the final Transport Rule or CSAPR: This rule will prohibit all significant contri bution to nonattainment and interference with respect to the annual and 24-hour PM 2.5 . In addition, it will resolve air quality issues at most nonattainment and maintenance receptors iden tified 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 PM 2.5 standard, EPA projects that this rule will help assure th at all areas in the east fully resolve their nonattainment and maintenance concerns. This ru le 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 M odel (IPM) emission projections for the EGUs (Kammer and Mitchell Power Stations) in the Wh eeling 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, dete rministic 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 (SO 2 ), nitrogen oxides (NO x ), carbon dioxide (CO 2 ), and mercury (Hg) from th e 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 NO x and 16,085 tons of SO 2 . Under CSAPR, for the same facilities in 2020, IPM projected 6,215 tons of NO x and 13,645 tons of SO 2 [ 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 Page 14 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance Planare consistent and the DAQ believes that CAIR or any likely replacement for CAIR, will constrain NO x and SO 2 emissions sufficiently to ensure that maintenance level emissions are not exceeded during the maintenance period. Furthermore, as shown in Section VI - Supplem ental Modeling Analyses, recent modeling -- CAIR, proposed Transport Rule, CSAPR (Final Transpor t 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 th at the Wheeling area will con tinue to maintain the 1997 PM 2.5 NAAQS. Therefore, it is West Virginia DAQ’s belief it is most appropriate to evaluate West Virginia’s demonstration that the projected level of emi ssions is sufficient to maintain the annual PM 2.5 standard by assessing future year emissions that incl ude the CSAPR program. Furthermore, modeling conducted as part of the Transport Rule developmen t (both the proposed Transport Rule and the Final Transport Rule, or CSAPR) projects the counties w ithin 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 project ed 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/LM I/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 S CCs. A list of SCCs contained in the 2008 WV inventory was compiled and the associated w ith each NAICS code for which there was a Workforce WV growth factor. Then directly pr oportional growth factors were calculated and applied to Workforce WV’s 2018 growth fact or 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 monthl y NONROAD Model runs for 2015 and 2022, and summing the monthly data to obtain annual data. • Ohio provided the emission estimates for th e 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 documen t 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 Page 15 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance Planwere made using federally approved interagency consultation procedures. As discussed in Section IV, DAQ determined that the mobile em ission 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 PM 2.5 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 follo wing 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 ta bles are: Electrical Generating Unit (EGU); Non-Electrical Generating Unit (Non-EGU); Non-ro ad 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 fr om 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.

Page 16 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanA. PM 2.5 Emissions Demonstrations

The 2005 and 2008 actual PM 2.5 EGU and NonEGU emissions data below reflects PM 2.5 -primary emissions. Although some facilities reported both PM 2.5 -pri and the PM fraction emissions, not all facilities reported PM 2.5 -pri emissions. When PM 2.5 -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 PM 2.5 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

Page 17 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 4: Ohio County, WV PM 2.5 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 PM 2.5 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

Page 18 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 6: Wheeling Nonattainment Area PM 2.5 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 PM 2.5 Total 5,103 5,505 3,048 2,456 3,141 2,364 Belmont, OH 545 497 388 109 332 165 Combined PM 2.5 Total 5,648 6,001 3,436 2,565 3,472 2,529

B. NO x Emissions Demonstrations
Table 7: Marshall County, WV NO x 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

Page 19 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 8: Ohio County, WV NO x 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 NO x 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

Page 20 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 10: Wheeling Nonattainment Area NO x 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 NO x 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 NO x Total 47,487 35,971 16,204 19,767 15,390 20,580

C. SO 2 Emissions Demonstrations

Table 11: Marshall County, WV SO 2 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

Page 21 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 12: Ohio County, WV SO 2 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 SO 2 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

Page 22 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 14: Wheeling Nonattainment Area SO 2 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 SO 2 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 SO 2 Total 153,448 67,103 36,843 30,260 31,487 35,617

D. Summary of PM 2.5 , NO x , and SO 2 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 PM 2.5 5,505 3,048 2,457 3,141 2,364 NO x 28,457 9,834 18,623 9,587 18,870 SO 2 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 PM 2.5 497 388 109 332 165 NO x 7,513 6,370 1,143 5,804 1,709 SO 2 15,252 8,886 6,366 6,157 9,095

Page 23 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 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 PM 2.5 6,001 3,436 2,565 3,472 2,529 NO x 35,971 16,204 19,767 15,390 20,581 SO 2 67,103 36,843 30,260 31,487 35,616
As shown in the table above (Table 17), PM 2.5 emissions in the nonattainment area are projected to decrease by 2,565tons in 2015 and 2,529 tons in 2022. NO x emissions in the nonattainment area are projected to decrease by 19,767 tons in 2015 and 20,581 tons in 2022. SO 2 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 PM 2.5 , NO x and SO 2 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 [65FR 6698,10FEB2000], 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 SO 2 emissions beginning December 31, 2007 and to operate their SCR continuously to reduce NO x emissions beginning January 1, 2009.

Page 24 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanE. Air Quality Improvement is Based on P ermanent and Enforceable Emission Reductions A demonstration that improvement in air quality be tween 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 s ites indicate that air quality met the NAAQS for PM 2.5 in 2007-2009 and in 2008-2010. EPA’s redesignation gui dance (Policy Memo from John Calcagni, Director, Air Quality Management Di vision 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 leve l of the attainment i nventory, or by modeling to show that the future mix of sources and emissi ons rates will not cause a violation of the NAAQS.”

Permanent and enforceable reductions of PM 2.5 , NO x , and SO 2 emissions have contributed to the attainment of the annual PM 2.5 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 Mo tor Vehicles: Tier 2 Motor Vehicle Emission Standards and Gasoline Sulfur Control Requirements), Title IV of the CAA, the NO x SIP Call, CAIR, CSAPR, and federal consent decrees requiring reductions of SO 2 and NO x 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 NO x 35,691 27,437 8,254 EGU PM 2.5 3,920 4,510 (590)

EGU SO 2 133,708 50,200 83,508 Onroad NO x 5,145 4,272 873 Onroad PM 2.5 172 145 27

Onroad SO 2 56 18 38 Nonroad NO x 505 463 42 Nonroad PM 2.5 60 54 6

Nonroad SO 2 47 13 34

Page 25 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanF. 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 coun ties are required to submit air emissions information annually. West Virginia DAQ prepares a new periodic inventory for all PM 2.5 precursor emission sectors every three years in accordance with EP A’s Air Emissions Reporting Requirements (AERR). These PM 2.5 precursor inventories will be prepared for fu ture years as necessary to comply with the inventory reporting requirements established in th e CFR. Emissions information will be compared to the 2005 base year and the 2022 projected maintena nce year inventories to assess emission trends, as necessary, and to assure continued compliance with the annual PM 2.5 standard.

Page 26 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanIV. 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 Tran sportation System Development-Modeling and Forecasting Section and the Belomar Regional Council, in coordination with the Ohio Environmental Protection Agency (OEPA) and West Virginia De partment of Environmental Protection (WVDEP). This evaluation represents the latest population a nd 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-cen tral 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 t ool 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 in to 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, ar e assumed to change linearly with time between 2000 and the Plan Horizon year of 2035. The Wheeling area travel demand model network c overs 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 dist ribution of trips by trip purpose and direction are constrained to match the hourly distribution of traffi c counts. Trip distribution also begins with a trip-length distribution by purpose bo rrowed from another urban area and adjusted to ensure modeled Page 27 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanVMT 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 ra tes 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/repor t.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 a ll specified volume groups. Overall modeled VMT for 2000 was less than 1% different than HPMS estim ated 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) a nd external roadway “stations” (31) are the basic geographic units for estimating travel patterns. So cioeconomic data used to forecast these patterns include household population, school enrollment, vehicl e 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 regist ration files, and QCEW/ES202 employment data. All data sources were geocoded to the zone level. Fu ture 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, NO x , CO, PM 10 and PM 2.5 and other pollutants and precursors from cars, trucks, motorcycles, and buses. MOVES replaces EPA’s previous emissions mode l, 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 Page 28 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance Planimprovements 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 oz one, carbon monoxide, PM, a nd nitrogen dioxide SIP development as expeditiously as possible. The CAA requires that SIP inventories and control measures be based on the most current informati on and applicable models that are available when a SIP is developed. The MOVES model generated the emission factor f iles 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 mob ile source emission analyses. And second, the annual emission estimates would be based upon a single-s eason 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 Atmospheri c Administration (NOAA) National Climatic Data Center (NCDC). The data used in this report, ta ken from the Wheeling Airport collection center, is representative of all 12 months in 2009.

Page 29 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 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 NO x , All PM 2.5 categories, SO 2 , 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

Page 30

Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanE. 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 NO x (tpy) 735.22 574.29 249.11 131.14 PM 2.5 (tpy) 26.37 19.75 9.75 6.86 SO 2 (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 NO x (tpy) 1,229.69 1,103.54 486.29 270.94 PM 2.5 (tpy) 40.46 35.73 18.29 13.03 SO 2 (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 NO x (tpy) 1,964.90 1,677.83 735.40 402.08 PM 2.5 (tpy) 66.83 55.48 28.03 19.89 SO 2 (tpy) 24.86 8.40 6.21 5.84 Annual VMT 1,935,046 2,240,994 2,373,962 2,533,005

Page 31 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 23: Belmont County, OH Emissions Estimations for Onroad Mobile Sources 2005 2008 2015 2022 NO x (tpy) 3,179.52 2,593.58 1,279.25 587.61 PM 2.5 (tpy) 105.74 88.66 45.08 26.32 SO 2 (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 NO x (tpy) 5,144.42 4,271.41 2,014.65 989.70 PM 2.5 (tpy) 172.57 144.14 73.11 46.21 SO 2 (tpy) 55.70 17.78 12.92 12.05 Annual VMT 4,395,678 4,716,395 4,911,264 5,132,823

Page 32 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanThe following table shows the emissions totals, by sector, for eachcounty in the nonattainment area. For a more detailed analysis seeAppendix C.Table 25: Percentage of Wheeling, WV-OH Emissions Attributable to Mobile Sources in 2005, 2008, 2015 and 20222005 2008 2015 2022 2005 2008 2015 2022 2005 2008 2015 2022WheelingMarshallCo.,WV Point‐EGU 31,541 23,269 6,067 6,366 3,826 4,440 2,121 2,271 96,378 35,074 14,008 12,797MarshallCo.,WV Point‐NonEGU 3,131 2,759 2,341 2,166 525 410 316 272 19,110 16,503 13,692 12,285MarshallCo.,WV Area 184 81 84 86 316 263 258 259 102 64 62 60MarshallCo.,WV LM 671 249 250 252 25 8 8 9 31 13 13 13MarshallCo.,WV NonRoad 113 108 86 69 12 11 7 5 10 2 0 0MarshallCo.,WV OnRoad735 574 249 131 26 20 10 7 9 3 2 2MarshallCo.,WV Subtotal 36,375 27,040 9,077 9,070 4,731 5,152 2,721 2,824 115,641 51,658 27,777 25,158OhioCo.,WV Point‐EGU 0 0 0 0 0 0 0 0 0 0 0 0OhioCo.,WV Point‐NonEGU 6 6 6 6 11 4 4 4 1 1 1 1OhioCo.,WV Area 613 151 152 152 263 293 290 289 232 183 175 166OhioCo.,WV LM 972 0 0 0 38 0 0 0 44 0 0 0OhioCo.,WV NonRoad 170 158 113 87 21 19 15 11 15 3 0 0OhioCo.,WV OnRoad1,230 1,104 486 271 40 36 18 13 16 6 4 4OhioCo.,WV Subtotal 2,991 1,418 757 516 372 352 328 317 308 193 180 172Total 39,366 28,457 9,834 9,587 5,103 5,505 3,048 3,141 115,949 51,851 27,958 25,3294.99% 5.90% 7.48% 4.19% 1.31% 1.01% 0.92% 0.63% 0.02% 0.02% 0.02% 0.02%BelmontCo.BelmontCo.,OH Point‐EGU 4,150 4,168 4,478 4,738 94 70 21 0 37,330 15,126 8,783 6,065BelmontCo.,OH Point‐NonEGU 23 21 20 19 3 3 4 4 0 0 0 0BelmontCo.,OH Area 285 287 287 287 308 305 297 289 93 92 87 82BelmontCo.,OH MAR 262 247 161 79 6 6 3 1 23 16 7 3BelmontCo.,OH NonRoad 222 197 146 93 27 24 17 11 22 8 1 0BelmontCo.,OH OnRoad3,180 2,594 1,279 588 106 89 45 26 31 9 7 6BelmontCo.,OH Subtotal 8,121 7,513 6,370 5,804 545 497 388 332 37,499 15,252 8,886 6,15739.15% 34.52% 20.08% 10.12% 19.42% 17.85% 11.62% 7.93% 0.08% 0.06% 0.08% 0.10%OnroadSubtotal 5,144 4,271 2,015 990 173 144 73 46 56 18 13 12Total 47,487 35,971 16,204 15,390 5,648 6,001 3,436 3,472 153,448 67,103 36,843 31,48710.83% 11.87% 12.43% 6.43% 3.06% 2.40% 2.13% 1.33% 0.04% 0.03% 0.04% 0.04%NAA County SectorNOx PM2.5 SO2WVOnroadPercentageOHPortionOnraodPercentageWheeling,WV‐OHNAAOnroadPercentageWheeling,WV‐OHNAAWVPortionofNAAWheeling,WV‐OHNAAPage 33Wheeling, WV 1997 PM2.5Redesignation and Maintenance PlanOnroad mobile source SO 2 constitutes less than one tenth of one percent (<0.1%) of the area’s total SO 2 emissions in the 2015 and 2022 horizon years.

Onroad mobile source NO x constitutes less than twelve and a half percent (<12.5%) of the area’s total NO x emissions in the 2015 and 2022 horizon years.

Onroad mobile source PM 2.5 constitutes less than two and a ha lf percent (<2.5%) of the area’s total PM 2.5 emissions in the 2015 and 2022 horizon years. The federal Transportation Conformity rule a llows 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 requi red to satisfy a regional emissions analysis for §93.118 and/or §93.119 for a give n 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 moto r 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 here in making a finding that regional highway emissions of PM 2.5 , NO x and SO 2 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 em issions constitute a relatively small fraction (<10%) of the overall emissions in most cases, as shown in Table 25, above. The exception is NO x , which contributes 11.87% in 2008 and 12.43% in 2015. Previ ous guidance from U.S. EPA regarding PM 2.5 attainment demonstrations indicated that 10% is a benchmark for precursors and 5% is a benchmark for direct PM. Therefore, DEP believes th at the low contribution of both PM and SO 2 to the emissions inventory, in concert with the cons iderations detailed below, clearly warrants an insignificance finding with respect to tr ansportation conformity The larger NO x contribution requires more justification with respect to insignificance. 40CFR93.109(k) says that emissions should be review ed “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. Fu rther, the SEMAP atmospheric modeling for the Wheeling area shows that NO x reductions are significantly less effective in reducing PM concentrations than are reductions in SO 2 or direct PM. This difference varies by season, such that in summer it takes about 37 tons of NO x to equal one ton of PM. Annually, about 109 tons of NO x reductions are equivalent to a one ton reduction in PM. In winter, NO x reductions may actually cause a disbenefit because atmospheric chemistry creates more sulfates under reduced NO x conditions. Page 34 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanTherefore, in the context of transportation conformity, NO x is less important than PM or SO 2 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 i nventory. 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 NO x Emissions by Sector

Figure 7: Wheeling, WV-OH NAA PM 2.5 Emissions by Sector

Page 35 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanFigure 8: Wheeling, WV-OH NAA SO 2 Emissions by Sector

Second, the current air quality (CY 2011) is represented by a design value of 13.0 ug/m 3 . This value is significantly lower than the 15.1 ug/m 3 design value (2002-2004) upon which the nonattainment designation was based. Figure 2 on page 6 shows the general improvement of PM 2.5 concentrations from the year 2001 to date. The annual values dropped from 16.1 μ g/m 3 in 2001 to 15.6 and 15.4, in 2002 and 2003, respectively. This may be attributed to an overall decrease in sulfates from SO 2 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 y ear to year variability in PM 2.5 . 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/m 3 in 2008, 12.19 in 2009, 14.14 and 12.56 in 2010 and 2011, respectively. This may be attributed to SO 2 and NO x decreases reductions mandated by the NO x 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 PM 2.5 nonattainment area has attained the 1997 annual PM 2.5 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 highw ay emissions to the total SIP inventory, highway emissions are not likely to contribute significantly to the local PM 2.5 mass concentrations. Among other factors, this is largely due to the dominan ce of sulfates in the ove rall 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 Trans portation Conformity for the 8-hour ozone standard, with SIP-approved, seasonal budgets for NO x and Volatile Organic Compounds (VOC). Further, the entire nonattainment area is currently subject to Transportation Conformity for the PM 2.5 standard. Emissions analysis has been mandatory for a nnual highway emissions of direct PM and NO x . However, upon a positive adequacy review or appr oval of this SIP submittal, no highway emissions Page 36 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance Plananalysis will be required under the annual PM 2.5 standard. Highway analysis of seasonal ozone precursors would continue to be mandatory. And, PM 2.5 hot-spot analyses woul d continue to apply for required projects under 40CFR93.116 and 93.123(b) of the Transportation Conformity Rule. Fourth, Belomar has extensively re searched 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 PM 2.5 NAAQS violation. Belomar and ODOT have estimated emissions out, at least, to the calendar year 2035 confirming this, based on federally approved conformity determina tions. 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, wh ich are derived from the regional traffic model assignments that are made for each of those years. Pursuant to the Transportation Conformity interim tests, NO x and direct PM were evaluated. The anal ysis employed the MOVES emissions factor model. Despite monotonically increasing VMT, NOx emissions decrease dramatically from 4505.3 tons/year [2002] to 2691.8 t py [2009] to 1171.9 tpy [2018] to 810.4 tpy [2025]. The decrease continues to the last value to 665.7 tpy [2030], whic h is less than one-fourth of the 2009 level. DEP believes this result solidly demonstrates that hi ghway emissions will remain insignificant in the future. Finally, DAQ notes that ad equate safety margins (see Tabl e 17) exist to potentially set NO x motor vehicle emission budgets that are more than double the estimated emissions. Under that scenario, there would never be any potential diffi culty in demonstrating conformity but the MPO would still have to devote resources to developi ng emission estimates in meaningless effort that would provide no environmental benefit.

Figure 9: Onroad NO x Emissions Tons per Year Page 37 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanV. 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 Amendm ents 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 Amendm ents requires states with nonattainment areas to submit a SIP providing for implementation of all reasonably available control measures as expeditiously as practicable (including such reducti ons in emissions from existing sources in the area as may be obtained through the adoption, at a mini mum, of reasonable available control technology).

EPA’s PM 2.5 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 c ontribute 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 Vi rginia monitored attainment of the 1997 PM 2.5 NAAQS with a 3-year design value of 14.2 μg/m 3 for the 2006-2008 time period, and continued to monitor attainment with a design value of 13.4 μg/m 3 for the 2007-2009 time period and 13.1 μg/m 3 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 th e area’s obligations to submit an attainment demonstration, reasonable available control m easures (RACM), reasonable further progress, contingency measures and other planning requirements related to attainment for as long as the area continues to attain. EPA’s statutor y interpretation of the Clean Data Policy is described in the “Final Rule to Implemen t the 8-hour Ozone National Ambient Air Quality Standard—Phase 2" (Phase 2 Final Ru le). 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, Attainme nt Demonstration, and Related Requirements for Ozone Nonattainment Areas Meeting the Oz one National Ambient Ai r Quality Standard,” and our December 14, 2004 memorandum from Ste phen D. Page entitled “Clean Data Policy for the Fine Particle National Ambient Air Qua lity Standards” are equally pertinent to all Page 38 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanNAAQS. EPA has codified the Clean Data Po licy 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 st andard. 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 Po licy/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 th e Wheeling, WV-OH area had attained the 1997 PM 2.5 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 PM 2.5 nonattainment area has attained the 1997 annual PM 2.5 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 PM 2.5 Implementation Rule of April 5, 2007 [72FR20664]. Complete quality-assured PM 2.5 ambient air quality data for the most recent th ree (3) years, 2008 through 2010,and preliminary data for 2009 through 2011, demonstrate that the air qua lity continues to meet the NAAQS for annual PM 2.5 in this nonattainment area. Therefore, RACM, including RACT, no longer applies. B. Reasonable Further Progress Section 172(c)(2) of the 1990 CAA Amendments re quires attainment demonstration SIPs for nonattainment areas to show reasonable further progress (RFP). EPA’s Implementation Rule requires RFP only for a ny area which a State projects an attainment date beyond 2010. The RFP would provide emission reduc tions 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 th e Wheeling, WV-OH area had attained the 1997 PM 2.5 NAAQS for the three-year period, 2006-2008. On D ecember 2, 2011, in accord ance with Section 179(c)(1) of the CAA, EPA determined that the Wheeling, WV-OH PM 2.5 nonattainment area has attained the 1997 annual PM 2.5 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 PM 2.5 Implementation Rule of April 5, 2007 [72FR20664]. Complete quality-assured PM 2.5 ambient air quality data for the most recent th ree (3) years, 2008 through 2010,and preliminary data for 2009 through 2011, demonstrate that the air quality continues to meet the NAAQS for annual

Page 39 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanPM 2.5 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 comprehe nsive 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 y ears 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 inventorie s 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 here by 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 PM 2.5 SIP revisions have been fully implemented.

1. NO x SIP Call, CAIR and CSAPR The EPA NO x SIP Call required 22 states to pass rules that would result in significant emission reductions from large EGUs, industrial boilers, and cement kilns in the eastern United States. West Virginia passed this rule in 2002. NO x 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 enforcemen t program to address violations discovered by field office staff. Compliance is tracked thr ough the Clean Air Markets data monitoring program. In West Virginia, this rule accounted for a reduction from 2003 levels of approximately 57 percent of NO x 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 Distri ct of Columbia to significantly reduce emissions of NO x and SO 2 . CAIR replaced the NO x SIP Call for EGUs. National NO x emissions were expected to be cut from 4.5 million tons in 2004, to a cap of 1.5 m illion tons by 2009, and 1.3 million tons in 2018 in 28 states. States were require d to submit a CAIR SIP as part of this effort. West Virginia submitted an initial CAIR SI P on June 1, 2006. Subsequently, WV submitted an abbreviated CAIR SIP on June 8, 2007, which request ed authority to allocate CAIR allowances. Final revisions to the CAIR SIP were subm itted 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 th e CAIR program, the Transport Rule [75 FR 45210]. On July 6, 2011, EP A finalized the Transport Rule, now commonly referred to as the Page 40 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanCross-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 NO x and SO 2 emissions in 2012 and 2014, ahead of the 2015 CAIR Phase 2.

EPA states on their Cross-Stat e Air Pollution Rule homepage: “By 2014, power plants in states common to both the Cross-State Air Pollution Rule and CAIR will achieve annual SO 2 emissions around 1.8 million tons lower and annual NO x emissions around 76,000 t ons lower than what would have been achieved at that time under CAIR.” ( www.epa.gov/airtransport/basic.html )

Controls for EGUs under the NO x 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 NO x SIP Call Rule. West Virginia developed the NO x 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 NO x emissions from EGUs and a 60 percent reduction of NO x emissions from non-EGUs, compared to hist orical levels. This cap was in place through 2008, at which time the CAIR program s uperseded 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 NO x 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 NO x reduction from 1995 levels was anticipated. Approval of the comp liance 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 (S UVs). Under this propos al, 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 NO x emission reductions will be approximately 77 percent for passenger cars, 86 percent for smaller SUVs, light trucks, and minivans, and 65 to 95 percent reductions for larger SUVs, vans, and heavier trucks. The sulfur content of gasoline is estimated to be reduced by up to 90 percent. 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.

Page 41 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance Plan3. Heavy-Duty Diesel Engines [65FR59896, 06OCT2000] In October 2000, EPA published a final rule for Hi ghway 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 truc ks and buses. This rule resulted in a 40 percent reduction in NO x from diesel trucks and buses, a large sector of the mobile sources NO x inventory. It also estimated the level of sulfur in highway diesel fuel 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, ag riculture, and mining. It also contains a cleaner fuel standard similar to the highway diesel pr ogram. 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 NO x 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 engi ne horsepower, starting in 2008. Together, these rules will substantially reduce local and regional sources of PM 2.5 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 M odification of Major Stationary Sources of Air Pollution for the Prevention of Significant Deterior ation (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 SI P 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 allo wed to construct, reopen, modify, or reconstruct without meeting all applicable NSR requireme nts. 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 PM 2.5 , SO 2 , and NO x as required for maintenance of the annual PM 2.5 standard in the Wheeling Area, will be submitted to EPA for approval as a SIP revision. West Virginia, through the Division of Environmen tal Protection, DAQ, has the legal authority and necessary resources to actively enforce any viol ations of its rules or permit provisions. After redesignation, it intends to continue enforcing all rules that relate to the emission of PM 2.5 precursors in the Wheeling Area.

Page 42 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanVI. SUPPLEMENTAL MODELING ANALYSES Although EPA’s Redesignation Guid ance 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 PM 2.5 concentrations. These modeling analyses determined that the Wheeling, WV-OH ar ea is significantly impacted by regional transport of PM 2.5 and its precursors, and that regional SO 2 and NO x reductions are an effective way to attain the annual standards for PM 2.5 in this area. Future year modeled annual PM 2.5 concentrations are expected to be reduced by 8% to 34% from ba seline 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 reduc tions 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) versi on 5.3 applied to the 2005 meteorology as processed by the Mesoscale Model (MM5), Version 3.7.4. Em issions input into the CAMx included SO 2 , NO x , VOC, NH 3 and direct PM 2.5 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 PM 2.5 of 15 μg/m 3 , 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 Techni cal 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/m 3 (12.8%) decrease in the average PM 2.5 concentration for 2012 and a 2.44 μg/m 3 (16.1%) decrease in the average concentration for 2014, without accounting fo r CAIR or reductions required by the Transport Rule or CSAPR. A reduction of 5.12 μg/m 3 (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/m 3 in the area. Furthermore, the monitored design values for 2008-2010 and 2009-2011 of 13.1 and 13.0 μg/m 3 , 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 PM 2.5 monitors in West Virginia and Ohio.

Page 43 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 26: CSAPR Annual PM2.5Design Values (μg/m3)Site ID County 2003-2007AverageAmbientValue2003-2007MaximumAmbientValues2012 BaseCaseAverageValues2012 BaseCaseMaximumValues2014 BaseCaseAverageValues2014 BaseCaseMaximumValues2014RemedyAverageValues2014RemedyMaximumValues54-003-0003 Berkeley 15.93 16.19 14.09 14.32 13.70 13.92 11.81 11.9954-009-0005 Brooke 16.52 16.80 14.3314.58 13.84 14.09 11.34 11.5554-009-0011 Brooke 16.04 16.37 13.8714.15 13.39 13.66 10.89 11.1354-011-0006 Cabell 16.30 16.57 14.71 14.94 14.05 14.28 11.57 11.7554-029-1004 Hancock 15.76 16.64 13.73 14.51 13.28 14.03 10.81 11.4454-033-0003 Harrison 13.99 14.19 13.17 13.36 12.71 12.90 9.36 9.4954-039-0010 Kanawha 15.15 15.38 13.40 13.60 12.78 12.97 10.13 10.2854-039-0011 Kanawha 13.17 13.17 11.67 11.67 11.13 11.13 8.67 8.6754-039-1005 Kanawha 16.52 16.59 14.65 14.71 14.01 14.06 11.30 11.3554-049-0006 Marion 15.03 15.25 14.22 14.43 13.76 13.95 10.16 10.3054-051-1002 Marshall 15.19 15.33 13.25 13.38 12.75 12.87 10.07 10.1754-061-0003 Monongalia 14.35 14.47 12.89 13.01 12.41 12.53 9.28 9.4054-069-0010 Ohio 14.58 14.58 12.5312.53 12.05 12.05 9.51 9.5154-081-0002 Raleigh 12.90 13.03 11.22 11.33 10.70 10.80 8.39 8.4754-107-1002 Wood 15.40 15.44 13.7413.77 13.16 13.20 10.84 10.87Source: Air Quality Modeling Final Technical Support Document for the Final Cross-State Air Pollution Rule , pages B-61 - B-62.(www.epa.gov/airtransport/techinfo.html)Page 44Wheeling, WV 1997 PM2.5Redesignation and Maintenance PlanB. EPA Modeling for Proposed Transport Rule 2010 EPA performed modeling to support the emission reduc tions associated with the Proposed Transport Rule. EPA used the Comprehensive Air Quality M odel 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 SO 2 , NO x , VOC, NH 3 and direct PM 2.5 for 2005. The modeling was based on the annual fine particle design va lues 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 PM 2.5 of 15 μg/m 3 , 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/m 3 ) Future Design Value

2012 Base

(μg/m 3 ) Future Design Value

2014 Base

(μg/m 3 ) Future Design Value 2014 Remedy (μg/m 3 ) 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 im plementation of all federal rules promulgated by December 2008 and assumes that CAIR is not in effect.” [75FR 45233, 02AUG2010] Page 45 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanModeling results for the Wheeling area show a 1.23 μg/m 3 (8.1%) decrease in the PM 2.5 concentration for 2012 and a 1.75 μg/m 3 (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/m 3 (29.3%) from the 2003-2007 baseline is expected for 2014 with the impl ementation 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 curre nt 2009 through 2011 design value of 13.0 μg/m 3 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/m 3 , respectively, are less than the modeled base case design vales for 2012 and 2014. Figures 2 and 3 (in Section II) show the downwar d trend of the design values from 1999 through 2010 for the PM 2.5 monitors in West Virginia and Ohio. C. VISTAS/ASIP Emissions and Air Quality Modeling to Support PM 2.5 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 th e year 2002 meteorology, as processed by MM5. Emissions input into CMAQ included SO 2 , NO x , VOC, NH 3 and direct PM 2.5 for 2002. The modeling was based on 2000 through 2004 design values. Fu ture 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/m 3 (15.4%) decrease in the projected PM 2.5 concentration for 2009 from the 2002 desi gn value. As shown in Table 1, the actual monitored design value for 2007-2009 was 13.4 μg/m 3 , a 2.2 μg/m 3 (14.1%) improvement, slightly less than predicted. The modeling results show a continued improvement in the area, with a PM 2.5 concentration of 12.1 μg/m 3 by 2018, a 22.4% reduction from the 2002 design value. The current 2009-2011 design value for the area is 13.0 μg/m 3

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Page 46 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 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 S outheastern Integrated Planning (ASIP) Emissions and Air Quality Modeling to Support PM 2.5 and 8-Hour Ozone State Implementation Plans, March 24, 2008.

Page 47 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanD. 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 im plementation 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

Page 48 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanThe 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 PM 2.5 standard by 2010. Although this was one year later than the attainment year for the area, the EP A’s predicted 2010 CAIR DVF was 0.4 μg/m 3 higher than the DAQ monitored 3 year design value for 2010 of 13.1 μg/m 3 , but still supports that the area will continue to attain the annual PM 2.5 standard through 2015 with a projected design value of 12.9 μg/m 3 . The current 2009-2011 design value for the area is 13.0 μg/m 3

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Page 49 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanVII. CONTINGENCY MEASURES CAA Section 107(d)(3)(E)(v)

A. Maintenance Plan Review West Virginia hereby commits to review its ma intenance 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 PM 2.5 average of the weighted annual mean of 15.5 μg/m 3 occurs in a single calendar year within the maintenance area. A warning level response will consist of a study to determine whether the PM 2.5 value indicates a trend toward higher PM 2.5 values or whether emissions appear to be increasing. The study will evaluate whether the trend, if any, is likely to continue and, if so, the control measures necessary to reverse the trend taking into consideration ease and tim ing 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 selec tion and implementation outlined under “action level response” shall be followed. 2. Action Level Response An action level response shall be prompted whenev er a two-year average of the weighted annual means of 15.0 μg/m 3 or greater occurs within the maintena nce area. A violation of the standard (three-year average of the we ighted annual means of 15.0 μg/m 3 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 PM 2.5 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 fr om 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, signifi cant new regulations not currently included as part of the maintenance provisions will be implemented in a timely manner and will constitute our response.

Page 50 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance Plan3. Control Measure Selection and Implementation Adoption of any additional control measures is s ubject 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 determ ined 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 th e proposed measures are adequate to return the area to attainment. C. Potential Contingency Measures Contingency measures to be cons idered will be selected from a comprehensive list of measures deemed appropriate and effective at the time the se lection 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 appr opriate. West Virginia DAQ will solicit input from all interested and affected persons in the maintena nce 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 compre ssed natural gas) and diesel retrofit programs for fleet vehicle operations. 3) Tighter PM 2.5 , SO 2 , and NO x emissions offsets for new and modified major sources. 4) Concrete manufacturing - upgrade wet suppression. 5) Additional NO x 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. PM 2.5 , SO 2 , and NO x sources potentially subject to futu re additional control requirements. The following is a list of PM 2.5 , SO 2 , and NO x sources potentially subject to future controls.

• ICI Boilers - SO 2 and NO x controls; • EGUs; • process heaters; • internal combustion engines; • combustion turbines; • other sources greater than 100 tons per year; • Fleet vehicles; • Concrete manufacturers; • Aggregate processing plants.

Page 51 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanVIII. PUBLIC PARTICIPATION West Virginia published notification for a public hearing and solicitation for public comment concerning the draft redesignation petition and main tenance plan in the State Register and the Intelligencer, Wheeling News-Register on January 27, 2011. The public hearing to receive comments on the re designation request was held at 6:00 p.m. on February 28, 2012, at the West Virginia Division of Environmental Protection Headquarters located at 601 57 th Street, SE, Charleston, WV. There were no attendees at the pub lic 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.

Page 52 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance PlanIX. CONCLUSIONS The Wheeling PM 2.5 nonattainment area has attained the 1997 annual and 24-hour NAAQS for PM 2.5 and complied with the applicable provisions of the 1990 Amendments to the CAA regarding redesignations of PM 2.5 nonattainment areas. Documentation to th at effect is contained herein. West Virginia DAQ has prepared a redesignation request a nd 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 PM 2.5 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 SO 2 and NO x 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 PM 2.5 nonattainment area be redesignated to attainment simultaneously with EPA approval of the CAA section 175A maintenance plan provisions contained herein.

Page 53 Wheeling, WV 1997 PM 2.5 Redesignation and Maintenance Plan